ENCLOSURE 1

Facility Questionnaire for Electric Arc Furnace Steelmaking,

Part A.  Facility Information

1. 	Name and address of the PARENT COMPANY that owns the facility:

	

	

	

2. 	Name and address of legal OPERATOR of the facility, if different
than the legal OWNER

	

	

	

	

3. 	Complete street address of facility (physical location) and
latitude/longitude (in decimal degrees to 6 decimal places):

a. 	Address:  	

b. 	City: 	

c. 	State: 	

d. 	Zip: 	

e. 	County: 	

f.	Latitude:  	

g.   Longitude:  	

4. 	Provide mailing address of the facility if different than physical
location: 

a. 	Address: 	

b. 	City: 	

c. 	State: 	

d. 	Zip: 	

5. 	Facility contact able to answer technical questions about the
completed survey:

a. 	Name (First Name, Last Name): 	

b. 	Title: 	

c. 	Telephone number:  ___________________________   ext. 	

d. 	Fax number: 	

e. 	E-mail: 	

6. 	Is the facility a major source of hazardous air pollutant (HAP)
emissions? (CHECK one)  (A definition of size classification for HAP
emissions is located at the following link:   HYPERLINK
"http://www.epa.gov/ttn/atw/pollsour.html" 
http://www.epa.gov/ttn/atw/pollsour.html ).  See Appendix B for a list
of HAP. 

	 

          Yes

          No

If yes, please list the specific HAPs that result in major source status
and the major source categories or subcategories that apply under
Section 112:  

Specific HAPs: 
__________________________________________________________

Section 112 standard (s) or subpart
(s):_______________________________________

7. 	Facility NAICS codes (FILL in)

Note: The primary NAICS code represents the line of business that
generates the most income for the facility.  The list of NAICS codes is
located at the following link:    HYPERLINK
"http://www.census.gov/eos/www/naics/" 
http://www.census.gov/eos/www/naics/  

a.	Primary NAICS code	 

b.	Other facility NAICS codes: ______________, ______________,	

8. 	Company Size (CHECK one)

Note:  Approximate number of employees (worldwide) of the business
enterprise that owns this facility, including where applicable, the
parent company and all subsidiaries, branches, and unrelated
establishments owned by the parent company.  

___ <50

___ 50-99

___ 100-499

___500-749

___ 750-999

___ >1000

9. 	Facility Size (CHECK one)

Note:  Approximate number of employees at facility in location
identified in question #3 above.

___ <50

___ 50-99

___ 100-499

___ 500-749

___ 750-999

___ >1000

10. 	Is the legal owner a small entity as defined by the Regulatory
Flexibility Act (if known)?  

(CHECK one)

Note:  For private businesses, small entity is defined for each NAICS of
the owning entity based on number of employees and/or company revenue. 
The parent company number of employees is used for the iron and steel
mills industry subsector (331).  The small business size standards for
NAICS subsectors is located at the following link:  HYPERLINK
"https://epic.od.nih.gov/naics/Naicscodelist.asp" \l "Manufacturing"
https://epic.od.nih.gov/naics/Naicscodelist.asp#Manufacturing 

___ Yes

___ No

11. 	a)	Does this facility have a Title V permit?

___ Yes

___ No

	b)	If yes, please provide a copy of the most current Title V permit.

	c)	Is the facility subject to Part 63, Subpart YYYYY (EAF Area Source
Rule)?

		___ Yes

		___ No

	d)	If yes, please indicate the selected compliance option(s):

		___ Site specific plan for mercury switches

		___ Option for EPA-approved mercury programs

		___ Option for specialty metal scrap

		___ Scrap that does not contain motor vehicle scrap

	e)	Is the facility subject to the NSPS for EAF (Subparts AA or AAa)?

		___ Yes

		___ No

	f)	If yes, please indicate which NSPS limits apply:

		___ Subpart AA

		___ Subpart AAa

	g)	Is the facility subject to a state mercury emission limit?

		___ Yes

		___ No

		If yes, please identify the limit and the regulation:

		______________________________________________

12. 	Normal Facility Production Hours:

	Most recent year of normal operation for your facility: ________

	Hours/day: ___________________

	Shifts/day: ___________________

	Days/week:___________________

	Weeks/year: __________________

	

	2009 Facility Production Hours (if different from above):

	Hours/day: ___________________

	Shifts/day: ___________________

	Days/week:___________________

	Weeks/year: __________________

13. 	Amount of steel produced in 2009 and the most recent year of normal
operation since 2003 (if different).  Please SPECIFY the alternate year
below, if used:

		tons of carbon steel produced 2009

		tons of stainless steel produced 2009

		tons of high alloy steel produced 2009

		tons of carbon steel produced in last normal operating year

		Year OTHER THAN 2009

		tons of stainless steel produced in last normal operating year

		Year OTHER THAN 2009

		tons of high alloy produced in last normal operating year

		Year OTHER THAN 2009

14. 	Amount of scrap charge in 2009 OR the most recent year of normal
operation since 2003 (if different).   Please SPECIFY the alternate year
below, if used:

_______________	tons of scrap charged in 2009

		tons of scrap charged in last normal operating year

		Year OTHER THAN 2009

 

15. 	Please provide a copy of a schematic of the plant layout for
equipment in service under subpart YYYYY.  Please include unit IDs in
the schematic that correspond to the unit IDs used in Table 1.  

	(CHECK one) 

	

___ Yes, I have provided a schematic.

___ No, I have not provided a schematic because (state reason):

	_____________________________________________

16. 	Types of charging system and burners used at a facility’s EAF.

	a)	What type of charging system does your EAF employ?  

		___ Top Charge

		___ Side Charge

		___ Continuous charging system

	Please describe the charging system (e.g., Consteel, shaft furnace,
twin shell, etc.): 

	__________________________________________________________

	b)	Does the EAF employ a sidewall burner system?

		___ Yes

		___ No

		

		If yes, please describe the burner system:
____________________________Part B.  Previously Performed Testing and
Test Reports for Mercury, PM, Opacity, and CO Emissions at Electric Arc
Furnace Steelmaking Facilities 

Please provide copies of all previous emission test reports for the
emission units and pollutants listed in the table below performed using
any EPA reference test methods within the last five (5) years.  Please
provide either the full test reports or summary pages that contain the
information listed below:  

If only test summaries are submitted, please ensure that the following
information is included (at a minimum):  

(a) Pollutants and emission rates measured (e.g., lb/hr, gr/dscf,
lb/ton) for the pollutants of interest for this survey, including
mercury, CO, and any of the forms of PM plus melt shop opacity
observations, 

(b) Stack parameters (volumetric flow rates, temperature, % oxygen, %
moisture, etc.), 

(c) Names of the test methods or procedures used, 

(d) For PM, identify whether it is filterable (front half) PM, total PM
(filterable plus condensable), PM10, or PM2.5 (indicating whether it is
filterable, condensable, or both), 

(e) Information on actual production or processing rates during the
test, and 

(f) Identify any runs where the process or control device was not
operating normally and any runs that were invalidated (including the
reason).  

Please include test reports for tests conducted for engineering purposes
if the tests were performed according to EPA reference test methods and
are representative of normal operation.  

We expect all facilities to have recent PM and opacity compliance test
results for the GACT PM and opacity limits in Subpart YYYYY.  Please
submit opacity data for the meltshop collected during PM performance or
compliance tests conducted over the past 5 years, plus up to 50 sets of
daily opacity observations (if available) representative of normal
operations, conducted at other times over the past 5 years.   

