EPA-450/3-82-005a
Revised Standards for Basic
Oxygen Process Furnaces -
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
December 1982
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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
^°«!Stlt,f^^rld0rSement °r recommendati°n for use. Copies of this report are available through the Library Services
Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or, for a fee from
the National Technical Information Services, 5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/3-82-005a
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ENVIRONMENTAL PROTECTION AGENCY
Background Information and Draft Environmental
Impact Statement for Revised Standards of
Performance for Basic Oxygen Process Furnaces
Jack R. Farmer
Acting Director, Emission Standards and Engineering Division
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
/ (Date)
1.
The proposed standards of performance would limit secondary
emissions of particulate matter from new, modified, and
reconstructed basic oxygen process steelmaking facilities. The
proposed standards implement Section 111 of the Clean Air Act
(42 U.S.C. 7411) and are based on the Administrator's determina-
tion that the previously promulgated standards for BOPF's no
longer reflect application of the best demonstrated technology
(BDT) for these facilities.
Copies of this document have been sent to the following Federal
Departments: Labor, Health and Human Services, Defense,
Transportation, Agriculture, Commerce, Interior, and Energy; the
National Science Foundation; the Council on Environmental Quality;
members of the State and Territorial Air Pollution Program
Administrators; the Association of Local Air Pollution Control
Officials; EPA Regional Administrators; and other interested
parties.
The comment period for review of this document is 75 days.
Mr. Gene W. Smith may be contacted regarding the date of the
comment period.
For additional information contact:
Mr. Gene W. Smith
Standards Development Branch (MD-13)
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina
Telephone: (919) 541-5624
27711
5. Copies of this document may be obtained from:
U.S. EPA Library (MD-35)
Research Triangle Park, North Carolina 27711
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
iii
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TABLE OF CONTENTS
Section
Page
1. Summary 1-1
1.1 Regulatory Alternatives 1-1
1.2 Impacts of Regulatory Alternatives 1-2
2. Introduction 2-1
2.1 Background and Authority for Standards 2-1
2.2 Selection of Categories of Stationary Sources. . . . 2-5
2.3 Procedure for Development of Standards of
Performance . 2-7
2.4 Consideration of Costs ........ 2-9
2.5 Consideration of Environmental Impacts ........ 2-10
2.6 Impact on Existing Sources 2-11
2.7 Revision of Standards of Performance . . . . . . . . 2-12
3. Basic Oxygen Process Steelmaking Industry 3-1
3.1 General. 3-1
3.2 Process Facilities and Their Emissions 3-2
3.2.1 Basic Oxygen Process Furnaces and
Their Operation 3-2
3.2.1.1 Material Flow 3-11
3.2.1.2 Material Balance 3-16
3.2.1.3 Methods of Operation . . 3-18
3.2.2 Emissions 3-21
3.2.2.1 Fugitive Emission Sources 3-27
3.2.2.2 Nonprocess Sources of
Fugitive Emissions 3-30
3.2.3 Process Emissions Characterization 3-31
3.2.3.1 Emissions Generated During
the Oxygen Blow . 3-31
3.2.3.2 Emissions from Secondary Sources . . 3-32
3.3 References 3-36
4. Emission Control Techniques . . 4-1
4.1 Introduction 4-1
4.2 Capture of Secondary Emissions from Furnace
Operations (Charging, Sampling, Tapping) 4-2.
4.2.1 Furnace Enclosures 4-3
4.2.1.1 Kaiser Steel (Closed Hood, Top
Blown) 4-8
4.2.1.2 Republic Steel, Chicago (Closed
Hood, Bottom Blown) 4-12
4.2.2 Primary Control Systems Used for Secondary
Emission Control . 4-14
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r
CONTENTS (continued)
Section
4.2.2.1 Bethlehem Steel, Bethlehem,
Pennsylvania 4-17
4.2.2.2 Jones and Laugh!in Steel,
Aliquippa, Pennsylvania 4-21
4.2.3 Canopy or Roof Hoods, Partial Building
Evacuation 4-24
4.2.3.1 Inland Steel, East Chicago,
Indiana (Closed Hood, Top Blown) . . 4-28
4.2.4 Building Evacuation 4-30
4.2.5 Factors Affecting Fume Capture 4-32
4.2.6 Other Control Systems 4-33
4.2.6.1 Foreign Installations 4-36
4.3 Control of Secondary Emissions from Ancillary
Operations (Hot Metal Transfer and Skimming) .... 4-38
4.3.1 Kaiser Steel, Fontana, California 4-38
4.3.2 U.S. Steel, Fairfield, Alabama 4-40
4.4 Control of Primary Emissions 4-41
4.4.1 Closed Hood Scrubber Control Technology . . . 4-42
4.4.1.1 Control System Performance--
Closed Hood, Top Blown 4-45
4.4.1.2 Control System Performance--
Closed Hood, Bottom Bilown 4-46
4.4.2 Open Hood Scrubber and ESP Control
Technology 4-51
4.4.2.1 Performance Data—Open Hood
Control Systems 4-54
4.5 Particulate Matter Control Devices 4-54
4.5.1 The Fabric Filter 4-56
4.5.1.1 Performance Data—Mass Emissions . . 4-58
4.5.1.2 Performance Data—Visible
Emissions 4-58
4.5.2 Wet Scrubbers 4-58
4.5.3 The Electrostatic Precipitator 4-64
4.6 References ....... 4-66
5. Modification, Reconstruction, and Additions 5-1
5.1 Summary of 40 CFR 60 Provisions for Modifications
and Reconstructions 5-1
5.1.1 Modification 5-1
5.1.2 Reconstruction 5-2
5.2 Applicability of Modification Regulations to
BOPF Shop Facilities 5-3
5.2.1 General 5-3
5.2.2 Addition of Another BOPF. . . 5-4
5.2.3 Addition or Expansion of Hot Metal
Transfer or Skimming Facilities 5-4
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• CONTENTS (continued)
Section
Page
5.2.4 Converting a Top Blown-BOPF to a
.Bottom or Top and Bottom Blown BOPF .... 5-4
5.2.5 Converting an Open Hood BOPF to a Closed
Hood BOPF or Vice Versa 5-5
5.2.6 Increasing the Production Rate of a BOPF. . . 5-5
5.2.7 Changes in a BOPF to Permit Scrap Preheat . . 5-6
5.2.8 Addition or- Expansion of Other BOPF Shop
Facilities 5-6
5.3 Applicability of Reconstruction Regulations
to BOPF Shop Facilities 5-6
5.3.1 General 5-6
5.3.2 Basic Oxygen Process Furnace 5-6
5.3.3 Hot Metal Transfer Station 5-7
5.3.4 Hot Metal Skimming Station. . 5-8
5.4 References 5-8
6. Model Plants and Regulatory Alternatives 6-1
6.1 Model Plants 6-1
6.1.1 Model Plant Selection 6-1
6.1.2 Fugitive Emission Sources ... 6-14
6.2 Regulatory Alternatives 6-17
6.2.1 Regulatory Alternative Overview 6-17
6.2.2 Regulatory Alternative I 6-18
6.2.3 Regulatory Alternative II 6-18
6.2.4 Regulatory Alternative III ... 6-19
6.2.5 Regulatory Alternative IV ..... 6-20
6.2.6 Emission Limitations 6-22
6.3 References 6-22
7. Environmental Impact 7-1
7.1 General 7-1
7.2 Air Pollution Impact . 7-5
7.3 Ambient Air Impacts. . . 7-6
7.4 Water Pollution Impact . 7-13
7.5 Solid Waste Impact 7-16
7.6 Energy Impact 7-16
7.7 Other Environmental Impacts 7-18
7.8 Other Environmental Concerns . 7-^20
7.9 References 7-20
8. Costs . . . . 8-1
8.1 Cost Analysis of Regulatory Alternatives 8-1
8.1.1 Basis for Capital Cost Estimates 8-1
8.1.1.1 Direct Costs 8-1
8.1.1.2 Indirect Costs .... 8-11
8.1.1.3 Working Capital 8-12
vn
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CONTENTS (continued)
Section
8.1.2
Basis for Annual Cost Estimates, 8-12
8.1.3 Description of Facilities g-12
8.1.3.1 Plant Facilities .'.'!."! 8-12
8.1.3.2 Primary Pollution Control
Equipment. 8-13
8.1.3.3 Water Pollution Control Systems. ! . 8-13
8.1.3.4 Secondary Pollution Control
Systems 8-13
8.1.3.5 Hot Metal Transfer and Skimming
Pollution Control System . . . 8-14
8.2 New Facilities o_i4
8.2.1 Model Plant Costs .....'. '. [ .' ." .' .' .' ' 8-14
8.2.2 Comparison of Costs for Various Regulatory
Alternatives 8-22
8.2.3 Typical Regulatory Alternative Plant
Costs 8-22
8.3 Modified/Reconstruction Facilities . . . . . 8-29
8.4 Other Cost Considerations ^
8.5 References ....... 8-29
9. Economic Impacts g.^.
9.0 Summary of Impacts . . . . 9-1
9.1 Industry Profile ......... 9-3
9.1.1 Introduction '.'.'.'.'.'.'. 9-3
9.1.1.1 Definition of the Blast Furnaces
and Steel Mills Industry 9-4
9.1.1.2 The Steel Industry in the
Macroeconomy g_4
9.1.2 Basic Conditions .' 9-5
9.1.2.1 Supply Conditions . 9-5
9.1.2.2 Demand Conditions .' 9-17
9.1.3 Market Structure 9-21
9.1.3.1 Geographic Distribution of Plants . 9-21
9.1.3.2 Firm Concentration 9-21
9.1.3.3 Vertical Integration 9-22
9.1.3.4 Horizontal Integration '. 9-24
9.1.3.5 Economies of Production 9-24
9.1.3.6 Entry Conditions 9-26
9.1.4 Market Conduct ' ' 9-25
9.1.4.1 Homogeneity of Product 9-27
9.1.4.2 Degree of Concentration ...... 9-28
9.1.4.3 Barriers to Entry 9-23
9.1.4.4 Observed Pricing Practices 9-29
9.1.5 Market Performance g-32
9.1.5.1 Financial Profile of the Steel
Industry g-32
vm
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CONTENTS (continued)
Section
Page
9.1.5.2 Financial Profile of Firms Owning
BOF Facilities 9-34
9.1.5.3 Industry Trends 9-37
9.1.5.4 Steel Industry Projections ..... 9-47
9.1.6 Small Business Impacts 9-54
9.2 Economic Impacts of Regulatory Alternatives .... 9-54
9.2.1 Summary 9-55
9.2.2 Methodology 9-57
9.2.2.1 The Discounted Cash Flows
Approach 9-57
9.2.2.2 Net Present Value Impact
Methodology 9-61
9.2.2.3 Steel Price Impact Methodology . . . 9-62
9.2.3 Economic Impacts of Regulatory
Alternatives. 9-64
9.2.3.1 Net Present Value Impacts 9-67
9.2.3.2 Steel Cost Impacts 9-70
9.2.3.3 Output, Employment and Imports
Impacts 9-78
9.2.4 Anticipated Economic Impacts 9-83
9.2.4.1 Model Plant Selection . . 9-83
9.2.4.2 Estimates of Anticipated Impacts . . 9-84
9.2.5 Capital Availability 9-91
9.2.6 Total Cost of Compliance 9-94
9.2.7 Economic Impacts of Achieving Baseline . . . 9-97
9.3 References . 9-100
Appendix A Evolution of the Proposed Standards A-l
Appendix B Index to Environmental Impact Considerations. . . . B-l
Appendix C Summary of Test Data , . . . . C-l
Appendix D BOPF Shop Fugitive Emissions Measurement and
Continuous Monitoring , . . D-l
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LIST OF FIGURES
Number Page
3-1 Schematic flow chart for integrated and
nonintegrated steel making 3-3
3-2 Geographic distribution of the U.S. BOPF
steelmaking facilities 3-5
3-3 Top blown and bottom blow BOPF vessels 3-6
3-4 Steps for making steel by the basic oxygen process . . 3-8
3-5 Time sequence of top blown BOPF operations 3-9
3-6 Schematic elevation of a typical two-furnace shop . . 3-12
3-7 Schematic cross section of a furnace shop 3-13
3-8 Flow diagram for basic oxygen process
furnace operations 3-14
4-1 BOPF furnace enclosure . 4-4
4-2 Furnace enclosure for a Q-BOPF 4-5
4-3 Schematic of Kaiser Steel-Fontana basic oxygen
secondary emission control system 4-9
4-4 Republic Steel Corporation's South Chicago, Illinois,
Q-BOP emission control system 4-13
4-5 Bethlehem Steel, Bethlehem, Pennsylvania--BOPF
partial furnace enclosure for open primary hood . . . 4-18
4-6 Kawasaki-Chiba Works plant arrangement with
partial building evacuation 4-37
4-7 Kaiser Steel hot metal transfer and skimming
station 4-39
4-8 Typical scrubber configuration for closed hood BOPF. . 4-43
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LIST OF FIGURES
Number
4-9
4-10
6-1
9-1
9-2
Typical configuration for BOPF with open, hood ESP . .
Fabric filter outlet concentration
for BOPF and EAF sources
BOPF model plants
Price Impacts with downward- si op ing demand
Supply From Existing Plants ....
Page
.4-52
4-59
6-5
9-86
9-88
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LIST OF TABLES
Number Page
1-1 Impacts of Regulatory Alternatives on a Typical
New BOPF Shop as Compared to Alternative I 1-4
1-2 Industry Wide Impacts of Regulatory Alternatives
as Compared to Alternative I 1-5
1-3 Assessment of Environmental and Economic Impacts
for Each Regulatory Alternative Considered 1-6
3-1 BOPF Locations and Design Capacities 3-4
3-2 Nationwide Particulate Emission Estimates for 1979 . . 3-23
3-3 Particulate Emissions from Primary Metals
Industries for 1979 3-24
3-4 Particulate Emissions from the Iron and Steel
Industry for 1979 3-24
3-5 Nationwide Total Particulate Emission and Iron
and Steel Industry Particulate Emission Trends,
1970-1979 3-25
3-6 Comparison of Particulate Composition from Open
and Closed Hood Collection Systems 3-26
3-7 Uncontrolled Emission Factors for BOPF Secondary
Emissions 3-28
3-8 Particle Size Distribution for Q-BOP Charging
Emissions 3-33
3-9 Composition of Fugitive Emissions from BOPF's. ..... 3-34
3-10 Elemental Analysis of BOPF Charging Emission
Particulates 3-35
4-1 Kaiser Steel, Fontana, California, BOPF Roof
Monitor Opacity Observations, 3-Minute Averages . . . 4-11
4-2 Republic Steel, South Chicago, Illinois, Q-BOP
Roof Monitor Opacity Observations, 3-Minute
Averages . 4-15
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LIST OF TABLES (continued)
Number
Page
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
4-12
4-13
4-14
4-15
6-1
6-2
6-3
6-4
Republic Steel, South Chicago, Illinois, Q-BOP
Roof Monitor Opacity Observations, 3-Minute
Averages ;
Bethlehem Steel, Bethlehem, Pennsylvania, Roof Monitor
Opacity Observations, 3-Minute Averages
J&L Steel, Aliquippa, Pennsylvania, Roof Monitor
Opacity Observations, 3-Minute Averages. .
J&L Steel, Aliquippa, Pennsylvania, Roof Monitor
Opacity Observations, 3-Minute Averages. .......
Scrap Types and Contaminants
Principal Primary Emission Data — Closed Hood . . . . .
Principal Primary Emission Data—Closed Hood
Supplementary Primary Emission Data — Cosed Hood . . .
Supplementary Primary Emission Data — Closed Hood . . .
Open Hood System Performance Data
Wheeling-Pittsburgh Steel, Mingo Junction,
Ohio, HMT Baghouse Visible Emission Data .......
United States Steel, Fairfield, Alabama, Canopy
Hood and South Mixer Baghouse
United States Steel, Fairfield, Alabama,
North Mixer Baghouse . .
BOPF Model Plants ,
Design Parameters of the Model Plants Pollution
Control Systems Gas Cleaning Devices
Model Plant Primary Pollution Control System
Gas Flow Rates
Model Plant Secondary Pollution Control System
Gas Flow Rates
4-16
4-20
4-25
4-26
4-34
4-47
4-48
4-49
4-50
4-55
4-60
4-61
4-63
6-2
6-10
6-11
6-12
xm
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LIST OF TABLES (continued)
Number
6-5 Particulate Matter Emission Table for BOPF
• Model Plants 5-15
6-6 Preliminary Emission Limitations for Comparing
Regulatory Alternatives 6-21
7-1 Typical Regulatory Alternative Plants 7-3
7-2 U.S. BOPF Steel making Capacity 7-4
7-3 Emissions from Typical Regulatory Alternative
Plants 7-7
7-4 Future Nationwide Emissions from Typical
Regulatory Alternative Plants 7-8
7-5 Estimated Maximum Annual Arithmetic Average Ground-
Level Particulate Concentrations at Selected
Distances 7-11
7-6 Estimated Maximum 24-Hour Arithmetic Average Ground-
Level Particulate Concentrations at Selected
Distances 7-12
7-7 Additional Power Plant and Total Particulate
Emissions Attributable to Typical Regulatory
Alternative Plants 7-14
7-8 Uncontrolled Inorganic Emissions from Hot Metal
Addition to a Q-BOP 7-15
7-9 Future Solid Waste Generation from Typical Regulatory
Alternative Plants 7-17
7-10 Control System Energy Requirements for Typical
Regulatory Alternative Plants 7-19
8-1 Capital Costs of Control—BOPF Emissions—July 1980. . 8-2
8-2 Annual Costs of Control—BOPF Emissions—July 1980 . . 8-5
8-3 Capital Costs of Control by Building Evacuation—
BOPF Secondary Emissions—July 1980 8-8
8-4 Annual Costs of Control by Building Evacuation—BOPF
Secondary Emissions—July 1980 8-9
XIV
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LIST OF TABLES (continued)
Number
Paqe
8-5
8-6
8-7
8-8
8-9
8-10
8-11
8-12
8-13
8-14
9-1
9-2
9-3
9-4
9-5
9-6
9-7
BOPF Shop Annual Operating Costs — July 1980. .....
Design Criteria for Model Plant Primary Emission
Control Systems
Design Criteria for Model Plant Secondary
Emission Control Systems
Cost Relationships for BOPF Primary and Secondary
Emission Control
Emissions Collected from Affected Facilities
in Model Plants
Unit Cost of Primary and Secondary Emission
Control
Emissions and Control Costs for Typical Regulatory
Alternative Plants .....
Comparative Unit Costs of Various Regulatory
Alternatives
Future Nationwide Capital and Annual Costs of Control
for Typical Regulatory Alternative Plants
Cost Estimate for OSHA Compliance— BOPF
Secondary Emissions— July 1980
Important Inputs to the Blast Furnaces and Steel
Mills Industry— SIC 3312— in 1972
Raw Steel Production by Process Type, 1968 to 1979 . .
Pig Iron and Scrap Inputs to Raw Steel Production . .
U.S. Real Gross National Product and Apparent Consump-
tion of Steel Mill Products
Important Purchasers of Output From the Blast Furnaces
and Steel Mills Industry— SIC 3312— in 1972
Plant Integration
After-Tax Profit to Stockholders' Equity
8-10
8-15
8-16
8-17
8-19
8-20
8-23
8-23
8-24
8-25
9-9
9-14
9-16
9-18
9-19,
9-23
9-33
XV
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LIST OF TABLES (continued)
Number
9-8
9-9
9-10
9-11
9-12
9-13
9-14
9-15
9-16
9-17
9-18
9-19
9-20
9-21
9-22
9-23
9-24
9-25
9-26
Page
Financial Information on Firms Owning Basic Oxvaen
Furnaces, 1979 . ............... a g_35
Financial Ratios for Firms Owning Basic Oxvaen
Furnaces, 1979 . . ............. g_36
Financial Ratios for Selected Industries, 1979 .... 9-33
Steel Mill Products and Total Industrial
Output Indexes ................. 9_39
Real Value of Output for SIC 3312 .......... 9-4!
Steel Price Index and GNP Price Deflator ....... 9-42
Indexes of Real New Investment ............ 9-43
Index of Output per Employee-Hour .......... 9-45
Steel Mill Products Trade .............. 9_46
Projected Steel Shipments, 1980-1990 ......... 9-43
Basic Oxygen Furnace Capacity Additions, 1981-1990 .
Basic Oxygen Furnace Capacity Additions by Model
Case, 1981- 1986 .............
9-50
Model Project Cost Data .............. 9_65
Model Parameter Values ............... 9.66
Project Net Present Values Assuming 6.2 Percent
Interest Rate ....
9-68
Net Present Value Reductions From Baseline Assuming
6.2 Percent Interest Rate 9_69
Project Net Present Values Assuming 10.0 Percent
Interest Rate
9-71
Net Present Value Reductions From Baseline Assuming
10.0 Percent Interest Rate 9_72
Average Total Cost of Raw Steel Assuming 6.2 Percent
Interest Rate
9-73
xvi
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LIST OF TABLES (continued)
Number
9-27
9-28
9-29
9-30
9-31
9-32
9-33
9-34
9-35
9-36
9-37
9-38
9-39
9-40
Page
Average Total Cost Impacts From Baseline Assuming
6.2 Percent Interest Rate . 9-75
Average Total Cost of Raw Steel Assuming 10.0 Percent
Interest Rate 9-76
Average Total Cost Impacts From Baseline Assuming
10.0 Percent Interest Rate 9-77
Domestic Steel Shipment Impacts From Baseline
for 1986 9-79
Domestic Steel Industry Employment Impacts From
Baseline for 1986 9-81
Steel Import Impacts From Baseline for 1986
9-82
Net Present Value and Average Total Cost Data for
Models A and J 9-85-
Summary of Economic Impacts From Baseline of Regulatory
Alternative II 9-90
Summary of Economic Impacts From Baseline of Regulatory
Alternative III 9-92
Capital Requirements of Regulatory Alternatives . . . 9-93J
Industry Debt Ratios 9-95
Total Cost of Compliance, 1986 9-96
Cost Data for Model Project A 9-98
Estimated Impacts of Moving from Primary Control
to No Control. 9-99
xvn
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UNITS OF MEASUREMENTS
acms
acfm
°C
dscm
dscms
9
mg
kg
Mg
Tg
J
kJ
m
cm
mm
m3
m3/s
Pa
kPa
scfs
scfm
scmm
sons
actual cubic meters per second
actual cubic feet per minute
degrees Celsius
dry standard cubic meter
dry standard cubic meters per second
gram
milligram (0.001)
kilogram (1,000)
megagram (1,000,000)
teragram (1,000,000,000,000)
joule
kilojoule (1,000)
meter
centimeter (0.01)
millimeter (0.001)
cubic meter
cubic meters per second
pascal
kilopascal
standard cubic feet per second
standard cubic feet per minute
standard cubic meters per minute
standard cubic meters per second
xvi i i
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1. SUMMARY
1.1 REGULATORY ALTERNATIVES
The Clean Air Act Amendments of 1977 require that the Administrator
review and, if appropriate, revise established standards of performance
for new stationary sources at least every 4 years. Review of the
standards of performance for particulate emissions from basic oxygen
process furnaces (BOPF's) at iron and steel plants (40 CFR 60.140,
Subpart N) was completed in 1979 and a notice of review was published
on March 21, 1979 (44 FR 17460). Review of the primary standard
resulted in recommendations for revisions to the standard in three
areas: (1) the inclusion of controls for secondary emissions; (2) the
clarification of the definition of a BOPF; and (3) the clarification
of the sampling period used to determine compliance. Based on the
first recommendation, a new Subpart Na has been proposed for the
control of secondary emissions from BOPF's, hot metal transfer stations,
and skimming stations in BOPF shops at iron and steel plants. Further
information regarding the review of the primary standard may be found
in the EPA document, "A Review of Standards of Performance of New
Stationary Sources—Iron and Steel Plants/Basic Oxygen Process Furnaces"
(EPA-450/3-78-116).
Four regulatory alternatives were considered as the basis for the
proposed standards. Regulatory Alternative I corresponds to no addi-
tional Federal standards for emissions from BOPF steelmaking facilities.
The level of emission control of this alternative is represented by
the current new source performance standard (NSPS) that limits the
mass and opacity of primary particulate emissions from an affected
BOPF. These emission limits can be met with either an open or closed
hood capture system in combination with an electrostatic precipitator
(ESP) or scrubber for particulate collection. However/due to the
1-1
-------
advantages of closed hood control when only primary emission control
is required, new BOPF shops would probably incorporate closed hood
systems under this alternative.
Under Regulatory Alternative II, additional NSPS would be proposed
to limit secondary emissions from the BOPF, hot metal transfer station,
and skimming station. Standards for secondary emissions associated
with this alternative would be achievable using auxiliary hooding
ducted to a baghouse for the control of emissions from hot metal
transfer and skimming and either of two methods for the control of top
blown furnace emissions. If open hooding were used for the control of
primary emissions from top blown furnaces, the primary control system
could also be used to capture and collect secondary emissions. If
closed hooding were the primary emission control method, a furnace
enclosure with hooding evacuated to a baghouse could be used to meet
the standards.
Because primary emissions are controlled to a greater degree with
a closed hood system, total emissions (primary and secondary) to the
atmosphere from a new BOPF shop would be less if closed hooding were
used. Under Regulatory Alternative III, the existing NSPS for primary
emissions would be revised to a limit that could only be achieved with
the use of a closed hood system. Standards for secondary emissions
would be based on the use of a furnace enclosure with hooding evacuated
to a baghouse for the control of emissions from top or bottom blown
furnaces plus auxiliary hooding ducted to a baghouse for the control
of emissions from hot metal transfer and skimming.
Under Regulatory Alternative IV, standards would be set for
secondary emissions from the affected facilities based on the use of a
total building evacuation system. The limits of the primary NSPS
would not be changed, therefore allowing the use of either closed or
open hooding for primary emission control.
1.2 IMPACTS OF REGULATORY ALTERNATIVES
It is assumed that closed hooding would be used as the primary
emission control method to meet the existing NSPS under Regulatory
Alternative I. Particulate emissions to the atmosphere from a typical
1-2
-------
plant (i.e., a new BOPF shop with two 270-Mg (300-ton) tqp blown
furnaces) with closed hood primary control on the furnaces and uncon-
trolled secondary emissions would be approximately 1,374 Mg/yr (1,515
tons/yr). The solid waste generated by the collection of primary
particulate emissions would be approximately 41,325 Mg/yr (45,552
tons/yr). The electrical energy required for emission control under
Regulatory Alternative I would be about 16 million kWh/yr for a typical
plant. The total plant capital cost and the pollution control annual-
ized cost for a typical new shop are estimated at $187.5 million (1980
dollars) and $5.4 million/yr, respectively. The estimated impacts of
the other alternatives on a typical plant as measured against the
baseline impacts of Regulatory Alternative I are shown in Table 1-1.
The longer term effects of the regulatory alternatives were
evaluated by estimating the sum effect of each alternative on all BOPF
steelmaking facilities for which construction was commenced during the
period from 1981 to 1986. The computation of these" industry wide
impacts was based on an estimated increase in BOPF steelmaking capacity
of 6.8 million Mg/yr (7.5 million tons/yr) by 1986. This projected
new capacity is equivalent to the construction of approximately three
new BOPF shops. Industry wide particulate emissions (controlled
primary emissions plus uncontrolled secondary emissions) would be
approximately 3,221 Mg/yr (3,551 tons/yr) for facilities commencing
construction from 1981 to 1986. The solid waste to be handled due to
the collection of emissions would be 96,855 Mg/yr (106,763 tons/yr).
Industry wide electrical energy requirements under Regulatory Alterna-
tive I would be about 37.5 milTion kWh/yr. Industry wide capital and
annualized costs for emission control would be about $42 million and
$12.6 million/yr, respectively. The estimated industry wide impacts
of the other alternatives, as measured against the baseline impacts of
Regulatory Alternative I, are shown in Table 1-2.
A matrix summarizing the environmental and economic impacts is
presented in Table 1-3.
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 technologies and degrees of efficiency, are expressed
as regulatory alternatives. Each of these alternatives is studied by
the U.S. Environmental Protection Agency (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 impacts on the environment. This document
summarizes the information obtained through these studies so interested
persons will be able to see the information considered by EPA in the
development of the proposed standards.
Standards of performance for new stationary sources are established
under Section 111 of the Clean Air Act (42 USC 7411) as amended,
herein 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 that •". . . 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 nonair quality health and environmental impact and
energy requirements) the Administrator determines has been adequately
demonstrated for that category of sources." The standards apply only
2-1
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to stationary sources, 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.
• 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, and
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
not on the list or may apply to the Administrator to have a standard
of performance revised.
• EPA is required to review the standards of performance every 4
years and, if appropriate, to revise them.
• 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.
• 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 nonpolluting process or.operation.
• The time between the proposal and promulgation of a standard
under Section 111 of the Act may be 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, considering the cost of achieving such emission reduction,
any nonair quality health and environmental impacts, and energy
requirements.
2-2
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Congress had several reasons for including these requirements.
First, standards with a degree of uniformity are needed to prevent
situations where some States may attract industries by relaxing stand-
ards 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 eliminating the need for more
expensive retrofitting when pollution ceilings may be reduced in the
future. Fourth, certain types of standards for coalburning 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 for New Source Performance Standards to 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
2-3
were—promti-i-gatea-or
=OUU-l-l-CO—I-UI WH-l-krH—HeW—»UU-!-bre-
under development during 1977, or earlier, were selected on these
criteria.
2-5
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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 treatment or innovative fuel combustion techniques
for control of each such pollutant. In no event shall
application of "best available control technology" result in
The Act amendments of August 1977 establish specific criteria to
be used in determining priorities for all major source categories not
yet listed by EPA. These are:
The quantity of air pollutant emissions that each such
category will emit, or will be designed to emit;
The extent to which each such pollutant may reasonably
be anticipated to endanger public health or welfare:
and
The mobility and competitive nature of each such category
of sources and the consequent need for nationally
applicable new source standards of performance.
The Administrator is to promulgate standards for these categories
according to the schedule referred to earlier.
In some cases it may not be feasible to develop a standard for a
source category with a high priority immediately. This problem might
arise when a program of research is needed to develop control techniques
or because techniques for sampling and measuring emissions may require
refinement. In the development 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
2-6
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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:
Realistically reflect best demonstrated control practice;
Adequately consider the cost, the nonair-quality health
and environmental impacts, and the energy requirements
of such control;
Be applicable to existing sources that are modified or
reconstructed as well as new installations; and
Meet these conditions for all variations of operating
conditions considered anywhere in the country.
The objective of a program for developing standards is to identify
the best technological system of continuous emission reduction that
has been adequately demonstrated. The standard-setting process involves
three principal phases of activity: information gathering, analysis
of the information, and 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
2-7
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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.
As early as is practical in each standard-setting project, EPA
representatives discuss with members of the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC) the possibilities of a
standard and the form it might take. 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 considered 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
standards are officially endorsed by the EPA Administrator. After
they are approved by the Administrator, the preamble and the proposed
regulation are published in the Federal Register.
As a part of the Federal Register announcement of the proposed
standards, the public is invited to participate in the standard-setting
process. EPA invites written comments on the proposal and also holds
2-8
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a public hearing to discuss the proposed standards 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, DC.
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.
2.4 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:
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 develop-
ment of less expensive or more efficient methods of
compliance;
Potential inflationary or recessionary effects of the
regulation;
Effects the regulation might have on small business
with respect to competition;
Effects of the regulation on consumer costs; and
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 in terms of the control
costs that would be incurred as a result of compliance with typical,
existing State control regulations. An incremental approach is
2-9
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necessary 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 from 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 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 additional capital require-
ments necessitated by these Federal standards can be placed in proper
perspective. Finally, it is necessary to assess the availability 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 counter-productive environmental effects of a
2-10
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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) specifi-
cally 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 USC 793c[lJ)
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 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 in this document 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 111 (d) of the Act if the standard for new
2-11
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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 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 ensure 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 proposal of the
revised standards.
2-12
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3. BASIC OXYGEN PROCESS STEELMAKING INDUSTRY
3.1 GENERAL
The procedure for making steel by blowing air through molten iron
was developed about a century ago and was practiced until the 1960's
in the form of the Bessemer process. The advantage of this process
was that it was relatively fast and yielded a high material-to-labor
ratio. The open hearth process could not be replaced by the blowing
process, however, because the steel produced by blowing air through
iron contains nitrogen, which makes it more brittle and less ductile
than open hearth process steel.
As tonnage quantities of pure oxygen (95 to 99 percent) at low
prices became available, the pure oxygen blown steel making process
became feasible and grew quickly from 1960 on, with a proportionate
decline in the open hearth process. The new process is effected in
furnaces called Basic Oxygen Process Furnaces (BOPF's). The BOPF
technology is now well established for making high quality steel using
a minimum amount of labor.
In 1978, the domestic steel industry was composed of 93 companies
operating 158 individual plants.1 The plants may be divided into
three groups based on the type of primary operations, products, and
marketing approach of the individual companies. These groups are:
integrated companies that have primary raw material and ironmaking
facilities (blast furnaces), steelmaking units, and finishing mills;
alloy and specialty steel companies that produce alloys and special
steels but do not engage in ironmaking activities; and nonintegrated
companies that operate melting and casting units and fabrication mills
for the production of a limited number of products for a regional
3-1
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market.1 BOPF shops are typically part of integrated steel mills. A
schematic flow chart for integrated and nonintegrated steel mills is
presented in Figure 3-1.
A list of the integrated steel mills that have BOPF facilities is
presented in Table 3-1. The distribution of these plants within the
United States is shown in Figure 3-2.2
3.2 PROCESS FACILITIES AND THEIR EMISSIONS
3.2.1 Basic Oxygen Process Furnaces and Their Operation
A basic oxygen process furnace is a large, open-mouthed vessel
lined with a basic refractory material (the term "basic" refers to the
chemical characteristic of the lining). The furnace is mounted on
trunnions that allow it to be rotated through 360° in either direction.
A typical vessel can have an opening 3.7 to 4.3 m (12 to 14 ft) in
diameter and be 6.1 to 9.1 m (20 to 30 ft) high.
The furnace receives a charge composed of scrap and molten iron
which it converts to molten steel. This is accomplished through the
introduction of high-purity oxygen that oxidizes the carbon and the
silicon in the molten iron, removes these products, and provides heat
for melting the scrap. After the oxygen blow is started, lime may be
added to the vessel to provide a slag of the desired basicity. Fluorspar
may also be added in order to achieve the desired slag fluidity.
Two distinct types of furnaces are in general use (see Figure 3-3).
The most common type is the "top blown" furnace, in which oxygen is
blown into the vessel through a water-cooled lance that can be lowered
into the mouth of the upright furnace. The other type of furnace,
commonly called a Q-BOP, is "bottom blown." In this furnace, oxygen
is introduced into the vessel through tuyeres (nozzles) in the furnace
bottom.
The major reason for installing a Q-BOP furnace is that it does
not require a great deal of vertical clearance above the furnace
enclosure and can therefore fit into existing open hearth buildings.
Existing ancillary facilities can be adapted easily for serving Q-BOP's.
Other advantages of bottom blown furnaces are slightly increased
yields and higher ratios of scrap to hot metal.
3-2
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Raw materials
preparation
(iron ore,
limestone)
Ironmaking
Coking
Blast
furnace
Direct reduction
- Pig»4
iron M.
Scrap
DRI
Steel making
furnace
Basic oxygen
Open hearth
Electric arc
Final hot rolling,
cold rolling,
finishing,
annealing, etc.
Ingot
casting
Ingot
breakdown,
primary
rolling
Finishing
Continuous
casting
Possible major routes:
Integrated:
Nonintegrated:
Semi-integrated:
coking-blast furnace-basic oxygen-ingot
casting-finishing.
scrap-electric furnace-continuousjcasting-finishing.
direct reduction + scrap-electric furnace-continuous
casting-finishing.
Figure 3-1. Schematic flow chart for integrated and nonintegrated steelmaking.1
3-3
-------
TABLE 3-1. BOPF LOCATIONS AND DESIGN CAPACITIES2 a
EPA
Region
2
3
4
5
8
9
Company
Bethlehem Steel Co.
Republic Steel Co.
Allegheny Ludlura
Steel Co.
Bethlehem Steel
Corp.
Bethlehem Steel
Corp.
Jones & LaughHn
Steel Corp.
National Steel
Corp.
Sharon Steel Corp.
U.S. Steel Corp.
U.S. Stael Corp.
Wheeling-Pitts-
burgh Steel Corp.
Amico Steel Corp.
Republic Steel
Corp.
U.S. Steel Corp.
Armco Steel Corp.
Bethlene* Steel Co.
Bethlahem Steel Co.
Ford Motor Co.
Inland Steel Co.
Inland Steel Co.
Interlake, Inc.
Jones & Uughlin
Steal Corp.
McLouth Steel Corp.
National Steel
Corp.
National Steel
Corp.
National Steel
Corp.
Republic Steel
Corp.
Republic Steel
Corp.
Republic Steel
Corp.
U.S. Steel Corp.
U.S. Steel Corp.
U.S. Steel Corp.
U.S. Steel Corp.
Wheeling-Pitts-
burgh Steel Corp.
Jones & Laugh 1 in
Steel Corp.
CF&I Steel Corp.
Kaiser Steel Corp.
Location
Lackawanna, N.Y.
Buffalo, N.Y.
Natrona, Pa.
Sparrows Pt. , Md.
Bethlehem, Pa.
AHquippa, Pa.
Weirton, W. Va.
Parrel 1 , Pa.
Duquesne, Pa.
Braddock, Pa.
Monessen, Pa.
Ashland, Ky.
Gadsden, Ala.
Fairfield, Ala.
Hiddletown, Oh.
Burns Harbor, Ind.
Burns Harbor, Ind.
Dearborn, Mich.
East Chicago, Ind.
East Chicago, Ind.
Chicago, 111.
Cleveland, Oh.
Trenton, Mich.
Ecorse, Mich.
Ecorse, Mich.
Granite City, 111.
Warren, Oh.
Cleveland, Oh.
So. Chicago, 111.
Gary, Ind.
Gary, Ind.
So. Chicago, 111.
Lorain, Oh.
Steubenville, Oh.
East Chicago, In.
Pueblo, Colo.
Fontana, Calif.
Year
installed
1964/66
1970
1966
1966
1968
1968
1967
1974
1963
1972
1964
1963
1965
1974/78
1969
1969
1978
1964
1966
1974
1959
1961
1958/59
1962
1970
1967
1965
1966/77
1976
1965
1973
1969
1971
1965
1970
1961
1978
BOPF
Number
3
2
2
2
2
3
2
3b
2
2
2
2
2
3C
2
2
1
2
2
2
2
2
5
2
2
2
2
2
2C
IF
3
2
2
2
2
2
furnaces
Size-Mg (tons)
282(310)
120(130)
75(80)
200(220)
240(270)
188(207)
277(360)
135(150)
200(220)
200(220)
180(200)
165(180)
136(150)
180(200)
182(200)
270(300)
270(300)
218(240)
230(255)
190(210)
71(78)
200(220)
109(120)
270(300)
209(230)
215(235)
136(150)
200(220)
204(225)
195(215)
180(200)
180(200)
205(225)
250(275)
264(290)
107(118)
208(229)
Capacity
million
Mg/yr,
(million
tons/yr)
4.5(5.0)
0.9(1.0)
0.4(0.5)
2.7(3.0)
3.1(3.5)
5.2(5.8)
1.4(1.6)
2.2(2.5)
2.2(2.5)
1.4(1.6)
1.8(2.0)
1.3(1.5)
3.2(3.5)
2.0(2.3)
4.0(4.5)
0.9(1.0)
3.4(3.8)
{6.0(6.7)}
0.9(1.1)
2.7(3.0)
2.5(2.8)
5.2(5.8)
2.2(2.5)
1.9(2.2)
3.3(3.7)
2.0(2.3)
{7. 2(8.0)
2.7(3.0)
2.7(3.0)
2.6(2.9)
2.7(3.0)"
1.2(1.4)
2.1(2.4)
This facility consists of one standard top-blown BOPF and two Kaldo Process BOPF's, the latter vessels being
Inclined and rotating during the oxygen blow. The Kaldo units have been virtually supplanted by the
standard fixed unit.
CQ-BOP installation.
3-4
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3-6
-------
A third type of furnace is currently being used on an experimental
basis at the Rational Steel plant in Granite City, Illinois. This
typical top blown furnace has been modified to allow 90 percent of the
oxygen to be introduced through the conventional oxygen lance and the
other 10 percent to be injected through bottom and side tuyeres within
the vessel.3 This particular installation is called the Klb'chner
Maxhiitte Scrap (KMS) conversion system.4 5 Presently, there is not
much information available about the success of the KMS system or
about the liklehood of its being adopted in other BOPF shops.
Steel is produced via the basic oxygen process in distinct opera-
tions that occur in the following order:
1. Charging—The addition of scrap metal or hot metal to the
BOPF.
2. Oxygen blow—The refining stage of the process, in which
pure oxygen is blown into the BOPF.
3. Turndown—After the blow, the vessel is tilted toward the.
charging aisle to facilitate taking hot metal samples and
making temperature measurements.
4. Reblow—If the samples taken during the turndown indicate
the need, oxygen can again be blown into the vessel, usually
for only a very brief period.
5. Tapping—Pouring the molten steel out of the BOPF into the
teeming ladle.
6. Deslagging--Pouring residual slag out of the BOPF into a
slag pot.
7. Teeming—The pouring of molten steel into ingot molds.
These operations are illustrated in Figures 3-4 and 3-5.
Generally, a BOPF shop is arranged in three parallel aisles. The
charging aisle has one or more cranes for conveying charge material
(molten iron and scrap) to the furnace, as well as for carrying ladles
of molten slag away from the furnace. The furnace aisle contains the
furnaces, collection hoods for fumes, lances for injecting the oxygen
into the bath, and the overhead bins for storing and metering out the
various flux materials and alloy additions. The pouring, teeming, or
tapping aisle handles the finished heats of steel. It has one or more
3-7
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3-9
-------
overhead cranes and facilities for pouring the molten steel either
into ingot molds or into continuous casting machines.
Adjacent to the charging aisle is a scrap yard with overhead
cranes where scrap is transferred from railroad cars into the charging
boxes. The charging boxes are moved by special railed cars from the
scrap yard into the charging aisle. Other railed cars under the
furnace hold the steel and slag ladles (teeming ladle and slag pots).
These cars transfer the slag ladles from under the furnace to the
charging aisle and move the steel ladles into the teeming aisle.
The emissions generated during the oxygen blow are captured by a
large, water-cooled hood located directly above the furnace. This
hood is called the primary hood since it captures the primary (blowing)
emissions.
During the oxygen blow of a top blown furnace, the oxygen lance
is lowered through an opening (the lance hole) in the top of the
primary hood. It is stopped a short distance above the molten iron
and the flow of oxygen (blow) is initiated. The vessel is upright
during the blow, allowing the fumes to pass directly from the mouth of
the furnace into the mouth of the primary hood. At other times during
the process, the vessel may be tilted so that the mouth of the vessel
does not align with the opening in the hood, and capture of the fumes
by the primary hood is less likely (Figure 3-4). The vessel is tilted
toward the charging aisle for at least four of the operations; namely,
charging the scrap, charging with molten iron, sampling the heat for
analysis, and dumping the slag. With very few exceptions, the furnace
is tilted toward the tapping aisle only when pouring the finished heat
of steel from the furnace into the teeming ladle. Alloy additions may
be made to the furnace while it is upright under the hood. However,
additions are more commonly made to the teeming ladle while it is
being filled with steel from the furnace.
There are several ancillary operations associated with the basic
oxygen process of making steel. The first is the scrap handling
operation described above. The next is hot metal transfer, or the
transfer of molten iron from the torpedo car to the charging ladle and
from the charging ladle to the furnace itself. (In several BOPF
3-10
-------
shops, hot metal is poured from the torpedo car into a mixer from
which it is eventually poured into the charging ladle. The mixer is a
refractory-lined vessel with sufficient capacity to hold the contents
of several torpedo cars.) The handling of molten iron may include the
operation of mechanically skimming slag from the top of the hot metal.
A third operation is the teeming of the finished steel into ingot
molds or into"continuous casting machines. Finally, there is the
handling and disposing of molten slag, generally accomplished by
carrying the slag pot to some location where the slag can be safely
poured on the ground and allowed to cool. The solidified slag is then
loaded into trucks or railroad cars for transport to a disposal site.
Figure 3-6 is a schematic elevation of a typical two-furnace shop
and indicates all of the facilities described above. Figure 3-7 shows
a schematic cross section that illustrates the various operating
units.6
3.2.1.1 Material Flow. A flow sheet for steelmaking in the BOPF
is shown in Figure 3-8. The principal components of the charge are
scrap and molten iron. Scrap usually arrives at the shop in railroad
gondola cars and is transferred to the charging box (scrap bucket) by
a magnet on an overhead crane. Molten iron is brought to the shop by
railroad torpedo cars and is transferred to the charging ladle at the
hot metal transfer station. This station is usually equipped with a
hood for capturing the emissions that evolve during the transfer
operation. When the furnace vessel is ready for charging, it is
tilted toward the charging aisle and the charging box is lifted and.
emptied into the vessel. Next, the ladle of molten iron is poured
into the vessel over the scrap. The vessel is turned upright, the
oxygen lance is lowered (for top blown furnaces), and the blow com-
mences. During the blow, the desired quantities of lime and fluorspar
may be fed through the chute into the vessel from the weigh hopper.
In Q-BOP's, these materials are injected through the tuyeres.
Two forms of primary (blowing) emission collection equipment are
in common use. One form is an open hood directed to an electrostatic
precipitator (ESP) and is similar to that shown in Figures 3-6 and
3-7. The emissions that evolve during the oxygen blow are captured by
3-11
-------
a
o
8
I
to
3-12
-------
CONVEYOR FROM
-RAW-MATERIAL
STORAGE
-STORAGE BINS
WEIGHING
BINS
CONVEYORS
BATCHING
HOPPER
LADLE
ADDITIVE
TRANSFER
CAR
DOTTED LINES SHOW POSITIONS
OF TILTED FURNACE AND SCRAP
HOOD BOX WHEN CHARGING SCRAP
SCRAP
CHARGING
CAR
SLAG POT ON
TRANSFER CAR
TEEMING
LADLE ON
TRANSFER
CAR
HOT-METAL
TRANSFER
LADLE ON
TRANSFER CAR
IN PIT
Figure 3-7. Schematic cross section of a furnace shop.
3-13
-------
Molten iron from
blast furnace
t
Desulfurization (optional)
Hotmetal transfer
i iui iiieiai
Skim
"crao 23-9tons
Fluxes and coolants b
Basic oxygen
process furnace operations
Alloying additions —
T^mina * 100 tons
steel
-4-
Cha
— ' — I
02
(21,
I
Turr
I
lO2 r
(not<
need
| — Tat
1
Deslc
(emissions
95.5 tons hot metal
ming Skimming ^a
emissions
Hot metal
ruing charging
1
3 lOW
000 scfm)
[
always
ed)
ping
ggi.ng
i
Emissions'00105"
Primary. ^9SRO th.
emissions
Turndown a
emissions
Reblow ^^ a
emissions
Tapping ^ ^lhe
emissions
Deslagging a
emissions
Slag disposal
a quantities unknown
"quantities vary from one heat to the next
Figure 3-8. Flow diagram for basic oxygen process furnace operations.
3-14
-------
the hood, enter a hood cooling section where some heat is extracted,
and pass through a conditioning chamber where the gas is cooled arid
humidified to the required levels for proper electrostatic precipitator
operation. The gas cleaning system commonly consists of precipi-
tators, fans, dust handling equipment, and a stack for carrying away
the cleaned gases. Electrostatic precipitators can be used with open
hoods because the combustible CO generated during the oxygen blow
burns at the mouth of the vessel, reducing the risk of explosions
which could be set off by sparks in the precipitator. Alternatives to
ESP's are scrubbers or, as has been tried at one plant, baghouses.
Additional information regarding control techniques for basic oxygen
process steelmaking operations is presented in Chapter 4.
The other primary emission system is the closed hood, in which
the diameter of the hood face is roughly the same as the diameter of
the mouth of the vessel. The lower portion of the hood is a skirt
that can be lowered onto the mouth of the vessel. This seals off the
space between the hood and the vessel, thus limiting the amount of air
that can enter the system. The gas (mainly CO) is collected in an
uncombusted state. The volume of gas collected in a closed hood
system is reduced by as much as 80 to 85 percent as compared to that
of an open hood system. Gas cleaning is performed by a scrubber to
minimize the risk of explosion. The cleaned gas is usually flared at
the stack.6
Because there is less danger of explosion in the open hood system
(most of the carbon monoxide has been converted to carbon dioxide),
all of the vessels in the shop may be connected to a common gas cleaning
system. Conversely, the closed hood system must have a separate
scrubber system for each vessel because of the potential explosion
hazard from leakage of air into the system from an idle furnace.
Generally, the flux bins are filled by a belt conveyor system
from a hopper at ground level. This hopper is usually equipped to be
loaded from a railroad car, a truck, or both. Transfer points of the
conveyor system are generally fitted with hooding and small, individual
baghouses.
3-15
-------
When the heat is complete, the vessel is tilted and the steel is
poured into the teeming ladle. The transfer car moves the ladle into
the pouring aisle and a crane picks up the ladle and carries it over
to the train of ingot molds parked at the teeming station. A stopper
or slide gate in the bottom of the ladle is opened and each ingot is
filled in turn. Alternatively, the ladle may be carried to the top of
a continuous casting machine for the production of continuously cast
products. , After the steel is out of the vessel, the slag is poured
into a slag pot. When the pot is filled, it is run into the charging
aisle by means of a transfer car. The charging crane then picks up
the pot and carries it away for disposal.
The slag is sometimes disposed of by pouring it on the ground at
one end of the shop, where it is allowed to cool. Alternatively, the
pot of molten slag may be carried away from the shop and the slag
processed at a remote site. In either case, the metal lies are generally
removed from the slag by a magnet and returned to the blast furnace or
sinter plant and charged as a portion of the burden. The remaining
slag is generally disposed of in a dump area.6
3.2.1.2 Material Balance. As indicated on the flow sheet
(Figure 3-8), in order to produce a metric ton of steel in the BOPF
the following raw materials are required:
1. Ferrous charge materials consisting of approximately 70 percent
molten iron and approximately 30 percent scrap (higher percent-
ages of hot metal may be used if desired).* The typical yield
in a BOPF with an open hood is 85 percent. Therefore, to produce
1,000 kg (2,205 Ib) of steel, 825 kg (1,819 Ib) of molten iron
and 350 kg (772 Ib) of scrap are required. In the closed hood,
the yield increases to approximately 87 percent and the use of
molten iron and scrap drops correspondingly. Some shops have the
capability of preheating the scrap prior to the addition of the
molten iron. This practice would add about 15 min to the tap-
to-tap time; however, less molten iron and more scrap could be
used. In general, the proportion of hot metal might drop, from
70 to 60 percent with scrap preheating.
^Calculations presented elsewhere in this document are based upon
the assumption that 80 percent of the charge is hot metal and 20 percent
is scrap.
3-16
-------
2. Flux materials consisting of lime and fluorspar. Lime is
the principal ingredient. 'Its quantity is generally about
90 kg (198 Ib) per megagram of steel and varies correspond-
ing to the sulfur content of the iron and the specification
of the finished steel with regard to freedom from sulfur.
The quantity of fluorspar is determined by the need to
maintain a fluid slag and is generally 3 percent by weight
of the amount of lime. During 1979, the domestic steel
industry used 6.6 Tg (7.3 million tons) of lime and 305 Gg
(337,000 tons) of fluorspar in basic oxygen process
steel making.7
3. Oxygen in the amount of 3.1 scmm (110 scfm) per metric ton
of steel is injected into the bath. The amount of oxygen
used depends on two factors. One is the composition of the
molten iron, especially with respect to its content of such
materials as carbon, silicon, and manganese. The other is
the final carbon level required in the finished steel.
4. Ladle additions consist of alloying elements, such as
manganese, nickel, and chromium, that are required in
varying amounts, depending upon the required final composi-
tion of steel.
The basic oxygen process, in addition to producing steel, yields
slag, gases, and gas-borne particulates. The amount of slag is essen-
tially equal to the amounts of lime and spar added to the heat, plus
additions for refining of the bath and minus the emissions of slag to
the hood along with the furnace gases.
The amount of gases from the furnace varies according to the type
of fume collection system employed. These primary emission control
systems are discussed below:6
1. Open hood operation with ESP involves the greatest volume of
gas, approximately 0.78 dscms/Mg (1,500 dscfm/ton) of heat
size. This high value results from the absolute neces-
sity to combust completely all of the carbon monoxide that
is emitted from the furnace, thereby avoiding any possibility
of explosion in the precipitator. A supplementary benefit
of the high volume is that it facilitates the capture of
emissions from the mouth of the vessel when it is tilted
partially out of the hood to receive scrap and molten iron.
2. Open hood operation with wet scrubber generally involves
less flow of gases than does the open hood-precipitator
system, the amount being approximately 0.52 dscms/Mg
(1,000 dscfm/ton) of heat size for top blown furnaces. The
reduced volume results from the need to conserve energy in
the scrubber systems, which usually operate with a pressure.
3-17
-------
drop in the range of 127 to 178 ,cm (50 to 70 in) of water.
Also, the presence of combustibles in the scrubber system
would not entail a significant risk of explosion.
3. Closed hood operation with scrubber involves the least flow
of the three systems, appoximately 0.15 dscms/Mg (290 dscfm/
ton) of heat size for top blown furnaces and 0.17 dscms/Mg
(325 dscfm/ton) for bottom blown furnaces. This reduced
value results because secondary air to complete the combus-
tion of carbon monoxide is not permitted to enter the hood.
Energy requirements for cleaning the gases in the closed
system, because of the sharply reduced volumes, are lower
than those for the open system.
The amount of particulates carried out of the furnace into the
primary emissions gas cleaning system is approximately 14.25 kg/Mg
(28.5 Ib/ton) of steel produced. Each of the gas cleaning systems
described above is capable of reducing the concentration of particu-
lates in the clean gas to, or below, the level of the existing New
Source Performance Standard, i.e., 50 mg/dscm (0.022 gr/dscf).8
Therefore, the mass rate of particulates in the clean gas depends
essentially upon the volume of gas leaving the stack and, in turn, is
related to the type of cleaning system employed.
