ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-75-010
Visible Emission Observations
Kaiser Steel Corporation
Font an a, California
September 1975
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
^t° s^
AND / ^ *
REGION IX r
i
SAN FRANCISCO, CALIFORNIA
% PRO^°
NOVEMBER 1975
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
VISIBLE EMISSION OBSERVATIONS
KAISER STEEL CORPORATION
Fontana, California
September 1975
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver, Colorado
and
REGION IX - San Francisco, California
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CONTENTS
I. INTRODUCTION 1
II. SUMMARY AND CONCLUSIONS 3
Visible Emission Observations 3
Compliance with Consent Order 5
III. APPLICABLE REGULATIONS 8
Visible Emissions 8
. Emergency Variations 9
IV. VISIBLE EMISSION OBSERVATIONS 11
Study Methods 11
Environmental Data 13
Facility Description 15
Blast Furnaces 19
Sintering Plant 24
Coke Oven Batteries 25
Open Hearth Furnaces 35
Basic Oxygen Steel Process Furnaces 38
Rolling Mill Soaking Pits 49
Hot Strip Mill 50
Scrap Cutting 51
V. ANALYSIS OF THE STATUS OF COMPLIANCE
WITH CONSENT ORDER 54
Appendix A Requirements 55
B " 56
C " . . . . 58
D -" 59
11 . E " 61
F " 62
Discussion 62
APPENDIX - VEO RECORD . . . 65
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TABLES
II-l Emissions Exceeding Applicable
Regulations - Summary 4
IV-1 Sources of Visible Emissions 12
IV-2 Meteorological Data from Kaiser Steel 14
IV-3 Stack Characteristics ..... 17
IV-4 VEO's at Blast Furnace Process Area 23
IV-5 VEO's at Open Hearth Furnace Area 29
IV-6 VEO's at Coke Battery Sources . 31
IV-7 VEO'S at Open Hearth Furnace Area 39
IV-8 VEO's at BOSP Furnaces 43
IV-9 VEO's at Rolling Mill Soaking Pits 50
IV-10 VEO's at Scrap Cutting Areas 53
FIGURES
IV-1 Kaiser Steel Plant Vicinity Map 16
IV-2 Schematic of Stack Orientation 18
IV-3 Blast Furnace Process Flow 20
IV-4 Coke Oven Process Flow 26
IV-5 Observed Coke Oven Leaks 32
IV-6 Open Hearth Furnace Process Flow 36
IV-7 BOSP Furnace Process Flow 41
IV-8 Smoke Density, Stack 23, 20 Sept 45
IV-9 Smoke Density, Stack 23, 21 Sept 46
IV-10 Smoke Density, Stack 21, 20 Sept 47
IV-11 Smoke Density, Stack 21, 21 Sept 48
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I. INTRODUCTION
Kaiser Steel Corporation operates a steel mill at Fontana,
California, about 80 km (50 mi) east of Los Angeles. The facility
is a fully integrated steel mill with basic coke, iron and steel
production processes and a full range of finishing operations. It
is the only integrated mill in California. The basic coke, iron
and steel processes result in the emission to the atmosphere of
excessive levels of particulate air pollutants, despite the instal-
lation of various air pollution control devices.
On 11 July 1974, the Corporation entered into a Consent Order
with EPA-Region IX to control these emissions. The Order specified
various steps to be taken by the Corporation, including process
modifications and installation of air pollution control devices. A
compliance schedule for both interim and final compliance dates was
also established. The Order was amended 11 November 1974, changing
several interim dates but not affecting the final compliance dates.
Subsequent to the amendment, the Corporation on 24 July 1975
submitted a $150 million Steelmaking Modernization Project Proposal
to EPA. The proposal included significant changes from the schedule
in the Consent Order. Among these were extended compliance dates,
with the final EPA compliance date of 31 December 1977 advanced to
30 June 1981. To date no EPA action has occurred on this proposal.
At the request of the Enforcement Director, EPA-Region IX,
San Francisco, California, the National Enforcement Investigations
Center (NEIC) conducted a study of the Kaiser facility in September
1975. The objectives of the study were to determine the status of
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compliance with the Consent Order and to observe sources of visible
emissions to determine compliance with applicable county regulations.
The field portion of the study was conducted 16-24 September 1975.
This report presents the results of the study. Applicable
visible emission regulations are presented in Section III. A dis-
cussion of the results of the visible emission observations is con-
tained in Section IV. The status of compliance with the Consent
Order is evaluated in Section V.
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II. SUMMARY AND CONCLUSIONS
A survey of Kaiser Steel Corporation's integrated steel mill
at Fontana, California was conducted 16-24 September 1975. The
survey was to determine the status of compliance with applicable
visible emission regulations and with an abatement schedule of the
Kaiser-EPA Consent Order.
VISIBLE EMISSION OBSERVATIONS
Observations were made of all major sources of visible emissions
in the blast furnaces, sinter plant, coke oven batteries, open hearth
furnaces, basic oxygen steel process (BOSP) furnaces, rolling mill
soaking pits, hot strip mill and scrap cutting areas. Visible emissions
exceeding applicable regulations were observed at 29 stacks and
numerous coke oven doors, standpipes and quench towers. These sources
and the number of observations at each source are summarized in
Table II-l.
Not all occasions were recorded during the study when emissions
exceeded allowable limits. Excessive visible emissions were almost
continuous from stack No. 6 serving coke oven Battery A, and from coke
oven door leaks. Excessive emissions also occurred from scrap cutting
operations while in progress.
Charging procedures at the coke oven batteries had recently
been changed from sequential to staged charging. Therefore, opera-
tions were no-t normal and observations of emissions from the charging
cycle were deferred until a later date.
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Table II-l
SUMMARY OF OBSERVATIONS OF VISIBLE EMISSIONS
EXCEEDING APPLICABLE REGULATIONS
Process Area Source
Blast Furnaces stack no.(l
)2
(4
Cast House Roof
Sinter Plant
Coke Oven Batteries
stack no.
5
6
7
8
9
10
11
' ..- ' Door Leaks
Standpipes
/ Quench Towers
Open Hearth Furnaces
stack no.
12
13
16 .
20
Roof Monitors
Basic Oxygen Steel Process
(BOSP) stack no.
21
23
ESP1" Bypass
Roof Monitors
Rolling Mills '31
stack no.
37
38
40
41
43
Hot Strip Mill 57
Scrap Cutting Main Area
Near BOSP
Observations
Exceeding Limits
3
1
3
1
1
10
8
3
8
6
6
29
2
3
8
5
1
8
5
7
2
3
7
1
2
1
1
1
2
1
6
2
Total 145
electrostatic precipitate?
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COMPLIANCE WITH CONSENT ORDER
Compliance with the 11 July 1974 Consent Order to date has been
minimal. This is best illustrated summarizing Corporation progress
under each Appendix to the Order.
Appendix A
Part A. Contracts should have been let for control equipment
to bring "A" Battery stack into compliance. The Corporation
has purchased an experimental unit processing half the stack
emission.
Part B. The Corporation has requested an extension of up to 30
months for compliance with emissions from Battery stacks B
through 6.
Appendix B
Part A. The Corporation certified that pushing and charging at
all batteries were in compliance with Rule 50A.
Part B. The Corporation certified that coke oven doors and stand-
pipes in Batteries C through G were in compliance with Rule 50A.
Part C. The Corporation has installed new doors on Batteries A and
B but is not required"to certify compliance until 31 December
1975.
Part D. No action required.
Part E. The final control plan to bring combined visible emissions
from each coke oven into compliance was not submitted on 30 July
1975 as required.
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Appendix C
Part A. The Corporation did not certify to compliance with Rule 50A.
However, they did indicate meeting the necessary increment of
progress for charging and tapping operations at furnaces No. 1 and 3
of the basic oxygen steel process (BOSP)*
Part B. A 7-1/2 month extension was requested due to delivery
problems with the baghouse.
Appendix D
On 17 January 1975 the Corporation was advised that they are in
violation of the Order. The Corporation has not met a later date
for installing additional control equipment at the open hearth
furnaces but has proposed an alternative Steelmaking Moderniza-
tion Program. This would extend the final compliance date on
these units for 17 months.
Appendix E
The Corporation has indicated they will not erect a scrap cutting
building with control equipment. They were advised of being in
violation of the Consent Order on 15 May 1975. The Steel Moderni-
zation Program included machine torch cutting devices on the
outside as .the alternative to an enclosure. These are in place
without EPA approval.
Appendix F
The Steelmaking Modernization Plan suggests a 3-1/2 year ex-
tension for compliance with the desulphurization of coke oven gas.
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Progress thus far has led to the following conclusions:
The Corporation has acted unilaterally in modifying elements of the
Consent Order without consulting EPA. These modifications may or
may.not bring the particular operation into final compliance.
The Corporation has certified to compliance with various elements
of the Consent Order that appear to be out of compliance.
Visible emission observations indicate that-other facilities at the
plant not covered by the Consent Order are exceeding Rule 50A.
Operations and Maintenance procedures which will play a major role
in meeting clean air objectives do not seem to receive the priority
necessary.
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8
III. APPLICABLE REGULATIONS
Emissions of air pollutants from the Kaiser steel mill are
subject to regulations promulgated for the San Bernardino County
Air Pollution Control Zone. Specific regulations concerned with
visible emissions and with upset or breakdown conditions are pre-
sented below.
In addition, emissions from the steel mill are the subject
of a Consent Order entered into by EPA and the Kaiser Steel Cor-
poration on 11 July 1974. The Order specifies various abatement
measures to be implemented by the Corporation on a specific time
schedule. The requirements of the Order and the Corporation's
progress to date in complying with the Order are discussed in
detail in Section V of this report.