  

Emission unit	Pollutants/Opacity

EAF primary control device1 	PM (including any tests for filterable and
condensable PM, PM10, PM2.5), mercury (including any tests for
particulate divalent mercury, gaseous divalent mercury, and elemental
gaseous mercury), carbon monoxide (CO)

EAF meltshop	Opacity by EPA Method 9

EAF control device for fugitive emissions from charging and tapping (if
different from the primary control device)	Mercury, PM (including any
tests for filterable and condensable PM, PM10, PM2.5)

Argon-oxygen decarburization (AOD) vessel control device	PM (including
any tests for filterable and condensable PM, PM10, PM2.5)

Ladle metallurgy facility (LMF) control device	PM (including any tests
for filterable and condensable PM, PM10, PM2.5)

1 The primary control device for an EAF with multiple baghouses is the
baghouse serving the direct-shell evacuation control (DEC) of the EAF. 
If there is no DEC, the baghouse primarily responsible for controlling
emissions from melting and refining operations is the primary control
device.  

For the previous tests that you enclose, please fill in the summary of
operation information during source testing in Table 1 for each test
report submitted.  You may make duplicates of Table 1 for each test,
facility, or emission unit tested.  Note that the production rate of raw
steel during each of the emission tests is part of the requested
information.  You are not required to enter previously-conducted
emission test results into the ERT database.  

Note that facilities with previously performed PM, PM2.5, mercury,
opacity, or CO tests are only exempt from the testing request in
Enclosure 2 if the testing was performed in the last five years, the
testing was done with EPA methods or approved alternative methods, and
certain criteria specified in Section 1.0 of Enclosure 2 are met.  If
you intend to submit past test data, you must do so by 30 days from
receipt of this letter because if EPA determines that such data are not
representative, you will need to conduct the testing and submit the test
data required by this survey by 120 days from the receipt of this
letter.   

2. 	If you are providing test reports, please fill in the following
information: 	

I have included previous test reports from the last five years (2005 to
present): 

	_________	No

		

_________	Yes, from 2005 or later (for SOME of the pollutants
requested*) AND 

			________	I am asking for a testing waiver for this pollutant

			________	Pollutant name

	_________	Yes, from 2005 or later (for ALL of the pollutants requested
*) AND 

			________	I am asking for a full waiver for this testing

	* Test requests include stack emissions of mercury, speciated forms of
mercury, PM, PM10, PM2.5 (filterable and condensable), and CO and EPA
Method 9 observations of opacity of melt shop fugitive emissions.

b.	If you have enclosed test reports, please indicate the pollutants
measured, the EPA methods used, the production rate during the tests,
and the year the data was taken.  The pollutants of primary concern are
Hg, PM, PM2.5 (filterable and condensable), CO, and opacity.

	Pollutant: 		______________ 	Pollutant:		______________

	Test(s) Used:		______________	Test(s) Used:		______________

	Production Rate:	______________	Production Rate:	______________

	Year(s) of Data:	______________	Year(s) of Data:	______________

	Pollutant: 		______________ 	Pollutant:		______________

	Test(s) Used:		______________	Test(s) Used:		______________

	Production Rate:	______________	Production Rate:	______________

	Year(s) of Data:	______________	Year(s) of Data:	______________

	

	

3.   	What percent of your scrap charge is shredded automobile scrap
(e.g., ISRI Code 210)?   Please provide your best estimate (average and
a range) if you do not have actual records:  Please differentiate
between what is typical and what was used during the source tests 

Typical		__________% (average) and ________% to ______% (range)

During tests		__________% (average) and ________% to ______% (range)

4.   	Please provide any available information on the mercury content of
the carbon electrodes:

__________ppm (average) and ________ppm to ______ppm (range)

5. 	Use the table below to report the generation rate of your EAF dust
(PM) and its HAP metal content.  Fill in the average and range in the
table below for HAP metals listed below, or provide the results of at
least five of the most recent analyses of the EAF dust for metals.

Dust (PM) generation rate: __________ tons/ton of raw steel  

HAP Metal	Content

	ppm (average)	ppm (low)	ppm (high)

Mercury



	Antimony



	Arsenic



	Beryllium



	Cadmium



	Total Chromium



	Hexavalent Chromium



	Cobalt



	Lead



	Manganese



	Nickel



	Selenium



	

6. 	Indicate below the fate of your EAF dust in 2009 and last year of
normal/full operation, if different.   (Indicate the year if not 2009:
__________.)

Fate of EAF dust	Tons per year at 2009 production rates	Tons per year at
normal production rates

Landfilled 



Shipped to a zinc recovery facility



Shipped for use as fertilizer



Recycled to EAF



Other (describe):





Table 1:  Previously Performed Source Tests (2005 to 2010)

Summary of Operational Information for Each Test Report Submitted*

Facility name

	Emission unit(s) ID - use same ID as in schematic

	Latitude of stack (decimal degrees, 6 decimal places)

	Longitude of stack (decimal degrees, 6 decimal places)

	Date of test

	Indicate if before or after MACT or GACT controls in place

	

Item	

Run 1	

Run 2	

Run 3	Units of Measure

Steel production (EAF, AOD vessel, LMF)





Type of scrap charged (for EAF test reports only):

	No. 2 heavy melting steel (ISRI Codes 204-206)





Shredded scrap (ISRI Code 210)





Other type of scrap 1 (describe)







Other type of scrap 2 (describe)







Other type of scrap 3 (describe)







Other type of scrap 4 (describe)







Other type of scrap 5 (describe)







Direct reduced iron charged





Other ferrous materials charged (describe):





Metallurgical coke charged





Petroleum coke charged





Coal charged





Lime charged





Alloy 1 charged (describe):







Alloy 2 charged (describe):







Alloy 3 charged (describe):







Tires charged





Other materials charged (list):







* Please make copies of this page for each previous test report
submitted.  We prefer receiving the completed tables electronically in
the MS Word file included with this package.

Enclosure 2

Source Testing Request for Electric Arc Furnace Steelmaking Facilities:

Procedures, Methods, and Reporting Requirements

This document provides an overview of approved methods, target pollutant
units of measure, and reporting requirements for owners/operators of
electric arc furnace (EAF) steelmaking facilities who are required to
provide emission test data under EPA’s authority under the Clean Air
Act (CAA) section 114. (42 U.S.C 7417).  See Enclosure 3 for details
about this authority.  The purpose for this testing is to gather data on
air pollutant emissions from EAF steelmaking facilities in this source
category for EPA air pollution rules that apply to these sources.  This
document is organized as follows: 

	1.0   Stack Testing Procedures and Methods

	2.0   How to Report Data

	3.0   How to Submit Data

	4.0   Contact Information for Questions

1.0  Stack Testing Procedures and Methods

This information collection request includes stack (performance) test
data requests for mercury, particulate matter (PM), PM 2.5 micrometers
(µm) or less in diameter (PM2.5), and carbon monoxide (CO) along with
EPA Method 9 observations of melt shop opacity.  We understand that
emission testing for some of these pollutants may have been recently
completed for some or all of the facilities.  In that case, we are not
requesting additional emission testing but only the submittal of the
test reports representative of your current operations.  You may submit
previous test reports instead of testing if the tests were conducted
within the past 5 years (2005 or later) using EPA methods shown in Table
1 and meet the following criteria:

Mercury testing was performed for the EAF primary control device for at
least 30 days using EPA Performance Specification (PS) 12A, 12B, or EPA
Method 30B.  (Note that we would like reports of tests performed in the
last five years for mercury measured by ANY method for information
purposes only; see Enclosure 1.)

Mercury testing was performed for the EAF control device for fugitive
emissions from charging and tapping for at least 7 days using EPA
Performance Specification (PS) 12A, 12B, or EPA Method 30B.  (Note that
we would like reports of tests performed in the last five years for
mercury measured by ANY method for information purposes only; see
Enclosure 1.)

CO testing was performed using EPA Method 10 or 10B; or CO data was
collected from a CO continuous emissions monitoring system (CEMS).

