EPA-450/2-77-004
March 1977
BACKGROUND INFORMATION
FOR AN OPACITY STANDARD
OF PERFORMANCE FOR
BASIC OXYGEN PROCESS
FURNACES IN IRON
AND STEEL PLANTS
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
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EPA-450/2-77-004
BACKGROUND INFORMATION
FOR AN OPACITY STANDARD
OF PERFORMANCE FOR
BASIC OXYGEN PROCESS
FURNACES IN IRON
AND STEEL PLANTS
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, N.C. 27711
March 1977
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This document does not constitute a general endorsement of supplementary
control systems as a control alternative. It is intended only to assist the
responsible control agencies in those limited situations where legislation,
EPA or the courts permit its use.
This report is issued by the Environmental Protection Agency to report
technical data of interest to a limited number of readers. Copies are
available free of charge to Federal employees, current contractors and
grantees, and nonprofit organizations - in limited quantities - from the
Library Services Office (MD-35) , Research Triangle Park, North Carolina
27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/2-77-004
11
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TABLE OF CONTENTS
PAGE
SUMMARY 1
. Proposed Amendment 1
. Economic and Environmental Impacts 2
BACKGROUND . 2
PROCESS AND EMISSION CONTROL SYSTEMS 4
DATA BASE FOR OPACITY STANDARD 8
RATIONALE FOR THE PROPOSED STANDARD 21
. Periods of BOPF Operations Subject to Opacity Standard . . 21
. Selection of the Format of the Proposed Opacity
Standard 22
. Selection of the Emission Limits 24
MONITORING REQUIREMENTS 28
REFERENCES 30
APPENDIX 31
iii
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LIST OF TABLES
Table Page
1 Mass and Opacity Emissions for Basic Process
Furnaces 17
2 Opacity Standardized to Maximum Stack Diameter of
6.1 Meters 20
IV
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SUMMARY
Proposed Amendment
On March 8, 1974 (39 FR 9308), under the authority of section 111 of
the Clean Air Act, as amended, EPA promulgated a standard of performance
limiting particulate matter emissions from Basic Oxygen Process Furnaces
(BOPFs) to less than 50 mg/dscm (0.022 gr/dscf). An opacity standard was
not promulgated due to unexplained variations in opacities from well
controlled facilities. This report presents the background information
and the rationale for the proposed opacity standard for BOPF facilities.
EPA establishes opacity standards in conjunction with mass or
concentration standards as a means of ensuring that control equipment
is adequately maintained and properly operated at all times between
performance tests. Opacity standards for each class of sources are
established at levels which are not more restrictive than the corres-
ponding concentration/mass standards and which consider the effect of
the normal range of operating variables on opacity. The proposed
standard is based on 73 hours of opacity observations taken in
accordance with Reference Method 9 and consideration of known process
variations. The proposed opacity standard limits emissions to less
than 10 percent opacity except emissions up to 20 percent opacity are
allowed once per steel production cycle. A limitation on peak
emissions during the cycle in addition to the baseline emissions is
1
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necessary because of variations in gas density over the operation cycle
and the lag in response of control systems.
Economic and Environmental Impacts
The proposed opacity standard and the monitoring of operations
requirements do not impose any additional significant requirements or costs
over those required to comply with the concentration standard. Therefore,
the proposed opacity standard does not have a major inflationary impact
and no inflation impact statement has been prepared. Any environmental
impacts or benefits of the standard of performance for BOPF also are
incurred in complying with the concentration standard. During the develop-
ment of the concentration standard, the intermedia effects of the standard
were assessed and determined to be negligible. No additional intermedia
effects would.be incurred in complying with the opacity standard.
Therefore, a formal environmental impact statement has not been prepared.
The environmental impact of the proposed opacity standard is beneficial,
since the standard would ensure .compliance of new BOPFs with the
concentration standard throughout their operational life.
BACKGROUND
On June 11, 1973 (38 FR 15406), under the authority of section 111 of
the Clean Air Act, as amended, the Environmental Protection Agency (EPA)
proposed standards of performance for new basic oxygen process furnaces
(BOPFs) in iron and steel plants. The proposed standards limited emissions
of particulate matter to less than 50 mg/dscm (0.022 gr/dscf) and to less
than 10 percent opacity except for two minutes in any one hour. On
March 8, 1974 (39 FR 9308), EPA promulgated the standard of performance
limiting emissions from new BOPFs to less than 50 mg/dscm (0.022 gr/dscf),
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but the opacity standard and the attendant continuous monitoring requirement
were not promulgated at that time. The opacity standard was reserved pending
study of (1) the reasons for observed variations in the opacity of emissions
from well-controlled facilities and (2) the effect that exemption of periods
of startup, shutdown, and malfunction from opacity standards would have on
the level of the opacity standard and the need for a time exemption.
On November 12, 1974 (39 FR 39872), EPA revised Reference Method 9 and
the general provisions applicable to standards of performance. These
revisions resulted from a study of the errors associated with single
observations made by qualified observers while reading smoke plumes
according to the prescribed procedures. It was shown in this study that
qualified observers can determine plume opacities with maximum positive
errors of less than 7.5 percent based on the average of 24 consecutive
readings. Accordingly, Reference Method 9 was revised to require that
opacity observations be recorded to the nearest five percent at 15-second
intervals with a minimum of 24 observations. The minimum time over which
opacity observations are made was extended to six minutes to obtain
sufficient observations to ensure acceptable accuracy. The use of sets
of opacity observations (or six-minute average opacity values) precludes
a single high reading from being cited as a violation. In addition,
§60.11(e) was added to the general provisions to provide a means for
an owner or operator to petition EPA to obtain a higher opacity standard
for any facility that demonstrates compliance with the mass standard
concurrent with failure to attain the opacity standard. The provisions
of 160.11(e) allow opacity standards to be established at levels which
reflect the maximum expected effects of the normal range of operating
variables and stack diameters at well-controlled new facilities.
