United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 27711
EPA-453/R-97-012
June 1997
Air
& EPA
NATIONAL EMISSION STANDARDS
FOR HAZARDOUS AIR POLLUTANTS
(NESHAP) FOR STEEL PICKLING -
HC1 PROCESS - BACKGROUND
INFORMATION FOR PROPOSED
STANDARDS
-------
This report has been reviewed by the Emission Standards
Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of
trade names or commercial products is not intended to
constitute endorsement or recommendation for use. Copies of
this report are available through the Library Services
Offices (MD-35), U. S. Environmental Protection Agency,
Research Triangle Park, NC. 27711, or from National
Technical Information Services, 5285 Port Royal Road,
Springfield, VA 22161.
11
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ENVIRONMENTAL PROTECTION AGENCY
Background Information
and Draft
Environmental Impact Statement
for Hazardous Air Pollutant Emissions
From Steel Pickling-HCl Process Operations
<^7/^\ Prepared by:
. Jordan . ,
r^ Emission Standards Division
(Date)'
C.
Directoi.,
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
1. The proposed standards of performance would reduce
hazardous air pollutant emissions from existing and new
steel pickling-HCl process facilities that are major
sources of hazardous air pollutant emissions. Under
Section 112 of the Clean Air Act as amended in 1990,
EPA is authorized to require the maximum degree of
reduction in emissions of hazardous air pollutants that
is achievable, taking into consideration the cost of
achieving such emissions reductions and any nonair
quality health and environmental impacts and energy
requirements.
2 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 Offices; EPA Regional Administrators; and other
interested parties.
3. For additional information contact:
Mr. James Maysilles
Metals Group (MD-13)
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Telephone: (919) 541-3265
4. Copies of this document may be obtained from:
U. S. EPA Library (MD-35)
Research Triangle Park, NC
27711
ill
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IV
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CONTENTS
Chapter
Page
Tables
1.0 Introduction 1~
1.1 Control Options ..... 1~*
1.2 Environmental Impacts . *-*
1.3 Costs and Economic Impacts •*- 2
2.0 Regulatory Authority and Standards Development . . 2-1
2.1 Regulatory Authority .........••• 2-1
2.2 standards Development for Steel Pickling-
HC1 Process Air Emissions 2~2
2.3 References 2~3
3.0 Industry Description and Air Emissions 3-1
3.1 Background ;*""*•
3.1.1 The Pickling Process 3-x
3.1.2 Health Effects of HCl and C12 .... 3-4
3.1.3 Emissions from the Pickling Process . 3-6
3.2 Processes and Their Uncontrolled Emissions . 3-6
3.2.1 Continuous Coil Pickling 3-6
3.2.1.1 Horizontal Pickling Tanks. . . 3-7
3.2.1.2 Emissions and Controls for
Continuous Coil Pickling
Lines 3-8
3.2.1.3 Trends in Continuous Coil
Pickling Facilities .... 3-12
3.2.1.4 Vertical Spray Towers ... 3-12
3.2.2 Push-Pull Coil Pickling 3-12
3.2.2.1 Emissions and Controls for
Push-Pull Pickling Lines . . 3-13
3.2.2.2 Trends in Push-Pull Pickling
Facilities 3-15
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CONTENTS (continued)
Chapter
Page
3.2.3 Continuous Tube, Rod, and Wire
Pickling 3-16
3.2.3.1 Emissions and Controls for
Tube/Rod/Wire Pickling Lines 3-17
3.2.3.2 Trends in Continuous Tube/
Rod/Wire Pickling Facilities 3-18
3.2.4 Batch Pickling ....... 3-18
3.2.4.1 Emissions and Controls for
Batch Pickling Tanks .... 3-19
3.2.4.2 Trends in Batch Pickling
Facilities 3-20
3.3 Acid Regeneration Processes ........ 3-21
3.3.1 Existing Acid Regeneration
Facilities . . 3-21
3.3.2 Process Description for Acid
Regeneraton Systems ... 3-21
3.3.3 Emissions and Controls for Acid
Regeneration Plants 3-23
3.3.4 Trends in Acid Regeneration Systems . 3-25
3.3.5 Fluidized Bed Roasting Acid
Regeneration „ 3-25
3.4 Acid Recovery Processes ..... 3-26
3.4.1 Evaporation/Condensation Processes . . 3-27
3.4.2 Resin Adsorption Processes ...... 3-27
3.4.3 Refrigeration/Crystallization
Processes ......... 3-28
3.5 Baseline Emissions ............. 3-28
3.5.1 Summary of Federal and State
Regulations 3-28
3.5.2 National Emission Estimates . . . . . 3-29
3.6 Summary of Industry Data 3-33
3.7 References 3-50
4.0 CONTROL TECHNOLOGY AND PERFORMANCE OF CONTROLS . . 4-1
4.1 Emission Capture Equipment 4-1
4.1.1 Fume Exhaust Hoods 4-2
4.1.1.1 Design Parameters for Hood
Extraction Systems ..... 4-5
VI
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CONTENTS (continued)
Chapter
Page
4.1.1.2 Operating Conditions and
Factors That Determine the
Effectiveness of Exhaust Hoods 4-7
4.1.1.3 Application of Emission Capture
Systems in the Pickling
Industry ..... . 4-8
4.1.2 Tank Enclosures 4-8
4.1.2.1 Design Parameters for Tank
Enclosures 4-9
4.1.2.2 Operating Conditions and Factors
That Determine the Effective-
ness of Tank Enclosures . . . 4-9
4.1.2.3 Application of Tank Enclosures
in the Pickling Industry . . . 4-10
4.2 Control Techniques for HC1 4-10
4.2.1 Types of Scrubbers . 4-11
4.2.1.1 Packed Bed Scrubbers .... 4-11
4.2.1.2 Sieve Tray Scrubbers .... 4-13
4.2.1.3 Venturi Scrubbers. 4-14
4.2.1.4 Demisters 4-14
4.2.1.5 Caustic Scrubbing Solution . 4-16
4.2.2 Use of Scrubbers in the U.S. Pickling
Industry 4-16
4.3 Scrubber Performance 4-29
4.3.1 Survey Information 4-29
4.3.2 Source Test Analysis 4-34
4.3.3 Source Tests at Continuous and
Push-Pull Coil Pickling Facilities . 4-36
4.3.4 Variables Affecting Emissions
and Controls 4-42
4.3.4.1 Types of Pickling Operations 4-42
4.3.4.2 Heating Methods 4-46
4.3.4.3 Types of Scrubbers 4-46
4.3.4.4 Types of Scrubbing Media . . 4-47
4.3.4.5 Types of Demisters 4-47
4.3.4.6 Control Efficiency vs. Outlet
Loading 4-47
4.3.5 Tests at Spray Roasting Acid
Regeneration Facilities . . 4-49
4.3.6 Variables Determining Spray
Roasting Emissions and Controls . . . 4-49
vii
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CONTENTS (continued)
Chapter Page
4.4 Pollution Prevention 4-58
4.4.1 Pickling Operations 4-58
4.4.2 Wastewater Reduction 4-59
4.4.2.1 Heat Exchange 4-59
4.4.2.2 Multistage Spray Rinse
Systems 4-60
4.4.2.3 Sieve Tray Scrubbers .... 4-60
4.4.3 Reuse of Pickling Tank Sludge .... 4-60
4.4.4 Acid Regeneration 4-61
4.5 Control Techniques for C12 4-61
4.6 References 4-63
5.0 Model Plants and Control Options 5-1
5.1 Model Plant Parameters . 5-2
5.1.2 Model Plants for Continuous Coil
Pickling 5-4
5.1.2.1 Distribution of Plants by
Size 5-4
5.1.2.2 Description of Process
Parameters 5-6
5.1.2.3 Emissions and Controls . . . 5-8
5.1.2.4 New Continuous Coil Pickling
Plants 5-10
5.1.3 Model Plants for Push-Pull Coil
Pickling ........ 5-11
5.1.3.1 Distribution of Plants by
Size 5-11
5.1.3.2 Description of Process
Parameters 5-13
5.1.3.3 Emissions and Controls . . . 5-13
5.1.3.4 New Push-Pull Coil Pickling
Plants ............ 5-15
5.1.4 Model Plants for Continuous
Rod/Wire Pickling .... 5-17
5.1.4.1 Distribution of Plants by
Size 5-17
5.1.4.2 Description of Process
Parameters 5-19
5.1.4.3 Emissions and Controls 5-19
5.1.4.4 New Continuous Rod/Wire
Pickling Plants 5-21
Vlll
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CONTENTS (continued)
Chapter
Page
5.1.5 Model Plants for Continuous Tube
Pickling .............. 5-21
5.1.5.1 Distribution of Plants
by Size 5-21
5.1.5.2 Description of Process
Parameters 5-24
5.1.5.3 Emissions and Controls 5-24
5.1.5.4 New Continuous Tube Pickling
Plants 5-26
5.1.6 Model Plants for Batch Pickling . . . 5-26
5.1.6.1 Distribution of Plants
by Size . . . . 5-26
5.1.6.2 Description of Process
Parameters 5-29
5.1.6.3 Emissions and Controls 5-30
5.1.6.4 New Batch Pickling Plants . 5-30
5.1.7 Model Plants for Acid Regeneration
Processes 5-33
5.1.7.1 Distribution of Plants by
Size . 5-33
5.1.7.2 Description of Process
Parameters 5-33
5.1.7.3 Emissions and Controls . . . 5-35
5.1.7.4 New Acid Regeneration Plants 5-37
5.1.8 Model Units for Storage Tanks .... 5-39
5.1.8.1 Distribution of Tanks by Size 5-39
5.1.8.2 Emissions and Controls . . . 5-39
5.2 Baseline Conditions • 5-40
5.2.1 Capture Devices 5-40
5.2.2 Baseline Control Techniques . -. . . . 5-43
5.2.3 Baseline Level of Control 5-43
5.3 Control Options for HC1 5-44
5.3.1 Use of Caustic Scrubbing Medium 5-44
5.3.1.1 Comparison of Caustic and
Water Scrubbing Media .... 5-45
5.3.1.2 Interference with Pollution
Prevention . 5-45
5.3.2 Increased Control Effectiveness . . . 5-45
5.3.3 Rationale for Limiting Control
Options to the MACT Floor 5-46
5.4 Control Options for C12 , 5-47
5.5 References ............ 5-48
IX
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CONTENTS (continued)
Chapter
6.0 Environment Impacts • 6-1
6.1 Summary « 6-1
6.2 Nationwide Emissions for Pickling Lines, Acid
Regeneration Plants, and Acid Storage Tanks . 6-4
6.3 Nationwide Cost of Control at a MACT floor
of 10 ppmv/97.5 Percent ....-„• 6-6
6.4 Energy, Solid Waste, and Wastewater Impacts . .6-7
6.5 Non-Air Health Impacts ........... 6-7
6.6 Small Business Impacts ........... 6-8
6.7 References ........... 6-10
7.0 Costs 7~1
7.1 Capital and Annual Cost Ranges ....... 7-1
7.2 Rationale for Sizing the Model Emission
Control Systems 7-4
7.3 Monitoring Options 7-6
7.4 Costs of Monitoring Options 7-10
7.5 References • 7-15
8.0 Economic Impacts Analysis for the Maximum Achievable
Control Technology (MACT) Standard for the Steel
Pickling Industry •
8.1 The Supply Side of the Industry ....... 8-2
8.1.1 Types of Steel 8-2
8.1.1.1 Carbon Steels . 8-2
8.1.1.2 Alloy Steels . . ... . . . 8-2
8.1.1.3 Stainless Steels 8-6
8.1.2 Costs of Production . . . , . . . . .. • 8-6
8.1.2.1 Nonavoidable Fixed Costs . . 8-7
8.1.2.2 Avoidable Fixed Costs . . . 8-9
8.1.2.3 Avoidable Variable Costs . . 8-9
8.1.2.3.1 Labor 8-10
8.1.2.3.2 Hydrochloric Acid 8-10
8.2 The Demand Side of the Steel Industry . . . . 8-14
8.2.1 Product Characteristics . . 8-14
8.2.2 Uses and Consumers of Steel 8-15
8.2.3 Substitution Possibilities in
Consumption 8-17
8.2.3.1 Beverage Cans ....... 8-19
8.2.3.2 Containers ......... 8-20
8.2.3.3 Automobiles ........ 8-20
8.2.3.3.1 Plastics ..... 8-20
8.2.3.3.2 Aluminum .... 8-21
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CONTENTS (continued)
Chapter
8.3 Industry Organization 8-22
8.3.1 Market Structure 8-22
8.3.1.1 Steel Products 8-22
8.3.1.2 Steel Producers 8-22
8.3.1.3 Geographically Distinct
Markets 8-24
8.3.1.4 Market Behavior 8-26
8.3.2 Firm Characteristics 8-27
8.3.2.1 Ownership 8-29
8.3.2.1.1 Sole
Proprietorship . . 8-29
8.3.2.1.2 Partnerships . . . 8-31
8.3.2.1.3 Corporations . . . 8-32
8.3.2.2 Size Distribution ..... 8-34
8.3.2.3 Issues of Vertical and
Horizontal Integration . . . 8-36
8.3.2.4 Financial Condition .... 8-37
8.3.2.5 Current Events 8-37
8.4 Markets • 8~41
8.4.1 Production ...... 8-41
8.4.1.1 Domestic Production .... 8-41
8.4.1.2 Foreign Production (Imports) 8-43
8.4.2 Consumption 8-46
8.4.2.1 Domestic Consumption .... 8-46
8.4.2.2 Foreign Consumption (Exports) 8-46
8.5 Control Cost, Environmental Impacts, and
Cost Effectiveness 8-49
8.5.1 Model Plants . 8-49
8.5.2 Estimated Environmental Impacts . . . 8-49
8.5.3 Control Cost Estimates 8-52
8.5.4 Cost Effectiveness 8-52
8.6 Economic Impact Analysis 8-52
8.6.1 Methodology 8-52
8.6.2 Results 8-55
8.7 Small Business Impacts 8-58
8.7.1 Small Business Categorization .... 8-59
8.7.2 Small Business Impacts 8-59
8.8 References 8-60
XI
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CONTENTS (continued)
Chapter
Page
Appendices
A Evolution of the Background Information
Document ..... A-l
B Index to Environmental Impact Considerations B-l
C Environmental Impacts Estimation Model . . . C-l
D Costs for Model Plant Scrubbers ....... D-l
E Tank Emissions Model ..... E-l
F Products in the Steel Industry by SIC Code . F-l
XII
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FIGURES
Number
Page
3-1 Continuous coil pickling line with looping
pits 3-9
3-2 Continuous coil pickling line with looping
cars 3-10
3-3 Push-pull pickling line 3-14
3-4 The spray roasting acid regeneration
process 3-22
4-1 Roof-mounted exhaust system .... 4-4
4-2 Wall-mounted exhaust system .......... 4-4
4-3 Slot-hood exhaust system 4-5
4-4 Lateral hood exhaust system 4-5
4-5 Vertical packed bed scrubber 4-12
4-6 Sieve tray scrubber 4-15
4-7 Distribution and sizes of sieve tray
scrubber systems for all pickling processes . . 4-17
4-8 Distribution and sizes of packed tower
scrubber systems for all pickling processes . . 4-18
4-9 Distribution and sizes of horizontal packed
bed scrubber systems for all pickling
processes 4-19
4-10A Distribution and sizes of sieve tray
scrubber systems for continuous coil
pickling - 4-20
4-10B Distribution and sizes of packed tower
scrubber systems for continuous coil
pickling 4-20
4-10C Distribution and sizes of horizontal
packed bed scrubber systems for continuous
coil pickling 4-20
4-10D Distribution and sizes of other scrubber
system types for continuous coil pickling . . . 4-21
4-11 Distribution and sizes of scrubber systems
for push-pull coil pickling .......... 4-22
4-12 Distribution and sizes of scrubber systems
for batch pickling ..... .... 4-23
4-13 Distribution and sizes of scrubber systems
for continuous wire, rod, and tube pickling . . 4-24
Xlll
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FIGURES (continued)
Number
Page
4-14 Distribution and sizes of scrubber systems
for acid regeneration . . 4-25
4-15 Distribution of reported HCl control
efficiencies for 111 scrubber systems
in pickling operations 4-30
4-16 Distribution of HCl control efficiencies
for 78 scrubber systems in coil pickling
operations 4-31
4-17 Distribution of reported HCl control
efficiencies for 33 scrubber systems
in non-coil pickling operations 4-32
4-18 Distribution of HCl control efficiencies
for 12 scrubber systems in acid regeneration
processes 4-33
4-19 Scrubber efficiencies for 10 tests at 9 coil
pickling facilities . . 4-43
4-20 Scrubber outlet HCl emission rates for
10 tests at 9 coil pickling facilities .... 4-44
4-21 Scrubber outlet HCl concentrations for 10
Tests at 9 coil pickling facilities ...... 4-45
4-22 Scrubber outlet HCl emission rates (in
ascending order) for 10 tests at 9 ceil pickling
facilities . ' 4-49
4-23 Scrubber outlet HCl concentrations (in ascending
order) for 10 Tests at 9 coil pickling
facilities 4-50
4-24 Scrubber outlet PM concentrations for 4 HCl
HCl acid regeneration facilities „ 4-53
4-25 Scrubber outlet HCl concentrations for 7
Acid regeneration facilities 4-54
4-26 Scrubber outlet HCl emission rates for
4 HCl acid regeneration facilities 4-55
4-27 Scrubber outlet chlorine concentrations for 4
HCl acid regeneration facilities 4-56
4-28 Scrubber outlet chlorine emission rates
for 4 HCl acid regeneration facilities .... 4-57
5-1 Distribution of 28 of 36 continuous coil pickling
facilities by size 5-5
5-2 Distribution of push-pull coil pickling
facilities by size 5-12
5-3 Distribution of continuous rod/wire
pickling facilities by size 5-18
5-4 Distribution of continuous tube pickling
facilities by size . . . . 5-23
5-5 Distribution of batch pickling facilities
by size . 5-28
5-6 Distribution of acid regeneration
facilities by size 5-34
xiv
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Number
8-1
8-2
FIGURES (continued)
Share of steel consumption for 1982 by
major market classification .......
Comparison of the legal form of ownership
for firms in the U.S. and primary metals
industry: 1987
Page
8-18
8-30
xv
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TABLES
Number
Page
3-1 Ambient Air Limits for HC1, By State „ . . . .3-30
3-2 Ambient Air Limits for C12/ By State ...... 3-31
3-3 Estimated National Baseline Emissions from
HC1 Steel Pickling Operations ......... 3-32
3-4 Steel Pickling and Hydrochloric Acid Regeneration
Facilities Providing Information Under Section
114 Requests 3-34
3-5 Employment Information ..... 3-38
3-6 Summary of Process Capacity and Annual
Production ...... 3-39
3-7 Processing Data for Continuous Steel Strip
Pickling Facilities ..... 3-40
3-8 Processing Data for Push-Pull Steel Strip
Pickling Facilities 3-42
3-9 Processing Data for Continuous Steel Rod and Wire
Pickling Facilities ..... 3-43
3-10 Processing Data for Continuous Steel
Tubing Pickling Facilities .......... 3-45
3-11 Processing Data for Batch Steel Pickling
Facilities ..... 3-46
3-12 Processing Data for Acid Regeneration
Facilities ..... 3-48
3-13 Use of Air Pollution Control Systems ..... 3-49
4-1 Air Extraction Rates Required for Different
Ventilation Systems for a3mx3m (lOftx
10 ft) Open Tank 4-3
4-2 Minimum Exhaust Rates for Ventilation Hoods
Used to Capture HC1 Emissions from Open
Batch Pickling Tanks 4-8
4-3 Summary of Scrubber System Types in
Pickling Operations .............. 4-26
4-4 Categorization of Reported Scrubbers by
Control Efficiency and Process Type ...... 4-35
4-5 Analysis of 10 Tests of 9 Coil Pickling
Facilities . 4-37
4-6 Descriptive Statistics of 9 Coil Pickling
Facilities . 4-48
xvi
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TABLES (continued)
Number
Page
4-7 comparison of Tests for 7 HC1 Spray
Roasting Facilities • 4~D^
5-1 Model Plant Codes for the Steel Pickling-
HC1 Process Source Category =>-J
5-2 Model Plant Parameters - Continuous Coxl
Pickling Processes (English units) ...... 5-/
5-3 specifications for Packed Tower Scrubbers -
Continuous Coil Pickling Processes (English ^^
units) ,*,**.-,
5-4 Model Plant Parameters -Push-Pull Coil
Pickling Processes (English units) s-j.4
5-5 specifications for Packed Tower Scrubbers -
Push-Pull Coil Pickling Processes (English
... ,...o 5—lo
5-6 Model Plant Parameters - Continuous Rod/Wire
Pickling Processes (English units) 5-2O
5-7 specifications for Packed Tower Scrubbers -
Continuous Rod/Wire Pickling Processes
(English units) .••••••••'
5-8 Model Plant Parameters - Continuous Tube
Pickling Processes (English units) 5 2b
5-9 specifications for Packed Tower Scrubbers -
Continuous Tube Pickling Processes (English
units)
5-10 Model Plant Parameters - Batch Pickling
Processes (English units) 5 Ji
5-11 Specifications for Packed Tower Scrubbers -
Batch Pickling Processes (English units) . . . 5-32
5-12 Model Plant Parameters - Spray Roasting Acid
Regeneration Processes (English unit) 5-J6
5-13 Specifications for Packed Tower Scrubbers -
Spray Roasting Acid Regeneration Processes
(English units) • • • • • • • ' ' ' 5
5-14 The Number of Pickling Operations and Acid
Regeneration Processes Included in the 1992
Industry Survey and Their Baseline Controls . . 5-41
5-15 Characteristics of Facilities Requiring New or
Upgraded Scrubbers • 5~42
5-16 Comparison of Water and Caustic Scrubbing
Media ...
6-1 Summary of Nationwide Environmental Impacts
for Acid Pickling at a MACT Floor of
10 ppmv/97.5 Percent Control Efficiency . . . o-t
6-2 HC1 Emissions and Cost Impacts for Acid
Pickling at a MACT Floor of 10 ppmv/
97.5 Percent Control 6-3
xvi i
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TABLES (continued)
Number Page
6-3 Additional Energy, Solids Disposal, and Wastewater
Treatment Impacts at a MACT Floor of 10 ppmv/97.5
Percent Control Efficiency .... 6-5
7-1 Capital and Annual Costs for Acid Pickling
Scrubber Models at 10 ppmv/97.5 Percent Control
Efficiency 7-2
7-2 Sensitivity of Scrubber Cost to Changes in
Required Efficiency 7-5
7-3 Overview of Available Monitoring Methods for
Scrubbers on Steel Pickling 7-7
7-4 Monitoring Options for Steel Pickling Processes 7-8
7-5 Costs of Monitoring Options for Steel Pickling
Processes 7-11
7-6 Monitoring Costs for Individual Steel
Pickling Plants. 7-12
7-7 Nationwide Monitoring Costs for Individual
Steel Pickling Model Plants .7-13
8-1 Shipments of Steel Mill Products by Grade:
1992 8-3
8-2 U.S. Major Mill Actual and "Break-even"
Operating Rates by Quarters—1981 TO 1986
(percent) ..... 8-8
8-3 Production Costs of U.S. Producers on Their
Operations Producing Hot-rolled Products,
Fiscal Years 1990-92 ....... 8-11
8-4 Hourly Labor Costs in the United States
Steel Industry: 1967-1990 .......... 8-12
8-5 Average Hourly Earnings for Production
Workers in Primary Metals Industry by
State: 1990-1992 ..... 8-13
8-6 Shipments of Steel by Market Classification:
1982-1992 ... ..... 8-16
8-7 Estimated Demand Elasticities for Various
Carbon Steel Products ...... 8-19
8-8 Share of the Six Largest Integrated
Producers in the U.S. Steel Shipments-
1950 to 1986 8-23
8-9 Inland Transportation Costs of Steel Products
by Shipping Distance: 1992 8-25
8-10 Prices Per Ton of Various Steel Mill
Products: 1990-1992 8-26
8-11 Concentration Ratios for Top 4, 8, and 20
U.S. Steel Companies by SIC: 1972, 1977,
1982, and 1987 0 8-28
8-12 Legal Form of Firm Organization in the
Primary Metals1 Industry: 1987 . 8-29
xviii
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TABLES (continued)
Number Page
8-13 Advantages and Disadvantages of the Sole
Proprietorship 8-32
8-14 Advantages and Disadvantages of the
Partnership 8-33
8-15 Advantages and Disadvantages of the Corporation 8-34
8-16 SBA Size Standards by SIC Code for the
Primary Metals Industry 8-35
8-17 Average Size of Facility by
Firm Size Category: 1991 8-36
8-18 Distribution of Firms by Number of Facilities
Owned: 1991 8-36
8-19 SIC Listings for U.S. Steel Companies
Owning Steel Pickling Facilities 8-38
8-20 Financial Experience of U.S. Steel Producers
and Converters: 1991-1992 8-40
8-21 Shipments of Steel Mill Products: 1983-1992 . . 8-42
8-22 Imports of Steel Mill Products (net tons):
1983-1992 8-44
8-23 Imports of Steel Mill Products by Regions of
Origin: 1988-1992 8-45
8-24 Imports of Steel Mill Products by Customs
District (net tons): 1992 8-45
8-25 Domestic Consumption of Steel Mill Products:
1983-1992 8-47
8-26 Exports of Steel Mill Products (net tons):
1983-1992 8-48
8-27 Exports of Steel Mill Products (net tons) by
Destination: 1992 8-50
8-28 Steel Pickling Industry Model Plants Baseline
Emissions and Emission Reductions 8-51
8-29 Steel Pickling Industry Control Costs and
Emission Reductions .... 8-53
8-30 Steel Pickling Industry Per Unit Cost of Emission
Controls 8-56
8-31 Steel Pickling Industry Percent Increase in Cost
of Production and Cost-to-Sales Ratios .... 8-57
xix
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1.0 INTRODUCTION
Steel pickling processes using hydrochloric acid (HC1)
as the pickling medium are potential sources of hazardous
air pollutant (HAP) emissions. These HC1 emissions can
cause adverse noncancer human health effects to exposed
populations.
In 1990, Congress passed amendments to the Clean Air
Act (CAA) that require EPA to promulgate regulations for the
monitoring and control of HAP emissions from certain sources
(defined in Chapter 2). Standards are being developed by
EPA under the authority of Section 112 of the CAA to reduce
air emissions of HC1 from sources in the steel pickling
source category. The standards would apply to owners and
operators of pickling and acid regeneration facilities and
their associated hydrochloric acid storage tanks.
1.1 CONTROL OPTIONS
To select a basis for the proposed standards, EPA
identified and evaluated possible strategies for applying
HC1 emission controls to pickling and acid regeneration
facilities. Each strategy is referred to as a control
option. Each control option defines a unique set of air
emission control levels that allows EPA to perform an
analysis to estimate the nationwide environmental and
economic impacts expected to occur if standards based on a
particular control option were promulgated. The EPA
compares the control option impacts relative to a common set
1-1
-------
of reference values called the baseline. The baseline
represents the estimated human health and environmental
impacts that would occur in the absence of developing the
standards.
The EPA considered three control options, but selected
only one for full analysis. This option would require that
a water scrubber (or its equivalent) be applied to all
pickling emission sources. Emission analyses were carried
out at the MACT floor, the average level at which the twelve
best performing facilities limit their emissions. A
description of the options is given in Chapter 5 of this
document.
1.2 ENVIRONMENTAL IMPACTS
In evaluating the environmental impacts of the scrubber
emission control option, EPA relied primarily on the use of
analytical models. The data required by the models were
obtained from nationwide surveys of the industry and include
characterization of the pickling processes and emissions and
effects of control devices on emission reduction.
Nationwide impacts are estimated by summing individual
facility impacts represented by 17 models that describe the
range of existing facilities. The models are described in
Chapter 5 and Appendix C. Included in the impacts are
estimated emission reductions, their costs, and additional
energy, solid waste, and wastewater quantities resulting
from increased control.
1.3 COSTS AND ECONOMIC IMPACTS
Estimates of the nationwide costs for the scrubber
control option are based on estimates of the control costs
for individual pickling lines or acid regeneration plants
within each model facility. The EPA developed a detailed
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estimate of the total capital investment, annual operating
costs, and total annual costs of each scrubber applied to
each pickling line or acid regeneration facility. To obtain
nationwide costs from model unit costs, each actual facility
was represented by one of the 17 model facilities, and the
estimates from each model were summed. Additional
information on the impacts and costs is presented in
Chapters 6 and 7.
Nationwide, the capital costs of the regulation are
estimated to amount to $20.0 million, and annualized costs
are expected to be $7.1 million.
Cost-to-sales ratios were evaluated on two alternative
bases. The first utilizes all facilities in the industry to
estimate the control cost per ton of steel produced. The
second estimates the per ton cost of control using only
those facilities that will be required to install controls.
Nationally, the control costs for the steel pickling
industry are 0.0329 percent of sales revenues and represent
a 0.0354 percent increase in the cost of production. For
those facilities that will be required to install controls
to meet the MACT standard, the costs represent 0.0515
percent of revenues and an increase in the cost of
production of 0.0554 percent.
The cost-to-sales ratios and percent increase in the
cost of production are well below 1.0 percent for the
industry as a whole and for the portion of the industry
required to incur control costs as a result of this
regulation. The costs on a model-plant basis approximate
1.0 percent or are less than 1.0 percent increase in the
cost of production and as a percent of sales for all model
plants. The magnitude of the costs relative to production
costs of the industry and sales revenues leads to a
conclusion that this standard will not significantly
adversely impact firms in the steel pickling industry. The
results also indicate that a more sophisticated economic
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impact analysis is not required. No plant closures are
anticipated nor significant employment losses. Significant
regional impacts are also not expected.
The Regulatory Flexibility Act (5 U.S.C. 601 et.seq.)
requires the EPA to consider potential impacts of proposed
regulations on small business "entities" and that special
consideration be given to the effects of all proposed
regulations on small business entities. The Regulatory
Flexibility Act (RFA) dictates that a determination be made
as to whether the subject regulation will have a significant
impact on a substantial number of small entities.
Pursuant to section 605(b) of the RFA, 5 U.S.C. 605(b),
the EPA has analyzed the impact of the rule on small
entities. Only four companies in the steel pickling
industry have fewer than 100 employees. Of these four, one
company is expected to meet the standard. Two companies are
projected to be nonmajor sources based on an estimate of
emissions using the ESCO Engineering model along with
information supplied by these firms. It is not anticipated
that these three firms will be adversely impacted by the
regulation. The remaining small firm employs a scrubber
that may meet the emission limitation. If this firm incurs
emission control costs, the costs would likely relate to
upgrading existing equipment or improved maintenance
practices. Any regulatory impacts for this firm are not
expected to be significant. Based on the preceding
information, this regulation will not significantly
adversely impact small business engaged in steel pickling
and acid regeneration.
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2.0 REGULATORY AUTHORITY AND STANDARDS DEVELOPMENT
This chapter presents an overview of EPA's regulatory
framework for controlling hydrochloric acid emissions from
steel pickling facilities. Regulatory authority for the
control of air emissions from pickling facilities under the
Clean Air Act (CAA), as amended is discussed in Section 2.1.
The EPA's standards development plan for controlling
pickling facility air emissions under the CAA is summarized
in Section 2.2.
2.1 REGULATORY AUTHORITY
In November 1990, Congress passed amendments to the
Clean Air Act. Section 112 requires EPA to establish
emission standards for all categories of sources of
hazardous air pollutants (HAPs). These national emission
standards for hazardous air pollutants (NESHAP) must
represent the maximum achievable control technology (MACT)
for all major sources. The CAA defines a major source as:
...any stationary source or group of stationary
sources located within a contiguous area and under
common control that emits or has the potential to
emit considering controls, in the aggregate, 10
ton per year or more of any hazardous air
pollutant or 25 tons per year or more of any
combination of hazardous pollutants.
In July 1992, the Documentation for Developing the
Initial Source Category List1 was published. Steel pickling
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was included as a source category for which the regulatory
process should be initiated. Subsequent action limited the
regulated processes to operations using hydrochloric acid.
Section 112(d) requires that all major sources must
control their emissions to: "...the average emission
limitation achieved by the best performing 12 percent of the
existing sources (for which the Administrator has emissions
information)..." The only HAP requiring control at pickling
facilities is determined to be hydrochloric acid (HC1). The
sources of emissions are pickling tanks, HC1 regeneration
facilities, and HC1 storage tanks. Reduction of HC1
emissions from these sources will reduce non-cancer health
effects in the exposed population.
2.2 STANDARDS DEVELOPMENT FOR STEEL PICKLING - HC1 PROCESS
AIR EMISSIONS
The standards developed for proposal that are supported
by this Background Information Document (BID) would control
air emissions from five types of pickling operations, acid
regeneration facilities, and all HCl storage tanks
associated with pickling and acid regeneration facilities.
The five types of pickling are: continuous coil (strip),
push-pull coil, continuous rod and wire, continuous tube,
and batch.
The potential control options for this source category
are assessed in Chapter 5. The evolution of the standard as
reflected in the evolution of this BID is described in
Appendix A of this document. In the next step of the
standards development process, a draft proposal package will
be assembled and reviewed by the EPA Assistant
Administrators and the Administrator for concurrence before
the standards are proposed in the Federal Register.
Information received and generated in studies in support of
the proposed standard is available to the public in Docket
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A-95-43 on file in Washington, D.C.
As part of the Federal Register notice of proposal, the
public is invited to participate in the standard-setting
process. The EPA invites written comments and, if
requested, will hold one or more public hearing to receive
comments on the proposed standards from interested parties.
All public comments will be analyzed, and written responses
will be prepared. A document will be prepared that
summarizes the comments and provides the Agency's responses.
If public comments indicate that changes to the proposed
standards are warranted, the standards will be revised
accordingly before publication in the Federal Register.
2.3 REFERENCES
1. U. S. Environmental Protection Agency. Documentation
for Developing the Initial Source Category List: Final
Report. Publication No. EPA-450/3-91-030. Research
Triangle Park, NC. July 1992.
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3.0 INDUSTRY DESCRIPTION AND AIR EMISSIONS
3.1 BACKGROUND
During the hot forming or heat treating of steel,
oxygen from the atmosphere reacts with the iron in the
surface of the steel to form a crust that is made up of a
mixture of the following iron oxides: FeO (ferrous oxide),
Fe304 (ferroso ferric oxide) , and Fe2O3 (ferric oxide). The
presence of oxide (or scale) on the surface of the steel is
objectionable when the steel is to be subsequently shaped or
coated. Removing the scale prior to these steps will
preserve the life of drawing dies and give the steel a
better surface quality.
Numerous methods have been used to remove iron oxides
from metal surfaces. These methods include abrasive
blasting, tumbling, brushing, acid pickling, salt bath
descaling, alkaline descaling, and acid cleaning.1
3.1.1 The Pickling Process
This chapter focuses on carbon steel pickling
operations using hydrochloric acid (HC1). Hydrochloric acid
is one of the 189 toxic air pollutants that are subject to
NESHAP. Hydrochloric acid pickling is a chemical process
that uses an HC1 solution (pickle liquor) to dissolve iron
oxides from the surface of steel without any significant
attack on the steel itself. Hydrochloric acid is also used
to clean light rust or to activate the metal surface before
plating; however, this type of operation is not considered a
pickling operation because its acid concentration,
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temperature, and usage rate, as well as emission potential,
are lower than that of typical pickling operations.
Starting in 1964, numerous steel pickling facilities
changed from sulfuric acid to hydrochloric acid. Besides
the advantage of lower costs, HC1 pickling offers faster and
cleaner pickling, lower acid consumption and greater
utilization of the acid, less steam consumption and reduced
quantities of waste pickle liquor, greater versatility, and
more uniform product quality than sulfuric acid pickling.2
The only significant disadvantage of HC1 is its volatility,
which is greater than that of sulfuric acid.
When iron oxides dissolve in HC1 solution, ferrous salt
and water are formed according to the following reactions:3
Fe2O3 + Fe + 6HC1 -» 3FeCl2 + 3H2O
Fe304 + Fe + 8HC1 -*• 4FeCl2 + 4H2O
FeO + 2HC1 -» FeCl2 + H2O
Some of the base metal is consumed in the first two
reactions. Hydrochloric acid also reacts with the base
steel by the following reaction:
Fe + 2HC1 -» FeCl2 + H2
Therefore, an inhibitor is usually added to the acid
solution to inhibit or lessen acid attack on the steel
itself while permitting preferential attack on the iron
oxides.
The rate of pickling is affected by several variables,
including the base steel constituents, the type of adherence
of oxides, acid concentration and ferrous chloride
concentration in the solution, temperature of the solution,
agitation, time of immersion, and the presence of
inhibitors.4 Pickling rate increases as acid concentration
or temperature increases.
As pickling continues, free HC1 is depleted and ferrous
chloride builds up in the pickle liquor to an extent that
pickling can not be accomplished effectively. At that
point, the pickle liquor is discharged from the pickling
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tank to a storage tank, and the pickling tank is replenished
with fresh acid solution. Acid transfer is done either
continuously or in a batch mode.
Several ways exist to manage the waste pickle liquor
(WPL) or spent acid: (1) hauling it away by a processing
company that converts ferrous chloride to ferric chloride
and sells the product as a precipitant to wastewater
treatment plants, (2) treating it on-site with caustics and
hauling the resultant sludge away, (3) regenerating it by an
acid regeneration process on site or at an off-site
facility, and reusing the regenerated acid, (4) recovering
the free acid by several commercially available recovery
systems, and (5) disposing of it by deep well injection.
The selection of the WPL management alternatives is
determined by the governing State or local regulations, the
amount of WPL generated, the proximity of processing or
disposal facilities, space availability, and costs. As
State or local regulations become more stringent, deep well
injection will phase out and will be replaced by other
alternatives. One of the WPL management alternatives, the
acid regeneration process, has the potential of emitting
significant quantities of HCl and chlorine (C12) . A
description of the acid regeneration process is given near
the end of this chapter.
Based on the data reported in a 1992 survey, annual
U.S. pickling capacity was 58.3 million standard tons of
steel, with more than 39.8 million tons actually being
processed. By comparison, U.S. crude steel shipments were
78.8 million tons in 1991. Thus, more than one-half of the
steel produced that year in this country was pickled.
Acid regeneration capacity was 155.6 million gallons
per year; actual production was 98.0 million gallons.
Assuming that 11 pounds of hydrogen chloride (equivalent to
6.8 gallons of hydrochloric acid containing 18 percent HCl)
are required to pickle one ton of steel, approximately 230
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million gallons of 18 percent acid were consumed annually.
Thus, acid regeneration supplied more than 40 percent of
pickling requirements.
The HC1 steel pickling operations are characterized by
the form of metal processed and the type of pickling process
used. The forms of steel pickled include strip (often
called coil), rod, wire, tubing, or pipe, and metal parts of
various shapes. The pickling process is conducted by
continues, semicontinuous, or batch mode. Continuous
pickling processes are used for coils, rod, wire, and pipe
in the sense that the steel material is connected end-to-end
and continuously run through the pickling tanks. The
semicontinuous process, also called push-pull, is usually
used for coils and is an operation in which each coil is fed
through the pickling tanks separately. The batch process is
used for rod or wire in coils, pipes, and me'-al parts. The
material is dipped into the pickling tank lor.g enough for
the scale to be dissolved. Every pickling process is
followed by a rinse stage to remove HC1 residue.
3.1.2 Health Effects of HC1 and C1-,
Hydrogen chloride is a colorless gas or liquid (with
the formation of hydrochloric acid when dissolved in water)
with an irritating odor; it may appear yellow if traces of
iron or organic matter are included.5 Acute effects on
humans exposed by inhalation include coughing and choking,
inflammation and ulceration of the respiratory track, and
chest pain. Gas concentrations of 50 to 100 parts per
million (ppm) are tolerable for 1 hour; a concentration of
1,000 to 2,000 ppm is dangerous, even for a brief period.
Exposure below the eye or taste threshold can cause
sneezing, laryngitis, chest pain, hoarseness, and a feeling
of suffocation. When inhaled in higher concentrations, the
gas may cause necrosis of the tracheal and bronchial
epithelium as well as pulmonary edema, atelectasis, and
emphysema, and damage to the pulmonary blood vessels.
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Prolonged exposure may be fatal. The upper limit of safety
for man is reported in one data base to be about 30 ppm, and
even this level may be harmful if daily exposures were
continued over periods longer than 1 month.6
Chlorine is a yellowish green gas with a distinctive,
pungent odor at normal temperatures and pressures. The
irritating properties of chlorine make it a serious
respiratory hazard, as well as a skin, eye, and throat
irritant because chlorine gas is converted to hydrochloric
acid and "active oxygen" in the lungs. Prolonged exposure
to low concentrations can cause respiratory problems, tooth
corrosion, inflammation of the mucous membranes of the nose,
and susceptibility to tuberculosis. Prolonged exposure at
moderate concentrations can cause decreased lung capacity;
at higher levels chronic poisoning can occur.7 Current
literature reports that the extent of injury depends on the
concentration and duration of exposure as well as the water
content of the tissue involved and the presence of
underlying cardiopulmonary disease. The estimated health
effects at different levels of exposure are: 1-3 ppm
results in mild mucous membrane irritation; exposure to 5-15
ppm may cause moderate irritation of the upper respiratory
track; immediate chest pain, nausea, vomiting, and coughing
occur at a 30 ppm exposure level; toxic pneumonitis and
pulmonary edema occur at 40-60 ppm; exposure to 1,000 ppm
for over 30 minutes can be fatal.8 When inhaled in high
concentrations, the gas can destroy the tracheal and
bronchial epithelium and cause pulmonary edema, atelectasis,
emphysema, and damage to the pulmonary blood vessels. In
addition, one data base reports that "mists of heated metal
pickling solution may cause bleeding of the nose and gums,
as well as ulceration of the nasal and oral mucosa, and
render the skin of the face so tender that shaving becomes
painful."
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3.1.3 Emissions from the Pickling Process
Emissions from pickling process lines are generated in
the pickling and rinse tanks and, to a lesser degree, from
acid transfer operations. Unlike most other stationary
source operations, emissions from pickling lines are almost
independent of the quantity of product being processed.
Acid emissions depend largely on acid bath surface area,
temperature, concentration, ventilation rate (for operations
with hoods or covers and ventilation systems), and degree of
agitation. Agitation is effected by heating, acid flow, and
steel movement through the bath. Bath area is affected by
the width of the steel being pickled (but not by its
thickness) and by line speed for continuous lines (the
higher the line speed, the longer the line). With even
continuous lines operating in intermittent fashion
(utilization rates of about 50 percent to 80 percent), but
with acid baths emitting HC1 continuously, emission rates
based on weight of steel processed are not meaningful.
3.2 PROCESSES AND THEIR UNCONTROLLED EMISSIONS
This section describes the types of pickling processes
and acid regeneration processes found in the industry. The
general arrangement of the processing equipment, operating
conditions, and sources of emissions for each process type
are presented. The information is extracted from responses
to a 1992 industry survey, site visit reports, and contacts
with process engineering firms. This section describes the
sources of pollutants emitted and the factors that influence
the levels and types of those emissions.
3.2.1 Continuous Coil Pickling
Continuously pickled coil comprises more than 80
percent of all steel pickled in the U.S. There are 36 known
facilities with a total of 64 continuous coil pickling lines
in the U.S. The annual processing capacities range from
35,000 to 1,900,000 tons per year (tpy) for a single
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pickling line and from 70,000 to 3,400,000 tpy for a single
facility. Overall maximum capacity for all continuous
pickling lines is approximately 47.1 million tpy, and the
overall actual production rate for 1991 is 27.2 million tpy,
exclusive of confidential data. Most of the larger
facilities or pickling lines are associated with integrated
steel mills. Some facilities have multiple continuous
pickling lines.
The capacity of a pickling line is related to the
thickness and width of coil treated, ability to prepare the
coil for pickling at the entry section and to recoil the
strip at the exit section, and line speeds in various
sections of the line. Maximum strip speeds in the pickling
sections of older lines are typically on the order of 350 to
500 feet per minute (fpm). Maximum speeds in modern lines
range from 1,000 to 1,500 fpm.
Continuous coil pickling lines are capable of handling
coils that are welded head to tail. The entry section
comprises a coil conveyor, one or two uncoilers, one or two
processors, one or two shears, and a welder. Processors are
integral with the uncoiling equipment and consist of a
mandrel, hold-down roll and a series of smaller diameter
rolls. As the strip is flexed through the processor, some
cracking occurs in the scale layer. Proper trimming and
welding of the strips is essential to avoid strip breaks in
the line. The section prior to the pickling tanks uses
bridles for tensioning the strip, a strip accumulator for
strip storage, and a temper mill to crack the scale on the
surface of the strip.
3.2.1.1 Horizontal Pickling Tanks. Continuous
pickling on a high speed line requires extensive storage of
strip within the line to maintain continuous operation of
the pickling section during subsidiary operations. These
operations include coil loading, end cropping, and strip
joining at the entry end of the line and strip shearing and
coil removal at the exit end. Storage areas such as fixed
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looping pits or movable looper cars are provided for the
strip before and after the pickling section. Figures 3-1
and 3-2 are side views of continuous coil pickling lines
with looping pits and looper cars, respectively, which are
shown before and after the tank sections.
Host continuous coil pickling is done in a series of
horizontal pickling tanks. The sizes of the pickling tanks
are determined by the operating conditions for pickling the
strip. The pickling section is usually several hundred feet
long and divided into 3 or 4 horizontal pickling tanks.
Virgin or regenerated acid is added to the last tank with or
without makeup water; then the pickle solution cascades to
the first tank over weirs between tanks, flowing
countercurrently to the moving direction of the strip. To
allow a short pickling time at high line speed, the pickling
liquor is maintained at 180 °F or higher by live steam
injection or by internal or external heat exchange. A rinse
section follows the pickling section to remove acid residue
from the strip surface with fresh water. A drier follows
the rinse section to dry the rinsed strip with heated air.
At the exit end of the line, there are usually an exit strip
accumulator, steering rolls, a strip inspection station,
dual side trimmers, an oiler, and one or two recoilers.
