MEMORANDUM

DATE:	April 3, 2023

TO:		Phil Mulrine, EPA/OAQPS/SPPD

FROM:	Haley Key, Jeremy Kaelin, and Gabrielle Raymond, RTI International

SUBJECT:	Unmeasured Fugitive and Intermittent Particulate Emissions and Cost Impacts for Integrated Iron and Steel Facilities under 40 CFR Part 63, Subpart FFFFF
__________________________________________________________________________________________
1.0	BACKGROUND AND INTRODUCTION

	This memorandum describes the proposed standards and associated costs and emission estimates for seven unmeasured fugitive and intermittent particulate (UFIP) sources in the Integrated Iron and Steel Manufacturing (II&S) industry in the amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) (40 CFR, part 63, subpart FFFFF) in response to the 2020 Louisiana Environmental Action Network (LEAN) decision. On April 21, 2020 a decision was issued in LEAN v. EPA, 955 F. 3d. 1088 (D.C. Cir. 2020) in which the Court held that the EPA has an obligation to set standards for unregulated pollutants as part of technology reviews under CAA section 112(d)(6). To comply with the LEAN decision, U.S. Environmental Protection Agency (EPA) examined the known UFIP sources for the II&S industry and is proposing a combination of opacity limits and work practice standards to control emissions from these sources.

In accordance with section 112 of the Clean Air Act (CAA), on May 20, 2003, the EPA established a NESHAP for the II&S industry (68 FR 27646). Under section 112(f)(2) of the CAA, the EPA is required to perform a residual risk analysis of maximum achievable control technology (MACT) standards within eight years of promulgation. For purposes of the RTR, the EPA sent an information collection request to the II&S industry in 2011 that included a questionnaire and a source test request. The II&S information collection request was sent under the authority of section 114 of the CAA (42 U.S.C. 7414) to acquire the necessary data for the RTR. Copies of the II&S section 114 collection request and responses received by EPA are included in docket for the RTR (Docket ID #EPA-HQ-OAR-2002-0083). The EPA sent out two additional section 114 collection requests in 2022 (one in January 2022 and another in September 2022), including another questionnaire and source test requests to acquire the additional necessary data to comply with the LEAN decision. Copies of the 2022 section 114 collection requests and responses received by the EPA are included in the docket for this action (Docket ID #EPA-HQ-OAR-XXXX-XXXX).

      As part of the analysis for the II&S RTR in 2019, the EPA identified seven UFIP emission sources of HAP emissions (also called "nonpoint" sources) at II&S facilities. These nonpoint sources were identified primarily from the extensive experience of regional EPA inspectors of II&S facilities in EPA Region V where seven of the eight total II&S facilities in the current industry are located. The nonpoint sources reviewed consist of the following sources: blast furnace (BF) bleeder valve unplanned openings; BF bleeder valve planned openings; BF bell leaks; BF casthouse fugitives; BF iron beaching; BF slag handling and storage operations; and basic oxygen process furnace (BOPF) shop fugitives. Two of these emission sources, BF casthouse fugitives and BOPF shop fugitives, are currently regulated under the NESHAP by opacity limits, as a surrogate for metal HAP. As part of this effort, work practices were identified that could achieve reductions in HAP emissions and associated risks from the seven nonpoint sources. A comment request was published for these work practice standards (Docket item #EPA-HQ-OAR-2002-0083-0030), but no work practice standards were incorporated to the rule at that time. For this LEAN review, new work practices were identified based on the previous 2019 efforts, the comments received in response to the publication, and new data from the 2022 section 114 collection. A description of these nonpoint sources and their estimated HAP emissions; description of the work practices as potential control measures; estimated reductions in emissions with the control measures; and estimated costs and cost-effectiveness of the control measures are discussed below.

2.0	DESCRIPTIONS OF THE UFIP (NONPOINT) EMISSION SOURCES

	The seven UFIP emissions sources identified for the II&S industry are listed below and discussed in this section. Note that two of the seven sources (BOPF Shop Fugitives and BF Casthouse Fugitives) are currently regulated by opacity standards in the NESHAP, where opacity is a surrogate for metal HAP.

 BF Unplanned Openings (intermittent, via bleeder valve exhaust)
 BF Planned Openings (intermittent, via bleeder valve exhaust)
 BF Bell Leaks (fugitive)
 BF Casthouse Fugitives (regulated fugitive)
 Beaching of Iron from BFs (fugitive)
 BF Slag Handling and Storage (fugitive)
 BOPF Shop Fugitives (regulated fugitive)

Appendix A shows photographs of some of the UFIP sources observed at II&S facilities by EPA regional enforcement staff.

	The following are definitions of some II&S equipment and processes used in the discussion of the seven UFIP sources below:

 BF is a key II&S process unit where molten iron is produced from raw materials such as iron ore, lime, sinter, and coke.
 BF casthouse is the structure that houses the lower portion of the BF and encloses iron and slag transport operations.
 BOPF is a key II&S process where steel is made from molten iron, scrap steel, and alloys.
 BOPF Shop is the structure that houses the entire BOPF and auxiliary activities, such as hot iron transfer, skimming and desulfurization of the iron.
 Bleeder valve is a device at the top of the BF that, when open, relieves BF internal pressure to the ambient air. The bleeder valve can operate as both a self-actuating safety device to relieve excess pressure and as an operator-initiated instrument for process control.
 Bleeder valve opening means any opening of the BF bleeder valve, which allows gas and/or particulate matter (PM) to flow past the sealing seat. For purposes of this rule, any multiple openings and closings of a bleeder valve that occur within a 30-minute period shall be considered a single bleeder valve opening.
 Planned bleeder valve opening means a bleeder valve opening that is initiated by an operator as part of a furnace startup, shutdown, or temporary idling for maintenance action.
 Unplanned bleeder valve opening means a bleeder valve opening that is not planned.

2.1	BF Bleeder Valves - Unplanned Openings

     A BF makes iron and operates under positive pressure. When the furnace is at pressures above standard operation, the pressure is automatically relieved out of bleeder valves that exhaust uncontrolled BF gas to the atmosphere. Bleeder valves also can be opened manually when operators wish to release internal pressure, such as when the furnace is taken out of service for maintenance (see separate discussion below under planned openings). The exhaust from bleeder valves are released from points located on the BF "uptake" ductwork that rises over 100 feet higher above the top of the BF casthouse, the structure that surrounds the bottom sections of the BF where opacity is measured to fulfill the NESHAP requirements.

	The most common cause of unplanned overpressure in a BF is a "slip". A slip is when raw materials loaded in the top of the furnace fail to descend smoothly in the furnace and bind together to form a "bridge" which than "hangs" (i.e., accumulates) in one position in the furnace. When a "hang" eventually falls, or "slips," it creates a pressure surge that opens the bleeder valves, releasing emissions in the form of a large dust cloud. A bleeder valve opening can last anywhere between 3 seconds and 10 minutes. These bleeder valve openings can result in significant PM that includes HAP metal emissions, and are the subject of numerous public complaints. Part of the reason for the public concern is the visibility of these releases because even a 3-second openings can cause alarmingly large amounts of visible emissions (see photographs in Appendix A).

	In a 1976 study (EPA, 1976), the EPA determined that the average number of unavoidable unplanned bleeder valve openings for a BF was about four per month. According to data collected from the 2022 section 114 request, some furnaces are still above the 1976 average. Table 2-1 below shows the past performance of each of the eight II&S facilities in regard to the average number of unplanned BF bleeder valve openings per month. The range in average monthly unplanned openings per BF was from zero to over seven, with an averaging time period of one year.

            Table 2-1.  Rates of Unplanned BF Bleeder Valves Openings
                      (from the 2022 Section 114 Collection)
                                   Facility
                                  Furnace ID
                          Average Unplanned Openings
                                   per Month
                                     Year
CC-BurnsHarbor-IN
                                       C
                                       0
                                     2021

                                       D
                                       0
                                     2021
CC-Cleveland-OH
                                      C-5
                                      4.5
                                     2021

                                      C-6
                                      3.8
                                     2021
CC-Dearborn-MI
                                       C
                                      7.1
                                     2021
CC-IndianaHarbor-IN
                                      IH4
                                      0.8
                                     2021

                                      IH7
                                      0.3
                                     2021
CC-Middletown-OH
                                     No. 3
                                      2.3
                                     2021
USS-Braddock-PA
                                       1
                                      2.8
                                     2021

                                       3
                                      2.1
                                     2021
USS-Gary-IN
                                     No. 4
                                      0.9
                                     2021

                                     No. 6
                                      1.3
                                     2021
USS-GraniteCity-IL
                                       B
                                      0.9
                                     2019

2.2	BF Bleeder Valves - Planned Openings

	BF planned openings are similar to BF unplanned openings, but because they are planned, the furnace conditions can be prepared before the bleeder valves are opened and emissions can be minimized. The most common reason to open bleeder valves is for repair of pipes (called "tuyeres") used for cooling or for injecting oxygen. Some steel companies have policies to immediately shut down the furnaces with water leaks in order to repair the leak; however, this is not universal. Operators also may open the bleeder values prior to other maintenance on the furnace or the stoves. In these procedures, the furnace is turned down to low idle before the relief valves are opened, hence the lower emissions during planned openings.

	The planned BF outages occur approximately twice per week and result in opening of bleeder valves for approximately 15 hours each week. The opacity during these open valve periods has been as high as 85 percent in the experience of EPA Region V staff, but also can be 5 percent or lower. The EPA Region V has numerous inspection records of BF operation where little to no opacity was recorded from bleeder valves during planned openings.

2.3	Bell Leaks

      BF bells (large and small) are part of raw material hoppers for some BFs. The typical double bell systems are arranged in a type of lock system on top of the BF so that raw materials can be charged into the BF without allowing the solid raw material or furnace gas to escape into the atmosphere. The bells look like inverted cones with flat tops and, hence, appear like bells. The raw material or "charge" is first placed in the small bell's open hopper. The small bell is on top of the large bell, and the large bell's hopper is closed during filling of the small bell hopper. After filling the small bell hopper, its top is closed to the atmosphere, then its bottom opens into the top of the large bell. After the charge material is transferred to the large bell, its top is closed and its bottom is opened to allow the charge to enter the furnace. Exhaust air from the furnace is released into the large bell hopper when the top of the furnace is opened to prepare for charging. The exhaust air exits through "uptake" ducts prior to the opening of the small bell.

      The large BF bell contacts the top of the furnace via a metal seal so that most of the BF gas and PM emissions evacuated into the uptakes are cleaned of PM by control devices. However, there is typically a narrow gap between the bell seal and the furnace that has been estimated to be about 50 micrometers (um).  A proper seal does not allow visible particulate to escape to the atmosphere. Proper sealing lasts for many weeks if not months before the surfaces wear enough to emit visible particulate. Thus, when the seals have degraded enough to emit visible PM, there is clear indication that the seals are no longer operating as designed and planning for repairs to those seals should commence. In a 1978 EPA study (EPA, 1978), it was estimated that "normally" operating bells release many tons of PM as invisible leaks and that PM emissions increase significantly when the bells wear down and the gaps in the sealing surface start to become so large that opacity is visible from the furnace top. See photos in Appendix A of a leaking large bell causing opacity to be released through the gaps in the bell seals.

