EPA 340/1-77-002
JANUARY 1977
                                Stationary Source Enforcement Series
         ir
                    INSPECTION MANUAL FOR ENFORCEMENT OF
                    NEW SOURCE PERFORMANCE STANDARDS
                    BASIC OXYGEN PROCESS
                    FURNACES
                         U.S. ENVIRONMENTAL PROTECTION AGENCY
                                Office of Enforcement
                             Office of General Enforcement
                               Washington, O.C. 20460

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 INSPECTION MANUAL FOR ENFORCEMENT OF

   NEW SOURCE PERFORMANCE STANDARDS:

     BASIC OXYGEN PROCESS FURNACES
        Contract No. 68-02-1086
          EPA Project Officer
              Mark Antell
             Prepared for

  U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
           Washington, D.C.
            January 1977

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This report was prepared for the U. S. Environmental Protection
Agency by Engineering-Science, Inc. of McLean, Virginia in partial
fulfillment of Contract No.  68-02-1086.  The contents of this
report are reproduced herein as received from the contractor.  The
o'pinions, findings and conclusions expressed are those of the au-
thor and not necessarily those of the U.S.  Environmental Protection
Agency.
                                ii

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                          ACKNOWLEDGEMENT
     This report was prepared under the direction of Terrence A.
Li Puma, Manager of the Air Pollution Control Department of
Engineering-Science, Inc.  The principal authors were Michael E.
Lukey and R. F. Krzmarzick.  The Technical Director and Editor of
the manual was M. Dean High, Vice President of Engineering-Science,
Inc.

     Project Officer for the U.S. Environmental Protection Agency
was Mr. Mark Antell.  The authors appreciate the contributions
made to this study by Mr. Antell and other members of the Division
of Stationary Source Enforcement.
                                iii

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                         TABLE OF CONTENTS

                                                      Page

ACKNOWLEDGMENT                                         iii

1.0  INTRODUCTION                                      1-1

2.0  NSPS AND SIP REQUIREMENTS                         2-1

     2.1  New Sources—NSPS                            2-1

     2.2  Existing Sources—SIP                        2-1

     2.3  Applicability of Standards                   2-3

3.0  PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS,        3-1
     AND EMISSION CONTROL METHODS

     3.1  Process Description                          3-1

     3.2  Atmospheric Emissions                        3_4

     3.3  Emission Control Methods                     o_g

4.0  MONITORING, RECORDKEEPING, AND REPORTING          4-1
     REQUIREMENTS

     4.1  Monitoring the Process, Control Device        4-1
          and Emissions

     4.2  Recordkeeping                                4-2

     4.3  Reporting Requirements                       4-4

5.0  STARTUP, SHUTDOWN, AND MALFUNCTIONS               5-1

     5.1  Startup                                      5-2

     5.2  Shutdown                                     5-2
                               IV

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                         TABLE OF CONTENTS (Continued)
                               •
                                                      Page


     5.3  Malfunctions                                 5-2

6.0  INSPECTION PROCEDURES                             6-1

     6.1  Conduct of Inspection                        6-2

     6.2  Inspection Checklist                         6-4

     6.3  Inspection Follow-Up Procedures              6-7

7.0  PERFORMANCE TEST                                  7-1

     7.1  Process Operating Conditions                 7-1

     7.2  Process Observations                         7-2

     7.3  Emission Test Observations                   7-3

     7.4  Performance Test Data                        7-5

8.0  REFERENCES                                        8-1

APPENDIX A    STANDARDS OF PERFORMANCE FOR NEW         A-l
              STATIONARY SOURCES

APPENDIX B    METHOD 9 - VISUAL DETERMINATION OF       B-l
              THE OPACITY OF EMISSIONS FOR
              STATIONARY SOURCES

APPENDIX C    S 12. - GENERAL POLICY OF THE-USE        C-l
              OF SECTION 114 AUTHORITY FOR ENFORCE-
              MENT PURPOSES

APPENDIX D    SUGGESTED CONTENTS OF STACK TEST         D-l
              REPORTS

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                          LIST  OF FIGURES

Figure                                                 Page

3.1     Basic Oxygen Process  Furnace                     3—3

3.2     Controlled Basic Oxygen Process  Furnace,         3-7
        Open Hood with Scrubber or Electrostatic
        Precipitator

3.3     Controlled Basic Oxygen Process  Furnace,         3-8
        Closed Hood with Scrubber


                          LIST  OF TABLES

Table                                                  Page

2.1     Representative Data from Process Weight Curve    2-2

6.1     Basic Oxygen Process  Furnace  Inspectors          6-9
        Worksheet, Part I - Process Data

6.2     Basic Oxygen Process  Furnace  Inspectors          6-10
        Worksheet, Part II -  Control  Equipment Data

6.3     Basic Oxygen Process  Furnace  Inspectors          6-11
        Worksheet, Part III - Startup,  Shutdown,  and
        Malfunction

6.4     Basic Oxygen Process  Furnace  Inspectors          6-12
        Worksheet, Part V - General Observations

7.1     NSPS Inspection Checklist for Basic Oxygen      7-6
        Process Furnace During  Performance Test
                              VI

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                         1.0  INTRODUCTION

     In accordance with Section 111 of the Clean Air Act, the
Administrator of the U.S. Environmental Protection Agency (EPA)
promulgated particulate standards of performance for new and modi-
fied basic oxygen process furnaces.  The standards became effective
8 March 1974 and apply to sources the construction or modifi-
cation of which was commenced after 11 June 1973.  The standards
are applicable to each basic oxygen process furnace and limit dis-
charge into the atmosphere of any gases which contain particulate
matter in excess of 50 mg/dscm (0.022 gr/dscf.)   For a complete
discussion of standards, see Appendix A.

     Under these new source performance standards, a performance
test must be conducted on any new or modified basic oxygen process
furnace to ensure that control equipment is designed and installed
which will provide compliance with the standard.  After determin-
ing that the facility with its control equipment does, in fact,
comply with the standards, it is the further intent of the regula-
tions that the equipment not be allowed to deteriorate to the point
where the standards are no longer maintained.  In fact, a specific
provision of the regulations, 40 CFR 60.11(d),  provides that affected
facilities shall be operated and maintained "in a manner consistent
with good air pollution control practice for minimizing emission."

     The purpose of this manual, therefore, was to provide the air
pollution inspector with necessary information so that he could
determine whether or not a furnace was still in compliance for
some period of time after the conduct of initial performance tests.
To provide for this continuing enforcement of emission standards,
the Division of Stationary Source Enforcement of the U.S. Environ-
mental Protection Agency properly anticipated the need for a series
of field inspection manuals, which could be used by an inspector to
assist him in determining whether a pollution source was complying
with all applicable regulations.  While this manual was developed
primarily to meet the need for enforcement of EPA's new source
performance standards, it was intended that the information con-
tained herein would be equally useful for enforcement of state
regulations applicable to all existing basic oxygen process fur-
naces .
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     In both cases the regulations jnay be enforced by  either
Federal or state air pollution control authorities.  Each  state
may develop a program for enforcing the Federal new  source per-
formance standards applicable to sources within its  boundaries.
If the proposed program is adequate, EPA will  delegate implementa-
tion and enforcement authority to the state  for all  affected  sources
with the exception of those owned by the U.S.  Government.   Also,
each state was required to submit implementation plans to  EPA in
1971 that included emission regulations which  would  reduce emissions
and ensure attainment and maintenance of the ambient air quality
standards (Section 110 of the Clean Air Act.)  If the  regulations
are not enforced at the state level, then EPA  is legally obligated
to enforce the State's Implementation Plan.  If a Federal  inspector
observes a violation of a state's regulation adopted under the
State Implementation Plan, he can enforce the  SIP regulation.
     The scope of this manual includes all operations normally
associated with basic oxygen process furnaces.   The standards apply
only to basic oxygen process furnaces.   Other pollutant sources in
the iron and steel industry are covered by other standards.

     This manual includes a description of the  process, a discus-
sion of process control and "emission instrumentation normally found
at EOF plants, startup and shutdown problems, an analysis of the
malfunctions that affect air pollution emissions,  operating para-
meters that are important from the inspector's  viewpoint, a step-
by-step inspection procedure which Federal (or State) enforcement
officials should follow, and recommendations for observing perfor™ar.C£
tests (stack tests).  Accompanying appendicies include supplemental
reference materials of importance to the inspector.
     This manual was prepared  from information  previously published
on basic oxygen process  furnaces,  from  stack tests  of several  fur-
naces at iron and steel  plants,  from applicable rules and regula-
tions promulgated by EPA and  published  in  the Federal Register and
from past experiences  of the  air  pollution  control  staff of
Engineering-Science,  Inc.   The assistance  of staff  from the Div-
ision of Stationary Source Enforcement  was  particularly helpful in
providing direction for  the  project.
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                     2.0  NSPS AND SIP REQUIREMENTS
2.1  NEW SOURCES—NSPS

     The Federal emissions regulations applicable to new or modi-
fied basic oxygen process furnaces are called New Source Perform-
ance Standards (NSPS).  They are published in the Code of Federal
Regulations under Title 40 CFR Part 60.  The standards require con-
trol at a level typical of a well controlled existing steel mill
and are attainable with existing technology.  To determine the
emission level which should be selected as the standard, extensive
on-site investigations were conducted and design factors, main-
tenance practices, available test data, and the character of stack
emissions were considered by EPA.  Economic analyses were also con-
ducted prior to promulgating the standards.  The EPA document which
provides background information on the derivation of the standards
is entitled "Background Information for Proposed New Source Per-
formance Standards" (7).

     Provisions of the regulation are applicable to each basic
oxygen process furnace.  A basic oxygen process furnace is defined
as any furnace producing steel by charging scrap steel, hot metal,
and flux materials into a vessel and introducing a high volume of
an oxygen-rich gas.  On and after the date on which the performance
test required to be conducted by paragraph 60.8 is initiated but
no later than 180 days after initial startup, no owner or operator
subject to the provisions of the regulations shall discharge or
cause the discharge into the atmosphere from a basic oxygen process
furnace any gases which contain particulate matter in excess of
50 mg/dscm (0.022 gr/dscf).  Opacity standards have not been pro-
mulgated for basic oxygen furnaces.

2.2  EXISTING SOURCES—SIP
     Under the 1970 Clean Air Act amendments, each state in 1971
had to file with EPA a State Implementation Plan which included
emission regulations to achieve and maintain ambient air quality
standards.  As a result of those implementation plans and efforts
to meet ambient air quality standards by 1975 through 1977, states
have developed emission limitations for practically all industries
that, when controlled, would help achieve the ambient air quality
goals.   EPA encouraged some uniformity and reasonable stringency
                                   2-1

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of the standards by publishing suggested standards as Appendix B
of a regulation on preparation of State Implementation Plans (23).
In the case of particulate emissions,  EPA published a reference
process weight table (Table 2.1)  representative of data from the
state and local regulations.  Thus, Federal standards are stated
with respect to grain loading in the emitted gas while the state
standards are generally stated with respect to the mass emissions
per unit of material processed.

     State or local agencies do not normally have an emission standard
specifically for the basic oxygen process furnaces.  Instead, process
weight regulations are commonly employed to limit particulate emissions
from a variety of industrial sources.   However, the actual limits vary
from state to state so Table 2.1 should be considered illustrative
only and should not be referenced for enforcement purposes.   Further-
more, state regulations are frequently modified and may contain quali-
fications, exceptions or  special provisions for certain source categories,
       Table  2.1  REPRESENTATIVE DATA FROM PROCESS WEIGHT CURVE
                                             Allowable
       Process weight rate,                 emission  rate,
              Ib/hr                            Ib/hr
50
100
500
1,000
5,000
10,000
20,000
60,000
80,000
120,000
160,000
200,000
400,000
1,000,000
0.36
0.55
1.53
2.25
6.34
9.73
14.99
29.60
31.19
33.28
34.85
36.11
40.35
46.72
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     By definition process weight per hour means "the total weight
of all materials introduced into a special process that may cause
any emissions of particulate matter" to the atmosphere.  In some
industries, the definition of process weight is somewhat complicated,
However, for the basic oxygen process and steel making industry, the
process weight referes mainly to the amount of hot metal and the
amount of scrap added to the vessel which sums to the production
rate.  Fluxes added to the furnace later in the cycle constitute
less than 1/2 of one percent of the process weight.  These quanti-
ties are normally recorded in an operator's daily log for each heat
produced at a steel plant.

     Basic Oxygen Process Furnaces  (BOPF) have steel production
capacities between 100 and 325 tons per heat; one BOPF cycle is
commonly referred to as a heat.  A  typical 140 ton furnace has a
cycle  time of approximately 40 minutes.  These furnaces would
have a process weight rate of approximately 200 tons per hour.
Therefore, a process having a process weight rate of 200 tons
per hour would be permitted to emit a maximum of 40.35 pounds
per hour of particulate matter to the atmosphere.

     The pollutant of most concern with respect to the existing
standards and this operation is particulate matter (grain loading).
Particulate concentration is limited to a maximum of 50 milligrams
per dry standard cubic meter (0.022 grains per dry standard cubic
foot.)  This standard refers to that portion of the heat beginning
with the oxygen blow and ending just prior to tapping.  Reblows
are included but charging, testing  and pouring are not covered by
this regulation.  Results of tests  conducted by the U.S. EPA have
demonstrated that the 50 mg/dscm (0.022 gr/dscf) is a practical
standard since many of the new steel plants currently operating
in this country today have little difficulty in achieving that
standard.

     Opacity regulations of most states apply to all point sources
regardless of whether the emission  is discharged from a stack.
Opacity limitations in some states may apply to fugitive dust
sources.
2.3  APPLICABILITY OF STANDARDS

     Emission standards are specifically referenced to the basic
oxygen process furnace and do not apply to the electric arc or
open hearth steel-making processes.  Other New Source Performance
Standards were promulgated by the U.S. EPA for the electric arc
                                 2-3

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furnace at 40 FR 43852 (September 23, 1975).  The BOPF emission
standards apply to the concentration of particulate matter in the
gas stream associated with the steel-making operation by the BOPF
which begins after the oxygen lance is inserted and ends prior to
tapping.  The heaviest concentration of particulate emission occurs
during the oxygen-blowing period.

