United States      Office of Air Quality       EPA-450/3-78-116
Environmental Protection   Planning and Standards      November 1978
Agency         Research Triangle Park NC 27711
Air
A Review of Standards
of Performance for  New
Stationary Sources  -
Iron and  Steel Plants/
Basic Oxygen Furnaces

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                                        EPA-450/3-78-116
A Review of  Standards of Performance
       for New Stationary  Sources -
         Iron and Steel  Plants/Basic
                Oxygen  Furnaces
                           by

                  Marvin Drabkin and Richard Helfand

                Metrek Division of the MITRE Corporation
                   1820 Dolley Madison Boulevard
                     McLean, Virginia 22102
                     Contract No. 68-02-2526



                   EPA Project Officer: Thomas Bibb

               Emission Standards and Engineering Division



                         Prepared for

               U.S. ENVIRONMENTAL PROTECTION AGENCY
                   Office of Air, Noise, and Radiation
               Office of Air Quality Planning and Standards
               Research Triangle Park, North Carolina 2771 1

                       November 1978
                                          ,    -
                                     77 VVt-;t ;.-;::•'••• ; •— -   -•, A -i rlucc
                                     Chicago, it

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This report hasbeen reviewed by the Emission Standardsand Engineering Division of the Office of Air
Quality  Planning and  Standards, EPA, and  approved for publication. Mention of trade names or
commercial products is not intended to constitute endorsement or recommendation for use. Copies of
this report are available through the Library Services Office (MD-35), U.S. Environmental Protection
Agency, Research Triangle Park, N.C. 27711; or, for a fee, from the National Technical Information
Services, 5285 Port Royal Road, Springfield, Virginia 22161.
                            Publication No. EPA-450/3-78-116

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                          TABLE OF CONTENTS
                                                                 Page
LIST OF ILLUSTRATIONS                                            v
LIST OF TABLES                                                   vi

1.0  EXECUTIVE SUMMARY                                           1-1

1.1  Best Demonstrated Control Technology for
     Primary Emissions                                           1-1
1.2  Revision of the Current NSPS                                1-2
1.3  Need for the Development of a Fugitive Emissions
     Control Standard                                            1-3
1.4  Future Growth of the BOPF Segment of the Steel
     Industry                                                    1-4
1.5  Wording of the NSPS Standard                                1-4

2.0  INTRODUCTION                                                2-1

3.0  CURRENT STANDARDS FOR BASIC OXYGEN PROCESS
     FURNACES IN IRON AND STEEL PLANTS                           3-1

3.1  Overview                                                    3-1
3.2  Facilities Affected                                         3-2
3.3  Controlled Pollutants and Emission Levels                   3-2
3.4  Testing and Monitoring Requirements                         3-3
3.5  Definitions in 40 CFR 60, Subpart N, Requiring
     Clarification                                               3-4

4.0  STATUS OF CONTROL TECHNOLOGY                                4-1

4.1  Scope of BOPF Steelmaking Operations                        4-1

     4.1.1  Geographic Distribution                              4-1
     4.1.2  Technological Trends in Raw Steel Production         4-4
     4.1.3  Technological Trends Affecting the BOPF              4-6

4.2  Basic Oxygen Process for Steelmaking                        4-7
4.3  BOPF Particulate Characterization                           4-10
4.4  Control Technology Applicable to the NSPS for
     the BOPF                                                    4-14

     4.4.1  Overview                                             4-14
     4.4.2  NSPS Control Technology in Current Use               4-14

4.5  Comparison of Levels Achievable with Best Demonstrated
     Control Technology Under the Current NSPS                   4-22
                                  iii

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                    TABLE OF CONTENTS (Concluded)


                                                                Page
5.0  INDICATIONS FROM TEST RESULTS                              5-1

5.1  Test Coverage in the EPA Regions                           5-1
5.2  Analysis of Test Results                                   5-1
5.3  Indications of the Need for a Revised Standard             5-4

6.0  ANALYSIS OF THE IMPACTS OF OTHER ISSUES ON NSPS            6-1

6.1  Industry Economics and the Prospects of new BOPF
     Construction                                               6-1
6.2  Control of Fugitive Emissions                              6-5

     6.2.1  Overview                                            6-5
     6.2.2  Characterization of Fugitive Emissions              6-6
     6.2.3  Fugitive Emissions Control Technology               6-12
     6.2.4  Regulation of Fugitive Emissions                    6-19

7.0  FINDINGS AND RECOMMENDATIONS                               7-1

7.1  Findings                                                   7-1

     7.1.1  Economic Considerations                             7-1
     7.1.2  Process Emission Control Technology                 7-1
     7.1.3  Fugitive Emission Control Technology                7-2
     7.1.4  Definitions                                         7-2

7.2  Recommendations                                            7_3

     7.2.1  Revision of the Standard                            7-3
     7.2.2  Research and Development                            7-3
     7.2.3  Definitions                                         7-4

8.0  REFERENCES                                                 8-1
                                 iv

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                        LIST  OF ILLUSTRATIONS
Figure Number
     4-1        Geographical Distribution  of  the U.S.
                Iron and Steel BOPF Steelmaking
                Facilities                                   4-3

     4-2        Raw Steel Production by Process in the
                United States and Canada                     4-5

     4-3        Schematic Layout of the Open  Hood BOPF
                Off-Gas Cleaning System Using ESP            4-18

     4-4        Schematic Layout of the Open  Hood BOPF
                Off-Gas Cleaning System Using Venturi
                Scrubbing                                    4-19

     4-5        Schematic Layout of the Closed Hood BOPF
                Off-Gas Cleaning System Using Venturi
                Scrubbing                                    4-20

     5-1        BOPF Emission Test Data                      5-3

     6-1        Raw Steel Production, Capacity, and
                Process Trends                               6-2

     6-2        BOPF Generation of Charging Emissions        6-7

     6-3        Auxiliary Hood Concept                       6-13

     6-4        Closure Plate Concept                        6-14

     6-5        Furnace Enclosure for a 200-Ton Q-BOP        6-17
                                 v

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                           LIST OF TABLES
Table Number                                                     page

    4-1         BOPF Locations, Design Capacity, Hood
                Design, and Air Pollution Control Device         4-2

    4-2         Typical Particle-Size Distribution of
                Basic Oxygen Furnace Particulate Emissions       4-11

    4-3         Typical Particle-Size Distribution of
                Particulates from Closed Hood Collection
                Process                                          4-12

    4-4         Comparison of Particulate Composition from
                Open and Closed Hood Collection Systems          4-13

    4-5         Comparison of Wet and Dry Gas Cleaning
                Characteristics Dictating Choice                 4-16

    4-6         Comparison of BOPF Control Technologies          4-21

    5-1         BOPF Particulate Emissions Test Data             5-2

    6-1         Amount of Fugitive Emissions from BOPFs          6-8

    6-2         Composition of Fugitive Emissions from
                BOPFs                                            6-9

    6-3         Fugitive Emission Particle Size Analysis         6-11

    6-4         U.S. BOPF Installations with Furnace
                Enclosures for Fugitive Emissions Control        6-20
                                 vi

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1.0  EXECUTIVE SUMMARY

     The objective of this report is to review the New Source Perfor-

mance Standard (NSPS) for the basic oxygen process furnace (BOPF) in

terms of the impact of new developments in control technology, the

steel industry economics, and other issues that have evolved since

the original standard was promulgated in 1974.  Possible revisions

to the standard, based on NSPS compliance test results, are also

analyzed.  The following paragraphs summarize the results and con-

clusions of the analysis, as well as recommendations for future

action.

1.1  Best Demonstrated Control Technology for Primary Emissions

     Particulate matter  emissions associated with the oxygen blow

portion  of the BOPF  steelmaking  cycle are the primary emissions  from

this process and are generated at the rate of approximately 25 to 28

Kg/Mg (50 to 55 Ib/ton)  of raw steel.  The use of a closed hood  in

conjunction with a scrubber or an open hood in conjunction with

either  a scrubber or electrostatic  precipitator are the best demon-

strated  control technologies  for controlling BOPF primary emissions.*

All BOPFs that have  been installed  since 1973 incorporate closed hood

systems  for particulate  emission control.  The closed hood control
 *It  should be  noted  that  standards  of  performance  for  new  sources
  established under Section 111 of the  Clean Air Act reflect emission
  limits  achievable with the best adequately demonstrated technolog-
  ical  system of continuous emission reduction  (taking  into consider-
  ation the cost of achieving  such emission reduction,  and  any nonair
  quality health and  environmental impact and energy  requirements).
                                  1-1

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system in combination with a venturi scrubber has become the system




of choice of the U.S. steel industry primarily due to this system's




energy savings and generally lower maintenance requirements as




compared with the older open hood electrostatic precipitator system.




The closed hood system conserves energy, since approximately 80 per-




cent less air is required to be cleaned than with the open hood




system.  The potential exists (only for the closed hood system) for




using the carbon monoxide off-gas as a fuel source.




1.2  Revision of the Current NSPS




     The rationale for the current NSPS level of 50 mg/dscm (0.022




gr/dscf) for primary stack emissions,  as described in 1973, is still




valid.  As of early 1978 no NSPS compliance tests had been carried




out since the promulgation of the standard.  However, data are avail-




able from emission tests on a limited  number of new BOPFs.   These




tests were carried out using EPA Method 5.   The results of these




tests indicate that primary particulate emission levels of between 32




mg/dscm (0.014 gr/dscf)  and 50 mg/dscm (0.022 gr/dscf) are being




achieved using the same  control technology  as described in the NSPS




background document.  Therefore, it is recommended that the control




level for primary emissions as specified in the current NSPS should




not be changed.
                                 1-2

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1.3  Need for the Development of a Fugitive Emissions Control
     Standard

     Fugitive emissions*,  i.e. emissions not captured by the BOPF

primary emissions control  system, can be generated in significant

amounts during various BOPF ancillary operations.  One of the

principal sources of these emissions, the hot metal charging cycle,

can generate amounts of fugitive emissions on the order of 0.25 Kg/Mg

(0.5 Ib/ton) of charge.  These emissions may contain heavy metals

(including lead, zinc, and cadmium) and a significant amount of par-

ticles < 5 microns in diameter (in the respirable range).  These

emissions are presently uncontrolled in most of the older BOPFs and

only partially controlled in most of the new BOPFs which have come on

stream during the last 5 years.  Regulation of these emissions is

presently minimal.

     Control of fugitive emissions not captured in the BOPF hood and

stack gas cleaning system from ancillary BOPF operations including

hot metal and scrap charging, turndown, and tapping operations is

still a developing technology and requires in-depth study to deter-

mine the most effective methods of fume capture.  The complete fur-

nace enclosure equipped with  several auxiliary hoods, a relatively

high cost technique, is the only currently demonstrated technology

for minimizing or eliminating fugitive emissions  from a new BOPF.
 These are also commonly referred to as secondary emissions.
                                 1-3

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 However,  several  other  techniques  utilizing  auxiliary  hoods  or




 devices may be  almost as effective as the  complete enclosure with  a




 much  lower cost.




      EPA  should continue evaluation of  fugitive emission control




 systems with a view toward  incorporating fugitive emissions  under




 the scope of the  BOPF NSPS  at a  later date.  As part of this




 effort, EPA should develop  a reliable fugitive emission measurement




 method which quantifies overall  capture efficiencies as well as




 emission  levels.  The method should specify  averaging  times  and




 appropriate adjustments for various BOPF configurations.




