1974 BID for EAF subpart AA  -  ORIGINAL RULE

Chapter V. SUMMARY OF THE PROCEDURE FOR DEVELOPING STANDARDS
D. Plant Inspections Pg. 63 (pdf pg. 88)

Preliminary investigations of 30 plants identified from a review of the literature and contacts with industry revealed the location of 11 plants reportedly well-controlled {BE or CH systems) for particulate emissions. Ten were visited, visible emissions evaluated, and information obtained on the process and control equipment. 
Although many of these practiced good control techniques, the facilities at only three plants (Plants A, I and J) were amenable to testing with EPA Method 5. Others were not suitable for emission measure­ments because they use pressure baghouses which have no stacks. Although development work is in progress, sampling methodology for this type installation has not been standardized. 

These three plants were nearly identical except for size. They all produced alloy steels and controlled particulate emissions with a building evacuation system. Each had a fabric filter control device that exhausted through multiple stacks. Rather than spread the test program effort over three tests at nearly identical plants, it was decided a more comprehensive test of one plant would provide more information. The middle sized plant offered the best possibilities for this comprehensive test. Its size was typical of the mid-range for the industry, and the fabric filter did not have an inordinately large number of exhaust stacks. This permitted simultaneous sampling of a higher percentage of the total stacks with much less effort than required for that required for a large plant. 

Background Information for Standards of Performance:  Electric Arc Furnaces in the Steel Industry, Volume 1:  Proposed Standards. Publication No. EPA-450/2-74-017a. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. October 1974.

1979 BID for EAF subpart AA  -  ORIGINAL RULE

6.4 JUSTIFICATION TO REVISE NSPS 

There is probably sufficient justification to revise the present NSPS, based on the following considerations:

1	In general, control technology better than that needed to comply with the NSPS is being used by industry today for new and existing EAF shops.
2.	Although data on NSPS compliance for new EAF shops are lacking, enough data may be available from existing well-controlled EAF shops to extrapolate to future EAF shops. This is especially true in the visible emission portion of the NSPS
3.	Fugitive emission control technology (especially, for charging and tapping emissions) has been developed. 
4.	AOD furnaces are significant sources of particulate and visible emissions, and should be considered for inclusion in the NSPS even though they are not really EAF's. However, they are an integral part of an EAF shop operation, and frequently use the same or similar control system as those used by EAF furnaces. This inclusion would probably require an additional definition of an affected facility in the NSPS.

Review of Standards of Performance for Electric Arc Furnaces in Steel Industry. Publication No EPA-450-3-79-033. U.S. Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina. October 1979. 