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The study to determine the appropriate level of an opacity standard
(consistent with the revisions to Method 9) for new BOPFs considered the
following factors:
1. Determination of opacity levels indicative of proper operation
and maintenance of a well-controlled facility.
2. The effects on opacity of process variations and any resultant
variations in the performance of the control devices.
3. Definition of startup for BOPFs.
PROCESS AND EMISSION CONTROL SYSTEMS
The basic oxygen process for production of steel uses high pressure
oxygen to oxidize and remove carbon, silicon, and other undesirable ele-
ments from molten iron and scrap steel. The furnace operation is cyclic
and the time required for a complete steel production cycle is typically
45 minutes, but can range from about 30 to 75 minutes due to variations
in shop operating conditions. The steel production cycle for a BOPF
includes five basic operations: (1) charging of scrap and hot metal,
(2) oxygen blowing, (3) testing, (4) tapping, and (5) slagging.
Generally the material charged to the BOPF consists of 10-30 percent
scrap and 90 to 70 percent molten pig iron. These relative proportions
are used so that the heat generated by oxidation of carbon, silicon, and
manganese plus the sensible heat from the molten pig iron provides
sufficient energy to melt all the scrap and to raise the metal to the
correct temperature for tapping. Charging of scrap and molten pig iron
requires only a few minutes. Just after initiation of oxygen blowing and
at intervals as necessary, slag forming flux materials (lime, limestone,
fluorospar etc.) are added to the vessel to remove undesirable elements
such as sulfur, phosphorus, manganese etc.
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After the vessel is charged, high purity oxygen is blown into the
charge materials either from above the molten charge using a lance or from
1 2
below through tuyeres. Oxygen is blown generally for about 18-20 minutes ' '
but due to variations in conditions (including scrap quality) and process
used the blowing period can vary from approximately 13 to 26 minutes in
duration. The gases emitted from the furnace primarily consist of CO and
COp from oxidation of carbon in the metal and oxygen derived from iron
oxides. The evolution rate of these gases and attendent iron oxide fume
varies greatly over the entire blowing period.
After blowing of oxygen for a specified period, a sample of the
metal is taken for analysis. If the metal is not of correct composition,
additional oxygen is blown for a short time period. If the steel is of
correct composition, the vessel is tapped. Tapping of the BOPF is simply
the pouring of molten metal from the vessel into a ladle.
The final operation, slagging, is the removal of slag from the
vessel after completion of a tap and before the vessel is charged again.
Slag is the fused product formed by the reaction of the flux materials
with impurities in the metal. Because slag is of lower density th&in the
metal, the slag floats on top of the molten metal bath and the metal can
be tapped from below the slag.
The fume generation rate in the basic oxygen process is dependent on
a number of factors such as: the oxygen blow rate, carbon content of
iron, percentage of scrap charged, quality of scrap charged, rate of
additions, and condition of the refractory lining of the vessel. Over
the production cycle the gas evolution rate and gas temperature vary
considerably. Due to the resultant variations in the concentration of
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particulate matter, gas temperature and gas volume in the inlet gas stream,
emissions will be greater in the beginning of the blowing period .than
during the remainder of the oxygen blow and the rest of the cycle.
Particulate matter emissions from BOPFs are produced primarily by
refractory erosion and by condensation of vaporized metal oxides and
coagulation of these particle^ to form agglomerates. Thus, BOPF particu-
late matter emissions consist mainly of spherical or agglomerates of
spherical particles of similar properties. The mass mean diameter of
emissions from top blown BOPFs has been reported to vary from 0.5. to 1.0
456
micrometer. ' ' Emissions from bottom blown BOPFs are smaller and are
generally estimated to be around 0.1 micrometer diameter. From light
scattering theory it is expected that emissions from bottom blown BOPFs
will scatter more light than an equivalent quantity of particulate matter
emitted by a tap blown BOPF. However, opacities of plumes from bottom
blown BOPF facilities should not be significantly higher than those from
top blown facilities due to the smaller gas volumes evolved from tightly.
hooded bottom blown vessels.
The analysis of the opacity data for electrostatic precipitator-
controlled BOPFs operating within the expected range of variables
indicated that emissions will be less than 35 percent opacity during the
start.,of oxygen blowing and less than 20 percent during the rest of the
cycle. These emission limitations were determined on the basis of an
engineering judgment of the performance of the control systems since
none of the opacity observations were made concurrently with the
concentration measurements. The judgment of the systems' performance
is based on an evaluation of the maintenance and operating conditions
of the control system by EPA engineers at the time of the Method 9
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observations and a comparison with opacity observations at poorly maintained
or malfunctioning facilities. Even a precipitator with one sixth of the
necessary plate area out of service could control.emissions to no greater
than 40 percent opacity during oxygen blowing and no greater than 21 percent
during the rest of the cycle.
EPA's opacity study of BOPF facilities finds that those facilities which
preheat scrap before the,addition of hot metal to the vessel exhibit the
highest opacity emissions during the preheat period with lower peak emissions
occurring during the oxygen blow. The maximum opacity and the opacity levels
associated with the remainder of the cycle are related to the degree of
emission reduction achieved over the cycle and the stability of the gas
temperature in the system. At facilities which operate the BOPF vessels
with overlapping production cycles, the gas temperatures and volumes are
maintained more uniformly near the peak values and hence peak opacity levels
are expected to be lower; but typical baseline opacity levels also are
expected to be higher than those for facilities operating each vessel with
a separate production cycle.
