v&m star expansion project psd/pti application:...

Prepared for: V&M Star Youngstown, OH

V&M Star Expansion Project PSD/PTI Application Tab B BACT Analysis Prepared by CH2MHILL

ENSR Corporation October 2008 Document No.: 10513-014-0550

Prepared for: V&M Star Youngstown, OH

PSD Permit Application for Proposed Expansion of V&M Star in Youngstown, OH Tab B BACT Analysis Prepared by: Robert V. Chalfant, P.E. CH2M HILL HILL Lockwood Greene Approved by: Jeff Bindas V & M Star Ohio

V&M Tab B-BACT Analysis rev0.doc October 2008 i

Contents

1.0 INTRODUCTION..........................................................................................................................................1

2.0 PSD BACT REQUIREMENTS ....................................................................................................................2 2.1 Electric Arc Furnace (EAF) and Ladle Metallurgy Furnace (LMF) ...............................................4

2.1.1 Particulate Matter Control ......................................................................................................6 2.1.2 CO Control .............................................................................................................................9 2.1.3 NOx Control .........................................................................................................................12 2.1.4 SOx Control..........................................................................................................................14

2.2 LMF Alloy, Additives, and Flux Handling System .......................................................................16 2.3 Continuous Caster ..........................................................................................................................17

2.3.1 Particulate Matter Control ....................................................................................................17 2.3.2 NOx Control .........................................................................................................................17

2.4 Vacuum Tank Degasser (VTD) .......................................................................................................17 2.4.1 Particulate Matter Control ....................................................................................................17 2.4.2 CO Control ...........................................................................................................................18

2.5 VTD Boilers ......................................................................................................................................18 2.5.1 NOx Control .........................................................................................................................18 2.5.2 PM10, CO, SO2, AND VOC Control ...................................................................................18

2.6 MPM Billet Reheat Furnace (Existing) ..........................................................................................19 2.7 FQM Billet Rotary Hearth Reheat Furnace (New) ........................................................................19

2.7.1 Particulate Matter Control ....................................................................................................19 2.7.2 CO, VOC and SO2 Control ..................................................................................................20 2.7.3 NOx Control .........................................................................................................................20

2.8 FQM Pipe Intermediate Reheat Furnace (New)............................................................................21 2.8.1 Particulate Matter Control ....................................................................................................21 2.8.2 CO, VOC and SO2 Control ..................................................................................................22 2.8.3 NOx Control .........................................................................................................................22

2.9 Mandrel Furnace ..............................................................................................................................22 2.10 Austenitizing Furnace #1 and #2 ...................................................................................................23

2.10.1 Particulate Matter Control ....................................................................................................23 2.10.2 CO, VOC and SO2 Control ..................................................................................................23 2.10.3 NOx Control .........................................................................................................................23

2.11 Tempering Furnace #1 and #2 .......................................................................................................24 2.11.1 Particulate Matter Control ....................................................................................................24 2.11.2 CO, VOC and SO2 Control ..................................................................................................25 2.11.3 NOx Control .........................................................................................................................25

2.12 FQM Pipe Mill Scrubber ..................................................................................................................26 2.12.1 Particulate Matter Control ....................................................................................................26

2.13 Abrasives Manufacturing Raw Materials Handling .....................................................................26

V&M Tab B-BACT Analysis rev0.doc October 2008 i

2.14 Abrasives Melting Furnace.............................................................................................................27 2.14.1 NOx Control .........................................................................................................................27 2.14.2 PM10....................................................................................................................................27 2.14.3 SO2 ......................................................................................................................................27 2.14.4 CO AND VOC ......................................................................................................................27

2.15 Abrasives Finished Product Handling ..........................................................................................28 2.15.1 PM10 Control .......................................................................................................................28

2.16 Cooling Towers................................................................................................................................28 2.17 Roadways .........................................................................................................................................28

V&M Tab B-BACT Analysis rev0.doc October 2008 ii

V&M Tab B-BACT Analysis rev0.doc October 2008 iii

Tables Table 1-1 V&M Star Source Emission Factors and Rate Calculations

Table 1-2 V&M Star Baseline Emission Rate Calculations

Table 1-3 V&M Star Annual Emission Rates Summary

Table 2-1 BACT Applicability

Table 2-2 Comparison of EAF/LMF Meltshop Exhaust with Industrial and Utility Coal Fired Steam Generators

Table 2-3 Technical Feasibility of EAF/LMF PE/PM10 Control Techniques

Table 2-4 Range of EAF/LMF Filterable PE/PM10 Emission Factors Determined BACT

Table 2-5 Technical Feasibility of EAF/LMF CO Control Techniques

Table 2-6 Range of EAF/LMF CO Emission Factors Determined BACT

Table 2-7 Technical Feasibility of EAF/LMF NOx Control Techniques

Table 2-8 Range of EAF/LMF NOx Emission Factors Determined BACT

Table 2-9 Technical Feasibility of EAF/LMF SO2 Control Techniques

Table 2-10 Range of EAF/LMF SO2 Emission Factors Determined BACT

Table 2-11 Range of Reheat Furnace NOx Emission Factors Determined BACT

Table 2-12 Range of Annealing Furnace NOx Emission Factors Determined BACT

Table 2-13 VTD Boiler NOx Reduction Cost Effectiveness Analysis

Table 2-14 New FQM Seamless Pipe Mill Furnaces

1.0 INTRODUCTION V & M Star is a manufacturer of seamless steel tubes that are mainly used in the oil and gas industry and that are referred to as oil country tubular goods (OCTG). The steel and pipe making operations based in Youngstown, Ohio, utilize the latest technology in electric arc furnace (EAF) steelmaking and retained mandrel mill pipe production. The planned modifications to the facility will upgrade the EAF steelmaking, hot metal refining, and billet casting operations, and may include a new Fine Quality Mill (FQM) pipe mill to expand production capacity. .

The meltshop’s current production capacity is about 710,000 liquid steel tons per year, although the PTI issued in September 2008 approved modifications to increase production to 830,000 tons per year. The actual 24-month annual average steel production through June 2006, prior to the last PSD application, was determined to be 667,344 tons per year and was selected as the baseline actual emissions period for the meltshop and pipe mill sources. Because the newly planned modifications are contemporaneous with and expand on the modifications just approved, the same baseline period is used. The existing V & M Star facility is a major stationary source and the proposed project modifications constitute a major modification subject to prevention of significant deterioration (PSD) requirements in accordance with Ohio EPA Rule 3745-31-15 and 40 CFR 52.21 incorporated by reference. Control technology review is applicable for each regulated PSD pollutant for which the modification would result in a significant emissions increase at the source. Section 2 addresses the best available control technology (BACT) analysis for new source review (NSR) regulated pollutants.

Additionally, Ohio EPA rule 3745-31-05 specifies criteria for issuance of a state permit-to-install and requires that the source employ best available technology (BAT) in accordance with Ohio administrative requirements. This requirement is addressed by the BACT demonstrations.

Table 1-1 V & M Star Source Emission Factors and Rate Calculations at the end of this BACT section provides the projected modified facility unit emission factors, production bases, and emission rate calculations for projected potential emissions. Table 1-2 V & M Star Baseline Emission Rate Calculations provides past actual emissions. Table 1-3 V & M Star Annual Emission Rates Summary provides pollutant emission rates summary by unit for the projected and baseline emissions, net change for each source, and the site net change in emissions.

V&M Tab B-BACT Analysis rev0.doc October 2008 1

2.0 PSD BACT REQUIREMENTS For the PSD regulated pollutants having a significant emissions increase and significant net emission increase, best available control technology (BACT) is applicable to the modification project for that pollutant, and BACT shall be applied to each proposed new or modified emissions unit at which a net emissions increase in the air pollutant would occur as a result of a physical change or change in the method of operation in the emissions unit. BACT is defined as:

"...an emission limitation based on the maximum degree of reduction for each pollutant subject to regulation under the Clean Air Act which would be emitted from any proposed major facility or major modification which the Administrator (or the permitting authority), on a case-by-case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such facility through application of production processes or available methods...for control of such pollutant."

To determine BACT, the multi-step "top down" analysis procedure is used for each process.

1. The first step identifies available control technology options with a "practical potential for application to the source".

2. Next, technical impediments that would preclude successful use on the emission unit are addressed, and the technically infeasible options are eliminated. Control technologies installed and operating successfully on the type of source under review are considered technically feasible. A technology may be technically feasible, if it has been applied to source categories other than the source under consideration and if the potential for its application exists, i.e., it is transferable. An undemonstrated control technology is technically feasible only if it is available and applicable. Technical judgment is exercised in determining feasibility and the reasons for considering a control option technically infeasible are explained.

3. Next, the feasible control alternatives are ranked by their control effectiveness, with the most effective control alternative at the top.

4. If the top control technology option is not chosen, an evaluation considers each control alternative's energy, environmental, and economic impacts.

5. The final BACT determination is based on the selection of the most effective control option not eliminated in the control impacts analysis.

This BACT demonstration describes emission limitations, production methods, and control technologies considered BACT within the industry. Table 1-1 calculations of source emissions use the planned modified facility production parameters and the unit source emission factors and control performance proposed as BACT in this technology review and application, Table 1-2 identifies the baseline emissions, and Table 1-3 identifies the unit source emissions change. The following Table 2-1 summarizes the project net emission increases above the baseline actual emissions, confirms BACT pollutant applicability, and identifies the BACT review applicability for each new or modified emissions unit.



Pollutant Emission Increases (Tons/Year) Project BACT Applicability New or

Mod PM10 CO NOx SO2 VOC Pb

Project Emission Increase 91 1,737 341 100 79 0.55

PSD Significant 15 100 40 40 40 0.6

BACT Required Yes Yes Yes Yes Yes No

Unit BACT Applicability PM10 CO NOx SO2 VOC Pb

EAF/LMF X Yes Yes Yes Yes Yes No

LMF Alloy, Additive, Flux Handling X Yes

Caster X Yes Yes

VTD X Yes Yes

VTD Boiler(s) X Yes Yes Yes Yes Yes

MPM Operations (determined BACT by September 2008 PSD PTI)

FQM Billet Rotary Hearth Furnace X Yes Yes Yes Yes Yes

FQM Pipe Intermediate Furnace X Yes Yes Yes Yes Yes

FQM Mandrel Furnace X Yes Yes Yes Yes Yes

FQM Pipe Mill Scrubber X Yes

FQM Austenitizing Furnace 1 & 2 X Yes Yes Yes Yes Yes

FQM Tempering Furnace 1 & 2 X Yes Yes Yes Yes Yes

G-S Raw Materials Handling X Yes

G-S Melter Furnace X Yes Yes Yes Yes Yes

G-S Finished Product Handling X Yes

G-S Fore Hearth Furnace X Yes Yes Yes Yes Yes

Additives material handling X Yes

Cooling Towers X Yes

Standby/Emergency Generators X Yes Yes Yes Yes Yes

Roadways X Yes

The proposed V&M Star modifications result in net pollutant emission increases exceeding the PSD significant thresholds for PM10, CO and NOx, SO2, and VOC requiring BACT for these pollutants.

The following sections address the technically feasible control alternatives for each of the emission units and pollutants subject to PSD review. If necessary, a top-down BACT impact analysis is prepared for evaluation of available alternatives.

With the hierarchy of control alternatives, the following emissions data are provided:

• Emissions performance • Expected emissions rate, tons/year • Expected emissions reduction from baseline, tons/year


If an economic impact analysis of the control alternatives is required, it should address the following information:

• Installed capital cost, $ • Total annualized cost, $/year • Cost effectiveness from baseline, $/ton of emission removed • Incremental cost effectiveness over the proposed alternative, $/ton of emission removed

Cost data regarding less effective control options are not provided when the top control technique alternative is proposed. Also, cost data is not given for the baseline condition, since it is the minimum design standard and basis for the vendor analysis of technology availability.

A collateral impacts analysis may be performed including energy impacts in the form of increased or decreased energy usage over baseline and environmental impacts in the form of new or increased air pollutants other than those being controlled, increased usage or contamination of water, new waste products, etc.

The feasible technologies are ranked in the control alternative hierarchy and the most effective control alternative not eliminated by environmental, energy or economic impacts should meet the criteria for BACT.

In no case are the BACT technologies less stringent than the technology identified in Standards of Performance for New Stationary Sources or any other applicable standard. 40 CFR 60 Subpart AAa: Electric Arc Furnaces in Steel Plants is the only applicable source specific standard. However, this EAF NSPS addresses only particulate and imposes no standards for the gaseous pollutants, which are also the subject of this BACT analysis.

2.1 Electric Arc Furnace (EAF) and Ladle Metallurgy Furnace (LMF)

The meltshop electric arc furnace (EAF) and the ladle metallurgy furnace (LMF) are the core processes of the steel mill and the major pollutant emission sources. Emissions from these existing sources are captured by direct furnace evacuation, hood exhausts, and roof area exhausts, which are combined and directed to a common baghouse particulate emission control system.

The Company is proposing to upgrade the current EAF with modifications to the furnace capacity, oxy-fuel burners, carbon and oxygen injection systems, and transformer to increase hourly and annual production capacities to 172 tons/hour and 1,400,000 tons/year. Under this proposed project, the existing LMF will be abandoned and replaced with a new LMF to be located in a new hot metal processing facility. The emission capture exhausts from the EAF and LMF will continue to be controlled by a common baghouse.

The first step of meltshop BACT review is the identification of available control options with a practical potential for application to the source. Control may be passive process and practice controls or add-on emission control devices. Sources of reference for control alternative consideration may include applicable regulations, EPA’s RBLC, control technology vendors, technical reports, control technologies applied successfully to similar gas streams in other industry sources, etc.

The applicable NSPS for steel manufacturing, Subpart AAa, regulates particulate matter and visible emissions from the EAF control device, dust-handling system, and the shop building housing the EAF equipment, but does not regulate gaseous emissions. The only mass emission limit is the NSPS, which limits the EAF particulate emission control device to an exit filterable particulate matter concentration of 0.0052 gr/dscf. The RACT/BACT/LAER Clearinghouse identifies various emission performance levels as BACT for particulate and gaseous pollutant emissions, but does not identify any add-on gaseous emission control devices installed on conventional EAFs, other than that provided by the direct-shell evacuation control system (DEC system) that exhausts the furnace and ducts emissions to the particulate control device.


Since add-on gaseous emission controls do not appear to have been applied to EAF or similar industry sources, we may look at other controlled operations for potential technology transfer. Gaseous NOx, CO and SO2 emissions control are most typically addressed for combustion sources. The following Table 2-2 provides a Comparison of EAF/LMF Meltshop Exhaust with Industrial and Utility Coal Fired Steam Generators.


Exhaust EAF/LMF Meltshop Industrial/cogen Utility with equivalent

Parameter Baghouse Spreader Stoker scfm exhaust flow total flow uncontrolled PC, dry bot,wall fired

MMBTU/hr 250 4,250

Scfm 980,000 51,000 980,000 avg. temp 186 350 300 temp range 100-300 avg. acfm 1,200,000 78,200 1,400,000 acfm range PM lb/hr 6,000 660 12,600 PM gr/scf 0.8 1.5 1.5

Controlled PM NSPS limits 0.0052 gr/scf 0.05 lb/MMBtu 0.03 lb/MMBtu (existing) gr/scf 0.0052 0.029 ~0.017gr/scf

0.015 lb/MMBtu (new) ~0.009 gr/scf

NOx lb/hr <69 110 2,048 NOx ppm avg. <10 300/~50 w/SCR 300 ppm range 0 - 30 Estimate basis total 0.40 lb/ton

AP-42: 11 lb/ton coal


SO2 lb/hr <43 400 6,800 SO2 ppm avg. <5 780 / 78 controlled 700 ppm range 0 - 10 Estimate basis total 0.25 lb/ton

1%S fuel

1%S fuel

CO lb/hr <688 48 85 CO ppm avg. <160 216 20 ppm range 0 - 250 Estimate basis <4.0 lb/ton


AP-42: 0.5 lb/ton coal

The EAF exhaust conditions and emission loadings are compared with those for a 250 MMBtu/hr spreader stoker coal fired industrial boiler and a utility size boiler (PC, dry bottom, wall-fired, bituminous, post-NSPS installation). Emissions for the large PC boiler are back-calculated for an approximate exhaust flow rate of 980,000 scfm, similar to the EAF/LMF baghouse flow. This provides interesting comparisons. The Subpart AAa NSPS particulate emission limit of 0.0052 gr/dscf for the EAF provides for substantially lower outlet grain loading than either of the boiler lb/MMBtu standards or the Subpart Da 99% reduction requirement. The estimated maximum average EAF baghouse NOx concentration at less than 10 ppm is about 3% of the uncontrolled boiler values, and even the Subpart Da emission reduction requirement results in a controlled


NOx concentration limit that is almost a factor of 10 above the uncontrolled EAF baghouse value. The uncontrolled sulfur dioxide average emission concentration of 5 ppm for the EAF baghouse compares to uncontrolled boiler concentrations of 700 ppm with 1% low sulfur coal and controlled concentrations greater than 50 ppm after application of BACT SO2 reduction measures. The estimated maximum EAF meltshop CO emission factor results in a calculated average CO concentration of around 160 ppm, which is midway between the AP-42 based emission estimates for the spreader stoker boiler and the large PC boiler. These comparisons indicate that the EAF baghouse exhaust stream is probably not a good candidate for transfer of gaseous emission control technologies often applied to large combustion sources.