PM and PM2.5 (both filterable and condensable) testing was performed for
the EAF primary control device or control device for fugitive emissions
from charging and tapping according to the testing procedures in the
NSPS (Subparts AA or AAa) or the GACT standard (Subpart YYYYY). 

Melt shop opacity readings were performed during the EAF PM and PM2.5
tests.

PM and PM2.5 (both filterable and condensable) testing was performed
according to your permit requirements for emission controls (other than
the EAF primary control device and control device for fugitive emissions
from charging and tapping) applied to AOD vessels or LMFs.

If you do not have previous tests that qualify, please perform testing
using the procedures described in Section 1.2 and Table 1.  Prior EPA
approval is required if you choose to submit past test data in order for
EPA to determine that the data and information you have identified are
representative.  

IMPORTANT NOTE:  If you intend to submit past test data, you must do so
by [insert date] because if EPA determines that such data are not
representative, you will need to conduct the testing and submit the test
data required by this survey by 120 days from the date of this letter.  


If you operate an EAF steelmaking facility, you are required to conduct
sampling to determine the following parameters:

Mercury (7439-97-6)

Carbon Monoxide (630-08-0)

Particulate Matter (Filterable)

Particulate Matter2.5 Filterable

Particulate Matter2.5 Condensable

Opacity

At a minimum, the process units listed below should be tested if you
operate an EAF steelmaking facility. 

Process Unit(s)	Test Location	Parameters to Test 

EAF primary control device 	Outlet 	Mercury, CO, PM, PM2.5 filterable,
PM2.5 condensable

EAF melt shop	Melt shop roof vent	Opacity

EAF control device for fugitive emissions from charging and tapping
Outlet	Mercury, PM, PM2.5 filterable, PM2.5 condensable

AOD control device	Outlet	PM, PM2.5 filterable, PM2.5 condensable

LMF control device	Outlet	PM, PM2.5 filterable, PM2.5 condensable

 

1.1  How to Select Sample Location and Gas Composition Analysis Methods

In addition to the tests for the target pollutants, use EPA Method 1 for
negative pressure baghouses and EPA Method 5D for positive pressure
baghouses, both in Appendix A of Part 60, to select the locations and
number of traverse points for sampling.  Please note that, for sources
equipped with emission controls, you are required to sample only at the
outlet of the control device.  For a complete copy of the methods and
guidance information, see   HYPERLINK
"http://www.epa.gov/ttn/emc/methods/method1.html" 
http://www.epa.gov/ttn/emc/methods/method1.html  and   HYPERLINK
"http://www.epa.gov/ttn/emc/methods/method5d.html" 
http://www.epa.gov/ttn/emc/methods/method5d.html .   

Analysis of flue gas composition, including oxygen concentration, also
must be performed simultaneous with PM, PM2.5, and CO testing using U.S.
EPA Methods 3A, 3B, or 3 of Appendix A of Part 60.  See   HYPERLINK
"http://www.epa.gov/ttn/emc/methods/method3a.html" 
http://www.epa.gov/ttn/emc/methods/method3a.html  for Method 3A,  
HYPERLINK "http://www.epa.gov/ttn/emc/methods/method3b.html" 
http://www.epa.gov/ttn/emc/methods/method3b.html  for Method 3B,  
HYPERLINK "http://www.epa.gov/ttn/emc/methods/method3.html" 
http://www.epa.gov/ttn/emc/methods/method3.html  for Method 3
information. 

1.2  Source Test Methods and Reporting

Table 1 presents a summary of the required and recommended alternative
test methods, minimum number of tests runs required, minimum test run
duration, and units of measure.  For copies of the recommended U.S. EPA
methods and additional information, please refer to EPA’s Emission
Measurement Center website:    HYPERLINK "http://www.epa.gov/ttn/emc/" 
http://www.epa.gov/ttn/emc/ .  For copies of the recommended Other Test
Methods (OTM), please refer to   HYPERLINK
"http://www.epa.gov/ttn/emc/prelim.html" 
http://www.epa.gov/ttn/emc/prelim.html .  If you would like to use a
method not on this list, please contact EPA for approval of an
alternative method.  If you have not performed emissions testing using
EPA methods or approved alternatives (shown in Table 1) in the past 5
years that meet the criteria provided in Section 1.0, you must conduct
emissions testing for mercury, PM, PM2.5, and CO at the exit of each EAF
shop’s primary control device; opacity of emissions from the melt shop
during the EAF PM and PM2.5 test; mercury, PM, and PM2.5 at the exit of
each EAF shop’s control device for fugitive emissions, and PM, and
PM2.5 for each AOD vessel control device and LMF control device (if they
are separately controlled and not routed to the EAF primary control
device).  If you have test data that were collected in the last five (5)
years, we also would like to have these data.  See Enclosure 1 for
details about the information we need in addition to these tests
reports.

Concentration and Flow Measurements—Positive Pressure Fabric Filters
(baghouses)

In the case of sampling at positive pressure baghouses for PM and PM2.5
concentrations, conduct sampling of the exhaust of one compartment of
the baghouse using the procedure for setting isokinetic sampling rates
as described in Method 5D.  In addition, the compartment selected should
be the one most representative of normal operation.  Only one baghouse
compartment needs to be traversed for PM, and for mercury, only a single
representative point in one compartment needs to be sampled.  Follow
Section 8.3 in Method 5D for determining the outlet stack flow rate
(i.e., measure the flow rate at the inlet using Method 2 and correct for
dilution air by measuring either temperature or CO2 concentration at
both the inlet and the sampling point, or alternatively, block or seal
all sources of dilution air between the flow measurement location and
the pollutant measurement location on a temporary basis during the
testing).

For the continuous mercury testing, facilities with positive pressure
baghouses may sample for mercury concentration at a single
representative point in a single compartment.  Determine the volumetric
flow rate during the continuous mercury emission testing using fan
performance curves for either static pressure or amperage unless the
facility already has calibrated flow meters installed for volumetric
flow rate, in which case the facility must use the calibrated flow
meters to determine the volumetric flow rate.  When using fan
performance curves, the facility should measure and record the static
pressure (or pressure differential across the fan) or the amperage,
collect at least three data points to confirm or adjust the
manufacturer's fan curve to the site-specific application, and monitor
that parameter to determine the volumetric flow rate during the mercury
emission test.  Alternatively, if the fan amperage is maintained during
the mercury testing within ± 15% of the average established during the
PM/PM2.5 testing, use the average flow rate from the PM/PM2.5 testing. 
Record fan amperage in accordance with the procedures in the NSPS
(Subpart AAa).  Facilities may also choose to install, calibrate, and
maintain a flow meter for continuously measuring and recording the
exhaust volumetric flow rate during mercury testing.  The volumetric
flow rate must be reported for each sampling period (e.g., daily to
weekly when using the sorbent trap).  

Continuous Flow Measurements—Negative Pressure Fabric Filters
(baghouses)

For the continuous mercury testing, facilities with negative pressure
baghouses should determine the volumetric flow rate using fan
performance curves as described above for positive pressure baghouses
unless the facility already has calibrated flow meters installed for
volumetric flow rate, in which case the facility must use the calibrated
flow meters to determine the volumetric flow rate.  A facility may
choose to install, calibrate, and maintain an instrument for
continuously measuring and recording the exhaust flow rate to the
atmosphere rather than using fan performance curves.  If this option is
chosen, install each sensor of the flow rate monitoring system in a
location that provides representative measurement of the exhaust gas
flow rate at the sampling location for mercury concentration taking into
account the manufacturer’s recommendations.  The flow rate monitoring
system must be:

Designed to measure the exhaust flow rate over a range that extends from
a value of at least 20 percent less than the lowest expected exhaust
flow rate to a value of at least 20 percent greater than the highest
expected exhaust flow rate.

Accurate within 5 percent of the exhaust flow rate.

