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UNITED STATES ENVIRONMENTAL PROTECTION AGENCV

REGION 5

77 WEST JACKSON BOUlEVARD

CHICAGO, IL 60604-3590

APR 3 G1999 REPLV TO THE ATTENTION OF

AR-18J

Paul Dubenetzky

Permit Branch

Office of Air Management

Indiana Department of Environmental Management

100 North Senate Avenue

P.O. Box 6015

Indianapolis, Indiana 46206-6015

Dear Mr. Dubenetzky:

This letter will outline and clarify the United States

Environmental Protection Agency's (USEPA) comments with regard to

the Prevention of Significant Deterioration (PSD) permit for the

proposed Steel Dynamics (SOl) steel facility (CP-183-10097) in

Whitley County Indiana. The USEPA believes that this permit does

not comply with the requirements of the Federal PSD regulations

(40 CFR 52.21). The comments to this permit are as follows.

Reheat Furnace Nitrogen oxide (NQx) Best Ayailable Control

Technology (BACT) Analysis:

The USEPA believes that the proposed SOl 373 MMBtu/hr Reheat

Furnace should install a Selective Catalytic Reduction (SCR) unit

as BACT for Nox. SDI'~ BACT an~lysis, however, contends that

since Beta Steel in Portage Indiana is having certain problems

with their SCR, that SCR is technically infeasible for similar

furnaces.

Additional information gathered suggests that Beta Steel's

process problems may have been caused by design issues. Based

upon this informatio~, USEPA believes that SCR is technically

feasible for steel reheat furnaces. Further, Beta Steel's SCR

reduces more NOx emissions than Low-NOx burners (which is

proposed by SOl for their Reheat Furnace), despite its process

problems. The USEPA contends that since the cost analysis shows

a $4300/ton of NOx figure, SCR should be BACT' for the Reheat

Furnace.

Post Combustion Technology: ..

Several Electric Arc Furnace (EAF) facilities across the country

use a post combustion chamber to greatly reduce CO emissions.

While this control does significantly reduce CO emissions, a

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certain amount of NOx emissions will be generated by this device.

IDEM has given the USEPA a preliminary analysis of the increased

NOx that will be formed with respect to the decreased co. The

impact of these increased NOx emissions will be minimal compared

to the huge NOx red~ctions facilitated by the NOx SIP Call. The

NOx SIP Call will reduce almost 30,000 tons per year of NOx

emissions from non-energy generating units ac~oss Indi~na by the

year 2003. Therefore, it is USEPA's opinion that the small

increase in NOx emissions from the post combustion chamber will

have a minimal impact on the attainment status of Whitley or

Allen County, and should be considered for use to control co

emissions.

The USEPA will also need some additional information regarding

the added amount of carbon attached to the Direct Reduced Iron

(DRI), as well as any DRI feed characteristics which might impact

the emissions of CO and NOx, compared "to normal scrap feed used

at other EAF's. This information will assist in the control

technology an~lysis.

PH-l0 An.~.i.:

Due to the hazardous nature of the dust generated by the EAF, the

design of the baghouse is crucial to control these particulate

emissions. The critical aspect of baghouse control is the. type

of material used for fabric. Also, ·different companies

manufacture baghouse fabrics at varying control efficiencies.

The PM-IO BACT analysis needs to include a cost analysis of these

different fabrics, compared to their control capabilities in

gr/dscf. .

IDEM has also traditionally allowed facilities to create their

own Preventive Maintenance Plan (PMP) in the past. We believe

that since the PMP will not be available for public review,

certain aspects of the upcoming plan should be discussed during

the public comment period. The USEPA would like to discuss the

possibility of a permit requirement to keep a certain supply of

fabric filter bags on site. This provision will ensure an

appropriate safety margin for continuous operation of the

baghouse during steel processing.