The following discussions address technical feasibility and rank the control alternatives having potential for applicability for the steel meltshop and include justifications for the proposed allowable emission rates and recommendations for determination of BACT.

2.1.1 Particulate Matter Control

Particulate matter emissions are generated at the EAF during charging, meltdown, refining, slagging, and tapping. The majority of the emissions are captured by the direct-shell evacuation control system (DEC). The EAF canopy hood and local hoods capture emissions from charging, slagging and tapping. All particulate capture exhausts are combined for control by the common meltshop baghouse system. The LMF utilizes a water cooled roof with a close fitting hood around the electrode ports to capture emissions from this process. For the facility modification to increase steel production, it is planned that the new baghouse being installed under the recent PTI will be increased from 1,000,000 acfm to 1,200,000 design flow to maintain and improve particulate capture and control.

Depending upon the nature of a particulate emission process, high efficiency particulate emission control might be provided by the following: (1) electrostatic precipitator (ESP), (2) high efficiency cyclones, (3) high energy scrubber, or (4) fabric filter baghouse.

The baghouse control device has been found to provide the highest control efficiency for EAF particulate emissions. Wet emission control systems are not acceptable at V&M Star because of the necessity to provide the captured EAF dust in a dry condition to the reclamation facility. For these reasons the baghouse control device is considered the only feasible control alternative.

BACT must establish a level of control performance. A control device outlet performance of 0.0052 gr/dscf is the NSPS requirement and is considered the BACT floor. Higher levels of emission performance may be attained with design, operation and maintenance enhancements. A higher level of control at or around 0.0032 gr/dscf has often been designated as BACT in recent PSD permits. The highest level of control identified to have been imposed as a BACT limit for an EAF is 0.0018 gr/dscf filterable particulate. The September 2008 PSD PTI approved 0.0018 gr/dscf as BACT.

The following Table 2-3 tabulates the technical feasibility of particulate matter emission control techniques.



Control Alternative Technology Feasibility

EAF/LMF Process

DEC Flow Combined

DEC/Canopy Yes No Yes No Yes No Passive Process/Practice EAF with DEC and canopy hood X Add-on Control Baghouse, 0.0018 gr/dscf X Baghouse, 0.0032 gr/dscf X Baghouse, 0.0052 gr/dscf X Electrostatic precipitator (ESP) X X High Efficiency Scrubber X X High Efficiency Cyclones X X

Particulate Emission Review EAF

For capture and control of EAF particulate emissions, V&M Star uses the most effective EAF shop air pollution control configuration, which consists of direct-shell evacuation control and canopy hood with a near closed meltshop roof configuration and a fabric filter control device.

Fabric filters have advantages over other control devices in that they use less energy for equivalent outlet concentrations, are efficient collectors of very fine emissions, are tolerant of fluctuations in inlet particle size distribution, and collect dust in dry form, which is easier to handle and is a requirement of the reclamation facilities treating the dust.

Electrostatic precipitators, cyclones, and scrubbers are not installed on electric arc furnace operations because they generally do not meet BACT or the Subpart AAa New Source Performance Standard of 0.0052 grains per dry standard cubic foot. EAF exhaust particulate emissions are mostly small particles with a high metal content. Electrostatic precipitators can not efficiently collect particles with a high metal content, have a high initial cost, and require precise temperature and moisture control. Cyclones alone are not effective enough on small particles. High energy scrubbers are not considered for this application because they have high energy requirements, reduce operating flexibility and generate large quantities of sludge resulting in problems associated with sludge handling, dewatering and disposal.

LMF

The ladle metallurgy furnace (LMF) further refines the steel produced by the EAF by adjusting and controlling the chemical composition of the steel and maintains with small electrodes proper temperature for casting. Emissions generated in the LMF are contained and captured by the LMF roof integral side draft hood and are exhausted to the EAF meltshop baghouse along with the emissions from the EAF. The common baghouse is sized to handle the exhaust flow and particulate emissions from the LMF. The use of a fume hood and baghouse is considered as BACT for this application.

Analysis of Control Technologies

Evaluation of control device applicability determined that equipment other than the fabric filter baghouse is either not applicable or provides no better performance. Therefore, the analysis of particulate matter control technologies is a determination of the outlet emission performance level that should be considered BACT for the V & M Star facility.


Analysis of Alternative Baghouse Particulate Matter Performance Levels

In reviewing recent BACT determinations and permits we find a wide range in the approved outlet concentration from the NSPS limit of 0.0052 gr/dscf at the high end down to the most stringent limit of 0.0018 gr/dscf. The major grouping is right in the middle at 0.0032 to 0.0035 gr/dscf. The facilities permitted at 0.0018 gr/dscf typically did not go through a comparative cost analysis, but proposed or accepted that limit as BACT in an initial permit.

Recent BACT determinations can be set at three performance levels: 0.0018, ~0.0032, and 0.0052 gr/dscf filterable particulate. Each of these is a very high level of performance, nearing total control, as is indicated below:

Outlet Reduction Loading Performance (gr/dscf) (%) 0.0018 99.7 0.0032 99.5 0.0052 99.1

Table 2-4 lists emission factors from the RBLC determined to be BACT for similar sources.


EAF (& LMF) Filterable PE/PM10 (gr/dscf)

V&M Star predicted performance ≤0.0018

MacSteel, MI 0.0052

Beta Steel, IN 0.0052

Corus Tuscaloosa, AL 0.0035

Ipsco, AL 0.0033

Nucor, AL 0.0032

Republic Technologies, OH 0.0032

Qualitech, IN 0.0032

Nucor, TN 0.0020

Nucor, IN 0.0018

Nucor Tuscaloosa, AL 0.0018

MacSteel, AR 0.0018

CF&I, CO 0.0018

Nucor, NC 0.0018

Detailed cost analyses have demonstrated that the more conservative design costs and additional maintenance activities to maintain 0.0018 gr/dscf performance can have a high cost relative to the benefit and the incremental cost effectiveness may exceed the normal range of acceptable BACT costs under PSD review procedures. However, with its aggressive maintenance program, V&M Star has been able to maintain its old baghouse performance at or below 0.0018 gr/dscf, and V&M Star believes that it can continue to meet this performance level with the planned upgraded baghouse system. For the modified EAF


and LRS process and baghouse emission control, 0.0018 gr/dscf filterable particulate is proposed as the BACT limitation for particulate emissions. One concern is that this is so close to the ultimate performance capability that there are no operating indicators that will predict performance to this level, and V & M Star proposes that should a periodic test determine emissions above this level but below the NSPS limit that it perform appropriate maintenance and retest to demonstrate emissions are maintained at BACT and the initial periodic test not be considered a violation.

Compliance with the particulate emission limitation shall be determined by emission testing using 40 CRF Part 60, Appendix A, Method 5 or 5D, consistent with the requirements of the applicable NSPS, 40 CFR Part 60, Subpart AAa.

Recommendation for Determination of BACT for PM

The proposed EAF meltshop baghouse performance level of 0.0018 gr/dscf is consistent with the highest performance level and most stringent PSD BACT determinations. At his high level of performance there is very little large particulate passing the filter material, we are projecting that the total filterable particulate (PE) is equal to the PM10 and PM2.5 emission. The calculated maximum emission rate is 15.12 pounds per hour at the design baghouse flow rate of 980,000 dscfm. The potential annual PE/PM10/PM2.5 is 66.2 tons per year at 8,760 hours per year, and the projected actual emission is 62.05 tons per year based on the scheduled available meltshop operating hours, 8,208 hours per year.

It is our determination that the baghouse controlled EAF and LMF meltshop with an outlet PE/PM10/PM2.5 emission performance of 0.0018 gr/dscf filterable particulate is BACT for the V&M Star facility. This is consistent with the September 2008 PSD PTI BACT determination for the new EAF/LMF baghouse.

2.1.2 CO Control

There is no applicable NSPS or other source specific standard establishing CO performance criteria. A review of the RACT/BACT/LAER Clearinghouse indicates that no add-on control device has ever been required for EAF or LMF CO control. However, the goal of this BACT analysis is to address all control technologies considered to have potential applicability. Multiple control systems have been investigated which would oxidize the CO to CO2 or otherwise provide for reduced CO emissions. The add-on control systems are all thermal, end of pipe processes. They are divided into two categories. The first category treats the entire main baghouse flow from all sources in the meltshop including the EAF, while the second category treats only the DEC gas flow from the EAF.

A Catalytic Oxidizer achieves control of CO by oxidation to carbon dioxide, but at a much lower temperature than a thermal oxidizer. The catalyst may be a precious metal or base metal compound that is applied to a structured or packed media material. The catalyst is mounted in a gas stream that is heated to the catalytic oxidation temperature for the contaminant. An engineered catalytic oxidizer may have heat recovery. Catalyst materials are very sensitive to blinding and poisoning of the catalyst sites by metals and to overheating, and care must be taken with application of the technology.

Vendor supplied thermal oxidation equipment is typically intended and designed for destruction of evaporated VOC solvents from coating and chemical process systems. For this analysis it is assumed that thermal oxidation equipment might be available for this CO oxidation application. Thermal oxidation systems may be designed in several configurations with and without heat recovery equipment. A Recuperative Thermal Oxidizer uses a heat exchanger to reclaim heat and a burner to boost gas temperature for CO reduction. A Regenerative Thermal Oxidizer uses a switched bed heat exchanger to reclaim more heat than a recuperative TO and uses a burner to boost gas temperature for CO reduction. A Direct Flame Thermal Oxidizer uses a large burner for CO reduction with no heat reclaim.

Since none of the above control devices have ever been used for EAF CO emission control, each is evaluated for its technology transfer potential.


Table 2-5 presents alternative process technologies and technology modifications considered. The conventional EAF with a DEC providing secondary post combustion of CO emissions exiting the furnace is considered baseline and is used for comparing alternatives. Per BACT guidance, it is termed the “baseline alternative” and is a realistic upper bound of emissions for the source.

Catalytic Oxidation for CO Control

Catalytic oxidation is used for CO oxidation on some process and combustion operations, but has never been applied to steelmaking furnaces, and it is generally recognized by catalyst vendors contacted as being an inappropriate application. For another study, a specification was prepared based on high efficiency filtration of the EAF particulate ahead of the catalyst, and major catalytic oxidizer equipment suppliers were requested to propose equipment. All suppliers declined to propose catalytic oxidation, indicating that it is not an appropriate technology for EAF exhaust gas control.

Based on the above, catalytic oxidation is not available and is not a feasible technology for CO control.

Main Baghouse DFTO (Direct Fired Thermal Oxidizer) for CO Control

Vendors requested to propose CO control for a similar study declined to propose direct fired thermal oxidation or regenerative or recuperative thermal oxidation for the main baghouse exhaust. None were aware of a thermal oxidizer of this size ever being constructed for a CO source and found the concept technically and economically infeasible on a practical basis. Based on calculations, this type of direct fired thermal oxidizer would require over 1,200 MMBtu/hr heat input, costing over $60 million annually in natural gas fuel alone. As an environmental impact issue, direct fired thermal oxidation of the main baghouse exhaust would generate about 700 lb of CO2 from added fuel for each 1 lb of process CO potentially oxidized. It is also questionable whether the necessary natural gas supply would be available for this use.

It is determined that add-on thermal oxidation of the main baghouse exhaust is not an available or feasible technology for EAF CO control.

The conventional EAF design with DEC provides for inherent good destruction of CO emissions leaving the furnace, and current emissions are low. The projected maximum average emission for the combined EAF and LMF baghouse is 4.0 lb/ton, which is consistent with BACT determinations. Table 2-5 tabulates technical feasibility of CO control techniques.




EAF/LMF Process

DEC Flow BH Flow

Yes No Yes No Yes No Passive Process/Practice EAF with DEC X Add-on Control Catalytic oxidation X X Thermal Oxidation X X

Analysis of DEC Controlled EAF and LMF Carbon Monoxide Performance

Modern conventional high energy electric arc furnaces follow similar practices of high carbon feed with resulting CO generation in the steel and slag to mix the steel, remove impurities, and maintain the foamy slag. The concentrations of CO and CO2 in the furnace head space can both be high in the range of 12% to 14%. By nature of the conventional furnace design with a direct evacuation control (DEC) system to capture and direct particulate matter and furnace gases to the particulate control device, the furnace system provides for good thermal oxidation of the CO to carbon dioxide. The air gap at the DEC interface between the fixed duct and movable duct mounted on the furnace roof allows necessary combustion air to enter the DEC and mix with the hot furnace gases and CO, providing oxygen for combustion/oxidation of the CO. The CO combustion further raises the exhaust gas temperature in the duct.

Testing of DEC controlled EAF sources finds that emission recordings during melting have CO concentration spikes with reasonably well controlled emissions in between. The CO spikes during the scrap melting may result from scrap cave-ins causing high variation in carbon boil rates, furnace pressure changes and other normal process variations, which rapidly increase the discharge of carbon dioxide and CO from the furnace. A design and operating practice of an EAF is optimal combustion control of the CO emissions through the DEC without causing unnecessary drafting of the furnace, which could adversely affect NOx emissions by pulling excess air with nitrogen through the furnace. Allowing the furnace to operate more positive can discharge more furnace gases into the shop, resulting in more quenched CO being captured by the canopy hood and higher overall CO emissions, and a balance is sought for optimum control of CO and NOx.

It is also observed from testing that there is an inverse correlation between CO and NOx. When CO concentration is peaking the NOx concentration is low, and NOx often appears to peak with a drop in CO concentration. This tends to indicate that that the CO combustion in the DEC is not temperature limited, but is influenced by oxygen availability. While it may be possible to adjust the gap for maximum oxygen availability to keep CO combustion high, this would probably have an adverse impact on NOx because of the higher temperature and availability of oxygen and nitrogen from the air during the times of high CO evolution from the EAF. Because NOx is the more environmentally critical pollutant, it is recommended that there be flexibility with regard to the CO emission in order to provide more targeted optimum NOx emission performance. Alternating current (AC) furnaces with DEC systems have tested and permitted in the range from below 2 lb/ton to over 7 lb/ton of steel. Requiring CO to be maintained at the lower end of the performance capability range would result in higher NOx emissions.

It is believed that the combined EAF and LMF emission of CO should average at or below the current combined limit of 4.0 lb/ton, which was determined by OEPA to be BACT in the September 2008 PSD PTI. This performance is consistent with similar equipment at other steel mills, and there is no reason to modify this limit. Table 2-6 lists CO emission factors identified in the RBLC as determined to be BACT for similar sources.



