                 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION 5
                          AIR AND RADIATION DIVISION
                           77 WEST JACKSON BOULEVARD
                            CHICAGO, ILLINOIS 60604
                                       

 	  DATE: September 10, 2006 (amended June 5, 2007)
		
SUBJECT: Inspection of Mittal Steel - Burns Harbor
			
	  FROM:	 Brian Dickens, Environmental Engineer
		 Enforcement and Compliance Assurance Branch

  THRU:  William L. MacDowell, Chief
		 Enforcement and Compliance Assurance Section (MN/OH)
		 Enforcement and Compliance Assurance Branch
		
	 TO:	 File, Mittal Steel  -  Burns Harbor, IN

SOURCE NAME AND LOCATION:

Mittal Steel Burns Harbor LLC (Mittal)
(aka ISG Burns Harbor, fka Bethlehem Steel)
250 West U.S. Highway 12
Burns Harbor, IN 46304

DATE(S) OF INSPECTION: July 28, 2006; July 31, 2006; August 9, 2006; August 22, 2006; and June 1, 2007

PARTICIPANTS:

Rob Maciel, Environmental Manager, Mittal
Rich Guerra, Environmental Engineer, Mittal
Brian Dickens, Environmental Engineer, U.S. EPA
Reza Bagherian, Environmental Engineer, U.S. EPA
Monica Onyszko, Environmental Engineer, U.S. EPA
Dave Sampias, Environmental Engineer, IDEM
Don Kuh, Environmental Engineer, IDEM

NEIGHBORHOOD DESCRIPTION: 

The mill is located at the south end of Lake Michigan adjacent to other steel mills and other related industries. 

OFF-SITE OBSERVATIONS OF PLANT:

The facility has various sources of emissions so some level of opacity and odor is always present while the facility is operating.
 
GENERAL PROCESS DESCRIPTION:

Mittal operates an integrated steel mill. The Burns Harbor location includes a coke oven, sinter plant, blast furnace, basic oxygen process furnaces, casters, slab reheat furnaces, pickling lines, and a coal granulation unit.  

PURPOSE AND SCOPE OF INSPECTION:

The purpose of the inspection was to assist in determining compliance with the Clean Air Act (CAA). This inspection report summarizes the events witnessed during five separate inspections. 

APPLICABLE RULES:

Mittal has applied for a Title V permit but the Indiana Department of Environmental Management (IDEM) has released only a draft of the permit as of the date of this report. Although it is not yet final, the draft Title V permit lists applicable requirements as summarized below. Despite the draft permit's usefulness, a formal statement of applicable requirements can only be found in the many individual construction and operating permits for each separate process. 

Mittal received a one-year compliance extension for the National Emission Standards for Hazardous Air Pollutants for Iron and Steel, Subpart FFFFF (Subpart 5F) for the blast furnace and BOF shop in order to install secondary controls at the casthouses and on all 3 BOF vessels.
 	

Blast Furnace: 
	Stoves -
         State 326 IAC 6-2-2 for process weight rate for
particulate matter (PM)
         State 326 IAC 7-4-14(1)(B) for sulfur dioxide (SO2)
			State 326 IAC 7-4-14 for SO2 from flare
	Blast Furnace Gas Dust Handling system - 326 IAC 5-1-2.1 for opacity
	Thaw shed (no control)- state 326 IAC 6-3 Process weight rate, 326 IAC 5-1-2.1 for opacity
	Car Dumper Shed (baghouse)- state 326 IAC 6-3 Process weight rate, 326 IAC 5-1-2.1 for opacity, 0.007 gr/dscf PM from PTI,
100% capture per 5.9.a of the draft Title V permit.
	Material Handling Transfer -(no control) 326 IAC 6-3 Process weight rate, 326 IAC 5-1-2.1 for opacity
	C&D Stockhouses (baghouses)- state 326 IAC 6-3 Process weight rate, 326 IAC 5-1-2.1 for opacity
	Casthouse (baghouses)- state only PM limits, not federally enforceable, 326 IAC 5-1-2.1 for opacity

Boilers:	
		Boilers 8-12 
			0.23 lb/MMBTU PM per state 326 IAC 6-2-2
			1.45 lb/MMBTU SO2 per state 326 IAC 7-4-14(1)
		Boiler 7 
			0.10 lb/MMBTU via PTI
			0.8 lb/MMBTU SO2
			NSPS Subpart D, opacity and fuel use requirements
		All Boilers
			0.17 lb/MMBTU via state 326 IAC 10-3-3				

BOF Shop:	
		BOF Vessels (#1&2 control by scrubbers, #3 by scrubber & flare) - 326 IAC 5-1-2.1 for opacity