Equipped with a data acquisition and recording system that is capable of
recording values over the entire range specified above. 

The signal conditioner, wiring, power supply, and data acquisition and
recording system for the flow rate monitoring system must be compatible
with the output signal of the flow rate sensors used in the monitoring
system.  The flow rate monitoring system must be designed to complete a
minimum of one cycle of operation for each successive 15-minute period. 
To have a valid hour of data, the flow rate monitoring system must
measure and record at least three of four equally spaced data values (or
at least 75 percent of the total number of values) for each hour (not
including startup, shutdown, malfunction, or out-of control periods). 
Perform an initial calibration of the flow rate monitoring system
according to manufacturer’s recommendations.  

Testing Similar EAFs 

If a facility has multiple EAFs that melt the same types of scrap from
the same scrap suppliers and there are no significant differences in the
other materials charged to the furnace or in the type of steel produced,
the facility is required to test only one of these EAFs for mercury
emissions under this test request.  Please fill out the table in
Appendix C to report the parameters used to establish similarity. 
Please provide a description of the required parameters used to
establish the similarity between your EAFs, along with other identifying
information.  All parameters that are denoted with an asterisk (*) are
required to be the same for EAFs to be considered “similar.”

Procedures for EAFs Operating on Reduced Schedules

We understand that some EAFs may not operate during each shift every day
or may not operate every day.  For EAFs that do not operate for full
days or every day during the week, sampling for mercury emissions from
the primary control device must be performed for each day the EAF
operates, even if it operates for only part of the day, for 30
consecutive calendar days when using PS 12A or Method 30B, or for four
(4) consecutive calendar weeks when using PS 12B.  If the sampling term
described above does not provide at least 8 daily average measurements,
the EAF facility must continue sampling and obtain a minimum of 8 daily
average mercury measurements for the primary control device.  

Sampling for mercury emissions for the control device for fugitive
emissions from melting and tapping (if different from the primary
control device) for an EAF not on a full operating schedule must be
performed for seven (7) consecutive calendar days when using PS12A or
Method 30B, or for one (1) calendar week when using PS 12B.   If the
sampling term described above does not provide at least three (3) daily
measurements for the fugitive emission control device, the EAF facility
must continue sampling and obtain a minimum of three (3) daily average
mercury measurements for the fugitive emission control device.  

If your EAF does not operate every day and you qualify for the minimum
sampling requirements above, please submit documentation (such as copies
of heat sheets showing operating days and hours) that shows this reduced
operating schedule has been in place for at least three (3) months from
the date of this letter.

Table 1. Summary of Required EAF Steelmaking Facilities 

Source Test Methods and Alternative Methodsa

Pollutant or Parameter	Recommended Method	Alternative Method	Minimum No.
of Test Runs and Duration	Units of Measureb

Mercury-- EAF  primary control device

	PS 12A, PS 12B, or EPA Method 30B 

	None	For PS 12A, sample for 30 consecutive calendar daysc (report daily
averages); for PS 12B, replace sorbent traps weekly and sample for four
(4) consecutive calendar  weeksc (report weekly averages); for Method
30B, replace the sorbent traps daily and sample for 30 consecutive
calendar daysc (report daily averages). 	mg/m3

mg/hr

mg/ton of raw steel

Mercury -- EAF control device for fugitive emissions from charging &
tapping	PS 12A, PS 12B, or EPA Method 30B 

	None	For PS 12A, sample for seven (7) consecutive calendar daysc
(report daily averages); for PS 12B, sample for one (1) calendar weekc;
for Method 30B, replace the sorbent traps daily and sample for seven (7)
consecutive calendar daysc (report daily averages). 	mg/m3

mg/hr

mg/ton of raw steel

PM

	EPA Method 5 (negative pressure baghouses) or EPA Method 5D (positive
pressure baghouses)	None	A minimum of three (3) runs that are performed
according to the testing requirements in the NSPS (subparts AA or AAa). 
	mg /m3 

mg/hr

mg/ton of raw steel



PM2.5 filterable & PM2.5 condensable 	EPA OTM 27 & 28; for positive
pressure baghouses, use EPA Method 5D  for establishing isokinetic
sampling rates 	Combination of EPA Method 5D and OTM 028 if sampling
location does not meet test equipment or method requirements of OTM 027
(e.g., if flow rate is too low)	A minimum of three (3) runs that are at
least four (4) hours and cover an integral number of heat cycles,d Weigh
and report the cyclone catch separately.	mg /m3 

mg/hr

mg/ton of raw steel



Opacity 

(melt shop)	EPA Method 9	None	Aggregate total of 180 minutes of
observation concurrent with PM and/or PM2.5 testing of EAF primary
control device.	Percent (%)

Carbon Monoxide	EPA Method 10 or 10B	CO CEMS	A minimum of three (3) runs
at least 4 hours each that cover an integral number of heat cycles.d 	mg
/m3 

mg/hr

mg/ton of raw steel

Flow Rate-- PM and PM2.5 testing 	EPA Method 2, 2F, or 2G  (negative
pressure baghouses) or EPA Method 5D, Section 8.3, (positive pressure
baghousese)	None	With each test run as required to support PM/PM2.5/CO
testing	acfm and dscfm

Flow rate--  Mercury testing of negative and  positive pressure
baghouses	 Measure fan  amperage and a correlation to determine flow
rate (see Section 1.2 for details)f,g	Install, calibrate, and operate an
instrument to continuously measure flow rate (see Section 1.2 for
details)	Each operating day for PS 12A and Method 30B; each operating
week for PS 12B	acfm and dscfm

O2 / CO2	EPA Method 3A	EPA Method 3 or 3B	Simultaneous with each
PM/PM2.5/CO test run.	Volume %, dry

Moisture	EPA Method 4	None	Simultaneous with each PM/PM2.5 test run.
Volume %

a If a single emission control device serves multiple emission units
(e.g., any combination of EAF exhaust, EAF fugitive emissions, AOD
vessel, and LMF), measure and report the combined emissions and test
while each unit is operating under normal and typical operating
conditions

b Where mg/m3 = milligrams per dry standard cubic meter, mg/hr =
milligrams per hour, mg/ton = milligrams per ton, acfm = actual cubic
feet per minute, and dscfm = dry standard cubic feet per minute.  Data
may be obtained and/or recorded in alternative units of measure, but
they must be converted to the above units before reporting for this test
request. 

c See the text above for minimum sampling requirements for EAFs that do
not operate all day or do not operate every day in the “Procedures for
EAFs Operating on Reduced Schedules” section.

d Heat cycle sampling may start and stop at any point in the cycle as
long as the start and stop occur at the same point in the cycle.  An
“integral number” means a whole number, e.g., 1, 2, 3, and not half
or partial numbers, e.g., 1.5, 2.75, etc.  Sampling for an integral
number of heat cycles is not required for facilities operating two or
more EAFs controlled by a common control device; in this case, follow
the testing requirements in the NSPS (Subpart AAa).  

e You may measure CO2 concentrations at both the inlet and outlet of the
positive pressure fabric filter in conjunction with the pollutant
sampling to correct pollutant concentrations for dilution and to
determine isokinetic sampling rates. You may use either Method 3A or 3B
(with integrated bag sampling).  Alternatively, all sources of dilution
air between the flow measurement location and the pollutant measurement
location can be blocked or sealed on a temporary basis during the
testing. 								(Continued)

f Establish a fan amperage range or correlation with flow during
PM/PM2.5 testing.  Determine flow rate using the correlation with fan
amperage, or if the fan amperage is maintained during the mercury
testing within ± 15% of the average established during the PM/PM2.5
testing, use the average flow rate from the PM/PM2.5 testing.  Record
fan amperage in accordance with the procedures in the NSPS (Subpart
AAa).

g Facilities must use a continuous flow meter if already installed, or
may elect to install and use a flow meter if they choose to (See Section
1.2 for details).  

