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)).
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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:
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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)
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202
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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.
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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
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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
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