ILL

~NOS

POLLUTION

CONTROL

BOARD

January

10,

1980

IN

THE

MATTER

OF:

R78—10

PARTICULATE

EMISSIONS

FROM STEEL

MILLS

(Revisions

to

Rule

203(d)

of Chapter

2)

OPINION

OF

THE

BOARD

(by

Mr.

Goodman):

The Clean Air Act Amendments of 1977,

Public Law No.

95—95,

amending the Federal Clean Air

Act,

42 U.S.C.

§7401 et

seq.,

imposed certain ne~requirements on the State of Illinois.

Section 172 of the Clean Air Act requires that Illinois provide

for the attainment of the National Ambient Air Quality Stan-

dard

(NAAQS)

for total suspended particulate

(TSP) by December

31,

1982.

The provisions

for attainment are to be included in

the State Implementation Plan

(SIP),

which must

“contain emis-

sion limitations,

schedules

of compliance,

and other such

measures

as may be necessary....” Clean Air Act,

§172(b)(8).

Such SIP limitations,

schedules and measures will be contained

primarily

in the Board’s Air Pollution Control Regulations.

The regulatory amendments

made

in this proceeding will aid in

fulfilling

the mandates of

§172.

Pursuant

to the 1977 Clean Air Act Amendments,

the Illi-

nois Environmental Protection Agency

(Agency) reevaluated the

SIP to determine which portions should he amended in order

to

attain and maintain NAAQS for all pollutants.

After identify-

ing geographical

areas which are nonattainment for TSP levels,

the Agency determined which sources were contributing

to high

TSP levels.

The Agency

found that

the

highest monitored TSP

levels were generally

located

in the vicinity

of

steel mills

(R.6).

Hence,

the Agency proposed amendments

to the Board’s

regulations covering particulate emissions from steel manufac-

turing processes.

*

On September

5,

1978,

the Agency filed

a proposal to

amend Rule 203(d) of the Ai.r Pollution Control Regulations

(Chapter 2 of the Board’s

Rules and Regulations).

The Board

docketed the proposal as R78—i0

and

ordered hearings set.

Agency revisions

to its proposal were published in the Board’s

The Board acknowledges the assistance of Carolyn

S.

HeSSe,

Technical Assistant,

and Ken F

Kirkpatrick,

Administrative

Assistant,

in the drafting of

this Opinion,

and the assis-

tance of Roberta Levinson in serving as Hearing Officer.

37—261

---

—2—

Environmental Register Numbers

183 and 191.

Public hearings

were held in the following locations:

October

31,

1978

Edwardsville

November

8,

1978

Chicago

December

11,

1978

Chicago

December 12,

1978

Chicago

February

14,

1979

Chicago

March

6,

1979

Chicago

March

13,

1979

Chicago

Pursuant to Public Act No.

80-1218, Ill.Rev.Stat.,

ch.

96 1/2,

§7401 et seq.,

the Illinois Institute of Natural

Resources

on March

28,

1979,

filed IINR Doc.

No.

79/06, The

Economic Impact of Proposed Regulations

to Reduce Particulate

Emissions from Steel Mills and Industrial Fugitive Sources.

Hearings on the economic impact of the proposed regulations

were held

in the following locations:

May

3,

1979

Ogleshy

May

4,

1979

Chicago

May

16,

1979

Belleville

May

17,

1979

Springfield

On March

29,

1979,

the Board proposed

an.

Interim Order to

meet the federal deadline

for submittal

of SIP revisions pur-

suant to the Clean Air Act.

On June

22,

1979,

the Board pro-

posed

a Final Draft Order and published

it in the Illinois

____

on July 20,

1r)79, pursuant to the Illinois Adminis-

trative Procedures

Act,

Ili.Rev.Stat.,

ch.

127,

§1001 et

~

The public comment period ended on September

4,

1979.

On

September

6,

1979,

the Board adopted a Final Order

in this

proceeding.

This Opinion supports that Order.

EXISTING AIR QUALITY

The Agency submitted information on total suspended par-

ticulate

(TSP)

monitoring and modeling studies which showed

that high ambient

levels of TSP are associated with steel

mills.

