ENVIRONMENTAL PROTECTION AGENCY
             OFFICE OF ENFORCEMENT
                  EPA-330/2-77-005-B
                 IMPACT OF
   PARTICULATE  MATTER EMISSIONS

        ON AMBIENT AIR  QUALITY

United States Steel Corporation -  Geneva  Works
      Appendix
Source Identification
                (JULY-AUGUST 1976)
 NATIONAL ENFORCEMENT INVESTIGATIONS CENTER

               DENVER.COLORADO
                  FEBRUARY 1977

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          ENVIRONMENTAL PROTECTION AGENCY
               OFFICE OF ENFORCEMENT
                EPA-330/2-77-005-B
                     IMPACT OF
          PARTICULATE MATTER EMISSIONS
             ON AMBIENT  AIR QUALITY
UNITED STATES STEEL CORPORATION - GENEVA WORKS
      APPENDIX II - SOURCE IDENTIFICATION
                (JULY-AUGUST 1976)
                  FEBRUARY 1977
     NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
                 Denver, Colorado

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                                 -   CONTENTS


   I   INTRODUCTION 	     1
       Background 	     2
       Site Description 	     3
       Project Description  	     5

  II   SUMMARY AND CONCLUSIONS  	     8
       Coke Ovens 	     8
       Coke Byproduct Plant 	    10
       Sintering Plant  	    11
       Blast Furnaces	    12
       Open Hearth Furnaces 	    12
       Rolling Mills  	    13
       Slag Handling Facilities 	    13
       Power Plant	    14
       Miscellaneous Sources  	    14
       Emissions Inventory  	    14

 III   COKE PLANT	    16
       Process Description and Inspection Observations  	    16
         Coal Preparation	    16
         Charging	    17
         Topside	    20
         Pushing	    21
         Quenching	    22
         Doors	    23
         Combustion System  	    25

  IV   COKE BYPRODUCT RECOVERY FACILITIES 	    28
       Process Description  	    28
         Byproduct Gas Plant  	    28
         Benzene Plant  	    31
         Nitrogen Plant 	    34
       Inspection Observations  	    37

  V   SINTERING PLANT  	    40
       Process Description  	    40
         Materials Handing  	    40
         Sintering	    41
       Particulate Emission Sources 	    42
       Particulate Control System 	    44
         Process Emissions  	    45
         Uindbox Cyclones    	    45
         Windbox Scrubbers  	    50
         Discharge-end Scrubber 	    55
       Inspection Observations  	    57

 VI  BLAST FURNACES	    59
       Process Description	    59
         Materials Handling 	    59
         Furnaces	    60
       Particulate Emission Sources 	    63
       Particulate Control System 	    64
       Inspection Observations  	    67

VII  OPEN HEARTH FURNACES	    70
       Process Description  	    70
         Hot Metal  Handling   	    70
         Furnaces	    72
         Ingot Pouring  	    77
       Particulate Emission Sources and Inspection Observations  ....    79
       Particulate Control System 	    81
         Process Emissions  	    81
         Electrostatic Precipitators	    83
         Scrubbers	    87

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                                CONTENTS  (Cont.)


VIII  ROLLING MILLS	   93
        Process Description  	   93
        Slab Hill	     93
          Plate and Hot  Strip Mill   	   94
          Structural  Hill    	                   95
          Pipe Mill	[     97
        Particulate Emission  Sources and  Inspection Observations   .  .  '. .   98

  IX  SLAG HANDLING	   99
        Process Description  	   99
          Open Hearth Side   	   99
          Blast Furnace  Side	101
        Particulate Emission  Sources and Control System  	  103
        Inspection  Observations  	  104

   X  POWER PLANT  	  105
        Process Description  	  105
          Small Boiler Units	105
          Large Boiler Units	106
        Particulate Emission  Sources and Control System  	  106

  XI  MISCELLANEOUS OPERATIONS   	  108
        Foundry   	108
        Pig Casting Machine  	  109
        Chemical Coke Plant   	  Ill

 XII  EMISSIONS INVENTORY 	  112
                                    ADDENDA

     A   Addendum  1 to Study Plan for Air Quality
          Monitoring at USSC-Geneva Works  	  118
     B   EPA June  8 and November 4, 1976 Letters
          to USSC-Geneva Works   	  125

     C   Particulate Grain Loading Calculations 	  138
     D   NEIC Emission Inventory Calculations 	  140

     E   USSC Emissions Inventory Calculations (1974) 	  158

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                                   Tables

  1   Average Chemical Analyses of Quench Water 	  24
  2   Approximate Chemical Analysis of Coke Oven
       Underfire Fuel Gas	27
  3   Typical Composition of Sintering Plant Feed Materials 	  43
  4   Characteristics of Exhaust Gas and Participate
       Emissions for Sintering Plant 	  49
  5   General, Physical, and Design Parameters for
       Sintering Plant Windbox Cyclones  	  51
  6   General and Design Parameters for Sintering Plant
       Windbox Emission Scrubbers  	  53
  7   General and Design Parameters for Sintering Plant
       Discharge - End Scrubber	56
  8   Average Composition of Charge to Blast Furnace 2 -
       August 23, 1976	61
  9   Typical Composition of Clean Blast Furnace Gas  	  66
10   Operating Parameters Monitored at Blast Furnaces  	  69
11   Metallurgical Composition Ranges of Steels Produced 	  71
12   Operating Parameters Monitored at Open Hearth Furnaces  	  78
13   Characteristics of Exhaust Gas and Particulate
       Emissions for Open Hearth Furnaces  	  82
14   General, Physical, and Design Parameters for Open Hearth
       Furnace Electrostatic Precipitators 	  84
15   Operating Data Collected from Open Hearth Furnace
       Electrostatic Precipitators - August 24, 1976 	  85
16   General and Design Parameters for Open Haarth
       Furnace Scrubbers 	  90
17   Typical Monthly Production at Foundry - 1975  	 110
18   Summary of EPA-NEIC Particulate Emissions Estimates 	 114
19   Comparison of Particulate Emissions Estimates
       USSC and EPA-NEIC Emissions Inventories 	 115
                                   Figures

 1   Facility Location - USSC Geneva Works   	   4
 2   Plot Layout - USSC Geneva Works	   7
 3   By-Product Gas Plant Flow Diagram -  USSC  Geneva Works 	  29
 4   Benzene Plant Flow Diagram - USSC Geneva  Works  	  32
 5   Nitrogen Plant Flow Diagram - USSC Geneva Works 	  35
 6   Sintering Plant Windbox Emission Control  System -
       USSC Geneva Works	46
 7   Sintering Plant Windbox Scrubber - USSC Geneva Works   	  47
 8   Sintering Plant Discharge End Scrubber -  USSC  Geneva  Works   ...  48
 9   Open Hearth Emission Control  System  - USSC Geneva  Works  	  73
10   Open Hearth Scrubber -  USSC Geneva Works	89
11   Open Hearth Slag Processing Flow Diagram
       Heckett Engineering Company 	 100
12   Blast Furnace Slag Processing Flow Diagram
       Heckett Engineering Company 	 102

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                           I.   INTRODUCTION
BACKGROUND

     In May 1972, EPA disapproved the control  strategy for participate
matter for the Wasatch Front Intrastate Air Quality Control  Region
(AQCR) in Utah.  On May 14, 1973, EPA promulgated particulate matter
control regulations applicable to, among other things, several of the
process and fugitive sources at United States Steel Corporation (USSC) -
Geneva Works, Orem, Utah.  USSC, in turn, filed a "Petition for Recon-
sideration."

     Following meetings with USSC and several plant visits, EPA proposed
amendments to those regulations and held a public hearing.  On September
5, 1974, EPA promulgated final particulate matter regulations for USSC
in the Utah State Implementation Plan (SIP), including:

     a.   45 seconds visible emissions allowed for coke pushing

     b.   35 seconds visible emissions allowed for coke charging

     c.   5% of the coke oven doors, charging hole covers, and stand-
          pipes allowed any visible emissions

     d.   10% of the chuckdoors and elbow covers allowed any visible
          emissions

     e.   0.027 gr/scf allowed from open hearth furnaces  (8-hr avg)

     f.   0.035 gr/scf allowed from sintering plants  (2-hr avg)

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On October 4, 1974, USSC filed a second petition challenging certain
aspects of the revised regulations.

     The EPA Region VIII office developed and in December 1975 submitted
a revised set of regulations through the EPA concurrence route.  These
proposed regulations:

     a.   acknowledged that the Utah visible emissions regulation is not
          applicable to coke pushing operations

     b.   allowed 10% of the coke oven doors to produce visible emissions

     c.   required the Geneva Works power plant to meet 0.1 Ib particu-
          late/10  Btu.  (Other power plants in the AQCR are required to
          meet 0.34 lb/10  Btu.)  The Region also provided a technical
          summary to justify their actions; the justification focuses on
          a revised emissions inventory and current air quality data.

     On March 12, 1976, the EPA Division of Stationary Source Enforcement
(DSSE) expressed concern with the Region VIII technical justification
underlying their regulation package and asked the National Enforcement
Investigations Center (NEIC) to gather additional data (emissions and
air quality) to evaluate the adequacy of the existing set of regulations
for the control of particulate matter from USSC Geneva Works.

     The report evaluating the adequacy of the Utah SIP as it pertains
to USSC Geneva Works is contained in four volumes.  Appendix I - Ambient
Air Quality deals with the design, operation, and results of the NEIC
air quality monitoring effort.  Appendix II - Source  Identification
deals with the evaluation of the process operations and the air pollution
control equipment, as well as the development of a revised emissions
inventory.  Appendix III - Source/Receptor Relationships deals with the
methodology employed, analyses performed, and results of the NEIC emissions

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characterization effort.  The fourth volume, Summary Report,  contains  an
analysis of all the findings in the three appendices, and the recom-
mendations.
SITE DESCRIPTION

     The United States Steel  Corporation (USSC) - Geneva Works is a
steel production facility located on the eastern shore of Utah Lake near
Orem, Utah [Figure 1].  The facility, constructed in 1942-43, was owned
and operated by the U. S. Government during World War II.  After the War
it was purchased by USSC and  has been operated by them ever since.

     The Geneva Works is a totally integrated steel production facility.
Three blast furnaces, four coke batteries, a coke byproducts complex
containing three separate plants, a sintering plant, ten open hearth
furnaces, and rolling mills for structural shapes, plate and strip steel
and steel pipe comprise the main production facilities.  Support services
include a foundry area, a power plant with turbo blowers and turbo
generators, slag handling facilities and shop areas.  Figure 2 is a plot
layout for the facility.

     About 4,600 people are employed at the Geneva Works when the plant
is in full operation.  Estimated annual production capacities provided
by USSC are based on a three-blast-furnace operation supplying about
1,440,000 m. tons (1,585,000 tons)/yr of hot metal.  The open hearth
furnaces produce about 2,200,000 m. tons (2,400,000 tons)/yr of ingot
steel from the hot metal plus scrap.  The ingot steel is consumed to
produce about 670,000 m. tons (750,000 tons) of steel plates, 960,000 m.
tons (1,060,000 tons) of coiled strip, 140,000 m. tons (155,000 tons) of
sheets, and 77,000 m. tons (85,000 tons) of structural shapes.  Ingots
are also shipped to other USSC plants on the West Coast for further
processing.

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1.  Foci/ify  Locaf/on  -  USSC  Geneva  Works

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PROJECT DESCRIPTION

     In June 1976 the NEIC developed an addendum to the Study Plan for
Air Quality Monitoring at USSC Geneva Works [Addendum A].   In this
addendum the required activities and time scheduling for the second
phase of the study (emissions inventory/characterization)  were defined.

     On July 1 and during the period August 23-27, 1976, NEIC personnel
conducted a thorough facilities inspection and operations  evaluation at
the Geneva Works.  The plant visits were announced in advance to USSC
and had been preceded by a letter sent on June 8, 1976 under the authority
of Section 114 of the Clean Air Act, as amended, requesting substantial
quantities of information.  A subsequent letter dated November 4, 1976
requested additional process and operating data [copies of both letters
appear in Addendum B].  The information obtained by both letters plus
that obtained during the July 1 and August 23-27 plant visits have been
incorporated into this appendix.

     The purposes of the plant visits were threefold:  1) to obtain an
understanding of the routine operations of the various processes at the
facility and the process variability, 2) to inspect air pollution
control equipment and work practices in use at the facility, and 3) to
develop an emissions inventory for  particulate matter emitted from the
facility.  The utility of the emissions inventory is, of course, greatly
influenced by the success of the first two objectives, as well as the
quality of the information obtained  from the Company during  the inspection
interviews and from  the Section 114  letter responses.

     The facility  inspection was prescheduled with USSC personnel to
allow  approximately  one-half day for each of the major processes, with
time allotted for  the smaller processes and/or support functions on an
 'as available' basis.  Pre-inspection conferences were held  each morning
between USSC  Plant Engineering  and  NEIC personnel for an overview of  the

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unit operations and coordination of the  day's  activities.   The  following
schedule was observed during the inspection:

          Monday, August 23, 1976
               a.m. - Pre-inspection briefing
               p.m. - Blast furnace operations
          Tuesday, August 24, 1976
               a.m. - Open hearth furnaces
               p.m. - Continuation  of same
                      Foundry area
                      Open hearth control system

          Wednesday, August 25,  1976
               a.m. - Raw materials handling
                      Sintering  plant
                      Sintering  plant control  systems
               p.m. - Coke production
                      Open hearth control system

          Thursday, August 26, 1976
               a.m. - Rolling mills
               p.m. - Coke byproduct plants
                      Coke plant
          Friday, August 27, 1976
               a.m. - Power plant
                      Pig casting machine
                      Raw material  unloading
                      Hot metal  mixing building
               p.m. - Pipe mill
                      Inspection debriefing

     The Heckett Engineering Company's slag handling operations,  located
on the northwest corner of the USSC plant site [Figure 2],  were inspected
independently on July 1, 1976.  NEIC personnel worked  directly  with
Heckett personnel in arranging and  conducting  this  inspection,  since
this operation, although located on USSC property,  is  independent of
USSC.

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c—'     llMTOOCEM PLANT j'\J  p	I—'


 IDU	_!}[.-	  '         COAL CHflCAL Pl»
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                         Figure  2.  Plof tayouf - USSC  Geneva Works

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                      II.   SUMMARY AND CONCLUSIONS
      In  response  to  a  request by  the EPA Division of Stationary Source
 Enforcement,  the  NEIC  undertook an evaluation of the particulate emissions
 from  the United States Steel Corporation - Geneva Works at Orem, Utah,
 and the  effect of these emissions on the ambient air quality of the
 Wasatch  Front Intrastate AQCR.  One portion of the NEIC program was
 oriented to investigating the particulate emission potential of USSC
 process  operations,  the evaluation of installed air pollution control
 equipment, and the development of a revised emissions inventory for the
 facility.  Facility  inspections were conducted on July 1 and August 23-
 27, 1976 to obtain specific process information to evaluate subjectively
 the particulate emission potential of the various processes.  Two compre-
 hensive  letters were also written to USSC requesting supplemental infor-
 mation on plant operations.  This appendix summarizes the results of
 these investigations.

     The following conclusions were developed based on the information
 obtained during those  site visits and from the information provided by
 USSC in  response  to EPA letters.


 COKE OVENS

     1.   Charging operations contribute significantly to the particulate
 emissions associated with the coke batteries.   A form of stage charging
 is employed at Geneva; however, the emissions  observed during seven
 charge sequences were  in excess of those at other stagecharged batteries
 observed by NEIC personnel.   Visible emissions during charging ranging
 from 40 to 100% opacity and  in excess of 35 seconds  duration were observed
during the inspection.

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     A major problem associated with the stage-charging technique employed
at Geneva appears to be an inadequate number of topside personnel for
the charge schedule.  Two persons, a larry car operator and a lid-man,
are responsible for a variety of topside operations including the entire
charge sequence, cleaning of goosenecks, mudding of charge port and
standpipe caps, etc.  The charge sequence of one oven every eight minutes
leaves very little time for error in personnel coordination.

     The current practice at Geneva of delaying the operation of the
push machine leveling bar until after the charge sequence is completed
is contrary to the practice at other coke batteries observed by NEIC
personnel.  USSC personnel stated that the coal used at Geneva Works to
charge the ovens has a naturally flat angle of repose and, hence, the
need for a leveling operation during the charge is minimal.  From the
density of charging emissions noted during the inspection, it appeared
that the oven aspiration was not sufficient to evacuate the gas volumes
generated during the charge.  Insufficient steam aspiration at the
collector mains and/or peaking of the coal in the ovens could be contrib-
uting to the charging emissions problems.

     2.   Several topside emissions were noted at the Geneva facility.
Numerous leaks were noted from oven charge port lids and standpipe caps.
The lid luting efforts were only partially successful, possibly due to
the technique employed (i.e., mopping the mud vs. pouring from a ladle),
the consistency and/or amount of luting material us.ed, the lid/casting
interface fit, or the general shortage of topside personnel.

     Several significant leaks were noted in the collector mains them-
selves.  These leaks appeared to be due to inadequate maintenance.

     3.   Coke pushing emissions observed during the inspection ranged
in opacity from 20 to 30% and appeared to result from thermal buoyancy
of coke fines.  No emissions normally associated with uncoked coal,
i.e., green coke, were noted during the inspection.

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      4.   A brief inspection of leaking pushside doors and chuck doors
 on battery 1 indicated that this battery would not have complied with
 the SIP regulation.

      5.   Considerable quantities of fine particulate  matter were noted
 in the coke quench plume after the steam had  dissipated.   USSC quenches
 the hot coke with contaminated water which contains  waste  products from
 the coke byproducts  plant,  such as excess flushing liquor.

      USSC reportedly uses impregnated pine baffles in  the  quench tower
 chimneys to knock out large particulate in the quench  plume.   It was
 noted that the  baffles in the  north quench tower were  in poor repair
 during the inspection.

      6.    The combustion stacks  on  batteries  1  and 4 were  noted  to
 periodically discharge dense plumes;  battery  1  stack emissions were
 periodically in excess of 40%  opacity.
COKE  BYPRODUCT PLANT

      1.   The majority of the operations conducted in these facilities
employ closed systems and, hence, do not pose a particulate emission
problem.

      2.   Waste flushing liquor and other waste byproduct liquid streams
resulting from these operations are currently discharged to the coke
quench water systems.  As a result, they indirectly contribute to the
particulate emissions from the complex.

     3.   The prill tower, and driers/coolers, and the blending opera-
tions at the ammonium nitrate facility are potential  sources of particu-
late emissions.   Of these sources, the uncontrolled prill  tower exhaust
appears to be the most significant with calculated emissions averaging

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                                                                         11
0.13 m. ton (0.14 ton)/day.  The other sources discharge to control
systems.

     4.   There are no sulfur removal systems installed on the coke oven
gas treatment facilities at the Geneva Works.  Sulfur dioxide emissions
from the combustion of these gases at the coke ovens and throughout the
facility could substantially contribute to the ambient sulfur dioxide
levels in the AQCR.  Further investigation of these contributions is
beyond the scope of the NEIC project.


SINTERING PLANT

     1.   Fugitive emissions were observed at the iron ore crushing and
screening stations adjacent to the sintering plant.  Water spray systems
at these locations were ineffectual or inoperative.

     2.   It is questionable whether the sintering machine windbox
emissions control system is adequate to meet the SIP requirement of 0.08
   o
g/m  (0.035 gr/scf).  The USSC-quoted removal efficiency for the scrubber
systems appears to be overstated.  The potential for particulate addition
due to mist carryover has been neglected in USSC considerations of
particulate removal efficiencies.

     Significant particulate plumes ranging from 10 to 40% opacity were
noted from the windbox scrubber exhaust stacks after the steam dissipated.

     3.   The exhaust hooding and ductwork associated with the discharge-
end of the sintering machines was in very poor repair.  Collection
efficiencies were severely reduced and fugitive emissions from these
sources were observed to be significant.  Insufficient information was
available to evaluate the performance of the scrubber system which
theoretically controls the emissions from these sources.  However, in
light of the collection efficiency problems mentioned above, it is

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                                                                         12
improbable that the scrubber is currently treating a satisfactory propor-
tion of the discharge end emissions.

     4.   Heavy fugitive emissions were noted at the sinter hot screen-
ing facility.   Incomplete sintering of the feed materials and poor
operation of water spray nozzles contributed to this problem.

     5.   Periodic heavy emissions were noted from the vents serving the
sintering plant pug mills.  Company personnel indicated that water
supply problems contribute to this condition.

     6.   The sintering plant is an antiquated facility.  The material
feed systems, pug mills, and sinter cooling facilities were originally
installed in the early 1940's and are not state-of-the-art.


BLAST FURNACES

     1.   The furnace hot metal casting and slag flushing operations are
significant sources of fugitive particulate emissions.  These emissions
are currently uncontrolled.

     2.   Some particulate leakage was noted from the hopper bells atop
furnaces 2 and 3.  Furnace 1 was not in operation during this inspection.

     3.   No furnace slips were observed during this inspection.

     4.   No visible emissions were noted from the stove combustion
stacks when the furnaces were in a normal operating mode.


OPEN HEARTH FURNACES

     1.   It is questionable whether the emission control systems on the

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                                                                         13
open hearth furnace exhausts can comply with the SIP regulation of
0.062 g/m  (0.027 gr/scf).   The electrostatic precipitator maintenance
and operating procedures appear inadequate.   The USSC-derived particulate
removal efficiencies for the scrubber units  used on these systems appear
to be overstated.  Mist carryover from the scrubbers, adding to the
exhaust gas particulate load, appears to be  a significant problem.

     2.   The open hearth furnace operations are significant sources of
fugitive particulate matter.  Fugitive emissions were observed from hot
metal transfer and reladling operations, furnace leaks, furnace charging
and tapping operations, and ingot pouring procedures.  All of these
fugitive emissions are uncontrolled.
ROLLING MILLS

     1.   There are no hot scarfing operations at the Geneva Works.
Handscarfing of slabs and blooms constitutes a minor fugitive emission
problem.

     2.   The major particulate emissions associated with the rolling
mills are the combustion of fuel oil in the soaking pits and reheat
furnaces of the facilities.


SLAG HANDLING FACILITIES

     Particulate emissions associated with this operation include fugi-
tive emissions from storage piles, haul roads, and crushing operations,
These emissions appear to be controllable with judicious use of water
sprays.

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                                                                        14
POWER PLANT

     The five power boilers are potential  major sources of particulate
emissions when they are fired with coal.   Currently none of these boilers
has an emission control system.  USSC is  in the process of installing
baghouse control systems for the three larger boilers.


MISCELLANEOUS SOURCES

     1.   The foundry sand reclaim system is a potential source of
particulate emissions.  Emissions from this system are reportedly
controlled by wet scrubbers.  These scrubbers were not seen in operation
during the inspection.

     The foundry casting operations are potential minor sources of
fugitive particulate emissions.

     2.   The pig casting machine at Geneva is a potential minor source
of fugitive emissions.  This unit is only operated intermittently.

     3.   The drier exhaust stacks on the chemical coke plant emit con-
siderable quantities of particulate emissions.  These exhaust stacks are
uncontrolled.
EMISSIONS INVENTORY

     Particulate emissions data computed by NEIC for the various sources
at the Geneva Works indicate an average daily particulate emission rate
during the period June-August 1976 of approximately 36 m. tons (38
tons)/day.  Fugitive emissions from storage piles, paved and unpaved
roads, and various open areas accounted for approximately 42% of this

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                                                                 15
total.  Several significant differences were noted between the NEIC-
calculated figures and those previously submitted by USSC to the EPA.
The majority of these differences can be accounted for by the use of
updated or additional emission factors, more in-depth evaluation of the
sources, or consideration of additional sources.

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                           III.  COKE PLANT
PROCESS DESCRIPTION AND INSPECTION OBSERVATIONS

     There are four coke batteries at the Geneva facility, numbered 1,
2, 3, and 4 in a south-to-north orientation.  Each battery has sixty-
three Becker type underjet ovens.  The ovens are tapered from 33 cm (13
in) wide at the pusher side to 39.4 cm (15.5 in) wide at the coke side
and are 4 m (13 ft) high by 12.3 m (40.5 ft) long.  The coke ovens
              3        3
average 16.3 m  (576 ft ) in volume and produce approximately 8 m. tons
(9 tons) of coke per 13.2 m. tons (14.5 tons) of coal charged.  The
normal coking cycle for these batteries is 16.25 hours during the summer
months and 15.75 hours in the winter.
Coal Preparation

     Coal used in the coking operations is received from three sources.
High volatile content coal is obtained from two USSC mines operated at
Price, Utah and at Sommerset, Colorado.  Both of these coals average 37%
volatile material, 0.6 to 0.7% sulfur, and 7.0% ash, all percentages by
weight.  The Sommerset coal is washed and dried at the mine site.   The
Price coal is washed and dried at Wellington, Utah.

     USSC purchases medium volatile coal  from the Mid-Continent Coal
Company which operates a mine near Carbondale, Colorado.  This coal
averages 25% volatile material, 0.6% sulfur, and 6.5% ash.  It is  washed
and dried at the Carbondale site before being shipped to the Geneva
Works.

