EPA-450/3-80-020a
    Electric Arc  Furnaces
   in Ferrous Foundries —
Background  Information for
     Proposed  Standards
      Emission Standards and Engineering Division
      U.S. ENVIRONMENTAL PROTECTION AGENCY
         Office of Air, Noise, and Radiation
      Office of Air Quality Planning and Standards
      Research Triangle Park, North Carolina 27711
               May 1980

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This report has been reviewed by the Emission Standards and Engineering
Division of the Office of Air Quality Planning and Standards, EPA  and
approved for publication.  Mention of trade names or commercial products
is not intended to constitute endorsement or recommendation for use.  Copies
of this report are available through the Library Services Office (MD-35),
U.S. Environmental Protection Agency,  Research Triangle Park, N.C. 27711,
or from National Technical Information Services, 5285 Port Royal Road
Springfield, Virginia 22161.                                        '
                   Publication No. EPA-450/3-80-020a
                                  11

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                          Background Information
                                 and Draft
                      Environmental Impact Statement
                       for Electric Arc Furnaces in
                             Ferrous Foundries

                      Type of Action:  Administrative

                               Prepared by:
Don R. Goodwin
Director, Emissionl Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C.  27711
                               Approved by:
David G. Hawkins
Assistant Administrator for Air, Noise, and Radiation
Environmental Protection Agency
Washington, D. C.  20460

Draft Statement Submitted to  EPA's
Office of Federal Activities  for Review on
This document may be  reveiwed  at:

Central Docket Section
Room 2902, Waterside  Mall
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C.   20460

Additional copies may be obtained  at:

Environmental Protection Agency  Library  (MD-35)
Research Triangle Park, N.  C.  27711

National Technical  Information Service
5285 Port  Royal  Road
Springfield, Virginia  22161
 (Date)
                                                             Mw
 (Date!)
July 1980

 (Date)

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TABLE OF CONTENTS
List of Figures 	
List of Tables 	
CHAPTER 1
1.1
1.2
1.3
CHAPTER 2
2.1
2.2
2.3

2.4
2.5
2.6
2.7
CHAPTER 3

3.1
3.2
3.3
3.4
CHAPTER 4
4.1
4.2
4.3
SUMMARY 	
Regulatory Alternatives 	
Environmental Impact ....
Economic Impact 	
INTRODUCTION 	
Background and Authority for Standards . . .
Selection of Categories of Stationary Sources ....
Procedure for Development of Standards of
Performance 	
Consideration of Costs 	
Consideration of Environmental Impacts ....
Impact on Existing Sources 	
Revision of Standards of Performance ....
THE IRON AND STEEL FOUNDRY INDUSTRY PROCESSES AND
POLLUTANT EMISSIONS 	 	 . .
General 	
Iron and Steel Foundry Processes and Emissions . . .
Baseline Emissions 	
References for Chapter 3 	
EMISSION CONTROL TECHNIQUES 	
Introduction 	
Control of Charging Emissions 	
Control of Melting and Refining Emissions 	
V
vii
1-1
1-1
1-2
1-2
2-1
2-1
2-5

2-6
2-9
2-10
2-11
2-11

3-1
3-1
3-9
3-30
3-41
4-1
4-1
4-2
4-29

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TABLE OF CONTENTS (continued)
Section
4.4
4.5
4.6
4.7
CHAPTER 5

5.1
5.2

CHAPTER 6
6.1
6.2
6.3
6.4
CHAPTER 7
7.1
7.2
7.3
7.4
7.5
7.6
7.7
CHAPTER 8
8.1
8.2
Title
Control of Tapping Emissions 	
Exhaust Gas Cleaning Devices 	
Emission Source Test Data 	
References for Chapter 4 	 	
MODIFICATION AND RECONSTRUCTION OF IRON AND STEEL
FOUNDRIES 	 	
Provisions for Modification and Reconstruction ...
Applicability to Electric Arc Furnaces in the Iron
and Steel Foundry Industry ... . . . . 	 	
MODEL PLANTS AND REGULATORY ALTERNATIVES 	
Introduction 	 	
Model Plants 	
Regulatory Alternatives 	 	
References for Chapter 6 	 	
ENVIRONMENTAL IMPACT ..... 	
Air Pollution Impact 	 	 	 . ... . . .
Water Pollution Impact ...............
Solid Waste Disposal Impact .............
Energy Impact 	 .... 	
Other Environmental Impacts 	 	 	
Other Environmental Concerns 	 	 . .-.".. - • •
References for Chapter 7 	 	
ECONOMIC IMPACT 	 	 ." 	
Industry Characterization 	
Cost Analysis of Control Options 	 	 . . .
Page
4-37
4-42
4-47
4-54

5-1
5-2

5-3
6-1
6-1
6-1
6-4
6-8
7-1
7-1
7-13
7-24
7-28
7-28
7-28
7-30
8-1
8-1
8-15

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                        TABLE  OF  CONTENTS  (concluded)


Section     Title                                                      page

     8.3    Other  Cost  Considerations	      8-27

     8.4    Economic  Impact of Regulatory Alternatives   	      8-29

     8.5    Potential Socioeconomic  Impacts  	      8-44

     8.6    References  for Chapter 8	      8-47

APPENDIX A  EVOLUTION OF THE  BACKGROUND INFORMATION
            DOCUMENT	      A-l

APPENDIX B  INDEX  TO ENVIRONMENTAL IMPACT CONSIDERATIONS   ....      B-l

APPENDIX C  EMISSION TEST DATA FOR FABRIC FILTERS ON ELECTRIC
            ARC FURNACES AT IRON AND STEEL FOUNDRIES	      C-'l

     C.I    Emission Levels From Fabric Filters at Iron
            Electric Arc Furnaces 	      C-l

     C.2    Particulate Emission Levels From Fabric Filters
            at Steel Electric Arc Furnaces	      C-10

     C.3    Visible Emission Observations of Process Emissions
            at Steel Foundries	      C-l5

     C.4    Visible Emission Observations of Emission Capture
            Devices at Steel Foundries	     C-l7

     C.5    References for Appendix  C	     C-70

APPENDIX D  EMISSION MEASUREMENT AND CONTINUOUS MONITORING  ...     D-l

     D.I    Emission Measurement Methods  	     D-l

     D.2    Monitoring Systems and Devices  	     D-2

     D.3    Performance Test Methods	     D-3

     D.4    References for Appendix D	    D-4

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LIST OF FIGURES
Figure
Figure 3-1

Figure 3-2
Figure 4-1


Figure 4-2
Figure 4-3
Figure 4-4

Figure 4-5

Figure 4-6
Figure 4-7
Figure 4-8
Figure 4-9
Figure 4-10
Figure 4-11
Figure 4-12
Figure 4-13

Figure 4-14

Figure 4-15
Figure 4-16

Figure 4-17

Title
Iron and Steel Foundry Process Flow and Emission
Sources 	
Emissions From Electric Arc Furnace Operation . . .
Canopy Hood Using Building Roof as Part of
the Canopy, Combined with Direct Furnace
Evacuation 	 • • • •
Design Aspects of Building Evacuation System . . .
Schematic Diagram of Bay Evacuation System ....
Sketch of Furnace Enclosure Design at Lone Star
Steel Co 	 •
Krupp Furnace—Sequence of Events During
Charging . . . 	 	 	
Hawley Close Capture Hood 	 	 .
The Brusa Charging and Preheating System .....
Hooded Charge Bucket 	 ...
Marchand Design for Charging Emission Control . . .
Roof Hood 	 	
Side Draft Hood 	 	
Direct Evacuation Through Fourth Hole 	
ARMCo Incorporated Design for Tapping Pit
Enclosure 	
Proposed Ladle Car and Ladle Enclosure by
Marchand ........ 	 • • 	 •
Mobile Tapping Hoods 	 • •
Summary of Source Test Data for Baghouses on
EAF's Producing Iron 	
Summary of Source Test Data for Baghouses on
EAF's Producing Steel 	 	 	 	
Page
3-1 r\
-10
3-14


4-4
4-9
4-12
41 A
-14
41 f^
-19
4-21
4-26
4-27
4-28
4-30
4-33
4-35

4-38
4/1 r\
-40
4-41

4-49

4-51

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Figure

Figure 7-1

Figure C-l


Figure C-2
                        LIST OF FIGURES (concluded)
Title

Proposed Scrubber Wastewater Treatment Syst
em
Summary of Source Test Data for Baghouses on EAF's
Producing Iron	

Summary of Source Test Data for Baghouses on EAF's
Producing Steel 	
Page

7-23


C-2


C-11
                                   viii

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                              LIST OF TABLES
Table
Title
Paqe
Table 1-1      Matrix of Environmental and Economic Impacts
               for Regulatory Alternatives .... 	    1-3

Table 3-1      Range of Compositions for Typical Cast Irons  .  .  .    3-2

Table 3-2      End-Use Distribution of Castings	  .    3-3

Table 3-3      Summary of Foundries by State	    3-5

Table 3-4      Foundry Industry Data and Projections .  .  	    3-8

Table 3-5      Raw Materials Used for Iron and Steel
               Production	    3-11

Table 3-6      Chemical Analysis of Particulate Emissions from
               an Electric Arc Furnace	    3-26

Table 3-7      Composition of Dust Collected by Fabric Filters
               at an Iron Foundry	    3-27

Table 3-8      Particle Size Distribution for Particulate
               Emissions From Electric Arc Furnaces at Three
               Iron Foundries	    3-28

Table 3-9      Steel Electric Arc Furnace Dust Composition  ....    3-29

Table 3-10     Summary of Emission Factors for Iron- and Steel-
               Producing Electric Arc Furnaces 	    3-31

Table 3-11     Summary of State Air Pollution Regulations   ....    3-32

Table 3-12     Mass Emission Rates for Iron and Steel
               Foundries	    3-40

Table 4-1      Typical Exhaust Flow Rates and Emission Capture
               Efficiency of Charging and Tapping  Control Devices
               at Model Foundries	    4-7

Table 4-2      Design  Data  for Lone Star Steel Company Furnace
               Enclosure	    4-15

Table 4-3      Design  Data  for Certified Alloy  Products  Furnace
               Enclosure	    4-18

Table 4-4      Typical  Exhaust Flow Rates and  Emission Capture
               Efficiency of Melting  Control Systems	    4-32

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                         LIST OF TABLES  (continued)


Table          Title                                                  Page

Table 6-1      Model Plant Parameters - Common 	    6-2

Table 6-2      Model Plant Parameters - Specific 	    6-3

Table 6-3      Regulatory Alternatives  and Control System
               Options	    6-6

Table 7-1      Summary  of National Air  Pollution Impact  	    7-3

Table 7-2      Source Data for Dispersion Modeling	    7-5

Table 7-3      Highest  Second-High, 24-hour Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Oklahoma City, Oklahoma - Baseline)  	    7-8

Table 7-4      Highest  Second-High, 24-Hour Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Oklahoma City, Oklahoma - NSPS)  .  .  	    7-9

Table 7-5      Highest  Second-High, 24-hour Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Pittsburgh, Pennsylvania - Baseline) 	    7-10

Table 7-6      Highest  Second-High, 24-hour Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Pittsburgh, Pennsylvania - NSPS) 	    7-11

Table 7-7      Summary  of 24-hour Concentration Impacts From New
               Sources	    7-12

Table 7-8      Maximum  Annual Geometric Mean Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Oklahoma City, Oklahoma - Baseline)  	    7-14

Table 7-9      Maximum  Annual Geometric Mean Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Oklahoma City, Oklahoma - NSPS)  	    7-15

Table 7-10     Maximum  Annual Geometric Mean Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Pittsburgh, Pennsylvania - Baseline)  	  .  .    7-16

Table 7-11     Maximum  Annual Geometric Mean Particulate
               Concentration Impacts From Electric Arc Furnaces
               (Pittsburgh, Pennsylvania - NSPS) 	    7-17

Table 7-12     Summary  of Annual Geometric Mean Concentration
               Impacts  From New Sources	    7-18

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                        LIST OF TABLES (continued)
Table
Title
Page
Table 7-13

Table 7-14
Table 7-15
Table 7-16

Table 8-1
Table 8-2
Table 8-3

Table 8-4

Table 8-5
Table 8-6
Table 8-7
Table 8-8

Table 8-9

Table 8-10

Table 8-11

Table 8-12

Table 8-13

Table 8-14

Categories of Pollutants Which Might Be Found in
an EAF Scrubber System Effluent 	
Summary of Wet Scrubber Solids Collection 	
Summary of Solid Waste Generation 	
Trace Metallic Components of Baghouse Hopper
Dust 	 	 •
End-Use Distribution of Castings 	
Summary of Foundries by State 	
Ferrous Castings: Trends and Projections
1972-1983 	 	
Estimated Year-End Foundry Electric Arc Furnace
Capacity 	 	 	
Expansions in Electric Arc Furnace Facilities . . .
Model Plant Parameters - Common 	 	 -
Model Plant Parameters - Specific 	
Regulatory Alternatives and Control System
Options 	
Capital Cost Estimates for Regulatory
Alternatives 	 , . . . .
Annual i zed Cost Estimates for Regulatory
Alternatives 	
Marginal Cost Effectiveness of the Second
Alternative . . 	 	
Base Cost of Installing Electric Arc Furnaces
in Foundries 	
Derived Income Statement and Balance Sheet
Data for Baseline Model Plants 	
Profitability Impact Analysis for Iron Model
Plants Meetina Requirements of Second Alternative .

7-20
7-22
7-25

7-27
8-2
8-4

8-10

8-16
8-17
8-18
8-19

8-20

8-22

8-24

8-25

8-26

8-32

8-34

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LIST OF TABLES (continued)
Table
Table 8-15
Table 8-16
Table 8-17
Table A-l
Table B-l
Table C-l
Table C-2
Table C-3
Table C-4
Table C-5
Table C-6
Table C-7
Table C-8
Table C-9
Table C-10
Table C-ll
Title
Profitability Impact Analysis for Steel Model
Plants Meeting Requirements of Second Alternative .
Price Impact Analysis for Iron Model Plants
Meeting Requirements of Second Alternative ....
Price Impact Analysis for Steel Model Plants
Meeting Requirements of Second Alternative ....
Evolution of the Background Information
Document 	
Cross-indexed Reference System to Highlight
Environmental Impact Portions of the Document . . .
Summary of Visible Emission Data for EAF's
Producing Iron 	
Summary of Visible Emission Data for EAF's
Producing Steel 	
Summary of Parti cul ate Results: Facility A
(Baghouse Inlet) 	
Summary of Particulate Results: Facility A
(Baghouse Outlet) 	
Summary of Particulate Results: Facility B
(Baghouse Outlet) 	
Summary of Particulate Results: Facility C
(Baghouse Outlet) 	
Summary of Particulate Results: Facility D
(Baghouse Inlet) 	
Summary of Particulate Results: Facility D
(Baghouse Outlet) 	
Summary of Particulate Results: Facility E
(Baghouse Outlet) 	
Summary of Particulate Results: Facility F
(Baghouse Outlet) 	
Summary of Visible Emissions: Facility A 	
Page
8-36
8-42
8-43
A-l
B-2
C-3
C-16
C-18
C-19
C-20
C-21
C-22
C-23
C-24
C-25
C-26
            xii

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                        LIST OF TABLES (continued)
Table
Table C-12
Table C-13
Table C-14
Table C-15
Table C-16
Table C-17
Table C-18
Table C-19
Table C-20
Table C-21
Table C-22
Table C-23
Table C-24
Table C-25
Table C-26
Table C-27
Table  C-28
 Table  C-29
 Table  C-30
 Table C-31
 Table C-32
 Table C-33
 Table C-34
 Table C-35
Title
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
Summary
 Summary
 Summary
 Summary
 Summary
 Summary
 Summary
 Summary
 Summary
 Summary
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
of Visible
 of Visible
 of Visible
 of Visible
 of Visible
 of Visible
 of Visible
                                    Page
Emissions:   Facility A 	     C-28
Emissions:   Facility A 	     C-29
Emissions:   Facility A 	     C-30
Emissions:   Facility A 	     C-31
Emissions:   Facility A 	     C-32
Emissions:   Facility A 	     C-33
Emissions:   Facility A 	     C-34
Emissions:   Facility B 	     C-35
Emissions:   Facility B 	     C-36
Emissions:   Facility B .  .  . . .     C-37
Emissions:   Facility B 	     C-38
Emissions:   Facility B 	    C-39
Emissions:   Facility B 	    C-40
Emissions:  Facility C 	    C-41
Emissions:  Facility C 	    C-42
Emissions:  Facility C .....    C-43
Emissions:  Facility C  	    C-44
Emissions:  Facility C  	    C-45
Emissions:  Facility  C  	    C-46
 Emissions:   Facility  D  	    C-47
 Emissions:   Facility  D  .  .  .  .  .     C-48
 Emissions:   Facility  D  	     C-49
 Emissions:   Facility D  	     C-50
 Emissions:   Facility D  	     C-51
                                     xili

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                         LIST OF TABLES (concluded)
 Table          Title                                                  Page
 Table C-36     Summary of Visible Emissions:   Facility D 	     C-52
 Table C-37     Summary of Visible Emissions:   Facility D 	     C-53
 Table C-38     Summary of Gaseous Results:   Facility A 	     C-54
 Table C-39     Summary of Gaseous Results:   Facility B 	     C-55
 Table C-40     Summary of Gaseous Results:   Facility G 	     C-56
 Table C-41      Summary of Gaseous Results:   Facility D 	     C-57
 Table C-42     Summary of Particu1ate Results:   Steel
                Furnaces (United States)   	     C-58
 Table C-43     Summary of Visible Emissions:   Facility G 	     C-59
 Table C-44     Summary of Visible Emissions:   Facility G 	     C-60
 Table C-45      Summary of Visible Emissions:   Facility G 	     C-61
 Table C-46      Summary of Visible Emissions:   Facility G .....     C-62
 Table  C-47      Summary of Visible Emissions:   Facility G 	     O63
 Table  C-48      Summary of Visible Emissions:   Facility G .....     C-64
 Table  C-49      Summary of Visible Emissions:   Facility I  .....     C-65
 Table  C-50      Summary of Visible Emissions:   Facility I  	     C-66
 Table  C-51      Summary of Visible Emissions:   Facility I  	     C-67
Table  C-52      Summary of Visible Emissions;   Facility I  .....     C-68
Table  C-53      Summary of Tapping Pit Enclosure Emissions  ....     C-69
                                   xiv

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                               1.   SUMMARY
1.1  REGULATORY ALTERNATIVES
     Standards of performance for new stationary sources are developed
under Section 111 of the Clean Air Act (42 U.S.C.  7411) as amended.
Section 111 requires the establishment of standards of performance for
new stationary sources which "...  may contribute significantly to air
pollution which causes or contributes to the endangerment of public
health or welfare."  The Act requires standards of performance for such
sources to ". . . reflect the degree of emission limitation and the
percentage reduction achievable through application of the best
technological system of continuous emission reduction which (taking into
consideration the cost of achieving such emission reduction, any nonair
quality health and environmental impact, and energy requirements) the
Administrator determines has been adequately demonstrated."  The standards
apply only to stationary sources, the construction or modification of
which starts after regulations are proposed in the Federal Register.
     Two regulatory alternatives were selected for study.  The first
alternative would require no additional federal regulatory action.  Only
state and  local regulations would be applicable to new sources.  This
alternative  is considered to be the baseline condition from which the
impacts of the other alternative are calculated.  The second alternative
would require  Federal  regulatory action and would place a more stringent
limitation on  the allowable level of particulate and visible emissions
than that  allowed by the baseline condition.  The same emission capture
and control  systems could be used for the  second alternative as for the
first,  but better maintenance  of the entire system would be required.
                                    1-1

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1.2  ENVIRONMENTAL IMPACT
     Regulatory Alternative 2 would have a beneficial impact on air
quality.  The projected decrease in annual emissions in the fifth year
would be approximately 600 Mg/yr (675 tons/yr), a 50 percent reduction
below the emission level of the baseline condition.  There would be a
negligible adverse solid waste impact; the projected annual increase
above baseline in the fifth year would be approximately 600 Mg/yr
(675 tons/yr), a 15 percent increase.   There would be a negligible
adverse impact on energy and water and no impact on noise.   The impacts
associated with Regulatory Alternative 2 are summarized in Table 1-1.
1.3  ECONOMIC IMPACT
     Regulatory Alternative 2 would result in a worst-case product price
increase of approximately 0.3 percent, including monitoring costs.   There
would be no significant effect on the growth of the foundry industry or of
the electric arc furnace segment.
                                   1-2

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             TABLE 1-1.   MATRIX OF ENVIRONMENTAL AND ECONOMIC
                    IMPACTS FOR REGULATORY ALTERNATIVES


Administrative
action
Alternative 1
Alternative 2

Air
impact
0
+2**

Water
impact
0
_!**
Solid
waste
impact
0
_]**

Energy
impact
0
_]**

Noise
impact
0
0

Economic
impact
0
_1 **
Key:       + Beneficial impact.
          - Adverse impact.
          0 No impact.
          1 Negligible impact.
          2 Small impact.
  3 Moderate impact.
  4 Large impact.
  * Short-term impact.
 ** Long-term impact.
*** Irreversible impact.
                                    1-3

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                             2.   INTRODUCTION

2.1  BACKGROUND AND AUTHORITY FOR STANDARDS
     Before standards of performance are proposed as a Federal regulation,
air pollution control methods available to the affected industry and the
associated costs of installing and maintaining the control equipment are
examined in detail.  Various levels of control based on different technolo-
gies and degrees of efficiency are expressed as regulatory alternatives.
Each of these alternatives is studied by EPA as a prospective basis for a
standard.  The alternatives are investigated in terms of their impacts on
the economics and well-being of the industry, the impacts on the national
economy, and the impacts on the environment.  This document summarizes
the information obtained through these studies so that interested persons
will be able to see the information considered by EPA in the development
of the proposed standard.
     Standards of .performance for  new stationary sources are established
under Section 111  of the Clean Air Act (42  U.S.C. 7411) as amended,
hereinafter  referred to as the Act.  Section  111 directs the Administrator
to establish standards of performance for any category of new stationary
source of  air pollution which "... causes,  or contributes significantly
to, air  pollution  which may  reasonably be anticipated to  endanger public
health or  welfare."
     The Act requires  that  standards of  performance  for stationary  sources
reflect  "...  the degree of emission  reduction achievable which  (taking
into consideration the cost of  achieving such emission reduction,  and any
non-air  quality health and  environmental impacts,  and  energy  requirements)
the  Administrator  determines has  been  adequately  demonstrated for that
category of sources."   The  standards  apply only  to stationary sources,
                                    2-1

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 the construction or modification of which commences after regulations are
 proposed by publication in the Federal Register.
      The 1977 amendments to the Act altered or added numerous provisions
 that apply to the process of establishing standards of performance.
      1.   EPA is required to list the categories of major stationary
 sources  that have not already been listed and regulated under standards
 of performance.  Regulations must be promulgated for these new categories
 on the following schedule:
      a.   25 percent of the listed categories by August 7,  1980
      b.   75 percent of the listed categories by August 7,  1981
      c.   100 percent of the listed categories by August 7,  1982
 A governor of a State may apply to the Administrator to add a category
 which is not on the list or may apply to  the Administrator to have  a
 standard of performance revised.
      2.   EPA is required to review the standards  of performance every
 4 years  and,  if appropriate,  revise them.
      3.   EPA is authorized  to promulgate  a  standard based  on  design,
 equipment,  work practice, or  operational  procedures when a standard based
 on emission levels  is  not feasible.
      4.   The  term "standards  of performance"  is redefined,  and  a new
 term,  "technological  system of continuous emission  reduction,"  is defined.
 The new  definitions  clarify that the  control  system must be continuous
 and may  include a low-  or non-polluting process or  operation.
      5.   The  time between the  proposal and promulgation of  a  standard
 under  Section  111 of the Act  is  extended to 6 months.
     Standards  of performance,  by  themselves, do  not guarantee  protection
 of  health or welfare because they  are  not designed  to achieve any specific
 air  quality levels.   Rather, they  are  designed to reflect the degree of
 emission  limitation achievable through application  of the best adequately
 demonstrated technological  system  of continuous emission reduction,
taking into consideration the cost of achieving such emission reduction,
any  nonair quality health and environmental impacts, and energy
requirements.
     Congress had several reasons for including these requirements.
First, standards with a degree of uniformity are needed to avoid situations
                                   2-2

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where some States may attract industries by relaxing standards relative
to other States.  Second, stringent standards enhance the potential for
long-term growth.  Third, stringent standards may help achieve long-term
cost savings by avoiding the need for more expensive retrofitting when
pollution ceilings may be reduced in the future.  Fourth, certain types
of standards for coal-burning sources can adversely affect the coal market
by driving up the price of low-sulfur coal or effectively excluding
certain coals from the reserve base because their untreated pollution
potentials are  high.  Congress does not intend that new source performance
standards contribute to these problems.  Fifth, the standard-setting
process should  create incentives for improved technology.
     Promulgation of standards of performance does not prevent State or
local agencies  from adopting more stringent emission limitations for the
same sources.   States are free under Section 116 of the Act to establish
even more stringent emission limits than those  established under
Section 111  or  those necessary to attain or maintain the National  Ambient
Air Quality  Standards (NAAQS) under Section 110.  Thus,  new sources may
in some cases be subject to  limitations more stringent than standards  of
performance  under Section 111, and prospective  owners and operators of
new  sources  should  be aware  of this possibility in planning for  such
facilities.
     A  similar  situation may arise when a  major emitting facility  is  to
be constructed  in a geographic area that  falls  under  the prevention of
 significant deterioration of air quality  provisions  of  Part C of the  Act.
These  provisions require, among  other  things,  that  major emitting
 facilities  to be constructed in  such  areas are to  be  subject  to  best
 available control technology.  The term best available  control  technology
 (BACT), as  defined  in the  Act,  means
           ... an  emission limitation based on the maximum degree
           of reduction of each pollutant subject to regulation under
           this Act emitted from, or which results  from,  any major
           emitting facility, which the permitting authority,  on a
           case-by-case basis,  taking into account energy,
           environmental, and economic impacts and other costs,
           determines is achievable for such facility through
           application of production processes and available methods,
           systems,  and techniques, including fuel  cleaning or
                                    2-3

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           treatment or innovative fuel combustion techniques for
           control of each such pollutant.   In no event shall
           application of "best available control technology" result
           in emissions of any pollutants which will  exceed the
           emissions allowed by any applicable standard established
           pursuant to Sections 111 or 112 of this Act.
           (Section 169(3))
      Although standards of performance are normally  structured in terms
 of numerical emission limits where feasible,  alternative approaches are
 sometimes necessary.   In some cases physical  measurement of emissions
 from a new source may be impractical  or exorbitantly expensive.
 Section lll(h)  provides that the Administrator may promulgate  a  design  or
 equipment standard in those cases where it is not feasible to  prescribe
 or enforce a standard of performance.   For example,  emissions  of
 hydrocarbons from storage vessels for petroleum liquids  are greatest
 during tank filling.   The nature of the emissions, high  concentrations
 for short periods during filling and  low concentrations  for longer  periods
 during storage,  and the configuration of storage  tanks make direct  emission
 measurement impractical.   Therefore,  a more practical approach to standards
 of performance  for storage vessels  has  been equipment specification.
      In addition,  Section lll(i)  authorizes the Administrator to grant  :
 waivers of compliance  to  permit  a source to use innovative  continuous
 emission  control  technology.   In  order  to  grant the waiver,  the
 Administrator must find:   (1)  a  substantial likelihood that  the technology
 will produce greater emission  reductions than the standards  require or an
 equivalent reduction at  lower  economic  energy or environmental  cost;
 (2) the proposed  system has not been  adequately demonstrated; (3) the
 technology will not cause  or contribute to an unreasonable risk to the
 public health, welfare, or safety; (4)  the governor of the State where
 the source is located consents; and (5) the waiver will not prevent the
 attainment or maintenance of any ambient standard.  A waiver may have
 conditions attached to assure the source will  not prevent attainment of
any NAAQS.  Any such condition will have the force of a performance
standard.   Finally, waivers have definite end dates and may be  terminated
earlier if the conditions are not met or if the system fails to perform
                                   2-4

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as expected.   In such a case, the source may be given up to 3 years
to meet the standards with a mandatory progress schedule.
2.2  SELECTION OF CATEGORIES OF STATIONARY SOURCES
     Section 111 of the Act directs the Adminstrator to list categories
of stationary sources.  The Administrator "... shall include a category
of sources in such list if in his judgment it causes, or contributes
significantly to, air pollution which may reasonably be anticipated to
endanger public health or welfare."  Proposal and promulgation of standards
of performance are to follow.
     Since passage of the Clean Air Amendments  of 1970, considerable
attention has been given to  the development of  a system for  assigning
priorities to various source categories.  The approach  specifies areas of
interest by  considering the  broad  strategy of the Agency for implementing
the  Clean Air Act.   Often, these "areas"  are actually pollutants which
are  emitted  then  by  stationary  sources.   Source categories which emit
these  pollutants  were evaluated and  ranked  by  a process  involving  such
factors as:   (1)  the level  of  emission  control  (if  any)  already  required
 by state regulations; (2)  estimated  levels  of  control  that might be
 required from standards  of performance  for  the source category;
 (3)  projections of growth and replacement of existing facilities for the
 source category;  and (4)  the estimated incremental  amount of air pollution
 that could be prevented in a preselected future year by standards  of
 performance for the source category.   Sources for which new source
 performance standards were promulgated or under development during 1977,
 or earlier, were selected on these criteria.
      The Act amendments of  August 1977 establish specific criteria to be
 used  in determining priorities for all source  categories not yet listed
 by  EPA.  These are:  (1) the quantity of air pollutant emissions which
 each  such category will emit,  or will be designed  to emit;  (2) the extent
 to  which each  such  pollutant may  reasonably be anticipated  to endanger
 public health  or welfare; and  (3) the mobility and competitive  nature of
  each  such category  of sources  and the consequent need  for  nationally
  applicable  new source standards of  performance.
                                     2-5

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      The  Administrator is  to  promulgate  standards  for  these  categories
 according to  the  schedule  referred  to  earlier.
      In some  cases  it  may  not be  feasible  immediately  to  develop  a  standard
 for  a source  category  with a  high priority.   This  might happen when a
 program of research is needed to  develop control techniques  or because
 techniques for  sampling and measuring  emissions may  require  refinement.
 In the developing of standards, differences  in the time required  to
 complete  the  necessary investigation for different source categories must
 also be considered.  For example, substantially more time may be  necessary
 if numerous pollutants must be investigated  from a single source  category.
 Further,  even late  in  the  development  process the  schedule for completion
 of a standard may change.   For example,  inablility to  obtain emission
 data from well-controlled  sources in time  to  pursue the development
 process in a  systematic fashion may force  a  change in  scheduling.
 Nevertheless, priority ranking is, and will  continue to be,  used  to
 establish the order in which  projects  are  initiated and resources assigned.
      After the  source  category has been  chosen, the types of facilities
within the source category to  which the  standard will  apply must  be
 determined.   A  source  category may have  several facilities that cause air
pollution, and  emissions from  some of  these  facilities may vary from
 insignificant to  very  expensive to control.   Economic  studies of  the
 source category and of applicable control  technology may show that air
pollution control is better served by  applying standards to the more
severe pollution  sources.   For this reason, and because there is  no
adequately demonstrated  system for controlling emissions from certain
facilities, standards  often do not apply to all facilities at a source.
For the same  reasons,  the  standards may  not apply  to all air pollutants
emitted.   Thus,  although a source category may be  selected to be  covered
by a standard of  performance,   not all  pollutants or facilities within
that source category may be covered by the standards.
2.3  PROCEDURE  FOR  DEVELOPMENT OF STANDARDS OF PERFORMANCE
     Standards  of performance must (1)  realistically reflect best demon-
strated control  practice;  (2)   adequately consider the cost,  the nonair
quality health and environmental impacts, and the energy requirements of
                                   2-6

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such control; (3) be applicable to existing sources that are modified or
reconstructed as well as new installations; and (4) meet these conditions
for all variations of operating conditions being considered anywhere in
the country.
     The objective of a program for developing standards is to identify
the best technological system of continuous emission reduction which has
been adequately demonstrated.  The standard-setting process involves
three principal phases of activity:  (1) information gathering,
(2) analysis of the information, and (3) development of the standard of
performance.
     During the information-gathering phase, industries are queried'
through a telephone survey, letters of inquiry, and plant visits by EPA
representatives.  Information is also gathered from many other sources,
and a literature search is conducted.  From the knowledge acquired about
the industry, EPA selects certain plants at which emission tests are
conducted to provide reliable data that characterize the pollutant emissions
from well-controlled existing facilities.
     In the second phase of a project, the information about the industry
and the pollutants emitted is used in analytical studies.  Hypothetical
"model plants" are defined to provide a common basis for analysis.   The
model plant definitions, national pollutant emission data, and existing
State regulations governing emissions from the source category are then
used in establishing "regulatory alternatives."  These regulatory
alternatives are essentially different levels of emission control.
     EPA conducts studies to determine the impact of each regulatory
alternative on the economics of the  industry and on the national economy,
on the environment, and on energy consumption.  From several possibly
applicable alternatives, EPA selects the single most plausible regulatory
alternative as the basis for a standard of performance for the source
category under study.
     In the third phase of a project, the selected regulatory alternative
is translated  into a  standard of performance, which, in turn, is written
in the form of a Federal regulation.  The Federal regulation, when applied
to newly constructed  plants, will  limit emissions to the  levels indicated
in the selected regulatory alternative.
                                   2-7

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     As early as is practical in each standard-setting project,  EPA
representatives discuss the possibilities of a standard and the  form it
might take with members of the National Air Pollution Control  Techniques
Advisory Committee.  Industry representatives and other interested parties
also participate in these meetings.
     The information acquired in the project is summarized in the
Background Information Document (BID).  The BID, the standard, and a
preamble explaining the standard are widely circulated to the industry
being considered for control, environmental groups, other government
agencies, and offices within EPA.  Through this extensive review process,
the points of view of expert reviewers are taken into consideration as
changes are made to the documentation.
     A "proposal package"  is assembled and sent through the offices of
EPA Assistant Administrators for concurrence before the proposed standard
is officially endorsed by  the EPA  Administrator.  After being approved  by
the EPA Administrator, the preamble  and  the proposed  regulation are
published in the Federal Register.
     As a part  of  the  Federal Register announcement of the proposed
regulation, the public is  invited  to participate in the standard-setting
process.  EPA  invites written comments on  the  proposal and also holds a
public hearing  to  discuss  the proposed standard with  interested parties.
All public  comments  are  summarized and incorporated  into  a second  volume
of the BID.  All  information reviewed and  generated  in studies in  support
of the  standard of performance  is  available  to the public in  a "docket"
on file  in  Washington, D.C.
      Comments  from the public are  evaluated,  and the  standard of
performance may be altered in response to  the comments.
      The  significant comments and  EPA's  position on  the  issues  raised are
 included  in the "preamble" of a promulgation package, which  also  contains
 the  draft of the final  regulation.  The  regulation is then subjected  to
 another round of review and refinement until  it is approved  by  the EPA
 Administrator.   After the Administrator  signs the  regulation, it  is
 published as a "final rule" in  the Federal Register.
                                    2-8

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2.4  CONSIDERATION OF COSTS
     Section 317 of the Act requires an economic impact assessment with
respect to any standard of performance established under Section 111  of
the Act.   The assessment is required to contain an analysis of:  (1) the
costs of compliance with the regulation, including the extent to which
the cost of compliance varies depending on the effective date of the
regulation and the development of less expensive or more efficient methods
of compliance; (2) the potential inflationary or recessionary effects of
the regulation; (3) the effects the regulation might have on small business
with respect to competition; (4) the effects of the regulation on consumer
costs; and (5) the effects of the regulation on energy use.  Section 317
also requires that the economic impact assessment be as extensive as
practicable.
     The economic impact of a proposed standard upon an industry is
usually addressed both in absolute terms and by comparison with of the
control costs that would be incurred as a result of compliance with
typical, existing State control regulations.  An incremental approach  is
taken because both new and existing plants would be required to comply
with State regulations in the absence of a Federal standard of performance.
This approach requires a detailed analysis of the economic impact of the
cost differential that would exist between a proposed  standard of
performance  and the  typical State standard.
     Air  pollutant emissions may cause  water pollution problems,  and
captured  potential air pollutants may pose a solid waste  disposal  problem.
The  total  environmental  impact  of an emission  source must, therefore,  be
analyzed  and the  costs  determined whenever possible.
      A thorough study of the profitability and price-setting mechanisms
of the industry is  essential to the analysis  so that  an accurate  estimate
of potential adverse economic  impacts  can  be  made for  proposed  standards.
 It is  also essential to  know the capital  requirements  for pollution
 control  systems already placed on  plants  so  that the  additional  capital
 requirements necessitated by these  Federal  standards  can be  placed in
 proper perspective.   Finally,  it is necessary to assess the  availability
                                    2-9

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of capital to provide the additional control  equipment needed to meet the
standards of performance.
2.5  CONSIDERATION OF ENVIRONMENTAL IMPACTS
     Section 102(2)(C) of the National Environmental Policy Act (NEPA) of
1969 requires Federal agencies to prepare detailed environmental impact
statements on proposals for legislation and other major Federal actions
significantly affecting the quality of the human environment.  The
objective of NEPA is to build into the decisionmaking process of Federal
agencies a careful consideration of all environmental aspects of proposed
actions.
     In a number of  legal challenges to standards of performance for
various industries,  the United States Court of Appeals for the District of
Columbia Circuit has held that environmental impact statements need not
be prepared by the Agency for proposed actions under Section 111 of the
Clean Air Act.  Essentially, the Court of Appeals has determined that the
best system of emission  reduction requires the Administrator to take  into
account counterproductive environmental effects of  a proposed  standard  as
well as economic costs to the industry.  On this basis, therefore, the
Court established a  narrow  exemption  from NEPA for  EPA determination
under Section  111.
     In  addition to  these judicial  determinations,  the Energy  Supply  and
Environmental  Coordination  Act  (ESECA) of  1974  (PL-93-319)  specifically
exempted  proposed actions under the Clean Air Act from NEPA requirements.
According to  Section 7(c)(l), "No  action taken  under the  Clean Air Act
shall be  deemed  a major  Federal  action significantly affecting the quality
of the  human  environment within the meaning  of  the  National  Environmental
Policy  Act of 1969." (15 U.S.C.  793(c)(l))
      Nevertheless,  the Agency has  concluded  that the preparation of
environmental  impact statements could have beneficial  effects on certain
 regulatory actions.   Consequently,  although  not legally  required to  do so
 by Section 102(2)(C) of NEPA, EPA has adopted a policy requiring that
 environmental  impact statements be prepared for various  regulatory actions,
 including standards of performance developed under Section 111 of the
                                     '-in

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Act.   This voluntary preparation of environmental  impact statements,
however, in no way legally subjects the Agency to  NEPA requirements.
     To implement this policy, a separate section  is involved in this
document which is devoted solely to an analysis of the potential
environmental impacts associated with the proposed standards.   Both
adverse and beneficial impacts in such areas as air and water pollution,
increased solid waste disposal, and increased energy consumption are
discussed.
2.6  IMPACT ON EXISTING SOURCES
     Section 111 of the Act defines a new source as ". .  .  any stationary
source, the construction or modification of which  is commenced ..."
after the proposed standards are published.  An existing source is redefined
as a new source if "modified" or "reconstructed" as defined in amendments
to the general provisions of Subpart A of 40 CFR Part 60, which were
promulgated in the Federal Register on December 16, 1975 (40 FR 58416).
     Promulgation of a standard of performance requires States to establish
standards of performance for existing sources in the same industry under
Section lll(d) of the Act if the standard for new sources limits emissions
of a designated pollutant (i.e., a pollutant for which air quality criteria
have not been issued under Section 108 or which has not been listed as a
hazardous pollutant under Section 112).  If a State does not act, EPA
must establish such standards.  General provisions outlining procedures
for control of existing sources under Section lll(d) were promulgated on
November 17, 1975, as Subpart B of 40 CFR Part 60 (40 FR 53340).
2.7  REVISION OF STANDARDS OF PERFORMANCE
     Congress was aware that the level of air pollution control achievable
by any  industry may improve with technological advances.  Accordingly,
Section 111 of the Act provides that the Administrator ". . . shall,  at
least every 4 years, review and, if appropriate, revise ..." the standards.
Revisions are made to assure that the standards continue to reflect the
best systems that become available in the  future.   Such revisions will
not be  retroactive but will apply to stationary sources constructed or
modified  after the proposal of the revised standards.
                                   2-11

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                  3.   THE IRON AND STEEL FOUNDRY INDUSTRY
                    PROCESSES AND POLLUTANT EMISSIONS
3.1  GENERAL
     Iron and steel foundries, as considered in this document, can be
defined as those which produce gray, white, ductile, or malleable iron
and steel castings.  Cast iron and steels are both solid solutions of
iron, carbon, and various alloying materials.   Although there are many
types of each, the iron and steel families can be distinguished by their
carbon content.   Cast irons typically contain 2 percent carbon or
greater; cast steels usually contain less than 2 percent carbon.
Chemical specifications of various cast irons are presented in Table 3-1.
     The major industry users of castings [by Standard Industrial Classi-
fication (SIC)] are summarized in Table 3-2.   Iron castings are used in
almost all types of equipment, including motor vehicles, farm machinery,
construction machinery, petroleum industry equipment, electrical  motors,
and iron and steel industry equipment.   Steel  castings are classified on
the basis of their composition and heat treatment, which determine their
end use.  Steel casting classifications include carbon, low alloy, general
purpose structural, heat resistant, corrosion resistant, and wear resistant.
They are used, for example, in motor vehicles, railroad equipment, con-
struction machinery, aircraft, agricultural equipment, ore refining
machinery, and chemical manufacturing equipment.
     In 1978 there were 4,438 foundries of all types in the United States,
                        2
including the following:
               Number of Foundries
                   1,400
                     590
                     107
                     631
Metal Cast
Gray Iron
Ductile Iron
Malleable Iron
Steel
                                   3-1

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      TABLE 3-1.  RANGE OF COMPOSITIONS FOR TYPICAL CAST IRONS1

Element
Carbon
Silicon
Manganese
Sulfur
Phosphorus
Gray
iron, %a
2.
1.
0.
0.
0.
5 -
0 -
25 -
02 -
05 -
4.0
3.0
1.0
0.25
1.0
i
1.
0.
0.
0.
0.
White
ron, %a
8 -
5 -
25 -
06 -
06 -
3.6
1.9
0.80
0.20
0.18
Malleable iron
(cast white), %a
2.00
1.10
0.20
0.04
0.18
- 2.
- 1.
— 1
- 0.
60
60
00
18
maximum
Ductile
iron, %a
3.0
1.8
0.00
0.03
0.10
-4.0
- 2.8
-1.00
maximum
maximum
Percent by weight.
                                   3-2

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               TABLE 3-2.  END-USE DISTRIBUTION OF CASTINGS'
                         SIC .
                         codec
                         Industry
A.  Iron castings
B.  Steel castings
   3714
   3523
   3519
   3494
   3561,3
   3585
   3531
   3566
   3621
   3541

   3743
   3531
   3714
   3494
   3495
   3559
   3561,3
   3728
   3711
   3533
     Motor vehicle parts and accessories
     Farm machinery and equipment
     Internal  combustion engines, nee.
     Valves and pipe fittings
     Pumps and compressors
     Refrigeration and heating equipment
     Construction machinery
     Power transmission equipment
     Motors and generators
     Machine tools, metal  cutting types

     Railroad equipment
     Construction machinery
     Motor vehicle parts and accessories
     Valves and pipe fittings
     Wire springs
     Special industry machinery, nee.
     Pumps and compressors
     Aircraft equipment, nee.
     Motor vehicles and car bodies
     Oil  field machinery
 SIC = Standard Industrial Classification.
 .Ranked by production
 'nee. = not elsewhere
(highest 10
classified.
listed).
                                     3-3

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     Some of the' above foundries may cast other metals in addition to
iron or steel.  In 1978 there were 1,074 electric arc furnaces (EAF) in
operation in 440 foundries of all types (e.g., iron, steel, nonferrous)
in the United States.  Other types of melting equipment may be used in
addition to the electric arc furnace at a foundry, and a foundry may have
more than one electric arc furnace.
     Limited data on iron foundries indicate that there were 371 electric
arc furnaces in use at gray and ductile iron foundries in 1973.   Table 3-3
presents a summary of foundry data by State which indicates 396 electric
arc furnaces were operational in steel foundries in 1977-78.   Table 3-3
also contains data on the total number of foundries, number of EAF's, and
employment at steel foundries with EAF's.  The employment figures are
estimates and include all personnel working at the company or foundry.
     Larger furnaces, 9 to 14 megagrams per hour (Mg/h) [10 to 15 tons
per hour (tons/h)], are usually located in integrated machine-producing
plants; very few furnaces produce more than 14 Mg/h (15 tons/h).  Smaller
furnaces, down to a fraction of a ton per hour, are located in plants
that produce a limited variety of products or small quantities of
speciality iron castings.  Small furnaces are operated periodically;
large furnaces usually are operated in two shifts.
     Almost all facilities that produce steel castings are jobbing (i.e.,
produce castings for sale to, or use by, other facilities) foundries.
Very few arc furnaces that melt steel are part of integrated plants.
Smaller furnace operations are located in plants that produce a limited
variety of products or small quantitites of special steel castings.
Small steel foundries operate their arc furnaces periodically; larger
foundries usually are operated in two shifts.
     The iron and steel foundry industry shipped 16.83 million Mg
(18.55 million tons) of castings during 1978.  Shipments in 1979 were
projected to reach 17.7 million Mg (19.5 million tons).    It should be
noted that total plant capacity will exceed total shipments by up to
40 percent as a result of the production of foundry returns and defective
castings.  A summary of the production, employment, shipment value,  and
export and import values are presented in Table 3-4.  Production for 1979
was projected to increase 5.0 percent over 1978, and production for 1980
                                   3-4

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is projected to increase 3.5 percent over 1979.   Additional data for the
period 1973 through 1983 are given in Section 8.1.
3.2  IRON AND STEEL FOUNDRY PROCESSES AND EMISSIONS
3.2.1  General Operations
     All iron and steel foundries perform four basic operations:
     1.  storage and handling of raw materials;
     2.  melting of the raw materials;
     3.  transfer of the hot molten metal into molds; and
     4.  preparation of the molds to hold the molten metal.
     Other processes present in most, but not all, foundries include:
     1.  sand preparation and handling;
     2.  mold cooling and shakeout;
     3.  casting cleaning, heat treating, and finishing;
     4.  coremaking; and
     5.  pattern making.
     A simplified, schematic flow diagram encompassing most of these
processes for a typical iron or steel foundry is presented in Figure 3-1.
Each foundry process generates certain quantitites of gases, smoke, fume,
and/or particulate emissions.
     Castings are produced in a foundry by injecting or pouring molten
metal  into cavities of  a mold made of sand, metal, or ceramic material.
When the metal has solidified, the molds are separated and the castings
removed from the mold  flasks on a casting shakeout unit with subsequent
abrasive (shotblasting) cleaning, grinding, and  heat treating,  if  necessary.
The  castings  are then  inspected and  shipped to another industry for
machining  and/or assembly  into a  final product.
     The raw  materials  that may be  used  for iron or  steel  castings include:
metal!ics,  carbon  and  flux, fuel, refractories (furnace lining), and
molding materials, as  indicated  in  Table 3-5.  All types of  furnaces
which  produce iron or  steel may  use  similar raw  materials.   A foundry  may
operate a  "scrap  receiving station"  where the scrap  is stored and  classi-
fied according to  size, chemistry,  and/or density.   Oil content may  be
adjusted  in a "cleaning station," where  part  of  the  oil can  be  removed by
centrifuging or heating.   Foundries with induction furnaces  often  feature
another station,  the "preheater,"  to remove water and  oil  to preclude  the

                                    3-9

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      TABLE 3-5.   RAW MATERIALS USED FOR IRON AND STEEL PRODUCTION'
Metal!ics
    o   Pig iron
    o   Cast iron scrap
    o   Steel scrap
    o   Turnings and borings (loose or briquettes)
    o   Foundry returns
    o   Ferroalloys
    o   Innoculants, including magnesium alloys
Carbon additive
    o   Graphite
        Electrode scrap
        Calcined gilsonite
        Anthracite
        Coke breeze
        Silicon carbide
    o
    o
    o
    o
    o
Fluxes
    o
    o
    o
Fuel
    o
    o
    o
        Carbonates  (limestone, dolomite, soda ash)
        Fluorides (fluorspar)
        Carbides (calcium carbide)
         Coke
         Electricity
         Other  fossil  fuel
 Refractories
     o    Firebrick:   alumina,  silica,  magnesite,  graphite
 Mold preparation
     o    Sand
     o    Additives,  binders
                                   3-11