 1.4   Future Growth of the BOPF Segment of  the Steel Industry




      The present  economic conditions in the U.S. and worldwide steel




 industry have created a significant excess U.S. BOPF capacity and a




 tightening of the availability of  capital  for future expansion.




 These two factors, coupled with  the lack of  industry announcements




 of new U.S. BOPF  construction,  indicate that no construction of new




 BOPFs, which would be subject to a revised NSPS, would likely  com-




mence before 1980, if then.




 1.5  Wording of the NSPS Standard




     Ambiguities  in the wording of the NSPS with regard to the defi-




nition of a BOPF and the component parts of the sampling cycle




require clarification.   Specifically,  the stack emissions  averaged




over the oxygen blow part of the cycle could be significantly differ-




ent from the emissions  averaged over  the entire cycle.   The current
                                 1-4

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standard is unclear as to which averaging time should be used.  Since




no tests to date have come under the NSPS, this has not been an




issue.  However, interpreting the standard could become a problem in




the future.
                                 1-5

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2.0  INTRODUCTION

     In Section 111 of the Clean Air Act, "Standards of Performance

for New Stationary Sources," a provision is set forth which requires

that "The Administrator shall, at least every four years, review

and, if appropriate, revise such standards following the procedure

required by this subsection for promulgation of such standards."

Pursuant to this requirement, the MITRE Corporation, under EPA Con-

tract No. 68-02-2526, is to review 10 of the promulgated NSPS in-

cluding the iron and steel industry BOPF.

     The main purpose of this report is to review the current BOPF

standard and to assess the need for revision on the basis of devel-

opments that have occurred or are expected to occur in the near

future.  This report addresses the following issues:

     1.  A review of the definition of the present standard.

     2.  A discussion of the status of the BOPF segment of the steel
         industry and the status of applicable control technology.

     3.  Analysis of BOPF particulate emission test results and
         review of level of performance of best demonstrated control
         technology for emission control.

     4.  Review of steel industry economics and projections of new
         BOPF construction.

     5.  Discussion of BOPF fugitive emissions and control technology
         presently available.

     Based on the information contained in this report, a set of

findings is presented and specific recommendations are made for

changes in the NSPS.  In addition, recommendations are made for R&D

studies on control technology for fugitive emissions.


                                2-1

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3.0  CURRENT STANDARDS FOR BASIC OXYGEN PROCESS FURNACES IN IRON
     AND STEEL PLANTS

3.1  Overview

     The principal air pollution emission from iron and steel plants

is particulate matter.  In the steel industry, the major sources of

particulate emissions include the basic oxygen process; operation of

open hearth, blast and electric furnaces; and operation of coke ovens

and sintering plants.  The NSPS under review applies only to the

BOPF.

     Due to the nature of the basic oxygen steelmaking process,

particulate control technology is essential to the operation of the

process.  Particulate emissions from BOPFs became subject to regu-

lation under NSPS in 1973.  The existing state and local regulations

designed specifically for BOPFs allowed between two and four times

more particulate emissions than the proposed NSPS, i.e., 0.045 to

0.090 gr/dscf as compared with the NSPS of 0.022 gr/dscf.  After the

promulgation of the NSPS, state limitations submitted pursuant to

Section 110 of the Clean Air Act became only slightly less stringent

than the standard. (EPA, 1973).

     It was estimated that during 1975 the primary metals segment

of industrial processes (point source category) accounted for 1.1

million tons or 10.1 percent of the total 10.8 million tons per year

of point source particulate emissions.  The iron and steel industry

is the largest single industrial category producing particulate emis-

sions from primary metal manufacture.  In 1975 these emissions were

                                 3-1

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estimated to be 0.37 million tons per year or 33.6 percent of the

primary metal segment of the nationwide point source inventory.   The

BOPF segment of the steel industry is estimated to have particulate

emissions of 0.047 million tons per year for 1975 or 12.7 percent of

the steel industry total (Barkhau, 1978).

3.2  Facilities Affected

     The NSPS regulates BOPFs that were planned or under construction

or modification as of June 11,  1973.   An existing BOPF is subject to

the promulgated NSPS if:  (1) a physical or operational change in an

existing facility causes an increase  in the emission rate to the

atmosphere of any pollutant to  which  the standard applies, or (2) if

in the course of reconstruction of the facility, the fixed capital

cost of the new components exceeds 50 percent of the fixed capital

cost that would be required to  construct a comparable entire new

facility that meets the NSPS.

3.3  Controlled Pollutants and  Emission Levels

     Particulate matter is the  BOPF pollutant to be controlled by the

NSPS, as defined by 40 CFR 60,  Subpart N:

         On and after the date  on which the performance
         test required to be conducted ... is completed,
         no owner or operator subject to the provisions of
         Subpart N, 40 CFR 60)  shall  discharge or cause the
         discharge into the atmosphere from any affected
         facility any gases which:  (1) Contain particulate
         matter in excess of 50 mg/dscm (0.022 gr/dscf).

     This standard was derived  from test results from five well-

controlled plants.  These tests indicated that a concentration
                                  3-2

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standard of 50 mg/dscm (0.022 gr/dscf) represented the lowest par-

ticulate concentration achievable by control devices for BOPF emis-

sions.  In addition, designers and manufacturers of all the control

equipment involved can guarantee collection efficiencies that will

achieve an average outlet concentration of 45 mg/dscm (0.020 gr/dscf)

(EPA, 1973).  In Section 5.0, recent non-NSPS emission test results

from BOPFs are discussed and compared with the original test results

which formed the basis for the standard.

3.4  Testing and Monitoring Requirements

     Performance tests to verify compliance with particulate stan-

dards for BOPFs must be conducted within 60 days after the plant has

reached its full capacity production rate, but not later than 180

days after the initial start-up of the facility (40 CFR 60.8).  The

EPA reference methods to be used in connection with BOPF testing

include:

     (1)  Method 5 for concentration of particulate matter
          and associated moisture content.

     (2)  Method 1 for sample and velocity traverses.

     (3)  Method 2 for volumetric flow rate.

     (4)  Method 3 for gas analysis.

     Each performance test consists of three separate runs that are

each 1 hour long with a sampling rate of at least 0.9 dscm/hr (0.53

dscf/min).  The arithmetic mean of the three runs taken is the test

result to which compliance with the standard applies (40 CFR 60.8).
                                 3-3

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Performance test requirements, including provisions for exceptions

and provisions for approval of alternative methods, are detailed in

40 CFR 60.8.

     No continuous monitoring requirement currently exists for NSPS

for BOPFs.

3.5  Definitions in 40 CFR 60, Subpart N, Requiring Clarification

     Several terms specifically defining BOPFs and their NSPS testing

are given in 40 CFR 60, Subpart N.  Two terms require clarification

because of ambiguous wording.

         Basic oxygen process furnace (BOPF) means any furnace
         producing steel by charging a scrap steel, hot metal,
         and flux materials into a vessel and introducing a high
         volume of an oxygen-rich gas.

     The above definition could also be used to describe an oxygen-

lanced open hearth furnace so that any modifications of open hearth

furnaces to include oxygen lancing may come under the NSPS for BOPFs.

         ... the sampling for each run shall continue for an
         integral number of cycles with total duration of at
         least 60 minutes.  The sampling rate shall be at least
         0.9 dscm/hr (0.53 dscf/min) except that shorter sampling
         times, when necessitated by process variables or other
         factors, may be approved by the Administrator.  A cycle
         shall start at the beginning of either the scrap preheat
         or the oxygen blow and shall terminate immediately prior
         to tapping.  (Underline for emphasis.)

     The previous definition is ambiguous for BOPF facilities that

preheat scrap; i.e., do they have a choice of sampling cycle.

Several of these facilities actually preheat scrap external to the

BOPF.   Scrap preheat could add a significant amount of particulate

to the total sampling cycle depending on the quality of the scrap.

                                 3-4

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4.0  STATUS OF CONTROL TECHNOLOGY




4.1  Scope of BOPF Steelmaking Operations




     4.1.1  Geographic Distribution




     The U.S. steel industry is composed of 200 companies operating




in 38 states.  Of the 200 companies, 19 have BOPF steelmaking facil-




ities with a design capacity of about 100 million metric tons per




year (110 million tons per year) (U.S. House of Representatives,




1977).  Table 4-1 presents an inventory of the location, design




capacity, and emission control technology of BOPFs in the U.S. in-




cluding four BOPFs to be dedicated in 1978 by Bethlehem Steel, U.S.




Steel, and Kaiser Steel Corporations.  Locations of these facilities




are shown in Figure 4-1.




     There has 'been a gradual decentralization trend throughout the




country due to the widespread use of the electric arc furnace which




converts  locally generated steel scrap or iron pellet to raw steel.




This grade of steel is then converted to relatively unsophisticated




products  such as reinforcing bars, which do not require sophisticated




finishing processes.




     However, a geographic concentration of large integrated steel




plants that accounts  for 80 percent of the U.S. finished steel




production has developed in Illinois, Michigan, Indiana, Ohio, and




Pennsylvania, due to  the following  factors:  (1) the proximity of




raw materials (about  55 to 60 percent of all coking coal is mined  in
                                  4-1

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                                                  TABLE  4-1
BOPF  LOCATIONS,  DESIGN  CAPACITY,  HOOD  DESIGN,  AND AIR POLLUTION  CONTROL  DEVICE
EPA

REG ION
2
3
















-


5


























8
9



COMPANY
Bethlehem Steel Co.
Republic Steel Co.
Alan Wood Steel Co.
Alleghany Ludlum
Steel Co.
Bethlehem Steel
Corp.
Bethlehem Steel
Corp.
Crucible, Inc.
Jones & Laughlin
Steel Corp.
Jones & Laughlin
Steel Corp.
National Steel
Corp.
Sharon Steel Corp.
U.S. Steel Corp.
U.S. Steel Corp.
burgh Steel Corp.
Annco Steel Corp.
Republic Steel
Corp.
I. S. Steel Corp,
Araco Steel Corp.
Bethlehem Steel Co.
Bethlehea Steel Co.
Ford Motor Co.
Inland Steel Co.
Inland Steel Co.
Interlace, Inc.
Jones & Laughlin
Steel Corp.
*lcLouth Steel Corp.
National Steel
Corp.
National Steel
Corp.
National Steel
Corp.
Republic Steel
Corp.
Republic Steel
Corp.
Republic Steel
Corp.
U.S. Steel Corp.
U.S. Steel Corp.
U.S. Steel Corp.
U.S. Steel Corp.
Wheeling-Pitts-
burgh Steel Corp.
Wisconsin Steel
Youngstown Sheet
«• Tube Co.
CF&I Steel Corp.
Kaiser Steel Corp.
Kaiser Steel Corp.


LOCATION
Lackawanna, N.Y.
Buffalo, N.Y.
Conshohocken , Pa .
Natrona, Pa.

Sparrows Ft. , Md.

Bethlehem, Pa.

Midland, Pa.
Aliquippa, Fa.
Aliquippa, Pa.

Weirton, W,Va.

Farrell, Pa.
Duquesne, Pa.
Braddock, Pa.

Ashland, Ky.
Gadsden, Ala.

Fairfield, Ala.
Middletovn, Oh.
Burns Harbor, Ind.
Burns Harbor, Ind.
Dearborn, Mich.
East Chicago, 111.
East Chicago, 111.
Chicago, III.
Cleveland, Oh.

Trenton, Mich.

Ecoree, Mich.
Ecorse, Mich.
Granite City, 111.

Warren. Oh.

Cleveland, Oh.

So. Chicago, 111.