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                                                                         17
     Coal from all  mines is received at Geneva in gondola railroad cars.
The cars are emptied by a Link Belt rotary railroad car dumper.  The
coal is transported via conveyor belts to two storage yards with a total
net capacity of 68,000 m. tons (75,000 tons).

     High and medium volatile coals are reclaimed from the storage yards
and transported via conveyor belts to two Pennsylvania center feed
hammer mills operating in parallel.  Each of these units has a capacity
of 320 m. tons (350 tons)/hr.  The crushed coals are then blended to
obtain the desired volatile content and sent to two Jeffery Manufacturing
Company reversible hammer mills for pulverizing and blending.  No. 2
fuel oil (without additives) is mixed with the blended coal at this
time.  Approximately 3.1 liters/m. ton coal  (0.75 gal/ton coal) of oil
is added.  The pulverized coal is screened and then sent to storage
bunkers atop the coke batteries.  Oversized material from the  screening
operations is recycled to the secondary hammer mills.

     The final coal blend sent to the  storage bunkers  is 70% less than
0.31 cm  (1/8 in) and has a moisture content  of 5.0 to  5.5% by  weight.
Volatile content is about 35%.

     There are two  storage bunkers at  the  coke batteries, each with a
capacity of 2,300 m.tons (2,500 tons).  Each  bunker serves two batteries.
One  bunker  is  located  between batteries  1  and 2  and the  other  between
batteries 3 and 4.
 Charging

      USSC employs  a  stage charging  technique at Geneva.   The  ovens  each
 have three charging  ports and dual  gas  collection  mains.   There are
 three,  three-hopper  larry cars available  at the batteries.   Normally one
 is kept in reserve status and the other two service the  four  batteries  -•

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                                                                       18
one for batteries 1  and 2 and one for batteries 3 and 4.   Two topside
personnel operate as a team servicing each pair of batteries.  They
alternate between the larry-car-man and lid-man roles.  It is normal
procedure to charge (and push) seven ovens per battery on an "alternating
tens" sequence and then to repeat the sequence on the adjoining battery.

     A normal charging sequence lasts approximately 2.5 to 3 minutes
from the time the larry car is positioned above the oven  charge ports
until the final port lid is replaced at the end of the charge.  The
procedural sequence is as follows.

     1.   The larry car hoppers are loaded with the coal  charge at the
          coal storage bunker and the car moves to the oven to be charged,

     2.   The charging port lids from ports No. 1 and 3 are manually
          removed while No. 2 lid remains in place.

     3.   The larry-car-man lowers the hopper sleeves from hoppers No. 1
          and 3 around the charge ports.

     4.   The steam aspiration jets at both collector mains are turned
          on and the oven is connected to the two collector mains by the
          lid-man.

     5.   The larry-car-man discharges hoppers 1 and 3 simultaneously
          into the oven.

     6.   After hoppers No. 1 and 3 have been discharged into the oven,
          the drop sleeves are retracted and the larry car is backed off
          about 3 m (10 ft).

     7.   The lids on ports No. 1 and 3 are then replaced, and lid No. 2
          is removed.

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                                                                        19
     8.   The larry car is then repositioned over the oven and hopper
          No. 2 is discharged.  All three of the larry car hoppers
          discharge approximately the same quantity of coal into the
          oven.

     9.   At the conclusion of No. 2 hopper discharge, the larry car is
          once again backed off about 3 m (10 ft), and No. 2 lid is
          replaced.

     10.  The two steam aspiration systems are then turned off and the
          charge port lids are mudded with a sealing mud.

     11.  The larry car then returns to the bunker for another coal
          charge.

     12.  After the charging operation is completed, the pusher machine
          operator opens the oven chuck door and makes one complete pass
          of the oven with the leveling bar.  USSC personnel reported
          that only one leveling bar pass is required because the coal
          has a relatively flat natural angle of repose and assumes a
          flat surface without additional leveling.

     During the NEIC inspection of the coke batteries, seven oven charges
were observed.  Visible emissions ranging from 40% to 100% opacity were
noted from all three charging ports.  The emissions did not pass from
the charge ports through the hoppers to the atmosphere; rather they
normally escaped from the ports directly to the atmosphere.  Emissions
ranged from black and brown to yellow-white in color and lasted from 30
to 90 seconds.

     USSC personnel reported they had modified the steam aspiration
systems for the batteries in an attempt to reduce the charging emissions.
They have experimented with various sized steam nozzles ranging as large

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                                                                        20
as 1.9 cm (3/4 in) diameter units.  They found that too many fine particles
were carried over into the collector mains with these larger units and
decided to use 1.3 cm (1/2 in) diameter nozzles.  Plant steam is reported
                                                      2
to be delivered to the aspiration nozzles at 8.8 kg/cm  (125 psi) gauge
pressure.  USSC personnel had no records on steam usage per battery nor
did they have any figures as to the amount of gases which could be
                                                                    2
aspirated from an oven with the 1.3 cm (1/2 in) nozzles at 8.8 kg/cm
(125 psi) steam pressure.
Topside

     The general condition of the topside brickwork of the batteries
appeared to be good.  There were no noticeable leaks in the paving brick
nor were there leaks at the brickwork/port casting interfaces.  USSC
personnel mentioned that several port castings are in poor condition
resulting in a poor seal between the casting and the lid.

     Several significant leaks were noted in the collector mains themselves
and the oven standpipes.  These leaks were apparently the result of
corrosion, poor joints, etc.

     The oven charging port lids and standpipe caps were routinely
sealed with a luting material (refractory mud slurry).  The luting
material was swabbed onto the lid or cap with mop-like devices.  The
sealing efforts were only partially successful; numerous leaks were
noted on both the charging port lids and standpipe caps.

     The goosenecks and standpipes were manually cleaned by topside
personnel working on the first and second turns.  The pipes were rodded
out with steel bars while the oven was decarburizing before a charge.

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                                                                         21
      A general  impression  obtained during  the  topside  inspection was
 that  the  two  topside  personnel  have  a  large  number  of  tasks  to  perform
 and cannot  successfully  do them all.   The  charge  sequence  requires  each
 topside crew  to charge an  oven  every eight minutes.  The charge itself
 takes 2-1/2 to  3 minutes and  the travel  time to and  from the bunker plus
 filling the larry  car hoppers accounts for another  3 to 4  minutes.  It
 is obvious  that little time is  available for lid  sealing and gooseneck
 cleaning, much  less attending to operational abnormalities.   Also,
 considerable  coordination  is  required  between  the larry car  operator and
 the lid-man during the charge to insure  that the  oven  is connected  to
 the collector main and aspirated correctly.  It was  noted  that  such
 coordination  was lacking at times during this  inspection.


 Pushing

      The Geneva  coke  push  cycle  is similar to  the charge cycle, in  that
 seven ovens are  pushed on  one battery  in an  alternating tens  sequence.
 After completing the  sequence on one battery,  the pusher machine moves
 to the adjacent  battery.   One pusher machine services  two  batteries.

      Five coke  pushes were  observed during this inspection.   None of
 these pushes  were  noted  to  contain green coke; all observed  pushes
 appeared to be  thoroughly  coked.  No voluminous clouds of  smoke and
 flame were  observed.  It was noted, however, that substantial quantities
 of fine coke  particles were carried aloft by thermal buoyancy, resulting
 in plumes of  20  to 30% opacity.

     Time did not  permit an exhaustive visible emissions evaluation of
 pushing operations; however, at  times during the remainder of the week,
 it was possible to observe additional pushes from a distance.  Although
 no official  records were kept, it appeared that at least two to three
 times  per day dense push emissions normally associated with green coke
were observed.

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                                                                         22
     To  assure homogeneous coking  in each oven, Geneva personnel routinely
 check  the  flue and  oven temperatures to insure that an even heat distribu-
 tion is  being obtained.  On the day turn  (No. 2), the two end ovens of
 each battery get a  complete cross-wall check of flue temperatures.
 Also,  all  ovens are checked for coke and  push side flue temperatures.
 On  No. 3 turn, the  coke side flues are checked on all ovens.  Three
 ovens  on each battery, on a rotating basis, are checked during each turn
 for oven temperatures.  Any temperature irregularities noted during
 these  inspections are corrected by adjusting the burning patterns of the
 underfire  jets or by removing the jets for major maintenance and cleaning.


 Quenching

     There are two  coke quench towers at the coke plant.  The south
 tower  services batteries 1 and 2 and the north tower services batteries
 3 and  4.  Contaminated industrial water from the byproduct plant is used
 at  both  towers.

     Both of the quench towers are equipped with impregnated white pine
 baffles  which are arranged in a single layer just below the stack portion
 of  the tower.  The  baffle design is based on the results of a study
 conducted at the USSC Clairton, Pennsylvania, coke works.

     Geneva personnel reported that it is difficult to keep the quench
 tower baffles in place due to the intense heat of the coke.  The baffles
 must be  replaced "every few months."  During the NEIC inspection it was
 noted that several  of the baffle portions in the north quench tower were
 missing.

     As mentioned above, USSC uses contaminated byproduct recovery
wastewater for quench water.   The quench water for the south tower
 contains the "devil  liquor"  which is acquired from blowdown of the

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                                                                        23
ammonia sulfate recovery process and the excess flushing liquor.  The
quench water for the north tower contains contaminated caustic material
from both the Benzene Plant and the Nitrogen Plant plus condensed water
from the latter plant.  USSC reported that they use approximately
15,000 liters (4,000 gal) of contaminated water per quench.  The analyses
of an average quench water sample are summarized in Table 1.

     During a quench, both towers exhibited copious quantities of satura-
ted steam.  Substantial particulate plumes were observed from both
towers after the steam had dissipitated.  The particulate plume from the
south tower appeared to be consistently denser than that from the north
tower.  Also, particulate emissions continued to evolve from the quench
car after it had been removed from the quench tower area.  The particu-
lates were noted to be white-grey in color.
Doors
     Leaks from the push side, coke side, and chuck doors of the four
batteries were observed during this inspection.  A brief door survey was
conducted on the pushside doors of battery 1; 12% of the oven doors and
20% of the chuck doors were observed to be leaking during this inspection,

     Geneva personnel reported that they have a routine door maintenance
program.  Every door and door jamb assembly is cleaned manually with a
spud bar when the door is removed during a push sequence.  Daily, twelve
doors per battery, on a rotating schedule, are given a thorough cleaning.
The normal door cleaning complement consists of three persons per pair
of batteries:  two on the pusher side, and one on the coke side.   On the
day turn, there are two additional men per pair of batteries, one for
the pusher side and the other for the coke side.   These individuals are
responsible for cleaning the chuck door (on the pusher side) and the
door jambs down to the first lock bar (on both sides).

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                                                                        24
                                Table 1
               AVERAGE CHEMICAL ANALYSES OF QUENCH WATER
                          USSC - GENEVA WORKS
 Chemical Constituent                          Concentration (ppm)
Total Dissolved Solids                               4,876
Total Suspended Solids                                 155
Phenol                                                  45
Sulfates                                                64
Sulfites                                               352

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                                                                         25
      Geneva personnel  report  that  they also  routinely remove  doors  from
 the ovens for major repair of the  refractory plugs  and knife  edges.
 Through July 24,  200 doors were  reported  to  have  been rehabilitated
 during 1976 and  90% of these  had received both  plug change  and  knife
 edge repair.

      The oven doors at Geneva are  equipped with spring steel  knife
 edges.   These knife edges  can be externally  adjusted while  the  doors  are
 in  place.   If significant  leakage  is  noted from any door, the battery
 maintenance personnel  can  adjust these knife edges  to attempt to  seal
 the knife edge against the jamb.
Combustion System

     By design, the Becker type coke ovens burn fuel gas on an entire
oven wall simultaneously.  The products of combustion from the vertical
flues of the walls in which the gas is burning ("on" walls) enter short
bus flues and then are conducted over the top of the oven through
cross-over flues to a companion series of bus flues on the opposite wall
("off" walls).  The combustion products are routed from here through the
vertical flues of the "off" wall to checker regeneration systems for
heat recovery.  Every thirty minutes the gas flow through the checkers
and flue system is reversed.   The stored heat in the checker brickwork
is thus recovered by the incoming combustion air.

     The products of combustion leaving the regenerative checkers are
collected in waste heat flues and routed to waste  heat stacks.   Each
battery has its own waste heat stack which is 76 m (250 ft) high and
tapers from a base diameter of 5.2 m (17.25 ft)  to an outlet diameter of
3.3 m (10.75 ft).

     The main parameters affecting emissions  discharged  from the waste

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                                                                        26
heat stacks are the air-to-fuel ratio in the combustion gases, the
"cleanliness" of the fuel gas, and the general condition of the oven
walls.  Geneva uses coke oven byproduct gas as fuel to the coke oven
underfire system.  This gas, which has been purified in the byproduct
recovery plant, consists mainly of methane and hydrogen and has an
average heat content of 4,000 to 5,200 kg-cal/m3 (560 to 580 Btu/ft3).
Approximately 0.8 x 106 m3 (27 x 106 scf)/day of this fuel is burned in
the four coke batteries.  Table 2 is an approximate chemical analysis,
provided by USSC personnel, of this gas.

     During the inspection an evaluation of oven wall condition was not
conducted.  However, Geneva personnel reported they use a mud gun to
repair brickwork cracks with a fireclay mud slurry.  They reportedly
repair three to four ovens per day.  They do not routinely mud the roofs
of the ovens since they feel that their roof decarburization program has
helped improve roof brick life.

     Visible emissions were observed from the four battery waste heat
stacks periodically throughout the duration of the week-long inspection
period.  Batteries 1 and 4 exhibited the densest plumes for the longest
periods of time.  At times, battery 1 stack emissions exceeded 40%
opacity.

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                                                                        27
                                Table 2
              APPROXIMATE CHEMICAL ANALYSIS OF COKE OVEN
                          UNDERFIRE FUEL GAS
                          USSC - GENEVA WORKS
 Gas Constituent                                  % by Volume

Hydrogen                                              50
Methane                                               26
Carbon Monoxide                                       10
Carbon Dioxide                                         3
Nitrogen                                               4
Hydrogen Sulfide                                      0.48
Miscellaneous Hydrocarbon                             6.52

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                 IV.  COKE BYPRODUCT RECOVERY  FACILITIES
PROCESS DESCRIPTION

     Coal decomposition products, which are mostly gaseous, are exhausted
from the  individual coke ovens through the oven standpipes and goosenecks
into the  battery collector mains.  There are two collector mains per
battery which are connected by jumper pipes at the north and south ends
of the batteries.  These jumper pipes are center tapped to four mains,
one per battery, which route the decomposition products to the Byproduct
Gas Plant.  At the Geneva Works, byproduct recovery is accomplished in
three separate plants: the Byproduct Gas Plant, the Benzene Plant, and
the Nitrogen Plant.  Each is discussed separately.
Byproduct Gas Plant

     Figure 3 shows a simplified process flow for the Byproduct Gas
Plant.

     The coal decomposition products collected from the four batteries
are first passed through knock-out pots to remove the main flushing
liquor.  This liquor is a combination of the liquor sprayed into the
collector mains to flush out particulate matter and condensed tars from
the coke ovens and the condensed water vapor driven from the charged
coal.  The flushing liquor collected in the knock-out pots is sent to
tar decanter units.  Here tar-like materials are removed from the liquor
by gravity separation, stored, and ultimately sold to a scavenger opera-
tion.  The separated flushing liquor is then chilled in shell and tube
cooling units before advancing to the next stage of the gas treatment.

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                TO FLARE
           GAS
          STORAGE
         V TANK  /
TO COKE OVEN
UNDER FIRE
  TO NITROGEN
     PLANT
      TO FLARE
 TO PLANT-WIDE
GAS SYSTEM
              1 J FINAL COOLERS
                                 SATURATORs(2
               ,\
               'B-T-X
                SCRUBBERS
                                         TAR PRECIPITATORSI
                                            AND REHEATERS,
                FINAL
                PRECIPITATORS
                                            EXHAUSTERS
                                                                1
                                          PRIMARY COOLERS(3;  (Z)   (l
                                             I
                                                                 KNOCK-OUT
                                                                 POTS
                                                       I
                                            COKE
                                           BATTERIES
     {BATTERIES}   |
DQ       QD
          Figure 3. By-Product Gas Plant Flow Diagram  - USSC Geneva Works
                                                                                  ro
                                                                                  vo

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                                                                        30
      The  coke  oven  gases  are  exhausted  from  the  knock-out pots  into
 three parallel  cooler units.   Here  the  gases are cooled  by indirect
 contact with the  chilled,  decanted  flushing  liquor  mentioned  above.   The
 coolers are vertical  steel  towers with  wooden baffles.   The flushing
 liquor discharged from these  coolers  is recycled through the  shell and
 tube  chiller units  in a closed loop.  Flushing liquor  is continuously
 blowndown from  this  loop  and  sent to  an ammonia  stripping still  for
 ammonia recovery.   Effluent from this still  is either  recycled  to  the
 collector mains or  discharged  from  the  system and used as coke  quench
 water.  The wasted  flushing liquor  is termed "devil  liquor."

      The  cooled coke  oven  gases are discharged from the  primary  coolers
 through four parallel  steam powered,  centrifugal  pumps termed exhausters.
 These  units supply  325  mm water vacuum  to bring  the  coke oven gases from
 the ovens, through  the  collector mains,  knock-out pots and  primary
 coolers and supply  pressure to force  the coke  oven  gas through  the
 remainder of the  gas  cleaning  systems.

      From the exhausters, the  coke  oven  gases  are routed  through three
 banks  of  electrostatic  precipitator (ESP) units  and  gas  reheaters.
 Additional tar materials are removed  from the  gases  in the  ESP's and
 sold  to scavengers.

     After passing through  the ESP's  and reheaters,  the  gases are bubbled
 through two parallel  sulfuric  acid tanks called  saturators.  Ammonia  in
 the coke  oven gas reacts with  the sulfuric acid  to form ammonium sulfate
 (NH4)2S04.  The (NH4)2S04 crystals precipitate, are collected, centri-
fuged, and air-dried  in piles before being sold as fertilizer.  Centrate
from this operation is returned to the saturators.  The sulfuric acid
concentration is maintained between 3% and 14% by the addition of 96%
acid.   Production capacity of this process is about 73 m. tons (80
tons)/day of dried ammonium sulfate.

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                                                                        31
     From the saturators, the coke oven gases are sent to two parallel
final coolers.  These units are bubble tray towers which provide contact
cooling of the gases with decanted tar materials.  The tar also absorbs
naphthalene from the coke oven gases.  The naphthalene is reclaimed
along with the tar by the scavenger operation.

     From the final coolers, the coke oven gases are passed through two
countercurrent flow scrubbers containing a packing material of curled
steel strips called "curlings."  Here the gases are scrubbed with "wash
oil" which has been returned from the Benzene Plant.  The wash oil
absorbs benzene, toluene, xylene, and solvent from the gas stream.  The
saturated wash oil is then returned to the Benzene Plant.

     From the scrubbers, the coke oven gas passes through two parallel
ESP's.  Here the remaining tars and other condensed materials are removed
from the gas stream.  The resulting purified gas is then separated
essentially into three gas streams.  About a third of the total gas
produced is returned to the coke ovens as fuel to the underfire system.
Another third is sent to the Nitrogen Plant.  The remaining third is
introduced into a plant-wide fuel gas system.  A flare is available to
burn any coke oven gas in excess of the plant requirement and storage
capacity.
Benzene Plant

     Figure 4 is a simplified process flow diagram for the Benzene
Plant.

     Saturated wash oil is pumped from the Byproduct Gas Plant through
two parallel heat exchangers and two parallel heater units.  The heated
wash oil is then introduced into two parallel stills where it is steam
stripped by a countercurrent flow of high pressure steam.  Benzene,

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                                                                                                  32
                                               WASH OIL  STILL
                                                              SCRUBBERS
                                                                    CAS FROM ClNAL
                                                                    '  COOLER
                        OIL —

                   FINAL HEATER
                                          PCOCN70LIZED WASH OIL

                                         	WASH OIL COOLER
               VAPOR TO  OIL
           HEAT EXCHANGER
                                    CAS  TO _.
                                    HOLDER
              LIGHT OIL VAPOR —
                                          INTfRUFDUTE  LIGHT OIL
          LtCHT OIL RECTIFIER
                                     SECONDARY LIGHT
                                     OIL CONDENSER
                                                                                       CONDENSER

                                                                                     nris-=-
                                                                                     U U EIV:
C5£ TO COKE -•
      OVEN  GAS  SUPPLY
                                      CS2 STRIPPER
                                         COLUMN
                                    — CRUDE LIGHT OIL


                                     TANK
             METERING
              TANKS
                                     AGITATOR

                                    — WASHED LIGHT OIL
 ACID SLUDGE
  TO LADLE
SODA WASH TO
INTERCEPTING SUMP
                                                                      |—| OCN- TOL
                                                                      1  4J.N1ERHEOIATES
                                      BENZOL

                                      COLUMN
                  figure  4.  Benzene Plant Flow  Diagram - USSC  Genora  Worki

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                                                                       33
 toluene, xylene  (B-T-X) and solvent are stripped from the wash oil and
 removed from  the still as overhead vapors.

     The stripped wash oil is then passed through cooler units and
 recycled to the Byproduct Gas Plant where it is used to absorb more B-T-
 X from the coke oven gas.  Make-up wash oil, purchased from the American
 Oil Company,  is added as needed.

     Stripped vapors from the wash oil stills, now termed light oil, are
 passed through the wash oil heat exchangers and sent to the light oil
 rectifier, which is a fractionation column.  About 80 m3 (21,000 gal)/day
 of light oil  is processed.

     The bottoms from the light oil rectifier, termed intermediate light
 oil, are routed to a storage tank.  From here they can be batch distilled
 in a "crude still."  The bottoms from this operation are crude residue
 which can be burned as a fuel at the open hearth furnaces.  Overhead
 vapors from the batch still are fractionated and condensed.  Naphthalene
 and crude aromatic solvents are the products of this distillation stage.

     Overhead vapors from the light oil rectifier are condensed to form
 a material termed secondary light oil.  This material is passed through
 a steam stripping column to remove carbon disulfide (CS2).   The CS2,
 which amounts to about 1.5% by weight of the original light oil, is
 mixed with the underfire gas supplied to the coke ovens.

     The stripped secondary light oil, now termed crude light oil, is
 mixed with 94% to 98% sulfuric acid and 50% sodium hydroxide to remove
 impurities such as mercaptans, sulfides, etc.   The washed light oil  is
 then stored for further processing.  Acid sludge resulting from the acid
wash is hauled to landfill.   Spent caustic from the caustic wash is sent
 to a process wastewater sump and is ultimately used in the north quench
 tower.

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                                                                        34
      Washed  light  oil  from  the  storage  tanks  is  stripped  of benzene  in
 the benzol column.  The  resultant  pure  benzene,  termed  1° Benzol,  is
 condensed and  stored  in  tanks.

      Bottoms from  the  benzol column contain residual amounts of benzene
 plus  toluene and xylene.  These bottoms are fed  to a batch still where
 they  are further separated  by fractionation distillation.  The products
 from  this unit operation  include pure benzene  (1° Benzol), pure xylene
 (10°  xylol) and pure toluene (1° toluol), plus mixtures of benzene and
 toluene, and toluene and  xylene.

      About 53 m3 (14,000  gal) of 1° Benzol, 11 m3 (3,000  gal) of
 1°  toluol, 4 m  (1,000 gal) of 10° xylol, and 8  m3 (2,000 gal) of crude
 solvent are produced each day from the 80 m3  (21,000 gal)/day of light
 oil processed.  About 4 m3  (1,000 gal)/day is regarded as  "lost" material

      The B-T-X produced from this facility are extremely  pure grades.
 The 1° and 10° terms used to describe the materials indicate that all of
 the material  will volatilize within 1°F and 10°F of the boiling point,
 respectively.  The B-T-X materials produced at the Geneva facility are
 considered to be suitable for nitrification.
Nitrogen Plant

     Figure 5 is a simplified process diagram for the Nitrogen Plant.
This facility is actually five separate plants in one unit:  an air
separation plant, a coke oven gas purification and separation plant, an
ammonia production plant, a nitric acid production plant, and an ammonia
nitrate production plant.

     In the air separation plant, atmospheric air is filtered and then
subjected to cryogenic separation into oxygen and nitrogen.  The oxygen

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                                                 Return Gas
                                                    to
                                                 Mixed Gas
                                                  System
                                 C.O.CA3 O N2

                                 PRECOOLINO

                                    UNIT
COKE OVEN CAS
                                                                    SEPERATION
C 0. CAS
COMP.
                                                                                       NH, SYNTHESIS
                                                                                        CAS COMP.


                                                                                       B-T-X TO B-T-X  PLANT
                                  Al R

                               SEPARATION

                                 PLANT
                                                                                 COLD
                                                                               KEROSENE
                                                                           BAGGED AMMONIUM NITRATE
                                                                     •  


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is sent to the open hearth steel furnaces where it is used for lancing
of molten steel to remove impurities.

     Coke oven gas is received from the Byproduct Gas Plant after the
gas has been partially purified [Figure 3].  At the Nitrogen Plant the
coke oven gas is compressed and further purified by sequential scrubbing
with an ammonia solution, water, caustic solution, and water again.
Hydrogen sulfide is removed from the coke oven gas by the ammonia scrub-
bing process.  Other impurities are removed by the subsequent scrubbing
stages.  Liquid blowdown from these scrubbing processes are ultimately
sent to the north quench tower.