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possibility of an explosion hazard.  Electric arc furnaces could have
preheaters also, but this is seldom done because they are not as suscep-
tible to explosion.  Moderate preheating of EAF charges may be done by
holding the charge over the furnace.
     The charges are made up in proper sequence at the "charge makeup
stations."  The bucket receiving the charge is either placed on a weighing
platform or a scale is attached to the crane used to lift the scrap into
the bucket.  In this way, the bucket is charged with proper quantities of
materials and additives.  The charge is transferred to an electric furnace
and dropped into the furnace by opening the bottom of the bucket.  Cupolas,
on the other hand, are charged via a skip hoist with special buckets or
by other methods.  The charge in a furnace is heated until it reaches a
certain temperature and the proper chemistry of the melt has been verified.
The molten metal can either be poured out of the furnace into various
sized teeming ladles and then into the molds or transferred to holding
furnaces for later use.
     About 70 percent of all iron  is produced in the cupola with lesser
amounts produced in electric arc and induction furnaces.  Steel foundries
rely almost exclusively on electric arc or induction furnaces.  Other
types of furnaces may also be used  in either foundry type, but to a minor
extent.  Since the electric arc furnace is the designated affected facility
under investigation in this document, it is the only process that is
discussed  in the following sections.
3.2.2  Electric Arc Furnace Operations and Emissions
     The direct electric arc furnace is a refractory-lined, cylindrical
vessel made of heavy, welded steel  plates and having a bowl-shaped hearth
and a dome-shaped  roof.  Three graphite or carbon electrodes are mounted
on a superstructure above the furnace and can be lowered and raised
through holes in the furnace roof.  Water-cooled glands are provided at
the holes  to cool  the electrodes.   With the electrodes raised, the furnace
roof can be swung  aside  to permit  the charge materials to be dropped into
the furnace (top charged).  Additional alloying agents, as  required, are
added through the  side  or slag door of the furnace.  Top charging of
materials  is the most economical method because a furnace can  be charged
to the brim within a few minutes.   (Some smaller or  older furnaces are
                                    3-12

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charged through side doors.)  The furnace is usually mounted on curved
rocker trunnions.   Hydraulic cylinders or electromechanical means are
used for tilting the furnace.
     Foundries using electric arc furnaces as melters may consist of the
electric furnace itself, scrap storage area, scrap weighing stations,
molten metal and slag ladles, and hot metal holding furnaces.  Holding
furnaces are usually of the  induction type; arc furnaces are rarely used
for this purpose.   Heavy duty cranes are used to transfer the materials
from one point to another within the shop.  The scrap is charged by a
drop bottom bucket carried by the crane.
     The production of  iron  or steel in an electric arc furnace is a
batch process where cycles or "heats" range from 60 minutes to several
hours depending on the  size  of the charge, the power input to the furnace,
and the quality of the  metal melted.  Each cycle normally consists of
charging, melting (melt down of  the charge), refining, and tapping.  An
overall diagram outlining the emissions from electric arc  furnace
operations  is presented in  Figure 3-2.
     There  are circumstances that may delay the operation  of an electric
arc  furnace.   "Sheds"  (the  cutting off  of  the power  to the electrodes)
occur  frequently  and  might  not  be considered unusual operating delays.
Delays  that might be  considered unusual,  however,  are:   lack of  room in
the  holding furnaces  or on  the  molding  floor, thus delaying  the  tapping
of the electric  furnace;  failure of  the crane to  arrive  on time;  failure
of the electrode  lifting  mechanism;  improper arcing of  electrodes;  loss
 of plant power;  and an inoperative  furnace roof which  cannot be  opened or
 closed.
      Electric arc furnaces  for iron foundries  and steel  foundries are
 very similar.7   At foundries which pour both  iron and steel,  both metals
 can be produced in the same furnace.   Steel production at times  requires
 an oxygen lance to dislodge scrap which adheres to furnace walls, to
 adjust the furnace chemistry, or to increase the melt rate.   Steel furnaces
 may also be backcharged with additional scrap of low density during the
 melt period.  Oxygen lancing and backcharging temporarily increase parti-
 culate emission rates  from  steel furnaces.  Iron production does not
 ordinarily require the use  of these operations, although backcharging may
                                    3-13

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PARTICULATE
 HC VAPORS
     CO
    SOOT
 METAL FUME
PARTICULATE
 HC VAPORS
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   SOOT
 METAL FUME
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    CO
  CHARGING
MELTING AND
  REFINING
                                                              TAPPING
  Figure 3-2.  Emissions  from electric-arc furnace operation.
                               3-14

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be performed.   The,chemical composition of the emissions from iron and
steel production is similar, although there is some variation in the
relative amounts of the metal oxides emitted.
     There are some differences in the design and operation of furnaces
used in iron and steel foundries.   While the refractory lining for furnaces
used in the production of iron is usually acidic, furnaces for steel
castings can have either basic or acidic refractory, depending on the
desired steel  composition and the availability of charging materials.
Acid-refractory-lined furnaces are used for the production of plain and
alloyed steels.  Acid furnaces have silica brick walls and supporting
brickwork, while the hearth is covered with quartzite.  Basic furnaces
are used also for melting plain and alloyed steels.  In basic furnaces>
the bottom is made of two or three layers of magnesite brick over which a
layer of magnesite or dolomite 150 to 200 mm (5.9 to 7.9 in.) thick is
rammed into place.
     3.2.2.1  Charging.  Iron or steel scrap is usually loaded into the
charge bucket with an electromagnet suspended from a crane.  The bucket
stands on a scale or a scale car in the scrap makeup area.  The weight of
the materials in the bucket is displayed electronically or on a dial that
is clearly visible to the crane operator.
     The charge to an electric arc furnace producing iron consists of
steel scrap, foundry returns, and additives such as carbon raiser, manga-
nese, and silicon.  Foundry returns include sprues, gates, runners,
risers, defective castings, and borings from machining operations.
Carbon raiser is carbon in the form of graphite or coke breeze and is
used to increase the carbon content of iron.  Loose charge, such as
turnings and borings, in excess of 20 percent is normally avoided because
it increases the power consumption, electrode consumption, and melting
time.  The material charged to an electric arc furnace in a gray iron
                                                ft—1 fl
foundry typically has the following composition:
     1.  50 to 60 percent iron (approximately 80 percent foundry returns and
20 percent cast iron turnings or borings);
     2.  37 to 45 percent steel (approximately 70 to 100 percent steel pieces
and less than 30 percent steel turnings);
                                  3-15

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     3.   0.5 to 1.1 percent silicon (usually as ferro silicon);
     4.   1.3 to 1.7 percent carbon raiser; and
     5.   0.2 percent ferro manganese (FeMn).
     The charge for steel production differs from the above in that the
foundry returns are mostly steel and little carbon raiser is added.  The
carbon raiser is added in very small amounts and may be in the form of
pig iron.   The carbon level for steel production is 83 to 87 percent
lower than the level for iron product!oh.   The charge to a basic furnace
can consist of 20 to 50 percent foundry returns and 50 to 80 percent
steel scrap and additives.  Basic furnace charges may contain variouis
kinds of materials with high levels of phosphorus and sulfur.  The charge
to an acid furnace must contain very small amounts of sulfur and phosphorus
because these elements cannot be removed by acid-lined furnaces.
     The charge is introduced into the furnace by the charging bucket.
This manner of charging the furnace produces emissions which are not
controlled in most of the existing plants.  Emissions result from:
(1) vaporization and partial combustion of the oil introduced with any
scrap, borings, turnings, and chips which are contained in the charge;
(2) oxidation of organic matter which may adhere to the scrap; and
(3) liberation of  sand particles which are  introduced into the furnace on
the surface of casting returns.  High oil content is characteristic of
the least expensive scrap, e.g., swarf (turnings, chips, and borings)
from machine operations.  Charging emissions are essentially made  up of
particulate matter, carbon monoxide, hydrocarbon vapors, and soot.
     Proper size selection and  distribution of the scrap during charging
(and backcharging)  is important.  During  its transfer into the furnace,
the scrap should be distributed in a way  that does not damage the  furnace
refractory.  In the case of scrap pieces  remaining above the parting  line
(bezel ring), the  pieces must be relocated  so that the roof will close.
This relocation may be done using the charge bucket, or some other large
mass of metal suspended  from the crane,  to  tamp the charge into the
furnace.  It may also be  performed by the  use of an oxygen  lance.   The
oxygen burns off the connection to the wall or cuts the pieces apart  if
they are  off the walls.  These  operations are carried out with the slag
door open.  Charging of  additives,  such  as  lime and coke,  is performed
                                   3-16

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through the slag door or when the roof is swung.   Both operations result
in emissions into the furnace bay area.   After charging is completed, the
roof is rotated back into position and lowered onto the furnace.   A very
small gap may remain between the roof and the bezel ring of the furnace.
     3.2.2.2  Melting and Refining.   Arc furnace transformers are designed
for connection to a high voltage supply.  The main items of electrical
equipment are a circuit breaker, a step-down transformer, and, for small
transformers, a tapped reactor to give arc stability and to dampen current
surges.  The transformer is provided with tap changing equipment to give
a range of secondary voltages to suit the melting, superheating, and
refining conditions in the furnace.   The electrodes are raised or lowered
by electromechanical or electrohydraulic devices.  At a given transformer
voltage, lowering the electrodes shortens the arc and increases the
current and power input and vice versa.   Electrode movement is accomplished
by automatic control in normal operation.
     The step-down transformer decreases voltage from 2.3-35  kilovolts to
80-375 volts.  The voltage varies with the primary line voltage available
and the size of the furnace transformer.  The transformer may have from 3
to 33 taps on the high voltage side for better control of electric supply
and  heat conditions of the furnace.  The power is first passed through
the  high voltage transformer, then through a selected tap among the
number of  taps off of the primary coil  of the transformer.  The voltage
levels applied to the furnace are governed by the  size of the furnace,
phase  of the furnace cycle, metal temperature, and other factors.
     When  the furnace is ready  for the  melting cycle, the electrodes  are
positioned manually just above  the scrap charge.   The electrodes then may
be  energized and put on  automatic operation.  As  the electrodes  lower,
one  will reach  the  scrap first.  With some controls, this electrode  will
rise instantly  at the slightest electrical contact with  the  scrap  to
break the  contact as though  anticipating the current  surge which occurs
when the second electrode  gets  close  to the  scrap.   In  a few seconds, the
phases should  be  balanced  and the  furnace  is  "in business."   If  short
arcs occur, the electrodes may not melt enough  metal  to  avoid damage to
the refractory on  the  bottom of the  furnace.  With long arcs, the
 electrodes will  melt out larger holes in the scrap charge.   Heat radiated
                                   3-17

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from the long arcs and reflected from the pool surface goes up into the
cold scrap surrounding the electrodes.  Thus the charge is preheated and
melted down faster into the molten bath.
     When the charge is melted down, the long arcs, if not shortened,
would overheat the sidewall and roof refractories before the molten metal
got hot.  Oxygen is now used almost universally (instead of iron ore or
mill scale) for "boiling" a heat of steel to flush out gases, mainly
hydrogen.  Oxygen may increase the metal temperature without the arcs
because the carbon boil reaction is exothermic.   If further arcing is
needed to increase the metal temperature but the refractories are already
too hot, then the arcs may be shortened by simply increasing the arc
current (if the circuits can handle a higher current) or by changing to a
lower voltage tap.   When the metal is up to temperature, further reductions
in the arc length may be made by switching to still lower taps as the
practice requires.
     Melting is accomplished by the heat supplied by direct radiation
from the arcs formed between the electrodes of the furnace and the metallic
charge, by direct radiation from the furnace lining, and by the resistance
of the metal between the arc paths.  Melting begins by striking an arc
between the electrodes often using the highest voltage tap in the trans-
former.  As the electrodes bore into the solid charge, much fume and
noise result.  After the charge is melted, the molten bath surface becomes
completely flat (i.e., with no incompletely melted pieces floating in the
molten material).   The bath temperature is about 1370°C (2500°F) but may
vary considerably,  depending on the type of metal melted.   During the
next period, the furnace is fed from another tap while the bath is super-
heated.  In some foundries, a sample is then taken for chemical analysis
prior to pouring.
     When the desired temperature is reached, the molten bath is usually
skimmed to remove the slag.  Slagging, which is  usually performed with
the power off, is normally carried out once per  heat.   The furnace is
tilted 10 to 15 degrees from the vertical.   Sand may be thrown on the
threshold of the slagging door to prevent the slag from sticking; the
slag is then manually withdrawn with slag rakes  into a slag pit, bucket,
or ladle.
                                  3-18

-------
     After slagging is complete, the power is restored at a lower tap for
15 to 30 minutes to superheat and refine the melt.   During this time, the
furnace chemistry and bath temperature are checked and adjusted if necessary.
These two operations last only a few minutes.  As soon as the proper
chemistry and metallurgy are reached, the furnace is prepared for tapping.
In some cases, refining may be performed in the ladle or in a holding
furnace.
     Steel melting in acid or basic EAF's can be carried out either with
oxidation (oxidizing the impurities with iron ore or oxygen) or without
oxidation (fusion of steel scrap).     The choice of a method depends on
the type of steel produced, the charge materials available, and, in
particular, the amounts of sulfur and phosphorus in the charge.
     Oxidation is not used if the metal ingredients of the charge are
close to those desired because oxidation would remove some of the valuable
alloying elements.  In such cases,  only a reducing slag is used, both in
melting and refining.  Usually, this process (single refining or single
slag practice) is employed to smelt alloy wastes to alloy steels.  During
melting with oxidation, also known as double slag working, the charge is
melted under an oxidizing (black) slag.  Then this slag is removed and a
reducing or white slag is formed under which refinement is completed.
This method may be used to remove gases (hydrogen, nitrogen) from the
plain carbon steels.
     The oxidizing slag is formed by the addition of lime and  iron ore
(or oxygen) to the furnace before the charge is molten.  Oxygen  is used
more frequently than  iron ore.  Oxidizing treatment under a basic slag
removes most of the phosphorus  and carbon from the melt, lowering their
concentrations to the desired levels.  The purposes of reducing  slag are:
(1) to  deoxidize the  metal;  (2) to eliminate the sulfur; and (3) to
finish  the  steel to  the specified composition.  The reducing slag is
formed  from lime, fluorspar, and coke  breeze.  The deoxidation of the
metal  results  from  the  reaction of dissolved oxygen in the metallic
solution  with  carbon  and  ferrosilicon  or  aluminum, both  very effective
deoxidizing additives.  Nonmetallic  inclusions,  such  as  sulfur,  are
removed from the  metal  into  the slag in  the  form of calcium  sulfide.
                                    3-19

-------
      Steel casting furnaces are sometimes backcharged (i.e.,  a second
 charge is added to the furnace) as soon as sufficient volume  is available
 in the furnace after the first charge.   Normally,  the furnace at an iron
 foundry is charged only once with the full charge, and backcharging is
 usually not practiced.   If the carbon level  is too high,  however,  some
 steel  can be added through the slag door—preferably clean, dry pieces
 that will drop to the bottom of the molten iron bath.
      Oxygen lancing in steel furnaces is used mainly for  adjustment of
 the chemistry of the steel,  for speeding up  of the melting process,  and
 for superheating of the bath.   Oxygen lancing results  in  increased bath
 and gas temperatures,  gas  evolution,  and generation of particulates.
 Oxygen lancing can be carried out with  moderate rates  of  oxygen addition,
 thereby avoiding excessive generation of high temperatures, gas evolution,
 and particulates.   However,  extended  periods  of oxygen lancing can increase
 refractory wear and oxidation of the  bath and decrease the production
 rate.
     Other occurrences  during melting that may result  in  emissions  are
 the sudden collapse of  pieces  of the  charge and the necessity  to push
 pieces  under the electrodes.   (Pushing  pieces  under the electrodes  is
 performed with  the power off.)   In  such instances,  the door (usually the
 slag door)  must be opened, which results  in emissions  escaping  through
 the electrode  holes.  Emissions  of  this kind  are highly visible within
 the shop  and may reach  the roof  openings  and  escape  into the atmosphere.
 These emissions  are more pronounced in  furnaces with direct furnace
 evacuation  than  in furnaces  with side draft hood evacuation.
     During  the  production of some alloys, as  already mentioned, a second
 slagging  operation  may  take  place, depending on the melting practice
 utilized.  The  addition of reducing slag must  be carried out with a
minimum amount  of  air since  induction of air into the furnace  will oxidize
the  reducing slag,  rendering it  ineffective.   An inflow of air will also
cool the  slag and  bath, slowing  the chemical  reactions between the two
substances.  If  direct  shell evacuation is used, it may be necessary to
adjust the air flow.  Some melters stop the flow of air completely by
shutting down the  fan; others reduce the flow of air to a much lower
       12 13
volume.   '    These techniques have two disadvantages.   Turning off the
                                  6-z

-------
                                     14
fan or operating the fan at a lower volume can result in the escape of
emissions through the electrode holes into the furnace bay area.   Second,
the industry advances a theory that the configuration of the furnace roof
which is required to accommodate the direct shell evacuation system may
produce a cold spot in the molten steel when the flow of air is reduced.
It is alleged that the absence of refractory where the discharge duct
enters the roof acts as a black body surface which absorbs radiant heat
from the melt, thus creating the cold spot.
     As another method of adjusting the chemistry of the molten metal,
some foundries practice reladling (refurnacing).  This procedure involves
tapping one-third to one-half of the molten metal into the ladle and then
pouring this tap back into the furnace.  The molten metal is thus forced
to mix with the slag, enhancing sulfur removal.  Reladling may also be
performed to preheat the ladle.
     During melting operations (meltdown, slagging, and refining), emissions
consist of:  (1) particulates as metallic and nonmetallic oxides generated
from vaporization of iron and transformation of mineral additives;
(2) carbon monoxide from combustion of the graphite electrodes, carbon
raisers and carbon in the metal; and (3) hydrocarbons from vaporization
and partial combustion of oil remaining in the charge.
     During melting, emissions escape  from the furnace through electrode
annuli  (holes), the slag doors, the roof ring (the joint between the
furnace shell and roof), and sometimes the tap spout.    Proper main-
tenance of the furnace will minimize the escape  of emissions through
these openings and improve the efficiency  of emission evacuation systems
used for control of melting emissions.
     Backcharging produces a violent eruption of particulate emissions
with a  strong thermal driving  force.   The  amount of pollutants generated
during  this phase of the operation  is  probably  higher than during either
the  first  charge or  during treatment of the molten bath  in the transfer
ladle.15
     3.2.2.3  Tapping.  When the proper chemistry, temperature, and
metallurgy of the melt  are reached,  the melt  is  tapped.  The tapping
temperatures  are  determined  by the  type of alloy being  cast, the  section
thickness  and size  of  the  castings  being  poured, as well as other pertinent
3-21

-------
 factors which affect the castability of the parts being produced.   These
 temperatures may be on the order of 1500°-1600°C (2730°-2910°F) for iron
 and 1600°-1815°C (2910°-3300°F) for steel, depending on the type.   The
 electrodes are raised, the furnace is tilted by as much as 45 degrees,
 and the refined metal flows into a ladle.   The melt is then poured into
 molds or temporarily stored in the molten  State in holding furnaces.
 During tapping, sparks and emissions consisting of molten iron or  steel
 fume are generated and become a source of  ferrous oxide particulate
 emissions.    Tapping of iron generally produces considerably fewer
 emissions than the charging of the furnace.   However,  when alloys  are
 added to the ladle,  tapping emissions are  somewhat greater than charging
 emissions and considerably greater than emissions from tapping of  unalloyed
 iron.   The higher emission rates from the  tapping of steel  furnaces are
 due to the higher temperature required for steel  production and the fact
 that generally more  alloys are added to steel  than to  iron.   Tapping
 emissions are often  unconfined and escape  as  fugitive  emissions through
 foundry roof vents.
      3.2.2.4  Material  Balances.   The metal yield of an  electric arc
 furnace is  rather high.   From a typical  charge  in the  gray  iron foundry
 industry,  94 to 98 percent gray iron is  produced.   In  addition,
 0.65  to 0.75 percent  of the iron in  the  charge  escapes as dust, and the
 remainder is lost in  the slag.   In steel foundries,  a  typical  charge may
 produce 92  to 93  percent molten steel.   Similarly,  0.65  to  0.75 percent
 of  the  iron  escapes as  dust,  and 6 to  7  percent is  lost  in  the  slag.
 Basic  furnaces  are generally  less  efficient than  acid  furnaces  because
 several  slags may sometimes be  required.
     Electrode  consumption  is 3.6  to 4.5 kilograms  per megagram (kg/Mg)
 [7.2 to 8.9  pounds per  ton  (lb/ton)] of metal melted for acid  furnaces
with a  slightly higher  consumption for basic furnaces.   Many factors
contribute to electrode  consumption; a systematic study of the complex
interactions  involved has not been published.   Electrode consumption is a
source of hydrocarbon,  carbon monoxide, and carbon dioxide emissions.
     3.2.2.5  Energy Considerations.  Only electrical energy is used in
electric arc furnace operations, unless some preheating of the charge or
ladle is carried out.   The largest portion  of energy is consumed for

-------
melting and refining of the charge, but some energy is used for the
operation of pumps, cranes, building evacuation equipment, and air pollution
control equipment.
     Between 1,620 and 2,475 megajoules per megagram (MJ/Mg) [410 and
625 kilowatt-hours per ton (kWh/ton)] of energy are consumed by the
furnace, depending on the quantity of borings added to the charge, the
type of operation (acidic or basic), the final temperature, and the
quality of the metal produced.   The lower figure corresponds to a quantity
of borings representing about 10 percent of the charge makeup; the higher
figure refers to a charge with well over 50 percent uncompressed borings.
     The power rating (kilovolt-ampere, kVA) increases with the size of
furnace.  The refractory wear becomes excessive with high power levels.
This is proven in practice and confirmed by theories developed by W. E.
Schwabe (i.e., the so-called "refractory wear index").
     Energy can also be expended in a pretreating process, such as
centrifuging out excessive oil  from borings, or by drying and/or preheating
the scrap.  It is desirable to have as little oil in the scrap as possible.
Borings are a special problem because their large surface can contain a
significant amount of oil.  Borings can be centrifuged to reduce their
oil content to about 2 percent by weight.
     If the charge is preheated to drive out superficial water, it is
heated to 93°C (200°F).  (Energy spent for this purpose does not improve
the operating efficiency of the furnace.)  If the drying process is
carried out at 202° to 232°C (395° to 450°F), not only will the water be
driven out but also some oil (which adheres to the scrap) will be
volatilized and partially combusted.  Scrap preheated to the above
temperature saves about 140 MJ/Mg  (35 kWh/ton) of metal produced.  With a
preheat of 650°C (1200°F), known as "full preheating," energy consumption
is theoretically reduced by about  495 MJ/Mg (125 kWh/ton).17  Preheating
is primarily used on charges for induction furnaces and is seldom used on
charges for EAF's.  The degree of  preheat is a function of several factors,
including the type and condition of the  scrap.
     Full preheating burns off the oil and some  other contaminants so
that substantially  fewer emissions are generated during charging and less
slag is formed, which  helps protect the  lining of the furnace.  Preheating,
                                    3-23

-------
therefore, results not only in energy savings but also in air pollution
reduction at the furnace plus extended life of the furnace lining.  The
preheater itself is a source of pollution; however, the gas volume from
the preheater is less than from the charging emissions from an open
furnace.
     3.2.2.6  Emissions.  As noted above, the equipment and processes
involved in each of the operations diagrammed in Figure 3-1 are capable
of producing air pollutants in the form of fumes, gases, and particulates.
The major emissions are fine particles (ferrous and nonferrous oxides)
from the melting furnace(s).  Coarse particles are generated during
grinding operations, shaking, blasting, and sand reclamation.  Poly-
nuclear aromatic hydrocarbons (PNA's) may be evolved during preheating of
scrap and charging of scrap to the furnace when the scrap is coated with
organics.
     Charging and tapping emissions from electric arc furnaces have not
been extensively quantified because these emissions are usually unconfined,
and they are difficult to segregate from other foundry emission sources.
Extrapolation of limited emission test data from charging and tapping at
steel making EAF's indicates that charging and tapping at iron and steel
foundries may account for up to 10 percent of the total furnace emissions,
                                        1 Q—on
when alloying is conducted in the ladle.        When there are no alloys
added to the ladle, as is sometimes the case with iron production, then
charging and tapping are estimated to produce 5 percent of total furnace
emissions.
     The rate of emissions from iron EAF's during melting and refining
can vary depending on furnace size, charge composition, melting rate,
tapping temperature, and, primarily, the quality and cleanliness of the
scrap.   The quality of scrap charged has a strong effect on emissions
because the inclusion of large quantities of lower boiling, nonferrous
metallic impurities in the melt will inevitably lead to high concentra-
tions of oxides of these metals in the fume.   The cleanliness pf the
scrap is also an important factor.
     The significance of these two factors was clearly shown by Coulter,
who performed several tests under identical operating conditions but
                                                        21
varied the cleanliness and quality of the scrap charged.     The quantity
                                   3-24

-------
of emissions per ton of metal  melted increased TOO percent when dirty,
subquality scrap was used.   This trend was substantiated by Kane and
Sloan, whose tests, although marred by a malfunction, showed an increase
of over 40 percent in the amount of emissions released per ton of metal
                                                               22
processed when poorer quality scrap was charged to the furnace.
     The composition of particulate emissions from iron EAF's during
melting and refining was determined for three iron foundries, as shown in
Table 3-6.  Iron oxide and silicon dioxide were the main components, with
trace amounts of other metal oxides also present.  Chemical analyses of
dust collected from the bottom hopper of a fabric filter at a fourth iron
foundry EAF are shown in Table 3-7.  As indicated in Table 3-7, substantial
quantities of oxides of manganese, aluminum, and magnesium were found in
addition to iron and silicon oxides.  Analysis of the same melting and
                                                                    23
refining samples for particle size indicated small median diameters.
Table 3-8 presents a summary of the particle size distribution obtained
at each of the three iron foundries.
      Particulate emission factors  reported in the literature for un-
controlled emissions during the charging, melting, and tapping phases of
electric arc furnace operation  in  iron foundries show large variations.
Particulate levels ranging  from 2  to 20 kg/Mg (4 to  40 Ib/ton) of iron
                            O/l  OC
produced  have been reported.   '    These  variations  are primarily
attributable to the cleanliness of the scrap and foundry returns.  Foundries
that  process relatively  clean  scrap and returns  have lower emission
factors.
                                                                         3
      A  study was  conducted  for EPA covering  all  types of  iron  foundries.
It was  concluded  that,  on the  average, emissions  from melting  and refining
at  iron foundries  are  7.0 kg/Mg (14 Ib/ton)  of  iron  produced.
      Emissions  from steel-producing furnaces are similar  to  those from
 iron  melting.   The dust generated in  arc  furnaces  that  melt  steel for
 castings may  have the  composition shown  in  Table 3-9.
      There are  often traces of tin, zinc, chromium,  and copper in the
 emissions.   The use of larger amounts of  galvanized  scrap can result in
                                            27
 higher levels  of emissions  of these metals.
      Oxygen lancing, when used in steel  furnaces,  temporarily increases
 gas volume as well as particulate and carbon monoxide emissions.   Carbon
                                   3-25

-------
TABLE 3-6.  CHEMICAL ANALYSIS OF PARTICULATE EMISSIONS
           FROM AN IRON ELECTRIC ARC FURNACE23

Constituent
Iron oxide
Silicon dioxide
Magnesium oxide
Manganese oxide
Lead oxide
Alumina
Calcium oxide
Zinc oxide
Copper oxide
Lithium oxide
Tin oxide
Nickel oxide
Chromium oxide
Barium oxide
Proportion of total
Foundry A
75-85
10
2
2
1
0.5
0.3
0.2
0.04
0.03
0.03
0.02
0.02
0.02
parti cul ate,
Foundry B
74-85
10
0.8
2
2
1
0.2
2
0.03
0.03
0.3
0.03
0.07
0.07
weight percent
Foundry C
75-85
10
1
2
0.5
0.5
0.8
0.3
0.01
0.03
0.02
0.01
0.01
0.01
                             3-26

-------
TABLE 3-7.  COMPOSITION OF DUST COLLECTED BY
     FABRIC FILTERS AT AN IRON FOUNDRY26

Constituent
Ferrous oxide
Ferric oxide
Silicon dioxide
Magnesium oxide
Aluminum oxide
Manganese dioxide
Calcium oxide

(FeO)
(Fe203)
(Si02)
(MgO)
(A1203)
(MnO£)
(CaO)
Weight percent
8.75
41.2
34.9
5.0
4.7
8.0
1.4
                   3-27

-------
  TABLE 3-8.  PARTICLE SIZE DISTRIBUTIONS FOR PARTICIPATE EMISSIONS
        FROM ELECTRIC ARC FURNACES AT THREE IRON FOUNDRIES23
Particle size (urn)
Foundry A
                                  Cumulative percent by weight for
                                    indicated particle diameter
Foundry B
Foundry C
Smaller than 1
Smaller than 2
Smaller than 5
Smaller than 10
Smaller than 15
Smaller than 20
Smaller than 50
     5
    15
    28
    41
    55
    68
    98
     8
    54
    80
    89
    93
    96
    99
    18
    61
    84
    91
    94
    96
    99
                                  3-28

-------
       TABLE 3-9.   STEEL ELECTRIC FURNACE DUST COMPOSITION'
                             (Weight Percent)
Components
Sample
Sample 2
Ferric oxide (Fe203)

Ferrous oxide (FeO)

Calcium oxide (CaO)

Aluminum oxide (A1203)

Silicon oxide (Si02)

Manganese oxide (MnO)

Carbon (C)
35% to 42%

 4% to  8%

 6% to 15%

 3% to 13%

 2% to 10%

 2% to  8%

 2% to  8%
 23.95%

  9.66%

 15.41%



  3.76%

 15.25%
                                    3-29

-------
monoxide  from  lancing  is  typically  combusted  at the furnace by air drawn
through furnace  openings  or  by mixing  furnace exhaust gases with outside
air.    Unlike iron  furnaces, steel  furnaces  may  be backcharged which
results in  a violent eruption of  iron  oxide fume.
     The  average concentration of particulate at  the inlet to control
devices is  in  the range of 2.5 to 8.5  g/dscm  (1.1 to 3.7 gr/dscf).*
During oxygen  lancing, peak  values  of  12 to 15 g/dscm (5.2 to 6.5 gr/dscf)
are obtained.  On the  average, melting and refining emissions from steel
                                                  00
furnaces  are about 8.0 kg/Mg (16  Ib/ton) of steel.    Peak emission rates
which occur during oxygen lancing and  backcharging are two or three times
larger than the  average.
     Table  3-10  presents  a summary  of  emission factors for iron and steel
producing electric arc furnaces.
3.3  BASELINE  EMISSIONS
3.3.1  General
     A summary of State air  pollution  regulations for those States having
electric arc furnaces in  foundries  is  presented in Table 3-11.  Most of  '
these States group foundries under  the general heading of "Industrial" or
"Manufacturing Processes" and regulate the class  as a whole.   Five States
(Iowa, Michigan,  New Hampshire, Virginia, and Wisconsin) have regulations
specific to new  and/or existing electric melting  or foundry facilities
(electric furnaces for metallurgical melting; secondary metal operations,
including gray iron  and steel foundries; electric arc or induction furnaces;
or ferrous  foundries with any melting  procedure).   Many other States have
regulations that  cover cupola furnaces in foundries but those regulations
are not pertinent  to this study.
     The most  common method  of regulating particulate source emissions is
through the use of one of two sets of  process weight equations.   They
are:
     1.  E =  3.59 P°-62
         E = 17.31 P°-16
P ^ 30
P > 30
*g/dcsm:  grams per dry standard cubic meter.
 gr/dscf:  grains per dry standard cubic foot.
                                 3-30

-------
           TABLE 3-10.   SUMMARY OF EMISSION FACTORS FOR IRON- AND
                  STEEL-PRODUCING ELECTRIC ARC FURNACES7
                                       Uncontrolled emissions
                                Iron furnaces

                              kg/Mga    Ib/ton1
                         Steel furnaces

                        kg/Mg     Ib/ton
Melt and refine

Charge and tap
7.0
0.71
14.0
8.0

0.8
16.0

 1.6
?kg/Mg = kilograms per megagram.
 Ib/ton = pounds per ton.
cWith alloys added to the ladle.
                                      3-31

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     2.   E =  4.10 P0-67
P ^ 30
         E = 55.0 P0-11-^     P > 30
             where E = allowable particulate emissions in Ib/h
                   P = process weight rate in tons/h
                       (raw material  input)

Equation set (2) is used by more States than equation set (1).  Several
of the States have calculated values  for various process weight rates
based on the equations and have generated tables or graphs for use in
their regulation.  These equations are used for existing and new and/or
modified sources.  Some States may use both equation sets depending on
the source type.  A few States have developed their own process weight
equation.
     Particulate emissions from both stack and fugitive sources may also
be limited through the use of visible emission or opacity regulations.
The maximum permissible opacities range generally from 20 to 40 percent;
most States use 20 percent.  Many of the States have specific time periods
per hour or times per day exclusions during which the opacity may be
greater, or even unlimited.  In most States, the visible emissions are
read at  the emission point from the stack or building.
     The State  regulations pertaining to fugitive emissions are less
specifically delineated.  Of those States having fugitive emission
regulations, most  require the emissions to be controlled to the extent
reasonable  or feasible with no  specific emission limit given.  A few
States  specify  an  opacity either  at the source or the plant boundary
while others require  only that  the ambient particulate concentration
limits  not  be exceeded.   No specific control equipment is specified for
process  fugitive emissions although  general  requirements  such as the
hooding or  ducting of emission  sources may be  recommended.
      Facilities utilizing current best capture  and  control technology can
meet  the above  process weight emission regulations  (see  Section 4.6 -
Emission Source Test Data).   The  technology  now commonly used for  the
capture of melting emissions  is either a  side  draft hood (iron or  steel
                                   3-37

-------
foundry) or direct shell evacuation (steel foundry).  Capture of fugitive
emissions is less common, but where practiced, the canopy hood is the
equipment usually used.  In nearly all EAF foundries the control device
used for particulate removal is the fabric filter.  Depending on the
extent of State Implementation Plan (SIP) revisions, the trend toward
capture and control of fugitive emissions will probably continue in new
foundries.
     There are two regulatory approaches used by those States having the
most strict regulations.  Massachusetts and the California South Coast
Air Quality Management District (SCAQMD) use process weight regulations
with lower allowable pound per hour emission rates than the majority of
the States.  New Jersey and Pennsylvania specify an emission concen-
tration limit of 45 mg/Nm3 (0.02 gr/dscf), which is the lowest among
States specifying concentration limits.  Due to their dependence on air
flow rates, concentration limits may provide stricter control than process
weight limits for some capture devices but not for others.
     The wording of "the visible emission regulation of the California
SCAQMD is stricter than that of any other State.  Although the opacity
limit is specified to be less than 20 percent, SCAQMD has defined
"emissions to the atmosphere" to include emissions into the air in a
building; therefore, the opacity measurements may be read in the building
at the site of the process equipment, prior to diffusion into and/or out
of the building.
3.3.2  Baseline Emission Level
     The baseline emission level is taken to be that emission rate
determined using the process weight equation:
          E =  4.10 P0-67
P   ^30
          E = 55.0 po.ii-4o        P   >30
          where:  E = allowable particulate emissions in Ib/h
                  P = process weight rate in tons/h
                      (raw material input)

This emission rate would apply to melting emissions only.  This equation
is the most commonly used particulate source emission regulation that
                                 3-38

-------
applies to iron and steel foundries.   This equation is also used for all
or part of regulations by 8 of the 13 States having 10 or more electric
arc furnaces in steel foundries.  These 8 States contain 17 of the top
36 foundry market areas, ranked by order of sales importance, including
the top 6 areas.2  The visible emission limit applicable to stack
emissions is taken to be less than 20 percent.
     Several States have fugitive emission regulations that could apply
to electric arc furnace operations.  However, compliance is difficult to
determine because of the general wording of the regulations.  No fugitive
(charging, tapping) emissions would be controlled under the baseline
emission level even though some fugitive control may  now be practiced.
     Table 3-12 presents representative emission rates for three furnace
sizes  for both iron and  steel electric arc furnaces.  The.baseline
emission level is given  along with the uncontrolled emission  level.
     No regulations other than  State and  local  air pollution  regulations
are  believed  to be a  factor  in  the baseline  emission  level  (e.g.,
Occupational  Safety  and  Health  Administration).
                                     3-39

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-------
3.4  REFERENCES FOR CHAPTER 3

 1.  Georgieff, N. T. and F. L. Bunyard.  An Investigation of the Best
     Systems of Emission Reduction for Electric Arc Furnaces in the
     Gray Iron Foundry Industry.  U.S. Environmental Protection Agency,
     Research Triangle Park, N.C.  October 1976.  Draft.

 2.  Foundry Management and Technology.  Metal Casting  Industry Census Guide,
     1979 Edition.  Cleveland.  April  1979.  64 p.

 3.  Davis, J. A., E. E. Fletcher, R.  L. Wenk, and A. R.  Elsea.  Screening
     Study on Cupolas and Electric Furnaces  in Gray Iron  Foundries.
     Final Report.  U.S. Environmental Protection Agency,  Research Triangle
     Park, N.C.   Contract No.  68-01-0611, Task No. 8.   August  1975.

 4.  Steel Founder's Society of America.  Directory of  Steel Foundries
     in the United States,  Canada, and Mexico, 1977-78.   Rocky  River, Ohio.
     1977.  274 p.

 5.  1979 U.S. Industrial Outlook.   U.S. Department of  Commerce,
     Industry  and Trade Administration.  Washington, D.C.  January  1979.
     p. 178-179.

 6  The  Foundry  Industry—A  Look Ahead.   Foundry Management and
     Technology.  Miske, J. C.  (ed.).   Figure  3,  p. 40.  January  1978.

 7.  Fennelly, P. F.  and P. D.  Spawn.   Air Pollutant  Control  Techniques
     for  Electric Arc Furnaces in the Iron and Steel  Foundry Industry.
     U.S.  Environmental  Protection Agency.   Research  Triangle Park,  N.C.
     Publication  No.  EPA-450/2-78-024.  June 1978.   221 p.

 8.   Letter from  Burgess,  P.,  Hayes-Albion Corporation.  Albion
     Malleable Division, to Georgieff, N.  T.,  EPA.   May 17,  1974.
      Information  on malleable iron melting practice.

  9   Letter from Ferguson,  W.  0., Gray and Ductile Iron Founders'  Society,
      to Georgieff,  N.  T.,  EPA.  May 29, 1974.   Information on EAF iron
      melting emissions.

 10   Letter from Ferguson,  W.  0., Gray and Ductile Iron Founders'  Society,
      to Georgieff,  N. T.,  EPA.  October 14, 1975.  Information on EAF
      melting emissions.

 11.  Bidulya, P.   Steel Foundry Practice.   Moscow, U.S.S.R., MIR Publishers,
      1968.  p. 295.

 12.  Letter and  attachments from Welzel K., Landesanstalt fur  Immissions
      und Bodennutzungsschutz  des  Landes Nordrhein-Westfalen,
      to Georgieff, N. T.,  EPA.  June  16, 1976.   Information on German
      EAF systems.
                                     3-41

-------
 13.
 14.
 15.
 16.
 17.
 18.
19.
20.
21,
23.
 Rosenbach, V.  K. and W. Bruchhauser.  Erfahrungen mit der
 Rauchgasabsaugung und NaBreinigung durch Desintegrator an einem
 Lichtbogenofen.   [Experiences with Waste Gas Removal and Wet Scrubbing
 Through a Disintegrator on an Electric Arc Furnace.]  Stahl und
 Eisen (Dusseldorf).   86(1):16-21.  January 13, 1966.

 Background Information for Standards of Performance:  Electric Arc
 Furnaces in the Steel Industry.   Vol.  1.  U.S. Environmental
 Protection Agency.   Research Triangle Park, N.C.   EPA-450/2-74-017a
 October 1974.   p.  26.

 Georgieff, N.  T.  Addendum to Standards Support and Environmental
 Impact for Electric  Arc Furnaces in the Gray Iron Foundry Industry.
 U.S.  Environmental  Protection Agency.   Research Triangle Park  N C
 December 1976.   Unpublished.

 Schwabe, W.  E.   New  Developments in UHP:  Theory and Practice.
 (Presented at  International Conference on Electric Arc Furnaces in
 Steel  Making.   Cannes.   June 7-9, 1971).  8 p.

 James,  A.  I.   Developments in Electric Furnace Plant and Operation.
 Crucible Induction Furnace Melting Plant at Sulzer Bros.
 GKN Birwelco (Uskside)  Ltd.   (Presented at 1972 British Cast Iron
 Association Meeting.   University of Keele.   October 3-5,  1972.)

 Background Information  for Standards of Performance:   Electric  Arc
 Furnaces in the  Steel Industry.   Vol.  2.   U.S.  Environmental  Protection
 Agency.   Research Triangle Park,  N.C.   EPA-450/2-74-017b.   October
 1974.   41  p.
Memo from Goodwin,  D.  R.,  EPA,  to  Helms,  G.  T.,  EPA.
Information  on  steel  electric arc  furnaces.
                                                            November  25,  1974.
Lindstrom,  R. N. and S.  E.  Sundberg.   Fugitive  Particulate  Emission
Rate and Characterization  for  Electric Arc  Steel making  Furnaces.
Keystone Consolidated  Industries,  Inc.,  Peoria, 111., and Particle
Data Labs.,  Elmhurst,  111.   (Presented at Air Pollution Control
Association  Meeting.   Cincinnati.  June  24-29,  1979.)   15 p.

Coulter, R.  S.  Smoke, Dust, Fumes Closely  Controlled in Electric
Furnaces.  The Iron Age.  J73:107-110.   January 14,  1954.
22.  Kane, J. M. and R. V. Sloan.  Fume Control -- Electric Melting
     Furnaces.  American Foundryman.  1_8(5):33-35.  November 1950.
Systems Analysis of Emissions and Emissions Control in the  Iron Foundry
Industry.  Vol. 1.  U.S. Environmental Protection Agency.   Research
Triangle Park, N.C.  EPA No. APTD-0644.  February 1971.
                                   3-42

-------
24.
25.
26.
 27.
 28.
 29.
 30.
 31.
 32.
Air Pollution Emissions and Control Technology-Iron and Steel
Foundries Report.  Prepared for Environment Canada, Air Pollution
Control Directorate by Hatch Associates, Ltd., Toronto, Ontario.
R-229.  March 1975.  120 p.  Draft report.

Systems Analysis of Emissions and Emissions Control in the  Iron
Foundry Industry.  Vol. II.  A. T. Kearney and Company, Inc.
February  1971.   Exhibit VI-16.

Memo  and  attachments from  Jungers, R.  H.,  EPA, to Bibb, T., EPA.
September 26, 1975.  Gray  iron  foundry sample analysis.

Schmidt,  K.  G.   Staubbekampfung in der GieBerei-Industrie.
[Dust Abatement in the Foundry  Industry.]   Dusseldorf,
VDI-Verlag,  1967.   p.  358.

Baum, K.   Removal  of  Dust from  Electric Furnace  Waste Gases
Stahl und Eisen (Dusseldorf).   84(11):1497-1500.  November 1964.
                                  Emissions from Electric
                                   Air Engineering.  9:53-57.
Doerschuk, V. C.  How to Control
Steel Melting Furnaces:  Part I.
September 1960.

Doerschuk, V. C.  How to Control Emissions from Electric
Steel Melting Furnaces:  Part II.  Air Engineering.
]_0:42-46.  October 1960.

Pring  R. T.  Control  of Fume from Electric  Steel  Melting  Furnaces:
Part I.   Air Conditioning,  Heating and Ventilating.   58:45-50.
January  1961.