The highest measured TSP levels

in the state occur

near steel mills when there are light winds from the direction

of the mills.

Chemical analyses

of

the monitoring

samples

indicate the presence of high

levels of iron

(R.21*).

The sam-

ples also show TSP concentrations more than twice the National

*

Citations

to page numbers

in transcripts from the substan-

tive hearings are designated with the letter

“R”.

After

this proceeding and R78-11 and R79-3 were consolidated, the

transcript pagination started again with the number

1.

Citations to transcripts

from the

last four hearings are des-

ignated with the letter

“S”.

When R78—10,

R78—l1,

and R79—3 were consolidated, the

37—262

---

—3—

Ambient Air Quality Standard (Ex.i/2).

Consequently, the Board

agrees with the Agency’s conclusion that particulate emissions

from

steel mills must he reduced

from their current

levels.

RULE

BY

RULE DESCRIPTION

The

Board’s

Final

Order

i.n

this

matter

is very similar

to the March

8,

1979 regulatory proposal

(Ex.1/53) developed

by the cooperative efforts of the Agency and representatives

of the steel industry.

The order reflects

a middle ground

between the original proposals

submitted by

them.

The proposal

presented at the first hearing by the Agency

is Exhibit 1/1.

A revised proposal was offered by the Agency on November

8,

1978

(Ex.1/7).

Interlake,

Inc.,

with the support of the steel

industry,

presented

its proposal on December 11, 1978

(Ex.1/15).

The rules were renumbered

in the Order

for the sake of

clarity.

Some of the rules are self—explanatory and need no

additional comments.

The following

is a rule by rule descrip-

tion of the Final Order.

203(d)(5)(A) Beehive Coke Ovens

This rule

is the same

as the previous rule and constitutes

a general

prohibition against the use of beehive coke ovens.

203(d)(5)(B) By—Product Coke Plants

(i) Exemption

This

rule

exempts

by—product

coke

plants

from the visible

emission standards and limitations set forth in

Rule

202.

(ii) Charging

Visible particulate emissions during coke oven charging

are limited to 170 seconds totaled over five consecutive oven

charges.

An exception

is allowed for existing five—meter cOke

batteries having three charging ports; emissions from them shall

not exceed 200 seconds totaled over five consecutive charges.

records

of these three proceedings were marked as group

Exhibits

1,

2 and

3

in the consolidated

record, respective-

ly.

The following notation

is used to refer to specific

exhibits:

Ex.

(group exhibit number)/(exhibit number as

identified before consolidation of records).

For example,

“Ex.1/2” refers to the document that was admitted as Exhibit

2 in the R78—10 record before consolidation.

“Ex.5” refers

to Exhibit

5 of the consolidated record and is part of the

record in all three proceedings.

37—263

---

Coke oven charging was deécribed in detail by several

witnesses (R.162—177, 340—387, 694—716,

730—732, 751—755).

During hearing, there was much testimony on the achievability

of various

time

limits on the duration of visible emissions.

The Agency originally pràposed that visible emissions be

limited to 125 seconds per five consecutive oven charges and

presented data derived from several exemplary coke ovens to

support their proposal.

Mr. Hopkins of the U.

S. EPA

believed

that stage charging and good work practices can achieve a 125

second emission limitation

(R.246).

The City of Chicago pre-

sented data on the coke ovens in Chicago which showed that

the

ovens could meet the 125-second limit.

The City urged

that a.

more stringent limitation be adopted.

Industry, on the other hand, testified that it would be

impossible to meet the 125-second limitation on a day—in, day-

out basis

(R.631).

Although they could

meet

the 125—second

limitation part of the time, they advocated adoption of a

longer

limitation

to

allow

a

cushion

in

the

event

of

malfunc-

tion or operator problems

(R.755).

The exemplary coke ovens

described first by the U.S. EPA witnesses have variations in

their charging times caused by malfunctions which increase

the charging

time,

such as misalignment of the larry car and

charging hold, a closed

damper

bet~ceenthe off-take pipe and

collector

main,

improper

seating or nonuse of the

jumper

pipe,

and abnormal operations resulting from extremely cold weather

(R.627).

Consequently, industry proposed that visible emissions

from coke oven charging be limited to 2 seconds

per

ton of

coal charged.