Gary, Ind.
Gary, Ind.
So. Chicago, 111.
Lorain, Oh.
SteubenvUle, Oh.
So. Chicago, 111.
East Chicago, 111.

Pueblo, Colo.
Fontana, Calif.
Font ana, Calif.

YEAR
INSTALLED
1964/66
1970
1968
1966

1966

1968

1968
1957
1968

1967

1974
1963
1972
1964
1963
1965

1974/78
1969
1969
1978
1964
1966
1974
1959
1961

1958/59

1962
1970
1967

1965

1966/77

1976

1965
1973
1969
1971
1965
1964
1970

1961
1958
1978


NUMBER
3
2
2
2

2

2

2
2
3

2

3"
2
2
2
2
2

3
2
2
1
2
2
2
2
2

5

2
2
2

2

2

2b

3"
3
2
2
2
2

2
3
2

BOP FURNACES
SIZE-Mg (TONS)
270(300)
120(130)
135(150)
75(80)

195(215)

240(270)

95(105)
75(80)
170(190)

350(320)

135(150)
195(215)
210(230)
i in (200)
165(180)
165(180)

180(200)
190(210)
270(300)
270(300)
225(250)
230(255)
190(210)
70(75)
205(225)

100(110)

270(300)
215(235)
215(235)

170(190)

220(245)

180(200)

195(215)
180(200)
180(200)
205(225)
260(285)
110(120)
255(280)

110(120)
110(120)
205(225)
CAPACITY
MM Mg/YEAR
MM (TOSS /YR)
4.5(5.0)
0.9(1.0)
1.8(2.0)
0.4(0.5)

2.7(3.0)

3.1(3.5)

0.9(1.0)
16.0(6.7)


5.2(5.8)

1.4(1.6)
2.2(2.5)
2.2(2.5)
1.4(1.6)
1.8(2.0)
1.3(1.5)

3.2(3.5)
2.0(2.3)
4.0(4.5)
0.9(1.0)
3.4(3-8)
16.0(6.7)
0.9(1.1)
2.7(3.0)

2.5(2.8)

f.2(5.8)

2.2(2.5)

1.9(2.2)

3.3(3.7)

2.0(2.3)

(7.2(8.0)
2.7(3.0)
2.7(3.0)
2.6(2.9)
1.0(1.2)
2.7(3.0)

1.2(1.4)
1.6(1.8)
2.1(2.4)
HOOD DESIGN/AIR POLLUTION CONTROL
OPEN HOOD/ OPEN HOOD/ CLOSED HOOD/
PRECIPITATOR SCRUBBER SCRUBBER
X
X
X
X

X

X

X
X
X

X

x
X
X
X
X
X

X
x
X
x
X
X
JJ
x
X



X
X
X

X

X

X

X
X X
X
X
X
X
X

X
X
X
     facility consists of one standard top-blown BOPF and two Kaldo Process BOPFs, the latter vessels being Inclined and rotating during the oxygen
  blow.  The Kaldo units have been virtually supplanted by the standard fixed unit (EPA, 1977).
 bQ-BOP installation
 SOURCES:  U.S. House of Representatives, 1977.
        EPA, 1977,
           ,    ,
        Nicola, 1978.
                                                      4-2

-------
-p-
i
OJ
                                                                             Legend

                                                                              • RAW STEEL  - BOPF

                                                                                PRODUCING  CENTERS
    SOURCE:
U.S.  House of
Representatives, 1977.

                                      FIGURE 4-1

                 GEOGRAPHIC DISTRIBUTION OF THE U.S. IRON AND STEEL

                            BOPFSTEELMAKING FACILITIES

-------
Pennsylvania, Ohio and Indiana),  (2) the easily accessible transpor-




tation network,  (3) the historic  location of large plants dating back




to  the turn of the century, and (4) the concentration of nearby steel




consuming industries.




     4.1.2  Technological Trends  in Raw Steel Production




     Since 1960  a major shift has been underway in the U.S. steel-




making facilities.  As illustrated in Figure 4-2, the BOPF has sup-




planted the traditional open hearth furnace as the predominant




process for the  production of raw steel.  In 1977 the BOPF produced




62  percent of U.S. steel, up from 3 percent in 1960.  The open hearth




furnace has also fallen behind the electric arc furnace, which pro-




duced 22 percent of the total output in 1977.  The heavy capital




spending for BOPF conversion from open hearth during the 1960s and




early 1970s has  served to modernize, the nation's steel-producing




facilities and improve steel quality and industrial productivity.




The BOPF, which  is a much faster and less labor-intensive process




than the open hearth furnace, has been important in increasing output




per manhour to the point that U.S. industry is  second only to Japan




in  productivity  (U.S.  House of Representatives, 1977).




     Between 1960 and 1970 new BOPFs were coming on stream at the




rate of approximately seven per year.   Since 1970 and including the




four BOPFs to be dedicated in 1978,  this rate of startup has  slowed




to between two and three per year.  Moreover, since the promulgation




of the BOPF NSPS in 1974,  the rate of  new BOPF  startup,  including







                                 4-4

-------
  100,
   80
c
o
u
a
•o

s
cr.
  60
                     Open Hearth-'1
  40
   1952 '
SOURCE: EPA,1977,
1957
1962
1967
1972
                                                                         1977
                                    Year
                                 FIGURE 4-2

     RAW STEEL PRODUCTION BY PROCESS IN THE UNITED STATES AND CANADA
                                   4-5

-------
again the four new BOPFs to be dedicated in 1978, has slowed to




between one and two per year.  Much of the new BOPF capacity has




replaced the corresponding open hearth capacity.  Overall raw steel




production grew only moderately during this period with much of that




growth accounted for by the increased production from electric arc




furnaces.  As a result of the high degree of conversion to BOPFs




already achieved and the unstable economic condition of the steel




industry in general, any growth in BOPF capacity will be tied to




substantial improvement in economic conditions in the industry.  As




of July, 1978, no new BOPF facilities had begun construction and none




are expected to begin before early 1980, if then (see Section 6.1).




     4.1.3  Technological Trends Affecting the BOPF




     The open hearth shops remaining in operation are still candi-




dates for eventual BOPF conversion.  The process of oxygen-lancing




open hearths to increase yield may extend their useful lifetimes.  In




addition, since open hearth operation is relatively unaffected by the




scrap/hot metal ratio in the furnace feed, the future economic condi-




tions of the scrap versus hot metal market may also affect the deci-




sion to  convert from open hearth to BOPF.




     A relatively new BOPF technology that introduces oxygen from




below the furnace, rather than from above as  in  conventional fur-




naces, is the Quality Basic Oxygen Process (Q-BOP) (described in




Section  4.2).  Open hearth furnaces at  the Fairfield works of U.S.




Steel Corporation and at Republic Steel's South  Chicago plant have







                                 4-6

-------
 recently been  converted  to Q-BOPs.   The  chief  advantage  of  these




 conversions  is  in  the use of  existing  open hearth  building  facilities




 and  a  continuity of  steel-making  operations  during conversion.




 4.2  Basic Oxygen  Process for Steelmaking




     In order  to discuss the  status  of control  technology required




 for  BOPF particulate emission control, a review of the basic oxygen




 process and  characterization  of BOPF emissions  is  appropriate.




     The basic  oxygen process  for production of steel uses high




 pressure oxygen to oxidize and remove  carbon, silicon, and other




 undesirable  elements from molten  iron and scrap steel.  The furnace




 operation is cyclic  and the time  required for a complete steel pro-




 duction cycle  is typically 45 minutes, but can  range from about 30




 to 75 minutes due  to variations in shop operating  conditions.  The




 steel production cycle for a  BOPF includes five  basic operations:




     1.  Charging  of scrap and hot metal




     2.  Oxygen blowing




     3.  Testing




     4.  Tapping




     5.  Slagging




     Generally the material  charged to the BOPF consists of 10 to




30 percent scrap and 90 to 70 percent molten pig iron (hot metal).




These relative proportions  are used so that the heat generated by




oxidation of carbon,  silicon,  and manganese,  plus the sensible heat




from the hot metal, provides  sufficient energy to melt  all  the scrap
                                 4-7

-------
and to raise the metal to the correct temperature for tapping.




Charging of scrap and hot metal requires only a few minutes.  Just




after initiation of oxygen blowing and at intervals, as necessary,




slag-forming flux materials (lime, limestone, fluorospar, etc.) are




added to the vessel to remove undesirable elements such as sulfur,




phosphorus, and manganese.




     After the vessel is charged, high purity oxygen is blown into




the charge materials from above the molten charge using a water-




cooled lance.  Oxygen is blown generally for about 18 to 20 minutes;




but due to variations in conditions (including scrap quality) and the




process used, the blowing period can vary from approximately 13 to 26




minutes.  The gases emitted from the furnace primarily consist of CO




and C02 from oxidation of carbon in the metal and oxygen derived




from iron oxides.  The evolution rate of these gases and attendant




iron oxide fumes varies greatly over the entire blowing period.




     After blowing of oxygen for a specified period, a sample of the




metal is taken for analysis.  If the metal is not of correct compo-




sition, additional oxygen is blown for a short period.  If the steel




is of correct composition, the vessel is tapped.  Tapping of the BOPF




is simply the pouring of molten metal from the vessel into a ladle.




     The final operation, slagging, is the removal of slag from the




vessel after completion of a tap and before the vessel is charged




again.  Slag is the fused product formed by the reaction of the flux




materials with impurities in the metal.  Because slag is of lower
                                 4-8

-------
density than the metal, the slag floats on top of the molten metal




bath and the metal can be tapped from below the slag.




     The Q-BOP is the latest version of the basic oxygen process




and is similar to a process developed by Oxygen Blasen Maximillian-




Huette, Bavaria, Germany (OEM process) originated in Europe.  The




Q-BOP process is now being licensed in the United States by the U.S.




Steel Corporation.




     The Q-BOP process is carried out in a modified basic-lined con-




verter which is fitted with bottom tuyeres through which both oxygen




and a hydrocarbon gas are injected.  Concentric tuyeres are built




into the bottom so that the oxygen enters the bath shrouded by a




shield of hydrocarbon gas through the larger of two concentric pipes.




On entry into the vessel, the hydrocarbon is cracked endothermically,




thus absorbing the heat that would otherwise be liberated where the




oxygen first contacts the molten metal.  This absorption of heat




protects the tuyeres from rapid erosion that took place in previous




attempts to bottom blow with oxygen.  The fact that the oxygen is




blown through the bottom rather than from above changes the character




of the slag.  Powdered lime is blown in through the bottom tuyeres




with the oxygen to assist in obtaining a slag that is effective in




removing phosphorus and sulfur from the bath.  This slag apparently




develops a much lower iron oxide content than the slags made in the




conventional basic oxygen process.
                                  4-9

-------
     The benefits of Q-BOP, as compared with conventional top-blown

BOPF, are (Pearce, 1976):

     •  Lower capital investment (greenfield plants*
        as well as open hearth conversions)

     •  Lower operating costs

     •  Higher productivity

     •  Metallurgical advantages.

     Of the 14 BOPFs, which have come on stream in the last 5 years

(through 1978), eight are of Q-BOP design.  Seven of the eight

represent open hearth steelmaking shop conversions, and the eighth

(U.S. Steel, Fairfield, Alabama) is a new Q-BOP started up in 1978.

4.3  BOPF Particulate Characterization

     Particulate matter emissions from BOPFs are produced primarily

by refractory erosion and by condensation of vaporized metal oxides

and coagulation of these particles to form agglomerates.  Thus,  BOPF

particulate matter emissions consist mainly of spherical particles or

agglomerates of spherical particles with similar properties.