Prina  R T   Control  of Fume  from  Electric  Steel  Melting
Furnaces:   Part II.   Air Conditioning, Heating,  and Ventilating.
58:121-125.  February 1961.
                                       3-43

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                      4.   EMISSION CONTROL TECHNIQUES

4.1  INTRODUCTION
     Control of emissions from electric arc furnaces in foundries results
from the efficiency of two completely separate operations.  The first
operation is the capture or containment of the exhaust gas stream from
the furnace.  The second operation is the removal of contaminants from
the exhaust gas stream.  Capture poses two separate problems in the
process operation itself:  capture of emissions during charging and
tapping (fugitive emissions), and capture of emissions during melting and
refining  (process emissions).
      Historically,  the control  of emissions from  electric arc furnaces
has progressed  through several  stages.   Prior  to  the development  of  more
sophisticated control  techniques, hot  air and  emissions were allowed to
rise  to the roof of the  shop  where  they  were vented through  louvres  or
 fans  into the  atmosphere.   Although this procedure cleared the  melting
 shop  of  emissions and heat,  it merely transferred the  emissions outside
 and resulted in complaints from residents of the surrounding area.
 Large, expensive fans were required for effective venting of the hot air
 and emissions.
      In order to reduce the exhaust volume and permit the use of less
 expensive fans, roof trusses were enclosed and equipped with baffles
 directly above the furnace.  This modification reduced the required
 exhaust volume, but the amount of dust discharged remained unchanged.
      The next  stage in the development of emission control techniques was
  the  installation of small canopy hoods above  the furnaces in conjunction
  with a relatively  inefficient  control device  to  remove pollutants from
  the  hot  gases.   The gas volume was  still large  and  required expensive,
  high volume collection  systems and control  devices.   Use of small canopy
                                     4-1

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  hoods also did not entirely solve the problem of in-plant air pollution.
  Strong cross-drafts (caused by open doors)  within the building disturbed
  the  flow pattern of the gases  from the furnace causing some  emissions  to
  bypass the hood and drift to the roof area.   These emissions would  occa-
  sionally flow downward  toward  the floor too rapidly to be removed by
  exhaust fans.   Under such conditions,  the overhead crane  operator's
  vision was sometimes impaired,  and dangerous  operating conditions existed
  in all  parts  of the electric furnace  bay area.
       Subsequently,  attempts  have  been  made  to  reduce  exhaust volumes as
 much  as  possible  by mounting hoods  closer to the  furnace  or  by directly
 evacuating the  furnace  itself  (direct  furnace  evacuation  system).   Although
 moving the hoods  closer to the  furnace  roof reduces the volume of air to
 be captured and cleaned, this control technique is not totally effective
 during charging or tapping.
      This chapter presents emission capture techniques in common use for
 charging, melting and refining, and tapping, respectively.  Control  of
 emissions from the melting phase of furnace operation is currently prac-
 ticed at most foundries.  Control of emissions from charging and tapping
 is not widely practiced at existing foundries.   New designs,  which may be
 feasible for capture of emissions during charging and tapping, have  been
 installed on several EAF's.   In addition, several  designs  for control  of
 emissions during charging and tapping have been developed  and are also
 addressed in this chapter.   Finally, this chapter details  exhaust gas
 cleaning devices and summarizes test data for currently used  emission
 control  techniques.
 4.2   CONTROL  OF CHARGING EMISSIONS
      Electric  arc  furnaces  are  typically charged by removing  the  entire
 roof-electrode-fume  hood assembly  and  dropping  scrap  into  the furnace
with drop-bottom charging  buckets.1  As  scrap contacts  the hot furnace,
fumes  consisting of  hydrocarbon  vapors  and soot (from  entrained oil),
iron oxides (from  splashing and  oxidation of iron), and smoke  (from  dirt
on the scrap) are  generated.  Charging emissions have traditionally  been
vented to the atmosphere through roof monitors, since conventional emission
collection devices only collect melting emissions.  However, charging
                                   4-2

-------
often results in substantial visible emissions, and it is becoming more
common for regulatory agencies to require control of charging operations
by visible or fugitive emission regulations.
     There are five basic techniques applicable for capturing charging
emissions:
     1.   canopy hoods;
     2.   building evacuation;
     3.   bay evacuation;
     4.   furnace enclosures; and
     5.   specially designed, "close capture" hoods.
Each technique may also apply to the control of tapping emissions, which
is discussed in Section 4.4.  Additional techniques are available for
control  of charging emissions.  For example, charging emissions can be
reduced by the use of clean scrap.   Although most foundries seek high
quality scrap, dirty scrap can be cleaned prior to charging by preheaters
or a degreasing process.  Degreasing is an expensive process that is
seldom used.   Conceptual designs (not yet in use at foundries) for
collecting charging emissions include the hooded charge bucket and closed
charging systems.   The following subsections describe each control
technique.
4.2.1  Canopy Hood
     The canopy hood is the most common device currently in use for the
collection of charging emissions at foundries.   Located above the overhead
crane, canopies are normally operated only during charging and tapping,
when the melting collection system is inoperative.  However, some air may
be drawn through the canopy hood even during melting.   A typical canopy
hood collector is illustrated in Figure 4-1.
     The configuration and proper location of a canopy hood is dependent
mainly on structural and geometrical considerations within the shop.  The
most effective position to place a canopy hood is as close to the furnace
as possible,  although clearance for overhead cranes and furnace electrodes
must also be available.  Canopies are usually suspended 7 to 14 meters
(m) [23 to 46 feet (ft)] above the furnace or attached directly to the
shop roof.  Umbrella-shaped hoods of a diameter larger than the furnace
are one design option, while other designs incorporate the foundry roof
                                   4-3

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 and side walls.   The canopy can be constructed in sections with separate
 dampers to control  the air suction exerted by each section.   The dampers
 can then be preset  or controlled by an operator to provide a greater
 suction to areas where the largest quantity of emissions is generated.
      Due to the  positioning of the hood,  the volume of air drawn through
 it must be large to ensure effective capture of emissions.  Although
 thermal currents from the hot furnace help direct emissions upwards to
 the canopy, the  flow rate necessary for adequate capture is several times
 greater than that required for control of melting emissions.   Consequently,
"the size and costs  of a final  gas cleaning device are substantially
 increased over costs for melting control  alone.
      Effective capture of emissions is not always attained by the use of
 a canopy hood.   As  the furnace is charged, emissions are sometimes diverted
 away from the canopy because of impingement on overhead cranes and the
 charge bucket.   Another problem is caused by cross-drafts in the shop,
 which lower canopy  hood collection efficiency.   Upward flow of the emission
 plume from the furnace is easily disrupted by drafts from openings along
 foundry walls and doors, passage of shop  vehicles, temperature gradients
 within the shop, and even suction hoods which may ventilate other nearby
 foundry processes.   A canopy hood is not generally as effective for small
 furnaces because there is less thermal uplift generated.   Meteorological
 conditions may also influence the plume conditions.   High pressure systems
 and low humidity tend to allow efficient upward flow of the plume to the
 canopy.  However, during periods of low pressure, high humidity, and/or
 strong winds, thermal columns above the furnace may not be sufficient to.'•
 carry fumes directly into the canopy.
      Several techniques have been used to reduce the effects of cross-
 drafts and improve  the upward flow of emissions to the canopy.  At foun-
 dries, scavenger openings (see Figure 4-1) may be provided immediately
 above the canopy in the exhaust ductwork to collect emissions which have
 escaped hood capture and have accumulated under the shop roof.  Curtain
 walls constructed of sheet metal have been used to screen sensitive
 portions of a steel making furnace area from drafts and improve upward
                            2
 flow of charging emissions.   This may be termed a modified canopy hood
 or a partial enclosure at some facilities.  Another technique recently
                                    4-5

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 applied to both foundry and steel making EAF's is the use of an air
         3 4
 curtain.  '   An upward flow (or curtain) of air is directed around the
 furnace to contain and help direct fumes to the canopy.   Mobile air
 curtains have provided an effective method for counteracting daily
 variations in cross-draft flow patterns at a steelmaking shop.5
 Unfortunately,  the air curtain often cannot completely overcome the force
 of cross-drafts.
      Control  of cross-drafts often involves modifying shop  ventilation
 systems.   For example,  the exhaust hood on a pouring line adjacent to  a
 furnace may create a negative pressure  which impedes upward air flow from
 the furnace.   At many foundries,  the scrap handling area is adjacent to
 the furnace and has large doors which open to the  atmosphere.   Influence
 of outside winds  on canopy efficiency can be reduced by  closing these  and
 other openings  in the foundry walls.
      The  particulate collection and removal  efficiency attainable  with
 canopy hoods  were evaluated during a research and  development  program
 conducted by  a  large British steel  company.    It was determined that 90
 to 100 percent  of charging (and tapping)  emissions  were  collected  under
 optimum conditions  (no  serious  crosswinds  in the shop).   During periods
 of strong prevailing winds outside the  shop,  up  to  30  percent  of charging'
 (and  tapping) emissions  drifted away from  the canopy.  To control  the
 influence of  cross-drafts  deflecting the  rising  plume, vertical  sheeting
 was installed over  the  entire length of  a  four-furnace melt  shop,  roof
 vents  were  blocked  off,  and doors  fitted on  large openings  in  the  shop
 wall.
      Exhaust  flow rates  and emission capture  efficiencies for  canopy
 hoods  and other capture  techniques  for charging  (and tapping)  emissions
 are summarized  in Table  4-1.  Exhaust requirements  for canopies  are high,
 ranging from about  65 m3/s  (138,000  ftVmin)  for a  3.6-Mg/h furnace to
81 m3/s (171,600  ftVmin)  for the  22.7-Mg/h  furnace.  Larger furnaces
require proportionally less  flow than the smaller furnaces because of the
benefits of thermal uplift provided  by the larger heat source.  The flow
rates shown are averages of  typical  values since the physical  layout of a
particular foundry dictates  its canopy location, size, and design flow
rate.   Capture efficiency of the canopy hood  is specified as 80 to
                                   4-6

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90 percent, with 80 percent considered a more typical value because of
the potential for deflection by crosswinds.  Efficiency can be much lower
for improperly designed canopies, especially in shops which do not control
cross-drafts.  Using the typical flow rates in Table 4-1, it can be
calculated that a net increase in emissions to the atmosphere can occur
if the power plant emissions generated as a result of the electrical
requirements of the canopy hood are considered for the 3.6-Mg/h (4-ton/h)
        12
furnace.
     Retrofitting an existing furnace with canopy hoods sometimes requires
extensive structural modifications.  Trusswork and roof beams must often
be relocated, reconstructed, and/or strengthened to accommodate the
canopy and exhaust ductwork.  In some shops, there may not be enough
clearance between the crane and the roof, or the roof configuration
itself may not be adaptable to a canopy installation.  Also, space must
be provided for the large baghouse required to handle the high exhaust
volume.
4.2.2  Building Evacuation
     Several large iron foundries operate ventilation systems which com-
pletely evacuate the shop—exhausting emissions from charging, tapping,
                                                      313
and other foundry operations to a gas cleaning device.  '     Building
evacuation systems are similar to canopy hoods but operate at greater
flow rates.  Building evacuation systems exhaust emissions which accumulate
under the shop roof (see Figure 4-2).  Factors which influence the install-
ation of a building evacuation system over other systems  for control of
charging emissions are:
     1.  structural limitations or insufficient space to  use a canopy
         hood;
     2.  need to collect fugitive or miscellaneous emissions;
     3.  a roof configuration well-suited to complete evacuation (often,
         the roof can be modified to serve as a collection hood, as shown
         previously in Figure 4-1); and
     4.  desire to exhaust the entire foundry internal  atmosphere to
         reduce pollutant concentration for reasons of industrial hygiene,
         to reduce heat stress, or for metallurgical reasons.
                                   4-8

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      Major considerations  in  the design  of a building  evacuation  system
 are  control  of air flow patterns through the building  and  maintenance  of
 an effective flow rate.  Ideally,  floor  level  air  inlets surround sources
 of heat and the emissions  are exhausted  to a-central outlet  located
 overhead in the shop  roof.  However,  differences in  air duct placement
 are  usually necessary because of structural  and shop operational  con-
 straints.   Excessive  turbulence  and dead zones must  be avoided  to ensure
 proper  removal  of contaminants.   Flow control  is enhanced  by isolating
 emission sources  with partitions constructed to provide the  maximum
 feasible emission containment without interfering  with foundry  operations.
 These concepts  are illustrated in  Figure 4-2.
      Air velocity through  inlet  openings of  the building must be  adequate
 to induce air flow through the proper locations within the shop.   Louvers
 or vertical  adjustable  doors  are sometimes used as air inlet openings
 through  building  external walls.   Air outlets in the roof can be  designed
 to avoid the necessity  for large evacuation  hoods, relying on the  building
 roof  truss  area or plenum as  a contaminant reservoir and collection
 chamber.
      The volume of air  typically withdrawn for building evacuation systems
 is difficult to generalize because each  foundry is of  a different  size
 and building configuration.   Five  air changes per  hour have  been  used at
 some  steel mills  to maintain  a clean  internal atmosphere.     The  number
 of air changes  per hour at a  given shop  may  be considerably more than
 this, depending on the  shop conditions.   Data developed for  steel making
 EAF shops show  that typical building  evacuation systems evacuate about
 25 percent more air than an efficient  canopy hood.    This criterion was
 used  for  flow rates summarized in Table 4-1:  81  ms/s  (171,600 ftVmin)
 for the  small 3.6-Mg/h  (4-ton/h) furnace, ranging to 101  ms/s
 (214,000 ftVmin)  for the large  22.7-Mg/h (25-ton/h) furnace.  Emission
capture efficiency is listed  in Table 4-1 as typically 99 percent, ranging
from 95 to 100 percent, in recognition of the fact that a few small
openings may exist through which some emissions escape.
     Since the air flow rates for building evacuation are greater  than
those for canopy hoods, the control device would  also be  larger than that
for the canopy hood.  In addition, a net increase  in emissions  to  the
                                   4-10

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atmosphere would be possible when building evacuation systems are used on
a 3.6-Mg/h (4-ton/h) furnace.15
     There is a trend towards enclosing roof monitor vents to contain
charging, tapping, and other fugitive emissions and to avoid violation of
visible emission codes.   A multiple, manifold-type exhaust system ducts
emissions to the gas cleaning device.  This system is not designed as a
complete building evacuation system but is designed merely to remove
contaminants which accumulate under the shop roof.  Fugitive furnace
emissions are eliminated at an exhaust flow rate somewhat less than that
of complete building evacuation systems since the exhaust flow rate is
adequate to remove only accumulated emissions, not to evacuate the entire
building.  Although most emissions are collected and removed, a small
amount could escape the foundry through open windows and doors.  The
Michigan casting facility of Ford Motor Company is an example of this
type of control.
4.2.3  Bay Evacuation
     A recent variation of the building evacuation capture system is the
bay evacuation system where each shop bay (e.g., furnace, ladle, casting,
                                   1718
stripping) is evacuated separately.  '    The furnace is located in a
window!ess room (bay) isolated from other bays by air locks and/or sound-
proof doors.  The furnace bay roof is shaped to accommodate a canopy hood
for fugitive emission control (see Figure 4-3).  The canopy hood may be
zoned so that proper airflow may be maintained during charging and tapping.
If more than one furnace is contained in the bay, each may have its own
canopy hood.  A bay evacuation system would greatly reduce the problems
involved with cross-drafts that are encountered with canopy hood and
building evacuation systems.
     This  system  is in use in at least three European steel mills but  is
not known  to be used in foundry operations either in the United States or
abroad.  Thus,  little extrapolation  can be done with regard to the volume
of air required to  remove the emissions since  this air volume would
depend on  the  size  and configuration of the individual shop.   Some compari-
 son can  be made,  however, for the  22.7-Mg  (25-ton) furnace size.  One  of
 the European facilities evacuates  64 m3/s  (135,000 ftVmin)  for a 22.7-Mg
                  1 o
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                                    4-11

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Table 4-1 for 22.7-Mg (25-ton) model furnaces.  The emission capture
efficiency of the bay evacuation system is not known but it should be in
the same range as that for building evacuation systems.
4.2.4  Furnace Enclosure
     A metal shell which completely encloses the furnace and tapping area
can capture emissions from charging, melting, and tapping (Figure 4-4).
A large takeoff duct near the enclosure top removes charging and melting
emissions while a separate, local duct contains tapping fumes.
     The first domestic application of the furnace enclosure concept
began operation in 1976 on two 54.4-Mg (60-ton) capacity steel making
EAF's at the Lone Star Steel Company, Lone Star, Texas.  The furnaces are
part of a new melt shop and each furnace was enclosed as an economical
alternative to canopy hoods or building evacuation for the control of
fugitive emissions.  A furnace enclosure has recently been installed in a
steel foundry, and several others are under construction or on order for
use on EAF's in foundry shops.
     The volume of air which must be removed from the furnace enclosure
is estimated at only 30 to 40 percent of that required for an efficient
canopy hood, considerably reducing  both capital and operating costs for
exhaust  ductwork, fans, and gas  cleaning equipment.  Major factors which
reduce effectiveness of a canopy hood, namely, cross-drafts and diversion
of fumes by the crane, are eliminated with a  furnace enclosure.  As a
secondary benefit, furnace noise is reduced  outside the enclosure.
      Figure 4-4 shows the basic  design of the furnace  enclosure at  Lone
Star  Steel  Company,  and pertinent design parameters are summarized  in
Table 4-2.  Constructed of riveted  steel plates,  each  enclosure is  a cube
with  a domed  or rounded top measuring  13.4 m (44  ft) on edge.  The
enclosures  contain the minimum  volume which  provides clearance for  furnace
roof  removal  during  charging  and for furnace electrodes when  tilted for  a
tap.   Pneumatic  cylinders  operate  large  vertical  doors on  the front of
the  enclosure;  an electric  motor operates  a  segmented,  horizontal,  cable-
 guided top  door  to allow  conventional  furnace charging by  crane.   Smaller
 vertical doors  at the rear of the  enclosure  allow access  for  oxygen
 lancing, slagging,  and chemical  additions.
                                    4-13

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Figure  4-4.   Sketch of  furnace  enclosure  design  at Lone  Star Steel  Co.19
                                    4-14

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  TABLE  4-2.   DESIGN DATA FOR LONE STAR STEEL COMPANY FURNACE ENCLOSURE19
 I.   Steelmaking facilities
          Two 54.5 Mg (60 ton) Whiting EAF's, each enclosed in 3230 m3
          (114,000 ft3) enclosure.   Enclosures measure 13.4 m,
          (44 ft) on edge; furnaces are 6.1 m (20 ft) above ground level
          Average 2-1/2 hours per heat.

II.   Gas flow rate, per enclosure
          Charge, melt, refine, and tap:  35 to 42 m3/s
                                          (75,000 to 90,000 ftVmin)
III. Exhaust gas temperatures
     A.  Charge, melt, and refine:  80°C (175°F)
     B.  Tap:  120°C (250°F)

IV.  Dust concentration measured  by Lone Star Steel  Company
     (EPA Method 5)
     A.  Inlet to scrubber:  2.29 g/m3  (1.0  gr/ft3)
     B.  Outlet from scrubber:  0.024 g/m3  (0.0045  gr/ft3)

 V.  Suction required
         Inlet to scrubber  units:   1.4  cm  Hg (7.5 in.  H20)

VI.  Capital cost3
     A.  Enclosures,  ducting,  and auxiliary equipment,
          including  gas cleaning device:  $900,000 per enclosure
      B.   Scrubber gas cleaning units  only:   $200,000 per enclosure
 h976 dollars.                                               -.,,..,.-.- ^
  Utilized existing waste heat boiler and slurry treatment facilities.-
                                                               - .;-. 3 a f. ~- r
                                    4-15

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      During positioning of the charge bucket, the crane operator has a
 line of sight to the furnace through the top enclosure doors.   When a
 charge is dropped into the furnace, the front doors are closed but the
 top door remains open.  A fan-type air curtain directs the emission plume
 past the open top doors to the exhaust duct.   During melting,  the top and
 front charge doors are closed and the emissions are exhausted  from the
 enclosure by a large rectangular exhaust duct located above the furnace
 1.2 m (4 ft) below the enclosure top.   Between 35 and 42 m3/s  (75,000 and
 90,000 ftVmin) of air is withdrawn from each enclosure by suction devel-
 oped by Lone Star's proprietary scrubber which cleans the furnace exhaust
 gases.   Slagging,  chemical  additions,  and oxygen lancing are conducted
 through a third door at the furnace rear.   This door is currently left
 open during the entire process.     The furnace is tapped into  a ladle
 which is placed on a rail car by the overhead  crane,  then rolled into
 position under the enclosure.   Tapping emissions are collected by diverting
 flow from the main exhaust  duct to a duct which is adjacent to the ladle.
 Both furnaces and  enclosures rest on a platform about 6.3 m (20 ft)  above
 the melt shop floor.   This  provides room for  the tapping ladle car and
 also provides air  flow from underneath the furnaces  to effectively carry
 contaminated gases to  the main  exhaust duct.   The elevated furnace and
 ladle car were provided for the  Lone Star  installation but are not
 necessary to,  nor  integral  parts  of, the total  enclosure  concept.
      Lone Star Steel operators  have encountered no major  problems  in
 using the enclosures.   Lone Star  has run trial  heats  charging  No.  2
 bundles  (automobile  bodies  processed through  a  compactor).  Because of
 combustion of contaminating oil and organic matter,  flames  from the hot
 furnace  reached to the  top  of the  enclosure.   Lone Star personnel  indicated
 that  the  trial  runs  showed  that additional enclosure  height would  be
 necessary if  dirty scrap is  used routinely.  Other methods of  protecting
 the structure  from the  heat  (e.g.,  the use of alternate materials or
 shielding) could also be used.  When clean scrap  is charged, about 95 to
 99 percent of the charging emissions appear to be collected.  This estimate
 is based  on observations by engineers who visited Lone Star Steel on
behalf of EPA  in 1977 and on statements by plant engineers and  the local
air pollution control agency.    When ordinary purchased scrap  (other
                                   4-16

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than clean) is charged, the capture efficiency drops to 50 to 80 percent.
This estimate is based on observations by engineers who visited the
facility in 1979.10  The charging process at this facility lasted
approximately two minutes.  Visible emission observations were made of
the total enclosure emissions, but, as information to reconcile the above
conflicting observations is not available, these visible emission data
are not presented in this document.20  This enclosure installation was
the only one operational at the time of the study; thus, no further
information could be obtained regarding the capture efficiencies.
     An enclosure system of a different design was  installed in a steel
foundry during  the  summer of 1979  but was not operational at the time of
this study.21"23 This system is on a 5.4-Mg (6-ton) capacity  basic EAF
at  Certified  Alloy  Products, Inc., Long Beach, California.  Pertinent
design parameters are  summarized in Table 4-3.   Constructed of steel
plate and  sheeting, the enclosure  dimensions are 5.8 by 8.8 m  (19 by
29  ft).  The  inside of the  enclosure  is  covered  with insulation for sound
proofing.   Air-operated doors are  used  to  allow  access  of  the  charge
bucket while  manually operated  doors  allow personnel entrance  (e.g.,  for
 slagging and bath sampling).   No  air  curtain  is  used during  charging,  and
 the end  and roof doors are open during  both charging and tapping.   Air is
 evacuated at a rate of 18.9 m3/s  (40,000 fts/min) from the enclosure  for
 emission control purposes.   The gas  stream is cleaned  in a fabric filter.
      Another steel making EAF enclosure is in use in Europe.     This
 system,  shown  in Figure 4-5, is offered by the Krupp Company.   It relies
 on an enclosure somewhat larger than the one at Lone Star Steel.  A
 direct roof evacuation tap supplements emission control during melting.
 Instead of sliding doors, a section of the enclosure side wall moves
 horizontally to allow passage of  a specially designed  charging crane.
 The crane  is designed with a section which seals the enclosure during
 charging  (see  Figure  4-5).  Procedures for tapping and alloy  additions
 are similar  to methods used at Lone Star.  Available data indicate.ithat;: "
 the enclosure  volume  for  a  128-Mg (140-ton) steel  EAF  is  11,000 m3
  (388,000  ft3), and the enclosure  exhaust  rate is  135 m3/s (290,000 ftVmin)
  during  charging and tapping  and  105  m3/s  (226,000  ft3/min) during melting.
                                     4-17

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    TABLE 4-3.  DESIGN DATA  FOR  CERTIFIED ALLOY  PRODUCTS  FURNACE  ENCLOSURE23
 I.  Furnace facilities
     One 5.4-Mg (6-ton) Lectromelt EAF located in an enclosure
     having dimensions of 5.8 by 8.8 m (19 by 29 ft).  Average
     3 hours per heat.
II.  Gas flow rate
     18.9 mVs (40,000 ftVmin)

III. Exhaust gas temperature
     54°C (130°F) maximum

IV.  Capital cost3
     A.   Enclosure, ductwork, fans,
         auxiliary equipment:
     B.   Fabric filter:
$159,000
$ 95,000
'1979 dollars.
                                   4-18

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4.2.5  Close Capture Hood
     The "close capture" concept for controlling charging, melting and
tapping emissions, as supplied by the Hawley Division of Envirotech
                                          oc
Corporation, is illustrated in Figure 4-6.     Melting and refining
emissions are evacuated by a rectangular hood which completely encom-
passes the electrodes, unlike conventional side draft hoods (see
Section 4.3.2) which are open on one side.  This allows improved collection
of emissions with minimum exhaust volumes.  Capture of charging emissions
is accomplished by an annular ring hood which encompasses the furnace rim
during charging.  The annular charging ring hood is designed to rotate
onto the furnace during a charge and then rotate back to the furnace side
during melting.  Charging emissions are withdrawn radially through slots
located on the inner side of the annular ring; the slots serve to increase
capture velocity and improve emission collection.  During the charging
sequences, dampers in the exhaust ductwork divert the exhaust flow from
the electrode hood to the annular charging ring hood.
     Tapping emissions are collected by enclosing the tap spout with an
inverted U-shaped hood which is exhausted to the main duct.   When charging
(or tapping), dampers divert most of the exhaust flow from the electrode
hood to the charge (or tapping) hoods.   A telescoping joint allows the
electrode hoods to withdraw a moderate amount of fume from the furnace
during tapping, supplementing the tapping hood exhaust.   The tap hood
only encloses the furnace tap spout and a portion of the ladle,  as opposed
to other designs (furnace enclosure, ladle pit enclosure) which  enclose
the entire ladle for more complete emission containment.   A small, separate
hood is also provided for the slag door.
     The advantage of the close capture design is that control  of charging
and tapping are provided at an exhaust flow rate much less than  for
canopy hoods or furnace enclosures.   This significantly reduces  the
quantity of exhaust gas delivered to the particulate control device,  thus
reducing costs of gas cleaning.   Also,  the close capture hoods are simpler
and considerably less expensive to install than a furnace enclosure or
canopy hood.   The disadvantage is that complete control  of charging and
tapping may not always be provided because the charge/tap hoods  do not
completely enclose emission sources.
                                   4-20

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HOOD EXHAUSTING
   SLAG DOOR
 ELECTRODE AREA
  ENCLOSED  WITH
RECTANGULAR HOOD
      HOOD ENCLOSING
        TAP SPOUT
       (STATIONARY)
                                                   a.  Top View
SWIVEL JOINT
                                                             ..TO
                                                              •BAGHOUSE
     ANNULAR RING HOOD
     SWINGS OVER
     FURNACE TOP
     DURING CHARGING
                                               ANNULAR RING HOOD
                                               IN PLACE TO COLLECT
                                               CHARGING EMISSIONS
HOOD ENCLOSING
 TAP SPOUT
           • TO
            BAGHOUSE
                                                     b.   Side  View
                Figure  4-6.   Hawley close  capture hood.
                                                       25
                                 4-21

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      Exhaust flow rates of the close capture design are comparable to
 those used with conventional  side draft hoods.   For example,  a 3.6-Mg/h
 (4 ton/h) furnace would require about 13.0 m3/s (27,500 ftVmin)  for the
 close capture hoods,  contrasting sharply with 65 mVs (138,000 ftVmin)
 for canopy hoods.   The manufacturer guarantees  total  emission capture
 efficiencies of 100 percent for melting and 80  percent for charging and
 tapping (of iron); however, these efficiencies  have not been  verified.
 No observations of the emission capture efficiency have been  made as
 sufficient facilities utilizing the entire system are not yet in  operation.
 When alloys are added to the  ladle (e.g.,  steel  foundries), tapping
 control  efficiency is expected to be substantially reduced.   Control  of
 backcharging is also  likely to be less  than 80  percent.
      The close  capture design is applicable to  most foundries where
 either the furnace area can be designed to accommodate the hoods  or the
 hood design can be modified to adapt to the shop restrictions.  The close
 capture  design  has been applied at several  foundries,  the majority of the
 installations being retrofit  applications  at existing foundries.   At one
 particular steel  foundry there was not  enough clearance between the
 furnace  and the transformer room wall to allow  employment of  the  annular
              oc
 charging ring.     In  this  retrofit case,  only a  partial  charging  hood    '•
 could be used,  mounted to  the furnace shell,  to  effect control of the
 charging emissions.   Collection efficiency of charging emissions  was
 observed to be  substantially  lower than that expected  from the complete
 charging hood.  Many  existing foundries may have similar  space restrictions
 which limit control options.
 4.2.6 Clean Scrap
      Charging clean scrap  to  an EAF  substantially  reduces  charging  emissions.
 When  dirty  scrap contacts  a hot furnace, oil  and other  volatile impurities
 combust,  releasing  dense clouds  of soot and  smoke.  Oily  scrap can  also
 cause premature roof  failure  around  the electrode ports,  damage dust
 evacuation  hooding and  ducts,  and  also  clog  or "blind" a  fabric filter
 control  device.   Use  of dirty,  substandard  scrap has been  estimated to
 increase overall furnace emissions by up to  100  percent,  although quanti-
tative test data for  charging emissions are generally not  available,27
Contact with several  State and  local air pollution agencies indicated
                                   4-22

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that quite often foundries are required to use a clean scrap to control
                   OQ
charging emissions.     For example, the Los Angeles County Air Pollution
Control District issues operating permits to furnaces which use clean
scrap as the method to control charging emissions.   No visible emissions
are detected at roof vents above the furnace during charging of clean
scrap.
     Dirty scrap can be cleaned prior to charging by preheaters or degreasing.
Charge preheaters are standard equipment on induction furnaces for cleaning
the charge, removing water, and avoiding the operating problems of charging
dirty scrap.  Few, if any, preheaters are used in EAF foundries in the
United States although they have been used in other countries as a method
for producing clean scrap for the reduction of charging emissions on
EAF's in foundries and to increase melting capacity.
     The most efficient preheater is the conveyor type which applies a
fossil fuel flame to the scrap under an emission collection hood.  The
conveyor typically discharges clean, hot scrap to a charge bucket although
a few systems have been designed to charge directly to the induction
        OQ  on
furnace.   '    Preheating in a special charge-preheat bucket has been
used but does not result in uniform preheating.  Ultra hot, intense flame
jets must be directed into the scrap for certain periods to heat the
entire charge, increasing the danger of overoxidation of thin pieces of
scrap.  Excessively oxidized scrap requires considerably more energy for
melting.
     Some preheaters are designed with a secondary  combustion chamber
which acts  as an afterburner for controlling emissions from the preheater.
One manfacturer of preheaters for  induction furnaces reports that the air
pollution  codes of Los Angeles County are met by a  local facility using
                       27 29
this type  of preheater.   '
     Preheaters used for  induction furnaces reportedly reduce overall
power  costs for melting because the preheaters are  more efficient in
heating the metal, and costs  for fossil fuel have traditionally been less
than those for electricity.   Net energy savings with preheaters  have been
quoted  on  the order  of 300 MJ/Mg (75  kWh/ton)  of metal, compared to
                                                            29 30
normal  melt requirements  of about  1,980 MJ/Mg  (500  kWh/ton).   '
Application of preheaters  to  EAF's will probably be severely  limited by
                                    4-23

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fuel shortages.  Retrofitting existing EAF's with a conveyor-type pre-
heater could require substantial reconstruction of scrap bins and scrap
bucket handling systems.
     A degreasing process to remove oil and dirt from the charge can also
be used to reduce emissions caused by dirty scrap.  Degreasing operations
involve washing scrap in a tank with either a solvent or detergent and
water.  Excessive amounts of oil may be removed from turnings and other
machining wastes by centrifuging, which typically reduces oil content to
about 2 percent.
     Degreasing has been traditionally used to remove oils from valuable
scrap, such as brass, bronze, and copper, but is not usually applied to
ferrous scrap at the foundry.  Degreasing may be performed by scrap
dealers.  For example, motor blocks are often crushed and cleaned and
then sold to the foundry.   Degreasing is not done extensively, however.
     Problems with degreasing at foundries stem primarily from the solvent
residues and air emissions of hydrocarbons from the solvents.  Approxi-
mately 1 to 2.5 kg of solvent per Mg of charge cleaned (2 to 5 Ib/tori)
requires disposal when borings and turnings are the charge material.   Of
more importance, the mass of solvent emissions from the degreaser has
been estimated to exceed emissions which would be generated by the charging
of dirty scrap.   Thus, degreasing is not considered an environmentally
acceptable option for reducing charging emissions from unclean scrap.
4.2.7  Briquetting Swarf
     In many foundries, particularly steel foundries, up to 20 percent of
each charge may be swarf, i.e., turnings and borings produced by the
machining of castings.   The swarf itself is readily oxidized upon charging
and also contains oils from machining.   Thus, charging swarf to the EAF
results in greater generation of emissions, compared to charging of
heavier scrap pieces.  A briquetter can be used to compress the swarf
into a more solid form which serves to minimize oxidation of metal during
charging, thus reducing charging emissions.  Briquetters are not common
at foundries, and no data are available to quantitatively indicate the
potential reduction in charging emissions.
                                   4-24

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4.2.8  The Brusa-Kemmetmueller Closed Charging System
     The Brusa closed charging system, illustrated in Figure 4-7, has
been operating on three steelmaking furnaces in Italy for several
years.31'32  Exhaust gases from the hot furnace are vented through a
rotary kiln or drum.  Charge material is fed continuously down through
the kiln, into the furnace, and is preheated by furnace gases to about
1000°C (1830°F).  Volatile matter entrained in the charge is thus oxidized
and withdrawn at the top of the kiln along with the furnace exhaust.
gases.
     This system has the advantages of heat recovery along with the
containment of charging emissions in a fashion that allow for simple
collection and ducting to a control device.  This type of steelmaking is
the continuous process, where charge material is continuously added.  The
Brusa and other conceptual designs for closed charging systems require
small-sized scrap in order to pass through the enclosed system.
4.2.9  Hooded Charge Bucket
     The hooded charge bucket, diagrammed  in Figure 4-8, is designed to
fit tightly over the top of the furnace during charging.  Charging emissions
pass upwards through the bucket and  into an attached hood.  Most of the
emissions from  charging would be  collected and the exhaust volumes would
be substantially lower than with  a canopy  collector.  Some emissions
would probably  be combusted in the hood, and the hood and duct should be
protected from  heat and flame.  Hooded charge buckets are commercially
available, but  none are known to  be  operating at present.
      A  similar  approach under study  in Europe is the Marchand design,
which utilizes  a local, mobile hood  that can be clamped above the charge
bucket  or suspended over  the  furnace by overhead crane, as shown  in
Figure  4-9.   This  system  is very  similar in  function to a canopy  but  is
smaller in  size and can be lowered close to  the furnace, minimizing the
air  volumes  necessary  to  effectively capture the emissions.  This varia-
tion of the  hooded  charge bucket  concept has not been  applied  to  foundry
 EAF's in this country.
                                    4-25

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                                            TO CONTROL DEVICE
 Figure 4-8.  Hooded charge bucket.
                        4-27

-------
          DESIGN I
                                                     DESIGN 2
                 TO CONTROL DEVICE
                                                                TO COKTROl. DEVICE
Figure 4-9.   Marchand design for  charging  emission control.
                               4-28

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4.3  CONTROL OF MELTING AND REFINING EMISSIONS
     Essentially all EAF's in iron and steel foundries collect furnace
emissions during melting and refining with one of three basic systems:
     1.   roof hoods;
     2.   side draft hoods; or
     3.   direct furnace evacuation.
This section describes typical components and configurations for each of
the above basic control systems.   Selection of the best system for  control
of melting  and. refining emissions  depends on site specific  variations,
such as  physical  and  structural  constraints at the foundry  and metallurgical
requirements of the furnace.
     When properly designed  and  maintained, each system can provide
efficient capture of  melting emissions  and  direct them to a gas  cleaning
device.  There is normally a small leakage  from  the  furnace or furnace
evacuation  systems.   Some emissions inevitably  escape through  electrode
 holes  and/or improperly sealed roof rings and slag  doors, especially
 during  initial meltdown,  oxygen lancing, and  when the slag door  is opened
 (e.g.,  during bath sample extractions).
      Melting and refining control systems are not designed to collect
 emissions from charging and tapping.  The collection hoods or ducts are
 attached to the furnace roof and  generally become inoperative during
 charging (when the roof is removed) and tapping (when the  furnace  tilts
 and disconnects from the main exhaust duct).   Partial evacuation of the
 furnace during tapping may be accomplished through the use of telescoping
 ductwork connecting  the furnace melting  emission capture device and the
 main duct  leading to the  control  device.
 4.3.1   Roof Hood
      A  typical roof  hood  evacuation system is shown  in Figure 4-10.  The
 hood is mounted  directly  on the furnace roof and maintains an indraft
 through the annuli between  the  electrodes  and  the openings in the furnace
  roof.   Extensions of the hood may also collect  fumes from the pouring
  spout  and  slag or working door.
       The full roof hood is the heaviest of the furnace  evacuation systems.
  When retrofitting an EAF, allowances must be made for increased structural
                                     4-29

-------
Figure 4-10.  Roof hood.
                        1
           4-30

-------
loads on the furnace roof, base, and the mechanisms which remove the
furnace roof for charging.
     The full roof hood can provide reliable collection of melting and
refining emissions due to the hood's storage capacity to contain an
instantaneous increase in emissions.  As shown in Table 4-4, capture
efficiency ranges from 95 to 100 percent for melting and refining emissions
with 99 percent being a typical, maximum level encountered at foundries.
Exhaust flow rates typically range from 7.7 mVs (16,300 ftVmin) for a
3.6-Mg/h (4-ton/h) furnace to about 30.0 m3/s (63,600 ftVmin) for a
22.7-Mg/h (25-ton/h) furnace.1
     The roof hood has an advantage in that it muffles the noise of the
furnace.  A disadvantage  is the difficulty of performing maintenance on
the furnace roof.  Hinged flaps mounted on the side or on the top of the
hood can help alleviate this problem as well as allow for inspection of
the furnace roof and the  electrode ports.
     A modification of the roof hood design, called a two-section hood,
reduces access and weight problems which may be associated with the full
roof hood.  The two-section hood has separate subhoods, one located over
the electrodes and the other located above the gap between the furnace
shell and roof.  Collection efficiency is slightly reduced over that of a
full roof hood.
4.3.2  Side Draft Hood
     The side draft hood  shown  in  Figure 4-11 is mounted on the furnace
roof.  One side  is open for the electrodes so that their travel is not
restricted.  Hoods may be mounted  above the slagging door and pouring
spout to connect back to  the same  exhaust duct as the side draft hood.
     The hood collects the emissions after they have escaped from the
furnace via  the  electrode holes.   A substantial part of the furnace roof
being  left clear permits  easy access for maintenance of the cooling
glands  and electrodes.  The  side draft  hood does require larger exhaust
volumes than a  roof hood.  The  larger exhaust flow  insures  complete
combustion of the  carbon  monoxide  and reduces downstream exhaust tempera-
tures.  The  side draft  hood  is  simpler  than a .roof  hood  and places  less
weight on the  furnace  and furnace  tilting mechanism.  The  furnace  roof
must seal tightly  to  the  furnace  shell  to  insure effective  capture  of
                                    4-31

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Figure 4-11.  Side draft hood.
              4-33

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 melting emissions.  Tight seals are not a requirement of roof hoods which
 enclose the entire furnace top.
      Retrofitting an .existing furnace with a side draft hood generally
 presents few problems.   One large new foundry, however, reported severe
 deterioration of the fingerlike projections which collect emissions from
 electrode ports.   The furnace was directly evacuated, with the side hood
 designed to catch fugitive emissions from the electrodes.   Heavy stainless
 ductwork was eroded in  a matter of weeks, and after many attempts at
 solving the problem,  the company installed a roof hood.35  This is not
 considered a common problem because many side draft hoods are operating
 quite satisfactorily on EAF's of all  sizes.
      Side draft hoods have the highest exhaust flow rate of the three
 devices for control  of  melting and refining emissions.   Flow rates range
 from about 13.0 ms/s  (27,500 fts/min)  for a 3.6-Mg/h (4-ton/h)  furnace to
 about 70.8 ms/s (150,000 ftVmin) for  a 22.7-Mg/h (25-ton/h) furnace.1
 These flow rates  are  typical  of recent installations;  older, less efficient
 side draft hoods  used lower flow rates.   The maximum emission capture
 efficiency expected  from a side draft  hood is 99  percent,  ranging from 90
 to  about 100 percent.7
 4.3.3  Direct Furnace Evacuation
      Direct furnace evacuation (Figure 4-12),  also  known as  fourth hole
 evacuation,  requires  another hole in the  furnace  roof  or sidewall  beyond
 the  three  required for  electrodes.  The exhaust gases  are withdrawn  from
 beneath the furnace roof.   Mounted  above  this  ventilation hole  is  an
 elbow which  is  connected via  ductwork  to  the  exhaust fan.  The  elbow must
 be designed  to  withstand the  heat of the  molten bath,  i.e.,  water-cooled,
 high  alloy  stainless, or refractory-lined.  The elbow  is often  not bolted
 to the  exhaust  duct;  rather,  a  gap  is  maintained  between the  flange of
 the elbow and the  off-take  to permit aspiration of air which  oxidizes the
 explosive, carbon-monoxide-rich  stream  to  harmless carbon dioxide and
 reduces the temperature  of the  exhaust  gases to protect  the  air pollution
 control equipment.
     This evacuation  system provides good emission control and minimizes
both the space  required  on the  furnace  roof and the gas volume which must
be withdrawn.  Because the air  flow necessary to capture emissions varies
                                   4-34

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              s;
Figure 4-12.  Direct evacuation through  fourth hole.
                      4-35

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during different phases of the operating cycle, the amount of draft can
be adjusted.  Disadvantages are that the ingress of air to the furnace,
although minimal, cools the slag, makes control of the temperature diffi-
cult, and reduces the carbon level in the melt through formation of
carbon monoxide.
     Direct evacuation systems are least applicable to EAF's which pour
high carbon alloys and certain other specialty iron and steel.  Direct
evacuation is more common with steel making EAF's than with foundry furnaces;
it is rarely used, if at all, with iron foundry EAF's.  Direct furnace
evacuation is not always a viable option for small steel furnaces because
of (1) lack of space for the fourth hole and (2) pressure fluctuations in
the furnace which are too rapid for automatic control of dampers in the
exhaust duct.  The direct evacuation system is easily retrofitted to an
existing furnace.  Problems reported concerning some EAF's which were
retrofitted with direct evacuation include:  additional weight on the
furnace roof, excessive deterioration of shell refractories and roofs,
water cooling problems, and clearance problems with roof rotation for
charging.
     Typically, exhaust flow rates for direct evacuation systems are
25 percent of those required for comparable fume control with side draft
hoods.   Table 4-4 shows flow rates ranging from 3.3 m3/s (7,000 ftVmin)
for a 3.6-Mg/h (4-ton/h) furnace to about 21.2 ms/s (45,000 ftVmin) for
a 22.7-Mg/h (25-ton/h) furnace.    Because the exhaust gas temperature is
considerably greater with direct evacuation systems compared to side
draft hoods, substantial dilution air is normally introduced to cool
gases prior to the gas cleaning device.   Emission capture efficiency is
comparable to side draft hoods,  ranging from 90 to 100 percent, with a
typical maximum level of 99 percent for well-designed systems.
4.3.4  Other Systems
     The furnace enclosure and close capture systems, described in
Sections 4.2.4 and 4.2.5, respectively,  also can control furnace emissions
from melting and refining.
     When viewing the furnace enclosure interior during melting,  emissions
generally appear to flow directly upwards in a column towards the exhaust
duct near the top.   The space around the inside perimeter of the enclosure
                                   4-36

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is usually relatively free from emissions, as the rising column does not
always fill the entire enclosure.   Flames and emissions violently escape
from the furnace electrode holes during melting.   At times, however, the
enclosure is full, or nearly full, of smoke and dust.  This is the case
during approximately the first 10 minutes of meltdown and periodically
thereafter, particularly whenever power is restored to the electrodes.
Emissions within the enclosure also increase during oxygen lancing.
     Emissions escaping from the top of the enclosure during melting are
generally of low to moderate volume, suggesting a capture efficiency of
80 to 95 percent.  Emissions are highest during the first portion of the
meltdown period and during oxygen lancing.  The effect of the continually
open rear enclosure door on enclosure emissions cannot be determined but
is believed to have little effect.
4.4  CONTROL OF TAPPING EMISSIONS
     The EAF is tapped by raising the electrodes, tilting the entire
furnace as much as 45 degrees and transferring the melt to a ladle through
the pouring spout.  Sparks and emissions of molten metal particles are
ejected from the  flowing metal.  Alloys are usually  added to the ladle,
and the ensuing  reaction may substantially increase  tapping emissions,
depending  on the  reactivity of the  added alloys.
      Some  of the  emission collection systems described  in Section  4.2 for
control of charging emissions, i.e., canopy hoods, building evacuation,
bay evacuation,  furnace enclosures, and close capture  hoods, also  collect
tapping emissions.  Tapping emissions can also be collected by  enclosing
and exhausting the  ladle  pit or by  use of a tapping  hood.  Also, several
designs  for tapping  hoods have been used  at  steelmaking furnaces.    Some
of these  tapping control  systems  are discussed below.   No  observations
have  been made of the close capture system to  assess emission  capture
efficiency; thus, reference  is  made to the general discussion  in
Section  4.2.5.
4.4.1  ARMCo  Tapping Pit  Enclosure
      ARMCo Incorporated was  granted a  U.S. patent  for the  tapping  pit
                                oc
 enclosure shown in Figure 4-13.     In  this  relatively simple  design, the
 ladle is placed under the furnace in  a tapping pit by conventional overhead
                                    4-37

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To
Control
Device
                                                 Furnace
 Figure 4-13.   ARMCo Incorporated design for
          tapping pit enclosure.36
                     4-38

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crane.  A removable cover effectively seals the tapping pit after the
crane is retracted.  Molten metal flows from a short spout in the furnace
to a launder, or chute, which extends through a side wall of the ladle
pit.  An exhaust duct near the top of the pit withdraws tapping emissions
to a gas cleaning device.
     ARMCo Incorporated uses the ladle pit enclosure design at its Torrance,
California, steel foundry.  A portion (66 to 75 percent) of the exhaust
flow which evacuates the furnace during melting is diverted to the ladle
enclosure and provides a high capture velocity to remove tapping emissions.
Exhaust flow rates are thus at or below those representative of side
draft hoods (Table 4-1).  The enclosure is designed to minimize openings
through which emissions can escape and a high capture efficiency would be
anticipated, i.e., about 80 to 95 percent.    This capture efficiency is
based on observations and engineering judgment of personnel who visited
the ARMCo facility in 1979.  Only a low to moderate amount of alloying in
the ladle is done at this facility.   This is the only example of this
type of emission capture system in the United States; thus, no determination
could be made on its capture efficiency when greater amounts of ladle
additions are made.  Visible emission observations of the capture efficiency
were made during the 1979 visit and are reported in Section 4.6.2.
     While the ladle pit enclosure system can be easily designed into a
new melt shop, retrofitting existing furnaces would depend largely on
available space in the tapping area.  At some shops there may be clearance
problems when the tapping pit roof is retracted for ladle removal.
4.4.2  Hoods
     Small, umbrella-shaped hoods located immediately above the ladle can
collect tapping emissions from the ladle area.   This type of tapping hood
is sometimes used with steelmaking EAF's but not at foundries.    Such a
design could be employed at foundries for tapping control.
     There are several approaches used to design a tapping hood.
Figure 4-14 shows a proposed design by Marchand whereby a tapping ladle
car receives the ladle by overhead crane, then is pushed into position
underneath a permanent tapping enclosure.  Such a system is most amenable
to new foundries, as space limitations will often limit retrofit potential.
Another design concept, shown in Figure 4-15, involves a ladle placed in
                                   4-39

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4-41

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            a tapping pit.  Further, as shown, a two-piece hood mounted on a track is
            placed over the ladle, around the crane cables.  Another design for
            tapping hoods calls for removing the crane and placing a hood into position
            over the ladle.  Flexible or easily matched ductwork connections are
            required for the latter two designs.
                 In general, the hood systems are somewhat more complicated than the
            enclosed ladle pit (ARMCo Incorporated design).  The emission capture
            efficiency of this type of hood at foundries is not known,  but high
            efficiencies would be expected for properly designed hoods.
            4.4.3  Furnace Enclosure
                 The furnace enclosure was described in Section 4.2.4.   During tapping,
            alloys are continously added to the ladle through a special  chute extending
            through the enclosure side.   Tapping emissions are drawn laterally into a
            rectangular side draft hood adjacent to the ladle top.   Most of the
            emissions are drawn into the hood, because the entire 35 to  42 mVs
            (75,000 to 90,000 ftVmin) exhaust is diverted from the enclosure top to
            the  tap hood and capture velocity is  quite high.   Ten to twenty-five
            percent of tapping emissions escape collection, based on observation and
            engineering judgment,  exiting the enclosure primarily through the alloy
            addition chute and through the enclosure top.     Emissions escaping the
            alloy addition chute  usually dissipate by the  time they reach the melt
            shop roof.   Smoke observers  at the Lone Star plant have read the  opacity
            of emissions escaping the roof monitors as ranging from 0 to 40 percent
            during tapping,  averaging about 8 percent.19
            4.5   EXHAUST GAS CLEANING DEVICES
                 After evacuation  of the emissions  by one  of  the  capture systems,  a
            dust cleaning device  is  used to treat the gases before  they  are discharged
            to the  atmosphere.  Because  of the small  size  of  the  dust particles
            generated  by EAF's, only the following  three types  of dust collectors
            have been  generally accepted as  being suitable:
                 1.   fabric  filter;
                 2.  wet scrubber; and
                 3.  electrostatic precipitator (ESP).
_
                                              4-42

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     Virtually all foundry EAF's in the United States use fabric filters.
Fabric filters use considerably less power than scrubbers, are normally
more efficient collectors of the fine particles characteristic of EAF
emissions, are relatively insensitive to particle size variations in the
gas stream, and also collect dust in a dry form which is readily dispos-
able.  Scrubbers produce wastewater which must be treated prior to
recirculation to scrubbing units and require a high energy input to
remove fine particles.  Electrostatic precipitators have received only
limited application to EAF's in the United States.  Recent improvements
in ESP collection efficiency may increase interest in using ESP's in this
country, but installation and energy costs are high relative to fabric
filters.
4.5.1   Fabric Filters
     Fabric filters depend on a filter media to remove the dust from the
gas stream.  The devices are simple to operate and come in many designs,
sizes, and shapes, differing primarily in the characteristics of the
filter media (woven or felted glass or woven or felted synthetic fabrics)
and the method of removing the dust from the fabric (reverse air pulse,
mechanical shaking, reverse air flow, or combinations of these three).
     Exhaust gas from the EAF contains fine particulates dispersed in a
gas stream that changes considerably in temperature, dust concentration,
size distribution, and volume during the various furnace phases.  Fabric
filter collectors (baghouses) are regarded as the most versatile and
efficient device for cleaning these dust streams.  Properly designed
fabric filters can generally handle a tenfold variation in the inlet dust
concentration without effecting the outlet dust concentration.  Baghouses
can be operated under positive or negative pressure and may be cleaned
intermittently or automatically.
     Positive pressure baghouses force exhaust gas through the bags using
a  fan placed between the collection duct and the baghouse.  Maintenance
and bag inspection is easier than with negative pressure units because
the baghouse is not airtight and can be entered while in service, if the
exhaust gas temperature  is not too hot for personnel safety.  Dirty gas
drawn through each bag is filtered through the cloth, then vented to the
atmosphere through louvers or vents along the top of each compartment.
                                   4-43

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 New baghouses installed on EAF's tend to be the positive-pressure type
 because of lower capital  costs and simple inspection procedures  for
 detecting damaged bags.    With suction,  or negative-pressure  type bag-
 houses, a fan on the clean air side of the baghouse pulls  air through the
 bags.   Bag compartments must be kept airtight,  and thus  inspection for
 defective bags requires the compartment  to be  taken off-line.  Suction
 baghouses usually require less fan maintenance  and less  operating horse-
 power  than the pressure type.
     Fabric filter bags periodically become clogged with a dust  cake and
 require cleaning to avoid excessive pressure loss.   So-called intermittent
 systems are designed to run without cleaning until  the end of a  furnace
 heat,  at which time flow  stops and the bags can be manually shaken.
 Intermittent baghouses  generally cost less and  are easier  to  maintain
 than the automatic continuous  service baghouse.   The intermittent filter
 is  most applicable to small,  single furnace shops where  there is  adequate
 time between heats to manually clean the filter.
     Automatic cleaning baghouses  are much more common than intermittent
 systems as  they are capable of continuous,  unattended service, and precise
 control  can  be maintained over both pressure loss and particulate  removal
 efficiency.   Cleaning methods  in common  use are mechanical  shaking,
 reversing the  air  flow, and pulse  jet mechanisms,  all of which dislodge
 collected particles  from  the bags  to a hopper located underneath.
     Current fabric  filter technology has  advanced  to the  extent  that
 under  certain  conditions  it may be  possible to  mount the unit directly on
                      18
 the foundry  shop roof.     The  filter inlet  section would act  as a  canopy
 hood,  eliminating  the need for ductwork.  Ground  space would  also  be
 saved.
4.5.2   Wet Scrubber
     Wet  scrubbers moisten  the  gas  stream to cool it and reduce the
volume, then collect the  dust-laden  water droplets by inertia! mechanisms.
There  are two  basic  scrubber types:  wet impingement and venturi.  In a
wet impingement scrubber,  furnace exhaust gas enters through the scrubber
bottom, is cooled  in a water spray  zone, and passes through one or more
impingement  baffles which  separate  dust-laden water droplets from the gas
stream.   In  a  venturi scrubber, pressurized nozzles inject a water spray
                                   4-44

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into the venturi section.   Intense turbulence within the venturi
constriction causes entrainment of particulates into the water droplets.
The water-dust mixture is removed from the gas stream both within the
venturi section itself and in a following cyclone separator.   For either
scrubber type, collection efficiency can approach 98 to 99 percent, but
it is dependent on pressure drop (or energy expended) in the scrubbing
(venturi) section.
     Overseas, venturi scrubbers are commonly used with cupolas and
steelmaking basic oxygen and electric arc furnaces, but there are no
known venturi installations on iron or steel foundry EAF's in the United
States.8  Fabric filters are preferred over scrubbers for several reasons.
High pressure venturi scrubbers are noisy, requiring elaborate muffler
systems to prevent noise problems.  Although installation costs and space
requirements for the scrubber are somewhat lower, power costs are higher
than those for  fabric filters (especially for high efficiency scrubbers
which operate at high pressure drop).  Disposal of scrubber wastewater
requires water  treatment and/or water recirculation systems at the plant.
Most importantly, wet scrubbers are generally not as efficient as bag-
houses  for collecting the fine particles generated by the EAF.   Because
of  low  capital  costs and low space requirements, high-efficiency scrub-
bers may be  a control option for  existing EAF's in areas of the country
with low power  costs.
     There  is one  commercially available, high energy scrubber which  has
been shown  capable of meeting stringent  concentration standards for an
EAF.   The  Lone  Star  Steel scrubber achieves  high removal efficiency on
fine particles  by  means  of  steam  injected at supersonic  velocity in a
mixing section.   This unit  was designed  to  operate with  waste process
heat from  an integrated  iron and  steel mill.   Where  sufficient  waste  heat
is  available,  this scrubber appears  quite economical as  compared to
fabric filters.  In  a foundry with  only  an  electric  arc  furnace, waste
 heat  from  the EAF alone  would  be  sufficient to provide  only  a portion of
the required energy.     An  auxiliary fan would be  necessary  to  provide
 the remainder;  the scrubber thus  would require about twice as much energy
 as a fabric filter system.   Maintenance and capital  costs  are less for
 the scrubber at Lone Star Steel  than for a baghouse.   That scrubber may
                                    4-45