3.2.1.3 Methods of Operation.
3.2.1.3.1 Top blown furnaces—In the basic oxygen steelmaking
process, molten iron is converted to steel using a jet of oxygen to
remove most of the carbon and silicon. The heat generated by oxida-
tion melts the scrap. Removal of impurities is accomplished by means
of the slag, the chief goal being to remove as much of the sulfur from
the steel as is possible. Meeting the desired specifications of the
end product is usually accomplished by the addition of suitable allo-
ying materials to the teeming ladle while the steel is being tapped.
In comparison to other steelmaking processes, a typical BOPF
furnace produces a heat of steel in a very short time. Tap-to-tap
times in a high performance shop may be as brief as 30 minutes. To
accomplish this, the process is highly mechanized and is under some
form of computer control. Computer control may be applied directly
from the computer through electrical circuits to the furnace or, as is
most often the case, the computer provides information to the operator,
who then controls the process. High performance depends on equipment
3-18
-------
that is sophisticated and reliable. These factors tend not only to
produce steel at a rapid rate but also to avoid abnormal operating
conditions..
The lining of the BOPF furnace is made of high quality basic
refractory material. During a campaign that may last 1,000 to 2,000
heats or more, the linings become worn, especially near the slag line.
These points of wear may be patched between heats by various gunning
techniques (spraying of patching materials onto the wear points).
Eventually, linings wear so much that the furnace must be taken out of
service, the refractory removed, and a new lining installed. Approxi-
mately 1 week is required to remove the old lining and replace it with
a new one.
A less frequent cause of vessel downtime is the intense heating
and cooling of the steel shell of the vessel which ultimately affects
the quality of the steel shell itself. As a result of these changes,
the entire vessel must be replaced every 7 to 15 years.
Since a vessel is entirely out of service for approximately
1 week while being relined, it is imperative that both vessels in a
two-vessel shop are not scheduled for reline at the same time. To
avoid this situation, the number of heats in each vessel is carefully
monitored. Visual and instrumented inspections of the linings are
performed frequently so that relines can be scheduled well in advance.
One operating mode option for a two-vessel shop is to operate one
vessel while the other is on standby. Alternatively, both vessels may
be operated either sequentially or simultaneously. In some shops,
sequential operation is mandatory due to limited oxygen supplies. In
open primary hood shops equipped with only one ESP, simultaneous
operation may be precluded by the limited capacity of the ESP system.
Where the oxygen supply is adequate, simultaneous operation may be
practiced with some overlap in the blow periods. Synchronous opera-
tion of furnaces would be precluded by the limited availability of the
charging aisle cranes. In three-vessel shops, operations are scheduled
so that only one vessel at a time is relined. Thus, two vessels are
!
always available for use.
3-19
-------
When an upset occurs that may damage the equipment, the environment,
or the process itself, the process can be shut down instantly by
stopping the flow of oxygen and raising the lance. The'heat may
remain in the vessel for a relatively long period of time, possibly 6
or more hours, until necessary repairs have been made. However,
dumping the heat is preferred if a very long delay is anticipated.
The hood that conveys the gases away from the furnace is water
cooled. Water may be recirculated through a heat exchanger and returned
again for use in the hood. Alternatively, the water may be converted
to steam and delivered to other steelmaking operations. On some steam
generating hoods, fuel is fired into the hood between blow periods in
order to maintain a constant rate of steam output. Another way of
maintaining the output at a constant rate is to use a steam accumulator;
however, the generation of steam per ton of steel is less with this
method because no supplementary fuel is used.
As indicated above, it is possible to decrease the amount of
molten iron required by preheating the scrap. This is accomplished
with a second lance inserted in place of the oxygen lance after charging
of the scrap but prior to the hot metal charging operation. The
second lance injects oxygen and natural gas or oil and preheats the
scrap to a glowing red color. After preheating the scrap, the lance
is withdrawn and the vessel is tilted to receive the hot metal charge.
Pouring of molten iron over the heated scrap results in a violent
reaction and the production of copious emissions. The pouring rate
must be controlled carefully in order to ensure that the hooding
captures substantially all of the emissions.6 At the present time,
scrap preheating is not widely practiced in the United States.
3.2.1.3.2 Bottom blown furnaces (Q-BOP's)---The Q-BOP process
offers an alternative to the use of an oxygen lance. This is the
latest version of the basic oxygen process and is similar to a process
developed by Oxygen Blasen Maximillian-Huette, Bavaria, Germany (OBM
process). The Q-BOP process is now being licensed in the United
States by the U.S. Steel Corporation.
The Q-BOP process is carried out in a basic lined vessel that is
fitted with bottom tuyeres, each of which is made up of two concentric
3-20
-------
tubes. The oxygen is injected through the center tube of the tuyere
and is shrouded by a shield of hydrocarbon gas (usually natural gas),
which is injected through the larger of the two concentric tubes. On
entry into the vessel, the hydrocarbon is cracked endothermically,
thus absorbing the heat that would otherwise be liberated when the
oxygen first contacts the molten metal. This absorption of heat
protects the tuyeres from the rapid erosion that would otherwise take
place during the oxygen blow.
When a Q-BOP vessel is tilted to receive scrap and molten iron or
to sample for steel analysis, it is necessary to maintain a flow
through the tuyeres so that they do not become blocked. In normal
practice, the oxygen and natural gas are turned off when the vessel is
tilted and these gases are replaced by a flow of nitrogen. In any
event, there is a copious flow of emissions from the mouth of the
vessel due to the gas flow from the tuyeres. Two large, horizontally
sliding doors assist in directing the gases back into the collection
system and protect the workers who are on the charging floor. These
doors are opened only to permit the addition of scrap and molten iron
and are closed at all other times.6
The principal advantage claimed for the Q-BOP is that it requires
less headroom in the furnace aisle than does a top blown BOPF This
feature has allowed the installation of Q-BOP1s in existing open
hearth buildings, thereby decreasing costs in construction of the
facility and allowing a continuity of steelmaking operations during
the conversion.6 The overhead clearance requirements of top blown
furnaces make it impossible to fit them into existing open hearth
buildings.
Of the 14 BOPF's that have come on stream in the last 8 years, 8
are Q-BOP's. Five of these furnaces are in converted open hearth
steelmaking shops and the other three are part of a greenfield facility.
3.2.2 Emissions
The U.S. Environmental Protection Agency (EPA) has estimated
that, in 1979, the nationwide total of particulate emissions was
9.5 Tg (10.5 million tons) from industrial processes, which includes
iron and steel and the other primary metals industries, contributing
3-21
-------
47 percent of this total (Table 3-2). As shown in Table 3-3, the
primary metals industries produced 609.8 Gg (672,000 tons) of particu-
late emissions in 1979 with iron and steel producing 78 percent of
that total. Of the 474.7 Gg. (523.3 thousand tons) of particulates
produced by the iron and steel industry, 64.9 Gg (71.5 thousand tons)
were emitted by BOPF operations (Table 3-4). This constitutes
14 percent of the total particulate emissions from all iron and steel
sources.
On a total nationwide basis, the trend in particulate emissions
has been downward (see Table 3-5). The 1970 total of 21 Tg (23 million
tons) had been reduced by 55 percent to 9.5 Tg (10.5 million tons) in
1979. The iron and steel industry has performed slightly better
during the same time period, having reduced its emissions from 1.2 Tg
(1.4 million tons) in 1970 to 470 Gg (518,000 tons) in 1979 for an
overall reduction of 62 percent.
The operations in the BOPF shop are directly responsible for two
general categories of pollution: air pollution and solid waste pollution.
Water pollution, where it occurs, is a by-product of gas cleaning
operations.
There are two principal sources of air pollution associated with
BOPF's. One of these sources is the steelmaking process itself, which
generates dense emissions of fumes. These fumes, which are generally
captured by the primary hood, are called the primary emissions. These
emissions are mainly iron oxides which result from the reaction between
oxygen and molten iron, and particles of slag. The reaction between
the carbon dissolved in the iron and oxygen produces CO at a rate of
about 70 kg/Mg (140 Ib/ton) of steel produced.9 For a more complete
list of the particulate components of BOPF primary emissions, see
Table 3-6.
The gases that leave the mouth of the furnace, in addition to
being dusty, are extremely hot. In the closed hood system, tempera-
tures can reach approximately 1,650° C (3,000° F). In the open system,
CO combustion takes place at the entrance of the hood, raising the
temperature perhaps another 540° C (1,000° F). Before the gases may
3-22
-------
TABLE 3-2. NATIONWIDE PARTICULATE EMISSION ESTIMATES FOR 19798
Source category
Transportation
Highway vehicles
Aircraft
Rai 1 roads
Vessels
Other off-highway vehicles
Transportation Total
Stationary Source Fuel Combustion
Electric utilities
Industrial
Commerci al - Insti tuti onal
Residential
Fuel combustion total
Industrial processes3
Solid waste disposal
Incineration
Open burning
Solid waste total
Miscellaneous
Forest fires
Other burning
Miscellaneous organic solvent
Miscellaneous total
Total
Parti cul ate
Teragrams
1.1
0.1
0.1
0.0
0.1
1.4
1.5
0.6
0.2
0.2
2.5
4.3
0.2
0.2
0.4
0.8
0.1
0.0
0.9
9.5
emissions/year
(Million tons)
(1.2)
(0.1)
(0.1)
(0.0)
(0.1)
(1.5)
(1.7)
(0.7)
(0.2)
(0.2)
(2.8)
(4.7)
(0.2)
(0.2)
(0.4)
(0.9)
(0.1)
(0.0)
(1.0)
(10.5)
Includes iron and steel industry.
3-23
-------
TABLE 3-3. PARTICULATE EMISSIONS
FROM PRIMARY METALS INDUSTRIES FOR 197910
Source
Iron and steel
Aluminum
Copper
Zinc
Lead
Other
Total
Parti cul ate
Gigagrams
474.7
56.8
26.1
3.4
6.1
42.7
609.8
emissions/year
(Thousand tons)
(523.3)
(62.6)
(28.8)
(3.8)
(6.7),
(47.0)
(672.0)
TABLE 3-4. PARTICULATE EMISSION FROM THE IRON AND
STEEL INDUSTRY FOR 197911
Source
Coke manufacturing
Blast furnace
Sintering
Open hearth furnace
Basic oxygen process furnace
Electric arc furnace
Other
Total
Parti cul ate
Gigagrams
131.5
23.6
42.9
26.5
64.9
95.7
89.6
474.7
emissions/year
(Thousand tons)
(145.0)
(26.0)
(47.3)
(29.2)
(71.5)
(105.5)
(98.8)
(523.3)
3-24
-------
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3-25
-------
TABLE 3-6. COMPARISON OF PARTICULATE COMPOSITION FROM OPEN
AND CLOSED HOOD COLLECTION SYSTEMS3 2
Component
Open hood
collection process
(weight, percent)
Closed hood
collection process
(weight, percent)
Fe total
Fe metal
Fe as FeO
Fe as Fe304, Fe203
CaO
Si02
59
—
1.6
57,4
2
1
75
10
63
2
2
1 .
Partial analysis is given in each case.
'Calculated by difference.
3-26
-------
be cleaned of their particulate matter, they must be cooled.6 The
methods of cooling and cleaning the gases are briefly described in
Section 3.2.1.2.
3.2.2.1 Fugitive Emission Sources. There are a variety of
ancillary operations in a BOPF shop which generate emissions that may
not be captured by the primary hood. These emissions are known as
fugitive or secondary emissions. The available emission factors for
these sources are listed in Table 3-7. Descriptions of the sources
are given below:
1. Reladling or "hot metal transfer" of molten iron from the
torpedo car to the charging ladle is accompanied by the
emissions of kish, a mixture of fine iron oxide particulates
together with larger graphite particles. The usual method
of control is to provide a close-fitting hood and a baghouse.
A spark box between the hood and the baghouse protects the
bags from destruction by large, hot particulates. Normally,
the spark box is built integrally with the baghouse.
2. Desulfurizing of molten iron may be accomplished by various
reagents such as soda ash, lime, magnesium, or calcium .
carbide. Injection of the reagents into the molten, iron is
accomplished pneumatically, either with dry air or nitrogen.
Desulfurizing may take place at various locations within the
iron and steelmaking facility; however, if the location is
the BOPF shop, then desulfurizing is often accomplished at
the reladling station to take advantage of the fume collection
system at that location.
3. Skimming of slag from the ladle of molten iron keeps, this
source of high sulfur out of the steelmaking process.
Skimming is often done under a hood because it results in
the emissions of fine particulates called "kish." The hood
is usually connected to a baghouse.
4. Charging of scrap and molten iron into the BOPF vessel
results in a dense cloud of emissions. Emissions from the
charging of hot metal are particularly severe if the scrap
is dirty, oily, otherwise contaminated, or contains such
potential sources of explosion as water or ice.15 In some
open hood shops, if the main hood is large enough and the
volume of air flow is sufficient, it is possible to capture
most of the charging fumes in the primary collection system
of the vessel. In this case, as much of the vessel mouth as
possible is kept under the hood and the iron is poured at a
slow controlled rate. In other facilities (closed hood
primary systems), it is necessary to provide auxiliary hoods
in front of the main collection hood. On occasion, a facility
3-27
-------
TABLE 3-7. UNCONTROLLED EMISSION FACTORS FOR BOPF PROCESS12 13 14
Process
Emission factor
Primay emissions
Oxygen blowing
Secondary emissions
Hot metal transfer
Skimming
Scrap charge
Hot metal charge
Top blown
Bottom blown
Turndown
Tapping
Top blown
Bottom blown
Deslagging
Teeming
Slag handling
Ladle maintenance
Flux handling
14.25 kg/Mg steel 28.5 Ib/ton steel
89.5 g/Mg steel9
(96 g/Mg hot
metal poured)
b
b
189 g/Mg steel3
(200 g/Mg hot
metal poured)
310 g/Mg steel9
(330 g/Mg hot
metal poured)
146 g/Mg steel
460 g/Mg steel
35 g/Mg steel
0.179 Ib/ton steel3
(0.19 Ib/ton hot metal
poured)
b
b
0.377 Ib/ton steel3
(0.4 Ib/ton hot metal
poured)
0.62 Ib/ton steel3
(0.6 Ib/ton hot metal
poured)
b
0.291 Ib/ton steel
0.92 Ib/ton steel
b
0.07 Ib/ton steel
b
b
b
Based on 85 percent
metal.
3No emission factors
furnace yield and 80 percent of charge being hot
are available for these processes.
3-28
-------
8.
10.
may also have a hood at the building monitor to capture any
fumes that escape the hoods at the vessel. More charging
emissions are produced in bottom blown than in top blown
furnaces due to the. constant flow of gas through the tuyeres.
Tapping of the molten steel from the BOPF vessel into the
ladle results in iron oxide fumes. The quantity of fumes is
substantially increased by additions into the ladle of
alloying materials such as silicon and manganese.16 Some
BOPF facilities enclose the space at the rear of the furnace
in such a manner that the fumes are ducted into the main
collection system. In other facilities the fumes are permitted
to exit through the roof monitors.
Turndown of the vessel for the purpose of taking samples or
for pouring out the slag results in emissions. These emissions
are particularly copious in the case of the Q-BOP due to the
flow of nitrogen Which must be maintained through the tuyeres
in the bottom of the vessel in order to keep out the molten
metal and slag. Some facilities have a pair of sliding
doors on the charging floor in front of the vessel. These
doors are kept closed as much as possible to direct the
fumes into the primary collection system.
Slag handling may consist of transporting the ladle of
molten slag from the shop to a remote dump area or dumping
the molten slag on the ground at the end of the shop and
allowing it to cool there. The dumping of slag and its
subsequent removal by bulldozer is a dusty operation that is
generally uncontrolled.
Teeming of steel from the ladle to the ingot mold or continuous
caster results in emissions that are normally uncontrolled.
In some shops where leaded steels are poured, the resultant
fumes are extremely hazardous to the health of the workers.
In these cases, local hooding is provided.
Flux handling is effected with a sophisticated system comprised
of receiving hoppers for accepting deliveries from trucks or
railroad cars, a belt conveyor, large overhead storage bins,
weigh hoppers, feeders, and controls. Hooding is provided
at the various transfer points to capture the particulates
that escape when the bulk material falls. Exhaust ducts
lead from the hoods to one or more baghouses.
Skull burning and ladle dumping (ladle maintenance). The
molten steel that remains in the ladle after teeming may
cool and solidify between successive uses. In the vessel,
skulls may build up around the lip, and after accumulating
for some time, may interfere with proper operation. To
prevent this, skulls are burned out with oxygen lances.
This lancing procedure results in the emission of iron oxide
3-29
-------
11.
12.
fumes. Ladles must also be relined at intervals to protect
the steel shell. The ladles are turned upside down to dump
looseematerial onto the shop floor. This generates fugitive
Fugitive blowing emissions (puffing emissions') are process
emissions that escape capture Dy both primary and secondary
emission control devices. Occasionally, during a blow
chemical reactions within the heat or splashing of the slag
will generate large quantities of excess emissions that
cannot be handled by the hoods in the furnace enclosure
The frequency or severity of these episodes cannot be predicted
or anticipated during the blow.
Torpedo car deskullina and dekishina. Skulls that build up
around the pouring spout of torpedo cars are broken up with
a jackhammer and dumped on the ground. This operation
produces fugitive dust. Excess molten slag that remains in
the car after hot metal transfer can be dumped into a pit
This operation, which is called dekishing, produces fugitive
K I sn.
3.2.2.2 Nonprocess Sources of Fugitive Emssions. Two other
sources of pollution are those associated with the disposal of solid
waste from the process. The first results from the transportation and
disposal of the BOPF dust. Unless closed containers or trucks are
used, the act of transporting the dust can cause some of it to be
reentrained into the air. If the dust is recycled to the ironmaking
process, its disposal does not cause further environmental problems.
However, in most BOPF facilities, the contaminants in the dust, princi-
pally oxides of zinc and tin, may cause serious problems in the blast
furnace. Rather than recycle the dust, the operators find it necessary
to either "store" it on the ground in the open or dump it in a landfill.
In either case, special precautions must be taken to prevent wind from
picking up the dust and reentraining it into the air or to prevent
rain from leaching out toxic compounds from the dust and delivering
them to the underground aquifer or the nearby water course.6
The second source is the BOPF slag recycling operation. In a
separate facility, metallics are recovered from the slag by magnets
and returned to the steelmaking operations. Some of the slag, because
its content is relatively low in sulfur and high in lime, may be
3-30
-------
charged into the blast furnace. The remaining slag is disposed of in
the landfill. As with the dust, special care is required to avoid the
adverse aspects of leaching.4
There are, no direct sources of water pollution associated with
the basic oxygen process. Those water pollution sources that may
exist result from the particular type of fume collection system employed.
However, since all of the waste water streams discussed are amenable
to recycling after treatment within the plant (zero effluent), water
pollution from BOPF operations can be controlled.17 If a scrubber is
used, there could be discharge of scrubber water. Normally, most of
this is recycled through a clarifier. Facilities would be required to
deal with any blowdown to the water system. Even a dry precipitator
system could discharge contaminated water. This would result from the
final step in gas cooling, which is the quenching and conditioning of
the gases by means of water spray. If the quantity of water used in
conditioning or its method of application is not carefully controlled,
there could be an effluent of water from the conditioning process that
is contaminated with BOPF dust.6
3.2.3 Process Emissions Characterization
3.2.3.1 Emissions Generated During, the Oxygen Blow. Particulate
matter emissions from BOPF's are produced primarily by refractory
erosion and by condensation of vaporized metal oxides and coagulation
of these particles to form agglomerates. Thus, BOPF particulate
matter emissions consist mainly of spherical particles or agglomerates
of spherical particles with.similar properties.2
There are no recent data on the particle size distribution of
uncontrolled particulates from the oxygen blow. Data gathered prior
to 1970 indicate a relatively coarse size distribution.2 However, in
view of the fact that high pressure drop scrubbers are required for
particulate control, it is believed that more than 50 percent of the
particulate is less than 10 micrometers in diameter.
In the closed hood collection process, the dust is composed
mainly of iron oxide (FeO), magnetite, and small amounts of metallic
iron. Because FeO and magnetite agglomerate more easily than hematite,
3-31
-------
the dust particles are larger than those obtained from the open hood
collection process. , In the open hood collection process, the particles
consist of an outer surface of hematite surrounding a core of magnetite.2
The particulate generation rate in the basic oxygen process
depends on several factors, including oxygen blow rate, blowing method,
carbon content of iron, percentage of scrap charged, quality of scrap
charged, rate of additions, and condition of the refractory lining of
the vessel. During the production cycle, the gas evolution rate and
gas temperature vary considerably. Due to the resultant variations in
the concentration of particulate matter and gas temperature and volume
in the inlet gas stream, emissions are greater in the beginning of the
blowing period than during the remainder of the oxygen blow and the
rest of the cycle. Particulate emissions from oxygen blowing are
estimated to be about 14.25 kg/Mg (28.5 Ib/ton) of raw steel.13
3.2.3.2 Emissions from Secondary Sources. The secondary sources
of emissions within a BOPF shop are hot metal transfer, desulfurization,
skimming, charging, turndown, tapping, deslagging, teeming, ladle
maintenance, flux handling, and slag handling and disposal. The
fugitive nature of these emissions make them very difficult to study
and quantify. For this reason, very little work has been done to
characterize the emissions from these secondary sources.
Emission factors have been developed for hot metal transfer,
charging, tapping, and teeming.6 These are listed in Table 3-7. The
emission factor for hot metal transfer is 89.5 g/Mg (0.179 Ib/ton) of
steel produced. This factor is an average derived from tests during
which the pouring rates ranged from 26.4 Mg (29.1 tons) to 82 Mg
(90.4 tons) of hot metal per minute.12 Charging and tapping emission
factors are different for top and bottom blown furnaces, with the
greater factors for the bottom blown furnaces being attributable to
the constant purging of the tuyeres.
Little is known about the particle-size distribution of BOPF
fugitive emissions. The size distribution for Q-BOP charging emissions
is presented in Table 3-8. Approximately 50 percent of the particles
are 10.5 urn or less. The composition of BOPF fugitive emissions is
3-32
-------
TABLE 3-8. PARTICLE SIZE DISTRIBUTION FOR
Q-BOP CHARGING EMISSIONS18
Particle size
range
Percent of
particles within
size range
<1.55
1.55-3.6
3.6-10.5
>10.5
3.1
30.2
16.2
50.2
3-33
-------
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3-34
-------
TABLE 3-10. ELEMENTAL ANALYSIS OF BOPF CHARGING
EMISSION PARTICIPATES19
Element
Molybdenum
Niobium
Zirconium
Yttrium
Stronti urn
Rubidium
Bromine
Selenium
Arsenic
Germanium
Gallium
Zinc
Copper
Nickel
Cobalt
Iron
Manganese
Chromium
.Uranium
Thori urn
Bismuth
Lead
Mercury
Concentration
in gas
pg/m3
75
10
26
<2.4
16
9
346
49
46
0.8
33a
MCa
180
35
17_
MC!
MCa
512
9
<9
3
MCa
0.8
Element
Vanadi urn
Titanium
Scandium
Calcium
Potassium
Chlorine
Sulfur
Phosphorus
Silicon
Aluminum
Magnesium
Sodium
Fluorine
Boron
Lithium
Cerium
Lanthanum
Barium
Cesium
Tellurium
Antimony
Tin
Cadmi urn
Si 1 ver
Concentration
in gas
ug/m3
76
a
MC
<0.6
- MCa
a
MC
a
MC
62
MCa
MCa
3
MC
MCa
MC
a
MC
25
2
24
9
MCa
0.6
15
6
18
73
17
Major Component:
ppm.
concentration in sample greater than 1,000
3-35
-------
presented in Table 3-9. While iron and iron oxides make up most of
the emissions, the relative amounts of the various compounds are
influenced by the type of scrap charged. A detailed elemental analysis
of the hot metal charging emissions generated at one top blown BOPF
plant is presented in Table 3-10.
3.3 REFERENCES
1. Technology and Steel Industry Competitiveness. Congress of the
United States, Office of Technology Assessment. Washington, D.C.
June 1980. p. 186-188.
2. Drabkin, M., and R. Helfand. A Review of Standards of Performance
for New Stationary Sources—Iron and Steel Plants/Basic Oxygen
Furnaces. Metrek Division of the Mitre Corporation. McLean,
Virginia. EPA-450/ 3-78-116. November 1978. 65 p.
3. Telecon. Goldman, L., Research Triangle Institute, with
Hoffman, Dan, Granite City Works, National, Steel Corporation.
May 28, 1981. Discussion of KMS system for BOPF's.
4. Anonymous. National Blueprints Big BOP Shop Conversion. 33 Metal
Producing. November 1979. p. 63.
5. Formadley, Robert J. Granite City: Bold Modernization of An
Integrated Steel Plant. Iron and Steel Engineer. 57(8):SL67-SL82.
August 1980.
6. Coy, D. W., et al. Pollution Effects of Abnormal Operations in
Iron and Steelmaking—Volume VI. Basic Oxygen Process, Manual of
Practice. Research Triangle Institute, Research Triangle Park,
North Carolina. EPA-600/2-78-118f. June 1978. p. 3-18.
7. Minerals Yearbook 1978-79, Volume 1, Metals and Minerals. United
States Department of Interior, Bureau of Mines. U.S. Government
Printing Office. Washington, DC. 1980. p. 465-501.
8. Code of Federal Regulations, Title 40, Part 60.140, Subpart N.
U.S. Government Printing Office. Washington, DC.
9. Compilation of Air Pollutant Emission Factors, Third Edition,
U.S. Environmental Protection Agency, Research Triangle Park,
N.C. Publication No. AP-42. August 1977. p. 7.5-5.
10. National Air Pollution Emission Estimates 1970-1979, EPA-450/
4-81-010, March 1981.
\
11. Unpublished Data. National Air Data Branch, U.S. Environmental
Protection Agency, Research Triangle Park, N.C. August 1981.
3-36
-------
12. Cuscino, T. A., Jr. Particulate Emission Factors Applicable to
the Iron and Steel Industry. Midwest Research Institute, Kansas
City, Missouri. EPA-450/4-79-028. September 1979. p. 27-31.
13. Supplement No. 11 for Compilation of Air Pollutant Emission
Factors, Third Edition (Including Supplements 1-7). U.S. Environ-
mental Protection Agency, Research Triangle Park, N.C. Publica-
tion No. AP-42, Supplement 11. October 1980. pp. 7.5-6, 7.5-9.
Nicola, A. G. Fugitive Emission Control in the Steel Industry.
Iron and Steel Engineering. 53(7):25. July 1976.
Memo from Goldman, L., Research Triangle Institute to MacDowell,
W., EPA, February 10, 1981, Types of scrap and their effects on
BOPF secondary emissions.
Memo from Coy, D. W., Research Triangle Institute, to MacDowell,
W., EPA, February 12, 1981, Additives used in BOPF steelmaking.
Development Document for Effluent Limitations Guidelines and
Standards for the Iron and Steel Point Source Category, Volume III,
EPA 440/1-80/ 024b, U.S. Environmental Protection Agency.
Washington, DC. December 1980. p. 115-121.
18. Steiner, J., and J. Knirck. Particulate Matter Emissions Factor
Tests for Q-BOPF Hot Metal Addition and Tapping Operations at
Republic Steel, Chicago, Illinois. Acurex Corporation, Mountain
View, California. Acurex Project 7270. November 1978. p. 5-5.
19. Westbrook, C. W. Hot Metal Desulfurization, BOF (Basic Oxygen
Furnace) Charging and Oxygen Blowing: Level 1 Environmental
Assessment. Research Triangle Institute, Research Triangle Park,
North Carolina. EPA 600/2-82-036. February 1981. p. 45-46.
14.
15.
16.
17.
3-37
-------
-------
4. EMISSION CONTROL TECHNIQUES
4.1 INTRODUCTION
Primary control systems for basic oxygen process furnaces (BOPF's)
have been described in Chapter 3 and elsewhere.1 Briefly summarizing,
the CO produced may be burned at the mouth of the vessel; then the
particulate matter, the products of combustion, and the excess air are
drawn into an "open hood," cooled, and cleaned by a wet scrubber or an
electrostatic precipitator (ESP).
Alternatively, to reduce the temperature and volume of the gas to
be cleaned, the gas may be cleaned before burning. In this case, a
carefully fitted "closed hood" is required and cleaning with a wet
scrubber is necessary because of the hazard of igniting this potentially
flammable gas if cleaned in an ESP. The application of primary emission
control techniques to both open and closed hoods are described in this
chapter.
Emissions that occur during those steps in the cycle that require
the vessel to be tipped out from under the hood—scrap charging, hot
metal charging, sampling, tapping, and des lagging—are often poorly
controlled by the primary system. The ancillary operations of hot metal
transfer and slag skimming are not controlled at all by the primary
system. Both types of emissions, ancillary emissions and furnace emis-
sions, may be called "secondary emissions." Other secondary emission
sources that may be found in the BOPF shop are desulfurization of hot
metal, ladle repair, and ladle deskulling, teeming, flux handling, and
slag handling. Dekishing of torpedo cars is a secondary emission
source that is usually external to the BOPF shop. Performance data in
this chapter include some emission data from these latter sources.
4-1
-------
Secondary furnace emissions typically are produced by unconfined
sources such as leaks from the primary furnace hood or the open top of
a ladle. With the use of control techniques, these emissions are
captured by enclosures or hoods and are usually ducted to a particulate
control device. Capture techniques are as follows:
Furnace enclosures
Local hoods
Building evacuation
Full
Partial
Adaptation of primary furnace hooding (for open hoods only)
Particulate removal techniques are as follows:
Baghouses
Pressurized
Suction
Electrostatic Precipitators
Classical
Roof-mounted
Scrubbers
This chapter describes specific control techniques for primary furnace
emissions and secondary furnace emissions and for hot metal transfer
and hot metal skimming.
4.2 CAPTURE OF SECONDARY EMISSIONS FROM FURNACE OPERATIONS (CHARGING,
SAMPLING, TAPPING)
When the vessel is tipped out from under the hood of the primary
control system, whether for charging, sampling, or discharging refined
steel, the traditional primary control system may be rendered ineffective.
Potential remedies range from enclosing the space around the vessel,
to specialized hoods, to building evacuation.
4-2
-------
4.2.1 Furnace Enclosures
A furnace enclosure is a structure that may partially (on at
least two sides) or fully (on four sides plus the top) enclose a
furnace vessel. Most of the BOPF's brought on stream in this country
since 1973 are enclosed.2
A partial enclosure may be designed to shield the BOPF from most
drafts (other than that of natural convection), permitting hoods
within or adjacent to the enclosure to be more effective at lower air
flow rates. In comparison to a full enclosure, a partial enclosure is
less expensive, easier to retrofit (possibly without interrupting
production), and less likely to impede operations.
However, the trend is toward "total" enclosures.2 Figures 4-1
and 4-2 show such installations. Since the vessel is designed routinely
to tilt about only one horizontal axis, the enclosure can be fairly
simple on two sides. The enclosure roof is usually penetrated by the
primary exhaust duct, and it must be high enough for a closed system
to permit maneuvering the hood. Similarly, the flux chute and the
oxygen lance of top blown vessels must penetrate either the roof of
the enclosure or the primary hood. Within the enclosure, and sometimes
as part of the enclosure, are charging and tapping hoods.
The enclosure can extend partially or completely to the operating
floor at the rear, i.e., the side where tapping occurs, facing the
teeming aisle. Tapping is carried out at and below the level of the
vessel, and there is a tendency for hot, dusty gases to escape, in the
natural draft induced by the process heat. A hood that is either
permanently arranged so that it does not interfere with operations or
that is otherwise retractable to collect tapping emissions is desired.
Most of the complications attending full enclosure arise in the
front, i.e., the side at which charging is carried out, facing the
charging aisle. Here the enclosure includes a door (or doors) that is
moved out of the way while charging scrap and hot metal. Since these
operations occur at and above the vessel, natural convection will
permit a plume of hot dusty gas to escape into the building. Figure
4-1 shows the charging ladle mouth inside the furnace enclosure and
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under the charging hood. If high fume capture efficiency is to be
achieved, it is necessary to design the ladle, scrap box, hood, furnace
enclosure, and crane facilities to allow the transfer to occur close
to and under the hood. This design also tends to minimize the air
evacuation rate required to achieve high fume capture efficiency.
Chain curtains can be used to decrease the open area between the
charging ladle and hood face, and unlike a rigid metal partition, they
are not subject to damage. Achievement of an effective system design
is complicated by clearances needed for the movement of cranes and
other heavy equipment.
If the enclosure doors are to maintain their original fit, they
must not warp, despite the differences between inside and outside
temperatures. This requirement suggests that the doors be of substan-
tial construction and generously insulated, water cooled,4 or both.
Figure 4-1 shows an opening at ground level on the charging side.
This opening permits the entry and removal of a transfer car carrying
the slag pot into which the furnace slag is poured. The concept of
total enclosure requires that a vertical shield designed to close this
opening be attached to the transfer car.4 Because the environment is
less severe here, this shield can be portable and need not be as
substantially constructed as the enclosure doors.
The total enclosure, then, is not truly total. The housing is
penetrated by ductwork and is opened and closed to permit access, and
the quality of closure is imperfect at best. However, the goal is not
perfect enclosure, but the substantial prevention of emissions to the
building. As such, if the capture system draws dusty air from inside
the enclosure, and if the enclosure and the exhaust system are compatibly
designed and are operated knowledgeably, the goal will be achieved.
The control system (capture plus particulate removal) may be an
extension of the primary control system. A hood designed to collect
charging emissions and another for tapping emissions could be ducted
to the primary system. Gas flows could be adjusted for the differing
demands of the several parts of the cycle.
4-6
-------
In the closed hood system that intermittently handles a flammable
gas, the use of the primary system to control dusty air from secondary
sources presents the possibility of an explosion. However, the facil-
ities in at least one shop have been designed to permit safe collection
of secondary emissions in the closed hood primary system.3
The more typical alternative is to duct the charging and tapping
hoods in the furnace enclosure to a secondary control unit, commonly a
bag filter. Such systems will be further described in following
sections.
Furnace operations dictate the necessity for opening and closing
the doors on a furnace enclosure. For a total enclosure, the charging
of scrap and hot metal to the furnace vessel requires the door(s) to
be open. Immediately following hot metal charging, the door(s) may be
closed. Since observation of the vessel top is important to the
operator (visual feedback on the occurrence of foaming and slopping
over the vessel top), a television picture or small observation port
in the upper part of the enclosure could be used to satisfy this need.
As the oxygen blow is completed, it is necessary to take a metal
sample and measure the metal temperature. In the United States, most
furnaces must be turned down to do this. Another opening in the
enclosure door may be provided to insert a thermocouple and sampling
spoon. Where such an opening has not been provided, it is necessary
to open the doors at least partially. This may cause poor control of
furnace,emissions during the sampling period. If the doors are left
open for the remainder of the production cycle, generally poorer
capture of secondary furnace emissions can be expected. In their Oita
and Yawata Works, Nippon Steel uses a sublance assembly to measure
temperature and obtain a metal sample.5 6 In a manner similar to that
for the oxygen lance, the sublance is lowered into the furnace through
a hole in the furnace enclosure. This sublance assembly avoids turn-
down for sampling, thus eliminating potential secondary emissions.
Doors on the tapping side of the enclosure generally need not be
opened except for maintenance. Observation ports with closure flaps
can be provided at required locations.
4-7
-------
Examples of plants with furnace enclosures that are considered
for best secondary controls systems are discussed in the following
sections.
4.2.1.1 Kaiser Steel (Closed Hood, Top Blown). The Kaiser Steel
secondary emission control facility at Fontana, California, controls
furnace emissions (charging, tapping, puffing of the primary, turndown)
from two 205-Mg (225-ton) furnaces plus hot metal transfer and hot
metal skimming.7 A schematic diagram of the secondary emission control
system is presented in Figure 4-3. The furnace enclosure is similar
to that in Figure 4-1.
The secondary emission control system has two fans, each rated at
149 acms (315,000 acfm) at 50 cm (20 in) of water column and 230° C
(450.° F).8 Both fans operate to provide the baghouse design flow of
283 acms (600,000 acfm). Dampers are used to reduce gas flow and
energy consumption when full system flow is not required. Air flow is
divided among the various secondary hoods according to the needs for
each operation. The operations permitted to occur simultaneously
depend on whether one or both furnace vessels are being used. Based
on design information, hot metal charging requires the largest air
flow, or about three-quarters of system capacity. The Kaiser system
does not permit hot metal transfer, hot metal skimming, or a hot metal
charge to the other vessel while one vessel is being charged. The
system does permit oxygen blow, turndown, tapping, or deslagging on
the second vessel when one vessel is being charged.
Hot metal transfer or hot metal skimming may occur at any time
that neither furnace is being charged. On this basis, about one-third
system flow capacity is required for hot metal transfer or skimming.
The baghouse is a 12-compartment (two cells each), positive
pressure installation with 33,400 m2 (360,058 ft2) gross cloth area.
The gross air-to-cloth ratio is 0.533:1 m/min (1.75:1 ft/min) with a
net air-to-cloth ratio of 0.610:1 m3/min/m2 (2.0:1 ftVmin/ft2) when
three cells are offline. Bag fabric is fiberglass treated with sili-
cones, graphite, and teflon. Bag cleaning is performed by a reverse
air system.
4-8
-------
/
/
Hot metal
transfer
1
— — I I I
\ / Slag \ / Hot metal \ / Slag V
V / skimming V / transfer \ / skimming \
Furnace
charging hood
1
Furnace
charging hood
2
\
Tapping hood
V
Tapping hood
Baghouse
1,020,000 m3/hr
maximum temperature 230° C
Exhaust fans
Figure 4-3. Schematic of Kaiser Steel-Fontana basic oxygen secondary
emission control system.
-------
Performance of the secondary emission control facility at Kaiser
has been measured by visible emission methods. Visible emission
measurements of roof monitor discharges were made during.April 1980.9
The measurements were made in accordance with EPA Reference Method 9.
These measurements, however, have been analyzed by computing
3-minute averages instead of the 6-minute averages directed by Reference
Method 9. The use of a 3-minute average was selected because of the
short duration and rapidly varying intensity of secondary visible
emissions characteristic of the BOPF steel production cycle. All of
the 3-minute averages were segregated by furnace cycle to analyze
performance of the secondary emission control system by furnace cycle.
Table 4-1 displays the maximum 3-minute average opacity and the second
highest 3-minute average opacity occurring during each observed furnace
cycle.
Selection of the maximum 3-minute average opacity was made by
computing running (or moving) averages for each cycle. The highest
moving average was chosen; then the second highest was chosen in such
a way that none of the individual readings used to compute either
average were common. Therefore, the maximum and second highest 3-minute
averages are mutually exclusive observations. The mean maximum 3-minute
average was 5.4 percent and the mean second highest 3-minute average
was 1.5 percent. These data were further analyzed statistically to
determine 95 percent prediction limits; i.e., there is a 5-percent
probability (1 chance in 20) that a further observation at this plant
or another plant performing equally well would exceed this limit. For
the maximum 3-minute averages, the 95-percent prediction limit is 16
percent opacity. For the second highest 3-minute averages, the prediction
limit is 7 percent opacity.
The data taken at Kaiser represent single-furnace operation.
They include the effects of hot metal transfer, hot metal skimming,
teeming, charging, tapping, and other secondary source emissions.
Based on these data, the Kaiser secondary emission control system was
more effective than the other top blown, closed hood installations for
which data were obtained.
4-10
-------
TABLE 4-1. KAISER STEEL, FONTANA, CALIFORNIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES9
Date
4/7/80
4/8/80
4/9/80 .
4/10/80
4/11/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Maximum
Observer 1
10.4
2.1
14.2
10.3
5.0
12.5
7.1
7.9
3.3
0.0
8.3
0.0
0.0
0.0
17.1
0.0
0.0
5.0
.7.9
15.0
0.0
average
Observer 2
5.4
2.5
13.8
10.4
5.4
16.3
5.8
5.4
3.3
0.8
6.3
0.0
0.0
0.0
13.3
0.0
0.0
5.4
6.7
0.0
0.0
Seond
highest average
Observer 1 Observer 2
4.2
0.0
10.0
0.0
3.3
2.9
3.3
1.3
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.0
3.3
0.0
0.0
0.0
4.2
0.0
10.4
10.4
3.8
1.7
3.8
0.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4-11
-------
4.2.1.2 Republic Steel, Chicago (Closed Hood, Bottom Blown).
Only three plants in the United States presently have bottom blown
furnaces (Q-BOPF's). Republic Steel near Chicago is one of them. The
two furnace vessels in the Republic Steel plant have a capacity of
205 Mg (225 tons). The secondary emission control system at this
plant includes full-furnace enclosures with charging hoods at the
front of each enclosure (Figure 4-2). There are no tapping hoods, and
neither hot metal transfer emissions nor hot metal skimming emissions
are ducted to this system. The Chicago shop is the best controlled
bottom blown BOPF shop in the United States.
The operations of the Q-BOPF during charging and turndown require
gas (either nitrogen or oxygen) to be blown through the tuyeres to
prevent liquid metal, slag, or solids from entering and clogging the
tuyeres. This factor makes the capture of secondary emissions more
difficult than for top blown furnaces.
Draft for the charging hood at the Republic plant is obtained
from the primary fume control system, as shown in Figure 4-4. Each
furnace has its own primary gas cleaning system; however, a crossover
duct between the two furnaces permits the system for the nonoperating
furnace to be used for secondary emission control. With both gas
cleaning system fans drafting the charging hood, the flow rate is
about 176 acms (373,000 acfm) at 93° C (200° F) during hot metal
charging.10 During the oxygen blow, the charging hood is drafted
continuously through the scrubbing system of the nonoperating vessel.
During turndown and tapping, the charging hood is drafted by the
scrubbing system of the nonoperating vessel. Fume capture during
these latter operations is assisted by drafting the primary hood as
well. Fumes captured in the secondary (charging) hood bypass the
quencher and pass directly to the venturi in the scrubbing system.
The design pressure drop of the venturi during furnace charging is
218 cm (86 in) of water column.
The performance of the secondary emission control system at
Republic Steel, as indicated by roof monitor opacity observations, was
poorer than the best performing top blown secondary emission control
4-12
-------
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system. Data are available for two test series, June 1979 and June
1980.10 X1 These measurements were made in accordance with EPA Reference
Method 9. The data was analyzed is the same manner as that for Kaiser
Steel. Tables 4-2 and 4-3 display the.maximum 3-minute average opacity
and the second and third highest 3-minute averages occurring during
each furnace cycle for the two test series. The overall mean of the
maximum 3-minute averages was 17.5 percent as compared to 5.4 percent
for Kaiser. The overall mean of the second highest 3-minute averages
was 10.0 percent as compared to 1.5 percent for Kaiser. The overall
mean of the third highest 3-minute averages was 6.6 percent. Also in
comparison to Kaiser, it is apparent that many of the maximum 3-minute
averages exceeded 20 percent opacity, whereas none did for Kaiser.
Statistical analysis of these data for 95 percent prediction limits,
as discussed in Section 4.2.1.1 for Kaiser, yields 55 percent for the
maximum 3-minute averages and 26 percent for the third highest 3-minute
averages.
During the 1979 tests, it was noted that leakage occurring on the
tapping side of the furnace enclosure contributed to tapping fugitive
emissions.10 The addition of a separate tapping side hood to the
enclosure might improve overall system performance.
4.2.2 Primary Control Systems Used for Secondary Emission Control
A number of consent decrees negotiated between EPA and steel
companies have included provisions for reducing roof monitor discharges
from existing BOPF shops. In several cases, roof monitor emissions
have been decreased to levels complying with consent decree terms by
using primary emission control systems to capture charging and tapping
emissions. This use of the primary system to achieve compliance has
been aided by the adoption of operating practices conducive to lesser
fume generation and by the modification of, and addition to, process
equipment and pollution control equipment.
In general, those shops with relatively large flow capacity in
their primary control system are better suited to achieving low roof
monitor emissions from furnace operations. Higher flow capacity means
that higher indraft velocities can be achieved to capture fugitive
emissions at a given distance from the hood.
4-14
-------
TABLE 4-2. REPUBLIC STEEL, SOUTH CHICAGO, ILLINOIS
Q-BOPF ROOF MONITOR OPACITY OBSERVATIONS8
3-MINUTE AVERAGES10
Maxium average
Second
highest average
Third
highest average
Date Run
6/18/79 1
6/18/79 1
2
3
4
5
6/19/79 6
7
8
9
10
11
6/20/79 12
13
14
15
16
17
18
6/21/79 19
20
21
22
23
24
25
6/22/79 26
27
Observers
1 2 .
12.4
—
—
—
—
12.5
16.7
10.8
2.3
2.5
3.8
10.8
15.8
0.8
4.6
3.8
11.3
8.8
60.4
27.5.
22.5
10.0
5.0
6.7
5.0
30.8
45.4
44.6
46.3
33.8
38.8
44.6
23.8
11.7
5.0
9.6
2.9
0.0
8.8
0.8
2.5
2.9 -
2.1
3.8
4.2
1.3
5.0
12.5
4.2
0.8
1.7
3.3
18.3
13.8
Observers
1 2
12.5
—
—
—
—
—
12.5
6.3
5.4
0.4
0.0
1.3
2.9
5.8
0.8
3.8
1.7
8.8
5.8
34.2
26.3
6.7
2.5
1.3
1.3
4.6
21.7
20.8
13.3
42.5
32.1
24.2
20.4
22.5
11.3
3.3
0.0
0.8
0.0
5.8
0.0
2.1
2.1
0.8
0.0
0.4
1.3
1.7
6.3
3.3
0.4
0.8
2.9
9.2
13.3
Observers
1 2
12.5
—
—
— -
—
11.3
5.0
2.1
0.4
0.0
1.3
2.1
3.8
0.4
1.7
0.4
5.4
1.7
11.3
2.1
6.3
2.1
0.0
0.8
4.2
12.9
12.5
12.9
27.5
29.2
22.9
8.8
18.8
10.4
2.9
0.0
0.0
0.0
5.4
0.0
1.3
0.4
0.4
0.0
0.4
0.0
0.8
5.4
1.7
0.0
0.4
0.4
3.8
12.9
Tested by GCA Corporation.
4-15
-------
TABLE 4-3. REPUBLIC STEEL, SOUTH CHICAGO, ILLINOIS
Q-BOP MONITOR OPACITY OBSERVATIONS3
3-MINUTE AVERAGE11
Maximum average
Second
highest average
Third
highest average
Date
6/2/80
6/3/80
6/4/80
6/5/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Observers
1 2
29.6
5.8
40.0
35.0
17.1
29.2
9.6
12.1
9.2
1.3
23.3
59.2
42.1
40.8
27.5
4.6
37.9
28.8
46.3
32.1
7.9
10.8
5.8
2.1
23.3
41.7
32.1
43.8
28.8
Observers
1 2
5.0
2.5
14.2
23.3
8.3
24.6
3.8
8.3
5.8
0.8
7.5
37.5
8.3
39.6
22.1
____
3.3
14.6
25.8
14.6
21.7
1.7
7.1
4.6
1.7
8.8
19.2
5.0
36.3
14.6
Observers
1 2
3.3
0.8
14.2
21.3
4.6
21.7
3.3 .
7.9
5.0
0.0
0.0
16.7
7.1
30.0
14.6
— — . — —
0.8
12.9
17.1
11.7
17.5
1.7
2.5
4.6
0.8
0.8
14.6
4.6
15.8
8.3
Tested by Clayton Environmental Consultants.
4-16
-------
Another factor contributing to the success of this approach is
the reduction of fume generation. The use of clean scrap (non-oil-
bearing, nongalvanized), the slow pouring of hot metal into the furnace,
the careful positioning of the hot metal ladle with respect to the
hood face and furnace mouth, and the proper furnace tilt angle are all
means of reducing charging emissions.
Extension (flanges) from the primary hood into the charging and
tapping aisles helps to provide more draft closer'to the points of
emission. Likewise, an extension of the pouring spout on the hot
metal charging ladle will move the emission generation point closer to
or under the hood.
4.2.2.1 Bethlehem Steel. Bethlehem, Pennsylvania. This BOPF
shop has two 272-Mg (300-ton) furnaces with an open-hood-type primary
gas cleaning system. Each furnace is partially enclosed by side
walls, with no enclosure on the charging or tapping sides. An awning
has been constructed on the tapping side between the side enclosures
that extends toward the teeming aisle, as shown in Figure 4-5. This
awning acts as a flanged extension of the primary hood and helps
direct tapping fumes into the primary hood. There is also an extension
from the primary hood on the charging side of the furnace.
During hot metal charging operations, the gas evacuation rate for
the primary hood is 236 acms (500,000 acfm) at about 82° C (180° F).12
13 The initial portion of the hot metal charge is performed with the
furnace mouth tipped only partially out from under the hood. As the
charge nears completion, the furnace is turned further, bringing out
the entire mouth. Fume escape is worst at the end of the charge.
During the oxygen blow, the primary hood evacuation rate is about
353 acms (750,000 acfm) at a temperature of 210° C (420° F).12 13
When the vessel is turned down for tapping or other reasons, the evacu-
ation rate is 236 acms (500,000 acfm) at about 82° C (180° F).12 13
The primary and secondary gas cleaning device for this BOPF shop
is an ESP. A dropout chamber precedes six horizontal dry precipitators
operating in parallel.
4-17
-------
Primary Hood
Hood Extension
for Tapping
Charging
Aisle
JJL
Steel Ladle
bo—-DO
Figure 4-5. Bethlehem Steel, Bethlehem, Pennsylvania-BOPF partial furnace
enclosure for open primary hood.
4-18
-------
Roof monitor visible emissions observations were performed at
this plant in June 1980.14 The observations were made in accordance
with EPA Reference Method 9. As previously discussed, the measurements
were analyzed by computing 3-minute averages instead of the 6-minute
averages directed by Method 9. From the 3-minute averages segregated
by furnace cycle, a maximum 3-minute average and second highest S^-minute
average were chosen for each cycle, as discussed in Section 4.2.1.1.
These data are presented in Table 4-4. The mean maximum 3-minute
average is 1.4 percent and the mean second highest average is 0.3
percent, as compared to 5.4 percent and 1.5 percent, respectively, at
Kaiser Steel. Also as discussed in Section 4.2.1.1, 95 percent predic-
tion limits were calculated for the Bethlehem data. The limit based
on maximum 3-minute averages is 6 percent and the limit based on
second highest 3-minute averages is 2 percent.
All these data for Bethlehem Steel represent single-furnace
operation. In addition to furnace operations, slag pot dumping, ladle
deskulling, hot metal transfer, and teeming occurred during these
tests.
A significant portion of the performance achieved at the Bethlehem
plant must be attributed to good operating practice and skillful crane
and furnace maneuvering. The plant is missing the benefits of a
full-furnace enclosure and the advantage of local hoods closer to and
immediately above the fume sources found in new plants. The effective-
ness of secondary emission control at the Bethlehem shop by using the
primary hood is superior to the effectiveness of the Kaiser system.
However, the techniques employed at Bethlehem are not applicable to
all BOPF shops. The Bethlehem shop vessels are equipped with open
hoods while most modern BOPF vessels are of closed hood design.
A further consideration in examining the effectiveness of primary
systems used for secondary emission control is how well total emissions
are controlled. Test data for Bethlehem's primary system presented in.
Section 4.4.2.1 show the open hood system to be much less effective
for the control of primary emissions than the most effective closed
hood primary systems. However, a new shop might choose to employ the
4-19
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TABLE 4-4. BETHLEHEM STEEL, BETHLEHEM, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES14
Date
6/23/80
6/25/80
6/26/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
Maximum
Observer 1
0.83
3.75
0.0
0.0
0.0
0.0
6.67
0.0
0.0
1.25
5.0
0.83
average
Observer 2
1.25
2.50
0.0
0.0
0.42
0.42
5.83
0.0
0.0
0.42
3.33
1.25
Second highest
average
Observer 1 Observer 2
0.83
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.75
0.0
0.42
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
1.67
0.42
4-20
-------
open hood design with a more efficient participate control device that
could match the closed hood effectiveness for primary emissions and
also effectively collect secondary furnace emissions.
4.2.2.2 Jones and Laugh!in (J&L) Steel, Aliquippa, Pennsylvania.15
This is a three-vessel shop with a nominal capacity of 188 Mg (205 tons)
per furnace per cycle.15 The primary gas cleaning systems for these
furnaces are open hood type with two ESP's. Normal operation in this
shop is two vessels in service that can be blown simultaneously, if
desired.
To achieve the control of secondary emissions from furnace operations,
each furnace is enclosed on three sides—tapping side plus the sides
with trunnion rings. The front or charging side may be partially
enclosed while the oxygen blow is in progress by means of a curtain
mounted on a trolley rail. Curtains have been hung underneath the
furnace operating floor to restrict air movement into the partial
furnace enclosure from the teeming ladle car side.
The gas capture and cleaning system for the shop consists of open
combustion hoods above each furnace, an evaporation chamber for each
furnace, downcomers to a common manifold and damper arrangement, two
ESP's, an outlet manifold leading to a draft arrangement with seven
fans, and two discharge stacks. The design of the evaporation chamber
includes the provision for steam injection or water injection to
achieve the correct moisture level in the waste gas for effective ESP
performance.
The damper arrangement provides for isolating the hood at the
furnace on which maintenance needs to be done. This prevents wasting
available draft on nonoperating furnaces. Gas flow from the combustion
hoods is controlled by louvered dampers between the downcomers and
precipitator inlets.
Two precipitators remove particulate from the waste gas streams.
Each ESP has its own stack. One precipitator consists of six chambers
with five fields each. The total collection surface available in this
precipitator is 26,648 m2 (286,848 ft2). The second precipitator
consists of eight chambers with five fields in the direction of gas
4-21
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flow. The total collection surface area in this precipitator is
44,146 m2 (475,200 ft2). With two furnaces in operation, normal .
practice is to use six of the eight chambers in the one precipitator
for one furnace, and the remaining two chambers plus the other ESP for
the other furnace. Based on actual gas flow during recent tests of
328 acms (695,000 acfm), the respective specific collection areas are
115 and 101 m2 per acms (584 and 512 ft2 per 1,000 acfm).15 The
design of the precipitators1 damper systems is such that a single
precipitator chamber can be taken out of service for maintenance while
the other precipitator chambers remain in use.
The seven induced draft fans are normally divided up four and
three between the two precipitators. However, the damper arrangement
permits the center fan to be used with either of the two precipitators,
depending upon the draft needs and whether one of the other fans may
be out of service for maintenance. There is sufficient draft with
only six fans that the furnaces can continue to operate at full production.
J&L personnel operate the draft system wide open during hot metal
charging, tapping, and oxygen blowing. The waste gas flow under these
conditions is reported to be about 221 scms (468,100 scfm).15.
