ArcelorMittal Cleveland 

Flat Carbon Steel 

November 15, 2010 

Certified Mail- Return Receipt Requested 

Mr. Alan Harness 

Ohio EPA - Division of Air Pollution Control 

P.O. Box 1049 

Columbus, OH 43216-1049 

Subject: ArcelorMittal Cleveland Inc. 

/ ! &dc:n<{C!/1;1 

Hot Strip Mill Reheat Furnaces P046, P047, P048 

NOx RACT Supplemental Information 

Premise No. 1318001613 

Dear Mr. Harness: 

/ o -fb J?<: /y;e:/calej 

io lAc f:'ilcr ":rrud;;-

ArcelorMittal 

On September 16, 2010, ArcelorMittal representatives met with you and Jim Orlemann to discuss your 

letter to the General Manager of the ArcelorMittal Cleveland Inc. facility dated July 21, 2010 requesting 

corrective measures to address NOx emissions in excess of the projected rate that ArcelorMittal included 

in its timely NOx RACT Plan. In the April 29, 2009 letter that approved our NOx RACT Plan for the three 

reheat furnaces at the Hot Strip Mill, Ohio EPA stated that the NOx emission limit for these units would 

"be established pursuant to stack tests." When the stack tests were conducted, the reheat furnaces 

were unable to meet the projected 0.24 lb/MMBtu NOx RACT emission rate in the approved NOx RACT 

Plan. During our meeting, we reviewed the stacl< test results and asked that Ohio EPA approve 0.35 

lb/MMBtu as the NOx RACT emission limits for Hot Strip Mill Reheat Furnaces No. 1 (P046), No. 2 

(P047) and No. 3 (P048). The requested NOxRACT emission limitation of 0.35 lb/MMBtu is based on 

the stack test results of 0.29 lb/MMBtu times a 1.2 factor which has previously been utilized by Ohio EPA 

when establishing limitations based on stack test results. The most recent stack tests verify that we 

have achieved a 51% NOx reduction over its 2003 baseline NOx emissions at these three furnaces. 

Ohio EPA asked for additional information in support of this NOx emission limit, which is provided in this 

letter and its attachment. 

Fundamentally, Ohio EPA was interested in why the actual NOx emissions from the ArcelorMittal reheat 

furnaces were significantly higher than the projected NOx emission rates submitted in the NOx RACT 

Plan for the U.S. Steel Lorain Pipe Mill reheat furnaces. Bloom Engineering is the burner vendor for 

both projects and its modeled emission rates were used to project NOx emission rates in both plans. 

Therefore, we asked Bloom Engineering to provide a report, which is transmitted with this letter, that 

explains the differences between the two NOx reduction projects and why the projected NOx rate for 

ArcelorMittal's furnaces is necessarily higher. In summary, the report concludes: 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105 

T +1 216 429 6542 

F +1 216 429 6631 

www.arcelormittal.com 
1. The furnaces are fundamentally different designs that process different products: U.S. Steel 

operates 1980s-era rotary reheat furnaces that heat on one side as the round billets rotate 

and ArcelorMittal operates 1970s-era pusher-type reheat furnaces that heat both top and 

bottom of the steel slabs. The newer U.S. Steel furnace design is more efficient and produces 

less NOx. 

2. The burner density (total furnace wall area/burner area) is five times higher in the pusher-type 

furnace, which Bloom projects would "more than double the NOx emissions" expected from 

the ArcelorMittal furnaces as compared with the U.S. Steel furnaces. 

3. ArcelorMittal installed ninety-six Bloom 1500 Ultra Low NOx Burners in the pre-heat and heat 

zones to achieve low NOx performance because they were the best performing burners that 

matched the existing furnace configuration and did not require a complete re-design of the 

furnace. U.S. Steel is proposing to install the next generation Bloorn 1610 Ultra Low NOx 

Burners, which can be accommodated in the existing rotary furnace configuration. 

4. The ArcelorMittal furnaces use forty-two Bloom 2010 Cold Air Burners in the soak zone of 

each furnace. Replacing these burners with the Bloom 2180 Ultra Low NOx burners proposed 

for the soak zone in one of the NOx RACT options for the U.S. Steel rotary furnaces would 

increase NOx emissions by 1.2%. The 2180 Burners are designed to reduce NOx when 

preheated combustion air is used at the burner. ArcelorMittal's reheat furnaces do not use 

preheated combustion air in the soak zone, and the cold combustion air naturally produces 

less NOx when used in conventional burners. 

ArcelorMittal has replaced 240 burners in its three HSM reheat furnaces since 2005 and stack tests 

verify that we have achieved a 51% NOx reduction over its 2003 baseline NOx emissions. Our early 

action resulted in significant NOx reductions well before other companies submitted their NOx RACT 

Plans. It is inappropriate to use these late-arriving NOx RACT plans to second guess the technology 

that was approved in the timely-submitted ArcelorMittal NOx RACT Plan. Based on our experience, 

Ohio EPA should wait until stack test verification before using projected NOx performance rates as a 

benchmark for other facilities. In the mean time, ArcelorMittal renews its request for approval of 0.35 

lb/MMBtu as the NOx RACT emission limit for each of the three HSM reheat furnaces. 

Sincerely yours, 

~ Rich Zavoda, ~ ~ 

Environmental Manager 

Attachment 

cc: Mr. George Baker, City of Cleveland - Division of Air Quality 

75 Erieview Plaza, 2nd Floor, 

Cleveland, Ohio 44114 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105 

T +1 2164296542 

F +1 2164296631 

www.arcelormittal.com 
ArcelorMittal 

Cleveland Works 

3060 Eggers Ave 

Cleveland OH 44105 

ATTENTION: 

SUBJECT: 

Bloomengineering 

November 15, 20 I 0 

Mr. Rich Zavoda 

Bloom Engineering Low-NOx Bumer Technology Applied to Cleveland Works Reheat Furnaces 

Per your request, this technical paper addresses the following issues regarding the low-NOx burner technology applied to 

ArcelorMittal Cleveland Hot Strip Mill reheat fumaces: 

L Compare the installed Bloom 1500 Ultra Low NOx Burner Air Staged Burners with other feasible burner 

options for reducing NOx from the No.I, No.2 and No.3 Reheat Furnace Preheat and Heat zones. 

2. Analyze Soak Zone burner replacements as a NOx control strategy. 

3. Summarize the material differences between the Cleveland pusher type reheat furnaces and the U.S.Steel Lorain 

Pipe Mill No.4 Rotary Furnace with respect to NOx emissions. 

Discussion: 

I. Comparin~ the Bloom 1500 Ultra Low NOx Burner Air Sta~ed Burners with other feasible burner options. 

Bloom 1500 Ultra Low NOx Air Staged Burners were installed in the pre-heat zone and the heat zone on each of the three 

reheat furnaces that serve the ArcelorMittal Cleveland Hot Strip Mill from 2006 through 20 I 0. This burner retrofit 

project replaced over 100 of the original 1200 series burners with Ultra Low-NOx technology. When this project was 

initiated in 2006, Bloom Engineering had recently introduced its 1610 Series burners, which model improved NOx 

performance in some applications. For the reasons itemized below, the 1610 series burners were not appropriate for the 

ArcelorMittal Cleveland project due to the extensive reconfiguration of the furnaces, fans, and electrical systems 

necessaty to accommodate these burners. This type of reconfiguration had not been perfonned on a similar furnace, so 

there was considerable uncertainty whether the burners would work to the modeled expectations after this complex and 

expensive reconfiguration. Shown below are the technical limitations (hurdles) to installing the 1610 Series burners at 

the ArcelorMittal Hot Strip Mill Reheat Furnaces: 

• Fit: Based on drawings supplied by ArcelorMittal for the Bottom Preheat Zone burner wall and standard 1610-

026 mounting plate dimensions, there is insufficient room to accommodate these bumers in this zone. There is a 

2' -9" (33") clearance in-between the buckstays of the burners in this zone. The mounting plate dimensions for the 

1610-026 burners that would be required to match existing burner capacity are 35" square. A complete 

modification of the burner wall, and potentially combustion air and gas piping would be required. The burner wall 

cutout would need to be re-engineered and reviewed by a structural engineer to ensure and maintain structural 

integrity of the fumace. 

• Additional piping (dive11er valve): To obtain the Ultra Low NOx perfonnance of the 1610 series burners, we 

require a diverter valve to be installed at the air inlet to the burner. This valve will be required to be switched on 

and off based on furnace temperature. We understand from ArcelorMittal that the Cleveland Works does not have 

an air compressor of sufficient capacity and pressure to provide valve actuation. Also, there are no compressed air 

lines running to where the dive1ter valves would have to be mounted on the burners presently. All of the 
2 

combustion air drops to the individual bumers would need to be modified (shottened) and then flanged to 

accommodate the installation of the diverter valve. 

• Additional piping (hot air lances): For longitudinal firing, Bloom recommends that a lance be used. The 1610 

burners are a little limited in their turndown capabilities and a lance is recommended in order to maintain flame 

geometry under turndown conditions. To provide the air for the burner lances a separate air line would have to be 

installed off of the existing zone air piping. The Preheat zones will require a 3" header and 1" drops for each of 

the burners, while the Heat zones will require a 2-I /2" header with%" drops at each of the burners. Additionally, 

the solenoid valves for on/off control of the lances will require wiring and installation. The solenoid valves will 

each require I I OV power with conduit running to each valve. The air piping should also have an internal 

refractory lining. 

• Suitability for retrofit of existing bumers: Due to the complexity of the 1610 Series burners, an in-situ burner 

modification is not feasible. 

• Gas pressure requirements: The Bloom 1610 Series burners require a higher gas pressure at the burner. The old 

1200 Series burners on the fumace had a gas pressure requirement of less than 2" w.c.; the 1610 Series burners 

will require 10 psig be made available at the burner. This higher pressure requirement will require modifications 

to the existing main fuel gas train. Based on the age of the existing gas train it would be safe to assume that a 

completely new gas train would be required for either the longitudinally fired zones (Preheat & Heat) or the Soak 

zone because of the great disparity in burner gas pressure requirements. 

• Air pressure requirements: The original 1200 Series burners operated with a pressure requirement of not more 

than 6" w.c. in the longitudinally fired zones. The 1610 Series bumers require 12" w.c. air pressure in order to 

function properly. The fumaces at Cleveland Works are blower capacity limited by pressure. It is extremely 

doubtful, that there would be sufficient air pressure available for the proper functioning of a standard design 161 0 

Series burner if existing capacities would have to be maintained. The discussion of upgrading the blowers at 

Cleveland Works has gone on for years. It is believed that a blower upgrade cannot be executed due to the change 

required on the blower motors (increased HP) from what we understand the change in the blower HP would 

require a higher FLA (current), which exceeds the design of the existing electrical substation. From our 

understanding of this matter, to increase the blower pressure, significant changes will need to be made to the 

electrical substation. 

Given these obstacles and uncettainties, and the cost to try and overcome these limitations, the 1500 series Ultra LowNOx burners were a more reliable and cost effective application for the Cleveland reheat fm11aces. 

2. Analvsis of Soak Zone bumer replacements. 

ArcelorMittal replaced 126 soak zone burners in 2006 and 2007 with Bloom 2010 Cold Air Burners. These new soak 

zone burners have expected NOx emissions of0.056lb/MMBtu. These are cold combustion air bumers in which the NOx 

concentrations and emissions are inherently low. Bloom makes a roof-fired Series 2180Ultra Low-NOx burner for soak 

zones. However, they cannot be run on cold combustion air. To accommodate the 2180 burners, ArcelorMittal would 

need to run a new combustion air line from the recuperator (950 deg Fair) to the soak zones. When you run the soak zone 

at temperature, with 950 deg F air, Ultra Low NOx roof burners, compared to the cold air burners installed now, the 

overall NOx fot· the furnace actually INCREASES by about 1.2%. 

3. The ArcelorMittal Cleveland pusher-tvpe furnaces compared with the U.S.Steel/Lorain Pipe Mills #4 Rotarv 

Furnace with respect to NOx emission retrofits. 

Background: 

A. Bloom issued a budgetaty proposal (P-B006702) for the replacement/retrofit of burners at the U.S.Steel/Lorain 

Pipe Mill No.4 Rotaty Fumace. This is a BUDGETARY proposal, as of yet there has not been any contractual 

agreements between either party and, as such, the proposal does not include all the necessary technical due 

diligence required before a contractual agreement is reached. Prior to establishing any contractually based 
3 

process performance standards a complete and thorough technical review needs to be conducted that accounts 

for actual operating practices. 

B. The Lorain proposal presented two options for replacement bumers. Option# I called for the replacement of all 

the bumers in the Preheat and Heat zones (2) with Bloom I 610 Series bumers, and leaving the soak zone 

bumers as they are. Option #2 was to replace the burners in the Preheat and Heat zones with higher efficiency 

regenerative burners. For either option, the anticipated NOx emissions for the overall fumace would be below 

0.150 #/MMBtu for the operating conditions described by USS/LPM. 

C. Differences between the ArcelorMittal Cleveland Works furnaces and the furnace at USSiLPM 

a. ArcelorMittal Cleveland: 

Iy 

! 

L 

H ~. \91· 

L. 

--z 

! 

1. Type of fum ace: Flat-Rolled Product- Slab reheat, pusher 

ii. Material to be processed: 8" thick slabs to 2300°F 

iii. Production rate: 250 TPH 

1v. Overall dimensions: 34' wide by 111' long 

=.B . ·-· ? ' 

v. Type of firing: 5 zone longitudinally fired, top & bottom with a roof fired solid soak hearth 

vi. Commissioned: circa 1970 

v11. Total connected fuel capacity: 602.6 MMBtu/hr 

viii. Fuel rate based on connected capacity: 2.4! MMBtu/Ton 

IX. Total wall area for bumers (excluding soak zone): 977.5 SQF 

x. Total pmt area for burners (excluding soak zone): 100.8 SQF 

XI. Calculated burner density= total wall area/total port area (excluding soak zone): 9.7 

xii. Max zone temperature (modeled): 2465°F 

XIII. Air preheat temperature (modeled): 950°F 

xiv. Amount of excess air (modeled): 5% 
b. USS/Lorain Pipe Mill #4 Rotary reheat furnace: 

CONTROL TEMPERATURE 5Efi!NG5 

1

-, - 1915 

11' 2 - 2r30 

ZONE 13 -- 2285 

4- - 2285 

5 - 2280 

Figur:: 3- Typical he;~rth roof .l:-ccl side w;lll t(!rnp~rature 

t:!irtributio!'l, as w~!! as thl! c:;,:-~tr~l ten,perature $et• 

tings, l:1 :~ mu!ti·b:~ffiad rot.1ry hnal"th furnac.::! aro 

glv("n in this sketch. 

Images are of a typical tube mill rotary 

hearth furnace. 

1. Type of furnace: Bar Product- Rotary reheat, rounds/billets 

4 

n. Material to be processed: round billets- in general discharge temp is less than that of slabs 

iii. Production rate: USS Confidential information 

iv. Overall dimensions: USS Confidential information 

v. Type of firing: USS Confidential inforn1ation 

vt. Commissioned: Circa 1980+ 

vn. Total connected fuel capacity: USS Confidential information 

viii. Fuel rate based on connected capacity: USS Confidential information 

ix. Total wall area for burners (excluding soak zone): 1,733.1 SQF 

x. Total port area for burners (excluding soak zone): 33.78 SQF 

xr. Calculated burner density= total wall area/total port area (excluding soak zone): 51.3 
xrr. Max zone temperature (modeled): 2350°F 

XIII. Air preheat temperature ( modeled): 750°F 

xiv. Amount of excess air (modeled): 5% 

c. Discussion of the differences between the two furnaces 

5 

i. Fundamental differences between a 5 zone Flat-Rolled Product slab pusher and a Bar 

Product rotary hearth furnace include only one sided heating for the rotary while the pusher 

is both top and bottom fired in the preheat and heat zones. 

11. Materials being processed: The round billet with single sided heating vs. the 8,. thick slab 

will have different heating characteristics, i.e. residence times in the furnace. For instance 

the round billet pieces in the rotary have a resonance time of about 1.5 hrs while the 8,. slabs 

will require over 2 hours of residence time. 

Ill. Differences in production rates: Intuitively, the higher the production rate the more heat 

(fuel) will be required to heat the product. More heat implies more connected fuel capacity. 

The slab reheat furnace has a much higher burner density than the rotary due to the way in 

which the furnace is fired, e.g. no unfired section. 

iv. Overall effective heating length. In general the longer the furnace, the more efficient for the 

same production rate. 

v. Type of firing. Over/under firing (2-sided heating) will generally increase the production 

rate of a furnace compared to single sided heating. Any unfired section near the charge end 

of the fumace will also promote fuel efficiency due to the hot gasses passing over and 

preheating the product. The rotary has an unfired section while the slab pusher does not. 

Therefore, the rotary should be more efficient and require less burner density. 

vi. Commissioning dates: There is about a 14-year difference between the two furnaces. Over 

this time there was additional experience and technology improvements in furnace design 

that were implemented into the rotary furnace that the slab furnace did not have access to. 

vii. Total connected fuel capacity: Overall there is greater than a 70% reduction to the overall 

connected capacity. Bumer capacity affects NOx emissions. In general the larger the burner 

the higher the NOx. 

viii. Fuel rates based on connected capacity: The rotary should have a lower fuel rate because of 

the unfired section of the furnace. Unfired sections will improve fuel efficiency. 

ix. See xi 

x. See xi 

xi. NOx emissions on a pound per MMBtu basis are a function of wall to p01t ratio or burner 

density. With the pusher at 9.7 and the rotary at 51.3 -over a 5 fold difference, higher NOx 

emissions will be expected from a pusher fumace at 9. 7 compared to a rotary at 51.3 wall 

ratio. From the chart below, one can see that the differences in the two wall to port ratios 

will produce an overall effect that would more than double the NOx emissions with respect 

to the wall-to-port ratio calculation. 
6 

Wall Ratio 

KFac-tor '·' I ·- -··--· 

,. 

" I 

• 

05 

aL -------···-- ·--·· 

" " "' ~ "' " ~ 

W~i!Rotic 

XII. Max furnace temperature setpoint used in the NOx model. 2465°F v. 2350°F. The affects of 

furnace temperature on NOx emissions can be observed by the graph below. By inspection 

there is an increase of 20% (=l.l/.9) that can be attributed to the difference in the max 

furnace temperature setpoints. 

''I· 

1.2: 

,L 

!! "i 

~ i : :.:: o.s r·~-----'-

1500-lXX 

Furnace Temperature 

K Factor 

'·' ~I =;,\;;;;;;;;;i;,......:-.....;.~= 

1600 1700 lilOIJ 1900 2000 21(1!1 2200 2300 240(1 2500 2600 

FumnceTemp 

xiii. Air preheat temperature: 750°F for the rotmy v. 950°F for the pusher. This 200°F difference 

in air preheat will affect NOx emissions by the chart shown below. By observation, one can 

see that the differences inK-Factors would imply that the overall NOx emissions of the slab 

furnace would increase by 16% (= 1.1/.95) 

L 

,, 

"'' ,., "' "' ~ 

1500.LXX 

Air Preheat 

K Factor 

"~_..J ___ 

""' AltPr<!tlool '" "' 

T ,. 

