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 the 1980’s. In 1990, LTV obtained a permit to incorporate these changes and to permit the addition of a second taphole to increase production by debottlenecking the casting operations. Maximum capacity increased from 108 to 204 tons of iron per hour. LTV did not accurately represent the nature and extent of the emissions increases associated with these modifications. Furthermore, LTV obtained an emissions limit on the net increase in emissions of particulate matter of 13.72 tons per year. The City of Cleveland tried to enforce apparent exceedances under this permit in 2005 and were told by Mittal’s attorneys that the permit conditions were not enforceable. This clearly appears to be the case. Since the emissions increase limits in PTI # 13-2122 that were put in place to avoid New Source Review (NSR) and the Prevention of Significant Deterioration (PSD) programs are not enforceable, the emissions increases associated with this permit must be assumed to be significant as calculated in the PTI # 13-2122 application (LTV STEEL CO. INC., Application No. 13-2122, pages 5 and 6 of 9). Other emissions increases appear to have been miscalculated by LTV Steel. As a result, Blast Furnace #5 does not have BACT pollution controls that would have correctly been required under PSD. An initial approximation by Ohio Citizen Action of the net emissions increases associated with this 2nd taphole project are:

Carbon Monoxide – 4,956 tons per yearParticulate Matter – 900.1 tons per year excluding slag operation and fugitive emissionsSulfur Dioxide – 140 tons per yearOxides of Nitrogen – Estimated in 1990 to be 102.6 tons per year (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 capacity without obtaining a permit during the 1980’s. It was again modified in 1990 under Ohio Permit to Install (PTI) # 13-2122. This permit retroactively included the modified capacity installed during the 1980’s, which reportedly increased the production capacity of BF #5 from 108 tons of iron per hour (tph) to 196 tph, this increase was above the pervious permit limit of 108 tons per hour of iron production. PTI # 13-2122 was issued in 1990 and allowed further modification (i,e, installation of a second taphole and tap system) that reportedly increased production capacity from 196 tph to 204 tph.

1.1 PTI #13-2122 Not Federally Nor Practically Enforceable

This PTI is problematic because the permit limitations in PTI 13-2122 are not federally nor practically enforceable. Hourly and annual numbers representing the maximum allowable emissions increase of particulate matter were included in the permit. However, neither the baseline emissions rate, nor the emissions rate as modified, have been quantified. This means that it is not possible for the regulatory authorities to determine compliance with the permit conditions. The conditions as summarized in the Title V Permit for Mittal Steel are:

OAC rule 3745-31-05(A)(3) (PTI #13-2122)Particulate emissions (PE) from the casthouse shall not exceed 3.14 lbs/hr and 13.72 tons/year (TPY).* PM10 emissions shall not exceed 7.08 TPY* See Sections A.I.2.a, A.I.2.b and A.I.2.c below. The requirements of this rule include compliance with the requirements of OAC rules 3745-17-07(A), 17-11, 17-12(P)(5), and 18-24.

*These allowable emission rates are only for the incremental emission increases resulting from the installation of the 2nd taphole for the C5 furnace.

The City of Cleveland issued a Notice of Violation (NOV) for conditions related to apparent exceedances of the “incremental emissions increases” on October 10, 2005. The response to this NOV (Douglas Williams to George Baker, November 30, 2005) informs the City of Cleveland that these apparent violations cannot be enforced because the incremental increases are not enforceable.

“We would prefer, however, to keep out of the Title V Permit the PTI emission limits that apply only to an incremental increase associate with the PTI project because they are not practically enforceable operating limits.”

The City of Cleveland has found these “incremental” limitations unenforceable. The company apparently also understands that the conditions of PTI # 13-2122 are unenforceable. Since the emissions increase limits in PTI # 13-2122 that avoid New Source Review (NSR) and the Prevention of Significant Deterioration (PSD) programs are not enforceable, the emissions increases associated with this permit must be assumed to be significant as calculated in the PTI # 13-2122 application (LTV STEEL CO. INC., Application No. 13-2122, pages 5 and 6 of 9). This indicates that a particulate increase of 30.9 tons per year (tpy) and a PM-10 increase of 22.1 tpy were calculated prior to establishing the unenforceable limits contained in the permit. It should also be noted that a significant increase in NOx emissions (102.6 tpy) is predicted in the PTI # 13-2122 application.

1.2 PM Emissions

1.2.1 PM Emissions from Blast Furnace Gas (BFG)

More troubling than the lack of enforceability of this permit is the underestimation and misrepresentations of the emissions increases associated with the emissions increases that occurred by the expansion of BF #5.