EAF (& LMF) CO (lb/ton)


Beta Steel, IN 6.5

Ameristeel, NC 6.0

MacSteel, MI 5.0

Hoeganaes, TN 5.0

MacSteel, AR 4.9

Nucor, Nebraska 4.7

Qualitech, IN 4.7

Koppel Steel, PA 4.5

Nucor, TN 4.0

Republic Technologies, OH 4.0

Nucor Jewett, TX 2.24

Nucor, NC 2.3

Nucor Tuscaloosa, AL 2.2

CF&I, CO 2.0

Nucor, IN 2.0

Recommendation for Determination of BACT for CO Emission Control

As noted in the top-down analysis, there are no cost effective add-on CO emission control techniques for a conventional EAF or LMF.

Based on extensive facility studies, it is our determination that the EAF with DEC CO combustion and uncontrolled LMF emission estimates are consistent with control technology chosen as BACT for similar PSD permitted facilities.

Based on experience and knowledge of engineering design and permitting for the steel making industry, it is determined that the uncontrolled EAF and LMF operation with a combined CO emission factor of 4.0 lb/ton is BACT for this EAF facility. The peak hourly average CO emission rate at the anticipated maximum production rate of 172 tons per hour is 688 pounds of CO per hour. The maximum projected actual emission at 1,400,000 tons of steel per year is 2,800 tons of CO per year from the EAF and LMF combined. This is consistent with the September 2008 PSD PTI BACT determination.

2.1.3 NOx Control

There is no applicable NSPS or other source specific standard establishing NOx performance criteria. A review of the RACT/BACT/LAER Clearinghouse indicates that no add-on control device has ever been required for EAF NOx control. However, the goal of this BACT analysis is to address all control technologies considered to have potential applicability. Multiple control systems have been investigated which would reduced NOx emissions. The add-on control systems are all NOx gaseous “reduction” techniques more typically applicable to large combustion processes.


The following table addresses technical feasibility of NOx control techniques. Review of the RBLC and numerous investigations with steel process engineers and NOx control technology suppliers confirm that there are no applicable add-on control techniques. Applicable NOx mitigation techniques involve maintenance and operation of the furnace to minimize air intrusion and good carbon injection foamy slag practices and proper oxy-fuel burner operation.



EAF/LMS Process

DEC Flow BH Flow

Yes No Yes No Yes No Passive Process/Practice EAF with DEC & good furnace practice X Add-on Control Selective Catalytic Reduction (SCR) X X Selective Non-Catalytic Red. (SNCR) X X Flue Gas Recirculation (FGR) X X

Previous BACT determinations for NOx emissions found in the RBLC and elsewhere have identified a wide range of emission factor performance as the basis for emission rate limits. The following Table 2-8 lists a range of EAF meltshop BACT emission factors determined to represent NOx BACT for similar facilities.


EAFs (& LMF)

NOx Factor (lb/ton)


Nucor, Jewett, TX 0.90

Chaparral Virginia, Dinwiddie, VA. (Fuchs) (1998 PSD permit for 1.7 mm ton shop)

0.7 (higher limit applied for)

Nucor, Memphis, TN 0.7

Koppel Steel, PA 0.55

Gerdau AmeriSteel, Jackson, MI 0.54

Newport Steel, Newport, KY (RACT),

negotiable if not met 0.51

Gallatin Steel, KY (BACT) 0.51

Nucor, Crawfordsville, IN (BACT) 0.51

Nucor, Hertford County, NC (BACT) 0.51

Steel Dynamics, Butler, IN (BACT) 0.51

Qualitech, Pittsboro, IN (BACT) 0.50

Qualitech, Pittsboro, IN (BACT) 0.50


Beta Steel, IN (BACT) 0.45

AmeriSteel, Knoxville, TN 0.42

IPSCO, AL 0.40

Nucor, AL 0.40

Corus, AL 0.35

Nucor, TX 0.3

Recommendation for Determination of BACT for NOx Emission Control

Having determined that add-on NOx control technologies are not available or applicable to the meltshop exhaust, it is necessary to determine the appropriate emission performance basis for the BACT limit for the EAF and LRS process technology.

Periodic testing has confirmed compliance with the current NOx limit based on 0.4 lb/ton emission factor, however, some average test results have been close to the limit with higher short-term periods. Modern high energy EAFs are recognized to have higher emissions than older published emission factors would indicate, and the combined EAF/LMF NOx emission factor of 0.40 lb/ton at capacity is lower than the majority of recent PSD BACT determinations. There is some consideration that with the higher chemical energy input the emission factor should be increased. However, there is also consideration that the newer design JetBOx™ oxy-fuel burners should provide for higher chemical energy efficiency and better control of the burners and carbon injection with improved penetration below the slag line after meltdown. These advancements in the chemical energy systems and other maintenance improvements should provide for better operator control of the melting process with potential for NOx mitigation. V & M Star has determined that good furnace melting practices and proper operation of the EAF oxy-fuel burners is BACT for NOx emissions. It is proposed that the allowable NOx emissions for the increased steel production levels continue to be based on the current NOx emission factor of 0.40 lb/ton for a peak hourly average NOx emission rate of 68.8 pounds per hour and potential NOx emission of 280 tons per year from the EAF and LMF combined. There are no available add-on emission controls, and this process emission performance will be evaluated periodically to confirm compliance or evaluate whether it is necessary and justified to adjust the NOx emission factor. This is consistent with the September 2008 PSD PTI BACT determination.

2.1.4 SOx Control

Sulfur enters into the EAF/LMF process as a component of the scrap and scrap contaminants (oil, plastics, etc.) and as a component of the carbon charged with the scrap and injected into the furnace for steelmaking chemistry and the foamy slag process. The preponderance of the sulfur reacts in the molten metal and slag to form sulfides in the slag, principally in the form of calcium and magnesium sulfide reactants from the lime and magnesite (MgO) component additions. Some of the sulfur may react with injected oxygen or oxidize at the slag surface or in the furnace headspace to form SO2 and be exhausted from the furnace. Baghouse dust contains a significant portion of calcium products, and dust processors report that sulfur is contained in the dust as a non-combustible compound and most probably tied up with the calcium that remains with the iron rich residue after processing for recoverable metals. There is no NSPS requirement for sulfur compound emissions.

Traditional SO2 control alternatives for combustion and process operations include fuel or feed product modification or substitution and flue gas desulfurization technologies. Fuel substitution is not a beneficial option since the natural gas used at the oxy-fuel burners is essentially a sulfur free fuel.

Add-on flue gas SO2 controls are typically employed on medium to high sulfur content fuel combustion systems with uncontrolled exhaust gas SO2 concentrations of 500 to 2,000 ppm. The EAF/LMF exhaust SO2 concentration is highly variable, but should average below 5 ppm, and it is accepted that further attempts at control would be ineffective. It is the consensus of industry experts and equipment suppliers that add-on


control is practicably infeasible. Periodically costs for control systems have be evaluated under PSD reviews, and even with optimistic assumptions for emission reduction, cost effectiveness values have been the range of $15,000/ton and above, which exceeds reasonable BACT cost values and is considered cost prohibitive. The table below summarizes feasibility of SO2 control techniques.


Technology Feasibility EAF/LRS Process DEC/LRS Exhaust Control Alternative Yes No Yes No

Passive Process/Practice Scrap management X Ultra-low sulfur carbon/coke X

Add-on Control Wet scrubber system X Spray dryer absorber X

Sulfur dioxide emissions test results have been observed to creep upward in recent years, and V&M Star believes this is largely a result of a decrease in quality of available scrap and the increased demand for shipment of U.S. scrap to overseas users. It is found that more flux is necessary to clean the poorer quality, dirtier scrap. The increased demand is exemplified by the cost of scrap, which as recently as five years ago was in the $90 to $130 per ton range and is now in the mid-$200’s to mid-$400’s per ton range averaging near $300 per ton of scrap. To maintain average SO2 emissions below 0.25 lb/ton of steel V&M Star has been optimizing the scrap mix for lower SO2 emissions within economic reason. A scrap optimizing cost analysis determined that the cost premium for further reduction would probably exceed seven dollars per ton of scrap for the low SO2 scrap mix over the scrap mix that otherwise would be used, and cost effectiveness could approach $300,000/ton of SO2 emissions reduction.

A higher cost ultra-low sulfur pet coke with about 1% sulfur is sometimes blended for foamy slag carbon injection to minimize the potential emission from this source of sulfur. A lower cost coke is used for charge carbon, but is not a suitable alternative for injection carbon. The normal alternative for the injection carbon is a Texas Gulf Coast pet coke with about 2.2% sulfur that provides a cost savings ranging from $56/ton to $66/ton of coke over the cost of ultra low sulfur pet coke. Although ultra-low sulfur pet coke may be used to ensure the lowest possible SO2 emissions, it is determined that use of this raw material should not be a requirement, but that V & M Star should have operating flexibility and be allowed to select the most cost effective means to meet emission and production criteria.

V&M Star believes that the costs of these charge modification techniques are excessive and are not justified under BACT cost effectiveness criteria. For these several reasons it is determined that a lower emission factor is not justified for establishing allowable SO2 emissions. The precise emission benefit of these possible sulfur reduction measures is not known. For a conservative analysis of the potential cost effectiveness of each technique, it is assumed for the following calculations that these techniques would reduce SO2 emissions by 0.05 lb/ton.

Texas Injection Pet Coke (~2.2% S) versus Ultra-Low Sulfur California Pet Coke (<1%) Additional cost premium for California ultra-low sulfur pet coke: $56/ton to $66/ton of coke Benefit: Reduction of sulfur content Assumed emission benefit: Reduction of 0.05 lb SO2/ton of liquid steel Annual cost premium = (1,400,000 tons stl/year)(20 lbPC/ton stl)(1 ton/2000 lb) ($56/ton PC) = $784,000/year (using the low range of recent PC costs)


Potential SO2 reduction = (1,400,000 tons stl/year)(reduction 0.05 SO2 lb/ton steel)(1 ton/2000 lb) = 35.0 tons SO2/year Cost effectiveness = ($784,000 increase)/(35.0 tons SO2 reduction) = $22,400/ ton SO2 reduction ($26,400/ton at $66/ton PC premium) These analyses, conservatively based on the assumption that a substantial EAF/LMF emission reduction might be provided by the scrap optimization or low sulfur pet coke substitution, demonstrates that these techniques exceed cost considered justified under BACT criteria and are not cost effective ways to reduce SO2 emissions for the V&M Star facility.

The following table shows a range of SO2 emission factors determined to be BACT for similar facilities. Several facilities that were originally permitted at the low end of the scale subsequently requested substantial increases in allowable emission based on determination of inability or excessive cost to maintain compliance.


Facility (EAF/LMS) SO2 Emission Factor

(lb/ton) V&M Star predicted performance ≤0.25

Quanex Corporation, AR 1.05

Ipsco Steel, AL 0.70

Arkansas Steel, AR 0.70

Chaparral – East, VA 0.70

Corus, AL 0.62

Nucor, AL 0.50

Nucor Steel, Hertford Cty, NC 0.35

Beta Steel, IN 0.33

Nucor Steel, Berkley Cty, SC 0.25

Republic Engineered Steels, OH 0.25

Steel Dynamics, Butler, IN 0.25

Steel Dynamics, Columbia, IN 0.20

Nucor, Hickman, AR 0.20

Nucor, TN 0.16

The proposed emission factor of 0.25 lb/ton is within this range of acceptable BAT performance and is lower than the majority of recent PSD BACT determinations. This is consistent with the September 2008 PSD PTI BACT determination.

2.2 LMF Alloy, Additives, and Flux Handling System

A new bulk LMF additives materials handling system will be installed to serve the proposed new hot metal building. There will be a three sided truck dump station and conveyor lift distributing materials to 12 storage bins. Dust capture exhaust from the truck dump enclosure, conveyor transfers, and bins will be directed to the large EAF/LMF baghouse. Preliminary design dust capture exhaust flow is 25,000 acfm (during truck


dumping). Any potential emissions are included in the calculation of emissions from the EAF/LMF baghouse system and are not specifically attributable to the materials handling system. Capture and control by baghouse filtration is BACT for this negligible particulate emission source.

2.3 Continuous Caster

The current caster emissions are not captured and escape the building roof monitor. The proposed project includes installation of a 5-strand caster machine in the new hot metal building to achieve the required billet quality levels, size variation, and desired production capacity. The current permit has a steel production limit and emission rate limits for NOx and PE/PM10 based on estimated pounds emission per ton of steel emission factors. These emission rate limits are proposed to be increased consistent with the increase in production.

The estimated small amounts of particulate and NOx will be captured by the caster hood that is planned for the new hot metal building, even though caster emissions often are considered negligible and not quantified in permit limits. With the proposed new caster building equipment arrangement and increased EAF baghouse capacity being installed, emissions from the caster and other minor source operations will be directed to the EAF baghouse. The preliminary design flow for the caster hood is 35,000 cfm.


The caster hood exhaust will be directed to and commingled with the larger EAF/LMF baghouse flow. Specific particulate emissions attributable to the caster operation will not be quantifiable. Capture and baghouse control of potential PM10 emissions from caster operations is determined to meet and exceed typical BACT for caster facilities.

2.3.2 NOx Control

No alternative add-on controls are identified as affective or available for the caster NOx emissions. NOx emissions are projected to be minimized by the source design characteristics with shrouding of the liquid pour stream. The caster NOx emission factor has historically been estimated to be 0.05 lb/ton for the V&M operation.

It is determined that there are no available add-on emission controls for the continuous caster, and it is proposed that the source design characteristic minimizing emissions is BACT. Projected potential NOx of 8.6 pounds per hour and 35.0 tons per year are estimated if the project is constructed.

2.4 Vacuum Tank Degasser (VTD)

A vacuum tank degasser (VTD) is needed for production of some steel products. V&M is proposing to install a new VTD in the new hot metal building. A VTD is used to reduce the concentrations of dissolved gases (H2, N2, O2) in the liquid steel, homogenize the liquid steel composition and bath temperature, and remove oxide inclusions in the steel. During operations at the VTD, the liquid steel is stirred to promote homogenization by percolating argon gas through a refractory stir plug arrangement in the bottom of the ladle.


At the VTD the ladle of molten steel is placed inside the sealed vacuum tank. The closed vacuum tank is evacuated to the required operating pressures using a multiple stage steam jet ejector and condenser system or a combination of steam jet ejectors and water ring pumps. Some particulate is entrained in the gases from the VTD and captured in the separator ahead of the steam jets and in the steam jet condensers, which inherently provide high collection efficiency. Particulate loading from the tank is very conservatively estimated at 0.20 lb/ton of steel processed. The vacuum system is predicted to provide greater than 99% capture of the particulate for an estimated PM/PM10 emission rate of 0.002 lb/ton of steel and 0.34 lb/hour.


There are no add-on particulate emission controls employed on VTD system other than that provided by the vacuum system, and the vacuum system design performance is determined to be BACT for particulate control.

2.4.2 CO Control

V&M will not be performing oxygen lancing decarburization, and the projected CO emissions are estimated to be very low. The predicted average CO concentration is 0.7%, which equates to about 2 Btu/cu.ft. and is not flammable, so a flare is not applicable. The average emission is expected to be around 0.1 lb/ton of steel and the maximum emission factor used for estimating potential emissions is 0.2 lb/ton.

There is little data available on similar VTD operations, and operations often have no limits. The RBLC identifies one BACT determination for a VTD performing natural decarburization and operating without a flare. The Charter Steel, Ohio VTD operation is allowed 25 lb/hr CO at 110 tons/hour steel VTD operation without a flare, which equates to 0.23 lb/ton of steel. We determined that the estimated maximum CO emission factor of 0.2 lb/ton and 34.4 lb/hour is BACT for the planned VTD operation.

2.5 VTD Boilers

Steam for the VTD will be generated by small “Ohio Special” natural gas fired boilers under 10 MMBtu/hr heat input. Up to five (5) boilers are proposed to be installed depending on whether the final vacuum system design employs only multiple steam jets or a combination of steam jets and water ring pumps. This type firetube boiler has a heating surface of 360 sq.ft., which allows it to be fired without an operator present. In Ohio larger boilers require an operator to be present 100% of the time that the boiler is fired. During a VTD heat cycle vacuum is applied for about half the cycle time, and only a portion of the steel production will require VTD processing, so the boilers will be in idle fire much of the time.

