ILLINOIS POLLUTION CONTROL BOARD
December 5, 1974
REPUBLIC STEEL COMPANY
v.
)
PCB 73—551
ENVIRONMENTAL PROTECTION AGENCY
MR. JOHN F. WARD, JR., O’KEEFE, ASHENDEN, O’BRIEND AND HANSON,
appeared on behalf of Petitioner;
MR. PETER ORLINSKY, appeared on behalf of the Environmental
Protection Agency;
OPINION AND ORDER OF THE BOARD (by Mr. Dumelle):
Petitioner, on December 21, 1973 filed a petition for
variance from Rule 203(d) (6) (B) (iv) (aa)
,
Rule 202(b), Rule
203(d) (6) (b) (ii) (bb) and Rule 206(d) of the Air Pollution
Regulations. The petition pertains to a by-product coke oven
battery, melt shop facilities and blast furnace excess gas
presently bled to the atmosphere.
Republic Steel Corporation, a New Jersey Corporation
(Petitioner), having principal offices in cleveland, Ohio,
operates an integrated steel mill at 11600 Burley Avenue,
on the Calumet River, approximately 3 miles upstream from
Lake Michigan and about 14 miles south and east of Chicago’s
Loop.
The coke plant consists of a single battery of 75 ovens
built in 19 2-3 by Wilputte using a patented Wilputte
underjet design of heating. Each oven is 18-3/8 inches
wide x 13 ft. 2-3/8 inches high and 40 feet 7-5/8 inches
long. The ovens have a rated capacity of 18 tons of coal
per charge which will produce approximately 13 tons of coke.
The design pushing schedule is 110 ovens per day, however,
the present operating rate is 100 ovens per day due to the
age of the battery. In 1972, 652,209 tons of coal were
coked for an average of 1,790 tons per day. The ovens are
grouped together, side by side, on approximately 3-1/3 foot
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centers. In each wall between adjacent ovens area row of
heating flues, thus, all but the flues at the ends of the
battery serve two adjacent ovens. Blast furnace gas and
coke oven by-product gas are used to heat the oven walls
through the heating flues. The ends of the oven chamber are
closed off with removable refractory lined doors. The oven
doors are in principle, selfsealing doors with a stainless
steel knife edge around the door which is spring-loaded and
which depends upon a metal-to-metal contact between the door
and the continuous machined surfaced cast iron jamb for
sealing. The sealing edge of the door is carried on a
flexible frame, and the door assembly is so designed that a
powerful spring between the locking bar and the door forces
the sealing edge against the metal door jamb with considerable
pressure. After the oven is charged with coal, the volatile
products liberated in the coking process are carried off
through a gas collecting system at the top of the oven. The
volatile products contain tar, and part of these products
escape into the atmosphere past the sealing edge of the
door. As the tar strikes the colder surfaces in the area of
the sealing edge, it hardens to complete the sealing of the
door.
At the conclusion of the coking cycle, the coke is
pushed out of the oven, through a guide, and into a quench
car. The hot coke is transported in the quench car to the
quenching station where generous quantities of water are
used to quench the coke. At the time of pushing, the coke
is 90—91 percent carbon and of a temperature of approximately
2,0000 Fahrenheit. When the hot coke (carbon) is pushed
from the oven where it has been coked in the absence of air,
the coke starts to oxidize in the presence of air and emissions
enter the atmosphere until the coke is quenched with water
to prevent it from burning to an ash.
Petitioner has achieved compliance in the operation of
the plant as far as charging and quenching is concerned.
However, he has not achieved compliance as far as oven door
leakage and pushing emissions are concerned. Petitioner has
committed himself to building a coke side shed, with whatever
particulate removal equipment may be required. However, it
will be impossible to achieve compliance with pushing emission
standards immediately, and therefore he requests a variance
from Rule 203(d) (6) (B) (ii) (bb) which requires control of
pushing emissions by December 31, 1974. Petitioner is under
orders by the Federal Environmental Protection Agency to
achieve compliance with Rule 203(d) (6) (B) (ii) (bb) by August
1, 1976, to which Petitioner has consented. We are therefore
granting a variance for one year from the date of this
Order. Petitioner will have to request additional variances
until compliance is achieved in 1976.
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The Board is aware that in granting this variance
beyond May 30, 1975 it raises legal questions as to whether
immunity from Federal enforcement action is granted. Counsel
for Petitioner has represented that an agreed-upon court order
with the Federal government is pending and will be entered.
