ILLINOIS POLLUTION CONTROL BOARD
September 25,
1986
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
35 Iii. Adm. Code 212.443
)
R85-33
By-Product Coke Plants
)
ADOPTED RULE.
FINAL ORDER.
OPINION AND ORDER OF THE BOARD
(by J. Theodore Meyer):
This matter comes before the Board upon
a December
19,
1985
proposal for regulatory change filed by the Illinois
Environmental Protection Agency (Agency), Citizens for
a Better
Environment
(CBE) and various steel companies.
This proposal
represents
the proposed settlement arising out of
a lawsuit filed
by CBE
in Federal District Court against the Agency and various
steel companies for failure to revise Illinois’ coke-battery and
casthouse rules.
First Notice was adopted on January 23,
1986
and published at
10 Illinois Register 3731, February
21,
1986.
Hearings were held on March 10 and 11,
1986,
in Chicago and
Granite City, Illinois, respectively.
On May 8,
1986,
the
Department of Energy and Natural Resources issued a Negative
Declaration for this proceeding stating that the net economic
impact of the regulation
is favorable and the cost of compliance
are small or are borne entirely by the proponents
of the
regulations, and the Economic and Technical Advisory Committee
concurred with this finding at its June 20,
1986,
meeting.
Second Notice was adopted on June
11,
1986, and submitted to the
Joint Committee on Administrative Rules
(JCAR).
JCAR determined
that no objection would
be issued to this proposed rulemaking
provided certain modifications were made
to the rules
to enhance
clarity.
The Board has agreed to make these modifications and
they appear in the Final Order.
The following is
a brief history
of
this
proceeding.
In 1979,
the Agency submitted to USEPA proposed revisions to
Illinois’
State Implementation Plan (SIP) which included rules
governing coke oven charging and pushing operations.
These rules
are presently codified at 35 Ill.
Adin.
Code 212.443(b) and (c).
Both of these rules were disapproved for inclusion in
Illinois’
SIP by USEPA.
In connection with this disapproval, CBE sued the
Administrator of USEPA in federal court
(CBE v. Thomas,
No. 80-C-
0003).
As
a result of settlement negotiations arising out of
that suit,
the Agency,
CBE and various steel companies have
proposed coke oven charging and pushing rules for adoption by the
Board in lieu of federal promulgation of these rules.
An
explanation of these rules follows.
72-451
-2-
The joint regulatory proposal submitted by the Agency, CBE
and various steel companies includes emission limitations
as well
as inspection and compliance procedures for coke oven charging
and pushing operations.
(Ri
p. i2L.~ There are currently three
coke plants operating in Illinois to which these rules are
applicable;
Interlake,
Inc., LTV Steel and Granite City Steel
Corporation,
a Division of National Steel Corporation.
(Id.)
Charging Operations
Section 212.443(b)
regulates coke oven charging operations
and is divided into two subsections.
Section 212.443(b)(i)
establishes an opacity limitation applicable to fugitive
emissions during charging operations and Section 212.443(b)(2)
establishes
a particulate matter emission limitation and an
opacity limitation applicable to charging emissions control
equipment.
Section 212.443(b)(1)
Mr. Anton Telford of the Agency testified that approximately
1200 pounds of steel coke is needed to make one ton of blast
furnace iron.
In order to make steel coke,
the proper blend of
coals must be introduced
(i.e., charged)
into the coke oven
in
which the coal is converted to coke by baking the coal at
approximately 24000
F in the complete absence of air during
a
period of about
16 hours.
(Ri pp.
16-17).
In general,
a charge can be defined as constituting the
transfer of the blended coal into the coke oven from the larry
car,
the larry car being the equipment used to bring the coal
from the coal hopper into
a position on top of the oven.
Section
212.443(b)(1)(A)
defines
a charging operation as the time from
the first introduction of coal into the first charge port of the
coke oven via the larry car to the replacement of the final
charge port lid.
Mr. Telford testified that the addition of
a
definition of charging operations to the Illinois regulations
remedies
a deficiency which was cited by the USEPA as one of the
bases for disapproval of the present charging rule.
(Ri p.
19).
The charging operation itself involves
a precise sequence of
events called stage charging.
Stage charging involves the
charging of a coke oven from one larry car at
a time while
simultaneou’sly exhausting the coke oven gas, organic material,
water and tar released from the coke oven being charged by
a
*There were two separate hearings conducted in this proceeding.
The March
10,
1986 hearing transcripts will be designated
“Ri”
and the March 11,
1986 hearing transcript will be designated
“R2”.
