ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-76-028
Visible Emission Observation
Kaiser Steel Corporation
¥ on tan a, California
September 1975
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
REG,ON,x 1222
SAN FRANCISCO. CALIFORNIA \ *
MAY 1976
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ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
VISIBLE EMISSION OBSERVATIONS
KAISER STEEL CORPORATION
Fontana, California
September 1975
May 1976
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver, Colorado
and
REGION IX - San Francisco, California
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CONTENTS
I. INTRODUCTION 1
II. SUMMARY AND CONCLUSIONS 3
Visible Emission Observations 3
Compliance with Consent Order 5
III. APPLICABLE REGULATIONS 8
Visible Emissions 8
Emergency Variances 9
IV. VISIBLE EMISSION OBSERVATIONS 11
Study Methods 11
Environmental Data 13
Facility Description 15
Blast Furnaces 19
Sintering Plant 24
Coke Oven Batteries 25
Open Hearth Furnaces 35
Basic Oxygen Steel Process Furnaces 38
Rolling Mill Soaking Pits 49
Hot Strip Mill 50
Scrap Cutting 51
V. ANALYSIS OF THE STATUS OF COMPLIANCE
WITH CONSENT ORDER 54
Appendix A Requirements 55
B " 56
C " 58
D " 59
E " 61
F " 62
Discussion 62
APPENDIX - VEO RECORD 65
• • •
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TABLES
II-l Emissions Exceeding Applicable
Regulations - Summary 4
IV-1 Sources of Visible Emissions 12
IV-2 Meteorological Data from Kaiser Steel 14
IV-3 Stack Characteristics 17
IV-4 VEO's at Blast Furnace Process Area 23
IV-5 VEO's at Open Hearth Furnace Area 29
IV-6 VEO's at Coke Battery Sources 31
IV-7 VEO'S at Open Hearth Furnace Area 39
IV-8 VEO's at BOSP Furnaces 43
IV-9 VEO's at Rolling Mill Soaking Pits 50
IV-10 VEO's at Scrap Cutting Areas 53
FIGURES
IV-1 Kaiser Steel Plant Vicinity Map 16
IV-2 Schematic of Stack Orientation 18
IV-3 Blast Furnace Process Flow 20
IV-4 Coke Oven Process Flow 26
IV-5 Observed Coke Oven Leaks 32
IV-6 Open Hearth Furnace Process Flow 36
IV-7 BOSP Furnace Process Flow 41
IV-8 Smoke Density, Stack 23, 20 Sept 45
IV-9 Smoke Density, Stack 23, 21 Sept 46
IV-10 Smoke Density, Stack 21, 20 Sept 47
IV-11 Smoke Density, Stack 21, 21 Sept 48
iv
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I. INTRODUCTION
Kaiser Steel Corporation operates a steel mill at Fontana,
California, about 80 km (50 mi) east of Los Angeles. The facility
is a fully integrated steel mill with basic coke, iron and steel
production processes and a full range of finishing operations. It
is the only integrated mill in California. The basic coke, iron
and steel processes result in the emission to the atmosphere of
excessive levels of particulate air pollutants, despite the instal-
lation of various air pollution control devices.
On 11 July 1974, the Corporation entered into a Consent Order
with EPA-Region IX to control these emissions. The Order specified
various steps to be taken by the Corporation, including process
modifications and installation of air pollution control devices. A
compliance schedule for both interim and final compliance dates was
also established. The Order was amended 11 November 1974, changing
several interim dates but not affecting the final compliance dates.
Subsequent to the amendment, the Corporation on 24 July 1975
submitted a $150 million Steelmaking Modernization Project Proposal
to EPA. The proposal included significant changes from the schedule
in the Consent Order. Among these were extended compliance dates,
with the final EPA compliance date of 31 December 1977 advanced to
30 June 1981. To date no EPA action has occurred on this proposal.
At the request of the Enforcement Director, EPA-Region IX,
San Francisco, California, the National Enforcement Investigations
Center (NEIC) conducted a study of the Kaiser facility in September
1975. The objectives of the study were to determine the status of
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2
compliance with the Consent Order and to observe sources of visible
emissions to determine compliance with applicable County regulations.
The field portion of the study was conducted 16-24 September 1975.
This report presents the results of the study. Applicable
visible emission regulations are presented in Section III. A dis-
cussion of the results of the visible emission observations is con-
tained in Section IV. The status of compliance with the Consent
Order is evaluated in Section V.
4
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3
II. SUMMARY AND CONCLUSIONS
A survey of Kaiser Steel Corporation's integrated steel mill
at Fontana, California was conducted 16-24 September 1975. The
survey was to determine the status of compliance with applicable
visible emission regulations and with an abatement schedule of the
Kaiser-EPA Consent Order.
VISIBLE EMISSION OBSERVATIONS
Observations were made of all major sources of visible emissions
in the blast furnaces, sinter plant, coke oven batteries, open hearth
furnaces, basic oxygen steel process (BOSP) furnaces, rolling mill
soaking pits, hot strip mill and scrap cutting areas. Visible emissions
exceeding applicable regulations were observed at 29 stacks and
numerous coke oven doors, standpipes and quench towers. These sources
and the number of observations at each source are summarized in
Table II-l.
Not all occasions were recorded during the study when emissions
exceeded allowable limits. Excessive visible emissions were almost
continuous from stack No. 6 serving coke oven Battery A, and from coke
oven door leaks. Excessive emissions also occurred from scrap cutting
operations while in progress.
Charging procedures at the coke oven batteries had recently
been changed from sequential to staged charging. Therefore, opera-
tions were not normal and observations of emissions from the charging
cycle were deferred until a later date.
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4
Table II-1
SUMMARY OF OBSERVATIONS OF VISIBLE EMISSIONS
EXCEEDING APPLICABLE REGULATIONS
Process Area
Source
Observations
Exceeding Limits
Blast Furnaces
Sinter Plant
Coke Oven Batteries
Open Hearth Furnaces
Rolling Mills
Hot Strip Mill
Scrap Cutting
stack no.
Basic Oxygen Steel Process
. (BOSP)
Cast House Roof
5
6
7
stack no.] 8
9
.110
11
Door Leaks
Standpipes
Quench Towers
12
13
stack no.116
20
Roof Monitors
stack no.(21
* 23
ESP* Bypass
Roof Monitors
stack no
57
Main Area
Near BOSP
3
1
3
1
1
10
8
3
8
6
6
29
2
3
8
5
1
8
7
2
3
7
1
2
1
1
1
2
1
6
2
Total 145
+ electrostatic precipitator
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5
COMPLIANCE WITH CONSENT ORDER
Compliance with the 11 July 1974 Consent Order to date has been
minimal. This is best illustrated summarizing Corporation progress
under each Appendix to the Order.
Appendix A
Part A. An EPA contractor is studying control technology that may
bring "A" Battery stack into compliance. An experimental unit is
presently processing half the stack emission as part of the study.
Part B. The Corporation has requested an extension of up to 30
months for compliance with emissions from Battery stacks B
through G.
Appendix B
Part A. The Corporation certified that pushing and charging at
all batteries were in compliance with Rule 50A. »
Part B. The Corporation certified that coke oven doors and stand-
pipes in Batteries C through G were in compliance with Rule 50A.
Part C. The Corporation has installed new doors on Batteries A
and B but is not required to certify compliance until 31 December
1975.
Part D. No action required.
Part E. The final control plan to bring combined visible emissions
from each coke oven into compliance was not submitted on 30 July
1975 as required.
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6
Appendix C
Part A. The Corporation did not certify to compliance with Rule
50A. However, they did indicate meeting the necessary increment
of progress for charging and tapping operations at furnaces No. 1
and 3 of the basic oxygen steel process (BOSP).
Part B. A 7-1/2 month extension was requested due to delivery
problems with the baghouse.
Appendix D
On 17 January 1975 the Corporation was advised that they are in
violation of the Order. The Corporation has not met a later date
for installing additional control equipment at the open hearth
furnaces but has proposed an alternative Steelmaking Moderniza-
tion Program. This would extend the final compliance date on
these units for 17 months.
Appendix E
The Corporation has indicated they will not erect a scrap cutting
building with control equipment as required by the Order. They
were advised of being in violation of the Consent Order on 15 May
1975. The Steel Modernization Program included installation of a
ball drop facility and machine torch cutting devices on the out-
side as the alternative to an enclosure. These are in place but
not in accordance with the Order.
Appendix F
The Steelmaking Modernization Plan suggests a 3-1/2 year extension
for compliance with the desulphurization of coke oven gas.
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7
Progress thus far has led to the following conclusions:
The Corporation has acted unilaterally in modifying elements of the
Consent Order without consulting EPA. These modifications may or
may not bring the particular operation into final compliance.
The Corporation has certified to compliance with various elements
of the Consent Order that appear to be out of compliance.
Visible emission observations indicate that other facilities at the
plant not covered by the Consent Order are exceeding Rule 50A.
Operations and Maintenance procedures which will play a major role
in meeting clean air objectives do not seem to receive the priority
necessary.
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8
III. APPLICABLE REGULATIONS
Emissions of air pollutants from the Kaiser steel mill are subject
to regulations promulgated for the San Bernardino County Air Pollution
Control Zone, Southern California Air Pollution Control District. Spe-
cific regulations concerned with visible emissions and with upset or
breakdown conditions are presented below.
In addition, emissions from the steel mill are the subject of a
Consent Order entered into by EPA and the Kaiser Steel Corporation on
11 July 1974. The Order specifies various abatement measures to be im-
plemented by the Corporation on a specific time schedule. The require-
ments of the Order and the Corporation's progress to date in complying
with the Order are discussed in detail in Section V of this report.
VISIBLE EMISSIONS
Visible emissions are subject to the limitations specified in the
.following San Bernardino County regulation:
Rule 50A. Visible Emissions
A person shall not discharge into the atmosphere from any
single source of emission whatsoever, any air contaminant
for a period or periods aggregating more than three (3)
minutes in any one (1) hour which is:
a. As dark or darker in shade as that designated as No. 1 on
the Ringelmann Chart, as published by the United States
Bureau of Mines, or
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9
b. Of such opacity as to obscure an observer's view to a
degree equal to or greater than does smoke described
in Section (a) of this Rule.