     The purified coke oven gas is routed to a cryogenic preceding
unit.  Nitrogen from the air separation plant is compressed and sent to
the precooling unit also.  In the precooling unit, hydrogen is separated
from the higher boiling point constituents (higher boilers) in the coke
oven gas.  The higher boilers are mixed with the hydrogen sulfide removed
earlier and returned to the mixed gas system.

     The hydrogen from the coke gas is further purified by scrubbing it
with a cold kerosene solution which absorbs trace quantities of B-T-X
from the hydrogen.  The recovered B-T-X is recovered in the Benzene
Plant.

     In the ammonia plant the purified hydrogen and nitrogen are com-
pressed to about 270 kg/cm  (3,800 psi) and passed through a bed of iron
oxide catalyst.  The resulting product is liquid, anhydrous ammonia.
About 180 m. tons (200 tons)/day of this material are produced, of which
25% is sold and 75% is used in subsequent processes.  The anhydrous
ammonia is stored in pressurized vessels at the site.

     In the nitric acid plant, anhydrous ammonia is mixed with air and
passed over a platinum catalyst to form nitrogen dioxide vapor.  This

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                                                                       37
vapor is then absorbed  in water to produce a 56% solution of nitric
acid.  The Geneva nitric acid plant has a nominal production capacity of
350 m3 (90,000 gal)/day of 56% nitric acid.  A portion of this produc-
tion is concentrated to 60% and sold.  The remainder is used in the
production of ammonium nitrate.

     In the ammonium nitrate plant, anhydrous ammonia, water, and 56%
solution of nitric acid are reacted to form an 83% solution of ammonium
nitrate.  This solution is concentrated to 96% by evaporation.  The
concentrated solution is then pumped to the top of a 49 m (160 ft) high
prill tower.  Atop the prill tower, the concentrated solution is passed
through strainer-like discs which form small droplets.  These droplets
free-fall the 49 m (160 ft) to the bottom of the tower.  During this
fall they cool from 150 to 74°C (300 to 165°F) and crystallize into
spheroids of ammonium nitrate with 4% water of crystallization.  About
85% of these spheroids are retained on a No. 14 screen.

     The spheroids (prills) are removed from the bottom of the prill
tower by a conveyor belt.  This belt transports the prills to a shaker
pan which discharges them into a series of driers and coolers.  The
prills are here dried and cooled from 4% moisture and 74°C (165°F) to
0.04% moisture and 29°C (85°F).

     From the final  cooler, the prills are screened, blended with talc
to form a water resistant talc barrier and sent to final  storage or
sales.  The ammonia nitrate plant has a nominal  capacity of 270 m. tons
(300 tons)/day of prilled product.
INSPECTION OBSERVATIONS

     The Byproduct Gas Plant and Benzene Plant are not inherently sources
of particulate emissions since they incorporate closed gas cleaning
systems.  The excess coke oven gas flare unit at the Byproduct Gas Plant

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                                                                        33
 is the only potential source of continuous particulate emissions.  Total
 dissolved solids in the liquid blowdowns from the various gas cleaning
 processes may be released as particulate matter during coke quenching
 operations.

      The Nitrogen Plant appears to be the main source of particulate
 emissions related to the coke byproduct operations.   The prill  tower
 which is uncontrolled is the primary emission point.   USSC personnel
 have estimated that approximately 135 kg (300 lb)/day of ammonium nitrate
 fines are lost to the atmosphere from the prill  tower.   A fine, fume-
 like plume was observed to be continuously discharged from the  top of
 the prill  tower during the inspection.

      The four  rotary prill  dryer/cooler units are  also  potential  sources
 of emissions of ammonium nitrate fines.   Exhaust gases  from these units
 are discharged to three identical  C.  0.  Bartlett and  Snow Co. Model  No.
 77-21-123  wet  cyclone  collector  systems  operating  in  parallel.  The
 collector  systems,  which were installed  in  1958, each have  a design  gas
 flow capacity  of 270 m3/min  (9,400 acfm)  and  a design collection  efficien-
 cy of 98%  to 99%.   USSC has  no emission  test  data  for these units.   No
 visible  emissions were  observed  from  the  collector exhaust  stacks  observed
 during the  inspection.

     The prill screening and  talc/prill blending operation are vented to
 a  baghouse which discharges through the side of the building to the
 atmosphere.  The baghouse is a Wheelabrator No. 8-R Model 126D, Dustube
 Dust Collector which employs cotton bags.  The air-to-cloth ratio for
 the unit is 2.72:1 at an average headloss of 4.6 cm (1.8 in) water.  The
design collection efficiency of the unit is 99%.   USSC has no emission
test data for this unit.

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                                                                        39
     There are no combustion devices (process heaters, furnaces, etc.)
associated with the various byproduct plants.  Steam heat exchangers are
used where heat transfer is required.  Steam is supplied from the Geneva
central power plant.

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                          V.   SINTERING PLANT
     The Sintering Plant personnel are responsible for the receipt and
handling of all iron ore materials and limestone at the Geneva facility
as well as the operation and maintenance of the sintering machines
themselves.  The materials handling, process operations, and participate
emission control system are discussed in this Section.


PROCESS DESCRIPTION

Materials Handling

     Iron ore is received in two forms at the Geneva facility, a magnetic
concentrate from southern Utah and beneficiated ore pellets received
from a USSC facility at Atlantic City, Wyoming.  The magnetic concentrate
as received at Geneva contains about 7% to 8% water and has an iron
content of about 57.5%.  The beneficiated ore pellets (called agglomerate)
are received at Geneva at an iron content of about 63% to 67%.

     All of the iron ore is received at Geneva by rail.  The railroad
cars are unloaded by a single Link Belt rotary railroad car dumper.  The
ore materials are transported from the dumper to the storage area by
conveyor belt.  At the storage area, the ore is stacked into long storage
piles with three Robbins double-wing stacker units.  The ores can be
blended with limestone at these stacks by alternating the raw materials
being fed to the stacker units.

     There are eight storage beds for the magnetic concentrate and two
storage beds for agglomerate.  The total storage capacities are 82,000
m. tons (90,000 tons) and 120,000 m. tons (130,000 tons), respectively.

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                                                                          41
 Ore is reclaimed  from the  storage  piles  by two  Robbins-Messiter reclaim-
 ing machines  and  a  Robbins rotary  buck wheel  reclaimer.   The  ore is
 transferred  from  the  reclaimers  to screening  facilities  by  conveyor
 belts.

      Agglomerate  pellets are  screened to remove fines  before  being
 transported  to  storage  hoppers.  From the storage  hoppers they  are
 transported directly  to the blast  furnaces.   The agglomerate  fines
 reclaimed  at  the  pellet screening  station are transferred by  conveyor
 belt and stored in  two  storage silos at  the Sintering  Plant.

      The magnetic concentrate, as  received at Geneva,  has a wide distri-
 bution of  particle  sizes ranging from fine dust to  large  rocks.   This
 material is reclaimed from storage  piles  and  sent by conveyor system to
 a crushing and  screening facility.  Here  the  ore is passed  through
 scalping screens  to produce size cuts of  +5 cm  (+2  in), +0.6  cm  to -5 cm
 (+1/4 in to -2  in) and  -0.6 cm (-1/4 in).  The  +5 cm (+2  in)  cut is
 routed directly to two  parallel Hydrocone crusher units.  The resulting
 crushed ore is recycled to  the scalping screens.  The  +0.6 cm to -5 cm
 (+1/4 in to -2 in) cut  from the scalpers  is sent directly to  the blast
 furnace feed  storage hoppers.  The  -0.6 cm (-1/4 in) cut from the scal-
 pers  is sent  to four storage silos  at the Sintering Plant.


 Sintering

      The function of the Sintering  Plant  is to  fuse fine iron ore par-
 ticles, iron  flue dust from the blast furnace and other iron bearing
 fines  into clinker-type materials which have  the structural  strength and
 porosity required of blast furnace charge.

     There are two Dwight Lloyd sintering machines at this facility each
with a maximum capacity of 1,400 m. tons  (1,500  tons)/day, operating
three turns per day.  A maximum month's  production from the  Sintering
Plant during 1975  was  81,000 m.  tons (89,000 tons)  and  the average

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                                                                       42
monthly production was 46,000 m. tons (50,000 tons).  Generally, both of
the sintering machines are operated when the Sintering Plant is operated.

     In the sintering process, iron bearing materials (e.g., agglomerate
fines, magnetic concentrate, blast furnace flue dust and clarifier
sludge, returns from slag reprocessing) are mixed with coke breeze
(fines), dolomite limestone, recycled sinter fines, and water in two
drum type pug mills.  A typical Sintering Plant feed composition is
shown in Table 3.  From the pug mills, the mixed materials are transported
via conveyor belts to the sintering machines.  Here the materials are
distributed by swinging spouts onto the machines' traveling grates.  The
grates carry the bed of feed materials through an ignition furnace where
overhead gas burners ignite the coke breeze.  The grate then transports
the ignited bed over a series of windbox sections which are 1.8 m (6 ft)
wide and total 31 m (102 ft) long.  As the grate traverses the windbox
sections, air is pulled down through the feed bed into the windboxes
causing the combustion zone to penetrate deeper into the bed.  The coke
breeze combustion creates sufficient heat to sinter the fine iron ore
particles together into porous, coherent lumps.  Ideally, as the traveling
bed approaches the end of the windbox, the combustion zone should just
be touching the traveling grate.

     At the end of the windboxes, the grates discharge the sinter onto
a bar grizzly to break up the large pieces.  From here the sinter is
transported by conveyor belts to a hot screening operation.  Oversize
material rejected by these screens is sent directly to the blast furnace
feed hoppers.  Sinter fines from the screens are returned to the sinter
feed pug mills and blended with the incoming feed materials.


PARTICULATE EMISSION SOURCES
     The largest potential sources of particulate emissions at the
Sintering Plant proper are the windbox exhaust systems.  Both sintering

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                                                                        43
                                Table 3
                        TYPICAL COMPOSITION OF
                    SINTERING PLANT FEED MATERIALS
                          USSC - GENEVA UORKS
   Material                                % by Weight, in Feed

-0.6 cm  (-1/4 in) magnetic concentrate           40
Blast furnace flue dust                            9
Sinter fines recycle                               5
-0.3 cm (-1/8 in) dolomite                        13
Slag ore fines recycle                             5
Coke breeze                                        5
Blast furnace clarifier sludge                     3
Agglomerate (pellet) dust                         20
                                       Total      100

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                                                                        44
machines have  identical windbox exhaust systems.  Air is drawn through
the  sinter bed and grates to promote combustion of the coke breeze.
Combustion products and sinter fines are drawn through the sinter bed by
the  air stream into the windbox exhaust system. The next largest poten-
tial  source of particulate emissions related to the Sintering Plant is
the  sinter discharge end.  Hot sinter is discharged from the grate
pallets at the end of the windbox section onto bar grizzlies.  Consider-
able  amounts of dust are generated at this point, especially if the
sinter bed has not been completely fused together before reaching the
discharge location.  The unfused materials are easily entrained because
of their fine size distribution.  The grizzly bars are enclosed units
which are vented by duct work to a scrubber unit and exhaust fan.

     Another potential source of particulate matter at the Sintering
Plant is the sinter screening station.  USSC reportedly employs water
sprays at this screening station to minimize particulate emissions.
Again the amount of emissions from this location will depend on the
relative degree of fusing of the sinter achieved on the sinter grates.
If the sintering process is incomplete, more fines will  be generated by
the screening process and the fugitive emissions will be higher.

     The last significant sources of particulate matter noted at the
Sintering Plant are two vent stacks which serve the two feed material
pug mills.   Neither of these emission points is controlled.


PARTICULATE CONTROL SYSTEM

     The windbox emission control  system consists  of two identical
trains, each  handling the emissions from an  individual  Dwight Lloyd
sintering machine.   An emissions control  train  includes  a fan,  two
parallel  banks of three cyclones in series,  and a  partial orifice

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                                                                       45
scrubber [Figures 6 and 7].  The discharge end emission control  system
consists of a single scrubber and fan which handle the emissions from
both sintering machines [Figure 8].
Process Emissions

     The Sintering Plant is an intermittent operation with the tempera-
ture and volume of windbox gases maintained at a relatively constant
level when the lines are operating.   The emissions consist of some
gaseous combustion products and entrained particulate which is generated
as air is drawn through the sinter bed.  The particulate loading, sizing
and characteristics can vary with the feed composition, bed depth, and
bed speed.  Windbox emissions are mainly generated early in the sintering
process and at the point where the flame front has reached the bottom of
the bed.

     Like the windbox emissions, discharge end emissions will also have
variable particulate characteristics.  Discharge end emissions result
when sinter is allowed to drop from the end of the sinter machine pallets,
The quantity and characteristics of particulates released are functions
of some of the same parameters as are the windbox emissions.  The particu-
lates are vented from the system at a relatively constant flow rate.
Temperatures may be expected to vary somewhat being especially dependent
upon where on the bed the flame front has ended relative to the sinter
discharge end.

     Table 4 shows the expected characteristics of the windbox and
discharge end emissions from the Sintering Plant, as provided by USSC.


Windbox Cyclones

     The cyclones in the windbox emission control system are multiple

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                                                     EXHAUST
 NOTE: Schematic  shows  control  system

   for one of the sintering machine trains.
SINTERING

  PLANT
                       CYCLONE
                  DUST COLLECTORS
OL
III
S
0
h


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                                                         47
                     EXHAUST
                         ZT"
                            SAMPLE  PORT
                                     MIST ELIMINATOR
         SPRAY NOZZLE HEADER
               CONTROL ROOM
                                         GROUND LEVEL
                                        y
Figure 7.   Sintering Plant  Windbox Scrubber
             USSC Geneva Works

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       EXHAUST
 EXHAUST
                                           GAS  INLET
       8'-O"  I D
       5'-6"  I.D
                        SPRAY  NOZZLE

                               VATER
                               /    y5O" ORIFICE  PLATE
                          y  v
                          *	j    /.SPRAY NOZZLE
                         £
                                            GAS INLET
                                                D.  DUCT
                                     WATER
                                          SLURRY
                ELEVATION
Figure 8. Sinfering Plant Discharge End Scrubber
             USSC Geneva  Works

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                                                                        49
                                Table 4

                    CHARACTERISTICS OF EXHAUST CAS
             AND PARTICULATE EMISSIONS FOP SINTERING PLANT
                          USSC - GENEVA WOPKS
 Parameter
    Windbox Exhaust
Discharge-end Exhaust
Temperature

Pressure (at fan
 discharges)

Flow rate

Particulate
 Concentration
Particulate
 Composition
 (% by weight)
93°C (200 °F)
61 cm (24 in) W.G.

5,000 m3/min (180,000 scfm)
7g/nr (3 gr/scf)
Particulate
Size Range




+40ym
20-40ym
10-20ym
5-1 Oum
0-5ym
53%
10%
16%
14.5%
6.4%
SiO,
Particulate
 Specific Gravity
          13.11
A1203
CaO
MgO
Fe
C
3.49
4.14
3.46
40.60
15.05
82°C (180°F)
18 cm (7 in) W.G.

2,200 m3/min (80,000 scfm)
2g/mJ (1 gr/scf)
                                                   not available
not available
     3.5
3.5 (estimate)

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                                                                         bO
centrifugal type dust collectors with primary settling chambers.  Table
5 presents general, physical, and design data for the cyclones, as
provided by USSC.  The cyclones, due to their simplistic design, should
be capable of operating as designed.  There are no moving or energized
parts to require constant monitoring.  The inlet velocity, which has an
important effect on particulate removal, should remain relatively con-
stant since the windbox fans maintain a relatively constant flow and the
cyclone liners are frequently inspected for wear.  Another important
factor affecting particulate removal by the cyclones is the presence of
air inleakage which could interfere with the cyclonic gas flow pattern.
Since the cyclones are routinely inspected for physical integrity this
should not be a problem.

     The major variables affecting cyclone operation are the fluctuating
grain loading and particle size resulting from the sintering operation.
Assuming the cyclones were designed for worst case conditions, these
variables should not affect cyclone operation.

     USSC has indicated that the cyclone shells are inspected weekly and
repaired as necessary.  The brick refractory liners are inspected monthly
and also repaired as necessary.  The bottom cones and discharge valves
were reported to be checked daily.  These procedures, if adhered to,
should insure that inlet velocity is maintained, inleakage is minimized,
and cone dust buildup with resultant carryover is minimized.

     Observations of maintenance were limited during the inspection.
With the exception of one obviously malfunctioning solid discharge
point, the rubber flapper discharge valves appeared to be in good con-
dition.
Windbox Scrubbers

     The scrubbers used in the windbox emission control  system are USSC-
designed and constructed partial orifice scrubbers [Figure 7].  Initially

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                                                                       51
                               Table 5
            GENERAL, PHYSICAL, AND DESIGN PARAMETERS FOR
                  SINTERING PLANT WINDBOX CYCLONES
                         USSC - GENEVA WORKS
Parameter                                   Specification

General                    Number of cyclones - 6 per train,
                                                2 identical trains
                           Date Installed - 1953
                           Manufacturer - American Blower Manuf. Co.
                           Model - No. 42 type D
Physical                   Arrangement - 2 parallel  sets of
                                                3 cyclones in series
                           Cyclone diameter - 3.7 m
                           Cyclone height - 10 m
                           Cyclone inlet width - 3.1  m
                           Diameter of cyclone outlet - 2.1 m
Design                     Particulate removal efficiency - 85%
                           Inlet velocity - 1,300 m (4,400 ft)/min

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                                                                        52
 erected in 1962, the scrubbers were modified in 1975 by relocating
 internal sprays.  USSC reported that this was done to provide better
 mist elimination.  Scrubber spray water consists of recycle water from
 the neutralization/clarification system diluted with plant makeup water.
 The discharge from the scrubber is pumped to the clarification/
 neutralization system for treatment.

      General  and design parameters for the windbox scrubbers, as provided
 by USSC, are shown in Table 6.  USSC stated that the scrubbers were
 originally designed for hydrogen fluoride (HF)  removal  and were selected
 because they would provide adequate HF removal  and good access for
 maintenance.   However,  the use of these scrubbers  for particulate removal
 is questionable for two reasons:   particulate removal  capability, and
 mist carryover.

      The most questionable design parameter is  the reported  particulate
 removal  efficiency (95%).   This  efficiency, which  is  typically a function
 of the  size of the particulate removed  and  the  energy  input  into the
 scrubber,  appears  to  be higher than  would be expected for  the  size  range
 of particulate estimated  to be discharged from  the  cyclones.   Although
 there is a lack  of good particle  size  information,  it is questionable
 that  these low pressure drop (5  to 7 cm W.G.) scrubbers could  remove the
 95% of  the particulates necessary to provide  an outlet  grain loading of
 0.08  g/m3  (0.04  gr/scf).

     A second  questionable  design feature is  the use of a packed  bed
 mist eliminator without a  spray wash to clean off solids deposits.  The
 scrubbing media  is saturated with dissolved solids which precipitate in
 the packed bed.  As the solids accumulate in the packed bed, higher
 velocities are created  around the plugged areas of the bed.  At higher
 velocities, more liquid is re-entrained, lowering the efficiency of the
mist eliminator.  The mist carried over contains suspended and dissolved
 solids which increase the particulate grain loading of the exhaust gas.

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                                                                        53
                               Table 6
                  GENERAL AND DESIGN PARAMETERS FOR
             SINTERING PLANT WINDBOX EMISSION SCRUBBERS
                         USSC - GENEVA WORKS
Parameter                                  Specification

General                      Number of scrubbers - 2
                             Date installed - 1962
                             Scrubber type - partial orifice
                             Manufacturer - USSC

Design                       Particulate inlet loading - lg/m3 (0.5 gr/scf)
                             Particle size - 95% <5jjm
                             Particulate specific gravity - 3.6
                             Particulate removal efficiency - 95%
                             Scrubber pressure drop - 5-7 cm (2-3 in)  W.G.
                             Scrubber water rate - 2,600 1(700 gal)/min
                             Scrubber gas velocity - 2.1 (6.9 ft)/sec
                                                 O
                             Gas volume - 5,000 m /min (180,000 scfm)
                             Gas temperature - 93°C (200°F)
                             Gas pressure - 730 mm Hg

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                                                                        54
This carryover could result in an 0.02 to 0.07 g/m3 (0.01  to 0.03
gr/scf) addition to the particulate grain loading [Addendum C].

     There are no gas side controls or monitors used for the windbox
scrubbers other than a WP-50 single point sampling train located, at the
time of the inspection, just above the mist eliminator of the north
scrubber.  The train withdraws periodic samples of gas which are then
later analyzed by USSC personnel.  The data obtained from this train are
highly questionable since the gas sampled may or may not exhibit particu-
late concentrations representative of the entire gas stream.  The scrub-
ber liquid pressure is monitored at the pumps and maintained manually.
No other scrubber-operating parameters are monitored.  As a result of
the lack of operating indicators, only visible emissions observations
were available as an indicator of collection efficiency.  The opacity of
the plume after the steam had detached was typically in the range of 10%
to 40%.  It was also observed that there was significant mist fallout
which appeared as large "rain" droplets near the base of the scrubber
stacks.

     USSC personnel reported that the scrubbers are cleaned every 3 to
4 weeks.  The cleaning program was said to include inspection, replace-
ment of  nozzles, flushing of pipes, and the removal of scale from the
mist eliminator and scrubber internals.

     The maintenance of the mist eliminator is not adequate because, as
reported by USSC, the buildup of solids occurs immediately.  This buildup
would be accompanied by higher droplet carryover and increased particu-
late loads.  However, keeping the mist eliminator clean enough to mini-
mize mist carryover problems could require a  high frequency of down
time.  This problem could be handled  by design modification.  Such
design modification might include  intermittent mist eliminator wash
systems, alternative mibt eliminator  designs  and orientation, and/or
use of an anti-scaling agent.

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                                                                          55
Discharge-end Scrubber

     The Sintering Plant discharge-end emissions are treated by a single
wet scrubber.  The scrubber consists of an orifice plate section followed
by a cyclone [Figure 8].  There are sprays located at the orifice opening
and in the entrance to the cyclone.  Limited data are available on the
discharge-end particulate emissions and, as a result, the analysis of
this scrubber's particulate emission control capability is limited.

     Table 7 shows some of the more relevant general and design param-
eters pertaining to the discharge-end scrubber.  Without approximate
particle size information, it is not practical  to evaluate design in any
great detail.  The orifice/cyclone scrubber should be capable of 97%
particulate removal assuming that a very small  portion of the total
particulate is less than 2ym to 3pm in diameter.  Mist carryover effects
are also difficult to estimate since the system has a wet fan downstream
from the scrubber, which would collect a large portion of the mist
droplets.

     Operation of the discharge-end scrubber is not monitored, other
than the scrubber water pressure.  No observations of scrubber operation
or emissions were made during the inspection.  The emissions were not
observed because they were not considered to be representative at the
time of the inspection because there were malfunctions in the sintering
process and water system.

     Maintenance problems may result from the abrasive nature of the
particulate-laden gas stream and the collection of mist on the wet fan.
The largest abrasive wear would be on the orifice plate but since this
is, by design, a large opening orifice (127 cm opening for a 152 cm
duct) this should not have a major influence on particulate removal
capabilities.  The wet fan, however, may have an important effect on
performance; the Company indicated no particular difficulties with the
fan.  It is believed, however, that the high potential for deposits on,

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                               Table 7
                  GENERAL AND DESIGN PARAMETERS FOR
              SINTERING PLANT DISCHARGE - END SCRUBBER
                         USSC - GENEVA WORKS
Parameter                                   Specification

General                         Number of scrubbers - 1
                                Date installed - 1962 (estimated)
                                Scrubber type - orifice/cyclone
                                Manufacturer - USSC
                                                                  3
Design                          Particulate inlet loading - 0.23 m
                                (0.1 gr/scf)
                                Particle size - unavailable
                                Particulate removal efficiency - 97%
                                Scrubber water rate - 1,100 1(300 gal)/min
                                Scrubber gas velocity - 7.9 m (26 ft)/sec
                                Gas volume - 2,200 m3/min (80,000 scfm)
                                Gas temperature - 80°C
                                Gas pressure - 822 mm Hg

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                                                                       57
and corrosion and abrasion of, the fan blades could make this a major
problem area.


INSPECTION OBSERVATIONS

     The Sintering Plant is an antiquated facility with several design
inadequacies which hinder optimum operating modes and substantially add
to the plant's air pollution potential.  Sintering Plant personnel
discussed some of these problem areas with NEIC personnel during the
inspection.

     The major problem areas are associated with the feed preparation
systems.  The pug mills do not provide adequate mixing of the feed
materials.  This, in turn, results in uneven sintering on the traveling
grates.  Additionally, there is an inadequate and unreliable v/ater
supply available to the pug mills.  During the inspection, intermittent
heavy discharges of particulate matter from the two pug mill stacks were
noted.

     Another problem related to the material feed equipment is that the
proportioning controls on the ore, coke, and pellet fines systems are
inadequate.  The proportioning systems do not consistently maintain
fixed set ratios of the various feed materials.