Slag Handling/Processing BACT Analysis:

The USEPA has researched the emissions calculatio~s and/or

estimations of the PM and PM-IO in the slag handl~g BACT

analysis. We believe that the initial PM calculations were under

estimated. The USEPA will submit a draft calculation shortly -

which depicts a significantly higher PM and PM-IO level compared

to the infor~ation listed within the permit application. With

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this rev~s~on, the corresponding cost analysis for the enclosed,

baghouse cont·rolled, processing area in the BACT analys,is is

economically feasible. The USEPA believes that all emissions

should be controlled from the time the molten slag exits from

under the EAF canQPY hood, to when the slag is fully processed

and is shipped off-site. This proposal is very similar to Beta

Steel's operation in Portage Indiana.

Also, the slag processing BACT analysis did not include any type

of heavy metal or Hazardous Air Pollutant (HAP's) emissions. The

USEPA believes that this slag may have a large amount of heavy

metals and HAP's. A calculation will be needed to determine

112(g) Analysis applicability.

BACT Limit. for Other Criteria Pollutant.:

Various criteria pollutant limits for SOl's EAF are higher than

similar respective EAF facilities nationwide. The USEPA

recognizes that some of these facilities may have processes which

are drastically different from the proposed SOl facility. We

continue th~exchange of information regarding these other

limits, and work together to attach the most reasonable

environmental limits. Some information that will be needed to

make these determinations are as follows:

1} The SOl facility will use DRI in their feed, which we

feel will have a significantly lower VOC content than normal

scrap feed. Despite the fact that DRI will only consist of

a certain percentage of the proposed incoming feed, this

characteristic should be reflected in the corresponding VOC

limit for SOl's EAF.

2) In the IDEM's BACT analysis for voe, certain facilities,

which are shown to attain their voe limits, are discounted

due to their use of "high grade scrap". IDEM should compare

the voe contents of this "high grade scrap" with a typical

composite of SOl's proposed feed.

3) On April 17th and 18th of 1997, a stack test was

performed on the existing SOl Butler facility, which showed

a 0.039 lb/ton result. While this result alone will not

entirely establish a BACT limitation, this result is

significantly lower than th~ 0.35 lb/ton listed in this.

permit. IDEM has stated that this test was discounted .. The

USEPA would like to understand the technical reasoning of

why this stack test was considered invalid.

4) In the S02 BACT analysis, there are two 'facilities listed

(NUCOR-Yamato Steel in Arkansas and Roanok; Electric Steel

i~ Virginia) which have lower S02 limits than the proposed

SOl limit of 0.25 Ib/ton. A comparison between the typical

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scrap fe~d of each of these two facilities with thestandard~

composite feed of.· the proposed SOl EAF will be needed. ...

5) lPSCO Iowa facility complies by their 0.0008 gr/dscf

filterable PM-IO limit. The USEPA will need information

regarding th~. cost and type of the fabric filter bags used.

Based upon the information given thus far, the USEPA

believes that the proposed SOl facility. should ~omply with

the lPSCO's PM-IO filterable BACT limit.

Lead Li mU;ation :

The USEPA believes that the potential exists for increased

emissions of lead due to fluctuations of lead content in the

scrap. These fluctuations could potentially exceed the 0.45

ton/year Potential to Emit(PTE) level, as indicated in the draft

permit. As you may be aware, lead has been commonly linked to

several health problems, specifically related to children.

Reportedly, there are two elementary schools near to the proposed

plant. The USEPA has received letters from citizens citing the

concerns over lead emissions from the SOl Whitley County

facility. In addition, IDEM has published a report which

indicates elevated blood lead levels within the proximity of the

site. Because of these concerns, the USEPA believes that IDEM

should consi~er including an enforceable lead limit in the PSD

permit •. The USEPA will work with IDEM to establish a method to

show compliance with this limit. .

Sulfur Monitoring:

The USEPA believes that additional parametric monitoring should

be conducted due to possible fluctuations of sulfur content in

the DRI that will be added to the furnace. Record keeping of the

amount of DRI, charge carbon and injection carbon that are

charged into the process, should be required at all times. Also,

a minimum periodic level of the times for test taking should be

conducted, in accordance with the test methods listed within the

permit. Vendor analysis should have some minimum requirements

specified in the enforceable permit document. These requirements

will need to be consistent with these test protocols as well.