Petitioner has made considerable progress in suppressing
door emissions but has not achieved compliance. On the
basis that he has agreed to a cooperative study with the
Agency and has also agreed to withdraw his judicial appeal
from the Board’s rules, we are granting a variance from
Rule 203(d) (6) (B) (iv) (aa) to December 31, 1974.
The Petitioner’s melt shop facilities consist of four
open-hearth furnaces and three electric arc furnaces.
Each of the open-hearth furnaces in this shop are
similar but not identical in physical makeup, and have been
upgraded during the past years to make them more efficient
and permit the use of natural gas roof burners and/or oxygen
roof lances.
Electrostatic precipitators for controlling particulate
emissions have been retro-fitted to Petitioner1s furnaces
between the waste heat boiler and the stack. The four open
hearth furnaces in this shop are rated at 250 tons per heat,
and actually averaged 260.5 ingot tons per heat during the
year 1973. There are four furnaces in the shop and the
average number of furnaces operated for 1973 was 3.0 furnaces
with one furnace being down for normal maintenance and
rebuilding of the refractories which deteriorate from the
high furnace temperatures which are in excess of 3000°F.
The process weight for the year 1973 averaged 112,800 lbs.
per hour based on a charge to tap time of 5.6 hours.
The furnace is charged through the five doors in the
front wall of the furnace. The ratio of cold to hot metal
charged is approximately one to three. The charging time
averages about 15 minutes.
Fuels used for melt down are Bunker “C” oil and coke
oven gas. Oxygen is used for metal working at the rate of
3,500 cfm. The oxygen lances are lowered through the roof
of the furnace.
The furnace is tapped on the opposite side of the
hearth from the charging doors and the metal flows through a
long spout into a ladle. Pouring time averages about 10
minutes.
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All of the furnaces are connected to a common flue and
the products of combustion and particulates are passed
through either a waste heat boiler or cooling chamber to
reduce the temperature of the gases below 5000F prior to
entry into the electrostatic precipitators (ESP).
The first ESP system was installed on two of the open
hearth furnaces in 1962 at a cost of approximately 4 million
dollars.
On April 23, 1971, six additional cells or units were
placed in operation, which more than tripled the capacity of
the original installation. The cost of the additional ESP
units was approximately 7 million dollars and has sufficient
capacity to handle the gases from the 3 operating furnaces.
The original installations made in 1962 are standby and used
as maintenance cells whenever work is required on the new
units.
The efficiency of the ESP units in controlling the
collected particulates is reported to be in excess of 99
percent. Considerable emissions from the charging and
tapping operations as well as residual emissions during
meltdowns and oxygen lancing from the furnace doors are not
collected by the control system, however, and are discharged
to the atmosphere through the building monitor.
Three electric arc furnaces rated at 150 tons each are
housed in the open-hearth building; in 1973 the shop averaged
2.8 furnaces. The charge-to-tap time of these furnaces is
approximately 5 hours/heat. In 1973, the process weight
rate for the furnaces was in the range of 92,000
—
93,000
lbs./hr.
Cold scrap is charged from a bottom drop bucket held by
an overhead traveling crane which requires the roof of the
furnace to be swung and disconnected from the central duct.
Hot steel is tapped into a ladle by tilting the furnace.
This process is also uncontrolled. In addition, some.
particulate emissions from the electrode ports during melt
down and from the slagging spout during slag—off are not
collected and are discharged to the atmosphere through the
building monitor. Republic has committed itself to the
control of these residual emissions are described in paragraph
13 of the Variance Petition.
Petitioner’s open hearth furnaces and electric furnaces
are in compliance so far as furnace discharges are concerned,
the particulates from the open hearth furnaces being removed
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in an electrostatic precipitator, and the particulates from
the electric arc furnaces in a bag filter installation.
However, during certain parts of the heat cycle there are
substantial emissions which are not captured by the control
equipment and leave the building without any control. For
the open hearth furnaces these operations are charging,
tapping, melt down and oxygen lancing phases of the heat
cycle. In the case of the electric arc furnaces there were
heavy emissions during the scrap charges, at the start of
meltdown through tho electrode parts, during slag-off and
during the tapping operation.
