United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 27711
EMB Report 80-BOF-4
August 1980
Air
Steel Processing
Fugitive Emissions

Emission Test Report
Armco Steel
Ashland, Kentucky

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     FUGITIVE EMISSION EVALUATION REPORT
           DESULFURIZATION STATION
                 ARMCO STEEL
              ASHLAND, KENTUCKY
              Prepared for the
    U.S. Environmental Protection Agency
        Emission Measurement Branch
Research Triangle Park, North Carolina 27711
                Prepared by
 Clayton Environmental Consultants, Inc.
          25711 Southfield Road
        Southfield, Michigan 48075
         EMB REPORT NO. 80-EOF-4
           Work Assignment 28
         Contract No. 68-02-2817

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                 TABLE OF CONTENTS
                                                  Page
List of Tables                                      -JL
List of Figures                                    ii
1.0  Introduction                                   1
2.0  Discussion of Results                          2
3.0  Observation Locations and Emission Points      7
4.0  Observation Procedures                        12

APPENDICES
A.    Project Participants
B.    Field Data Sheets
     B-l.   Fugitive Emissions  (Method 22)
            B-l.l.  Desulfurization
            B-l.2.  Lance Opening and Skimming
     B-2.   Visible Emissions (Method 9)
     B-3.   Velocity Traverse
C.    Summary of Visible Emissions
D.    Method 22
E.    Method 9
F.    Visible Emission Certifications of Observers
G.    Calibration Data

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                   LIST OF TABLES
Table                                             Page

  2.1     Fugitive  Emission  Evaluations  of             3
         the  Desulfurization  Station

  2.2     Fugitive  Emission  Evaluations                4
         of the  Lance  Opening and Skimming
         Station

  2.3     Stack Gas Parameters -  Baghouse              5
         Outlet, Desulfurization Station

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                  LIST OF FIGURES

Figure                                              Page

  3.1    Plan view of desulfurization station         8
         and observation points

  3.2    Baghouse outlet sampling location           11

  4.1    Elevation view of desulfurization           13
         station and emission points

  4.2    Stack cross-section and sampling            16
         point locations
                         11

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                 1.0  INTRODUCTION



     The Clean Air Act mandates that Standards of Perform-



ance be established for new stationary air pollution



sources.  Establishment of these standards requires that



an emission data base be developed for each source category.



This data base is used as a guide for the establishment



of Performance Standards which will minimize air quality



degradation and yet not be impossible to attain.



     The U.S. Environmental Protection Agency (EPA)



retained Clayton Environmental Consultants, Inc., to



evaluate both visible and fugitive emissions emanating



from the desulfurization station at the Armco Steel



facility in Ashland, Kentucky.  The study was conducted



on April 22 and 23,  1980.  Velocity traverses were



conducted simultaneously with the emission observations



of the desulfurization station.  Emissions were also



documented of the lance opening and the skimming process



(both are uncontrolled).



     The results of this study will be used as part of



the field sampling data for supporting New Source Perform-



ance Standards for fugitive process emissions in the iron



and steel industry.   This study was commissioned as



Project No. 80-BOF-4, Contract No. 68-02-2817, and



Work Assignment 28.

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            2.0  DISCUSSION OF RESULTS




DESULFURIZATION STATION




     Table 2.1 presents the results for both the fugitive




and visible emission evaluations of the desulfurization




station.  Ten observation runs were conducted.




     Emission frequencies during Test Runs 1 through 10




ranged from 0.0 to 68.2-percent, averaging 44.2-percent,




for Observer 1, from 0.0 to 99.9-percent, averaging




60.4-percent, for Observer 2, and 0.0 to 97.8-percent,




averaging 55.9-percent, for Observer 3.  Therefore, the




variability between observers in perceived emission fre-




quency was over the range of 44 to 60-percent.




     The average opacities for six tests ranged from




2 to 14-percent.






LANCE OPENING AND SKIMMING




     Table 2.2 presents the results for observations




conducted at the lance opening and the skimming station.




Three tests were conducted at each location.




     Emission frequencies were 100-percent for each




test at both locations.  Both are uncontrolled processes.






VELOCITY TRAVERSE




     Table 2.3 presents the flowrates and temperatures




from velocity traverses conducted simultaneously with the




fugitive emission evaluations.  The flowrates are expressed




in standard cubic feet per minute (scfm)  and temperatures



in degrees Fahrenheit  (F).
                        - 2 -

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                                               TABLE 2.1.  FUGITIVE EMISSION EVALUATIONS OF THE DESULFURIZATION STATION
Test Date
No. 1980
1 4/22
2 4/22
3 4/22
4 4/22
5 4/22
6 4/22
7 4/23
8 4/23
9 4/23
10 4/23