VISIBLE EMISSIONS
Visible emissions are subject to the limitations specified
in the following San Bernardino County regulation:
Rule 50A. Visible Emissions
A person shall not discharge into the atmosphere from any
single source of emission whatsoever, any air contaminant
for a period or periods aggregating more than three (3)
minutes in any one (1) hour which is:
a. As dark or darker in shade as that designated as No. 1 on
the Ringelmann Chart, as published by the United States
Bureau of Mines, or
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b. Of such opacity as to obscure an observer's view to a
degree equal to or greater than does smoke described
in Section (a) of this Rule.
This Rule is effective on 1 June 1972 for all sources which
are not either in operation or under construction prior to
that date, and Rule 50 shall not be applicable to such sources
on or after that date. This Rule is to become effective for
all other sources on 1 January 1975, and Rule 50 shall not be
applicable on or after that date.
Variances from compliance with Rule 50A have been granted to
Kaiser Steel Corporation for several of their Fontana operations
by the San Bernardino County Hearing Board. These variances have
not been approved by EPA. Operations excepted and compliance dates
are as follows:
Scrap Cutting 31 May 1976
Open Hearth Stacks 31 July 1977
Coke Oven Battery A Stack 31 Dec. 1976
Coke Oven Batteries B to G Stacks 31 Dec. 1977
EMERGENCY VARIANCES
The regulations grant emergency variances for excessive emissions
during upset or breakdown of control equipment under certain conditions,
Rule 55. Upset Conditions or Breakdowns
Emissions exceeding any of the limits established in this regu-
lation as a direct result of upset conditions in or breakdown
of any air pollution control equipment or related processing
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10
equipment shall not be deemed to be in violation of the rules
establishing such limits, provided the following requirements
(a) and (b) of this section are met.
Any upset condition or breakdown of equipment which causes
a violation of the Rules and Regulations of the District
or the Health and Safety Code of the State of California
shall be reported to the office of the District within
thirty (30) minutes.
As soon as possible after notification, the District shall
be informed of the estimated time for repairs; and if more
than four (4) hours are required to repair the condition,
the Control Officer shall request the source either to
shut down the operation until repairs can be made or file
immediately for an emergency or interim variance in accord-
ance with Rule 85(d). In the event that the breakdown
or upset condition occurs during other than normal working
hours of the Air Pollution Control District, the intent
to file for an emergency or interim variance shall be
transmitted by telephone for recording within four (4)
hours after the violation is reported and that every
reasonable effort is taken to minimize the emissions.
Investigations will be made by a member of the District
staff to verify the upset conditions.
This Rule is effective 10 September 1974.
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11
IV. VISIBLE EMISSION OBSERVATIONS
STUDY METHODS
The primary purpose of the field study was to observe the major
sources of visible emissions to determine the present status of
compliance with applicable regulations. Detailed process information
had previously been obtained by both San Bernardino County and EPA-
Region IX personnel. Therefore, no detailed process evaluation was
made. A limited walk-through reconnaissance of the plant was conducted
by San Bernardino County personnel to familiarize study staff with
the location and identification of emission sources to be observed.
Actual observations of visible emissions were conducted 16-24
September 1975. Ten certified smoke readers from NEIC, EPA-Region IX,
the California Air Resources Board, and the San Bernardino County
Air Pollution Control Zone took visible emission observations (VEO's)
during the study. Sources observed are listed in Table IV-1. The
smoke readers used standard observation methods (EPA Method 9) for
orientation of the observer with respect to sun position, wind direc-
tion and viewing background. Environmental data, plume characteristics,
source data, visible emission readings and other pertinent information
for each set of readings were recorded on EPA-IX-Form 298 [Appendix],
a modification of the California Air Resources Board visible emission
observation record form. Environmental data collected by the ob-
servers included wind speed and direction, air temperature and relative
'humidity. Only summaries of the VEO records are included in this report.
Individual VEO records are on-file at NEIC.
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12
Table IV-1
SUMMARY OF SOURCES OF VISIBLE EMISSIONS EVALUATED
PROCESS AREA SOURCES
Blast Furnaces Stove Stacks (3), Cast House
Roof Monitors (3)
Sinter Plant Main Stack
Coke Oven Batteries Main Stacks (6), Oven Doors,
Standpipes, Quench Towers
Open Hearth Furnaces Main Stacks (8), Roof Monitors
Basic Oxygen Steel Process Furnace Stacks (3), ESPf Bypass,
Roof Monitors
Rolling Mills Soaking Pit Stacks (19)
Hot Strip Mill Reheat Furnace Stacks (3)
Scrap Cutting Open Areas (2)
t. electrostatic precipitator
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13
During the study, no attempt was made to record every visible
emission that appeared to exceed applicable regulations. Instead,
a number of VEO's were systematically taken at major emission sources
within each process area listed in Table IV-1. When practical, in-
cidental emissions occurring in the area being observed were recorded.
Smoke readers periodically switched sources so that several readers
observed each major source of emissions at different times during
the survey.
Color photographs were taken to document visible emissions and
to record a general overview of the plant. Several types of cameras
were used and the photographs were taken from ground and roof level
at the plant and from a low-flying light aircraft. The photographs
are not presented in this report but are on-file at NEIC.
ENVIRONMENTAL DATA
In addition to the environmental data recorded by the study crew,
data was obtained from a meteorological station at the plant operated
by Kaiser's Environmental Quality Control Department. The system includes
wind speed and direction sensors mounted on a tower atop the galvanizing
facility and temperature, pressure, and relative humidity sensors on the
roof of the Environmenta-1 Quality Control office. Data are automatically
scanned, printed, and punched every two minutes. Hourly readings were
tabulated from this file for the period during which VEO's were being taken
[Table IV-2]. Wind speed data are suspect because of problems with the
sensor at the lower wind speed threshold, which will be corrected by Kaiser
in the near future. Relative humidity also appeared to be inaccurate when
compared on several occasions to EPA wet and dry bulb hygrometer readings.
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Table IV-i
HETEOOOUCICAL DATA:FROM KAISER STBSL
FONTANA, CALIFORNIA
Date
9/16
9/17
9/18
,
s/w :
;_
T1r.ie
1200
1300
1400
1500
1600
1700
1800
1900
0800
0900
1000
1100
1200
1300
1400
1500
1600
1700
0800
0900
1000
1100
1200
1300
1400
1500
1600
1700
1800
1900
0800
0900
1000
1100
1200
1300
1400
1500
1600
1700
1800
1900
ilind Speed
(l:m/hr
15.6
9.0
'19.2
25.2
19.3
' 26.2
19.6
; 23.2
0.6
0.6
0.8
0.6
0.6
16.4
19.5
24.3
21.6
30.4
7.0
0.6
0.4 .
0.4
0.4
0.4
0.4
21.8
9.8
33.2
19.0
0.6
0.6
0.6
0.6
0.6
. 0.4
0.4
0.4
0.4
1.3
0.6
0.6
0.6
(rophj
9.7
5.6
11.9
15.7
12.0
16.3
12.2
14.4
0.4
0.4
0.5
0.4
0.4
10.2 :
12.2
15.1
13.4
18.9
4.3
0.4
0.3
0.3
0.3
0.3
0.3
13.5
6.2
14.4
-11.8
0.4
0.4
0.4
o.<«
0.4
0.3
0.3
0.3
0.3
0.8
0.4
0.4
.0.4
Wind
Direction
(°)
256
279
256
279
276
274
260
257
149
171
208
255
283 '
288 .
' ' 264
250 '
299
' 280
174
180
213
' 266
238
262
265
278'
264
280
269
259
146
166
160 .
254
200
251
279
260
267
283
273
'. 268
F
Temperature J
(°C)
33
34
36
36
36
36
. 34
31
26
28
29
31
32
33
. 34
. 35
34
33
' ' 24
27
27
29
31
31
32
32
32
32
29
27
22
24
28
29
30'
32
32
32
32
32-
29
27
(°f)
91
94
97
97
96
96
94
88
78
83
85
87
90
92
94
94
93
92
75
81
81
84
87
88 .
90
90
89
89
85
81
. 72
76
82
. 85
86
90
90
90
90
89
84
81
'
telatwe
tumidity Date Time
(X) \
55
57
57
56
56
57
57
57
62
59
58
58
58
58
58
58.
59
53
62
59
58 '
57
55
51
46
45
47
46
46
45
54
54 '
49
49
50
51
51
49
50
53
53
56
0/20 °800
0900 '
1000 '
1100
1200
1300
1400
1500
1600
1700
1800
1900
d/22 0800
, 0900'.
. 1000
1 1100
1200
' 1300
1400
; isoo
' ' 1600
1700
1800
' 1900
-
9/23 OBO°
0900 .
.' 1000 '
1100
1200
1300
1400
1500 '
1600
1700
1800
i 1900
;9/24 0800
0900
1000
1100
1200
1300
1400
1500
.1630
Wind Speed
[Ttm/hrJ
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.4
0.4
0.4
1.1
0.4
0.4
0.4
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.4
0.4
0.4
0.4
0.4
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.6
0.4
0,4
v
(mph)
0.4
0.4
0.4 .
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
'0.4
0.4
0.4
0.3
0.3
0.3
0.7
0.3
0.3
0.3
0.4
0.4
0.4
0.4
0.4
. 0.4
0.4
0.4
0.3
0.3
0.3
0.3.
0.3
0.4
0.4
0.4
0.4
0.4
. 0.4
0.4
0.4
0.3
0.3
Wind
Direction Temperature
(°) pc) rn
1 128
192
281
267
219
283
258
293
254
252
284
277
076
077
101
. 397
405
422
402
403
413
400
413
420
52
147
. ! 191
204
242
243
400
; 401
391
411
261
279
103
165
.191
167
111
, 110
39
167
147
22
24
27
28
1 30
31
32
33
33
32
30
28
27
35
37
37
37
38
39
39
39
. 39
36
34
24
29
33
34
36
37
38
38
39
38
35
33
27
29
33
. 35
37
37
38
38
38
71
76
80
83
86
88
90
91
91
89
86.