Since most of the four meter coke batteries in

Illinois charge approximately 17 tons of coal per charge, this

calculates to 170 seconds totaled over five consecutive oven

charges.

The coke oven battery at Wisconsin Steel is a five—

meter-high battery and takes a charge of approximately 28 tons

of coal

(R.697).

Industry’s original proposal would have

allowed Wisconsin Steel’s coke oven charging limitation to be

280 seconds totaled over five consecutive oven chargeb (R.714).

However, information in the record suggests that Wisconsin

Steel

can

meet

a

200

second

limitation

without

having

to

take

extraordinary

measures

(R.1169).

The

Board

has determined that a limitation of 170 seconds

of visible emissions during five consecutive oven charges

(with

an exception

o~f

200 seconds for existing five

rieter

batteries

with three charging ports)

.

is a reasonable limitation.

230).

steel mills will be able to comply with this limitation.

determining compliance with the coke oven charging limitation,

the Board does

not

intend that mere wisps of smoke be included;

37—264

---

—5—

(iii) Pushing

For the most part,

this Rule

is self—explanatory.

Mobile

and stationary hoods are to he used to control

coke pushing

emissions.

Sources are allowed the option of using either

stationary or closely hooded mobile particulate collection

systems.

The coke side sheds

at Wisconsin’s and Republic’s

facilities are examples of stationary

systems

(R,888).

Granite City Steel has two closely hooded mobile systems

which were described at hearing

(R.886—888).

Particulate

control equipment in the latter type of system

is allowed

to emit a higher concentration of particulate matter

(0.06

gr/dscf) than the former

(0.03 gr/dscf),

since this system

exposes

less ambient air to the emissions and,

consequently,.

a smaller total volume of air needs to be collected.

This

volume of air contains

a higher concentration of particulate

matter than the volume of air collected by a stationary system.

Hence,

the

two

systems are essentially equivalent

(R.893—894).

The phrase

“shall he designed to capture” is used instead

of the phrase

“shall capture” because

of difficulties

in quan-

tifying actual capture efficiencies

(R.399).

It is easier to

design a piece of equipment to this

standard of performance

than to determine

if

it achieves this standard.

(iii) Coke Oven Doors

Coke oven doors

leak when the door

is not sealed against

the jamb.

Leaks can be minimized by maintenance procedures

such as properly cleaning the doors and jambs, maintaining

the knife—edge sealing surface on the door,

adjusting the

springs

to increase or decrease the pressure applied to the

knife-edge,

inspecting the knife-edge to insure that

it

is

not damaged and inspecting the

jarnbs to insure that the seat-

ing surface

is adequate and that the jambs are not warped

(R.866).

The Board’s Final Order allows no more than 10

of the

coke oven doors on a given battery

to leak at a given time.

Two witnesses,

one from the U.S.

EPA and the other from the

City of Chicago, testified that

a standard of 10

door leakage

is attainable through good operating and maintenance practices

(R.166).

At least one steel

mill in Illinois has been meeting

that standard (R.571).

The Final Order also requires either

that

a door repair facility exists nearby or that spare doors

are on the premises

so that defective doors can be repaired

and replaced promptly.

(v) Coke Oven Lids

This Rule limits visible emissions from coke oven charging

lids;

no more than 5

of the lids can emit visible emissions

at a given time.

Both industry and Agency representatives

37—265

---

stated that they thought this was, a reasonable standard (R.637)

and was achievable through good work practices (L168).

All

proposals

(Ex.

1/1,

1/7,

1/15, 1/53) submitted to the Board

contained the same limitation as that contained in the’ Final

(vi) Coke Oven Offtake Piping

All of the proposals

(Ex.

1/1, 1/7,

1/15, 1/53) contained

the same wording as found in this Rule.

Visible emissions from’

coke oven offtake piping shall not emerge from more than 10

of

such piping at

any

given time.

This standard is achievable

through proper work practices

(R.168).

Since most of these

emissions

are

wispy,

any

adverse environmental impact from

these is expected to be minimal

(vii) Coke Oven Combustion Stacks

Particulate emissions from coke overcombustion stacks

are not to exceed 0.05 gr/dscf (0.11 g/m

at

dry

standard

conditions).