2.4	BF Casthouse Fugitives

      The BF produces iron from raw materials of iron ore, limestone, dolomite, sinter, and coke. The casthouse encloses the area around the base of the furnace that includes multiple processes where PM can be released. The majority of the PM emissions from BFs occur during tapping when molten iron and slag are removed from the furnace and transported from the furnace to points outside the casthouse. PM is emitted at the taphole, from iron and slag troughs, from runners that transport iron and slag, and from the ladle that receives the molten iron. These emissions include flakes of graphite (carbon) called "kish" that is released as the metal cools (because the solubility of carbon in the metal decreases as it cools) and metal oxides that form when the reduced metal (e.g., iron, manganese) reacts with oxygen in the air. Factors affecting these emissions include the duration of tapping, exposed surface area of metal and slag, length of runners, and the presence/absence of runner covers and flame or fume suppression, which reduce contact of the iron with air.

      Most II&S facilities use local capture of PM and other emissions, with subsequent routing to a baghouse located outside the casthouse. These emissions are called primary emissions and considered point sources when emitted from the control device stacks. A few facilities use fume or flame suppression to reduce generation of emissions from the runners that transport the iron and slag outside the casthouse. These emissions are mostly emitted via roof vents at the top of the casthouse and also considered point sources. The current NESHAP has PM-related limits for both controlled emission sources from the BF casthouse, BF control device or opacity for secondary emissions from any opening, that applies to both casthouse vent.

	The regulated UFIP fugitives from the BF casthouse result from less than 100 percent capture by the systems in place at various emission points within the buildings. The casthouses at II&S facilities are similar to gigantic barns with multiple openings for emissions to escape to the atmosphere. These openings can be the roof monitor (vent), windows, general exhaust fans, and/or missing wall sheeting. The UFIP emissions from the BF casthouse can be significant and are considered an under-regulated emission source.

2.5	Beaching of Iron from BFs

      Beaching of iron occurs when the steelmaking process at the BOPF stops suddenly and cannot receive the molten iron produced in the BF. In this situation, the iron is dumped into an open air sand pit, in a process known as "pooling" or "beaching." The ensuing dust and fumes constitute an environmental hazard and the resultant pool or beached iron takes a long time to solidify before it can be crushed into usable material. Beaching typical occurs near the BF. Fugitive PM emissions result from the impact of the iron on the ground as well as the initial high temperature of the iron, which causes fumes to be emitted from the pile of molten iron until it cools in ambient temperature. Most, if not all, of the emissions are expected to be metal particulate with some gaseous sulfur dioxide emissions.

2.6	BF and BOPF Slag Handling and Storage

      Slag is the substance skimmed from the surface of the metal produced in BFs and BOPFs that contains impurities as well as components of the raw materials. Slag is a molten liquid solution of (mostly) silicates and metal oxides with some elemental metal HAP that solidifies upon cooling. The slag leaves the furnaces in open ductwork (called "runners") and is transported to receiving locations directly outside the buildings. The slag is typically dumped from the runners into front-end loaders that transport the slag to pits located near the BF. Sometimes the slag pit is immediately adjacent to the BFs and the runners empty directly into the slag pit. Emissions from slag is thought to consist of three distinct steps that can generate fugitive PM (and metal HAP) emissions: (1) dumping of slag into pits (note that almost all current II&S facilities report using water spray to cool the hot slag when it leaves the BF to minimize PM fumes and other PM emissions1); (2) slag storage in open pits where wind and weather conditions can disturb the slag surface in the open pits and generate fugitive PM emissions (because the slag becomes solid soon after delivery to the slag pit, no fuming PM emissions are expected on a long term basis); and (3) slag removal from the slag pit with front-end loaders to be processed for recycling or removal from the facility.

2.7	BOPF Shop Fugitives

      The BOPF is the steel making furnace at II&S facilities. One or more BOPF are housed in a structure called the BOPF Shop. The BOPF Shop includes both iron and steel operations that can generate emissions. The BOPF Shop receives the hot iron metal from the BF that is transported via "torpedo" cars to the BOPF shop ladle. The reladling generally takes place under a hood to capture these emissions. Desulfurization of the hot iron metal may occur in the BOPF Shop using various reagents such as soda ash, lime, and magnesium. Desulfurization may take place at various locations at an II&S facility; however, if the location is the BOPF shop, then it is most often done at the reladling station to take advantage of the fume collection system at that location. Skimming of slag from the molten iron also removes sulfur from the steelmaking process and is normally done occurs in the ladle, under a hood.

      The emissions from steelmaking in the BOPF are from charging of molten iron, metal scrap, and alloys to the furnace; introducing oxygen into the furnace to refine the iron (called oxygen blow), tilting the BOPF vessel to obtain a sample and check temperature, tapping of the molten steel into a ladle, and pouring residual slag into a slag pot. Exhaust PM and gases from the steelmaking furnace itself are captured at the opening to the BOPF and routed to PM control devices. These emissions are called primary emissions and are considered point sources after emission from the control device stacks. Numerous capture systems within the BOPF Shop collect emissions from the iron and steel processes done in open ladles, from material transfer, or charging and tapping. These captured emissions also are routed to PM control devices. These emissions are called secondary emissions and are considered point sources after emission from the control device stacks. The current NESHAP has PM limits for both primary and secondary emissions from the BOPF Shop.

	The unregulated UFIP fugitives from the BOPF Shop result from less than 100 percent capture by the systems in place at various emission points within the buildings. The BOPF Shops at II&S facilities are similar to gigantic barns with multiple openings for emissions to escape to the atmosphere. These openings can be the roof monitor (vent), windows, general exhaust fans, and/or missing wall sheeting. The UFIP emissions from the BOPF Shop can be significant and are considered an under-regulated emission source.

3.0	EMISSIONS FROM UFIP SOURCES

3.1	Opacity

	Opacity data were requested through Method 9 testing for which there was no data available between 2015 and the time the 114 collection request was received. Opacity data were requested for the following sources:

 BF bleeder valve planned openings
 BF casthouse fugitives
 Beaching of iron from BFs
 BOPF shop fugitives
 BF and BOPF shop slag processing, handling, and storage
      The opacity data are typically measured at every 15 seconds within a minute for the duration of testing. Tests lasted anywhere from a few minutes to a few hours. From this testing, one-minute averages, six-minute averages, maximum six-minute averages, and average opacity were derived for each unit. A summary of each facility and source's count of tests, maximum six-minute average, maximum 3-minute averages for BOPFs and average opacity are provided in Appendix B.

      This opacity data was used to determine best performing facilities for each UFIP source, to set opacity limits for UFIP sources, and to calculate estimated emission reductions necessary for each facility to meet these opacity limits.
3.2	Particulate Matter and HAP Emissions

	Emissions of PM were estimated for the UFIP sources using PM emission factors developed by EPA from the literature, first principles, discussions with the II&S industry, or a combination of all three. Activity factors of continuous nonpoint sources were based on industry production values. The frequency of emissions for noncontinuous (i.e., intermittent) nonpoint sources were estimated by EPA or the II&S industry. The resulting PM estimated emissions from the seven nonpoint sources in the II&S industry are shown in Table 3-1.

	The PM emission factors developed in 2019 and discussed in the technical memorandum titled Development of Emissions Estimates for Fugitive or Intermittent HAP Emission Sources for an Example II&S Facility for Input to the RTR Risk Assessment (EPA, 2019a) were used in this analysis for each of the UFIP sources except for bell leaks. The emission factor estimate that was provided by EPA Region V in 2019 (0.60 lb/ton iron) was based on a 1975 study (Batelle, 1975) and a 1978 EPA study (EPA, 1978), assuming a leak rate of 12 percent, Japanese BF particle sizes, 50 um seal gaps, 1975 PM loading, and a flow at the upper end of the estimated range (30 gr/ft[3]). The authors of these studies state that their estimates are based on "few available data;" that "some data has not been verified;" that "emission estimates cannot be accepted as accurate;" and that it "needs further research." The American Iron and Steel Institute (AISI) on EPA's 1978 task force suggested that the results from these studies were significant overestimates. Industry input on the PM emission factor for bell leaks indicated that bell leaks are rare. Subsequently, another 2019 estimate of 0.050 lb/ton iron was calculated based on this feedback by substituting a 1 percent leak rate in place of EPA Region V's 12 percent leak rate. For the purpose of this analysis, an average of EPA Region V's emission factor and the emission factor calculated from industry feedback (0.325 lb/ton iron) was used as the PM emission factor for bell leaks.

	Facility-wide emissions for each facility were estimated by multiplying the emission factors by the activity of each source. Appendix C shows the activity and estimated emissions for each facility by UFIP source.

	The HAP emitted from the nonpoint sources were metal HAP that included antimony, arsenic, beryllium, cadmium, chromium, cobalt, lead, manganese, mercury, nickel, and selenium. To estimate metal HAP emissions, a ratio of HAP-to-PM was developed from the point source data from the 2011 II&S section 114 collection data. The PM estimates for each UFIP source were multiplied by the HAP-PM ratio for the appropriate sources (i.e., from the BF for all BF-related UFIP sources and from the BOPF for the BOPF UFIP source. For slag UFIP sources, a combination of literature information and section 114 collection data for the BF were used to develop HAP/PM factors for each HAP emitted from slag UFIP sources. The development of the HAP-PM factors also are described in the technical memorandum for the example facility cited above (EPA, 2019a). The resulting HAP estimated emissions from the seven nonpoint sources in the industry are shown in Table 3-1 along with the HAP-to-PM ratios used to estimate HAP emissions from PM emissions. Derivation of the HAP-PM factors are described in detail in the memorandum cited above (EPA, 2019a).

                Table 3-1.  Total Estimated HAP Emissions for
                   Nonpoint Sources in the II&S Industry
                                Nonpoint Source
                              PM Emissions (TPY)
                                 HAP/PM Factor
                                 HAP Emission
                                     (TPY)
BF Unplanned Openings
                                      79
                                     0.037
                                      2.9
BF Planned Openings
                                      51
                                     0.037
                                      1.9
BF Bell Leaks
                                     2,302
                                     0.037
                                      85
BF Casthouse Fugitives
                                     1,240
                                     0.037
                                      46
BOPF Shop Fugitives
                                     5,434
                                     0.032
                                      174
Beaching
                                      0.9
                                     0.037
                                     0.034
Slag Handling & Storage
                                     1,198
                                     0.034
                                      41
                                     Total
                                    10,305

                                      351
Note: PM emissions are estimated from emissions factors obtained from the literature and EPA reports. HAP emissions are developed from the estimated PM emissions and the ratio of HAP to PM at the example facility in the 2019 analysis.

4.0	CONTROL MEASURES FOR REDUCING HAP EMISSIONS FROM UFIP SOURCES

	This section discusses the control measures that were identified for the seven UFIP sources, described in Section 2.0 above. The following are definitions of II&S processes used in this discussion:

 Corrective Action means the design, operation and maintenance changes that are taken, consistent with good engineering practice, to reduce or eliminate the likelihood of the recurrence of the primary cause and any other contributing cause(s) of an event identified by a root cause analysis as having resulted in a discharge of pollutants from an affected facility in excess of specified thresholds.

 Root Cause Analysis are actions taken to determine the cause of an exceedance in emissions and to determine appropriate corrective action. The root cause analysis and initial corrective action analysis should be completed and initial corrective actions taken in a timely manner after determining there is an exceedance.

