                          Technical Support Document
       NOx and VOC RACT Source Specific SIP Revision State of New Jersey
                                      for
                             CMC Steel New Jersey
                          (Commercial Metals Company)
                             Sayreville, New Jersey
                                       
                         Docket: EPA-R02-OAR-2019-0720

                                       
 INTRODUCTION
   
   This technical support document (TSD) outlines the state of New Jersey Department of Environmental Protection's (the State) State Implementation Plan (SIP) revision to the ozone SIP. Specifically, the State seeking EPA's approval on facility-specific volatile organic compounds (VOC) control plan and facility-specific Nitrogen oxides (NOx) control plan for the electric arc furnace (Sayreville EAF) at the CMC Steel New Jersey located at 1 N. Crossmen Road, Sayreville, New Jersey, Middlesex county. The facility operates a mini-mill that consist of melting reclaimed scrap metal using an electric arc furnace and is then cast into billets and reinforcing bars. This SIP revision would establish facility-specific VOC emission rate of 57 pounds per hour (lb/hr) and facility-specific maximum allowable NOx emission rate of 31 lb/hr for the electric arc furnace and does not change allowable emissions. The electric arc furnace will not increase hourly VOC and NOx emissions, therefore, the National Ambient Air Quality Standard (NAAQS) for ground level ozone is protected.
      On December 5, 2018, the State approved an administrative amendment reflecting new ownership and name change from Gerdau Ameristeel to CMC Steel New Jersey. All control options for the Sayreville EAF and associated Clean Air Act (CAA) permit limits remain the same under the new ownership as were under the former owner Gerdau Ameristeel. 

II.	CLEAN AIR ACT REQUIREMENTS FOR NOx OZONE AND RACT
      
A.	Federal Ozone Requirements  

Ground level ozone is created by chemical reactions between NOx and VOCs when pollutants emitted by sources chemically react in the presence of sunlight. Nonattainment for ground level ozone is defined as an area that is not meeting (or that contributes to ambient air quality in a nearby area that does not meet) the primary or secondary NAAQS for ozone. Nonattainment areas are classified as either marginal, moderate, serious, severe, or extreme based on the degree to which the ozone level in the area exceeds the NAAQS.  
      On March 6, 2015, the EPA established a final rule for implementing the 2008 ozone NAAQS. This final rule repeals the 1997 ozone NAAQS and adds anti-backsliding requirements to help smooth the transition between the 1997 and the 2008 ozone standards for nonattainment areas. The March 6, 2015 rule addresses a range of nonattainment area SIP requirements for the 2008 ozone NAAQS. See 80 FR 12264 (March 6, 2015).
      To summarize the federal ozone rules, in 1997 the EPA revised the health-based NAAQS for 8-hour ozone, setting it at 0.084 parts per million (ppm) averaged over an 8-hour time frame. See 62 FR 38856 (July 18, 1997). The EPA revised the 8-hour ozone standard twice since 1997; in March 2008, the EPA revised the standard to 0.075 ppm, and in October 2015 the EPA revised it to 0.070 ppm while retaining the 2008 ozone indicators. See 73 FR 16436 (March 27, 2008); 80 FR 65292 (October 26, 2015). After the EPA establishes a new or revised NAAQS, the CAA directs the EPA and the states to take steps to ensure that the new or revised NAAQS are met. One of the first steps, known as the initial area designations, involves identifying areas of the country that are not meeting the new or revised NAAQS, as well as the nearby areas that contain emissions sources that contribute emissions to the areas not meeting the NAAQS. The EPA finalized its attainment/nonattainment designations on June 4, 2018 for most areas across the country with respect to the 2015 ozone standard. See 83 FR 25776 (June 4, 2018). This action became effective on August 3, 2018. 
  

B.	Federal Ozone Design Values and Standards

A design value is a statistic that describes the air quality status of a given location relative to the level of the NAAQS. In 1997, the EPA revised the health-based NAAQS for 8-hour ozone, setting it at 0.084 parts per million (ppm) averaged over an 8-hour time frame. This rule became effective on September 16, 1997.  See 62 FR 38856. This rulemaking was based on scientific evidence demonstrating that ozone causes adverse health effects at lower ozone concentrations and over longer periods of time than was understood when the 1-hour ozone standard was set in 1979.   