82
79
95
99
98
99
100
' 103
102
103
102
97
94
76
85
91
94
96
98 .
101
101
102
101
95
91
81
85
91
95
98
99 .
100
100
99
Relative '
Humidity
(S)
65
62
60
56
S3
54
. 52
51
51
51
54 '
53
51
41
33
32
32
32
33
32
28
27
27
25
31
30
30
29
29
09
10 '
10
11
11
10
10
.
38
39
39
37
37
37
. 37 '
-36
36
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15
The data are useful, however, in showing the general environmental
conditions prevailing during the study.
FACILITY DESCRIPTION
The large Kaiser facility is the only fully-integrated steel
mill in California. Basic operations include coke making with by-
product recovery, basic production of iron in blast furnaces, con-
version of iron to steel in both open hearth and basic oxygen process
furnaces, a sintering plant, and a full range of finishing operations
including production of structural shapes, pipe, sheet metal, galvan-
ized products and tin plate. Production of coke, iron and steel in
1972 was 1.36, 2.07, and 2.72 million metric tons (1.50, 2.28, 2.99
tons) respectively.
Basic process units are compactly arranged in a rectangular
area about 2.6 km2(1.0 mi2) [Fig. IV-1]. The basic coke, iron and
steel making processes are located in the north half of this area.
Most of the emission points of interest are also in the north half.
Finishing operations occupy most of the south half of the plant site.
An inventory of stacks including sources of emissions and stack
characteristics is presented in Table IV-3. The relative locations
of the stacks are shown schematically in Figure IV-2.
In the following sections, the results of the visible emission
observations are discussed by process area. A limited basic process
discussion common to the industry is presented to orient the reader
and to define what emission points were observed. Minor variations
may be expected throughout the industry. Detailed process information
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P L A;N T D
Figure /V-l. fCoiser Sfee/ P/anf Vicinify
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Table IV-3
STACK CHARACTERISTICS
Stack
ft-
Type Furnace
Height Type Stack Stack
Type Furnace
Height Type Stack
1. .-
2.
3.
4.
5.
6.
7.
8.
9.
10.
11. .
12. '
13.
14.
15.
16.
17.
13.
19.
20.
21.
22.
23.
24. .
25.
25.
27.
23.
29.
30.
31.
32.
33.
34.
35.
35.
37.
33. '
39.
40.
.41.
42.
.43.
44.,, '
Blast Furnace ffl . .
Blast Furnace K2
Blast Furnace fl3
Blast Furnace |74
Sinter Plant
Coke Oven, Battery A " .
Coke Oven, Battery B
Coke Oven, Battery C
Coke Oven, Battery D
Coke Oven, Battery E
Coke Oven, Batteries F&S
Open Hearth #1
Open Hearth #2
. Open Hearth #3
Open Hearth />4
Open Hearth ff5
Open Hearth Ho
.Open Hearth S7
Open Hearth S3
."Dpcn Hearth ff9
Oxygen Furnace
Oxyc.cn Furnace .
Oxygen Furnace
Soaking Pits 21 ft 22
Socking Pits 19 B 20 .
Soaking Pits 17 £ 10
Soaking Pits 15 & 16
Soaking Pits 13 I 14
Vest preheating pits
Soaking Pits 11 6 12
Soaking Pits 9 a 10
Soaking Pits 7 6 8
Soaking Pits 5 & 6 .'
Soaking Pits 3 ft 4
East preheating pits
Soaking Pits 23 ft 24
Soakinq Pits 25 6 26
Soaking Pits 27 & 20
Soaking Pits 29 & 30
Soaking Pits 31 f< 32
Soaking PUs 33 t 34 - "
Soaking PUs 35 & 36 .
Soaking PUs 37 & 30 . .
Soaking Pits .39 & 40
200'
200' .
200'
200'
300' '
225' '
225'
225'
225'
225'
250'
175'
175'
175'
175'
175'
175'
175'
175' '
175'
150'
150' .
150'
no1
no1'
no1
no1
no1' '
75'
no1
no1
no1
1 1 f\ 1
no*
no1
75'
no«
no'-
no' .
no1
no1
no1 .
no1
no1 .
110^
Concrete .
Concrete
Concrete .
Concrete _'"'
Concrete ...
Concrete
Concrete '/
Concrete '
Concrete' '
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Concrete
Steel
Steel
Steel
Concrete . .
Concrete
Concrete
Concrete
Concrete .
Steel . . . ';
Concrete
Concrete
Concrete
Concrete -
Concrete .
Steel
Concrete
Concrete i
Concrete '
Concrete
Concrete
Concrete
Concrete
Concrete .
Concrete
45.
46.
47.
43.
49.
50.
51.
52.
53.
54.
55.
56.
57.-
58.
59.
60.
61.
62.
63.
64.
65.
66.
67.
63.
69.
70.
71.
72.
73.
74.
75.'
t
tt
.
.' Merchant liil1(SI:c1p line) 135' Concrete
.' . Plate Mill (Slab Fee. 112 159' Steel (Abandoned)
. Plats IlilHSlab Fce.fll 175' Steel
V Plate Mill (Slab Fcc.i S3 -175' Steel
. C.H.Pipc HillfSkelp Fee.) 125' Steel
C. 11. Pipe MilKGalv.Dept.) . 52' Steel
. ' C. II. Pipe Mill(Ga1v.Dcpt.) 60' Steel
Merchant Hill (Rouqhing) 125' Steel (Reaoved) .
Structural Hill (29") 159' Steel
Tin Plate llvll (Scruff) 75' Steel
Tin Plate Mill (Pickle) 70' Steel
OG" Hot Strip Mill (Fce.03) 150' Steel
G6" Hot Strip Mill (FceJ2) ' ISO* Steel
CG" Hot Strip Mill (Fce.fl) ISO' Steel
Power House . .. .
Power House . ..
Power House ' . .
Power House
Power House . ;_ -
Power House
Power House .
Flare
Flare ..."
Sheet Galv. Pickle Line . .
Hot Scarfcr '
62" Pickle Line
Alk. Cln. Line Sheet Galv. ; '
. Walking Beam Furnace '. . ' '
Type R Rotoclone Exhaust Stack (Foundry)
Type 11 Rotoclone Exhaust Stack (Foundry)
Type N Rotoclone Exhaust Stack (Foundry)
.
Table prepared by the San Bernardino County Air
Pollution Control Zone staff and current through
IS October 1975.
See Figure 17-2 for etaok locations.
I
.' "
- '
* .
^
-------
47 HI
44 ni run
» « M 5IRTII
oxTOiR IUIR
1 I »
ten ovtRs
it
i i i
IIA5T IUIRACIS
5 5 «
* * *
SS S SSSS5 3S» 5SS2 tsss;;=53
41 HIICRART Bill
SHIP IIXI
jo*n«e FITS
VI IN IUI »'
ROT
POWII HOUSI
1* It 14 If U 17 II 1* tO
RIAtTR
4*
>0
-------
19
is on-file at the San Bernardino County Air Pollution Control Zone
and EPA-Region IX offices. Observations of visible emissions ex-
ceeding applicable regulations are summarized and evaluated.
BLAST FURNACES
Basic Process
Blast furnaces are used to reduce iron ore to metallic iron.
The basic process flow is shown schematically in Figure IV-3. Raw
materials including coke, iron ore, limestone and sinter are inter-
mittently charged to the top of the blast furnace through a hopper
equipped with air locks. Hot air blown into the bottom of the furnace
causes the coke to burn, producing high temperatures and large volumes
of carbon monoxide (CO). The combination of heat and the reducing
atmosphere in the mid-level of the furnace converts the iron ore to
metallic iron that collects in a molten state at the bottom of the
furnace. Impurities in the ore combine with the limestone to form
slag that collects as a liquid on top of the molten iron. This re-
.duction process proceeds continuously. Periodically the furnace
is tapped during casting operations and the molten iron is drawn off
to hot metal cars for transfer to the steelmaking operations. Slag
is also drawn off periodically. In many blast furnace operations,
the slag flows to ladles for transfer to disposal points at other
plant locations. At Fontana, the slag is discharged directly to pits
adjacent to the blast furnaces. After cooling, the solidified slag
is removed mechanically for byproduct processing.
The gas that flows upward in the furnace has a useful fuel value
because of its high CO content. Before use, the gas is cleaned in a
dust catcher and a wet scrubber to remove flue dust. The flue dust
-------
ja T«* y *»»%VT^
yr-*'Tv*.J
4*» « T*t«> *»»i»i y*«MCX
^ftt^n>«v»t'Ci.«*a
*' -fyaJmrV*"'
HOT t^>T^.L
f>0
o
Figure /V-3. Typicof Blosf Furnace Process Flow Diagram
-------
21
(primarily iron fines) is sent to the sinter plant for processing
and recycle to the blast furnace. About one-third of the blast
furnace gas is used to heat stoves as discussed below. The remainder
is primarily used to fire powerhouse boilers that drive turbines
that compress the air for the hot blast.
Each blast furnace is equipped with three stoves used to heat
air for the hot blast. Blast furnace gas is burned in the stoves to
heat a checkerwork of refractory material filling the stove. Com-
bustion gases are vented to the atmosphere through a single stack
serving all three stoves. Normally, while two stoves are being
heated, cold air is blown through the third (preheated) stove and
heated by the refractory material before entering the blast furnace.
Blast furnace gas is usually cleaned before burning in the
stove. However, periodically the blast furnace is "back drafted."
During this operation, gas is drawn off the bottom of the furnace
and, without being cleaned, it is burned in a stove.
Emission Sources
Visible emissions may occur from the stove stack, from the
hopper at the top of the furnace during charging operations, from
bleeder valves on the blast furnace gas lines, and from the cast
house roof monitors during hot metal transfer and slag drawoff opera-
tions.