In some modern lines the pickling solution is contained
in shallow tanks and, although they comprise a cascade
system, the solution in each tank is recirculated through an
external heat exchanger and a storage tank. During an
extended line stop the pickling solution can be drained into
storage tanks to prevent acid attack on strip. For older
lines, strip lifters are provided to lift the strip from the
acid solution during an extended stop.
3.2.1.2 Emissions and Controls for Continuous Coil
Pickling Lines. When heated, the pickle liquor vaporizes
and emits HC1 fumes; therefore, the pickling and rinse
sections are usually covered and the acid fumes are captured
3-8
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by induced-draft (ID) fans. Acid fumes are through ductwork
and treated by control devices to remove HCl. Inlet
concentrations at the control device range from less than
100 parts per million by volume (ppmv) to more than 5,000
ppmv. Controlled annual emissions range from less than
1 tpy to more than 200 tpy, depending on facility size and
control effectiveness.
The majority of the facilities use a packed tower
scrubber, sieve tray scrubber, or horizontal packed bed
scrubber, each coupled with a demister, for HCl emission
controls. Actual control efficiencies for older control
systems are usually not known. Most newer scrubbers are
designed for 95 to 98 percent control efficiency. A few
scrubbers are designed for 99.9 percent control efficiency.
Only two facilities (6 pickling lines) have no emission
control devices. The control devices use rinse section
effluent, process water, city water, or a neutralized
solution as the scrubbing medium. Scrubber effluent is
reused in the pickling line as makeup water, reused in other
processes, pretreated onsite and discharged to a publicly
owned treatment work (POTW), or treated in an onsite
wastewater treatment plant.
Except for a few new lines, most of the continuous
pickling lines were built before the 1970s. However, new
emission control systems have been installed on these older
lines.
Acid storage tanks are also a potential source of
emissions. A typical facility has several storage tanks for
fresh acid and for spent acid. The tanks are closed, but
emissions from tank vents are caused by working losses
(filling the tank) and breathing losses (expansion of the
tank contents as the tank heats during the day). Working
losses occur for short time periods (minutes) up to several
times per week, while breathing losses occur through the day
during times of increasing temperature. A typical tank may
be 12 ft in diameter and 17 ft in height. Uncontrolled
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storage tank emissions may be on the order of 0.07 to 0.4
tpy of HC1 per tank, depending on tank size and usage.
At older facilities tanks may be vented to the
atmosphere. However, at newer facilities the tank vents are
commonly routed to the pickling line scrubber. This
arrangement prevents both working and breathing losses from
escaping to the atmosphere and emissions may be reduced to
about 0.03 to 0.06 tpy depending on tank size and usage.
3.2.1.3 Trends in Continuous Coil Pickling Facilities.
The trends in process or equipment modifications include:
replacing live steam injection with heat exchangers,
replacing old scrubbers with other types such as sieve tray
scrubbers that generate less scrubber effluent (blowdown),
venting storage tank emissions to an emission control
system, or reusing rinse effluent or scrubber blowdown to
reduce waste quantity and to lower treatment costs. With
proper maintenance, existing continuous pickling lines are
expected to operate for many more years. However, the
introduction of new pickling capacity may diminish as steel
processing declines in the U.S.
3.2.1.4 Vertical Spray Towers. A second, less
popular, type of continuous coil pickling operation uses a
vertical spray tower, where pickle liquor is sprayed onto
moving strip in multiple vertical passes in an enclosed
tower. Spray rinsing is done in a similar fashion with
fresh water. Currently, there are only three operating
units in the country. Two are stand-alone processes, the
other is associated with a continuous annealing process
line. Acid emissions from vertical spray towers are
controlled by scrubbers similar to those used for horizontal
continuous coil pickling operations.
3.2.2 Push-Pull Coil Pickling
There are 19 known facilities with a total of 22 push-
pull coil pickling lines in the U.S. The newest plant
opened in 1992. The annual processing capacities range from
110,000 to 1,300,000 tpy for a single line and also for a
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single facility. The majority of the push-pull pickling
lines are associated with mini-mills or the steel service
industry, which cleans, splits, and cuts coils to specific
customer requirements. One facility has 2 and one has
3 lines; the remaining 17 facilities each have one line.
Overall maximum capacity for all push-pull pickling lines u
8.28 million tpy, and overall actual production rate for
1991 was 4.47 million tpy.
Push-pull coil pickling lines have mechanical
arrangements similar to horizontal continuous coil pickling
lines except that push-pull lines do not have welders at the
entry sections nor storage areas for the strips. Each coal
is threaded through the process line separately. Figure 3-3
shows a side view of a push-pull pickling line. The
pickling tanks of a push-pull line are generally shorter
than those of a continuous line because the line speed
during pickling (from about 250 to 660 fpm) is usually
slower than that of a continuous line. Other operating
procedures of a push-pull line are similar to those of a
continuous line. The pickle liquor is usually maintained at
180 °F or higher by external heat exchangers. A rinse
section follows the pickling section to remove acid residue
from the strip surface with fresh water. The spent acid is.
managed by onsite neutralization, reuse as a flocculent in
wastewater treatment plants, or regeneration.
3.2.2.1 ^missions and Conl-rols for Push-Pull Pickling
Lines." Emissions from push-pull lines are similar to those
from continuous coil lines except as modified by slower
processing speeds and shorter pickling sections.
Concentrations at the inlet to the scrubber are in the range
of less than 700 ppmv to more than 3,000 ppmv, while annual
controlled emissions may range from less than 1 to about 1O
tpy. Although the concentration range for the two tested
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push-pull operations is smaller and within the range for
continuous coil operations, it is not clear that a
fundamental difference in emission potential exists between
the two types of operations. A comparison of emission
estimates for the two types of lines is given in
Section 3.5.2.
The emission control systems for push-pull pickling
lines are similar to those for continuous pickling lines.
Twenty-five emission control devices are use by the 19
facilities for HCl emission controls; including 10 sieve
tray scrubbers, 13 packed tower scrubbers, and 2 horizontal
packed bed scrubbers. As found for continuous coil
pickling, most newer emission control systems are designed
to remove from 98 percent to as high as 99.9 percent HCl.
The control devices use rinse section effluent, conditioned
surface water, or city water as the scrubbing medium.
Scrubber effluent is reused in the pickling line as makeup
water, pretreated onsite and discharged to a POTW, or
treated in an onsite wastewater treatment plant.
3.2.2.2 Trends in Push-Pull Pickling Facilities.
Except for a few older lines, most of the push-pull pickling
lines were built in the 1980s and in the early 1990s. The
trends in push-pull line process design are: (1) installing
shallow pickling tanks, (2) using external heat exchangers
for heating pickle liquor, (3) providing circulation tanks
for pickle liquor during line stoppage, and (4) combining
emissions from acid storage and circulation tanks for
treatment in the same emission control system for the
pickling line. With improved loading, uncoiling, and
coiling mechanisms, a new push-pull pickling line may reach
an annual capacity of 1 million tpy, which is comparable to
a continuous line. The push-pull operation is the pickling
process of choice for the steel service industry because
coils of various sizes and gages can be handled and less
capital investment is required than for a continuous
pickling operation of comparable size.
3-15
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3.2.3 Continuous Tube. Rod, and Wire Pickling
Approximately three percent of steel pickled is
processed by these types of operations. There are 24 known
facilities with a total of 66 continuous tube/rod/wire
pickling lines in the U.S. Four facilities that pickle rod
or wire also conduct batch operations. It is estimated that
these 24 facilities represent 70 to 80 percent of the total
operating facilities of this type in the U.S. The annual
processing capacities range from 120 to 156,000 tpy for a
single pickling line and from 380 to 421,000 tpy for a
single facility. Most facilities have multiple process
lines of similar capacities. Continuous tube/rod/wire
pickling operations are grouped together because the
dimensions of their pickling sections and the gas flow rates
in the enclosed capture systems are similar and are smaller
than those of coil pickling operations. The difference in
these operations is that usually multiple wiias are
simultaneously treated in a process line, while a single
tube is treated per process line.
Reported capacity for continuous tube, rod, and wire
facilities is 1.56 million tpy. Reported processing rate
for 1991 was 1.12 million tpy.
The capacity of a tube pickling line is related to the
tube outside diameter, gauge, and the speed of the line.
The capacity of a rod/wire pickling line is related to the
wire gauge, the number of wires that can be processed
simultaneously, and the line speed.
Continuous tube pickling prepares a clean surface on a
continuously welded tube before cold drawing or tube
reducing to preserve the life of a die or before final
galvanizing. Similarly, continuous rod pickling removes
oxide or scale from a continuous rod before drawing to
preserve the life of a die. Once a rod is drawn through a
die, it is called wire. Continuous wire pickling prepares a
clean wire surface for subsequent coating such as
galvaniz ing.
3-16
-------
In the continuous tube/rod/wire pickling process, the
steel products are continuously pulled through an acid
solution and rinsed to remove acid residues in a manner
similar to a continuous coil pickling process. In
continuous wire/rod pickling, several strands of wire or rod
are uncoiled from pay-off reels, simultaneously pickled in
one or two shallow pickling trays, rinsed in a following
rinse tray to remove acid residues, then followed by drawing
or coating. Depending on the size of the material, as few
as 6 rods or as many as 40 wires may be processed at the
same time. Pickle liquor is replenished to and drained from
the pickling trays continuously. In continuous tube
pickling processes, a welded tube is immersed in an enclosed
pickling trough that is placed in a covered empty tank.
Pickle liquor is replenished at the trough and overflows
from the trough through drainage holes to an external tank,
from which the pickle liquor is transferred to spent acid
storage tanks. Depending on the temperature of the incoming
steel material, the pickle liquor may need to be cooled or
heated for effective pickling. Heating can be done by live
steam injection or by external heat exchange, and cooling
can be done by external heat exchange. The spent acid is
managed by onsite neutralization, pretreatment and discharge
to a POTW, or removal by waste disposal contractors.
3.2.3.1 Emissions and Controls for Tube/Rod/Wire
Pickling Lines. Emissions from continuous tube/rod/wire
pickling lines are assumed to be similar to those from
continuous coil or push-pull coil operations in terms of
concentration at the inlet to the control device. However,
much smaller gas flow rates are used because the lines are
physically smaller. No measurements by the EPA Method 26A
are available for verification. Annual emissions, many from
uncontrolled facilities, are estimated to range from less
than 1 to more than 45 tpy.
Acid fumes from the pickling and rinse sections are
exhausted through an enclosed capture system and then either
3-17
-------
led to an emission control system or released uncontrolled
to the atmosphere. Eleven of the twenty known tube/rod/wire
facilities have emission control systems with reported
control efficiencies ranging from 95 to 99 percent. Packed
tower scrubbers, horizontal packed bed scrubbers, and tray
scrubbers are used for emission controls by these
facilities.
3.2.3.2 Trends in Continuous Tube/Rod/Wire Pickling
Facilities. Continuous tube/rod/wire pickling processes
have been used in their present general form for decades.
Future improvements for this type of operation may include:
(1) installing water curtains on both ends of the enclosure
on the pickling section to prevent acid carry-over or fume
escape, (2) using external heat exchange for heating pickle
liquor, and (3) installing emission control systems on
processes that are currently uncontrolled.
3.2.4 Batch Pickling
There are 26 known facilities that operate a total of
59 batch pickling processes in the U.S. Eight facilities
use HC1 batch pickling as a metal surface cleaning or
etching process for various metal shapes prior to applying
surface coatings such as galvanizing. The other 18
facilities, with a total of 37 process units, perform rod or
wire batch pickling to remove oxide or scale from the
material. Generally, the acid solution is maintained at
ambient temperature for surface cleaning or etching and at
an elevated temperature for oxide removal. Acid fume
emission potential is higher at elevated temperatures (up to
120°F). It is not clear what fraction these facilities
represent of the total number of facilities operating in the
U.S. The annual processing capacities range from less than
1 to 100,000 tpy for a single batch pickling process and
from 50 to 170,000 tpy for a single facility. Most
facilities have multiple process units. Overall capacity
3-18
-------
for batch pickling is 1.25 million tpy, while reported
production for 1991 was 0.85 million tons.
in the batch pickling process, the steel is immersed in
an acid solution for 10 to 30 minutes until the scale or
oxide film is removed, lifted from the bath, allowed to
drain, then rinsed by subsequent immersion in one or more
rinse tanks or by spraying. Steel rod and wire in coil form
(up to 3,000 Ib) can be pickled in a batch operation. Tubes
or flat sheets can be batch pickled but the sheets must be
held vertical and physically separated to improve acid
contact.
Typical HC1 concentrations in the batch pickling
process ranges from 12 percent at the beginning of a fresh
batch to 4 percent before acid replacement. A fresh batch
of acid solution is used until the iron concentration of the
solution reaches the maximum allowable concentration (about
13 percent by weight) or until the free HC1 becomes
insufficient for proper scale removal. Acid and iron
concentrations are monitored by the operator a few times a
day. When the acid solution is no longer effective, the
spent acid is drained or pumped to storage tanks and a new
batch of acid solution prepared. For surface cleaning or
etching, immersion time ranges from 5 to 15 minutes with the
acid bath at ambient temperature. For oxide or scale
removal, the immersion time may range from 10 to 30 minutes
and the acid bath may be heated to 120 °F. Heating is done
by live steam sparging or internal heat exchange. The spent
acid is managed by onsite neutralization, pretreatment and
discharge to a POTW, or removal by waste disposal
contractors.
3.2.4.1 Emissions and Controls for Batch Pickling
Tanks. Acid and steam fumes rise from the open surface of
the pickling tank and from the surface of the pickled
material as it is transferred from the pickling tank to the
next process. The emission control systems for open-top
3-19
-------
batch pickling usually include emission capture devices,
such as lateral exhaust hoods (which will not interfere with
crane operation), and are followed by emission control
devices. One emission control device may handle acid fumes
collected from multiple batch pickling units. Because of
the non-enclosure capture system, a high exhaust rate is
needed to capture the fumes. This high exhaust flow rate
may result in dilute HCl concentration in the captured gas
stream compared to continuous pickling lines. However,
measurements are not available to provide a range of
concentrations. Annual emissions are estimated to range
from less than 1 to more than 27 tpy. Many of the batch
operations are not controlled.
Three of the 11 known batch operations pickling
miscellaneous metal shapes have emission control systems
with reported control efficiencies ranging from 92 to 99
percent. Six of the 11 facilities performing batch pickling
for wire and rod have emission control systems with reported
control efficiencies ranging from 75 to 97 percent.
Facilities having large capacities or process units tend to
have emission control systems.
3.2.4.2 Trends in Batch Pickling Facilities. Rinsing
was formerly done in a series of rinse tanks; however, the
rising costs of rinse water, rinse water treatment, and
disposal, may drive the operators to use improved spray or
dip rinse systems that can use a minimum amount of water
effectively. The emission potential of batch operations for
surface cleaning or etching at ambient temperature is lower
than that for oxide or scale removal at an elevated
temperature. If acid fumes are a concern in the work place,
they are usually exhausted through a capture device.
Currently, more than half of the batch wire pickling
facilities are uncontrolled. Future developments may
include: (1) tank enclosures, (2) surface blanketing of
open tank surfaces with plastic balls, and (3) installation
3-20
-------
of fume exhaust and emission control systems to curtail acid
fume emissions.
3.3 ACID REGENERATION PROCESSES
3.3.1 Existing Acid Regeneration Facilities
Information is available for 10 operating acid
regeneration plants in the U.S. Annual capacities range
from 3.2 million gallons per year (gpy) to 39.8 million gpy
for a single facility. One facility has three identical
process units and one has two units; the other eight
facilities each have one process unit. One operation is a
commercial acid regeneration plant that acts as a toll
operator for area picklers, another plant is owned and
operated by a contractor not directly associated with the
steel mill, and the remaining eight plants are captive to an
associated pickling facility.
3.3.2 Process Description for Acid Regeneration Systems
The spray roasting acid regeneration process dominates
the current market; only one facility, which was built in
1974, uses a fluidized bed roasting process. However, a
second fluidized bed roaster is being installed to replace a
spray roaster. These two acid regeneration processes are
similar in chemical reaction principles but are different in
roaster designs and the quality of iron oxide produced.
Figure 3-4 shows a typical spray roasting acid
regeneration process flow chart. Incoming waste pickle
liquor (WPL), at 2 to 4 percent HC1, is first stored in
storage tanks. Liquor from the storage tanks first comes in
contact with hot flue gas from the spray roaster in a
venturi preconcentrator where HC1 in the hot flue vaporizes
some of the water in the WPL, which becomes concentrated
pickle liquor (CPL). Concentrated pickle liquor is pumped
to the spray roaster and atomized through spray nozzles.
The droplets fall through the rising hot gases in the
3-21
-------
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roaster, and ferrous chloride in the droplets reacts with
oxygen and water vapor to form ferric oxide (Fepj) and HCl.
Heat for the reaction is provided by natural gas burners
mounted in the lower cylindrical section of the roaster.
The burners tangentially inject hot gas at 1,200 °F into the
roaster. As the hot gas rises, it is cooled by the
reactions, and leaves the roaster top at approximately
700 °F. Chlorine is a non-desirable byproduct from the
oxidation process, which is formed by excess air provided
for the reaction. Chlorine may exit the process as a
residue in the iron oxide product or as a component of the
gas emissions.
Iron oxide is removed from the bottom of the roaster
and transferred into a storage bin. The storage bin is
usually equipped with a pulse-jet fabric filter (baghouse)
on top to prevent the escape of dust with the collected dust
being returned to the bin.
From the roaster, flue gas containing HCl either passes
through a cyclone to separate heavier metal oxide particles
or proceeds directly to the venturi preconcentrator, where
the flue gas is cooled and cleaned by direct contact with
fresh WPL plus recirculated CPL. Entrained CPL droplets are
removed from the preconcentrator and returned to the roaster
feed tank, while the HCl laden gas is scrubbed in one or two
absorbers. The absorber is a counter-current packed tower
where process water is sprayed across the top of the packing
while HCl laden gas flows upward and contacts the scrubbing
solution. The scrubbing solution absorbs HCl from the gas
to produce regenerated acid containing approximately
18 percent HCl by weight. Regenerated acid is pumped from
the bottom of the absorber to storage tanks.
3.3.3 Emissions and Controls for Acid Regeneration Plants
Gas leaving the absorber contains some residual HCl and
C12. Concentrations of HCl are on the order of 11,000 ppm
or less depending on the recovery efficiency of the
3-23
-------
absorber. Annual emissions range from about 1 to more than
10 tpy from existing controlled and uncontrolled facilities.
According to the few reliable measurements available,
concentrations of C12 are from less than 10 to 60 ppm at the
inlet of the scrubber and concentrations of C12 at the
scrubber outlet range from less than 1 to 60 ppm. Caustic
scrubbing solution seems to remove more C12 than plain water
scrubbing. Annual emissions of C12 have not been reported,
but are estimated to be as high as 32 tpy for a single
facility.
The gas from the absorber is further treated in an
emission control system to remove HC1. Plants built before
the 1980s are equipped with a single packed tower scrubber.
One facility, built in 1990, has one large packed tower
scrubber using plain water, followed by a small packed tower
scrubber using caustic solution. A plant built in 1989 is
equipped with a venturi scrubber using caustic solution to
scrub HC1. This scrubber also serves as a secondary control
device for particulate emissions from baghouses on the iron
oxide storage bin. The venturi scrubber was installed to
meet stringent state emission standards.
Plain water scrubbing is not effective in removing C12.
A metal oxide producing facility has a spray roasting unit
that uses sodium thiosulfate and Na2CO3 solutions as the
scrubbing media and apparently is able to reduce C12 to less
than the detection limit of the test method. This plant is
the only spray roasting acid regeneration facility that
operates an emission control system specifically designed
for C12 reduction.
Acid regeneration plants usually have spent acid and
fresh acid storage tanks similar to those at pickling
plants. These tanks are potential sources of emissions if
not vented to a scrubber. Emission quantities are estimated
to be similar to those from pickling plant tanks. In some
3-24
-------
cases, acid is pumped to and from the pickling facility
tanks and is not stored at the acid regeneration unit.
3.3.4 Tr-ends ir Acid Regeneration Systems
The only fluidized bed acid regeneration plant (built
in 1974) is investigating alternatives to replace their
aging process units. The spray roasting process seems to be
the predominant commercialized process for regenerating
large volumes of spent liquor. This process can be
considered either as an acid regeneration process or as a
metal oxide production process. In terms of metal oxide,
the current market for oxide generated from the existing
process feeds is saturated. Future development is to
improve the quality of the metal oxide by removing
impurities from the spent liquor feed. The market for
better quality metal oxide seems to be more diversified and
less competitive at the present time compared to previous
years. Chlorine emissions from the process may be a concern
that could be addressed either by controlling process
parameters (i.e., maintaining an appropriate amount of
excess air in the roaster) or by improving emission control
systems (i.e., using effective scrubbing solutions).
3.3.5 Fluidized Bed Roasting Acid Regeneration9'10
This process consists of a fluid bed reactor, cyclone,
pre-evaporator, absorber, and scrubber. The process flow
chart for the fluidized bed process is very similar to that
for a spray roasting process shown in Figure 3-4. Dempster
and Gomaa10 describe the process:
The waste pickle liquor is concentrated in
the pre-evaporator and is then fed into the
reactor. There, the complete vaporization of the
water and decomposition of the iron chloride into
iron oxide and hydrogen chloride gas takes place
in a fluid bed at a temperature of approximately
1500 °F. In the reactor a bed of small iron oxide
pellets is fluidized by a flow of combustion
gases.
The hydrogen chloride gas is driven off along
with some iron oxide particles entrained in the
3-25
-------
gas stream. The solid particles are separated in
a cyclone, are returned directly to the reactor,
and grow in size to form spherical pellets which
are continuously removed from the reactor as by-
product. The gases from the cyclone, after
cleaning and cooling in the pre-evaporator, are
passed to an absorption column in which
hydrochloric acid is formed.
The resulting regenerated hydrochloric acid
is returned to the pickle line. The remaining
gases leaving the absorption tower are scrubbed
and cooled if required and vented to atmosphere.
Almost all of the acid is recovered and recycled
within the pickling regeneration system.
Advantages claimed for the fluidized bed system over
spray roasters are greater fuel economy, simpler absorber
construction, and elimination of problems in handling by-
product iron oxide dust and high-pressure spray systems for
hot acids. However, the quality of the metal oxide produced
by the fluidized bed process is inferior to that produced by
the spray roasting process.
Emissions of HCl from one of the four fluidized-bed
units in the single facility are 1.81 x 1CT6 Ib/dscf or 19.1
ppmv. These values represent a mass emission rate of 0.66
Ib/hr of HCl from one fluidized bed unit.
3.4 ACID RECOVERY PROCESSES
Three process, representing ways to recover usable free
HCl from the spent acid, are briefly described below. None
of these processes is widely used for large HCl pickling
operations because they recover only the remaining 2 to
3 percent free HCl from the spent acid and leave more
concentrated ferrous chloride in the solution that requires
further conversion or disposal. These acid recovery
processes usually are closed-loop process units that do not
emit HCl.
3-26
-------
3.4.1 Evaporation/Condensation Processes11
Spent acid is pumped to one or more storage tanks, from
which it is fed to a steam heated evaporator. A heat
exchanger is used to preheat the feed using concentrated
effluent from the evaporator as the heating medium. Most of
the HC1 leaves the evaporator in the vapor stream, from
which it is sent to an acid recovery column. The column
separates the incoming vapor into an overhead water stream
and a liquid stream containing 15 percent hydrochloric acid.
This latter stream is cooled, stored, and recycled to the
pickling operation.
The liquid stream from the evaporator contains about 40
percent FeCl2, but is diluted to about 30 percent, cooled,
and stored for sale.
The overhead water stream from the recovery column has
up to 10 ppm HC1 by weight, which is neutralized with
caustic to prevent process overloads in subsequent waste
treatment steps. This water is then recycled to the
pickling line. Sludge accumulates in the feed tanks and is
removed once or twice per year. The sludge, which contains
iron values, may be sent to acid regeneration facilities for
recovery as iron oxide.
3.4.2 Resin Adsorption Processes12
Spent acid is pumped through a filter to remove sludge.
The clarified stream is then sent through a bed containing
resins of proprietary composition that adsorb acid molecules
but reject dissolved salt ions. The FeCl2-rich stream is
available for sale if customers can be found, or it can be
neutralized and disposed of. It is likely that a
concentration step would be necessary prior to selling the
iron stream product.
When the resin reaches its working capacity limit, it
is backflushed with fresh water to produce HC1 solution at
the strength used by the pickling process. The resin is
long-lived and needs only infrequent replacement.
3-27
-------
3.4.3 Refrigeration/Crystallization Processes13
Spent acid is pumped through a heat exchanger to reduce
the temperature, then through two additional stages of
refrigeration to an agitated slurry tank. The low
temperature in the tank causes FeCl2 to crystalize. The
crystals are separated from the slurry and washed in a
centrifuge operation, then are discharged to a concentrated
FeCl2 solution tank. The solution may be sold or discarded.
The liquid stream from the centrifuge is used as the
coolant in the heat exchanger, then is pumped to storage
tanks or directly back to the pickling tanks.
3.5 BASELINE EMISSIONS
3.5.1 Summary of Federal and State Regulations
No explicit Federal air regulations exist for steel
pickling operations using HC1. However, because some acid
mist may be released, States may choose to apply Federal
particulate standards based on ambient air quality
considerations.
Among the States, those that regulate HC1 pickling
emissions do so primarily on a case-by-case basis. Permits
are issued after an existing control device is tested, and
the results of the test help to set particulate and HC1
emission limitations. States that regulate in this manner
include Indiana and Illinois. States that also regulate HC1
include Tennessee and Utah. These states have issued
permits to individual facilities specifying emission
limitations ranging from 0.73 Ib/hr to 3 Ib/hr of HC1.
Pennsylvania permits require facilities to operate in a
manner consistent with good operating and maintenance
practices but does not specify emission limits. Texas
requires only that opacity from scrubber exhausts not exceed
20 percent.
3-28
-------
At least 19 States and Territories have established
ambient air limits for HCl; these are values for allowable
limits outside the facility boundaries or in adjacent
neighborhoods downwind from the source of the chemical. As
shown in Table 3-1, the ambient limits vary widely.
Chlorine is emitted in low quantities as an unwanted
by-product of the acid regeneration process. While no
States are known to control C12 emissions from acid
regeneration operations, at least 16 States (many being the
States shown in Table 3-1) have established ambient air
limits. These limits are shown in Table 3-2. Like HCl, C12
is a designated hazardous substance under section 311(b) of
the FWPCA with a reporting threshold of 10 pounds (see 40
CFR 116.4) and is listed as an extremely hazardous substance
under CERCIA at 40 CFR 355, Appendix B with a reportable
quantity threshold of 10 pounds. The OSHA threshold level
defining a catastrophic event is 1,500 pounds. Occupational
exposure is limited to a ceiling limit of 1 ppm or 3 mg/m3.
3.5.2 National Emission Estimates
This section presents national baseline emission
estimates for four types of pickling, for acid regeneration,
and for storage tanks. The estimates were developed from a
combination of emission factors obtained through source
tests and regulatory requirements at the Federal and State
level.
Baseline emissions are estimated from uncontrolled
emissions adjusted for the impact of current Federal and
State regulations and additional controls known to be in
place. Table 3-3 shows the estimated annual emissions for
each type of pickling operation, for acid regeneration
facilities, and for storage tanks.
3-29
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TABLE 3-1. AMBIENT AIR LIMITS FOR HC1, BY STATE
14
State
AZ
FL
LA
MA
ME
NC
ND
NV
NY
OK
PRC
RI
SC
SD
TX
VA
VT
WA
Ambient Air Limit (#tg/m3)
0.5 hr 8.0 hr. 24 hr
160 (1 hr) 53
70 16.8
180
2.03
2,000 (1 hr)
700 (15 min)
75 (1 hr)
167
700
50 15
2,000 (1 hr) 600
175
140
75
63
16.7
23.3
Annual
0.007
2.03
7.0
0.1
3-30
-------
TABLE 3-2. AMBIENT AIR LIMITS FOR C12, BY STATE15
Ambient Air Limit
0.5 hr 8.0 hr
AZ 69 (1 hr) 60
CT 60
FL 15-30
KS
LA 35-7
MA
ME 300 (15 min)
NC 900 (15 min)
ND 29 (1 hr) 15
NV 71
NY
OK
PRC 100
SC
TX 15
VA
VT 30
24 hr
23
3.6
7.14
3.95
60
37.5
15
30
75
25
Annual
0.007
3.95
3.5
15
3-31
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3-32
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3.6 SUMMARY OF INDUSTRY DATA
Tables 3-4 through 3-13 provide data on existing pickling
and acid regeneration facilities, their distribution, and their
'capacities. For capacity and 1991 processing rates, individual
lines are shown for each facility. Table 3-13 lists air
pollution control devices used for each segment of the industry.
3-33
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TABLE 3-4. STEEL PICKLING AND HYDROCHLORIC ACID REGENERATION
FACILITIES PROVIDING INFORMATION UNDER SECTION 114 REQUESTS
Facility
ID No.
Name
Location
1
2
3
4
5
6
7
8
9
10
11
12
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Wiremil, Inc.
Kasle Steel Corp.
Samuel-Whittar, Inc.
National Galvanizing, Inc.
Wheeling Pittsburgh Steel Corp.
HS Processing Co.
Omega Tube and Conduit Corp.
Goodyear Tire and Rubber Co.
Allied Tube and Conduit Corp.
Wheeling Pittsburgh Steel Corp.
Valley City Steel Co.
LTV Steel Co., Inc.
American Spring Wire Corp.
LTV Steel Co., Inc.
CF & I Steel Corp.
WCI Steel, Inc.
Northwestern Steel and Wire Co.
Page Aluminized Steel Corp.
Armco Steel Co.
Keystone Seneca Wire Cloth Co.
Trinity Industries, Inc.
National Wire Products Industries
Voss Steel
Smith Industries, Inc.
National Standard Co.
Bethelehem Steel Corp.
Heidtman Steel Products, Inc.
Cargill Steel and Wire, Inc.
Dana Corporation
Sanderson, FL'
Dearborn, MI
Detroit, MI
Monroe, MI
Yorkville, OH
Baltimore, MD
Little Rock, AR,
Randleman, NC
Harvey, IL
Allenport, PA
Valley City, OH
East Chicago, IN
Kankakee, IL
Cleveland, OH
Pueblo, CO
Warren, OH
Sterling, IL
Monessen, PA
Ashland, KY
Hanover, PA
Lima, OH
Baltimore, MD
Taylor, MI
Houston, TX
Stillwater, OK
Johnstown, PA
Erie, MI
Nashville, TN
Antwerp, OH
3-34
-------
TABLE 3-4. (Continued)
Facility
ID No.
Name
Location
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
, 55
56
57
58
59
60
Armco Advanced Materials Co.
Bethelehem Steel Corp.
Mount Joy Wire Corp.
Commonwealth Industries
U.S. Department of Energy (Y-12)
Midwest Steel
Carpenter Technology Corp.
Carpenter Technology Corp.
Indiana Pickling and Processing
Inland Steel Co.
National Standard Co.
Amac Enterprises, Inc.
Granite City Steel
Gulf States Steel, Inc.
Bethlehem Steel Corp.
Bethlehem Steel Galvanizing Mill
Weirton Steel Corp.
National Steel corp.
Armco Steel Co.
Sherman Wire, West Plant
Granite City Pickling & Warehouse
American Spring Wire Corp.
Teledyne Pittsburgh Tool Steel
Rappahannock Wire Co.
Sherman Wire, East Plant
L-Tec Welding Materials
Empire-Detroit Steel
Keystone Steel and Wire
Gulf Coast Galvanizing, Inc.
Samuel Steel Pickling Co.
Butler, PA
Sparrows Point, MD
Mount Joy, PA
Detroit, MI
Oak Ridge, TN
Portage, IN
Orangeburg, SC
Reading, PA
Portage, IN
East Chicago, IN
Niles, MI
Parma, OH
Granite City, IL
Gadsden, AL
Lackawanna, NY
Lackawanna, NY
Weirton, WV
Ecorse, MI
Middletown, OH
Sherman, TX
Granite City, IL
Bedford Heights, OH
Monaca, PA
Gallatin, TN
Sherman, TX
Ashtabula, OH
Dover, OH
Peoria, IL
Citronelle, AL
Cleveland, OH
3-35
-------
TABLE 3-4. (Continued)
Facility
ID No.
Name
Location
80 Florida Wire and Cable Co.
81 National Processing
82 Wheeling Pittsburgh Steel Corp.
83 LTV Steel Co., Inc.
84 Sherman Wire
85 Nucor Steel
86 Sharon Steel Corp.
100 Maneely-Illinois, Inc.
101 Worthington Steel
102 Copperweld Steel Co.
103 Allied Tube and Conduit Corp.
104 Steel Processing, Inc.
105 Acme Steel Co.
106 C-K Company
107 Heidtman Steel Products, Inc.
108 Paulo Products Co.
109 Bethlehem Steel Corp.
110 Amber Plating Works, Inc.
Ill Double Eagle Steel Coating Co.
112 Steel Warehouse Company, Inc.
113 Indiana Steel and Wire Co.
114 USS POSCO Industries
115 Worthington Steel
116 Toledo Pickling and Steel Sales
117 Thomas Processing Co.
118 Chicago Steel and Wire Co.
119 National-Standard Co.
120 Paulo Products Co.
121 Wheeling Pittsburgh Steel Corp.
122 California Steel Industires, Inc.
Jacksonville, FL
East Chicago, IN
Martins Ferry, OH
Hennepin, IL
Caldwell, TX
Crawfordsville, IN
Farrell, PA
Chicago, IL
Porter, IN
Warren, OH
Philadelphia, PA
Pottstown, PA
Riverdale, IL
South Boston, VA
Granite City, IL
Murfreesboro, TN
Burns Harbor, IN
Chicago, IL
Dearborn, MI
South Bend, IN
Muncie, IN
Pittsburg, CA
Monroe, OH
Toledo, OH
Warren, OH
Chicago, IL
Columbiana, AL
Memphis, TN
Steubenville, OH
Fontana, CA
3-36
-------
123
124
125
126
127
128
129
130
131
132
133
134
135
136
_————————^^
American Steel Corp.
Greer Steel
Midway Wire, Inc.
Western Tube and Conduit Corp.
U S Steel - Irvin Works
U S Steel - Fairfield Works
U S Steel - Fairless Works
U S Steel - Gary Works
Magnetics International, Inc.
I/N Tek
Rouge Steel Co.
Riverdale Plating & Heat Treating Riverdale, IL
ATR Wire and Cable Co., Inc. Danville, KY
Detroit, MI
Dover, OH
Chicago, IL
Long Beach, CA
Dravosburg, PA
Fairfield, AL
Fairless Hills, PA
Gary, IN
Burns Harbor, IN
New Carlisle, IN
Dearborn, MI
Bailey Engineers, Inc.
Facility distribution;
Fairfield,' AL
Region 2:
Region 3:
Region 4:
Region 5:
Region 6:
Region 8:
Region 9:
1 state
4 states
6 states
4 states
3 states
1 state
1 state
TOTALS: 7 regions, 20 states
Facility identification numbers are not consecutive.
3-37
-------
TABLE 3-5. Employment Information
Number of
employees in
company
26
50
55
70
-100
-100
-100
101-250
251-500
Totals :
Facility ID
No.
51
134
125
136
11
34
60
7
21
24
33
42
50
100
110
116
126
1
2
3
14
23
80
85
108
112
1-100: 7
101-250:10
251-500: 9
Number of
employees Facility ID
in company No.
501-750 117
124
750-1000 4
28
122
1001-1500 9
26
54
102
114
>1500 5
6
7
8
12
16
17
18
20
22
27
29
30
35
36
37
501-750:2
750-1000:3
1001-1500:5
Number of
employees Facility ID
in company No.
> 1500 39
40
43
44
47
48
53
56
57
58
81
86
101
105
106
111
113
123
127
132
133
135
Not known 59
but >10Q 118
> 1500:37
Not Known :
but > 100:2
Notes:
Fourteen companies operate multiple facilities, 39 in all:
Allied Tube and Conduit (9, 103), American Spring Wire (14,
52), Armco (20, 31, 49), Bethlehem (27, 32, 45, 46, 109),
Carpenter Technology (37, 38), Heidtman (28, 107), Inland (40,
131), LTV (12, 15, 83), National Standard (26, 41, 119), Paulo
Products (108, 120), Sherman Wire (50, 55, 84), U. S. Steel
(127, 128, 129, 130), Wheeling Pittsburgh (5, 10, 82, 121) and
Worthington (101, 115).
Operations 19, 25, and 104 were discontinued after the survey
was made and are not included in the above table.
3-38
-------
TABLE 3-6. SUMMARY OF PROCESS CAPACITY
AND ANNUAL PRODUCTION
Type of process
Reported
processing
capacity, tons
per year
Reported
processing rate,
tons per year
Continuous strip
Push-pull strip
Continuous rod and
wire
Continuous tubing
Batch
50,453,000
8,280,000
889,000
669,000
1,251,000
33,320,000
4,471,000
596,000
596,000
850,000
TOTALS:
61,500,000
39,800,000
3-39
-------
TABLE 3-7. PROCESSING DATA FOR CONTINUOUS
STEEL STRIP PICKLING FACILITIES
Facility ID
No.
109
40
12
15
49
47
133
114
36
83
5
48
17
43
86
45
10
82
Number of
processes
2
2
2
3
2
2
3
1
1
1
1
2
2
1
3
1
1
3
Reported
processing
capac i ty , tons
per year
1,700,000
1,700,000
1,300,000
1,900,000
1,290,000
1,800,000
750,000
750,000
1,400,000
1,330,000
1,330,000
800,000
1,400,000
600,000
600,000
700,000
1,580,000
1,400,000
1,310,000
1,270,000
840,000
250,000
400,000
650,000
888,000
390,000
308,000
104,000
750,000
748,000
101,000
266,000
379,000
Reported
processing
rate, tons per
year
400,000
1,200,000
900,000
1,700,000
797,000
1,160,000
750,000
750,000
1,300,000
834,000
859,000
776,000
1,310,000
444,000
468,000
655,000
1,320,000
1,290,000
1,070,000
610,000
750,000
120,000
236,000
585,000
446,000
307,000
271,000
85,000
480,000
532,000
64,300
160,000
325,000
(continued)
3-40
-------
TABLE 3-7. (Continued)
—_•. ' ii _j-Beg-g— ^— ^s-^gi^asi^Bs^^sei^^a^^^a
Facility ID Number of
No . processes
111
31
122
44
20
46
24
121
57
116
29
100
Confidential
1
4
1
1
1
1
1
1
2
1
1
2
13
Totals:
Reported
processing
capacity, tons
per year
710,000
149,000
82,000
274,000
109,000
Not reported
Not reported
560,000
549,000
500,000
480,000
450,000
Not reported
Not reported
237,000
200,000
35,000
35,000
Confidential
50,453,000
Reported
processing
rate, tons per
year
707,000
123,000
38,100
230,000
63,930
363,000
206,000
410,000
489,000
425,000
350,000
337,000
160,000
107,000
200,000
150,000
30,000
30,000
Confidential
33,320,000
Notes: Facilities are listed in order of processing
capacity to the extent that this information is
known.
In calculating total capacity, actual processing
rate is used for operations in which capacity is
not reported.
Processing capacity reported for facilities
claiming confidentiality is 14,300,000 tons per
year.
Total processing rate for facilities claiming
confidentiality is 5,960,000 tons per year.
*These facilities are owned by companies that
employ 100 or fewer people.
3-41
-------
TABLE 3-8.
PROCESSING DATA FOR PUSH-PULL STEEL
STRIP PICKLING FACILITIES
Facility
ID No.
85
123
39
112
115
101
2
11*
6
60*
4
107
81
117
104*
28
51*
3
124
Number of
processes
1
3
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Totals:
Reported
processing
capacity, tons
per year
1,300,000
228,000
266,000
266,000
600,000
555,000
275,000
275,000
500,000
458,000
380,000
360,000
350,000
350,000
325,000
307,000
300,000
300,000
280,000
250,000
245,000
110,000
8,280,000
Reported
processing rate,
tons per year
876,000
48,000
115,000
116,000
125,000
257,000
202,000
202,000
200,000
219,000
236,000
202,000
290,000
300,000
300,000
213,000
103,000
16,000
207,000
125,000
83,000
36,800
4,471,000
3-42
-------
TABLE 3-9,
PROCESSING DATA FOR CONTINUOUS STEEL
ROD AND WIRE PICKLING FACILITIES
Facility Number of
ID No. processes
58 9
18 3
26 3
119 3
27a 3
8 4
135 4
32 1
113 4
23 1
Reported
processing Reported
capacity, processing rate,
tons per year tons per year
18,900
9,000
36,900
10,800
15,300
29,800
29,800
29,800
31,500
60,600
36,100
19,800
30,000
35,000
25,000
35,000
7,500
35,000
36,000
10,800
10,800
27,600
9,150
9,150
9,150
13,200
13,200
13,200
13,200
52,000
6,200
12,700
12,700
10,600
36,000
11,400
3,940
28,000
4,820
8,070
26,300
14 , 000
18,200
15,500
24,000
12,600
6,250
30,000
35,000
25,000
32,500
7,500
33,500
16,800
6,540
8,180
24,800
8,240
8,240
8,240
9,700
10,600
10,500
10,500
12,000
5,300
5,900
10,200
10,300
29,000
(continued)
3-43
-------
TABLE 3-9. (Continued)
Facility
ID No.
16
84
19*
33a
21
14a
50
55
118
41a
Number of
processes
3
1
1
2
1
1
1
1
7
2
Totals :
Reported
processing
capacity.
tons per year
10,000
10,000
4,300
12,500
12,000
Not reported
Not reported
10,000
9,000
7,500
6,300
673
673
673
673
673
673
673
120
260
889,000
Reported
processing rate,
tons per year
7,200
7,240
1,250
7,890
8,300
6,380
5,210
4,550
3,979
4,520
5,630
168
168
168
168
168
673
673
45
182
596,000
aFacility also conducts batch operations
3-44
-------
TABLE 3-10.
PROCESSING DATA FOR CONTINUOUS STEEL
TUBING PICKLING FACILITIES
Facility
ID No.
Number of
processes
Reported
processing
capacity, tons
per year
Reported
processing rate,
tons per year
103
126
7
2
2
1
43,000
52,000
35,000
83,000
53,000
156,000
55,800
80,700
35,000
35,000
40,000
33,000
40,000
27,000
64,000
40,000
120,000
42,600
59,300
35,000
35,000
28,000
TOTALS:
669,400
523,900
3-45
-------
TABLE 3-11.
PROCESSING DATA FOR BATCH STEEL
PICKLING FACILITIES
Facility
ID No.
27b
38
125*
1
22
54
52
80
56
25*
110
34*
59
14b
37
Number of
processes
4
3
2
1
1
1
1
1
2
3
6
2
1
1
1
Reported
processing Reported
capacity, tons processing rate,
per year tons per year
54,000
54,000
54,000
54,000
50,000
60,000
60,000
58,800
78,500
100,000
88,000
81,000
75,000
56,000
50,100
3,120
35,000
12,000
3,000
5,760
5,760
5,760
5,760
5,760
5,760
15,000
15,000
30,000
28,800
25,000
33,700
33,700
33,700
33,700
26,000
51,000
50,000
36,000
56,100
72,000
42,000
78,200
45,000
48,000
23,400
2,080
22,000
2,300
1,100
4,320
6,480
4,320
2,160
4,320
4,320
10,500
9,500
12,000
12,400
19,000
(continued)
3-46
-------
TABLE 3-11. (Continued)
Facility
ID No.
134*
42
30
108
53
41b
33b
120
106
102
35
Reported
processing Reported
Number of capacity, tons processing rate,
processes per year tons per year
4 8,300
3,200
2,100
4,500
4 Not reported
Not reported
Not reported
Not reported
5 4,400
7,500
3,500
880
800
4 4,000
Not reported
600
10,000
1 11,500
1 8,760
1 Not reported
3 2,000
1,500
1,500
1 1,700
1 70
4 7
7
0.12
36
TOTALS: 1,251,000
6,910
2,590
1,730
3,740
3,600
3,600
3,600
7,200
3,920
5,600
3,080
760
760
2,700
90
430
5,420
100
3,200
7,250
694
987
987
975
70
5
5
0.06
25
850,000
b Facility also conducts continuous rod or wire operations.
3-47
-------
TABLE 3-12.
PROCESSING DATA FOR ACID REGENERATION
FACILITIES
Facility
ID No.
131
47
114
17
20
136*
86
85
117
11*
Number of
processes
2
3
1
1
1
1
1
1
1
1
TOTALS :
Reported
processing
capacity,
gallons per year
19,900,000
19,900,000
10,250,000
10,250,000
10,250,000
20,000,000
18,000,000
13,500,000
13,000,000
9,400,000
4,500,000
3,500,000
3,150,000
155,600,000
Reported
processing rate,
gallons per year
11,000,000
11,000,000
4,900,000
4,900,000
4,900,000
12,000,000
12,000,000
7,290,000
13,000,000
7,300,000
3,400,000
3,500,000
2,800,000
98,000,000
3-48
-------
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3-49
-------
3.7 REFERENCES
1. Metals Handbook Ninth Edition, Volume 5, Surface Cleaning,
Finishing, and Coating, American Society for Metals, 1982.
p. 11.
2. The Making, Shaping, and Treating of Steel, 10th Edition,
Association of Iron and Steel Engineers, Pittsburgh, PA,
1985. p. 1085.
3. Hudson, R. M. Pickling of Hot Rolled Strip: An Overview.
Iron and Steelmaker, 18(9), September 1991. p. 31.
4. Reference 2, p. 1084.
5. Encyclopedia of Occupational Health and Safety, vol. I,
McGraw-Hill Book Company, 1974, pp. 693-694.
6. Hydrochloric Acid. Hazardous Substance Data Bank. National
Library of Medicine. National Institute of Health.
Printouts dated August 31, 1992 and November 12, 1993. See
also: Hydrogen chloride. Integrated Risk Information
System. U.S. Environmental Protection Agency. Printout
dated July 10, 1995.