This limit is achievable by the use of electro-

stati;precipitators or baghouses

(R.208).

The proposals

included provisions which required that an opacity limit be

met

unless

a stack test showed that particulate emissions do

not

exceed 0.05 gr/dscf.

Since the Board feels that determin-

ing compliance with the grain—loading limitation is more

accurate than determing compliance with the opacity limitation,

(viii) Quenching

This

Rule

requires

that

coke

oven

quench

towers

be

equipped

with

grit

arresters

or

equipment

of

comparable

effec-

tiveness

in

reducing

emissions

of

~articulate

matter

which

may

be

entrained

in

the

steam

plume.

Such

control,

technology

represents

the

state

of

the

art

for

controlling particulate

matter from coke quench towers

(R.641).

Because there is a

correlation between quench water quality and particulate emis-

sions (R.195),

the total dissolved solids concentration of the

quench

make-up

water is to be limited to 1500 mg/l.

The

quench water quality itself is not limited to this number

because doing so would require either once—through quenching

or an expensive water treatment system (R.161).

The TOS limit

will allow the steel industry to reduce water pollution by

recycling water in the quench towers.

Sources which use an equivalent method to’control coke

quenching emissions do not need to meet the TOS limit in the

make—up water ‘(S.476—478).

The

Board agrees that if another

method

of coke quenching is developed which is as effective

in reducing particulate emissions,

then its use should be

allowed.

37—266

.

---

—7—

(ix) Work

Rules

This Rule is essentially the same as the old rule,

and

no proposals suggested changing it.

203(d)(5)(C) Sinter Processes

Emission limitations’ from sinter plants are set out in

four separate Rules:

ft)

Breaker

Box

Allowable

particulate

emissions

from

breaker

boxes

are

determined on a process weight rate basis and are not to

exceed the allowable emission rates specified by Rule 203(a).

This limitation is achievable by enclosing the breaker box’

area and exhausting the emissions to a baghouse or venturi

scrubber

(R.131-133).

The wording contained in the final Rule

is

the

same

wording

as

contained

in

the

various

proposals.

(ii) Main Windbox

The record indicates that it is possible to meet the

specified emission limitation for existing main windboxes.

However, Industry pointed out that this Rule would be overly

restrictive for new,

large sinter plants since it might

require emission levels to be less than the level which has

been determined to be the Lowest Achievable Emission Rate

(LAER)

(R.725)

The industry proposal contained a provision

to limit

new

sinter plant sources to 0.03 gr/dscf.

The Board,

however, finds that a determination of LAER should not be done

in this proceeding.

If and when a~steel mill wants to build

a

new

sinter plant, that facility will have to meet whatever

LAn is at that time.

If Rule 203(d)(5)(C)(ii) would be more

restrictive then than LAER, this rule could be modified at that

time

to conform with

LAER

for

that

source.

(iii) Balling Mill Drum, Mixing Drum,

Pug

Mill

and

Cooler

The 30

opacity limitation contained in the Rule is the

same as the one included in the Agency and industry proposals.

The ability of sources to meet this limitation was not disput-

ed at hearing.

,

used to achieve a limitation of 0.03 gr/dscf (0.07 g/m

37—267

---

—8—

203(d)(5)(D)

Blast Furnace Cast Houses

The Rule governing blast furnace cast house emissions

is the same as the rule found in the March

8,

1979 proposal

(Ex.

1/53).

Paragraph

(i) requires that sources meet the

process weight rate

in Rule 203(a).

The original Agency

proposal required equipment which would capture all particulate

emissions.

Industry, on the other hand,

disagreed with this

approach and suggested that sources meet the process weight

rate rule,

Rule 203(a),

if

it is felt that a new rule for con-

trolling cast house emissions is necessary

(R.653).

The Board

finds that

it

is necessary to control blast furnace cast house

emissions because they are a substantial source of TSP and a

large proportion

of these emissions

is

in the respirable size

range

(R.1001).

The measurement method which

is to be used in determining

compliance with paragraph

(i)

is described

in the Rule to avoid

any future ambiguities that may arise regarding which test

should he used.

The record

is clear that determination of

compliance may depend on the test method used.

