EPA 340/1-77-007
MAY 1977
Stationary Source enforcement Series
INSPECTION MANUAL FOR ENFORCEMENT OF
NEW SOURCE PERFORMANCE STANDARDS
STEEL PRODUCING
ELECTRIC ARC FURNACES
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
Office of General Enforcement
Washington, D.C.20460
-------
GCA-TR-76-31-G
INSPECTION MANUAL FOR THE ENFORCEMENT OF NEW SOURCE
PERFORMANCE STANDARDS: STEEL PRODUCING
ELECTRIC-ARC FURNACES
Final Report
by
James Sahagian
Paul F. Fennelly
Manuel Rei
Contract No. 68-01-3155
Technical Service Area 1
Task No. 5
EPA Project Officer: Mark Antell
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Division of Stationary Source Enforcement
Washington, D.C.
April 1977
-------
The Enforcement Technical Guideline series of reports is issued by the
Office of Enforcement, Environmental Protection Agency, to assist the
Regional Offices in activities related to enforcement of implementation
pi arts; new srmrre emission standards, and hazardous emission standards
to be developed under the Clean Air Act. Copies of Enforcement Technical
Guideline reports are available - as supplies permit - from Air Pollution
Technical Information Center, Environmental Protection Agency, Research
Triangle Park, North Carolina 27711, or may be obtained, for a nominal
cost, from the National Technical Information Service, 5285 Port Royal
Road, Springfield, Virginia 22161.
This Final Report was furnished to the Environmental Protection Agency by the
GCA Corporation, GCA/Technology Division, Bedford, Massachusetts 01730, in ful-
fillment of Contract No. 68-01-3155, Technical Service Area 1, Task No. 5. The
opinions, findings, and conclusions expressed are those of the authors and not
necessarily those of the Environmental Protection Agency or of the cooperating
agencies. Mention of company or product names is not to be considered as an
endorsement by the Environmental Protection Agency.
-------
CONTENTS
Sections Page
I Introduction 1
II Summary of New Source Performance Standards for Steelmaking
Electric-Arc Furnaces 2
Emission Standards 2
Performance Testing 3
Monitoring Requirements 5
Record Keeping and Reporting 5
References 7
III Process Description 8
Furnace Description 8
Operating Practices 12
Pollutant Emissions 20
Ventilation Practices 24
Emission Control Systems 27
References 33
IV Inspection Procedures 34
Conduct of Inspection 35
Operating Parameters to be Checked 38
inspection Checklist 40
iii
-------
CONTENTS (continued)
Sections Page
Inspection Follow-up Procedures 49
References 51
V Performance Test 52
Process Operating Conditions 52
Process Observations 54
Emission Test Observations 54
References 62
Appendixes
A Part 60 - Standards of Performance For New Stationary
Sources - Electric Arc Furnaces in the Steel Industry 63
B Method 9 - Visual Determination of the Opacity of Emis-
sions From Stationary Sources 69
iv
-------
FIGURES
No. Page
1 Electric-Arc Furnace Subhearth Construction 10
2 Cross-Sectional View of a Steelmaking Electric - Arc
Furnace Indicating Typical Refractories Employed in
(Left) an Acid Lining and (Right) a Basic Lining 11
3 Overhead and Vertical Schematic Diagrams of a Steel-
making Electric - Arc Furnace 13
4 Ventilation Systems for Electric Arc Furnaces 26
-------
TABLES
No. Page
1 Chemical Composition of Steelmaking Electric-Arc
Furnace Dust 21
2 Size Distribution of Particulate Emissions From Steel-
making Electric-Arc Furnaces 21
3 Changes in Composition of Electric Furnace Dust During a
Single Heat 22
vi
-------
SECTION I
INTRODUCTION
Pursuant to Section 111 of the Clean Air Act, (USC 1857 et. seq.) the
Administrator of the Environmental Protection Agency (EPA) promulgated
particulate and opacity standards for performance of new and modified
Electric-Arc Furnaces. These proposed standards were issued in the
Federal Register of October 21, 1974 and final standards became effective
on September 23, 1975. The standards which were published in the Federal
Register of September 23, 1975 apply to all sources whose construction
or modification commenced after October 31, 1974.
Enforcement of these standards may be delegated by the EPA to individual
1 state agencies for all sources except those owned by the U.S. Government.
Each state must first, however, develop a program of inspection procedures
for verifying compliance with the standards, and EPA must approve the
program.
The purpose of this document is to provide guidelines for the appropriate
enforcement agency in the development of inspection programs for Electric-
Arc Furnaces which are covered by New Source Performance Standards (NSPS).
Included are sections which explain the regulations, the process, control
techniques and the responsibilities of the enforcement agency personnel.
-------
SECTION II
SUMMARY OF NEW SOURCE PERFORMANCE STANDARDS
FOR STEELMAKING ELECTRIC-ARC FURNACES1
Performance standards which are applicable for new and modified Electric-
Arc Furnaces in the steel industry, the construction or modification of
which was commenced after October 31, 1974, limit particulate emissions
from the control device, the shop, and from dust handling equipment. They
also specify that the opacity of these emissions not exceed a certain
level for each specified emission point. The regulations were published
in the September 23, 1975 Federal Register, Volume 40, Number 185. They
include both maximum emission limits for particulate pollutants as well
as standards for monitoring emissions and emission control equipment.
They also include all pertinent definitions with regard to the EAF and the
regulations. These standards do not apply to Electric-Arc Furnaces that
use continuous feeding of prereduced ore pellets as the primary source of
iron. A copy of the New Source Performance Standards for Steelmaking
Electric-Arc Furnace is presented in Appendix A.
EMISSION STANDARDS
Allowable levels of furnace particulate emissions and shop opacity are
outlined in the following sections. These levels are not to be exceeded
on or after the date on which the required performance test is completed.
Particulate Matter
The New Source Performance Standard for particulate loading limits the
emission from an electric-arc furnace emission control device to less than
12 mg/dscm (0.0052 gr/dscf).
2
-------
Opacity
The New Source Performance Standards state that gases from the particulate
control equipment may not exceed 3 percent opacity. Emissions from the
furnace which escape the particulate control equipment and pass through
the shop may not exceed 0 percent except: during charging emissions may
exceed 0 percent but must be less than 20 percent opacity; and during
tapping emissions may exceed 0 percent but must be less than 40 percent
opacity. In some shops the roof is closed during the charging and tapping
periods, preventing emissions from escaping until the roof is opened. For
these sources, the respective charging and tapping opacity levels of
20 percent and 40 percent will be allowed in each case for the length of
time defined by the charging and/or tapping periods.
Emissions from equipment handling the dust collected by particulate emis-
sion control devices may not exceed 10 percent opacity.
The primary means of determining compliance with opacity regulations is
observation utilizing EPA Method 9. Opacity may also be determined by
passing a light transverse through the effluent gas flow at a point near
their exit, and measuring the intensity of the beam with a transmissometer.
These data, however, are considered probative but not conclusive as evidence
of compliance.
PERFORMANCE TESTING
Demonstration that the standards are being met is accomplished only by
performance testing. The owner or operator of a new or modified steel-
making electric-arc furnace is required to conduct performance tests within
a specified period after start-up and thereafter, from time to time, as
specified by EPA.
-------
Initial Performance Test
The initial performance test of a new facility must be conducted within
60 days after achieving the maximum production rate at which the EAF will
be operated, but not later than 180 days after initial start-up. Further
tests may be required at other times by the Administrator, as outlined in
Section 114 of the Act. Thirty days must be allowed for prior notice to the
EPA, to allow the Agency to designate an observer to witness the test.
Performance tests must be conducted as per the instructions given in the
regulations, which are discussed in detail in Section IV of this manual.
The test consists of three repetitions of the specified procedure. Per-
formance of the facility is judged acceptable if, for each of the charac-
teristics tested, the average value from the three repetitions is less than
the NSPS standard value.
Necessary modifications in the details of the test methods may be made,
if approved in advance by the EPA. A written report of the test would be
furnished to the EPA.
Subsequent Performance Tests
Subsequent to the initial test, further performance tests may be required
from time to time at the discretion of EPA. Alternatively, the Agency
may decide to conduct performance tests. For this purpose the owner or
operator is required to provide testing facilities, which include necessary
utilities, sampling ports, safe platforms, and safe access to the sampling
platform.
Performance testing subsequent to the initial test is most likely to be
required when records indicate a relatively high frequency of occurrence
of emission levels near, at, or above the NSPS levels.
-------
MONTORING REQUIREMENTS
The opacity of the emissions discharged into the atmosphere from the
control device(s) must be continuously monitored as described below.
Opacity Monitoring
The NSPS require that the owner or operator of a new or modified EAF will
install, calibrate, maintain, and operate monitoring instruments to con-
tinuously measure the opacity of emissions discharged from the emission
control device(s).
Process Monitoring
The NSPS require that the owner or operator of a new or modified EAF must
install, calibrate, maintain, and operate monitoring device(s) which con-
tinuously records the volumetric flow rate through each separately ducted
hood. The flow rate monitoring device(s) shall have an accuracy of
+ 10 percent over its normal operating range, and may require calibration
relative to EPA Methods 1 and 2.
The NSPS also require that the owner or operator install, calibrate, and
maintain a monitoring device that continuously records the pressure in the
free space in side electric-arc furnaces whose emissions are controlled
via direct shell evacuation.
RECORD KEEPING AND REPORTING
The owner or operator of any EAF is required to maintain certain records,
to furnish certain reports, and to notify EPA of certain occurrences, as
follows.
-------
Notifications Regarding Initial Start-Up
The owner or operator must notify EPA of the anticipated date of initial
start-up of the facility not more than 60 days nor less than 30 days
previous to the anticipated date. Notification of the actual start-up
date must be postmarked within 15 days after: such date. "Start-up" is
defined as the operation of the facility for any purpose;
Records Regarding Start-Up, Shutdown, and Malfunction
The owner or operator shall maintain records of the occurrence and duration
of any start-up, shutdown, or malfunction in the operation of the affected
facility, including the emission control system and continuous monitoring
systems. These records shall be maintained for at least 2 years following
their occurrence. '
The record should include the nature and cause of any malfunction, together
with a notation as to corrective action and any measures undertaken to
prevent recurrence of the malfunction.
In this connection, "start-up" refers to a renewed operation of the facility
for any purpose; and "malfunction" is defined as any sudden, unavoidable
failure of either the air pollution control equipment or the EAF to operate
in a normal manner. Preventable failures, such as those which may have
been caused by poor maintenance or careless operation, or by equivalent
breakdown due to such causes, are not included in this definition.
Records Regarding Performance Testing
In order to facilitate conduct of performance tests by the Agency, the
owner or operator is required to make available to the EPA, any records
necessary to determine whether performance of the EAF is representative
performance at the time of the test. Time and duration of each charge
-------
and tap, as well as all flow rate data, pressure data, and opacity data
required to be monitored should be maintained daily. A file of all measure-
ments of opacity and particulate measurements shall be maintained by the
operator. Appropriate measurements shall be reduced to necessary units
of the applicable standards daily, and summarized and maintained for at
least 2 years following the date of such measurements and summaries.
These records should also be made available during inspections of the
facility.
REFERENCE
1. Fed. Regist. 40(185). September 23, 1975. p. 43850-43854.
-------
SECTION III
PROCESS DESCRIPTION
FURNACE DESCRIPTION
The direct-arc furnace (series-arc type) is the electric-arc furnace most
commonly used today for steelmaking. This furnace was originally developed
by Paul Heroult in France during the late 1800's. In this furnace, electric
current passes from one electrode through an arc to the metal charge,
through the charge, then from the charge through an arc to another
electrode.
Electric-arc furnaces are cylindrical vessels which are lined with refrac-
tory material, the composition of which is dependent upon the type of
1 2
scrap metal being used and the type of steel being produced. '
Both the acid and basic processes for making steel in electric furnaces
were used extensively during World War II. Since then, technical and
economic obstacles to the use of select scrap and the increasing utiliza-
tion of alloy steels have greatly decreased the use of acid-lined furnaces
(acid process). Almost all arc furnaces used for ingot-steel production
and a substantial number of the arc furnaces making steel castings are
basic lined. These furnaces generally use a combination of both high
and low alloy steel scrap and plain carbon steel scrap. Acid-lined
electric-arc furnaces are seldom employed outside of steel foundries and
forging shops. These furnaces are chiefly used for the production of
straight carbon castings and to a lesser extent for the production of
1 O / C*.
alloy steels. ' ' '
-------
The bottoms of basic-lined arc furnaces consists of a burned magnesite
brick subhearth with a working surface, 6 to 12 inches thick, of high
magnesia ramming material. Basic arc furnace roofs are generally con-
structed of high-alumina brick, with high alumina rammed or castable
materials for the center section around the electrodes. The bottoms of
acid-lined arc furnaces consist of a silica brick subhearth with a working
surface of ground ganister. The roofs are also constructed with silica
brick with ground ganister around the electrodes. Schematic diagrams of
both stadium type and inverted arch type subhearth construction are shown
in Figure 1. Figure 2 presents a schematic cross-section of an electric-arc
furnace with a stadium type subhearth construction, indicating typical
refractories employed in (left) and acid lining and (right) a basic lining.
Although only two electrodes are shown in the cross-sectional view, furnaces
128 10
of this type usually have three electrodes. ' ' '
Electric-arc furnaces are equipped with a tight fitting roof consisting of
a hollow circular ring which acts as a retainer for the dome-shaped
refractory portion of the roof. Water is circulated through the interior
%
of the hollow ring for cooling of both the ring and the adjacent roof
refractories. There are usually three triangularly shaped holes in the
roof to facilitate the raising and lowering of the carbon electrodes.
Annular water cooled steel rings (electrode glands) are set on top of the
refractory roof structure and surround the electrodes where they pass
through the ports into the furnace. Electrodes are usually powered by a
1237
three-phase transformer equipped for varying the secondary voltage. • ' ' '
Practically all modern steelmaking arc furnaces are top charged. There
are two types of top charged furnace roof removal techniques: (1) the
swing type where the roof is lifted and swung to one side in order to
clear the top of the furnace shell and (2) the gantry lift type where the
electrode masts and roof-raising mechanism are built into a gantry crane
that travels on rails along the charging floor. Both mechanisms require
-------
HEARTH LINE
STADIUM-TYPE SUBHEARTH CONSTRUCTION
HEARTH LINE
INVERTED-ARCH TYPE SUBHEARTH CONSTRUCTION
Figure 1. Electric-arc furnace subhearth construction.
-------
ELECTRODES
/ X
WATER-COOLED
ROOF RING
SILICA BRICK
HIGH-ALUMINA
BRICK
FIRECLAY BRICK
SILICA BRICK
METAL-ENCASED
DIRECT-BONDED
MAGNESITE-CHROME
BRICK
—BURNED-
MAGNESITE BRICK
SHOWS AN ACID LINING
SHOWS A BASIC LINING
Figure 2. Cross-sectional view of a steelmaking electric-arc furnace indicating typical
refractories employed in (left) an acid lining and (right) a basic lining.
-------
that the electrodes are raised to clear the furnace shell prior to removal
of the roof. All modern furnace roofs are the swing type although many
12347
older gantry type furnaces are still in operation.
Openings are provided in the side of the furnace shell structure for both
the tap hole and the rear slagging-working door. Sometimes a side door is
included as an aid during refining and fettling operations. Covered ports
are sometimes provided to facilitate fettling and oxygen lancing. Ports can
also be provided for lime and carbon injection lances. All furnace shell
i j !>4
openings are water cooled.