      On April 30, 2004, the EPA finalized attainment/nonattainment designations for areas across the country with respect to the 1997 8-hour ozone standard and set design values based on fourth-highest daily maximum, averaged across three consecutive years. This rule became effective on June 15, 2004. See 69 FR 23951. 

      On November 29, 2005, the EPA finalized rules regarding emissions control and planning obligations applicable to areas designated nonattainment for 1997 8-hour ozone, including RACT measures and attainment demonstrations among other elements. This rule became effective on January 30, 2006. See 70 FR 71612.

      The EPA has revised the 8-hour ozone standard twice since 1997. First, on March 27, 2008, the standard was revised to 0.075 ppm. This rule became effective on May 27, 2008. See 73 FR 16436. On May 21, 2012, the EPA finalized the air quality thresholds that define the classifications assigned to all nonattainment areas for the 2008 ozone NAAQS. This rule became effective on July 20, 2012. See 77 FR 30088.

      Then, the EPA revised the 8-hour ozone standard again on October 26, 2015, down to 0.070 ppm, but retained the 2008 ozone indicators, design value (i.e., fourth-highest daily maximum, averaged across three consecutive years) and averaging times (eight hours). This rule became effective December 28, 2015. See 80 FR 65292. On March 9, 2018, the EPA finalized the air quality thresholds that define the classifications assigned to all nonattainment areas for the 2015 ozone NAAQS. This rule became effective on May 8, 2018.  See 83 FR 10376.  
      
      
C. 	New Jersey Ozone Designations  
      
      As explained above, nonattainment areas are classified as either marginal, moderate, serious, severe, or extreme based on the degree to which the ozone level in the area exceeds the NAAQS. The State of New Jersey has two ozone nonattainment areas, which are the Philadelphia-Wilmington-Atlantic City (PA-NJ-MD-DE), classified as marginal, and the New York-Northern New Jersey-Long Island (NY-NJ-CT), reclassified as serious, also referred to as the New York Metropolitan Area (NYMA). The New Jersey portion of the NYMA is made up of  -  -  - 12 counties (Bergen, Essex, Hudson, Hunterdon, Middlesex, Monmouth, Morris, Passaic, Somerset, Sussex, Union and Warren counties).  
      
      On May 4, 2016 the EPA ruled that the NYMA did not attain their marginal 2008 ozone NAAQS by the applicable marginal attainment date July 20, 2015 and therefore the area was reclassified from marginal to moderate nonattainment. See 81 FR 26697 (May 4, 2016). As an area that is reclassified to a higher classification, the NYMA must demonstrate attainment by the applicable attainment date of July 20, 2018, however, the NYMA again failed to meet the attainment date. Consequently, on August 23, 2019 the EPA reclassified the area to serious for 2008 ozone NAAQS. CAA sections 172(c)(1), 182(b)(2) and 182(f) require nonattainment areas that are designated as "moderate" or above to adopt reasonably available control technology.
      

D.	Federal RACT Requirements, OTR, and the NOx Supplement   
Reasonably available control technology (RACT) is defined as the lowest emission limit that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility. Under EPA guidance, States should consider in their RACT determinations technologies that achieve 30 - 50 percent reduction within a cost range of $160 - 1300 per ton of NOx removed. See 70 FR 71612 (November 29, 2005). 
      The CAA section 182, Plan Submissions and Requirements, requires states with nonattainment areas to include in their SIPs, among other things, provisions to require the implementation of RACT. Section 182(f) does not fully define NOx requirements for marginal and moderate nonattainment, but it does address NOx requirements for serious, severe and extreme nonattainment (i.e., 182(c), (d), and (e) respectively). In addition, section 182(f) outlines requirements that do not apply to sources located in Ozone Transport Region (OTR),but does not address situations that not that apply to OTR. To clarify, the CAA NOx Supplement was developed that clarifies requirements for NOx.  The NOx Supplement explains that the CAA section 182(f), read in conjunction with section 182(a)(2)(C) and other New Source Review (NSR) related provisions in section 182, require state new source review (NSR) plans to apply to major stationary sources of NOx, the same requirements that govern major stationary sources of VOC emissions in ozone nonattainment areas and in other areas located in OTR. Section182(a)(2)(C) requires states to adopt and submit revised NSR regulations for all ozone nonattainment areas classified as marginal or above. 
      In addition, the CAA section 184(a), Control of Interstate Ozone Air Pollution, Ozone Transport Regions, addresses requirements for nonattainment areas located in the OTR, and the CAA section 176A, Interstate Transport Commissions, set forth the formation and responsibilities for the Ozone Transport Commission, that among other things, the Commission establishes control measures for RACT NOx for major sources located in the OTR.