The standard of performance, 50 mg/ciscm, can be achieved by use
o
of any of three basic types of emission control systems : (1) open hood
with a high-energy venturi scrubber, (2) open hood with an electrostatic
precipitator, and (3) closed hood with a high-energy venturi scrubber. Most
new basic oxygen process furnaces are expected to be designed with tight
fitting combustion hoods and to use scrubbers for control of emissions to
the atmosphere. The trend is toward this type process emission control
system to reduce energy costs of the gas cleaning system.
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Open hoods on BOPFs are generally located at a distance of 0.46 to
0.91 meter (1.5 to 3 feet) above the vessel rim. As a result of this
separation between the vessel and the base of the collection hood, excess
air is drawn into the control system. Depending on the amount of the
separation the gas volume from open hooded BOPFs will be 4.7 to 6.7
times greater than gas volumes from similar closed hooded BOPFs. Conse-
quently, BOPFs with open hood control systems can be expected to have
larger diameter .stacks for discharge of emissions to the atmosphere than
BOPFs with closed or tightly hooded control systems. Therefore, BOPFs
with closed hood control systems were expected to exhibit lower opacities
because the smaller the stack diameter, the smaller the length of the
path through which light is attenuated before it reaches the observer.
DATA BASE FOR OPACITY STANDARD . -
Opacity observations for support of an opacity standard were obtained
at six well-controlled facilities. A total of 73 hours of valid obser-
vations were obtained. The six observed facilities are representative of
typical new BOPF shops: that is, the vessel sizes were within the typical
range of 91-318 Mg* (100-350 tons) capacity of steel per heat,.both two
vessel and three vessel shops were observed, and some shops used dirty
scrap. Three of the observed facilities had control systems consisting
of an open hood with electrostatic precipitator and three facilities had
control systems consisting of.an open hood with venturi scrubber. Emissions
from facilities C and E had been previously tested by EPA and these data
were part of the bases of the concentration standard. These facility's
*Mg (Megagram) is the recommended unit for large masses in the
International System of Units (SI).
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codes correspond to their codes in Technical Report No. 12 of Volume I of
"Background Information for New Source Performance Standards: Asphalt
Concrete Plants ..." (APTD-1352a) which gives the bases of the concen-
tration standard for BOPFs. In order to resolve the questions on the
opacity standard raised by comments on the previously proposed opacity
standard, facilities F, G, H, and I were observed after proposal of the
standard (June 11, 1973).
The opacity observations at the six facilities were taken in accor-
dance with the requirements of Method 9 as revised on November 12, 1974
(39 FR 39872). As required by Method 9 the opacity levels of the data
were determined as the average of 24 consecutive observations taken at
15-second intervals. Since the sets of 24 observations may not overlap,
there are 10 sets of 24 observations or 10 average opacity values in any
sixty-minute period of observation. For this report, the opacity data
from the five topblown vessels were grouped in sets of 24 consecutive
observations starting with the first six-minutes of each clock hour defining
the first set. This procedure provided a consistent method for data
reduction without requiring synchronization of observer times with BOPF
shop operating times or arbitrary assignment of observation periods with
specific production cycles.* The opacity observations from the facility
using bottom blown vessels were grouped in sets of 24 consecutive obser-
vations starting at the beginning of the production cycle.
Due to the frequent occurrence of condensed water vapor plumes at
both scrubber and electrostatic precipitator-controlled facilities, not
Calculation of maximum opacity levels for start of oxygen blow
periods showed that there was no significant difference between results
obtained by this approach and by the method of dividing each hour into
10 sets of 24 consecutive observations.
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all of the observation periods resulted in data useful for establishment of
an opacity standard. That is, opacities read at the point of dissipation
of attached water vapor plumes are biased low due to dilution of the concen-
tration of particulate matter in the plume below that at the stack exit.
The opacity data discussed in this report and used as the basis of the
opacity standard are only the six-minute average values for periods in which
either no condensed water vapor plumes were present or when a detached plume
was present. Thus, the opacity standard is based on the opacities of
undiluted emissions and is not biased 1'ow due to interference from steam
plumes. All the opacity values, including those observations made at the
end of condensed water vapor plumes, are presented in the Appendix to this
report.
In general, the observed emission patterns at the six well-controlled
facilities showed the expected emission cycle of three to four minutes of
high opacity emissions with decreasing opacity emissions throughout the
remainder of the operation cycle. Each facility observed and a summary of
the six-minute average opacity values of the non-steam plume emissions are
discussed below.
Facility C consists of two open hooded BOPFs each with a capacity of
130 Mg (140 tons) of steel per heat. Emissions from these BOPFs are
controlled by a single dry electrostatic precipitator which has a design
collection efficiency of 99.85 percent. Previous emission tests conducted
by EPA on this facility showed an average effluent concentration over the
BOPF cycle of 16 mg/dscm (0.007 gr/dscf). Due to the greater actual gas
volumes handled by open hood electrostatic precipitator control systems-,
emissions from these BOPFs are exhausted to the atmosphere through a single
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relatively large stack of 5.03 meters (16.5 feet) diameter. Method 9
observations on visible emissions from this facility were conducted in
September 1973 and again in September 1974 after maintenance and repair of
the electrostatic precipitator. Emissions from the control device were
observed for a total of six hours over a two day period in 1973 and 30
hours over a five day period in 1974. In the 1973 observations, a maximum
opacity level (six-minute average basis) of less than 30 percent was
associated with the start of oxygen blows, and typically the remainder
of the cycle had emissions of less than 15 percent opacity. After repair
and maintenance of the electrostatic precipitator, the opacity of
emissions from this facility was substantially reduced. In 1974 opacity
observations showed that the maximum opacity associated with start of
oxygen blows was 11 percent, and during the rest of the operating cycle
the opacity levels were typically less than five percent. (Figures 1-2
of the Appendix show the opacity levels observed in 1973 and Figures 3-14
show the opacity levels observed in 1974.)