72-452
—3—
steam jet into one or two large pipes which conduct the gases and
other materials to the by-products plant.
The total charging
time is normally four to five minutes, and the leakage of visible
particulate emissions to the ambient air during this time is
subject to the charging rule.
(Ri p.
17).
Section 212.443(b)(i)(A) provides that visible particulate
emissions from coke oven charging operations shall not exceed a
total of 125 seconds over
5 consecutive charges with the
exception that one charge out of any
20 consecutive charges may
be deemed
an uncountable charge.
Under this procedure,
a total
of at least
6 charges must be observed and recorded and another
charge may not be disregarded until
after the 21st charge has
been completed.
(Ri.
p.
20).
The Agency states that
it is their
belief that this standard constitutes reasonably available
control technology (RACT) for coke oven charging operations in
Illinois
(Ri p.
21).
This opinion
is based on the fact that
IJSEPA stated
in its final rulemaking on the present charging rule
that such
a standard constitutes
RACT.
(Ri pp.
21-22).
Section 212.443(b)(1)(B) establishes the procedures for
determining compliance with the visible emissions limitation for
charging operations.
Mr. Cezary Krzynowski of the Agency
testified that the addition of procedures for determining
compliance with the visible emissions limitation remedies another
deficiency which was cited by the USEPA as one of the bases for
its disapproval of the present charging rule.
(RI p. 46).
The inspection procedures of Section 212.443(b)(1)(B)
require that
a qualified observer who is certified to read
visible emissions pursuant to 35 Ill. Adm. Code 230.Appendix A
(40 CFR 60, Appendix A, Method
9) position himself on the topside
of the coke oven battery with
a cumulative stopwatch so that an
unobstructed view can be obtained of the charging larry car and
charging ports and that the visible emissions
from these sources
can be timed during a charge.
The qualified observer then
determines and records
the total number of seconds of visible
emissions timed for that oven and battery,
including the start
and stop time for the charging operation.
This procedure
continues for five consecutive charges unless the observer deems
one an uncountable charge
in which case the procedure would
continue until at least five consecutive charges are observed.
(Ri pp. 46—47).
212.443(b) (2)
Section 212.443(b)(2) establishes standards applicable to
emissions from charging emissions control equipment.
Mr. Teiford
testified that the Agency is only aware of one coke plant in
Illinois which uses control equipment to capture charging
emissions and that facility
is operated by LTV Steel; LTV’s
charging emissions control equipment operates by exhausting the
72-453
—4—
coke oven through the larry car, the larry car fugitive gas
igniter and subsequently to a stationary venturi scrubber.
Section 212.443(b)(2)(A) provides that
a mass emission
limitation oE 0.020 grains per dry standard cubic foot be
applicable
to particulate matter emissions from charging
emissions control equipment.
Compliance with this mass emission
limitation shall be determined pursuant to the procedures
set out
in
35 Ill. Adm. Code 230, Appendix A, Methods
1 through
5 which
are the procedures specified for stack testing.
Section 212.443(b)(2)(B) provides that the opacity of
emissions from charging emissions control equipment shall not
exceed an average of
20,
averaging the total number of readings
taken at
15-second intervals during a charge.
Compliance with
this limitation shall be determined pursuant to 35 Iii. Adm. Code
230, Appendix A
(40 CFR 60, Appendix A, Method 9) except for the
number of
readings or observations required.
Mr. Krzynowski
testified that this exception for the number of readings required
refers to the requirement
in Section 2.4 of Method
9 that a
minimum of 24 observations be made and that opacity be determined
as an average of 24 consecutive observations recorded at 15-
second intervals.
This exception is necessitated by the fact
that
a charge generally lasts less than 6 minutes and the intent
of the regulation is that compliance with the 20
opacity
standard be determined as an average of the total number of
readings taken at 15-second intervals over the duration of
a
charge.
(Ri. pp. 48—49).
Lastly,
Section 2i2.443(b)(2)(C) requires that the opacity
readings from the charging emissions control equipment be taken
concurrently with the observations of fugitive particulate
matter.
Two qualified observers
shall take these readings.
Pushing Operations
Section 212.443(c)
regulates coke oven pushing operations
and is divided into two subsections.
Section 212.443(c)(1)
establishes an opacity limitation applicable to fugitive
emissions during pushing operations and Section 212.443(c) (2)
establishes
a particulate matter and an opacity limitation
applicable to pushing emissions control equipment.
Section 212.443(c)(1)
Mr. Teiford also described what constitutes
a “push.”
He
testified that after the coal has cooked sufficiently,
the end
doors on the coke ovens are removed and the cooked coal
is pushed
out of the oven by
a pushing machine.