Paragraph

(ii) provides sources with an alternative for

complying

with the emission limitation

in paragraph

(i) by

operating and maintaining collection equipment designed to

capture

50

of certain emissions from the blast furnace cast

house and by ducting them to particulate collection equipment.

203(d)(5)(E) Basic Oxygen Furnaces

This Rule

limits particulate emissions from operations

associated with basic oxygen furnaces

(BOF’s).

Since hot

metal transfers

to mixers and ladles are major sources

of par-

ticulate emissions

(S.343),

it is important to control these

operations.

During the time of hearing,

one source was

in the

process of

installing a canopy hood system which would comply

with this rule

(R.938).

The Board finds that this rule

is

achievable.

Rule

203(d)(5)(F)

Hot

Metal

Desulfurization

Not

Located

in

the BOF

This Rule

is self—explanatory.

It is the same as the

industry-proposed rule and

is similar to the original Agency-

proposed

rule.

Rule

203(d)(5)(G) Electric Arc Furnaces

The Board’s

final rule limiting particulate emissions

from electric arc furnaces

is the same as the rule contained

37—268

---

—9—

in the March

8,

1979 proposal

(Ex.

1/53).

The rule

is also

very similar to the rules contained in the Agency’s

(Ex.

1/1,

1/7)

and industry’s

(Ex.

1/15) original proposals.

From the

limited

testimony

on

this

topic,

it appears

to the Board that

this standard is an attainable one

(R.759).

203(d)(5)(H) Argon—Oxygen Decarburization Vessels

This

Rule

requires

that

particulate

emissions

from

argon—

oxygen decarburization vessels be limited to the allowable

emission rate specified in,Rule

203(a),

for new sources,

or

Rule 203(b),

for existing sources, whichever

is applicable.

One industry witness testified that these limitations represent

Reasonably Available Control Technology

(R.416).

203(d)(5)(I) Liquid Steel Charginq~

All of the proposed rules

lithiting particulate emissions

from liquid

steel charging were exactly the same.

The Board

finds

that this rule can he met.

203(d)(5)(J) Hot Scarfing Machines

All of the proposed rules were exactly the same.

At

least one source was

in compliance with this rule at the time

of hearing

(R.755).

Based on evidence in the record, the Board

finds that this Rule can be

met.

203(d)(5)(K) Measurement Methods

This Rule specifies the measurement methods

to be used

to determine compliance with Rule 203(d)(5).

The measurement

methods are the same methods that were used to obtain the

data upon which these regulations were first developed

(R.647).~

Compliance Date and Severability

Rule 203(d)(5)(L)

sets forth compliance dates for emis-

sions sources governed by Rule 203(d)(5).

Any source the

construction

or

modification

of

which

begins

after

September

6,

1979

must comply immediately.

Sources constructed or

modified on or prior to this date must fully comply by no later

than December

31,

1982 and,

in addition,

must satisfy certain

incremental emission reduction requirements.

Part D of the Clean Air

Act

mandates that SIP provisions

relating to nonattainment areas “require,

in the interim,

reasonable further progress

(as defined in Section 171(1))

37—269

---

—10—

including such reduction in emissions from existing sources

in

the area as may be obtained through the adoption,

at a minimum,

of reasonably available control technology” Section 172(b)(3).

“Reasonable further progress”

is defined as “annual incremental

reductions

in emissions

of the applicable air pollutant (includ-

ing substantial reductions

in the early years following approval

or promulgation

of plan provisions under this part

DI

and sec-

tion 110(a)(2)(I)

and regular reductions thereafter) which are

sufficient

in the judgment of the Administrator,

to provide for

attainment of the applicable national ambient air quality stan-

dard by

December

31, 1982,”

Section 171(1).

This definition Has been incorporated into Rule 203(d)(5)

(L).

Specifically, the Rule provides that compliance with an

approved Compliance Program and Project Completion Schedule pur-

suant to Rule 104 constitutes compliance with the particulate

emission standards and limitations of Part II

of Chapter

2:

Air Pollution Control Regulations, provided that the Compliance

Program and Project Completion Schedule meet certain require-

ments.