L ·- j-

,., "" "" ,., ""' "" 
7 

xiv. Amount of excess air- no difference. 

In conclusion, based on the overall technological improvements over I 4 years of increasingly better design the 

rotary furnace is able to heat steel more efficiently than the pusher. It is also noted that the burner density of the 

two fm11aces is reduced in the case of the rotary which implies a greater wall to port ratio which would help 

reduce the overall NOx emissions of a fumace. The differences noted in the max zone furnace operating 

temperatures and air preheat differences between the two furnaces will always favor the rotmy v. the pusher. 

Generally speaking, the higher the zone temperatures and air preheat temperatures, the higher the NOx. Finally, 

Bloom 1610 series burners fit the application in Lorain on the rotary fumace, while the 1500 series burner·s (as 

discussed above) fit the application in Cleveland for the 5-zone pusher type furnace. 

We feel that the enclosed provides you an adequate summary of the infonnation that you've requested. Should you have 

any questions concerning any of the information enclosed in this document please don't hesitate to contact the 

undersigned. 

Yours truly, 

!Yo,vt/ JL~ BLOOM ENGINEERING 

David G. SchaiJes 

VP-Technical Services 

5460 Horning Rd 

Pittsburgh, PA 15236 
ArcelorMittal Cleveland 

Flat Carbon Steel 

December 12, 2008 

Certified Mail- Return Receipt Requested 

Mr. Alan Harness 

Division of Air Pollution Control 

Ohio Environmental Protection Agency 

Lazarus Government Center 

P.O. Box 1049 

Columbus, OH 43216-1 049 

Subject: ArcelorMittal Cleveland Inc. 

Ohio EPA 1318001613 

OAC 37 45-11 0 NOx RACT 

Dear Mr. Harness: 

ArcelorMittal 

In accordance with OAC 3745-110, ArcelorMittal Cleveland Inc. submits the enclosed NOx Reasonably 

Available Control Technology Report (RACT) study. As is described within this study, ArcelorMittal 

Cleveland has been installing control equipment, especially during the last few years in order to reduce 

emissions of nitrogen oxides. 

ArcelorMittal Cleveland submits this NOX RACT study for your timely approval. Please contact Rich Zavoda 

at (216) 429-6542, if you have any questions or require additional information regarding this issue. 

Sincerely yours, 

General Manager 

Attachment 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105 

T +1 2164296542 

F +1 2164296631 

www.arcelormittal.com 

.," 

' 
NOx REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) STUDY 

ARCELORMITTAL CLEVELAND 

CLEVELAND, OHIO 

Prepared for: 

ArcelorMittal Cleveland 

3060 Eggers Avenue 

Cleveland, Ohio 44105-1012 

Prepared by: 

Environmental Quality Management, Inc. 

1800 Carillon Boulevard 

Cincinnati, Ohio 45240 

PN 050397.0020 

December 2008 
CONTENTS 

Section 

1 Introduction ..................................................................................................................... 1-1 

2 Required Contents of the NOx RACT Engineering Study .............................................. 2-1 

3 NOx Sources at ArcelorMittal Cleveland ....................................................................... 3-1 

4 Presumptive NOx RACT Limits for Boilers at ArcelorMittal Cleveland ...................... 4-1 

5 Required Emissions Data for Each Applicable NOx Source ........................................... 5-1 

6 Required Production Data for Each Applicable NOx Source ......................................... 6-1 

7 NOx Control Technologies That Are Not Applicable or Technically Feasible at 

ArcelorMittal Cleveland .................................................................................................. 7-1 

8 General Discussion of Potentially Feasible NOx Controls for the Remaining 

NOx Sources .................................................................................................................... 8-1 

9 Source-by-Source NOx RACT Discussion ..................................................................... 9-1 

10 Selection ofNOx RACT Recommended Controls ........................................................ 10-1 

11 Schedule for Installation of Proposed NOx Control Equipment ................................... 11-1 

Appendix: 

• ArcelorMittal Cleveland NOx PTE Emission Calculations 

• ArcelorMittal Cleveland NOx RACT Information & Calculations 

• No. 1 Reheat Furnace Low NOx Burners Cost Calculations 

• No. 2 Reheat Furnace Low NOx Burners Cost Calculations 

• No.3 Reheat Furnace Low NOx Burners Cost Calculations 

• ArcelorMittal Cleveland Plot Plat Showing Affected NOx Sources 

• Documentation of Prior NOx Stack Test Results- Sururnary Reports 

• Proposed NOx RACT Emission Factors Calculations by Source 

ii 
TABLES 

Number 

3-1 Title V Permitted Sources at ArcelorMittal Cleveland ................................................... 3-2 

4-1 Presumptive NOx RACT Limits for Applicable Boilers ................................................. 4-1 

5-1 Required Emission Data Source Information .................................................................. 5-2 

6-1 Required Production Data Source Information ............................................................... 6-2 

10-1 NOx RACT Recommended Selection and Proposed NOx RACT Recommended 

for Applicable Sources at ArcelorMittal Cleveland ...................................................... 10-1 

iii 
SECTION 1 

INTRODUCTION 

On December 12,2007, the Ohio Environmental Protection Agency (OEPA) 

promulgated OAC Rule 3745-110, Nitrogen Oxides- Reasonably Available Control Technology 

(RACT). These rules apply to facilities located in Ashtabula, Cuyahoga, Geauga, Lake, Lorain, 

Medina, Portage, or Summit County that have the potential to emit more than 100 tons per year 

of nitrogen oxides (NOx) emissions from all sources at the facility. 

The rules impose specific presumptive NOx RACT emission limits for boiler categories 

(mid-size, large, and very large), stationary combustion turbines, and stationary internal 

combustion engines. For affected sources ofNOx at an affected facility that is not subject to an 

NOx emission limit, or is subject to a presumptive NOx RACT emission limit but the owner or 

operator claims that the applicable limit is technically infeasible and/or economically 

unreasonable (i.e., not cost-effective), the owner or operator must conduct a detailed engineering 

study to determine the technical and economic feasibility of reducing the NOx emissions and to 

define RACT for the source. The NOx RACT Engineering Study must be completed no later 

than 1 year, or December 12, 2008, from the effective date of this rule. Any source other than a 

boiler, gas turbine, or internal engine that has the potential to emit less than 25 tons per unit of 

NOx is exempt from the requirement to complete the NOx RACT Engineering Study. 

The ArcelorMittal Cleveland facility is located in Cuyahoga County and has the potential 

to emit more than 100 tons per year ofNOx. As such, the facility falls under the requirements of 

OAC rule 3745-110. 

The following section comprises the required NOx RACT Engineering Study for the 

facility. 

1-1 
SECTION2 

REQUIRED CONTENTS OF THE NOx RACT ENGINEERING STUDY 

OAC Rule 3745-110-03(I) requires that the NOx RACT Engineering Study provide the 

following information: 

(a) The complete facility name and address. 

(b) The name, title, address and telephone number of the owners or operator's representative 

within the company who shall be the contact person for this facility regarding the 

engineering study and affected sources. 

(c) The name, title, address, and telephone number of the official who is responsible for 

approval of the engineering study. 

(d) The standard industrial classification code number(s) which are applicable to the 

facility's operation. 

(e) The following general information for each affected source: 

(i) Ohio EPA application number(s). 

(ii) Company identification. 

(iii) Source description. 

(iv) Month and year installed. 

(v) Normal operating schedule (hours per day, days per week, and weeks per year). 

(vi) Annnal production rates for each of the three full calendar years preceding the 

effective date of this rule. 

(vii) Average and maximum daily production rates for each of the three full calendar 

years preceding the effective date ofthis rule. 

(viii) The type of control equipment employed and the date installed. 

(f) A plot plat which shows the general layout of the facility and the affected sources(s). 

(g) The following emission data for each affected source: 

(i) Average daily NOx emissions (pounds per day of operation) based upon the 

highest average daily production rate for each of the three full calendar years 

preceding the effective data of this rule or any other year that may be 

representative of the highest daily emissions. 

(ii) Maximum daily NOx emissions (pounds per day of operation) based upon the 

highest maximum daily production rate for each of the three full calendar years 

preceding the effective date of this rule or any year that may be more 

representative of the highest maximum daily emissions. 

(iii) Annual NOx emissions (tons per year) based upon the highest annual production 

rate for each of the three full calendar years preceding the effective date of this 

rule or any period that may be more representative of the armual production rate. 

2-1 
(iv) Documentation of the efficiency of the existing control equipment. 

(v) Documentation of any emission testing which as been performed. 

(h) A detailed discussion of the technical feasibility of employing each of the following types 

of control measures for each affected source (or combination of sources): 

(i) Low NOx burners. 

(ii) Close coupled or separated over-fire ports. 

(iii) Flue gas recirculation. 

(iv) Burners out of service. 

(v) Steam/water injection. 

(vi) Dry low NOx burners. 

(vii) Ignition timing retard. 

(viii) Separate circuit after-cooling. 

(ix) Fuel emulsification. 

(x) Selective noncatalytic reduction. 

(xi) Nonselective catalytic reduction. 

(xii) Selective catalytic reduction using urea ammonia and methane as reducing agents. 

(xiii) Incineration (for sources other than boilers). 

(xiv) Scrubbing (for sources other than boilers). 

(xv) Process modification. 

(xvi) Fuel switching. 

(xvii) Low excess air. 

(xviii) Gaseous fuels reburn. 

(xix) Any other such RACT alternatives as are proposed by the owner or operator. 

A detailed engineering discussion is not required for those control measures 

which are not applicable to a particular source. 

(i) For each type of control measure that is determined to be technically feasible, an estimate 

of the control efficiency that can be achieved. 

(j) For each control measure that is determined to be technically feasible, an estimate of the 

capital cost, annualized cost (including capital and operating cost) and the costeffectiveness (armual dollars per ton ofNOx removed armually). 

(k) A comparison and discussion of the advantages and disadvantages of the control options 

that are determined to be technically feasible. 

(1) A recommended definition of RACT for the source, including enforceable production 

limits, emission limits, control efficiencies, and/or operating limits. 

(m) An expeditious schedule for implementing the recommended definition ofRACT, 

including milestones for awarding contracts, initiating construction, completing 

construction, and performing emissions testing, if necessary, to demonstrate compliance 

with the approved definition ofRACT. 

(n) In the engineering study, all calculations of the NOx emissions, including all assumptions 

made, shall be documented clearly and in detail. In addition, the capital and operating 

costs and the cost-effectiveness estimates shall be calculated in a marmer that is 

2-2 
consistent with the OEPA, Division of Air Pollution Control document entitled 

"Guidance for Estimating Capital and Annual Costs of Air Pollution Systems." 

Subsections (a) through (d) of the requirement are specific to the facility in general, and 

are completed as follows: 

(a) The complete facility name and address: 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105-1012 

(b) The name, title, address and telephone number of the owners or operator's representative 

within the company who shall be the contact person for this facility regarding the 

engineering study and affected sources: 

R. M. Zavoda 

Manager, Environmental 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105-1012 

(216)-429-6542 

(c) The name, title, address, and telephone number of the official who is responsible for 

approval of the engineering study: 

R. M. Zavoda 

Manager, Environmental 

ArcelorMittal Cleveland Inc. 

3060 Eggers Avenue 

Cleveland, Ohio 44105-1012 

(216)-429-6542 

(d) The standard industrial classification code number(s) which are applicable to the 

facility's operation. 

3312 

Subsections (e) through (n) contain source-specific requirements and are completed in 

subsequent chapters of this study. 

2-3 
SECTION3 

NOx SOURCES AT ARCELORMITTAL CLEVELAND 

The ArcelorMittal Cleveland facility is located on the Cuyahoga River south of 

downtown Cleveland. Except for cokemaking operations, the facility is a totally integrated iron 

and steel manufacturing facility. The facilities include blast furnaces, basic oxygen furnace 

vessels, slab casters, ladle metallurgy and vacuum degassing facilities, reheat furnaces, hot strip 

mill, cold mill, temper mill, continuous annealing lines, and a continuous galvanizing line. 

Table 3-1 presents a summary ofTit1e V permitted sources ofNOx within the facility. 

F016 (Coal Thawing), P068 (Continuous Caster), P073 (VCP), and P266 (Continuous 

Caster) have NOx emissions with the potential to emit less than 25 tons per year. As such, they 

are exempt from the requirement to complete the NOx RACT Engineering Study, and no 

additional information needs to be provided. 

In addition, OAC Rule 3745-11 0-03(J)(l8) ofthe NOx RACT rules states that those 

boilers covered under the NOx SIP Call rules are also exempt from these requirements. These 

boilers include BOO! (Boiler A), B002 (Boiler B), B003 (Boiler C), B004 (Boiler D), and B007 

(Boiler 3). The Walking Beam Furnace (P265), which was indefinitely idled, has not operated 

since 2001. The Walking Beam furnace is also exempt under OAC Rule 3745-110-03(J)(20). 

No additional information is provided in regard to these 1 0 sources. 

3-1 
TABLE 3-1 TITLE V PERMITTED SOURCES AT ARCELORMITTAL CLEVELAND 

Rated Rated Potential to 

Emission Unit Capacity Capacity EmitNOx NOx Emission 

# Description (MMBtu/hr) Fuels Burned (Tons/hr) (Tons/yr) • Limits 

BOO! Boiler A 336 BFG!NG/ N/A 510.0 N/A Fuel Oil 

B002 Boiler B 336 BFG!NG/ N/A 510.0 N/A Fuel Oil 

B003 Boiler C 336 BFG!NG/ N/A 510.0 N/A Fuel Oil 

B004 Boiler D 467 BFG!NG/Coal N/A 1469.1 N/A 

BOOS Boiler I 237.5 BFG!NG N/A 284.2 N/A 

B006 Boiler 2 237.5 BFG!NG N/A 284.2 N/A 

B007 Boiler 3 388 BFG!NG/Coal N/A 1221.3 N/A 

F0\6 Coal Thawing N/A NG N/A 5.5 N/A - (<25) 

\,~~ Reheat Fee #I 630 NG, (Fuel Oil N/A 806.4 N/A -Standby) 

'•"" 630 NG, (Fuel Oil 

·.'-P047) Reheat Fee #2 - Standby) N/A 806.4' N/A " '---~--~-

( '~ \ ' NG, (Fuel Oil ('.P048 . Reheat Fee #3 ,639) N/A 806.4 N/A -....._-:;--.,, ,I "·-,~~~- . -Standby) "'-···-- 14.7 

P049 Anneal- 80 NG N/A (practical N/A North PTE) 

Anneal- 14.7 

P0 50 80 NG N/A (practical N/A South PTE) 

P068 Continuous 12 NG N/A 5.4 N/A Caster (<25) 

Continuous 

(Hot Dip) 0.23 

P071 Galvanizing !59 NG N/A 160.2 lb/MMBtu 

Line (formerly and 160.2 

a Continuous tons/yr 

Anneal Line) 

Vacuum 5.9 P073 Degassing 9.45 NG NA (<25) NA 

Facility (VCP) 

~ .. 

0.4 [--· 

8 Walking lb!MMBtu& 

613 NG UNK 283.6 1.2 times the Beam Furnace actual firing 

rate 

P266 Continuous 20.3 NG N/A 9.1 N/A Caster (<25) 

Stoves: 51.2 total C5 Blast approx. Stoves: 17.8 

P903 Furnace: 338.5' BFG 204 Flare: 10.1 N/A Stoves, Flare, Flare: Casthouse: and Casthouse approx. 23.2 191.8' 

3-2 
TABLE 3-1 (continued) 

Rated Rated 

Emission Unit Capacity Capacity 

# Description (MMBtu/hr) Fuels Burned (Tons/br) 

Stoves: 

C6 Blast approx. 

P904 Furnace: 338.5' BFG 191 Stoves, Flare, Flare: 

and Casthouse approx. 

19!.8' 

Ladle 

No.2 BOF: Preheaters: 

P905/ Vessels, Ladle approx. N/A 500 P906 b Preheaters, 9!.3' 

and Flare Flare: 

approx. 4.6' 

No. l BOF Ladle 

P925/ Vessels and Preheaters: N/A 269.4 P926' Ladle approx. 

Pre heaters 57.1' 

a See attached ArcelorMtttal Cleveland NOx PTE Emtsston Calculattons. 

b ArcelorMittal Cleveland has renamed these sources No. l BOF. 

'ArcelorMittal Cleveland has renamed these sources No.2 BOF. 

BFG =Blast Furnace Gas which is an inherent low-NOx generating gas. 

NG = Natural Gas 

3-3 

Potential to 

EmitNOx NOx Emission 

(Tons/yr) • Limits 

128.5 total 

Stoves: 68.1 

Flare: 38.6 N/A 

Casthouse: 

2!.8 

326.7 total 

Vessels: 

284.7 N/A Flare: 2.0 

Preheaters: ' 

40.0 

178.4 total .. 

Vessels: 

153.4 N/A 

Preheaters: ' 

25.0 ) 
SECTION4 

PRESUMPTIVE NOx RACT LIMITS FOR BOILERS AT 

ARCELORMITTAL CLEVELAND 

As previously mentioned, the rules impose specific presumptive NOx RACT emission 

limits for boiler categories (mid-size, large, and very large), stationary combustion turbines, and 

stationary internal combustion engines. The facility contains two boilers which fall under these 

requirements. The presumptive NOx RACT emission limits for these boilers are sununarized in 

Table 4-1. 

TABLE 4-1 PRESUMPTIVE NO RACT LIMITS FOR APPLICABLE BOILERS X 

Rated Presumptive NOx 

Emission Capacity Fuels RACTLimit 

Unit# Descriotion (MMBtu/hr) Burned Boiler Classification (lbs/MMBtu) 

BOOS Boiler 1 237.5 BFG/NG Large 0.10 

B006 Boiler 2 237.5 BFG/NG Large 0.10 

For these affected sources subject to an NOx emission limit, the rules allow the facility to 

claim that the applicable limit is technically infeasible and/or economically unreasonable (i.e., 

not cost-effective) and then conduct a detailed engineering study to determine the technical and 

economic feasibility of reducing the NOx emissions and to define RACT for the source. 

ArcelorMittal Cleveland accepts the presumptive NOx RACT limits for these two boilers. 

As such, no NOx RACT Engineering Study is required for these two remaining boilers. 

Boilers BOOS and B006 share a common stack. On November 2, 1994, Enviroumental 

Quality Management, Inc. (EQ) conducted stack testing of this common stack utilizing U.S. EPA 

Method 7. The results of the triplicate 60-minute sampling runs indicated that these BFG-fired 

boilers produce less than 0.017 lb NOx per MMBtu. 

4-1 
SECTIONS 

REQUIRED EMISSION DATA FOR EACH APPLICABLE NOx SOURCE 

The rules impose the following emission data to be reported for each applicable source, 

as summarized in Table 5-1. 

Both the average and maximum daily NOx emissions for each source are based upon the 

highest average daily production rate for each ofthe three full calendar years (2004, 2005, and 

2006) preceding the effective data of this rule. The maximum daily emissions are based on 10% 

higher than the average daily NOx emissions for each source. Annual NOx emissions for each 

source are based upon the highest armual production rate for each of the three full calendar years 

(2004, 2005, and 2006) preceding the effective data of this rule. Prior NOx emission stack tests 

are included in the Appendix. 

