ILLINOIS POLLUTION CONTROL BOARD
3uly
26, 1973
INTERNATIONAL HARVESTER COMPANY,
Petitioner,
PCB 72—321
v.
)
PCB 73—176
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
Alan I.
Becker on behalf of Petitioner;
James Rubin, Assistant Attorney General, on behalf of Respondent.
OPINION AND ORDER OF THE BOARD
(by Mr.
Seaman):
On April
30,
1973,
Petitioner,
International Harvester
Company,
the operator of an integrated steel mill in Chicago,
County of Cook,
Illinois,
filed a Petition requesting variance
for the operation of the following facilities
in
a manner
which would otherwise violate the indicated regulations:
a)
For the stacks on #3 battery
front Rule 202(b) (onacity)
of
the Rules and Regulations of the Pollution Control Board
(hereinafter PCB Rules).
b)
For the lids on
#3 battery from Rule 203(d) (6) (B) (i) (aa)
of the PCB Rules
(lid replacement within 20 seconds).
c)
For charging on batteries #3 and #4 from Rule 203(d) (6) (B) (1) (bb)
of the PCB Rules
(installation of automated negative pressure
charging or its equivalent by December 31, 1973).
d)
For pushing and quenching on batteries
#3 and #4 from Rule
203(d) (6) (B) (i) (bb)
of the PCB Rules
(installation of
enclosed pushing and quenching system or equivalent by
December 31,
1974).
e)
For coke oven doors on batteries
#3 and #4 from Rule 203(d)
(6) (B) (iv) (aa)
of the P03 Rules
(door leakage opacity
limitations)
8
—
595
—2—
Although regulations requiring automated negative pressure
charging systems and enclosed pushing and quenching systems are
not effective until December
31,
1973,
and December
31, 1974,
respectively,
a compliance plan
and project completion schedule
leading to compliance by
the specified date is necessary in order
to obtain an operating permit.
Therefore,
Petitioner also needs
a Variance from Rule 104 of
the PCB Rules,
in order to obtain an
operating permit.
Agency investigators visited Petitioner’s facility on May
9
and
10,
1973 and on many occasions prior thereto.
During the
May
9,
1973 inspection, several instances of allegedly faulty
coke oven operation were noted.
A further inspection was con-
ducted on June 12,
1973.
Petitioner’s coke plant consists of two batteries of
Wilputte by-product coke ovens.
#3 Battery contains 67 ovens
installed in 1952 and 1956 with
a capacity of 15.6
tons of coal
per oven.
#4 battery contains 45 ovens installed in 1968, with
a
capacity of 27.8 tons of coal per oven.
Both batteries are
charged from larry—cars through topside lids.
The lids on #3
Battery are removed and replaced manually by Petitioner’s
employees.
The lids on
#4 Battery are removed and replaced by
magnetic lid—lifters.
#4
Battery is also equiped with
a
disintegrator-type wet scrubber which, however, has experienced
operational difficulties.
The coking process inherently produces large amounts of
gases and smoke,
95
of which are allegedly captured by the by-
product system and used for various purposes.
The gases which
are not captured in the by-product plant create the coke oven
emission problem.
These emissions result from minute imperfections
in the seal of the coke-oven door.
Additional emissions occur
during the pushing operation and some leakage is emitted from
the stack of the
#3 Battery.
It
is apparent from the Petition that Petitioner is well
aware of its emissions problem and has already taken substantial
steps toward compliance.
Also contained in the Petition is a
lengthy and detailed description of additional measures Petitioner
pledges to take in order to achieve total compliance.
It is noted
that the Agency is in substantial agreement with the remedial
procedures submitted by the Petitioner for this Board1s approval
and recommends
that the several variances requested be granted
subject to certain conditions.
This Opinion constitutes the
findings of fact and conclusions
of law of the Board.