1.3  Electric Arc Furnace Baghouse Dust Sampling and Mercury Analysis

If you operate an electric arc furnace steelmaking facility, you must
sample and analyze the EAF baghouse dust during the mercury emission
test to determine the concentration of mercury.  EAF baghouse dust
samples must be collected once per day during each week of the test for
mercury emissions and composite into a weekly sample.  Each weekly
sample must be analyzed using the procedures in the following table

Parameter/Pollutant	Recommended Method	Alternative Method	Units of
Measure

EAF Dust Digestion	EPA SW 846 Method 3050	EPA SW 846 Method 3051	Not
applicable

Mercury Analysis	EPA SW 846 Method 7471	None	mg/kg (dry basis)



For copies of the recommended U.S. EPA SW-846 methods, please refer to
EPA’s SW-846 Online website:    HYPERLINK
"http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm" 
http://www.epa.gov/waste/hazard/testmethods/sw846/index.htm .

1.4  Ensuring Data Quality of the Source Tests Performed

While we are not specifying numerical minimum detection levels for the
tests to be performed, we have specified the testing conditions and
methods required, including test run times when appropriate, which we
believe will provide data of a quality sufficient for decision making.  

We remind source owners and testers of the CAA section 114(a)(1)
requirement to provide information requested for the development of
emissions standards using methods that provide data necessary for the
decisions.  That includes data of quality sufficient to support those
decisions.  For the most part, we can identify test methods and
procedures that will satisfy those decision making needs (e.g., minimum
sampling times).  In other cases, we recognize that the source owner's
or tester's selection of test procedures or equipment could bear
significantly on the quality of the data. 

We believe that the CAA is clear in that it is the responsibility of the
source and the tester to apply methods and procedures that result in
optimized data quality, including providing for the lowest possible
detection limits considering practical and reasonable limitations.  For
example, source owners and testers should not automatically choose to
use low or medium quality equipment for testing (e.g., for cost reasons)
if high quality equipment is reasonably available.  We will review test
reports in light of this expectation and will be particularly mindful of
whether the testing procedures applied are representative of the highest
reasonably expected capabilities (e.g., comparing reported minimum
measurement detection levels between tests and testers).  

If we believe that a source owner or tester has failed to meet the
requirement of the CAA to provide data sufficient for our decisions, we
can and will request additional measurements that require the use of
improved testing procedures. 

On completion of your required tests, please provide either the full
test reports or summary pages that contain the information listed below.
 If only test summaries are submitted, please ensure that the following
information is included (at a minimum):  

Run-by-run pollutants and emission rates measured (e.g., lb/hr, gr/dscf,
lb/ton) for the pollutants of interest for this survey, including
mercury, CO, and any of the forms of PM plus melt shop opacity
observations; 

Stack parameters (volumetric flow rates, temperature, % oxygen, %
moisture, etc.); 

Names of the test methods or procedures used; 

For PM, identify whether it is filterable (front half) PM, total PM
(filterable plus condensable), PM10, or PM2.5 (indicating whether it is
filterable, condensable, or both);

Information on actual production or processing rates during the test; 

Identify any runs where the process or control device was not operating
normally and any runs that were invalidated (including the reason); and

Quality assurance and quality control activities performed.  

In addition to the emission test data, you should also report the
following process information recorded at the time of, and during, the
emissions test:  

Stack or exhaust gas flow rate (as determined using EPA Method 2, 2F, 
2G, or 5D); and

Production rate of raw steel during each of the emission tests, as in
Table 2 below.

2.0  How to Report Data

The method for reporting the results of any testing and monitoring
requests depends on the type of tests and the type of methods used to
complete the test requirements.  This section discusses the requirements
for reporting the data.

2.1  Reporting Stack Test Data

If you conducted additional stack tests in response to this test request
using one of the methods listed in Table 3 shown below, you must report
your data using the EPA Electronic Reporting Tool (ERT) Version 3.  ERT
is a Microsoft® Access database application.  Two versions of the ERT
application are available.  If you are not a registered owner of
Microsoft® Access, you can install the runtime version of the ERT
Application.  Both versions of the ERT are available at   HYPERLINK
"http://www.epa.gov/ttn/chief/ert/ert_tool.html" 
http://www.epa.gov/ttn/chief/ert/ert_tool.html .  The ERT supports an
Excel spreadsheet application (which is included in the files downloaded
with the ERT) to document the collection of the field sampling data. 
After completing the ERT, you will also need to attach an electronic
copy of the emission test report (PDF format preferred) to the
Attachments module of the ERT.  Both the ERT spreadsheet and the
emission test report should be transmitted to EPA using one of the
options described below in Section 3.  You are not required to report
your data from previously-conducted emission tests using the ERT. 

Alternatively, if you perform tests with methods PS12A, PS12B, or EPA
Method 30B for mercury; EPA Method 9 for opacity; EPA Method 10B or CO
CEMS for CO testing; EPA Method 2F, 2G, or 5D for flow rate; EPA Method
3B for O2/CO2; or any of the EPA SW 846 Methods for EAF baghouse dust
sampling and analysis, you must report the results of these tests in an
individual Microsoft® Excel “EAF Emission Test Template.”  The
individual Excel EAF templates are specific to each pollutant and type
of unit, and they can be downloaded from the Electric Arc Furnace EPA
Test Request 2010 website   HYPERLINK "http://icr2010.rti.org" 
http://icr2010.rti.org .  

You must report the results of each test on an appropriately labeled
worksheet that you develop using the EAF Emission Test Template that
corresponds to the specific tests requested at your facility.  If more
than one source at your facility was tested using methods not currently
supported by the ERT, you must make an electronic copy of the EAF
worksheet to report these data, making sure to update the source ID in
order to distinguish between each separate source/test.  After
completing the EAF worksheet, you must also submit an electronic copy of
the emission test report (PDF format preferred).  Both the EAF worksheet
and the emission test report should be transmitted to EPA using one of
the options described below in Section 3.

Table 3:  List of Applicable Test Methods Supported by 

EPA’s Electronic Reporting Tool (ERT)

Test Methods Supported by ERT

Methods 1 through 4

Method 3A

Method 5

Method 5D

Method 10 

Method 29

OTM 27

OTM 28

Note:  Data collected with other EPA methods or 

alternative methods have an alternate reporting tool 

discussed in Section 2.1.





2.2  Required Fields for ERT Reporting

Enclosure 8 provides an EPA ERT Version 3 example test plan and lists
each field within the ERT.  Note that the required reporting includes
the latitude and longitude of each stack tested (in decimal degrees to 6
decimal places).

2.3  Guidance for Calculating and Reporting Measurements Less Than
In-Stack Method Detection Levels for Emissions Data Submitted in
Response to Information Collection Request (ICR) Programs 

Please identify the status of the measured values relative to the
detection levels on the individual Excel spreadsheet or in the ERT
Access database using the following descriptions:

BDL (below detection level) – all analytical values used to calculate
and report an in-stack emissions value are less than the laboratory’s
reported detection level(s); 

DLL (detection level limited) – at least one but not all values used
to calculate and report an in-stack emissions value are less than the
laboratory’s reported detection level(s); or

ADL (above detection level) – all analytical values used to calculate
and report an in-stack emissions value are greater than the
laboratory’s reported detection level(s).

For each reported emissions value, insert the appropriate flag (BDL,
DLL, or ADL) in the Note line of Excel emission test spreadsheet
template or in the Flag column of the Electronic Reporting Tool (ERT).