Air Pollution Controls
There are no air pollution control devices on the stove stack,
the furnace hopper or the bleeder valves. The blast furnace cast
house encloses the base area of the furnace where hot metal transfer
-------
22
and slag drawoff operations take place. Emissions from these sources
are thus semi-confined in the building but vent directly to the
atmosphere through roof monitors.
Observations
The Fontana mill has four blast furnaces numbered 1 through 4 from
west to east [Fig. IV-2]. The stove stacks have the same numbers.
Furnaces No. 2 and No. 4 were in continuous operation during the survey.
Furnace No. 3 was out of operation for relining. Furnace No. 1 was
being reheated and was placed in operation on 22 September. Furnace No. 2
was casting on a 3-1/2 hour schedule beginning at 3:00 a.m. daily;
iron from the unit normally supplies the basic oxygen steel process
furnaces. The No. 4 furnace was casting on a 4-hour schedule starting
at 12:30 a.m. daily. This unit supplied iron to the open hearth
furnaces and the foundry.
Observations of the stove stacks for the three operating furnaces
documented seven occurrences of visible emissions in excess of allow-
able limits. These are summarized in Table IV-4. The table lists the
total time during each observation period that emissions were in excess
of allowable limits (a reading greater than 20% opacity was considered
to exceed the Ringlemann No. 1 limit). Actual observation periods
varied in length and ranged from a minimum of the time shown in the
table to a maximum of 60 minutes. In cases where the emissions were
esentially in excess of limits continuously, observation periods of
10 to 15 minutes were used. The emissions thus continued beyond
.the recorded time. For intermittent emissions or occasional emissions
in excess of limits, longer observation periods were necessary.
-------
23
Table IV-4 also lists the maximum opacity observed and the
average opacity of readings exceeding the 20% limit. These values
give an indication of how excessive the observed emissions were.
For stack No. 1 serving stoves on blast furnace No. 1, one obser-
vation of excessive emissions was made while the furnace was being
heated and two more observations after the furnace began operating.
The Corporation indicated that visible emissions from the stacks
result from "back drafting" during casting. This practice draws dirty
furnace gases back through the stoves where the gases are burned and
exhausted through the stove stack.
Table IV-4
SUMMARY OF VISIBLE EMISSION
OBSERVATIONS AT THE BLAST FURNACE PROCESS AREA
Emission
Source
Stack 1
Stack 2
Stack 4
Blast Furnace
Cast House
Date
(1975
9/17
9/23
9/23
9/20
9/17
9/19
9/20
9/19
Time
(minutes)
10.75
12.50
9.75
12
11.50
20
12
9
Max. Opacity
(*)
100
35
70
90
90
100
40
95
Avg. Opacity
(*)
79
29
63
72
74
84
68
68
^ Time emissions, were observed in excess of Rule 50A
tt Average opacity of emissions observed in excess of Rule 50A
-------
24
Visible emissions occasionally were observed originating from
roof monitors on blast furnace cast houses during casting and slag
drawoff activities. One such excessive emission recorded during
slag drawoff is shown in Table IV-4.
SINTERING PLANT
Basic Process
The primary function of a sintering plant is to agglomerate and
recycle fines back to the blast furnace. Fines, consisting of iron-
bearing wastes such as mill scale from finishing operations and dust
from the basic oxygen open hearth and blast furnaces, are blended
with coke fines that serve as fuel in the sintering process. The
material is spread on a moving down-draft grate and ignited. Com-
bustion of the coke produces heat that fuses the material together.
The fused sinter is crushed, screened and air-cooled.
The material handling, crushing and cooling operations are very
dusty. In addition, dust and volatized oil are present in the pro-
cess gases. &he sinter machine, crusher, cooler and part of the
material-hand!ing equipment are contained in the sinter plant building.
Emission Sources
Visible emissions may occur as fugitive dust emissions from
material handling operations outside the sinter plant building or
as process gas emissions from the sinter plant stack (stack No. 5)
At 91 m (300 ft), this stack is the tallest in the steel mill.
-------
25
Air Pollution Controls
Process gases from the sinter emissions and dust emissions from
other points within the sinter plant building are exhausted to a
large baghouse before discharge to the plant stack.
Observations
Visible emissions from the sinter plant stack were infrequent.
When visible, the plume was white and detached. The visible emissions
probably originated from volatization of oil from mill scale fed to
the process.
A single observation of stack No. 5 on 16 September documented
excessive emissions. Emissions of greater than 20% opacity were re-
corded for a total of 9.25 minutes during the observation. The ex-
cessive emissions averaged 32% opacity with a maximum of 40%.
COKE OVEN BATTERIES
Basic Process
The primary function of the coke ovens is to convert bituminous
coal to coke. This is accomplished by heating the coal in special
ovens to drive off the volatiles, leaving the residue coke. The
volatiles are collected and processed to yield a number of byproduct
chemicals and coke oven gas. The gas is used to fuel burners in
"the ovens and other furnaces in the steel mill complex.
Figure IV-4 is a schematic diagram of a typical process flow
for coke ovens. The ovens are rectangular and constructed of
silica brick. Each oven is usually about 45 cm wide, 4.5 m high and
-------
V VTS
^AJfl « «V1*^ ^ *
DDD
1
Nil
r
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-------
27
12 m long (18 in x 15 ft x 39 ft). The ovens are arranged side-by-
side in groups called batteries. The Fontana installation has seven
batteries designated A through G from west to east. Each battery
has 45 ovens. The ovens are numbered sequentially from west to east
as 1 through 349 except that numbers ending in 0 are not used.
Coal is charged through holes (ports) in the roof of each oven
from hopper bottom (larry) cars that run on tracks on top of the
battery. A leveler bar on the push machine that runs on tracks
parallel to the battery is inserted into the oven through the small
chuck door to level the top of the coal. Heat is applied by burning
coke oven gas in flues in the walls between ovens. Combusion pro-
ducts are collected from all flues in a battery and discharged through
one stack.
During the coking period, volatile materials are distilled
from the coal and are collected through standpipes passing out
through the roof of the oven at either end. These materials are
processed in the byproducts plant and coke oven gas is recovered.
When the coking period is completed, the doors at both ends
of the oven are opened and the red-hot coke is pushed from the oven
into the quench car by the ram on the push machine. The quench car
moves the coke to the quench tower where it is sprayed with water
to cool it. The cooled coke is delivered to handling equipment for
subsequent movement to point of use, normally the blast furnaces.
Once the coke has been removed from an oven, the doors are
closed and the charging cycle is repeated.
Emission Sources
Combustion gases from the flues are exhausted to the atmosphere
through the main battery stack. If there are leaks in the oven walls,
-------
28
volatile material from the ovens may also vent through this stack.
Large visible emissions occur when the coke is pushed into the quench
car, and from the quench car, as it is moved to the quench tower. The
quench produces visible emissions from the tower, along with large
volumes of steam. Volatile materials in the ovens may escape to the
atmosphere through leaks around the charging ports and oven doors and
from leaks at blowoff valves on the gas standpipes or around the base
of the standpipes. Emissions also occur from the charging ports
during charging operations.
Air Pollution Controls
There are no control devices on any of the sources of emissions
with the exception of a TRW charged droplet scrubber installed on
Battery A for a pilot study of control of flue gas emissions.
Observations
Batteries A through E are served by stacks #6 through 10. Batteries
F and G are served by stack No. 11. During this survey, the coking period
for Batteries A through E was 40 hours while for Batteries F and G, the
period was 15.7 to 17.1 hours. Batteries A through E are operated at
lower temperatures than are F and G. Each oven was charged with 12,200 kg
(26,800 Ib) of coal.
Visible emissions from the battery stack normally occur only when
leaks into the flues from the ovens are present. Since the batteries
are never shut down, maintenance to seal the leaks must be done while
the ovens are hot. A silicone sealer is used for this purpose.
Observations of excessive visible emissions from coke battery
stacks are summarized in Table IV-5. The worst emissions occurred
-------
Table IV-S
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT OPEN HEARTH FURNACE AREA
29
Battery
A
(stack #6)
v
B
(stack #7)
c
(stack #8)
D
(stack #9)
E
(stack #10)
F, G
(stack 111)'
Date
9/17
9/18
9/20
9/22
9/17
9/18
9/20
9/22
9/17
9/18
9/19
9/17
9/18
9/19
9/22
9/18
9/19
9/20
9/17
9/18
9/19
9/20
Time
(minutes)
"18.25
' 25.75
24.75
12.25
25
9
10
13
23.50
20
7.75
17.25
22.5
13
20
10
19
9
9.75
16.25
10
5.5
13.75
15
7
13
18.75
12
10
25.75
15
22.5
13
11.75
22.25
9.5
18.75
4.75
4.25
8
9
Max. Opacity
(X)
100
100
100
60
100
65
100
65
100
100
80
100
100
60
100
100
100
95
100
100
65
85
100
85
95
60
80
100
70
95
80
70
100
70
95
100
80
50
65
100
40
Avg. Opacity
(X)
98
79
94
50
91
55
88
58
98
80
67
82
74
43
93
84
86
74
53
75
48
44
52
56
60
34
48
80
43.
61
42
35
55
51
49
49
45
37
48
85
28
-------
30
from stack #6 serving Battery A, the oldest battery in the installation.
Excessive visible emissions also occurred from other coke battery
operations. The most significant emissions were from oven door leaks.
Observations of excessive door emissions are summarized in Table IV-6.
Door leaks occurred both immediately after charging and later during
the coking period. Doors on the A through E Batteries (oven numbers
less than 250) appeared to take longer to seal. The company indicated
that this was due to the lower operating temperatures in these batteries.
