ILLINOIS POLLUTION CONTROL BOARD

October

20,

1988

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Complainant,

V.

)

PCB 85—38

HECKETT,

a Division of HARSCO

)

CORPORATION,

a Delaware

)

corporation, and ACME STEEL

)

COMPANY,

successor of INTERLAKE,

)

INC.., a Delaware corporation,

)

Respondents..

MR.. JAMES T. HARRINGTON,

ESQ.., OF ROSS AND HARDIES, APPEARED ON

BEHALF OF THE RESPONDENT..

MR. JOSEPH J. ANNUNZIO,

ESQ.., ASSISTANT ATTORNEY GENERAL,

APPEARED ON BEHALF OF THE COMPLAINANT..

OPINION AND ORDER OF THE BOARD

(by

M.. Nardulli):

This matter comes before the Board upon

a complaint filed on

behalf of the Illinois Environmental Protection Agency

(hereinafter “Agency”),

by and through

its attorney, Neil

F..

Hartigan, Attorney General of the State of Illinois,

against

Heckett and Interlake,

Inc.

Interlake,

Inc..

is the predecessor

to Acme Steel Company

(hereinafter

“Acme”)..

The complaint

alleges that Heckett and Acme violated Section 9(c)

of the Act

and 35

Ill..

Adm.. Code Sections 201..l07,

20l..141,

20l..l42 and

212..123(a)..

Hearing on this matter was held on September 16,

1988

in

Chicago,

IL..

At hearing, the parties submitted a Stipulation and

Proposal for Settlement

(Stipulation)..

The Stipulation is

attached and adequately addresses the facts

in this matter..

Accordingly,

this opinion will not contain the customary

discussion of

the

issues..

The Board

notes

that according

to the Stipulation, Acme and

Heckett are not admitting their liability

for violations alleged

in the Complaint..

Also,

the Stipulation states that the Agency

agrees

to issue Heckett a five—year operating permit

for its

entire slag handling operations

consistent with the applicable

terms of the Stipulation..

The operating permit shall become

effective upon

the Board’s entry of

the following order approving

the Stipulation..

93—139

---

—2—

In evaluating this enforcement action and proposed

settlement agreement,

the Board has taken

into consideration all

the facts and circumstances

in light of

the specific criteria

delineated

in Section

33(c)

of the Act and finds the Stipulation

and Proposal

for Settlement acceptable under

35

Ill.

Adm.

Code

103.180.

Accordingly,

the Board orders Acme and Heckett to

comply with the Order

set forth herein.

ORDER

It

is

the Order of the Illinois Pollution Control Board

that:

1)

The Board hereby accepts

the Stipulation and Proposal for

Settlement executed by Acme,

Heckett and the Illinois

Environmental Protection Agency concerning Acme’s

Riverside facility and filed with the Board on March 27,

1985.

The Stipulation and the Proposal for Settlement

is

attached hereto.

2)

Acme and Heckett,

jointly, by certified check

or money

order payable

to the State

of Illinois and designated for

deposit

into the Environmental Protection Trust

Fund,

shall pay the sum of $25,000.00

(Twenty—five thousand

dollars).

The sum shall

be paid within 30 days of the

date the Respondents receive notice of this order.

The

payment shall be mailed

to:

Fiscal Service Division

Illinois Environmental Protection Agency

2200 Churchill Road

Springfield,

IL

62706

3)

The terms

and conditions of the Stipulation and Proposed

Settlement are incorporated into and made

a part of this

Order.

IT IS SO ORDERED.

R.C.

Flemal dissented.

93—140

---

I,

Dorothy M.

Gunn,

Clerk of the Illinois Pollution~Control

Board, hereby certify that the above Opi

ion and Order was

adopted on

______________

day of

_____________________,

1988, by

a vote of

_____________

Dorothy M.~tunn,Clerk

Illinois Pollution Control Board

93—14 1

---

.L),iT

.

lUl

RECEIVED

STATE

OF

ILLINOIS

)

~\f

OCT

I

3

1988

IU

I

ENFORCFMENT

PPQGr

ssjJ~_____

COUNTY

OF

COOK

)

STATE Of

IWNOIS

~uunONcONTROLD~RD

-

BEFORE

THE

POLLUTION

CONTRO!r’~O~D~

STATE

OF

ILLINOIS

Environmental

Protection

~

ILLINQ~SENVIRONMENTAL PROTECTION

)

AGENCY,

)

Complainant,

)

)

•.

V.

)

~CB

85—38

~trE\\JE

HECKETT,

a Division of HARSCO

)

CORPORATION,

a Delaware corporation,

)

and

ACME STEEL

COMPANY,

)

~Yk

~

successor of INTERLAKE,

INC.,,

a

)

Delaware corporation,

)

~

Respondents.

)

STIPULATION OP FACTS

AND PROPOSED SETTLEMENT

Complainant,

the

Illinois Environmental Protection Agency

(“Agency”), by and through its attorney, Neil F.

Hartigan, Attor-

ney General of Illinois, and respondents, Heckett,

a Division of

Harsco Corporation,

a Delaware corporation (“Heckett”) and Acme

Steel Company, successor of Iriterlake,

Inc.,

a Delaware corpora-

tion (“Acme”),

submit

the following Stipulation of Facts and Pro-

posed Settlement.

The parties agree that the statement of facts

contained herein represents

a fair summary of the evidence and

testimony which would be introduced by the parties if

a full

hearing were held.

The parties further stipulate that this

statement of facts

is made

and

agreed upon for purposes of set-

tlement only and neither the fact a party has entered into

this

Stipulation nor any of the facts stipulated herein shall be

introduced into evidence in this or any other proceeding except

—1—

93—142

---

to

enforce

the

terms

by

the

parties

to this agreement.. This

agreement shall be null and void and held for naught unless the

Pollution Control Board

(“Board”) approves and disposes of this

matter on each and

every

one of the terms and conditions of the

settlejnent set forth herein.

I.

JURISDICTION

The Board has jurisdiction of

the

subject matter herein and

of the parties consenting hereto pursuant to the Illinois Envi-

ronmental Protection Act, Ill.Rev.Stat.,

ch.

111-1/2, pars.

1001

et ~2•

(1985)

(“Act”)

II.

MYTBORIZATION

The undersigned representatives for each party certify that

they are fully authorized by the party whom they represent to

enter into the terms and conditions of this Stipulation of Facts

and Proposed Settlement and to legally bind them to it.

III.

APPLICABILITY

This Stipulation of Facts and Proposed Settlement

(“Settlement”)

shall apply to and be binding upon the complainant, the Illinois

—2—

93—143

---

httorney

General

and

respondents,

as

well

as

the

successors

and

assigns of each and any officer, director,

agent, employee or

servant.

Respondents

shall

give

notice

of

this Settlement to any

successors

in

interest,

prior

to

transfer

of

interest,

and

con-

temporaneously verify to the Illinois Environmental Protection

Agency at the addresses provided in Section VI.E. below that such

notice has been given.

Iv.

UNCONTESTED PACTS

A.

Complainant, the Agency,

is an agency of the State of

Illinois created pursuant to Section 4 of the Act and is charged,

inter alia, with the duty of enforcing the Act pursuant to Title

VIII thereof.

B.

Respondent Heckett is a division of Hareco Corporation,

a corporation organized and existing under the laws of the State

of Delaware and duly licensed to conduct business in the State of

Illinois.

