Final Amendments to Integrated Iron and Steel Manufacturing MACT Standards

Posted: June 11th, 2024

Authors: Roy R.

The Administrator of the U.S. Environmental Protection Agency (U.S. EPA) signed the final version of amended 40 CFR Part 63, Subpart FFFFF – National Emission Standards for Hazardous Air Pollutants (NESHAP) from Integrated Iron and Steel Manufacturing Facilities (Subpart FFFFF) on March 11, 2024. ALL4’s November 2023 blog post regarding the proposed rule, which provides additional background, can be accessed here. The final rule has not been published in the Federal Register as of June 6, 2024. Subpart FFFFF applies to facilities engaged in producing steel from refined iron ore. There are currently eight operating facilities and one idle facility in this source category.

The final rule amendments:

Add new requirements to regulate hazardous air pollutants (HAP) emissions from five unmeasured fugitive and intermittent particulate (UFIP) sources
Add new requirements for five HAP from sinter plants
Add new requirements for three HAP from blast furnace (BF) stove and basic oxygen process furnace (BOPFs) control devices
Add new work practice standards for BOPF shops
Add new visible emissions monitoring requirements for BOPF shops and BF casthouses
Revise standards for dioxins/furans (D/F) and polycyclic aromatic hydrocarbons (PAH) for sinter plants
Add a new fenceline monitoring requirement for chromium (Cr), an associated “action level,” and requirements for a “root cause analysis” and corrective actions if the action level is exceeded.

The final rule also removes exemptions for periods of startup, shutdown, and malfunction (SSM), clarifies that emissions standards apply at all times, and includes new electronic reporting requirements for performance test results and compliance reports.

Summary of Changes from the Proposal

The proposed revisions to Subpart FFFFF were originally published in the Federal Register on July 31, 2023. The final amendments are substantial and include multiple revisions to meet EPA’s statutory obligations under CAA section 112(d)(6) to address the Louisiana Environmental Action Network v. EPA, 955 F.3d 1088 (D.C. Cir. 2020) (LEAN) decision. The final amendments also include a fenceline monitoring requirement that U.S. EPA justifies under CAA section 112(d)(6) that will become effective one year after U.S. EPA promulgates a sampling method, or two years upon the publication date of the rule, whichever is later. Summaries of the changes from the original proposal related to UFIP sources; unregulated HAP from Sinter Plants, BF Stoves and BOPFs; and EPA’s reconsideration of standards for D/F and PAH for sinter plants are provided in Tables 1, 2, and 3 below, respectively. In each table, summaries of the original proposed requirements and final requirements are provided for comparison. Note that the information presented in Tables 1 through 3 are summaries and should not be relied upon for compliance purposes. Please refer to the final rule for exact regulatory references and requirements.