5-1 
TABLE 5-1. Rl!,vu EMISSION DATA SOURCE INFORMATION 

Average NOx Maximum 

Emission Source Month & Year Emissions Emissions 

1 Unit,~ Installed 

\eo46\ . Not 6170 2291 3553 

Strip Mill 

Furnace #1 

i ·, 

~;o4~ 84-inch Not 6/70 2482 3607 

·, I Strip Mill 

Furnace #2 

--

p.~48 . Hot 6/70 2805 3531 

Strip Mill 

Furnace #3 

P049 6171 78 94 

Anneo{ North 

P0 50 6171 78 94 

, ......•• Anne"! South 

~~~ Continuous 6/89 65 71 

(Hot Dip) 

Galvanizing 

Line 

P903 C5 Blast 6/43 176 197 

Furnace: (total of three (total of three 

Stoves, Flare, sources) sources) 

andr, 

P904 C6 Blast 6/52 466 S06. 

Furnace: (total of three (total of three 

Stoves, Flare, sources) sources) 

and Casthouse 

P905/ No.2 BOF: 6/66 1133 1246 

P906 b Vessels, Ladle (total of four (total offm,1r 

Preheaters and sources) sources) 

Flare 

P925/ No.1 BOF 6/61 370 40?. 

P926' Vessels and L. (total of three (total of three 

n. -" sources) sources) 

'See Arcelorinmm l NOx RACT uuv""""v" and r 

h ArcelorMittal Cleveland has renamed these sources No. 1 BOF. 

'ArcelorMittal Cleveland has renamed these sources No.2 BOF. 

5-2 

annuai-NOx Efficiency of 

Emissions ~Ox Control 

419.2 at 

58%for most 

existing lowNOx burners 

454.2 at 

58% for most 

existing lowNOx bUrners 

513.4 · I at 

58% fo~ \most 

existing lowNOx burners 

14.3 N/A 

14.3 N/A 

9.7 at 

50% fu~; 

existing lowNOx burners in 

ind;~~~~q~~ed 

32.1 N/A 

(total of three 

sources) 

81! N/A 

(total of three 

sources) 

202.9 N/A 

(total of four 

sources) 

61.2 N/A 

(total of three 

sources) 

,,, 

E:i?s~on TestiRg 

Doc. 

See attached 

report 

summaryMarch 2003 

tests 

See attached 

report 

summaryMarch 2003 

tests 

see attached 

report 

summaryMarch 2003 

tests 

None 

None 

See attached 

report 

summaryFebruary 

2007 tests 

See attached 

report 

summaryNovember 

1994 tests 

See attached 

report 

summaryNovember 

1994 tests_ 

None 

None 
SECTION6 

REQUIRED PRODUCTION DATA FOR EACH APPLICABLE NOX SOURCE 

The rules also impose the following production data to be reported for each source, as 

summarized in Table 6-1. For sources listed for ArcelorMittal Cleveland in which the only 

emissions are the result of fuel burning activities, fuel usage is the parameter for determining the 

average and maximum "production" rates. 

Both the average and maximum daily NOx emissions for each source are based upon the 

highest average daily production rate for each ofthe three full calendar years (2004, 2005, and 

2006) preceding the effective data of this rule. Annual NOx emissions for each source are based 

upon the highest armual production rate for each of the three full calendar years (2004, 2005, and 

2006) preceding the effective data of this rule. 

6-1 
TABLE 6-1 . REQUIRED PRODUCTION DATA SOURCE INFORMATION 

Normal 

Operating Average Maximum 

Schedule Production Production 

(hours/day, (tons/day or (tons/day or 

Emission days/week, MMBtu/day MMBtu/day 

Unit# Source Descr:!J!!ion weeks/vea~) where noted\~ where noted)a 

P046 84-inch Not Strip 2417/52 4464 MMBtu min. 6924MMBtu 

Mill Furnace # l based on 2004 (Sept 2005) 

annual 

P047 84-inch Not Strip 2417/52 483('MMBtu min. 7028 MMBtu 

Mill Furnace #2 based on 2004 (Sept 2005) 

annual 

P048 84-inch Hot Strip 2417/52 5467 MMBtu min. 6880 MMBtu 

Mill Furnace #3 based on 2004 (July 2006) 

annual 

P049 84-inch Anneal 2417/52 798 MMBtu min 950 MlviBtu 

North based on 2004 (Sept 2004) 

annual 

P0 50 84-inch Anneal 2417/52 798 MMBtu min 959 Mlv!Btu 

South based on 2004 (Sept 2004) 

annual 

P07l Continuous 2417/52 438 Nllv1Btu min 25,257 MMBtu 

(Hot Dip) Based on 2006 (June, 2006) 

Galvanizing Line annual 

P903 C5 Blast 2417/52 3816 tons min 267,838 tons 

Furnace: Stoves, based on 2004 (May 2006) 

Flare, and annual (both fumaees) 

Casthouse 

P904 C6 Blast 2417/52 3531 tons min 267,838 tons 

Furnace: Stoves, based on 2006 (May 2006) 

Flare, and 

annual (both furnaces) 

Casthouse 

P905/ No.2 BOF: 2417/52 7706 tons min 274,561 tons 

P906b Vessels, Ladle based on 2004 (Mareh, 2004) 

Preheaters, and annual 

Flare 

P925/ No, l BOF 2417/52 1975 tons min 74,896 tons 

P926' Vessels and Assume 330 days (January, 2006) 

Ladle Preheaters in 2006 

' See attached ArcelorMtttal Cleveland NOx RACT InformatiOn and CalculatiOns. 

b ArcelorMittal Cleveland has renamed these sources No, l BOF. 

'ArcelorMittal Cleveland has renamed these sources No.2 BOF. 

6-2 

Annual 

Production 

(tons/yr or 

MMBtu/y;

1

;vhere Type of Control 

noted a Eauinment 

1,633,850 MMBtu Low~NOx burners-

(2004) preheat and heat 

zones 

1,770,175 MMBtu Low~NOx burners -

(2004) heat zones 

2,000,800 Low~NOx burnersMMBtu (2004) preheat and heat 

zones 

292,125 MMBtu None 

(2004) 

292,125 MMBtu None 

(2004) 

128,433 MMBtu Low NOx burners in 

(2006) indirect fired section. 

1,396,775 tons None 

(2004) 

I ,288,924 tons None 

(2006) 

2,820,292 tons None 

(2004) 

65 I ,683 tons None 

(2006) 
SECTION7 

NO, CONTROL TECHNOLOGIES THAT ARE~ APPLICABLE OR 

TECHNICALLY FEASIBLE AT ARCELORMITTAL CLEVELAND 

As discussed in Section 2, at least 18 NOx control technologies are to be evaluated for the 

NOx RACT Engineering Study. Many of these technologies are not applicable to the facility. 

Several of these control technologies apply to boilers only. Because no RACT Engineering 

Study is required for the boilers, however, many will simply not be applicable. Other 

technologies are better suited for operations such as gas turbines and ships. 

Other than BOF vessel process emissions and the blast furnace stove burners, the 

remaining applicable sources at ArcelorMittal Cleveland involve essentially natural-gas-fired 

burners ranging from less than 1 MMBtulhr to 20 MMBtulhr in size. In some cases that will be 

discussed later in the document, low~NOx and Ultra-low-NOx burners have already been 

installed to replace conventional or standard burners. For those sources, ArcelorMittal Cleveland 

believes that no further investigation ofNOx alternative control technologies is needed, and that 

NOx RACT has been satisfied. 

The following is a summary of the NOx control technologies that are not applicable or 

are technically infeasible at ArcelorMittal Cleveland. 

7.1 Close Coupled or Separate Over-Fire Ports 

Over-fire air (OFA) is a type of stage combustion. With OFA, the burners are fired more 

fuel-rich than normal, and the additional air needed to complete combustion is admitted through 

overfire air ports or an idle row of burners. This technique is applicable to all fuels. 

In this technique a controlled portion of the total combustion airflow, typically 10 to 20 

percent, is directed through over-fire ports located above the highest elevation of burners in the 

furnace. The removal of airflow from the burners results in a fuel-rich primary combustion zone 

to limit the NOx formation. The combustion of the CO produced in the primary combustion 

zone is completed using the air supplied by the over-fire air ports. In most cases, new furnaces 

penetrations are required to implement an over-fire air system in an existing furnace. For the 

7-1 
remaining NOx emission sources, this approach could not be adapted to these operations and is 

deemed technologically infeasible. 

7.2 Flue Gas Recirculation (FGR) 

This method of combustion uses flue gas recycled from the stack and mixed with 

combustion air to reduce the oxygen content of the combustion air and cool the flame. The 

' 

target percentage of the total combustion airflow to be replaced with recirculated flue gas is 

typically 10 to 15 percent. This control technique has been used with gas-fired and oil-fired 

furnaces. 

Additional external FGR is added to enhance NOx control in some furnace installations. 

Flue gas recirculation is implemented by recycling a portion of the flue gas to the primary 

combustion zone. It reduces NOx formation by two mechanisms. The recycled flue gas contains 

combustion products that act as inerts during combustion and lower the peak flame temperature, 

reducing thermal NOx formation. To a lesser extent, FGR also reduces thermal NOx formation 

by lowering the oxygen concentration in the primary flame zone. These factors lower flame 

temperature, altering heat distribution and reducing fuel efficiency. 

For the remaining NOx emission sources, this approach could not be adapted to these 

operations and is deemed techno logically infeasible. 

7.3 Burners Out of Service (BOOS) 

Burners out of service is a simple technique to achieve NOx reductions of around 15 

percent in multiple burner level furnaces with multiple levels of burners. In this technique, fuel 

flow is isolated from selected burners and only air passes through the burners. The balance of 

the fuel required to maintain the unit firing rate is redirected to other burners. This technique 

provides for air and fuel staging in the combustion zone. Depending on the capacity margins in 

the existing burner design, a slight furnace de-rate penalty may result. The specific capacity of 

the pulverizers will also affect the implementation of this technique in coal-fired furnaces. This 

technique has been applied successfully on many industrial boilers in the United States. Higher 

7-2 
CO emissions and oxygen imbalances may result from this technique. These conditions can be 

minimized by selecting the appropriate burners to be removed from service. 

This approach could not be adapted for the remaining NOx emission sources because of 

their maximum continuous or subsequent firing rates; therefore, it is deemed technologically 

infeasible. 

7.4 Steam/Water Injection 

Water or steam traditionally has been injected into combustion turbines to reduce the 

firing temperature and thereby minimize NOx emissions. This combustion control technology, 

however, has also been applied to furnaces. Adding water or steam in the combustion zone can 

suppress NOx formation by up to 25 percent. 

The use of water/steam injection to control NOx emissions has several disadvantages. 

Carbon monoxide and unburned hydrocarbons increase, especially at low loads. Fuel 

consumption increases by as much as 5 percent to make up for the heat of vaporization of the 

water. If steam injection is utilized, about 50 percent higher mass rate is required compared to 

water injection and there is an inherent loss of energy that is required to produce the steam. 

Additionally, water that has been extensively treated is lost out of the stack. 

For the remaining N Ox emission sources, this approach could not be adapted to these 

operations and is deemed technologically infeasible. 

7.5 Dry Low NOx Combustion Systems 

Dry Low NOx (DLN) combustors have been used to reduce NOx emissions from naturalgas-fired heavy duty gas turbines since the early 1990s. These two-stage premixed combustors 

are designed for use with natural gas and capable of operation on liquid fuel. The combustion 

system includes four major components: fuel injection system, liner, venturi, and cap/center 

body assembly. The configuration of these units is only adaptable to gas turbines, which the 

facility does not possess. 

7-3 
7.6 Ignition Retard 

Ignition timing in an internal combustion engine is the process of setting the time that a 

spark will occur in the combustion chamber (during the power stroke) relative to piston position 

and crankshaft angular velocity. Timing retard refers to the number of degrees that ignition is 

delayed after the point that would have resulted in generating maximum power. The facility 

does not possess internal combustion engines for which this approach could be evaluated. 

7.7 Separate-Circuit After Cooling 

Separate-Circuit After Cooling is another technology that has been applied to ships. The 

freshwater circuit is self-contained and is used continuously to cool the engine. The facility does 

not possess such equipment for which this technology could be applicable. 

7.8 Selective Noncatalytic Reduction (SNCR) 

Selective non-catalytic reduction involves the injection of ammonia or urea into a region 

where the gas temperature is in the range of 1500 to 21 00°F. At lower flue gas temperatures, the 

reaction rate will decrease resulting in higher levels ofNOx and increased ammonia slip (unreacted ammonia). At higher flue gas temperatures, not only will the effectiveness of the reagent 

reaction with NOx be diminished, but increased NOx levels may occur due to the oxidation of 

the reagent. 

The objective of the system is to deliver the required reagent in the temperature window 

with sufficient residence time for the required reaction to occur. The minimum residence time 

required is 1 second. The design of the reagent injector and the specific injection locations are 

therefore an important part of the SNCR system design. 

Complete coverage of the flue gas in the furnace requires that multiple injection nozzles 

be used in the SNCR design. Multiple injection ports can be provided either by installing 

multiple injectors or retractable lances with multiple nozzles. To maximize NOx reduction and 

minimize reagent slip, it is often necessary to vary the injection rate to each nozzle location as 

boiler load changes. 

7-4 
This approach was investigated for the three reheat furnaces. The added equipment 

needed to heat the gases to over 1500°F, take off the existing exhaust stacks, and replace them 

with SNCR units and new stacks on the existing Hot Strip Mill roof was deemed technologically 

infeasible for RACT purposes. For the remaining NOx emission sources, this approach could 

not be adapted to these operations and is deemed technologically infeasible. 

7.9 Non-Selective Catalytic Reduction (NSCR) 

This three-way catalyst technology has been developed to control carbon monoxide, 

hydrocarbons, and NOx emissions from rich-burning engines used in gas compression, irrigation, 

pumping, and power generation. It has also been used to control tail-gas emissions from nitric 

acid manufacturing plants. The facility does not possess such equipment for which this 

technology could be applicable. 

7.10 Fuel Emulsification 

This innovative NOx technology has been used on ships, primarily on the West Coast, to 

reduce NOx emissions as much as 40 percent. This process injects water into the fuel burned by 

the ship's engine with appropriate in-cylinder controls. Water is used in the combustion process 

to lower maximum combustion temperature, and therefore lower NOx formation, with an 

insignificant increase in fuel consumption. This technology can also be applied to a wide variety 

of smaller displacement diesel engines. The facility does not possess such equipment for which 

this technology could be applicable. 

7.11 Incineration (for sources other than boilers) 

This technology, for example, could apply to paint lines within steel mills which would 

contain high VOC concentrations that would be destroyed through incineration, with some minor 

benefit ofNOx reductions. Hazardous waste incinerator manufacturers have developed artificial 

intelligence-based NOx control systems. The facility does not possess paint lines or hazardous 

waste incinerators in which this approach could be evaluated. 

7-5 
7.12 Scrubbing (for sources other than boilers) 

Scrubbing using urea or the addition of hydrogen peroxide within the pickling baths of 

stainless steel operations is effective for the control and suppression of the highly visible N02• 

This facility does not use nitric acid as a pickling acid at its pickle line, and hence this 

technology is not applicable. 

7.13 Process Modification 

Process Modification is not an option at ArcelorMittal Cleveland. There are no 

alternative technologies for the remaining NOx sources (blast furnaces, BOFs, reheat furnaces, 

annealing furnaces, and ladle pre heaters). 

7.14 Low Excess Air 

Low excess air (LEA) is a combustion modification technique in which NOx formation is 

inhibited by reducing the excess air to less than normal ratios. It reduces the local flame 

concentration of oxygen, thus reducing both thermal and fuel NOx formation. It can be used for 

all fuels and all firing methods. It is easily implemented and can be used in both new and retrofit 

applications. 

The potential of LEA as an NOx control technique is limited by the onset of smoke or 

CO emissions. Tests on utility boilers have indicated that LEA firing can reduce NOx emissions 

between 16 and 21 percent as compared to baseline levels. Other sources have suggested 

reductions of up to 16 percent. In the case of utility boiler applications, LEA also increases 

thermal efficiency. It decreases the volume of combustion air to be heated, allowing more heat 