     Table 4-2 presents a typical particle-size distribution of BOPF

particulate emissions.  Other investigations have reported that the

mass mean diameter of particulates from top-blown BOPFs varies
 Greenfield plants represent completely new facilities built in
 areas where no steel mills existed previously.

                                 4-10

-------
between 0.5 and 1.0 micron.  Particulates from bottom-blown BOPFs

(Q-BOP) are smaller and generally estimated to be about 0.1 micron in

diameter (EPA, 1977).
                              TABLE 4-2

         TYPICAL PARTICLE-SIZE DISTRIBUTION OF BASIC OXYGEN
                    FURNACE PARTICULATE EMISSIONS
           Particle Diameter                Weight (percent)
              (microns)
                 <1                               25

                1-65                              15

               65-90                              20

               90-110                             15

                 >110                             25


  Source:  Skelly, 1966.



     A significant change in particle size distribution appears to

occur when BOPF emissions are collected in the newer closed hood gas

collection systems as compared with the older open hood gas collec-

tion system.  Table 4-3 presents a typical particle-size distribution

from a Japanese closed hood collection system.
                                  4-11

-------
                              TABLE 4-3

         TYPICAL  PARTICLE-SIZE DISTRIBUTION  OF  PARTICULATES
                 FROM  CLOSED HOOD  COLLECTION PROCESS
Particle Diameter
(microns)
<5
5-10
10-20
20-30
>30
Weight (percent)
8.7
9.0
39.5
28.8
14.0
  Source:   Yawata,  1966.



     Recognizing that these distributions may vary depending on

operating practice  and analytical technique, it is probable that

a much smaller percentage of the particulates from the closed hood

collection system are in the respirable range (_<_ 5 microns in diam-

eter).

     In the closed hood collection process the dust is composed

mainly of iron oxide (FeO), magnetite, and small amounts of metallic

iron.  Because FeO and magnetite agglomerate more easily than hema-

tite, the dust particles are larger than those obtained from the open

hood collection process.  In the latter process, the particles con-

sist of an outer surface of hematite surrounding a core of magnetite.
                                 4-12

-------
Table 4-4 presents a comparison of the composition of particulates

from open and closed hood collection systems.


                              TABLE 4-4

           COMPARISON OF PARTICULATE COMPOSITION FROM OPEN
                AND CLOSED HOOD COLLECTION SYSTEMS3
Component
Fe total
Fe metal
Fe as FeO
Fe as Fe304, Fe2<
CaO
Si02
Open Hood Collection Closed Hood Collection
Process Process
(weight, percent) (weight, percent)
59 75
10
1.6 63
)3b 57.4 .. 2
2 2
1 1
 aPartial analysis is given in each case,
 "Calculated by difference.

 Source:  Cavaghan, 1970.
     The particulate generation rate in the basic oxygen process

depends on several factors such as:  oxygen blow rate, carbon con-

tent of iron, percentage of scrap charged, quality of scrap charged,

rate of additions, and condition of the refractory lining of the

vessel.  During the production cycle the gas evolution rate and gas

temperature vary considerably.  Due to the resultant variations in
                                4-13

-------
the concentration of particulate matter and gas temperature and




volume in the inlet gas stream, emissions are greater in the begin-




ning of the blowing period than during the remainder of the oxygen




blow and the rest of the cycle.  About 50 Ib of particulates and




140 Ib of carbon monoxide (CO) are produced per ton of raw steel.




4.4  Control Technology Applicable to the NSPS for the BOPF




     4.4.1  Overview




     Emission control technology for BOPFs is directed at two types




of emissions:  direct process emissions (primary) and fugitive emis-




sions (secondary).  The current NSPS for the BOPF regulates only




primary process emissions and does not address fugitive emissions




resulting from ancillary BOPF operations.




     The status of control technology, which is currently meeting the




NSPS for BOPF primary emissions, is discussed in the following para-




graphs.  All demonstrated control technologies are in use.  Fugitive




emissions and their control are discussed in Section 6.2.




     4.4.2  NSPS Control Technology in Current Use




     Only one type of emission control system has been installed on




the BOPF since the promulgation of the NSPS.  This system is based on




suppressing or limiting the combustion of off-gases from the basic




oxygen process.




     The basic oxygen process off-gases consist largely of carbon




monoxide and a small proportion of carbon dioxide.  All early BOPFs
                                 4-14

-------
had full combustion or open hood systems.  Large quantities of air




were drawn into the hood above the vessel mouth to burn all of the




hot CO gas to C02 before the gas was cleaned.  This technique re-




quired that large quantities of heat generated by the combustion of




CO be absorbed, and it was necessary to clean not only the furnace




gases but also the oxygen and nitrogen from the combustion air drawn




into the hood.  By limiting the excess air and cleaning only the mix-




ture of CO and C0_, the gas volume to be cleaned has been reduced by




as much as 75 percent.  This substantial reduction has been accom-




plished through the use of a movable skirt positioned during a heat




to limit the air drawn into the hood.  This arrangement minimizes the




mass emission rate of particulate matter from the process.




     Emission control systems designed according to the principle of




limited or suppressed combustion are all of foreign origin.  These




systems specify a high-energy venturi scrubber for cleaning the com-




bustible gases (to minimize the danger of explosions that could occur




in ESP cleaning systems due to the presence of carbon monoxide).  The




closed-hood system designs also specify  that furnaces have a separate




gas cleaning system to avoid the danger  of "dead spots" in the system




and leakage around large valves used to  connect two vessels to one




gas cleaning system.




     Table 4-5 presents a comparison of  the significant features of




wet scrubber and the dry ESP methods for BOPF particulate emissions
                                 4-15

-------
removal.  In the recent BOPF installations, wet scrubbing as exem-

plified by the variable throat venturi has become the method of

choice by the steel industry due to its superiority over the ESP

in terms of maintenance and safety.


                              TABLE 4-5

               COMPARISON OF WET AND DRY GAS CLEANING
                  CHARACTERISTICS DICTATING CHOICE
         Precipitator
         Scrubber
    The precipitator requires
    less fan horsepower than
    that required for a scrub-
    ber because a high pressure
    drop is not required.

    The so-called dry precip-
    itator requires about  15
    percent moisture in the
    gas to attain reasonable
    gas cleaning efficiency.

    Maintenance required to keep
    the precipitator, gas  collec-
    tion,  rapping, and discharge
    systems operating efficiently
    is more sophisticated  than
    that required for wet  scrub-
    bers.

    The precipitator cannot be
    used on closed hood gas
    cleaning systems due to CO
    explosion hazard.
The wet scrubber requires
more  fan capacity to develop
the high pressure drop that is
necessary for high efficiency
gas cleaning.  As a result,
the fan power requirements
are higher than those for a
precipitator.

Water is required in large
quantities.  The effluent
water as well as the gas
must meet all applicable
control regulations.

Maintenance of a scrubber is
significantly simpler than
a precipitator.

Only wet scrubbing systems
are considered safe by most
suppliers for use on closed
hood gas recovery systems
such as the Japanese system.
                                4-16

-------
     Figures 4-3 through 4-5 present schematic flow sheets of typical




open and closed hood particulate emission control systems for BOPFs.




Table 4-6 presents a comparison of the key features of open and




closed hood control technologies.




     A review of the NSPS background document (EPA, 1973) indicates




that the description of applicable control technologies for BOPF




particulate emissions remains unchanged, i.e., closed hood/venturi




scrubber or open hood/ESP or venturi scrubber remain the best demon-




strated control technologies.




     A review of recent installations indicates a strong trend




towards closed hood systems for future BOPFs.  In the last 4 years




(through 1978), six new BOPF installations and one retrofit gas




cleaning installation will have been completed, all using closed hood




systems.  Operational problems with closed hood systems and somewhat




higher capital costs, as described in the EPA NSPS background docu-




ment (EPA, 1973) apparently have not deterred the steel industry from




the use of this control technology.  In choosing closed hood emission




control systems, the industry appears to be influenced by severe




maintenance problems with EPSs and the significantly lower energy




consumption of the closed hood system as compared with open hood




systems.  Additionally, the potential for significant energy recov-




ery exists for closed hood systems if the carbon monoxide (which is




presently flared) is utilized for its fuel value.
                                4-17

-------
AIR
WATER
           BOPF OFF-GAS
         CO COMBUSTION HOOD
         GAS CONDITIONING
             PRIMARY
           DUST SEPARATOR
           ELECTROSTATIC
           PRECIPITATOR
             TO STACK


          FIGURE 4-3
  SCHEMATIC LAYOUT OF THE
  OPEN HOOD BOPF OFF-GAS
 CLEANING SYSTEM USING ESP
               4-18

-------
           BOPF OFF-GAS
AIR
WATER
         CO COMBUSTION HOOD
             QUENCHER
       (LOW VELOCITY VENTURI)
WATER
                I
          SLUDGE SEPARATOR
            HIGH ENERGY
         VENTURI SCRUBBER
                I
         SLUDGE SEPARATOR
                1
          MIST ELIMINATOR
             TO STACK
         FIGURE 4-4
 SCHEMATIC LAYOUT OF THE
 OPEN HOOD BOPF OFF-GAS
  CLEANING SYSTEM USING
     VENTURI SCRUBBING
                4-19

-------
WATER
WATER
           BOPF OFF-GAS
              SKIRT
               HOOD
GAS
COOLER
                1
           LOW VELOCITY
              VENTURI
         SLUDGE SEPARATOR
            HIGH ENERGY
          VENTURI SCRUBBER
          SLUDGE SEPARATOR
       TO FUEL
   OR PROCESS USE
TO STACK  (FLARE)
             FIGURE 4-5
      SCHEMATIC LAYOUT OF THE
         CLOSED HOOD BOPF
      OFF-GAS CLEANING SYSTEM
      USING VENTURI SCRUBBING
                  4-20

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                               TABLE 4-6

                COMPARISON OF BOPF CONTROL TECHNOLOGIES
          Closed Hood
            Open Hood
 •  CO is not burned in hood:
    only process gases have to
    be cleaned.   Gas flow only
    20-25% of open hood flow.
 •  Presence of CO in off-gases
    precludes use of ESP for
    particulate removal.

 •  Process off-gases require less
    heat removal in hood due to
    minimal CO combustion;  there
    is minimal waste heat recovery.
•  Large quantities of air needed
   to combust process-generated
   CO — this requires cleaning
   of excess combustion air in
   addition to process off gases.

•  ESP or venturi scrubber can be
   used for particulate removal.
   Large quantities of waste heat
   required to be removed due to
   combustion of CO in hood; heat
   is recoverable as by-product
   steam.
 •  Achieves lower mass rate of
    emissions (Ib/hr) than open
    hood due to lower gas flow
    rate.
•  Higher mass rate of emissions
   (Ib/hr) due to much higher gas
   flow.
 •  Particulate removal efficiency
    is 99% + .
 •  Much higher percentage of
    larger particles sizes.

 •  Electricity consumption is
     8 KWH/ton of raw steel.3

 •  Potential energy recovery in
    CO off-gas is  0.44 x 10°
    Btu/ton of raw steel.3
•  Particulate removal efficiency
   (both ESP and venturi) is
   99% +.

•  Much higher percentage of
   smaller particles sizes.