Facility E consists of two open hooded BOPFs of 230 Mg (250 tons) of
steel per heat capacity which are usually operated with overlapping
production cycles. The emissions from these furnaces are controlled by a
single dry electrostatic precipitator with a design collection efficiency
of 99.7 percent. Previous emission tests conducted by EPA on this
facility showed an average effluent concentration of 62 mg/dscm (0.027
gr/dscf). Facility E was observed to provide an indication of opacity
levels associated with an effluent concentration near or slightly in excess
of 50 mg/dscm (0.022 gr/dscf). Emissions from this facility are discharged
through a single stack of 5.5 meters (18 feet) diameter which is near the
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maximum size of the typical range of stacks.for open hooded BOPFs. Due to
interference by weather conditions and malfunction of the electrostatic
precipitator on one day, opacity data useful for establishment of a standard
were obtained only during six hours of observation. These opacity observa-
tions show that during periods of proper operation of the control device,
the maximum opacity level associated with the start of oxygen blowing is 22
percent and typically opacity levels during the remainder of the cycle are
less than 15 percent. During the malfunction of the control device, opacity
levels in excess of 41 percent were observed during the first six minutes of
one oxygen blowing period. (See Figures 15 t& 17 of the Appendix).
Facility F was observed to obtain further data on opacity levels
associated with a well-designed and operated electrostatic precipitator.
Facility F consists of three BOPF vessels each with a production capacity
of 100 Mg (110 tons) of steel per heat; Emissions from the BOPF vessels
are controlled by a single electrostatic precipitator. Emission tests
conducted by the local air pollution control agency using an out-of-stack
filter test procedure (not EPA Method 5) indicated the average concentration
of particulate matter emissions was 14 mg/dscm (0.006 gr/dscf). The control
system discharges emissions through three stacks of 2.67 meters (8.75 feet)
diameter which is an atypically small stack diameter for an electrostatic
precipitator-controlled BOPF.
On the first day of observation (December T8, 1973), one-sixth of the
electrostatic precipitator was out of service and the remaining units had
a higher than normal load. Consequently, emissions were higher than normal
for the facility. Emissions from stack #2 were observed for 4.5 hours by
observer 1 and emissions from stack #3 were observed for 5.5 hours by observer
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2. The observed opacity levels of effluent from the two stacks were compa-
rable within the errors of Method 9. The maximum observed opacity level
associated with the start of oxygen blowing was 25 percent and during the
rest of the production cycle emissions'were typically less than 10 percent
opacity. Normalization of these opacity levels to equivalent opacities at
6.1 meters pathlength to allow comparison with the other precipitator-
controlled facilities shows that during malfunctions the respective opacity
levels are 48 percent and 21 percent. On the second day of observation
(December 19, 1973) all units of the precipitator were operating normally,
and both peak and baseline opacity levels of emissions were lower.
Emissions from stack #3 were observed for five hours by observer 1 and 6.5
hours by observer 2. The maximum observed opacity associated with the
start of oxygen blowing was less than 15 percent and typically over the
remainder of the operation cycle emissions were less than five percent
opacity. (See Figures 18 to 21 of the Appendix).
Facilities G and H were observed to obtain opacity data on well-designed
and operated venturi scrubber-controlled BOPF vessels using an open hood for
fume capture. The BOPF shop at Facility G has three vessels of 200 Mg (220
tons) of steel per heat production capacity which usually operate with over-
lapping production cycles. Emissions from the three vessels are controlled
by two parallel venturi scrubbers which are operated at about 11 kPa* (45 in.
w.g.) pressure drop across the throat of each venturi. Emissions are
discharged to the atmosphere through two stacks of 2.67 meters (8.75 feet)
diameter. This facility has never been emission tested, but the design of
the control system appears to be comparable to that of a system capable of
*kPa (kilopascal) is the pressure of one thousand newtons per square
meter. One pascal is equivalent to 4.03 x 10~3 inches of water at 60°F.
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achieving an emission reduction to about 50 mg/dscm (0.022 gr/dscf) over the
production cycle. Emissions from the stack were observed continuously for
7.5 hours by each of the two observers. During the first hour of observation
two sessels were operated simultaneously, and halfway through the cycle a
malfunction occurred with the hood of one vessel and excessive emissions were
observed from the control dev.^e stacks and the building roof monitor. After
completion of the cycle the vessel was shutdown for repairs and was out of
service for most of the remaining period of observation. During the first
half of this operation cycle, the scrubber was operated at reduced pressure
drop and the opacity of emissions was 35 percent. The
malfunction of the hood increased the emission level further so that the
associated opacity increased to 55 percent. During periods of normal
operation, the maximum observed opacity associated with the start of oxygen
blowing was less than 17 percent and for the rest of the cycle emissions
typically were less than 10 percent opacity (See Figures 22 to 23 of the
Appendix).
The BOPF shop at facility H contains two vessels with a production
capacity of 254 Mg (280 tons) of steel per heat. Emissions from each vessel
are captured by an open hood and ure manifolded to three venturi scrubbers.
Emissions from each scrubber are discharged through a stack of 2.67 meters
(8.75 feet) in diameter. The scrubbers are normally operated at 14 kPa (55
in. w.g.) pressure drop across the throat of the venturi. This emission
control system has been previously emission tested using an in-stack filter
test procedure and the average effluent concentration (for the oxygen
blowing period only) was 46 mg/dscm (0.020 gr/dscf). Due to unequal
distribution of the gases to the scrubbers, the scrubber nearest the
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operating vessel handled the bulk of the exhaust gas load and had visible
emissions. Consequently, depending on which vessel was operating and hence
which stack had visible emissions, emissions from either the east or west
t
stack were observed. Visible emissions from the two stacks were observed
for a total of about 5.5 hours. The maximum observed opacity associated
with the start of oxygen LI owing was less than 18 percent and emissions
from the rest of the cycle typically were five percent opacity or less.