     The New Source Performance Standards apply to each basic oxygen
process furnace used in iron and steel plants.  Moreover, the standards
apply after a new facility has been started up and reached some
degree of equilibrium.  For the first performance test, the owner
must give 30 days advance notice to the Administrator of EPA.  The
standards are not applicable during startup, shutdown and malfunction
since these periods do not constitute representative operating con-
ditions.  However, as will be described later, the owner must report
all excess emissions on-a quarterly basis although NSPS address only
stack emissions and not fugitive emissions.  Also, the regulations
ensure that plant operators properly maintain and operate the affected
facility and control equipment between performance tests including the
periods of startup, shutdown and unavoidable malfunction.

   In addition to the BOPF, steel mills recently have begun utilizing
the Q-BOP furnace.  The primary difference between the Q-BOP and
BOPF is that the Q-BOP has no lance; the oxygen is introduced into the
furnace through tuyeres in the bottom of the vessel.  The NSPS require-
ments are not applicable to the Q-BOP furnace, however, inspectors
should be aware that this process is in commercial use and many Q-BOPTs
will probably be installed over the next several years.  Sufficient
information and data has not been developed at this time to discuss
inspection procedures for the Q-BOP furnace.  When such information
is available, it will be published as an addendum to this report.

     One of the more difficult subject areas to determine is the
applicability of the standards to existing sources which undergo
modification.  Under the revised regulations the definition of
affected facility is limited to an apparatus to which a standard
applies.  "Modification" means any physical change in, or change
in the method of operation of, an existing facility which increases
the amount of any air pollutant (to which a standard applied) emit-
ted into the atmosphere by that facility or which results in the
emission of any air pollutant (to which a standard applied) emitted
into the atmosphere not previously emitted.  The definition of
modification and other questions of applicability are fully dis-
cussed at 40 FR 58416 (December 16, 1975)(9).
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     A recommended procedure is offered in Section 6.0 of this
manual for Federal and state enforcement officials to inspect a
basic oxygen process furnace of a steel plant.  The enforcement of
state standards and Federal standards are nearly the same except that
the nature of the emission standards is different.  The Federal
standard is written with respect to grain loading or stack gas con-
centration and the state standards are generally written in terms
of the mass emissions from this type of process.
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         3.0  PROCESS DESCRIPTION, ATMOSPHERIC EMISSIONS,
                   AND EMISSION CONTROL METHODS

     Existing technology for producing steel in this country
centers around three different furnaces:  the open hearth, electric
arc, and basic oxygen process furnace (BOPF).  The open hearth fur-
nace uses an oil or gas flame and air jet to convert solid and mol-
ten iron into steel.  This process is relatively slow and the amount
of raw steel produced by this method has decreased from 84% in 1962
to 37% in 1970.  Electric furnaces are generally charged with scrap
and alloys to produce a variety of specialty steels and other high
grade metals.  The heat is produced by an electric arc between the
electrode and the metal.  Steel production by the electric arc fur-
nace increased from 9% in 1962 to 15% in 1970.  The basic oxygen
process furnace converts molten pig iron and scrap to steel by blow-
ing large quantities of oxygen into the charge.  The principle ad-
vantage of this system over the open hearth is its higher production
capacity.  Undoubtedly, new steel mills desiring additional steel
production capacity in this country will build BOPF or electric
arc furnaces in lieu of open hearth furnaces.
     The basic oxygen process furnace is a major operation in the
integrated iron and steel industry.  It is unlikely that an enforce-
ment official would have to contend with a basic oxygen furnace in
any manufacturing plant other than at an integrated iron and steel
facility.  On the other hand, blast furnaces, sintering plants, and
even electric arc steel furnaces can be found separately in dif-
ferent shops throughout this country.

3.1  PROCESS DESCRIPTION
     Basic raw materials for the BOPF consist of hot molten metal
pig iron produced by a blast furnace and scrap.  Steel is produced
by lowering the carbon, manganese and silicon contents of pig iron
by oxidation at elevated temperatures to levels desired for the
particular brand of steel.  Impurities, such as sulfur and phosphorus,
are also lowered by using fluxes of appropriate composition.  Steel
scrap, flux and hot metal are charged into the furnace lined with a
refractory material.  The steel scrap consists mainly of billets and
slabs, compacted automobiles, and even recirculated metal.  The hot
metal comes from the blast furnace and is usually brought in the
molten state to the BOPF by means of submarine ladle cars.  The

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basic oxygen process furnace is also known as the oxygen blown
steel-making process.  (It should be noted that oxygen may also be
used in the open hearth process to increase production ratas.)
High purity oxygen (95% or better) is blown into the molten metal
bath in the vessel.  The BOPF is a vertical cylindrical container
open on the top end and about 20 feet in diameter at its widest
point.  It is pear-shaped as depicted in Figure 3.1.  The BOPF is
charged through the top and a water-cooled lance is lowered during
the oxygen blowing.  The vessel is tilted to facilitate operations
which include charging, slagging, tapping, and pouring.  Sixteen
steel companies have 34 of the 36 BOPF's in the U.S. today.

     The charge is generally 25 to 35% scrap metal, and 65 to 75%
molten pig iron.  The scrap is charged first and may be preheated
by the combustion of natural gas introduced into the vessel by the
lance.  Charging is completed by the introduction of flux and mol-
ten pig iron.  The blowing portion of the heat occurs when oxygen
is introduced into the molten charge through the lance at sonic
speeds.  The amount of oxygen varies slightly and depends on the
quantity of impurities and grade of steel desired but is on the
order of 2,000 scf/ton of steel produced.  The oxygen combines
with the iron and carbon in an exothermic reaction (a chemical re-
action which liberates heat) thus precluding any requirement for
external heating of the vessel.  The oxygen blowing is carried out
at sonic velocity so as to provide sufficient agitation of the
molten charge to melt the scrap and provide a good thermal reaction.
The blowing lasts about 20 to 25 minutes on a 250-ton vessel, at the
end of which time the vessel is tilted to obtain a sample and the
steel composition is spectrographically analyzed by computers.  If
the analysis indicates that the composition has not been reached
the vessel is tilted to the upright position and a reblow takes
place.  Reblow generally occurs about every third heat and will
last about 5 minutes.  When the desired composition is reached
(mainly depending on the carbon content of the steel) , the steel
is poured into a ladle where it is subsequently poured into molds.
The cycle time depends on the process, but is generally about 40
to 45 minutes.

     Furnace capacity varies greatly and in the U.S. typical ranges
are between 100. and 325 tons capacity per heat with production rates
between 150 and 500 tons per hour.  The trend in new units is towards
larger furnaces.

     For a more complete description of the operations of a basic
oxygen process furnace, please refer to:

     - A Systems Study of the Integrated Iron and Steel
       Industry (2)
     - Air Pollution Aspects of the Iron and Steel
       Industry (3)

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                                                      EXHAUST HOOD
HIGH PURITY
OXYGEN AT
SUPERSONIC
SPEED
                                                      REFRACTORY LINING
TAPPING PORT
      Figure  3.1    Basic oxygen  process  furnace
                                 3-3

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     - Background information for Proposed New
       Source Performance Standards (7)

3.2  ATMOSPHERIC EMISSIONS

     Potential atmospheric emissions associated with basic oxygen
process furnaces are formed when a water-cooled lance impinges
oxygen at high velocity on the hot metal and scrap charge to cause
violent agitation and mixing of oxygen with molten iron.  Rapid
oxidation of carbon, silicon, manganese, and some iron occurs.
Fumes and gaseous emissions emanate from the mouth of the converter
and enter the hood during the oxygen blow.  Highest emissions occur
during this oxygen-blowing period.

     Emissions from the BOPF unit also occur during charging, flux-
ing, slagging, metal testing, and tapping.  Charging of the molten
pig iron and tapping are by far the largest of these lesser stages
of the heat.  The vessel is tilted for these two operations and, as
a result, some particulate (reddish brown in color) escapes the hood
and passes through the roof monitors.   During charging, when the
hot pig iron comes in contact with the cool scrap metal, a fine
silver-like dust known as kish is emitted.  Kish is also emitted
from the ladle when the hot metal surface is skimmed prior to
charging to the furnace.  Kish consists of angular flakes of
graphite having smooth surfaces.  The emission of kish may include
coarse fragments of opaque magnetic iron oxide particles, rounded
particles of red iron oxide, and traces of quartz and calcite.
The kish is uncontrolled, yet because of its density, it can
become airborne.

     The silica fume that occurs in the early part of the blow is
collected as a grey to off-white material.  It often contains small
amounts of iron, manganese, and carbon.

     Later, during the BOPF blow, the predominant particulate emis-
sion is reddish-brown iron oxide.  The particulates are rounded,
transparent, smaller than 1 micron, and tend to agglomerate.   Some
fine, black spheres of magnetite are present and are covered with
red iron oxide.  If galvanized scrap is part of the charge, zinc
oxide in the collected dust makes the dust unsuitable for sintering
for feed to the blast furnace.

     The fineness of the BOPF particulates makes them difficult to
measure.  As a result, size analyses have varied widely.  Reports
show (1) 95 per cent are smaller than 1 micron, with a median of
0.45 micron, and (2) 99 per cent smaller than 0.2 micron, with a
median of 0.065 micron.  Another recent report gives a median dia-
meter of 0.012 micron.  Another report states that 20 per cent are
smaller than 0.5 micron, 65 per cent are between 0.5 and 1.0 micron,
and 15 per cent are between 1.0 and 1.5 microns.

     The dust concentration (as reported by one source) varied from
2.02 to 4.96 grains/scf.  Another source states that dust concen-
trations range up to 20 grains/scf.  The volume of exhaust gas  (at

                                3-4

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temperature of combustion) is about 25 times greater than the vol-
ume of oxygen blown for combustion hood designs.  The amount of
dust per net ton of raw steel was reported in 1959 to range from
14.5 to 27.4 pounds/ton.  In 1968, an average of 40 pounds per ton
was reported by one plant.  Others state it is 1 to 2 per cent of
the weight of the metallic charge.
     In the Stora-Kaldo Oxygen Process, a cylindrical vessel is
rotated in almost a horizontal position.   Operating principles are
similar to those for the upright BOPF vessels.   More scrap can be
charged than in the BOPF, but the heat time is  longer.   The Sharon
Steel Corporation has the only two Kaldo furnaces in the United
States, rated at 150 tons per heat.  The size of particulate emis-
sions is reported to be larger than particulate emissions from the
BOPF; only 6 per cent is smaller than 1 micron, probably as a result
of agglomeration.  About 10 pounds of dust are said to be generated
per net ton of raw steel produced.

     The standard of performance that has been set by the U.S. EPA
restricts particulate emissions to the atmosphere from the begin-
ning of the oxygen blow until just prior to tapping.  The ancillary
operations are not easily controlled and also are not regulated by
the U.S. EPA, but some states are requiring operating practices
which minimize dust and visible emissions during these ancillary
phases.

     During the oxygen-blowing process, exhaust gases leave the
mouth of the converter to be captured in the hood system.  The
temperature of the gases leaving the furnace is several thousand
degrees F so the exhaust must be cooled before entering any air
pollution control device.  The exhaust gases contain iron oxide as
described above but also may contain carbon monoxide.   In this
country, two types of capture systems have traditionally been used
to collect the exhaust gas as it leaves the vessel:  the closed
hood (also known as a movable hood) and combustion hood.  For a
system which utilizes a combustion hood, the iron is oxidized to
Fe20s, while for the BOPF shops using a closed hood (movable hood)
the iron is just partially oxidized to FeO.  In the combustion hood
most of the carbon monoxide emitted from the vessel is  converted to
a non-explosive carbon dioxide in the upper portion of  the hood.
For a closed hood system, carbon monoxide is a major constituent of
the exhaust gas all the way to the scrubber exhaust stack.  The
iron oxide dust is very fine with both hoods but is somewhat larger
in BOPF using movable hoods.  Particle size ranges from 0.01 to
10.0 p. for combustion hoods and 0.5 to 30.0 u for movable hoods.

     While there are several process factors which can affect air
pollution emissions from the basic oxygen process furnace, the two
most important operating variables are oxygen-blowing rate and
steel production rate.  Naturally, larger vessels can be expected
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to emit more contaminants (on the basis of mass emissions) to the
atmosphere than smaller vessels.  Very seldom do steel companies
use other than design capacities during their production schedules.
In other words, an inspector does not have to worry about a half
charge or quarter charge to the vessel when he visits the plant.
If the unit is designed for 250 tons per heat, it is likely that
the charge will be of that quantity.  Typical operating capacities
from each plant/vessel can be obtained from operators' daily logs
which are routinely kept at each shop.
     The emissions from the BOPF are governed by the oxygen-blow-
ing time and oxygen-blowing rate.  It has been noted that approxi-
mately 1,800 to 2,000 cubic feet of oxygen are required for each
ton of steel produced.  Different types of steel will require dif-
ferent amounts of oxygen.  The oxygen-blowing time is about 25
minutes including reblows.  A reblow may be required after the
vessel has been turned down and the metal spectrographically anal-
yzed if it does not have the proper carbon content.  A reblow may
last 5 to 10 minutes.
3.3  EMISSION CONTROL METHODS
     The best controlled BOPF plants in the U.S. will either have
high energy venturi scrubbers or electrostatic precipitators to
reduce particulate emissions to acceptable limits.  There are
three combinations of hood arrangement and abatement devices that
are traditionally used for the BOPF facilities.  These include:
          Combustion Hood, High Energy Venturi Scrubber
          Combustion Hood, Electrostatic Precipitator
          Closed Hood, High Energy Venturi Scrubber
     High concentrations of combustible carbon monoxide make the
hot gases potentially too hazardous to clean in the arcing electric
field of an electrostatic precipitator when using  the closed hood
system.  Figures 3.2 and 3.3 illustrate the overall abatement  system
involved in capturing particulate emissions emanating from a BOPF
operation.  The system utilizing a  closed hood will flare carbon
monoxide gases at the stack exit although some foreign plants have
used the carbon monoxide gas stream from the BOPF  for the production
of process steam.  Smaller volumes  of exhaust gases will be treated
with a closed-hood, high-energy venturi system than with the other
two combustion hood systems.  All three combinations mentioned  above,
had been tested prior to enactment of the particulate concentration
emission regulation for the BOPF.  Furthermore, all present systems
are capable of attaining the U.S. EPA New Source Performance
Standards for the BOPF.