Observer 1
Accum.
Observ.
MiruSec
19:34
15:29
11:16
11:12
16:29
05:25

15:16
12:31
Accum.
Emission
Min:Sec
04:14
00:00
07:41
05:01
10:56
03:27
b
08:28
04:12
Emission
Frequency
%
21.6
0.0
68.2
44.8
66.3
63.7

55.5
33.6
Method
22
Observer 2
Accuro.
Observ.
Min:Sec
19:32
15:29
11:10
11:10
16:26
05:21
15:31
14:48
15:16
13:32
Accum.
Emission
Min:Sec
05:37
00:00
07:28
06:06
12:43
04:08
15:30
14:45
10:21
04:13
Emission
Frequency
%
28.8
0.0
66.9
54.6
77.4
77.3
99.9
99.7
67.8
31.2
Observer 3
Accum. Accum.
Observ. Emission
Min:Sec Min:Sec
19:32 05:32
15:29 00:00

c

15:42 15:19
15:00 14:40
c


Emission
Frequency
%
28.3
0.0



97.6
97.8

Method 9 (Percent)
a
Observer 3
Low High
c
0 25
0 15
0 75
0 50
c
0 20
0 10
Average

7
4
14
12

5
2
 I
to
 I
            Observers  are as follows:   (1)  Dusanka Lazarevic, (2) John Holm, (3) Bruce Bird.
           Emissions  emanating from  the lance opening were observed (see Table 2.2).
           C0bserver alternated using Methods 22 and 9.

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                TABLE 2.2.  FUGITIVE EMISSION  EVALUATIONS OF THE LANCE OPENING AND SKIMMING STATION
Test
Number
1
2
I
t»
1 3
Date
1980
4/23
4/23
4/23
Method 22
a
Lance Opening
Accum. Accum.
Observ. Emission
Min:Sec Min:Sec
15:33 15:33
14:32 14:32
15:17 15:17
Emission
Frequency
%
100
100
100
b
Skimming
Accum.
Observ.
Min:Sec
3:00
2:52
3:11
Accum.
Observ.
Min: Sec
3:00
2:52
3:11
Emission
Frequency
%
100
100
100
Tests 1 and 2 were observed by D. Lazarevic and Test 3 by John Brown.
Observed by John Brown.

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TABLE 2.3.  STACK GAS PARAMETERS - BAGHOUSE OUTLET,
                    DESULFURIZATION STATION
Test
Number
1
2
3
4
5
6
7
8
Date
1980
4/22
4/22
4/22
4/22
4/22
4/22
4/22
4/22
Flowrate
scfm
22,300
20,400
22,000
20,900
24,200
24,000
23,100
23,000
Temp
F
127
154
120
144
101
107
105
113
                         - 5  -

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     The flowrates ranged from 20,400 to 24,200-scfm and



temperatures ranged from 101 to 154F.
                         -  6  -

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    3.0   OBSERVER LOCATIONS  AND  EMISSION POINTS




     Figure  3.1  depicts  a plan  view of  the  desulfurization




 station  and  the  EOF  shop showing all  respective  observa-



 tion points.






 DESULFURIZATION  STATION




     Observation points  1 and 2 were  located  approximately




 25  and 60-feet east  of the  station at ground  level,




 respectively.  Observers alternated between the  two




 positions  depending  on wind direction and how heavy




 emissions  were during desulfurizing.  Several times




 Point 1  became engulfed  in  smoke, forcing the observers




 to  move  to the second location.   Both Stations A and B




 were observed from these locations.




     The observation locations  permitted optimum viewing




 of  the process and were  also the safest from  hot splashing




 metal during the desulfurizing  process.





     Even though observers were  facing into  the  sun during




the afternoon readings,  this did not interfere with the




observations.  The desulfurization building  was  tall enough




to block the afternoon sun,  allowing the observers to view




the stations without any difficulty-   The south side of




the station would have been the best afternoon observing




location with respect to the sun, but the plant had




installed  shields on this side to minimize  interference




caused by  the winds.  Therefore, the view of  the stations
                         -  7  -

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                                                                     N
                             Desulfurization station


i
T -

4:
f
s

1

s
/

00
1























Baghouse















Only obse

;rved

/
this lance opening




(D












III
(





/~\

Pulpit
(D



r\
_--^\ 7
-^^ ' \ I












Lance openings

(&) (3)
J i I7\\ t , ; (Pi i

^-Stations
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III
















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7

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EOF shop
                                                           L
                                                                          Skimming
                                                                           station
Figure 3.1  Plan view of desulfurization station and observation points.

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was completely blocked.  Also, since prevailing winds




were from the west-northwest, they would cause emissions




to exit at the opposite side of the station.






