Modifications and Changes in Emissions at Mittal Steel Cleveland Blast
Furnace #5
Summary
LTV (now Mittal) Steel of Cleveland made off permit modifications to Blast Furnace #5 during
the 1980’s. In 1990, LTV obtained a permit to incorporate these changes and to permit the
addition of a second taphole to increase production by debottlenecking the casting operations.
Maximum capacity increased from 108 to 204 tons of iron per hour. LTV did not accurately
represent the nature and extent of the emissions increases associated with these modifications.
Furthermore, LTV obtained an emissions limit on the net increase in emissions of particulate
matter of 13.72 tons per year. The City of Cleveland tried to enforce apparent exceedances under
this permit in 2005 and were told by Mittal’s attorneys that the permit conditions were not
enforceable. This clearly appears to be the case. Since the emissions increase limits in PTI # 132122 that were put in place to avoid New Source Review (NSR) and the Prevention of Significant
Deterioration (PSD) programs are not enforceable, the emissions increases associated with this
permit must be assumed to be significant as calculated in the PTI # 13-2122 application (LTV
STEEL CO. INC., Application No. 13-2122, pages 5 and 6 of 9). Other emissions increases
appear to have been miscalculated by LTV Steel. As a result, Blast Furnace #5 does not have
BACT pollution controls that would have correctly been required under PSD. An initial
approximation by Ohio Citizen Action of the net emissions increases associated with this 2nd
taphole project are:
Carbon Monoxide – 4,956 tons per year
Particulate Matter – 900.1 tons per year excluding slag operation and fugitive emissions
Sulfur Dioxide – 140 tons per year
Oxides of Nitrogen – Estimated in 1990 to be 102.6 tons per year (current emissions rates are
lower)
1.0 Emissions Increase Not Correctly Estimated under Ohio PTI #13-2122
Mittal Steel’s (as LTV Steel) Blast Furnace #5 (BF #5) was modified to increase production
capacity without obtaining a permit during the 1980’s. It was again modified in 1990 under Ohio
Permit to Install (PTI) # 13-2122. This permit retroactively included the modified capacity
installed during the 1980’s, which reportedly increased the production capacity of BF #5 from
108 tons of iron per hour (tph) to 196 tph, this increase was above the pervious permit limit of
108 tons per hour of iron production. PTI # 13-2122 was issued in 1990 and allowed further
modification (i,e, installation of a second taphole and tap system) that reportedly increased
production capacity from 196 tph to 204 tph.
1.1 PTI #13-2122 Not Federally Nor Practically Enforceable
This PTI is problematic because the permit limitations in PTI 13-2122 are not federally nor
practically enforceable. Hourly and annual numbers representing the maximum allowable
emissions increase of particulate matter were included in the permit. However, neither the
baseline emissions rate, nor the emissions rate as modified, have been quantified. This means
that it is not possible for the regulatory authorities to determine compliance with the permit
conditions. The conditions as summarized in the Title V Permit for Mittal Steel are:
OAC rule 3745-31-05(A)(3) (PTI #13-2122)
Particulate emissions (PE) from the casthouse shall not exceed 3.14 lbs/hr and 13.72 tons/year
(TPY).* PM10 emissions shall not exceed 7.08 TPY* See Sections A.I.2.a, A.I.2.b and A.I.2.c
below. The requirements of this rule include compliance with the requirements of OAC rules
3745-17-07(A), 17-11, 17-12(P)(5), and 18-24.
*These allowable emission rates are only for the incremental emission increases resulting from the
installation of the 2nd taphole for the C5 furnace.
The City of Cleveland issued a Notice of Violation (NOV) for conditions related to apparent
exceedances of the “incremental emissions increases” on October 10, 2005. The response to this
NOV (Douglas Williams to George Baker, November 30, 2005) informs the City of Cleveland
that these apparent violations cannot be enforced because the incremental increases are not
enforceable.
“We would prefer, however, to keep out of the Title V Permit the PTI emission limits that
apply only to an incremental increase associate with the PTI project because they are not
practically enforceable operating limits.”
The City of Cleveland has found these “incremental” limitations unenforceable. The company
apparently also understands that the conditions of PTI # 13-2122 are unenforceable. Since the
emissions increase limits in PTI # 13-2122 that avoid New Source Review (NSR) and the
Prevention of Significant Deterioration (PSD) programs are not enforceable, the emissions
increases associated with this permit must be assumed to be significant as calculated in the PTI #
13-2122 application (LTV STEEL CO. INC., Application No. 13-2122, pages 5 and 6 of 9). This
indicates that a particulate increase of 30.9 tons per year (tpy) and a PM-10 increase of 22.1 tpy
were calculated prior to establishing the unenforceable limits contained in the permit. It should
also be noted that a significant increase in NOx emissions (102.6 tpy) is predicted in the PTI #
13-2122 application.