     From the air pollution control viewpoint, the major problem
associated with the BOPF is particulate matter and the abatement
equipment.   In reality,  this problem is one of maintenance rather

                               3-6

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              COMBUSTION
                CHAMBER
              OIYGEN
               LANCE
OJ
ELECTROSTATIC
 PRECIPITATOR
                                                 SLUDGE
              Figure 3.2   Controlled  basic oxygen process  furnace,  open hood with
                            scrubber or  electrostatic  precipitator

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       OXYGEN /
       LANCE V
           /
                               PRIMARY
                              SCRUBBER
u>
i
00
                                          WATER
                                          SPRAYS

                                        VENTURI „
                                       SCRUBBER
                                                                MIST
                                                            ELIMINATOR
STACK
                        WASTEHATER RECIRCULATED

               Figure 3.3  Controlled  basic oxygen  process  furnace,  closed hood
                                            with scrubher

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than design parameters.  It has successfully been proven that
application of currently available air pollution technology, will
result in compliance with applicable Federal and state emission
standards.
     Energy requirements for a 60-inch pressure drop venturi with
a 50,000 cfm gas flow rate is about 800 horsepower.  In modern steel
mills, the abatement equipment is an important part of the BOPF op-
eration and malfunction of a precipitator or scrubber would soon be
noticed due to the resulting visible emissions.  In other cases, the
plant would continue to operate with limited control available during
malfunction.  Operators would not exhaust these gases untreated to the
atmosphere since they are easily distinguishable.  Instrumentation is
commonly employed and almost all steel mills will have a routine main-
tenance schedule for the air pollution abatement equipment.

     One of the critical factors which applies to both types of con-
trol devices (scrubbers and precipitators) is the gas temperature
entering the unit.  Gas temperatures at the mouth of the furnace
average about 2,800°F-  Cooling is mandatory before the gases enter
either a precipitator or venturi scrubber and is accomplished with
a series of water sprays controlled automatically by temperature
sensors.  Certain banks of water sprays are activated as the temp-
erature increases from the first portion of the oxygen-blowing
period.  Generally, the gas temperature entering the precipitator
or venturi scrubber ranges between 300 and 500°F.  Higher tempera-
tures will cause reduced efficiencies due to the temperature effect
on particulate resistivity with electrostatic precipitators and may
also cause adverse operation of the venturi scrubber.
     There are several operational control features of an electro-
static precipitator which are important in cleaning the effluent
gas.  The spark rate of a precipitator for a BOPF installation
should range between 75 and 125 with an average of about 100 sparks
per minute.  Spark rate meters have traditionally been installed on
modern precipitators as an indication of their operating performance
to the manufacturers.  Some of the newer precipitators will use the
spark rate to automatically adjust the primary and secondary voltages
to certain sections in order to maintain a uniform cleaning efficiency.
The spark rate from each section of the precipitator would be the
quickest indication whether any abnormal conditions exist for this
abatement device.
     Other instrumentation which exists on electrostatic precipitators
include the primary and secondary voltage meters.  In this case,
specific quantities indicating voltage cannot be universally applied
to all precipitators controlling BOPF emissions.  At best, the pri-
mary and secondary voltage meters will indicate if there are any "dead"
sections present.  In a similar fashion, ampere meters on precipitators
would indicate the operability of certain sections within the

                               3-9

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precipitator.   BOPF precipitators will have 20 to 50 sections and,
if several are "dead", the overall collector efficiency is reduced.

     Other instrumentation may include a device to determine the
velocity of the gas stream entering the precipitator.  To maintain
a desired efficiency, the flow rate through a precipitator must be
uniform.  By changing the velocity by a factor or two (from the
design velocity), the efficiency may decrease by as much as 20%.
     Temperature sensors are usually connected to alarms to prevent
severe damage  to a precipitator or scrubber in the event that the
inlet gas temperature becomes too high.   Several steel plants have
bypasses which would exhaust the gas,  untreated, to the atmosphere
in the event that the temperature exceeded the designed operating
condition for  the precipitator.  Changes in temperature and moisture
will alter the resistivity of the BOPF dust.
     Venturi scrubbers have fewer operating control variables than
a precipitator for BOPF installations.  Of prime importance on
scrubbers is the pressure drop.  For removing the small diameter
particulate that is associated with the  BOPF steel-making operation,
high energy venturi type scrubbers must  be used.  This refers to
pressure drops between 60 'and 75 in wg.   Some venturi systems have
twin throats and some might even be equipped with variable throats.
At any rate, the pressure drop across  the entire system should be
in excess of 60 in wg.  Typical throat velocities which correspond
to these pressure drops range from 200 to 600 ft/sec.
     Almost all scrubbers will include manometers or other gauges
which would indicate the pressure drop across the unit.   Some plants
may have manometers on the water injection nozzles at the throat.
To a lesser degree, the water flow rate  within the scrubber is
important.  For the BOPF installations,  the water requirements for
a venturi scrubber are about 3 gallons per minute per 1,000 scfjn.
Most modern steel plants will have monitoring systems that will
record the pressure drop, water flow rate,  and air flow rate to the
scrubber.

     Many plants whether using venturi scrubbers or electrostatic
precipitators  may have an opacity meter  on the stack outlet.   For
safety precautions many steel plants will also monitor the exhaust
gas in the duct for carbon monoxide, hydrocarbons, and temperature.
For these BOPF installations, the opacity meter is an indication
of particulate emission.  Of the modern  steel plants observed, con-
tinuous 24 hour charts were available  for opacity on the BOPF stack.

     Further detail on air pollution control equipment applications
for basic oxygen process furnaces can  be obtained from:
     - Air Pollution Engineering Manual  (4)
     - Background Information for Proposed N^w Source
       Performance Standards (7)
                               3-10

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Air Pollution, Volume III, Sources of Air Pollution
and Their Control (18)

Control of Metallurgical and Mineral Dusts and
Fumes in Los Angeles County (6)

Control Techniques for Particulate Air
Pollutants (10)

Survey of Air Pollution from the Kaiser Steel
Plant (22)

Electrostatic Precipitator Technology (1)

Air Pollution Manual, Part II, Control Equipment (5)

An Outline of Metallurgical Practice (17)

Wet Scrubber System Study (20)
                        3-11

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   4.0  MONITORING, RECORDKEEPING, AND REPORTING REQUIREMENTS

4.1  MONITORING THE PROCESS, CONTROL DEVICE AND EMISSIONS
     One purpose of monitoring operations and maintenance of the
basic oxygen process furnaces at iron and steel plants is to ensure
that the compliance determined by performance tests is maintained
on a continuing basis by proper operation and maintenance of all
equipment.

     From an air pollution control viewpoint, the major problem
associated with steel making is efficient capture of particulate
matter generated by the furnaces and subsequent removal of the
particulate by abatement equipment.  It has been positively shown
that with current air pollution control technology, particulate
emissions from these plants can be reduced to meet all applicable
Federal and state emission standards.  Thus assuming proper design
of the abatement system, the problem becomes one of proper main-
tenance and use of the equipment.
     At the present time, new source performance standards for new
or modified basic oxygen process furnaces do not require any moni-
toring equipment on the processes, on the control equipment, or on
the emissions discharged to the atmosphere.  However, the process
monitoring that will likely be found on a BOPF will be the temper-
ature of the molten steel and the oxygen-blowing rate.  The emission
monitoring that will likely be found on a BOPF will be the measure-
ment of carbon monoxide concentrations.  Occasionally one may find
opacity being monitored.  The control equipment monitoring will be
an integral part of the control equipment design and will typically
identify pressure drops across the equipment, water use, electrical
use, spark rate, etc.

     Either specific or general monitoring requirements may be
in effect under certain State Implementation Plans.  However,
EPA has not promulgated any minimum requirements for BOPF's.
                               4-1

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4.2  RECORDKEEPING
     Since automatic monitoring is not presently required for basic
oxygen process furnaces, recordkeeping on a routine basis becomes
extremely important to provide a method for the air pollution inspector
to determine that operating and maintenance practices are consistent
with reasonable air pollution control needs.  Records should be kept
on production processes, on control equipment and on emissions.  Each
of these parameters are described separately although obviously there
are interrelationships.

     Also, it should be clear that the suggested recordkeeping is
not now required by the NSPS and probably not by any of the state
agencies.  Section 114(a)(ii) of the Clean Air Act, as amended, pro-
vides that the Administrator may require the owner or operator of
any source to provide information for the purpose of determining
"whether any person is in violation of any such standard or any
requirement of such a plan."  This is one of the most important
enforcement tools under the Clean Air Act, in that the source can be
required to provide the information which may be the basis for later
enforcement by EPA.
     The facility operator should maintain a description (tabulation
and schematic diagrams) of the plant identifying major equipment
items, types of furnaces, and controls used for steelmaking opera-
tions.  Process instrumentation does exist at all steel mills and on
a continuing basis records are kept of the amount of scrap and mol-
ten iron charged to the furnace and the amount of oxygen used per
,blow.  These historical records will be of importance to the field
enforcement official in assessing the operating status of the BOPF
during his plant visit.

     Within an integrated iron and steel mill, there may be three
different types of furnaces:  open hearths, electric arcs and basic
oxygen processes.  However, the types of records that will likely
be maintained are similar.   On each BOPF furnace, the following
information should be recorded and very likely will be available
in the company's records for each heat or batch:

     (1)  Quantity of pig iron and scrap charged, to nearest ton;

     (2)  Quantity of steel produced, to nearest ton;

     (3)  Specification of the steel ingot ;

     (4)  Date and time heat began and ended, to nearest minute;
                                 4-2

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Errata: EPA 340/1-77-002.  Basic Oxygen Process Furnace Inspection Manual
page 2-4
amend paragraph two to read:  In addition to the BOPF, steel mills recently
have begun utilizing the Q-BOP furnace.  The primary difference between the
Q-BOP and BOPF is that the Q-BOP has no lance; the oxygen is introduced into the
furnace through tuyeres in the bottom of the vessel.  The NSPS requirements
are applicable to the Q-BOP furnace, however sufficient information and data
has not been developed at this time to discuss inspection procedures for the
Q-BOP furnace.  When such information is available, it will be published as
an addendum to this report.

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     (5)  Oxygen consumption, to nearest 100 cubic feet;

     (6)  Fuel or compressed air consumption, if any, to
          nearest 100 cubic feet;

     (7)  Flux identification by constituents, and consumption,
          to nearest 100 pounds;

     (8)  Malfunctions;

     (9)  Operating deviations for above items.
     The purpose of recording the above process  data is to be able
to compare the batch or heat production cycle at the time of in-
spection with the production at the time of the  performance test.
The emission rate for a given steel specification will increase if
the heat is produced quicker by using more oxygen.  Also, the cap-
ture efficiency of the hood would probably decrease as production
rates increased above the performance tested production rate.
     The exhaust gas collection, venting, and emission control
system should be described (diagrammed) in detail.  The sequence
of controls and types of controls should be outlined and described
using quantitative parameters.  For each control system, the re-
spective information listed below should be recorded at the inter-
vals indicated:
     (1)  Quantity of collected dust and fume, by month
          to nearest ton;

     (2)  Volumetric flow on inlet to collector, on first
          of each month;

     (3)  Volumetric flow on outlet from collector, on
          first of each month;

     (4)  Pressure drop across the collector (venturi
          scrubber or electrostatic precipitator) after
          cleaning, on first of each month;

     (5)  Static pressure from fan through collector,
          gas cooling system and ductwork to collecting
          hood, on first of each month;

     (6)  Results of any carbon monoxide analyses, on
          first of each month;
                               4-3

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     (7)  Inspections, maintenance and repairs, by month; and,

     (8)  Malfunctions, by month.

     The purpose of having the above information kept on the air
pollution control system is to ensure that air contaminants gener-
ated by the furnaces will be collected by the electrostatic precipi-
tator,  scrubber or other collection system the same as when the
performance tests were conducted.   The quantity of dust collected
should remain proportional to the production of furnaces hooked to
the system.  The volumetric flow measurement on the inlet and out-
let will indicate leaks in the precipitator or scrubbers.  Static
pressure measurements will indicate leaks in ductwork or ductwork
filled with dust.  Capture velocity at the hoods will indicate if
the particle capture efficiency is changing.

     Many steel plants will have daily maintenance records which
indicate some of the less critical operating parameters of the
control system.  These data might include the voltage or amperage
to the various fans, the alkalinity of the scrubber water, the
water addition rate, voltage and amperage to the electrostatic
precipitator, etc.  Those plants which do not have periodic main-
tenance inspections are likely to have malfunctioning control equip-
ment.  Proper maintenance is an absolute requirement to reducing
emissions to the atmosphere.

     The inspector should not record visual emission observations
which have been taken by plant owners or operators unless they have
been certified by EPA or a state agency to make such opacity obser-
vations.  The plant operator should record and report complaints
and should indicate the probable cause of the problem.  This data
should be noted by the inspector.

4.3  REPORTING REQUIREMENTS
     The EPA reporting requirements suggest that the owner or
operator of a source, subject to continuous monitoring and record-
ing requirements> should summarize such measurements monthly and
should submit such summaries to the state on a quarterly or more
frequent basis.  As will be described later, the Federal require-
ment for new facilities to report startup, malfunction or shutdown
is on a quarterly basis.  Therefore, it seems logical and consistent
to suggest the above records also be summarized on a monthly basis
and submitted to the state quarterly.

     40 CFR 60.7 contains notification and recordkeeping requirements
for all facilities subject to NSPS.  This section details the proce-
dures for notifying the Administrator of construction, reconstruction,
modification and startup and also requires that owners and operators
maintain a file of all recorded information required by the regula-
tions for at least two years following the dates of such measurements
or reports.

                               4-4

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     Suggestions for formats and contents of recordkeeping tables
are indicated in Tables 6.1, 6.2, 6.3, 6.4 and 6.5 at the end of
section 6.0.

     For further detail on monitoring, recordkeeping, and report-
ing requirements, please refer to:

     - Federal Register, October 6, 1975  (14); and

     - Guideline for the Selection and Operation of a Continuous
         Monitoring System for Continuous Emissions (16).
                               4-5

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            5.0  STARTUP, SHUTDOWN, AND MALFUNCTIONS

     The Code of Federal Regulations, Title 40, Part 60, addresses
the problem of startup, shutdown, and malfunctions.  Section 60.11
(d) states, in part, "at all times, including periods of startup,
shutdown, and malfunction, owners and operators shall, to the ex-
tent practicable, maintain and operate any affected facility in-
cluding associated air pollution control equipment in a manner con-
sistent with good air pollution control practice for minimizing
emissions."
     The above provisions presently apply to basic oxygen process
furnaces.  State agencies may well adopt similar requirements and,
in fact, some states already require existing plant upset conditions
to be reported.  The principal difference, however, may be EPA's
definition of malfunction which exclude several common causes of
excessive emissions.  The wording is as follows:  "Malfunction means
any sudden and unavoidable failure of air pollution control equip-
ment or process equipment or of a process to operate in a normal or
usual manner.  Failures that are caused entirely or in part by poor
maintenance, careless operation, or any other preventable upset con-
dition or preventable equipment breakdown shall not be considered
malfunctions."

