ArcelorMittal Cleveland Flat Carbon Steel

November 15, 2010 Certified Mail- Return Receipt Requested Mr. Alan Harness Ohio EPA
- Division ofAir 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: 

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# ArcelorMittal

On September 16, 2010, ArcelorMittal representatives met with you and Jim Orlemann to discuss your letter to the General Manager ofthe ArcelorMittal Cleveland Inc. facility dated July 21, 2010 requesting corrective measures to address NOx emissions in excess ofthe 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 ofthis 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.com1. 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 ofthe 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 ofthe 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 ofthe 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 NOxwhen 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 ofthe three HSM reheat furnaces. Sincerely yours,

# ~**~** Rich Zavoda,

# ~ Environmental Manager
Attachment

cc: Mr. George Baker, City ofCleveland
- Division ofAir 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.comArcelorMittal Cleveland Works 3060 Eggers Ave Cleveland OH 44105 ATTENTION: SUBJECT: 

# Bloomengineering

November 15, 20I0

Mr. Rich Zavoda Bloom Engineering Low-NOx BumerTechnology Applied to Cleveland Works ReheatFurnaces 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 pushertype 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 LowNOx Burner Air**Sta~ed** Burners with other feasible burneroptions. Bloom 1500 Ultra LowNOx Air Staged Burners were installed in the pre-heat zone and the heat zone on each ofthe three reheat furnaces that serve the ArcelorMittal Cleveland Hot Strip Mill from 2006 through 20I0. This burner retrofit project replaced over 100 ofthe 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 ofreconfiguration 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 ofthe 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 ofthe 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 ofthe 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 offbased on furnace temperature. We understand from ArcelorMittal that the Cleveland Works does not have an aircompressor ofsufficient 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 the2 combustion air drops to the individual bumers would need to be modified (shottened) and then flanged to accommodate the installation ofthe 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 offofthe 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 ofthe burners. Additionally, the solenoid valves for on/offcontrol ofthe lances will require wiring and installation. The solenoid valves will each require I IOV 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 ofthe 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 ofless 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 ofthe 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 ofthe 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 ofa standard design 1610 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 ofSoak 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 ofburners at the U.S.Steel/Lorain Pipe Mill No.4 Rotaty Fumace. This is a BUDGETARY proposal, as ofyetthere 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 ofall the bumers in the Preheat and Heat zones (2) with Bloom I610 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:


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1. Type offumace: 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 

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v. Type offiring: 5 zone longitudinally fired, top & bottom with a rooffired solid soakhearth 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 preheattemperature (modeled): 950°F xiv. Amount ofexcess air (modeled): 5%b. USS/Lorain Pipe Mill #4 Rotary reheat furnace:

CONTROL TEMPERATURE 5Efi!NG5
1 -, - 1915 11' 2
- 2r30 ZONE 

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- 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 ofa typical tube mill rotary hearth furnace.

1. Type offurnace: Bar Product- Rotary reheat, rounds/billets 4

n. Material to be processed: round billets- in general discharge temp is less than that ofslabs iii. Production rate: USS Confidential information iv. Overall dimensions: USS Confidential information v. Type offiring: 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): 51.3xrr. Max zone temperature (modeled): 2350°F XIII. Air preheat temperature ( modeled): 750°F xiv. Amount ofexcess air (modeled): 5%

c. Discussion ofthe 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 ofabout 1.5 hrs while the 8,. slabs will require over 2 hours ofresidence 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 ofa 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 ofthe 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 ofwall to p01t ratio or burner density. With the pusher at 9.7 and the rotary at 51.3 -over a 5 fold difference, higherNOx 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 

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

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## ""' ""7 xiv. Amount ofexcess air- no difference. In conclusion, based on the overall technological improvements over I4 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 ofthe two fm11aces is reduced in the case ofthe 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 ofthe 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 15236ArcelorMittal Cleveland Flat Carbon Steel

December 12, 2008 Certified Mail- Return Receipt Requested Mr. Alan Harness Division ofAir Pollution Control Ohio Environmental Protection Agency Lazarus Government Center P.O. Box 1049 Columbus, OH 43216-1049
Subject: ArcelorMittal Cleveland Inc. Ohio EPA 1318001613 OAC 3745-110 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, ifyou 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
Preparedby: Environmental Quality Management, Inc. 1800 Carillon Boulevard Cincinnati, Ohio 45240

PN 050397.0020

December 2008

### CONTENTS


### Section 1 Introduction

..................................................................................................................... 1-1 2 Required Contents ofthe 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 Datafor Each Applicable NOx Source

......................................... 6-1 7 NOx Control Technologies That Are Not Applicable orTechnically Feasible at ArcelorMittal Cleveland

.................................................................................................. 7-1 8 General Discussion ofPotentially FeasibleNOx 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 ofProposed NOx Control Equipment

................................... 11-1 

### Appendix:

• ArcelorMittal ClevelandNOx PTE Emission Calculations • ArcelorMittal Cleveland NOx RACT Information & 

### Calculations • No. 1Reheat Furnace LowNOx Burners Cost Calculations • No. 2 Reheat Furnace LowNOx Burners Cost Calculations • No.3 Reheat Furnace LowNOx Burners Cost Calculations • ArcelorMittal Cleveland Plot Plat Showing AffectedNOx Sources • Documentation ofPrior NOx StackTest 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 Countythat have the potential to emit more than 100 tons per year ofnitrogen 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 combustionturbines, and stationary internal combustion engines. For affected sources ofNOx at an affected facility that is not subject to an NOx emission limit, oris subjectto a presumptive NOx RACT emission limit butthe 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 ofreducing the NOx emissions and to define RACT for the source. The NOx RACT Engineering Study mustbe completed no later than 1year, or December 12, 2008, from the effective date ofthis rule. Any source other than a boiler, gas turbine, or internal engine thathas the potential to emit less than 25 tons perunit 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 thatthe NOx RACT Engineering Study provide the following information: (a) The complete facility name and address. (b) The name, title, address andtelephone number ofthe owners or operator's representative within the company who shall be the contactperson for this facility regarding the engineering study and affected sources. (c) The name, title, address, and telephone number ofthe official who is responsible for approval ofthe 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 peryear). (vi) Annnal production rates for eachofthe three full calendar years precedingthe effective date ofthis rule. (vii) Average and maximum daily production rates for each ofthe three full calendar years preceding the effective date ofthisrule. (viii) The type ofcontrol equipment employed and the date installed. 

### (f) A plot plat which shows the general layout ofthe facility and the affected sources(s). (g) The following emission data for each affected source: (i) Average daily NOx emissions (pounds per day ofoperation) based upon the highest average daily productionrate for each ofthe three full calendar years preceding the effective dataofthis rule or any other year that may be representative ofthe highest daily emissions. (ii) Maximum daily NOx emissions (pounds per day ofoperation) based upon the highest maximum daily production rate for each ofthe three full calendar years preceding the effective date ofthis rule or any year that may be more representative ofthe highest maximum daily emissions. (iii) Annual NOx emissions (tons per year)based upon the highest annual production rate for each ofthe three full calendar years preceding the effective date ofthis rule or any period that may be more representative ofthe armual productionrate. 2-1

### (iv) Documentation ofthe efficiency ofthe existing control equipment. (v) Documentation ofany emission testing which as been performed. (h) A detailed discussion ofthe technical feasibility ofemploying each ofthe following types ofcontrol measures for each affected source (or combination ofsources): (i) Low NOx burners. (ii) Close coupled or separated over-fire ports. (iii) Flue gas recirculation. (iv) Burners out ofservice. (v) Steam/water injection. (vi) Dry lowNOxburners. (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 otherthan boilers). (xv) Process modification. (xvi) Fuel switching. (xvii) Low excess air. (xviii) Gaseous fuels reburn. (xix) Any other such RACT alternatives as are proposedby the owner or operator. A detailed engineering discussion is not required for those control measures which are not applicable to a particular source. (i) Foreach type ofcontrol measure that is determined to be technically feasible, an estimate ofthe control efficiency that can be achieved. (j) 

### For each control measure that is determined to be technically feasible, an estimate ofthe capital cost, annualized cost (including capital and operating cost) and the costeffectiveness (armual dollars per ton ofNOxremoved armually). (k) A comparison and discussion ofthe advantages and disadvantages ofthe control options that are determined to be technically feasible. (1) A recommended definition ofRACT for the source, including enforceable production limits, emission limits, control efficiencies, and/or operating limits. (m) An 

### expeditious schedule for implementingthe recommended definition ofRACT, including milestones for awarding contracts, initiating construction, completing construction, and performing emissions testing, ifnecessary, to demonstrate compliance with the approved definition ofRACT. (n) In the engineering study, all calculations ofthe 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 ofAir Pollution Control document entitled "Guidance for Estimating Capital and Annual Costs ofAir Pollution Systems." Subsections (a) through (d) ofthe 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, Ohio44105-1012 (b) The name, title, address andtelephone number ofthe 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 ofthe official who is responsible for approval ofthe engineering study: R. M. Zavoda Manager, Environmental ArcelorMittal Cleveland Inc. 3060 Eggers Avenue Cleveland, Ohio 44105-1012 (216)-429-6542 (d) The standard industrial classificationcode 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 ofthis study.