The furnace structure is mounted on curved toothed rockers and rails which
permit forward and backward tilting of the furnace. Tilting is accomplished
by a dual rack and pinion mechanism which is attached to the rockers. Most
modern furnaces are designed to tilt 15° backward for deslagging and at
least 45 forward for tapping. Figure 3 presents both overhead and vertical
diagrams of a steel making arc furnaces. ' ' '
OPERATING PRACTICES
Charging
As mentioned in the previous section, basic-lined steelmaking arc furnaces
generally melt scrap made up of a combination of alloy and plain carbon
steel. The percentages of each of these two types of steel in a furnace
charge is dependent upon the particular grade of steel being produced.
Acid-lined electric-arc furnaces producing steel castings must use scrap
which has a low sulfur and phosphorous content. '
The necessity for conserving the valuable alloy content of steel scrap,
to economize in the use of virgin alloys and to insure that only the ele-
ments desired be introduced into the steel requires that scrap used in
basic lined furnaces be segregated into stock piles of identified grades.
The more the grades of steel produced by a furnace vary, the more
12
-------
(OVER SLAG PIT)
(OVER POURING AREA)
r-r-j uu ^
1 \J CONTROL BOOM
r^^lN
c
1
1
i
i
)(
1 (
i!
9 I
| \
M
> i
II
i i
1 1
)
1
1
il
[•
j _,
•a
z
crt
-n
O
FtMER VAULT 1
Figure 3. Overhead and vertical schematic diagrams of a steelmaking electric-arc
furnace . 1
-------
extensive this scrap classification by alloy content must be. Classifica-
1.4
tion by scrap thickness and cleanliness is also employed.
Prior to charging, the furnace power is turned off and the roof and elec-
trodes are moved out of the way. Top charged arc furnaces are charged by
bucket. A bottom dump bucket charges scrap from a considerable height
resulting in a shock to the furnace bottom. Scrap size and bulk density
may vary from heavy scrap such as ingots to light scrap such as machine
shop turnings. The charging bucket is normally loaded with a layer of
light and medium scrap on the bottom. This is done for two reasons: (1)
to provide some cushioning of the fall of the larger pieces of scrap, (2)
because this type of scrap melts more quickly than large pieces of scrap,
thus forming a pool of molten metal upon the furnace bottom. However,
extremely large pieces of scrap such as ingot butts and broken roll sections
are preferably charged by magnets onto the bottom of the furnace prior to
bucket charging. Heavy scrap is charged in the area within or adjacent to
the triangle formed by the electrodes. This heavy scrap must be charged
in such a way that it will not shift during melt-down and cause possible
damage to electrodes by falling against them. After this, light or medium
scrap is usually piled high around the sides of the furnace to protect the
roof and side walls from the high-power arc during the melt-down. Alloying
materials that are not easily oxidized and limestone may be charged into
the furnace along with the scrap prior to melt-down. Limestone is used as
a slagging agent to reduce the sulfur and phosphorous content in the steel
and is often charged with the scrap prior to melt-down or during back-
charging. Iron ore and coke may also be charged depending on the carbon
content of the scrap and the product requirements. »''»''
Meltdown/Oxidation
Once the furnace has been initially charged, the banks in front of the
furnace doors are built up with refractory material to form a dam in order
to keep molten metal from slopping out of the furnace. Once the doors and
roof are securely closed, the electrodes are lowered to about an inch above
14
-------
the scrap. For the first three to five minutes, an intermediate voltage
is selected to allow the electrodes to bore into the scrap, thereby shield-
ing the lining and roof of the furnace from the heat of the arc. After
this initial period, maximum voltage is usually applied in order to melt
the scrap as fast as possible. The electrodes melt the portion of the
charge directly underneath and around them and continue to bore through the
metallic charge forming a pool of molten metal oh the furnace hearth which
in turn helps melt the charge via radiational heat. Since the bulk density
of an unmelted scrap charge is considerably lower than the density of
molten steel, the space occupied by unmelted scrap is relatively high in
comparison to the space it occupies once it is melted. Because of these
spatial characteristics, electric arc furnaces are usually backcharged once
or twice after the initial charging. Sometimes unmelted scrap hangs up on
the refractory internal walls of the furnace. When this happens, the fur-
nace is tilted in order to get this unmelted metal to slide into the center
of the furnace. ' '
During the formation of molten metal, phosphorous, silicon, maganese, car-
bon; etc., present in the scrap are oxidized. The oxygen responsible for
this oxidation is primarily obtained from (1) oxygen in the furnace atmo-
sphere, (2) oxides of alloying elements present in the scrap, (3) calcina-
tion of limestone (if used), and (4) oxygen that is lanced into the bath.
Oxygen lancing is usually employed to reduce the carbon content of the
steel by reacting with it to form carbon monoxide. Oxidation practices
must be varied with different grades of carbon steel.
Refining
The Basic Electric-Arc Furnace Process - In the basic process, the refining
period begins after the metal is completely molten, oxygen lancing has been
completed and the desired carbon content level has been achieved. Basic-
lined electric furnaces may employ either a single or double slagging pro-
cess during refining. The single slag process is generally used to produce
specialty steels having various alloy contents. Product quality (chemical
15
-------
and mechanical properties) is better with the double slag process than with
the single slag process.
In the single slag process, the oxidizing slag which initially forms is
made reducing by adding coke breeze or old electrodes during the refining
period. This carbon reacts with calcium in the slag to form calcuim car-
bide which makes the slag basic. Calcium in the slag may be obtained from
either lime or limestone. As mentioned previously, these materials are
usually charged into the furnace with the scrap and, if needed, further
additions may be made to the furnace during the refining period. Additions
of fluorspar and silica sand which thins the slag may also be made as
needed during the refining period, and lime and carbon additions may either
be blown in through injection lance ports on the furnace shell or made
through the furnace door. Fluorspar, silica sand and ferrosilicon additions
are conventionally made through the side door of the furnace. ' ' ' ' '
In the basic double slag process, the oxidizing slag which initially forms
is removed and followed by a reducing slag. Oxidizing slag removal is
accomplished by cutting off the electric power to the electrodes, back-
tilting the furnace slightly and then raking the slag out through the
slagging door with wooden or steel rabbles. After the initial oxidizing
slag has been removed, the furnace is returned to its normal position,
the electrodes are lowered and a second or reducing slag is formed by
adding burnt lime, powdered coke, fluorspar, silica sand, ferrosilicon
and ferromanganese. When low-carbon grades (> 0.12 percent C) of steel
are being produced, a lime silica, a lime alumina or a modified carbidic
slag containing less coke than normal, is used. ' ' '
A carbide slag acts to return reducible oxides such as those of manganese,
chromium, vanadium, tungsten, iron, etc. from the slag to the metal;
consequently, such oxides may be added for direct reduction as soon as
the carbide slag is formed. The slag also serves to reduce the oxides
in the bath and facilitates the removal of sulfur as calcium sulfide.
16
-------
Desulfurization is aided by the addition of lime, limestone and fluorspar,
by agitation of the bath and high temperature. Once the desired carbon and
alloy contents have been achieved, the furnace is tapped shortly
thereafter- ' '
The Acid Electric-Arc Furnace Process - Most American steel foundries using
the acid process employ the single slag complete'oxidation method of refin-
ing. The refining period begins as soon as the charge is completely melted
or nearly all melted. Iron ore and silica sand are added to the bath at
this time. The iron oxide and silicon oxide resulting from the additions
of these materials serve to form an oxidizing slag. If a high percentage
of returned foundry scrap has been melted in the furnace, the silicon and
manganese in the scrap will become slag forming oxides, thereby reducing
the silica sand additions required during the refining period. The carbon
content of the molten bath should be higher than the carbon desired in the
finished steel.' The excess carbon will be removed by the boil. '
After the bath is covered with an oxidizing slag which is black in color
(indicates a high iron oxide content) and the carbon content in the molten
bath is high enough, the temperature of the steel is increased until it
is hot enough to boil. The boil is a reaction between the carbon and the
oxygen dissolved in the steel. This decarburization process is sometimes
accelerated by injecting oxygen gas into the bath. The boil is usually
maintained for at least ten minutes. After the boil, silicon and manganese
are added as ferroalloys for deoxidation. The heat is tapped as soon as
these materials have completely melted and diffused through the bath.
At regular intervals during the refining period of both the acid and basic
processes, the temperature and composition of the melt are monitored.
This is usually done by opening the slagging door, taking a thermocouple
temperature reading and withdrawing a sample of the molten steel. Once
the sample has cooled, the carbon content and sometimes the content of
4
certain alloys are measured.
17
-------
Tapping
In tapping a heat, the electrodes are raised sufficiently to clear the bath
after the power is shut off. The tap hole is opened and the furnace is
tilted so that the steel heat is drained from the furnace into a teeming
ladle used to hold the molten steel. This steel holding ladle is usually
held close to the furnace spout by a teeming crane during tapping to mini-
mize exposure of the molten steel to air and to minimize the erosion of the
ladle refractories. The slag may be tapped before, with or after the steel,
depending on the particular operation. The slag serves as an insulating
blanket during teeming. Additions of feromanganese and ferrosilicon may be
made in the ladle in order to tie up oxygen. If the final product require-
ments call for them, alloys such as aluminum, titanium, zirconium, vanadium
and boron may also be added in the ladle. The common practice is to add
these alloys in paper sacks which are thrown into the ladle as the steel is
being tapped so that the sacks hit the molten metal stream. If a chrome
alloy steel is being produced, chromium additions are usually made just
prior to tapping in order to minimize the formation of chromium oxide.
Copper, nickel and molybdenum alloys can be added at any time without loss
due to oxidation or adsorption by the slag. ' ' '
Pouring
In the basic steel-making process, once the steel holding ladle is full,
it is transported by crane or ladle transfer car to either a teeming or
a continuous casting area. At this time, either of two pouring practices
may be employed, direct (top pouring) or indirect (bottom pouring). Direct
pouring is accomplished by raising the stopper rod, thus allowing the
molten steel to run directly from the ladle. In the indirect method, the
molten steel runs from the bottom of the ladle through a refractory funnel
and runner. Basket pouring, a modification of indirect pouring, utilizes
a small intermediate ladle which is filled from the bottom of the large
ladle. When the small ladle is filled, the nozzle in its bottom is opened,
allowing the molten steel to be poured. Basket pouring results in more
18
-------
uniform steel pouring rates. The purpose of indirect pouring is to reduce
splash, thereby minimizing scabs and defects on the surface of the steel
products. '
The teeming section of a mill building consists of a long aisle where
strings of flat bed railroad cars called "drags" are stationed. A number
of cast iron ingot molds seated on flat cast iron plates called "stools"
are located on the bed of each car. The teeming crane holds the ladle
over each ingot mold. The molten steel is poured through a bottom ladle
nozzle into the ingot molds. When one mold is filled, the stopper rod
which blocks the ladle nozzle is closed and the teeming crane shifts the
ladle to the next ingot mold. This procedure continues until all the steel
in the ladle has been poured. At this time, any slag remaining in the
ladle is dumped and, if required, the ladle is returned for another heat of
steel. During the teeming operation, some materials are added to the steel
such as aluminum or lead shot. The aluminum acts as a deoxidizing agent
1 3 9 10
whereas lead is added to make the steel more freely machinable. ' ' '
Steel that is not teemed into ingot molds can be cast in a process known
as continuous casting. In this process, billets, blooms, slabs and other
shapes are cast directly from the teeming ladle. To accomplish this, the
steel ladle is suspended above a refractory-lined rectangualar container
with several nozzles in the bottom. This "tundish" regulates the flow of
molten steel from teeming ladle to the continuous casting molds. When
casting billets or blooms, several parallel casting molds are served by one
"tundish".1'3
In the acid steelmaking process, molds can be poured either directly or
indirectly, depending on the size of the castings being produced.
Vacuum Degassing
Vacuum degassing is defined as, "the exposure of molten steel to a low-
pressure environment to remove gases (chiefly hydrogen and oxygen) from
19
-------
the steel. Gases, especially hydrogen and oxygen, which have been absorbed
into molten steel can cause voids, inclusions, and other flows which contri-
bute harmful properties to the solidified steel. These gases are sometimes
removed using vacuum degassing. If vacuum degassing is used it can be done
at various points following furnace tapping.
Since most vacuum degassing is performed separate of the electric-arc
furnace operation, it is not covered by the NSPS. However, vacuum
degassing is a source of particulate emissions and should be considered
by the inspector and operator so that those emissions do not interfere with
the measurement of emissions from the operation of the arc-furnace.
One method of vacuum degassing coincides with furnace tapping, called "tap
degassing", and as such, emissions during this process are covered by the
NSPS concerning tapping. Tap degassing is performed by tapping the furnace
directly into a tundish which is mounted upon a covered steel ladle where
the degassing is performed. Emissions caused during the tapping of the
molten metal into the tundish should be considered tapping emissions at this
point. Emissions from the degassing should not be considered by the field
"inspector.
POLLUTANT EMISSIONS
The chemical compositions and size distributions of particulate emissions
that were generated by various steelmaking electric-arc furnaces are pre-
sented in Tables 1 and 2 respectively. As one might expect, iron oxide is
the primary constituent in the dust. Oxides of fluxes, deoxidizing agents
and alloys occur in the furnace dust at various concentrations, depending
on the composition of the scrap, the types of fluxes and alloys used and
the steelmaking techniques employed. Table 3 shows the composition of a
typical arc-furnace dust during the various stages of a heat. As can be
seen from this table, iron oxide fume is the major dust constituent during
the meltdown/oxidation cycle and during oxygen lancing while calcium oxide
from the slag is the major dust constituent during refining. As was the
20
-------
Table 1. CHEMICAL COMPOSITION OF STEELMAKING
ELECTRIC-ARC FURNACE DUST6'15
Constituents
FeO
Fe2°3
Cr2°3
MnO
NiO
PbO
ZnO
SiO
A12°3
CaO
MgO
Range of dust
4
19
0
0.
0
0
0
0.
1
3
2
composition, % (wt)
- 10
- 53
- 14
6 - 12
- 3
4
- 44
9-9
- 13
- 15
- 15
Table 2.- SIZE DISTRIBUTION OF PARTICULATE
EMISSIONS FROM STEELMAKING ELECTRIC-
ARC FURNACES6
Particle size range,
microns
0-5
5 - 10
10 - 20
20 - 40
40
Size distribution range,
7o (wt)
57 -
8 -
3 -
2 -
0 -
72
38
8
15
18
21
-------
Table 3. CHANGES IN COMPOSITION OF ELECTRIC FURNACE
DUST DURING A SINGLE HEAT6*12
Constituent
Fe203
Cr203
MnO
Si02
CaO
MgO
A1203
P205
so2
Composition, % (wt)
Meltdown
56.75
1.32
10.15
9.77
3.39
0.46
0.31
0.60
2.08
Oxidation
66.00
1.32
5.81
0.76
6.30
0.67
0.17
0.59
6.00
Oxygen lancing
65.37
0.86
9.17
2.42
3.10
1.83
0.14
0.76
1.84
Refining
26.60
0.53
6.70
trace
35.22
2.72
0.45
0.55
7.55
22
-------
case previously, these compositions will vary depending on the input mate-
rials and steelmaking practices employed.
Some elements are quite volatile under steelmaking conditions. Cadmium and
zinc are volatile so that the oxides of these elements are deposited in
the fume collection system. Calcium and magnesium are also very volatile
but the chemical reactions involving them are such that these elements
remain in the slag as oxides. Lead is also quite volatile however, a bath
containing considerable nickel may retain some lead. Copper, nickel, man-
ganese and chromium are moderately volatile and these metals may be vapor-
ized from the surface of an iron melt that is exposed to a vacuum such as
that created by a fourth hole ventilation system.