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 be an alternative to the fabric filter for efficient collection of the
 fine participates from the EAF, if sufficient waste heat is available.
 4.5.3  Electrostatic Precipitator
      The electrostatic precipitator (ESP), another type of exhaust gas
 cleaning device,  is often used in the control of particulates  from basic
 oxygen steelmaking furnaces;  however, no ESP's are currently in operation
 on domestic foundry EAF's.
      The ESP operates by routing the gases through a high voltage field
 to impart an electrical  charge to the dust particles and by subsequently
 trapping the particles on the oppositely charged collecting electrodes  or
 plates by coulombic attraction forces.   The dust particles are periodi-
 cally removed from the collecting electrodes by water or mechanical
 vibration.   On wet precipitators,  dust is removed by flushing  the collecting
 plates with water;  on dry precipitators,  dust is dislodged by  "rapping"
 (i.e., shaking) the collecting plates.
      Electrostatic precipitators  have a relatively high collection
 efficiency for particles  larger than several  micrometers,  but  their
 successful  operation is  strongly  dependent on the resistivity  character-
 istics of the dust.   Dusts  from metallurgical  processes must sometimes  be
 wet  with water to decrease  resistivity to an acceptable range.37   ESP
 collection efficiency has  traditionally dropped markedly for smaller
 particles;  however,  developments  in  ESP technology have improved
 performance.
      Installed costs  and  energy consumption  for ESP's  are  somewhat greater
 than  those  for fabric filters.  ESP's  periodically require  a certain
 amount of downtime  for maintenance purposes.   The space requirements of
 both  precipitators  and fabric  collectors  are  almost  the same.
      A recent  emission control  system  utilizing an  ESP  has  been developed
                    OO
 by a  Japanese  firm.    In this  system,  the ESP  is  mounted directly on the
 building  roof  with  the inlet to the  ESP being  located at the roof  crown.
 Fans  are  not used to move the  exhaust gases through  the  ESP; rather, the
 upward thermal  convection of the plume  and the  natural  draft of the
workshop  are used to carry the plume into the ESP.   Electric power consump-
tion  of the unit  is, therefore, reported to be  2 to  5 percent of that
required  for baghouse  systems.  Although not in current usage in the
                                   4-41

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United States, the system is being used on EAF and basic oxygen furnace
                                                   39
(BOF) shops and blast furnace cast houses in Japan.
4.6  EMISSION SOURCE TEST DATA
4.6.1  Control Device Data
     Virtually all foundry EAF's in the United States are controlled by
fabric filters; thus, there is a general lack of emission source test
data for scrubbers and ESP's.  Particulate emissions from the EAF are
predominately smaller than 20 (jm (see Section 3.2) in size, and fabric
filters are generally recognized as the most efficient collectors of fine
             o
particulates.
     Based on EPA test data presented in this section plus standard
emission factors, properly designed and operated fabric filters can
achieve effluent concentrations of 16 mg/dscm (0.007 gr/dscf)* or less.
The technical literature reviewed confirms the above efficiency. ''
Fabric filter vendors also indicate that the above effluent concentration
           41
can be met.    Wet scrubbers can be designed for 98 to 99 percent removal
of EAF dusts with effluent concentrations of about 46 mg/dscm
               Q
(0.02 gr/dscf).   Other references indicate that scrubber performance on
fine particle emissions from steel mills can be 97 percent for a scrubber
                             40
with a 60-inch pressure drop.
     ESP efficiency on fine particle metallurgical emissions is reported
                               40
in one reference as 95 percent.    Recent data reported for a large
steelmaking EAF showed that effluent concentrations of 69 mg/dscm
(0.03 gr/dscf) are obtainable with ESP's, and other data show that ESP's
at steel mill EAF's are capable of achieving concentrations of 6 mg/dscm
                 i A?
(0.0025 gr/dscf). ' '^
     The following subsections present data obtained by EPA on emissions
from EAF fabric filter systems.  The data are from field tests performed
by EPA contractors on units selected as representing good control tech-
nology or  submitted by industry or vendor representatives from performance
tests.
*mg/dscm - milligrams per dry standard cubic meter.
 gr/dscf - grains per dry standard cubic foot.
                                   4-47

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                       4.6.1.1  Iron Foundry Industry.   EPA personnel obtained data frqm
                  six iron foundry EAF's to establish typical levels of control  of which
                  fabric filters are capable.   Figure 4-16 presents the results  of measure-
                  ments of particulate concentrations.   Data for each plant are  grouped in
                  one vertical data bar; each data point represents a separate sample
                  collected by traversing the sampling plane (unless otherwise noted).
                  Data for Plants A, B, C, and D were obtained by EPA contractors during
                  field tests while data for Plants E .and F were submitted by industry  or
                  State agency representatives.   A detailed summary of these test results
                  is presented in Appendix C.
                       All  furnaces were fitted with side draft hoods, except Plant C which
                  had roof hoods for the capture of melting emissions.  Figure 4-16 indi-
                  cates average emissions ranging from 3.2 to 16.5 mg/dscm (0.0014 to
                  0.0072 gr/dscf) for five of the tested furnaces.   However, Plant C showed
                  average grain loadings of 58.9 mg/dscm (0.026 gr/dscf).   At this foundry
                  during the period of the tests, carbon black was injected into the molten
                  metal  via a pressure lance,  and a manually cleaned baghouse was used.
                  The use of the pressure lance  is believed to be the cause of the increased
                  emission  rate.   This foundry currently uses the pressure lance method of
                  carbon injection only one percent of  the time and would  not use it again
                                                49
                  should a  new foundry be built.     Other methods of carbon injection
                  available to the industry are  used more frequently,  are  less expensive,
                  and are less polluting.   Available information indicates that  industry
                  reliance  on these alternate  methods of carbon injection  would  not preclude
                  the production of any metals now being produced.   Thus,  the data for
                  Plant C will  not be used as  part of the data base.
                       The  data for Plant E were  provided by a State agency from its
                  compliance test records.   Due  to discrepancies in the  isokinetic sampling
                  rate,  sampling locations,  and  sample  time  vs.  process  conditions,  the
                  data may  not be representative  of results  obtainable from tests  adhering
                  to  the conditions  of EPA Reference Method  5.50 Therefore,  the data will
                  be  given  less  weight in the  data base.   The  data  presented for Plant  F
                  were obtained  during the ASTM  Project  Threshold program  and represent
                  16  tests.   As  only slight modifications  to  EPA Reference  Method  5 were
_
                                                    4-48

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 made, the data were determined to be suitable for use in the data
 base.51'52
      Opacity readings were obtained from the baghouse stack outlets of
 four of these furnaces (Plants A, B, C, and D) and the foundry roof
 monitors above the furnaces for three of the furnaces (Plants A, B, and
 D).  Stack opacity (6-minute averages) ranged from 0 to 11.5 percent for
 three of the plants with 6-minute average readings of 5 percent or less
 for 90 percent of the time.  Plant C, which had emission concentrations
 considerably greater than the other plants, had somewhat greater stack
 opacities with the 6-minute averages ranging up to 30.4 percent and being
 5 percent or less only 70 percent of the time.   Visual  observations of
 foundry roof vents for three plants during melting indicated an opacity
 range (6-minute averages) from 0 to 10.4 percent,  with  average readings
 of 5 percent or less at least 93 percent of the time.   A detailed summary
 of these opacity data is  presented in Appendix C.
      4.6.1.2  Steel  Foundry Industry.   Performance data for fabric filters
 operating on steel-producing EAF's are summarized  in  Figure 4-17.   These
 data were obtained from industry representatives (Plants G,  H,  I,  J,  and
 K)  and  foreign contacts (Plants  L, M,  N,  0,  and P).   The foreign data are
 presented for informative purposes only and will not  be  used in the data
 base.   Detailed emission  data for steel  foundries  are reported  in
 Appendix C.
      Data for Plants  G, H,  I,  J,  and  K were  obtained  from acceptance
 tests on newly installed  baghouses.   Plants  G and  H use  side draft hoods
 for the  capture  of melting  emissions while  Plants  I and  J use direct
 furnace  evacuation.   Plant  K  uses  a modification of the  close capture
 system.   Since the data for these  plants were not  obtained through  EPA
 contractor field testing, in most  cases only the results are available.
 Little is  known about the specific fabric filter or EAF  installations,
air/cloth ratios, or process and testing conditions during the test
periods.  Partial test reports are available for plants G, H, and J.61'62
The data were determined to be suitable for use in the data base in
                      63
support of other data.    The data for plant I will be given less weight
in the data base because of discrepancies in the portion of the heat
sampled for each run.
                                   4-50

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n p
i
i
i
i
i
3 1
i ** i
i 1
nil O i
ti A ' * '
V) i' ' i i ,
5 v |T | 1 Q |
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• 	 1 	 1 	 1 r~ i i i i i i
Plant GHIJK LMNOP
Reference : 53 53 54 55 26 56 57 58 59 60
            Figure 4-17.  Summary  of  source  test data for
                  baghouses on  EAF's  producing  steel.
                                    4-51

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      Data  for plants  L and M were obtained  from acceptance  tests  on
 fabric  filter installations in  the Federal  Republic  of  Germany.   These
 facilities use direct furnace evacuation  for  melting emission  capture.
 The  data shown for Plants  N,  0,  and P  represent the  typical  levels of
 performance found  on  foundry or foundry size  EAF fabric filter systems  in
 Germany, France, and  Italy,  respectively, and do not represent tests
 performed  on specific installations.   Again,  little  is  known about the
 specific installations or  test  conditions.  All  of the  data presented
 were obtained using the VDI  particulate test  method.  Based on prior
 tests conducted in the Federal  Republic of  Germany on municipal incin-
 erators, EPA Reference Method 5  collected 30  percent more dust from the
 clean gas  stream than did  the VDI  method.   The data  presented  in
 Figure  4-17 have been corrected  to incorporate this  variation.
      Visible emission observations were performed by EPA personnel at
 Plants  G and I.  '     Stack opacity (6-minute averages) ranged from 0 to
 21.9 percent with  6-minute  average readings of 5 percent or less  for
 91 percent of the  time.  The  maximum 6-minute average opacity  during
 oxygen  lancing was  2.7 percent.  These observations  were not performed at
 the  same time as the  particulate tests noted  earlier.  The  opacity of the
 baghouse exhaust at steel foundries may be  lower than at iron  foundries
 because the  carbon  black added to  iron is not completely absorbed by the
 melt.   Five  to  forty  percent  of carbon added  to  iron furnaces  escapes in
 the  furnace  exhaust gas, and  these  extremely  fine particles may also pass
 through the  baghouse.    Carbon black addition  is generally not done at
 steel foundries.
      Maximum  opacity  (6-minute average) reported from roof vents and
monitors was  16.7 percent at  Plant G and 10.0 percent at Plant I.   The
value for  Plant G was  observed during tapping, while that for  Plant I was
observed during the melt cycle.   Neither facility had charging or tapping
emission capture systems.   The maximum 6-minute average opacity during
oxygen lancing was  6.9 percent at Plant I.  No visible emissions were
observed during the melt cycle,  including oxygen lancing, at the roof
vents of Plant G.  The 6-minute average opacity from the roof vents of
Plant I was 5.0 percent or less, 89 percent of the time.  The opacities
are higher during tapping because of alloy addition to the ladle.   Charging
                                   4-52

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generated substantially less visible emissions at the shop roof while
backcharging emission levels were between tapping and charging in magnitude
for Plant G.  Because of the quantity of alloys added to the ladle and
the hotter tap temperature, fugitive emissions from a steel furnace are
generally somewhat greater in magnitude than those from iron production.
The opacity data for steel foundries are detailed in Appendix C.
4.6.2  Capture Device Data
     Visible emission observations using EPA Reference Methods 9 and 22
were made on the tapping pit enclosure.    Based on limited data, the
emissions, as read 1.8 m (6 ft) above the pit enclosure, were visible
only 30 percent of the time and had an opacity of 15 percent or less,
both averaged over the entire tapping period.  It should be noted that
these values do not represent 6-minute averages as the readings (utilizing
both reference methods) were made only from the start to the end of metal
flow during tapping, a period of approximately 2.5 minutes.  Due to the
limited number of observations made, the data obtained are not sufficient
for use in the data base.
     As noted in Section 4.2.4, observations were made of emissions from
the total enclosure system, but because of discrepancies in the data the
results are not presented  here nor are they to be used in the data base.
                                    4-53

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 4.7  REFERENCES FOR CHAPTER 4

  1.   Fennelly,  P.  F.  and P. D.  Spawn.   Air Pollutant Control Techniques
      for Electric Arc Furnaces in the Iron and Steel Foundry Industry.
      U.S.  Environmental  Protection Agency.   Research Triangle Park  N C
      Publication No.  EPA-450/2-78-024.  June 1978.   221 p
  2.   Wood,  R.  M.,  Superintendent,  Electric Furnace.
      the Ford Steel  Division Electric Furnace Shop.
      Dearborn,  Mich.   Unpublished  paper.   1976.
 9.
10.
11
                                                      Design Aspects of
                                                      Ford Motor Company,
  3.   Telecon.   Wright,  A.,  Puget Sound Air Pollution Control Agency, with
      Spawn,  P., GCA/Technology Division.   March 24, 1977.   Information on
      EAF's in  Puget Sound area.

  4.   Kaercher,  L.  T.  and J.  D.  Sensenbaugh.   Air Pollution Control for an
      Electric  Furnace Melt  Shop.   Iron and Steel Engineer.   51(5V47-51
      May 1974.                                               —

  5.   Bintzer, W. W.  and R.  A.  Malehorn.   Air Curtains on Electric Furnaces
      at  Lukens  Steel  Company.   Iron and Steel  Engineer.   53(7):53-55
      July 1976.                                           —

  6.   Flux, J. H.   Containment  of  Melting  Shop  Roof Emissions in Electric
      Arc Practice.   Iron and Steelmaking  (Quarterly).   (3):121-133
      1974.

  7.   Memo and attachment from  Georgieff,  N.  T.,  EPA,  to  Spawn, P., GCA/
      Technology Division.   March  15,  1978.   Information  on flowrates.

  8.   Davis, J.  A.,  E. E.  Fletcher,  R.  L.  Wenk,  and A.  R.  Elsea.
      Screening  Study  on Cupolas and Electric Furnaces  in Gray Iron
      Foundries.  Final  Report.  U.S.  Environmental  Protection Agency.
      Research Triangle  Park, N.C.   Contract  No.  68-01-0611,  Task No. 8
      August 1975.

      Letter from Bonistalli, R. J., Obenchain Calumet, to  Maxwell,  W.  H.,
      Midwest Research Institute.    April  2£, 1979.  Response  to
      EAF  questionnaire.

      Memo and attachments from Maxwell, W. H., Midwest Research  Institute,
      to Crowder, J. U.,  EPA.  July  11, 1979.  Report of  June  1979  plant
      visit to Lone Star  Steel Company, Lone  Star, Tex.

     Memo and attachments from Maxwell, W. H., Midwest Research  Institute
     to Georgieff,  N. T., EPA.   July 5, 1979.  Report of May  1979  plant
     visit to ARMCo Steel Corporation, National  Supply Division,
     Torrance,  Calif.

12.   Memo from Maxwell, W. H.,  Midwest Research  Institute, to  EAF  Files.
     March 21,  1980.  Calculation of canopy hood related emissions.
                                   4-54

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13.  Telecon.  Hoenstine, J., Anderson Air  Pollution  Control  Agency,  with
     Spawn, P., GCA/Technology Division.  March  21,  1977.   Information  on
     General Motors/Delco foundry.

14.  Hansen, M. and H. Spitzer.  Die Hallenentluftung in  Huettenbetrieben.
     [Ventilation of  Industrial Halls in  Iron Metallurgical Plants.]
     Stahl und Eisen  (Dusseldorf).  77(2):210.   February  1957.

15.  Memo from Maxwell, W. H., Midwest Research  Institute,  to EAF  Files.
     March 21, 1980.  Calculation of building evacuation  related emissions.

16.  Telecon.  Aschinger, T., Wayne County  Air Pollution  Control Agency,
     with Spawn, P.,  GCA/Technology Division.  March  22,  1977.
     Information on Ford Motor Company foundry.
17.
18.
Graf Spee, D.  Ultra-Modern Electric Steelworks in Denmark.
Engineering Digest,  p. 21-25.  November-December 1977.

Letter and attachments from Aston, W. T., Banco Systems, Inc., to
Georgieff, N. T., EPA.  July 13, 1979.  Response to inquiry on EAF
emission control  systems.
19.  Memo from Spawn, P., GCA/Technology Division, to EAF file.
     September 14, 1977.  8 p.  Report of September 1977 plant visit to
     Lone Star Steel Company, Lone Star, Tex.

20.  Emission Test Report: Lone Star Steel Company, Lone Star, Texas.
     U.S. Environmental Protection Agency.  Research Triangle Park, N.C.
     EMB Report No. 79-ELC-5.  May 1979.

21.  Telecon.  Rosentreter, W., Otto H. Rosentreter Company, with
     Maxwell, W., Midwest Research Institute.  July 2, 1979.
     Information on EAF total enclosure system.

22.  Telecon.  Baustian, K. F., Certified Alloy Products, Inc., with
     Maxwell, W.  H., Midwest Research Institute.  July 5, 1979.
     Information on EAF total enclosure system.

23.  Letter and attachments from Baustian, K. F., Certified Alloy
     Products, Inc., to Cuffe, S.  T., EPA.  August 14, 1979.  Response to
     Section 114 letter on EAF total  enclosure.

24.  Krupp Stahltechnik GmbH.  Possibilities of Efficient and Low-
     Pollution Steelmaking in Electric Arc Furnaces.  299-070ell27805.
     Rheinhausen, Federal Republic of Germany.  Undated.  6 p.

25.  U.S. Patent No. 3,979,551.  Arc Furnace Fumes Control System.
     Assigned to Hawley Manufacturing Corporation.  Indianapolis, Ind.
     September 7, 1976.
                                   4-55

-------
                26.   Memo and attachments from Spawn, P., GCA/Technology Division, to EAF
                     file.   September 16, 1977.   16 p.   Report of September 1977 plant
                     visit to Hensley Industries, Inc., Dallas, Tex.

                27.   Coulter, R.  S.   Smoke, Dust, Fumes Closely Controlled in Electric
                     Furnaces.   The Iron Age.   ]73(1):107-110.  January 14, 1954.

                28.   Memo from Spawn, P., GCA/Technology Division, to EAF File.
                     May 9, 1977.   Summary of telephone conversations with air pollution
                     control agencies.

                29.   Telecon.  Sharpless, R.,  Melting Systems, Inc.,  with Spawn, P.,
                     GCA/Technology Division.   April 4, 1977.   Information on scrap
                     preheater.

                30.   Spencer, I.  L.   The Case for Conveyor Preheating.  Foundry Manage-
                     ment and Technology.  1_03(4): 100-104.  April 1975.

                31.   Brown, Boveri & Company,  Ltd.   The BBC/Brusa Process:  A
                     Contribution to the Economical Production of Arc-Furnace Steel.
                     Publication No. CH-IW 511 090 E.  Baden,  Switzerland.  Undated.
                     9 p.

                32.   U.S. Patent No. 3,645,515.   Metallurgical Furnace Installation and
                     Operating Method.   Assigned to American Waagner-Biro Company, Inc.,
                     Pittsburgh,  Pa.  February 29,  1972.

                33.   Pennsylvania Engineering Corporation.  Electric Arc Furnace
                     Pollution Control.   Pittsburgh.  Undated.  16 p.

                34.   Letter and attachment from Oakland, D., Whiting Corporation,  to
                     Georgieff,  N. T.,  EPA.  February 9, 1976.  Information on EAF
                     evacuation flow rates.

                35.   Telecon.  Andrews,  W., Wayne County Air Pollution Control Agency,
                     with Spawn,  P., GCA/Technology Division.   March 24, 1977.
                     Information on foundries in Detroit area.

                36.   U.S. Patent No. 3,791,638.   Metal  Pouring Organization.   Assigned to
                     ARMCo Steel  Corporation.   Middletown, Ohio.   February 12, 1974.

                37.   Watkins, E.  R.  and K. Darby.  The Application of Electrostatic
                     Precipitation to the Control of Fume in the Steel Industry.  In:
                     Fume Arrestment.  Special Report 83.  Report of the Proceedings
                     of the Autumn General Meeting of The Iron and Steel Institute held
                     at Church House, Great Smith Street SW1 on 26 and 27 November 1963.
                     London, England, Williams Lea and Company Limited.  1964.  p, 24-35.
                                                   4-56
-

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38.   Ito, S. ,  S.  Noso, M. Sakai, and K. Sakai.  Roof-Mounted Electro-
     static Precipitator.  In:  Symposium on the Transfer and Utilization
     of Particulate Control Technology.  Vol. 1.  Electrostatic
     Precipitators. U.S. Environmental Protection Agency.  Publication
     No. EPA-600/2-79-044a. February 1979.  p. 485-494.

39.   Telecon.   Tomita, S., Sumitomo Heavy Industries,  Ltd., with
     Maxwell,  W.  H., Midwest Research  Institute.  May  4, 1979.  Uses of
     roof-mounted ESP units.

40.   Arthur D. Little, Inc.  Steel and the Environment:  A Cost Impact
     Analysis.  A Report to the American Iron and Steel  Institute.
     Report No. C-76482.  May 1975.  p. IV-2 to IV-6.

41.   Memo from Spawn, P., GCA/Technology Division, to  EAF File.
     May 9, 1977.  Summary of telephone conversations  with fabric
     filter vendors.

42.   Whitehead, C.  Design and Operating Experience with Electrostatic
     Precipitators on Electric Arc Furnaces.  In:  Proceedings:  Parti-
     culate Collection Problems Using  ESP's  in the Metallurgical Industry.
     Feazel, C. E., (ed.).  Research Triangle Park, N.C., U.S. Environ-
     mental Protection Agency.  Publication  No. EPA-600/2-77-208.
     October 1977.  p. 23-39.

43.   Air Pollution Emission Test:  John Deere Tractor  Works, Waterloo,
     Iowa.  U.S. Environmental Protection Agency.  Research Triangle
     Park, N.C.  EMB  Report No. 75-GFE-l.  June 1974.

44.   Source Sampling:  John Deere Tractor Works,  East  Moline,  Illinois.
     U.S. Environmental  Protection Agency.   Research Triangle  Park, N.C.
     EMB Report No. 74-GFE-2.  July  1974.

45.  Air Pollution Emission Test:  The Gleason Works,  Rochester, New
     York.  U.S. Environmental Protection Agency.  Research Triangle
     Park, N.C.  EMB  Report No. 75-GFE-4.  January 1975. 85  p.

46.  Air Pollution Emission Test:  The Paxton-Mitchell Plant,  Omaha,
     Nebraska. U.S.  Environmental  Protection Agency.   Research Triangle
     Park, N.C.  EMB  Report No. 75-GFE-3.   February  1975.   173 p.

47.  Letter and  attachment from Hevey, L. A.,  State  of Wisconsin
     Department  of Natural  Resources,  to  Georgieff,  N. T.,  EPA.
     November 21,  1974.   Report of source test at Beloit Corporation,
     Beloit,  Wis.

48.   Letter and  attachment from Cropper,  W.  V.,  American Society  for
     Testing  and Materials,  to Ajax, R.  J.,  EPA.   June 27,  1974.
     Submission  of Draft D 2928 Report.
                                    4-57

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49.  Telecon.  Georgieff, N. T., EPA, to Bencus, H., The Gleason Works.
     February 20, 1980.  Information on carbon  injection via pressure
     lancing.

50.  Memo from McCarley, J. E., Jr., EPA, to Georgieff, N. T., EPA.
     December 3, 1974.  State  of Wisconsin Test Report, Beloit
     Corporation, Beloit, Wisconsin.

51.  Memo from Kelly, W. E., EPA, to Georgieff, N.  T., EPA.
     July 19, 1974. Gray iron  foundry data contained in
     ASTM D-2928 Report.

52.  Memo from McCarley, J. E., Jr., EPA, to Georgieff, N. T., EPA.
     July 19, 1974.  Gray iron  foundry test  ASTM D-2928 Report.

53.  Letter from Wasem, J. W.,  American Steel Foundries, to
     Goodwin, D. R., EPA.  June 18, 1976.  Response to Section 114  letter
     on emission test results.

54.  Allegheny County Health Department.  Source Test of Baghouse on
     Steel Electric Arc Furnace at Bucyrus-Erie, Glassport, Pennsylvania.
     Pittsburgh, Pennsylvania.  May 1975.

55.  Telecon.  Glenn, D., Buckeye Steel Casting Company, to
     Georgieff, N. T., EPA.  September 18, 1976.  Information on source
     tests at Buckeye Steel Casting Co.

56.  Telecon.  Welzel, K., Landesanstalt fur Immissions und
     Bodennutzungsschutz des Landes Nordrhein-Westfalen, to
     Georgieff, N. T., EPA.  June 10, 1976.  Information on source  test at
     German steel EAF.

57.  Letter and attachments from Welzel, K., Landesanstalt fur Immissions
     und Bodennutzungsschutz des Landes Nordrhein-Westfalen, to
     Georgieff, N. T., EPA.  June 16, 1976.  Information on source  tests
     at German steel EAF's.

58.  Letter from Rohrick, Thyssen Giesserei AG, to  Georgieff, N. T., EPA.
     June 24, 1976.  Information on source tests at German steel EAF's.

59.  Letter from Berton, D., Air Industrie, to  Georgieff, N. T., EPA.
     June 18, 1976.  Information on French foundry  EAF's.

60.  Letter from Bozzetti, M. A., Air Industrie, S.P.A., to
     Georgieff, N. T., EPA.  March 4, 1976.  Information on Italian
     foundry EAF's.

61.  Letter and attachments from Mitrick, S.  F., American Steel
     Foundries, to Goodwin, D.   R., EPA.  October 26, 1976.  Information
     on steel foundry EAF source tests.
                                   4-58

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62.   Memo and attachments from Shepherd, J. L. , Buckeye Steel Castings,
     to Georgieff, N. T., EPA.  December 11, 1979.  Information on steel
     foundry EAF source test.

63.   Memo from McCarley, J.  E. , Jr., EPA, to Cuffe, S. T., EPA.
     December 27, 1979.  Review of EAF foundry test reports.

64.   Memo and attachments from Harrison, R. T. and Holzschuh, D., EPA, to
     McCarley, J. E., Jr., EPA.  July 26, 1976.  Trip report of visible
     emission observations of an EAF at American Steel Foundry.

65.   Memo and attachments from Harrison, R. T. , EPA, to
     McCarley, J. E., Jr., EPA.  August 17, 1976.  Trip to observe
     visible emissions of a steel foundry EAF.

66.   Emission Test Report.  Armco Steel, Torrance, California.  U.S.
     Environmental Protection Agency.  Research Triangle  Park, N.C.
     EMB Report No.  79-ELC-6.  May 1979.
                                   4-59

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     5.   MODIFICATION AND RECONSTRUCTION OF IRON AND STEEL FOUNDRIES

     In accordance with Section 111  of the Clean Air Act,  as amended in
1977, standards of performance shall be established for a  list of
categories of stationary sources which may cause or contribute
significantly to air pollution.  These standards apply to  affected
facilities, i.e., those identifiable pieces of process equipment or
individual components which, taken together, would comprise a source that
emits pollutants for which a standard has been promulgated and the
construction, modification, or reconstruction of which commenced after
proposal of the standard.
     On December 16, 1975, EPA promulgated amendments (40  FR 58416) to
the general provisions of 40 CFR Part 60, including clarification of the
modification section and addition of a reconstruction section.  Under
these provisions, Sections 60.14 and 60.15 respectively, an "existing
facility" may become subject to standards of performance if.it is deemed
to have been modified or reconstructed.  An "existing facility" defined
in Section 60.2(aa) is any apparatus of the type for which a standard of
performance is promulgated and the construction, modification, or
reconstruction of which was commenced before the date of proposal of that
standard.
     This chapter examines the provisions for modification and
reconstruction and the applicability of these to electric arc furnaces
(EAF's) in the iron and steel  foundry industry, outlining conditions
under which existing facilities could become subject to standards of
performance.  It is important  to stress that standards of performance
apply to  affected facilities which, combined with existing and other
facilities, comprise a stationary source.  The addition of an affected
facility  to a stationary source through any mechanism (i.e., new
construction, modification, or reconstruction) does not make the entire
                                 5-1

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                stationary source subject to standards of performance,  but rather only
                the added affected facility.
                5.1  PROVISIONS FOR MODIFICATION AND RECONSTRUCTION
                5.1.1   Modification
                     Section 60.14 defines modification,  clarifies what constitutes  an
                emission rate increase and the methods for determining  the emission  rate
                increase, and confirms the individuality  of other emission sources within
                the stationary source.
                     Paragraph (e) of Section 60.14 lists certain physical  or operational
                changes that will not be considered as modifications, irrespective of any
                change in the emission rate.   These changes include:
                     1.   routine maintenance, repair,  and replacement;
                     2.   an increase in the production rate not requiring  a capital
                expenditure,  as defined in Section 60.2(bb),  or reqiuring  a capital
                expenditure which does not exceed the  guidelines provided  in IRS
                Publication 534 (Tax Information on Depreciation) and 40 FR 58416
                (Modification,  Notification,  and Reconstruction);
                     3.   an increase in the hours of operation;
                     4.   use of an alternative fuel  or raw material  if,  prior to  proposal
                of  the standard,  the existing facility was designed to  accommodate that
                alternate fuel  or raw material;
                     5.   the addition or use  of any system or device whose  primary function
                is  the reduction of air pollutants,  except when  an emission control
                system is removed or replaced by a system considered to  be  less
                environmentally beneficial; and
                     6.   relocation or an ownership  change.
                5.1.2   Reconstruction
                    Section  60.15 defines reconstruction and provides  for  EPA
                determination of reconstruction  if requested.  The reconstruction provi-
                sion  is  applicable only when  the components of an existing  facility  are
                replaced to such  an extent that  the  fixed capital  cost of the  new compo-
                nents  exceeds 50  percent of the  fixed  capital  cost required to construct
                a comparable, entirely  new facility  and it is  technologically  and
                economically  feasible for the facility to meet the applicable  standard.
_
                                                5-2

-------
The purpose of this provision is to ensure that an owner or operator does
not perpetuate an existing facility by replacing all but vestigial
components (e.g., support structures, frames, housings), rather than
totally replacing it, in order to avoid falling under the applicable
standards of performance.
5.2  APPLICABILITY TO ELECTRIC ARC FURNACES IN THE IRON AND STEEL FOUNDRY
     INDUSTRY
     For the purposes of this document, an electric arc furnace is
considered to include the following components:
      1.  furnace shell, including roof;
      2.  tilting platform;
      3.  furnace superstructure (arms, columns, electrode positioning
apparatus, roof elevating suspension beams);
      4.  roof lift and swing apparatus;
      5.  furnace tilting gear;
      6.  electric switch gear;
      7.  transformer;
      8.  secondary conductor system;
      9.  operator's control panel; and
     10.  dust handling system.
     Except as noted in Section 5.1.1, any physical or operational change
to any of these items that would result in an increase in the particulate
emission rate (emissions per hour) to the atmosphere could be considered
a modification.  Replacement of any single item would not appear to
constitute reconstruction although replacement or more than one item
could be considered reconstruction, depending on the costs involved.
     The enforcement division of the appropriate EPA regional office
should be contacted whenever a source has questions regarding modification
and reconstruction.
                                 5-3

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               6.   MODEL PLANTS AND REGULATORY ALTERNATIVES

6.1  INTRODUCTION
     Due to the large number of plant configurations and process operating
practices within the iron and steel foundry industry, it would be imprac-
tical to discuss each configuration with regard to emissions, environmental
impact, and economics.   For this reason, model plants will be used to
describe the general types of facilities that are expected to be constructed,
modified, or reconstructed within the industry in the future.  These
model plants do not necessarily represent any one specific facility but
are meant to encompass the range of possibilities.  The following sections
of this chapter define both the foundry electric arc furnace model
plants and the alternative methods to regulate emissions from processes
and sources in plants related to the iron and steel foundry industry.
6.2  MODEL PLANTS
     The production of iron and steel from foundries varies widely from
plant to plant even though the basic operations are similar.  Individual
facility production is primarily determined by operating time and capacity.
The plant capacity  is generally dependent upon the ability to cast the
molten metal rather than on the furnace capacity.  Demand for the product
and general economic conditions also affect production.
     Three model plant configurations are presented in Tables 6-1 and 6-2
that reflect the conditions currently found within the industry and those
expected to occur in the future.   The production  rates are based on the
use  of one of  three EAF sizes:  3.6 Mg/h (4 tons/h), 9.1 Mg/h (10 tons/h),
and  22.7 Mg/h  (25 tons/h)  (i.e., small, medium, and large furnaces,  respec-
tively).  Table 6-1 presents  data  common to both  iron  and steel foundries
relating to production, operating  hours, process  energy usage,  and  land
area requirements.  Table  6-2 presents  data for gas temperature,  exhaust
                                    6-1

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 air  flow,  and emission control  energy usage specific  to  the  control
 systems  expected to  be used.
      The model  plants  are  assumed to  be  capable  of casting either  iron  or
 steel.   The  exhaust  gas characteristics  are somewhat  different  for iron
 and  steel  and are described  in  detail  in Section 3.2.3.6.  The  nature of
 the  gas  is such that ductwork and gas  cleaning devices can be constructed
 of carbon  steel.   No emission control  systems are required for  process
 operation  or are routinely used specifically for product recovery  or
 safety.  The raw materials used and products manufactured are typical of
 those discussed in Chapter 3.   Water  is  used during EAF  process operations
 for  noncontact  cooling but is generally  recirculated  with no disposal
 problems.
 6.3   REGULATORY ALTERNATIVES
      The three  phases  of EAF  operation (charging,  melting and refining  in
 the  furnace,  and tapping)  have  been examined for standards development.
 These phases  are discussed in Chapters 3  and 4.   Approximately  90  percent
 of the EAF particulate emissions  are generated during the melting  and
 refining phase.   Techniques to  capture the  emissions  from melting  and
 refining in  the  furnace and to  remove the particulate from the captured
 gases have been  demonstrated.
      Various  techniques are used  at some plants  to  capture emissions from
 the  charging  and tapping phases of the EAF  operation.   These techniques
 include:   canopy hoods, building  evacuation  systems,  bay evacuation
 systems, total  furnace  enclosures, close capture  systems, and tapping pit
 enclosures.   Canopy  hoods  can capture emissions  effectively under  ideal
 conditions, but  their  performance is highly  dependent on shop conditions.
These hoods frequently achieve  a  relatively  low  capture efficiency because
 of the cross-drafts  typically present in most shops.  Also,  because of
the  relatively large gas flow volumes that must  be  handled (up to 20 times
the volume required  for capturing emissions  during melting and refining
 in the furnace), canopy hoods and any associated control  device equipment
 require  high energy  and sufficient physical  space.  These requirements
can  lead to capital  costs that are prohibitively high for the 3.6-Mg/h
 (4-ton/h)  and 9.1-Mg/h (10-ton/h) furnace sizes.1  In addition,  net
emissions to the atmosphere can increase if emissions  generated at the

                                .   6-4

-------
power plant are also considered for canopy hood installations on a
                           2
3.6-Mg/h (4-ton/h) furnace.   The performance of bay evacuation systems,
which are not used in domestic foundries, and building evacuation systems
is not affected by cross-drafts.  However, both of these systems may have
higher energy requirements than the canopy hood.  Thus, the same economic
and net emission problems can result for these systems as for the canopy
hood.   The performance of the only total EAF enclosure that was operational
at the time of this study was characterized by EPA.  The system did not
perform adequately during charging operations.  The emission capture
effectiveness was low, possibly as a result of several factors, one of
which is believed to be inadequate air flow through the system.  No
foundries utilizing the total close capture system were available for
observation.  A tapping pit enclosure is in use at one United States
foundry.  At this foundry, a relatively small amount of alloying is
performed in the ladle, and the performance of the system under a normal,
higher level of ladle alloying could not be determined.  None of these
techniques for the capture of charging and tapping emissions are considered
to be demonstrated, at this time, for the full range of furnace operating
conditions to be found in the industry.  Therefore, the proposed standards
apply only to the melting and refining phase of the EAF operation.
     Two regulatory alternatives are presented for EAF operation in
foundries.  These alternatives are discussed in this section along with
the control device systems that could be utilized to provide the required
level of control.  Table 6-3 presents the alternatives and the control
systems along with the allowable emission limits for each alternative.
6.3.1.  Regulatory Alternative No. 1
     This alternative provides for no additional regulatory action by
EPA.  The regulatory baseline would be relied upon to control emissions
from foundry EAF operations.  As noted in Section 3.3, only particulate
and visible emissions from the control device stack would be directly
controlled  by the typical  State regulation applicable to foundries.  This
typical regulation takes the form of a process weight equation coupled
with a  specified visible emission limit.  The trend of using side draft
hoods and direct furnace evacuation as emission capture devices for
melting and refining  operations and fabric filters as emission control
                                    6-5

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systems would continue.  A few new furnaces would be required to control
fugitive emissions under state regulations, a trend which is already
underway.
6.3.2  Regulatory Alternative No. 2
     This alternative, similar to Alternative No. 1, also would require
control of melting and refining (in the furnace) emissions only.  However,
the emission limit would be more stringent than that specified under the
baseline condition for both particulate and visible emissions.   Current
fabric filter technology, combined with proper maintenance practices, can
achieve lower emission limits than specified by State regulations.   The
use of the following systems would be expected to continue as suitable
systems for this alternative:
     1.  side draft hood and fabric filter (iron and small steel
foundries); or,
     2.  direct furnace evacuation and fabric filter (medium and large
steel foundries).
                                   6-7

-------
6.4  REFERENCES"FOR CHAPTER 6
1.




2.


3.
Georgieff, N. T. and F.  L. Bunyard.  An  Investigation of the Best
Systems of Emission Reduction for Electric Arc Furnaces in the Gray
Iron Foundry Industry.   U.S. Environmental Protection Agency, Research
Triangle Park, N.C.  October 1976.  Draft.

Memo from Maxwell, W., Midwest Research  Institute, to EAF Files.
March 21, 1980.  Calculation of canopy hood related emissions.

Memo from Maxwell, W., Midwest Research  Institute, to EAF Files.
March 21, 1980.  Calculations of building evacuation related
emissions.
                                 6-8

-------
                       7.0  ENVIRONMENTAL IMPACT

     The environmental  impacts of the two regulatory alternatives presented
in Chapter 6 are discussed below.   One alternative requires an NSPS for
electric arc furnace emissions during melting and refining; the
other is the existing baseline control condition, which includes typical
State regulations but no Federal regulations.
7.1  AIR POLLUTION IMPACT
     To assess the impact of standards of performance on air pollution,
the incremental reduction in air pollution beyond what would otherwise be
achieved by. the baseline case has been estimated.  The baseline case
assumes that the EAF's are subject to the process weight regulation (see
Sectfon 3.3):
               E = 4.10 P°'67      P S30
               E = 55.0 P°-1:l-40   P >30
     where  E = emission rate in Ib/h
     and    P = process weight rate in tons/h.
7.1.1  National Parti cul ate Emissions
     Particulate emissions can  be calculated using the following general
equation:

                     E = (I.e.
      where  E  = particulate  emissions,  in  tons/yr
            i  = index for plant size
            n  = number of furnaces  (from Table  8-2)
            e  = emission rate per furnace  (from Table  6-3),  in  Ib/h  per
                furnace
            H  = plant operating hours,  in  h/yr
        2,000  = conversion factor from  pounds to tons.
                                    7-1

-------
      Table 7-1 presents the projected particulate emissions for each
 regulatory alternative.  The increase in emissions from year 1 to year 5
 is a result of an approximate 20 percent increase in production, which is
 described in Chapter 8.
      As indicated in Table 7-1, the second regulatory alternative shows a
 51 to 53 percent reduction in total (including fugitive) emissions over
 the baseline regulatory alternative for iron and steel foundries, respec-
 tively.  The second alternative also provides approximately a 90 percent
 reduction over uncontrolled melting emissions.
 7.1.2  Dispersion Analysis
      Ground-level pollutant concentrations at specified locations downwind
 from three sizes, of electric arc furnaces at iron and steel foundries
 have been estimated using atmospheric dispersion modeling.1   A description
 of the model  used and the results obtained are  presented in the following
 subsections.
      7.1-2.1   Model  Description and Input Data.   The  model  used in this
 dispersion analysis  was the Industrial Source Complex (ISC) model.2  ISC
 is an expanded version  of the  single source (CRSTER)  model, modified  to
 account for aerodynamic downwash and a larger number  of sources and
 receptors.  Concentration  estimates were  made using ISCST,  the  hour-by-hour
 version of ISC,  for  a network  of receptors  at various downwind  distances
 from  a  model plant.
      The ISC model requires  input data on sources, receptors, and meteoro-
 logy.   These items are  described in the following subsections.
      7-1-2.1.1  Source  data.  Each  source configuration and control
 alternative for EAF's was assumed to consist  of one stack adjacent to a
 building.  Each stack was treated in this analysis as a point source
 emitting particulates on a continuous basis.  Fugitive emissions were
 also treated as a point source and  assumed to be emitted near the building
 and at rooftop elevation.  Each point source  (stack and fugitive) was
modeled separately in this analysis.
     In this modeling,  particulate  emissions were considered as gaseous
emissions, i.e., as though the particles  would not settle out.   Since
96 percent of the particles are smaller than 20 |jm (Section 3.2.2.6),  this
assumption should not affect the concentration estimates.
                                   7-2

-------
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     The following data are  required  by  the  ISC model for each  source:
     1.  emission height  (m);
     2.  exit diameter (m);
     3.  exit velocity (m/s);
     4.  exit temperature  (K); and
     5.  particulate emission rate  (g/s).
Table 7-2 summarizes the  source characteristics for each of the six model
plants and the two regulatory alternatives.
     Downwash effects are  also considered  in the ISC model.  As indicated
in Table 7-2, the source  emission heights  are comparable to the height of
adjacent structures (i.e., 10 m).   Emission gas streams, such as those
modeled (with low emission heights, low  exit velocities, and temperatures
close to ambient), have small plume rise and thus low effective emission
height.  These sources will  be affected  by aerodynamic downwash, resulting
in maximum concentration  impacts close to  the source.
     7.1.2.1.2  Meteorological data.  Meteorological data required by the
ISC model include hourly values (for  an  entire year) of:
     1.  ambient temperature (K);
     2.  wind speed (m/s);
     3.  wind direction (nearest 10 degrees); and
     4.  stability class.
Daily morning and afternoon mixing height  data are also required and
interpolated internally in the ISC model to hourly values.
     In this study, 1964 climatological data for Pittsburgh, Pennsylvania,
and Oklahoma City, Oklahoma, were used for comparison purposes.   Both
data sets are reasonably consistent with meteorological  conditions repre-
senting maximum or worst-case impact  for short stacks.   Maximum impacts
occur when the wind direction persists within a narrow angular sector and
moderate winds are predominant.
     Pittsburgh is characterized by roll ing-to-mountainous terrain,
strong-to-moderate wind speeds,  some persistent wind directions, neutral
stability,  and periods of calms.   Oklahoma City, on the other hand, is
located on relatively flat terrain.   The climatological  conditions are
characterized by very persistent wind directions,  moderate-to-high wind
speeds, neutral  stability, and few calms.
                                   7-4

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     Climatological data from 1964 were used because these data are
fairly complete on an hour-by-hour basis.   These data are considered to
be meteorologically representative although no claim can be made in terms
of Climatological normalcy.  The ISC model rejects days with questionable
wind directions (which are often associated with light winds).
     Finally, electric arc furnaces were assumed to be located in urban
areas, i.e., including heat island effect.
     7.1.2.1.3  Receptor data.  The ISC model calculates concentration
impacts for receptors at specified radial  distances from the source.
Receptors were located around each source at distances of 100, 300,
2,000, and 20,000 m at 10-degree intervals.  It was assumed that the
plant boundary was located 100 m from the nearest point source.  A network
of 216 other receptors was arranged around the plant at various distances.
These latter receptors were located as a result of a preliminary source
dispersion analysis which  identified potential maximum impact locations.
     All receptors were assumed to be at the same elevation as plant
grade.  The only terrain effects included in the modeling were those
implicitly contained in the meteorological data (Pittsburgh, Pennsylvania
and Oklahoma City, Oklahoma).
     7.1.2.2  Discussion of Dispersion Calculations.  Hourly concentration
impacts from each stack are calculated by the ISC model.  Concentrations
are summed for each receptor  and midnight-to-midnight averages are deter-
mined for each 24-hour period.  Annual arithmetic mean concentrations are
then calculated by the model  for each receptor.  Annual geometric means
are obtained using the relationship between the arithmetic mean (m), the
geometric mean (m ), the standard geometric deviation (s ), and by assuming
                 *^                             3                    •
the concentrations are lognormally distributed.   The relationship is:
                            _ 	m
                         mg ~ exp  (0.5  In*  s  )
The  standard  geometric deviations  are  estimated  from area-specific monitors
                                                                        45
from quarterly  and yearly  air  quality  data  statistics  for 1977 and 1978.  '
Site-to-site  and year-to-year  s  for particulates  range  from about 1.5 to
                               y

                                    7-6

-------
2.2.  In this study, s  was set equal to 1.8 for Oklahoma City and 1.72 for
                      y
Pittsburgh.
     Concentration estimates calculated by the ISC model are generally
within a factor of 2 of measured ambient concentrations, especially for
the uncomplicated conditions modeled here.
     The modeled concentration impacts can be compared to the National
Ambient Air Quality Standards (NAAQS):
                              Standard                  Particulate
                                type                concentration (ug/m3)
Averaging time
Annual geometric mean
                              Primary
                              Secondary
                                                             75
                                                             60
                              Primary
                              Secondary
                                                            260
                                                            150
24-hour maximum (not to
be exceeded more than
once per year)
     7.1.2.3  Twenty-Four Hour Maximum Concentration Impacts.   Maximum
24-hour (highest second-high) particulate concentration impacts are
presented in Tables 7-3 through 7-6 for Oklahoma City and Pittsburgh and
for the two regulatory alternatives.   The highest second-high concentrations
are specified for radial distances of 100, 300, 2,000, and 20,000 m.
The maximum highest second-high concentration is indicated for each case;
for all cases the maximum highest second-high occurred at 100 m downwind
from the source.  The concentration estimates for all cases are greater in
Oklahoma City than in Pittsburgh.
     The maximum 24-hour concentration impact (from the stack only) was
138 ug/m3 for baseline conditions and 5.5 ug/m3 for the second alternative.
This shows a significant reduction in concentration impacts of the second
alternative over the baseline alternative.  Maximum concentration impacts
from fugitive sources ranged from 27 to 332 ug/m3 at 100 m downwind from
the source.
     Weighted-average, 24-hour maximum concentration impacts (including
stack  and fugitive impacts) from new sources are given in Table 7-7.  The
reduction in  impact over baseline for the NSPS alternative was calculated to
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based  on the  proportion of small to medium to  large  new furnaces in year 5
after  NSPS promulgation, as  indicated in Table 7-1.
                                    7-7

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 TABLE 7-7.  SUMMARY OF 24-HOUR CONCENTRATION IMPACTS FROM NEW SOURCES3
24-hour maximum weighted average
concentration impact (uq/m3)
Location
Oklahoma City, Okla.

Pittsburgh, Pa.

Plant
type
Iron
Steel
Iron
Steel
Baseline
134
191
87
124
NSPS for melting
and refining only
86
108
52
66
Percent
reduction
in impact
over
baseline
36
43
40
47
Stack and fugitive concentration impact; year 5 after NSPS promulgation.
                                        7-12

-------
     7.1.2.4  Annual Geometric Mean Concentration Impacts.   Maximum annual
geometric mean concentrations are presented in Tables 7-8 through 7-11 for
Oklahoma City and Pittsburgh and for the two regulatory alternatives.
The maximum annual concentrations are specified for each radial distance
(100, 300, 2,000, and 20,000 m).  The maximum concentrations for each
case (without regard for distance) are also specified.  As in the 24-hour
concentration results, the concentration impacts are greater in Oklahoma
City than in Pittsburgh.
     The maximum annual concentration impact (from the stack only) is
20.8 ug/m3 for baseline conditions and 0.62 [jg/m3 for the second alterna-
tive.  Maximum concentration impacts from fugitive sources range from 2.3
to 50 ug/m3 at 100 m downwind from the source.
      Weighted-average, maximum annual concentration impacts (including
stack and fugitive impacts) from new sources are given in Table 7-12.
The reduction in impact over baseline for the second alternative was
calculated to be in the range of 30 to 43 percent.  The data in Table 7-12
were calculated assuming the proportion of small to medium to large new
furnaces in year 5 after NSPS promulgation given in Table 7-1.
7.2  WATER POLLUTION IMPACT
     It is  expected that fabric filters will continue to be the principal
method of EAF emission  control.  Water sprays may be used to cool the gas
stream before it enters a fabric filter or ESP, but when properly designed
                                                            fi
and  operated, these water sprays produce no water discharge.   However,
as noted  in Section 4.5, wet scrubbers could  be used to control particulate
emissions from EAF's.   The blowdown from the  scrubbers would require
treatment.
7.2.1  Volume of Wastewater
     Since EAF's  used  in iron and  steel foundries are similar  to those  used
in the steelmaking  industry, effluent volumes have been computed using  the
blowdown  rates recommended by EPA  for scrubbers utilized on EAF's in  the
steelmaking  industry.   The operation  of a well-controlled system calls  for
0.21-m3  blowdown  per  Mg (50  gal/ton)  of iron  or steel manufactured.
Although  many plants  may now use  larger quantities of water, this water
                                   7-13

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7-17

-------
                        TABLE 7-12.  SUMMARY OF ANNUAL GEOMETRIC MEAN CONCENTRATION
                                         IMPACTS FROM NEW SOURCES3

24-hour maximum weighted average
concentration impact (|jg/ro3)

Location
Oklahoma City, Okla.