2.5.1 NOx Control

The emission factors are based on AP-42 natural gas combustion, except for NOx. The small heating surface area and small furnace volume of this Ohio Special boiler results in a high volumetric heat release rate, which impacts NOx performance. The vendors contacted that fabricate this boiler report that the best NOx performance attainable is about 80 ppmvd, which equates to 0.097 lb/MMBtu rounded to 0.10 lb/MMBtu. Hourly emissions are based on the firing capacity of the boilers, and annual emission estimates are conservatively estimated based on 75% annual capacity factor.

Lower NOx performance could only be attained by a conventional boiler with ultra low NOx burners and flue gas recirculation. Utilization of a single D-type water tube boiler was investigated. This boiler could perform at 30 ppm NOx with ULN burner and about 15% FGR, and it could possibly attain LAER performance of 9 ppm with ULN burner and about 25% FGR.

A top-down economic impacts analysis was done for the technically feasible alternatives in accordance with EPA BACT procedures. Capital and operating costs were evaluated to determine total annual costs for each alternative in Table 2-13. The primary difference in operating cost is due to the requirement that the larger boiler have a qualified operator present whenever fuel is fired, which is not required for the small qualifying “Ohio Special” boiler. The average NOx cost effectiveness for the LAER 9 ppm boiler was determined to be $47,000/ton of NOx reduction as compared to the baseline proposed boiler, and the average cost effectiveness for the 30 ppm boiler was determined to be $62,000/ton of NOx reduction. These costs exceed that reasonably required for BACT economic applicability. It is determined that the NOx BACT is 0.10 lb/MMBtu using the small Ohio Special boilers.

2.5.2 PM10, CO, SO2, AND VOC Control

No alternative emission reduction techniques for PM10, CO, SO2, or VOC are applied to small natural gas fired boilers. Good natural gas combustion practices are determined to be BACT, and emissions are


estimated based on AP-42 emission factors for natural gas combustion.

2.6 MPM Billet Reheat Furnace (Existing)

The existing Billet Reheat Furnace (BRF) is being upgraded with new ultra-low NOx natural gas burner systems. The NOx emission performance for the billet reheat furnace will be significantly improved with the burner retrofit utilizing updated and improved ultra-low NOx burner technology systems reducing the NOx emissions performance from a currently permitted emission performance of 0.15 pound per MMBtu to a guaranteed emission performance of 0.10 pound NOx per MMBtu or less. This performance was determined to be BACT in the September 2008 PSD PTI.

2.7 FQM Billet Rotary Hearth Reheat Furnace (New)

V & M Star is proposing to construct a new tube mill utilizing equipment supplied by the manufacturer and referred to as the Fine Quality Mill (FQM). Nominal production capacities are 154 tons/hour and 660,000 tons/year. The processes involve cold billet cutting, billet heating in a rotary hearth furnace, piercing of the billet into a shell, insertion of a mandrel and rolling of the shell into a mother tube, extracting of the tube from the mandrel, reheating of the tube in the intermediate pipe furnace, final tube rolling, cooling, and cutting to length. A significant portion of the tubes may go through one of two finishing lines having an austenitizing furnace (hardening) and a tempering furnace. The new emission sources are subject to BACT review for the PSD triggered pollutants, PM10, CO, NOx, SO2, and VOC.

The feedstock is continuously cast round billets. Preparatory to billet piercing the billets are heated up to a maximum temperature of approximately 1,280°C (2,336°F) in a natural gas fired rotary hearth type furnace. For fuel efficiency the burner combustion air is preheated in an exhaust gas recuperator. This type of furnace uses a rotating refractory surfaced hearth inside the furnace. The furnace uses 40 lateral burners each with a nominal heat input capacity of 7 MMBtu/hr and 36 radiant burners having nominal heat input capacities of <1 to 2 MMBtu/hr. The total installed rated capacity of all burners is 265 MMBtu/hr, but the simultaneous firing capacity of the furnace is about 203 MMBtu/hr.

The standard European burners in the initial the manufacturer offering had a projected NOx emission of 250 mg/Nm3 (about 0.17 lb/MMBtu). We informed the manufacturer that this would not be acceptable in the U.S., that ultra low NOx burners would be required where available regardless of whether they have been used in Europe, and set a target performance around 0.07 lb/MMBtu.

The proposed NOx BACT performance in the following discussion is based on the manufacturer predicted ultra low NOx performance. The PE/PM10, CO, SO2, and VOC emission rates are based on AP-42 emission factors for natural gas combustion.


The baseline particulate matter emission estimates are the uncontrolled emissions resulting from combustion of the furnace fuel. There might also be contribution from atmospheric dust entrained in the combustion air, refractory degradation and steel surface oxidation, but these are generally unquantified and are not considered. The proposed permit emission is based on the AP-42 emission factors for natural gas combustion and the furnace fuel input.

Depending upon the nature of a particulate emission source, high efficiency particulate emission control might be provided by: (1) electrostatic precipitator, (2) high efficiency cyclones, (3) high energy scrubber, or (4) fabric filter baghouse. However, based on AP-42 the filterable particulate loading should only be between 0.001 and 0.002 grains/dscf and all PM (total, condensable and filterable) is assumed to be less than 1.0 micrometer in diameter. It is unlikely that any control device would provide any significant reduction of particulate emission. Even considering 100% emission reduction, the cost effectiveness would be over $100,000 per ton based on other baghouse cost estimates.


No similar natural gas fired furnaces have installed particulate control, and it is our determination that no add-on control is feasible and that the use of natural gas fuel and good combustion practices is BACT. It is proposed that PM/PM10 emissions based on AP-42 factors and fuel usage are BACT, which would be: 7.6 pounds total PM per mmcf of natural gas, 1.5 pounds per hour, and 3.54 tons per year.

2.7.2 CO, VOC and SO2 Control

The baseline carbon monoxide and VOC emission estimates are the uncontrolled emissions resulting from combustion of the natural gas furnace fuel. The proposed permit emission is based on the AP-42 emission factors for natural gas combustion and the furnace fuel input.

The more important emission performance constraint is the minimizing of combustion NOx emissions, which includes operating parameters, such as low burner excess air. Imposition of process changes, such as increasing excess air to reduce CO below the AP-42 estimate could have overall negative impact. No similar natural gas fired furnaces have installed CO control or been required to modify combustion operation to reduce the CO emission factor, and it is our determination that no control is applicable and that the use of natural gas fuel and good combustion practices is BACT. It is proposed that CO emission based on the AP-42 factor and fuel usage are BACT, which would be: 84 pounds CO per mmcf of natural gas, 16.7 pounds per hour, and 39.14 tons per year. VOC emissions are 1.1 pounds per hour and 2.6 tons per year.

There is no economically feasible SO2 control for natural gas combustion emissions. Utilization of pipe line natural gas or equivalent is determined to be BACT for SO2 emissions.

2.7.3 NOx Control

The proposed billet rotary hearth reheat furnace (RHF) is designed to utilize the best applicable ultra-low NOx burner technology systems. However, we are not aware of demonstrated low NOx performance on this type furnace, as compared to the water cooled walking beam furnace, which is more prevalent in the U.S. We are concerned that because of the furnace geometry with large refractory surface areas and requirement for high internal billet temperature for piercing, that the rotary hearth furnace will not be able to attain the performance of more standard rolling mill reheat furnaces.

From prior analyses and engineering evaluation of the existing billet reheat furnace (BRF) and previously proposed billet preheat furnace (BPF), it is determined that SCR add-on NOx control would be economically if not technologically infeasible. It is our determination that use of natural gas fuel and new ultra-low NOx burner technology is BACT for the RHF.

NOx is recognized to be a critical regional pollutant and is the pollutant of primary focus for this furnace design. The manufacturer has projected that the furnace should attain 0.07 pounds NOx per MMBtu, but it is not currently demonstrated. Considering the undemonstrated performance and allowing for operating variability, testing precision, and degradation of furnace efficiency and performance between major maintenance cycles, we propose a 15% allowance over the predicted emission and a BACT allowable emission of 0.08 pounds NOx per MMBtu. This NOx performance of 0.08 pound NOx per MMBtu is believed to equal to or lower than BACT limits for numerous billet heating furnace. At the proposed BACT performance level, the maximum hourly NOx emission rate is 16.2 pounds per hour and the potential annual emission is 38.0 tons per year.



Reheat Furnace

NOx Factor


Ipsco Steel, AL 0.172

Qualitech Steel, IN 0.15

Thyssenkrupp Steel, AL 0.11

V&M Star, OH (reheat furnace) 0.10


Nucor Auburn, NY 0.084

Beta Steel, IN 0.077

V&M Star,OH (preheat furnace/lower temp) 0.070

Nucor Blytheville Mill, AR 0.070

2.8 FQM Pipe Intermediate Reheat Furnace (New)

The Intermediate Furnace reheats the tube prior to final tube rolling and stretch reducing. The tubes are heated up to a temperature of approximately 950°C (1,742°F) in a natural gas fired furnace. For fuel efficiency the burner combustion air is preheated in an exhaust gas recuperator. The furnace uses 80 frontal burners each with a nominal heat input capacity around 1.2 MMBtu/hr. The total installed rated capacity of all burners is 98 MMBtu/hr, but the simultaneous firing capacity of the furnace is about 88 MMBtu/hr.

The standard burners in the initial manufacturer’s offering had a projected NOx emission of 250 mg/Nm3 (about 0.17 lb/MMBtu), and as for the rotary hearth furnace, V&M informed the manufacturer that this would not be acceptable in the U.S., that ultra low NOx burners would be required where available and set a target performance around 0.07 lb/MMBtu.

The proposed NOx BACT performance in the following discussion is based the manufacturer’s predicted ultra low NOx performance. The PE/PM10, CO, SO2, and VOC emission rates are based on AP-42 emission factors for natural gas combustion.



No similar natural gas fired furnaces have installed particulate control. As for each of the natural gas fired furnaces and it is our determination that no add-on control is feasible and that the use of natural gas fuel and good combustion practices is BACT. It is proposed that PM/PM10 emissions based on AP-42 factors and fuel usage are BACT, which would be: 7.6 pounds total PM per mmcf of natural gas, 0.7 pounds per hour, and 1.52 tons per year.




No similar natural gas fired furnaces have installed CO control or been required to modify combustion operation to reduce the CO emission factor. Similar to the other furnaces, it is our determination that no control is applicable and that the use of natural gas fuel and good combustion practices is BACT. It is proposed that CO emission based on the AP-42 factor and fuel usage are BACT, which would be: 84 pounds CO per mmcf of natural gas, 7.25 pounds per hour, and 16.8 tons per year. VOC emissions are 0.5 pounds per hour and 1.1 tons per year.


2.8.3 NOx Control

The proposed Intermediate Furnace will be constructed using the available ultra-low NOx burner technology systems.

From prior analyses and BPF engineering evaluation it is determined that SCR add-on NOx control would be economically if not technologically infeasible. It is our determination that use of natural gas fuel and new ultra-low NOx burner technology is BACT for the RHF.

Two furnace design concepts were evaluated, (1) application of a furnace exhaust gas recuperator (heat exchanger) to preheat the burner combustion air, and (2) use of a cold combustion air burner. The cold combustion air burner would have a predicted lower NOx emission factor, 0.0634 lb/MMGBtu versus 0.70 lb/MMBtu. However, the exhaust gas temperature without the recuperator would be 1238°F versus 590°F, and the required firing capacity would increase from 88 MMBtu/hour to 111 MMBtu/hour. Although the lb/MMBtu performance is better, the resulting lb/hr NOx emission rate would be higher with the cold air burner. The emission of other combustion pollutants would also increase in a direct relationship to the fuel increase.

The manufacturer has projected that the furnace with the recuperator and hot combustion air burner systems should attain 0.07 pounds NOx per MMBtu with ultra low NOx burners, but it is not currently demonstrated. Considering the undemonstrated performance and allowing for operating variability, testing precision, and degradation of furnace efficiency and performance between major maintenance cycles, we propose a 15% allowance over the predicted emission and a BACT allowable emission of 0.08 pounds NOx per MMBtu. This NOx performance of 0.08 pound NOx per MMBtu is found to be equal to or lower than BACT limits for numerous billet heating furnace. At the proposed BACT performance level, the maximum hourly NOx emission rate is 7.04 pounds per hour and the potential annual emission is 16.3 tons per year. We have not identified BACT permit levels specific for this type of intermediate reheating furnace, but we think the table of billet reheat furnace BACT limits shown above is an appropriate comparison.

2.9 Mandrel Furnace

Mandrels used in tube rolling are preheated in a car type furnace with external recirculation combustion chamber. The single burner is specially designed for operation in a combustion chamber of limited dimension. The rated capacity of the single natural gas burner is 4.4 MMBtu/hour. The estimated NOx emission performance is 0.11 lb/MMBtu based on the manufacturer’s design information. The PE/PM10, CO, SO2, and VOC emission rates are based on AP-42 emission factors for natural gas combustion. Annual emissions estimates are based on conservatively predicted fuel consumption for the annual production capacity.


The mandrel preheating furnace is exempt for PTI requirements per OAC 3745-31-03 for furnaces less than 10 MMBtu/hour burning only natural gas. It is determined natural gas and good combustion practices is BACT for this small combustion operation.

2.10 Austenitizing Furnace #1 and #2

There are two proposed tube finishing lines, each with an austenitizing furnace followed by a tempering furnace. The Austenitizing Furnace is a tube finishing operation that heats the tube in a manner to provide surface hardening and corrosion resistance. For fuel efficiency the burner combustion air is preheated in an exhaust gas recuperator. The furnace uses 88 small burner. The total installed rated capacity of all burners is 40 MMBtu/hr, but the simultaneous firing capacity of the furnace is about 32 MMBtu/hr.









2.10.3 NOx Control

The proposed Austenitizing Furnace will be constructed using the available ultra-low NOx burner technology systems. However, we are not aware of demonstrated low NOx performance on this type furnace.



Two furnace design concepts were evaluated, (1) application of a furnace exhaust gas recuperator (heat exchanger) to preheat the burner combustion air, and (2) use of a cold combustion air burner. The cold combustion air burner could have a predicted lower NOx emission factor, 0.060 lb/MMBtu versus 0.70 lb/MMBtu. However, the exhaust gas temperature without the recuperator would be 1,112°F versus 500°F, and the required firing capacity would increase from 31.9 MMBtu/hour to 40.5 MMBtu/hour. Although the lb/MMBtu performance is better, the resulting lb/hr NOx emission rate would be higher with the cold air burner. The emission of other combustion pollutants would also increase in a direct relationship to the fuel increase.

The manufacturer has projected that the furnace should attain 0.07 pounds NOx per MMBtu, but it is not currently demonstrated. Considering the undemonstrated performance and allowing for operating variability, testing precision, and degradation of furnace efficiency and performance between major maintenance cycles, we propose a 15% allowance over the predicted emission and a BACT allowable emission of 0.08 pounds NOx per MMBtu. This NOx performance of 0.08 pound NOx per MMBtu is believed to equal to or lower than BACT limits for numerous billet heating furnace. At the proposed BACT performance level, the maximum hourly NOx emission rate is 2.56 pounds per hour and the potential annual emission is 7.06 tons per year. We have not identified BACT permit levels specific for this type of austenitizing furnace, but the table of billet reheat furnace BACT limits given above may be an appropriate comparison, and we have identified RBLC BACT values for some annealing furnaces, which also provides some comparison.


Annealing Furnace

NOx Factor


Hoeganeas, TN 0.143

Ellwood National Steel, PA 0.14

Thyssenkrupp Steel, AL (3 furnaces) 0.11

Nucor Steel, IN 0.10


USS Galvanizing, OH 0.06

2.11 Tempering Furnace #1 and #2

The Tempering Furnace is a tube finishing operation that heats the tube in a manner to relieve stress. The furnace total installed rated capacity of all burners is 33.4 MMBtu/hr, but the simultaneous firing capacity of the furnace is about 26.5 MMBtu/hr. For fuel efficiency the burner combustion air is preheated in an exhaust gas recuperator.