C.

Respondent Acme is

a corporation organized and existing

under the laws of the State of Delaware and duly licensed to con-

duct business in the State of Illinois.

D.

At all times pertinent hereto, Acme or its predecessor

Interlake has owned and operated

a steel manufacturing facility

(“facility”)

at 135th Street and Perry Avenue, Riverdale, Cook

—3—

93—144

---

County,

Illinois.

Located at the facility is a Basic Oxygen Fur-

nace, or BOF.

At the BOY,

steel

is made by a pneumatic process

involving the blowing of high-purity oxygen onto the surface of

molten pig iron.

During the making of steel using this basic

oxygen process, slag is formed.

E.

The slag formed by the Acme basic oxygen steel making

process is hauled from the BOY shop and subsequently processed by

Heckett at the facility pursuant to

the terms

of a contract

between Heckett and Acme.

All of Heckett’s slag handling pro-

cesses at the facility can be classified as being a part of the

slag—away operations or the slag processing operations.

1.

In the slag-away operation, molten slag from

Acme’s BOY shop (also

known

as its “melt shop”)

is removed

by Heckett in slag-lined pots owned by Acme and transported

to a pit area where the molten slag is dumped and cooled.

Periodically, slag which has solidified in the pot

(

a

“skull”)

is removed in a process called “skulling.”

After

skulling, the empty pots are relined with slag by Heckett.

2.

In the slag processing operation, slag is removed

from the pit by Heckett and is then scriened and sized in

order to make it commercially useful.

F.

On January 30,

1981,

Heckett filed a permit application

with the Agency for its slag-away operation as described in Sec-

tion IV.E.l.

above

(I.D.

031 258 AAS, Permit No.

81020019)

.

Said

permit application is attached hereto as Exhibit A.

In Addendum

—4—

93—145

---

A of the application, Heckett provided for, with respect to slag

pot lining,

the

use of a layer of

dry

processed slag.

G.

That on the basis of the permit application, the Agency

issued to Heckett a joint ~Constructionand Operating Permit for

its slag-away process on February 9,

1981.

The

permit

stated

that it was to expire on February 8, 1986.

A copy of this joint

Construction

and Operating Permit is attached hereto as Exhibit

B.

H.

Following issuance of the permit, Heckett did not submit

a new permit application nor did

it request a revision of its

existing permit to allow material other than

dry

processed slag

to be used as

a slag pot lining material in its slag-away

process.

I.

From on or about the issuance date of the permit until

November 18,

1982, Heckett used

1 x 4 inch sized processed slag

to line the pots.

3.

From November 18, 1982 until on or about June 1,

1984,

Heckett discontinued the use of 1 x

4 inch

sized

processed

slag

as a pot liner.

Heckett informed the Agency that the practice

was discontinued because of explosions caused by moisture in the

slag.

K.

Since

on

or about June

1,

1984, Heckett has

used

1

x

4

inch processed slag as a pot liner.

On one occasion after June

1,

1984,

the use of

1

x

4 sized slag was discontinued during a

—~—

93—146

---

period of extremely wet weather so as to avoid injury to persons

or severe damage to equipment because of-the danger of explosion.

L.

On March 27,

1985, the Illinois Attorney General’s

Office, on behalf of the Agency,

filed a Complaint with the Board

against Heckett and Acme’s predecessor, Interlake, alleging cer-

tain violations of the Act and the Board’s Air Pollution Control

Rules-,

(35 Ill. Adm. Code Section 201.101 et ~g.)

by respon-

dents.

The violations alleged concerned slag handling at the

Heckett facility.

Said Complaint is incorporated herein by

reference as if fully set out.

N.

Heckett and Acme moved to dismiss the Complaint for

various reasons and the Notion to Dismiss and the Agency’s

Response are incorporated herein by reference as though fully set

out.

The Board denied the motions to dismiss on May 16,

1985.

Further, Heckett and Acme contend that there are factual and le-

gal defenses to each count of the Complaint.

N.

In November,

1985, Heckett applied for a renewal of its

operating permit for the slag-away operations at the facility,

based upon data in its original permit application.

Said renewal

application is attached hereto as Exhibit C.

0.

On December 11,

1985,

the

Agency denied Heckett’s ap-

plication for a renewal operating permit.

Said denial letter is

attached hereto as Exhibit

D.

—6—

93—147

---

P.

On January 13,

1986., Heckett appealed the Agency’s De-

cember 11,

1985 denial to the Board.

(Heckett

V.

IEPA,’ PCB 86-

B).

V.

PROPOSAL

FOR

SETTLEMENT

As a result of settlement discussions, respondents, the At-

torney General and the Agency believe the public interest in this

matter will be best served by resolution of this enforcement ac-

tion and permit appeal under the terms and conditions provided

herein.

The parties agree that Acme’s steel manufacturing busi-

ness is of significant social and economic benefit and that

Heckett’s processing and reclamation of slag,

an industrial by-

product of steel manufacturing,

is a necessary and useful ser-

vice.

The Acme steel facility is located in an area zoned for

general industrial uses by the Village of Riverdale; the Heckett

operation at the facility is similarly zoned.

Riverdale is lo-

cated in Cook County, which is a non-attainment area for ozone.

There are no residences located in the immediate vicinity of the

facility.

Heckett’s operations are a source of particulate emis-

sions,

which can cause adverse health effects in certain quanti-

ties.

Discharges of particulates during Heckett’s lining and

skulling operations can be effectively controlled by use of an

environmentally sound,

safe,

lining material.

All statements contained herein are agreed to for purposes

of settling this action only and shall be null and void and of

rio

93—148

---

effect in any further proceeding or cause of action if the Board

does not approve this proposal for settlement in its entirety.

VI.

TERKS OF SETTLEMENT

Respondents and the Agency have agreed to the following

terms of settlement.

These terms shall be in full settlement of

the action filed herein by the Agency and respondents’ liability

for all violations alleged in the Complaint.

A.

The respondents neither admit nor deny the violations of

Section 9(a)

of the Act, and 35 Ill.

AcLm.

Code

201.141,

212.123(a), 212.301 and 201.142 as alleged by the Agency in

Counts

I,

II,

III and V of the Complaint filed in this action.

B.

Heckett neither admits nor denies the violations of Sec-

tion 9(a)

of the Act and 35 Ill. Adm. Code 201.207 as alleged by

the Agency in Count IV of the Complaint filed in this action.

C.

Respondent Heckett agrees that

it

will

consistently

use

1 x

4

inch screened, processed slag as a pot lining for the slag

pots used to transport slag from Acme’s BOY shop.

The pot lining

material may consist of hot, unsized slag in a quantity that will

not cause or contribute to violations of the Act or Board Rules.

D.

Respondent Acme agrees that it will accept the consis-

tent use of a

1 x

4

inch screened, processed slag as a lining for

the slag pots used to transport slag from Acme’s BOY shop.

93—149

---

E.

Notwithstanding the terms of Paragraph VI.C.,

if any

event including, but not limited to, weather conditions and/or

other conditions necessitating the discontinuance of the use of 1

x

4 inch screened, processed slag to prevent injury to persons or

severe, damage to

equipment,

precludes

Heckett’s

use

of

1

x

4

inch

screened, processed slag as

a lining material for the slag pots,

Heckett shall immediately notify the Agency by telephone and no

later than two

(2) business days thereafter in writing of the

event at the addresses provided below.

