ILLINOIS POLLUTION CONTROL BOARD
December
2,
1982
GRANITE CITY STEEL DIVISION
OF NATIONAL STEEL CORPORATION,
Petitioner,
v.
)
PCB 82—109
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
MR.
RANDALL ROBERTSON AND MR. ERIC ROBERTSON, LUEDERS, ROBERTSON
& KONZEN, APPEARED ON BEHALF OF PETITIONER;
MS.
HEIDI
E. HANSON, DIVISION OF AIR POLLUTION CONTROL, APPEARED
ON BEHALF
OF RESPONDENT.
OPINION AND ORDER OF THE BOARD
(by
I.
G. Goodman):
On September
3,
1982 Granite City Steel Division of National
Steel Corporation (GCS)
filed this petition for variance from
Rule 203(d)(5)(B)(iii) of Chapter
2, Air Pollution,
to allow
intermittent, uncontrolled coke pushing from two existing coke
ovens during the rebuilding of a third oven.
Hearing was held
on October 26,
1982.
Both citizen testimony and public comments
have been received by the Board in this matter.
This situation is substantially similar to a previous request
for variance by GCS in PCB 81—44.
In that case the Board granted
variance for reconstruction of one of the other coke ovens.
The
increase
in emissions
in this proposed variance would be approx-
imately twice that of the variance granted
in PCB 81—44 since two
existing coke ovens will be
in operation rather than one.
Since
the basic situation is the same as that delineated in the June 25,
1981 Board Opinion in PCB 81—44, the Board shall not reiterate the
details, but rather shall incorporate that previous Opinion by
reference.
This situation results from the continuing project by GCS
to rebuild three coke oven batteries.
During the first phase of
construction involving renovation of Battery “C”,
the enclosed
pushing emissions control systems car serving Batteries
“A” and
“B” will be unable to service the last fourteen coke ovens.
These fourteen coke ovens, however,
can be serviced by the uncon-
trolled conventional pushing systems car resulting in increased
particulate emissions.
Failure to use these fourteen ovens in
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their normal sequence would result in physical damage to the bat-
teries.
GCS estimates that the uncontrolled pushing will occur
on approximately 176 calendar days intermittently over a period
of approximately two years
(R.
7),
It is estimated that uncon-
trolled pushing will definitely take place 53 days at 24 hours
per day, with a possibility of an additional
60 days at 24 hours
per day, and another 63 days during daylight hours only.
The Illinois Environmental Protection Agency (Agency) esti-
mates that the grant of the proposed variance would create an
additional
30 tons per year of particulate emissions.
For pur-
poses of comparison, this is approximately one—half of the total
emissions allowed Battery “C” when it is in operation.
The
facility is in a Non—attainment Area for particulate matter with
monitoring data showing consistent violations of Rule 307 of
Chapter 2,
Ambient Air Quality Standards.
The Agency has received six objections to this variance
petition.
These objectors are concerned mainly with the possi-
bility of carcinogenic emissions which might threaten health
and the enjoyment of property.
As the Agency points out
in
its Recommendation,
however, the carcinogens are contained in
those coke oven emissions which are driven off during the coking
process.
Emissions which occur during the pushing process, which
is subsequent to the coking process,
are thought to be less car-
cinogenic than other coke oven process emissions.
At hearing,
thirteen of the fourteen citizens testifying were in favor of the
proposed variance citing
for the most part their interest in the
construction jobs and future increased employment at the plant.
GCS alleges that should the Board refuse to grant the pro-
posed variance, it must either risk damaging its existing coke
oven batteries or forego rebuilding Battery “C”.
If it is unable
to rebuild Battery “C”, GCS alleges it will be
forced to continue
to purchase part of its coke requirement from “foreign countries.”
The estimated cost of the proposed construction is $70 million and
it will involve 150 to 250 construction workers over the period of
construction.
Upon completion,
Battery “C” will require the perma-
nent employment of an additional
43 people at the facility.
All
the citizens and groups who support the petition for variance cite
the present economic situation and the need for jobs in the area.
The Agency recommends that variance be granted subject to
certain conditions citing the hardship to the public due to the
loss of both construction and permanent jobs in Illinois balanced
against the minimal and temporary environmental impact.
The Board
agrees.
Although there is no question that the operation of
Batteries “A” and
“B” without the use of the enclosed pushing
emissions control system car will further burden an area where
the primary particulate Air Quality Standard is already being
exceeded, that burden is indeed minimal and probably contains
the least troublesome of the plant’s emissions.
In addition,
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3
as the Agency points out in its Recommendation,
the total emis-
sions caused by the variance would constitute less than one—half
the emissions now allowed Battery “C” when it is in operation.
It is also noted that ultimately the renovation of Battery “C”
will result in a permanent reduction in the amount of particu—
lates contributed by GCS to the area.
The Board shall therefore
grant the variance requested under certain conditions.
To be
consistent with the prior variance granted in PCB 81—44,
the
Board shall grant variance from Rules 102,
203(d)(5)(B)(iii)
and 307 of Chapter 2,
Air Pollution.
This Opinion constitutes the finding of facts and conclu-
sions of law of the Board in this matter.
ORDER
Granite City Steel Division of National Steel Corporation
is hereby granted variance from Rules 102,
203(d)(5)(B)(iii)
and 307 of Chapter
2 of the Board’s Regulations for pushing
operations related to Batteries “A” and
“B” at its Granite City,
Madison County, Illinois facility through December
1,
1984,
subject to the following conditions:
1.
Granite City Steel Division of National Steel Corporation
shall adhere to the construction schedule contained in
Exhibit A,
Table
1 in its variance petition filed September
3,
1982, which schedule is hereby incorporated by reference
as if fully set forth herein.
2.
Granite City Steel Division of National Steel Corporation
shall give notice of the start and finish of each of the
five construction phases at least
five days prior to their
occurrence and shall immediately give notice of any occur-
rence which might affect its ability to comply with the
schedule incorporated in paragraph 1
above.
Such notice
shall be sent to the Illinois Environmental Protection
Agency,
ll5A West Main Street, Collinsville, IL
62234.
3.
Within forty—five days of the date of this Order, Peti-
tioner shall execute and forward to the Illinois Environ-
mental Protection Agency,
2200 Churchill Road,
Springfield,
Illinois 62706,
a Certificate of Acceptance and Agreement
to be bound to all terms and conditions of this variance.
This forty—five day period shall be held in abeyance for
any period this matter
is being appealed.
The form of the
certificate
shall be as follows:
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4
CERTIFICATE
I,
(We),
,
having read
the Order of the Illinois Pollution Control Board in PCB 82-109,
dated _______________________________, understand and accept the
said Order, realizing that such acceptance
renders all terms and
conditions thereto binding and enforceable.
Petitioner
By:
Authorized Agent
Title
Date
IT IS SO ORDERED.
Board Member
J.
Dumelle concurred.
I,
Christari L.
Moffet, Clerk of the Illinois Pollution
Control Board, hereby ~~rtify that~theabove Opinion and Order
was adopted onAthe
c~k”
day of
__________________,
1982
by a vote of
~-~)
Illinois Pollution
Ltrol Board
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