Table 2:  Required EAF Source Tests Performed 2010 –

Summary of EAF Operation Information for Each Test Report Submitted1

Facility name

	Emission unit(s) ID - use same ID as in schematic

	Latitude of stack (decimal degrees, 6 decimal places)

	Longitude of stack (decimal degrees, 6 decimal places)

	Date of test

	Indicate if before or after MACT or GACT controls in place

	 

Item	

Run 1	

Run 2	

Run 3	Units of Measure

Steel production (EAF, AOD vessel, LMF)





Type of scrap charged (for EAF test reports only):

	No. 2 heavy melting steel (ISRI Codes 204-206)





Shredded scrap (ISRI Code 210)





Other type of scrap 1 (describe)





Other type of scrap 2 (describe)





Other type of scrap 3 (describe)





Other type of scrap 4 (describe)





Other type of scrap 5 (describe)





Direct reduced iron charged





Other ferrous materials charged (describe):





Metallurgical coke charged





Petroleum coke charged





Coal charged





Lime charged





Alloy 1 charged (describe):







Alloy 2 charged (describe):







Alloy 3 charged (describe):







Tires charged





Other materials charged (list):







1 Please make copies of this page for each previous test reported.  We
prefer receiving the completed tables electronically in the MS Word file
included with this package. 

When reporting and calculating individual test run data:

For analytical data reported from the lab as “nondetect” or “below
detection level;”

Include a brief description of the procedures used to determine the
analytical detection and in-stack detection levels:

In the Note line of Excel emission test spreadsheet template; or

In the Comments line of Lab Data tab in the Run Data Details in the ERT.

Describe these procedures completely in a separate attachment including
the measurements made, the standards used, and the statistical
procedures applied.

Calculate in-stack emissions rate for any analytical measurement below
detection level using the relevant detection level as the “reported”
value.

Report the calculated emissions concentration or rate result:

As a bracketed “less than” detection level value (e.g., [<0.0105])
in the Excel emission test spreadsheet template and include the
appropriate flag in the Note line; or

As a numerical value in the ERT with the appropriate general flag in the
Flag column and as a bracketed “less than” detection level value
(e.g., [<0.0105]) followed by a space and any specific flag identifier
in the Comments line.  The following specific flag identifiers are
commonly used by laboratories:  B, E, J, Int, R, DPE.

Report as numerical values (i.e., no brackets or < symbol) any
analytical data measured above the detection level including any data
between the analytical detection level and a laboratory-specific
reporting or quantification level (i.e., flag as ADL).

For pollutant measurements composed of multiple components or fractions
(e.g., Hg and other metals sampling trains) when the result for the
value for any component is measured below the analytical detection
level; 

Calculate in-stack emissions rate or concentrations as outlined above
for each component or fraction;

Sum the measured and detection level values as outlined above using the
in-stack emissions rate or concentrations for all of the components or
fractions; and

Report the sum of all components or fractions:

As a bracketed “less than” detection level value (e.g., [<0.0105])
in the Excel emission test spreadsheet template and include the
appropriate flag in the Note line; or

As a numerical value in the ERT with the appropriate flag in the
Comments line.

Report also the individual component or fraction values for each run if
the Excel emission test spreadsheet template or ERT format allows; if
not (i.e., the format allows reporting only a single sum value):

For the Excel emission test spreadsheet template, next to the sum
reported as above report in the Notes line the appropriate flag along
with the values for the measured or detection level value for each
component or fraction as used in the calculations (e.g., 0.036,
[<0.069], 1.239, [<0.945] for a four fraction sample)

For the ERT, next to the sum reported as above, report in the Flag
column the appropriate general flag in the Comments column and the
measured or detection level value for each component or fraction as used
in the calculations followed by a space and any specific flag identifier
provided by the laboratory (e.g., 0.036, [<0.069] J, 1.239, [<0.945] B
for a four fraction sample)

For measurements conducted using instrumental test methods (e.g.,
Methods 3A,  10)

Record gaseous concentration values as measured including negative
values and flag as ADL; do not report as BDL

Calculate and report in-stack emissions rates using these measured
values

Include relevant information relative to calibration gas values or other
technical qualifiers for measured values in Comments line in the ERT

When reporting and calculating average emissions rate or concentration
for a test when some results are reported as BDL

Sum all of the test run values including those indicated as BDL or DLL
as numerical values

Calculate the average emissions rate or concentration (e.g., divide the
sum by 3 for a three-run test)

Report the average emissions rate or concentration average:

As a bracketed “less than” detection level value (e.g., [<20.06]) in
the Excel emission test spreadsheet template and include the appropriate
flag in the Note line

As a numerical value in the ERT and include the appropriate flag in the
Comments line.

3.0  How to Submit Data 

3.1  Non-confidential Data

You should submit your non-confidential data (including the responses to
the survey questions, test reports from previous tests, new test
reports, ERT database, Excel spreadsheets, and associated information,
etc.,) in one of the ways listed below.  Please refer to Enclosure 4 to
aid you in determining what information can be claimed confidential.  In
order to avoid duplicate data and keep all data for a particular
facility together, we request that you submit all of the data requested
from your facility in the same way, if possible.  To submit your data,
you may choose any ONE of the procedures below:

(1)  Upload an electronic copy of all requested files to a website that
has been created specifically for this EAF test request:    HYPERLINK
"http://icr2010.rti.org"  http://icr2010.rti.org .  See below in Section
3.3 for the procedures to access this site as well as for setting up a
password unique to your company.

OR

(2) Mail a CD, or DVD containing an electronic copy of all requested
files to either of the two EPA addresses below (hard copies are
permitted if that’s the only possibility; otherwise, electronic is
preferred):

Please use the address below for U.S. mail:

Dr. Donna Lee Jones (Mail Code D243-02)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Research Triangle Park, NC  27711

Please use the street address below for commercial package carriers,
such as FedEx and UPS:

			

			Dr. Donna Lee Jones (Mail Code D243-02)

109 T.W. Alexander Drive

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Durham, NC 27709

3.2  Confidential Data

If the process data or other information you are providing is considered
confidential, please create a separate CD or DVD containing only the
confidential portion of your data or prepare a copy of the hard copy
materials containing only the pages that include the information you
consider confidential.  Clearly mark the disk and/or materials with the
words “Confidential Business Information.”  Please refer to
Enclosure 4 to aid you in determining what information can be claimed
confidential.  Send the confidential files under separate cover to the
attention of Dr. Donna Lee Jones at either of the two addresses below.

Please use the following address for U.S. mail:

Roberto Morales (C404-02)

c/o Donna Lee Jones (ESD Project 91-60)

U.S. EPA Mailroom (C404-02)

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711

Please use the street address below for commercial package carriers,
such as FedEx and UPS:

Roberto Morales (C404-02) 

c/o Donna Lee Jones (ESD Project 91-60)

109 T.W. Alexander Drive

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards 

Durham, NC 27709

For the security of your data, EPA recommends sending your confidential
files to Mr.  Morales via registered U.S. mail using return receipt
requested, Federal Express, or other method for which someone must
provide a signature upon receipt.  Do not electronically transmit
confidential business information (CBI) to EPA.  E-mail and facsimile
are not secure forms of communication and should never be used to
transmit CBI.

3.3  Directions for Uploading Your Data to the EAF Test Request Website 

Open the Web site

Open the Electric Arc Furnace EPA Test Request 2010 Web site, located at
the following address:

   HYPERLINK "http://icr2010.rti.org"  http://icr2010.rti.org . 

Click on the “Industries” menu item within the menu bar at the left
of the screen, and then click on the “Electric Arc Furnace (EAF)”
menu item.

To register a User Name

Click on the “Register” menu item at the top of the screen.

Register your User Name filling in all the required fields.

To submit your account information, click on “Register” at the
bottom of the screen.

You will immediately receive an email notification confirming you have
registered.  You will receive a second email confirming that you have
been added as a Registered User to the website within 24 hours.

To Log in

Click on the “Login” menu item at the top of the screen. 