Observations were made of all ovens on three days to determine
the frequency of occurrence of door leaks without regard to the
opacity of emissions. The results of these observations are shown
graphically in Figure IV-5. On 20 September, only the coke side of
the battery was observed during the first five time periods. Be-
ginning at 1555 hours, both sides of the battery were observed, as
was the case for all three periods on 23 September. On 24 September,
only the push side was observed. These observations indicated that
door leaks occurred much more frequently on the push side, probably
due to additional wear produced by the pushing ram and leveling bar
striking the rim of the oven and chuck doors. Changes in pressure
within the coke oven gas collecting system was the probable cause of
changes in the number of door leaks. This is shown in Figure IV-5
for 1130 hours on 23 September and 1135 hours on 24 September when
a large increase in door leaks occurred.
Closer examination of individual doors after charging indicated
that in some cases the initial leakage emissions were from 20 to 40%
opacity and sealed within 15 minutes. Others took longer to seal or
were of a higher opacity. These high opacity emissions are summarized
in Table IV-6 for the observations of leaks immediately after charging.
Emissions from doors that took longer to seal are summarized under
the observations taken during coking.
-------
31
Table IV-6
SUMMARy OF VISIBLE EMISSION OBSERVATIONS
AT MISCELLANEOUS COKE BATTER? SOURCES
Date
(1975)
9/23
9/24
Oven
No.
204
244
75
85
267
277
283
25
35
45
285
333
Oven
Side
Door
Coke
Coke
Coke
Coke
Coke
Coke
Push
Coke
Coke
Coke
Coke
Push
Time Max.
(Minutes)
Leaks Immediately After
8.25
7
22
19.25
11.75
8.25
9.25
6.25
9
9.75
13
9
Opacity
(%)
Charging
80
80
100
60
100
60
70
50
50
60
60
70
Avg. Opacity
(%)
48
64
66
38
52
36
65
41
45
48
39
61
Door Leaks During Coking
9/17
9/20
9/22
9/23
9/24
24
157
14
186
124
74
53
143
15
113
101
65
213
47
315
127
157
Push
Push
Coke
Push
Push
Coke
Push
Coke
Push
Coke
Coke
Push
Coke
Coke
Coke -
Coke"
Coke
9
14.5
9
11.75
6.75
8.75
10
7.75
10
10.25
13
10
10
10
13
9.75
9
100
60
85
80
80
80
90
80
90
80
65
80
65
65
100
45
100
82
44
56
74
64
74
80
74
83
61
48
70
43
48
53
33
58
Standpipe Leaks
9/20
129
187
Coke
Push
10
14.75
100
65
85
49
Quench Tower Emissions
9/18
9/19
9/20
.
-
-
-
-
-
20.25
17
13.5
100
80
100
41
54
47
-------
Time
; 9/20 0840 (
0945 i
1055 L
L
1345:
1555 _j
9/23 0950 Lp
1130IZj
15251
0845'-
0920'
-
1135
1
-l-fl-fM
.:dl.
_L
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rntTn~J vlrr TnliBBiirr^
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Tt~~n i~~tnli irrriiT«B !^ i r
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((- -| ^-rj-t-.p~|~i-!
n^ji~iir~jii~in iii~ih~|ii;n
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arrta-jnnnrBiiB-Hir
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itch
JLjJ:i
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-.-._>-(-
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::L
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UL
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rrnr
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rr
unii
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ur
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'rpTT
rirri
in
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inr
-N
n:
iirtTn
n
jll
T.rn~n-r
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L_
M-
TS
id;;
ii
_J_
liiiiil
iLH-
'h
r i~~fr !''
i i >t
^r
ffllll'BI I rniMIIBTlIlT
1
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11
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i
rrr
T±£
n~rrnr
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nirnTQT
!rri ri-
- 1
-rl-rr-
20 .40 60 80 100 120 140. 160 180
Overi number
200 220
240
260 280
.300
320 340
Figure /V-5. Observed Coke Oven Leaks
CO
ro
-------
33
Excessive emissions from standpipe leaks on top of the coke
batteries were observed on several occasions [Table IV-6]. The
optimum location for observing these leaks, however, is from on
top the batteries as discussed below.
Excessive emissions were also observed from the quench towers
[Table IV-6]. Large steam clouds are produced by the quench. How-
ever, when the quench car arrived at the quench tower, emissions
could be observed before quenching began. During quenching, the
steam in the plumes dissipated about 30 m (100 ft) downwind leaving
a visible white plume. About 3 minutes were required from the time
the car arrived at the tower until the quench was completed, during
*
which time reading was possible. On several occasions, a delay
occurred between arrival of the quench car at the tower and the start
of the water spray. This resulted in excessive smoke emissions. For
Batteries F and G, processing coke on a 15 to 17 hour cycle, about 6
quenches per hour would be expected. However, during one 60-minute
period eight quenches were observed.
Each process associated with the pushing and charging cycle was
timed to examine the range of these variables. The push cycle was
separated into the period between the coke door opening and time the
coke began to move; the time during which the coke was being pushed
into the coke car; and the time of travel of the coke car to the quench
tower.
Charge time was measured from the time the larry car moved into
place until it moved from over the oven. This may not correspond in
all cases to the actual charging time. However, to determine actual
charge time would have required personnel to be on top of the battery.
Deterioration of baffles in the tower and the poor quality of quench
water probably contributed to these emissions.
-------
34
The company instituted stage charging quite recently, 5 September,
on Batteries A through E and 25 August for Batteries F and G. Only
one larry car had been completely modified for this new procedure
and it was out of operation. The company indicated that this change
was being resisted (as most changes will be) by operating personnel.
Thus, while sequential charging required about 2-1/4 minutes, stage
charging was presently requiring between 3 and 6 minutes but should
reduce to about 2-3/4 minutes when accepted. The break-in period,
plus the hazards and heat associated with monitoring the process
from top-side during high ambient temperature conditions, suggested
that timing and evaluation of visible emissions from the push-charge
cycle would be more productive and meaningful at a later date. The
heat and hazardous conditions also suggested that standpipe and
charge port leaks would best be evaluated at that time as well.
The largest time variable in the push cycle (27 observations)
was the time between door opening and the push. This ranged from 30
seconds to 14-1/2 minutes, with a median of 2-3/4 minutes. The push
time into the coke car was relatively uniform, between 25 and 50
seconds, with a median of 30 seconds. The time to reach one of the
three quench towers largely depended on the towers in use relative
to the location of the particular oven. This ranged between 15
seconds and 2-1/3 minutes with a median of 55 seconds. Total time
for the push varied from 2 to 17-1/4 minutes with a median of 4-1/4
minutes.
Charging time as measured required from 2-1/4 to 12-3/4 minutes
(23 observations) with a median time of 4-1/4 minutes. Four of these
observations (17%) were below 3 minutes, indicating either that stage
charging was beginning to be accepted or that sequential charging
was still occurring.
-------
35
OPEN HEARTH FURNACES
Basic Process
For many years, the open hearth furnace process was the major means
of converting iron to steel. In most steel mills, the open hearths are
being replaced by basic oxygen steel process (BOSP) furnaces. At Fontana,
both processes are in use but additional conversions from open hearth to
BOSP furnaces have been proposed as discussed in Section V.
The open hearth furnace is basically a shallow rectangular refractory
basin or hearth enclosed by refractory lined walls and roof. A typical
process flow diagram is shown in Figure IV-6. Scrap iron and steel,
iron ore, and limestone are charged into the furnace, and fuel from a
burner at one end of the hearth is ignited to produce heat over the scrap
to melt it. Combustion gases are drawn off at the other end of the
hearth through a chamber filled with a checkerwork of refractory materials
that absorb heat and cool the gas. An identical chamber at the burner
end of the furnace preheats combustion air. Periodically the air flow.
direction is reversed.
When meltdown of the scrap has been completed, molten iron from
the blast furances is charged. The iron is poured from the hot metal
transfer car into a hot metal ladle which, in turn, charges it into the
furnace.
As heating continues, carbon monoxide and carbon dioxide are re-
leased from the iron ore and limestone to produce the ore and lime boils.
Further heating refines the steel by removing impurities. The refining
period can be speeded up by lancing the surface of the hot metal with
pure oxygen.
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4t A|/JAi (>oVo k*VT*»O _
*4VC (C»*o'*) vr»»M»*r A
Oli A^/*^em. (soo r»iA.) y [
F73I
7»«*«P-» 1&O*C 4P~^ I
(*oo-M T M
Figure /V-6. Typical Open Hearth Furnace Process F/ow Diagram
co
o>
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37
When the proper steel composition and temperature are reached,
the furnace is tapped and the molten contents drawn off to a teeming
ladle. Slag is floated off the metal surface in the teeming ladle
to slag ladles for disposal. The molten steel is ladled into ingot
molds and is air cooled.
Emission Sources
The primary emission source is the stack that conveys combustion
gases and fumes from the hearth to the atmosphere. In addition,
various operations produce emissions inside the furnace building that
are vented to the atmosphere through roof monitors. These include
the charging of scrap and hot metal, the transfer of hot metal to the
charging ladle, and the tapping of steel into the teeming ladle.
Air Pollution Controls
Emissions from the hearth are controlled by electrostatic pre-
cipitators (ESP) before release to the furnace stack. There are no
controls on roof emissions.
Observations
There are currently eight operable open hearth furnaces at Fontana.
These are numbered 1 through 9 with unit No. 3 disassembled. The corre-
sponding stack numbers and locations are shown in Table IV-3 and
Figure IV-2. Stack No. 14* that formerly served furnace No. 3 is still
in place. During the survey only furnaces No. 1, 2, 5 and 9 were
operating.
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38
Excessive visible emissions were observed to originate from
both furnace stacks and roof monitors. These are summarized in
Table IV-7.
Excessive stack emissions generally occur as a result of mech-
anical or electrical problems with the ESP or when rapid fluctuations
in process emissions cause the ESP to be operated outside design
specifications.