One requirement is that the Compliance Program and

Project Completion Schedule provide for compliance

“as expedi-

tiously as practicable considering what

is economically reason-

able and technically feasible.”

Rule 203(d)(5)(L)(iii)(aa).

In no case may final compliance he projected to a date later

than December 31,

1982.

Another requirement

is that incremental

emission reductions must be achieved by December 31, 1980 and

by December

31,

1981,

unless the Board allows an alternate time-

table not to extend beyond December

31,

1982.

This requirement

ensures that sources will show “reasonable further progress.”

Rule 203(d)(5)(L)(iv) specifies that prior emission limita-

tions and standards shall

be enforceable

in the event that these

regulations are rendered unenforceable due to judicial action.

This will ensure that emissions are continuously

limited by some

enforceable regulation.

Rule

203(d)(5)(M)

states that the provisions

of Rule

203(d)(5)(L)

are

not

severable.

If

any

part

of

203(d)(5)(L)

is

invalidated

or

disapproved

by

the

U.

S.

EPA

or

by

any

court

of

law, then the entire Rule 203(d)(5)(L) must fall.

This

reflects the Board’s view of the interrelated nature of••these

provisions.

Should the entire Rule 203(d)(5)(L) become void,

then the limitations

stated

in prior Rules shall he given

effect.

These provisions reflect the Board’s determination

that changes

to the limitations governing by—product coke

plants are warranted independently of the requirements of Part

D of the Clean Air Act.

Total Plant Compliance,

Limited Life Facilities and Replace-

ment

in Kind

The industry proposal contained three provisions which were

not adopted by the Board.

The first one,

“Total Plant Compliance”

37—270

---

—11—

was not adopted because

it was

an oversimplification of U.S.

EPA’s

“bubble” policy and did not adequately address issues

inherent in the application of the principle of total plant

compliance

(R.953).

For example,

it did not consider that TSP

emissions vary

in particle size distribution and/or chemical

composition; both parameters have varying effects

on health

and ambient air quality

(R.812,

839).

Additionally,

it did

not contemplate a demonstration of attainment of NAAQS

(R.838—

842)

or a requirement of compliance with the existing SIP

(R.841).

Because of these facts,

the Board does not find

industry’s total plant compliance proposal to be appropriate.

Industry’s second provision which the Board did not adopt

concerned

“Limited Life Facilities”.

This provision would have

allowed compliance plans regarding certain operations to consist

of terminating operations by certain dates

(Ex.

1/15).

This

provision is unnecessary because existing variance procedures

can he used to achieve the same result

(R.1086).

The third provision concerned

“Replacement in Kind”.

It

was not adopted because of potential conflicts with the 1977

Clean Air Act Amendments

(R.814).

ECONOMIC IMPACT

The Illinois Institute of Natural Resources submitted a

document to the Board entitled The Economic Impact of Proposed

Regulations to Reduce Particulate Emissions from Steel Mills

and Industrial Fugitive Sources,

IINR Doc. No.

79/06 (here-

after “Study”)

(Ex..6).

Control costs for the steel

industry

set forth in the Study were provided by certain steel

companies

to the Illinois State Chamber

of Commerce

(S.457).

Benefits

were monetized based on modeling data provided by the Agency

(Ex.6,

p.3; S.299).

Order—of—magnitude accuracy was claimed

(Ex.6,

p.4; S.8).

The Study does not provide a precise presentation of the

control costs attributable to R78—10.

First,

the Study’s

best estimate of direct costs

(Ex.15) includes certain costs

fOr controls which would be necessary under the previous rules

(S.67-69).

That

is, the Study does not present an incremental

analysis

of

cost

differences

between

the

prior

regulations

and

R78-10.

Secondly,

the

Study

presents

costs

which

were

not

measured by the authors;

further the authors were unable to

specify what type of equipment might be installed as a result

of

this

proposed

rulemaking

(S,457).

Such constraints limit

the

usefulness

of

the

Study’s cost estimates.

For example,

the Study authors’ best estimate of annual direct costs to the

steel

industry

is

$38 million

(Ex.15).

However,

this estimate

includes

$21 million

for reverse osmosis water treatment

systems which are not required by the Rule as adopted.