The baseline particulate matter emission estimates are the uncontrolled emissions resulting from combustion of the furnace fuel. There might also be contribution from atmospheric dust entrained in the combustion air, refractory degradation and steel surface oxidation, but these are generally unquantified and are not considered. The proposed permit emission is based on the AP-42 emission factors for natural gas


combustion and the furnace fuel input.






2.11.3 NOx Control

The proposed Tempering Furnace will be constructed using the available ultra-low NOx burner technology systems. However, we are not aware of demonstrated low NOx performance on this type furnace.


Two furnace design concepts were evaluated, (1) application of a furnace exhaust gas recuperator (heat exchanger) to preheat the burner combustion air, and (2) use of a cold combustion air burner. The cold combustion air burner could have a predicted lower NOx emission factor, 0.060 lb/MMBtu versus 0.70 lb/MMBtu. However, the exhaust gas temperature without the recuperator would be increased, and the required firing capacity would increase from 26.5 MMBtu/hour to 32.1 MMBtu/hour. Although the lb/MMBtu performance is better, the resulting lb/hr NOx emission rate would be higher with the cold air burner. The emission of other combustion pollutants would also increase in a direct relationship to the fuel increase.

The manufacturer has projected that the furnace should attain 0.07 pounds NOx per MMBtu, but it is not currently demonstrated. Considering the undemonstrated performance and allowing for operating variability, testing precision, and degradation of furnace efficiency and performance between major maintenance cycles, we propose a 15% allowance over the predicted emission and a BACT allowable emission of 0.08 pounds NOx per MMBtu. This NOx performance of 0.08 pound NOx per MMBtu is believed to equal to or lower than BACT limits for numerous billet heating furnace. At the proposed BACT performance level, the maximum hourly NOx emission rate is 2.16 pounds per hour and the potential annual emission is 6.1 tons per year. We have not identified BACT permit levels specific for this type of tempering furnace, but the table of billet reheat furnace BACT limits and the table for annealing furnaces given above may be an appropriate comparisons.


2.12 FQM Pipe Mill Scrubber

At the outlet of the piercing mill, an antioxidant powder (borax) is blown by nitrogen into the bore of the shell. At the FQM rolling line the mandrel is inserted into the shell and graphite is injected to lubricate the mandrel. Dust hoods capture particulate generated at these production operations. These hood exhausts and other minor pick up points are exhausted to a rod deck venturi scrubber for control of particulate emissions. The preliminary nominal design flow to the scrubber recommended by the manufacturer was 250 Nm3/hr, which is about 157,000 scfm. The actual flow should be about 180,000 acfm. Some adjustment to design flow is expected with vendor input. The specified scrubber outlet particulate performance is 0.004 gr/dscf.


The specified scrubber emission performance is 0.004 grains/dscf. Because of the nature of the particulate, exhaust humidity, and temperature range, a scrubber is determined to be the best control technology. The vendor recommended design for optimum performance is a rod deck venturi scrubber. The rod deck venturi design consists of multiple horizontal pipe rods uniformly sprayed with recycle water of up to 1% solids. The open nozzles have no internal vanes to plug. When the gas velocity within the throat exceeds 150 fps, large droplets and liquid films on the walls are atomized to a 200-300 micron cloud of droplets. Making fine droplets results in a tremendous increase in droplet surface area increasing the probability of particulate capture. The pressure drop could be adjusted to some extent by changing the number of pipe rods, but with an increase in power required. The preliminary design is for a scrubber pressure drop of 11 inches w.g.

It is our determination that the proposed venturi scrubber is BACT for the pipe mill particulate emission control. The proposed filterable particulate performance limit is 0.004 grains per dry standard cubic foot. At the preliminary design flow of 157,913 dscfm, this results in a particulate emission rate of 5.4 pounds per hour and 23.7 tons per year potential at 8,760 hours per year. It is proposed that the venturi scrubber with emission performance of 0.004 gr/dscf or better is BACT.

2.13 Abrasives Manufacturing Raw Materials Handling

The proposed vendor’s process abrasive product raw materials are EAF dust plus glass cullet, sand, foundry sand, feldspar and rejected finished product fines. These raw materials are pneumatically conveyed to and between the six silos and the melter receiving bins. Each of these raw material receiving operations, the material weigh hopper, and the air blender are vented through bin vent filters into the building.

Based on materials handling systems vent filter outlet grain loading of 0.005 gr/cf, exhaust flows, and potential operating time, the total instantaneous PM emission rate during simultaneous operation of systems is estimated to be <0.07 lb/hr, and the potential emission is estimated to be les than 0.8 lb/day and 0.14 tons/year. These facilities are all inside the building workspace, and any malfunction of a filter releasing raw materials would be detected and corrected immediately. The proposed building will have vents to remove heat, but the simultaneous air flow released in the building from the materials handling system, ~1,580 cfm, is likely to be captured in the aggregate manufacturing and product handling systems induced air flows (~30,000 cfm), which are exhausted through emission control devices that will be permitted.

The raw material handling facilities are determined to be de minimis and exempt from PTI requirements in accordance with OAC 3745-15-05, because these similar sources as a group have potential particulate emissions of less than 10 pounds per day.

It is determined that the vent filter outlet loading performance of 0.005 gr/cf and operating practices are BACT for particulate control.


2.14 Abrasives Melting Furnace

The proposed vendor’s vitrification process incorporates the EAF dust and other raw materials into a glass-ceramic product. The materials are melted in the natural gas fired furnace and form a molten ceramic material. The 20.1 MMBtu/hour furnace utilizes oxy-fuel burners.

The melter glass temperature approaches 2700°F. The furnace gas temperature is about 2900°F, and oxy-fuel natural gas burners are used to meet BACT for NOx emissions, increase efficiency, and reduce off-gas flow. The off gas from the melter is reduced in temperature to about 800°F by dilution with ambient air, then quenched with water to near 300°F. The exhaust gas is filtered to recover product solids and reduce loading to the scrubber water, then is directed to the venturi scrubber for particulate emission control and the caustic liquor packed tower scrubber for control of sulfur and any halides that might be present in the original EAF dust. Uncontrolled emission factors are preliminary estimates because there is no similar operating abrasive manufacturing furnace to test.

Uncontrolled PM is estimated by the furnace supplier to be around 10 lb/ton of product based on engineering evaluation of other glass processes. The expected particulate control efficiency is 99%, and the estimated outlet PM/PM10 loading is 0.010 gr/dscf and 0.5 lb/hour. The packed column caustic scrubber is specified to provide better than 90% control of sulfur dioxide and 99% control of any halides.

Other uncontrolled emission factors are 0.2 lb/ton of product for CO, 3.4 lb/ton for SO2, and 0.2 lb/ton for VOC based on AP-42 emission factors for glass manufacturing.

2.14.1 NOx Control

The NOx emission factor predicted by the intended furnace supplier for the oxy-fuel fired furnace is less than 0.5 lb/MMBtu. This is substantially lower than performance identified for air-fuel fired glass furnaces other oxy-fuel fired glass furnaces.

There is very little glass furnace data in the RBLC and none for a similar abrasive manufacturing furnace. The Cardinal FG Co., WA float glass furnace has a BACT limit of 7.0 lb/ton of product (2.33 lb/MMBtu heat input). Another furnace with oxy-fuel burners at a glass plant tested around 1.0 lb/MMBtu input. The projected NOx emission performance of 0.5 lb/MMBtu heat input is believed to be BACT for the planned V&M melter furnace.

2.14.2 PM10

Uncontrolled PM is estimated by the furnace supplier to be around 10 lb/ton of product based on engineering evaluation of other glass processes. The combined recovery filter, venturi scrubber, and packed tower scrubber are projected to provide 99% particulate control efficiency. The estimated outlet PM/PM10 loading is 0.010 gr/dscf and 0.5 lb/hour. The particulate scrubber performance is determined to be BACT for this melter furnace.

2.14.3 SO2

The predicted uncontrolled SO2 emission factor is 3.4 lb/ton of product based on AP-42, 11.15 Glass Manufacturing, Table 11.15.1. The caustic packed tower scrubber is designed to provide better than 90% control of potential SO2 emissions. The controlled emission is predicted to be less than 1.64 lb/hr. It is determined that the caustic packed tower scrubber is BACT for SO2.

2.14.4 CO AND VOC

Other AP-42 Table 11.15-1 glass manufacturing uncontrolled emission factors are 0.2 lb/ton of product for CO and 0.2 lb/ton for VOC. It is determined that the natural gas oxy-fuel burner and good combustion practices are BACT for CO and VOC emissions from the furnace. There are no applicable add-on controls.


2.15 Abrasives Finished Product Handling

The product exiting (or tapping out of) the melter is viscosity controlled in a typical glass melter fore hearth and then immediately quenched with water to control crystallization. The intermediate quenched product is then dried and conveyed to the finishing area where it is converted into the various sizes required for the loose grain abrasive market. The rotary drum dryer, crushing, screening, handling, bagging, and other potential product dust generating activities are exhausted to a common baghouse to capture particulate. Product fines and dust collected in this manner from the finishing operation are recycled to the melter for remelting.

2.15.1 PM10 Control

The nominal particulate control baghouse flow is 23,000 cfm (20,000 dscfm), and the predicted maximum baghouse outlet loading for determination of potential emissions is 0.005 gr/dscf. It is determined that a baghouse and specified outlet loading performance of 0.005 gr/dscf is BACT for particulate control.

2.16 Cooling Towers

The cooling tower operations will be modified with the addition of several new cooling towers. New non-contact and contact cooling water systems will be installed to serve the new hot metal LMF and VTD operations, designated cooling tower 1 and 1A. FQM contact and non-contact cooling water systems will be installed to serve the new FQM pipe mill, designated cooling tower 7 and cooling tower 8.

Cooling tower PM10 emission is largely dependent on the drift mist eliminator performance and the total dissolved solids of the circulating cooling water, and drift eliminator performance is largely a function of the type of cooling tower. Cross flow tower design with PVC film fill and chevron mist elimination, such as supplied by Marley and BAC, is typical and most often applied for industrial cooling. Drift eliminator performance capability is determined to be 0.005% of design liquid flow rate for this industrial tower design. Cross flow tower design cannot match the higher drift performance capability of counterblow design. Large utility field erected towers and some industrial counter flow towers have been identified as being capable of 0.001% to 0.0005% drift efficiency, but this performance capability has limited applicability and is not determined available for this industrial application. A related and notable effect observed by the Cooling Technology Institute during testing of cross flow eliminators was the lower breakthrough velocities of drift carryover, as compared to that for counter flow towers, which limits performance. Breakthrough velocity is the velocity at which visible droplets consistently get re-entrained into the exiting air stream.

Operating TDS is projected to be around 1000 ppm or less. Estimated potential emissions are based on an assumed maximum TDS of 1000 ppm.

It is determined that particulate control by high efficiency integral drift eliminators with a drift performance of 0.005% of the circulating water flow rate is BACT for the cooling tower facilities.

2.17 Roadways

The current permit imposes no vehicle use restriction on the roadways, but does require implementation of dust control measures, including: sweeping and flushing of paved roadways and treatment of unpaved roadways and parking areas with water or suitable dust suppression chemicals.

The plant employs an aggressive dust control program with operational restrictions, monitoring, testing, and reporting, which we determine meets RACT and BACT for steel mill operations. The small potential increase of about 3.5 tons per year in estimated PM10 emissions is based on the estimated increase in vehicle traffic from the prior actual steel production to the future potential production of 1,400,000 tons per year.



Tables and Figures Table 1-1 V&M Star Source Emission Factors and Rate Calculations

Table 1-2 V&M Star Baseline Emission Rate Calculations

Table 1-3 V&M Star Annual Emission Rates Summary













Table 2-13 VTD Boiler NOx Reduction Cost Effectiveness Analysis

Table 2-14 New FQM Seamless Pipe Mill Furnaces

1 of 4

Table 1-1 V & M Star Source Emission Factors and Rate Calculations

2008 Application for Melt Shop, Refining and Caster Upgrades and New FQM Pipe Mill

Production basis: 172 tons liquid steel/hour

1,400,000 tons liquid steel/year

Hourly Emission Factors and Maximum Emission Rates Annual Emission Factors & Potential Emissions

OEPA Emission Factor Process Factor Other Control Factor Emission Process Factor Operating Hr Basis Annual

code Source Discharge Point Pollutant Units Units Units lb/hr Units Units tons/yr

Meltshop, Refining and Billet Casting Upgrade Facilities

P905 EAF EAF/LMF combined emission factors x x PM10 0.0018 gr/dscf 980,000 dscfm 15.12 8,208 hrs/yr 62.05

Expanded Meltshop Baghouse CO 4.0 lb/ton 172 tons/hr Total EAF+LMF factor 688 1,400,000 tons/yr 8,208 hrs/yr 2,800.0

(1,200,000 acfm) NOx 0.40 lb/ton 172 tons/hr 68.8 1,400,000 tons/yr 8,208 hrs/yr 280.0

SO2 0.25 lb/ton 172 tons/hr 43.0 1,400,000 tons/yr 8,208 hrs/yr 175.0

VOC 0.18 lb/ton 172 tons/hr 31.0 1,400,000 tons/yr 8,208 hrs/yr 126.0

Pb 1.7% % of PM 172 tons/hr 0.26 1,400,000 tons/yr 8,208 hrs/yr 1.05

P905 EAF Meltshop Fugitives x x PM10 1.4 lb PE/ton 172 tons/hr 99% % control 1.83 1,400,000 tons/yr 8,208 hrs/yr 7.45

76% PM10/PE %

Pb 1.7% % of PM 172 tons/hr 0.031 1,400,000 tons/yr 8,208 hrs/yr 0.127

P906 LMF (EAF/LMF baghouse) x x PM10 [Included in EAF/LMF emission factors] [Included in EAF/LMF baghouse emissions]

CO 0.5 lb/ton 172 tons/hr [prel. est. exhaust flow to EAF bh 70,000 acfm]

NOx 0.05 lb/ton 172 tons/hr

SO2 0.10 lb/ton 172 tons/hr

VOC

P005 Ladle Pre-heaters x x PM10 7.6 lb/mmcf 14.7 mcf/hr 0.11 120,706 mcf/yr 8,208 hrs/yr 0.46

P006 (3 @ 5 MMBtu/hr) CO 84 lb/mmcf 14.7 mcf/hr 1.24 120,706 mcf/yr 8,208 hrs/yr 5.07

NOx 100 lb/mmcf 14.7 mcf/hr 1.47 120,706 mcf/yr 8,208 hrs/yr 6.04

SO2 0.6 lb/mmcf 14.7 mcf/hr 0.009 120,706 mcf/yr 8,208 hrs/yr 0.04

VOC 5.5 lb/mmcf 14.7 mcf/hr 0.081 120,706 mcf/yr 8,208 hrs/yr 0.33

P907 EAF additive, alloy & flux handling x x PM10 8.00E-04 lb/ton 172 tons/hr 0.14 1,400,000 tons/yr 8,064 hrs/yr 0.56

LMF alloy & flux bulk handling x PM10 8.00E-04 lb/ton 172 tons/hr 0.14 1,400,000 tons/yr 8,064 hrs/yr 0.56

(EAF/LMF baghouse) [prel. est. exhaust flow to EAF bh 25,000 acfm] [Included in baghouse emission]

F003 Caster (EAF/LMF baghouse) x x PM10 0.07 lb/ton 172 tons/hr 95% % control 0.60 1,400,000 tons/yr 8,208 hrs/yr 2.45

NOx 0.05 lb/ton 172 tons/hr 8.6 1,400,000 tons/yr 8,208 hrs/yr 35.00

[prel. est. exhaust flow to EAF bh 35,000 acfm] [PM included in baghouse emission, NOx additive to bh exhaust]

VTD Steam jet vacuum condenser x PM10 0.2 lb/ton 172 tons/hr 99% system capture 0.34 1,400,000 tons/yr 8,208 hrs/yr 1.40

CO 0.20 lb/ton 172 tons/hr 34.4 1,400,000 tons/yr 8,208 hrs/yr 140.0

[Assumes 100% VTD annual capacity factor. Est actual <25%.]