There is a time delay on the damper controls in the system to
prevent puffs that may occur at the end of the oxygen blowing periods
by premature closing of the dampers. The primary hood is not drafted
at all during vessel turndown.
To improve precipitator performance, water conditioning sprays
are used to add moisture to the gas stream during the oxygen blowing
cycle. Because the flue gas temperature is too low at the beginning
of the blowing cycle to evaporate a sufficient amount of water, steam
is injected. Steam injection is used during the hot metal charging
operation and also during tapping operations due to low gas temperature
at those times. Steam injection during hot metal charging of the
furnace is controlled by a timer and lasts approximately 2 min. The
crane operator is not supposed to begin pouring hot metal until he
hears the steam turned on. Steam injection at the beginning of the
oxygen blow is also controlled by a timer. The steam is turned on as
4-22
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the oxygen lance is lowered into the furjiace and continues to flow for
about Ih min into the blowing period. Steam injection is practiced
for approximately 15 min per furnace cycle. The steam injection rate
is approximately 36,300 kg/hr (80,000 Ib/hr) for the duration of the
injection period.
A water ring and water sprays are used to reduce fugitive emissions
from the hood during furnace puffing. A water ring is placed on the
oxygen lance and water sprays are placed around the lance hole in the
hood. The function of the water ring and sprays is to partially cool
the gases leaving the furnace, especially during periods of puffing,
to reduce gas volume and avoid exceeding the capacity of the system to
withdraw these gases. In the case of the water sprays around the
lance hole, the purpose is to reduce fume leakage from the lance hole
opening. The lance water ring technology is proprietary and available
from Republic Steel Corporation.
To avoid fugitive discharges from the flux chute, a flapper valve
has been installed in the chute. It allows flux materials to fall
through, but closes to prevent fumes from rising up through the chute
at other times.
Hot metal charging practices have been changed since adoption of
the program to control secondary emissions. The normal hot metal
charging rate -prior to this program was 45 s; it is now a minimum of
75 s. During hot metal charging, the furnace is tilted to an angle of
38° from the vertical. To improve fume capture by the primary hood, a
longer pouring spout has been installed on all the charging ladles.
After hot metal is charged to the furnace, the emission control practice
requires the movement of the curtain on the charging side of the
furnace to a position in front of the furnace to reduce the open area.
Doors on the tapping side of the furnace enclosure are kept
closed while the vessel is in operation. Holes in the tapping side
doors and windows in the furnace enclosure provide the needed visibility
for the operators.
In October 1980, 6 days of roof monitor visible emission tests
were performed at the plant under the direction of EPA Region III.16
4-23
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The observations were made in accordance with EPA Reference Method 9.
These data were analyzed by computing 3-minute average opacities
instead of 6-minute averages. The maximum and second highest 3-minute
averages were selected for each cycle on each furnace. Because the
furnace operations are overlapping, some of the values reported are
common to both furnaces. Tables 4-5 and 4-6 display the test results.
The data are representative of simultaneous two-furnace operation, hot
metal transfer, and teeming, which occurred during these tests. The
overall mean maximum 3-minute average was 3.9 percent and the mean
second highest 3-minute average was 2.1 percent as compared to Kaiser
Steel's 5.4 percent and 1.5 percent, respectively. As discussed in
Section 4.2.1.1, 95 percent prediction limits were calculated for
these data. The limit for the maximum 3-minute averages was 11 percent
and the limit for the second highest 3-minutes averages was 6 percent.
Both purchased and in-house scrap are used in the furnaces.
Normally they do not use much No. 2 bundle, but it was used during
these performance tests to see how well the emission controls would
perform.15 The J&L personnel reported that steel heats to which
molybdenum is added are particularly smoky, so molybdenum heats were
also made during the performance tests, again to see how well the
emission controls would perform.15
4.2.3 Canopy or Roof Hoods, Partial Building Evacuation
Hooding is a common method for capturing particulate emissions
from scattered sources in a plant. The design of hoods for BOPF
secondary emissions is complicated by cross drafts that develop within
the building, interfering with fume capture. A hood that is located
close to the source and intended to reduce cross drafts may get in the
way of crane operations. Every design is a compromise between hood
and vessel clearance and the clearance necessary for crane operations.
The design of a hood, a duct, a fabric filter, and an exhaust fan.
to handle a specified volume of air is routine. The temporal variation
in average temperature and dust loading can cause mild fluctuations in
volume, which can be accommodated by modest overdesign. It is more
difficult to predict the source of the air that flows into the hood,
4-24
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TABLE 4-5. J&L STEEL, ALIQUIPPA, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES16
Date
10/6/80
10/7/80
10/8/80
10/9/80
10/10/80
10/13/80
10/14/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
No. 2 furnace
Maximum average
3.8
3.3
5.0
2.1
0.0
0.0
0.0
5.0
1.3
5.8
9.6
3.3
6.7
5.8
11.7
11.3
1.3
10.4
2.1
0.8
2.1
2.1
1.7
2.1
11.7
2.1
5.0
4.2
2.9
4.2
4.6
Second
highest average
3.3
2.1
1.7
0.4
0.0
0.0
0.0
1.7
0.0
4.2
5.0
2.1
5.8
0.0
3.3
2.5
0.0
8.3
1.3
0.4
0.4
0.0
1.7
0.0
5.4
0.0
1.7
3.8
2.5
2.5
4.2
4-25
-------
TABLE 4-6. J&L STEEL, ALIQUIPPA, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES16
Date
10/6/80
10/7/80
10/8/80
10/9/80
10/10/80
10/13/80
10/14/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
No. 3 furnace
Maximum average
2.1
0.0
1.7
2.1
0.0
0.0
0.0
5.0
5.8
5.0
9.6
3.3
2.1
0.4
5.8
11.7
2.5
7.1
1.3
2.1
2.1
1.7
2.1
11.7
5.4
0.8
2.1
1.7
4.2
4.2
4.6
5.4
Second
highest average
0.8
0.0
0.8
0.4
0.0
0.0
0.0
1.7
4.2
4.6
4.6
3.3
1.3
0.4
2.1
3.3
2.5
0.8
0.0
0.8
0.0
1.7
0.0
0.0
2.1
0.0
0.0
1.3
3.8
2.9
3.8
4.6
4-26
-------
unless the hood fits closely around the source. However, close fitting
can interfere with the batch operations of the process. If the hood
is positioned so as not to interfere and the system is undersized,
part of the rising plume may escape on one side while clean air is
drawn in on the other. Cross drafts are unpredictable; sheet metal
barriers may be erected to diminish their effect. If the hood is to
capture the plume consistently, a remedy is overdesign or a "factor of
safety." The degree of excess capacity in a system cannot be known
until it is operated under a variety of climatic and production conditions.
Apart from the emissions that are collected regularly at fixed
locations, certain necessary maintenance operations generate dust that
is less susceptible to collection by local hoods. For example, when
it is necessary to reline a ladle, it will be allowed to cool; after
dislodging the refractory lining, the ladle will be turned upside down
and dumped into a truck or onto the shop floor.
Local hoods exhausting to a secondary system are only a part of
the secondary emission control system. Of those observed, the best
systems exhaust the several local hoods to a single baghouse,. using
interlocks and status lights to ensure that the full air-moving power
of the system is devoted to only a few tasks at any one time.7 17
Buildings to cover hot operations like glass melting, synthetic
graphite production, and BOPFs exploit natural convection for operator
comfort. The heated air rises and exits through roof openings (roof
monitors) with covers that prevent rain from falling on the furnaces.
Fine particles can be entrained in this rising air and exit through
the monitors.
The canopy hood is one answer for some emissions that either have
not been provided for or that inevitably escape the local hoods described
above. To the degree that the source is concentrated in one area of
the building, but not so concentrated as to permit local hooding of
the desired capture efficiency, there will be a relatively concentrated
plume of hot dusty gas rising from that area. A canopy hood will not
interfere with operations; can collect the fine, entrained particulate
at relatively low velocities; and can be ducted continuously to a
collecting device.
4-27
-------
There are disadvantages to canopy hoods. Cross drafts in the
shop can displace rising fume so that it evades the hood, or the
rising plume may expand and diffuse to dimensions larger than the hood
face. The canopy hood system adds a significantly larger gas volume
to be cleaned. When added to an existing system, canopy hoods may
reduce draft in the rest of the system to the point that air velocity
in the other hoods is too low to capture fume effectively.
One means of reducing the impact of cross drafts and avoiding the
problem of the plume's becoming larger than the hood face dimensions
is to use partial building evacuation. The building structure, in
essence, becomes the hood for a particular part of the operation.
Partition walls may be installed between building columns to prevent
lateral movement of the plume into adjacent portions of the building.
These partition walls may extend as low as crane operations will
permit and may extend as high as the roof. Sheeting or partitions may
also be used to seal the roof area to prevent the escape of emissions
by natural thermal draft. One or more duct connections may be made
into the sealed portion of the building to extract contaminated air
for gas cleaning.
A further variation of this approach is available by altering the
choice of gas cleaning device. Instead of ducting contaminated air
away to a remote collector, the collector may be erected immediately
above the enclosed roof area. At least three companies presently
offer roof-mounted ESP's that take advantage of the natural thermal
drafts above the hot processes. However, none are installed in U.S.
BOPF shops. Since precipitators are characteristically low-pressure-
drop devices, the thermal draft assist means little or no fan power is
required to move contaminated air through the collector. Additional
information concerning roof-mounted collectors will be presented later
in this chapter.
4.2.3.1 Inland Steel, East Chicago. Indiana (Closed Hood, Top
Blowr|)- There are two principal secondary emission control systems in
this plant. One system treats furnace emissions captured in local hoods
located in the partial furnace enclosure. The second system cleans
4-28
-------
emissions captured by partial building evacuation and emissions from
local hoods at the hot metal transfer and hot metal skimming stations.
Local hoods within the partial furnace enclosure include a charging
hood, a tapping hood, and a wrap-around hood (at the side of the
furnace) to capture puffing emissions during the oxygen blow. During
charging, only the charging hood is drafted; during tapping, the
tapping hood and wraparound hoods are drafted. While oxygen blowing
is occurring, all three hoods are drafted. Air flow for the furnace
enclosure secondary emission control system is induced through a
venturi scrubber by a fan rated for 62 acms (131,000 acfm) at 21° C
(70° F).18 The overall system pressure drop is 130 cm (51 in) of
water column. Since this evacuation rate is not sufficient to capture
all charging and furnace deslagging emissions, the partial building
evacuation system provides additional capture of these emissions.
The partial building evacuation system is applied only to the
furnace charging aisle. There is a curtain wall between the charging
aisle and furnace aisle to prevent substantial movement of charging
emissions into the uncontrolled furnace aisle. There are two duct
takeoffs in the charging aisle roof, one centered above each furnace.
A damper is provided in each takeoff to open or close it as necessary.
During hot metal charging and furnace deslagging, the damper is opened
to maximize the evacuation rate above the affected furnace.
The total air flow capacity for this partial building evacuation-hot
metal handling secondary emission control system is 189 acms (400,000 acfm)
at 135° C (275° F). Flow is divided between partial building evacuation
and hot metal handling, with 130 acms (275,000 acfm) allotted to the
roof ventilation system and 59 acms (125,000 acfm) to the hot metal
station. The available system pressure drop is 38 cm (15 in) of water
column, and gas cleaning is provided by a baghouse.
The relatively low charging hood draft (as compared to Kaiser's)
leads to a strong dependence on the partial building evacuation system
to capture fugitive emissions escaping the partial furnace enclosure.
Although curtain walls and partitions are used to reduce the effects
of cross drafts at Inland, the partial building evacuation rate appears
4-29
-------
to be insufficient to prevent leakage from the enclosed portion of the
building. The partial building evacuation rate of 189 acms (400,000 acfm)
is less than that available through Kaiser's local charging hood.
Considering that as the charging plume rises, additional building air
becomes entrained in the plume, the partial building evacuation rate
should be considerably greater than that for a local hood. For this
reason, the Inland No. 2 BOPF facility is not considered a candidate
for best secondary emission control.
4.2.4 Building Evacuation
Extension of the canopy hood concept leads to total building
evacuation. In effect, the entire building becomes a hood. Theoretically,
a well-designed building evacuation system should be able to capture
nearly 100 percent of all secondary emissions. There are disadvantages,
however. Exhausting the air at a sufficient rate for building evacuation
requires a system gas flow larger than that described for local hoods.
Consequently, costs are greater. Since fan work is proportional to
the product of pressure drop (Ap) and flow rate, and given the same
type of collector (fabric filter) for both local hooding and building
evacuation, the energy expenditures will be higher for the building
evacuation system.
Particulate emissions from BOPF shops equipped for building
evacuation could also be greater than particulate emissions from shops
equipped with furnace enclosures or hoods. Baghouses tend to produce
relatively constant outlet concentrations over a wide range of inlet
particulate concentrations. In comparing the particulate emissions
from baghouses applied to building evacuation versus furnace enclosures
and hoods, the principal parameter then is flow. The capture of
emissions near the source tends to require less flow than ventilating
a large building. At equal concentrations, the mass emission rate from
a building evacuation baghouse would be greater because of the much
larger exhaust volume. Although outlet concentrations from a baghouse
installed to control particulates from building evacuation should
theoretically be lower than concentrations from a furnace enclosure
4-30
-------
baghouse, there are not enough data to demonstrate a lower concentration
limit for building evacuation baghouses than for furnace enclosures or
local hood baghouses.
There are no total building evacuation systems applied to BOPF
shops in the United States. There are several such systems in use for
other types of steelmaking, particularly electric arc steelmaking and
argon/oxygen decarburizer (ADD) steelmaking. Three of the plants that
use these systems produce alloy and stainless steel.
Babcock and Wilcox in Beaver Falls, Pennsylvania, operates two
plants—Wallace Run and Koppel. The Wallace Run plant has one shop
with two 22.7-Mg (25-ton) electric arc furnaces (EAF's) and another
shop with a 45.5-Mg (50-ton) and a 68.2-Mg (75-ton) EAF. The Koppel
plant has a 45.5-Mg (50-ton), a 68.2-Mg (75-ton), and three 90.9-Mg
(100-ton) EAF's. The design building evacuation rates at Wallace Run
are 109 and 217 acms (230,000 and 460,000 acfm), respectively, for the
s.mall and large shops. Total design evacuation rate for the Koppel
plant is 850 acms (1.8 million acfm).19 The Koppel plant system is
designed to provide one air change every 2.5 minutes. Design gas
temperature for all these systems is about 100° C (212° F).
To achieve satisfactory air movement through the buildings,
ventilation openings (to supply and distribute incoming air) were
added and changed. At some locations, partition walls (curtains) were
installed on building columns to reduce the travel of fume into adjacent
areas. Roof monitors were sealed and duct takeoffs were installed in
the roof above the furnaces.19
In both of the plants, the fume capture systems are connected to
baghouses. Details of the collector design are discussed in a later
section of this chapter.
Crucible Steel at Midland, Pennsylvania, operates an EAF and AOD
facility to produce alloy and stainless steel. There are four EAF's
each with an 81.8-Mg (90-ton) capacity and one AOD vessel with a
90.9-Mg (100-ton) capacity. Duct takeoffs for the evacuation system
are in the roof of the building. The evacuation rate for the whole
building is 850 acms (1.8 million acfm) at a design temperature of
4-31
-------
121° C (250° F).20 The fume collection system for this plant is a
baghouse. Recovered dust contains chrome and nickel because of the
stainless alloying process; the dust is recycled. Additional data on
baghouse design are presented in a later section of this chapter.
4.2.5. Factors Affecting Fume Capture
Several process factors affect the ability of hoods in secondary
emission control systems to capture fumes. One important factor
already mentioned is the type of furnace. The differences between top
and bottom blown furnace operations have been discussed in Chapter 3.
The need to maintain a flow of gas through the bottom blown furnace
tuyeres tends to generate a larger volume of gas and fume to be captured
during hot metal charging. Other important process factors include
furnace additives, scrap types, and furnace operating practices.
The amount of fume generated is affected by additives to the
steel. Additions are made to the furnace or the steel ladle, or both.
Common furnace additions include materials used as fluxing agents such
as dolomite, burnt lime, and fluorspar. Deoxidizing agents such as
ferrosilicon and silicomanganese are also added to the furnace.21
Ladle additions during or after tapping are numerous and include
ferromanganese, chromium, aluminum, phosphorus, sulfur, and molybdenum.
Among the additives of importance from an emissions standpoint are
chromium, molybdenum, and sulfur.21
As was previously described in Section 4.2.2.2, the test series
performed at J&L, Aliquippa, explored the effects of some additives on
roof monitor visible emissions.17 Comparisons of the observed maximum
3-minute opacities were made among groups of furnace cycles (grouped
by additive) for the J&L test series.22 While differences in the
amount of fume generation were expected between cycles with various
types of additives, there were no statistically significant differences
detected in the average maximum 3-minute opacities that were observed
at the roof monitor for the five additives compared to the cycles
without those additives.22
Variation of scrap charge composition can also affect fume capture.
There are a large number of scrap types classified according to size,
4-32
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density, and source of scrap, as shown in Table 4-7.2S Generally, the
use of in-house scrap (which tends to be cleaner) is the preferred
mode of operation.
Scrap contaminated with oil produces large volumes of gas and
fumes during hot metal charging as the molten iron and combustible
material come into contact. Wet scrap can similarly produce increased
emissions when the water flashes to steam on contact with molten
metal. Both oily scrap and wet scrap produce serious in-plant safety
problems, so there is additional incentive to avoid those types of
scrap.
As was discussed in Section 4.2.2.2, the J&L test series included
some test runs with purchased scrap. Therefore, the effects of some
purchased scrap types on roof monitor visible emissions were present
in the data that are analyzed and presented in Table 4-6.
The use of certain operating practices can improve the degree of
fume capture. These have been described for specific plants previously
in Sections 4.2.2.1 and 4.2.2.2. Slow pouring the hot metal from the
ladle to the furnace and minimizing the angle of furnace tilt (perhaps
putting longer pouring spouts on the hot metal ladle) to keep the fume
generation point close to the hood are the most important of these.
4.2.6 Other Control Systems
A literature survey conducted for EPA in 1977 found descriptions
of eight control systems for charging emissions at BOPF's in this
country.24 Seven consisted of auxiliary hoods connected to open hood
primary systems, as outlined in Section 4.2.2. The eighth control
system was the patented Gaw damper.23 This damper is placed at the
inlet (face) of the open hood primary system and is used to reduce the
open area of the hood face during charging and tapping. The opening
is constricted to increase hood face velocity and direct hood suction
t
to the side of the hood nearest the charging or tapping operation.
The relationship among gas properties, fan performance, system resistance,
and total volumetric flow rate is complex. To design such a system
for specified performance during charging and to adjust it after
installation is difficult since emissions from one charge to the next
4-33
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are quite variable. Perhaps for these reasons the industry has not
widely adopted the Gaw damper. Engineers from National Steel, who
studied the device as it applied to a 1-ton pilot furnace, gave it a
favorable report, but anticipated that there might be maintenance
problems at full scale.23 In pilot study, Republic Steel at Gadsden,
Alabama, has retrofitted two furnace hoods with Gaw dampers.25
The same pilot study described charging through a "launder,"
i.e., a refractory-lined chute built through the hood.23 Since the
vessel did not have to be tipped for charging, emissions were collected
by the primary system. This scheme worked well but apparently has not
been commercialized.
4.2.6.1 Foreign Installations. Other BOPF secondary emission
control systems in use outside the United States have performed in a
manner comparable to the system at Kaiser Steel.17 No official visible
emissions observations have been performed on these systems, however.
Specifically, the Oita and Yawata Works of Nippon Steel are examples
of well controlled BOPF facilities in Japan.5 6 The Taranto Works of
Italsider in Taranto, Italy, is also in this category.26 All of these
plants depend on furnace enclosures and local hooding to capture
furnace emissions. Local hooding is also applied to other secondary
emission sources in these plants, i.e., hot metal transfer, hot metal
skimming, ladle deskulling, external desulfurization of hot metal, and
steel transfer for continuous casting.
At least one foreign installation with partial building evacuation
has been observed to control visible emissions from secondary emissions
relatively well. The Chiba Works of Kawasaki Steel has a relatively
new Q-BOP shop. The No. 3 shop has two 230-Mg (250-ton) bottom blown
furnaces. This plant was constructed with furnace enclosures, including
charging hoods inside the enclosures and roof-mounted ESP's to collect
furnace emissions that escape during hot metal charging as shown in
Figure 4-6.17 One precipitator is located above each furnace. The
design gas flow rate for each is 225 acms (477,000 acfm).27 The total
gas flow in the secondary system for the local hoods is 300 acms
(635,400 acfm). This latter capacity is shared with other secondary
4-36
-------
Roof mounted ,'
ESP
Flare stack
for primary system
Secondary
system stack
Figure 4-6. Kawasaki-Chiba Works plant arrangement with partial
building evacuation.
4-37
-------
sources, including raw materials handling, torpedo car desulfurization,
hot metal transfer, and hot metal skimming.
Based on limited observations of roof-mounted ESP performance,
their application to bottom blown furnace shops in combination with
local hooding looks promising for matching the performance of furnace
enclosures alone for top blown furnaces. Application to top blown
furnaces may be considered as well to supplement furnace secondary
emission control systems with relatively low flow rates.
4.3 CONTROL OF SECONDARY EMISSIONS FROM ANCILLARY OPERATIONS (HOT METAL
TRANSFER AND SKIMMING)
Given the trend to enclosed BOPF's, the emissions from charging,
sampling, and tapping are closely associated with the vessel, and
their control is integrated with the design of the enclosure. Charging,
sampling, and tapping do not occur during blowing, so the integration
of these operations with a primary furnace control system is theoreti-
cally feasible. However, the ancillary operations of hot metal transfer
and hot metal skimming take place at various times and distances from
the furnace. The integration of their control with that of the other
operations would be both structurally and operationally awkward.
Therefore, the trend has been to install a separate secondary control
system.
Local hoods are the principal choice for capture of emissions
from hot metal transfer and hot metal skimming. Hoods placed above
the source are more effective than those attempting to capture the hot
emissions with side draft unless side draft exhaust ventilation is
employed in conjunction with a cover over the mixer or ladle.
4.3.1 Kaiser Steel, Fontana, California.7
Kaiser Steel performs hot metal transfer and ladle deslagging
(skimming) at one side of the BOPF shop where there are two stations.
A shed or lean-to is built onto the side of the main building as shown
in Figure 4-7. Torpedo cars are moved into the shed on tracks passing
through the shed. Chain curtains hanging from the top of each entrance
help to restrict the opening size and reduce required draft. The
torpedo car pours hot metal through a slot into a shop ladle sitting
4-38
-------
Exhaust to
baghouse
Figure 4-7. Kaiser Steel hot metal transfer and skimming station.
4-39
-------
on a transfer car below ground level. Upon completion of the hot
I
metal transfer, a ladle transfer car moves under an adjacent hood in
the same station where slag is raked off the metal surface while the
ladle is tilted. Both hoods in the station are evacuated through the
same duct. Draft is apportioned between the two hoods by means of
dampers located at the duct entrance above the station.
Operation of the system in conjunction with the furnace enclosure
hoods is discussed in Section 4.2.1.1. The estimated gas evacuation
rate during hot metal transfer and skimming is about one-third system
capacity or 94 acms (200,000 acfm).8 Tests at Kaiser, Fontana, showed
that the hood system captures virtually all of the particulates from
hot metal transfer and skimming.9 Consequently, there are no visible
emissions from the roof monitor for these Kaiser secondary sources.
4.3.2 U.S. Steel, Fairfield, Alabama28
Hot metal handling operations are performed at two locations in
this plant, at a north and a south hot metal mixer. Molten iron is
brought into the building in torpedo cars and poured into the hot
metal mixers for storage. Hot metal ladles are filled by pouring the
molten iron out of the opposite side of the mixers. Therefore, there
are two transfer points associated with each mixer, a torpedo car
transfer point and a ladle transfer point. Both ladle transfer stations
are partially enclosed in that the ladle is set in a pit and a partial
cover is rolled into place above the ladle as the metal transfer takes
place. Side draft hoods are used at all of the transfer points. The
south mixer is evacuated through a dust control system shared with the
canopy hood over Furnace C (one of three furnace vessels). The gas
flow capacity of the system is about 230 acms at 93° C (490,000 acfm
at 200° F). However, only a portion of this draft is available to the
transfer hoods.
The control device is a six-compartment, pressure-type baghouse
with a gross air-to-cloth ratio of 0.79:1 m/min (2.6:1 ft/min) and a
net air-to-cloth ratio of 0.94:1 m/min (3.1:1 ft/min) with one compart-
ment offline. The bag fabric is nomex and bag cleaning is performed
by a shaker mechanism.
4-40
-------
The north mixer transfer points are controlled by a separate
system with a maximum evacuation rate of 80 acms at 120° C (170,000 acfm
at 250° F). It is a suction-type baghouse with eight compartments.
The gross air-to-cloth ratio is 0.94:1 m/min (3.1:1 ft/min). Bag
cleaning is accomplished by a shaker mechanism and the fabric type is
dacron. No visible emissions evaluation was attempted on the transfer
points at the hot metal mixers. However, the fume capture was noted
to be very effective. Visible emissions observations were performed
on the baghouse discharge points. The data are presented and discussed
in Section 4.5.1.2.
4.4 CONTROL OF PRIMARY EMISSIONS1
Primary emissions refer to those emissions leaving the mouth of
the furnace vessel during the oxygen blow that are captured by the
primary hood. The types of control equipment used in the United
States to capture and collect particulate emissions from the vessel
mouth are open hood systems with scrubbers or ESP's and closed hood
systems used in conjunction with scrubbers. Selection of a control
device for the vessel waste gases is interrelated with the selection
of hood design for capturing the gases.
Carbon monoxide is emitted from the vessel mouth during the
oxygen blowing phase of the cycle. The gas temperature is sufficiently
hot to promote combustion of CO if air is permitted to mix with the
waste gas. A design decision must be made to determine how much air,
if any, is allowed to mix with the gas, so that hood cooling capacity
can be matched to the system needs. Obviously, some air must be
admitted to obtain the capture velocity that is required to contain
fume emissions within the hood.
Many of the early BOPF furnace installations used precipitators
for controlling particulate emissions. Because of the potential for
igniting CO/air mixtures by precipitator sparking, it was necessary to.
use an open hood to admit large quantities of excess combustion air at
the hood and to facilitate the complete combustion of CO. This design
decision led to larger gas volumes to be treated for control of
particulate emissions than is necessary for closed hood furnaces.
4-41
-------
More recent plant designs have incorporated limited or partial
combustion of CO (closed hood design), thereby reducing the heat
generated in the hood and the gas volume to be treated. Careful
control of the amount of air admitted to the hood allows 10 to 50 percent
combustion of CO according to the designer's preference. Gas cleaning
over recent years has involved exclusively scrubbers to reduce explosion
hazards. The advantages of partial combustion are reduced energy
consumption for gas cleaning, as compared to a scrubber on a full
combustion hood, and the potential for recovering CO as a low-grade
fuel source—7.5 million J/scm (200 BTU/scf). Though many plants in
the United States are now operating with partial combustion hoods,
none of the plants are recovering the CO and the gas is flared before
discharging it to the atmosphere.
Under the present new source performance standard (NSPS) for BOPF
primary emissions, participate discharges are limited to 50 mg/dscm
(0.022 gr/dscf). Because of the large differences in waste gas flows
that are produced by the various open and closed hood designs, the
total particulate discharges vary significantly. For instance, with a
typical open hood, ESP gas flow rate of 47 dscm/min/Mg (1,500 dscfm/ton)
of steel, 2.35 g/min (0.0047 Ib/min) of particulate may be discharged
per megagram (ton) of steel.29 For a typical closed hood scrubber flow
rate of 9.1 dscm/min/Mg (290 dscfm/ton) of steel for a top blown
furnace, only 0.47 g/min (0.00094 Ib/min) of particulate may be dis-
charged per megagram (ton) of steel.29 Therefore, from the standpoint
of total air pollutant emissions, the closed hood scrubber control
technology is more effective. Data presented later in this section
support this point.
4.4.1 Closed Hood Scrubber Control Technology
Figure 4-8 shows a typical configuration for a scrubber installed
on a BOPF with a closed hood. In the closed system, the hood usually
fits close to the furnace mouth to restrict the inflow of combustion
air. Since a completely closed hood would restrict vessel tilting,
the hood skirt must be movable. Otherwise, the flow of combustion air
must be restricted by some other means than a close fitting hood.
4-42
-------
GAS STORAGE HOLDER
Flare
BY-PASS STACK
sr
sSPRAY QUENCH WATER
WATER COOLED
OXYGEN LANCE
Figure 4-8. Typical scrubber configuration for closed hood BOPF.1
4-43
-------
There is also a need to limit the amount of air infiltration
downstream of the hood. Normal points of leakage in an open hood
system such as the lance port and flux chutes must be sealed and
purged of nitrogen before use.
Initial cooling of the gas leaving the furnace is carried out via
a water-cooled hood: Cooling is continued by the use of a spark box
or quencher, in which grit and coarse particles resulting from refrac-
tory and chunks of slag or metal are separated from the gas stream.
Quenchers reduce the gas temperature to less than 93° C (200° F) and
saturate the gas with water vapors.
From the quencher, the waste flows to a high-energy scrubbing
device where the removal of fine particles occurs. The most common
scrubber type is a venturi with an adjustable throat. The venturi is
opened or closed to increase or decrease gas velocity, i.e., pressure
drop through the throat.
An integral part of the scrubbing unit is a moisture-separating
device to knock out drops of water carried out of the throat. The
device may be a series of baffles or a centrifugal chamber in which
the gas rotates, causing the drops to impinge on the chamber walls.
Also, an after-cooling chamber is sometimes used in which the used
cooling water is sprayed to further reduce the gas temperature. At
cooler temperatures, moisture condenses from the gas, thus reducing
the volume of gas to be handled by the fan. The system may have
multiple venturi throats, but draft is provided only by a single fan.
The gas cleaning facilities are not shared between adjacent furnace
vessels; each furnace has an independent gas cleaning system.' At
present all closed hood systems in the United States flare the carbon-
monoxide-rich waste gas stream generated during oxygen blowing.
Alternatively, the gas may be recovered in a gas holding device and
used as fuel gas for other plant operations.
Draft control for the closed hood systems is critical to the
proper control of the combustion reaction. The systems typically
include hood pressure sensors to alter draft via the adjustable venturi
4-44
-------
throat. Because the hood draft is so carefully limited to near
atmospheric pressure, there is a tendency for these primary systems to
emit hood puffs.
A recycle water system is the typical way in which scrubber
wastewater is handled. This system incorporates a preclassifier, a
thickener(s), and a thickener underflow dewatering device. Schemati-
cally, the "clean" water overflow from the thickener is pumped to the
venturi throat. The use of high pressure spray nozzles dictates the
need for a relatively clean water supply at this point. The water and
solids are separated from the gas stream in the moisture separator.
The water out of the separator flows to a recycle or surge tank.
From the tank, part of this water is pumped to the quencher and part
to the thickener(s). The used quench water, containing coarse particles,
flows through the preclassifier before returning to the thickener.
There are variations on this flow arrangement as to location of the
preclassifier and the recycle tank, but the water supply to the venturi
must be the cleanest water available in the system.
Underflow from the thickener(s) is pumped to a rotary drum vacuum
filter or centrifuge for dewatering. The cake produced is usually
trucked to a landfill in an open or tank truck. If the dewatering
operation is not sufficiently effective, the tank truck would be the
preferred method of transport.
Improved settling and sludge dewatering may be achieved by the
addition of polyelectrolytes. Slowdown from the recycle system may
require pH adjustment and further removal of suspended solids to meet
effluent guideline limitations. Chemical additions are also made to
the recycled water to control scaling and corrosion.
4.4.1.1 Control System Performance—Closed Hood, Top Blown. The
data base for this subcategory is composed of tests performed in
developing the current NSPS as far back as 1971 and more recent com-
pliance tests in 1978. The particulate measurements were made in
accordance with EPA Reference Method 5. All of these data were obtained
by sampling over the period beginning with the oxygen blow (or scrap
preheat) and ending just prior to tapping. These data are presented
4-45
-------
in Tables 4-8 and 4-9. For the purposes of the analysis of data in
Table 4-8, all the participate emissions measured were assumed to have
been produced during the oxygen blow only.
Since the length of oxygen blow can have a significant effect on
the total particulate emissions, the data have been normalized to unit
time of oxygen blow. The mean emission rate for top blown furnaces
listed in the table is 0.443 g/Mg (0.886 x 10"3 Ib/ton) of steel
produced per minute of oxygen blow/cycle.
Table 4-9 presents the test results based on outlet concentration
as opposed to a process weight basis. The concentration data for the
top blown furnaces were obtained by sampling during both blowing and
nonblowing periods of the furnace cycle. These concentrations were
adjusted by calculations based on the assumption that all particulate
mass measured was emitted during oxygen blowing only. This assumption
tends to overestimate the concentration that would be measured during
oxygen blowing only. The 3-test averages for both Kaiser Steel furnaces
were below the present NSPS of 0.05 g/dscm (0.022 gr/dscf) even with
the adjustment. The three-test average for Armco Steel on an adjusted
basis is 0.055 g/dscm (0.024 gr/dscf), which is above the present NSPS.
As discussed in Section 4.2.1.1, 95-percent prediction limits were
calculated for these data. The 95-percent prediction level for primary
emissions from the closed hood collection devices was 0.066 g/dscm
(0.029 gr/dscf).
Other closed hood, top blown furnace performance data tending to
support the principal data base are shown in Tables 4-10 and 4-11.
The test reports in which these data were found were subjected to an
internal review by EPA. The review criteria included a data reduction
check, availability of all field and analytical data, documentation of
process and control device operating parameters, and the presence of
an on-site regulatory observer or authorized representative. The data
in Tables 4-10 and 4-11 were not put into the principal data base
because they failed to meet one or more of the above criteria.
4-4-1-2 Control System Performance—Closed Hood. Bottom Blown.
The data base for this subcategory consists of tests performed to
determine compliance in 1978. These measurements were also made in
4-46
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TABLE 4-11. SUPPLEMENTARY PRIMARY EMISSION DATA-CLOSED HOOD34
35 36 37 38 39
Emissions
Plant
U.S. Steel3
Lor a in
U.S. Steel d
Gary
East
West
Date
11/16/71
11/17/71
11/18/71
11/26/72
11/27/72
11/27/72
4/17/75
4/21/75
4/24/75
4/22/75
4/23/75
4/23/75
Blow time
(min)
97.20
102.20
109.10.
102.80°
102.80°
102.80°
78.00
77.00
73.00
67.00
68.00
72.00
Number
of
cycles
6
6
6
6
6
6
4
4
4
4
4
4
Process weight
basis, g/Mg
steel produced
(Ib/ton)
0.97 (0.0020)
3.93 (0.0079)
1.73 (0.0035)
1.04 (0.0021)
0.71 (0.0014)
2.40 (0.0048)
13.77® (0.0276)
14.52s, (0.0291)
10.496 (0.0210)
5.42f (0.0109)
2.2lf (0.0044)
5.96e (0.0119)
Outlet concentration
(g/dscro [gr/dscf])
0.007 (0.003)c
0.030 (0.013)c
0.011 (0.005)c
0.007 (0.003)c
0.005 (0.002)
0.018 (0.008)c
0.021 (0.009)C
0.023 (0.010)C
o.oie (o.ooer
0.011 (0.005)C
0.005 (0.002)c
0.011 (0.005)c
— Scrubber
pressure
drop,
cm H20
(in H20)
>178 (>70)
>178 (>70)
>178 (>70)
160 (63)
158 (62)
173 (68)
160 (63)
158 (62)
163 (64)
Republic Steel d
U.S. Steel d
Furnace U
Furnace C
8/4/77
8/6/77
1V6/74
11/7/74
11/7/74
9/8/78
9/9/78
9/9/78
48.00
48.00
75.00
64.00
59.00
67.25
55.20
70.67
4
4
5
.. 4
4
5
4
5
6.67? (0.0134)
6.91e (0.0139)
4.76? (0.0095)
5.57® (0.0112)
5.42e (0.0109)
7.79 (0.0156)
10.68 (0.0214)
7.91 (0.0159)
0.053 (0.023)
0.050 (0.022)
0.030 (0.013)
0.032 (0.014)
0.034 (0.015)
0.055 (0.024)
0.059 (0.026)
0.050 (0.022)
203 (80)£
203 (80) f
180 (71)
175 (69)
173 (68)
170 (67)
160 "(63)
178 (70)
Average oxygen blow based on earlier tests.
Adjusted to oxygen blow time only.
eBased on 200 tons/heat, nominal production.
Design value, Reference 10.
4-50
-------
accordance with EPA Reference Method 5. All of these data were obtained
by sampling during the primary oxygen blow only. The data are pre-
sented in Tables 4-8 and 4-9. The data in Table 4-8 have also been
normalized to unit time of oxygen blow. The mean emission rate for
the bottom blown furnaces listed in the table is 0.577 g/Mg
(1.153 x 10 Ib/ton) of steel produced per minute of oxygen blow/
cycle. Both the process weight column and normalized process weight
column data have been adjusted to reflect total emissions during the
entire oxygen blowing period. The adjustment was made by multiplying
emissions measured during the primary oxygen blow by the factor (total
blow time/primary blow time).
Table 4-9 shows the measured emission concentration for bottom
blown furnaces. These concentrations were not adjusted because the
measurements were made during oxygen blow only. The three-test
averages for both furnaces are less than or equal to the present NSPS.
Other closed hood, bottom blown furnace performance data tending
to support the principal data base are shown in Tables 4-10 and 4-11.
These data were not included in the principal data base after EPA
review due to test and test report deficiencies as discussed in
Section 4.4.1.1.
4.4.2 Open Hood Scrubber and ESP Control Technology
An open hood scrubber control system is basically the same as the
closed hood system. The hood skirt is in a fixed position instead of
movable and no precautions for leakage into the system are necessary.
Control systems may be shared between furnaces and multiple fans
operating in a parallel flow arrangement can be used if desired.
When a precipitator is used (Figure 4-9), gas cooling downstream
from the hood skirt is continued by the use of water sprays located in
the upper part of the hood. These sprays are generally controlled by
time and temperature to turn on and off at various points in the
operating cycle. The intent is to limit the gas temperature reaching
the precipitator and to moisture condition the gases for better
precipitation. The maximum temperature of gases entering the precipi-
tator is usually kept under 343° C (650° F). Flaring of carbon-
4-51
-------
O-
w
LU
T3
O
O
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09
Q.
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.
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09
4-52
-------
monoxide-rich gas practiced in closed hood systems is not necessary in
open hood systems since the CO is burned in the open hood.
Because the gas temperature is relatively low during hot metal
charging and the early minutes of a blow, some plants use steam injec-
tion either at the hood sprays or spark box location to achieve the
desired conditioning of gases. Water sprays do not evaporate suffici-
ently under the low temperature conditions, and puffs of iron oxide
fume are typically observed coming from the stack during this period.
Steam injection, both at the beginning and end of the blow, can reduce
these puffing emissions.
Downstream of the spark box, the gases are carried to an inlet
plenum that distributes the gas to multichambered precipitators. On
the outlet side of the precipitator there is usually a manifold arrange-
ment that distributes the .gases among multiple fans. The precipitators
may or may not have spare capacity in terms of an extra chamber or
extra collection field in the direction of gas flow. It is common
that at least one spare fan is available.
In a two-vessel shop, ducts from each vessel join into a common
flue upstream of the precipitator inlet plenum. Isolation of each
vessel from the precipitator is usually managed by installing guillotine
dampers upstream of the junction point. When a vessel is being relined,
the fans are then drafting only the operating vessel; otherwise, much
draft is wasted on the nonoperating vessel.
Draft and temperature monitoring are normally done at several
locations in the system. Sprays are used to control precipitator
temperatures; so the spray must be temperature controlled to a certain
extent.
At several locations in the system, suction pressure is sensed
and used to control the opening and closing of flow control (louver)
dampers. For certain phases of the operating cycle, there are specific
draft set points that control the evacuation rate of the system. Full
system draft is typically used during hot metal charging and the
oxygen blow. There may be little or no draft during the remainder of
the operating cycle. Draft is limited when hot gases are not available
to avoid too much precipitator cooling. The continual expansion and
4-53
-------
contraction of hood, ducting, and precipitator is structurally
detrimental, resulting in leaks. Corrosion may also be a problem for
a precipitator if cold air is alternated with hot, moist gas.
Dust removal from the precipitator hopper is most often done by
screw conveyors to some common discharge point. Dust removal from the
precipitator site is usually by truck to a landfill site.
Overflow water from the spray chamber or spark box flows or is
pumped to a settling tank of some sort and the settled solids dragged
out by conveyor. If not recycled, plants generally combine the overflow
or the blowdown with process water from other plant areas for clarifi-
cation prior to discharge.
4.4.2.1 Performance Data—Open Hood Control Systems. Performance
data from open hood control systems are available from the period
between 1975 and 1979. The data were obtained primarily during
compliance tests and the data show compliance with the present NSPS.
The data are presented in Table 4-12. All the data were taken during
oxygen blowing only. None of the three-run averages exceeded 0.050 g/dscm
(0.022 gr/dscf). As discussed in Section 4.2.1.1, 95-percent prediction
limits were calculated for these data. The 95-percent prediction level
for primary emissions from the open hood furnaces was 0.039 g/dscm
(0.017 gr/dscf).
It is apparent that some of these open hood control systems
complying with the present NSPS have not achieved emission levels as
low as those achieved by closed hood control systems. Use of additional
precipitator collection surface area or higher scrubber pressure drops
in combination with reduced gas flow rates might allow open hood
control systems to achieve similar low emission rates on a more
consistent basis.
4.5 PARTICULATE MATTER CONTROL DEVICES
The dominant feature of the particles arising in the several
steps of the basic oxygen process is their size. The size distributions
for Q-BOP charging emissions was presented in Table 3-8. The finest
particles are believed to be formed by condensation, the quenching of
vaporized iron when it contacts combustion air at the mouth of the
4-54
-------
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vessel. Mixed with these fine particles of condensed iron oxide in
the secondary emissions are graphite or kish that are formed from
carbon present in molten iron. If not collected, these emissions,
particularly the iron fume, are carried by natural convection up to
and out of the roof monitor. If these rising velocities are in the
range 0.3 to 3.0 m/s« (1 to 10 ft/s), and the particles have specific
gravities near five, then sizes up to 200 urn could be lifted.46 When
the plume mixes with cooler air and slows somewhat before accelerating
through the constriction imposed by the roof monitor, there may be an
opportunity for particles larger than perhaps 40 urn to "rain out," but
the smaller fume is entrained.
Devices suitable for the collection of such fine solids with a
98-percent or higher efficiency are the fabric filter, the high perform-
ance wet scrubber, and the ESP. Precipitators and wet scrubbers are
in widest use for primary emissions. Fabric filters are in widest use
of the three types in BOPF secondary emission control." In fact,
these three devices can be designed with such efficiencies that the
limitation in overall performance on secondary emissions traces to the
hood rather than the control device.
4.5.1 The Fabric Filter
This control device has been amply described in previous EPA
documents47 ** and vendors' literature. Only a brief summary is
appropriate here. The fume, after capture at the hood and transport
through a duct, comes to the fabric filter. The interstices between
the fibers in a woven or felted bag are partially blocked by particles
not removed during the last cleaning operation, and ordinarily a
coating or cake of particles is deposited on the fabric. The gas can
penetrate the cake and the underlying fabric, but few particles can
pass through an undamaged fabric with a cake deposited on it. The
collection efficiency can be very high (> 99 percent) if damaged
fabric is promptly replaced.
The common geometry is multiple cylindrical fabric bags disposed
in several independent compartments to permit cleaning and maintenance.
As the dusty air is filtered, the cake builds up and the pressure drop
4-56
-------
increases. On a predetermined schedule, or when the pressure drop
across a compartment has risen to a predetermined level, the bags in
that compartment are cleaned mechanically or pneumatically, although
never to their original condition. The solids thus collected drop
into a hopper. If the solids are abrasive or if cleaning is too
frequent or vigorous, bag life is shortened; frequent bag failure is
expensive and reduces the average collection efficiency. For similar
reasons, the dust should not approach a freshly cleaned bag too fast;
this maximum face velocity or air-to-cloth ratio for iron oxide is
said to be about 0.61 m3/min/m2 (2 fts/min/ft2).47 Current bag materials
and cleaning methods may have modified this figure somewhat. Taken
together with the desired exhaust volume and the specified excess
capacity, this rule of thumb dictates the total fabric area and the
cost of the control unit.
Depending on the gas temperatures involved, polyester, aramide,
or fiberglass fabrics may be used for the secondary emissions. If
certain operations should happen to be near the filter unit, it is
conceivable that hot particles may be cast onto the fabric. Since the
smaller particles cool more rapidly, it is necessary to provide a
spark box to deflect the larger ones.
Dust-handling facilities must be provided. Ideally, the collected
solids are recycled to the process via the sinter plant. However, if
the charge is in part galvanized or terne scrap, the charging emissions
may contribute unacceptable levels of zinc or lead to the filter
catch. Since these ingredients are detrimental to blast furnace
refractory linings, such solids (in this country) are commonly
landfilled.49
Fabric filters are in use for several steel process gas cleaning
applications. The facility at Kaiser Steel for secondary emission
control treats waste gases from charging, tapping, puffing (during
oxygen blow), furnace deslagging, hot metal transfer, and hot metal
skimming. Fabric filters are used to collect hot metal transfer
emissions at numerous plants in the United States. Fabric filters are
also applied to many U.S. EAF's. In addition to the U.S. installations,
4-57
-------
there are many secondary emission control systems with fabric filter
collectors in use in BOPF shops outside the United States, particularly
in Japan but also in several European plants. Fabric filters are not
normally used for the control of primary emissions from BOPF shops
4'5-1-1 .Romance Data-Mass Emission. Performance test data
are available from fabric finer controlled systems applied to both
BOPF secondary sources and EAF's. Because the particulate characteris-
tics are similar, data on the performance of EAF enclosures are applicable
to BOPF secondary emission control baghouses. Figure 4-10 presents
the performance data graphically. Each point represents an individual
test run. As is evident, ail of the outlet concentrations are below
22.8 mg/dscm (0.010 gr/dscf).
4'5-1-2 Perfo™a"ce Data-Visible Emission, visible emissions
data for discharged gases leaving BOPF secondary emission baghouses
have been obtained for three sources. Visible emissions were read
during the performance testing of the Wheeling-Pittsburgh Steel hot
metal transfer baghouse in Mingo Junction, Ohio." S1milar data were
obtained from two baghouses at U.S. Steel Q-BOPF in Fairfield, Alabama ™
One baghouse serves the canopy hood above Furnace C for collecting
fugitive hot metal charging emissions and the south hot metal mixer
and transfer station. The other baghouse serves the north hot metal
mixer and transfer station.
I
The test method used was EPA Reference Method 9. The data were
analyzed, however, by computing 3-minute averages instead of 6-minute
averages. These data are summarized in Tables 4-13, 4-14, and 4-15
As is evident, none of the 3-minutes averages equalled or'exceeded 5
percent opacity.
4.5.2 Wet Scrubbers
This class of particulate control devices has been amply
described." ™ Scrubbers are most frequently used for primary emission
control. Few scrubbers are currently used for secondary emission
control.3 17 is
Briefly, the operating principle of the venturi scrubber is as
follows: The dusty gas is forced into a constriction, where it attains
a velocity in the range 45 to 150 m/s (150 to 500 ft/s). At about
4-58
-------
8
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-------
TABLE 4-13.
WHEELING-PITTSBURGH STEEL, MINGO JUNCTION, OHIO
HMT BAGHOUSE VISIBLE EMISSION DATA52
Time
Date start
7/29/80 1400
1511
1600
7/30/80 1100
1140
1220
1315
1400
7/31/80 1100
1138
1215
1250
1340
1425
Stop
1505
1530
1614
1120
1204
1249
1335
1426
1123
1204
1244
1310
1356
1438
Number
of 3-minute
averages
18
1
2
1
6
5
6
1
8
10
7
9
6
2
8
1
10
7
5
4
Opacity
(percent)
0.0
0.4
0.8
4.2
0.0
0.0
0.0
0.4
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.4
0.0
0.0
0.0
0.0
4-60
-------
TABLE 4-14. UNITED STATES STEEL, FAIRFIELD, ALABAMA,
CANOPY HOOD AND SOUTH MIXER BAGHOUSE57
Date
Observer: Howl son
5/11/81
5/12/81
5/13/81
5/14/81
5/15/81
Observer: Clark
5/11/81
5/12/81
5/13/81
Time
Start
1434
1542
0937
1200
1310
1420
0930
1200
1310
1420
1530
1345
1455
1605
1433
1542
0937
1200
1310
Stop
1533
1635
1000
1259
1409
1519
1029
1259
1409
1519
1629
1444
1554
1634
1532
1632
1000
1259
1409
Number
of 3-minute
averages
20
18
8
10
3
2
2
2
1
9
6
3
1
1
19
1
20
16
2
2
16
2
2
19
1
20
19
1
20
10
20
18
7
14
5
1
14
2
2
1
1
Opacity
(percent)
0.0
0.0
0.0
0.0
0.4
1.3
1.7
2.1
2.5
0.0
0.4
1.3
2.1
4.2
0.0
2.5
0.0
0.0
0.4
1.3
0.0
0.4
0.8
0.0
0.4
0.0
0.0
0.8
0.0
0.0
0.0
0.0
0.0
0.0
0.8
1.3
0.0
0.4
0.8
3.3
5.0
4-61
(continued)
-------
TABLE 4-14 (continued)
Time
Date
Start
Stop
Number
of 3-minute
averages
Opacity
(percent)
5/13/81
5/14/81
5/15/81
1421
1530
0930
1200
1310
1420
1530
1345
1455
1605
1520
1617
1029
1259
1409
1519
1629
1444
1554
1634
19
1
16
20
18
1
1
17
3
30
20
20
20
10
0.0
2.5
0.0
0.0
0.0
1.3
1.7
0.0
0.4
0.0
0.0
0.0
0.0
0.0
4-62
-------
TABLE 4-15. UNITED STATES STEEL, FAIRFIELD, ALABAMA,
NORTH MIXER BAGHOUSE57
Date-
Observer: Howison
5/12/81
5/13/81
5/14/81
5/15/81
Observer: Clark
5/12/81
5/13/81
5/14/81
5/15/81
Time
Start
1115
0930
1040
1045
0930
1115
0930
1039
1045
0930
1040
Stop
1156
1029
1139
1144
1029
1156
1029
1138
1144
1029
1139
Number
of 3-minute
averages
11
1
2
20
20
20
20
10
1
1
1
1
20
20
20
20
20
Opacity
(percent)
0.0
0.8
0 4
\J • ~
0.0
0 0
\J • \J
0.0
0.0
0.0
1.7
2.5
4.2
0 4
\J * T^
0.0
0.0
0 0
w » W
0.0
0.0
4-63
-------
this point, the dusty gas encounters a sheet or spray of liquid
(ordinarily recirculatecl water) having a relatively low velocity. The
interaction creates many small droplets that rapidly attain the velocity
of the gas. While the droplets are accelerating, the air must pass
around each droplet and the heavier particles tend to impact on the
droplets in the process . More water and a higher (initial) relative
velocity permit the collection of finer particles.
The pressure drop across the device for secondary emssions is 80
to 120 cm (30 to 50 in) of water and 153 cm (60 in) or more of water
for primary systems, and the fan work is accordingly high. In fact,
the energy consumption of the venturi scrubber is the highest of the
three high performance control units described in this section.
Downstream of the venturi proper, a cyclone separates the dirty
water droplets from the gas. The resulting slurry of particles in
water is conveyed to a settling pond or a thickener, from which a
relatively clean overflow is recirculated. Makeup water is required
because the dusty gas is hot and must be cooled by evaporation of a
direct spray of water. The underflow from a thickener may be filtered
and the wet cake recycled under certain circumstances, as described in
Section 4.4.1.
Performance of scrubbers applied to primary emission control is
discussed in Sections 4.4.1 and 4.4.2. Performance data are displayed
in Tables 4-8 through 4-12.
4.5.3 The Electrostatic Precipitator
This control device has also been amply described.47 59 When a
static potential of several thousand volts is maintained between a
metal plate and a wire parallel to it, gas moving through the space
between the plate and the wire will be ionized (corona discharge).
The resulting ions and electrons become attached to dust particles in
the gas, usually imparting a net charge. The particles thus charged
experience a coulombic attraction toward the plate or grounded electrode.
The larger particles will reach the plate and be removed from the gas
before it leaves the apparatus. A higher potential (voltage) (within
limits) or more residence time will cause the collection of finer
particles.
4-64
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The dust cake that builds up on the plates may fall off by its
own weight, or it may be dislodged by mechanical impact on the plate
or by washing. Dry dust can be handled as in the fabric filter case,
and the slurry from a wet ESP is comparable to that from a wet scrubber.
Precipitators for large-scale, continuous applications are normally
compartmentalized. This requires independent power supplies but
permits some maintenance without shutdown.
A limiting voltage has been referred to above. When the voltage
is raised to a certain level that depends on the gas--its temperature
and humidity--and on the geometry, character, and thickness of the
cake, an unstable arc replaces the stable corona discharge. The arc
is of no use to the process and may damage the power supplies if
continued. Therefore, progressively better performance is achieved as
the potential is raised, until an arc is struck. In modern ESP's the
power supply automatically reduces voltage when arcing occurs; the
voltage is brought back up until another arc occurs, and so on. A
fortunate consequence of this equipment feature is the ability of the
system to track the continually changing composition and temperature
of the primary or secondary BOPF emissions.
Because the ionizing behavior of the gas and the character of the
cake depend on gas temperature and composition, it is sometimes desirable
to condition the gas. This may be as simple as adding moisture, but
in other industries it has been found feasible to inject substances
such as ammonia, ozone, or sulfur trioxide. For primary BOPF applica-
tions, moisture (as water or steam) is essential to good performance.
Steam conditioning is important for good performance for secondary
emission control, as described in Section 4.2.2.2.
The distinctive feature of the ESP in the steel industry is its
low power consumption--the lowest of the three devices considered
here. Secondary emission collection by ESP's in the United States is
the result of exhausting the secondary gas stream through a primary
system or conversion of ESP's once used for primary emissions to
secondary system applications. No new ESP's have been constructed
specifically for BOPF secondary emission control. Performance data
for ESP's applied to BOPF's are presented in Section 4.4.2, Table 4-11.