5.1  STARTUP
     Startup operations are common practice occurring daily or
even hourly, in the iron and steel industry.  Since basic oxygen
process furnaces are batch operations, startup of these furnaces
poses no particular problem from the emission point of view.  When
a furnace is being heated up, only fuel is being burned.
     Some irregularities in atmospheric emissions may occur during
the startup of a new vessel.  Most steel mills will have more than
one BOPF as part of their total steel production capacity.  Hence,
one vessel may sit idle for several hours.  When the scrap and hot
metal are added to a cold furnace, higher emissions are likely on
the first several heats of the new vessel.  This is probably due
to the additional oxygen required and additional blowing time re-
quired to get the steel to the proper temperature.  Performance
tests should not include any of these first several blows when a
new vessel goes on-line.

                                 5-1

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     Another startup condition that may affect air pollution  emis-
sions occurs when new refractory bricks have to be added  to the
vessel.  This occurs about once a week.  The bricks are replaced
while the vessel is hot.  Some additional particulate emissions
are likely to occur as a result of the new refractory material and
hence performance tests should not be made on the first heat  after
a relining has taken place.

5.2  SHUTDOWN

     Shutdown of the furnace can be more of a problem than startup,
however, since several tons of molten metal cannot be allowed to
solidify in the furnace.  In the event of a malfunction or failure in
the control equipment (precipitator or scrubber), the furnace must be
vented to the atmosphere for the remainder of the heat cycle  or until
the furnace can be prepared or stoked for holding.  It is not desir-
able to allow the firebrick to become completely cold since damage to
the firebrick may occur with frequent or extreme temperature  changes.

5.3  MALFUNCTIONS
     There are a few abnormal conditions relating  to  the  process
which can cause excessive emissions to the  atmosphere.  A marked
increase in the oxygen blow rate may cause  the  vessel  to  froth and
boil excessively.   This  additional  splashing  of the molten metal
causes additional emissions to the  atmosphere.   It  generally  occurs
during rapid production periods.  This abnormal condition can be
avoided by reducing the  Q£ blow rate.   The  addition of  magnesium
to the molten iron is supposed to reduce the  amount of  froth  and
slag in the vessel.   An  insufficient amount of  magnesium  may  cause
the froth conditions to  occur.

     Upset conditions also may occur with the air  pollution abate-
ment equipment.  A number of problems may arise with  an electro-
static precipitator.  The most serious with respect to  air pollution
emissions occurs when a section becomes dead  and inoperative.   Other
precipitator deficiencies might include insufficient  voltage,  excess-
ive spark rate, inadequate maintenance of the wrappers  and corrosion
of the ductwork in the precipitator lining.
     One of the easiest  parameters  to use in  assessing the performance
of a scrubber is the pressure drop  across the throat.   For this
industry, it has been shown that there exists a proportional rela-
tionship between scrubber pressure  drop and scrubber  efficiency.
However, certain upset conditions or malfunctions  can occur on
scrubbers.
                                 5-2

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     Any scaling or particulate build-up on the interior walls of
the scrubber system that would cause an uneven distribution of the
gas stream across the throat or on other critical portions of the
scrubber may cause an overall decrease in collection efficiency of
the unit.  For those gas streams having high grain loadings, a build-up
of mud will occasionally occur at the venturi throat.  This mud build-
up will cause a poor distribution of water at the throat and result
in decreased efficiency.  Some venturi systems have special gauges
that monitor the pressure at each spray nozzle at the venturi throat.

     Most venturi units will also have a mist eliminator to con-
serve on the water addition.  The mist eliminator should be observed
for mud build-up.  Generally, the fans are located after the mist
eliminator on the clean stream of exhaust gas prior to the stack.
Because of the existence of water and some particulate matter in the
exhaust stream, mud may also form on the blades of the fan causing
excess vibration and imbalance.  These conditions may ultimately
cause the scrubber components to fail.

     The task of minimizing emissions to the atmosphere is one of
maintaining the air pollution abatement system.  Those steel mills
which utilize a routine maintenance system on electrostatic pre-
cipitators, scrubbers and the process equipment are certain to min-
imize emissions that would otherwise be caused by malfunctions or
upsets.  The plant philosophy of maintenance on production equip-
ment should also apply to maintenance on air pollution control
equipment.  In the case of the basic oxygen process furnace, oper-
ators are usually forced to maintain their abatement equipment since
it is a strategic part of the BOPF process.

     Concentrating then on malfunctions that could cause excessive
emissions, two types of malfunctions may be considered.  The first
category is made up of those conditions which would create exces-
sive emissions into the workspace with subsequent discharge through
the roof monitors to the atmosphere.  Such a condition would very
likely be manifested by insufficient draft on the collection hoods
which could be due to:

     (1)  slippage on fan belts

     (2)  excessive pressure drop across the precipitator
          or scrubber

     (3)  fan rotating in the wrong direction

     (4)  leaking ductwork, access doors, explosion doors
          or discharge valve on air lock
                                  5-3

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     (5)  clogged ductwork or faulty damper

     (6)  duct size improper

     (7)  high temperatures and increased volumes of the
          exhaust gases

     The second category of malfunctions could result from control
equipment failures.  The more important examples would include:

     (1)  motor failure

     (2)  fan unbalanced due to particulate build-up

     (3)  pump failure

     (4)  clogged or worn nozzles

     (5)  poor water distribution due to build-up of
          scale

     (6)  broken discharge wires

     (7)  excessive electrical arcing

     (8)  faulty rappers

     (9)  air circulation in the collection hopper
                                  5-4

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                   6.0  INSPECTION PROCEDURES

     Generally speaking, emission rates from a BOPF installation
will depend on the operating condition of the control device.
Before an inspector visits a plant, he should obtain information ,
relative to the  type of control equipment and process capacities
utilized including feed rates and production rates from performance
test and design  data.  This background data and performance test
data will establish the operating history for this particular BOPF
shop.  Most steel plants will, in fact, have more than one vessel
that is capable  of. producing steel and operating simultaneously.
It is important  that the inspector check the design data, plant
capacity, and ductwork to assure that the abatement equipment is
capable of handling one or more vessels running simultaneously.
For a plant which has a number of vessels and several different
control units, operators will frequently connect the ductwork so
that vessels and control devices are interchangeable.  This design
feature is desirable from the production viewpoint but during high
production periods with two or more vessels operating simultaneous-
ly, emission loadings and gas flow rates may exceed the capacity of
the abatement unit.

     Visual emission observations should be coordinated with roof
observations and control room process sequencing.  For example, two
or three people  on "walkie-talkie" radios  may be required to identi-
fy the process and the capture efficiency of the hood at the time
of visual emission observations.  The visual emissions survey would be
conducted to determine compliance with applicable SIP requirements
since there are no visual emission limits under the NSPS requirements
for BOPF's.

     The inspector should observe at least one complete heat cycle
from tap to tap during his visit.   Certain types of operational
data with respect to the process equipment and emission control
equipment should be recorded on the inspector's worksheet.   These
include the operator's daily logs for each of the vessels,  and a
flow diagram of  the plant's steelmaking process.   Examples are
shown at the end of Section 7.0.   The inspector should examine
previous records for other heats to diagnose whether current oper-
ations are normal or abnormal.   Changes in the parameters mentioned
above will alter emissions to the atmosphere.

                                 6-1

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     The inspector should make a visual inspection from the floor
of the BOPF shop of the adequacy of the collection system.  For
movable type hoods, it is necessary that the hood come in close
proximity to the mouth of the vessel for effective capture of the
particulate matter.  Otherwise, dense smoke may emanate from the
vessel and escape the hood, especially during the first part of
the blow.  The enforcement official should check for a build-up
of slag on the lip of the vessel when the unit is turned down.

     A check should be made to determine whether or not the inspir-
ation flow rate is adequate during this inspection visit.  If the
plume escapes the hood it may be an indication that the collection
system/fan is not operating properly or there is a leak in the
ductwork.

     Certain types of continuous recorded data will be available
to ascertain the operating condition of the control equipment.  It
is not only important that the control equipment be operating cor-
rectly during the inspector's visit, but operating continuously.
From any continuous recording charts, the inspector will be in a
position to note factors like variations in pressure drop and opacity
and ascertain whether or not this BOPF installation has been complying
with emission regulations on a continuous basis.  The inspector should
also inquire about the maintenance program and the maintenance records
for the air pollution control devices.

6.1  CONDUCT OF INSPECTION
     Before an air pollution inspector visits a facility, it is
necessary to establish the objectives of the inspection.  In this
regard, he may wish to check with his administrative, legal, or
engineering advisors prior to the inspection since some or all of
the following objectives may be important for a given plant inspection,

     (1)  Determine the scope of the facility's operation.

     (2)  Determine the applicability of standards.

     (3)  Inspect records and/or monitoring equipment.

     (4)  Evaluate visible emissions.

     (5)  Determine if a stack test is required.

     (6)  Conduct or observe stack tests or other field tests.

     (7)  Evaluate maintenance and operation of equipment.

     (8)  Establish compliance or non-compliance with
          compliance schedules.

                                  6-2

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     (9)  Investigate feasibility of various control methods.

    (10)  Investigate compliance with emergency episode plans.

     Section 114(a)(2) of the Clean Air Act enables the Administrator
or his authorized representative to enter a source so that EPA can do
its own monitoring, sampling, inspecting, or copying of records.  Such
authority may be delegated to a state and be exercised by a state
official.

     In preparing for the inspection, «:he control official should:

     (1)  Review the literature on the subject industry's
          process descriptions, inspection points, and
          control equipment;

     (2)  Review the NEDS file or other plant file for
          details of processes and control equipment in
          use including plot plan;

     (3)  Review applicable standards (Federal, state and
          local);

     (4)  Review enforcement history on the plant;

          - administrative and court actions

          - compliance schedules
          - monitoring and recordkeeping requirements

          - previous inspections
          - section 115 abatement actions
          - waivers, notifications, quarterly reports,
            registration (NSPS and NESHAPS)

     (5)  Finalize objectives;

     (6)  If appropriate provide advance notice;

     (7)  Obtain credentials and business cards (EPA has
          a procedure regarding the issuance and control
          of credentials);

     (8)  If desired, obtain for handout a supply of
          applicable statutes and regulatory authority
          as well as EPA or state literature explaining
          the enforcement program;
                               6-3

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     (9)  Obtain or develop a supply of inspection checklists;

    (10)  Obtain personal safety equipment.   (A source owner
          or operator has no responsibility to supply EPA
          inspectors with safety equipment.)

          - fire retardant coveralls

          - hard hat
          - safety glasses or goggles

          - steel-toed shoes
          - respirator

          - gloves
          - overalls

    (11)  Obtain necessary inspection equipment

          - tape measure

          - flashlight

          - thermometer and gauge

          - manometer (flex-tube)

          - inclined manometer

          - RPM indicator
          - velometer

          - camera
          - Fyrite combustion analyzer- 02,  CO, C02

          - smoke spot analyzer

6.2  INSPECTION CHECKLIST

     After preparing for the inspection by reading appropriate
information and obtaining necessary equipment, the control official
is ready for the actual site visit.  Before entering the plant pro-
perty it is desirable to observe the stacks and roof monitors for
evidence of visible emissions.  If a plume is consistently visible,
opacity observations should be recorded for possible violation.
Time should be allowed for such observations prior to the appoint-
ment.

     At the plant entrance, present credentials and request to see
the most senior or responsible official of the company.   Generally
this person will be the plant manager.   The inspector should not
sign the waiver forms or "visitor releases."  The inspector has
specific legal authority (Federal or state)  for right of entry and
signing such forms may adversely affect his Federal or state

                               6-4

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insurance or survivors benefits.  If a source persists in its
refusal, the matter should be carried "to court.  If a source
simply refuses right of entry; a request must be made through a
U.S. attorney for a search warrant.

     Upon meeting the responsible plant official, the inspector
may be questioned on the following items and should be prepared
to discuss:

     (1)  The purpose of the inspection (NSPS, SIP, NESHAPS);

     (2)  The authority for the inspection (113, 114, State law,
          etc.);

     (3)  The agency's organization and responsibilities;

     (4)  Recent history of legislative and enforcement
          activity affecting the subject industry and
          specific plant;

     (5)  The scope, timing, and organization of the
          inspection;

     (6)  Information and records to be examined (self-
          incrimination - see Appendix C);

     (7)  The treatment of confidential data (trade
          secrets - see Appendix C);

     (8)  Possible measurements to be made;

     (9)  Possible follow-up activity regarding:

          - future inspections

          - section 113 or 114 letter
          - stack tests

          - notice of violation.

     After the preliminaries are completed, the inspector should
request the name, title and address of the most appropriate company
officer for official correspondence and for contact on future
inspections.

     Next, he should request a brief summary of the plant's pro-
duction facilities and air pollution control equipment.  This
information will substantiate the NEDS or other emission source
data that the agency has on file or will provide the basis for up-
dating or correcting such files.

                               6-5

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     The company official should be asked to indicate which pro-
cesses, unit operations, furnaces, and control equipment are (at
the time of the discussion) operating at or near normal operating
conditions.  Likewise, the company official should be asked to
indicate which facilities are not operating at or near normal oper-
ating conditions and to indicate the reasons and the timing (date
and hour) for shutdown or malfunctioning equipment.  The schedule
for returning shutdown equipment to operation should be indicated.
The malfunctioning equipment should be shutdown if such malfunc-
tioning adversely affects emission rates to the atmosphere and the
schedule for shutdown and correction should be indicated.

