### Date: August 1, 2012

To: Phil Mulrine, U.S. E nvironmental Protection Agency

From: Sandra Burns, RTI International

Subject: Meeting Summary

Date and Time: Wednesday, June 13, 2012, 1:00 p.m.

– 3 :00 p.m

.

Location: EPA Offices, Research Triangle Park, NC

Purpose: Meeting requested by International Steel Services, Inc. (ISSI) to discuss the National Emission Standard for Hazardous Air Pollutants (NESHAP) for Steel Pickling, HCl Process Facilities and Hydrochloric Acid Regeneration Plants supplemental pr oposal whic h was published in the Federal R egister on February 8, 2012.

Attendees: Phil Mulrine, EPA Chuck French, EPA Sandra Burns, RTI International Franz R. Mullings, ISSI Malvin G. Sander, ISSI Edgar J. Robert, ISSI Douglas Murray, TRC Solutions

Meeting Summary: Representatives from ISSI and their consultant presented information pertaining to their hydrochloric acid (HCl) regeneration facilities in Pennsylvania and Indiana. This included a brief overview of the company, a customer reference list, an overview of the HCl regeneration process , and arguments against proposed changes to the NESHAP. The presentation

slides are included as Attachment 1.

ISSI includes the American Iron Oxide Company (AMROX) and Magnetics International, Inc. (MII). AMROX is a joint venture with ISSI and Ma rubeni Corporation, and operates three

facilities in the U.S.

- two in Indiana and one in Pennsylvania. Only one of these, AMOROX II in Portage, Indiana, is classified as a major source and is thus subject to the NESHAP. T he MII facility located in Burns Harbor, Indiana, is also a major source and subject to the rule.

These facilities take spent pickle liquor from steel p ickling operations

. Each gallon of pickle liquor contains about eight percent iron and two percent HC l

, and can be regenerated using spray

roasters to produce 1 gallon of 12 percent HCl and iron oxide, which can then be sold. ISSI

### 2

asserted that if their facilities could no longer take the spent pickle liquor, the steel plants would

shut down.

The iron oxid e produced is used in the ferrite industry, as a pigment or colorant, as well as in chemical manufacturing. Iron oxide sold to the ferrite industry is used in lighting, electronics, appliances, automotive manufacturing, and in products such as cosmetics an d pet food. The ISSI representatives noted that only two of the ISSI facilities in the U.S. and a “handful” of companies around the world can meet the specifications for soft iron oxide. Specialized technology is needed to meet the specifications needed by buyers.

The ISSI representatives also asserted that without the option of an alternative compliance method, these facilities would not be able to meet the emission limit for chlorine. ISSI has sought

an alternative limit for the AMROX II and MII faciliti es with EPA Region 5, including the

results of emissions tests at both facilities and an analysis of the results.

Both facilities that sought the alternative standard use water scrubbers. EPA pointed out that

caustic scrubbers are known to reduce chlorine emissions much more effectively than water. ISSI representatives indicated that there was a caustic scrubber on one of their facilities which is now idled, but they removed it because they did not see a consistent reduction in chlorine emissions,

and it c reated another waste stream.

EPA responses to the comments to the proposed rule submitt ed by ISSI can be found in the preamble to the final r ule.

Attachment 1: Printout of ISSI presentation: EPA Research Triangle Park, June 13, 2012

# June 13, 2012

### AMROX

#  

# Representing:

◦ International Steel Services, Inc. (ISSI)

◦ American Iron Oxide Company (AMROX)

◦ Magnetics International, Inc. (MII)

 Malvin Sander, Senior Vice President

 Edgar Roberts, Director of Special Projects

 Franz Mullings , V.P. Compliance & Business Development



# ◦ TRC

 Doug Murray, Principal Consulting Meteorologist

AMROX

# REPORT DATE

AMROX Emission Control System April 2004

Odor Study Report December 2007

Assessment of Potential Health
Risk December 2007

Alternative Concentrations
Standard for Chlorine December 2009

Addendum to the Alternative
Concentration Standard for
Chlorine June 2012

AMROX

#  

# Incorporated in 1989

 

# Successor of PEROX Company

 

# Specializes in the design, construction and operation of hydrochloric acid facilities

AMROX

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP Shougang Jingtang

– 3
China 10,000 LPH Acid Regeneration Plant and Silica
Reduction Plant With Pre

Sedimentation Plant 05/1/2013

ThyssenKrupp Steel USA, LLC
Steel Alabama, USA 15,000 LPH Acid Regeneration Plant 02/1/2013

Shougang Jingtang United Iron &
Steel Co. Ltd.
China 15,000 LPH (Twin Roaster)
ARP and Silica Reduction
Plant 11/1/2010

China Steel Corporation

Taiwan 11,000 LPH Acid Regeneration Plant
Silica Reduction Plant and Oxide Washing Plant 9/1/2010

Handan Iron & Steel Group
China Dual 8,000 LPH ARP and16,000 LPH SRP 5/1/2010

Bokaro Steel
India 8,500 LPH Acid Regeneration
Plant and Silica Reduction
Plant 3/1/2010

Shougang Jingtang United Iron & Steel Co., Ltd

., China 10,000 LPH Acid Regeneration Plant and Silica
Reduction Plant With Pre

Sedimentation Plant 12/1/2009

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP
Bokaro Steel
India 5,500 LPH Acid Regeneration Plant 9/1/2007

Novolipetsk Iron &Steel Company
RUSSIA 6,000 LPH Acid Regeneration Plant and
Silica Reduction Plant with
Presedimentation 12/1/2006