Boiler(s) Nominal 39k lb/hr steam capacity x x PM10 7.6 lb/mmcf 48.4 mcf/hr 25 min vac.degass 0.37 300,000 mcf/yr 8,208 hrs/yr 1.14

Natural Gas fire only CO 84 lb/mmcf 48.4 mcf/hr per heat 4.06 300,000 mcf/yr 8,208 hrs/yr 12.60

5 Ohio Special firetube boilers NOx 0.100 lb/MMBtu 49.3 MMBtu/hr 4.93 300,000 mcf/yr 8,208 hrs/yr 15.30

~9.865 MMBtu/hr each SO2 0.6 lb/mmcf 48.4 mcf/hr 0.03 300,000 mcf/yr 8,208 hrs/yr 0.09


PT

I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

V&M-2008 PSD mod emissions-rev0.xls/ProposedModEmissionsData Rev.: 10/17/2008

2 of 4



code Source Discharge Point Pollutant Units Units Units lb/hr Units Units tons/yrPT

I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

MPM Pipe Mill

P001 Billet Reheat Furnace x PM10 7.6 lb/mmcf 284.31 mcf/hr 2.16 1,750,000 mcf/yr 8,024 hrs/yr 6.65

CO 84 lb/mmcf 284.31 mcf/hr 23.9 1,750,000 mcf/yr 8,024 hrs/yr 73.50

NOx 0.10 lb/MMBtu 290.00 MMBtu/hr 29.0 1,750,000 mcf/yr 8,024 hrs/yr 89.25

SO2 0.6 lb/mmcf 284.31 mcf/hr 0.17 1,750,000 mcf/yr 8,024 hrs/yr 0.53

VOC 5.5 lb/mmcf 284.31 mcf/hr 1.6 1,750,000 mcf/yr 8,024 hrs/yr 4.81

P011 Billet Preheat Furnace (previously proposed) x [Permitted for installation by PTI P0103660, installation canceled.]

New Pipemill Scrubber (Sept.2008 PTI) x PM10 0.004 gr/dscf 329,000 dscfm 11.28 8,760 hrs/yr 49.41

P002 MPM Pipemill Scrubber x x

P002 Sizings Pipemill Scrubber x x

P002 Existing Plasma Arc Torch x x PM10 0.01 gr/dscf 1,900 dscfm 0.16 8,024 hrs/yr 0.65

P010 New Plasma Arc Torch (Sept.2008 PTI) x PM10 0.01 gr/dscf 1,900 dscfm 0.16 8,760 hrs/yr 0.71

New FQM Pipe Mill

Billet Rotary Hearth Furnace x PM10 7.6 lb/mmcf 199.02 mcf/hr 1.51 932,001 mcf/yr 8,760 hrs/yr 3.54

Installed burners 265 MMBtu/h CO 84 lb/mmcf 199.02 mcf/hr 16.72 932,001 mcf/yr 8,760 hrs/yr 39.14

Max firing capacity 203 MMBtu/h NOx 0.08 lb/MMBtu 203 MMBtu/hr 16.24 932,001 mcf/yr 8,760 hrs/yr 38.03



Pipe Intermediate Furnace x PM10 7.6 lb/mmcf 86.27 mcf/hr 0.66 399,427 mcf/yr 8,760 hrs/yr 1.52





Mandrel Furnace x x PM10 7.6 lb/mmcf 4.31 mcf/hr 0.03 5,325 mcf/yr 8,760 hrs/yr 0.02

Installed burners 4.4 MMBtu/h CO 84 lb/mmcf 4.31 mcf/hr 0.36 5,325 mcf/yr 8,760 hrs/yr 0.22

Max firing capacity 4.4 MMBtu/h NOx 0.12 lb/MMBtu 4.4 MMBtu/hr 0.53 5,325 mcf/yr 8,760 hrs/yr 0.33



Pipemill Scrubber x PM10 0.004 gr/dscf 157,913 dscfm 5.41 8,760 hrs/yr 23.71

Pipe Austenitizing Furnace #1 x PM10 7.6 lb/mmcf 31.4 mcf/hr 0.24 173,145 mcf/yr 8,760 hrs/yr 0.66





Pipe Tempering Furnace #1 x PM10 7.6 lb/mmcf 26.5 mcf/hr 0.20 149,534 mcf/yr 8,760 hrs/yr 0.57


Max firing capacity 26.5 MMBtu/h NOx 0.08 lb/MMBtu 27 MMBtu/hr 2.16 149,534 mcf/yr 8,760 hrs/yr 6.10




3 of 4




I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

Pipe Austenitizing Furnace #2 x PM10 7.6 lb/mmcf 31.4 mcf/hr 0.24 173,145 mcf/yr 8,760 hrs/yr 0.66





Pipe Tempering Furnace #2 x PM10 7.6 lb/mmcf 26.5 mcf/hr 0.20 149,534 mcf/yr 8,760 hrs/yr 0.57


Max firing capacity 26.5 MMBtu/h NOx 0.08 lb/MMBtu 27 MMBtu/hr 2.16 149,534 mcf/yr 8,760 hrs/yr 6.10



Green Steel Abrasives Manufacturing

Raw Materials Handling x x PM10 0.005 gr/scf 1582 scfm 0.07 8,760 hrs/yr 0.14

Melter Furnace x PM10 10 lb/ton 4.81 ton/hr 99% % control 0.48 8,760 hrs/yr 2.11

Scrubber 5,576 dscfm 0.010 gr/dscf

CO 0.2 lb/ton 4.81 ton/hr 0.96 8,760 hrs/yr 4.21

NOx 0.5 lb/MMBtu 20.1 MMBtu/hr 10.05 8,760 hrs/yr 44.02

SO2 3.4 lb/ton 4.81 ton/hr 90% % control 1.64 8,760 hrs/yr 7.16

VOC 0.2 4.81 ton/hr 0.96 8,760 hrs/yr 4.21

Pb 1.27% of PM 0.006 8760 hr/yr 0.03

Sodium Hydroxide Tank (20% NaOH) x x (No quantifiable emission) 8,760 hrs/yr

Finished Product Handling x PM10 0.005 gr/dscf 20,000 dscfm 0.86 8760 hr/yr 3.75

Baghouse 23,000 acfm

Fore Hearth heater x x PM10 7.6 lb/mmcf 0.200 MMBtu/hr 0.00020 mmcf/hr 0.0015 8760 hr/yr 0.007

CO 84 lb/mmcf 0.200 0.00020 0.0165 8760 hr/yr 0.072

NOx 100 lb/mmcf 0.200 0.00020 0.0196 8760 hr/yr 0.086

SO2 0.6 lb/mmcf 0.200 0.00020 0.00012 8760 hr/yr 0.0005

VOC 5.5 lb/mmcf 0.200 0.00020 0.0011 8760 hr/yr 0.005

Site Support

Cooling Towers: max.flow max.TDS avg.flow avg.TDS

P007 Cooling Tower 2, 3 cells x x PM10 0.005% drift 1,200,000 gph 1400 ppm TDS 0.70 990,000 gph 850 ppm TDS 1.54

Cooling Tower 2A, 3 cells x x PM10 0.005% drift 960,000 gph 840 ppm TDS 0.34 888,000 gph 700 ppm TDS 1.14

Cooling Tower 4, 4 cells x x PM10 0.005% drift 750,000 gph 840 ppm TDS 0.26 750,000 gph 700 ppm TDS 0.96

Cooling Tower 6, refining-caster contact w. x x PM10 0.005% drift 180,000 gph 840 ppm TDS 0.06 750,000 gph 700 ppm TDS 0.96

Cooling Tower 1, LMF, VTD non-contact w. x PM10 0.005% drift 900,000 gph 1000 ppm TDS 0.38 900,000 gph 1000 ppm TDS 1.64

Cooling Tower 1A, LMF, VTD contact water x PM10 0.005% drift 300,000 gph 1000 ppm TDS 0.13 300,000 gph 1000 ppm TDS 0.55

Cooling Tower 7, FQM Contact Water x PM10 0.005% drift 1,200,000 gph 1000 ppm TDS 0.50 1,200,000 gph 1000 ppm TDS 2.19

Cooling Tower 8, FQM Non-Contact Water x PM10 0.005% drift 600,000 gph 1000 ppm TDS 0.25 600,000 gph 1000 ppm TDS 1.10


4 of 4




I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

F001 Roadways: Max. emission factor Avg. emission factor

Paved Roads, Road A (scrap) x x PM10 0.024 lb/veh.mi. 122 trips/day 1.33 miles/veh.trip 0.162 0.022 lb/veh.mi. 365 days/yr 0.63

Paved Roads, Road B1 (commodity & tube) x x PM10 0.024 lb/veh.mi. 33 trips/day 0.82 miles/veh.trip 0.027 0.022 lb/veh.mi. 365 days/yr 0.11

Paved Roads, Road B2 (FQM com'ity & tube) x x PM10 0.024 lb/veh.mi. mixed trips/day mixed miles/veh.trip 0.028 0.022 lb/veh.mi. 365 days/yr 0.11

Paved Roads, Road C (slag) x x PM10 0.024 lb/veh.mi. 31 trips/day 0.35 miles/veh.trip 0.011 0.022 lb/veh.mi. 365 days/yr 0.04

Paved Roads, Road D (ladle carrier) x x PM10 0.308 lb/veh.mi. 33 trips/day 0.68 miles/veh.trip 0.288 0.276 lb/veh.mi. 365 days/yr 1.13

Paved Roads, Road E (transporter) x x PM10 0.125 lb/veh.mi. mixed trips/day mixed miles/veh.trip 0.440 0.084 lb/veh.mi. 365 days/yr 1.30

Unpaved Roads, Road A (scrap) x x PM10 0.729 lb/veh.mi. 122 trips/day 0.24 miles/veh.trip 0.872 0.429 lb/veh.mi. 365 days/yr 2.25

Unpaved Roads, Road B (commodity & tube) x x PM10 0.729 lb/veh.mi. 33 trips/day 0.00 miles/veh.trip 0.000 0.429 lb/veh.mi. 365 days/yr 0.00

Unpaved Roads, Road C (slag) x x PM10 0.729 lb/veh.mi. 31 trips/day 0.37 miles/veh.trip 0.356 0.429 lb/veh.mi. 365 days/yr 0.92

Unpaved Roads, Road E (transporter) x x PM10 1.194 lb/veh.mi. mixed trips/day mixed miles/veh.trip 0.30 0.704 lb/veh.mi. 365 days/yr 0.77

Standby (Emergency) Diesel Generators & Miscellaneous Combustion

Standby (Emergency) Diesel Generator Sets x PM10 0.11 g/hp-hr 1482 hp 5 units 100 hrs/yr 0.09

3 FQM pipe mill standby generators CO 0.66 g/hp-hr prel.size 1,000 kW 0.54

each = 1 MW (~1482 hp) NOx 3.95 g/hp-hr Cummins or equal 3.22

2 meltshop standby generators SO2 0.00809 lb/hph*%S 0.05 % Sulfur 0.15

each = 1 MW (~1482 hp) VOC 0.064 g/hp-hr 0.05

Miscellaneous NG burners ≤5 MMBtu/hr x x x PM10 7.6 lb/mmcf 28.00 mcf/hr 0.21 8,208 hrs/yr 0.87

R Bay-ladle & tundish dryers CO 84 lb/mmcf 28.00 mcf/hr 2.35 8,208 hrs/yr 9.65

EAF bldg-vert.ladle hold burner NOx 100 lb/mmcf 28.00 mcf/hr 2.80 8,208 hrs/yr 11.49

Caster-tundish htrs,shroud,torch SO2 0.6 lb/mmcf 28.00 mcf/hr 0.017 8,208 hrs/yr 0.07

VOC 5.5 lb/mmcf 28.00 mcf/hr 0.154 8,208 hrs/yr 0.63


1 of 2

Table 1-2 V & M Star Baseline Emission Rate Calculations

Baseline 2004-2006 Prior Actual Emissions

Production basis: 110 tons liquid steel/hour

667,344 tons liquid steel/year


Emission Factor Process Factor Other Control Factor Emission Process Factor Operating Hr Basis Annual

Source Discharge Point Pollutant Units Units Units lb/hr Units Units tons/yr

Modified Existing Meltshop Building

EAF/LRS Existing Meltshop Baghouse x PM10 0.0018 gr/dscf 619,584 dscfm 9.56 7,394 hrs/yr 35.34

CO 4.0 lb/ton 110 tons/hr 440.0 667,344 tons/yr 7,394 hrs/yr 1,334.7

NOx 0.4 lb/ton 110 tons/hr 44.0 667,344 tons/yr 7,394 hrs/yr 133.5

SO2 0.25 lb/ton 110 tons/hr 27.5 667,344 tons/yr 7,394 hrs/yr 83.4

VOC 0.18 lb/ton 110 tons/hr 19.8 667,344 tons/yr 7,394 hrs/yr 60.1

Pb 1.7% % of PM 110 tons/hr 0.16 667,344 tons/yr 7,394 hrs/yr 0.60

EAF/LRS Meltshop Fugitives x PM10 1.4 lb PE/ton 110 tons/hr 99% % control 1.17 667,344 tons/yr 7,394 hrs/yr 3.55

76% PM10/PE %

Pb 1.7% % of PM 110 tons/hr 0.020 667,344 tons/yr 7,394 hrs/yr 0.060

Ladle Pre-heaters x PM10 7.6 lb/mmcf 14.71 mcf/hr 0.11 8,018 hrs/yr 0.45

(3 @ 5 MMBtu/hr) CO 84 lb/mmcf 14.71 mcf/hr 1.24 8,018 hrs/yr 4.95

NOx 100 lb/mmcf 14.71 mcf/hr 1.47 8,018 hrs/yr 5.90

SO2 0.6 lb/mmcf 14.71 mcf/hr 0.009 8,018 hrs/yr 0.04


Caster x PM10 0.07 lb/ton 110 tons/hr 95% % control 0.39 667,344 tons/yr 7,394 hrs/yr 1.17

NOx 0.05 lb/ton 110 tons/hr 5.5 667,344 tons/yr 7,394 hrs/yr 16.68

Alloy, Additives, Flux, Lime x PM10 8.00E-04 lb/ton 110 tons/hr 0.09 667,344 tons/yr 7,394 hrs/yr 0.27

MPM Pipe Mill as It Will Exist at Completion of Project

Billet Reheat Furnace x PM10 7.6 lb/mmcf 161.76 mcf/hr 1.23 1,021,142 mcf/yr 7,721 hrs/yr 3.88

CO 84 lb/mmcf 161.76 mcf/hr 13.6 1,021,142 mcf/yr 7,721 hrs/yr 42.89

NOx 0.11 lb/MMBtu 165.00 MMBtu/hr 18.2 1,021,142 mcf/yr 7,721 hrs/yr 57.29

SO2 0.6 lb/mmcf 161.76 mcf/hr 0.10 1,021,142 mcf/yr 7,721 hrs/yr 0.31

VOC 5.5 lb/mmcf 161.76 mcf/hr 0.9 1,021,142 mcf/yr 7,721 hrs/yr 2.81

New Pipemill Scrubber (Sept.2008 PTI) x

MPM Pipemill Scrubber x PM10 0.0086 gr/dscf 85,130 dscfm 6.28 7,721 hrs/yr 24.23

Sizings Pipemill Scrubber x PM10 0.004 gr/dscf 130,508 dscfm 4.47 7,721 hrs/yr 17.27

Existing Plasma Arc Torch x PM10 0.01 gr/dscf 1,900 dscfm 0.16 7,721 hrs/yr 0.63

New Plasma Arc Torch (Sept.2008 PTI) x PM10

Site Support

Cooling Towers: max.flow max.TDS avg.flow avg.TDS

Cooling Tower 2 x PM10 0.005% drift 1,380,000 gph 1400 ppm TDS 0.81 1,170,000 gph 850 ppm TDS 1.82

Cooling Tower 2A x PM10 0.005% drift 750,000 gph 840 ppm TDS 0.26 690,000 gph 700 ppm TDS 0.88

Cooling Tower 4 x PM10 0.005% drift 420,000 gph 840 ppm TDS 0.15 282,600 gph 700 ppm TDS 0.36