7. Chlorine. Hazardous Substance Data Bank. National Library
of Medicine. National Institute of Health. Printout dated
August 18, 1993. See also: Chlorine. Integrated Risk
Information System. U.S. Environmental Protection Agency.
Printout dated September 1, 1995.
8. Ref. 7.
9. Keystone Environmental Resources, Inc. Weirton Steel
Corporation, Weirton, West Virginia, Compliance
Demonstration Results, Hydrochloric Acid Regeneration Unit
#3. Monroeville, PA, January 1992.
10. Dempster, J. H. And H. M. Gomaa. Recovery and Recycling of
Waste Acid From Steel Pickling Operations, Wire Journal, 6.,
April, 1973. p. 63-66.
11. Stanier, R. J., and D. R. Poulson. Recycling's Revenue
Path: Acid Waste Streams Become Profits. Haztech
International, Houston TX, May 8-10, 1990.
12. Eco-Tec, Inc. Acid Purification Unit. Bulletin No. ET-4-
84-5M. Pickering, Ontario.
13. Acid Recovery Systems, Inc. Crown Recovery Systems.
Product bulletin. Lenexa, KS, 1987.
3-50
-------
14. World-wide Limits for Toxic and Hazardous Chemicals in Air,
Water, and Soil. M. Sittig. Noyes Publications. Park
Ridge, NJ 1994. pp. 425-426.
15. Ref. 14, pp. 178-179.
3-51
-------
-------
4.0 CONTROL TECHNOLOGY AND PERFORMANCE OF CONTROLS
This chapter presents an overview of the techniques
typically used to capture and control hydrochloric acid
(HC1) emissions from steel pickling operations and HC1 and
chlorine (C12) emissions from acid regeneration processes.
The sources of emissions from pickling operations include
pickling tanks and acid storage tanks. The sources of
emissions from acid regeneration processes include
regeneration units and acid storage tanks. This overview
describes equipment design parameters, operating conditions,
application of these control techniques in the industry, and
factors that determine the effectiveness of these techniques
in reducing emissions. Section 4.1 focuses on capture
systems and Section 4.2 focuses on control techniques. The
performance of controls for the steel pickling source
category is presented in Section 4.3. The presentation is
based on emission source tests that were conducted by the
EPA and on information reported by pickling facilities.
Section 4.4 discusses pollution prevention opportunities in
the steel pickling operations and in related activities. A
list of references that provide detailed descriptions of
control technology also is included.
4.1 EMISSION CAPTURE EQUIPMENT
The emission capture equipment refers to the local
exhaust ventilation system that is typically used to capture
4-1
-------
and remove acid emissions from steel pickling operations.
The capture equipment includes exhaust hoods for open-tank
batch pickling operations and tank enclosures for other
types of pickling operations. The major differences between
these two types of capture systems are that (1) exhaust
hoods usually provide an open space above or around the
pickling tanks for the movement of equipment and transfer of
steel material and (2) tank enclosures usually cover entire
pickling tanks and provide only small openings at each end
for steel to enter and exit. Acid storage tanks usually are
completely enclosed and do not require a capture system, but
they have vents to equalize pressure during transfer
operations.
4.1.1 Fume Exhaust Hoods
Fume exhaust hoods are used to capture and remove acid
fumes from open tanks in order to prevent damage to
buildings and equipment, to protect the health of the
employees, and to control air pollution.
Acid fumes from open tanks may be controlled in two
ways:
1. By blanketing the surface of the solution in the
tanks, and
2. By creating an air flow above the tanks to direct
the fumes to a collecting system.
Blanketing by foam is not completely effective as foam
may be pushed aside by agitation and leave exposed surface.
In some instances, the foam picked up by the steel leaving
the tank causes quality problems in subsequent processing.
Sometimes a layer of floating plastic balls is used for
blanketing the tank surface. However, plastic balls may be
crushed by or entrapped in the steel stock.
Most open-tank batch pickling operations use fume
extraction to capture and remove acid fumes. Some of the
common ways of fume extraction are (1) roof mounted fans
4-2
-------
above the tanks/ (2) wall mounted fans on one side of the
tanks, (3) slot hood extraction from one or more sides of
tanks, and (4) lateral exhaust hoods on one side of the
tanks. Figures 4-1 through 4-4 show these common fume
TABLE 4-1. AIR EXTRACTION RATES REQUIRED FOR DIFFERENT
VENTILATION SYSTEMS FOR A 3 m X 3 m (10 ft X 10 ft)
OPEN TANK1 (essentially complete control)
=====
Extraction Rate
Roof fans
Wall fans
Slot hoods
Lateral hood (push/pull system)
cfma
90,000
90,000
30,000
15,000
===^==
m3/minb
2,500
2,500
850.
425
acfm = cubic feet per minute
bm3/min = cubic meters per minute
extraction methods. Table 4-1 shows the extraction rates of
various types of fume exhaust systems for essentially
complete control on a 3 meter (m) (10 foot [ft]) square open
tank.
Roof- or wall-mounted fans are simple and inexpensive
to install. However, they extract air from the whole
building and not specifically from the pickling tanks.
Extracting large quantities of air is disadvantageous in the
winter months because warming the make-up air is expensive.
General building ventilation has other disadvantages: the
building walls and roof act as a collection hood for acid
fumes with consequent deterioration; workers are subject to
the hazardous effects of acid fumes; equipment located above
or near the tanks is corroded by fumes; and emission control
devices, if installed, are very large and need special fans.
4-3
-------
Exhaust
Air Flow
i
wv\/v/\/\/>^x/^/"\/\/>'^"
Tanks
Crane
Air Flow
Figure 4-1. Roof-Mounted Exhaust System
Crane
-Exhaust
Air Flow
Figure 4-2. Wall-Mounted Exhaust System
4-4
-------
Air Flow
Flange
Figure 4-3. Slot-Hood Exhaust System
Air Flov
Push Air
Supply
Tank
Slots Each
Side
Exhaust
Suction Ducts
Any Two
Opposite Sides
ood
To Exhaust
System
Figure 4-4. Lateral Hood Exhaust System
4-5
-------
Slot extraction and lateral hood extraction use
horizontal air flow to capture emissions. These systems
exhaust only the air from the area of the pickling tanks;
therefore, they are preferable to general ventilation
methods for open-tank batch pickling operations. Slot
extraction is attractive to picklers because of the low
profile of the slot hoods and the location of the suction
duct below the tank level. These arrangements keep the
extraction openings and duct out of .the way of moving loads.
However, the slots must be either of heavy construction or
well protected to prevent damage if loads are dropped on
them.
Lateral hood extraction with push air on the opposite
side of the tank (a push/pull system) creates an air curtain
across the surface of the tank and directs the acid fumes
toward the exhaust hood. The major advantage of push/pull
systems over slot exhaust systems is that they provide equal
ventilation efficiency while using only about one-half the
volume of air (see Table 4-1). This efficiency results in
smaller air handling equipment (ductwork and fans), lower
utility and makeup air requirements, and a smaller scrubber
system. Furthermore, the high hoods beside the tank help to
capture some of the fumes generated from lifting the steel
out of the tank. The major problem with lateral hood
extraction is damage from the steel loads or cranes. The
lateral hood is usually placed on the side of the tank
opposite the crane cab or hoist pendant operating area.
4.1.1.1 Design Parameters for Hood Extraction Systems.
The general design of a hood extraction system can be found
in Industrial Ventilation.2 The design and costing of a
fume extraction system relevant to pickling is presented by
Stone.1 Push/pull systems are based on the required capture
or control velocity, the exhaust rate, push-air volume, the
width-to-length ratio of the tank, the surroundings of the
4-6
-------
tank, and the subsequent emission control device. To
maintain control of acid fumes by a cross-air flow, a
minimum air velocity of 46 m/min (150 fpm) across the HCl
pickling tank is recommended.1 Table 4-2 shows the minimum
exhaust rates for lateral hood exhaust at various width-to-
length ratios and the required minimum air velocity.
4.1.1.2 operating Conditions and Factors That
Determine the Effectiveness of Exhaust Hoods. Exhaust hoods
for batch processes are arranged so that cranes hoisting
material to be pickled have access to the pickling tank.
Because the hood is not close fitting, air flow patterns
within the building, drafts from open doors or windows, and
convective patterns surrounding heat sources (the pickling
tanks) may all affect flow into the hood.3 Stone1
recommends keeping the pickling plant closed, fitting
personnel doors with automatic closers, hanging flexible
curtains or swinging doors at lift-truck doors, and
installing elevated make-up air supply openings opposite the
hood.
Conditions described by Stone1 that can substantially
reduce exhaust system performance include the use of
improper materials that corrode quickly, leak, and reduce
air flow above the tank; absence of push air, which prevents
proper air flow across the tank and into the exhaust system;
improper layout of the hood system, which promotes
inefficient operation; attempts to recycle air exhausted
from the scrubber back into the plant, which leads to
damaging condensation on building and equipment surfaces;
and improper maintenance that allows equipment degradation
to the point of failure. The solutions to these problems
include using appropriate materials of construction
(polypropylene, fiberglass reinforced plastic [FRP], or
polyvinyl chloride plastic); ensuring that push-air fans are
4-7
-------
Table 4-2. Minimum Exhaust Rates* for Ventilation Hoods
Used to Capture HC1 Emissions from Open Batch Pickling
Tanks4
Hood along one side or two parallel sides'1
of a tank when the tank is against a wall
Tank width-to- or baffled. Also for a manifold along tank
length ratio centerlineb.
Hood along one side or two parallel sides'* of a free-
standing tank not against a wall or baffled
Lateral hoods with
push/pull system. Lateral hoods with
Slot hoods, m3/min-m2 m3/min-m2 (tV/min- Slot hoods, m3/min-m2 push/pull system, m3/min-
(fV/min-ft2) ft2) {frVmin-ft2) m2 (ftVmin-ft2)
O.O-O.09
O.I -0.24
0.25-0.49
0.5-0.99
1 .0-2.0
46(150)
58 (190)
69 (225)
76 (250)
76 (250)
23 (75)
26 (95)
35 (115)
38 (125)
38 (125)
69 (225)
76 (250)
76 (250)
76 (250)
76 (250)
35 (1 1 5)
38(125)
38(125)
38 (1 25)
38 (125)
* Exhaust rates are based on the minimum air velocity of 46 m/min (150 fpm) recommended for HCI fumes emitted
from open tanks.
b Use width/2 as tank width in computing W/L ratio when manifold is along centerline or two parallel sides of tank.
included in the system design; positioning the hood as close as possible to the tank; not recycling air from the
scrubber outlet; and providing proper maintenance.
4.1.1.3 Application of Emission Capture Systems in the
Pickling Industry. Batch pickling systems in the U.S. that
are equipped with hood capture systems are limited to about
60 percent of the known population. Categorizing the
systems into small (less than 25,000 tons per year), medium
(25,000 to 75,000 tons per year), and large (greater than
75,000 tons per year) sizes, the fractions of facilities
that employ capture systems are about 50 percent for the
small facilities, 85 percent for the medium, and 60 percent
for the large.
4.1.2 Tank Enclosures
Tank enclosures or covers used on continuous and push-
pull pickling systems differ from the hoods used on batch
pickling systems by providing a relatively tight closure
over all the tanks. The enclosure edges are sealed against
4-8
-------
the tank sides, and openings are required only for entry and
exit of the steel strip and for piping that pierces the
enclosure. The volume of air entering the exhaust system
can be relatively small when compared to batch systems of
the same size.
4.1.2.1 resign Pg-rameters for- Tank Enclosures.
information for designing tank enclosures for continuous
lines can be found in Industrial Ventilation' and is simzlar
to the information needed to design hoods. The tank
enclosures are normally placed over the pickling and rinse
tanks and are sectioned to allow separate access into each
tank as needed. Ductwork is designed to extract acid fumes
from the sides or top of the enclosure, then convey it to a
scrubber, which is normally used as a control device.
4.1.2.2 np^T-atinq renditions and Factors That
l the T^^tivene^ of Tank Enclosures. As with
hoods, ventilation velocity must be sufficient to overcome
any tendency for fumes to escape the system at the openings.
For large tank enclosures on continuous or push-pull coil
pickling lines, one or more exhaust intakes evacuate acid
fumes from each sectional cover and vent to ductwork along
the tanks. These exhaust intakes are equipped with dampers
so that the evacuation rate from each intake can be adjusted
to balance the overall emission capture system. The exhaust
rate is balanced to capture all acid fumes while not venting
too much heat from the pickling tanks. Most tank enclosures
and exhaust intakes are designed to allow air flow to sweep
over all the liquid surface, thus creating excess
evaporation and resulting in high emissions. A more
effective design is to evacuate more air near the major
openings so that air curtains are created to keep the add
fumes stagnant in the center of the tank enclosures. A
tight enclosure system is required for the latter approach.
Construction materials commonly used are FRP, PVC, granite.
4-9
-------
and plastic-coated sheet metal. Water seals along the edges
of the covers ensure a tight enclosure. Rubber strips are
used to cover the gaps and prevent leaks between section
covers.
4.1.2.3 Application of Tank Enclosures in the Pickling
Industry. Tank enclosures are usually used for pickling
tanks where steel stock is transferred continuously. Almost
all of the continuous coil, push-pull coil, continuous
rod/wire, and continuous tube pickling operations use tank
enclosures on their pickling tanks to confine and capture
acid emissions. Without tank enclosures, acid emissions
would damage building structures and equipment, and cause
health hazards to operators.
4.2 CONTROL TECHNIQUES FOR HC1
Scrubbers (gas absorbers) are the only control devices
used for HC1 emissions from pickling lines and acid
regeneration plants. A general description of absorbers,
including design, operation, and maintenance, can be found
in Buonicore and Davis.5 Information on tray scrubbers
specific to pickling can be found in publications by
Stone.6-7
Scrubbers operate by contacting the gas to be absorbed
with liquid in which the gas is soluble. Because HC1 is
highly soluble in water, scrubbers can be an effective means
of control. The effectiveness of a scrubber also depends on
maintaining good contact between the gas and liquid. The
method of contact separates scrubbers into two maj or types
used in the pickling industry: packed bed and sieve tray.
The purpose of packing or trays is to provide intimate
mixing of gas and liquid so that gas molecules have the
opportunity to come within capture distance of the liquid
surface. Without such mixing, bubbles of gas can traverse
4-10
_
-------
the entire scrubber without capture of HC1 molecules near
the bubble center.
Scrubber size depends on gas characteristics and flow.
The more soluble the gas is at the temperature of
absorption, the shorter the contacting length that is
required. For a given type of scrubber (in normal operation
and with consistent internal design), its diameter depends
on the gas volumetric flow rate. Materials of construction
are normally FRP or corrosion resistant steel.
One characteristic of scrubbers is a tendency to form
mists, either from physical agitation of the liquid or from
temperature and moisture conditions that promote
condensation. Mists can be troublesome because of small
particle size (2 to 5 Aim)8 and thus require installation of
a mist eliminator downstream of the scrubber. The mist
eliminator is often part of the scrubber design and is built
into the scrubber body. However, especially where
conditions lead to mist formation downstream of the
scrubber, a mist eliminator may be installed at some
distance from the scrubber. In some cases, the mist
eliminator may be placed in the stack.
4.2.1 Types of Scrubbers
The following sections briefly describe the specific
types of scrubbers and demisters used for pickling and acid
regeneration. The use of caustic solution as a scrubbing
medium is also described. Characteristics particular to HC1
pickling are discussed.
4.2.1.1 Packed Bed Scrubbers. Packed bed scrubbers
can be vertical or horizontal in configuration. Vertical
scrubbers are usually tubular in shape and have a bed of
packing whose purpose is to provide good contact between gas
and liquid. Figure 4-5 illustrates a vertical packed bed
scrubber. Gas flows up the tower while water flows down and
is distributed over the surface of the packing. Packing has
evolved in form from rocks or shards of broken glass to
4-11
-------
Liquid In
Mist Eliminator
Liquid Distributor
Spray Nozzle
Packing Restrainer
Shell
Packing
Liquid Re-Distributor
Packing
^Packing Support
Gas In
Liquid
Out
Figure 4-5. Vertical Packed Bed Scrubber
4-12
-------
intricate forms (often molded plastic) that provide a
maximum of surface area without overly impeding gas flow.
During operation of a scrubber, the liquid flow rate must be
sufficiently high to wet the packing surface thoroughly,
while the gas flow fate must be sufficiently low to prevent
flooding, i.e., preventing the liquid from flowing down the
tower. The packing is irrigated by spray nozzles near the
top of the tower that are designed to distribute the water
evenly. Typical bed heights are 4 to 6 ft; typical
diameters are up to several ft.
Because HC1 is so soluble, the scrubbing water that
leaves the bottom of the tower is usually not saturated and
can be partially recycled to the top of the tower. Eighty
percent or more of the water may be recycled. As a
pollution prevention measure, water pumped from the sump
below the tower (blowdown) may be used as rinse water or
make-up water for fresh acid in the pickling line. Scrubber
effluent not used elsewhere must normally be treated at a
wastewater treatment plant before disposal. The major
advantage of packed scrubbers over tray scrubbers is lower
capital cost. The major disadvantage is that much higher
volumes of wastewater must be treated before disposal.
In the horizontal packed bed design, gas traverses the
scrubber horizontally, while water is sprayed on the packing
from the top and, for some designs, from the inlet side of
the packing. This design is useful where overhead height is
limited, a significant volume of air is to be scrubbed (more
than 35,000 acfm), and a large horizontal area is available.
4.2.1.2 Sieve Tray Scrubbers. Rather than packing,
sieve tray scrubbers have an internal arrangement of trays
spaced along the tower. Water flows down to a tray (or
plate) pierced by holes through which gas passes upward.
Intimate contact is obtained as the gas moves through the
holes and bubbles through a layer of water above the tray.
Efficiency is increased as the number of trays increases.
4-13
-------
Figure 4-6 illustrates a sieve tray scrubber. Scrubbers
used for pickling lines typically have three to six trays.
Sieve tray scrubbers use significantly less water than
packed bed scrubbers (1 gpm/10,000 cfm vs 100 gpm/10,000
cfm)1 and produce less effluent that must be treated. This
fact prompts some pickle line operators to use sieve tray
rather than packed tower scrubbers. Some scrubbers are
equipped with a spray system underneath the bottom tray (or
packing in packed bed scrubbers). This lower spray uses a
small amount of water, either continuously or
intermittently, to prevent scale from forming on the tray or
packing.
4.2.1.3 Venturi Scrubbers. The venturi design is used
primarily for particulate matter collection rather than gas
absorption. Only one venturi scrubber, used at an acid
regeneration plant, is known to be employed in the industry.
The scrubber is used to control iron oxide particles as well
as HC1 emissions. The design makes use of violent mixing at
a constriction where water is introduced into the gas
stream. Shearing forces in the water break it into tiny
droplets that are effective in collecting particles. The
mixing also provides good, but of limited duration, contact
for gas absorption.
4.2.1.4 Demisters. The two common types of demisters
are chevrons and mesh pads. Chevron demisters, so named
because of their shape (which is like the military insignia)
collect mist droplets on their surface. The droplets then
coalesce, run down the chevrons, and drain back into the
scrubber or into a sump underneath the demister. The
thickness of a chevron demister is determined by the number
of bends in the chevron blades. Three or four bends are
common in this application.
Mesh pad demisters consist of plastic fibers arranged
either as an irregular mass or as a graded assembly.
4-14
-------
Gas Out
Liquid Inlet
Underside Water
Sprays
-.!-. Gas In
Liquid Out
Figure 4-6. Sieve Tray Scrubber.
4-15
-------
Typical thickness for a mesh pad eliminator is 6 in., with
some thicknesses as high as 18 in. In some applications,
such as removing the liquid droplets generated in chrome
plating, demisters are used as the sole element for
pollution control. In these applications the demisters are
irrigated to prevent accumulation of solids during
evaporation of the liquid. These installations are larger
and more complex than the simpler demisters found in HC1
pickling.
4.2.1.5 Caustic Scrubbing Solution. Scrubbing with
water depends solely on absorption, which is limited by the
equilibrium vapor pressure of the HC1 absorbed in the water.
One method of increasing efficiency is by reacting the HC1
in the liquid with caustic so that less HC1 is available to
vaporize. A few facilities use caustic scrubbing media in
an attempt to meet requirements for outlet concentrations of
5 ppm or lower. Disadvantages of using caust ic are greater
cost for the scrubbing medium and inability to reuse it as
rinse water.
4.2.2 Use of Scrubbers in the U.S. Pickling Industry
Table 4-3. summarizes the total number of scrubbers in
different types of pickling operations and acid regeneration
processes in the U.S. Figures 4-7 through 4-10 present the
distribution and sizes of scrubbers by scrubber types.
Figures 4-11 through 4-14 show the distribution and sizes of
different scrubbers by process types. This information was
obtained from a 1992 survey that sent questionnaires to all
known pickling operations in the U.S. Adjustment of the
flow rates that were reported in terms of standard cubic
feet per minute (scfm) rather than actual cubic feet per
minute (acfm) was required.
The bar charts show the number of scrubber systems in
2,500 acfm or 5,000 acfm increments. A bar at a specific
flow rate on the x-axis shows the number of scrubbers whose
size is between the specific flow rate and the smaller flow
4-16
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4-25
-------
TABLE 4-3.
SUMMARY OF SCRUBBER SYSTEM TYPES IN PICKLING
OPERATIONS*
Others (fume
washer,
• Horizontal venturi.
Packed Sieve packed demister,
tower tray bed etc.)
Total no.
of process
Total no. of Total no. units Percent of
control of process without process units
systems
units
control
controlled
Continuous
coil pickling
Push-pull coil
pickling
Batch pickling
Continuous
wire, rod, end
pipe pickling
Acid
regeneration
Total
37
12
7
12
11
79
12
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64
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1
93
94
100
22
40
92
59
'Nine process units are serviced by two scrubbers in series. Only the last scrubber in the series is identified in this
table.
bSome control systems are devoted to one or more process units. Also, some process units are serviced by more
than one control system.
rate to the left. For example, in Figure 4-7 there are
2 scrubber systems between the sizes of 5,000 acfm and 7,500
acfm and 6 scrubber systems in the size range between 10,000
and 12,500 acfm. Table 4-3 shows 23 sieve tray scrubber
systems in operation for all processes. As shown in
Figure 4-7, most of the scrubber systems are 25,000 acfm or
smaller in size. Most of the sieve tray scrubber systems
are fabricated by two vendors: ESCO Engineering and Heil.
Table 4-3 shows 68 packed tower scrubber systems in
operation for pickling processes. Figure 4-8 shows that
most of the packed tower scrubber systems are smaller than
40,000 acfm in size; only 3 scrubbers are larger than 50,000
acfm. Packed tower scrubber systems are fabricated by many
equipment vendors. Figure 4-9 shows a discontinuous
distribution of 13 horizontal packed bed scrubber systems.
Ten of the 13 scrubbers are smaller than 20,000 acfm, and 3
4-26
-------
of the 13 scrubber systems are larger than 45,000 acfm.
Larger horizontal packed bed scrubber systems are used by
older large continuous coil pickling operations and were
installed by the architect and engineering (A&E) firms who
fabricated the pickling lines. Most of the smaller
horizontal packed bed scrubber systems are used by batch
pickling and continuous wire/rod/tube pickling operations.
Figures 4-10A through 4-10D show the distribution and
sizes of different types of scrubber systems for continuous
coil pickling operations. As shown in Table 4-3 and
Figure 4-10A, there are 12 sieve tray scrubber systems for
continuous coil pickling. They range in size from 20,000
acfm to 100,000 acfm. Most of the sieve tray scrubbers for
continuous coil pickling are replacements for old scrubbers.
Probably replacement was done to reduce the amount of
blowdown for wastewater treatment or for reuse as makeup
water in the pickling lines. Figure 4-10B shows 37 packed
tower scrubber systems of various sizes for continuous coil
pickling. As shown in Figures 4-9 and 4-10C, all 3 of the
horizontal packed bed scrubber systems that are larger than
20,000 acfm are located in continuous coil pickling
facilities. Most of the 13 horizontal packed bed scrubber
systems appear to be comprised of old scrubbers that were
fabricated by the A&E firms when the pickle lines were
built. Figure 4-10D shows 3 other types of control devices,
such as fume washers or demisters, used by the continuous
coil pickling facilities.
Table 4-3 and Figure 4-11 show 12 packed tower scrubber
systems, and 10 sieve tray scrubber systems used in push-
pull coil pickling operations. Because the physical
dimensions of the pickling tanks in push-pull lines are
generally smaller than those of continuous coil lines, the
scrubbers used by push-pull operations also generally are
smaller.
4-27
-------
Table 4-3 and Figure 4-12 show seven packed tower
scrubber systems, one sieve tray scrubber system, one
horizontal packed bed scrubber system, and four other types
of control systems used in batch pickling operations. The
four largest packed tower scrubbers systems shown in
Figure 4-12 are associated with four batch pickling
operations with fairly large annual processing rates. The
percentage of sources with emission control in batch
pickling is relatively small compared to continuous coil
pickling operations (22 percent vs 94 percent), probably
because the physical dimensions of the batch pickling units
and the associated acid emissions are smaller than those in
coil pickling operations.
Figure 4-13 shows that most scrubber systems used by
continuous wire/rod/pipe pickling operations are smaller
than 22,500 acfm in size. Smaller control devices are used
in this type of operation because the physicc1 dimensions of
the pickling tanks are relatively small compared to those in
coil pickling and the emission capture systems are enclosed.
The packed tower scrubber, with a total number of 12, is the
most common control used in this type of pickling operation.
There are also eight horizontal packed bed scrubber systems
used in this type of pickling operation. Of the 21
continuous wire/rod/pipe pickling facilities (or 63 process
units) reported in the questionnaires, only 12 facilities
(or 25 process units) are controlled.
Figure 4-14 shows that acid regeneration processes use
10 packed tower scrubber systems and 1 venturi scrubber
system (with caustic for pH adjustment) for emission
controls. There are three typical capacities for the acid
regeneration process units: 7 gpm (3 units), 26 gpm
(2 units), and 38 gpm (6 units). The sizes of the scrubbers
are closely related to the capacities of the process units.
Acid regeneration processes built before the early 1980s are
equipped with a single stage water scrubber.
4-28
-------
4.3 SCRUBBER PERFORMANCE
Two sources of information are available that describe
scrubber performance: the 1992 survey previously mentioned
and source tests performed to the specifications of EPA Test
Method 26A. The two sources of information are described
below.
4.3.1 Survey Information
Scrubber efficiencies reported by facilities in the
1992 survey are categorized by efficiency ranges and process
types in Table 4-4. There are 123 primary scrubber systems
in service in the industry, but some facilities are without
controls. Most of the uncontrolled facilities are batch and
continuous rod/wire pickling operations.
Figure 4-15 shows the efficiency distribution of all
scrubbers used in pickling operations. The x-axis shows the
control efficiency of individual scrubbers and the y-axis
shows the cumulative number of scrubbers. Figures 4-16 and
4-17 present similar distributions for coil pickling
operations and non-coil pickling operations, respectively..
Coil pickling operations include continuous and push-pull
coil pickling. Non-coil pickling operations include
continuous rod/wire, continuous pipe, and batch pickling.
The distribution of control efficiencies for 12 scrubber
systems used in HCl spray roasting processes are shown in
Figure 4-18.
These reported scrubber efficiencies are based either
on test results or on design values. A test can be either a
complete source test by an EPA test method or a simple
Drager tube test. A design value is provided or guaranteed
by the equipment vendor, and may be higher or lower than the
actual efficiency. Unknown scrubber efficiencies are
reported as zeros.
4-29
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4-33
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The results in Table 4-4 show that 63 percent of the
scrubbers used by the industry are either designed or tested
to achieve at least 95 percent efficiency. The number of
scrubbers that need to be upgraded to meet future MACT
standards can be determined from the distribution curves.
Comparing Figures 4-16 and 4-17 shows that the distributions
are similar for coil and non-coil pickling operations; few
differences are found in control efficiency distribution for
scrubbers used in the two operations.
As shown in Figure 4-18, reported efficiencies of
scrubbers used in HC1 spray roasting processes are, with one
exception at 83 percent, all 95 percent or higher. The
control efficiency for C12 in spray roasting processes is
unknown.
4.3.2 Source Test Analysis
The scrubber performance analysis for coil pickling
operations is based on 10 tests at 9 continue as and push-
pull facilities. 9>10'u'12 The analysis for spray roasting
processes incorporates one EPA source test13 and three
compliance tests acquired from three facilities.14'15-16
The EPA Method 26A is used in all EPA-conducted source
tests because it provides a measurement of hydrogen halide
and halogens from a stationary source. The isokinetic
measurement required by the method ensures that particulate
matter (including droplets) in the gas stream are sampled
properly. A facility-conducted test is considered valid
when it uses EPA Method 26A or when (1) sampling is
conducted from traverse points in the ductwork or stack,
(2) sampling rate at the probe is isokinetic with respect
to the gas flow velocity, (3) sampling time is long enough
to collect an adequate amount of gas volume, (4) volume and
type of impinger solution is adequate to readily dissolve
and completely capture the incoming HC1, and (5) the
4-34
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4-35
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analytical method is sensitive and accurate for analyzing
chloride in the impinger solution.
Using the above validation criteria, 10 tests from 9 coil
pickling facilities and 4 tests from 4 acid spray roasting
facilities were considered valid and are included in this
analysis.
The U.S. EPA conducted 5 of the 14 source tests in 4
facilities. Two of the facilities are continuous coil
pickling operations, another is a push-pull coil pickling
operation, and the other is a continuous coil pickling
operation with a spray roasting acid regeneration plant.
These four facilities were selected based on their being
representative of the U.S. coil pickling industry.17 The
test plans for the facilities were formulated to evaluate
the differences between: continuous vs. push-pull coil
pickling operations, steam sparging vs. heat exchangers,
packed tower vs. sieve tray scrubbers, and caustic scrubbing
vs. water scrubbing. Besides the EPA tests, an additional
six tests acquired from five pickling facilities and three
tests from three HC1 spray roasting facilities were
determined to be valid.
4.3.3 Source Tests at Continuous and Push-pull Coil
Pickling Facilities
The process information, scrubber specifications, and
test results are shown in Table 4-5 for 10 tests from 9 coil
pickling facilities. The data are arranged by decreasing
order of scrubber efficiencies for HC1. The EPA-conducted
tests are noted in the facility names. The acid consumption
rate in Table 4-5 is calculated from the annual acid
consumption rate and steel production rate reported by each
facility for 1991. The virgin acid (32 wt. percent HC1 vs
18 to 20 wt. percent for regenerated acid) consumption rates
are between 30 and 34 Ib HCl/ton of steel for 2 push-pull
coil facilities, between 37 and 65 Ib/ton for 6 continuous
4-36
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coil facilities, and 11 lb/ton for a vertical pickling tower
facility. The theoretical amount of acid required to remove
the scale from 1 ton of steel is estimated to be 28.7 Ibs of
31.45 wt. percent HC1.18 It appears that the immersed
pickling in horizontal continuous pickling operations uses
up to twice the theoretical value, while the spray pickling
in a vertical tower uses less than half of the theoretical
value. The uncontrolled and controlled emission rates based
on quantity of steel pickled (process weight rates) rather
than on concentration or mass per unit time are shown in
Table 4-5 for non-EPA tests. The process weight rates are
estimated from the production rates of the process lines
reported in the EPA survey and the uncontrolled and
controlled HC1 emission rate respectively. These production
rates are used in the place of steel processing rates
because these rates are not recorded in the non-EPA tests.
Emissions based on process weight rates appear not to be a
useful measure because of variability in processing
conditions that do not correlate well with generation of HC1
vapor and mist, i.e., a process weight rate regulation would
be difficult to support. Reasons for the poor correlation
between process emissions and steel processing rate are
based on at least two factors not obvious from source
testing. The rate of emissions from the pickling tanks,
which may vary over time depending on degree of agitation,
is continuous, but the steel processing rate is intermittent
(even for continuous lines). Also, the quantity of acid
used depends on the surface area of the steel being pickled,
not on its weight. Different quantities of acid are
required for a ton of steel depending on the thickness of
the strip being pickled. A line pickling heavy gauge strip
will process higher tonnages with a lower amount of scale
than a line pickling the same tonnage of light gauge strip.
Table 4-5 gives acid consumption rate and process weight
rates on a tonnage basis for comparison.
4-41
-------
The majority of the older process lines have new
scrubbers that were installed in the past several years.
These new scrubbers usually are of packed tower or sieve
tray design. Two of the packed tower scrubbers tested use
neutralized scrubbing water to scrub HC1. Sodium hydroxide
is added to the recirculating water as the neutralizing
agent to maintain the pH at 7 or 8. All scrubbers are
equipped with a demister to remove droplets formed in the
scrubber. The demisters are located either at the tops of
the scrubbers or downstream from them in the ventilation
system.
4.3.4 Variables Affecting Emissions and Controls
Acid emission rates are a compound effect of tank sizes
(i.e., surface area), acid concentration and temperature,
iron concentration, ventilation system, gas flow rate,
tightness of enclosure cover, heating method, and degree of
agitation (e.g., as caused by line speed or steam sparging)
in the acid tanks. Ii6'7>19 The performance of an emission
control may be affected by the inlet loading to the
scrubber, number of trays for sieve tray scrubbers, depth
and type of packing material for packed tower scrubbers,
depth and type of demister, and type of scrubbing medium and
its flow rate.1>2-5'8'19 A discussion follows of the effects of
these process variables and equipment specifications with
respect to emission quantities or control efficiencies. A
qualitative interpretation of available data is also given.
4.3.4.1 Types of Pickling Operations. Figures 4-19,
4-20, and 4-21 show the ranges of scrubber effectiveness (in
terms of efficiency, outlet mass emission rate, and outlet
concentration) for each of the tests. Figure 4-19 is
ordered by decreasing efficiency among facility numbers. To
maintain consistent comparison, the facility numbers in
Figures 4-20 and 4-21 follow the same order used in
Figure 4-19. As shown in Figures 4-19 and 4-20, the
4-42
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scrubber efficiency and controlled HC1 emission rate for the
two push-pull coil pickling operations (Facilities 115 and
101) are within the range of continuous coil pickling
operations. The only test result for a vertical, spray
pickling tower (Facility 44) is also within the range of
continuous coil pickling operations. As shown in Figure 4-
21, the only significant variation is the wide range of
outlet concentrations from the vertical pickling tower,
which may be due to the nature of spray pickling. When the
line stops for more than several seconds, the acid spray
automatically stops. Based on the results shown in Figures
4-19, 4-20, and 4-21, it appears that scrubber effectiveness
for push-pull and vertical spray tower pickling units is in
the same range found for continuous pickling units.
4.3.4.2 Heating Methods. The effect of heating method
is shown from the uncontrolled emission rate and process
weight rate in Table 4-5. It is apparent that steam
sparging causes more acid emissions from the picking tanks
than is caused by other heating methods. There is no
apparent difference between internal and external heat
exchange regarding acid emissions.
4.3.4.3 Types of Scrubbers. in most cases, a scrubber
is designed for a certain degree of collection efficiency or
a specified outlet concentration. In either case, the
outlet concentration is tied to the inlet concentration.
Table 4-5 shows that all but two scrubbers are able to
achieve greater than 95 percent collection efficiency for
HC1. Both packed tower scrubbers and sieve tray scrubbers
are able to achieve a similar degree of HC1 collection. For
sieve tray scrubbers, the collection efficiency clearly
increases as the number of trays increases. For packed
tower scrubbers, the dependence of collection efficiency on
packing type and depth, scrubbing medium and its flow rate,
and demister effectiveness is not apparent.
4-46
-------
4.3.4.4 Types of Scrubbing Media. City water, process
water, river water, and neutralized solution are used in
these scrubbers. As shown in Table 4-5, the scrubbing water
for sieve tray scrubbers usually flows once-through at a
relatively small rate, ranging from 5 to 17 gpm. The
scrubbing water flow rate for packed tower scrubbers usually
is recirculated from 25 gpm for small scrubbers up to 220
gpm for large scrubbers. Make-up water for packed tower
scrubbers is roughly 10 to 15 percent of the recirculation
flow rate.
One of the packed tower scrubbers uses neutralized
water as the scrubbing medium. Caustic is added to the
recirculating water to maintain the pH at 7 or 8. This
scrubber has the lowest outlet concentration and the second
highest efficiency of the 10 scrubbers listed in Table 4-5.
4.3.4.5 Types of Demisters. No measurements were made
to determine the sole effectiveness of a demister. These
test results also did not address the topic of aerosol
formation in the scrubber and removal by the demister;
therefore, no conclusions can be made regarding the
effectiveness of one type of demister over another for
aerosol removal. However, all of the scrubbers tested had
one or more demisters.
4.3.4.6 Control Efficiency vs. Outlet Loading. The
correlations between control efficiencies and inlet/outlet
loadings or concentrations are not statistically
significant. However, generally the higher the control
efficiency, the lower the scrubber outlet concentration or
emission rate. Table 4-6 shows the descriptive statistics
of control efficiency, outlet HC1 concentration, and outlet
HC1 emission rate for all 10 test results. The standard
deviations of these parameters are relatively large because
of a low efficiency scrubber test (92.76 percent) from
Facility 49, Pickling line no. 4. This particular
scrubber's efficiency is lower than most of the control
4-47
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4-48
-------
efficiencies reported by the coil pickling facilities in the
1992 survey as shown in Figure 4-19. By excluding this
worst data point, Facility 49(4), the mean values and
standard deviations improved significantly for outlet HC1
concentration and emission rate as shown in Table 4-6.
Figures 4-22 and 4-23 present the ranges of outlet emission
rates and outlet concentrations in ascending orders and
their mean values when Facility 49(4) is excluded.
ests at Sr>rav Roasting Acid Regeneration Facilities
4.3.5
The process information, scrubber specifications, and
test results are shown in Table 4-7 for one EPA-conducted
source test at Facility 17 and for compliance tests at three
other facilities (Facilities 114, 131, and 136). Facility
131 has two identical units; each with a 38 gpm capacity.
Each of the processes has two scrubbers following the HC1
absorber. The first scrubber uses plain scrubbing water,
while the second scrubber uses NaOH in the recirculating
water to maintain it at a pH of 9. Emission testing was
conducted at the stack following the second scrubber.
Only facility 17 has both inlet and outlet
measurements. All other tests have only outlet
measurements. Therefore, comparisons are based on scrubber
outlet concentrations and mass emission rates of HC1 and C12
as shown in Figures 4-24 through 4-28. Figures 4-25 and
4-27 suggest that C12 emissions are correlated with HC1
emissions.
4.3.6 variables Determining Spray Roasting Emissions and
Controls
Emissions from spray roasting processes are determined
by the feed solution composition and by the operation of the
roaster, HC1 absorber, and scrubber. The ferrous chloride
concentration in the acid solution affects its viscosity and
therefore the size of the droplets formed when the acid is
4-49
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-------
Table 4-7. Comparison of Tests for 4 HCI Spray Roasting Facilities
Facility ID
Facility Name
City
State
Process ID
Age
Design Capacity, gpm
Production Rate, gpy
Type of Scrubber
Type of Packing
Depth of Packing, ft
Type and Depth of
Demister
Scrubbing Solution
Recirculation rate, gpm
Gas Flow Rate-in, dscfm
Gas Flow Rate-out,
dscfm
Pollutant cone, at
scrubber inlet
HCI-in, ppm
CI2-in, ppm
Pollutant cone, at
scrubber outlet
HCI-out, ppm
CI2-out, ppm
Uncontrolled emission
rates
HCI-in, Ib/hr
CI2-in, Ib/hr
Controlled emission
rates
HCI-out, Ib/hr
CI2-out, Ib/hr
Control efficiencies
HCI-control eff., %
CI2-control eff., %
17
WCI STEEL,
INC.
WARREN
OH
OP-10
10
38
12,000,000
PACKED
TOWER
6" PP SADDLES
10
4" MESH
CITY WATER
50
7,200
11,500
11,100
92.0
136.67
59.67
467.00
7.36
8.93
7.67
98.09
-4.21
136
BAILEY ENGINEERS
FAIRFIELD
AL
OP-1
12
27
13.000,000
PACKED TOWER
2"/3" NORTON
SADDLES
10
1 ' OF 2" NORTON
SADDLES
CITY WATER
200
NA
6,415
NA
NA
15.75
3.31
NA
NA
0.58
0.24
NA
NA
131
MAGNETICS INT.
INC.
BURNS HARBOR
IN
OP-3/OP-4
2
38X2
22,000,000
PACKED TOWER
3" SADDLES
7
4" PP MESH
NaOH solution at pH
9
200
4,690
6,260
OP-3 OP-4
23 22
5.1 7.8
2.7 0.9
2.1 0.3
0.64 0.57
0.30 0.38
0.11 0.03
0.13 0.02
82 94
53 94
114
USS POSCO
PITTSBURG
CA
OP-5
3
NA
12,000,000
VENTURI
NA
NA
NA
NaOH sol'n
NA
NA
16,467
NA
NA
0.96
NA
NA
NA
0.09
NA
99
NA
Note: NA = not available, PP = polypropylene
4-52
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atomized by the high-pressure nozzles that are used to
introduce feed to the roaster. The operation of the roaster
and HC1 absorber strongly affects the inlet loading to the
scrubber. However, process data are not available to assess
the impacts of roaster and absorber operating conditions on
emissions. Hydrochloric acid and C12 are the primary
pollutants emitted from the process. Factors that increase
chlorine formation in the roaster appear to be feed solution
with high FeCl2 concentration, large droplet size of the
injected feed, high excess air, and high roasting
temperature. A trace amount of HF was found in one test,
probably due to an impurity in the acid. The large scrubber
inlet HC1 loading (467 Ib/hr) at Facility 17 suggests that
more HC1 can be recovered from the gas stream before it goes
to the scrubber. As more HC1 is recovered by the absorber,
the lower inlet loading at the scrubber should allow it to
achieve a lower emission rate.
The collection efficiency of a packed tower scrubber is
determined by packing type and depth, scrubbing medium and
its flow rate, and demister effectiveness. Table 4-7 shows
that the scrubber at Facility 17 has a relatively small
liguid-to-gas ratio (low scrubbing medium flow rate)
compared to other scrubbers. The small liquid-to-gas ratio
may have resulted in the higher outlet concentration of HC1.
The test at Facility 17 also shows that plain water
scrubbing is ineffective in removing C12.
4.4 POLLUTION PREVENTION
4.4.1 Pickling Operations
Pollution from pickling operations is generated by HC1
emissions from the pickling tanks. Prevention of these
emissions could be obtained by substituting a less polluting
solution for removing scale or by finding an entirely
4-58
-------
different process to remove it. However, the use of HC1 is,
in itself, a pollution prevention measure as it is less
polluting than the sulfuric acid it replaces. Although most
scale removal formerly was by sulfuric acid pickling, the
industry moved to HC1 pickling to obtain a smoother surface
after pickling, to reduce acid usage, and, in part, to
reduce sulfuric acid emissions. Other, less polluting,
solutions that can provide effective scale removal have not
been found.
Another method of removing scale is sandblasting.
However, this method does not leave a sufficiently smooth
surface for further treating or shaping operations, and is
not able to treat large quantities of steel in a cost-
effective manner.
4.4.2 Wastewate-r Reduction
Three methods exist for reducing the quantity of acidic
wastewater that, in addition to being an emitter of HC1
fumes, must be treated in a wastewater treatment plant or
sent to a regeneration plant. The methods are: replacing
steam sparging with heat exchange systems, using multistage
spray rinse systems instead of dip rinses, and using sieve
tray scrubbers instead of packed bed scrubbers. All three
of these methods (described below) are in use at one or more
pickling facilities. Estimates of the amount of potential
pollution prevention from each method are not available.
4.4.2.1 Heat Exchange. As described in Chapter 3,
pickling tanks are heated by steam sparging (the
introduction of live steam into the tank) or by heat
exchange equipment that prevents the acid from being
diluted. The latter method reduces the quantity of spent
acid generated from pickling and the frequency with which
the acid must be replaced. The former method is still being
used by facilities that dispose of the spent acid by deep-
well injection. As deep-well injection permits expire in
the next few years, the spent acid must be neutralized or
4-59
-------
regenerated. Steam sparging probably will be discontinued
because it increases the volume of spent acid and dilutes
the iron concentration of the pickle liquor, thus making it
less suitable for regeneration. Many facilities have
converted to heat exchange, but encouraging the remaining
facilities to convert would reduce the volume of spent acid
to be treated. For facilities with acid regeneration,
converting to heat exchange in the pickling operation would
also make the spent acid more suitable for regeneration and
would reduce the energy requirements in the roaster because
of having to evaporate less water.
4.4.2.2 Multistage Spray Rinse Systems. For pickling
operations, rinsing after pickling is commonly done by
dipping into a vat of fresh water. As the rinse water
becomes concentrated with acid, emissions increase and the
water must eventually be discarded to a waste treatment
plant. By using a multistage spray rinse system to remove
acid from the steel being pickled, the quantity of rinse
water is reduced. HCl emissions are also reduced because
the rinse water is collected in an enclosed tank.
4.4.2.3 Sieve Tray Scrubbers. As mentioned in the
description of scrubbers, packed bed scrubbers use much
higher amounts of water than do sieve tray scrubbers. For
those facilities that do not reuse the scrubber water
elsewhere in the pickling process, converting to sieve tray
scrubbers would reduce the amount of wastewater requiring
treatment.
4.4.3 Reuse of Pickling Tank Sludge
Sludge that collects in the bottom of a pickling tank
has iron values that may be reused in steel making
processes. For those pickling facilities in an integrated
mill, or near a steel making facility, the sludge may be
recovered and recycled back into the steel making process.
Sludge handling and transportation equipment is currently
used for disposal purposes, but could be used for transfer
4-60
-------
to a sludge treatment station (if necessary) prior to reuse
in the steel mill.
4.4.4 Acid Regeneration
The use of acid regeneration is a pollution prevention
measure, as spent acid was formerly disposed of by deep-well
injection. Hydrochloric acid emissions from acid
regeneration occur at the outlet of the acid absorber. In
current practice a scrubber is employed as a control device
to reduce the emissions. Further methods of preventing
emissions from the spent acid include modifying the
regeneration process so that the absorption process is more
efficient or using the acid in some manner that eliminates
emissions (for example, reacting it with a basic stream that
neutralizes the HCl). Higher efficiency techniques may be
available but have not been studied. Neutralizing the acid
stream would not be useful unless there were specific
processing reasons for doing so. Such reasons would be
found only on a case-by-case basis; no general case has been
found that would suggest use of a neutralized stream.
