Modifications and Changes in Emissions at Mittal Steel Cleveland Blast

Furnace #5
Summary
LTV (now Mittal) Steel of Cleveland made off permit modifications to Blast Furnace #5 during
te !"#$%s& 'n !""$( LTV o)tained a permit to incorporate tese canges and to permit te
addition of a second tapole to increase production )* de)ottlenec+ing te casting operations&
Ma,imum capacit* increased from !$# to -$. tons of iron per our& LTV did not accuratel*
represent te nature and e,tent of te emissions increases associated wit tese modifications&
Furtermore( LTV o)tained an emissions limit on te net increase in emissions of particulate
matter of !/&0- tons per *ear& Te Cit* of Cleveland tried to enforce apparent e,ceedances under
tis permit in -$$5 and were told )* Mittal%s attorne*s tat te permit conditions were not
enforcea)le& Tis clearl* appears to )e te case& Since te emissions increase limits in 1T' # !/2
-!-- tat were put in place to avoid 3ew Source 4eview (3S4) and te 1revention of Significant
5eterioration (1S5) programs are not enforcea)le( te emissions increases associated wit tis
permit must )e assumed to )e significant as calculated in te 1T' # !/2-!-- application (LTV
ST66L C7& '3C&( 8pplication 3o& !/2-!--( pages 5 and 9 of ")& 7ter emissions increases
appear to ave )een miscalculated )* LTV Steel& 8s a result( Blast Furnace #5 does not ave
B8CT pollution controls tat would ave correctl* )een re:uired under 1S5& 8n initial
appro,imation )* 7io Citi;en 8ction of te net emissions increases associated wit tis -
nd

tapole pro<ect are=
Car)on Mono,ide > 4,956 tons per ear
1articulate Matter > 9!!"# tons per ear e,cluding slag operation and fugitive emissions
Sulfur 5io,ide > #4! tons per ear
7,ides of 3itrogen > 6stimated in !""$ to )e #!$"6 tons per ear (current emissions rates are
lower)
1.0 Emissions Increase Not Correctly Estimated under Ohio PTI #13-2122
Mittal Steel%s (as LTV Steel) Blast Furnace #5 (BF #5) was modified to increase production
capacit* witout o)taining a permit during te !"#$%s& 't was again modified in !""$ under 7io
1ermit to 'nstall (1T') # !/2-!--& Tis permit retroactivel* included te modified capacit*
installed during te !"#$%s( wic reportedl* increased te production capacit* of BF #5 from
!$# tons of iron per our (tp) to !"9 tp( tis increase was a)ove te pervious permit limit of
!$# tons per our of iron production& 1T' # !/2-!-- was issued in !""$ and allowed furter
modification (i(e( installation of a second tapole and tap s*stem) tat reportedl* increased
production capacit* from !"9 tp to -$. tp&
1.1 PTI #13-2122 Not ederally Nor Practically En!orcea"le
Tis 1T' is pro)lematic )ecause te permit limitations in 1T' !/2-!-- are not federall* nor
practicall* enforcea)le& ?ourl* and annual num)ers representing te ma,imum allowa)le
emissions increase of particulate matter were included in te permit& ?owever( neiter te
)aseline emissions rate( nor te emissions rate as modified( ave )een :uantified& Tis means
tat it is not possi)le for te regulator* autorities to determine compliance wit te permit
conditions& Te conditions as summari;ed in te Title V 1ermit for Mittal Steel are=
78C rule /0.52/!2$5(8)(/) (1T' #!/2-!--)
1articulate emissions (16) from te castouse sall not e,ceed /&!. l)s@r and !/&0- tons@*ear
(T1A)&B 1M!$ emissions sall not e,ceed 0&$# T1AB See Sections 8&'&-&a( 8&'&-&) and 8&'&-&c
)elow& Te re:uirements of tis rule include compliance wit te re:uirements of 78C rules
/0.52!02$0(8)( !02!!( !02!-(1)(5)( and !#2-.&
BTese allowa)le emission rates are onl* for te incremental emission increases resulting from te
installation of te -nd tapole for te C5 furnace&
Te Cit* of Cleveland issued a 3otice of Violation (37V) for conditions related to apparent
e,ceedances of te Cincremental emissions increasesD on 7cto)er !$( -$$5& Te response to tis
37V (5ouglas Eilliams to Feorge Ba+er( 3ovem)er /$( -$$5) informs te Cit* of Cleveland
tat tese apparent violations cannot )e enforced )ecause te incremental increases are not
enforcea)le&
