COKE PLANT SURVEY
CF & I STEEL CORPORATION
PUEBLO/ COLORADO
MAY 1977
ENVIRONMENTAL PROTECTION AGENCY
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver
REGION VIII
Denver
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
BUILDING 53, BOX 25227, DENVER FEDERAL CENTER
DENVER, COLORADO 80225
10 Director, Enforcement Division DATE May 12, 1977
EPA, Region VIII
FROM Assistant Director, Technical Programs
SUBJECT Coke Plant Survey - CF&I Steel, Pueblo, Colorado
Enclosed is a copy of a report entitled "Coke Plant Survey, CF&I Steel
Corporation, Pueblo, Colorado." If you have any questions regarding
this report, please contact Mr. Jonathan Dion or'Mr. Gary Young at
234-4706.
Robert D. Harp fl
cc: Gary E. Parish, Reg. VIII, w/c
Norman A. Huey, Reg. VIII, w/c
Director, NEIC
G. Young, NEIC
J. Dion, NEIC
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COKE PLANT SURVEY
CF&I STEEL CORPORATION
Pueblo, Colorado
(February 14-15, 1977)
INTRODUCTION
Background
CF&I Steel Corporation operates an integrated steel manufacturing
facility in Pueblo, Colorado. It is the single largest stationary source
of air pollution in the State of Colorado.
Since 1966, various process operations, including the coke plant, have
been operating under State variances and since 1975, the variances have
included compliance schedules. However, for the coke plant, the issued
compliance schedules only considered door leaks and pushing emissions.
Since then CF&I has failed to meet final compliance requirements for its
coke batteries. EPA Region VIII issued a notice of violation (NOV) and
subsequently an order, pursuant to Section 113 of the Clean Air Act, as
amended, requiring CF&I to comply with Colorado Air Pollution Control
Commission (CAPCC) Regulation 1.A.l for pushing emissions, door leaks,
and bench cleanup emissions at its three coke batteries. CF&I failed to
comply with the EPA order and the matter is currently in litigation.
Charging emissions violations had apparently not been documented by
EPA prior to EPA Region VIII issuing the above mentioned NOV and order.
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2
On September 13—14, 1976 EPA Region VIII, with the assistance of the
Pueblo City/County Health Department (PC/CHD) conducted an inspection of
CF&I’s three coke batteries to observe charging operations. As a result
of that inspection, on December 6, 1976 EPA Region VIII issued an NOV to
CF&I for its charging emissions.
On February 14 and 15, 1977, EPA Region VIII, assisted by the EPA
National Enforcement Investigations Center (NEIC) and the PC/CHD, conducted
a survey of CF&I’s three coke batteries to document continuing violations
of CAPCC Regulation 1.A.1 for charging operations. Simultaneously, an
EPA NEIC engineer documented process operations, work practices, and
current equipment in use at CF&I to minimize charging emissions. In
addition, the engineer documented available charts and records which are
kept by the coke plant operations personnel.
Inspection Participants
John Winkley, Manager, Air and Water Quality Control, CF&I
Dave Shilton, Engineer, Air and Water Quality Control, CF&I
Chelsea Pearson, Coke Plant Superintendent, CF&I
Jim Oliver, Assistant Coke Plant Superintendent, CF&I
John Lane, Coke Plant Smoke Control Officer, CF&I
Avery Wyant, PC/CHD
Fred Longenberger, EPA Region VIII
John Dale, EPA Region VIII
Jim Lewis, EPA Region VIII
Jon Dion, EPA NEIC
Gary Young, EPA NEIC
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3
Applicable Regulation
For this inspection, the CAPCC Regulation l.A.l applied, and read
as follows:
“Regulation No. 1 — Particulates, Smokes, and Sulfur Oxides
A. Stationary Air Contamination Sources:
1. No person shall emit or cause to be emitted into the
atmosphere, from any air contamination source whatsoever,
any air contaminant which is of such a shade or density
as to obscure an observor’s vision to a degree in excess
of 20 percent opacity. . •“
PROCESS DESCRIPTION - CHARGING
CF&I Corporation operates a three—battery coke plant at Pueblo,
Colorado [ Figure 1]. The batteries are designated as B, C, and D and
have 65, 47, and 31 ovens, respectively. The three batteries are operated
as two units with no distinct physical demarcation between the two
operating units. Each unit has its own coal bunker, larry car, and
pusher machine equipped with levelling bar. All three batteries are
equipped with double collector mains and are gun—flue fired.