.Promoting the use of acid regeneration plants by more
pickling facilities would be useful. However, unless the
plant can be designed to recover acid at a feed rate of
about 3 gal/min or greater, costs become unattractive.
4.5 CONTROL TECHNIQUES FOR C12
Referring to Table 4-7, C12 emissions of less than 4
ppmv are achieved at three acid regeneration facilities.
Scrubbing with alkaline solution is used at two of these
facilities. The third facility employs control of process
conditions to minimize C12 formation. Chlorine formation is
reduced by increasing the operating temperature of the
roaster and decreasing the oxygen in the air fed to the
roaster.20 Data are too limited to make a qualitative
4-61
-------
assessment of the capabilities of alkaline scrubbing and
process control.to collect or reduce C12 emissions.
4-62
-------
4.6 REFERENCES
1. Stone, J.N. Economical Fume Control in Pickle Houses.
Presented in 50th Annual Convention, Wire Association
International, Cincinnati, Ohio, October 5-9, 1980.
2. industrial Ventilation, 22nd Edition: A Manual of
Recommended Practice. American Conference of
Governmental Industrial Hygienists. Cincinnati. 1995.
3. Kashdan, E.R, D.W. Coy, J.J. Spivey, T. Cesta, H.D.
Goodfellow, and D.L. Harmon. Hood System Design for
Capture of Process Fugitive Particulate Emissions.
Heating/Piping/Air Conditioning, February 1986. pp.
47-54.
4. American National Standard Practices for Ventilation
and Operation of Open-Surface Tanks. ANSI Z9.1-1977.
American National Standards Institute, Inc. New York.
1977. pp. 13-14.
5. Buonicore, A.J., and W.T. Davis. Air Pollution
Engineering Manual. Air and Waste Management
Association. Van Nostrand Reinhold, New York. 1992.
6. Stone, J.N. Pickle Line Fume Control With Plate
Scrubbers. Presented at the AISE conference,
Pittsburgh, 1991.
7. Stone, J.N. Sieve Tray Design. ACCESS, Nov/Dec 1984,
pp. 10-20. LEDS Publishing Co.
8. Letter from Schott, W.M., Kimre, Inc., to Maysilles,
J.H., EPA/ESD. July 31, 1991. p. 2. Discussion of
HC1 absorption in steel pickling.
9. Memo from Kong, E., RTI, to Maysilles, J., EPA/ESD.
Validation of Existing Test Results. March 12, 1993.
10. Memo from Kong, E., RTI, to Maysilles, J., EPA/ESD.
Revision of Data Analysis for Nine Valid Test Results.
March 24, 1993.
11. Emission Test Report: Acme Steel Company, Riverdale,
Illinois. Energy and Environmental Research
Corporation, Durham, North Carolina. Prepared for U.S.
Environmental Protection Agency, Research Triangle
Park, North Carolina. December 1993.
4-63
-------
12. Emission Test Report: Worthington Steel Company,
Porter, Indiana. Energy and Environmental Research
Corporation, Durham, North Carolina. Prepared for U.S.
Environmental Protection Agency, Research Triangle
Park, North Carolina. December 1993.
13. Emission Test Report: WCI Steel Inc., Warren, Ohio.
Roy F. Weston Inc., Horrisville, North Carolina.
Prepared for U.S. Environmental Protection Agency,
Research Triangle Park, North Carolina. February 1994.
14. Report of Determination of Emissions. Spang and
Company, Magnetics Division - Metal Oxide Plant,
Booneville, Arkansas. Environmental .Services Co.,
Inc., Little Rock, Arkansas. Prepared for Magnetics,
Division of Spang and Company, Booneville, Arkansas.
November 1987.
15. Emission Test Report: Magnetics International, Inc.,
Burns Harbor, Indiana - Plants A and B Caustic Scrubber
Inlet and Outlet. Clean Air Engineering, Palatine,
Illinois. Prepared for Magnetics International, Inc.,
Burns Harbor, Indiana. June 1994.
16. Particulate, HC1, and C12 Emission Test Report: Bailey
Engineers, Fairfield, Alabama. Guardian Systems, Inc.,
Leeds, Alabama. Prepared for Bailey Engineering,
Fairfield, Alabama. April 1992.
17. Memo from Kong, E., RTI, to Maysilies, J., EPA/BSD.
Source Test Plan. National Emission Standards for
Hazardous Air Pollutants (NESHAP) for Steel Pickling -
HC1 Process. August 21, 1992.
18. Hudson, R.M. Pickling of Hot Rolled Strip; An
Overview. Iron and Steel Maker, 18(9), September 1991.
p. 32.
19. Esco Engineering Co. Estimation of HC1 Losses From
Pickling Tanks (spreadsheet model). Kingsville,
Ontario. March 1993.
20. Chlorine Control of Pickling Acid Regeneration Plants.
E.Th. Herpers, B. Schweinsberg, N. Ozer, and J. Bozcar.
International Chemical Engineering Symposium Series No.
57, pp. BB1-BB14. Available from University of
California, Los Angeles, PSTL/Interlibrary Loans, 8251
Boelter Hall, Los Angeles, CA 90024-1598.
4-64
-------
5.0 MODEL PLANTS AND CONTROL OPTIONS
This chapter describes representative model plants and
emission control systems for reducing HC1 emissions from
steel pickling operations and HC1/C12 emissions from acid
regeneration processes. Model plants are developed as
parametric descriptions of the general types of steel
pickling operations and acid regeneration processes to
represent the current industry or facilities that are
expected to be constructed in the future. Model plants are
used because it is impractical to evaluate environmental,
economic, and energy impacts of various emission control
options for every existing facility on a case-by-case basis.
Control options are the sets of demonstrated emission
control techniques currently being evaluated as the
reference control technologies in determining the maximum
achievable control technology (MACT). The models are
derived from information in Chapters 3 and 4 that describes
HC1 steel pickling operations and control technologies,
respectively. Seventeen model plants were developed to
represent five types of pickling operations and one acid
regeneration process. The model plants include one or more
size variations for each process type. Section 5.1 presents
the rationale for the development of these model plants.
Section 5.2 describes the baseline controls for the source
category. Section 5.3 provides a discussion of potential
control options.
5-1
-------
5.1 MODEL PLANT PARAMETERS
This section presents the model plants for each process
type, the rationale for sizing model plants, and a
description of the parameters that are critical to plant
size, control equipment, and baseline emissions. For the
purpose of the analysis, the processes for this source
category were divided into acid pickling operations and acid
regeneration processes. The acid pickling operations focus
on the removal of metal oxides with HC1 acid, and the acid
regeneration process focuses on the regeneration of spent
acid by spray roasting.
Based on information collected through a 1992 industry
survey, site visits, and process engineering firms, five
pickling operations and one acid regeneration process were
selected for model plant development. These five pickling
operations are: continuous strip or coil pickling, push-
pull strip or coil pickling, continuous rod/wire pickling,
continuous tube pickling, and batch pickling. Acid
regeneration plants are usually associated with continuous
or push-pull coil pickling facilities; therefore, models for
continuous or push-pull coil pickling operations can be
combined with a model for acid regeneration to represent a
complete model facility.
As defined, the steel pickling - HC1 process source
category includes 36 continuous coil pickling facilities (64
process lines), 19 push-pull coil pickling facilities (22
process lines), 20 continuous rod/wire pickling facilities
(55 process lines), 4 continuous tube pickling facilities
(11 process lines), 26 batch pickling facilities (59 process
units), and 10 acid regeneration facilities (13 units).
Four of the above facilities conduct both batch and rod/wire
pickling. Two of the 10 acid regeneration plants are stand-
alone facilities operated by independent companies, and the
remaining 8 plants are collocated with a pickling operation.
5-2
-------
The sizes of model plants are based on the annual
production capacity in tons of steel processed for pickling
facilities or on gallons of spent acid regenerated for acid
regeneration facilities. According to the distribution of
plant sizes for each type of operation, two or three model
plants of varying sizes are proposed. Table 5-1 shows the
model plant codes for each type of operation.
TABLE 5-1. MODEL PLANT CODES FOR THE STEEL PICKLING -
HC1 PROCESS SOURCE CATEGORY
Type of operation
Continuous Coil Pickling
Push-pull Coil Pickling
Continuous Rod/Wire Pickling
Continuous Tube Pickling
Batch Pickling
Acid Regeneration
Plant size
Small
CCS
PCS
CWS
CTS
BS
ARS
Medium
CCM
PCM
CWM
BM
ARM
Large
CCL
PCL
CWL
CTL
BL
ARL
Each model plant description also includes capacity
utilization rate, economic lifetime, annual operating hours,
process parameters, properties of the uncontrolled gas
stream, and specifications for emission control systems.
The capacity utilization rate is determined from the actual
annual production and the maximum production capacity
reported by the facilities in the 1992 industry survey. The
capacity utilization rates for facilities in the model plant
size range are averaged and reported for that model plant.
The economic lifetime for existing plants and the average
control efficiency for controlled sources are calculated in
the same manner from reported information. The ratio of
controlled process lines and total process lines within the
5-3
-------
model plant size range represents the baseline control for
the existing plants. From the ranges shown in Table 4-7,
MACT is selected as a scrubber capable of meeting a 10 ppmv
outlet concentration limit, or, at high inlet
concentrations, a 97.5 percent efficiency limit.
The design procedures outlined in Chapter 9 of the
OAQPS Control Cost Manual1 for gas absorbers are used to
determine the specifications for packed tower scrubbers,
which are commonly used by the industry for emission
control. Sieve tray scrubbers, which use less water than
packed tower scrubbers, are also used in the pickling
industry. They would be expected to have higher capital and
lower annual costs depending on costs of water and
wastewater treatment.
When estimating emissions from individual pickling
tanks, a model developed by Esco Engineering was used. This
model is described in Appendix E, Tank Emissions Model.
5.1.2 Model Plants for Continuous Coil Pickling
5.1.2.1 Distribution of Plants bv Size. A frequency
distribution of the annual processing capacities of 28 of
the 36 continuous coil pickling facilities is shown in
Figure 5-1. Capacities for the remaining eight facilities
are either confidential or were not reported. The x-axis
shows the maximum annual production capacity of each
facility and the y-axis shows the cumulative number of all
continuous coil pickling facilities. Reported annual
production capacities for these facilities range from 82,000
tpy to 1.9 million tpy for a single pickling line and from
200,000 tpy to 3.4 million tpy for an individual facility.
Most of the larger facilities or pickling lines are
associated with integrated steel mills. Most facilities
have multiple pickling lines. Of the 64 individual process
lines, 61 are configured horizontally and three vertically.
Three models of varying sizes (small, medium, and
large) are selected to cover the distribution of continuous
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coil picklers. A facility with a maximum production
capacity less than 740,000 tpy is considered small, between
740,000 and 1.5 million tpy is considered medium, and
greater than 1.5 million tpy is considered large. Three
model plants (450,000, 1.0 million, and 2.7 million tpy
annual capacity) are selected to represent the median value
of each size range. Two process lines are designated for
each model plant. All are horizontally configured. The
number of process lines for each model plant is determined
from the distribution of process lines and their capacities
in continuous coil pickling facilities. The model plant
parameters are shown in Table 5-2. The capacity utilization
rates for these model plants are the averages of actual
capacity utilization rates in each size range reported
the 1992 industry survey.
in
5.1.2.2 Description of Process Parameters. There
are
many mechanical characteristics that affect the capacity and
speed of a continuous coil pickling line. Most continuous
coil pickling is done in a series of 3 or 4 horizontal
pickling tanks. The lengths of the pickling tanks
determined by the processing speed that provides adequate
residence time to remove scale. The width of the pickling
tanks limits the width of the coil that
are
can be processed.
xn
Most pickling lines can process strips from 0.05 to 0.5
thick. Following the pickling tanks are rinse sections that
remove acid residue from the strip. The number of pickling
tanks and rinse tanks and their dimensions determine the
surface area for HC1 emission and for costs of enclosures
and ductwork. Typical dimensions for a pickling tank range
from 70 to 90 ft long, 6 to 9 ft wide, and 4 to 6 ft deep.
The dimensions for rinse tanks are similar to those of
pickling tanks except that the tanks may be shorter.
The HC1 concentration and bath temperature in the
pickling tanks are the key factors that affect HC1 emission
rates and the design of emission control systems. The
5-6
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pickling liquor is maintained betwen 180 and 200 °F by live
steam injection or by internal or external heat exchange to
achieve effective pickling of the fast-moving strip.
Typical acid concentrations in a 4-tank pickling line are 2
to 4 percent in Tank 1, 5 to 7 percent in Tank 2, 8 to
10 percent in Tank 3, and 10 to 14 percent in Tank 4.
The properties of the uncontrolled gas stream and the
emission control system design criteria are provided for
designing and costing the emission control system. These
parameters represent typical ranges found in continuous coil
pickling facilities.
5.1.2.3 Emissions and Controls. All of the 64
continuous coil pickling lines are equipped with emission
capture systems and all but 4 lines are equipped with
control devices. The pickling and rinse tanks are typically
enclosed by plastic covers. The acid fumes are collected by
ductwork, vented by induced-draft (ID) fans, and treated by
control devices to remove HC1. The ratio of controlled
process lines to total process lines for facilities in each
model plant size range is shown in Table 5-2. This ratio
represents the baseline control for sources within the model
plant size. The average efficiency for existing controls is
also calculated for each model plant size range.
Fugitive emissions from acid storage tanks are not
significant compared to those from pickling operations.
However, they are a nuisance, as the displaced vapor is
emitted from tank vents during the tank filling stage.
Traditionally, emissions from acid storage tanks have not
been captured, but in newer emission control systems these
tank vents are commonly tied into the same fume exhaust
system used for the pickling line.
Table 5-3 shows the specifications for a packed tower
scrubber that can achieve the required degree of control.
The specifications in Table 5-3 are determined from the
5-8
-------
TABLE 5-3. SPECIFICATIONS FOR PACKED TOWER SCRUBBERS -
CONTINUOUS COIL PICKLING PROCESSES (English units)
1===========
Plant size (model plant
code)
Gas flow rate, acfm
Dimensions (HxD), ft
Packing depth, ft
Overall pressure drop, inch
w.c.
Scrubbing water
recirculation rate, gpm
=========
Smell (CCS)
7.5OO
20.2x5.0
8.O
6.7
92
g==
15,000
21 .3x7.2
8.0
6.7
184
«==
.
Medium (CCM)
10,000
20.O x 5.9
8.0
6.7
122
=========
30.OOO
24.3 x 10
8.0
6.7
367
===========
================
Large (CCL)
35,000
25.2 x 1 1
8.0
6.7
428
42,500
26.3 x 1 2
8.0
6.7
520
Note:
1. Uncontrolled HCI cone. = 835 ppmv
2. Design control efficiency = 97.5 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
7. An 8-inch mesh pad demister is required above the packing
8. Two ID fans are required, one on standby. (This is a common practice for this process type.)
5-9
-------
sizing procedures shown in the OAQPS Control Cost Manual for
packed tower scrubbers based on the properties of
uncontrolled gas stream and the gas flow rates shown in
Table 5-2. Additional specifications are shown at the
bottom of Table 5-3. The EPA OAQPS Control Cost Manual also
presents costing procedures for packed tower scrubbers so
that cost comparisons between model plants can be done
consistently using the same type of scrubber.
5.1.2.4 New Continuous Coil Pickling Plants. Except
for two new lines, the majority of the continuous coil
pickling lines were built before the 1970s. Both new lines
were built in 1988 and were designed for 1.4 million tpy
capacity.
One line includes three shallow horizontal pickling
tanks. Pickle liquor is sprayed continuously onto the
moving strip. The pickling line is equipped with looper
cars for strip storage. The maximum line speeds at the
entry section and pickling section are 1,800 fpm and 820
fpm, respectively. The pickle liquor is recirculated
through external circulation tanks and heated by external
heat exchangers. The pickle liquor is drained to
circulation tanks when the line is not operating. Pickle
liquor cascades in the circulation tanks not in the pickling
tanks. The other pickling line is the descaling section of
a continuous annealing process line that also includes
tandem rolling, annealing, and temper rolling. The pickling
line is equipped with looper cars for strip storage. The
maximum line speeds at the entry section and pickling
section are 1,970 fpm and 660 fpm, respectively. The
pickling line design uses the traditional horizontal dip
tank design, and the pickle liquor is heated by internal
heat exchangers. The line is equipped with strip lifters to
lift the strip up in the event of line stoppage.
Both lines use multi-stage spray rinsing to remove acid
residue from the strip and hot compressed air to dry the
5-10
-------
strip. Spray rinsing uses much less water than the
traditional dip rinse and therefore minimizes the amount of
wastewater generated, pickling tanks and rinse sections on
both lines are enclosed by plastic covers, and the acid fume
is evacuated by ID fans through ductwork and treated by
packed tower scrubbers. Acid emissions from circulation
tanks and acid storage tanks are also piped into the same
emission control systems in both plants. Both plants use
packed tower scrubbers and caustic scrubbing liquor for HC1
emission control.
The trend in process or equipment modification in the
past few years includes: regenerating spent acid to avoid
deep well injection or neutralization, replacing live steam
injection with heat exchangers to minimize the quantity of
spent acid generated (because steam condensate dilutes the
acid), replacing old scrubbers with devices that generate
less blowdown such as sieve tray scrubbers, venting acid
storage tank emissions to the emission control system, and
reusing rinse effluent or scrubber blowdown to reduce
wastewater quantity and to lower treatment costs.
5.1.3 Model Plants for Push-Pull Coil Pickling
5.1.3.1 Distribution of Plants bv Size. A frequency
distribution of the reported annual production capacities of
all 19 push-pull coil pickling facilities is shown in
Figure 5-2. Annual processing capacities for these
facilities range from 110,000 to 1,300,000 tpy. The
majority of the push-pull pickling lines are associated with
mini-mills or the steel service industry, which cleans,
splits, and cuts steel strip to specific requirements. All
but two facilities operate only one pickling line; the
remaining two operate 2 and 3 lines, respectively. All
push-pull pickling lines are configured horizontally with
three or four pickling tanks followed by a rinse section.
Three models of varying sizes (small, medium, and
large) are selected to cover the distribution of push-pull
5-11
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coil picklers. A facility with a production capacity less
than 400,000 tpy is considered small, between 400,000 tpy
and 800,000 tpy is considered medium, and greater than
800,000 tpy is considered large. Facilities with the larger
capacities are generally newer than the smaller facilities.
Model plants of 300,000 tpy and 550,000 tpy are selected
that represent the median values of small and medium plants.
A model plant of 1.3 million tpy annual capacity represents
the largest facility. One process line is specified for
each model plant. The average capacity utilization rates
for each model plant size are calculated from the actual
capacity utilization rates of facilities in each model plant
size range.
5.1.3.2 Description of Process Parameters. Push-pull
coil pickling lines are similar to horizontal, continuous
coil pickling lines except that push-pull lines do not have
welders at the entry sections nor storage areas for the
strips; therefore, individual strips are threaded through
the process line. The pickling tanks of a push-pull line
are generally shorter than those of a continuous line
because the line speed during pickling is usually slower
than that of a continuous line. Other operating conditions
and procedures of a push-pull line are similar to those of a
continuous line. Table 5-4 includes the parameters for the
proposed process lines in the model plants. These
parameters, compiled from process data provided by the
industry and engineering firms, are nominal conditions for
push-pull coil pickling lines.
5.1.3.3 Emissions and Controls. The pollutant,
emission sources, and emission control systems for push-pull
coil pickling lines are similar to those for continuous coil
pickling lines. All 22 push-pull coil lines are equipped
with emission capture systems and control devices. Twenty-
five emission control devices are use by the 19 facilities
5-13
-------
TABLE 5-4. MODEL PLANT PARAMETERS - PUSH-PULL COIL
PICKLING PROCESSES (English units)
Parameters
A. Total production capacity, tpy
No. of pickling lines
Production capacity per line, tpy
Capacity utilization rate, percent
Model plant remaining lifetime (existing/new), yr
B. Annual operating hours
C. Process parameters1
D. Properties of uncontrolled gas stream2
E. Emission control system design criteria3
Total gas flow rate per line, acfm
No. of scrubbers for each pickling line
F. Uncontrolled HCI emissions, Ib/hour*
G. Number of facilities represented by the model plant
H. Ratio of controlled to total process lines within the
model plant size range (percent controlled)
1. Average control efficiency for existing controlled
sources, percent
Plant size (model plant code)
Small (PCS)
300,000
1
300.OOO
57
20/30
5.OOO
5,000
1
12
12
12/12(100%)
98
Medium (PCM)
550,000
1
550,000
44
22/30
4,400
11,000
1
27
6
9/9 (100%)
98
Large (PCD
1,300,000
1
1,300,000
67
27/30
8,760
17,500
1
42
1
1/1 (100%)
95
Note:
(1) Acid temperature in the pickling tanks is 190"F; acid concentrations range from 3 percent at the strip entry end to
12 percent at the exit end.
(2) Average HCI cone, in the uncontrolled gas stream is 450 ppmv, the temperature of the uncontrolled gas stream is
100 °F, and the moisture content is 8 percent,
(3) Pickling tanks and rinse section are enclosed with covers having multiple intakes to evacuate acid fumes,
(4) Uncontrolled emission rates are determined from HCI concentration in the gas stream and the given flow rates.
5-14
-------
for HC1 emission controls; including 10 sieve tray
scrubbers, 13 packed tower scrubbers, and 2 horizontal
packed bed scrubbers. Most newer emission control systems
are designed to remove from 98 percent to as high as 99.9
percent HCl. Referring to Table 5-4, the average efficiency
for existing controls is calculated for each model plant
size range. In newer facilities, acid storage tank
emissions are ducted to the same emission control system.
Table 5-5 shows the specifications for packed tower
scrubbers for HCl emission controls. The specifications in
Table 5-5 are determined from design procedures shown in the
QAOPS Con+™i cost Manual for packed tower scrubbers, which
are based on properties of the uncontrolled gas stream and
the gas flow rates shown in Table 5-4. Additional
specifications are shown at the bottom of Table 5-5.
5.1.3.4 New Push-Pull Coil Pickling Plants. Except
for a few older lines, most of the push-pull pickling lines
were built in the 1980s and 1990s. Two typical process
designs emerged: a simple version using granite-lined
tanks, hydraulic drives, and coil to coil tension
technology; and a more sophisticated version with tanks
designed for high-speed threading, direct current electric
drives, and an advanced strip tracking system for more
demanding process control requirements. Both designs use
shallow-tray pickling and high-volume sprays of hot acid
over the strip to reduce pickling time. The pickling liquor
is recirculated to external circulation tanks and heat
exchangers that are located alongside the pickling line.
This design permits better control over acid temperature and
concentration in each pickling tank. During line stoppage,
the pickle liquor is drained to the circulation tanks.
Multi-stage spray rinse is usually used to minimize water
consumption, and the rinse effluent is used as makeup water
for the acid. New process lines usually minimize wastewater
5-15
-------
TABLE 5-5.
SPECIFICATIONS FOR PACKED TOWER SCRUBBERS - PUSH-PULL
COIL PICKLING PROCESSES (English units)
Plant sizes (model plant codes)
Gas flow rate, ocfm
Dimensions (HxD), ft
Pocking depth, ft
Overall pressure drop, inch w.c.
Scrubbing water recirculation
rate, gpm
Small (PCS)
5,000
18.2x4
8.0
6.7
61
Medium (PCM)
11.OOO
20.3 x 6.1
8.0
6.7
134
Large (PCL)
17,500
21 .9 x 7.8
8.0
6.7
214
Note:
1. Uncontrolled HCI cone. = 450 ppmv
2. Design control efficiency — 97.5 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
• 7. An 8-inch mesh pad demister is required above the packing
8. Only one ID fan is required
5-16
-------
generation by reusing rinse water in the scrubber or reusing
scrubber blowdown in the rinse stage. Acid emissions from
pickling lines, external circulation tanks, and acid storage
tanks are usually treated in the same emission control
system.
With improved loading, uncoiling, and coiling
mechanisms, a new push-pull pickling line may reach anannual
capacity above 1 million tpy, which is comparable to a
medium-sized continuous coil pickling line. The push-pull
operation is the pickling process of choice for the steel
service industry because coils of various sizes and gages
can be handled and less capital investment is required than
for a continuous pickling operation of comparable size.
5.1.4. Model Plants for Continuous Rod/Wire Pickling
5.1.4.1 Distribution of Plants bv Size. A frequency
distribution of the annual production capacities of all 20
continuous rod/wire pickling facilities is shown in
Figure 5-3. Annual processing capacities for rod and wire
range from as low as 120 tpy to 60,600 tpy for a single
process line and from 380 tpy to 211,800 tpy for a single
facility. The majority of the facilities have multiple
process lines, ranging from two to nine. Continuous
rod/wire pickling is also called strand pickling because a
process line can pickle multiple strands of rods or wires at
the same time. Four facilities have both continuous and
batch wire pickling operations in the same location. For
consistency, the model plants present only the continuous
wire pickling. Model plants for batch pickling operations
are presented in Section 5.1.6.
Three models of varying production capacities (small,
medium, and large) are selected to cover the distribution of
continuous rod/wire picklers. A facility with an annual
production capacity less than 24,000 tpy is considered
small, between 24,000 and 150,000 tpy is considered medium,
and greater than 150,000 tpy is considered large. A model
5-17
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plant is selected to represent the median value of each size
range. These model plants are 10,000 tpy, 55,000 tpy, and
215,000 tpy. The small, medium, and large model plants
respectively have four, three, and nine process lines of
varying capacities and strands.
5.1.4.2 Description of Process Parameters. The
capacity of a continuous rod/wire pickling line is
determined by the gauge of the material processed, the
number of strands, and the line speed. A process line may
pickle as few as 6 rods or as many as 40 wires at the same
time. Line speed is faster for finer wires. Pickling is
usually done in shallow trays where wires are immersed in an
acid solution that is replenished continuously. The
pickling trays usually range from 15 to 40 ft long, 40 to 65
in. wide, and 10 to 25 in. deep. Acid temperature usually
ranges from 90 to 150 °F, and its concentration ranges from
10 to 25 percent HCl. Typical process parameters are
presented in Table 5-6 for the continuous rod/wire pickling
lines in the model plants.
5.1.4.3 Emissions and Controls. The pickling and
rinse sections are the emission sources from the process
line. The pickling and rinse sections are usually covered
by enclosure hoods and the acid fumes are exhausted by ID
fans. Some hoods have water seals on the sides and layers
of split rubber flaps on the ends, which allow the material
to enter and exit. Some newer process lines have water
curtains on both ends of the hood to prevent acid fumes from
escaping the enclosure hood. Of the 55 continuous rod/wire
pickling lines, 19 are equipped with emission capture and
control devices, 32 are equipped with capture devices but
without controls, and the remaining 4 lines are without
capture or control devices. Packed tower scrubbers,
horizontal packed bed scrubbers, and sieve tray scrubbers are
commonly used by this process type. Sometimes a control
5-19
-------
TABLE 5-6. MODEL PLANT PARAMETERS - CONTINUOUS ROD/WIRE
PICKLING PROCESSES (English units)
Parameter*
A. Total production rate, tpy
No. of pickling lines
Production rate per line, tpy
Capacity utilization rate, percent
Model plant remaining lifetime (existing/new), yr
B. Annual operating hours
C. Process parameters1
D. Properties of uncontrolled gas stream2
E. Emission control system design criteria3
No. of scrubbers for the model plant4
Gas flow rate for each scrubber, acfm
F. Uncontrolled emissions, Ib/hour6
G. Number of facilities represented by the model
plant
H. Ratio of controlled to total process lines within the
model plant size range (percent controlled)
1. Average control efficiency for existing controlled
sources, percent
Plant size (model plant code)
Small (CWS)
10,000
4
5,000x1
3,000x1
1,000x2
66
22/45
5,100
2
2,5OOx2
46
9
4/17 (24%)
98
Medium (CWM)
55.OOO
3
10,000x2
35,OOOx1
71
21/45
7,800
2
8,OOOx1
5,000x1
119
10
1 5/29 (52%)
94
Large (CWL)
21 5,000
9
35,OOOx1
30,OOOx4
20,OOOx2
10,OOOx2
61
11/45
7,200
5
8,OOOx2
1 2,OOOx2
5,000x1
413
1
0/9 (0%)
0
Note:
(1) Typical acid temperature in the pickling tanks is 110 °F and acid concentration is 12 percent HCI, line speed ranges from
1OO fpm for rods to 500 fpm for wires.
(2) Average HCI cone, in the uncontrolled gas stream is 1,680 ppmv, temperature of the uncontrolled gas stream is 90 °F, and
the moisture content is 8 percent,
(3) Pickling tanks and rinse sections are enclosed with covers having one or two intakes to evacuate acid fumes,
(4) One scrubber controlling emissions from multiple process lines is a common practice for this process type.
(5) Uncontrolled emission rates are determined from HCI concentration in the gas stream and the given flow rates.
5-20
-------
device is used to control emissions from multiple process
lines. The ratio of controlled process lines to total process
lines for facilities in each model plant size range is shown
in Table 5-6. This ratio represents the baseline control for
sources within the model plant size. The average efficiency
for the existing controls is also calculated for each model
plant size range. A few facilities also installed simple fume
washers to capture emissions from the acid storage tanks.
Table 5-7 shows the specifications for packed tower scrubbers.
The specifications correspond to the gas flow rates and
uncontrolled HCl concentration shown in Table 5-6. These
specifications are determined by the design procedures shown
in Chapter 9 of the QAOPS Control Cost Manual.
5.!.4.4 NAW Continuous Rod/wire Pickling Plants. Only a
few plants were built in the past 10 years. Most of the
facilities are old process lines that have been renovated or
have new equipment added. Some process lines use a fumeless
pickler, in which the pickling section is enclosed and both
the entry and exit ends are closed by water curtains. Acid
fumes in the fumeless pickler are contained within the
enclosure hood and are not exhausted. For older lines, the
heating method may change from steam sparging to heat
exchangers.
5.1.5. Model Plants for Continuous Tube Pickling
5.1.5.1 Distribution of Plants bv Size. A frequency
distribution of. the annual production capacities of four
continuous tube pickling facilities is shown in Figure 5-4.
Facilities other than these four may exist but were not
identified in the survey. Annual processing capacities range
from 35,000 tpy to 156,000 tpy for a single process line and
from 40,000 tpy to 421,000 tpy for a single facility. The
majority of the facilities have multiple process lines,
ranging from two to six.
Two models of varying production capacities (small and
large) are selected to cover the distribution of continuous
5-21
-------
TABLE 5-7. SPECIFICATIONS FOR PACKED TOWER SCRUBBERS -
CONTINUOUS ROD/WIRE PICKLING PROCESSES (English units)
Plant sizes (model plant
codec)
Gas flow rate, acfm
Dimensions (HxD), ft
Packing depth, ft
Overall pressure drop,
inch w.c.
Scrubbing water
recirculation rate, gpm
Small (CWS)
two
2,500
17.0x2.9
8.0
6.7
31
Medium (CWM)
5,000
18.2x4.1
8.0
6.7
61
8.OOO
19.3x5.2
8.0
6.7
98
Large (CWL)
5,000
18.2x4.1
8.0
6.7
61
two
8,000
19.3x 5.2
8.0
6.7
98
two
12.OOO
20.5 x 6.4
8.0
6.7
147
Note:
1. Uncontrolled HCI cone. = 1,680 ppmv
2. Design control efficiency = 97.5 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
7. An 8-inch mesh pad demister is required above the packing
8. Only one ID fan is required
5-22
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5-23
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tube picklers. A facility with an annual production capacity
less than 150,000 tpy is considered small and greater than
150,000 tpy is considered large. One model plant is selected
to represent the median value of the small size range and the
other to represent the largest facility. The small and large
model plant production capacities are 80,000 tpy and 420,000
tpy, respectively. The small and large model plants
respectively have two and six process lines of varying
capacities.
5.1.5.2 Description of Process Parameters. The capacity
of a continuous tube pickling line is determined by the
outside diameter and gauge of the tube and the processing
speed. The smaller the diameter, the faster the processing
speed. During the tube manufacturing process, steel coils are
formed into tube and the seam is butt-welded or electric-
resistance welded continuously. Following the welding step,
the tube is pickled to remove scale formed during the heat
forming or welding steps and to clean the exterior surface for
subsequent coating. Continuous pickling is usually done by
pouring acid over the seam in an enclosed tank or immersing
the seamed tube in an acid bath. The acid is replenished
continuously. The pickling tank usually ranges from 6 to 20
ft in length, 2 to 6 ft in width, and 1 to 2 ft in depth.
Acid temperature usually ranges from 90 to 110 °F, and its
concentration ranges from 5 to 15 percent HC1. Typical
process parameters are presented in Table 5-8 for the
continuous tube pickling lines in these two model plants.
5.1.5.3 Emissions and Controls. The pickling section is
the emission source from the process line. The pickling
section is usually enclosed and the acid fumes are exhausted
by ID fans. Of the 11 continuous tube pickling lines, 6 are
equipped with emission capture and control devices, and the
remaining 5 process lines are equipped with capture systems
but not controls. Horizontal packed bed and vertical packed
5-24
-------
TABLE 5-8. MODEL PLANT PARAMETERS - CONTINUOUS TUBE
PICKLING PROCESSES (English units)
Parameters
Production rate per line, tpy
Capacity utilization rate, percent
Model plant remaining lifetime (existing/new), yr
B. Annual Operating hours
D. Properties of uncontrolled gas stream2
E. Emission control system design criteria3
No. of scrubbers for the model plant*
Gas flow rate for each scrubber, acfm
F. Uncontrolled emissions, Ib/hour6
G. Number of facilities represented by the model plant
H. Ratio of controlled to total process lines within the model
plant size range (percent controlled)
1. Average control efficiency for existing controlled sources.
Plant size (model plant code)
Small (CTS)
80,000
2
30,000x1
50,OOOx1
82
21 /4O
6,400
1
8,000
73
3
5/5 (100%)
95
Large
-------
tower scrubbers are used by these picklers for emission
controls. If a facility has two process lines, one scrubber
is used to treat the emissions from both lines. The ratio of
controlled process lines to total process lines for facilities
in each model plant size range is shown in Table 5-8. This
ratio represents the baseline control for sources within the
model plant size. The average efficiency for existing
controls is also calculated for each model plant size range.
Table 5-9 shows the specifications for packed tower scrubbers.
The specifications correspond to the gas flow rates and
uncontrolled HC1 concentration shown in Table 5-8. These
specifications are determined by the design procedures shown
in Chapter 9 of the OAQPS Control Cost Manual.
5.1.5.4 New Continuous Tube Pickling Plants. The newest
plant was built 7 years ago. Most of the facilities have 20-
to 30-year-old process lines. Under the current market
situation, it is uncertain if any new plants will be built.
5.1.6 Model Plants for Batch Pickling
5.1.6.1 Distribution of Plants by Size. The 1992
industry survey included 26 batch pickling facilities with a
total of 59 batch pickling units. Twelve facilities (38
units) use HCl batch pickling as a metal surface cleaning or
etching process for various metal shapes prior to applying
surface coatings such as galvanizing. The other 14 facilities
with a total of 21 process units perform rod or wire batch
pickling to remove oxide or scale from the material.
Generally, the acid solution is maintained atambient
temperature for surface cleaning or etching and at an elevated
temperature (up to 120°F) for oxide removal. Acid fume
emission potential is higher at elevated temperatures. The
annual processing capacities range from less than 1 to 100,000
tpy for a single batch pickling process and from 70 to 216,000
tpy for a single facility. Most facilities have multiple
5-26
-------
TABLE 5-9.
SPECIFICATIONS FOR PACKED TOWER SCRUBBERS - CONTINUOUS
TUBE PICKLING PROCESSES (English units)
=====
Plant si;
Gas flo
Dimensi
Packing
Overall
=========
es (model plant codes)
ons (HxD), ft
depth, ft
Scrubbing water recirculation
rate, gpm
Small (CTS)
8.00O
19.3x5.2
8.0
6.7
98
========================
Large (CTU
three 8.OOO
19.3x5.2
8.0
6.7
98
10,000
20.0 x 5.9
8.0
6.7
122
Note:
1. Uncontrolled HCI cone. = 1,680 ppmv
2. Design control efficiency = 97.5 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
7. An 8-inch mesh pad demister is required above the packing
8. Only one ID fan is required
5-27
-------
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process units. The plant size frequency distribution is shown
in Figure 5-5. Three model plants of varying capacities are
proposed for this process type. A facility with an annual
production capacity less than 40,000 tpy is considered small,
between 40,000 and 120,000 tpy is considered medium, and
larger than 120,000 is considered large. A model plant xs
selected to represent the median value of each size range.
These model plants are 15,000, 75,000, and 170,000 tpy,
respectively. The small, medium, and large model plants
respectively have three, one, and three process units of
varying capacities.
5162 ivac^-Hption »* Process Parameters. Open tank
batch picking operations are different from other continuous
pickling operations in the way the steel is handled and the
way the pickling is done. In the batch pickling process, the
steel material is hung on a rack and immersed in an add
solution until the scale or oxide is removed. Rinsxng xs
performed in a separate dip or spray rinse tank. The
processing capacity is determined by the type of material, the
size of the tank, the size of the load, and the picking txme.
Steel rod and wire in coils up to 3,000 Ib can be pickled xn a
batch operation. Flat sheets can be batch pickled, but the
sheets must be held vertical and physically separated to
improve acid contact.
A fresh batch of acid solution is prepared, then the
pickling is performed until the iron concentration of the acxd
solution reaches the maximum allowable concentration (about 13
percent by weight) or until the free HCl reaches the lower
effective limit. Typical HCl concentration in the batch
pickling process ranges from 12 percent at the beginnxng of a
fresh batch to 4 percent before acid replacement. Acxd and
iron concentrations are monitored by the operator a few txmes
a day. When the acid solution is no longer effective, the
spent acid is drained or pumped to storage tanks and a new
batch of acid solution is prepared. For surface cleanxng or
5-29
-------
etching, immersion time ranges from 5 to 15 minutes with the
acid bath at ambient temperature. For oxide or scale removal,
the immersion time may range from 10 to 40 minutes at 120 °F.
Heating is done by live steam sparging or internal heat
exchange. Table 5-10 shows the physical parameters for the
proposed model plants.
5-1-6-3 Emissions and Controls. Acid and steam fumes
arise from the open surface of the pickling tank and from the
surface of the pickled material as it is lifted from the acid
bath and transferred to the next process unit. Of the 55
batch pickling units, 36 units are equipped with a capture
devices and 13 of these units have subsequent control systems.
The emission capture devices usually are lateral exhaust hoods
or push-pull systems. Control devices used in batch pickling
operations include fume washers, horizontal packed bed
scrubbers, sieve tray scrubbers, and packed tower scrubbers.
It is common to treat acid emissions from 2 or 3 batch
pickling units with one control device.
Information from a 1992 survey conducted by the EPA shows
that 3 of the 12 batch operations pickling various metal
shapes have emission control systems with control efficiencies
ranging from 92 to 99 percent. Six of the 11 facilities
performing batch pickling for wire and rod have emission
control systems with control efficiencies ranging from 75 to
97 percent. The total number of process"units for facilities
in the model plant size range and those with control devices
are shown in Table 5-10. The ratio of these two numbers
represents the fraction of sources controlled within the model
plant size. The properties of the uncontrolled gas stream and
the gas flow rate are shown in Table 5-11 for each model
plant.
5-1-6'4 New Batch Picklincr Pi^rH-g. Most of the wire/rod
batch pickling facilities were built in the 1970s and 1980s,
and only a few were built in the past 5 years. Most new batch
5-30
-------
TABLE 5-10. MODEL PLANT PARAMETERS - BATCH
PICKLING PROCESSES (English units)
Parameters
A. Total production rato, tpy
No. of pickling units
Plant size (model plant code)
Small IBS)
1 5,000
Medium (BM)
75.000
Large (BU
170,000
50,000x2
70,OOOx1
1,000x1
4,000x1
10,OOOx1
Production rate per unit, tpy
Capacity utilization rate, percent
Model plant remaining lifetime (existing/new), yr
B. Annual Operating hours
.^
C. Process parameters'
D. Properties of uncontrolled gas stream2
E. Emission control system design criteria3
No. of scrubbers for the model plant4
25,OOOx2
40.000x1
Gas flow rate for each scrubber, acfm
F. Uncontrolled emissions, Ib/hour6
G. Number of facilities represented by the model
plant
H. Ratio of controlled to total process lines within
the model plant size range (percent controlled)
1. Average control efficiency for existing controlled
sources, percent
id temperature in the pickling tanks starts from ambient temperature at a fresh batch of acid and up to 120 °F before the
acid is replaced,
,2) Average HC. cone, in the uncontrolled gas stream is 300 ppmv. the temperature of the uncontrolled gas stream ,s 9O F. and
the moisture content is 8 percent,
(3) Pickling tanks and rinse section are enclosed with covers having one or two intakes to evacuate acid fumes,
<4) One scrubber controlling emissions from multiple process lines is a common practice for this process type,
(5) Uncontrolled emission rates are determined from HCI concentration in the gas stream and the given flow rates.
5-31
-------
TABLE 5-11,
SPECIFICATIONS FOR PACKED TOWER SCRUBBERS - BATCH
PICKLING PROCESSES (English units)
Plant sizes (model plant codes)
GM flow rate, acfm
Dimensions (HxD), ft
Packing depth, ft
Overall pressure drop, inch w.c.
Scrubbing water recirculation rate, gpm
Small (BS)
10,000
19.1 x 5.9
7.4
6.2
122
Medium (BM)
40,000
25.1x11.7
7.4
6.2
489
Large (BL)
two 25,000
22.6 x 9.3
7.4
6.2
305
4O.OOO
25.1 x 11.7
7.4
6.2
489
Note:
1. Uncontrolled HCI cone. = 30 ppmv
2. Design control efficiency = 96.7 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
7. An 8-inch mesh pad demister is required above the packing
8. Only one ID fan is required
5-32
-------
pickling facilities are for cleaning non-wire products such as
metal parts. Newer batch pickling units may use a spray rinse
as opposed to a dip rinse to conserve rinse water and minimize
rinse effluent treatment and disposal. The emission potential
of batch operations for surface cleaning or etching at ambient
temperature is lower than that for oxide or scale removal at
an elevated temperature. If acid fume is a concern to the
work place, the fume is usually exhausted to the atmosphere
through a capture device.
5.1.7 Model Plants for Acid Regeneration Processes
5.1.7.1 nistributinr. of Plant Sizes. There are 10 known
operating acid regeneration plants. One additional iron oxide
production plant that uses acid feed similar to spent pickling
acid and operates in similar fashion to spent acid
regeneration plants is not considered here. The annual
capacities of the acid regeneration plants range from
3.2 million gpy to 39.8 million gpy for a single facility.
One facility has three identical processes, one facility has
two identical processes, and the other eight facilities each
have one process. Two of the 10 plants are commercial acid
regeneration plants; the remaining 8 plants are each
collocated with a continuous or.push-pull coil pickling
facility.
The plant size frequency distribution is shown in
Figure 5-6. Plants with less than 8 million gpy processing
capacity are considered small, plants from 8 million gpy to 25
million gpy are considered medium, and plants above 5 million
gpy are considered large. Three model plant sizes are
specified for this type of process. Their capacities for
small, medium, and large plants respectively are 4 million
gpy, 13.5 million gpy, and 30 million gpy. The small and
medium model plants have one acid regeneration process while
the large model plant has two processes.
5.1.7.2 Description of Process Parameters. The spray
roasting process is the predominant process for acid
5-33
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regeneration; only one facility, which was built in 1974, uses
a fluidized bed roasting process. However, one other facility
is replacing its spray roasting process with a fluid bed unit.
The spray roasting and fluidized bed processes are similar xn
chemical reaction principles. Although there are minor
differences in roaster designs, operating temperature, energy
consumption rate, and the quality of iron oxide produced in
these two process, the emission characteristics and potentzal
are the same. One of the fluidized bed acid regeneration
plants is considering rehabilitation or replacement by a spray
roasting process; therefore, the model plants focus on the
spray roasting process only.
Acid regeneration is a complex process that involves
spent liquor characteristics, spraying conditions, droplet
sizes, roaster temperature, roaster pressure, and HC1 absorber
efficiency. Spray roasters usually are operated under a
slightly negative pressure (- 1 inch of water column [in
w o ]) to prevent acid fumes from escaping the process unit.
The roaster temperature is about 1,800 °F. Typical operating
hours and spent liquor characteristics are shown in Table
5-12.
5173 missions and Controls. Gas leaving the HC1
absorber contains some residual HCl and C12. The absorber tail
gas is the most significant source of emissions in the acid
regeneration plant. The other sources are fugitives from acid
storage tanks. Chlorine is a nondesirable byproduct formed in
the roaster when there is too much excess air, too much FeCl2
in the spent liquor, and when nonhomogeneous droplets are
formed during spraying. Chlorine formation can be minimized
by controlling these factors. Hydrochloric acid in the tail
gas is related to the HCl removal efficiency in the absorber.
Any HCl that is not removed by the absorber will become a
burden on the emission control system. Of the 10 acid
regeneration plants, 1 does not have any controls after the
5-35
-------
TABLE 5-12. MODEL PLANT PARAMETERS - SPRAY ROASTING
ACID REGENERATION PROCESSES (English units)
Parameters
A. Total processing rate, million gpy
No. of process lines
Processing rate per line, million gpy
Capacity utilization rate, percent
Model plant remaining lifetime (existing/new), yr
B. Annual operating hours
C. Characteristics of acid streams1
D. Properties of uncontrolled gas stream2
E. Emission control system design criteria
No. of scrubbers for the model plant
Gas flow rate for each scrubber, acfm
F. Uncontrolled emissions (HCI/CI2), Ib/hour3
G. Number of facilities represented by the model plant
H. Ratio of controlled to total process lines within the model
plant size range (percent controlled)
1. Average control efficiency for existing controlled sources,
percent
Plant size (model plant code)
Small (ARS)
4
1
4
85
15/20
8,200
1
4,000
(7/1)
3
2/3 (67%)
98 for HCI
7O for CI2
Medium (ARM)
13.5
1
13.5
85
14/20
7,700
1
1 5,000
(28/3)
5
4/4(100%)
98 for HCI
50 for CI2
30
2
10x1
20x1
85
19/20
8,760
2
1 2,000x1
20,000x1
(1,064/2)
2
5/5 (100%)
98.5 for HCI
70 for CI2
Note:
(1) Typical spent acid contains 3 percent HCI and 22 percent ferrous chloride, the roaster operates at 1,800 °F.