		BOF Vessel 3
			State 326 IAC 9-1-2(2) for CO, must be flared
			326 IAC 5-1-2.1 for opacity
			NSPS Subpart N, PM and (10%) Opacity from stack, 6 minute average
			PTI for secondary controls - 100% capture 6.12.a
		Desufurization
			PTI for 100% Capture 326 IAC 6.12.b
		Hot Metal Transfer and 3 baghouses, 
			326 IAC 5-1-2.1 for opacity
			#3 baghouse construction permit PM limit
			#1 construction permit PM limit
		Argon stirring station  -  326 IAC 5-1-2.1 for opacity
			Stirring and Desulfurization baghouse control- 
			326 IAC 5-1-2.1 for opacity	
		Steel treatment stations 4&5 - 326 IAC 5-1-2.1 for opacity		
		Vacuum Degasser with flare
			Construction permit limiting CO from flare
			Steam Ejector construction permit PM and PM10 limits
			Degasser material handing construction permit PM, PM10 limits
			Degasser material handling PTI 100% capture per 6.2.c.3 of the draft Title V permit, 326 IAC 5-1-2.1 for opacity
			Vacuum Degasser, alloy handling, vessel preheat, refract dryer burners -  5% opacity 6.6.b of draft permit
		Track Hopper with baghouse- 326 IAC 5-1-2.1 for opacity	


Pickling: 
		2 lines using two scrubbers:
			NESHAP subpart CCC (97% removal and 18 ppm exhaust)
		9 acid storage tanks controlled by same scrubbers
			NESHAP subpart CCC ((un)loading control, closed vent system, continuous heat treat line)
		Cold Sheet Mill using mist eliminator:
			State 326 IAC 6-3 process weight rate 
			Hot dip coating line (heat, clean, coat) using scrubber, SCR for NOx and CEM
			Construction permit NOx and PM limits
		
Sinter Plant		
		Windbox
			PM  -  NESHAP Subpart 5F, lb/ton sinter
			SO2 per state 326 IAC 7-4-14
			VOC 3150lb/day via state rule 326 IAC 8-13-3
		Discharge End
			Opacity - 20% 6 minute average per NESHAP Subpart 5F
			30 day rolling average of oil 0.02% per NESHAP Subpart 5F
			0.4 lb/ton sinter per NESHAP Subpart 5F
		Cooler stack
			PM limit per NESHAP Subpart 5F

	Granulated Coal Injection
		PTI 100% capture for raw coal bins, cyclone separators, storage bins, lock hopper vents

	Slab yard -3 lines, all natural gas burning

	Hot Strip Mill - 3 furnaces at 730 MMBTU/hr each
		326 IAC 6-3-2 PM limit via process weight rate
		326 IAC 7-4-14 for SO2, 1.96 lb/MMBTU and 79 lb/hr 
			
INSPECTION CONFERENCE:

I performed four inspections at the Burns Harbor facility. The inspection performed on July 31, 2006, consisted of viewing the mill's operations from off-site. The other three were on-site inspections. Each of the on-site inspections consisted of an opening conference where I explained which operations I wished to view, topics I wished to discuss, and records I wanted to review. A plant tour followed the opening conference. I held a closing conference at the end of each on-site visit with the Mittal representatives available on that day, and Mike Long, Manager of Environmental Compliance, participated by phone.



Process Description

This report will not attempt to summarize steel making operations, but notable characteristics of this plant are highlighted below. 
 
 	BOF Shop: Vessels 1 and 2 were installed in or around 1968 and are controlled by a primary hood. Vessel 3 was installed around 1978 and uses a suppressed hood, flare and a secondary hood to capture charge emissions.  
 
 	Blast Furnace: There are two blast furnaces named C and D. The tilting runners within the casthouse are controlled by baghouses. Mittal claims the use of these baghouses was voluntary. In fact, on or around July 29, 2006, Mittal took them out of service. Mittal claimed there was no state or federal regulation that applied to the casthouse. 
 
 	Granulated Coal Injection (GCI): Mittal adds coal to the blast furnace as a source of fuel in place of natural gas and coke. The granulated coal operating unit is in a separate building and prepares the coal for injection. 
 
 	BOF Shop Desulfurization: Hot metal desulfurization (HMD) is performed at three stations within the BOF shop. Station #3 was added last and requires capture and control via baghouse. Mittal claims that the equipment being installed in order to comply with the MACT will improve control at all three HMD stations.
  
 	Blast Furnace Slag Pit: Slag from the blast furnaces flows outside each casthouse to a slag pit. Each pit contains three rows so that Mittal can: 1) pour to the pit, 2) allow the slag to cool, and 3) clean out the pit, and prepare, or dress, the pit row for the next poor. The slag pits are open to the atmosphere and have no emission control. 
 