(See Figures 24 to 25 of the Appendix).
Facility I consists of two bottom blown basic oxygen process vessels
with a steelmaking capacity of 184 Mg (200 tons) per heat. Emissions from
each vessel are collected by a water cooled hood and are controlled by a
venturi scrubber. Emissions from each scrubber are discharged through a
stack of approximately 2.13 meters (seven feet) in diameter. The scrubbers
are automatically operated and the pressure drop across the throat is
maintained at about 19 kPa (76 in. w.g.). Emission tests of this control
system conducted using an out-stack filter test procedure showed an average
concentration of emissions of 32 rag/dscm (0.014 gr/dscf). During the
period of the opacity observations only one vessel was operating.
The waste gas stream from the bottom blown basic oxygen process contains
high concentration of carbon monoxide and other combustible compounds; and
hence is flared. During the production cycle the flare is extinguished for
four to six minutes during the beginning of the oxygen blowing period.
Therefore, observations at Facility I were made at the point of maximum
opacity when the flare was out or when the gases were being flared the
emissions were read at a point after the flare. Visible emissions were
observed for six hours by two observers. The maximum opacity level observed
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during the start of the oxygen blow was less than eight percent and emissions
during the remainder of the cycle were zero percent opacity. (See Figures 26
and 27 of the Appendix).
The opacity data discussed above and the facility descriptions are
summarized in Table 1 to facilitate comparison of the data. The opacity
observations at the six facilities showed that when the facilities were
properly operated the maximum six-minute average opacity was less than 30
percent at electrostatic precipitator-controlled BOPFs and less than 20
percent for scrubber-controlled BOPFs. Emissions during the remainder of
the cycle were less than 16 percent opacity for properly operating
precipitator-control systems and were less than 10 percent for properly
operating-scrubber control systems. During malfunctions of the electrostatic
precipitator-controlled units, the opacity of emissions (on a 6.1 meter
basis) increased to 40-48 percent during the remainder of the cycle. Opacity
observations at two electrostatic precipitator-controlled BOPFs which were
not considered well-controlled because of poor maintenance or design of the
system, showed maximum six-minute average opacity values of 50 to 70 percent
during oxygen blow periods and typical baseline six-minute average opacity
values of 25 to 30 percent.* At one scrubber-controlled BOPF (Facility G)
emissions were observed to increase to 30 percent during periods of opera-
tion at reduced pressure drops across the scrubber throat. An increase in
emissions to 55 percent opacity followed the occurrence of the malfunction
on the hood.
Comparison of the opacity data from the six facilities shows that in
general a large difference exists in the opacity levels associated with
*These data are not presented and the facilities are not discussed in
this report because the control systems employed were not representative of
best systems of emission reduction.
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Table 1. MASS AND OPACITY EMISSIONS FOR BASIC OXYGEN PROCESS FURNACES
Facility Code
(Vessel Production
Capacity)
C
(127 Mg/ht)
E
(227 Mg/ht)
F
(100 Mg/ht)
G
; (200 Mg/Ht)
H
(254 Mg/ht)
I
(184 Mg/ht)
Control System
Open hood with
electrostatic
preci pita tor
Open hood with
electrostatic
preci pita tor
Open hood with
electrostatic
preci pi tator
Open hood with
scrubbers
Open hood with
scrubbers
Closed hood
with
scrubbers
Stack
Diameter
5.03 m (16.5
ft)
5.49 m (18 ft)
2.67 m (8.75
ft)
2.67 m (8.75
ft)
2.67 m (8.75
ft)
2.13 m (7 ft)
Effluent Concentration
at Time of Stack Test
(date of test)
16 mg/dscm (0.007 gr/dscf)
(10/10-11/71)
62 mg/dscm, (0.027 gr/dscf)
(1/12-14/72)
14 mg/dscm, b (0.006 gr/dscf)
(7/28/73)
Unknown
46 mg/dscm, c (0.020 gr/dscf)
(7/22-27/70)
32 mg/dscmb (0.014 gr/dscf)
Maximum Six-Minute
Opacity Value
(date of observation)
28% (9/20/73)
11% (9/8-13/74)
41%a (10/17/73).
22% (10/18/73)
25%a (12/18/73)
15% (12/19/73)
17% (5/14/74)
16% (5/15/74)
7% (6/29/76)
Baseline Six-Minute
Opacity Value
(date of observation)
15% (9/20/73)
0% (9/13/74)
13% (10/18/73)
10% (12/18/73)
5% (12/19/73)
10% (5/14/74)
5% (5/15/74)
0% (6/29/76)
a One sixth of electrostatic precipitator plate area was out of service
Out-of-stack filter test procedure, not EPA Method 5
c In-stack filter test procedure
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properly operating scrubber-controlled BOPFs and electrostatic precipitator-
controlled BOPFs. One possible reason for the higher opacity emissions from
precipitator-controlled BOPFs is that changes in gas temperatures and particle
conditioning initially allow large numbers of small particles to escape
collection. With ap effective wet gas conditioning system and maintenance
of the unit within the design operating parameters, poor collection of the
finer sized particles should not be sufficient to result in a difference of
15 percent opacity. It was also considered possible that the difference in
performance of the control systems could be due to variations in the stack
diameter rather than due to significant differences in the emission concen-
trations. Stack diameter affects opacity because the diameter determines
the length of the path through which light is attenuated as it passes
through the plume. Consequently, the larger the stack diameter, the more
light will be attenuated as it passes through the plume and hence the
greater the opacity of the plume.