2-3

### SECTION3 NOx SOURCES AT ARCELORMITTAL CLEVELAND



### The ArcelorMittal Cleveland facility is located onthe CuyahogaRiver 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 ofNOxwithin 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 3745-110-03(J)(l8) oftheNOx RACT rules states thatthose boilers covered under the NOx SIP Call rules are also exempt from these requirements. These boilers include BOO! (Boiler A), B002 (BoilerB), 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.

3-1TABLE3-1 TITLE V PERMITTED SOURCES AT ARCELORMITTAL CLEVELAND Rated Rated Potential to Emission Unit Capacity Capacity EmitNOx NOxEmission # 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 P050 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 sourcesNo. 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 FORBOILERS 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 combustionengines. The facility contains two boilers which fall under these requirements. The presumptiveNOx RACT emission limits for these boilers are sununarized in Table 4-1.
TABLE 4-1 PRESUMPTIVE NO RACT LIMITS FORAPPLICABLE 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 subjectto anNOx emission limit, the rules allowthe facility to claim that the applicable limit is technically infeasible and/or economically unreasonable (i.e., not cost-effective) andthenconduct a detailed engineering study to determine the technical and economic feasibility ofreducing the NOx emissions and to define RACT for the source. ArcelorMittal Cleveland accepts the presumptiveNOxRACT 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. OnNovember 2, 

### 1994, Enviroumental Quality Management, Inc. (EQ) conducted stacktesting ofthis common stack utilizing U.S. EPA Method 7. The results ofthe 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 FOREACH 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 dailyNOx 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 ofthis 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 ofthe three full calendar years (2004, 2005, and 2006) preceding the effective data ofthis rule. PriorNOx emission stacktests
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 P050 6171 78 94 

# ,......•• Anne"! South

# ~~~ Continuous 6/89 65 71 (Hot Dip) Galvanizing Line P903 C5 Blast 6/43 176 197 Furnace: (total ofthree (total ofthree Stoves, Flare, sources) sources) andr, P904 C6 Blast 6/52 466 S06. Furnace: (total ofthree (total ofthree Stoves, Flare, sources) sources) and Casthouse P905/ No.2 BOF: 6/66 1133 1246 P906 b Vessels, Ladle (total offour (total offm,1r Preheaters and sources) sources) Flare P925/ No.1 BOF 6/61 370 40?. P926' Vessels and L. (total ofthree (total ofthree
n. -" sources) sources) 'See Arcelorinmm lNOx RACT uuv""""v" and r h ArcelorMittal Cleveland has renamed these sources No. 1BOF. '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 · Iat 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 ofthree

sources)

81! N/A (total ofthree

sources)

202.9 N/A (total offour

sources)

61.2 N/A (total ofthree

sources)

,,,

## E:i?s~on TestiRg

Doc. See attached reportsummaryMarch 2003 tests See attached reportsummaryMarch 2003 tests see attached reportsummaryMarch 2003 tests None
None
See attached reportsummaryFebruary 2007 tests See attached reportsummaryNovember 1994 tests See attached reportsummaryNovember 1994 tests_

None

None

### SECTION6 REQUIRED PRODUCTIONDATA FOREACH APPLICABLE NOX SOURCE

The rules also impose the following production data to be reported for each source, as summarized inTable 6-1. For sources listed for ArcelorMittal Cleveland in which the only emissions are the result offuel 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 uponthe highest average daily production rate for eachofthethree full calendar years (2004, 2005, and 2006) preceding the effective data ofthis rule. Annual NOx emissions for each source are based upon the highest armual production rate for each ofthe three full calendaryears (2004, 2005, and 2006) preceding the effective data ofthis 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 NotStrip 2417/52 483('MMBtu min. 7028 MMBtu Mill Furnace #2 based on 2004 (Sept2005) 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 P050 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 ClevelandNOx RACT InformatiOn and CalculatiOns. bArcelorMittal 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 ofControl noted a Eauinment 1,633,850 MMBtu**Low~NOx** burners- (2004) preheatand 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 LowNOx burners in (2006) indirect fired section. 1,396,775 tons None (2004)

I,288,924 tons None (2006)

2,820,292 tons None (2004)

65I,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 ofthese technologies are not applicable to the facility. Several ofthese 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. Otherthan 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 

### 1MMBtulhrto 20 MMBtulhr in size. In some cases that will be discussed later inthe document,**low~NOx** 

### andUltra-low-NOx burners have already been installed to replace conventional or standard burners. Forthose sources, ArcelorMittal Cleveland believes that no further investigation ofNOx alternative control technologies is needed, andthat NOx RACT has been satisfied. The following is a summary ofthe 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 ofstage combustion. With OFA, the burners are fired more fuel-rich than normal, andthe additional air needed to complete combustion is admitted through overfire air ports or an idle row ofburners. This technique is applicable to all fuels. Inthis technique a controlledportion ofthe total combustion airflow, typically 10 to 20 percent, is directed through over-fire ports located above the highest elevation ofburners inthe furnace. The removal ofairflow from the burners results in a fuel-rich primary combustion zone to limit the NOx formation. The combustion ofthe CO produced inthe 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. Forthe 7-1

### remaining NOx emission sources, this approach could not be adaptedto these operations and is deemed technologically infeasible.



### 7.2 Flue Gas Recirculation (FGR) This method ofcombustion uses flue gas recycled from the stack and mixed with combustion air to reduce the oxygen content ofthe combustion air and cool the flame. The ' 

### target percentage ofthe 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 ofthe flue gas to the primary combustion zone. It reduces NOx formation by two mechanisms. The recycled flue gas contains combustionproducts that act as inerts during combustion and lower the peakflame temperature, reducing thermal NOx formation. To a lesser extent, FGRalso 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. Forthe remaining NOx emission sources, this approach could not be adapted to these operations and is deemed technologically infeasible.



### 7.3 Burners Out ofService (BOOS) Burners out ofservice is a simple technique to achieve NOx reductions ofaround 15 percent in multiple burner level furnaces with multiple levels ofburners. In this technique, fuel flow is isolated from selected burners and only air passes through the burners. The balance of the fuel required to maintainthe unit firing rate is redirected to otherburners. This technique provides for air and fuel staging in the combustion zone. Depending onthe capacity margins in the existingburner design, a slight furnace de-rate penalty may result. The specific capacity of the pulverizers will also affect the implementation ofthis 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 beremoved 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/WaterInjection Water or steam traditionally has been injected into combustionturbines to reduce the firing temperature and thereby minimizeNOx emissions. This combustion control technology, however, has also beenapplied to furnaces. Adding water or steam in the combustion zone can suppress NOx formation by up to 25 percent. The use ofwater/steam injectionto control NOx emissions has several disadvantages. Carbonmonoxide and unburned hydrocarbons increase, especially at low loads. Fuel consumption increases by as muchas 5 percentto make up for the heat ofvaporization ofthe water. Ifsteam injection is utilized, about 50 percent higher mass rate is required compared to water injection and there is an inherent loss ofenergy that is required to produce the steam. Additionally, waterthat has been extensivelytreated is lost out ofthe stack. Forthe remaining NOx emission sources, this approach could notbe 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 ofoperationonliquid fuel. The combustion system includes four major components: fuel injection system, liner, venturi, and cap/center body assembly. The configuration ofthese 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 ofsetting the time that a spark will occur in the combustion chamber (during the power stroke) relative to pistonposition and crankshaft angular velocity. Timing retard refers to the number ofdegrees that ignition is delayed after the pointthat 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-CircuitAfter Cooling Separate-Circuit After Cooling is anothertechnology that has been applied to ships. The freshwater circuit is self-contained and is used continuously to cool the engine. The facility does notpossess such equipment for which this technology could be applicable.