CEe would prefer( owever( to +eep out of te Title V 1ermit te 1T' emission limits tat
appl* onl* to an incremental increase associate wit te 1T' pro<ect )ecause te* are not
practicall* enforcea)le operating limits&D
Te Cit* of Cleveland as found tese CincrementalD limitations unenforcea)le& Te compan*
apparentl* also understands tat te conditions of 1T' # !/2-!-- are unenforcea)le& Since te
emissions increase limits in 1T' # !/2-!-- tat avoid 3ew Source 4eview (3S4) and te
1revention of Significant 5eterioration (1S5) programs are not enforcea)le( te emissions
increases associated wit tis permit must )e assumed to )e significant as calculated in te 1T' #
!/2-!-- application (LTV ST66L C7& '3C&( 8pplication 3o& !/2-!--( pages 5 and 9 of ")& Tis
indicates tat a particulate increase of /$&" tons per *ear (tp*) and a 1M2!$ increase of --&! tp*
were calculated prior to esta)lising te unenforcea)le limits contained in te permit& 't sould
also )e noted tat a significant increase in 37, emissions (!$-&9 tp*) is predicted in te 1T' #
!/2-!-- application&
1.2 P# Emissions
1.2.1 P# Emissions !rom $last urnace %as &$%'
More trou)ling tan te lac+ of enforcea)ilit* of tis permit is te underestimation and
misrepresentations of te emissions increases associated wit te emissions increases tat
occurred )* te e,pansion of BF #5&
7ne source of underestimation from te unpermitted and unenforcea)le e,pansions at BF #5 is
tat te main air pollution control device on BF #5 is a venturi scru))er tat was installed in !"0-
(1urification 'ndustries( two2stage venturi scru))er( -$D G 9$D w&c&) tat as a capacit* of
!5$($$$ acfm and was designed and installed to serve BF #5 wen te ourl* production capacit*
was !$# tp of iron& Te production capacit* of BF #5 as )een effectivel* dou)led to -$. tp
iron( )ut te capacit* of te !"0- vintage venturi scru))er was not increased& Te venturi
scru))er is designed to clean )last furnace gas (BFF) tat is used as a fuel and com)usted in te
stoves prior to )eing emitted )* te stove stac+s& BFF gas is a usa)le fuel )ecause it contains a
large amount of car)on mono,ide (C7) tat is surplus from reducing iron o,ide in te )last
furnace& Tis BFF can )e used as a fuel in te )last furnace stoves( )urned in te flare at BF #5(
or it can )e )urned in te steel mill%s )oilers as a fuel&
Te o)vious pro)lem is tat te amount of BFF tat can )e cleaned is limited& B* increasing
production )e*ond te capacit* of te venturi scru))ers( te amount of uncontrolled BFF tat is
com)usted( eiter in te flares or )oilers( must increase su)stantiall*& Tis led to a su)stantial
increase in particulate emissions&
Ta)le ! > BFF Capacit* of te Venturi Scru))er
BFF Fas Control Calculations for Venturi Scru))er
Volume (acfm) !5$($$$
Temperature F 9-5
Standard Temperature F /-
Capacit* of Venturi (scfm) 90("0/
Capacit* of Venturi (MMscf@r)B .&$#
annual capacit* 059$rs /$(#//
annual capacit* #09$rs /5(0-0
BCompares wit reported value of .&$/ MM cf@r
Te capacit* of te venturi scru))er as remained at !5$($$$acfm or a)out 9#($$$ scfm& Tis is
sown in Ta)le ! and compares well wit reported values& Te amount of BFF generated at BF
#5 as )een calculated (1T' #!/2-!-- letter from LTV Steel to Ted 6s)orn( Ma* !9( !""$) using
$&$0 cf of BFF per ton of iron produced tat as )een descri)ed as LTV%s rule of tum)& 't can
)e seen tat te percentage of BFF tat would )e unscru))ed went from a)out //&-H of te total
in !"#$ to a)out 0!&.H of te total )ased on te ourl* potential production after te !""$
installation of te second tap ole&
Ta)le - > Incontrolled BFF Fas Calculation
Aear
?ourl* Tons
'ron
8nnual
Tons 'ron
8nnual MMcf
BFF
Scru))er
Capacit*
Inscru))ed
BFF
1ercent BFF
Inscru))ed
!"#$ avg #0&- 09/(#!# 5/(.90 /5(0-0 !0(0.! //&-H
ma, !$#&$ ".9($#$ 99(--9 /5(0-0 /$(."" .9&!H
!"#/ avg !$9&$ "-#(##9 95($-- /5(0-0 -"(-"5 .5&!H
ma, !$#&$ ".9($#$ 99(--9 /5(0-0 /$(."" .9&!H
!"#52
!"#0 avg !/0&0 !(-$9(!-- #.(.-" /5(0-0 .#(0$- 50&0H
ma, !"9&$ !(0!9("9$ !-$(!#0 /5(0-0 #.(.9! 0$&/H
!"##2
!"#" avg !5!&0 !(/-#(#"- "/($-- /5(0-0 50(-"9 9!&9H
ma, !"9&$ !(0!9("9$ !-$(!#0 /5(0-0 #.(.9! 0$&/H
post
!""!