One source of underestimation from the unpermitted and unenforceable expansions at BF #5 is that the main air pollution control device on BF #5 is a venturi scrubber that was installed in 1972 (Purification Industries, two-stage venturi scrubber, 20” & 60” w.c.) that has a capacity of 150,000 acfm and was designed and installed to serve BF #5 when the hourly production capacity was 108 tph of iron. The production capacity of BF #5 has been effectively doubled to 204 tph iron, but the capacity of the 1972 vintage venturi scrubber was not increased. The venturi scrubber is designed to clean blast furnace gas (BFG) that is used as a fuel and combusted in the stoves prior to being emitted by the stove stacks. BFG gas is a usable fuel because it contains a large amount of carbon monoxide (CO) that is surplus from reducing iron oxide in the blast furnace. This BFG can be used as a fuel in the blast furnace stoves, burned in the flare at BF #5, or it can be burned in the steel mill’s boilers as a fuel.

The obvious problem is that the amount of BFG that can be cleaned is limited. By increasing production beyond the capacity of the venturi scrubbers, the amount of uncontrolled BFG that is combusted, either in the flares or boilers, must increase substantially. This led to a substantial increase in particulate emissions.

Table 1 – BFG Capacity of the Venturi ScrubberBFG Gas Control Calculations for Venturi ScrubberVolume (acfm) 150,000Temperature F 625Standard Temperature F 32Capacity of Venturi (scfm) 67,973Capacity of Venturi (MMscf/hr)* 4.08annual capacity 7560hrs 30,833annual capacity 8760hrs 35,727*Compares with reported value of 4.03 MM cf/hr

The capacity of the venturi scrubber has remained at 150,000acfm or about 68,000 scfm. This is shown in Table 1 and compares well with reported values. The amount of BFG generated at BF #5 has been calculated (PTI #13-2122 letter from LTV Steel to Ted Esborn, May 16, 1990) using 0.07 cf of BFG per ton of iron produced that has been described as LTV’s rule of thumb. It can be seen that the percentage of BFG that would be unscrubbed went from about 33.2% of the total in 1980 to about 71.4% of the total based on the hourly potential production after the 1990 installation of the second tap hole.

Table 2 – Uncontrolled BFG Gas Calculation

Year Hourly Tons Iron

Annual Tons Iron

Annual MMcf BFG

Scrubber Capacity

Unscrubbed BFG

Percent BFG Unscrubbed

1980 avg 87.2 763,818 53,467 35,727 17,741 33.2%max 108.0 946,080 66,226 35,727 30,499 46.1%

1983 avg 106.0 928,886 65,022 35,727 29,295 45.1%max 108.0 946,080 66,226 35,727 30,499 46.1%

1985-1987 avg 137.7 1,206,122 84,429 35,727 48,702 57.7%

max 196.0 1,716,960 120,187 35,727 84,461 70.3%1988-1989 avg 151.7 1,328,892 93,022 35,727 57,296 61.6%

max 196.0 1,716,960 120,187 35,727 84,461 70.3%post 1991

avg 2005 151.6 1,328,421 92,989 35,727 57,263 61.6%max 204.0 1,787,040 125,093 35,727 89,366 71.4%

In LTV’s response to the City of Cleveland (CoC) (April 25, 1990, pg. 11), LTV tells the City of Cleveland that the CoC has incorrectly used the AP-42 emissions factor for estimating BFG particulate emissions. However, a review of the AP-42 chapter on iron and steel production (AP-42 Chapter 12.5) shows that the emissions factor LTV chooses is an emissions factor for particulate matter from the combustion of scrubbed BFG (AP-42 Ch.12.5.2.8 Miscellaneous Combustion). It is incorrect to use this factor because the potential to emit is characterized by an increase in uncontrolled BFG combustion emissions. As the scrubber capacity, which was already less than the total BFG production capacity, has not been increased, the increase in BFG must be presumed to be unscrubbed. In addition there are no permit conditions that actually

require Mittal to scrub BFG before it is combusted and the emissions increases must, therefore, be calculated on an uncontrolled basis. In their 2005 Title V Emissions Fee Report Mittal used the AP-42 cleaned BFG gas factor for estimating emissions from the stove stacks, boilers and the flare that burn BFG. The stove stacks in 2005 used 23,932 MMcf of BFG and 3,486 MMcf of BFG was reported flared through the gas bleeder. Mittal reported a particulate emissions factor of 2.9 lbs/ MMcf of BFG (the cleaned gas AP-42 factor) for this combustion. This factor is not appropriate for flared gas as it is typically not scrubbed prior to release. In addition, the boilers were reported to burn over 83,000 MM cf of BFG in 2005. While it is clear that Mittal has used a controlled factor in estimating these emissions, there is not enough scrubbing capacity for Mittal to have cleaned this amount of BFG. Some of the BFG may come from BF #6, which still retains its original capacity of 108 tph iron production. From Table 2 we can compare the actual average unscrubbed production capacity in 1983 prior to the modifications with the maximum capacity after the 1990 modifications (89,366 – 29,295 MMcf) and see that the actual to potential increase in unscrubbed BFG is about 60,000 MMcf per year. Assuming that the control efficiency of the venturi scrubbers is 90% (it is probably higher), we get an uncontrolled particulate emissions factor for the BFG of 29 lbs/MMcf (2.9/(1-0.90)). This means that the increase in potential to emit from uncontrolled particulate in the BFG is 870 tons per year.