This notice shall

describe the expected length of time said lining material cannot

be used, the specific reasons precluding the use of said lining

material, and the expected time period at which use of a

1 x 4

inch screened, processed slag will be resumed.

Notice shall be sent to:

Manager, Field Operations Section

Division of Air Pollution Control

Illinois Environmental Protection Agency

1703. South First Avenue

Suite 600

Maywood, Illinois 60153

(312)

345—9780

Manager, Permits Sections

Division of Air Pollution Control

Illinois Environmental Protection Agency

2200 Churchill Road

Springfield, Illinois 62706

(217)

782—2113

Heckett’s use of pot lining material under such circumstances

shall not constitute a violatio~iof the terms of the permit

referred to in paragraph VI.F.

—

93—150

---

F.

The Agency agrees to issue to Heckett

a..five

year

operating permit for its entire slag handling operatinga consis-

tent with Paragraphs VI.C.

through VI.F. and with all other ap-

plicable terms of this Settlement.

The permit to be issued to

Hecket-t is attached hereto as Exhibit E.

Under this permit all

of Heckett’s activities shall be covered by one operating permit.

Heck~ttagrees to dismiss its pending permit appeal, Heckett

V.

IEPA,

PCB 86-8 in consideration of the Agency’s issuance of an

operating permit.

The operating permit shall become effective

upon the Board’s entry of an order approving this settlement and

dismissing PCB 86-8.

G.

The parties enter into this Stipulation and Proposal for

Settlement and the respondents agree to pay the penalty specified

in this paragraph in order to avoid the substantial costs, incon-

veniences and uncertainties of further litigation.

In order to

resolve this dispute and as a condition of Settlement, the

respondents agree to jointly pay a penalty of twenty-five thou-

sand ($25,000.00)

into the Environmental Protection Trust Fund

within thirty

(30) days from the date on which the Board adopts a

final order approving, accepting and incorporating this Stipula-

tion and Proposal for Settlement.

Payment shall be made by cer-

tified check or money order and shall be sent by first class mail

to:

Illinois Environmental

Protection Agency

Fiscal Services Division

2200 Churchill Road

Springfield,

Illinois 62706

—

10

—

93—151

---

H.

The Illinois Attorney General and the Agency agree that

they shall not pursue claims against respondents for violations

of the Illinois Environmental Protection Act or Pollution Control

Board

Rules

as

stated

in

the

Complaint.

VII.

INSPECTION

The respondents agree that the Agency, pursuant to Section

4(d)

of the Illinois Environmental Protection Act, Ill,Rev.Stat.,

ch.

111—1/2, par.

1004(d)

(1985)

shall have the right of entry

into, and upon the Acme Steel manufacturing facility in Riverdale,

Illinois, which is the subject of this Settlement Agreement,

for

the purposes of carrying out inspections, reviewing records,

and/

or observing any tests which are necessary to ensure that the

purposes of this Settlement Agreement are

effectuated.

VIII

COMPLIANCE

WITH

OTHER

LAWS

AND REGULATIONS

A.

This Settlement Agreement in no way affects respondents’

responsibility to comply with any federal,

state or local regula-

tions,

including

but

not

limited

to,

the

Illinois

Environmental

Protection Act, Ill.Rev.Stat.,

ch.

111-1/2, par. 1001 et !!..g•

(1985)

and the Illinois Pollution Control Board Air Pollution

Control Regulations.

—

1’l

—

93—152

---

B.

This S~tt1ementAgreement resolves and disposes of all

violations alleged in the Agency’s complaint and all air pollu-

tion

violations

that could have have been alleged by the Agency

at the time of this agreement.

However, t~ôthingin this Settle-

aent Agreement shall be construed as a waiver by complainant of

the right to redress future violations or obtain penalties with

respect thereto.

WBEREFORE,

complainant and respondents jointly request that

the Board adopt and accept; the following Stipulation and Pro-

posal for Settlement as written.

AGREED:

FOR THE COMPLAINANT:

ILLINOIS ENVIRONMENTAL

NEIL

F. HARTIGAN

Attorney General

State of Illinois

By:

~sep

A~Ss1 ant~)~ttorneyGeneral

Dated:

nsof1

—

1~~

—

FOR THE RESPONDENTS:

HECKETT,

a Division of

HARS

C

RPOPAT

0

BygL44~,i4~

Richard E. Chapla

Vice President

—

Finance &

Administration

Dated:

August 25,

1987

ACME STEEL COMPANY

Vice President

—

Operations

Dated:

July

6,

1988

93—153

---

STATE OF

aliHols

ENViR0~ZM*.j.PROTECTION AGENCY

DI~ION Of

AIR POLLUTION

CONTROt

2203 DcJRCN

ILL

ROAD

SPRINGFIELD. ILLINOIS 62706

FOR AGENCY USE ONLY

‘APPLICATION

FOR

A

PER$IT~~

I

~CONSTRUCT

~

OPERATE

PE~’1ITNO.

N*~OFEQUIPPtEJ1T’TOIE

Slag-Away Operation

DATE

CONS~RUCTLD

OR

OPEMIED

—

3

kUtGf.O.’itR:

*

2a.

kANE

OF

OPERATOR:

HECKETT,

Division of Barsco Corporation

HECKETT, Division

of

Harsco Corporation

lb.

STREET AD3RESS

OF

O~4NER:

2b.

STREET ADORESS OF

OPERATOR~

P.

0. Box 1071

P.

0. Box 559

Ic.

CITY OF C~.ER:

2c.

CITY

OF O~ER~AT0R:

Butler

East Chicago

)c.

~F

C,~F,:

It.

2I~c~:z:

~.

5~T(C: C?E~TO~:

2e.

2I~

CC~

Pennsylvania

1600?

1r~diana

3d..

N~.’~EOF COPP3RATE DIVISIOl~CR PLANT:

HECKETT,

Plant

No.

2?

3~. STREET A~tSSOF EY1SSION SOURCE:

13500

Perry

Avenue

3c.

CITY

OF

EMiSSION

SOURCE:

3~.LOCATED ~Tk~

m~

-

Riverdale

~

D~o

3e.

TO~NSNIP:

3f.

C0U~TY:

Thornton

Cook

3g.

ZIP

CC~E:

60627

—~

~.

ALt. CORRESPO~3ENCE10:

(TITLE

AND/OR N~YEOF INDIVIDUAL)

Robert C. Pfeilsticker, Jr.

S.

TELEPHONE NUMBER FOR AGENCY 10 CALL:

(412) 283—5741

6.

ADDRESS

FOR

CORRE5O~3ENCt:

(CNECK

O~~LY

OUt)

DOPERATOP

fJtMISS3c~.

s~_~cr

7.

YOUR

OLSLG~ATI0NFOR

THIS

APPLICATICN:(t)

.ZL~~.~I___

8.

THE U~3ZP,SIG;EOF:t~EBYt’AKES

LICAT1O~~

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in

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.See

attac.he~

AUTHORiZED SIG~ATURE(5):(0)

cover

letter.

BY

A

Tt~~E

It

~

c

—

_______

Paul

R. Pack

.

..

TYF-EIJ

OR

~~IhuiD

Nk~CO~STG~ER

~YTED

OR

~

(i

~

Vice President

—

Operations

TT1~?T~i~

.

TITLE

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IE~~e’.,-b~

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FOR~.SA.D INFOR”.~TIOH.