4-65
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I
Previous mention was made in this chapter of steel plants outside
the United States having constructed roof-mounted ESP's specifically
for secondary emission control. These BOPF roof installations are
primarily supplements to local hoods connected to fabric filters. In
the case of the Kawasaki Steel, Chiba Works Q-BOPF, the roof-mounted
ESP is an effective addition to control the difficult fugitive emissions
generated by bottom blowing when the furnace is turned down.17 The
design inlet concentration for this plant is 0.4 g/scm (0.175 gr/scf)
and the corresponding outlet is 0.03 g/scm (0.013 gr/scf).60 Actual
measurements have shown an inlet maximum of 1.09 g/scm (0.48 gr/scf)
and a maximum outlet of 0.038 g/scm (0.017 gr/scf). In two other
installations, outlet concentrations as low as 0.02 g/scm (0.0087 gr/
scf) have been measured. Additional collector surface area could
provide lower outlet concentrations, but increased collector size and
weight would result.
4.6 REFERENCES
1. Coy, D. W., et al. Pollution Effects of Abnormal Operations in
Iron and Steel Making—Volume VI. Basic Oxygen Process, Manual
of Practice. U.S. Environmental Protection Agency. Research
Triangle Park, NC. EPA-600/2-78-118f. June 1978.
2. Drabkin, M., and R. Helfand. A Review of Standards of Performance
for New Stationary Sources—Iron and Steel Plants/Basic Oxygen
Furnaces. U.S. Environmental Protection Agency. Research Triangle
Park, NC. EPA-450/3-78-116. November 1978.
3. Williams, A. E., and K. W. Hazard. The Engineering and Installation
of Two 225-Ton Q-BOP Vessels in an Open-Hearth Shop. Iron and
Steel Engineer. 55(11):33. November 1978.
4. Nicola, A. G. Fugitive Emission Control in the Steel Industry.
Iron and Steel Engineer. 53(7):25. July 1976.
5. Trip Report. Nippon Steel Corporation, Oita Works. Research
Triangle Institute. September 19, 1979.
6. Trip Report. Nippon Steel Corporation, Yawata Works. Research
Triangle Institute. September 20, 1979.
7. Trip Report. Kaiser Steel, Fontana, California.
Institute. December 9, 1981.
Research Triangle
4-66
-------
8. Letter and attachments from Martzloff, J. A., Kaiser Steel
Corporation, to Goldman, L. J., Research Triangle Institute.
December 13, 1979. Response to BOPF questionnaire.
9. Clayton Environmental Consultants. Steel Processing Fugitive
Emissions -Emission Test Report, Kaiser Steel Corporation,
Fontana, California. U.S. Environmental Protection Agency.
Research Triangle Park, NC. EMB Report 80-BOF-3. August 1980.
10. GCA Corporation. Assessment of Air Emissions From Steel Operations,
Republic Steel Corporation, Chicago District Q-BOP Shop Visible
Emissions and Process Evaluation. U.S. Environmental Protection
Agency. Washington, DC. Contract No. 68-01-4143, Task No. 58
Report. January 1980.
11. Clayton Environmental Consultants. Steel Processing Fugitive
Emissions -Emission Test Report, Republic Steel Company, South
Chicago, Illinois. U.S. Environmental Protection Agency. Research
Triangle Park, NC. EMB Report 80-BOF-7. September 1980.
12. Trip Report. Bethlehem Steel, Bethlehem, Pennsylvania. Research
Triangle Institute. May 21, 1980.
13. Letter and attachments from Ricketts, A. T., Bethlehem Steel
Corporation, to McGrogan, J. E., Pennsylvania Department of
Environmental Resources. July 14, 1977. Test report on Bethlehem,
Pennsylvania, BOPF shop.
14. Clayton Environmental Consultants. Steel Processing Fugitive
Emissions - Emission Test Report, Bethlehem Steel Corporation,
Bethlehem, Pennsylvania. U.S. Environmental Protection Agency.
Research Triangle Park, NC. EMB Report 80-BOF-9. October 1980.
15. Trip Report. Jones & Laughlin Steel, Aliquippa, Pennsylvania.
Research Triangle Institute. April 9, 1981.
16. JACA Corporation, Fort Washington, Pennsylvania. Inspection
Report. J&L Aliquippa Works. BOF Shop Roof Monitor Emissions.
Volume I. Public Information. Final Report EPA Contract 68-01-
4135, Task 53. June 1981.
17. Coy, D. W., and R. Jablin. Review of Foreign Air Pollution
Control Technology for BOF Fugitive Emissions. In: First Symposium
on Iron and Steel Pollution Abatement Technology, Ayer, F. A.
(ed.). Research Triangle Park, NC, U.S. Environmental Protection
Agency. EPA-600/9-80-012. February 1980. p. 233-251.
18. Letter with attachments from Lang, D. C., Inland Steel Company,
to Goldman, L. J., Research Triangle Institute. May 12, 1980.
Response to BOPF questionnaire.
4-67
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19. Trip Report. Babcock and Wilcox, Beaver Falls, Pennsylvania
Research Triangle Institute. June 29, 1977.
Trip Report. Crucible, Inc., Midland, Pennsylvania. Research
Triangle Institute. August 4, 1977.
Memorandum with attachments from Coy, D. W., Research Triangle
Institute to MacDowell, W., U.S. Environmental Protection Agency,
February 12, 1981. Subject: Additives Used In Steelmaking.
Memorandum with attachments from Coy, D. W., Research Triangle
Institute, to Copeland, J. 0., U.S. Environmental Protection
Agency, December 1981. Subject: Statistical Comparisons of
Additives Effects on Roof Monitor Opacities - J&L Steel, Aliquippa
Pennsylvania. H HH '
23. Caine, K. E. Jr. Development of Technology for Controlling BOP
Charging Emissions. U.S. Environmental Protection Agency
Research Triangle Park, NC. EPA-600/2-77-218. October 1977
20.
21.
22.
24.
25.
26.
27.
28.
29.
30.
31.
Gaw, R. C. Containment of Dust and Fumes from a Metallurgical
Vessel. U.S. 3,854,709. December 17, 1974.
GCA Corporation. Assessment of Air Emissions From Steel Plant
Operations, Republic Steel Corporation, Gadsden, Alabama. U S
Environmental Protection Agency. Washington, DC. Contract No.
68-01-4143, Task Order 58 Report. March 1980.
Trip Report. Italsider Steel Company, Taranto Works. Research
Triangle Institute. March 26, 1979.
Trip Report. Kawasaki Steel Corporation, Chiba Works.
Triangle Institute. September 25, 1979.
Research
Trip Report. U.S. Steel, Fairfield, Alabama.
Institute. January 19, 1982.
Research Triangle
PEDCo Environmental, Inc., Cincinnati, Ohio. Estimated Costs
Associated with the Proposed Revision of New Source Performance
Standards for Basic Oxygen Furnaces. U.S. Environmental Protection
Agency. Research Triangle Park, NC. Contract No. 68-02-3554
Work Assignment No. 5. July 1981. '
Engineering Science. Report on Source Tests, Visible Emissions
and Plant Observations. Kaiser Steel Corporation, Fontana, CA.
™ ;, , ronmenta1 Protection Agency, Region IX. Contract No.
68-01-4146, Task Order 50/TSA 2. February 1979.
Midwest Research Institute. Source Testing—EPA Task No 2
ARMCO Steel Corporation, Middletown, Ohio. EPA Contract No
69-02-0223 (MRI Project No. 3585-C). February 7 1972
4-68
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32. CH2M Hill. Participate Emission Measurement on Q-BOP "C" at
United States Steel Corporation, Fairfield, Alabama. MG63302.80.
November 1978.
33. CH2M Hill. Particulate Emission Measurement on Q-BOP "X" at
United States Steel Corporation, Fairfield, Alabama. Project No.
MG63302.80. December 1978.
34. Engineering Science, Inc. U.S. Environmental Protection Agency
Test. No. 71-MM-24. Basic Oxygen Furnace. United States Steel
Corporation, Lorain, OH. March 7, 1972.
35.
36.
37.
38.
39.
40.
41.
42.
43.
Engineering Science, Inc. U.S. Environmental Protection Agency
Test No. 72-MM-02. Basic Oxygen Furnace. United States Steel
Corporation, Lorain, OH. June 27, 1972.
United States Steel, Gary Works. Stack Emission Tests, No. 2
Q-BOP, 18-E-005(003). April 1975.
Mostardi-Platt Associates, Inc. Particulate Emission Studies.
Republic Steel Corporation. Chicago, Illinois. U.S. Environ-
mental Protection Agency, Chicago, IL. P.O. 600-792434-621, MPA
70620-71. August 4-7, 1977.
United States Steel Corporation. Q-BOP Emission Tests at United
States Steel Corporation, Fairfield, Alabama. December 12, 1974.
CH2M Hill. Particulate Emission Measurement on Q-BOP "C" at
United States Steel Corporation, Fairfield, Alabama. MG40.40.
October 4, 1978.
Engineering Services Division, Department of Environmental Control,
City of Chicago. Stack Test Particulates B.O.F. Scrubbers, U.S.
Steel South Works. Report No. SS-258. July 1977.
York Research Corporation. Performance Testing of Basic Oxygen
Furnace Electrostatic Precipitators. Report No. 7-9651. CF&I
Steel Corporation. Pueblo, Colorado. May 8, 1979.
Republic Steel, Buffalo, New York.
Emission Tests. November 1975.
Basic Oxygen Furnace Stack
44.
Acurex Corporation. Particulate Matter Emission Rates for BOF
Operations at Youngstown Sheet and Tube, East Chicago, Indiana.
U.S. Environmental Protection Agency. Chicago, Illinois. EPA
Contract No. 68-01-4142, Task 9. Acurex Report TR-78-123, Volumes 1
and 2. August 1978.
Research Triangle Institute. Report of Plant Visit Observations
and Process Operations During Compliance Testing at Youngstown
4-69
-------
Sheet and Tube BOF Shop, East Chicago, Indiana. U.S. Environ-
mental Protection Agency, Research Triangle Park, NC. EPA Con-
tract No. 68-01-4141, Task 9. RTI Project No. 41U-13719. August
31, 1978.
45. Watanabe, T. Ventilation Method and Apparatus with Dust
Collection by Electric Static Precipitator. U.S. 3,844,205.
October 29, 1974.
46. Perry, R. H., et al. Chemical Engineers' Handbook. 4th Edition,
New York. McGraw-Hill. 1963. p. 5-62.
47. Air Pollution Control Equipment for Particulate Matter. Daniel son,
J.A. (ed.). In: Air Pollution Engineering Manual, AP-40, 2nd
Edition. Washington, U.S. Government Printing Office. May 1973.
48. Billings, C. E., and J. Wilder. Fabric Filter Systems Study.
Four Volumes. U.S. Environmental Protection Agency. Research
Triangle Park, NC. NAPCA APTD-0690-0691. December 1970. Also
available from National Technical Information Service PB 200 648,
649, 650, 651.
49. Baldwin, V. H., et al. Environmental and Resource Conservation
Considerations of Steel Industry Solid Waste. U.S. Environmental
Protection Agency. Research Triangle Park, NC. EPA-600/2-79-074.
April 1979.
50. Background Information For Standards of Performance: Electric
Arc Furnaces in the Steel Industry, Volume 2: Test Data Summary.
U.S. Environmental Protection Agency. Research Triangle Park,
NC. EPA-450/2-74-017b. October 1974.
51. Cass, R. W., and J. E. Langley. Fractional Efficiency of an
Electric Arc Furnace Baghouse. U.S. Environmental Protection
Agency. Research Triangle Park, NC. EPA-600/7-77-023. March
1977.
52. Clean Air Engineering, Inc. Report on the Particulate Emission
Tests Conducted for the Wheeling-Pittsburgh Steel Corporation,
Mingo Junction, Ohio. September 8, 1980.
53. Memorandum from Copeland, J. 0., U.S. Environmental Protection
Agency, to Coy, D. W., Research Triangle Institute, December 3,
1981. Subject: BOPF hot metal transfer baghouse data for
U.S. Steel Corporation, Duquesne, Pennsylvania (permit no.
74-I-7028-P).
54. Memorandum from Copeland, J. 0., U.S., Environmental Protection
Agency, to Coy, D. W., Research Triangle Institute, December 3,
1981. Subject: BOPF hot metal transfer data for Sharon Steel
Corporation, Parrel!, Pennsylvania.
4-70
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56.
57.
55. Memorandum from Copelarid, J. 0., U.S. Environmental Protection
Agency, to Coy, D. W., Research Triangle Institute, December 9,
1982. Subject: BOPF hot metal transfer baghouse data for U.S.
Steel Corporation, Braddock, Pennsylvania (permit no. 7035003-
002-9380).
Memorandum from Copeland, J. 0., U.S. Environmental Protection
Agency, to Coy, D. W., Research Triangle Institute, December 9,
1982. Subject: BOPF hot metal transfer baghouse data for U.S.
Steel Corporation, Braddock, Pennsylvania (permit no. 74-I-7052-P).
PEDCo Environmental, Inc. Visible Emission Survey Report. U.S.
Steel Corporation, Fairfield, Alabama. U.S. Environmental Pro-
tection Agency. Research Triangle Park, NC. EMB Report 81-BOF-10
May 1981.
58. Calvert, S., et al. Wet Scrubber System Study. Two Volumes.
U.S. Environmental Protection Agency. Research Triangle Park,
NC. EPA-R2-72-118a, -118b. July and August 1972. Also available
from National Technical Information Service PB 213 016, -017.
59. Oglesby, S., and Nichols. A Manual of Electrostatic Precipitator
Technology. Two Volumes. U.S. Environmental Protection Agency.
Research Triangle Park, NC. NAPCA APTD-0610, -0611. August
1970. Also available from National Technical Information Service
PB 196 380, -381).
60. Ito, S., et al. Roof-Mounted Electrostatic Precipitator. In:
Symposium on the Transfer and Utilization of Particulate Control
Technology, Volume 1. U.S. Environmental Protection Agency.
Washington, DC. EPA-600/7-79-044a. February 1979. p. 485-495.
4-71
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5. MODIFICATION, RECONSTRUCTION, AND ADDITIONS
In accordance with Section 111 of the Clean Air Act, as amended
in 1977, standards of performance shall be established for new sources
within a stationary source category that "may contribute significantly
to air pollution . . . ." Affected facilities are those for which
standards of performance have been promulgated and whose construction
or modification began after the proposal of the standards.
Under the provisions of 40 CFR 60.14 and 60.15, an "existing
facility" may become subject to standards of performance if deemed
modified or reconstructed. An "existing facility" as defined in 40
CFR 60.2(aa) is a facility for which a standard of performance has
been promulgated but for which construction or modification began
before the date of proposal of that standard. The following discussion
examines the applicability of these provisions to basic oxygen process
furnace facilities and describes conditions under which existing
facilities could become subject to standards of performance.
An important note is that a plant may contain both affected and
existing facilities and that reclassifying a facility from existing to
affected status by new construction, modification, or reconstruction
does not necessarily subject any other facility within that source to
standards of performance.
5.1 SUMMARY OF 40 CFR 60 PROVISIONS FOR MODIFICATIONS AND RECONSTRUCTIONS
5.1.1 Modification
Section 40 CFR 60.14 defines modification as follows:
"Except as provided under paragraph (e) and (f) of this
section, any physical or operational changes to an
existing facility which result in an increase in emis-
sion rate to the atmosphere of any pollutant to which a
standard applies shall be a modification. Upon modifica-
tion, an existing facility shall become an affected
5-1
-------
facility for each pollutant to which a standard applies
and for which there is an increase in the emission
rate."
Paragraph (e) specifies certain physical or operational changes
that are not considered as modifications, irrespective of any changes
in the emission rate. These changes include:
1. Routine maintenance, repair, and replacement;
2. An increase in production rate accomplished without a capital
expenditure [as defined in Section 60.2(bb)];
3. An increase in hours of operation;
4. Use of alternate fuels or raw materials if the existing
facility were designed to accommodate the alternate fuel or
raw material prior to the standard (conversion to coal
required for energy considerations, as specified in Section
111 (a)(8) of the Clean Air Act is also exempted.);
5. 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 efficient; and
6. Relocation or change in ownership.
Paragraph (f) provides for superseding any conflicting provisions.
Paragraph (b) of CFR 60.14 clarifies what constitutes an increase
in emissions and the methods for determining the increase. The emphasis
is on the use of emission fact9rs. However, other methods such as
material balances, continuous monitoring systems, and manual emission
tests may be used where utilization of emission factors is not conclusive.
Paragraph (c) of CFR 60.14 affirms that the addition of an affected '
facility to a stationary source does not make any other facility
within the source subject to standards of performance.
5.1.2 Reconstruction
j
Section 40 CFR 60.15 defines reconstruction as follows:
"An existing facility, upon reconstruction, becomes an
affected facility, irrespective of any change in emission
rate. 'Reconstruction' means the replacement of components
of an existing facility to such an extent that: (1) the
fixed capital cost of the new components exceeds 50 per-
cent of the fixed capital cost that would be required
to construct a comparable entirely new facility, and
5-2
-------
(2) it is technologically and economically feasible to
meet the applicable standards set forth in this part."
The purpose of this provision is to ensure that an existing
facility is not perpetuated by replacing all but minor components,
such as support structures, frames, and housing, rather than totally
replacing the facility in order to avoid becoming subject to applicable
standards of performance.
When it is determined that reconstruction has occurred, the
regulations require that the affected facility be equipped to meet all
applicable new source performance standards.
5.2 APPLICABILITY OF MODIFICATION REGULATIONS TO BOPF SHOP FACILITIES
5.2.1 General
When a change to an existing facility at a BOPF shop increases
particulate emissions, it may or may not be deemed to be "modified,"
depending upon the following factors:
1. The definition of the affected facility.
2. The applicability of the exception provisions of 40 CFR
60.14.
3. The applicability of any other exception provisions that are
specially promulgated for the affected facility.
Examples of facility changes at a BOPF shop which may or may not
qualify as modifications are as follows:
1. Addition of another BOPF.
2. Addition or expansion of hot metal transfer facilities.
3. Addition or expansion of skimming facilities.
4.
g a BOPF from top blown to bottom blown or to top and
bottom blown.
5. Converting an open hood BOPF to a closed hood BOPF.
6. Converting a closed hood BOPF to an open hood BOPF.
7. Increasing the production capacity of a BOPF.
8. Modifying facilities to permit scrap preheat.
5-3
-------
9. Addition or expansion of other BOPF shop facilities.
10. Modifying air pollution control facilities.
" j
These cases are discussed in the following sections.
5.2.2 Addition of Another BOPF
Because the affected facility is defined as only the BOPF, then
this kind of change would not be a modification, but would be new
source construction and, therefore, the new facility would be subject
to NSPS.
5-2.3 Addition or Expansion of Hot Metal Transfer or Skimming Facilities
Hot metal transfer and skimming are each defined as a separate
affected facility. Therefore, the addition of either would be new
source construction.
The expansion of an existing hot metal transfer or skimming
station could be deemed a modification if particulate emissions to the
atmosphere increased on a mass rate (kg/hr) basis as a result of the
expansion. If emissions increased and the change were not exempted
under §60.14(e), then the modified facility would be subject to NSPS.
An expansion of the facility could be considered an increase in produc-
tion rate and under §60.14(e)(2), if it were accomplished without a
capital expenditure, it would not be a modification.
5-2-4 Converting a Top Blown BOPF to a Bottom or Top and Bottom Blown BOPF
This type of change would increase secondary particulate emissions.
It is not certain what effect this kind of change would have on primary
particulate emissions. Under §60.14(a), modification determinations
are made on the basis of whether or not the emission rate of a pollutant
increases. No distinction is made as to the specific nature of the
pollutant (e.g., primary or secondary). Therefore, if there is a net
increase in the total primary and secondary particulate emission rates
to the atmosphere as the result of converting a top blown BOPF to a
bottom blown or top and bottom blown BOPF, then the BOPF would be
subject to NSPS for both primary and secondary particulate emissions.
Conversely, if it could be demonstrated that the increase in secondary
emissions was offset with a similar decrease in primary emissions
(i.e., total emissions did not increase), then the change would not be
a modification.
5-4
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5.2.5 Converting an Open Hood BOPF to a Closed Hood BOPF or Vice Versa
In at least one instance, open hood BOPF's have been converted to
closed hood BOPF's. In general, primary emissions from well-controlled
open hood BOPF's are greater than those from well-controlled closed
hood systems. For case's where secondary emissions from an open hood
BOPF are controlled using the primary hood, secondary emissions from
the open hood system are less than secondary emissions from a closed
hood BOPF where the primary hood is the only means used for secondary
emission control. Estimates based on emission factors for secondary
emissions (Chapter 3) and data on the comparative primary emissions
(Chapter 4) indicate that the net difference in secondary emissions is
greater than the net difference between primary emissions for the
foregoing cases. Consequently, for these cases total particulate
emissions would be increased by changing from open hood to closed hood
BOPF systems, unless the closed hood BOPF is equipped for effective
secondary emission control. For this latter case, total particulate
emissions from the closed hood BOPF would be less than total particulate
emissions from an open hood BOPF.
5.2.6 Increasing the Production Rate of a BOPF
Increasing the production rate of a BOPF could increase particulate
emissions. If an increase in production rate could be accomplished
without a capital expenditure on the facility, then it would not be a
modification as discussed in Section 5.1.1. A capital expenditure is
an expenditure that exceeds the product of the applicable "annual
asset guideline repair allowance percentage (AAGRAP)" specified in the
latest edition of Internal Revenue Service Publication 534 and the
facility's installed cost. The AAGRAP listed in IRS Publication 534,
as revised in November 1980, is 18 percent. Increases in production
capacity that are effected by improving operating techniques would
thus probably not be modifications. Equipment changes to increase
production would have to be evaluated on a case-by-case basis.
Relining the furnace with thinner refractory material would tend
to increase production capacity. However, since relining the furnace
is considered to be routine maintenance, this would not cause the BOPF
to become modified and therefore subject to NSPS (see Section 5.1.1).
5-5
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5.2.7 Changes in a BOPF to Permit Scrap Preheat
A BOPF might be altered to inject fuel for scrap preheat. There
would theoretically be increased participate emissions from the fuel
combustion. However, there are no data to confirm this theory. If
natural gas or fuel oil is used for scrap preheat, it would be difficult
to measure any particulate emission increase since the emission increase
would be small in comparison with total emissions from other parts of
the production cycle.
Theoretically, this type of change could be a modification.
However, in the absence of any data showing that an emission increase
has occurred it would be difficult to make this determination.
5'2'8 Addition or Expansion of Other BOPF Shop Facilities
Additions or expansions of other BOPF facilities could involve
hot metal desulfurization, dekishing, teeming, ladle cleaning, and
slag handling. Since these facilities are not affected facilities,
any changes to them would not be "modifications."
5.3 APPLICABILITY OF RECONSTRUCTION REGULATIONS TO BOPF SHOP FACILITIES
5.3.1 General
As discussed in Section 5.2.2, a reconstructed source must be
equipped to meet the applicable NSPS. Determining if reconstruction
has occurred involves (1) comparing reconstruction costs with the cost
of a comparable new facility and (2) determining the technical and
economic feasibility of installing controls to meet NSPS.
One purpose of the reconstruction regulations is "to recognize
that replacement of many of the components of a facility can be substan-
tially equivalent to totally replacing it at the end of its useful
life with a newly constructed affected facility" (42 FR 58417,
December 16, 1975).
5.3.2 Basic Oxygen Process Furnace
The affected facility for determining reconstruction costs for a
BOPF is as follows:
1. The BOPF vessel, including lining, supports, and foundations.
2. The BOPF drive controls, control room, and instrumentation,
including electrical and hydraulic systems and supports and
foundations.
5-6
-------
3. The oxygen lance, controls, and instrumentation, including
electrical and hydraulic systems and supports.
4. The steel ladle and/or slag pot positioning systems, including
controls, instrumentation, supports, and foundations.
The affected facility does not include any of the air pollution control
system such as the furnace enclosure, primary hood, ductwork, exhaust
ventilation system, air pollution control device, or stack. All
facilities used to transport or handle raw materials to the furnace
and to transport or handle products from the furnace are not part of
the affected facility. These latter systems include facilities such as
additive handling systems, ladles, scrap buckets, slag pots, cranes,
etc.
Vessel replacement, lining replacement, and oxygen lance replacement
by themselves are not considered reconstruction. Because of extreme
temperature conditions, vessel replacement is an inherent consequence
of making steel by the basic oxygen process. About every 7 to 15
years the vessel shell must be replaced because of changes in the
characteristics of the metal of the shell. Replacement cost is about
$1 million, or about 20 percent of the $5-million cost of vessel
shell, trunnion ring and drive, lance system, and controls.1 Vessel
linings are routinely renewed about every 1,000 to 2,000 production
cycles. In addition, parts of the oxygen lance must be renewed on a
continuing basis. Consequently, these are not replacements within the
intent of the reconstruction regulations as described in Section 5.3.1.
5.3.3 Hot Metal Transfer Station
The affected facility for determining reconstruction costs for a
BOPF hot metal transfer station is as follows:
1. The pit and other foundations and supports.
2. Ladles and/or vessels that are an integral part of the
station.
3. Systems used to moved the hot metal BOPF ladles within the
station.
4. Instrumentation, controls, control room, hydraulic and
electrical systems used for hot metal transfer.
5-7
-------
The affected facility does not include the air pollution control
system such as the hood, ductwork, exhaust ventilation system, air
pollution control device, and stack. All facilities used to transport
hot metal to and from the station are not part of the affected facility.
In determining costs for reconstruction purposes, routine maintenance
and consumable item replacement costs should not be included such as
spare parts and mixer vessel replacements that are normally needed to
conduct operations. In each case the intent of the regulations as
described in Section 5.3.1 should be considered in determining if the
cost should be included to decide if reconstruction has occurred.
5.3.4 Hot Metal Skimming Station
The affected facility for determining reconstruction costs for a
hot metal skimming station includes all parts of the station that are
needed for skimming the hot metal, including foundations and supports,
and hydraulic, electrical, and instrumentation systems, control rooms,
and controls.
The affected facility does not include the air pollution control
system such as the hood, ductwork, exhaust ventilation system, air
pollution control device, and stack. All facilities used to transport
hot metal to and from the skimming station are not part of the affected
facility.
5.4 REFERENCES
1. Telecon. Turner, J. H. , Research Triangle Institute with Schempp,
E. G., Pennsylvania Engineering Corporation. July 29, 1981
BOPF vessel costs.
5-8
-------
6. MODEL PLANTS AND REGULATORY ALTERNATIVES
The impact of various emission control regulations on BOPF's is
determined through an analysis of model plants. Model plants are
parametric descriptions of both the types of plants that are presently
in operation and those which, in EPA's judgment, may be constructed,
modified, or reconstructed in the future.
Regulatory alternatives are the courses of action that EPA
considers for regulating emissions. Each alternative represents a
different level of emission control for the affected facilities and is
associated with a particular regulatory action. The bases of the
alternatives are the control techniques discussed in Chapter 4.
Numerous other courses of action were investigated and then rejected
for consideration in conjunction with selection of the alternatives
discussed in this chapter.
6.1 MODEL PLANTS
6.1.1 Model Plant Selection
Fifteen model plants have been developed to represent the basic
oxygen process furnace (BOPF) source category. Descriptions of the
models, including a separate hot metal transfer and slag skimming
facility (Model I), are presented in Table 6-1. Schematic drawings of
selected models are presented in Figure 6-1.
Two sizes of furnace vessels are represented in the models, with
design capacities of 136 Mg (150 tons) and 272 Mg (300 tons). Actual
heat sizes may vary slightly depending on production requirements and
hot metal availability. The 136-Mg (150-ton) models are representative
of some older shops and shops that are involved in the production of
6-1
-------
TABLE 6-1. BOPF MODEL PLANTS
Model Production capacity
plant Description Mg/yr (tons/yr)
A
B
Two new 272-Mg (300-ton)
vessels, closed hoods with
scrubbers, top blown equip-
ped with furnace enclos-
ures and baghouse.
One new 272-Mg (300-ton)
vessel added to two existing
2,900,000
(3,200,000)
5,350,000
(5,900,000)
Operating
mode
Sequential
Overlapping
272-Mg (300-ton) vessels,
closed hood with scrubber,
top blown, equipped with
furnace enclosure and bag-
house.
Two new 272-Mg (300-ton)
vessels, closed hoods with
scrubbers,bottom blown,
equipped with furnace
enclosures and baghouse.
One new 272-Mg (300-ton)
vessel added to two
existing 272-Mg (300-ton)
vessels, open hood with ESP,
top blown, equipped with
local hoods and baghouse.
Two existing 272-Mg
(300-ton), top blown
vessels converted to top-
bottom blown (KMS) process,
closed hoods with scrubbers
equipped with furnace
enclosures and baghouse.
Two new 136-Mg (150-ton)
vessels, closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
2,900,000
(3,200,000)
5,350,000
(5,900,000)
Sequential
Overlapping
2,900,000
(3,200,000)
Sequential
1,450,000
(1,600,000)
Sequential
See footnotes at end of table.
(continued)
6-2
-------
TABLE 6-1. (continued)
Model • Production capacity Operating
plant Description Mg/yr (tons/yr) mode
G
One new 136-Mg (150- ton) 2,630,000
vessel added to two existing (2,900,000)
136-Mg (150-ton) vessels,
closed hood with scrubber,
top blown, equipped with fur-
nace enclosure and baghouse.
Overlapping
Two new 272-Mg (300-ton)
vessels,closed hoods with
scrubbers, bottom blown
equipped with furnace
enclosures and baghouse.
Conversion of an open hearth
shop to basic oxygen process.
Hot metal transfer and
skimming station with
baghouse.
Two new 272-Mg (300-ton)
vessels,open hoods, with
ESP, top blown. Secondary
emissions controlled with
primary system.
One new 272-Mg (300-ton)
vessel added to two existing
272-Mg (300-ton) vessels,
open hood with ESP, top
blown, primary system used
to control secondary
emissions.
Two new 272-Mg (300-ton)
vessels,closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
Two new 272-Mg (300-ton)
vessels, open hoods with ESP,
bottom blown, primary system
used to control secondary
emissions.
2,900,000
(3,200,000)
Sequential
Meets shop
production needs
2,900,000
(3,200,000)
5,350,000
(5,900,000)
Not
applicable
Sequential
Overlapping
4,540,000
(5,000,000)
2,900,000
(3,200,000)
Overlapping
Sequential
See footnotes at end of table.
(continued)
6-3
-------
TABLE 6-1. (continued)
Model
plant
Description1
Production capacity
Mg/yr (tons/yr)
Operating
mode
0 Two new 272-Mg (300-ton)
vessels, open hoods with
scrubbers, top blown, pri-
mary system used to control
secondary emissions.
P One new 272-Mg (300-ton)
closed hood vessel added
to two existing 272-Mg
(300-ton) open hood vessels,
top blown. New vessel has
primary scrubber, furnace
enclosure and baghouse.
Existing vessels have ESP
for primary control
2,900,000
(3,200,000)
5,350,000
(5,900,000)
Sequential
Overlapping
All models of new plants include a hot metal transfer and skimming
station. Models of additions to existing .plants do not include a .
hot metal transfer and skimming station.
In sequential operation only one vessel operates at any time with no
overlap in the production cycles. In overlapping operation two
vessels operate simultaneously with varying degrees of overlap in
their production cycles.
6-4
-------
B
FF
F = FURNACE
C = CLOSED HOOD
O = OPEN HOOD
B = BOTTOM BLOWN
T = TOP BLOWN
HMT = HOT METAL TRANSFER & SKIMMING
WS =WET SCRUBBER
FF = FABRIC FILTER (BAGHOUSE)
ESP = ELECTROSTATIC PRECIPITATOR
H2O = WATER TREATMENT
ESP
FF
Figure 6-1. BOPF model plants.
6-5
-------
F- FURNACE
C-CLOSED HOOD
B - BOTTOM BLOWN
T= TOP BLOWN
FF
HMT - HOT METAL TRANSFER & SKIMMING
WS = WET SCRUBBER
FF - FABRIC FILTER (BAGHOUSE)
H2O = WATER TREATMENT
1
H
Figure 6-1. BOPF model plants, (con.)
6-6
-------
FF
FF
F = FURNACE
O = OPEN HOOD
B = BOTTOM BLOWN
T = TOP BLOWN
HMT = HOT METAL TRANSFER & SKIMMING
FF = FABRIC FILTER (BAGHOUSE)
ESP = ELECTROSTATIC PRECIPITATOR
K
N
T
HMT
FF
Figure 6-1. BOPF model plants, (con.)
6-7
-------
F ^ FURNACE
C - CLOSED HOOD
O = OPEN HOOD
T - TOP BLOWN
HMT
FF
HMT = HOT METAL TRANSFER & SKIMMING
WS = WET SCRUBBER
FF - FABRIC FILTER (BAGHOUSE)
H20 = WATER TREATMENT
Figure 6-1. BOP F model plants, (con.)
6-8
-------
specialty steels. The 272-Mg (300-ton) vessel models are characteristic
of the major, high volume, steel production facilities that exist
today in the United States.
Several different operational schedules are possible in multiple
vessel shops. In a two-vessel shop, one vessel may be used while the
second one remains idle, or alternatively, both vessels may be in
service at the same time with some overlap possible in their cycles.
(For example, one vessel may be charged or tapped while the other
vessel is in the blowing phase). In a three vessel shop, one or two
vessels may be in operation while the third is idle. In shops that
have sufficient oxygen capacity, portions of the blowing phase of the
cycles may overlap.
The model plants also differ in the type of primary emission
collection hood present (open or closed hoods). This distinction is
made because some shops with open primary hoods can use these systems
to enhance secondary emission control, particularly during charging
and tapping. Most of the older plants have open primary hoods in
which complete combustion of the process off-gas takes place (complete
combustion system). The trend in new shops is towards the installation
of closed primary hoods that limit combustion of the off-gas to about
10 percent of the total volume of combustible gas generated (suppressed
combustion system). The high concentration of combustible gas remaining
in the exhaust makes it essential to use a scrubber for gas cleaning.
After cleaning, the combustible gases are flared at the stack. The
exhaust rate in a closed hood system is considerably less than that in
an open hood system because excess air for combustion is excluded.
The design parameters for the model plant pollution control systems
are given in Tables 6-2, 6-3, and 6-4.
Model A (Table 6-1) is representative of a new shop with two
272-Mg (300-ton) top blown vessels. The secondary emission control
system consists of full furnace enclosures, equipped with charging and
tapping hoods, ducted to a common baghouse. Model C is a similar
installation with bottom blown furnaces (Q-BOP's). Model H is also a
Q-BOP shop but, unlike Model C, which is a greenfield facility, this
6-9
-------
TABLE 6-2. DESIGN PARAMETERS OF THE MODEL PLANTS
POLLUTION CONTROL SYSTEMS GAS CLEANING DEVICES
Device
Parameter
ESP (primary systems)
Scrubber venturi (primary systems)
Baghouse (secondary systems)
SCA = 72.8 mVacms
(370 ft2/!,000 acfm)
AP = 16.2 kPa (65 inH20)
Air-to-cloth ratio = 0.61 m/
min (2.0 ft/min)
6-10
-------
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6-11
-------
standard. This would be done when only one vessel was operating,
because the data supporting potential standards were obtained in shops
operating single vessels.
In shops that contain unregulated sources, a roof-monitor standard
would have to allow for emissions seen at the monitor that may not be
easily attributable to a given source within the shop. The approach
for these cases would be to allow unregulated sources to be shut down
during compliance testing.
The affected sources in greenfield BOPF shops are hot metal
transfer, skimming, and furnace operations. Sources that would remain
unregulated under all alternatives are teeming, slag handling, ladle
and furnace maintenance, and flux handling.
6.2.2 Regulatory Alternative I (Baseline)
Regulatory Alternative I (identified as the "baseline" alternative
to which other, more stringent alternatives are compared) would involve
no change in the current NSPS for primary emissions. If this alterna-
tive is selected, it is anticipated that closed hood BOPF facilities
would be the most economical for achieving the NSPS as discussed in
Chapter 8. Under Alternative I, there would be no NSPS for secondary
emissions. In the absence of additional NSPS, states may still choose
to require secondary emission control at new facilities. However, for
the purpose of computing the relative impacts of more stringent alter-
natives, it is assumed that under Alternative I, secondary emissions
from all new facilities would be uncontrolled.
6.2.3 Regulatory Alternative II
Under Regulatory Alternative II, additional NSPS would be proposed
to limit the opacity of roof monitor emissions from the BOPF, hot
metal transfer, and skimming and to limit emissions from any air
pollution control device other than the primary emission control
system that is used to control secondary emissions. Regulatory Alter-
native II would involve no change in the current NSPS for primary
emissions and, thus, would allow the use of either closed hood or open
hood control of BOPF primary emissions. The roof monitor opacity
limits would be achievable using either a furnace enclosure with ',
hooding for the capture of secondary emissions from the furnace (as :
6-18
-------
would be done at shops using closed hood;primary.control), or the
primary hood for the capture of furnace secondary emissions (as would
be done at shops using open hood primary control). However, if this
alternative is selected, it is anticipated that open hood control of
the BOPF would be the most economical alternative if the primary
emission control system is also used to capture secondary emissions
(see Chapter 8). Charging emissions can -be captured by the primary
system if the furnace is kept as close to vertical as can be achieved
during the introduction of the hot metal. The capture of the emissions
is made possible by the large gas volume exhausted through th$ open
hood system (Table 6-3). Effective capture of charging emissions from
a 272-Mg (300-ton) furnace can be "achieved with a primary system
evacuation rate of 461 acms (977,000 acfrn) at 204° C (400° F). The
capture of tapping emissions can be facilitated by enclosing the
tapping side of the furnace enclosure with refractory-lined doors or,
as has been done at one plant, by installing an awning-like extension
on the tapping side of the enclosure (see Chapter 4). Doors and '
awnings serve to contain the tapping emissions and direct them towards
the primary hood. Cleaning of the secondary emissions would be accom-
plished with the primary system gas cleaning device.
Emissions generated during hot metal transfer and skimming can be
controlled with local hooding ducted to a secondary emission collection
system gas cleaning device. Effective hot metal transfer facilities
at which tests were conducted were exhausted at a rate of approximately
94.4 acms (200,000 acfm) at 66° C (150° F) (see Chapter 4). Gas
cleaning was accomplished with a baghouse.
6.2.4 Regulatory Alternative III
This alternative would change the current NSPS for primary emis-
sions from a standard achievable by either open or closed hood primary
control to one based on closed hood primary control. This would
involve changing the current NSPS for primary emissions from a mass-
per-unit-gas-volume basis to a mass-per-unit-production basis. Since
the gas volume per unit of production for open hood systems is much
greater than for closed hood systems, Alternative III might preclude
the use of open hood BOPF facilities. The available data are not
6-19
-------
sufficient to show that open hood BOPF facilities could comply with
Regulatory Alternative III. It would add NSPS for secondary emissions
from BOPF shops that would limit the opacity of roof monitor emissions
and that would limit emissions from any air pollution control device
other than the primary emission control device that is used to control
secondary emissions. Charging and tapping emissions from closed hood
furnaces can be controlled effectively with full furnace enclosures
equipped with charging and tapping hoods. Alternative III can be
achieved with evacuation rates for 272-Mg (300-ton) vessels of 283 acms
(600,000 acfm) at 66° C (150° F) for top blown furnaces and 354 acms
(750,000 acfm) at 66° C (150° F) for bottom blown furnaces. Effective
gas cleaning can be achieved with a baghouse although scrubbers or
ESP's can also be used. Full-furnace enclosures probably would not be
suitable for open hood systems in which a limitation on the amount of
air available for primary fume combustion might create an explosion
hazard. For these systems, partial enclosures with charging and
tapping hoods would provide adequate control.
Emissions from top blown, closed hood 136-Mg (150-ton) furnaces
can be controlled as described above for 272-Mg (300-ton) furnaces
with a secondary system evacuation rate of 189 acms (400,000 acfm) at
66° C (150° F). Canopy hood systems or partial building evacuation
systems may be effective alternatives to furnace enclosures. At the
present time, however, the test data are insufficient to support the
efficacy of either of these systems.
6.2.5 Regulatory Alternative IV
Regulatory Alternative IV would involve no change in the current
NSPS for primary emissions. This alternative would add NSPS for
secondary emissions from BOPF shops that would prohibit any visible
secondary emissions and that would limit emissions from any air
pollution control device, other than a primary emission control device,
that is used to control secondary emissions. Alternative IV is based
on the use of building evacuation to meet the no-visible-secondary-
emission requirement.
The most economical system for achieving the primary emission
requirements of Alternative IV would be closed hood BOPF facilities as
6-20
-------
TABLE 6-6. PRELIMINARY EMISSION LIMITATIONS
FOR COMPARING REGULATORY ALTERNATIVES
Emission source
and parameter
Alternative
number
Emission limitation used
for computing imports
Primary control device-
mass emissions
Primary control device-
opacity
Roof monitor—opacity
Secondary control device-
mass emissions
Secondary control device-
opacity
I, IV
III
I, II, III, IV
I
II, III
IV
I
50 mg/dscm
(0.022 gr/dscf)
15 mg/kg (0.03 Ib/ton)
of steel produced
10 percent with an
exceedance of less
than 20 percent
allowed once each
production cycle
None
10 percent with an
exceedance of not
greater than 20 per-
cent allowed once
each production
cycle
No visible emissions
None
II, III, IV 23 mg/dscm
(0.01 gr/dscf)
I None
II, III, IV 5 percent
6-21
-------
described in conjunction with Alternative III (see Chapter 8). The
requirement for no visible secondary emissions can be achieved by
sealing the BOPF shop building and installing an exhaust ventilation
system capable of changing the air once every 2.5 min. A baghouse
would most probably be installed to comply with air pollution control
device effectiveness requirements. However, either ESP systems or
scrubbers could be used.
As discussed in Section 6.1.2, emissions from sources equipped to
meet the limits of Alternative IV are greater than the emissions from
sources equipped to meet the limits of Alternatives II and III. As
shown in Tables 8-2 and 8-3, the annual cost for meeting the limits of
Alternative IV is greater than the annual cost for meeting the limits
of Alternatives II and III. Consequently, Alternative IV is not a
viable regulatory option. This alternative is included primarily to
show that it was considered and to document why it is not practical.
6.2.6 Emission Limitations
Table 6-6 shows the emission limitations corresponding to the
various regulatory alternatives. The limitations were used for comparing
the impact of the various alternatives discussed in Chapters 7, 8, and
9. These emissions limits represent the performance capabilities of
the control techniques (as discussed in Chapter 4) that are the basis
for the alternatives.
6.3 REFERENCES
1. Anonymous, National Blueprints Big BOP Shop Conversion. 33 Metal
Producing. November 1979. p. 63.
2. Telecon. Goldman, L., Research Triangle Institute, with Hoffman,
Dan, Granite City Works, National Steel Corporation. May 28,
1981. Discussion of KMS system for BOPF's.
3. Cuscino, T. Particulate Emission Factors Applicable to the Iron
and Steel Industry. Midwest Research Institute, Kansas City,
Missouri. EPA-450/4-79-028. September 1979. pp. 27-31.
6-22
-------
7. ENVIRONMENTAL IMPACT
Chapter 7 identifies the productive and adverse environmental
changes caused by the addition of BOPF secondary emission controls.
The following impacts are discussed:
The impact of reducing particulate matter and other air
emissions.
The impact of emission control on water pollution.
The impact of emission control on solid wastes.
The energy impact of emission control.
Other environmental impacts such as noise.
Other environmental concerns such as resource commitments
and trade-offs.
7.1 GENERAL
This chapter provides background information for use in making
decisions on the various regulatory alternatives. As discussed in
Chapter 6, the various alternatives selected for consideration are:
I.
II.
III.
IV.
Baseline alternative (the basis to which other alternatives
are compared). No change in the current new source perform-
ance standard (NSPS) for primary emissions from basic oxyqen
process furnaces (BOPF's).
Promulgation of an additional NSPS for secondary emissions
from BOPF facilities with no change in the current NSPS for
primary emissions.
Promulgation of an additional NSPS for secondary emissions
from BOPF facilities and a new NSPS for primary emissions
that might preclude the installation of open hood BOPF
facilities.
Promulgation of an additional NSPS for secondary emissions
from BOPF facilities that might preclude the use of any
control technique other than building evacuation and with no
change in the current NSPS for primary emissions.
7-1
-------
Although all alternatives would allow either open or closed hood
furnaces and either top or bottom blown furnaces, the type of new BOPF
shop selected will depend largely upon: (1) the cost of control for
each alternative, and (2) the technical feasibility of achieving the
emission limitation. For Alternative I (baseline), the most likely
system that would be applied is a closed hood BOPF, since the cost of
primary emission control is less costly for a closed hood BOPF than
for an open hood BOPF (compare Models A and J, Table 8-2). For Alterna-
tive II the lowest cost system for both primary and secondary emission
control is an open hood system where the primary emission control
system is used to control secondary emissions (compare Models A and J,
Table 8-2). Alternative III might preclude the use of an open hood
system. Consequently, it would be necessary to use a closed hood
system (see Model A, Table 8-2). As discussed in conjunction with
Alternative I, a closed hood type shop would probably be the most
economical for meeting the requirements of Alternative IV. Table 7-1
shows the control basis for each alternative.
This chapter also provides information that can be used if other
regulatory alternatives are considered. Within each regulatory alter-
native there are several different model plant situations that might
occur. These various model plant situations are described in Chapter 6.
The alternatives evaluated in this chapter involve top blown shops
equipped with two 272-Mg (300-ton) vessels operated in such a manner
that one is on-line at all times while the other vessel is available
for service. As discussed in Chapter 6, there are numerous different
sizes and types of vessels and modes of operation.
The estimates of changes in mass emissions, solid waste generation,
and energy consumption are based on new source construction adding
6.81 Tg (7.5 million tons) of steelmaking capacity during the period
1981 through 1986 (see Table 7-2). The increases would be less than
those estimated because of 4.15 Tg (4.6 million tons) of retirements
during the period between 1981 and 1986. The offset for retirements
is not estimated because it is not certain whether the retired facilities
7-2
-------
Plant
TABLE 7-1. TYPICAL REGULATORY ALTERNATIVE PLANTS
Description
Baseline plant. Two 272-Mg (300-ton) vessels, closed
hood, top blown, no secondary control. Primary control
by scrubber emits 50 mg/dscm (0.022 gr/dscf). Production
2,900,000 Mg/yr (3.2 million tons/year). Represented by
Model Plant A without secondary control.
II
III
IV
Open hood plant. Two 272-Mg (300-ton) vessels, open
hood, top blown, combined primary and secondary control
with ESP system. Control device emits 50 mg/dscm
(0.022 gr/dscf). Production 2.9 million Mg/y (3.2 mil-
lion tons/year) Represented by Model Plant J.
Furnace enclosure plant. Two 272-Mg (300-ton) vessels,
closed hood, top blown. Primary control by scrubber
emits 15 nig/kg (0.03 Ib/ton). Secondary control by
furnace enclosure and baghouse emits 23 mg/dscm
(0.01 gr/dscf). Production 2.9 million Mg/yr (3.2 mil-
lion tons/year). Represented by Model Plant A.
Building evacuation plant. Two 272-Mg (300-ton) vessels,
closed hood, top blown. Primary control by scrubber
emits 50 mg/dscm (0.022 gr/dscf). Secondary control by
building evacuation and baghouse emits 23 mg/dscm
(0.01 gr/dscf). Production 2.9 million Mg/yr (3.2 mil-
lion tons/year). Represented by Model Plant A with
building evacuation instead of furnace enclosure.
7-3
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would be open hearth or BOPF furnaces. Since the offset would be the
same for all four alternatives valid impact comparisons can be made
without taking the offsets into account.
The ambient air concentration estimates are based on the operation
of 272-Mg (300-ton) vessel plants, as previously discussed. Although
it is possible that larger facilities might be constructed, it' is
unlikely that any facilities would be more than 25 percent larger.
Currently, there are only six U.S. BOPF shops equipped with vessels
larger than 245 Mg (270 tons). Vessel sizes in these shops range from
254 Mg (280 tons) to 320 Mg (350 tons).
7.2 AIR POLLUTION IMPACT
As shown in Figure 3-8, uncontrolled primary emissions.of
particulate matter from either top or bottom blown BOPF vessels are
14,250 g/Mg (28.5 Ib/ton) of steel produced. Using production capacity
estimates for 1981 given in Table 7-2, nationwide emissions would be
1.15 Tg (1.27 million tons) if primary emissions were not controlled.
As shown in Table 3-5, the uncontrolled secondary emission of
particulate matter from BOPF hot metal transfer, charging, tapping,
and teeming ranges from 460 g/Mg of steel produced for top blown
vessels to 895 g/Mg for bottom blown vessels (0.92 to 1.79 Ib/ton).
Under current new source performance standards (NSPS) primary emissions
from a new BOPF shop are limited to 50 mg/dscm (0.022 gr/dscf). For
closed hood furnaces, this limit is estimated to be equivalent to
15 mg/kg (0.03 Ib/ton) of steel produced. For open hood furnaces,
because of their greater volume of gas flow, the limit is estimated to
be equivalent to 75 mg/kg (0.15 Ib/ton) of steel produced. Primary
emissions from furnaces not subject to the current NSPS range from
103 mg/dscm (0.045 gr/dscf) to 206 mg/dscm (0.090 gr/dscf).
As shown in Table 3-4, 1979 nationwide particulate emissions from
BOPF operations are estimated to be 64.9 Gg (71,500 tons). This
includes 51.8 Gg (57,100 tons) of secondary emissions and 13.1 Gg
(14,400 tons) of primary emissions. The estimates assume that
98.8 percent of the primary particulates are controlled and that
23 percent of the secondary particulates are controlled.2 Steel
7-5
-------
production during the years 1976 through 1979 ranged from 70 2 to
75.7 Tg (77.4 million to 83.4 million tons).3 since there was very
little difference among production rates during these 4 years it is
estimated that 1981 production will be about the same and that 1981
emissions will be the same as 1979 emissions.
The four regulatory alternatives described in Chapter 6 may be
represented by typical regulatory alternative plants (TRAP's) Four
TRAP'S defined in Table 7-1 are used to make comparisons among the
regulatory alternatives. These plants are selected to be similar in
size to plants of the type most likely to be built under each regulatory
alternative.
Emissions from the TRAP'S are given in Table 7-3. Reductions
from baseline are 66 percent for open hood, 77 percent for furnace
enclosure, and 20 percent for building evacuation. When divided into
primary and secondary emissions, all TRAP's have the same primary
emissions except open hood, which has increased emissions of 631 percent
over the baseline. Reductions from the baseline for secondary emissions
are 88 percent for open hood, 79 percent for furnace enclosure, and
21 percent for building evacuation.
The projected increase in nationwide emissions through 1986 under
each alternative is shown in Table 7-4. This table is based on a
projected new capacity addition of 6.81 Tg/yr (7.5 million tons/yr)
and the assumption that BOPF shops built under an alternative would be
of the same type as the TRAP for that alternative. Percentage reductions
from baseline are the same as above, although the total amounts are
different.
7.3 AMBIENT AIR IMPACTS
Dispersion calculations have been made for three of the regulatory
alternatives as described below.
Regulatory Alternative I—Baseline
Two 272-Mg (300-ton) closed hood, top blown vessels- one
vessel in operation, one on standby. 'Heat cycTe is 50 minxes.
7-6
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Hot metal transfer emissions are uncontrolled and are at a
rate of 89.5 mg/kg (0.179 Ib/ton) of BOPF steel 272 Mg (300 tons)
per heat. These emissions are emitted from the roof monitor
directly above the operation. This is at a different location
than the charging and tapping emissions and the teeming emissions.
Charging and tapping emissions are uncontrolled at rates of
189 and 146 mg/kg (0.377 and 0.291 Ib/ton), respectively. These
emissions are emitted from the roof monitor directly above the
operation. This is at a different location than the hot metal
transfer and teeming emissions.
Teeming emissions are uncontrolled and are at a rate of
35.0 mg/kg (0.07 Ib/ton). These emissions are emitted from the
roof monitor directly above the operation. Since the teeming
aisle is long, the plume length at the roof monitor is much
greater than for hot metal transfer, charging, and tapping.
Consequently, at times teeming emissions could mingle with the
other emissions.
Since all of the foregoing operations are cyclic, the actual
rate of emissions varies with time. The cycle is repeated about
once every 50 min. For modeling purposes an average emission
rate for a 50-min cycle was used.
Primary emissions are controlled to a level of 50 mg/dscm
(0.022 gr/dscf) and are discharged from a 67.7-m (220-ft) stack.
Flow rate is 41.1 scms (87,000 scfm) at 82° C (180° F).
Regulatory Alternative II
Two 272-Mg (300-ton) open hood, top blown vessels; one
vessel in operation, one on standby. Heat cycle is 50 minutes.
Charging and tapping emissions are controlled with the
primary systems to a level of 50 mg/dscm (0.022 gr/dscf) and are
discharged from a 67.7-m (220-ft) stack. Flow rate is 461'acms
(977,000 acfm) at 204° C (400° F).
Hot metal transfer operations are controlled by a separate
baghouse to a level of 23 mg/dscm (0.01 gr/dscf) and are discharged
from a stack as in Case 2. Flow rate is 94.4 acms (200,000 acfm)
at 66° C (150° F).
Teeming emissions are discharged uncontrolled from the roof
monitor.
Regulatory Alternative III
Two 272-Mg (300-ton) closed hood top blown vessels; one
vessel in operation, one on standby. Heat cycle is 50 minutes.
7-9
-------
Hot metal transfer, charging, and tapping emissions are
ventilated at a rate of 283 acms (600,000 acfm) at 66° C (150° F)
to a baghouse that reduces emissions to 23 mg/dscm (0.01 gr/dscf).
Teeming emissions are discharged uncontrolled from the roof
monitor.
Primary emissions are 15 mg/kg (0.03 Ib/ton). Flow rate is
81.6 acms (173,000 acfm) at 82° C (180° F). Secondary controlled
emissions are discharged from a separate 6.1-m (20-ft) stack
located on top of a 24.4-m (80-ft) baghouse.
Regulatory Alternative IV
The air quality impact of Regulatory Alternative IV was not
analyzed because analysis showed that emissions with Alternative IV
are greater than emissions with Alternatives II or III and that costs
with Alternative IV are greater than costs with Alternatives II or
III. Consequently, Alternative IV is a more costly, less effective
alternative and is impractical (see Tables 6-5, 7-10, 8-2, and 8-4).