4.1	Control of HAP UFIP Emissions from BF Unplanned Openings

	Most BF slips are preventable and many of the practices to avoid slips have no or minimal cost. Documents as old as 1917 (Wilcox, 1917) have prescribed operating practices that reduce or eliminate slips. Slip avoidance actions that have minimal cost include screening raw materials for very small particles (called "fines") and enhancing instrumentation on the furnace to be sufficiently precise in the monitoring of temperature and pressure so that operators can take early action to avoid a slip. Temperature and pressure changes in the furnace can be used to identify when a hang has started and furnace operation has become abnormal. Setting a limit on the number of BF unplanned openings has reduced unplanned openings in at least one area of the U.S. with II&S facilities. Allegheny County (PA) previously imposed a limit on the number of slips, but after several years the slip limit was removed because slips at II&S facilities in the county had been eliminated through effective management of BF operations spurred by the limit (Allegheny, 1989).

	Operator attentiveness to BF conditions is central to avoiding unplanned openings. Standard operating plans (SOPL) with appropriate documentation and recordkeeping can be used to ensure a facility takes certain actions, such as proper damper positions in pollution collection systems and use of better quality raw materials, to minimize slips. See Appendix E for an example SOPL to prevent unplanned openings (USOPL). The USOPL would enable facilities to achieve emission reductions in any number of ways to meet a specified number of unplanned openings.

	Most companies now have instrumentation, programming and procedures that reduce the likelihood of unplanned openings. The few facilities that do not have preventive procedures and warning devices are outliers in the number of openings experienced by BFs in the II&S industry. Stockline monitoring devices also are used to alert operators when the BF burden stops descending naturally which indicates a slip could be imminent. Many II&S facilities currently have one or two of these devices.

	For extra control of unplanned openings, a number of II&S facilities have installed what is termed a "clean" or "semi-clean" gas bleeder valve. These devices are installed after the BF dust collector and Bischoff scrubber (i.e., variable throat scrubber that allows BF top pressure to be adjusted and maintained in response to furnace conditions). If a slip or sudden surge of pressure occurs, the clean gas bleeder valve opens allowing the cleaner BF gas to be vented to the atmosphere first rather than opening the dirtier gas bleeder valves on the BF uptakes. Most existing furnaces have clean gas bleeders and all new furnaces have them. For older furnaces, the clean gas bleeder valve can be retrofit. However, the cost could be considerable to install clean gas valves on older existing furnaces.

4.2	Control of HAP UFIP Emissions from BF Planned Openings

	A procedure for establishing the lowest possible internal pressure before opening bleeder valves was developed by EPA Region 5 to ensure visible emissions are minimized to the greatest extent possible. See Appendix F for example language for planned opening standard operating plan (PSOPL). Some II&S facilities have used a similar procedure to reduce the pressure before they open the bleeder valves and this practice has significantly reduces emissions. It may be possible for all II&S facilities to perform this evaluation or a similar evaluation at each of their furnaces to minimize emissions during dirty gas bleeder valve planned openings. If opacity levels are already too high, operators should reevaluate the sequence and timing of steps when bringing a BF down for maintenance via a planned bleeder valve opening. Based on EPA enforcement experience, the most critical points in opening dirty gas bleeder valves are when the fuel is stopped, the input air is stopped, and/or when there is high internal BF pressure.

	Work practices that can be done by facilities to avoid excess emissions during shut down and before planned openings of dirty gas bleeder valves include the following:

 Tap as much liquid (iron and slag) out of the furnace as possible;
 Remove fuel and/or stop fuel injection into furnace;
 Reduce air/wind to 5 pounds per square inch (psi) bottom pressure; and
 Add steam into system at various places when there is insufficient draft, mostly near the scrubber and dust catcher (PM control)

4.3	Control of HAP UFIP Emissions from BF Bell Leaks

	It is estimated that the small and large bell seals are repaired or replaced regularly, with large bells replaced about every 5 years with a number of small bell repairs during this time period. Significant leaks can occur if the seals on both bells are not repaired or replaced in a timely manner, and as needed for high wear situations. Leaking of large bell seals at the furnace/bell seal interface can be visible to an observer. Therefore, one control technique would be to monitor the furnace/bell seal interface for visible emissions (VE) on a regular basis with the plan to replace the bell seals as soon as leaks are visible, or is above some level of opacity (e.g., 10%).

	Based on EPA Region V experience with the II&S industry, repair or replacement of the small bell seal periodically based on site-specific conditions would reduce PM and HAP metal emissions from a BF.

4.4	Control of HAP UFIP Emissions from BF Casthouse

	The opacity limit in the II&S NESHAP for monitoring fugitive PM and HAP emissions BF casthouse is less than 20 percent during thirty 6-minute tests, as 6-minute averages, from any opening in the casthouse, and between the casthouse and the furnace shell during tapping (once per Title V permit cycle, e.g., 5 years or every 2.5 years without a Title V permit). To better monitor fugitive emissions, opacity could be measured more often during events expected to produce high opacity, such as tapping, where opacity could be monitored 4 taps per week from casthouse roof vents. In order to determine the true emissions, all other openings to the casthouse should be closed. Use of EPA Method Alt-082 (DOCS) rather than EPA Method 9 would ensure accurate emissions are measured and would reduce the amount of facility labor needed to take the measurements.

	In addition, preventive measures can be done to reduce generation of emissions that contribute to opacity. These measures include keeping iron and slag runner covers in place at all times except when runner or cover is being repaired or removed for inspection purposes (2-hour repair limit).

	To identify all potential opacity sources and measures to reduce fugitive emissions, the facility could develop and operate according to a "BF Casthouse Operating Plan" to minimize fugitive emissions, to include:

 Identification of each opening in casthouse;
 Number of opacity readers needed and method of making observations;
 Locations and status of each runner cover;
 Schedule for inspection of casthouse for openings and leaks above 12 feet high, where all openings are  closed (except for roof monitor) during the opacity observations;
 Procedures to ensure all doors and other openings are closed during all transfer operations; and
 Procedures to ensure that runner covers are in place on top of runners at all times except when runner or cover is being repaired or removed for inspection purposes (specify a repair or observation limit, such as 2 hours).

4.5	Control of HAP UFIP Emissions from Beaching of Iron from BFs

	Methods of controlling beaching emissions include enclosing the process, using fume suppressants, or granulation. Granulation of the excess hot metal produces a by-product, granulated pig iron, that can readily be used internally; for example, as BOPF coolant, or sold to third parties as feedstock for electric arc furnaces, cupolas and induction furnaces (IIMA, 2019). Granulation is also used for slag processing. Application of granulation has capital and operating costs that can be offset by proceeds from sale of the granulated product. No air emissions result from the use of a granulator.

	Enclosures that prevent beached iron fumes from being mixed with the atmosphere are used at many current II&S facilities (AISI, 2017). These enclosures need only three sides to be effective. Due to the heat of the beached iron, having one side open to air allows for a better worker environment. Use of fume suppressants, such as atomized CO2, can be used alone or in conjunction with enclosures. It is our understanding that emissions can also be reduced by minimizing the height, slope, and speed of beaching.

4.6	Control of HAP UFIP Emissions from BF Slag Handling and Storage

      Slag handling has multiple points of potential fugitive emissions during slag handling operations. Measuring opacity during these events will identify points in the process where attention is need and where methods to reduce fugitives are warranted. An opacity limit or action level can be set, such as 5 percent or 10 percent opacity, as 3-minute average, or 6-minute averages. Various methods are available to reduce methods of slag emissions. Because the slag emissions are emitted from an open outdoor area, most methods of control involve purchase of equipment, some more expensive than others. The equipment used to reduce or eliminate slag emissions includes wind screen, foggers, and granulation. These are discussed below.

      Dry Fog Water Spray System--Another method is the use of (dry) fog spray systems over the pit area, where the spray is applied after each dump of slag and during all digging activities to extent feasible and safe. Dry fogging is particularly successful at controlling dust where the use of ultrasonic nozzles (and compressed air) produce a plume of very small low-mass droplets. Dry fogging controls droplet size by utilizing a special nozzle design that allows water to pass through high-frequency sound waves produced by a highly accelerated mixture of water and compressed air. The speed of the compressed air and water mixture hitting a small cup in front of the nozzle reflects the energy back into itself and creates a sonic shock wave that produces very small droplets in a cloud dispersion (NIOSH, 2019).

      The very small droplets of dry fog nozzles make this system particularly effective at knocking down respirable airborne dust because the water droplets need to be in similar size ranges to the dust particles to be effective. The intent is to have the droplets collide and attach themselves (agglomerate) to the dust particles, causing them to fall from the air. If the droplet diameter is much greater than the diameter of the dust particle, the dust particle simply follows the air stream lines around the droplet. If the water droplet is of a size comparable to that of the dust particle, contact occurs as the dust particle follows the stream lines and collides with the droplet. Therefore, for optimal agglomeration, the particle and water droplet sizes should be roughly equivalent. Water droplets in the range of 2 to 20 um have been shown to be most effective (NIOSH, 2019).

	One dry fogger can control dust in a 20 ft. x 20 ft. slag pit. The dry foggers need water and compressed air, and can be equipped with a freeze protected system. Each fogger has three manifolds, with 10 nozzles per manifold for a total of 30 nozzles. A slag pit would be fogged for at minimum about 1 minute during a slag dump. Assuming there are 15 minutes between dumps, four dumps per hour, that equates to 96 dumps per day and 96 minutes of fogging per day (DSI, 2018).

	Slag Granulation--Slag can be sent to a granulator that turns slag into granules that can be used for other purposes. No air emissions result from the use of a granulator. The granulator takes the slag and blasts it with water that turns the slag into granules that have the appearance of beach sand. The slag granules are used to make concrete. Although use of slag granulation has capital and operating costs, these can be offset by proceeds from sale of the granulated product. Two current II&S facilities use granulation for one of their BFs' slag. A separate company typically owns and runs the granulator.

      Wind Screens--One method to reduce slag pit fugitive PM is the use of wind screens that block the prevailing wind from disturbing the surface of the slag pit or the surface of the slag as it is dumped or removed from the pit. See photos of wind fencing from one vendor of wind fences in Appendix G. Unlike other forms of fugitive dust control, wind fences provide continuous control of dust without the operational and maintenance costs of other methods. Once installed, there are no additional requirements for wind fences. The fence support structures are custom designed to withstand the forces of wind specific for the area located. One vendor, offers wind fabric that is designed to "break away" on the bottom and sides while still remaining attached at the top during an extraordinary wind event. This prevents, in most cases, the fabric from being damaged due to higher than specified wind speeds. The exact wind shear speed that it takes to break the wind fabric loose from the frame is custom tailored to each end users requirements and geographical location and is designed to protect the entire wind fence system from critical support failure. After the weather event has passed the wind fabric can simply be reattached to the support structure and the wind fence can be put back into service. By being designed to release part of the fabric during a high wind event the fabric is better protected from ripping and tearing if wind exceeds its maximum designed operational limits.

4.7	Control of HAP UFIP Emissions from BOPF Shop

	The opacity limit in the II&S NESHAP for monitoring fugitive PM and HAP emissions BOPF Shop is less than 20 percent during thirty 3-minute tests, as 3-minute averages, from any opening in the BOPF Shop, and between the BOPF and the furnace shell during tapping (once per Title V permit cycle, e.g., 5 years or every 2.5 years without a Title V permit). To better monitor fugitive emissions, opacity could be measured more often during events expected to produce high opacity, such as tapping, where opacity could be monitored 4 taps per week from BOPF Shop roof vents. To help ensure accurate opacity readings from the roof vents, all other openings to the BOPF should be closed. Use of EPA Method Alt-082 (DOCS) rather than EPA Method 9 could help ensure accurate opacity readings and would reduce the amount of facility labor needed to take the measurements.