•  Electricity consumption is
    14 KWH/ton of raw steel.3

•  No energy recovery from off
   gas.
3EPA,  1976.
                                   4-21

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4*5  Comparison of Levels Achievable with Best Demonstrated Control
     Technology Under the Current NSPS

     The available data from the testing of BOPFs (see Section 5.2)

are not conclusive enough to indicate whether one or the other of the

two best demonstrated control technologies (open hood/ESP or venturi

scrubber or closed hood/venturi scrubber) is clearly superior.  Both

control technologies have demonstrated emission control capabilities

consistent with the NSPS allowable particulate emission level.
                                4-22

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5.0  INDICATIONS FROM TEST RESULTS




5.1  Test Coverage in the EPA Regions




     The MITRE Corporation conducted a survey of all 10 EPA regions




to gather all available NSPS compliance test data generated since




the promulgation of the respective NSPS for each of the 10 categories




under study (MITRE Corporation, 1978).  No NSPS compliance test data




were found for the BOPF category.  Since the NSPS was proposed for the




BOPF segment of the iron and steel industry, only one basic oxygen




furnace has been announced, built, and tested for compliance—that




owned by Republic Steel Corporation of Chicago.  In this case, how-




ever, compliance testing was done for the Illinois EPA to obtain an




operating permit for the unit (Kortge, 1977).  The test procedure did




not meet with the sampling time requirements of 40 CFR 60, Subpart N,




i.e., total sampling cycle for primary particulate emissions was




approximately 40 minutes (60 minutes is the required time interval).




The applicable state emission limit applies to total process




particulate emissions (including some secondary emissions) and is




approximately four times the allowable NSPS mass emission rate.




5.2  Analysis of Test Results




     The results of a number of particulate emission tests on BOPFs




are available including test results for the five BOPFs tested in 1971




and 1972, which formed a portion of the rationale for the NSPS.  Table




5-1 summarizes these results and Figure 5-1 displays these data.




     The original test data for the NSPS included three open hood con-




trolled BOPFs and two closed hood controlled BOPFs.   The additional



                                 5-1

-------
                                                                  TABLE  5-1
                                              BOPF  PARTICULATE EMISSIONS  TEST DATA
Facility
Bethlehem Steel
Bethlehem, Pa.
National Steel
Wierton, w. Va.
Alan Wood Steel
Conshohocken, Pa.
Armco Steel
Middleto-m, Ohio
U.S. Steel
O> Lorain, Ohio
KJ
Inland Steel
E. Chicago, 111.
Bethlehem Steel
Burns Harbor, 111,
Kaiser Steel
Fontana , Cal .
Interlace Steel
Chicago, 111.
U.S. Steel
Fairfield, Ala.
Republic Steel
Chicago, 111.
Nominal
BOPF
Capacity
Mg(tons):
200(220)
295(325)
127(140)
182(200)
200(220)
191(210)
273(300)
109(120)
73(80)
205(225)
228(250)
Particulate
Collection
Hood Design
Open
Open
Open
Closed
Closed
Closed
Open
Open
Open
Closed
Closed
Method of
Oxygen
Blowing
Top
Top
Top
Top
Top
Top
Top
Top
Top
Bottom
(Q-BOP)
Bottom
(Q-BOP)
Test
Date
1972
1971
1971
1971
1971, 1972
1975
1974
1972
1975
1974
1977
Particulate
Removal
Method
ESPa
vsb
ESP
VS
(45"ip)C
VS
(-55"Ap)
VS
VS
(55"Ap)
ESP
ESP
VS
(57"Ap)
VS
Test
Method
EPA 5
EPA 5
EPA 5
EPA 5
EPA 5
EPA 7
EPA 5d
Unknown
Unknown
EPA 5
EPA 5
Average
Primary Stack Emissions
Mg/Nm3 (gr/dsc£)
6K.027)
57(.025)e
15.9(.007)
27(.012)
1K.005), 7(.003)f
18(.008)
50 (.022)
14 (.006)
20 (.009)
32 (.014)
50 (.022)
Reference
EPA, 1973
EPA, 1973
EPA, 19 7 3
EPA, 1973
EPA, 19 73
McDowell, 1978
McDowell, 1978
McDowell, 1978
Inter lake, 1975
McDowell, 1978
Kortge, 1977
  Electrostatic Precipitator
  Venturi scrubber
c Venturi scrubber pressure drop,  inches of water
  Industrial Gas Cleaning Institute (IGCI) method extrapolated to EPA Method 5
e Estimated by EPA from an EPA Method 5 total average particulate catch of 84 Mg/Nm  (.037 gr/dscf)

-------
                 0.040
                 0.030
Particulate
V
co
                 0.010:
                                                                            O   Open Hood
                                                                            D   Closed Hood
                           O     EPA estimate

                                 °         NSPS 0.022
                                                        EPA estimate
                                                      D
                                                                                              •M
                                                                                        D
                                                                      Test Method Unknown
  /
 J"
 'y
ff
                              V
                                                     /    /
                                                    ff     •/

                 (1972) (1971) (1971)  (1971)  (1971)  (1974)  (1975)  (1972) (1975)  (1974) (1977)
                                             (1972)

                                             FIGURE 5-1
                                     BOPF EMISSION TEST DATA

-------
data include three closed hood controlled BOPFs and three open hood

controlled BOPFs.  The available test data, therefore, encompass a

total of six open hood and five closed hood control units.  Based on

an evaluation of these data, there is no discernible trend insofar

as the improvement of efficiency of particulate removal by the best

demonstrated control technology (as compared with the original NSPS

test data).  Although data are insufficient to draw a definite con-

clusion, it appears that closed hood technology may provide a better

emission control capability.

     While the recent emissions data presented in this report are

not the result of NSPS compliance testing, some of the data were

developed through the use of EPA Method 5 (a requirement for NSPS

testing).  Based on this limited information, control technology

capable of meeting the standard is clearly available to the industry.

5.3  Indications of the Need for a Revised Standard

     At this time, there is not sufficient justification for revision

of the present NSPS,  based on the following considerations:

     1.  The best demonstrated control technology is being used in
         all new BOPFs.

     2.  There is a lack of NSPS compliance test data.

     3.  The limited amount of particulate emissions test data
         available do not show a conclusive trend that would
         warrant consideration of an adjustment to the standard.

Economic factors, which also play a key role in the decision not to

revise the NSPS at this time, are discussed in Section 6.1.
                                 5-4

-------
6.0  ANALYSIS OF THE IMPACTS OF OTHER ISSUES ON NSPS




6.1  Industry Economics and the Prospects of New BOPF Construction




     Lead time for construction of new BOPFs ranges from 3 to 5 years,




depending on whether the new units are added to existing steelmaking




facilities or whether they are part of a greenfield plant.  Since




construction of new BOPFs requires large capital investment, it is




important to consider the current overall economic and production




conditions within the domestic and world steel industry to ascertain




the probability of future new BOPF installations.




     Figure 6-1 describes the trends in domestic raw steel production




by type of process as well as the overall production and utilization




rate since 1950.  From Figure 6-1 it is apparent that since 1965,




U.S. raw steel production has been subject to increasingly larger




oscillations, reflecting the fluctuating U.S. and world economies.




     Last year, production was at the same level as it was in 1965,




although overall steelmaking capacity had increased slightly.  Since




the current BOPF NSPS went into effect in 1973, unused capacity has




increased.  Thus, schedules for the introduction of new BOPF facil-




ities in the U.S. have been cancelled or postponed.  In fact, as of




the end of 1977 only one BOPF facility subject to NSPS regulation has




come on stream (Republic Steel, South Chicago, Illinois).  In 1978,




Bethlehem Steel (Burns Harbor, Indiana), Kaiser Steel (Fontana, Cali-




fornia), and U.S. Steel (Fairfield, Alabama) will have a total of four




BOPFs coming on line which will be subject to NSPS testing.  Three of







                                6-1

-------
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-------
these units had been scheduled to start up in 1974.   Several planned




BOPFs have been either delayed or cancelled,  including a Bethlehem




Steel BOPF facility in Johnstown, Pennsylvania,  a Jones & Laughlin




facility in Pittsburgh, a National Steel facility in Portage, Indiana,




and a Youngstown Sheet and Tube Company facility in Campbell, Ohio.




The total capacity of these plants would have added approximately 9




million Mg/year (10 million tons/year) in BOPF capacity in 1979 if




they had been built (EPA, 1977).  Furthermore, during 1977 Bethlehem




Steel reduced its overall steelmaking capability by 10 percent (2.3




million Mg/year) through the shutting down of facilities at Johns-




town, Pennsylvania and Lackawanna, New York.   The Alan Wood Steel




Company BOPF facility has closed down permanently.  It had a capacity




of 1.0 million Mg/year (U.S. House of Representatives, 1977).




     Several companies, besides those described above, appear to be




actively considering construction or modification of BOPF facilities.




These include a complete greenfield facility for U.S. Steel at




Conneaut, Ohio, for which a draft environmental impact statement was




recently published (Corps of Engineers, 1978).  The total of all the




proposed construction mentioned above would result in an approximate




increase of 18 percent in raw steel capacity by 1985 and 15 new BOPFs.




Construction of these BOPFs would not be expected to commence before




early 1980 even if improved economic conditions prevail (Bloom, 1978).




However, it is unknown whether construction of some of these units




will be further delayed or cancelled.
                                  6-3

-------
     In September,  1977 the U.S.  House of Representatives held hear-

ings on the current trends and problems associated with the domestic

and world steel industries (U.S.  House of Representatives, 1977).

The current economic problems of  the U.S. and world industry were

described as follows:

          ...slow growth in the world economy and conse-
          quent depressed demand, excess capacity, unem-
          ployment and low profits and prospects on the
          immediate future are for more of the same....
          (U.S. House of Representatives, 1977)

     Worldwide excess capacity has affected the U.S. steel industry

through highly competitive pricing of foreign imports which have

reached 18 percent of total domestic consumption during the first

quarter of 1978 (Wall Street Journal, 1978).  As an outgrowth of the

hearings the Department of the Treasury established a set of "trigger

prices" for imported steel products.  The trigger prices would estab-

lish minimum price levels for imported steel products below which  an

antidumping action would be implemented if necessary.  The effect,

if any, of the trigger price on the production of U.S. steel will  be

felt beginning with the second quarter of 1978 (42 FR 65214, 1977;

43 FR 1463, 1978).

     In comparative analyses of the Japanese and American steel indus-

tries conducted for setting the trigger prices, a significant lag in

processing efficiency of U.S. steel plants as compared with Japanese

plants was noted with respect to conversion of raw steel to finished

products (43 FR 1463, 1978).  It is likely that future expansion of
                                6-4

-------
capacity by the U.S. industry will emphasize modernization of the




processing of raw steel similar to its prior emphasis on open hearth




conversion to BOPF in the 1965-1975 period.  In its forecast of future




capital expenditures, Iron and Steel Engineering (January, 1978) con-




firmed this trend of no new BOPF construction and increased emphasis




on finishing modernization.




     In summary, the world economic climate and the status of current




domestic raw steel production resources indicate that little, if any,




expansion of U.S. BOPF capacity will take place over the next few




years.  The uncertainty of new BOPF construction minimizes the neces-




sity of NSPS revision at this time.  However, EPA can review the NSPS




at any time, i.e., before the next mandatory review in 1982, should




circumstances dictate.