(C)

rR3vIDE A CESIG~TIONIN ITEM

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Ti~E

-L1C~’..~

i~

ii-~

C.-~ERc’ c;’~

~sA

::~T1c.,,

~

~

t’~’7

~..E

C~Flit I.~

;:~:~

A

ct;TIFTI: c:~

c~

i

CF

Ti-

(C

~i-1

IF~

5

C

I

..

r’

S

SL

•

~i

Ir

S

~

‘.T

C.-

(

C~

I.

Ir C~

~

C

C--~iC~~

C~ThE EQ~U~Z’;T

TO U

El ThE FE;.~~1.

(V~_1 ~f,

-

---

•

I_I

-

IF

A

PLOT PLAN/PM.?

HAS

PREVIOUSLY BEEN SUBMITTED, ~PtCIFY:

AGENCY I.D.

NUMBE1

APPLiCATION

NUMBER

IS

THE

APPROXIMATE

SIZE

OF

APPLICANT’S

PREMISES

LE.~S

‘IIi.&N I

ACRE?

YES

0

NO:

SPECIFY

ACRES

10.

DOES

THIS

APPLICATION CONTAIN A

PROCESS

FLOW

DIAGRAM(S)

ThAT

ACCURATELY

AND

CLEARLY

REPRESENTS

CURRENT

PRACTICE.

~YES’

3

NO

lb.

WAS ANY

EQUIPMENT.

COVERED BY

THIS

APPLICATION,

OWNED

lIb

HAS ANY EQUIPMENT.

COVERED BY THIS

APPLICATION,

NOT

OR

CONTRACTEDFOR,

BY THE

APPLICANT

PRIOR To

AP&L

14,

1972:

~

PREVIOUSLY

RECEIVED AN

OPERATING

PERMIT:

3

YES

~

NO

I

0

“~

(~

NO

IF

‘YES’

‘ATTACWAN ADDITIONAL.

SHEET,

EXHIBIT A,

THAT:

U ‘YLS~,ATTACH AN ADDITIONAL.

SHEET, EXHIBIT

B, THAT:

(a)

LISTS

OR

DESCRIBES

THE

EOUIPMLNT

i

(a)

LISTS

OR

DESCRIBES THE

EQUIPMENT

~b) STATES WHETHER

THE

EQUIPMENT WAS IN COMPLIANCE

‘

~b)

STATES

WHETHER

THE

EOUIPMENT

WITt4

THE

RULES AND

REGULATIONS

GOVERNING

THE

(I)

IS

ORIGINAL.

OP. ADDITIONAl.

EQUIPMENT

CONTROL OF AIR POLLUTION

PRIOR

TO APRIL

14,

1972.

(II)

REPLACES

EXISTING

EQUIPMENT,

OR

-

I

(lu)

MODIFIES

EXISTING

EQUIPMENT

(c)

PROVIDES

THE

ANTICIPATED OR

ACTUAL

DATES OF

THE

I

COMMENCEMENT

OF

CONSTRUCTION AND

THE

START-UP

OF

THE

EQUIPMENT

12.

IF

THIS

AFFiICATION

INCORPORATES

BY

REFERENCE A PREVIOUSLY

GRANTED

PERMIT(S),

HAS

FORM APC-210,

‘DATA AND

INFOR.MAIION--

INCCRPO~.&TIONEY

F-EFEr-ENCE’

BEEN

CO~.~FJTED.

DYES

~

NO

13. DOES THE STARTUP OF AN EMISSIONSC~FCECOVERED BY THIS AFPLICATION PRODUCE AIR CONTAMINANT EMISSION IN EXCESS OF

AP?,ICASLE

STANDARDS:

DYES

NO

IF

‘YES,” HAS

FOFM AFC—203, “OPERATION DURING STARTUPS EEEN COMPLETED FOR THIS SOURCE:

DYES

0

NO

14.

DOES THIS

APPLICATION

REQUEST PERMISSION

TO

OPERATE

AN EMISSION

SOURCE

DURING MALFUNCTIONSOR BREAKDOWNS:

DYES

0

NO

IF

“YES.”

HAS FORM APC-20-4,

“OPERATION

DURING

MALFUNCTION AND BREAKDOWN”

BEEN

COMPLETED FOR

THIS SOURCE:

O

EYES

3

NO

15.

IS

AN EMISSION

SOURCE

COVERED

BY THIS

APPLICATION

SUUECT

TO A FUTURE

COMPLIANCE

DATE:

D

YES

0

NO

IF

“YES,”

HAS

FORM APC-202,

COMPL

LANCE PROGRAM

£.

PROJECT

COMPLETION SCHEDULE,” BEEN

COMPLETED FOR THIS

SOURCE:

~JYES

ONO

~

16.

DOES

THE

FACILITY COVERED

BY THiS APPLICATION

REQUIRE

AN

EPiSODE

ACTION

PLAN

(REFER

TO

GUIDELINES

FOR EPISODE

O

ACTION

PLANS):

-—

F~YES

NO

Z

17.

WAS

ThIS

OFtr..ATION

THE EUSJECT OF

A

\‘2.~RI~NCL

PETITION

FLED

WITH

THE

ILLINOIS

POLLUTION

CONTROL ECARD

ON

OR EEFCRE

JUNE 13, I~72:

D~

NO

IF

~YES,’CITE:

PCB

NUMEIER(S)

__________________________

,

Dt~TEOF

BOARD

ORDER

—

‘,‘,‘L5

CONSTRUCTION CF MCDIRICATION OF tCeV?/.tNT, SUFFICIENT TO ACPIEVE COMPLiANCE WITH ThE “RULES AND REc-L’LATIONS

C0V1FNING

THE CONTROL OF AIR PCLLLTICN” EFFECTIVE F~ICR TO

APRIL

1~,1972,

CC’..MENCED

FRIOR

TO AFP.IL

14,

1972:

D~

3

NO

Not

Applicable

IF “YES,~EXPLAIN IN DETAIL, AND IDENTIFY EXPLANATION AS EXHIEIT 0.

lB.

LIST

A

~DIUNTIFY

L FCTMS, (X~’~tTS,

I.N~

CTI~RJ’~FC.

-,

~UCN

S~JE’-’.I1TED I~SFART OF THIS f~FLICATION.INCLUDE TI~EFACE

F-L’?-~ERSON EACH ITEM (ATTACH ADD1TICNLL SHETS IF NECES52~~Y):

Cover

Letter

1 page

Resolution for Signature Authorization.

1 page

APC 200

2 pages

Plot

Plan

1

page

Flow

Diagram

1

page

APC

202

2

pages

APC

20L.

w/Exhibit

F

2

pages

Add~ndun A

2

pages

.\d~endun

B

2

pages

TC7~1

~-‘~ECF F.~C-~S

93-.-155

FAGS

2 CF

2

---

/

Illinois Environmental Protection Agency

P.O.

Box 1927&Springfleld,IL ~94.~j6

RECEI

217/782-2113

U

OPERATING PERIIT

‘~-~

PERNI TEE

Heckett Engineering Division of Harsco

Attention:

Robert

C. Pfeilsticker

Post Office Box 1071

.B~itier, Pennsylvania

16001

~pplication No.: 84030043

1.0.