 	Sinter Plant: The sinter plant agglomerates coal and metal fines into small balls for introduction into the blast furnace. The sinter plant is a stand-alone operating unit within the plant. 
 
 	Boilers: There are six boilers on site that are named Boiler 7 through Boiler 12. Boiler 7 was the last one constructed, which was in or around 1978. All boilers burn a combination of natural gas, coke oven gas and blast furnace gas. 
 				
 
 
 
 	
 PLANT TOUR:
 
 7/28/06
 
 I toured the BOF shop with Mr. Bob Bolander of Mittal, Mr. Sampias and Mr. Kuh. Mr. Bolander explained that because of the installation of new emission control equipment being performed to comply with the MACT, the existing secondary control hood at #3 BOF vessel was taken out of service in May 2006. We observed the abandoned hood from the BOF shop platform.
 
 I witnessed the hot metal transfer and desulfurization at HMD #3. There were significant emissions outside the building from the transfer and the bottle car. I was not able to take Method 9 readings from my vantage point.
 
 We walked on to the vacuum degasser. I witnessed the degassing process. There were very few fugitive emissions from the degassing ladle and there were no emissions from the material handling conveyors associated with the system that I was able to view.
 
 Mr. Bolander left the group and Mr. Denny Durko joined the group to lead a tour of the sinter plant. We viewed the discharge end, the ring cooler, and the mixer/trimmer, which ensures the sinter contains the correct amount of carbon. 
 
 Mr. Durko left the group and Mr. Steve Horvath of Mittal joined us. As the group was walking to the blast furnaces, I saw significant emissions from the tilting runner baghouses for Furnace C. Mr. Horvath explained that the baghouses were not required and they were to be shut off July 28 or July 29, 2006. The emissions would then flow out of the roof monitor, for which he claimed there was no emissions limitation. I observed the baghouse exhausts for a few minutes but then noticed significant emissions from the slag pit for Furnace C. I completed Method 9 observations at the slag pit. Mittal explained that the emissions from the pit were caused by an end-loader cleaning out slag, dressing the pit row, and re-building the dam at the end of the pit row. 
 
 The group moved on to the GCI building. We viewed the operation from the first floor of the building. Mr. Horvath pointed out the major equipment. He explained the coal is milled, and then 185 F air is blown on to the coal. Several baghouses control emissions from the operation. Mr. Horvath was unsure if or how Mittal had quantified volatile organic material emissions from the baghouse vents.
 
 
 7/31/06
 
 Mr. Sampias and I drove to the Port of Indiana, which is on property immediately west of Mittal. We were able to park our car and observe nearly all of Mittal's operations from afar. Our observations lasted from approximately 13:00 to 14:30 and during this time I took Method 9 reading for visible emissions from the blast furnace relief valves. There was significant opacity from the valves that sit on top of the southwestern-most blast furnace.
 
 8/9/06
 
 I returned to the site to visit a specific few number of operations. Unfortunately, many of the operations I wished to view were not operating. The sinter plant was to be down until 19:00. The #3 hot metal desulfurization was to be down until at least 15:00. I walked with Rich Guerra and Rob Maciel to see other areas of the plant.
 
 We walked to the slagpit for Casthouse C. There were large plumes of grey smoke billowing from the slag pit. I began to take Method 9 visible emissions readings and Mr. Guerra went to investigate. When he returned he explained that the center pit was being filled for the first time after cleanout and dressing. Mr. Guerra said we approached the pit approximately 20 minutes after the cast started. Hot slag was running into the pit and down to the end of the row. Mr. Guerra said there may have been water in the pit but I could tell by the way in which the smoke dissipated, and compared to other steam plumes in the plant, that steam did not constitute a significant part of the plume. 
 
 We then walked on to the slag pit for Casthouse D. An endloader was removing slag from a row and dumping it into trucks to be hauled to the slag piles on the north end of the plant. I did not take Method 9 readings of the slag pit and although there was considerable smoke from the loading operations, I could not take Method 9 readings of this activity because of my position relative to the sun. 
 
 Mittal explained that the slag handling operations are managed by Levy. Mittal stated that Levy has its own Title V permit and as far as the environmental team understood, the slag was the property of Levy as it fell out of the casthouse and into the slag pit.
 
 The group walked on to the scrap handling operations managed by PSC Metals, Inc. (PSC). We met Mr. Bill Skopelja and he gave us an overview of the operations. PSC receives steel from various sources, cuts the steel into manageable sizes, and sells it back to Mittal as a product to be added back into the process, usually by placement into the BOF vessels. The raw material for PSC consists of rejected material from the mill (such as off-spec slabs), obsolete equipment from the mill (old machinery), and some outside material (various steel scrap). There are 121 burning, or cutting, stations and one breaking station. The breaking station consists of a crane to crush large objects into pieces. The burning stations consist of cutting torches where slabs are cut into chunks. There was relatively little smoke from the operations and PSC said they rarely take coated scrap, which would usually cause heavier emissions.
 