     Next, the inspector should request a quick rather cursory tour
of the plant facilities and the company official should point out
all of the sources and control equipment indicated earlier.  Access
to the roof and to the stacks should be requested and visual obser-
vations should be made of hood capture efficiencies, stack effluents,
sampling ports and platforms, ductwork conditions,  and general house-
keeping in and around the plant.  However, the inspector should be
aware  that the upper levels and roof area of the BOPF shop itself are
extremely hazardous during operation and access is not recommended.
Evidence of dust or fume accumulation on the plant  roof or at the
stack  exit should be noted where safe access can be obtained.  During
this tour the inspector should note whether the process, furnace, etc.
is running and whether its operation warrants more  detailed analysis.

     After getting  acquainted with  the  plant and  its  facilities,
 the  inspector  should  request  that  the  company official provide
 information  from  his  records  that will  allow  the  inspector to com-
 plete  the  process,  control  equipment and malfunction  record forms
which  are  appended.   Records  for  the complete calendar month prior
 to the visit will generally suffice  to  give a baseline of  the
 plant's operations.  With  such  information, comparisons can be
made with  future  operations, with  past  performance test and.design
 operating  conditions,  and with  operations  at  the  time of  the current
 inspection.   In the event  the company  identified  certain  data as
 confidential,  a company official must make a request  for  such con-
 fidentiality  in writing  to  EPA.

     Next,  the control  official  should  request  the company official's
 assistance  in  verifying  the real-time  operating conditions and  actual
 production rate of  each  process,  furnace,  etc.  in the plant.  This
 plant  inspection may  take  several hours and the records or data which
 the official  cites—weights,  fuel  flow measurements,  temperatures,
 etc.--should be seen  and verified by  the air pollution inspector.
 After  verifying that  certain  equipment  is  operating,  the  inspector
 should be  prepared  to  take  his  own  data on fan  speeds, gas* velocity
 and  duct  flow  rates,  static  pressure,  pressure  drops, hood capture
 velocities,  and temperatures  (both  dry  bulb and wet bulb).  On

                                 6-6

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equipment that-is not operating, especially control equipment, the
opportunity should be taken to open access doors to check ductwork,
clean-air plenum, valves and dampers, fan drive belts, collection
hoppers, etc.  The inspector should take note of those conditions
given in section 5.0 which can lead to malfunctions and check the
equipment accordingly.

6.3  INSPECTION FOLLOW-UP PROCEDURES

     Upon completion of the inspection, the inspector should sign
and date all notes and inspection forms making certain that all
blanks are completed.  He should advise the company officials that
he will review his findings with his legal and technical advisors
prior to making recommendations for any necessary action.  The
inspector should not advise the company official of specific vio-
lations.  The conclusion of all inspections will be:  (1) affected
facilities are in violation of standards; (2) affected facilities
are in compliance with standards; or (3) affected facilities are
not being operated or maintained precisely in accordance with the
performance  tests but violations are not clearly evident.  Where oper-
ating conditions have a high probability of producing greater emissions
than those recorded during the performance tests, a new performance test
may" be required of the source by the Administrator   Also, poor main-
tenance and housekeeping is a violation of NSPS regulation 60.11(d).
     In the first case for basic oxygen process furnaces subject
to the NSPS, the only violations which could be cited at the pre-
sent time under Section 113 are particulate matter or failure to
record or report malfunctions.
     In the  second case, the plant will be found to be operating
and maintaining its facilities in a manner consistent with good
air pollution control practice for minimizing emissions.  Also
the affected facilities will be found to be operating essentially
at the production rates and under the conditions recorded at the
time of the  performance tests.
     In the  third case, which will be the most common and the most
difficult, inspections will be concluded with a need for recom-
mendations to improve specific operating or maintenance procedures
so as to be  consistent with the performance test conditions and
with good air pollution control practice for minimizing emissions.
If such recommendations are not followed and the inspector feels
that emissions may be excessive, a performance test would be re-
quired to substantiate or refute compliance with the regulations.
On the matter of what conditions constitute a significant deviation
so as to require a new performance test, the inspector should not
make a decision  in the field.  Instead, he should record field
data from which  technical and legal advisors can draw such a con-
clusion.

                                   6-7

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     Regardless of the findings, the designated company officer
should be notified in writing of the inspection results and any
required action on the company's part should be spelled out in
detail with a time schedule to bring the facilities back into
compliance.  Section 113 of the Act should be cited.  At the con-
clusion of the designated time period for compliance, a follow-up
inspection should be made to verify conformance with the recom-
mendations and applicable standards.
     For further information on inspection procedures refer to:
     - Field Surveillance and Enforcement Guide for
       Primary Metallurgical Industries  (15)

     - Workshop on Stationary Source  Inspections (21)

     - Air Pollution Control Field  Operations  Manual (19)

     - S12. - General Policy on the Use  of Section 114
       Authority for Enforcement Purposes (Appendix C)

     - Emission Testing Compliance  Manual (11)
                                  6-8

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                      Table 6.1   BASIC OXYGEN PROCESS FURNACE INSPECTORS WORKSHEET

                                             Part I  - Process  Data

                      	                                            FROM:                TO:
                      Company
                                     Dates  Covered
                  Street Address
           City
State
             Official Completing Form
                Title of Official
                                     Furnace - Company Designation
Furnace Identification No.  or NEDS No.
                                     Furnace Type
                                     Furnace Rated Capacity
Heat
Number










H
Charge
m

-








EAT PERIOE
Refine
m










Pour
m










Total
m










RAW MATERI
Pig
Iron
tons










ALS
Iron
Scrap
tons










Oxygen
ft3










SPECIF
Fe










PRODUCTIO
ICATION -
C










N
PER CENT
Other

•
a

"-
V
< —
-


I
VO
                                                                  date
                                                         Inspector

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                      Table 6.2  BASIC OXYGEN PROCESS FURNACE INSPECTORS WORKSHEET

                                      Part II  - Control Equipment  Data
                                                                         FROM:
                       Company
                                                                                TO:
                                                              Dates Covered
                   Street Address
                                                              Control Equipment  Co.  Designation
              City
                       State
          State Permit  Number  or NEDS Number
           Official Providing Information
                                                              Control Equipment Type
              Title of Official
           Process equipment ducted to this  control equipment
ON
 I
                                                  _tons
                                                  _acfm
                                                  _acfm
                                                  OF
                                                  rpm
Quantity of dust collected       	
Gas flow rate @ collector inlet  	
Gas flow rate @ collector outlet 	
Temperature @ collector  inlet    	
Temperature @ collector  outlet   	
Fan Speed                       	
Capture velocity of hood over
  furnace                       	
Precipitator
       spark rate               	
       primary voltage          	
       primary amps             	

Remarks concerning inspections, maintenance and repairs
                                                  fpm
                                                  _spm
                                                  _volts
                                                  _amps
Static pressure in collection  system
       stack
       before fan
       collector outlet
       collector inlet
       before coolers
       duct after  hood

Scrubber
       pressure drop
       water flow  rate
                                "H20
                                _"H20
                                _"H20
                                _"H20
                                                                                               _"H20
                                _"H2°
                                _gpm
                                                                  date
                                                                              Inspector

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             Table 6.3  BASIC OXYGEN  PROCESS  FURNACE INSPECTORS WORKSHEET
                      Part III - Startup, Shutdown,  and Malfunction
                                                               FROM:            TO:
            Company                                            Dates Covered
         Street Address
   City                State

  Official Providing Information

     Title of Official
Excess emissions occurred                     Were excess emissions due to startup,  shutdown, or mal-
                                             function                                          '
     Began_
            date               time           Describe  the magnitude of the excess emissions
     Ended   -                                 	
            date               time
Detailed explanation of reasons for  excess emissions
Corrective action taken to halt excess emissions
Preventative measures adopted to prevent recurrence
Further comments
                                                             date              Inspector

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                            Table 6.4  BASIC  OXYGEN  PROCESS  FURNACE  INSPECTORS WORKSHEET

                                                       Part IV -  General  Observations
                                                                          FROM:              TO:
                         Company                                           Dates Covered
                     Street Address
               City                 State



            Official Providing  Information



                   Tital of Official


            Process

                 Charging procedures - weights, frequency
 I                Charge quality - percent  scrap and percent pig iron_
(-•
M
                 Capture efficiency of hoods
            Control Equipment


                 Cleaning cycle__
                 Structural integrity^


                 Ductwork condition
                 Testing facilities
            Emissions


                 Visible emissions from stack Method 9
                 Visible emissions around  hoods Method  9
                                                                                            Inspector

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                       7.0  PERFORMANCE TEST

     The Code of Federal Regulations, Title 40, Part 60 provides in
Section 60.8 for performance tests of new basic oxygen process fur-
naces.  The test calls for three separate runs using standard EPA
test methods and procedures.  The Administrator, however, can modi-
fy the testing requirement; he can even waive it.  If tests are to
be conducted, the owner or o'perator must give EPA 30 days notice.
EPA must then specify the operating conditions of the tested fur-
nace.  At the time of the test, the inspector should be present to
observe process and control device operation so that subsequent
inspections can be correlated with the performance test "baseline"
operating conditions.  Also at the time of the tests, the inspector
should check certain of the source testing procedures to
ensure that the tests are conducted properly.  Each of these three
requirements is considered separately in the ensuing discussion.

7.1  PROCESS OPERATING CONDITIONS

     The purpose of the performance test is to determine whether
the emission standards will be met when the furnace is operating
at normally encountered conditions that create the maximum emis-
sion rate.  The operating conditions that should be specified for
the tests are as follows:

     (1)  The production rate should be the maximum rated capacity
          of the furnace;

     (2)  The period of the heat should be the minimum possible to
          achieve the specification of the melt;

     (3)  The specification of the steel to be produced should be
          typical of the product produced by the affected facility
          to be tested;

     (4)  The consumption rate for oxygen should be the maximum
          rate anticipated;

     (5)  The fuel consumption rate, if any, should be the maximum
          rate anticipated;
                                7-1

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     (6)   The flux addition rate should provide a slag and flux
          cover depth typical of the operation to be tested; and,

     (7)   The pouring temperature should be the maximum anticipated
          for the steel being produced.

7.2  PROCESS OBSERVATIONS
     There are several subjective type observations which need to
be made during the performance test.  For the closed or movable
hood systems, it is important that the hood come in very close
proximity to the converter mouth.  Sometimes a build-up of slag on
the converter lip may prevent the hood from fitting snugly over the
vessel.  During the performance tests, an observation and description
should be made of the movable hood and its relationship to the amount
of slag on the lip and how well it fits over the vessel.
     Another observation that can be made which will affect air
pollution emissions and establish the manner in which steel is pro-
duced at  this shop is the amount of slag or froth which overflows
during the oxygen-blowing period.  If the slag "boils over" and is
emitted from the mouth of the converter during the oxygen blow
period, it may indicate an abnormal heat or one made in haste.  Data
taken during the performance test should also indicate the number of
reblows that have taken place for each heat.

     Changes in the above mentioned data taken during the performance
tests are likely to change air pollution emissions from the BOPF.
Increase  in particulate emissions from the BOPF will likely result
from an increase in the amount of hot metal, scrap, spark rate, pri-
mary voltage, and the temperature at the inlet to the abatement
device.  An increase in air pollution emissions also will result
from a decrease in the oxygen-blowing period, cycle time, pressure
drop, and water flow rate.  The converse of these situations is
also true.

     The  total charge or the total production rate will affect
emissions.  Since most of the emissions are due to oxidation, a
furnace half full will have only one-half the mass rate of emission
of iron oxide.  Yet the oxygen consumption rate and certainly the
air delivered to the precipitators and scrubbers will be nearly the
same in both cases; thus, the grain loading will be reduced if the
production is reduced.

     The  duration of the heat is important in that the quantity of
impurities to be removed from scrap remains constant regardless of
the duration of the heat.  There is effective dilution and lowering
of the grain loading with longer than normal refining times.
     The  approximate iron and steel content of the scrap which is
charged should be noted.  If the charge is high in impurities and

                               7-2

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the final product is very low in impurities, then more refining
will be necessary to remove impurities and most of this material
will go to the control equipment.

     The oxygen consumption rate relates to the speed with which
the impurities in the molten metal are removed.  If the rates are
low and the time longer, emission rates will be less than if the
rates are high and the time shorter.  If the source test is con-
ducted for only one hour or so, care should be exercised to include
representative oxygen blowing conditions.

     The thickness of the slag cover may be important since the
slag cover reduces the loss of steel due to oxidation.

     If the pouring temperature is higher than necessary, the fume
emission will be increased.

7.3  EMISSION TEST OBSERVATIONS

     Certain operational parameters should be recorded during a
performance test that are critical for future plant visits by the
federal enforcement official to establish what changes in the
operating parameters have taken place that would affect the pol-
lution emissions to the atmosphere.
     The standards of performance for the basic oxygen process
furnace are applicable only to a certain portion of the heat.
40 FR 60.144(b) requires that the Method 5 tests be conducted for
an integral number of cycles; a cycle shall start at the beginning
of either the scrap preheat or the oxygen blow and shall terminate
immediately prior to tapping.  Sampling shall be conducted for a
minimum total duration of 60 minutes with a sampling rate of at least
0.9 dscm/hr (0.53 dscf/min).

     Emission tests and opacity determinations should be conducted
by qualified emission testing personnel.  The inspector is respon-
sible for ensuring that all pertinent data are collected, that the
field procedures and equipment meets CFR, and that the BOPF is run
at representative performance during all sampling runs.  A qualified
technician or engineer reads visible emissions during the three
particulate runs.  The approved visible emission observation data
form appears in Appendix B.
     The inspector's degree of surveillance of the stack sampling
team depends on the confidence of  the inspector and qualifications
of the test personnel.  Even if the inspector has complete trust
in the sampling crew, the  following tasks should always be per-
formed :

     (1)   Record duct dimensions (both inside and outside)  and
          locations of sample ports,
                                7-3

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(.2)  Check the number of ports at the sampling site and
     examine the ducting for the nearest upstream and down-
     stream obstructions.  Ask the crew leader how many total
     points will be traversed and check with Figure 1.1 in
     40 CFR 60 (Method 1) to determine whether the stream will
     be properly sampled.

(3)  Note whether the crew runs a preliminary traverse, and if
     so, inquire what nozzle diameter is selected.  Nozzle
     diameter should be measured with a micrometer to verify
     indicated size.  (.Isokinetic sampling is a function of
     nozzle size.)

(4)  Check to ensure that the moisture content of the gas
     stream is determined by Method 4 or an equivalent method
     such as drying tubes or volumetric condensers; assumption
     of the moisture content is not allowed.  Note, however, that
     EPA has proposed a method for the estimation of the moisture
     content for the purpose of determining isokinetic sampling
     rate settings.  The proposed method appears at 41 FR 23060
     (June 8, 1976).