avg
-$$5 !5!&9 !(/-#(.-! "-("#" /5(0-0 50(-9/ 9!&9H
ma, -$.&$ !(0#0($.$ !-5($"/ /5(0-0 #"(/99 0!&.H
'n LTV%s response to te Cit* of Cleveland (CoC) (8pril -5( !""$( pg& !!)( LTV tells te Cit* of
Cleveland tat te CoC as incorrectl* used te 812.- emissions factor for estimating BFF
particulate emissions& ?owever( a review of te 812.- capter on iron and steel production (812
.- Capter !-&5) sows tat te emissions factor LTV cooses is an emissions factor for
particulate matter from te com)ustion of scru))ed BFF (812.- C&!-&5&-&# Miscellaneous
Com)ustion)& 't is incorrect to use tis factor )ecause te potential to emit is caracteri;ed )* an
increase in uncontrolled BFF com)ustion emissions& 8s te scru))er capacit*( wic was
alread* less tan te total BFF production capacit*( as not )een increased( te increase in BFF
must )e presumed to )e unscru))ed& 'n addition tere are no permit conditions tat actuall*
re:uire Mittal to scru) BFF )efore it is com)usted and te emissions increases must( terefore(
)e calculated on an uncontrolled )asis&

'n teir -$$5 Title V 6missions Fee 4eport Mittal used te 812.- cleaned BFF gas factor for
estimating emissions from te stove stac+s( )oilers and te flare tat )urn BFF& Te stove stac+s
in -$$5 used -/("/- MMcf of BFF and /(.#9 MMcf of BFF was reported flared troug te gas
)leeder& Mittal reported a particulate emissions factor of -&" l)s@ MMcf of BFF (te cleaned gas
812.- factor) for tis com)ustion& Tis factor is not appropriate for flared gas as it is t*picall*
not scru))ed prior to release& 'n addition( te )oilers were reported to )urn over #/($$$ MM cf of
BFF in -$$5& Eile it is clear tat Mittal as used a controlled factor in estimating tese
emissions( tere is not enoug scru))ing capacit* for Mittal to ave cleaned tis amount of BFF&
Some of te BFF ma* come from BF #9( wic still retains its original capacit* of !$# tp iron
production& From Ta)le - we can compare te actual average unscru))ed production capacit* in
!"#/ prior to te modifications wit te ma,imum capacit* after te !""$ modifications (#"(/99
> -"(-"5 MMcf) and see tat te actual to potential increase in unscru))ed BFF is a)out 9$($$$
MMcf per *ear& 8ssuming tat te control efficienc* of te venturi scru))ers is "$H (it is
pro)a)l* iger)( we get an uncontrolled particulate emissions factor for te BFF of -" l)s@MMcf
(-&"@(!2$&"$))& Tis means tat te increase in potential to emit from uncontrolled particulate in
te BFF is %&! tons per ear&
Ta)le / > BFF 4eported Burned in Mittal Boilers
Boiler
'5 8nnual MMcf BFF
Boiler 8 -9("0!&-
Boiler B !(.--&9
Boiler C !#(//9&.