     A major concern with the feed systems is the lack of surge storage
and proportioning controls on the sinter fines recycle systems.  The
fines are currently recycled directly as they are received from the
sinter screening station, with little control on the correct ratios
required.  The amount of recycle fines added to the feed materials is
critical in that it affects the sinter bed porosity.

     A final problem mentioned by the plant personnel  is the lack of
adequate sinter cooling facilities.  Having to bundle  the sinter in a

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hot form increases conveyor belt maintenance and equipment down time.

     Not all of the materials handling procedures were in operation at
the time of this inspection.  No ore railroad cars were being unloaded,
nor were the ore pile stackers being used.   The pile reclaimers and the
ore crushing/screening station were observed in operation.

     No fugitive emissions were noted from the ore reclaiming operations,
the primary grizzly screens, or the crushers.  However, considerable
fugitive emissions were noted from the secondary screening operations
which receive the pulverized ore from the crushers.

     The ore received from Southern Utah contains 7% to 8% moisture.  It
appeared that this moisture was sufficient to suppress dusts during the
preliminary material handling stages.  However, the ore produced from
the crushing of oversized ore chunks is apparently much drier.  When
this material was screened, it liberated significant quantities of dust.
USSC personnel stated that water sprays are usually used to suppress the
dusts at these screens.  During this inspection, the water sprays were
not in operation.

     It was noted during the inspection that the ductwork serving the
grizzly bar hooding at the sinter line discharge-end was in disrepair.
Several rusted-out holes were noted in the ducts.  Suspended particulate
matter was heavy in the atmosphere near the hooding.  Since the water
spray system was not in operation, considerable fugitive emissions were
also noted at the sinter screening station during the inspection.

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                                                                        59
                          VI.   BLAST FURNACES
     There are three blast furnaces at the Geneva facility which are
used to convert iron ore, agglomerate, and sinter, into pig iron.  The
three furnaces are numbered 1, 2, and 3 in a south-to-north plant
orientation.  All three of the furnaces are essentially identical;   each
is 32.3 m (106 ft) high with a hearth diameter of 8.1  m (26.5 ft).   The
nominal production capacity of the three furnaces is 1,680,000 m. tons
(1,850,000 tons)/yr.  The daily production capacity varies significantly
with the type of materials fed to the furnaces.  The furnaces are each
nominally rated at 1,600 m. tons (1,800 tons)/day capacity with a feed
material based on ore and sinter.  However, when the feed is predomi-
nantly agglomerate or pelletized ore the furnace capacity is increased
to 2,000 to 2,200 m. tons (2,200 to 2,400 tons)/day.
PROCESS DESCRIPTION

Materials Handling

     Coarse ore, agglomerate pellets, sinter and coke, which have been
screened to remove fines, and dolomite limestone are transported from
their respective storage facilities by railroad transfer cars to the
blast furnace area.  The materials are discharged from the transfer cars
to below grade storage bins.  From these bins, the materials are dis-
charged into a scale car which transfers predetermined amounts of the
materials to skip hoists which actually feed the furnaces.

     Alternating skips of coke, ore, and limestone are fed to the furnace.
The skip hoist lifts the load to the top of the furnace and dumps it
into a receiving hopper.  The receiving hopper is isolated from the

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                                                                         60
 furnace proper by two sets of inverted  cone-shaped  cast  steel  plates
 called bells.   These bells can be independently depressed  providing
 access to the  furnace proper.   The uppermost  bell,  termed  the  small
 bell,  isolates the receiving  hopper from the  region between  the  two
 bells  which  is termed the  hopper.   The  lower  bell,  termed  the  large
 bell,  isolates the furnace from the hopper.

     After the skip hoist  discharges  its  load  of material  into the
 receiving hopper,  it descends  the skip  bridge  to be reloaded.  Simulta-
 neously,  another  skip ascends  the bridge  with  another  load of  material.
 The  small  bell  is  then depressed,  allowing the  skip load to  enter the
 hopper area.   The  small bell  is  then  closed and  another skip load is
 dumped into  the receiving  hopper.   The  cycle  is  repeated until three
 skip loads are  in  the hopper area.  Then, the  small  bell is  closed and
 the  large  bell  is  opened allowing  the feed material  to enter the furnace.

     During  the inspection, blast  furnace 2 was  operating in a split
 filling mode.  The  term split filling means that more than one large
 bell dump  is required  to accomplish a single charge.  The charge sequence
 was  small bells of  ore (0), stone  (S)s and coke  (C)  followed by a large
 bell dump and then  small bells of ore (0), coke  (C) and coke (C) with a
 second  large bell  dump.  This sequence is denoted as OSC/OCC with the
 entire sequence constituting a single charge.   The average charge
 composition during the inspection is presented in Table 8.


 Furnaces

     Each of the blast furnaces has three regenerative stoves which  are
used to preheat the blast air (wind) introduced into the  blast furnace
tuyeres.  The stoves preheat the wind to about 930  to 980°C (1,700  to
1,800°F).   Normally the checkers in two  of the three stoves are being

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                                                                   61
                          Table 8

                AVERAGE COMPOSITION OF CHARGE
            TO BLAST FURNACE 2 - August  23,  1976
                     USSC - GENEVA WORKS
Material
Ore"1"
Do! onri te
Roll Scale"1"1"
Coke

Weight
kg
24,000
5,700
1,100
9,500
Total 40,300
by charge
Ib
52,800
12,600
2,500
21 ,000
88,900
 t  Ore was 80% agglomerate pellets,  10% concentrate;
    10% sinter
tt  Poll scale is material reclaimed from scarfing
    operations3 and other product finishing steps.

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                                                                         62
 heated by combustion of blast furnace off-gas.   The third stove is used
 to preheat the wind by reclaiming heat previously stored in the checker
 brickwork.  The stoves are on the heat cycle for about 1.5 hours and
 then on blast wind for 1  hour.   The wind to any given blast furnace
 averages about 2,400 m3/min (85,000 acfm).   When only two of the three
 blast furnaces are in operation, as was the case during the inspection,
 additional turbines can be added to increase the wind to the operating
 furnaces to about 3,100 m3/min  (110,000 acfm).

      Steam at a rate of 14 to 18 g/m (6 to  8 gr/scf)  is added to the
 wind at the tuyeres.   Natural gas,  during the summer  months when it is
 readily available, is also added here at a  rate of about 28 m3/min
 (1,000 acfm).   The steam  addition reacts with the coke in the furnace
 burden to produce hydrogen which aids in the reduction of the iron
 oxides in the ore; it also helps to cool the tuyeres  and burden  ma-
 terials, and  reportedly reduces  the burden  slip potential.   Natural  gas
 addition helps reduce the  amount of coke required in  the furnace burden
 and  provides  a means  by which the furnace hearth  temperature can be more
 effectively controlled.

     At  Geneva Works,  the  blast  furnace  operators  reduce the wind  supply
 to the  furnace every  half  hour.   This  procedure,  termed  checking,  causes
 the  furnace burden  to  slump in a  controlled  fashion,  and  reportedly
 minimizes  the  potential for a stuck burden which  bridges  between  the
 furnace walls.  Such bridging leads to uncontrolled burden  collapses
 which are  called  slips.  When slips occur, top  pressures  in  the  furnace
 increase  instantaneously, resulting in potential damage  to  the furnace
 structure  and  off-gas handling systems.

     The hot metal tap-to-tap cycle for the  Geneva blast furnaces varies
 from 4 to  5 hours depending on the type of furnace burden.  A normal tap
 is about 320 m. tons (350 tons)  of hot metal per furnace and  lasts about
45 minutes.  The hot metal is transferred from the furnaces to ladle

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                                                                         63
cars via runners constructed in the cast house sand floor.  The hot
metal ladles are then transferred via railroad tracks to the open hearth
area.

     At the midpoint of each tap-to-tap cycle is a slag flushing operation,
The flush lasts about 30 to 45 minutes or as long as required to fill
four slag ladle cars.  The slag is flushed from the furnace via the
monkey hole, a tap hole which is about six feet higher on the furnace
than the hot metal tap hole.  The slag which floats on the hot metal
surface in the furnace hearth flows from the monkey down runners to the
slag ladle cars.  The slag is then taken to a dump area at the northern
end of the facility.  The slag is ultimately reclaimed from the dump
area and processed by the Heckett Engineering Company.


PARTICULATE EMISSION SOURCES
     The off-gases from the blast furnaces contain a high percentage of
carbon monoxide (CO) formed by the combustion of the burden coke in the
reducing atmosphere of the furnaces.  These off-gases have a heat value
of about 760 kg-cal/m  (85 Btu/scf) and hence, it is practical to
reclaim them.  However, the off-gases also contain high particulate
grain loadings which must first be removed before the gases can be used
for fuel.
     The other major potential sources of particulate emissions at the
blast furnace are in the cast houses where the hot metal tapping and
slag flushing operations occur.  The emissions from both of these opera-
tions are fugitive, and they emanate from the open building sides and
roof louvers.

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                                                                        64
PARTICULATE CONTROL SYSTEM

     At the Geneva Works, the blast furnace gases are subjected to four
stages of particulate removal.  Each furnace has its own particulate
removal train and all are identical.  Off-gases from each furnace are
collected in four vertical ducts called uptakes.  The tops of two adjacent
uptakes are joined together to form two pairs, each pair being connected
to a large descending duct called a downcomer.  Each joined pair of
uptakes terminates as a single duct with a counter-weighted flap valve
called a bleeder valve.  These valves can be opened to release excessive
pressure from the furnace interior to the atmosphere.  At Geneva, the
bleeder valves are set to open at a pressure of 0.4 kg/cm  (6 psi) above
the normal furnace topside pressure.

     The downcomer carries the off-gases to a cyclone dust collector,
which is original equipment.  The unit, designed by Freyn Engineering
Company, has a 10.6 m (35 ft) inside diameter shell by 10.9 m (36 ft)
high chamber.  It is a top-entry, top-exit design.   There is a bleed-off
valve to the atmosphere located just ahead of this  cyclone collector.
The bleeder valve is set to open at 0.3 kg/cm  (4 psi) above the normal
furnace topside pressure.

     After the gases are partially treated for particulate removal in
the cyclone, they are routed to an orifice scrubber.  This unit consists
of an orifice plate with an upstream water spray system.   The orifice
scrubber unit was designed by USSC personnel.

     The gases from the orifice scrubber are routed to a  second stage of
scrubbing in a baffle type counter-current gas washer designed by the
Freyn Engineering Company.  The unit is 5.8 m (19 ft) in  diameter and
18.2 m (60 ft) long.   The gases enter the bottom of the unit and water
enters the top.

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                                                                         65
     From the gas washer, the gases are routed to a Western Precipitation
wet electrostatic precipitator.  The unit is 8.5 m (28 ft) in diameter
and contains 260 tubes, each 0.3 m (1 ft) in diameter and 4.5 m (15 ft)
long.  There is a final gas bleed-off valve located on the gas ductwork
after the ESP unit.  This bleeder is set at 0.1 kg/cm  (2 psi) above the
normal furnace topside pressure.

     The blast furnace gas dust cleaning systems are each designed to
handle variable flow rates from 1,800 to 3,100 m3/min (65,000 to 110,000
scfm) with an overall particulate collection efficiency of 99.5%.   USSC
personnel reported that the actual gas flow rates for these systems are
variable, but fall within the design ranges.

     Particulate matter collected in the cyclone units is transported in
a dry form to the Sintering Plant where it is ultimately incorporated
into the feed materials.  The particulate matter collected in the  scrub-
ber and ESP is in a slurry form.  This slurry is piped to a Dorr thick-
ener where the particulate materials are concentrated into a sludge.
This sludge is vacuum filtered to form a cake which is ultimately used
as a feed material at the Sintering Plant.

     The clean off-gases (blast furnace gas) exit from the ESP and are
fed to a collector main which feeds various combustion sources in  the
plant or to a gas storage tank.  The blast furnace stoves are fueled
directly from this main.  The blast furnace gas is also used to fuel
five power boilers.  The blast furnace gas is additionally used to
supplement natural gas to obtain a mixed gas supply.   The addition of
blast furnace gas reduces the natural gas heat content and results in a
mixed gas heat content of about 5,100 kg-cal/m3 (575  Btu/scf).

     Table 9 shows the typical  composition, as supplied by USSC person-
nel, of the clean blast furnace gas.

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                                                                 66
                          Table 9
      TOPICAL COMPOSITION OF CLEAN BLAST FURNACE GAS
                    USSC - GENEVA WORKS
  Gas Constituent
Hydrogen                                 2.5
Oxygen                                   0.01
Nitrogen                                54.4
Carbon Monoxide                         22.5
Carbon Dioxide                          20.5
Participate Matter                0.001  to 0.002 g/m3
                               (0.002 to 0.005 gr/acf)

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                                                                         67
INSPECTION OBSERVATIONS

     The hot metal taps and slag flushes are by far the major participate
emission contributors of the blast furnace-related activities.  Visible
emissions in excess of 40% opacity were noted from both the cast and
flush operations.

     Geneva personnel indicated that the amount of emissions associated
with a given tap depends on the silicon dioxide (SiOp) content of the
hot metal.  They try to maintain the Si02 level at about 1.0%.  When it
drops to about 0.7%, heavy emissions of red-brown iron oxide evolve
during the tap.  This condition was observed during the inspection.

     A strong irritating odor was noted in the cast house area during
the slag flushing operation.  The odor was characteristic of an oxide of
sulfur or phosphorous and persisted for the duration of the flush.  The
particulate emissions observed during the flush were blue-white in
color.

     Some leaking of the furnace bells was noted on both blast furnaces
2 and 3.  The bell leakage was evident whenever a skip hoist unloaded
into the bell hoppers.  Blast furnace 1 was not in operation, but rather
was banked in a stand-by condition due to reportedly unfavorable market
conditions.

     The combustion stacks on the furnace stoves had no visible emissions
when the furnaces were in a normal  operating mode.  Once during the
inspection, blast furnace 2 was placed in a backdrafting mode to repair
a water leak at one of the furnace tuyeres.  When the furnace was back-
drafted, a white-blue plume was noted from the stove combustion stack.
This plume appeared to consist mainly of condensed steam.

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                                                                        68
     There are several  circular or strip chart meters,  located  in each
blast furnace control  room, which are used to monitor pertinent furnace
operating parameters.   Table 10 summarizes the parameters  monitored.

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                                                                   69
                          Table 10
       OPERATING PARAMETERS MONITORED AT BLAST FURNACES
                      USSC - GENEVA WORKS
 1     Blast  Pressure
 2     Furnace Topside  Pressure
 3     Furnace Topside  Gas Temperature
 4     Blast  Temperature
 5     Furnace Temperature at  Various Locations
 6     Stove  Stack Temperature
 7     Steam  Injection  Rate  at Tuyeres
 8     Furnace Burden Height
 9     Water  Pressure to  Furnace Cooling  Members
10     Water  Flow Rate  Through Gas  Cleaning  Scrubber
11     Gas Pressure Before and After Scrubber
12     Gas Collector Main Pressure
13     Stove  Dome Pressure
14     Pressure  Between Furnace  Bells
15     Blast  Rate
16     Natural  Gas Injection Rate at Tuyeres
17*   Gas Bleeder Pressure  (actual and set-point
      for release to  atmosphere)
      Gas bleeder pressures are monitored but not
      recorded.  All other listed parameters are
      recorded on circular or strip charts.

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                                                                        70
                      VII.  OPEN HEARTH FURNACES
     There are ten basic hearth construction open hearth furnaces at the
Geneva Works.  These units are used to convert pig iron from the blast
furnaces, scrap steel, and some iron ore into finished steel.  The total
annual production of ingot steel from these furnaces is about 2,300,000
m. tons (2,500,000 tons)/yr.  The majority of this production is tin
plate steel.  Table 11 lists the metallurgical range of steels produced
at this facility.  The majority of the steel produced has a carbon
content of less than 0.25%.  However, some high carbon steel (0.93%
carbon) is produced for grinding rod manufacture.


PROCESS DESCRIPTION

Hot Metal  Handling

     Molten pig iron (hot metal) is transported by rail to the open
hearth building from the blast furnace cast houses in ladles.  The
ladles are received at the mixer building which adjoins the north end of
the open hearth building.  At the mixer building, the ladles are hoisted
approximately 23 m (75 ft) by overhead crane from the building floor to
one of two Pennsylvania hot metal  mixer vessels.   The hot metal  is
poured from the ladles into the mixer units.

     The two hot metal  mixers have a rated capacity of 730 m. tons (800
tons) each.   These vessels are not mixers in the  true sense of the word,
since external energy is not added to the hot metal  via vessel  rotation,
   •
agitator blades, etc.  The mixers  serve as a hot  metal  surge storage to
compensate for differences between the blast furnace supply and  the

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                                                                 71
                        Table 11
   METALLURGICAL COMPOSITION RANGES OF STEELS PRODUCED
                   USSC - GENEVA WORKS
Component                               % by weight

Carbon                                 0.04 to 0.93
Manganese                              0.03 to 1.75
Phosphorous                            0.035 to 0.075
Silica                                 0.04 to 0.15
Sulfur                                 0.015 to 0.045

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                                                                         72
 open  hearth demand.   Some hot metal mixing  is achieved by combining  the
 contents  of several  hot metal ladle cars  to one mixer.  During  the
 inspection, only  one of the mixers (the north unit) was in operation.
 The south mixer was  off-line for repair to  its refractory brick  lining.

      Hot  metal is  supplied from the mixer units to the open-hearth
 furnaces  by reladling.  When hot metal is required at one of the furnaces,
 the mixers are rotated about 45° and hot metal is poured into waiting
 ladle cars.  These cars, generally three per open hearth charge, are
 then  transported  by  rail to the furnace being charged.


 Furnaces

      The  ten basic hearth open hearth furnaces are rated at 314 m. tons
 (345  tons)/heat and  have an average tap-to-tap cycle of 8 to 9 hours.
The primary function  of these furnaces is to reduce the carbon content
of pig iron received  from the blast furnaces from about 4% to below 1%.
Trace impurities are  also removed from the hot metal in the slag formed
 in the furnace.

     During this inspection period, only five of the furnaces (90, 93,
94, 96, and 99) were  in operation [Figure 9].   Under normal  production
schedules, seven to eight of the furnaces are operated simultaneously
while two to three of them are undergoing major rebuilding or maintenance.
Due to a general  slump in the demand for steel  production, the furnace
production had been curtailed at the time of the NEIC inspection.

     The open hearth furnaces are both reverberatory and regenerative in
design.   They are reverberatory in that the charge to the furnace is
heated both by a  flame passing over the charge  and from radiation from
the relatively low roof of the furnace.   The furnaces are regenerative
in that the hot gases from combustion  of the fuel  pass out of the

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              EXHAUST
           SCRUBBING
            TOWERS
                FANS
       ELECTROSTATIC _
        PRECIPITATORS ^~
NO.I
no. 2
i

NO. 3
! MIXER
* f
NO. 4
; ;

NO. 5
NO. 6
I
MIXER
NO. 7 f
f1
\J
                                                                                MAIN COLLECTOR
                                                                                  FLUE
WASTE GAS
 STACK
    OPEN
   HEARTH
  FURNACES
                                                                                         I.D.FANS


                                                                                         WASTE  HEAT
               Figure 9.  Open Hearth Emission Control System  — USSC Geneva V/orfes
                                                                                                      CO

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                                                                        74
 reverberatory furnace through regenerative chambers which contain fire
 brick  arranged  in checker-work patterns.  The hot combustion gases
 relinquish heat to  the checker bricks.  Periodically, the air flow and
 combustion pattern  directions are reversed, allowing the combustion air
 to be  pre-heated by the previously heated checker work.  This procedure
 permits higher  flame temperatures than could be obtained with cold
 combustion air.  At the Geneva Works open hearths, the frequency of
 checker reversal is about five to six times per hour.  The reversal
 frequency is controlled primarily by the checker temperature with a time
 clock  override.

     The open hearth furnaces can be fueled with natural gas and/or No. 6
 fuel oil.  Pitch and tar obtained from the coke byproduct recovery plant
 can be used in  place of the fuel oil; however, USSC personnel report
 that pitch and  tar  are no longer used for fuel since the market value of
 these materials  is  higher than their equivalent fuel market value.
 Normally the furnaces are operated with 35% of the heat input obtained
 from natural gas and the remainder from fuel  oil.

     The open hearth furnaces are normally run continuously between
major repair periods.  The length of run between major repairs, termed
 the furnace campaign, is usually five to six  months, with minor repairs
being made as required.   A major furnace repair takes two weeks to a
month.

     A normal  open  hearth furnace cycle begins just after the furnace
tap has been completed.   The first half-hour  of the cycle is termed the
fettling period.  During this time,  minor furnace repairs are made to
the hearth bottom and bench by flinging twice-baked dolomite into the
furnace with a dolomite  gun.  Pools  of molten steel  or slag remaining in
the furnace bottom after the tap are blown from the furnace with com-
pressed air.

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                                                                         75
     Once the fettling period is concluded, the charge period begins.
The charging machine places a layer of limestone on the hearth bottom
using preweighed charging boxes.  These boxes are introduced into the
furnace through charging doors located on the front wall of the furnace.
Iron ore and scrap steel are then placed on top of the limestone layer.
The layered combination of limestone, ore, and scrap steel is termed the
header.  The period required for the total cold charging of the furnace
varies from 1 to 1.5 hours.  The furnace burners are operating during
this period.

     Once the furnace has been cold charged, the charge doors are banked
with twice-burned dolomite lime and the melt period begins.  The melt
lasts approximately 45 to 60 minutes.

     At the conclusion of the melt period, hot metal  which has been
reladled from the hot metal mixers is poured into the furnaces from
ladles handled by an overhead crane.  Normally three ladles of hot metal
are added.  A typical  charge to a furnace is 390,000 kg (850,000 Ib) of
total metal of which 160,000 to 280,000 kg (350,000 to 615,000 Ib) are
hot metal.  The hot metal charge period consumes approximately one-half
hour.

     Following the hot metal charge, the slag flush period begins.  A
small break is made in the dolomite bank at the center charging door.
The slag overflows the bank and flows through a floor grate to the slag
pit beneath the furnace.  After the slag is cooled it is broken up and
removed by front-end loader to be ultimately reprocessed at the Heckett
Engineering facility.   The slag run-off period lasts  approximately one
hour.

     The ore boil  and  lime boil  periods follow the flush period.   The
ore boil,  characterized by a gentle and even aggitation of the molten
steel, is  caused by the evolution of carbon monoxide  (CO)  gas.   The

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                                                                        76
CO gas is formed by the oxidation of carbon contained in the molten pig
iron contacting reducible iron oxides in the ore and scrap charge.  The
lime boil, which is characterized by a more violent aggitation of the
molten metal, is caused by the evolution of carbon dioxide (CCL) gas
from the calcining of limestone.  As the lime boil progresses, chunks of
lime migrate up through the molten metal and react with various impuri-
ties in the slag materials.  The ore and lime boil periods require about
2.5 hours.

     After the ore and lime boil periods have subsided, the working or
refining periods begin.  At this time all charged materials are in a
molten form, and the lime has risen from the header to the slag layer.
The purposes of the refining period are to oxidize the remaining phospho-
rous and neutralize it in the slag, to reduce the carbon to the desired
percentage, to lower the sulfur content, and to raise the temperature of
the molten metal bath to a point suitable for finishing and tapping of
the steel.  Additional iron ore and/or limestone are added to the molten
steel during the refining period if chemical analyses of the molten
metal indicate that the carbon, phosphorous, silica, and/or sulfur
content are too high.  Likewise, additional hot metal may be charged
during this period if the levels of these components are too low.  The
refining period lasts about 2.5 hours.

     The majority of the open hearth chemical reactions are based on
oxidation of various impurities in the metal, such as carbon, phosphorous,
sulfur.  Oxygen for these reactions comes, in part, from the iron oxides
in the ore and scrap materials.  Pure oxygen is also introduced into the
molten bath through oxygen lance tubes suspended through the furnace
roof.  There are two such lances per furnace located about mid-furnace
in a front-to-back direction and opposite the number 3 and 5 charge
doors.  The oxygen lancing rate is about 1,100 m /hr (38,000 acfh) per
furnace.  The oxygen lancing period begins shortly after the hot metal
addition to the furnace and continues up through the refining period,
accounting for about one-half of the entire heat period.

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                                                                        77
     At the end of the refining period the furnace is readied for the
tap.  A ladle capable of holding the entire furnace contents is po-
sitioned at the rear of the furnace below the tap hole and tapping
spout.  The clay-loam plug and most of the dolomite which block the tap
hole are manually removed.  The tap hole is then completed by detonating
an explosive charge of nitroglycerine in the hole.  When the hole is
completed, the furnace contents are emptied into the ladle via the tap
spout.  Steel additives and alloying materials are added to the ladle
from storage hoppers by feeder mechanisms as the molten steel is pouring
into the ladle.  Slag materials accumulate on the surface of the molten
metal in the ladle.  Toward the end of the tap, the slag overflows the
ladle's slag spout and is discharged into the slag pit.