Process data (heat reports) made available by the company indi-
cated that the overall time from charge to tap was between 5 and 7
hours. Charging of raw materials required between 30 and 90 minutes,
followed by the addition of hot metal between 30 minutes to 2-1/2
hours later. Comparison of stack emission observations with these
heat records showed that the excessive visible emissions occurred
during the working period following hot metal addition, except for
one instance when emissions were observed during the melting period.
The emissions during the working period probably occurred during
oxygen lancing. For those cases checked, no excessive visible
emissions from the stacks occurred during scrap charging or hot metal
addition.
BASIC OXYGEN STEEL PROCESS FURNACES
Basic Process
The basic oxygen steel process, through the use of large volumes
of oxygen, condenses the process for converting iron to steel from
5 to 7 hours in the open hearth furnaces into a period of less
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39
Table IV-7
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT OPEN HEARTH FURNACE AREA
Emission
Source
^§
Open Hearth #1
(stack #12)
Open Hearth #2
(stack #13)
Open Hearth #5
(stack #16)
Open Hearth #9
(stack #20)
#2
#4
Open Hearth #5
#6
V
Date
(1975)
9/18
9/20
9/22
9/23
9/18
9/19
9/20
9/22
9/24
9/17
9/18
9/19
9/20
9/22
9/17
9/17
9/18
9/19
9/18
Time
(minutes)
Stack
9
8
22.75
25.50
21.75
15.25
15.25
10
7.5
14.25
18
12
10
10
18.5
10.75
6
19.5
5.75
11.25
14
11
Roof
8
5.25
13.25
6
24.5
Max. Opacity
(%)
Emissions
45
50
60
45
70
45
50
60
90
80
<50
70
75
55
45
60
60
70
60
50
95
60
Monitors
40
80
50
80
80
Avg. Opacity
(%)
33
36
40
32
70
28
28
41
58
42
53
54
43
29
34
45
42
42
28
57
53
"28
32
34
43
44
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40
than 1 hour. The process is carried out in a refractory-lined pear-
shaped open-mouthed furnace mounted on trunions so that it may be
tipped for charging and pouring of melted metal. A typical process
flow design is shown in Figure IV-7. Iron from the blast furnace is
poured from the hot metal transfer car into the hot metal ladle for
subsequent charging into the furnace. Scrap metal up to 30% of the
melt weight is also charged into the furnace. Limestone and other
fluxes are added. Oxygen is then blown into the furnace at supersonic
velocities through a water-cooled lance. This produces an exothermic
reaction that releases enough heat to melt the scrap metal without
adding of fuel. After about 20 minutes of oxygen lancing, the steel
has been refined and reaches the desired temperature. Off gases from
the furnace are collected in a hood that fits over the mouth of the
furnace.
The furnace is tilted and the molten steel is tapped into the
teeming table for subsequent ingot casting. Slag remaining in the
furnace is then poured into slag ladles and the process cycle can be
repeated.
Emission Sources
The major off-gas emissions from the furnace are collected in the
hood, cleaned in an ESP and then discharged to the atmosphere through
a stack. Emissions can al-so occur from pressure relief or bypass hatches
on the ducts from the furnaces to the ESPs. There are three BOSP fur-
naces at Fontana, Nos. 1, 2, 3, served by stacks No. 21, 22, 23,
respectively. Emissions from each ESP can be vented through any of
the three stacks.
Various operations in the BOSP building including hot metal re-
ladling, charging, tapping, and oxygen lancing of ladles to remove
residual metal from the refractory lining produce emissions that reach
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/I r\ e-
J ) -»o
f»
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42
the atmosphere through roof monitors and other building openings.
Some of these emissions are captured by a series of ducts that convey
them to the ESP serving furnace No. 3.
Air Pollution Controls
The major off-gas emissions are controlled by large electrostatic
precipitators. Partial control of emissions within the building is
also achieved by an ESP. A baghouse is scheduled to be installed to
control building emissions as discussed in Section V.
Observations
During the survey, furnace No. 2 was not in use. Excessive
visible emissions were observed originating from stacks No. 21 and 23
and from roof openings. These observations are summarized in Table IV-8.
The emissions were generally rust-red although yellow emissions charac-
teristic of scrap cutting were observed from roof openings on five
occasions. The 23 September observation of stack No. 23 was taken
when furnace No. 3 was not in operation. This emission thus originated
from either furnace No. 1 or from other operations within the building.
Company representatives indicated that visible emissions from
the stack could result from several causes. If the ESP was operating
cooler or hotter than its design range, or if any of the steam or
water sprays in the hood duct were inoperative, continuous emissions
could be expected.
Each of the main stacks is equipped with a Bailey Smoke Density
Meter and an'integrator to measure the total time the emissions exceed
20% opacity.
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Table IV-8
SUMMARY OF VISIBLE EMISSION OBSERVATIONS .
AT THE BASIC OXYGEN STEEL PROCESS FURNACES
43
Emission
Source
Date
(1975)
Time
(minutes)
Max. Opacity
Avg. Opacity
Stack Emissions
Stack 21
Stack 23
9/19.
9/19
9/22
9/22
9/23
9/23}
9/231
9/191
9/23
t
12
4,
14
19.
5.
10
12
5
75
13.5
15.25
60
60
100
50
45
100
60
100
100
40
45
58
41
30
47
33
83
27
ESPft Bypass Hatches
9/19 12.5 100 51
9/19 8.25 100 59
9/23 10.25 95 54
Yellow Smoke Emissions
Rbof~0pen"ing? "9717" 8.5" FO " 47
9/17 13.5 55 42
9/17 10.5 65 42
9/18 14.5 85 49
9/18 7.5 85 54
White and Rust Emissions
Roof Openings 9/17 12 80 44
9/17 5.25 45 38
t Upset condition reported to the San Bernardino County Air Pollution
Control Zone.
tt electrostatic precipitator.
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44
Examination of the smoke density recordings [Figs. IV-8, IV-9]
indicates that emissions from stack No. 23 varied only slightly and
were within acceptable opacity limits on both days illustrated, 20-21
September. The charts also show that the meters are kept in good
repair since they continue to return to a 2% minimum, indicative of
routine maintenance and the use of a live zero. On the other hand,
similar charts for stack No. 21 [Figs. IV-10, IV-11] show that
emissions from this stack were in excess of the Rule 50A limitation
for about six periods each day. This is probably indicative of
poor operation or maintenance of the ESP, but it is also directly
related to the cyclical operation of the BOSP furnace.
Reddish-brown emissions were observed when leaks occurred at the
seals on the pressure relief or bypass hatches mounted on the roof in
the exhaust stream from the furance to the ESP. These emissions were
related to the cyclical operations of the furnaces. Visible emissions
in the building were also observed during charging and tapping opera-
tions.
The most significant visible emissions within the BOSP furnace .
building that eventually reached the atmosphere through roof openings
resulted from hot metal reladling and lancing of ladles. Emissions
were produced when molten iron was poured from the hot metal transfer
car into the hot metal lad.le at the reladling station. Emissions
also resulted when ladles were lanced as part of regular maintenance
to remove metal deposits remaining on the refractory lining. Both
activities produced emissions that appeared to far exceed those pro-
duced by charging and tapping operations.
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45
Figure JV-8. Smoke Density Readings-Stack No. 23, 20 September 1975
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46
figure IV-9. Smoke Density Readings-Stack No. 23, 21 September 1975
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47
Figure IV-10. Smoke Density Readings-Slack No. 21, 20 September 1975
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48
Figure IV-11. Smoke Density Readings-Stack No. 21, 21 September 1975
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49
ROLLING MILL SOAKING PITS
Basic Process
Steel ingots from the BOSP or open hearth furnaces must be passed
through hot forming processes before they can be converted to finished
steel products. The ingots are heated in special furnaces called soak-
ing pits before they are fed to the primary rolling mills for forming
into intermediate forms such as slabs, blooms and billets. Coke oven
gas or natural gas is usually burned in the pits with combustion gases
and exhausted to the atmosphere through furnace stacks.
Emission Sources
There are 38 soaking pits serving the rolling mills at Fontana.
Each pair of soaking pits is served by a single 34 m (110 ft) tall
stack. Stack locations and designations are shown in Figure IV-2 and
listed in Table IV-3.
Air Pollution Controls
There are no air pollution controls on soaking pit emissions,
Observations
Excessive visible emissions were observed from six of the soaking
pit stacks [Table IV-9]. The emissions were gray to black and resulted
from improper fuel combustion. Because of the location of the stacks
with respect 'to the rolling mill buildings, many were virtually impos-
sible to observe from ground level while meeting EPA Method 9 require-
ments.
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50
Table IV-9
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT ROLLING MILL SOAKING PITS
Stack
No.
38
37
40
37
31
41
43
43
Date
(1975)
9/17
9/18
9/19
9/20
9/20
9/22
Time Maximum Opacity
(minutes) (%)
6
30.25
25
10
16.25
16.5
9
9
50
60
30
85
40
35
35
55
Average Opacity
(%)
38
56
25
58
27
26
26
45
HOT STRIP MILL
Basic Process
Hot strip mills reduce slabs formed from ingots in primary rolling
mills to flat strip steel generally less than 30 cm (12 in) thick. The
slabs are heated in reheating furnaces and then conveyed to a rolling
train for forming and finishing to size. The furnaces heat the slabs to
a temperature of about 1,100° to 1,300°C (2,010° to 2,370°F). Coke oven
gas or natural gas is generally used to fire the furnaces.
Emission Sources
The 218 cm (86 in) hot strip mill has three reheat furnaces
(Nos. 1, 2, 3). Each furnace is served by a 46 m (150 ft) tall stack.