8
—
596
—3—
IT
IS THE ORDER of the Pollution Control Board that variances
for the equipment enumerated on page
1 of this Opinion be granted
for
a period of one year from the date of this Order unless other-
wise provided, subject to the conditions specified below:
A)
1)
For the stacks on
#3 battery from Rule
202(b)
of the
P03 Rules;
2)
For the lids on
#3 battery from Rule 203 (d) (6) (B) (I) (aa)
of the PCB Rules;
3)
For charging operations on batteries #3 and #4 from Rule
203(d) (6) (B) (i) (bb)
of the PCB Rules until the installa-
tion of controls;
4)
For pushing and quenching operations
on batteries
#3 and
#4 from Rule 203(d) (6) (B) (ii) (bb)
of the PCB Rules;
5)
For coke oven doors on batteries
#3
and #4 from Rule
203
(d) (6) (B) (iv) (aa)
of the P03 Rules;
6)
For charging, pushing and quenching operations on batteries
#3 and
#4 from Rule 104 of the PCB Rules to the extent that
timely compliance with Part
2 of Chapter
2 of the PCB Rules
will not be achieved~
B)
I)
Within
35 days of this Order, Petitioner
shall repair the
grit arrestor
in the coke quench tower and shall operate
the tower with an adequate layer of coke on the grit
arrestor screen.
2)
Within 60 days of
this Order, Petitioner shall
submit a
report to the Agency detailing the operating and maintenance
problems with the scrubber on the
#4 battery larry car and,
if
appropriate,
set forth
a program for the repair,
maintenance and operation of this scrubber.
3)
Within 60 days of this Order, Petitioner shall inspect and,
if necessary,
clean, replace and repair goosenecks and
caps,
liquor flushing nozzles, steam aspirators, and
combustion port caps on batteries
#3 and #4.
4)
One lidman shall be present at all times on #3 battery and
#4 battery.
If necessary to prevent leakage, lids on both
batteries shall be luted.
5)
Petitioner shall maintain at all times one man on each side
of
#4 battery and one man on the coke side of
#3 battery
to clean doors
arid jambs.
Doors and jambs shall be
inspected and,
if necessary,
cleaned after each push.
8
—
597
6)
All doors shall be reconditioned at regular intervals.
Within
35 days of this Order, Petitioner shall submit
to
the Agency for its approval a program for the maintenance
of all doors on a regular schedule.
Such program may
involve an outside contractor
to do this work on
a regular
basis.
7)
Petitioner shall replace lids on charging ports of battery
#4 within
20 seconds of withdrawal of the charging sleeve
and shall replace lids on charging ports of battery
#3
within 20 seconds of withdrawal of the charging sleeve
unless prevented by danger to workmen or danger of damage
to equipment,
in which case lids shall be replaced as soon
as possible.
8)
On September 30,
1973,
and at three month intervals there-
after, Petitioner shall report to the Agency on its
investigation of pushing emissions controls and its
progress in adopting and implementing a pushing emission
control program.
9)
Within
60 days of this Order, Petitioner shall place in
effect operating and maintenance work rules for its coke
ovens approved by the Agency.
Such rules shall provide,
among other things,
for the presence of at least one lid—
man on each battery,
the completion of charging operations
in conformance with subparagraph
7, supra
the inspection
and cleaning of doors and jambs after each push,
the repair
and reconditioning of all doors on a regular basis, the
setting and enforcement of coking times to avoid green
pushes, the availability
to the Agency of coking deter-
minations and actual coking records and the revision of
the work rules and resubmission for Agency approval when
coke oven practices are changed or when new or modified
equipment is installed.
10)
Within 35 days of this Order, Petitioner shall agree with
the Agency on procedures
for a study of door leakage.
11)
Within 35 days of this Order, Petitioner shall agree with
the Agency on procedures for a study of controlled coking
times to limit pushing emissions.
12)
Beginning on September 30, 1973,
and every three months
thereafter, Petitioner shall submit to the Agency a report
of its progress in implementing the program covered by the
Order of the Board herein.
13)
Within
35 days of this Order, Petitioner shall furnish a
form acceptable to the Agency a bond in the amount of $50,000
to insure the installation of equipment as set forth In the
Order.
8— 598
—5—
I, Christan L. Moffett,
Clerk of the Illinois
Pollution Control Board, certify that the above
Opinion and Order was adopted by the Board on
the~(o~”~
day of
~
,
1973,
by a
voteof~
to
~
.~
~
//,
~
8
—
599