This Rule is effective on 1 June 1972 for all sources which
are not either in operation or under construction prior to
that date, and Rule 50 shall not be applicable to such sources
on or after that date. This Rule is to become effective for
all other sources on 1 January 1975, and Rule 50 shall not be
applicable on or after that date.
Variances from compliance with Rule 50A have been granted to
Kaiser Steel Corporation for several of their Fontana operations
by the San Bernardino County Hearing Board. These variances have
not been approved by EPA. Operations excepted and compliance dates
are as follows:
Scrap Cutting 31 May 1976
EMERGENCY VARIANCES
The regulations grant emergency variances for excessive emissions
during upset or breakdown of control equipment under certain conditions.
Rule 55. Upset Conditions or Breakdowns
Emissions exceeding any of the limits established in this regu-
lation as a direct result of upset conditions in or breakdown
of any air pollution control equipment or related processing
Open Hearth Stacks
Coke Oven Battery A Stack
Coke Oven Batteries B to G Stacks
31 July 1977
31 Dec. 1976
31 Dec. 1977
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10
equipment shall not be deemed to be in violation of the rules establish-
ing such limits, provided the following requirements (a) and (b) of this
section are met.
a. Any upset condition or breakdown of equipment which causes
a violation of the Rules and Regulations of the District
or the Health and Safety Code of the State of California
shall be reported to the office of the District within
thirty (30) minutes.
b. As soon as possible after notification, the District shall
be informed of the estimated time for repairs; and if more
than four (4) hours are required to repair the condition,
the Control Officer shall request the source either to
shut down the operation until repairs can be made or file
immediately for an emergency or interim variance in accord-
ance with Rule 85(d). In the event that the breakdown
or upset condition occurs during other than normal working
hours of the Air Pollution Control District, the intent
to file for an emergency or interim variance shall be
transmitted by telephone for recording wUnn four (4)
hours after the violation is reported and tnat every
reasonable effort is taken to minimize the emissions.
Investigations will be made by a member of the District
staff to verify the upset conditions.
This Rule is effective 10 September 1974.
Rule 55 has not been approved as part of the California State
Implementation Plan.
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11
IV. VISIBLE EMISSION OBSERVATIONS
STUDY METHODS
The primary purpose of the field study was to observe the major
sources of visible emissions to determine the present status of
compliance with applicable regulations. Detailed process information
had previously been obtained by both San Bernardino County and EPA-
Region IX personnel. Therefore, no detailed process evaluation was
made. A limited walk-through reconnaissance of the plant was conducted
by San Bernardino County personnel to familiarize study staff with
the location and identification of emission sources to be observed.
Actual observations of visible emissions were conducted 16-24
September 1975. Ten certified smoke readers from NEIC, EPA-Region IX,
the California Air Resources Board, and the San Bernardino County
Air Pollution Control Zone took visible emission observations (VEO's)
during the study. Sources observed are listed in Table IV-1. The
smoke readers used standard observation methods (EPA Method 9) for
orientation of the observer with respect to sun position, wind direc-
tion and viewing background. Environmental data, plume characteristics,
source data, visible emission readings and other pertinent information
for each set of readings were recorded on EPA-IX-Form 298 [Appendix],
a modification of the California Air Resources Board visible emission
observation record form. Environmental data collected by the ob-
servers included wind speed and direction, air temperature and relative
humidity. Only summaries of the VEO records are included in this report.
Individual VEO records are on-file at NEIC.
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12
Table IV-1
SUMMARY OF SOURCES OF VISIBLE EMISSIONS EVALUATED
PROCESS AREA
SOURCES
Blast Furnaces
Sinter Plant
Coke Oven Batteries
Open Hearth Furnaces
Basic Oxygen Steel Process
Rolling Mills
Hot Strip Mill
Scrap Cutting
Stove Stacks (3), Cast House
Roof Monitors (3)
Main Stack
Main Stacks (6), Oven Doors,
Standpipes, Quench Towers
Main Stacks (8), Roof Monitors
Furnace Stacks (3), ESP+ Bypass,
Roof Monitors
Soaking Pit Stacks (19)
Reheat Furnace Stacks (3)
Open Areas (2)
t electrostatic precipitator
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13
During the study, no attempt was made to record every visible
emission that appeared to exceed applicable regulations. Instead,
a number of VEO's were systematically taken at major emission sources
within each process area listed in Table IV-1. When practical, in-
cidental emissions occurring in the area being observed were recorded.
Smoke readers periodically switched sources so that several readers
observed each major source of emissions at different times during
the survey.
>
Color photographs were taken to document visible emissions and
to record a general overview of the plant. Several types of cameras
were used and the photographs were taken from ground and roof level
at the plant and from a low-flying light aircraft. The photographs
are not presented in this report but are on-file at NEIC.
ENVIRONMENTAL DATA
In addition to the environmental data recorded by the study crew,
data was obtained from a meteorological station at the plant operated
by Kaiser's Environmental Quality Control Department. The system includes
wind speed and direction sensors mounted on a tower atop the galvanizing
facility and temperature, pressure, and relative humidity sensors on the
roof of the Environmental Quality Control office. Data are automatically
scanned, printed, and punched every two minutes. Hourly readings were
tabulated from this file for the period during which VEO's were being taken
[Table IV-2]. Wind speed data are suspect because of problems with the
sensor at the lower wind speed threshold, which will be corrected by Kaiser
in the near future. Relative humidity also appeared to be inaccurate when
compared on several occasions to EPA wet and dry bulb hygrometer readings.
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T1r«
1200
1300
1400
1500
1600
1700
1800
1900
0800
0900
1000
1100
1200
1300
MOO
1500
1600
1700
0800
0900
1000
1100
1200
1300
1400
1500
1600
1700
1800
1900
0800
0900
1000
1100
1200
1300
1400
1500
1600
1700
1800
1900
51
51
51
54
53
51
41
33
32
32
32
33
32
28
27
27
25
31
30
30
29
29
09
10
10
11
11
10
10
38
39
39
37
37
37
Table 1V-2
METEOROLOGICAL DATA FROM KAISER STEEL
fo::ta:ia, California
Wind Speed
Wind
Direction
C)
Temperature
Relati
Kumdl
(X)
(1 m/hr
(mph)
(UC)
( F)
15 6
9 7
256
33
91
55
9.0
5.6
279
34
94
57
19.2
11.9
256
36
97
57
25 2
15.7
279
36
97
56
19 3
12.0
276
36
96
56
26 2
16 3
274
36
96
57
19.6
12.2
260
34
94
57
23 2
14 4
257
31
88
57
0 6
0 4
149
26
78
62
0 6
0 4
171
28
83
59
0 8
0.5
208
29
85
58
0 6
0 4
255
31
87
58
0 6
0 4
283
32
90
58
16.4
10.2
288
33
92
58
19 5
12 2
264
34
94
58
24.3
15.1
250
35
94
58
21 6
13 4
299
34
93
59
30.4
18.9
280
33
92
53
7.0
4 3
174
24
75
62
0 6
0.4
180
27
81
59
0 4
0.3
213
27
81
58
0 4
0 3
266
29
84
57
0 4
0 3
238
31
87
55
0 4
0.3
262
31
83
51
0 4
0.3
265
32
90
46
21.8
13 5
278 '
32
90
45
9 8
6 2
264
32
89
47
33 2
14 4
280
32
89
46
19 0
11.8
269
29
85
46
0.6
0.4
259
27
81
45
0 6
0 4
146
22
72
54
0.6
0.4
166
24
76
54
0 6
0.4
160
28
82
49
0.6
0 4
?54
29
85
49
0 4
0 3
200
30'
86
50
0.4
0.3
251
32
90
51
0.4
0.3
2'9
32
90
51
0.4
0.3
260
32
90
49
1.3
0.8
267
32
90
50
0.6
0.4
283
32
89
53
0.6
0.4
273
29
84
53
0.6
0.4
263
27
81
56
Date
Time
Wind Speed
(km/hr) (mph)
Wind
Direction
C)
Temperature
m i°n
0800
0 6
0.4
128
22
71
0900
0 6
0.4
192
24
76
1000
0 6
0 4
281
27
60
1100
0 6
0 4
267
28
83
1200
0 6
0 4
219
30
86
1300
0 6
0 4
283
31
88
1400
0 6
0 4
258
32
90
1500
0 6
0 4
293
33
91
1600
0.6
0.4
254
33
91
1700
0.6
0.4
252
32
89
1000
0.6
0.4
284
30
86
1900
0.6
0.4
277
28
82
0300
0.6
0.4
076
27
79
0900
0 6
0 4
077
35
95
1000
0 6
0 4
101
37
99
1100
0.4
0 3
397
37
98
1200
0 4
0 3
405
37
99
1300
0 4
0 3
422
38
100
1400
1 1
0 7
402
39
103
1500
0.4
0.3
403
39
102
1600
0.4
0.3
413
39
103
1700
0 4 •
0.3
400
39
102
1800
0.6
0.4
413
36
97
1900
0 6
0 4
420
34
94
0000
0 6
0.4
52
24
76
0900
0 6
0 4
147
29
85
1000
0 6
0 4
191
33
91
1100
0 6
0 4
204
34
94
1200
0 6
0 4
242
36
96
1300
0.6
0 4
243
37
98
1400
0 4
0 3
400
38
101
1500
0 4
0.3
401
38
101
1600
0.4
0 3
391
39
102
1700
0 4
0 3
411
38
101
1800
0.4
0 3
261
35
95
1900
0.6
0 4
279
33
91
0800
0 6
0.4
103
27
81
0900
0 6
0.4
165
29
85
1000
0 6
0.4
191
33
91
1100
0.6
0 4
167
35
95
1200
0.6
0.4
111
37
98
1300
0.6
0.4
110
37
99
1400
0.6
0.4
39
38
100
1500
0.4
0.3
167
38
100
1600
0,4
0.3
147
38
99
9/20
0/22
•9/23
9/24
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15
The data are useful, however, in showing the general environmental
conditions prevailing during the study.