No.: 031258AAS

Applicant’s Designation:

Date Received:

Subject:

Steel Scrap & Slag Reclamation Plant & Slag Away

Date Issued:

1988

Expiration Date:

1993

Location:

13500 Perry Avenue, Riverdale,

Illinois

Pemit

is

hereby

granted

to

the

above-designated

Permitee

to

OPERATE

emission

source(s)

and/or

air

pollution

control

equipment

consisting

of

a

steel

reclamation

plant

involving

a

grizzly,

7

conveyors,

2

screens,

stockpiles

and

the

slag

away process

as

described

in the above-referrenced application.

This

Permit

is

subject

to

standard

conditions

attached

hereto

and the following special condition(s):

1.

This

permit

becomes

effective

upon

the

day

that

the

Pollution

Control

Board

enters

an

order

approving

the

settlement

agreements

reached

in

PCB

85-38

and

PCB

86-8

and dismisses PCB 86-8.

2.

Hekckett

is

authorized to use up to

3 parts

of hot unsized

slag

for

every

15

parts

of

sized

1

x

4

slag

as

pot

liner

when

the

hot

unsized

slag

is

necessary

to

dry

the

sized

1

x

4

slag for

safety reasons.

At all

other

times Heckett

shall use

1

x 4 sized slag as

a pot liner.

3.

This

permit

incorporates

by

reference

all

terms

and

conditions

of

the

settlement

agreement

adopted

by

the

Board

in

E.P.A.

versus

Heckett

Engineering

Division

of

Harsco Corporation & Acme Steel,

PCB 85-38.

It

should

be

noted

that

this

permit,

84030043,

includes

the

operation

of

the

“Slag

Away”

process

formerly

covered

in

81020019 as requested

in the settlement agreement

in PCB 85-38.

Terry A.

Sweitzer,

P.E.

Manager,

Permit Section

Division of Air Pollution Control

TAS:WDI :kjh/25

cc~ Region

1

93—156

---

5*1

0

P’lV”ld

£O~cJ

£‘“*‘q”’Rd

,~

Soe.i~~71

4.

?

ON

~.Lr~”v~7d

“d~c?z

O~?Jb’H4Q(VOI~I/tlQ

_1_JJw,~

~-1

•~a

~

d

---

CALCULATION

SHEET

301

TITLE

EKGIP4EE*

PAGE

fE.

.~PE0JECT

DArE

tXIS”TlW~I)4TtRLP~.KtP#~ELT

SHOP

~/I1H

)4~WSL~POT

1”RkW~FERLOCk’TIOW FOR

RaMOVfr~LO~

P#OLT~3

~L?~G

SL~P~’T

JcPO~I!~

N~.W

C~ErI

P~.J5ER

~

!WITH

SLAG

POUR1WC,

I)’JCLINE

PLMJE

MOLTF~JSL~C~

EXIS-r~~G HECKE.TT

PRcC~SSFDM*.TFR~kLS~

PROc.E.SSINc~

PIT

HEC~’(E1T

DIV1SIO~J

OF

HP~RSCO

CORPS

PLM~TNO.27

FLOW

DIAQ,RM’\:

SLAG—A~WAY OPERATION

93— 158

---

STATE OF ILLINOIS

tt~Y1RO~NtNTA1.

PROTLCTIOU

ATENCY

DIYISI~OP

AIR

POLLUTION CONTROl.

2200 CHURC~(1U.ROAD

SPRIU~FIELD, ILLIUOIS

62706

FOR

A~EUCTUSE

0t4.Y

lIME

COIlS

OP1~flPMZtfl

TO

BE

TR)CTED OR

?.DDIFIED

W4PLIAI~CEPROGRAM

SJ~

PRO.)ECT

COMPLETION

SCHEDULE

Slag—Away

Operation

(A)

1.D.NO.

PERMIT

~.

DATE

Ii.

~J~tL

Cf

O.~lER:

HECKETT,

Division of Harsco Corporation

lb.

ic.

STREET

ADDRESS

OF

0~NER:

P.

0.

Box 1071

CI1’i

OF

C.~.ER:

Butler

2~. kAJ4L Of

OPERATOR:

HECKETT.

Division of Harsco

~

-~-•-~

lc.

S~TEOF

C.~:

Pennsylvania

Z:P

c::E~

16001

2b.

‘C.

STREET AD

P.

0.

DRESS Of OPERATOR:

Box 559

CITY OF OPERATOR:

East Chica~c~

~.

STATE

CF C:E:TC:

n~c:::~

Indiana

46

312

3i.

t~A’~EOF CORR3R.AT(

DIVISIC:I

C~

HECKETT, Plant No.

27

3~.

CITY

OF

EMISSION

SOURCE:

Riverdale

i~.

)

L~ATE~

~1Th~,

CITY

LI~ITS~J~s

~

NO

3e.

TO~Y.S~i1P:

3f.

COUhTY:

Thornton

Cook

3;.

ZIP

CODE:

60627

3b.

STREET

ADDRESS

OP

EMISSIO’~SOURCE:

13500 Perry Avenue

4.

ALL CORRESPOUDENCE

TO:

(I~.F1hD1~ui.AL)

5.

TElEPHONE

?tLP~.?ER

FOR

A&EI1CY

TO

CALL:

Robert

C.

Pfeilsticker,

Jr.

(412)

283—5741

6.

ADDRESS

FOR

CORRESP3~DENC(:

(~NER

0

OPEF.ATCR

(~:!5IoNEDURCE

THE

UI.~P~IO.ED

IiEFE~Y

C(R:~r:Es1F~T

s~Z’~.’.’5

CC~.:AINrDHEREIN

ARE

CfFRECT

A~.DCL~E’iT.

BY

AFFIXTN~.

P~l

SI’~ATcRE

HUETO

I

FLR~hERCERTIFY

ThAT

~.:

::E:

~C!‘ECUT(

THIS

cD:u:’E,~T.

AI.~HO~IZED

5~C:J4TuRE(S)(B)

7.

BY

p

-

J4~

•-~~

BY

5

A.

.

T

V

Paul

R.

Pack

T~EDOR PR1~TEDi~C

Vice President

—

Operati’ns

UTLE

&~

1~LU

‘‘t

h~lI.tO

t.A~~Eti

~J1,T.LR

TITlE EflJ~m

(A)

TuIS fC:~.IS TO F~DvICtP-: ::z.:~~I~-

~

i’

~i:’.

I~

~T

YE

C~L~’CE

F~D.~kM.

CL(LFLY

TtE’~TIRyT~’Z

(~‘.F;~

.?~

Cii ~..iECUIF:’tNT TO BE CO’.ST

~ED N

:::r:E:

•~.“.i

1r~ 11.15

~

(B)

~i!~

~.T

E.t

STC.ED

IN

ACcC~:~~:r

~

;:e

~

c~r;tp2.

PART

1,

rLE

l~.~c)(2). IF

THE

PEP5C~ISIF.\Trr.

T.iE

C

~1I~’Z(

PP

~

A.D

F;:.’Ec~

CC

-~ET1~ ~::.~i

IS

AU;~:zIZED13

O~ SO

BY

A

WESOLUTIC,

OF

T~EED~R:CT

OIF(CTC~S,

SJ:h

AJ1H3R1ZA;IO~KILL

US~.~.LY

C~’~.~LT

~

~

E

:i-~:’.TIc•’.(oRULE.

bATE

93—159

---

G(N(P.AL

IHIORMAT

ION

B.

THE APPL~(~J~T

P~.iSI S(ISM!T A PROCESS rL~OI~.C.RAH~.