E. 	New Jersey RACT Requirements
All the State of New Jersey is subject to RACT due to nonattainment area designations for the 8-hour ozone standard at 40 CFR 81.331. In addition, the entire state of New Jersey is located within the OTR, which triggers the RACT NOx requirements. The State developed an ozone SIP to attain the NAAQS standards and considers source-specific SIP revisions as necessary. A source-specific SIP revision is submitted by a facility to request approval for source-specific emission limitations, through a RACT analysis, and if approved by the State and the EPA, are incorporated into the State's ozone SIP. Furthermore, the state of New Jersey is located in the OTR.  
      On August 1, 2007, the State finalized RACT revisions to its SIP to address the 8-hour ozone NAAQS (2007 NJ RACT plan) and focuses on control measures that reduce NOx and VOC emissions. On May 15, 2009 the EPA approved the 2007 NJ RACT plan. See 74 FR22837. 
      
      The State of New Jersey choose to use more stringent RACT requirements. Most counties in New Jersey were previously classified under the 1979 1-hour ozone standard as severe nonattainment (i.e., major source defined as 25 TPY NOx), and the remaining counties were subject to RACT as part of the OTR. In comparison, under the 1997 8-hour standard most of New Jersey was classified as moderate (i.e., major source defined as 100 TPY NOx). Leading up to 2007, the State worked collaboratively with stakeholders to conduct a RACT analysis of statewide NOx source operations and pieces of equipment that have the potential to emit 25 TPY because the State was interested in finding methods to go beyond the 1997 federal requirements. The result was that the State choose to implement more stringent RACT requirements based on the 1979 1-hour severe nonattainment. The use of 25 TPY for RACT is also consistent with the anti-backsliding provisions of the CAA. 
   
      The more stringent RACT requirements are outlined in the 2007 NJ RACT plan, at pages 18-21, as the following:
 past New Jersey costs for retrofitting a given control;
 average RACT cost (dollars per tons reduced) for a control technology and maximum RACT cost. The idea is that once a reasonable number of sources in a source category achieve a lower emission level, other sources should do the same;
 the seriousness of the Region's ozone air quality exceedance. For nonattainment areas with higher ozone levels higher cost for controls are reasonable;
 the seriousness of the need to reduce transported air pollution. As an OTR state, higher costs for RACT are justified; and
 the State plan for addressing economic feasibility in RACT rules. The State intends to specify RACT at the lowest emission limit that a reasonable number of similar industries had already successfully implemented for each source category

      The State of New Jersey was to codify in a rule by defining what is considered a major source of NOx, thus requiring use of RACT. On September 2, 2010 the EPA approved the New Jersey Department of Environmental Protection revised SIP to incorporate several amendments to the New Jersey Administrative Code Title 7, Chapter 27, one of which is Subchapter 19, "Control and Prohibition of Air Pollution from Oxides of Nitrogen" (N.J.A.C. 7:27-19). See FR 45483. As such, Subchapter 19.2 defines 14 sources as being major. Essentially 13 of the major sources derive from the stakeholder RACT study for sources with potential to emit 25 TPY NOx and thus have strictly defined maximum allowable emission rates. The fourteenth category is reserved for all other source operations or pieces of equipment that exceed 10 TPY NOx, such as the electric arc furnace subject to this current SIP revision. 