(.5)   Observe  the  leak  test  of  the  sampling  train.  The allow-
     able  leak  rate is  given  in Method  5.   Leakage results  in
     lower  concentrations than are actually present.  Be next
     to the  dry gas meter during  the  leak check,  note whether
     the meter  hand is moving.   (The  more the hand is moving,
     the greater  the leakage.)  Leak  checks must  be made if
     the train  is disassembled during the run  to  change a
     filter  or  to replace any  component.

(6)   Record  dry gas meter reading before and after test.

(7)   Record  average velocity head  and temperatures in duct
     during  test.

(_8)   If impingers are  used  during  test,  observe whether they
     are bubbling.   If  they are not,  the sampling train is
     either  plugged or  disconnected from the pump.

(9)   Check  the  cleaning  procedure  for the front half of the
     train.   Careless  removal  of  filters or cleaning of
     probes  will  result  in  lower  calculated emissions.  Look
     for broken glass  from  probes  or  connectors.  Test is
     void  if glass  probe is broken during test.   If glass
     connectors are broken  in  transport  from sampling site
     to cleanup area,  test  is  still valid.   Be sure identifi-
     cation  labels  are  properly attached to collection

                         7-4

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          containers,  The probe should be brushed and rinsed with
          acetone thoroughly to remove all particulates.  The
          probe should be visually inspected after cleaning to as-
          certain that all particulates have been removed.

    (.10)  Observe gas analysis procedure for determining CC>2.
          Technician should take at least three samples before
          averaging readings.  Variations greater than 0.5 per cent
          (grab sample) or 0.2 per cent (integrated sample) indicate
          gas mixture was not thoroughly bubbled in reagents.  Ask
          technician or crew leader when new reagents were added
          to apparatus.

    (11)  Check per cent isokinetic.

    (12)  Inquire about the calibration history of the flow volume
          recorder.  The flow measuring device is required to main-
          tain an accurate of + 5 per cent over its operating range.
7.4  PERFORMANCE TEST DATA
     The inspector must observe furnace operation and emission tests
simultaneously to ensure that valid data are used in determining
plant performance.  The performance test checklist shown in Table 7.1
is based upon the observations described in Sections 7.1, 7.2 and
7.3.  Suggested contents for stack test reports are given in
Appendix E.
     The reasons for having the inspector observe the test and
complete the inspection sheet are twofold.  First, furnace and con-
trol device parameters will serve as guidelines for future NSPS
recordkeeping requirements; and second, the inspector's observation
of a few major parameters ensures that the tests were properly con-
ducted.
     The emission-testing firm is required to submit test reports
to the facility and the control agency.  Results from the testing
firm must be carefully checked and compared with data from the
inspector's form.
                               7-5

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                             Table 7.1
    NSPS INSPECTION CHECKLIST FOR BASIC OXYGEN PROCESS FURNACE
                      DURING PERFORMANCE TEST
Facility Name	
Facility Address
Name of Plant Contact
Source Code Number
Unit Identification (To be tested)
Design Input Capacity 	tons/day
Initial Start-up Date 	
Test Date
A. FACILITY DATA
   Type               Furnace             No. of Furnaces
                                          Specify 	
   Charging Method    Batch      Continuous
   Control Devices    Precipitator        Specify Type
                      Scrubber            Specify Type 	
                      Other
Operating Schedule 	hrs/day 	days/wk 	wks/yr
B. OPERATING PARAMETERS
   Data to Obtain During Performance Test3
	Parameter	^^^_^
Charge Capacity
Charge Rate
Period of Heat
Oxygen Rate
Pouring Temperature
a
 Data should be recorded for every heat.
                                7-6

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    Table 7.1 (continued).  NSPS INSPECTION CHECKLIST FOR BASIC

          OXYGEN PROCESS FURNACE DURING PERFORMANCE TEST


C.  PRETEST DATA (OBTAIN FROM TEST TEAM FIELD LEADER)

    Test Company ^	

    Field Leader 	
                                                                  2
    Duct Dimensions 	in. x 	in. ;  Area 	ft

    Nearest Upstream Obstruction 	ft

    Nearest Downstream Obstruction 	ft

    No. of Sampling Ports 	

    No. of Sampling Points 	

    No. of Sampling Points Required From 40 CFR 60 	

D.  PARTICULATE PERFORMANCE TEST

    Test No.          Start Time         Finish Time
                                                Yes      No
    Preliminary Traverse Run (Method 1)
    Chosen Nozzle Diameter 	in.

    Train Leak Check

    Opacity Readings Taken

    Moisture Determination (Method 4)
    Per cent Moisture
                                                    3
    ml Collected/Gas Volume 	ml 	ft
      (or wet/dry bulb readings)

    Combustion Gas Analyzer      02 	%
                                CO, 	%
                                                 3
    Dry Gas Meter Reading Before Test 	ft  at 	(time)
                                                 3
    Dry Gas Meter Reading After Test  	ft  at 	(time)

        Volume Sampled	ft
                                7-7

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    Table 7.1 (continued).  NSPS INSPECTION CHECKLIST FOR BASIC
          OXYGEN FURNACES DURING PERFORMANCE TEST
D.  PARTICULATE PERFORMANCE TEST (continued)
    Test Duration 	minutes
    Average Meter Orifice Pressure Drop 	
    Average Duct Temperature
    Velocity Head at Sampling Point
    Meter  H
    Repetition Start Time
    Repetition Finish Time
E.  CLEAN-UP PROCEDURE
    Filter Condition
    Probe Status
    Glass Connectors
    Clean-up Sample Spillage
                               Dry
                               Unbroken
                               Unbroken
                               None
Sample Bottle Identification   Yes
Acetone Blank Taken            Yes
                                               inches
                                               inches
         Wet
         Broken
         Broken
Slight   Major
         No
         No
                                7-8

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                           8.0  REFERENCES

 (1)   "A Manual of Electrostatic Precipitator Technology,  Part I."
      National Air Pollution Control Administration,  Durham,  N.C.
      (1970)

 (2)   "A Systems Study of the Integrated Iron and Steel Industry."
      National Air Pollution Control Administration,  Durham,  N.C.
      (1970)

 (3)   "Air Pollution Aspects of the Iron and Steel Industry."  U.S.
      Department of Health, Education and Welfare, Cincinnati,
      Ohio (1963)

 (4)   "Air Pollution Engineering Manual."  U.S.  Department of
      Health,  Education and Welfare, Cincinnati, Ohio (1967)

 (5)   "Air Pollution Manual, Part II, Control Equipment."   American
      Industrial Hygiene Association, Detroit, Michigan (1968)

 (6)   Allen,  Glen L. "Control of Metallurgical and Mineral Dusts
      and Fumes in Los Angeles County, California," U.S. Department
      of the  Interior- Washington, D.C.  (April 1952)

 (7)   Background Information for Proposed New Source  Performance
      Standards;  Vol. 1, Main Text.  Environmental Protection
      Agency,  Research Triangle Park, N.C. (June 1973)

 (.8)   Calvert, S. "Systems Study of Scrubbers,"   Environmental
      Protection Agency, Research Triangle Park, N.C.  (1972)

 (_9)   Federal Register, Vol. 40, No. 242.  General Services
      Administration, Washington, D.C. (December 16,  1975)

(10)   "Control Techniques for Particulate Air Pollutants," U.S.
      Department of Health, Education and Welfare, Washington, D.C.
      (January 1969)
                                8-1

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(11)  Emission Testing Compliance Manual, EPA 68-02-0237.  Environ-
     mental Protection Agency,  Washington,  B.C.  (1974)

(12)  Federal Register, Vol.  39, No,  177.   General Services
     Administration,  Washington, D.C.  (September 11, 1974)

(13)  Federal Register, Vol.  39, No.  200.  General Services
     Administration,  Washington, D.C.  (October 15,  1974)

(14)  Federal Register, Vol.  40, No.  194,   General Services
     Administration,  Washington, D.C.  (October 6, 1975)

(15)  Field Surveillance and Enforcement Guide for Primary Metal-
     lurgical Industries.   Engineering-Science,  Inc.,  Washington,
     D.C. (December 1973)

(16)  Guideline for the Selection and Operation of a Continuous
     Monitoring System for Continuous Emissions.  Division of
     Stationary Source Enforcement,  Environmental Protection
     Agency- Washington, D.C. (1974)

(17)  Hayward, C.R., "An Outline of Metallurgical Practice," D. Van
     Nostrand Company, N.Y.  (1952)

(18)  Stern, A.C., "Air Pollution, Volume III, Sources  of Air
     Pollution and Their Control," Academic Press,  N.Y. (1968)

(19)  Weisburd, Melvin I.,  "Air Pollution Control Field Operations
     Manual," U.S. Department of Health,  Education and Welfare,
     Washington, D.C. (December 1962)

(20)  "Wet Scrubber System Study."  Environmental Protection Agency,
     Durham, N.C. (1972)

(21)  Workshop on Stationary Source Enforcement,  Engineering-
     Science, Inc., Washington, D.C. (December 1974)

(22)  Zavier, J.A. "Survey of Air Pollution from the Kaiser Steel
     Plant," State of California Air Resources Board,  Sacramento,
     California  (1971)

(23)  Code of Federal Regulations, Title 40, Part 51 Revised as of
     July 1, 1976, General Services Administration, Washington, D.C.
     (1976)
                                8-2

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           APPENDIX A

STANDARDS OF PERFORMANCE FOR NEW
       STATIONARY SOURCES
               A-l

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           Chapter 1 - Environmental Protection Agency

                   SUBCHAPTER C - AIR PROGRAMS

              PART 60 - STANDARDS OF PERFORMANCE
                  FOR NEW  STATIONARY SOURCES

             Subpart N - Standards of performance  for
                      Iron and Steel Plants



§60.140  Applicability and  designation of affected facility.

     The affected facility  to which the provisions of this subpart
apply is each basic oxygen  process furnace.

§60.141  Definitions.

     As used in this  subpart, all terms not defined herein shall
have the meaning given them in the Act  and in subpart A of this
part.
     (a)  "Basic oxygen process  furnace" (BOPF)  means any furnace
producing steel by charging scrap steel, hot metal, and flux
materials into a vessel and introducing a high volume of an oxygen-
rich gas.
     (b)  "Steel production cycle" means the operations required
to produce each batch of steel and includes the  following major
functions:  scrap charging, preheating  (when used), hot metal
charging, primary oxygen blowing,  additional oxygen blowing (when
used), and tapping.

§60.142  Standard for particulate matter.

     (a)  On and after the  date  on which the performance test
required to be conducted by §60.8 is  completed,  no owner or operator
subject to the provisions of this subpart shall discharge or cause
the discharge into the atmosphere from any affected facility any
gases which:
     (1) contain particulate matter in excess of 50 mg/dscm (0.022
gr/dscf).
     (2)  (Reserved.)

§60.143  (Reserved)
                               A-2

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§60.144  Test methods and procedures.

     (a)  The reference methods appended to this part, except as
provided for in §60.8(b), shall be used to determine compliance
with the standards prescribed in §60.142 as follows:
     (1)  Method 5 for concentration of particulate matter and
associated moisture content,
     (2)  Method 1 for sample and velocity traverses,
     (3)  Method 2 for volumetric flow rate,  and
     (4)  Method 3 for gas analysis.
     (b)  For Method 5, the sampling for each run shall continue
for an integral number of cycles with total duration of at least
60 minutes.  The sampling rate shall be at least 0.9 dscm/hr (0.53
dscf/min) except that shorter sampling times, when necessitated by
process variables or other factors, may be approved by the
Administrator.  A cycle shall start at the beginning of either the
scrap preheat or the oxygen blow and shall terminate immediately
prior to tapping.
                                A-3

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                 APPENDIX B

   METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FOR STATIONARY SOURCES
                  B-l

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                      METHOD  9  -  VISUAL  DETERMINATION OF  THE
                 OPACITY  OF EMISSIONS  FROM STATIONARY SOURCES
METHOD  9—VISUAL  DETZSMETATTON  OS1  TH3
  OPACITY OP E1HSSION3  7SOH  STATIONiaT
  301TSCE3 .