B Battery is divided into three sections numbered A:i—23, B:l-23,
and C:l-19; C Battery is divided into two sections numbered E:l-23 and
F:l-24. D Battery is not subdivided. All ovens are pushed and charged
by the Marquard system (A-7, B-7, C-7, A-9, B-9, C-9, A-li. . . A-23,
B-23, A—2, B—2, C—2, A—4, B-4, etc.).
Each oven has an overall length of 13.2 m (43.2 ft), with a length
inside the doors of 12.3 m (40.5 ft). The height is 4.0 m (13 ft),
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N
By Products
Recovery Plant
South
Quench
Station
0
North
Quench
Station
Washery
“B”
Blending
Coal Storage
FIGURE 1: CF & I COKE PLANT
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4
with a design coal height of 3.7 in (12 ft). The oven width tapers from
43 cm (16.8 in) on the pusher side to 50 cm (19.8 in) on the coke side.
The volume of each oven is reported by the Company to be 21.2 m 3 (747 ft3).
[ Note that the coal volume charged to an oven is reported as being greater
than the physical volume of the oven.J The oven capacity at a bulk
density of 800 kg/rn 3 (50 lb/ft 3 ) is 17.0 in. tons (18.7 tons) of coal
per charge, producing 10.3 m. tons (11.3 tons) of coke. 1
Each oven has four charge ports nmnbered from push to coke side
{east to west). The corresponding hoppers in the larry car contain the
following volumes of coal: 2
in — 5.9 in 3 (208 ft 3 ) 27.7%
#2 — 4.4 in 3 (155 ft 3 ) 20.7%
#3 — 4.1 in 3 (144 if 3 ) 19.2%
#4 — 6.9 in 3 (243 ft 3 ) 32.4%
21.3 in 3 (750 ft 3 ) 100.0%
During the February 14—15 survey, the Company reported the coking
times to be approximately 18 hours on B Battery, 20 hours on C Battery,
and 27 hours on 0 Battery. The coal analysis-—the composite of six
incremental grab samples taken during the day shift——for the two days
was as follows: 2
Parameter (units) 2— 1 14—77 2-15-77
Ploisture (%) 9.3 10.4
Pulverization (% minus 6 mesh) 19.1 76.0
Ash (%) 8.5 8.8
Volatile flatter (%) 34.2 37.2*
Sulfur (%) 0.52 0.49
Bulk Density {lb/ft 3 ) 5D.1O 50.35
3 TIw Company reported this value to be higher than usually experienced. 2
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5
The blend of coal charged the two days of inspection was as follows: 2
Washed Allen - 53%
Sommerset - 19%
Low Volatile - 24%
Petroleum Coke - 4%
VISIBLE EMISSION OBSERVATION RESULTS
The visible emission observation methods used to determine the
charging emissions were twofold. With both observers topside, one
observer (X) read with a stopwatch and recorded the number of seconds of
visible emissions ?25%* opacity; X read from the south side of the
larry car a distance of about seven ovens south of the oven being charged.
The view of observer X was significantly obstructed by the larry car
itself and required him to stoop down to obtain a limited view. The
other observer (Y) located himself between the #2 and #3 charge ports
north of the larry car about three to four ovens from the oven being
charged. [ Note: This observer’s position is not indicated on his data
sheets.] Observer V read with a stopwatch and recorded the number of
seconds any visible emissions were observed. However, the proximity of
V to the oven being charged prevented him from ever seeing above the
larry car (as is true also of the other observer) or having a full view
of all drop sleeves simultaneously. The results of the charging observa-
tions are contained in Tables 1 and 2.
*25% was stipulated by EPA Region VIII as the level at which opacity
should be read by observer X.