Tables 7-5 and 7-6 show the results of the dispersion calculations
These tables give estimates of ground-level concentrations of particu-
late matter at various distances downwind from the BOPF shops. Meteoro-
logical data from Chicago and Pittsburgh were chosen so that periods
of calm winds were minimized, and plant orientations were chosen to
give maximum annual concentrations. Calculations were performed using
the EPA Industrial Source Complex Dispersion Model. The tables show
that BOPF model shops slightly exceed ambient air quality standards
when secondary emissions are not controlled. Maximum concentrations
occur at distances of 0.2 km (656 ft) from the shop.
When the model shops are assumed to have secondary emission
control, both configurations produce downwind maximum concentrations
appreciably below the Federal National Ambient Air Quality Standards
for particulate matter:5
Primary—75 ug/m3--annual geometric mean.
Secondary—260 \ig/m3—maximum 24-hr concentration not to be
exceeded more than once per year.
Reduction of emissions from BOPF operations are offset by increased
emissions from electric power produced to operate the BOPF emission
7-10
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control system. Table 7-7 shows power plant emissions for each regulatory
alternative. As shown, these emissions are small in comparison with
the emissions shown in Table 7-4. They represent 0.53 to 5.6 percent
of the TRAP emissions.
Reduction of secondary particulate emissions from BOPF's would
also reduce organic and inorganic emissions. For the hot metal addition
phase associated with a 233-Mg (257-ton) Q-BOP charge, uncontrolled
organic emissions have been measured as 64.1 mg/dscm (0.028 gr/dscf)
or about 6.9 mg/kg (0.014 Ib/ton) of total charge.6 About 50 percent
of the emissions were associated with particle sizes of less than
3 p.m. Fused aromatics, amines, and carboxylic acid were present.
Uncontrolled inorganic emissions during the hot metal addition include
nickel, iron, chromium, calcium, arsenic, lead, sulfur, and phosphorus,
as shown in Table 7-8.
7.4 WATER POLLUTION IMPACT
Scrubbers and wet gas cooling systems are installed at BOPF shops
in conjunction with air pollution control. Scrubbers are almost the
universal choice for control of primary participate emissions from
closed hood BOPF shops. At some open hood BOPF shops, scrubbers are
installed for primary particulate emission control. At other open
hood shops electrostatic precipitators (ESP's) are used. Where ESP's
are used the gases are cooled prior to the electrical system. The gas
cooling system can be designed as either a dry or a wet system. For
dry cooling systems, all of the water is evaporated into the gas
stream. For wet cooling systems, there is an excess of water and,
consequently, there is a wastewater stream out of the gas cooler.
Scrubbers are not commonly applied for control of BOPF secondary
particulate emissions, except where the primary emission control
system is used for secondary emission control.
For the various alternatives discussed in Section 7.1,
Alternative III would have the greatest potential for increasing water
pollution. Alternative III might preclude the use of open hood BOPF
facilities, thereby requiring the use of closed hood systems that need
to be equipped with scrubbers to avoid potential explosion hazards.
7-13
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-------
TABLE 7-8. UNCONTROLLED INORGANIC EMISSIONS FROM HOT METAL ADDITION
TO A Q-BOP3
Element
Nickel
Iron
Chromium
Calcium
Arsenic
Lead
Sulfur
Phosphorus
Concentration in
mg/m3
0.18
85.30
0.26
64.00
0.021
0.15
7.90
0.53
158.34
off-gas from Q-BOP
gr/scfb
0.000079
0.0373
0.00011
0.0280
0.000009
0.000066
0.00345
0.000232
0.0692
"Reference 6, pp. 22, 30-32.
During hot metal addition only; about 1 min of each production cycle.
Total particle concentration = 1,298 mg/m3.
7-15
-------
However, since both scrubber and gas cooler wastewater effluents are
amenable to total recycle (zero effluent), any water pollution impact
caused by BOPF particulate emission control would be negligible.8 The
potential water pollution impact of solid waste disposal is discussed
in Section 7.5.
7.5 SOLID WASTE IMPACT
Solid waste produced from BOPF operations consists of particulate
matter collected from primary and secondary control devices. For
shops equipped with scrubbers the particulate matter is separated from
the scrubber water before being disposed of. For shops equipped with
ESP's or baghouses, the dry dust is disposed of directly. Collected
dusts and sludge cake are most often disposed of by trucking to landfill
or similar disposal sites. Solid waste generation requires the use of
land for disposal. Disposal potentially involves pollution of ground
waters by leachates.
Table 7-9 shows the amounts of solid waste expected to be generated
from TRAP'S when future new BOPF capacity of 6.81 Tg/yr (7.5 million
tons/yr) is in place, as well as for the individual plants.
Total percentage increases in solid waste above baseline for the
various regulatory alternatives are 2.17 percent for open hood, 2.55
percent for furnace enclosure, and 0.68 percent for building evacuation.
The increases are due almost entirely to collected secondary emissions.
With these small increases, the increase in waste disposal land require-
ments and any leaching problems would be negligible.
7.6 ENERGY IMPACT
Total energy input to the steelmaking process up through the BOPF
is equivalent to 11,561 kWh/Mg (10,488 kWh/ton).9 Air pollution
control energy requirements for the TRAP's range from 5.5 to 46.2 kWh/Mg
(5.0 to 41.9 kWh/ton). These amounts represent 0.05 and 0.40 percent
of the steelmaking energy requirements.
Primary and secondary emission control systems require energy to
overcome system pressure drop, to pump water in systems that use
scrubbers, and to transport waste materials within and outside the
7-16
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plant site. Table 7-10 gives energy requirements for the various
TRAP's when future new BOPF domestic steelmaking capacity of 6.81 Tg
(7.5 million tons) is in place and for the individual plants. Comparison
of the total TRAP energy requirements above baseline shows that the
open hood alternative requires 60.8 percent more, the furnace enclosure
alternative requires 125 percent more, and the building evacuation
alternative requires 738 percent more energy.
The 125-percent increase for the furnace enclosure alternative is
entirely attributable to secondary control, as is the 735-percent
increase for building evacuation. For the open hood alternative,
approximately 20 percent of the increase is due to primary control by
ESP and the rest is due to secondary control.
One method of reducing energy consumption would be to recover
heat values from hot gases produced during charging and tapping. This
recovery would be minimal, however, since the major heat evolution is
from blowing.
During the primary emission phase, heat recovery from water
cooled open hoods would yield about 167,000 kJ/Mg (71.8 Btu/lb) of
steel, while CO recovered from suppressed combustion systems would
produce about 420,000 kJ/Mg (181 Btu/lb) of steel.10 European practice
in some installations has been to recover CO for its fuel value, but
U.S. practice has been to flare the CO. Recovery of 420,000 kJ/Mg
(181 Btu/lb) of steel for 6.18 Tg (6.8 million tons) of steel would
amount to 2,600 TJ (2.46 billion Btu) more heat recoverable in 1986
than in 1981 from primary control.
7.7 OTHER ENVIRONMENTAL IMPACTS
Control of secondary emissions will not require new types of
equipment. Volume of noise generated will increase in proportion to
new BOPF furnaces built, but noise intensity will not increase, and
may decrease, as new equipment designs such as less noisy air compressors
come on the market.
7-18
-------
TABLE 7-10. CONTROL SYSTEM ENERGY REQUIREMENTS FOR
TYPICAL REGULATORY ALTERNATIVE PLANTS: TOTAL NATIONWIDE AND
SINGLE PLANT CAPACITY .
Control system energy requirements
(millions of kWh/yr)
Regulatory Alternative
Primary
Secondary
Total
Total nationwide capacity (6.81 Tg/yr)'
I (Baseline) 37.5
II (Open hood) 44.6
III (Furnace enclosure) 37.5
IV (Building evacuation) 37.5
Single plant capacity (2.90 Tg/yr)'
I (Baseline)
II (Open hood)
III (Furnace enclosure)
IV (Building evacuation)
16.0
19.0
16.0
16.0
0
15.7
46.9
276
0
6.70
20.0
118
37.5
60.3
84.4
314
16.0
25.7
36.0
134
Based on reference 7.
7-19
-------
7.8 OTHER ENVIRONMENTAL CONCERNS
One effect of promulgating an NSPS for secondary BOPF emissions
may be to lengthen operating lifetimes of existing shops. As long as
existing equipment is continued in service it will produce secondary
(and primary) emissions at a rate determined by the difference between
Federal NSPS and state and local standards for existing sources. The
increased lifetimes of existing shops would come about from diversion
of capital from purchasing steel production facilities to purchasing
particulate control equipment. This long-term loss is expected to be
minor.
7.9 REFERENCES
1. Background Information for Proposed New Source Performance Standards:
Asphalt Concrete Plants, et al. Volume 1, Main Text. U.S.
Environmental Protection Agency, Research Triangle Park, NC.
APTD-1352a. June 1973. p. 50.
2. Unpublished data, National Air Data Branch, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina, August
1981.
3. American Iron and Steel Institute. Annual Statistical Report.
Washington, D.C., various years. 1979. p. 55.
4. Analysis of Economic Effects of Environmental Regulations on the
Integrated Iron and Steel Industry. Volume II. Temple, Barker
& Sloane, Inc. Wellesley Hills, Massachusetts. EPA Contract No.
68-01-2832, NTIS PB-273-214, July 1977.
5. U.S. Environmental Protection Agency. Code of Federal Regulations.
Title 40, Chapter I, Subchapter C, Part 50. Washington, D.C.
Office of the Federal Register. July 1977.
6. Westbrook, C. W. Level 1 Assessment of Uncontrolled Q-BOP Emissions.
Research Triangle Institute. EPA-600/2-79-190. September 1979.
p. 3, 4.
7. Estimated Costs Associated with the Proposed Revision of New
Source Performance Standards for Basic Oxygen Furnaces. PEDCo
Environmental, Inc., Cincinnati, Ohio. EPA Contract No. 68-02-3554,
Work assignment No. 5. July 1981.
8. Proposed Development Document for Effluent Limitations Guidelines
and Standards for the Iron and Steel Manufacturing Point Source
Category, U.S. Environmental Protection Agency, Washington, D.C.
EPA 440/1-80-024B. December 1980.
7-20
-------
10.
Reding, John T. , and B. P. Shepherd. Energy Consumption: The
Primary Metals and Petroleum Industries. Dow Chemical, U.S.A.,
Texas Division. EPA-650/2-75-032b. April 1975.
Dixon, T. E. Capital and Operating Costs of OBM/Q-BOP Gas Cleaning
Systems. Iron and Steel Engineer. 55:37-41. March 1978*.
7-21
-------
-------
8. COSTS
8.1 COST ANALYSIS OF REGULATORY ALTERNATIVES
Tables 8-1 through 8-5 give cost information for the model plants
described in Chapter 6.
8.1.1 Basis for Capital Cost Estimates
Capital costs represent the initial investment necessary to
install and commission the system. All costs are based on July 1980
dollars. Capital costs consist of direct and indirect costs incurred
prior to the startup of the system for continuous operation. Direct
costs include the costs of various items of equipment and the labor
and material (construction costs including field overhead) required
for installing these items and interconnecting the systems. Indirect
costs include the costs of such items as freight, procurement, and
allocated costs associated with the purchase and installation of the
control equipment.
8.1.1.1 Direct Costs. The purchased cost of the equipment and
the cost of installing it are considered direct costs. The cost of an
equipment item is the purchase price paid to the equipment supplier on
a free-on-board (f.o.b.) basis; this does not include any freight
charges. Installation costs cover the interconnection of the system,
including piping costs, electrical costs, and the other work needed to
commission it, such as the cost of securing permits and the cost of
insurance for the equipment and personnel onsite. The costs of founda-
tions, supporting structures, enclosures, ducting, control panels,
instrumentation, insulation, painting, and similar items are attributed
to installation. Costs including site development, relocation, or
alteration of existing facilities, administrative facilities,
8-1
-------
TABLE 8-1. CAPITAL COSTS OF CONTROL3---BOPF EMISSIONS—JULY 19801
(millions of dollars)
Case Model
A Two new 272-Mg (300-ton)
Plant b
investment
169.6
Primary
pollution
control
investment
13.2
U/a-f 0«
pollution
control in-
vestment '
4.7
Secondary
pollution
control
investment
12.2
Hot metal
transfer and
skimming
pollution
control f
investment
0.36g
Total
pollution
control
investment
30.5
vessels, closed hoods
with scrubbers, top blown
equipped with furnace
enclosures and baghouse.
Production 2,900,000 Mg
(3,200,000 tons) per year.
B One new 272-Mg (300-ton) 105.3
vessel added to two
existing 272-Mg (300-ton)
vessels, closed hood
with scrubber, top blown,
equipped with furnace
enclosure and baghouse.
Production 5,350,000 Mg
(5,900,000 tons) per year.
C Two new 272-Mg (300-ton) 169.6
vessels, closed hoods
with scrubbers, bottom
blown, equipped with
furnace enclosures and
baghouse. Production
2,900,000 Mg (3,200,000
tons) per year.
D One new 272-Mg (300-ton) 105.3
vessel added to two
t existing 272-Mg (300-ton)
vessels, open hood with
ESP, top blown, equipped
with local hoods and
baghouse. Production
5,350,000 Mg (5,900,000
tons) per year.
E Two existing 272-Mg (300- 16
ton) vessels converted to
KMS process, closed hoods
with scrubbers, top and
bottom blown, equipped with
furnace enclosures and bag-
house. Production 2,900,000 Mg
(3,200,000 tons) per year.
F Two new 136-Mg (150-ton) 84.8
vessels, closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
Production 1,450,000 Mg
(1,600,000 tons) per year.
7.0
10.4
17.4
14.0
4.7
14.0
0.36y
33.1
16.8
10.4
27.2
15.0
15.0
9.3
3.1
9.26
0.249
21.9
See footnotes at end of table.
(continued)
8-2
-------
TABLE 8-1. (continued)
Case Model
G One new 136-Mg (150-ton;
Plant .
investment
) -50.7
Primary
pollution
control
investment
5.0
pollution
control in-
vestment 'e
0
Secondary
pollution
control
investment
7.6
Hot metal
transfer and
skimming
pollution
control .,
investment
0
Total
pollution
control
investment
12. 6
vessel added to two
existing 136-Mg (150-ton)
vessels, closed hood with
scrubber, top blown,
equipped with furnace ,
enclosure and baghouse.
Production 2,630,000 Mg
(2,900,000 tons) per year.
Two new 272-Mg (300-ton) 99.8 14.7 4.7 14.7 0.439 34.5
vessels, closed hoods
with scrubbers, bottom
blown equipped with
furnace enclosures and
baghouse. Conversion
of an open hearth shop to
basic oxygen process.
Production 2,900,000 Mg
(3,200,000 tons) per year.
Two new 272-Mg (300-ton) 169.6 21.3 0 1.0 3.4 25.7
vessels, open hoods, top
blown, equipped with ESP
for primary and second-
ary control. Production
2,900,000 Mg (3,200,000
tons) per year.
One new 272-Mg (300-ton) 105.3 17.4 0 0.6 0 18.0
vessel added to two
existing 272-Mg (300-ton)
vessels, open hood, top
blown, primary system ESP
used for secondary control.
Production 5,350,000 Mg
(5,900,000 tons) per year.
Two new 272-Mg (300-ton) 169.6 13.2 4.7 12.2 0.369 30 5
vessels, closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
Production 4,540,000 Mg
(5,000,000 tons) per year.
Two new 272-Mg (300-ton) 169.6 22.4 0 1.0 3.4 26.8
vessels, open hoods, bottom
blown, equipped with ESP
for primary and secondary
control. Production
2,900,000 Mg (3,200,000
tons) per year.
See footnotes at end of table.
(continued)
8-3
-------
TABLE 8-1. (continued)
Case Model
0 Two new 272-Mg (300-ton)
Plant .
investment
169.6
Primary
pollution
control
investment
19.3
pollution
control in-
vestment >e
.6.8
Secondary
pollution
control
investment
1.0
Hot metal
transfer and
skimming
pollution
control f
investment
3.4
Total
pollution
control
investment
30.5
blown, equipped with
scrubbers for primary
and secondary control.
Production 2,900,000 Mg
(3,200,000 tons) per year.
One new 272-Mg (300-ton)
closed hood vessel added
to two existing 272-Mg
(300-ton) open hood vessels,
top blown. New vessel has
primary scrubber, furnace
enclosure and baghouse,
existing vessels have ESP
for primary control.
Production 5,350,000 Mg
(5,900,000 tons) per year.
105.3:
7.0
4.7
10.4
22.1
alnc1udes direct and indirect capital costs.
Plant investments were taken from Temple, Barker & Sloane, personal communication to J. 0. Copeland,
Assumes separate control device for closed hood, and common control device for open hood. Investments were
taken front reference 1 with some minor adjustments for secondary pollution control equipment.
For BAT 2 control (see note e).
eCosts ware supplied by Effluent Guidelines Division (EGD) of EPA. A 0.6 scale factor was used with EGD
data, and costs were adjusted to July 1980 from July 1978 using a C.E. Cost index value of 219 2 Existina
plants were assumed not to require additional water treatment facilities for the addition of a third vessel
*06 ^ " assumed not to require
Assumes same control _ device as secondary emission control except for models J, N, and 0.
9For models with new closed hood vessels (greenfield shops), only hooding, ductwork and dampers were used as
the najor cost elements.
The KMS conversion was assumed to use existing primary pollution control equipment.
8-4
-------
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construction of access roads and walkways, and establishing rail,
barge, or truck facilities have not been included in developing the
roundout costs except as noted.
8.1.1.2 Indirect Costs. The indirect costs include freight from
point of origin and indirect capital costs. Indirect capital costs
consist of several cost items that are calculated as percentages of
the total installed cost (TIC), the direct costs as noted above. The
indirect capital costs include the following items:
1- Interest—covers costs accrued on borrowed capital during
construction.
2. Engineering costs—includes administrative, process, project,
and general costs; design and related functions for specifica-
tions; bid analysis; special studies; cost analysis; accounting;
reports; procurement; travel expenses; living expenses;
expediting; inspection; safety; communications; modeling;
pilot plant studies; royalty payments during construction;
training of plant personnel; field engineering; safety
engineering; and consultant services.
3. Taxes—includes sales, franchise, property, and excise
taxes.
4. Allowance for shakedown—includes costs associated with
system prior to startup for continuous operation.
5. Spare parts—represents costs of items stocked in an effort
to achieve 100 percent process availability; such items
include pumps, valves, controls, special piping and fittings,
instruments, spray nozzles, and similar equipment.
6. Contingency costs—includes costs resulting from malfunctions,
equipment design alterations, and similar unforeseen sources.
7. Contractors fee and expenses--includes costs for field labor
payroll, supervision field office, administrative personnel,
construction offices, temporary roadways, railroad trackage,
maintenance and welding shops, parking lot, communications,
temporary piping, electrical, sanitary facilities, rental
equipment, unloading and storage Of materials, travel expenses,
permits, licenses, taxes, insurance, overhead, legal liabilities,
field testing of equipment, and labor relations. Contractor
fees and expenses are about 5 percent of the TIC.
The indirect cost for a given estimate is about 65.5 percent of
the TIC. Indirect costs have been added.to all capital costs presented
in this chapter.
8-11
-------
8.1.1.3 Working Capital. Working capital is not included in the
estimated capital costs, nor is the cost of .land for sludge disposal.
8.1.2 Basis for Annual Cost Estimates
Annualized costs represent the cost of operating and maintaining
the system and the charges needed to recover the capital investment,
which are referred to as fixed costs. As with capital costs, all
costs are in July 1980 dollars. Components of annualized cost for the
secondary emission control system are:
1- Operating labor—based on number of hours of equipment
operation. The charge is $18.45 per hour for labor and
$22.14 per hour for supervision. Payroll overhead is taken
as 20 percent.
2. Maintenance—divided into maintenance labor, materials, and
supplies. Total costs for maintenance are about 5 percent
of capital costs.
Solid waste disposal—includes cost of $13.23 per megagram
($12 per ton) for disposal of nonhazardous material.
Utilities—includes electrical power at $0.04 per kilowatt
hour, process water at $0.13 per thousand gallons, and steam
at $3.72 per 1,000 pounds.
Overheads--includes payroll overhead at 20 percent of labor
costs and plant overhead at 50 percent of labor costs plus
materials and supplies costs.
Fixed costs—includes the charges made to recover capital
costs over the depreciable-life of the system. These costs
are taken as a percent of total capital cost (including
indirect costs) amounting to 2 percent for taxes, 2 percent
for insurance, and approximately 6 to 10 percent for capital
recovery.
8.1.3 Description of Facilities
Cost components of the various model plants and associated pollution
control equipment are given below.
8.1.3.1. Plant Facilities. Greenfield shops include the BOPF
building, BOP furnace (including primary hood), cranes, ladles, and
stations for materials handling, hot metal transfer, skimming, teeming,
and facilities for slag and scrap handling. The oxygen plant is
included, and half of the transportation facilities (the other half is
3.
4.
5.
6.
8-12
-------
charged to the blast furnace shop). Control rooms and instrumentation,
office space within the shop, and locker rooms for the shop are included,
as well as auxiliary equipment. Since desulfurization may take place
away from the BOPF shop, desulfurization stations are excluded.
Pollution control equipment is excluded and treated separately below.
Roundout shops include only new vessels. KMS conversion includes only
modifications to the vessel.
8-1-3.2 Primary Pollution Control Equipment. For open hood
model plants, primary air pollution control equipment is designed to
meet an emission limit of 50 mg/dscm (0.022 gr/dscf). For closed hood
model plants primary air pollution control equipment is designed to
meet an emission limit of 68 mg/dscm (0.03 gr/dscf). Designs include
all necessary ductwork, instrumentation, fans, flares, stacks, and
auxiliary equipment. A separate primary control system is constructed
for each closed hood furnace. The primary hood is included in these
costs.
For the open hood model, primary control systems differ from the
closed hood systems in that they have all furnaces tied to a single,
common primary control system, except when a third vessel is added to
two existing vessels. For those models, a second primary control
system is added. Open hood systems have no flare.
8-1-3.3 Water Pollution Control Systems. Costs for water pollution
control systems are based on use of a clarifier and lime treatment,
sulfide treatment, filtration, and pH control of scrubber effluents.
No additional costs for water pollution control systems are estimated
for roundout cases or for KMS conversion.
8.1.3.4 Secondary Pollution Control Systems. Secondary systems
using furnace enclosures are based on pressure baghouses operating at
a gas-to-cloth ratio of 0.01 m/s (2 ft/min) and water pressure drop of
50.8 cm (20 in). Ductwork, fans, auxiliary equipment, and the furnace
enclosure are included.
For building evacuation costs, designs are based on pressure
baghouses operating at a gas-to-cloth ratio of 2:1 and a water pressure
drop of 50.8 cm (20 in). Ductwork, fans, and auxiliary equipment are
8-13
-------
included. System size allows evacuation of the BOPF shop every 2.5
rain. Building volumes are taken as 240,607 and 176,830 m3 (8,496,000
and 6,244,000 ft3) for shops with two 272-Mg (300-ton) top blown and
two 272-Mg (300-ton) bottom blown furnaces, respectively.
8.1.3.5 Hot Metal Transfer and Skimming Pollution Control System.
The only costs allocated for hot metal transfer and skimming control
systems are for hooding, dampers, and ductwork connections to the
secondary emission control system for building evacuation and for
vessels with furnace enclosures. Other vessels have a complete baghouse
system.
8.2 NEW FACILITIES
8.2.1 Model Plant Costs
Costs for secondary emission control systems are based on baghouses
with the design criteria shown in Tables 8-6 and 8-7. For these
tables, it is assumed that no water pollution control or hot metal
transfer and skimming control are required for shops in which a new
vessel is added to existing vessels. Only the new vessel must be
controlled and, as stated in Section 8.1.3.3, it is unlikely that
water pollution control equipment would be needed in addition to that
already existing in the plant, since scrubbers are not ordinarily used
for secondary emission control. For KMS conversions (Model E), it is
also assumed that existing primary emission control equipment is
sufficient. Conversion from an open hearth shop to a BOPF shop requires
primary and secondary emission control equipment, as well as water
pollution control and hot metal transfer and skimming control equipment.
The Chemical Engineering Plant Cost Index was used to adjust costs
given in the references for Tables 8-1 through 8-5.
Design criteria given in Tables 8-6 and 8-7 were derived as
conservative estimates based on typical specifications for existing
installations.
Cost relationships for secondary emission control are given in
Table 8-8. These relationships are shown as percentages of total cost
represented by primary or secondary control systems or by total pollution
control equipment. For primary pollution control investment in furnace
8-14
-------
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8-15
-------
TABLE 8-7. DESIGN CRITERIA FOR MODEL PLANT
SECONDARY EMISSION CONTROL SYSTEMS3
Model
A, L
B, D, P
C, H
E
F
6
J, 0
K
N
^••" - .a - "5^_LS
Control basis
Furnace enclosure
Building evacuation
Furnace enclosure
Furnace enclosure
Bui.lding evacuation
Furnace enclosure
Building evacuation
Furnace enclosure
Building evacuation
Furnace enclosure
Open hood
Building evacuation
Open hood
Open hood
Building evacuation
----- -- • _ . ..
Gas
acms
283
1,600
283
354
1,180
354
1,180
189
1,060
189
94. 4b
1,600
0
94. 4b
1,180
volume
(acfm)
(600,000)
(3,400,000)
(600,000)
(750,000)
(2,500,000)
(750,000)
(2,500,000)
(400,000)
(2,240,000)
(400,000)
(200,000)b
(3,400,000)
0
(200,000)b
(2,500,000)
Operating
time for
affected
unit,
hr/yr
8,760
8,760
5,384
8,760
8,760
8,760
8,760
8,760
8,760
5,293
8,760
8,760
0
8,760
8,760
e*
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air change. Gas temperatures
^bmlding evacuation and 66° C
Hot metal transfer station.
f11ter Wlth an air-to-cloth ratio
lding evacuation assumes 2.5 minutes per
at the baghouse are 52° C (125° F) for
(150° F) for furnace enclosures.
8-16
-------
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enclosures, the range is about 6 to 14 percent and for secondary
pollution control investment, about 6 to 12 percent. For open hoods,
the primary pollution control investment is about 9 to 14 percent, and
for secondary pollution control investment, about 0.5 to 6.3 percent.
The KMS conversion, however, has a cost of about 50 percent, because
plant investment for the conversion is small compared to greenfield
plant investment. For building evacuation, the range of investments
is about 15 to 22 percent depending on vessel size and location of
blowing. Again the KMS conversion appears high (72.6 percent) because
of low plant investment.
For total pollution control investment as a percentage of total
plant investment, the percentages range from about 20 to 26 percent
for furnace enclosures for all but KMS conversion, which is 60.8
percent. Building evacuation control covers a broader range from
about 29 to 46 percent. KMS, again, costs more (75.6 percent) because
of low plant investment.
When secondary pollution control annual costs are compared with
net cost of steel produced, furnace enclosures on greenfield shops are
about 2 to 2.6 percent, and on roundout shops are about 1 to 1.3
percent. Building evacuation systems range from about 5 to 8 percent.
Total annual costs of pollution control compared with net cost of
steel are about 1.3 to 4.7 percent for shops with furnace enclosures
or open hoods. Building evacuation costs are from about 4.7 to 9.0
percent.
Amounts of emissions collected in the various model plants are
given in Table 8-9. These quantities are used to calculate costs of
pollution control on a basis of dollars per megagram (dollars per ton)
of pollutant collected. The costs are given in Table 8-10. These
costs range from a low of $104/Mg ($94/ton) to a high of $62,789/Mg
($69,212/ton) depending on the basis used for comparison. As discussed
in Chapter 6, the effectiveness of furnace enclosures on bottom blown
furnaces has not been measured accurately. Three capture efficiencies
(60, 80, and 100 percent) have been used for estimating purposes, and
are included in the ranges given above.
8-18
-------
TABLE 8-9. EMISSIONS COLLECTED FROM AFFECTED FACILITIES IN MODEL PLANTS
Emissions collected, Hq/yr (tons/yr)a
Model
A
B
C (100% capture)
(80% capture)
(60% capture)
D
E (100% capture)
(80% capture)
(60% capture)
F
G
H (100% capture)
(80% capture)
(60% capture)
I
J
K
L
N (100% capture)
(80% capture)
(60% capture)
0
P
Furnace
41,325
25,397
41,325
41,325
41,325
25,292
41,325
41,325
41,325
20,662
12,484
41,325
41,325
41,325
41,138
30,720
64,570
• 41,132
41,142
41,140
41,215
25,397
primary
(45,552)
(27,995)
(45,552)
(45,552)
(45,552)
(27,879)
(45,552)
(45,552)
(45,552)
(22,776) .
(13,761)
(45,552)
(45,552)
(45,552)
(45,346)
(27,869)
(71,175)
(45.353)
(45,351)
(45,348)
(45,431)
(27,995)
Furnace
830
487
2,036
1,595
1,155
487
2,099
1,653
1,205
402
222
2,036
1,595
1,155
964
592
1,376
2,224
1,779
1,334
966
487
secondary
(915)
(537)
(2,244)
(1,758)
(1,273)
(537)
(2,314)
(1,822)
(1,328)
(432)
(244)
(2,244)
(1,758)
(1,273)
(1,063)
(653)
(1,517)
(2^451)
(1,961)
(1,470)
(1,065)
(537)
Hot metal transfer
222
0
237
231
173
0
0
0
0
95
0
237
231
173
200
200
0
369
200
200
200
200
0
(245)
0
(261)
(255)
(246)
0
0
0
0
(116)
0
(261)
(255)
(246)
(221)
(221)
0
(407)
(221)
(221)
(221)
(221)
0
Building evacuation
172 (190)
1,824 (2,011)
1,824 (2,011)
1,824 (2,011)
172 (190)
923 (1,017)
1,824 (2,011)
172 (190)
cases, but are shown separately, and are calculated based on apparent baghouse efficiency. For example,
Model A has uncontrolled secondary emissions of 1,229 Mg/yr (1,355 tons/yr), excluding teeming, and controlled
secondary emissions of 177 Mg/yr (195 tons/yr), excluding teeming (Table 6-5) for an apparent baghouse
efficiency of 85.61 percent. Uncontrolled hot metal transfer emissions are 259 Mg/yr (286 tons/yr), of which
259 (286) x 0.8561 = 222 Mg/yr (245 tons/yr) are collected. The same methodology is used for calculating
secondary emissions for open hood models in which the primary collector is used for both primary and secondary
emissions. An underline is used to indicate emissions collected in the same device.
8-19
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-------
Table 7-12 shows an estimated increase in new BOPF steel making
capacity of 6.81 Tg (7.5 million tons) from 1981 through 1986. This
amount is equivalent to 2.3 to 5.8 times model plant production,
depending on which model plant is chosen. Using the 2.3 factor for
two new 272-Mg (300-ton) furnaces, capital required to finance primary
pollution control equipment for the new capacity (in July 1980 dollars)
ranges from $41.2 million to $60.0 million for open hoods and furnace
enclosures. Secondary equipment investments, including hot metal
transfer stations, range from $10.1 million to $34.8 million for open
hoods and furnace enclosures and from $75.7 million to $97.5 million
for building evacuation. Annualized costs range from $12.3 million to
$23.4 million for primary systems, from $3.82 million to $10.2 million
for secondary systems, and from $21.7 million to $27.4 million for '
building evacuation.
8-2.2 Comparison of Costs for Various Regulatory Alternatives
Tables 8-11 and 8-12 compare the air pollution control costs for
the four regulatory alternative plants described in Table 7-1. As
shown, building evacuation is a more costly, less effective alternative
when compared to open hood or closed hood exhaust ventilation control.
Comparing the open hood alternative (II) with the closed hood alterna-
tive (III) shows that the closed hood alternative is more effective
for reducing particulate emissions and is more costly ($19,100/Mg or
$17,300/ton of additional particulate removed).
8-2.3 Typical Regulatory Alternative Plant Costs
Comparison of costs based on Typical Regulatory Alternative
Plants (TRAP'S) as described in Table 7-1, is given in Table 8-13.
These costs are for future new BOPF in-place capacity of 6.81 Tg/yr
(7.5 million tons/yr).
Percentage increases in total capital investment above baseline
for the various regulatory alternatives are 43.3 percent for open
hood, 70.0 percent for furnace enclosure, and 236 percent for building
evacuation.
Percentage increases in total annual cost above baseline are
44.4 percent for open hood, 71.4 percent for furnace enclosure, and
222 percent for building evacuation.
8-22
-------
TABLE 8-11. EMISSIONS AND CONTROL COSTS FOR TYPICAL
REGULATORY ALTERNATIVE PLANTS
Alternative
I
II
III
IV
Total emissions
Mg/yr (tons/year)
1,375 (1,515)
396 (437)
323 (355)
1,202 (1,325)
Total participate emission
control costs
$/yr
5,360,000
7,780,000
9,200,000
17,290,000
TABLE 8-12. COMPARATIVE UNIT COSTS OF VARIOUS
REGULATORY ALTERNATIVES
Alternatives
Unit cost per mass of
additional particulate removed
$/Mg ($/ton)
II
III
IV
III
IV
IV
vs.
vs.
vs.
vs.
vs.
vs.
I
I
I
II
III
II
2
3
69
19
,475
,650
,300
,100
0.
00
(2,
(3,
(62
(17
a
a
245)
310)
,800)
,300)
Less effective, more costly alternative.
8-23
-------
r™™ c™™ NATIONWIDE CAPITAL AND ANNUAL COSTS OF
CONTROL FOR TYPICAL REGULATORY ALTERNATIVE PLANTS-
6.81 Tg/yr TOTAL CAPACITY
Regulatory
alternative3
Primary
42.0
49.9
42.0
Capital
Secondary
0
10.3
29.4
Total
42.0
60.2
71.4
Primary
12.6
14.3
12.6
Annual
Secondary
0
3.89
9.0
Total
12.6
18.2
21.6
I (Baseline)
II (Open hood)
III (Furnace
enclosure)
IV (Building
evacuation)
-- -- _
aSee Table 7-1 for definition of typical regulatory alternative plant.
42.0
99.4 141.0
12.6
28.0
40.6
8-24
-------
TABLE 8-14. COST ESTIMATE FOR OSHA COMPLIANCE—
BOPF SECONDARY EMISSIONS—JULY 1980
(millions of dollars)
Case Model
A Two new 272-Mg (300-ton)
Plant
invest-
ment
169.6
Total
pollution
control
invest-
ment
30.5
OSHA
directed
invest-
ment
4.27
vessels, closed hoods
with scrubbers, top blown
equipped with furnace
enclosures and baghouse.
Production 2,900,000 Mg
(3,200,000 tons) per year.
One new 272-Mg (300-ton) 105.3
vessel added to two
existing 272-Mg (300-ton)
vessels, closed hood with
scrubber, top blown,
equipped with furnace
enclosure and baghouse.
Production 5,350,000 Mg
(5,900,000 tons) per year.
Two new 272-Mg (300-ton) 169.6
vessels closed hoods with
scrubbers, bottom blown,
equipped with furnace
enclosures and baghouse.
Production 2,900,000 Mg
(3,200,000 tons) per year.
One new 272-Mg (300-ton) 105.3
vessel added to two
existing 272-Mg (300-ton)
vessels, open hood with
ESP, top blown equipped
with local hoods and
baghouse. Production
5,350,000 Mg (5,900,000
tons) per year.
17.4
33.1
27,2
2.44
4.63
3.81
See footnote at end of table.
(continued)
8-25
-------
TABLE 8-14. (continued)
Case
Model
Plant
invest-
ment
Total
pollution
control
invest-
ment
.OSHA
di rected
invest-
ment
Two existing 272-Mg (300-ton) 16
vessels converted to KMS
process, closed hoods with
scrubbers, top and bottom
blown, equipped with
furnace enclosures and
baghouse. Production
2,900,000 Mg (3,200,000
tons) per year.
Two new 136-Mg (150-ton) 84.8
vessels, closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
Production 1,450,000 Mg
(1,600,000 tons) per year.
One new 136-Mg (150-ton) 50.7
vessel added to two
existing 136-Mg (150-ton)
vessels, closed hood with
scrubber, top blown,
equipped with furnace
enclosure and baghouse.
Production 2,630,000 Mg
(2,900,000 tons) per year.
Two new 272-Mg (300-ton) 99.8
vessels, closed hoods with
scrubbers, bottom blown
equipped with furnace
enclosures and baghouse.
Conversion of an open
hearth shop to basic oxygen
process. Production
2,900,000 Mg (3,200,000
tons) per year.
15.0
2.10
21.9
3.07
12.6
1.76
34.5
4.83
See footnote at end of table.
(continued)
8-26
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TABLE 8-14. (continued)
Case Model
J Two new 272-Mg (300-ton)
Plant
invest-
ment
169.6
Total
pollution
control
invest-
ment
25.7
OSHA
di rected
invest-
ment
3.60
vessels, open hoods, top
blown, equipped with ESP
for primary and secondary
control. Production
2,900,000 Mg (3,200,000
tons) per year.
One new 272-Mg (300-ton) 105.3
vessel added to two
existing 272-Mg (300-ton)
vessels, open hood, top
blown, primary system ESP
used for secondary control.
Production 5,350,000 Mg
(5,900,000 tons) per year.
Two new 272-Mg (300-ton) 169.6
vessels, closed hoods with
scrubbers, top blown,
equipped with furnace
enclosures and baghouse.
Production 4,540,000 Mg
(5,000,000 tons) per year.
Two new 272-Mg (300-ton) 169.6
vessels, open hoods, bottom
blown, equipped with ESP
for primary and secondary
control. Production
2,900,000 Mg (3,200,000
tons) per year.
Two new 272-Mg (300-ton) 169.6
vessels, open hoods, top
blown, equipped with
scrubbers for primary
and secondary control.
Production 2,900,000 Mg
(3,200,000 tons) per year.
18.0
30.5
26.8
30.5
2.52
4.27
3.75
4.27
See footnote at end of table.
(continued)
8-27
-------
TABLE 8-14. (continued)
Case Model
P One new 272-Mg (300-ton)
Plant
invest-
ment
105.3
Total
pollution
control
invest-
ment
22.1
i
OSHA
directed
invest-
ment
3.09
closed hood vessel added
to two existing 272-Mg
(300-ton) open hood
vessels, top blown. New
vessel has primary
scrubber, furnace
enclosure and baghouse,
existing vessels have ESP
for primary control.
Production 5,350,000 Mg
(5,900,000 tons) per year.
Calculated as 14 percent of total pollution control investment.
8-28
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Percentage increases in cost of secondary control above primary
control are less than 30 percent for open hood (capital or annual),
approximately 70 percent for furnace enclosure, and approximately
230 percent for building evacuation.
8.3 MODIFIED/RECONSTRUCTION FACILITIES
The KMS process can be used for either new or modified vessels.
Conversion to this process and the open hearth process has been included
in Section 8.2.
8.4 OTHER COST CONSIDERATIONS
In addition to the cost of control for secondary emissions, there
are other regulatory costs mandated under the Occupational Safety and
Health Act (OSHA), the Water Pollution Control Act (WPCA), and the
Resource Conservation and Recovery Act (RCRA).
The Office of Technology Assessment shows estimates that OSHA
investment costs are about 14 percent of EPA costs on an industry wide
basis. Applying this percentage to BOPF secondary emission control
options gives the results shown in Table 8-14.
Water pollution control costs would apply to effluents from
scrubbers. These costs have been shown in Table 8-1 and range from
13.6 to 22.3 percent of total pollution control investment for new
facilities.
There are no existing regulations for RCRA applicable to BOPF
shops.
Promulgation of a standard for BOPF secondary emission control is
not expected to impose major resource requirements on regulatory and
enforcement agencies since the agencies are already maintaining surveil-
lance over BOPF shops for primary emission control.
8.5 REFERENCES
1. Estimated Costs Associated with the Proposed Revision of New
Source Performance Standards for Basic Oxygen Furnaces. PEDCo
Environmental, Inc., Cincinnati, Ohio. EPA Contract No. 68-02-3554,
Work Assignment No. 5. July 1981.
2. Memorandum from Goldman, L. J., Research Triangle Institute to
, Fitzsimmons, J. G., U.S. Environmental Protection Agency. June
I 26, 1981.
8-29
-------
3. Office of Technology Assessment. Technology and Steel Industry
Competitiveness. June 1980. p. 349.
8-30
-------
9. ECONOMIC IMPACTS
9.0 SUMMARY OF.IMPACTS
Three regulatory alternatives are considered in this analysis.
Regulatory Alternative I is the baseline case from which impacts are
computed. Under Alternative I, primary emissions are controlled but
secondary emissions are not. Alternative II would also control secondary
emissions using open-hood collection systems. Alternative III, which
is more stringent than II, would require the use of closed-hood collection
systems to control secondary emissions. Regulatory Alternative IV,
which would require building evacuation, is shown in Chapters 7 and 8
to be not cost-effective. Thus, this alternative is not considered
further in this analysis.
A range of impacts is computed for each alternative because there
are 14 model plants costed under Alternative I, 5 model plants under
Alternative II, and 9 model plants under Alternative III. In an
effort to provide a more useful analysis, a single impact estimate is
presented for each alternative based on the premise that a new basic
oxygen furnace (BOF) shop with two 272-Mg top blown vessels is most
representative of future BOF construction. These estimated impacts
are summarized below. All dollar estimates are in 1980 dollars.
Regulatory Alternative I is the baseline from which the impacts
of Alternatives II and III are computed. It is projected that in 1986
baseline domestic steel output would be 94 million Mg and baseline
steel industry employment would be 468,120 workers. In 1986, U.S.
steel users would import 19.6 million Mg of foreign steel at baseline.
It should be noted that Alternative I, which controls only primary
emissions, has associated impacts in that the average total cost of
producing steel in a representative shop, as described above, is $2.03
9-1
-------
higher per megagram under Alternative I than under a no-control situation.
If the $2.03 cost impact is fully realized in higher steel prices, the
price impact is 0.53 percent. It can thus be estimated that in the
absence of Alternative I, 1986 steel shipments would be 926,652 Mg, or
0.99 percent, higher. Projected 1986 employment is computed to be
4,615 jobs, or 0.99 percent, higher with no control than under Alterna-
tive I. It should be understood that this employment impact and those
to follow do not occur as layoffs of employed workers but as lost
employment opportunities; that is, there will be 4,615 fewer job
openings created by 1986 under Alternative I than there would have
been without the control. This employment impact estimate, as well as
those that follow, may be an overestimate because employment is likely
to increase in sectors of the economy that produce substitutes for
steel and in industries that produce control equipment. The 19.6-million-
Mg projection of 1986 steel imports under Alternative I is 156,859 Mg,
or 0.80 percent, higher than it would be in the absence of the alternative.
The impacts of Alternative II are measured as changes from baseline.
The steel price increase of $0.65 per megagram represents an 0.17 percent
impact. This price impact would cause an estimated 297,228 Mg output
reduction in 1986, a loss of 0.32 percent. It is estimated that
0.32 percent fewer jobs, a total of 1,498 fewer jobs, would be created
by 1986 under Alternative II than at baseline. Imports in 1986 are
computed to be 50,313 Mg, or 0.26 percent, higher than at baseline.
The estimated total cost of compliance with Alternative II in 1986 is
$15.6 million. This cost is not incurred in any single year, but over
the entire several-year period ending in 1986. It may be an overestimate
since it does not account for new capacity adjustments that could
result from the regulation.
The impacts of Alternative III are also measured from baseline.
The estimated price impact is $1.49 per megagram, or 0.39 percent.
Domestic steel output in 1986 would be 686,200 Mg lower under Alterna-
tive III than under Alternative I. An estimated 0.73 percent fewer
jobs would be created in the steel industry by 1986 under Alterna-
tive III. This loss of 3,417 job opportunities may be offset by
9-2
-------
employment gains elsewhere in the economy. The estimated import
impact is 0.59 percent over baseline. The estimated total cost of
compliance capital through 1986 is $18.4 million for Alternative III.
9.1 INDUSTRY PROFILE
9.1.1 Introduction
This industry profile focuses on the blast furnaces and steel
mills industry. The profile has two main purposes. The first is
informative in nature; the profile should provide the reader with a
broad overview of the industry. In this sense, the industry profile
should be meaningful when read alone. The second purpose is to lend
support to an economic analysis involving the industry by helping to
assess the appropriateness of using a competitive, monopoly or some
other model to analyze the industry. Further, the profile can provide
some of the necessary data that will be used in the analysis itself.
The industry profile is comprised of five major sections. The
remainder of this introduction, which constitutes the first section,
provides a brief, descriptive, and largely qualitative look at the
industry. The remaining four sections of the profile conform with a
particular model of industrial organization analysis. This model
maintains that an industry can be characterized by its basic conditions,
market structure, market conduct, and market performance.1
The basic conditions in the industry, discussed in the second
major section of this profile, are believed to be a major determinant
of the prevailing market structure. Most important of these basic
conditions are supply and demand conditions. Supply conditions are
largely technological in nature, while demand conditions are determined
by the attributes of the products themselves.
The market structure of the blast furnaces and steel mills industry
is examined in the third section of this profile. Issues addressed
include economic aspects of production functions, cost structures,
market power, integration, and barriers to entry. Market structure is
the second link in the overall framework, and has major influence on
the third link, the conduct of market participants.
9-3
-------
Market conduct, addressed in the fourth section, concerns price
and nonprice. behavior of sellers. Of particular interest is the
degree to which the industry pricing behavior approximates the competi-
tive pricing model, the monopoly pricing model, or some model of
imperfect competition.
The fifth and final section of the industry profile addresses
market performance. The historical record of the industry's financial
performance is examined, with some emphasis on its comparison with
other industries. Industry trends are noted, and projections are
presented for key variables such as price, output, and investment.
9.1.1.1 Definition of the Blast Furnaces and Steel Mills Industry.
The blast furnaces and steel mills industry (hereafter the steel
industry) is the name given to those firms classified in Standard
Industrial Classification (SIC) 3312. The industry comprises establish-
ments primarily engaged in the production of hot metal, pig iron, and
ferroalloys from iron ore and iron and steel scrap. SIC 3312 also
includes establishments that produce coke, an important fuel input to
iron production. Establishments primarily engaged in converting pig
iron, scrap iron, and scrap steel into steel are also classified in
SIC 3312. Finally, SIC 3312 includes establishments primarily engaged
in hot rolling iron and steel into such basic products as plates,
sheets, bars, and tubing.2
The majority of all goods produced by plants in the steel industry
are intermediate in nature. As such, they are generally shipped to
other plants within SIC 3312 or other industries to be used as inputs
in the production of final goods or other intermediate goods. The
input/output relationships of SIC 3312 will be dealt with in detail in
Section 9.1.2. It is worthwhile to note here that the demand for
blast furnace and steel mill products is dependent only indirectly on
consumer tastes and preferences. It will be shown later that this
indirect link is nonetheless significant.
9.1.1.2 The Steel Industry in the Macroeconomy. The value added
by all establishments in SIC 3312 in 1977 was $15,331.9 million. This
represents approximately 0.8 percent of total gross national product
9-4
-------
fpr 1977. Employment in the steel industry in 1977 was 441,900, which
was approximately 0.5 percent of total U.S. employment in 1977.
Capital expenditures on new plant and equipment in SIC 3312 was
$2,143.1 million in 1977, approximately 0.7 percent of the national
total.3 4
A comparison of these shares to those of other industries provides
a greater understanding of the importance of SIC 3312 in the, overall
economy. The $15,331.9 million of value added by the steel industry
in 1977 was approximately 6.3 percent greater than that of SIC 2911,
the petroleum refining industry. Value added by the motor vehicle
industry, SIC 3711 in 1977 was approximately 22 percent greater than
that of the steel industry.5 SIC 3312 is thus seen to be among the
larger manufacturing industries.
The U.S. steel industry is a major contributor to total world
steel production. In 1979, the world leader in steel production was
the Soviet Union, which produced 19.9 percent of worldwide steel
output. The United States was second, with 16.5 percent of total
world production. Japan produced 14.9 percent of total steel produced
in 1977.6
9.1.2 Basic Conditions
9.1.2.1 Supply Conditions.
j """
9.1.2.1.1 Product description. Nearly all output of SIC 3312
consists of intermediate goods. As such, most steel mill products are
sold to producers of other goods. These goods in turn might be final
goods such as automobiles, or other intermediate goods, such as engine
pistons and valves.
Sales of these intermediate goods can be classified into three
types. The first type consists of sales of the intermediate goods
from plants classified in SIC 3312 to plants classified in other SIC
codes. In 1972, approximately 83 percent of all sales from SIC 3312
were of this type.7 The second type of sale involves shipments from
plants classified in SIC 3312 to other plants classified in the same
industry. The third type of sale is actually implicit in nature and
is represented by the transfer of goods within a plant from one
9-5
-------
production stage to another. These two types of intraindustry sales
together accounted for approximately 17 percent of all SIC 3312 sales
in 1972.7
A large number of identifiably different products is produced by
plants classified in SIC 3312. For definitional purposes, it is
useful to categorize SIC 3312 output into four products: coke, pig
iron, raw steel, and finished steel products.
Coke is the carbon residue that results from the heating of coal
in the absence of oxygen. Coke constitutes the chief fuel used in the
blast furnace to produce pig iron from iron ore. Coke is classified
as a steel industry product since it is nearly always produced as a
secondary product in SIC 3312 plants. While certain other fuels may
be used to supplement coke in the blast furnace, none are used to
replace coke entirely.
Pig iron is the chief material input in raw steel production.
The conversion of iron ore into pig iron takes place in a blast furnace,
fueled mainly by coke. Pig iron is drawn from the furnace in a molten
state, and is approximately 93 percent iron and 7 percent impurities.
Once produced, the molten iron is utilized in one of two ways. In an
integrated steel mill, the molten iron can be charged, with or without
iron and steel scrap, into a steel furnace. Alternatively, the molten
iron is poured into molds called "pigs" where it solidifies when
cooled. In solid form, pig iron can be stored in plant for later
conversion into steel or shipped to other steel producing facilities.8
Raw steel is the primary product of plants classified in SIC 3312.
Produced in one of several types,of steel furnaces, steel is substan-
tially freer from impurities than pig iron.
The American Iron and Steel Institute identifies three major
grades of steel—carbon, alloy, and stainless.9 Carbon steel contains
only small amounts of such alloying elements as vanadium, molybdenum,
manganese, silicon, and copper.10 Carbon steel is suitable for use in
applications not requiring additional strength or other special proper-
ties. As most applications are of this type, carbon steel accounted
for 85.3 percent by weight of U.S. raw steel production in 1979.9
9-6
-------
Alloy steel consists of steels containing specific percentages of
vanadium, molybdenum, or other elements as well as larger amounts of
manganese, silicon, and copper than carbon steel. Tool steel is an
alloy containing such elements as tungsten and molybdenum. Its added
strength and hardness make it well suited for use in tools and power-
driven cutting and shaping machinery. Another alloy, high-strength
low-alloy steel, contains only small amounts of alloying elements. At
the same time, it is harder than carbon steel because of special
processing.10 Alloy steels are gaining relative importance in the
steel market, increasing from 9.7 percent of total U.S. raw steel
production by weight in 1970 to 13.2 percent in 1979.9
Stainless steel accounted for 1.6 percent by weight of U.S. raw
steel production in 1979.9 Most stainless steel is an alloy of steel,
chrome, and nickel. Stainless steel is generally strong and highly
resistant to rust and corrosion, making it particularly useful in
medical, chemical, and aerospace applications.10
Raw steel exists as solid ingots and crude shapes such as slabs,
billets, and blooms. Slabs, billets, blooms, and other semifinished
shapes are suitable for rolling or other processing into finished
steel products. These semifinished products can either be continuously
cast from molten steel directly from the furnace or can be formed from
reheated steel ingots. Approximately 15 percent of U.S. produced raw
steel is continuously cast currently; the rest is produced in ingot
form.11 12
The fourth major category of SIC 3312 output is finished steel
products. Included in this category are only very basic steel shapes
such as plates, sheets, strips, rods, bars, and tubing. Establishments
that produce these products are classified in SIC 3312 only if they
are "hot-rolled" from iron and steel. Establishments that produce
very similar products by a cold-finishing technique are classified in
other SIC codes by the type of product. For example, the total value
of output by all domestic industries of steel nails and spikes in 1977
was $359.0 million. Of this total, 43 percent was produced in SIC 3312
while 52 percent was produced in SIC 3315--steel wire and related
products.13 14
9-7
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9.1.2.1.2 Production technology.
9.1.2.1.2.1 Raw materials and other inputs. Coke, iron, and
steel production require a wide variety of material inputs. Some of
these inputs—coal and iron ore for example—are nonrenewable resources.
Others such as steel, scrap are better .labeled renewable. An examination
of which goods and services are purchased by plants classified in
SIC 3312 can reveal some information about how steel products are
produced.
The 1972 input-output (1-0) model of the United States economy
identifies 492 distinct goods and services that comprise all economic
activity. The national 1-0 model can be used to determine the economic
and technical interrelationships between all 492 "industries." One of
the 492 sectors identified is SIC 3312—blast furnaces and steel
mills.7
One feature of the 1-0 model allows a determination of the "recipe"
for producing $1.00 of output of SIC 3312. This recipe is an industry
average, and several cautions should be voiced. First, different
plants may use somewhat different mixes of inputs to produce the same
kind of product. Second, a plant that produces only coke, for example,
will use quite a different set of inputs than a plant that produces
only steel. Both plants, however, are classified in SIC 3312. Third,
this industry-average recipe is based on the U.S. economy in 1972. No
more recent model is available. To the extent that input substitution
has occurred in the steel industry since 1972, the input mix has
changed.
Of the 492 input-output sectors, the 10 representing the largest
input cost shares to the blast furnaces and steel mills industry are
recorded in Table 9-1. Most interesting is that the input having the
largest cost share in blast furnaces and steel mill products production
is blast furnaces and steel mills products themselves. Table 9-1
indicates that the steel industry purchased 17.3 cents of its own
output for every dollar of output it produced. This observation can '.
be explained as follows. Producers of iron, who are classified in
SIC 3312, purchase significant quantities of coke from coke plants,
9-8
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TABLE 9-1. IMPORTANT INPUTS TO THE BLAST FURNACES AND STEEL
MILLS INDUSTRY—SIC 3312—IN 19727
Input
Share of total
input cost (percent)
Blast furnace and steel mill products
Iron ore
Railroad transportation
Wholesale trade services
Coal
Industrial chemicals
Electrometallurgical products
Scrap
Electricity
Natural gas
17.3
5.8
3.7
3.7
2.7
2.0
2.0
2.0
1.7
1.4
9-9
-------
which are also classified in SIC 3312. Similarly, steel plants purchase
pig iron. The relatively large size of this intraindustry input
coefficient stresses the importance of vertical integration in the
iron and steel industry.
The second most important input by value is iron ore, which
represents an input cost share of 5.8 percent. The third and fourth
most significant inputs by value are not goods at all, but services.