     Each furnace has its own operations booth which contains the various
monitors and recorders required to accurately control the heat cycle.
Table 12 summarizes the parameters which are monitored at each furnace.
Ingot Pouring

     At the end of the tap, the ladle of molten steel is transported to
the pouring platforms which are situated along the inside wall of the
open hearth building opposite the rear of the furnaces.  Ingot molds
standing on mold rail cars are situated along these platforms ready for
filling.  The ladle is equipped with a lever-actuated pouring nozzle
which is situated in the ladle bottom.  Operators, standing on the
pouring platforms and working in conjunction with the crane operator,
operate the nozzle lever to direct molten steel from the ladle into the
ingot molds.  The actual pouring operation takes about 45 to 60 minutes.

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                                                                  78
                         Table 12

             OPERATING PARAMETERS MONITORED AT
                   OPEN HEARTH FURNACES

                    USSC - GENEVA WORKS

1
2
3
4
5
6*
7f
8
Parameters
Oxygen in Furnace Exhaust Gases
Natural Gas Consumption by Furnace Burners
Oxygen Flow to Both Furnace Lances
Combustion Air Flow
Fuel oil Consumption by Furnaces Burners
Carbon Content of Metal Bath
Temperature of Metal Bath
Furnace Pressure
Units
%
scfh
scfh
scfh
9Ph
%
°F
inches of wat<
9   Exhaust Gas Temperature
 t The metal bath carbon content and temperatures are
   periodically obtained from grab samples of the
   bath.
tt Exhaust gas temperatures are obtained from four
   locations^ after both sets of regenerative checkers
   and in both flues leading to the waste heat boiler.

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                                                                         79
 PARTICULATE EMISSION SOURCES AND INSPECTION OBSERVATIONS

      The open hearth furnaces discharge their combustion gases through
 the regenerative heating systems to collection and control  equipment.
 After passing through the checker brickwork,  the  gases  are  routed to
 waste heat boilers and induced draft fans  on  each furnace.   The fans
 discharge into a common collector main  which  serves both to mix the
 exhaust gases and to equalize the flow  variations associated with furnace
 operations.   From the manifold, the gases  are routed to eight banks of
 electrostatic precipitator/scrubbing tower systems operating in parallel.
 From the scrubbers,  the gases are discharged  to the atmosphere.

      There are considerable  quantities  of  fugitive emissions associated
 with the hot  metal mixing and furnace operations.   These fugitive emis-
 sions are essentially uncontrolled.   It was observed during  the  inspec-
 tion that these emissions escape  through louvers  in the  building  roof  to
 the atmosphere.

      There are significant fugitive  emissions  associated with  the hot
 metal  transfer and reladling  operations.   Kish, a  graphite-like material,
 is  liberated  from  the  hot metal during both the transfer and  reladling
 operations, and  fallout  of this material is very  noticeable.   Copious
 quantities of  smoke  and  fume  were noted within  the  mixing building
 during  these operations.  Substantial amounts  of  these emissions  exit
 the  building  through  roof louvers as fugitive  emissions.

     The  pouring of  hot metal from the ladles  to the mixer during
 transfer  operations  takes approximately two minutes  per ladle.  The
 emissions from this operation did not appear to be  too dense.  A  typical
 reladling operation from the mixer to the ladle transfer cars  takes
about four to five minutes for a three-ladle transfer.  Relatively heavy
emissions were observed during these operations.  The mixing building
personnel indicated that the heaviest emissions occur when the silicon
dioxide and/or sulfur content of the hot metal is  high.

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                                                                         80
     The open hearth furnaces themselves are operated under a slight
 positive pressure  to minimize air infiltration into the combustion and
 regenerative zones.  Since they are under positive pressure, the furnaces
 tend to leak fugitive emissions at various points such as charge door
 seals, faulty brickwork, etc.  The degree of such leakage appeared to
 vary from furnace  to furnace, reportedly in proportion to the relative
 length of time into the current campaign.  The furnace leakage was
 continuous throughout the heat cycle.  The heaviest leakage appeared to
 occur whenever a checker reversal occurred.

     Fugitive emissions occurred during the various furnace charging
 periods, whenever  the charge doors were opened.  The emissions during
 the scrap and hot metal charges were relatively light, with the heaviest
 emissions occurring during the light scrap charges.  A relatively heavy
 emission of 30 to 60 seconds duration was noted at Furnace 94 when a
 charge of iron ore was added to the molten metal  bath near the end of
 the refining cycle.

     The heaviest fugitive emissions occurred during the furnace tapping
 operations.  These emissions were also of significant duration.  The
 entire furnace tap operation lasted 8 to 10 minutes.  The heaviest
 emissions occurred when the molten steel first entered the receiving
 ladle.   The second heaviest emissions were observed during the 4 to 5
minute period during which alloys and additives were added to the
molten steel  in the ladle.   The emissions from the latter operation were
very dense and reddish in color.

     Relatively heavy fugitive emissions were also noted  throughout the
 ingot casting period.   The emissions from this  operation  were not as
heavy as from the tapping operation, but lasted considerably longer,
about 45 minutes.

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                                                                         81
 PARTICULATE CONTROL SYSTEM

      Figure 9 shows a flow diagram of the open hearth furnace emission
 control system, which consists of a main collector flue and eight gas
 treatment trains.  The collector flue receives off-gas from the ten
 waste heat boilers through individual induced draft fans.   The flue
 combines and mixes the off-gases so that their temperature and parti-
 culate concentrations are equalized as much as possible prior to entry
 into the individual gas treatment trains.  Each gas treatment train
 consists of an electrostatic precipitator,  a fan,  and a scrubbing tower
 arranged in series.


 Process Emissions

      The gases emitted from the  open  hearth process consist principally
 of air which has  been modified by the oxidation of fuel.   As  the result-
 ant combustion gases  sweep across the surface  of the furnace  charge,
 particulate is entrained  and  carried  out with  the  gases.   As  the furnace
 is cycled  throughout  a heat,  the  amount,  size  range and characteristics
 of particulate from the furnace  can be  expected to vary significantly.
 However,  since there  can  be as many as  ten  furnaces on-line in  various
 stages  of  a  heat,  the  ranges  in  particulate emissions  from the  open
 hearths  overall tend  to be  less varied  than those  from an  individual
 furnace.   The  temperature  of  the  off-gases  to  the  particulate control
 system  should  be fairly uniform,  because  of the  flue gas collector main
 and  the waste  heat  boilers.   By nature  of the  operation, the gases
 leaving  the waste heat boilers are expected  to  have  reasonably constant
 temperatures (+ 8°C).  The off-gas flowrate, on  the other  hand, can be
 expected to vary significantly.   It will change with such  variables as
 the number of  furnaces in operation, air inleakage at  the  checkers, etc.

     The expected characteristics of the emissions from the open hearth
furnace system are shown in Table 13.

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                                                                        82
                               Table  13
            CHARACTERISTICS OF EXHAUST GAS AND PARTICULATE
                  EMISSIONS FOP OPEN  HEARTH FURNACES
                          USSC - GENEVA WORKS
 Parameter
         Furnace Exhaust
Temperature
Pressure
Flow Rate
Particulate Concentration
Particulate Size Range
220 to 228°C (425 to 450°F)
-9 to -13 cm (-3.5 to 5.0 in) U.G.
1,900 std m3/min (67,000 scfm) per train
2 to 7 g/m3 (1  to 3 gr/scf)
> 149 vim
7-149ym
44-74ym
20-44]im
10-20ym
5-10ym
<5ym
0.1%
1.2%
8.7%
1.0%
3.0%
5.0%
81.0%
Particulate Composition
  (% by weight)
Fe
CaO
A1203
Zn
Si09
2
MgO
S
Pb
K2°
65
1.9
1.4
1.0
0.89

0.81
0.50
0.30
0.30

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                                                                        83
Electrostatic Precipitators

     The electrostatic precipitators (ESP's) used in the open hearth
furnace emission control system are Research-Cottrell plate-type precipi-
tators initially installed in 1955.  The ESP's were modified in 1972 by
increasing the number of transformer-rectifier sets for each ESP from
two to three.  The ESP's have three electrical fields with two sections
per field.  Perforated plate distribution devices are located at both
the inlet and outlet of the precipitators.  Dust which is collected in
the ESP hoppers located below the collection plates is transferred
through wet eductors to a clarifier.  USSC has reported that the ESP
design particulate removal efficiency is currently 95.8% with an inlet
dust loading of 8 g/m  (3.4 gr/scf).

     General, physical, and design parameters for the precipitators were
supplied by USSC and are presented in Table 14.  All parameters appear
typical of literature values for other open hearth applications.  The
resistivity value given in Table 14 was determined by USSC consultants
through laboratory measurements.  Such laboratory data are typically
more than an order of magnitude higher than for actual operating con-
ditions.  Nonetheless, the actual resistivity should still be well
within the accepted range for effective precipitator performance.

     The operation and control  of the open hearth ESP's are monitored by
various meters located in the ESP control room.  There are meters  for
primary current and voltage, secondary current and voltage, and spark
rate.   During the inspection, one set of readings was taken from the
meters.  These data are shown in Table 15.

     The usefulness of the data shown in Table 15 is limited.  The data
presented are for only one set  of operating conditions, but do provide
an indication of the parametric values.   It should be noted that each
field  in a given precipitator is energized differently -- fields 1  and 3

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                             Table 14
           GENERAL, PHYSICAL, AND DESIGN PARAMETERS FOR
          OPEN HEARTH FURNACE ELECTROSTATIC PRECIPITATORS
                        USSC - GENEVA WORKS
Parameter
               Specifications
General
Number of Precipitators - 8
Date Installed - 1955
Precipitator Type - Plate
Manufacturer - Research Cottrell
Physical
Design
Number of mechanical sections - 4
Collection area
     Electrical field 1 - 562 m2 (6,043.5 ft2)
     Electrical field 2 - 562 m2 (6,043.5 ft2)
     Electrical field 3 - 1,124 m2(12,087 ft2)
Number of gas passages - 34
Width of gas passages - 20 cm (8 in)
Flow distribution devices - perforated
plates located at inlet and outlet
Number of HT sections per field - 2
T-R sets
     field 1 - 1/2 wave, silicon/saturables
               reactor
     field 2 - 1/2 wave, silicon/transistor
     field 3 - 1/2 wave, silicon/saturable
               reactor
DC Voltage - 45 kV design, 35 kV actual
Control mode - automatic voltage control
based on spark rate (200 - 400 sparks/min
setting)
Meters - primary current and voltage, sec-
ondary current and voltage, spark rate
Particulate removal efficiency - 95.8%
Specific collection area - 180 ft2/!,000 acfm
Resistivity - 4 x 10  ohm-cm @ 205°C
Velocity - 1.6 m (5.2 ft)/sec
Precipitation rate parameter - 8.05 cm/sec

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                                    Table IS

                OPERATING DATA COLLECTED FROM OPEN HEARTH FURNACE
                  ELECTROSTATIC PRECIPITATOES - AUGUST ?.4,  1976*
                               USSC - GENEVA WORKS
                                                                                       85
ESP
1

2


3


4


5


6



8


Field
1
2
3
1
2
3
1
2
3
1 .
2
3
1
2
3
1
2
3
7
1
2
3
Primary
Voltage
Volts
240
270
240
260
260
230
240
240
220
240
250
230
260
270
220
240
270
230
Not in
210
250
200
Primary
Current
Amps
23
29
33
30
32
32
22
26
43
23
32
35
25
29
25
27
32
38
operation
12
20
6
Power
kVA
5,500
7,800
7,920
7,800
8,300
7,360
5,300
6,500
9,500
5,500
8,000
8,000
6,500
7,800
5,500
6,500
8,600
8,700

2,500
5,000
1,200
Secondary
Current
mi Hi amps
40
160
80
NRft
150
70
NR
160
100
45
170
80
NR
160
50
50
180
90

25
110
10
Power
Secondary Spark Efficient
Voltage Rate Power kW
kV spin kW kVA
30
34
35
35
34
32
32
31
26
30
27
27
35
32
31
30
35
30

32
31
28
380
390
260
350
5
10
260
130
115
310
35
180
290
280
230
135
130
300

380
10
375
1,200
5,400
2,800
5,100
2,200
--
5,000
2,600
1,400
4,600
2,300
—
5,100
1,500
1,500
6,300
2,700

800
3,400
280
21%
69%
35%
61%
30%
--
77%
27%
252
58%
29%
—
65%
27%
23%
73%
31%

32%
58%
23%
:y Current
wA
m2
0.61
2.5
0.61
1.2
0.54
--
2.5
0.77
0.69
2.6
0.62
—
2.5
0.38
0.77
2.8
0.69

0.38
1.7
6.07
v.A
ft2
6.6
26.5
6.6
12.4
5.8
--
26.5
8.3
7.4
28.1
6.7
—
26.5
4.1
8.3
29.8
7.4

4.1
18.2
0.8
 t  Data obtained between  2:00 and  4:00 p.m. from ESP control room meters.
tt  Reading was low or off scale.

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                                                                        85
utilize the older saturable reactor transformer-rectifier (T-R) sets,
while field 2 uses a transistorized set.   Field 3 also energizes twice
the collection area of the other two fields.

     From Table 15, it appears that fields 1  and 3 in each ESP are
operating at relatively low current densities (
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                                                                         87
     1.   A large buildup of particulates was observed over the face of
the inlet flow distribution plate, covering up approximately 50% to 60%
of the total plate surface area.  This condition can contribute to
significant flow imbalances within the precipitator and cause increased
turbulence and pressure drop.

     2.   Several relatively large particulate deposits (2 to 5 cm
thickness) were noted on the collector plates.  Such deposits can
produce increased turbulence, flow imbalance and pressure drop, as well
as affect voltage-current characteristics.  These deposits further
indicate that the rapping system may not be operating properly.  In
addition, re-entrainment losses caused by higher gas velocity through
constricted flow passages may also result.

     USSC representatives indicated that each ESP is taken off-line for
cleaning and maintenance every 3 to 4 months.  The statements as to the
extent of the maintenance provided, however, were not entirely consist-
ent between representatives.  Typical maintenance as performed by USSC
probably includes removal of broken or malfunctioning corona wires,
checking and cleaning insulator wires, and removal of particulate
buildup on collection plates as can be accomplished by an air lance.
Any significant particulate buildup would probably include continuous,
prolonged use of the mechanical rappers.   Only if major electrical
problems or very severe dust buildup were found would an extensive
cleaning program be initiated.   USSC did  not appear to conduct routine
inspections of the precipitators by knowledgeable personnel  to check for
poor flow distribution, significant dust  accumulations, etc.


Scrubbers

     The scrubbers used in the  open hearth furnace emission  control
system are USSC-designed and constructed  partial-orifice wet  scrubbers

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[Figure 10].  Initially erected in 1962, the scrubbers were modified
during 1973 through 1975 by relocating internal sprays and removing the
mist eliminator.  USSC reported that this was done to reduce maintenance
requirements and provide better mist elimination.  Scrubber spray water
consists of recycle water from the neutralization/clarification system
diluted with plant makeup water.  The discharge from the scrubber is
pumped to the clarification/neutralization system for treatment.

     General and design parameters for the open hearth scrubbers, as
supplied by USSC, are shown in Table 16.  USSC stated that the scrubbers
were originally designed for hydrogen fluoride (HF) removal and were
selected because they would provide adequate HF removal and good access
for maintenance.  However, the use of these scrubbers for particulate
removal is questionable for two reasons:  particulate removal capa-
bility, and mist carryover.

     The most questionable design parameter is the reported particle
removal efficiency (75%).   This efficiency is typically a function of
the size of particulate removed and the energy input into the scrubber
(pressure drop).  The USSC-reported efficiency for these units appears
to be much higher than would be anticipated for low pressure drop opera-
tions (10 cm W.G.) with the submicron particulates anticipated.  The
particle size data provided by USSC is limited and is based on laboratory
measurements rather than in-situ measurements.  However, based on other
open hearth operations, the majority of the particulates in the gas
stream is expected to be in the submicron size range.  This submicron
particulate typically requires high scrubber energy inputs (i.e., 50+ cm
W.G.) to obtain 75% removal.  For example, wet scrubber tests sponsored
by the EPA have indicated  that even with an energy input of 50 cm W.G.,
collection of fine particulates would be much less than 50% for <0.5pm
particles.  Although factors other than classical impaction dynamics
(i.e. diffusiophoretic and electrophoretic forces) may enhance parti-
culate capture in the treatment system, it is highly questionable that
the USSC scrubbers could remove as much as 75% of the particulates.

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                                EXHAUST
                                                             89
                                 SAMPLE PORT
                   SPRAY BANK
                   ?	O	
            SPRAY NOZZLE HEADER
                                ORIFICE
                                                •GAS INLET
Figure 10. Open Hearth  Scrubber — USSC Geneva Works

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                                                                     90
                            Table 16
               GENERAL AND DESIGN PARAMETERS FOR
                 OPEN HEARTH FURNACE SCRUBBERS
                       USSC - GENEVA WORKS
Parameter                          Specification

General               Number of scrubbers  - 8
                      Date installed  - 1962
                      Scrubber type - partial  orifice
                      Manufacturer -  USSC
                                                          3
Design                Particulate inlet loading -  0.23  g/m
                                                  (0.1  gr/scf)
                      Particle size - submicron (estimated)
                      Particulate removal  efficiency -  75%
                      Scrubber pressure drop - 10  cm (4 in)  W.G.
                      Scrubber water  rate  - 2,500  1(650 gal)/min
                      Scrubber gas velocity - 0.85 m (2.8 ft)/sec
                      Gas volume - 1,900 m7min (67,000  scfm)
                      Gas temperature - 200°C
                      Gas pressure -  640 mm Hg

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                                                                       91
     A second questionable design feature is the lack of mist elimina-
tors.  USSC stated that the bank of sprays located above the orifice
sprays [Figure 10] provide adequate mist elimination.  However, with a
gas velocity of 0.85 m (2.8 ft)/sec, a large portion of <250iim diameter
droplets will be carried out with the gas stream.   The hollow cone
nozzles used in the USSC open hearth scrubbers when operating at 11  to
12 atmospheres (150 to 170 psig) pressure and under evaporating condi-
tions will produce a significant amount of <250iam diameter droplets.
These droplets would contain dissolved and suspended solids which would
become particulate upon leaving the stack.  Based on rough calculations,
this droplet carryover could amount to an 0.02 to 0.07 g/m  (0.01 to
0.03 gr/scf) addition to the exit particulate concentrations [Addendum
C].

     Operation of the open hearth furnace scrubbers is not monitored,
other than the scrubber water pressure.  Two WP-50 single point sampling
trains are located on two of the gas treatment trains.  However, the
utility of the resultant data has been discussed previously.  As a
result of the lack of operating indicators, the analysis of the open
hearth furnace scrubber operations was limited to observation of the
exhaust plumes from active scrubbers and the internals of the inactive
No. 7 scrubber.  The following points were noted during the inspection:

     1.   The opacity of the plume, after the steam had dissipated,  was
          highly variable.  There were, however, many cases when the
          plume opacity was in the range of 40% to 60%.

     2.   There was a significant buildup of solids in the No. 7 scrub-
          ber unit at the wet/dry interface, just as the incoming gas
          contacts the orifice spray.  The effect of this phenomena  on
          particulate removal is not readily apparent.

     3.   There was a significant buildup of solids on the scrubber  wall
          just opposite the gas entrance.  This would indicate that  the

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                                                                         92
          major portion of the gas was flowing up one side of the
          scrubber.   Consequently, it can be deduced that the gas stream
          is not well  distributed as it reaches the top section of
          sprays.  With the resulting higher velocities and reduced
          spray coverage, mist carryover would increase and effective
          particulate removal  would decrease.

     USSC reported that routine maintenance is performed on the open
hearth scrubbers by Company personnel about every 3 to 4 months.  The
maintenance program involves removing solids deposits, which are predomi-
nantly calcium sulfate and calcium fluorides.  The areas most affected
by these deposits are the inlet orifice wet-dry interface, the scrubber
waste slurry discharge drain and the nozzles, piping, and piping supports.
Since the recycle water supplied from the clarification/neutralization
system is low in total suspended solids and is below saturation with
respect to dissolved solids, degradation in the nozzle spray pattern
resulting from effects of plugging, scaling or erosion should be adequately
minimized with the current 3 to 4 month inspection frequency.  Overall,
there did not appear to be major maintenance problems of the open hearth
scrubbers which would affect nominal particulate removal.

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                         VIII.   ROLLING MILLS
     The final steel products from the Geneva facility include plate and
coiled strip steel, steel  pipe, and structural shapes such as I-beams,
angles, and channels.  The conversion of the open hearth ingots into
these products occurs in the various rolling mills.


PROCESS DESCRIPTION

Slab Mill
     The ingots produced at the open hearth building are cooled and
transported in their molds by railroad car to the slab mill.  Here the
molds are stripped from the ingots by overhead cranes and placed in
reheat ovens known as soaking pits.  The function of the soaking pits is
to raise the temperature of the steel until it is sufficiently plastic
to allow reduction from ingot size by rolling.

     At the slab mill there are twenty soaking pits.  Sixteen of these
units are bottom fired and four are top fired.  Each of the twenty pits
have a rated capacity of 5 x 106 kg-cal (20 x 106 Btu)/hr heat input.
They were originally designed to be fueled with excess coke oven gas.
However, under current operating modes, the pits are fueled exclusively
with mixed gas, which is natural gas stabilized with blast furnace gas
to a heat value of 4,980 to 5,160  kg-cal/m3 (560 to 580 Btu/scf).

     The heated ingots are removed from the soaking pits by overhead
crane and placed on a buggy unit.  The buggy  is used to transport the
ingot to the head end of the 110 cm  (45 in) diameter slab mill.

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                                                                        94
     The 110 cm (45 in) mill has, until just recently, served the dual
role of producing slabs and blooms from ingots.  Slabs are the starting
point for producing sheet, plate, and strip steel.  Blooms are the
starting point for producing structural steel shapes.  The 110 cm (45
in) mill can roll either shape.  Previously the blooms and slabs were
then segregated after this mill for final rolling in the appropriate
finish mill.  USSC has recently completed construction of a new bloom
mill which is an integral part of the structural mill.  The new bloom
mill, discussed in detail later in this section, thus removes the dual
rolling duties from the 110 cm (45 in) mill and allows it to be used
exclusively for slab rolling.  USSC feels that the new bloom mill will
eliminate a substantial bottleneck in the production facility and permit
optimization of plant production.  The following discussion considers
the 110 cm (45 in) mill strictly as a slab mill.

     Slabs produced in the 110 cm (45 in) mill are edge-treated and
sheared to length before being removed to a holding yard.  At the
holding yard, the slabs are examined and any surface blemishes which are
found are removed by hand scarfing.  There are no automatic scarfing
operations at the Geneva facility.  The scarfed slabs are then stock-
piled in the holding yard to await finish rolling.


Plate and Hot Strip Mill

     The slabs are removed from the storage yard and placed in reheating
furnaces.  There are four, three-zone reheating furnaces of the pusher
design which serve the plate and hot strip mill.  Each furnace has three
heating zones:  the top, bottom, and hearth zones.  The hearth zones are
fueled with mixed gas exclusively.  The top and bottom zones are fueled
with mixed gas and/or No. 6 fuel oil.  The furnaces each have a rated
capacity of 63 x 106 kg-cal (250 x 106 Btu)/hr heat input.

-------
     The plate and hot strip mill  is a dual  purpose mill  which can
produce either plate steel  or coils of strip steel.  Slabs from the
reheat furnaces enter the rolling  line.  They are first subjected to
edging and scale breaking operations.  The slabs are then passed through
a broadside mill which is a Mesta  340 cm (132 in), 4-high mill.  This
mill reduces the slab thickness and obtains  the finished plate width.
The rough plate then passes to a reversing rougher, which is also a 4-
high mill used to further reduce the rough plate to a thickness suitable
for finish rolling.

     The rough plate passes through a pair of pinch rollers to six
finishing strands.  This operation also includes a 4-high mill.  On the
finishing strands, the plate is reduced to final thickness.

     The finished plate passes through a runout area to a leveler which
flattens it, and then to the finishing facility.  Here the plate is cut
to finished length and width.  The finished  plate is then sent to
stockpile.  Plate up to 3 m (10 ft) wide and 12 m (40 ft) long can be
produced at this facility.

     Essentially the same rolling  equipment  is used to produce steel
strip.  However, after the strip is leveled  it can either be cut into
short lengths on a flying shear and stacked  by a hot piler or it can be
rolled into coils.  At Geneva Works there are two Bliss hot strip
rotating mandrel downcoilers and one Mesta hot strip stationary mandrel
downcoiler which can receive the continuous  strip from the mill and
produce coils of strip steel.


Structural Mill
     With the completion of the new 100 cm (40 in) bloom mill, the
structural mill is now an autonomous unit.  Ingots are received at this

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                                                                        96
mill in molds, stripped, and placed in the soaking pits by overhead
cranes.  There are eight soaking pits for the structural  mill.  Each pit
has a rated heat input of 9 x 10  kg-cal  (36
fueled with mixed gas and/or No. 6 fuel oil.
has a rated heat input of 9 x 10  kg-cal  (36 x 10  Btu)/hr and can be
     Heated ingots are removed from the soaking pits and placed on a
buggy by overhead crane.  The buggy conveys the ingot to the bloom mill
where it is reduced in cross-section to form a bloom.