POSCO, Kwangyang

Korea 10,000 LPH Acid Regeneration Plant 12/1/2006

POSCO, Kwangyang

Korea 11,000 LPH Acid Regeneration Plant 11/1/2006

Angang
China Dechlorination units for two10,000 LPH Plants 7/1/2006

Wuhan Iron and Steel,
China 10,000 LPH Acid Regeneration Plant and
Silica Reduction Plant With
Presedimentation Plant 6/1/2006

Jinan Iron and Steel,
China 7,500 LPH Acid Regeneration Plant 5/1/2006

Seah Steel Corporation

Korea 2,800 LPH Acid Regeneration Plant 4/1/2006

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP Tangshan Iron & Steel
China 14,000 LPH Silica Reduction
Plant 1/1/2006

POSCO, Kwangyang

Korea 10,000 LPH Acid Regeneration Plant 10/1/2005

Mittal Steel Galati, Romania Design and Supply 7,000 LPH Acid Regeneration and 12,000 LPH Rinse Water
Neutralization Plants 8/1/2005

INCO of Australia New Caledonia, Australia 3 x 30000 LPH Fluidized Bed Reactor Plants to produce
Nickel Oxide 9/1/2004

MAGNITORGORSK

Russia 7000 LPH and 11000 LPH Acid Regeneration Plants 5/1/2004

SIDERAR San Nicolas, Argentina Owned and Operated by ISSI 4000 LPH Acid Regeneration
Plant with Silica Reduction System 5/01/2004

JINDAL of India, Ltd

. Calcutta, India 2200 LPH Acid Regeneration
Plant 12/1/2003

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP
INDROX Global Pvt. Ltd. Tarapur

, India Owned and Operated by INDROX (a wholly

owned subsidiary of ISSI) Design, install, own and operate 3500 LPH plant with Silica Reduction System 7/1/2003

ACERIA COMP De Biskaya Bilbao, Spain 3000 LPH Acid Regeneration
Plant 7/1/2003

TECHINT Technologies Milan, Italy 5000 LPH Acid Regeneration
Plant 7/1/2003

Eregli Iron and Steel Works
Erdemir , Turkey Design, supply, supervise and

commission 7000 LPH ARP 4/1/2003

USINOR/SOLLAC Mardyck , France Upgrade two

- stream Acid Regeneration Plant

– 5500 LPH
each Feb/Aug. 2001

Dongbu Steel Inchon, S. Korea Upgrade and increase plant capacity to 3500 LPH from 2800

LPH 8/1/2000

SIDERAR Ensenada, Argentina Owned and Operated by ISSI 4000 LPH Acid Regeneration Plant Revamping and increase production capacity 3/1/2000

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP
National Mineral Development Corporation.,
Ltd.
India 6000 ton/yr. High

- purity Iron Oxide from Blue Dust by Digestion Solvent
Extraction Purification and Spray Roaster 12/1/1999

Jenn An Steel Kaohsiung, Taiwan 6400 LPH Acid Regeneration Plant 12/1/1999

Dongbu Steel Co., Ltd

. Seoul, Korea 10,000 LPH Acid Regeneration Plant and
Silica Reduction Plant 10/1/1999

National Steel Owned and Operated by

AMROX 2 x 10,000 LPH Acid Regeneration Plant and
Silica Reduction Plant 10/1/1999

AK Steel Owned and Operated by

AMROX 2 x 10000 LPH Acid Regeneration and Silica Reduction Plant (Solvent Extraction Process) 9/1/1999

Steel Corporation of the Phillipines 2800 LPH Acid Regeneration Plant 9/1/1999

USINOR/SOLLAC

Montataire , France 5000 LPH Acid Regeneration Plant Owned and Operated by ISSI 8/1/1999

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP Hyundai Pipe Co

. Korea 11000 LPH Acid Regeneration Plant 7/1/1999

Consolidated Industries OH, USA 9000 LPH Acid Regeneration Plant, originally installed by

Perox , upgraded, managed and operated by ISSI 5/1/1999

Pohang Iron & Steel

Korea 3500 LPH Acid Regeneration Plant 8/1/1998

Thai Cold Rolled Steel Strip Co., Ltd

. Thailand 4800 LPH Acid Regeneration Plant 6/1/1997

Altos Hornos de Mexico,

S.A. 40 GPM Silica Reduction System 11/1/1995

ISSI/Marubeni for Wheeling

- Pittsburgh Steel Owned & Operated by

AMROX 40 GPM (9000 LPH) Produce High

- Purity Iron Oxide using IROX Plant 7/1/1995

Lloyds Steel Industries, Ltd

. Wardha , India 5.28 GPM (1200 LPH) Acid Regeneration Plant 5/1/1995

Liangxi Cold Rolling Mills
China 4.4 GPM (1000 LPH) Acid Regeneration Plant 12/1/1994

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP Tinplate of India, Ltd

. Jamshedpur, India 5.28 GPM (12000 LPH) Acid Regeneration Plant 11/1/1994

ISSI/Marubeni for Wheeling

- Pittsburgh Steel Design, Installation of Indirect (in tank) Heat Exchangers for Allenport
and Yorkville Pickle Lines 11/1/1994

Associated Cement Co.,
Ltd

. India 40 GPM (9100 LPH) Produce 10,000 TYP of High

- Purity Iron Oxide from Scrap Steel using the

IROX Process 10/1/1994

Altos Hornos de Mexico,

S.A. Contract for plant operations and marketing of the produced Iron Oxide 8/1/1994