FACILITY DESCRIPTION
The large Kaiser facility is the only fully-integrated steel
mill in California. Basic operations include coke making with by-
product recovery, basic production of iron in blast furnaces, con-
version of iron to steel in both open hearth and basic oxygen process
furnaces, a sintering plant, and a full range of finishing operations
including production of structural shapes, pipe, sheet metal, galvan-
ized products and tin plate. Production of coke, iron and steel in
1972 was 1.36, 2.07, and 2.72 million metric tons (1.50, 2.28, 2.99
tons) respectively.
Basic process units are compactly arranged in a rectangular
area about 2.6 km2(1.0 mi2) [Fig. IV-1]. The basic coke, iron and
steel making processes are located in the north half of this area.
Most of the emission points of interest are also in the north half.
Finishing operations occupy most of the south half of the plant site.
An inventory of stacks including sources of emissions and stack
characteristics is presented in Table IV-3. The relative locations
of the stacks are shown schematically in Figure IV-2.
In the following sections, the results of the visible emission
observations are discussed by process area. A limited basic process
discussion common to the industry is presented to orient the reader
and to define what emission points were observed. Minor variations
may be expected throughout the industry. Detailed process information
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A (41 tuu ]|
V (S'ding) .V
•WT^"
i
Figure / V -1. Kaiser Steel Plant Vicinity Map
cr>
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Table IV-3
STACK CHARACTERISTICS
Stack1"1" Type Furnace Height Type Stack Stack Type Furnace Height Type Stack
1. Blast Furnace #1 200' Concrete
2. Blast Furnace #2 200' Concrete
3. Blast Furnace #3 200' Concrete
4. Blast Furnace #4 200' Concrete
5. Sinter Plant 300' Concrete
6. Coke Oven, Battery A 225' Concrete
7. Coke Oven, Battery B 225' Concrete
8. Coke Oven, Battery C 225' Concrete
9. Coke Oven, Battery D 225' Concrete
10. Coke Oven, Battery E 225' Concrete
11. Coke Oven, Batteries F&G 250* Concrete
12. Open Hearth #1 175' Concrete
13^. Open Hearth £2 175' Concrete
141 Open Hearth h3 175' Concrete
15. Open Hearth #4 175' Concrete
16. Open Hearth §5 175' Concrete
17. Open Hearth #6 175' Concrete
18. Open Hearth #7 175' Concrete
19. Open Hearth 88 175' Concrete
20. Open Hearth #9 175' Concrete
21. Oxygen Furnace 150' Steel
22. Oxygen Furnace 150' Steel
23. Oxygen Furnace 150' Steel
24. Soaking Pits 21 & 22 110' Concrete
25. Soaking Pits 19 & 20 110' Concrete
26. Soaking Pits 17 & 18 110' Concrete
27. Soaking Pits 15 & 16 110' Concrete
28. Soaking Pits 13 & 14 110' Concrete
29. West preheating pits 75' Steel
30. Soaking Pits 11 & 12 110' Concrete
31. Soaking Pits 9 & 10 110' Concrete
32. Soaking Pits 7 & 8 110' Concrete
33. Soaking Pits 5 & 6 110' Concrete
34. Soaking Pits 3 & 4 110' Concrete
35. East preheating pits 75' Steel
36. Soaking Pits 23 & 24 110' Concrete
37. Soaking Pits 25 & 26 110' Concrete
38. Soaking Pits 27 & 28 110' Concrete
39. Soaking Pits 29 & 30 110' Concrete
40. Soaking Pits 31 S 32 110' Concrete
41. Soaking Pits 33 & 34 110' Concrete
42. Soaking Pits 35 & 36 110' Concrete
43. Soaking Pits 37 & 38 110' Concrete
44. Soaking Pits 39 a 40 110' Concrete
45.
46.
47.
48.
49.
50.
5"
52.
53.
54.
55.
56.
57.
58.
59.
60.
61 .
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
Merchant Mill (Skelp line)
Plate Hill (Slab Fee. #2)
Plate Mill (Slab Fee. #1 )
Plate Mill (Slab Fee. #3)
C.W.Pipe Mill (Skelp Fee.)
C.W.Pipe Mill (Galv.Dept.)
C.W.Pipe Mill (Galv.Dept.)
Merchant Mill (Roughing)
Structural Mill (29")
Tin Plate Mill (Scruff)
Plate Mi 11 (Pickle)
Hot Strip Mill (Fee.
Hot Strip
Hot Strip
House
Mi 11
Mill
(Fee
(Fee.
#3)
#2)
Tin
86"
86"
86"
Power
Power House
Power House
Power House
Power House
Power House
Power House
Flare
Flare
Sheet Galv. Pickle Line
Hot Scarfer
62" Pickle Line
Alk. Cln. Line Sheet Galv.
Walking Beam Furnace
Type R Rotoclone Exhaust Stack
Type N Rotoclone Exhaust Stack
Type N Rotoclone Exhaust Stack
35' Concrete
59" Steel (Abandoned)
75' Steel
75' Steel
25' Steel
52' Steel
60' Steel
25' Steel
59' Steel
75" Steel
70' Steel
50' Steel
50' Steel
50' Steel
(Removed)
(Foundry)
(Foundry)
(Foundry)
t Table prepared by the San Bernardino County Air
Pollution Control Zone staff and current through
15 October 1975
tt See Figure TV-2 for stack locations.
ttt Abandoned
-------
67 e fll
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11
9
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O
statu
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54
e
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NOTE: See Table IV-3 for
stack characteristics
HOT STRIP Bill
NOT TO SCALE
Figure IV-2. Schematic of Stack Orientation
-------
19
is on-file at the San Bernardino County Air Pollution Control Zone
and EPA-Region IX offices. Observations of visible emissions ex-
ceeding applicable regulations are summarized and evaluated.
BLAST FURNACES
Basic Process
Blast furnaces are used to reduce iron ore to metallic iron.
The basic process flow is shown schematically in Figure IV-3. Raw
materials including coke, iron ore, limestone and sinter are inter-
mittently charged to the top of the blast furnace through a hopper
equipped with air locks. Hot air blown into the bottom of the furnace
causes the coke to burn, producing high temperatures and large volumes
of carbon monoxide (CO). The combination of heat and the reducing
atmosphere in the mid-level of the furnace converts the iron ore to
metallic iron that collects in a molten state at the bottom of the
furnace. Impurities in the ore combine with the limestone to form
slag that collects as a liquid on top of the molten iron. This re-
duction process proceeds continuously. Periodically the furnace
is tapped during casting operations and the molten iron is drawn off
to hot metal cars for transfer to the steelmaking operations. Slag
is also drawn off periodically. In many blast furnace operations,
the slag flows to ladles for transfer to disposal points at other
plant locations. At Fontana, the slag is discharged directly to pits
adjacent to the blast furnaces. After cooling, the solidified slag
is removed mechanically for byproduct processing.
The gas that flows upward in the furnace has a useful fuel value
because of its high CO content. Before use, the gas is cleaned in a
dust catcher and a wet scrubber to remove flue dust. The flue dust
-------
HOT MITMCM
Figure IV-3.
Typical Blast Furnace Process Flow Diagram
ro
"o
-------
21
(primarily iron fines) is sent to the sinter plant for processing
and recycle to the blast furnace. About one-third of the blast
furnace gas is used to heat stoves as discussed below. The remainder
is primarily used to fire powerhouse boilers that drive turbines
that compress the air for the hot blast.
Each blast furnace is equipped with three stoves used to heat
air for the hot blast. Blast furnace gas is burned in the stoves to
heat a checkerwork of refractory material filling the stove. Com-
bustion gases are vented to the atmosphere through a single stack
serving all three stoves. Normally, while two stoves are being
heated, cold air is blown through the third (preheated) stove and
heated by the" refractory material before entering the blast furnace.
Blast furnace gas is usually cleaned before burning in the
stove. However, periodically the blast furnace is ''back drafted."
During this operation, gas is drawn off the bottom of the furnace
and, without being cleaned, it is burned in a stove.
Emission Sources
Visible emissions may occur from the stove stack, from the
hopper at the top of the furnace during charging operations, from
bleeder valves on the blast furnace gas lines, and from the cast
house roof monitors during hot metal transfer and slag drawoff opera-
tions.
Air Pollution Controls
There are no air pollution control devices on the stove stack,
the furnace hopper or the bleeder valves. The blast furnace cast
house encloses the base area of the furnace where hot metal transfer
-------
22
and slag drawoff operations take place. Emissions from these sources
are thus semi-confined in the building but vent directly to the at-
mosphere through roof monitors.
Observations
The Fontana mill has four blast furnaces numbered 1 through 4
from west to east [Fig. IV-2]. The stove stacks have the same numbers.
Furnaces No. 2 and No. 4 were in continuous operation during the survey.
Furnace No. 3 was out of operation for relining. Furnace No. 1 was
being reheated and was placed in operation on 22 September. Furnace
No. 2 was casting on a 3-1/2 hour schedule beginning at 3:00 a.m. daily;
iron from the unit normally supplies the basic oxygen steel process fur-
naces. The No. 4 furnace was casting on a 4-hour schedule starting at
12:30 a.m. daily. This unit supplied iron to the open hearth furnaces
and the foundry.
Observations of the stove stacks for the three operating furnaces
documented seven occurrences of visible emissions in excess of allow-
able limits. These are summarized in Table IV-4. The table lists the
total time during each observation period that emissions were equal to
or greater than 20% opacity. Rule 50-A limits emissions to 20% opacity;
however, since an average deviation not to exceed 7.5% opacity is al-
lowed during certification readings, Region IX Enforcement Division con-
siders 30% opacity to be in violation of Rule 50-A for purposes of en-
forcement actions. Thus the table also includes the time readings ex-
ceeded 30% opacity. Actual observation periods varied in length and
ranged from a minimum of the time shown in the table to a maximum of 60
minutes. In cases where the emissions were essentially in excess of
limits continuously, observation periods of 10 to 15 minutes were used.