7.8 Selective Noncatalytic Reduction (SNCR) Selective non-catalytic reduction involves the injection ofammonia or urea into a region where the gas temperature is inthe range of 1500 to 2100°F. At lower flue gas temperatures, the reaction rate will decrease resulting inhigher levels ofNOx and increased ammonia slip (unreacted ammonia). At higher flue gas temperatures, not only will the effectiveness ofthe reagent reaction withNOxbe diminished, but increased NOx levels may occur due to the oxidation of the reagent. The objective ofthe system is to deliver the required reagent inthe temperature window with sufficient residence time for the required reaction to occur. The minimum residence time required is 1 second. The design ofthe reagent injector and the specific injection locations are therefore an important part ofthe SNCR system design. Complete coverage ofthe flue gas in the furnace requires that multiple injection nozzles be used inthe SNCRdesign. Multiple injection ports canbe provided either by installing multiple injectors orretractable lances with multiple nozzles. To maximize NOxreduction 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 heatthe gases to over 1500°F, take offthe existing exhaust stacks, and replace them with SNCRunits and new stacks on the existing Hot Strip Mill roofwas 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 beendeveloped to control carbon monoxide, hydrocarbons, andNOx emissions from rich-burning engines used in gas compression, irrigation, pumping, and power generation. Ithas also been used to control tail-gas emissions from nitric acid manufacturing plants. The facility does not possess suchequipment for which this technology could be applicable.



### 7.10 Fuel Emulsification This innovative NOx technology has been used on ships, primarily onthe 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 combustionprocess to lower maximum combustion temperature, and therefore lower NOx formation, with an insignificant increase infuel consumption. This technology can also be applied to a wide variety ofsmaller displacement diesel engines. The facility does notpossess 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 ofNOxreductions. Hazardous waste incinerator manufacturers have developed artificial intelligence-basedNOx control systems. The facility does not possess paint lines orhazardous waste incinerators in whichthis approach could be evaluated.
7-5

### 7.12 Scrubbing (for sources other than boilers) 

### Scrubbing using urea or the addition ofhydrogen peroxide withinthe pickling baths of stainless steel operations is effective for the control and suppression ofthe 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 preheaters).

7.14 Low Excess Air 

### Low excess air (LEA) is a combustion modification technique in which NOx formation is inhibited by reducing the excess airto less thannormal ratios. It reduces the local flame concentration ofoxygen, thus reducing boththermal and fuel NOx formation. It canbe usedfor all fuels and all firing methods. 

### Itis easily implemented and can be used in bothnewand retrofit applications. The potential ofLEA as an NOx control technique is limitedby the onset ofsmoke or CO emissions. Tests onutility boilers have indicated that LEA firing can reduce NOx emissions between 16 and 21 percent as comparedto baseline levels. Other sources have suggested reductions ofup to 16 percent. Inthe case ofutility boiler applications, LEA also increases thermal efficiency. It decreases the volume ofcombustion air to be heated, allowing more heat ofcombustionto be transferred, thus lowering fuel requirements for a given output. To maintain proper control ofthe furnace pressure, positive pressure mustbe maintained inthe furnace to prevent the influx oftramp air. A number ofother factors affect the excess air levels that can be implemented. These include the type offuel fired, uniformity ofthe air/fuel ratio, air and fuel control lags during load swings, and othercombustion control features such as staging offuel 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 ofburners above the primary combustion zone. Typically, up to 25 percent ofthe 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 ofadditional NOx is limited due to the lower oxygen concentrations and lower combustiontemperature 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. Reburn combustion requires significant changes to the design ofthe furnace and the additional operating expense ofthe reburn 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 generationby carrying out initial combustion ina primary fuel-rich combustion zone and subsequently completing combustion at lower temperatures in a second fuel-lean zone. This technique is essentiallythe 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 itselfas is done with LNBs. In practice, OSC is implementedthrough biased burnerfiring (BBF), burners out of service, or overfire air. The latter two techniques have beenpreviously discussed. In BBF, fuel distribution among the burners is redistributed so that the lower rows ofburners are fired more fuel rich than the upper rows. The additional air neededto complete combustion is provided through the upper rows ofburners, 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 POTENTIALLYFEASIBLE NO, CONTROL TECHNIQUES FORTHE REMAINING NOx SOURCES

There are three fundamentally different mechanisms ofNOx formation. These mechanisms yield: thermal.NOx, fuel NOx, and promptNOx. The thermal NOx mechanism arises from the thermal dissociation and subsequent reaction ofnitrogen and oxygen molecules in combustion air. The fuel NOx mechanism arises from the evolution and reaction offuelbound nitrogen compounds with oxygen. The promptNOx mechanism involves the intermediate formation ofhydrogen cyanide (HCN), followed by the oxidation ofHCNtoNO. Natural gas andmost distillate oils have no chemically bound fuel nitrogen, and essentially all NOx formed from the combustion ofthese 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 canbe placed into one oftwo basic categories: (1) techniques designed to minimize NOx generation and (2) techniques to remove previously generatedNOx 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 treatmenttechniques such as selective catalytic reduction (SCR) and selective noncatalytic reduction (SNCR) are examples ofthe second. FGRand SNCR have already been ruled out as technologically infeasible for ArcelorMittal Cleveland. The following is a general discussion oflow-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 ofLNBs is to minimize NOx formation while maintaining acceptable combustion ofcarbon 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 ofNOxemissions. Boththe temperature and oxygen concentrations are lowered in the "fuel-rich" zones. With air staging, normally 75 to 85 percent ofthe air is supplied to the primary combustion zone alone with all ofthe required fuel. This creates a "fuel-rich" flame zone where the formation ofNOx is retarded due to sub-stoichiometric (i.e., lack ofoxygento achieve completed combustion ofthe hydrocarbons in the fuel) combustion conditions. The substoichiometric conditions limit NOx formation by reducing the combustion temperature and limiting the amount ofoxygen available for NOxproduction. The remainder ofthe air is injected outside the primary combustion zone to complete the combustion ofthe fuel. Low-NOx burners relying on staged air typically achieve NOx reductions of40 to 50 percent in gas-fired furnaces and 30 to 40 percentfor oil-fired and coal-fired furnaces. A low-NOx burner designed for fuel staging works the opposite ofair staging. Inthe primary combustion zone, about 60 to 70 percent ofthe fuel is injected with all ofthe air. Although excess oxygen is available, NOx formation is retarded due to the low combustion temperature. The remainder ofthe fuel is injected downstream ofthe primary combustion zone. PromptNOx 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 ofless than**~in** 

### certain gas-fired applications. Ultra-low NOx burners generally premix significant amounts offuel 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 ofa noble metal catalyst bed. The NH3 reacts with the NOx in the gas stream on the surface ofthe catalystto form molecular nitrogen and water. The optimal reaction temperature for the SCR catalyst is 500° to 1100°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 ofthe SCRunit's catalyst are poisoning due to the presence oftrace metals or other chemicals in the gas stream and fouling/plugging due to particulate emissions coatingthe catalyst. SCRcouldhave potential applicationto the reheat furnaces and the Galvanizing Line armealing furnace, as will be discussed later.



### 8.3 

### Fuel Switching Thefuel order ofgreatestNOx formation on a lbs/MMBtu basis is coal, oil, natural gas, and then blast furnace gas. NOxemissions are considerably lower for blast furnace gas, which bums at a much lower flame temperature thannatural gas. The utilization ofthe maximum available amount ofblast furnace gas is always the objective ofArcelorMittal 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 muchblast furnace gas as possible.