Furnace No. 1 is served by stack No. 58, furnace No. 2 by stack No. 57
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51
and furnace No. 3 by stack No. 56. With the exception of minor
emissions released to the hot strip mill building when slabs are
removed from the furnace, all combustion products are exhausted
to the atmosphere through the stacks.
Air Pollution Controls
Emissions from the stacks are monitored by Bailey Smoke Meters
set to sound an alarm whenever the opacity exceeds 10%. This re-
portedly permits sufficient time for operating personnel to adjust
the combustion characteristics of the furnace before emissions exceed
the 20% opacity limit. The stack emissions are not visible from
within the mill; thus the need for the automatic alarm. There are
no other air pollution controls on the furnaces.
Observations
On 23 September, excessive visible emissions were observed from
Stack No. 57 serving Furnace No. 2 when the alarm failed to operate.
Emissions exceeded the 20% limit for 10 minutes during the period of
observation. The maximum opacity observed was 60%, with a 49% average.
SCRAP CUTTING
Basic Process
Basic iron and steel production processes and the finishing mills
generate scrap iron and steel that can be recycled through the steel
making process without waste. This scrap ranges in size from large
ladle "skulls" to small sheet scraps. Scrap steel is also imported
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52
to the plant from other locations. The large pieces must be cut or
broken into smaller sizes before they can be charged into the basic
oxygen and open hearth furnaces. This can be accomplished by cracking
the pieces by impacting with a large steel ball, by shearing plates
or more commonly by cutting with gas torches. When torches are used
for cutting ingots and other thick scrap, visible emissions in the
form of yellow-brown or green smoke are released to the atmosphere.
Emission Sources
The major scrap cutting operation is conducted in the open on
the east side of plant property. On several occasions, scrap cutting
was observed at other locations on plant property. For these open air
operations, the smoke is released directly to the atmosphere. Scrap
cutting inside buildings produces emissions that are released to the
atmosphere through roof monitors.
Air Pollution Controls
There are no air pollution controls for the scrap cutting operations,
Observations
Excessive visible emissions from scrap cutting operations were
observed on several occasions at both the main scrap area and south
of the BOSP area. These are summarized in Table IV-10.
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53
Table IV-10
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT SCRAP CUTTING AREAS
Date
Area (1975)
South of BOSP 9/17
Main Area 9/18
9/19
Time Maximum Opacity
(minutes) (%)
7.5
7.5
10
10.5
10
7.5
20
9.5
50
80
75
80
80
80
90
95
Average Opacity
(%)
34
57
37
46
52
44
56
79
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54
V. ANALYSIS OF THE STATUS OF COMPLIANCE WITH THE CONSENT ORDER
On 11 July 1974, the EPA and the Kaiser Steel Corporation entered
into a Consent Order (Docket No. 9-74-9) under which the Company agreed
to an implementation plan and schedule for reducing air pollution from
that facility. This Order was revised on 11 November 1974 to adjust
intermediate increments to the Order without affecting final compliance
dates. The Order included these six Appendices dealing with various
processes at the plant:
A Coke Oven Battery Stacks
B Coke Oven Batteries
C Basic Oxygen Steel Processing Shop
D Open Hearth Furnace Stacks
E Scrap Metal Cutting Operation
F Desulfurization of Coke Oven Gas
Subsequent to this revision, the Company proposed a $150 million
Steelmaking Modernization Project contingent upon securing financial
commitments and obtaining the necessary concurrence and permits from
regulatory agencies. This plan would extend the compliance dates of
portions of the air quality control program past those contained in the
Consent Order.
On 17 September 1975 progress toward compliance with the Consent
Order was discussed with a representative of the Company. Present were:
Mr. John H. Smith, Director, Environmental Quality Control,
Kaiser Steel Corporation
Ms. Lois E. Green, Enforcement Branch, EPA-Region IX
Dr. Jules B. Cohen, EPA-NEIC
Mr. Karl Krause, California Air Resources Board
Information obtained during that discussion is contained below.
Every milestone in each Appendix to the Order to date has been listed,
followed by Company progress in meeting that milestone.
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55
EVALUATION OF APPENDIX A REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Division,
shall complete the following acts with respect to its coke oven
battery stacks, listed below, on or before the dates specified:
A. "A" Battery Stack.
(1) 1 November 1974 - submit progress report on status
of research and development program.
By letter dated 30 October 1974 the Company transmitted "TRW Systems
Group Progress Report No. 15" prepared for EPA. TRW is conducting a
research and development program on a Charged Droplet Scrubber for Fine
Particle Control. The pilot plant portion of the program included a
proposal'to process one-half the normal output of "A" Battery stack at
the Kaiser coke ovens.
(2) 1 May 1975 - submit final control plan.
The corporation submitted a control plan on 10 June 1975 confirming
the system in (1) above. But the plan only addressed installation of
the prototype unit designed to process up to half the normal capacity
of the stack. A submittal on 23 April 1975, including drawings of the
unit, did not meet the requirements of the Order. The Company was so
advised on 23 May 1975. .
(3) 1 July 1975 - let contracts for the purchase of control
equipment or process modification.
On 25 June 1975 the Company advised they had let a contract for pur-
chase of the Charged Droplet Scrubber and for installation of the unit.
B. "B", "C", "D", "E", "F" and "G" Battery Stacks.
The Consent Order has no requirements to date; however, the Kaiser
Steel Modernization Program proposes to extend the EPA compliance date
of 31 December 1977 until 31 December 1978 on two stacks, and 30 June
1980 on the remaining three stacks. This assumes the success of the
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56
TRW project discussed above. Should this not be successful, a Wet
Precipitrol by Fluid Ionics would be considered; however, this
could extend dates even further.
EVALUATION OF APPENDIX B REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Division,
shall complete the following acts with respect to its coke oven
operations on or before the dates specified:
A. Pushing and charging operations at each coke oven in coke
Batteries "A", "B", "C", "D", "E", "F" and "G". For the
purposes of this paragraph, visible emissions from the
pushing and charging operations at each coke oven shall
be combined for determining interim compliance as re-
quired by sub-paragraph (5).
(1) 31 July 1974 - submit approvable operating and
maintenance program. Either certify compliance
as required by sub-paragraph (5) or submit final
control plan.
By letter dated 30 July 1974 the Company submitted an operating
and maintenance program and certified compliance with San Bernardino
County Air Pollution Control District (SBAPCD) Regulation IV, Rules 50
and 50A. The above action precluded the necessity for further activity
under this paragraph.
B. Coke oven doors and standpipes at each coke oven in coke
oven Batteries "C", "D", "E", "F" and "G". For purposes
of this paragraph, visible emissions from the doors and
standpipes at each coke oven shall be combined for deter-
mining interim compliance as required by sub-paragraph (5).
(1) 31 July 1974 - submit approvable operating and
maintenance program. Either certify compliance
as required by sub-paragraph (5) or submit final
control plan.
By letter dated 30 July 1974 the Company submitted an operating
and maintenance program and certified compliance with San Bernardino
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57
County Air Pollution Control District Regulation IV, Rules 50 and
BOA. The above action precluded the necessity for further activity
under this paragraph.
C. Coke oven doors and standpipes at each coke oven in coke
oven Batteries "A" and "B". For the purpose of this
paragraph, visible emissions from the doors and stand-
pipes at each coke oven shall be combined for determining
interim compliance as required by sub-paragraph (6).
(1) SI July 1974 - submit approvable final control
plan to -include installation of new doors as
well as operating and maintenance program.
A final control plan to replace all doors on "A" and "B" Bat-
teries was submitted on 30 July 1974. The operation and maintenance
program was included in the A(l) submittal above.
(2) 30 August 1974 - let contracts for the purchase of
control equipment or process modification.
On 4 September 1974 the Company advised that contracts were
awarded for new coke oven doors.
(3) 30 September 1974 - commence on-site construction or
installation of control equipment or process modification.
No submittal required.
(4) 31 December 1974 and 30 June 1975 - submit progress
report.
Progress reports were submitted on the dates required. The report
of 30 June 1975 indicated no foreseeable problem in meeting the com-
pliance schedule.
D. Such approvable operating and maintenance programs as are
required by paragraphs A, B and C above, shall be incor-
porated into and made a part of this Order.
No action required.
E. Program designed to bring combined visible emissions from
pushing and charging operations, doors and standpipes at
each coke oven in coke oven Batteries "A", "B", "C", "D",
"E", "F" and "G" into compliance with San Bernardino
County Air Pollution Control District Regulation IV,
Rules 50 and 50A.
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58
CD 31 August 1974 - submit plan for engineering studies.
A plan for conducting engineering studies, prepared by Battelle,
Columbus Laboratories, was submitted on schedule.
(2) 31 December 1974 - submit progress report on status
of engineering studies.
The Corporation advised that Battelle had completed the first
portion of their report to EPA on 30 December 1974. On 26 March 1975,
Kaiser submitted the Battelle report to EPA. The report, dated
31 December 1974 was a state-of-the-art review on control of emis-
sions from coke ovens.
(3) 31 July 1975 - submit results of engineering studies
and either certify compliance as defined above with
San Bernardino County Air Pollution Control District
Regulation JF, Rules 50 and 50A3 or submit an approvable
final control plan reflecting the state-of-the-art in
technology to achieve compliance. Such approvable
control plan shall be incorporated into and made a
part of this Order.
On 30 July 1975 the Corporation submitted the final portion of the
Battelle study resulting from field trips to a number of steel com-
panies throughout the country. The San Bernardino Air Pollution
Control Officer has indicated by letter (6 August 1975) to the cor-
poration that the report contained certain errors and drew some in-
correct conclusions.
The transmittal of 30 July 1975 did not certify compliance nor
did it contain an approvable final control plan as required.
EVALUATION OF APPENDIX C REQUIREMENTS
The KAISER Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to its basic oxygen steel processing shop building on or
before the dates specified:
A, Charging and tapping operations at furnaces No. 1 and 3.