The emissions thus continued beyong the recorded time. For intermittent
emissions or occasional emissions in excess of limits, longer observa-
tion periods were necessary.
-------
23
Table IV-4 also lists the maximum opacity observed and the average
opacity of readings exceeding the 20% and 30% values. These give an
indication of how excessive the observed emissions were.
For stack No. 1 serving stoves on blast furnace No. 1, one obser-
vation of excessive emissions was made while the furnace was being
heated and two more observations after the furnace began operating.
The Corporation indicated that visible emissions from the stacks
result from "back drafting" during casting. This practice draws dirty
furnace gases back through the stoves where the gases are burned and
exhausted through the stove stack.
Table IV-4
SUMMARY OF VISIBLE EMISSION
OBSERVATIONS AT THE BLAST FURNACE PROCESS AREA
Emission
Source
Date
(1975)
Time (min)
Avq.
Opacity^
Max.
Opacity (%)
Observed
>20%
>30%
>20%
>30%
Stack 1
9/17
10.75
10.75
10.75
79
79
100
9/23
13
12.50
8.50
29
32
35
9/23
9.75
9.75
9.75
63
63
70
Stack 2
9/20
12
12
12
72
72
90
Stack 4
9/17
11.5
11.5
11.5
74
74
90
9/19
20
20
20
84
84
100
9/20
12
12
10
36
38
40
#4 Blast Furnace
Cast House
9/19
9
9
9
68
68
95
+ Average opacity of emissions observed in excess of stated value.
-------
24
Visible emissions occasionally were observed originating from
roof monitors on blast furnace cast houses during casting and slag
drawoff activities. One such excessive emission recorded during
slag drawoff is shown in Table IV-4.
SINTERING PLANT
Basic Process
The primary function of a sintering plant is to agglomerate and
recycle fines back to the blast furnace. Fines, consisting of iron-
bearing wastes such as mill scale from finishing operations and dust
from the basic oxygen open hearth and blast furnaces, are blended
with coke fines that serve as fuel in the sintering process. The
material is spread on a moving down-draft grate and ignited. Com-
bustion of the coke produces heat that fuses the material together.
The fused sinter is crushed, screened and air-cooled.
The material handling, crushing and cooling operations are very
dusty. In addition, dust and volatized oil are present in the pro-
cess gases. The sinter machine, crusher, cooler and part of the
material-handling equipment are contained in the sinter plant building.
Emission Sources
Visible emissions may occur as fugitive dust emissions from
material handling operations outside the sinter plant building or
as process gas emissions from the sinter plant stack (stack No. 5).
At 91 m (300 ft), this stack is the tallest in the steel mill.
-------
25
Air Pollution Controls
Process gases from the sinter emissions and dust emissions from
other points within the sinter plant building are exhausted to a large
baghouse before discharge to the plant stack.
Observations
Visible emissions from the sinter plant stack were infrequent.
When visible, the plume was white and detached. The visible emissions
probbably originated from volatization of oil from mill scale fed to the
process.
A single 9.25-minute observation of stack No. 5 on 16 September
documented excessive emissions. Emissions of greater than 20% opacity
were recorded for the total of 9.25 minutes of which 7.50 minutes were
in excess of 30% opacity. The excessive emissions averaged 32% opacity
for the 9.25-minute period and 34% opacity during the 7.5-minute period.
The maximum capacity observed during the interval was 40%.
COKE OVEN BATTERIES
Basic Process
The primary function of the coke ovens is to convert bituminous
coal to coke. This is accomplished by heating the coal in special
ovens to drive off the volatiles, leaving the residue coke. The vola-
tiles are collected and processed to yield a number of byproduct chemi-
cals and coke oven gas. The gas is used to fuel burners in the ovens
and other furnaces in the steel mill complex.
Figure IV-4 is a schematic diagram of a typical process flow
for coke ovens. The ovens are rectangular and constructed of
silica brick. Each oven is usually about 45 cm wide, 4.5 high and
-------
Figure IV-4. Typical Coke Oven Process Flow Diagram
1\>
CD
-------
27
12 m long (18 in x 15 ft x 39 ft). The ovens are arranged side-by-
side in groups called batteries. The Fontana installation has seven
batteries designated A through G from west to east. Each battery
has 45 ovens. The ovens are numbered sequentially from west to east
as 1 through 349 except that numbers ending in 0 are not used.
Coal is charged through holes (ports) in the roof of each oven
from hopper bottom (larry) cars that run on tracks on top of the
battery. A leveler bar on the push machine that runs on tracks
parallel to the battery is inserted into the oven through the small
chuck door to level the top of the coal. Heat is applied by burning
coke oven gas in flues in the walls between ovens. Combusion pro-
ducts are collected from all flues in a battery and discharged through
one stack.
During the coking period, volatile materials are distilled
from the coal and are collected through standpipes passing out
through the roof of the oven at either end. These materials are
processed in the byproducts plant and coke oven gas is recovered.
When the coking period is completed, the doors at both ends
of the oven are opened and the red-hot coke is pushed from the oven
into the quench car by the ram on the push machine. The quench car
moves the coke to the quench tower where it is sprayed with water
to cool it. The cooled coke is delivered to handling equipment for
subsequent movement to point of use, normally the blast furnaces.
Once the coke has been removed from an oven, the doors are
closed and the charging cycle is repeated.
Emission Sources
Combustion gases from the flues are exhausted to the atmosphere
through the main battery stack. If there are leaks in the oven walls,
-------
28
volatile material from the ovens may also vent through this stack.
Visible emissions occur when the coke is pushed into the quench car,
and from the quench car, as it is moved to the quench tower. The
quench produces visible emissions from the tower, along with large
volumes of steam. Volatile materials in the ovens may escape to the
atmosphere through leaks around the charging ports and oven doors and
from leaks at blowoff valves on the gas standpipes or around the base
of the standpipes. Emissions also occur from the charging ports dur-
ing charging operations.
Air Pollution Controls
There are no control devices on any of the sources of emissions
with the exception of a TRW charged droplet scrubber installed on
Battery A for a pilot study of control of flue gas emissions.
Observations
Batteries A through E are served by stacks #6 through 10. Bat-
teries F and G are served by stack No. 11. During this survey, the
coking period for Batteries A through E was 40 hours while for Batteries
F and G, the period was 15.7 to 17.1 hours. Batteries A and E are op-
erated at lower temperatures than are F and G. Each oven was charged
with 12,200 kg (26,800 lb) of coal.
Visible emissions from the battery stack normally occur only when
leaks into the flues from the ovens are present. Since the batteries
are never shut down, maintenance to seal the leaks must be done while
the ovens are hot. A silicone sealer is used for this purpose.
Observations of excessive visible emissions from coke battery
stacks are summarized in Table IV-5. The worst emissions occurred
-------
Table IV- 5
swmm of visible mission observations
AT COKE BATTERY STACKS
Date
Time (mm)
Avg.
0pacity+
Max.
Battery
(1975)
Observed
>20i
>305;
••20%
>30'^
Opacity (%)
A
(Stack #6)
9/17
18.25
28
18.25
25.75
18.25
25.50
98
79
98
80
100
100
9/18
24.75
12.25
25
9
24.75
12.25
25
9
24.75
12.25
25
9
94
50
91
55
94
50
91
55
100
60
100
65
9/20
10
13
10
13
10
13
88
57
88
57
100
65
9/22
23.50
20
23.5
20
23.5
20
98
80
98
80
100
100
B
(Stack #7)
9/17
8
17.25
7.75
17.25
7
17.25
67
82
72
82
80
100
9/18
22.50
13
20
22.50
13
20
22.50
12.50
20
74
43
93
74
44
93
100
65
100
9/20
10
10
10
84
84
100
9/22
19
9
19
9
19
9
86
74
86
74
100
95
C
(Stack #8)
9/17
9/18
9.75
16.25
9.75
16.25
8.75
16.25
53
75
56
75
100
100
9/19
10
10
9.25
48
50
65
0
(Stack #9)
9/17
6
13.75
5.5
13.75
3.75
12.75
44
52
55
55
85
100
9/10
15
7.25
15
7
15
5
56
60
56
75
85
95
9/19
15
19
12
13
18.75
12
8.5
15.75
12
34
48
80
44
63
80
60
80
100
9/22
10
10
8.75
43
46
70
E
(Stack #10)
9/18
26
16.75
25.75
15
24.50
13
61
42
63
46
95
80
9/19
23
13
12.25
22.5
13
11.75
17.25
10.5
11
35
55
51
39
63
53
70
100
80
9/20
22.25
22.25
18.75
49
54
95
F. G
(Stack #11)
17
10.25
19
6
9.5
18.75
4.75
5.5
16
3.5
49
45
37
68
49
42
100
80
50
9/18
4.25
4.25
4
48
50
65
9/19
8
8
8
85
85
100
9/20
10.5
9
4.25
28
33
40
t Average opacity observed in crces3 of stated value.
-------
30
from stack #6 serving Battery A, the oldest battery in the installation.
Excessive visible emissions also occurred from other coke battery
operations. The most significant emissions were from oven door leaks.
Observations of excessive door emissions are summarized in Table IV-6.
Door leaks occurred both immediately after charging and later during
the coking period. Doors on the A through E Batteries (oven numbers
less than 250) appeared to take longer to seal. The company indicated
that this was due to the lower operating temperatures in these batteries.
Observations were made of all ovens on three days to determine
the frequency of occurrence of door leaks without regard to the
opacity of emissions. The results of these observations are shown
graphically in Figure IV-5. On 20 September, only the coke side of
the battery was observed during the first five time periods. Be-
ginning at 1555 hours, both sides of the battery were observed, as
was the case for all three periods on 23 September. On 24 September,
only the push side was observed. These observations indicated that
door leaks occurred much more frequently on the push side, probably
due to additional wear produced by the pushing ram and leveling bar
striking the rim of the oven and chuck doors. Changes in pressure
within the coke oven gas collecting system was the probable cause of
changes in the number of door leaks. This is shown in Figure IV-5
for 1130 hours on 23 September and 1135 hours on 24 September when
a large increase in door leaks occurred.