The emissions resulting from charging a hot electric-arc furnace with scrap
are usually heavy and difficult to capture. The intensity of charging
emissions is a function of scrap cleanliness. Scrap containing heavy rust,
oil, grease or dirt is highly emissive during charging. Wet or icy scrap
may also cause heavy emissions. Emissions during charging are highly car-
bonaceous being composed primarily of smoke and soot.
Highest furnace emissions occur during the meltdown/oxidation period. These
emissions are primarily composed of iron and other metallic fume. The fume
emission during meltdown is highly dependent upon the intensity of the arc
and the thickness of the scrap. Thin scrap will generate more fume during
meltdown than thick scrap. Fume generation is greatly accelerated during
periods of oxygen lancing. Fume emissions during the refining period are
moderate with periods of maximum emissions taking place when the bath is
agitated during additions to the melt or at any time when working doors
or sampling doors are opened, creating an induced draft through the furnace.
Fume emissions during tapping, like charging emissions, are difficult to
capture. They are primarily composed of metallic oxides resulting from
9 *} f\
contact with the air and from bath agitation. ' '
23
-------
VENTILATION PRACTICES
There are several types of fume collection devices which can be used on
electric-arc furnace off-gases. Meeting NSPS will require the use of such
a device for the furnace, and one to vent the shop, in which case a combi-
nation of fume collection devices may be utilized. There are several types
of fume collection devices currently in use, however, we will only describe
those which are currently being designed for new furnaces. For more infor-
mation on evacuation systems refer to reference 2.
Fourth Hole
The fourth hole evacuation consists of ducting attached to a separate or
fourth hole in the roof of the furnace, from which the shell is directly
evacuated, see Figure 4. A negative pressure must be maintained within the
furnace shell indicating that the evacuation system is in fact evacuating
the shell. The gases are cooled and the CO combusted in water cooled elbows,
The fourth hole system has potentially the lowest air volume requirements
of any fume collection systems.
The fourth hole system only collects fume while the roof is in place and
does not collect fume during charging and tapping. Since charging and tap-
ping emissions are not captured, emissions from the shop may be excessive
if some system is not used to capture these shop emissions. Fume collec-
tion efficiency is also impaired by the opening of any furnace doors
beyond the openings for which the system was designed.
Side Draft
Side draft hoods are designed to capture the furnace off-gases after they
leave the furnace around the electrode holes and the work doors, as shown
12
in Figure 4. The pressure inside the furnace shell does not require
monitoring, and open doors do not substantially affet the fume capture
collection efficiency. The gases are cooled by the use of bleed-in air.
24
-------
Side draft capture systems only operate while the furnace roof is in place,
therefore they do not capture charging and tapping emissions. Due to high
operating costs side draft evacuation is only used for small furnaces
(< 25 ton). Advantages include elimination of explosion potential and no
requirement for close control over internal vacuum.
Combination Hood
This hooding arrangement, illustrated in Figure 4 incorporates elements of
side draft and fourth hole ventilation systems. The fume is collected from
a fourth hole as well as from around the electrodes, and there is an air
gap in the ducting to introduce secondary combustion air for oxidation of
CO to C02- This system uses the least air volume next to the fourth hole
system but requires a very accurate control system to regulate internal
12
furnace pressure plus draft at the electrodes. The combination hood also
only operates when the furnace roof is in place, thus it does not capture
charging and tapping emissions.
Canopy Hood
12
The canopy hood shown in Figure 4 is the least efficient method of arc
furnace fume capture. The canopy hood does not capture the quantity of
fume which the other systems capture and must use far greater air volumes.
The main advantage of this arrangement is that it captures emissions during
charging and tapping. For this reason, many new electric-arc furnaces will
incorporate canopy hooding with one of the other three systems previously
described.
A combined system should qperate as follows. In a single or multi-furnace
shop, when the roof is removed from a furnace, the furnace ventilation air
should be dampered off. At the same time, the canopy hood should begin to
operate to capture the fumes escaping the open furnace. It is important
that the FEO verifies that the system is operating properly since any use
of the furnace evacuation system when the roof is not in place, or of the
canopy hood while the roof is in place constitutes the addition of
25
-------
o
Fourth hole
Side draft
Combination hood
Canopy hood
Figure 4. Ventilation systems for electric arc furnaces
26
-------
essentially clean dilution air- Since the emission standard is strictly
a concentration limit, the additional dilution air would obviously yield
a false low concentration measurement.
Building Evacuation
It is possible to have a fume collection system consisting of scavenging
duct work in the peaks of the building roof which collects air from the
4
entire shop building. This type of system requires huge volumes of
ventilation air, however it does not allow any shop emissions to escape
without being cleaned. This type of system could be used in combination
with furnace capture systems, however, it is unlikely to fine widespread
use in new facilities. The FED may encounter this type of system in a
shop which has increased capacity by upgrading existing units or by the
addition of new units. A building evacuation system will be necessary
to meet the standards in certain shops that produce alloy steels without
the use of furnace evacuation systems.
EMISSION CONTROL SYSTEMS
Particulate emissions from the operation of electric-arc furnaces may be
controlled by fabric filtration (baghouse), wet scrubbing, or electrostatic
precipitation. However, to meet the New Source Performance Standards,
fabric filtration is the most likely candidate. The required efficiency and
opacity regulations make fabric filtration the best available control tech-
13
nology for meeting these regulations. For these reasons, more emphasis
will be placed upon control utilizing fabric filtration, than the other
two possible alternatives. The NSPS do not specifically require that fabric
filtration be utilized however; therefore the use of scrubbers and electro-
static precipitators is not precluded.
27
-------
Fabric Filtration
Fabric filter collectors suitable for use on arc furnace dust may be classi-
fied by their cleaning mechanism or cycle, and by whether they are operated
under pressure or suction. Each distinction is important to emissions and
emissions testing, therefore the field inspection officer (FEO) should be
aware of the type of system he is inspecting.
Pressure and Suction Systems - Pressure systems are those in which the
effluent gases are forced through the bags by a fan placed between the
fume collection duct or inlet to the baghouse and the baghouse itself.
In this type of system, the compartment housing the bags need not be air-
tight, since only the dirty air side of the collector needs to be sealed.
The pressure system can be easily inspected while in operation since air
entering the bag compartment has no effect on the furnace, fan, or fabric
12
filter collector performance. Another, and perhaps the most important
aspect of pressure systems from the FEO's viewpoint, is that pressure
systems do not require and almost never have a stack. Pressure systems
normally vent electric-arc furnace effluent through louvered openings or
monitors near the top of each compartment where full advantage of the
height of the fabric filter itself is utilized to disperse the gases.
It would be extremely difficult to properly sample a pressurized fabric
filter for particulate if it did not have a common stack to vent the com-
partments of the baghouse. Secondly it would also be difficult to monitor
the opacity of the multiple vents from which a pressurized fabric filter
exhausts effluent gases. More details concerning testing and monitoring
this type of system are given in reference 13.
The alternative to the pressure system is the exhaust system or suction
type collectors. The fan is placed on the clean air side of the baghouse
and it sucks the air through the bags. With this system it is necessary to
make the bag compartments airtight, especially during the cleaning cycla.
28
-------
Maintenance is difficult since the bags may not be inspected while they
12
are in use without affecting fan and furnace performance.
Suction or exhaust system fabric filters are normally vented to the atmo-
sphere through a common stack which is easily sampled for particulate and
monitored for opacity. The FED should have no problems in determining if
this type of system is performing satisfactorily to meet the NSPS.
Intermittent or Continuous Automatic Cleaning Baghouses - Another important
feature or fabric filter collectors which is of concern to the FED is the
method of cleaning. Fabric filter collectors all operate by filtering dirty
gases through fabrics and may be broken into two broad categories by clean-
ing method. Fabric filter collectors become clogged with the particulate
matter which they capture, and must be cleaned if they are to be of further
use. Systems designed to run without being cleaned until they are taken
off-line or shut down are intermittent. Those systems which can be operated
and cleaned without interruption of the overall filtering process are con-
14
sidered continuous automatic.
Intermittent systems can be used for applications in which the fabric filter
is subjected to low particulate loadings and short time durations, since
they cannot be cleaned while in use. Intermittent systems must be cleaned
by mechanical shaking, since there is no provision for cleaning dirty re-
verse air. This type of system may be utilized on an EAF, especially in a
single furnace shop. In a single furnace shop utilizing an evacuation sys-
tem which only operates while the roof is in place, the bags could be
cleaned during the charge or back charge, when the roof is removed and the
evacuation system is inoperative. For this type of system the FEO should
carefully note the pressure drop across the baghouse when it is first
brought back on line after a cleaning cycle, since this will be an important
factor in determining the efficiency at which the baghouse will operate. It
will also be important to coordinate the sampling time with the times that
the baghouse is operating, since it will be necessary to stop sampling during
the cleaning cycle.
29
-------
Continuous automatic cleaning baghouses are more complex than intermittent
systems, however they are more flexible in that they may be operated con-
tinuously without interruption for necessary cleaning. These systems will
likely be found in multiple furnace shops which duct the effluent gases
from all the furnaces to a single fabric filter collector. In this situa-
tion, there would be no time at which the baghouse could be shut down for
cleaning since the furnaces would be charged at different times, which
would require that the fume collection system is never inoperative. With a
continuous automatic fabric filter collector, it is necessary for the FED
to note the type of cleaning mechanism, and the time cycle and duration
of the cleaning mode.
Cleaning Mechanisms - There are three major types of cleaning mechanisms
for fabric filters and they are: (1) shaker, (2) reverse flow, and (3)
reverse pluse. The shaker type cleaning mechanism disloges the particulate
matter from the bag filter by shaking the bag from an oscillating top
supporting mechanism which is driven by a motor- The important parameters
which determine the cleaning efficiency with this type of system are:
the duration of the shaking cycle, the amplitude of the shaker, and the
number of shakes per unit time. The interrelationship between these
parameters and fabric filter performance is quite complex however, and is
beyond the scope of this manual. It is sufficient that the FEO realize
that any change in these cleaning parameters may affect the performance
of the fabric filter collector. The same is true for any of the cleaning
mechanisms mentioned in this manual, though the important parameters may
not be the same. To utilize a shaker cleaning mechanism on a continuous
automatic unit, the compartment being cleaned is isolated on a timed
basis, allowing no air to flow through while shaking.
Reverse flow type cleaning can be utilized by continuous automatic systems
and consists of isolating the compartment to be cleaned using dampers, and
forcing air through the bags (using an auxilliary fan) in the opposite
direction which collapses the bag, dislodging the filter cake.
30
-------
This sequence may be repeated several times during the cleaning cycle.
The most important parameters in this type of cleaning are the number of
collapse/reinflation cycles, and the amount of reverse air utilized.
Reverse pulse type cleaning consists of a short pulse of compressed air
directed through a venturi from the top to the bottom of the bag. The dirty
air is filtered from the outside to the inside of the bag, building up a
dust layer on the outside of the bag, The burst of compressed air violently
expands the bag disloging the dust layer and cleaning the bag. No section-
alization is required since the pulse of air effectively stops the flow of
air through the bag during cleaning. The most important parameters with
reverse pulse cleaning are the duration and pressure of the pulse and the
number of pulses per cleaning cycle, although normally only one pulse is used,
Wet Scrubbers
Wet scrubbers may be utlized to remove particulate matter from electric-arc
O O /
furnace off-gases. ' ' in order to meet NSPS it would be necessary to
utilize a high energy (pressure drop greater than 60 inches w.g.) venturi
13
type scrubber. However, Section 60.275 (e) of the regulation allows a
scrubber operating with a fourth hole evacuation system to exceed 0.0052 gr/
standard cubic foot if the furnace also has a canopy hood vented to a bag-
house which achieves less than that level. Scrubbers operate by mixing the
gas stream with a liquid medium (water) used to collect the particulate,
and followed by -collection of the liquid droplets with inertial entrapment.
The gases must be conditioned before entering the scrubber and this is us-
ually accomplished by quenching the gases to their saturation temperature
14
in the spark box. It will be necessary therefore for the FEO to note the
water injection rate at the spark box, and the temperature of the exiting
gases (entering the scrubber) .
Because of the scrubber's very high energy requirement per unit volume of
gases handled, it is very important to minimize the gas volume being treated
to make their use practicable. Therefore scrubbers will normally only
be found on furnaces equipped with direct shell evacuation such as a
31
-------
fourth hole, or combination roof fume capture systems. Also since the
particulate collected by scrubbers is in the form of a sludge or slurry,
there should be no opacity problem with the dust handling system. The
most important parameters for the FEO to observe are the scrubber's
water utilization rate, both recirculation and make-up, and the pressure
drop across the scrubber. These parameters are directly related to the
performance of the scrubber.
Electrostatic Precipitators
Electrostatic percipitators may be used to remove particulate matter from
electric arc furnace off-gases. Electrostatic precipitators operate by
charging the particulate matter electrically and collecting the charged
particles upon oppositely charged plates by coulombic attraction forces.
The plates which collect the particles are periodically cleaned by
mechanically shaking loose these deposits with hammers called rappers.
For electrostatic percipitators to perform satisfactorily, the current and
voltage must be controlled to within specified limits determined by the
overall design of the unit as well as the charactistics of the particles
and gas stream. Also, the resistivity of the particles must be maintained
within certain limits for them to properly accept a charge and dissipate
the charge upon collection. To properly condition the gases and particu-
late matter it is necessary to quench the off-gases in a wet spark box to
the appropriate temperature and humidity. ' ' The FEO should note the
water injection rate in the spark box as well as the temperature of the
exiting gases (the gases entering the precipitator).
The frequency and rate of cleaning the collection plates should also be
noted by the FEO. It is also possible that a wet electrostatic precipi-
tator could be used in which case the collection plates are continuously
washed with water. In this less likely case, the amount of water used
to clean the collection plates should be noted.
32
-------
REFERENCES
1. The Making, Shaping and Treating of Steel. United States Steel.
December 1970.
2. Background Information for Standards of Performance. Electric-Arc
Furnaces in the Steel Industry. EPA-450/2-74-017a. October 1974.
3. Development Document for Effluent Limitations Guidelines and New
Source Performance Standards for the Steel Making Segment of the
Iron and Steel Manufacturing Point Source Category. EPA-440/1-74->024-a.
4. Site Visitation. Bethlehem Steel Corporation. Steelton Electric
Furnace Shop. Steelton, Pa. April 1976.
5. Personal Communication, Harold E. McGannon. U.S. Steel. Pittsburg, Pa.
July 1976.
6. A Systems Analysis Study of the Integrated Iron and Steel Industry.
Batelle Memorial Institute. Columbus, Ohio. Hay 1969.
7- Site Visitation. Marathon LeTourneau Electric Furnace Shop.
Longview, Texas. June 1976.
8. Nafziger, R.H., J.E. Tress and W. L. Hunter. Rapid Addition of Charge
Materials in Continuous Electric Furnace Steelmaking. Iron aird"Steelmaker
May 1975.
9. Pongia, Vincent J. Start-up of 150-ton Electric-Arc Furnace at Lukens
Iron and Steel Engineer. December 1975.
10. Hayes - Albion's Electric Foundry J. C. Tuohy. Iron and Steelmaker.
May 1975.
11. J.F. Elliot, The Chemistry of Electric Furnace Steelmaking. Iron
and Steelmaker. January 1975.
12. Technical Bulliten, Carborundum Corp, "Electric-Arc Furnace Dust and
Fume Control."
13. Federal Register- 40(185). Electric Arc Funaces in the Steel Industry -
Standards of Performace.
