ILLINOIS POLLUTION CONTROL BOARD

September 15,

1976

ENVIRONMENTAL PROTECTION AGENCY,

)

Complainant,

v.

)

 PCB 76—124

GRANITE CITY STEEL, a division of

)

NATIONAL STEEL CORPORATION,

)

Respondent.

Messrs.

 John Palincsar and Roger Zehntner, appeared on behalf of

Complainant.

Messrs.

 Randall Robertson and Edmund S.

 Ruffin,

 III,

 appeared on

behalf of Respondent.

OPINION AND ORDER OF THE BOARD

 (by Mr. Goodman):

This matter comes before the Board upon the May

 4, 1976

Complaint filed by the Illinois Environmental Protection Agency

(Agency) against Granite City Steel, a division of National Steel

Corporation,

 (Granite City).

 Hearing was held in this matter on

June 25, 1976 and a proposed Settlement Stipulation was filed here-

in on July

6,

 1976.

The Complaint

In its Complaint the Agency alleges that Granite City owns

and operates a steel mill in Granite City,

 Illinois including a

basic oxygen furnace

 (BOF)

 shop with facilities including two BOF

vessels,

 an electrostatic precipitator

 (ESP),

 a hot metal reladling

station, a roof monitor

 (an exhauster on the roof of the BOF

enclosure),

 and an ESP stack.

 It is alleged that in the operation

of this equipment Granite City has violated certain provisions of

the Environmental Protection Act

 (Act)

 and of Chapter

2:

 Air Pollu-

tion Control Regulations

 (Regulations).

—2—

In particular Granite City is alleged in Count

 I of the

Complaint to have caused or threatened to allow emission of contami-

nants into the environment so

 as to cause or intend to cause air

pollution in the state,

 in violation of 9(a)

 of the Act and Rule 102

of the Regulations,

 since May

3,

 1972 until the date of filing of the

Complaint.

 In addition the Complaint alleges violation of Rule 202(b)

of the Regulations including but not limited to certain dates, with

respect to the aforementioned roof monitor and ESP stack.

 The Com-

plaint also alleges that Granite City violated Rule 203(a)

 of the

Regulations in that it caused or allowed the emission of particulate

matter into the atmosphere in the operation of the BOF shop and vio-

lation of Rule 104(a) of the Regulations in that the BOF shop is

without a compliance program and project completion schedule approved

by the Agency.

Count II of the Complaint alleges that Granite City owns and

operates

 a coke plant which includes three batteries of coke ovens

(referred to as Battery A,

 B, and C respectively) each of which is

 equipped,

 •inter alia, with a battery stack and associated facilities

and equipment for charging the ovens with coal, pushing coke from

the ovens,

 and transporting and quenching the coke.

 The Agency

alleges that in the operation of this coke plant Granite City has

been in violation of Rule 104(a)

 of the Regulations in that they

failed to have a compliance program and project completion schedule

approved by the Agency,

 and that they caused or allowed the emission

of smoke from the coke batteries

 in violation of Rule 202(b)

 of the

Regulations.

 In addition, Granite City is charged with violation of

Rule 203(d) (6) (B) (i) (bb)

 of the Regulations concerning requirements

in the charging of the coke ovens and with violation of the same Rule

with regard to the pushing and quenching systems associated with the

said ovens.

 Granite City denies the violations as alleged by the

Agency.

Proposed

Settlement

Hearing

 was held in this matter on June

25,

 1976 at which a

proposed Settlement Stipulation was presented under Rule 333 of the

Board’s Procedural Rules.

 The proposed stipulation recites the

situation much as indicated in the pleadings herein.

 It is noted

that Granite City has had variances from the substantive rules appli-

cable to the coke ovens in PCB 70-34, PCB 73-26,

 and PCB 74-34.

Granite City contends that the Agency wrongfully denied an operating

 permit but it agrees

 to institute and complete a program as set forth

in the Exhibits attached to the Proposed Stipulation.