1.2 PM Emissions
1.2.1 PM Emissions from Blast Furnace Gas (BFG)
More troubling than the lack of enforceability of this permit is the underestimation and
misrepresentations of the emissions increases associated with the emissions increases that
occurred by the expansion of BF #5.
One source of underestimation from the unpermitted and unenforceable expansions at BF #5 is
that the main air pollution control device on BF #5 is a venturi scrubber that was installed in 1972
(Purification Industries, two-stage venturi scrubber, 20” & 60” w.c.) that has a capacity of
150,000 acfm and was designed and installed to serve BF #5 when the hourly production capacity
was 108 tph of iron. The production capacity of BF #5 has been effectively doubled to 204 tph
iron, but the capacity of the 1972 vintage venturi scrubber was not increased. The venturi
scrubber is designed to clean blast furnace gas (BFG) that is used as a fuel and combusted in the
stoves prior to being emitted by the stove stacks. BFG gas is a usable fuel because it contains a
large amount of carbon monoxide (CO) that is surplus from reducing iron oxide in the blast
furnace. This BFG can be used as a fuel in the blast furnace stoves, burned in the flare at BF #5,
or it can be burned in the steel mill’s boilers as a fuel.
The obvious problem is that the amount of BFG that can be cleaned is limited. By increasing
production beyond the capacity of the venturi scrubbers, the amount of uncontrolled BFG that is
combusted, either in the flares or boilers, must increase substantially. This led to a substantial
increase in particulate emissions.
Table 1 – BFG Capacity of the Venturi Scrubber
BFG Gas Control Calculations for Venturi Scrubber
Volume (acfm)
150,000
Temperature F
625
Standard Temperature F
32
Capacity of Venturi (scfm)
67,973
Capacity of Venturi (MMscf/hr)*
4.08
annual capacity 7560hrs
30,833
annual capacity 8760hrs
35,727
*Compares with reported value of 4.03 MM cf/hr
The capacity of the venturi scrubber has remained at 150,000acfm or about 68,000 scfm. This is
shown in Table 1 and compares well with reported values. The amount of BFG generated at BF
#5 has been calculated (PTI #13-2122 letter from LTV Steel to Ted Esborn, May 16, 1990) using
0.07 cf of BFG per ton of iron produced that has been described as LTV’s rule of thumb. It can
be seen that the percentage of BFG that would be unscrubbed went from about 33.2% of the total
in 1980 to about 71.4% of the total based on the hourly potential production after the 1990
installation of the second tap hole.
Table 2 – Uncontrolled BFG Gas Calculation
Hourly Tons
Iron
Year
1980
1983
19851987
19881989
post
1991
Annual
Tons Iron
Annual MMcf
BFG
Scrubber
Capacity
Unscrubbed
BFG
Percent BFG
Unscrubbed
avg
max
avg
max
87.2
108.0
106.0
108.0
763,818
946,080
928,886
946,080
53,467
66,226
65,022
66,226
35,727
35,727
35,727
35,727
17,741
30,499
29,295
30,499
33.2%
46.1%
45.1%
46.1%
avg
max
137.7
196.0
1,206,122
1,716,960
84,429
120,187
35,727
35,727
48,702
84,461
57.7%
70.3%
avg
max
avg
2005
max
151.7
196.0
1,328,892
1,716,960
93,022
120,187
35,727
35,727
57,296
84,461
61.6%
70.3%
151.6
204.0
1,328,421
1,787,040
92,989
125,093
35,727
35,727
57,263
89,366
61.6%
71.4%
In LTV’s response to the City of Cleveland (CoC) (April 25, 1990, pg. 11), LTV tells the City of
Cleveland that the CoC has incorrectly used the AP-42 emissions factor for estimating BFG
particulate emissions. However, a review of the AP-42 chapter on iron and steel production (AP42 Chapter 12.5) shows that the emissions factor LTV chooses is an emissions factor for
particulate matter from the combustion of scrubbed BFG (AP-42 Ch.12.5.2.8 Miscellaneous
Combustion). It is incorrect to use this factor because the potential to emit is characterized by an
increase in uncontrolled BFG combustion emissions. As the scrubber capacity, which was
already less than the total BFG production capacity, has not been increased, the increase in BFG
must be presumed to be unscrubbed. In addition there are no permit conditions that actually
require Mittal to scrub BFG before it is combusted and the emissions increases must, therefore,
be calculated on an uncontrolled basis.
In their 2005 Title V Emissions Fee Report Mittal used the AP-42 cleaned BFG gas factor for
estimating emissions from the stove stacks, boilers and the flare that burn BFG. The stove stacks
in 2005 used 23,932 MMcf of BFG and 3,486 MMcf of BFG was reported flared through the gas
bleeder. Mittal reported a particulate emissions factor of 2.9 lbs/ MMcf of BFG (the cleaned gas
AP-42 factor) for this combustion. This factor is not appropriate for flared gas as it is typically
not scrubbed prior to release. In addition, the boilers were reported to burn over 83,000 MM cf of
BFG in 2005. While it is clear that Mittal has used a controlled factor in estimating these
emissions, there is not enough scrubbing capacity for Mittal to have cleaned this amount of BFG.