6.2  Control of Fugitive Emissions




     6.2.1  Overview




     Inasmuch as the primary emissions from the BOPFs appear to be




adequately controlled, collection of secondary (fugitive) emissions




has now become the major particulate control problem for this source




category.  The problem arises from the difficulty of efficiently




collecting significant amounts of fumes generated during several dis-




tinct operational phases of the basic oxygen steel production cycle




both from top-blown BOPFs, i.e., charging and tapping, and bottom-




blown BOPFs (Q-BOPs), i.e., charging, turndown and tapping.  Once




these fumes escape from the source into the building, they are almost




impossible to control and create a visible emission that leaves the



                                 6-5

-------
BOPF building via  the  roof monitor.  Possible major  sources of  fugi-




tive emissions within  the BOPF building  include:   (1)  the operating




furnace  (puffing during oxygen blow),  (2) charging mechanisms for  lime




and other process  (flux) additives, (3)  scrap charging, (4) hot metal




charging, (5) slagging and (6) tapping.  These emissions contain lead




and zinc oxides and hydrocarbons depending on the nature of the scrap




used.




     In  the following sections, data are presented on  the character-




ization  of the BOPF fugitive emissions (including data on amounts




and composition) and the state-of-the-art with respect to fugitive




emission control technology.  This is  followed by a discussion of




the problems entailed in developing a standard for the regulation




of fugitive emissions.




     6.2.2  Characterization of Fugitive Emissions




     A significant quantity of fugitive emissions is generated during




turndown of the BOPF and during charging of hot metal into the furnace




already holding a charge of scrap.  During charging of scrap and hot




metal to the vessel prior to the oxygen blowing operation, the vessel




must be tilted out from beneath the hood system (generally 25° to 30°




from the vertical) to provide access to the charging mechanisms.




Emissions generated during this charging period are not captured




effectively by the main hood system (Figure 6-2).




     Several studies have attempted to determine amounts and com-




position of fugitive emissions leaving the BOPF.   Results  of these




studies are tabulated in Tables 6-1 and 6-2,  respectively.




                                 6-6

-------
Off-Gas  Collection
  System
                                               Uncontrolled
                                                 Emissions
                                                     Hot Metal
                                                     Transfer
                                                     Ladle
                                       BOP Vessel
                       FIGURE 6-2
       BOPF GENERATION OF CHARGING EMISSIONS
                          6-7

-------
                                                                  TABLE  6-1
                                          AMOUNT  OF  FUGITIVE EMISSIONS FROM  BOPFS
Facility
U.S. Steel
Fairfield, Ala.
Republic Steel
Chicago, 111.
Interlake Inc.
Chicago, 111.
Colorado Fuel
& Iron
Pueblo, Colorado
National Steel
Wierton, W.Va.


Nippon Steel
Oita, Japan
O
1 Japanese BOPF
00 Practice
Nominal
BOPF Size
Mg(ST))
205(225)a

228(250)a

73(80)

109(120)


325(360)


340(374)




Average
Production Rate
Mg/day(ST/day)
5870(5600)

6990(7680)

2180(2400)

2620(2880)


11,270(12,380)


14,360(15,785)




Total Fugitive
Emission Rate
Kg/day(lb/day)
1454(3200) C

Unknown

366(806)d

1538(3400)e
f
215(474) r
4075 (9000) g
2680 (5900) h
10, 730(23, 600)1
9900 (21, 800) ^
18, 600(41, 000)k




Total Fugitive
Emission Rate
Kg/Mg charged
(Ib/ton produced)
0.28(0.57)

Unknown

0.17(0.34)

0.43(0.86)
0.06(0.12)
0.34(0.68)
0.23(0.45)
0.80(1.79)
0.83(1.65)
1.3(2.6)


0.2-0.3(0.4-0.6)

Fugitive Emissions
Capture Rate
Kg/day/lb/day
465(1024)m

121(266)

None

Unknown
Unknown
None
None
None
None
18,500(40,600)"




Fugitive Emissions
Capture Efficiency
(percent)
32

Unknown

None

Unknown
Unknown
None
None
None
None
99




	 Reference 	
Gibbs, 1978

Kortge, 1977

Interlake, 1975

Seton et aL , 1976
Seton et aL , 1976
EPA, 1977
EPA, 1977
EPA, 1977
EPA, 1977
McCutchen, 1977


Nicola, 1976

  Q-BOP process
  Based on a 24 hour day  and the appropriate  cycle time for each plant.
 Amount measured at  the roof monitor plus  capture by fugitive emission hood-baghouse system.  These were measured only during
 the hot metal charging period and do not  include emissions from tapping, slagging or turn-down periods.
  Amount measured at  the  roof monitor.                            ,
  Not Including a limited amount of fugitive emissions  captured by an auxiliary hood.
  Hot metal  charging  emissions only measured at the roof monitor (total  based on 45  minute cycle, 2 minute hot metal pouring time).
  Hot metal  charging  emissions only based  on 45 second  average pour time; clean scrap used.
  Hot metal  charging  emissions only based  on 45 second  average pour time; galvanized scrap used.
  Hot metal  charging  emissions only based  on 45 second  average pour time; oily scrap used.
•* Hot metal  charging  emissions only based  on 45 second  average pour time; No.  2 scrap (principally galvanized sheet)  used.
  Design basis of fugitive emission collection system.
  This range of values given for hot metal pour cycle fugitive emissions only.
m As of April 1975, this  system has been subsequently modified  to improve fugitive  emissions capture efficiency.
n Design basis of fugitive emissions hood  and baghouse  system.

-------
                                                    TABLE  6-2




                                COMPOSITION OF FUGITIVE  EMISSIONS FROM BOPFS
•o
Facility
itlonal Steel
terton, W.Va.











ilorado Fuel
Iron Corp.
leblo, Col.

ilorado Fuel
Iron Corp.
ieblo, Col.


Source of Fugitive
Emissions Fe FeO Fe2°3 Ca°
Hot Metal Charging
Emissions:
a) Clean Scrap in 13.1 12.7 8.3 3.5
Initial Charge
b) Galvanized Scrap 3.3 8.3 12.7 2.0
in Initial Charge
c) Oily Scrap in 11.3 16.7 10.6 2.9
Initial Charge
d) No. 2 Bundles 3.8 17.6 10.5 1.7
in Initial Charge
(large % of gal-
vanized sheet
scrap)
Total Fugitive
Emissions as , -
Collected at Building '° "'
Roof Monitor
Baghouse particulate
collected from aux-
iliary hood capturing 32.6 6.7
charging and tapping
emissions
Benzene Soluble
MgO SiO- PbO ZnO MnO C Cd Organics Reference


1.0 5.2 0.3 3.4 0.5 34.3 EPA, 1977

0.5 2.6 0.2 5.3 0.3 60.3 EPA, 1977

0.7 3.0 0.8 8.1 0.6 37.8 (a) EPA, 1977

0.5 2.8 1.8 12.0 0.6 41.5 EPA, 1977





8.6 6.7 <4.1 6.8 1.1 3.2 <1.0 1.2 Love, 1976



1.0 6.4 2.0 16.2 1.4 8 .2 Love, 1976


     Gaseous methane averaged 61 ppm.

-------
      Inspection of these  two tables permits several  conclusions:

      1.   The quantity  of  fugitive  charging  emissions appears  to
          average approximately 0.25 kg/Mg (0.5  Ib/ton)  of BOPF
          charge, except  in the case of  "dirty"  scrap in which
          a^significant increase in the  amount of  charging emis-
          sions  occurs. There are  no definitive U.S.  data avail-
          able on the total fugitive emissions from the  BOPF.
          The total fugitive emissions given for one  Japanese  BOPF
          cited  is based on the design emission  collection rate
          for the secondary hood collection  system and is probably
          a  highly conservative value.   Incidentally,  the Japanese
          BOPFs  have been  operating with 90  to 100 percent charging
          of hot metal  in  combination with 10 to 0 percent in-house
          scrap  as compared with the typical 30  percent  scrap,  70
          percent hot metal charge  used  in the U.S.  As  a result,
          the composition  of fugitive emissions  from Japanese  and
          U.S. BOPF operations  differs substantially.  Particulate
          matter collected  from Japanese BOPF operations  can be
          recycled; particulate matter from  the  U.S.  operations
          is presently  disposed of  due to  the high zinc  content.*

      2.   The percent of zinc  oxide  in fugitive  charging  emissions
          increases significantly when "dirtier" grades  of scrap are
          used.   There  is  a limit on the amount  of high  quality scrap
          available, and the usage  of lower quality scrap  containing
          impurities which  result in additional  charging  emissions
         will increase as  the  world  market  for  steel  increases.  The
          need for  effective  secondary emission  control will,  there-
          fore,  become  more  imperative during the  next 5  to 10  years.

      3.  The data  available with which  to judge the effectiveness of
          control  of fugitive emissions  by existing secondary  control
          systems are meager at  present.    Further  studies  are needed
          in  this  area  to fully  evaluate the collection efficiencies
         of various control configurations.

     4.  Composition of fugitive emissions is quite variable,  but this
         material  appears  to be predominantly carbon  and  oxides of
         iron with lesser amounts of calcium oxide,  silicon dioxide,
         zinc oxide and lead oxide.  Oily scrap in the initial BOPF


*Processes to recycle particulate matter  from BOPF emission collec-
 tion operations after separation  of the zinc values, are available
 (Georgieff,  1978).  However, the steel industry does not consider
 processing of  high zinc-bearing waste  particulate  economically
 feasible at this  time (Jackson, 1978).


                                 6-10

-------
          charge will  lead  to  the  presence  of  significant  hydrocarbon
          levels in  the  fugitive emissions.

      Limited data from  one  study  indicate  that  the  average median

 diameter  of charging  emissions determined  from  several  tests  is  2  to

 3 microns, independent  of  the type  of  scrap used  in the initial  charge

 (EPA,  1977).   In another study, particle size range analyses  were  made

 on  fugitive emissions leaving the building monitor, as well as on  par-

 ticulate  matter collected  in  the  secondary emission collection bag-

 house  hopper.  These  results are  shown in Table 6-3.

                              TABLE 6-3

               FUGITIVE EMISSION  PARTICLE SIZE ANALYSIS
Building Monitor Particulate Baghouse Hopper Particulate
(Percent)
5-50
30 - 70
80 - 99
<14







(Microns) (Percent)
<0.5 3.6
<1 13.7
<5 30.3
>10 19.6
12.5
7.1
3.8
3.3
3.7
2.3
Largest Particle -
(Mi

0.70
1.41
2.82
4.23
5.64
7.05
8.45
9.87

16.9
.crons)
0.70
- 1.41
- 2.82
- 4.23
- 5.64
- 7.05
- 8.45
- 9.87
- 14.1
15.5
microns
     As evidenced by the particle size analysis, the test results

indicate that 80 to 90 percent of the particulate material escaping

from the building roof monitor and collected by the existing baghouse

system is estimated to be in the range of 5 to 10 microns in diameter

and/or respirable in nature.


                                 6-11

-------
     6.2.3  Fugitive Emissions Control Technology




     A literature survey has been conducted to develop information on




charging emissions control technology on both new and existing BOPFs




(EPA, 1977).  Of the eight U.S. BOPF fugitive emission control systems




described in the literature, seven employ auxiliary hoods located near




the charging area, tied into the main process emissions cleaning sys-




tem, i.e., connected into the main hood exhaust system upstream of the




EPS or venturi particulate removal device.  The effectiveness of these




systems depends largely on the available fan capacity of the main hood




system (since much larger volumes of the emission-laden BOPF room air




are required to be removed as compared with the primary emissions




system), and the location of auxiliary hoods with respect to the




points of discharge of the charging, reladling and tapping fugitive




emissions.  The eighth system described in the literature features the




use of the Gaw patented damper.  In this system, the main hood is




partially blocked by a sliding damper which increases the velocity in




the charging emission area, thereby increasing the effectiveness of




the primary hood system.  The Gaw system is currently being evaluated




at one BOPF installation.  Figures 6-3 and 6-4 illustrate the auxil-




iary hood and Gaw damper concepts, respectively.