Altos Hornos de Mexico, S.A.de C.V. Monclova,

Mexico 40 GPM (9100 LPH)Acid Regeneration Plant 5/1/1994

Union Steel

Korea 22 GPM (5000 LPH)Acid Regeneration Plant 9/1/1992

Magnetics International
Division of Inland Steel USA Two (2) 38 GPM, each (17,260 LPH) Acid Regeneration Plant Silica Reduction System 5/1/1991

### AMROX CUSTOMER PROJECT DESCRIPTION START

- UP Dongbu Steel

Korea 12 GPM (9000 LPH) Acid Regeneration Plant 11/1/1989

Republic Steel OH, USA 39.6 GPM (9000 LPH) Acid Regeneration Plant 5/1/1981

China Steel Kaohsiung, Taiwan 26.4 GPM (6000 LPH) Acid Regeneration Plant 12/1/1980

Sharon Steel PA, USA 21.1 GPM (4800 LPH) Acid Regeneration Plant 10/1/1980

U.S. Steel Al, USA 26.4 GPM (6000 LPH) Acid Regeneration Plant 12/1/1979

Mitchell Steel TN, USA 6.6 GPM (1500 LPH) Acid Regeneration Plant 9/1/1978

POSCO Pohang, S. Korea 4 GPM (900 LPH) Acid Regeneration Plant 10/1/1976

Armco Steel Kentucky, USA 37.4 GPM (8500 LPH) Acid Regeneration Plant 6/1/1971

Steel Co. of Canada Ontario, Canada 34.1 GPM (7750 LPH) Acid Regeneration Plant 8/1/1970

#  

# 50/50 joint venture partnership with ISSI & Marubeni Corporation

 

# Operates three (3) facilities in North America

◦ Indiana

– 2

◦ Pennsylvania

- 1

AMROX

## MARUBENI 100% Ownership

50% Ownership

Amrox I

(1)

Allenport, PA Amrox II

(2)

Portage, IN

Amrox III

(2)

Rockport, IN 

# AMROX ISSI OPERATIONS & OXIDE 

# ISSI

India (INDROX) (2)

a. Tarapur

b. Bokaro MII

(2)

Burns Harbor, IN WCI

(1)

Warren, OH

Mexico

(AHMSA)

(1) Argentina (SAMROX) (2)

a. Ensenada
b. San Nicolas

France

(1)

Montaiaire



### AMROXFACILITY AMROX I AMROX II AMROX III MII WCI TOTALS

LOCATION Allenport, PA Portage, IN Rockport, IN Burns Harbor, IN Warren, OH

DESIGN
CAPACITY liters/hour & (GPM) 10,000 LPH (44 GPM) 24,000 LPH (105 GPM) 20,000 LPH (88 GPM) 18,000 LPH (80 GPM) 7,000 LPH (30 GPM) 80,000 LPH (350 GPM)

PLANT
DESCRIPTION Single (1) roaster plus IROX/NKK purification plant Dual (2) 12,000 liter/hour

roasters Dual (2)

- 10,000 liter/hour roasters
with solvent

extraction purification process for UHP Dual (2) 9,000 liter
roasters with soft oxide (batch) purification process Single (1 ) 7000

LPH roaster 8 ROASTERS

At 5 Locations in
the

PLANT OXIDE
PRODUCTION
CAPACITY (MT )

CURRENT PROD. 14,000 MT/yr

.

1,200 MT/month 32,000 MT/yr

.

2,500 MT/month 28,000 MT/yr. (1 roaster offline )

1,200 MT/month 24,000 MT/yr. (1 roaster offline )

1,100 MT/month 10,000 MT/yr

.

500 MT/month 108,000 MT/yr

= 9,000/mo.

6,500 MT / mo

.

GRADES
PRODUCED *G

- 300 & 300M
G

- 500 & 500M
*G

- 100 & G

- 150 G

- 300
*G

- 500
G

- 700
G

- 1000 *G

- 98
*G

- 97

G

- 96

AM

- UHP (TBD) G300 & 300M
*G

- 500 & 500M
G

- 700, G

- 150,
*G

- 100,

- HP *G

- 700 BULK

SOFT OXIDE
PRODUCTION 3,600 MT/year

= 300 MT/mo

.

Re

- start 5,000 MT

= 400 MT/mo.

Start

- up

TBD 3,600 MT

= 300 MT/mo. 12,000 MT/yr.

1,000 MT /month



### AMROX

# FeCl 2 

# HCl

Iron Oxide 

# PROCESS

AMROX

#  

# Steel Finishing

AMROX

#  

# Steel Finishing Operations Support

Pennsylvania

- 6 Indiana

- 20

AMROX

#  

# Ferrite Industry

◦ Soft Ferrite

◦ Hard Ferrite

 

# Pigment/Colorant

 