(2) Average HCI and CI2 concentrations in the uncontrolled gas stream are 400 ppmv and 10 ppmv, respectively, for
small plants, 400 ppmv and 20 ppmv, respectively, for medium plants, and 7,2OO and 10 ppmv, respectively, for
large plants; the temperature of the uncontrolled gas stream is 190 °F, and the moisture content is 50 percent,
(3) Uncontrolled emission rates are determined from HCI and CI2 concentrations in the gas stream and the given flow rates.
5-36
-------
HC1 absorber, 7 have a single packed tower scrubber for
control, 1 has a packed tower scrubber using plain water that
is followed by a second packed tower scrubber using caustic
solution, and 1 is equipped with a venturi scrubber using
caustic solution to scrub particulate matter and HC1. Table
5-13 shows the specifications for packed tower scrubbers that
correspond to the gas flow rates and uncontrolled HC1/C12
concentrations shown in Table 5-12. Metal oxide emissions
from storage bins are usually controlled by baghouses as
particulate matter and they are not considered as HAPs. Acid
storage tank emissions have not been controlled in older
plants, but the emissions are routed to a separate emission
control device in newer plants. Packed tower scrubbers are
used for acid tank emission controls.
5.1.7.4 New Acid peaeneration Plants. The spray
roasting process seems to be the predominant commercialized
process for regenerating large volumes of spent acid. The
spray roasting process can be considered as an acid
regeneration process or as a metal oxide production process.
According to a spray roasting process engineering firm, the
current market for the metal oxide generated from the existing
operations is saturated. Future developments will improve the
quality of the metal oxide by removing impurities from the
spent liquor feed. The future market for purer metal oxides
is expected to be more diverse and less competitive than at
the present time. New acid regeneration plant construction is
affected by the availability of spent acid disposal practices.
Deep-well injection is being used by several large pickling
facilities in Indiana, Ohio, and Pennsylvania to dispose of
their spent liquor. As their deep-well injection permits
expire in the next few years, other alternatives will be
sought to manage their spent acid. Spray roasting is a
matured technology readily available. Regional acid
regeneration plants probably can be built to handle spent
5-37
-------
TABLE 5-13. SPECIFICATIONS FOR PACKED TOWER SCRUBBERS - SPRAY
ROASTING ACID REGENERATION PROCESSES (English units)
Plant sizes (model plant codes)
GM flow rate, •cfm
Dimensions (HxD), ft
Packing depth, ft
Overall pressure drop, inch w.c.
Scrubbing water recirculation
rate, gpm
Small (ARS)
4,000
17.8x3.7
8.0
6.7
49
Medium (ARM)
1 5.0OO
21.3x7.2
8.0
6.7
183
Large (ARL)
12,000
20.6 x6.4
8.0
6.7
147
20.OOO
22.5x8.3
8.0
6.7
246
Note:
1. Uncontrolled HCI and CI2 cone. = 400 ppmv and 10 ppmv, respectively, for small plants, 400 ppmv and 20 ppmv,
respectively, for medium plants, and 7,200 ppmv and 10 ppmv, respectively, for large plants
2. Design control efficiency = 97.5 percent
3. Material of construction for the scrubber is fiber-reinforced plastic (FRP)
4. Type of packing is 2" Raschig rings
5. Type of make-up water is clean process water without HCI
6. Make-up water flow rate is 5 percent of the recirculation rate
7. An 8-inch mesh pad demister is required above the packing
8. Only one ID fan is required
5-38
-------
liquor generated from facilities in the same geographic area
The large model represents new regional facilities to be built
in the future.
5 1.8 Morfgl Uni+« for Storage Tanks.
5 i 8.1 T^+r-ibutior »* T™V« ^ Size. Review of
reported tank sizes for fresh acid shows a range from If300 to
40,000 gal. However, there is little correlation between tank
size and facility production capacity. The average tank size
is 14,300 gal and the median size is 13,000 gal. Most
facilities have one or two tanks for fresh acid.
Reported tank sizes for spent acid range from 1,000 gal
to 175 000 gal with an average size of 19,500 gal and a median
size of 12,000 gal. As with fresh acid storage, there IB
little correlation between tank size and facility production
capacity. Most facilities have one or two spent acid storage
tanks. .
Model tank sizes are chosen as 13,000 gal for fresh add
and 12,000 gal for spent acid. Each model facility is assumed
to have two fresh acid tanks and two spent acid tanks for a
total capacity of 50,000 gal.
5 1.8.2 FT'—J— ™* controls. No facilities reported
measured emissions from tanks. Three reported estimates for
uncontrolled tanks were 0.065 tpy of HCl for an 8,000-gal
tank, 0.13 tpy combined for a 5,000-gal tank and a 400-gal
tank, and 0.37 tpy combined for a 25,000-gal tank and a
40 000-gal tank. The average of these values is equivalent to
0 0126 tpy/1,000 gal of storage capacity. Two reported
estimates for controlled tanks were 0.03 tpy combined for two,
1 000-gal tanks and 0.06 tpy combined for a 12,500-gal tank
and a 10,000-gal tank. The average of these values is
equivalent to 0.008 tpy/1,000 gal of storage capacity. Fewer
than half of the facilities reported having emission controls
on the tanks. Where controlled, most of the tank emissions
were vented to the pickling line scrubber. Other control
methods included bubbling emissions from tank vents through
5-39
-------
water or caustic solution. About a third of the plants with
controls used a scrubber dedicated to the storage tanks. For
model facilities, each set of tanks is assumed to require
piping to a control device (scrubber) associated with the
pickling operations. Emissions from storage tanks are based
on tank losses of 0.39 tpy of HC1 for each million tons of
steel processed at continuous coil or push-pull coil model
facilities. Tank emissions for the remaining pickling models
are based on 11.19 tpy of HC1 for each million tons of steel
processed. These values are averages from the five facilities
reporting emissions.
5.2 BASELINE CONDITIONS
Because only a few states have air pollution regulations
specific to HC1 emissions, the baseline conditions in this
source category are not based on existing state regulations.
Rather, the baseline conditions are based on information about
the level of control currently achieved at existing facilities
as reported in the 1992 industry survey. Table 5-14 shows the
baseline conditions for controls at facilities represented by
the model plants for each of the process type. However,
examination of the pickling and acid regeneration facility
population showed that about two-thirds .would require new or
upgraded scrubbers to meet an emission level of 10 ppmv (or an
efficiency of 97.5 percent). The characteristics of these
facilities were examined for significant differences from the
overall population. Table 5-15 lists the results of the
examination as revised parameters for estimating impacts based
on scrubber sizes.
5.2.1 Capture Devices
Each process line in continuous coil pickling, push-pull
coil pickling, and acid regeneration is equipped with a
capture device. These capture devices protect the building
and equipment from acid corrosion while complying with
5-40
-------
Process type/Model plant
lines or
units with
existing
capture
devices
1. Continuous coil
pickling
Small
•^•^•v
Medium
Large
.^——
2. Push-pull coil pickling
•^^•^K*
Small
«—^—
Medium
^•^•^^
Large
3. Continuous rod/wire
pickling
4. Continuous tube
pickling
Small
•——••
Large
_^—^^"-
5. Batch pickling
Small
^—^—
Medium
Large
6. Acid regeneration
_•••«•
Small
Number of j Number of Percent of
process lines I process lines
or units with
existing
controls
15
17
•^MKH
28
^•^^K
12
4
15
0
5
1
7
1
5
2
•^•M
5
5
or units with
existing
controls
I Associated
level of
control for
controlled
sources,
percent HCI
reduction
83
94
MM«
100
•^—^—
100
«^—^—
100
100
•™^^™«
24
•HIHHB
52
0
100
17
18
10
56
67
«^™^—i
100
^^^^>^«
1OO
Overall
reduction in
Emissions.
percent HCI
93
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92
92
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98
98
95
98
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70 for CI2 I 70 for CI2
5-41
-------
5-42
-------
Occupational Safety and Health Administration (OSHA)
regulations that limit the HCl inside the plant to a threshold
concentration of 5 ppmv. Some of the continuous rod/wire
pickling, continuous tube pickling, and batch pickling
processes are equipped with capture devices to comply with
OSHA regulations. Some facilities do not have capture
systems, probably because the acid concentration in the
working environment does not exceeded the OSHA regulations.
Not all facilities that have capture systems also have control
systems. Twenty-five percent of process lines capture
emissions and vent them directly to the atmosphere. Tins
situation means that these lines, if required to control t*exr
emissions, will need only a control device and transition from
existing ductwork rather than having to install a complete
capture and control system.
5 2.2 Baseline Control Techniques
' information on the types of control techniques currently
applied in steel pickling operations and acid regeneration
process were derived from responses to the 1992 industry
survey. Common control techniques applied by steel pickling
operations are packed tower scrubbers (plain water or caustic
solution scrubbing), sieve tray scrubbers, horizontal packed
bed scrubbers, fume washers, and demisters. Common control
techniques applied by acid regeneration processes are packed
tower scrubbers with plain water or caustic solution
scrubbing. There is only one venturi scrubber, with caustic
solution scrubbing, used in the acid regeneration process.
Although there are many types of scrubbers, they can be
designed to achieve the same degree of gas collection
efficiency.
5.2.3 Baseline Level of Control
Baseline control levels were determined from the
distribution of control techniques currently applied in steel
pickling operations and acid regeneration processes. The
level of control is determined from information provided by
5-43
-------
the facilities for their existing control devices in the 1992
industry survey. The level of control for a process type is
the average of reported control efficiencies. The reported
control efficiencies are based on test results or on design
values provided by equipment vendors. The current overall
reduction in emissions for each type of size of pickling or
acid regeneration facility is shown in the last column of
Table 5-14.
5.3 CONTROL OPTIONS FOR HC1
Scrubbers are the only controls used on pickling lines.
Because HC1 is highly soluble in water and can be scrubbed
with high efficiency, it is not likely that other more cost-
effective methods of control will be found. Two options are
available in addition to control at the MACT floor. These
options are:
1. Use of caustic scrubbing medium to improve control
efficiency.
2. Requirement for a control effectiveness higher than
the MACT floor.
Each of these options is discussed below.
5.3.1 Use of Caustic Scrubbing Medium
Addition of caustic (commonly sodium hydroxide, NaOH) to
the scrubbing medium acts to convert absorbed HC1 to sodium
chloride (NaCl) and water. By removing HC1 almost as quickly
as it enters the scrubbing medium, the vapor pressure of HC1
over the medium is reduced nearly to zero. This factor
theoretically allows the concentration of HC1 in the outlet
gas from the scrubber to reach a lower concentration than
without the caustic. In practice, however, benefits from
using caustic scrubbing medium appear to be negated for two
5-44
-------
reasons as discussed below. These reasons suggest that
caustic scrubbing media should not be required.
5.3.1.1 Comparison of Caustic and Water Scrubbing Media.
One facility, an acid regeneration plant, uses caustic
scrubbing media in two scrubbers on two processes. As shown
in Table 5-16, facilities with water as the scrubbing medium
can achieve equivalent efficiencies and outlet concentrations
when compared with the facility using a caustic scrubbing
medium.
5.3.1.2 Interference with Pollution Prevention
Practices. Many facility operators have learned that they can
prevent pollution and reduce wastewater treatment costs by
returning scrubber effluent to the pickling line tanks. This
practice reduces both water consumption and the quantity of
effluent sent to the wastewater treatment plant. Addition of
caustic to the scrubber water interferes with pollution
prevention practices by preventing reuse of the scrubbing
medium in the pickling tanks. Caustic scrubbing media also
increase the burden on the wastewater treatment plant.
TABLE 5-16. COMPARISON OF WATER AND CAUSTIC SCRUBBING MEDIA
Facility ID No.
131, process 1
131, process 2
114
132
105
5.3.2 Increased
Reported HCI control Reported outlet HCI
efficiency, % (by EPA concentration, ppmv
Method 26A or CARB (by EPA Method 26A Scrubbing
421) or CARB 421) medium
83 3.1
95 0.94
1
99.49 1.6
99.96 2.0
Control Effectiveness
caustic
caustic
water
water
water
At the MACT floor, a scrubber will emit HCI at a
concentration of about 10 ppmv or an efficiency of about 97.5
5-45
-------
percent. The best controlled facility in terms of outlet HCl
concentration as measured by EPA Method 26A emits at reported
values of about 1.6 ppmv and 99.49 percent efficiency.
However, considerations of practical test method application
suggest that reported values below about 3 ppmv may not be
reliable.2 The equivalent efficiency for this facility at 3
ppmv is 99.04 percent. If all scrubber systems were required
to meet a 3 ppmv emission limit, nationwide reductions of HCl
are estimated at 9,070 Mg/yr. This value, which assumes that
all existing scrubbers emit at the apparent limit for new
facilities, is 710 Mg/yr greater than the estimated reduction
of 8,360 Mg/yr at the MACT floor level (see Chapter 6, Table
6-1). An intermediate value between 8,500 Mg/yr and 9,000
Mg/yr that would result from an emission limit more stringent
than the MACT floor and less stringent than the requirements
for new facilities would reduce emissions by only a few
hundred Mg/yr. A review of Chapters 3 and 7 of this document
suggests that the burden for this modest reduction would fall
largely on smaller facilities. Additionally, the number of
facilities having scrubbers that would have to be completely
replaced, as compared with making improvements to existing
scrubbers, would increase from about 23 to about 55.
5.3.3 Rationale for Limiting Control Options to the
MACT Floor
Each of the two potential control options presented above
that go beyond the MACT floor have characteristics that
suggest they not be considered further. Caustic scrubbing, in
practice, appears not to provide more efficient control than
water scrubbing; and higher efficiency requirements appear to
provide a small reduction in emissions beyond the floor that
would impact smaller facilities. For these reasons, further
costs and impacts are not estimated in Chapters 6 and 7. The
MACT floor is retained as the only option for further
consideration.
5-46
-------
5.4 CONTROL OPTIONS FOR C12
A reduction of C12 in the acid regneration plant scrubber
offgas to below 4 ppmv through the use of process control
alone has been demonstrated. By contrast, C12 reductions
through scrubbing with alkaline media have not been
quantified. It therefore appears that process control may be
the most reliable means to achieve reductions of C12 emissions.
A T
-------
5.5 REFERENCES
OAQPS Control Cost Manual, Chapter 9, Gas Absorbers.
Fourth Edition. U.S. Environmental Protection Agency,
Office of Air Quality Planning and Standards. Research
Triangle Park, NC. Publication No. EPA 450/3-90-006b.
Laboratory and Field Evaluation of a Methodology for
Determination of Hydrogen Chloride Emissions from
Municipal and Hazardous Waste Incinerators. U.S. EPA,
Atmospheric Research and Exposure Assessment
Laboratory, Office of Research and Development. RTF,
NC. Publication No. EPA 600/3-89-064.
5-48
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6.0 ENVIRONMENTAL IMPACTS
6.1 SUMMARY
Table 6-1 summarizes HC1 impacts for continuous and
batch pickling and for acid regeneration. Table 6-2 expands
the information in Table 6-1 to each of 17 model plants used
to estimate impacts. These impacts are based on estimated
total uncontrolled HCl emissions of about 38,600 Mg/yr.
Under current controls, baseline emissions are estimated to
be about 9,330 Mg/yr. Application of MACT controls reduces
estimated nationwide emissions to about 970 Mg/yr for a
reduction above baseline (rounded) of 8,360 Mg/yr.
Changes in acid regeneration plant operating parameters
would reduce emissions of C12 from approximately 35 Mg/yr to
an estimated 16 Mg/yr.
Nationwide capital costs for new and upgraded scrubbers
are estimated to be about $20.0 million. Annual costs are
estimated to be about $7.1 million.
Additional annual energy, solids disposal, and
wastewater treatment requirements above current usage are
estimated to be 10.2 million kWh, 1,680 Mg, and 457,000 m3,
respectively.
Appendix C provides the methodology for deriving each
of the impacts. Descriptions are given below for each
element of the estimates.
6-1
-------
6.2 NATIONWIDE EMISSIONS FOR PICKLING LINES, ACID
REGENERATION PLANTS, AND ACID STORAGE TANKS
Tables 6-1, 6-2, and 6-3 give emissions, cost, and
other impacts information for standards based on 10 ppmv of
HC1 emitted from scrubbers on pickling lines and 8 ppmv of
HC1 emitted from acid regeneration plants or, alternatively,
scrubbers operating at a collection efficiency not lower
than 97.5 percent. This information is based on the series
of 17 model plants described in Chapter 5 of this document.
The nationwide distribution of plants by model type is
included in Table 6-2. Table 6-3 shows estimated energy,
solid waste, and wastewater impacts for each model. The
data used to formulate the models were obtained primarily in
1992 and 1993.
Uncontrolled emissions were estimated by multiplying
the number of plants times uncontrolled emission rate
(Ib/hr) times annual operating hours. The uncontrolled
emission rate was estimated by choosing an uncontrolled
emission concentration (based on ranges of concentrations
reported in information collection requests [ICRs]) times
the gas flow assigned to the model plant.
Baseline emissions were estimated based on uncontrolled
emissions times the fraction of pickling lines controlled
and the control efficiencies of the scrubbers serving the
lines. Total uncontrolled emissions were added for plants
without controls. Baseline emissions include 24 Mg/yr from
storage tanks. Data for the number of lines controlled were
obtained from the ICRs; scrubber efficiencies were estimated
from test.data and reported design values.
Emissions after application of MACT were estimated
similarly to uncontrolled emissions except that all plants
were assumed to have scrubbers with outlet concentrations at
the MACT floor value of 10 ppmv or at a value consistent
with a scrubber collection efficiency of 97.5 percent.
6-4
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Estimated tank emissions were reduced to about 2 Mg/yr
nationwide.
6.3 NATIONWIDE COST OF CONTROL AT A MACT FLOOR OF 10
ppmv/97.5 PERCENT
Tables 6-1 and 6-2 provide nationwide capital and
annual costs for reducing emissions. These costs were
estimated using assumptions about purchasing new scrubbers,
upgrading existing scrubbers, and providing increased
maintenance for existing scrubbers. Costs were estimated on
a 1993 basis and escalated to 1996.
Capital costs were estimated based on a mixture of new
scrubbers for uncontrolled pickling lines, and upgraded
scrubbers and increased maintenance applied to existing
controls. New scrubbers were applied to the fraction of
pickling lines not currently controlled. The unit costs for
these scrubbers were taken from information presented in
Chapter 7, but revised to reflect the characteristics of
only the facilities expected to require new or upgraded
scrubbers. Capital costs for upgraded scrubbers were
estimated as being 40 percent of the cost for a new
scrubber. Upgrades were applied to existing scrubbers not
estimated to be capable of meeting the MACT floor without
improvements. Capital costs were also estimated for
installation of vent piping from storage tanks to the
pickling line scrubber. These costs were estimated at
$3I/ft for 200 ft of 4-in. fiberglass reinforced plastic
pipe.1
Annual costs above those currently incurred were also
estimated from information in Chapter 7. Pickling lines not
currently controlled were assigned annual costs directly
from each model plant described in Table 5-15. Annual costs
for pickling lines currently controlled were estimated as
being 40 percent of the cost for a new scrubber.
6-6
-------
6.4 ENERGY, SOLID WASTE, AND WASTEWATER IMPACTS
Additional energy use due to new and upgraded scrubbers
was estimated by summing the power requirements to overcome
the pressure drops for all of the new scrubbers and adding
an estimated 20 percent of the power used to overcome the
total pressure drop for upgraded scrubbers. Additional
solids disposal was estimated by taking scrubber solids as
0.62 percent of the scrubber flow. This quantity was
obtained from the ICRs. Examination of the 10 highest
efficiency scrubbers showed an average effluent to gas ratio
of 1.44 gal/acf. This value was used with the scrubber gas
flow rate to obtain the liquid flow rate used for estimating
solids content for new scrubbers. The solids for upgraded
scrubbers were estimated in the same manner but only 20
percent of the total scrubber solids were attributed to the
upgrade. Wastewater flow rates for new and upgraded
scrubbers were also estimated using 1.44 gal/acf.
6.5 NON-AIR HEALTH IMPACTS
Nonair health impacts also are associated with HC1
emissions. Ingestion of HCl may cause corrosion of the
mucous membranes, esophagus and stomach, nausea, intense
thirst, diarrhea, or death. Dermal exposure to concentrated
solutions can cause severe and disfiguring burns and
permanent visual damage; occupational exposures have led to
dermatitis, photosensitization, gastritis, and chronic
bronchitis. Digestive diseases are frequent and are
characterized by dental molecular necrosis in which the
teeth lose shine, turn yellow, become soft, pointed, and
then break off.2 Although HCl is not itself flammable, its
reaction with steel in the presence of moisture produces
hydrogen gas. This co-product can present both a fire and
explosive hazard.3
6-7
-------
Chlorine is a very reactive element and combines easily
with a variety of organic compounds. These chemical
reactions constitute the primary mechanism for destruction
of ozone in the stratosphere.4 Dermal exposure to C12
irritates the skin, causing sensations of burning or
prickling, inflammation, or blister formation.
Conjunctivitis, keratitis, pharyngitis are common. The
corrosive effect can cause complete destruction of the skin
or mucous membrane. Chlorine is a poison if digested.5
HC1 and C12 also are phytotoxicants . Tomatoes, sugar
beets, and certain fruit trees and flowers are known to be
sensitive to HC1; a concentration of 350 mg/L has been found
to be injurious to crops. Some of the most Cl2-sensitive
crops and plants include alfalfa and tobacco; blackberries
and radishes; box elder, crab apple, pin oak, sugar maple,
and sweet gum trees; and roses, sunflowers, and zinnias.6
HC1 is highly soluble in water and is known to inhibit
plant growth at a level of about 6 mg/L. The acute and
chronic ambient water quality criteria for chloride are 8.6
x 105 /tg/L (1-hr average) and 2.3 x 10s /*g/L (4-day average),
with the notation that excursions above the acute criterion
may affect a substantial number of species because
freshwater animals are quite susceptible to 'chloride.7 The
acute and chronic ambient water criteria for C12 in
freshwater and marine waters are 19 and 11 M9/L and 13 and
7.5 M9/L, respectively (50 FR 30788). HC1 and C12, when
dissolved in water, also are among the most corrosive
chemicals and can cause damage to building materials such as
limestone, plant equipment, and to all types of metals and
textiles.
6.6 SMALL BUSINESS IMPACTS
Steel pickling companies are considered to be small
businesses if they employ fewer than 100 people. Review of
6-8
-------
Table 3-5 shows that four facilites fit this criterion
(facility numbers 51, 125, 134, and 136). Of the four,
facility 136 is an acid regeneration plant that is well
controlled and emits chlorine at a level below the MACT
floor. Of the remaining facilites, two are expected not to
be major sources based on emissions estimates from the Esco
Engineering model described in Appendix E. The remaining
facility employs a scrubber that is expected to require
either routine maintenance or a minimal upgrade to meet an
efficiency level of 97.5 percent.
6-9
-------
6.7 REFERENCES
1.
2.
Means Building Construction Cost Data 1993, 51st Annual
Edition. R. S. Means Co., Kingston, MA. 1993
Hydrochloric Acid. Hazardous Substance Data Bank.
National Library of Medicine. National Institute of
Health. Printouts dated August 31, 1992 and November
12, 1993. See also: Hydrogen chloride. Integrated
Risk Information System. U.S. Environmental Protection
Agency. Printout dated July 10, 1995.
3.
4.
5.
Chlorine and Hydrogen Chloride.
Sciences. Washington, DC. 1976,
Ref. 3, pp. 85-86, 93.
National Academy of
pp. 163-72, 198.
6,
7,
Chlorine. Hazardous Substance Data Bank. National
Library of Medicine. National Institute of Health.
Printout Dated August 1, 1993. See also: Chlorine.
Integrated Risk Information System. U.S. Environmental
Protection Agency. Printout dated September 1, 1995.
Ref. 3, pp. 145-53, 161.
Hydrogen Chloride. Integrated Risk Information System.
U.S. Environmental Protection Agency. Printout dated
July 10, 1995.
6-10
-------
7.0 COSTS
Table 7-1 is a summary of the estimated average costs
for applying scrubbers to 14 of the model pickling
facilities that are similar to those described in Chapter 5.
These models represent the estimated 66 facilities requiring
new or upgraded scrubbers. The costs are estimated using a
spreadsheet program version of the OAQPS Control Cost
Manual,1 Chapter 9, for scrubbers. All costing is done for
packed bed scrubbers. Sieve tray scrubbers are also used in
the industry, but tend to have higher capital costs than
packed bed scrubbers. However, sieve tray scrubbers use
significantly less water and can have lower annual costs
than packed bed scrubbers depending on the costs of water
and of wastewater treatment. The scrubbers are assumed to
be 97.5 percent efficient on inlet concentrations greater
than 320 ppmv of hydrochloric acid (HC1) and of sufficient
efficiency to provide a 10 ppmv outlet concentration for
inlet concentrations below 320 ppmv. Only the batch plant
models meet the latter condition. Costs have not been
rounded. Example cost sheets are presented in Appendix D.
Costs are presented for HC1 control and monitoring
only. Costs for C12 control are projected to be negligible
because no new controls on operations are required. Testing
C12 emissions would be done simultaneously with HC1 using
the same samples collected by Method 26A.
7.1 CAPITAL AND ANNUAL COST RANGES
Total capital investment, in 1996 dollars per facility,
ranges from about 5 to 31 $/acfm, with larger units having
7-1
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•the lower cost. Total annual costs range from about
$0.05/ton of production for large plants to about $8.50/ton
for plants with low production rates.
To determine sensitivity of costs to changes in inlet
concentration and required efficiency, one model
(small continuous coil with a scrubber flow rate of 7,500
acfm) was run at several values from 97 to 99.5 percent
efficiency and at outlet concentrations from 30 to 5 ppmv.
Inlet concentrations were specified as 1,000 ppmv, 500 ppmv,
or 250 ppmv. Table 7-2 shows the conditions and costs for
each case. Both capital and annual costs increase as
required efficiency increases. At higher efficiencies, cost
increases accelerate. At an inlet concentration of 1,000
ppmv, the change in estimated annual cost to reduce outlet
concentration to 8 ppmv (99.2 percent efficiency) instead of
10 ppmv (99.0 percent efficiency) is about 1.4 percent. To
further reduce the outlet concentration to 5 ppmv (99.5
percent efficiency) increases the annual cost by 4.5 percent
over the original annual cost. Capital cost increases are
2.4 percent and 7.4 percent, respectively, for these two
cases.
7.2 RATIONALE FOR SIZING THE MODEL EMISSION CONTROL SYSTEMS
Sizing emission control systems for the model plants is
based on engineering judgement coupled with several types of
information: (1) the distribution of facility capacities,
(2) the distribution of process line capacities, (3) the
distribution of emission control systems based on gas flow
rates, and (4) the actual listing of process line capacities
and their associated scrubber sizes. While existing
scrubber sizes are a function of pickling tank size, hood
arrangements, and bath temperature and concentration, model
plant sizes are determined by reviewing the actual plant
size distributions and choosing the appropriate grouping of
facilities for the size range. This procedure ensures that
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model scrubber sizes (as measured by gas flow rates) are
consistent with existing scrubbers. The process line sizes
for a model plant are selected to represent the common
process line combinations in a typical plant. Using the
scrubber size distribution, the lower and upper limits ofthe
scrubber sizes for the particular type of pickling
operations are identified. The corresponding scrubber sizes
and the associated number of lines for the same scrubber
aredetermined by comparing the model process line capacities
with the actual listing of process line sizes and their
associated scrubber sizes.
This process was carried out using the information
available from Information Collection Requests (ICRs)
available for 101 facilities. Model plants are discussed in
Chapter 5.
7.3 MONITORING OPTIONS
Monitoring options are presented for continuous
pickling, batch pickling, acid regeneration, and storage
tanks. In each case, the pollutant to be monitored is HC1
and the control system to be monitored is a scrubber. The
options are based on review of a range of existing
capabilities from continuous monitoring of HC1 through
continuous monitoring of a surrogate compound, continuous
monitoring of control device parameters, continuous
monitoring of process parameters, and periodic testing of
control device emissions. Table 7-3 provides an overview of
the monitoring methods that can reasonably be applied
technically. The table shows that for steel pickling, the
options selected for review include continuous monitoring of
HC1, continuous monitoring of control device parameters, and
periodic testing. The remaining options do not lend
themselves to reliable monitoring of HC1 emissions. For
example, monitoring process variables is not expected to
provide accurate emission results because of the poor
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correlation between production rate and emission rate.
Monitoring of surrogate compounds is not feasible
because no surrogate compound usable for monitoring
exists in the scrubber offgas. Table 7-4 provides
options for eachpickling process, acid regeneration,
and storage tanks. The options are described
individually below. Option I requires the use of a
continuous HC1 monitor (and C12 monitor for acid
regeneration) for each stack and an annual compliance
test by Method 26A. The monitors are self-calibrating
and records HC1 and C12 concentration (for gas and
liquid phases) in ppmv. However, these monitors have
not been demonstrated for steel pickling operations;
hence the requirement for compliance tests. Option II
requires that each scrubber have continuous monitoring
of pressure drop across the body of the scrubber and
acidity of the scrubber effluent. Option II also
requires annual testing at the outlet of each stack by
Method 26A. Option III requires the use of a
continuous HC1 monitor (or C12 monitor for acid
regeneration) for each scrubber outlet at facilities
capable of pickling more than 500,000 tons per year of
steel, or of regenerating more than 10 million gallons
per year of spent acid. All other facilities are
required to monitor continuously the pressure drop and
acidity for each scrubber as described above in
Option II. An annual compliance test is required for
all stacks.
Record keeping and reporting of monitoring data
are as required in the general provisions for
compliance with MACT standards at the time the EMTIC
program (described below) was written.
7-9
-------
7.4 COSTS OF MONITORING OPTIONS
Costs for each of the monitoring options are shown
in Tables 7-5 through 7-7. Table 7-5 summarizes the
estimated costs for each type of pickling and for acid
regeneration. Table 7-6 gives estimated costs for
individual model plants, while Table 7-7 gives costs on
a nationwide basis. Costs for continuous monitoring of
HC1 are based on procedures and software (EMTIC CEM
COST MODEL, version 2.0 and its associated users
manual2) developed by EPA that include estimates for
planning and selection of equipment, support
facilities, purchase price for the monitor and
peripherals, installation, performance test, and
quality assurance/ quality control plans and
procedures. Recurring costs include operation and
maintenance, annual and supplemental relative accuracy
test audits (RATAs), quarterly reports, recordkeeping
and reporting and annual review and update as required
when the EMTIC program was written. Costs are
escalated to 1996.
Costs of equipment and operation for continuous
monitoring of scrubber parameters include all of the
elements for HC1 monitors, but equipment purchase,
installation, and maintenance costs are lower than
those of the continuous emission monitors because of
the simpler equipment being used. Many plants now have
the required equipment. For costing, one-half the
plants are assumed to monitor pressure drop and all
plants are assumed to monitor process acidity. This
latter capability can also be used to measure scrubber
outlet acidity.
7-10
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Costs for annual testing by Method 26A are based on
costs collected by EPA in its test programs. Costs assume
the use of a test contractor and include time for
participation by plant personnel. Only the scrubber outlet
is tested. Costs would increase if efficiency were
measured, which requires simultaneous inlet,and outlet
testing.
The three tables include capital and annual costs for a
typical model plant and estimates of nationwide costs based
on the distribution and sizes of existing plants. The
estimated nationwide capital and annual costs for Option I
are $18.1 million and $9.2 million, respectively. Estimated
nationwide costs for Option II are $0.45 million and $1.52
million, respectively; and for Option III are $8.6 million
and $3.5 million, respectively.
Option II (scrubber monitoring and annual testing)
appears to be the lowest-cost option because low capital
expenditures are required. Options I and III (which use
continuous monitoring equipment) are higher than Option II
because they require higher capital expenditures and
equipment maintenance in addition to annual compliance
testing.
7-14
-------
7.5 REFERENCES
U S Environmental Protection Agency. OAQPS Control
Cost Manual, Chapter 9, Gas Absorbers. Fourth Edition.
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. Publication No. EPA 450/3-90-006b.
October 1992.
Walch, G., T. Brozell, and J. Miller. Program Users^
Manual for Estimates of CEMS and Annual 0 & M Costs for
new and existing Combustion Facilities. Office of Air
Quality Planning and Standards, Research Triangle Park,
NC. Contract No. 68D90055WA49, March 21, 1991.
7-15
-------
-------
8.0 ECONOMIC IMPACTS ANALYSIS FOR THE
MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY, (MACT)
STANDARD FOR THE STEEL PICKLING INDUSTRY
The U.S. has approximately 101 steel pickling
facilities operating currently.1 Many, but not all, are
integrated into iron and steel manufacturing plants. In an
ancillary process, spent HCl pickle liquor, which contains
iron chloride plus residual HCl solution is converted by a
spray oxidation process into a marketable iron oxide product
plus HCl solution that can be recycled for the pickling
operation. Ten facilities perform acid regeneration in the
U.S., including two independently operated plants and eight
process lines operating in conjunction with steel pickling
facilities.2 Emissions from about half of the existing
pickling and but one of the regeneration facilities are
currently well controlled.
For 1991, steel pickling facilities reported a capacity
utilization rate of 64.7 percent with total annual
production of 39.8 million tons of steel.3 A large number
of steel products are subjected to acid pickling, including
sheet and strip, bars, rods, wires, and tubes. All of these
products can be classified as steel mill products. The
American Iron and Steel Institute (AISI) estimated 1991 U.S.
shipments of steel mill products at 78.8 million tons.4
Although statistics on the percentage of total steel mill
products processed by pickling operations are not available,
we can infer from the above data that roughly 51 percent of
all steel mill products in 1991 were pickled.
This chapter presents information on the types of steel
produced that may require pickling, industry organization
8-1
-------
including market structure and firm characteristics, and
markets (including production and consumption)• A listing
of facilities and their production capacities is given in
Chapter 3.
8.1 THE SUPPLY SIDE OF THE INDUSTRY
This section describes the types of steel that may be
pickled, then discusses the costs of producing steel.
8.1.1 Types of Steel
All steels are classified as either carbon or alloy
steel. Within the alloy classification, however, variations
in both the chemical composition of the product and the
manner in which it is processed yield steels with special
properties. As a result, steel products can be grouped into
three .grades: carbon steels, alloy steels, and stainless
steels. Table 8-1 provides information on U.S. shipments of
steel mill products by carbon, alloy, and stainless grades
for 1992.
8.1.1.1 Carbon Steels
Carbon steels accounted for more than 93 percent of
total steel mill product shipments in 1992. Carbon steels
are those containing very small amounts of alloying
elements—not more than -1.65 percent manganese, 0.6 percent
silicon, and 0.6 percent copper—with a carbon content of
0.03 percent to 1.7 percent. Low carbon steels, with 0.08
percent to 0.35 percent, are used primarily for flat-rolled
products because of the ease with which they can be formed
and welded. Machines, auto bodies, most structural steel
for buildings, and ship hulls are among the products made
from carbon steels.5
8.1.1.2 Alloy Steels
In 1992, alloy steels accounted for roughly 5 percent
of total steel mill product shipments. Alloy steels are
steels containing specific percentages of vanadium,
molybdenum, or other elements, as well as larger amounts of
8-2
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manganese, silicon, and copper than carbon grades contain.
The major alloy grades are the full alloy series, silicon
electrical sheets and strip, tool, and high-strength, low-
alloy steels. The greater strength, corrosion-resistance,
and special electrical attributes of the alloy steels
contribute to their use in the auto industry, construction,
industrial machinery and equipment, and electrical
equipment.6
8.1.1.3 Stainless Steels
Stainless steels accounted for less than 2 percent of
total steel mill product shipments in 1992. Some 70 to 75
percent of the stainless grades are chromium or nickel
steels, which are highly resistant to rust and corrosion.
In addition, certain of the stainless grades have unusual
strength and resistance to temperature changes, factors that
have led to their growing use in the aerospace industry. In
addition, their corrosion resistance makes them useful for
the petrochemical industry for pipes and tanks and the
medical industry for surgical equipment.7
8.1.2 Costs of Production
The costs of steel production are classified as either
nonavoidable (sunk) or avoidable. The former category
includes costs to which the firm is committed and that must
be paid regardless of any future actions of the firm. The
second category, avoidable costs, describes any costs that
are foregone by ceasing production at the plant. These
costs can be further refined to distinguish between costs
that are independent of the production level (avoidable
fixed) and those that vary with the level of production
(avoidable variable). These three categories of costs are
described below:
• Nonavoidable fixed costs: the costs associated
with the decision to open a manufacturing plant.
• Avoidable fixed costs: the recurring costs
associated with the decision to operate the
manufacturing plant.
8-6
-------
• Avoidable variable costs: the costs associated
with the decision to operate the plant at a given
level of production.
The decision to open a new plant must be evaluated
based on the costs included in all three categories above.
However, for existing facilities, nonavoidable costs are
sunk and do not affect the owner's decision to continue
operating. "Breakeven" is the capacity utilization rate at
which costs are recovered given prices and cost in each
period. Table 8-2 shows the actual and breakeven operating
rates for U.S. major mills from 1981 to 1986. As shown,
breakeven rates varied from roughly 65 to 80 percent from
1984 to 1986, after a period of wide fluctuation from 1981
to 1983.
8.1.2.1 Nonavoidable Fixed Costs
Nonavoidable fixed costs include most, if not all,
capital costs as well as long-term materials contracts and
capacity investments. These expenses are the fixed start-up
costs that are incurred regardless of the level of
production or whether the plant operates at all. For
example, debt incurred to construct a steel manufacturing
plant must be repaid regardless of the plant's production
plan and even if the plant closes prior to full repayment,
unless the range of viable alternatives includes declaring
bankruptcy by the owners.
Hogan reports that the development of the electric arc
furnace reduced the barrier of entry into the steel
industry. In 1987, the integrated mill, with a blast
furnace and basic-oxygen converters, required a large
investment of at least $1 billion for a million-ton plant,
whereas a nonintegrated mill (minimill), with electric arc
furnace, required a capital investment as little as $55
million.8
Heidtman Steel Products Inc., a flat-rolled steel
service center based in Toledo, Ohio, spent $12-million on
8-7
-------
TABLE 8-2. U.S. MAJOR MILL ACTUAL AND "BREAK-EVEN"
OPERATING RATES BY QUARTERS—1981 TO 1986 (PERCENT)
Operating Rates
Year Quarter
1981 Ql
Q2
Q3
Q4
1982 Ql
Q2
Q3
Q4
1983 Ql
Q2
Q3
Q4
1984 Ql
Q2
Q3
Q4
1985 Ql
Q2
Q3
Q4
1986 Ql
Q2
Q3
04
Actual
84
85
75
62
57
47
42
36
52
60
57
59
74
77
58
54
67
70
64
63
72
68
50
72
Breakeven
55
42
34
60
97
115
125
124 ,
103
90
85
75
78
67
64
70
78
67
70
72
80
70
65
77
Note:"Break-even" is the capacity utilizatipn rate at which costs are
recovered given prices and cost in each period.
8-8
-------
building its steel pickling and processing plant in Sparrows
Point, Maryland. The state-of-the-art HCl acid pickling
line has an annual capacity of approximately 360,000 tons of
flat-rolled coil steel resulting in an estimated new
capacity cost of $33.33 per ton of steel processed.9
Assuming a 20-year life of the newly installed pickling line
and an interest rate of 8 percent, the estimated cost is
$3.40 per ton of installed pickling capacity.
8.1.2.2 Avoidable Fixed Costs
Avoidable fixed costs include rent and building
overhead costs, some administrative fees, insurance
payments, property taxes, and depreciation. These expenses
are the recurring fixed costs that are due when the plant is
in operation regardless of the level of production.
Also included in these costs are the capital
expenditures for environmental control purposes. The U.S.
International Trade Commission reports that these capital
expenditures (related mainly to the 1990 Clean Air Act
amendments and water quality standards in the Great Lakes
region) continued to account for a significant portion of
total capital expenditures in 1991 and 1992.10
Environmental capital expenditures by carbon and alloy steel
producers accounted for roughly 14 percent of total capital
expenditures in each year. Furthermore, spending on air
quality control dominated total environmental capital
expenditures, accounting for 63 percent in 1992 and 81
percent in 1991.11
8.1.2.3 Avoidable Variable Costs
Avoidable variable costs, or production costs, are
influenced by a number of factors including plant location,
plant age and level of modernization, production process,
availability of raw materials, and labor. The main variable
inputs used in the pickling of 1 ton of hot-rolled carbon
steel strip (including scale) prior to cold rolling are
electricity, mill water, makeup acid (either sulfuric or
hydrochloric), and labor.
8-9
-------
Table 8-3 provides the production costs of U.S.
producers for hot-rolled products during fiscal year 1990
through 1992.12 For 1992, the total production cost for
pickling and oiling was only 2.4 percent of total production
costs of hot-rolled products. Similarly, the contribution
of pickling and oiling costs to total production costs of
hot-rolled products was 2.6 percent for both 1990 and 1991.
The average cost of pickling and oiling per ton of output is
calculated as $8.11 for 1990, $8.09 for 1991, and $7.27 for
1992.
8.1.2.3.1 Labor. Table 8-4 shows the hourly earnings
and total employment cost per hour for employees in the U.S.
steel industry from 1967 to 1992. Total employment cost per
employee is calculated as the sum of total payroll cost per
hour (earnings, holiday, and vacation pay) and employee
benefits cost per hour. As shown in Table 8-4, total
employment cost has consistently been one and a half times
hourly earnings throughout the past decade. This trend
should continue and the difference become larger as the
health care cost component of employee benefits increases in
the future. Table 8-5 displays average hourly earnings for
production workers in the primary metals industry (SIC 33)
by state for 1990 through 1992. Based on the data in
Table 8-5, no significant disparities in labor costs appear
across steel producing states or regions.
8.1.2.3.2 Hydrochloric Acid. The U.S. merchant market
for HC1 is going through difficult times at the time this is
written (December 1993). Tight HCl supplies and climbing
prices are the results of the high cost of chlorine.
Interestingly, one of the normally stable factors now
appears to be in flux,13 i.e., the share of HCl supply to
the merchant market contributed by companies that produce
the acid as a co-product of other chemical manufacturing
operations and those that produce it by burning elemental
chorine with hydrogen.
8-10
-------
TABLE 8-3 PRODUCTION COSTS OF U.S. PRODUCERS ON THEIR
OPERATIONS PRODUCING HOT-ROLLED PRODUCTS,
FISCAL YEARS 1990-9214
Item
••^^••^^••M
Hot-rolled
Steelmaking
Basic oxygen process
Electric furnace
Casting
Ingot
Continuous
Trade sales
Company transfers
Cokemaking
Ironmaking
Steelmaking
Basic oxygen process
Electric furnace
Other
Casting
Ingot
Continuous
Purchased slabs/ingots
Purchased
Hot-strip rolling with ingot breakdown
Pickling and oiling
Shearing
Other
Total production cost
Change in finished goods inventory
Total production cost and inventory
change
Steelmaking
Basic oxygen process
Electric furnace
Casting
Quantity (103 short tons)
46,355 40,681
44,587
Ingot
Continuous
Trade sales
Company transfers
Note: *** indicates mat
41,200
2,524
11,954
34,313
16,689
29,483
1,491
4,022
**
-------
TABLE 8-4.
HOURLY LABOR COSTS IN THE UNITED STATES STEEL
INDUSTRY: 1967-199015-16
Average
Year
1967
1968
1969
1970
1971
1972
1973
1974
1975
1976
1977
1978
1979
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
Hourly Earnings
BLS
3.62
3.82
4.09
4.22
4.57
5.15
5.56
6.38.
7.11
7.86
8.67
9.70
10.77
11.84
13.11
13.96
13.40
13.53
13.98
14.53
14.54
14.72
15.00
15.59
16.21
16.87
($)
AISI'
3.66
3.86
4.12
4.24
4.57
5.22
5.69
6.55
7.23
8.00
8.91
9.98
11.02
12.11
13.43
14.06
13.63
13.73
14.27
14.63
14.53
14.70
15.00
15.73
16.56
17.45
Total Employment Cost
"flay
4.76
5.03
5.38
5.68
6.26
7.08
7.68
9.08
10.59
11.74
13.04
14.30
15.92 ;
18.45
20.16
23.78
22.21
21.30
22.81
23.24
23.71
24.65
24.62
25.62
27.64
29.57
BLS data exclude office, clerical, and supervisory personnel.
Calculated as the sum of total payroll cost per hour (earnings
and holiday and vacation pay) and employee benefits costs per
hour). .
8-12
-------
TABLE 8-5. AVERAGE HOURLY EARNINGS FOR PRODUCTION
WORKERS IN PRIMARY METALS INDUSTRY BY STATE: 1990-1992'-17
====================s=3====
State
Alabama
Arizona
Arkansas
California
Connecticut
Florida
Georgia
Illinois
Indiana
Iowa
Kentucky
Maryland
Massachusetts
Michigan
Minnesota
Missouri
New Hampshire
New Jersey
New York
North Carolina
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
Tennessee
Texas
Utah
Virginia
Washington
West Virginia
Wisconsin
National avg.
=========
1990
11.98
13.23
10.34
13.38
11.35
9.85
10.92
13.21
15.27
13.33
13.88
15.84
11.13
14.77
11.24
11.32
11.06
11.48
12.85
10.48
14.55
11.04
12.59
13.21
10.32
11.94
11.36
12.96
10.83
13.24
14.45
11.04
12.33
1991
12.54
12.68
10.71
14.23
11.58
10.52
10.79
13.40
15.80
13.37
14.39
16.57
11.59
14.86
11.93
12.36
11.41
11.99
13.19
11.02
15.08
10.70
12.92
13.69
10.23
12.02
11.51
13.55
10.86
13.78
14.84
11.54
12.68
1992
12.96
12.30
11.21
14.85
11.79
10.55
11.44
13.75
16.21
13.80
14.46
17.56
12.04
15.08
12.60
12.64
12.06
12.54
13.71 .