  Many stationary sources discharge visible
emissions Into the atmosphere;  these emis-
sions  are usually in the shape of a plume.
This method Involves the  determination of
plume opacity by qualified  observers.  The
methcd Includes procedures for the training
and certification of observers, and procedures
to be used In the field for determination of
plume opacity. The appearance of a plume as
viewed by an observer depends upon a num-
ber of variables, some of which may be con-
trollable  and some  of  which  may not be
controllable In the field. Variables which can
be controlled to an extent  to which they no
longer  exert  a  significant Influence  upon
plume appearance Include: Angle of the ob-
server with respect to the plume: angle of the
observer with respect to the sun;  point of
observation of attached and detached steam
plume: and angia of the observer  with re-
spect to a plume emitted from a rectangular
stack with a large length to width ratio. Tie
 method Includes specific criteria applicable
 to these variables.
   Other variables which may not be control-
lable In the field are luminescence and color
contrast between the plume and the  back-
ground against  which the plume Is viewed.
Thesa variables  exert an Influence upon the
appearance of a plume  as  viewed by an ob-
server,  and can  affect the  ability of the ob-
server  to accurately assign opacity  values
to tha observed plume. Studies of the theory
of plume opacity and field studies have dem-
onstrated that a plume  U most visible and
presents the  greatest apparent opacity when
viewed against a contrasting background. It
follows from this, and 13 confirmed by field
trials, that the  opacity  of a plume, viewed
under conditions where  a contrasting back-
ground Is present can be assigned  with the
greatest degree of accuracy. Howerer, the po-
tential for a positive error Is also the greatest
whan a plume Is viewed under such contrast--
Ing conditions. Under conditions presenting
a less contrasting background, tha apparent
opacity of a plume  Is less and approaches
zero as the color and luminescence contrast
decrease toward  sero. As  a result, significant
negative  bias and  negative errors can be
made when a plume is viewed under less
contrasting conditions.  A negative  bias de-
creases  rather than increases the possibility
that a plant operator will be cited for a vio-
lation of opacity standards due to  observer
error.
  Studies have been undertaken to determine
the magnitude of positive  errors which can
be made by qualified observers  while  read-
Ing plumes under contrasting conditions and
using  tha procedures   set  forth  In  this
method. The results of these studies  (field
trials) which  Involve a total of 769 sets of
25 readings each are  as follows:
   (1) For black plumes (133 sets at a smoke
generator),  100  percent  of the  seta  were
read with a. positive  error1 of less than  7.5
percent opacity;  99 percent were read with
a positive error of less than 5 percent opacity.
   (2) For white plumes (170 sets at a smoka
generator, 138 seta at a coal-fired power plant,
298 seta at a sulfurlc  acid plant), 99 percent;
of tha seta were read with a positive error of
less than. 7.5 percent opacity: 95 percent wera
read with a positive error of less than 9 per-
cent opacity.
  Tha positive observational error associated
with an average of twenty-five readings la
therefore  established. Tha accuracy of the
method must be taken into account  when
determining possible violations  of  appli-
cable opacity standards.
  1. Principle and applicability.
  1.1  Principle.  The  opacity of  emissions
from stationary sources  is  determined vis-
ually by a qualified observer.
  1.2  Applicability.  This method  Is appli-
cable for  the determination of the opacity
of emissions from  stationary sources  pur-
suant to  § 60.11 (b) and for qualifying ob-
servers for visually determining  opacity  of
emissions.
  2.  Procedures.  The observer qualified  In
accordance with paragraph 3 of this method
shall use  the following procedures  for vis-
ually determining the opacity of emissions:
  2.1  Position. The qualified observer shall
stand at a distance sufltclent  to  provide a
clear  view of the emissions with the sun
oriented in the 140* sector to his back. Con-
sistent with maintaining the above require-
ment, the observer shall, as much as possible,
make his  observations from a position such
that  hla  line  of vision 13 approximately
perpendicular to the plume direction, and
when observing  opacity of emissions from
rectangular  outlets  (e.g. roof monitors, open.
baghauses,  nonclrcular   stacks),  approxi-
mately  perpendicular to the longer axis  of
the outlet. The observer's line of sight should
not Include more than one  plume at a time
when multiple stacks are involved, and  In
any  case  tha observer should make his ob-
servations with his line of sight perpendicu-
lar to the longer axis  of such a set of multi-
ple stacks (e.g. stub  stacks  on baghouses).
  2-2 Field  records.  The  observer  shall re-
cord the came of tha plant, emission loca-
tion,  type  facility,  observer's  nami. and
affiliation, and the data on a field data sheet
(Figure 9-1). Tha time, estimated  distance
to the emission  location, approximate  wind
direction, estimated wind speed, description
of the sky condition  (presence and color of
clouds ).^nd pluma background'are recorded

  1 For  a set. positive error=average opacity
determined  by observers' 25 observations—
average opacity determined  from transaia-
someter's 25 recordings.
                                                 B-2

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on a field data sheet at the time opacity read-
ings axe initiated and completed.
  2.3  Observations.  Opacity  observations
shall be made at the point of greatest opacity
in that portion of the  plume  when con-
densed water vapor la not present. The ob-
server  «*a'l  not loot continuously at th»
plume, but Instead shall observe the pluma
momentarily at 15-second Intervals.
  2.3.1  Attached steam plumes. When con-
densed water vapor  Is present  within the
pluma as It emerges from the emission out-
let, opacity observations shall be made be-
yond th* point In the plume at which con-
densed water vapor Is no  longer visible. The
observer  shall  record the approximate dis-
tance from the amtMinn outlet  to the point
In the plume at which the observations are
made.
  2.3.2  Detached steam plume.  When water
vapor La the plume condenses and becomes
visible at a distinct distance from the emis-
sion outlet, the opacity of emissions should
be evaluated at the emission outlet prior to
the condensation of water vapor  and the for-
mation of the steam plume.
  2.4  Recording observations.  Opacity ob-
servations shall be recorded to the nearest 5
percent at  15-second intervals  on an ob-
servational record sheet. (See Figure 9-3 for
an example.) A minimum of 24  observations
shall be recorded. Each momentary observa-
tion recorded shall ba deemed  to represent
the  average  opacity of emissions for a 15-
second period.
  13  Data Seduction. Opacity «*>»" be de-
termined as an, average of  24  consecutive
observations recorded at 15-second intervals.
Divide the observations- recorded on the rec-
ord sheet into sets of 24 consecutive obser-
vations.  A set is  composed  of  any 24 con-
secutive observations. Sets need not be con-
secutive In  time and In no case «h«n two
sets overlap. For each set of 24  observations.
calculate the average  by summing the opacity
of the- 24 observations and dividing this sum
 by 24. If an applicable standard specifies an
 averaging time requiring more than 24 ob-
 servations, calculate  the average for all ob-
 servations made during the specified time
 period. Becord the average opacity on a record
.sheet. (S«e Figure 9-1 for an example.)
   3. Qualifications and testing.
   3.1  Certification requirements. To receive-
testification aa a qualified  observer, a ean-
•dldate must be tested and demonstrate the
•ability to assign opacity readings in 5 percent
 Increments to 23 different black plumes and
 2S  different white plumes, with an  error
 not to exceed 15 percent opacity on any one
 reading and an average  error not to exceed
 7.5 percent  opacity In each  category. Candi-
 dates shall  be tested according to the pro-
 cedures described In paragraph 3-2. Smolce
 generators used pursuant to paragraph 3.2
 shall be equipped  with a smoke meter which
 meets the requirements  of paragraph 3.3.
   The certification shall be  valid for a period
 of 8 months, at which time the qualification
 procedure must be repeated by any observer
  In order to retain certification.
  3.2  Certification procedure. The certifica-
tion test consists of showing the candidate a
complete run of 50 plumes—25 black plumes
and 25 white plumes—generated by a smoke
generator. Flumes within each set of 25 black
and 25 white runs shall be presented In ran-
dom order. The candidate assigns an opacity
value to each plums and records his obser-
vation on a suitable form. At the completion
of each run of 50  readings, the  score of the
candidate Is determined. If a candidate falls
to qualify, the complete run of 50 readings
must be repeated  In any retest. The smoke
test may be administered as part of a smoke
school or training program, and  may be pre-
ceded by training or familiarization runs of
the smoke generator during which candidates
are shown black and white plumes of known
opacity.
  3.3   Smoke generator specifications. Any
smoke gsneratcr used  for the  purposes  of
paragraph 3.2 shall be equipped with a smoke
meter  Installed to measure opacity across
the diameter of the smoke  generator stack.
The smoke meter output shall display  Ln-
stack opacity based upon a pathlength equal
to the stack exit diameter, on a  full 0 to  100
percent  chart   recorder  scale.  The  smoke
meet the specifications shown In Table 9—1.
The smoke meter shall be calibrated as pre-
scribed in paragraph 3.3.1 prior to the con-
duct  of each  smoke  reading test. At  the-
completion of each test, the  zero and span
drift  shall be checked and If the drift  ex-
ceeds ±1 percent opacity, the condition shall
be  corrected prior to conducting any subse-
quent test runs. The smoke meter shall  be
demonstrated, at the time of Installation, to
meet the specifications listed in Table 9-1.
This  demonstration shall be repeated fol-
lowing any subsequent repair or replacement
of the photocell or associated electronic cir-
cuitry including the chart recorder or output
meter, or every 3  months, whichever occurs
first.

    TABLZ 9-1	SMOKS  MZTEB DESIGN A*TB
                    3PECmCATlON3

                         Specification
                      Incandescent   lamp
                        operated ax nominal
                        rated voltage.
                      Fhotoplc    (daylight
                        spectral response of
                        the  human  eye-
                        reference 4.3).
                      15*  marlrniim tOCal
                        angle.
                      15*  m-.-Tlrrm.ri total
                        angle.
                      ±3 %  opacity,  maxi-
                        mum.
                      ±i %    opacity,   30
                         minutes.
                      S3 seconds.
Parameter:
a. Light source	
b.  Spectral response
    of photocell.
c. Angle of view	

d. Angle of  projec-
    tion.
e. Calibration error.

f. Zero   and  span
     drift,
j. Response  time—
 . 3.3.1  Calibration.  The  smoke  meter  is
calibrated  after allowing a minimum of  30
mlzutss wanaup  by alternately  producing
                                                B-3

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simulated opacity of 0 percent and 100 per-
cent.  When stable response at 0 percent or
100 percent Is cosed, the smoke meter la ad-
justed to produce an output of 0 percent or
100 percent, as appropriate. This calibration
snail  b« repeated until stable 0 percent and
100 percent readings are produced  without
adjustment.  Simulated  0  percent and 100
percent opacity values  may be  produced by
alternately switching the power to the light
source on and off while the smoke generator
is not producing amoks.
   132  Smoke meter evaluation. The smoke
meter design  and  performance  are  to be
evaluated as follows:
   3.3.2.1  Light source. Verify  from manu-
facturer's  data and from voltage measure-
ments made at the lamp, as iastailsd.  that
the lamp is operated  within ±5  percent of
the nominal ratsd voltage.
   3.3.2.2  Spectral   response   of  photocell.
Verify  from  manufacturer's  data that the
 photocell has  a  photoplc  response; i.e., the
 spectral sensitivity of  the cell shall  closely
 approximate  the standard spectral-luminos-
 ity curve for photoplc  vision which Ls refer-
 enced In (b)  of Table  9-1.
   3.3.2.3  Angle of view. Checls construction
 geometry to ensure that  the total angle of
 view of the  smoke plume,  as seen by tha
 photocell, does  not ezceed 15*. The total
 angle of view may be calculated  from: *=2
 tan-* d/2L, where  3=total angle  of view:
 d=the sum of the photocell diameter-f the
 diameter  of  the   limiting  aperture:  and
 L=tbe  distance from  the photocell  to the
 limiting aperture. The limiting aperture is
 the point In the path between  the photocell
 and  the smote  plume where  the  angle of
 view la  niost restricted. In smofca generator
 smoke meters  this Is  normally an orifico
 plate.
   3.3-2.4 Anglft  of projection, check con-
 struction geometry to  ensure that the total
 angle  of  projection  of the lamp  on the
 smoke plume does not exceed 13*. The total
 angle of projection may be calculated from:
 f=2 tan-1 d/2L, where te total  angle of pro-
 jection; d= the siim of the length  of the
 lamp filament + the diameter of the limiting
 aperture; and L= the distance from the lamp
 to the limiting aperture.
   3.3.2.3  Calibration  error. Using  neutral-
 density alters of known opacity, check the
 error between the actual response and the
 theoretical  nn«*y  response  of the  smote
 meter. This check  Is  accomplished  by first
 calibrating the  smote meter  according to
 3.3.1 and  then Inserting a series  of three
 neutral-density niters of nominal opacity of
 20, 50, and 73 percent In the  smoke meter
 pathlength. Filters callbarted •within ±2 per-
cent  T**" be used. Care should b« taken
when Inserting the filters to prevent stray
light from affecting the meter. Malta a total
of five  nonconseeutlva readings for each
filter. The rr"t'l1rrmTT' error on any one read-
ing shfr" be 3 percent opacity.
   3,3.2.3  Zero  and span drift.  Determine
the zero and span drift by  calibrating and
operating the smoke generator In a normal
manner over a 1-hour period. The  drift Is
 measured by checking the zero and span at
 the end of this period.
  3.3.2.7  Response time. Determine the re-
sponse time by  producng the series of five
simulated 0 percent and 100 percent opacity
values ""* observing the time  required  to
 reach stable  response. Opacity  values of  0
percent and 100 percent may be simulated
by alternately' switching the  power to the
light  source  off i""l on  while the  smoke
generator Is not operating.
  4. References.
  4.1  Air Pollution Control District Rules
and  Regulations,  Los Angeles County Air
Pollution Control  District,  Regulation IV,
Prohibitions, Rule  SO.
  4JJ  Welsburd, itelvtn t. Field  Operations
and Enforcement Manual for Air, T7.S. Envi-
ronmental Protection Agency, Research Tri-
angle Park, N.C.,  APTD-1100, August 1972.
pp. 4.1-4.38.
  4.3  Condon. E. U1., and Odlshaw, H- Hand-
book of Physics, McGraw-Hill Co., N.Y., N.Y.,
1958, Table 3.1. p. 3-52.
                                                B-4

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                                            9-1
                         UCOU Or VUBAL DROUflHATXOM Of OfACITT
 COHTAUT
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HOOTS or owi»7ATioi_
ountvp   •	
 nre FACILITY
 cantoL smcE_
msexva camncAiiou DATS
oil am AmiUTioM	
JOIHT or IXISJIONI	
HEIGHT or DUCHAMS POINT
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8«i|KC o( Maanacioa faint
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nATm coroiTiina
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                                         B-5

-------
COMPANY
LOCATION
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          (Cont.)

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                    TYPE FACILITY
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*


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30
31 •
32
33
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                    APPENDIX C

        S 12. - GENERAL POLICY ON THE USE
OF SECTION 114 AUTHORITY FOR ENFORCEMENT PURPOSES
                       C-l

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S 12.  - GENERAL POLICY ON THE USE OF SECTION 1.14 AUTHORITY FOR
        ENFORCEMENT PURPOSES

INTRODUCTION

     The purpose of this guideline is to provide guidance relating
to the exercise of the authority set forth in Section 114 of the
Clean Air Act, as amended, for enforcement purposes .JL'

USES OF SECTION 114

Use in Determining Status of Compliance

    Section 114(a)(ii) provides that the Administrator may require
the owner or operator of any source to provide information for the
purpose of determining "whether any person is in violation of any
such standard or any requirement of such a plan."  This is one of
the most important enforcement tools under the Clean Air Act, in
that the source can be required to provide the information which may
be the basis for enforcement action by EPA.  Regions are urged to
make extensive use of §114 for enforcement purposes since this is
usually the most effective method of obtaining the necessary informa-
tion to begin an enforcement action.