The cooked coal which is
now coke exits the coke oven on the opposite side from the
pushing machine through a piece of duct called
a coke guide which
interfaces with the oven on one side and the coke receiver car on
72-454
—5-
the other
side and falls into
a hooded receiver car.
After the
coke falls into the receiver car,
which is on
a track,
the car
moves down to the quench tower or quench device at which the coke
is cooled with water to reduce its temperature from 2,000°Fto
approximately 400°F.
A push takes about one and a half minutes
from the time
the coke falls into the receiver or until the car
enters the quench tower or quench device.
(Ri pp.
24-25).
Section 212.443(c)(1)(A) provides that emissions of fugitive
particulate matter from pushing operations
shall not exceed an
average of 20
opacity for four consecutive pushes considering
the highest average of six consecutive readings
in each push.
Mr. Teiford testified that this procedure allows
a brief
surge of
visible particulate emissions during the pushing of the coke into
the receiver car to be mitigated by less emissions during the
movement of
the receiver car to the quenching tower or device.
(Ri pp. 26-27).
Mr. Telford also testified that all of the coke
facilities in Illinois can meet this standard and that this
standard constitutes RACT.
He based this latter conclusion on
the fact that USEPA stated
in its final rulemaking on the Indiana
Steel State Implementation Plan that such an opacity standard
constitutes
RACT.
(Ri p.
27).
Section 212.443(c)(1)(B)
sets forth the procedures to be
followed by the qualified observer when conducting opacity
readings of fugitive emissions during pushing operations.
The
procedures account for the fact that opacity readings are taken
over the duration
of
a push including readings as the receiving
car travels
to the quench tower or device by requiring that the
qualified observer position himself so that the entire pushing
operation can be observed.
The procedures also require that
emissions from the receiving car and associated equipment,
the
coke oven and the stand pipe on the coke side of the oven being
pushed be read.
(Ri p.
52).
The observation procedures are to
be conducted pursuant to (40 CFR
60, Appendix A, Method 9) except
that Section 2.5 for data reduction shall be used.
This
exception to Method 9 procedures is necessary to account for the
fact that a push lasts less than six minutes.
(Ri
p. 53).
Section 212.443(c)(2)
Section 212.443(c)(2) establishes standards applicable to
emissions from pushing emissions control equipment.
Mr. Telford
testified that two types
of pushing emissions control systems are
in use in Illinois,
a mobile hood receiver connected to a
stationary emissions collector and
a mobile hooded receiver car
equipped with a mobile emissions collector.
(Ri p.
33).
Section 212.443 (c)(2)(A) establishes a mass emission
limitations of 0.040 pounds
of particulate matter per ton of coke
pushed.
Mr. Telford testified that all the coke facilities in
Illinois are capable of meeting this standard and such standard
72-455
—6-
constitutes RACT.
(Ri pp. 35-36).
Be based this latter
conclusion on the fact that for those systems using mobile
collectors, the standard is identical to the lowest achievable
etnission rate limit currently applicable to
such
a system.
)tlso,
for those systems using stationary collectors,
the Agency
believes that 0.040 pounds of particulates per ton of coke pushed
constitutes
an appropriate RACT limitation since 0.030 pounds of
particulate per ton of coke pushed has been determined to be the
best available control technology for such systems.
(Ri p.
36).
Section 212.443(c)(2)(fl) establishes
an opacity limitation
for the pushing emissions control system.
The rule states that
the opacity from such control equipment shall not exceed 20.
For
a push of less than six minutes, the number of 15-second
readings
shall
be averaged.
Again, Method
9 of 40 CFR 60,
Appendix A governs the observation procedures and Section 2.5 for
data reduction shall not apply for pushes less than six minutes
in duration.
As
a final note, on August 15,
1986, the Board received
JCAR’s formal certification that no objection will be issued on
this rulemaking provided that the Board make some non-substantive
modifications to the rules
as submitted for Second Notice.
The
modifications suggested by JCAR relate to the opacity reading
procedure and the Board has agreed to clarify that all observers
conducting opacity reading be qualified pursuant to 40 CFR 60,
~ppendix P~,Method
9
(35 III. ~dm. Code 230J~ppendixM.
ORDER
The Board hereby adopts the following amendments to 35
Iii.