LANCE  OPENING




     The  lance opening was  located  about  20-feet  above




ground level, in  a  building enclosure  above  the desulfuriza-




tion station.  The  opening  was a  slot  in  the desulfurization




pick-up hood through which  the lance was  lowered  into the




torpedo car.  The first test run  began at Point 3, which




was northwest of  the lance.  Within minutes, the  entire




enclosure was smoke filled  and the  lance  was barely




visible.  At  this time the  observer moved to Point 4,




 (outdoors) to escape the  emissions.  Test 3  was also



conducted at  this  location.  Test 2 was conducted within




the pulpit  (Point 5),  which was  adjacent  to  the lance




opening.






 SKIMMING



      Observations of  the  skimming process were conducted




 indoors  about 100-feet south of  the ladle  at  Location




 6 (Figure 3.1).   The  ladle  was  approximately 25-feet




above  the ground.






VELOCITY  TRAVERSE



      The  baghouse outlet  was a  36.0-inch  by  36 7/8-inch




duct  located  approximately  23-feet above  ground level.
                        - 9 -

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The duct was accessed through three 2 1/2-inch ports



equally spaced across the 36.0-inch duct face.  The



ports were located about 11.5-feet downstream from a



bend and 4.5-feet upstream from another bend, providing



adequate upstream/downstream distances to disturbances.



     Each traverse consisted of three sampling points for



Test Nos. 1 and 2, and four points for the remaining six



tests.  Velocity pressures were measured at each of the



9 and 12 points, respectively.   Temperatures were taken



at the center of each port location.   Figure 3.2 presents



both plan and elevation views of the  traverse location.
                       - 10 -

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                       Plan view
 fan
                        Baghouse
                 t!
                     ports
                              •
                    Elevation view
                         Baghouse
  To
  fan
Figure  3.2.  Baghouse outlet sampling location,
                          - 11 -

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            4.0  OBSERVATION PROCEDURES




     Visible emissions were evaluated in accordance




with EPA Method 22, Visible Determinations of Fugitive




Emissions from Material Processing Sources, and EPA




Method 9, Visual Determination of the Opacity of




Emissions from Stationary Sources.






DESULFURIZATION STATION




     The station is equipped with two desulfurizing units




but only one torpedo car is lanced at a time.  Initially,




the lance was partially lowered into the torpedo car




and the nitrogen purge begun.  When the lance was fully




lowered into the car, the magnesium/lime mixture was




added.  This indicated the starting point of the test.




The designated stop time was when the lance was fully




raised into the hood.



     Initially, all three observers used only Method 22.




After the second run, the EPA Technical Manager, Mr.




John Brown, suggested that one individual use Method 9,




while the other two use Method 22.  Ms. Dusanka Lazarevic




and Mr. John Holm  used Method 22, while Mr. Bruce Bird




used Method 9.



     Emission points A and B were observed during the




study.  Emissions  from the uncontrolled lance opening




emanated from Point C, and were not included (Figure 4.1)
                         - 12 -

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                                                             Desulfurization Station
   To
  fan
                                                                       x
CO

I
                                                         A    /I
V \  \
    B
               Figure 4.1.  Elevation view of desulfurization station and emission points.

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     A great deal of interference was encountered during



the third test.  A machine located in front of Point B



was filling the lime bins and spewing lime dust into the



air, making observations at Point B impossible.



     The wind may also have been a contributing factor



to the higher emission levels.  The wind direction was



predominantly from the west-southwest, channeling itself



through the station.  Since the exhaust shrouds were



positioned high enough for a locomotive to pass under



them, it appeared that the emissions were carried away



before they could be drawn into the exhaust system.  The



plant has installed shields on the southern side of the



desulfurization building to minimize capture interference



caused by the prevailing winds.






LANCE OPENING AND SKIMMING



     Both locations were observed using Method 22.  Three



runs were conducted at each location.






VELOCITY TRAVERSE



     Exhaust gas sampling was conducted in accordance



with procedures outlined in the U.S. Environmental



Protection Agency's "Standards of Performance  for



New Stationary Sources"  (Federal Register 40CFR60,



December 23, 1971, as amended through August 18,  1977).



     The duct was divided into equal areas and exhaust



gas velocities were measured at each midpoint.  Velocity
                             -  14  -

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pressures were obtained using an S-type Pitot tube and



inclined 0 to 10-inch water gauge manometer, in accordance



with EPA Methods 1 and 2.     Figure 4.2 shows the inlet



and outlet stack cross-sections and sampling point loca-



tions .
                       - 15 -

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1
H
1 1
1 1
1 »
O 0 1 0
1 I
	 [. 	 „ J 	
1 1
0 , 0 ( 0
I
I 1
1 ,
o i o ' o
1
1 1
1 .
1 i

±2 I*. | 0
jG

36




7/8"




                                                36 7/8"
U |

--J.4 | J.£
36"
• - t>

    Point
      1

      2

      3
Distance
(inches)
   6.1

  18.4

  30.7
Point
  1

  2

  3

  4
Distance
(inches)
   4.6

  13.8

  23.0

  32.3
Figure 4.2.  Stack cross-section and sampling point locations.

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