Petitioner has been studying the problem of residual
emissions from the melt shop for 18 months and has agreed to
announce the solution by June 28, 1974. However, a variance
will be necessary to allow time to make whatever installations
are necessary.
The excess blast furnace gas, which is vented to atmosphere
violates the CO standards because it contains over 200 parts
per million of CO. Petitioner is installing a 250,000
lb./hr. steam generator which will use the excess blast
furnace gas and thus come into compliance. The steam generator
is well on its way to completion and is scheduled to become
available by December 31, 1974. ~~1eare therefore granting a
variance from Rule 206(d) to that date.
Petitioner and the Agency have come to an agreement of
the issues in this case and to a course of action which will
greatly benefit the cause of cleaner air and we are basing
our Order on this agreement.
It is the Order of the Board that:
1. Petitioner be granted variances from the following
rules for the periods stated:
a) Rule 203(d) (6) (B) (iv) (aa) for its coke oven doors
from January 1, 1974 to December 31, 1974.
b) Rule 203(d) (6) (B) (ii) (bb) for its pushing and
quenching operations for one year from the date of this
order.
C)
Rules 202(b) and 203(b) for its open hearth and
electric furnaces from January 1, 1974 to December 31,
1974.
(d)
Rule 206(d) for its blast furnace gas emission
from January 1, 1974 to December 31, 1974.
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2. That said variance be subject to the following conditions:
a) Within 30 days of the Board’s Order herein, Petitioner
shall submit to the Agency for its approval a program
for the maintenance of all doors and a regular schedule
including work to be done by outside contract.
b) Within 30 days of the Board’s Order herein, Petitioner
and the Agency shall jointly agree on procedures for a
study of door leakage and, thereafter, the Petitioner
shall share with the Agency engineers all available
data as may be required to conduct and complete such a
study.
c) Petitioner shall be required to maintain at all
times an adequate inventory of doors, frames, janths,
and seals so that any defective equipment can be
expeditiously replaced.
d) Petitioner shall continue to experiment with the
use of coke oven doors with vented refractory linings
on the coke side in order to reduce door leakage.
Progress reports including the number of such doors in
use and the effectiveness of the doors shall be included
as part of the quarterly reports required in condition
j) below.
e) Petitioner shall continue to operate and maintain
the integrity of controls with respect to oven charging,
topside off—gas collection system, battery, underfiring,
and coke oven doors in order that air pollution from
these sources does not increase over present levels.
f) Within 10 days of the Board’s Order herein, Petitioner
shall submit to the Agency an acceptable method for
controlling smoke and particulate emissions from coke
pushing, quench car travel and quench tower.
g) Within 30 days of the Board’s Order herein, Petitioner
shall apply to the Agency for a construction permit for
the installation of hoods over the electric arc furnaces.
h) On or before July 1, 1974, Petitioner shall submit
to the Agency an acceptable plan for controlling residual
emissions from its open—hearth furnaces.
1) within 30 days of any changes in operating procedures,
Petitioner shall submit revisions to its Work Rules
which are on file with the Agency.
j) Petitioner shall submit to the Agency a report of
its progress made in implementing the program covered
by the Order of the Board herein at the end of each
calendar quarter.
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—602
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k) All required reports shall be sent to:
Environmental Protection Agency
Division of Air Pollution Control
2200 Churchill Road
Springfield, Illinois 62706
Attn: Control Program Coordinator
1) That with respect to its Variance from Rule 203(d)
(6) (B) (ii) (bb) for its pushing operation, the Petitioner
shall be required to comply with Order No. EPA-5-74-a
of the United States Environmental Protection Agency, a
copy of which is attached to this Joint Recommendation
as Exhibit A and which is hereby incorporated and made
a part of the Joint Recommendation.
m) Within 60 days of the Board’s granting of the
Variance requested by Petitioner, the Petitioner
shall dismiss its appeal of various of the PCB
rules now pending before the Illinois Appellate
Court as number 57478.
3. Within 10 days of this Order, Petitioner will post a
bond with the Environmental Protection Agency signed by the
appropriate officers in the amount of $100,000 to cover the
cost of purchasing, construction, and installation of the
new equipment.
Mr. Henss dissents.
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, here~ycertify the above Opinion and Order were
adopted on the S1~ day of December, 1974 by a vote of
/ ))J~~
() -
Ch~istan L. Noffett, clerk
Illinois Pollution Control Board
14—603