8-3

### SECTION9 SOURCE-BY-SOURCE NOx RACT DISCUSSION

9.1 Reheat Furnaces
The total firing capacity ofeachreheat furnace is 602.6 MMBtulhr. Only natural gas can be fired in them. Each furnace has three unique zones: the preheat zone, healzone, and soak
zone. The preheat and heat zones have top andbottom 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 soakzone has 18 burners each rated at 2.4 MMBtulhr, followed by 12 burners eachrated at 1.2 MMBtulhr, followed by 12 burners each rated at 1.95 MMBtulhr. The burners in the preheat and heat zones ofeach 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 ofthe combustion airhas a large impact onuncontrolled NOx emissions. Increasing the

..combustion air temperature from 1 00°F to 1 000°F will increase uncontrolled NOx emissions by a factor ofabout 4.**----w------~-~** 

## ---•**~------" -~**  

## -- - -**--~;;;luation-~f th~** **pot';;"uti~l-t~~b;;.~!ogi~-;;1 fe~ibill~y**  ofSCR for each reheat furnace
was performed. Each reheat furnace has avertical exhaust stack venting through the top ofthe building that contains parallel roofmonitors. It is notpossible to install an SCRunit with an ammonia feed tank on the roofofthis building. Likewise, the cost ofreplacing the existing 

# \

# I

I 

### stacks, then installing new stacks and ducts down to ground level, and utilizing three new S5/ units is costprohibitive 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 ofPSD BACT analysis. This unit has experienced problems over the years, and therefore no BACT evaluations since have supported the installation ofSCRfor reheat furnaces.

9-1

### Within the past 2 years and in anticipation ofthis rulemaking, ArcelorMittal Cleveland has installed low-NOx burners throughout several zones ofeach ofthe three reheat furnaces. A summary ofthese 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 ofthe inherently reduced NOx concentration resulting from the use ofcold combustion air. Additional information related to the soak zone burners is provided below. Priorstack testing ofthe source !Jdore·the burner changes resulted in a three-furnace average NOxemissions of,O.Sl lb/MMBta. Based on Bloom vendor information, the new ''-. 

### preheat and heat zone low-NOx burners shouldresult in a 0.298lb/MMBtureduction inNOx

.**~** 

### overall, or0

..21211J/JylMBtu. Based on 2006 fuel usages for the furnace and actual capital and estimated installation costs,ArcelorMittal Cleveland calculates an annualized costper actual ton ofNOxremoved of$1048/ton as a result ofthe 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 airburners 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% ofthe total NOx emissions from the furnace. In accordance with OAC 3745-110-03 (I)(l), which allows ArcelorMittal Clevelandto recommend an "operating requirement" as an acceptable option to satisfy anNOx RACT definition, ArcelorMittal Cleveland recommends an "operatingrequirement" for the No. I Reheat Furnace which restricts the use ofburners to only those that are equal to or less than the 9-2

### existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes anNOx RACT ··**.~ '-~---'-·"":'-**  ' 

### expected NOx emission factor of0.,4;4lb/MMBtufor the No. 1Reheat Furnace based on vendor-

.. ,._;..- . ) 

### expected NOx performance/and a twenty-five percent contingencyf;lctor. See attached

-- -·-"'**·-~.::;.:~~~::~';;:'-~-·--=-** 

### calculations supportingthe proposed expectedNOx emission factor.



### 9.3 No.2 Reheat Furnace

# ~---~~celorMittal Clevelandreplaced the 18 Bloom 1200 Series conventional 

## I burners inthe heat zone withNorthAroerican 482 LNI- 14 x 848 low-NOx burners. The 42 

# I burners inthe soak zone were replaced by more-efficient, but conventional burners. 

# I ArcelorMittal Cleveland did not installlow-NOx burners inthe soak zones because ofthe inherently reducedNOx concentration resulting from the use ofcold combustion air. No burners

lb/MMBtu. Based on2007 fuel usages for the furnace (first full year ofoperation) 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 thatNOx RACT was '-...[""-,.=::::·-:'::':: 

### met at that time for those burners. According to Bloom vendor information, the new soak zone burners have expectedNOx 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-NOx burners in the soak zone due to their inherently lowNOx emissions. NOx emissions for the soak zone burners comprise approximately 4 to 5% ofthe total NOx emissions from the furnace. ArcelorMittal Cleveland also determined the cost per ton ofNOx removed for the preheat
zone. Based onBloom vendor information, the new preheat and heat zone low-NOx burners should result in a 0.298 lb/MMBtureduction in NOx overall, or 0.212 lb/MMBtu. Again, based
on2006 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 basedonthe installation oflow-NOx burners for the preheat zone to be $824/ton. Calculations are included in the Appendix. NOx RACT supports the installation oflow-NOxburners in the preheat zone oftheNo.2 Reheat Furnace. In accordance with OAC 3745-110-03 (!)(!),whichallows ArcelorMittal Cleveland to recommend an "operating requirement" as an acceptable option to satisfy an NOx RACT definition, ArcelorMitta1 Cleveland recommends an. "operatingrequirement" for the No. 2 Reheat Furnace which restricts the use ofburners to only thoseburners that are equal to or less than the existing manufacturer'sNOx 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 currentNorthAmerican burners in the heat zone have resulted in

. 

### ' performance problems in this application, ArcelorMittal Cleveland reserves the right to replace these burnerswithl;mrners that are equal to or less than the existing manufacturer's NOx specification ofnon-North Americanburners 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 orequivalent. ArcelorMittal Cleveland proposes anNOx RACT_ expected NOx emission factor of0.24.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 ofthe othertwo reheat furnaces. The contingency factor is based onthe current, unique utilization ofa combination ofmultiple burner manufacturers within the same furnace, prior operating experience with the NorthAmerican burners that were replaced with non-North Americanburners and to be consistent with the proposed NOx RACT expected emission factor ofthe other two reheat furnaces. See attached calculations supporting the proposedexpectedNOx 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 ofthe inherently reduced NOx concentration resulting from the use ofcold combustion air. Prior stack testing ofthe

## ofu~~before the burner changes resulted in a three-furnace average NOxemission 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/MMBtureduction in NOx /---·ovefa11, or0.212lb/MMBtu. Based on 2006 fuel usages for the furnace and actual capital and estimated installation costs, ArcelorMittal Clevelandcalculates an annualized cost of$1104 per actualtonofNOx removed as a result ofthe 2006 burner changes. Calculations are included in the Appendix.

·

### .• ArcelorMittal Cleveland believes that

## t~9J~brlrner changes inthe 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 soakzone burners have expectedNOx

## ~~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 supportedby the further installation oflow-NOxburners in the soak zone due to their inherently lowNOx emissions. NOx emissions for the soak zone burners comprise approximately 4% ofthe total NOx emissions from the furnace. In accordance with OAC 3745-110-03 (I)(!), which allows ArcelorMittal Cleveland to recommend an "operatingrequirement" as an acceptable option to satisfy anNOx RACT definition, ArcelorMittal Cleveland recommends an "operating requirement" for the No. 3 Reheat Furnace which restricts the use ofburners to only those burners that are equal to or less than the existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes an NOx ' ' 

### RACT expectedNOx 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 expectedNOx emission**factor~** 

### 9.5 Batch Annealing In general, annealing furnaces, whether continuous orbatch, subject steel products to a plannedtime-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 atthe North Annealing and SouthAnnealing 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 withboth sources combined. As such, ArcelorMittal Cleveland considers their applicability under this rule to be questionable. However, ArcelorMittal Clevelandwill considerthese sources to be applicable under this study. All the batch annealing furnaces bumnatural gas exclusively and contain burners manufactured by North American. Because the emissions ofthe batch annealing furnaces are fugitive in nature, SCR is immediately ruled out. Based oninformation provided by North American, the existing 4422-4 burners have**inher~ntly** 