 The Proposed

Stipulation and the Exhibits attached thereto are hereby incorpor-

ated by reference as

 if fully set forth herein.

—3—

The proposed program includes

 a number of equipment modifi—

cations and procedures which the Agency feels will result in Granite

City’s eventual compliance with the appropriate Board Regulations.

The program is divided generally into two basic areas; the coke ovens

and the basic oxygen furnace

 (BOF)

 operation.

Coke Ovens

The coke oven proposal is further divided into the charging

operation,

 the pushing operation,

 and the coke battery stacks.

A.

 Charging.

 The Charging Operation entails loading the

coke oven with coal utilizing a hopper car and charging ports with

lids which are part of the oven itself.

 Particulate matter gene-

rated by the heating of the coal in the ovens may escape through

the charge ports during the actual charging operation or through

incomplete sealing of the charge port and lid after the lid has

been repositioned.

 This situation precipitated the alleged violation

of

 Rule 203(d) (6) (B) (i) (bb)

 of the Regulations.

 Granite City has

heretofore installed a specially designed charging car known as the

AISI/EPA Charging Car and has agreed to undertake a program to modify

its existing charging cars and to install such additional equipment

as

 is necessary to utilize what is known as

 a stage charging method

of charging coal into its coke ovens.

 It is the opinion of the

Q

 Agency that completion of such a program for Granite City’s charging

operation and the proper application of the stage charging method

will result in compliance with the current charging rule.

B.

 Pi~shing. At the end of the coking period, the oven doors

are removed and the coke is pushed out of the oven (exiting the

oven at a temperature of approximately 2000 degrees Fahrenheit)

 into

a car (quench car) which travels on tracks along the side of the coke

batteries.

 The hot coke is carried to a chimney-like quenching tower

equipped with overhead sprays and grit-arresting baffles.

 The coke

is cooled with water and dumped on a coke wharf for further cooling

prior to screening.

During this pushing operation emissions are generated as the hot

coke is dumped into the quench car.

 These emissions continue as the

car travels to the quenching tower for cooling.

 These particulate

emissions are the basis for the allegation of violation of Rule 203(d)

(6) (B) (i) (bb).

 The company has agreed to install two complete pushing

emission control systems

 in accordance with Agency construction permit

No.

C

 4 12 031 which the Agency believes will result in

 a controlled

system that will bring Granite City into compliance with the current

—4—

pushing rule.

 The Agency notes however that this control system is

not an enclosed system as envisioned as one method to control pushing

emissions under the current Regulations.

C.

 Battery Stacks.

 As the coal is reduced to coke within the

oven, products of combustion of the gas, used for heating are ducted

to a single stack on each battery.

 If there are defects in the refrac-

tory of the coke oven walls, particulate matter being generated

within the oven may leak through the oven walls into the flues and be

discharged from the battery stack.

 The Agency contends that these

leaks cause particulate emissions

 in the battery stack that violate

the opacity limitations of Rule 202(b).

 Granite City has agreed

to undertake a program of repair and replacement of the interior

lining of its coke ovens in an attempt to prevent leaking through

the walls.

 Should this program of repair and replacement be inade-

quate,

 the Company agrees to take corrective actions as indicated

in Exhibit I to the Proposed Stipulation under the sub-title Coke

Ovens

starting

page

This

final

solution

the

problem,

necessary,

includes

generally

particulate

control

device

perma-

nent shutdown of the battery, whichever appears appropriate to the

Company.

 It is the opinion of the Agency that completion of the

program for battery stacks will result in Granite City’s compliance

with the current opacity limitations.

BOF

SHOP

The

BOF

shop

facilities

include

two

BOF

vessels

and

hot

metal

reladling station, all of which are housed in the BOF building en-

closure.

 Hot metal from the Company’s blast furnaces is transported

by means of torpedo ladle railway cars into the BOF shop.

 The hot

metal is transferred from the torpedo car to the hot metal charging

ladle at the hot metal reladling station.