•For each dollar of output, producers in SIC 3312 purchased 3.7 cents
of railroad transportation and 3.7 cents of wholesale trade services
in order to have all other inputs delivered to their plants.
The 2.7-percent input cost share for coal is a reminder that coke
producers are classified in SIC 3312 and that some integrated steel
mills produce their own coke. Coal, of course, is the primary input
in coke production.
Note finally that the purchase of iron and steel scrap represents
the eighth largest cost share input. Few other industries purchase
such a large share of scrap. This share can be explained by the
importance of iron and steel scrap as a substitute for pig iron in raw
steel production.
9.1.2.1.2.2 Production processes. It has been stressed earlier
that coke, pig iron, raw steel, and finished steel products are all
produced by plants classified in SIC 3312. The purpose of this sec-
tion is to focus only on the production processes employed to produce
the primary output of the industry—raw steel. A discussion of
technological change and trends follows in Section 9.1.2.1.2.3.
The production of raw steel generally involves the introduction
of some combination of pig iron, iron scrap, and steel scrap into a
steel furnace. In the furnace, the impurities in the input charge are
oxidized at high temperature. Steelmaking technologies differ in the
type of furnace used. There are three primary furnace types currently
in use worldwide: the open hearth furnace, the basic oxygen furnace
(EOF), and the electric arc furnace (EAF). The Bessemer type furnace
has virtually disappeared from use.
9-10
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The open hearth furnace is the oldest furnace type currently in
use in the United States, and is the least prevalent. In 1979, only
14.1 percent of all raw steel produced in the United States was produced
using an open hearth process.9 In this process, pig iron, scrap, or
both are placed in a long, shallow furnace made of dolomite or silica
brick. Gas or oil is burned to produce a flame that heats the input
charge from above the open furnace. Preheated combustion air, sometimes
enriched with pure oxygen, is forced into the furnace to aid the
oxidation of impurities.15 16
One advantage of the open hearth furnace is its ability to handle
a charge of all pig iron, all scrap, or any combination of both. This
allows open hearth operators to utilize inputs in an economically
efficient manner as relative prices change. The major disadvantage of
the open hearth process is that the heating cycle time is lengthy—up
to 8 hours.16 Because of the open hearth furnace's lengthy heat time,
the process requires approximately 2.5 times as much energy (measured
in Btu's) per ton of steel than does the electric arc process. The
open hearth process is relatively labor-intensive as well, requiring
up to twice as many labor hours per unit of steel as the basic oxygen
process.1V
The BOF process accounted for 61.1 percent of all U.S. steel
production in 1979.9 The metal charge for a BOF must be largely
molten furnace iron—seldom less than 70 percent. The remaining
charge can be cold pig iron or scrap. A largely molten metal charge
is necessary because supplemental heat is not added to a BOF as it is
to an open hearth furnace. The sole heat source in a BOF is the
latent heat in the molten charge itself.18 Even without the addition
of supplemental heat to a BOF, steel refining is achieved in a short
period of time due to the introduction of large quantities of pure
oxygen. The availability in recent years of large quantities of pure
oxygen at low relative prices has made BOF steelmaking economically
feasible.19
The chief advantage of BOF steelmaking is that pig iron is converted
to steel in a period of approximately 45 minutes. Labor and certain
9-11
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other costs per ton of steel are thus substantially lower for the BOF
process than with the open hearth process. The major disadvantage of
the BOF process is that the charge must consist mainly of molten iron.
A BOF shop must have access to a source of molten metal; it is therefore
usually part of an integrated steel mill.
The EAF steelmaking process accounted for 24.9 percent of all
U.S. steel production in 1979.9 In the EAF process, solid iron and
scrap steel are placed in the furnace. The EAF can accept a charge of
up to 100 percent scrap. Electrically charged electrodes resting
above the iron and steel create an electric arc between the electrodes
and the metal charge. The heat so generated is the sole heat source,
and oxidizes the impurities. Because no impurities are added by
fossil fuels, EAF's are particularly well suited to the production of
alloy steels and stainless steel.20
Because the EAF may be charged entirely with scrap, it need not
be affiliated with an integrated plant. EAF facilities can be quite
small relative to open hearth or basic oxygen furnace operations.
Thus, they are relatively inexpensive to build and market entry is not
prohibited by high startup costs.
9.1.2.1.2.3 Technical potential for input substitution and production
process innovation. This section discusses the technical potential
for input substitution and process innovation in raw steel production.
The distinction should be made between technical potential and economic
potential.
Technical potential is purely an engineering concept regarding
the physical ability to employ different inputs or processes to produce
a certain output. Technical potential does not ensure economic poten-
tial. Innovation is economically feasible only if (1) technical
innovation is possible, and (2) market conditions are such that profit-
maximizing firms are willing to incorporate the technology. It is
clear that if technical innovation is observed in the industry, it
must be both economically and technically feasible. On the other
hand, if technical innovation is not observed, only economic !
9-12
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feasibility can be absolutely ruled out. Technical potential is
thus a necessary, but not sufficient condition for adoption of the
technology by firms.
Evidence generally indicates that considerable potential exists
in a technical sense for process innovation. However, the domestic
steel industry is frequently criticized for being slow to adopt new
technologies.21
The very fact that significant quantities of steel are produced
by three distinctly different basic processes supports the notion that
process innovation occurs. Table 9-2 presents the percent of total
raw steel produced in the United States from 1968 through 1979 by the
three steelmaking processes. The increase in the proportion of steel
produced by the basic oxygen and electric arc processes at the expense
of the open hearth process is striking. BOF production increased from
37.1 percent of the total in 1968 to 61.1 percent in 1979. Over the
same period, EAF production increased nearly twofold.
Technological innovation within the steelmaking processes is
evident as well. Preheating scrap metal allows more of it to be used
in the basic oxygen process. BOF efficiency is also being increased
by the practice of blowing oxygen into the metal charge from below as
well as from above the surface.22
Significant technological advances of other types are also occurring.
Perhaps the most significant change currently is the adoption of
continuous casting technology. In continuous casting, freshly refined
molten steel from the furnace is poured directly into a water-cooled
\
mold. The hardening steel shape is mechanically pulled continuously
from the bottom of the mold and cut into desired lengths. Bypassing
the steel ingot stage and subsequent reheating saves energy, time,
manpower and waste steel. Continuous casters are being most rapidly
employed by EAF operators.11
The major material input in raw steel production is metal—molten
iron, pig iron and scrap steel. The technical potential for substitu-
tion between pig iron and scrap steel can be characterized in two
ways. First, in the general activity labeled steelmaking, pig iron
9-13
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TABLE 9-2. RAW STEEL PRODUCTION BY PROCESS TYPE,
1968 TO 19799
(PERCENT)
Year
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
Open hearth
14.1
15.5
16.0
18.3
19.0
24.4
26.4
26.2
29.5
36.5
43.1
50.1
Basic oxygen
61.1
60.9
61.8
62.4
61.6
56.0
55.2
56.7
53.1
48.2
42.6
37.1
Electric arc
24.9
23.6
22.2
19.2
19.4
19.7
18.4
17.8
17.4
15.3
14.3
12.8
9-14
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and scrap metal are excellent substitutes for each other. Second,
within a defined steelmaking process, substitution potential varies
greatly with the type of process.
When steelmaking is considered as a broadly defined, homogeneous
activity, input substitution is excellent. The ferrous metal input
can be anywhere between 100 percent pig iron (open hearth process) and
100 percent scrap (electric arc process). In practice, a mixture of
pig iron and scrap is more typical. Table 9-3 indicates that in 1978
the open hearth process consumed a 53.5 percent pig iron/46.5 percent
scrap mixture. In basic oxygen steelmaking, the pig iron/scrap mixture
was 72.1 percent/27.9 percent and in electric arc steelmaking, it was
2.7 percent/97.3 percent.
Substitution potential between pig iron and scrap within a given
steelmaking process varies, depending on the process. In the open
hearth process, the ferrous charge can be all pig iron, all scrap, or
any mixture.24 As indicated though in Table 9-3, pig iron has steadily
comprised a little over half of the ferrous charge in open hearth
process steel production in recent years.
The basic oxygen furnace is far less tolerant of input substitution
than the open hearth furnace. The pig iron/scrap mixture rarely
varies far from 70 percent/30 percent. Technological advances, though,
are beginning to relax this constraint. By simultaneously bottom-
blowing additional oxygen into the BOF and preheating the scrap input,
scrap can comprise up to 42 percent of the ferrous charge.22
Electric arc furnaces have historically depended on scrap as
their major input (see Table 9-3). Technically, though, the EAF can
operate satisfactorily with a wide range of variation in pig iron/
scrap content.25
Substitution among fuel inputs is possible as well. Gas and oil
work equally well in generating heat for the open hearth process. In
a basic oxygen furnace, the molten ferrous charge itself is the heat
source, but varying amounts of oxygen are utilized in the process.
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TABLE 9-3. PIG IRON AND SCRAP INPUTS TO RAW
STEEL PRODUCTION23
(Percent)
Pig iron
Scrap
1978
Open hearth
Basic oxygen
Electric arc
1976
Open hearth
Basic oxygen
Electric arc
1974
Open hearth
Basic oxygen
Electric arc
53.5
72.1
2.7
55.7
71.6
1.5
54.2
71.5
3.0
46.5
27.9
97.3
44.3
28.4
98.5
45.8
28.5
97.0
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9.1.2.2 Demand Conditions.
9.1.2.2.1 Historical demand trends. As indicated earlier, steel
is an intermediate good; most sales are to other producing industries.
Because steel is an intermediate good, demand for it tends to increase
in times of increasing business activity and vice versa.
Apparent consumption of steel mill products in the United States
is defined as shipments from U.S. plants plus imports minus exports.
It is a measure of how much steel, imported and domestic, U.S. buyers
purchase. Table 9-4 depicts 11 years of U.S. apparent consumption of
steel mill products and real gross national product (GNP). Note that
the decline in real GNP from 1973 to 1975 is accompanied by a decline
in apparent consumption of steel mill products. The recovery from
1976 to 1978 is marked by an increase in the demand for steel.
While apparent consumption of steel tends to rise and fall with
general economic conditions, it has not increased at an annual rate
equal to that of real GNP. The continuously compounded annual rate of
growth of real GNP from 1969 to 1979 was 2.8 percent. The comparable
growth rate for steel consumption was only 1.1 percent. Possible
reasons for the slow growth in steel demand relative to that for
general economic activity will be discussed in Section 9.1.2.2.3.
9.1.2.2.2 Important users of steel mill products. In Section
9.1.2.1.2.1, the 1972 input-output table of the U.S. economy was
used to identify major suppliers of inputs to SIC 3312--the blast
furnaces and steel mills industry. The same table indicates the value
of output of steel mill products sold to each of the 492 industries.
Table 9-5 identifies the 10 industries that received the most shipments
from plants classified in SIC 3312 in 1972.
Table 9-5 indicates that the most important buyer of steel mill
products was the steel mill industry itself. This fact emphasizes the
great degree of vertical integration in the industry. Coke producers
sell their output to producers of pig iron who in turn sell pig iron
to steel producers; all are classified in SIC 3312.
The next two most significant purchasers of steel mill products
by value of goods purchased are the motor vehicle parts and accessories
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TABLE 9-4. U.S. REAL GROSS NATIONAL PRODUCT AND APPARENT
CONSUMPTION OF STEEL MILL PRODUCTS26 27 28
Year
Real GNP
(109 1972 $)
Apparent consumption
of steel mill products
(10s Mg)
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1,431.6
1,399.2
1,340.5
1,273.0
1,202.3
1,217.8
1,235.0
1,171.1
1,107.5
1,075.5
1,078.8
104,270
105,800
98,365
91,678
80,738
108,485
111,133
96,698
92,981
88,070
93,133
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TABLE 9-5. IMPORTANT PURCHASERS OF OUTPUT FROM THE BLAST FURNACES
AND STEEL MILLS INDUSTRY—SIC 3312—IN 19727
Purchasing industry
Percent of total
SIC 3312 output purchased
Blast furnaces and steel mill products
Motor vehicle parts and accessories
Automotive stampings
Metal cans
Fabricated structural metal
Fabricated plate work
Screws, bolts, nuts, rivets, washers
Iron and steel forgings
Miscellaneous fabricated wire products
Sheet metal work
17.3
6.8
6.3
5.6
4.5
3.3
2.3
2.1
2.1
1.9
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industry, which purchased 6.8, percent of all steel in 1972, and the
automotive stampings industry, which purchased 6.3 percent of the
total in that year. In 1979, 18.6 percent of all steel products was
sold to a broadly defined "automotive" market.29
As shown in Table 9-5, the remaining seven of the ten most
significant purchasers of output of the steel industry are all producers
of intermediate goods: metal cans (used as an input to produce canned
goods), fabricated structural metal (for building), fabricated plate
work, etc. Again, the table stresses the intermediate nature of the
goods produced in the steel industry.
9-1.2.2.3 Competing products. Section 9.1.2.2.1 indicated that
the growth rate in the demand for steel has lagged behind the growth
rate in real GNP in recent years. Section 9.1.2.2.2 emphasized that
steel mill products are primarily intermediate goods used in the
production of other intermediate goods. It is possible that the rela-
tively slow increase in demand is due to a degree of substitution
potential that exists between steel and competing materials for use in
the production of other goods. This section addresses this issue.
As stated previously, 18.6 percent of all steel was purchased by
automotive producers in 1979. According to one examination:
... the longer-range probabilities for more shipments [of steel] to
this area [automotive] do not look good. Fuel economy regulations
legislated by the government have compelled automobile manufacturers
to design more efficient cars. This has meant not only smaller
autos [which use less steel], but cars that contain proportionately
less steel....30 *
The chief materials being substituted for steel in automobile production
are aluminum and plastic, which are being well accepted.
The substitution of aluminum for steel is also having an adverse
impact on the demand for steel by beverage container manufacturers.
Even though canned beverage consumption continues to increase, steel
shipments to the container market peaked in 1974.31
Steel faces competition from materials on many fronts. In
construction, steel competes with concrete and, to a lesser extent,
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aluminum. Aluminum has replaced steel in some facets of ship con-
struction. Polyvinyl chloride pipe and tubing is a major competitor
to the steel counterparts.32
9.1.3 Market Structure
In 1977, there were a total of 396 blast furnaces and steel mill
companies. This represents an increase of 64.3 percent from the
241 companies in 1972. From 1967 to 1972, the number of companies
increased only 20.5 percent, from 200 in 1967.3 This is an interest-
ing observation in that apparent steel consumption grew at least as
quickly in the earlier 5-year period as in the latter. A possible
explanation is market entry in recent years by small companies operating
small, EAF mills. This issue is addressed later in Section 9.1.3.2.
9.1.3.1 Geographic Distribution of Plants. The influence of basic
supply conditions on market structure is also apparent'in the effect on
geographic distribution. BOF plants and, to a lesser extent, open
hearth plants favor plant integration. In turn, integrated plants are
ideally located near sources of coal and iron ore. EAF plants, however,
utilize scrap as their major input. Thus, EAF facilities are less tied
to coal and ore producing regions of the country.
The geographic distribution of plants bears this out. In 1972,
50.0 percent of all plants were located in five states: Pennsylvania,
Ohio, Indiana, Illinois, and Michigan. These states are near coal and
ore production sites. In 1977, only 38.9 percent of all plants were
located in these same states.33 34 As EAF steel production increased
from 17.8 percent of the total in 1972 to 24.9 percent of the total in
1977 (see Table 9-2), geographic concentration became less pronounced.
Fully integrated plants, which need coal to produce coke and ore
to produce iron, are, as expected, very concentrated in the five
states listed above. In 1977, 65.7 percent of all fully integrated
plants were located in these five states.
9.1.3.2 Firm Concentration. Basic supply conditions affect
industry concentration ratios. The greater the proportion of total
output produced by a given number of the largest firms, the more
concentrated the industry.
. 9-21
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Raw steel production would be expected to become less concentrated
as more steel is produced by EAF facilities. This is because EAF
facilities are generally smaller and less integrated than open hearth
and basic oxygen facilities. Thus, EAF facilities are less costly to
build. One estimate places the cost (per ton of annual output) of
building an integrated steel mill at near six times that for building
a small EAF plant.35
The four largest domestic producers of steel mill products together
shipped 53.7 percent of total market tonnage in 1974. In 1979, these
same producers, still the four largest, accounted for only 49.8 percent
of all shipments.36
The recent market entrance of small, EAF steel plants is being
credited in part with reducing industry concentration. One analyst
estimates that the so-called "mini-mills" accounted for 13 percent of
domestic steel shipments in 1978; the same analyst forecasts that they
will capture at least 25 percent of the market by 1990.3S
9.1.3.3 Vertical Integration. As indicated previously, certain
steel production technologies favor some degree of integration. A
plant that produces steel using the basic oxygen process, for example,
requires a ferrous charge comprised largely of molten iron. The
molten iron can most efficiently be transferred directly from the
blast furnace where it is produced, never having cooled. Conversion
of iron ore into iron in the blast furnace in turn requires coke.
Coke can be purchased from other plants, but is frequently produced in
the same establishment.
Production of steel via the electric arc furnace requires little
plant integration. As cold scrap is the usual ferrous charge, neither
coke nor blast-furnace-produced molten iron is necessary.
The 1977 Census of Manufactures indicates that in 1977 there were
504 plants classified in SIC 3312. This represents an increase of
38.5 percent from 364 plants in 1972. In Table 9-6, the plants classi-
fied in SIC 3312 are further classified by degree of integration for
the years 1972 and 1977. Plants that produce coke, iron, raw steel,
and finished steel are regarded as "fully integrated." Plants that
9-22
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TABLE 9-6. PLANT INTEGRATION37 38
Degree of integration
Percent of total plants
1972 1977
Coke, iron, raw steel, finished steel
Iron, raw steel, finished steel
Raw steel, finished steel
Single product or other combination
Total number of plants
10.7
3.6
19.5
66.2
364
6.9
3.4
16.3
73.4
504
9-23
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produce iron, raw steel, and finished steel or just raw steel and
finished steel might be considered "partially integrated." Plants
that produce only one of these four products are called "nonintegrated."
As shown in Table 9-6, the proportion of total plants that were
fully integrated declined from 10.7 percent in 1972 to 6.9 percent in
1977. Over the same period, the percent of total plants that were
partially integrated declined from 23.1 in 1972 to 19.7 in 1977.
Nonintegrated plants, however, increased from 66.2 percent of the
total in 1972 to 73.4 percent in 1977.
The trend away from fully and partially integrated plants towards
nonintegrated plants is an apparent example of how basic supply
(technological) conditions influence market structure. Table 9-2
indicated a substantial increase in the production of steel by the
electric arc process since 1972. This trend towards a technology
requiring little plant integration may account for the shift away from
plant integration.
9.1-3.4. Horizontal Integration. Horizontal integration is
defined here as diversification into the production of nonsteel goods
or services by steel firms. Integration of this type is evidenced by
firms in the steel industry. One estimate indicates that as much as
25 percent of total sales by U.S. steel firms are nonsteel.39
Inadequate profit margins in steelmaking, to be discussed later
in this profile, are frequently cited as the reason for diversifica-
tion by steel firms. Petroleum, chemicals, and financial services are
among the industries in which steel companies have invested. Diversi-
fication is expected to continue. Investment in nonsteel enterprises
by steel manufacturers presently accounts for 20 percent of their
total investment.40
9.1.3.5 Economies of Production.
9.1.3.5.1 Long-run cost structure. An industry is said to have
an increasing (decreasing) cost structure if the expansion of industry
output over time increases (decreases) the real, average total cost of
producing one unit of output. The long-run cost structure of the
steel industry is examined here under the assumption that price equals
average total cost.
9-24
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From 1961 to 1979, U.S. raw steel production (in tons) increased
at a continuously compounded average annual rate of 1.8 percent.28 41
During this same 18-year period, the nominal price of steel increased
at an average annual rate of 6.2 percent.42 That part of the nominal
price increase attributable to inflation can be removed by deflating
the nominal estimate by the increase in the general price level (as
measured by the implicit price deflator) over the same period. The
implicit price deflator was estimated at 4.8 percent per year over
this period; therefore, the real price of steel increased 1.4 percent
per year from 1961 to 1979. An increasing long-run cost structure is
thus indicated for the steel industry.
9.1.3.5.2 Short-run cost structure.
9.1.3.5.2.1 Economies of scale. The presence or absence of
economies of scale is often cited as being partially responsible for
determining short-run cost structure. There is general agreement that
significant economies of scale do exist in steel production; that is,
physical output increases more than proportionately with all inputs.
The Office of Technology Assessment of the U.S. Congress states that
domestic steel producers, because they have smaller, higher cost
plants than their foreign counterparts, are less able to realize
economies of scale.43 The U.S. General Accounting Office says
"...bigger is cheaper in integrated steelmaking. Large-scale plants
can more efficiently use equipment, labor, and energy than small
plants."44 The same report proceeds to estimate 4 million tons (of
raw steel) annually as a minimum economically efficient plant scale.
Economies of scale and minimum efficient scale must not be
considered, however, aside from the plant's technology. Many new
companies are operating EAF plants with capacities under 0.5 million Mg
annually. Far from being uneconomical, these small plants are able to .
sell raw steel below prices charged by integrated mills and still make
a profit.35 Further advances in steelmaking technology could further
reduce the presence of economies of scale.
9.1.3.5.2.2 Production costs and plant vintage. There is a
definite link between steel production costs and plant age. In general,
9-25
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per-unit costs of steel production are higher for older plants than
for newer plants. The General Accounting Office believes the obsoles-
cence of U.S. steel plants to be the industry's major obstacle in
meeting domestic steel demand.45
The cost/age relationship is primarily the result of technological
advance over time. EAF's can produce steel at a lower cost than the
open hearth and basic oxygen furnaces. Newer plants increasingly
adopt the electric arc process, which results in lower cost operations.
9.1.3.6 Entry Conditions. The U.S. steel industry has long been
regarded as presenting barriers to entry to potential market entrants.46
Entry is said to be difficult because very large minimum efficient
plant scale makes for a substantial initial capital investment. One
estimate places the cost of a new integrated steel mill at $1,107 per
megagram of capacity, in 1978 dollars.35 This would put the capital
cost of a 4-million-Mg plant at nearly $5 billion (see Section
9.1.3.5.2.1).
That barriers to entry are actually restrictive is not clear from
U.S. Bureau of the Census data. In 1967, 200 companies operated one
or more establishments classified in SIC 3312. The number of companies
increased 20.5 percent from 1967 to 1972, for a total of 241 companies
in 1972. Market penetration was even more pronounced from 1972 to 1977.
A total of 396 companies operated in SIC 3312 in 1977, an increase of
64.3 percent from 1972.3
Much of the dramatic increase in the number of new companies since
1972 is no doubt the result of new, small-scale, EAF plant operations.
"Mini-mills" are less expensive to build because blast furnace and coking
facilities are unnecessary. An estimate for building a new mini-mill is
$19'2 per megagram of capacity, in 1978 dollars—far under the $1,107
estimate for an integrated mill.35 Removal of the startup cost barrier
is significant. Entry barriers of other types appear to be minimal.
9.1.4 Market Conduct
This section focuses mainly on pricing behavior in the steel
industry. The question is whether the steel industry most closely
approximate the competitive pricing model, the monopoly pricing model,
9-26
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or some model of imperfect competition. Important factors to be
considered include homogeneity of product, degree of industry
concentration, barriers to entry, and observed pricing practices.
9.1.4.1 Homogeneity of Product. The degree to which the .output
of an industry is perceived by demanders to be homogeneous is an .
important determinant of industry pricing behavior. The more homogeneous
the product, the more likely a single market price will be observed.
A perfectly homogeneous good is difficult to sell at some price higher
than that offered by one or more competitors. Interestingly, in his
discussion on this subject, Nicholson suggests steel girders as one
tentative example of a strictly homogeneous good.47
The degree of product homogeneity in the steel industry is not
easily determined. Section 9.1.2.1.1 of this profile suggests there
are four major categories of products produced by establishments
classified in the blast furnaces and steel mills industry—coke, pig
iron, raw steel, and finished steel products. These products differ
greatly from one another in use. Coke, for example, is of no interest
to a construction firm demanding steel girder. The price for a megagram
of coke would not be equivalent to that for a megagram of steel girder;
the two are not homogeneous products.
A meaningful discussion of "product homogeneity cannot proceed
without some reasonable limitation of product definition. Sec-
tion 9.1.2.1.2.2 of this profile, which discusses production processes
employed in SIC 3312, concentrates on the primary output of the
industry—raw steel. The same approach will be adopted here. The
relevant question is whether raw steel is perceived by buyers to be
homogeneous.
In 1979, approximately 85 percent of all raw steel was carbon
steel, the remainder being alloy and stainless.9 Raw carbon steel is
produced as ingots, blooms, slabs, billets, and other semifinished
shapes. All of these shapes resemble one another in that they are, to
varying degrees, square, blocky, solid forms with rounded edges. All
are similar in that they are not useful in these forms, but must be
rolled, drawn, or otherwise processed into more finished shapes such
as girders, rails, bars, rods, sheets, pipes, and plates.
9-27
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Scherer compares the homogeneity of steel with that of cement and
rayon.48 Any differences in steel, he argues, are superficial. There
may be complex differences in finish, temper, packaging, etc., but
steel is fairly homogeneous.49 The Federal Trade Commission says that
within each steel product line, steel is relatively homogeneous; the
product of one plant is physically substitutable for the product of
another.50
Homogeneous output alone does not ensure a single pricing model.
A strictly homogeneous product can be produced under perfect competi-
tion, monopoly, or any other market model.51 It becomes necessary to
investigate other indicators of pricing behavior. However, recognizing
the hazards of such a generalization, product homogeneity will be
accepted as characterizing steel output.
9.1.4.2 Degree of Concentration. Industry concentration largely
determines market pricing behavior. At the one extreme, where all
industry output is produced by a single firm, the pure monopoly pricing
model is most relevant. The other extreme is an industry characterized
by many sellers, with no one firm producing a significant share of
total output. A perfect competition pricing model is applicable here.
Either extreme is rare, and the steel industry is neither extreme.
The U.S. steel industry is clearly not a pure monopoly. In 1977,
there were 396 companies with plants classified in SIC 3312.3 Whether
the existence of 396 companies justifies the use of a perfect competi-
tion pricing model is less clear. For perfectly competitive pricing
practices to result, it is not sufficient that a large number of firms
exist. No one firm must produce a large enough share of industry
output to enable it to influence market price by its own actions. In
1979, the single largest domestic steel firm, U.S. Steel, accounted for
20.8 percent of total domestic steel shipments.52 This large market
share of a single producer brings into question the appropriateness
of the perfectly competitive pricing model for the industry.
9.1.4.3 Barriers to Entry. The degree to which barriers to
entry effectively reduce market penetration by new firms influences
industry pricing behavior. Nicholson calls barriers to entry the
9-28
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source of all monopoly power.53 Section 9.1.3.6 concludes that
effective barriers to entry do not exist in the steel industry.
The apparent lack of significant barriers to entry promotes the
selection of the perfectly competitive pricing model. "Free" market
entry is necessary but not sufficient to support this model. "Free"
market entry obtains when the only costs of production incurred by new
firms are those incurred by established firms.54 In the case of the
steel industry, economies of scale enjoyed by existing firms once
resulted in lower per unit cost of production. Technological advances,
especially the development of the EAF, have apparently diminished this
technological advantage, as evidenced by recent market entry.
9.1-4.4 Observed Pricing Practices. The purpose of this section
is to comment on actually observed pricing practices in the steel
market as another aid in selecting an appropriate pricing model. If
market participants behave as perfect competitors, a perfect competition
model would logically be deemed appropriate. If evidence of imperfect
competition behavior is apparent, other market models can be explored.
Emphasis will be placed on observed pricing behavior in recent times--
the past 20 years.
Selection of the past 20-year period for examining pricing behavior
is not entirely arbitrary. Until the 1960's, the U.S. steel industry
had a long history of adherence to a pattern of rigid administered
pricing. During normal times in the period prior to the 1960's,
U.S. Steel Corporation, with a market share exceeding one-half, assumed
the role of price leader and its smaller rivals followed.55
In the 1960's and 1970's, pricing behavior has been complicated
by two factors. First is the competition provided by foreign steel
supply. Second is the industry structural change resulting from
changing basic conditions, especially technological advance.
Pricing behavior in the domestic steel industry is most frequently
said to be characteristic of an oligopolistic market. An oligopoly is
a market with relatively few firms producing a homogeneous product. A
single firm in an oligopoly can have some effect on the price it will
receive for its output because it has a significant market share of
the total output.56
9-29
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Smolik cites the U.S. steel industry as being a "... concentrated
oligopoly on the basis of concentration ratios and on the basis of its
highly knit social structure." The oligopolistic structure, he argues,
is further strengthened by the homogeneous nature of most steel products.57
Adams (writing in 1977) states:
The steel industry today is—structurally speaking—an oligopoly and
is dominated by a relatively few, large, integrated producers.
These, taken together, own or control about three quarters of the
nation's . . . ingot and "steel for casting" capacity . . . .58
Unfortunately, a tentative conclusion that the American steel
industry is an oligopoly makes it more difficult, not easier, to
identify a specific pricing behavior model. 'There are no generally
accepted pricing behavior models for oligopolists as there are for
perfect competitors and monopolists. Many price/output combinations
can result based on various sets of behavioral assumptions. Observation
of actual oligopoly markets suggests that almost anything can happen.5?60
One generalization that perhaps can be made is that some form of ;
administered pricing behavior will emerge under oligopoly. The outcome
of a single firm in an oligopoly changing its output price depends, in
part, on the reactions of other firms. A firm stands to suffer if it
cannot accurately determine beforehand how its actions will be met by
other firms. Prices tend to be fixed until some unifying event can
ensure the "appropriate" response by all firms.61
A system of price leadership often emerges in oligopoly. If a
single firm is recognized as the price leader, price adjustments can
occur with some assurance of market order as other firms follow in
concert.
Price leadership has been an apparent characteristic of the U.S.
steel industry. U.S. Steel Corporation is the usually recognized
price leader. All other companies follow the leader's actions
closely.57 62 As recently as 1971, an announcement of a price hike
for all mill products by U.S. Steel Corporation was promptly followed
by a similar declaration by other major producers.63 When the U.S.
General Accounting Office in 1979 asked steel users why they buy
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foreign steel, one answer given was that they, as buyers, perceived
that many U.S. mills follow sui.t each time a major steel mill
publishes a new price list.64
While there is near universal agreement that the domestic steel
industry has historically been oligopolistic with U.S. Steel Corporation
acting as price leader, trends in recent years indicate the situation
is changing or has changed. The reason for this basic change in
market conduct is, once again, changes in market structure. Three
structural changes have been observed.
First, the Federal Trade Commission reports that since 1960,
U.S. Steel Corporation has had to share the leader role with Armco
Steel and Bethlehem Steel. Efforts to raise prices by any leader have
frequently been ignored unless they reflected basic supply and demand
conditions.65
A second major structural change has been the dramatic increase
in steel output by independent mini-mills. Mini-milIs regularly
engage big producers in price competition, and are beginning to be a
greater threat to historically large steelmakers than are the foreign
producers.35 66 The success of mini-mills is in turn the result of a
successful technological advance—the EAF. This is an example of how
changes in basic conditions can, by influencing market structure,
ultimately result in changes in market conduct.
The third major structural change is the increasingly significant
role of steel imports. In 1961, imported steel mill products accounted
for only 4.7 percent of United States consumption. This import market
share increased to 13.8 percent in 1970 and reached a peak of 18.1
percent in 1978.28 41
Steel imports may have a significant role in the price behavior
of domestic steel firms. If the U.S. steel industry is an oligopoly,
the U.S. Steel Corporation is the dominant firm, with steel shipments
of 19.0 million Mg in 1979.52 In that same year, total steel mill
imports totaled 15.9 million Mg--83.7 percent of the dominant firm's
output.28 As foreign producers collectively capture more of the U.S.
market, domestic firms individually and collectively enjoy less market
power.
9-31
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To summarize, it is not easily concluded that currently observed
pricing behavior in the steel industry is oligopolistic. Increasingly,
individual firms are setting their own price based mainly on their own
cost structures and basic underlying supply and demand conditions.
9.1.5 Market Performance
In a conditions-structure-conduct-performance industry profile,
the performance section is of special importance. Market performance
is seen as the result of the earlier causal chain. Emphasis in this
section will be on three aspects of market performance. First, a
financial profile of the steel industry will be presented with comments
and comparisons to other industries. Second, recent trends in such
industry variables as price, output, employment, and investment will
be presented. Third, industry projections will be discussed.
9.1.5.1 Financial Profile of the Steel Industry. The objective
of a firm is to maximize shareholders' wealth. It can be shown that a
firm that behaves so as to maximize profit maximizes the discounted
stream of cash flows to its shareholders.67 If this is accepted as
the primary objective of firms, some measure of success in achieving
this objective is surely a relevant measure of financial performance.
Stockholders' equity is the portion of a corporation's assets
owned by holders of common and preferred stock. It is equal to the
excess of a firm's assets over its liabilities.68 A ratio frequently
used to assess a firm's success in maximizing shareholder's wealth is
the ratio of after-tax profit to stockholders' equity. An average of
this ratio for firms representing approximately 90 percent of raw
steel output over the period 1960-1979 is presented in Table 9-7. As
a comparison, the same ratio is presented for firms representing all
manufacturing over the same period.
A profit-to-equity ratio of 10 percent or higher is usually
regarded as necessary to provide dividends to the holders of stock, as
well as funds for future growth.72 The 20-year average profit-to-
equity ratio for all manufacturing, as indicated in Table 9-7, is
13.0 percent. The 20-year average for the steel industry is consider-
ably lower--7.4 percent. In only one year, 1974, was the ratio for
9-32
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TABLE 9-7. AFTER-TAX PROFIT TO STOCKHOLDERS' EQUITY69 70 71
.(PERCENT)
Year
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
1960
Steel
6.8 .
7.3
0.1
7.8
9.8
17.1
9.3
5.8
4.3
4.1
7.0
8.2
6.9
8.9
9.4
9.0
7.3
5.3
6.5
7.9
All manufacturing
16.7
15.9
14.9
15.0
12.6
15.2
14.9
12.1
10.8
10.1
12.4
13.3
12.6
14.2
13.9
12.6
11.6
10.9
9.9
10.6
9-33
-------
steel firms equal to or greater than that for all manufacturing. The
profitability difference as measured by this ratio between steel and
other industry is even more pronounced in recent years. During the
period 1970-1979, return to steel stockholders was only 7.2 percent
compared to 13.8 percent for all manufacturing stockholders. i
These figures tend to support the contention by Adams that the
steel industry's profit record has been poor in recent years. Adams
blames the industry's noncompetitive pricing conduct, leading to
technological lethargy and inadequate capacity utilization, for low
profitability.73
9.1.5.2 Financial Profile of Firms Owning BOF Facilities.
Financial data on 18 companies that now own BOF facilities are presented
in Table 9-8. From these financial data, three ratios have been
calculated for each company. These ratios are presented in Table 9-9.
The liquidity ratio is a measure of the firm's ability to meet
current obligations as they come due. A liquidity ratio above one
indicates the firm is solvent enough to meet current obligations with
little trouble. A firm with a liquidity ratio below 1 may be unable
to pay bills on time, a condition which could lead to its eventual
demise.75 The liquidity ratios of BOF-operating firms vary from 1.25
to 2.55.
The profit ratio measures the ability of the firm to pay dividends
to stockholders while maintaining adequate funds to ensure growth. A
ratio of 10 percent or higher is usually deemed necessary to secure
these ends.72 One firm, U.S. Steel, has a negative profit ratio for
1979. The ratios for the remaining firms vary between 5 percent and
23 percent. Of the 18 companies, 12 have a ratio of 10 percent or
higher.
The leverage ratio indicates the relationship between total
liabilities, including those owed to stockholders, and stockholders'
equity. Because the numerator, total liabilities, is largely comprised
of debt owed to bondholders and stockholders' equity, a ratio exceeding
2 is an indication that there is more interest debt outstanding than
there is owner-contributed equity. While it is difficult to say what
9-34
-------
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9-35
-------
TABLE 9-9. FINANCIAL
RATIOS FOR FIRMS
FURNACES, 1979
OWNING BASIC OXYGEN
Liquidity
Company name ratio
Allegheny Ludlum
Armco Steel
Bethlehem Steel
CF&I Steel
Crucible Steel
Ford Motor Co.
Inland Steel
Interlake, Inc.
International Harvester
Jones and Laugh! in Steel
Kaiser Steel
McLouth Steel
National Steel
Republic Steel
Sharon Steel
U.S. Steel
Wheeling Pittsburgh Steel
Youngstown Sheet & Tube
aLinuidit- Ratio - Current Assets
Liquidity Katio Current L1abn
bPrrfit Patio - Net Prof1t
2.01
2.07
1.78
1.58
2.55
1.25
1.43
1.73
1.74
1.45
1.67
1.44
1.74
1.62
1.84
1.43
1.59
1.46
ities
Profit
ratio0
0.15
0.13
0.10
0.07
0.17
0.11
0.10
0.11
0.17
0.16
0.09
0.05
0.09
0.08
0.23
-0.05
0.12
0.15
Leverage
ratio
2.35
1.90
1.96
1.88
2.04
2.26
2.06
2.10
2.43
2.04
2.19
2.46
2.20
1.85
4.32
2.04
2.13
2.90
Katio Tangible Net Worth
cLeveraap Ratio - Total Liabilities
Tangible Net Worth
9-36
-------
the highest satisfactory ratio is, in general the higher the ratio,
the more likely that the firm would be unable to meet its long-term
obligations. Of the 18 companies 14 have leverage ratios exceeding 2,
indicating that they are substantially debt financed.
Table 9-10 lists the simple (unweighted) means of the three
ratios for the 18 BOF companies. Also listed are industry average
ratios for several arbitrarily selected industries for the same year.
While it is difficult to draw meaningful conclusions, observations can
be made. Of the five industries compared, only one, petroleum refining,
has a lower liquidity ratio. The profit ratio for the BOF steel
industry is well below those of the five industries compared. Finally,
the leverage ratio for the BOF steel industry is in line with those of
the other industries compared.
9-1.5.3 Industry Trends. The purpose of this section is to
highlight recent trends in certain steel industry variables. The
variable values presented and the related discussion are intended only
as an indication of past industry performance. Projections of future
performance are presented in Section 9.1.5.4.
9.1.5.3.1 Physical output. The annual physical output of an
industry is perhaps the single best indicator of industry performance.
In general, a healthy industry is expected to increase physical produc-
tion in pace with general economic activity. As the population increases
and real income increases,, the demand for industry output is expected
to increase. An annual index of shipments of domestically produced
steel mill products tonnage has been constructed and is presented in
Table 9-11. In the same table is the total industrial production
index of the U.S. Board of Governors of the Federal Reserve System.
Both are indexes of actual physical output.
It is clear from Table 9^-11 that during the 13 years ending in
1979, steel production did not keep pace with total industrial produc-
tion. The average annual continuously compounded rate of growth of
total industrial output was 3.5 percent, compared with only 1.5 percent
for steel mill products. For the period covered, domestic steel
shipments peaked in 1973. The 2-year decline in the total industrial
9-37
-------
TABLE 9-10. FINANCIAL RATIOS FOR SELECTED INDUSTRIES, 197976
Industry
Liquidity
ratio
Profit
ratio
Leverage
ratio
BOF steel firms 1.69
Primary nonferrous metals, NEC--SIC 3339 1.86
Aluminum foundries—SIC 3361 2.15
Primary metal products, NEC—SIC 3399 2.28
Motor vehicles—SIC 3711 1.73
Petroleum refining—SIC 2911 1.36
0.11
0.22
0.22
0.24
0.17
0.26
2.28
2.32
2.84
1.69
2.44
2.56
Means from Table 9-9.
9-38
-------
TABLE 9-11. STEEL MILL PRODUCTS AND TOTAL INDUSTRIAL OUTPUT
INDEXES (1967 = 100)28 41 77 7&
Year
Steel mill products
Total industrial output
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
119.5
116.7
108.6
106.6
95.3
130.5
132.8
109.4
103.7
108.2
111.9
109.5
100.0
152.5
146.1
137.1
129.8
117.8
129.3
129.8
119.7
109.6
107.8
111. 1
106.3
100.0
9-39
-------
output index in 1974-1975 marks a recession. Steel output declined as
well during those years, but has been far slower to recover than the
overall economy.
9.1.5.3.2 Real value of output. Because of the effect of inflation,
observation of the value of industry output over time can be misleading.
Industry value of output is more meaningful when deflated to constant
dollars for some base year.
Table 9-12 presents the real value of output (deflated by the
implicit price deflator for GNP) of all establishments classified in
SIC 3312 from 1967 to 1977. The annual growth rate for real output of
SIC 3312 was 1.8 percent during the period, well below the 2.4 percent
growth rate of real GNP.
9.1.5.3.3 Steel mill products prices. The producer price index
for steel mill products is compared with the, GNP price deflator index
in Table 9-13. Steel prices increased at a rate very near the general
rate of inflation until 1973. Note that in 1973 the steel index is
only four-tenths higher than the GNP index with 1967 = 100. In 1974,
however, steel prices increased 26.8 percent over 1973 levels while
the implicit price deflator increased only 9.6 percent. Steel prices
continued to outpace inflation through 1979.
The increase in the price of steel relative to overall prices
from 1973 to 1979 can in part be attributed to an important basic
supply condition. Steel production is energy intensive. OPEC-induced
energy price increases beginning in 1974 raised the price of this
important input to production, which was in turn reflected in increased
real price of steel.
9.1.5.3.4 Investment in new plant and equipment. In 1967, new
capital expenditures by SIC 3312 firms totaled about $1.7 billion. In
1977, new capital expenditures totaled only $1.2 billion in 1967
dollars.3 In order to determine the significance of this decline, an
index has been constructed of new investment by steel firms and is
compared with an index of new investment by all industry in Table 9-14.
Real investment in new plant and equipment by all industry increased
at a continuously compounded average annual rate of 1.5 percent during
9-40
-------
TABLE 9-12. REAL VALUE OF OUTPUT FOR SIC 3312
(106 1967 $)
Year
Real value of output
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
23,487.6
23,423.5
22,157.2
28,382.8
22,679.4
18,922.7
18,081.9
23,360.0
20,319.8
20,251.8
19,620.6
9-41
-------
TABLE 9-13. STEEL PRICE INDEX AND GNP PRICE DEFLATOR
(1967 = 100)42 79 80
Year
Steel price index
GNP deflator
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
280; 4
254.4
229.9
209.8
197.2
170.0
134.1
130.4
123.0
114.3
107.4
102.5
100.0
209.1
192.2
179.0
169.2
160.7
146.6
133.7
126.4
121.4
115.5
109.6
104.4
100.0
9-42
-------
TABLE 9-14. INDEXES OF REAL NEW INVESTMENT
(1967 = 100)3 81 82
Year
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
SIC 3312
72.2
76.1
77.4
67.4
49.9
45.7
49.8
69.3
86.4
67.3
100.0
All industries
115. 9
108.6
107.0
116.9
113.8
106.7
102.1
105.9
105.2
99.1
100.0
NOTE: Investment expenditures were deflated using the GNP
implicit price deflator before indexing.
9-43
-------
the period 1967-1977. Real expenditures by firms in SIC 3312 declined
over the same period at an average annual rate of 3.3 percent.
The American Iron and Steel Institute believes the steel industry's
poor investment record is due to general economic conditions and
government policy, specifically, high inflation, excessive taxation,
and burdensome regulation, which discourage new capital formation.83
One independent observer, however, blames the poor investment record,
not on the inability of U.S. steel firms to invest, but on their
unwillingness to compete with foreign steel by investing in new, lower
cost techniques.84
9.1.5.3.5 Productivity. Productivity is meant to be a measure
of technological advance. The most common measure of productivity is
output per employee-hour. Table 9-15 compares the index of output per
employee-hour for the steel industry with that for all manufacturing
for the period 1967-1978. Output per employee-hour increased 28 percent
for all manufacturing from 1967 to 1978 while output per employee-hour
increased only 21.8 percent for the steel industry.
Increases in labor productivity are often attributed to improvements
in capital stock. To the extent it is true that more advanced capital
results in greater labor productivity, the relatively slow growth in
output per employee-hour in steel is not surprising. As mentioned in
Section 9.1.5.2.4, investment in new steel plant and equipment declined
in real terms from 1967 to 1977.
9.1.5.3.6 Exports and imports. Much is said about the declining
U.S. steel trade balance. There can be little doubt that the domestic
industry is losing importance in the world market. Table 9-16 presents
data on exports of steel mill products by domestic producers and
imports of steel mill products by domestic consumers. During the
period 1961-1979, exports of steel mill products changed very little.
Exports peaked at 6.4 million Mg in 1970. Over this period imports of
steel mill products by domestic consumers increased rapidly, at average
an annual rate of 9.5 percent. On balance, the United States was a
net importer of steel during the 1960's and 1970's. Net exports
declined at an average annual rate of 14.1 percent from 1961 to 1979.
9-44
-------
TABLE 9-15. INDEX OF OUTPUT PER EMPLOYEE-HOUR
(1967 = 100)85 86 87
Year
Steel industry
All manufacturing
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
121.8
116.0
114.5
107.6
123.5
123.5
112.7
106.2
101.3
104.0
103.5
100.0
128.0
127.2
124.2
121.2
129.3
128.3
121.5
115.2
107.9
107.4
104.7
100.0
9-45
-------
TABLE 9-16.
STEEL MILL PRODUCTS
(103 Mg)
TRADE28 41
Year
1979
1978
1977
1976
1975
1974
1973
1972
1971
1970
1969
1968
1967
1966
1965
1964
1963
1962
1961
Exports
2,556
2,197
1,817
2,407
2,678
5,291
3,675
2,606
2,564
6,405
4,743
1,968
1,528
1,564
2,264
3,122
2,017
1,826
1,813
Imports
15,889
19,169
17,511
12,956
10,895
14,485
13,741
16,037
16,602
12,121
12,729
16,290
10,390
9,753
9,417
5,841
4,940
3,719
2,869
Net exports9
• -13,333
-16,972
-15,694
-10,549 .
-8,217
-9,194
-10,066
-13,431
-14,038
-5,716
-7,986
-14,322
-8,862
-8,189
-7,153
-2,719
-2,923
-1,893
-1,056
Exports minus imports.
9-46
-------
9.1.5.4 Steel Industry Projections. The purpose of this section
is to present projected values of certain important steel industry
variables. Projection can involve much work, and is innately risky—it
involves predicting the future. The projections here were developed
by Temple, Barker and Sloane, Inc., (TBS) for the U.S. Environmental
Protection Agency.88 All projections assume a continuation of current
government policies affecting the steel industry.89
9.1.5.4.1 Steel shipments. The total shipment of domestically
produced steel mill products is perhaps the variable of most interest.
TBS, noting a post-World War II growth rate in domestic steel shipments
of 1.2 percent per year and adjusting downward for more recent trends,
projects an overall annual growth rate of 1.0 percent.90 Table 9-17
presents TBS projected steel shipments, incorporating cyclical
fluctuations.
9.1.5.4.2 Investment in new plant and equipment. TBS projects
capital expenditures for plant and equipment that add to capacity,
together with equipment that maintains "efficient" established capacity.
The industry's financial limitations in raising capital as well as its
unconstrained "needs" are taken into consideration.
The steel industry's total expenditure for capacity addition and
capacity maintenance is projected to be $18.4 billion in 1978 dollars
for the 10-year period 1981-1990. This is an average annual expenditure
of $1.8 billion in 1978 dollars. This compares with an average annual
expenditure of $2.3 billion in 1978 dollars for the period 1976-1980.92
TBS attributes this projected low capital expenditure program to a
substantial financing constraint.93
9.1.5.4.3 Projections of BOF capacity additions. Projecting BOF
capacity additions is complicated by several considerations. These
include uncertainties about steel demand in future years, the ability
of steel firms to raise capital sufficient to meet investment demands,
the rate at which existing furnaces of all types will be retired, and
the relative merits of various competing technologies. This last
consideration, concerning the future economic desirability of competing
steelmaking technologies, seems of some importance currently and is
addressed below.
9-47
-------
TABLE 9-17. PROJECTED STEEL SHIPMENTS,
1980-199091
(106 Mg)
Year
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
Shipments
77.1
82.9
88.7
90.8
91.9
94.6
94.0
94.5
98.0
98.0
96.1
9-48
-------
There seems to be general agreement that slow to moderate increases
in steel demand in the 1980"s, coupled with retirement of open hearth
steelmaking capacity during the same period, will inspire the construc-
tion of new steel furnace capacity.12 94 9S The mix of steelmaking
technologies that will comprise the new capacity is less certain.
Some disagreement exists as to whether the majority of new capacity
demand will be met by the construction of electric furnaces.
Several sources support the view that most new capacity in the
1980's will be in electric arc steelmaking. Data Resources, Inc.
(DRI) forecasts that increasing BOF steel production through 1984 will
involve utilizing existing capacity more fully rather than increasing
capacity. New electric furnace capacity, on the other hand, is expected
by DRI to be forthcoming. DRI cites the lower capital requirements
and lower operating costs of electric furnace facilities as reasons
for the forecast of slow additions to BOF capacity.94 A recent survey
of U.S. companies currently operating BOF plants lends credence to
this view. None of the firms surveyed indicated they had any current
plants to add BOF .capacity.96
The American Iron and Steel Institute does anticipate construction
of new BOF capacity in coming years. The Institute projects that by
1988 all open hearths will be retired and that the retired tonnage
capacity will be replaced half by electric capacity and half by oxygen
capacity.12
TBS has projected steelmaking capacity retirements and additions
by furnace type through 1990. Table 9-18 presents the TBS results
that are relevant to this study. Based on TBS projections, the industry
will build 6.86 million Mg of new BOF capacity from 1981-1986. Of
this projected new capacity, approximately 2.6 million Mg can be con-
sidered replacement in that this amount of currently existing BOF
capacity is projected to be retired during the. period.98
The TBS new BOF capacity projections are utilized in this report.
Several factors contribute to the selection of these projections, and
are outlined below.
9-49
-------
TABLE 9-18.
1981 - 1984
BASIC OXYGEN FURNACE CAPACITY ADDITIONS
1981-199097
(106 Mg)
1985 - 1990
1981 - 1986a
6.10
2.28 6.86
^._ ,_,.., ,_.. .
addition of 0.38 Mg a year during the
9-50
-------
First, the TBS projections are in agreement with American Iron
and Steel Institute estimates that both electric furnaces and oxygen
furnaces would replace retiring open hearths through 1988, given
sufficient funds.
Second, TBS projections rely on an important assumption which,
while not necessarily entirely correct, has some validity. TBS expects
the price of scrap steel, the primary metal input to electric steelmaking,
to increase over time as more electric furnaces are operated." While
there is disagreement over the future availability of scrap and the
extent of future price increases, there is general agreement that the
price of scrap will rise in future years.100 To the extent that steel
scrap prices do rise, the operating cost advantage of electric steel-
making relative to oxygen steelmaking will dwindle, making BOF investment
more attractive than it would be without scrap price increases.
A final reason for accepting the TBS projection of new BOF. capacity
additions involves the integrated nature of steelmaking. Open hearth
furnaces, many of which are expected to be retired by 1986, are necessarily
part of an integrated steel plant. Open hearth furnaces utilize a
largely hot metal (molten pig iron) charge. Thus, they are operated
in plants with blast furnaces which convert iron ore into molten pig
iron. These plants frequently have coke ovens as well.
An integrated steel plant with aging open hearth capacity is a
plant with several types of independently functioning but interrelated
equipment. That is, a single operation such as coking, iron making,
or steelmaking can be terminated without technologically affecting the
other operations. Termination of a single operation will, however,
eliminate or reduce the capacity of the plant as a whole to earn
surpluses over operating costs.
In an integrated plant with aging open hearth capacity, a single
replacement condition is relevant: an open hearth furnace (or shop)
is obsolete when the future savings in operating costs which can be
achieved by installing a new steel furnace (or shop) are just sufficient
to cover the installed cost and earn a normal rate of return. This
comparison must be made in terms of the integrated steel mill as a
9-51
-------
whole. The rate of return accrues from the sale of the output of the
entire plant. It is the surplus of these plant revenues over total
plant operating costs that are weighed against the installed capital
cost of the new steel furnace operation.101
A firm would not seriously consider replacing an aged open hearth
furnace with a new open hearth furnace. The operating costs of the
open hearth technology is far above that of the oxygen and the electric
furnace. At the same time, a firm owning an integrated plant with
coking and blast furnace capital in place (a "hot metal" plant) would
not necessarily view installation of electric furnaces as a viable
option:
The [electric arc furnace] is relatively inflexible in its
ability to utilize molten iron in the charge. It is essen-
tially a 100 percent cold metal user.102
Use of an electric furnace shop does not utilize the existing hot
metal capacity.
The BOF is like the open hearth in its ability to accept a largely
hot metal charge. The integrated plant can reasonably be expected to
either: (1) convert its existing open hearth shop into a BOF shop; or
(2) build a new BOF shop at the hot metal site and scrap the open
hearth shop once the replacement criterion is satisfied.
In Table 9-19, the 6.86 million Mg (7.56 million tons) of new BOF
capacity expected to be built by 1986 is expressed in terms of numbers
of BOF "shops." The 14 shops listed in Table 9-19 are the same as
those described in Chapter 6. Reading from the table for case A, for
example, the construction of two shops of the type specified in model
case A would add 5.8 million Mg (6.39 million tons) capacity. This
total is about 1 million Mg (1.1 million tons) shy of the 6.86 million
Mg projection. Given the tonnage projection, the maximum number of
BOF projects that can be expected from 1981 to 1986 is six. Six
separate additions of a single 136-Mg (150-ton) vessel to existing two
136-Mg vessel shops as specified in model case G would generate 7.8 mil-
lion Mg (8.6 million tons) of new capacity. Of course, actual
construction might well consist of a mix of two or more model types.
9-52
-------
TABLE 9-19. BASIC OXYGEN FURNACE CAPACITY ADDITIONS
BY MODEL CASE, 1981-19863
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Number of
model shops
2
3
2
3
2
5
6
2
2
3
2
2
2
3
Capacity addition
(10* Mg)
5.8
8.1
5.8
8.1
5.8
8.0
7.8
5.8
5.8
8.1 .
10.0
5.8
5.8
8.1
Projected new capacity additions total 6.86 million Mg
1981-1986.
9-53
-------
9.1.6 Small Business Impacts
The Regulatory Flexibility Act (RFA) requires consideration of
proposed regulations on small "entities." This section briefly examines
the applicability of the RFA to the proposed NSPS on BOF shops.