### low NOxemissions (0.10 lb/MMBtu). This value is identical to the already accepted
more stringent BACT (Best Available Control Technology) value inIndianabased on AK Rockport Works batch annealing furnace low-NOx burners. A value of0.10 lb/MMBtu is also the most common one posted onthe EPA BACT/LAERClearinghouse. A low-NOx burner manufacturedbyNorth American was also investigated. This burner is not the same configuration and size ofthe existing burner, however, and thus substantial modifications would be needed. As such, ArcelorMittal Cleveland believes thatNOx RACT is satisfied by the installation ofthe 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 ofburners to only those burners that are equal to or less than the existing manufacturer's NOx specification. ArcelorMittal Cleveland proposes anNOx RACT expectedNOx emission factor of0.10**lb/MMB~**

### based onthe use ofthe existingNOx 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 of98.60 MMBtulhr. These burners
are manufactured by Selas. Following the direct-fired section, there are several hundred indirectfired radiant tube burners with a total of60.57 MMBtulhr. These burners are manufactured by North American. Both SCR and low-NOxburners were evaluated. SCRis technologically feasible for a Greenfield site. Such a control device was built to control NOx emissions from an annealing furnace ona continuous hot-dip galvanizing line at AK Steel Rockport Works. However, Rockport was a Greenfield location and was part ofa BACT PSD pennit approval process. For the ArcelorMittal Cleveland Continuous (Hot Dip) Galvanizing Line, itis cost prohibitive to install an SCRunit onthe exhaust ofthe annealing furnace. The existing stack location was visually inspected as a result ofthis study. Two exhaust ducts (one from the directfired section and one from the radiant tube section) discharge into a common stacklocated inside the CGL Building. There are spatial considerations in the removal ofthe existing exhaust stack, subsequent relocation ofthe three ducts into a common duct, and relocation through an SCR unit and new exhaust stack onthe outside ofthe building. ArcelorMittal Clevelandbelieves that the installation ofSCRis technologically infeasible for NOx RACT purposes. North American was notified about its existingburners used onthe indirect-fired section. It confirmed that their existing burners (Model No. 4325-5) are low-NOx burners. The expecte NOxloading 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 newerburners simply for purposes ofNOxreduction. ArcelorMittal Cleveland concurs with North American's opinion onthis 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. Basedon information obtained from Selas Furnace, the expectedNOxemissions 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 anNOx RACT definition, ArcelorMittal Cleveland recommends an "operating requirement" for the Continuous (Hot Dip) Galvanizing Line annealing furnace which restricts the use ofburners to only those burners that are equal to or less than the existing manufacturer'sNOx specification. ArcelorMittal Cleveland proposes an NOx RACT expectedNOx emission factor ofQ.23

_ lb/MMBtu applicable to the single furnace exhaust stackthat includes the combination ofboth**,,..-.-·----··~--.** ' 

### furnace sections. This is the. existing NOx limit for this source. A stacktest conducted on February 16, 2007 and submittedto the City ofClevelandprovided the NOx results of0.15 lb perMMBtu.



### 9.7 Blast Furnaces Stoves Blast furnace stoves are anNOx emission source because they consume large quantities offuel. At ArcelorMittal Cleveland's two blast furnaces, however, the only fuel utilized is BFG, whichhas a low heating value and contains inerts, factors that reduce flame temperature. Thus, the NOx concentrationinblast furnace stove flue gas tends to be low and the potential for NOx reduction is considered to 

### be small. Attached to this study are stacktesting results confirming this fact. As such, ArcelorMittal Cleveland considers RACT to have already been satisfied with the use ofblast furnace gas as the only fuel. In accordance with OAC 3745-110-03 (I)(l), which allows ArcelorMittal Clevelandto 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 ofburners to only those that are equal to orless thanthe existing manufacturer'sNOx specification. ArcelorMittal Cleveland proposes anNOx RACT expectedNOx emission factor of0.06lb/MMBtubased 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 suppressionto minimize the formation ofparticulate emissions during casting. Natural gas is used as the fuel for flame suppression for bothblast furnaces. The gas is directed toward the ends ofpipes 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 BlastFurnaces Flares Similar to the stoves, ArcelorMittal Cleveland considers NOx RACT to have already been satisfied with the use ofblast 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 ofsteelmaking is an exothermic process that does not require the burning offossil 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 ofair, and the off-gases are subsequently flared. A potential for NOx generation does exist during the combustion ofthe waste gases. Nitrogen oxides production from this process had beenestimated to range from. 30 to 180 ppm, or 0.36 to 1lb NOx perton ofsteel produced.**-~** 

### The combustion ofthe waste gas results in the generation ofNOx. There are no existing BOFs in the United States (and to the best ofArcelorMittal Cleveland's knowledge, the world) that have any kind ofNOxemission controls. Nor are any control techniques even suitable or feasible. Outlet temperatures from an electrostatic precipitator (ESP) are too low for SCRto be feasible. Although the temperatures for SNCR may be suitable for a short period oftime prior to the control equipment, the large amount ofparticulate matter (estimated at 50 lbs/ton ofsteel produced prior to the control equipment) makes any post-combustion control infeasible. ArcelorMittal Cleveland utilizes bothtypes offurnaces 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). Forthe open-hood vessels, the combustion occurs at the mouth ofthe 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) offurnace operation. Because SCR catalysts require high gas stream temperatures (500 to 1100°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 ahuge energy penalty (probably natural gas combustion) and result in additional NOx emissions, along with CO and C02 emissions. Additionally, ifthe exhaust gas temperature drops below the SCRcatalyst range, unreacted arnrnonia (referred to as "ammonia slip") would be emitted directly to the atmosphere. Otherparameters that can affect the performance ofthe SCRunit's catalyst are poisoning due to the presence oftrace metals or other chemicals in the gas stream and fouling/plugging due to particulate emissions coating the catalyst. The batch-wise operation ofa 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 ofairflow volume and NOx generation. Further, the SCR catalystbed 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 ofgas flow, temperature, NOx concentration, and potential catalyst fouling make SCRtechnically 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 8to 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, SCRis immediately ruled out. Based on information provided byNorth American, the Magna Flame burners have inherently low NOx emissions (0.08 and 0.097 lb/MMBtu). Anewer design low-NOx burner
was investigated. However, it is technologically infeasible to install this burnerbecause ofthe 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 ofthe existing burners, and no additional operating requirements are proposed. ArcelorMittal Cleveland proposes a NOx RACT expectedNOx emission factor of0.10 lb/MMBtu based onthe
use ofexisting low-NQx burners for this application.

9-12

### SECTION 10

Table I0-1 presents a summary ofthe NOx RACT recommended controls and operating requirements that were evaluatedand 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 FACTORFORAPPLICABLE 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 ,,~.**  P050 Anneal

- South LNBs Existing burners. 0. I0 lb/MMBtu P071 Continuous LNBs, SCR Existing LNBs for the 0.23 lb/MMBtu '- i..M; 5r •., 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. Preheaters 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 contraI. Existing burners for ladle

preheaters. LNBs not technologically feasible

for process control. \ 0.06 lb/MMBtu

0.I0 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 ofthe No. 2 Reheat Furnace. Upon approval ofCapital appropriations, vendor selection, procurement ofthe equipment, and installation and startup ofthe 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 combustionmodifications, including the installation oflow-NOxburners, contingentupon Ohio EPA Director approval per OAC 3745-110-03(I)(2) and reasonable approval notice providedto ArcelorMittal Cleveland Inc. by the Ohio EPA. Futhermore, ArcelorMittal Cleveland proposes to installlow-NOx burners inthe preheat zone of the No. 2 Reheat Furnace based onthe 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-NOxburners prior to resuming operation ofNo. 2 Reheat Furnace for any operation after December 12, 2009.