 The hot metal

 is then

dumped or charged into the BOF vessel by means of an overhead crane

along with scrap steel which is charged into the vessel by means of

a scrap charging car.

 After charging is completed an oxygen lance

is lowered into the vessel and the contents or “heat”

 is then “blown”

by injecting oxygen into the surface of the hot metal.

 At this time,

additives,

 including fluxing agents,

 are introduced into the vessel

by means of an additive chute.

 The purpose of the oxygen blow is to

oxidize the excess carbon and impurities which results in the refining

 of the contents of the vessel into steel.

 In addition, this oxi-

dation creates an exothermic reaction which melts the scrap within

the vessel and brings the heat to the correct temperature for pour-

ing.

 At the end of the refining period the metallurgy and tempera-

ture are checked and the heat

 is tapped by tipping the vessel and

pouring the contents into a teeming ladle.

 The vessel is then pre-

pared for another charge and the beginning of a new cycle or heat.

—5—

Particulate emissions are generated during the hot metal re—

ladling operation,

 charging of the hot metal,

 oxygen blowing,

and

during tapping, resulting in emissions which escape into the atmos-

phere and may cause violations of Rule 202(b)

 and 203(a)

 of the

Regulations.

 These violations occur with respect to emissions from

the apparently inadequate electrostatic precipitator

 (ESP)

 connected

to the BOF building enclosure and from the roof monitor exhauster

located at the top of the BOF enclosure.

 In addition, the Agency has

never issued an operating permit for the BOF facility and therefore

alleges a continuing violation of Rule 103(b)

 of Chapter

 2 of the

Regulations and Section 9(b)

 of the Act.

 The Company has agreed to

implement a program to control the aforementioned emissions.

 This

program is divided into a number of subsections.

A.

 Reladling.

 Emissions generated at the reladling station

presently are controlled by a centrifugal collector.

This collector being deemed inadequate,

 Granite City pro-

poses to install a new system of fume and dust control

including an improved fume collection hood,

 improvements

to the collecting system,

 a new final gas cleaning in-

stallation and other appropriate

 fans, motors, pumps and

controls.

B.

 Charging.

 Granite City has proposed to provide a maximum

draft through the ESP hood during the charging operation

in order to improve the capture of particulate emissions

resulting from hot metal charging which are vented to the

existing hood.

 Granite City also proposes to utilize a

steam injection system to condition the gas so that the

particulate so captured will be collected adequately by

the existing ESP.

C.

 Oxygen Blow.

 During the oxygen blow,

 large amounts of

particulate matter escape the ESP hood through the lance

hole and additive chute.

 To eliminate this problem the

Company has proposed to install a lance hole closure

device and additive chute closure and to increase the

draft through the ESP hood during the oxygen blows.

D.

 Tapping.

 Granite City proposes to install

 a tapside

partial enclosure and utilize increased draft through

the ESP hood to capture emissions that otherwise would

go to the ambient atmosphere during the tapping opera-

 tion.

—6—

E.

 ESP Dust Handling.

 Granite City has proposed an ESP

dust collection program to control fugitive emissions

generated by equipment associated with the collection

of ESP dust from the BOF electrostatic precipitator

site.

Considerations

It is the belief of the Agency and Granite City that the public

interest will be best served by the resolution of this enforcement

action under the terms and conditions of the Proposed Stipulation.

The Stipulation provides for the improvement of the Company’s emission

control facilities and the quality of the ambient air in the vicinity

of the company’s facilities while at the same time providing for the

saving of a substantial amount of time, effort and expense that could

be expended in litigating the issues in dispute.

 During the period of

the Proposed Stipulation the Agency,

 as outlined in paragraph

 8 of the

Proposed Stipulation,

 shall have the authority to enter the plant at

all reasonable times for the purpose of inspection and examination of

papers and documents pertaining to the implementation of the plan.