The guidelines for conducting a regulatory flexibility analysis
define a small business as "any business concern which is independently
owned and operated and not dominant in its field as defined by the
Small Business Administration Regulations under Section 3 of the Small
Business Act." A firm owning plants that operate basic oxygen steel-.
making furnaces is classified in SIC 3312. The Small Business
Administration has determined that any firm classified in SIC 3312
which employs less than 1,000 workers will be considered small in
regard to the Small Business Act.
It cannot be known with certainty whether new or existing companies
that might build new BOF facilities in the future would employ fewer
than 1,000 workers. It might be expected, however, that these companies
would not be much different than companies that currently own and
operate BOF facilities as regards employment. Indeed, companies that
currently own BOF facilities are among the more likely candidates to
construct new BOF shops. Thus, an examination of employment
characteristics of existing BOF operating firms is relevant.
A total of 18 independently owned businesses that now operate
basic oxygen steelmaking shops can be identified.96 103 Of this
total, the company that employed the fewest workers in 1979 employed a
total of 5,862 workers.104 Even the smallest BOF firm thus does not
qualify as a small company under the Small Business Act.
The above investigation reveals that it is not appropriate to
conduct a regulatory flexibility analysis for the proposed NSPS on BOF
shops. All firms that currently operate BOF facilities, and most
likely any that would in the future, are too large to qualify as small
businesses under the act.
9.2 ECONOMIC IMPACTS OF REGULATORY ALTERNATIVES
This section presents the estimated impacts of the regulatory
alternatives for BOPF shops. As described in Chapter 6, 14 types of
9-54
-------
model plants are used to represent typical new and modified facilities
that might be constructed by the industry in the future. For 272-Mg
vessel shops, six model plants represent greenfield facilities, four
are additions to existing facilities, one is a conversion of an exist-
ing shop to the KMS process, and one is the conversion of an open
hearth shop into a Q-BOF shop. For shops using 136-Mg vessels, one
model represents a greenfield facility and one is an addition to an
existing facility.
Three regulatory alternatives are considered. Regulatory
Alternative I is the baseline case from which impacts are computed.
Under Alternative I, primary emissions are controlled but secondary
emissions are uncontrolled. Alternative II would also control secondary
emissions using open hood collection systems. Alternative III, which
is more stringent than II, would require the use of closed hood
collection systems to control secondary emissions.
Section 9.2.1 summarizes the range of estimated maximum impacts
that could result from the NSPS alternatives and presents anticipated
impact estimates. Section 9.2.2 presents the discounted cash flows
theoretical model employed to compute both net present value and price
impacts. Section 9.2.3 presents the full range of maximum impacts on
project net present value assuming full cost absorption and the full
range of maximum price impacts assuming full cost pass-through.
Section 9.2.4 employs a refined model to compute a single set of price
impacts and associated output, employment, and import impacts for each
alternative. The issue of capital availability is addressed in
Section 9.2.5. Section 9.2.6 presents estimates of maximum total
costs of industry compliance. Finally, the impacts of achieving
baseline are discussed in Section 9.2.7.
9.2.1 Summary
Control of secondary emissions under Regulatory Alternatives II
or III imposes additional capital costs on the construction of a BOF
project and increases its annual operating cost. It is estimated that
Alternative II would increase the cost of producing steel by between
$0.16 and $1.39 per megagram. These changes represent impacts of
9-55
-------
between 0.05 percent and 0.44 percent. Alternative III would increase
average total cost by between 0.30 percent and 0.69 percent, or by
between $0.96 and $2.21 per megagram.
If the computed cost changes were exactly reflected in higher
prices, price impacts of 0.04 percent to 0.36 percent would result
under Alternative II and impacts of 0.25 percent to 0.58 percent would
result under Alternative III. These estimated price impacts would
lead to impacts on domestic steel output, domestic steel industry
employment, and steel imports. The full ranges of these impacts are
presented in Section 9.2.3.
The economic impacts that would actually result from the NSPS
depend on which projects are pursued by industry participants and the
supply and demand conditions prevalent in the market. The conclusion
of this economic analysis, which is based on the premise that model
plants A and J most closely typify future BOF construction, is that
impacts would occur as changes in the price of carbon steel, reductions
in domestic steel production, losses in employment opportunities, and
increases in steel imports.
The anticipated steel price impact of Alternative II, measured
from baseline, is $0.65 per megagram, or 0.17 percent. The anticipated
price impact of Alternative III, also from baseline, is $1.49 per
megagram, or 0.39 percent.
The demand for steel is downward sloping. Thus, the price increases
presented above are expected to reduce steel demand. It is estimated
that 1986 domestic steel production would be 297,228 Mg lower under
Alternative II than under Alternative I. This represents an impact of
0.32 percent. The 1986 impact from baseline of Alternative III is
computed to be 686,200 Mg, or 0.73 percent.
It is projected that the steel industry in 1986 under baseline
will employ 468,120 workers. Under Regulatory Alternative II, it is
estimated that there would be 0.32 percent fewer job opportunities in
1986. This represents a total of 1,498 fewer jobs. The employment
impact from baseline of Alternative III is computed to be 0.73 percent,
or 3,417 jobs. These employment impacts do not take account of possible
9-56
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employment gains that might result in other sectors of the economy.
Steel has viable substitutes in many applications, and substitution
would likely result in increased employment in those industries produc-
ing substitutes such as aluminum, plastics, and concrete. There would
also be employment gains in those industries that produce control
equipment.
The quantity of steel imported into the United States in 1986
would also be affected by the NSPS alternatives. The import impact of
Alternative II is computed to be 0.26 percent. This is the effect of
an import increase of 50,313 Mg over the baseline import projection of
19.6 million Mg. The estimated impact of Alternative III is 115,424 Mg,
or 0.59 percent, over baseline.
The estimated total cost of control capital for the industry to
comply in 1986 with Alternative II is $15.6 million. The estimated
compliance cost of Alternative III is $18.4 million. These may be
overestimates because they do not account for the estimated quantity
adjustments.
9.2.2 Methodology
9.2.2.1 The Discounted Cash Flows Approach. The economic impacts
of NSPS on BOPF are estimated using a discounted cash flows (DCF)
analysis. Under this approach, the expected future annual net revenue
flows generated by an investment in a BOF project are discounted at an
appropriate interest rate and summed to determine the net present
value of the project. This section describes the DCF theory and
methodology in some detail.
An investment is expected to generate a series of cash inflows
and outflows during its lifetime. The net cash flow in the first year
(year zero) is negative as the cash outflows of the initial investment
are not offset by any cash inflows. After the project begins produc-
tion, it will generate a stream of cash inflows in the form of revenues
from the sale of its output and depreciation of the capital equipment,
and cash outflows in the form of operating expenses. Beginning with
year one and continuing throughout the lifetime of the project, annual
cash flows are expected to be positive, but need not be. Although
9-57
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cash inflows and outflows may occur at any time, it is assumed that
they will take place at the end of the year. It is also assumed that
the only investment in the project takes place at the end of year zero
and is followed by a series of net cash inflows. These assumptions
guarantee a unique rate of return for each project.105
The cash outflow in the first year may be expressed:
(9-1)
YQ = (FCC + WC) - (TCRED • FCC)
where FCC is the principal value of the capital investment, WC is the
value of the working capital, and TCRED is the percentage of the
capital investment resulting in a direct tax savings, or tax credit,
to the firm.
The project generates its first revenues at the end of its first
year of production (year two). The net cash flows in this and suc-
ceeding years can be expressed:
Yt = (Rt - Et) (1 - T)
DtT
t = 1, . . . , N .
(9-2)
The first term in equation (9-2) represents the net after-tax inflows
of the project generated by the sales of the output. Total revenues
in year t can be expressed:
Rt =
Q)
(9-3)
where P is the per- unit price of output and Q is the quantity of
output sold during the year. Total operating costs in year t can be
expressed:
Et = (V
Q + F)
(9-4)
where V is the per-unit variable cost of production and F is the fixed
annual cost of operating the project. Variable costs include expendi-
tures on material inputs, labor and energy. Fixed costs include such
expenses as site rent (explicit or implicit), insurance, and
administrative overhead.
Only net revenues are subject to the Federal corporate income tax
(T). Thus, annual total operating cost is deducted from total revenue
9-58
-------
to yield the taxable net revenue. The firm's after-tax net revenue in
year t is thus the first term in equation (9-2).
Federal income tax lav/s allow a deduction for depreciation of the
capital equipment. This deduction reduces income tax payments and is
thus treated as a cash inflow in the second term in equation (9-2).
In this analysis, the straight-line method of capital depreciation is
assumed. Thus,
DtT = (FCC/N) - T (9-5)
where N is the project life in years.106 The salvage value of the
plant is assumed to be zero; there is no additional cash inflow in the
last year of the project's life.
The net cash flows represented by equation (9-2) occur at the end
of the first through the Nth years, where N is the life of the project.
An additional cash inflow actually occurs at the end of the Nth year
when the working capital, WC in equation (9-1), is recovered at the
end of the project. This inflow is in fact accounted for in the
analysis.
The investment project is thus represented as a cash outflow in
the first year, followed by N cash inflows and outflows in successive
years. Cash flows that occur over a future period must be discounted
by an appropriate interest rate to reflect the fact that a sum of
money received at some future date is worth less than an equal sum
received today. The discounted value of this sum received in the
future is called its present value. The discount factor is a function
of both time and the interest rate, and can be expressed:
DFt = (1 + r)
(9-6)
where DF is the discount factor for year t and r is the interest rate.
An understanding of the discount factor and the selection of an
appropriate rate of interest in practice is important. ,The interest
rate r in equation (9-6) can be viewed as the cost to the firm of
acquiring funds for the project. The firm can acquire funds in essen-
tially any combination of three ways. It can issue bonds, sell stock,
9-59
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or utilize currently held liquid assets. There is a cost associated
with each method. Interest must be paid on bonds, dividends on stock,
and there is an opportunity cost associated with utilizing internal
funds. A firm typically uses all three methods to finance a project,
and the cost of capital becomes a weighted average of all three.
The sum of the discounted cash flows from a project over its life
is the net present value (NPV) of the project. The NPV of a project
can be expressed most simply as:
(Y
DF,) -
(9.7)
where all terms have been defined above. The net present value of a
project is thus the sum of the discounted after-tax net revenues minus
the initial capital expenditure.
Future cash inflows in equation (9-7) are discounted by a factor
reflecting the weighted average cost of capital to the firm. The
decision criterion for the firm is to invest in any project with a
positive net present value. "7 ios In practic6j however> wnere a
firm's access to funds is limited, the criterion is to invest in the
project with the greatest positive net present value.
In this analysis, a steel firm considering investing in a BOF
project is assumed to invest in the project with the highest positive
net present value. Equation (9-7) can be used to calculate the net
present value of each plant under any given regulatory alternative and
to evaluate each plant type according to the decision criterion.
In Section 9.1.4.4, it is concluded that recent pricing behavior
in the domestic steel industry does not strongly support either a
monopoly or an oligopoly market structure. Increasingly, steel prices
appear to be more the result of underlying supply and demand conditions
than the result of price-setting behavior of any market participant.
Thus, in this analysis, competitive conditions are assumed to prevail.
In particular, firms are assumed to be price takers.
In this analysis, two types of impacts that could result from the
proposed NSPS on BOF facilities are estimated. Equation (9-7) is
9-60
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utilized as stated to estimate the NPV of each project under each
regulatory alternative. A different form of the same equation is used
to estimate the average total cost of EOF steel production for each
plant under each regulatory alternative. . This estimate is used in a
discussion of steel price impacts.
The NPV calculated in equation (9-7) is the sum of the discounted
after-tax net revenues from a project minus the initial capital expendi-
ture. As discussed previously, the objective of a firm is to maximize
shareholders' wealth. This is accomplished by maximizing the discounted
stream of cash flows to the stockholders. The NPV of an investment is
in fact the discounted value of cash flows from the project available
as dividends payable to stockholders. Thus, the objective of the firm
is to invest in any project with a positive NPV or, where funds are
limited, to invest in the project with the highest positive NPV.
9-2.2.2 Net Present Value Impact Methodology. In general, an
NSPS increases average total cost (ATC) of production. This can
result from additional capital costs for pollution control equipment,
increased operating costs, or both. If market demand for the project
is perfectly elastic, a situation of full cost absorption prevails--
the increase in ATC cannot be passed forward in the form of increased
product price. ATC is an expense deducted from gross revenue in
equation (9-7). Thus, the NSPS will reduce the NPV of a project if
unit price remains unchanged. In a full cost absorption situation,
the effect of an NSPS is to reduce the present value of dividends
payable to investors.
The nature of the NPV impact on a stockholder depends on whether
the stock was purchased before or after the impact was perceived by
the market as a whole. The recipients of the loss in NPV are the
owners of stock at the time the loss information becomes known. Once
it is perceived that the increased ATC resulting from the NSPS will
reduce future dividend streams, prices of outstanding stock decline
until the new, lower present value of the dividends yields the same
rate of return available on other shares of stock.109 Holders of
outstanding stock at the time this price adjustment occurs suffer a
one-time wealth loss.
9-61
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Once stock prices have adjusted downward, the dividend payments
yield the same rate of return on these shares as dividend payments on
totally unaffected stocks yield. The holders of NSPS affected stock
at the time the information is learned receive this same market rate
of return on their new, lower priced stock. Moreover, investors who
purchase BOF steel firm stock after the market has accounted for the
NSPS impact suffer neither a loss in wealth nor a loss in their rate
of return. The lower price they pay for stock compensates them for
the lower dividend payments they anticipate.
In this analysis, equation (9-7) is utilized to calculate NPV
impacts resulting from the proposed regulatory alternatives. The net
present values of relevant investment projects under Regulatory Alter-
natives II and III, which would control secondary emissions, are
compared to the NPV's of these same projects under Regulatory Alterna-
tive I, which controls only primary emissions. The loss of net present
value occurring as a result of the NSPS under a situation of full cost
absorption is interpreted as the impact on stockholders' wealth.
9-2.2.3 Steel Price Impact Methodology. An increase in the ATC
of BOF steel will be exactly reflected in higher prices in a situation
of full cost pricing. Price changes occurring in this manner result
in a market with perfectly elastic supply or perfectly inelastic
demand.
Price impacts of the proposed regulatory alternatives are calculated
assuming that the price change is exactly equal to the change in ATC.
This change in ATC is in turn calculated using a revised form of
equation (9-7), derived below. In a market situation where price
equals average total cost, the NPV of a project is equal to zero.
That is, dividend payments in excess of those required to raise capital
for the project, which themselves yield the rate r in equation (9-6),
are zero. When equation (9-2) is substituted into (9-7) and (9-7) is
set equal to zero, (9-7) can be written:
N
- Et)Cl -
DFt = Yo
(9-8)
9-62
-------
If revenues and expenses are assumed to be the same over all periods,
equation (9-8) can be written
N N
(R - E) - (1 - T) • I DF, + I D.TDF. = Y (9-9)
t=l t t=l * * °
recognizing that (1 - T) is a constant. The sum of the discount
factors as t ranges from 1 to N can be written:
N
(9-10)
F = I DFt = [1 - (1+ r)"]/r .
Substituting equations (9-5) and (9-10) into (9-9) yields:
(R - E) • (1 - T) • F + (FCC/N) • T • F = Y . (9-11)
Substituting equations (9-3) and (9-1) into (9-11) and rearranging
further:
(P • Q) - E = (FCC + WC) - (TCREO - FCC) - DSL
(1 - T) • F ^ J
where DSL = (FCC/N) • T • F and represents the present value of the
tax savings due to straight- line depreciation of the fixed capital.
Finally, Q and E can be moved to the right-hand side of (9-12) to
yield:
p. (FCC + WC) - (TCRED -FCC) - DSL , E
r (1 - T) • F - Q § '
Where P = ATC, equation (9-13) calculates average total cost. The
first term in (9-13) is per-unit capital cost including allowances for
the tax credit and depreciation, while the second term is per-unit
operating cost.
The cost per megagram of BOF steel is calculated using equation
(9-13) for each model project under each regulatory alternative.
Assuming that some or all of any additional cost resulting from a
proposed NSPS is passed forward in a higher price, price impacts are
estimable.
In Section 9.2.3.1, maximum impacts on net present value, price,
and other relevant variables are presented for all plants under each
'9-63
-------
regulatory alternative. In 9.2.3.2, an assessment is made of actual
expected impacts based on a somewhat refined model and certain
simplifying assumptions.
9-2.3 Economic Impacts of Regulatory Alternatives
This section presents ranges of maximum impact estimates for the
regulatory alternatives. Maximum impacts on net present value are
presented for the case of full cost absorption. The presented range
of impacts on steel prices, output, employment, and imports results in
a situation of full cost pricing.
Table 9-20 contains cost data for each model project under each
regulatory alternative. The costs are taken directly from tables in
Chapter 6 except that annual operating cost includes an estimate for
the value of hot metal used by the steel furnace equivalent to $223.77
per megagram of hot metal.110 The hot metal value is included as an
operating expense so that the NPV calculated by equation (9-7) is
interpretable as the NPV of the BOF project alone, not of the BOF
project plus the remainder of the integrated plant. Capital costs in
Table 9-20 are employed in the FCC term of equation (9-1) while annual
operating costs are employed in the E term in equation (9-4). ;
Table 9-21 lists the parameter values actually employed to calculate
NPV and ATC. A value of working capital equal to 10 percent of the
value of the fixed capital and a project life of 15 years are engineer-
ing estimates. The currently relevant investment tax credit and
Federal corporate tax rate are 10 percent and 46 percent, respectively.
Two separate interest rates are employed. The working average cost of
capital to the steel industry has been estimated to be 6.2 percent.111
An alternative interest rate of 10 percent is employed to investigate
the sensitivity of the estimates to this parameter. The steel price
of $383.15 per megagram is the observed June 1980 producer price for
carbon steel billets.110
In this analysis, it is assumed that while nominal prices and
interest rates are sure to fluctuate in the future, real prices and
rates will remain constant. Thus, constant 1980 dollar revenues and
expenses are employed in the analysis, along with real interest rates.
9-64
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Table 9-20. MODEL PROJECT COST DATA
(106 1980 $)
Regulatory
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Capital
cost
187.5
112.3
188.3
122.1
16.0
97.2
55.7
119.2
190.9
122.7
187.5
192.0
195.7
117.0
I
Annual
operating
cost
900.1
734.2
900.4
735.6
896.6
469.4
364.0
900.3
900.8
735.7
1,405.2
900.9
904.1
734.4
Alternative
II
Capital
cost
-
-
-
132.5
-
-
-
-
195.3
123.3
-
196.4
200.1
-
Annual
operating
cost
-
-
-
737.6
-
-
-
-
902.1
736.0
-
902.2
905.9
-
Ill
Capital
cost
200.1
122.7
202.7
-
31.0
106.7
63.3
134.3
-
-
200.1
-
-
127.4
Annual
operati ng
cost
902.8
736.3
903.5
-
899.7
471.5
365.6
903.5
-
-
1,407.9
-
-
736.4
9-65
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TABLE 9-21. MODEL PARAMETER VALUES
=
Parameter Value
Working capital (WC)
Federal investment tax credit (TCRED)
Federal corporate tax rate (T)
Project life (N)
Interest rate (r)
Steel price (P)
0.1 x FCC
0.1 x FCC
46 percent
15 years
6.2 percent and 10.0 percent
$383.15 per megagram
9-66
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9.2.3.1 Net Present Value Impacts. Recall that the NPV of a
project is the discounted present value of total revenue minus total
costs over the life of the project, where total costs include capital
recovery. The project NPV is equivalent to stockholders' wealth
attributable to the project.
The NPV of each model project under each regulatory alternative
is presented in Table 9-22. Each model has a NPV estimate under
Regulatory Alternative I, which is baseline. Only one of the two
other alternatives is relevant to a particular model project; some
table entries are accordingly left blank.
The baseline project net present values range from a low value of
$458.8 million for model G to a high value of $1,526.5 million for
model L. Thus, all projects are profitable in that they yield a
positive NPV at an interest rate of 6.2 percent.
It is evident from Table 9-22 that for each model the NPV is
lower under the relevant secondary emissions alternative than under
baseline. Project NPV's range from $853.8 million to $952.2 million
under Alternative II and from $445.4 million to $1,504.1 million under
Alternative III. The reason for this is simple: The control of
secondary emissions imposes additional capital and operating costs
while leaving the value of marketable output, and hence revenues,
unchanged. It must be remembered, however, that the plants under
Regulatory Alternatives II and III yield an additional output not
produced under baseline—reduced emissions.
Table 9-23 presents the maximum changes in NPV that could occur
from baseline primary emissions control to proposed secondary emissions
control. The loss in NPV should be interpreted as the reduction in
wealth that affected stockholders would experience if a steel firm
were to invest in a particular project meeting both the secondary and
primary standards instead of the primary standard alone. The impact
would be felt as a one-time reduction in affected stock prices.
Moving from baseline to Alternative II results in NPV losses
between $2.0 million and $17.3 million, or 0.2 and 2.0 percent.
Moving from baseline to Alternative III results in losses of NPV from
$13.3 million to $26.6 million, or 2.9 to 2.6 percent.
9-67
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TABLE 9-22. PROJECT NET PRESENT VALUES ASSUMING
6.2 PERCENT INTEREST RATE
(106 1980 $)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory Alternative
I
967.7
884.8
965.6
871.1
1,100.0
480.6
458.8
1,012.1
961.8
870.1
1,526.5
960.6
941.5
880.7
II
-
-
-
853.8
-
-
-
-
952.2
868.2
-
950.9
929.3
-
Ill
945.3
867.0
940.0
-
1,0.73.9
463.4
445.4
985.5
- '
-
1,504.1
-
-
863.4
9-68
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TABLE 9-23. NET PRESENT VALUE REDUCTIONS FROM BASELINE
ASSUMING 6.2 PERCENT INTEREST RATE
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
native
106 1980 $
-
-
-
-17.3
-
-
-
-
-9.7
-2.0
. -
-9.7
-12.2
-
AHer-
II
Percent
-
-
-
-2.0
-
-
-
-
-1.0
-0.2
-
-1.0
-1.3
-
Regulatory
native
106 1980 $
-22.4
-17.8
-25.6
-
-26.0
-17.2
-13.3
-26.6
-
-
-22.4
-
-
-17.3
Alter-
Ill
Percent
-2.3
-2.0
-2.7
-
-2.4
-3.6
-2.9
-2.6
- .
-
-1.5
-
-
-2.0
9-69
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Tables 9-24 and 9-25 present analogous NPV impacts using an
interest rate of 10.0 percent. Note that in all cases project NPV is
lower than when an interest rate of.6.2 percent is employed. This is
because the present value of future net revenues declines as the
interest rate rises. However, neither the magnitude changes nor the
percentage changes are significantly different when an interest rate
of 10.0 percent is used.
To reiterate, these estimated changes in NPV are maximum impacts.
They occur only in the extreme case of full cost absorption. The
other extreme, the case of full cost pass through, is examined in
Section 9.2.3.2.
9.2.3.2 Steel Cost Impacts. The purpose of this section is to
present NSPS impacts on the average total cost of producing steel in
each of the model plants. Equation (9-13), which is derived in Sec-
tion 9.2.2.3, is used to calculate the average (per megagram) total
cost of producing raw carbon steel in each plant type under each
alternative. The difference in the ATC of producing steel in a given
plant under the more stringent emissions control alternative is attri-
butable to the added capital and operating costs of the control equipment.
In the extreme case where the entire increase is passed forward in
higher steel prices, these changes represent maximum steel price
impacts.
The average total cost in 1980 dollars of producing 1 Mg of raw
steel in each model plant under each regulatory alternative is presented
in Table 9-26. Under Regulatory Alternative I, the total cost per
megagram of raw steel varies from a low of $309.30 for model plant G
to a high of $321.26 for model plant F. The ATC of production increases
for all model plants when secondary emissions are controlled. This is
because of the additional capital costs that must be recovered plus
the increased operating expense associated with the control equipment.
The ATC of producing steel varies from a low of $313.27 to a high of
$321.25 under Alternative II. Under Alternative III, the range in ATC
is between $311.44 and $323.48.
9-70
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TABLE 9-24. PROJECT NET PRESENT VALUES ASSUMING
•10.0 PERCENT INTEREST RATE
(106 1980 $)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory Alternative
I
727.5
677.9
725.7
664.9
869.3
360.4
352.0
777.4
722.1
664.0
1,170.8
720.9
705.0
673.6
II
-
'
-
648.9
-
-
-
-
713.5
662.3
-
712.3
694.3
-
Ill
707.1
661.6
702.3
-
845.4
344.7
339.8
753.1
-
-
1,150.4
-
-
657.7
9-71
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TABLE 9-25. NET PRESENT VALUE REDUCTIONS FROM BASELINE
ASSUMING 10.0 PERCENT INTEREST RATE
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
native
106 1980 $
-
-
-
-15.9
-
-
-
-
-8.6
-1.7
-
-8.6
-10.7
_
Alter-
II
Percent
-
-
-
-2.4
-
-
-
-
-1.2
-0.3
-
-1.2
-1.5
..
Regulatory
native
106 1980 $
-20.4
-16.3
-23.4
.
-23.9
-15.7
-12.2
-24.4
-
-
-20.4
-
-
-15. Q
Alter-
Ill
Percent
-2.8
-2.4
-3.2
-
-2.7
-4.4
-3.5
-3.1
_
_
-1.7
-
-
-1) A
9-72
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TABLE 9-26. AVERAGE TOTAL COST OF RAW STEEL ASSUMING
6.2 PERCENT INTEREST RATE
(1980 $/Mg)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory Alternative
I
318. 69
311.93
318.83
313.04
309.88
321.26
309.30
315.73
319.08
313.11
317.62
319.17
320.43
312.27
II
-
-
-
314.43
-
-
-
.
319.73
313.27
-
319.81
321.25
-
Ill
320.18
313.36
320.54
-
311. 62
323.48
311.44
317.51
-
-
318.58
-
-
313.66
9-73
-------
The ATC changes associated with moving from baseline to Regulatory
Alternative II or III are more explicity presented in Table 9-27.
Moving from baseline to Alternative II increases the ATC of producing
steel by between $0.16 and $1.39 per megagram, or by 0.05 to 0.44 per-
cent. Increases in ATC of between $0.96 and $2.21 per megagram, or
0.30 to 0.69 percent, result between baseline and Alternative III.
The ATC data presented above pertain to estimates using an interest
rate, or average cost of capital, of 6.2 percent. Analogous estimates
using a 10-percent rate are presented in Tables 9-28 and 9-29. The
ATC of steel is higher in any given situation when the rate of interest
is higher because the higher cost of borrowed funds must be recovered.
The differences, however, are slight.
The observed June 1980 producer price for carbon steel billets of
$383.15 per megagram is used in NPV equation (9-7).110 As seen in
Table 9-26, however, average total cost tends to hover around $315,
depending on the plant and regulatory alternative. It is precisely
this spread of approximately $68 per megagram between ATC and market
price that yields the positive net present values reported in
Section 9.2.3.1. •'•
An understanding of the relationship between costs, price, and
NPV is very important. In general, positive net present values are
not expected to be observed over any significant length of time.
Recall that the investment criterion is to invest in any project that
yields a positive NPV at the average cost of capital. In a competitive
market with free entry available to potential producers, new firms are
expected to drive up the prices of scarce inputs, raising costs, while
simultaneously increasing supply relative to demand, lowering market
price. The result is that NPV is driven towards zero.112
In a market where new entry is restricted, the stock market
drives up the price of stock of any firm undertaking a project with
positive net present value. The capital stock of such a firm is thus
revalued upwards. Excess profits are said to be "capitalized," and
the true cost of employing the fixed capital rises until positive NPV
is eliminated.109
9-74
-------
TABLE 9-27. AVERAGE TOTAL COST IMPACTS FROM BASELINE
ASSUMING 6.2 PERCENT INTEREST RATE
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
native
10s 1980 $
-
-
-
1.39
-
-
-
-
0.64
0.16 •
-
0.64
0.82
-
Alter-
II
Percent
-
-
-
0.44
-
-
-
-
0.20
0.05
-
0.20
0.25
-
Regulatory
native
106 1980 $
1.49
1.43
1.71
-
1.73
2.21
2.15
1.77
-
-
0.96
•-
-
1.39
Alter-
Ill
Percent
0.47
0.46
0.54
-
0.56
0.69
0.69
0.56
-
-
0.30
-
'
0.45
9-75
-------
TABLE 9-28. AVERAGE TOTAL COST OF RAW STEEL ASSUMING
10.0 PERCENT INTEREST RATE
(1980 $/Mg)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Reaulatory Alternative
I -
322.07
314. 78
322.23
315.70
310.17
324.65
311.73
317.88
322.53
315.79
319.80
322.63
323.96
314.82
II
-
-
-
317.32
'-
-
-
_
323.25
315.96
-
323.35
324.86
-
Ill
323.79
316.04
324.19
-
312.18
327.20
314. 21
319.93
-
-
320.91
-
-
316.43
9-76
-------
TABLE 9-29. AVERAGE TOTAL COST IMPACTS FROM BASELINE
ASSUMING 10.0 PERCENT INTEREST RATE
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
native
106 1980 $
-
-
-
1.62
-
-
-
-
0.72
0. 17
-
0.72
0.90
-
Alter-
II
Percent
• -
-
-
0.51
-
-
-
-
0.22
0.05
-
0.22
0.27
-
Regulatory
native
106 1980 $
1.72
1.66
1.97
-
2.01
2.55
2.48
2.05
-'
-
1.11
-
-
1.61
Alter-
Ill
Percent
0.53
0.53
0.61
-
0.65
0.78
0.80
0.64
-
-
0.35
-
-
0.51
9-77
-------
In light of this reasoning, one might suspect that the positive
net present values reported in Section 9.2.3.1 are overstated either
because the observed market price is too high, the ATC estimates are
too low, or both. It is quite possible that some of the positive net
present value results from the price consideration. Ideally, the
price used in equation (9-7) would be a market price for molten, raw
steel. The carbon steel billet price actually employed is necessarily
higher than the unknown raw steel price since the production of billets
requires some further processing. It is also likely that the fixed
capital costs employed in the model, being based on historical or
accounting costs are leading to underestimates of ATC.
9.2.3.3 Output, Employment and Imports Impacts. Estimates of
NSPS impacts on output and employment in the domestic steel industry
and on steel imports are presented in this section. Impacts are
presented for the year 1986 for all model plants assuming that the
real market price of carbon steel increases from its 1980 price of
$383.15 per megagram by an amount exactly equal to the change in ATC
resulting from the regulatory alternatives. All impacts are computed
using the estimated average cost of capital of 6.2 percent.
9.2.3.3.1 Impacts on steel output. Domestic steel shipments are
projected to total 94.0 million Mg in 1986 (see Table 9-17). If the
real price of domestic steel increases as a result of the NSPS, demand
for domestic steel would be expected to decline and industry output
would fall below the 94-million-Mg projection.
For a given model plant, the projected change in industry output
is computed by multiplying the percentage change in ATC resulting from
the relevant secondary emissions alternative reported in Table 9-27 by
an estimated own-price elasticity of demand for domestic steel of
-1.86.113 These percentage changes are then multiplied by the 94-mil-
lion-Mg projection to yield a tonnage reduction estimate. Results of
these computations are presented in Table 9-30.
It is computed that 1986 domestic steel shipments would be 90,000
to 830,000 Mg lower under Alternative II than at baseline. This
9-78
-------
TABLE 9-30. DOMESTIC STEEL SHIPMENT IMPACTS FROM
BASELINE FOR 1986a
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
native
106 Mg
-
-
-
-0.83
-
.
-
-
-0.38
-0.09
-
-0.37
-0.47
-
Alter-
II
Percent
-
-
-
-0.78
-
-
-
*
-0.35
-0.09
-
-0.35
-0.44
-
Regulatory
native
106 Mg
-0.88
-0.86
-1.01
- •
-1.05
-1.30
-1.31
-1.06
-
-
-0.56
-
-
-0.84
Alter-
Ill
Percent
-0.82
-0.80
-0.94
-
-0.98
-1.21
-1.21
-0.98
-
-
-0.53
-
-
-0.78
Average cost of capital =6.2 percent.
9-79
-------
represents a percentage reduction between 0.09 and 0.78 percent.
Under Alternative III, shipments would be 560,000 to 1,310,000 Mg
lower, or 0.53 to 1.21 percent.
9.2.3.3.2 Steel industry employment impacts. Estimated impacts
on domestic steel employment are presented in Table 9-31. They are
computed by multiplying the estimated tonnage changes in Table 9-30 by
an employment-to-output coefficient of 4,980 workers per million
megagrams.28
The impact on industry employment resulting from moving from
baseline to Alternative II ranges from a loss of 437 to 3,867 jobs.
This represents a loss of between 0.09 and 0.83 percent. The employ-
ment impact from baseline to Alternative III is between 2,362 and
6,045 jobs, or from 0.50 to 1.29 percent.
It is important to remember that these employment losses are not
layoffs. Rather, they are jobs that will not be created by 1986 that
otherwise would have been. Also, these computed losses do not take
account of any employment increases that might result in other sectors
of the economy. For example, because aluminum competes with steel,
employment increases might be expected in the aluminum industry.
Additional employment gains are expected in industries that produce
control equipment.
9.2.3.3.3 Impacts on steel imports. As the real price of domestic
steel rises relative to that for imported steel, domestic users are
expected to increase their purchases of foreign steel. It has been
estimated that a 1-percent increase in the domestic price for finished
steel results in a 1.51-percent increase in steel imports.113 This
import elasticity is multiplied by the percentage change in ATC from
Table 9-27 to compute the percentage change expected to result in
steel imports from the NSPS on BOF secondary emissions.
Steel imports increased at a continuously compounded annual rate
of 3.03 percent from 1970 to 1979 (Table 9-16). If this rate of
change continues, steel imports would total 19.6 million Mg in 1986.
The NSPS-induced percentage change in steel imports estimated as
explained above is multiplied by 19.6 million Mg to compute the import
impacts. Estimates are presented in Table 9-32.
9-80
-------
TABLE 9-31. DOMESTIC STEEL INDUSTRY EMPLOYMENT IMPACTS
FROM BASELINE FOR 1986
(Number of workers)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory
Alternative
II
'
-
-
-3,867
-
-
-
.
-1,775
-437
-1,755
-2,216
-
Regulatory
Alternative
III
-4,070
-3,997
-4,662
- •
-4,871
-6,001
-6,045
-4,889
-
-
-2,362
-
-
-3,877
9-81
-------
TABLE 9-32. STEEL IMPORT IMPACTS FROM BASELINE FOR 1986<
Model
case
A
B
C
0
E
F
G
H
J
K
L
N
0
P
Regulatory
native
106 Mg
-
-
-
0.13
-
-
- -
-
0.06
0.01
-
0.06
0.07
-
Alter-
II
Percent
-
-
-
0.67
-
-
-
-
0.30
0.08
-
0.30
0.38
-
Regulatory
native
106 Mg
0.14
0.14
0.16
-
0.17
0.20
0.21
0.17
-
-
0.09
-
-
0.13
Alter-
Ill
Percent
0.71
0.69
0.81
— if.
0.84-
1.04
1.05:';
0.85
—
—
0.46 .
-
—
0.67
9-82
-------
It is estimated that there would be from 10,000 to 130,000 Mg
more steel imported into the United States in 1986 under Alternative II
than at baseline. This represents an impact of 0.08 to 0.67 percent.
The impact of moving from baseline to Alternative III would be an
increase in imports of from 90,000 to 210,000 Mg, or 0.46 to 1.05 percent.
9.2.4 Anticipated Economic Impacts
Section 9.2.3 presented ranges of impacts on NPV assuming full
cost absorption and price and other variables assuming full cost
pricing. The purpose of this section is to present estimates of
impacts on net present value, steel price, and other relevant variables
that are considered most likely to result under the proposed alterna-
tives. The impacts that actually occur depend on a number of factors
including the types of projects actually built and the extent to which
cost increases are passed forward. This first factor is addressed in
Section 9.2.4.1, while Section 9.2.4.2 deals with the cost/price
mechanism.
9.2.4.1 Model Plant Selection. A total of 14 model.projects are
described in Chapter 6. They vary in certain respects but are all
basic oxygen process steel furnace projects. As seen in Table 9-20,
each model has associated with it a unique set of fixed capital and
annual operating costs. Accordingly, as evidenced in TabTes 9-22 and
9-26, each project has associated with it a unique net present value
and average total cost. It is thus clear that the economic impacts
that will actually result from the proposed NSPS will depend in part
on which types of facilities are actually affected.
Of the model plants investigated in this report, plants A and J
typify the project type expected to be most representative of BOF
shops to come on line over the next several years. These represent
new shops with two 272-Mg top blown vessels.
These models are considered representative of future projects for
several reasons. First, they are similar to shops recently built in
the United States. Their 272-Mg vessels are well suited to producing
high quality carbon steel. Specialty steels, on the other hand, which
9-83
-------
have sometimes been produced in the smaller 136-Mg vessels of other
model shops, are more likely to be produced in electric furnaces in
coming years.114
9-2-4-2 Estimates of Anticipated Imparts. The economic impacts
that are expected to result from the proposed regulatory alternatives
are estimated assuming that model projects A and J typify future BOF
construction through 1986. Table 9-33 has been constructed from
several tables presented earlier in this chapter.
The ATC data in Table 9-33 are a certain result of the NSPS,
given that the cost data and model parameter values are correct.' That
is, the total cost of producing a megagram of raw steel in each model
plant is sure to increase as a result of the NSPS. The impact of this
change on other relevant variables is less certain. Two extreme
results are possible. If the market price of raw steel remains totally
unchanged, the NPV of project A would decline to $945.3 million under
Alternative III and the NPV of project J would decline to $952.2 million
under Alternative II. However, if the market price of steel increases
by an amount equal to the change in ATC, the NPV of each project will
remain unchanged. A most relevant question thus becomes: What is the
mechanism linking ATC to price and .what will be the result of this
mechanism in this circumstance?
It was stated in Section 9.2.2.2 that if market demand is perfectly
elastic, added costs must be fully absorbed and a maximum NPV loss
must occur. This is not the case in the steel market, where the
estimated elasticity of demand for domestic steel is -1.86. Since the
demand for steel is not perfectly elastic, at least some part of any
increase in ATC will be reflected in higher price. This is illustrated
in Figure 9-1. The demand curve (D) is drawn downward sloping to
indicate that demand is neither perfectly elastic nor perfectly inelastic
Two supply curves are drawn for illustrative purposes. S± is perfectly
elastic and S2 is upward sloping. It is clear that whatever the shape
of the supply curve, an upward shift in supply resulting from an
increase in ATC will result in some price increase. The initial
9-84
-------
TABLE 9-33. NET PRESENT VALUE AND AVERAGE TOTAL COST
DATA FOR MODELS A AND Ja
Regulatory Alternative
Model
case
A
J
I
NPV
(106
1980 $)
967.7
961.8
ATC
(1980
$/Mg)
318. 69
319.08
II
NPV
(106
1980 $)
-
952.2
ATC
(1980
$/Mg)
-
319.73
III
NPV
(106
1980 $)
945.3
-
. ATC
(1980
$/Mg)
320.18
-
Average cost of capital =6.2 percent.
9-85
-------
Q/time
Figure 9-1. Price impacts with downward-sloping demand.
9-86
-------
market price P., is determined by the intersection of $! and D or S2
and D. An increase in ATC shifts Sj to Si, yielding market price Px.
The same change in ATC shifts S2 to S2, yielding market price P2.
Given a downward-si oping demand for steel, the extent of the impact on
price from a change in ATC is determined by the slope of the supply
curve; the more elastic supply, the greater the price impact.
The pricing model adopted for this analysis takes demand as
downward sloping—the elasticity of demand equals -1.86. The nature
of market supply assumed in the analysis is like that expounded by
W. E. G. Salter.115 At any point in time, the market supply of steel
is determined by operating costs of existing plants. A plant will
produce steel as long as market price is equal to or greater than its
average operating costs. Failure to do so would result in forgone
returns to fixed capital. The higher market price is, the more plants
there are that have average operating costs (AOC) at or below market
price, and the greater market output. The oldest producing plant with
the highest operating costs is said to be a marginal plant: market
price is equal to its AOC.
In Figure 9-2, market supply is the result of five plants (A-E)
having average operating costs at or below market price. The supply
from any given plant is perfectly elastic because factor supplies are
elastic. Plant A is a modern plant with an AOC well below market
price. Plant E is the "marginal plant": price equals (AOCV.
It has been determined that the proposed NSPS alternatives on BOF
steelmaking affect only projects that are as yet unconstructed. A
long-run supply criterion is thus relevant; the option to not build is
open to the firm. A plant will not be built unless price is equal to
or greater than average total cost. The investing firm must antici-
pate covering not only AOC, but capital costs as well, including a
normal return.
In the model described above, a plant will not be built unless
ATC ^ P. Recall from Section 9.2.3.2 that in any market, positive net
present values are short lived. In a market with unrestricted entry,
entering firms increase market output until price falls, eliminating
9-87
-------
Q/Time
Figure 9-2. Supply from existing plants.
9-88
-------
positive NPV. In a restricted entry market, positive NPV is capitalized
in higher valued capital stock. In either case the result is the
same: market price equals average total cost, properly measured.
Returning to Figure 9-2, plant A has a low AOC. Its capital,
however, is technically superior and thus highly valued. So while A
has low operating costs, it also has high capital costs. Thus, ATC. = P.
At the other extreme, plant E has inefficient capital of little value
but high operating costs. In this case, AOCE = ATC£ = P. Indeed, the
value of a piece of durable equipment, or a plant, is precisely the
present value of the revenues it generates over operating costs.
Thus, the ATC of any plant is equal to market price: NPV = 0.
It has been concluded that a project will not be undertaken until
market price equals ATC. Also, it has been shown that a necessary
result of each alternative is an increase in the ATC of steel production.
It thus follows, that the new steel facility will not be built until
the difference between market price and ATC is eliminated. This could
result from a market price increase due to increasing demand or declining
supply as older plants are retired. The difference could also disappear
over time as new technology reduces the average operating cost of a
newer generation model. In either case, a delay is expected in BOF
plant construction. Price increases are more likely than operat-
ing-cost reductions to eliminate the difference; technological advance
is relatively slow.
Table 9-34 summarizes the anticipated economic impacts of Regulatory
Alternative II. The price impact of $0.65 per megagram is a 0.17 percent
increase. There is no anticipated impact on NPV because project
construction will be delayed until the market price has increased to
cover the increase in ATC. Domestic output in 1986 would be 297,228 Mg
lower under Alternative II than at baseline, a 0.32 percent difference.
There would be a corresponding employment impact of 0.32 percent, or
1,498 jobs. Again, this employment impact estimate is a maximum.
U.S. steel users would import 50,313 Mg more foreign steel in 1986
under Alternative II than at baseline. The estimated total cost of
compliance in 1986 is $15.6 million.
9-89
-------
TABLE 9-34. SUMMARY OF ECONOMIC IMPACTS FROM BASELINE
OF REGULATORY ALTERNATIVE IIa
Price impact (1980 $/Mg) 0.65 ' (0.17%)
NPV impact
Domestic output impact (Mg) -297,228 (-0.32%)
Employment impact (jobs) . -1,498 (-0.32%)
Imports impact (Mg) 50,313 (0.26%)
Total cost of compliance (106 1980 $) 15.6
Model parameters:
Cost of capital =6.2%
Baseline price = $383.15/Mg
Baseline output = 94.0 x io6 Mg
Baseline employment = 468,120 jobs
Baseline imports = 19.6 x io6 Mg
Own-price demand elasticity = -1.86
Import elasticity = 1.51.
9-90
-------
The anticipated economic impacts of Regulatory Alternative III
are summarized in Table 9-35. BOF project construction would be
delayed until the market price of steel increased 0.39 percent, or
$1.49 per megagram. Domestic steel output in 1986 would be 686,200 Mg
lower than at baseline. There would be 3,417 fewer jobs created by
1986, a 0.73 percent impact. Imports of steel would be 115,424 Mg
higher than at baseline, an increase of 0.59 percent. The estimated
total cost of compliance is $18.4 million.
9.2.5 Capital Availability
This section investigates how the proposed regulatory alternatives
will affect the steel industry's ability to raise capital.
To begin, the capital required to build each model plant under
each regulatory alternative is compared. Table 9-36 shows capital
requirements by plant type under baseline and under the relevant
secondary emissions alternative (Alternative II or III), and the
percent change from the baseline to the stricter alternatives. Moving
from baseline to the relevant secondary emissions alternative involves
increasing capital requirements from between 0.49 percent and 93.75
percent, depending on the model project.
Particular attention should be drawn to the incremental capital
requirement for model A, since this is the project considered to be
most representative of future projects (see Section 9.2.4.1). The
incremental requirement of $12.6 million represents a 6.72 percent
increase. It is not felt that an additional capital need of this
magnitude would sufficiently impair a firm's ability to raise capital
or significantly affect its cost of doing so.
Viewed in a larger respective, incremental capital requirements
due to the NSPS on BOF's under consideration are quite small. By
1986, when three new projects of type A might be in place or under
construction, incremental capital requirements would be expected to
total 3 x $12.6 million = $37.8 million. By the same year, the steel
industry is expected to invest $3,276.6 million in new productive
capital of all types.116 The incremental requirement is only 1.2 percent
of this total.
9-91
-------
' ' " - iT^^
Price impact (1980 $/Mg)
NPV impact
Domestic output impact (Mg) -686,200
Employment impact (jobs) -3,417
Imports impact (Mg) 115,424
Total cost of compliance (106 1980 $) 18.4
a ~ --. T;~ - •— - .-...I _, ...i...i, ,.,.„..,,,, ,„__,.
Model parameters: Cost of capital =6.2%
Baseline price = $383.15/Mg
Baseline output = 94.0 x lo6 Mg
Baseline employment = 468,120 jobs
Baseline imports = 19.6 x io6 Mg
Own-price demand elasticity = -1.86
Import elasticity = 1.51.
(-0.73%)
(-0.73%)
(0.59%)
9-92
-------
TABLE 9-36. CAPITAL REQUIREMENTS OF REGULATORY ALTERNATIVES
Capital requirements
(106 1980 $)
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Regulatory Alternative
I II
187.5
112.3
188.3
122.1 132.5
16.0
97.2
55.7
119.2
190.9 195.3
122.7 123.3
187. 5
192.0 196.4
195.7 200.1
117.0
III
200.1
122.7
202.7
-
31.0
106.7
63.3
134.3
-
-
200.1
-
-
127.4
Change from baseline
(percent)
Regulatory Alternative
II III
6.72
9.26
7.65
8.52
93.75
9.77
13.64
12.67
2.30
0.49
6.72
2.29
2.25
8.89
9-93
-------
One qualification should be discussed. The NSPS on basic oxygen
steelmaking is only one of several environmental regulations affecting
the steel industry. Others include regulations on coking facilities
and on other steelmaking processes. Each is expected to impose addi-
tional capital needs on the industry. Taken together these regulations
may result in some difficulties in obtaining financing for some companies.
Even this is not certain. Table 9-37 presents the "funded-debts-to-net
working-capital" ratio (debt ratio) for several industries. Funded
debts are all obligations with maturities exceeding 1 year, including
bonds, mortgages, and term loans. These are the same instruments that
would likely be utilized to finance a new steel project. Net working
capital represents the excess of current assets over current liabilities;
it represents available liquid funds. The higher the debt ratio, the
more difficult it becomes to obtain further capital through debt
issue. A ratio in excess of 100 is ordinarily considered excessive.117
The debt ratio for the steel industry, 87.2, is a little under
the recommended maximum. It is, however, significantly higher than
the ratios for other listed industries. This may be some indication
that the steel industry has borrowed to its financially practical
limit. If this is true, as other studies have reported it is, the
imposition of regulations alternatives that require further capital
investment could be financially damaging to the industry.118
9.2.6 Total Cost of Compliance
The estimated total annualized costs to the steel industry of
complying with the regulatory alternatives are presented in Table 9-38.
The costs presented are for 1986, at which date an additional annual
capacity of 6.86 million Mg of BOF steel shops is projected to be in
place (see Section 9.1.5.4.3).
Fourteen separate estimates—one for each model plant—are computed.
The estimate for any given model is computed by multiplying the annualized
total cost of compliance for a plant of that type by the total number
of plants of that type that would have to be built to at least meet
the 6.86-million-Mg requirement. Total annualized compliance costs
for each plant are obtained from Table 8-2.
9-94
-------
TABLE 9-37. INDUSTRY DEBT RATIOS76
Industry
Debt
ratio3
Blast furnaces and steel mills--SIC 3312
Primary nonferrous metals, NEC—SIC 3339
Aluminum foundries—SIC 3361
Primary metal products, NEC—SIC 3399
Motor vehicles—SIC 3711
Petroleum refining—SIC 2911
87.2
48.4
60.6
39.5
41.8
61.2
Debt ratio =
Funded debts
Net working capital
9-95
-------
Model
case
A
B
C
D
E
F
G
H
J
K
L
N
0
P
Number of
projects
3
3
3
3
3
5
6
3
3
3
2
3
3
3
lotal annual
industry capacity
(106 Mg)
8.7
7.2
8.7
7.2
8.7
7.5
7.2
8.7
8.7
7.2
9.0
8.7
8.7
7.2
Regulatory
II
-
-
23.1
-
-
-
-
23.4
16.4
-
24.1
36.9
• _
Alternative
III
———————__«_
27.6
16.9
30.2
13.5
33.3
24.1
30.8
— t
,
19.8
^
_
10 c.
9-96
-------
As an example, consider model plant A. The annual output of
model A is 2.9 million Mg per year. To produce at least 6.86 million
Mg of steel, three plants of type A would have to be built (three
type A plants have a capacity of 3 x 2.9 million Mg = 8.7 million Mg
annually). The total annualized cost of compliance with Regulatory
Alternative III for a type A plant is $9.2 million. Thus, if the
entire 6.86 million Mg of projected new capacity took the form of the
construction of three type A plants, the total cost of compliance with
Alternative III would be 3 x $9.2 million = $27.6 million.
The total cost of compliance with Regulatory Alternative II is
estimated to be between $16.4 million and $36.9 million. For Regulatory
Alternative III, the estimates range from $13.5 million to $33.3 million.
The anticipated total costs for Alternatives II and III are
$23.4 million and $27.6 million, respectively. These are maximum
impact estimates. As seen in Table 9-19, the construction of only two
model A or J plants would nearly meet projected 1986 capacity needs.
If only two plants were constructed, total compliance costs for
Alternatives II and III would be only $15.6 million and $18.4 million,
respectively.
Under certain circumstances, the output adjustment resulting from
a proposed regulation is significant enough to reduce plant construction.
When this occurs, compliance cost estimates are revised downwards
since lower control capital expenditures are required with fewer
plants. In the case of the currently proposed NSPS alternatives for
BOF steel shops, the anticipated quantity adjustment for the more
stringent Alternative III is 686,200 Mg (see Table 9-35). This annual
output represents only one-fourth of the total output of a single
plant like A or J. It is unlikely that an anticipated quantity adjust-
ment of this magnitude would alter plant construction activity. Thus,
compliance costs would be unaffected.
9.2.7 Economic Impacts of Achieving Baseline
Throughout this analysis, Regulatory Alternative I, which includes
control of primary emissions, has been used as baseline. This section
summarizes the impacts anticipated as the result of achieving primary
control; that is, the impacts of moving from no control to baseline.
9-97
-------
TABLE 9-39.
COST DATA FOR MODEL PROJECT A
No control
(106 1980 $)
Primary
control
Change from no control
to primary control
Capital cost
Annual operating
cost
9-98
-------
TABLE 9-40. ESTIMATED IMPACTS OF MOVING FROM PRIMARY
CONTROL TO NO CONTROL
Price impact (1980 $/Mg)
NPV impact
Domestic output impact (Mg)
Employment impact (jobs)
Imports impact (Mg)
Total cost of compliance (106 1980 $)
-2.03
-
926,652
4,615
156,859
-16.1
(-0.53%)
-
(0.99%)
(0. 99%) |
(-0.80%)
(-100.00%)
9-99
-------
Recall from Section 9.2.4.1 that BOF projects like those described
by models A and J are most likely to come on line in the next several
years. For estimation of primary control impacts, model J can also be
eliminated since when controlling primary emissions alone it is less
costly to use a closed hood collection system. Thus, these impact
estimates are based on data for model plant A.
Table 9-39 presents cost data for model A with and without primary
control equipment. Capital costs increase by $17.9 million, or 10.55 per-
cent. Annual operating costs increase 0.40 percent from $896.5 million
to $900.1 million.
The regulations requiring control of primary BOF shop emissions
have been in force for some time. It is thus felt that the current
market price of carbon steel and projections of such variables as
output, employment and imports account for these control costs. For
this reason, the impacts reported in Table 9-40 require a special
interpretation. The price impact of $2.03 per megagram is the additional
price per megagram currently being paid for carbon steel as a result
of primary control. This is an impact of 0.53 percent. Projected
1986 output would be 926,652 Mg higher in the absence of primary
control. Accordingly, projected employment in 1986 would be higher by
4,615 jobs. U.S. steel users would purchase 156,859 Mg less of foreign
steel if domestic producers were uncontrolled. Finally, the total
cost of compliance with the primary standards is an estimated $16.1 mil-
lion for 1986. '
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-------
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63.
64.
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68.
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70.
71.
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79.
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Copeland, Thomas E., and Weston, J. Fred. Financial Theory and Cor-
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Ammer, Christine, and Ammer, Dean S. Dictionary of Business and
Economics. New York, The Free Press, 1977. p. 138.
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Moody1s Industrial Manual. New York, Moody's Investors Service,
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Jones, Charles P. Ratio Techniques of Financial Analysis.
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Reference 27, p. 19.
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9-104
-------
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81.
82.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
Reference 77, p. 15.
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of Labor Statistics, 1975. Washington, D.C., U.S. Government
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of Proposed Effluent Limitations Guidelines, and Pretreatment
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68-01-6102. December 1980.
Reference 88, p. VIII-1.
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Reference 88, Exhibit 10.
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9-105
-------
99. Reference 88, p. II-9.
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April 24, 1981. pp. 25, 28.
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1977. Washington, D.C., American Iron and Steel Institute 1977
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Englewood Cliffs, N.J., Prentice-Hall, Inc., 1978. pp. 220-223.
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N.C. , Research Triangle Institute. RTI working paper. 1981. '
109. Kamerschen, David R. , and Valentine, Lloyd M. Intermediate
Microeconomic Theory. Cincinnati, South-Western Publishing Co
1977. pp. 452-453. ' '
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Prices and Price Indexes. Washington, D.C. , U.S. Government
Printing Office, August 1980. p. 32.