of combustion to be transferred, thus lowering fuel requirements for a given output. To maintain 

proper control ofthe furnace pressure, positive pressure must be maintained in the furnace to 

prevent the influx of tramp air. A number of other factors affect the excess air levels that can be 

implemented. These include the type of fuel fired, uniformity of the air/fuel ratio, air and fuel 

control lags during load swings, and other combustion control features such as staging of fuel or 

air. 

7-6 
Due to quality and fuel penalty considerations for the remaining NOx emission sources, 

this approach could not be adapted to the operation and is deemed technologically infeasible. 

7.15 Gaseous Fuels Reburn 

Reburn was developed as an NOx combustion control technique primarily for use on 

coal-fired furnaces. This technique involves splitting the combustion zone by installing a second 

level of burners above the primary combustion zone. Typically, up to 25 percent of the total heat 

input is injected into this "reburn" zone to create a fuel rich condition in the primary combustion 

zone. In the reburn zone, NOx formed in the combustion zone is partially reduced to elemental 

nitrogen. The formation of additional NOx is limited due to the lower oxygen concentrations 

and lower combustion temperature in the reburn zone. 

Most installations employing reburn for NOx control have used natural gas as the reburn 

fuel above a coal-fired combustion zone. However, micronized coal has also been used as the 

reburn fuel. Reb urn combustion requires significant changes to the design of the furnace and the 

additional operating expense of the reb urn fuel. 

Due to quality and fuel penalty considerations for the remaining NOx emission sources, 

this approach could not be adapted to the operation and is deemed technologically infeasible. 

7.16 Off-Stoichiometric or Staged Combustion (OSC) 

OSC reduces NOx generation by carrying out initial combustion in a primary fuel-rich 

combustion zone and subsequently completing combustion at lower temperatures in a second 

fuel-lean zone. This technique is essentially the control technique implemented through the use 

ofLNBs; however, it can be implemented using conventional burners by staging the combustion 

in the furnace or firebox rather than within the burner itself as is done with LNBs. 

In practice, OSC is implemented through biased burner firing (BBF), burners out of 

service, or overfire air. The latter two techniques have been previously discussed. In BBF, fuel 

distribution among the burners is redistributed so that the lower rows of burners are fired more 

fuel rich than the upper rows. The additional air needed to complete combustion is provided 

through the upper rows of burners, which are fired fuel-lean. 

7-7 
For the remaining NOx emission sources, this approach could not be adapted to the 

operations and is deemed technologically infeasible. 

7-8 
SECTIONS 

GENERAL DISCUSSION OF POTENTIALLY FEASIBLE NO, CONTROL 

TECHNIQUES FOR THE REMAINING NOx SOURCES 

There are three fundamentally different mechanisms ofNOx formation. These 

mechanisms yield: thermal.NOx, fuel NOx, and prompt NOx. The thermal NOx mechanism 

arises from the thermal dissociation and subsequent reaction of nitrogen and oxygen molecules 

in combustion air. The fuel NOx mechanism arises from the evolution and reaction of fuelbound nitrogen compounds with oxygen. The prompt NOx mechanism involves the intermediate 

formation of hydrogen cyanide (HCN), followed by the oxidation ofHCN to NO. Natural gas 

and most distillate oils have no chemically bound fuel nitrogen, and essentially all NOx formed 

from the combustion of these fuels is thermal NOx. Residual oils and coal all have fuel-bound 

nitrogen, and when these are combusted, NOx is formed by all three mechanisms. Iron and steel 

mill processes tend to use gaseous fuels; i.e., natural gas and blast furnace gas, and oxygen; and 

the NOx generation tends to be thermal NOx. 

Control techniques for NOx emissions can be placed into one of two basic categories: 

(1) techniques designed to minimize NOx generation and (2) techniques to remove previously 

generated NOx from the gas stream. Combustion modification techniques such as low-NOx 

burners (LNBs) and flue gas recirculation (FGR) fit into the first category. Add-on flue gas 

treatment techniques such as selective catalytic reduction (SCR) and selective noncatalytic 

reduction (SNCR) are examples of the second. FGR and SNCR have already been ruled out as 

technologically infeasible for ArcelorMittal Cleveland. 

The following is a general discussion of low-NOx burners, selective catalytic reduction 

(SCR), and fuel switching. 

8.1 Low-NOx Burners 

Low-NOx burners (LNB) have been used since the early 1970s for thermal NOx control. 

The objective in the application of LNBs is to minimize NOx formation while maintaining 

acceptable combustion of carbon and hydrogen in the fuel. 

8-1 
In this combustion control technology, fuel and air are staged across the burner. A 

specific installation design can stage these combustion components either separately or in 

combination. The staging in the low-NOx burner results in "fuel-lean" and "fuel-rich" 

combustion zones in the furnace. In the "fuel-lean" zones, the combustion temperature is 

lowered, reducing the production ofNOx emissions. Both the temperature and oxygen 

concentrations are lowered in the "fuel-rich" zones. 

With air staging, normally 75 to 85 percent of the air is supplied to the primary 

combustion zone alone with all of the required fuel. This creates a "fuel-rich" flame zone where 

the formation ofNOx is retarded due to sub-stoichiometric (i.e., lack of oxygen to achieve 

completed combustion of the hydrocarbons in the fuel) combustion conditions. The substoichiometric conditions limit NOx formation by reducing the combustion temperature and 

limiting the amount of oxygen available for NOx production. The remainder of the air is injected 

outside the primary combustion zone to complete the combustion of the fuel. Low-NOx burners 

relying on staged air typically achieve NOx reductions of 40 to 50 percent in gas-fired furnaces 

and 30 to 40 percent for oil-fired and coal-fired furnaces. 

A low-NOx burner designed for fuel staging works the opposite of air staging. In the 

primary combustion zone, about 60 to 70 percent of the fuel is injected with all ofthe air. 

Although excess oxygen is available, NOx formation is retarded due to the low combustion 

temperature. The remainder of the fuel is injected downstream of the primary combustion zone. 

Prompt NOx formation is also reduced due to the highly oxidizing conditions across the burner. 

Staged fuel can reduce NOx formation by up to 60 percent for gas-fired boilers and heaters. 

r

---Contemporary low-NOx burners can safety operate with NOx emissions as low as 30 to 

50 ppmv. "Ultra-low" NOx burners can achieve NOx emissions of less than ~in certain 

gas-fired applications. Ultra-low NOx burners generally premix significant amounts of fuel and 

air, prior to injection into the furnace combustion zone. 

Low-NOx burners have potential application to the remaining NOx sources, as will be 

discussed later. 

8-2 
8.2 Selective Catalytic Reduction 

In an SCR system, ammonia (NH3) is injected into the exhaust gas stream upstream of a 

noble metal catalyst bed. The NH3 reacts with the NOx in the gas stream on the surface of the 

catalyst to form molecular nitrogen and water. The optimal reaction temperature for the SCR 

catalyst is 500° to 11 00°F. Properly designed, operated, and efficient SCR systems require a 

very stable gas stream with regard to flow rate, temperature, and NOx concentrations. 

Other parameters that can affect the performance of the SCR unit's catalyst are poisoning 

due to the presence of trace metals or other chemicals in the gas stream and fouling/plugging due 

to particulate emissions coating the catalyst. 

SCR could have potential application to the reheat furnaces and the Galvanizing Line 

armealing furnace, as will be discussed later. 

8.3 Fuel Switching 

The fuel order of greatest NOx formation on a lbs/MMBtu basis is coal, oil, natural gas, 

and then blast furnace gas. NOx emissions are considerably lower for blast furnace gas, which 

bums at a much lower flame temperature than natural gas. The utilization of the maximum 

available amount of blast furnace gas is always the objective of ArcelorMittal Cleveland because 

that fuel is generated on site. There is no need to perform an NOx RACT Engineering Study to 

address this existing ongoing operating practice to utilize as much blast furnace gas as possible. 

8-3 
SECTION9 

SOURCE-BY-SOURCE NOx RACT DISCUSSION 

9.1 Reheat Furnaces 

The total firing capacity ofeach reheat furnace is 602.6 MMBtulhr. Only natural gas can 

be fired in them. Each furnace has three unique zones: the preheat zone, heal zone, and soak 

zone. The preheat and heat zones have top and bottom sections. The top and bottom preheat 

zones have, 10 burners each, all rated at 16.9 MMBtulhr. The .top heat section has 8 burners each 

rated at 10.2 MMBtulhr. The bottom heat section has 10 burners each rated at 10.2 MMBtulhr. 

The soak zone has 18 burners each rated at 2.4 MMBtulhr, followed by 12 burners each rated at 

1.2 MMBtulhr, followed by 12 burners each rated at 1.95 MMBtulhr. 

The burners in the preheat and heat zones of each furnace are ~ratiye-~; i.e., they 

preheat the combustion air in order to increase fuel efficiency. The burners in the soak zones use 

cold combustion air. The temperature of the combustion air has a large impact on uncontrolled 

NOx emissions. Increasing the .. combustion air temperature from 1 00°F to 1 000°F will increase 

uncontrolled NOx emissions by a factor of about 4. ----w------~-~ ---• ~------" -~ -- - - --~;;;luation-~f th~ pot';;"uti~l-t~~b;;.~!ogi~-;;1 fe~ibill~y of SCR for each reheat furnace 

was performed. Each reheat furnace has a vertical exhaust stack venting through the top of the 

building that contains parallel roof monitors. It is not possible to install an SCR unit with an 

ammonia feed tank on the roof of this building. Likewise, the cost of replacing the existing 

\ 

I 

I 

stacks, then installing new stacks and ducts down to ground level, and utilizing three new S5/ 

units is cost prohibitive for RACT purposes; ·-·----·-·:::·.::::::::::::::.::::co"'~···-----==::_,-:::::: ... --------· 

// ___ .. __ Beta Steel ini~dlanaistheonly fa~iiity ~h~~has installed an SCR on a reheat furnace. 

This was at a Greenfield site and was the result of PSD BACT analysis. This unit has 

experienced problems over the years, and therefore no BACT evaluations since have supported 

the installation of SCR for reheat furnaces. 

9-1 
Within the past 2 years and in anticipation of this rulemaking, ArcelorMittal Cleveland 

has installed low-NOx burners throughout several zones of each of the three reheat furnaces. A 

summary of these installations follows: 

9.2 No. 1 Reheat Furnace 

In 2006 ArcelorMittal Cleveland replaced the 20 Bloom 1200 Series conventional 

burners in the p~~~at. :(:Qne and the 18 Bloom Series 1200 conventional burners in the heat zone 

with Bloom Series 1500 ultra-low-NOx burners. The 42 burners in the soak zone were replaced 

by more efficient, but conventional burners. ArcelorMittal Cleveland did not installlow-NOx 

burners in the soak zones because of the inherently reduced NOx concentration resulting from 

the use of cold combustion air. Additional information related to the soak zone burners is 

provided below. 

Priorstack testing of the source !Jdore·the burner changes resulted in a three-furnace 

average NOx emissions of,O.Sl lb/MMBta. Based on Bloom vendor information, the new 

''-. 

preheat and heat zone low-NOx burners should result in a 0.298lb/MMBtu reduction in NOx . ~ 

overall, or 0 .. 21211J/JylMBtu. Based on 2006 fuel usages for the furnace and actual capital and 

estimated installation costs, ArcelorMittal Cleveland calculates an annualized cost per actual ton 

ofNOx removed of$1048/ton as a result of the 2006 burner changes. Calculations are included 

in the Appendix. 

ArcelorMittal Cleveland believes that the 2006 burner changes in the preheat and heat 

zone sections clearly constitute thatNOx RACT was met at that time for those burners. . . ' 

Per Bloom vendor information, the new soak zone burners have expected NOx emissions --~ 

~~Btu. These are cold combustion air burners in which the NOx concentrations 

and emissions are inherently low. ArcelorMittal Cleveland believes that NOx RACT is not 

supported by the further installation oflow-NOx burners in the soak zone due to their inherently 

low NOx emissions. NOx emissions for the soak zone burners comprise approximately 4 to 5% 

of the total NOx emissions from the furnace. 

In accordance with OAC 3745-110-03 (I)(l), which allows ArcelorMittal Cleveland to 

recommend an "operating requirement" as an acceptable option to satisfy an NOx RACT 

definition, ArcelorMittal Cleveland recommends an "operating requirement" for the No. I 

Reheat Furnace which restricts the use of burners to only those that are equal to or less than the 

9-2 
existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes an NOx RACT ·· .~ '-~---'-·"":'- ' 

expected NOx emission factor of0.,4;4lb/MMBtu for the No. 1 Reheat Furnace based on vendor- .. ,._;..- . ) 

expected NOx performance/and a twenty-five percent contingencyf;lctor. See attached -- -·-"' ·-~.::;.:~~~::~';;:'-~-·--=-

calculations supporting the proposed expected N Ox emission factor. 

9.3 No.2 Reheat Furnace 

~---~~celorMittal Cleveland replaced the 18 Bloom 1200 Series conventional 

I burners in the heat zone with North Aroerican 482 LNI- 14 x 848 low-NOx burners. The 42 I burners in the soak zone were replaced by more-efficient, but conventional burners. I ArcelorMittal Cleveland did not installlow-NOx burners in the soak zones because of the 

inherently reduced NOx concentration resulting from the use of cold combustion air. No burners 

lb/MMBtu. Based on 2007 fuel usages for the furnace (first full year of operation) and actual 

··l ~ capital and estimated installation costs, ArcelorMittal Cleveland calculates a cost of $1766/ton of 

·~ •. ~Ox removed. Calculations are included in the Appendix. ArcelorMittal Cleveland believes 

th~it~(rioo7··~urner changes in the heat zone sections clearly constitute that NOx RACT was '-...[""-,.=::::·-:'::':: 

met at that time for those burners. 

According to Bloom vendor information, the new soak zone burners have expected NOx 

emissions of 0.0~6 11;>/MMB~. These are s_~,t~combustion air burners in which the NOx 

concentrations and emissions are inherently low. ArcelorMittal Cleveland believes that NOx 

RACT is not supported by the further installation of !ow-N Ox burners in the soak zone due to 

their inherently low NOx emissions. NOx emissions for the soak zone burners comprise 

approximately 4 to 5% of the total NOx emissions from the furnace. 

ArcelorMittal Cleveland also determined the cost per ton ofNOx removed for the preheat 

zone. Based on Bloom vendor information, the new preheat and heat zone low-NOx burners 

should result in a 0.298 lb/MMBtu reduction in NOx overall, or 0.212 lb/MMBtu. Again, based 

on 2006 fuel usages for the furnace and actual capital and estimated installation cost, 

9-3 

J 

0 
ArcelorMittal Cleveland calculates a cost per actual ton ofNOx removed based on the 

installation of low-NOx burners for the preheat zone to be $824/ton. Calculations are included in 

the Appendix. 

NOx RACT supports the installation oflow-NOx burners in the preheat zone ofthe No.2 

Reheat Furnace. 

In accordance with OAC 3745-110-03 (!)(!),which allows ArcelorMittal Cleveland to 

recommend an "operating requirement" as an acceptable option to satisfy an NOx RACT 

definition, ArcelorMitta1 Cleveland recommends an. "operating requirement" for the No. 2 

Reheat Furnace which restricts the use of burners to only those burners that are equal to or less 

than the existing manufacturer's NOx specification for the heat zone and soak zone and is equal 

or less than the proposed low-NOx burner manufacturer's NOx specification to be installed in 

the preheat zone. Because the current North American burners in the heat zone have resulted in . ' 

performance problems in this application, ArcelorMittal Cleveland reserves the right to replace 

these burners with l;mrners that are equal to or less than the existing manufacturer's NOx 

specification of non-North American burners installed in the heat zone ofNo. 1 or 3 Reheat 

Furnaces that are proposed as satisfying the NOx RACT definition, e.g., Bloom Series 1500 

ultra-low-NOx burners or equivalent. ArcelorMittal Cleveland proposes an NOx RACT_ 