III.	EPA'S ANALYSIS OF STATE SUBMITTAL  

CMC Steel New Jersey, 1 N Crossman Road, Sayreville, Middlesex County, NJ 08872, Program Interest Number 18052, Activity Number BOP 150002 

CMC Steel New Jersey submitted this source-specific SIP revision requesting that they continue to operate under their current approved emission limits for the Sayreville EAF. Specifically, the VOC emission rate of 57 lb/hr and the NOx emission rate of 31 lb/hr. The facility met the statutory deadline to qualify for continuing to operate under existing limits, as outlined below:
 On April 20, 2009, the State revised regulations at 7:27-16.17(c) stating that if a VOC RACT plan was originally approved prior to May 19, 2009 and if a facility wishes to continue to operate under the original plan, the facility must submit a revised proposed plan by August 17, 2009. The original VOC RACT plan addressing the Sayreville EAF was approved October 1994. Therefore, on August 17, 2009, in accordance with N.J.A.C. 7:27-16.17(c)(3), Gerdau Ameristeel submitted a revised VOC RACT plan with VOC emission rate of 57 lb/hr. CMC Steel New Jersey assumes VOC RACT plan as new owner as of December 5, 2018.  
 On April 20, 2009, the State revised regulations at N.J.A.C. 7:27-19.13(b) stating that if a NOx RACT plan was originally approved prior to May 1, 2005 and if a facility wishes to continue to operate under the original plan, the facility must submit a revised proposed plan by August 17, 2009. The original facility-specific NOx RACT plan for the Sayreville EAF dates to May 31, 1995 and the facility wishes to continue to operate facility-specific maximum allowable NOx emission rate of 31 lb/hr. CMC Steel New Jersey assumes NOx RACT plan as new owner as of December 5, 2018. 
 In an email correspondence to Gerdau Ameristeel on September 7, 2018, the State requested an updated VOC RACT plan and NOx RACT plan to determine if other electric arc furnace control strategies have emerged since 2009. 
 Gerdau Ameristeel sold the facility to CMC Steel New Jersey on December 5, 2018. The EPA verified that all control options for the Sayreville EAF and associated CAA permit limits remain the same under the new ownership as were under the former owner Gerdau Ameristeel. 
 The State reviewed CMC Steel New Jersey's submitted VOC RACT plan and NOx RACT plan and in a letter dated April 30, 2019 from Catherine R. McCabe, New Jersey Department of Environmental Protection (NJDEP) Commissioner, to Peter D. Lopez, Regional Administrator U.S. EPA Region 2, the State requests EPA's approval of a revision to the New Jersey SIP for ozone. The SIP revision was submitted to EPA to evaluate the request to continue to use the control options as outlined in N.J.A.C.7:27-16.17 Proposed Facility-Specific VOC Control Plan for Electric Arc Furnace updated October 31, 2018 and N.J.A.C.7:27-19.13 Proposed Facility-Specific NOx Control Plan for Electric Arc Furnace updated October 31, 2018. 
      
      This is SIP revision establishes facility-specific VOC emission rate of 57 lb/hr and facility-specific maximum allowable NOx emission rate of 31 lb/hr and, therefore, does not change allowable emissions from the affected source. The permit levels of the Sayreville EAF are maximum potential to emit 78.7 TPY of VOC and maximum potential to emit of 78.8 TPY of NOx emissions. Based on the most recent emissions inventory, the other VOC and NOx emissions for the Melt Shop include scrap pre-heater, three ladle preheaters, a tundish preheater, and billet cutting torches, however, each of these sources contributes substantially less than 3 pounds per hour of VOC emissions and less than one ton per year of NOx to the overall NOx emissions from the Melt Shop. Therefore, only the Sayreville EAF source operation is subject to the VOC RACT rule and the NOx RACT rule as per N.J.A.C. 7:27-16.17(a) and N.J.A.C. 7:27-19.2(b)12 respectively. 

EPA's Evaluation

The EPA reviewed CMC Steel New Jersey application and the source specific SIP revision for completeness and approvability. The following was considered in evaluating comparable electric arc furnace control technologies: reviewed control options on other electric arc furnaces from similar facilities that operate EAF as CMC Steel New Jersey is the only facility in New Jersey to operate an EAF; consulted with NJDEP and the EPA experienced air inspectors; and reviewed the EPA technical guidance. 