14. Basic Handbook of Air Pollution Control Equipment, Prepared by Western
Precipitation Division. Joy Manufactoring Co.
33
-------
SECTION IV
INSPECTION PROCEDURES1.2
An air pollution inspection involves the visiting of an EAF to determine
if the equipment and process meet the NSPS. The Field Enforcement Officer
(FEO) must observe, qualitatively, the operation and condition of the EAF,
fume capturing system and control device. The condition as well as the
type of equipment and general housekeeping practices all could influence
the emission rate, and should be noted for future reference. The deter-
mination of whether the EAF is in compliance with NSPS, does not directly
require the general observations just mentioned, however, it is suggested
that they be made to aid future decisions concerning the frequency of
future testing.
Plant inspections are an important part of field operation activities which
aid in the systematic detection and observation of emission sources. The
following will outline the overall inspection process, however much of
this process does not apply specifically to the initial determination of
compliance with NSPS. The main point of interest will be: (1) the
formal procedure, and (2) the safety precautions. The frequency of
inspection and overall inspection are more specific to the continuous
monitoring activity of perhaps a local agency. The whole process of
inspection follows certain rules and guidelines which are discussed
briefly in the following sections.
34
-------
CONDUCT OP INSPECTION
There are four important components in the conduct of inspection of a given
equipment or a process.
• Formal procedure (e.g., use of credentials, ask to see
appropriate official)
• Frequency of inspection
• Overall inspection process (e.g., review of process
and records)
• Safety precautions and procedures
Formal Procedure
Prior to the actual on site inspection, the FEO should investigate any
available data on plant operations. In preparation for the inspection the
official should obtain the following data:
• Information for each major source (from an air pollution point
of view) including process descriptions, flow diagrams, estimates
of emissions, applicability of standards, and previous related
enforcement actions.
• Plot plans showing disposition of all major units at the facility.
• Business and ownership data including names of responsible
management personnel.
At the time of inspection, the FEO must have with him the credentials
showing his identity as an official of the air pollution control agency.
He should arrange an interview with the management of the shop. The
interview with plant managers and equipment operators can verify data
gathered and clarify any misunderstanding with regard to the information
reviewed prior to the inspection.
35
-------
Frequency of Inspections
The EAF and related equipment should be inspected systematically and
regularly. The frequency of reinspection is based upon the findings
during the initial inspection and the recommendations of the FEO and his
supervisor. These recommendations obviously depend on whether or not the
"good" maintenance practices from the pollution standpoint are followed
by the operator. Further, the frequency would depend on the overall in-
spection load of the control agency for the whole district. The rein-
spections are scheduled so that they can be completed within a month. The
number of reinspections assigned per district is based on the estimate
that all required inspections can be completed within 1 year.
The enforcement officer may have occasion to inspect the process out of
schedule because of complaints or violations. In these cases, he does
not make a formal inventory reinspection, but uses the copy of the previous
inventory record (equipment list) from his files as a check on status of
the permit, compliance, or other situation.
Overall Inspection Process
Some inspections, especially initial ones, are comprehensive, designed to
gather information on all equipment and processes of the plant. Others
are conducted for specific purposes such as:
• Obtaining information relating to violations
• Gathering evidence relating to violations
• Checking permit or compliance plan status of equipment
• Investigating complaints
• Following up on a previous inspection
• Obtaining emissions information by source testing
36
-------
The initial inspection has two phases: a plant survey and a physical
inspection of the equipment and processes. After this inspection is com-
plete, routine surveillance continues. Periodic reinspections are scheduled
and ocasional special purpose inspections (unscheduled) may be required.
During the initial survey, the inspector examines the possible effects of
emissions on property, persons and vegetation adjacent to the source; he
may also collect samples or specimens that exhibit possible pollution re-
lated damage. Sensory observations (odor detection) are also made.
An aid to the FED is the information incorporated in applications to operate
the equipment. The permit status of the equipment should be routinely
checked to detect any changes in equipment or process that might invalidate
an existing permit or conflict with variance conditons. Similarly, alter-
ation of equipment is frequently detected by discrepancies in the equipment
description or by changes noted on engineering applications in the permit
file.
Safety Equipment and Procedures
Most steel plants have standard safety procedures for employees and vistors.
These procedures also concern the FED. The FED is accompanied to the unit
or units to be inspected by the air pollution representative within the
plant or by such other informed plant personnel as he might indicate.
Personnel protection is necessary in many of the industrial locations that
an enforcement officer may be required to visit. The FEO should wear a
hard hat, safety glasses and flame retardant clothing while in the plant.
The FEO should be accompanied by another person and two parsons should re-
main together until the job is completed. Specific safety related rules
and precautions should be determined by the FEO before entering proceeding
or with any part of the inspection.
37
-------
OPERATING PARAMETERS TO BE CHECKED
The inspector should check specific operating parameters of the control
system, looking at both the system itself, and the operating and maintenance
records kept by the plant. A summary of what to look for is given below,
to supplement the inspection checklists presented in the next section.
More detailed information can be obtained from reference 3, a handbook for
operation and maintenance of control equipment.
Fabric Filter Collectors
A properly installed and operated baghouse requires a minimum of routine
maintenance based on recommendations furnished by the baghouse manufacturer
supplemented by operating experience. Visible emissions are indicative of
a faulty bag. Continuous, automatic monitoring and recording of opacity
will be required of new sources, but is not currently performed at most
plants. Faulty or leaking bags are also indicated by dust on the floor
of the clean side of the filter house; patches on the individual filter
bags are acceptable provided the hole is completely covered. The in-
spector should verify that an inventory of parts which are susceptible
to failure are kept on hand, particularly replacement bags.
Fans and blowers tend to be a problem area and periodic maintenance should
be scheduled to avoid equipment failure. Vibration noise probably indicates
an out-of-balance rotor and/or bad bearings, and is a precursor to an
equipment failure.
Hoods and collection points should be checked for ill-advised changes such
as holes cut in hoods, additional hoods added, ducts blocked off or intakes
moved away from the dust source.
Manometer records of the pressure drop across the fabric filter are espe-
cially revealing of baghouse performance, although continuous records are
38
-------
not typically kept on file. A high pressure drop indicates an increase in
flow, blinding of the filter, overfilled hoppers, and/or an inoperative
cleaning mechanism. A low pressure drop suggests fan problems, broken
or undamped bags, plugged inlet ducting or clogged valves, or leakage
between sections of the baghouse.
Wet Scrubbers
Malfunction of wet scrubbers rarely occurs in the scrubber itself since
most scrubbers have few or no moving parts, but the system as a whole
must be investigated regularly by the plant. The following points should
be checked and recorded in plant records each day, and should also be
3
evaluated by the inspector as he checks the scrubber system.:
• Reduction in scrubber recycle flow is an indication of pump im-
peller wear or line pluggage. Increase in scrubber recycle flow
indicates valve or nozzle erosion.
• Scrubber bleed flow reduction is usually associated with line
pluggage. Bleed increase can mean a worn valve.
• Scrubber pressure drop increase can be associated with plugging
of packing or an unexpected increase in gas or liquor flow.
• Pump discharge pressure increase at proper flow indicates a
line restriction - usually plugging.
• Fan inlet and outlet pressure can be used to check flow as
well as incorrect damper setting. Occasionally it may indicate
gas duct pluggage.
• Slurry bleed concentration is a check against instrument read-
ing associated with bleed flow rate.
• Fan vibration usually indicates buildup on the fan blades.
• Inlet temperature and saturation temperature are recorded
because of danger to equipment if saturation is not attained.
39
-------
• Motor currents are used to determine if flow decrease is
caused by impeller wear, line pluggage or simply an incorrect
flow meter setting. Fan current can be used as a measure of
gas flow.
• Auxiliary items are treated as above.
Electrostatic Precipitators
A properly designed and operated electrostatic precipitator (ESP) should
require a relatively low level of routine maintenance but this varies
considerably between individual units. Controls for ESP's should be checked
daily for sparking rate, electrical reading, and the ash handling system
should also be checked daily. Rapper functioning should be checked approx-
imately weekly. The plant should record the electrical readings for each
control unit on a daily basis, and these can be checked for abnormal
readings. A general assessment of these operating parameters can be made
by the inspector, while plant records should indicate the frequency of,
and problems discovered during these checks.
If an internal inspection is made, several items should be checked.
Interior corrosion may indicate either an air leak through the ESP housing,
or moisture carryover from the air heater washer. Discharge wire spacers
and hanger weights should be in place, and the wires should hang midway
between plates. Wires and electrodes should be examined to insure they
are not broken. Dust deposits on the plates greater than a quarter of an
inch indicate faulty rappers while a clean plate suggests that the section
is shorting out.
INSPECTION CHECKLIST
Data obtained during an inspection can be summarized on forms similar to
the ones shown on the following pages. The forms also serve as a record
of inspection.
40
-------
INSPECTION CHECK LIST FOR
ELECTRIC ARC FURNACES I
FACILITY IDENTIFICATION
Facility Name
Facility Address
Hailing Address
Telephone Number
Nature of Business
Date of Last Inspection
Responsible Person to
Contact
Persons Contacted at
Plant Site
Inspectors
Source Code Number
41
-------
INSPECTION CHECK LIST FOR
OPACITY OBSERVATIONS (II)
Observer's Name
Number of Observations
Duration of Observations
Average percent equivalent opacity from Method 9 Observation:
Control Equipment (Stack)
Shop Ventilators
During Charging
During Tapping
Dust Handling Equipment
42
-------
INSPECTION CHECK LIST FOR
PERFORMANCE TEST OBSERVATION (III)
Company Name: Date:
Plant Identification and Address: Performance Test By:
Plant Official: Crew Leader:
1) Cross-sectional duct dimensions at sampling location
(i) inside circular D rectangular
(ii) outside
2.1) Flow obstructions
(a) upstream from the sampling location
(b) downstream from the sampling location
2.2) Total no. of sampling points chosen
3) Moisture content
n assumed _ % moiscure
[] method 4
4) Inside nozzle diameter
5) Leak test
(i) Vacuum gage reading _ in Hg
(ii) Dry gas meter reading _ cf in _ sec
6) Impinger bubbles, yes _ no _
7) Gas Analysis Procedure No. of samples analyzed
8) Cleaning and Sample Recovery, Adequate _ Careless
9) Calibration check Date calibrated
(i) pitot tube _
(ii) thermometer /thermocouple _
(iii) dry gas meter _
(iv) orifice diameter _
(v) nozzle diameter _
43
-------
INSPECTION CHECK LIST FOR
THE OPERATION OF THE ELECTRIC ARC FURNACE (IV)
Initial Charge Time and Duration Weight Composition Comments
Charging * * *
Opening of any
furnace doors * __
Additions (Alloy,
lime, etc) *
Remove Slag *
Second Charge and/or Subsequent Charges
Back Charging * ^_
Opening of any
furnace doors *
Additions (Alloy,
lime, etc) * * *
Oxygen Lance
Tapping
44
-------
INSPECTION CHECK LIST FOR
THE FUME COLLECTION SYSTEM (V)
Type of System(s)
Direct Shell Evacuation (4th Hole)
Side Draft Hood
Combination Hood
Canopy Hood
Building Evacuation
Pressure in Furnace Shell (Combination
and 4th Hole)
Average
Automatic Control Setting
Flow Rate (Total)3
Furnace (If separate)
Shop (If separate)
Spark Box
Wet
Water Injection Rate
Dry
a
If the flow of the fume capture system is cyclic in nature, note the time
and duration of the cycle.
45
-------
INSPECTION CHECK LIST FOR
FABRIC FILTER COLLECTORS (VI)
Design Air to Cloth Ratio
Operating Air to Cloth Ratio
Pressure Drop Across Baghouse
Cleaning Cycle Time
Type of Cleaning
a) shaking
b) reverse air
c) pulse jet
d) combination
Inlet temperature
46
-------
INSPECTION CHECK LIST FOR
SCRUBBERS (VII)
Pressure Drop
Water Injection Rate
Water Recycle Rate
Water Make-up Rate
Inlet Temperature
Throat Control Setting (if venturi)
47
-------
INSPECTION CHECK LIST FOR
ELECTROSTATIC PRECIPITATORS (VIII)
Inlet Temperature
Voltage Measurements and Regulation
Amperage Measurements and Regulation
Rapper Timing (Internal and Duration)
Sparking Rate
n
Internal Inspection If Necessary
Evidence of Corrosion
Check for Broken Electrodes
Condition of Collection Plates or Tubes
Alignment of Plates
Condition of Rapping Mechanism
a
Internal inspection only possible if ESP is shut down.
48
-------
INSPECTION FOLLOW-UP PROCEDURES
After the completion of the inspection, the FEO must determine the compli-
ance status of the source. If an inspection indicates that a source is not
operating in compliance with applicable regulations, the FEO should follow
the established Agency procedures regarding notice of violation, request
for source test, and related matters.
The inspector's findings during his inspection of the plant should be
briefly conveyed to the plat official at the site before leaving the pre-
mises. Specific violation decisions should neither be made nor discussed
in the field.
The inspector should, within 48 hours after the inspection, complete his
report on the inspection. This report will consist of updated forms and
recommended action and should be forwarded to the supervisor.
Decisions for subsequent action should be made in a conference with the
supervisor- If the inspection revealed that the plant was operating
normally and if the decision requires no further action, the report should
be filed in the source file for future reference.
The FEO checks to ensure that permits have been granted for all applicable
processes and equipment and their modifications. For any later public
complaints, he determines cause of complaint, records pertinent data,
issues violation notices if appropriate, and ascertains adequacy of plans
for prevention of future accidents. He periodically reviews emergency
procedures plans. He makes sure that all shutdown procedures are being
implemented during periods of process curtailment. He coordinates with
other agencies participating in pollution reduction effort. As a part of
inspection followup procedures, he also checks to see that engineering,
procurement, he also checks to see that engineering, proceeding according
to the approved plan.
49
-------
If the inspection revealed a significant change in plant operation, and
if the decision is to require a new performance test, the plant official
should be so informed in writing.
If the inspection revealed a violation of the opacity standard, then the
decision may be to issue an order requiring compliance with the standard.
If the inspection revealed a violation of the opacity standard and if the
plant official has claimed an unavoidable malfunction as a reason, then
the decision should be to advise the plant operator of the recordkeeping
requirements of 40 CFR 60.7, and followup inspection should be planned,
prior to any other action.
50
-------
REFERENCES
1. Inspection Manual for the Enforcement of New Source Performance
Standards: Asphalt Concrete Plants. U.S. Environmental Protection
Agency, Division of Stationary Source Enforcement. June 1975.
2. Inspection Manual for the Enforcement of New Source Performance
Standards: Catalytic Cracking Regenerators. U.S. Environmental
Protection Agency, Division of Stationary Source Enforcement.
March 1976.
3. Cross, Frank L. Jr. and H. E. Hesketh. Handbook for the Operation
and Maintenance of Air Pollution Control Equipment. Technomic
Publishing Co., Inc., Westport, Conn. 1975.
51
-------
SECTION V
PERFORMANCE TEST 1,2
The NSP Standards require a performance test of any new or modified EAF
In order to guarantee the validity of the test, an inspection team will
be present at the facility for observation. The team should consist of
three enforcement personnel with the following areas of responsibility
during the test period:
• Monitor process operating conditions from the control room.
o Make visible observations of opacity and process operations
from the plant area.
• Monitor emission testing procedures from the test site.
Each team member will fill out check list type data during the test
and will submit a report including analysis of the data and indication
of any upset conditions which may have affected the test.