	In addition, preventive measures can be done to reduce generation of emissions that contribute to opacity. These measures include keeping iron and slag runner covers in place at all times except when runner or cover is being repaired or removed for inspection purposes (2-hour repair limit). To identify all potential opacity sources and measures to reduce fugitive emissions, the facility could develop and operate according to a "BOPF Shop Operating Plan" to minimize fugitive emissions, to include:

 List all events that generate visible emissions (including slopping) and state the steps the company will take to reduce the incidence rate.
 Minimum hot iron pour/charge rate (minutes).
 Schedule of regular inspections of BOP Shop for openings and leaks above 12 feet high with all openings closed (except for roof monitor).
 Optimize positioning of hot metal ladles with respect to the hood face and furnace mouth.
 Optimize furnace tilt angle during charging.
 Prohibit burning material, such as bags, pallets and other material in the shop.
 Keep all openings closed except when in use, especially during transfer operations. (Does not include roof monitors.)
 Continuously monitor opacity from all openings with EPA Method Alt-082 (camera); re-evaluate use of monitor every two years (alternative is Method 9).
 Use higher draft velocities to capture more fugitive emissions at a given distance from the hood.
 Perform a ventilation study to maximize secondary (fugitive) emissions capture by hooding.
 Install additional equipment to minimize fugitive emissions:
 Add extension (flanges) from primary hood into charging and tapping aisles for better draft and to shorten distance to emission source.
 Add extension of pouring spout on hot metal charging ladle to move emission point closer to or under hood.
 Add small openings in furnace doors to allow monitoring of temperature and other parameters to avoid opening doors.
 Add wall partitions or ducts to direct air into local hoods to prevent escape from building.
 Add canopy hoods to enhance fugitive collection for local hoods.

4.8	Opacity Issues

4.8.1	Opacity Monitoring

      Given the history of numerous opacity violations at II&S facilities at BF casthouses and the BOPF shop roof monitors, the use of a camera to measure opacity, as in EPA Alternative Method 082 (digital opacity camera system (DOCS)), taken from ASTM D7520-13, is an alternate to EPA Reference Method 9 and an improvement in the reliability and accuracy of opacity monitoring. The recently promulgated Ferromanganese RTR rule, published on June 30, 2015 (80 FR 37366), required opacity monitoring to be conducted according to ASTM D7520-13. For II&S facilities, the DOCS also could be used to determine the opacity from bleeder valve openings which are difficult to observe because they are either unplanned or occur during shutdown activities. The DOCS method provides reliable, unbiased opacity readings and is an improvement in the transparency of opacity monitoring results.

4.8.2	Location of Opacity Measurements

      It is commonly known to EPA inspectors that II&S facilities only read opacity at BF casthouse roof monitors and ignore emissions from openings on the sides of the casthouse and from the gap between the casthouse and the furnace. To improve the opacity monitoring from casthouses, a facility's standard operating procedures (SOP) can include identification of all openings in the casthouse that could emit opacity, identifying which openings typically have the highest opacity, and specifying which openings to be observed for opacity concurrently as a group of openings. The II&S facility SOP can identify the openings and groups of openings to be measured for opacity on a casthouse drawing; the SOP could then be reviewed and approved by their management and delegated permit authority.

      When conducting Method 9 for visible emission observations of a group of openings, the reader must look at the point of highest opacity. Therefore, the EPA Method 9 or visible emission (VE) report for a group of openings might contain a "mixture" of 15-second readings, where each 15-second reading may indicate the instantaneous opacity from a location on the casthouse several feet away from other readings. It is important to note that most often there are many openings in a casthouse and it would be necessary to perform any required readings in series or to use several readers for the different groups being read at the same time. While this may increase costs above the current practice, this practice will ensure opacity is measured from any and all opening in the casthouse.

	The alternative method to Method 9, EPA Alt-082 (DOCS), could be used to monitor the opacity from these sources. One of the benefits of EPA Alternative 082 is that many more openings can be viewed at one time, possibly saving the company money in the long term. Also, when a DOCS is used, the images of one observation can be reanalyzed if EPA or delegated authority believes the point of highest opacity was not used in calculating the opacity. The ability to reanalyze opacity readings provides the opportunity for better agreement of observations and the casthouse opacity limit. The DOCS provides a more objective, better substantiated opacity readings compared to Method 9 and would improve transparency of opacity monitoring results.

4.9	Reductions of PM and HAP With Work Practices for II&S Nonpoint Sources

	The control efficiency of  the work practices are expected to range from 50 to 80 percent based on EPA estimates of the efficiency of work practices in general. In EPA's 2019 estimates of the impacts of UFIP work practices for the II&S industry, an average value of 70 percent efficiency was used for most of the nonpoint sources (except for BOPF shop work practices, which was estimated at a 65 percent efficiency). However, in response to the EPA's request for comment on those work practice standards, some comments were received that indicated these efficiency estimates were likely an overestimation. Therefore, in this analysis, the lower end of the expected control efficiency range (50 percent) was used as a default value for each source. The submitted public comments can be found in Docket ID #EPA-HQ-OAR-2002-0083.

	Since BF casthouse fugitives, BOPF shop fugitives, and slag handling and storage were estimated to be the highest emitting sources, more specific control efficiencies were developed for these sources using opacity data that was collected in the 2022 section 114 collection request as well as the 2011 section 114 collection request. For sources that already have a maximum 6-minute opacity average that is below the proposed opacity limit, a control efficiency of zero was applied. For sources with a maximum 6-minute average above the proposed opacity limit, the percent reduction that would be needed to meet the proposed opacity limit was applied as the control efficiency, except where the percent reduction was higher than the default control efficiency value of 50 percent. Sources with a maximum 6-minute opacity average that would need greater than 50 percent reduction to meet the proposed limit were assigned the default control efficiency value of 50 percent. See Appendix D for the control efficiency values that were applied for each of these sources.

      Table 4-1 shows the estimated HAP emissions for the nonpoint sources before and after implementation of the work practices using estimates of control efficiency described above, with 351 TPY HAP before control, 238 TPY HAP after control, and 113 TPY HAP reduced.

         Table 4-1.  Estimated HAP Emissions Before and after Control
       Using Work Practices at Nonpoint Sources for the II&S Industry
                                Nonpoint Source
                              HAP Emissions (TPY)

                                Before Control
                                 After Control
                                  Reductions
BF Unplanned Openings
                                      2.9
                                      1.5
                                      1.5
BF Planned Openings
                                      1.9
                                     0.95
                                     0.95
BF Bell Leaks
                                      85
                                      43
                                      43
BF Casthouse Fugitives
                                      46
                                      31
                                      14
BOPF Shop Fugitives
                                      174
                                      134
                                      40
BF Iron Beaching
                                     0.034
                                     0.017
                                     0.017
Slag Handling & Storage
                                      41
                                      27
                                      14
                                 Overall Total
                                      351
                                      238
                                      113

5.0	COSTS OF CONTROL MEASURES FOR UFIP EMISSIONS FROM NONPOINT SOURCES

	The control measures for UFIP sources that were selected for AMOS analysis are discussed below along with the costs and emission impacts, and cost-effectiveness.

5.1	 Selected Control Measures for UFIP Sources

	The following are the control measures discussed above that were selected for analysis as part of the AMOS review for nonpoint sources. Control measures that were not selected were either not well-developed or not expected to be viable for the entire II&S industry.

5.1.1	Work Practices for BF Unplanned Openings

 Develop and operate according to a "Slip Avoidance Plan" to minimize slips and submit it to EPA for approval;
 Install devices to continuously measure/monitor material levels in the furnace (i.e., stockline), at a minimum of three locations, with alarms to inform operators of static (i.e., not moving) stockline conditions which increase the likelihood of slips; and
 Install and use instruments on the furnace to monitor temperature and pressure to help determine when a slip is likely to occur.

5.1.2	Work Practices for BF Planned Openings

 Limit opacity to 8 percent, as 6-minute average. We received opacity data from six of the eight operating facilities for planned openings. We reviewed the maximum six-minute opacity readings for all six facilities. The average of the maximum six-minute opacity values for the best performing five facilities is 7.75 percent (rounded to 8 percent). We did not apply the standard UPL approach because that method has not been used in the past when calculating opacity limits. The current UPL approach was designed around run-by-run data, usually for 3 runs per test, and could not directly be applied to opacity 6-minute averages. We estimate that the "MACT floor" is the average of the maximum 6-minute opacity levels, which is 8 percent.

5.1.3	Work Practices for BF Bell Leaks

For large bells:

       Maintain metal seats to minimize wear on seals;
       Observe BF top for VE monthly to identify beginning of leaks; measure opacity if VE positive;
 If VE are positive, conduct opacity testing monthly; and
 If opacity exceeds 10 percent, repair/replace the seal within 4 months.

For small bells:

       Maintain metal seats to minimize wear on seals; and
       Repair or replace seals prior to the metal throughput limit that has been proven and documented to produce no opacity from the small bell.

5.1.4	Work Practices for BF Casthouse Fugitives

       Limit opacity to 5 percent, as a 6-minute average;
       Develop and operate according to a "BF Casthouse Operating Plan" to minimize fugitive emissions and detect openings and leaks;
       Measure opacity frequently during the tapping operation (e.g., during four taps per month) with all openings closed (except for roof monitor) using EPA Method Alt-082 (camera) or Method 9;
       Keep doors and other openings, except roof monitors, closed during all transfer operations to extent feasible and safe; and
       Keep runner covers in place at all times except when runner or cover is being repaired or removed for inspection purposes (2-hour repair or observation limit).

5.1.5	Work Practices for BF Iron Beaching

 Minimize height, slope, and speed of beaching;
 Use carbon dioxide shielding during beaching event; and/or use full or partial (hoods) enclosures around beached iron; and
 Conduct annual opacity testing using EPA Method 9 in 6-minute blocks for 4 hours.

5.1.6	Work Practices for BF Slag Handling and Storage Operations

       Limit opacity to 5 percent, as 6-minute average;
       Use a water system over pit areas, and apply water to maintain moist slag and reduce emissions during digging and dumping; and
       If the opacity of slag dumping, loading, and digging events exceed 5 percent opacity for 2 6-minute events in one week, subsequently install and use water fog spray systems over that excess emission operation, applying the fog spray to each dump of slag to a pit or pile, each loading of slag, or during all digging activities, except on days that, due to weather conditions, applying fog spray would pose a safety risk.

5.1.7	Work Practices for BOPF Shop Fugitives

       Limit opacity to 5 percent, as a 3-minute average;
       Develop and operate according to a "BOPF Shop Operating Plan" to minimize fugitive emissions and detect openings and leaks. The BOPF Shop Operating Plan may include:
          List of all events that generate visible emissions (VE), including slopping, and steps company will take to reduce incidence rate;
          Minimize hot iron pour/charge rate (minutes) and set a maximum pour rate in tons/second.
          Schedule of regular inspections of BOPF shop structure for openings and leaks to the atmosphere;
          Optimize positioning of hot metal ladles with respect to hood face and furnace mouth;
          Optimize furnace tilt angle during charging and set a maximum tilt angle during charging;
          Keep all openings, except roof monitors, closed, especially during transfer, to extent feasible and safe;
          Use higher draft velocities to capture more fugitives at a given distance from hood, if possible; and
       Monitor opacity periodically (e.g., once per month) from all openings with EPA Method Alt-082 (camera) or with EPA Method 9.