11.49
15.87
10.83
13.48
14.43
10.81
12.05
11.94
14.12
11.31
14.19
15.52
11.91
13.11
1 Estimates are measured in current dollars.
8-13
-------
Traditionally, the HC1 supply from co-product producers such
as Dow Chemical is dependent on the overall chemical
business. When production of other lines such as
fluorocarbons, isocyanide, and vinyl chloride monomer (VCM)
drops, HC1 supply drops. These producers of HC1 have been
raising prices to the level of $90 to $100 per ton in the
past few months. Some co-producers do not consider HC1 a
viable market and simply dispose of the acid by deep-well
injection, in effect keeping it off the merchant market.
According to Dow, the major consumer market for HC1 are
steel pickling (21 percent), oil field acidizing
(21 percent), chemical manufacturing (20 percent), food
products (18 percent), industrial cleaning (10 percent), and
metals production (5 percent).18
8.2 THE DEMAND SIDE OF THE STEEL INDUSTRY
This section characterizes the demand side of the
market for steel mill products. We describe the
characteristics, uses and consumers of steel mill products,
and the substitution possibilities in consumption.
8.2.1 Product Characteristics
As Lancaster describes, goods are of interest to the
consumer because of the properties or characteristics they
possess; these characteristics are taken to be an objective,
universal property of the good.19 Therefore, the demand for
a commodity is not simply for the good itself but also for a
set of characteristics and properties that is satisfied by a
particular commodity.
The characteristics of steel mill products provide
certain attributes that are desired in manufacturing
numerous products like motor vehicles, machinery and
equipment, appliances, and containers. In deciding which
materials to consume, manufacturers consider both economic
and technical factors. Economic factors include price,
transformation and installation cost, and maintenance and
8-14
-------
operation cost. Technical factors include physical
properties such as density, tensile strength, durability,
thermal conductivity, versatility, and appearance.
8.2.2 Uses and Consumers of Steel
The demand for steel can be characterized as a derived
demand in that steel consumption is driven by the
consumption of products that use steel as a raw material in
production. The demand for products and services such as
motor vehicles, construction, machinery and equipment,
shipbuilding, household appliances, and utilities is
instrumental in determining the demand for steel products.
Because steel has a wide range of applications, trends in
its consumption reflect the trends in the U.S. economy as a
whole. In particular, the demand for steel is closely tied
to construction activity and conditions in the automotive
industry.
Table 8-6 shows steel shipments by market
classification, or consumer groups, from 1982 to 1992.20
Consumers of steel can be divided into two broad categories:
industrial consumers and nonindustrial consumers. The
industrial consumer group comprises a number of industries
that most directly determine the level of demand for steel.
These industries include the automobile, agriculture and
mining, heavy machinery and equipment, appliance,
construction, transportation, oil and gas, and other
industries. As Table 8-6 shows, the largest industrial
markets served by the steel mill industry in 1992 were
construction, including maintenance and contractors'
products (14.9 percent), motor vehicles (13.5 percent), and
producer durables (11.2 percent), which includes steel for
converting and processing, independent forgers, industrial
fasteners, machinery, equipment and tools, and electrical
equipment.
Nonindustrial consumers are primarily steel service
centers, included with nonclassified shipments in the
8-15
-------
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8-16
-------
"other" category of Table 8-6. Steel service centers
generally perform four functions in the U.S. market:
• Act as broker between buyer and the U.S. or
foreign steel producer without taking possession
of the product;
• Act as a buying broker ordering specified products
on behalf of customers taking possession of the
product and shipping to the customer;
• Act as distributors by buying and inventorying
products that are commercial quality and reselling
to U.S. customers in the merchant market; and
• Act as processors that purchase products, perform
further processing like forming, and then resell
the product to U.S. customers.fi
Steel service centers and distributors accounted for 25.9
percent of steel shipments in 1992.B
Figure 8-1 illustrates the share of steel consumption
for 1982 and 1992 by the major market classifications. The
relative distribution of consumption has not changed much
over the past decade. Steel service centers (within the
"other" category) continue to be the largest user of steel
followed by industries in the producer durables category,
construction industry, and the automotive industry.
8.2.3 Substitution Possibilities in Consumption
Because the demand for steel is a derived demand,
discussing substitute materials is necessary to understand
the markets for steel products. Empirical evidence suggests
that the demand for steel is relatively inelastic with
respect to price due, in part, to the varied end products
that result from using substitute materials in manufacturing
and other applications. Table 8-7 presents demand
elasticities for various carbon steel products and advanced
composites compete with steel in the automotive and
container industries. In this section we discuss
substitution materials for steel in the beverage can,
containers, and automobile markets.
8-17
-------
Containers & Packaging
7.3%
1982
69.6 Million Tons
Consumer Durables
4.5%
Construction
13.9%
Motor Vehicles
15.1%
Oil & Gas Industry
4.5%
Producer Durables
14.3%
Agriculture & Mining
1.9%
Other
34.8%
Transportation Exports
2.3%
1992
82.3 Million Tons
Producer Durables
17.8% ___ Transportation
Oil & Gas Industry
1.8%
Motor Vehicles
13.5%
Exports
3.3%
Containers &
Packaging
4.8%
Consumer Durables
3.0%
Construction
14.9%
Other
38.4%
Agriculture & Mining
1.1%
Figure 8-1. Share of steel consumption for 1982 and 1992 by
major market classification.
8-18
-------
TABLE 8-7.
ESTIMATED DEMAND ELASTICITIES FOR VARIOUS
CARBON STEEL PRODUCTS24
Consuming Industry/Carbon Steel
Product
Own-Price Demand
Elasticity
Automotive
Hot-rolled bars
Hot-rolled sheet and strip
Hot-rolled sheet and strip
Construction
Structurals
Hot-rolled bars
Plates
Container and Packaging
Tin mill products
-0.07
-0.44
-0.28
-0.73
-0.47
-0.19
-0.70
8.2.3.1 Beverage Cans
In 1961, the steel industry enjoyed 100 percent of the
beverage can market; however, by 1991, steel's share of the
beverage can market had dropped to 4 percent, while
aluminum's share had grown to 96 percent.25 Standard and
Poor's Industry Survey states that the prospects for steel
regaining a significant share of the beverage can market are
slim. First, the cost of converting production lines makes
switching to steel from aluminum unattractive, even when the
cost of steel is depressed. Secondly, prices of aluminum
ingot and aluminum for can sheet are very low at present.
Moreover, large inventories and continued high output of
aluminum from the former Soviet Union are expected to keep
the price of aluminum ingot low in 1993. This situation is
in great contrast to the one that prevailed in 1989, when
can manufacturers contemplated switching to steel because of
aluminum's high prices.26
8-19
-------
8.2.3.2 Containers
In 1974, the most recent peak, steel shipments to the
container industry totaled 8.2 million tons. By 1991,
however, total steel shipments to this industry had dropped
to 4.3 million tons — a 47.6 percent decline.27
Substituting aluminum has prevented steel from improving its
share in the container market, although steel's share of the
container market has stabilized since 1985. Steel still
dominates the food container market, but this segment may
decline on a secular basis because of the growing consumer
preference for frozen foods and the increased use of
microwave ovens.28
8.2.3.3 Automobiles
8.2.3.3.1 Plastics. The increased use of plastics in
cars has eroded the commanding position that steel had
occupied in this large and critical market. Pressure to
increase fuel efficiency has compelled automakers to reduce
the weight of their cars; substituting plastics for steel
decreases the car's weight. From the automaker's point of
view, plastics have certain advantages over steel. Not only
are they lighter, but their production costs are lower as
well. Although on a pound-for-pound basis plastics cost
more than steel, assembled and finished plastic bodies are
generally less expensive than comparable metal parts because
tooling costs are substantially lower. Additionally, one
plastic part can take the place of several steel parts that
must be welded or bolted together. The results include
labor and weight savings and enhanced aerodynamic
properties. Plastics have replaced steel in such
applications as dashboards, fenders, and inner panels.29
Steel still enjoys several advantages over plastics,
including lower material cost, higher production speed,
paintability, and superior surface finish. Furthermore,
steelmakers have successfully produced thinner, lighter
weight steels for auto panels and parts. In addition,
plastics are problematic in high-temperature applications,
8-20
-------
and they are difficult, to recycle, whereas steel is one of
the most recyclable materials.30
Over the long term, plastics' contribution to fuel
savings, combined with its corrosion resistance and design
flexibility, poses a strong threat to steel. In the near
term, however, the substitution rate of plastics for steel
should begin to plateau because of plastics'' inability to be
recycled and because the steel industry is continuously
introducing improved products. American Metals Market
reported in October 1992 that Ford dropped plans to bring
out a plastic-intensive model in its F-Series pickup truck
line for the 1996 model year. Ford engineers cited cost
considerations and the improvement in steel product prices
as factors in the company's decision to retain steel.
Furthermore, the article noted that GM planned to substitute
steel for plastics in its next generation of front-wheel
drive minivans beginning with the 1996 or 1997 model year.31
8.2.3.3.2 Aluminum. In the auto market, aluminum
poses a more formidable threat to steel than plastics.
Aluminum is an extremely attractive alternative to steel
because it is recyclable, corrosion resistant, much lighter
in weight, and has lower tooling costs. From an
environmental point of view, aluminum's recyclability makes
it a compelling substitute for steel, while its weight
advantage contributes to increased fuel efficiency for the
typical passenger car. Current applications for aluminum
include engine blocks, castings, bumpers, hoods, and
wheels.32 In the near term, Standard & Poor's estimates
that aluminum applications in automobiles will grow by about
3.0 percent annually, thereby eroding steel's position
gradually.33
8-21
-------
8.3 INDUSTRY ORGANIZATION
8.3.1 Market Structure
Market structure is of interest because of the effect
it has on the behavior of producers and consumers. A market
is generally considered the locus where producers and
consumers interact to trade goods and services. Economic
theory usually takes the market as given; however, when
considering regulatory impacts, the analyst must define the
products and producers that constitute the markets. The
products of interest here are steel products that are
pickled during their manufacture, and the number of
producers included in the analysis is determined by the
geographic bounds of the market.
8.3.1.1 Steel Products. As mentioned in Section 2,
steel is divided into two distinct types: carbon (including
light alloy) and alloy steel. The market for carbon steel
products accounted for over 93.2 percent of total production
of steel mill product by tonnage in 1992. The carbon steel
products category is further subdivided into types such as
flat-rolled, plate, and tubular products. These divisions
highlight the differentiation across steel products.
Generally, consumers do not demand a standard type of steel
product. Instead, specific products are required to meet
consumers' needs. Because many different product categories
are produced and consumed across the U.S., steel is not a
homogeneous product (see Appendix Tables F-l through F-5 for
a complete and detailed listing of steel mill products by
SIC code).
8.3.1.2 Steel Producers. Steel producers are
generally classified as either integrated or nonintegrated
mills. Integrated mills are usually large capital-intensive
facilities that possess both steelmaking facilities (e.g.,
coke ovens, blast furnaces, and basic oxygen furnaces) and
rolling and finishing mills. The range of products produced
8-22
-------
by integrated mills is extensive, although most are carbon
steel products. Nonintegrated mills include so called
"minimills" and "converters." Minimills typically produce
steel by melting recycled scrap metal in electric arc
furnaces, involving much less capital investment than
required for integrated steelmaking. Steel converters, or
processors, purchase steel for further processing as opposed
to producing molten steel on site.
As shown in Table 8-8, the share of U.S. steel
shipments for the six largest integrated producers fell from
TABLE 8-8. SHARE OF THE SIX LARGEST INTEGRATED PRODUCERS
IN THE U.S. STEEL SHIPMENTS—1950 TO 198634
Year
1950
1960
1970
1982
1983
1984
1985
1986
Armco
4.1
6.7
5.1
6.1
5.7
5.6
5.4
5.4
Bethlehem
14.9
15.3
13.1
13.2
12.9
12.1
12.0
12.1
Inland
4.5
6.8
4.5
6.7
7.1
6.8
6.4
7.0
LTV
18.0
16.6
14.4
8.3
8.6
11.2
14.6
13.1
National
5.5
7.1
6.9
5.6
6.0
6.1
6.0
6.4
USS
30.8
25.0
19.9
16.2
16.3
16.0
17.1
12.1
Total
77.8
77.5
63.9
56.1
56.6
57.8
. 61.7
56.0
Note: USS was shut down after a labor disruption from August 1986 to
February 1987.
78 in 1960 to 56 percent in 1986. Partial and complete
shutdowns of plants were major contributors to this
reduction, which was principally due to market shrinkage and
import penetration. From 1977 to 1987, the number of
integrated steel companies in the U.S. fell from 20 with 47
plants to 14 with 23 plants. The market shrinkage resulted
not only from reduced demand by consuming industries, but
also from increased competition from the minimills in
traditional integrated mill products.
At their inception, minimills tended to specialize in
products like bars and rods. Of late, however, minimills
8-23
-------
have begun to produce hot- and cold-rolled sheet and large
structurals, which formerly were only produced by integrated
producers. Minimills have moved into other product lines
because they can satisfy demand for traditional minimill
products and have available capacity.
8.3.1.3 Geographically Distinct Markets. Since
transportation costs account for a significaht portion of
the delivered price of steel products, the steel industry is
characterized by geographically distinct markets for its
products. These costs generally account for 3 to 10 percent
of the total delivered cost of carbon steel products. The
International Trade Commission (ITC) reported that U.S.
inland transportation costs for carbon steel products are
a significant factor in customers' purchase decisions and
can affect a producers' or importers' price competitiveness,
depending on the particular product and the location of the
customer.35 The substantial cost of inland transport makes
imported steel products more competitive in ooastal regions
of the U.S. near their ports of entry than in inland markets
where most of the domestic mills are located. Exceptions
occur at locations like the Great Lakes region and parts of
the inland Southeast where transporting imported products by
barge on the St. Lawrence Seaway and the Mississippi River
is relatively inexpensive.
Recent investigations by the ITC of unfair trade
practices by foreign producers of steel indicate that
freight advantages usually only occur on standard quality
products.36 Freight advantages are not as important a
factor for the sales of specialty products—those produced
by a small number of domestic or foreign plants. Therefore,
these products are shipped to all markets in the U.S. The
ITC investigations also indicated that 85 to 95 percent of
steel producers report selling their products to customers
within 500 miles of the plant.37 Table 8-9 provides
estimated inland transportation costs (in dollars per ton)
8-24
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TABLE 8-9.
INLAND TRANSPORTATION COSTS OF STEEL PRODUCTS
BY SHIPPING DISTANCE: 199238
Distance
Shipped
Estimated
Freight
($/tpn)
Less than 100 miles
100 to 500 miles
Greater than 500 miles
10 to 20
15 to 45
35 to 60
of domestic producers and importers of steel products by
distance shipped from the plant or port of entry.
The ITC report also lists the cost and availability of
freight for shipments to steel customers as the most
important factor in defining the geographic bounds of the
market.39 In fact, Mueller suggests that the delivered
price of steel products is more important than production
costs in determining which supplier is competitive in a
particular market.40 Mueller reports that despite shipping
distances, consumers of steel along the West Coast or in the
Gulf region find purchasing steel from foreign producers
more economical than purchasing it from domestic producers
in the steel belt. Other "market-defining" factors listed
by the ITC include the degree to which the product is
specialized, competition from neighboring suppliers, product
quality, and existing relationships with certain
customers.41 In general, geographical markets are
delineated where only neighboring plants compete directly.
However, exceptions occur in markets where domestic or
foreign producers have access to inexpensive transportation
such as waterways.
Table 8-10 provides free-on-board (f.o.b.) prices
obtained from American Metal Market for various steel mill
products for 1990 to 1992. The f.o.b. prices vary by
product—the more finished products (i.e., cold-rolled and
galvanized steel) command a higher price. Comparing the
8-25
-------
TABLE 8-10.
PRICES PER TON OF VARIOUS STEEL MILL
PRODUCTS: 1990-199242
Steel Mill Product
Hot-rolled carbon steel
bar*
Hot-rolled strip1
Hot-rolled sheet*
Carbon steel plates'
Cold-finished carbon
steel bar*
Cold-rolled sheetb
Cold-rolled strip*
Galvanized sheet*
1990
$408.60
$442.00
$445.00
$475.00
$507. 4O
$612.80
$744.80
$671.00
F.O.B. Price
1991
$412.00
$463.00
$457.60
$490.00
$515.00
$643.60
$777.20
$707.00
1992
$349.60
$470.00
$382.60
$490.00
$480.60
$555.80
$788.00
$617.60
• Estimate reflects annual average F.O.B. (free on board)
price reported at Pittsburgh mills.
b Estimate reflects price reported at most Midwest mills.
inland transportation costs given in Table 8-9 to these
product prices provides cost-to-value ratios in the range of
1 to 17 percent. This high ratio supports the notion that
steel mill product markets are defined regionally across the
U.S. This statement should be especially true in the case
of low valued semi-finished products.
8.3.1.4 Market Behavior. Once the market structure is
defined, we characterize the behavior of consumers and, most
importantly, producers of steel. The discussion on behavior
generally focuses on monopoly, oligopolistic, or competitive
pricing. Making inferences about the behavior of producers
often relies on developing a measure of the concentration of
an industry or market. A concentration measure should
reflect the ability of firms to raise prices above the
competitive level. Less concentrated markets are predicted
to be more competitive and should result in a low
concentration measure value, while a higher value should
8-26
-------
indicate a higher price-cost margin or a higher likelihood
of noncompetitive behavior on the part of producers. A
widely used measure is the concentration ratio. The n-firm
concentration ratio reflects the share of total industry
sales accounted for by the n largest firms. Unfortunately,
concentration ratios only describe one point on the entire
size distribution of sellers or producers.
Table 8-11 provides concentration ratios for the top 4.
8, and 20 U.S. steel companies by SIC code from 1972 through
1987. For all years, SIC codes 3312 (blast furnaces and
steel mills) and 3315 (cold finishing of steel shapes) had a
higher concentration of the value of shipments across the
top 4, 8, and 20 U.S. steel companies than SIC codes 3315
(steel wire and related products) and 3317 (steel pipes and
tubes). The industry concentration ratios may not be so
high as to infer noncompetitive behavior, but that may be
because no one steel company serves the entire U.S. market.
The 'concentration within a geographically defined product
market would be more indicative of market behavior.
Unfortunately, information of this type at the regional
level by specific products is not available at this time.
8.3.2 Firm Characteristics
A regulatory action to reduce pollutant discharges from
steel pickling facilities and acid regeneration plants will
potentially affect the business entities that own the
regulated facilities. Facilities comprise a site of land
with plant and equipment that combine inputs (raw materials,
fuel, energy, and labor) to produce outputs (steel).
Companies that own these facilities are legal business
entities that have the capacity to conduct business
transactions and make business decisions that affect the
facility. The terms facility, establishment, plant, and
mill are synonymous in this analysis and refer to the
physical location where products are manufactured.
Likewise, the terms company and firm are synonymous and
refer to the legal business entity that owns one or more
8-27
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TABLE 8-11. CONCENTRATION RATIOS FOR TOP 4, 8, and 20 U.S.
STEEL COMPANIES BY SIC: 1972, 1977, 1982, and 198743
Value of Shipments
Percent accounted for by
SIC/Description/ No. of Total
Year Companies ($10 )
3312
3315
3316
3317
Blast Furnaces
and Steel Mills
1987
1982
1977
1972
Steel wire and
Related
products
1987
1982
1977
1972
Cold finishing
of steel shapes
1987
1982
1977
1972
Steel pipe and
tubes
1987
1982
1977
1972
271
211
395
241
274
252
262
234
156
146
118
85
155
170
130
115
15,804.7
11,763.3
15,331.9
10,304.7
3,330.3
2,420.9
2,258.6
1,227.7
5,216.3
3,005.1
2,713.2
1,635.7
3,856.3
3,762.2
2,681.4
1,292.1
4 largest
companies
44
42
45
45
21
22
21
18
45
42
37
40
23
24
24
23
20
8 largest largest
companies companies
63
64
65
65
34
32
32
30
62
58
54
56
34
39
39
40
81
82
84
84
54
54
52
52
82
77
80
82
58
64
68
7.0
8-28
-------
facilities. The chain of ownership may be as simple as one
facility owned by one company or as complex as multiple
facilities owned by subsidiary companies. Potentially
affected firms include entities that own steel pickling
plants as well as acid regeneration plants.
8.3.2.1 ownership. The legal form of ownership
affects the cost of capital, availability of capital, and
effective tax rate faced by the firm. Business entities
that own steel pickling facilities or acid regeneration
plants will generally be one of three types of entities:
• Sole proprietorships,
• Partnerships, and
• Corporations.
Each type has its own legal and financial
characteristics that may influence how firms are affected by
the regulatory alternatives. Table 8-12 provides
information about the legal form of ownership of firms for
the relevant SIC codes.44 Figure 8-2 compares the legal
form of ownership of all firms in the U.S. and the steel
industry.45-46
TABLE 8-12. LEGAL FORM OF FIRM ORGANIZATION IN THE PRIMARY
METALS* INDUSTRY: 198747
Item
Sole
Proprietor- Partner Other
Corporation ship -ships Total
Single-
facility firms
Multifacility
firms
ALL FIRMS
3,610
1,168
4,777
N.A.
N.A.
210
N.A.
N.A.
113
N.A.
N.A.
300
4,215
1,185
5,400
* Primary metals is defined by SIC 33.
8.3.2.1.1 Sole Proprietorships. A sole proprietorship
consists of one individual in business for him/herself who
contributes all of the equity capital, takes all of the
8-29
-------
U.S.
Sole Proprietorships
71.3%
Corporations
19.7%
Partnerships
9%
Primary Metals
Industry
Corporations
88.4%
Sole Proprietorships
Partnerships 3-8%
Other 2.0%
5.5%
Figure 8-2. Comparison of the legal form of ownership for firms
in the U.S. and primary metals industry: 1987.48-49
8-30
-------
risks, makes the decisions, takes the profits, or absorbs
the losses. Behrens reports that sole proprietorships are
the most common form of business.50 The popularity of the
sole proprietorship is in large part due to the simplicity
of establishing this legal form of organization. For 1987,
Internal Revenue Service (IRS) data indicate that nonfarm
sole proprietorships represented almost 72 percent of U.S.
businesses but accounted for only 6 percent of business
receipts.51 The 1987 Census of Manufactures reports,
however, that very few firms in the U.S. primary metals
industry are sole proprietorship—only 210 of the 5,400
firms under SIC 33. This type of business organization
accounts for a minimal proportion of the industry at less
than 4 percent.
Legally, the individual and the proprietorship are the
same entity. From a legal standpoint, personal and business
debt are not distinguishable. From an accounting
standpoint, however, the firm may have its own financial
statements that reflect only the assets, liabilities,
revenues, costs, and taxes of the firm, aside from those of
the individual. When a lender lends money to a
proprietorship, the proprietor's signature obligates him or
her personally of all of his/her assets. A lender's
assessment of the likelihood of repayment based on the firm
and the personal financial status of the borrower is
considered legal and sound lending practice because they
are legally one-and-the-same. Table 8-13 highlights the
advantages and disadvantages of this ownership type.52
8.3.2.1.2 Partnerships. For 1987, IRS data on
business tax returns indicate that partnerships represented
only 9 percent of U.S. businesses and accounted for an even
smaller percentage of business receipts—4 percent.53 For
1987, the Census of Manufactures reports that only 113 of
the 5,400 companies listed under SIC code 33 are
partnerships—accounting for just over 2 percent of all
firms in the industry.
8-31
-------
TABLE 8-13.
ADVANTAGES AND DISADVANTAGES OF THE SOLE
PROPRIETORSHIP54
Advantages
Disadvantages
Simplicity of organization
Owner's freedom to make all
decisions
Owner's enjoyment of all
profits
Minimum legal restrictions
Ease of discontinuance
Tax advantages
Owner's possible lack of
ability and experience
Limited oppbrtunity for
employees
Difficulty in raising
capital
Limited life of the firm
Unlimited liability of
proprietor
Note: A brief evaluation of these advantages and
disadvantages is available in Steinhoff and
Burgess (1989).
A partnership is an association of two or more persons
to operate a business. In the absence of a specific
agreement, partnerships mean that each partner has an equal
voice in management and an equal right to profits,
regardless of the amount of capital each contributes. A
partnership pays no federal income tax; all tax liabilities
are passed through to the individuals and are reflected on
individual tax returns. Each partner is fully liable for
all debts and obligations of the partnership. Thus, many of
the qualifications and complications present in analyses of
proprietorships (e.g., capital availability) are present—in
some sense magnified—in analyses of partnerships.
Table 8-14 lists the advantages and disadvantages of this
ownership type.
8.3.2.1.3 Corporations. According to IRS business tax
returns for 1987, corporations represented only 19.7 percent
of U.S. businesses but accounted for 90 percent of all
business receipts
55
For 1987, the Census of Manufactures
8-32
-------
TABLE 8-14.
ADVANTAGES AND DISADVANTAGES OF THE
PARTNERSHIP56
Advantages
Disadvantages
Ease of organization
Combined talents, judgement, and
skills
Larger capital available to the
firm
Definite legal status of the firm
Tax advantages
Unlimited
liability
Limited life
Divided
authority
Danger of
disagreement
Note: A brief evaluation of these advantages and disadvantages is
available in Steinhoff and Burgess (1989).
reports that 4,777 of 5,400 firms listed under SIC code 33
for the primary metals industry are corporations.
Therefore, corporations represent the vast majority (88.5
percent) of the business entities involved in manufacturing
steel.
Unlike proprietorships and partnerships, a corporation
is a legal entity separate and apart from its owners or
founders. Financial gains from profits and financial losses
are borne by owners in proportion to their investment in the
corporation. Analysis of credit availability to a
corporation must recognize at least two features of
corporations. First, they have the legal ability to raise
needed funds by issuing new stock. Second, institutional
lenders (banks) to corporations assess credit worthiness
solely on the basis of the financial health of the
corporation—not the financial health of its owners. A
qualification of note is that lenders can require (as a loan
condition) owners to agree to separate contracts obligating
them personally to repay loans. Table 8-15 highlights the
advantages and disadvantages of this ownership type.
8-33
-------
TABLE 8-15.
ADVANTAGES AND DISADVANTAGES OF THE
CORPORATION57
Advantages
Disadvantages
Limited liability to stockholders
Perpetual life of the firm
Ease of transferring ownership
Ease of expansion
Applicability for both large and small firms
Government regulation
Expense of organization
CapitaJ. stock tax
Note: A brief evaluation of these advantages and disadvantages is
available in Steinhoff and Burgess (1989).
8.3.2.2 Size Distribution. Firm size is likely to be
a factor in the distribution of the regulatory action's
financial impacts. Grouping the firms by size facilitates
the analysis of small business impacts, as required by the
Regulatory Flexibility Act (RFA) of 1982.
Firms are grouped into small and large categories using
Small Business Association (SBA) general size standard
definitions for SIC codes. These size standards are
presented either by number of employees or by annual receipt
levels, depending on the SIC code. As presented in
Table 8-16, the firms owning steel pickling facilities or
acid regeneration plants are covered by various SIC codes
within the two-digit code 33 for the primary metals
industry. Thus, according to SBA size standards, these
firms are categorized small if the total number of employees
at the firm is less than 1,000; otherwise the firm is
classified as large. Small firms comprise 51.4 percent of
the total, while large firms are the remaining 48.6 percent.
Control economies are typically plant-related rather
than firm-related. For example, a firm with six
uncontrolled plants with average annual receipts of $1
million per plant may face approximately six times the
control capital requirements of a firm with one uncontrolled
8-34
-------
TABLE 8-16. SBA SIZE STANDARDS BY SIC CODE FOR THE PRIMARY
METALS INDUSTRY
SBA Size
Standard in
Number of
SIC Code
3312
3315
3316
3317
3357
3398
Description
Blast furnaces and steel mills
Steel wire and related products
Cold finishing of steel shapes
Steel pipe and tubes
Nonferrous wire drawing and
insulating
Metal heat treating
Employees
1,000
1,000
1,000
1,000
1,000
750
plant whose receipts total $6 million per year.
Alternatively two firms with the same number of plants
facing approximately the same control capital costs may be
financially affected very differently if the plants of one
are larger than those of another.
Table 8-17 shows the average size of the plants (based
on 1991 total employment level) represented in each company
size category. As expected, larger firms own larger
facilities on average. Table 8-18 shows the distribution of
firms by the number of plants owned. A slight correlation
seems to exist between the number of steel pickling plants
owned and the size of the firm. The average number of steel
pickling plants owned by small firms is 1.14 (41 facilities
•* 36 firms) as compared to an average of 1.82 steel pickling
plants (62 facilities * 34 firms) owned by large firms. Of
course, nonsteel pickling plants are not reflected in this
distribution.
8-35
-------
TABLE 8-17. AVERAGE SIZE OF FACILITY BY
• FIRM SIZE CATEGORY: 1991*-58
Firm size based on
employment (1991)
Average Size
of Facility
Small (< 1,000)
Large (>1/000)
Total, all firms
17.8
62.9
45.4
•Facility size is measured as total employment in 1991.
TABLE 8-18. DISTRIBUTION OF FIRMS BY NUMBER OF
FACILITIES OWNED: 1991
59
Number of facilities owned per
firm
Firm-level size
based on employment
Small (< 1,000)
Large (>1,000)
Total, all firms
8.3.2.3 Issues of
1 2
32
21
53
Vertical
to
4
7
11
and
3 Over 3
0
6
6
Horizontal
Total
36
34
70
Intearation.
Vertical integration is a potentially important dimension in
analyzing firm-level impacts because the regulation could
affect a vertically integrated firm on more than one level.
For example, the regulation may affect companies for whom
pickling is only one of several processes in which the firm
is involved. For example, a company owning steel pickling
facilities may also manufacture beverage containers, heavy
machinery, or automobile parts, for example. This firm
would be considered vertically integrated because it is
involved in more than one level of production requiring
steel manufacture and finished products made from steel. A
regulation that increases the cost of pickling steel will
affect the cost of producing products like beverage
containers made from steel products that are pickled during
the production process.
8-36
-------
Horizontal integration is also a potentially important
dimension in firm-level impact analyses for either or both
of two reasons:
• A diversified firm may own facilities in
unaffected industries. This type of
diversification would help mitigate the financzal
impacts of the regulation.
• A diversified firm could be indirectly as well as
directly affected by the regulation. For example,
if a firm is diversified in manufacturing
pollution control equipment (an unlikely
scenario), the regulation could indirectly and
favorably affect it.
The range of SIC codes represented by firms owning
steel pickling facilities is presented in Table 8-19.
Seventeen companies report conducting business within SIC
3312 (blast furnaces and steel mills), eight list SIC 3315
(steel wire and related products) and SIC 3316 (cold-
finishing of steel shapes), and four list SIC 3317 (steel
pipe and tubes). Lines of business reported by companies
that are outside the primary metals industry include SIC
3452 (bolts, nuts, screws, rivets, and washers), SIC 3465
(automotive stampings), and SIC 7538 (general automotive
repair shops).
8.3.2.4 Financial Condition. Table 8-20 illustrates
the financial experience of U.S. steel producers,
processors, and converters for 1991 and 1992.^ Integrated
producers, as a whole, incurred rather large operating
losses for both 1991 and 1992. Alternatively, the
nonintegrated mills (minimills, specialty mills, and
processing mills) were slightly profitable over these years,
except for minimills in 1992.
8.3.2.5 current Events. American Metal Market
reported a number of developments that changed the U.S.
steel industry during 1992.61 Bethlehem Steel shut down its
Bar, Rod, and Wire division based in Johnstown,
Pennsylvania, and sold the wire mill to TMB Industries of
8-37
-------
TABLE 8-19. SIC LISTINGS FOR U.S. STEEL COMPANIES
OWNING STEEL PICKLING FACILITIES62
SIC
1311
2911
3011
3052
3069
3299
3312
3315
3316
3317
3325
3356
3357
3398
3423
3441
3443
3449
3452
3462
3465
3471
3479
Description
Crude petroleum and natural gas
Petroleum refining
Tires and inner tubes
Rubber and plastics hose and belting
Fabricated rubber products, n.e.c.
Nonmetallic mineral products, n.e.c.
Blast furnaces and steel mills
Steel wire and related products, mfpm
Cold finishing of steel shapes
Steel pipe and tubes-mfpm
Steel foundries, n.e.c.
Rolling, drawing and extruding of nonferrous
metals, except copper and aluminum
Nonferrous wire drawing and insulating
Metal heat treating
Hand and edge tools, n.e.c.
Fabricated structural metal
Fabricated plate work
Miscellaneous metal work
Bolts, nuts, screws, rivets and washers
Iron and steel forging
Automotive stampings
Metal plating and polishing
Metal coating and allied services
Number of
Companies
1
1
1
1
1
1
17
8
8
4
1
1
2
2
1
2
1
1
1
1
I
3
4
8-38
-------
TABLE 8-19, (Continued)
SIC
3496
3499
3531
3532
3533
3545
3548
3568
3592
3624
3625
3644
3714
3731
3743
3799
5051
6719
7538
Description Number of
Companies
Miscellaneous fabricated wire products
Fabricated metal products, n.e.c.
Construction machinery
Mining machinery and equipment
Oilfield and gasfield machinery and
equipment
Machine tool accessories
Gas and electric welding and soldering
equipment
Power transmission equipment, n.e.c.
Carburetors, pistons, piston rings and
valves
Carbon and graphite products
Relays and industrial controls
Noncurrent-carrying wiring devices
Motor vehicle parts and accessories
Ship building and repairing
Railroad equipment
Transportation equipment, not elsewhere
classified
Metal service centers and offices- wholesale
Offices of holding companies, n.e.c.
General automotive repair shops
5
3
1
1
1
1
1
1
1
1
1
1 •
1
2
1
1
4
3
1
8-39
-------
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Chicago and the remaining mills to the Ispat Group of
Indonesia. Oregon Steel made a bid to purchase CF&I Steel
out of Chapter 11 creditor protection, while Sharon Steel
Corporation halted all steelmaking and rolling operations in
November before re-entering bankruptcy court protection.
Armco Incorporated purchased Cyclops Industries, Inc.,
making the combined company the nation's second largest
specialty steel producer behind Allegheny Ludlum
Corporation. Late in the year, Lukens, Inc., purchased
Washington Steel Corporation and Washington Specialty
Metals, Incorporated. Other U.S. producers facing financial
difficulties during the year were Northwestern Steel and
Wire Corporation, McLouth Steel Corporation, Thomas Steel
Corporation, and Edgewater Steel Corporation.
8.4 MARKETS
Steel products are produced and consumed domestically
as well as traded internationally. Therefore, domestic
producers export some of these products to other countries,
and foreign producers supply their steel products to U.S.
markets. This section includes tables on quantity trends
over the past decade for steel mill products. Although the
fraction of each steel mill product actually pickled is not
known at present, the information provided here is useful
because these products represent all the finished products
that are subject to steel pickling processes.
8.4.1 Production
8.4.1.1. Domestic Production. U.S. shipments for steel
mill products from 1983 to 1992 are shown in Table 8-21.64
As shown, net shipments increased by 21.6 percent over this
period from 67.6 million tons in 1983 to 82.2 million tons
in 1992. Sheets and strip consistently account for the
largest percentage of annual U.S. shipments followed by
8-41
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semi-finished products, shapes and plates, and bars. In
1992, these four product groups accounted for 88.3 percent
of total U.S. shipments of steel mill products. Rails, tool
steel, and wire products together account for less than 2
percent of total shipments in 1992.
8.4.1.2 Foreign Production (Imports). Table 8-22
shows the imports of steel mill products to the U.S. between
1983 and 1992.* Imports increased from 17.1 million tons
in 1983 to 26.2 million tons in 1984, an increase of 53.3
percent. From 1984 to 1991, the quantity of imported steel
mill products dropped by 39.6 percent, falling to a low of
15.8 million tons in 1991. Imports rose again from 1991 to
1992, reaching a level of 17.1 million tons. As shown, in
1992, the largest categories of U.S. imported steel mill
products were sheets and strip (44.1 percent); ingots,
blooms, billets, slabs, etc. (14 percent); plates
(9.4 percent); and pipe and tubing (9 percent).
Table 8-23 shows imports of steel mill products by
country of origin from 1988 to 1992.67 Throughout this
period the U.S. imported the largest share of steel mill
products from Europe, Asia, and Africa—primarily due to
imports from the European Economic Community (EEC) and
Japan. However, U.S. dependence on imports from Canadian
sources is increasing. Imports from Canada increased by
33.4 percent since 1988 to 4.2 million tons in 1992. At the
same time, Canada increased its share of total U.S. imports
from 15.2 percent in 1988 to 24.8 percent in 1992.
Table 8-24 shows imports of steel mill products by U.S.
customs district for 1992.M Importation of steel mill
products through customs districts in the Great Lakes and
along the Canadian border accounted for 38.3 percent of
total U.S. imports in 1992. Customs districts within the
Gulf Coast and along the Mexican border accounted for 22.8
percent of total U.S. steel mill product imports in 1992
followed by Pacific Coast custom districts (21.5 percent),
8-43
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8.4.2 Consmmpt j-Qfl
8.4.2.1 Domestic Consumption. Domestic consumption,
or apparent U.S. consumption, is calculated as U.S. shipment
minus exports, plus imports. Table 8-25 shows domestic
consumption of steel mill products from 1983 to 1992.
Domestic consumption of steel mill products increased by
13.9 percent over this period from 83.5 million tons in 1983
to 95 million tons in 1992. Sheets and strip consistently
accounted for the largest percentage of annual U.S.
consumption followed by bars and tool steel, shapes and
plates, and semi-finished products. In 1992, these four
product groups accounted for 88.2 percent of total U.S.
consumption of steel mill products. Rails and wire products
together accounted for roughly 2 percent of total
consumption in 1992.
Table 8-25 also shows the import share of U.S. total
consumption during the period 1983 through 1992. The share
of imports in domestic consumption declined slightly from
20.5 percent in 1983 to 18 percent in 1992. Import
penetration,, as reflected by this share, reached a high of
26.5 percent in 1984. In other words, foreign sources
accounted for over one-quarter of U.S. consumption of steel
mill products in that year. The share of imports in
domestic consumption slowly fell from 1984 to its 1992 level
of 18 percent.
8.4.2.2 Foreign Consumption (Exports). Table 8-26
provides U.S. exports of steel mill products for 1983
through 1992.n From 1983 to 1990, U.S. exports of steel
mill products rose by 284 percent—from 1.2 million tons to
4.3.million tons. Exports rose again to 6.3 million tons in
8-46
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8-47
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TABLE 8-26,
EXPORTS OF STEEL MILL PRODUCTS (net tons):
1983-199273
•1 'II as^=gsss^^^=^^^^*=
Steel Mill Products;
Ingots, blooms, billets,
slabs, etc.
Wire rods
Structural shapes and
pilings
Plates
Rails and accessories
Bars and tool steel
Pipe and tubing
Wire and wire products
Tin mill products
Sheets and strip
TOTAL 1
Ingots, blooms, billets
slabs, etc.
Wire rods
Structural shapes and
pilings
Plates
Rails and accessories
Bars and tool steel
Pipe and tubing
Wire and wire products
Tin mill products
Sheets and strip
_m_1^ _ "^™ -
1983
102,754
6,137
49 ,-116
101,982
20,071
170,052
257,952
27,259
249,556
213,698
,198,577
1988
61,430
10,161
61,922
119,393
13,647
141,460
250,390
36,164
430,699
943,357
2,068,623
1984
73,536
8,646
32,403
88,184
19,078
133,595
207,426
27,968
162,020
227,557
980,414
1989
390,816
36,094
169,678
630,695
17,035
251,157
442,996
31,344
217,822
2,390,306
4,577,944
1985
89,708
4,740
42,261
82,988
13,430
99,096
199,319
25,037
163,904
211,491
931,976
1990
522,326
106,633
314,825
458,335
67,794
445,049
470,783
70,052
175,693
1,671,090
4,302,581
1986
58,885
5,876
37,426
69,565
13,132
81,225
121,050
34,579
279,473
227,946
929,156
1991
699,087
166,457
415,232
731,441
41,216
580,371
753,117
89,416
193,610
2,675,936
6,345,883
" -^^^=
1987
73,543
8,217
65,711
85,211
15,755
121,868
152,156
35,746
236,628
333,684
1,128,519
1992
422,915
70,847
304,517
409,413
26,977
567,095
636,468
90,139
343,665
1,415,549
4,287,582
8-48
-------
1991, but fell back to 4.3 million tons in 1992. As Table 8-26
shows, in 1992, sheets and strip (33 percent), pipe and tubing
(14.8 percent), and bars and tool steel (13.2 percent) were the
largest categories of U.S. steel mill product exports.
Table 8-27 presents U.S. exports of steel mill products by
country of destination for 1992.74 Latin America (41.8 percent),
Canada (32.9 percent), and Asia (16.7 percent) are the largest
importers of U.S. exported steel mill products.
8.5 CONTROL COST, ENVIRONMENTAL IMPACTS, AND COST
EFFECTIVENESS
The emission control costs used as inputs into the economic
impact model are presented in this section. The environmental
impacts associated with the proposed regulation and the cost
effectiveness are also shown.
8.5.1 Model Plants
The model plants representing the industry include six
different types: continuous coil, push-pull coil, continuous
rod/wire, continuous tube, batch, and acid regeneration
facilities. Within these types, model plants have been
developed for three different size categories including small,
medium, and large. Table 8-28 lists the model plants types, the
number of plants, lines of each type, and the fraction of
facilities currently meeting MACT.
8.5.2 Estimated Environmental Impacts
Table 8-28 reports estimates of annual emission reductions
associated with the proposed regulation. Under current controls,
reductions from baseline HC1 emissions are estimated to be 8,336
Mg per year. These emission reductions were calculated based on
the assumption that sufficient controls are applied to bring each
model plant into compliance with the proposed regulation, or MACT
floor of 10 ppmv or 97.5 percent control efficiency. The total
HC1 emission reductions resulting from regulation of steel
8-49
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8-51
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pickling facilities are estimated to be 8,358 Mg of HCl per
year.
8.5.3 Control Cost Estimates
The cost estimates represent the incremental cost to
bring each model plant from the existing control level or
baseline conditions to the control level defined by the
proposed regulation. Only one regulatory alternative, the
MACT floor, has been considered. Nationwide total cost of
controls and the cost for each type of model plant facility
are shown in Table 8-29. The national control costs
relating to capital equipment for new and upgraded scrubbers
are estimated to be approximately $20.0 million, while
annualized costs are $7.1 million. These cost estimates are
based upon 1996 prices.
8.5.4 Cost Effectiveness
Economic cost effectiveness is computed by dividing the
annualized economic cost by the estimated emission
reductions. In this instance, annualized control costs are
being used as a proxy for the annual economic cost of the
regulation. Estimates of cost effectiveness are shown in
Table 8-29. The proposed regulation has a calculated total
cost effectiveness of $853 per Mg of total HAP reduced per
year. Cost effectiveness per model plant type range from
$241 per Mg of HAP reduced to $121,515 per Mg of HAP
reduced.
8.6 ECONOMIC IMPACT ANALYSIS
This section describes the economic impact analysis
conducted for the steel pickling industry.
8.6.1 Methodology
A comparison of the cost of emission controls to the
average total cost of production and average sales revenues
was conducted to give an indication of the impact this
regulation will likely have on the domestic steel industry.
8-52
-------
Table 8-29
Steel Pickling Industry
Control Costs and Emission Reductions
jj— — — — — ^— — ujan-Ma^MIMgMa
Model Pint Type
Continuous Coil ,
Small
Continuous Coil,
Medium
Continuous Coil, Large
Push- Pull Coil, Small
Push-Pull Coil, Medium
Push-Pull Coil, Large
Continuous Rod/Wire,
Small
Continuous Rod/Wire,
Medium
Continuous Rod/Wire,
Large
Continuous Tube, Small
Continuous Tube, Large
Batch, Small
Batch, Medium
Batch, Large
Acid Regeneration,
Small
Acid Regeneration,
Medium
Acid Regeneration,
Large
Nationwide Total
••OBEESSsssEnaB
OpfelCoib
(dotUn)
$3,390,511
2,157,667
5,584,580
245,380
0
0
431,252
1,707,834
753,522
152,040
552,316
2,556,534
1,547,027
552,316
269,203
0
187,844
$20,088,026
AaaulCoiU
(doOin)
$1,038,051
648,452
1,929,403
92,705
0
0
203,324
788,575
.316,386
121,515
222,952
836,615
468,512
211,873
127,852
0
101,204
,$7,107,417
as^^^sss^s^sssss:^^
HCI Removed
(Mg/yr)
691
651
728
4.6
0
0
711
2,063
1,315
1
48
424
848
600
199
0
52
8,336
^ -••- •
Coct
Effectiveness
$1,502
996
2,650
20,153
Indeterminate
Indeterminate
286
382
241
121,515
4,644
1,973
552
353
642
Indeterminate
1,946
$853
8-53
-------
Since all steel companies do not conduct steel pickling
activities, this regulation will directly affect only those
companies that operate steel pickling facilities or obtain
pickling services from firms that do conduct steel pickling
activities. The analysis was conducted on a model plant
basis. '
The cost-to-sales ratio is an approximation of the
percentage price increase necessary for a facility to
recover the cost of emission controls. The increase in
price of pickled steel products resulting from this
regulation is a function of demand and supply conditions and
the per unit cost of control for the marginal facility
producing the product after regulation. Since the cost to
marginal facility is unknown a range of potential per unit
costs was used.