expected NOx emission factor of 0.24.lb/MMBtu for the No. 2 Reheat Furnace based on vendorexpected NOx performance and ~~ftYp$~entco~inge_!!CY ~actor to be consistent with the 

proposed NOx RACT expected emission factor of the other two reheat furnaces. The 

contingency factor is based on the current, unique utilization of a combination of multiple burner 

manufacturers within the same furnace, prior operating experience with the North American 

burners that were replaced with non-North American burners and to be consistent with the 

proposed NOx RACT expected emission factor of the other two reheat furnaces. See attached 

calculations supporting the proposed expected NOx emission factor. 

9.4 No. 3 Reheat Furnace 

c!j120~elorMittal Cleveland replaced the 20 Bloom 1200 Series conventional 

burners in the preheat zone and the 18 Bloom Series 1200 conventional burners in the heat zone 

with Bloom Series 1500 ultra-low-NOx burners. The 42 burners in the soak zone were replaced 

9-4 
by more-efficient, but conventional burners. ArcelorMittal Cleveland did not installlow-NOx 

burners in the soak zones because of the inherently reduced NOx concentration resulting from 

the use of cold combustion air. 

Prior stack testing of the ofu~~before the burner changes resulted in a three-furnace 

average NOx emission o ().51 lb MMBtu. Based on Bloom vendor information, the new 

preheat and heat zone low-NOx burners should result in a 0.298 lb/MMBtu reduction in NOx 

/---·ovefa11, or0.212lb/MMBtu. Based on 2006 fuel usages for the furnace and actual capital and 

estimated installation costs, ArcelorMittal Cleveland calculates an annualized cost of $11 04 per 

actual ton ofNOx removed as a result of the 2006 burner changes. Calculations are included in 

the Appendix. 

· .• 

ArcelorMittal Cleveland believes that t~9J~brlrner changes in the preheat and heat 

zone sections clearly constitute that NOx RACT was met at that time for those burners. 

According to Bloom vendor information, the new soak zone burners have expected NOx 

~~i~~ions of0.056 lb/M¥Btu. These are cold combustion air burners in which the NOx 

concentrations and emissions are inherently low. ArcelorMittal Cleveland believes that NOx 

RACT is not supported by the further installation oflow-NOx burners in the soak zone due to 

their inherently low NOx emissions. NOx emissions for the soak zone burners comprise 

approximately 4% of the total NOx emissions from the furnace. 

In accordance with OAC 3745-110-03 (I)(!), which allows ArcelorMittal Cleveland to 

recommend an "operating requirement" as an acceptable option to satisfy an NOx RACT 

definition, ArcelorMittal Cleveland recommends an "operating requirement" for the No. 3 

Reheat Furnace which restricts the use of burners to only those burners that are equal to or less 

than the existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes an NOx 

' ' 

RACT expected NOx emission factor 0.24 lb/MMBtu for the No. 3 Reheat Furnace based on ' ' ' ~_,..=~·-· 

vendor-expected NOx performance and a t~enty-fiye £ercejlt contingency factor. See attached 

calculations SUj)porting the proposed expected NOx emission factor~ 

9.5 Batch Annealing 

In general, annealing furnaces, whether continuous or batch, subject steel products to a 

planned time-temperature profile in a reducing atmosphere with heating supplied from gas-fired 

9-5 
radiant tube burners. The continuous annealing process produces a softened steel desired for its 

heightened formability. 

At ArcelorMittal Cleveland, there are currently 77 operational and 9 spare batch 

annealing furnaces at the North Annealing and South Annealing sections. Each furnace contains 

eight burners for a total furnace capacity of2.4 to 2.7 MMBtulhr. The annealing furnaces are 

fired in the following sequence: 16 hours at maximum firing rate, followed by 32 hours at 20% 

maximum firing rate (soak), and then 4 hours on cool down (no fuel). 

From a potential emissions standpoint, annual NOx emissions are believed to be less than 

25 tons per year for each source, but greater than 25 tons per year with both sources combined. 

As such, ArcelorMittal Cleveland considers their applicability under this rule to be questionable. 

However, ArcelorMittal Cleveland will consider these sources to be applicable under this study. 

All the batch annealing furnaces bum natural gas exclusively and contain burners 

manufactured by North American. Because the emissions of the batch annealing furnaces are 

fugitive in nature, SCR is immediately ruled out. 

Based on information provided by North American, the existing 4422-4 burners have 

inher~ntly low NOx emissions (0.1 0 lb/MMBtu). This value is identical to the already accepted 

more stringent BACT (Best Available Control Technology) value in Indiana based on AK 

Rockport Works batch annealing furnace low-NOx burners. A value of0.10 lb/MMBtu is also 

the most common one posted on the EPA BACT/LAER Clearinghouse. 

A low-NOx burner manufactured by North American was also investigated. This burner 

is not the same configuration and size of the existing burner, however, and thus substantial 

modifications would be needed. As such, ArcelorMittal Cleveland believes that NOx RACT is 

satisfied by the installation of the existing burners, and no additional controls are proposed. In 

accordance with OAC 3745-110-03 (!)(1), which allows ArcelorMittal Cleveland to recommend 

an "operating requirement" as an acceptable option to satisfy an NOx RACT definition, 

ArcelorMittal Cleveland recommends an "operating requirement" for the batch annealing 

furnaces which restricts the use of burners to only those burners that are equal to or less than the 

existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes an NOx RACT 

expected NOx emission factor of 0.10 lb/MMB~ based on the use of the existing NOx burners 

for this application. 

9-6 
9.6 Continuous (Hot Dip) Galvanizing Line (CGL) 

The Continuous (Hot Dip) Galvanizing Line includes a 159.17 MMBtulhr annealing 

furnace section. There is a direct fired section with a total of 98.60 MMBtulhr. These burners 

are manufactured by Selas. Following the direct-fired section, there are several hundred indirectfired radiant tube burners with a total of 60.57 MMBtulhr. These burners are manufactured by 

North American. 

Both SCR and low-NOx burners were evaluated. SCR is technologically feasible for a 

Greenfield site. Such a control device was built to control NOx emissions from an annealing 

furnace on a continuous hot-dip galvanizing line at AK Steel Rockport Works. However, 

Rockport was a Greenfield location and was part of a BACT PSD pennit approval process. 

For the ArcelorMittal Cleveland Continuous (Hot Dip) Galvanizing Line, it is cost 

prohibitive to install an SCR unit on the exhaust of the annealing furnace. The existing stack 

location was visually inspected as a result of this study. Two exhaust ducts (one from the directfired section and one from the radiant tube section) discharge into a common stack located inside 

the CGL Building. There are spatial considerations in the removal of the existing exhaust stack, 

subsequent relocation of the three ducts into a common duct, and relocation through an SCR unit 

and new exhaust stack on the outside of the building. ArcelorMittal Cleveland believes that the 

installation of SCR is technologically infeasible for NOx RACT purposes. 

North American was notified about its existing burners used on the indirect-fired section. 

It confirmed that their existing burners (Model No. 4325-5) are low-NOx burners. The expecte 

NOx loading is 0.27 to 0.30 lb/MMBtu. North American manufactures a new design low-NOx 

radiant tube burner with flue gas recirculation at 0.25 lb/MMBtu. North American has indicated 

that it would be impractical and cost prohibitive to replace the existing radiant tube burners with 

the newer burners simply for purposes ofNOx reduction. ArcelorMittal Cleveland concurs with 

North American's opinion on this matter. As such, ArcelorMittal Cleveland believes that 

existing North American 4325-5 burners represent NOx RACT for the indirect-fired section. 

Low-NOx burners for the direct-fired section were investigated. Based on information 

obtained from Selas Furnace, the expected NOx emissions from the existing conventional 

burners are 0.104 lb/MMBtu for their 7018 model or 0.156\b/MMBtu for their DNHA model. 

Based on Selas vendor information, newer low-NOx burners for this direct-fired section are sized 

9-7 
differently than the existing burners, and their installation would require a complete rebuild of 

this furnace section. As such, ArcelorMittal believes that the existing Selas burners represent 

NOx RACT for the direct-fired section. 

In accordance with OAC 3745-110-03 (I)(l), which allows ArcelorMittal Cleveland to 

recommend an "operating requirement" as an acceptable option to satisfy an NOx RACT 

definition, ArcelorMittal Cleveland recommends an "operating requirement" for the Continuous 

(Hot Dip) Galvanizing Line annealing furnace which restricts the use of burners to only those 

burners that are equal to or less than the existing manufacturer's NOx specification. 

ArcelorMittal Cleveland proposes an NOx RACT expected NOx emission factor ofQ.23 _ 

lb/MMBtu applicable to the single furnace exhaust stack that includes the combination of both ,,..-.-·----··~--. ' 

furnace sections. This is the. existing NOx limit for this source. A stack test conducted on 

February 16, 2007 and submitted to the City of Cleveland provided the NOx results of 0.15 lb 

perMMBtu. 

9. 7 Blast Furnaces Stoves 

Blast furnace stoves are an NOx emission source because they consume large quantities 

of fuel. At ArcelorMittal Cleveland's two blast furnaces, however, the only fuel utilized is BFG, 

which has a low heating value and contains inerts, factors that reduce flame temperature. Thus, 

the NOx concentration in blast furnace stove flue gas tends to be low and the potential for NOx 

reduction is considered to be small. Attached to this study are stack testing results confirming 

this fact. 

As such, ArcelorMittal Cleveland considers RACT to have already been satisfied with 

the use of blast furnace gas as the only fuel. In accordance with OAC 3745-110-03 (I)(l), which 

allows ArcelorMittal Cleveland to recommend an "operating requirement" as an acceptable 

option to satisfy an NOx RACT definition, ArcelorMittal Cleveland recommends an "operating 

requirement" for the blast furnace stoves which restricts the use of burners to only those that are 

equal to or less than the existing manufacturer's NOx specification. ArcelorMittal Cleveland 

proposes an NOx RACT expected NOx emission factor of0.06lb/MMBtu based on prior testing ----------·-··-·-·--· 

results and a 25% typical engineering contingency. See attached calculations supporting the 

proposed expected NOx emission factor. 

9-8 
9.8 Blast Furnaces Casthouses 

Both blast furnaces utilize flame suppression to minimize the formation of particulate 

emissions during casting. Natural gas is used as the fuel for flame suppression for both blast 

furnaces. The gas is directed toward the ends of pipes and then ignited. There are no burners per 

se. As such, there are no potential NOx controls available, and no NOx RACT operating 

requirements are proposed. 

9-9 
9.9 Blast Furnaces Flares 

Similar to the stoves, ArcelorMittal Cleveland considers NOx RACT to have already 

been satisfied with the use of blast furnace gas as the only fuel. No post combustion controls 

after the flares are technologically feasible. As such, there are no potential NOx controls 

available, and no NOx RACT operating requirements are proposed. 

9.10 BOF Vessels 

The basic oxygen furnace process of steelmaking is an exothermic process that does not 

require the burning of fossil fuels. The process does produce an off-gas which is burned prior to 

discharge to the atmosphere. Some BOF facilities use suppressed combustion hoods, which 

suppress the influx of air, and the off-gases are subsequently flared. A potential for NOx 

generation does exist during the combustion of the waste gases. Nitrogen oxides production 

from this process had been estimated to range from. 30 to 180 ppm, or 0.36 to 1 lb NOx per ton 

of steel produced. 

-~ The combustion of the waste gas results in the generation ofNOx. There are no existing 

BOFs in the United States (and to the best of ArcelorMittal Cleveland's knowledge, the world) 

that have any kind ofNOx emission controls. Nor are any control techniques even suitable or 

feasible. Outlet temperatures from an electrostatic precipitator (ESP) are too low for SCR to be 

feasible. Although the temperatures for SNCR may be suitable for a short period of time prior to 

the control equipment, the large amount of particulate matter (estimated at 50 lbs/ton of steel 

produced prior to the control equipment) makes any post-combustion control infeasible. 

ArcelorMittal Cleveland utilizes both types of furnaces in their two BO Shops. The two 

No. 1 ~OF vessels (P925/P926, which were renamed as No. 2 BOF by ArcelorMittal Cleveland) 

are open hood (CO) systems controlled by an ESP (for PM), and the two No.2 BOF vessels 

(P905/P906, which were renamed as No. I BOF by ArcelorMittal Cleveland) are suppressed 

combustion systems controlled by venturi scrubbers (PM) and flares (CO). For the open-hood 

vessels, the combustion occurs at the mouth of the vessel into the hood. For closed-hood vessels, 

the combustion occurs at the flare. 

Properly designed, operated, and efficient SCR systems require a very stable gas stream 

with regard to flow rate, temperature, and NOx concentrations. These stable conditions rarely 

9-10 
exist in BOF exhaust gases. The highly variable exhaust gas stream can be attributed to the 

distinct cycles (tap and charge, blow) of furnace operation. 

Because SCR catalysts require high gas stream temperatures ( 500 to 11 00°F), the gas 

stream for the scrubber applications would have to be reheated from about 180°F to the proper 

operating temperature for the catalyst. This would require a huge energy penalty (probably 

natural gas combustion) and result in additional NOx emissions, along with CO and C02 

emissions. Additionally, if the exhaust gas temperature drops below the SCR catalyst range, 

unreacted arnrnonia (referred to as "ammonia slip") would be emitted directly to the atmosphere. 

Other parameters that can affect the performance of the SCR unit's catalyst are poisoning 

due to the presence of trace metals or other chemicals in the gas stream and fouling/plugging due 

to particulate emissions coating the catalyst. The batch-wise operation of a BOF vessel 

inherently results in highly unstable conditions for these parameters. During typical scrap melt 

cycles, the BOF exhaust gases can range from 300° to 3000°F. In addition, this temperature 

variability adversely affects the stability of airflow volume and NOx generation. Further, the 

SCR catalyst bed could not resist elevated exhaust gas temperatures and would also be clogged, 

blinded, or poisoned by the particulate in the dirty exhaust gases. The instability of gas flow, 

temperature, NOx concentration, and potential catalyst fouling make SCR technically infeasible. 

As such, no NOx RACT operating requirements are proposed for the BOF Shop vessels 

and flare emissions. 

9.11 Ladle Preheaters 

The ladle preheaters at both BOF Shops range in size from 8 to 15 MMBtulhr. None of 

the individual preheaters have the potential to emit greater than 25 tons NOx per year. 

Collectively, however, they have the potential to emit more 25 tons NOx per year. 

All existing ladle preheaters at both BOF Shops bum natural gas exclusively and utilize 

North American Magna Flame burners. Because the emissions from the preheaters are fugitive 

in nature, SCR is immediately ruled out. 

Based on information provided by North American, the Magna Flame burners have 

inherently low NOx emissions (0.08 and 0.097 lb/MMBtu). A newer design low-NOx burner 

was investigated. However, it is technologically infeasible to install this burner because of the 

difficulty in maintaining a tight seal at the interface ofthe burner with the ladle lid opening. As 

9-11 
such, ArcelorMittal Cleveland believes that NOx RACT is satisfied by the installation of the 

existing burners, and no additional operating requirements are proposed. ArcelorMittal 

Cleveland proposes a NOx RACT expected NOx emission factor of 0.10 lb/MMBtu based on the 

use of existing low-NQx burners for this application. 

9-12 
SECTION 10 

Table I 0-1 presents a summary of the NOx RACT recommended controls and operating 

requirements that were evaluated and then chosen. In addition, this table includes the proposed 