5.2	Costs of Work Practices for UFIP Sources

	Equipment and operating costs for the work practices to control UFIP emissions were obtained from vendors of equipment, as available, or were estimated using good engineering judgement (GEJ) along with experience with the industry. Similarly, labor estimates were based on EPA experience with the tasks needed to be performed to either operate equipment or perform VE and opacity tests. Table 5-1 shows the estimated labor, capital, and annual costs of the work practices for the II&S industry based on the unit costs and the number of units at the facilities in the industry (shown in Appendix H). The labor, capital, and annual costs for the work practices for one emission unit used to develop the industry estimates in Table 5-1 are also shown in Appendix H along with individual cost factors used in the estimates. Details of the costs for the identified control measures for the seven UFIP sources are discussed in the technical memorandum cited above and titled Cost Estimates and Other Impacts for the Integrated Iron and Steel Risk and Technology Review, available in the docket to this rule. (EPA, 2019b)

	The estimated effectiveness of the work practices for each nonpoint source to reduce HAP emissions and the costs are combined in a ratio to produce a cost-effectiveness factor. Table 5-2 shows the cost-effectiveness (CE) of control of HAP emissions at each nonpoint source using the work practices described above and the HAP emission reductions shown in Table 4-1. The CE values ranged from $12,475 per ton HAP removed (BOPF Shop Fugitives) to $3,171,774 per ton HAP removed (BF Iron Beaching) with an overall cost-effectiveness for all seven nonpoint sources at $24,285/ton HAP.

                 Table 5-1.  Total Costs of the Work Practices
                 for Nonpoint Sources in the II&S Industry
                                Nonpoint Source
                             Total Industry Costs

                                     Labor
                                    Capital
                                    Annual
BF Unplanned Openings
                                   $42,387
                                  $1,468,841
                                   $197,402
BF Unplanned Openings
                                   $54,604
                                      --
                                      --
BF Bell Leaks
                                   $12,326
                                  $2,138,542
                                   $922,229
BF Casthouse Fugitives
                                   $63,005
                                   $765,373
                                   $676,890
BOPF Shop Fugitives
                                   $58,967
                                   $495,241
                                   $437,988
BF Iron Beaching
                                   $16,674
                                      --
                                   $37,955
Slag Handling & Storage
                                   $190,731
                                      --
                                   $29,018
                                  Total Costs
                                   $438,694
                                  $4,867,996
                                  $2,301,482

               Table 5-2.  Cost-Effectiveness of Work Practices
                 at Nonpoint Sources at 11 II&S Facilities
                                Nonpoint Source
                              Total Annual Costs
                             HAP Reductions (TPY)
                              Cost Effectiveness

                                     $/ton
                                  HAP removed
BF Unplanned Openings
                                   $239,789
                                      1.5
                                   $163,855
BF Planned Openings
                                   $54,604
                                     0.95
                                   $57,684
BF Bell Leaks
                                   $934,555
                                      43
                                   $21,949
BF Casthouse Fugitives
                                   $739,895
                                      14
                                   $51,354
BOPF Shop Fugitives
                                   $496,955
                                      40
                                   $12,475
BF Iron Beaching
                                   $54,629
                                     0.017
                                  $3,171,774
Slag Handling & Storage
                                   $219,749
                                      14
                                   $16,181
                                 Overall Total
                                  $2,740,176
                                      113
                                   $24,285

6.0	REFERENCES

AISI, 2017. AISI Response to U.S. EPA comments/questions on interim response. Email and attachments from P. Balserak, American Iron and Steel Institute (AISI), to D. L. Jones, U. S. Environmental Protection Agency, Research Triangle Park, NC. September 15, 2017.
Allegheny, 1989. Allegheny County Portion of the Pennsylvania State Implementation Plan for the Attainment and Maintenance of the National Ambient Air Quality Standards. Appendix 27, Article XX - Rules And Regulations. Section 518: Blast Furnace Slips. County Ordinance Number 16782. (Removed 1989.)
Battelle, 1975. "Potential for Energy Conservation in the Steel Industry." Battelle Columbus Laboratories, Columbus, OH.  PB-244-097, pages V-67 and V-68. 1975.
DSI, 2018. Personal communication (email). D. Gilroy, Sales Manager, Dust Solutions, Inc. (www.nodust.com), Vancouver, WA, with D. L. Jones, U. S. Environmental Protection Agency, Research Triangle Park, NC. 3/27/18 and 2/27/19.
EPA, 1976. Blast Furnace Slips and Accompanying Emissions as an Air Pollution Source. EPA -600/2-76-268. Battelle Columbus Laboratories, Columbus, OH, for U.S. Environmental Protection Agency, Industrial Environmental Research Laboratory, Research Triangle Park, NC. October 1976.
EPA, 1978. Pollution Effects of Abnormal Operations in Iron and Steel Making - Volume Ill.  Blast Furnace Ironmaking, Manual of Practice. EPA-600/2-78-118c. U.S. Environmental Protection Agency, Industrial Environmental Research Laboratory, Research Triangle Park, NC. June 1978.
EPA, 2019a. D.L. Jones. Development of Emissions Estimates for Fugitive or Intermittent HAP Emission Sources for an Example II&S Facility for Input to the RTR Risk Assessment. U.S. Environmental Protection Agency, Research Triangle Park, NC. May 1, 2019.
EPA, 2019b. D.L. Jones and G. Raymond. Cost Estimates and Other Impacts for the Integrated Iron and Steel Risk and Technology Review. U.S. Environmental Protection Agency, Research Triangle Park, NC. May 1, 2019.
EPA, 2019c. D. L. Jones. Ample Margin of Safety Analysis for Point Sources in the II&S Industry. U.S. Environmental Protection Agency, Research Triangle Park, NC. May 1, 2019.
IIMA, 2019. Granulated pig iron. Website of the International Iron Metallics Association, Burnham, UK. https://www.metallics.org/gpi.html. Accessed March 29, 2019.
NIOSH, 2019. A.B. Cecala, et. al. Dust Control Handbook for Industrial Minerals Mining and Processing. Second Edition. NIOSH Mining Program Report of Investigations RI 9701. Department of Health and Human Services, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, Office of Mine Safety and Health Research, Pittsburgh, PA, and Spokane, WA. March 2019.
Wilcox, 1917. F. H. Wilcox. Blast Furnace Breakouts, Explosions, and Slips, and Methods of Prevention. Bulletin 130. Department of the Interior, Bureau of Mines, Washington, DC. Government Printing Office, Washington, DC. 1917.

                                  APPENDIX A:
                          PHOTOGRAPHS OF UFIP EVENTS

    Bell Leaks

    Beaching

       BF Unplanned Openings

                                  APPENDIX B:
        SUMMARY OF NEW OPACITY DATA COLLECTED FROM II&S FACILITIES

      Table B-1: Count of New Opacity Tests Analyzed by Facility and Source Type

                                   Facility
                    BF Bleeder Valves  -  Planned Openings
                            BF Casthouse Fugitives
                           Beaching of Iron from BFs
                              BOPF Shop Fugitives
                         BF Slag Handling and Storage
CC-BurnsHarbor-IN
                                       0
                                       0
                                       0
                                       0
                                      13
CC-Cleveland-OH
                                       1
                                       6
                                       0
                                       0
                                       3
CC-Dearborn-MI
                                       0
                                       0
                                       0
                                       0
                                      25
CC-IndianaHarbor-IN
                                       1
                                       0
                                       3
                                       0
                                      26
CC-Middletown-OH
                                       6
                                       0
                                       0
                                       0
                                       0
USS-Braddock-PA
                                       5
                                      12
                                       0
                                       3
                                      54
USS-Gary-IN
                                       2
                                      12
                                       3
                                       6
                                      14
USS-GraniteCity-IL
                                       1
                                       8
                                       5
                                       3
                                      196

      Table B-2: Maximum Six-Minute Average by Facility and Source Type Based on the New Data

                                   Facility
                    BF Bleeder Valves  -  Planned Openings
                            BF Casthouse Fugitives
                           Beaching of Iron from BFs
                            BOPF Shop Fugitives[a]
                         BF Slag Handling and Storage
CC-BurnsHarbor-IN
                                   [no data]
                                   [no data]
                                   [no data]
                                   [no data]
                                     7.92
CC-Cleveland-OH
                                     6.25
                                     7.25
                                   [no data]
                                   [no data]
                                     27.71
CC-Dearborn-MI
                                   [no data]
                                   [no data]
                                   [no data]
                                   [no data]
                                     2.50
CC-IndianaHarbor-IN
                                     8.33
                                   [no data]
                                     16.46
                                   [no data]
                                     14.58
CC-Middletown-OH
                                     13.75
                                   [no data]
                                   [no data]
                                   [no data]
                                   [no data]
USS-Braddock-PA
                                     25.42
                                     3.54
                                   [no data]
                                     0.00
                                     15.42
USS-Gary-IN
                                     0.00
                                     4.17
                                     3.33
                                     6.25
                                     5.00
USS-GraniteCity-IL
                                     10.42
                                     7.50
                                     31.38
                                     2.50
                                     19.17
a Three-minute averages were calculated in place of six-minute averages for BOPF shop fugitives.

      Table B-3: Average of All New Opacity Values by Facility and Source Type

                                   Facility
                    BF Bleeder Valves  -  Planned Openings
                            BF Casthouse Fugitives
                           Beaching of Iron from BFs
                              BOPF Shop Fugitives
                         BF Slag Handling and Storage
CC-BurnsHarbor-IN
                                       0
                                       0
                                       0
                                       0
                                      13
CC-Cleveland-OH
                                       1
                                       6
                                       0
                                       0
                                       3
CC-Dearborn-MI
                                       0
                                       0
                                       0
                                       0
                                      25
CC-IndianaHarbor-IN
                                       1
                                       0
                                       3
                                       0
                                      26
CC-Middletown-OH
                                       6
                                       0
                                       0
                                       0
                                       0
USS-Braddock-PA
                                       5
                                      12
                                       0
                                       3
                                      54
USS-Gary-IN
                                       2
                                      12
                                       3
                                       6
                                      14
USS-GraniteCity-IL
                                       1
                                       8
                                       5
                                       3
                                      196

Several of the facilities also submitted "previous" opacity data files per our recent 114 collection, but we did not evaluate all of that previous data because there were so many previous opacity data files (most of them PDFs, which would take a long time to pull data from).  However, we did review and evaluate the data from 37 of the opacity tests for BOF Shops presented in PDF files or Excel spreadsheets at Indiana Harbor, Gary, Burnsharbor and Dearborn facilities as shown in Table B-5 below, and 28 of the opacity tests for BF casthouses presented in PDF files or Excel spreadsheets at Indiana Harbor, Gary and Dearborn facilities as shown in Table B-6 below.  The number of previous opacity data files submitted by 5 facilities are shown in Table B-4.