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TABLE 1: CHARGIN( EMISSIONS - 2/14/77
CF&I STEEL CORPORATION
Battery Oven Time (seconds)
25% OpacitY O% Opacity
C E-18 7 0
B A-16 4 13
B B—16 2 18
B C-16 2 8
B A-18 3 23
B B—18 4 13
B C—18 16 30
C F—24 7 17
D 7 0 2
B A-20 a 3
B B-2 ) 30 15
B A-22 9 24
B B-22 b 2
C F-i 15 11
B A-5 1 2
B B-5 2 8
B C-S 61 58
B A-7 0 1
B B-7 5 28
C E—il 4 21
D 17 0 5.5
B C-i 2.5 27
a - no observation made
b - view blocked
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TABLE 2: CHARGING EMISSIONS - 2/15/77
CF&I STEEL CORPORATION
Battery Oven Time (seconds)
25% Opacity O% Opacity
C F-24 6 40
C E—22 7 44
D 24 27 36
C E—1 9.5 56
C F—i 14 113
D 26 0.5 32
D 28 2 20
C E-5 8 49
C F—5 0.5 5
C E—7 2.5 14
D 30 4 37
C F—7 2 32
C E-9 6 51
C F-9 13 48
C E—17 0 2
D 7 0.5 6
B B-li 8 51
B C-17 4 16
B A-19 2 17
B B—19 3 51
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6
PROCESS OBSERVATIONS
During the time visible emission observations were made, an NEIC
engineer documented process operations, work practices, and current
equipment affecting charging emissions. In addition, information on
record keeping practices at the plant were obtained from CF&I management
personnel. The results are discussed below.
Staged Charging Procedure
The typical charging cycle sequence presently employed at CF&I
was instituted in July 1972 on B Battery and is now used on all batteries.
Modifications to the sequence have been made from time to time thereafter.
The cycle begins when the Koppers—designed and constructed larry car
is loaded to the desired hopper loadings as permitted by the volumetric
rings at the coal bunkers. The loaded car travels to the oven to be
charged and is spotted over the charge ports; the charge port lids had
been removed soon after the oven was pushed. Once spotted over the
charge ports, the dropsleeves are lowered, the standpipe caps are closed,
the dampers to the collector main are opened and the aspiration steam is
turned on. The larryman then pushes one button and the charge proceeds
automatically as follows:
1. The coal is charged simultaneously from 112 hopper for 16
seconds and from 113 hopper for 11 seconds and the feeders
shut off; this practice was instituted in August 1976 to
reduce door refractory damage caused by insufficient coal
height at the doors.
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7
2. The #1 and #4 hoppers are emptied simultaneously with #1
about 10 seconds ahead of #4, then the slide gates are
closed. The slide gates close automatically when the
amperage on the screw feed drive motors goes to zero.
The operator raises the dropsleeves mechanically and
replaces the lids mechanically with the magnetic lid
lifters one at a time as the hoppers go empty; the cycle
cannot continue until this is done by the larryman. This
practice was adopted in February 1977. This operation
takes about 100 seconds.
3. After #1 and #4 lids are replaced, #2 hopper is emptied,
the dropsleeve is raised, and the lid is replaced. This
requires about 38 seconds.
4. A signal is then given the pusherman to open the chuck door
and start levelling the oven; this precise practice was
adopted in December 1976. (The pusher machine is also Koppers-
designed and constructed.)
5. The #3 hopper is emptied in a start-stop manner - run 11
seconds, down 4 seconds, run 8 seconds, down 4 seconds, run
4 seconds, down 4 seconds. The 4 - 4 run-stop then continues
until the hopper is emptied, at which time the slide gate
closes, the dropsleeve is raised, and the lid is replaced.
This practice was developed during June - September 1976.
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8
6. The levelling bar makes one stroke after #3 hopper is emptied
and is then withdrawn and the chuck door closed.
7. When the charge is complete (the dropsleeves raised, the lids
replaced, the levelling bar withdrawn, and the chuck door
closed), the lidman seats the charge port lids and turns the
aspirating steam off both sides.
8. The larryman, upon finishing the charge, moves to the oven
just pushed and simultaneously mechanically removes the charge
port lids and mechanically cleans the goosenecks with a pair
of reamers )
On B Battery, pushes are three ovens ahead in the sequence (i.e.,,
when B—8 is pushed, B-6 will be charged, and A-B and C-6 are both empty);
whereas on C and D Batteries, pushes are only two ovens ahead in the
sequence. This allows three ovens on B Battery and two ovens on C and
D Batteries to decarbonize at a time.