11-1

### APPENDIX

### ARCELORMITTAL CLEVELAND NOx PTE EMISSSION CALCULATIONSArcelorMittal Cleveland PTE NOx Emissions Calculations

Page 1ArcelorMittal Cleveland PTE NOx Emissions Calculations

Page2ArcelorMittal Cleveland PTE NOx Emissions Calculations

Page3ArcelorMitlal Cleveland PTE NOx Emissions Calculations

Page4ArcelorMittal 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 & 

### CALCULATIONS12/11/2008 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 bythe NOx SIP Call rules.
8004 Boilero 467 BFG/NG/Coal none N/A (under NOx 1469.1 N/A, see comments Exempt underthe 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 < 25tons/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%. P050 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 < 25tons/yr - exempt from rules Caster

---------**~** // . c;;.23Jbs/MMBTU_./ 16.0.2 P071 _/·Continuous 159 NG low NOx 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. ( & 1.2timesthe \ 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/Afor 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/Afor 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

< 1l 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 2006EMISSION 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

< 1JLight purple: assumes max day is 10% greater than an average day. DAYS) DAYS) DAYS) Burnt orange: actual max monthly average divided by days in monthEMISSION 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) of3 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 maxyear 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

(1JLight 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 of602.6 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/hrtotal 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/hrtotal 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/hrtotal; 12- 1.95 MMBTU/hr burners at 14.4 MMBTU/hrtotal; 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 perton of NOx reduced less than $4000/ton.CALCULATION FOR THE ANNUALIZED COST PERTON NOx REMOVED BASED ON THE 2006 BURNERCHANGES FOR THE PREHEAT ZONE AND HEATZONE 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): IndirectAnnual Costs (lAC): Overhead (0.60(0+M)) Administrative (0.01TCC) Property Tax (0.01TCC) Insurance (0.02 TCC) Total IndirectAnnual 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 ofthe 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/hrvalues. 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 of602.6 MMBTU/hr burner capacity forthis furnace. SUMMARY OF 2007 BURNER CHANGES HeatZone: 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/hrtotal 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.

### t')1;~l SoakZone: ('' ·' 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 representa 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 forthe HeatZone 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 FORTHE ANNUALIZED COST PER TON NOx REMOVED BASED ON THE 2005 BURNER CHANGES FOR THE HEATZONE 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 DirectAnnual Costs (DAC): IndirectAnnual Costs (lAC): Overhead (0.60(0+M)) Administrative (0.01TCC) Property Tax (0.01TCC) Insurance (0.02 TCC) Total IndirectAnnual 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 othertwo 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 perton NOx removed ifthe conventional Bloom 1200 burners in the Preheat Zone were replaced with Bloom 1500 low NOx burners. CALCULATION FORTHE ANNUALIZED COST PERTON 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): IndirectAnnual Costs (lAC): Overhead (0.60(0+M)) Administrative (0.01TCC) Property Tax (0.01TCC) Insurance (0.02 TCC) Total IndirectAnnual 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.IJj,"- P0 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 ofthe 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 HeatZone Burners proportional to MMBTU/hrvalues. Adjusted to 2008 dollars. Includeswaste disposal of refractory brick. Assume similar costs for No. 2 Reheat Furnace replacement. (4) Assume no production lost during the outage as the othertwo 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 LOWNOx BURNERS COST CALCULATIONS

### ArcelorMittal Cleveland No. 3 Reheat Furnace NOx RACT Analysis 

# yoc\

# 8' There is a total of602.6 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/hrtotal There are 10- 16.9 MMBTU/hr burners in the bottom section: 169.0 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 Bloom information, use 0.212 lbs NOx/MMBTU as the expected NOx emissions for the newer burners. HeatZone: 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/hrtotal There are 10- 10'2 MMBTU/hr burners in the bottom section: 102.0 MMBTU/hrtotal 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 forthe newer burners. SoakZone: 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/hrtotal; 12- 1.95 MMBTU/hr burners at 14.4 MMBTU/hrtotal; and 12 -1.20 MMBTU/hr burners at 14.4 MMBTU/hrtotal 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 HeatZone burners satisfied the requirements in the NOx RACT rules to install NOx controls with annualized costs perton of NOx reduced less than $4000/ton.CALCULATION FORTHE ANNUALIZED COST PERTON NOx REMOVED BASED ON THE 2006 BURNER CHANGES FORTHE PREHEAT ZONE AND SOAKZONE 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): DirectAnnual 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): IndirectAnnual Costs (lAC): Overhead (0.60(0+M)) Administrative (0.01TCC) Property Tax (0.01TCC) Insurance (0.02 TCC) Total IndirectAnnual 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)

rReferences: (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 ofthe 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/hrvalues. 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.

### ARCELORMITTAL CLEVELAND PLOT 

### PLAT SHOWINGAFFECTED NOx SOURCES

# •=-=----====----Meters 0 145 290 580 870 1,160

### DOCUMENTATION OF PRIORNOx STACKTEST RESULTS- SUMMARY REPORTS

### DOCUMENTATION OFPRIORNOx STACKTEST RESULTS SUMMARY REPORTS

### BOll..ERS 1 AND 2 TEST SUMMARY NOVEMBER2, 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 coatfiring ollloller3 5.0 ppm Iathe lowerdetection limitfor 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. 

# lI

' /



# . A:Ir·CompliaiJce ··Testing, Inc.·

Rich!ll'dZavada l:lnv:iram;nental**Milllj~ger** 

### ISG 

### ClevelandIm:i. · ·· '060Eggers**Av~nue** 

### Clevelarid, Ohio 441OS

. '•' 

### 06\U'Richaf:d: · PqfloX.41156,:Cil>V.IOrnl

### OK44141 Plione: (1!00\EPA:AJR1**(3'1~-2471)** 

### April 18, 2063

### Tt~efollowing

### ~ix>it**pr<~vides**the·results 

### ofthe

### self-ey.~lllllti;;>nengineerlng.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 CFRPart60 AppeidiicA

### abbreviated

### iritheir appl\eatiap in

### ordertG 

### reduce



## . . .

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### studies, 

### !li!dpre- · . .



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# emissionlevei**·~tll~ieS**

### .. 

## AirCciljlpliance**T~tlilg:does:nllt**

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### behinii'the**a~cc.uracy·ofthe·tei!lllts.**

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### ify!)U:-qave ainy queStiims

## Gf**COilCe~** ahaut$ese

## teStresults

# orany · other

### 'eii1issi01l

## i¢sti.rigrelate4tapjcs. On behalf

### of Ait: 

### CampliaitteTesting; 

### Iw0uld

### also. like

### to**pe~sona!'Jy**

### thank)'!'JU

### fa~

### '$e oppelti¥iity !G.

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### anthi~**.tes~ng**

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### andoWGUld

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.

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### J. 

### LisyJr. : 

### Techilical MariagerSelf.:EvaJI;!jltjon SaoJneertma 

### S!udli Ills! ReiN!! ISG ClevelandInc.


### 2.0 SUMMARY AND DISCUSSION OF TEST RESUlTS
2.1 Objectives andTest Matrix


### The purpose afthis testwas t0 determine the mass emissien rate 0fNO,(as NOz) atthe Billet ReheatFumaseNe. 1,

### N0. 2, 

### andNa. 3

### ExhaustStacks duringnermal maximum eperations. This tast

### was cenductedto previaeISG Cleveland, 

### Inc. with emissions inf0rmation fartheir awn internal use. The sPAAitictestabjectives for this testwere to;



### Measure the cencentratieas efNO., andC02

### at the

### BilletReheatFurnaceNo. l,No.2, andNo.3 ExhaustStacks duringnarmal maximum operatiens. Measure the ae!Ual and dry 

### standardvolumel.!icflow rates ofthe stackgas atthe BilletReheat Furllllce No. I,Na. 2, 

### andNo. 3ExhaustStacks duringnormal maximumoperatiolls.**Utili~**

### the abovevariables to calculatethe mass emissionrate ofNO,(asN02 ) 

### atthe Billet ReheatFurnaceNo. l,Ne. 2, andNo.3 Exhaust Smksduring normall!llOOmum operations. Table 2.1 presentsthe sampling and analytical matrix leg f0r this test.
2.2 FieldTest Changes andProblems


### The EPAMethod4post-test samplillgtrailllcall:checks perfol'l1\ed afterRum I at boththe Billet ReheatFumaceNo. 1andN1r>. 2ExhaustStacksyielded alcall:agerates which were greaterthan the 

### method allowable leakagerate of 0.020 efin. Theref9re, an additional**samplt~**

### tum was**perfor~ned** 

### at both the 

### BilletReheatFumaeeNo. 1andNG. 2Exhaust Stacks. The datacollectdmingRun 1at boththe BilletReheatFurnaceNo. 1andNo. 2Exhaust Smksare notdisplayed inthis report.