     Little or no data were reported in the literature on the success




of auxiliary hood systems in recovery of fugitive emissions from the




BOPF.  This, coupled with the wide diversity of hood configurations
                                6-12

-------
  FURNACE
CHARGING  AISLE
                     CRANE GIRDER
                     CANOPY  HOOD
                        CHARGING
                        LADLE
      FIGURE 6-3
AUXILIARY HOOD CONCEPT
        6-13

-------
£URNACE
"* AISLE
                                  CHARGING AISLE
                                     CRANE
                                     GIRDER
RETRACTED
POSITION
      CLOSURE
      PLATE
                                      CHARGING
                                      LADLE
                       FIGURE 6-4
                  CLOSURE PLATE CONCEPT
                         6-14

-------
reported, prevented a definitive conclusion about the utility of




auxiliary hoods for fugitive emissions capture.




     Application of the auxiliary hood, e.g., canopy hood concept to




an existing (retrofit) or new BOPF installation for charging emissions




control will require accurate, prediction of fume volumes and veloc-




ities for a variety of hot metai charging operations.  Since these




conditions are not completely predictable, the design of canopy hood




systems to capture charging emissions  from BOPF furnaces would be




difficult.  Available data indicate that the emission volume rate




required divided by the vessel tonnage should be in the range of 33




to 81 m3/min/Mg (1,100 to 2,600 cfm per ton) (EPA, 1977).  It is




apparent from the over twofold variation of this number, that design




of canopy hood systems at this time is highly empirical, and a large




margin of safety in hood design is required to assure achievement of




design control level.  The application of a canopy hood requires con-




sideration of the type of air pollution control system and fan capac-




ity needed, and dimensional restrictions and operating clearances




unique to individual shops.  Due to the distance of these hoods from




the emission source, consideration must also be given to the adverse




effects  of cross drafts in the shop which affect collection effi-




ciency.  Major advantages of the canopy hood concept are that it




involves minimum constraints and changes to operating practices, and




that  auxiliary mechanical or electrical devices are not required in




the immediate vicinity of the furnace.







                                 6-15

-------
     Collection of BOPF fugitive emissions by means of a total furnace




enclosure appears to offer a comprehensive solution to this problem,




since it allows collection of emissions at the source and prevents




their escape into the atmosphere.  With properly designed total fur-




nace enclosures, it should be possible to effectively control scrap




charging, hot metal charging, furnace tapping, ladle alloy additions,




furnace slagging, and puffing emissions with relatively low exhaust




volume s.




     Figure 6-5 shows a typical schematic arrangement and design of




a BOPF enclosure in which the enclosure essentially forms a gas-tight




seal when the biparting doors are closed.  Since the furnace enclosure




extends below the charging floor, the only openings are for the ladle




car.  However, these openings can be effectively reduced by the addi-




tion of a vertical shield on the end of the ladle car, which will also




increase the efficiency of the furnace enclosure.




     Enclosures of this type were initially developed to control emis-




sions from the Q-BOP process.  However, the original enclosure designs




have been modified to effectively collect the charging, tapping and




slagging emissions generated during the oxygen steelmaking process,




in addition to puffing emissions during the oxygen blowing period




(Nicola, 1976).




     Present furnace designs incorporate a secondary hood inside the




furnace enclosure with sufficient volume for efficient charging




emission control.  At present, systems of this type are effectively







                                 6-16

-------
             FIGURE 6-5
FURNACE ENCLOSURE FOR A 200-TON Q-BOP
     (REPUBLIC STEEL CORPORATION
        SO. CHICAGO, ILLINOIS)

                6-17

-------
controlling fugitive emissions with exhaust volumes of approximately




350,000 acfm (Nicola, 1976).




     For controlling emissions during the blow and tapping periods,




the biparting doors are closed, forming an essentially gas-tight seal




while the fumes are evacuated from the enclosure through .the main or




secondary hood.  During charging, the biparting doors are opened




while charging scrap or pouring hot metal and the fumes are collected




through the secondary hood located inside the enclosure directly above




the furnace mouth  (Nicola, 1976).




     With a properly designed furnace enclosure (including appropriate




secondary hoods),  it is possible to collect secondary emissions from




the basic oxygen process with approximately 90 percent efficiency,




provided the charging of the hot metal into the furnace is done at  a




controlled rate and  the scrap is relatively clean  (Nicola, 1976).




     Seven new BOPF  vessels that have been  installed  in the U.S. in




the past 7 years have incorporated a partial or full  furnace enclosure




for collection of  fugitive  emissions as  part of the  original partic-




ulate  emission control  system.   Since the early furnace enclosure




designs had  many deficiencies,  these systems are  operating  today with




varying degrees  of success.   Six new furnace enclosure  installations




 (due  to commence operations in 1978)  including  four  on  new  BOPFs  and




 two retrofit installations  will incorporate a  secondary hood  inside




 the  furnace  enclosure  with  sufficient volume  for  fugitive emission




 control.   These  systems should be  capable  of  effectively collecting
                                  6-18

-------
 the oxygen steelmaking fugitive emissions under controlled conditions.




 Table 6-4 lists the recent known BOPF furnace enclosure installations.




      6-2.4  Regulation of Fugitive Emissions




      Fugitive emissions,  e.g.,  emissions not captured by the BOPF pri-




 mary emissions control system,  can be generated in significant amounts




 during various BOPF ancillary operations.   During the hot metal charg-




 ing portion of the BOPF production cycle,  fugitive emissions can




 amount to 0.25 Kg/Mg (0.5 Ib/ton)  of  charge while total fugitive emis-




 sions may amount  to 0.5 to 0.75 Kg/Mg,  (1-1.5  Ib/ton).   Therefore,  a




 NSPS should be considered for control of these  emissions.




      Regulation of fugitive emissions is presently minimal,  i.e.,




 insofar as  is  known there are no specific  Federal or  state BOPF




 fugitive emission  control regulations.   However,  Section 173 of the




 Clean Air Act  requires, among other things,  that  a new  or modified




 source constructed in  an  area in violation  of the National Ambient Air




 Quality Standards  (NAAQS),  e.g., in a non-attainment area, must  reduce




 emissions to the level  which  reflects the "lowest  achievable  emission




 rate"  (LAER) for such  category  of  source as  defined in  Section  171(3).




 When  a  source  is constructed  in  an attainment area, the  source  becomes




 subject  to  the  "prevention  of significant deterioration" (PSD)  air




 quality  provisions of  the act (Part C).  An  example of  these




 requirements being applied  to a new BOPF in a non-attainment  situation




 is the U.S. Steel Q-BOP at  the Fairfield, Alabama plant.  This BOPF




has had a fugitive emission standard applied of 0.01 gr/dscf.  This
                                  6-19

-------
o
 I
                                                    TABLE  6-4



              U.S. BOPF INSTALIATIONS WITH FURNACE ENCLOSURES FOR FUGITIVE EMISSIONS CONTROLS
No. of
Units
Facility Enclosed
Inland Steel 2
E. Chicago, 111.
U.S. Steel 3
Gary, Ind.
D.S. Steel 2
Fairfield,
Ala.
U.S. Steel 1
Fairfield ,
Ala.

Republic Steel 2
Chicago, 111.


Bethlehem Steel 1
Burns Harbor, Ind.


Kaiser Steel 2
Font ana, Cal.



Colorado Fuel 4 2
Iron
Pueblo, Col.

BOPF
Nominal Size
Ms(tons)
190(210)

180(200)

180(200)


180(200)



180(200)



270(300)



205(225)




110(120)




Type of Furnace
Enclosure
Partial

Complete

Complete


Complete



Complete



Complete



Complete




Complete



Year of
Furnace Enclosure
Installation
1975

1971

1973


1978



1977



1978



1978




1978



Effectiveness of
Fugitive Emissions
Capture
Fair

Fair

Fair


Not yet operating



Good charging
emissions. Poor-
tapping emissions

Started operations
Spring, 1978


Starting operations
Fall, 1978



Starting operations
Fall, 1978




Remarks
Tapping emissions capture remains a
problem.
No secondary hood available for
charging emissions capture.
Secondary hood for charging emissions
installed outside of furnace enclosure .

EPA consent decree requires installation
of secondary charging emissions hood
inside furnace enclosure tied to a
200,000 CFH baghouse system.
Secondary charging emissions collec-
tion hood installed inside furnace
enclosure tied to primary exhaust
system.
Secondary charging emissions collec-
tion hood installed inside furnace
enclosure tied to primary exhaust
system.
All fugitive emissions processed
through a 600,000 CFM baghouse system.
Secondary charging emissions collec-
tion hood installed inside furnace
enclosure.
Retrofit system; vendor claims that
there has been no Interruption of
steel production from the BOPF during
installation of furnace enclosure.
     *Nicola, 1978, unless otherwise indicated.


     bMiller, 1978.

-------
standard resulted from a March 31, 1978 consent decree and does not




become effective until system revisions and performance testing are




complete.  U.S. Steel has until August 31, 1980 to achieve compliance




(United States District Court, 1978).




     Several engineering/economic areas should be further researched




before a fugitive standard is promulgated.  For instance, because the




NSPS can apply to a new BOPF vessel in an existing location,  varia-




tions in space and operating constraints may require many different




control techniques to meet a common standard, with a resultant wide




spread in capture efficiencies and control costs.  To date, experi-




mentation with fugitive emission control techniques that, in exist-




ing locations, require a minimum of space and new equipment have not




yielded satisfactory emission control and/or have had unreliable




performance.




     When an entirely new BOPF shop is to be built, it appears that




complete furnace enclosures with modern seals and separate venting




and removal equipment (e.g.., baghouses) may provide good control of




fugitive emissions.   A minimal amount of emissions information is




available on the effectiveness of this approach to fugitive emissions




control.  Several locations starting up in 1978 will incorporate com-




plete furnace enclosures for fugitive emissions control as an inte-




grated part of the BOPF facility and should supply information for




quantification of an emissions level.
                                 6-21

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      A fugitive  emissions  standard would  also  require  an  applicable




measurement  technique  if based  on a quantitative grain loading.  An




EPA method that  normalizes  fugitive emissions  would be required  to




ensure a  fair  system of measurement due to  the many different physical




variations in  facilities and the dispersed  nature of the  emissions.




A  standard based on emissions levels from a control device should also




incorporate  a  capture  efficiency measurement.  For example, a baghouse




system should  operate with  a very low emissions rate.  However,  if the




majority  of  the  fugitive emissions escape the  collecting hood leading




to the  baghouse  system, such a  standard would  be ineffective in  its




intent  to control these emissions.




      It is recommended that a fugitive emissions standard not be con-




sidered during this review period, based on the following:  (1)  there




appears to be  a  lull in new BOPF construction  due to the financial




status  of the  steel industry and the almost completed  conversion from




aging open hearths to BOPFs, (2) further research and development is




required on  fugitive emission measurement techniques;  and (3) informa-




tion on relative costs versus control effectiveness is required  (this




should be forthcoming within the next 1 to 2 years).  However,  as data




are developed EPA should reexamine the promulgation of such a standard




earlier than the required 4-year NSPS review period.  In the interim,




EPA should monitor the effectiveness of new plant controls and  further




research measurement and control techniques applicable to fugitive




emissions from new BOPFs.
                                  6-22

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7.0  FINDINGS AND RECOMMENDATIONS

     The primary objective of this report has been to assess the need

for revision of the existing BOPF NSPS including the possible need to

develop a standard applicable to BOPF fugitive emissions.  The find-

ings and recommendations developed in these two areas are presented

below.

