Date: August 1, 2012

To: Phil Mulrine, U.S. Environmental 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 proposal which was 

published in the Federal Register 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 Marubeni 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. The 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 pickling operations. Each gallon of pickle 

liquor contains about eight percent iron and two percent HCl, 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 oxide 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 and 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 facilities 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 created another waste stream.

EPA responses to the comments to the proposed rule submitted by ISSI can be found in the 

preamble to the final rule. 

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 PreSedimentation 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 PreSedimentation 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 whollyowned 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

AMROX 
FACILITY 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 
FeCl2 

HCl 

Iron Oxide 

PROCESS 

AMROX 
 Steel Finishing

AMROX 
 Steel Finishing Operations Support

Indiana - 20 Pennsylvania - 6

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

SiO2 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

Na2O wt.% 0.03 ≤0.05 0.02 ≤0.04 0.02 ≤0.03 0.015 ≤0.02

Al2O3 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

P2O5 wt.% 0.05 0.05 0.05 0.05

TiO2 wt.% 0.02 0.02 0.02 0.02

Cr2O3 wt.% 0.05 0.05 0.05 0.05

K2O wt.% 0.00 0.00 0.00 0.00

CuO wt.% 0.01 0.01 0.01 0.01

* Fe2O3 wt.% 99.0 ≥98.5 99.0 ≥98.8 99.2 ≥99.0 99.4 ≥99.2

Fe3O4 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 

m2/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

SiO2 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

Na2O wt. % 0.006 ≤0.010 0.010 ≤0.015 0.010 ≤0.020

Al2O3 wt. % 0.007 ≤0.015 0.010 ≤0.020 0.015 ≤0.030

Fe2O3 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

P2O5 wt. % <0.001 <0.001 <0.001

TiO2 wt. % 0.001 0.001 0.001

Cr2O3 wt. % 0.001 0.002 0.003

K2O wt. % 0.002 0.003 0.004

CuO wt. % <0.001 0.001 0.002

Fe3O4 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 

m2/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
4FeCl2 + 4H2O + O2 = 2Fe2O3 + 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 Cl2 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 Cl2

 Neither HCl or Cl2 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 Cl2 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 Cl2 emissions and that the minimization 

of Cl2 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 Cl2 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 

O2 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 O2 and AMROX/MRI operate with 

O2/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 Cl2 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 ΔP Demister

Ro aster CPL % FeCl2 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 ΔP

WPL Venturi Spray Pressure Scrub 2 %HCl

WPL Flo w Scrub 2 ΔP Demister

WPL % FeCl2 Scrub 3 Exhaust Temp

WPL % HCl Scrub 3 ΔP Demister

Absorb Temp Scrub 3 Flow

Absorber ΔP

Abso rber RA % HCl Stack Temp, F

Absorber Flow Stack Flow Rate (dry scfm)

Scrub 1 Flow HCl Emission Rate (ppm)

Cl2 Emission Rate (ppm)

Parameter Parameter

Moist %

Scrub 1 ΔP

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 H20

ppmv

percent

percent

percent

percent degrees Fahrenheit

gallons per minute scfm

gallons per minute ppmv

TRC 
 Cl2 stack concentrations were correlated 

against each operating parameter. No 

reliable correlations were identified.

TRC 
Roaster Top Temperature (Fahrenheit)

MII

MII

MII

MII

MII MII

MII

MII MII

MII

Allen

Port PortPort AllenAllen

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

60

Cl2 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

MIIMII

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

60

Cl2 Emission Concentration (ppm)

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

TRC 
 Cl2 emissions are highly variable and not dependent on operating conditions

◦ Cl2 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

◦ Cl2 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

TRC 
Plant Roaster Date

HCl

Emission

Rate

(ppmv)

Cl2

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 - AllenportA 05/26/05 8.58 3.52

AMROX 1 - AllenportA 05/26/05 7.55 1.13

AMROX 1 - AllenportA 05/26/05 7.26 0.43

AMROX 1 - AllenportA 02/20/03 92.00 27.00

AMROX 1 - AllenportA 02/20/03 55.00 34.00

AMROX 1 - AllenportA 02/20/03 42.00 32.00

AMROX 1 - AllenportA 01/29/03 48.00 6.00

AMROX 1 - AllenportA 01/29/03 42.00 7.00

AMROX 1 - AllenportA 01/29/03 27.00 2.00

AMROX 2 - PortageB 09/20/07 10.50 8.68

AMROX 2 - PortageB 09/20/07 4.09 7.55

AMROX 2 - PortageB 11/03/05 7.42 3.81

AMROX 2 - PortageB 11/03/05 8.94 5.79

AMROX 2 - PortageB 11/03/05 7.07 4.31

AMROX 2 - PortageB 02/04/02 13.60 17.80

AMROX 2 - PortageB 02/04/02 10.30 19.09

AMROX 2 - PortageB 02/04/02 12.70 23.26

AMROX 2 - PortageB 10/07/01 44.90 0.00

AMROX 2 - PortageB 10/17/01 36.80 0.00

AMROX 2 - PortageB 10/17/01 44.50 0.00

AMROX 3 - RockportA 11/01/07 19.02 55.85

AMROX 3 - RockportA 11/01/07 23.60 44.96

AMROX 3 - RockportA 11/01/07 13.49 17.50

AMROX 3 - RockportA 04/10/10 9.00 37.80

AMROX 3 - RockportA 04/10/10 15.80 59.90

AMROX 3 - RockportA 04/10/10 14.60 47.10

AMROX - RegenA 08/09/07 68.47 19.87

AMROX - RegenA 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 Cl2 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 Cl2 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 Cl2 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 Cl2 could be 

determined based on the body of data 

available for that technology so long as there 

was also the option to set alternative sourcespecific 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 Cl2 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 Cl2 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 Cl2 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 Cl2 or that will need 

to do so in the future will continue to be able to produce saleable iron oxide.

AMROX