15'October 1974 - achieve compliance with San Bernardino
County Air Pollution Control District Regulation IV,
Rules 50 and 50A.
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59
On 18 October 1974 Kaiser Steel advised that the required in-
crement of progress regarding the charging and tapping operation
had been completed. They did not certify to compliance with SBAPCD
Regulation IV, Rules 50 and 50A as required.
B. Hot metal transfer operation*.
(1) 31 December 1974 - submit final control plan.
The Company submitted an engineering drawing depicting the bag-
house and ductwork location with some details, in fulfillment of this
requirement.
(2) 15 February 1975 - let contracts for purchase of
control equipment or process modification.
On 18 February 1975 Kaiser advised that contracts had been let as
required. However, since delivery was not possible until January 1976
they requested an extension of the final compliance date from 15 De-
cember 1975 until 31 July 1976.
(3) 1 May 1975 - commence on-site construction or in-
stallation of control equipment or process
modification.
Kaiser Steel advised the Agency on 8 May 1975 that on-site prepa-
ration and installation of utilities had begun in order to comply with
this increment. The final compliance date has not yet been extended
by the Agency.
EVALUATION OF APPENDIX D REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Di-
vision, shall complete the following acts with respect to
its open hearth furnace stacks Nos. 1, 2, 4, 5, 6, 7, 8, and
9, on or before the dates specified:
* For purposes of Appendix C, the hot metal transfer operation at the
basic oxygen steel processing shop shall include the hot metal trans-
fer station which results in emissions from the sides and roof moni-
tors of the basic oxygen steel processing shop building. The hot
metal transfer station includes pouring of molten pig iron from tor-
pedo cars into ladles which carry the molten iron to the basic
oxygen furnaces.
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60
(1) 31 July 1974 - submit final control plan for upgrading
of existing electrostatic precipitators as well as an
operating and maintenance program therefor and for
the construction of additional control equipment (electro-
static precipitators).
On 24 July 1974 the Corporation submitted a final control plan
which included modifications to the precipitators, included an op-
eration and maintenance (O&M) program, and called for installation
of a balloon flue between the furnaces and precipitators to average
the flow.
(2) 30 November 1974 - let contracts for the purchase of
control equipment or process modification. Continue
to upgrade existing electrostatic precipitators and
implement operating and maintenance program as re-
quired by Decision No. 86-D of the Hearing Board,
Air Pollution Control District, County of San Ber-
nardino, California, which is incorporated into and
made a part of this Appendix.
On 14 November 1974 Kaiser Steel requested a revision in the
compliance date to 21 December 1974. This was followed on 4 De-
cember by a letter advising that the increment of progress had not
been met. After a meeting on 7 January 1975 at the EPA offices, the
Agency could find no justification for a delay. Kaiser Steel was
advised on 17 January 1975 that they were in violation of the Order
and must let contracts forthwith.
(3) 15 May 1975 - complete construction or installation
of all process modifications as required by the
Decision referenced in subparagraph (2) above.
The Corporation certified completion of all construction and pro-
cess modifications required by Decision No. 86-D of the Hearing Board,
SBAPCD, on 21 May 1975.
(4) 1 September 1975 - commence on-site construction or
installation of additional control equipment.
The date was not met. Instead, the Company has proposed their
Steelmaking Modernization Program which includes two new basic oxygen
steel furnaces. These furnaces would replace five open hearth fur-
naces, leaving two in operation and one for standby. The open hearth
furnaces would be operated at reduced rates so as not to exceed ex-
isting precipitator capacity.
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61
The Kaiser Steel plan calls for a final compliance date of 31
December 1978, 17 months later than required by the Consent Order.
EVALUATION OF APPENDIX E REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to its scrap metal cutting operation on or before the
dates specified:
(1) SI July 1974 - submit final control plan to include
a building enclosure and baghouse.
The Company submitted design drawings of a scrap cutting build-
ing with baghouse control on 24 July 1974.
(2) SO September 1974 - let contract for purchase of
building and control equipment (baghouse). Commence
off-site fabrication of building and control equip-
ment (baghouse).
On 4 October 1974 the Company advised that they had "initiated
contract awards" for the scrap cutting operation. As stated, this
did not indicate that the contract had been let as required by'the
Consent Order. This was clarified on 28 October 1974 when the
Company indicated awarding contracts for fabrication of the building
and for design and fabrication of a baghouse.
(3) 1 April 1975 - commence on-site construction or instal-
lation of building and control equipment (baghouse).
No certification was received; however, this date was missed and
the Company now indicates they will not erect a building for this
facility. Thus, the Company was advised by the Agency on 15 May 1975
that they were in violation of the Consent Order.
The new proposal is included in the Steel making Modernization
Program. By 5 October, machine torch cutting devices were anticipated
to be in place, along with the ball drop facility. Compliance by this
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62
facility will take advantage of the increased size of the charg-
ing boxes on the oxygen furnaces that have been proposed. However,
the anticipated completion date for those is 31 December 1978, 31
months after the compliance date in this Order.
The Company anticipates that using the machine torches will
reduce emissions enough to negate the requirement for a building
and the necessary air.pollution control equipment. This remains
to be seen.
EVALUATION OF APPENDIX F REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to the sulfur content of its coke oven gas on or
before the dates specified:
(1) 31 October 1974, SO April 1975, and 30 September
1975 - submit progress reports on status of
the research and development program.
Progress reports regarding similar installations at other
steel plants were submitted on 30 October 1974 and 30 April 1975.
The Company is considering two alternative processes for de-
sulphurization, the Firma Karl Still and the Sulfiban Process, but
a decision has not been made to date.
While the Consent Order requires a final compliance date of
31 December 1977, the Steelmaking Modernization Program is suggest-
ing 30 June 1981 for achieving compliance with SBAPCD Regulation IV,
Rule 62.
DISCUSSION
Review of the Consent Order documentation, coupled with in-plant
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63
observations and VEO's, indicates that the Kaiser Steel Corporation
has made progress in air pollution control at the plant but still
has much to accomplish.
Analysis of the documentation required by the Consent Order in-
dicated that in some cases the Corporation implied actions that did
not take place or were not going to take place. Thus, they submitted
plans for (1) modifying the ESP's on the open hearth furnaces, which
they now propose to eliminate through the Steelmaking Modernization
Program, and (2) for a scrap metal cutting building which they now
plan to negate by use of machine cutting torches which may or may not
be effective.
A major problem appears to be that those certifying compliance
at Corporate headquarters are not those complying at Fontana. Thus,
compliance will be elusive and certification meaningless unless:
(1) plant employees in the shops comprising the steel making operation
are aware of the necessity for following O&M procedures, submitted as
a requirement of the Consent Order to control air pollution, and (2)
plant employees are advised of Corporate determination to comply with
Federal, State and local -requirements. For example, O&M programs
have been submitted for coke oven Batteries "C" through "G"
(Appendix B, Part B) and "A" and "B" (Appendix B, Part C); yet the
field study documented numerous door leaks, including 29 VEO's that
recorded excessive emis-sions from doors and two VEO's that showed
excessive emissions from standpipes. If observations had been made
from top-side, additional excessive emissions from standpipes would
have been documented.
Without rigid requirements for the O&M necessary to bring in-
dividual portions of the coke oven door emission problem under con-
trol, it will certainly be impossible to bring combined emissions
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64
from pushing and charging operations, door and standpipes into
compliance. Thus, even if pushing and charging operations can
be modified to certail emissions to within the 3-minute limita-
tion, leaking standpipes, doors or charge ports (operating and
maintenance problems) will negate this effort.
The survey also indicated air pollution contributions from
facilities that were not covered by the Consent Order. Most of
these could be improved by additional instrumentation or by better
O&M procedures, but some need air pollution control equipment or
a combination of these methods. Excessive visible emissions were
recorded from blast furnace cast house roofs and stove draft
stacks (8), from the ESP stacks of the basic oxygen steel furnaces
(9), and from the soaking pits (8). Only those indicated earlier
were reported as emergencies, so others must be considered as routine.
In the case of the basic oxygen steel furnace, it would appear
that with three ESP's available and only two furnaces operating,
generally not concurrently, that sufficient ESP capacity is available
to control these emissions. Either a manifold across the inlets to
the ESP's or a ballon flue as proposed on the open hearth fur-
naces should provide a solution if additional maintenance will
not reduce stack emissions.
Since soaking pit stacks are probably not visible from within
the facility, smoke detectors with alarms could indicate when fuel
mixtures must be adjusted. This approach has been used success-
fully at other locations at the plant.
In the absence of Federal scrutiny in these areas, Complaint
Citations issued by the SBAPCD against those sources not covered
by APCD variances may provide some impetus for control. However,
with nominal assessments this may not be the case.
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APPENDIX
VISIBLE EMISSION OBSERVATION RECORD
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VISIBLE EMISSTOM OBSERVATION RECORD
Company
Date
Time First Sighted Plume
Time Start
Time Stop
Air Temperature
Wind Speed
Sky Condition_
Relative Humidity_
Wind Direction
Backqround
Plume Characteristics:
Color
Stack Height
(ft)
Continuous: ( ) yes
Dispersion Description
Observer location: (ft)
no
of stack
Sun location
( ) Back of Observer
( ) Right Shoulder
Emission Point
( ) Left Shoulder
( ) Other
4in
01
32
53
34
35
36
37
38
39
10
11
12
13
L4
15
16
17
L8
19
20
0
15
:
30
45
Min
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
0
IS
30
45
Min
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
0
15
30
45
NOTES:
Inspector
TSB-A-8
Date
-i:-:-FOP>: ?98
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MAP
Symbols
Sun =
Plume direction = -- ->
Water Vapor Condensate
Point where plume observed
Observer = -^f
Photographs: S&A File ( )
Comments
Enclosed ( )
None ( )
Signature_
Date
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