During the two days of inspection, a few charging cycle sequences
were timed. The results are contained in Table 3.
Gooseneck and Standpipe Carbon Buildup
Goosenecks are cleaned by a pair of mechanical rearners mounted on
the larry car. These devices are used simultaneously while the charge
port lids are being removed from a “just-pushed” oven. After the larry
car is spotted for a charge, the larryman manually uses a chipping bar
to remove carbon deposits in the gooseneck not removed by the mechanical
reamers, and carbon deposits on the lip of the standpipe opening and
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TABLE 3: CHARGING CYCLE SEQUENCE TIMES
CF&I STEEL CORPORATION
Date
Battery
Ove’i
Events and Elapsed Time (minutes:seconds)
2 b
4 d
5 e
6 f
2—14—77
B
B—i
0:Q0 0:14
i i
9:14 1:15
1:29 3:14
ii I L
1:45
1:03
4:17
I I
1:35
5:52
I
2-15-77
C
F—24
1:56
1:35 —
#1
oo
2; 61:38
2— 5-77
C
E—22
0:00 %:U*
L...._....._J
0 43* 3:10
I
1:59
0:56
4:06
1:22
5:28
0:43
*Operator reversed practice on this charge sequence.
a Larry car spotted
b Dropsleeves lowered
C Goosenecks checked and/or chipped, standpipe caps closed, collector main
dampers opened, aspiration steam turned on
d Ill and #4 dropsleeves raised and charge port lids replaced
e fl2 drops1eeve raised and charge port lid replaced
1? #3 dropsleeve raised and charge port lid replaced
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9
on the standpipe cap seating edge. No cleaning of the standpipe itself
was observed during the two-day inspection, although Company officials
Indicated this is done occasionally.
During the survey, the standpipes were inspected for carbon buildup.
The results are contained in Table 4. For the one oven at which significant
standpipe carbon was observed [ Table 4], the emissions during the ensuing
charge were significantly worse, as read by both observers, than for
any other charge observed that day [ Table 1].
No gooseneck carbon buildup was observed after cleaning with the
reamer and chipping bar. The liquor spray entering the sides of the
gooseneck prevented a view of the complete length of the gooseneck.
However, no obstruction should occur because of the type and frequency
of cleaning.
Aspiration System
The main header pipe for the charging steam aspiration system
enters the batteries at the south end of B Battery. From there it
splits into two header pipes which run along the pusher and coke sides
of all three batteries.
Each header pipe feeds the aspiration steam nozzle which on B, C,
and the coke side of D Battery are located atop the gooseneck pointing
directly downward into the collector main. On the pusher side of 0
Battery the steam nozzle points into the gooseneck a few inches below
the standpipe opening in the front. The steam nozzles used are multiport
self—cleaning nozzles constructed of stainless steel. Each nozzle
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TABLE 4: STANDPIPE CARBON BUILDUP
CF&I STEEL CORPORATION
Date
Battery
Oven
PS or CSa
Extent of Buildup
2-14-77
B
D
A-7
B—5
B-7
C_5*
C-5
B-7
B-5
A-7
A-9
A-9
19
19
B-9
PS
PS
PS
PS
CS
CS
CS
CS
PS
CS
PS
CS
CS
Noneb
None
None
SignificantC
None
None
None
None
Somed
None
None
None
None
2/15/77
0
B
7
7
C-17
B-19
B—l7
A-19
A-19
B-17
B-19
C—17
CS
PS
PS
PS
PS
PS
CS
CS
CS
CS
None
Some
None
None
None
None
Some
None
None
None
a PS means push side; CS means coke side.
b None means no carbon buildup observed; refractory lining seen.
c Significant means greater than 2.5 cm (1 in) buildup on interior wall.
d Some means less than significant carbon buildup, but more than none.
* Observed before push, but obstruction remained after the oven was
pushed.
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contains six openings, the midpoints of which are on a concentric
circle. Each opening is 6.4 m (1/4 in) and angles slightly outward.