Table B-4.  Number of "Previous" Opacity Files Received per the 2022 114 Collection
Facility  /  Source Type
BF casthouse fugitives
BOPF shop fugitives
CC-BurnsHarbor-IN
                                                                            202
                                                                              2
CC-Cleveland-OH
-
-
CC-Dearborn-MI
                                                                              3
                                                                              5
CC-IndianaHarbor-IN
                                                                             51
                                                                              6
CC-Middletown-OH
                                                                              1
                                                                              1

Table B-5. Opacity Data for BOF Shop at Gary, Burns Harbor, Dearborn and Indiana Harbor (IH) facilities
Facility
Date
Duration of test (minutes)
BOF Shop ID
Total minutes opacity = 0%
Total minutes Opacity was >0%
Max 6-minute Opacity During test unless indicated otherwise
Comments
IH
8/3/17
74 min
BOF 4SP
74 min
0
0%

IH
8/4/17
255 min
BOF 4SP
255 min
0
0%

IH
6/7/19
44 min
BOF 3SP
44 min
0
0%

IH
6/7/19
109 min
BOF 3SP
109 min
0
0%

IH
6/7/19
108 min
BOF 3SP
109 min
0
0%

Burnsharbor
1/8/22
140 min
BOF
140 min
0 min
0%

Burnsharbor
1/8/22
126 min
BOF
138 min
2 min
2.1%

Dearborn
5/14/18
240 min
BOF
202 min
37 min
17.7% (6-min), 17.9% (3-min)

Dearborn
11/17/21
130 min
BOF
127.5
2.5 min
2.1% (3-min)

Dearborn
11/17/21
130 min
BOF
129 min
3 min
3.75% (3 min. avg)

Gary
2/11/22
120 min
BOF #1
120 min
0 min
0%

Gary
2/14/22
120 min
BOF #1
118.5 min
1.5 min
4.2% (6-min), 8.4% (3-min)

Gary
2/22/22
120 min
BOF #1
120 min
0 min
0%

Gary
4/15/22
120 min
BOF ?
118 min
2 min
6% (6-min), 12% (3-min)

Gary
4/18/22
90 min
BOF ?
116.875 min
3.25 min
5.6% (6-min), 11% (3-min)?

Gary
4/20/22
120 min
BOF #1
120 min
0 min
0%

Gary
4/22/22
120 min
BOF #1
120 min
0 min
0%

Gary
4/25/22
120 min
BOF #1
120 min
0 min
0%

Gary
4/27/22
30 min
BOF ?
28 min
2 min
16.25% (6-min), 32.5% (3-min)?

Gary
4/27/22
60 min
BOF
57 min
3 min
2.7%

Gary
4/29/22
60 min
BOF ?
60 min
0 min
0%

Gary
5/2/22
60 min
BOF ?
57 min
3 min
17.9% (6-min), 35.8% (3-min)

Gary
5/4/22
120 min
BOF
120 min
0 min
0%

Gary
5/6/22
120 min
BOF
120 min
0 min
0%

Gary
5/9/22
120 min
BOF
120 min
0 min
0%

Gary
5/11/22
120 min
BOF
120 min
0 min
0%

Gary
5/16/22
120 min
BOF
120 min
0 min
0%

Gary
5/18/22
60 min
BOF
60 min
0 min
0%

Gary
5/20/22
60 min
BOF
60 min
0 min
0%

Gary
5/23/22
60 min
BOF
60 min
0 min
0%

Gary
5/24/22
120 min
BOF
120 min
0 min
0%

Gary
5/25/22
120 min
BOF
120 min
0 min
0%

Gary
5/26/22
120 min
BOF
120 min
0 min
0%

Gary
5/27/22
120 min
BOF
120 min
0 min
0%

Gary
5/31/22
120 min
BOF
120 min
0 min
0%

Gary
5/31/22
120 min
BOF
118 min
2 min
5.6% (6-min), 11.2% (3-min)

Gary
6/1/22
120 min
BOF
120 min
0 min
0%

Table B-6.  Opacity Data for BF Casthouse at the US Steel Gary and Indiana Harbor facilities
Facility
Date
Duration of test (minutes)
BF Casthouse
Total minutes that opacity = 0%
Total minutes opacity
was > 0%
Max 6-minute Opacity During test
Comments
Gary
3/16/22
136 min
BF #14
136
0
0%

Gary
3/15/22
118 min
BF
118 min
0
0%

Gary
2/28/22
149 min
BF
149 min
0
0%

Gary
2/21/22
121 min
BF #4
119.75 min
1.25 min
3.13%

Gary
2/18/22
120 min
BF #4
119.25 min
0.75 min
2.5%

Gary
2/10/22
120 min
BF #4
120 min
0
0%

Gary
2/7/22
120 min
BF #6
119.25 min
0.75 min
1.7%

Gary
2/22/22
120 min
BF #8
120 min
0
0%

Gary
2/11/22
102 min
BF #8
102 min
0
0%

Gary
2/8/22
234 min
BF #8
232.5 min
1.5 min
4.17%

Indiana Harbor (IH)
6/7/19
44 min
BOF 3SP
44 min
0
0%

IH
6/7/19
109 min
BOF 3SP
109 min
0
0%

IH
6/7/19
108 min
BOF 3SP
109 min
0
0%

IH
8/3/17
74 min
BOF 4SP
74 min
0
0%

IH
8/4/17
255 min
BOF 4SP
255 min
0
0%

IH
4/29/19
179 min
BF IH3
179 min
0
0%

IH
4/29/19
130 min
BF IH3
179 min
0
0%

IH
5/4/19
239 min
BF IH3
179 min
0
0%

IH
10/25/16
? min
BF IH4
? min
?
1.9%

IH
9/10/21
74 min
BF IH4
74 min
0
0%

IH
9/10/21
164 min
BF IH4
164 min
0
0%

IH
9/10/21
219 min
BF IH4
219 min
0
0%

IH
10/9/18
179 min
BF IH7
179 min
0
0%

IH
10/11/18
150 min
BF IH7
?? min
?
1%

IH
10/11/18
136 min
BF IH7
?? min
?
1.7%

IH
2/20/19
145 min
BF IH7
145 min
0
0%

IH
2/20/19
205 min
BF IH7
205 min
0
0%

IH
2/21/19
185 min
BF IH7
185 min
0
0%

                                  APPENDIX C:
      PM EMISSION FACTORS USED TO ESTIMATE EMISSIONS FROM II&S NONPOINT SOURCES

      Table C-1. Estimated Nonpoint Emissions by Source and Facility

                                    Source
                              PM Emissions (TPY)
                                 Frequency[a]
                                  Activity[b]
                               CC-BurnsHarbor-IN
BF Unplanned Openings
                                                                             10
                                                                             48
events/yr
                                  by unit (2)
BF Planned Openings
                                                                              6
                                                                            156
events/yr
                                  by unit (2)
BF Bell Leaks
                                                                            651
                                  continuous
  4,007,423
TPY iron
BF Casthouse Fugitives
                                                                            200
                                  continuous
  4,007,423
TPY iron
BOPF Shop Fugitives
                                                                            929
                                  continuous
  4,470,258
TPY steel
                              BOPF Top Fugitives
                                      637
                                  continuous
  4,470,258
TPY steel
                                 Tapping Steel
                                      103
                                  continuous
  4,470,258
TPY steel
                                 Iron Sources
                                      189
                                  continuous
  4,007,423
TPY iron
                                                                       Charging
60
                                  continuous
  4,007,423
TPY iron
                                                                    HM Transfer
19
                                  continuous
  4,007,423
TPY iron
                                                                         DeSulf
110
                                  continuous
  4,007,423
TPY iron
Beaching
                                                                           0.13
                                      700
TPY
                                  by unit (2)
Slag Pits
                                                                            204
                                  continuous
  1,407,335
TPY slag
                                     Total
                                                                          2,001

                                CC-Cleveland-OH
BF Unplanned Openings
                                                                             10
                                                                             48
events/yr
                                  by unit (2)
BF Planned Openings
                                                                              6
                                                                            156
events/yr
                                  by unit (2)
BF Bell Leaks
                                                                            205
                                  continuous
  1,260,588[c]
TPY iron
BF Casthouse Fugitives
                                                                            122
                                  continuous
  2,437,140
TPY iron
BOPF Shop Fugitives
                                                                            581
                                  continuous
  2,813,021
TPY steel
                              BOPF Top Fugitives
                                      401
                                  continuous
  2,813,021
TPY steel
                                 Tapping Steel
                                      65
                                  continuous
  2,813,021
TPY steel
                                 Iron Sources
                                      115
                                  continuous
  2,437,140
TPY iron
                                                                       Charging
37
                                  continuous
  2,437,140
TPY iron
                                                                    HM Transfer
12
                                  continuous
  2,437,140
TPY iron
                                                                         DeSulf
67
                                  continuous
  2,437,140
TPY iron
Beaching
                                                                        0.00[d]
                                      700
TPY
                                  by unit (2)
Slag Pits
                                                                            146
                                  continuous
  1,009,563
TPY slag
                                     Total
                                                                           1070

                                    Source
                              PM Emissions (TPY)
                                 Frequency[a]
                                  Activity[b]
                                CC-Dearborn-MI
BF Unplanned Openings
                                                                              5
                                                                             48
events/yr
                                  by unit (1)
BF Planned Openings
                                                                              3
                                                                            156
events/yr
                                  by unit (1)
BF Bell Leaks
                                                                              0
                                  continuous
  2,031,843
TPY iron
BF Casthouse Fugitives
                                                                            102
                                  continuous
  2,031,843
TPY iron
BOPF Shop Fugitives
                                                                            516
                                  continuous
  2,536,194
TPY steel
                              BOPF Top Fugitives
                                      361
                                  continuous
  2,536,194
TPY steel
                                 Tapping Steel
                                      58
                                  continuous
  2,536,194
TPY steel
                                 Iron Sources
                                      96
                                  continuous
  2,031,843
TPY iron
                                                                       Charging
30
                                  continuous
  2,031,843
TPY iron
                                                                    HM Transfer
10
                                  continuous
  2,031,843
TPY iron
                                                                         DeSulf
56
                                  continuous
  2,031,843
TPY iron
Beaching
                                                                           0.07
                                      700
TPY
                                  by unit (1)
Slag Pits
                                                                            116
                                  continuous
     799,126
TPY slag
                                     Total
                                                                            741

                              CC-IndianaHarbor-IN
BF Unplanned Openings
                                                                             10
                                                                             48
events/yr
                                  by unit (2)
BF Planned Openings
                                                                              6
                                                                            156
events/yr
                                  by unit (2)
BF Bell Leaks
                                                                            260
                                  continuous
  1,600,000[c]
TPY iron
BF Casthouse Fugitives
                                                                            235
                                  continuous
  4,700,000
TPY iron
BOPF Shop Fugitives
                                                                            917
                                  continuous
  4,200,000
TPY steel
                              BOPF Top Fugitives
                                      599
                                  continuous
  4,200,000
TPY steel
                                 Tapping Steel
                                      97
                                  continuous
  4,200,000
TPY steel
                                 Iron Sources
                                      222
                                  continuous
  4,700,000
TPY iron
                                                                       Charging
71
                                  continuous
  4,700,000
TPY iron
                                                                    HM Transfer
22
                                  continuous
  4,700,000
TPY iron
                                                                         DeSulf
129
                                  continuous
  4,700,000
TPY iron
Beaching
                                                                           0.13
                                      700
TPY
                                  by unit (2)
Slag Pits
                                                                            229
                                  continuous
  1,580,000
TPY slag
                                     Total
                                                                          1,658