PROCESS OPERATING CONDITIONS
For the purpose of obtaining source test data which is truly representative
of the operating characteristics of the EAF being tested, it is extremely
important that the test be conducted at or above the maximum production
rate at which the particular unit will normally be operated. In certain
cases, the EPA may feel that conditions other than the maximum production
operating rate of the unit should be used to achieve valid test results.
In such cases, the EPA will specify the conditions at which source testing
must take place. In all cases, inspectors must personally verify that the
52
-------
unit is operating at the specified conditions. Such verification should
be made with unit operator and plant manager, and inspectors should
observe process controls (i.e., gauges, rate meters, and recorders) to
determine that operating conditions are as specified. Inspectors
should periodically check operating conditions of the EAF and control
equipment throughout the test, noting changes in operating parameters
such as temperature, pressure, flow rate, and type and quantity of each
charge.
Inspectors should be careful to note that the sampling is being performed
at the proper location(s) in the system, namely at the exit of the control
device. The location and operation of dampers which may allow dilution
air into the system should be observed and noted, to be sure that their
operation does not interfere with the test. Often a baghouse will have
a provision for the automatic introduction of cold dilution air to protect
the bags from temperature excursions which could damage the bags. In the
event of this occurance the test would be invalid, therefore the observer
should be sure that the dilution air system is not engaged during a test.
Since the NSPS for the EAF also apply to shop emissions from the EAF, it
is very important that shop emissions due to only the EAF are measured.
Most shops housing an EAF also contain areas where other processes are
performed, such as pouring from the ladle into ingots or smaller molds.
In order to assure that non EAF related emissions do not contribute to
test observations it is necessary that the observer carefully note the
time of charging and tapping the EAF. It would be advisable to have the
observer explain to the owner or operator the potential for mixed emissions
being observed as coming from the EAF, so that the owner or operator can
schedule all operations causing emissions into the shop so as not to coin-
cide with periods of EAF shop emissions. Only direct EAF emissions are
considered under the NSPS.
53
-------
PROCESS OBSERVATIONS
The pollutants generated by an EAT which are limited in the NSPS are
particulate matter as it exits the control equipment, and as it escapes
the furnace and capture system in the form of visible emissions. The
regulations apply to the EAF, the fume collection system, the shop
housing them, the particulate control equipment, and the dust-handling
equipment. The NSPS apply to the concentration of particulate emissions
exiting the particulate control device(s) and its opacity, as well as
the opacity of the emissions from the shop and dust handling equipment.
At the time of the performance test, the inspector should carefully
note the existing layout of the EAF, fume capture system, and control
equipment as well as the operating range parameters of the unit. The
control equipment is particularly important as well as the type of
scrap being charged to the EAF, since subsequent source performance
testing will be affected by any modifications in this equipment. The
inspector should note the type, size, and model of the particulate
collector, as well as the method and schedule for bag cleaning, the
voltage for electrostatic precipitators, or the pressure drop and
water consumption for a scrubber. If possible a photographic record
should be made of at least the control equipment and possibly the fume
capture system.
EMISSION TEST OBSERVATIONS
Emission source testing discussed here concerns determining compliance
of new sources with EPA New Source Performance Standards. During the
source testing operations, field inspectors should periodically spot
check testing procedures, equipment, and data to make certain that the
test is valid.
54
-------
All performance tests should be conducted while the unit being tested is
operating at or above maximum production rate at which the unit will normally
be operated. If the EPA Administrator feels that other conditions should
be used to achieve valid test results, such conditions will be used as
basis for testing.
Traversing (EPA Method No.l)
Of first importance is the selection of a sampling point and determination
of the minimum number of traverse points to ensure the collection of a
representative sample. Inspectors should make certain that the sampling
site selected is a minimum of eight (8) diameters downstream and at least
two (2) diameters upstream from any disturbance to the flow of gases
within the duct or stack which is being sampled. Such disturbances are
commonly caused by expansions or contractions, bends, observable cross
members, or other entering ducts.
Stack or Duct Gas Velocity Determination (EPA Method No. 2)
In the determination of gas velocity within the duct or stack, the
inspector should be certain that all data from each traverse point is
carefully and accurately recorded, as this is the basic information used
to determine the isokinetic sampling rate. Each point shall be identified
by a number and the following information shall be recorded for each
point: Velocity head in inches of water, stack (duct) pressure in inches
of mercury, and temperature (unless the total temperature variation with
time is less than 10°C)• Care should be taken to determine that a type
"S" pitot tube is used to obtain the velocity head readings and that this
tube is of sufficient length to reach all traverse points. The pitot tube
should be graduated with temporary markings (i.e., tape or chalk marks)
such that each traverse point may be reached by successively moving the
tube deeper into or withdrawing it further from the duct or stack being
sampled. All tubing and connectors between the pitot tube and the inclined
55
-------
manometer or draft gauge should be tight and leak-free. An inclined
manometer or draft gauge should be used to obtain velocity head readings
from the pitot tube. Make certain that this gauge is filled with suffi-
cient colored liquid to give readings throughout its range of calibration,
and that the manometer liquid level is adjusted to read "zero" with the end
of the pitot tube shielded from incidental breezes, prior to beginning the
velocity head measurement. Periodically check to make sure that no con-
striction occurs in the hose connections during the course of the velocity
head measurement.
The most common means of stack temperature measurement is by thermocouple
and potentiometer; operation of this equipment is rather straight-forward
although several points should be checked to ensure accurate measurement.
The thermocouple connecting wires should be securely tightened to the
terminal lugs on the potentiometer, and it should be determined that the
thermocouple circuit is complete (an open circuit will be evident if the
potentiometer fails to balance, giving readings off the scale of the
instrument). If the potentiometer being used is not an automatic compen-
sating type (automatic reference to ambient temperature), see that the
ambient air temperature has been recorded or that the potentiometer scale
has been calibrated with this temperature as a reference. While taking
gas temperature readings, sufficient time should be allowed (normally
about five minutes) for the thermocouple probe to reach thermal equilib-
rium with the duct gas before taking the first few readings.
As part of the data necessary for the velocity determination, the static
pressure within the stack or duct should be measured. This is done using
a mercury filled "U" tube manometer, one end of which is open to the
atmosphere and the other connected to a probe extending into the duct
or stack itself. Again, the tubing from the probe to the manometer must
be free of constrictions and tightly connected at both ends. A barometric
pressure reading (of atmospheric pressure) in inches of mercury, should be
obtained from a standard barometer located in the general vicinity of the
56
-------
test site; this can be a wall mounted barometer in the plant offices,
laboratory, or any convenient location which is at ambient temperature
and free of vibration.
Gas Analysis (EPA Method No. 3)
Two methods of sampling are acceptable in obtaining an analysis of the
gases within a duct or stack: grab sampling and integrated sampling. In
the grab sampling method, the gases are drawn through a probe directly
into an Orsat type analyzer- If grab sampling is used, inspectors should
make sure that the sampling probe is of pyrex or stainless steel (316)
construction and that a small piece of glass wool has been loosely inserted
in the end of the probe to stop particles. A flexible tubing is used to
connect the probe with the analyzer, however, there must be some provision
for purging the line; most often a oneway squeeze bulb is used. During
analysis using the Orsat, notice that care is being taken to equalize the
liquid levels with the leveling bottle when readings are taken, and that
the efficiencies of the absorbing solutions are such that no more than
ten (10) passes are required to achieve constant readings (usually three
to five passes will produce a constant reading).
The integrated sampling method utilizes the same type of probe, but requires
an air-condenser to remove moisture, as well as a valve, pump, and rota-
meter in line between the probe and sample. If the velocity of the gas
varies with time or if a "sample traverse" is taken, a type "S" pitot
tube may be used along with the probe so that the sampling rate can be
kept proportional to the gas velocity. The rotameter should have a flow
range from 0 to 0.001 cubic meters/min. In operation, the sampling line
is purged using the pump and the pre-evacuated flexible sample bag is
attached to the system via a quick disconnect coupling. Sampling is
carried out at a rate proportional to the gas velocity using the rotameter
as a guide and the valve for control. The sample bag should be sufficiently
large enough to obtain a sample of about 0.232 to 0.786 cubic meters.
57
-------
Again, all connections must be leak-free. After sampling is complete,
the bag is transferred to an Orsat apparatus for analysis. Gas analysis
must be performed whenever a determination of particulate matter (Method 5),
sulfur dioxide (Method 6), or carbon monoxide (Method 10) is carried out.
Particulate Matter (EPA Method No. 5)
When sampling for particulate matter according to EPA Method 5, the mini-
mum sampling volume will be 4.5 dscm (160 dscf) and the sampling period
will be at least 4 hours. When a single EAF is sampled, the sampling time
for each run shall also include an integral number of heats. Shorter
sampling times may only be used if previously approved by the Administrator.
During the sampling operation, the inspector should check the probe to
make sure that it is either pyrex or stainless steel (316) to ensure non-
reactivity of the probe material with either the gas stream or the sample
being collected. These materials are selected also because of their
resistance to distortion at elevated temperature. The probe nozzle must
be pointed opposed to the direction of gas flow while sample is being
collected, and a type "S" pitot tube must be attached to it in order to
monitor the gas velocity. Check to determine that the probe heater is
working (about 120°C at the probe outlet), and that a fresh filter was
placed in the filter holder before beginning the test. The filter-
heating system must also be operating.
The impinger box must be filled with an ice and water bath and there should
be an additional supply of ice on hand to maintain the bath cold enough so
that the impinger temperature remains at 21°C or less throughout the test.
Four Greenburg-Smith type impingers are placed in series in the ice bath
and connected by means of ball and socket joints. All glassware should
be clean and the ball joints should be snugly connected and secured with
the proper size metal spring clamp. Note that the second impinger in the
series has the conventional impingement nozzle, but that all others have
the straight glass tubing extending to 1/2 inch from the bottom. The first
58
-------
two impingers in the series have exactly 100 ml of water each (measured
by graduated cylinder); the third is empty, and the fourth must contain
200 grams (pre-weighted) of silica gel, preferably the indicating type.
A thermometer should be placed in or just after the fourth impinger,
followed by a check valve to prevent reverse- flow surges. From this
point the line should contain the following components: vacuum gauge,
with temperature dials at inlet and outlet, and an orifice meter connected
to an inclined manometer, respectively.
Check to make sure that all gauges and temperature dials are operating
properly, and that all appropriate valves are in the open position
(bypass will normally remain closed) , that pump and test meter are
correctly functioning, and be sure that connecting lines are attached to
their proper inlets and outlets - reverse order is a common mistake here.
Both pitot and orifice manometers should be checked out as previously
described.
The following information should be recorded from the data sheets for
purpose of spot-checking the accuracy of the calculated final results.
(a) Average velocity, cm
(b) Average gas temperature, °C
(c) Static pressure in duct or stack, mm Hg
(d) Barometric pressure, mm Hg
(e) Diameter or width and height of duct or stack
(f) Sampling time (start and finish)
(g) Average pressure differential across orifice meter
(h) Gas sample volume
(i) Gas sample temperature at dry gas meter (average for inlet and
for outlet)
59
-------
(j) Impinger bath temperature, °C
o
(k) Impinger temperature, C
(1) Volume of condensate collected in impingers, ml
Opacity (EPA Method 9)
Measurement of opacity must be performed in accordance with EPA Method 9
and will require a trained observer to locate a suitable site from which
to observe the opacity of the particulate emission control equipment, the
shop, and the dust handling equipment. The opacity observation sites
should be chosen before the actual date of the compliance test. It will
also be necessary for the observer to coordinate the time of observations
with the actual time of the process operations, since emissions from the
shop are allowed to be significantly higher during charging and tapping.
The timing of the opacity observations is critical to the determination
of compliance of the EA.F and related control equipment with the NSPS.
Emission Monitoring
Since continuous emission source monitoring is required for opacity of
particulate materials, inspection must be made of monitoring instruments
to determine that they are properly installed and operating, and that
proper calibration and maintenance procedures are being followed.
For particulate emission monitoring the photoelectric monitor may be used.
This essentially measures the opacity or optical density of a stream of
gases. Characteristically such installations are in widespread use and
operate on the principal that particulate matter, in a gas" stream, will
interrupt a beam of light (between source and detector) in proportion to
its concentration in the gas stream. In practice the system consists of
a light source, a detector (photo-multiplier tube), and a recorder.
Often an alarm feature is incorporated in the system to sound when the
opacity reaches a predetermined level. These systems work well if
60
-------
maintenance and calibration are performed on a regular and thorough basis.
It should be determined that: calibration is frequently performed, optical
surfaces are kept clean and in proper repair, proper alignment of source
and detector is maintained, and that recorder and alarm systems are in good
working order. Variations exist between many different suppliers of such
opacity metering systems, however, the principle involved as well as the
operating problems are basically alike for these systems in general.
Some systems may have both the source and detector on the same side of the
stack, utilizing reflectance to return the light beam. Calibration and
zeroing is quite a problem while the plant is operating; one technique
often employed uses a sliding tube to connect the source and detector and
thus exclude the gas stream from the beam path for calibration.
Source monitoring installations should be free from vibration, shock, and
excessive heat, should be weathertight and so placed as to provide safe
and convenient access for calibration purposes.
61
-------
REFERENCES
1. Inspection Manual for the Enforcement of New Source Performance
Standards: Asphalt Concrete Plants. U.S. Environmental Protection
Agency, Division of Stationary Source Enforcement. June 1975.
2. Inspection Manual for the Enforcement of New Source Performance
Standards: Catalytic Cracking Regenerators. U.S. Environmental
Protection Agency, Division of Stationary Source Enforcement.
March 1976.
62
-------
APPENDIX A
PART 60 - STANDARDS OF PERFORMANCE
FOR NEW STATIONARY SOURCES
ELECTRIC ARC FURNACES IN THE STEEL INDUSTRY
63
-------
43850
Title 40—Protection of Environment
CHAPTER I—ENVIRONMENTAL
PROTECTION AGENCY
SUBCHAPTER C—AIR PROGRAMS
[FBL 407-3]
PART 60—STANDARDS OF PERFORM-
ANCE FOR NEW STATIONARY SOURCES
Electric Arc Furnaces in the Steel Industry
On October 21, 1974 (39 PR 37466),
under section 111 of the Clean Air Act,
as amended, the Environmental Protec-
tion Agency (EPA) proposed standards
of performance for new and modified
electric arc furnaces in the steel industry.
Interested persons participated in the
rulemaking by submitting written com-
ments to EPA. A total of 19 comment let-
ters was received, seven of which came
from the industry, eight from State and
local air pollution control agencies, and
four from Federal agencies. The Free-
dom of Information Center, Room 202
West Tower, 401 M Street, 8.W., Wash-
ington, D.C., has copies of the comment
letters received and a summary of the
Issues and Agency responses available for
public inspection. In addition, copies 6f
the issue summary and Agency responses
may be obtained upon written request
from the EPA Public Information Cen-
ter (PM-215), 401 M Street, S.W., Wash-
ington, D.C. 20460 (specify—Public
Comment Summary: Electric Arc Fur-
naces in the Steel Industry). The com-
ments have been carefully considered,
and where determined by the Adminis-
trator to be appropriate, changes have
been made to the proposed regulation
and are incorporated in the regulation
promulgated herein.
The bases for the proposed standards
are presented in "Background Informa-
tion for Standards of Performance:
Electric Arc Furnaces In the Steel In-
dustry," (EPA-450/2-74-017a, b). Copies
of this document are available on request
from the Emission Standards and En-
gineering Division, Environmental Pro-
tection Agency, Research Triangle Park,
N.C. 27711, Attention: Mr. Don R.
Goodwin.