     The blooms are sent to a storage yard where they are inspected for
surface defects.  If defects are found, the entire bloom is manually
scarfed as there are no automatic scarfing machines at this facility.
There are ten hand scarfing stations, four to ten of which are operated
simultaneously, depending on production rates.  The scarfing stations are
operated 24 hr/day.

     From the storage yard, the blooms are placed in three, three-zone
pusher-type reheat furnaces.  These reheat furnaces are similar to those
used in the plate and hot strip mill in that they have top, hearth, and
bottom heating zones.  The top and bottom zones are fueled with mixed
gas and/or No. 6 fuel oil.  The hearth zones are fueled with mixed gas
exclusively.  The furnaces each have a rated capacity of 50 x 10  kg-
cal (200 x 106 Btu)/hr heat input.

     Blooms from the reheat furnaces enter the structural shape rolling
line.  They first are passed through an 81 cm (32 in) 2-high Birdsboro
reversing mill to produce a blank.  This blank is then passed through a
66 cm (26 in) 3-stand, 3-high Morgan structural mill to produce the
desired structural steel shapes.  The structural mill has an annual
production capacity of 77,000 m. tons (85,000 tons) and an average daily
production capacity of 210 m. tons (236 tons).

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                                                                        97
 Pipe Mill

      The  pipe  mill  is  located  in a  separate  building  situated  at  the
 northern  end of  the Geneva Works.   There are two  steel  pipe  production
 lines in  this  plant.   One line  produces pipe ranging  in diameter  from 10
 to  40 cm  (4 to 16  in);  the second line produces the large diameter pipe
 ranging from 50  to  100 cm (20  to 40 in).   Neither of  these lines  incor-
 porates furnaces, ovens or other combustion  devices since all  of  the
 rolling or forming  is  accomplished  cold.

      The  small diameter line produces steel  pipe  by a continuous  forming
 and electric-resistance welding process.   Strip steel is fed into the
 head end  of the  line from coils.  The strip  is passed through  a series
 of  forming rolls which  sequentially convert  the flat  strip into a circu-
 lar shape.  The  circular shape  is then passed through welding  electrodes
 to  form a continuous strand of  pipe.  The  welded  pipe is then  passed
 through sizing mills which insure a  round  finished product of  desired
 diameter.  Straightening the pipe also occurs here.  After sizing, the
 pipe is cut to predetermined lengths by traveling saws and transferred
 to  the finishing floor.  The lengths of pipe are  again straightened, if
 required, and  subjected to special  cutting and end finishing,  when
 needed, before being packed for shipment.

      The large diameter line produces pipe on a piece-by-piece basis by
 electric welding of formed plate steel.   Steel plates used in  the process
 are  received from the plate mill.   At the pipe mill, plates are edge-
 planed to provide square and true edges.   The plates are then edge-
 crimped in a crimping press and transferred to a "U"-ing machine.   This
device forms the crimped plate into a U-shape using hydraulic presses
and a large die.   The U-shaped plate is  next transferred to the "0"-ing
machine, which  uses hydraulic pressure and  special dies  to form the U-
shape into an  almost closed  circular shape.  From  here the 0-shape is
sent to welding machines which place inside and  outside  welded  beads

-------
                                                                        98
along the gap using submerged-arc techniques.   The welded pipe section
is then sent to an expanding station where it  is expanded to final  size
and roundness by subjecting it to internal hydraulic pressure against a
retaining jacket.  After expanding the pipe, the hydraulic pressure is
reduced and the pipe pressure is tested.   The  expanded pipe is then
routed to the finishing area where it is  end-faced and beveled, if being
prepared for field welding.


PARTICULATE EMISSION SOURCES AND INSPECTION OBSERVATIONS

     A complete inspection was made of the rolling mill facilities.  The
entire plate and hot strip mill, the 110  cm (45 in) slab mill, and the
small diameter pipe mill line were not operating during the inspection.
The former was not operating due to emergency repair of the slab mill.
The small diameter pipe mill was not operating because product inventory
was high.  The structural mill and the large diameter pipe mill were
observed in operation.

     The rolling mill operations appear to contribute relatively small
amounts of particulate emissions to the overall emissions from the
Geneva Works.  The largest potential emission sources are the eight
soaking pits in the new 100 cm (40 in) bloom mill and the seven slab and
bloom reheat furnaces, all of which can burn No. 6 fuel oil.  The air-
to-fuel ratio control for these units is  accomplished by manual adjust-
ment.  There are no stack gas opacity meters on these systems so there
is no reliable method to permit the operators to maintain clean burning
stacks.

     The other potential sources of particulate emissions related to the
rolling operations are the hand scarfing  stations in both the plate and
hot strip mill and the structural mill.  Scarfing was observed at both
of these locations during this inspection.  Some scarfing-related fugi-
tive emissions did escape from the louvers in the roofs covering these
areas.  The magnitude of these emissions  did not appear significant when
compared with other particulate emission  sources at the Geneva Works.

-------
                          IX.  SLAG HANDLING
     All slag produced at the blast furnaces and open hearth furnaces at
the Geneva Works is processed at a plant adjacent to the northwest end
of the steel production operations.  The slag processing facilities are
operated under contract between USSC and the Heckett Engineering Company.
The Geneva plant is one of several similar operations carried out by
Heckett throughout the world.  The primary objective is to recover
metallics (iron and steel) from slag.  Additionally, at the Geneva plant
non-metal!ics from the slag are processed to produce aggregates for road
building materials and for railroad ballast.  At Geneva, Heckett employs
about 70 people, operating 16 hr/day, 5 days/week.

     Slag from either the blast or open hearth furnace  is transported
to the Heckett plant by USSC vehicles.  Although some metallics are
recovered from the blast furnace slag, the bulk of the metallics are
recovered from the open hearth slag.  Thus, Heckett operates two process-
ing lines, or "sides," the open hearth and blast furnaces "sides."


PROCESS DESCRIPTION

Open Hearth Side

     A flow diagram of the process is shown in Figure 11.  Throughput is
about 180 m. tons (200 tons)/hr.  Hot open hearth furnace slag is off-
loaded from USSC trucks and cooled for 3 to 4 days prior to processing.
Simple lawn sprinklers are used to cool the slag and assist in reducing
potential  dust emissions.   A magnet is used to separate large metallic
pieces from the non-metallic or mixed material and these larger pieces
are returned to the open hearth furnaces.   The remaining material

-------
Hot SI an to Storane
Area from USSC


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Screen j-<— — 1 Screen 1 I Refined 1

[
Oversize Undersize OvC,si/c
t t {
Waste Rail y yg^p
Undersize \
y
Waste
Figure 7?.  Open Hearth Slag  Processing Flow Diagram



              Heckeff   Engineering Company
                                                                                       o
                                                                                       o

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                                                                         101
 is moved  by  front-end  loader  to one of two feeders which  transfer  the
 material  to  belt conveyors.   The material passes through  "scalpers"
 which  separate all material greater than 30 cm  (12 in).   Material
 smaller than 30 cm (12  in)  is conveyed through  drum magnets which
 separate  non-metallic  material from metallic material.

     The  non-metallic  material passes through screens which separates
 material  greater than  10 cm (4 in).  Oversize material passes through a
 jaw crusher  and then rejoins  the undersize material to be screened
 again.  Material greater than 2.5 cm (1 in) is  wasted, while undersize
 material  is  sold as railroad  ballast.

     Metallic material  separated by the drum magnets is screened to
 segregate all material  greater than 12.5 cm (5  in).  The  oversize
 material  is  "refined"  by passing slowly through a "barrel," a rotating
 drum where non-metallic material is removed by  impact with the drum
 sides, as well as the  other material in the drum.  Retention time  in the
 drum is about 30 minutes.   The refined metallics are then transported to
 USSC for melting in the open  hearth furnaces.   The undersize material is
 screened and all material less than 0.9 cm (3/8 in) is wasted.  Oversize,
 ranging from 0.9 cm (3/8 in)  to 12.5 cm (5 in), is transported to USSC
 for melting  in the blast furnaces.


 Blast Furnace Side

     A flow diagram of the  process is shown in Figure 12.   Throughput
was about 180 m. tons  (200  tons)/hr.  However, plans for major process
changes to be made in October 1976 increased the capacity to about 360
m. tons (400 tons)/hr.

     Molten slag from the blast furnaces  is transported by rail  and
dumped at the Heckett site in  one  of two  "pits."  The partially cooled

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                                                                                      102
                             Slan Pit
                              Ripning
                                u
-Mater  Snray
                              Scalper
                    Oversize
Hater.
Spray
Cone Crusher
                           Undersize
                                                  Hannet
                                                    Metallic*     To USSC
                                                  Screen
                                         Oversize
                                              Undersize
                                                        Hannet
                                        Water Snray
                                                                     •letallics
                                                                    To USSC
                                                         Screen
                                                       >2.5 cm (1 in)
                                                                       Cone  Crusher
                                                      0.9 en (3/8 in) - 2.5  cm  (1 in)
                                                                                    Rail
                                                                                  Ballast

                                                      0.5 cm (.1/16 in) - 0.9 cm  (3/8 in)
                                                                                    Road
                                                                                   Chins
                                                      <0.5 cm (3/16 in)
                                                                   Driveway
                                                                   Materials
             Figure 12. Blast Furnace Slag Processing  Flow Diagram

                             Heckelt Engineering Company

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                                                                          103
  material  is  "ripped," or  broken  up  by USSC-operated  bull  dozers,  and
  then  sprayed with water to complete the coolinq process and  to assist  in
  reducing  fugitive emissions.  The cooled wet slag  is moved by front end
  loader from the pit to a  hopper  from which  it moves  over  a "scalper"
  which removes all material greater  than 28  cm (11  in).  Undersize
  material  passes by a magnet which removes the limited amount of metallic
  material.  The non-metallic material is screened to  remove any material
  greater than 10 cm (4 in).  The oversize passes through a cone crusher
  and is returned to the screen.  Undersize is conveyed to a crusher
  building and passes by a second magnet for  further removal of the lim-
  ited metal!ics material.

      After removal  of the metal lies, the material  passes through screens
 which segregate the material  into four size categories (-0.5  cm,  +0.5 cm
 to -0.9 cm, +0.9 cm to -2.5 cm,  and  +2.5 cm).   The latter material is
 processed in a cone crusher and  returned to the  screens.   The +0.9 cm
 to -2.5 cm material  is sold as railroad  ballast;  the +0.5  cm  to  -0.9 cm
 material  is sold as road  chips,  the  material used  as overlay  on  asphalt
 roads  and streets.   The smaller  material  (-0.5 cm)  is sold for use on
 driveways or for "de-icing".   The road chips must  be cleaned  prior to
 sale and  this  is accomplished  by "wet screening,"  or washing.
 PARTICULATE  EMISSION SOURCES AND CONTROL SYSTEM

     Virtually all phases of the operation are potential sources of
 particulate  emissions.  These include the roadways used for hauling
 materials, loading and unloading of raw and finished materials, screen-
 ing and crushing operations, and conveying materials between process
 steps.

     The primary method for abatement of emissions is the use of water.
The slag is thoroughly wetted prior to beginning  of processing on

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                                                                        104
either side.  On the open hearth side, water sprays are utilized on the
final screening of the non-metallic material and on the screen prior to
barrel-refining the metallic material.  Water sprays are used on the
blast furnace side prior to final screening.  Location of water spray
devices is shown as Figures 11 and 12.  To control dust on roadways a
13,000 liter (3,500 gal) water truck is operated virtually continuously.


INSPECTION OBSERVATIONS

     At the time of the July 1 inspection, all processes were in opera-
tion.  The water spray systems were adequately operating to prevent
fugitive dust emissions from the various crushing and screening opera-
                        v
tions.  Where roadways had been freshly watered, dust emissions were
adequately controlled.  Dumping of waste materials was being conducted
at the north end of the USSC property about 300 m (300 yards) south of
an NEIC air monitoring station (No. 3), and no fugitive dust was observed
from the dumping operation.  However, the roadway to the dump site had
not been watered, and fugitive dust was observed from movement of the
trucks.   Fugitive dust had been observed previously from this area, as
well as  from other Heckett roadways.

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                            X.  POWER PLANT
     USSC operates a power plant at the Geneva Works which produces
steam, electric power, and compressed air for use throughout the complex.
Five boilers supply steam to drive electric generation and compressing
equipment.  Electrical power is generated with a single General Electric
50,000 kW turbogenerator.  Additional electrical power is purchased from
the Utah Power and Light Company on an as-needed basis.  Four Ingersoll-
Rand turbo blowers, each rated at 2,700 m /min (95,000 acfm) up to 2.5
     o
kg/cm  (35 psig), provide compressed air for use primarily in the blast
furnaces.
PROCESS DESCRIPTION

Small Boiler Units

     There are two Babcock and Wilcox Sterling-type water tube boilers,
Units 2 and 3, each rated at 68,000 kg (150,000 Ib) steam/hr at a de-
livery pressure of 32 kg/cm (450 psi) and a temperature of 400 °C (750°F)
at the superheater outlet.  Each boiler has a heating surface of 1,170
m2 (12,536 ft2).

     These boilers can be fueled with mixed gas, blast furnace gas, or
coal.  The boilers have travelling grates and normally operate with a
bed depth of 11.5 to 12.7 cm (4.5 to 5 in) when operating on coal.   The
rated heat input  for each boiler is 52 x 106 kg-cal (206 x 106 Btu)/hr.

     Boilers 2 and 3 share a common exhaust stack.   This tapered stack
is 61 m (200 ft)  high and 3.3 m (11 ft)  in diameter at the top.   There

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                                                                         106
 are no stack gas opacity meters on  this  stack  or on  the  ductwork  leading
 from the boilers to the stack.

 Large Boiler Units

      Boilers 4,  5,  and  6 are  Babcock  and Wilcox  Sterling-type  water  tube
 units which are  each rated  at 136,000 kg (300,000 lb)/hr of  steam at a
 delivery pressure of 32 kg/cm (450  psi)  and  a  temperature of 400°C    '
 (750°F)  at the superheater  outlet.  These boilers each have  a  heating
 surface  of 2,070 m2 (22,270 ft2).

      These three boilers can  be fueled with  mixed gas, blast furnace
 gas,  or  pulverized  coal.  When  on the latter fuel, the coal  is  introduced
 into  the boilers through direct entry, front wall  burners  which are
 inclined at about 60° downward  into the  combustion zone.   Each  boiler
 has a rated heat input  of 100 kg-cal  (412  x  106  Btu)/hr.

      Each of the three  boilers  has  its own waste  gas stack.  The  tapered
 stacks,  which are identical,  are 3.3  m (11 ft) in diameter at the  outlet
 and 61 m (200 ft) high.   Each of the  boilers is  equipped with a Bailey
 Bolometer stack  gas  opacity detector  which is  located in  the breeching
 between  the boiler  and  the exhaust stack.
PARTICULATE EMISSION SOURCES AND CONTROL SYSTEM

     Each of the five boilers has the potential for emitting significant
quantities of particulate matter, especially when fueled with coal.
There are no emission control devices currently installed on these
stacks.

     USSC has reportedly contracted with Wheelabrator, Inc.  for the
design and installation of a single baghouse control  system to treat the
exhaust gases from boilers 4, 5, and 6.   USSC has proposed to operate

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                                                                        107
these boilers with pulverized coal exclusively once the baghouse is
installed.  Boilers 2 and 3 would be fueled on blast furnace gas or
mixed gas only after the baghouse is installed.  There would be no
control equipment installed on these two boilers.

     The new baghouse to be installed on the exhausts from boilers 4, 5
and 6 will be a Wheelabrator-Frye, Inc. Model  264, series 8RS, size
1618D Dustube Dust Collector.  The unit will have fiberglass cloth bags,
operate at 290°C (550°F), have an air-to-cloth ratio of 3.2:1  at a
design head loss of 12.7 to 17.8 cm (5 to 7 in) water, and be designed
for a particulate collection efficiency of 99.6%.

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                     XI.  MISCELLANEOUS OPERATIONS
     There are several operations at the Geneva Works which, due either
to their intermittent operation or size, constitute a relatively small
potential impact on the total particulate emissions from this complex.
These sources are discussed below.
FOUNDRY

     USSC operates a foundry which produces ingot molds and stools, slag
and hot metal ladles, and miscellaneous castings for use within the
complex.

     The majority of the castings made in the foundry are ingot molds
and stools used in the casting of steel ingots.  The foundry schedules
about 360 m. tons (400 tons)/day of hot metal from the blast furnaces
for the production of ingot molds.  The average life of an ingot mold is
reported to be 47 casts before cracks occur or some irregularity requires
that it be retired from service.  The retired mold is recycled as feed
scrap to the open hearth furnaces.  The foundry prepares green sand
cores and flasks for casting of ingot molds.  The cores are baked in
core baking ovens, each fueled by natural gas and each rated at 5 x 106
kg-cal  (20 x 106 Btu)/hr heat input.

     The majority of the castings done at the foundry use green molding
sands.   A typical green sand composition is 2.5% bentonite clay, 1.7%
gilsonite (a coal-like material), 2% C-grade coal, 1.3% fireclay, 27%
new sand, and 65.5% recycled sand.  Recycled sand is obtained by reclaim-
ing the green sand from the ingot mold flasks after casting.

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                                                                         109
     There  are  three National Hydrofliter wet scrubber systems on the
 sand reclaiming system  at  the foundry.  The smaller system has a design
 capacity  of 600 m /min  (21,000 acfm); the larger two units are rated at
 960 m3/min  (34,000 acfm).  USSC has no emission test data on these
 scrubbers.  They were reportedly designed to reduce the particulate
                                              o
 concentration in the exhuast gases to 0.11 g/m  (0.05 gr/scf) or better.

     The  foundry also prepares some molds and cores for steel castings
 such as slag ladles.  These molds are transported to the pouring floor
 of the open hearth building and cast at this location.

     There  is a small gas-fired reverberatory furnace located at the
 foundry building.  This furnace is used to melt aluminum and copper for
 specialty casts required at the facility.

     Table  17 lists a typical month's production at the foundry during
 1975.  It should be noted  that the majority (92%) of the tonnage cast at
 the foundry is  accounted for by ingot molds and stools used at the
 Geneva facility.

     During the  inspection, ingot mold casts were observed.  Some
 fugitive  particulate emissions were noted during the cast period, but
 these emissions were not considered significant when compared with other
 sources at  the  complex.  The sand reclaiming operations were not being
 conducted during the inspection period.   Mold shakeout and sand reclaim
 took place  during the night turn.
PIG CASTING MACHINE

     There is a Pittsburg Coal Washer Company  two-strand pig casting
machine at the Geneva Works.  It is east of the open hearth building,
just north of the foundry area.  This machine casts 18 kg (40 Ib) iron

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                                                          no
                  Table  17
TYPICAL MONTHLY PRODUCTION AT FOUNDRY -1975
             USSC -  GENEVA WORKS
Product
Ingot Molds
Ingot Stools
Ingot Molds for Torrance, Calif, plant
Miscellaneous Iron Castings
Miscellaneous Steel Castings
Miscellaneous Aluminum Castings
Miscellaneous Copper Castings
m. tons
5,000
1,380
71
161
290
-v-1
'bl
tons
5,510
1,522
78
177
318
1
1

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                                                                        Ill
pigs.  The pig machine is used whenever hot metal  is produced at the
blast furnaces in quantities in excess of that which can be used by the
open hearth furnaces.  The excess hot metal is cast into pigs which can
be stockpiled and later charged to the open hearths as solid iron.  The
pig machine has a maximum capacity of 18 m. tons (20 tons)/hr and has an
average production of 1,700 m. tons (1,900 tons)/month.

     The pig casting machine is a potential source of fugitive particu-
late emissions when the hot metal is transferred from the ladles to the
pig molds.  The strands are not enclosed in a building, so any particu-
late emitted is discharged directly to the atmosphere.  The pig casting
machine was not in operation at the time of the inspection.


CHEMICAL COKE PLANT

     A small portion of the coke produced at the Geneva Works is further
processed to produce a dried and homogeneously sized grade of coke which
is sold as chemical coke.  This material is sold to chemical companies
such as Stauffer Chemical.

     At the chemical coke plant, coke is crushed in a two-stage roll
crusher (Gunlach Model 70-DA) and screened to produce 1.9 x 0.5 cm  (3/4
x 3/16 in) particles.  This material is then dried in two gas-fired
Jefferey vibrating conveyors, 1.5 m (5 ft) wide and 12.2 m  (40 ft)  long.
The driers can be operated  in series or parallel.  The dried product is
transferred by conveyor belt to storage hoppers and ultimately shipped
by rail.

     The production capacity of the chemical coke plant is  127 m. tons
(140 tons)/day.

     The chemical coke plant was in operation during the inspection.
Considerable amounts of particulate matter were discharged  from the
dryer and crusher exhaust stacks.

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                       XII.   EMISSIONS  INVENTORY
     An emissions inventory for the USSC Geneva Works  has been developed
from:  a) production and operational data supplied by  the Corporation in
letters to the Environmental Protection Agency;1,2  b) data gathered by
EPA and contractor personnel during plant visits the weeks of August 16
and 23, 1976; c) EPA pubication AP-42, Compilation of  Air Pollutant
Emission Factors;3 and d) unpublished references including two tables of
emission factors — one compiled by EPA,1*,5  and the other by Midwest
Research Institute6 — and a fugitive dust study conducted by Midwest
Research Institute.7

     The emissions inventory for the Geneva Works was  compiled according
to the following stipulations:  only particulate emissions were inven-
toried; emissions were based on actual production data for the summer
(June, July, and August)1 of 1976;  and emissions were calculated on an
average daily rate (tons/day) for each month and for each source.

     The following sources were inventoried:

          Coke  plant                         Blast  furnaces
             coal handling                      material  loading
             charging                           material  dumping
             oven/door  leaks                     leaks
             pushing                            building  monitors
             quenching                          off-gas combustion
             combustion
             coke handling
          Open  hearth  furnaces               Boilers
             stack                               gas  combustion
             fugitive  (taps,  scrapcharge,        coal combustion
              hot metal  charge,  flushing,
              bottom repair,  leaks,  etc.)

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                                                                         113
           Sintering Plant                    Nitrogen plant
              stack                             prilling
              fugitive                          dryer and coolers
           Rolling Mills                      Fugitive Dust
              fugitive  (scarfing)               unpaved roads
              combustion                        paved roads
                                               open areas
                                               storage piles
     Table 18  is a summary of the NEIC-calculated participate emissions
 itemized by source.  A more detailed breakdown of emissions estimates
 and the calculations used to obtain them is contained in Addendum D.
 Table 19 is a  comparison of particulate emissions submitted by USSC to
 EPA in a letter dated July 8, 19761 and those calculated by the NEIC and
 summarized in  Table 18.  The calculations submitted with the USSC
 emissions data are contained in Addendum E.

     The main  difference between the NEIC and USSC total daily emissions
 estimate totals is due to the NEIC inclusion of fugitive (unpaved roads,
 paved roads, open areas and storage piles) sources in its inventory.
 However, the differences in emissions from the process sources (coke
 plant, blast furnaces, open hearth furnaces, sintering plant, rolling
 mills, boilers, and nitrogen plant) are also large.   With the exception
 of the coke plant where production rates are known to be nearly the same
 for both inventories, production rate differences may account for some
 of the differences between the two inventories.  Most production rates
 are not referenced in the USSC inventory.1  However, the more significant
 differences are probably due to other reasons and are discussed below on
 a source-by-source basis.

     For the coke plant emission estimates, the differences can be
attributed to the use by the NEIC of updated emission factors.•»  The
updated factors decrease the allowable reduction in  quench  emissions due
to baffles from 75% to 50% and include new factors for combustion and

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                                                    114
           Table 28

     SUMMARY OF EPA-NEIC
PARTICULATE EMISSIONS ESTIMATES
          SUMMER 1976
      USSC - GENEVA WORKS
Source
Coke Plant
Blast Furnaces
Open Hearth Furnaces
Sintering Plant
Rolling Mills
Boilers
Nitrogen Plant
Unpaved Roads
Paved Roads
Open Areas
Storage Piles

m. tons/day
5.90
6.29
3.88
2.22
0.54
0.38
0.63
2.10
0.41
1.70
10.42
Total 34.47
tons/day
6.50
6.93
4.27
2.45
0.60
0.42
0.69
2.31
0.45
1.87
11.48
37.97
% of Total
17.12
18.25
11.25
6.45
1.58
1.11
1.82
6.08
1.18
4.92
30.23
100

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                                                                       115
                               Table 19
             COMPARISON OF PARTICIPATE EMISSIONS ESTIMATES
                USSC AND EPA-NEIC EMISSIONS INVENTORIES
                          USSC - GENEVA WORKS
Source
Coke Plant
Blast Furnaces
Open Hearth Furnaces
Sintering Plant
Rolling Mills
Boilers
Nitrogen Plant
Unpaved Roads
Paved Roads
Open Areas
Storage Piles
Total
NEIC
m. tons/day
5.90
6.29
3.88
2.22
0.54
0.38
0.63
2.10
0.41
0.70
10.42
34.47
USSC
tons/day
6.50
6.93
4.27
2.45
0.60
0.42
0.69
2.31
0.45
1.87
11.48
37.97
m. tons/day
4.50
0.06
1.09
0.84
0.36
7.97
N.C.1"
N.C.
N.C.
N.C.
N.C.
14.82
tons/day
4.96
0.07
1.20
0.92
0.40
8.78
N.C.
N.C.
N.C.
N.C.
N.C.
16.33
t  N.C.  - not calculated

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                                                                        116
coke handling.  Also the 60% emission reduction factor for oven and door
rehabilitation, which appears in the USSC inventory,1 was not used in
the NEIC inventory.  During the NEIC August 1976 inspection of the coke
plant, visibility from one end of the batteries to the other was observed
to be significantly obscured by smoke from oven and door leaks.