Type in your User Name and Password.

Click on the gray “Login” button.

To Upload Files:  completed ERT Database, Excel Spreadsheets, electronic
survey responses, and electronic test reports.

Click on the "Upload Files" menu item.

Enter a description for the upload (please include facility name(s) and
type of document i.e., ERT Database, Excel Spreadsheet, Survey Response,
Test Report).

Browse to the file that you wish to upload. 

After selecting the file, click on the “Upload” link.  Uploading may
take a few seconds or minutes depending on the size of the file you are
attempting to upload, and your internet connection speed.  

To View Uploaded Files

Click on the “View Uploaded Files” menu item.

Next to each file will be links to “Download” and “Delete” the
file.

If you would like to check the file that is currently uploaded, click on
the “Download” link to download a copy of it.

You can click on the “Delete” link if you wish to remove the file in
order to upload a new version.

You have complete ownership of the files you upload; only you have the
access to view and delete the files.  You will not be able to view or
delete files uploaded by another company.

4.0  Contact Information for Questions on Test Plan and Reporting 

For questions on how to report data using the ERT Access database,
contact:

Ron Myers (U.S. EPA)

(919) 541-5407

  HYPERLINK "mailto:Myers.Ron@epa.gov"  Myers.Ron@epa.gov 

Barrett Parker (U.S. EPA)

(919) 541-5635

  HYPERLINK "mailto:Parker.Barrett@epa.gov"  Parker.Barrett@epa.gov 

For questions on the test methods contact: 

Jason DeWees (U.S. EPA) 

919-541-9724 

  HYPERLINK "mailto:Dewees.Jason@epa.gov"  Dewees.Jason@epa.gov 

Gary McAlister (U.S. EPA) 

919-541-1062 

  HYPERLINK "mailto:McAlister.Gary@epa.gov"  McAlister.Gary@epa.gov 

Peter Westlin (U.S. EPA) 

919-541-1058 

  HYPERLINK "mailto:Westlin.Peter@epa.gov"  Westlin.Peter@epa.gov 

Bill Grimley (U.S. EPA)

919-541-1065

  HYPERLINK "mailto:Grimley.William@epa.gov"  Grimley.William@epa.gov 

For questions on reporting mechanisms other than the ERT Access
database, contact:

Donna Lee Jones (U.S. EPA)

  HYPERLINK "mailto:Jones.DonnaLee@epa.gov"  Jones.DonnaLee@epa.gov 

Appendix A

Abbreviations and Acronyms

acf			actual cubic feet

		acfm			actual cubic feet per minute

		acm			actual cubic meters

		acmm			actual cubic meters per minute

		CAA			Clean Air Act

		CBI			confidential business information

		day/yr			days per year

		°C			degrees Celsius 

		°F			degrees Fahrenheit

		dscf			dry standard cubic feet

		dscfm			dry standard cubic feet per minute

		dscm			dry standard cubic meters

		dscmm			dry standard cubic meters per minute

		EAF			electric arc furnace

		EPA			U.S. Environmental Protection Agency					ft			foot or feet	

ft2			square feet		

ft3			cubic feet

fpm			feet per minute (acfm divided by ft2 of filter area)

fps			feet per second

gal			gallon

gpm			U.S. gallons per minute

gr			grain

		gr/dscf			grains per dry standard cubic foot

g			gram

		HAP			hazardous air pollutants

		hr			hour or hours

		hr/day			hours per day

		in			inch or inches

		in H2O			inches of water (pressure drop)

		kg			kilogram

		kPa			kilopascals

kv			kilovolt

kw-hr			kilowatt hour

lb			pound

		lb/day			pounds per day

		lb/gas			pounds per U.S. gallon

lb/hr			pounds per hour

lb/ton			pounds per ton

m			meter

MACT			maximum achievable control technology

m3			cubic meters

min			minute or minutes

Mg			megagram

mg			milligram

mg/l			milligrams per liter	

MM scf		millions of standard cubic feet

MMlb/yr		million pounds per year

NAICS		North American Industry Classification System

NESHAP		National Emission Standards for Hazardous Air Pollutants

OAQPS		Office of Air Quality Planning and Standards

OTM			Other Test Method

PM			particulate matter

ppmv			parts per million by volume

ppmw			parts per million by weight

		%			percent

s			second or seconds

SPPD			Sector Policies and Programs Division

scf			standard cubic feet

scfm			standard cubic feet per minute

scm			standard cubic meters

scmm			standard cubic meters per minute

		tpd			tons (short) per day

		tpy			tons (short) per year 

		vol%			volume percent, or percent by volume

		wt% 			weight percent, or percent by weight

yr			year

Unit Conversions

To convert from	To	Multiply by

°C	°F	multiply by 1.8, then add 32

°F	°C	subtract 32, then multiply by 0.556

ft	m	0.0348

ft/min	m/min	0.0348

ft2	m2	0.0929

ft3	m3	0.028

g	lb	0.0022

g/m3	lb/ft3	0.0000624 

gr	lb	0.000143

gr/dscf	mg/dscm	2,290

in water	mm water	25.4

kg/hr	lb/hr	2.205 

lb	g	454

lb	gr	7000

lb/ft3	g/m3	16,000

lb/hr	kg/hr	0.454  

m	ft	3.28

m/min	ft/min	3.28

mm water	in water	0.0394

m2	ft2	10.76

mg/dscm	gr/dscf	0.00044

m3	ft3	35.31 

Mg	ton	1.1 

ton (short)	Mg	0.907 



Appendix B

List of Hazardous Air Pollutants (HAP)

CAS Number	Chemical Name

	Antimony Compounds 

	Arsenic Compounds (inorganic including arsine) 

	Beryllium Compounds 

	Cadmium Compounds 

	Chromium Compounds 

	Cobalt Compounds 

	Coke Oven Emissions 

	Cyanide Compounds1 

	Glycol ethers2

	Lead Compounds

	Manganese Compounds 

	Mercury Compounds 

	Fine mineral fibers3 

	Nickel Compounds 

	Polycylic Organic Matter4 

	Radionuclides (including radon)5

	Selenium Compounds

75070	Acetaldehyde

60355	Acetamide

75058	Acetonitrile

98862	Acetophenone

53963	2-Acetylaminofluorene

107028	Acrolein

79061	Acrylamide

79107	Acrylic acid

107131	Acrylonitrile

107051	Allyl chloride

92671	4-Aminobiphenyl

62533	Aniline

90040	o-Anisidine

1332214	Asbestos

71432	Benzene (including benzene from gasoline)

92875	Benzidine

98077	Benzotrichloride

100447	Benzyl chloride

92524	Biphenyl

117817	Bis(2-ethylhexyl)phthalate (DEHP)

542881	Bis(chloromethyl)ether

75252	Bromoform

106990	1,3-Butadiene

156627	Calcium cyanamide

133062	Captan

63252	Carbaryl

75150	Carbon disulfide

56235	Carbon tetrachloride

463581	Carbonyl sulfide

120809	Catechol

133904	Chloramben

57749	Chlordane

7782505	Chlorine

79118	Chloroacetic acid

532274 	2-Chloroacetophenone

108907 	Chlorobenzene

510156	Chlorobenzilate

67663	Chloroform

107302	Chloromethyl methyl ether

126998	Chloroprene

1319773	Cresols/Cresylic acid (isomers and mixture)

95487	o-Cresol

108394	m-Cresol

106445	p-Cresol

98828	Cumene

94757	2,4-D, salts and esters

3547044	DDE

334883	Diazomethane

132649	Dibenzofurans

96128	1,2-Dibromo-3-chloropropane

84742	Dibutylphthalate

106467	1,4-Dichlorobenzene(p)