Since particulate matter concentration measurements and the opacity
observations were not conducted concurrently, the cause of the difference
in opacity levels cannot be determined exactly. However, adjusting the
opacity data to a common stack diameter, does provide an indication of
the effect of stack diameter on opacity levels. The opacity data were
standardized to a common basis using the following relationship:
111 (1-0.) • 8 " 1"0-° actual)
where:
0 . = The opacity at standard diameter
D standard = Standard stack diameter
D actual = Observed stack diameter
0 actual = The observed opacity
18
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Information available to EPA indicates that stacks used to discharge
emissions from open hooded BOPFs are typically less than three meters (10
feet) for scrubber-controlled facilities and less than 6.1 meters (20 feet)
for electrostatic precipitator-controlled facilities. Electrostatic
precipitator-controlled units use a larger volume of exhaust gas to prevent
explosions; consequently, "larger diameter stacks are used in discharging
emissions to the atmosphere. Adjusting all the opacity data to a common
basis of 6.1 meters (20 feet) shows that scrubbers would have emissions
of comparable opacity to those of electrostatic precipitators if comparable
gas volumes were used and the gases were discharged from single stacks
having the same diameter. As shown in Table 2, on an adjusted basis both
scrubber and electrostatic precipitator-controlled facilities had emissions
less than 35 percent opacity during start of oxygen blowing and less than
19 percent opacity during the remainder of the cycle when the control
systems were operating properly. This agreement in the opacity data after
normalization to a common diameter indicates that the differences in plume
apparent opacities may be primarily due to differences tn the gas volumes
handled by the two control systems rather than any major differences in the
particulate matter concentration of the emissions. In addition these
projections of the data show that a well-designed and operated electrostatic
precipitator-contrdlled facility operating within the expected range of
variables, emissions will be less than 35 percent opacity during the start
of oxygen blowing and less than 20 percent during the remainder of the
cycle. Similarly a well-designed and operated venturi scrubber-controlled
facility will have emissions less than 20 percent opacity during the start
of oxygen blowing and less than 10 percent during the remainder of the cycle.
19
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Table 2. OPACITY STANDARDIZED TO MAXIMUM STACK
DIAMETER OF 6.1 METERS
Faci 1 i ty
Code
C
E
F
G
H
I
Actual
Stack
Diameter .
5.03 m (16.5 ft)
5.49 m (18 ft)
2.67 m (8.75 ft)
2.67 m (8.75 ft)
2.67 m (8.75 ft)
2.13 m (7 ft)
Observed
Maximum
Six-Minute
Average
Opacity
28%
11
41 a
22
25a
15
17
16
7
Observed
Baseline
Six-Minute
Average
Opacity
15%
0
13
10
5
10
5
0
Adjusted
Peak
Six-Minute
Average
Opacity
33%
13
44a
24
48a
31
35
34
19
Adjusted
Baseline
Six-Minute
Average
Opacity
18%
0
14
21a
11
21
11
0
ro
o
One sixth of electrostatic precipitator plate area was out of service
-------
RATIONALE FOR THE PROPOSED STANDARD
Periods of BOPF Operations Subject to Opacity Standard
Section 60.11(c) of the general provisions applicable to all new stationary
sources of air pollution provides that emissions occurring during periods of
startups and shutdowns of the affected facility are not subject to the limita-
tions of opacity standards of performance. Due to the nature of BOPF operations,
this general exclusion of startups and shutdowns required consideration of the
appropriateness of the exclusion to BOPF operations as well as its effect on the
level of the opacity standard and the need for a time exemption.
Startups and shutdowns are defined in the general provisions in a manner
such that if applicable to BOPF operations, the start of every oxygen blow
and every tap could potentially be exempted from the opacity standard. Conse-
quently, this application of the definitions of startups and shutdowns in the
general provisions to BOPF operations is considered inappropriate. First,
the majority of emissions from BOPFs occur during the start of oxygen blowing
and exemption of this period would make the opacity standard meaningless.
Second, in order for the opacity standard to effectively insure proper operation
and maintenance of the control device, the standard should be applicable to
the same process emissions as the concentration standard. Compliance with
the concentration standard is demonstrated by emission testing over an integral
number of cycles which commence immediately after charging of the vessel and
cease just prior to tapping of the vessel. Therefore, an opacity standard
which applies to the same emissions sampled during compliance tests must limit
emissions during the start of the oxygen blow as well as during the remaining
periods of the cycle. Due to the lower uncontrolled emission rate and the
emission period tested in determining compliance with the concentration
standard, exclusion of the tapping period emissions from applicability of the
21
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opacity standard is not inappropriate. During a normal removal of a BOPF
from production, excess emissions do not occur; however, a shutdown under
malfunction conditions can unavoidably produce emissions in excess of best
demonstrated control levels. The provisions of section 60.11(c) also
exclude malfunctions from applicability of the opacity standard where a
malfunction is a sudden or unavoidable failure of the control system or
process to operate in the normal manner. Therefore, for BOPF operations
only a specific definition of startups is required to ensure continued
proper operation and maintenance of the control device.
For the purpose of standards of performance for basic oxygen process
furnaces, a startup is considered to be only the setting into operation ;
of a vessel after the vessel has been out of operation for a minimum
continuous time period of eight hours. Excess emissions possibly could
occur during the startup of the vessel after routine maintenance and may
persist until the control system reaches stable operating conditions or
the excess pitch is baked off. Thus for BOPF operations, unlike other
batch operations, routine initiations of the production cycle are not
considered startups; and these periods are subject to regulation by the
opacity standard. During periods of startup of a vessel, the owner or
operator is required to control emissions to the maximum practicable extent.