Pittsburgh, Pa.

Plant
type
Iron
Steel
Iron
Steel

Baseline
18.5
28.0
6.15
9.43
NSPS for melting
and refining only
12.9
16.4
4.24
5.38
Percent
reduction
in impact
over
baseline
30
41
31
43
                 Stack and fugitive concentration impact; year 5 after NSPS promulgation.
                                                   ,7-18
_

-------
discharge rate is considered proper operation by EPA and has been used to
                                           o
set standards for the steel making industry.
7.2.2  Quality of Wastewater
     Slowdown could contain both dissolved and suspended pollutants.
Potential pollutants in the wastewater are listed in Table 7-13.   These
pollutants y/ill be present as suspended particulate matter and as dissolved
trace materials.
     Currently, the effluent limitations promulgated by EPA for effluent
from scrubbers on steel making EAF's apply only to total suspended solids
and pH when application of the best practicable control technology is to
            9
be utilized.   The scrubber effluent from an EAF in an iron or steel
foundry should be very similar.  Of the potential pollutants listed in
Table 7-13, only oil and grease, pH, suspended solids, and total  oxygen
demand (TOD) might need treatment.
     7.2.2.1  pH.  The pH of the scrubber effluent should be similar for
iron and steel EAF scrubbers because the EAF's utilize similar raw
materials.  It is not anticipated that treatment for pH will be required.
     7.2.2.2  Total Oxygen Demand (TOD).  Oil and grease, and hence total
                        ' &                   -
organic carbon (TOC), are potentially higher for the iron and steel
foundry EAF than the steel making EAF.  The charge in an iron or steel
foundry EAF may contain borings, turnings, and chips which are contaminated
with cutting oils.  Partial combustion of these oils produces soot and
vapor which may dissolve and increase the total oxygen demand of the
wastewater.  No data are available which indicate the biochemical oxygen
demand (BOD) or the TOD in a scrubber effluent from an EAF.  Even if
1 percent of the total carbon  content in the particulate  is soluble, the
total carbon content of the wastewater will be from 1.8 to 25 mg/£, which
would not require treatment.
     The presence of oils  and  grease in the  scrap is deleterious to
electric arc and other types of  furnaces and especially to the air
pollution control equipment.   To  avoid  problems, foundries are imposing
increasingly stringent specifications for the amount of oil permissible
in  scrap.   This  has  resulted in  more pretreatment and  cleaning of  scrap
by  the  suppliers.   Therefore,  the likelihood of  oil being found  in  scrubber
effluent from  EAF's  is diminishing.
                                   7-19

-------
TABLE 7-13.  CATEGORIES OF POLLUTANTS WHICH MIGHT BE FOUND
            IN AN EAF SCRUBBER SYSTEM EFFLUENT8
              Acidity
              Alkalinity
              Carbon and its compounds
              Color
              Fluorides
              "Hardness"
              Heat (temperatures above ambient)
              Iron and compounds
              Lead and compounds
              Mercury and compounds
              Nitrogen and compounds
              Oil and grease
              Phosphorus compounds
              Silica
              Sulfur compounds
              Solids (suspended and dissolved)
              Total oxygen demand
                             7-20

-------
     If an EAF were consistently charged with very oily scrap, such as
turnings from machining operations, then the scrubber effluent might
contain enough oily matter to require the use of an oil skimmer as part
of the water treatment facility.
     7.2.2.3  Total Suspended Solids (TSS).   Total suspended solids from
the scrubber effluent would be generated as shown in Table 7-14.  These
data are based on the emission limits provided in Table 6-3.  Normal   ;
scrubber efficiencies (i.e., in the range of 97-99 percent particulate
removal) could produce greater amounts of suspended solids than those
indicated.
7.2.3  Water Treatment
     The blowdown from scrubbers can be treated for removal of suspended
solids using a classifier followed by a clarifier and/or a magnetic
flocculator.  (Figure 7-1 is a simple schematic diagram of a proposed
treatment system.)  This system is recommended by EPA for use on the
scrubber effluent from steel making EAF's and is capable of reducing the
suspended solids to 50 mg/£, a removal efficiency of 99.8 percent.   The
blowdown is sent to a classifier from which solids are continuously removed
using a moving trowel or screw conveyor.  The solids are trucked to a land-
fill for disposal.  The liquid effluent from the classifier is sent to a
clarifier that utilizes polyelectrolytes to promote chemical  coagulation.
Sludge  is drawn  from the bottom of the clarification tank and is vacuum
filtered.   The dewatered sludge is disposed of with the classifier solids,
and  the water  is recycled  into  the clarifier.  If  further solids reduction
is required, the water effluent from  the clarifier can be discharged  to a
magnetic  flocculation tank.  This  step  is not likely to be  required when
chemical  coagulation  is  utilized.
7.2.4   Conclusions
      A wet  scrubber on an  EAF would  produce  about 0.21 m3/Mg  (50  gal/ton)
of wastewater  if operated  prudently.  Available  data  indicate that this
wastewater  would have a  pH of  approximately  8.0  and  a  TOC  content  of  less
than 25 mg/£.
      Treatment to  remove suspended solids would  be required before the
wastewater  could be discharged to  a receiving stream.  Water treatment
                                   7-21

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-------
technology for removal of suspended solids is well established.  "Best
practicable control technology currently available," as defined by EPA,
will reduce TSS to 50 mg/£, a 99.8 percent removal.   The incremental
increase in solids collection is shown in Table 7-14.
     The use of the above treatment would require disposal of approximately
6.9 kg of solids per Mg of iron (13.8 Ib/ton) and 8.0 kg of solids per Mg
of steel (15.9 Ib/ton).  These solids would be in the form of a high-solids
sludge containing up to 60 percent solids.  Disposal of this quantity of
sludge will not significantly increase the environmental impact above that
of the baseline conditions.  The sludge composition will be essentially the
same as that of the particulate generated, which would require disposal
regardless of the air pollution control technique employed.
7.3  SOLID WASTE DISPOSAL IMPACT
     When scrubbers, precipitators, or fabric filters are used to control
emissions from EAF's in iron or steel foundries, solid wastes, in the
form of dust or sludge, will be generated.
7.3.1  Quantity of Solid Waste
     The quantities of solid wastes that would be generated, based on the
regulatory alternatives and emission limits presented in Tables 6-3 and
7-1, are shown in Table 7-15.
7.3.2  Composition of Solid Waste
     Typical chemical analysis of electric arc furnace dust is given in
Section 3.2.  The major oxides are ferric oxide (Fe203) and silicon
dioxide (Si02).  There are also trace elements that may act as fluxes and
have an effect on the melting behavior of the material.
     When the provisions of the Resource Conservation and Recovery Act
(RCRA) are finalized, it is possible that EAF dust will be classified
as a toxic waste.  This classification results from the probability that
some of the trace metals present in the dust would fail the Teachability
test.  In the event that the dusts are clasified as toxic, the dusts
generated by both the first (baseline) and second alternatives would be
subject to the provisions of the RCRA.
7.3.3  Solid Waste Handling and Disposal
     Dust collected from foundries is usually placed in landfills.
Economic recycling of these iron-bearing dusts has not been demonstrated.

                                   7-24

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Should EAF dusts be classified as toxic under the provisions of RCRA,
landfilling the solid waste along with municipal wastes would not be
permitted.  The dust would have to be placed in disposal sites secured
for hazardous wastes.
      Improper handling and disposal of particulates collected from the
EAF can easily cause some reentrainment of dust to the atmosphere.  The
most  effective method for handling dust is a pelletizing operation which
practically eliminates reentrainment problems.  Dust from the baghouses
(or ESP's) can be emptied into sealed bags or containers which would also
serve to contain dusts at the disposal site.  Another option is to produce
a slurry by injecting water into the dust handling system.  Many foundries
will  probably continue to handle loose dust, usually transporting it by
truck to the disposal site.  Open-bodied trucks should have a cover
placed over the load, and vehicle speed should be limited to avoid losses
during transport.
      7.3.3.1  Recycling Potential for EAF Dust.  Dusts collected from
foundry EAF's contain significant amounts of iron oxides.  Recycle and
recovery operations for steelmaking dusts are under investigation, but
there are currently no commercial processes for recovering this material.
      7.3.3.2  Landfill Disposal.  Care in disposal of EAF dusts is necessary
because, as shown in Table 7-16, relatively high levels of trace elements,
including the toxic metals lead, cadmium, and arsenic, are often present.
These metals are present as metal oxides.  Some of these oxides are soluble
in pure water, and some are soluble in acidic solutions.  The solubility of
these compounds in acidic solutions may cause the dusts to fail the
Teachability test and thus be classified as toxic under the provisions of
the RCRA.
      Landfill site design for current practice must preclude horizontal or
vertical migration of these metals to surface or groundwaters.   The Safe
Drinking Water Act of 1974 provides for protection of potential drinking
water supplies and sets limits on the concentration of certain toxic metals.
Where geohydrological conditions do not provide reasonable protection
against leaching of these elements, technologies such as impervious liners
are needed.
11
                                   7-26

-------
TABLE 7-16.   TRACE METAL COMPONENTS OF BAGHOUSE HOPPER DUST11
                            (ppm)
    Lead
    Copper    (Cu)
    Zinc      (Zn)
    Potassium (K)
    Sodium
    Nickel
    Tin
    Titanium
    Lithium
    Chromium
(Na)
(Ni)
(Sn)
(Ti)
(Li)
(Cr)
    Zirconium (Zr) -
10,000
 8,000
 5,000
 5,000
 3,000
 1,500
   300
   300
  <300
   200
   200
Barium
Molybdenum
Cadmi urn
Arsenic
Boron
Vanadium
Cobalt
Antimony
Stronti urn
Silver
Beryllium
(Ba) - 200
(Mo) - 150
(Cd) - 100
(As) -<100
(B)  -  50
(V)  -  50
(Co) -  50
(Sb) - <50
(Sr) -  30
(Ag) -  10
(Be) -  <1
                            7-27

-------
                     When disposal is to a municipal landfill, dust must be segregated
                from municipal refuse.  As organic matter decomposes, acidic conditions
                develop and portions of the trace metals in the dust could possibly
                dissolve.  This would create the potential for leachate contamination of
                nearby waters.
                     Where wet scrubbers are used, scrubber wastewater should be contained
                in a settling pond and recirculated.  Protection of groundwaters and
                surface waters is essential, and the landfill disposal requirements for
                scrubber sludge are the same as those for dust.
                7.4  ENERGY IMPACT
                     Since fabric filters are projected as the control system of choice
                for both the baseline and NSPS alternatives, the incremental energy
                impact of the second alternative over the baseline will be negligible.
                7.5  OTHER ENVIRONMENTAL IMPACTS
                     No  increase  in noise levels over those existing under baseline
                control  is expected with the regulatory alternative.
                7.6  OTHER ENVIRONMENTAL CONCERNS
                     If  landfill ing is used as the solid waste disposal technique, an
                irreversible land commitment might be required.  The future usefulness of
                this land is dependent on the quantity and characteristics (chemical and
                physical) of the  solid waste material.  If toxic materials are present,
                the land may become unfit for agricultural and recreational use.  However,
                if the landfill site  is clay-lined, no irreversible impacts on the land
                should result from leaching of toxic materials.
                     When a venturi scrubber is employed as an emission control device,
                the blowdown wastewater must be disposed of.  Both the type of treatment
                used and the wastewater disposal method may result in irretrievable and
                irreversible natural  resource commitments.  Water treatment in the form
                of a pond or lagoon will prevent alternate use of the land involved.  The
                properties of the material pumpecMnto the pond or lagoon will have
                the greatest effect in determining future alternative applications of the
                area.  In most cases, ponds or lagoons are permanent installations.
                     A commitment of  land for disposal purposes would be required under
                the baseline alternative.  The incremental increase in the commitment
_
                                                    7-28

-------
would be the indeterminate extra amount required resulting from the
increased dust or sludge load generated under the second alternative.
                                  7-29

-------
7.7  REFERENCES FOR CHAPTER 7
 1.
 2.
 3.
 6.
 7.
 8.
 9.
 10.
 n.
Memo and attachments from Schewe, G. J. , EPA, to Cuffe, S., EPA.
September 11, 1979.  Air quality estimates of particulate emissions
from electric arc furnaces in the iron and steel foundry industry.

Bowers, J. F., J. R. Bjorklund, and C. S. Cheney.  Industrial Source
Complex (ISC) Dispersion Model User's Guide.  U.S. Environmental
Protection Agency, Research Triangle Park, N.C.  2 Vols.
EPA-450/4-79-030, 031.  December 1979.  Draft.

Larsen, R. I., A Mathematical Model for Relating Air Quality Measure-
ments to Air Quality Standards.  U.S. Environmental Protection  Agency.
Research Triangle Park, N.C.  Publication No. AP-89.  November  1971.
p. 9-10.
     Air Quality Data—1977 Annual Statistics.  U.S.
     Protection Agency, Research Triangle Park, N.C.
     No. EPA-450/2-78-040.  September  1978.

     Air Quality Data—1978 First Quarter Statistics.
     Protection Agency, Research Triangle Park, N.C.
     No. EPA-450/2-78-043.  November 1978.
                                                Environmental
                                                 EPA Report
                                                  U.S. Environmental
                                                  EPA  Report
Development Document for Effluent  Limitations Guidelines and  New
Source Performance Standards:   Iron and  Steel Foundry  Industry.
Draft Report.  U.S. Environmental  Protection Agency, Research
Triangle Park, N.C.  Contract  No.  68-01-1507.  July  1974.   p.  96-97.

Development Document for Effluent  Limitations Guidelines and  New
Source Performance Standards for the  Steel  Making  Segment  of  the  Iron
and Steel Manufacturing Point  Source  Category.   U.S. Environmental
Protection Agency.  EPA Report No. EPA-440/l-74-024a.   June 1974.
p. 352-357.

Georgieff, N. T.  Addendum  to  Standards  Support  and  Environmental
Impact for Electric Arc Furnaces in the  Steel Foundry  Industry.
U.S. Environmental Protection  Agency.  Research  Triangle Park,  N.C.
Unpublished.  December 1976.

U.S. Environmental Protection  Agency.  Code of Federal  Regulations.
Title 40, Chapter I, subchapter N, part  420.  Washington,  D.C.
Office of the Federal Register.  June 28,  1974.

Aleshin, E.  Utilization of Waste  By-Products.   In:  Transactions of
the American Foundrymen's Society.  Proceedings  of the Seventy-
Second Annual Meeting, April 29 to May 3,  1968.  Vol.  76.   Des
Plaines, 111., American Foundrymen's  Society.  1968.   p. 313-322.

Memo and attachments from Jungers, R.  H.,  EPA, to  Bibb, T., EPA.
September 26, 1975.  Gray iron foundry sample analysis.
                                    7-30

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                           8.  ECONOMIC IMPACT

8.1  INDUSTRY CHARACTERIZATION
     A brief description of the structure of the iron and steel foundry
industry has been presented in Section 3.1 of this document.  It is the
intent in this section to expand on some of the information that appears
in Section 3.1 and to establish the framework on which the economic
impact analysis (Section 8.4) is based.
8.1.1  General Profile
     8.1.1.1  Ferrous Castings Markets and Products.   Markets for ferrous
castings, which include iron castings (gray, ductile, and malleable) and
steel castings, are widespread and include almost all segments of the
economy.   The major industry users of castings [by Standard Industrial
Classification (SIC)] are summarized in Table 8-1.   Large amounts of iron
castings are used in almost all types of equipment, including motor
vehicles, farm machinery, construction machinery, petroleum production
and refining equipment, and iron-and-steel-industry equipment.
     Steel castings are classified on the basis of their composition and
heat treatment.  For instance, general purpose castings made of carbon
steel are the most widespread.  They are used in earthmoving machinery,
the automotive and transport industries, and agricultural and general
machine manufacture.  Heat-resistant castings, as the name implies, are
high-alloy steel castings used in high temperature environments (e.g.,
steam and gas turbines, jet aircraft, oil refining machinery, and nuclear
equipment).   Corrosion-resistant steel alloy castings find application in
the chemical industry.  Wear-resistant steel castings, made of alloy
steels, are versatile and are found on earthmoving machinery or shovel
tracks, tramway spiders, parts of railway switches, side plates of
crushers, pulverizers, and dipper brackets.
                                  8-1

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               TABLE 8-1.  END-USE DISTRIBUTION OF CASTINGS
                                                           1
                      SIC .
                      Codee
                         Industry
A.  Iron castings
B.  Steel castings
3714         Motor vehicle parts and accessories
3523         Farm machinery and equipment
3519         Internal combustion engines, nee.
3494         Valves and pipe fittings
3561,3       Pumps and compressors
3585         Refrigeration and heating equipment
3531         Construction machinery
3566         Power transmission equipment
3621         Motors and generators
3541         Machine tools, metal cutting types

3743         Railroad equipment
3531         Construction machinery
3714         Motor vehicle parts and accessories
3494         Valves and pipe fittings
3495         Wire springs
3559         Special industry machinery, nee.
3561, 3      Pumps and compressors
3728         Aircraft equipment, nee.
3711         Motor vehicles and car bodies
3533         Oil field machinery
aSIC = Standard  Industrial  Classification.
 Ranked by production  (highest  10  listed).
cnec. = not  elsewhere  classified.
                                    8-2

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     8.1.1.2   Plant Locations, Employment, and Structure.  In 1978 there
were 4,438..foundries of all types in the United States, including the
following:
               Number of foundries
                   1,400
                     590
                     107
                     631
                                                  Metal  cast
                                                  Gray iron
                                                  Ductile iron
                                                  Malleable iron
                                                  Steel
     Some of these foundries may cast other metals in addition to iron or
steel.  In 1978 there were 1,074 electric arc furnaces in operation
in 440 foundries of all types (e.g., iron, steel, nonferrous) in the
United States.  Other types of melting equipment may be used in addition
to the electric arc furnace at a foundry, and a foundry may have more
than one electric arc furnace.
     Incomplete data indicate that there were at least 371 electric arc
                                                           2
furnaces in use at gray and ductile iron foundries in 1973.   Table 8-2
presents data which indicates 396 electric arc furnaces were operational
                              3
in steel foundries in 1977-78.   Table 8-2 also contains data on the
total number of foundries, number of EAF's, and number of personnel at
steel foundries with EAF's.  The employment figures are estimates and
include all personnel working at the company or foundry.
     Industrywide data (includes non-EAF and nonferrous shops) for 1978
indicate an employment breakdown as follows:
               Number of employees
                   1,000+
                     500 - 999
                     250 - 499
                     100 - 249
                      50 - 99
                      20 - 49
                       1 - 19
                                                  Number of foundries
                                                             43
                                                             68
                                                            207
                                                            592
                                                            648
                                                          1,037
                                                          1,843
It is expected that ferrous EAF's will follow the same pattern, i.e.,  a-
large portion of the foundries having few employees.   Specific data
applicable only to ferrous EAF shops are not available.
                                  8-3

-------
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      Larger  iron  furnaces,  9  to  14  Mg/h  (10  to  15  tons/h),  are  usually
 located  in integrated  machinery  producing  plants.   Smaller  furnaces,  down
 to a  fraction  of  a  ton per  hour,  are  located  in  plants  that produce  either
 a limited variety of products  or  small quantities  of  speciality iron
 castings.  Small  furnaces are  usually  operated periodically;  large furnaces
 usually  are  operated in two shifts.  Industrywide,  the  ratio  between
 jobbing  and  captive foundries  is  approximately 3.5:1.   This  value is
 assumed  to hold for the iron  EAF  segment also.
      Almost  all facilities  that produce steel castings  are  jobber (i.e.,
 produce  castings  for sale to or use by other  companies) foundries.  Very
 few arc  furnaces  that  melt  steel  are part  of  integrated plants.  Smaller
 furnaces are located in plants that produce a limited variety of products
 or small quantities of special steel castings.   Small steel foundries
 operate  their  arc furnaces periodically; larger  foundries usually are
 operated in  two shifts.
      8.1.1-3   Market Competition.  Since the majority of ferrous facilities
 are jobber foundries,  competition for product markets is prevalent.
 Large (over  20 Mg/h) foundries compete with other large foundries for the
 same  markets.  For example, large pipe foundries will compete with other
 large pipe foundries for these markets; large foundries that produce
parts for motor vehicles will  compete with other large foundries producing
 similar castings even  though part of the large foundries are captive.
These very large foundries are generally fully automated and produce
 large numbers  of similar parts.  This repetitive production of  large
numbers of castings with automated equipment permits the large  foundries
to produce castings at a minimum cost.
     Medium-size foundries (7 to 20 Mg/h) generally produce a wider range
of casting designs and make fewer of each design than do the large
foundries.   Most medium-size foundries have some automated equipment for
making large numbers of castings but seldom will  make the same casting
design every day.   Medium-size foundries have a higher unit cost than do
large foundries.
     Smaller foundries must find markets that are unattractive to medium-
size or large foundries.  These markets for very small jobbing foundries
include replacement parts where only a few castings are needed,  castings
                                  8-7

-------
for customers that only need a few parts per month, and some very low
quality castings (e.g., counterweights or manhole covers) where very
little quality control is required.  The very small foundry cannot compete
with medium-size or large foundries for the casting markets of interest
to the larger foundries.
     A few small foundries compete with other small foundries for
speciality markets such as piano-plate castings or alloy-extrusion augers.
These small, specialty foundries generally are a part of a captive
operation and are not jobbing foundries.
     8.1.1.4  Product/Substitute Competition.  The various types of iron
castings (gray, ductile, and malleable) frequently compete with each
other, with steel and nonferrous castings, steel weldments, powdered-metal
parts, metal forgings and stampings, and plastics for the same markets.
The material of lowest initial cost may or may not be the one selected
for use.  Not only must a product meet the desired physical and mechanical
properties, but differences in machinability, weldability, performance in
service, service life, and the cost of repairs and downtime can have
marked effects on total cost during the life of the product.
     For medium- and large-size parts, gray and ductile iron generally
compete with each other and with steel castings.  Frequently, use of
either gray iron or ductile iron will result in a part at the lowest
cost.  Sometimes, when only a few parts of a given design are required,
weldments are more economical to use than castings.  Forgings may be
competitive for medium-size parts but not for large parts.
     Some castings, such as gray iron ingot molds and motor blocks, have
little or no competition whatsoever because no other material will perform
satisfactorily in that application.  Ingot molds are being replaced,
however, by a change in technology to the production of continuously cast
slabs and billets.  Some competition is being provided in the motor block
area by aluminum castings made in permanent molds.
     The rapid growth of ductile iron results from its replacement of
steel castings in many applications and, to a lesser extent, replacement
of gray and malleable iron castings.  Ductile iron soil pipe has become
very popular with municipalities because, unlike gray iron, ductile iron
can withstand some shifting of the soil without breaking.  Ductile iron
                                  8-8

-------
also has good resistance to soil  corrosion and is superior in that respect
to carbon steel.
8.1.2  Trends.
     Table 8-3 presents trend data (historic and projected) for casting
shipments, product value, employment, and balance of trade.
     8.1.2.1  Shipments.  In 1978, the ferrous castings industry shipped
16.85 million Mg (18.55 million tons).  This represented about a 5 percent
increase over the 1977 level.  Ferrous casting shipments in 1979 were
projected to rise 5 percent over the 1978 level, representing the fourth
                            4
consecutive annual increase.   Rising capital goods purchases by industry,
especially railroad equipment and industrial machinery of all kinds,
together with high-level automobile and truck output, were expected to
support increased casting production.
     Gray iron castings (including ductile iron) remain the major product
of ferrous foundries, comprising 85 percent of the 1977 output and about
                             4
81 percent of 1978 shipments.   Gray iron shipments in 1978 were about
11.7 million Mg (12.9 million tons), in addition to approximately
2.7 million Mg (3 million tons) of ductile iron.  Gray iron shipments in
1977 totaled 13.63 million Mg (15.03 million tons), in addition to
2.46 million Mg (2.71 million tons) of ductile iron.  In 1979, gray iron
shipments were forecast to reach 12.1 million Mg (13.4 million tons)
while ductile iron castings were also expected to gain, reaching, an
estimated 3.0 million Mg (3.3 million tons).  Malleable iron castings
shipments have been more stable as ductile iron preempts some markets.
Malleable iron shipments were expected to total 771,000 Mg (850,000 tons)
in 1978 and 798,000 Mg (880,000 tons) in 1979.  In 1977, production of
malleable iron castings totaled 752,700 Mg (829,700 tons).
     Steel castings shipments, buoyed by railroad car construction, were
especially active in 1979.  Orders for railroad car component castings
were largely on extended delivery terms with contracts quite frequently
                                                        4
covering the entire annual requirements of car builders.   Almost 50 percent
of the  1979 steel castings production was forecast for rail car uses com-
pared with 35 to 40 percent  in the years prior to 1979.  The probability
that railcar output would remain strong in 1979, coupled with improved
demands for machinery components, indicated continuing growth for steel
                                  8-9

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castings beyond the anticipated 1978 shipment level of 1.6 million Mg
(1.8 million tons).  Shipments of steel castings during 1979 were expected
                                           A
to reach 1.7 million Mg (1.9 million tons).    In 1977, these shipments
were reported at 1.56 million Mg (1.72 million tons).
     Production of ferrous castings is largely influenced by the general
economic climate, and, consequently, shipments from iron foundries decreased
from 16.4 million Mg (18.1 million tons) in 1973 to 13.9 million Mg
(15.3 million tons) in 1976.  Shipments of steel castings dropped slightly
from 1.71 million Mg (1.89 million tons) in 1973 to 1.63 million Mg
(1.80 million tons) for 1976.  Production of ferrous castings in 1976,
however, was substantially improved over 1975 due to an easing of material
shortages, increased demand by the automobile industry, and general
improvement of the economy.  Future demand for ferrous castings is considered
to be strong.  Many unknowns remain in proposed environmental and health
standards and the problem of generating capital to meet these responsibilities
is an important factor in the health of this industry.  Substantial
growth in modern, technologically advanced foundries is occurring which
has reduced the labor component of foundry cost to below 50 percent of
                           4
the total production costs.    New moldmaking processes will likely keep
castings competitive with other modes of fabrication for machinery parts.
     According to 1979 projections made by the Department of Commerce,
the market for ferrous castings is expected to grow at a faster rate in
the next 5 years than is the market for steel mill products, the industry's
                  4
largest component.   A growth rate of 3.5 percent per year may be realized,
reaching 20.3 million Mg (22.4 million tons) shipped in 1983.  The value  of
product shipments was predicted to rise at a faster rate, 8 percent per
year, and total $23 billion in 1983.  For the purposes of this profile,
employment in the ferrous castings industry was also projected to increase
at a rate of 3.5 percent per year.
     8.1.2.2  Prices/Product Values.  The higher volume of shipments
anticipated  in 1979 was expected to be shared, across the casting industry,
including the large foundries captive to other industries and small
independent  jobbing foundries, and by various types of cast iron and cast
steel products.  The value of shipment increases is expected to
                                  8-11

-------
substantially exceed the tonnage increases, however,  reflecting continuing
price increases for. cast products.   The value of ferrous castings shipments
is projected to rise 16 percent in 1979, compared to  an estimated 24 percent
increase in 1978.
     The value of industry shipments for ferrous castings in 1978 was
estimated at $14.16 billion, compared with $11.42 billion in 1977.  The
value of industry shipments includes the value of all products and services
sold by the ferrous castings industry (SIC 332).  The value of product
shipments (i.e., value of shipments of ferrous castings produced by all
industries) reached $11.75 billion in 1977, was expected to reach
$14.58 billion in 1978, and then rise to $16.95 billion by the end of
1979 (a 16 percent increase over 1978).
     The value of gray and ductile iron shipments in  1979 was forecast to
increase 15 percent to $12.4 billion, reflecting price increases in
                             4
addition to growth in volume.   A 7 percent tonnage gain was estimated
for 1978 with almost as large a gain forecast for 1979.  In dollar terms,
steel castings shipments were expected to rise more sharply, by 19 percent
                               A
in 1978 and 22 percent in 1979.   The average value of all product ship-
ments has increased from $356.90/Mg ($324.69/ton) in  1972, to $958.38/Mg
($869.43/ton) in 1979.  The compound annual rate of change from 1973 to
1978 in the value of product shipments has been 15.4  percent based on
                A
current dollars.
     8.1.2.3  Import/Export.  In 1978, the value of the combined exports
of gray, ductile, and malleable iron castings and of  steel castings was
2.1 percent of the value of all domestic shipments of ferrous castings
and the value for combined imports was 0.9 percent of the total value.
These percentages have changed very little over the past 10 years and are
not expected to significantly alter in the future.  Each year, export
shipments are usually about 2 percent of all shipments while import
totals are generally less than 1 percent.  The United States continues
to enjoy a positive balance of trade in ferrous castings of more than two
to one.  Current figures for castings exports are less precise than
formerly due to revised data gathering procedures and the fact that
measurement of trade must be approximated.  For example, trade volumes in
component parts for machinery, especially automobiles, and for
                                  8-12

-------
   *J^.,;?..
                         A - g
                           ^v&-
                           5 ,"•
construction end uses is considerable, particularly on the import side.
Much of this trade is reported as various machinery and not as castings;
thus, the impact on castings markets is not amenable to accurate measure-
ment.
     The compound annual rate of change during the period of 1973 through
1978 was 14 percent on the value of exports and 22.5 percent on the value
           4
of imports.    The trade balance favorable to the United States has widened
from $109 million in 1973 to $170 million in 1978.
     Major castings exporters to the United States are Canada, the Federal
Republic of Germany, Japan, France, the United Kingdom, and India.  In
order of dollar value, Canada exceeds the next two largest countries and
represents a third of the total value of imports of castings.   Canada is
also the largest export market for U.S. castings, followed by Mexico and
Western Europe.  In 1978, the value of foreign trade in castings, capable
of being measured, was estimated at less than 4 percent of the value
                                    n
of the domestic market for castings.
     The exportation and importation of ferrous castings at present are
small in volume and, therefore, have minor effects on the industry.  The
balance of trade in this industry is not expected to change drastically
even if economic conditions or government controls increase the cost of
producing castings in the United States.  Castings are different from
each other in form and complexity.  Speciality casting buyers often visit
the vendor to discuss the problems and arrange for sample castings to be
delivered.  After the samples are delivered, the design may be changed
one or more times to improve the product in which the castings are used.
The frequent monitoring of the casting design, casting scrap, and the
production of castings does not lend itself to long-distance negotiations.
     Some castings, such as pressure pipe, soil pipe, and malleable iron
pipe fittings, are fairly standard in design.  However, differences in
size because of the metric versus English units of measure make inter-
national trade difficult even for those items.
     Many castings, such as motor blocks and heads, brake drums, and ingot
molds, are made in large numbers and could be a part of international trade.
However, castings of these types have not been standardized, and each
                                  8-13

-------
company demands individual designs.  The freight on heavy ingot molds is
also a problem.
     Certain standard castings are imported in relatively large
quantities, including steel valves and valve bodies, pump cases and
related fittings, and large hydraulic turbine castings.   These castings
come primarily from the Far East where the production costs have been
reduced through mechanization and high efficiency.
     Under present conditions, long lead times of up to a year or more
are required between the placement of an order for castings and the
receipt of the first production castings.  These slow deliveries are even
slower when castings must be shipped long distances, and this is another
factor that tends to discourage foreign trade.  (Even when foundry pro-
duction is low, lead times of about six months are required.)  These
various factors encourage a close geographical location of casting producers
and customers and tend to limit international trade.
     8.1.2.4  Facility Projections.  The projected demand will be met by
a combination of existing unused capacity and by construction of new
facilities.  Only 73 percent of available capacity was used in 1976, and
current plans for new equipment will increase foundry capacity by 18 percent
by 1981.   Although demand for castings is subject to cyclic swings, iron
is expected to account for a majority (85 percent) of ferrous metal
castings in the future.
     According to a survey of foundrymen made during 1977, 71 percent of
the industry was planning some type of capital improvement in 1978.
Those plans included new plants, plant additions, and new equipment.
Overall, 4 percent of the industry planned new facilities.  Plant
additions ranged from none (malleable foundries) to 29 percent for steel
foundries.  In new equipment considerations during 1978, 65 percent
(steel) to 81 percent (ductile iron) of producers reported plans for new
equipment purchases.  Melting equipment led the list of equipment plans.
     New installations of electric arc furnaces at foundries have increased
steadily over recent years.  In fact, the growth of arc melting in the
foundry industry has been dramatic in the 1970's—doubling in 7 years—and
it is anticipated that this momentum will continue into 1983.  In 1970,
capacity of iron and steel electric furnaces was 3.2 million Mg (3.5 million
                                  8-14

-------
tons).   By 1983, it is estimated that the capacity will be 8.3 million Mg
(9.2 million tons).8  The estimated year-end EAF capacity for the period
1976 to 1983 is presented in Table 8-4.   No projections are available beyond
1983.  The capacity figures will be larger than the shipment figures as a
result of the production of foundry returns and defective castings.
     For new installations, arc furnaces are somewhat more common than
the traditional cupola because of improved metallurgical control, reliable
energy sources, and relative ease of air pollution control.  Escalating
electricity costs, coupled with improvements in the design and operation
of the cupola, suggest that a significant percentage of iron will continue
to be melted in this type of furnace.
     By nearly a two-to-one margin, capacity expansion of EAF facilities
in the last 5 years resulted from adding furnace units to existing shops
rather than by building new shops.  Information on capacity expansion,
provided by one source, is presented in Table 8-5.  The expansion trend
of adding furnaces to existing shops is expected to continue.
8.2  COST ANALYSIS OF CONTROL OPTIONS
     In this section, the estimated capital and annualized costs are
presented for the control systems, model plants, and regulatory alterna-
tives outlined  in Chapter 6.  The costs for retrofitting the control
systems to modified/reconstructed facilities outlined  in Chapter 5 have
not  been determined since the likelihood of modification or reconstruction
is considered  remote.
8.2.1  Introduction
     The model  plants and control options  have been described in Chapter 6.
The  model plant parameters  are  summarized  in Tables 8-6 and 8-7.  These
tables provide  the  information  on unit  size, production, energy  usage,
and  flow rate  necessary  for the  subsequent cost analyses.
     The regulatory alternatives  and associated emission levels  are presented
in Table 8-8.   The  first alternative (baseline) provides for  no  additional
regulatory  action by  EPA,  but relies on the typical State  regulation  (pre-
sented  in Section 3.3) to  control emissions from  foundry EAF  operations.
The  second  alternative would  utilize the  same  control  equipment  as would be
                                   8-15

-------
TABLE 8-4.  ESTIMATED YEAR-END FOUNDRY
     ELECTRIC ARC FURNACE CAPACITY8
        [106 Mg (TO6 tons)]

Year
1976
1977
1978
1979
1980
1981
1982
1983
Iron
3.0 (3.3)
3.4 (3.7)
3.5 (3.9)
3.5 (3.9)
3.6 (4.0)
3.8 (4.2)
4.1 (4.5)
4.2 (4.6)
Steel
3.0 (3.3)
3.2 (3.5)
3.4 (3.7)
3.4 (3.8)
3.6 (4.0)
3.9 (4.3)
4.1 (4.5)
4.2 (4.6)
Total
6.0 (6.6)
6.6 (7,2)
6.9 (7.6)
6.9 (7.7)
7.2 (8.0)
7.7 (8.5)
8.2 (9.0)
8.4 (9.2)
                 8-16

-------
     TABLE 8-5.  EXPANSIONS IN ELECTRIC ARC FURNACE FACILITIES
                                                              8

Furnace ' ' ',

1
2
3
4
5
6
7
8
9
10
11
12
13
14
Number

2
1
3
1
3
1
1
1
1
1
1
2
1
3
Size
Mg
9.1
5.4
18.1
9.1
18.1
45.4
13.6
13.6
45.4
40.8
4.5
31.8
27.2
22.7
a
ton
10
6
20
10
20
50
15
15
50
45
5
35
30
25
Year of
startup
1975
1975
1976
1976
1977
1977
1977
1977
1977
1978
1979
1980
1980
1981
Type of expansion
New iron foundry
New steel foundry
Expansion - iron
Expansion - steel
New steel foundry
Expansion - steel
Expansion - steel
Expansion - steel
Expansion - steel
New iron foundry
Expansion - steel
Expansion - steel
Expansion - steel
New steel foundry
Foundry capacity is recorded in tons of castings shipped and not in
terms of molten iron or steel produced.  Therefore, it is not
possible to give a typical size of melting furnaces in terms
of production rate.
                                8-17

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-------
used to meet the baseline alternative but would have a more stringent
emission limit.
     The capture and control equipment, assumed for both regulatory
alternatives, is a side draft hood and fabric filter for all size iron
EAF's and small  steel EAF's and direct furnace evacuation and fabric
filter for medium and large steel EAF's (Section 4.3).   The only economic
differences assumed between the two regulatory alternatives are more fre-
quent bag replacement for the second alternative over that performed for
the baseline alternative and continuous monitoring of the control device
exhaust gas opacity for the second alternative.  All costs are given in
first quarter 1979 dollars.
8.2.2  New Facilities
     This section presents the cost estimates associated with new EAF
foundry construction.  Unless noted otherwise, the cost data have been
updated from previous documents using either the Chemical Engineering
(CE) plant cost index or the Marshall and Swift (M&S) equipment cost
index.
     8.2.2.1  Capital Costs.  Table 8-9 presents the capital cost estimates
for the two regulatory alternatives.  Since the control equipment is the
same for both alternatives, the only incremental cost increase is incurred
through the use of continuous opacity monitors for the second alternative.
These costs were updated from Reference 10 using the M&S equipment cost
index and corrected for size using the ratios of the air flow rates.
Information for the capital costs was originally developed through EPA
contractor studies and files and also from contacts with foundry operators,
equipment vendors, and design engineering firms.
     These estimates include the cost of designing, purchasing, and
installing the capture systems, control devices, and continuous monitors.
They include costs for both major and auxiliary equipment, rearrangement
or removal of existing equipment, site preparation, equipment installation,
and design engineering.  Specific items that are included are control
hardware, fans, ductwork, stacks (where required), dust handling equipment,
storage, taxes, freight, engineering, supervision, labor, vendor overhead,
performance acceptance tests, and startup costs.  The capital costs
                                  8-21

-------
      TABLE 8-9.   CAPITAL COST ESTIMATES FOR REGULATORY ALTERNATIVES
                               (103 dollars)

Capital cost
Furnace
Mg/h
3.6
9.1
22.7
size
tons/h
4
10
25
Basel ine
Iron
233. 2b
531. 5b
l,179.5b

Steel
233. 2b
179. 6C
356. lc
NSPS
Iron
251. 2b
550. 5b
l,199.5b

Steel
251. 2b
198.6°
376.1°
 1979 dollars.
b';
 Side draft hood and baghouse.
 Direct furnace evacuation
                                   8-22

-------
range from 14 to 23 percent of the total facility costs presented in
Section 8.2.2.4.
     8.2.2.2  Annualized Costs.  Table 8-10 presents the annualized cost
estimates for the two regulatory alternatives.  The annualized costs consist
of the sum of the fixed costs (capital charges, taxes, insurance) and the
annual operating expenses.  The only incremental cost increase realized
through the use of the second alternative over the baseline alternative
results from the increased bag replacement required to meet the more strin-
gent emission limit of the second alternative and the continuous monitoring.
     The capital charges have been calculated on the basis of 100 percent
debt financing and recovery of capital by uniform periodic payments
[capital recovery factor (CRF)].  The useful life for all equipment has
been assumed as 15 years.  A 10 percent interest rate was assumed.  The
property taxes, insurance, general, and administrative costs were based
on 4 percent of the total capital requirement or approximately 6 percent
of the installed equipment cost.  The labor cost was based on 0.4 person-
year/year and $15.00 per labor hour.  Maintenance costs were based on
1.0 percent of the total capital requirement or 1.5 percent of the installed
equipment cost.  Energy costs were assumed to be 4
-------











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8-24

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TABLE 8-11.  MARGINAL COST EFFECTIVENESS OF THE SECOND ALTERNATIVE'

Cost effectiveness
Furnace size
Mg/h tons/h
3.6 4
9.1 10
22.7 25
1*1979 dollars.
Annuali zed dollars
Based on operating
Iron
$/Mg ($/ton)
1,962 (1,776)
1,384 (1,270)
932 (840)
per incremental unit weight
hours from Table 8-6 and emi

$/Mg
1,962
778
489
parti cul ate
ssions from
Steel
($/ton)
(1,776)
(711)
(446)
removed.
Table 8-8.
                                 8-25

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            TABLE 8-12.   BASE COST OF INSTALLING
             ELECTRIC ARC FURNACES IN FOUNDRIES'

Furnace size
Mg/h tons/h
3.6 4
9.1 10
22.7 25
Base cost
(10b dollars)
1 . 772
2.658
5.170
*1979  dollars.
                                   8-26

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arc furnaces as the primary melting unit in a foundry and are assumed to
be valid for either iron or steel production.   The costs include the arc
furnace(s), electrical transformers, charging equipment, holding furnace(s),
spare parts, and air pollution control.equipment (for baseline level of
control).  Equipment and installation costs are included in the total.
8.3  OTHER COST CONSIDERATIONS
     This section summarizes the impacts currently being imposed on the
iron and steel foundry industry in general and the electric arc furnace
affected facility in particular as a result of other environmental regula-
tory actions (water, solid waste, and occupational health).  The impact
of the regulatory alternatives on the cost to the industry of compliance
testing and the resource requirements of local, State, and regional
regulatory and enforcement agencies is also addressed.
8.3.1  Water Pollution Regulations
     Water effluents from foundry operations come from four basic
           12
operations.    These are:
     1.  melting (cooling and gas cleaning);
     2.  molding (gas cleaning);
     3..  casting cleaning (gas cleaning and cast rinsing); and
     4.  heat treating (quenching).
     Of these sources, only the melting source is directly attributable
to the EAF.  Any cooling water systems used for EAF door, electrode
glands,  roof ring, or transformer systems are usually either once-through
or closed  recirculating systems.  The water discharge is of a quality
equal to the input stream but of a  somewhat higher temperature.  Water
sprays may be used to cool the gas  stream prior to the control device,
but when properly designed and operated, there is no  aqueous discharge.
If a wet scrubber is  used as the control device, a water pollution  impact
could be generated, but  scrubbers are not recommended for  use on  EAF's.
Thus, the  use of an EAF will not increase the water treatment load  of a
foundry, nor will there  be any incremental  increase over baseline as  a
result of  the  second  alternative.
      In  order  for a typical foundry (272 Mg/d, 300 tons/d) to meet  the
proposed 1983 water quality standards for all  of  its  effluent streams, an
energy consumption  increase of 43  MJ/Mg  (12 kWh/ton)  of metal produced
12
                                   8-27

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                   12
has been estimated.    Compared to the EAF furnace process energy consump-
tion presented in Chapter 6 (2,085 MJ/Mg, 525 kWh/ton), this value is
inconsequential and would have no effect on the ability of an EAF foundry
to meet the second alternative.
8.3.2  Solid Waste Regulations
     EAF wastes do not currently fall under the provisions of the Resource
Conservation and Recovery Act (RCRA).  Thus, solid waste restrictions do
not impact on the ability of an EAF foundry to meet the second alternative.
As noted in Section 7.3, however, when the provisions of RCRA are finalized,
EAF dusts may be classified as toxic.  The current practice of landfill ing
EAF dusts is expected to continue until such time as a toxic waste
determination under RCRA is made.  The only cost increase due to the
second alternative will result from the increased quantities of dust which
will be generated.
     At this time, the costs associated with compliance with the provisions
of RCRA can only be estimated.  The costs for toxic waste handling and
disposal range from $15 to $70 per Mg ($13.60 to $63.50 per ton),
                                       13
depending on the toxicity of the waste.    Based on these costs, the hauling
and disposal costs for the additional dust created by the second alter-
native would range from $235 to $1,095 per plant per year for the 9.1-Mg/h
(10-ton/h) model plant, a maximum annualized cost increase of 0.02 percent.
These costs have not been included in the impact analyses of Section 8.4
because the RCRA provisions do not yet apply to this industry.
8.3.3  Environmental Health Regulations
     No data were obtained regarding the cost to a foundry of compliance
with the Occupational Safety and Health Administration Act (OSHA).  Since
the same control equipment is forecast for use under the second alterna-
tive as under the baseline condition, no incremental cost impact is
expected as a result of the second alternative.
8.3.4  Compliance Test Costs and Regulatory Agency Resource Requirements
     The cost borne by the EAF foundry for the compliance testing of a
new facility would be approximately $10,000 for a set of three particulate
and visible emission tests per control device.
     The facility is responsible for making application to the State for
a permit to construct and subsequently operate a new installation.  The
                                  8-28

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review of these applications, and any later enforcement action, would be
handled by local, State, or regional regulatory agencies.  Since it is
assumed that only 10 EAF units per year will become affected facilities
through 1983, that these plants will be distributed through the United
States instead of clustered in one State, and that they will be added in
States already having foundry facilities, the promulgation of standards
for this affected facility should not impose major resource requirements
on the regulatory agencies.
8.4  ECONOMIC IMPACT OF REGULATORY ALTERNATIVES
8.4.1  Introduction
     This section analyzes the economic impact of the second regulatory
alternative which controls melting and refining emissions emanating from
electric arc furnaces in the ferrous foundry industry.
     The States presently have emission regulations which control partic-
ulate source emissions on the basis of process weight and/or visibility;
some States even have regulations specific to electric melting or foundry
facilities.  It has been assumed in this study that all model plant iron
EAF's and the small (3.6-Mg/h) model plant steel EAF's would have installed
a side draft hood with baghouse to meet existing State regulations in the
absence of any Federal regulation.   Similarly, it has been assumed that
the medium and large (9.1-Mg/h, 22.7-Mg/h) model plant steel EAF's would
have a direct furnace evacuation system with a baghouse operating to
control melting and refining emissions.   It is further assumed that the
second alternative can be achieved with the same control equipment required
for compliance with State regulations.   The additional Federal requirements
over those of the States would be better maintenance of the control
device and continuous monitoring of the opacity of the control device
exhaust gas.
     Therefore, the purpose of this section is to identify the incremental
costs and impacts that would be imposed on the foundry industry and the
economy by the second alternative above those already imposed by States'
emission standards.  Since Federal  standards for water effluents and OSHA
health and safety requirements are not expected to have an impact on new
sources, the full impact of Federal standards on arc furnaces will be the
                                  8-29

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incremental costs of those required air pollution controls that are more
stringent than State regulatory requirements.
     Section 8.4.2 will address potential impacts of the second alternative
on foundries in regard to profitability and competition from within the
industry and from imports.  Any impacts on consumers due to increased
product prices will be discussed in Section 8.4.3.  Section 8.4.4 will
present a dicussion of impacts on employment.   Finally, Section 8.4.5
will cover the impacts of the regulation spanning the 5-year period after
promulgation.
8.4.2  Impact on Foundries
     The immediate economic impact of the second alternative would fall
on newly constructed ferrous foundries with electric arc furnaces.  The
impact would most likely  be small because the proposed alternative requires
minimal capital expenditures over the baseline case, and only slight
increases  in operation and maintenance (O&M) expenses.  Furthermore,
foundries  probably would  not absorb the  full increase in costs and, instead,
would pass part or all of the costs on to the consumer.  A discussion
of potential impacts of the second alternative regulation on foundries
regarding  profitability,  shifts in competitive advantage within the
industry,  and imports will be presented  below.
     8.4.2.1  Profitability.  In this section, the profitability of the
model plants that would be affected by the second alternative is examined
in comparison with the profitability of  existing  sources.  The determination
of profitability requires information on the cost structure of.the model
plants chosen to depict the industry infrastructure.  Based on 1979 sales
and  cost data, an  income  statement was constructed and relevant financial
ratios calculated  for  each baseline model plant  in iron and steel foundries.
Development  of the sales  and cost figures is discussed below.
     In this analysis  all dollar figures were adjusted to reflect first
quarter 1979 dollars.  Since the cost data were  presented in first quarter
1979 dollars, no adjustment of  these figures was  necessary.  The  price
data,  however, which were provided  in  1978 dollars, were  inflated upward
by  the producer  price  index for foundry  and forge shop products.
     Sales data  were determined for each model plant  by multiplying the
average casting  price  in  dollars per megagram  (refer  to Section 8.1,
                                   8-30