                                    Source
                              PM Emissions (TPY)
                                 Frequency[a]
                                  Activity[b]
                               CC-Middletown-OH
BF Unplanned Openings
                                                                              5
                                                                             48
events/yr
                                  by unit (1)
BF Planned Openings
                                                                              3
                                                                            156
events/yr
                                  by unit (1)
BF Bell Leaks
                                                                            328
                                  continuous
  2,020,451
TPY iron
BF Casthouse Fugitives
                                                                            101
                                  continuous
  2,020,451
TPY iron
BOPF Shop Fugitives
                                                                            174
                                  continuous
     472,744
TPY steel
                              BOPF Top Fugitives
                                      67
                                  continuous
     472,744
TPY steel
                                 Tapping Steel
                                      11
                                  continuous
     472,744
TPY steel
                                 Iron Sources
                                      95
                                  continuous
  2,020,451
TPY iron
                                                                       Charging
30
                                  continuous
  2,020,451
TPY iron
                                                                    HM Transfer
10
                                  continuous
  2,020,451
TPY iron
                                                                         DeSulf
56
                                  continuous
  2,020,451
TPY iron
Beaching
                                                                           0.07
                                      700
TPY
                                  by unit (1)
Slag Pits
                                                                             96
                                  continuous
     660,634
TPY slag
                                     Total
                                                                            707

                                USS-Braddock-PA
BF Unplanned Openings
                                                                             10
                                                                             48
events/yr
                                  by unit (2)
BF Planned Openings
                                                                              6
                                                                            156
events/yr
                                  by unit (2)
BF Bell Leaks
                                                                            366
                                  continuous
  2,253,630
TPY iron
BF Casthouse Fugitives
                                                                            113
                                  continuous
  2,253,630
TPY iron
BOPF Shop Fugitives
                                                                            554
                                  continuous
  2,701,327
TPY steel
                              BOPF Top Fugitives
                                      385
                                  continuous
  2,701,327
TPY steel
                                 Tapping Steel
                                      62
                                  continuous
  2,701,327
TPY steel
                                 Iron Sources
                                      106
                                  continuous
  2,253,630
TPY iron
                                                                       Charging
34
                                  continuous
  2,253,630
TPY iron
                                                                    HM Transfer
11
                                  continuous
  2,253,630
TPY iron
                                                                         DeSulf
62
                                  continuous
  2,253,630
TPY iron
Beaching
                                                                           0.13
                                      700
TPY
                                  by unit (2)
Slag Pits
                                                                             68
                                  continuous
     470,994
TPY slag
                                     Total
                                                                          1,117

                                    Source
                              PM Emissions (TPY)
                                 Frequency[a]
                                  Activity[b]
                                  USS-Gary-IN
BF Unplanned Openings
                                                                             20
                                                                             48
events/yr
                                  by unit (4)
BF Planned Openings
                                                                             13
                                                                            156
events/yr
                                  by unit (4)
BF Bell Leaks
                                                                            322
                                  continuous
  1,978,609[e]
TPY iron
BF Casthouse Fugitives
                                                                            256
                                  continuous
  5,121,867
TPY iron
BOPF Shop Fugitives
                                                                          1,214
                                  continuous
  5,871,382
TPY steel
                              BOPF Top Fugitives
                                      837
                                  continuous
  5,871,382
TPY steel
                                 Tapping Steel
                                      135
                                  continuous
  5,871,382
TPY steel
                                 Iron Sources
                                      242
                                  continuous
  5,121,867
TPY iron
                                                                       Charging
77
                                  continuous
  5,121,867
TPY iron
                                                                    HM Transfer
24
                                  continuous
  5,121,867
TPY iron
                                                                         DeSulf
141
                                  continuous
  5,121,867
TPY iron
Beaching
                                                                           0.27
                                      700
TPY*
                                  by unit (4)
Slag Pits
                                                                            229
                                  continuous
  1,580,467
TPY slag
                                     Total
                                                                          2,053

                              USS-GraniteCity-IL
BF Unplanned Openings
                                                                             10
                                                                             48
events/yr
                                  by unit (2)
BF Planned Openings
                                                                              6
                                                                            156
events/yr
                                  by unit (2)
BF Bell Leaks
                                                                            169
                                  continuous
  1,042,769[c]
TPY iron
BF Casthouse Fugitives
                                                                            111
                                  continuous
  2,229,682
TPY iron
BOPF Shop Fugitives
                                                                            550
                                  continuous
  2,689,151
TPY steel
                              BOPF Top Fugitives
                                      383
                                  continuous
  2,689,151
TPY steel
                                 Tapping Steel
                                      62
                                  continuous
  2,689,151
TPY steel
                                 Iron Sources
                                      105
                                  continuous
  2,229,682
TPY iron
                                                                       Charging
33
                                  continuous
  2,229,682
TPY iron
                                                                    HM Transfer
11
                                  continuous
  2,229,682
TPY iron
                                                                         DeSulf
61
                                  continuous
  2,229,682
TPY iron
Beaching
                                                                           0.13
                                      700
TPY
                                  by unit (2)
Slag Pits
                                                                            109
                                  continuous
     750,594
TPY slag
                                     Total
                                                                            957

a Frequency estimates are described in detail in the technical memorandum titled Development of Emissions Estimates for Fugitive or Intermittent HAP Emission Sources for an Example II&S Facility for Input to the RTR Risk Assessment (EPA, 2019a)
[b] Production in the most recent typical year for U.S. Steel facilities was claimed as confidential in the 2022 section 114 collection; therefore, the production values reported in the 2011 section 114 collection were used for U.S. Steel's active units.
c One of the active BFs for this facility was reported to have a bell-less top in the 2022 section 114 collection. The activity recorded is that of any active BFs with two-bell tops.
d Responses to the 2022 section 114 collection indicated that there was no beaching at the CC-Cleveland-OH facility.
e Responses to the 2022 section 114 collection indicated that two of the active BFs have bell-less tops.

                                  APPENDIX D:
EMISSION REDUCTION FACTOR DETERMINATION FOR PROPOSED BF CASTHOUSE FUGITIVE, BOPF SHOP FUGITIVE, AND SLAG PROCESSING, HANDLING, AND STORAGE LIMITS

Table D-1. Emission Reduction Factor Determination for BF Casthouse Fugitives

                                   Facility
                           Max 6-Minute Opacity (%)
                                    Source
                              Emission Reduction
                           Emission Reduction Basis
CC-BurnsHarbor-IN
                                     12.08
2011 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Cleveland-OH
                                     7.25
2022 114 data
                                      31%
(max - 5%)/max
CC-Dearborn-MI
                                     12.5
2011 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-IndianaHarbor-IN
                                     13.75
2011 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Middletown-OH
                                     9.17
2011 114 data
                                      45%
(max - 5%)/max
USS-Braddock-PA
                                     3.54
2022 114 data
                                      0%
Max is already below 5% limit
USS-Gary-IN
                                     4.17
2022 114 data
                                      0%
Max is already below 5% limit
USS-GraniteCity-IL
                                      7.5
2022 114 data
                                      33%
(max - 5%)/max

Table D-2. Emission Reduction Factor Determination for BOPF Shop Fugitives

                                   Facility
                           Max 6-Minute Opacity (%)
                                    Source
                              Emission Reduction
                           Emission Reduction Basis
CC-BurnsHarbor-IN
                                     12.08
2011 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Cleveland-OH
                                     4.58
2011 114 data
                                      0%
Max is already below 5% limit
CC-Dearborn-MI
                                     4.17
2011 114 data
                                      0%
Max is already below 5% limit
CC-IndianaHarbor-IN
                                     13.75
2011 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Middletown-OH
                                     9.17
2011 114 data
                                      45%
(max - 5%)/max
USS-Braddock-PA
                                       0
2022 114 data
                                      0%
Max is already below 5% limit
USS-Gary-IN
                                     6.25
2022 114 data
                                      20%
(max - 5%)/max
USS-GraniteCity-IL
                                      2.5
2022 114 data
                                      0%
Max is already below 5% limit

Table D-3. Emission Reduction Factor Determination for Slag Processing, Handling, and Storage

                                   Facility
                           Max 6-Minute Opacity (%)
                                    Source
                              Emission Reduction
                           Emission Reduction Basis
CC-BurnsHarbor-IN
                                     7.92
2022 114 data
                                      37%
(max - 5%)/max
CC-Cleveland-OH
                                     27.71
2022 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Dearborn-MI
                                      2.5
2022 114 data
                                      0%
Max is already below 5% limit
CC-IndianaHarbor-IN
                                     14.58
2022 114 data
                                      50%
Default value; (max - 5%)/max > 50%
CC-Middletown-OH
                                   [no data]
[no data]
                                      50%
Default value
USS-Braddock-PA
                                     15.42
2022 114 data
                                      50%
Default value; (max - 5%)/max > 50%
USS-Gary-IN
                                       5
2022 114 data
                                      0%
Max already meets 5% limit
USS-GraniteCity-IL
                                     19.17
2022 114 data
                                      50%
Default value; (max - 5%)/max > 50%

                                  APPENDIX E:
                    COMPONENTS IN A STANDARD OPERATING PLAN
                 TO REDUCE UNPLANNED BLEEDER OPENINGS (USOPL)

Alarms, Operational and Maintenance Procedural Changes
 Create acceptable ranges and alarms for top temperature (minimum temperature assumed to be above 212°F), pressure differential across the burden, stockline movement (descent rate), and rate of charges (how many charges over a one hour period).
 Revise SOPs to dictate the steps to address alarms and potential bridging in burden, including when to, and how to, check the furnace.
 Create or review an USOPL that instructs operators how to change burden distribution when burden descent problems are found, such as changing charging sequence, armor position, bell opening speed, and/or bell opening depth.

Raw Material Practices
 Review effectiveness of the screening equipment for raw materials.
 Ensure weighing systems for coke, pellets and PCI are calibrated and accurate.
 Ensure there is a moisture sensor in the cold blast and measurement of all sources of moisture into the furnace and that these instruments are accurate and maintained.
 Review purchasing specifications of raw materials to ensure purchasing department purchases quality materials, and take a larger number of samples to confirm actual delivered material meets specs.
 Develop or review the SOP for raw material selection (e.g. from where in the pile given atmospheric conditions), raw material blending procedures for raw materials that do not meet minimum specifications or are of poor quality, and screening procedures. Include actions to take when using Destock coke.
 Review the number and appropriateness of instruments and alarms in the gas cleaner system to reduce the number of instances of high back pressure and thus high top pressure.