Cost-to-sales ratios and the percent increase in
production cost statistics were calculated using two
alternative per-unit cost estimates. The first estimate was
calculated by dividing the cost of the regulation by the
total production for all model plants
regardless of whether the facility
within
will 1
a category
install controls. If any unit
likely to be the marginal unit
5 required, to
of production is equally
, then this estimate is a
point estimate of the shift in the supply curve and the
resulting price increase. The second per unit cost estimate
was calculated by dividing the cost of control by the total
production for model plants that will be required to install
controls within each category. This estimate is the higher
of the two estimates and represents a worst case estimate
for the price increase. Together these estimates represent
a range of potential impacts. A cost-to-sales ratio
exceeding one percent is indicative of a potentially
significant economic impact.
All costs are stated in 1996 prices. The per-unit
prices of different types of steel were taken from the
8-54
-------
March 29, 1996 issue of American Metals Market.16 The
prices range from $365 to $852 per ton. Cost of production
was estimated to be approximately 93 percent of price.77
Table 8-30 reflects the per-unit control cost for all
facilities and for facilities that will be required to
install controls. The emission control cost per ton of
steel produced varies from approximately $ 0.05 to $4.40
for small push-pull coil and batch small model plants,
respectively.
8.6.2 Results
The cost-to-sales ratios and percent increase in
production cost ratios are shown on Table 8-31.
Nationally, the control costs for the steel pickling
industry are 0.0329 percent of sales revenues and represent
a 0.0354 percent increase in the cost of production. For
those facilities that will be required to install controls
to meet the MACT standard, the costs represent 0.0515
percent of revenues and an increase of 0.0554 percent in the
cost of production. The costs for individual model plants
vary from a low of 0.0107 to a high of 0.7888 percent
increase in the cost of production and from 0.0099 to 0.7336
percent of revenues for all facilities in the industry. The
costs range from 0.0231 to 1.1481 percent increase in the
cost of production and from 0.0214 to 1.0678 percent of
sales for the facilities required to install emission
controls and incur costs. The cost-to-sales ratios and
percent increase in the cost of production are well below
1.0 percent for the industry as a whole and for the portion
of the industry required to incur control costs as a result
of this regulation. Model plant costs represent the cost to
individual facilities, and these costs approximate 1.0
percent or are less than 1.0 percent of sales and of the
cost of production for all model plants. The magnitude of
the costs relative to production cost of the industry and
sales revenues leads to a conclusion that this standard will
8-55
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not significantly adversely impact firms in the steel
pickling industry. The results also indicate that a more
sophisticated economic impact analysis is not required. No
plant closures are anticipated nor significant employment
losses. Significant regional impacts are also not expected
8.7 SMALL BUSINESS IMPACTS
The Regulatory Flexibility Act (5 U.S.C. 601 et sea.)
requires the EPA to consider potential impacts of proposed
regulations on small business "entities" and that special
consideration be given to the effects of all proposed
regulations on small business entities. The Regulatory
Flexibility Act (RFA) dictates that a determination be made
as to whether the subject regulation will have a significant
impact on a substantial number of small entities.
The Small Business Regulatory Enforcemert Fairness Act
of 1996 (SBREFA) Subtitle D extends the requirements of the
RFA and requires the EPA to establish a review panel. This
small entity stakeholder process must involve small entity
stakeholders, the Small Business Administration (SBA), and
the Office of Management and Budget prior to proposing any
rule that has a significant impact on small entities.
Subtitle E of the SBREFA establishes opportunity for
Congress to review and potentially disapprove nonmajor rules
promulgated on or after March 29, 1996. This rule, which is
nonmajor, will be submitted to Congress in accordance with
these requirements upon promulgation.
In order to meet the requirements of the RFA and
SBREFA, small business impacts analysis is conducted. The
small business categorization and small business impacts are
determined in order to assess whether or not significant
small business impacts will exist in the steel pickling
industry as a result of the proposed regulation.
8-58
-------
8.7.1 ?mall Business Categorization
Production of steel and steel products are classified
into several four digit Standard Industrial Classification
(SIC) codes within the Major Group 33, Primary Metal
Industries. The small business size standard within the
Primary Metal Industries classification producing steel or
steel products varies from 500 to 1000 employees (13 CFR
121). Neither steel pickling nor acid regeneration are
assigned to a specific individual four digit SIC code.
Steel pickling and acid regeneration represent only one
phase in the production of some steel products. Since only
a small number of employees are required to operate a steel
pickling facility or pickling section of a steel plant, a
small business size standard of fewer than 100 employees is
being used for the steel pickling industry.
8.7.2 Small Business Impacts
Only four companies in the steel pickling industry have
fewer than 100 employees and would be categorized as small.
Of these four,, one company is expected to meet the standard.
Two companies are projected to be nonmajor sources based on
an estimate of emissions using the ESCO Engineering model
along with information supplied by these firms. It is
anticipated that these three firms will not be adversely
impacted. The remaining small firm employs a scrubber that
may meet the emission limitation. If this firm incurs
emission control costs, the costs would likely relate to
upgrading existing equipment or improved maintenance
practices. Based on the preceding information, this
regulation will not significantly adversely impact small
businesses engaged in steel pickling and acid regeneration.
8-59
-------
8.8 REFERENCES
2.
3,
4,
6.
7,
8,
10.
11.
12.
13.
14.
15.
U.S. Environmental Protection Agency.
Collection Request (ICR) Database. 1993.
Ref. 1.
Ref. 1.
American Iron and Steel Institute (AISI) .
Statistical Report. 1992.
Information
Annual
Steel and
Standard & Poor's Industry Surveys. 1992
Heavy Machinery: Basic Analysis, p. S-25.
Ref. 5.
Ref. 5.
Hogan, William T. 1987. Miriimills and Integrated
Mills: A Comparison of Steelmaking in the United
States. Lexington, Mass .: D . C . Heath and Company.
American Metal Market. June 27, 1989. "Heidtman Steel
breaks ground for its fourth pickling facility."
97(124):3.
Certain Flat-Rolled Carbon Steel Products from
Argentina, Australia, Austria, Belgium, Brazil, Canada,
Finland, France, Germany, Italy, Japan, Korea, Mexico,
the Netherlands, New Zealand, Poland, Romania, Spain,
Sweden, and the United Kingdom: Volume II:
Information Obtained in the Investigation. (Publication
2664). U.S. International Trade Commission. August
1993. p. 20.
Ref. 10, Tables 17 and 18.
Ref. 10, Table 29.
Chemical Week. June 16, 1983. "HC1 as complex as ever:
tightness can't last." 152 (23) :67-68.
Ref. 10, Table 29.
American Iron and Steel Institute; Annual Statistical
Report, 1992. Cost per hour. National Research
Council. The Competitive Status of the U.S. Steel
Industry.
8-60
-------
16. National Research Council. The Competitive Status of
the U.S. Steel Industry: A Study of the Influences of
Technology in Determining International Industrial
Competitive Advantage. Washington DC, National Academy
Press. 1985.
17. U.S. Department of Labor, Bureau of Labor Statistics,
SIC 33. January 1990-1993.
18. Ref. 13.
19. Lancaster, Kelvin J. A New Approach to Consumer
Theory. Journal of Political Economy. 74:132-157.
1966.
i
20. American Iron and Steel Institute (AISI). Annual
Statistical Report, 1992. Table 12.
21. Ref. 4, Table 12.
22. Ref. 10, pp. 1-48 to 1-49.
23. Ref. 20.
24. Ref. 16.
25. Standard & Poor's Industry Surveys. 1992. Steel and
Heavy Machinery: Basic Analysis, p. S-18.
26. Ref. 25.
27. Ref. 25.
28. Ref. 25.
29. Ref. 25, p. S-19.
30. Ref. 29.
31. Ref. 29.
32. Ref. 29.
33. Ref. 29.
34. Lima, Jose Guilerme de Heraclito. Restructuring the
U.S. Steel Industry: Semi-finished Steel Imports,
International and U.S. Adaptation. Boulder, CO.
Westview Press. 1991. Table 4.5, p. 67.
35. Ref. 10, p. 1-168.
8-61
-------
36. Ref. 10, p. 1-167.
37. Ref. 10, p. 1-168.
38. Ref. 10, p. 1-168.
39. Ref. 10, p. 1-168.
40. Mueller, Hans. 1984. Protection and Competition in
the U.S. Steel Market: A Study of Managerial Decision
Making in Transition (Monograph No. 30). Murfreesboro,
TN: Business and Economics Research Center, Middle
Tennessee State University.
41. Ref. 10, p. 1-168.
42. American Metal Market. 1993. Metal Statistics: 1993.
New York. Chilton Publications.
43. U.S. Department of Commerce. Census of Manufactures.
Industry Series: Concentration Ratios in
Manufacturing. Washington, D.C., Government Printing
Office. 1991
44. U.S. Department of Commerce. 1987 Census of
Manufactures Industry Series: Type of Organization. ,
Washington, DC, Government Printing Office. February
1991.
45. U.S. Department of Commerce. Statistical Abstract of
the U.S. Washington, DC, Government Printing Office.
Table No, 826. 1992.
46. Ref. 44.
47. Ref. 45.
48. Ref. 44.
49. Ref. 45.
50. Behrens, Robert H. f!rtTmne-reial Loan officer's Handbook.
Boston, Banker's Publishing Company. 1985.
51. Ref. 44.
52. Steinhoff, D., and J.F. Burgess. Small Business
Management Fundamentals. 5th ed. New York, McGraw-
Hill Book Company. 1989.
53. Ref. 44.
8-62
-------
54. Ref. 45.
55. Ref. 45.
56. Ref. 52.
57. Ref. 52.
58. Ref. 1.
59. Ref. 1.
60. Steel: Semiannual Monitoring Report (Publication 2655).
U.S. International Trade Commission. June 1993. Table
22.
61. American Metal Market. 1993. Metal Statistics, 1993.
New York: Chilton Publications.
62. Ref. 1.
63. Ref. 60.
64. Ref. 4, Table 11.
65. Ref. 4, Table 11.
66. Ref. 4, Table 19.
67. Ref. 4, Table 21.
68. Ref. 4, Table 23.
69. Ref. 4, Table 19.
70. Ref. 4, Table 21.
71. Ref. 4, Table 23.
72. Ref. 4, Table 15.
73. Ref. 4, Table 15.
74. Ref. 4, Table 17.
75. Ref. 4, Table 17.
76. American Metals Market, March 29, 1996, p. 6.
77. Memo from Turner, J., RTI to Chappell, L. and Maysilles,
J. EPA/OAQPS. Source of Steel Prices and Cost Treatment
of Acid Regeneration Plants. August 13, 1996.
8-63
-------
-------
APPENDIX A.
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
-------
-------
APPENDIX A.
EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
The purpose of this study was to provide data to
support the development of the proposed national emission
standard for hazardous air pollutants (NESHAP) for steel
pickling - HCl process. To accomplish the objectives of
this program, technical data were gathered on the following
aspects of the pickling industry: (1) the operation of five
types of pickling facilities (continuous coil, push-pull
coil, continuous rod and wire, continuous tube, and batch),
acid regeneration plants, and storage tanks, (2) the release
and controllability of hazardous air pollutants (HAPs)
emitted into the atmosphere from the above emission points,
and (3) the types and costs of demonstrated emission control
technologies. The bulk of the information was gathered from
the following sources:
1. Technical literature,
2. Plant visits,
3. Questionnaires sent to industry,
4. Industry representatives,
5. State and regional air pollution control agencies,
and
6. Equipment vendors.
Significant events relating to the evolution of the
background information document are itemized in Table A-l.
-------
TABLE A-l. EVOLUTION OF THE BACKGROUND INFORMATION DOCUMENT
Company, consultant, or agency/location
Hutchinson Technology, Hutchinson, MN
Worthington Steel Company. Porter, IN
I/N Tek Steel Company, New Carlisle, IN
Gulf States Steel Company, Gadsden, AL
12/20/91
1/1/92
1/15/92
Nucor Steel Company, Crawfordsville, IN
Inland Steel Company, East Chicago, IN
USS Company, Fairfield, AL
Weirton Steel Company, Weirton, WV
Cargill Company, Nashville, TN
1/22/92
Kasle Steel Company, Dearborn, Ml
1/30/92
2/4/92
2/25/92
3/1/92
Inland Steel Company, East Chicago, IN
Worthington Steel Company, Porter, IN
jon
MN
N
IN
,IN
AL
IN
/
est Leechburg, PA
IN
Nature of action
Report of company test
Report of company test
Report of company test
Report of company test
Report of company test
Report of EPA test
Report of company test
Report of company test
Report of company test
Report of company test
Report of company test
Report of plant visit
[Report of company test
Valley City Steel Company, Valley City. OH
U.S. Environmental Protection Agency (EPA), Research
6/1/92 Triangle Park, NC
California Steel Industries, Fontana, CA
Acme Steel Company, Riverdale, IL
Bailey Engineers, Fairfield, AL
National Wire Products, Baltimore, MD
USS Posco, Pittsburg, CA
6/1 /92|Valley City Steel Company, Valley City, OH
National Steel Corporation, ECORSE. Ml
U.S. EPA, Research Triangle Park, NC
[Report of company test
Report of company test
Report of company test
Report of company test
Report of company test
Report of company tests
Initial source category list
report
Report of company test
Report of company test
Cargill Company, Nashville, TN
Carpenter Company, Reading, PA
Information collection
request (ICR) distribution
to more than 100
companies
Report of company test
Report of company test
Magnetics International Company, Burns Harbor, IN p
I/N Tek Steel Company, New Carlisle, IN
Report of company test
Mt. Joy Wire Company, Mount Joy, PA
Report of company test
8/8/92 Kasle Steel Company, Dearborn, Ml
Report of plant visit
8/20/92 LTV Steel Company, East Chicago, IN
8/20/92 WCI Steel Company, Warren, OH
2 Acmi
Report of plant visit
8/21/92 National Steel Company, Ecorse, Ml
8/22/92
Worthington Steel Company, Porter, IN
Report of plant visit
Report of plant visit
teport of plant visit
Report of plant visit
9/2/92
Valley City Steel Company, Valley, City, OH
9/16/92
9/23/92
USS Posco, Pittsburg, CA
teport of plant visit
teport of plant visit
UOO ruoviu, rinow>mM, **" ^__^_————^———
ESCO Engineering Company. Kingsville, Ontario, CANADA |Report of site visit
A-2
-------
Date
10/1/92
1/14/93
1/21/93
2/26/93
3/2/93
5/10/93
5/21/93
7/1/93
7/1/93
3/31/94
6/1/94
6/1/95
2/22/96
2/28/96
3/14/96
3/15/96
4/2/96
4/1 1 /96
11/27/96
12/11/96
Company, consultant, or agency/location
WCI Steel Company, Warren, OH
USS - Gary, Gary, IN
Goodyear Tire and Rubber Company, Raridleman, NC
/N Tek Steel Company, New Carlisle, IN
Goodyear Tire and Rubber Company, Randleman, NC
Magnetics International Company, Burns Harbor, IN
Bailey Engineers, Fairfield, AL
Acme Steel Company, Riverdale, IL
Worthington Steel Company, Porter, IN
Inland Steel Company, East Chicago, IN
Magnetics International Company, Burns Harbor, IN
National Galvanizing, Monroe, Ml
Dept. of Environmental Protection, FL
Air Pollution Control Div., CO
Dept. of the Environment, MD
Dept. of Public Utilities, Toledo, OH
Dept. of Environmental Protection, KY
Natural Resources Conservation Commission
USS-POSCO, Pittsburg, CA
Valley City Steel, Valley City, OH
Nature of action
Report of EPA test
Report of company test
Report of company test
Report of company test
Report of plant visit
Report of company test
Report of company test
Report of EPA test
Report of EPA test
Report of company test
Report of company test
Report of company test
Comments on Presumptive
MACT
Comments on Presumptive
MACT
Comments on Presumptive
MACT
Comments on Presumptive
MACT
Comments on Presumptive
MACT
Comments on Presumptive
MACT
Report of company test
Report of company test
A-3
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
-------
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
This appendix consists of a reference system (index)
that is cross-linked with the October 21, 1974, Federal
Reaister (39 FR 37419) containing the Agency guidelines
concerning tne preparation of environmental impact
s?atementl Table B-l contains the index. This index can
be uSedtS identify sections of the document that contain
datHnd information germane to any portion of the Federal
Reaister.
-------
TABLE B-l. CROSS-INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency guidelines for
preparing regulatory
action environmental
impact statements (39 FR
37419)
1. Background and
summary of
regulatory
alternatives
Summary of the
regulatory
alternatives
Statutory basis for
proposing standards
Relationship to
other regulatory
agency actions
Industries affected
by the regulatory
alternatives
Specific processes
affected by the
regulatory
alternatives
2 . Regulatory
alternatives
Control techniques
Regulatory
alternatives
3 . Environmental
impact of the
regulatory
alternatives
Location within background informatiol
document 1
The regulatory alternatives 1
(considered as control options for 1
this regulation) from which standards!
will be chosen for proposal are 1
summarized in Chapter 1, Section 1.1,1
and are discussed more fully in 1
Chapter 5, Section 5.3. 1
The statutory basis for proposing 1
standards is summarized in Chapter 2,1
Section 2.1. 1
The relationships between EPA and 1
other regulatory arency actions are 1
discussed in Chapter 3 . 1
The industries affected by the 1
regulatory alternatives are discussed!
in Chapter 3 , Sections 3 . 1 and 3.5, 1
and in and Chapter 8, Sections 8.2 an!
8.3. 1
The specific processes and facilities!
affected by the regulatory 1
alternatives are summarized in Chapte!
1, Section 1.1. A detailed technical 1
discussion of the processes affected 1
by the regulatory alternatives 1
(control options) is presented in 1
Chapter 3 , Sections 3 . 2 and 3.3. |
Alternative control techniques are 1
discussed in Chapter 4 . 1
The various regulatory alternatives 1
(as control options) are defined in 1
Chapter 5, Section 5.3. 1
B-2
-------
Agency guidelines for
preparing regulatory
action environmental
impact statements (39 FR
37419) • '
vocation within background information
document
Primary impacts
directly
attributable to the
regulatory
alternatives
The primary impacts on mass emissions
and ambient air quality due to
alternative control systems are
discussed in Chapter 6, Section 6.2
Secondary or
induced impacts
Secondary impacts for the various
regulatory alternatives are discussed
in Chapter 6, Sections 6.2 and 6.3
4. Other
considerations
The potential adverse impacts
associated with the regulatory
alternatives in terms of additional
commitments of energy, waste disposal,
and wast©water treatment are included
in Chapter 6, Sections 6.1 and 6.2.
Potential socioeconomic and
inflationary impacts are discussed in
Chapter 8.
B-3
-------
-------
APPENDIX C
ENVIRONMENTAL IMPACTS ESTIMATION MODEL
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-------
APPENDIX C
ENVIRONMENTAL IMPACTS ESTIMATION MODEL
Environmental impacts, including emission reductions
and energy, solid waste, and wastewater increases, were
estimated from the model plants described in Chapter 5 of
this document. Costs were also estimated from these models
after individual scrubber costs were estimated from methods
in the OAQPS Control Cost Manual.1 The 17 impacts models
are based on a spreadsheet program that uses successive
•columns to estimate required values for the rows
representing the models. The calculations used xn each
column are described below. Columns not named were not used
in the estimation procedure. A nomenclature table and an
abbreviated flow sheet for impacts are shown following the
description, followed by an expanded flow sheet showing
steps used in the impacts model and the methods used with
the steps.
Column A, Model Plant Name
Example: Continuous Coil, Small (CCS).
Column B, Number of Plants [NP]
Taken from information collection request (ICR)
analysis, e.g., 12 for the CCS model.
Column C, Number of Lines [NJ
Taken from ICR analysis, e.g., 18 lines for the 12
plants of the CCS model.
Column D, HC1 Concentration, Uncontrolled [CHCUjnCippmv]
Taken from ICR analysis, e.g., 835 ppmv for the CCS
model.
Column E, Uncontrolled Emission Rate [€„<;,„«., Ib/hr]
Taken from the model plant descriptions in Chapter 5.
Gas flows must be summed for models with more than one
scrubber. Temperatures are 100 °F, 90 °F, or 190 °F
depending on the model. Estimated at 101 Ib/hr for
the CCS model from:
HCluoc
1X106
359
(46 0+3 2) °F
(460+100)°F
60min
where: Q = Gas flow rate, acfm
MWHa = Molecular weight of HC1, 36.5
Column G, Annual Plant Operating Time [T, hrs]
Taken from ICR analysis, e.g., 6,300 hrs for the CCS
model.
-------
Column H, Uncontrolled Annual Plant Emissions [E^, Mg/yr]
Estimated at 3,455 Mg/yr for the CCS model from:
T x
j. x
ton
0.9072 Mg
—
where:
= Storage tank emissions, Mg/yr
Column I, Controlled Lines [L^, %]
Taken from ICR analysis and as reported in Chapter 5,
e.g., 15 controlled lines/18 total lines = 83 percent
for the CCS model.
Column J, Control Efficiency [77, %.]
Taken from ICR analysis and as reported in Chapter 5,
e.g., 93 percent for the CCS model.
Column K, Baseline Emissions From the Model Plant
[eB, Mg/yr]
Estimated from the percentages of controlled and
uncontrolled lines and written to account for mixtures
of facilities having scrubbers with efficiencies above
and below the MACT floor level. In the expression
below, a triple IF statement is used to distinguish
among facilities having 100 percent of lines
controlled, facilities with control efficiency greater
than 97.5 percent, and models for which all facilities
report meeting MACT emission levels. If all lines are
controlled, scrubber efficiency is greater than 97.5
percent, and all facilities meet MACT, baseline
emissions are the same as MACT floor emissions.
Otherwise emissions are estimated as uncontrolled
emissions times one minus the average efficiency of
scrubbers not meeting 97.5 percent or as uncontrolled
emissions times the fraction of controlled lines at
their average efficiency plus the fraction of
uncontrolled lines at zero efficiency. For the CCS
model emissions are 777 Mg/yr from:
where: E ~ MACT floor emissions, Mg/yr
= Fraction of facilities reporting meeting
MACT emission levels
= Average efficiency of scrubbers not meeting
the MACT floor, fraction
Column L, Model Plant Gas Flow Rate [Q, acfm]
C-2
-------
6B - -uj. v-"con
= IF (Lcoa = 100, JF (t| > 97.5, JF
•L,
- I/
(1 -
icon / « v
x Too xr " 100) +
•'con
oo
\
1QO/
T -
^
Taken from ICR analysis and as reported in Chapter 5,
e.g., 22,500 acfm. Gas flows must be summed for models
with more than one scrubber .
Column M, MACT Floor Scrubber Outlet Concentration
10 ppmv or the value obtained for a
scrubber efficiency of 97.5 percent if the outlet^
concentration would be higher than 10 PP*v.^ F^cthef,ol
latter case, the outlet concentration for the CCS model
is estimated as 21 ppmv from:
(L - 0.975)
Column N, Emissions After MACT Floor Implementation
Estimated/S386 Mg/yr for the CCS models from:
HClout
x
x
1 X106 359
(460 + 32)
X ~
5 x
2 , 0 0 0
0.9072 + 0.0275 X 1
where: 0.0275 = Fraction of uncontrolled storage tank
emissions after control
Column P, Unit Scrubber Capital Cost [TCI, $]
Taken from scrubber costing (see Appendix D of this
document). Costs must be summed for models with more
than one scrubber. For the CCS models the cost is
$355,618.
Column Q, Capital Cost Required to Meet MACT [TCI^, $]
Controlled lines are expected to require 40 percent of
the cost of a new scrubber for improvements. Costs are
C-3
-------
escalated to 1996 with a factor of 1.061. Estimated as
$3,390,511 for the CCS models from:
= ((TCI + TCIvent ) X
X 0.4) X 1.061
+ TCIvenc)
where: TCIvcot = Total capital investment for vent system
piping, $
= Unit capital cost for upgraded scrubbers,
$
= Number of new scrubbers required to meet
MACT
= Number of upgraded scrubbers required to
meet MACT
Column R, Unit Scrubber Annual Cost [TACS, $/yr]
Taken from scrubber costing. Costs must be summed for
models with more than one scrubber. For the CCS model
the Cost is $100,690.
Column T, Annual Cost to Meet MACT [TAC^^., $/yr]
Lines without scrubbers require all annual costs; lines
with existing scrubbers require an upgrade and
additional operating and maintenance costs, which are
taken as 40 percent of the cost of a new scrubber.
Estimated as $1,038,050 for the CCS models from:
x N
UPG
0.4 X
1-061
TACvenc)
where: TACvent = Annual cost for tank vent piping, $/yr
TACupQ = Annual cost for upgraded scrubbers,
$/yr
ACW = Solids disposal cost, $/yr
Column W, Plant Production Capacity for plants requiring new
or upgraded scrubbers [CAPA, t/yr]
Taken from ICR analysis, e.g., 514,000 t/yr for the CCS
model.
Column X, Plant Utilization Rate [UT, %]
Taken from ICR analysis, e.g., 84 percent for the CCS
model.
C-4
-------
Column Y, Solids Disposal from the scrubber System
[W, Mg/yr]
Taken from ICR analysis estimates of 0.62 percent
solids in the scrubber water and 1.44 gal of scrubber
water per 1,000 acf of gas. Estimated as 331 Mg/yr for
the CCS model from:
where: ACW = Solids disposal cost, $/yr
Column Z, Solids Disposal Cost [ACW, $/yr]
Estimated as $79,025/yr for the CCS model using a
disposal cost of $239/ton and:
1,000
X 0 .0062 X60
2,000
x 1 • 4A x 0 . 0062 x 60 x TapB x 239
'DFO 1,000
'apG 2,000
x 0 . 2
where: QNEW
QUPG
= Average gas flow rate for new scrubbers, acfm
= Average gas flow rate for upgraded scrubbers,
acfm
= Annual operating time for new scrubbers,
hrs/yr
= Annual operating time for upgraded scrubbers,
hrs/yr
Column AA, Capital Cost for Tank Vent Piping [TCIveot, $]
Estimated from 400 ft of pipe per facility at $31/ft
(updated from R. S. Means Construction Cost Data ) ,
e.g., $12,400 for the CCS model.
Column AB, Annual Cost for Tank Vent Piping [TACvent, $/yr]
Taken as 15 percent of the capital cost for the tank
vent piping, e.g., $l,860/yr for the CCS model.
Column AE, Energy Use [P, kWh/yr]
Taken from analysis of the ICR and results of the
scrubber program. Estimated at 1,508,614 kWh/yr for
the CCS model from:
C-5
-------
"
PUPG x
where: P
HEW ~ Annual energy use for new scrubbers, kWh/yr
= Annual energy use for upgraded scrubbers,
kWh/yr
Column AF, Scrubber Effluent Quantity [QEF, m3/yr]
Taken from analysis of the ICR and results of the
scrubber program. Estimated at 68,650 m3 for the CCS
model from:
QSF Q
EFNEW
x
"
\ UPG
where.:
QEFNEW
QEFUPO
= Effluent quantity for new scrubbers, m3/yr
= Effluent quantity for upgraded scrubbers,
m3/yr
Column AG, Annual Emissions Reduction [RED, Mg/yr]
Taken as baseline emissions minus MACT floor emissions
(0 for negative quantities), e.g., 691 Mg/yr for the
CCS model from:
RED = JF(en - E,
'MACT
0, o, es -
Column AH, Number of Scrubbers per Line [NSL]
Taken from ICR analysis, e.g., 1 for the CCS model.
Column AL, Storage Tank Emissions [E,^, Mg/yr]
Taken from ICR analysis, which showed an average of
0.39 x 10"6 tons of HC1 emitted per ton of steel
produced for continuous coil and push-pull coil (11.19
x 10"6 for continuous wire, rod and tube and batch) .
For acid regeneration plants, 0.63 t/yr are emitted at
each facility. Estimated as 1.83 Mg/yr for the CCS
models from:
^tan* = CAPA x
100
X 0.39 x 10-6 x ND X 0.9072
Column AX, Number of Facilities Reporting Meeting MACT
Emission Levels [N^er]
Taken from ICR analysis, e.g., 5 for the CCS model.
C-6
-------
Column AY, Fraction of Facilities Reporting Meeting MACT
Emission Levels [f^cr]
to Np, e.g., 0.417 for
Estimated as the ratio of
the CCS model from:
-MACT
_ -"AHCT
N0
Column AZ, Control Efficiency of Facilities Not Meeting MACT
[I/NM, fraction]
Estimated from ICR analysis, e.g., 0.79 for the CCS
model.
Column BA, Production Cost Increase [PC, $/t]
Increase in cost of producing steel due to addition of
new or upgraded control systems. Estimated as $0.343/t
for the CCS model from:
PC =
TAC,
MACT
CAPA X
UT
100
X N,
FAC
where: NFAC = Number of facilities requiring new or
upgraded scrubbers
Column BC, Production Cost Increase Percent [PCP, %]
Increase in cost of producing steel, as a percent, due
to addition of new or upgraded control systems.
Estimated as 0.0747 percent for the CCS model based on
a steel cost of $460/t (for steel strip) from:
PCP =
' PC
460
x 100
Column BE, New Scrubbers Required to Meet MACT [
Estimated from ICR analysis, e.g., 8 for the CCS model.
Column BF, Upgraded Scrubbers Required to Meet MACT [
Estimated from ICR analysis, e.g., 2 for the CCS model.
Column BG, Unit Capital Cost for Upgraded Scrubbers
C-7
-------
Estimated from ICR analysis, e.g., $301,896 for the CCS
model.
Column BH, Average flow rate for new scrubbers [QNEW, acfm]
Estimated from ICR analysis, e.g., 23,444 acfm for the
CCS model.
Column BI, Average flow rate for upgraded scrubbers [Qm^]
Estimated from ICR analysis, e.g., 21,000 acfm for the
CCS model.
Column BJ, Unit Annual Cost for Upgraded Scrubbers
[TACupo, $/yr]
Estimated from ICR analysis and scrubber cost program,
e.g., $96,821 for the CCS model.
Column BK, Annual Operating Time for New Scrubbers
[TNEW, hrs/yr]
Estimated from ICR analysis, e.g., 6,300 hrs for the
CCS model .
Column BL, Annual Operating Time for Upgraded Scrubbers
[Tupo, hrs/yr]
Estimated from ICR analysis, e.g., 6,300 hrs for the
CCS model.
Column BM, Annual Energy Use for New Scrubbers
[PNEW/ kWh/yr]
Estimated from ICR analysis and scrubber costing
program, e.g., 180,298 kWh/yr for the CCS model.
Column BN, Annual Energy Use for Upgraded Scrubbers
kWh/yr]
Estimated from ICR analysis and scrubber costing
program, e.g., 33,115 kWh/yr for the CCS model.
Column BO, Effluent Quantity for New Scrubbers [QEFNEW,
m3/yr]
Estimated from ICR analysis and scrubber costing
program, e.g., 8,213 m3/yr for the CCS model.
Column BP, Effluent Quantity for Upgraded Scrubbers
m3/yr]
Estimated from ICR analysis and scrubber costing
program, e.g., 1,473 m3/yr for the CCS model.
Column BQ, Facilities Requiring New or Upgraded Scrubbers
[NFAC]
Estimated from ICR analysis, e.g., 7 for the CCS model.
C-8
-------
Column BU, Inlet Chlorine Concentration [CiC12/ ppmv]
Estimated from ICR analysis, e.g., 10 ppmv for the ARS
model.
Column BV, Outlet Chlorine Concentration [COCQ, ppmv]
Estimated from ICR analysis, e.g., 3 ppmv for the ARS
model .
Column BW, Uncontrolled Model Plant Emissions l&caaxr Mg/yr]
Chlorine emissions from acid regeneration plants
estimated as 0.94 Mg/yr for the ARS model from:
_
CI2uac IxlO*
0 460 +32 1
^ 460 + 190 359
X 60 X T X
2,000
X 0.9072
where: QAR = Flow rate from acid plant scrubber, acfm
71 = Molecular weight of C12, Ib/lb mol.
Column BX, Uncontrolled US Emissions [E^us, Mg/yr]
Estimated as 2.81 Mg/yr for- the ARS model from: Column
~^ ~ " X e
C12unc
BY, Model Plant Baseline Emissions OCQ^, Mg/yr]
Estimated as 0.65 Mg/yr for the ARS model from:
°cl2
106
460 +32 1 ?1
460 + 190
359
x 60 x T x
2,000
x 0.9072
Column BZ, US Baseline Emissions [E^,,,,,,., Mg/yr]
Estimated as 1.96 Mg/yr for the ARS model from:
X G
ci2ann
Column CA, Model Emissions Controlled at 3 ppmv [ecl23,
Mg/yr]
Estimated as 0.28 Mg/yr for the ARS model from:
Column CB, US Emissions Controlled at 3 ppmv
Mg/yr]
C-9
-------
460 + 32 1
460 + 190 X 359
x 60 x T x
2,000
X 0.9072
Estimated as 0.84 Mg/yr for the ARS model from:
JC1230S
X Na
Column CC, Emissions Reduction at 3 ppmv [ER^, Mg/yr]
Estimated as 1.12 Mg/yr for the ARS model from:
Column CD, Flow Rate From Acid Plant Scrubber [QAR, acfm]
Taken from ICR analysis, e.g., 2,800 acfm for the ARS
model .
Column CE, Model Emissions Controlled at 4 ppmv
Mg/yr]
Estimated as 0.37 Mg/yr for the ARS model from:
0124
v r,
^
460 +32
460 + 190
x 60 x T x
2, 000
X 0.9072
Column CF, US Emissions Controlled at 4 ppmv [EC124US, Mg/yr]
Estimated as 1.12 Mg/yr for the ARS model from:
Column CG, Emissions Reduction at 4 ppmv [ER^, Mg/yr]
Estimated as 0.84 Mg/yr for the ARS model from:
C-10
-------
~ E
C124US
Column CH, Model Emissions Controlled at 8 ppmv, [ecl28,
Mg/yr]
Estimated as 0.75 Mg/yr for the ARS model from:
8
-cue ! x 106 - -«
x 60 x T x
460 + 190 359
1
2,000
0.9072
Column CI, US Emissions Controlled at 8 ppmv [E^us, Mg/yr]
Estimated as 2.25 Mg/yr for the ARS model from:
C128US ~
Column CJ, Emissions Reduction at 8 ppmv [ER^, Mg/yr]
Estimated as the difference between baseline emissions
and emissions controlled at 8 ppmv. If the computation
leads to a value below 0, 0 is used, as is the case for
the ARS model from:
ER,
C128
~ E
C12BUS
' EC12base EC128US>
Column CO, Number of Stacks at Model Plant [Ns]
Estimated from analysis of ICR, e.g., two at the CCS
model.
Column CP, Cost of One Continuous Monitor [CM/ $]
Estimated from EPA EMTIC program and updated to 1996
with a factor of 1.054. Found as $129,326 for the CCS
model.
Column CQ, Annual Cost of One Continuous Monitor [CA/ $/yr]
Estimated from EPA EMTIC program and updated to 1996
with a factor of 1.054. Found as $65,032 for the CCS
model.
C-ll
-------
Column CR, Cost of Two Continuous Monitors Combined [C^, $]
Estimated from EPA EMTIC program and updated to 1996
with a factor of 1.054. Found as $204,265 for the CCS
model.
Column CS, Annual Cost of Two Continuous Monitors Combined
[CAJ, $/yr]
Estimated from EPA EMTIC program and updated to 1996
with a factor of 1.054. Found as $72,410 for the CCS
model.
Column CT, Cost of Annual Emission Test for One Stack [ST,
$/yr]
Estimated as $13,800 for the CCS model.
Column CU, Capital Costs for Monitoring Parameters of New
Scrubbers, Single Plant [CSP, $]
Taken from EMTIC cost elements, including a minimum
cost of $7,776 and an added fractional cost of 0.35
times original cost for each scrubber after the first.
Estimated as $9,137 for the CCS model from:
Csp = IF( (7,776 + '(NL X ah/Np - 1) X 7,776 X 0.35) > 7,776,
7,776 + (NL X ah/Np - 1) X7,776x0.35, 7,776)
Column CV, Annual Cost for Monitoring Parameters of New
Scrubbers, Single Plant [CAP, $/yr]
Taken from EMTIC cost elements, including a minimum
cost of $5,489 and an added fractional cost of 0.35
times original cost for each scrubber after the first.
Estimated as $6,450 for the CCS model from:
C^p = IF( (5,489 + (NL X NSL/NP -1) x 5,489 X Q .35) > 5,489,
5,489 + (NL X NSL/NP - I) X 5,489 X 0.35, 5,489)
Column CW, Capital Costs for Monitoring Parameters of
Existing Scrubbers, Single Plant [CSPE, $]
Taken from EMTIC cost elements, including a minimum
cost of $1,296 and an added fractional cost of 0.35
times original cost for each scrubber after the first.
Estimated as $1,523 for the CCS model from:
C-12
-------
SPE (1,296 + (NL X NSL/NP - 1) X 1,296 X 0.35) > 1,296,
1,296 + (NL X NSL/NP - 1) X 1,296 X 0.35, 1,296)
Column CX, Annual Cost for Monitoring Parameters of Existing
Scrubbers, Single Plant [CAPE, $/yr]
Taken from EMTIC cost elements, including a minimum
cost of $431 and an added fractional cost of 0.35 times
original cost for each scrubber after the first.
Estimated as $506 for the CCS model from:
CAPE = Jl?{(431 + (NL X NSL/NP - 1) X 431x0. 35) >431,
431 + (NL X NSL/NP - 1) X 431 X 0.35, 431)
Column CY, Record Keeping and Reporting Costs for Monitors
. . .
Taken from EMTIC cost elements, including a minimum
cost of $11,600 and an added fractional cost of 0.13
times original cost for each scrubber after the first.
Estimated as $12,354 for the CCS model from:
RXM (H/600 + (NL X NSL/NP - 1) X 11,600 X 0.13) > 11,600,
11,600+ (NLxNSL/Np-I) X 11,600 X 0.13, 11,600)
Column CZ, Record Keeping and Reporting Costs for Scrubber
Parameters [C^g, $/yr]
Taken from EMTIC cost elements, including a minimum
cost of $63 and an added fractional cost of 0.13 times
original cost for each scrubber after the first.
Estimated as $67 for the CCS model from:
RXS
<63
L x NSL/NP - 1) X 63 X 0.13) > 63
63 + (NL x NSL/NP - 1) X 11,600 x 0.13, 63)
Column DA, Number of Facilities Requiring New Equipment,
[NNW]
Taken from ICR analysis, e.g., 4 for the CCS model.
Column DB, Number of Facilities with Existing Equipment,
C-13
-------
Taken from ICR analysis, e.g., 8 for the CCS model.
Column DC, Capital Costs for Monitoring Option I, [COPi, $]
Selected from Cs or
based on number of exhaust
stacks for the model, e.g., $204,265 for the CCS model
from:
-OPI
= IF(N, = 1, Cst C-,)
Column DD, Annual Cost for Monitoring Option I, [ACOPJ, $/yr]
Selected from CA or C^, based on number of exhaust
stacks for the model, e.g., $72,410 for the CCS model
from:
AC,
OPI
= IF(NS = 1, C,, C,,)
Column DE, Capital Costs for Monitoring Option II with
Existing Scrubbers, [Copn, $]
Same as CSPE, $1,523 for the CCS model.
Column DF, Annual Cost for Monitoring Option II with
Existing Scrubbers, [ACopn, $/yr]
Summed from previous cost elements, e.g., $14,374 for
the CCS model from:
= ST + C
APE
Column DG, Capital Costs for Monitoring Option II with New
Scrubbers, [CNopn, $]
Same as CSP, $9,137for the CCS model.
Column DH, Annual Cost for Monitoring Option II with New
Scrubbers, [ACNOPn, $/yr]
Summed from previous cost elements, e.g., $6,517 for
the CCS model from:
WOPJJ
Column DI, Capital Costs for Monitoring Option III,
[CNopm, $]
Same as C^, $204,265 for the CCS model.
C-14
-------
Colvunn DJ, Annual Cost for Monitoring Option III, [ACNopm,
$/yr]
Same as CA2, $72,410 for the CCS model.
Column DK, Nationwide Capital Costs for Monitoring Option I,
[CTOPI, $]
Estimated from model plant cost times number of plants,
e.g., $2,451,182 from:
X
Column DL, Nationwide Annual Costs for Monitoring, Option I,
[ACTOPI, $/yr]
Estimated from model plant cost times number of plants,
e.g., $868,918 from:
Column DM, Nationwide Capital Costs for Monitoring Option
II, [CTOPn, $]
Estimated from model plant cost times number of plants
for plants with existing scrubbers and plants requiring
new scrubbers, e.g., $48,730 from:
CT
OPII
OPI
N
EX
CN
OPII
Column DN, Nationwide Annual Costs for Monitoring Option II,
[ACTopn, $/yr] ... ^
Estimated from for plants with existing scrubbers and
plants requiring new scrubbers, e.g., $141,055 from:
ACTOPII = ACNOPII
AC
OPII
Column DO, Nationwide Capital Costs for Monitoring Option
II, [CTOPin, $-] . •
Estimated from model plant cost times number of plants,
e.g., $2,451,182 from:
~ <-OPJJJ x
C-15
-------
Column DP, Nationwide Annual Costs for Monitoring Option II,
[ACTOPm, $/yr]
Estimated from model plant cost times number of plants,
e.g., $868,918 from:
REFERENCES
OAQPS Control Cost Manual. Fourth Edition, Chapter 9, U.S.
Environmental Protection Agency, Office of Air Quality
Planning and Standards. Research Triangle Park, NC.
Publication No. EPA 450/3-90-006. 1990.
Means Building Construction Cost Data, 51st Ed. R. S. Means
Company, Inc. Kingston, Massachusetts. 1992, p 313.
C-16
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NOMENCLATURE
ACNopn
ACopn
ACW
ACTOPI
$/yr
ACTora
$/yr
$/yr
A2
AP
CAPA
CAPE
M
CM2
CNopn
COPI
COPH
RKM
$/yr
CRKS
CSP
CSPE
CTopn
CTOPin
Control Efficiency, %
Control Efficiency of Facilities Not Meeting MACT,
fraction
Annual Cost for Monitoring, Option II with New
Scrubbers, $/yr
Annual Cost for Monitoring, Option III, $/yr
Annual Cost for Monitoring, Option I,, $/yr
Annual Cost for Monitoring, Option II with Existing
Scrubbers, $/yr
Solids Disposal Cost, $/yr
Nationwide Annual Costs for Monitoring, Option I,
Nationwide Annual Costs for Monitoring, Option II,
Nationwide Annual Costs for Monitoring, Option III,
Annual cost of a Continuous Monitor, $/yr
Annual Cost of Two Continuous Monitors (one
location), $/yr
Annual Cost for Monitoring Scrubber Parameters (new
scrubbers), $/yr
Plant Production Capacity, t/yr
Annual Cost for Monitoring Scrubber Parameters (new
scrubber), $/yr
MACT Floor Scrubber Outlet Concentration, ppmv
HC1 Concentration, Uncontrolled ppmv
Scrubber Inlet Chlorine Concentration, ppmv
Cost of a Continuous Monitor, $
Cost of Two Contiuous Monitors (one location), $
Capital Cost for Monitoring, Option II with new
scrubbers, $
Capital Cost for Monitoring, Option III , $
Scrubber Outlet Chlorine Concentration, ppmv
Capital Costs for Monitoring Option I, $
Capital Costs for Monitoring Option II with
Existing Scrubbers, $
Record Keeping and Reporting Cost for Monitors,
Record Keeping and Reporting Costs for Scrubber
Parameters, $/yr
Capital Costs for Monitoring Scrubber Parameters
(new scrubber), $
Capital Cost for Monitoring Scrubber Parameters
(existing scrubber), $
Nationwide Costs for Monitoring, Option I, $/yr
Nationwide Costs for Monitoring, Option II, $/yr
Nationwide Costs for Monitoring, Option III, $/yr
Uncontrolled Annual Plant Emissions, Mg/yr
Baseline Emissions From the Model Plant, Mg/yr
C-17
-------
eCQ3
Mg/yr
6028
Mg/yr
eCI2unc
HClunc
EMACT
LOCO
MWHC1
NEX
NFAC
Model Chlorine Emissions Controlled at 3 ppmv,
Model Chlorine Emissions Controlled at 8 ppmv,
US Chlorine Emissions Controlled at 3 ppmv, Mg/yr
US Chlorine Emissions Controlled at 8 ppmv, Mg/yr
Model Plant Baseline Chlorine Emissions, Mg/yr
US Baseline Chlorine Emissions, Mg/yr
Uncontrolled Model Plant Chlorine Emissions, Mg/yr
Uncontrolled US Chlorine Emissions, Mg/yr
Uncontrolled Emission Rate, Ib/hr
MACT Floor Emissions, Mg/yr
Storage Tank Emissions, Mg/yr
US Chlorine Emissions Reduction at 3 ppmv, Mg/yr
US Chlorine Emissions Reduction at 8 ppmv
Fraction of Facilities Reporting Meeting MACT
Emission Levels
Controlled Lines, %
Molecular Weight of HCl, 36.5
Number of Facilities with Existing Scrubbers
Number of Facilities requiring New or Upgraded
Scrubbers
N,
MACT
NEW
NW
P
PC
PCP
Q
QAR
QEF
QEFNEW
QEFUPQ
QNEW
QUPG
RED
ST
T
Number of Lines
Number of Facilities Reporting Meeting MACT
Emission Levels
Number of New Scrubbers Required
Number of Facilities Requiring New Scrubbers
Number of Plants
Number of Stacks at Model Plant
Upgraded Scrubbers Required
Energy Use, kWh/yr
Production Cost Increase, $/t
Production Cost Increase percent, %
Energy Use for New Scrubbers, kWh/yr
Energy Use for Upgraded Scrubbers, kWh/yr
Model Plant Gas Flow Rate, acfm
Flow Rate from Acid Plant Scrubber, acfm
Scrubber Effluent Quantity, m3/yr
Effluent Quantity for New Scrubbers, m3/yr
Effluent Quantity for Upgraded Scrubbers, m3/yr
Average Flow Rate for New Scrubbers, acfm
Average Flow Rate for Upgraded Scrubbers, acfm
Annual Emissions Reduction, Mg/yr
Cost of Annual Emission Test, per stack, $/yr
Annual Plant Operating Time, hrs
Annual Operating Time for New Scrubbers, hrs/yr
Annual Operating Time for Upgraded Scrubbers,
hrs/yr
TAC
Annual Cost to Meet MACT, $/yr
Unit Scrubber Annual Cost, $/yr
Unit Annual Cost for Upgraded Scrubbers,
$/yr
C-18
-------
TCI
TCI
UT
W
VCTt
Annual Cost, for Tank Vent Piping, $/yr
Unit Scrubber Capital Cost, $
Capital Cost Required to Meet MACT, $
Unit Capital Cdst for Upgraded Scrubbers, $
Capital Cost for Tank Vent Piping, $
Plant Utilization Rate, %
Solids Disposal from Scrubber System, Mg/yr
C-19
-------
Input
Data
Estimate
uncontrolled
emissions from
processes and
storage tanks
Estimate baseline
emissions from
processes and
tanks
Estimate emissions
at MACT floor
Estimate capital
costs for control of
processes and
tanks
Estimate annual
costs for control of
processes and
tanks
Estimate energy,
water, and solid
waste impacts
Estimate annual
emission reduction
at the MACT floor
Estimate cost
increase for steel
product
Figure C-l.