Test Date: March 18, 19, and 24,2003 Pago3 AirCompliance Testing, Inc.
- 030302Self-Evaluation Engineering StudyTest Repgrt JS!O Cieyeiand

## Inc.

2.3 Presentation ofResults


### Two samplingtrains were utilized ateach locatien duriageachrun iaorderte detennine the mass emissienrate ofNO, (asN()z). One samplingtrain measuredthe stackgss 

### volumetric flew rate, dry molecularweight, and moisture coatentofthe stackgas and asecendtrain, utilizing a sample gas dilution system, measuredthe stack gas cencentratiens ofNO, and COz. The mass emissien rates ofNO,(asN()z) measuredduringthis testeventare displayed inTables 2.2.1 - 

### 2.2.3. The graphs 

### thatfollow Table 2.2.3 presentthe raw, uncorrected cencentratien datameasured in the field by

### the C()z andNO, analyzersfer all threetesting locations.

Test Date: Manch 18, 19, and 24,2003 Page4 AirCompliance Testing, Inc.

-030302

# • Se!f"Evaluatioo Engineering StudyTestRei!Ort 

# • ISGCleve.lnc,

EPATESTMETHODS UTILIZED MI/M2 M3A 

### M3B M4 M7E (Flow) (COt) IDrv MoLWU (%H10) (NOx) Run SamplingTimeI SamplingTimeI SamplingTimeI SampllugTimeI SampllugTimeI Date No. SamnliDI!Location Du,..tlon (min) Daration(mlnl Duratl!la(min) Duration(mln) Duration (min) 311812003 2 BilletReheatF- No. I 10:04 " II:22 10:04- lt:19 1'0:04

- II:22 10:04

- ll:22 10:04-11:19 ExhaustStack 64 60 64 64 60 3/18/2003 3 Bill<:tReheatFurnace No. I 11:43- 12:59 11:43

- 12:57 11:43- 12:59 11:43- 12:59 II:43 • 12:57 ExhaustStack 64 60 64 64 60 3/18/2003 4 Bill<:tReheatFurnaceNo. I 13:5I

- 15:08 13:5I • 15:06 13:51

- IS:OS 13:51- 15:08 13:5I

- 15:06 ExhaustStack 64 60 64 64 60 3/2412003 2 Billet ReheatFwnaceNo.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 ReheatFurnace No.2 11:11-12:34 11:11

- 12:32 11:11

- 12:34 II:II • 12:34 11:11

- 12:32 ExhaustStack 64 60 64 64 60 312412003 4 Bill<:tReheat FurnaceNo.2 12:53- 14:17 12:53- 14:15 12:53. 14:17 12:53- 14:17 12:53- 14:15 ExhaustStack 64 60 64 64 60 AlltimesarellastomSiondlniTune.


### Table2.1.1- SamplingandAnalyticalMatrix

TestDate: Man:h 18, 19. and 24, 2003 Page5 AirCompllanee Tasllng, Inc.
- 030302

# • • Self-Evaluation Enajneerinq Study Test Report

EPATESTMETHODSUTILIZED Ml/Ml M3A M3B M4 M7E _(Flow) (Co,) (DeyMoL Wt.) (%H10) (NOs) Ruo SampliogTimeI SamplingTimeI SamplingTimeI SamplingTimeI SamplingTimeI O.te No. SamplingLocatkm D1.1ratlonJntlnJ Dl.lratloo_(mlnJ. Durallon(mlnl**Ot~ralloa!!llill)** Duralloo(mio) 3/1912003 2 Billet RdleatFu11lll0eNo. 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 BilletRdleat FurnaceNo.3 10:58 " 12:21 10:58- 12:19 10:58- 12:21 I0:511

- 12:21 10:511- 12:19 ElchaustSlack 64 60 64 64 60 3119/2003 4 Billet RdleatFUlllllteNo. 3 12:42- 14:23 12:42- 14:21 12:42- 14:23 12:42- 14:23 12:42- 14:21 ExhaustStack 64 60 64 64 60 Allllmos

..EaslemSiaodan!Timo. 

### • 

### Table2.1.2

- SampliJig andAnalyticalMatrix

TestDate: Mamh 18, 19, and24, 2003 PageS

.AirCompliance Testing, Inc.
- 030302

# • 

# • ISG

# ClevA Inc. Self-EvaluaUon Engineering Study Test Report

## ~ReheatFurnaceNo. 1ExhaustStack



# . Run2 Run3 Run4 Average Average C01 Based (FJNO•.Mass Emission Rate(asNID,), (JbiMMBtu 

### 0-91 0.56 0.47 0.$_5 AverageNO,.MassEmission Rate (asNO,),Oblhr 365.0 265.9 174.9 26!:1.!)_ Nitrogen.Oxides(NO.)Concentration (ppmvd 529 472 387 463 Natural GasUsage Rate (cfllu' 344,26'7 318,519 247,893 303,560 StackGas AverageFlow Rate (acfin' 380,852 303,596 228,779 304,409 StackGas Average Flow Rate(scfin' 116,689 94,884 76,213 95,929 StackGasAverageFlowRate(dscfin' 96,376 78,558 63,122 79,352 StackGas Average Velocity (fpm) 2,221 1,771 1,334 1,775 StackGasAveragt! StaticPressure (in-H 20\ -0.31 -0.28 -0.25 -0.28 StackGas AverageTemperatllre ("F) 1,208 1,176 1,076 1,153 StackGas PercentbyVolume Moisture (o/.JI,m 17.41 17.21 17.18 17.26 Measured StackInnerDiameter(in 177.31 177.31 177.31 11731 PercentbyVolume Carbon Dioxide in StackGru; (DryBasis)("/.CO,: 10.69 10.43 10.19 10.44 PereentbyVolume OXygen in StackGas (J)ry.Basis) 

### ("'.o,: 2.97 3.40 3.97 3.45 PercentbyVolume CarbonMonoxideinStackGas (DryBasis) (%CO 0.00 0.00 0.00 0.00 PercentbyVolumeNitrogt!n in StackGas (DryBasis)(%N2J 86.34 86.17 85.84 86.12 PercentExcess Air (% 14.98 17.57 21.24 17.93 MeasuredFuel FactorValue (FoJ 1.68 1.68 1.66 1.67


### Table2.2.1

- Emission Results

Test Date: March 18, 19, and 24, 2003 Page7 AirCompliance Testing, Inc.
-030302Self-Evallon Eooineenna StudyTest Reoort 

# •

WSM 

### ..-ReheatFurnaceNo.2ExhaustStack Run2 Rnn3 Run4 

### Average Average C02 Based (FJNO,MassEmission Rate (OJ' NO,), (lbiMMBtu) 

## o:s3 0.40**0:4~** 

# : Cll-46 ) AverngeNO, Mass Emission Rate (asNO,), (lblhr 285.2 122.5 158.5 

### l88.8 Nitr!Jgen OXides (NO.)Concentration{ppmvd 407 282 319 336 Natural Gas Usage Rate (efflu' 300,233 204,620 239,752 248,202 StackGasAverageFlow Rate (aejiR 351,676 202,584 239,148 264,469 StackGasAverageFlow Rate {scfin 117,254 71,540 82,193 90,329 StackGas AverageFlow Rate (dscfin 97,758 60,623 69,258 75,879 StackGas Average Yeloci'" 1 ""' 2,131 1,228 1,449 1,603

· SteckGas Average Static Pressure (in-li10 -0.35 -0.23 -0.33 -030 StackGas AverageTemperature (•F) 1,077 981 1,013 1,024 StackGas Percentl)y VolumeMoisture (%H20 16.63 15.26 15.74 15.87 MeasnredStackInnerDiameter(in 173.94 173.94 173.94 173.94 PercentbyVolume CarbonDioxide in SteckGas (DrY Basis)(o/oCO,J 9.53 