NOx RACT expected emission factor for each applicable source. 

TABLE 10-1. NO, RACT RECOMMENDED SELECTION AND PROPOSED NO, 

RACT EMISSION FACTOR FOR APPLICABLE SOURCES AT 

ARCELORMITTAL CLEVELAND 

Description Operating Requirements Emission Factor 

Selected F-~~-+~~~~~+-~~~~~~~~~~~~~~~~~~-~--~-~----~---~-~-~1 

P046. Reheat Fee #I LNBs, SCR Existing LNBs in heat and _094 lb/MMBtu 

Emission 

Unit# 

Feasible NOx Controls 

Evaluated 

preheat zones. Existing 

,. 

NOx RACT Controls & Expected NOx .' 

1

/ 

lr-=::-:-::-+--::-:---:::-=-+----::-=::-=::::---+--2:burn"7''7er"'s..:;in:;:-:.:so:;:a:::k-cz:::.on;:.e:.:s.;... -t,--::e·':::·...,·..,..,==-'-1-1l,'l 1. , , 1,, , P047_ Reheat Fee #2 LNBs, SCR Existing LNBs in heat < .. 0.241b/MMBtu) ' ,.,_,_ .. , ... rv· iF~ ' 

zones. Proposed new .::.::.: ·--~-- ~~....-- !Jr·~IA c,{y 

LNBs in preheat zone. _ "---~ r ..JI ,o; ·\-wA 1'/ 

Existing burners in soak 

P048 Reheat Fee #3 LNBs,SCR 

zones. 

Existing LNBs in heat and 

preheat zones .. Existing 

burners in soak zones. 

0.24 lb/MMBtu " ~_...-/ 

P049 Anneal- North LNBs Existing burners. 0.10 lbiMMBtu -"'" ~-~~-t-'.;:.:.:.:.:::::;c....;,C"":;.:-t-~-""'"""'~~---+--.;:;::7"7"""'::""="--+-7;.:::-;~~~'-----ll ,,~. P0 50 Anneal - South LNBs Existing burners. 0. I 0 lb/MMBtu 

P071 Continuous LNBs, SCR Existing LNBs for the 0.23 lb/MMBtu '- i..M; 5 r •. , 1 

I--=:=-+'G::.:a::.lv:;a;.:;n~iz;cinC'g,.,L:::i:::n:::.e+=o;:;--c-""""-=:;:;---;:-!--:::'a;;:nn;;:e::;:a:::li:cng"-"fur'7'na:;c;.::e:.,. -+-;;-=-;;-c::-:::=,--1l .- ~ , •. u7 

P903 CS Blast LNBs, burning BFG only BFG is the only fuel 0.06 lb/MMBtu "'" .i oJ{' "' 

P904 

P905/ 

P906 

P925/ 

P926 

Furnace: Stoves, (stoves) burned (stoves) 

Flare, and None feasible for the flare 

Casthouse and casthouse. 

C6 Blast LNBs, burning BFG only 

Furnace: Stoves, (stoves) 

Flare, and None feasible for the flare 

Casthouse and casthouse. 

No.2 BOF: LNBs (ladle preheaters). 

Vessels, Flares, None feasible for the 

and Ladle vessels and flares. 

Pre heaters 

No. I BOF 

Vessels and 

Ladle Preheaters 

LNBs (ladle preheaters). 

None feasible for the 

vessels. 

10-1 

BFG is the only fuel 

burned 

(stoves) 

Existing burners for ladle 

preheaters. LNBs not 

technologically feasible 

for process contra I. 

Existing burners for ladle 

preheaters. LNBs not 

technologically feasible 

for process control. 

\ 

0.06 lb/MMBtu 

0 .I 0 lb/MMBtu 

0.10 lb/lY1MBtu 
SECTION l1 

SCHEDULE FOR INSTALLATION OF NOx CONTROL EQUIPMENT 

ArcelorMittal Cleveland proposes to installlow-NOx burners in the preheat zone of the 

No. 2 Reheat Furnace. Upon approval of Capital appropriations, vendor selection, procurement 

of the equipment, and installation and startup of the burners, ArcelorMittal Cleveland requests 

that the NOx control equipment (low-NOx burners) operational date be established as December 

12, 2009 per OAC 3745-110-04(B)(l)(a) for combustion modifications, including the installation 

oflow-NOx burners, contingent upon Ohio EPA Director approval per OAC 3745-110-03(I)(2) 

and reasonable approval notice provided to ArcelorMittal Cleveland Inc. by the Ohio EPA. 

Futhermore, ArcelorMittal Cleveland proposes to installlow-NOx burners in the preheat zone of 

the No. 2 Reheat Furnace based on the following schedule that provides additional clarification 

and interim milestones: 

A) Award Contracts by August, !, 2009, 

B) Initiate Construction by November 1, 2009 and 

C) Complete Construction by December 12, 2009; 

or complete construction oflow-NOx burners prior to resuming operation of No. 2 Reheat 

Furnace for any operation after December 12, 2009. 

11-1 
APPENDIX 
ARCELORMITTAL CLEVELAND NOx PTE EMISSSION CALCULATIONS 
ArcelorMittal Cleveland PTE NOx Emissions Calculations 

Page 1 
ArcelorMittal Cleveland PTE NOx Emissions Calculations 

Page2 
ArcelorMittal Cleveland PTE NOx Emissions Calculations 

Page3 
ArcelorMitlal Cleveland PTE NOx Emissions Calculations 

Page4 
ArcelorMittal Cleveland PTE NOx Emissions Calculations 

.. --·+ ----....... I 

-rUnless noted, emissions factors are either AP-42 based or historical emission factors. 

-_f -- -- 1 

Page 5 
ARCELORMITTAL CLEVELAND NOx RACT INFORMATION & 

CALCULATIONS 
12/11/2008 

ARCELORMITTAL CLEVELAND NOx RACT INFORMATION & CALCULATIONS 

EMISSION DESCRIPTION RATED FUELS BURNED NOx NOx <::;;{fE HO,./ FEASIBLE NOX COMMENTS 

UNIT# CAPACITY CONTROLS LIMITS EMISSIONS CONTROLS 

(MMBTU/HR) (TONS/YR) t1l 

8001 Boiler A 336 8FG/NG/Fuel Oil none N/A (under NOx 510.0 N/A, see comments Exempt under the rules because boiler 

SIP Call rules) is covered by the NOx SIP Call rules. 

8002 Boiler 8 336 8FG/NG/Fuel Oil none N/A (under NOx 510.0 NIA, see comments Exempt under the rules because boiler 

SIP Call rules) is covered by the NOx SIP Call rules. 

B003 Boilerc 336 8FG/NG/Fuel Oil none N/A (under NOx 510.0 N/A, see comments Exempt under the rules because boiler 

SIP Call rules) is covered by the NOx SIP Call rules. 

8004 Boilero 467 BFG/NG/Coal none N/A (under NOx 1469.1 N/A, see comments Exempt under the rules because boiler 

SIP Call rules) is covered by the NOx SIP Call rules. 

Has not operated for years. 

8005 Boiler 1 237.5 8FG/NG none N/A 284.2 N/A, see comments Will take presumptive NOx limits (0.10 

lbs/MM8TU) under the rule. 

8006 Boiler 2 237.5 BFG/NG none N/A 284.2 N/A, see comments Will take presumptive NOx limits (0.10 

lbs/MM8TU) under the rule. 

8007 Boiler 3 388 8FG/NG/Coal none N/A (under NOx 1221.3 N/A, see comments Exempt under the rules because boiler 

SIP Call rules) is covered by the NOx SIP Call rules. 

F016 Coal Thawing N/A NG none N/A 5.5 N/A, see comments PTE is < 25 tons/yr - exempt from rules 

& Unloading 

r'f?Q46 Reheat Fee #1 630 NG mostly low N/A 806 .. 4 See comments SCR clearly cost prohibitive and little 

' (actually 602.6) NOx burners additional NOx removed. No benefit to 

low NOx burners in soak zone. 

~d'_047 Reheat Fee #2 630 Np some low N/A 808.4 LNB SCR clearly cost prohibitive and little 

(actually 602.6) NOx burners (in preheat zone) additional NOx removed. No benefit to 

low NOx burners in soak zone. 

'!- P048 Reheat Fee #3 630 NG mostly low N/A 80f4 See comments SCR clearly cost prohibitive and little_~- ' .______ _____ , 

(actually 602.6) NOx burners additional NOx removed. No benefit to 

low NOx burners in soak zone. 

\'-... 
-----~ EMISSION DESCRIPTION RATED FUELS BURNED NOx NOx CeJ:ENOxL FEASIBLE NOX COMMENTS - - ---

UNIT# CAPACITY CONTROLS LIMITS EMISSIONS CONTROLS''' 

(MMBTU/HR) (TONSNR) 1'

1 

P049 Anneal - North 80 NG Conventional N/A 34.2 Existing burners PTE is unrealistic as they cant burn at 

burners low in NOx represent RACT. 100% load. Actually about43.07%. 

P0 50 Anneal- South 80 NG Conventional N/A 34.2 Existing burners PTE is unrealistic as they cant burn at 

burners low in NOx represent RACT. 100% load. Actually about 43.07%. 

P068 Continuous UNK NG none N/A 5.4 N/A, see comments PTE is < 25 tons/yr - exempt from rules 

Caster --------- ~ 

// 

. 

P071 _/·Continuous 159 NG low NOx c;;.23Jbs/MMBTU_./ 16.0.2 Existing burners SCR clearly cost prohibitive and little 

Galvanizing Line (formerly 173) burners for 160.2 tons/yr !!!£:: in indirect section additional NOx removed anyway. 

indirect section and direct section 

represents NOx RACT. 

;;:-~ ~Walking 613 NG none lbs/MMBU\ 283.6 N/A, see comments ill probably never operate again, and 

Beam Fee. ( & 1.2times the \ 1 exempt from rules due to lack of 

( actual firing rate ) 

P266 Continuous UNK NG none ~ 9.1 N/A, see comments ~-------- PTE is < 25 tons/yr - exempt from rules 

Caster 

P903 C5 Blasi Fee UNK BFG none N/A for all 51.2 not required since Applicable to the Stoves only. Burning 

Stoves/Flare (Stoves:) 17.8 burning BFG BFG (very low NOx) satisfies RACT. 

(Flare:) 10.1 represents NOx RACT 

P904 C6 Blast Fee UNK BFG none N/A for all 128.5 not required since Applicable to the Stoves only. Burning 

Stoves/Flare (Stoves:) 68.1 burning BFG BFG (very low NOx) satisfies RACT. 

(Flare:) 38.6 represents NOx RACT 

P905 No.2 BOF, UNK N/A none N/A 163.4 Existing ladle preheater 

No.1 Vessel (Ladle Preheaters:) 20.0 burners represent RACT. 

(Flare:) 1.0 

P905 No.2 BOF, UNK N/A none NIA 163.4 

No. 2Vessel (Ladle Preheaters:) 20.0 

(Flare:) 1.0 

P905 No.1 BOF, UNK N/A none N/A 89.2 Existing ladle preheater 

No. 94 Vessel (Ladle Preheaters:) 12.5 burners represent RACT. 

P905 No.1 BOF, UNK NIA none N/A 89.2 

No. 95 Vessel (Ladle Preheaters:) 12.5 

P073 VCP NG NG none none 5.9 N/A, see comments PTE is < 25 tons/yr - exempt from rules 

<

1

l Per ArcelorMittal Cleveland NOx PTE Emission Calculations. Emissions from highest fuel type selected. 

\ 
SPECIFIC REQUIRED INFORMATION FOR RACT ENGINEERING STUDY FOR REMAINING APPLICABLE SOURCES 

EMISSION DESCRIPTION MONTH/YEAR NORMAL ANNUAL PRODUCTION RATE 

UNIT# INSTALLED OPERATING (TONS/YR or MMBTU/YR) UNITS 

SCHEDULE 20041

" 2oos1

'

1 2006 

P046 Reheat Fee #1 Jun-70 24/7/52 1,633,850 1,493,425 1,512,900 MMBTU 

P047 Reheat Fee #2 Jun-70 2417/52 1,770,175 1,661,525 1,659,475 MMBTU 

P048 Reheat Fee #3 Jun-70 2417/52 2,000,800 1,395,025 1,395,025 MMBTU 

P049 Anneal - North Jun-71 2417/52 292,125 231,650 202,950 MMBTU 

P050 Anneal - South Jun-71 24/7/52 292,125 231,650 201,925 MMBTU 

P071 Continuous Jun-89 2417/52 0 0 128,433 MMBTU 

Galvanizing Line 

P903 C5 Blast Fee Jun-43 2417/52 1,396,775 1,328,421 1,385,344 tons 

Stoves 2,127,312 2,106,016 1,832,424 MMBTU 

Flare 308,792 306,768 428,296 MMBTU 

P904 C6 Blast Fee Jun-52 24/7/52 1,257,945 924,269 1,288,924 tons 

Stoves 2,578,928 1,875,016 2,312,992 MMBTU 

Flare 374,352 273,152 540,672 MMBTU 

P905 No.2 BOF, 

No.1 Vessel Jun-66 24/7/52 1,410,146 1,190,545 1,311,350 tons 

P906 No.2 BOF, 

No. 2Vesset Jun-66 24/7/52 1,410,146 1 '190,544 1,311,348 tons 

P905/P906 Flares 20,808 17,528 19,475 MMBTU 

P905/P906 Ladle Preheaters 381,300 443,825 469,450 MMBTU 

P925 No.1 BOF, 

No. 94 Vessel Jun-61 2417/52 231,668 202,959 325,842 tons 

P926 No.1 BOF, 

No. 95 Vessel Jun-61 2417/52 231,668 202,959 325,840 tons 

P905/P906 Ladle Preheaters 200,900 231,650 386,425 MMBTU 

111 Assumes 1025 MMBTU/MMCF for NG, 88 MMBTU/MMCF for BFG, and 153,375 MMBTU/1000 gal for fuel oil for all three years- same as in 2006 
EMISSION DESCRIPTION MAXIMUM DAILY PRODUCTION RATE AVERAGE DAILY PRODUCTION RATE NOx EMISSION TESTING RESULTS, 

UNIT# (TONS/DAY or MMBTU/DAY) 1'1 (TONS/DAY or MMBTUIOAY) IF ANY 

2004 2005 2006 2004 2005 2006 

(366 days) (366 days) 

P046 Reheat Fee #1 6478 6924 6112 4464 4092 4145 526 lbs/MMCF 

(Sept) 

P047 Reheat Fee #2 6543 7028 5996 4837 4552 4547 

(Sept) 

P048 Reheat Fee #3 6112 5996 6880 5467 3822 3822 

(July) 

P049 Anneal - North 959 698 612 798 635 556 ~----~--- --~--~-

(Sept) 

P050 Anneal - South 959 698 609 798 635 553 

(Sept) 

P071 Continuous 0 0 471 0 0 428 155 lbs/MMCF 

Galvanizing Line (ASSUfo1E 3000}\YS) (ASSUME 300 DAYS) 

P903 C5 Blast Fee 4198 4003 4175 3816 3640 3795 

Stoves 7252 7142 7610 5812 5770 5020 1.01 lbs/MMCF for BFG 

Flare 928 925 1291 644 840 1173 (Same value used for the flare) 

P904 C6 Blast Fee 3781 2785 3864 3437 2532 3531 

Stoves 8028 7640 7939 7046 5137 6337 3.86 lbs/MMCF for BFG 

Flare 1125 823 1629 1023 748 1481 (Same value used for the flare) ------>~---·------

P905 No.2 BOF, 

No.1 Vessel 4238 3588 3"952 3853 3262 3593 -· .... , ___ ··- .. 

P906 No. 2BOF, 

No. 2Vessel 4238 3588 3952 3853 3262 3593 

P905/P906 Flares 63 53 59 57 48 53 

P905/P906 Ladle Preheaters 1146 . ________ 1338 , ___ .1415 1042 1216 1286 

P925 No.1 BOF, 

No. 94 Vessel 1062 .612 982 965 966 987 

P926 No.1 BOF, 

No. 95 Vessel 1062 612 982 965 966 987 

P905/P906 ladle Preheaters 921 . 698 1165 837 1103 1171 -·----··-··---- (ASSUME 240 (ASSUME210 (ASSUME 330 

<

1

J Light purple: assumes max day is 10% greater than an average day. DAYS) DAYS) DAYS) 

Burnt orange: actual max monthly average divided by days in month 
EMISSION DESCRIPTION 

UNIT# AVERAGE DAILY MAX DAILY ANNUAL NOx EMISSIONS YEAR OF HIGHEST ANNUAL EMISSIONS 

NOx EMISSIONS NOx EMISSIONS 1'

1 BASED ON HIGHEST 

(lbs/day) (lbs/day) of 3 YEARS (tons/yr) 

P046 Reheat Fee #1 2291 3553 419.2 2004 

P047 Reheat Fee #2 2482 3607 454.2 2004 

P048 Reheat Fee #3 2805 3531 513.4 2004 

P049 Anneal - North 78 94 14.3 2004 

P050 Anneal - South 78 94 14.3 2004 

P071 Continuous 65 71 9.7 2006 

Galvanizing Line 

P903 C5 Blast Fee 99 109 18.2 2004 

Stoves 67 77 12.2 32.1 2004 

Flare 10 1t 1.8 tpy max year all: 2004 2004 

P904 C6 Blast Fee 92 101 16.8 2006 

Stoves 309 334 56.6 81.1 2004 

Flare 65 71 11.9 tpy max year all: 2004 2006 

P905 No.2 BOF, 

No.1 Vessel 501 551 91.7 2004 

P906 No.2 BOF, 

No. 2Vessel 501 551 91.7 2004 

P905/P906 Flares 6 6 1.0 202.9 2004 

P905/P906 Ladle Preheaters 125 138 22.9 tpy max year all: 2004 2006 

P925 No.1 BOF, 

No. 94 Vessel 128 141 21.2 2006 

P926 No.1 BOF, 

No. 95 Vessel 128 141 21.2 61.2 2006 

P905/P906 Ladle Preheaters 114 126 18.9 tpy max year all: 2006 2006 

(

1

J Light purple: assumes max day is 10% greater than an average day. Burnt orange: actual max monthly average divided by days in month 

Light grey: revised from previous version. 
NO.1 REHEAT FURNACE LOW NOx BURNERS COST CALCULATIONS 
ArcelorMittal Cleveland No. 1 Reheat Furnace NOx RACT Analysis 

There is a total of 602.6 MMBTU/hr burner capacity for this furnace. 

SUMMARY OF 2006 BURNER CHANGES 

Preheat Zone: 

Bloom 1500 low NOx burners were installed in both the tOP and bottom sections in 2006. 

There are 10- 16.9 MMBTU/hr burners in the top section: 169.0 MMBTU/hr total 

There are 10- 16.9 MMBTU/hr burners in the bottom section: 169.0 MMBJ.Ul total 

12/10/2008 

Based on Bloom information for the former Bloom 1200 burners, u€§1 lbs NO MMBTU as the expected NOx emissions for the 

former burners. ---~ 

Based on Bloom information, use 0,213 lbs NOx/MMBTU as the expected NOx emissions for the newer burners. 

Heat Zone: 

Bloom 1500 low NOx burners were installed in both the top and bottom sections in 2006. 

There are 8- 10.2 MMBTU/hr burners in the top section: 81.6 MMBTU/hr total 

There are 10- 10.2 MMBTU/hr burners in the bottom section: 102.0 MMBTU/hr total 

Based on Bloom information for the former Bloom 1200 burners, ~seo.51it;"s]lox!MMBTU as the expected NOx emissions for the 

former burners. ~- --- -

Based on Bloom information, use 0.212 lbs NOx/MMBTU as the expected NOx emissions for the newer burners. 

Soak Zone: 

Bloom 2010 conventional burners were installed for all 42 soak zone burners in 2006. 

These include: 18- 1.95 MMBTU/hr burners at 23.4 MMBTU/hr total; 12- 1.95 MMBTU/hr burners at 14.4 MMBTU/hr total; and 

12-1.20 MMBTU/hr burner.s-aH<t:4-f\(1MBTU/hrtotal 

Per Bloom informatio~~~NOx /MMBTU as the expected emissions for the newer burners. 

These are cold air bur~ich the NOx emissions are inherently low. As such, replacement low NOx burners would only 

represent a minimal reduction in NOx emissions. 

As such, ArcelorMittal Cleveland does not believe that an additional NOx RACT analysis is required for the Soak Zone burners based 

on the low NOx emissions from the new Bloom 2010 conventional burners. 

The following assessment is used to confirm that the 2006 burners changes for the Preheat Zone and Heat Zone burners 

satisfied the requirements in the NOx RACT rules to install NOx controls with annualized costs per ton of NOx reduced 

less than $4000/ton. 
CALCULATION FOR THE ANNUALIZED COST PER TON NOx REMOVED BASED ON THE 2006 BURNERCHANGES 

FOR THE PREHEAT ZONE AND HEAT ZONE 

Direct Capital Costs (DCC): 

Purchased Equipment Costs: 

Equipment Costs (EC): 

Sales Tax (0.03EC): 

Total Purchased Equipment Costs (PEC): 

Installation Costs (IC), Including instrumentation, 

Freight, Engineering, Startup Consultancy 

Total Purchased Equipment and Installation Cost (ICC=PEC + IC): 

Other Indirect Capital Costs (OCC) 

Lost Production: 

Total Other Indirect Capital Costs (OCC): 

Contingency (CONT. 0.20 [ICC+OCC]): 

Total Capital Cost (TCC=ICC+OCC+CONT): 

Annualized Capital Cost (ACC=TCCxCFR): 

Capital Recovery Factor (CRF): 

Direct Annual Costs (DAC): 

Operation ( 0) 

Maintenance (M) 

Replacement Materials 

Utilities 

Waste Disposal 

Chemicals 

Other 

$328,302 

$9,849 

$338,152 

$310,149 

$648,301 

$0 

$0 

$129,660 

$777,961 

$189,737 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

Reference 

(1) 

(2) 

(3) 

(4) 

(5) 
Total Direct Annual Costs (DAC): 

Indirect Annual Costs (lAC): 

Overhead (0.60(0+M)) 

Administrative (0.01TCC) 

Property Tax (0.01TCC) 

Insurance (0.02 TCC) 

Total Indirect Annual Costs (lAC): 

Total Annual Cost (TAC=ACC+DAC+IAC): 

Capital Recovery Factor (CFR) = I (1+ 1)0 

(1+1)"-1 

I = 7 ...?~<\ - interest rate 

n =::!Jears - economic equipment life 