Closer examination of individual doors after charging indicated
that in some cases the initial leakage emissions were from 20 to 40%
opacity and sealed within 15 minutes. Others took longer to seal or
were of a higher opacity. These high opacity emissions are summarized
in Table IV-6 for the observations of leaks immediately after charging.
Emissions from doors that took longer to seal are summarized under
the observations taken during coking.
-------
31
Table IV-6
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT MISCELLANEOUS COKE BATTERY SOURCES
Date
(1975)
Oven
No.
Oven
Side
Time (Min.)
Observed >20%
>30%
Avq.
>20%
0pacity+
>30%
Max.
Opacity (%)
Door
Leaks
Immediately After Charging
9/23
204
Coke
8.25
8.25
8.25
48
48
80
244
Coke
7
7
7
64
64
80
9/24
75
Coke
22
22
20.75
66
70
100
85
Coke
20.25
19.25
14.75
38
43
60
267
Coke
11.75
11.75
11
52
53
100
277
Coke
8.25
8.25
6
36
41
60
283
Push
9.25
9.25
9.25
65
65
70
25
Coke
6.25
6.25
6.25
41
41
50
35
Coke
9
9
9
45
45
55
45
Coke
9.75
9.75
9.75
48
48
60
285
Coke
14
13
11.25
39
42
60
333
Push
9
9
9
61
61
70
Door Leaks After Coking
9/17
24
Push
9
9
9
82
82
100
9/20
157
Push
15
14.5
14.25
44
44
60
14
Coke
0
9
9
56
56
85
9/22
186
Push
11.75
11.75
11.75
74
74
80
124
Push
6.75
6.75
6.75
64
64
80
9/23
74
Coke
8.75
8.75
8.75
74
74
80
9/24
53
Push
10
10
10
80
80
90
143
Coke
7.75
7.75
7.75
74
74
80
15
Push
10
10
10
83
83
90
13
Coke
10.25
10.25
10.25
61
61
80
101
Coke
13
13
13
48
48
65
65
Push
10
10
10
70
70
80
213
Coke
10
10
9.5
43
44
65
47
Coke
10
10
9
48
50
70
315
Coke
13
13
12.75
53
54
100
127
Coke
11.25
9.75
7.5
33
36
45
157
Coke
9
9
8
58
62
100
Standpipe Leaks
9/20
129
Coke
10
10
10
85
85
100
187
Push
15.75
14.75
14.25
49
50
65
Quench Tower Emissions
9/18
East
-
23.25
20.25
16.50
41
46
100
9/19
East
-
17
17
16.75
54
54
80
9/20
East
-
14.50
13.50
12.25
47
49
100
f Average opacity observed in excess of stated value.
-------
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20 40 60 80 100 120 140 160 180
Oven Number
200
220
240
260
280
300
320
340
Figure IV-5. Observed Coke Oven Leaks
U>
ro
-------
33
Excessive emissions from standpipe leaks on top of the coke
batteries were observed on several occasions [Table IV-6]. The
optimum location for observing these leaks, however, is from on
top the batteries as discussed below.
Excessive emissions were also observed from the quench towers
[Table IV-6]. When the quench car arrived at the quench tower, emis-
sions could be observed before quenching began. During quenching,
large steam clouds were produced but dissipated about 30 m (100 ft)
downwind leaving a visible white plume. About 3 minutes were required
from the time the car arrived at the tower until the quench was com-
pleted, during which time reading was possible.* On several occasions,
a delay occurred between arrival of the quench car at the tower and
the start of the water spray. This resulted in excessive smoke emis-
sions. For Batteries F and G, processing coke on a 15 to 17 hour
cycle, about six quenches per hour would be expected. However, during
one 60-minute period, eight quenches were observed.
Each process associated with the pushing and charging cycle was
timed to examine the range of these variables. The push cycle was
separated into the period between the coke door opening and time the
coke began to move; the time during which the coke was being pushed
into the coke car; and the time of travel of the coke car to the
quench tower.
Charge time was measured from the time the larry car moved into
place until it moved from over the oven. This may not correspond in
all cases to the actual charging time. However, to determine actual
charge time would have required personnel to be on top of the battery.
* Deterioration of baffles in the tower and the poor quality of quench
water probably contributed to these emissions.
-------
34
The company instituted stage charging quite recently, 5 September,
on Batteries A through E and 25 August for Batteries F and G. Only
one larry car had been completely modified for this new procedure
and it was out of operation. The company indicated that this change
was being resisted (as most changes will be) by operating personnel.
Thus, while sequential charging required about 2-1/4 minutes, stage
charging was presently requiring between 3 and 6 minutes but should
reduce to about 2-3/4 minutes when accepted. The break-in period,
plus the hazards and heat associated with monitoring the process
from top-side during high ambient temperature conditions, suggested
that timing and evaluation of visible emissions from the push-charge
cycle would be more productive and meaningful at a later date. The
heat and hazardous conditions also suggested that standpipe and
charge port leaks would best be evaluated at that time as well.
The largest time variable in the push cycle (27 observations)
was the time between door opening and the push. This ranged from 30
seconds to 14-1/2 minutes, with a median of 2-3/4 minutes. The push
time into the coke car was relatively uniform, between 25 and 50
seconds, with a median of 30 seconds. The time to reach one of the
three quench towers largely depended on the towers in use relative
to the location of the particular oven. This ranged between 15
seconds and 2-1/3 minutes with a median of 55 seconds. Total time
for the push varied from 2 to 17-1/4 minutes with a median of 4-1/4
minutes.
Charging time as measured required from 2-1/4 to 12-3/4 minutes
(23 observations) with a median time of 4-1/4 minutes. Four of these
observations (17%) were below 3 minutes, indicating either that stage
charging was beginning to be accepted or that sequential charging
was still occurring.
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35
OPEN HEARTH FURNACES
Basic Process
For many years, the open hearth furnace process was the major means
of converting iron to steel. In most steel mills, the open hearths are
being replaced by basic oxygen steel process (BOSP) furnaces. At Fontana,
both processes are in use but additional conversions from open hearth to
BOSP furnaces have been proposed as discussed in Section V.
The open hearth furnace is basically a shallow rectangular refractory
basin or hearth enclosed by refractory lined walls and roof. A typical
process flow diagram is shown in Figure IV-6. Scrap iron and steel,
iron ore, and limestone are charged into the furnace, and fuel from a
burner at one end of the hearth is ignited to produce heat over the scrap
to melt it. Combustion gases are drawn off at the other end of the
hearth through a chamber filled with a checkerwork of refractory materials
that absorb heat and cool the gas. An identical chamber at the burner
end of the furnace preheats combustion air. Periodically the air flow
direction is reversed.
When meltdown of the scrap has been completed, molten iron from
the blast furances is charged. The iron is poured from the hot metal
transfer car into a hot metal ladle which, in turn, charges it into the
furnace.
As heating continues, carbon monoxide and carbon dioxide are re-
leased from the iron ore and limestone to produce the ore and lime boils.
Further heating refines the steel by removing impurities. The refining
period can be speeded up by lancing the surface of the hot metal with
pure oxygen.
-------
Figure IV-6. Typical Open Hearth Furnace Process Flow Diagram
CO
C7>
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37
When the proper steel composition and temperature are reached,
the furnace is tapped and the molten contents drawn off to a teeming
ladle. Slag is floated off the metal surface in the teeming ladle
to slag ladles for disposal. The molten steel is ladled into ingot
molds and is air cooled.
Emission Sources
The primary emission source is the stack that conveys combustion
gases and fumes from the hearth to the atmosphere. In addition,
various operations produce emissions inside the furnace building that
are vented to the atmosphere through roof monitors. These include
the charging of scrap and hot metal, the transfer of hot metal to the
charging ladle, and the tapping of steel into the teeming ladle.
Air Pollution Controls
Emissions from the hearth are controlled by electrostatic pre-
cipitators (ESP) before release to the furnace stack. There are no
controls on roof emissions.
Observations
There are currently eight operable open hearth furnaces at Fontana.
These are numbered 1 through 9 with unit No. 3 disassembled. The corre-
sponding stack numbers and locations are shown in Table IV-3 and
Figure IV-2. Stack No. 14 that formerly served furnace No. 3 is still
in place. During the survey only furnaces No. 1, 2, 5 and 9 were
operating.
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38
Excessive visible emissions were observed to originate from
both furnace stacks and roof monitors. These are summarized in
Table IV-7.
Excessive stack emissions generally occur as a result of mech-
anical or electrical problems with the ESP or when rapid fluctuations
in process emissions cause the ESP to be operated outside design
speci fications.
Process data (heat reports) made available by the company indi-
cated that the overall time from charge to tap was between 5 and 7
hours. Charging of raw materials required between 30 and 90 minutes,
followed by the addition of hot metal between 30 minutes to 2-1/2
hours later. Comparison of stack emission observations with these
heat records showed that the excessive visible emissions occurred
during the working period following hot metal addition, except for
one instance when emissions were observed during the melting period.
The emissions during the working period probably occurred during
oxygen lancing. For those cases checked, no excessive visible
emissions from the stacks occurred during scrap charging or hot metal
addition.
BASIC OXYGEN STEEL PROCESS FURNACES
Basic Process
The basic oxygen steel process, through the use of large volumes
of oxygen, condenses the process for converting iron to steel from
5 to 7 hours in the open hearth furnaces into a period of less
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39
Table IV-7
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT OPEN HEARTH FURNACE AREA
Emi ssion
Date
Time (min)
Avq.
Opaci ty1
Max.