Cooling Tower 6, refining-caster contact w. x PM10 0.005% drift 180,000 gph 840 ppm TDS 0.06 750,000 gph 700 ppm TDS 0.96

PT

I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

V&M-2008 PSD mod emissions-rev0.xls/PriorEmissions Rev.: 10/07/2008

2 of 2


Emission Factor Process Factor Other Control Factor Emission Process Factor Operating Hr Basis Annual

Source Discharge Point Pollutant Units Units Units lb/hr Units Units tons/yrPT

I E

xem

pt

Rem

oved

New

Sourc

e

Exis

ting

Modifie

d

No c

hange

Roadways: Max. emission factor Avg. emission factor

Paved Roads, Road A (scrap) x PM10 0.024 lb/veh.mi. 58 trips/day 1.28 miles/veh.trip 0.074 0.022 lb/veh.mi. 365 days/yr 0.29

Paved Roads, Road B (commodity & tube) x PM10 0.024 lb/veh.mi. 16 trips/day 0.88 miles/veh.trip 0.014 0.022 lb/veh.mi. 365 days/yr 0.06

Paved Roads, Road C (slag) x PM10 0.024 lb/veh.mi. 15 trips/day 0.35 miles/veh.trip 0.005 0.022 lb/veh.mi. 365 days/yr 0.02

Paved Roads, Road E (transporter) x PM10 0.125 lb/veh.mi. mixed trips/day mixed miles/veh.trip 0.302 0.084 lb/veh.mi. 365 days/yr 0.89

Unpaved Roads, Road A x PM10 0.729 lb/veh.mi. 58 trips/day 0.24 miles/veh.trip 0.416 0.429 lb/veh.mi. 365 days/yr 1.07

Unpaved Roads, Road B x PM10 0.729 lb/veh.mi. 16 trips/day 0.19 miles/veh.trip 0.091 0.429 lb/veh.mi. 365 days/yr 0.23

Unpaved Roads, Road C x PM10 0.729 lb/veh.mi. 15 trips/day 0.37 miles/veh.trip 0.170 0.429 lb/veh.mi. 365 days/yr 0.44

Unpaved Roads, Road E (transporter) x PM10 1.194 lb/veh.mi. mixed trips/day mixed miles/veh.trip 0.299 0.704 lb/veh.mi. 365 days/yr 0.77

Miscellaneous NG burners ≤5 MMBtu/hr x x PM10 7.6 lb/mmcf 28.00 mcf/hr 0.21 8,018 hrs/yr 0.85

R Bay-ladle & tundish dryers CO 84 lb/mmcf 28.00 mcf/hr 2.35 8,018 hrs/yr 9.43

EAF bldg-vert.ladle hold burner NOx 100 lb/mmcf 28.00 mcf/hr 2.80 8,018 hrs/yr 11.23

Caster-tundish htrs,shroud,torch SO2 0.6 lb/mmcf 28.00 mcf/hr 0.017 8,018 hrs/yr 0.07


V&M-2008 PSD mod emissions-rev0.xls/PriorEmissions Rev.: 10/07/2008

1 of 4Table 1-3 V & M Star Annual Emission Rates Summary

2008 Application Emissions for Melt Shop, Refining and Caster Upgrades and New FQM Pipe Mill

Production basis: 1,400,000 tons liquid steel/year

Pollutants

tons/year

Source Discharge Point PM10 CO NOx SO2 VOC Pb

Meltshop, Refining and Billet Casting

EAF/LMF New EAF/LMF Baghouse x x 62.1 2,800 280.0 175.0 126.0 1.05

EAF/LMF Meltshop Fugitives x x 7.4 - - - - 0.13

Ladle Pre-heaters (3 @ 5 MMBtu/hr) x x 0.46 5.1 6.0 0.04 0.33 -

EAF additive, alloy & flux handling x x 0.56 - - - - -

LMF Alloys & Flux bulk handling x incl w/BH - - - - -

New EAF/LMF Baghouse

Caster New EAF/LMF Baghouse x x incl w/BH - 35.0 [NOx additive to bh exhaust]

VTD Vacuum System x 1.4 140 -

VTD Boiler x x 1.1 12.6 15.3 0.09 0.8 -

MPM Pipe Mill

Billet Reheat Furnace x 6.7 73.5 89.3 0.53 4.8 -

Billet Preheat Furnace (previously proposed) x

New Pipemill Scrubber (Sept.2008 PTI) x 49.4 - - - - -

MPM Pipemill Scrubber x x - - - - - -

Sizings Pipemill Scrubber x x - - - - - -

Existing Plasma Arc Torch x x 0.65 - - - - -

New Plasma Arc Torch (Sept.2008 PTI) x 0.71 - - - - -

New FQM Pipe Mill

Billet Rotary Hearth Furnace x 3.5 39.1 38.0 0.3 2.6 -

Pipe Intermediate Furnace x 1.5 16.8 16.3 0.12 1.1 -

Mandrel Furnace x x 0.02 0.22 0.33 0.002 0.015 -

Pipemill Scrubber x 23.7 - - - - -

Pipe Austenitizing Furnace #1 x 0.7 7.3 7.1 0.1 0.5 -

Pipe Tempering Furnace #1 x 0.6 6.3 6.1 0.0 0.4 -




G-S Raw Materials Handling x 0.14

G-S Melter Furnace x 2.1 4.2 44.0 7.2 4.2 0.03

G-S Finished Product Handling x 3.8

G-S Fore Hearth heater x x 0.007 0.07 0.09 0.0005 0.005

Site Support

Cooling Towers: x x x x 10.07 - - - - -

Roadways: x x 7.27 - - - - -

Standby/Emergency Diesel Gen Sets (5) x 0.09 0.54 3.22 0.15 0.05

Miscellaneous NG burners ≤5 MMBtu/hr x x 0.87 9.7 11.5 0.07 0.63

PM10 CO NOx SO2 VOC Pb

Total Site Emissions (tons/yr) 186.0 3,128.9 565.4 183.6 142.3 1.21

PT

I E

xe

mp

t

Re

mo

ve

d

Ne

w S

ou

rce

Exis

tin

g

Mo

difie

d

No

ch

an

ge

V&M-2008 PSD mod emissions-rev0.xls/Proposed & Prior Summary Rev.: 10/07/2008


2004/2006 Baseline Prior Actual Operations and Emissions

Production basis: 667,344 tons liquid steel/year

Pollutants

tons/year



EAF/LRS Existing Meltshop Baghouse x x 35.3 1,334.7 133.5 83.4 60.1 0.60

EAF/LRS Meltshop Fugitives x x 3.6 - - - - 0.06


EAF/LMF Alloy, Additives, Flux, Lime x x 0.27 - - - - -

Caster x x 1.2 - 16.7 - - -

LMF Alloy, Additives, Flux, Lime x - - - - -

MPM Pipe Mill

Billet Reheat Furnace x x 3.9 42.9 57.3 0.31 2.8 -

New Pipemill Scrubber (Sept.2008 PTI) x - - - - - -

MPM Pipemill Scrubber x x 24.2 - - - - -

Sizings Pipemill Scrubber x x 17.3 - - - - -

Existing Plasma Arc Torch x x 0.63 - - - - -

New Plasma Arc Torch (Sept.2008 PTI) x - - - - - -

Site Support

Cooling Towers: x x x x 4.02 - - - - -

Roadways: x x 3.78 - - - - -



Total Site Prior Actual Emissions (tons/yr) 95.4 1,392 224.6 83.8 63.8 0.66

PT

I E

xe

mp

t

Ne

w S

ou

rce

Exis

tin

g

Mo

difie

d

No

ch

an

ge

Re

mo

ve

d



Net Change for Melt Shop, Refining and Caster Upgrades and New FQM Pipe Mill

Production basis: Future Actual/Allowable 1,400,000 tons liquid steel/year

Baseline 2004-2006 667,344 tons liquid steel/year

Pollutants Change (Future Minus Prior Actual)

tons/year



EAF/LMF New Meltshop Baghouse x x 26.71 1,465.31 146.53 91.58 65.94 0.45

EAF/LMF Meltshop Fugitives x x 3.90 0.066


EAF Alloy, Additives, Flux, Lime x x 0.29

LMF Alloy, Additives, Flux, Lime x

Caster x x x (1.17) 18.32

VTD Vacuum System x 1.40 140.00 -

VTD Boiler x 1.14 12.60 15.30 0.09 0.83 -

MPM Pipe Mill

Billet Reheat Furnace x x 2.77 30.61 31.96 0.22 2.00 -

New Pipemill Scrubber (Sept.2008 PTI) x 49.41

MPM Pipemill Scrubber x x (24.23)

Sizings Pipemill Scrubber x x (17.27)

Existing Plasma Arc Torch x x 0.02

New Plasma Arc Torch (Sept.2008 PTI) x 0.71

New FQM Pipe Mill

Billet Rotary Hearth Furnace x 3.5 39.1 38.0 0.3 2.6 -

Pipe Intermediate Furnace x 1.5 16.8 16.3 0.1 1.1 -

Mandrel Furnace x x 0.0 0.2 0.3 0.0 0.0 -

Pipemill Scrubber x 23.7 - - - - -






G-S Raw Materials Handling x 0.14

G-S Melter Furnace x 2.11 4.21 44.02 7.16 4.21 0.03

G-S Finished Product Handling x 3.75

G-S Fore Hearth heater x x 0.01 0.07 0.09 0.00 0.00

Site Support

Cooling Towers: x x x x 6.05

Roadways: x x 3.49

Standby/Emergency Diesel Gen Sets (5) x 0.09 0.54 3.22 0.15 0.05



Site net change in emissions (tons/yr) 90.6 1,737 340.8 99.8 78.5 0.55

PT

I E

xe

mp

t

Re

mo

ve

d

Ne

w S

ou

rce

Exis

tin

g

Mo

difie

d

No

ch

an

ge



Site Emissions Change Summary and PSD Applicability

Pollutants Change (Future Minus Prior Actual)

Project PSD Applicability tons/year


Proposed Modified Source Emissions 186 3,129 565 184 142 1.21

Prior Actual Emissions 95 1,392 225 84 64 0.66

Net Change in Emissions 91 1,737 341 100 79 0.55

PSD Significant Thresholds 15 100 40 40 40 0.6

PSD Review Applicability Yes Yes Yes Yes Yes No


Table 2-13

VTD Boiler NOx Reduction Cost Effectiveness Analysis

BOILER CONCEPT 1 Water Tube 1 Water Tube Multiple Firetube

ULN w/25% FGR ULN w/FGR "Ohio Special"

CAPITAL COST 9 ppm 30 ppm 80 ppm

Direct Costs (DC)

Purchased Equipment Costs (PE)

Basic equipment: (A) 1,314,816 1,228,800 550,000

Auxiliary equipment (B) x% A incl. 0 incl. 0 vendor 630,000

Instrumentation (C) 0 A incl. 0 incl. 0 incl. 0

Taxes & Freight 0.08 ABC 105,185 98,304 94,400

PE Total 1,420,001 1,327,104 1,274,400

Direct Installation Costs (DI)

Furnace modifications supplier estimate-incl.in basic 0 0 0

Handling & erection 0.14 PE 198,800 185,795 178,416

Electrical (for larger motor) 0.04 PE undet.diff. 60 HP undet.diff. 50 HP base 40 HP

Piping (assume no diff.) 0 PE 0 0 0

Insulation 0.01 PE 14,200 13,271 12,744

Painting 0.01 PE 14,200 13,271 12,744

DI Total 227,200 212,337 203,904

Site Preparation & Buildings allowance 100,000 100,000 100,000

DC Total 1,747,201 1,639,441 1,578,304

Indirect Costs (IC)

Engineering 0.10 PE 142,000 132,710 127,440

Const. & field exp. 0.05 PE 71,000 66,355 63,720

Contractor fees 0.10 PE 142,000 132,710 127,440

Start-up 0.02 PE 28,400 26,542 25,488

Performance test $4,000 per test 4,000 4,000 4,000

Contingencies 0.03 PE 42,600 39,813 38,232

IC Total 430,000 402,131 386,320

Total Capital Investment (TCI) 2,177,202 2,041,572 1,964,624

ANNUAL COST

Direct Annual Costs (DAC)

Operating

Operator hr/shift $47/hr 8 hr/shift 385,776 8 hr/shift 385,776 0.5 hr/shift 24,111

Supervisor 15%op 57,866 57,866 3,617

Maintenance

Labor 0.5 h/shift $47/hr 24,111 24,111 24,111

Material 100%labor 24,111 24,111 24,111

Annual service (increase)

Instrument & burner service undetermined undet. undet.

Utilities (assuming 75% annual capacity for fuel costs)

Natural gas $9.94/mcf (boiler eff. differences) 2,918,151 2,907,717 2,982,000

Electricity $0.053/kwh (FGR added HP) 60 HP 19,472 50 HP 16,226 40 HP 12,981

Total DAC 3,429,487 3,415,807 3,070,931

Indirect Annual Costs (IAC)

Overhead 60% O & M labor 295,119 295,119 45,570

Administrative 0.02 TCI 43,544 40,831 39,292

Insurance 0.01 TCI 21,772 20,416 19,646

Property tax 0.01 TCI 21,772 20,416 19,646

Capital recovery CRF(10yr,7%) 0.1424 TCI 309,985 290,674 279,718

Total IAC 692,191 667,455 403,873

Total Annual Cost 4,121,678 4,083,263 3,474,804

COST EFFECTIVENESS

NOx performance, ppmvd @ 3% O2 9 30 80

NOx performance equivalent, lb/MMBtu 0.011 0.036 0.100

Baseline Emission, allowable tons/yr 1.7 5.5 15.3

Emission Reduction, tons/yr 13.6 9.8 0.0

Average Cost Effectiveness, $/ton 47,417 62,138 NA baseline

Incremental Cost Effectiveness for Next Alternative, $/ton 9,977 62,138

Incremental Cost Effectiveness for Proposed Alternative, $/ton 47,417 62,138

TopDownBoilerCosts-rev0.xls/BoilerIncrement$ Rev: 0, Oct. 2008

Table 2-14 1 of 5

New FQM Seamless Pipe Mill Furnaces Rotary Hearth Furnace

EMISSION DATA FOR NEW SEAMLESS PIPE MILL AND

FINISHING AREA HOT COMBUSTION AIR

Furnace Name/Description Rotary Hearth Furnace Notes:

Charging Rate 140 t/hr 154.2 ston/hr

Max Production Rate 140 t/hr 154.2 ton/hr

Annual Scheduled Production 450,000 t/yr 495,595 ston/yr

Annual Design Production Capacity 600,000 t/yr 660,793 ston/yr

Product Discharge Temp. 1,280 °C 2,336 °F

Burner Information

Fuel Nat.Gas Nat.Gas

N.G.Lower Heating Value 8,747 kcal/Nm3 930 Btu/scf Nm3 (0ºC and 760 mmHg)

N.G.Higher Heating Value 9,688 kcal/Nm3 1,030 Btu/scf SCF(60ºF and 29.92 "Hg)

Number of furnace zones 8 Nr 8 Nr

Number of Burners 76 Nr 76 Nr

Total installed capacity (HOT AIR + NG)(Based on HHV) 78,936 Mcal/h 313 106Btu/hr Based on gross calorific value

Installed capacity from NG (Based on HHV) 66,802 Mcal/h 265 106Btu/hr Based on gross calorific value

Installed capacity from HOT AIR 12,134 Mcal/h 48 106Btu/hr

Total firing capacity (HOT AIR + NG)(Based on HHV) 60,577 Mcal/h 240 106Btu/hr Based on gross calorific value

Firing capacity from NG (Based on HHV) 51,266 Mcal/h 203 106Btu/hr Based on gross calorific value

Firing capacity from HOT AIR 9,312 Mcal/h 37 106Btu/hr

Firing Capacity (Natural Gas flow) 5,292 Nm3/hr 197,510 SCF/hr

Wet waste gas 11.579 Nm3/Nm3 11.579 scf/scf Including air infiltration

Dry waste gas 9.67 Nm3/Nm3 9.67 scf/scf Including air infiltration

Wet waste gas 100.00 % 100.00 % Including air infiltration

Dry waste gas 83.53 % 83.53 % Including air infiltration

Scheduled Annual production 450,000 t/yr 495,595 ston/yr

Capacity/Maximum Annual production 600,000 t/yr 660,793 ston/yr

Max Total Annual Heat Input (from NG, LHV) 210,000,000 Mcal/yr 833,343 106Btu/yr Based on net calorific value

Max Total Annual Heat Input (from NG, HHV) 232,580,645 Mcal/yr 922,950 106Btu/yr Based on gross calorific value

Max Total Annual fuel consumption 24,242,670 Nm3/yr 904,844,180 SCF/yr

Annual average hourly input rate, HHV 27,609 Mcal/hr 109.6 106Btu/hr Based on 8424 hours and HHV

Annual average hourly NG flow rate 2,850 Nm3/hr 106,370 SCF/hr Based on 8424 hours

Exhaust Gas Parameters

Furnace Exhaust Temp.to Recuperator 910 °C 1670 °F

Ehaust Gas Temp to Stack Outlet 410 °C 770 °F

Exhaust Gas Oxygen at Recup.Outlet 2 % O2 2 % O2

Exhaust Gas Oxygen at Stack Outlet 2 % O2 2 % O2

Exhaust Gas Outlet Flow Rate, (max firing capacity) 61,273 Nm3/hr 38,116 scf/min Including air infiltration

Exhaust Gas Flow Rate at stack temperature (max firing capacity) 153,294 m3/hr 90,159 cf/min Actual flow

Exhaust gas moisture (volume based ratio) 16.47 % H2O 16.47 % H2O

Stack Parameters

Stack Height (force draught - exhaust fan type) 24.4 m 80.0 ft

Stack Diameter (force draught - exhaust fan type) 2.0 m 6.56 ft

NOx Emissions

NOx vendor predicted max @ 3%O2 at nominal production rate (DRY) 119 mg/Nm3

58 ppm

NOx vendor predicted max emission performance 30.0 g/GJ 0.070 lb/MMBtu

NOx vendor predicted max emission rate 6.44 kg/hr 14.21 lb/hr

Proposed allowable NOx (15% margin for confidence, test error,

degradation between maint.)

