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
-------
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
-------
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
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-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
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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
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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
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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
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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
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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
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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
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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
-------
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 compliancethat
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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
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8-1
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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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