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

Transcription

1 Prepared for: V&M Star Youngstown, OH V&M Star Expansion Project PSD/PTI Application Tab B BACT Analysis Prepared by CH2MHILL ENSR Corporation Document No.:

2 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 i

3 Contents 1.0 INTRODUCTION PSD BACT REQUIREMENTS Electric Arc Furnace (EAF) and Ladle Metallurgy Furnace (LMF) Particulate Matter Control CO Control NOx Control SOx Control LMF Alloy, Additives, and Flux Handling System Continuous Caster Particulate Matter Control NOx Control Vacuum Tank Degasser (VTD) Particulate Matter Control CO Control VTD Boilers NOx Control PM10, CO, SO2, AND VOC Control MPM Billet Reheat Furnace (Existing) FQM Billet Rotary Hearth Reheat Furnace (New) Particulate Matter Control CO, VOC and SO 2 Control NOx Control FQM Pipe Intermediate Reheat Furnace (New) Particulate Matter Control CO, VOC and SO 2 Control NOx Control Mandrel Furnace Austenitizing Furnace #1 and # Particulate Matter Control CO, VOC and SO 2 Control NOx Control Tempering Furnace #1 and # Particulate Matter Control CO, VOC and SO 2 Control NOx Control FQM Pipe Mill Scrubber Particulate Matter Control Abrasives Manufacturing Raw Materials Handling...26 i

4 2.14 Abrasives Melting Furnace NOx Control PM SO CO AND VOC Abrasives Finished Product Handling PM10 Control Cooling Towers Roadways...28 ii

5 Tables Table 1-1 Table 1-2 Table 1-3 Table 2-1 Table 2-2 Table 2-3 Table 2-4 Table 2-5 Table 2-6 Table 2-7 Table 2-8 Table 2-9 Table 2-10 Table 2-11 Table 2-12 Table 2-13 Table 2-14 V&M Star Source Emission Factors and Rate Calculations V&M Star Baseline Emission Rate Calculations V&M Star Annual Emission Rates Summary BACT Applicability Comparison of EAF/LMF Meltshop Exhaust with Industrial and Utility Coal Fired Steam Generators Technical Feasibility of EAF/LMF PE/PM10 Control Techniques Range of EAF/LMF Filterable PE/PM10 Emission Factors Determined BACT Technical Feasibility of EAF/LMF CO Control Techniques Range of EAF/LMF CO Emission Factors Determined BACT Technical Feasibility of EAF/LMF NOx Control Techniques Range of EAF/LMF NOx Emission Factors Determined BACT Technical Feasibility of EAF/LMF SO 2 Control Techniques Range of EAF/LMF SO 2 Emission Factors Determined BACT Range of Reheat Furnace NOx Emission Factors Determined BACT Range of Annealing Furnace NOx Emission Factors Determined BACT VTD Boiler NOx Reduction Cost Effectiveness Analysis New FQM Seamless Pipe Mill Furnaces iii

6 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 and 40 CFR 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 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. 1

7 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. 2

8 Table 2-1 BACT Applicability Project BACT Applicability New or Mod Pollutant Emission Increases (Tons/Year) PM10 CO NOx SO 2 VOC Pb Project Emission Increase 91 1, PSD Significant BACT Required Yes Yes Yes Yes Yes No Unit BACT Applicability PM10 CO NOx SO 2 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, SO 2, 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 3

9 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 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. 4

10 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 SO 2 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. Table 2-2 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 avg. temp temp range avg. acfm 1,200,000 78,200 1,400,000 acfm range PM lb/hr 6, ,600 PM gr/scf Controlled PM NSPS limits gr/scf 0.05 lb/mmbtu 0.03 lb/mmbtu (existing) gr/scf ~0.017gr/scf lb/mmbtu (new) ~0.009 gr/scf NOx lb/hr < ,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 AP-42: 12 lb/ton coal SO 2 lb/hr < ,800 SO 2 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 < CO ppm avg. < ppm range Estimate basis <4.0 lb/ton AP-42: 5 lb/ton coal 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 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 5