NOx proposed BACT emission performance 34.53 g/GJ 0.080 lb/MMBtu

NOx proposed allowable emission rate 7.41 kg/hr 16.34 lb/hr

Other Emissions Based on AP-42 Emission Factors for NG Combustion

CO predicted performance 0.082 lb/MMBtu

CO maximum emission rate 16.75 lb/hr

VOC predicted performance 0.0054 lb/MMBtu

VOC maximum emission rate 1.10 lb/hr

PM10 predicted performance 0.0075 lb/MMBtu

PM10 maximum emission rate 1.52 lb/hr

SO2 predicted performance 0.0006 lb/MMBtu

SO2 maximum emission rate 0.12 lb/hr

The furnaces employ the best NOx performance burners available for this application.

FQM Furnaces-rev0.xls FurnaceData-Emission

Table 2-14

New FQM Seamless Pipe Mill Furnaces


FINISHING AREA

Furnace Name/Description

Charging Rate

Max Production Rate

Annual Scheduled Production

Annual Design Production Capacity

Product Discharge Temp.

Burner Information

Fuel

N.G.Lower Heating Value

N.G.Higher Heating Value

Number of furnace zones

Number of Burners

Total installed capacity (HOT AIR + NG)(Based on HHV)

Installed capacity from NG (Based on HHV)

Installed capacity from HOT AIR

Total firing capacity (HOT AIR + NG)(Based on HHV)

Firing capacity from NG (Based on HHV)

Firing capacity from HOT AIR

Firing Capacity (Natural Gas flow)

Wet waste gas

Dry waste gas

Wet waste gas

Dry waste gas

Scheduled Annual production

Capacity/Maximum Annual production

Max Total Annual Heat Input (from NG, LHV)

Max Total Annual Heat Input (from NG, HHV)

Max Total Annual fuel consumption

Annual average hourly input rate, HHV

Annual average hourly NG flow rate


Furnace Exhaust Temp.to Recuperator

Ehaust Gas Temp to Stack Outlet

Exhaust Gas Oxygen at Recup.Outlet

Exhaust Gas Oxygen at Stack Outlet

Exhaust Gas Outlet Flow Rate, (max firing capacity)

Exhaust Gas Flow Rate at stack temperature (max firing capacity)Exhaust gas moisture (volume based ratio)

Stack Parameters

Stack Height (force draught - exhaust fan type)

Stack Diameter (force draught - exhaust fan type)

NOx Emissions

NOx vendor predicted max @ 3%O2 at nominal production rate (DRY)

NOx vendor predicted max emission performance

NOx vendor predicted max emission rate



NOx proposed BACT emission performance

NOx proposed allowable emission rate


CO predicted performance

CO maximum emission rate

VOC predicted performance

VOC maximum emission rate

PM10 predicted performance

PM10 maximum emission rate

SO2 predicted performance

SO2 maximum emission rate


2 of 5

Mandrel Furnace

COLD COMBUSTION AIR

Mandrel FceN.A. t/hr N.A. ston/hr

N.A. t/hr N.A. ton/hr

30,000 t/yr 33,040 ston/yr

40,000 t/yr 44,053 ston/yr

150 °C 302 °F

Nat.Gas Nat.Gas

8,747 kcal/Nm3 930 Btu/scf

9,688 kcal/Nm3 1,030 Btu/scf

1 Nr 1 Nr

1 Nr 1 Nr

1,108 Mcal/h 4.4 106Btu/hr

1,108 Mcal/h 4.4 106Btu/hr

N.A. Mcal/h N.A. 106Btu/hr

1,108 Mcal/h 4.4 106Btu/hr

1,108 Mcal/h 4.4 106Btu/hr

0 Mcal/h 0 106Btu/hr

114 Nm3/hr 4,267 SCF/hr

12.955 Nm3/Nm3 12.955 scf/scf

11.05 Nm3/Nm3 11.05 scf/scf

100.00 % 100.00 %

85.28 % 85.28 %

30,000 t/yr 33,040 ston/yr

40,000 t/yr 44,053 ston/yr

1,200,000 Mcal/yr 4,762 106Btu/yr

1,329,032 Mcal/yr 5,274 106Btu/yr

138,530 Nm3/yr 5,170,587 SCF/yr

158 Mcal/hr 0.63 106Btu/hr

16 Nm3/hr 608 SCF/hr

N/A °C N/A °F

350 °C 662 °F

N/A % O2 N/A % O2

5 % O2 5 % O2

1,481 Nm3/hr 921 scf/min

3,651 m3/hr 2,179 cf/min

14.72 % H2O 14.72 % H2O

19.5 m 64 ft

0.38 m 1.25 ft

200 mg/Nm3

98 ppm

43.0 g/GJ 0.1000 lb/MMBtu

0.20 kg/hr 0.44 lb/hr

49.46 g/GJ 0.115 lb/MMBtu

0.23 kg/hr 0.51 lb/hr

0.082 lb/MMBtu

0.36 lb/hr

0.0054 lb/MMBtu

0.02 lb/hr

0.0075 lb/MMBtu

0.03 lb/hr

0.0006 lb/MMBtu

0.00 lb/hr


Table 2-14



FINISHING AREA


Charging Rate

Max Production Rate




Burner Information

Fuel




Number of Burners








Wet waste gas

Dry waste gas

Wet waste gas

Dry waste gas















Stack Parameters



NOx Emissions


















3 of 5

Intermediate Furnace

NORMALIZATION CYCLE

HOT COMBUSTION AIR COLD COMBUSTION AIR

Intermediate Fce Intermediate Fce140.0 t/hr 154.2 ston/hr 140.0 t/hr 154.2 ston/hr

140.0 t/hr 154.2 ton/hr 140.0 t/hr 154.2 ton/hr

450,000 t/y 495,595 ston/yr 450,000 t/y 495,595 ston/yr

600,000 t/y 660,793 ston/yr 600,000 t/y 660,793 ston/yr

950 °C 1,742 °F 950 °C 1,742 °F

Nat.Gas Nat.Gas Nat.Gas Nat.Gas

8,747 kcal/Nm3 930 Btu/scf 8,747 kcal/Nm3 930 Btu/scf

9,688 kcal/Nm3 1,030 Btu/scf 9,688 kcal/Nm3 1,030 Btu/scf

2 Nr 2 Nr 2 Nr 2 Nr

40 Nr 40 Nr 40 Nr 40 Nr

27,986 Mcal/h 111 106Btu/hr 31,865 Mcal/h 126 10

6Btu/hr


6Btu/hr

3,407 Mcal/h 14 106Btu/hr 295 Mcal/h 1 10

6Btu/hr


6Btu/hr


6Btu/hr

3,061 Mcal/h 12 106Btu/hr 262 Mcal/h 1 10

6Btu/hr

2,279 Nm3/hr 85,080 SCF/hr 2,885 Nm3/hr 107,691 SCF/hr

12.497 Nm3/Nm3 12.497 scf/scf 12.955 Nm3/Nm3 12.955 scf/scf


100.00 % 100.000 % 100.00 % 100.00 %

84.74 % 84.740 % 85.28 % 85.28 %

450,000 t/hr 495,595 ston/yr 450,000 t/hr 495,595 ston/yr

600,000 t/hr 660,793 ston/yr 600,000 t/hr 660,793 ston/yr

90,000,000 Mcal/yr 357,147 106Btu/hr 105,000,000 Mcal/yr 416,672 10

6Btu/hr

99,677,419 Mcal/yr 395,550 106Btu/yr 116,290,323 Mcal/yr 461,475 10

6Btu/yr

10,389,716 Nm3/yr 387,794,023 SCF/yr 12,121,335 Nm3/yr 452,426,360 SCF/yr

11,833 Mcal/hr 47 106Btu/hr 13,805 Mcal/hr 55 10

6Btu/hr

1,221 Nm3/hr 45,587 SCF/hr 1,425 Nm3/hr 53,185 SCF/hr

710 °C 1310 °F 710 °C 1310 °F

310 °C 590 °F 670 °C 1238 °F

4 % O2 4 % O2 5 % O2 5 % O2

4 % O2 4 % O2 5 % O2 5 % O2

28,487 Nm3/hr 17,721 scf/min 37,379 Nm

3/hr 23,252 scf/min

60,834 m3/hr 41,917 cf/min 129,114 m

3/hr 55,001 cf/min

15.26 % H2O 15.26 % H2O 14.72 % H2O 14.72 % H2O

24.4 m 80.0 ft 24.4 m 80.0 ft

1.0 m 3.28 ft 1.0 m 3.28 ft

111 mg/Nm3

54 ppm 95 mg/Nm3

46 ppm

29.9 g/GJ 0.0696 lb/MMBtu 27.24 g/GJ 0.0634 lb/MMBtu

2.77 kg/hr 6.1030 lb/hr 3.19 kg/hr 7.0272 lb/hr



0.082 lb/MMBtu 0.082 lb/MMBtu

7.22 lb/hr 9.13 lb/hr


0.47 lb/hr 0.60 lb/hr


0.65 lb/hr 0.83 lb/hr


0.05 lb/hr 0.07 lb/hr


Table 2-14



FINISHING AREA


Charging Rate

Max Production Rate




Burner Information

Fuel




Number of Burners








Wet waste gas

Dry waste gas

Wet waste gas

Dry waste gas















Stack Parameters



NOx Emissions


















4 of 5

Austenitizing Furnace


Austenitizing Furnace Austenitizing Furnace31.7 t/hr 34.9 ston/hr 31.7 t/hr 34.9 ston/hr

31.7 t/hr 34.9 ston/hr 31.7 t/hr 34.9 ston/hr

133,000 t/yr 146,476 ston/yr 133,000 t/yr 146,476 ston/yr


900 °C 1,652 °F 900 °C 1,652 °F




2 Nr 2 Nr 2 Nr 2 Nr

44 Nr 44 Nr 44 Nr 44 Nr

11,646 Mcal/h 46.2 106Btu/hr 13,388 Mcal/h 53.1 10

6Btu/hr


6Btu/hr

1,589 Mcal/h 6.3 106Btu/hr 124 Mcal/h 0.5 10

6Btu/hr


6Btu/hr


6Btu/hr


6Btu/hr

830.9 Nm3/hr 31,013 SCF/hr 1,052.3 Nm3/hr 39,276 SCF/hr



100 % 100 % 100 % 100 %

84.74 % 84.74 % 85.28 % 85.28 %

133,000 t/h 146,476 ston/yr 133,000 t/h 146,476 ston/yr



6Btu/yr


6Btu/yr


5,129 Mcal/hr 20.4 106Btu/hr 6,528 Mcal/hr 25.9 10

6Btu/hr

529.4 Nm3/hr 19,761 SCF/hr 673.8 Nm3/hr 25,151 SCF/hr

650 °C 1,202 °F 650 °C 1,202 °F

260 °C 500 °F 600 °C 1,112 °F

4 % O2 4 % O2 5 % O2 5 % O2

4 % O2 4 % O2 5 % O2 5 % O2

10,384 Nm3/hr 6,459 scf/min 13,632 Nm

3/hr 8,480 scf/min

19,893 m3/hr 15,279 cf/min 26,116 m

3/hr 20,059 cf/min

15.26 % H2O 15.26 % H2O 14.72 % H2O 14.72 % H2O

24.384 m 80 ft 24.384 m 80 ft

1.0 m 3.28 ft 1.0 m 3.28 ft

111 mg/Nm3

54 ppm 90 mg/Nm3

44 ppm






2.63 lb/hr 3.33 lb/hr


0.17 lb/hr 0.22 lb/hr


0.24 lb/hr 0.30 lb/hr


0.02 lb/hr 0.02 lb/hr


Table 2-14



FINISHING AREA


Charging Rate

Max Production Rate




Burner Information

Fuel




Number of Burners








Wet waste gas

Dry waste gas

Wet waste gas

Dry waste gas















Stack Parameters



NOx Emissions


















5 of 5

Tempering Furnace


Tempering Furnace Tempering Furnace31.7 t/hr 34.9 ston/hr 31.7 t/hr 34.9 ston/hr

31.7 t/hr 34.9 ston/hr 31.7 t/hr 34.9 ston/hr



800 °C 1,472 °F 800 °C 1,472 °F




3 3

66 66


6Btu/hr


6Btu/hr


6Btu/hr


6Btu/hr


6Btu/hr

964 Mcal/h 3.8 106Btu/hr 76 Mcal/h 0.3 10

6Btu/hr

690.1 Nm3/hr 25,756.2 SCF/hr 835.0 Nm3/hr 31,167.1 SCF/hr



100 % 100.000 % 100 % 100.000 %

85.28 % 85.280 % 85.28 % 85.280 %

133,000 t/h 146,476 ston/yr 133,000 t/h 146,476 ston/yr



6Btu/yr


6Btu/yr


4,430 Mcal/hr 17.6 106Btu/hr 5,246 Mcal/hr 20.8 10

6Btu/hr

457.2 Nm3/hr 17,066 SCF/hr 541.5 Nm3/hr 20,210 SCF/hr

550 °C 1022 °F 550 °C 1022 °F

220 °C 428 °F 500 °C 932 °F

5 % O2 5 % O2 5 % O2 5 % O2

5 % O2 5 % O2 5 % O2 5 % O2

8,940 Nm3/hr 5,561 scf/min 10,818 Nm

3/hr 6,729 scf/min

16,144 m3/hr 13,154 cf/min 19,535 m

3/hr 15,918 cf/min

14.72 % H2O 14.72 % H2O 14.72 % H2O 14.72 % H2O

24.384 m 80 ft 24.384 m 80 ft

1.0 m 3.28 ft 1.0 m 3.28 ft

105 mg/Nm3

51 ppm 90 mg/Nm3

44 ppm






2.18 lb/hr 2.64 lb/hr


0.14 lb/hr 0.17 lb/hr


0.20 lb/hr 0.24 lb/hr


0.02 lb/hr 0.02 lb/hr


v&m star expansion project psd/pti application:...

Documents