Source
(1975)
Observed
>20%
>30%
>20%
>30%
Opacity (%)
Stack Emissions
Hearth #1
9/18
9
9
6.50
33
36
45
(Stack #12)
8.25
8
6.75
36
39
50
23
22.75
21.50
40
41
60
26.75
25.50
19.25
32
36
45
21.75
21.75
18.75
42
45
70
9/20
19.75
15.25
6.50
28
35
45
9/22
18
15.25
7.75
28
34
50
9/23
10
10
9.75
41
43
60
Hearth #2
9/18
7.5
7.5
7.5
58
58
90
(Stack #13)
9/19
16.75
14.5
12.25
42
45
80
18.75
18
13
31
34
50
9/20
12.25
12
11.50
53
55
70
9/22
10
10
10
54
54
75
Hearth #5
9/24
10
10
10
43
43
55
(Stack #16)
Hearth #9
9/17
28.75
18.5
11.5
29
33
45
(Stack #20)
13.75
10.75
9
34
37
60
7.5
6
5.5
45
47
60
9/18
22
19.5
16.75
42
45
70
7.25
5.75
5
42
45
60
9/19
17
11.25
5
28
36
50
9/20
14
14
12.25
57
61
95
9/22
11
11
11
53
53
60
Roof Monitors
Hearth #2
9/17
21.25
8
4
28
35
40
#4
6.25
5.25
4.25
32
35
80
#4
9/18
17.50
13.25
9.75
34
38
50
#6
25.75
24.50
18.50
44
53
90
#6
9/19
9
6
4.75
43
48
80
t Average opacity observed in excess of stated value.
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40
than 1 hour. The process is carried out in a refractory-lined, pear-
shaped, open-mouthed furnace mounted on trunnions so that it may be
tipped for charging and pouring of melted metal. A typical process
flow design is shown in Figure IV-7. Iron from the blast furnace is
poured from the hot metal transfer car into the hot metal ladle for
subsequent charging into the furnace. Scrap metal up to 30% of the
melt weight is also charged into the furnace. Limestone and other
fluxes are added. Oxygen is then blown into the furnace at supersonic
velocities through a water-cooled lance. This produces an exothermic
reaction that releases enough heat to melt the scrap metal without
adding fuel. After about 20 minutes of oxygen lancing, the steel
has been refined and reaches the desired temperature. Off gases from
the furnace "are collected in a hood that fits over the mouth of the
furnace.
The furnace is tilted and the molten steel is tapped into the
teeming table for subsequent ingot casting. Slag remaining in the
furnace is then poured into slag ladles and the process cycle can be
repeated.
Emission Sources
The major off-gas emissions from the furnace are collected in the
hood, cleaned in an ESP and then discharged to the atmosphere through
a stack. Emissions can also occur from pressure relief or bypass hatches
on the ducts from the furnaces to the ESPs. There are three BOSP fur-
naces at Fontana, Nos. 1, 2, 3, served by stacks Nos. 21, 22, 23, re-
spectively. Emissions from each ESP can be vented through any of the
three stacks.
Various operations in the BOSP building including hot metal re-
ladling, charging, tapping, and oxygen lancing of ladles to remove
residual metal from the refactory lining produce emission that reach
-------
Figure IV-7. Typical
Basic
Oxygon Steel Process (BOSP) Furnace Process Flow Diagram
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42
the atmosphere through roof monitors and other building openings.
Some of these emissions are captured by a series of ducts that convey
them to the ESP serving furnace No. 3.
Air Pollution Controls
The major off-gas emissions are controlled by large electrostatic
precipitators. Partial control of emissions within the building is
also achieved by an ESP. A baghouse is scheduled to be installed to
control building emissions as discussed in Section V.
Observations
During the survey, furnace No. 2 was not in use. Excessive
visible emissions were observed originating from stacks No. 21 and 23
and from roof openings. These observations are summarized in Table IV-8.
The emissions were generally rust-red although yellow emissions charac-
teristic of scrap cutting were observed from roof openings on five
occasions. The 23 September observation of stack No. 23 was taken
when furnace No. 3 was not in operation. This emission thus originated
from either furnace No. 1 or from other operations within the building.
Company representatives indicated that visible emissions from
the stack could result from several causes. If the ESP was operating
cooler or hotter than its design range, or if any of the steam or
water sprays in the hood duct were inoperative, continuous emissions
could be expected.
Each of the main stacks is equipped with a Bailey Smoke Density
Meter and an integrator to measure the total time the emissions exceed
20% opacity.
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43
Table IV-8
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT THE BASIC OXYGEN STEEL PROCESS FURNACES
Emi ssion
Source
Date
(1975)
Time (min)
Avg.
Opacity1
Max.
Opacity (%)
Observed
>20% >30%
>20%
>30%
Stack Emissions
Stack m
9/19
13.75
12 11.25
40
41
60
ft
5.25
4.5 3.75
45
50
60
9/22
14
14 12.75
58
61
100
22
19.5 17.25
41
42
60
9/23
9
5.75 3.25
30
35
45
ft
12
10 8.75
47
50
100
tt
12
12 7.25
33
40
60
Stack §23
9/19++
14.75
13.5 11.75
83
93
100
9/23
19
15.25 4.75
27
40
100
ESP
fH +
Bypass Hatches
9/19
18.25
12.5 10
51
57
100
8.25
8.25 8
59
60
100
9/23
12
10.25 8.5
54
61
95
Yellow Smoke Emissions
Roof
9/17
8.75
8.5 8
47
49
60
Openings
13.5
13.5 13
42
43
55
11.75
10.5 9.5
42
45
65
9/18
14.75
14.5 12.75
49
53
85
7.5
7.5 7.5
54
55
85
White and Rust Emissions
Roof
9/17
16
12 7.75
44
65
80
Openings
5.25
5.25 4.75
38
39
45
t Average opacity observed in excess of stated value.
ft Upset Condition reported to the San Bernardino County Air Pollution
Control Zone.
t+t Electrostatic precipitator.
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44
Examination of the smoke density recordings [Figs. IV-8, IV-9] in-
dicates that emissions from stack No. 23 varied only slightly and were
within acceptable opacity limits on both days illustrated, 20-21 Septem-
ber. The charts also show that the meters are kept in good repair since
they continue to return to a 1% minimum, indicative of routine main-
tenance and the use of a live zero. On the other hand, similar charts
for stack No. 21 [Figs. IV-10, IV-11] show that emissions from this
stack were in excess of the Rule 50A limitation for about six periods
each day. This is probably indicative of poor operation or maintenance
of the ESP, but it is also directly related to the cyclical operation
of the BOSP furnace.
Reddish-brown emissions were observed when leaks occurred at the
seals on the pressure relief or bypass hatches mounted on the roof in
the exhaust stream from the furnace to the ESP. This occurred when the
hatches were not closed and sealed properly. These emissions were re-
lated to the cyclical operations of the furnaces. Visible emissions
in the building were also observed during charging and tapping opera-
tions.
The most significant visible emissions within the BOSP furnace
building that eventually reached the atmosphere through roof openings
resulted from hot metal reladling and lancing of ladles. Emissions
were produced when molten iron was poured from the hot metal transfer
car into the hot metal ladle at the reladling station. Emissions also
resulted when ladles were lanced as part of regular maintenance to re-
move metal deposits remaining on the refractory lining. Both activities
produced emissions that appeared to far exceed those produced by charg-
ing and tapping operations.
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45
•- - —rr50l
Ses
Figure IV-8. Smoke Density Readings-Stack No. 23, 20 September 19/5
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46
riioNiGHUSv
¦-—T j0 \ . \
Figure IV-9. Smoke Density Readings-Stack No. 23, 21 September 1975
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47
Figure IV-10. Smoke Density Readings-Stack No. 21, 20 September 1975
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48
Figure IV-11. Smoke Density Re adi n g s-5 t ack No. 21, 21 September 19 75
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49
ROLLING MILL SOAKING PITS
Basic Process
Steel ingots from the BOSP or open hearth furnaces must be passed
through hot forming processes before they can be converted to finished
steel products. The ingots are heated in special furnaces called soak-
ing pits before they are fed to the primary rolling mills for forming
into intermediate forms such as slabs, blooms and billets. Coke oven
gas or natural gas is usually burned in the pits with combustion gases
and exhausted to the atmosphere through furnace stacks.
Emission Sources
There are 38 soaking pits serving the rolling mills at Fontana.
Each pair of soaking pits is served by a single 34 m (110 ft) tall
stack. Stack locations and designations are shown in Figure IV-2 and
listed in Table IV-3.
Air Pollution Controls
There are no air pollution controls on soaking pit emissions.
Observations
Excessive visible emissions were observed from six of the soaking
pit stacks [Table IV-9]. The emissions were gray to black and resulted
from improper fuel combustion. Because of the location of the stacks
with respect to the rolling mill buildings, many were virtually impos-
sible to observe from ground level while meeting EPA Method 9 require-
ments.
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50
Table IV-9
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT ROLLING MILL SOAKING PITS
"h
Emission Date Time (mirt) Avq. Opacity Max.
Source (1975) Observed >20% >30% >20% >30% Opacity (%)
Stack No.
33
9/17
6
6
5.5
38
39
50
37
31
30.25
30
56
57
60
40
12.75
11
3.25
25
32
35
37
9/18
10
10
10
58
58
85
31
9/19
19.25
16.5
8.5
27
32
40
41
9/20
18.5
16.5
6.75
26
31
35
43
11
9
3.75
26
31
35
43
9/22
9
9
9
45
45
55
t Average opac%ty observed in excess of stated value.
HOT STRIP MILL
Basic Process
Hot strip mills reduce slabs formed from ingots in primary rolling
mills to flat strip steel generally less than 30 cm (12 in) thick. The
slabs are heated in reheating furnaces and then conveyed to a rolling
train for forming and finishing to size. The furnaces heat the slabs to
a temperature of about 1,100° to 1,300°C (2,010° to 2,370°F). Coke oven
gas or natural gas is generally used to fire the furnaces.
Emission Sources
The 218 cm (86 in) hot strip mill has three reheat furnaces (Nos.
1, 2, 3). Each furnace is served by a 46 m (150 ft) tall stack.
Furnace No. 1 is served by stack No. 58, furnace No. 2 by stack No. 57
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5]
and furnace Mo. 3 by stack No. 56. With the exception of minor
emissions released to the hot strip mill building when slabs are
removed from the furnace, all combustion products are exhausted
to the atmosphere through the stacks.