Table 1
Summary of Changes to UFIP Sources

Source/Operation	Proposed Requirement	Final Rule Requirement
BF Unplanned Bleeder Valve Openings, existing	Five unplanned openings per year, per furnace	Large furnaces – four unplanned openings per rolling year, per furnace Small furnaces – fifteen unplanned openings per rolling year, per furnace
BF Unplanned Bleeder Valve Openings, new	Zero unplanned openings per year, per furnace	Zero unplanned openings per rolling year, per furnace (large and small furnaces)
BF Unplanned Bleeder Valve Openings, existing and new	Install furnace level monitoring devices at three locations with alarms to indicate when a slip may occur Install instruments to monitor furnace temperature and pressure to indicate when a slip may occur Install screens to remove fine material from charge material Develop/submit implementation plan Report unplanned openings and corrective actions in semiannual reports	No changes from proposal
BF Planned Bleeder Valve Openings, existing	8 percent opacity for any 6-minute averaging period during planned BF bleeder valve openings	No changes from proposal
BF Planned Bleeder Valve Openings, new	0 percent opacity for any 6-minute averaging period during planned BF bleeder valve openings	No changes from proposal
BF and BOPF slag processing, handling, and storage, existing	5 percent opacity limit (beyond the floor) based on 6-minute averages for BF and BOPF slag processing, handling, and storage, and slag pits	10 percent opacity limit based on 6-minute averages for BF and BOPF slag processing, handling, and storage, and slag pits.
BF and BOPF slag processing, handling, and storage, new	2.5 percent opacity limit based on 6-minute averages for visible emissions from slag pits and during slag handling, storage, and processing	3 percent opacity limit based on 6-minute averages for visible emissions from slag pits and during slag handling, storage, and processing
BF Bell Leaks	10 percent opacity as an action level for large bell leaks (not a MACT emissions limit) Monthly visible emission (VE) observation of BF top using U.S. EPA Method 22 Opacity test using Method 9 if VE observed out of interbell relief valve Repair/replace large bell seals with 4 months if opacity is > 10%	10 percent opacity as an action level for large bell leaks (not a MACT emissions limit) Monthly visible emission (VE) observation of BF top using U.S. EPA Method 22 Opacity test using Method 9 if VE observed out of interbell relief valve Initiate operational or other corrective actions within five business days if opacity is > 20% Retest after five days and initiate further operational or corrective actions to reduce opacity, if opacity is > 20% Retest after five days and repair/replace large bell seals within 4 months if opacity is > 20%
BF Bell Leaks, existing and new	For small bells, replace or repair seals prior to a metal throughput limit, specified by the facility, which has been proven and documented to produce no opacity from the small bells.	No changes from proposal
Beaching of Iron from BFs, existing and new	Full or partial enclosures for the beaching process or use CO₂ to suppress fumes Minimize the height, slope, and speed of beaching	No changes from proposal
BF Casthouse	5 percent opacity limit based on 6-minute averages Measure opacity during the tapping operations (at least two times per month) Keep all openings, except roof monitors, closed during tapping and material transfer events	U.S. EPA did not finalize any changes to the opacity limits for the BF casthouse in the final rule Comply with existing 20 percent opacity limits in the rule
BOPF Shop	5 percent opacity limit based on 3-minute average Work practices including reduced building openings, shop structure inspections, hot metal ladle optimization, monitor opacity twice per month, and develop/implement an operating plan to minimize emissions	U.S. EPA did not finalize any changes to the opacity limits for the BOPF Shop in the final rule Comply with existing 20 percent opacity limits in the rule Work practices including reduced building openings, shop structure inspections, hot metal ladle optimization, monitor opacity twice per month, and develop/implement an operating plan to minimize emissions
Fenceline Monitoring	Install four ambient air monitors at or near the fenceline at appropriate locations around the perimeter of the facility Collect and analyze samples for total chromium every sixth day Condict root cause analysis if rolling 12-month delta c exceeds action level of 0.1 µg Cr/m³ Take corrective action to prevent exceedances Report data to Compliance and Emissions Data Reporting Interface (CEDRI) on a quarterly basis Data to be available through the Web Factor Information Retrieval system (WebFIRE) website Sunset provision if the annual average delta c remains 50-percent or more below the action level (i.e., 0.05 μg/m³ or lower) for a 24-month period	No changes from proposal

Table 2
Summary Changes to Unregulated HAP from Sinter Plants, BF Stoves and BOPFs, and BFs