SUMMARY OP REGULATION
The promulgated standards of per-
formance for new and modified electric
arc furnaces in the steel industry
limit participate matter emissions from
the control device, from the shop, and
from the dust-handling equipment.
Emissions from the control device are
limited to less than 12 mg/dscm (0.0052
gr/dscf) and 3 percent opacity. Furnace
emissions escaping capture by the collec-
tion system and exiting from the shop
are limited to zero percent opacity, but
emissions greater than this level are
allowed during charging periods and
tapping periods. Emissions from the
dust-handling equipment are limited to
less than 10 percent opacity. The regula-
tion requires monitoring of flow rates
through each separately ducted emission
capture hood and monitoring of the
pressure inside the electric arc furnace
for direct shell evacuation systems. Ad-
RULES AND REGULATIONS
diUonally, continuous monitoring of
opacity of emissions from the control de-
vice is required.
SIGNIFICANT COMMENTS AND CHANGES
MADE TO THE PROPOSED REGULATION
All of the comment letters received by
EPA contained multiple comments. The
most significant comments and the dif-
ferences between the proposed and pro-
mulgated regulations are discussed below.
In addition to the discussed changes, a
number of paragraphs and sections of
the proposed regulation were reorganized
In the regulation promulgated herein.
(1) Applicability. One commentator
questioned whether electric arc furnaces
that use continuous feeding of prere-
duced ore pellets as the primary source
of Iron can comply with the proposed
standards of performance since the
standards were based on data from con-
ventionally charged furnaces. Electric
arc furnaces that use prereduced ore
pellets were not investigated by EPA
because this process was still being re-
searched by the steel Industry during
development of the standard and was
several years from extensive use on com-
mercial sized furnaces. Emissions from
this type of furnace are generated at
different rates and in different amounts
over the steel production cycle than
emissions from conventionally charged
furnaces. The proposed standards were
structured, for the emission cycle of a
conventionally charged electric arc
furnace. The standards, consequently,
are not suitable for application to electric
arc furnaces that use prereduced ore
pellets as the primary source of iron.
Even with use of best available control
technology, emissions from these fur-
naces may not be controllable to the level
of all of the standards promulgated
herein; however, over the entire cycle the
emissions may be less than those from
a well-controlled conventional electric
arc furnace. Therefore, EPA believes that
standards of performance for electric arc
furnaces using prereduced ore pellets
require a different structure than do
standards for conventionally charged
furnaces. An Investigation into the emis-
sion reduction achievable and best avail-
able control technology for these fur-
naces will be conducted in the future and
standards of performance will be estab-
lished. Consequently, electric arc fur-
naces that use continuous feeding of pre-
reduced ore pellets as the primary source
of iron are not subject to the require-
ments of this subpart.
(2) Concentration standard for emis-
sions from the control device. Four com-
mentators recommended revising the
concentration standard for the control
device effluent to 18 mg/dscm (0.008 gr/
dscf) from the proposed level of 12 mg/
dscm (0.0052 gr/dscf). The argument for
the higher standard was that the pro-
posed standard had not been demon-
strated on either carbon steel shops or on
combination direct shell evacuation-
canopy hood control systems. Emission
measurement data presented in "Back-
ground Information for Standards of
Performance: Electric Arc Furnaces in
the Steel Industry" show that carbon
steel shops as well as alloy steel shops
can reduce partlculate matter emissions
to less than 12 mg/dscm by application
of well-designed fabric filter collectors.
These data also show that combination
direct shell evacuation-canopy hood sys-
tems can control emission levels to less
than 12 mg/dscm. EPA believes that re-
vising the standard to 18 mg/dscm would
allow relaxation of the design require-
ments of the fabric filter collectors which
are installed to meet the standard. Ac-
cordingly, the standard promulgated
herein limits particulate matter emis-
sions from the control device to less than
12 mg/dscm.
Two commentators requested that spe-
cific concentration and opacity stand-
ards be established for emissions from
scrubber controlled direct shell evacua-
tion systems. The argument for a sep-
arate concentration standard was that
emissions from scrubber controlled direct
shell evacuation systems can be reduced
to only about 50 mg/dscm (0.022 gr/
dscf) and, thus, even with the proposed
proration provisions under § 60.274(b),
it is not possible to use scrubbers and
comply with the proposed concentration
standard. The commentators also argued
that a separate opacity standard was
necessary for scrubber equipped systems
because the effluent is more concentrated
and, thus, reflects and scatters more vis-
ible light than the effluent from fabric
filter collectors.
EPA would like to emphasize that use
of venturi scrubbers to control the efflu-
ent from direct shell evacuation systems
Is not considered to be a "best system of
emission reduction considering costs."
The promulgated standards of perform-
ance for electric arc furnaces reflect
the degree of emission reduction achiev-
able for systems discharging emissions
through fabric filter collectors. EPA be-
lieves, however, that the regulation does
not preclude use of control systems that
discharge direct shell evacuation system
emissions through venturi scrubbers.
Available information indicates that
effluent from a direct shell evacuation
system can be controlled to 0.01 gr/dscf
or less using a high energy venturi scrub-
ber (pressure drop greater than 60 in.
w.g.). If the scrubber reduces particulate
matter emissions to 0.01 gr/dscf, then the
fabric filter collector Is only required to
reduce the emissions from the canopy
hood to about 0.004 gr/dscf in order for
the emission rates to be less than 0.0052
gr/dscf. Therefore, it is technically feasi-
ble for a facility to use a high energy
scrubber and a fabric filter to control the
combined furnace emissions to less than
0.0052 gr/dscf. A concentration standard
of 0.022 gr/dscf for scrubbers would not
require installation of control devices
which have a collection efficiency com-
parable to that of best control technology
(well-designed and well-operated fabric
filter collector). In addition, electric arc
furnace particulate matter emissions are
Invisible to the human eye at effluent
concentrations less than 0.01 gr/dscf
64
FEDERAL REGISTER, VOl. 40, NO. 185—TUESDAY, SEPTEMBER 23, 1975
-------
RULES AND REGULATIONS
43851
when emitted from average diameter
stacks. For the reasons discussed above,
neither a separate concentration stand-
ard nor a separate opacity standard will
be established as suggested by'the com-
mentators.
(3) Control device opacity standard.
Four commentators suggested that the
proposed control device opacity stand-
ard either be revised from less than five
percent opacity to less than ten percent
opacity based on six-minute average val-
ues or that a time exemption be provided
for visible emissions during the cleaning
cycle of shaker-type fabric filter collec-
tors.
EPA's experience indicates that a time
exemption to allow for puffing during
the cleaning cycle of the fabric filter col-
lector is not necessary. For this appli-
cation, a well-designed and well-main-
tained fabric filter collector should have
no visible emissions during all phases of
the operating cycle. The promulgated
opacity standard, therefore, does not pro-
vide a time exemption for puffing of the
collector during the cleaning'cycle..
The suggested revision of the proposed
opacity standard to ten percent (based on
six-minute average values) was con-
sidered in light of recent changes in
Method 9 of Appendix A to this part~(39
FR 39872). The revisions to Method 9
require that compliance with opacity
standards be determined by averaging
sets of 24 consecutive observations taken
at 15-second intervals (six-minute aver-
ages). All six-minute average values of
the opacity data used as the basis for
the proposed opacity standard are zero
percent. EPA believes that the ten per-
cent standard suggested by the com-
mentators would allow much less effec-
tive operation and maintenance of the
control device than is required by the
concentration standard. On the basis of
available data, a five percent opacity
standard (based on six-minute average
values) also is unnecessarily lenient.
The proposed opacity standard of zero
percent was revised slightly upward to be
consistent with previously established
opacity standards which are less strin-
gent than their associated concentration
standards without being unduly lax. The
promulgated opacity standard limits
emissions from the control device to less
than three percent opacity (based on
averaging sets of 24 consecutive observa-
tions taken at 15-second intervals). Use
of six-minute average values to deter-
mine compliance with applicable opacity
standards makes opacity levels of any
value possible, Instead of the previous
method's limitation of values at discrete
intervals of five percent opacity.
(4) Standards on emissions from the
shop. Twelve commentators questioned
the value of the shop opacity standards,
arguing that the proposed standards
are unenforceable, too lenient, or too
stringent.
Commentators arguing for less strin-
gent or more stringent standards sug-
gested various alternative opacity values
for the charging or tapping period stand-
ards, different averaging periods, and a
different limitation on emissions from the
shop during the meltdown and refining
period of the EAF operation. Because of
these comments, the basis for these
standards was thoroughly reevaluated,
including a review of all available data
and follow-up contacts with commenta-
tors who had offered suggestions. The
follow-up contacts revealed that the sug-
gested revisions were opinions only and
were not based on actual data. The re-
evaluation of the data bases of the pro-
posed standards reaffirmed that the
standards represented levels of emission
control achievable by application of best
control technology considering costs.
Hence, EPA concluded that the standards
are reasonable (neither too stringent nor
too lenient) and that revision of these
standards is not warranted in the ab-
sence of specific information indicating
such a need.
Four commentators believed that the
proposed standards were impractical to
enforce for the following reasons:
(1) Intermingling of emissions from
non-regulated sources with emissions
from the electric arc furnaces would
make enforcement of the standards
impossible.
(2) Overlap of operations at multi-
furnace shops would make it difficult to
identify the periods in which the charg-
ing and tapping standards are applicable.
(3) Additional manpower would be
required in order to enforce these
standards.'
(4) The standards would require ac-
cess to the shop, providing the source
with notice of surveillance and the re-
sults would not be representative of rou-
tine emissions.
(5) The standards would be unen-
forceable at facilities with a mixture of
existing and new electric arc furnaces
in the same shop.
EPA considered all of the comments on
the enf orceability of the proposed stand-
ards and concluded that some changes
were appropriate. The proposed regula-
tion was reconsidered with the intent of
developing more enforceable provisions
requiring the same level of control. This
effort resulted in several changes to the
regulation, which are discussed below.
The promulgated regulation retains the
proposed limitations on the opacity of
emissions exiting from the shop except
for the exemption of one minute/hour
per EAF during the refining and melt-
down periods. The purpose of this ex-
emption was to provide some allowance
for puffs due to "cave-ins" or addition of
iron ore or burnt lime through the slag
door. Only one suspected "cave-In" and
no puffs due to additions occurred during
15 hours of observations at a well-con-
trolled facility; therefore, it was con-
cluded that these brief uncontrolled puffs
do not occur frequently and whether or
not a "cave-in" has occurred is'test eval-
uated on a case-by-case basis. This ap-
proach was also necessitated by recent
revisions to Method 9 (39 FE 39872)
which require basing compliance on six-
minute averages of the observations. Use
of six-minute averages of opacity read-
Ings is not consistent with allowing a
time exemption. Determination of
65
whether brief puffs of emissions occur-
ring during refining and meltdown pe-
riods are due to "cave-ins" will be made
at the time of determination of compli-
ance. If such emissions are considered to
be due to a "cave-in" or other uncontroll-
able event, the evaluation may be re-
peated without any change in operating
conditions.
The purpose of the proposed opacity
standards limiting the opacity of emis-
sions from the shop was to require good
capture of the furnace emissions. The
method for routinely enforcing these
capture requirements has been revised
in the regulation promulgated herein in
that the owner or operator is now re-
quired to demonstrate compliance with
the shop opacity standards just prior to
conducting the performance test on the
control device. This performance evalua-
tion will establish the baseline operating
flow rates for each of the canopy hoods
or other fume capture hoods and the
furnace pressures for the electric arc fur-
nace using direct shell evacuation sys-
tems. Continuous monitoring of the flow
rate through each separately ducted con-
trol system is required for each electric
arc furnace subject to this regulation.
Owners or operators of electric arc fur-
naces that use a direct shell evacuation
system to collect the refining and melt-
down period emissions are required to
continuously monitor the pressure inside
the furnace free space. The flow rate and
pressure data will provide a continuous
record of the operation of the control
systems. Facilities that use a building
evacuation system for capture and con-
trol of emissions are not subject to the
flow rate and pressure monitoring re-
quirements if the building roof is never
opened.
The shop opacity standards promul-
gated herein are applicable only during
demonstrations of compliance of the af-
fected facility. At all other times the
operating conditions must be maintained
at the baseline values or better. Use of
operating conditions that will result in
poorer capture of emissions constitutes
unacceptable operation and maintenance
of the affected facility. These provisions
of the promulgated regulation will allow
evaluation of the performance of the col-
lection system without interference from
other emission sources because the non-
regulated sources can be shut down for
the duration of the evaluation. The moni-
toring of operations requirements will
simplify enforcement of the regulation
because neither the enforcing agency1-
nor the owner or operator must show
that any apparent violation was or was
not due to operation of non-regulated
sources.
The promulgated regulation's monitor-
ing of operation requirements will add
negligible, additional costs to the total
cost of complying with the promulgated
standards of performance. Flow rate
monitoring devices of sufficient accuracy
to meet the requirements of § 60.274(b)
can be installed for $600-$4000 depend-
ing on the flow profile of the area being
monitored and the complexity of the
monitoring device. Devices that monitor
FEDERAL REGISTER, VOL. 40, NO. 185—TUESDAY, SEPTEMBER 23, 197S
-------
43852
RULES AND REGULATIONS
the pressure Inside the free space of an
electric arc furnace equipped with a di-
rect shell evacuation system are installed
by most owners or operators in order to
obtain better control of the furnace oper-
ation. Consequently, for most owners or
operators, the pressure monitoring re-
quirements will only result in' the addi-
tional costs for installation and operation
of a strip chart recorder. A suitable strip
chart recorder can be installed for less
than $600.
There are no data reduction require-
ments in the flow rate monitoring pro-
visions. The pressure monitoring pro-
visions for the direct shell evacuation
control systems require recording of the
pressures as 15-minute integrated aver-
ages. The pressure inside the electric arc
furnace above the slag and metal fluctu-
ates rapidly. Integration of the data over
15-minute periods is necessary to provide
an Indication of the operation of the sys-
tem. Electronic and mechanical integra-
tors are available at an initial cost of less
than $600 to accomplish this task. Elec-
tronic circuits to produce a continuous
Integration of the data can be built di-
rectly into the monitoring device or can
be provided as a separate modular com-
ponent of the monitoring system. These
devices can provide a continuous inte-
grated average on a strip chart recorder.
(5) Emission monitoring. Three com-
mentators suggested deletion of the pro-
posed opacity monitoring requirements
because long path lengths and multiple
compartments In pressurized fabric filter
collectors make monitoring infeasible.
The proposed opacity monitoring require-
ments have not been deleted because
opacity monitoring is feasible on the con-
trol systems of interest (closed or suction
fabric filter collectors). This subpart also
permits use of alternative control sys-
tems which are not amenable to testing
and monitoring using existing proce-
dures, providing the owner or operator
can demonstrate compliance by alterna-
tive methods. If the owner or operator
plans to install a pressurized fabric filter
collector, he should submit for the Ad-
ministrator's approval the emission test-
ing procedures and the method of mon-
itoring the emissions of the collector. The
opacity of emissions from pressurized
fabric filter collectors can be monitored
using present instrumentation at a rea-
sonable cost. Possible alternative methods
for monitoring of emissions from pres-
surized fabric filter collectors include:
(1) monitoring of several compartments
by a conventional path length transmis-
someter and rotation of the transmis-
someter to other groups of collector com-
partments on a scheduled basis or (2)
monitoring with several conventional
path length transmissometers. In addi-
tion to monitoring schemes based on con-
ventional path length transmissometers,
a long path transmissometer could be
used to monitor emissions from a pres-
surized fabric filter collector. Transmis-
someters capable of monitoring distances
up to 150 meters are commercially avail-
able and have been demonstrated to ac-
curately monitor opacity. Use of long
path transmissometers on pressurized
fabric filter collectors has yet to be dem-
onstrated, but if properly installed there
is no reason to believe that the transmis-
someter will not accurately and repre-
sentatively monitor emissions. The best
location for a long path transmissometer
on a fabric filter collector will depend on
the specific design features of both;
therefore, the best location and monitor-
ing procedure must be established on an
individual basis and is subject to the
Administrator's approval.