Air Pollution Controls
Emissions from the stacks are monitored by Bailey Smoke Meters
set to sound an alarm whenever the opacity exceeds 10%. This re-
portedly permits sufficient time for operating personnel to adjust
the combustion characteristics of the furnace before emissions exceed
the 20% opacity limit. The stack emissions are not visible from
within the mill; thus the need for the automatic alarm. There are
no other air pollution controls on the furnaces.
Observations
On 23 September, excessive visible emissions were observed from
stack No. 57 serving Furnace No. 2 when the alarm failed to operate.
Emissions exceeded the 30% limit for 10 minutes during the period of
observation. The maximum opacity observed was 60%, with a 49% average.
SCRAP CUTTING
Basic Process
Basic iron and steel production processes and the finishing mills
generate scrap iron and steel that can be recycled through the steel
making process without waste. This scrap ranges in size from large
ladle "skulls" to small sheet scraps. Scrap steel is also imported
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52
to the plant from other locations. The large pieces must be cut or
broken into smaller sizes before they can be charged into the basic
oxygen and open hearth furnaces. This can be accomplished by cracking
the pieces by impacting with a large steel ball, by shearing plates
or more commonly by cutting with gas torches. When torches are used
for cutting ingots and other thick scrap, visible emissions in the
form of yellow-brown or green smoke are released to the atmosphere.
Emission Sources
The major scrap cutting operation is conducted in the open on
the east side of plant property. On several occasions, scrap cutting
was observed at other locations on plant property. For these open air
operations, the smoke is released directly to the atmosphere. Scrap
cutting inside buildings produces emissions that are released to the
atmosphere through roof monitors.
Air Pollution Controls
There are no air pollution controls for the scrap cutting operations.
Observat ions
Excessive visible emissions from scrap cutting operations were
observed on several occasions at both the main scrap area and south
of the BOSP area. These are summarized in Table IV-10.
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53
Table IV-10
SUMMARY OF VISIBLE EMISSION OBSERVATIONS
AT SCRAP CUTTING AREAS
Emission Date Time (min) Avq. Opacity^ Max.
Source (1975) Observed >20% >30% >20% >30% Opacity (%)
South of
BOSP
9/17
9.25
7.5
5.75
34
37
50
9
7.5
6.75
57
61
80
Main Area
9/18
18.25
10
6.5
37
45
75
19.50
10.5
9.25
46
49
80
11.75
10
9.5
52
54
80
13.25
7.5
6.75
44
46
80
9/19
28
20
18
56
60
90
9.5
9.5
9.5
79
79
95
t Average opacity observed in excess of stated value.
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54
V. ANALYSIS OF THE STATUS OF COMPLIANCE WITH THE CONSENT ORDER
On 11 July 1974, the EPA and the Kaiser Steel Corporation entered
into a Consent Order (Docket No. 9-74-9) under which the Company agreed
to an implementation plan and schedule for reducing air pollution from
that facility. This Order was revised on 11 November 1974 to adjust
intermediate increments to Appendix E of the Order without affecting
final compliance dates. The Order included these six Appendices dealing
with various processes at the plant:
A Coke Oven Battery Stacks
B Coke Oven Batteries
C Basic Oxygen Steel Processing Shop
D Open Hearth Furnace Stacks
E Scrap Metal Cutting Operation
F Desulfurization of Coke Oven Gas
Subsequent to this revision, the Company proposed a $150 million
Steelmaking Modernization Project contingent upon securing financial
commitments and obtaining the necessary concurrence and permits from
regulatory agencies. This plan would extend the compliance dates of
portions of the air quality control program past those contained in the
Consent Order.
On 17 September 1975 progress toward compliance with the Consent
Order was discussed with a representative of the Company. Present were:
Mr. John H. Smith, Director, Environmental Quality Control,
Kaiser Steel Corporation
Ms. Lois E. Green, Enforcement Division, EPA-Region IX
Dr. Jules B. Cohen, EPA-NEIC
Mr. Karl Krause, California Air Resources Board
Information obtained during that discussion is contained below.
Every milestone in each Appendix to the Order to date has been listed,
followed by Company progress in meeting that milestone.
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55
EVALUATION OF APPENDIX A REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Division,
shall complete the following acts with respect to its coke oven
battery stacks, listed below, on or before the dates specified:
A. "A" Battery Stack.
(1) 1 November 1974 - submit progress report on status
of research and development program.
By letter dated 30 October 1974 the Company transmitted "TRW Systems
Group Progress Report No. 15" prepared for EPA. TRW is conducting a
research and development program on a Charged Droplet Scrubber for Fine
Particle Control. The pilot plant portion of the program included a
proposal to process one-half the normal output of "A" Battery stack at
the Kaiser coke ovens.
(2) 1 May 1975 - submit final control plan.
The Corporation submitted a control plan on 10 June 1975 confirming
the system in (1) above. But the plan only addressed installation of
the prototype unit designed to process up to half the normal capacity
of the stack. A submittal on 23 April 1975, including drawings of the
unit, did not meet the requirements of the Order. The Company was so
advised on 23 May 1975.
(3) 1 July 1975 - let contracts for the purchase of control
equipment or process modification.
On 25 June 1975 the Company advised they had let a contract for pur-
chase of the Charged Droplet Scrubber and for installation of the unit.
However, the only contract that had been let at that time was a contract
from TRW to Kaiser Steel for installation of the prototype Charged Drop-
let Scrubber.
The Consent Order has no requirements to date; however, the Kaiser
Steel Modernization Program proposes to extend the EPA compliance date
of 31 December 1977 until 31 December 1978 on two stacks, and 30 June
1980 on the remaining three stacks. This assumes the success of the
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56
TRW project discussed above. Should this not be successful, a Wet
Precipitrol by Fluid Ionics would be considered; however, this
could extend dates even further.
EVALUATION OF APPENDIX B REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Division,
shall complete the following acts with respect to its coke oven
operations on or before the dates specified:
A. Pushing and charging operations at each coke oven in coke
Batteries "A", "B", "C\ "D", "E", "F" and "G". For the
purposes of this paragraph, visible emissions from the
pushing and charging operations at each coke oven shall
be combined for determining interim compliance as re-
quired by sub-paragraph (5).
(1) 31 July 1974 - submit approvable operating and
maintenance program. Either certify compliance
as required by sub-paragraph (5) or submit final
control plan.
By letter dated 30 July 1974 the Company submitted an operating
and maintenance program and certified compliance with San Bernardino
County Air Pollution Control District (SBAPCD) Regulation IV, Rules 50
and 50A. The above action precluded the necessity for further activity
under this paragraph.
B. Coke oven doors and standpipes at each coke oven in coke
oven Batteries "C", "D", "E", "F" and "G". For purposes
of this paragraph, visible emissions from the doors and
standpipes at each coke oven shall be combined for deter-
mining interim compliance as required by sub-paragraph (5).
(1) 31 July 1974 - submit approvable operating and
maintenance program. Either certify compliance
as required by sub-paragraph (5) or submit final
control plan.
By letter dated 30 July 1974 the Company submitted an operating
and maintenance program and certified compliance with San Bernardino
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57
County Air Pollution Control District Regulation IV, Rules 50 and
50A. The above action precluded the necessity for further activity
under this paragraph.
C. Coke oven doors and standpipes at each coke oven in coke
oven Batteries "A" and "B". For the purpose of this
paragraph, visible emissions from the doors and stand-
pipes at each coke oven shall be combined for determining
interim compliance as required by sub-paragraph (6).
(1) 31 July 1974 - submit approvable final control
plan to include installation of new doors as
well as operating and maintenance program.
A final control plan to replace all doors on "A" and "B" Bat-
teries was submitted on 30 July 1974. The operation and maintenance
program was included in the A(l) submittal above.
(2) 30 August 1974 - let contracts for the purchase of
control equipment or process modification.
On 4 September 1974 the Company advised that contracts were
awarded for new coke oven doors.
(3) 30 September 1974 - commence on-site construction or
installation of control equipment or process modification.
The Company did not certify to completion of this increment of
progress.
(4) 31 December 1974 and 30 June 1975 - submit progress
report.
Progress reports were submitted on the dates required. The report
of 30 June 1975 indicated no foreseeable problem in meeting the com-
pliance schedule.
D. Such approvable operating and maintenance programs as are
required by paragraphs A, B and C above, shall be incor-
porated into and made a part of this Order.
No action required.
E. Program designed to bring combined visible emissions from
pushing and charging operations, doors and standpipes at
each coke oven in coke oven Batteries "A", "B", "C", "D",
"E", "F" and "G" into compliance with San Bernardino
County Air Pollution Control District Regulation IV,
Rules 50 and 50A.
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58
(1) 31 August 1974 - submit plan for engineering studies.
A plan for conducting engineering studies, prepared by Battelle,
Columbus Laboratories, was submitted on schedule.
(2) 31 December 1974 - submit progress report on status
of engineering studies.
The Corporation advised that Battelle had completed the first
portion of their report to EPA on 30 December 1974. On 26 March 1975,
Kaiser submitted the Battelle report to EPA. The report, dated
31 December 1974 was a state-of-the-art review on control of emis-
sions from coke ovens.
(3) 31 July 1975 - submit results of engineering studies
and either certify compliance as defined above with
San Bernardino County Air Pollution Control District
Regulation IV, Rules 50 and 50A} or submit an approvable
final control plan reflecting the state-of-the-art in
technology to achieve compliance. Such approvable
control plan shall be incorporated into and made a
part of this Order.
On 30 July 1975 the Corporation submitted the final portion of the
Battelle study resulting from field trips to a number of steel com-
panies throughout the country. The San Bernardino Air Pollution
Control Officer has indicated by letter (6 August 1975) to the cor-
poration that the report contained certain errors and drew some in-
correct conclusions.
The transmittal of 30 July 1975 did not certify compliance nor
did it contain an approvable final control plan as required.
EVALUATION OF APPENDIX C REQUIREMENTS
The KAISER Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to its basic oxygen steel processing shop building on or
before the dates specified:
A. Charging and tapping operations at furnaces No. 1 and 3.
15 October 1974 - achieve compliance with San Bernardino
County Air Pollution Control District Regulation IV,
Rules 50 and 50A.