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Table 8-3, which gives average casting price) by megagrams of shipments
per year.   Megagrams of shipments per year were calculated for each model
plant (Table 8-6) by multiplying the megagrams melted per hour by hours
per year by the yield of marketable castings of the annual melt rate,
assumed to be 60 percent.  Cost of goods sold, operating expenses, and all
other expenses were estimated through the percent of sales data given in
Reference 14. Total assets were" calculated by applying the sales/assets
ratios in Reference 14 to the sales figures.  Finally, the profitability
ratio for return on assets was calculated for the baseline model plants,
i.e., those existing plants that have met State emission regulations but
would not yet have incurred the costs required by the second alternative.
     A second set of profitability calculations was generated for model
plants required to comply with the second alternative.  In order to
evaluate the worst possible impact on the foundries, it is assumed that
all costs are absorbed by the foundries.  Thus, the balance sheet for the
manufacturer reflects unchanged sales figures with an increase in the cost
of goods sold due to incremental operating and maintenance costs.  As a
result of cost absorption, profitability decreases for those foundries
affected by the second alternative under this worst-case scenario.
     Tables 8-13, 8-14, and 8-15 show the profitability percentages of
the model plants for the baseline and second alternative and the percent-
age, reduction in profitability resulting from the second alternative.
The impact on profitability is slight for all the model plants.  The
largest impact falls on the small (3.6-Mg/h) foundry, which undergoes a
reduction in profitability after taxes from 6.0 percent to 5.4 percent,
or a 9.6 percent decrease.  The least affected facility is the large
(22.7-Mg/h) steel foundry, in which aftertax profits decrease 1.0 percent
below the baseline alternative.
     The above analysis is not intended to show that profitability would
decrease by the amounts calculated in Tables 8-14 and 8-15.  These calcu-
lations instead indicate the maximum profitability impact that new
foundries would experience relative to existing sources.  It is  likely
that some small new foundries competing with small existing foundries
will absorb at least a portion of the costs of the second alternative to
remain competitive, and likewise for medium and large-si zed foundries.
                                  8-31

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      TABLE 8-13.   DERIVED  INCOME STATEMENT AND BALANCE SHEET DATA
                         FOR BASELINE MODEL PLANTS3

Furnace size (Mg/h)

Shipments (Mg/yr)
Income statement
Sales ($943.0/Mg)b
Cost of goods soldc
Gross profit
Operating expenses
Operating profit
All other expenses
Profit before taxes
Profit after taxes6
Balance sheet
Sales/total assets ratio
Total assets^
Percent profit before taxes/
total assets
Percent profit after taxes/
total assets
3.6
3,460
$3,263,000
2,522,000
741,000
626,000
115,000
-7,000
122,000
85,000
2.31
$1,413,000
8.6
6.0
9.1
10,480
$9,883,000
7,758,000
2,125,000
1,443,000
682,000
119,000
563,000
323,000
2.00
$4,942,000
11.4
6.5
22.7
38,140
$35,966,000
29,312,000
6,654,000
4,028,000
2,626,000
396,000
2,230,000
1,223,000
1.51
$23,819,000
9.4
5.1
*A11 dollars are in first quarter 1979 dollars.
 Sales determined by multiplying average casting price in dollars per mega-
 gram times megagrams of shipments per year.   Shipments are calculated by
 multiplying the operating rates (Mg/yr) from Table 8-6 by the yield
 of 60 percent.
 Cost of goods sold determined from percent of sales data found in
 Reference 14.  Each model plant is identified with one of the three asset
 size categories in Reference 14 based on volume of sales.  The percentages
 associated with that category are applied to the sales figures, which were
 derived externally for each model plant.
                                   8-32

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       TABLE 8-13.   DERIVED INCOME STATEMENT AND BALANCE SHEET DATA
                         FOR BASELINE MODEL PLANTS3
                                (concluded)
 Operating expenses and all other expenses determined by percent of sales
 method.   Percentages for each model plant are obtained from Reference 14
 as described above in footnote ,c.
 Taxes calculated at following rates:   first $25,000—17 percent;
 second $25,000--20 percent; third $25,000--30 percent;
ffourth $25,000--40 percent; over $100,000—46 percent.15
 Sales/assets ratios for each model plant were calculated from the sales
 and assets figures in the appropriate asset-size category in Reference 14.
 See footnote c above.
^Total assets calculated by dividing sales by sales/assets ratios.
                                   8-33

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    TABLE 8-14.  PROFITABILITY IMPACT ANALYSIS FOR IRON MODEL PLANTS
              MEETING REQUIREMENTS OF SECOND ALTERNATIVE*>u
Furnace size (Mg/h)

Shipments (Mg/yr)
Income statement
Sales
Cost of goods soldc
Gross profit
Operating expenses
Operating profit
All other expenses
Profit before taxes
Profit after taxes
Balance sheet
Total assets
Percent profit before taxes/
3.6
3,460
$3,263,000
2,535,500
727,500
626,000
101,500
-7,000
108,500
77,800
$1,431,000
7.6
9.1
10,480
$9,883,000
7,779,100
2,103,900
1,443,000
660,900
119,000
541,900
312,000
$4,961,000
10.9
22.7
38,140
$35,966,000
29,348,000
6,618,000
4,028,000
2,590,000
396,000
2,194,000
1,204,000
$23,839,000
9.2
  total  assets
Percent profit after taxes/
total assets
Percent reduction in retugn
on assets (after taxes)
5.4
9.6
6.3
3.8
5.0
1.6
?A11 dollars are in first quarter 1979 dollars.
 See footnotes in Table 8-13 for explanation of how numbers were derived.
°Cost of goods sold for the second alternative are equal to cost of goods
 sold in the baseline case plus the incremental  annualized costs of
 pollution control devices to meet the second alternative.  Incremental
 costs for the.3.6-Mg/h (4-ton/h) iron foundry equal $13,500; for the
 9.1-Mg/h (10-ton/h) iron foundry, $21,100; and for the 22.7-Mg/h (25-ton/h)
 iron foundry, $36,000.  Refer to Table 8-10 for breakdown of cost figures.
                                   8-34

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     TABLE 8-14.   PROFITABILITY IMPACT ANALYSIS FOR IRON MOI
               MEETING REQUIREMENTS OF SECOND ALTERNATIVEa'C
                                (concluded)
'EL PLANTS
 Assets for the second alternative increase by the amount of the capital
 costs of the continuous opacity monitors.  These costs for the 3.6 Mg/h
 iron foundry equal $18,000; for the 9.1 Mg/h iron foundry, $19,000; and
gfor the 22.7 Mg/h iron foundry, $20,000.
 Calculations were carried out retaining three significant digits in
"percent profits after taxes/total assets."
                                    8-35

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     TABLE  8-15.   PROFITABILITY IMPACT ANALYSIS  FOR  STEEL MODEL PLANTS
               MEETING REQUIREMENTS  OF SECOND  ALTERNATIVE3'

Furnace size (Mg/h)

Shipments (Mg/yr)
Income statement
Sales
Cost of goods soldc
Gross profit
Operating expenses
Operating profit
All other expenses
Profit before taxes
Profit after taxes
Balance sheet
Total assets
Percent profit before taxes/
3.6
3,460
$3,263,000
2,535,500
727,500
626,000
101,500
-7,000
108,500
77,800
$1,431,000
7.6
9.1
10,480
$9,883,000
7,770,700
2,112,300
1,443,000
669,300
119,000
550,300
316,000
$4,961,000
11.1
22.7
38,140
$35,966,000
29,331,100
6,632,900
4,028,000
2,604,900
396,000
2,208,900
1,212,000
$23,839,000
9.3
  total assets
Percent profit after taxes/
total assets
Percent reduction in rgturn on
assets (after taxes)
5.4
9.6
6.4
2.6
5.1
1.0
?A11 dollars are in first quarter 1979 dollars.
 See footnotes in Table 8-13 for explanation of how numbers were derived.
°Costs of goods sold for the second alternative equal the baseline costs
 plus the incremental costs resulting from the second alternative.
 Incremental annualized costs for the 3.6-Mg/h (4-ton/h) steel foundry are
 $13,500; for the 9.1-Mg/h (10-ton/h) steel foundry, $12,700; for the
 22.7-Mg/h (25-ton/h) steel foundry, $21,100.
                                   8-36

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     TABLE 8-15.   PROFITABILITY IMPACT ANALYSIS FOR STEEL MODEL PLANTS
               MEETING REQUIREMENTS OF SECOND ALTERNATIVE3'D
                                (concluded)
 Assets for the second alternative increase by the amount of the capital
 costs of the continuous opacity monitors.   These costs for the 3.6 Mg/h
 steel foundry equal $18,000; for the 9.1-Mg/h steel foundry, $19,000;
gand for the 22.7-Mg/h steel foundry, $20,000.
 Calculations were carried out retaining three significant digits in
 "percent profits after tax/total assets."
                                    8-37

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                                     16
However, the facts that many foundries have specialized markets, that the
industry is near capacity, and that demand for castings exhibits price
inelasticity all support the hypothesis that foundries may be able to
pass some costs through to the consumer.
     Foundries produce a wide variety of castings, many of which are de-
signed specifically to a customer's needs.  For those castings which are
unique, producers may be able to mark up casting prices and thereby pass
the incremental pollutions costs on to the consumer.  Cost passthrough
may also occur when the foundry industry is at or near full capacity.  A
survey of foundrymen indicated that foundries were operating at about
82 percent of capacity in 1978, a figure that comes close to the 85 to
90 percent at which most foundries feel they are at a realistic maximum.
Lastly, passthrough of costs may occur where demand for a product is
fairly  inelastic, since price increases will not result in a loss of
revenue.  Castings in the aggregate appear to be price inelastic for
consumers of castings as measured against the producer price index.  This
is supported by the fact that castings prices during the last several
years have been rising faster than the producer price index.  Along with
higher  prices, volumes of shipments have been increasing.
     In the absence of additional data, such as demand elasticities for
castings, it can  only be concluded that the model plants under  the second
alternative would suffer profit  losses  anywhere between 0 percent (full cost
passthrough) and  9 percent  (full cost absorption  in the small-size iron
foundry model plant).
     8.4.2.2  Shifts  in Competitive Advantage Within the Foundry  Industry.
Since the magnitude of the  cost  increases  imposed by the second alternative
are  so  small,  it  is not expected that any discernable  shifts  in competitive
advantage  among foundries would  occur.   Furthermore, differences  in
castings products and the production  methods to create the  castings  have
resulted  in market  segmentation,  limiting at the  outset competition  among
foundries  of  differing  sizes.
      Large foundries  with standardized,  highly mechanized production
methods can  operate profitably only with  large volumes of  orders.   Unit
production costs  are  low  on large-scale production, predominantly
 reflecting melting  costs.   Pattern  and  mold costs are  low  because of
8-38

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standardized patterns and automated machinery capable of high output.
Small foundries, on the other hand, are less capital and more labor
intensive.   These foundries produce specialty castings made to specific
buyer needs.  For small volume orders of specialty castings, the cost is
strongly influenced by the cost of core and mold making, with much of the
cost resulting from the specialized experience of individual foundrymen
to produce a casting more or less handmade according to specifications.
     Because of the differences in production methods, large jobbing
foundries for the most part compete with large foundries.   Similarly,
small jobbing foundries compete with small foundries.  However, small
foundries may compete with a larger foundry for certain orders, where the
cost structure becomes marginal for the large foundry.  Any limited
competition that exists as such may be reduced since the small iron and
steel foundries face higher percentage cost increases due to the second
alternative than do the large size foundries.   As indicated earlier, any
shifts in competitive advantage toward the large foundries would be
slight.
     The last issue to be addressed here is whether or not the incre-
mental costs of the second alternative would lead to delays in plant
construction.  It can be concluded that any firm which is able to raise
the capital to build a new facility would also be able to finance the
incremental costs of the second alternative.  First of all, there would
be minimal capital requirements resulting from the second alternative.
Based on data for the six model plants, the cost of the continuous opacity
monitors would comprise one percent or less of the base cost of installing
electric arc furnaces in a foundry.  Secondly, the O&M costs of the
second alternative would represent a small fraction of total operating
costs of the model plants studied.  Calculations show that the annual
incremental O&M costs due to the second alternative range from a low of
0.4 percent to a high of 1.7 percent of the total operating expenses in the
six model plants.  Since the cost requirements of the second alternative
involve only minimal capital expenditures and operating costs, no delay
in plant construction will result should the second alternative be adopted.
     8.4.2.3  Imports.  In 1978 exports of iron and steel castings were
2 percent of the value of all  domestic shipments of ferrous castings,
                                  8-39

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and imports were 1 percent of that value, as stated in Section 8.1.2.3.
These percentages have stayed relatively constant over the past 10 years.
Although the importation of castings is small in volume and the balance
of trade in castings is favorable to the U.S., some imported castings may
have an impact on domestic foundries.  For instance, 34 percent of U.S.
purchased cast steel valves were imported in 1977.    A sampling of steel
foundry sales executives in 1978 revealed that respondents had lost sales
to importers for such castings as valve bodies, pump cases and related
                                               18
fittings, and large hydraulic turbine castings.    According to the
foundry executives, foundries have lost out to imports because of price
differentials, with foreign competitors undercutting domestic producers'
                                       18
bid prices by an average of 30 percent.
     The imported castings are predominantly standardized, large volume
production castings coming from Japan and other Far East nations, where
costs of production have been reduced through mechanization and high
efficiency.  Few specialty castings  are imported because casting designs
are frequently changed following delivery of samples to the buyer.
Frequent monitoring of casting design, casting scrap, and the production
of castings tends to limit international trade and instead encourage a
close geographical  location of specialty casting producers and buyers.
     Import competition will continue to exist regardless of enactment of
Federal regulations.  The second alternative,  however, should lead neither
to increased imports nor profitability impacts on domestic foundries from
import competition.
     Imported castings, as discussed above,  are large production,
standardized castings which would compete with domestic castings produced
in large foundries, typified in this analysis  by  the 22.7-Mg/h model
plant.  It  is in  the large foundries that the  incremental costs of the
second alternative  begin to disappear; they become  a very small fraction
of total operating  costs.  The costs of  the second  alternative comprise
0.8 percent of operating expenses in the 22.7-Mg/h  iron foundry model
plant and  0.4 percent of operating  expenses in the  22.7-Mg/h  steel foundry
model plant.  These costs, if  incurred,  would  represent less  than  a
2 percent  reduction in  return  on  assets  for both  model plants.
                                   8-40

-------
     It is assumed that a new foundry would be more highly automated and
more efficient than the older foundries, thus resulting in lower costs
per unit of output.  Lower costs translated into lower prices should
serve to dampen imports.   The slight increase in production costs resulting
from the second alternative would be insignificant in comparison with
savings accrued from building a new plant.
8.4.3  Impact on Product Prices
     Due to the second alternative, consumers could be impacted by higher
prices as foundries partially or fully pass the costs of pollution control
on to the consumer.  A worst case analysis, which assumes full passthrough
of costs, is used here to demonstrate the maximum degree to which consumers
would be impacted.   The method for determining these price increases and
a discussion of the significance of the increases is given below.
     In Table 8-13, income statements were constructed for each baseline
model plant in iron and steel foundries based on externally calculated
sales values, which were then multiplied by percent of sales data found
in Reference 13.  The baseline alternative assumes that the model plants
have sufficient pollution controls to meet the baseline State regulations
but that the plants have not yet incurred the expenses of the second
alternative.
     In Tables 8-16 and 8-17, new sales figures are calculated which
reflect the level of sales required for foundries to obtain their baseline
return on investment.  In these tables, profits after tax are first
determined from the baseline assets and return and investment figures.
Profit after tax and total costs under the second alternative are summed
to determine sales.  The new sales figures, divided by shipments, yield
the average castings prices that foundries would charge customers under a
full cost passthrough scenario.  By comparing prices under the baseline
and second alternatives, the cost passthrough and percent price increases
are then calculated.
     In order to determine the price of castings for the baseline case
against which to measure the price increases resulting from the second
alternative, an average castings price ($/Mg) for the industry was
calculated.  This method was chosen because pricing information on
individual castings  is unavailable.  The average price in first quarter
                                  8-41

-------
         TABLE 8-16.   PRICE IMPACT ANALYSIS FOR IRON MODEL PLANTS
               MEETING REQUIREMENTS OF SECOND ALTERNATIVE*

Shipments (Mg/yr)
Furnace size (Mg/h)
3.6 9.1
3,460 10,480

22.7
38,140
Income statement

  Sales ($943.00/Mg)b         $3,277,850
  Total costsc        .         3,154,500
  Profit before taxes"           123,350
  Profit after taxes              85,860

Balance sheets

  Total assets                $1,431,000
  Percent profit before           8.6
    taxes/total assets
  Percent profit after            6.0
    taxes/total assets
$9,902,600
 9,341,100
   561,520
   322,470
$4,961,000
    11.4

     6.5
$35,987,800
 33,772,000
  2,215,810
  1,215,790
$23,839,000
    9.4

    5.1
Price after NSPS
Cost passthrough
Percent price increase
$


947.
4.
0.
40
40
47
$


944.
1.
0.
90
90
20
$


943.
0.
.
60
60
f\/*
06
aAll dollars are in first quarter 1979 dollars.
 The sales figures calculated reflect the required level of sales for the
 plant to retain its baseline return on investment.  Sales are calculated
 by summing total costs and profit before taxes.
cTotal costs include the costs of goods sold, operating expenses, and all
 other expenses, as determined for the second alternative.  Refer to
 Table 8-14 for cost figures.
aProfit before tax is  back-calculated after profit after tax is
 eProfit  after  tax  is  calculated  by multiplying total assets by the return
 fon  investment (percent  profit after  taxes/total assets).
 Total assets  are  derived  in  Table 8-14, while percent profit before
 taxes/total assets and  percent  profit  after  taxes/total assets are
 derived in Table  8-13.
                                    8-42

-------
         TABLE 8-17.  PRICE IMPACT ANALYSIS FOR STEEL MODEL PLANTS
                MEETING REQUIREMENTS OF SECOND ALTERNATIVE9
                                  3.6
                                           Furnace size (Mg/h)
           9.
              22.7
Shipments (Mg/yr)
3,460
10,480
38,140
Income statement

  Sales ($943.00/Mg)b         $3,277,850     $9,894,220
  Total costs         .         3,154,500      9,332,700
  Profit before taxes            123,350        561,520
  Profit after taxes6             85,860        322,470

Balance sheets

  Total assets                $1,431,000     $4,961,000
  Percent profit before           8.6            11.4
    taxes/total assets
  Percent profit after            6.0             6.5
    taxes/total assets
                           $35,970,000
                            33,755,000
                             2,215,800
                             1,215,790
                           $23,839,000
                               9.4

                               5.1
Price after NSPS
Cost passthrough
Percent price increase
$


947.
4.
0.
40
40
47
$


944.
1.
0.
90
10
12
$


943.
0.
0.
10
10
01
bAll dollars are in first quarter 1979 dollars.
 The sales figures calculated reflect the required level of sales for the
 plant to retain its baseline return on investment.   Sales are calculated
cby summing total costs and profit before taxes.
 Total costs include the costs of goods sold, operating expenses, and all
 other expenses, as determined for the second alternative.  Refer to
dTable 8-15 for cost figures.
 Profit before tax is back-calculated after profit after tax is
 determined.
 Profit after tax is calculated by multiplying total  assets by the return
fon investment (percent profit after taxes/total  assets).
 Total assets are derived in Table 8-15, while percent profit before
 taxes/total assets and percent profit after taxes/total assets are
 derived in Table 8-13.
                                   8-43

-------
1979 dollars ($943.01/Mg or $855.3/ton) was calculated by dividing 1978
total industry value of shipments by volume of shipments and adjusting
the figure upward to reflect first quarter 1979 dollars.
     In actuality, product pricing is negotiated on a per piece basis
rather than a cents per pound basis for good castings (i.e., the material
the customer receives rather than the metal poured).   The unit price
will be dependent upon the volume of an individual order, the requirements
for the core and mold, and the desired precision and quality of the
casting itself.  For unique castings produced predominately in small jobber
foundries, the price will be highly sensitive to the cost of pattern, core,
and mold preparation.  For large production and standardized molds and
cores, the price of castings may not be much more than the melting cost.
This is the case in assembly line production foundries or in captive
foundries.  Therefore, the average castings price per ton calculated above
may be understated for specialty castings and overstated for large volume,
standardized castings.
     Returning to the income statement and balance sheet items, calcula-
tions show that under full cost passthrough prices would rise a minimum
of 0.01 percent in the large-size steel foundry and a maximum of
0.47 percent in the small iron and steel foundries.  These percentage
increases are insignificant, especially when compared against the producer
price index for iron and steel products, which rose from 230.4 in 1977 to
253.6 in 1978.19"25
8.4.4  Employment
     The proposed alternative for the iron and steel foundry industry
would have no effect on employment within the industry because it is
assumed that there will be no delay in plant construction as a result of
the alternative.
8.5  POTENTIAL SOCIOECONOMIC IMPACTS
     The purpose of this section is to review the fifth year impacts that
would arise under the second alternative and to determine if any of the
criteria for a regulatory (significant action) analysis are triggered.
     Summarized below are the aggregate economic impacts which would
occur 5 years after the NSPS is imposed, including total annualized
costs, inflationary impact on the price of castings, and changes in

                                  8-44

-------
energy consumption.  Annualized costs of the second alternative in the
fifth year would be no greater than $3.5 million, which represents the
costs of incremental capital and operations and maintenance expenses.
Total industry annualized costs for the year 1983 were determined by
multiplying the number of new plants expected to come on line in the next
5 years by the annualized costs per plant.  It was assumed here under a
worst-case hypothesis that  all new plants would be the small 3.6-Mg/h
foundries since these foundries have the highest annualized costs as a
percentage of total costs.  The expected increase in capacity for the
industry between 1978 and 1983 (see Table 8-4) is divided by the megagrams
per year capacity for the 3.6-Mg/h foundries (see Table 8-6) to obtain
the estimated number of new plants.  This figure is multiplied by the
increased costs ($13,500/yr) that would be incurred by the small foundries
as a result of the second alternative.
     The potential price increase in the fifth year would be $0.17/Mg,
which is a 0.02 percent over the average castings price in the first
quarter of 1977.   The dollar per megagram increase is calculated by
dividing the 5-year annualized cost figure given above by the projected
volume of shipments in 1983.  This calculation gives dollar per megagram
increases resulting from the second alternative affecting new sources
coming on line within the next 5 years.
     Energy consumption in the foundry industry would not be affected by
the second alternative.   This is because the additional requirements of
the second alternative over the baseline,  better maintenance and continuous
monitoring,  would result in a negligible energy usage change over the
baseline level.
     The issues covered in Section 8.4 demonstrate that no macroeconomic
or socioeconomic impacts will result from the proposed alternative.
Likewise, as indicated below, no significant action analysis will  be
required.  The criteria which would trigger a significant action analysis
are enumerated below:
     1.   Additional annualized costs of compliance totaling $100 million
within 5 years of implementation of the NSPS.
     2.   Additional production costs exceeding 5 percent of the selling
price of the product.
                                  8-45

-------
     3.  Net national energy consumption increasing by the equivalent
of 25,000 barrels of oil per day.
     None of the these guidelines will be exceeded as a result of the
second alternative.  Annualized costs of compliance over the 5-year
period would only rise to $3.5 million, additional productions costs
would be considerably under 1 percent of the selling price of castings,
and national energy consumption would remain the same.
                                  8-46

-------
 8.6  REFERENCES FOR CHAPTER 8
  1.


  2.




  3.
 7.


 8.



 9.

10.
11.
12.
 Foundry Management and Technology.  Metal Casting  Industry
 Census Guide, 1979 edition.  Cleveland.  April 1979.  54 p.

 Davis, J.  A.  E. E. Fletcher, R. L. Wenk, and A. R. Elsea.  Screening
 btudy- on Cupolas and Electric Furnaces in Gray Iron Foundries
 Final Report.  U.S. Environmental Protection Agency  Research'
 Triangle Park, N.C.  Contract No. 68-01-0611, Task No. 8.  August 1975.

 Steel Founders'  Society of America.  Directory of Steel Foundries in
 the United States,  Canada, and Mexico, 1977-78.   Rocky River, Ohio.
 1977.  274 p.
  4.   1979  U.S.  Industrial  Outlook.   U.S.  Department of Commerce,
      Industry  and Trade  Administration.   Washington,  D.C.   January 1979.


  5.   The Foundry  Industry—A  Look Ahead.   Foundry Management and
      Technology,   p.  38-48.   January 1978.
     Gaultier, M.
     65(9):46-47.
               Have You Been to the Market Lately.
               September 1976.
Modern Casting.
 Foundrymen  Forecast  9.1% Increase.   Foundry Management and
 Technology,  p.  32.   January 1978.

 Letter  from Eliason,  C.  R.,  Union  Carbide  Corporation, Carbide
 Products Division, to Maxwell,  W.  H.,  Midwest Research Institute.
 April 18, 1979.   Response  to questionnaire on foundry EAF units.

 Economic Indicators.   Chemical  Engineering.   86(14):7.   July 2,  1979.

 Fennelly, P. F.  and  P. D.  Spawn.   Air  Pollutant  Control  Techniques
 for Electric Arc Furnaces  in the Iron  and  Steel  Foundry  Industry
 U.S. Environmental Protection Agency,  Research Triangle  Park  N  C
 Publication No.  EPA-450/2-78-024.   (OAQPS  No.  1.2-099).   June 1978.
 215 p.                                         --....

 Davis, J. A., C.  S.  DuMont,  E.  E.  Fletcher,  and  A.  R.  Elsea.
 Economic Impact  of the Proposed New-Source-Performance Standards Upon
 Construction of  Arc  Furnaces  in the Gray Iron Foundry Industry.
 Final Report.  U.S.  Environmental  Protection Agency,  Research
 Triangle Park, N.C.   Contract No.  68-02-1323, Task  No 28
 August 1975.  p.  8-36 to 8-41.

 Development Document  for Effluent  Limitations Guidelines  and
 New Source Performance Standards:  Iron and Steel Foundry
 Industry.  Draft  Report.   U.S.  Environmental Protection Agency
 Research Triangle Park, N.C.  Contract No.  68-01-1507  July  1974
p. 71-72, 96-97,  132, 139.
                                 8-47

-------
13.   Memo and attachment from Pahl,  D.A., EPA, to the Files.
     March 13, 1980.  Basis for estimation of hazardous waste hauling
     and disposal costs.

14.   '78 Annual Statement Studies.  Robert Morris Associates.
     Philadelphia, Pa.  1978. p. 76.

15.   United States Congress.-  Internal  Revenue Code.  Income, Estate and
     Gift Tax Provisions.  Chicago, 111.  Commerce Clearing House, Inc.
     January, 1979.  p. XIV.

16.   Late News.  Foundry Management and Technology, p. 9. January 1979.

17.   Imported Castings:  A Status Report.  Foundry Management and
     Technology,  p. 26-32.  December  1977.

18.   Steelmen Measure  Inroads by  Imports.  American Metal Market.
     p.  10A.  April 21,  1978.
19.
20.
 21.
 22.
 23.
 24.
 25.
Statistical Abstract of the United States:  1978.  99th Annual
Edition.  U.S. Department of Commerce.  Bureau of the Census.
Washington, D.C.  September 1978.  p. 486.

Producer Prices and Price Indexes.  Data for May 1978.
U.S. Department of Labor.  Bureau of  Labor Statistics.
Washington, D.C.  July 1978.  p. 33.

Producer Prices and Price Indexes.  Data for June 1978.
U.S. Department of Labor.  Bureau of  Labor Statistics.
Washington, D.C.  August 1978.   p. 38.

Producer Prices and Price Indexes.  Data for July 1978.
U.S. Department of Labor.  Bureau of  Labor Statistics.
Washington, D.C.  October 1978.  p. 38.

Producer Prices and Price Indexes.  Data  for September  1978.
U.S. Department of Labor.  Bureau of  Labor Statistics.
Washington D.C.   November 1978.  p. 34.

Producer Prices and Price Indexes.  Data  for November 1978.
U.S. Department of Labor.  Bureau of  Labor Statistics.
Washington, D.C.  January 1979.  p.  34.

Producer Prices and Price Indexes.   Data  for January 1979.
U.S. Department of Labor.   Bureau of  Labor Statistics.
Washington, D.C.  March  1979.   p. 37.
                                  8-48

-------
                   APPENDIX A



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                              APPENDIX B
             INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS

     This appendix consists of a reference system, cross-indexed with
the October 21, 1974, Federal Register (39 FR 37419) containing the Agency
guidelines concerning the preparation of environmental impact statements.
This index can be used to identify sections of the document which contain
data and information germane to any portion of the Federal  Register
guidelines.
                                   B-l

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          TABLE B-l.  CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
                 ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
                                      Location within the Background
                                         Information Document
1.
BACKGROUND AND SUMMARY OF
REGULATORY ALTERNATIVES

Summary of regulatory alternatives
    Statutory basis for proposing
    standards
    Relationship to other regulatory
    agency actions
    Industry affected by the
    regulatory alternatives
     Specific  processes  affected  by
     the  regulatory  alternatives
 2.   REGULATORY ALTERNATIVES

     Control  techniques
The regulatory alternatives from
which standards will be chosen
for proposal are summarized
in Chapter 1, Section 1.1.

The statutory basis for proposing
standards is summarized in
Chapter 2, Section 2.1.

The relationships between the
regulatory agency actions are
summarized in Chapter 8,
Section 8.3.

A discussion of the industry
affected by the regulatory
alternatives is presented in
Chapter 3, Section 3.1.  Further
details covering the business
and economic nature of the
industry are presented in
Chapter 8, Section 8.1.

The specific processes and
facilities affected by the
regulatory alternatives are
summarized in Chapter 1,
Section 1.1.  A detailed technical
discussion of the processes
affected by  the regulatory
alternatives is presented  in
Chapter 3, Section  3.2.
                                       The  alternative  control  techniques
                                       are  discussed  in Chapter 4,
                                       Sections  4.2,  4.3,  and 4.4.
                                    B-2

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          TABLE B-l.  CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
                 ENVIRONMENTAL  IMPACT PORTIONS OF THE DOCUMENT
                                 (concluded)
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419)
                                      Location within the Background
                                           Information Document
    Regulatory alternatives
3.
ENVIRONMENTAL IMPACT OF THE
REGULATORY ALTERNATIVES

Primary impacts directly
attributable to the regulatory
alternatives
    Secondary or induced impacts
4.  OTHER CONSIDERATIONS
                                      The various regulatory alterna-
                                      tives, including "no additional
                                      regulatory action," are defined
                                      in Chapter 6, Section 6.3.   A
                                      summary of the major alternatives
                                      considered is included in
                                      Chapter 1, Section 1.3.
The primary impacts on mass
emissions and ambient air quality
due to the alternative control
systems are discussed in
Chapter 7, Sections 7.1, 7.2, 7.3,
7.4, and 7.5.   A matrix
summarizing the environmental
impacts is included in Chapter 1.

Secondary impacts for the various
regulatory alternatives are
discussed in Chapter 7,
Sections 7.1,  7.2, 7.3, 7.4, and
7.5.

A summary of the potential
adverse environmental impacts
associated with the regulatory
alternatives is included in
Chapter 1, Section 1.2, and
Chapter 7.  Potential socio-
economic and inflationary impacts
are discussed  in Chapter 8,
Section 8.5.   Irreversible and
irretrievable  commitments of
resources are  discussed in
Chapter 7, Section 7.6.
                                   B-3

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                                APPENDIX C
      EMISSION  TEST DATA FOR FABRIC  FILTERS  ON ELECTRIC  ARC FURNACES
                        AT  IRON  AND  STEEL FOUNDRIES

      This  appendix presents the emission test data  for  iron and  steel
 electric arc furnaces  (EAF's) which were summarized in  Section 4.6.
 Section C.I presents the results  of particulate  and gaseous sampling and
 visible emission observations conducted by  EPA at four  iron foundries and
 data  obtained  from two  other foundries.  Section C.2 presents data
 concerning steel foundry particulate emissions.  Section C.3 presents
 visible emission data from  observations  made  by  EPA observers at two
 steel-producing foundries.   Section C.4  presents the results of visible
 emission observations of a  tapping  pit  capture device at a  steel foundry.
 Summary tables presenting the data  for  each individual plant follow
 Section C.4.
 C.I   EMISSION  LEVELS FROM FABRIC  FILTERS AT IRON ELECTRIC ARC FURNACES
 C.I.I  Particulate  and Visible  Emissions
     The following  discussion summarizes results of  emission sampling
 conducted  on baghouses installed  on EAF's at  six'gray iron  foundries.
 Analyses were conducted for both  particulate  and gaseous pollutants.   The
 concentration of particulate emissions was measured  by EPA  Reference
Method 5.   Each test consisted of sampling in  the baghouse  exhaust stack,
 downstream of the baghouse and exhaust fans.   The visible emission observa-
tions were made using EPA Reference Method 9.   The particulate and visible
emissions data are  summarized in  Figure C-l  and Table C-l,   respectively.
The data for Plants A,  B, C, and D were obtained during field tests by
EPA contractors while those for Plants E and F were submitted by outside
sources.
                                   C-l

-------





.



in
§
i/l
in
1
Ol
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IB
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0_






gr/dscf nig/Nm Key
0.036
0.034.
0.032
0.030
0.028
0.026
0.024
0.022 .
0.020 -
0.018 .
0.016 -
0.014 .

0.012 -
O.OiO .
0.008 -
0.006 -
Q.004 -
0.002 -
' Plant:
Referenc
	 T—
C EPA Reference Method 5
-80 - ^
f> 9 Modified EPA method
-75 i — i Average
-70
-65
aAverage of 16 tests.
-60
.*
-50
-45 ID
.40
35

30

25
20 '!
D ' |
15 ft ' i
f. i i D
in 1 1 i T* )•
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5 H j|
• a
	 1 	 1 i i i i
A B C D E F
e: 1 23456
Figure C-l. Summary of source test data for
baghouses on EAF's producing iron.
C-2

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        TABLE C-l.   SUMMARY OF VISIBLE EMISSION DATA FOR
                      EAF'S PRODUCING IRON
                       (6-minute average)
Plant
                   Stack
Maximum

   9.6

  11.5

  30.4

   5.0
Percent
of time
 ^ 10%

  100

   99

   87

  100
                                   Roof vent
Maximum

  10.4

   2.3



   7.3
Percent
of time
 ^ 10%

   99

  100
                                                         100
                              C-3

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     C.I. 1.1  Plant A.   Plant A has three arc furnaces of 13 to 15 Mg (14
to 16 tons) melting capacity each.   Two automatically shaken baghouses are
used for exhaust gas cleaning.   Two furnaces are exhausted to one baghouse,
and a third furnace is exhausted to the second baghouse.   Each furnace is
equipped with a side draft hood and with hoods above the pouring spout and
the slag door for emission capture.  The three hoods from each furnace are
connected to a common duct which is under suction from the baghouse
centrifugal fan.  Overhead roof fans and monitors ventilate the furnace
scrap bays and also withdraw a small amount of air from adjacent areas.
An open-ended duct [1.5 m (5 ft) in diameter] is located about 13 m (43 ft)
above each furnace.  These ducts are not canopy-type hoods but extend down
from the roof area toward each furnace and are used only during charging
and tapping of the furnace.   The ducts are connected to the same baghouse
as the other furnace hoods.   Since a canopy hood is not used, complete
control of charging and tapping emissions is not provided.  The baghouses
are equipped with Dacron* filter bags which withstand a maximum temperature
of 135°C (275°F) and have an air-to-cloth ratio of 2.5:1.
     The baghouse which controls two furnaces (Nos. 1 and 2) was tested.
The exhaust gases at the baghouse  inlet and outlet were sampled simul-
taneously for particulates, carbon monoxide [using a nondispersive infra-
red (NDIR) analyzer], hydrocarbons (using a Beckman Hydrocarbon Analyzer*),
sulfur dioxide (by EPA Reference Method 6), and nitrogen oxides (by EPA
Reference Method 7).  Both furnaces were performing at design capacity
during the tests, and the emission control system appeared to be operating
well.  The exhaust gas flow rate averaged 76.1 (dscm/min)/Mg of iron
produced (2,445 dscfm/ton).   Each sample period commenced with the
beginning of a heat on one of the  furnaces and continued for approximately
3 hours.  Generally, the furnaces were on a staggered schedule.  An
average heat lasted about 70 minutes, and a sampling period encompassed
at least two full heats on each furnace.  A "heat" encompasses the time
from the beginning of charging to  the end of the tapping of molten metal.
^Mention of trade names does not constitute endorsement by EPA.
+(dscm/min)/Mg = dry standard cubic meters per minute per megagram.
 dscfm/ton = dry standard cubic feet per minute per ton.
                                   C-4

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      Detailed results  of the tests are presented in Tables C-3 and C-4.
 The outlet particulate concentrations  determined from the four samples
 were 8.7,  8.0,  6.5,  and 12.3 mg/dscm (0.0038,  0.0035,  0.0028,  and
 0.0054 gr/dscf),*  for  an average  of 8.9 mg/dscm (0.0039  gr/dscf).
      Concurrent with baghouse sampling,  visible emission data  were obtained
 for the baghouse stack and  for the roof monitor above  the furnaces.   The
 results are presented  in Tables Oil through C-18.   The  highest opacity
 (6-minute  average)  observed from  the baghouse  stack during the nearly
 15  hours that readings were taken was  9.6 percent.   The  opacity
 (6-minute  average) was 5 percent  or less about 90 percent of the time.
 At  the  roof monitor, the maximum  6-minute average opacity was  10.4 percent,
 and the opacity (6-minute average)  was  5 percent or less  about 95  percent
 of  the  time.
      C.I. 1.2  Plant  B.   Plant B is  a foundry with four electric arc
 furnaces.    The melting capacity  of each furnace ranges  from 10 to  12 Mg
 (11  to  13  tons) per  heat.   Particulate emissions from each  pair of  furnaces
 are  controlled  by a  common  fabric  filter.  The  furnaces are equipped with
 side  draft  hoods and also with  hoods above the  pouring spouts  and  slag
 doors.  All  of  the hoods  for  a  furnace are connected to a  header which
 discharges  to the automatically shaken baghouse.  The baghouse  fan with-
 draws an average of 85.9  (dscm/min)/Mg of iron  produced (2,745  dscfm/ton).
 The baghouse  is equipped with Dacron filter bags which withstand a maximum
 temperature  of  135°C (275°F)  and have an air-to-cloth ratio of  1.9:1.  Roof
 fans and monitors ventilate the furnace and scrap bays and also withdraw
 small amounts of air from adjacent  foundry areas.  Sampling at  Plant B was
performed only at the outlet  of the control  device.   The two furnaces
tested  (Nos. 3 and 4) were performing at design capacity, and the baghouse
was operating normally during the test.  The furnaces were on a staggered
schedule.  The sampling cycle was begun at the beginning of a heat on one
furnace and continued for approximately 3 hours.  The average heat
 lasted about 70 minutes, and  sampling covered at least two full heats on
*mg/dscm = milligrams per dry standard cubic meter.
 gr/dscf = grains per dry standard cubic foot.
                                   C-5

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each furnace.  Sampling results are presented in Table C-5.  The particulate
concentrations (probe and filter) from the three samples were 15.0, 8.8, and
8.6 mg/dscm, averaging 10.8 mg/dscm (0.0066, 0.0038, and 0.0038 gr/dscf,
averaging 0.0048 gr/dscf).
     Concurrent with the particulate sampling, visible emissions data
were obtained for the stack of the baghouse and also the roof monitor
vent above the furnaces.   The results are presented in Tables C-19 through
C-24.  The maximum 6-minute average opacity at the baghouse stack was
11.5 percent and was 5 percent or less about 90 percent of the time.   At
the roof monitor, the maximum 6-minute average opacity was only 2.3 percent.
     C.I.1.3  Plant C.  Plant C has two furnaces which produce up to 7 Mg
                                    o
(8 tons) of gray iron each per heat.   Each arc furnace is controlled by
a separate fabric filter, and both furnaces and collectors are retrofits.
The furnaces are equipped with roof type hoods and also with hoods above
the pouring spout and slag door which are connected to individual takeoff
boxes.  The exhaust gas flow rate averaged 56.0 (dscm/min)/Mg of iron
produced (1,805 dscfm/ton).  The Orion* filter bags withstand a maximum
temperature of 107°C (225°F), and the air-to-cloth ratio is 2.8:1.   The
furnace tested (south furnace) and the fabric filter Were operating
normally during the tests.  Furnace production during each test varied,
namely 7, 6, and 4.5 Mg (8, 7, and 5 tons) per heat for each of the three
sampling periods.  Roof fans and monitors ventilate the furnace and scrap
bays, withdrawing small amounts of air from adjacent areas and exhausting
directly to the atmosphere.
     Particulates, carbon monoxide, hydrocarbons, sulfur, and nitrogen
oxides were measured at the discharge of the control device.  Each sample
was collected during a 1.5-hour period.  Sampling periods coincided with
the beginning of a furnace heat and were completed prior to the end of
the heat.  An average furnace heat lasted about 90 minutes.  The parti-
culate emissions for the three tests were 45.0, 53.0, and 78.7 mg/dscm,
averaging 58.9 mg/dscm (0.0197, 0.0232, and 0.0344 gr/dscf, averaging
0.0257 gr/dscf).  These results are presented in Table C-6.  Emissions at
Plant C are higher than at the other facilities for two probable reasons.
^Mention of trade names does not constitute endorsement by EPA.
                                   C-6

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 These are:
      1.   The collector is manually shaken at irregular intervals and
 therefore overcleaning is probable.   Overcleaning results in a poor
 filter cake buildup,  reduced collection efficiency,  and higher emissions.
      2.   During the period of the testing,  carbon raiser was injected into
 the molten  bath using compressed air.   When this  method of carbon injection
 is  used,  only about 60 to 85 percent of the carbon is  dissolved in the metal
 or  retained in the  slag;  the rest escapes the  furnace  to the baghouse.
 Because of  the very small  particle size,  only  a portion of the carbon
 particles are collected in the  baghouse.
      This foundry currently uses  the pressure  lance  method of carbon
 injection only one  percent of the time  and  would  not use it again should
 a new foundry be built.7   Since other methods  for introducing the carbon into
 the molten  bath exist,  are used more frequently than pressure lancing,
 produce lower emission  rates, and are economically viable,  the  data for
 Plant C will  not be used as  a part of the data base.
      Visible  emissions  data  were  also obtained at Plant  C  during  sampling
 periods for the baghouse exhaust  stack.  The results are presented in
 Tables C-25 through C-30.   The  maximum  6-minute average  opacity at the
 stack was 30.4 percent, but  occasional  peaks of up to  100  percent were
 observed  for  short periods  (several  seconds only).   At the  stack, the
 opacity (6-minute average) was  5  percent or less  about 70  percent of the
 time.  The much higher  opacity  of  the emissions from this  plant are
 consistent with the higher particulate  emissions.
      C.I.1.4  Plant D.  Plant D has one furnace, which produces 5 Mg
 (6  tons)  of gray iron per  heat.    The arc furnace is surrounded on three
 sides by  two walls and the transformer  room so that  fumes  from charging
 and upset conditions (gas  puffs escaping through the electrode holes or
 other furnace openings) are directed upward to a ventilation fan located
 above the furnace.   Thus,  fugitive emissions from the furnace are emitted
 to the atmosphere in greater concentrations than at the other foundries
 tested in this program.  In the previous foundries, the furnaces were
 located in large open bay  areas.  Consequently, the furnace emissions
were  subject to cross-drafts and drifted at times  sidewards instead of
 upwards.   The furnace at Plant D is retrofitted with a side draft hood
                                   C-7

-------
and with hoods above the pouring spout and slag door.   The discharge rate
to the fabric filter averaged 91.5 (dscm/min)/Mg of iron produced
(2,910 dscfm/ton).  The Dacron filter bags withstand a maximum temperature
of 135°C (275°F) and have an air-to-cloth ratio of 2.6:1.   The first test
was run for only one hour, i.e., covering only one heat.  The next two tests
each extended over two heats.  Each test was started at the beginning of
two consecutive heats and continued for one hour during each heat.  An
average furnace heat lasted about 70 minutes, and the furnace operated at
design capacity.  Particulate measurements were made at both the inlet
and outlet of the collector.  The three measurements showed particulate
concentrations of 18.1, 2.9, and 6.1 mg/dscm, averaging 9.1 mg/dscm (0.0079,
0.0013, and 0.0027 gr/dscf, averaging 0.0040 gr/dscf) at the baghouse
outlet.  The results of the tests are in Tables C-7 and C-8.
     Concurrent with the particulate testing, visible emissions data were
recorded for the baghouse exhaust stack and the roof monitor vent above
the furnace.  The data are presented in Tables C-31 through C-37.  The
highest 6-minute average opacity at the stack was only 5.0 percent.  The
opacity (6-minute average) at the foundry roof vent was 5 percent or less
about 93 percent of the time with a maximum 6-minute average of 7.5 percent.
     C.I.1.5  Plant E.  Plant E operates one electric arc furnace which
produces at a rate of 13 Mg (14 tons) per heat or 6 Mg/h (7 tons/h).
Particulate emissions from the furnace are controlled by a fabric filter.
The furnace is equipped with a side draft hood and with hoods above the
pouring spout and slag door.  Roof fans and monitors which discharge
directly to the atmosphere ventilate the furnace bay area.  Emissions
were sampled at the baghouse outlet stack.  The bags are made of Dacron
and withstand a maximum temperature of 135°C (275°F).  The air-to-cloth
ratio is 3.1:1.  Average particulate loadings, as determined by the three
samples, were 12.8, 23.3, and 13.5 mg/dscm, averaging 16.5 mg/dscm (0.0056,
0.0102, and 0.0059 gr/dscf, averaging 0.0072 gr/dscf).  These data are
presented in Table C-9.
     The first test was started at the beginning of one heat; the second
test was started one hour after the beginning of a second heat, and the
third test was started 1.5 hours after the beginning of a third heat.
Because of discrepancies in the isokinetic sampling rate, sampling locations,
                                   C-8

-------
and sample time vs. process conditions, the data may not be representative
of results obtainable from tests adhering to the conditions of EPA Reference
         o
Method 5.   Therefore, the data will be given less weight in the data base.
     C.I.1.6  Plant F.  Plant F has two electric arc furnaces each with a
melting capacity of 14 to 15 Mg/h (15 to 17 tons/h) or 27 to 32 Mg per
heat (29 to 35 tons per heat).   One baghouse serves the two gray iron
EAF's, two induction holding furnaces, and one duplexing arc furnace.
Sampling was conducted at the baghouse stack outlet.  The EAF's are equipped
with side draft hoods, hoods above the pouring and slag doors, and also with
a direct furnace evacuation tap.  All hoods are connected to a header which
leads to the baghouse.  The direct furnace evacuation system is only in
operation 20 to 25 minutes at the beginning of the melt until the oil from
the scrap charge is burned off.   (These furnaces melt scrap consisting of
40 percent by weight of borings and turnings which contain up to 10 percent
oil.)  Roof fans and roof canopy hoods which exhaust directly to the atmos-
phere ventilate the furnace bay area and adjacent aisles.   Sampling was
conducted for two hours with a test method similar to EPA's Reference
Method 5.  As only slight modifications to the EPA method were made, the
data have been determined to be suitable for use in the data base.
                                                                  9,10
In
these tests, the sampling period was not selected to coincide with the
beginning of a heat cycle on one of the furnaces.  Generally, the furnaces
are on a staggered schedule.  Specific process and operation data are not
available.
     The highest particulate concentration during these tests was
10.3 mg/dscm (0.0045 gr/dscf).   The lowest level measured was 1.6 mg/dscm
(0.0007 gr/dscf), while the average of 16 measurements was 3.7 mg/dscm
(0.0016 gr/dscf).  The available data are summarized in Table C-10.
C.I.2  Other Emissions
     Carbon monoxide levels were measured during the four EPA foundry
tests, and the data are presented in Tables C-38 through C-41.  During
all tests,  emissions were continuously monitored with a nondispersive
infrared analyzer (NDIR).  The sampling location was downstream of the
furnace at the fan where the temperature is far below 700°C (1290°F),
above which pyrophoric conditions exist.   Measurements were begun during
charging and continued until the tap was completed.
                                   C-9

-------
     At Plant A, individual carbon monoxide levels ranged from 33 to
275 ppm with an daily average (based on three test days) of 96 ppm.   The
overall hourly emission rates were generally uniform, the highest differing
from the lowest by about 16 percent.  The average level, based on three
tests, was 0.58 (kg/h)/(Mg/h) [1.16 (lb/h)/(ton/h)] of melting capacity.
     At Plant B, individual carbon monoxide levels ranged from 14 to
142 ppm with an daily average (based on three test days) of 73 ppm.   The
overall hourly emissions vary somewhat, the highest differing from the
lowest by about 33 percent.  The average level of carbon monoxide, based
on three tests, was 0.35 (kg/h)/(Mg/h) of furnace capacity
[0.70(lb/h)/(ton/h)].
     At Plant C, individual carbon monoxide levels ranged from 10 to
425 ppm with an daily average (based on three test days) of 115 ppm.  The
overall hourly emissions also vary, the highest differing from the lowest
by about 44 percent.  The  average level, of carbon monoxide, based on
three tests, was 0.56 (kg/h)/(Mg/h) [1.12 (lb/h)/(ton/h)].
     At Plant D, individual carbon monoxide levels ranged from 0 to
435 ppm with an daily average (based on three test days) of 93 ppm.   The
highest measurement differs from the lowest by about 60 percent.  The
average level of carbon monoxide, based on three tests, was
0.87 (kg/h)/(Mg/h) [1.74 (lb/h)/(ton/h)].
     During these tests, emissions of sulfur dioxide, hydrocarbons, and
nitrogen oxides were also  measured.  Because no control techniques exist
for any of these pollutants on electric arc furnaces, these measurements
are not discussed further.  Detailed data on these readings are reported
in Tables C-38 through C-41.
C.2  PARTICULATE EMISSION  LEVELS FROM FABRIC FILTERS AT STEEL ELECTRIC
     ARC FURNACES   ,
     Several steel foundries and air pollution control agencies in the
United States and abroad were contacted to obtain emission test data.
These  data are presented in Table C-42 (United States foundries only) and
in Figure C-2.  The foreign data are presented for information purposes
only and are not part of the data base.
                                    C-10

-------
                                              Key










CO
c
o
1/5
•r-
E
Ul

*
CO
—
3
O
r—
^_

CO
O.