Two commentators argued that the
proposed reporting requirements would
result in excessive paperwork for the
owner or operator. These commentators
suggested basing the reporting require-
ments on hourly averages of the moni-
toring data. EPA believes that one-hour
averaging periods would not produce
values that would meaningfully relate to
the operation of the fabric filter collec-
tor and would not be useful for com-
parison with Method 9 observations. In
light of the revision of Method 9 to base
compliance on six-minute averages, all
six-minute periods in which the average
opacity is three percent or greater shall
be reported as periods of excess emis-
sions. EPA does not believe that this re-
quirement will result in an excessive
burden for properly operated and main-
tained facilities.
(6) Test methods and procedures.
Two commentators questioned the pre-
cision and accuracy of Method 5 of Ap-
pendix A to this part when applied to gas
streams with particulate matter con-
centrations less than 12 mg/dscm. EPA
has reviewed the sampling and analytical
error associated with Method 5 testing
of low concentration gas streams. It was
concluded that if the recommended
minimum sample volume (160 dscf) is
used, then the errors should be within
the acceptable range for the method.
Accordingly, the recommended minimum
sample volumes and times of the pro-
posed regulation are being promulgated
unchanged.
Three commentators questioned what
methodology was to be used in testing of
open or pressurized fabric filter collec-
tors. These commentators advocated that
EPA develop a reference test method for
testing of pressurized fabric filter collec-
tors. From EPA's experience, develop-
ment of a single test procedure for repre-
sentative sampling of all pressurized
fabric filter collectors is not feasible be-
cause of significant variations in the de-
sign of these control devices. Test proce-
dures for demonstrating compliance with
the standard, however, can be developed
on a case-by-case basis. The promulgated
regulation does require that the owner
or operator design and construct the
control device so that representative
measurement of the particulate matter
emissions is feasible.
Provisions in 40 CPR 60.8(b) allow the
owner or operator upon approval by the
Administrator to show cdmpliance with
the standard of performance by use of
an "equivalent" test method or "alterna-
tive" test method. For pressurized fabric
filter collectors, the owner or operator Is
responsible for development of an "alter-
66
native" or "equivalent" test procedure
which must be approved prior to the de-
termination of compliance.
Depending on the design of the pres-
surized fabric filter collector, the per-
formance test may require use of an
"alternative" method which would pro-
duce results adequate to demonstrate
compliance. An "alternative" method
does not necessarily require that the
effluent be discharged through a stack.
A possible alternative procedure for test-
ing is representative sampling of emis-
sions from a randomly selected, repre-
sentative number of compartments of
the collector. If the flow rate of effluent
from the compartments or other condi-
tions are not amenable to isokinetic
sampling, then subisokinetic sampling
(that is, sampling at lower velocities
than the gas stream velocity, thus biasing
the sample toward collection of a greater
concentration than is actually present)
should be used. If a suitable "equivalent"
or "alternative" test procedure is not de-
veloped by the owner or operator, then
total enclosure of the collector and test-
ing by Method 5 of Appendix A to this
part is required.
A new paragraph has been added to
clarify that during emission testing of
pressurized fabric filter collectors the
dilution air vents must be blocked off for
the period of testing or the amount of
dilution must be determined and a cor-
rection applied in order to accurately
determine the emission rate of the con-
trol device. The need for dilution air cor-
rection was discussed in "Background
Information for Standards of Perform-
ance: Electric Arc Furnaces in the Steel
Industry" but was not an explicit re-
quirement in the proposed regulation.
(7) Miscellaneous. Some commenta-
tors on the proposed standards of per-
formance for ferroalloy production facil-
ities (39 FR 37470) questioned the ra-
tionale for the differences between the
electric arc furnace regulation and the
ferroalloy production facilities regulation
with respect to methods of limiting fugi-
tive emissions. The intent of both regu-
lations is to require effective capture and
control of emissions from the source. The
standards of performance for electric arc
furnaces regulate collection efficiency by
placing limitations on the opacity of
emissions from the shop. The perform-
ance of the control system is evaluated
at the shop roof and/or other areas of
emission to the atmosphere because it is
not possible to evaluate the performance
of the collection system inside the shop.
In electric arc furnace shops, collection
systems for capture of charging and tap-
ping period emissions must be located at
least 30 or 40 feet above the furnace to
allow free movement of the crane which
charges raw materials to the furnace.
Fumes from charging, tapping, and other
activities rise and accumulate in the
upper areas of the building, thus obscur-
ing visibility. Because of the poor visibil-
ity within the shop, the performance of
the emission collection system can only
be evaluated at the point where emis-
sions are discharged to the atmosphere.
Ferroalloy electric submerged arc fur-
FEDERAL REGISTER, VOL. 40, NO. 185—TUESDAY, SEPTEMBER S3, 1975
-------
RULES AND REGULATIONS
43853
nace operations do not require this large
free space between the furnace and the
collection device (hood). Visibility
around the electric submerged arc fur-
nace is good. Consequently, the perform-
ance of the collection device on a ferro-
alloy furnace may be evaluated at the
collection area rather than at the point
of discharge to the atmosphere.
Effective date. In accordance with sec-
tion 111 of the Act, these regulations pre-
scribing standards of performance for
electric arc furnaces in the steel Indus-
try are effective on September 23, 1975,
and apply to electric arc furnaces and
their associated dust-handling equip-
ment, the construction or modification
of which was commenced after Octo-
ber 31, 1974.
Dated: September 15, 1975.
JOHN QUARLES,
Acting Administrator.
Part 60 of Chapter I, Title 40 of the
Code of Federal Regulations is amended
as follows:
1. The table of sections is amended by
adding subpart AA as follows:
*****
Subpart AA—Standards of Performance for Steel
Plants: Electric Arc Furnaces
60.270 Applicability and designation of af-
fected facility.
60.271 Definitions.
60.372 Standard for participate matter.
60.273 Emission monitoring.
60.274 Monitoring of operations.
60.275 Test methods and procedures.
• * * ( * *
2. Part 60 is amended by adding sub-
part AA as follows:
*****
Subpart AA—Standards of Performance
for Steel Plants: Electric Arc Furnaces
§ 60.270 Applicability and designation
of affected facility.
The provisions of this subpart are ap-
plicable to the following affected facili-
ties in steel plants: electric arc furnaces
and dust-handling equipment.
§ 60.271 Definitions.
As used In this subpart, all terms not
denned herein shall have the meaning
given them In the Act and in subpart A
of this part.
(a) "Electric arc furnace" (EAT)
means any furnace that produces molten
steel and heats the charge materials
with electric arcs from carbon electrodes.
Furnaces from which the molten steel is
cast into the shape of finished products,
such as in a foundry, are not affected fa-
cilities included within the scope of this
definition. Furnaces which, as the pri-
mary source of Iron, continuously feed
prereduced ore pellets are not affected
facilities within the scope of this
definition.
(b) "Dust-handling equipment" means
any equipment used to handle particu-
-late matter collected by the control de-
vice and located at or near the control
device for an EAF subject to this sub-
part.
(c) "Control device" means the air
pollution control equipment used to re-
move particulate matter generated by
an EAF(s) from the effluent gas stream.
(d) "Capture system" means the
equipment (including ducts, hoods, fans,
dampers, etc.) used to capture or trans-
port particulate matter generated by an
EAF to the air pollution control device.
(e) "Charge" means the addition of
iron and steel scrap or other materials
into the top of an electric arc furnace.
(f) "Charging period" means the time
period commencing at the moment an
EAF starts to open and ending either
three minutes after the EAF roof is
returned to its closed position or six
minutes after commencement of open-
ing of ,the roof, whichever is longer.
(g) "Tap" means the pouring of
molten steel from an EAF.
(h) "Tapping period" means the time
period commencing at the moment an
EAF begins to tilt to pour and ending
either three minutes after an EAF re-
turns to an upright position or six
minutes after commencing to tilt, which-
ever is longer.
(i) "Meltdown and refining" means
that phase of the steel production cycle
when charge material is melted and un-
desirable elements are removed from the
metal.
(j) "Meltdown and refining period"
means the time period commencing at
the termination of the Initial charging
period and ending at the initiation of the
tapping period, excluding any intermedi-
ate charging periods.
(k) "Shop opacity" means the arith-
. metic average of 24 or more opacity ob-
servations of emissions from the shop
taken in accordance with Method 9 of
Appendix A of this part for the applica-
ble time periods.
(1) "Heat time" means the period
commencing when scrap is charged to an
empty EAF and terminating when the
EAF tap is completed.
(m) "Shop" means the building which
houses one oi1 more EAF's.
(n) "Direct shell evacuation system"
means any system that maintains a neg-
ative pressure within the EAF above the
slag or metal and ducts these emissions
to the control device.
§ 60.272 Standard for particulate mat-
ter.
(a) On and after the date on which
the performance test required to be con-
ducted by S 60.8 is completed, no owner
or operator subject to the provisions of
this subpart shall cause to be discharged
into the atmosphere from an electric arc
furnace any gases which:
(1) Exit from a control device and
contain particulate matter In excess of
12 mg/dscm (0.0052 gr/dscf).
(2) Exit from a control device and ex-
hibit three percent opacity or greater.
(3) Exit from a shop and, due solely
to operations of any EAF(s), exhibit
greater than zero percent shop opacity
except:
(1) Shop opacity greater than zero per-
cent, but less than 20 percent, may occur
during charging periods.;
(ii) Shop opacity greater than zero
percent, but less than 40 percent, may
occur during tapping periods.
67
(iii) Opacity standards under para-
graph (a) (3) of this section shall apply
only during periods when flow rates and
pressures are being established under
§60.274 (c) and (f).
(iv) Where the capture system is op-
erated such that the roof of the shop is
closed during the charge and the tap,
and emissions to the atmosphere are pre-
vented until the roof is opened after
completion of the charge or tap, the shop
opacity standards under paragraph (a)
(3) of this section shall apply when the
roof is opened and shall continue to ap-
ply for the length of time defined by the
charging and/or tapping periods.
(b) On and after the date on which the
performance test required to be con-
ducted by § 60.8 is completed, no owner
or operator subject to the provisions of
this subpart shall cause to be discharged
into the atmosphere from dust-handling
equipment any gases which exhibit 10
percent opacity or greater.
§ 60.273 Emission monitoring.
(a) A continuous monitoring system
for the measurement of the opacity of
emissions discharged into the atmosphere
from the control device(s) shall be in-
stalled, calibrated, maintained, and op-
erated by the owner or operator subject
to the provisions of this subpart.
(b) For the purpose of reports under
§ 60.7 fc), periods of excess emissions that
shall be reported are defined as all six-
minute periods during which the aver-
age opacity is three percent or greater.
§ 60.274 Monitoring of operations.
(a) The owner or operator subject to
the provisions of this subpart shall main-
tain records daily of the following Infor-
mation:
(1) Time and duration of. each
charge;
(2) Time and duration of each tap;
(3) All Sow rate data obtained under
paragraph (b) of this section, or equiva-
lent obtained under paragraph (d) of
this section; and
(4) All pressure data obtained under
paragraph (e) of this section.
(b) Except as provided under para-
graph (d) of this section, the owner or
operator subject to the provisions of this
subpart shall install, calibrate, and
maintain a monitoring device that con-
tinously'records the volumetric flow rate
through each separately ducted hood.
The monitoring device (s) may be in-
stalled in any appropriate location in
the exhaust duct such that reproducible
flow rate monitoring will result. The flow
rate monitoring device (s) shall have an
accuracy of ±10 percent over its normal
operating range and shail be calibrated
according to the manufacturer's instruc-
tions. The Administrator may require
the owner or operator to demonstrate
the accuracy of the monitoring device(s'»
relative to Methods 1 and 2' of Appendix
A of this part.
(c) When the owner or operator of
an EAF is required to demonstrate com-
pliance with the standard under § 60.272
(a) (3) and at any other time the Ad-
ministrator may require (under section
114 of the Act, as amended), the volu-
FEDERAL REGISTER, VOL. 40, NO. 185—TUESDAY, SEPTEMBER 73, 1975
-------
43854
RULES AND REGULATIONS
metric flow rate through each separately
ducted hood shall be determined during
all periods in which the hood is operated
for the purpose of capturing emissions
from the EAP using the monitoring de-
vice under paragraph (b) of this section.
The owner or operator may petition the
Administrator for reestablishment of
these flow rates whenever the owner or
operator can demonstrate to the Admin-
istrator's satisfaction that the EAP oper-
ating conditions upon which the flow
rates were previously established are no
longer applicable. The flow rates deter-
mined during the most recent demon-
stration of compliance shall be main-
tamed (or may be exceeded) at the ap-
propriate level for each applicable period.
Operation at lower flow rates may be
considered by the Administrator to be
unacceptable operation and maintenance
of the affected facility.
(d) The owner or operator may peti-
tion the Administrator to approve any
alternative method that will provide a
continuous record of operation of each
emission capture system.
Ce) Where emissions during any phase
of the heat time are controlled by use
of a direct shell evacuation system, the
owner or operator shall install, calibrate,
and maintain a monitoring device that
continuously records the pressure in the
free space inside the EAF. The pressure
shall be recorded as 15-minute» inte-
grated averages. The monitoring device
may be installed in any appropriate lo-
cation in the EAF such that reproduc-
ible results will be obtained. The pres-
sure monitoring device shall have an ac-
curacy of ±5 mm of water gauge over
its normal operating range and shall be
calibrated according to the manufac-
turer's instructions.
(f) When the owner or operator of an
EAF is required to demonstrate compli-
ance with the standard under § 60.272
(a) (3) and at any other time the Ad-
ministrator may require (under section
114 of the Act, as amended), the pressure
in the free space inside the furnace shall
be determined during the meltdown and
refining period(s) using the monitoring
device under paragraph (e) of this sec-
tion. The owner or operator may peti-
tion the Administrator for reestablish-
ment of the 15-minute integrated aver-
age pressure whenever the owner or
operator can demonstrate to the Admin?
istrator's satisfaction that the EAF op-
erating conditions upon which the pres-
sures were previously established are no
longer applicable. The pressure deter-
mined during the most recent demon-
stration of compliance shall be main-
tained at all times the EAF is operating
in a meltdown and refining period. Opr
eration at higher pressures may be con-
sidered by the Administrator to be un-
acceptable operation and maintenance
of the affected facility.
(g) Where the capture system is de-
signed and operated such that all emis-
sions are captured and ducted to a con-
trol device, the owner or operator shall
not be subject to the requirements of this
section.
§ 60.275 Test methods and procedures.
(a) Reference methods in Appendix A
of this part, except as provided under
§60.8(b), shall be used to determine
compliance with the standards pre-
scribed under § 60.272 as follows:
(1) Method 5 for concentration of par-
ticulate matter and associated moisture
content;
(2) Method 1 for sample and velocity
traverses;
(3) Method 2 for velocity and volu-
metric flow rate; and
(4) Method 3 for gas analysis.
(b) For Method 5, the sampling time
for each run shall be at least four, hours.
When a single EAF is sampled, the sam-
pling time for each run shall also in-
clude an integral number of heats.
Shorter sampling times, when necessi-
tated by process variables or other fac-
tors, may be approved by the Admin-
istrator. The minimum sample volume
shall be 4.5 dscm (160 dscf).