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On 18 October 1974 Kaiser Steel advised that the required in-
crement of progress regarding the charging and tapping operation
had been completed. They did not certify to compliance with SBAPCD
Regulation IV, Rules 50 and 50A as required.
B. Hot metal transfer operation*.
(1) 31 December 1974 - submit final control plan.
The Company submitted an engineering drawing depicting the bag-
house and ductwork location with some details, in fulfillment of this
requirement.
(2) IS February 1975 - let contracts for purchase of
control equipment or process modification.
On 18 February 1975 Kaiser advised that contracts had been let as
required. Kaiser stated that delivery was not possible until January
1976 and requested an extension of the final compliance date from 15 De-
cember 1975 until 31 July 1976.
(3) 1 May 1975 - commence on-site construction or in-
stallation of control equipment or process
modification.
Kaiser Steel advised the Agency on 8 May 1975 that on-site prepa-
ration and installation of utilities had begun in order to comply with
this increment. The final compliance date has not yet been extended
by the Agency.
EVALUATION OF APPENDIX D REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing Di-
vision, shall complete the following acts with respect to
its open hearth furnace stacks Nos. 1, 2, 4, 5, 6, 7, 8, and
9, on or before the dates specified:
* For purposes of Appendix C3 the hot metal transfer operation at the
basic oxygen steel processing shop shall include the hot metal trans-
fer station which results in emissions from the sides and roof moni-
tors of the basic oxygen steel processing shop building. The hot
metal transfer station includes pouring of molten pig iron from tor-
pedo cars into ladles which carry the molten iron to the basic
oxygen furnaces.
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(1) 31 July 1974 - submit final control plan for upgrading
of existing electrostatic precipitators as well as an
operating and maintenance program therefor and for
the construction of additional control equipment (electro-
static precipitators).
On 24 July 1974 the Corporation submitted a final control plan
which included modifications to the precipitators, included an op-
eration and maintenance (O&M) program, and called for installation
of a balloon flue between the furnaces and precipitators to average
the flow.
(2) 30 November 1974 - let contracts for the purchase of
control equipment or process modification. Continue
to upgrade existing electrostatic precipitators and
implement operating and maintenance program as re-
quired by Decision No. 86-D of the Hearing Board,
Air Pollution Control District, County of San Ber-
nardino, California, which is incorporated into and
made a part of this Appendix.
On 14 November 1974 Kaiser Steel requested a revision in the
compliance date to 21 December 1974. This was followed on 4 De-
cember by a letter advising that the increment of progress had not
been met. After a meeting on 7 January 1975 at the EPA offices, the
Agency could find no justification for a delay. Kaiser Steel was
advised on 17 January 1975 that they were in violation of the Order
and must let contracts forthwith.
(3) 15 May 1975 - complete construction or installation
of all process modifications as required by the
Decision referenced in subparagraph (2) above.
The Corporation certified completion of all construction and pro-
cess modifications required by Decision No. 86-D of the Hearing Board,
SBAPCD, on 21 May 1975.
(4) 1 September 1975 - commence on-site construction or
installation of additional control equipment.
The date was not met. Instead, the Company has proposed their
Steelmaking Modernization Program which includes two new basic oxygen
steel furnaces. These furnaces would replace five open hearth fur-
naces, leaving two in operation and one for standby. The open hearth
furnaces would be operated at reduced rates so as not to exceed ex-
isting precipitator capacity.
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61
The Kaiser Steel plan calls for a final compliance date of 31
December 1978, 17 months later than required by the Consent Order.
EVALUATION OF APPENDIX E REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to its scrap metal cutting operation on or before the
dates specified:
(1) 31 July 1974 - submit final control plan to include
a building enclosure and baghouse.
The Company submitted design drawings of a scrap cutting build-
ing with baghouse control on 24 July 1974.
(2) 30 September 1974 - let contract for purchase of
building and control equipment (baghouse). Commence
off-site fabrication of building and control equip-
ment (baghouse).
On 4 October 1974 the Company advised that they had "initiated
contract awards" for the scrap cutting operation. As stated, this
did not indicate that the contract had been let as required by the
Consent Order. This was clarified on 28 October 1974 when the
Company indicated awarding contracts for fabrication of the building
and for design and fabrication of a baghouse.
(3) 1 April 1975 - commence on-site construction or instal-
lation of building and control equipment (baghouse).
No certification was received*, this date was missed. The Company
indicated by letter of 24 March, 1975 that they would not erect a building
and baghouse for this facility. The Company was advised by the agency on
15 May 1975 that they were in violation of this provision of the Consent
Order.
A new proposal is included in the Steelmaking Modernization
Program. By 5 October, machine torch cutting devices were anticipated
to be in place, along with a ball drop facility. Compliance by this
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62
facility will take advantage of the increased size of the charging
boxes on the oxygen furnaces that have been proposed. However, the
anticipated completion date for those is 31 December 1978, 31 months
after the compliance date in this Order.
The Company anticipates that using the machine torches will reduce
emissions enough to negate the requirement for a building and the neces-
sary air pollution control equipment. However, while the torches and
ball drop facility will process an estimated 13,970 m. tons (15,400
tons)/month, an additional 9,070 m. tons (10,000 tons)/month remains to
be processed by as yet undetermined means.
EVALUATION OF APPENDIX F REQUIREMENTS
The Kaiser Steel Corporation, Steel Manufacturing
Division, shall complete the following acts with respect
to the sulfur content of its coke oven gas on cr before
the dates specified:
(1) 31 October 1974, 30 April 1975} and 30 September
1975 - submit progress reports on status of the
research and development program.
Progress reports regarding similar installations at other steel
plants were submitted on 30 October 1974 and 30 April 1975.
The Company is considering two alternative processes for desulfur-
ization, the Firma Karl Still and the Sulfiban Process, but a decision
has not been made to date.
While the Consent Order requires a final compliance date of 31
December 1977, the Steelmaking Modernization Program is suggesting 30
June 1981 for achieving compliance with SBAPCD Regulation IV, Rule 62.
DISCUSSION
Review of the Consent Order documentation, coupled with in-plant
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63
observations and VEO's, indicates that the Kaiser Steel Corporation
has made progress in air pollution control at the plant but still
has much to accomplish.
Analysis of the documentation required by the Consent Order in-
dicated that in some cases the Corporation submitted plans which they
did not follow. Thus, they submitted plans for (1) modifying the ESP1 s
on the open hearth furnaces, which they now propose to eliminate through
the Steelmaking Modernization Program, and (2) for a scrap metal cut-
ting building which they now plan to negate by use of machine cutting
torches which may or may not be effective.
A major problem appears to be that those certifying compliance
at Corporate headquarters are not those complying at Fontana. Thus,
compliance will be elusive and certification meaningless unless:
(1) plant employees in the shops comprising the steel making operation
are aware of the necessity for following O&M procedures, submitted as
a requirement of the Consent Order to control air pollution, and (2)
plant employees are advised of Corporate determination to comply with
Federal, State and local requirements. For example, O&M programs
have been submitted for coke oven Batteries "C" through "G"
(Appendix B, Part B) and "A" and "B" (Appendix B, Part C); yet the
field study documented numerous door leaks, including 29 VEO's that
recorded excessive emissions from doors and two VEO's that showed
excessive emissions from standpipes. If observations had been made
from top-side, additional excessive emissions from standpipes would
have been documented.
Without rigid requirements for the O&M necessary to bring in-
dividual portions of the coke oven door emission problem under con-
trol, it will certainly be impossible to bring combined emissions
from pushing and charging operations, door and standpipes into
compliance. Thus, even if pushing and charging operations can be
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modified to curtail emissions to within the 3-minute limitation,
leaking standpipes, doors or charge ports (operating and maintenance
problems) will negate this effort.
The survey also indicated air pollution contributions from fa-
cilities that were not covered by the Consent Order. Most of these
could be improved by additional instrumentation or by better O&M pro-
cedures, but some need air pollution control equipment or a combination
of these methods. Excessive visible emissions were recorded from blast
furnace cast house roofs and stove draft stacks (8), from the ESP stacks
of the basic oxygen steel furnaces (9), and from the soaking pits (8).
Only those indicated earlier were reported as emergencies, so others
msut be considered as routine.
In the case of the basic oxygen steel furnace, it would appear
that with three ESP's available and only two furnaces operating, gen-
erally not concurrently, that sufficient ESP capacity is available to
control these emissions.
Since soaking pit stacks are probably not visible from within the
facility, smoke detectors with alarms could indicate when fuel mixtures
must be adjusted. This approach has been used successfully at other
locations at the plant.
In the absence of Federal scrutiny in these areas, Complaint
Citations issued by the SBAPCD against those sources not covered by
APCD variances inay provide some impetus for control. However, with
nominal assessments this may not be the case.
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APPENDIX
VISIBLE EMISSION OBSERVATION RECORD
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VISIBLE EMIS?Tf)1 OBSERVATION RECOPD
Company
Date
Time Start
Time Fir^t Sighted Plume
Time Stop
Air Temperature
Wind Speed
Sky Condition
Relative Humidity
Wind Direction
Background
Plume Characteristics
Color
Stack Height
(ft)
Continuous: ( ) yes
Dispersion Description
Observer location: (ft)
( ) no
of stack
Sun location
( ) Back of Observer
( ) Right Shoulder
Emission Point
( ) Left Shoulder
( ) Other
pi"
0
j 15 | 30
TT
.02
03
!' S 1
!04
( f
05
b6
07
P8
P9
P-°
u
14
15
16
\
|
18
|
19
|
—
20
s
Min
21
22 ""
23"
0
IS
30
45
24
25
26
27
¦ ¦
28
29
30
31
32
33
34"
1
!
1
35
36 ~
37
38
39
40
Min
0
15
30
45
41
42
43
44
45
46
47
48
49
50
31
52
|
53
|
54
|
55
j
56
57
58
59
60
NOTES:
Inspector Date
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MAP
i
i
i
Symbols
Sun = j$f Point where plume observed =
Plume direction = —y~ Observer =
Water Vapor Condensate
Photographs: S&A File { ) Enclosed ( ) None ( )
Comments
Signature
Date
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