# Chemical Manufacturing

AMROX

### AMROX G1000 G700 G500 G300

TYPICAL SPEC TYPICAL SPEC TYPICAL SPEC TYPICAL SPEC

Cl

- wt. % 0.20 ≤0.30 0.15 ≤0.20 0.12 ≤0.15 0.10 ≤0.15

SiO 2 wt.% 0.10 ≤0.12 0.07 ≤0.08 0.05 ≤0.06 0.03 ≤0.04

CaO wt.% 0.06 ≤0.12 0.05 ≤0.08 0.05 ≤0.06 0.03 ≤0.04

Na 2 O wt.% 0.03 ≤0.05 0.02 ≤0.04 0.02 ≤0.03 0.015 ≤0.02

Al 2 O 3 wt.% 0.10 ≤0.16 0.09 ≤0.14 0.08 ≤0.12 0.07 ≤0.10

MnO wt.% 0.40 0.40 0.40 0.40

P 2 O 5 wt.% 0.05 0.05 0.05 0.05

TiO 2 wt.% 0.02 0.02 0.02 0.02

Cr 2 O 3 wt.% 0.05 0.05 0.05 0.05

K 2 O wt.% 0.00 0.00 0.00 0.00

CuO wt.% 0.01 0.01 0.01 0.01

* Fe 2 O 3 wt.% 99.0 ≥98.5 99.0 ≥98.8 99.2 ≥99.0 99.4 ≥99.2

Fe 3 O 4 wt.% 0.0 0.0 0.0 0.0

Particle Size

Microns 0.75 .50

- 1.0 0.75 .50

- 1.0 0.75 .50

- 1.0 0.75 .50

- 1.0

Surface Area

m 2 /g 3.5 ≥2.5 3.5 ≥2.75 3.75 ≥3.0 3.50 ≥3.0

Loss of Moisture

wt. % 0.3 ≤0.5 0.3 ≤0.5 0.3 ≤0.5 0.3 ≤0.5

Bulk Density gm/cm3 0.45

. 40

– .60 0.45 .40

- .60 0.45 .40

- .60 0.45 .40

- .60

### AMROX G

- HP G

- 100 G

- 150

TYPICAL SPEC TYPICAL SPEC TYPICAL SPEC

Cl

- wt. % 0.10 ≤0.125 0.12 ≤0.15 0.14 ≤0.175

SiO 2 wt. % 0.006 ≤0.008 0.010 ≤0.012 0.014 ≤0.018

CaO wt. % 0.015 ≤0.020 0.020 ≤0.025 0.025 ≤0.030

Na 2 O wt. % 0.006 ≤0.010 0.010 ≤0.015 0.010 ≤0.020

Al 2 O 3 wt. % 0.007 ≤0.015 0.010 ≤0.020 0.015 ≤0.030

Fe 2 O 3 wt. % 99.5 ≥99.4 99.4 ≥99.3 99.3 ≥99.2

MnO wt. % 0.300 0.300 0.300

NiO wt. % 0.002 0.002 0.002

P 2 O 5 wt. % <0.001 <0.001 <0.001

TiO 2 wt. % 0.001 0.001 0.001

Cr 2 O 3 wt. % 0.001 0.002 0.003

K 2 O wt. % 0.002 0.003 0.004

CuO wt. % <0.001 0.001 0.002

Fe 3 O 4 wt. % 0.20 0.30 0.40

Particle Size μ 0.85 0.70

- 1.0 0.85 0.70

- 1.0 0.85 0.70

- 1.0

Surface Area

m

2 /g 3.25 ≥2.50 3.25 ≥2.50 3.25 ≥2.50

Loss of Moisture % 0.3 ≤0.5 0.3 ≤0.5 0.3 ≤0.5 Bulk Density g/cm3 0.45 .40

- .50 0.45 .40

- .50 0.45

. 40

- . 50

# 4FeCl 2 

# + 4H 2 

# O + O 2 

# = 2Fe 2 

# O 3 

# + 8HCl

AMROX

### AMROX

#  

# National Emission Standards for Hazardous Air
Pollutant Emissions:

Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks; and Steel Pickling

- HCl Process Facilities and Hydrochloric Acid Regeneration
Plants

AMROX

#  

# II Background Information, Section D:

This action supplements our proposed amendments to National Emission Standards for Hazardous Air Pollutant Emissions for Hard and Decorative Chromium Electroplating and Chromium Anodizing Tanks; and Steel Pickling

- HCl Process Facilities and Hydrochloric Acid Regeneration Plants, which were published on October 21, 2010 (75 FR 65068, October 21, 2010). In that action, EPA proposed amendments to these NESHAP under section 112(d)(6) and (f)(2) of the Clean Air Act. Specifically, this action presents a new technology review and a new residual risk analysis for chromium electroplating and anodizing facilities and proposes revisions to the NESHAP based on those reviews. This action also proposes to remove an alternative compliance method for Steel Pickling hydrochloric acid regeneration plants. Finally, this action proposes to incorporate electronic reporting requirements into both NESHAP.

AMROX

##  

# Section V. What action are we proposing for the steel pickling source category?

A. Elimination of an Alternative Compliance Option

“...Upon review of this provision, we believe that it does not meet the requirements in section 112(d)(2) and (3) of the CAA. MACT standards for existing sources cannot be less stringent than the average emissions limitation achieved by the best

- performing 12 percent of existing sources in the category or subcategory (or the best

- performing five sources for categories or subcategories with fewer than 30 sources). This is referred to as the ‘‘MACT floor.’’ “

“...We do not have authority to allow a source to seek an alternative standard if such a source is unable to meet a standard which reflects the MACT floor level of control.”

“In addition to fulfilling the statutory requirements of Sections 112(d)(2) and (3), we note that this proposed action also will reduce the emissions of chlorine and HCl from this source category, resulting in a reduction of the Hazard Index (HI) from 2 due

to HCl (that was presented in the October 21, 2010 proposal) to an HI of less than one. The one facility that posed the HI of 2 (in the October 21, 2010 proposal) will need to improve controls and reduce emissions by more than a factor of 2 to comply with this proposed action.”