 BF Monitoring and Control Equipment
 Install modern (microwave) stockline monitoring equipment. Several microwave monitors ensure accurate reading of entire top of burden.
 Install "profile meter" and "in-burden probe" to gather data necessary to assess conditions in the furnace.
 Develop and install furnace software/models to analyze meter and probe data and make changes to charging sequence to mitigate furnace conditions that lead to instability.
 Install clean gas bleeder valve.
 Upgrade or install variable throat venturi system to ensure it can quickly adjust to furnace top pressure changes.
 Install "movable armor" to allow for accurate burden distribution.
 Install "bell-less top" to allow for accurate burden distribution.
        Table E-1. Example Components of a Standard Operating Plan To
                   Reduce Unplanned Bleeder Openings (USOPL)
                                   Category
        Components of Unplanned Opening Standard Operating Plan (USOPL)

                                  Furnace Top
Two bell system

Bell-less top
                               Normal Operations
Normal range of top temperature

Normal range of burden pressure differential (dP)

Normal burden descent pattern

Normal charge rate (number of charges per hours)

Charging (e.g., speed of large bell opening, how far open)
                        Alarms for Abnormal Conditions
Alarms for top temperature deviations

Alarms for burden dP deviations

Alarms for stockline movement (e.g., failure to descend at normal rate, ft/min)

Alarms if skip car cannot dump (waiting for burden to descend)

Alarm for permeability deviations
                        Correcting Abnormal Conditions
Top temperature deviations

Burden dp deviations

Stockline movement alarms

Skip car not dumping issues

Permeability deviations

Documenting/investigating causes of abnormal condition
                            Monitoring Instruments
Electronic (microwave) stockline measurement

Burden distribution instruments (profile meter or in-burden probe)
                                 Raw Materials
Raw material handling during rain/snow (selection, screening, blending)

Sampling pellets upon delivery

Sampling coke upon delivery
                           Equipment/Computer Models
Burden distribution model

Charging sequence model

Permeability model

Manufacturer of operating software

Movable armor for burden distribution

Variable throat venturi

Bischoff scrubber

Clean gas bleeder

                                  APPENDIX F:
                  EXAMPLE OPERATING PLAN FOR PLANNED OPENINGS
                          OF BF BLEEDER VALVES (PSOPL)

 	The purpose of the planned opening standard operating plan (PSOPL) is to minimize visible emissions during BF (BF) bleeder valve (BV) planned openings. Records should be kept on-site for 5 years and made available for inspection at any time.

       The following items shall be recorded before, during, and after the BV planned openings as part of the PSOPL to minimize emissions:
             Record the time and duration of BV planned openings.
             Record BF operating parameter data during the period that the facility is preparing for a planned opening and during the time of the BV opening itself, including which bleeder opened, top pressure and hot blast pressure leading up to and during the opening;
             Identify and record the primary operational reason for each BV planned opening (i.e., scheduled maintenance, production adjustments, burden adjustments);
             Evaluate and record operationally acceptable ranges of top pressure and hot blast pressure such that visible emissions performance is optimized during BV planned opening without incurring adverse effects on safety and furnace operations. The facility will determine what it deems adverse effects and operationally acceptable.
             Perform visible emission (VE) readings according to Method 9, 22, or EPA Alternative Method 082 (DOCS) protocol during all BV planned openings (regardless of duration) that occur Monday through Friday 7:00 am  -  3:00 pm, excluding holidays. The facility should begin VE readings at least 15 minutes in advance of the initiation of the BV planned opening.
             The facility shall commence the visible emission observations upon opening of the BV and continue such observations for at least 10 minutes. At the end of the ten-minute period, if there are visible emissions greater than 10 percent in a six-minute average, the facility shall continue to take the observations for at least one hour or until visible emissions are less than or equal to 10 percent for three continuous minutes.

       As part of the recordkeeping for the PSOPL, the facility also should state its findings and conclusions, including, but not limited to, the items outlined below:

             Detailed description of process variables that could have a material impact on opacity from bleeders during BV planned openings, including, the blast pressure at which the bleeders open, the period between ceasing fuel input and opening the bleeders, and the period between opening the bleeders and isolating the stoves/blast; and
             Detailed description of the operationally acceptable ranges of top pressure and hot blast pressure such that visible emission performance is reduced to the greatest extent practicable. The facility should state with specificity the basis for the lowest pressure in the operationally acceptable range and why an even lower pressure is not operationally acceptable.

                                                                    (continued)

             In the event that a 10 percent, 6-minute average opacity is exceeded, facilities should submit a compliance demonstration report that includes the information stated above and results of all VE readings. On the occasion of the third BV planned opening that results in visible emissions greater than 10 percent in a six-minute average, the facility is required to use the DOCS prior to any BV planned opening, during the planned opening, and to continue until opacity is less than or equal to 10 percent in a six-minute average. On the occasion of the fifth BV planned opening that results in visible emissions greater than 10 percent in a six-minute average, the facility shall install a DOCS in the area of the BV for 24-hour observations for a 6-month period. At the end of this period, if no exceedances of the 10 percent six-minute averages occur, the DOCS can be removed.
                                 APPENDIX G:
                PHOTOS OF WIND FENCES FOR SLAG PIT DUST CONTROL

       The following are photographs of wind fences in various applications for dust control from one vendor of wind fences. http://dustcontroltech.com/products/industrial-wind-fences

                                  APPENDIX H:
                COST FACTORS AND ESTIMATES FOR NONPOINT SOURCES

	Table H-1. Summary of Annualized Capital & Annual Operating Costs for Nonpoint Work Practices at One Unita
                                 Cost Item[b]
                                Nonpoint Source
                                  Comments[e]

                              Unplanned Openings
                               Planned Openings
                                  Bell Leaks
                                 BF Casthouse
                                   BOP Shop
                                   Beaching
                                    Slag[d]

                                     Small
                                     Large

                                 Enclosure[c]
                                 Fume Control

                                 Capital Costs

Total Capital Investment (TCI)
                                   $169,958
                                      $0
                                    $56,277
                                   $225,110
                                    $45,022
                                    $45,022
                                      $0
                                      $0
                                      $0
See individual worksheets for details of cost items.
Capital Recovery Factor (CRF)
                                   0.094393
                                      NA
                                   2.104408
                                   0.070081
                                   0.094393
                                   0.094393
                                      NA
                                      NA
                                      NA
[(IN*(1+IN)^LIF)/((1+IN)^LIF-1)]*TCI,[f] 7% interest (IN)[g]
Total Capital Recovery (TCR)
                                    $16,043
                                      $0
                                   $118,431
                                    $15,776
                                    $4,250
                                    $4,250
                                      $0
                                      $0
                                      $0
TCI*CRF
Administrative charges (ADM)
                                    $3,399
                                      $0
                                    $1,126
                                    $4,502
                                     $900
                                     $900
                                     $883
                                      $0
                                      $0
2%*TCI.
Property taxes (TAX)
                                    $1,700
                                      $0
                                     $563
                                    $2,251
                                     $450
                                     $450
                                     $442
                                      $0
                                      $0
1%*TCI
Insurance (INS)
                                    $1,700
                                      $0
                                     $563
                                    $2,251
                                     $450
                                     $450
                                     $442
                                      $0
                                      $0
1%*TCI
Annualized Capital Cost, $/yr
                                    $22,841
                                      $0
                                   $120,682
                                    $24,780
                                    $6,051
                                    $6,051
                                    $1,766
                                      $0
                                      $0
TCR+ADM+TAX+INS
                               Operating  Costs

Control device specific costs
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                      NA
                                    $1,066
                                    $4,145
See individual worksheets for cost items.
Consulting Costs, $/yr.
                                      NA
                                      NA
                                      NA
                                      NA
                                    $33,766
                                    $33,766
                                      NA
                                      NA
                                      NA
See individual worksheets for cost items.
Total Annual O&M Cost, $/yr[a]
                                      $0
                                      $0
                                      $0
                                      $0
                                    $33,766
                                    $33,766
                                      $0
                                    $1,066
                                    $4,145
Control device + consulting.
Total Annualized Capital Costs, $/yr
                                  $22,841.12
                                     $0.00
                                  $120,681.74
                                  $24,780.24
                                  $39,817.08
                                  $39,817.08
                                   $1,961.84
                                   $1,065.99
                                   $4,145.39
Annualized capital + Annual O&M

                                  $145,461.98

                                   $3,027.83

[a] NA = Not applicable.
[b] No maintenance (or overhead), electricity, or waste disposal are needed and, therefore, are not shown.
[c] Administrative costs, taxes, and insurance for beaching enclosure built from on-site materials are based on costs for a purchased unit.

[d] Not requiring a dry fog system; facilities may spray water on top of slag instead.
[e] Cost procedures from EPA Cost Manual at https://www.epa.gov/sites/production/files/2017-12/documents/epaccmcostestimationmethodchapter_7thedition_2017.pdf
[f] See individual worksheets for lifetime (LIF) of capital investment.
g Interest rate taken from https://fred.stlouisfed.org/series/PRIME. December 7, 2022.

    Table H-2. Labor Costs for Nonpoint Source Work Practices for One Unit
                               Nonpoint Sources
                 Labor for Nonpoint Work Practices at One Unit
                                  Total Labor

                                 Steel Worker
                             Environmental Worker
                                    Manager

                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                     Hours
                                     Cost
                                     Hours
                                     Cost
BF Unplanned Openings
                                      10
                                     $619
                                      10
                                     $732
                                       8
                                    $1,142
                                      28
                                    $2,493
BF Planned Openings
                                      26
                                    $1,609
                                      26
                                    $1,904
                                       4
                                     $571
                                      56
                                    $4,084
BF Bell Leaks
                                       6
                                     $371
                                       6
                                     $439
                                       4
                                     $571
                                      16
                                    $1,382
BF Casthouse Fugitives
                                      24
                                    $1,485
                                      24
                                    $1,758
                                       4
                                     $571
                                      52
                                    $3,814
BOP Shop Fugitives
                                      34
                                    $2,103
                                      34
                                    $2,490
                                       8
                                    $1,142
                                      76
                                    $5,736
BF Beaching
                                       4
                                     $247
                                       4
                                     $293
                                       4
                                     $571
                                      12
                                    $1,112
Slag Handling
                                      84
                                    $5,197
                                      84
                                    $6,153
                                       4
                                     $571
                                      172
                                   $11,921
                                Total Cost ($)
                                      188
                                   $11,631
                                      188
                                   $13,771
                                      36
                                    $5,140
                                      412
                                   $30,541
Note: Labor rates from "BLS National Occupational Employment and Wage Estimates," at link below, with 110 percent markup to produce "loaded" wages. https://www.bls.gov/oes/current/oes_nat.htm. See Wage Rate table.

Table H-3. II&S Industry Units per Facility for which Work Practices Apply (from 2022 II&S Section 114 Collection)
                                   Facility
            Number of Emission Units for which Work Practices Apply

                             BF Unplanned Openings
                              BF Planned Openings
                                  Bell Leaks
                            BF Casthouse Fugitives
                              BOPF Shop Fugitives
                           Beaching of Iron from BFs
                           Slag Handling and Storage
CC-BurnsHarbor-IN
                                       2
                                       2
                                       2
                                       2
                                       1
                                       2
                                       2
CC-Cleveland-OH
                                       2
                                       2
                                       1
                                       2
                                       2
                                       0
                                       2
CC-Dearborn-MI
                                       1
                                       1
                                       0
                                       1
                                       1
                                       1
                                       1
CC-IndianaHarbor-IN
                                       3
                                       3
                                       2
                                       3
                                       2
                                       3
                                       3
CC-Middletown-OH
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
                                       1
USS-Braddock-PA
                                       2
                                       2
                                       2
                                       2
                                       1
                                       2
                                       2
USS-Gary-IN
                                       4
                                       4
                                       0
                                       4
                                       2
                                       4
                                       3
USS-GraniteCity-IL
                                       2
                                       2
                                       1
                                       2
                                       1
                                       2
                                       2
Total for II&S Industry
                                      17
                                      17
                                       9
                                      17
                                      11