The Company was experimenting with bored-out nozzles on a few ovens
during our inspection. Ovens A-l through A-9 on B Battery and Oven
F—5 on C Battery have nozzles which have the openings bored out to
4.8 nun (516 in). Only two charges were observed on ovens (B/A—5
and B/A-7) with bored-out nozzles [ Table 1]. However, these charges
were among the best observed by both observers over the two—day inspec-
tion.
The principal gauge to measure header steam pressure is located on
the south end of B Battery at the bench level. The steam is saturated
and regulated to a nominal pressure of 9.1 kg/cm 2 (130 psi). Two
additional steam gauges are located at the catwalk level 0 f C Battery.
The pusher side gauge is located behind the standpipe for oven E-l3;
the coke side gauge is located between the standpipes for ovens E-ll
and E-12. Several readings of both static (no charging being conducted)
and dynamic (during charging) steam pressures were recorded during the
two—day inspection [ Table 5].
Collector main pressures are measured at the Askania valves for
both the pusher side and coke side for each battery by pressure gauges
located in a “doghouse” (small corrugated steel shed) on a catwalk east
of the battery. These pressures are also recorded on charts in the
battery reversing rooms. Nominal readings range between +8 and +12 mm
of water.
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TABLE 5: ASPIRATION STEAM PRESSURES
CF&I STEEL CORPORATION
Date
Time
Battery
Oven
Being
Static
Pressure
Dynamic
Pressure
Charged
kg/cm 2
psig
kg/cm 2
psig
2-14-77
1030
1040
1525
1528
a
C
C
C
C
C
C
-
-
-
E-11
E-11
—
8.6
8.8
8.8
-
—
95
9.5
123
125 b
12 5C
—
—
5 b
135
-
9.1
9.1
-
130 b
13 0 C
2-15-77
0835
1110
1138
1142
1353
C
C
C
C
C
C
a
C
C
-
-
—
-
E-9
E—9
-
-
9.1
9.1
9.1
9.1
-
9.0
9.2
130 b
13OC
130 b
130C
—
128
135 b
9.5
-
13 gb
135 c
-
a — Reading taken at header gauge at bench level, south end of B Battery.
b - Reading taken at C Battery pusher side gauge.
C - Reading taken at C Battery coke side gauge.
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Charge Port lid Operation
The lid removal and replacement sequences are discussed above in
the subsection, Staged Charging Procedure. All lids are removed simultaneously
with magnetic lid lifters while both goosenecks are being reamed. The lid
replacement sequence is identical to the stage charging sequence.
Typically #1 and #4 lid replacement requires 20 seconds; the charge takes
80 seconds, lid replacement 20 seconds, for a total of 100 seconds.
Replacement of #2 lid after the #2 hopper is emptied takes about 12 seconds.
Once the #3 hopper is discharged, it takes about 21 seconds to replace
the charge port lid. 2
Once the lids are replaced, the lidman may lift a corner to sweep
coal spillage into the oven, or he may just tamp the lids until he believes
they are seated properly. The lidman then turns off aspiration steam
and, if the charge ports leak around the lid, he will sweep excess coal
around the perimeter of the lid in an attempt to stop the leaks. At no
time is a wet luting material used; the Company believes that use of
luting material inhibits effective use of the magnetic lid lifters.
Chuck Door Operation
A process observer positioned on the pusher machine timed the
intervals from when the chuck door was opened until levelling began,
until levelling ended, and until the chuck door was closed [ Tables 6 and
7].