AMROX

#  

# VII. Summary of Cost, Environmental, and Economic Impacts

A. What are the affected sources?

For the proposed amendments to the Steel Pickling NESHAP, the affected sources are hydrochloric acid regeneration plants that are major sources of HAPs.

AMROX

#  

# VII. Summary of Cost, Environmental, and Economic Impacts

B. What are the emission reductions?

We estimate that the proposed amendment to remove the alternative compliance provision for hydrochloric acid regeneration facilities would reduce emissions of chlorine by 15 tpy

.

AMROX

#  

# VII. Summary of Cost, Environmental, and Economic Impacts

C. What are the cost impacts?

For HCl acid regeneration plants, we estimate that the capital cost for the proposed amendments would be between $100,000 and $200,000, depending on whether the existing equipment can be upgraded or will need to be replaced. The annualized cost are estimated to be between $11,419 and $22,837 per year. The estimated cost effectiveness would be $761 to $1,522 per ton of HAP (mainly chlorine and HCl ).

AMROX

#  

# VII. Summary of Cost, Environmental, and Economic Impacts

D. What are the economic impacts?

Because only one of the approximately 100 facilities incurs any cost for controls and that cost is estimated to be less than 1 percent of sales, no significant price or productivity impacts are anticipated.

AMROX

#  

# VII. Summary of Cost, Environmental, and Economic Impacts

E. What are the benefits?

The estimated reductions in hydrogen chloride and
chlorine emissions that will result from this proposed action will provide benefits to public health. The proposed limits will result in reductions in the potential for non

- cancer health
effects due to emissions of these HAPs.

AMROX

###  

# AMROX opposes and requests modification to EPA's proposal to "remove an alternative compliance method for Steel Pickling hydrochloric acid regeneration plants" as described in 40 CFR 63.1157(b)(2).

 

# The proposed revision will eliminate a necessary regulatory mechanism for addressing the nonexistence of improved control technology that enhances current controls for Chlorine emissions.

 

# At the time the current regulation was promulgated, EPA found that the "alternative concentration standard" provision complied with the Clean Air Act

 

# EPA's proposal to remove the "alternative concentration standard" provision will deny HCl facilities the ability to produce marketable iron oxide should operational factors result in emissions above 6 ppmv

.

AMROX

##  

# NESHAP regulation, 40 CFR 63.1157(b)(2), provides as follows:

 

# In addition to the requirement of paragraph (b)( I) of this section, no owner or operator of an existing affected plant shall cause or allow to be discharged into the atmosphere from the affected plant any gases that contain chlorine in a concentration in excess of either 6ppmv or an alternative source

- specific maximum concentration

. The source specific maximum concentration standard shall be established according to Sec. 63.11161(c)(2) of this subpart.

 

# The alternative concentration standard shall be established through performance testing while the plant is operated at maximum design temperature and with the minimum proportion of excess air that allows production of iron oxide of acceptable quality while measuring the chlorine concentration in the process exhaust gas. The measured concentration shall be the concentration standard for that plant.

AMROX

#  

# Began in early 2000’s when EPA Region V suggested TRC as an independent engineering firm to evaluate AMROX’s spray roasters and control technology and provide recommendation to meet NESHAP compliance regulations

 

# Beginning in 2004, TRC prepared engineering, odor impact, risk and air quality
assessments relative to Cl 2 

# emissions

 

# All of the reports have been submitted to EPA

TRC

#  

# TRC reviewed the emissions control systems
at AMROX facilities

 

# Consist of an absorber followed by two packed bed scrubbers

 

# Concluded that this is an appropriate engineering approach for MACT compliance

TRC

##  

# Residents approximately 0.6 miles from the Portage industrial complex with AMROX and several other industrial companies complained about potential odor impacts

 

# Indiana Department of Environmental Management investigated but could not identify any responsible sources

 

# As a supplemental environmental project, AMROX volunteered to conduct an independent odor survey/assessment of their emissions

 

# TRC conducted in situ odor surveys in the residential and industrial areas, sampled and characterizes the odor strength of AMROX’s emissions and performed odor dispersion modeling

 

# Concluded that emissions were not found or predicted to cause or contribute to odor impacts in the residential community

TRC

#  

# Conducted screening

- level and refined health risk assessment of emissions of HCl and Cl 2



#  

# Neither HCl or Cl 2 

# are carcinogens, but exposure to high airborne concentrations may result in nose, eye and throat irritation

 

# Stack test data were used to establish maximum measured emission rates

 

# Conservative (SCAQMD screening methods and refined “Tier 3” TSCREEN modeling) were used to calculate potential exposures

 

# Predicted Hazard Quotient levels are below EPA’s target HQ of 0.25 for all scenarios: commercial/industrial workers, adult and child residents, even at the point of maximum predicted impact

TRC

#  

# Committed AMROX/MII to a program of source sampling with extensive coincident operating data collection

 

# All tests conducted while producing marketable iron oxide

 

# Sought input from EPA and IDEM on the approach

 

# Periodic analyses are conducted and shared with EPA and IDEM

 

# Objective is identify operating variables that influence stack concentrations of Cl 2 

# and establish alternative emission limits for each facility

TRC

#  

# EPA Relied on:

D. Th. Herpers , B. Scheinsburg , N. Ozer and J. Bozcar , "Chlorine Control of Pickling and Regeneration Plants" (I. Chem. E. Symposium Series No. 57, 1979).