Similar operation: 
      The Delaware Division of Air Quality confirms that a typical fuel fired combustion equipment applied to NOx emitting sources are not technically feasible for an electric arc furnace. Specifically, in 2001 the state certified that no additional requirements on the Citisteel's electric arc furnace operations are required under RACT. (CitiSteel: 66 FR 32231 (6/14/2001)  -  "Approval and Promulgation of Air Quality Implementation Plans; Delaware; Conversion of the Conditional Approval of the NOX": Direct final rule approving 3 source specific NOx RACT determinations https://www.federalregister.gov/documents/2001/06/14/01-14898/approval-and-promulgation-of-air-quality-implementation-plans-delaware-conversion-of-the-conditional). Delaware submitted the case-by-case RACT Determinations for CitiSteel that can be found in the June 2000 edition of the Delaware Register of Regulations at http://leghall.delaware.gov/LIS/Register.nsf/vwRegisters/312/$file/June2000.pdf?openelement (pg 1755 of the document). This document includes information about the process description, NOx emissions, and the RACT Analysis for CitiSteel.
      The EPA's Technology Transfer Network identifies two facilities in Ohio with similar operations to the Sayreville EAF, Dearborn Industrial Generation and Norths Star Blue Scope Steel, that use natural gas fuel, have melt shops and similar emission rates and do not have thermal incineration as a control device for VOC. They have other emission control technologies suitable for their operations, such as, DES, bag house, post combustion chamber, among others.   

New Jersey experienced air inspector: 
      The New Jersey Department of Environmental Protection air inspector has been conducting inspections at the Sayreville EAF since 2001 and confirms that Sayreville EAF is the only electric arc furnace in New Jersey. Inspection records for the last 5 years demonstrate no violations for VOC or NOx in the Sayreville EAF stack testing. The most recent full compliance evaluation and stack tests for VOC and NOx was conducted by the State in August 2019 and there were no issues with VOC or NOx. The Sayreville EAF has a continuous emission monitor for VOC, NOx, Oxygen, and Carbon Monoxide and the 3-hour rolling average sometimes creates a blip for VOC and NOx, but the inspector is not concerned. The noncompliance at the Sayreville facility over the years (i.e. over 2 million in penalties) is due to the electric arc furnace opacity and mercury and not for VOC or NOx. The State is working with the facility to improve mercury and opacity issues and they recently implemented a dust management plan. The State rule has a very low standard for opacity and the continuous opacity monitor has a 2% tolerance and this results in quarterly noncompliance for opacity. The facility is considering replacing the continuous opacity monitor with broken bag detectors, however, switching control equipment will require State approval. The State rule for electric arc furnace addresses mercury in pounds/year and milligrams/ton/steel produced and it is the latter that the Sayreville EAF does not meet.
      
The EPA experienced air inspector: 
      The EPA Region 2 Air Compliance Branch confirms with the State air inspector findings that the facility has been having issues complying with their opacity limit of 3% for the electric arc furnace, however, the complying issues do not apply to VOC or NOx.  