Abbreviated Pickling Impacts Model Flow
Chart
c-20
-------
Set up 17 model plants
For each
model plant
Insert data from cost
model and information
collection requests1
Estimate
uncontrolled emission
rate:
concentration x gas flow
rate
Estimate storage
tank emissions:
emission rate x
capacity
x utilization rate
AL
Estimate uncontrolled H
plant emissions:
uncontrolled emission
rate x hours per year x
number of plants +
tank emissions
Cost model estimates2
Estimate fraction of facilities
meeting MACT:
number of facilities meeting MACT
number of facilities
AY
Goto
BoxM
Figure C-2. Pickling Impacts Model
C-21
-------
M
Estimate scrubber outlet concentration
at MACT floor
Will facility
use 10 ppm or 97.5
percent?
Estimate US baseline emissions
K
Is the
model
efficiency
97.5%?.
Are all
facilities
ontrolled?
Baseline emission = (uncontrolled
emissions x fraction of lines
controlled x (1 - control efficiency))
+ uncontrolled emissions x fraction
of uncontrolled lines
Do all
real facilities
currently meet
MACT?
Baseline emissions
emission at
MACT floor
Baseline emissions =
uncontrolled emissions x
average efficiency of facilities
not meeting MACT
Figure C-2. Pickling Impacts Model (continued)
C-22
-------
Estimate US emissions
at MACT floor:
N
plants x hours x flow rate x
outlet concentration +
(0.0275 x uncontrolled
storage tank emissions)
AA
Estimate capital cost for
storage tank vent piping:
400 feet pipe x $31 per foot
Q
Estimate capital cost to meet
MACT:
(unit capital cost for scrubbers and
tank vent lines x number of new
scrubbers required) + 0.4 x unit
costs x number of upgraded
scrubbers required
AB
Estimate annual cost for
tank vent piping:
0.15 x capital cost
Figure C-2. Pickling Impacts Model (continued)
C-23
-------
Estimate solids disposal cost:
number of new scrubbers required x
flow rate x hours x amount of sludge x
solids in sludge x $239 per ton disposal
cost + number of upgraded scrubbers
required x flow rate x hours x amount of
sludge x solids in sludge x $239 per ton
Estimate annual cost to meet MACT:
unit annual cost for scrubbers and
tank vent lines x number of new
scrubbers required + 0.4 x unit
costs x number of upgraded
scrubbers required
Estimate quantity of solids for
disposal:
Y
solids disposal cost
S239 per ton
Estimate energy use:
AE
number of new scrubbers x unit annual
energy use for new scrubbers + number of
upgraded scrubbers x unit annual energy use
for upgraded scrubbers
Figure C-2. Pickling Impacts Model (continued)
C-24
-------
Estimate scrubber effluent quantity:
number of new scrubbers x unit
annual effluent for new scrubbers +
number of upgraded scrubbers x unit
annual effluent for upgraded
scrubbers
AF
AG
Estimate annual emission
reduction:
baseline emissions - MACT floor
emissions
(= 0 for negative quantities)
Estimate increase in steel
production cost due to new or
upgraded scrubbers:
annual cost of scrubbers
BA
annual plant production x number
of facilities requiring new or
upgraded scrubbers
Estimate percentage increase
in steel production cost due to
new or upgraded scrubbers:
production cost increase
BC
cost of steel
Figure C-2. Pickling Impacts Model (continued)
C-25
-------
Acid Regeneration Plant
Chlorine Emissions
BW
Uncontrolled model plant
emissions: inlet concentration x
flow rate x time
BX
Uncontrolled US emissions:
uncontrolled model plant emissions
x number of plants
BY
Model plant baseline emissions:
(inlet concentration - outlet
concentration) x flow rate x time
BZ
US baseline emissions:
model plant baseline emissions x
number of plants
CA
Model plant emissions controlled at
3 ppmv: 3 x 1 Cr6 x flow rate x time
Figure C-2. Pickling Impacts Model (continued)
C-26
-------
r
CB
US emissions controlled at 3 ppmv:
model plant emissions at 3 ppmv x
number of plants
i
r
cc
Emission reduction at 3 ppm:
baseline emissions - US emissions at
3 ppmv
i
r
CE
Model plant emissions controlled at
4 ppmv: 4 x 1 0^ x flow rate x time
i
r
CF
US emissions control a 4 ppmv:
model plant emissions at 4 ppmv x
number of plants
r
Figure C-2. Pickling Impacts Model (continued)
C-27
-------
'
r
Emission reduction at 4 ppm\
baseline emissions - US emission
4ppmv
i
r
CG
/:
sat
CH
Model plant emissions controlled at
8 ppmv: 8 x 1 Cr* x flow rate x time
T
r
Cl
US emissions controlled at 8 ppmv:
model plant emissions at 8 ppmv x
number of plants
i
r
CJ
Emissions reduction at 8 ppmv:
baseline emissions - US emissions at
8 ppmv
Fig-are C-2. Pickling Impacts Model (continued)
C-28
-------
Column
Item
Symbol
1 A
B
C
D
G
I
J
L
W
X
Y
AH
AL
AX
AZ
BE
BF
BH
Bl
BK
BL
BM
BN
BO
BP
BQ
BU
BV
CD
2 P
R
BG
BJ
HCIunc
N
N
Q
Q
'tank
MACT
'NM
Model plant name, e.g., continuous coil, small None
Number of plants NP
Number of lines NL
Uncontrolled HCI concentration C
Annual operating hours T
Percent controlled lines LCON
Percent control efficiency , n
Gas flow rate Q
Plant productjon capacity CAPA
Plant utilization rate UT
Scrubber solids disposal W
Number of scrubbers per line Ns
Storage tank-emission rate
Number of facilities meeting MACT N
Control efficiency of facilities not meeting MACT
New scrubbers required to meet MACT
Upgraded scrubbers required to meet MACT
Average gas flow rate for new scrubbers
Average gas flow rate for upgraded scrubbers
Annual operating time for new scrubbers
Annual operating time for upgraded scrubbers
Annual energy use for new scrubbers
Annual energy use for upgraded scrubbers
Effluent quantity for new scrubbers
Effluent quantity for upgraded scrubbers
Facilities requiring new or upgraded scrubbers
Inlet chlorine concentration C:
Outlet chlorine concentration
Flow rate for acid plant scrubber
Unit capital cost for new scrubbers
Unit annual cost for new scrubbers
Unit capital cost for upgraded scrubbers
Unit annual cost for upgraded scrubbers TAG
NEW
UPG
NEW
_ UPG
_NEW
UPG
J
NEW
J
UPG
EFNEW
EFUPG
FAC
(iCI2
'oCI,
TCI
TAC
UPG
Note: letters above and in the upper right corner of the flow sheet boxes correspond to
spreadsheet columns.
Fig-tire C-2. Pickling Impacts Model (continued)
C-29
-------
-------
APPENDIX D
COSTS FOR MODEL PLANT SCRUBBERS
-------
-------
APPENDIX D
COSTS FOR MODEL PLANT SCRUBBERS
The following pages contain three examples of a
spreadsheet program that estimates capital and annual costs
for the model plant scrubbers formulated for acid pickling
facilities. The program is based on procedures described in
the OAQPS Control Cost Manual.1 Costs are estimated for
scrubbers assigned to 17 model plants, as described in
Chapter 5 of this document, and modified to fit the
population of existing plants estimated to require new or
upgraded scrubbers. Each cost estimate has 5 pages (1
through 6; page 4 is not used) and is identified near the
top of page 1 as to the application for which the scrubber
is being costed. For example, the first cost estimate is
for a large continuous coil model using a 130,000 acfm
scrubber. The second esimate is for a small batch model
using a 10,000 acfm scrubber; the third estimate is for a
small continuous rod/wire model with a 3,000 acfm scrubber.
Costs include a fan and a motor for new systems; existing
scrubber upgrades are estimated to require 40 percent of the
cost of a new fan and motor. Where an existing ventilation
system is in place, the added resistance of a new scrubber
is assumed to require a new fan and motor. Costs are
estimated in third-quarter 1993 dollars. In Chapters 6, 7,
and 8 they are escalated to 1996 dollars using an escalation
factor of 1.061.
Chapter 7 of this document provides more information
about the aggregation of scrubbers for each model facility.
Information is also given about the rationale for sizing the
various scrubbers. Table 5-15 gives averages of the
characteristics used as input for the cost models. For the
economic impacts described in Chapter 8 and other impacts in
Chapter 6, a review of facility data and emission estimates
from 17 model plants led to an estimate of 20 percent of the
existing 103 facilities being area sources.
U.S. Environmental Protection Agency. OAQPS Control
Cost Manual, Chapter 9, Gas Absorbers. Fourth Edition.
Office of Air Quality Planning and Standards, Research
Triangle Park, NC. Publication No. EPA 450/3-90-oo6b.
-------
SCRUBBER COSTING
ccllAI
PACKED BED SCRUBBER SIZING AND COSTING
riodel:
OAQPS CONTROL COST MANUAL - EPA - Chapter 9
CCL 1 , large continuous coil, 1 30,000 acfm
Yhen finished, print pages 5 and 6
or costs, pages 1 ,2, and 3 for data.
You enter data on pages 1,2,3, 5,
nd 6. Page 5 starts at cell 11.
Gas flow rate
acfm
Gas temperature, deg F
'ollutant
Pollutant cone, in gas, ppm
Required removal efficiency
Gas density
, Ib/ft 3
.iauid density, Ib/ft 3
Gas molecular weight
Liquid molecular weight
Gas viscosity, Ib/ft hr
Liquid viscosity, Ib/ft hr
Pollutant diffusivity in air, ft2/hr
Pollutant diffusivity in water, ft2/hr
Packing type
Packing factor, Fp (see cell A146)
Packing constants (see cell A146)
a
P
Y
b
a
MWR: 0.85 for RRs > 3 in. & grids, else 1 .3
L/G adjustment factor, 1 .2 to 1 .5
Value of Xi
Yo
at Yo (see equilibrium curve)
= [program calculates this value]
Value of Xo* at Yi
Yi
= [program calculates this value]
Value of Yo* at Xo
Xo - [program calculates this value]
Value of Yi* at Xi
Values
you enter
ixcept cell
F13
130,000
130,000
100
1CI
835
99.64
0.0709
62.30
29.00
18.00
0.0440
2.16
0.7740
1 .02E-04
•
Also open
SCRUBMAC
.XLM
2 in ceramic raschig rings
65
3.82
0.4'
0.45
0.0125
0.22
28
1.3
1.5
0
3.01 E-6
1 .53E-1
8.36E-4
8.10E-5
1 .02E-'
O.OOE+0
(Minimum wetting
rate factor)
See cell A 190
for explanations
of Yi, Xi, etc. Xi is
0 if solvent is fresh.
SB3CCL1.XLS
6/18/97 1:00 PM
-------
SCRUBBER COSTING
C8IIA49
Calculated values
(Ls/Gs)min slope of operating line
(Ls/Gs)act
Gs
Ls
Gmol,i
Lmol,i
Xo
xo
yo'
xi
yi'
m
Absorption factor, AF
ABSCISSA
Abscissa correction if value too low,
from Fig. 9.5 in Chapter 9.
ORDINATE
Gsfr,i, Ib/sec ft2
Flooding factor, you choose: 0.6 to 0.75
A, ft2
Lsfr,i, Ib/hr ft2
Lsfr,i,min, Ib/hr ft2
D, ft
New A, ft2
New Gsfr
New Lmol,i
New D, ft
New Xo
New xo
Enter new Yo* at Xo (see equilibrim curve)
New yo*
new m
yo
Yi
Absorption Factor
Ntu
5.43E-3
8.14E-3
1.91E + 4
1.55E + 2
1.91E + 4
1.55E + 2
1 .02E-1
9.28E-2
8.10E-5
P.OOE + O
O.OOE+0
8.73E-4
9.32
1.70E-4
1 .OOE-2
2.06E-1
6.80E-1
0.7
323.4
8.6
2,268
-
HIT MACRO, RUN, SCRUB
350.3
0.6270
44,134
21.12
3.60E-4
3.60E-4
O.OOE + 0
O.OOE+0
O.OOE+0
3.01 E-6
8.35E-4
#DIV/0!
5.63
(0 if fresh solvent)
#DIV/0!
IS OK
SB3CCL1 .XLS
Page 2
6/18/97 1:00 PM
-------
SCRUBBER COSTING
C4JIA97
Hg,ft
HI, ft
Htu, ft
Hpack, ft
Htower, ft
S, ft2
Enter c, see cell A 146
Enter j, see cell A146
Delta P, in. water
Packing volume, ft3
Equipment selection
Enter material factor on this line (FRP = 1 )
304 Stainless = 1.10 to 1.75
Polypropylene = 0.80 to 1.10
Polyvinyl chloride = 0.50 to 0.90
Enter packing unit cost on this line, $/ft3
1", 304ss Pall, Raschig, or Ballast rings
1 ", ceramic Raschig rings, Berl saddles
1", polypro Tri-pack, Pall or Ballast rings,
Flexsaddles
2", ceramic Berl saddles, Raschig rings
2", polypro Tri-pack, Lanpac, Flexiring,
Flexisaddle, Tellerette
3.5", 304ss Ballast rings
3.5", polypro Tri-Pack, LanPac,
Ballast rings
Structured packing, stainless steel
Structured packing, polypropylene
Enter unit pump cost, $/gpm (16 for FRP
at 60 ft of H20 pressure drop)
Packing cost, $
Pump cost, $
Fan cost, $
Motor cost, $ (scrubber = 75% of delta P)
Choose fan/moter efficiency (0.4 to 0.7)
Other Auxiliaries in your year $ (if needed)
Cost of Auxiliaries
Total Equipment Cost, EC, '91 3rd quarter $
2.17
1.06
2.17
12.18
41.41
3,448.07
0.24
0.17
10.17
4,268.20
1
20
16
85,364
25,401
25,265
11,656
0.7
24929
87,529
569,421
,
Use for packing
cost below « or >
100ft3).
$/ft3
< 1 00 ft3
70-109
33-44
14-37
13-32
3-20
30
6-14
45 to
65 to
$/ft3
> 1 00 ft3
65-99
26-36
12-34
10-30
5-19
27
6-12
405
350
(Requires a 0
if no costs)
SB3CCL1 .XLS
Page 3
6/18/97 1:00 PM
-------
SCRUBBER COSTING
<
Direct Costs
CAPITAL COST FACTOR SHEET
Purchased equipment costs (A)
:.n '
Typical
values
Absorber, packing, aux equip., etc. (from cell F143 = A)
Instrumentation
Sales taxes
Freight
Purchased equipment cost, PEC = B
Direct installation costs
Foundation and supports
Handling and erection i
Electrical
Piping
Insulation
Painting
Direct installation costs
Site preparation (as needed), $
Buildings (as needed), $
Total direct costs, DC
Indirect Costs (installation)
Engineering
Construction and field expenses
Contractor fees
Start-up
Performance test
Contingencies
Total indirect costs, 1C
Total Capital Investment =
DC + 1C, your year $
0.1
0.03
0.05
0.12
0.4
0.01
0.3
0.01
0.01
0.1
0.'
0.'
0.01
0.0'
0.03
Values
you
choose
except
cellN11
569,421
0.1
0.03
0.05
0.12
0.4
0.01
0.3
0.01
0.01
0.1
0.1
0.1
0.01
0.01
0.03
Cost
in your
year $
563,129
56,313
16,894
28,156
664,492
79,739
265,797
6,645
199,348
6,645
6,645
564,819
1,229,311
66,449
66,449
66,449
6,645
6,645
19,935
232,572
$1,46
1,883
SB3CCL1.XLS
Page 5
6/18/97 1:00 PM
-------
SCRUBBER COSTING
ctHI49
Direct Annual Cost, DC
Operating labor
Operator, hrs/shift
ANNUAL COST ITEM SHEET
Supervisor, % of operator
Operating Materials
Solvent, $/1 ,000 gal
Chemicals, $/lb (if used)
Wastewater Disposal, $/1 ,000 gal
Maintenance
Labor, hrs/shift
Material, % of maintenance labor
Electricity, $/kWh
Fan
&•
Pump (assumes 60 ft H2O delta P)
Total DC
Indirect Annual Costs, 1C
Overhead, % of labor and materials
Administrative charges, % of TCI
Property tax, % of TCI
Insurance, % of TCI
Capital recovery, % interest
Total 1C
Typical Value
1/2
15
(water) 0.2
(Na2O)0.15
3 to 6
1/2
100
0.06
60
2
1
1
10
Total Annual Cost, DC + 1C, your year $
DATA YOU ENTER
Shifts per day
Days per week
Weeks per year
Sovent use, fraction of throughput (0.001 to 0.1)
Chemical usage, Ib per gal
Equipment lifetime, yrs
Labor cost, $/hr
Maintenance labor cost, $/hr
Chemical Engineering Cost Index for your year
Hrs/yr =
Year of your costs
7000.056
3
5.719
51
0.02
0
15
16.1
17.71
358
May-93
You Choose
0.5
1,5
0.2
0
3.8
0.5
100
0.06
60
2
1
1
7
Cost
7,044
1,057
2,641
0
50,188
7,748
7,748
92,774
7,509
176,709
14,158
29,238
14,619
14,619
160,507
233,140
$409,850
(blowdown fraction)
(if chemical is used)
(15 is typical)
($15.64 for 1991)
($17.21 for 1991)
(1991, 3rd quarter
(See Chemical
Engineering
Magazine for other
year values)
362)
SB3CCL1.XLS
Page 6
6/18/97 1:00 PM
-------
SCRUBBER COSTING
cell A1
PACKED BED SCRUBBER SIZING AND COSTING
Model:
L.
OAQPS CONTROL COST MANUAL - EPA - Chapter 9
BS, small batch, 10,000 acfm
When finished, print pages 5 and 6
for costs, pages 1 ,2, and 3 for data.
You enter data on pages 1 ,2,3, 5,
and 6. Page 5 starts at cell 11 .
Gas flow rate
acfm
Gas temperature, deg F
Pollutant
Pollutant cone, in gas, ppm
Required removal efficiency
Gas density, Ib/ft 3
Liquid density, Ib/ft 3
Gas molecular weight
Liquid molecular weight
Gas viscosity, Ib/ft hr
Jquid viscosity, Ib/ft hr
Pollutant diffusivity in air, ft2/hr
Pollutant diffusivity in water, ft2/hr
Packing type
Packing factor, Fp (see cell A146)
Packing constants (see cell A146)
a
P
i
b
a
MWR: 0.85 for RRs > 3 in. & grids, else 1 .3
L/G adjustment factor, 1 .2 to 1 .5
Value of Xi at Yo (see equilibrium curve)
Yo = [program calculates this value]
Value of Xo* at Yi -
Yi = [program calculates this value]
Value of Yo* at Xo
Xo = [program calculates this value]
Value of Yi* at Xi
Values
you enter
except cell
F13
10,000
10,000
90
HCI
300
97.30
0.0,709
62.30
29.00
18.00
0.0440
2.16
0.7740
1 .02E-04
Also open
SCRUBMAC
.XLM
2 in ceramic raschig rings
65
3.82
0.41
0.45
0.0125
0.22
28
1.3
1.5
0
8.10E-6
3.00E-3
3.00E-4
3.00E-6
2.00E-3
O.OOE+0
(Minimum wetting
rate factor)
See cell A1 90
for explanations
of Yi, Xi, etc. Xi is
0 if solvent is fresh.
SCBBS.XLS
Page 1
(i/18/97 1:07 PM
-------
SCRUBBER COSTING
CHDA49
Calculated values
Ls/Gs)min slope of operating line
Ls/Gs)act
Gs
Ls
Gmol,i
Lmol,i
Xo
xo
yo*
xi
Vi*
m
Absorption factor, AF
ABSCISSA
Abscissa correction if value too low,
from Fig. 9.5 in Chapter 9.
ORDINATE
Gsfr,i, Ib/sec ft2
Flooding factor, you choose: 0.6 to 0.75
A, ft2
Lsfr.i, Ib/hr ft2
Lsfr,i,min, Ib/hr ft2
D, ft
New A, ft2
New Gsfr
New Lmol,i
New D, ft
NewXo
New xo
Enter new Yo* at Xo (see equilibrim curve)
New yo*
new m
yo
Vi
Absorption Factor
Ntu
9.73E-2
1 .46E-1
1.47E + 3
2.14E + 2
1.47E + 3
2.14E + 2
2.00E-3
2.00E-3
3.00E-6
O.OOE + 0
O.OOE+0
1 .50E-3
97.11
3.06E-3
1 .OOE-2
2.06E-1
6.80E-1
0.7
24.9
155.2
2,268
>
HIT MACRO, RUN, SCRUB
26.9
0.6273
3,391
5.85
1 .26E-4
1 .26E-4
O.OOE+0
O.OOE+0
O.OOE+0
8.10E-6
3.00E-4
#DIV/0!
3.61
(0 if fresh solvent)
#DIV/0!
IS OK
SCBBS.XLS
Page 2
6/18/97 1:07 PM
-------
SCRUBBER COSTING
cell A97
Hg, ft
HI, ft
Htu, ft
Hpack, ft
Htower, ft
S, ft2
Enter c, see cell A 146
Enter j, see cell A146
Delta P, in. water
Packing volume, ft3
Equipment selection
- • . _
Enter material factor on this line {FRP = 1 )
304 Stainless = 1.10 to 1.75
Polypropylene = 0.80 to 1.10
Polyvinyl chloride = 0.50 to 0.90
Enter packing unit cost on this line, $/ft3
1", 304ss Pall, Raschig, or Ballast rings
1", ceramic Raschig rings, Berl saddles
1", polypro Tri-pack, Pall or Ballast rings,
Flexsaddles
2", ceramic Berl saddles, Raschig rings
2", polypro Tri-pack, Lanpac, Flexiring,
Flexisaddle, Tellerette
3.5", 304ss Ballast rings
3.5", polypro Tri-Pack, LanPac,
Ballast rings
Structured packing, stainless steel
Structured packing, polypropylene
Enter unit pump cost, $/gpm (16 for FRP
at 60 ft of H20 pressure drop)
Packing cost, $
Pump cost, $
Fan cost, $
Motor cost, $ (scrubber = 75% of delta P)
Choose fan/moter efficiency (0.4 to 0.7)
Other Auxiliaries in your year $ (if needed)
Cost of Auxiliaries
Total Equipment Cost, EC, '91 3rd quarter $
2.17
1.06
2.17
7.82
19.73
416.77
0.24
0.17
6.53
210.58
1
20
16
4,212
1,952
4,741
987
0.7
3072
10,786
62,926
Use for packing
cost below « or >
100ft3).
$/ft3
< 1 00 ft3
70-109
33-44
14-37
13-32
3-20
30
6-14
45 to
65 to
$/ft3
>100ft3
65-99
26-36
1 2-34
10-30
5-19
27
6-12
405
350
(Requires a 0
if no costs)
SCBBS.XLS
Page 3
6/18/97 1:O7PM
-------
SCRUBBER COSTING
c*HI1
Direct Costs
CAPITAL COST FACTOR SHEET
Purchased equipment costs (A)
Typical
values
Absorber, packing, aux equip., etc. (from cell F143 = A)
Instrumentation
Sales taxes
Freight
Purchased equipment cost, PEC = B
Direct installation costs
Foundation and supports
Handling and erection
Electrical
Piping
Insulation
Painting
Direct installation costs
Site preparation (as needed), $
Buildings (as needed), $
Total direct costs, DC
Indirect Costs (installation)
Engineering
Construction and field expenses
Contractor fees
Start-up
Performance test
Contingencies
Total indirect costs, 1C
Total Capital Investment = DC + IC, your year $
0.1
0.03
0.05
0.12
0.4
0.01
0.3
0.01
0.01
0.1
0.1
0.1
0.01
0.01
0.03
Values
you
choose
except
cellN11
62,926
0.1
0.03
0.05
0.12
0.4
0.01
0.3
0.01
0.01
0.1
0.1
0.1
0.01
0.01
0.03
Cost
in your
year $
62,231
6,223
1,867
3,112
73,433
8,812
29,373
734
22,030
734
734
62,418
135,850
7,343
7,343
7,343
734
734
2,203
25,701
$161,552
SCBBS.XLS
6/18/97 1:07 PM
-------
SCRUBBER COSTING
call A1
'
SACKED BED SCRUBBER SIZING AND COSTING
w
OAQPS CONTROL COST MANUAL - EPA - Chapter 9
CWS, small continuous rod/wire, 3,000 acfm
When finished, print pages 5 and 6
for costs, pages 1 ,2, and 3 for data.
You enter data on pages 1,2,3, 5,
and 6. Page 5 starts at cell 11 .
Gas flow rate
acfm
Gas temperature, deg F
Pollutant
Pollutant cone, in gas, ppm
Required removal efficiency
Gas density
, Ib/ft 3
Liquid density, Ib/ft 3
Gas molecular weight
Liquid molecular weight
Gas viscosity, Ib/ft hr
Liquid viscosity, Ib/ft hr
Pollutant diffusivity in air, ft2/hr
Pollutant diffusivity in water, ft2/hr
Packing type
Packing factor, Fp (see cell A146)
Packing constants (see cell A146)
a
P
Y
4>
b
a
MWR: 0.85 for RRs > 3 in. & grids, else 1 .3
L/G adjustment factor, 1 .2 to 1.5
Value of Xi at Yo (see equilibrium curve)
Yo
= [program calculates this value]
Value of Xo» at Yi
Yi
= [program calculates this value]
Value of Yo' at Xo
Xo = [program calculates this value]
Value of Yi* at Xi
Values
you enter
ixcept cefl
F13
3,000
3,000
90
ICI
1,680
99.52
0.0709
62.30
29.00
18.00
0.0440
2.16
0.7740
1 .02E-04
Also open
SCRUBMAC
XLM
2 in ceramic raschig rings
65
3.82
0.41
0.45
0.0125
0.22
28
1.3
1.5
0
8.06E-6
1.57E-1
1 .68E-3
1 .07E-4
1.05E-1
O.OOE + C
(Minimum wetting
rate factor)
See cell A190
for explanations
of Yi, Xi, etc. Xt is
0 if solvent is fresh.
SBCWS.XLS
Page 1
6/18/97 1:12 PM
-------
SCRUBBER COSTING
Mil MS
Direct Annual Cost, DC
Operating labor
Operator, hrs/shift
ANNUAL COST ITEM SHEET
Supervisor, % of operator
Operating Materials
Solvent, $/1 ,000 gal
Chemicals, $/lb (if used)
Wastewater Disposal, $/1 ,000 gal
Maintenance
Labor, hrs/shift
Material, % of maintenance labor
Electricity, $/kWh
Fan
Purnp (assumes 60 ft H2O delta P)
Total DC
Indirect Annual Costs, 1C
Overhead, % of labor and materials
Administrative charges, % of TCI
Property tax, % of TCI
Insurance, % of TCI
Capital recovery, % interest
Total 1C
Typical Value
1/2
15
(water) 0.2
(Na2O)0.15
3 to 6
1/2
100
0.06
60
2
1
1
10
Total Annual Cost, DC + 1C, your year $
DATA YOU ENTER
Shifts per day
Days per week
Weeks per year
Sovent use, fraction of throughput (0.001 to 0.1)
Chemical usage, Ib per gal
Equipment lifetime, yrs
Labor cost, $/hr
Maintenance labor cost, $/hr
Chemical Engineering Cost Index for your year
Hrs/yr =
Year of your costs
4399.99
2
5.28845
52
0.02
0
15
16.1
17.71
358
May-93
You Choose
|
0.5
1,5
0.2
0
3.8
0.5
100
0.06
60
2
1
1
7
Cost
4,427
664
128
0
2,424
4,870
4,870
2,883
363
20,630
8,899
3,231
1,616
1,616
17,738
33,099
$53,728
(blowdown fraction)
(if chemical is used)
(15 is typical)
($15.64 for 1991)
($17.21 for 1991)
(1991, 3rd quarter
(See Chemical
Engineering
Magazine for other
year values)
I
362)
SCBBS.XLS
Page 6
6/18/97 1:07 PM
-------
SCRUBBER COSTING
Calculated values
{Ls/Gs)min slope of operating line
1.07E-2
(Ls/Gs)act
1.60E-2
Gs
4.41E + 2
7.05E + 0
Gmol.i
4.42E + 2
Lmol.i
7.05E + 0
Xo
1.05E-1
xo
9.48E-2
vo'
1.07E-4
XI
O.OOE + 0
Vi
O.OOE + 0
m
1.13E-3
Absorption factor, AF
14.15
ABSCISSA
3.34E-4
Abscissa correction if value too low.
1 .OOE-;
from Fig. 9.5 in Chapter 9
ORDINATE
2.06E-1
Gsfr,i, Ib/sec ft2
6.80E-1
Flooding factor, you choose: 0.6 to 0.75
0.
A, ft2
7.5
Lsfr,i, Ib/hr ft2
17.0
sfr,i,min, Ib/hr ft2
2,268
D, ft
HIT MACRO, RUN, SCRUB
New A, ft2
8.1
ew Gsfr
0.6277
view Lmol,i
1,018
New D, ft
3.21
New Xo
7.25E-4
Mew xo
7.26E-4
Enter new Yo* at Xo (see equilibrim curve)
O.OOE-i-0
(0 if fresh solvent)
New yo*
O.OOE+0
new m
O.OOE+0
vo
8.06E-6
yi
1.68E-3
Absorption Factor
#DIV/0!
#DIV/0!
IS OK
Ntu
5.34
Hg, ft
2.17
SBCWS.XLS
Page 2
6/18/97 1:12PM
-------
SCRUBBER COSTING
HI, ft
Htu, ft
Hpack, ft
Htower, ft
S, ft2
Enter c, see cell A1 46
Enter j, see cell A146
Delta P, in. water
Packing volume, ft3
Equipment selection
,
c«IIA146
Enter material factor on this line (FRP = 1 )
304 Stainless = 1.10 to 1.75
Polypropylene = 0.80 to 1.10
Polyvinyl chloride = 0.50 to 0.90
Enter packing unit cost on this line, $/ft3
1", 304ss Pall, Raschig, or Ballast rings
1", ceramic Raschig rings, Berl saddles
1", polypro Tri-pack, Pall or Ballast rings,
Flexsaddles
2", ceramic Berl saddles, Raschig rings
2", polypro Tri-pack, Lanpac, Flexiring,
Flexisaddle, Tellerette
3.5", 304ss Ballast rings
3.5", polypro Tri-Pack, LanPac,
Ballast rings
Structured packing, stainless steel
Structured packing, polypropylene
Enter unit pump cost, $/gpm (16 for FRP
at 60 ft of H20 pressure drop)
Packing cost, $
Pump cost, $
Fan cost, $
Motor cost, $ (scrubber = 75% of delta P)
Choose fan/moter efficiency (0.4 to 0.7)
Other Auxiliaries in your year $ (if needed)
Cost of Auxiliaries
Total Equipment Cost, EC, '91 3rd quarter $
1.06
2.17
11.57
22.28
240.64
0.24
0.17
9.67
93.48
1
20
16
1,870
586
1,900
507
0.7
1197
4,204
33,747
•
Use for packing
cost below « or >
100 ft3).
$/ft3
<100fl3
70-109
33-44
14-37
13-32
3-20
30
6-14
45 to
65 to
$/ft3
>100ft3
65-99
26-36
12-34
10-30
5-19
27
6-12
405
350
(Requires a 0
if no costs)
SBCWS.XLS
Page 3
6/18/97 1:12PM
-------
SCRUBBER COSTING
coll 11
Direct Costs
CAPITAL COST FACTOR SHEET
Purchased equipment costs (A)
^ -
*"• ' •
Typical
values
Absorber, packing, aux equip., etc. (from cell F143 = A)
Instrumentation
Sales taxes
Freight
Purchased equipment cost, PEC = B
Direct installation costs
Foundation and supports
Handling and erection
Electrical
Piping
Insulation
Painting
Direct installation costs
Site preparation (as needed), $
Buildings (as needed), $
Total direct costs, DC
Indirect Costs (installation)
Engineering
Construction and field expenses
Contractor fees
Start-up
Performance test
Contingencies
Total indirect costs, 1C
Total Capital Investment = DC +IC, your year $
0.1
0.03
0.05
0.12
0.4
0.01
o.a
0.01
0.01
0.1
0.1
0.1
0.0'
o.qij
0.03
Values
you
choose
except
cellN11
33,747
0.1
0.03
0.05
0.12
0.4
0.01
0.3
0.01
0.01
0.1
0.1
0.1
0.01
0.01
0.03
Cost
in your
year $
33,374
3,337
1,001
1,669
39,381
4,726
15,753
394
11,814
394
394
33,474
72,855
3,938
3,938
3,938
394
394
1,181
13,783
$86
,639
SBCWS.XLS
Page 5
6/18/97 1:12PM
-------
SCRUBBER COSTING
C*flM9
Direct Annual Cost, DC
Operating labor
Operator, hrs/shift
ANNUAL COST ITEM SHEET
Supervisor, % of operator
Operating Materials
Solvent, $/1 ,000 gal
Chemicals, $/lb (if used)
Wastewater Disposal, $/1 ,000 gal
Maintenance
Labor, hrs/shift
Material, % of maintenance labor
Electricity, $/kWh
Fan
Pump (assumes 60 ft H2O delta P)
Total DC
Indirect Annual Costs, 1C
Overhead, % of labor and materials
Administrative charges, % of TCI
Property tax, % of TCI
Insurance, % of TCI
Capital recovery, % interest
Total 1C
Typical Value
1/2
15
[water) 0.2
[Na2O)0.15
3 to 6
1/2
100
0.06
60
2
1
1
10
Total Annual Cost, DC + 1C, your year $
DATA YOU ENTER
Shifts per day
Days per week
Weeks per year
Sovent use, fraction of throughput (0.001 to 0.1)
Chemical usage, Ib per gal
Equipment lifetime, yrs
Labor cost, $/hr
Maintenance labor cost, $/hr
Chemical Engineering Cost Index for your year
Hrs/yr =
Year of your costs
5100.077
2.
6.1299
52
0.02
0
15
16.1
17.7'
358
May-93
rou Choose
0.5
15
0.2
0
3.8
0.5
100
0.06
60
2
1
1
7
Cost
5,132
770
44
0
844
5,645
5,645
1,484
126
19,690
10,315
1,733
866
866
9,512
23,293
$42,984
(blowdown fraction)
(if chemical is used)
(15 is typical)
($15.64 for 1991)
($17.21 for 1991)
(1991, 3rd quarter
(See Chemical
Engineering
Magazine for other
year values)
362)
SBCWS.XLS
Page 6
6/18/97 1:12PM
-------
APPENDIX E
TANK EMISSIONS MODEL
-------
-------
The following open tank emissions model for HCl
pickling processes was developed by Mr. Neil Stone of Esco
Engineering Company, Kingsville, Ontario, Canada. It is
based on a paper by Friedman1 for estimating heat losses
from tanks .
The basic equations are:
EW = 15.8(0.46 + 0.117 V) log [(760 - pa) / (760 - pv) J
EH = 25(0.46 + 0.117 V) log [(760 - pa)/ (760 - pv) ]
where:
f t2
surface rate of evaporation of water, Ib/hr-
Eu = surface rate of evaporation of HC1, lr/hr-ft2
n
V = air velocity across surface, ft/s
pa = partial pressure of water or HC1 in air, mm
Hg
pv = vapor pressure of water or HCl in equilibrium
with liquid, mm Hg.
The article by Friedman also provides graphs of heat
losses from open liquid surfaces at various temperatures and
air velocities.
To use the equations, the vapor pressures of water and
HCl over solutions of HCl and ferrous chloride may be found
from a Cox chart for water (of vapor pressure vs reciprocal
absolute temperature) that has been modified for the
solutions. For HCl in pickling solutions, the vapor
pressure can be estimated from:
loglO(vp) = -6.466 + 0.01715t + 0.2028(A) + 0.07313(F)
where: vp = vapor pressure of HCl, g/ft3 of inert gas
t = liquid temperature, »F
A = acid concentration in liquid, wt %
F = ferrous chloride concentration in liquid, wt
%
Using the ideal gas law, vapor pressure may be treated
as a partial pressure in air by the following equation:
where:
pp = Oi.0335 (460 + t) vp
pp = partial pressure, mm Hg
-------
1.
Air velocities across the pickling tanks may be found
from:
V = Q/2WLN/60
where: V = air velocity across the liquid, ft/s
Q = exhaust rate per tank, actual ft3/min
N = no. of exhaust points per tank
W = width of tank, ft
L = distance from liquid surface to tank cover, ft
The true evaporation rate is less than the theoretical
rate as estimated from the above equations. A factor of
0.41 is applied to the equation estimates to correct for
observed differences.
Friedman, S. J. Heat Losses From Tanks, Vats, and Kettles.
Heating and Ventilating, April 1948. pp. 94-107.
E-2
-------
APPENDIX F
PRODUCTS IN THE STEEL INDUSTRY BY SIC CODE
-------
-------
APPENDIX F
This appendix contains full descriptions of the
relevant 4-digit SIC codes in the Primary Metals industry
(SIC 33). Appendix Tables F-l through F-5 contain a
detailed listing of steel producers included in each SIC
code discussed below. Information in this appendix was
taken from Standard Industrial Classification Manual.1
SIC 3312: Steel Works. Blast Furnaces (Including Coke
ovens). and Rolling Mills. Establishments primarily engaged
in manufacturing hot metal, pig iron, and silvery pig iron
from iron ore and iron steel scrap; converting pig iron,
scrap iron, and scrap steel into steel; and hot-rolling iron
and steel into basic shapes, such as plates, sheets, strips,
rods, bars, and tubing.
SIC 3315; Steel Wiredrawing and Steel Nails and Spikes.
Establishments primarily engaged in drawing wire from
purchased iron or steel rods, bars, or wire and may be
engaged in the further manufacture of products made from
wire; establishments primarily engaged in manufacturing
steel nails and spikes from purchased materials are also
included in this industry.
SIC 3316; Cold-Rolled Steel Sheet. Strip, and Bars.
Establishments primarily engaged in: cold-rolling steel
sheets and strips from purchased hot-rolled sheets, cold-
drawing steel bars and steel shapes from purchased hot-
rolled steel bars, and producing other cold finished steel.
sic 3317; Steel Pipe and Tubes. Establishments primarily
engaged in producing welded or seamless steel pipes and
tubes and heavy riveted steel pipe from purchased materials.
-------
SIC 3357: Drawing and Insulating of Nonferrous Wire.
Establishments primarily engaged in drawing, drawing and
insulating, and insulating wire and cable of nonferrous
metals from purchased wire bars, rods, or wire. Also
included are establishments primarily engaged in
manufacturing insulated fiber optic cable.
SIC 3398; Metal Heat Treating. Establishments primarily
engaged in heat treating or metal for the trade.
F-2
-------
TABLE F-l.
PRIMARY PRODUCTS AND PRODUCT CODES FOR SIC 3312:
BLAST FURNACES AND STEEL MILLS
Primary Product Description
Product Code
Steel ingots and semifinished shapes
and forms
Semifinished products (excluding
wire rods), carbon
Wire rods, carbon
Semifinished products (excluding
wire rods), alloy
Semifinished products (excluding
wire rods), stainless
Tin mill products, h.r. sheets and
strip
Sheets, h.r. carbon
Sheets and strip, hot dipped
galvanized, carbon
Sheets and strip, electrolytic
galvanized, carbon
Other metallic coated sheets and
strip, carbon
Strip, h.r. carbon
Tinplate
Tin free steel
Strip, h.r. stainless
Hot rolled bars, plates and structural
shapes
Plates, carbon
Heavy structural shapes, piling
and piles, carbon
Bars, h.r., carbon
Bars, light structurals, carbon
Concrete reinforcing bars, carbon
Plates, alloy
3312-2
3312-213
3312-219
3312-236
3312-256
3312-3
3312-311
3312-313
3312-315
3312-317
3312-319
3312-326
3312-328
3312-359
3312-4
3312-412
3312-415
3312-422
3312-424
3312-425
3312-431
(Continued)
F-3
-------
TABLE F-l. (Continued)
Primary Product Description
Product Code
Bars, h.r., (including light
structurals), alloy
Tool steel, other than high speed
alloy
Plates and structural shapes,
stainless
Bars, h.r., stainless
Steel wire
Carbon wire
Steel pipe and tubes
Pipe and oil country tubular
goods, carbon
Pipe and tubing, alloy
Cold rolled sheets and strip (excl.
metallic coated and electrical)
Sheets and strip, c.r., carbon
Sheets and strip, c.r., stainless
Cold finished bars
Bars, c.f., stainless
3312-441
3312-449
3312-45
3312-461
3312-5
3312-5A
3312-6
3312-6A
3312-6E
3312-7
3312-71
3312-75
3312-8
3312-851
F-4
-------
TABLE F-2. PRIMARY PRODUCT AND PRODUCT CODES FOR SIC 3315:
STEEL WIRE AND RELATED PRODUCTS-MFPM2
Primarv Product Description
Product Code
Noninsulated ferrous wire, rope, cable
and strand
Wire rope and cable
Wire strand and forms
Steel nails and spikes
Steel wire nails
Wire staples and tacks, cut nails
and spikes
Steel wire
Carbon wire
Steel fencing and fence gates
Ferrous wire cloth and other woven
wire products
Other fabricated ferrous wire
products
Welded steel wire fabric
Other wire products
3315-1
3315-111
3315-151
3315-2
3315-2A
3315-2B
3315-5
3315-5A
3315-6
3315-7
3315-9
3315-96
3315-98
F-5
-------
TABLE F-3.
PRIHARY PRODUCT AND PRODUCT CODES FOR SIC 3316;
COLD FINISHING OF STEEL SHAPES-MFPM3
Primary Product Description
Sheets and strip, metallic coated and
electrical, c.r.
Cold rolled sheets and strip
Sheets and strip, c\r., carbon
Sheets and strip, c.r., alloy
Sheets and strip, c.r., stainless
Cold finished bars
Bars, c.f., carbon
Bars, c.f., alloy
Product Code
3316-3
3316-7
3316-71
3316-73
3316-75
3316-8
3316-811
3316-831
TABLE F-4,
PRIMARY PRODUCT AND PRODUCT CODES FOR SIC 3317
STEEL PIPE AND TUBES-MFPM4
Primary Product Description
Steel pipe and tubes
Pipe and oil country tubular goods,
carbon
Pressure tubing, carbon
Mechanical tubing, carbon
Pipe and tubing, alloy
Pressure tubing, stainless
Mechanical tubing, stainless
Product Code
3317-6
3317-6A
3317-6B
3317-6C
3317-6E
3317-6F
3317-6G
F-6
-------
TABLE F-5. PRIMARY PRODUCT AND PRODUCT CODES FOR SIC 3357:
NONFERROUS WIRE DRAWING AND INSULATING5.
Primary Product Description
Product Code
Aluminum and aluminum-base alloy bare wire and
cable
Copper & copper-base alloy wire & cable for
electrical transmission, including bare & tinned
Other bare nonferrous metal wire
Fiber optic cable
Electronic wire & cable
Telephone & telegraph wire and cable
Control and signal wire and cable
Building wire and cable with underwriters, labels
Apparatus wire and cordage
Magnet & wire
Power wire and cable
Other insulated wire and cable
3357-A
3357-B
3357-C
3357-E
3357-1
3357-2
3357-3
3357-4
3357-6
3357-7
3357-8
3357-9
F-7
-------
3.
4.
5.
Executive Office of the President, Office of Management and
Budget. Standard Industrial Classification Manual. NTIS PB
87-100012. 1987.
U.S. Department of Labor. Bureau of Labor Statistics
Producer Price Indexes Data for November 1991.
Ref. 2.
Ref. 2.
Ref. 2.
F-8
-------
TECHNICAL REPORT DATA
(Please read instructions on the reverse before completing)
1. REPORT NO.
EPA-453/R-97-012
2.
3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
National Emission Standards for Hazardous Air Pollutants
(NESHAP) for Steel Pickling - HCI Process - Background
Information for Proposed Standards
5. REPORT DATE
Issued June 1997
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATIpN NAME AND ADDRESS
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
68-D6-0014
12. SPONSORING AGENCY NAME AND ADDRESS
. Director, Office of Air Quality Planning and Standards
Office of Air and Radiation
U. S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
1 3. TYPE OF REPORT AND PERIOD COVERED
Final
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
A rule regulating hazardous air pollutant emissions from the steel pickling (HCI process) industry has been proposed
under the authority of sections 101, 112, 114, 116, and 301 of the Clean Air Act, as amended in 1990. This
document presents background information for the proposed rule including industry characterization and emissions,
control technology and performance, model plants and control options, environmental impacts, costs, and economic
impacts. Rules are proposed under 40 CFR 63, Subpart CCC.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b. IDENTIFIERS/OPEN ENDED TERMS
c. COSATI
Field/Group
Air Pollution
Hazardous Air Pollutants
Steel Pickling
National Emission Standards
Hydrochloric Acid
Hydrogen Chloride
Air Pollution Control
Scrubbers
18. DISTRIBUTION STATEMENT
19. SECURITY CLASS (THIS REPORT)
Unclassified
21. NO. OF PAGES
380
21. SECURITY CLASS (THIS PAGE)
Unclassified
22. PRICE
EPA Form 2220-1 (Rev. 4-77) PREVIOUS EDITION IS OBSOLETE
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