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TABLE 6: CHUCK DOOR OPERATION - 2/14/77
CF&I STEEL CORPORATION
Battery
Oven
Time (minutes:seconds)
1
2
3
1+2+3
C
E—18
0:08
1:17
0:50
2:15
B
A-16
0:15
1:54
0:31
2:30
B
B-16
0:12
1:29
0:44
2:25
B
C-16
0:10
1:50
0:18
2:18
B
A-18
0:18
1:53
0:20
2:31
B
8—18
0:15
1:43
0:29
2:27
B
C-18
0:14
1:15
0:51
2:20
B
A-20
0:14
1:43
0:18
2:16
B
B-20
0:14
1:54
0:21
2:29
B
A-22
0:15
1:36
0:21
2:12
B
B-22
0:16
1:15
0:19
2:26
C
F—i
0:13
2:09
0:17
2:39
B
A-5
0:10
1:53
0:11
2:14
B
B-5
0:09
1:33
0:11
1:53
B
C-5
0:10
1:47
0:11
2:08
B
A-7
0:10
1:39
0:09
1:58
B
B-7
0:9
1:43
0:09
2:01
C
E—11
0:10
1:32
0:41
2:23
B
C—7
0:10
1:32
0:11
1:53
AVERAGE 0:12 1:42 0:23 2:17
2 3
A
A = Chuck door opened
B = Levelling begun
C — Levelling ended
D — Chuck door closed
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TABLE 7: CHUCK DOOR OPERATION - 2/15/77
CF&I STEEL CORPORATION
Battery
Oven
.
Time (minutes:seconds)
1
2
3
1+2+3
C
F—24
0:15
2:13
0:23
2:51
C
E—22
0:15
2:08
0:22
2:45
D
24
0:11
2:15
0:21
2:47
C
E—1
0:15
2:22
0:21
2:58
C
F-i
0:20
2:18
0:21
2:59
D
26
0:16
2:07
0:21
2:44
D
28
0:14
2:21
0:25
2:59
C
E-5
0:17
2:22
0:21
3:00
C
F_5*
0:15
2:38
0:31
3:14
C
E—7
0:15
1:56
0:16
2:27
D
30
0:15
1:57
0:20
2:32
C
F—7
0:15
1:46
0:19
2:20
C
E—9
0:11
2:11
0:15
2:37
C
F—9
0:10
2:14
0:16
2:40
C
E—17
0:11
2:04
0:13
2:28
D
7
0:10
1:58
0:17
2:25
AVERAGE 0:14 2:10 0:20 2:44
— 1 2 .3
A B C
A = Chuck door opened
B = Levelling begun
C = Levelling ended
D = Chuck door closed
*Second time chuck door was opened.
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12
Roof and Charge Port Carbon Buildup
The perimeters of a few open charge ports were inspected and no
significant buildup, which could obstruct the free flow of coal into
the oven, was observed. In addition, the roofs of a few ovens were
inspected following the push. The results of the roof carbon buildup
observations are contained in Table 8.
No air cleaning of oven roofs is conducted. The pusher machine rams
are plumbed for it, but the Company has disconnected the air line because
it believes air cleaning would not be worthwhile.
Peak and Channel Heights
According to a Company official, measurements of coal peak heights
and channel height after levelling have been conducted by CF&I. However,
no data on these measurements were requested or received. The Company
desires a 30 cm (12 in) channel height. No measurements of coal peak
or channel heights were made during the two-day inspection.
Personnel
CF&I provided one larr,yman and one lidman for each of the two
operating units. However, between 2:30 and 6:30, both a.m. and p.m.,
only one crew of these two persons operated the batteries because of the
coking schedule. [ Note: only three of the four blast furnaces were in
operation during this inspection.] In addition, CF&I purportedly
provided one “tar chaser” per battery during the day shift, although
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TABLE 8: ROOF CARBON BUILDUP
CF&I STEEL CORPORATION
Battery
Oven
Roof Carbon
Buildup
Loca
tion
D
26
Nonea
C
E-3
None
-
C
F-3
None
-
C
E-5
Someb
Between CS
H charge
standpipe
port
and
C
F-5
None
Between PS
#1 charge
standpipe
port
and
a None means no roof carbon to some roof carbon (c2.5 cm thick)
b Some means roof carbon patches 2.5 to 5 cm (1 to 2 in) thick
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13
this person was not readily identifiable. Patching crews, usually
consisting of a patcher and a helper, were available both on the topside
and at the bench level. The pusher machine man and coke side door machine
man both had helpers who assisted in door cleaning. A newly appointed
Smoke Control Officer (may not be correct title), who reports directly
to the Coke Plant Superintendent’s office, observes smoke emissions from
all facets of the coking operation, including charging, and attempts to
determine the reasons for and to take corrective action when significant
emissions occur.