7.1  Findings

     7.1.1  Economic Considerations

     •  The large conversion from open hearth furnaces to BOPF
        occurred during the 1960 to 1970 period.

     •  The present economic conditions in the U.S.  and worldwide
        steel industry have created a significant excess U.S. raw
        steel capacity and a tightening of the availability of
        capital for future expansion.

     •  Since the promulgation of the BOPF NSPS, there has been
        a significant slowdown in new BOPF construction due to
        the economic condition of the industry.  Three of the
        four units scheduled for startup in 1978 had been planned
        to begin production in 1974.

     •  No new BOPF construction activity is  expected before early
        1980.  Even this date is subject to slippage if economic
        conditions in the steel  industry do not improve significantly.

     7.1.2  Process Emission Control  Technology

     •  Since the promulgation of the NSPS for the BOPF,  no NSPS
        compliance tests have been performed  on BOPFs.

     •  The best demonstrated control technologies described in
        the ..NSPS background document  have  not  changed in  the last
        4 years.

     •   Limited  emissions test data available  from recent BOPF
        installations  show particulate  emission levels  between
        32  mg/dscm (0.014 gr/dscf)  and  50  mg/dscm (0.022  gr/dscf).
                                7-1

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 •  Emission levels lie in the same range as the data used as
    part of the rationale for the original NSPS of 50 mg/dscm
    (0.022 gr/dscf).

7.1.3  Fugitive Emission Control Technology

•  Fugitive emissions from BOPFs are primarily generated from
   three distinct operational phases of the basic oxygen steel
   production cycle:  charging,  turndown and tapping.

•  The largest amounts of fugitive emissions occur during the
   hot metal charging portion of the BOPF production cycle.

•  The total quantity of fugitive emissions appears to range
   from 0.5 to 1 kg/Mg BOPF charge (1 to 2 Ib/ton), depending
   on the degree of contamination of the metal scrap charge.
   Zinc and lead oxides and hydrocarbons can be present in
   significant levels in fugitive emissions when "dirty"
   grades of scrap are used.

•  Design of hoods for collection of fugitive emissions from
   existing BOPFs has so far been highly site-specific.  This
   is due to limitations on available space and exhaust capac-
   ity.  Local hoods for collection of these emissions appear
   to have had only limited success to date.

•  Fugitive emission control from the ancillary BOPF operations
   is still a developing technology and will require in-depth
   studies to determine and develop the most effective methods
   of fume capture.

•  The complete furnace enclosure is the only currently de-
   mon 'trated control technology exhibiting the potential for
   minimizing or eliminating fugitive emissions from a new
   BOPF.

7.1.4  Definitions

•  Ce   lin ambiguities exist in the definition of the affected
   fa  iity and in the testing requirement contained in 40 CFR
   60  Subpart N.
                            7-2

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7.2  Recommendations

     7.2.1  Revision of the Standard

     At this time, there is not sufficient justification for revision

or inclusion of fugitive emissions under the present NSPS, based on

the following considerations:

     •  The best demonstrated control technology for process emis-
        sions is being used on all new BOPFs.

     •  The limited amount of particulate emission test data avail-
        able does not show a conclusive trend which would warrant
        consideration of an adjustment to the primary emission
        standard.

     •  There is as yet insufficient data with which to make a
        judgment as to the availability of a satisfactory method
        for quantitative measurement of fugitive emissions from a
        BOPF.

     •  Definitive data on a best demonstrated control technology
        for efficient fugitive emission capture from new BOPFs have
        not yet become available.

     •  The impact of any revised NSPS would be very small due to
        the low growth rate of the industry.

     7.2.2  Research and Development

     EPA should continue evaluation of fugitive emission controls for

BOPFs with a view toward incorporating fugitive emissions under the

scope of the standard at a later date.  In addition, an EPA measure-

ment standard technique must be devised to include capture efficien-

cies and normalization for various physical configurations and to

specify averaging times.
                                 7-3

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     7.2.3  Definitions




     EPA should review and,  as appropriate, revise or clarify cer-




tain definitions and testing requirements contained in 40 CFR 60,




Subpart N.
                                 7-4

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8.0  REFERENCES

Barkhau, H., 1978.  Personal Communication.  Requests and Information
Section.  National Air Data Branch.  Research Triangle Park,  N.C.

Bloom, B., 1978.  Personal Communication.  Office of Stationary Source
Enforcement.  U.S. Environmental Protection Agency.   Washington,  D.C.

Cavaghan, N.J. et al., 1970.  Utilization of In-Plant Fines.   Journal
of Iron and Steel Institute 108:538-542.

Carroll, James L., 1978.  Letter dated June 30, 1977 to Mr. L.
Kertcher.  Enforcement Division.  Region V.  U.S. Environmental Pro-
tection Agency.  Chicago, 111.

Federal Register, 1977.  Proposed Amendments to the  Customs Regula-
tions Relating to the Documents and Information Required to be Filed
at the Time of Importation of Certain Articles of Steel.  Department
of the Treasury Customs Service.  42FR65214.

Federal Register, 1978.  Trigger Prices for Imported Steel Mill Pro-
ducts.  Department of the Treasury.  43FR1463.

Georgieff, N.J., 1978.  Personal Communication.  U.S. Environmental
Protection Agency, Research Triangle Park, N.C.

Interlake, Inc., 1975.  The Effect of the Emissions  from the  B.O.F.
Melt Shop on Ambient Air.  Interlake Steel, Inc.  Chicago, 111.

Jackson, W.E., 1978.  Personal communication.  U.S.  Steel Corpora-
tion, Pittsburgh, Pa.

Kortge, R.M., 1977.  Letter dated September 26, 1977 to Mr. L.
Kertcher.  Enforcement Division.  Region V.  U.S. Environmental Pro-
tection Agency.  Chicago, 111.

Kotsch, Labee and Schmidt, 1978.  Developments in the Iron and Steel
Industry U.S. and Canada - 1977.  Iron and Steel Engineer. February.

Love, H.M., 1976.  Letter dated January 9, 1976 to Mr. Thomas M.
Heaton.  Colorado Air Pollution Variance Board.  Denver, Colo.

McCutchen, G.W., 1978.  Personal Communication.  Emissions Standards
and Engineering Division.  Research Triangle Park, N.C.

McDowell, W., 1978.  Personal Communication.  Office of Air Quality,
Planning and Standards.  Research Triangle Park, N.C.
                                8-1

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Miller, B.P., 1978.  Personal Communication.  Air and Hazardous
Materials Division.  U.S. Environmental Protection Agency.  Region IV.

MITRE/Corporation, 1978.  Regional Views on NSPS for Selected Catego-
ries, Metrek Division, MTR-7772.  McLean, Va.

Nicola, A.G., 1976.  Fugitive Emission Control in the Steel Industry.
Iron and Steel Engineer, July.

Nicola, A.G., 1978.  Personal Communication.  Manager.  Air Pollution
Control Systems.  Pennsylvania Engineering Corp.  Pittsburgh, Pa.

Pearce, J., 1976.  Q-BOP Facility Planning and Economics.  Iron and
Steel Engineer, March.

Seton, Johnson & Odell, Inc., 1976.  Investigation of Particulate
Emissions - Basic Oxygen Furnace Roof Monitor.  Prepared for CF&I
Steel Corp.  Pueblo, Colo.

Skelly, J.S., 1966.  Profits in BOP Gas Collection.   Iron and Steel
Engineer 43(3):82.

U.S. Army Corps of Engineers, 1978.  Draft EIS for Permit Application
for Proposed Lakefront Steel Mill, Conneaut, Ohio by U.S. Steel.  U.S.
Corps of Engineer District, Buffalo,  N.Y.

U.S. District Court for the Northern District of Alabama, Southern
Division, 1978.  Civil Action No. 77-H-1630-S.

U.S. Environmental Protection Agency, 1973.   Background Information
for Proposed New Source Performance Standards.  Vol.  I, Main Text.
APTD-1352a.  Office of Air Quality Planning and Standards.  Research
Triangle Park, N.C.

U.S. Environmental Protection Agency, 1976.   Environmental Consid-
erations of Selected Energy Conserving Manufacturing Process Options.
Vol. Ill, Iron arid Steel Industry Report.  EPA-600/7-76-034c.  Indus-
trial Environmental Research Laboratory.   Office of  Research and
Development.  Cincinnati, Ohio.

U.S. Environmental Protection Agency, 1977.   Development of Technology
for Controlling BOP Charging Emissions.  EPA-600/2-77-218.  Industrial
Environmental Research Laboratory.  Office of Research and Develop-
ment.  Research Triangle Park, N.C.

U.S. House of Representatives, 1977.   World Steel Trade:  Current
Trends and Structural Problems.   Serial 95-37.
                                  8-2

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Vranka, R.G.,  1975.  Air Quality Analysis for the Proposed National
Steel Plant.  Arthur D. Little, Inc.   Report No.  77823-02.

Wall Street Journal, 1978.  Speer Warns U.S. Steel May Boost Prices
Further in 1978 Unless Productivity Rises.   May 2.

Yawata, 1966.   OG Process Sales Brochure.  Yawata Iron and Steel Co.,
Ltd.
                                 8-3

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                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)
  REPORT NO.

  EPA  -  450/3-78-116
                                                            3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
 A Review of Standards of  Performance for New
 Stationary Sources-Iron and  Steel  Plants/Basic  Oxygen
 Furnaces                                      	
                                                            5. REPORT DATE
                                                              November 1978
             6. PERFORMING ORGANIZATION CODE
  AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO.
 Marvin  Drabkin and Richard  Helfand
               MTR-7324
  PERFORMING ORGANIZATION NAME AND ADDRESS

  Metrek  Division of the MITRE Corporation
  1820  Dolley Madison Boulevard
  Me  Lean,  VA  22102
                                                            10. PROGRAM ELEMENT NO.
             11. CONTRACT/GRANT NO.


               68-02-2526
12. SPONSORING AGENCY NAME AND ADDRESS
                                                            13. TYPE OF REPORT AND PERIOD COVERED
  DAA for Air Quality Planning and Standards
  Office of Air, Noise,  and  Radiation
  U.  S..Environmental Protection Agency
  Research Triangle Park,  NC  27711	
             14. SPONSORING AGENCY CODE
               EPA  200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
 This  report reviews the  current Standards of Performance for New  Stationary Sources:
 Subpart  N  - Iron and Steel  Plants/Basic Oxygen  Furnaces.  It includes  a summary of
 the current standards, the  status of current applicable control technology, and the
 ability  of plants to meet the current standards.   No changes to the  existing standard
'are recommended, but EPA will continue evaluation of fugitive emission controls for
 BOPFs with a view toward incorporating fugitive emissions under the  scope of the
 standard at a later date.
17.
                                KEY WORDS AND DOCUMENT ANALYSIS
                  DESCRIPTORS
                                               b.lDENTIFIERS/OPEN ENDED TERMS
                           c.  COSATI Field/Group
  Basic oxygen process
  oxygen blown converters
  steel making
  iron and steel  industry
  performance standards
  regulations
                            13B
 18. DISTRIBUTION STATEMENT

  Release Unlimited
19. SECURITY CLASS (This Report)
 Unclassified
21. NO. OF PAGES
 76
                                               20. SECURITY CLASS (Thispage)
                                                Unclassified
                                                                           22. PRICE
 EPA Form 2220-1 (Rev. 4-77)
                       PREVIOUS EDITION IS OBSOLETE

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