ILLINOIS POLLUTION CONTROL BOARD
    July 24, 1975
    IN THE MATTER OF PROPOSED
    AMENDMENTS TO AIR POLLUTION
    )
    R73-16
    CONTROL REGULATIONS, RULES
    203(d) (6) (B) (ii) (bb) and
    203(d) (6) (B) (iv) (aa~
    OPINION AND ORDER O~THE BOARD (by Mr. Dumelle):
    Granite City Steel, a wholly-owned subsidiary of National
    Steel Corporation (Granite City), filed a proposed regulation
    amendment to Rule3 203 (d) (6) (B) (ii) (bb) and 203 (d) (6) (B)
    (iv) (aa) of Chapter 3, Air Pollution Control Regulations
    (Air Regulations) on November 30, 1973. The proposal was
    published on February 25, 1974 in Board Newsletter ~81.
    Hearings were held on June 21, 1974 in Edwardsville and on
    October 22, 1974 in Chicago. A public comment period was
    set until December 20, 1974. Representatives from Granite
    City and Interlake Steel Company (Interlake) testified in
    support of the pr3t~osa1 at the Chicago hearing. Representatives
    of the Illinois Ecivironmental Protection Agency (Agency)
    appeared at both hearings in opposition to the proposal but
    did not present any testimony.
    Granite City proposed an amendment to two subsections
    of Rule 203(d) Exceptions to Rules 203(a), 203(b) and
    203(c) (6) Coke Manuf~tcturingProcesses to the Air Regulations.
    Specifically, Granite City proposed to first amend the
    following existing language:
    On and after December 31, 1974, all coke oven facilities
    shall be equipped with enclosed pushing and quenching
    systems with particulate collection equipment, or shall
    employ alterr~ative methods of comparable effectiveness
    in reducing emission during pushing and quenching (Rule
    203(d) (6) (ii) Pushing and Quenching (bb)).
    18— 200

    Granite City proposed that the Board adopt the following
    amendment in place of the above language:
    On
    and after July 1, 1975, all coke oven facilities
    shall be
    operated to reduce smoke or other particulate
    matter, other than water, during pushing of coke from
    coke
    ovens to an opacity of 30 per cent or less when
    the opacity of such emission is observed above the top
    of the coke oven battery against an open sky.
    The
    second proposal was to replace the following existing
    language:
    On
    and after July 1, 1972, no person shall cause or
    allow the operation of a coke oven that emits any
    specified air contaminants into the atmosphere during
    coking from the coke oven doors for more than ten
    minutes after commencement of the coking cycleS
    During
    such ten minutes the emission shall have an
    opacity no greate.r than 30 per cent. Rule 203(d) (6) (iv)
    (Coke Oven Doors (aa)),
    Granite City proposed the adoption of the following
    amendment:
    After December 31, 1973, no person shall cause or allow
    the operation of a coke oven that emits smoke ir~othe
    atmosphere during coking from the coke oven doors for
    more than thirty minutes after commencement of the
    coking cycle in excess of 30 per cent opacity when
    observed above the top of the battery against an open
    sky, except that smoke emitted from any door in excsss
    of thirty minutes shall be suppressed by appropriade
    means to meet the standard contained in this ru1e~
    The first proposed amendment concerned coke pushing and
    quenching operations, Dr. Donald Cairns, Vice President of
    Granite
    City Steel, testified that:
    There is no enclosed pushing and quenching system which
    has been evaluated so that a rational decision can be
    made as to what an alternative of equal effectiveness
    would be... R, 30,
    Rule
    203 (d) (6) (ii) (bb) required that all coke oven facilities
    be
    equipped with such enclosed pushing and quenching systems
    or
    employ alternative methods of comparable effectiveness~
    The
    opinion of the Board which accompanied the adoption the
    rule
    referred to the:

    —3—
    development of a largely enclosed quench car into which
    the coke could be pushed, with potential emissions
    captured and treated by a control device mounted on the
    car itself (R. 2798—2805) (Opinion of the Board, R71-
    23, page 24 (April 13, 1972)).
    Such an enclost~d quenching car was originally scheduled
    for operation by :he end of 1972 (Ibid). Based upon such
    testimony the Board stated:
    We believe it reasonable, based upon the timetable, to
    allow others to await the outcome of Interlake’s demonstration,
    recognizing rhat pushing control technology is somewhat
    behind that foi charging, and still to install the
    Allen car or ai~ alternative of equivalent effectiveness
    by the end of 1972 (Ibid).
    Mr. Fred Krikau of Interlake Steel Company testified
    that their Hanley Allen Car (Halcar) has undergone a series
    of testing and mockification, and was currently “back in
    operation again and tested” IR. 11211. It is therefore
    apparent that the initial prediction that the Harley Allen
    car would be in oporation by the end of 1972 has not been
    brought to fruitioc~,
    Dr. John Manda, Directo.r of Environmental Quality
    Control Department at Granite City, raised the objection
    that the present rule:
    implies that an enclosed pushing and quenching system
    exists, in operation, and the effectiveness of the
    system can be measured in its ability to reduce emissions
    during pushi:ta and quenching (R. 45).
    Dr. Manda stated
    tr~at
    because there is no enclosed system in
    operation, “no standard exists to which other alternative
    systems can be compared, and this fact makes application of
    the present rule 203(d) (6) (B) (ii) (bb) impossible for any
    alternative pushing and quenching system” (R. 45).
    We agree with t.e Agency’s interpretation of Rule 203
    (d) (6) (B) (ii)
    (bb)
    to call for the application of state of
    the art control of particulate and gaseous emissions from
    the pushing and quenching portion of the coking cycle
    (Agency Brief, page 7). The Agency states that reference to
    an enclosed system “qualifies such a system as the state of
    the art standard to which all other systems must point”
    (Ibid)
    18
    202