The right of appeal of each party is outlined in paragraph 9 and the

Agency agrees not to cause any other enforcement action to be brought

or initiated pursuant to Section

 31(a)

and

 (c) of the Act on any

element of the program so long as Granite City

 is in compliance with

 that particular element.

 In addition,

 the Agency agrees to withhold

enforcement action pertaining to the operating permits in the coke

ovens and the BOF until all portions of the program related to each

facility separately shall have been completed.

The Agency agrees

 to look favorably upon any petition for

variance by Granite City to the Board provided that such a favorable

recommendation is consistent with the objectives contained in the

program.

 The Company agrees to supply quarterly reports on its pro-

gress to the Agency until the program is completed,

 advising the

Agency of any delays or advancement in this schedule.

 The Company

shall apply for and obtain construction permits necessary to imple-

ment the provisions of the program, and the Agency agrees to promptly

process such applications.

Granite City agrees

 in the Proposed Stipulation to pay in two

installments to the State

 of Illinois a total of $75,000.00 in

settlement of this action.

 In addition, Granite City will post

personal bonds of the Company as set forth in Exhibits

 2 A through

2 G of the Proposed Stipulation guaranteeing the faithful performance

of certain parts of the program.

 In consideration of the Company’s

agreement to pursue the program, the Agency agrees that the pending

enforcement complaint in this case will be dismissed with prejudice

—7—

for

the

period

time

covered

the

complaint

the

date

any

Order

the

 Board herein approving the Proposed Stipulation.

The

foregoing

 general review of the Proposed Settlement

and

Stipulation

filed

the

parties

herein.

estimated

that

the total cost of the program proposed is seventeen and one—half

million dollars.

 The Agency agrees that upon completion of this

program Granite City should be in compliance with the Board’s Rules

and Regulations.

 The time span of the longest construction period

in the proposed program is two years which appears reasonable con-

sidering the amount of engineering and construction required.

 On the

other hand there have been complaints registered with the Board

concerning Granite City both at the hearing and by letters received

at the Board offices.

 Some of the complaints were not appropriate

~or this action, concerning themselves with vibration problems and

with personal damage actions.

 In general, however, the stated com-

plaints revolve around the lack of response from Granite City with

regard to control of its alleged pollution

 (R.l07-l27).

The Board finds that the Proposed Program with its enforceable

 provisions and its $550,000.00 in bonding requirements is

 a reason-

able resolution of Granite City’s pollution problems.

 It is the

opinion of the Board that an end of litigation at this time and be-

ginning of the construction of abatement facilities

 is the correct

method with which to alleviate the burden of the people of the State

of Illinois with respect to the alleged pollution caused by Granite

City.

 The Board will therefore accept the Proposed Settlement and

Stipulation as presented by the parties herein and will order them

to carryout the provisions of the Proposed Abatement Program as set

forth by them in the Stipulation.

This Opinion represents the findings of fact and conclusions of

law of the Board in this matter.

ORDER

It is the Order of the Pollution Control Board that:

1.

 The parties herein pursue their duties as set forth

in the Stipulation filed with the Board July

6,

 1976 with

regard to the BOF emission and coke oven emission control

program as set forth in Exhibit

 1 of the said Stipulation.

—8—

2.

 Within

 60 days of the date of this Order Granite City

shall execute the personal bonds

 as indicated in Exhibits

2 A

through

 2 G of the aforesaid Stipulation.

3.

 Granite City shall, in consideration of the settlement

of this action, pay to the State of Illinois a total of

 $75,000.00, said amount to be paid in two installments as

follows:

1.

 $37,500.00 within 30 days of the

receipt of this Order.

2.

 $37,500.00 ten months after the

date of receipt of this Order.

The Complaint in PCB 76-124

 is hereby dismissed with

4.

prejudice.

I,

 Christan L.

 Moffett, Clerk of the Illinois Pollution Control

Board, h~ebycertif

th

 abo e Opinion and Order were adopted on

the

~‘

 day ~

 1976 by a vote of

Illinois ?ollution