Table 3 – BFG Reported Burned in Mittal BoilersBoiler ID Annual MMcf BFGBoiler A 26,971.2Boiler B 1,422.6Boiler C 18,336.4Boiler D 0.0Boiler 1 11,010.2Boiler 2 8,813.2Boiler 3 16,493.7sum 83,047.3

1.2.2 PM Emissions from the Casthouse and Charging

Emissions of PM in the casthouse are estimated based on the increased production of iron. Total emissions for 2005 were reported to be 39.85 tons of total particulate matter (PM) based on annual production of 1,328,421 tons of iron. Actual production in 1983 prior to modification was 928,886 tons of iron and the potential production for BF #5 as modified with the second taphole is 1,787,040 tons of iron. Proportioning the total PM emissions based on production rates, Ohio Citizen Action estimates the actual emissions in 1983 to be 27.9 tpy of PM. OCA estimates the potential to emit to be 53.6 tpy of PM. The net increase in PM emissions is, therefore, estimated to be approximately an increase of 25.8 tpy at the casthouse. A similar estimate for the charging emissions results in an additional 5.3 tpy of PM.

1.2.4 PM Emissions from Slag Handling and Fugitive Emissions

Emissions from slag handling were excluded from the calculation of the net change in emissions under PTI 13-2122. This was done because LTV asserted that the slag handling was done by a

contractor under a different permit. Mittal/LTV is a named source under PSD regulations and must include fugitive emissions in estimating the net change in emissions. EPA has issued a guidance memo (Gallatin Steel) that also reinforces the position that these emissions must be included in calculating the net change in emissions. The extent of slag handling and other excluded emissions in this permit should be further investigated but must be calculated along with other fugitive emissions as Mittal (Iron and Steel Mill) is a named PSD source.

1.3 Carbon Monoxide (CO) Emissions Increases

A more detailed analysis of CO may be warranted. However, because the magnitude of the CO increase from the second taphole is so large, a simple proportioning of emissions was done to determine if the net increase would be expected to be significant. Mittal reported total emissions for 2005 of 7,666.8 tons from BF #5 based on annual production of 1,328,421 tons of iron. Actual production in 1983 prior to modification was 928,886 tons of iron and the potential production for BF #5 as modified with the second taphole is 1,787,040 tons of iron. Proportioning the CO emissions based on production rates, Ohio Citizen Action estimates actual emissions in 1983 to be 5,360.7 tpy of CO. OCA estimates the potential to emit to be 10,316.7 tpy of CO. The net increase in CO emissions is, therefore, estimated to be approximately an increase of 4,956 tpy.

1.4 NOx Emissions Increases

The 1990 application (page 6 of 9) showed that the net emissions increase for NOx was significant at 102.6 tpy. Current emissions estimates (2005 Title V Emissions Report) show very low emissions due largely to a reported 1994 NOx Stack Test of combustion of BFG. This should be further investigated to see if the Stack Test is representative of the overall emissions from the blast furnace including the emissions resulting from combustion of coke and other process feeds and if separate emissions estimates need to be produced to represent flaring emissions and the emissions from burning BFG in other units such as boilers. The impact of the increased production at BF #5 should also be considered in evaluating increased boiler utilization.

1.5 SO2 Emissions Increases

Emissions of SO2 are expected to result from the materials charged in making iron in the blast furnace. Total emissions for 2005 were reported to be 216.5 tons from BF #5 based on annual production of 1,328,421 tons of iron. Actual production in 1983 prior to modification was 928,886 tons of iron and the potential production for BF #5 as modified with the second taphole is 1,787,040 tons of iron. Proportioning the SO2 emissions based on production rates, Ohio Citizen Action estimates actual emissions in 1983 to be 151.4 tpy of SO2. OCA estimates the potential to emit to be 291.3 tpy of SO2. The net increase in SO2 emissions is, therefore, estimated to be approximately an increase of 140 tpy.