Electric Arc FurnACe CompliAnce:

The USEPA would like to ensure proper periodic monitoring for·

this PSD permit. One example is the collection of transformer

power usage data, for both EAF units. These rec9rds should be

continuously kept on file, to assure the compliciQ.ce of the permit

condition limiting EAF operation to one furnace at a time.

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Offsets Langqage:

The USEPA would also like IDEM to clarify the state enforceable

Ozone credits used for this permit. SDI may acquire a certain

number of offsets to comply with a state requirement concerning

the potential 8-h<;>ur Ozone non-attainment status of Whitley

County. These offsets should be denoted as non-federally

enforceable, and therefore, they can be transferred from any site

across the state. Also, the permit should clarify that these

credits will not be required if Whitley County is considered

attainment for the 8-hour Ozone standard. Whitley County,

according to the USEPA, is projected to be considered attainment

for the 8-hour Ozon"e standard by the year 2000.

Combined Stack Ltmit:

Since the continuous caster, Ladle Metallurgical Furnace {LMF)

and the EAF are all emitting through one stack, a compliance

limit needs to be established 'based upon the tightest emissions

limitation of the three.

We have enc10sed two separate attachments which ask that IDEM

consider additional options for a more effective permit. One

enclosure deals with possible alternatives to IDEM for further

discussion. The USEPA would also like to discuss the second

enclosure which addresses an additional impact analysis on soils

and vegetation.

The USEPA will look fcrward to working with IDEM on these permit

issues. If you have any questions, please call Kushal Som, of my

staff, at (312) 353-5792.

Sincerely yours,

Hb-fai{ t0JJv?, (..

Pamela Blakley, Acting Section Chief

Permits & Grants Section tIL/IN/OH)

Enclosures

cc: JaimeWesseler

Citizen's Organized Watch {COW)

Glenn Landers

Sierra Club

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Enclosure '-!':

In our effort to work with IDEM more effectively, the USEPA would

like to provide alternatives to IDEM for future discussion:

1. We understand that many Electric Arc Furnaces (EAF's), •

such as the one listed in this proposed PSD permit, emit

various carcinogenic compounds which can have potential

health impacts. Several of these EAFfacilities,

nationwide, stack test for different heavy metal

concentrations. These speciated stack test requirements

will make data available for air deposition, critical

ecosystem and cumulative risk studies. We would like to

discuss this issue further.

2. The SDI BACT analysis refered to the proposed use of a

DEC air gap to reduce CO emissions. IDEM stated that SOl

planned to use "trial and error" in order to determine the

most optimal gap distance to reduce the highest amount of CO

emissions. The USEPA has learned that there may be

additional methods to minimize CO and NOx emissions on a

real-time basis. A further discussion with IDEM is

warranted.

3. A NOx CEM will develop more detailed information

regarding inpact of these new emissions with the ambient

Ozone levels. The USEPA would like to discuss the potential

benefits of this device for possible NOx trading

opportunities.

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Enclosure #2:

According to 40 CFR 52.21(0), all sources which are subject to

PSO must provide apditional impact analyses which investigate the

impairment causedoy a source on the soils and vegetation of an

area.

The USEPA is also concerned about the impact that the hazardous air

pollutants (such as Zinc (Zn), Magnesium (Mg), Lead (Pb), Mercury

(Hg), Arsenic (Ar), Chromium (Cr), Cadmium (Cd), Manganese (Mn) and

Vanadium (V» emitted by SOl may have on environmentally sensitive'

areas in the airshed. IDEM and the Indiana Department of Natural

Resources have collected data and identified higher quality

watersheds with critical habitats that contain a number of federal

and state listed species. In particular, EPA is requesting that

IDEM work with its own state agencies to potentially include in the

SOl permit application: (1) a study that analyzes the emissions

that will be deposited into the Cedar Creek ecosystem and (2) how

will the identified hazardous air compounds affect the important

federal and scate listed species in this ecosystem. EPA has worked

with a variety of agencies and groups in the state and will provide

SDI the relevant data and a suggested methodology to conduct such

studies.

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