     For the blast furnace emission estimate differences, the USSC
inventory included only off-gas combustion emissions, while the NEIC
inventory included material loading, material dumping, furnace leaks,
and building monitor emissions, in addition to off-gas combustion
emissions.

     The differences in the open hearth furnace and sintering plant
emissions estimates can be attributed to differences in the method of
calculation.  The USSC emissions from these sources were calculated from
in-stack monitoring data.1  The NEIC emissions from these sources were
calculated from updated emission factors.**   As a result of the inspec-
tion, the accuracy of the data derived from the in-stack monitoring
equipment has been questioned.  In addition, the NEIC emissions estimates
include the calculated effect of fugitive emissions from these two
facilities.

     The differences in the rolling mill emissions are small and can
probably be attributed to the fact that the NEIC inventory includes
scarfing emissions and the USSC inventory does not.

     The large difference between the NEIC and USSC inventories for the
boiler emissions can be attributed to the fuels' use factors that the
calculations are based on.  The NEIC boiler emission calculations are
based mainly on the summer use of natural gas to fire the boilers, while
the USSC boiler emission calculations are based on yearly data and
include winter data, during which coal is used to fire the boilers.

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                 ADDENDA
A    Addendum 1 to Study Plan for Air Quality
     Monitoring at USSC-Geneva Works
B    EPA June 8 and November 4, 1976 Letters to
     USSC-Geneva Works
C    Particulate Grain Loading Calculations
D    NEIC Emissions Inventory Calculations
E    USSC Emissions Inventory Calculations (1974)

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         ADDENDUM A

ADDENDUM 1 TO STUDY PLAN FOR
  AIR QUALITY MONITORING AT
      USSC-GENEVA WORKS

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                                                                       119
                       AIR QUALITY MONITORING
                       USSC-GENEVA WORKS, UTAH
 INTRODUCTION

     The  purpose of this addendum is to provide a more definitive
 description of the required activities, time scheduling, and study
 responsibilities for Phase II of the USSC Geneva Works Study.  Phase II
 will consist of three activities:  (1) updating the existing emissions
 inventory of all sources within the property boundaries of the USSC
 Geneva Works, (2) conducting emission characterization studies, and
 (3) evaluating the potential for and conducting emission source tests
 and remote sensing activities as required to fulfill .the objectives
 of the Study Plan.   Phase II will be initiated immediately and will
 extend beyond the completion of Phase I activities.   The scope of
 each activity of Phase II is described below.

 EMISSION INVENTORY

     This activity  will  be  comprised of three  inseparable tasks:
 (1) an  evaluation of the basis  of the existing  emissions  inventory
and updating of it  based on  newly acquired data,  (2) thorough process
inspections  to  observe process  operations  and  control  systems,  and

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                                                                      120
(3) an evaluation of the in-stack monitoring equipment and the data
derived from it.  The primary objective of Tasks (2)  and (3)  is to
aid in the accomplishment of Task (1).
     To initiate Task (1), EPA Region VIII will  send  USSC Geneva
Works a Section 114 letter asking for essential  information,  as
follows:
     (1) background information used to develop  the USSC
     Geneva Works emission inventory for 1974 particulate
     matter;
           t
     (2) all Company continuous monitoring data  for the
     open hearth and sintering stacks collected  during
     the study period;
     (3) all particulate matter ambient air quality data for
     all USSC Geneva Works sampling sites collected during
     the study period;
     (4) process block flow diagrams, control equipment design
     parameters, and daily operating records for process and
     control equipment.
The Company will be requested to periodically report  emissions and
air quality data collected during the study period to the EPA.

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     Process inspections [Task (2)] will  be conducted by the EPA-
NEIC during mid to late August.   The process inspections will  be
conducted in an orderly series.   Each inspection will be devoted
to a major process -unit.  USSC will be provided a schedule of
inspections and be requested to discuss the process and control
equipment information available at the time of each process
inspection.  A tentative listing of process units for the inspec-
tions is as follows:
         1) open hearth furnaces
         2) sintering and ore preparation operation
         3) blast furnaces
         4) coke plant
         5) coke by-products and benzol plant
         6) nitrogen plant
         7) rolling mills and boilers
         8) Heckett Engineering facility*
Following the completion of the individual  inspections, time will  be
allocated to discuss with the Company miscellaneous air pollution
sources and to clarify  outstanding issues.
 *The facility located on USSC property which crushes and grinds USSC
  Geneva Works slag into aggregate.

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                                                                       122
     Task (3) will  include an EPA-NEIC  evaluation of  the  in-stack
monitoring equipment following receipt  of pertinent information  and
completion of the process  inspections.   The  emission  monitoring
equipment will be evaluated for its  comparability with  the minimum
emission monitoring requirements of  40  CFR Part  51, Appendix  P,  and
accepted emission monitoring methods, as well  as for  operational
and maintenance procedures.  In addition, during the  process  inspec-
tions, the CPA-NEIC will  evaluate the suitability of  the  individual
process units to be emission tested.  Suitability will  be determined
as a function of sampling  port size  and location, flow  disturbance
locations ih the exhaust  gas streams, estimated  accuracy  of a test,
etc.

EMISSION CHARACTERIZATION
     The primary objective of this activity  is to enable  correlation
of particulate catch at the air quality monitoring  sites  with the
particulate matter emitted by the individual process  units at USSC
Geneva Works.  Individual  tasks will  include collection of particulate
samples at or near each individual process unit  and a quality assurance
audit of all particulate  matter air  quality  data collected in the
vicinity of USSC Geneva Works during the study period—EPA, State,

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                                                                      123
and Company.  The first task will be conducted in early September
for approximately three weeks.  The second task will  be conducted
as time permits during the study period.

     The particulate samples collected at or near each process
unit will be used to identify specific physical and/or chemical
characteristics of that particular emission.  An attempt will
be made to gather at least two samples at or near each process
unit during each unique phase of that unit's process  cycle.   A
list of the process units, process cycle  phases, and  the minimum
number of particulate samples to be taken will be completed  and
distributed following the completion of the process inspections
and prior to the initiation of this activity.   During this activity,
visible emission observations will be made during the period
particulate samples are obtained.
     Each EPA particulate air quality monitoring site will be
routinely audited.  As time permits during the study  period  a
quality assurance audit will be conducted for State and Company
monitoring and laboratory facilities.  A  quality assurance audit
will include an equipment calibration check, an evaluation of
the site location, and a check on laboratory procedures.

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                                                                       124
SOURCr TESTING AND REMOTE SENSING

     A decision on whether or not to source test  will  be  based on
the findings of the air quality monitoring network  and the  evaluation
of the in-stack monitoring equipment.   However, some  testing,  such
as at the open hearth furnace roof monitors and at  the sinter  plant
transfer points, may be conducted prior to the completions  of
Activities (1) and (2) [Emission Inventory and Emission Characteri-
zation].  Any other actual source testing will not  take place  until
after the process inspections.
     Remote sensing techniques, including aerial  photography and/
or plume tracking/opacity LIDAR, will  be employed during  the emission
characterization activity to identify source/receptor relationships.

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       ADDENDUM B
EPA JUNE 8 AND NOVEMBER 4,
    1976 LETTERS TO
    USSC-GENEVA WORKS

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               ENVIRONMENTAL PROTECTION  AGENCY               126
                                 RCGION VIII
                         SUITE 9OO. IOCO LINCOLN STREET
                           DENVER.COLORADO OO203

                                                          June 8,  1976
United States Steel  Corporation - Geneva Works
P. 0. Box 510
Provo, Utah   84601

ATTENTION:  Mr.  H.  A.  Huish, General Superintendent

       RE:  United  States  Steel Corporation - Geneva Works

Dear Mr. Huish:

Pursuant to the authority  contained  in  Section 114 of the Clean Air Act,
as amended, (42 U.S.C. 1857 et seq), we are formally requesting that the
following information on the Geneva  Works  be provided to this office.
The  information requested  is required  in the development of implementation
plans under Section 110 of the Clean Air Act and  for a determination or
attainment of ambient air standards.

The  data requested in items A  through  D below  should be submitted not later
than 30 days following receipt of this letter.   Procpss and monitoring data
requested in items E through G below should  be submitted for uie period
June 1 through October 1, 1976, by the 10th  of the month following the month
the  data was collected.

Please provide:

      A)   all background  information (emission and  production  data,
          calculations, assumptions, etc.) used to  develop  the
          estimated 1974  particulate emissions inventory  submitted
          by USSC  to  EPA  Region VIII.

      B)   the description (manufacturer, type, model  number),  and
           location  (number of diameters upstream and downstream
           from  flow disturbances) of the continuous emission moni-
           tors  on  the open  hearth scrubber and sintering  plant
           scrubber stacks.

      C)    the description (manufacturer, type, model number), and
           location on a map of all ambient air monitoring sites
           owned and/or operated  by USSC, Geneva Works.

      D)   control  equipment and  process data listed below:

           1)   block flow diagrams  for:

                a)    coke  by-products  plant

                b)    benzol plant

                c)    nitrogen  plant

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                                                               127
2)   electrostatic precipitators
     a)   manufacturer, type, model  number
     b)   manufacturer's guarantees, if any (i.e., percent
          efficiency at 10 microns, grains/scf,* Ibs/hr)
     c)   date of installation or last modification and a
          detailed description of the nature and extent of
          the modification
     d)   description  of cleaning and maintenance practices,
          including  frequency and method
      e)   design and actual  values  for  the following  variables:
          1)   current (secondary  - amps)
           2)   voltage (secondary  and primary)
           3)   rapping frequency (times/hr) and intensity (psig)
                                         2
           4)   collection plate area (ft )
           5)   number of stages
           6)   particulate  resistivity (ohm-centimeters)
           7)   conditioning agents added and amount  (Ibs/hr)
                                         C
           8)    effective migration velocity  (ft/sec)
           9)    gas  flow rate (scfm)
           10)   operating  temperature (°F)  and  pressure (psig)
            11)   inlet particulate  concentration and particle
                 size distribution  (Ibs/hr) or grains/scfm)
            12)   outlet particulate concentration and  particle
                 size distribution (Ibs/hr or grains/scfm)
            13)  pressure drop (inches of water)
         conditions  used for temperature and pressure.

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                                                                128
          14)  gas velocity (fps)
          15)  spark rate
     f)   quantity of fines removed or recycled per day
     g)   collection plate height, collection plate length,
          discharge electrode total length,  number of flow
          passages, width of flow passages,total  number of
          bus sections and number in series  with gas flow
     h)   flow distribution devices (location and type)
3)   scrubbers
     a)   manufacturer, type, model number
     b)   manufacturer's guarantees, if any  (i.e.,  percent
          efficiency at 10 microns, grains/scf,  Ibs/hr)
     c)   date of installation or last modification  and a
          detailed description of the nature and  extent of
          the modification
     d)   description of cleaning and maintenance practices,
          including frequency and method
     e)   scrubbing media (composition)
     f)   design  and actual  values for the following  variables:
          1)    scrubbing media flow rate  (gals/min)  vs.  gas
               flow rate (scfm)
          2)    pressure of scrubbing media (psig)
          3)    gas flow rate (scfm)
          4)    operating temperature (°F) and pressure  (psig)
          5)    inlet particulate  concentration and flow rate
               (Ibs/hr  or grains/scfm)
          6)    outlet particulate  concentration and flow rate
               (Ibs/hr  or grains/scfm)

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                                                               129
          7)    pressure  drop  (inches of water)
          8)    gas  velocity  (ft/sec)
          9)    pressure  drop  vs.  particle collection efficiency
     g)    dimensions  of  scrubber  (vertical, horizontal),
          location  of spray  nozzles, flow distribution devices,
          details of  scrubber internals
     h)    sketch or plan of  scrubber
     i)    type of pollutants  removed
     j)    mist eliminator (type,  superficial  gas velocity,
          location, spray rate and  operation)
4)   cyclones
     a)    manufacturer,  type, model  number
     b)    manufacturer's guarantees,  if  any  (i.e.,  percent
          efficiency  at  10 microns, grains/scf,  Ibs/hr)
     c)    date of installation or last modification and  a
          detailed  description of the  nature  and extent  of
          the modification
     d)    description of cleaning and  maintenance  practices,
          including frequency and method
     e)    number of cyclones and  physical  arrangement  (include
          a diagram,  if available)
     f)    dimensions of cyclone (diameter,  length)
     g)    inlet temperature, velocity (ft/min),  flow rate  (cfm)
     h)    quantity of material removed or recycled per day
     i)    approximate inlet particle type,  specific gravity,
          and  size distribution

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                                                                    130
E)   process data listed below reflecting daily averages:
     1)   coke plant
          a)   amount of coal  charge by battery (tons)
          b)   coking time - average for battery
          c)   number of charges and pushes  for each  battery
     2)   blast furnaces
          a)   amount of ore charged by furnace (tons)
          b)   amount of agglomerates charged  by furnace  (tons)
          c)   number of slag and hot metal  taps by furnace
          d)   furnace pressure recorder data  or estimate  of total
               elapsed time and time of day  by-pass valve  is open
               for each furnace
          e)   the frequency,  total  elapsed  time and  time  of day
               top gas dust removal  equipment  is by-passed, if
               applicable
     3)   open hearth furnaces
          a)   production rate by furnace (tons)
          b)   number of charges and taps by furnace
          c)   duration and amount of oxygen lancing  by
               furnace per heat
          d)   percent of hot metal  and of cold scrap charged,
               by furnace
          e)   frequency, total elapsed time and time of day control
               equipment is by-passed or non-operational
          f)   the number of  bottom repairs,  length  of down time
               and time of day repair takes  place by  furnace

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                                                                          131
          4)   sintering plant
               a)   production rate (tons)
               b)   frequency, total elapsed time and time of day control
                    equipment is by-passed or non-operational
               c)   average number of start-ups and time of start-up
               d)   approximate ratio of charged materials in sintering
                    operation
          5)   rolling mills
               a)   tonnage scarfed
               b)   frequency, total elapsed time and time of day control
                    equipment is by-passed or non-operational, if applicable
               c)   composition and amount of gas used to fire soaking pits
          6)   coke by-products and benzol plant
               a)   production rates (tons or set')
          7)   nitrogen plant
               a)   production rates (tons)
          8)   boilers
               a)   composition and amount of fuel used to fire boilers
     F)   the data from the continuous  emission monitors on the open
          hearth and sintering plant scrubber stacks, as well  as any
          emission test data conducted  at any process unit.
     G)   the particulate matter data from all  ambient air monitoring
          sites owned and/or operated by USSC,  Geneva Works.
Any questions relating to this request  should be brought to the attention of
Mr. Robert King (303/234-5306) or Mr. Jonathan  Dion (303/234-4658)  of  the
United States Environmental  Protection  Agency - National  Enforcement Investi-
gations Center, Denver, Colorado.
                                                  Sincerely,
                                                 John  A.  Green
                                                 Regional  Administrator
     cc:   Dr.  Philip X.  Masciantonio
          Director,  Environmental  Control
          U.S.  Steel  Corporation
          600  Grant  St.,  Pittsburgh,  PA  15230

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                ENVIRONMENTAL PROTECTION AGENCY                     132
                      OFFICE OF ENFORCEMENT
           NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
               BUILDING 53. BOX 25227, DENVER FEDERAL CENTER
                      DENVER, COLORADO  80225

                                               DAT*  November 4, 1976
Mr. H. A. Huish
General Superintendent
United States Steel  Corporation
Geneva Works
P. 0. Box 510
Provo, Utah  84601

Dear Mr. Huish:

As a result of the recent on-site  inspections  conducted by NEIC
personnel at the Geneva Works, we  are  in  need  of  additional infor-
mation to complete studies of the  air  pollution control equipment,
process operation, and emissions inventory.

The following information is  needed.

     A.  Blast Furnaces

         1)  How is material  transferred  from  coke  storage,
             ore storage, sinter storage  to  the skip  hoists?

         2)  What was the hot metal  production from the blast
             furnaces for June, July,  August and  September of
             1976 (tons/month)?

         3)  What is the design data (type manufacturer, model
             number, design and actual  flow  rates and efficiency)
             on cyclones, scrubbers, and  ESP's used as blast
             furnace gas cleaning  devices?

         4)  Please provide test  data  on  BF  gas composition and
             particulate content.

     B.  Sintering Plant

         1)  Please provide the  following information on the
             sinter plant cyclones:

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                                                                 133
        a)  manufacturer and model
        b)  height of cyclone (ft.)
        c)  diameter of cyclone (ft.)
        d)  expected variation in temperature  and  pressure
            of inlet gas (°F, psig)
        e)  diameter of gas  outlet from cyclone  (ft.).
    2)  Please provide the following informaiion on  the  sinter
        plant discharge end  (north end) scrubbers:
        a)  gas flow rate, temperature  pressure  and  fluctua-
            tions (scfm, °F, psig)
        b)  spray configuration and  location of  nozzles
        c)  scrubbing media  flow rate and  pressure (gallons/
            min., psig)
        d)  inlet particulate concentration and  particle size
            distribution (gr/scf)
        e)  outlet particulate concentration and particle size
            distribution (gr/scf)
        f)  gas velocity through scrubber  (ft./sec.)
        g)  sketch of scrubber.
    3)  Please provide the following information on  the  sinter
        plant windbox scrubbers:
        a)  spray nozzles; type, location  and  number
        b)  IDS of discharge from scrubbers (mg/1)
        c)  TsS of water spray into  scrubber (mg/1)
        d)  gas pressure at  inlet (psig).
C.  Coke Ovens
    1)  Please provide the height, base diameter and exit diameter
        of the coke battery  waste heat  stacks  (ft.).

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                                                                   134
     2)  What is the amount of gas burned in the coke ovens and
        the gas analysis (MCF/month, % by weight of H2, CH4, etc.,
        gr/ft3 of S and particulate)?

     3)  What is the amount of quench liquor used per quench and
        the chemical analysis of the quench liquor (i.e., IDS,
        TSS, phenol content, sulfate, sulfide, sulfite content--
        mg/D?

     4)  Briefly describe the chemical coke production process.
        Include a process diagram.

     5)  What is the average production rate of chemical coke
        (tons/day)?

D  Open Hearth Furnaces

   1)   Please provide the BTU input to a typical  open hearth.
        Include the range during the cycle (106 BTU/hr).

   2)   Please provide the following information on the open
        hearth ESP's:

        a)  pressure of gas at inlet (psig)

        b)  secondary  design current amps

        c)  particulate composition.

   3)   Please provide the following information on the open
        hearth scrubbers:

        a)  spray nozzle manufacturer and model  number, loca-
            tion and number

        b)  IDS of discharge (mg/1)

        c)  TSS of water spray into  scrubber (mg/1)

        d)  gas pressure at inlet (psig).

E.   Foundry and Pig Machine

    1)  What are the ratings  for the core baking ovens
        (106 BTU/hr input)?

    2)  Please  provide the  amount and type  of  fuel  used for
        the core baking ovens  and reverberatory  furnaces  for
        June, July,  August, and  September of 1976  (MCF/month
        or gallons/month).

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                                                                 135
    3)   Please provide  data  on  the  air  pollution controls
        for the sand  handling and reclaim systems at the
        foundry (manufacturer and model, design and actual
        scfm and efficiency).

    4)   What is the amount of hot metal and steel poured at
        the foundry for June, July,  August and September of
        1976 (tons/month).

    5)   What is the production  capability and average monthly
        production of the pig machine  (tons/hr, tons/month)?

F.  Rolling Mills

    1)   What are the  base diameters, exit diameters, heights
        (ft.), number and location  of  stacks serving the
        soaking pits?

    2)   What are the  ratings of the soaking pits  and reheat
        furnaces (10^ BTU/hr input)?

    3)   What is the  amount  and  type of fuel used  for the
        reheat furnaces and  soaking pits  at all rolling mill
        operations for June, July,  August and September of
        1976 (MCF/month, gallons/month)?

6.  Coke By-Products  and Nitrogen  Plant

    1)   Where is the  "surplus  gas  flow" shown near  the  primary
        coolers on Figure 4-1  "By  Product Gas System"  (provided
        by USSC to EPA) sent?
    2)  Where does centrate from (NH/^SC^ at the by-products
        plant centrifuging operation go?

    3)  Please provide the following information on the four
        cyclonic scrubbers serving the prill  dryers:

        a)  manufacturer, type, model

        b)  height of the cyclones (ft.)

        c)  diameter of the cyclones (ft.)

        d)  gas flow rates, temperatures, pressures, and
            fluctuations (SCFM, °F, psig)

        e)  spray configurations and locations

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                                                                 136
        f)  scrubbing media flow rates and pressures
            (gall on/min, psig)
        g)  diameter of gas outlets from cyclones (ft.).
    4)  Please provide the following information on the baghouse
        serving the prill screening and talc prill  blending
        operations:
        a)  manufacturer, type, model
        b)  filter material and weave
        c)  air to cloth ratio
        d)  pressure drop (in, of water)
        e)  collection efficiency
        f)  stack test data
H.  Boilers
    1)  What is the heat input for all three boilers (106/BTU/hr)?
    2)  What are the base diameters, exit diameters, and heights
        for the boiler stacks (ft.)?
    3)  What is the percent ash of the coal  used to fire the
        boilers?
    4)  Please provide the following information on the baghouses
        that will be used to control boiler emissions:
        a)  manufacturer, type, model
        b)  filter material and weave
        c)  maximum service temperature of filter material  (°F)
        d)  air to cloth ratio
        e)  pressure drop (in. of water)
        f)  collection efficiency.

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                                                                       137
     I.  General
         1)  What is the porosity of the ceramic alumdum  thimbles
             used in the participate monitoring  equipment?

         2)  What is mixed gas?

         3)  Where are blast furnace, natural, mixed  and  coke  oven
             gas used and what are their average monthly  usage
             figures (MCF/month)?

We would appreciate it if you would submit  the information  requested
above no later than 30 days following the receipt of  this letter.

Any questions concerning this request should be  brought to  the atten-
tion of Mr. David Brooman, Mr.  Robert Gosik or Mr. Jonathan  Dion
(303/234-4658) of the U.  S. Environmental Protection  Agency, National
Enforcement Investigations Center, Denver,  Colorado.

Thank you for your cooperation.

                                         Sincerely,
                                         Thomas P. Gallagher
                                         Director

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       ADDENDUM C

PARTICULATE GRAIN LOADING
      CALCULATIONS

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                                                                        139
                              ADDENDUM C

      APPROXIMATION OF PARTICULATE LOADING DUE TO MIST CARRYOVER
               SINTERING PLANT AND OPEN HEARTH SCRUBBERS
                          USSC - GENEVA WORKS
SINTERING PLANT (one scrubber)

     1.   Assumptions

          a.  Scrubber liquid droplets <500um diam.  will  be entrained in gas
              stream.

          b.  Aproximately 10% of scrubbers liquid is atomized to <500ym diam.
              droplets under typical  scrubber operating conditions.
          c.  Mist eliminator efficiency is 50%.

          d.  There are 2,900 ppm TDS and TSS in  scrubber liquid.

     2.   Calculation

          700 gal/8.34 1b/10 Ib of <500um/    5 Ibs  lost    /2.900 Ib  solids/
           min   / gal   /100 Ib sprayed / 10 Ibs of <500ym/   100falb lost  /

          7.000 gr/      1       /  *  n no   /  c
            Ib    /180.000 scfm /  =  °'03 9r/scf

OPEN HEARTH (one scrubber)

     1.   Assumptions

          a.  Scrubber liquid droplets of <250ym  diam.  will  be entrained
              in gas  stream

          b.  Approximately 5% of scrubber liquid is  atomized  to  <250um.
              diam. under typical  scrubber operating  conditions.
          c.  Spray capture of carryover droplets is  60%,  net.
          d.  There are 2,500 ppm TDS and TSS  in  scrubber  liquid.