Boiler 5 $&$
Boiler ! !!($!$&-
Boiler - #(#!/&-
Boiler / !9(."/&0
sum #/($.0&/
1.2.2 P# Emissions !rom the Casthouse and Char(in(
6missions of 1M in te castouse are estimated )ased on te increased production of iron& Total
emissions for -$$5 were reported to )e /"&#5 tons of total particulate matter (1M) )ased on
annual production of !(/-#(.-! tons of iron& 8ctual production in !"#/ prior to modification was
"-#(##9 tons of iron and te potential production for BF #5 as modified wit te second tapole
is !(0#0($.$ tons of iron& 1roportioning te total 1M emissions )ased on production rates( 7io
Citi;en 8ction estimates te actual emissions in !"#/ to )e -0&" tp* of 1M& 7C8 estimates te
potential to emit to )e 5/&9 tp* of 1M& Te net increase in 1M emissions is( terefore( estimated
to )e appro,imatel* an increase of $5"% tp at the casthouse& 8 similar estimate for te
carging emissions results in an additional 5"' tp of (M"
1.2.) P# Emissions !rom Sla( *andlin( and u(iti+e Emissions
6missions from slag andling were e,cluded from te calculation of te net cange in emissions
under 1T' !/2-!--& Tis was done )ecause LTV asserted tat te slag andling was done )* a
contractor under a different permit& Mittal@LTV is a named source under 1S5 regulations and
must include fugitive emissions in estimating te net cange in emissions& 618 as issued a
guidance memo (Fallatin Steel) tat also reinforces te position tat tese emissions must )e
included in calculating te net cange in emissions& Te e,tent of slag andling and oter
e,cluded emissions in tis permit sould )e furter investigated )ut must )e calculated along
wit oter fugitive emissions as Mittal ('ron and Steel Mill) is a named 1S5 source&
1.3 Car"on #ono,ide &CO' Emissions Increases
8 more detailed anal*sis of C7 ma* )e warranted& ?owever( )ecause te magnitude of te C7
increase from te second tapole is so large( a simple proportioning of emissions was done to
determine if te net increase would )e e,pected to )e significant& Mittal reported total emissions
for -$$5 of 0(999&# tons from BF #5 )ased on annual production of !(/-#(.-! tons of iron&
8ctual production in !"#/ prior to modification was "-#(##9 tons of iron and te potential
production for BF #5 as modified wit te second tapole is !(0#0($.$ tons of iron&
1roportioning te C7 emissions )ased on production rates( 7io Citi;en 8ction estimates actual
emissions in !"#/ to )e 5(/9$&0 tp* of C7& 7C8 estimates te potential to emit to )e !$(/!9&0
tp* of C7& Te net increase in C7 emissions is( terefore( estimated to )e appro,imatel* an
increase of 4,956 tp"
1.) NO, Emissions Increases
Te !""$ application (page 9 of ") sowed tat te net emissions increase for 37, was
significant at #!$"6 tp& Current emissions estimates (-$$5 Title V 6missions 4eport) sow ver*
low emissions due largel* to a reported !"". 37, Stac+ Test of com)ustion of BFF& Tis
sould )e furter investigated to see if te Stac+ Test is representative of te overall emissions
from te )last furnace including te emissions resulting from com)ustion of co+e and oter
process feeds and if separate emissions estimates need to )e produced to represent flaring
emissions and te emissions from )urning BFF in oter units suc as )oilers& Te impact of te
increased production at BF #5 sould also )e considered in evaluating increased )oiler utili;ation&
1.- SO2 Emissions Increases
6missions of S7- are e,pected to result from te materials carged in ma+ing iron in te )last
furnace& Total emissions for -$$5 were reported to )e -!9&5 tons from BF #5 )ased on annual
production of !(/-#(.-! tons of iron& 8ctual production in !"#/ prior to modification was
"-#(##9 tons of iron and te potential production for BF #5 as modified wit te second tapole
is !(0#0($.$ tons of iron& 1roportioning te S7- emissions )ased on production rates( 7io
Citi;en 8ction estimates actual emissions in !"#/ to )e !5!&. tp* of S7-& 7C8 estimates te
potential to emit to )e -"!&/ tp* of S7-& Te net increase in S7- emissions is( terefore(
estimated to )e appro,imatel* an increase of #4! tp"