€> EPA Reference Method
gr/dscf mg/dscm ° VDI Test Meth°d
0. 01 6 f\

0.015_

0.014_
0.013_

0.012_

o.on_
0.010_
0.009_


0.008_
0.007_


0.006,

0.005_

0; 004_
0.003_

0.002_
0.001_


35 '
1
1
i
1
. 30 j
1
i
l
- 25 1
1
1
_20 ,
1
I
1
15 i
4-,
T1
1
1
1
-10
1
? Average of 14 tests.
h
Unknown number of tests.
.Range for 30 facilities.
Range for typical facilities.



P fl
1
P i!
1
I f
1 '
! '
j i i
-< 1 ( 1

|j j
i
i
	 1 a
R j
k| fl j! » b
ID nf-H , i
- 5 tj i R
*J-Tl • , - '
to trb c




P
. i

1
1 1 I

1 *
' r;
' ! | '[d-
1
1 1
"^? 1
| '
,0
J
i ' '* '
i 1 ""^^
c
i i i i i i i i i i
Plant; GHIJK LMNOP
Reference: 11 11 12 13 14 15 16 17 18 19
Figure  .C-2.  Summary of source test data for
      baghouses on EAF's producing steel.
                      c-n

-------
C.2.1  United States Foundries
     C.2.1.1  Plant G.   Plant G operates a 27-Mg (30-ton) basic electric
arc furnace with single slag.    Furnace emissions are evacuated
by a side draft hood, and the control device is a fabric filter with an
air-to-cloth ratio of 2.5:1.  The fabric filter is shaken at the end of
the furnace heat.  The baghouse was designed for 2,275 mVmin
(80,400 ftVmin); however, it is operated at 1,980 mVmin (68,800 ftVmin).
The installation was acceptance tested in February 1969 using EPA Reference
Method 5.  Each test lasted 60 minutes whereas a typical furnace heat
with oxygen lancing lasts about 2 hours.  Each of the four sampling
periods encompassed oxygen lancing (i.e., the time of highest particulate
emissions).  The outlet loadings for the four tests were 9.15, 5.72, 6.97,
and 36.6 mg/dscm (0.004, 0.0025, 0.003, and 0.016 gr/dscf).  The average
outlet loading was 14.6 mg/dscm (0.064 gr/dscf).
     C.2.1.2  Plant H.  Plant H operates a 30-Mg (33-ton) basic electric
                                   A side draft hood collects emissions
                               11
arc furnace with a single slag.
which are exhausted to a fabric filter with an air-to-cloth ratio of
2.5:1.  The baghouse was designed for 2,800 mVmin (98,000 ftVmin) but
operates at 2,200 m3/min (77,000 ftVmin).  The installation was acceptance
tested in February 1969 using EPA Reference Method 5.  Each test lasted
60 minutes, whereas a typical furnace heat with oxygen lancing lasts
about 2 hours.  Each sampling period included the oxygen lancing operation.
The outlet loadings recorded in two different tests were 4.58 and
6.87 mg/dscm  (0.002 and 0.003 gr/dscf).  The average outlet loading was
5.73 mg/dscm  (0.0025 gr/dscf).
     A review of partial test reports for plants G and H was performed
by EPA.20'21  The data were determined to be suitable for use in the data
base in support of other data.
     C.2.1.3  Plant I.  Plant I operates a 33-Mg (36.5-ton) basic electric
arc furnace with single slag.    Furnace gases are evacuated by direct
furnace evacuation to a baghouse which handles 835 mVmin (29,550 ftVmin).
The Dacron bags operate at an air-to-cloth ratio of  2:1.  A typical
furnace heat  with oxygen lancing lasts 3 to 4 hours  depending on
the availability of electrical energy.  The tests were carried out  using
EPA Reference Method 5.  The  first test encompassed  the backcharging, and
                                    C-12

-------
 the  total test  time was 80 minutes.  The  second test was  conducted  near
 the  middle of a 5-hour heat, and the total time for the second test was
 also 80 minutes.  The third test, of 30 minutes duration, was conducted
 after backcharging but prior to oxygen lancing.  The outlet particulate
 loadings recorded in the three tests were 0.53, 2.75, and 8.70 mg/dscm
 (0.0002, 0.0012, and 0.0038 gr/dscf), averaging 3.99 mg/dscm
 (0.0017 gr/dscf).  These data will be given less weight in the data base
 because the sampling periods did not cover similar segments of each heat
 sampled.
     C.2.1.4  Plant J.  Plant J operates one basic arc furnace producing
                                          -i -3
 27 Mg (30 tons) per heat with single slag.    Direct furnace evacuation
 directs emissions to a fabric filter.  The installation was acceptance
 tested in May 1973 using EPA Reference Method 5.  The gas volume is
 2,900 mVmin (102,600 ftVmin); the temperature of the outlet gas stream
 is 49°C (120°F).  The tests were run during two consecutive heats,  the
 first handling  28.3 Mg (31.2 tons) of scrap and additives and the second
 28.2 Mg (31 tons).   The average outlet concentration measured was
 6.63 mg/dscm (0.0029 gr/dscf).   The entire test lasted 4 hours;  2 hours
were needed to  complete each heat.
     A review of a partial test report indicated that the data were
 suitable for use in the data base in support of other data.21'22
     C.2.1.5  Plant K.   Plant K operates two arc furnaces having a total
 capacity of 5.4 Mg (6 tons).     Furnace emissions are evacuated by a
modified close capture system to a fabric filter having an air-to-cloth
ratio of 2.25:1.  The design flow for the baghouse is 1,420 mVmin
 (50,000 ftVmin).   The installation was tested in September 1977 using
EPA Reference Method 5.   Each test lasted 88 minutes whereas a typical
heat lasts about 65 minutes,  tap to tap.   The outlet particulate concen-
trations were 13.5,  12.8,  and 21.7 mg/dscm (0.0059,  0.0056,  and
0.0095 gr/dscf).  The average outlet was 16.0 mg/dscm (0.0070 gr/dscf)
particulate concentration.
C.2.2  Foreign Foundries
     The data for Plants  L,  M,  and N originate in the Federal  Republic of
Germany.   The data for Plant 0  originate in France while those for Plant  P
originate in Italy.   All  these  data are based on tests  conducted with
                                   C-13

-------
the VDI particulate test method which is not identical to EPA Reference
Method 5.  Based on previous tests carried out in Germany on municipal
incinerators, EPA Reference Method 5 collected 30 percent more dust from
the cleaned gas stream than did the German VDI method.  The German test
results are very similar to those obtained from steel electric arc furnaces
in the United States if this correction is applied, as shown in Figure C-2.
     Plant L operates a 20 to 22 Mg (22 to 24.2 tons) basic electric arc
furnace with single slag.    Furnace gases are also evacuated by direct
shell evacuation to a fabric filter which treats about 28,000 to
30,000 dscm/h (16,500 to 17,700 dscfm).  Emission sampling tests were
conducted at both the inlet and the outlet of the baghouse.  Outlet
particulate loadings ranged between 6 and 20 mg/dscm  (0.0026 to
0.0087 gr/dscf), with an average for 14 tests of 7 mg/dscm (0.0031 gr/dscf).
The highest loadings were experienced during oxygen lancing.  A normal
heat for this furnace lasts 2.5 hours.
     Plant M has two furnaces, one producing 7 Mg (8  tons) per heat and
the other 4 Mg  (4.4 tons) per heat.    The gas volume for the first
furnace  is 16,000 dscm/h (9,400 dscfm) and for the second is 12,000 dscm/h
(7,100 dscfm).  Furnace exhausts are controlled by a  single fabric filter.
The outlet temperature is 70° to 80°C (160° to 180°F).   Inlet and outlet
loadings were taken during tests; outlet loadings ranged between 1 and
4 mg/dscm (0.0004 and 0.0017 gr/dscf).
     A German company reports that the outlet loadings range between  2 and
20 mg/dscm (0.0009 and 0.0087 gr/dscf) for about 30 fabric filters installed
in plants (represented as Plant N) producing steel castings (mos.tly with
direct shell evacuation).    Higher emissions were experienced on charges
that contained  large amounts of swarf.
     A French company that has built many control devices for steel
electric arc furnaces for general steel production and which has pipneered
some of  today's techniques in the control of fumes from  arc furnaces  was
                                         18
also contacted  (represented as Plant 0).    The company  reports that
emissions on steel arc furnaces,  similar in size to those used for steel
castings, range between  5 and  15  mg/dscm (0.0022 and  0.0066 gr/dscf)  and
that there are  no  visible emissions at the  stack of the  control devices.
The  higher loadings  occur at  older  installations.
                                    C-14

-------
     Emissions from wen-controlled (fabric filters) electric arc furnaces
in steel foundries in Italy (represented as Plant P) are reported to
range between 4 and 12 mg/dscm (0.0017 and 0.0052 gr/dscf).19
C.3  VISIBLE EMISSION OBSERVATIONS OF PROCESS EMISSIONS AT STEEL
     FOUNDRIES
     Visible emission observations were performed by EPA personnel at
               23 24
Plants G and I.  '    These data are summarized in Table C-2.
     Stack opacity (6-minute averages) ranged from 0 to 21.9 percent with
6-minute average readings of 5 percent or less for 91 percent of the
time.  The maximum 6-minute average opacity during oxygen lancing was
2.7 percent.   These observations were not performed at the same time as
the particulate tests noted earlier.  The opacity of the baghouse exhaust
at steel foundries may be lower than at iron foundries because the carbon
black added to iron is not completely absorbed by the melt.   Five to
forty percent of carbon added to iron furnaces escapes in the furnace
exhaust gas,  and these extremely fine particles may also pass through the
         25
baghouse.    Carbon black addition is generally not done at steel foundries.
     Maximum opacity (6-minute average) reported from roof vents and
monitors was 16.7 percent at Plant G and 9.8 percent at Plant I.  The
maximum value for Plant G was observed during tapping.   It is not known
what phase of the process operation corresponds to the maximum value at
Plant I.  Neither facility had charging or tapping emission capture
systems.  The maximum 6-minute average opacity during oxygen lancing was
6.9 percent at Plant I.   No visible emissions were observed during the
melt cycle, including oxygen lancing, at the roof vents of Plant G.   The
6-minute average opacity from the roof vents at Plant I was 5 percent
or less 89 percent of the time.  The opacities were highest during tapping
because of alloy addition to the ladle.  Charging generated substantially
fewer visible emissions at the shop roof while backcharging emission
levels were between tapping and charging in magnitude for Plant G.
Because of the quantity of alloys added to the ladle and the hotter tap
temperature,  fugitive emissions from steel production are generally some-
what greater in magnitude than those from iron production.
data are detailed in Tables C-43 to C-52.
                                                          26
The opacity
                                   C-15

-------
        TABLE  C-2.   SUMMARY  OF VISIBLE  EMISSION DATA  FOR
                       EAF'S PRODUCING  STEEL
                        (6-minute  averages  )




Plant
G23
I24
Stack
Percent
of time
Maximum ^ 10%
21.9 93
4.0 100
Roof


Maximum
0.0
10.0
vent
Percent
of time
^ 10%
100
100
^Melting and refining,  including oxygen  lancing,  only.
                               C-16

-------
     The high opacity levels shown for Plant G may result from the fact
that at this plant the bags are shaken once between heats.  Following
shaking, a certain time is required for a filter cake to build up and
provide efficient filtering.  During this time, some emissions might
escape and cause a visible plume.   Inspection of the bags one week after
the visit of the EPA engineers revealed that three to four bags were
cracked.  This could also result in higher-than-normal visible emissions.
C.4  VISIBLE EMISSION OBSERVATIONS OF EMISSION CAPTURE DEVICES AT
     STEEL FOUNDRIES
     Visible emission observations were made using EPA Reference Methods 9
(indoors) and 22 at a steel foundry that utilizes a tapping pit enclosure
                             27
for tapping emission control.     This facility has two furnaces, one of
22.7-Mg capacity (20 tons) and the other of 9.1-Mg capacity (10 tons).
The enclosure system on the 22.7-Mg furnace was not operating properly;
therefore, data for that furnace are not presented.  A summary of the
results of the observations is given in Table C-53.
     For this series of observations, emmission readings were made for
the period of time encompassing the start of metal flow to the end of
metal flow.  As tapping on the 9.1-Mg furnace lasted only 2 to 3 minutes,
6-minute average readings could not be made.  Except for the first two
sets of readings, observations were made approximately 1.8 m (6 ft) above
the roof of the pit enclosure.  This foundry practices reladling
(refurnacing) in which one-third to one-half of the molten metal is
poured into the ladle and then returned to the furnace.  This operation
lasts approximately one minute which is not enough time for EPA Reference
Method 9 readings.  This facility practices only a limited amount of
alloying in the ladle.
     For the last three sets of readings, the emissions rose 1.8 m (6 ft)
above the roof of the tapping pit enclosure approximately 30 percent of
the time and had an average opacity of 15 percent or less.
                                   C-17

-------
TABLE C-3.  SUMMARY OF PARTICULATE RESULTS
       FACILITY A (BAGHOUSE INLET)
Run number
Date

Test data
Sampling time
Average total furnace production
(2 furnaces)
Nominal furnace capacity
(2 furnaces)
Shop effluent
Flow rate



Flow rate per capacity

Temperature

Water vapor
C02, dry
02, dry
Particulate emissions
Probe and filter catch:
Concentration



Emission rate

Emission factor
(emission rate per furnace
production)
Total catch:
Concentration



Emission rate

Emission factor

Units

min
ton/h
Mg/h
ton
Mg

acfm
fl!3/rai n
dscfm
Mm3 /rain
dscfm/ton
(Nm3/rain)/Mg
°F
°C
%, volume
%, volume
%, volume


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg
2
6-19-74

180
27.6
25.0
31.3
28.4

95,431
2,702
72,783
2,061
2,325
72.6
188
87
2.5
0.3
19.5


0.2132
488
0.2766
635
172.5
78.2
6.25
3.13


0.2281
522
0.2960
676
184
83.5
6.67
3.34
3
6-19-74

180
33.0
29.9
32.1
29.1

85,721
2,427
65,176
1,846
2,030
63.4
185
85
3.1
0.3
19.5


0. 2626
601
0.3415
783
190.7
86.5
5.78
2.89


0.2837
649
0.3690
845
206
93.4
6.24
3.12
4
6-20-74

180
28.4
25.8
31.6
28.7

90,990
2,577
70,069
1,984
2,215
69.1
189
87
1.6
0.3
20.1


0.2491
570
0.3201
734
192.2
87.2
6.77
3.38


0.2529
579
0.3250
744
195
88.5
6.87
3.43
Average


29.7
26.9
31.7
28.8

90,714
2,569
69,343
1,964
2,185
68.2
187
86
2.4
0.3
19.7

%
0.2416
553
0.3127
717
185.1
84.0
6.23
3.12


0.2549
583
0.3300
755
195
88.5
6.57
3.29
                    C-18

-------
TABLE C-4.  SUMMARY OF PARTICULATE RESULTS
       FACILITY A (BAGHOUSE OUTLET)
Run number
Date

Test data
Sampling time
Average total furnace production
(2 furnaces)
Nominal furnace capacity
(2 furnaces)
Shop effluent
Flow rate



Flow rate per capacity

Temperature

Water vapor
C02, dry
02, dry
Particulate emissions
Probe and filter catch:
Concentration



Emission rate

Emission factor
(emission rate per furnace
production)
Total catch:
Concentration



Emission rate

Emission factor

Units

min
ton/h
Mg/h
ton
Hg

acfm
m-Vmin
dscfm
Nm3/min
dscfm/ ton
(Nm3/min)/Mg
°F
°C
%, volume
%, volume
%, volume


gr/acf
mg/m3
gr/dscf
mg/Nra3
Ib/h
kg/h
Ib/ton
kg/Hg


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Hg
1
6-18-74

180
28.6
25.9
31.9
28.9

96,674
2,738
79,992
2,265
2,510
78.4
183
84
2.2
0.3
19.7


0.0029
6.64
0.0038
8.70
2.44
1.11
0,085
0.043


0.0056
12.8
0.0072
16.5
4.62
2.10
0.162
0.081
2
6-19-74

180
27.6
25.0
31.3
28.4

100,302
2,840
78,432
2,221
2,505
78.2
177
81
2.7
0.3
19.5


0.0027
6.40
0.0035
8.02
2.35
1.07
0.085
0.043


0. 0045
10.3
0.0057
13.1
3.83
1.74
0.139
0.070
3
6-19-74

180
33.0
29.9
32.1
29.1

98,140
2,779
76,080
2,154
2,370
74.0
185
85
2.4
0.3
19.5


0.0022
5.03
0.0028
6.46
1.83
0.83
0.055
0.028


0.0034
7.8
0.0044
10.1
2.87
1.30
0.087
0.043
4
6-20-74

180
28.4
25.8
31.6
28.7

100,111
2,835
76,985
2,180
2,435
76.0
188
87
2.9
0.3
20.1


0.0042
9.61
0.0054
12.3
3.56
1.61
0.125
0.062


0.0056
12.8
0.0073
16.8
4.83
2.19
0.170
0.085
Average
(2-4).


29.7
26.9
31.7
28.8

99,349
2,813
77,465
2,193
2,445
76.1
182
84
2.7
0.3
19.7


0.0031
7.01
0..0039
8.93
2.59
1. 17
0.087
0.043


0.0045
10.3
0.0058
13.3
3.86
1.75
0.130
0.065
                    C-19

-------

TABLE C-5.  SUMMARY OF PARTICULATE RESULTS
       FACILITY B (BAGHOUSE OUTLET)
Run number
Date

Test data
Sampling time
Average total furnace production
(2 furnaces)
Nominal -furnace capacity
(2 furnaces)
Shop effluent
Flow rate



Flow rate per capacity

Temperature

Water vapor
C02, dry
02, dry
Particulate emissions
Probe and filter catch:
Concentration



Emission rate

Emission factor
(emission rate per furnace
production)
Total catch:
Concentration



Emission rate

Emission factor

Units

min
ton/h
Hg/h
ton
Hg

acfm
m3/min
dscfm
Mm3 /min
dscfm/ ton
(Nm3/rain)/Hg
°F
°C
%, volume
%, volume
%, volume


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg
1
7-8-74

180
31.2
28.3
24.4
22.1

85,212
2,413
65,973
1,868
2,705
84.5
197
92
3.0
0.3
19.3


0.0051
11.6
. 0. 0066
15.0
3.72
1.69
0.119
0.060


0.0084
19.2
0.0109
24.9
6.17
2.80
0.198
0.099
2
7-9-74

180
31.0
28.1
24.5
22.2

86,454
2,448
69,611
1,971
2,840
88.8
171
77
2.8
0.2
20.0


0.0031
7.2
0.0038
8.8
2.26
1.04
0.073
0.037


0.0052
11.9
0.0064
14.6
3.81
1.72
0.123
0.061
3
7-9-74

180
33.2
30.1
24.3
22.0

84,818
2,402
65,508
1,855
2,695
84.3
195
91
3.2
0.2
20.0


0.0029
6.6
0.0038
8.6
2.11
0.96
0.064
0.032


0.0039
9.0
0.0050
11.5
2.83
1.28
0.085
0.043
Average


31.8
28.8
24.4
22.1

85,495
2,421
67,031
1,898
2,745
85.9
188
87
3.0
0.2
19.8


0.0037
8.5
0.0048
10.8
2.71
1.23
0.085
0.043


0.0058
13.4
0.0074
17.0
4.27
1.93
0.134
0.067
                    C-20

-------
                    TABLE  C-6.   SUMMARY OF PARTICULATE RESULTS
                             FACILITY C  (BAGHOUSE OUTLET)
Run number
Date

Test data
Sampling time
Average total furnace production

Nominal furnace capacity

Shop effluent
Flow rate



Flow rate per capacity
Temperature

Water vapor
C02, dry
Oz, dry
Particulate emissions
Units-

min
ton/h
Mg/h
ton
Mg

acfm
m-Vniin
dscfm
Nm3/min
dscfm/ton
(Nm3/min)/Mg
°F
°c
%, volume
%, volume
%, volume

1
9-18-74

120
3.6
3.3
7.2
6.5

14,771
418
12,006
340
1,670
52.3
184
84
0.7
0.7
20.6

2
9-18-74

78
3.9
3.5
5.1
4.6

15,196
430
12,317
349
2,415
75.9
186
86
0.7
0.5
20.4

3
9-19-74

120
4.1
3.7
8.2
7.4

14,987
424
12,463
353
1,520
47.7
161
72
1.0
0.5
21.0

Average


3.9
3.5
6.8
6.2

14,985
424
12,262
347
1,805
56.0
177
81
0.8
0.6
20.7

Probe  and filter catch:

  Concentration
  Emission rate

  Emission factor
    (emission rate per furnace
     production)
gr/acf
mg/m3
gr/dscf
mg/Nm3

Ib/h
kg/h
Ib/ton
kg/Mg
 0.0160
36.6
 0.0197
45.0

 2.03
 0.92
 0.564
 0.279
 0.0188
43.0
 0.0232
53.0

 2.45
   11
   628
                                                                          0.0286
                                                                         65.4
                                                                          0.0344
                                                                         78.7
              0.317
3.67
1.67
0.895
0.451
             0.0211
            48.3
             0.0257
            58.9
2.71
1.23
0.695
0.351
                                             C-21

-------
TABLE C-7.  SUMMARY OF PARTICIPATE RESULTS
       FACILITY D (BAGHOUSE INLET)
Run number
Date

Test data
Sampling time
Average total furnace production

Nominal furnace capacity

Shop effluent
Flow rate



Flow rate per capacity
Temperature
Water vapor
COZ, dry
02, dry
Particulate emissions
Probe and filter catch:
Concentration



Emission rate

Emission factor
(emission rate per furnace
production)
Total catch:
Concentration



Emission rate

Emission factor

Units

min
ton/h
Mg/h
ton
Mg

acfm
nrVmin
dscfm
Mm3 /min
dscfm/ ton
(Nm3/min)/Mg
°F
°C
%, volume
%, volume
%, volume


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg
1
10-1-74

60
4.6
4.2
6.1
5.5

21,783
617
19,166
543
3,140
98.7
125
52
0.8
0.8
19.7


0.3630
831
0.4125
944
67.8
30.7
14.7
7.3


0.3750
858
0.4262
975
70.0
31.8
15.2
7.6
2
10-2-74

120
3.9
3.5
6.1
5.5

26,815
759
23,855
676
3,910
122.9
124
51
0.1
3.9
17.7


0.2550
584
0.2867
656
58.6
26.6
15.0
7.6


0.2613
598
0.2937
672
60.0
27.2
15.4
7.8
3
10-3-74

120
4.4
4.0
6.1
5.5

22,086
625
19,387
549
3,180
99.8
126
52
0.5
3.8
20.0


0.4063
930
0.4629
1,059
76.9
34.9
17.5
8.7


0.4192
959
0.4776
1,093
79.4
36.0
18.0
9.0
Average


4.3
3.9
6.1
5.5

23,561
667
20,803
589
3,410
107.1
125
52
0.5
2.8
19.1


0.3414
782
0.3874
886
67.8
30.7
15.8
7.9


0.3518
805
0.3992
913
69.8
31.7
16.2
8. 1
                     C-22

-------
TABLE C-8.  SUMMARY OF PARTICULATE RESULTS
       FACILITY D (BAGHOUSE OUTLET)
Run number
Date

Test data
Sampling time
Average total furnace production

Nominal furnace capacity

Shop effluent
Flow rate



Flow rate per capacity

Temperature

Water vapor
C02, dry
02, dry
Particulate emissions
Probe and filter catch:
Concentration



Emission rate

Emission factor
(emission rate per furnace
production)
Total catch:
Concentration



Emission rate

Emission factor

Units

min
ton/h
Mg/h
ton
Mg

acfm
nrVmin
dscfm
Mm3 /min
dscfm/ton
(Nra3/min)/Mg
°F
°C
%, volume
%, volume
%, volume


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg


gr/acf
mg/m3
gr/dscf
mg/Nm3
Ib/h
kg/h
Ib/ton
kg/Mg
1
10-1-74

60
4.6
4.2
6.1
5.5

16,790
475
15,185
430
2,490
78.2
112
45
0.8
0.8
19.7


0.0072
16.40
0.0079
18.13
1.03
0.468
0.224
o.m


0.0213
48.70
0.0235
53.85
3.06
1.389
0.665
0.331
2
10-2-74

120
3.9
3.5
6.1
5.5

21,758
616
20,037
567
3,285
103.1
107
42
0.0
3.9
17.7


0.0012
2.67
0.0013
2.90
0.22
0.099
0. 056
0.028


0.0029
6.73
0.0032
7.31
0.55
0.249
0.141
0.071
3
10-3-74

120
4.4
4.0
6.1
5.5

20,486
580
18,061
511
2,960
92.9
125
52
0.2
3.8
20.0


0.0024
5.41
0.0027
6.14
0.42
0.188
0.095
0.047


0.0044
10.13
0.0050
11.49
0.78
0.353
0.177
0.088
Average


4.3
3.9
6.1
5.5

19,678
557
17,761
503
2,910
91.5
115
46
0.3
2.8
19.1


0. 0036
8. 16
0. 0040
9.06
0.56
0.252
0.130
0. 065


0. 0095
21.85
0.0106
24.22
1.46
0.664
0.340
0.170
                    C-23

-------
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-------
             TABLE C-10.  SUMMARY OF PARTICULATE RESULTS
                   FACILITY F (BAGHOUSE OUTLET)

Shop effluent
Flow rate
Temperature
Water vapor
C02, dry
Oa, dry
Particulate emissions
Probe and filter catch
Concentration
Emission rate
Units Range
ftVmin
mVmin
°F 95 -180
°C 35 - 82
%, volume 1-2
%, volume
%, volume

gr/dscf 0.007 - 0.0045
mg/Nm3 1.6-10.3
Ib/h 1.04 - 6.77
kg/h 0.47 - 3.07
Average3
2,280
65
137.5
59
1.5
Negligible
21

0.0016
3.7
2.43
1.10
Sixteen tests total.
                                 C-25

-------
                             Table  C-ll
                             FACILITY*  A
                     SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:   Gray Iron Foundry
           Date. June 18, 1974
 Type of Discharge;  Particulates

 Location of Discharge:  Stack
Height of Point of Discharge; 40 ft.	

Height, of Observation Point: Ground Level
 Distance from Observer to Discharge Point: 100  ft. Duration: 4 hrs., 15 min.

 Direction of Observer from Discharge Point:_  North	
 Descript.  of Background;Black Bldg.wind Direction: North  Color of Flume;Brown

 Descript.  of Sky;  Clear	Wind Velocity;10-15  mptoetached Flume:  No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
10:45
10:50
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:38
End
10:50
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:38
12:44
Sum
0
0
0
0
0
50
130
120
40
10
5
0
0
65
120
5
80
45
120
5
Avg.
0
0
0
0
0
2,1
5.4
5.0
1.7
0.4
0.2
0
0
2.7
5.0
0.2
3.3
1.9
5.0
0.2
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
12:44
12:50
12:56
1:02
1:08
1:14
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
End
12:50
12:56
1:02
1:08
1:14
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
Sum
0
0
5
120
165
230
195
25
40
5
5
5
50
90
0
0
50
125
115
0
Avg.
0
0
0.2
5.0
6.9
9.6
8.1
1.0
1.7
0.2
0.2
0.2
2.1
3.8
0
0
2.1
5.2
4.8
0
  LO


•8
So
fH
0)
P(

<§<
             Sketch showing how opacity varied with time;
                        	;	p.
                    T
                                     1

                              Time, hours

                                     C-26

-------
                              Table  C-ll (concluded)


                              FACILITY:  A
                     SUMMARY  OF VISIBLE EMISSIONS
 Type of Plant;  Gray  Iron Foundry
           Date:   June 18,  1974
 Type of Discharge; Particulates

 Location of Discharge; Stack
Height of Point of Discharge; 40 ft.
Height, of Observation Point:  Ground Level
 Distance from Observer to Discharge Point; 100 ft. Duration:  4 hrs., 15 min.

 Direction of Observer from Discharge Point;   North	
 Descript. of Background;Black Bldq.Wind Direction: North Color of  Plume: Brown

 Descript. of Sky:  Clear	wind Velocity:!0-15 mptoetached  Plume:  No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set Ho.
41
42
4-3
Start
2:44
2:50
2:56
End
2:50
2:56
3:02
Sum
0
20
0
Avg.
0
0.8
0
Set No



Start



End



Sum



Avg.



o
in
0)
ft
-P
•H
O


I"
             Sketch showing how opacity varied with time;
                                     J_
                                      1

                              Time, hours

                                     C-27

-------
                              Table   O12
                              FACILITY: A
                     SUMMARY  OF VISIBLE EMISSIONS
 Type of Plant;  Gray Iron Foundry
Date.  June 18, 1974
 Type of Discharge:
                     Particulates
                     Ft
                   	               _ Height of Point  of  Discharge:  3
Location of Discharge: Roof Vents      Height of Observation  Point:   60 Ft
Distance from Observer to Discharge Point:  24 Ft Duration;  4 Mrs,,  10 Min
 Direction of Observer from Discharge Point: East of Roof Fan	
 Descript. of Background:  Sk^	Wind Direction:  North color  of Plume:  Brown
 Descript. of Sky;  Sunny Blue Sky  wind Velocity;10-15 mphpetached Plume:  No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

Start
10:50
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:38
12:44

End
10:56
11:02
11:08
11:14
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:38
12:44
12:50

Sum
75
35
5
0
0
0
10
0
0
0
90
55
115
55
0
150
10
30
0
95

Avg.
3.1
1.5
0.2
0
0
0
0.4
0
0
0
3.8
2.3
4.8
2.3
0
6.2
0.4
1.2
0
4.0

Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Start
12:50
12:56
1:02
1:08
1:14
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
End
12:56
1:02
1:08
1:14
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
Sum
0
45
5
0
250
30
45
0
195
25
0
0
0
90
145
110
0
0
245
75
35
Avg.
0
1.9
0.2
0
10.4
1.2
1.9
0
8.1
1.0
0
0
0
3.8
6.0
4.6
0
0
10.2
3.1
1.5
2 Sketch showing how opacity varied with time: 4
O)

-------
                              Table  C-13
 Type of Plant;
        FACILITY:  -A
SUMMARY OF VISIBLE EMISSIONS

Iron Foundry
                                                   Date.  June 19, 1974
 Type of Discharge:  Parti culates
                                        Height of Point of Discharge; 40 ft.
 Location of Discharge; Stack _  Height,  of Observation Point; Ground Level
 Distance from Observer to Discharge  Point: ^0 f^- Duration:  3 hrs., 21 min.
Direction of Observer from. Dischar
Descript. of Background:
                                      Point :  North
 rescript, of Sky;   Clear
               .Wind Direct ion :Ca1m   Color of Plume;Brown
               .Wind Velocity:^£orded Detached Plume: No
                  SUMMARY OF TIME .AND AVERAGE  OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
10:00
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11:30
11:36
11:42
11:48
11:54
End
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11:30
11:36
11:42
11:48
11:54
12:00
Sum
0
5
0
10
80
90
45
50
0
80
75
85
15
40
45
0
10
45
120
55
Avg.
0
0.2
0
0.4
3.3
3.7
1.9
2.1
0
3.3
3.1
3.5
0.6
1.7
1.9
0
0.4
1.9
5.0
2.3
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18






End
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:21






Sum
115
125
125
65
95
35
10
0
5
5
5
5
0
5






Avg.
4.8
5.2
5.2
2.7
4.0
1.5
0.4
0
0.2
0.2
0.2
0.2
0
0.2






  o
  If)
go
•H
O
Pi
o
             Sketch showing how opacity varied with time:
                                     J_
                                      1
                              Time, hours
                                     C-29

-------
                             Table  C-14
                             FACILITY:  'A
                     SUMMARY OF VISIBLE EMISSIONS
 Type of Plant; Gray Iron Foundry
           Date: June 19.  1974
 Type of Discharge:  Roof Vent
Height of Point of Discharge; 3  ft.
 Location of Discharge;Over Furnace No.2Height of Observation Point:  60  ft.
 Distance from Observer to Discharge Point: 24 ft. _Duration; 3 hrs.,  22  min.
 Direction of Observer from Discharge Point:Sun in  the Back of Observer	
 Descript.  of Background: Sky	Wind Direction:|§£o£4£dpolor of Plume:JBn£Mn_
 Descript.  of Sky; r.lnudy. Bright SunWind Velocity:Not Rec. Detached Plume:  No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
10:00
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11:30
11:36
11:42
11:48
11:54
End
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11:30
11:36
11:42
11:48
11:54
12:00
Sum
120
20
0
0
40
:-60
0
0
0
0
65
10
20
0
0
60
0
0
0
35
Avg.
5.0
0.8
0
0
1.7
2.5.
0
0
0
0
2.7
0.4
0.8
0
0
2.5
0
0
0
1.5
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18






End
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:22






Sum
0
0
0
20
50
0
0
0
0
0
0
0
55
0






Avg.
0
0
0
0.8
2.1
0
0
0
0
0
0
0
2.3
0






  If)

•8
go
fH
t>
             Sketch showing how opacity varied with time:
                              Time,  hours
                                     C-30

-------
                              Table  C-15
                              FACILITY:  A
                      SUMMARY OF VISIBLE EMISSIONS
 Type of Plant; Gray Iron Foundry
                                                   Date:   June 19.  1974
 Type of Discharge:  Particulates
                                        Height of Point of Discharge:  40 ft.
 Location of Discharge: Stack _  Height, of Observation Point: Ground  Level
 Distance from Observer to Discharge Point;  TOO ft. Duration;  4 hrs. _
 Direction of Observer from  Discharge Point:  North _
 Descript. of Background §fSe-o£^I4Vind Direct ion ;Nnt. RPP.. Color of Plume:
Descript. of SkyrCloudy &  Sunny
                 (after 6:30  p.m.)
                 SUMMARY OF TIME AND AVERAGE OPACITY
                                     Wind Velocity :Not Rec . Detached Plume: No
Set No.
1
2
3
4
5
6
7
• 8
9
10
11
12
13
14
15
16
17
18
19
20
Start
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
5:10
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
End
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
3:58
5:04
~ 5:10
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
6:04
Sum
0
5
15
.•30
0
30'
90
130
120
120
80
15
5
5
5
10
75
120
135
125
Avg.
0
0.2
0.6
1.2
0
1.2
3.8
5.4
5.0
5.0
3.3
0.6
0.2
0.2
0.2
0.4
3.1
5.0
5.6
5.2
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
6:04
6:10
6:16
6:22
6:28
6:34
6:40
6:46
6:52
6:58
7:04
7:10
7:16
7:22
7:28
7:34
7:40
7:46
7:52
7:58
End
6:10
6:16
6:22
6:28
6:34
6:40
6:46
6:52
6:58
7:04
7:10
7:16
7:22
7:28
7:34
7:40
7:46
7:52
7:58
8:04
Sum
60
15
25
90
60
85
0
35
0
65
125-
125
no
5
0
5
75
75
5
0
Avg.
2.5
0.6
1.0
3.8
2.5
3.5
0
1.5
0
2.7
5.2
5.2
4.6
0.2
0
0.2
3.1
3.1
0.2
0
 Lf>
-P
a
tt)
-P
•rl
O
O
             Sketch showing how opacity varied with time:
                                    3
                                     JL
                                     1
                              Time,  hours
                                     C-31

-------
                             Table C-16

                             FACILITY: A
                     SUMMARY OF VISIBLE EMISSIONS
     of Plant: Gray  Iron  Foundry
                                                   Date:   June  19,  1974
                                        Height of Point of Discharge:.
                                                                        3  ft.
Type of Discharge;  Roof Vent _
Location of Pis charge; Over  Furnace  No. 2 Height of Observation Point; 60 ft.

Distance from Observer to Discharge Point:  24  ft.  Duration; 4 hrs.

Direction of Observer from  Discharge Point:

Descript. of Background:  Sky
                                    ,c r^u.  East of Roof Fan	
                                    Wind Direct ion :Not_RecjCoior of Plume: Brown
Descript.  of Skv:Cloudy, Rainy to
                  Partly uiouay
                                    Wind Velocity:Not_Rec_._Detached Plume:.
                                                                           No
SUMMARY. OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
5:10
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
End
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
5:10
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
6:04
Sum
0
0
0
20
5
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Avg.
0
0
0
0.8
0.2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
6:04
6:10
6:16
6:22
6:28
6:34
6:40
6:46
6:52
6:58
7:04
7:10
7:16
7:22
7:28
7:34
7:40
7:46
7:52
7:58
End
67TO
6:16
6:22
6:28
6:34
6:40
6:46
6:52
6:58
7:04
7:10
7:16
7:22
7:28
7:34
7:40
7:46
7:52
7:58
8:04

Sum
0~~
35
0
0
0
0
0
0
0
0
0
0
0
65
0
0
0
0
0
0

Avg.
0
1.5
0
0
0
0
0
0
0
0
0
0
0
2.7
0
0
0
0
0
0
  in
•8
0)

-------
                              Table  C-17
                              FACILITY:  A
                      SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:  Gray  Iron  Foundry
 Type of Discharge: Particulates
 Location of Discharge; Stack	
                Date:    June  20,  1974
     Height of Point of Discharge; 80  ft.
     Heij
Observation Point; Ground Level
 Distance from Observer to Discharge  Point:4|rft"''Duration; 3  hrs., 16 min.
 Direction of Observer from Discharge PointT^0^ °bserver  North	
 Descript. of Background Rfi-Je  §P^] ^gWind  Direct ion ;Not  Rec Color of Plume; Brown
 Rescript, of Sky;   Clear	
_₯ind Velocity:!5  mph   Detached Plume: No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
9:20
9:26
9:32
9:38
9:44
9:50
9:56
10:02
10:08
10:14
10:20
10:26
10:32
10:38
10:44
10:50
10:56
11:02
11:08
11:14
End
9:26
9:32
9:38
9:44
9:50
9:56
10:02
10:08
10:14
10:20
10:26
10:32
10:38
10:44
10:50
10:56
11:02
11:08
11:14
11:20
Sum
0
0
0
0
0
15
0
0
0
0
0
0
0
0
0
0
0
0
0
40
Avg.
0
0
0
0
0
0.6
0
0
0
0
0
0
0
0
0
0
0
0
0
1.7
| Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32







End
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:36







Sum
120
125
50
60
150
55
30
5
0
0
0
0
0







Avg.
5.0
5.1
2.1
2.5
6.2
2.3
1.3
0.2
0
0
0
0
0







 LO

-P
a
go
Sn
0)
-p
•H
O
o
             Sketch showing how opacity varied with time:
                                     _L
                                     1
                              Time, hours
                                      C-33

-------
                             Table C-18

                             FACILITY: A
                     SUMMARY OF VISIBLE EMISSIONS
 Type  of Plant;   Gray Iron Foundry
                                                  Date: June 20. 1974
 Type  of Discharge: Roof Vent
                                       Height  of Point of Discharge:  3 ft.
 Location of Discharge:Over Furnace No.2Height of Observation Point: 60  ft.
 Distance from Observer  to Discharge Point: 24 ft.  Duration; 3 hrs., 18  min.
                                              East of the Vent
Direction of Observer from Discharge Point:
Descript. of Background:  Sky	Wind Direction:Not RecColor  of  Plume:.
Descript. of Sky; Sunny  with Haze   Wind Velocity: 15 mph Detached  Plume:.

                 SUMMARY  OF TIME AND AVERAGE  OPACITY
                                                                           No
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
9:20
9:26
9:32
9:38
9:44
9:50
9:56
10:02
10:08
10:14
10:20
10:26
10:32
10:38
10:44
10:50
10:56
11:02
11:08
11:14
End
9:26
9:32
9:38
9:44
9:50
9:56
10:02
10:08
10:14
10:20
10:26
10:32
10:38
10:44
10:50
10:56
11:02
11:08
11:14
11:20
Sum
5
0
0
0
10
70
0
0
115
0
0
0
30
0
0
35
10
30
0
20
Avg.
0.2
0
0
0
0.4
2.9
0
0
4.8
0
0
0
1.2
0
0
1.5
0.4
1.2
0
0.8
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
11:20
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32







End
11:26
11:32
11:38
11:44
11:50
11:56
12:02
12:08
12:14
12:20
12:26
12:32
12:38







Sum
80
0
0
0
5
60
0
20
0
0
55
5
100







Avg.
3.3
0
0
0
0.2
2.5
0
0.8
0
0
2.3
0.2
4.2







             Sketch showing how opacity varied with time:
            	1	
                                                                       4
  to
•p
c
go
PM
•H
O
                                     3
                                    n
                                            J—L
                                     1
                              Time, hours
                                     C-34

-------
                              Table  C-19
                              FACILITY: B
                      SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:  Gray Iron Foundry
                                                   Date:    July 8,  1974
 Type of Discharge; Particulates

 Location of Discharge;  Stack
                                                                       50  ft.
                                        Height  of Point of Discharge:.

                                        Height,  of Observation Point: Ground  Level
Distance from Observer to Discharge Point:  125 ft.Duration;  3  hrs.. 48 mln.	

                                             South-East	
                                       Point:
                               pnlnfWind Direction;  Calm  Color of Plume; Brown
Direction of Observer from, Dis
Descript. of Background: &  pfy'j-	               	               	
Descript. of Sky; Sunny,Scat.ClBs., Wind Velocity;Not  Rec. Detached Plume: No
                  Blue Sky, Humid, 95°F

                 SUMMARY OF TIME AND AVERAGE  OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
.1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
End
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
3:20
Sum
0
0
0
0
0
55
0
10
50
40
70
25
0
0
0
0
0
0
0
0
Avg.
0
0
0
0
0
2.3
0
0.4
2.1
1.7
2.9
1.0
0
0
0
0
0
0
0
0
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
3:20
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08

End
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08
5:10

Sum
50
25
35
0
30
10
0
0
25
115
130
50
55
65
145
40
0
0
15

Avg.
2.1
1.0
1.5
0
1.2
0.4
0
0
1.0
4.8
5.4
2.1
2.3
2.7
6.1
1.7
0
0
2.5

-P
S3
(U
d>
O)
O
oS if)
             Sketch showing how opacity varied with time;
            	1	o	1—
                                     _L
                                      1

                              Time, hours

                                     C-35

-------
                             Table C-20
                             FACILITY: B
                     SUMMARY OF VISIBLE EMISSIONS
Type of Plant;  Gray Iron Foundry
                    Date:  July 8. 1974
Type of Discharge: Particulates	  Height of Point of Discharge: 3 ft.  Above Roof
Location  of Discharge:   Roof Vent      Height of Observation Point:  At Vent Level
Distance  from Observer  to Discharge Point:  30 ft.  Duration: 3 hrs., 50 min.	
Direction of  Observer from Discharge Point:30 ft.  South of Discharge Point	
Descript.  of  Background:  Sky	Wind Direction: Calm  Color of Plume: Brown	
Descript.  of  Sky;  Scattered Clouds Wind Velocity-.Not Rec. Detached Plume:.
                                            No
SUMMARY OP TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
End
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
3:20
Sum
0
0
0
0
25
0
0
0
0
0
0
10
0
0
0
0
0
0
0
0
Avg.
0
0
0
0
1.0
0
0
0
0
0
0
0.4
0
0
0
0
0
0
0
0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
3:20
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08

End
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08
5:10


Sum
0
0
0
10
30
0
0
0
5
0
0
0
0
0
15
0
0
0
0


Avg.
U
0
0
0.4
1.2
0
0
0
0.2
0
0
0
0
0
0.6
0
0
0
0

 If)
E!

-------
                              Table  C-21
                              FACILITY:  B
                      SUMMARY OF VISIBLE EMISSIONS
  Type of Plant;  Gray Iron Foundry
  Type of Discharge; Parti dilates
  Location of Discharge:  Stack
                                                   Date:  July 9.  1974
                                        Height of Point of Discharge;  50  ft.	
                   -  	.  Height, of Observation Point;   Ground  Level
Distance from Observer to Discharge Point:125 ft.  Duration:  3 hrs., 42 min.	
Direction of Observer fr^m Discharge  Point:   South-East
 Descript.  of  Background
 Descript.  of  Sky;  Clear
                        Jrav B~lffa^"~	'—	  ——— -
                           jinpmPnf Wind Direction;  Calm  Color  of Plume: Brown
                                   _Wind Velocity;Not Rec.Detached Plume:  No
                   SUMMARY  OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
7*55
8:01
8:07
8:13
8:19
8:25
8:31
8:37
8:43
8:49
8:55
9:01
9:07
9:13
9:19
9:25
9:31
9:37
9:43
9:49
End
8:01
8:07
8:13
8:19
8:25
8:31
8:37
8:43
8:49
8:55
9:01
9:07
9:13
9:19
9:25
9:31
9:37
9:43
9:49
9:55
Sum
25
15
30
30
55
0
10
20
135
130
130
50
0
0
45
0
0
5
10
20
Avg.
1.0
0.6
1.2
1.2
2.3
0
0.4
0.8
5.6
5.4
5.4
2.1
0
0
1.9
0
0
0.2
0.4
0.8
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
9:55
10:01
10:07
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
11:31



End
10:01
10:07
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
11:31
11:37



Sum
25
10
10
0
0
10
0
0
0
0
0
0
0
0
10
5
0



Avg.
1.0
0.4
0.4
0
0
0.4
0
0
0
0
0
0
0
0
0.4
Q.2
0



  o
  in
CD
P)
•H
O
r
 o -
             Sketch showing how opacity varied with time;
                     '                 ;	•—i—
                                     1
                              Time, hours
                                     C-37

-------
                             Table   C-22

                             FACILITY:  B
                     SUMMARY OF VISIBLE EMISSIONS
                    Gray Iron Foundry
Date:  July 9. 1974
Type of Plant:_
Type of Discharge; Parti dilates	  Height of Point of Pis charge; 3 ft.  Above Roof
Location of Discharge; Roof Vent	  Height of Observation Point:	
Distance from Observer  to Discharge  Point:	Duration;   3 hrs.,  40  min.	
Direction of Observer from Discharge Point:30 ft. South of Discharge  Point	
Descript. of Background; Sk.y	Wind Direction;  Calm  Color of Plume: Brown
Descript. of Sky; Scattered Clouds Wind Velocity:Not Rec.Detached Plume: No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set Wo.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
8:00
8:06
8:12
8:18
8:24
8:30
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
End
8:06
8:12
8:18
8:24
8:30
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
Sum
0
0
0
0
0
0
0
0
0
0
0
0
15
0
0
0
15
0
0
0
Avg.
0
0
0
0
0
0
0
0
0
0
0
0
0.6
0
0
0
0.6
0
0
0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
10:00
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11:30
11:36



End
10:06
10:12
10:18
10:24
10:30
10:36
10:42
10:48
10:54
11:00
11:06
11:12
11:18
11:24
11;30
11;36
11:40



Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0



Avg.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0



             Sketch showing how opacity varied with time:
  tnf-
•s
?H

-------
                              Table C-23

                              FACILITY: B
                      SUMMARY OF VISIBLE EMISSIONS
  Type  of Plant;  Gray Iron Foundry
  Type  of Discharge; Participates
  Location of Discharge:  Stack
                                                   Date:   July 9,  1974
                                        Height of Point of Discharge; 50  ft.	
                   _  	  Height of Observation Point:   Ground Level
Distance from Observer to Discharge Point; 125 ft.  Duration:   3  hrs.,  39  mi'n.	
Direction of Observer frojn Discharge Point:_    South-East
Descript. of Background:
Descript. of Sky;  Clear
                                  i^tWind Direction:CaJm__Color of Plume; Brown
                                     Wind Velocity;Not Rec.Detached Plume:  No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1:20
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
End
1:26
1:32
1:38
1:44
1:50
1:56
2:02
2:08
2:14
2:20
2:26
2:32
2:38
2:44
2:50
2:56
3:02
3:08
3:14
3:20
Sum
5
0
0
0
60
0
0
0
0
0
0
32
0
85
95
5
0
0
0
10
Avg.
0.2
0
0
0
2.5
0
0
0
0
0
0
1.3
0
3.5
4.0
0.2
0
0
0
0,4
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
3:20
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56



End
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
4:59



Sum
75
25
0
0
105
150
85
0
0
75
180
150
90
120
275
225
65



Avg.
3.1
1.0
0
0
4.4
6.2
3.5
0
0
3.1
7.5
6.2,
3.7
5.0
11.5
9.4
5.4



  LQ

•8
go
^
0)
P)
•H
o
  .
P)
O
  LO
             Sketch showing how opacity varied with time;
                                      1
                              Time, hours
                                     C-39

-------
                             Table  C-24

                             FACILITY: B
                     SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:  Gray  Iron  Foundry
. Date:  .1u1y 9. 1974
 Type of Discharge; Parti dilates	 Height  of  Point  of  Discharge; 3 ft. Above Roof
 Location of Discharge: Roof Vent	 Height,  of  Observation Point;At Vent Level
 Distance from Observer to Discharge Point: 30  ft. Duration;  3 hrs., 35 min.	
 Direction of Observer from Discharge Point: 30 ft. South of Discharge Point	
 Descript. of Background:  Sky	Wind Direction;Ca1m   Color of Plume: Brown
 Descript. of Sky; Clear	Wind Velocity;Not Rec. Detached Plume-..
                        No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1:30
1:36
1:42
1:48
1:54
2:00
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18
3:24
End
1:36
1:42
1:48
1:54
2:00
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18
3:24
3:30
Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
55
0
0
Avg.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2.3
0
0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
3:30
3:36
3:42
3:48
3:54
4:00
4:06
4:12
4:18
4:24
4:30
4:36
4:42
4:48
4:54
5:00




End
3:36
3:42
3:48
3:54
4:00
4:06
4:12
4:18
4:24
4:30
4:36
4:42
4:48
4:54
5:00
5:05




Sum
0
0
0
0
0
0
0
30
0
0
0
0
0
0
0
0




Avg.
0
0
0
0
0
0
0
1.2
0
0
0
0
0
0
0
0




  in

-------
                             Table   C-25
                             FACILITY:   C
                     SUMMARY OF VISIBLE  EMISSIONS
 Type of Plant;   Gyiay Iron  Foundry
                                                   Date:	September 18, 1974
 Type of Discharge: Particulates
 Location of Discharge: Stack
                                  	  Height  of  Point  of Discharge: 15 ft. Above Roof
                                  	  Height,  of  Observation  Point;Even with Stacktop
Distance from Observer to Discharge Point:^0 ft.  Duration: 2 hrs., 8 min.	
Direction of Observer from Discharge Point: Roof, N.W.  of Stack	
Descript. of Background;  Sky	Wind Direction: N.W.
Descript. of Sky:
                    100%  Overcast    Wind Velocity; 0-5
_Color of Plume:  Brown
 Detached Plume:
No
Q)
O
•H
O
a}
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15"
16
17
18
19
20
Start
11:30
11:36
11:42
11:48
11:54
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:24
End
11:36
11:42
11:48
.11:54
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:24
1:30
Sum
285
135
10
20
20
5
15
25
125
210
245
145
185
130
40
70
35
20
0
. 40
Avg.
11.9
5.6
0.4
0.8
0.8
0.2
0.6
1.0
5.2
8.8
10.2
6.0
7.7
5.4
1.7
2.9
1.5
0.8
0
1.7
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1:30
1:36


















End
1:36
1:38


















Sum
65
0


















Avg.
2.7
0


















            Sketch showing how opacity varied with time:
                                      1
                              Time, hours
                                     C-41

-------
                             Table  C-26
                             FACILITY:  C
                     SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:   Gray Iron Foundry
               Date.  September 18, 1974
 Type of Discharge: Participates
    Height of Point of Discharge; 15 ft.
 Location of Discharge; Stack	 Height of Observation Point:Even with Stack Top
 Distance from Observer to Discharge Point: 30 ft. Duration:   2 hrs., 8 min.	
 Direction of Observer from Discharge Point: North-West of Stack	
 Descript. of Background: Sky	Wind Direction:JOL
 Descript. of Sky; 100% Overcast
                      .Color of Plume; Brown
Wind Velocity: 0-5 mphDetached Plume: No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set Wo.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
11:30
11:36
11:42
11:48
11:54
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:24
End
11:36
11:42
11:48
11:54
12:00
12:06
12:12
12:18
12:24
12:30
12:36
12:42
12:48
12:54
1:00
1:06
1:12
1:18
1:24
1:30
Sum
260
130
0
20
0
0
0
40
120
240
200
150
155
120
25
90
15
15
5
50
Avg.
10.8
5.4
0
0.8
0
0
0
1.7
5.0
10.0
8.3
6.2
6.5
5.0
1.0
3.8
0.6
0.6
0.2
2.1
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1:30
1:36


















End
1:36
1:38


















Sum
55
0


















Avg.
2.3
0


















-p
C
OJ
o
P<
s
  o .
             Sketch showing how opacity varied with time:
                                     1
                              Time, hours
                                     C-42

-------
                             Table C-27

                             FACILITY: c
                     SUMMARY OF VISIBLE EMISSIONS
      of Plant;   Gray Iron Foundry
Date:
                                                                        1Q74
 Type  of Discharge;  Parti dilates
                                       Height  of Point of Discharge:  15 ft.  Ahnvp Roof
 Location of Pis charge;  S tac k
                                	 Height,  of Observation Point:gven with Stark

Distance from Observer to Discharge Point;  20  ft.  Duration:  1  hr., 24 min.	