Herpers et al. concluded that the equilibrium constant should be as high as possible in order to minimize Cl 2 

# emissions and that the minimization of Cl 2 

# emissions is possible only through the use of high reaction temperatures. "Owing to operation at high temperature and with a small amount of excess oxygen, the aforesaid secondary reaction towards the formation of chlorine is largely suppressed", Harpers et.al. This apparently led EPA to conclude that Cl 2 

# could be minimized through the use of operational controls, namely high temperatures and low excess oxygen, though Herpers et al. did not evaluate the quality of the product that would result from maximizing temperature to determine whether such an operational parameter would still produce marketable product.

TRC

##  

# Review of “Chlorine Control of Pickling and Acid Regeneration Plants” (E. Herpers , et al.), basis of recommendation for high operating temperatures and low O 2 

# process concentration

 

# Based on theoretical chemical kinetics model of the

process

 

# Herpers example theoretical plant operation temperature 1,112 ° F, while maximum operating temperature at AMROX plant is 840 ° F to prevent damaging the roasters

 

# Herpers recommends low O 2 

# and AMROX/MRI operate with O 2 

# /fuel ratios near stoichiometric

 

# Concluded that, based on stack sampling results and operating limitations (roaster temperature) that facilities “are unable to consistently meet the NESHAP Cl 2 

# emission standard of 6 ppmv ”

TRC

#  

# Summarize source test and plant operating data to date for 5 facilities (MII, Allenport, Portage, Rockport, Regen )

 

# Operating parameters considered:

Roaster Burner Temp Scrub 1 Pump Pressure

Roaster Top Temp Scrub 1 Header Pressure

Roaster Nozzle Size

Ro aster No. of Nozzles Scrub 1 % HCl

Ro aster CPL Flo w Scrub 1 Δ P Demister

Ro aster CPL % FeCl 2 Scrub 1 P-16

Roaster CPL Pump Pressure Scrub 2 Flow

Roaster Air/ Gas Ratio air volume/ gas volume Scrub 2 Pump Pressure

Roaster Oxide % Cl Scrub 2 Header Pressure

WPL Sep Temp Scrub 2 Δ P
WPL Venturi Spray Pressure Scrub 2 %HCl

WPL Flo w Scrub 2 Δ P Demister

WPL % FeCl 2 Scrub 3 Exhaust Temp

WPL % HCl Scrub 3 Δ P Demister

Absorb Temp Scrub 3 Flow

Absorber Δ P

Abso rber RA % HCl Stack Temp, F

Absorber Flow Stack Flow Rate (dry scfm)

Scrub 1 Flow HCl Emission Rate (ppm)

Cl 2 Emission Rate (ppm) Parameter Parameter

Moist % Scrub 1 Δ P Units Units

degrees Fahrenheit pounds per square inch

degrees Fahrenheit pounds per square inch

X 0.001 inches inches water column

no. of nozzles in-service percent
gallons per minute inches water column

percent gallons per minute

pounds per square inch gallons per minute

pounds per square inch

pounds per square inch

degrees Fahrenheit inches water column

pounds per square inch percent
gallons per minute inches water column

degrees Fahrenheit

inches water column

degrees Fahrenheit gallons per minute

inches water column percent H 2 0

ppmv percent

percent percent

percent degrees Fahrenheit

gallons per minute scfm

gallons per minute ppmv



### TRC

#  

# Cl 2 

# stack concentrations were correlated against each operating parameter. No
reliable correlations were identified.

TRCRoaster Top Temperature (Fahrenheit)

MII

MII MII

MII MII MII MII MII MII

MII

Allen Allen

Allen Port Port Port Port Port Port Port Port Port

Port Port Port Port Port Port

Port Rock Rock Rock

Rock

Rock

Rock

Rock Rock Rock Regen

Regen Regen

640 660 680 700 720 740 760 780 800 820 840

RoasterTopTemp -10

0 10 20 30 40 50 60Cl2 Emission Concentration (ppm)

RoasterTopTemp:Cl2 Emission Concentration (ppm): r = -0.2412, p = 0.1239



### TRC

### Roaster Air/Gas Ratio (vol/vol)

MII

MII MII

MII

MII MII MII

MII MII MII

Allen Allen Allen Port Port Port Port Port Port Port Port Port

Port Port Port Port Port Port Rock Rock Rock Rock

Rock

Rock

Rock Rock Rock Rock Regen

Regen Regen

10.6 10.8 11.0 11.2 11.4 11.6 11.8 12.0 12.2 12.4 12.6 12.8 13.0 13.2

RoasterAir/Gas Ratio -10

0 10 20 30 40 50 60Cl2 Emission Concentration (ppm)



### RoasterAir/Gas Ratio:Cl2 Emission Concentration (ppm): r = -0.0017, p = 0.9915



### TRC

#  

# Cl 2 

# emissions are highly variable and not dependent on operating conditions

◦ Cl 2 

# is not efficiently removed by scrubbers (very low solubility) that are designed to control HCl emission

◦ Feed stocks of spent pickle liquor are inconsistent, not controllable by the plants and the effects of variable feed stocks is not understood

◦ The demands of clients for iron oxide quality/particle size change, and in order to produce saleable product, the process must be changed accordingly

◦ Cl 2 

# stack emissions often exceed 6 ppmv

 

# Facility emissions are non

- carcinogenic and do not present a health risk to workers or nearby residents, even at maximum recorded stack concentrations

TRC

##  

# Relied on test data from 3 units (2 at MII and 1 at Bailey Engineers, Inc.)

 