CFR = ': 0.244 

Actual Emissions Reduction (tons/yr): 

Based on 2006 actual fuel usage 

Potential Emissions Reduction (tons/yr) 

Cost-Effectiveness ($/ton Actual): 

Cost-Effectiveness ($/ton Poten.tial): 

$0 

$0 

$7,780 

$7,780 

$15,559 

$31,118 

$220,856 

211 

681 

~~ / - ~ 

$324' ./ 

(6) 

(6) 

(6) 

(7) 

(7) 

(8) 
References: 

(1) Cost quotation from 2006 Bloom Engineering to replace all the No. 3 Reheat Furnace burners. Adjusted to 2008 dollars. 

Similar costs for No. 1 Reheat Furnace replacement. Soak zone burners cost pulled out of the cost quotation. 

Assume 5% annual inflation adjustment. 

(2) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Table 2.4, Page 2-27. 

(3) Installation costs provided for No. 3 Reheat Furnace by Jack Scott, consultant on the No. 3 Furnace. 

Total installation cost for all three zones estimated at $325,000. Assume installation for Preheat and Heat Zone Burners 

proportional to MMBTU/hr values. Adjusted to 2008 dollars. Includes waste disposal of refractory brick. Assume similar 

costs for No. 1 Reheat Furnace replacement. 

(4) Assume no production lost during the outage as the other two reheat furnaces picked up the additional slab production. 

(5) From EPA "Cost-Air" spreadsheets available on-line at http://www.epa.gov/ttn. 

(6) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Section 2.5.5.8 

(7) "Alternative Control Techniques Document- NOx Emissions from Iron and Steel Mills," EPA/453/R-94-065, September, 1994, 

Section 6.1.3 for costs of low-NOx burners applied to reheat furnaces. 

(8) NOx loadings obtained from Steve Simko, P.E., Bloom Engineering. The 2006 fuel usages provided by ArcelorMittal Cleveland. 
NO.2 REHEAT FURNACE LOW NOx BURNERS COST CALCULATIONS 
ArcelorMittal Cleveland No. 2 Reheat Furnace NOx RACT Analysis 

There is a total of 602.6 MMBTU/hr burner capacity for this furnace. 

SUMMARY OF 2007 BURNER CHANGES 

Heat Zone: 

North American 482 LNI - 14 x 848 low NOx burners were installed in both the top and bottom section in 2005. 

There are 8 - 10.2 MMBTU/hr burners in the top section: 81.6 MMBTU/hr total 

There are 10-10.2 MMBTU/hr burners in the top section: 102.0 MMBTU/hrtotal 

12/10/2008 

Based on Bloom information for the former Bloom 1200 burners, use 0.51 lbs NOx/MMBTU as the expected NOx emissions for the 

former burners. 

Based on North American information, use 0.097 lbs NOx/MMBTU as the expected NOx emissions. 

These low NOx burners represent RACT already and no NOx RACT analysis is required for these burners. 

Soak Zone: t')1;~l ('' ·' 

Bloom 2010 conventional burners were installed for 2 soak zone burners in 2007. / 

These include: 18 - ~MBTU/hr burners t- MBTU/hr tot~; 12 - ~MBTU/hr burners at 1l!fi MMBTU/hr total; and 

12 @1\i!MBTU/hr burners at Til,;AAME3Il)ihrt()t;,l .. / - ' ! 

Per Bloom information, use 0.056 lbs NOx /MMBTU as the expected emissions for the newer burners. 

These are cold air burners in which the NOx emissions are inherently low. As such, replacement low NOx burners would only 

represent a minimal reduction in NOx emissions. 

As such, ArcelorMittal Cleveland does not believe that an additional NOx RACT analysis is required for the Soak Zone burners based 

on the low NOx emissions from the new Bloom 2010 conventional burners. 

The following assessment is used to confirm that the 2005 burners changes for the Heat Zone burners 

satisfied the requirements in the NOx RACT rules to install NOx controls with annualized costs per ton of NOx reduced 

less than $4000/ton. 
CALCULATION FOR THE ANNUALIZED COST PER TON NOx REMOVED BASED ON THE 2005 BURNER CHANGES 

FOR THE HEAT ZONE 

Direct Capital Costs (DCC): 

Purchased Equipment Costs: 

Equipment Costs (EC): 

Sales Tax (0.03EC): 

Total Purchased Equipment Costs (PEC): 

Installation Costs (IC), Including instrumentation, 

Freight, Engineering, Startup Consultancy 

Total Purchased Equipment and Installation Cost (ICC=PEC + IC): 

Other Indirect Capital Costs (OCC) 

Lost Production: 

Total Other Indirect Capital Costs (OCC): 

Contingency (CONT, 0.20 [ICC+OCC]): 

Total Capital Cost (TCC=ICC+OCC+CONT): 

Annualized Capital Cost (ACC=TCCxCFR): 

Capital Recovery Factor ( CRF): 

Direct Annual Costs (DAC): 

Operation ( 0) 

Maintenance (M) 

Replacement Materials 

Utilities 

Waste Disposal 

Chemicals 

Other 

$241,200 

$7,236 

$248,436 

$245,000 

$493,436 

$0 

$0 

$98,687 

$592,123 

$144,413 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

Reference 

(1) 

(2) 

(3) 

(4) 

(5) 
Total Direct Annual Costs (DAC): 

Indirect Annual Costs (lAC): 

Overhead (0.60(0+M)) 

Administrative (0.01TCC) 

Property Tax (0.01TCC) 

Insurance (0.02 TCC) 

Total Indirect Annual Costs (lAC): 

Total Annual Cost (TAC=ACC+DAC+IAC): 

Capital Recovery Factor (CFR) = 

I = 7 % - interest rate 

I (1+ ll" 

(1+1}"-1 

n =cwrs - economic equipment life 

CFR = ~ 0.244 

Actual Emissions Reduction (tons/yr): 

Based on 2006 actual fuel usage 

Potential Emissions Reduction (tons/yr) 

Cost-Effectiveness ($/ton Actual): 

Cost-Effectiveness ($/ton Potential): 

$0 

$0 

$5,921 

$5,921 

$11,842 

$23,685 

$168,098 

95 

332 

$1,766 

$506 

(6) 

(6) 

(6) 

(7) 

(7) 

(8) 
References: 

(1) Cost quotation from North American to replace the 18 No. 2 Reheat Furnace Heat Zone burners. 

(2) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Table 2.4, Page 2-27. 

(3) Installation costs provided for No. 2 Reheat Furnace by Jack Scott, consultant on the No. 2 Furnace project. Actual 2005 dollars. 

(4) Assume no production was lost during the outage as the other two reheat furnaces picked up the additional slab production. 

(5) From EPA "Cost-Air" spreadsheets available on-line at http://www.epa.gov/ttn. 

(6) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Section 2.5.5.8 

(7) "Atternative Control Techniques Document- NOx Emissions from Iron and Steel Mills," EPA/453/R-94-065, September, 1994, 

Section 6.1.3 for costs of low-NOx burners applied to reheat furnaces. 

(8) NOx loadings obtained from Bruce Abe, North American Burners. The 2006 fuel usages provided by ArcelorMittal Cleveland. 
The following assessment is the calculation for the annualized cost per ton NOx removed if the conventional Bloom 1200 

burners in the Preheat Zone were replaced with Bloom 1500 low NOx burners. 

CALCULATION FOR THE ANNUALIZED COST PER TON NOx REMOVED IF THE PREHEAT ZONE BURNERS 

ARE REPLACED WITH LOW NOx BURNERS 

Direct Capital Costs (DCC): 

Purchased Equipment Costs: 

Equipment Costs (EC): 

Sales Tax (0.03EC): 

Total Purchased Equipment Costs (PEG): 

Installation Costs (IC), Including instrumentation, 

Freight, Engineering, Startup Consultancy 

Total Purchased Equipment and Installation Cost (ICC=PEC + IC): 

Other Indirect Capital Costs (OCC) 

Lost Production: 

Total Other Indirect Capital Costs (OCC): 

Contingency (CONT, 0.20 [ICC+OCC]): 

Total Capital Cost (TCC=ICC+OCC+CONT): 

Annualized Capital Cost (ACC=TCCxCFR): 

Capital Recovery Factor (CRF): 

Direct Annual Costs (DAC): 

Operation (0) 

Maintenance (M) 

Replacement Materials 

Utilities 

Waste Disposal 

Chemicals 

Other 

$111,090 

$3,333 

$114,423 

$191,408 

$305,831 

$0 

$0 

$61,166 

$366,997 

$89,507 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

Reference 

(1) 

(2) 

(3) 

(4) 

(5) 

\ 
Total Direct Annual Costs (DAC): 

Indirect Annual Costs (lAC): 

Overhead (0.60(0+M)) 

Administrative (0.01TCC) 

Property Tax (0.01TCC) 

Insurance (0.02 TCC) 

Total Indirect Annual Costs (lAC): 

Total Annual Cost (TAC=ACC+DAC+IAC): 

Capital Rec.overy Factor(CFR) = 

I = 7 % - interest rate 

1(1+1l" 

(1+1)"-1 

$0 

$0 

$3,670 

$3,670 

$7,340 

$14,680 

$104,187 

n~-economic equipm~nt life 

s, CFR = 0.244 "'-,it ou.IJ j, "- P 0 Y'·:; 

Actual Emissions Reduction (tons/yr): 126 

Based on 2006 actual fuel usage 

Potential Emissions Reduction (tons/yr) 441 

Cost-Effectiveness ($/ton Actual): ~-~-) 

Cost-Effectiveness ($/ton Potential): $236 

(6) 

(6) 

(6) 

(7) 

(7) 

(8) 
References: 

(1) 2006 cost quotation from Bloom Engineering to replace all the No. 3 Reheat Furnace burners. Adjusted to 2008 dollars. 

Similar costs for No. 2 Reheat Furnace replacement. Heat and soak zone burners cost pulled out of the cost quotation. 

Assume 5% annual inflation adjustment. 

(2) EPA Pollution Control Cost Manual, Sixth Edition, EPN452/B-02-001, January, 2002, Table 2.4, Page 2-27. 

(3) Installation costs provided for No. 3 Reheat Furnace by Jack Scott, consultant on the No. 3 Furnace. 

Total 2007 installation cost for all three zones estimated at $325,000. Assume installation for Heat Zone Burners 

proportional to MMBTU/hr values. Adjusted to 2008 dollars. Includes waste disposal of refractory brick. Assume similar 

costs for No. 2 Reheat Furnace replacement. 

(4) Assume no production lost during the outage as the other two reheat furnaces picked up the additional slab production. 

(5) From EPA "Cost-Air" spreadsheets available on-line at http://www.epa.gov/ttn. 

(6) EPA Pollution Control Cost Manual, Sixth Edition, EPN452/B-02-001, January, 2002, Section 2.5.5.8 

(7) Alternative Control Techniques Document- NOx Emissions from Iron and Steel Mills, EPN453/R-94-065, September, 1994, 

Section 6.1.3 for costs of low-NOx burners applied to reheat furnaces. 

(8) NOx loadings obtained from Steve Simko, P .E., Bloom Engineering. The 2006 fuel usages provided by ArcelorMittal Cleveland. 
NO.3 REHEAT FURNACE LOW NOx BURNERS COST CALCULATIONS 
ArcelorMittal Cleveland No. 3 Reheat Furnace NOx RACT Analysis 

yoc\ 8' 

There is a total of 602.6 MMBTU/hr burner capacity for this furnace. ~ 

SUMMARY OF 2007 BURNER CHANGES 

Preheat Zone: 

Bloom 1500 low NOx burners were installed in both the top and bottom sections in 2007. 

There are 10- 16.9 MMBTU/hr burners in the top section: 169.0 MMBTU/hr total 

There are 10- 16.9 MMBTU/hr burners in the bottom section: 169.0 MMBTU/hr total 

12/10/2008 

Based on Bloom information for the former Bloom 1200 burners, use 0.51 lbs NOx/MMBTU as the expected NOx emissions for the 

former burners. 

Based on Bloom information, use 0.212 lbs NOx/MMBTU as the expected NOx emissions for the newer burners. 

Heat Zone: 

Bloom 1500 low NOx burners were installed in both the top and bottom sections in 20Q7. 

There are 8- 10.2 MMBTU/hr burners in the top section: 81.6 MMBTU/hr total 

There are 10- 10'2 MMBTU/hr burners in the bottom section: 102.0 MMBTU/hr total 

Based on Bloom information for the former Bloom 1200 burners, use 0.51 lbs NOx/MMBTU as the expected NOx emissions for the 

former burners. 

Based on Bloom information, use 0.212 lbs NOx/MMBTU as the expected NOx emissions for the newer burners. 

Soak Zone: 

Bloom 2010 convention<JI burners were installed for all, 42 soak zone burners in 2007. 

These include: 18- 1.95 MMBTU/hr burners at 23.4 MMBTU/hr total; 12- 1.95 MMBTU/hr burners at 14.4 MMBTU/hr total; and 

12 -1.20 MMBTU/hr burners at 14.4 MMBTU/hr total 

Per Bloom information, use 0.056 lbs NOx /MMBTU as the expected emissions for the newer burners. 

These are cold air burners in which the NOx emissions are inherently low. As such, replacement low NOx burners would only 

represent a minimal reduction in NOx emissions. 

As such, ArcelorMittal Cleveland does not believe that an additional NOx RACT analysis is required for the Soak Zone burners based 

on the low NOx emissions from the new Bloom 2010 conventional burners. 

The following assessment is used to confirm that the 2007 burners changes for the Preheat Zone and Heat Zone burners 

satisfied the requirements in the NOx RACT rules to install NOx controls with annualized costs per ton of NOx reduced 

less than $4000/ton. 
CALCULATION FOR THE ANNUALIZED COST PER TON NOx REMOVED BASED ON THE 2006 BURNER CHANGES 

FOR THE PREHEAT ZONE AND SOAK ZONE 

Direct Capital Costs (DCC): 

Purchased Equipment Costs: 

Equipment Costs (EC): 

Sales Tax (0.03EC): 

Total Purchased Equipment Costs (PEC): 

Installation Costs (IC), Including instrumentation, 

Freight, Engineering, Startup Consultancy 

Total Purchased Equipment and Installation Cost (ICC=PEC + IC): 

Other Indirect Capital Costs (OCC) 

Lost Production: 

Total other Indirect Capital Costs (OCC): 

Contingency (CONT, 0.20 [ICC+OCC]): 

Total Capital Cost (TCC=ICC+OCC+CONT): 

Annualized Capital Cost (ACC=TCCxCFR): 

Capital Recovery Factor (CRF): 

Direct Annual Costs (DAC): 

Operation (0) 

Maintenance (M) 

Replacement Materials 

Utilities 

Waste Disposal 

Chemicals 

Other 

$312,669 

----$9,-:lSO 

$322,049 

$310,149 

$632,198 

$0 

$0 

$12(3,440 

$758,638 

$185,025 

$0 

$0 

$0 

$0 

$0 

$0 

$0 

Reference 

_) (1) 

(2) 

(3) 

(4) 

(5) 
Total Direct Annual Costs (DAC): 

Indirect Annual Costs (lAC): 

Overhead (0.60(0+M)) 

Administrative (0.01TCC) 

Property Tax (0.01TCC) 

Insurance (0.02 TCC) 

Total Indirect Annual Costs (lAC): 

Total Annual Cost (TAC=ACC+DAC+IAC): 

Capital Recovery Factor _,.,. (CFR) = 

('':(f 

~ 'Y-- ~ I = 7 % - interest rate 

l(1+ ll" 

(1+1)"-1 

n = cl>YeafS) economic equipment life -·--::.:.::~-c.---·- -

CFR= . 0.244 

(c f' ~") 

Actual Emissions Reduction (tons/yr): 

Based on 2006 actual fuel usage 

Potential Emissions Reduction (tons/yr) 

Cost-Effectiveness ($/ton Actual): 

Cost-Effectiveness ($/ton Potential): 

$0 

$0 

$7,586 

$7,586 

$15,173 

$30,346 

$215,370 

195 

(6) 

(6) 

(6) 

(7) 

(7) 

(8) 

r 
References: 

(1) Cost quotation from 2006 Bloom Engineering to replace all the No. 3 Reheat Furnace burners. Adjusted to 2008 dollars. 

Soak zone burners cost pulled out of the cost quotation. 

Assume 5% annual inflation adjustment. 

(2) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Table 2.4, Page 2-27. 

(3) Installation costs provided for No. 3 Reheat Furnace by Jack Scott, consultant on the No. 3 Furnace. 

Total installation cost for all three zones estimated at $325,000. Assume installation for Preheat and Heat Zone burners 

proportional to MMBTU/hr values. Adjusted to 2008 dollars. Includes waste disposal of refractory brick. 

(4) Assume no production lost during the outage as the other two reheat furnaces picked up the additional slab production. 

(5) From EPA "Cost-Air'' spreadsheets available on-line at http://www.epa.gov/ttn. 

(6) "EPA Pollution Control Cost Manual, Sixth Edition," EPA/452/B-02-001, January, 2002, Section 2.5.5.8 

(7) "Alternative Control Techniques Document- NOx Emissions from Iron and Steel Mills," EPA/453/R-94-065, September, 1994, 

Section 6.1.3 for costs of low-NOx burners applied to reheat furnaces. 

(8) NOx loadings obtained from Steve Simko, P.E., Bloom Engineering. The 2006 fuel usages provided by ArcelorMittal Cleveland. 
ARCELORMITT AL CLEVELAND PLOT PLAT SHOWING AFFECTED NOx 

SOURCES 
•=-=----====----Meters 0 145 290 580 870 1,160 
DOCUMENTATION OF PRIOR NOx STACK TEST RESULTS- SUMMARY 

REPORTS 
DOCUMENTATION OF PRIOR NOx STACK TEST RESULTS 

SUMMARY REPORTS 
BOll..ERS 1 AND 2 TEST SUMMARY 

NOVEMBER 2, 1994 

'~( 
( 

LTV STEEL COMPANY 

CLEVELAND WORKS 

NITROGEN OXIDES EMISSIONS EVALUATION 

•• •• < 

Prepared for 

LTV Steel Company 

3100 East 45th Street 

Cleveland, Ohio 44127 

PN 5146·1 

Pr~bf: 

Environmental Quality Mlulag'-'"nt 1310 Kemper Meac:tpw Drive 

Cincinnati, Ohio 4N40 
• 

• 

• 

• 

TABLE 2-1. SUMMARY OF TEST RESULTS 

LTV STEEL COMPANY . CLEVELAND WORKS 

Date 'll. 

l.ocalfon Run 1994 Molltura 

lloller 1 u 81&2-1 11102 8.1 

81&2-2 

81&24 

Average 8.8 

Part per million 

Pound per mllllon Btu 

Results det811111ned during coat firing ollloller 3 

5.0 ppm Ia the lower detection limit for analyzer 

'll. 

0. 

7.7 

8.8 

8.1 

8.1 

'll. 

co. 

17.7 

15.3 

18.8 

16.5 

NO.,• 1111" 

ppm MMBtu 

..s.o 0.018 

s.a 0.017 

..s.o 0.018 

5.1 0.018 
REHEAT FURNACES 1, 2, AND 3 TEST SUMMARY 

MARCH 18, 19, AND 24, 2003 
I 

I 

,. 

! 

• . ' I 

I 

j. 

l 

I 

' 

/ 

. A:Ir·CompliaiJce 

··Testing, Inc.· 

Rich!ll'd Zavada 

l:lnv:iram;nental Milllj~ger 

ISG Cleveland Im:i. · · · 

'060 Eggers Av~nue 

Clevelarid, Ohio 441 OS . '•' 

06\U' Richaf:d: · 

Pq floX.41156,:Cil>V.IOrnl OK 44141 

Plione: (1!00\ EPA:AJR1 (3'1~-2471) 

April 18, 2063 

Tt~e following ~ix>it pr<~vides the·results ofthe self-ey.~lllllti;;>n engineerlng.stlldy c~nducted 11n . 

Mareh !8, W. anli 24, 20Q3, Thes~ results: are.: p~u.et of the EPA SUiti0nary SoureeSI!lnpling 

Me.thedS lis~·.bf 40 CFR Part 60 Appeidiic A abbreviated iri their appl\eatiap in order tG reduce . . . . . . " . '. . . . ' . ' . ~ -· . ' . . . . any uAAecessary casts' VllthOllt.sacri.fieill.g ac9tir~. . · · .. · .. · ' : . . '. . :·. . . . . '. . ; 

The're§l!ltS ofthjs .. i~ are ;~tel)d¢.w b~ ~ f~rappijc~tia~s sucp a;,siack~issiens' inventory . 

· ·dati gathe~iilg. pro~s· ;IDe;\ aic 11atiu~ol\ ea11trol :eq~ipitient ~timizaticin studies, !li!d pre- · . . 