(c) For the purpose of this subpart,
the owner or operator shall conduct the
demonstration of compliance with 60.-
272(a) (3) and furnish the Adminis-
trator a written report of the results of
the test.
(d) During any performance test re-
quired under § 60.8 of this part, no gase-
ous diluents may be added to the
effluent gas stream after the fabric in
any pressurized fabric filter collector,
unless the amount of dilution is sepa-
rately determined and considered in the
determination of emissions.
(e) When more than one control de-
vice serves the EAF(s) being tested, the
concentration of partlculate matter shall
be determined using the following
equation:
c,=~
N
See.),
where:
C,=concentration of particulate matter
in mg/dscm (gr/dscf) as determined
by method 5.
N.— total number of control devices
tested.
Q. = volumetric now rate of the effluent
gas stream In dscm/hr (dscf/hr) as
determined by method 2.
or (QB)»=value of the applicable parameter for
each control device tested.
(f) Any control device subject to the
provisions of this subpart shall be de-
signed and constructed to allow meas-
urement of emissions using applicable
test methods and procedures.
(g) Where emissions from any EAF(s)
are combined with emissions from facili-
ties not subject to the provisions of this
subpart but controlled by a common cap-
ture system and control device, the owner
or operator may use any of the follow-
ing procedures during a performance
test:
(1) Base compliance on control of the
combined emissions.
(2) Utilize a method acceptable to
the Administrator which compensates
for the emissions from the facilities not
subject to the provisions of this subpart.
(3) Any combination of the criteria
of paragraphs (g) (1) and (g) (2) of this
section.
(h) Where emissions from any EAF(s)
are combined with emissions from facili-
ties not subject to the provisions of
this subpart, the owner or operator may
use any of the following procedures for
demonstrating compliance with § 60.272
(a)(3):
(1) Base compliance on control of the
combined emissions'.
(2) Shut down operation of facilities
not subject to the provisions of this
subpart.
(3) Any combination of the criteria
of paragraphs (h) (1) and (h) (2) of this
section.
(Sees. Ill and 114 of tho Clean Air Act, as
amended by sec. 4 (a) of Pub. L. 91-604, 84
Stat. 1678 (42 UJ3.O. 1857O-6, 1857C-9))
[FR Doc.76-25138 Filed 9-22-75;8:46 am)
68
FEDERAL REGISTER, VOL. 40, t 0. 185—TUESDAY, SEPTEMBER 23, 1975
-------
APPENDIX B
METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FROM STATIONARY SOURCES
69
-------
I METHOD 0—VISUAL DETERMINATION OP THEl
OPACITY OF EMISSIONS FROM STATIONARY]
L 6OOTCE3
iany stationary sources discharge visible
emissions Into the atmosphere; these emis-
sions ore usually In the shape of a plume.
This method Involves the determination of
plume opacity by qualified observers. The
method 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 oa
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 bun; point of
observation of attached and detached steam
plume; and angle of the observer with re-
spect to a plume emitted from a rectangular
stack with a large length to width ratio. The
method Includes specific criteria applicable
to these variables.
Other variables which may not be control-
lable In the Held are luminescence and color
contrast between the plume and the back-
Cround against which the plume Is viewed.
These 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 the observed plume Studies of the theory
of plume opacity and field studies have dem-
onstrated that a plume Is most visible and
presents the greatest apparent opacity when
viewed against a contrasting background. It
follows from this, and Is 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. However, the po-
tential for a positive error Is also the greatest
when a plume Is viewed under such contrast-
Ing conditions. Under conditions presenting
a less contrasting background, the apparent
opacity of a plume Is less and approaches
zero as the color and luminescence contrast
decrease toward zero. As a result, significant
negative bins and negative errors can be
made when a plume la viewed under less
contrasting conditions. A negative bins de-
creares rather than increases tho possibility
that a plant operator will be cited for a vio-
lation of opacity standards due to observer
error.
Studies hai-c 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 the procedure™ set forth In this
method. The re-suits of these studies (field
trials] which Involve a total of 7U9 sets of
25 readings each are as follows;
(1) For bla<-k plumes (133 sets at a smoke
generator), 100 percent of the sets were
read with a p^ltlve error1 of luss than n,5
percent opacity; 91' percent were read with
a positive error of less "han 5 percent opacity,
(2) For wh'te plumes (170 sets at u. smoke
generator, KiB sct^ ^t a ccal-fired power plant.
i!98 fcrts at a sulfurlr. acid plant). 00 percent
of the sets were^eud with a positive error of
less than 7.5 percent opacity; 95 percent wero
read with a positive error of less than 6 per-
cent opacity.
The positive observational error associated
with an average of twenty-five readings Is
therefore established. The 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:
1 For a set, positive error=average opacity
determined by observers' 26 observations —
average opacity determined from transmls-
someter's 26 recordings.
2.1 Position. The qualified observer shall
ctand at a distance sufficient 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 hU observations from a position such
that his line of vision la approximately
perpendicular to the plume direction, and
when observing opacity of emissions from
rectangular outlets (e.g. roof monitors, open
baghouses, 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 the 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 name of the plant, emission loca-
tion, type facility, observer's name and
affiliation, and the date on a field data sheet
(Figure 9-1). Tho time, estimated distance
to the emission location, approximate wind
direction, estimated wind tpeed, description
of the sky condition (presence and color of
clouds), and plume background arc recorded
on a field data sheet at the time opacity read-
Ings are Initiated and completed.
2.3 Observations. Opacity obEcrvatlons
shall be made at the point of greatest opacity
In that portion of the plume where con-
densed water vapor is not present. The ob-
server shall not look continuously at tho
plumo, but Instead shall observe the plume
momentarily at 16-second Intervals.
2.3.1 Attached steam plumes. When con-
densed water vapor Is present within the
plume B.B It emerges from the emission out-
let, opacity observations shall be made be-
yond the point In the plume at which con-
densed water vapor Is no longer visible. Tho
observer shall record the approximate dis-
tance from the emission outlet to the point
In the plume at which the observations are
made.
2.3.2 Detached steam plume. When water
vapor In the plume condcrses 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 6
percent ut 15-second Intervals on an ob-»
tervatlonal record sheet, (Sec Figure 9-2 for
an example.) A minimum of 24 ob^ervallona
shall be recorded. Each momentary observa-
tion recorded shall be deemed to represent
tho average opacity of emissions for a 15-
second period.
2.6 Data Reduction. Opacity shall be de-
termined as on average of 24 consecutive
observations recorded at 15-sccond Intervals.
Divide the observations recorded on the rec-
ord sheet Into sets of 24 corsecutlve obser-
vations. A set la composed of any 24 con-
s:cutlve observations. Sets need not be con-
secutive In time and in no cose shall 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. Record the average opacity on a record
sheet. (See Figure 9-1 for an example.)
3. Qualifications and testing.
3.1 Certification requirements. To receive
certification as a qualified observer, a can-
didate must be tested and demonstrate the
ability to assign opacity rcadlrgs In 5 percent
Increments to 25 different black plumes and
26 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. Smoke
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 0 months, at which time the qualification
procedure must be repeated by uny 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. Plumes 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 plume and records his obser-
vation on a suitable form. At the completion
of each run of CO readings, the score of the
candidate Is determined. If a candidate fails
to qualify, the complete run of 50 readings
must be repeated In any re test. 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 generator used for the purposes of
paragraph 3.2 shall be equipped with a smoke
meter Instilled to measure opacity across
the diameter of the smoke generator stack.
Tho smoke meter output shall display In-
stack opacity based upon a pathlength equal
to the stack exit diameter, on a full 0 to 100
percent chart recorder scale. The smoke
mstor optical design and performance shall
meet the specifications shown in Table 9-1.
The smoke ineLer shall be calibrated as pre-
scribed In paragraph 3.3.1 prior to the con-
duct of each snrjko rending test. At the
completion of each test, tho zero and spaa
drift shall be checked and If the drift ex-
ceeds il percent opacity, the condition shall
ho corrected prior to conducting; any subse-
quent test runs. The smoke muter shall bo
demonstrated, at the time of installation, to
meet the lipeciiicatluns listed In Table 9-1.
This demonstration shall be repca-ted fol-
lowing any subsequent repair or replacement
of the photocell or associated electronic cir-
cuitry Including the chart recorder or output
meter, or every 0 months, whichever occurs
llrst.
TABLE 9-1 SMOKE MKTF.U DESIGN AND
PEKFOHMANCli SPECIFICATIONS
Parameter: Specif cation
a. Light source Incandescent lamp
operated at nominal
rated voltage.
70
-------
ameter:
Spectral response
of photocell.
Angle of view
Angle of projec-
tion.
Calibration error.
Zero and apan
drift.
Response time—
Specification
Photoplc (daylight
spectral response of
the human eye—
reference 4.3).
IS* maximum total
angle.
15* maximum total
angle.
±3% opacity, maxi-
mum.
±1 % opacity, 30
minutes.
£6 ssconds.
1.3.1 Calibration. The smoke meter Is
Ibrated after allowing u minimum of 30
nutcs warmup by alternately producing
ailated opacity of 0 percent and 100 per-
it. When stable response at 0 percent or
i percent Is noted, the smoke meter Is ad-
ted to produce an output of 0 percent or
• percent, as appropriate. This calibration
.11 bo repeated until stable 0 percent and
percent readings arc produced without
uatment. Simulated 0 percent and 100
cent opacity values may be produced by
rnately switching the power to the light
rce on and o£t while the smoke generator
;ot producing smoke.
.3.2 Smoke meter evaluation. The smoke
,cr design and performance are to bo
mated as' follows:
3.2.1 Light source. Verify from manu-
.urer's data and from voltage measure-
its made at the lamp, as Installed, that
lamp Is operated within ±5 percent of
nominal rated voltage.
3.3.2.2 Spectral response of photocell.
Verify from manufacturer's data that the
photocell has a photopic response; I.e., the
spectral sensitivity of the cell shall closely
approximate the standard spectral-luminos-
ity curve for photoplc vision which Is refer-
enced In (b) of Table 0-1.
3.3.2.3 Angle of view. Check construction
geometry to ensure that the total angle of
view of the smoke plume, as eccn by the
photocell, docs not exceed 15*. The total
angle of view may be calculated from: 9=2
tan-' d/2L, where 0=:total angle of view;
d = the sum of the photocell dlametcr + the
diameter of the limiting aperture; and
L = the distance from the photocell to the
limiting aperture. The limiting aperture Is
the point In the path between the photocell
and the smoke plume where the angle of
view Is most restricted. In smoke generator
smoke meters this la normally an oritlca
plate.
3.3.2.4 Angle of projection. Check con-
struction geometry to ensure that the total
ancle of projection of the lamp on the
smoke plume docs not exceed 16°. The total
angle of projection may be calculated from:*
0=2 tan-' d/2L. where «= total angle of pro-
jection; d= the sum of the length of the
lamp filament + the diameter of the limiting
aperture; and L= the distance from the lamp
to the limiting aperture.
3.3.2.5 Calibration error. Using neutral-
density filters of known opacity, check the
error'between the actual response and the'
theoretical linear response of the smoke
meter. This check Is accomplished by Brut
calibrating the smoke meter according to
3.3.1 and t*-«« inserting a series of three
neutral-density filters of nominal opacity of
20, 50, and 75 percent In the smoke meter
pathlength. Filters callbarted within ±2 per-
cent shall bo used. Cure should be taken
whou inserting the filters to prevent stray
light from affecting the meter. Make a total
of five nonconsccutlve readings for each
filter. The maximum error on any one read-
ing shall be 3 percent opacity.
3.3.2.0 Zero and span drift. Determine
the zero and span drift by calibrating and
operating the smoke generator in a normal
manner over u 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 flve
simulated 0 percent and 100 percent opacity
values and 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 and 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. Hule 50.
4.2 Welsburd. Melvin I., Field Operations
and Enforcement Manual for Air, U.S. Envi-
ronmental Protection Agency, Research Tri-
angle Park, N.C., APTD-1100, August 1972.
pp. 4.1-4.30.
4.3 Cjudon, E. U., and Odlshaw, H., Hand-
book lit Physics, McGraw-Hill Co!, N.Y., N.Y.,
IBSd, Table 3.1, p. C-52.
71
-------
COMPANY^ _
LOCATION
TEST >-".:-;eER_
DATE
TYPE FACILIfY
CONTROL DEVICE
FIGURE 9-1
RECORD OF VISUAL. DETERMINATION OF OPACITY
PAGE of
HOURS OF OBSERVATION,
OBSERVER
OBSERVER CERTIFICATION DATE_
OBSERVER AFFILIATION
POINT OF EMISSIONS
HEIGHT OF DISCHARGE POINT
N>
CLOCK TIME
OBSERVER LOCATION
Distance to Discharge
Direction from Discharge
Height of Observation Point
BACKGROUND DESCRIPTION
WEATHER CONDITIONS
Wind Direction
Wind Speed
Ambient Temperature
SKY CONDITIONS (clear,
overcast, % clouds, etc.)
PLUME DESCRIPTION
Color
Distance Visible
OTHER INFOITiATIOil
Initial
Final
SUMMARY OF AVERAGE OPACITY
Set
Number
Time
Start—End
Opacit}
Sum
'verage
Readings ranged from
to
opacity
The source was/was not in compliance with
the time evaluation was made.
.at
-------
COMPANY
LOCATION
TEST NUMBER
DATE
FIGURE 9-2 OBSERVATION RECORD
OBSERVER
PAGE OF
TYPE FACILITY
POINT OF EMISSWT
Hr.
Min.
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
U
Seconds
15
oO
4b
STEAM PLUME
(check 1f applicable)
Attached
Detached
V.
-=
-
COMMENTS
FIGURE 9-2 ' C
(Cor
COMPANY
LOCATION
TEST
DATE
Hr.
NUMBER
Win.
30
31
32
33
34
35
36
37-
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
Seconds
0
15
30
IIP
4b
(cf
A
OBSERVATION RECORD
PAGE
OF
OBSERVER
TYPE FACILITY ~
POINT OF EMISSIONS
[FR Doc.74-26150 Filed 11-11-74:8:45 am]
-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO.
EPA 340/1-77-007
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Steel Producing Electric Arc Furnaces
(Inspection Manual for the Enforcement of New Source
Performance Standards)
5. REPORT DATE
May 1977
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO,
James Sahagian
Paul Fennelly
Manuel Rei
9. PERFORMING ORGANIZATION NAME AND ADDRESS
10. PROGRAM ELEMENT NO.
GCA Corporation
GCA/Technology Division
Bedford, Massachusetts
11. CONTRACT/GRANT NO.
68-01-3155
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
Division of Stationary Sourc Enforcment (EN-341)
401 M Street, S.W.
Washington, D.C. 20460
14. SPONSORING AGENCY CODE
EPA - OE
15. SUPPLEMENTARY NOTES
One of a series of NSPS Enforcment Inspection Manuals
16. ABSTRACT
This document presents guidelines to enable enforcement personnel to determine
whether new or modified EAF's in the steel production industry 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. The electric arc process, atmospheric
emissions from these processes, and emissions control methods are described.
The inspection methods and types of records to be kept are discussed in detail.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Electric Arc Furnaces
Air Pollution Control
Verification Inspection
Performance Tests - Steel Making
New Source Performance
Standards
Enforcement Emission
13B
14D
13. DISTRIBUTION STATEMENT
Release
19. SECURITY CLASS (ThisReport)
Unclassified
20. SECURITY CLASS (This page)
Unclassified
21. NO. OF PAGES
73
22. PRICE
EPA Form 2220-1 (9-73)
------- |