11 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 SO 2 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 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 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 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 gr/dscf filterable particulate. The September 2008 PSD PTI approved gr/dscf as BACT. The following Table 2-3 tabulates the technical feasibility of particulate matter emission control techniques. 6

12 Table 2-3 Technical Feasibility of EAF/LMF PE/PM10 Control Techniques Control Alternative Passive Process/Practice EAF with DEC and canopy hood EAF/LMF Process Technology Feasibility DEC Flow Combined DEC/Canopy Yes No Yes No Yes No X Add-on Control Baghouse, gr/dscf X Baghouse, gr/dscf X Baghouse, 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 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. 7

13 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 gr/dscf at the high end down to the most stringent limit of gr/dscf. The major grouping is right in the middle at to gr/dscf. The facilities permitted at 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: , ~0.0032, and 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) (%) Table 2-4 lists emission factors from the RBLC determined to be BACT for similar sources. Table 2-4 Range of EAF/LMF Filterable PE/PM10 Emission Factors Determined BACT EAF (& LMF) Filterable PE/PM10 (gr/dscf) V&M Star predicted performance MacSteel, MI Beta Steel, IN Corus Tuscaloosa, AL Ipsco, AL Nucor, AL Republic Technologies, OH Qualitech, IN Nucor, TN Nucor, IN Nucor Tuscaloosa, AL MacSteel, AR CF&I, CO Nucor, NC Detailed cost analyses have demonstrated that the more conservative design costs and additional maintenance activities to maintain 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 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 8

14 and LRS process and baghouse emission control, 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 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 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 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 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 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 CO 2 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. 9

15 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 CO 2 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. 10

16 Table 2-5 Technical Feasibility of EAF/LMF CO Control Techniques Control Alternative Technology Feasibility 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 CO 2 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. 11

17 Table 2-6 Range of EAF/LMF CO Emission Factors Determined BACT EAF (& LMF) CO (lb/ton) V&M Star predicted performance 4.0 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 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. 12

18 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. Table 2-7 Technical Feasibility of EAF/LMF NOx Control Techniques Control Alternative Technology Feasibility 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. Table 2-8 Range of EAF/LMF NOx Emission Factors Determined BACT EAFs (& LMF) NOx Factor (lb/ton) V&M Star predicted performance 0.40 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)

19 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 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 SO 2 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 SO 2 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 SO 2 controls are typically employed on medium to high sulfur content fuel combustion systems with uncontrolled exhaust gas SO 2 concentrations of 500 to 2,000 ppm. The EAF/LMF exhaust SO 2 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 14

20 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 SO 2 control techniques. Table 2-9 Technical Feasibility of EAF/LMF SO 2 Control Techniques Control Alternative Passive Process/Practice Scrap management Ultra-low sulfur carbon/coke Add-on Control Wet scrubber system Spray dryer absorber Technology Feasibility EAF/LRS Process DEC/LRS Exhaust Yes No Yes No X X X 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 SO 2 emissions below 0.25 lb/ton of steel V&M Star has been optimizing the scrap mix for lower SO 2 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 SO 2 scrap mix over the scrap mix that otherwise would be used, and cost effectiveness could approach $300,000/ton of SO 2 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 SO 2 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 SO 2 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 SO 2 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 SO 2 /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) 15

21 Potential SO 2 reduction Cost effectiveness = (1,400,000 tons stl/year)(reduction 0.05 SO 2 lb/ton steel)(1 ton/2000 lb) = 35.0 tons SO 2 /year = ($784,000 increase)/(35.0 tons SO 2 reduction) = $22,400/ ton SO 2 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 SO 2 emissions for the V&M Star facility. The following table shows a range of SO 2 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. Table 2-10 Range of EAF/LMF SO 2 Emission Factors Determined BACT Facility (EAF/LMS) SO 2 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 16

22 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 Particulate Matter Control 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 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 Particulate Matter Control 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 lb/ton of steel and 0.34 lb/hour. 17