Adm. Code 212.443:
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE
B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
c:
EMISSION STANDARDS AND LIMITATIONS
FOR STATIONARY SOURCES
PART 212
VISUAL AND PARTICULATE MATTER EMISSIONS
Section 212.443
By-Product Coke Plants
a)
Subpart
B shall not apply
to by-product coke plants.
b)
Charging:
No person
sl’tall
cause
or allow ~he em~ss~on
e? vtsi~lepe~e~e
~
?~om e~’je~ok~
~‘#a~
e1~argingepera~ionw1’~eneoal ~s ~e~ng eharged~exeept
o
~ot~l e~no ~,torethan ~
seeonds over
5
72-456
—7—
eonseeu~ivesoven ehargesT or in the ease o?
existing
?ive meter eeke bo~erieshaving three ebarging parts~
?or
a total e~r~omere than 2~ seconds ever
5
censeetitive even ehargesT
1)
Uncaptured Emissions
A)
No person
shall cause or allow the emission of
visible particulate matter from any coke oven
charging operation, from the introduction of
coal into the first charge port,
as indicated
by the first mechanical movement of the coal
feeding mechanism on the larry car,
to the
replacement of the final charge port lid for
more than
a total of
125 seconds over
5
consecutive charges; provided however that
1
charge out of any 20 consecutive charges may
be deemed an uncountable charge
at the option
of the operator.
B)
Compliance with the limitation set forth in
subsection
(A) shall be determined in the
following manner:
i)
Observation of charging emissions shall
be made from any point or points on the
topside
of
a coke oven battery from i~hich
a qualified observer can obtain an
unobstructed view of the charging
operation
ii)
The qualified observer shall time the
visible emissions with
a stopwatch while
observing the charging operation.
Only
emissions from the charge port and any
part
of the larry car shall be timed.
The observation shall commence as soon as
coal is introduced into the first charge
port
as indicated by the first mechanical
movement of the coal feeding mechanism on
the larry car and shall terminate when
the last charge port lid has been
replaced.
Simultaneous emissions from
more than one emission point shall be
timed and recorded
as one emission and
shall not be added individually to the
total time.
iii) The qualified observer shall determine
and record the total number of seconds
that charging emissions are visible
during the charging of coal to the coke
oven.
72-457
-8-
iv)
For each charge observed,
the qualified
observer shall record the total number of
seconds of visible emissions, the clock
time for the initiation and completion of
the chargin~~peration and the battery
identification and oven number.
v)
The qualified observer shall not record
any emissions observed after all charji~g
port lids have been firmly seated
~ollow±ng removal of the larry car, such
as emissions occurring when a lid has
been temporarily removed to permit
spilled coal to be swept into the oven.
Vi)
In the event that observations from a
charge are interrupted the data from the
charge
shall be invalidated and the
qualified observer shall note on his
observation sheet the reason for
invalidating the data.
The qualified
observer shall then resume observation of
the next consecutive charge or charges
and continue until
a set of five charges
has been recorded.
Charges immediately
preceding and following interrupted
observations shall
be considered
consecutive.
2)
Emissions from Control Equipment
A)
Emissions of particulate matter from control
equipment used to capture emissions during
charging shall not exceed 0.046 gm/dscm (0.020
gr/dscf).
Compliance shall
be determined in
accordance with the procedures set forth in
35
Ill. Adm. Code 230.Appendix
A
(40 CFR 60,
Appendix A, Methods 1-5).
B)
The opacity of emissions from control
equipment shall not exceed an average of 20,
averaging the total number of readings
taken.
Opacity readings shall be taken at 15-
second intervals from the introduction of coal
into the first charge port as
indicated by the
first mechanical movement of the coal feeding
mechanism on the larry car to the replacement
of the final charge port lid.
Compliance
shall
be determined
in accordance with
35 Ill.
Adm. Code 230.Appendix A
(40
CFR 60, Appendix
A,
Method 9), except for the number of
readings required.
72-458
—9-
C)
Opacity readings of emissions from control
equipment shall
be taken concurrently with
observations of fugitive particulate matter.
Two_qualified observers shall be required.
3)
qualified observers referenced
in subsection
(b)
shall
be certified pursuant to 35
Iii.
Adtn. Code
230.Appendix A
(40 CFR 60, Appendix A, Method 9).
c)
Pushing:
All coke ?aeilities shall be equipped with
pushing systems with pa
ulate
eemtroi equipment which
shall be designed
to capture at least 90 o?
all
particulate emissions ?rom pushing operationsT
The
particulate control equipment shall be operated end
maintained in
a manner to achieve the design
e??ieieney~ 1?
a stationery hood system is usedT the
particulate emissions ?rom the outlet
e?