Selection of the Format of the Proposed Standard
As a result of the operation period covered by the concentration
standard, the opacity standard must be structured such that it is indicative
of proper operation and maintenance of the control device over all phases
of the steel production cycle. Analysis of the opacity data showed that
22
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higher opacity emissions occurred during the start of oxygen blowing than
during the remainder of the production cycle for both types of control
systems. Separate opacity standards are necessary for these periods due to
the large variations in gas volume and temperature which result in less
than optimum performance of the control device during brief periods of the
production cycle in addition to the fluctuations in fume generation rate
over the cycle. Several alternative formats for writing the opacity were
considered. The alternative formats considered were writing the standard
(1) to allow higher emissions on a frequency per sixty-minute basis, (2) on
a frequency (once) per primary oxygen blow basis, or (3) on a frequency
(once) per production cycle basis. The advantage of frequency per hour
approach to writing the opacity standard is that compliance with the
standard can be determined without knowledge of, or synchronization with,
shop activities. The major disadvantage of this approach is that the
standard cannot be established at any one level which requires the same
degree of control from both high and low productivity shops. That is, the
need for allowing higher emissions is related to the number of oxygen blows
started in the time period, and high and low productivity shops differ
considerably in this regard (one vs. three oxygen blows in an hour).
The advantage of writing the opacity standard to allow higher emissions
only during oxygen blowing periods is that higher emissions are limited to
the necessary specific process operation, and a blanket exemption is not
provided. However, determination of compliance with this type standard would
be difficult due to the problems at some multiple furnace shops of determining
if emissions in a specific period result from a specific process operation.
This lack of discrete identifiable emission periods for specific process
operations results from the common practice of overlapping the operation
23
-------
of two BOPFs (i.e. charging one BOPF vessel while another is blowing or in
a delay period) and ducting the effluent gases from all vessels to a common
control device. Thus, for these cases it would be difficult to determine
if the separate standard were applicable for any given period in question
and compliance with the standard cannot be ,__.-i.ermined.
The third alternative of Allowing higher emissions on a production
cycle basis requires the same degree of control from both high and low
productivity shops and allows higher emissions only as necessary. This
production cycle approach does have the disadvantage of requiring the
observer to determine the number of production cycles in the observation
period before compliance with the standard can be determined. This require-
ment does not represent a major disadvantage to enforcing the opacity
standard because BOPF shops routinely maintain records of the furnace
operations. Implementation of this approach can be facilitated by
requiring that owners or operators of affected BOPF facilities keep
records of the time of each steel production cycle available for inspection.
As the disadvantages of the production cycle approach can be minimized by
record keeping requirements in the regulation, the proposed opacity
standards were written to allow rn, set of higher opacity emissions in each
steel production cycle.
Selection of Emission Limits
Where opacity and concentration (or mass) standards are applicable to
the same source, EPA establishes the opacity standards at a level which is
not more restrictive than the corresponding concentration (or mass) stan-
dard. Such opacity standards are established at levels which will require
continuous proper operation and maintenance of the control systems at all
24
-------
times. The basis for the opacity limitations considered in the alternative
standards is summarized below:
For scrubber-controlled facilities, analysis of the opacity data showed
that a well-controlled BOPF operating within the expected range of variables
will have emissions of less than 20 percent opacity during oxygen blows and
less than 10 percent opacity during the rest of the cycle. Again these
limitations are based on engineering judgments and evaluations of the per-
formance of the systems and systems required for minimal compliance with
the concentration standard. In the background study on the concentration
standard, it was determined that emissions from a properly operated top blown
BOPF can be reduced to less than 50 mg/dscm using a well-designed scrubber
operating with a minimum pressure drop of 11 kPa (45 in. w.g.) across the
venturi throat. Control of emissions from bdttorn blown vessels requires
operation of the scrubber at a minimum pressure drop of 16 kPa (65 in. w.g.)
to reduce emissions to less than 50 mg/dscm. Observations at Facility G
during a period of operation of the scrubber at a pressure drop of (38 in.
w.g.) showed emissions of 30 percent opacity during an oxygen blow period.
Opacity levels of less than 20 percent during oxygen blow periods and less
than 10 percent were observed when the venturi scrubbers on top blown BOPFs
were operated with pressure drops of 11-14 kPa (45-55 in. w.g.) and when
venturi scrubbers on bottom blown are operated at 16 kPa (65 in. w.g.).
In the selection of the proposed opacity standard, three alternative
standards based on the emission limitations for the two different control
systems were considered. One alternative was to propose separate opacity
standards for scrubber-controlled facilities and for electrostatic
preci pitator-control1ed faci1ities.
25
-------
The standards considered for proposal under alternative A were:
1. Emissions from electrostatic precipitator-controlled facilities
shall be less than 20.percent opacity except emissions of up to
35 percent opacity are allowed once per steel production cycle;
and
2. Emissions from BOPFs equipped with control systems other than
electrostatic precipitators shall be less than 10 percent opacity
except emissions of up to 20 percent opacity may occur once per
steel production cycle.
This alternative established opacity limitations at levels which would
require proper operation and maintenance of either control system. Since
few electrostatic precipitator-controlled facilities will be constructed,
inclusion of a specific standard for these facilities was not considered
necessary. Hence, alternative A was not selected for the proposed standard,
Alternative B recommended that for all control systems emissions shall
be less than 20 percent opacity except that emissions of greater than 20
but less than 35 percent opacity may occur once per steel production cycle.
This alternative opacity standard is achievable by facilities controlled
by either control device whose eni^iions are in compliance with the concen-
tration standard, 50 mg/dscm (0.022 gr/dscf). However, the emission
limitations of alternative B are based on the performance of well-designed
and operated electrostatic precipitator-controlled BOPFs. The majority of
new BOPFs are expected to use processes and control systems that reduce
effluent gas volumes in order to conserve energy. Facilities designed in
this manner must use scrubbers to control particulate matter emissions
because of the explosion hazard in electrostatic precipitators. These
26
-------
scrubber-controlled facilities will discharge emissions to the atmosphere
through small stack diameters relative to those used on precipitator-
controlled facilities; and hence will exhibit lower opacities at equivalent
concentrations. Consequently, opacity limitations established according to
the second alternative would not require proper operation and maintenance
of the majority of new facilities.