CGfqpliance emission levei ·~tll~ieS .. Air Cciljlpliance T~tlilg:does:nllt f(ICPmtneiid ~~~~ .~se ~~this' . 

perfannll!lce' ~~ !Iilla 'fer demal)Siratian te'the EM af CG!Dpliai!ce \villi i!\i .~ppli~b!e timissie.n. 

H~'lft ar stanil~ such-.S these th!!.t are eo~tsiJlell in a)il eiPe.ratiig ar. irislllll.~tian.permit. . Air.. · 

<;:ompliaqce'1'estihg'deitS. hawever, stand behinii'the a~cc.uracy·ofthe·tei!lllts. of ibis test anil·et1sutes · 

aeceptable rep~\lf.bilitY afthes!J res'titts imderideiiticl\fpraceSs eperatlng cOnditions. . .. . . . . . . ' . ' . ·. . .. 

f!e~e ·do ilot ~itatp ta call ify!)U :-qave ainy queStiims Gf COilCe~ ahaut $ese teSt results or any · 

other 'eii1issi01l i¢sti.rig relate4 tapjcs. On behalf of Ait: Campliaitte Testing; Iw0uld also. like to 

pe~sona!'Jy thank )'!'JU fa~ '$e oppelti¥iity !G. wark' With yeti anthi~ .tes~ng project an do WGUld enjoy . the opportun\tY to. work wtth you 8gai~ an any adi!itlenal.future testing projects. . ' . ' :. . 

72~tLL Ro~r.t J. Lisy Jr. : 

Techilical Mariager 
Self.:EvaJI;!jltjon SaoJneertma S!udli Ills! ReiN!! ISG Cleveland Inc. 

2.0 SUMMARY AND DISCUSSION OF TEST RESUlTS 

2.1 Objectives and Test Matrix 

The purpose af this test was t0 determine the mass emissien rate 0fNO, (as NOz) at the Billet 

Reheat Fumase Ne. 1, N0. 2, and Na. 3 Exhaust Stacks during nermal maximum eperations. This 

tast was cenducted to previae ISG Cleveland, Inc. with emissions inf0rmation far their awn internal 

use. 

The sPAAitic test abjectives for this test were to; 

Measure the cencentratieas efNO., and C02 at the Billet Reheat Furnace No. l, No.2, and No.3 

Exhaust Stacks during narmal maximum operatiens. 

Measure the ae!Ual and dry standard volumel.!ic flow rates of the stack gas at the Billet Reheat 

Furllllce No. I, Na. 2, and No. 3 Exhaust Stacks during normal maximum operatiolls. 

Utili~ the above variables to calculate the mass emission rate ofNO, (as N02) at the Billet 

Reheat Furnace No. l, Ne. 2, and No.3 Exhaust Smks during normall!llOOmum operations. 

Table 2.1 presents the sampling and analytical matrix leg f0r this test. 

2.2 Field Test Changes and Problems 

The EPA Method 4 post-test samplillg trailllcall: checks perfol'l1\ed after Rum I at both the Billet 

Reheat Fumace No. 1 and N1r>. 2 Exhaust Stacks yielded a lcall:age rates which were greater than the 

method allowable leakage rate of 0.020 efin. Theref9re, an additional samplt~ tum was perfor~ned at 

both the Billet Reheat Fumaee No. 1 and NG. 2 Exhaust Stacks. The data collect dming Run 1 at 

both the Billet Reheat Furnace No. 1 and No. 2 Exhaust Smks are not displayed in this report. 

Test Date: March 18, 19, and 24,2003 Pago3 Air Compliance Testing, Inc. - 030302 
Self-Evaluation Engineering Study Test Repgrt JS!O Cieyeiand Inc. 

2.3 Presentation of Results 

Two sampling trains were utilized at each locatien duriag each run ia order te detennine the mass 

emissien rate of NO, (as N()z). One sampling train measured the stack gss volumetric flew rate, 

dry molecular weight, and moisture coatent of the stack gas and a secend train, utilizing a sample 

gas dilution system, measured the stack gas cencentratiens ofNO, and COz. 

The mass emissien rates ofNO, (as N()z) measured during this test event are displayed in Tables 

2.2. 1 - 2.2.3. 

The graphs that follow Table 2.2.3 present the raw, uncorrected cencentratien data measured in 

the field by the C()z and NO, analyzers fer all three testing locations. 

Test Date: Manch 18, 19, and 24,2003 Page4 Air Compliance Testing, Inc. - 030302 
Se!f"Evaluatioo • Engineering Study Test Rei!Ort • ISGCleve.lnc, 

EPA TEST METHODS UTILIZED 

MI/M2 M3A M3B M4 M7E 

(Flow) (COt) IDrv MoL WU (%H10) (NOx) 

Run Sampling Time I Sampling Time I Sampling Time I Sampllug Time I Sampllug Time I 

Date No. SamnliDI! Location Du,..tlon (min) Daration(mlnl Duratl!la (min) Duration(mln) Duration (min) 

311812003 2 Billet Reheat F-No. I 10:04 " II :22 10:04- lt:19 1'0:04 - II :22 10:04 - ll :22 10:04-11:19 

Exhaust Stack 64 60 64 64 60 

3/18/2003 3 Bill<:t Reheat Furnace No. I 11:43- 12:59 11 :43 - 12:57 11:43- 12:59 11:43- 12:59 II :43 • 12:57 

Exhaust Stack 64 60 64 64 60 

3/18/2003 4 Bill<:t Reheat Furnace No. I 13:5 I - 15:08 13:5 I • 15:06 13:51 - IS:OS 13:51- 15:08 13:5 I - 15:06 

Exhaust Stack 64 60 64 64 60 

3/2412003 2 

Billet ReheatFwnace No.2 9:02- 10:35 9:02. 10:35 9:02- 10:35 9:02-10:35 9:02-10:35 

Exhaust Stack 64 60 64 64 60 

312412003 3 

Billet Reheat Furnace No.2 11:11-12:34 11:11 - 12:32 11:11 - 12:34 II: II • 12:34 11:11 - 12:32 

Exhaust Stack 64 60 64 64 60 

312412003 4 Bill<:t Reheat Furnace No. 2 12:53- 14:17 12:53- 14:15 12:53. 14:17 12:53- 14:17 12:53- 14:15 

Exhaust Stack 64 60 64 64 60 

AlltimesarellastomSiondlniTune. 

Table 2.1.1- Sampling and Analytical Matrix 

Test Date: Man:h 18, 19. and 24, 2003 Page5 Air Compllanee Tasllng, Inc. - 030302 
• • Self-Evaluation Enajneerinq Study Test Report 

EPA TEST METHODS UTILIZED 

Ml/Ml M3A M3B M4 M7E 

_(Flow) (Co,) (Dey MoL Wt.) (%H10) (NOs) 

Ruo Sampliog Time I Sampling Time I Sampling Time I Sampling Time I Sampling Time I 

O.te No. Sampling Locatkm D1.1ratlonJntlnJ Dl.lratloo_(mlnJ. Durallon (mlnl Ot~ralloa!!llill) Duralloo (mio) 

3/1912003 2 Billet Rdleat Fu11lll0e No. 3 9:01-10:20 9:01 - 10:18 9:01 -10:20 9:01 "10:20 9:01 "10:111 

ElchaustStack 64 60 64 64 60 

3/1912003 3 Billet Rdleat Furnace No.3 10:58 " 12:21 10:58- 12:19 10:58- 12:21 I 0:511 - 12:21 10:511- 12:19 

Elchaust Slack 64 60 64 64 60 

3119/2003 4 Billet Rdleat FUlllllte No. 3 12:42- 14:23 12:42- 14:21 12:42- 14:23 12:42- 14:23 12:42- 14:21 

Exhaust Stack 64 60 64 64 60 

Allllmos .. EaslemSiaodan!Timo. 

• 

Table 2.1.2 - SampliJig and Analytical Matrix 

Test Date: Mamh 18, 19, and 24, 2003 PageS . Air Compliance Testing, Inc. - 030302 
• • Self-EvaluaUon Engineering Study Test Report ISG ClevA Inc. 

~Reheat Furnace No. 1 Exhaust Stack 

. Run2 Run3 Run4 Average 

Average C01 Based (FJ NO •. Mass Emission Rate (as NID,), (JbiMMBtu 0-91 0.56 0.47 0.$_5 

Average NO,.Mass Emission Rate (as NO,), Oblhr 365.0 265.9 174.9 26!:1.!)_ 

Nitrogen. Oxides (NO.) Concentration (ppmvd 529 472 387 463 

Natural Gas Usage Rate (cfllu' 344,26'7 318,519 247,893 303,560 

Stack Gas Average Flow Rate (acfin' 380,852 303,596 228,779 304,409 

Stack Gas Average Flow Rate (scfin' 116,689 94,884 76,213 95,929 

Stack Gas Average Flow Rate (dscfin' 96,376 78,558 63,122 79,352 

Stack Gas Average Velocity (fpm) 2,221 1,771 1,334 1,775 

Stack Gas Averagt! Static Pressure (in-H20\ -0.31 -0.28 -0.25 -0.28 

Stack Gas Average Temperatllre ("F) 1,208 1,176 1,076 1,153 

Stack Gas Percent by Volume Moisture (o/.JI,m 17.41 17.21 17.18 17.26 

Measured Stack Inner Diameter (in 177.31 177.31 177.31 11731 

Percent by Volume Carbon Dioxide in Stack Gru; (Dry Basis) ("/.CO,: 10.69 10.43 10.19 10.44 

Pereent by Volume OXygen in Stack Gas (J)ry. Basis) ("'.o,: 2.97 3.40 3.97 3.45 

Percent by Volume Carbon Monoxide in Stack Gas (Dry Basis) (%CO 0.00 0.00 0.00 0.00 

Percent by Volume Nitrogt!n in Stack Gas (Dry Basis) (%N2J 86.34 86.17 85.84 86.12 

Percent Excess Air (% 14.98 17.57 21.24 17.93 

Measured Fuel Factor Value (FoJ 1.68 1.68 1.66 1.67 

Table 2.2.1 - Emission Results 

Test Date: March 18, 19, and 24, 2003 Page7 Air Compliance Testing, Inc. - 030302 
Self-Evallon Eooineenna Study Test Reoort • 

WSM 

..-Reheat Furnace No.2 Exhaust Stack 

Run2 Rnn3 Run4 Average 

Average C02 Based (FJ NO,Mass Emission Rate (OJ' NO,), (lbiMMBtu) o:s3 0.40 0:4~ : Cll-46 ) 

Avernge NO, Mass Emission Rate (as NO,), (lblhr 285.2 122.5 158.5 l 88.8 

Nitr!Jgen OXides (NO.) Concentration {ppmvd 407 282 319 336 

Natural Gas Usage Rate (efflu' 300,233 204,620 239,752 248,202 

Stack Gas Average Flow Rate (aejiR 351,676 202,584 239,148 264,469 

Stack Gas Average Flow Rate {scfin 117,254 71,540 82,193 90,329 

Stack Gas Average Flow Rate (dscfin 97,758 60,623 69,258 75,879 

Stack Gas Average Yeloci'" 1

""' 2,131 1,228 1,449 1,603 

· Steck Gas Average Static Pressure (in-li10 -0.35 -0.23 -0.33 -030 

Stack Gas Average Temperature (•F) 1,077 981 1,013 1,024 

Stack Gas Percent l)y Volume Moisture (%H20 16.63 15.26 15.74 15.87 

Measnred Stack Inner Diameter (in 173.94 173.94 173.94 173.94 

Percent by Volume Carbon Dioxide in Steck Gas (DrY Basis)(o/oCO,J 9.53 8.69 8.95 9.06 

Percent l)y Volume OXygen in Steck Gas (Dry Basis) (%0,] 5.73 6.13 6.27 6.04 

Percent by Volume Carbon Monoxide in Stack Gas (Dry Basis)(%CO 0.00 0.00 0.00 0.00 

Percent by Volume Nitrogen in Stack Gas (Dry Basis) (%N:zJ 84.74 85.18 84.78 84.90 

Percent Excess Air(% 34.43 37.47 38.92 36.94 

Measnred Fuel Factor Value (Fa 1.59 l.70 1.63 1.64 

Table 2.2.2 - Emission Results 

Test Date: Mamh 18, 19, and 24, 2003 P.age8 Air Compliance Testing, Inc. - 030302 
Self:Eya!uation • £ing!neering Study Test Report ISG Clevef~c. 

,!!!M 

-.Reheat Furnace No. 3 Exhaust Staek 

Runl Run2 Run3 Average 

I 

A-CO, Based {F.) NO, Mass Emission Rat<! (as.NO,), (lb/MMBtu O.S6 0.52 0.52 0.53 

Average NO, Mass Emission Rate (as NO,), flblbr 2m.1 169.3 218.4 196.8 

Nitrogen OXides (NO.) Concenlrlrtion (ppmv\1 476 397 436 436 

Natural Gas Usage Rate (cf/hi 308,413 232,952 301,155 280,340 

Slack Gas Average Flow Rate (acfin 221,839 209,806 264,160 231,935 

Stack Gas Average Flow Rate (scfin 72,622 71,460 85,047 76,376 

Stack Gas Average Flow Rate ( dscfm 59,466 59,515 69,$63 62,948 

Stack Gas Averae.~ Velocity Cft>m' 1,379 1,305 1,643 1442 

Stack Gas Average Static Pressure (in-H.Ol .0.29 .0.25 .0.32 -0.29 

Stack Gas Avera~re Temoel'lltllre ("F) 1,108 j 047 I 132 1,095 

Stack Gasl'enlent bv Volwne MoiSlllnl (%Fit0 lll.H 16.72 17.85 17.56 

Measured Stack Inner Diameter (in 171.71 171.71 171.71 171.71 

Percent bv Volmne Carbon Dioxide in Slack Gas (Drv Basis) (o/.CO, 10.63 9.53 10.43 10.20 

P4l'Cellt bv Volmne Ox.ygenin Stack Gas (Dry Basis) (%0.,' 2.77 4.30 2.97 3.35 

Pernent by Volume Carbon Monoxide in Stack Gas (Dry Basis) (o/..CO 0.00 0.00 0.00 0.00 

Percent bY Volume Nitrogen in Slask Gas (D!y Basis) (o/eN,: 86.60 86.17 86.60 116.45 

Peroent Excess Air(% 13.79 23.31 14.93 17.34 

Measured Fuel Factor Value (F. 1.70 1.74 1.72 1.72 

Table 2.2.3 - Emission Results 

Test Date: Maroh 18, 19, and 24,2003 Page9 Air Compliwu:e Testing, Inc. - 030302 
HOT DIP GALVANIZING LINE TEST SUMMARY 

FEBRUARY 16, 2007 
• 

• 

• 

Superior Quality 

Emission Testing. 

Valid Results 

Guaranteed. 

Richard Zavoda 

Manager, Environmental 

ISG Cleveland, Inc. 

1060 Eggers Avenue 

Cleveland, Ohio 44lOS 

Dear Richard: 

Air Compliance 

Testing, Inc. 

P.O. Box41158 Clevelloncl, Ohio 44141 

1-801J.EPA-AIFI1WIIW.Ai'l:emp.com 

teallngCIIalrcomp.com 

March 14,2007 

e folio=· . art pro.vides the results afth. ·e eamplian~ e.~ission testing condu~ en 

Febn.wy 16,200 . These results are a praduct aftbe application of the U.S. EPA Statienary 

. plin Methods listed in 40 CFR Part 60 Appendix A that were in effect at the time 

afthis test. 

Please mail one cepy of this report alang with any ether supportive precess operating Cilata 

callected during this test to your local EPA representative within 30 days af the actual test 

day. You sheuld alsa ll.ttaeh a oovcr letter (on oompany letterhead) stilting the purpose and the 

outoome af this test. Additienally, you may address, preferably in a timetable format, any 

abligations er implicatlens that might be necessary te achieve envirat'!mental eampliance 

because afthe result efthis test. 

Please do net hesitate to call if yeu have any questions or ceneems about these test results. 

On behalf ef Air Cempliancc Testing, I weuld alse like to persanally thank yeu fer the 

oppartunity te wark with you on this testing project and would enjey the apportunity to work 

with yeu again an any additional future testing projects. 

Sincerely, 

;2?~1) 1.: t., 

Rabert J. LisY, Jr. 

Quality Assurance Officer 
• 

• 

""' ISG Clevela11d l11c • 

~dl!le!4 MaJJ.,.. iMt~m ftl!lllli!!t.lil!!!Mllte,!il 

Mr. Ge~ l!!aker 

City ef Clevelar.l!il • DAQ 

1925 St Clair Avei1Ue 

Cievelam!il, OhiG 44114 

L$6 Clevelan!illn\1:. 

Pramtse No. 131SOI!l1S 13 

NG~i\1:8 of Cempl!anee 

Dear Mr. Baker: 

March 16, 2007 

ISG Clevelam!illnG. (l$G) sl:lemits,lhe enclese!il staek: test rasllilts fer line. HGt Dip Clalvan!ZiAg Lil'ie natural 

$las flrea a!i~Aeal flama.ee, seW~"ee Pl!l71, as "'l!llili!'elil ey the Title v Jil&rmlt iA!il permit-ta-lrtstatl No. 13- · l!l1!lt5. T:lte stMk tastiR(II fer Altfe(llen ellides tNOx) was GGfldl)0tel.!l. en fel:lfuacy 16, 20&7. 

l!l1!$e!il eFt •vaitaBle Information and Dellef ferme!il. af.ter ln<i!I!.IIRAg, I eel'lift. the ~11racy ef this statement 

11\at lllis souree l!las eempiie!il With the relewnt standard,. am;t tltat the statemeAts ami iAfermatien Ill llms 

report are true, accurate and cemplete. Please §It Rieb &veaa at (:218) 4211-6$42, if yl!iu llave any 

qt>Jestla!'lS 

~;u_ .· . • , Fe!ilar . . 

General Mama(ller 

AltaQhmeRt 

IS() Cleveland Inc. • Environmental • 3060 EggetS Avenue • Cleveland, Ohio 44105 • (216) 429-6542 • (216) 429-6631 fax 
Compliance Stack Emission Test Reoort -· 

!5G Cieyeland. Inc. 

Pll71 Exhaust Stack 

Rual Rma2 Raa3 Average 

Oxygen-Based Nitrogen Oxides Mass Emission Rate (lbiMMBIII 0.151 0.129 0.174 O.lSl 

Nittn~ten Oxides Mass Emission Rate (lblhr as NO, 22.49 19.92 20.89 21.10 

Nitrogen Oxides Concentration (ppmvd' 60.80 55.64 54.24 56.89 

Measured Awroximate Oxygen-Based Heat Input Rate (MMbtullu' 149.2 . 154.8 119.9 141.3 

Published Oxygen-Based F·Factor (Fd) (dscfiMMBIII 1!,710 8,710 8,710 8,710 

Meuured l'uel Factor Vl!lue (l'o 1.71 1.74 1.68 1.71 

Percent Excess Air(% 125.0 lll0.2 188.3 141.1 

Stack Gas Average Flow Rate (acfui. 115.289 110,759 ll7,5Ci4 114,537 

Stack Gas Average Flow Rate (scfin 56,930 55,229 57,593 56,5114 

Stack 9as Average Flow Rate (dsclin 51,630 49,971 53,776 51.793 

Stack Gas Average Velocity (lPm) 3,205 3,1179 3,2611 3,184 

Stack Gas AVetl!2e Static Pressure (in-H;,O) -0.47 -0.50 -0.46 -0.47 

Stack Gas Average Ttm! :•FJ 579 571 588 579 

Stack Gas PeteO!It I!Y .Vollll!18 Moistun> W.H.O'. 9.31 9.52 6.63 11.49 

Meuured Stack Inner DiamebM' (in)•• 7UOx&2.6S 79.80x &2.6S 79.110 X &2.6S 19.110 X &2.6S 

Percent lly Volume Carilon Dioxide in Stack Gas (Dry Basis) (%CO,] 5.13 5.40 4.00 4.84 

Percent by VoliUlle Oxv2en in Stack Gas (Dry Basis) (%().,] 12.13 11.50 14.13 12.59 

Percent bv Volume Nitrogen.in Stack Gas (l)ry Basis) C%N,J 82.74 83.10 81.83 82.56 

•"The P071 ---ollijltical in sllapo 

Table 2.2 - Emission Results 

Test Date: February 16, 2007 PageS Air Compliance Testing, Inc. -070212 
BLAST FURNACES CS AND C6 TEST SUMMARY 

NOVEMBER 1, 1994 
! 

LTV STEEL COMPANY 

CLEVELAND WORKS 

NITROGEN OXIDES EMISSIONS EVALUATION 

··., •. 

Prepared tor 

lTV Steel Company 

3100 East 45th Street 

Cleveland, Ohio 44127 

PN 5146-1 

Pr~lv.. 

Environmental Quality Mellag$.JMnt 

1310 Kemper Me~ Drive 

Cincinnati, Ohlo 4U40 
TABlE 2·1. SUMMARY Of TEST RESUlTS 

LTV STEEl. COMPANY 

CliEVIEII.AND WORKS 

. , ...... - 1'"'\t.i$#~~ r:J,_ Co;; 

• 

• 

• 

• 

Blast Flll'l*e M 01·1 

01~ 

Cl-3 

Av81l1QB 

IBiast~C-6 Cli-1 

()5.2 

CS-3 

Avetllge 

Blast~C-6 C6-1 

Ql-2 

~ 

l'wrllp 

Part per mllllon 

Pound par million l8lu 

11131 5.8 

5.8 

11101 7.J 

1.3 .. 

11!01 u 

u 

Rasulla detennlned during CD8I llril)g of Bollef a 

8.0 ppm Is Ilia lower detec:tlon llm!llcr analyzer 

0.9 28.4 

1.0 28.4 

1.0 27.8 

1.0 28.2 

u 21.8 

3.1 23.2 

3.9 21.8 

3.7 22.1 

1.1 25.4· 

4.11 22.3 

2.7 25.5 

a.o 24.4 

HM lb Ml'l'i>! 

...s.o 0.010 

...s.o 0.010 

...s.o 0.010 

...s.o 11.010 

...s.o 11.012 

...s.o 11.012 

...s.o 11.012 

...s.o 11.012 

7.2 11.018 

27.4 ll.tn 

23.2 11.053 

:IU 11.048 
PROPOSED NOx RACT EMISSION FACTOR CALCULATIONS BY SOURCE 
12/10/2008 

Proposed NOx RACT Emission Factor Calculations by Source 

No. 1 and No.3 Reheat Furnace: 

Per Bloom information, 

Preheat and Heat Zone Bloom Low NOx Burners (521.6 MMBTU/hr): 0.212 lbs/MMBTU 

Soak Zone Bloom Cold Air Burners (81.0 MMBTU/hr): 0.056 lbs/MMBTU 

Weighed NOx Base Limit: 0.191 lbs/MMBTU 

at 25% continpencY: 0.239 lbs/MMBTU 

,,Ro~~d to 0.24 lbs/MMBTU) 

No. 2 Reheat Furnace: 

Per Bloom information, 

Preheat Zone Bloom Low NOx Burners (338 MMBTU/hr): 0.212 lbs/MMBTU 

Soak Zone Bloom Cold Air Burners (81.0 MMBTU/hr): 0.056 lbs/MMBTU 

Per North American information, 

Heat Zone NA Low NOx Burners (183.6 MMBTU/hr) 0.097 lbs/MMBTU 

Weighed NOx Base Limit: 0.156 lbs/MMBTU 

at 50% contingency: 0.234 lbs/MMBTU (,.,,,_..-.~·-·······-·· .,.,_. ___ ,,_~---~--~ ·-- ------- --~ 

~~~nd to 0.24 lbs/MMBTU) 

"-·-~- ,_. ' __ /" . -.. . ., ____ _ 

Blast Furnaces Stoves: 

Per prior test information, 

NOx loadings: 0.046 lbs/MMBTU 

at 25% contingency: 0.06 lbs/MMBTU