R 336.1430
R 336.1430 Emission of SO2 from United States Steel, Great Lakes Works.
Cite as Mich. Admin. Code R 336.1430
Rule 430. (1) The provisions in this rule supersede the requirements of R 336.1407 that
apply to United States Steel, Great Lakes Works reheat furnaces and Zug Island boilers as
referenced in subrules (2) and (3) of this rule.
(2) All of the following apply to United States Steel, Great Lakes Works, 80” hot strip
mill reheat furnaces:
(a) On and after December 31, 2016, the combined SO2 emission rate from the 5 reheat
furnaces shall not exceed 148 pounds per hour, based on a 1-hour average starting on the
hour for each clock-hour.
(b) On and after December 31, 2016, the company shall install, calibrate, maintain, and
operate in a manner approved by the department devices to separately monitor and record
the coke oven gas and natural gas usage rates, in cubic feet per hour, for the 5 reheat
furnaces combined for each hour of operation. The 5 furnaces shall be equipped with a
common coke oven gas usage meter and a common natural gas usage meter. The company
shall keep the usage rate records on file at the facility for a period of 5 years, in a format
acceptable to the department, and make them available to the department upon request.
(c) On and after December 31, 2016, the company shall compile hourly SO2 emission
rate calculations for the 5 reheat furnaces combined in pounds per hour, for each hour of
operation. Emission rates shall be determined using the method specified in subrule (3)(g)
of this rule. The company shall keep the records of the calculations on file at the facility
for a period of 5 years, in a format acceptable to the department, and make them available
to the department upon request.
(d) Not later than June 30, 2017, the company shall conduct SO2 emission stack tests of
the reheat furnaces, based on testing of a representative furnace. Not less than 30 days
before testing, a complete stack test protocol shall be submitted to the department for
approval. The final plan must be approved by the department before testing. Verification
of emission rates includes the submittal of a complete report of the test results to the
department within 60 days following the last date of the test. The company shall keep the
records of the test on file at the facility for a period of 5 years, in a format acceptable to the
department, and make them available to the department upon request.
(e) On and after September 15, 2017, the company shall submit an excess emission report
in an acceptable format to the department semiannually. The report shall be submitted by
September 15 for the January 1 to June 30 reporting period, and by March 15 for the July
1 to December 31 reporting period. The excess emission report shall include the following
information:
(A) A report of each exceedance above the SO2 limitation including the date, time,
magnitude, cause, and corrective actions for all occurrences during the reporting period.
(B) A report of all periods of fuel gas usage rate monitoring system downtime and
corrective action.
(C) If no SO2 limitation exceedance and no fuel gas usage rate monitoring system
downtime occurred during the reporting period, the company shall report that fact.
(3) All of the following apply to United States Steel, Great Lakes Works, Zug Island
boiler houses number 1 and 2:
(a) The following limits shall be met on and after December 31, 2016:
(i) The combined SO2 emission rate from the number 1 boiler house boilers 1 to 5 shall
not exceed 15 pounds per hour, based on a 1-hour average starting on the hour for each
clock-hour.
(ii) The combined SO2 emission rate from the number 2 boiler house boilers 1 to 5 shall
not exceed 21 pounds per hour, based on a 1-hour average starting on the hour for each
clock-hour.
(iii) The maximum hydrogen sulfide content of the blast furnace gas fired in the boilers
shall not exceed .0274 grains per dry standard cubic foot, based on a 1-hour average starting
on the hour for each clock-hour.
(b) The type of fuels burned in the boilers shall be restricted to blast furnace gas, coke
oven gas, and natural gas.
(c) On and after December 31, 2016, the company shall install, calibrate, maintain, and
operate in a manner approved by the department devices to separately monitor and record
the coke oven gas, blast furnace gas, and natural gas usage rates in cubic feet per hour for
the combined number 1 boiler house boilers and for the combined number 2 boiler house
boilers for each hour of operation. The company shall keep the usage rate records on file
at the facility for a period of 5 years, in a format acceptable to the department, and make
them available to the department upon request.