Some of the BFG may come from BF #6, which still retains its original capacity of 108 tph iron
production. From Table 2 we can compare the actual average unscrubbed production capacity in
1983 prior to the modifications with the maximum capacity after the 1990 modifications (89,366
– 29,295 MMcf) and see that the actual to potential increase in unscrubbed BFG is about 60,000
MMcf per year. Assuming that the control efficiency of the venturi scrubbers is 90% (it is
probably higher), we get an uncontrolled particulate emissions factor for the BFG of 29 lbs/MMcf
(2.9/(1-0.90)). This means that the increase in potential to emit from uncontrolled particulate in
the BFG is 870 tons per year.
Table 3 – BFG Reported Burned in Mittal Boilers
Boiler
ID
Boiler A
Boiler B
Boiler C
Boiler D
Boiler 1
Boiler 2
Boiler 3
sum
Annual MMcf BFG
26,971.2
1,422.6
18,336.4
0.0
11,010.2
8,813.2
16,493.7
83,047.3
1.2.2 PM Emissions from the Casthouse and Charging
Emissions of PM in the casthouse are estimated based on the increased production of iron. Total
emissions for 2005 were reported to be 39.85 tons of total particulate matter (PM) based on
annual production of 1,328,421 tons of iron. Actual production in 1983 prior to modification was
928,886 tons of iron and the potential production for BF #5 as modified with the second taphole
is 1,787,040 tons of iron. Proportioning the total PM emissions based on production rates, Ohio
Citizen Action estimates the actual emissions in 1983 to be 27.9 tpy of PM. OCA estimates the
potential to emit to be 53.6 tpy of PM. The net increase in PM emissions is, therefore, estimated
to be approximately an increase of 25.8 tpy at the casthouse. A similar estimate for the
charging emissions results in an additional 5.3 tpy of PM.
1.2.4 PM Emissions from Slag Handling and Fugitive Emissions
Emissions from slag handling were excluded from the calculation of the net change in emissions
under PTI 13-2122. This was done because LTV asserted that the slag handling was done by a
contractor under a different permit. Mittal/LTV is a named source under PSD regulations and
must include fugitive emissions in estimating the net change in emissions. EPA has issued a
guidance memo (Gallatin Steel) that also reinforces the position that these emissions must be
included in calculating the net change in emissions. The extent of slag handling and other
excluded emissions in this permit should be further investigated but must be calculated along with
other fugitive emissions as Mittal (Iron and Steel Mill) is a named PSD source.
1.3 Carbon Monoxide (CO) Emissions Increases
A more detailed analysis of CO may be warranted. However, because the magnitude of the CO
increase from the second taphole is so large, a simple proportioning of emissions was done to
determine if the net increase would be expected to be significant. Mittal reported total emissions
for 2005 of 7,666.8 tons from BF #5 based on annual production of 1,328,421 tons of iron.
Actual production in 1983 prior to modification was 928,886 tons of iron and the potential
production for BF #5 as modified with the second taphole is 1,787,040 tons of iron.
Proportioning the CO emissions based on production rates, Ohio Citizen Action estimates actual
emissions in 1983 to be 5,360.7 tpy of CO. OCA estimates the potential to emit to be 10,316.7
tpy of CO. The net increase in CO emissions is, therefore, estimated to be approximately an
increase of 4,956 tpy.
1.4 NOx Emissions Increases
The 1990 application (page 6 of 9) showed that the net emissions increase for NOx was
significant at 102.6 tpy. Current emissions estimates (2005 Title V Emissions Report) show very
low emissions due largely to a reported 1994 NOx Stack Test of combustion of BFG. This
should be further investigated to see if the Stack Test is representative of the overall emissions
from the blast furnace including the emissions resulting from combustion of coke and other
process feeds and if separate emissions estimates need to be produced to represent flaring
emissions and the emissions from burning BFG in other units such as boilers. The impact of the
increased production at BF #5 should also be considered in evaluating increased boiler utilization.
1.5 SO2 Emissions Increases
Emissions of SO2 are expected to result from the materials charged in making iron in the blast
furnace. Total emissions for 2005 were reported to be 216.5 tons from BF #5 based on annual
production of 1,328,421 tons of iron. Actual production in 1983 prior to modification was
928,886 tons of iron and the potential production for BF #5 as modified with the second taphole
is 1,787,040 tons of iron. Proportioning the SO2 emissions based on production rates, Ohio
Citizen Action estimates actual emissions in 1983 to be 151.4 tpy of SO2. OCA estimates the
potential to emit to be 291.3 tpy of SO2. The net increase in SO2 emissions is, therefore,
estimated to be approximately an increase of 140 tpy.