~eid
pertieulate control equipment shall net exceed ~0
mg/dsem ~9~03 gr,edse?.~7 1?
a closely hooded mobile
system is used in eenneetion with the operation o?
an
existing coke even battery with the emissions exhausted
directly to the particulate control equipment~the
particulate emissions ?rem the outlet e?
said
particulate control equipment shall net exceed
140
mg’dsem ~0~96 gri’dse?4~
1)
Uncaptured Emissions
A)
Emissions of fugitive particulate matter from
pushing operations shall not exceed an average
of 20
opacity for
4 consecutive pushes
considerin~gthe highest
average of six
consecutive readings in each push.
Opacity
readings shall be taken at 15-second
intervals, beginning from the time the coke
falls into the receiving car or is first
visible as it emerges from the coke guide
whichever occurs earlier, until the receiving
car enters the guench tower or quenching
device.
For
a push of less than
90 seconds
duration,
the actual number of 15-second
readings shall
be averaged.
B)
Opacity readings shall be taken by a qualified
observer located in
a position where the oven
being pushed,
the coke receiving car and the
path to the quench tower are visible.
The
opacity shall
be read as the emissions rise
and_clear_the top of the coke battery gas
mains.
The qualified observer shall record
opacity readings of emissions originating at
72-459
-10-
the receiving car and associated equipment and
the coke oven, including the standpipe on the
coke side of the oven being pushed.
Opacity
readings shall be taken
in accordance with the
procedures
set forth in
35
Ill. Adm. Code 230.
Appendix
A
(40 CFR 60, Appendix A, Method 9),
except that Section 2.5 for data reduction
shall not be used.
The qualified observer
referenced
in this subsection
shall be
certified pursuant to
35 Ill. Adm. Code
230.Appendix A
(40 CFR 60, Appendix A, Method
9).
2)
Emissions from Control Equipment
A)
The~particulateemissions from control
equipment used
to control emissions during
pushing operations
shall not exceed 0.040
pounds per ton of coke pushed.
Compliance
shall be determined
in accordance with the
procedures
set forth in
35 Ill.
Adm. Code 230.
Appendix
A
(40 CFR 60, Appendix A, Methods
1-
5) and shall be based on an arithmetic average
of three runs
(stack tests) and the
calculations shall
be based on the duration of
a push as defined
in subsection (c)(1)(A).
B)
The opacity of emissions from control
equipment used
to control emissions during
pushing operations
shall not exceed 20.
For
a push
of less than six minutes duration, the
actual number of 15-second readings taken
shall be averaged.
Compliance shall be
determined
in accordance with 35 Ill. Adm.
Code 230.Appendix
A
(40 CFR 60, Appendix A,
Method
9),
except that Section 2.5 for data
reduction shall not be used for pushes of less
than six minutes duration.
d)
Coke Oven Doors:
1)
No person shall
cause or allow visible emissions
from more than 10
of all coke oven doors at any
time.
Compliance shall be determined by
a one pass
observation of all coke oven doors on any one
battery.
2)
No person shall cause or allow the operation of
a
coke oven unless there is on the plant premises at
all times
an adequate inventory of spare coke oven
doors and seals and unless there is
a readily
available coke over door repair facility.
72-460
—11—
e)
Coke Oven Lids:
No person shall cause or allow visible
emission from more than 5
of all coke oven lids at any
time.
Compliance shall be determined by
a one pass
observation of all coke oven lids.
f)
Coke Oven Offtake Piping:
No person shall cause or
allow visible emissions from more than 10
of all coke
oven offtake piping at any time.
Compliance shall
be
determined by a one pass observation of all coke oven
ofttake piping.
g)
Coke Oven Combustion Stack:
No person shall
cause or
allow the emission of particulate matter from
a coke
oven combustion stack to exceed
110 mg/dscm (0.05
gr/dscf).
h)
Quenching:
All coke oven quench towers shall be
equipped with grit arrestors or equipment of comparable
effectiveness.
The make-up water shall not directly
include coke by-product plant effluent.
Total dissolved
solids concentrations in the make-up water shall not
exceed 1500 mg/i.
Provided however that the limitations
on the quality of quench make-up water shall not apply
where the operator employs an equivalent method of
control as determined by the Agency.
i)
Work Rules:
No person shall cause or allow the
operation of
a by-product coke plant except in
accordance with operating and maintenance work
rules
approved by the Agency.
IT IS SO ORDERED.
I, Dorothy M. Cunn,
Clerk of the Illinois Pollution Control
Board, hereby certify that the abc~weOpinion and Order was
adopted on the
~7~Z
day of ~
,
1986 by a vote
of
~-O
•
~___
Dorothy
M. Gun4~,Clerk
Illinois Pollution Control Board
72-461