91941	3,3-Dichlorobenzidene

111444	Dichloroethyl ether (Bis(2-chloroethyl)ether)

542756	1,3-Dichloropropene

62737	Dichlorvos

111422	Diethanolamine

121697	N,N-Diethyl aniline (N,N-Dimethylaniline)

64675	Diethyl sulfate

119904	3,3-Dimethoxybenzidine

60117	Dimethyl aminoazobenzene

119937	3,3'-Dimethyl benzidine

79447	Dimethyl carbamoyl chloride

68122	Dimethyl formamide

57147	1,1-Dimethyl hydrazine

131113	Dimethyl phthalate

77781	Dimethyl sulfate

534521	4,6-Dinitro-o-cresol, and salts

51285	2,4-Dinitrophenol

121142	2,4-Dinitrotoluene

123911	1,4-Dioxane (1,4-Diethyleneoxide)

122667	1,2-Diphenylhydrazine

106898	Epichlorohydrin (l-Chloro-2,3-epoxypropane)

106887	1,2-Epoxybutane

140885	Ethyl acrylate

100414	Ethyl benzene

51796	Ethyl carbamate (Urethane)

75003	Ethyl chloride (Chloroethane)

106934	Ethylene dibromide (Dibromoethane)

107062	Ethylene dichloride (1,2-Dichloroethane)

107211	Ethylene glycol

151564	Ethylene imine (Aziridine)

75218	Ethylene oxide 

96457	Ethylene thiourea

75343	Ethylidene dichloride (1,1-Dichloroethane)

50000 	Formaldehyde

76448	Heptachlor

118741 	Hexachlorobenzene

87683 	Hexachlorobutadiene

77474	Hexachlorocyclopentadiene

67721	Hexachloroethane

822060	Hexamethylene-1,6-diisocyanate

680319	Hexamethylphosphoramide

110543	Hexane

302012	Hydrazine

7647010	Hydrochloric acid

7664393	Hydrogen fluoride (Hydrofluoric acid)

123319	Hydroquinone

78591	Isophorone

58899	Lindane (all isomers)

108316	Maleic anhydride

67561 	Methanol

72435	Methoxychlor

74839	Methyl bromide (Bromomethane)

74873	Methyl chloride (Chloromethane)

71556 	Methyl chloroform (1,1,1-Trichloroethane)

60344 	Methyl hydrazine

74884	Methyl iodide (Iodomethane)

108101	Methyl isobutyl ketone (Hexone)

624839	Methyl isocyanate

80626	Methyl methacrylate

1634044	Methyl tert butyl ether

101144 	4,4-Methylene bis(2-chloroaniline)

75092	Methylene chloride (Dichloromethane)

101688	Methylene diphenyl diisocyanate (MDI)

101779	4,4'¬-Methylenedianiline

91203	Naphthalene

98953	Nitrobenzene

92933	4-Nitrobiphenyl

100027 	4-Nitrophenol

79469 	2-Nitropropane

684935	N-Nitroso-N-methylurea

62759	N-Nitrosodimethylamine

59892 	N-Nitrosomorpholine

56382	Parathion

82688	Pentachloronitrobenzene (Quintobenzene)

87865	Pentachlorophenol

108952	Phenol

106503	p-Phenylenediamine

75445	Phosgene

7803512	Phosphine

7723140	Phosphorus

85449	Phthalic anhydride 

1336363	Polychlorinated biphenyls (Aroclors) 

1120714 	1,3-Propane sultone 

57578	beta-Propiolactone 

123386	Propionaldehyde 

114261	Propoxur (Baygon) 

78875	Propylene dichloride (1,2-Dichloropropane) 

75569	Propylene oxide 

75558	1,2-Propylenimine (2-Methyl aziridine) 

91225	Quinoline 

106514	Quinone 

100425	Styrene 

96093	Styrene oxide 

1746016	2,3,7,8-Tetrachlorodibenzo-p-dioxin 

79345	1,1,2,2-Tetrachloroethane 

127184	Tetrachloroethylene (Perchloroethylene) 

7550450	Titanium tetrachloride 

108883	Toluene 

95807	2,4-Toluene diamine 

584849	2,4-Toluene diisocyanate 

95534	o-Toluidine 

8001352	Toxaphene (chlorinated camphene) 

120821	1,2,4-Trichlorobenzene 

79005	1,1,2-Trichloroethane 

79016	Trichloroethylene 

95954	2,4,5-Trichlorophenol 

88062	2,4,6-Trichlorophenol 

121448	Triethylamine 

1582098	Trifluralin 

540841	2,2,4-Trimethylpentane 

108054	Vinyl acetate 

593602	Vinyl bromide 

75014	Vinyl chloride 

75354	Vinylidene chloride (1,1-Dichloroethylene) 

1330207	Xylenes (isomers and mixture) 

95476 	o-Xylenes

108383	m-Xylenes

106423	p-Xylenes

NOTE: For all listings above which contain the word "compounds" and for
glycol ethers, the following applies: Unless otherwise specified, these
listings are defined as including any unique chemical substance that
contains the named chemical (i.e., antimony, arsenic, etc.) as part of
that chemical's infrastructure.

1:  X'CN where X = H' or any other group where a formal dissociation may
occur. For example KCN or Ca(CN)2

2:  Includes mono- and di- ethers of ethylene glycol, diethylene glycol,
and triethylene glycol R-(OCH2CH2)n -OR' where

n = 1, 2, or 3

R = alkyl or aryl groups

R' = R, H, or groups which, when removed, yield glycol ethers with the
structure: R-(OCH2CH)n-OH. Polymers are excluded from the glycol
category.  Also excludes ethylene glycol monobutyl ether (EGBE)
(2-Butoxyethanol) (Chemical Abstract Service (CAS) No. 111-76-2)  and
surfactant alcohol ethoxylates and their derivatives (SAED).

 3:  Includes mineral fiber emissions from facilities manufacturing or
processing glass, rock, or slag fibers (or other mineral derived fibers)
of average diameter 1 micrometer or less.

4:  Includes organic compounds with more than one benzene ring, and
which have a boiling point greater than or equal to 100º C. 

5:  A type of atom which spontaneously undergoes radioactive decay. 

Appendix C

Documentation of Rationale for Reduced Mercury Testing for Similar EAFs

Please fill out the following table and include a description of the
required parameters used to establish the similarity between your EAFs. 
All parameters noted with * are required to be the same for EAFs to be
considered “similar” with respect to mercury emissions potential.

Parameter	EAF Being Tested	Similar EAF	Similar EAF	Similar EAF

EAF ID No.





Latitude and longitude of stack(s) decimal degrees, 6 decimal places





*Type and proportion of scrap charged (please list scrap grades and
percent or tons of each)





*Scrap supplier(s)





*Materials charged other than scrap (please list each material)





*Type of steel produced







Amount of steel produced (tpy)







   See Appendix A for an explanation of acronyms used.

  Please complete this form for every facility in your company subject
to this request for information, as described in the cover letter from
EPA.  If possible, we would prefer receiving the completed forms in the
electronic file in MS Word included with this package.

 “Guidelines for Ferrous Scrap:  FS-2009.”  Prepared by the
Institute of Scrap Recycling Industries (ISRI).    HYPERLINK
"http://www.isri.org/iMIS15_PROD/ISRI/Resources/Scrap_Specifications_Cir
cular/isri.org/Resources/Scrap_Specifications_Circular.aspx?hkey=a5ab8ca
b-3c69-464f-816f-cf2a92e3e1e9" 
http://www.isri.org/iMIS15_PROD/ISRI/Resources/Scrap_Specifications_Circ
ular/isri.org/Resources/Scrap_Specifications_Circular.aspx?hkey=a5ab8cab
-3c69-464f-816f-cf2a92e3e1e9 .  

 PAGE   1 

  PAGE   \* MERGEFORMAT  1 

Appendix A

Appendix B

Appendix C