DEPICTING RU. RELATED EMISSION SOURCES

£J.D Lit. RELATED AIR POt.LL.1IO?~CO,TPOL

£OU~MEtiT. THE DIAGRAM SHALL

INCLUDE

LA.~ELS

FOR

LACK

SOURCE

A!1D

EACH

ITEM

OF

POUIJTIC~

C0.TPCL LOUlPML~T

•

AND

SMALL

SET

FORTH

P.AzI:N.Ji

FLO.~RAILS

FOR

(1)

ALL RELATED PROCESSING LQUIP”LNT,

(2)

ALL RELATED AIR POLLUTID. CONTROL (OUIP”ENT.

(3)

LL1~

PLATED EMISSION SOURCES A~D(4) ALL RELATED STACKS OR VENTS.

IF A PROCESS FLOW OIAGRA” ~ASBE(t~St~”ITT(D11TH

A PREVIOUS

APPLICATION, THE APPLiCANT

MIJST R(FLREIiC

SUCH APPLICATIOM:

PLR”!TjjO.:

See AddendutnB

—

—

2.0.

MD.:

~.

THE

APPLICANT

SMALL

SL~MITA

DETAILED

DESCRIPTION

OF

THE

EQUIPMENT

Mt

PROPOSES

TO

CONSTRUCT

TO

COMPLY

WITH

THE

Et;VIRON”E’.YLL

PROTECTIOn

ACT

AND APPLICABLE REGULATIONS.

THIS DESCRIPTION SHALL

INCtUDE

THE FOLLOWING:

THE TYPE OF PROPOSED RIP,

POLLITIO

CONTROL

LQU1,,PP’.EIIT

OR PROPOSED AIR

POLLUTION

CONTROL

TECHNIQUE

WHIQ~HAS

BEEN

CHOSEN

TO

ACHIEVE

CO”.PLIA.MCL:

THE

COST.

AVATL&SILT~.

AUDIECMNICAL

REASONABLENESS OF ‘THE

PROPOSED

AIR

POLLUTION

CONTROL

EQUIPMENT

OR

PROPOSED

AIR

POtJJJTION

CO~TROt.TECKIIDUC.

!~:Lt::’.~

DETAILED

COST

ANALYSES

AND

COPIES OF ENGINEERING REPORTS

OA

STUDIES

SUFFICIENT

TO

PROVE

TO

THE

AL~LNCY

THAT THIS OPERATIO~.WILL BE

Iii CO~’.PLIANCE

WITH

THE

ACT

AND

APPLICABLE

REGULATIONS.

THIS

EQUIPMENT

SMALL

BE

CLEARLY

LLEELED ON

THE

PROCESS

FLO~

DIt.~AM.

a.

STATE

DATE

THE

ADPLICk~TWILt.

ENTER

IKTO A BINDING AGREEMENT

TO

M&r.E NECESSARY

PURCHASES

OR

rDDTFICATIDNS.

t.

SIAT( CA~E

Tr~~

~:i~:‘r~yF~

~

CC’.STR’.’TID’~

~

FCR

THE

FF~D~SED

EQU;P:ZN’T OR t.~FIZ.ATIc”,Di

EQF~EN~.

STATE DATE THIS

ITEM OF EQUIPMZ~T

WILL

BE

DELIVERED

(IF

PRESENT

EQUTP~ZNTIS TO BE MODIFIED,

STATE

DATE SUOH ~SD3lFICATIOfl

SHALL

BEGIN) TO THE AFPLICA’,T5 FACILITY.

d.

STATE DATE CO~STRUZT1ONOR MODIFICATIOM OF EQUIPMENT WTLL BE

COM?LEYED.

STATE

CATE APPLICANT WILL TEST EQUIPV.EN’T TO DEHDNSTP.AT

CON-

RLIA~CEWITH

‘THE

(N~IRD;’~!,Tt.LFPDT(CT1O’,

ACT

AND SUESTANTIVE

RECU.AT IONS

PRD

ULGATED

THEREUNDER.

f.

STATE

DATE

EQUIPMENT

WILL

BE

FULLY

OPERATIONAL.

A

EXPECTED DATE

ACTIVITY WILL

EL COMPLETED

NOTE:

THE TIME EET~EENTHE SUBMISSION OF THIS FORM AND THE

INITIAL

EVENT

LISTED

IN

ITEM 10 SHALL

NOT EXCEED 6 P3NTHS.

THE TIME

BETWEEN ANY TWO CONSECUTIVE EVENTS LISTED TN ITEM 10 SHALt NOT EXCEED 6 MONTHS.

‘THE

FIT~ALCOMPLIFJ,CE DATE SNAiL BE NO LATER ThAN THE APPLICABLE

DATE SET FORTH IN PCB PEGS., CIAPTER 2:

AIR POLLUTION.

A

CO

0’.

P):EC1

Lt’~.B.

il!,AL

CC’:~,(TIO~

R~F~R,

A~C-271,P.~SI

SUCH T~)~ECTCD~ETID.pE;3:T

CO’~LIANCED~TE.

BE

M~ST

SU~11TECTO

NL

BE RECETVEC EY

AOE!.Ci

fOR EACH INTERIM

THE AOEMCY

1.0 LATER

TMAN

AND

30

tR~i

C(’~LI&’,ZEDATE

LISTED

IN

C~SAFTER

THE

APPLICASLE ~

10.

C~PLUEAj.LOF

COLIJtMS

A

AND

B.

COMPLETE

COLIJ’~N

C

AS

APPLICABLE.

C

ACTUAL DATE

ACTIVITY

WAS

TED

B

LATEST

DATE

ACTIVITY

WILL

BE COMPLETED’

8/31/81

7 /31/81

93—160

---

STATE OF ILLINOIS

ENVIRO~*1ENTAL PROTECTION

AGENCY

DIVISION OF AIR PO1.LUTION CONTROL

2200 CHURCHiLL ROAD

SPRINGFIELD,

ILLINOIS

62706

OPERATION

DURING

MALFUNCTION

AND

BREAY.DOWN

(WHERE OPERA’ITON

DU~NG

NALFLRICTION

OR

BREAKOO~i~EXCEEDS ALLOWABLE

EMISSIONS)

FOR AGENCY

USE

ONLY

1.

HNIE

OF

PLANT

OWNER:

Heckett, Div. of iarsco

Corp.

~1.

STREET ADDRESS

Of

~MIS5ION

sOURCE:

2.

NAME

OF

CORPORATE

DIVISION OR PLANT

(IF DIFFERENT PRE~4

OWNER):

Plant No.

27

4.

CITY

OF

EMISSION

SOURCE:

13500 Perry Avenue

Riverdale

THE APPLI~M’!SHALL SUBMIT THE INFO~ATIONREOUESTED BY THIS F0~FOR j~Q~LEMISStDN

SOURCE WHiCH.

DURING

MALFUNCTION

OR

BREAKDOWN,

V.AY

VIOLATE

THE

STANDARDS

AND

LIMITATIOMSSE’T

FORTH

INPCB

REGS.,

CsAPrr~’7.PART

Ii.

C.

FOR EACH

SUCH EMISSION SOURCE AND DIRECTLY

RELATED

EQUIPMENT.