Record Keeping
An attempt was made to determine the kinds of data recorded by the
Company as normal practice and the length of time such records are kept.
Primary emphasis was on those kinds of data which may be directly or
indirectly associated with charging operations.
In the reversing rooms of all three batteries, the following
parameters and their units are recorded on circular charts:
1. inlet and outlet temperatures of fuel gas heater (°C)
2. Fuel gas flow rate (1 ,000 scfm)
3. Fuel gas pressure (mm of water)
4. Waste gas draft (mm of water)
5. Waste gas flue temperature (°C)
6. Pressures (mm of water)
a. North offtake main
b. South offtake main
c. North crossover main
d. South crossover main
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7. Temperatures (°C)
a. North offtake main
b. South offtake main
According to a Company official, these charts are removed daily,
examined for aberrations, and discarded. No attempt was made to obtain
the pertinent charts for the days of this inspection.
Coal is sampled daily by developing a composite of six grab samples
from the conveyor belt to the coal bunkers. To date, no attempt has been
made by the Company to take samples at the larry car hoppers. Daily
coal analysis parameters include percent moisture, percent ash, percent
volatile matter, percent sulfur, bulk density, and size distribution
[ +13 mm (1/2 in), — 13 mm (1/2 in) + 6 mesh, -6 mesh + 20 mesh, —20 mesh
+100 mesh, -100 mesh].
Coke is also analyzed daily. Parameters of interest to the Company
include percent moisture, percent ash, percent fixed carbon, percent
volatile matter, percent sulfur, size distribution, and stability.
The Company presently uses the available tar in the blast furnaces,
so they are not overly concerned with tar quality. However, they do measure
and record tar quality as percent quinoline insolubles (QI).
Coal, coke, and tar quality analytical data are all recorded daily
on special forms. These forms are kept for historical purposes. Although
the precise length of time they are kept was not revealed, it is probable
that they are kept for several years because of their use in the operation
of the coke plant.
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SUMMARY AND CONCLUSIONS
CF&I Steel Corporation operates an integrated steel manufacturing
facility in Pueblo, Colorado. It is the single largest stationary source
of air pollution in the State of Colorado.
On February 14 and 15, 1977 EPA Region VIII, with assistance from
the EPA NEIC and the Pueblo City/County Health Department (PC/CHD),
conducted a survey of CF&I’s three coke batteries to document continuing
violations of Colorado Air Pollution Control Commission (CAPCC) Regulation
l.A.1 for charging operations. Simultaneously, an EPA NEIC engineer
observed process operation, work practices, and current equipment used
at CF&I to minimize charging emissions. In addition, the engineer
reviewed available charts and records which are kept by the coke plant
operations personnel.
The following conclusions are based on the two-day survey and a
review of the information and data obtained:
1. Charging at CF&I is not in compliance with CAPCC Regulation
1.A.l. Nearly all of the charges observed produced emissions that
exceeded 25 percent opacity.
2. The automation of the larry cars reduces the probability of
stage charging procedures changing from oven to oven. Indeed, the
electronically controlled system should reduce the chance for operator-
error-caused charging emissions to zero.
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3. The mechanical reamers mounted on the larry car and used to
clean the goosenecks should assure clean goosenecks, hence assure
maximum effectiveness of steam aspiration.
4. Significant standpipe carbon buildup can impair airflow through
the standpipe and gooseneck into the collector main. In the one case
where a significant buildup was observed, the ensuing charging emissions
were twice the duration of any other charges observed that day.
5. Charging emissions from the ovens with bored-out nozzles
(B/A-5 and B/A-7) were of shorter duration than most charges observed.
Increasing the effective steam nozzle diameter appeared to reduce charging
emissions.
6. Roof and charge port carbon buildup were not significant.
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REFERENCES
1. Letter from J. C. Winkley, Manager, Air and Water Quality Control,
CF&I Steel Corporation to Norman A. Huey, Chief, Technical Support
Section, EPA-Region VIII, March 9, 1977.
2. Letter from J. C. Winkley, Manager, Air and Water Quality Control,
CF&I Steel Corporation to Gary D. Young, Chief, Air Technology Branch,
EPA—NEIC, Denver, February 22, 1977
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