     2.   Calculation

          650  gal/8.34 1b/5 Ib of <250um/   4  Ibs  lost   /2,500 Ib solids/
            min  /  gal    /100 Ib  sprayed/10  Ibs of <250ym/   10b Ibs lost /

          7.000  qr/	1      /    •».«„,,
            Ib   /67,000 scfm/    =   °'03 9r/scf

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       ADDENDUM D

NEIC EMISSIONS INVENTORY
      CALCULATIONS

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                          NEIC EMISSION INVENTORY
                        (JUNE, JULY,  AUGUST,  1976)
                                                                          141
                                 Coke Plant
Coal charged (TONS)
Battery
1
2
3
4
Totals
(Tons/Month)
Average (Tons/Day)
Emissions:
Coal handling
.
June,
40,595
40,450
40,291
40,172
161,508
5,384



July,
41 ,679
41,531
41,321
41 ,340
165,871
5,351


     factor:  0.43 Ib/ton of coal  charged
June (5384 tons/day)    0.4 Ib/ton)  = 2153 Ibs/day =
July (5351 (0.4) =                    2140 Ibs/day =
August (5414) (0.4) =                 2166 Ibs/day =
                                      AVERAGE
     Charging
     factor:  (1.53 Ib/ton of coal  charged)  (0.41) =
June (5384 tons/day)    (0.6 Ib/ton) = 3230  Ibs/day =
July (5351) (0.6) =                    3210  Ibs/day =
August (5414 (0.6) =                   3248  Ibs/day =
                                       AVERAGE
                                                                August'
                                                                41,959
                                                                41,906
                                                                41,961
                                                                42.020
                                                               167,846

                                                                 5,414
         1.08 tons/day
         1.07 tons/day
         1.08 tons/day
         1.08 tons/day

0.6 Ib/ton
:         1.6 tons/day
1         1.6 tons/day
:         1.6 tons/day
!         1.6 tons/day

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                                                                           142
     Oven/Door Leaks
     factor:  0.13 ib/ton of coal  charged
June (5384 ton/day)    0.1 Ib/ton  = 538 Ibs/day =
July (5351) (0.1)                 = 535 Ibs/day =
August (5414) (0.1)               = 541 Ibs/day =
                                    AVERAGE

     Pushing
     factor:  0.78^ Ib/ton of coal charged
June (5384)tons/day    (0.78 Ib/ton) = 4200 Ibs/day =
July (5351) (0.78)                   = 4173 Ibs/day =
August (5414) (0.78)                 = 4223 Ibs/day =
                                       AVERAGE

     Quenching
     factor:  0.45^ Ib/ton of coal charged
June (5384 ton/day)    (0.45 Ib/ton) = 2423 Ibs/day  =
                                     = 2402 Ibs/day  =
                                     = 2436 Ibs/day  =
                                       AVERAGE
                                                          0.27 ton/day
                                                          0.27 tons/day
                                                          0.27 tons/day
                                                          0.27 tons/day
                                                          2.1ptons/day
                                                          2.08 tons/day
                                                          2.lQtons/day
                                                          2.09 tons/day
July (5351 (0.45)
August (5414) (0.45
   1.21  tons/day
1.20 tons/day
1.22 tons/day
1.21 tons/day
     Combustion
     factor:  0.0694 Ib/ton of coal  charged
June (5384 tons/day (0.069 Ib/ton)  = 371  Ibs/day
July (5351 (0.69)                   = 369  Ibs/day
August (5414) (0.069)               = 374  Ibs/day
                                      AVERAGE
                                                       0.19 tons/day
                                                       0.18 tons/day
                                                       0.19 tons/day
                                                       0.19 tons/day

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                                                                          143
     Coke Handling
     factor:  0.0234 Ib/ton of coal  charged
June (5384 tons/day) (0.023 Ibs/ton)  =  124  Ibs/day
July (5351) (0.023)   -                =  123  Ibs/day
August (5414)  (0.023)                =  124  Ibs/day
                                       AVERAGE
  0.06 tons/day
  0.06 tons/day
  0.06 tons/day
  0.06 tons/day
Coke Plant Total:
          Coal Handling
          Charging
          Oven/Door Leaks
          Pushing
          Quenching
          Combustion
          Coke Handling
  TOTAL
1.08
1.60
0.27
2.09
1.21
0.19
0.06
6.50 tons/day

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                                                                          144
                               Blast Furnaces
Production                     (tons/month)             (average tons/day)
June                             126,178                       4,206
July                             130,820                       4,220
August                           125,342                       4,043
Emissions:

     Material Loading
     Factor:  0.37^ Ib/ton of hot metal produced
June (4,206 tons/day (0.37 Ibs/ton = 1556 Ibs/day = 0.78 tons/day
July (4,220) (0.37                 = 1561 Ibs/day = 0.78 tons/day
August (4,043) (0.37)              = 1496 Ibs/day = 0.75 tons/day
                                     AVERAGE      = 0.77 tons/day

     Material Dumping
     Factor:  0.734 Ib/ton of hot metal produced
June (4,206 ton/day (0.73 Ib/ton = 3,070 Ibs/day  = 1.54 tons/day
July (4,220 (0.73)               = 3,081 Ibs/day  = 1.54 tons/day
August (4,043) (0.73)            = 2,951 Ibs/day  = 1.48 tons/day
                                   AVERAGE        =1.52 tons/day

     Leaks
     Factor:  1.1^ Ib/ton of hot metal  produced
June (4,206 ton/day (1.1  Ib/ton = 4,627 Ibs/day = 2.31  tons/day
July (4,220) (1.1)              = 4,642 Ibs/day = 2.32  tons/day
August (4,043) (1.1)            = 4,447 Ibs/day = 2.22  tons/day
                                  AVERAGE       =2.28  tons/day

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     Building Monitor
     Factor:  1.1^ Ib/ton of hot metal produced
June (4,206 ton/day) (1.1 Ib/ton = 4,627 Ibs/day = 2.31  tons/day
July (4,220) (1.1)               = 4,642 Ibs/day = 2.32  tons/day
August (4,043) (1.1)             = 4,447 Ibs/day = 2.22  tons/day
                                   AVERAGE       =2.28  tons/day
     Off Gas Combustion
     Factor:  0.38^ Ib/ton of hot metal  produced
June (4,206 tons/day) (0.038 Ib/ton = 160 Ibs/day = 0.08 tons/day
July (4,220) (0.038)                = 160 Ibs/day = 0.08 ton/day
August (4,043) (0.038)               = 154 Ibs/day = 0.08 ton/day
                                      AVERAGE     = 0.08 ton/day
Blast Furnace Total:
          Material Loading                          0.77
          Material Dumping                          1.52
          Leaks                                     2.28
          Buildup Monitor                           2.28
          Off  Gas Combustion                       0.08
TOTAL                                               6.93 tons/day

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                                               146
Open Hearth Furnaces
Production (Tons/Month)
Furnace
90
91
92
93
94
95
96
97
98
99
TOTALS (Tons/Month)
Average Tons/Day
Emissions
Stack
June
678
9,674
24,188
15,768
19,106
11,495
27,575
28,274
26,485
12,284
175,527
5,851


Factor: 0.734 Ib/ton of steel
June (5851 ton/day (0
July (5682 (0.73
August (4565 (0.73)
.73 Ib/ton) =
~
=
July
28,350
20,037
19,933
24,143
23,974
18,005
12,662
22,104
—
6,946
176,154
5,682


produced
4271 Ibs/day = 2.
4147 Ibs/day = 2.
3332 Ibs/day = 1.
August
25,161
18,741
--
26,510
17,236
10,643
—
16,762
—
26,452
141 ,505
4,565



1 tons/day
07 tons/day
67 tons/day
       AVERAGE
=1.95 tons/day

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                                                                          147
     Fugi ti ve
     Factor:  0.87  Ib/ton of steel  produced
June (585/ton/day) (0.87 Ib/ton) = 5090 Ibs/day = 2.5 tons/day
July (5682 (0.87)    '            = 4943 Ibs/day = 2.47 tons/day
August (4565) (0.87)             = 3972 Ibs/day = 1.99 tons/day
                                   AVERAGE      =2.32 tons/day

Open Hearth Furnaces Total:
          Stack                                   1.95
          Fugi ti ve                                2.32
TOTAL                                             4.27 tons/day

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                                                                          148
                            Sintering  Plant
     Production (tons/month)
     June                           July                       August
    52,245                         45,693                      47,442
                (tons/day)
     1,742                          1,474                        1,530
Emissions
     Stack
     Factor:  l.O3 Ib/ton of sinter produced
June (1,742 ton/day)  (1.0 Ib/ton)  = 1,742  Ibs/day  =  0.87  ton/day
July (1,474)(1.0)                 = 1,474  Ibs/day  =  0.74  ton/day
August (1,530) (1.0)               = 1,530  Ibs/day  =  0.76  ton/day
                                    AVERAGE        =  0.79  ton/day
     Fugitive
     Factor:  2.I3 Ib/ton of sinter produced
June (1,742 ton/day (2.1  Ib/ton)  = 3,658  Ibs/day = 1.83 tons/day
July (1,474) (2.1)               = 3,095  Ibs/day = 1.55 tons/day
August (1,530) (2.1)              = 3,213  Ibs/day = 1.61 tons/day
                                   AVERAGE      =1.66 tons/day

Sintering Plant Total:
         Stack                                     0.79
         Fugitive                                  1.66
TOTAL                                              2.45 tons/day

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                                                                           149
                                 Rolling Mills
     Production
June
July
August
                                 (tons/month)
                                    126,486
                                    127,479
                                    112,567
     Combustion (mixed gas I? 500 BTU/ft3)
                     (MCF/month)           (Gal/month)
June                  1,297,986              26,079
July                  1,198,123              78,347
August                1,121,774             113,520
     Natural Gas Equivalents
                                 (MCF/month)
June                                648,993
July                                599,062
August                              560,872
     Emissions
     Scarfing Factor:  0.25 Ib/ton  of metal scarfed
June (4,216 ton/day (0.2 Ib/ton) =  843 Ibs/day = 0.42 ton/day
July (4,112) (0.2)                =  822 Ibs/day = 0.41 ton/day
August (3,631) (0.2)             =  726 Ibs/day = 0.36 ton/day
                                   AVERAGE     =0.40 ton/day
(average tons/day)
       4,216
       4,112
       3,631

      (Gal/day)
         869
       2,527
       3,662

   (MCF/day)
      21,633
      19,325
      18,093

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                                                                           150
     Gas Factor:  183 lb/106 ft3 of gas burned
June (21.63 x 106 ft3/gas) (18 lb/106 ft3 of gas  =  389  Ibs/day =  0.19  ton/day
July (19.32 x 106) (18 lb/106)                   =  348  Ibs/day =  0.17  ton/day
August (18.09 x 106) (18 lb/106)                 =  326  Ibs/day =  0.16  ton/day
                                                   AVERAGE     =0.17  ton/day
     Fuel Factor:  233 lb/103 gallons of fuel = 20  Ibs/day
June (0.869 x 103 gal/fuel) (23 lb/103 gal fuel = 20 Ibs/day = 0.01  ton/day
July (2.527 x 103) (23 lb/103)                  = 58 Ibs/day = 0.03  ton/day
August (3.662 x 103) (23 lb/103)                = 84 Ibs/day = 0.04  ton/day
                                                  AVERAGE    =0.03  ton/day

Rolling Mill Total:
          Scarfing                                0.40
          Gas Combustion                          0.17
          Oil Combustion                          0.03
TOTAL                                             0.60  tons/day

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                                                                     151
                             Boilers
Fuel  consumption  per month  (CF  for  gas,  tons  for coal)
NG
MG
BF
Coal
            June
         180,242,000
         894,344,000
       3,911,369,000
                                       July
                                     122,282,000
                                     809,570,000
                                   4,530,655,000
                                             206
(NG = natural  gas,  MG  =  mixed  gas @  500 BTU/Ft3, BF =
 100 FTU/Ft3)
                                                         August
                                                          65,587,000
                                                         884,928,000
                                                       4,206,414,000

                                                blast  furnace gas @
     Natural  Gas  Equivalents
            June
NG       180,242,000
MG       447,172,000
BF       391.137.000
Total  1,018,551,000
(Ft /month)
Avg.
(FtVday)
          33,951,700
                                       July
                                      122,282,000
                                      404,785,000
                                      453,065.500
                                      980,132,500

                                       31,617,177
                                                        August
                                                          65,587,000
                                                         442,464,000
                                                         420.641 .400
                                                         928,692,400

                                                          29,957,819
     Emissions
     Factor:  183 lb/106 ft3 gas  burned
June (33.95 x 106 ft3)  (18 lb/106 ft3) =  611  Ibs/day
July (31.62 x 106 )  (18)              =569  Ibs/day
August (29.96 x 106)  (18)              =  539  Ibs/day
                                         AVERAGE
                                                  0.30  ton/day
                                                  0.28  ton/day
                                                  0.27  ton/day
                                                  0.28  ton/day

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                                                                           152
                  o    2
     Factor:  (16)° (8)  Ib/ton coal  burned
                    128  Ib/ton coal  burned
July (128 Ib/ton (6.65 tons/day) = 0.42 ton/day
     Three month average         =0.14 ton/day

Boiler Total:
          Gas                       0.28
          Coal                     0.14
TOTAL                              0.42 ton/day

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                                                                           153
                               Nitrogen Plant
     Production tons/month
     June                             July                     August
    9,395                            7,355                     11,181
                tons/day
      313                              237                        361
Emissions
     Prilling
     Factor:  0.93 Ib/ton of product
June (313 ton/day) (0.9 Ib/ton) = 282 Ibs/day = 0.14 ton/day
July (237 (0.9)                 = 213 Ibs/day = 0.11 ton/day
August (361) (0.9)              = 324 Ibs/day = 0.16 ton/day
                                  AVERAGE     =0.14 ton/day
     Dryers and Coolers
     Factor:  3.63 Ib/ton of product
June (313 ton/day) (3.6 Ib/ton) = 1127 Ibs/day = 0.56 ton/day
July (237) (3.6)                = 8532 Ibs/day = 0.43 ton/day
August (361) (3.6)              = 1300 Ibs/day = 0.65 ton/day
                                  AVERAGE      =0.55 ton/day

Nitrogen Plant Total:
          Prilling                               0.14
          Dryers and Coolers                     0.55
TOTAL                                            0.69 ton/day

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                             EXPERIMENTALLY DETERMINED FUGITIVE DUST EMISSION  FACTORS6'7
Source category

Aggregate storage
  (sand and gravel;
  crushed stone)

Unpaved roads
Paved roads
Wind erosion
    Measure of extent

Tons of aggregate put
   through storage cycle
Vehicle-miles traveled
   (light duty)
Vehicle-miles traveled
  (light duty)
Acre-years of exposed
  land
Emission factor—
  (Ib/unit of
 source extent)

     0.33
    (PE/100)2
°'49 (Su>   o  is
  9 x 10"5 L
                                                  18
        esf
                                                     (PE/50)2
                                                                     u
                              Correction parameters
PE  » Thornthwaites Precipitation
        Evaporation Index
      road surface silt content
S   = average vehicle speed (mph)
d   = dry days per year

L   = surface loading (Ib/mile)
Sp  = fractional silt content of
        road surface material
                      e   = soil  erodibility (tons/acre-yr)
                      s   « silt  content of  surface soil (%)
                      f   •= fraction of time wind exceeds
                              12  mph
                      PE  = Thornthwaites Precipitation-
                              Evaporation Index
a./  Annual average emissions  of  dust particles smaller than 30 micrometers in diameter based on particle  -J
      density of 2.5 g/cm3.                                                                               2

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ROAD EMISSIONS'


Source Extent
Correction Factors Emissions*
Road Length Vehicle Miles Vehicle Class Vehicle Weight Vehicle Speed Road Surface Surface Emission Dally
Roads Traveled Correction Silt Content Loading Factor Emissions
Miles8 Kilc8/Dayb Light Duty A Based on mphb Z or fraction Lbs. Material Lba/VMT Tons/Day
Medium Duty B Observation per Mile
Heavy Duty C
Unpaved
Slag Hauling
Hot Strip
Slag Plane
Coke Pile
Total
Paved
Coal Storage
Coke Plant
Other Paved
Total

1.3
0.9
3.0
0.3
5. 5

0.7
0.8
12.8
14.3

'JO
72
238
28
478

56
120
1.030
1,206
a Determined from plant icap.
b Data obtained from plant personnel.
c Determined by means of dry sieving.
d Assumed value based on observation.
•
C 8.0 25 7C — 4.3e 0.19
A&B 1.3 25 10d — 4.0 0.14
C . 8.0 10 13C — 12.8 1.84
C 8.0 25 4C -- 9.8 0.14
2.31

A&B 1.3 • 25 0.10d >15,000d 4.0f 0.11
B 3.5 25 O.l0d > 15.000d 5.4* 0.32
A&B 1.3 25 0.07d 5.000d 0.04 0.02
0.45
e Factor has been reduced by 757. to account for road surface oiling.
£ Calculated as an unpavcd road due to its high surface loading.
g Same as f , but reduced by 50%.
* All emissions are based on participates leas than 30 microns in diameter.

Yearly
Emissions
Tons /Year

69.4
51. 1
671.6
51.1
843.2

40.2
116.8
7.3
164.3
CJI
Ul

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                                                    OPEN AREA EMISSIONS'
                        Source extent
 Wind erosion

Plant A Open
  Areas
Total
plant
area
acres

1,502
Total
open
area
acres

 376
                                                          Correction  factors
                                                           E-nissions
                                  Effective
                                  open area
                                  fraction
   Soil
credibility
Surface silt
soil content
    (7.)
                                                                20£/
PE
                             0.19^
  Emission
   factor
Ib/acre year

   3,631
 Daily
emissions
tons/day

  1.87
sj  Effective open area fraction:  That area which is unsheltered by nearby buildings (effective open area « total ope
      0.5).
b_/  Tons of naterial eroded/acre-year.
£/  Assumed value based on known nearby agricultural land silt content.
d/  Fraction of the tine the wind speed is greater than 12 mph.
e_/  Thornthwaites Precipatation-Evaporation Index.
                                                                                                                   en
                                                                                                                   CTI

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                                                   STORAGE PILE EMISSIONS7



Material
in
Storage
Medium
volatil-
ity coal

High
volatil-
ity coal
Iron ore
pellets
Lump
iron ore
Coke

Slag
Total


Source
Amount
in
Storage
(tons)."/
42,500



127,000


125,000

242,333

185,000^

129,000
851,333


extent
Annual
thruput
(million
tons)^/
0.5



1.5


1.5

2.9

1.0

1.5
8.9





Emission
factors'*
Correction factors

Silt
content
tt)
6£/


.
IS.'


13£/

9£/

!«/

1.3S/


Duration
of
storage
(days)li/
30



30


30

30

Surge
basis'
30



Load in
(Ib/ton
stored)
0.16



0.05


0.35

0.24

0.03

0.04


Vehicular
traffic
(Ib/ton
stored)
tl



il


0.43

J/

0.16

&/


Wind
erosion
(Ib/ton
stored)
0.72



0.24


0.31

1.09

0.12

0.18


Load
out
(Ib/ton
stored)
0.79



0.26


f/

f/

0.16

0.25



Total
storage
cycle
(Ib/ton
stored)
1.67



0.55


1.09

1.33

0.47

0.47





Emissions
(tons/day) (tons/yr)
1.15 420


1.14 415



2.25 820

5-30 1,935

0.64 235

1 365

11.48 4.1Qn
£/  Calculated as 1/12 the annual thruput.
j>/  Data obtained through plant personnel.
_£/  Determined by means of dry sieving.

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       ADDENDUM E

USSC EMISSIONS INVENTORY
   CALCULATIONS (1974)

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                            ADDENDUM E
                   USSC  EMISSIONS INVENTORY                             159
                      CALCULATIONS (1974)


    Emission  Inventory fcr Year of \-7l

    Coke Plant - EPA Emission Factors
                                  v
      .Discharging -

       .6#/T coal charged
       .6# x 1.939JOOO tons coal charged
      "= ^62 tons part,  per year

      Unloading

      •Wr coal charged
      •kf x 1,939,000 tons  coal
      * 3JJ8 tons part, per year

      Charging

      1.5#/T coal charged
      1.5# X 1,939,000 tons coal
      - l.JS'i tons part,  per year
     \i*y* x .1.0* = 582 tons part, per year
     * At 60* reduction  due to using stage  charging.

     Coke Cycle

     .1#/T coal  charged
     .1//JC 1,939,000 tons  coal
     B 97  tons part . per year
     97 x  .kO* = 3J? tons part,  per year
    Quenching
          coal charged
    •9# x 1,939,000 tons coal
    " 873 tons part, per year
    873 x .25* = 218 tons part.

                       e°iSS10ns  froni no co"trols  due  to installation  of
 Open Hearth

 Average volume = 1*50,000 SCFM
 Average GR/CF = .026

 1.50,000 ^CF x .026 GR/CF   1,1,1,0 Min.    365" D/Y    2 000#
        Mm   7,000 CR/# x       DaF                '   ? =  ^3J tons part, per year
ginter Plant^

   Wind Box both
   Average volume  =  35^,000 SCFM
   Average GR/CF = .03  GR/CF

-------
                                                                           160
     351* ,000 SCF    .03 CR/CF   Y 6027 Oner. Hrs. y 60 Min y    ]
             Min.   7,000 GR/#           Yr .          Hr.   g.OOC/^/T

     g7j« tons part .  per year .

     North End Discharge

     Average  volume  = 80,000 SCFM
     Average  CR/CF  = .03 GR/CF

     80,000 SCFY -03 GR/CF  y 6027 Oner. Hrs. x 60 Min. x   1
           Min  7,000 GR/j?          Yr.          Hr.    2,000 #/Yr

     62  tons  part . per 'year.

     Total Sinter Plant
                Wind Box
           _62  Discharge End

           336  Tons/Year Total
           • -•-      '

 Blast Furnace Steves
 Rated capacity iM M ETU/Hr/Stove
 Based on EPA emission factor for natural gas 15# part./MCF


.1M*'0001X  1^557000 CF. KG  =  2.1# Part./Hr ./Stove
 2.1#/HR x 2U Hrs. x 3 fees, x 365 D/YR = 27.6#/Yr for all 3 fees.

 1971* - One furnace down 2 months for a total of 31* fee. months out of a
        possible  of 36 months.

 27.6///YR x 2± =  26.1 tons part, per year.


 Power House

 Fuels

    Coal -  57, 89^  tons
    B.P.  gas -  75,000,000 MCF @ 100 BTU/CF
    Natural Gas -  1,800,000 MCF @ 1,000 BTU/CF
    Mixed Gas  - 3,200,000 KCF @ 570 BTU/CF

    Coal  -  EPA  emission  factor 1.6#/ton coal burned
    57,891*  NJ_Coal     16#/T x 6.7^ Ash x _^_ *A =  3,103 tons part, per year
            *r.                           2,000       •  -

    Gaseous  Fuels @  1,000 BTU

    Based on EPA emission factor for natural gas -  18# per MCF.

-------
B.F. Gas   =
Nat .Gas   =
Mixed Gas  =
                     7,500 MMCF
                     1 ,800 me?
                     1.82^ MMCF
Total         11, 12^ MMCF

11,121. MMCF x 181/HCF x -
                                               Tons part, per year
Rolling Mill

Coke Oven Gas - 6,500,000 MCF @  570 BTU
Kat. Gas      - 3,700,000 MCF @ 1,000 BTU
Fuel Oil      - 7>000 Gals.

   Gaseous Fuels

   Ba,sed on natural gas @ 1,000 BTU and EPA emission factor of l8#/MMCF

   7,li05 MMCF X 18# MMCF = 66.6 tons.

   Fuel Oil

   EPA emission factor 23#/M Gals.

   7,000 M gals. X 23#/M gals. = 80.5 tons.

      Total      66.6
                 80.5
                lt>7.1 Tons Part. Per Year

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                                                                        162
                              REFERENCES
1.   USSC letters of July 8,  July 19,  August  20,  and  September  17,
     1976 to John Green, Regional  Administrator,  EPA, Region  VIII.

2.   USSC letter ofDecember  13,  1976  to Thomas Gallagher,  Director,
     National Enforcement Investigations Center,  EPA.

3.   Compilation of Air Pollutant Emission Factors, U.S.  Environmental
     Protection Agency, OAWM, OAWPS, 2nd Ed.,  AP-42,  March  1976,
     pp. 6.8-2, 7.2-2, 7.5-4  and  7.5-5.

4.   Emission factors compiled by ESED,  OAQPS, U.S. Environmental
     Protection Agency, Research  Triangle Park, N.C.  (unpublished
     tables with references).

5.   Personnel  communication  with  Reid Iverson, on October  15,  1976,
     OAQPS, U.S. Environmental  Protection Agency.

6.   Emission Factors compiled by Midwest Research Institute, Kansas
     City, Mo.  (unpublished tables with  references).

7.   Midwest Research Institute letter with fugitive  emission tabula-
     tions of November 5, 1976 to Jonathan Dion,  National Enforcement
     Investigations Center, EPA.
                             BIBLIOGRAPHY

     Abbott,  J.  H.  and  Drehmel,  D.C.,  Dec.  1976.  Control of Fine
     Particulate Emissions,  Chemical Engineering Progress.

     Drehmel, D.C.  June 27-July  1,  1976.  Primary Fine Particle Control
     Technology, Paper  presented at the 69th Annual Meeting of the Air
     Pollution Control  Association, Portland, Ore.

     The Mcllvain Co.,  1976.  The Electrostatic Precipitator Manual -
     Vol.  2,  Northbrook,  111.

     Oglesby, S., Jr.,  and Nichols, G. B. Sept. 1970.  A Manual of
     Precipitator Technology, Part  II: Application Areas, Document
     A3  196351,  National  Technical  Information Service, Springfield, Va.

     Schueneman, J.  J.,  High, M.D.  and Bye, W.E., June 1965.  Air
     Pollution Aspects  of the Iron  and Steel Industry, U.S. DHEW,
     Cincinnati, Ohio.

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