Reviewed the EPA technical guidance: 
 RACT/BACT/LEAR Clearinghouse, https://cfpub.epa.gov/rblc/index.cfm?action=Home.Home&lang=en, demonstrates that no electric arc furnace in the U.S. has a thermal incinerator for a VOC control device
 The EPA Air Pollution Control Cost Manual, Chapter 2 Incinerators and Oxidizers, Section 2.5.1.1. Equipment Cost (updates as of August 2018), https://www.epa.gov/economic-and-cost-analysis-air-pollution-regulations/cost-reports-and-guidance-air-pollution
 Alternative Control Techniques Document  -  NOx Emissions from Iron and Steel Mills (EPA-453/R-94-065), https://www.epa.gov/ground-level-ozone-pollution/control-techniques-guidelines-and-alternative-control-techniques
 AP-42 Iron and Steel Mills, https://www3.epa.gov/ttnchie1/ap42/ch12/final/c12s0501.pdf
 Handbook Control Techniques for Hazardous Air Pollutants (EPA 625/6-91/014), https://cfpub.epa.gov/si/si_public_record_report.cfm?Lab=NRMRL&dirEntryId=124752
 Air Pollution Control Technology Factsheet - Thermal incinerator (EPA-452/F-03-022), https://www3.epa.gov/ttncatc1/cica/files/fthermal.pdf
 Air Pollution Control Technology Factsheet  -  Catalytic incineration (EPA-452/F-03-018), https://www3.epa.gov/ttncatc1/cica/files/fcataly.pdf
 Air Pollution Control Technology Factsheet  -  Flares (EPA-452/F-03-019), https://www3.epa.gov/ttn/catc/dir1/fflare.pdf
 Technology Transfer Network - Choosing Adsorption System for VOC (EPA-456/F-99-004), https://www3.epa.gov/ttn/catc/cica/other6_e.html 
 EPA Air Pollution Control Cost Manual, sixth edition (EPA-452/B-02-001),  https://nepis.epa.gov/Exe/ZyPDF.cgi/910118CI.PDF?Dockey=910118CI.PDF
 EPA Technical Bulletin Refrigerated Condensers for Control of Organic Air Emissions (Clean Air Technology Center (EPA-456/R-01-004), https://www3.epa.gov/ttn/catc/dir1/refrigeratedcondensers.pdf


EPA's Evaluation of Facility RACT analysis
In considering RACT for a source it is important to understand how the source fits into the overall facility process. The Sayreville EAF receives scrap metal and is positioned in the Melt Shop. The incoming scrap metal is subject to a Scrap Management Plan that minimizes oil, grease, and plastic and other elements that would result in VOC emissions if burned. The remaining particulates, metals, and emissions are controlled with a Direct Evacuation System (DES) and evacuated through two main branches of ductwork: through direct evacuation by a preheater chamber which feeds scrap to the furnace and through a canopy hood positioned high above the electric arc furnace in the Melt Shop roof. This process generates no more than 57 lb/hr of VOC. Several modifications were made to the DES system after its initial design in 1997 for the primary purpose of reducing VOC emissions. Specifically, two methods of post-combustion control are integrated into the Consteel(TM)/DES system evacuation design to rapidly melt the scrap as it is introduced into a hot heel of metal.  These included oxygen injection in the freeboard space in the Sayreville EAF above the foamy slag and oxygen injection into the preheater at ports along the length of the scrap conveyor.  The antechamber and DES water spray chambers were replaced with larger vessels to increase residence time. Lastly, modifications to the DES were made to increase temperature in the antechamber by reducing infiltration of cold air.  
      The proposed CMC Steel New Jersey facility-specific VOC and NOx RACT control plans identify seven possible VOC control technologies and eight possible NOx control technologies for a typical electric arc furnace, summarized in the table below. The facility demonstrates that the Sayreville EAF is capable of meeting 57 lb/hr VOC through their current practices with the DES and scrap management plan; and is capable of meeting 31 lb/hr NOx by avoiding temperature spikes and minimizing electrical use as control technologies. 
      
      The two RACT control plans also consider the cost of all the technologically feasible control devices not currently in use in the Melt Shop so that they can determine if the not-in-use control devices should be added or not. In the source-specific SIP revision before us, the control that could be added is the thermal incinerator for VOC emission reductions, as such, the facility conducted a RACT analysis on the thermal incinerator. The RACT analysis must demonstrate that VOC reductions from the thermal incinerator are cost effective to be considered RACT.  If the cost to the facility to install and operate a thermal incinerator on the Sayreville EAF is higher than what is expected by the federal or state regulation, the thermal incinerator is not cost effective and is not RACT, which is the case under this source-specific SIP revision. 
      
      Cost effectiveness is a figure in dollars per ton of emissions reductions per year (i.e., the cost per ton of pollutant controlled). Factors of cost effectiveness include, for example, consideration of process capital equipment, total plant cost and investment, fixed and variable operating cost, total capital requirement and consumable costs. Because sources (e.g., electric arc furnace) will vary in age, condition, and size, among other considerations, the actual cost, emission reduction, and cost effectiveness levels that an individual source will experience in meeting the RACT requirements will vary from unit to unit and from area to area. The EPA believes that it is appropriate to focus on a range of cost effectiveness due to the variability of the actual cost effectiveness that is expected from unit to unit. See, March 16, 1994 D. Kent Berry Memorandum "Cost effective Nitrogen Oxides (NOx) Reasonably Available Control Technology (RACT)". 
      