Direction of Observer from Discharge Point:  Roof N.UI.  nf Stark	
Descript. of Background; Sky	Wind Direction: N.W.   Color of Plume; Brown	

Descript. of Sky;  95% Overcast    Wind Velocity;0-5 mph Detached Plume:.
                                                                          Nn
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
2:00
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18






End
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18
3:24






Sum
505
45
70
15
5
105
30
125
0
140
315
150
155
160






Avg.
21.0
1.9
2.9
0.6
0.2
4.4
1.3
5.2
0
5.8
13.1
6.2
6.5
6.7






Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End




















Sum




















Avg.




















 in
 CM
-PO

             Sketch showing how opacity varied with time:
                                      1

                              Time,  hours

                                     C-43

-------
                             Table  C-28
                             FACILITY:  C
                     SUMMARY OF VISIBLE EMISSIONS
 Type of Plant:   Gray Iron Foundry
           Date:  September 18,  1974
 Type of Discharge; Particulates
Height of Point of Discharge; 15 ft.
 Location of Discharge:  Stack
Height, of Observation Point: Even with  Stack Top
 Distance from Observer to Discharge Point; 30 ft. Duration: 1 hr., 24 min.
 Direction of Observer from Discharge Point: 30 ft. N.W. of Stack	
 Descript. of Background; Sky	Wind Direct ion: N.W.   Color of Plume; Brown
 Descript. of Sky;  95% Overcast     Wind Velocity: 0-5 mphDetached Plume: No
 in
 CM
o
O
OJ
 CD
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
2:00
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18






End
2:06
2:12
2:18
2:24
2:30
2:36
2:42
2:48
2:54
3:00
3:06
3:12
3:18
3:24






Sum
495
35
70
25
0
75
20
120
0
95
215
70
135
145






Avg.
20.6
1.5
2.9
1.0
0
3.1
0.8
5.0
0
4.0
9.0
2.9
5.6
6.0






Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End




















Sum




















Avg.




















            Sketch  showing how opacity varied with time:
                                     1
                              Time, hours
                                     C-44

-------
                              Table  C-29
                              FACILITY:  C
                      SUMMARY OF VISIBLE  EMISSIONS
  Type of Plant;   Gray Iron Foundry
  Type of Discharge; Particulates
                                                    .Date;   September 19, 1974
  Location of Discharge; Stack
                                     	 Height of Point of Discharge;! 5 ft. Above Flat

                        	. Height, of Observation Point;20 ft. Above    Roof

  Distance from Observer to Discharge Point: 30 ft.  Duration:2 hrs.. 14 min.  Hase of Stkl

  Direction of Observer from Discharge Point:30 ft.  Roof. East of Stack     	

  Descript.  of Background:_	Wind Direction: S.E.  Color of Plume: Brown

  Descript.  of Shy: Clear and Sunnv   Wind Velocity:0-5     Detached Plume:  No

Set No
_ _

2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20

Start
8:30
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
SUMMARY OF TIME AND AVERAGE OPACITY
End
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
10:30
Sum
290
5
5
0
0
0
40
40
80
10
60
55
75
20
80
325
650
730
140
10
Avg.
12.1
0.2
0.2
0
0
0
1.7
1.7
3.3
0.4
2.5
2.3
3.1
0.8
3.3
13.5
27.1
30.4
5.8
0.4
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
10:30
10:36
10:42

















End
10:36
10:42
10:44

















Sum
25
15
0

















Avg.
1.0
0.6
0

















  o
  co
  LO
  CM
IS


I"
•H
O
05

8
  LO
  o .
             Sketch showing how opacity varied with time;
                                     1
                              Time,  hours

                                     C-45

-------
                             Table C-30
                             FACILITY:  C
                    SUMMARY  OF VISIBLE EMISSIONS
Type of Plant:   6rav Iron Foundry
                                                   Date:   September 19, 1974
Type of Discharge; Particulates
                                        Height  of Point  of  Discharge:  15 ft.
Location of Discharge;  Stack
                      	Height  of Observation Point: Even with Base of
Distance from Observer to Discharge  Point: 30 ft.  Duration:  2 hrs.. 16 mln.	 stac
                                             30 ft. East of Stack	
Direction of Observer from Discharge Point:_
Descript. of Background; Sky   	Wind Direction :_S.E.
Descript. of Skv: Clear  and  Sunny    Wind Velocity: 0~5"
_Color of Plume :
 Detached Plume :
                                                                          Brown_
SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
8:30
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
End
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
10:30
Sum
24b
0
5
0
0
0
45
15
60
0
45
70
55
20
80
335
605
680
140
5
Avg.
10.2
0
0.2
0
0
0
1.9
0.6
2.5
0
1.9
2.9
2.3
0.8
3.3
14.0
25.2
28.3
5.8
0.2
Set Wo.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
10:30
10:36
10:42

















End
10:36
10:42
10:46


















Sum
10
5
0


















Avg.
0.4
0.2
0

















  o
  CO
  If)
o
•H
O
 ^ILO
            Sketch  showing how opacity varied with time:
                                     _L
                              Time, hours
                                    C-46

-------
                             Table  C-31
                              FACILITY:  D
                     SUMMARY  OF VISIBLE  EMISSIONS
 Type of Plant;   Gray  Iron Foundry
                Date:    October  1,  1974
 Type of Discharge; Dust
     Height of Point of Discharge; 20 ft.
 Location of Discharge; Baghouse Outlet Height of Observation Point: Ground Level
 Distance from Observer to Discharge Point: 50 ft. Duration: 87 min.	
 Direction of Observer from Discharge Point: South	
 Descript. of Background;  Sky
 Descript. of Sky;  Overcast
_Wind Direction:
_Wind Velocity; 3
East
 to 5
_Color of Plume;  White
 Detached Plume:    No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
3:20
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44





End
3:26
3:32
3:38
3:44
3:.50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:47





Sum
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0





Avg.
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0





Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End




















Sum




















Avg.




















o
-p
•H


I"
             Sketch showing how opacity varied with time:
                                     _L
                                     1
                              Time, hours

                                     C-47

-------
                              Table C-32
                              FACILITY:  D
                     SUMMARY  OF  VISIBLE EMISSIONS
 Type of Plant;  Gray  Iron  Foundry
                                                   Date:   October 1, 1974
                                                                       80 ft.
Type of Discharge;Furnace Roof Exhaust Height  of  Point  of  Discharge:.
Location of Discharge;Fur. Roof ExhaustHeight  of  Observation  Point:  Ground Level
Distance from Observer to Discharge Point: 90 ft. Duration: 120 min.	
Direction of Observer from Discharge Point:	South	
Descript. of Background: Sky	Wind Direction; East  Color  of  Plume: White
Descript. of Sky; Overcast-Part.Cldywind Velocity: 3 to 5 Detached  Plume:  No
                  SUMMAEY OF TIME AND AVERAGE  OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
3:20
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08
5:14
End
3:26
3:32
3:38
3:44
3:50
3:56
4:02
4:08
4:14
4:20
4:26
4:32
4:38
4:44
4:50
4:56
5:02
5:08
5:14
5:20
Sum
120
120
120
120
120
120
120
120
175
120
120
120
120
120
120
135
120
120
120
120
Avg.
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
7.3
5.0
5.0
5.0
5.0
5.0
5.0
5.6
5.0
5.0
5.0
5.0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End




















Sum




















Avg.




















1
o
J?
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             Sketch showing how opacity varied with time:
                                     1
                              Time, hours

                                     C-48

-------
                            : 'Table C-33
                              FACILITY: D
                     SUMMARY OF. VISIBLE EMISSIONS
Type of  Plant:    Gray Iron Foundry
                                                     Date:.-	October 2, 1974
                                         Height of Point of Discharge:   20  ft.
 v fr           a*i o^ •	     .   	..           j.j.-»._i_^ii v  vj.  j. WJ.AA \j w.i_ j_/ _i_o v-iJ.o.j. £^C •   —•*•  • ** •	
Location  of  Discharge; Baghouse Outlet  Height  of  Observation Point: Ground  Level"
Distance  from Observer to Discharge Point: 50  ft. Duration: 210 min.	
Direction of Observer from  Discharge Point:    South	ZZZIZZZZZZIZZZ^ZZ
Descript.  of Background;   Sky	wind Direct ion; South  color of Plume: White
      or  ~	~-~o™ — —-.••*— *     \j       at ,i-j,i.\ju u J-JL. \^\~ \j _I_WAJ. »^ _    	w\J_1_W-L \J J. JT .LUIUC •
Descript.  of Sky; Partly  Cloudy     wind Velocity:20  to 30Detached Plume:  No
SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1A.M.
2
3
4
5
6
7
8
9
10
11
12 P.M.
13
14
'15
16
17
18
19
20
Start
9:25
9:31
9:37
9:55
10:01
10:07
10:13
10:15
10:21
10:27
10:39
3:10
3:16
3:22
3:28
3:34
3:40
3:46
3:52
3:58
End
9:31
9:37
9:55
10:01
10:07
10:13
10:15
10:21
10:27
10:39
10:41
3:16
3:22
3:28
3:34
3:40
3:46
3:52
3:58
4:04

Sum
0
0
No R
0
0
0
0
No R«
10
No R(
5
0
0
0
0
0
0
0
0
0

Avg.
0
0
ading
0
0
0
0
ading
0.4
ading
0.6
0
0
0
0
0
0
0
0
0

Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Start
4:04
4:10
4:16
4:22
4:28
4:34
4:39
4:48
4:54
5:00
5:06
5:12
5:18
5:24
5:30
5:36
5:42
5:48
5:54
6:00
6:06
End
4:10
4:16
4:22
4:28
4:34
4:39
4:48
4:54
5:00
5:06
5:12
5:18
5:24
5:30
5:36
5:42
5:48
5:54
6:00
6:06
6:10
Sum
0
0
0
0
0
0
No Re
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Avg.
0
0
0
0
0
0
idings
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2 Sketch showing how opacity varied with time: 4

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1 3 '



-

PM 	 	
-

AM
i i

-


m


.

-

0 2
                              Time,  hours
                                     C-49

-------
                             Table  C-34
                             FACILITY:  D
                     SUMMARY OF VISIBLE EMISSIONS
Type of Plant; Gray Iron Foundry
           Date:   October 2, 1974
Type of Discharge: Dust
Height of Point of Discharge: 80 ft.
AJ LJG WJ. J-f J-t» W1.J.MJ. O1-* '     	  • --•-      	W                               .      _
Location of Discharge:Furnace Roof Exst.Height of. Observation Point: Ground  Level
Distance from Observer to Discharge Point:90 ft.  Duration: 120 mln.—_	
Direction of Observer from Discharge Point:   South    	.——	
Descript. of Background:.  Skv	Wind Direction:_Sou±h__.Color of Plume:
Descript. of Skv:C1ear. Set.  Clds.  Wind Velocity; 20  to  SODetached Plume:.
                                   No
RTTMMARY OF TTMF, AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
9:25
9:31
9:37
9:43
9:49
9:55
10:01
10:07
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55 .
11:01
11:07
11:13
11:19
End
9:31
9:37
9:43
9:49
9:55
10:01
10:07
10:13
10:19
10:25
10:31
10:37
10:43
10:49
10:55
11:01
11:07
11:13
11:19
11:25
Sum
5
10
110
0
0
65
120
120
120
120
120
120
120
120
120
120
120
120
120
120
Avg.
0.2
0.4
4.6
0
0
2.7
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End





















Sum





















Avg.




















•8
0)
o
P4
$
O
;$ in
8f
  o
             Sketch showing how opacity varied with time:
                               Time, hours
                                      C-50

-------
                              Table  C-35

                              FACILITY: D
                      SUMMARY OF VISIBLE EMISSIONS
 Type of Plant;  Gray Iron  Foundry
                                                  .Date:   October 2. 1974
 Type of Discharge;  Dust
                                        Height of Point of Discharge:  80 ft.
 Location of Pis charge; Furnace Roof  Exst .Height of Observation Point; Ground Level
 Distance from Observer to Discharge Point;  90 ft. Duration; 180 min.	
                                              South
Direction of Observer from Discharge Point:_
Descript. of Background;  Sky	Wind Direction; South
                                                           Color of Plume;  White
 Descript. of Sky; Clear,  Scat. Clds.Wind Velocity: 20 to 3QDetached Plume; No
                  SUMMARY  OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
JL9
20
Start
3:10
3:16
3:22
3:28
3:34
3:40
3:46
3:52
3:58
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
End
3:16
3:22
3:28
3:34
3:40
3:46
3:52
3:58
4:04
4:10
4:16
4:22
4:28
4:34
4:40
4:46
4:52
4:58
5:04
5:10
Sum
120
120
120
120
120
120
120
120
120
120
120
120
150
140
120
165
150
120
120
120
Avg.
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
6.3
5.8
5.0
6.9
6.3
5.0
5.0
5.0
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
5:10
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
6:04










End
5:16
5:22
5:28
5:34
5:40
5:46
5:52
5:58
6:04
6:10










Sum
120
120
120
120
120
120
120
120
120
120










Avg.
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0
5.0










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                                      1
                               Time,  hours
                                     C-51

-------
                             Table C-36
                             FACILITY: D
                    SUMMARY  OF VISIBLE EMISSIONS
Type of Plant;  Gray  Iron  Foundry
           Date:   October 3, 1974
Type of Discharge;  Dust
Height of Point of Discharge: 20 ft.
Location of Discharge:BaqhOUSe Outlet   Height, of Observation Point; Ground Level

Distance from Observer to  Discharge Point:  50 ft .-Duration:  82 min.	

Direction of Observer from Discharge Point;  South	
Descript. of Background:. Sky        Wind Direction:JJL._Color of Plume:JslM±e_
Descript. of Skv: Partly  Cloudy      Wind Velocity: 20 to 35petached Plume:.
                                  No
K1TMMA-RY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
9:18
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
10:29
10:52
10:58





End
9:24
9:30
9:36
9:42
9:48
9:54
10:00
10:06
10:12
10:18
10:24
10:29
10:52
10:58
11:03





Sum
0
0
0
0
0
0
0
100
20
0
0
0
No Re
120
100





Avg.
0
0
0
0
0
0
0
4.2
0.8
0
0
0
idings
5.0
5.0





Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End





















Sum





















Avg.





















-------
                              Table  C-37

                              FACILITY:  D
                      SUMMARY OF VISIBLE EMISSIONS
 Type of Plant; Gray Iron Foundry
                Date:   October 3, 1974
 Type of Discharge;  Dust
     Height of Point of Discharge: 80 ft.
 Location of Pis charge; Furnace  Roof  Exst-Height of Observation Point; Ground Level
 Distance from Observer to Discharge Point; 90 ft. Duration; 63 min.	
 Direction of Observer from Discharge Point; South	
 Descript. of Background;  Sky	Wind Direction; S.W
                       Color of Plume;  Whi'tp
 Descript. of Sky;Partly  Cloudy
_Wind Velocity: 20 to 35Detached Plume:    No
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set Wo.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
9:03
9:09
9:15
9:18
10:47
10:53
10:57
11:08
11:14
11:20
11:26
11:32
11:38
11:44






End
9:09
9:15
9:18
10:47
10:53
10:57
11:08
11:14
11:20
11:26
11:32
11:38
11:44
11:46






Sum
0
20
20
No Re
120
80
No Re
120
120
120
120
120
120
40






Avg.
0
0.8
1.7
idings
5.0
5.0
idings
5.0
5.0
5.0
5.0
5.0
5.0
5.0






Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End




















Sum




















Avg.




















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                                     1

                              Time,  hours

                                     C-53

-------











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C-57

-------
                  TABLE C-42.  SUMMARY  OF PARTICULATE  RESULTS
                        STEEL FURNACES  (UNITED STATES)
Sampling
time
Facility min
G 60

60

60

60

H 60

60

I 80

80

30

J 240

K 88

88

88

Nominal Exhaust
furnace capacity flowrate
Mg mVmin
(ton) (ft3/min)
27.2
(30)






29.9
(33)


33.1
(36.5)
33.1
(36.5)
33.1
(36.5)
27.2
(30)
5.4
(6)
5.4
(6)
5.4
(6)
1,948a
(68,800)






2,180a
(77,000)


732
(25,857)
729
(25,754)
734
(25,850)
2,905
(102,600)
310
(10,945)
301
(10,615)
299
(10,552)
Stack
Particulate emissions
temperature mg/Nnr*
°C kg/h (gr/dscf)
(°F)
	
•






—
—


56
(133)
59
(139)
60
(140)
49
(120)
68
(154)
63
(146)
65
(149)
(Ib/h) Test
9.15
(0.004)
5.72
(0.0025)
6.87
(0.003)
36.6
(0.016)
4.58
(0.002)
6.87
(0.003)
0.46
(0.05) (0.0002)
2.75
(0.27) (0.0012)
. 8.70
(0.85) (0.0038)
—
— —
13.5
(0.5549) (0.0059)
12.8
(0.5130) (0.0056)
21.7
(0.8613) (0.0095)
Average
14.6
(0.0064)






5.73
(0.0025)


3.97
(0.0017)




6.64
(0.0029)
16.0
(0.0070)




^Nominal.
 Dry standard.
                                      C-58

-------
                              Table  C-43
                                                    Date:July 14, 1976
                              FACILITY:  G
                      SUMMARY OF VISIBLE EMISSIONS
                              Heat 1206
 Type of Plant;  Steel  Foundry	
 Type of Discharge: Partlculate	                               	
 Location of Discharge; Baghouse outlet Height of Observation Point;ground level
 Distance from Observer to Discharge  Point;10-15 m  Duration: 155 min.
 Direction of Observer from  Discharge Point:_	
 Descript. of Background; sky
 Descript. of Sky; clear	
                                        Height  of  Point  of  Discharge:  10-15 m
                                    Wind Direction; NW     Color  of Plume:qrey-white
                                   _Wind Velocity; 3-7mph Detached  Plume:.
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
0929
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
End
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
1129
Sum
5
5
20
0
15
0
85
95
145
525
285
55
0
10
65
60
155
150
130
190
Avg.
0.2
0.2
0.8
0.0
0.6
0.0
3.5
4.0
6.0
21.9
11.9
2.3
0.0
0.4
2.7
2.5
6.5
6.3
5.4
7.9
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1129
1135
1141
1147
1153
1159














End
1135
1141
1147
1153
1159
1204














Sum
375
15
50
0
0
0














Avg.
15.6
0.6
2.1
0.0
0.0
0.0














  cv
  to
  If).
d)
CJ
fn UT
£ «4*
ft
CJ
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            Sketch  showing how opacity varied with time:
            	1	1	
                      Tap
      Charge


B
/

ac

:kc
                                     _L
                                     1
                              Time, hours

                                  C-59

-------
                             Table  C-44
                             FACILITY: 6
                     SUMMARY OF VISIBLE EMISSIONS
                             Heat 1206
 Type  of Plant;  Steel  Foundry
                                                  .Date:  July 14. 1976
Type of Discharge:Particulate
Location of Pischarge;Roof Vent A
                                                                       85 ft.
Height of Point of Discharge:.
Height of Observation Point:   75  ft.
                                            50
                                                   Duration;
Distance from Observer to Discharge Point:
Direction of Observer from Discharge Point:  SE of Stack
 Descript.  of Background;  Dark wall  Wind Direction:  NW    Color of Flume: Grey_
 Descript.  of Sky;  Partly  Cloudy    wind Velocity: 3-7 mph Detached Plume:.No	
                  SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
0929
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
End
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
1129
Sum
30
0
0
0
0
0
0
0
0
0
150
45
0
0
0
0
0
0
0
0
Avg.
1.2
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
6.2
1.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1129
1135
1141
1147
1153
' 1159
1205













End
1135
1141
1147
1153
1159
1205
1208













Sum
0
0
0
0
0
310
0













Avg.
0.0
0.0
0.0
0.0
0.0
12.9
0.0













 LO
CLO

-------
                              Table  C-45
  Type of Plant:.
             FACILITY:  6
     SUMMARY OF VISIBLE EMISSIONS
             Heat 1206
Steel Foundry
  Type of Discharge; Particulate
                                                   Date:  July  14,  1976
                        Height of Point of Discharge:.
                        Height of Observation Point:
                                                                      85 ft.
                                                               159 min.
                                                                        75 ft.
Location of Discharge; Roof Vent B       _&_.  _  _=i _u^
Distance from Observer to  Discharge  Point:  25  ft.  Duration:
Direction of Observer from Discharge Point:    SE  of  stack
Descript. of Background: Dark  wall  Wind Direction; NW     Color of Plume:
Descript. of Sky;  Partly Cloudy   Wind Velocity;  3-7 mphDetached Plume i  No
                                                                            Grey

Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
SUMMARY OF TIME AND AVERAGE OPACITY
Start
09~2~9"
0935
0941
0947
0953
0959
1,005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
End
0935
0941
0947
0953
0959
1005
1011
1017
1023
1029
1035
1041
1047
1053
1059
1105
1111
1117
1123
1129
Sum
3b
0
0
0
0
0
0
0
0
0
190
40
0
0
0
0
0
0
0
0
Avg.
I.B
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
7.9
1.7
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set No
21
22
23
24
25
26
27
28
29
30
31
•ZO
Oe:
33
34
35
36
37
38
39
40
Start
1129
1135
1141
1147
1153
• 1159
1205













End
1135
1141
1147
1153
1159
1205
1208













Sum
0
0
0
0
0
400
0













Avg.
0.0
0.0
0.0
0.0
0.0
16.7
0.0













  o
  IT)
M
d>
P)
P)
otn
 o -
             Sketch showing how opacity varied with time;
                              	1	
                        Tap
      ?
                                        Backcharge
                                      1
                              Time, hours
                                  C-61

-------
                             Table  C-46
Type of Plant:
                             FACILITY:  G

                    SUMMARY  OF VISIBLE EMISSIONS

                             Heat 1207


                     foundry	
                                                   Date:    Julv  14,  1976
Type of TVisnharge;  pa*.H ml ate
                                  	  Height of Point of Discharge:!0-15  m 	


Location of Discharge: Baohouse Outlet  Height of Observation Point:.qround level


Distance from Observer to Discharge  Point:lO-lSm  Duration:  135 min.	
Direction of Observer from Discharge Point:	

Descript. of Background: _Sky	Wind Direct ion :_NW_

Descript. of Skv. r.lpar to overcast Wind Velocity: 3-7 mph Detached Plume:.
                                                          color of PIurne;grey white
SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5

7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
End
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
1410
Sum
90
30
90
40
25
100
135
75
20
0
0
0
75
45
50
30
5
205
285
30
Avg. {
3,8
1.3
3.8
1.7
1.0
4.2
5.6
3.1
0.8
0.0
0.0
0.0
3.1
1.9
2.1
1.3
0.2
8.5
11.9
1.3
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1410
1416
1422


















End
1416
1422
1425


















Sum
0
0
0


















Avg.
0.0
0.0
0.0

















             Sketch showing how opacity varied with time:
 
      Charge
                              Backcharge
                                                                             Tap
                                                                                \
                                      1

                               Time, hours




                                    C-62

-------
                            Table  C-47
                            FACILITY:  S
                    SUMMARY OF VISIBLE EMISSIONS
                            Heat 1207
Type of Plant: Steel Foundry
Type of Discharge; Partlr.nlat.P
                    .Date:  July 14. 1976
                                         85 ft.
                                	 Height  of Point of Discharge:
Location of Discharge: Roof Vent A     Height  of Observation Point:  75 ft.
Distance from Observer to Discharge Point; 50 ft. Duration; 136 min.	
Direction of Observer from Discharge Point:  SE of stack	
Descript. of Background:Dark wall
Descript. of Sky; Partly Cloudy
                                   Wind Direction:
                           .Color of Flume:  Grey
                                  _₯ind Velocity; 3-7 mph Detached Plume:   No
                 SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
End
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
1410
Sum
45
0
0
0
0
0
0
0
135
0
0
0
0
0
0
0
0
0
0
0
Avg.
1.9
0.0
0.0
0.0
0.0
0.0
0.0
0.0
5.6
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1410
1416
1422

















End
1416
1422
1426

















Sum
0
0
200

















Avg.
0.0
0.0
12.5

















           Sketch showing how opacity varied with time:
      Charge
Backcharge
 /
                                   _L
                                                                         Tap
                            Time, hours
                                C-63

-------
                             Table C-48


                             FACILITY: G

                    SIBMARY  OF VISIBLE EMISSIONS

                             Heat 1207
Type of Plant:  Steel  Foundry
                                                   Date:  Julv 14. 1976
Type of Discharge:  Parti Clll ate
                                       Height  of Point of Discharge: 85 ft.
                                        Height, of Observation Point:  75  ft.


Distance from Observer to Discharge  Point:  25 ft_._Duration:  136 min...
Location of Discharge:_Roof_Vent_B_
Direction of  Observer  from Discharge Point:  SE of Stack

Descript. of  Background:Dark wall   Wind Direction:_NW	

Descript. of  Sky;   Partly Cloudy   Wind Velocity: 3-7 mphDetached Plume:
                                                          Color of Plume: Grey ._

                                                                            No
qnMMARY Otr TTMF, AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
1210
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
End
1216
1222
1228
1234
1240
1246
1252
1258
1304
1310
1316
1322
1328
1334
1340
1346
1352
1358
1404
1410
Sum
10
0
0
0
0
0
0
0
115
0
0
0
0
0
0
0
0
0
0
0
Avg.
0.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
1410
1416
1422

















End
1416
1422
1426


















Sum
0
0
385


















Avg.
0.0
0.0
24.1

















  in
  CM:




!<°
o

CD ,
•H
O

-------
                              Table  C-49
                              FACILITY:  I
                      SUMMARY OF VISIBLE EMISSIONS
                             Heat El -3251
 Type  of Plant;   Steel  Foundry
                                       	Date:  July 21. 1976

                                       Height  of Point of Discharge: 20
 Type  of Discharge;  Stack	

 Location  of Discharge;  Baghouse  outlet  Height of Observation Point; ground

 Distance  from Observer  to Discharge Point;30  m     Duration; 222 min	
                                               NE
Direction of Observer from Discharge Point:

Descript. of Background: Sky	Wind Direction:

Descript. of Sky:  Overcast	wind velocity :J
                                                          _Color of Plume:.

                                                           Detached Plume:
                  SUMMARY OF TIME AND  AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
6:18
6:24
6:30
6:36
6:42
6:48
6:54
7:00
7:06
7:12
7:18
7:24
7:30
7:36
7:42
7:48
7:54.
8:00
8:06
8:12
End




















Sum
0
0
15
80
0
0
0
0
0
0
0
10
55
0
0
0
0
0
0
0
Avg.
0.0
0.0
0.6
3.3
0.0.
0.0
0.0
0.0
0.0
0.0
0.0
0.4
2.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
Set No
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
8:18
8:24
8:30
8:36
8:42
8:48
8:54
9:00
9:06
9:12
9:18
9:24
9:30
9:36
9:42
9:48
9:54



End




















Sum
0
85
0
0
0
0
0
0
0
0
65
0
0
0
0
0
0



Avg.
0.0
3.3
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
2.7
0.0
0.0
0.0
0.0
0.0
0.0



s
0)
oo
f-f
Q)
-p
-H
O
05
  O -
             Sketch showing how opacity varied with time:

                                      1	:	1—
                   T
                    Oxygen Lance
                                   Oxygen Lance
                     A
                                                     Backcharge

                                                         \
                                      1

                              Time, hours


                                    C-65

-------
                             Table  C-50
                             FACILITY:   J
                    SUMMARY  OF VISIBLE EMISSIONS
                           Heat El -3251
Type of Plant: Steel  Foundry
                                                   Date:
Type of Discharge:  Roof  Vent
                                        Height of Point of Discharge; 25
j_ v M v ^* •*• A^-t, w vj A. ^ «-**-!. Q^* •                	  —  	  *—'

Location of Pischarge:Roof of Building  Height of Observation Point:

Distance from Observer to Discharge  Point:45 m    Duration: 108  irrin.
                                                                      10 m
                                               West
Direction of Observer  from Discharge Point:		_—

Descript. of Background: Bui 1 di ng   Wind Direct ion :yariabT_«olor of  Plume:.

Descript. of Sky;  Overcast	.Wind Velocity:	Detached  Plume:.
KTTMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
7:51
7:57
8:03
8:20
8:26
8:32
8:38
8:44
8:50
8:56
9:10
9:16
9:22
9:28
9:34
9:40
9:46
9:55


End


8:09






9:02










Sum
35
0
0
0
0
0
0
30
0
10
20
115
160
100
125
75
240
0


Avg.
1,5
0.0
0.0
0.0
0.0
0.0
0.0
1.3
0.0
0.4
0.8
4.8
6.7
4.2
5.2
3.1
10.0
0.0

_ r» t
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start




















End





















Sum





















Avg.




















•8
0)
o

oJir>
Pr-

 *\
>£3

•H
O
O)
          Last data  set  consists  of 16 readings

             Sketch showing how opacity varied with time:
                                           Oxygen Lance
        Backcharge
                                      1

                               Time,  hours

                                   C-66

-------
                              Table C-51
                              FACILITY:  *
                      SUMMARY OF VISIBLE EMISSIONS
                           Heat  El -3255
 Type of Plant; Steel Foundry
 Type of Discharge; Stack
           Date: July 22, 1976
Height of Point of Pischarge:20 m
 Location of Discharge;Baghouse outlet   Height of Observation Point: ground
 Distance from Observer  to  Discharge Point: 30 m    Duration;    216 mln.	
 Direction of Observer from Discharge Point:  West	
 Descript. of Background: Sky	wind Direct ion yariablecolor of Plume:	
 Descript. of Sky;  Overcast	Wind Velocity:	Detached Plume:	
                  SUMMARY OF TIME AND AVERAGE  OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
7:53
7:59
8:05
8:11
8:17
8:23
8:29
8:35
8:41
8:47
8:53
8:59
9:05
9:11
9:17
9:23
9:29
9:35
9:41
9:47
End




















Sum
0
0
0
0
0
50
0
0
0
0
0
0
0
0
45
0
0
0
0
0
Avg.
0.0
0.0
0.0
0.0
0.0
2.1
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.9
0.0
0.0
0.0
0.0
0.0
Set No
21
22 .
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
9:53
9:59
10:05
10:11
10:17
10:23
10:29
10:35
10:41
10:47
10:53
10:59
11:05
11:11
11:17
11:23




End




















Sum
0
0
0
95
0
0
0
0
0
0
0
0
0
55
0
0




Avg.
0.0
0.0
0.0
4.0
0.0
0.0
0.0
0.0
0.0
0.0
c.o
0.0
0.0
2.3
0.0
0.0




(U
o
-P
•H
O
0}
  to
             Sketch showing how opacity varied with time:
                     Oxygen Lance
                                                          Backcharge
                                     _L
                              Time, hours
                                   C-67

-------
                             Table  C-52

                             FACILITY:  I
                    SUMMARY  OF VISIBLE EMISSIONS
                           Heat  El-3255
Type of Plant; Steel  Foundry
       Date:  July 22.  1976
Type of Discharge; Electric Arc Furnace Height of Point of Discharge; 25 m

Location of Discharge: Roof Vent	 Height of Observation Point: 10 m
Distance from Observer to  Discharge  Point;45 m    Duration:  210 min.

Direction of Observer from Discharge Point: West	
Descript. of Background: Building  Wind Direction:variablgolor of Plume:_
Descript. of Sky; Overcast	Wind Velocity:	Detached Plume:_
SUMMARY OF TIME AND AVERAGE OPACITY
Set No.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Start
7:56
8:02
8:08
8:14
8:20
8:26
8:32
8:38
8:44
8:50
8:56
9:02
9:08
9:14
9:20
9:26
9:32
9:38
9:44
9:50
End




















Sum
90
25
110
0
0
0
5
0
0
0
5
0
0
0
0
10
0
10
25
135
Avg.
3.8
1.0
4.6
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.2
0.0
0.0
0.0
0.0
0.4
0.0
0.4
1.0
5.6
Set No.
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
Start
9:56
10:02
10:08
10:14
10:20
10:26
10:32
10:38
10:44
10:50
10:56
11:02
11:08
11:14
11:20





End














11:26






Sum
b
5
0
0
0
25
120
165
35
0
0
85
0
235
0






Avg.
0.2
0.2
0.0
0.0
0.0
1.0
5.0
6.9
1.5
0.0
0.0
3.5
0.0
9.8
0.0





0
t-t
•H
O
            Sketch  showing how  opacity varied with time:
            	1—	1	r-
                     Oxygen Lance
LJ
             Backcharge
                                     1
                              Time, hours
                                   C-68

-------
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-------
C.5  REFERENCES FOR APPENDIX C

 1.  Air Pollution Emission Test:  John Deere Tractor Works, Waterloo,
     Iowa.   U.S. Environmental Protection Agency.  Research Triangle Park,
     N.C.  EMB Report No. 75-GFE-l.  June 1974.

 2.  Source Sampling:  John Deere Tractor Works, East Moline, Illinois.
     U.S. Environmental Protection Agency.  Research Triangle Park, N.C.
     EMB Report No. 74-GFE-2.  July 1974.

 3.  Air Pollution Emission Test:  The Gleason Works, Rochester, New York.
     U.S. Environmental Protection Agency.  Research Triangle Park, N.C.
     EMB Report No. 75-GFE-4.  January 1975.  85 p.

 4.  Air Pollution Emission Test:  The Paxton-Mitchell Plant, Omaha,
     Nebraska. U.S. Environmental  Protection Agency.  Research Triangle
     Park, N.C.  EMB Report No.  75-GFE-3.   February 1975.   173 p.

 5.  Letter and attachment from  Hevey, L. A., State of Wisconsin Department
     of Natural Resources, to Georgieff,  N. T.,  EPA.  November 21,  1974.
     Report of  source test at Beloit Corporation,  Beloit, Wis.

 6.  Letter and attachment from  Cropper,  W. V.,  American Society for
     Testing  and Materials, to Ajax, R. J., EPA.   June 27,  1974.
     Submission of Draft  D 2928  Report.

 7.  Telecon.   Georgieff, N. T.,  EPA, to  Bencus, H., The Gleason Works.
     February 20,  1980.   Information on carbon  injection via pressure
     lancing.

 8.  Memo from  McCarley,  J.  E.,  Jr., EPA,  to Georgieff, N.  T. , EPA.
     December 3,  1974.   State of Wisconsin  Test Report, Beloit Corporation,
     Beloit,  Wisconsin.

 9.  Memo from  Kelly, W.  E.,  EPA,  to Georgieff,  N.  T., EPA.  July  19,  1974.
     Gray iron  foundry  data  contained  in  ASTM  D-2928  Report.

 10.  Memo from  McCarley,  J.  E.,  Jr., EPA, to Georgieff, N.  T., EPA.
     July 19, 1974.   Gray iron  foundry test ASTM  D-2928  Report.

 11.  Letter  from  Wasem,  J. W.,  American  Steel  Foundries,  to Goodwin,  D.  R.,
     EPA.  June 18,  1976.   Response  to Section 114 letter  on emission test
     results.

 12.  Allegheny  County Health Department.   Source Test of  Baghouse  on  Steel
     Electric Arc Furnace at Bucyrus-Erie,  Glassport,  Pennsylvania.
     Pittsburgh,  Pennsylvania.   May  1975.

 13.  Telecon.  Glenn,  D., Buckeye Steel  Casting Company,  to Georgieff, N.  T.,
      EPA.   September 18, 1976.   Information on source tests at Buckeye
     Steel  Casting Co.
                                    C-70

-------
 14.  Memo  and  attachments  from  Spawn,  P.,  GCA/Technology Division,  to EAF
     file.   September  16,  1977.   16  p.   Report of September 1977 plant visit
     to Hensley  Industries,  Inc.,  Dallas,  Tex.

 15.  Telecon.  Welzel,  K., Landesanstalt fur Immissions  und
     Bodennutzungsschutz des  Landes  Nordrhein-Westfalen,  to
     Georgieff,  N. T.,  EPA.   June  10,  1976.   Information on source
     test  at German  steel  EAF.

 16.  Letter  and  attachments  from Welzel,  K.,  Landesanstalt fur Immissions
     und Bodennutzungsschutz  des Landes  Nordrhein-Westfalen,  to
     Georgieff,  N. T.,  EPA.   June  16,  1976.   Information on source
     tests at  German steel EAF's.

 17.  Letter  from Rohrick, Thyssen  Giesserei  AG, to  N. T.  Georgieff,  EPA.
     June  24,  1976.  Information on  source  tests  at German steel  EAF's.

 18.  Letter  from Berton, D.,  Air Industrie,  to Georgieff,  N.  T.,  EPA.
     June  18,  1976.  Information on  French  foundry  EAF's.

 19.  Letter  from Bozzetti, M. A.,  Air  Industrie,  S.P.A.,  to Georgieff,  N. T.,
     EPA.   March 4, 1976.  Information on Italian foundry EAF's.

20.  Letter  and  attachments from Mitrick, S.  F.,  American Steel  Foundries,
     to Goodwin, D. R., EPA.   October 26, 1976.   Information  on steel
     foundry EAF source tests.

21.  Memo  from McCarley, J. E., Jr., EPA, to  Cuffe, S. T.,  EPA.
     December  27, 1979.  Review of EAF foundry test reports.

22.  Memo and  attachments from Shepherd, J.  L., Buckeye  Steel  Castings,
     to Georgieff, N. T., EPA.  December 11,  1979.  Information on
     steel foundry EAF source test.

23.  Memo and  attachments from Harrison, R. T., and D. Holzschuh, EPA,
     to McCarley, J.  E., Jr., EPA.  July 26,  1976.  Trip  report
     of visible emission observations of an EAF at  American Steel Foundry.

24.  Memo and attachments from Harrison R. T., EPA, to McCarley, J.  E., Jr.,
     EPA.   August 17, 1976.  Trip  to observe  visible emissions  of a  steel
     foundry EAF.

25.  Memo and attachment from Georgieff, N. T., EPA, to Spawn,  P.,
     GCA/Technology Division.  March 15, 1978.  Information on  flowrates.

26.  Fennelly, P. F.  and P. D. Spawn.  Air Pollutant Control  Techniques for
     Electric Arc Furnaces in the  Iron and Steel  Foundry  Industry.   U.S.
     Environmental Protection Agency.  Research Triangle  Park,  N.C.
     Publication No.  EPA-450/2-78-024.   June  1978.  221 p.
                                   C-71

-------
27.   Emission Test Report:   Armco Steel, Torrance, California.   U.S.
     Environmental Protection Agency.   Research Triangle Park,  N.C.
     EMB Report No. 79-ELO6.  May 1979.
                                    C-72

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                                APPENDIX D
              EMISSION  MEASUREMENT AND  CONTINUOUS  MONITORING

 D.I   EMISSION MEASUREMENT METHODS
 D.I.I   Control  Device  Exhaust
      Participate  emissions were measured at  six iron  foundry  electric  arc
 furnaces  (EAF's)  and five steel-producing EAF's.   Five of  the iron  foundry
 EAF tests were  conducted  using  EPA Reference Method 5 (Appendix A 40 CFR
 Part  60).  The  sixth iron foundry EAF  test was conducted using a modified
 version of EPA  Reference  Method 5 where  an additional in-stack filter  was
 added to the  standard Method 5  sampling  configuration, fewer  than the
 required minimum  number of traverse points were used, and  a water wash of
 the probe was added in addition to the acetone wash.  However, the  data
 are judged to be  reasonably close to those obtained by a standard Method 5.
 The five steel-producing  EAF particulate  results were obtained from
 industry representatives.  These were reportedly obtained  using EPA
 Reference Method 5.  EPA  did not  review the detailed emission test  reports.
 Visible emission observations were made at the control system exhaust  at
 four of the ironLproducing EAF's and two of the steel-producing EAF's
 following EPA Reference Method 9  (Appendix A 40 CFR Part 60).
 D.I.2  Visible Emission at the Shop Roof Vent or Monitor
     Visible emission observations were made at the shop roof vent or
monitor of three of the iron-producing EAF's and two of the steel-producing
 EAF's.  Except for one plant where a modified version of Method 9 was
 used,  EPA Reference Method 9 was followed for the testing.   A modified
Method 9 was used at one plant because of the configuration of the plant.
 In this case, the observers read visible emissions from a position approxi-
mately perpendicular to the roof monitor.
                                   D-l

-------
D.2  MONITORING SYSTEMS AND DEVICES
D.2.1  Opacity Monitoring Systems
     The monitoring systems that are adequate for monitoring opacity from
control system exhausts from other stationary sources, such as steel
plant electric arc furnaces, are described by performance specifications
contained in Appendix B of 40 CFR 60 Federal Register, October 6, 1975.
They are technically feasible for control systems generally employed at
foundry electric arc furnaces.   In a case where condensed moisture would
be present in the control system exhaust, monitoring  of opacity would  not
be applicable; therefore, another operating parameter would need to be
monitored as an indication of emission control.
     Equipment and installation  costs for opacity monitoring  are estimated
to be  about $18,000 to  $20,000 per site.  Annual operating costs which
include the recording  and  reducing of the data  are  estimated  at  about
$8,000 to $9,000 per site.   Some savings in  operating costs may  be  achieved
if multiple systems are required at  a given  facility.
0.2.2  Exhaust Hood Volumetric  Flow  Monitoring  Systems
     The  exhaust  hood  volumetric monitoring  system  employed will depend
on plant  configuration.   EPA experience  with field-proven,  continuous
volumetric  flow monitoring systems  is  limited.   Two EPA Office of  Research
and  Development  sponsored reports indicate  that several  flow  monitoring
 systems  are available  which can meet accuracy requirements  of 10 percent.  '
 Because  of varying duct configurations,  in  situ calibration is needed.
 The Emission Measurement Branch (EMB),  Emission Standards and Engineering
 Division (ESED),  Office of Air Quality Planning and Standards (OAQPS),
 Environmental  Protection Agency, installed one monitor in a ferroalloy
 plant.3  This test program was  suspended after it became apparent  that
 the probe could not withstand the severe corrosive and temperature
 environment.   This problem appears to be a correctable physical limitation.
 Equipment and installation costs are estimated to range between $18,000
 and $25,000 per site.   Annual operating costs, which include recording
 and reducing of data, are estimated at $8,000 to $9,000 per  site.   Some
 savings in operating and equipment costs should be achieved  if multiple
 systems are required at a given facility.
                                     D-2

-------
D.3  PERFORMANCE TEST METHODS
     Consistent with the data base upon which the new source standard has
been developed, the recommended performance test method for particulate
matter is EPA Reference Method 5 (Appendix A 40 CFR Part 60, as amended
August 18, 1977).   In order to perform Reference Method 5, EPA Reference
Methods 1 through 4 must also be employed.
     Subpart A of 40 CFR Part 60 requires that affected facilities which
are subject to new source standards must be constructed such that sampling
ports adequate for the performance test are provided.   Platforms, access,
and utilities necessary to perform testing at those ports must be provided.
     Sampling cost for performing a test of three Reference Method 5 runs
is estimated to range from $9,000 to $12,000.
     The recommended performance test method for visible emissions is EPA
Reference Method 9 (Appendix A 40 CFR Part 60, as amended November 12, 1974).
                                   D-3

-------
D.4  REFERENCES FOR APPENDIX D
1.
2.
3.
Brooks, E. F., E. C. Beder, C. A. Flegal, D. J. Luciani, and
R. Williams.  Continuous Measurement of Total Gas Flowrate from
Stationary Sources.  U.S. Environmental Protection Agency.  Research
Triangle Park, N.C. Publication No. EPA-650/2-75-020.  February 1975.
248 p.
Brooks, E. F. and R. L. Williams.  Flow and Gas Sampling Manual.
Environmental Protection Agency.  Research Triangle  Park,  N.C.
Publication No. EPA-600/2-76-203.  July 1976.  93 p.
                                                                        U.S.
McKendree, J. R.   Instrument  Evaluation Test  on  Brandt  Industries
DP 2711 Flow Monitor.  U.S. Environmental  Protection  Agency.  Research
Triangle Park, N.C.  Contract No.  68-02-2818, Work Assignment No.  11.
Project No. 78-FEA-15.  April  1979.   72 p.
                                      D-4

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                                    TECHNICAL REPORT DATA
                             (flease read Instructions on the reverse, before completing)
   EPA-450/3~80-020a
4. TITLE AND SUBTITLE
  Electric Arc Furnaces  in Ferrous Foundries  -
  Background Information for Proposed Standards
                                                             3. RECIPIENT'S ACCESSION NO.
                                                             5. REPORT DATE
                                                               May 1980
                                                             6. PERFORMING ORGANIZATION CODE
   kUTHOR(S)
                                                             8. PERFORMING ORGANIZATION REPORT NO
 9. PLR
          NG ORGANIZATION NAME AND ADDRESS
  Office  of Air Quality  Planning and Standards
  Environmental Protection  Agency
  Research  Triangle Park, North Carolina  27711
                                                             10. PROGRAM ELEMENT NO.
                                                            11. CONTRACT/GRANT NO.

                                                                68-02-3059
 2. SPONSORING AGENCY NAME AND ADDRESS
  DAA for  Air Quality Planning  and Standards
  Office of  Air,  Noise, and  Radiation
  U.S. Environmental Protection Agency
  Research Triangle Park, North Carolina  27711
                                                            13. TYPE OF REPORT AND PERIOD COVERED
                                                            14. SPONSORING AGENCY CODE
                                                                EPA/200/04
      'LEMENTARY NOTES
  Standards of  Performance for  the control of emissions from electric  arc furnaces in
  ferrous foundries are being proposed under the authority of Section  111  of the Clean
  Air Act.  These standards would  only apply during  periods of melting and refining in
  the furnace.   This document contains background  information and environmental and
  economic impact assessments of the  regulatory alternatives considered in developing
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
 Air pollution
 Pollution control
 Standards of performance
 Ferrous  foundries
 Electric arc furnaces
 particulates
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                                                Air Pollution  Control
                                                                          c.  COSATI Field/Group
13 B
 unlimited
                                               19. SECURITY CLASS (This Report)
                                                 unclassified
                                                                         21. NO. OF PAGES
                                                                             290
                                               2O. SECURITY CLASS (Thispage)
                                                 unclassified
                                                                         22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EDITION is OBSOLETE

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