# EPA eliminated a result from WCI Steel at 60 ppmv calling it not representative of effective control and a 9.9 ppmv result from MII call it not representative of current operations

◦ In retrospect, it may have been representative of variability inherent in these units

 

# Commenters noted that limit should be based on 5 units

 

# To encompass inherent variability, the maximum concentration data from the available tests could have been used

◦ This would have resulted in an average maximum of 22 ppmv for the four units available at the time with an absolute maximum of 64 ppmv

 

# NESHAP set at 6 ppmv , despite higher concentrations in the limited data set

TRC

#  

# Test data from AMROX and MII facilities

 

# Using 2001

- 2010, the average maximum test
result from all facilities is 21 ppmv

 

# The absolute maximum test result is 60 ppmv

 

# These results will be updated after the upcoming round of emissions tests this

summer

TRCPlant Roaster Date HCl

Emission

Rate (ppmv) Cl 2 Emission

Rate ( ppmv )

Magnetics International, Inc. A 11/12/10 14.04 26.41

Magnetics International, Inc. A 11/12/10 13.47 30.10

Magnetics International, Inc. A 11/12/10 8.87 29.26

Magnetics International, Inc. A 04/30/08 8.21 8.60

Magnetics International, Inc. A 04/30/08 9.07 6.71

Magnetics International, Inc. A 04/30/08 10.16 6.33

Magnetics International, Inc. A 10/26/06 8.24 33.40

Magnetics International, Inc. A 10/26/06 13.47 30.47

Magnetics International, Inc. A 10/26/06 8.87 36.09

Magnetics International, Inc. B 12/20/02 27.00 38.00

Magnetics International, Inc. B 12/20/02 91.00 38.00

Magnetics International, Inc. B 12/20/02 43.00 38.00

AMROX 1

- Allenport A 05/26/05 8.58 3.52

AMROX 1

- Allenport A 05/26/05 7.55 1.13

AMROX 1

- Allenport A 05/26/05 7.26 0.43

AMROX 1

- Allenport A 02/20/03 92.00 27.00

AMROX 1

- Allenport A 02/20/03 55.00 34.00

AMROX 1

- Allenport A 02/20/03 42.00 32.00

AMROX 1

- Allenport A 01/29/03 48.00 6.00

AMROX 1

- Allenport A 01/29/03 42.00 7.00

AMROX 1

- Allenport A 01/29/03 27.00 2.00

AMROX 2

- Portage B 09/20/07 10.50 8.68

AMROX 2

- Portage B 09/20/07 4.09 7.55

AMROX 2

- Portage B 11/03/05 7.42 3.81

AMROX 2

- Portage B 11/03/05 8.94 5.79

AMROX 2

- Portage B 11/03/05 7.07 4.31

AMROX 2

- Portage B 02/04/02 13.60 17.80

AMROX 2

- Portage B 02/04/02 10.30 19.09

AMROX 2

- Portage B 02/04/02 12.70 23.26

AMROX 2

- Portage B 10/07/01 44.90 0.00

AMROX 2

- Portage B 10/17/01 36.80 0.00

AMROX 2

- Portage B 10/17/01 44.50 0.00

AMROX 3

- Rockport A 11/01/07 19.02 55.85

AMROX 3

- Rockport A 11/01/07 23.60 44.96

AMROX 3

- Rockport A 11/01/07 13.49 17.50

AMROX 3

- Rockport A 04/10/10 9.00 37.80

AMROX 3

- Rockport A 04/10/10 15.80 59.90

AMROX 3

- Rockport A 04/10/10 14.60 47.10

AMROX

- Regen A 08/09/07 68.47 19.87

AMROX

- Regen A 08/09/07 69.83 11.86 

### TRC

#  

# 2010 EPA Risk Assessment

Facility ID Facility Name City State Year Pollutant Total

TPY

SPG_NEIRAL730437 BAILEY

- PVS OXIDES L.L.C. FAIRFIELD AL 2002 Chlorine 0.924

NEI52751 ISG HENNEPIN INC HENNEPIN IL 2005 Chlorine 0.375

SPG_NEI42439 ISG WEIRTON INC. WEIRTON WV 2005 Chlorine 0.835

SPG_NEIIN127192 MAGNETICS INTERNATIONAL,
INC. BURNS
HARBOR IN 2006 Chlorine 15.330

SPG_NEI1120 NUCOR STEEL ARKANSAS BLYTHEVILLE AR 2005 Chlorine 0.053

SPG_NEIPA2156 US STEEL CORPORATION

- IRVIN PLANT DRAVOSBURG PA 2002 Chlorine 0.283



### AMROX

#  

# 2010 EPA Risk Assessment

Gray: Not in operation Teal: Steel Finishing Operation

- no Acid Regeneration



### AMROX Facility ID Facility Name City State Year Pollutant Total

TPY

SPG_NEIRAL730437 BAILEY

- PVS OXIDES L.L.C. FAIRFIELD AL 2002 Chlorine 0.924

NEI52751 ISG HENNEPIN INC HENNEPIN IL 2005 Chlorine 0.375

SPG_NEI42439 ISG WEIRTON INC. WEIRTON WV 2005 Chlorine 0.835

SPG_NEIIN127192 MAGNETICS INTERNATIONAL,

INC. BURNS HARBOR IN 2006 Chlorine 15.330

SPG_NEI1120 NUCOR STEEL ARKANSAS BLYTHEVILLE AR 2005 Chlorine 0.053

SPG_NEIPA2156 US STEEL CORPORATION

- IRVIN PLANT DRAVOSBURG PA 2002 Chlorine 0.283

#  

# EPA Concluded:

Pursuant to section 112(f)(2) of the CAA, we evaluated the residual risk associated with the NESHAP in 2010. We also conducted a technology review, as required by section 112(d)(6) of the CAA. Based on the results of our residual risk assessment, we proposed on October 21, 2010 that the risks were acceptable and that there were no additional cost effective controls to reduce risk further and that the NESHAP provides an ample margin of safety to protect public health and prevented an adverse environmental effect. In that notice, we also proposed no changes based on the technology review because we did not identify any new, feasible technologies that warranted changes to the NESHAP. We are not taking comment on these proposed determinations.