      Based on the November 2017 updates to the EPA Air Pollution Control Cost Manual, the maximum costs considered are for a 50,000 standard cubic feet per minute (SCFM) thermal incinerator. Although larger thermal incinerator units can be built, applications are rare at flow rates above 50,000 SCFM. Therefore, CMC Steel New Jersey calculated the cost needed to handle a flow rate of 100,000 SCFM based on the cost of two 50,000 SCFM units. The cost effectiveness of operating two thermal incinerators was calculated using the total annual cost of two thermal incinerators ($3,647,283) and the VOC emissions that would be removed (74.8 TPY). Therefore, the annual cost effectiveness to install two thermal incinerators on the Sayreville EAF is $48,760 per ton VOC reduced ($3,647,283 / 74.8 = $48,760). The VOC reduction was based on a baseline of 78.7 TPY from the facility's Title V permit and an assumed thermal incinerator control efficiency of 95%, resulting in a reduction of 74.8 TPY of VOC.  A control efficiency of 95% was selected based on EPA guidance (i.e., Handbook Control Technologies for Hazardous Air Pollutants, EPA/625/6-91/014, June 1991).   
      
      Although capital costs are not conserved in the RACT cost effectiveness, consideration of process capital equipment was estimated to demonstrate RACT. To purchase two thermal incinerators at 2018 dollars the cost is $2,645,690. And because of the presence of sulfuric acid that can be in the gas stream, a 100,000 SCFM packed-bed/packed-tower wet scrubber to control the halogenated/sulfur compounds can cost $4,703,832 to install. Since $48,760 per VOC tons removed is above the federal RACT and no other electric arc furnace in the U.S. has thermal incinerator control technology to compare, the thermal incinerator is not cost effective.
      
      The two tables below summarize the VOC and NOx control technologies identified by CMC Steel New Jersey for the electric arc furnace and which are technologically feasible, which have RACT analysis, and which are currently being implemented:  
      
                           VOC control technologies
                                       
Scrap management plan


Technically feasible; Currently implementing  -  purchased scrap material is of consistent and verifiable quality to minimize the amount of nonmetallic/organic material, including oil, grease, and plastic that would result in VOC emissions.
Direct evacuation system (DES)


Technically feasible; Currently implementing  -  VOC emissions are both generated in and destroyed (controlled) in the preheater by the DES. Utilizes a "Fourth-hole evacuation" to capture gas from the electric arc furnace through the preheater to send to the baghouse through ducts. To destroy VOCs the temperature in the preheater is maintained between 1,400 and 2,100º F with an oxygen content varying from 0 to 14% as measured at the preheater exit.
Thermal incineration


Technically feasible; RACT analysis provided  -  This technology has not been implemented for an electric arc furnace. Not well suited for streams with large fluctuations in flow rate because the reduced residence time and mixing during increased flow would result in lower destruction efficiency. Thermal incineration can handle minor fluctuations in flow, however, excess fluctuations require the use of a flair. Thermal incinerator fuel consumption is high so thermal units are best suited for small process operations with moderate to high VOC loadings. Also, see the "disadvantage" section of the factsheet (EPA-452/F-03-022), speaks of formation of highly corrosive acid gases.
Catalytic incineration


Not technically feasible  -  Strong likelihood of catalyst poisoning and deactivation and the high level SO3 and sulfuric acid (H2SO4) would cause catalyst fouling.
Flares


Not technically feasible  -  Require constant fuel combustion to maintain the pilot flame which would result in higher emissions including CO and NOx. Flares cannot be used to treat waste with halogenated compounds (CMC Steel New Jersey has halogenated/sulfur compounds in the gas stream, such as dioxin). Flares are primarily a safety device which deal with flow in short duration (an upset or accidental release condition) rather than a control device that treats a continuous stream. 
Mixed bed carbon adsorption

Not technically feasible  -  Not feasible based on the VOC concentration in the exhaust gas.
Condensers/recapture

Not technically feasible  -  Not feasible based on requirement of large amounts of energy to meet the high cooling requirements.


