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

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                                                   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

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 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.

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                               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

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                       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

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                               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

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                                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

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                               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.

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                              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

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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.

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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.

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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.

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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

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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.

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                               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. '  ' '

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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

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        HEARTH LINE
     STADIUM-TYPE SUBHEARTH CONSTRUCTION
         HEARTH LINE
  INVERTED-ARCH TYPE SUBHEARTH CONSTRUCTION
Figure  1.   Electric-arc furnace  subhearth construction.

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                                              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.

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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

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                                                             (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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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                                                                 o
    Fourth hole
Side draft
    Combination hood
 Canopy hood
Figure 4.  Ventilation systems for electric arc furnaces
                             26

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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

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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

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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

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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

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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

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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

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 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

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                                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

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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

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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

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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

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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

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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

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    •   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

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                       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

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                      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

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                       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

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                      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

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                       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

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                       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

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                       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

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                         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

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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

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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

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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

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                               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

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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

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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

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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

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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

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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

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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

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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

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   (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

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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.
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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

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                 APPENDIX A

      PART 60 - STANDARDS OF PERFORMANCE
         FOR NEW STATIONARY SOURCES
ELECTRIC ARC FURNACES IN THE STEEL INDUSTRY
                   63

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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

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                                             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

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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-
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                                            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

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 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

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                 APPENDIX B

  METHOD 9 - VISUAL DETERMINATION OF THE
OPACITY OF EMISSIONS FROM STATIONARY SOURCES
                   69

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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

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 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

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               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

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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]

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                                   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)

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