AMROX

##  

# EPA's 2010 assessment concluded that there is no new technology to provide further control of Cl 2 

# emissions beyond those technologies already employed in the industry.

 

# AMROX confirms that, in its experience in the industry worldwide, no such technologies have emerged and existing facilities must continue to utilize existing controls.

Therefore:

The alternative concentration standards remains critical for those facilities that find it necessary to utilize that provision or will require it in the future; they cannot simply add new or additional control technologies because no such technologies exist.

AMROX

#  

# EPA's discussion of its basis for removing the "alternative concentration standard" provision, EPA asserts that the provision "does not meet the requirements in section 112(d)(2) and (3) of the CAA [because] MACT standards for existing sources cannot be less stringent than the average emissions limitation achieved by the best performing 12 percent of existing sources in the category or subcategory (or the best

- performing five sources for categories or subcategories with fewer than 30 sources)."

 

# EPA further states that, "We do not have authority to allow a source to seek an alternative standard if such a source is unable to meet a standard which reflects the MACT floor level of control.

AMROX

#  

# However, EPA previously promulgated a regulation which set the Cl 2 

# NESHAP at 6

ppmv or an "alternative concentration standard".

 

# The regulatory mechanism of the "alternative concentration standard" is not, in and of itself, a violation of the MACT floor for a given regulated pollutant or Clean Air Act sections 112(d)(2) or (3).

AMROX

#  

# The Cl 2 

# NESHAP was established based on single stage scrubber technology.

 

# The limit for new or reconditioned sources in the 1999 published final rule was based on the assumption that in the future technological advancements in control technology would be developed.

AMROX

#  

# A numerical standard for Cl 2 

# could be determined based on the body of data available for that technology so long as there was also the option to set alternative source

specific limits in order to ensure that facilities could actually produce marketable products.

 

# The limit for new and reconditioned facilities should have been the same as the limit for existing facilities, 6 ppmv or an alternate limit based on product quality considerations.

AMROX

#  

# It does not appear from EPA's proposed revision or the documentation in support of the revision that EPA considered any new data from existing sources or did any new
calculations.

AMROX

#  

# 42 U.S.C.A. § 7412(3) provides, in relevant part, that, "Emission standards promulgated under this subsection for existing sources ... may be less stringent than standards for new sources in the same category or subcategory but shall not be less stringent, and may be more stringent than ... (B) the average emission limitation achieved by the best performing 5 sources (for which the Administrator has or could reasonably obtain emissions information) in the category or subcategory for categories or subcategories with fewer than 30 sources."

AMROX

#  

# EPA can lawfully set an "alternative concentration standard" in excess of 6 ppmv because, using the MACT floor calculation method described in EPA guidance, one may calculate a MACT floor in excess of 6 ppmv

. In addition, EPA has the authority under the Clean Air Act to account for variability in emissions data or operational factors in setting such standards. Cement Kiln Recycling Coalition v. EPA, 255 F.3d 855 (D.C. Cir. 2001).

AMROX

##  

# AMROX notes that the maximum achievable control technology utilized by the facilities EPA looked to in setting the current NESHAP is based on one single scrubber. The NESHAP limit is thus based on emissions from facilities with the control technology of a single scrubber.

 

# In addition, EPA's proposed revision does not consider the fact that removing the alternative concentration standard provision will affect those facilities that are presently requesting or have received alternative concentration standards.

 

# EPA's conclusion that the proposed removal of the "alternative concentration standard" provision will have a capital cost in the range of $100,000 to $200,000, "depending on whether the existing equipment can be upgraded or will need to be replaced"

AMROX

#  

# There is no control technology available that is more effective in removing Cl 2 

# than existing technology already used by HCl regeneration facilities.

 

# EPA can and should keep the “alternative concentration standard” provision in 40 CFR 63.1157(b)(2) because it will not result in the
authorization of emissions standards for a particular facility in excess of the MACT floor.

AMROX

###  

# AMROX requests that EPA maintain the ability of existing facilities to seek a

source

- specific maximum concentration for Cl 2 

# based on performance testing while the plant is operated at maximum design temperature and with the minimum proportion of excess air that allows production of iron oxide of acceptable quality as provided for in the 1999 NESHAP CCC final rule based on the following reasons:

1. 

# It was lawful to establish the 1999 NESHAP of 6 ppmv or an alternative concentration standard.

2. 

# Since the publication of the NESHAP CCC, no additional Cl 2 

# control technology has been developed.

3. 

# HCl regeneration facilities control operational variables, including temperature and excess air, to produce saleable iron oxide, and those variables continue to change as market specifications for iron oxide evolve.

4. 

# EPA's proposed revision does not address how existing facilities that are currently seeking an alternate concentration standard for Cl 2 

# or that will need to do so in the future will continue to be able to produce saleable iron oxide.

AMROX