SUBMIT

TIlE

FOLLOWING

INFO~4ATION

MD ATTACK TO THIS APPLICATION

AS

E~T~IT

F:

(a) DESCRIBE

THE EXTENT TO W’4ICH DISCONTINUED OPERATION Of THIS EQUIPMENT WOULD:

(A) CAUSE 0* TEND TO

CAUSE

INJURY

TO

PERSONS

OR SEVERE DAMAGE TO EQUIPMENT.

OR

(B)

PREVENT

THE

APPLICANT

FROM

PROVIDING ESSENTIAL SERVICES

TO THE PUBLIC.

(b)

STAC

THE

ANTICIPATED

LENGTH

OF

TIME

THE

EQUIPMENT

WILL

CONTINUE

TO

OPERATE

DURING

THE MALFUNCTION OR BREAKDOWN,

INCLUDING

AN EXPLANATION WHY

THIS

LENGTH

OF TIlt

IS

NECESSARY.

Cc)

DESCRIBE ALL MEASURES THE

APPLICANT

WILL

TAKE TO MINIMIZE THE

DURATION

OF

A

MALFUNCTION

01

BREAKDOWN.

(d)

DESCRIBE

ALL

MEASURES

THE

APPLICANT

WILL

TAXE

TO

MINIMIZE

THE

QUANTITY

OF

AIR

COf(TANINAKI’

EMISSIONS

THAT

MAY

OCCUR

DURING

A

MALFUNCTION

OR

BREAKDOWN.

L

Ce)

IDENTIFY THE EMISSION

SOURCE

0$

THE

PROCESS FLOW

DIAGRAM

TO

BE

OPERATED

DURING

MALFUNCTION

MD

$REMDOWW

THAT

EXCEEDS

APPLICABLE

STANDARDS

AICI

LIMITATIONS.

TOTAL

NUMBER

OF

PAGES

IN

EXHIBIT

F:

1

ANALYSIS OF EXHAUST GAS TO THE

AMBIENT

AIR

DURING

MALFUNCTION

AND

BREAKDOWN

CONTAMiNA.~T

CONCENTRATION

OR

EMISSION RATE

METHOD OF MEASURE AND ANALYSIS

METHOD OF R~NITORING

7.

CARBON

MONOXIDE

a.

P~b.

LB/HR

c.

d.

See

Addendum

B

8.

ORGANIC

KATERIALS

a.

PPM

b.

LB/HP

c.

d.

9.

HYDROGEN

SULFIDE

a.

PPM b.

LB/HR

c.

d.

10.

NITROGEN OXIDES

a.

PPM

b.

LB/HR

C.

d.

11.

SULFUR

DIOXIDE

a.

PPM b.

LB/HR

c.

d.

12.

PARTICULATE

MATTER

a.

GP/SCF b.

LB/HR

c.

d.

13.

OTHER

(Sr(CIFY)

a.

PPM b.

LB/HR

c.

d.

14.

E)~I1

C,.~5 FLO.~RATE:

Not Applicable

ACFY~R

15. I~OTH~Ew!~SIONSOURCES

OR

AIR

P~L1JTION

CONTROL EQUIPMENT ARE

EXHAUSTED

THPOU~H

TH(

STACK 01 VENT SERvING THE

EDUIP’~Et~TCOVERED B’

~4iS

A

‘~ICATION,IKE APPLICANT SMALL DEFINE THE

EMISSIONS

FROM

SUCH OTHER EQUIPMENT AND ATTACH IUFO~.,A~I0NTO THIS APPLICATIO:, AS

E~NIEI

C.

‘~DTA~.

‘..‘~EE~

N

PAGES

IN

EXHIBIT

G:

Not

Applicable

S.

PACE

I

or

1

93—161

---

Heckett

Division

of

Harsco

Corporation

Plant

No.

27

Riverdale,

Illinois

60627

Slag-Away

Operation

Operation

During

Malfunction

and

Breakdown

EXHIBIT

F

Permission

is

sought

to

continue

the

transfer

of

slag

from

the

Interlake,

Inc.

Melt

Shop

to

the

Heckett

slag

processing

pit,

following the malfunction or breakdown of any

slag

transfer

equipment or upsets in transfer schedules.

The operation for which a construction/operating permit

application

is being requested,

involves the transfer of

molten steelmaking process slag to the Heckett processing

pit.

The possibility exists that unavoidable delays

may

occur, which can result

in the cooling and solidification

of the slag, before transfer to the slag processing pit can

be accomplished.

To the best of our knowledge and belief,

there

is no equipment designed and manufactured for the

purpose of remelting slag, prior to processing.

Failure

to remove the solidified slag from the slag pots would

render the pots unusable for future use.

We

believe that

the loss of these pots under these conditions falls within

the meaning of “severe damage to equipment.”

Therefore, we request permission

to continue operations following

a malfunction or breakdown of equipment or

upset

in transfer

schedules

for

the purpose of transferring solidified slag to

the

Heckett processing

pit.

93—162

---

Heckett

Division of Hareco Corporation

Plant No.

27

Riverdale, Illinois 60627

Slag-Away Construction/Operating Permit Application

~DENDUM

A

Heckett, as part of its services offered to Industry, processes

and reclaims industrial by-products.

Plant No. 27

is the result

of a service contract with Interlake,

Inc. to process and reclaim

certain steelraaking by-products occuring at and located on

property owned by Interlake,

Inc.

For reference purposes,

Interlake’s Riverdale Plant Illinois Environmental Protection

Agency

Air

Pollution

Control

identification

number

is

031258AA1.

The subject of this application are the procedures for the

transfer of steelmaking process slag from Interlake’s Nslt

Shop,

to the Heckett operated slag processing area.

Presently, molten slag

is collected in slag pots

and

is

allowed to cool and solidify before transfer to the Heckett

processing pit.

The Agency believes that the du~ingof

solidified slag

into the processing pit results in fugitive

emissions

in excess of that allowed by Illinois Pollution

Control Board Rules and Regulations, Chapter 2:

Air Pollution.

Rule 202:

Visual Emission standards and limitations.

The

applicant, by making this submittal, makes no representation

as to the validity of these allegations,

nor should it be

implied that the applicant is legally obligated to make such

submittal or any part of it.

Heckett,

in cooperation with Interlake,

Inc., proposes to make

the following operational chan~es,which will result in an

operation

known as

“slag-away.

At Interlake’s Melt

Shop, molten slag will continue to be

placed in vessels

known

as slag pots.

An overhead crane will

move the molten slag laden pots to a newly prepared transfer

point within the west

end

of the melt shop.

Interlake will

also make

such modifications as are necessary to railroad

tracks and roadways as are required to facilitate the movement

of slag pots between the Melt

Shop and the

Heckett processing

area.

Heckett will obtain and use a specially modified transporter to

move the molten slag laden slag pots from Interlake’s Melt Shop

to the Heckett processing pit.

Heckett will also have a new

transfer ramp and slag pouring incline plane installed at the

93—163

---

processing pit.

The inc1ine plane will extend downward from the

transfer ramp to the bottom of the processing pit.

In actual

operation,

the transporter will position the slag pot at the

end of

the transfer ramp, over the incline plane.

The slag

pot will then be mechanically rotated to allow the molten slag

to flow

onto

the

incline

plane

and

down

to

the

bottom

of

the

processing pit.

The slag will then be allowed to cool and

solidify before traditional processing begins.

As occurs now, a layer of dry processed slag will be added to

th~bottom of the emptied slag pots, before the transporter

returns the pots to the melt shop for reuse.