Uses During Emergency Episodes

    Section 114(a)(iii) of the Act enables EPA to obtain informa-
tion necessary to implement Section 303 authority (emergency
episodes).  During an emergency episode, it may be necessary to
obtain recordkeeping by such owner or operator to ensure that he
is taking appropriate action.  This section can also be used to
develop Section 303 emergency episode action plans, as discussed
in General Enforcement Guideline S.15.
   Section 114(a)(l) enables the Administrator to require owners or
   operators -of emission sources "to (A) establish and maintain such
   records, (B) make such reports, (C)  install, use, and maintain
   such monitoring equipment or methods, (D) sample such emissions
   (in accordance with such methods, at such locations, at such
   intervals, and in such manner as the Administrator shall pre-
   scribe), and (E) provide such other information, as he nay
   reasonably require." Section 114(a)(2) authorizes right of entry
   for certain purposes and the right of the Administrator to
   sample emissions.
                                C-2

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REQUEST FOR INFORMATION

Section 114 Letter Format

    The letter to an owner or operator should recite expressly that
it is being sent pursuant to Section 114(a)(ii) or  (iii), state
specifically the information required, recite the penalties for
non-compliance, and specify a reasonable time to answer.  Generally
it should be sent certified mail, return receipt required, to
document receipt.  In the letter, the Regional Office may require
the source owner or operator to appear at a designated time and
place to discuss the information required to be provided to
EPA.

    During an emergency episode a Section 114 letter should be
delivered personally to the source owner or operator and a receipt
should be obtained upon delivery.

Privilege Against Self-Incrimination

    A problem may arise in the case of an individual who refuses to
provide information on the grounds of the Fifth Amendment privilege
against self-incrimination.  This is not a problem with respect to
a corporation, since a corporation does not have this privilege.
However, except as discussed in the following, an individual, as
opposed to the corporation, may refuse to answer any request for
information under Section 114 if the information might tend to
incriminate him.   (See OGC memo dated 8/7/72).   If  an individual re-
fuses to comply with the request for information on this ground,  the
Regional Office should consider itself on notice of a probable viola-
tion and should gather the information by other methods.

    If the information needed from the source owner or operator is
required to be kept under a recordkeeping provision of a State
Implementation Plan, then the privilege may not be invoked, even
by an individual. ?/  Thus, if an individual raises an objection
on Fifth Amendment grounds, the State Implementation Plan should be
checked to determine whether the plan requires such information to
be kept by the source, and if it does, Fifth Amendment objections
are not valid and the information must be provided.
2J According to the Shapiro Doctrine, "the privilege which exists as
   to private papers cannot be maintained in relation to  'records re-
   quired by law to be kept in order that there may be suitable in-
   formation of transactions which are the subject of governmental
   regulations and the enforcement of restrictions validly estab-
   lished'".
                               C-3

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    The Section 114 letter need not call to the attention of the
source owner or operator that he may have a right to invoke the
privilege against self-incrimination nor need this be done at an
onsight investigation.   The Miranda warning is required only where
a person is "in custody".

Federal Reports Act

    Section 114 letters sent to persons suspected of being in viola-
tion of an implementation plan requirement or Section 303 are not
subject to the Federal Reports Act.  Identical letters may be
sent to multiple sources without the need for securing OMB approval
since this use of Section 114 is an enforcement function rather than
the gathering of technical data for standard setting purposes.

    Before sending out a Section 114 letter, check the NEDS data
bank to determine whether EPA already has such information.  How-
ever, where immediate enforcement action is contemplated, the
Regional Offices should direct a Section 114 letter to the source
regardless of the results secured from the data bank.  Duplication
of reported information can be avoided by advising the source of the
information in our possession and affording the source the opportunity
to confirm such information as responsive to the Section 114 inquiry.
This practice will be necessary because information employed for en-
forcement purposes must constitute reliable evidence on the present
status of compliance and be so represented by the source under pain
of penalty for any misrepresentation.  To proceed otherwise presents
the prospect that a source may repudiate information in our possession
on which we base a finding of violation, and we then would be forced
to gather further proof to verify and substantiate our determination
before commencement of any judicial proceedings.

Trade Secrets

    It is anticipated that some of the information required by
Section 114 letters will contain trade secrets.  Although the infor-
mation asked for must be provided, the source owner or operator can
designate certain portions of his response confidential and EPA
must treat it as such unless and until the Administrator determines
that it is not entitled to protection as a trade secret.  This de-
termination should be made after the information has been submitted,
if either the source owner or operator requires that such a deter-
mination be made or if someonw else requests the information from
EPA.  Regional Offices can also make these determinations on their
own initiative to keep down the amount of material which must be
afforded confidential treatment.  No determination or agreement will
be made concerning trade secrets status prior to receipt of the


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Section 114  information.  The regulations  in  40  CFR Part  2
outline the  EPA procedures  for making  this determination.

ENTRY AND INSPECTION

     Section 114(a)(2) enables the Administrator or his authorized
representative to enter a source so  that EPA  can do its own
monitoring,  sampling, inspecting or  copying of records.  This
authority also can be used  to determine whether  a source is carrying
out any obligations imposed on it by EPA under Section 114(a)(l).

     The term "authorized representative"  would  include specific
individuals  from each Regional Office, preferably permanently de-
signated to  give a sense of continuity and familiarity with the
tasks.  This does not mean  that other Regional Office or EPA employees
cannot perform such tasks on an ad hoc basis  when necessary to
achieve EPA  objectives.

     A contractor for EPA or other person  assisting EPA in carrying
out its functions may be designated  as an  "authorized representative"
for specific purposes which should be stated  in  a letter granting
such representative status  to the contractor.  However, if the con-
tractor is refused entry by the source owner  or  operator despite
this letter, it is not advisable to  request a U.S.  Attorney to obtain
a search warrant to gain entry for the contractor,  since a judge
would most likely refuse to issue one.  EPA personnel should perform
the task themselves if such a situation arises or accompany the EPA
contractor performing the work.

     Where a state has been delegated Section 114 authority from
EPA, the same authority EPA has to monitor, sample,  inspect or
copy records, and any other authority under Section 114(a)(1) and
(2) of the Clean Air Act can, in like manner  be  exercised by the
State.  No representative of EPA need accompany  the state officials.

     Section 114(a)(2) requires that the person  exercising the right
of entry should have credentials.  EPA has established a procedure
governing the issuance and  control of credentials.   Regional Offices
may obtain such credentials in accordance with the procedures.   The
Regional Offices can still issue their own credentials to carry out
Section 114  in the period until the  procedures in the EPA order can
be implemented or in unusual circumstances.   If  the Regional Office
chooses to issue its own credentials in such  instances, such credentials
should contain the agency name; the  bearers name,  signature, and
photograph;   the division in the agency with thich he is employed; the
quotation of Section 114 authority under which entry is sought; and a
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citation of  the penalties for noncompliance with Section  114.   The
credentials  should be signed by the Regional Administrator.  Credentials
can also be  issued by the -Regional Office  in the form of  a  letter on
an ad hoc basis where there is not sufficient time to obtain more
permanent credentials.   The letter should contain all of the in-
formation that is  in the permanent credentials  except the photograph
and signature of the bearer.

     Entry for Section 114  purposes  should  be confined,  except  in
emergencies,  to normal business hours to minimize inconvenience to
the source.

Safety Equipment

     A source owner or operator has no responsibility to supply EPA
inspection teams exercising Section 114 authority with safety equip-
ment such as hard  hats or shoes.   EPA should provide whatever equip-
ment is necessary  for an inspection team to safely perform those
duties entrusted to them by law.

Visitors Releases

     Members of inspection teams exercising Section 114 authority
should not sign waivers or "visitors releases"  that would absolve
the company of responsibility of injury due to  negligence.  In a
memo to all Regional Counsels dated November 8, 1972, from John
Quarles, it is stated that "Inasmuch as the Clean Air Act .  . .
grant(s) EPA employees a right of  entry to corporate facilities,
a company may not  lawfully condition the exercise of this right
upon the signing of a release or indemnity agreement."  "When
a firm refuses entry to an EPA employee performing his function
under the Clean Air Act, the employee may appropriately cite
the statute and remind the company of EPA's right to seek judicial
enforcement.   If the company persists in its refusal, EPA should
go to court in preference to signing a 'Vistors Release'".

Search Warrants

     If a  source owner or operator refuses to admit EPA authorized
representatives attempting to exercise Section 114 responsibilities,
entry cannot be made until a search warrant is obtained.  Appro-
priate Regional personnel should be notified so that they can  request
that the U.S. Attorney obtain a search warrant.  (DSSE is developing
a model application for a search warrant and a model search warrant
for use by the Regional Offices).  If any  delay is anticipated  from
a source in  permitting the exercise of Section 114 authority and such
delay is unacceptable to the successful completion of EPA tasks, a

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search warrant should be obtained.  If delay is anticipated even
with a search warrant, it can be requested that the search warrant
be written so that immediate entry be granted.

ENFORCEMENT PROCEDURES

     Section 113(a)(3) provides that if the Administrator finds that
any person is in violation of any requirement of Section 114, he may
bring a civil action or issue an administrative order.  Guideline S4.
outlines procedures relevant to the commencement of a civil action
or issuance of an administrative order.

     In cases of failure to comply with Section 114, issuance of an
administrative order is more appropriate.  However, in most cases
regional enforcement personnel will want to phone the source prior
to the issuance of such an order to determine the reasons for the
source owner or operator's failure to comply.  If the source owner
or operator continues his refusal to comply after the phone call,
issuance of the order should proceed.  The order should include a
final date for compliance, and should specify a date for an oppor-
tunity to confer pursuant to Section 113(a)(4) prior to the effective
date of the order.  If the source owner or operator violates the
order, civil and criminal action will then be appropriate.

     While there are no criminal penalties for refusing to comply
with Section 114 per se, a knowing failure to comply with any order
issued under Section 113 relating to a Section 114 violation would
subject the violator to criminal penalties of up to $25,000 per
day or imprisonment for not more than one year, or both, for the
first offense.  Criminal penalties are also appropriate in the case
of any person who knowingly makes any false statement or tampers with
any monitoring device.  The criminal penalties specified in Section
113(c)(2) for a violation of this type- are a fine not to exceed
$10,000 or imprisonment for not more than six months, or both.  (See
Guideline S.O, General Policy on Commencement of Criminal Actions
Pursuant to Section 113(c)).
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               APPENDIX D




SUGGESTED CONTENTS OF STACK TEST REPORTS
                   D-l

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CONTENTS OF STACK TEST REPORTS

     In order to adequately assess the accuracy of any test report
the basic information listed in the following suggested outline is
necessary:

     (1)  Introduction.  Background information pertinent to the
          test is presented in this section.  This information shall
          include, but not be limited to, the following:
          (a)  Manufacturer's name and address.
          (b)  Name and address of testing organization.
          (c)  Names of persons present, dates and location of
               test.
          (d)  Schematic drawings of the process being tested showing
               emission points, sampling sites, and stack cross-
               section with the sampling points labeled and dimen-
               sions indicated.
          (e)  Brief Process Description

     (2)  Summary.  This section shall present a summary of test
          findings pertinent to the evaluation of the process
          with respect to the applicable emission standard.  The
          information shall include, but not be limited to, the
          following:
          (a)  A summary of emission rates found.
          (b)  Isokinetic sampling rates achieved if applicable.
          (c)  The operating level of the process while the tests
               were conducted.

     (3)  Procedure.  This section shall describe the procedures
          used and the operation of the sampling train and process
          during the tests.  The information shall include, but not
          be limited to, the following:
          (a)  A schematic drawing of the sampling devices used
               with each component designated and explained in a
               legend.
          (b)  A brief description of the method used to operate the
               sampling train and procedure used to recover samples.

     (4)  Analytical Technique.  This section shall contain a brief
          description of all analytical techniques used to determine
          the emissions from the source.

     (5)  Data and Calculations.  This section shall include all
          data collected and calculations.  As a minimum, this
          section shall contain the following information:
          (a)  All field data collected on raw data sheets.
          (b)  A log of process and sampling train operations.
                                D-2

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     (c)  Laboratory data including blanks, tare weights, and
          results of analysis.
     (d)  All emission calculations.

(6)   Chain of Custody.  A listing of the chain of custody of
     the emission test samples.

(7)   Appendix:

     (a)  Calibration work sheets for sampling equipment.
     (b)  Calibration or process logs of process parameters.
                           D-3

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                                    TECHNICAL REPORT DATA
                            (Please read luuntt: (ions on the reverse before completing)
 =5=PORT MO.
EPA 340/1-77-002
                                                             ,3. RECIPIENT'S ACCESSION
  iTLE AND SUBTITLE
                                                              i. REPORT DATE
    Inspection Manual far Enforcement of New Source
    Performance  Standards:  Basic  Oxygen Process Furnaces
                              6. PERFORMfNG ORGANIZATION CODE
                                    February  1977
 AUTHOH(S)
             M.D.  High
             T.A.  Li Puma
M.E. Lukey
R.F. Krzmarzick
                                                              . PERFORMING OHGANI3
 PERFORMING ORGANIZATION NAME AND ADDRESS

    Engineering-Science, Inc.
    7903 Westpark Drive
    McLean, Virginia 22101
                                                             10. PROGRAM ELEMENT NO.
                              11. CONTRACT/GRANT NO.
                                    68-02-1086
 2. SPONSORING AGENCY NAME AND ADDRESS

    U.S. Environmental Protection Agency
    Division of  Stationary Source Enforcement
    Washington  ,  D.C.
                              13. TYPE OF REPORT AND PERIOD COVERED
                                      Final
                              14. SPONSORING AGENCY COO6
15. SUPPLEMENTARY NOTES

    One of a series  of NSPS Enforcement  Inspection Manuals
IS. ABSTRACT
    This document  presents guidelines  to  enable enforcement  personnel to determine
    whether new  or modified basic oxygen  process furnaces  comply with New  Source
    Performance  Standards (NSPS).  Key parameters identified during the performance
    test are used  as  a comparative base during subsequent  inspections to determine
    the facility's compliance status.   Basic oxygen process  furnaces, atmospheric
    emissions from these furnaces, and emission control methods  are described.
    Inspection methods and types of records  to be kept are discussed in detail.
17.
                                 KEY WORDS AND DOCUMENT ANALYSIS
                   DESCRIPTORS
                                                b.IDENTIFIERS/OPEN ENDED TERMS
                                             c. COSATI Field/Group
   Basic Converters
   Steel Oxygen Blow Converters
   Air  Pollution
                   Basic Steel Industry
    13B
    14D
    11F
13. DISTRIBUTION STATEMENT

      Release unlimited
                 19. SECURITY CLASS (This Report)
                    Unclassified
                                                20. SECURITY CLASS (This page)
                                                    Unclassified
21. NO. OF PAGES
        *>   80
                                             22. PRICE
EPA Form 2220-1 (9-73)
                              ', U S. GOVERNMENT PRINTING OFFICE: 1977-720-117/1c:'63

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