Source/Operation	HAP	Proposed Limit	Final Rule Limit
Sinter Plants	Carbon Disulfide (CS₂)	Existing and new: 0.028 lb CS₂ /ton sinter	Meet applicable carbonyl sulfide (COS) limit Meet requirements of 40 CFR § 63.7790(d)
Sinter Plants	COS	Existing: 0.064 lb COS/ton sinter New: 0.030 lb COS/ton sinter	No changes from proposal
Sinter Plants	Hydrogen Chloride (HCl)	Existing: 0.025 lb HCl/ton sinter New: 0.0012 lb HCl/ton sinter	No changes from proposal
Sinter Plants	Hydrogen Fluoride (HF)	Existing and new: 0.0011 lb HF/ton sinter	Meet applicable HCl standard
Sinter Plants	Mercury (Hg)		Existing: 1.8e-5 lb Hg/ton sinter New: 1.2e-5 lb Hg/ton sinter
BF Casthouse Control Devices	HCl	Existing: 0.0013 lb HCl/ton iron New: 5.9e-4 lb HCl/ton iron	Existing: 0.0056 lb/ton iron New: 5.9e-4 lb/ton iron
BF Casthouse Control Devices	THC	Existing: 0.092 lb THC/ton iron New: 0.035 lb THC /ton iron	Existing: 0.48 lb/ton iron New: 0.035 lb/ton iron
BOPF	D/F (TEQ)	Existing and new: 4.7e-8 lb DF/ton steel	Existing and new: 9.2e-10 lb/ton steel
BOPF	HCl	Existing: 0.078 lb HCl/ton steel New: 9e-4 lb HCL/ton steel	Existing: 0.058 lb HCl/ton steel New: 2.8e-4 lb HCl/ton steel
BOPF	Total Hydrocarbons (THC)	Existing: 0.04 lb THC/ton steel New: 0.0017 lb THC/ton steel	No changes from proposal
BF Stoves	D/F (TEQ)	Existing and new: 3.8e-10 lb DF/ton iron	Good combustion practices demonstrated by meeting the THC limit
BF Stoves	HCl	Existing: 5.2e-4 lb HCl/ton iron New: 1.4e-4 lb HCl/ton iron	Existing: 0.0012 lb/MMBtu New: 4.2e-4 lb/MMBtu
BF Stoves	THC	Existing: 0.1 lb THC/ton iron New: 0.0011 lb THC/ton iron	Existing: 0.12 lb/MMBtu New: 0.0054 lb/MMBtu

Table 3
Summary Changes to Reconsidered Standards for Sinter Plants

Source/Operation	HAP	Proposed Limit	Final Rule Limit
Sinter Plants	D/F (TEQ)	Existing: 3.5E-08 lb D/F per ton of sinter (TEQ) New: 3.1E-09 lb D/F per ton of sinter (TEQ)	Existing and new: 1.1E-08 lb D/F per ton of sinter (TEQ) Activated carbon injection (ACI) controls
Sinter Plants	Polycyclic Aromatic Hydrocarbons (PAH)	Existing: 5.9E-03 lb PAH/ton of sinter New: 1.5E-03 lb PAH/ton of sinter	Existing: 1.8E-03 lb PAH/ton of sinter New: 1.5E-03 lb PAH/ton of sinter ACI controls
Sinter Plants	Hg	Existing: 3.5E-05 lb Hg/ton sinter New: 1.2E-05 lb Hg/ton sinter	Existing: 1.8E-05 lb Hg/ton sinter New: 1.2E-05 lb Hg/ton sinter ACI controls

Next Steps

Based on the assumption that the final version of the signed rule will be promulgated as-is, the next steps are related to planning for compliance. A summary of compliance dates for the final rule, adopted from the pre-publication version, is provided in Table 4. Several of the compliance timelines for new rule requirements and standards have been extended as noted.

Table 4
Summary of Compliance Dates

Sources	Requirement	Proposed Compliance Date	Final Compliance Date
Existing Sinter Plant Windboxes	New HCl, COS, D/F, and PAH standards	6 months after promulgation	3 years after promulgation
All existing affected facilities	Fenceline ambient monitoring	Begin 1 year after promulgation of the fenceline method for metals or 2 years after the promulgation date of the final rule, whichever is later	No changes from proposal
All existing affected facilities	Opacity limits for planned openings Work Practices for Bell Leaks, and Work practices for BOPF Shops	12 months after promulgation	No changes from proposal
All existing affected facilities	Work Practices and limits for unplanned openings Work practices for beaching Opacity limit for slag processing	12 months after promulgation	24 months after promulgation
Existing BF and BOPF sources	New emissions limits for HCl, THC, and D/F	6 months after promulgation	3 years after promulgation
All new affected sources	All new and revised provisions	Effective date of the rule or upon startup	Effective date of the rule or upon startup

The rule revisions are substantial and impact multiple operations at integrated iron and steel facilities. The final rule standards and work practice requirements, along with the fenceline monitoring requirements, Cr action level tracking, and, as applicable, root cause analyses and corrective actions, will pose a heavy compliance burden on affected facilities. ALL4 staff are experienced in planning for and implementing updated air regulatory requirements, including fenceline monitoring. If you have any questions on this rule or would like help preparing for these new requirements, please contact Roy Rakiewicz at rrakiewicz@all4inc.com.