The final alternative opacity standard considered required that for
all control systems emissions shall be less than 10 percent opacity except
that emissions of greater than 10 but less than 20 percent opacity may
occur once per steel production cycle. This standard is based on typical
stack diameters and other operating variables expected for scrubber-
controlled facilities operating with emission rates near the level of the
concentration standard. The third alternative considered was to propose
an opacity standard based on typical stack diameters and other variables for
scrubber-controlled facilities operating with emissiqn rates near the
concentration standard. This alternative was selected since most new
facilities will be scrubber-controlled and these opacity limitations would
require proper operation and maintenance of these systems. Therefore,
the proposed opacity standard limits emissions to less than 10 percent
opacity, except emissions up to 20 percent opacity are allowed once per
steel production cycle.
EPA recognizes that electrostatic precipitator-control led facilities
may not be able to achieve the proposed opacity limitations while
concurrently achieving the concentration standard. As very few new
electrostatic precipitator-controlled BOPFs will be constructed, it was
concluded that the opacity standard should not reflect the opacity levels
27
-------
associated with these control systems. Should there be any electrostatic
precipitator-controlled BOPFs subject to the standard, the provisions of
§60.11(e) allow the owner of the facility to request establishment of a
special opacity standard if the facility does not meet the opacity standard
while concurrently complying with the conct.. Oration standard. This approach
to considering electrostatic nrecipitator-controlled BOPFs will not be
administratively cumbersome because it is expected that it will be necessary
to establish few if any special opacity standards.
MONITORING REQUIREMENTS
Section lll(e) of the Clean Air Act, as amended, requires that new
sources continue to be operated in compliance with the applicable standards
throughout their operational life. Under section 301(a) of the Act, EPA
is authorized to prescribe regulations as necessary to carry out its
functions under the Act.. Under this authority EPA establishes process and
control device monitoring requirements for some source categories.
In EPA!s judgment for basic oxygen process furnaces monitoring of
scrubber operating parameters will allow evaluation of the performance of
the control system. For basic oxygen process furnaces constructed after
June 11, 1973, it is proposed to require continuous monitoring of the
pressure loss through the venturi constriction and of the water supply
pressure to the control device. These factors are important in determining
the performance of a venturi scrubber and monitoring these parameters will
provide a means of evaluating the operation and maintenance of the control
system.
These scrubber operating parameters are routinely monitored in any
well-designed and operated facility. Hence, the proposed monitoring
requirements are expected to add negligible additional costs to the total
28
-------
costs of complying with the concentration standard of performance. It is
estimated that the costs of complete monitoring of scrubber operations will
be less than $100,000 for a typical new facility. The proposed opacity
standard is no more restrictive than the concentration standard, and hence
there are no additional control equipment costs associated with the opacity
standard. Therefore, this proposal is not considered a major action under
the Inflationary Impact Statement (IIS) program and no IIS is required.
29
-------
REFERENCES
1. Wheeler, D. H., "Fume Control in L-D Plants," JAPCA. 18(2): 98-101
(1968).; ... • - ~" .
2. Background Information for Proposed New Source Performance Standards:
Asphalt Concrete Plants ..." Sewage Treatment Plants," Volume I,
Proposed Standards, APTD-1352a. June 1972.
3. Air Pollution Emission Test - Final Report,. EPA Office of Air Quality
Planning and Standards, Emission Standards and Engineering Division,
Emission Measurement Branch-, Project, No. 73-BOF-l, December 1975.
4. A Systems Analysis Study of the Integrated Iron and Steel Industry
(Contract No. PH 22-68-75), Battelle Memorial Institute, May 15, 1969.
5. Baum, K., "New Developments in the Wet Scrubbing of Effluent Gases
from Oxygen Steel Works," STAUB. 25(10): 11-18 (1975).
6. Preliminary Report Field Study of In-Stack Transmissometer Measurement
of Particulate Mass Concentration at Jones and Laugh!in Steel Corpora-
tion, EPA Contract No. 68-02-0239.
30
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APPENDIX
31
-------
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TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-450/2-77-004
4. TITLE AND SUBTITLE
Background Information for an Opacity S1
Performance for Basic Oxygen Process Fui
and Steel Plants
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency
Office of Air Quality Planning and Stan
Research Triangle Park, North Carolina
12. SPONSORING AGENCY NAME AND ADDRESS
3, RECIPIENT'S ACCESSION-NO.
5. REPORT DATE .
tandard of March, 1977 (Issuing Date)
"naces in Iron 6. PERFORMING ORGANIZATION CODE
a. PERFORMING ORGANIZATION REPORT NO.
10. PROGRAM ELEMENT NO.
Jdrds 11. CONTRACT/GRANT NO.
27711
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
1S. ABSTRACT
The document presents the basis for the
process furnaces. Included is process
the rationale for the proposed standard
results are also included.
proposed opacity standard for basic oxygen
and emission control information along with
. Monitoring requirements and visual test
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Iron and Steel Plants
Basic Oxygen Process Furnaces
Standards of Performance
18. DISTRIBUTION STATEMENT
Unlimited. Available from Public
Information Center (PM-215), EPA
Washington, D. C. 20460
EPA Form 2220-1 (9-73)
b.lDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air Pollution Control
19. SECURITY CLASS (This Report) 21. NO. OF PAGES
Unclassified 63
20. SECURITY CLASS (This page) 22. PRICE
Unclassified
60
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