### 8.69 8.95 9.06 Percentl)y Volume OXygen in SteckGas (DryBasis)(%0,] 5.73 6.13 6.27 6.04 PercentbyVolume Carbon Monoxide in StackGas (Dry Basis)(%CO 0.00 0.00 0.00 0.00 Percent by VolumeNitrogen in StackGas (DryBasis) (%N:zJ 84.74 85.18 84.78 84.90 PercentExcess Air(% 34.43 37.47 38.92 36.94 MeasnredFuel FactorValue (Fa 1.59 l.70 1.63 1.64


### Table2.2.2

- Emission Results

Test Date: Mamh 18, 19, and24, 2003 P.age8 AirCompliance Testing, Inc.
- 030302

# • Self:Eya!uation £ing!neering StudyTest Report ISG

# Clevef~c. ,!!!M 

### -.ReheatFurnaceNo. 3ExhaustStaek 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 AverageNO,Mass EmissionRate (asNO,),flblbr 2m.1 169.3 218.4 196.8 Nitrogen OXides (NO.)Concenlrlrtion (ppmv\1 476 397 436 436 Natural GasUsageRate (cf/hi 308,413 232,952 301,155 280,340 SlackGas Average FlowRate (acfin 221,839 209,806 264,160 231,935 StackGas Average Flow Rate (scfin 72,622 71,460 85,047 76,376 StackGasAverage Flow Rate(dscfm 59,466 59,515 69,$63 62,948 StackGas

### Averae.~Velocity Cft>m' 1,379 1,305 1,643 1442 StackGasAverageStatic Pressure (in-H.Ol .0.29 .0.25 .0.32 -0.29 StackGas**Avera~re** Temoel'lltllre ("F) 1,108 j 047 I 132 1,095 StackGasl'enlent

### bvVolwneMoiSlllnl(%Fit0 lll.H 16.72 17.85 17.56 Measured StackInnerDiameter(in 171.71 171.71 171.71 171.71 Percentbv VolmneCarbon Dioxidein SlackGas (DrvBasis) (o/.CO, 10.63 9.53 10.43 10.20 P4l'Celltbv Volmne Ox.ygenin StackGas (DryBasis) (%0.,' 2.77 4.30 2.97 3.35 Pernent by Volume Carbon Monoxide in StackGas(DryBasis) (o/..CO 0.00 0.00 0.00 0.00 Percent

### bY VolumeNitrogen in SlaskGas (D!yBasis)(o/eN,: 86.60 86.17 86.60 116.45 PeroentExcess Air(% 13.79 23.31 14.93 17.34 MeasuredFuel FactorValue (F. 1.70 1.74 1.72 1.72


### Table2.2.3

- EmissionResults

TestDate: Maroh 18, 19, and 24,2003 Page9 AirCompliwu:e Testing, Inc.
- 030302

### HOT DIP GALVANIZINGLINETEST SUMMARY FEBRUARY 16,2007

# •

•

• SuperiorQuality Emission Testing. ValidResults 

### Guaranteed.

RichardZavoda Manager, Environmental ISG Cleveland,Inc. 1060

### Eggers Avenue Cleveland, Ohio 44lOS Dear Richard: 

# AirCompliance Testing, Inc.
P.O. Box41158 Clevelloncl, Ohio44141 1-801J.EPA-AIFI1WIIW.Ai'l:emp.com teallngCIIalrcomp.com

March 14,2007



### efolio=·

. artpro.vides the results afth. ·e**eamplian~ e.~ission** 

### testing**condu~**

### en Febn.wy 16,200

. 

### Theseresults are apraductaftbeapplication ofthe U.S. EPA Statienary

. plin Methods listed in40 CFRPart60

### AppendixAthat

### were 

### in effectat

### thetime afthistest. 

### Pleasemail one cepy ofthisreportalangwith any

### ethersupportive precessoperating

### Cilata callectedduringthistestto

### yourlocal EPArepresentative within30days afthe actualtest 

### day. You sheuld alsa ll.ttaeh a oovcrletter(on oompany letterhead) stilting the 

### purpose andthe outoomeafthistest. 

### Additienally, youmay address,preferably in atimetableformat, any abligations erimplicatlens thatmightbe necessaryteachieve envirat'!mental eampliance because aftheresultefthistest. 

### Please do

### nethesitate to

### call if

### yeu have anyquestions orceneems aboutthese 

### testresults. On

### behalfefAirCempliancc Testing,Iweuld alse like to

### persanallythankyeuferthe oppartunityte

### warkwithyouonthistestingprojectand would enjeythe apportunityto work withyeu again an any additional future 

### testingprojects. Sincerely,

# ;2?~1)1.:

# t., RabertJ. 

### 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 

### efClevelar.l!il • DAQ 

### 1925 St ClairAvei1Ue Cievelam!il, 

### OhiG44114 L$6 Clevelan!illn\1:. Pramtse No. 131SOI!l1S13**NG~i\1:8** ofCempl!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 eythe Title

## vJil&rmlt iA!il permit-ta-lrtstatl No. 13- · l!l1!lt5. T:lte stMktastiR(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

. . GeneralMama(ller AltaQhmeRt

IS() ClevelandInc. •Environmental •3060EggetS Avenue •Cleveland, Ohio44105 •(216) 429-6542 •(216) 429-6631 fax

# -· Compliance Stack Emission Test Reoort !5GCieyeland. Inc.

Pll71 ExhaustStack 

### Rual Rma2 Raa3 Average Oxygen-BasedNitrogen OxidesMassEmissionRate (lbiMMBIII 

### 0.151 0.129 0.174 O.lSl**Nittn~ten**Oxides MassEmission Rate (lblhrasNO, 

### 22.49 19.92 20.89 21.10 NitrogenOxides Concentration(ppmvd' 

### 60.80 55.64 

### 54.24 56.89 MeasuredAwroximateOxygen-BasedHeat InputRate (MMbtullu' 

### 149.2 

# . 154.8 119.9 141.3 PublishedOxygen-BasedF·Factor(Fd)(dscfiMMBIII 

### 1!,710 8,710 8,710 8,710 Meuured

### l'uelFactorVl!lue (l'o 

### 1.71 1.74 1.68 1.71 PercentExcess Air(% 

### 125.0 lll0.2 188.3 141.1 StackGas AverageFlow Rate (acfui. 

### 115.289 110,759 ll7,5Ci4 114,537 StackGas AverageFlow Rate (scfin 

### 56,930 55,229 57,593 56,5114 Stack

### 9asAverageFlowRate (dsclin 

### 51,630 49,971 53,776 51.793 StackGas AverageVelocity (lPm) 

### 3,205 3,1179 3,2611 3,184 StackGas AVetl!2e StaticPressure (in-H;,O) 

### -0.47 -0.50 -0.46 -0.47 StackGas AverageTtm! 

### :•FJ 579 571 588 579 StackGasPeteO!ItI!Y.Vollll!18Moistun>W.H.O'. 

### 9.31 9.52 6.63 11.49 Meuured StackInnerDiamebM'(in)•• 7UOx&2.6S 79.80x &2.6S 79.110 X&2.6S 19.110 X &2.6S PercentllyVolume CarilonDioxide in StackGas (DryBasis)(%CO,] 

### 5.13 5.40 4.00 4.84 Percentby VoliUlle Oxv2enin

### StackGas (DryBasis) (%().,] 

### 12.13 11.50 14.13 12.59 Percentbv VolumeNitrogen.in

### StackGas (l)ryBasis)C%N,J 

### 82.74 83.10 81.83 

### 82.56 •"TheP071
--- ollijltical insllapo 

### Table2.2

- EmissionResults

Test Date: February 16, 2007 PageS AirCompliance Testing, Inc. -070212

### BLAST FURNACES CS AND C6TEST 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 OfTEST RESUlTS 

## LTV STEEl. COMPANY CliEVIEII.AND WORKS

. ,

## ...... -**1'"'\t.i$#~~** r:J,_ Co;;



## • 

# • • • Blast Flll'l*eM 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 8.0ppm 

### Is Ilia lowerdetec:tlon 

### llm!llcranalyzer 

### 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 FACTORCALCULATIONS BY SOURCE12/10/2008 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