This layer of

slag insulates the bottom of the pots and prevents

“burn

outs,”

which is the melting through of the pots and the accidental

:rélease of molten slag.

Such a release can result in injuries

to persons and severe damage to equipment.

Therefore, the

slag pot insulating practice will be continued.

The slag-away operation is a relatively new fugitive emission

control procedure.

Our

experiences at other locations within

the United States indicates that in comparison with “cold

slag” transfer, the slag-away procedure can offer significant

reductions

in fugitive emissions.

Engineering calculations

of anticipated emissions are included

in this application in

Addendum B.

A search of the Illinois Environmental Protection Agency Air

Pollution Control permit application forms reveals that no

forms are truely applicable

to the slag-away operation.

Therefore, we are providing the information, which is typical

of the data required by the Agency forms:

1.

The slag-away procedure

is a batch-type operation.

2.

A.

Average operating

time,

under the presently

depressed steel market conditions,

is 16

hours/day,

7 days/week and 50 weeks/year.

B.

Average operating

time,

under normal conditions,

is

24

hours/day,

7 days/week and 50 weeks/year.

3.

Maximum operating time

is 24 hours/day,

7 days/week

and 50 weeks/year.

4.

Percent of annual throughput

is

25 percent for each

calendar quarter.

5.

A.

Average “raw material” throughput

(see Item 2A)

is 16 pots per day, with each slag pot containing

approximately 15

tons of molten slag.

B.

Average “raw material” throughput

(see Item 2B)

is

24 pots per day, with each slag pot containing

approximately 15 tons of molten slag.

6.

Maximum

“raw material” throughput

is 45 pots per day,

with each slag pot containing

15 tons of molten slag.

93—164

---

Heckett

Division of Harsco Corporation

Plant No.

27

Riverdale, Illinois 60627

Slag-Away Construction/Operating Permit Application

ADDENDUM

B

Emission calculations for “cold” and molten

slag

dumping

operations based on “Particular Emission Factors Applicable

to the

Iron and Steel Industry,” EPA-450/4-79-028.

September, 1979.

Average slag handled— 576 tons per day.

Operations—

7 days per week, 50 weeks per year.

Annual average throughput—

(576x7x50)

201,600 tons per year.

Cold Sl~g

Emissions

Assumptions

(S)

Silt

content

5.37.

(U)

Mean wind speed

10.3 MPH

(h)

Drop height— 6 feet

M)

Moisture content— 0.92 percent

Y)

Dumping device capacity— 330 cubic feet, or

13 cubic yards

d)

Dry days

per year— 250 days

f)

Percent time wind exceeds 12 MPH

35.6 percent

D)

Duration of storage—

2 days

Table

13 Emission Factor Calculations

Load

and

Loadout

(2)

.0018

~~5.:44i4~

~r~i

—

0.010

lbs./ton

Pile Maintenance and Traffic—

0.10

(1)

~5.3~3

~25~

—

0.113 lbs./ton

93—165

---

Wind

Erosion:

(0.05)

.~

~35.6~ ~

—

0.003 lbs./ton

Total

Emissions

Factor:

0.126

lbs./ton

576 tons of slag handled per day

—

24

tons/hr.

24 tons/hr.

x 0.126 lbs./ton

—

3.024 lbs./hr. present

uncontrolled emissions.

Slag-Away Emissions

There are no emission factors available for this operation.

Therefore, based on visual observations and engineering

judgment,

emissions

are

decreased

by

80

percent

over

cold

slag operations.

3.024

lbs./hr.

x

(1007.

-

807k)

—

0.605

lbs./hr.

93—166

---

fñvirônmental

Pi~t~ctiön

Agenc~

2200

Churchill

Road,-Springfield, Illinois 62706

RECEIVED

217/782—2113

cHIcAGO OFFICE

JOINT

C0NSTRUCT10t~ N~D

OPERATING PER~’4IT

MAR

1 3

198!.

Operating

Permit Expir&tlcn Data:

February 3, 1~

EIIYIRONUENThJ.

PROTECTION

AGENCY

Application No.:

81020019

STATEOFlW~IS

1.0.

No.:

031258M5

;Appll-cant’s

Designation:

27—5-5a

Received:

February

~,

1~31

Construction & Operation of:

Slag—Away Operation

Location:

13500 Perry

Avenue, Riverdale,

Illinois

Ilarch

~,

1~i

HECKEIT,

Division

of

Harsco

Corporation

Post

Office

Box

1.071

Butler,

Pennsylvania

~6001

Atte~ticn:

Robert

C. Pfdlsticker, ~r.

Gentlemen:

Permit

is

here5y

grantee

to

construct

and

operate the above—ref~re~~ced

equipment

subject

to

stan~erd conditions

att~ch~d

hereto

and jncorpcr~ted

herein

by reference.

Very

truly

~‘ours,1

‘.

I

~~:

/;,.~

J.

Bharat

Mathur,

P.E.

Manager,

Permit Sectlcn

Division

of

A~r

Pollution Control

8~1

:H~IP

:

ct

/

25

~

1

cc:

RegIon

1

/~i -

3

i

rte pecmittee snail not continue operation

during malfunctionorbreakdown

beyond

such

time

as

is

necessary

to

prevent

iniUryto persona

or severe dama~

equipment

or to

provide essentiat

services.

1.532-0224

APC16I

(Revised

11/05/Bi)

93167

2815C

---

Illinois Environmental Protection

Agency

•

2200 Churchill Road,

Springfield,

IL

62706

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93—168

---

Illinois

Environmental Protection Age~icy

•

2200 Churchill Road,

Springfield,

IL 62706

1r

~

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A.~)~I..iCL.TIr~

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93—16 9

---

_____

Illinois Environrncntai

Protection A~cncy

-2200

Churchdl

Road, Springf~eId.IL

62706

217/732-2112

CERTIF!~D;-AIL

PEP~!T~E’~IPL

~.

,

~

~~_5._3

Sf3)

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11,

1

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Hcckett

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Attention:

Ro’~ort

C.

Pflsti:t~

Post

Cffic~~

~C7;

612 ~i.~

Butler,

Pc-nnsy1var~i.~1 3C01

Anplic~tion‘~o.:

~C2OC~i~

App!icEirtt~.~r-Th~:

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ovc~.t~or

7,

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cctio;i

Act,

~nd 3~Iii.

Adm.

Code 2Cl.~2,212.123

and 212.~

(fc~-2rly

1f.

1C3C~)(l),

2~)2ih)

and 233(fl) might

~i

~i3~fatcd.

The foilowir~gar~

sc~f~

~m.~sors

why t~c

Act

~

the ~u~s

and

1at~c~s

nay

not

5c~

Pursuant

to

1~i.

T~.

Co~o201.142 (fc~e;1yRt~1~

iU3Ca)~1

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,

a

Construction

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s

~o ~e

c~aTh~i

prior

to

con~tructi,~ c~:.~ifyi~

an

ai:’

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S3urC~ o.’

control e~ui’~v~”~.

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ava~1a5ie

tc -t~~

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violatic~cl f ~CiV3 p-trtic~lato

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iir~itatici~s,25 I~.A-~’.. ~

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202ff))

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addition

cxcc~

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111. A~.

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h3~

obsorv~at t~c~s~

nzr~oper~tticn~.

The

A~ncy~:i1i

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c-F your ~

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93—170

---

Pc

2

I’~~

~‘cvc

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c:

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93—171