.. UNITEDSTATESENVIRONMENTALPROTECTIONAGENCV REGION5 77WESTJACKSONBOUlEVARD CHICAGO,IL60604-3590



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# 1999 REPLVTOTHEATTENTIONOF AR-18J

Paul Dubenetzky Permit Branch Office ofAirManagement Indiana Department ofEnvironmental 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 ProtectionAgency'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.

ReheatFurnaceNitrogenoxide (NQx) BestAyailable 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 causedby 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 proposedby SOl for their Reheat Furnace), despite its process problems. The USEPA contends that since the cost analysis shows
a $4300/ton ofNOx figure, SCR should be BACT'for the Reheat Furnace.

Post CombustionTechnology:

.. 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 increasedNOx 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 ofNOx emissions fromnon-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 ofWhitley or Allen County, and shouldbe 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 ofCO and NOx, compared"to normal scrap feed used at otherEAF's. This information will assist in the control technology**an~lysis.** 

### PH-l0**An.~.i.:** Due to the hazardous nature of the dust generatedby the EAF, the design of the baghouse is crucial to control these particulate emissions. The critical aspect ofbaghouse control is the.type ofmaterial used for fabric. Also, ·different companies manufacture baghouse fabrics at varying control efficiencies. The PM-IO BACT analysis needs to include a cost analysis ofthese 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 shouldbe discussed during the public comment period. The USEPAwould 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.
SlagHandling/ProcessingBACTAnalysis: The USEPAhas 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 USEPAbelieves that all emissions shouldbe controlled fromthe time themolten slag exits from under the EAFcanQPY 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 ofheavymetal or Hazardous Air Pollutant (HAP's) emissions. The USEPAbelieves that this slagmay have a large amount ofheavy metals and HAP's. Acalculation will be needed to determine 112(g) Analysis applicability.


### BACTLimit. for Other Criteria

### Pollutant.: Various criteriapollutant limits for SOl's EAF are higher than similar respective EAF facilities nationwide. The USEPA recognizes that some ofthese facilities may have processes which
are drastically different from the proposed SOl facility. We continue**th~exchange** ofinformation regarding these other limits, andwork 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 certainpercentage 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 compositeof 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. Acomparison 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 USEPAwill need information regarding**th~.** cost and type ofthe fabric filter bags used. Basedupon 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

### LimU;ation: The USEPAbelieves that the potential exists for increased emissions oflead due to fluctuations ofleadcontent in the scrap. These fluctuations couldpotentially exceed the 0.45 ton/year Potential to Emit(PTE) level, as indicated in the draft permit. As youmaybe aware, leadhas been commonly linkedto several healthproblems, specifically related to children. Reportedly, there are two elementary schools near to the proposed plant. The USEPAhas received letters from citizens citing the
concerns over lead emissions from the SOl Whitley County facility. In addition, IDEM has publisheda report which indicates elevatedblood lead levels within the proximity of the site. Because ofthese concerns, the USEPAbelieves that IDEM should**consi~er** including an enforceable lead limit in the PSD permit•. The USEPA will workwith IDEM to establish a method to show compliance with this limit.

. SulfurMonitoring: The USEPAbelieves that additional parametricmonitoring 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, 

## aminimumperiodic level ofthe times for test taking should be conducted, in accordance with the testmethods listed within the permit. Vendor analysis should have some minimumrequirements specified in the enforceable permit document. These requirements will need to be consistent with these test protocols as well.

ElectricArcFurnACe CompliAnce: The USEPAwould like to ensure proper periodic monitoring for· this PSDpermit. 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 USEPAwould 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 ofWhitley County. These offsets shouldbe denoted as non-federally enforceable, and therefore, they canbe transferred from any site
across the state. Also, the permit should clarify that these credits will not be required ifWhitley 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 standardby the year 2000.

Combined StackLtmit: 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 ofthe 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 USEPAwould 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. Ifyou have any questions, please call Kushal Som, ofmy staff, at (312) 353-5792. Sincerely yours, 

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(.. 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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In our effort to work with IDEMmore 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, stacktest for differentheavy metal concentrations. These speciated stacktest 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 proposeduse 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 theremay be additional methods to minimize CO and NOx emissions on a real-time basis. Afurther discussion with IDEM is warranted. 3. ANOx 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. -,Enclosure #2:
According to 40 CFR 52.21(0), all sources which are subject to PSOmust provide apditional impact analyses which investigate the impairment causedoy a source on the soils and vegetation of an area.
The USEPAis also concernedabout 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» emittedby SOl may have on environmentally sensitive'
areas in the airshed. IDEM and the Indiana Department ofNatural 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 IDEMworkwith 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. EPAhas worked with a varietyofagencies andgroups in the state andwill provide SDI the relevant data and a suggestedmethodology to conduct such studies.



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