    —4—
    Dr. Manda poinLs out the Granite City’s misinterpretation
    of the standard when he stated that:
    there exists no quantitative or qualitative measurement
    techniques by c~hich the effectiveness of an enclosed
    pushing and quenching system can be determined, nor the
    effectiveness in reducing pushing and quenching emissions
    from an alternative system (B. 46).
    Dr. Manda testified that measurement of particulate concentrations
    cannot be perforn’ed to arrive at accurate and reproducible
    results because of the short—term transient process emissions
    during pushing and ~uenching (B. 47). He therefore recommends
    adoption of the alternative opacity standard proposed by
    Granite City (B. 48).
    We disagree with Dr. Manda in that the opinion accompanying
    the Rule states tha1::
    Performance standards for such installations, as well
    as more specific ones for charging controls, will have
    to await testing results. For now the important thing
    is to get the control equipment installed and in operation
    (Opinion of che Board, R7l-23, page 24 (April 13,
    1972)).
    We recognized when ~ieadopted the rule that performance
    standards for the Hanley Allen car would have to await the
    successful operation and testing by Interlake. In addition,
    the opinion refers to the development of standards for
    enclosed pushing tnd quenching systems, as well as more
    specific ones for charging controls, will have to await
    testing results” (emphasis added) (Ibid). We recognized the
    potential difficulty in developing such performance standards
    for pushing and quenching systems.
    What the Board adopted when we enacted this rule was a
    “state of the art” technology requirement. At the time of
    adoption the Hanley Allen car constituted the most promising
    control strategy. I is now clear that other technologies
    exist such as the Weirton system, Coke Sheds, Mitsubishi
    Mobilehoods, and Granite City’s proposed mobile hood with a
    water spray. Dr. Cairns presented some testimony regarding
    what he believed to be the benefits and draw backs of such
    systems (R. 30 through 37). Granite City is proceeding
    with the development of a mobile hood it has developed.
    Interlake is continuing the development of the Hanley Allen
    car. Republic Steel has completed final specifications and
    has placed an order to build a shed over the coke side of
    the coke battery to control pushing emissions (comment
    letter from Republic Steel, November 19, 1974). Nothing
    was introduced as to what control Wisconsin Steel and
    International Harvester, two of the major Illinois coke makers,
    were utilizing.
    18— 203

    —5—
    Given the development of three different control devices
    by three out of the four major Illinois coke producers, the
    Board is convinced the state of the art approach is correct
    for controlling coke pushing and quenching emissions.
    Individual companies are to develop the control strategy
    best suited for their existing coke ovens after consultation
    with the Agency.
    The plans for the proposed control equipment would then
    be submitted by the tgency for the appropriate permits. In
    the event that the Agency disagreed that what an individual
    company had proposed would adequately reduce emissions
    during pushing and quenching, then the company would appeal
    the Agency permit denial to the Board in accordance with
    Title 10 of the Environmental Protection Act (Act). If
    additional time beyond December 31, 1974 is needed to develop
    and install equiprient, individual companies have the variance
    procedure of Title 9 of the Act available. We are not
    discussing a rule with broad application, but rather a rule
    designed to allow for developing technology by the few coke
    manufacturers located in Illinois.
    The second ameno~nentproposed by Granite City related
    to the requirement that coke oven doors be sealed within 10
    minutes after the start of the coke cycle and that the
    leakage be limited to 30 opacity. Dr. Cairns testified
    that in his opinion coke oven self sealing doors took 30
    minutes to seal g~.venthe present state of the art (R. 63).
    Mr. J.D. Burroughs, Manager of Environmental Control, Granite
    City, testified that the opacity measurements should be made
    with the open sky behind the plume (R. 70). Interlake
    presented testimony that would have measured all coke oven
    emissions, including types from leaking doors, some thirty
    feet over the battery against the open sky (R. 103).
    Republic Steel agreed that a change in Rule 203(d) (6) (B)
    (iv) (aa) was in order, but proposed an alternative changes
    (Public comment, November 19, 1974).
    An analysis of the record indicates that a potential
    exists for amendment to Rule 203(d) (6) (B) (iv) (aa), but the
    Board finds that Cranite City has failed to develop a record
    which would allow the Board to adopt a revision in accordance
    with Section 27 of the Act. It is suggested that representatives
    18—
    204

    from Granite City7 Interlake, Republic Steel ~e cercy an~
    any others interested, meet and develop a mu~ual~yacceptable
    proposal and subi~it it to the Board, The st~rict~onthat a
    regulation proposal not have been heard within the proceeding
    6 months is not mandatory, but is within Board discretion to
    waive (Section 28 of the Act). If any additional proposal
    is made, the proponents should carefully consider the problems
    and objections outliced on pages 15 through 18 of the Agency’s
    Brief dated December 23, 1974.
    In summary, the Board finds that no change is warranted
    to Rule 203(d) (6)
    (B)
    (ii) (bb) of Chapter Three and that
    Granite City Steel Company has failed to prov Be the Board
    with an adequate record to adopt the suggested c ange to
    Rule 203(b) (6) (B) (iv) (aa)
    This Opinion constitutes the Board~s findinjs Ot fact
    and conclusions of law.
    ORDER
    In accordance with the above Opinion, the proposed
    amendments to Rule 203 (b) (6) (B) of the Air Pollut~onControl
    Regulations, entitled R73-l6, are hereby d~smiosed,
    IT IS SO ORDERED.
    I, Christan l~. Moffett, Clerk of the Illinois Pollution
    Control Board, heieby cer ify the above Opir ion and Order
    were adopted on the
    ,~
    day of July, 1975 by a vote of
    -0
    PollutionanL.ControlMo
    tt,BoardIc MT~i
    18— 205

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