(d) On and after December 31, 2016, the company shall install, calibrate, maintain, and
operate in a manner approved by the department devices to monitor and record the blast
furnace gas hydrogen sulfide content in grains per cubic foot for the blast furnace gas fired
in the number 1 boiler house boilers 1 to 5 and in the number 2 boiler house boilers 1 to 5
on a continuous basis to determine the 1-hour average hydrogen sulfide concentration in
the blast furnace gas for each hour of operation. The company shall keep the records of
the hydrogen sulfide content on file at the facility for a period of 5 years, in a format
acceptable to the department, and make them available to the department upon request.
(e) On and after December 31, 2016, the company shall compile hourly SO2 emission
rate calculations separately for the combined number 1 boiler house boilers 1 to 5 and for
the combined number 2 boiler house boilers 1 to 5 for each hour of operation. Emission
rates shall be determined using the method specified in subdivision (g) of the subrule. The
company shall keep the calculation records on file at the facility, for a period of 5 years, in
a format acceptable to the department, and make them available to the department upon
request.
(f) On and after September 15, 2017, the company shall submit an excess emission report
in an acceptable format to the department semiannually. The report shall be submitted by
September 15 for the January 1 to June 30 reporting period, and by March 15 for the
July 1 to December 31 reporting period. The excess emission report shall include the
following information:
(i) A report of each exceedance above the SO2 and/or hydrogen sulfide limitations
including the date, time, magnitude, cause, and corrective actions for all occurrences during
the reporting period.
(ii) A report of all periods of fuel gas usage rate monitoring system and/or fuel gas
hydrogen sulfide monitoring system downtime and corrective action.
(iii) If no SO2 and/or hydrogen sulfide limitation exceedances, no fuel gas usage rate
monitoring system downtime, or no fuel gas hydrogen sulfide monitoring system downtime
occurred during the reporting period, the company shall report that fact.
g) The company shall determine the average hourly SO2 emission rate for the group of 5
furnaces or boilers grouped as number 1 boiler house or number 2 boiler house boilers
subject to subrule (2) or (3) of this rule as specified below or by a method approved by the
department as required in subrule (4) of this rule:
HOURLY RATE (lbs SO2/hour) = [COG (1000 ft3/hour) * (0.702 lbs SO2 / 1000 ft3) +
BFG (ft3/hr) * H2S (gr/ft3 BFG) * (1 lb H2S / 7,000 gr H2S) * (1.88 lb SO2 /lb H2S) + NG
(1,000,000 ft3/hr)* (0.6 lb SO2 / 1,000,000 ft3)]
Where:
HOURLY RATE = boiler house group or furnace group emission rate (lbs SO2/hour).
COG = actual volume of coke oven gas consumed (1000 ft3 per clock-hour) in a furnace
group or boiler house group.
BFG = actual volume of blast furnace gas consumed (ft3 per clock-hour) in a furnace group
or boiler house group.
NG = actual volume of natural gas consumed (1,000,000 ft3 per clock-hour) in a furnace
group or boiler house group.
H2S = actual concentration of hydrogen sulfide in BFG (gr/ft3) determined on a 1-hour
average basis for each clock-hour of operation.
(h) Not later than June 30, 2017, the company shall conduct SO2 emission stack tests of
a representative boiler in number 1 boiler house and of a representative boiler in number 2
boiler house. Not less than 30 days before to testing, a complete stack test protocol must
be submitted to the department for approval. The final plan must be approved by the
department before testing. Verification of emission rates includes the submittal of a
complete report of the test results to the department within 60 days following the last date
of the test. The company shall keep the records of the test on file at the facility for a period
of 5 years, in a format acceptable to the department, and make them available to the
department upon request.
(4) The emission rate limits in subrules (2)(a) and (3)(a) of this rule, or equivalent limits
as determined by dispersion modeled SO2 impacts, may be met with several different
control methods including sulfur dioxide flue gas emission controls, blending of alternate
lower sulfur content fuels with currently used fuels, application of fuel desulfurization
control to the currently used coke oven gas and blast furnace gas, use of improved
dispersion techniques such as use of taller exhaust stacks, or a combination of these and/or
other control measures. By August 31, 2016, the company shall submit to the MDEQ for
approval the control methods, control efficiencies as appropriate, and associated testing,
recordkeeping and reporting methods that the company will use to comply with this rule.