                           NOx control technologies
                                       
Good operating practices


Technically feasible; Currently implementing  -  CMC Steel New Jersey maintains constant temperature in the pre-chamber and in the Sayreville EAF which avoids temperature spikes that would create more NOx emissions. They also use the least amount of electricity as possible to reduce indirect NOx emissions.
Direct evacuation system (DES)

Not technically feasible  -  Even though the DES vents NOx emissions to the baghouse, it does not prevent the formation of NOx nor does it destroy already created NOx.
Low NOx/oxy-fuel burner 


Not technically feasible  -  This technology is used on burners and the Sayreville EAF does not utilize burners to melt scrap.
Low excess air


Not technically feasible  -  This technology is used on burners and the Sayreville EAF does not utilize burners to melt scrap.
Flue gas recirculation / temperature reduction


Not technically feasible  -  The Sayreville EAF requires a temperature of over 2,000°F for the incoming air, well above the temperature required to control NOx using gas recirculation. Carbon Monoxide (CO) is combusted in the preheater to maintain the correct temperature and to control CO. Reducing the temperature at the preheater could jeopardize the CO combustion and control.
Selective Catalytic Reduction (SCR)
Not technically feasible  -  Catalyst poisoning by acid gases and particulate matter can occur. The scrap metal contains large amounts of sulfur, which leads to the formation of sulfuric acid and sulfite (SO3) in the EAF. SO3 can combine with the ammonia to form Ammonium Bisulfate, which sticks to the catalyst causing fouling of the catalyst. The sulfuric acid created can also cause poisoning of the catalyst directly. The exhaust gas from the EAF contains high concentrations of particulate matter including metals. The high concentration of particulate matter will cause unacceptable fouling of the catalyst, which can deactivate the catalyst rendering it impractical for the EAF. Also, the presence of metals, such as arsenic, mercury, vanadium, zinc, etc, can deactivate the catalyst as well.
Selective Non-Catalytic Reduction (SCNR)
Not technically feasible  -  The Sayreville EAF has a wide variability of temperature, flow rate, and pollutant concentrations in the gas exhaust. The SNCR reaction needs a certain temperature range to take place. If the temperature is too low the ammonia (NH3) and NOx do not react, resulting in ammonia slip emissions (in addition to the NOx that wasn't destroyed being released). At too high of a temperature NH3 decomposes into nitric oxide (NO) and water, resulting in higher NOx emissions.
Non-Selective Catalytic Reduction (NSCR)
Not technically feasible  -  NSCR is generally applicable to rich burn reciprocating engines running near stoichiometric conditions to destroy NOx, CO, and VOC/HAP. The Sayreville EAF does not operate as a reciprocating engine, rather, it operates with excess oxygen (lean-burn) and the oxygen content in the exhaust gas would be too high for NSCR to be technically feasible. 
  

EPA's Determination

Based on a thorough review of similar sources, and analysis of this source-specific SIP revision, the EPA is proposing to allow CMC Steel New Jersey to continue to operate under their current approved emission limits for the Sayreville EAF. Specifically, the VOC emission rate of 57 lb/hr and the NOx emission rate of 31 lb/hr. And that there are no VOC nor NOx control technologies that are RACT besides what the facility already has in place. The control technologies currently in place are DES and scrap management plan capable of meeting 57 lb/hr VOC and best management practices to avoid temperature spikes and minimize electrical use that results in meeting the 31 lb/hr NOx limit. The facility met the statutory deadline to qualify for continuing to operate under existing limits.  


Note this technical support document summarizes the State submission and the EPA/State consultations.  The related correspondence and State Implementation Plan revision are available for inspection and review at the EPA regional office located at 290 Broadway, floor 25, NY, N Y and the New Jersey Department of Environmental Protection office. Or by contacting Linda Longo, Air Programs Branch, Environmental Protection Agency, (212) 637-3565, or longo.linda@epa.gov.  