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112. Reference 59, pp. 120-121.
113. Bingham, T. , et al. Economic Impact of Air Quality Regulations
on_Steelmaking: Coke Oven By-Product Plant NESHAP. Research
Triangle Park, N.C. , Research Triangle Institute. June 1981
p. 9-54.
114. Revised Standards for Basic Oxygen Process Furnaces— Background
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?;«;' Research Triangle Institute. Preliminary Draft. November
1980. pp. 6-1 - 6-3.
9-106
-------
115. Reference 101, pp. 74-77.
116. Reference 88, Exhibit 7.
117. Reference 72, pp. 2-3.
118. Reference 88, Chapter VI.
9-107
-------
-------
APPENDIX A
EVOLUTION OF THE PROPOSED STANDARDS
As required by the Clean Air Act, a review of the Standards of
Performance for New Stationary Sources—Iron and Steel Plants/Basic
Oxygen Furnaces was performed in 1978. This review concluded that
there should be no change in the primary emission control level speci-
fied in the current NSPS. A recommendation was made to evaluate
fugitive emission control systems with the intent of incorporating
fugitive emissions in the BOPF NSPS at some future date. Also, a
recommendation was made to clarify the period of time during which
sampling should be done for determining compliance with the primary
emission standard.
In November 1978, Brief Number 78-1534 was filed in the U.S.
Court of Appeals for the District of Columbia Circuit by the Group
Against Smog and Pollution, Incorporated; Natural Resources Defense
Council, Incorporated; and Friends of the Earth, Incorporated. The
intent of the brief was to force consideration of an NSPS for BOPF
fugitive emission sources. The U.S. Environmental Protection Agency
filed a brief in response on December 15, 1978. After reply briefs by
both petitioners and respondent, the Department of Justice sent a
letter dated October 1, 1979, to the Circuit Court. In this letter,
the U.S. EPA agreed to work towards an NSPS for proposal in April
1981.
Subsequent events that have occurred in the development of
background information are presented below in chronological order.
Date Activity
Initial project meeting.
July 6, 1979
December 2, 1979
Plant visit to Kaiser Steel to observe and
discuss BOPF secondary emission control
system.
A-l
-------
December 11, 1979
December 12, 1979
January 25, 1980
February 1, 1980
February 5, 1980
February 26-
March 3, 1980
March 4, 1980
April 7-11, 1980
April 22, 23, 1980
May 12-16, 1980
May 21, 1980
June 2-6, 1980
Plant visit to Republic Steel's Cleveland
plant to observe and discuss the BOPF
secondary emission control system.
Plant visit to Republic Steel's South Chicago
plant to observe and discuss the Q-BOP
secondary emission control system.
Plant visit to Armco Steel's Ashland, Kentucky,
plant to observe and discuss hot metal desul-
furization emission control system.
Plant visit to Inland Steel's East Chicago
plant to observe and discuss the No. 2 BOPF
shop secondary emission control systems.
Don R, Goodwin, Director of Emission Standards
and Engineering Division, met with Frances
Dubrowski, attorney for the Natural Resources
Defense Council, for briefing on project
plans for revision of BOPF standards.
Plant visit to Kaiser Steel to make visible
emission observations on torpedo car
desulfurization facility.
A meeting between AISI Environmental Quality
subcommittee, EPA Emission Standards and
Engineering Division, and EPA contractor to
discuss project status.
Plant visit to Kaiser Steel to make visible
emissions observations on BOPF shop secondary
emission sources.
Plant visit to Armco Steel's Ashland, Kentucky,
plant to make visible emissions observations
on torpedo car desulfurization facility.
Plant visit to Inland Steel's East Chicago
Plant to make visible emissions observations
in the No. 2 and No. 4 BOPF shops.
Plant visit to Bethlehem Steel's Bethlehem
plant to observe and discuss BOPF charging
and tapping emission controls.
Plant visit to Republic Steel's South Chicago
plant to make visible emissions observations
at their Q-BOP shop.
A-2
-------
June 10-13, 1980
June 23-26, 1980
December 3, 1980
December 16, 1980
January 13, 1981
January 15, 1981
April 9, 1981
May 11-27, 1981
November 12, 1981
February 1982
Plant visit to Republic Steel's Cleveland
plant to make visible emissions observations
at their BOPF secondary emission sources.
Plant visit to Bethlehem Steel's Bethlehem
plant to make visible emission observations
at the BOPF open hood secondary emission
control system.
Presentation of proposed standards to National
Air Pollution Control Techniques Advisory
Committee.
Presentation of proposed standards to EPA
working group committee.
Plant visit to CF&I BOPF shop in Pueblo,
Colorado, to observe and discuss secondary
emission control systems.
Plant visit to U.S. Steel Q-BOP shop at
Fairfield, Alabama, to observe and discuss
secondary emissions control systems.
Plant visit to J and L Steel BOPF shop at
Aliquippa, Pennsylvania, to observe and
discuss secondary emission control systems
and operating practices.
Plant_visit to U.S. Steel Q-BOP shop at
Fairfield, Alabama, to participate in emission
test and to observe the operation of secondary
emission control equipment.
Action memorandum, Preamble and Background
Information Document submitted to Steering
Committee.
Action memorandum, Preamble and Background
Information Document submitted for Assistant
Administrator concurrence.
A-3
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
Table B-l lists the locations in this document of certain
information pertaining to environmental impact, as outlined in Agency
guidelines (39 FR 37419, October 21, 1974).
B-l
-------
TABLE B-l. LOCATIONS OF INFORMATION CONCERNING ENVIRONMENTAL
IMPACT WITHIN THE BACKGROUND INFORMATION DOCUMENT
Agency guidelines for preparing
regulatory action environmental
impact statements (39 FR 37419,
October 21, 1974)
Location within the Background
Information Document
Background and summary of
regulatory alternatives
Statutory basis for proposing
standards
Relationships to other regulatory
agency actions
Industry affected by the regulatory
alternatives
Specific processes affected by
the regulatory alternatives
Chapter 6, Section 6.2
Chapter 2, Section 2.1
Chapters 3, 7, and 8
Chapter 3, Section 3.1, and
Chapter 9, Section 9.1
Chapter 3, Section 3.2
Chapter 4, Section 4.2
B-2
-------
APPENDIX C
SUMMARY OF TEST DATA
The data summaries presented in this section are drawn from the
reports of tests conducted at the 10 BOPF shops listed in Table C-l.
General descriptions of top blown and bottom blown furnace steel making
processes are presented in Chapter 3. The steelmaking processes in
the test plants do not deviate significantly from the general descrip-
tions. Brief descriptions of the test plants and the control equipment
tested are presented below.
C.I KAISER STEEL, FONTANA, CALIFORNIA
The new (number 2) BOPF shop at Kaiser Steel, Fontana, California,
is equipped with two 230-ton top blown furnaces. Each furnace is
housed in a complete enclosure designed by Pennsylvania Engineering
Corporation. The primary emission control system consists of closed
hoods exhausted to separate scrubbers. The primary system exhaust
rate during charging, tapping, and turndown is 3,540 ms/min (125,000 scfm).
The draft is reduced to 2,266 mVmin (80,000 scfm) during the oxygen
blow.
Emissions from the BOPF during the oxygen blow are drawn through
a two-stage venturi scrubber and demister manufactured by Baumco GMBH,
Essen, West Germany. The first stage of the scrubber is the quencher,
which has a fixed throat area and a relatively low pressure drop. The
second stage has a variable throat area and a high pressure drop of
around 70 to 90 in H20.
The secondary emission control system consists of a single baghouse
serving local hoods at the hot metal transfer and skimming stations
and also serves charging and tapping hoods within the furnace enclosures.
The baghouse is a 12-compartment (2 cells each), positive pressure
installation with 33,400 m2 (360,058 ft2) of gross cloth area. The
C-l
-------
TABLE C-l. PLANT AND TEST METHOD SUMMARY
BOPF DATA BASE
Emissions
Plant tested
Kaiser Steel ,
Fontana, CA1
Republic Steel,
S. Chicago, IL2 3
Bethlehem Steel ,
Bethlehem, PA4
J&L Aliquippa
Aliquippa, PA5
ARMCO Steel,
Middletown, OH6
U.S. Steel,
Fairfield, AL7 8
U.S. Steel, South Works
Chicago, IL9
CF&I,
Pueblo, CO10
Republic Steel
Buffalo, NY11
Youngstown Sheet and Tube
Indiana Harbor, IN12
Primary
Secondary
Secondary
Secondary
Secondary
Primary
Primary
Primary
Primary
Primary
Primary
Reference
test
Type of test method
Parti cul ate loading
Visible emissions
Visible emissions
Visible emissions
Visible emissions
Parti cul ate loading
Parti cul ate loading
Parti cul ate loading
Parti cul ate loading
Parti cul ate loading
Parti cul ate loading
5
9
9
9
9
5
5
5
5
5
5
C-2
-------
gross air-to-cloth ratio is 0.533:1 m/min (1.75:1 ft/min) with a net
air-to-cloth ratio of 0.610:1 m/min (2.0:1 ft/min) when three cells
are offline. Bag fabric is fiberglass treated with silicon, graphite,
and teflon. Bag cleaning is performed by a reverse air system.
The facility is equipped with two fans, each rated at 535,000 mVhr
(315,000 acfm) at 5 mm of water column and 230° C (450° F). Both fans
operate to provide the baghouse design flow of 283 acms (600,000 acfm).
Dampers are used to reduce gas flow and energy consumption when full
system flow is not required. Air flow is divided among the various
secondary hoods according to the needs for each operation. The opera-
tions permitted to occur simultaneously depend on whether one or both
furnace vessels are being used. Based on design information, hot
metal charging requires the largest air flow, or about three-quarters
of system capacity. The Kaiser system does not permit hot metal
transfer, hot metal skimming, or a hot metal charge to the other
vessel while one vessel is being charged. The system does permit
oxygen blow, turndown, tapping, or deslagging on the second vessel
when one vessel is being charged.
Hot metal transfer or hot metal skimming may occur at any time
that neither furnace is being charged. About one-third system flow
capacity is required for hot metal transfer or skimming.
The visible emission tests and the particulate tests performed at
this facility were conducted in accordance with EPA Reference Methods 5
and 9, respectively.
C.2 REPUBLIC STEEL, S. CHICAGO WORKS, ILLINOIS
This shop is equipped with two bottom blown vessels which have a
capacity of 205 Mg (225 tons) each. The secondary emission system at
this plant includes full-furnace enclosures with charging hoods at the
front of each enclosure. There are no tapping hoods, and neither hot
metal transfer emissions nor hot metal skimming emissions are ducted
to this system.
Draft for the charging hood at the Republic plant is obtained
from the primary fume control system. Each furnace has its own primary
gas cleaning system; however, a crossover duct between the two furnaces
C-3
-------
permits the system for the nonoperating furnace to be used for secondary
emission control of the operating furnace. With both gas cleaning
system fans drafting the charging hood, the flow rate is about 176 acms
at 93° C (373,000 acfm at 200° F) during hot metal charging. During
the oxygen blow, the charging hood is drafted continuously through the
scrubbing system of the nonoperating vessel. During turndown and
tapping, the charging hood is drafted by the scrubbing system of the
nonoperating vessel. Fume capture during these latter operations is
assisted by drafting the primary hood as well. Fumes captured in the
secondary (charging) hood bypass the quencher and pass directly to the
venturi in the scrubbing system. The design pressure drop of the
venturi during furnace charging is 218 cm (86 in) of water column.
The visible emission tests conducted at this plant were performed in
accordance with EPA Reference Method 9.
C.3 BETHLEHEM STEEL, BETHLEHEM, PENNSYLVANIA
The BOPF shop at Bethlehem Steel, Bethlehem, Pennsylvania, contains
two top blown furnaces rated at 272 Mg (300 tons) each. These furnaces
are equipped with open primary hoods which also serve, along with
careful work practices, as the control system for secondary furnace
emissions.
Each furnace is partially enclosed with side walls, with the
charging and tapping sides of the facility remaining open. An awning-
like extension has been added to the tapping side of each furnace at
the level of the primary hood. This structure acts as a flanged
extension of the primary hood and serves to direct the tapping emissions
to the hood face. Fugitive charging emissions are minimized by good
work practices, which consist of pouring the hot metal slowly and
keeping the furnace vessels as upright as possible so that the majority
of the emissions are captured by the primary system. As the ladle is
emptied, the vessel must be tipped out from under the hood, and it is
during this final portion of the charge that some fumes escape.
During the charging and tapping, the primary emission control system
is evacuated at the rate of 236 acms at 82° C (500,000 acfm at 180° F).
During the oxygen blow, this rate is increased to 353 acms at 210° C
C-4
-------
(750,000 acfm at 420° F). Gas cleaning is accomplished with an
electrostatic precipitator (ESP). The visible emission tests performed
at this plant were performed in accordance with EPA Reference Method 9.
C.4 JONES AND LAUGHLIN STEEL, ALIQUIPPA, PENNSYLVANIA
The Jones and Laugh!in (J&L) Aliquippa BOPF shop has three furnace
vessels with nominal capacities of 188 Mg (207 tons) each. The oxygen
blowing rate is about 680 mVmin (24,000 ftVmin). The plant is
normally operated with two vessels in service which can be blown
simultaneously if desired. On an average day with two furnaces in
operation, the shop can produce 55 heats of steel; on some days, the
production rate runs as high as 61 heats per day.
The gas capture and cleaning system for the shop consists of
open, complete combustion primary hoods above each furnace, an evapora-
tion chamber for each furnace, downcomers to a common manifold and
damper arrangement, two ESP's, an outlet manifold leading to a draft
arrangement with seven fans, and two discharge stacks. The furnace is
enclosed on two sides and at the rear (tapping side). While the
oxygen blow is in progress, the front or charging side of the furnace
may be partially enclosed by means of a curtain mounted on a trolley
rail. The curtain can be moved in front of the furnace or away from
the furnace as need dictates during the furnace cycle. Curtains have
been hung underneath the furnace operating floor to restrict air
movement into the partial furnace enclosure from the teeming ladle car
side. The design of the evaporation chamber includes provision for
steam or water injection to achieve the correct moisture level in the
waste gas for proper precipitation.
The damper arrangement provides for isolating the hood at the
furnace on which maintenance needs to be done. This prevents wasting
the available draft on nonoperating furnaces. Gas flow from the
combustion hoods is controlled by louvered dampers between the down-
comers and precipitator inlets.
Two precipitators remove particulates from the waste gas streams.
Each precipitator has its own stack. One precipitator was built by
Western Precipitation and consists of six chambers with five fields
C-5
-------
per chamber. The total collection surface available in this precipitator
is 26,648 m2 (286,848 ft2). The second precipitator was built by
Research Cottrell. It consists of eight chambers with five fields in
the direction of gas flow. The total collection surface area in this
precipitator is 44,146 m2 (475,200 ft2). With two furnaces in operation,
the normal practice is to use six of the eight chambers in the Research
Cottrell precipitator with one furnace and the remaining two chambers
plus all of the chambers of the Western ESP with the other furnace.
The design of the precipitators1 damper system is such that a single
chamber of a precipitator can be taken out of service for maintenance
while the other chambers remain in use.
The seven induced draft fans are normally divided up four and
three between the two precipitators. However, the damper arrangement
permits the center fan to be used with either of the two precipitators,
depending upon the draft needs and whether one of the other fans is
out of service for maintenance. There is sufficient draft so that
with only six fans the furnaces can continue to operate at full
production.
To improve precipitator performance, water conditioning sprays
are used to add moisture to the gas stream during the oxygen blowing
cycle. Because the flue gas temperature is too low at the beginning
of the blowing cycle to evaporate a sufficient amount of water, steam
is injected. Steam injection is used during the hot metal charging
operation and tapping operations. Steam injection during hot metal
charging of the furnace is controlled by a timer and lasts approxi-
mately 2 min. The .crane operator is not supposed to begin pouring hot
metal until he hears the steam turned on. Steam injection at the
beginning of the oxygen blow is also controlled by a timer. The steam
is turned on as the oxygen lance is lowered into the furnace and
continues to flow for about 1% min into the blowing period. Steam
injection is practiced for approximately 15 min per furnace cycle.
The steam injection rate is approximately 80,000 Ib/hr for the duration
of the injection period.
C-6
-------
A water ring and water sprays are used to reduce fugitive emissions
from the hood during furnace puffing. A water ring is placed on the
oxygen lance, and water sprays are placed around the lance hole in the
hood. The water ring is a proprietary design of Republic Steel. The
function of the water ring and sprays is to partially cool the gases
leaving the furnace, especially during periods of puffing, to reduce
gas volume and to avoid exceeding the capacity of the system to withdraw
these gases. The purpose of the water spray around the lance hole is
to reduce fume leakage from the lance hole opening.
To avoid fugitive discharges from the flux chute, a flapper valve
has been installed in the chute. It allows flux materials to fall
through, but closes to prevent fumes from rising up through the chute
at other times.
The visible emission tests performed at this facility were conducted
in accordance with EPA Reference Method 9.
C.5 ARMCO, MIDDLETOWN, OHIO
The BOPF shop contains two furnace vessels, each having a capacity
of 190 Mg (210 tons). Each vessel is equipped with a closed hood
primary emission control system ducted to separate venturi scrubbers.
During the 1972 tests, the exhaust rate (inferred from the stack flow
rate) ranged from 905 mVmin (31,996 dscfm) to 1,381 mVmin (48,787 dscfm).
At the time these tests were performed, there was no secondary emission
control system in place.
The tests performed on this system were conducted in accordance
with EPA Reference Method 5.
C.6 U.S. STEEL, FAIRFIELD, ALABAMA
The U.S. Steel plant at Fairfield, Alabama, is equipped with
three 200-ton bottom blown furnaces (Q-BOP's). The primary emission
control system for each furnace consists of a suppressed combustion
hood ducted to a venturi quencher where the gas is cooled and some of
the particulate material is removed. The final cleaning is accomplished
with a venturi scrubber, after which the gas stream passes through a
demister and into the exhaust stack where the CO gas is burned with a
flare.
C-7
-------
The exhaust rate design value for the primary system is 5,038 mVmin
at 71° C (177,900 acfm at 160° F). The design pressure drop for the
quencher is 2.5 kPa (10 in H20) while the venturi scrubber is designed
to operate at a pressure drop of 13.7 kPa (55 in H20). In actual
practice, however, the scrubber is operated in the range of 15 to
17 kPa (60 to 70 in H20).
The particulate emissions tests performed at this facility were
conducted in strict accordance with EPA Reference Method 5.
C.7 U.S. STEEL, SOUTH WORKS, CHICAGO, ILLINOIS
This plant contains three top blown vessels designated "H", "J",
and "K" with design capacities of 180 Mg (200 tons) each. When the
test was conducted in 1977, there were no secondary emission controls
in place on the furnaces. The primary emission control system consisted
of open primary hoods ducted to a common manifold. The manifold lead
to a single prescrubber where some of the particulate was removed from
the offgas. The single duct leaving the prescrubber branched into
three separate ducts, each of which served as an independent scrubber.
The total gas flow for the system was 11,385 nrVmin (402,000 scfm).
During the tests, the individual scrubbers, designated "A," "B," and
11 C" handled 3,741; 4,070; and 3,551 mVmin (132,100; 143,700; and
125,400 scfm), respectively.
The tests performed at this facility were conducted in accordance
with EPA Reference Method 5.
C.8 CF&I CORPORATION, PUEBLO, COLORADO
This BOF shop is equipped with two top blown furnaces with design
capacities of 110 Mg (120 tons) each. The furnaces are equipped with
both primary and secondary emission control systems. The secondary
controls consist of local charging hoods and large scavenger hoods
located at the roof monitor level of the shop.
The primary emission control system was the subject of the tests
in this volume. This system consists of open, complete combustion
hoods vented to a dropout chamber and ultimately to a four-unit ESP.
Each precipitator was equipped with a knife-edge damper, so that any
unit could be isolated at any given time.
C-8
-------
The testing conducted at this site was done in accordance with
EPA Reference Method 5.
C.9 REPUBLIC STEEL, BUFFALO, NEW YORK
This plant has two 120-Mg (130-ton) furnaces equipped with open,
complete combustion primary hoods and EPS's. More detailed descriptions
of the plant are not available. Testing conducted at this plant was
done in accordance with EPA Reference Method 5.
C.10 YOUNGSTOWN SHEET AND TUBE, INDIANA HARBOR, INDIANA
The Youngstown Sheet and Tube BOPF shop has two vessels with
.design capacities of 240 Mg (265 tons) of steel each. Heats as large
as 259 Mg (285 tons) have been achieved on a regular basis. At the
time the test was conducted, scrap preheating was practiced.
The furnaces are not equipped with secondary emission control
systems. Primary emissions are captured with open, complete combustion
hoods. The captured emissions are ducted to a quench chamber where 11
banks of water sprays can be actuated to cool and condition the gas.
Steam is also added to the offgas at a rate of 60,000 Ib/hr at 480° F
but is shut off as soon as the third bank of spray is actuated. The
quenched gases pass into a dropout chamber where large particulates
are removed. Final gas cleaning is achieved with four ESP's composed
of two chambers each. In normal operation, only seven chambers are
used; the eighth chamber is held in reserve. Total gas volume for the
system is 36,391 mVmin at 315° C (1.3 million ftVmin at 600° F).
The tests conducted at this plant were performed in accordance with
EPA Reference Method 5.
C-9
-------
TABLE C-2. KAISER STEEL, FONTANA, CALIFORNIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES1
Date
4/7/80
4/8/80
4/9/80
4/10/80
4/11/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
Maximum
Observer 1
10.4
2.1
14.2
10.3
5.0
12.5
7.1
7.9
3.3
0.0
8.3
0.0
0.0
0.0
17.1
0.0
0.0
5.0
7.9
15.0
0.0
average
Observer 2
5.4
2.5
13.8
10.4
5.4
16.3
5.8
5.4
3.3
0.8
6.3
0.0
0.0
0.0
13.3
0.0
0.0
5.4
6.7
0.0
0.0
Second
highest average
Observer 1 Observer 2
4.2
0.0
10.0
0.0
3.3
2.9
3.3
1.3
0.0
0.0
0.0
0.0
0.0
0.0
0.4
0.0
0.0
3.3
0.0
0.0
0.0
4.2
0.0
10.4
10.4
3.8
1.7
3.8
0.8
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
C-10
-------
TABLE C-3. REPUBLIC STEEL, SOUTH CHICAGO, ILLINOIS
Q-BOP ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES2
Maximum average
Second
highest average
Third
highest average
Date Run
6/18/79 1
2
3
4
5
6/19/79 6
7
8
9
10
11
6/20/79 12
13
14
15
16
17
18
6/21/79 19
20
21
22
23
24
25
6/22/79 26
27
Observer
1 2
—
—
12.5
16.7
10.8
2.3
2.5
3.8
10.8
15.8
0.8
4.6
3.8
11.3
8.8
60.4
27.5
22.5
10.0
5.0
6.7
5.0
30.8
45.4
46.3
33.8
38.8
44.6
23.8
11.7
5.0
9.6
2.9
0.0
8.8
0.8
2.5
2.9
2.1
3.8
4.2
1.3
5.0
12.5
4.2
0.8
1.7
3.3
18.3
13.8
Observer
1 2
—
—
12.5
6.3
5.4
0.4
0.0
1.3
2.9 ,
5.8
0.8
3.8
1.7
8.8
5.8
34.2
26.3
6.7
2.5
1.3
1.3
4.6
21.7
20.8
42.5
32.1
24.2
20.4
22.5
11.3
3.3
0.0
0.8
0.0
5.8
0.0
2.1
2.1
0.8
0.0
0.4
1.3
—
1.7
6.3
3.3
0.4
0.8
2.9
9.2
13.3
Observer
1 2
—
—
11.3
5.0
2.1
0.4
0.0
1.3
2.1
3.8
0.4
1.7
0.4
5.4
1.7
11.3
2.1
6.3
2.1
0.0
0.8
4.2
12.9
12.5
27.5
29.2
22.9
8.8
,18.8
10.4
2.9
0.0
0.0
0.0
5.4
0.0
1.3
0.4
0.4
0.0
0.4
0.0
0.8
5.4
1.7
0.0
0.4
0.4
3.8
12.9
Tested by GCA Corporation.
C-ll
-------
TABLE C-4. REPUBLIC STEEL, SOUTH CHICAGO, ILLINOIS
Q-BOP ROOF MONITOR OPACITY OBSERVATIONS3
3-MINUTE AVERAGES3
Maximum average
Second
highest average
Third
highest average
Date
6/2/80
6/3/80
6/4/80
6/5/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
Observer
1 2
29.6
5.8
40.0
35.0
17.1
29.2
9.6
12.1
9.2
1.3
23.3
59.2
42.1
40.8
27.5
4.6
37.9
28.8
46,3
32.1
7.9
10.8
5.8
2.1
23.3
41.7
32.1
43.8
28.8
Observer
1 2
5.0
2.5
14.2
23.3
8.3
24.6
3.8
8.3
5.8
0.8
7.5
37.5
8.3
39.6
22.1
3.3
14.6
25.8
14.6
21.7
1.7
7.1
4.6
1.7
8.8
19.2
5.0
36.3
14.6
Observer
1 2
3.3
0.8
14.2
21.3
4.6
21.7
3.3
7.9
5.0
0.0
0.0
16.7
7.1
30.0
14.6
0.8
12.9
17.1
11.7
17.5
1.7
2.5
4.6
0.8
0.8
14.6
4.6
15.8
8.3
Tested by Clayton Environmental Consultants.
C-12
-------
TABLE C-5. BETHLEHEM STEEL, BETHLEHEM, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES4
Date
6/23/80
6/25/80
6/26/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
Maximum
Observer 1
0.83
3.75
0.0
0.0
0.0
0.0
6.67
0.0
0.0
1.25
5.0
0.83
average
Observer 2
1.25
2.50
0.0
0.0
0.42
0.42
5.83
0.0
0.0
0.42
3.33
1.25
Second highest
average
Observer 1 Observer. 2
0.83
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
3.75
0.0
0.42
0.0
0.0
0.0
n n
\j • \J
0.0
0.0
0.0
n n
\J * \J
0.0
1.67
0.42
C-13
-------
TABLE C-6. J&L STEEL* ALIQUIPPA, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES5
Date
10/6/80
10/7/80
10/8/80
10/9/80
10/10/80
10/13/80
10/14/80
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
No. 2 furnace
Maximum average
3.8
3.3
5.0
2.1
0.0
0.0
0.0
5.0
1.3
5.8
9.6
3.3
6.7
5.8
11.7
11.3
1.3
10.4
2.1
0.8
2.1
2.1
1.7
2.1
11.7
2.1
5.0
4.2
2.9
4.2
4.6
Second
highest average
3.3
2.1
1.7
0.4
0.0
0.0
0 0
\J t \J
1.7
0.0
4.2
5.0
2 1
C, • 1
5.8
0.0
3.3
2.5
0.0
8.3
1.3
0.4
0.4
0 0
\J • \J
1.7
0.0
5.4
0.0
1.7
3.8
2.5
2.5
4.2
C-14
-------
TABLE C-7. J&L STEEL, ALIQUIPPA, PENNSYLVANIA
ROOF MONITOR OPACITY OBSERVATIONS
3-MINUTE AVERAGES5
Date
10/6/80
10/7/80
10/8/80
10/9/80
10/10/80
10/13/80
10/14/80
•
Run
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
No. 3 furnace
Maximum average
2.1
0.0
1.7
2.1
0.0
0.0
0.0
5.0
5.8
5.0
9.6
3.3
2.1
0.4
5.8
11.7
2.5
7.1
1.3
2.1
2.1
1.7
2.1
11.7
5.4
0.8
2.1
1.7
4.2
4.2
4.6
5.4
Second
highest average
0 8
W 4 W
0.0
0.8
0.4
0.0
0.0
0.0
1.7
4.2
4.6
4.6
3 3
*J * O
1.3
0.4
2.1
3.3 ,
2.5
0 8
\J t \j
0.0
0.8
0 0
w • \J
1.7
0.0
0.0
2. 1
0.0
0.0
1.3
3.8
2.9
3.8
4.6
C-15
-------
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-------
TABLE Oil. UNITED STATES STEEL, FAIRFIELD, ALABAMA
CANOPY HOOD AND SOUTH MIXER BAGHOUSE
Time
Date
Observer:
5/11/81
5/12/81
5/13/81
5/14/81
5/15/81
Observer:
5/11/81
5/12/81
5/13/81
Start
Howison
1434
1542
0937
1200
1310
1420
0930
1200
1310
1420
1530
1345
1455
1605
Clark
1433
1542
0937
1200
1310
Stop
1533
1635
1000
1259
1409
1519
1029
1259
1409
1519
1629
1444
1554
1634
1532
1632
1000
1259
1409
Number of 3-minute
averages
20
18
8
10
3
2
2
2
1
9
6.
3
1
1
19
1
20
16
2
2
16
2
2
19
1
20
19
1
20
10
20
18
7
14
5
1
14
2
2
1
1
Opacity
(percent)
0.0
n n
V • \J
o n
w • \J
0.0
0.4
1.3
1.7
2.1
2.5
0.0
0.4
1.3
2.1
4.2
0.0
2.5
0.0
0.0
0.4
1.3
0.0
0.4
0.8
0.0
0.4
n n
U • \J
0.0
0.8
0.0
0.0
0.0
0.0
0.0
0.0
0.8
1.3
0.0
0.4
0.8
3.3
5.0
C-19
(continued)
-------
TABLE C-ll. (con.)
Time
Date
Start
Stop
Number of 3-minute
averages
Opacity
(percent)
5/13/81
5/14/81
1421
1520
1530 1617
0930 1029
1200 1259
5/15/81
1310
1420
1530
1345
1455
1605
1409
1519
1629
1444
1554
1634
19
1
16
20
18
1
I
17
3
30
20
20
20
10
0.0
2.5
0.0
0.0
0.0
1.3
1.7
0.0
0.4
0.0
0.0
0.0
0.0
0.0
C-20
-------
TABLE C-12. UNITED STATES STEEL, FAIRFIELD, ALABAMA,
NORTH MIXER BAGHOUSE
Time
Date
Observer:
5/12/81
5/13/81
5/14/81
5/15/81
Observer:
5/12/81
5/13/81
5/14/81
5/15/81
Start
Howl son
1115
0930
1040
1045
0930
Clark
1115
0930
1029
1045
0930
1040
Stop
1156
1029
1139
1144
1029
1156
1029
1138
1144
1029
1139
Number of 3-minute
averages
11
1
2
20
20
20
20
10
1
1
1
1
20
20
20
20
20
Opacity
(percent)
0.0
0.8
0.4
0.0
0.0
0.0
0.0
0.0
1.7
2.5
4.2
0.4
0.0
0.0
0.0
0.0
0.0
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C.ll REFERENCES
1. Clayton Environmental Consultants. Steel Processing Fugitive
Emissions— Emission Test Report Kaiser Steel Corporation, Fontana,
California. U.S. Environmental Protection Agency. Research
Triangle Park, NC. EMB Report 80-BOF-3. August 1980.
2.
4.
5.
6.
7.
8.
9.
10.
11.
GCA Corporation. Assessment of Air Emissions From Steel Operations,
Republic Steel Corporation, Chicago District Q-BOP Shop Emission
Evaluation. U.S. Environmental Protection Agency, Washington,
DC. Contract No. 68-01-4143, Task No. 58 Report. September 1979.
Clayton Environmental Consultants. Steel Processing Fugitive
Emissions—Emission Test Report, Republic Steel Company, South
Chicago, Illinois. U.S. Environmental Protection Agency, Research
Triangle Park, NC. EMB Report 80-BOF-7. September 1980.
Clayton Environmental Consultants. Steel Processing Fugitive
Emissions—Emission Test Report, Bethlehem Steel Corporation,
Bethlehem, Pennsylvania. U.S. Environmental Protection Agency,
Research Triangle Park, NC. EMB Report 8Q-BQF-9. October 1980.
JACA Corporation, Fort Washington, Pennsylvania. Inspection
Report. J&L Aliquippa Works. BOF Shop Roof Monitor Emissions.
Volume I. Public Information. Final Report EPA Contract 68-01-
4135, Task 53. June 1981.
Midwest Research Institute. Source Testing—EPA Task No. 2.
ARMCO Steel Corporation, Middletown, Ohio. EPA Contract No.
02-0223 (MRI Project No. 3585-C). February 7, 1972.
69-
CH2M Hill. Particulate Emission Measurement on Q-BOP "C" at
United States Steel Corporation, Fairfield, Alabama. MG63302.80.
November 1978.
CH2M Hill. Particulate Emission Measurement on Q-BOP "X" at
United States Steel Corporation, Fairfield, Alabama. Project
No. MG63302.80. December 1978.
Engineering Services Division, Department of Environmental Control,
City of Chicago. Stack Test Particulates B.O.F. Scrubbers, U.S.
Steel South Works. Report No. SS-258. July 1977.
York Research Corporation. Performance Testing of Basic Oxygen
Furnace Electrostatic Precipitators. Report No. 7-9651. CF&I
Steel Corporation, Pueblo, Colorado. May 8, 1979.
Republic Steel, Buffalo, New York.
Emission Tests. November 1975.
Basic Oxygen Furnace Stack
C-30
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12. Acurex Corporation. Participate Emission Rates for BOF Operations
at Youngstown Sheet and Tube, East Chicago, Indiana. U.S. Environ-
menta] Protection Agency, Chicago, Illinois. EPA Contract No. 68-
01-4142, Task 9. Acurex Report TR-78-123, Volumes 1 and 2
August 1978.
C-31
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APPENDIX D
BOPF SHOP FUGITIVE EMISSIONS
MEASUREMENT AND CONTINUOUS MONITORING
D.I EMISSION MEASUREMENT METHODS
EPA Methods 9 and 22 are used currently for measuring visible
emissions. In Method 9, a trained and certified observer visually
determines and records the percent opacity of the emission plume of
interest. In Method 22, an observer times and records the duration of
visible emissions during an observation period suitably defined for
the process of interest. Method 22 observers are not required to have
opacity certification but are required to have a basic understanding
of and experience in the use of visible emissions testing techniques.
The two methods were used to assess basic oxygen process furnace
(BOPF) fugitive emissions because these emissions do not enter the
atmosphere in a manner that can be practicably quantified by conventional
mass sampling techniques. In addition, fugitive emissions from processes
essentially related to BOPF operations were measured by Methods 9 and
22. Emphasis was placed on measuring the visible emissions from the
principal BOPF shop roof monitors. Simultaneous visible emissions
tests were conducted inside the shop at the furnace vessel to provide
more detailed information on fugitive furnace emissions that were not
captured by the control systems. Related steel processes that were
also tested included iron desulfurization, slag skimming, and hot
metal transfer. In order to characterize fume exhaust capacities,
duct velocity measurements were made by EPA Method 2 where suitable
testing accessibility was available at the secondary control devices.
Certified observers conducted all EPA Method 9 testing throughout the
test series.
D-l
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The first emission test was conducted at an iron desulfurization
facility1 from February 26 through March 4, 1980. Initially, only
Method 22 was used. When the first few test runs indicated high
results, one observer was asked to conduct Method 9 observations
simultaneously. (The quantity of uncaptured emissions at this plant
appeared to be directly proportional to the degree of overfilling of
the hot metal cars.) The scales used to weigh the charged torpedo
cars were inoperable because of recent heavy rains. Consequently,
many of the cars were filled to overflowing to ensure a full charge
for desulfurization. Eighteen iron desulfurization tests were made by
Method 22 and 15 tests were made by Method 9. The presence of high
Method 22 results continued, so a modified Method 22 was used on the
last two tests in which the observers timed only those emissions that
exceeded 15-percent opacity. The results of the modified method were
slightly less than those for Method 22. The modified Method 22 results
were similar because most of the emissions observed were significantly
higher than 15-percent opacity.
Visible emissions testing at the BOPF shop at the first plant1
was completed April 7-11, 1980. The roof monitor was tested for 19
hours by Method 9 and for 16 hours by Method 22. During the roof
monitor observations, 21 furnace heats were tested indoors by Method 22.
A typical BOPF heat consists of several distinct operations. Furnace
visible emissions observations were structured to cover the individual
operations to aid in specific identification of the emissions source.
These separate operations included: scrap charging, hot metal charging,
blowing, turndown, tapping, and deslagging.
Method 22 recommends a maximum observation period of 30 minutes
to prevent observer eye fatigue. A typical BOPF heat lasted about 45
minutes and required constant observation. During the first three
heats it was noted that the blowing operation produced no emissions;
therefore, the observers were asked to discontinue readings during
blowing except to note any emissions on subsequent heats.
Ten hot metal transfers and two slag skimming operations were
tested by Method 22. The skimming tests were interrupted because the
D-2
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test personnel were needed to perform additional testing at the BOP
furnace to determine any effect of high winds which occurred on the
last day of testing. A Santa Anna wind produced velocities up to
60 mph on April 11, 1980. This high wind did not cause any discernable
effect on the level or duration of furnace or roof monitor emissions;
however, it caused significant interference for the outdoor observers
testing at ground level at the hot metal transfer station.
An iron desulfurization station at a second plant2 was tested
during April 24-26, 1980. Ten desulfurization tests were conducted by
Method 22. Because the Method 22 emission frequencies were high,
Method 9 was used by one observer for the last six tests. Exhaust
velocity was measured using Method 2 for eight traverses at the baghouse
outlet.
The physical configuration of the desulfurization station at this
plant did not permit visible emissions observers to maintain proper
sun angle positioning in the late afternoon. The observers could not
read from the south side of the building because it was enclosed from
the ground level to the roof. This enclosure is designed to minimize
emission capture interference caused by the prevailing winds. Whenever
the observers were forced to face the sun, they were always standing
well within the shadow of the building which effectively prevented any
observational interferences caused by the improper sun angle.
Two BOPF shops at a third steel plant3 were tested during May 12-16,
1980. Testing at the Number 2 shop included 24 hours each of Method 9
and Method 22 observations of the roof monitor, 19 heats inside at the
furnace by Method 22, and 12 velocity traverses by Method 2 at the
inlet to the secondary scrubber control. Indoor emissions for all
segments of the heat cycle were tested for the first three heats. No
emissions were observed; therefore, during normal blowing for the
first three heats, testing of this process segment was discontinued
for all subsequent heats to be consistent with the procedure established
at the first indoor furnace testing for this industry.
Testing at this plant's Number 4 BOPF shop included three iron
desulfurization tests by Method 22, 12 hot metal transfers by Method 22,
D-3
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12 velocity traverses at the secondary baghouse outlet by Method 2,
6.5 hours of roof monitoring testing by Method 9, and 3 hours of roof
monitor testing by Method 22.
The roof monitor over the Number 2 BOPF shop at this plant is
open on only one side. The open side was not visible from the
observation location used for the afternoon readings; consequently,
the observers could not see the origin of any emissions rising over
the top edge of the monitor. To document possible interfering emissions
from other sources, two additional observers were assigned to read
simultaneously from the opposite side of the shop. A comparison of
the data taken simultaneously from both sides of the shop indicated
that any emissions seen from the west location originated from the
Number 2 shop. The extra observers were located facing the sun since
they were opposite the primary observers who carefully positioned
themselves with the sun in the required 140° arc behind them. Both
sets of observers switched locations at around 2:00 p.m. from morning
to afternoon positions. Data collected by the additional readers at
the Number 2 shop cannot be used for standard setting in this industry
because an improper sun angle was used. These data are summarized in
Tables 2.2, 2.3, 2.4 and 2.5 of the referenced emissions test report.3
Emissions from extraneous sources interfered with visible emissions
observations at this plant. A coke plant adjacent to the Number 2
BOPF shop produced a periodic steam plume which occasionally completely
obscured the BOPF shop roof monitor. Emissions from a small lower
roof monitor over the teeming aisle and from the primary scrubber
stacks interfered with testing at the Number 4 BOPF shop. The inter-
ferences at the Number 4 shop were more consequential than those at
the Number 2 shop and much more testing time was lost to these extraneous
plumes. The presence and times of these interferences were noted on
the field data forms. The inherent chronology of Method 9 was used to
record observation times lost to the various interferences. The
occurrence of visual interference during roof monitor testing was
addressed by summarizing the data in different forms to provide a
D-4
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variety of options for data analysis for this plant. The same type of
summaries were used for all subsequent tests at other plants where
significant periods of visual interferences were encountered.
Overall averages for the Number 2 and Number 4 BOPF shop tests
were computed using all the roof monitor data for Methods 9 and 22.
Averages were also computed for both methods using only those data
sets without interferences. The Method 9 roof monitor data were
reduced two ways to accommodate the periods of interference. In the
first procedure, sets of 24 consecutive readings were computed as
prescribed by the reference method where periods of interferences were
skipped when counting the sets. The intervals of interference recorded
by the paired Method 9 observers did not always match; therefore, a
direct comparison of the two readers' observations is not assured by
the 24 consecutive reading mode of reduction. In the second procedure,
Method 9 data were divided into successive 6-minute segments that
included the periods of interference. Averages for each 6-minute set
were calculated based on the number of actual readings recorded for
the set. This second mode of Method 9 reduction provides a continuing
comparison of opacity data between the two observers.
Fugitive emissions testing was performed at a fourth steel plant4
during June 2-6, 1980. The BOPF shop roof monitor was tested for
24 hours by Method 9 and for 23 hours by Method 22. Indoor furnace
emissions were tested for 10 heats by Method 22, and nine velocity
traverses were conducted at the inlet to the secondary collector.
Significant quantities of emissions during the blowing segment of the
furnace heat were observed at this shop; therefore, the entire heat
was tested by Method 22. The problem of observer eye fatigue was
addressed by having the observers read only alternate heats; every
other heat was used as a break period. The only accessible ports for
duct velocity traverses at this shop were directly above the furnaces.
Plant safety requirements prohibited any use of these ports during
furnace operations; therefore, the velocity traverses were made before
furnace operations began. Because three modes of secondary fume
exhaust are used at this shop, "cold" velocity traverses were made in
D-5
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all three modes. A wind shift on the fourth day of testing prevented
roof monitor observations from the preferred locations. The observers
moved to an alternate position which faced the long dimension of the
roof monitor and forced the use of an improper sun angle; therefore,
the roof monitor readings from 1:00 to 5:00 p.m. on June 4, 1980,
should not be included in the data base for this series.
A testing program for fugitive emissions was conducted at the
fifth steel plant5 during June 9-16, 1980. Roof monitor observations
were made for a total of 29 hours by Method 9 and 26 hours by Method 22.
Eleven hot metal transfers were tested by Method 22,. and 13 furnace
heats were observed by Method 22. Rainy weather on the first day of
testing produced marginal conditions for reading the roof monitor.
Periods of interference caused by the weather were noted on the field
data forms. Furnace operation at this plant produced significant
emissions during blowing so that entire heats were read. The observers
tested only on alternate heats to avoid excessive eye fatigue. Lighting
inside the BOPF shop building at this plant was noticeably lower than
at previous shops tested in the series. Light level measurements were
below the 10-foot candle minimum recommended by Method 22 for indoor
testing. This condition probably caused underestimated observations
because the testers reported difficulty in seeing faint emissions.
The sixth plant in the BOPF series was tested during June 23-27,
1980.6 The roof monitor was observed for 24 hours by both Methods 9
and 22. The BOP furnace was tested for 20 heats by Method 22.
Emissions observed during blowing at this plant necessitated testing
during the entire furnace heat. Typical furnace operations here
included a 15 to 20-minute delay between heats. The indoor observers
used this time as a break to avoid undue eye fatigue.
A seventh BOPF facility was tested during May 11-15, 1981.7
Emissions observations by Method 9 were conducted at the outlets of
two separate baghouses controlling secondary emissions. One of these
units was used to control fugitive emissions from a Q-BOP furnace and
emissions generated in the transferring of hot metal. The two types
of hot metal transfer involved were pouring fresh cast metal into a
D-6
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large capacity mixer and pouring from the mixer to ladles for furnace
charging. The second baghouse was used to control only the two hot
metal transfer processes.
D.2 MONITORING SYSTEMS AND DEVICES
No instrumental or automated systems are available for suitably
quantifying the mass of fugitive emissions from secondary BOPF control
devices. These emissions are uncontained; therefore, they are not
suitable for representative sampling by any material capture technique.
These difficulties apply to the emission sources around the steel
processing hardware and to emissions passing through the roof monitor.
Opacity transmissometers could be considered for measuring roof
monitor emissions; but application of this type of instrument is
highly questionable because of practical problems. A long path trans-
mi ssometer mounted to cover the full length of a roof monitor could be
used to monitor opacity, but the values measured would have to be
instrumentally or mathematically corrected to the short dimension of
the roof monitor. Since multiple plumes of varying opacities are
typical at these sources, any correlation between Method 9 observations
and transmissometer output would be highly questionable.
The exhaust velocity in the secondary control device ducting for
steel processing plants could be monitored if required. These measure-
ments could be obtained by periodic manual velocity traverses or by
commercially available flow detection devices. The cost of velocity
monitoring could range from about $100 for a half-day series of manual
velocity tests to about $5,000 for an automated electronic flow detector.
The cost of instrumental flow detectors ranges from less than $500 to
around $5,000, depending upon the degree of precision and length of
performance desired. Compatibility with either chart type recording
devices or digital data acquisition systems is probably available on
the more expensive flow measuring instruments.
Field experience with automated velocity measuring projects in
the iron and steel industry has shown that blockage of the probe and
sampling lines from duct contaminants is the greatest problem. This
problem especially occurs when measurements are attempted in a control
D-7
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device inlet duct. A probe-sample line purge and routine maintenance
cleanout are recommended to enhance continuous operation of a stack
velocity monitor.
D.3 PERFORMANCE TEST METHODS
Method 9--"Visual Determination of the Opacity of Emissions from
Stationary Sources"—and Method 22—"Visual Determination of Fugitive
Emissions from Material Processing Sources"—are recommended as appro-
priate for determining the level of visible emissions from BOPF shop
roof monitors and baghouses. No method can be recommended for
characterizing visible emissions from buildings or structures such as .
the iron desulfurization facilities tested where emissions escaped
from the sides of the facility rather than from a roof monitor.
Both of these methods have inherent advantages and disadvantages.
Method 9 can be used to quantify the intensity of the fugitive emissions
as the various opacity levels are determined. Since Method 9 is
applied at only 15-second intervals, it does not necessarily provide
an indication of the duration of emissions. Consequently, fugitive
emission plumes that last less than 15 seconds might not be recorded
by this method. Experience gained from the six fugitive emissions
test programs indicates that most of the emissions observed from the
roof monitors lasted more than 15 seconds and typically lingered for
1 to 2 minutes. Therefore, the Method 9 requirement that readings be
taken at 15-second intervals does not pose a serious problem to its
application for roof monitor testing at BOPF shops.
Method 22 is designed to provide quantitative determination of
the duration of fugitive emissions without measuring plume opacity.
This method is quite suitable to processes that produce intermittent
visible fugitive emissions, and it is also more suitable than Method 9
for sources of multiple fugitive plumes because the observer does not
have to select the plume of highest opacity but merely records the
total time that any emissions are observed. Method 22 is the preferred
method for sources that simultaneously produce multiple fugitive plumes.
Test data obtained at six BOPF shops in the steel industry indicate
that visible emissions test methods are applicable to the various
process sources as follows:
D-8
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BOP Furnace - Method 22; furnace emissions are highly intermittent
and originate indoors; therefore, the level of lighting does not
permit an accurate determination of opacity. Establishing the
observation period for Method 22 by individual process operation is
recommended.
Iron Desulfurization - No method can be recommended for measuring
visible emissions from iron desulfurization facilities not located
inside the BOPF building. Although fume escape can be detected by
Method 22, the present data base is insufficient for recommending this
method. Because of poor conditions and the multiplicity of locations
where fumes escaped, no reliable measure exists for determining percent
opacity that is consistent with EPA methods and techniques.
Hot Metal Transfer - Method 22; process stations for this operation
can be located indoors or outdoors. When the stations are indoors,
lighting levels are too low for Method 9, and when they are outdoors,
the equipment configuration typically gives very poor background
options for opacity determinations.
Skimming - Method 22; this operation is usually performed indoors;
therefore, opacity measurements are impractical because of low lighting
levels.
BOPF Shop Roof Monitors - Method 9 or Method 22; typical roof
monitors over BOPF shops are suitable for either method of visible
emissions observations. Method 9 observers must position themselves
to read across the shortest dimension of the roof monitor and not
through the long dimension from the end of the monitor. Failure to
observe this precaution in positioning would result in a high bias in
opacity determinations. Consideration could be given to using both
Methods 9 and 22 for combined performance testing of roof monitors. A
two-method test of this type would provide a more comprehensive
coverage of emission monitoring, but the cost effectiveness of such an
approach is questionable. Application of both methods for roof monitor
testing would essentially double the cost of a performance test.
Method 9 is recommended for performance tests at BOPF shop roof monitors
D-9
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because it is a better quantifier of roof monitor emissions, and field
testing applications have indicated its suitability for this source of
emissions.
Any modification of the time base for averaging Method 9 roof
monitor data should be considered for statistical accuracy prior to
implementation. A statistical analysis of Method 9 data reduction
options indicated that either a 6-minute or 3-minute average is suit-
able for an accurate determination of opacity levels.8
Secondary Emission Control Device Outlets - Method 9; this method
is applicable for either stack or roof monitor outlets from secondary
control devices. When multiple stacks are encountered, the number of
stacks will determine the number of observers required. One observer
can provide sufficient coverage for up to eight multiple stacks if the
control efficiency is high and emissions are infrequent (less than 5
minutes per hour). Frequently emitting multiple stacks could require
one observer for each pair of stacks. When long rectangular roof
monitor outlets on secondary control devices are tested, the observers
need to position themselves so that readings are made through the
shortest dimension of the roof monitor. It is recommended that Method
9 observers be paired for testing these sources to provide corroborative
emissions data.
Secondary Emission Exhaust Systems - Methods 1 and 2; exhaust gas
velocities in the secondary steel processing control devices can be
tested by these two reference methods. Any instrumental or automated
flow measuring devices cannot be used for testing until a procedure
for demonstrating the accuracy of such a system relative to Reference
Methods 1 and 2 and performance specifications for such a device have
been established.
Costs for conducting performance tests of steel processing fugitive
emissions are estimated to range between $3,000 and $10,000, exclusive
of travel expenses. Variations in costs depend primarily upon the
number of sources that require testing at a given plant. Testing
costs can be minimized if observations are limited to the BOPF shop
roof monitor by Method 9 alone. Related processes that are not under
D-10
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the same roof monitor would require separate testing. An example
breakdown for a test of a roof monitor and iron desulfurization unit
follows:
Assignment
Presurvey
Field work
Data reduction
Report preparation
Management
Total
Number
of Persons
1
4
1
1
1
8
Number
of Days
0.5
3
3
3
0.5
Man-days
0.5
12
3
3
0.5
1970
D.4 REFERENCES
1. Emission Test Report, Kaiser Steel, Fontana, California. Clayton
Environmental Consultants. EPA Contract No. 68-02-2817. EPA
Report No. 80-BOF-3. Work Assignment 26 and 27 and Engineering-
Science under EPA Contract No. 68-02-2815. Work Assignment 41.
2. Emission Test Report, Armco Steel, Ashland, Kentucky. Clayton
Environmental Consultants. EPA Contract No. 68-02-2817. EPA
Report No. 80-BOF-4. Work Assignment 28.
3. Emission Test Report, Inland Steel, East Chicago, Indiana.
Clayton Environmental Consultants. EPA Contract No. 68-02-2817.
EPA Report No. 80-BOF-6. Work Assignment 30 and York Research
Corporation under EPA Contract No. 68-02-2819. Work Assignment
26.
4. Emission Test Report, Republic Steel, South Chicago, Illinois.
Clayton Environmental Consultants EPA Contract No. 68-02-2817.
EPA Report No. 80-BOF-7. Work Assignment 32.
5. Emission Test Report, Republic Steel, Cleveland, Ohio. Clayton
Environmental Consultants. EPA Contract No. 68-02-2817. EPA
Report No. 80-BOF-8. Work Assignment 33.
6. Emission Test Report, Bethlehem Steel, Bethlehem, Pennsylvania.
Clayton Environmental Consultants. EPA Contract No. 68-02-2817.
EPA Report No. 80-BOF-8. Work Assignment 36.
7. Emission Test Report, U.S. Steel, Fairfield, Alabama. PEDCo
Environmental. EPA Contract No. 68-02-3546. EPA Report No.
81-BOF-10. Work Assignment 8.
8. Hartwell, T. D. Examining the Properties of Qualified Observer
Opacity Readings Averaged Over Intervals of Less than Six Minutes.
Research Triangle Institute. Research Triangle Park. EPA Contract
No. 68-02-1325.
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
REPORT NO.
EPA-450/3-82-005a
TITLE AND SUBTITLE
Revised Standards for Basic Oxygen Process Furnaces-
Background Information for Proposed Standards
i. REPORT DATE
December 1982
6. PERFORMING ORGANIZATION CODE
AUTHOFHS)
8. PER
PORT NO.
PERFORMING ORGANIZATION NAME AND ADDRESS
Environmental Protection Agency
Office of Air Quality Planning and Standards
Emission Standards and Engineering Division
Research Triangle Park, North Carolina 27711
1O. PROGF
11. CONTRACT/GRANT NO.
2. SPONSORING AGENCY NAME AND ADDRESS
DAA for Air Quality Planning and Standards
Office of Air, Noise, and Radiation
United States Environmental Protection Agency
Research Triangle Park, NC 27711
13. TYPE OF REPORT AND PERIOD CO'
14. SPONSORING AGENCY CODE
EPA/200/04
15, SUPPLEMENTARY NOTES
16. ABSTRACT . .
A New Source Performance Standard for secondary emissions from basic oxygen
process furnace (BOPF) steelmaking shops is being proposed under authority of _
Section 111 of the Clean Air Act. The purpose of the proposed standard is to minv
mize BOPF secondary particulate emissions to the level attainable with the best
demonstrated technology. Revisions to the existing BOPF primary standard
(40 CFR 60.140, Subpart N) are also being proposed. These would clarify the
definition of a BOPF and the sampling time used to determine compliance.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Held/Group
Air Pollution
Pollution Control
Standards of Performance
Basic Oxygen Process Furnaces
Opacity
Particulates
Air Pollution Control
18, DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (Tills Report)
\ Unclassified
I 20. SECURITY CLASS /This page/
11. NO. OF PAGES
386
22. PRICE
Unclassified
EPA Form 2220-1 (Rov. 4-77) PREVIOUS EDITION is OBSOLETF
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