The

remaining

$17 million includes some coke oven controls which

37—271

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—12—

would have been necessary under the previous rules

(5.286;

S. 458).

Somewhat more useful

is Exhibit

14,

which provides esti-

mates

of costs

of specific control equipment.

These estimates,

provided by the Illinois State Chamber of Commerce, were

in

part

supported

by

an

independent

literature

review

(S.288-293).

Again,

the

two

caveats

mentioned

above

apply.

In

addition,

Exhibit 14 pertains to the Board’s

Interim Order

of March

29,

1979, not its Final Order; this means that certain items

included

in Ex.14,

e.g.,

a water treatment plant for coke

quench

water,

may

not

he

installed.

The

Study

also

estimated

benefits

due

to

decreased

ambient

concentrations

of

particulate

matter.

The

estimate

was

based

on

Agency

modeling

results,

population

estimates,

and damage coefficients.

The damage coefficients translate

ambient concentrations

of particulate matter into monetary

estimations

of

morbidity,

mortality,

and

materials

damage

attributable

to

the

particulates.

These monetary estimates

are very rough approximations

of benefits.

However, the dis-

cussion of the development of the damage coefficients was

useful

in pointing out the relative impact among morbidity,

mortality

and

materials

damage.

Damages

due

to

soiling

are

a

significant

part

of

the

damage coefficients

(Ex.6, p.21;

Ex.6,

App.B,

App.C).

Some

of

the

testimony

offered

by

specific

steel

companies

must

be

viewed

in

light

of

its context.

Much of the testimony

related

to

early

proposals

or

preexisting

rules

rather

than

to

the

Final

Order.

Examples

include

cost

estimates

for

total

blast

furnace

cast

house

evacuation

systems

(R.579),

once—

through

quenching

(S,161;

S.500),

and modifications to meet a

125 seconds/five consecutive charges rule

(R.495).

The overall control strategy mandated by R78—10 will

redirect control expenditures.

This control

strategy repre-

sents

an economically reasonable approach to obtaining emis-

sion reductions necessary

to meet the NAAQS for TSP in the

nonattainment areas of the State.

IMPACT ON HEALTH

In

an

attempt

to

assess the improvements in health which

would occur as a result of compliance with Rule 203(d) (5),

the

Study

authors

made

estimates

using

Agency

data

on

predicted

improvements

in air quality

(S.87).

Since very little infor-

mation exists in the literature which quantifies

a relation—

ship between exposure to particulate matter and the incidence

of disease, any estimates on improvement

in health are rough

estimates.

Part

of

the problem of estimating health effects

is due to the fact that different sizes and different chemical

37—272

---

-13—

compositions

of particulate matter have different impacts.

For example,

small particulates

in the size range of 0.5

to

2.0 micrometers are more dangerous

to

human

health

than

larger

particulates

(S.10).

Many

of

the sources of particulates

covered

by

this

Regulation

emit

respirable-size

particulate

matter

(R.78—83,

123-125,

837)

and will impact on health.

It

has

also

been

found

that

exposure

to

coke

oven

emissions

is associated with increased rates

of cancer

(R.908,

S.319,

Ex.7(a) and

(b)).

Consequently, the Board agrees with the

Study

authors’

conclusions

that,

although

it

is

not

possible

to

reliably

quantify

improvements

in

human

health,

“control-

ling

air

pollution

will

decrease

disease

and its concomitant

financial burden”

(Ex.6,

p.11).

CONCL US ION

The Clean Air Act Amendments

of

1977 specified strict

requirements

for

the

contents

of

state

SIP’s.

Failure

to

comply

with

those

requirements

could

drastically

disrupt

the

economy

of

the State of

Illinois.

This

rulemaking

will

help

prevent any such disruption, while improving the health and

well being of the people of the State of Illinois, by facili-

tating the attainment of the NAAQS for TSP.

This

Opinion

supports

the

Order

of

September

6,

1979.

Mr.

Werner

dissents.

I,

Christan

L.

Moffett,

Clerk

of

the

Illinois

Pollution

Contro~Board,

he eby certify the above Opinion was adopted on

the

j

day of

________________,

1979 by

a vote

of

3~

I

Christan L.

Moffe

~lerk

Illinois Pollution

ontrol Board

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