 8/22/06
 
 I began the tour by talking with Mr. Maciel about the sinter plant's method of continuous compliance with the Iron and Steel MACT, Subpart FFFFF. He explained that Mittal uses a continuous emission monitor to measure VOC at the sinter windbox exhaust. 
 
 At approximately 10:00, Mr. Maciel and I began driving to the BOF shop. Along the way we witnessed large volume of smoke. Mr. Maciel explained that Mittal sprays dust suppressant at various places around the plant to minimize dust from vehicle traffic. One of these areas is roadways for the slab haulers  -  giant tractors that move finished slabs from the slab mills to a lay-down area for cooling. Unfortunately, if the slab hauler driver puts a hot slab down on gravel that has been coated with the petroleum-based dust suppressant, there is smoke. We watched the plume of approximately 100% opacity for approximately 10 minutes. It did not dissipate.
 
 As we continued on to the BOF shop, we witnessed smoke from the sinter plant windbox exhaust. This large plume of steam and smoke had much higher amounts of smoke than I had seen on previous inspections. Mr. Maciel explained that the production level may be higher than normal because there was a performance test taking place at the time. Mr. Maciel asked that I drive within the plant to find Mr. Warren Howard, a contractor that reads opacity for Mittal. We found Mr. Howard, then returned to the sinter plant to take Method 9 readings. I walked to a viewing area and began my readings. Mr. Howard joined me after awhile and began taking readings of his own. 
 
 Mr. Maciel, Mr. Howard and I then drove to the BOF shop to view the #3 hot metal desulfurization station from outside the northeast corner of the BOF shop. There were no visible emissions escaping outside the wall of the BOF shop during reladle or desulfurization. The wind was blowing emissions into the BOF shop.  
 
 Mr. Maciel and I drove to meet with Mr. Carlos Patino, Mr. Phil Kelley, and Mr. Jake Smidt of Mittal to discuss the six boilers. Mittal explained that they run all six boilers online at all times and use the steam to create power. Three turbogeneraters make between 120 and 180 MW per day. Mittal burns natural gas, coke oven gas and blast furnace gas in the boilers. Fuel oil was burned approximately six years ago. I asked about modification to the boilers and Mittal explained that they replaced the igniters in the boilers from the kind that burn natural gas to those that burn coke oven gas. This change reduced natural gas usage and increased coke oven gas usage. Some boilers had new digital controls installed in the mid and late 1990's and Mittal suffered less down time because of it. About half of the tubes in boiler 11 were replaced in-kind in 1996.
 
 6/1/07
 
 Mr. Bagherian, Ms. Onyszko of U.S. EPA and I inspected the BOF shop and D blast furnace cast house with Mr. Maciel. Mittal had requested and received a one year compliance extension for the Subpart FFFFF NESHAP. This extension allowed Mittal to install new controls for secondary emissions at the BOF shop and at C and D blast furnaces to control emissions from the trough and tilting runner.
 
 We first viewed a tap hole drilling at D casthouse. Mr. Barry Felton of Mittal explained the operations and equipment. We observed the new hood over the trough and new, larger ductwork at the tilting runner cover. The system appeared to capture most emissions during drilling and steady tapping, but significant emissions evaded the capture hoods just as the hot metal began to flow. Mittal claimed it was still tuning the system in an attempt to improve capture during the tap hole opening.
 
 The next destination was the BOF shop where we met with Mr. Ray Vincel of Mittal. We viewed a tap of one heat and then the charge of another at #1 vessel. The new baghouse and ductwork captured emissions from the charge via a new side-draft hood, and the tap sides were enclosed with ductwork pulling a draft from the enclosure. The system worked well and there were minimal emissions. 
 
 Lastly, Ms. Onyszko performed visible emission readings at D casthouse roof monitor. There were notable visible emissions from the monitor during the start of the tap, just as the group had witnessed while on the casthouse floor. 
 
 
 
RECORDS REVIEW AND DISCUSSION:
 
 BOF Vessels #3 is subject to NSPS recordkeeping and reporting requirements. I reviewed quarterly reports submitted to the State of Indiana for the four quarters of 2005, and first and second quarters of 2006. Deviations from emissions limits and parametric monitoring limits appeared to be duly noted.
  
 I also viewed records of VOC emissions from the sinter plant windbox. The emissions were reported "as-carbon". 
 
 
 
 
 
 
 DISCUSSION, FINDINGS AND RECOMMENDATIONS (separate from report)
 
 
 
 
                                        
                                        
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