Environmental Protection Agency
Office of Enforcement
EPA-330/2-79-008
VISIBLE EMISSIONS OBSERVATION SURVEY
BETHLEHEM STEEL CORPORATION - LACKAWANNA PLANT
LACKAWANNA, NEW YORK
[Oct. 23-27, Nov. 29, Dec. 1, 1978]
Gary D. Young
February 1979
National Enforcement Investigations Center - Denver
and
EPA Region II - New York
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CONTENTS
I. INTRODUCTION 1
II. SUMMARY AND CONCLUSIONS . 3
III. PLANT DESCRIPTION 5
IV. SURVEY METHODS 9
COKE OVEN BATTERIES 9
OTHER SOURCES 12
V. SURVEY RESULTS 14
COKE OVEN BATTERIES 14
OTHER SOURCES 17
APPENDICES
A NYSDEC Regulations 214.2 and 212.7
B EPA Region II Coke Oven Battery Inspection Procedures
C Observation Summaries by Inspector Position for Coke
Oven Batteries
TABLES
1. Daily Emissions Summary 19
2. Source Emissions Summary 22
3. Charging Data 23
4. Pushing Data 25
5. Door Data 28
6. Topsides Data 30
FIGURES
1. Buffalo, N.Y. Vicinity Map 2
2. Bethlehem Steel - Lackawanna Plant Layout 6
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I. INTRODUCTION
The National Enforcement Investigations Center (NEIC) conducted
a visible emissions observation survey at the Bethlehem Steel Corpora-
tion, Lackawanna Plant, October 23 through 27, November 29, and December
1, 1978. The Lackawanna Plant is an integrated iron and steel mill
located in Lackawanna, New York, south of Buffalo, along Lake Erie
[Figure 1].
EPA Region II and the New York State Department of Environmental
Conservation (NYSDEC) have conducted inspections at the Lackawanna
Plant over the past few years and have documented a number of opacity
violations. EPA Region II prepared and referred a case to the Depart-
ment of Justice who requested that EPA acquire additional visible emis-
sions data to determine current compliance status.
In a memorandum dated August 30, 1978 EPA Region II requested that
the NEIC conduct a visible emissions observation survey at the Lackawanna
Plant coke batteries 8 and 9. The purpose of the survey was to determine
compliance of the coke batteries with the visible emissions limitation
contained in NYSDEC Regulation 214.3 [Appendix A]. Subsequently, on
October 27, 1978 EPA Region II supplemented the request, asking that
the NEIC also determine compliance of the blast furnaces, basic oxygen
furnace (BOF) shop, sintering plant, and scarfing operations with the
visible emissions limitation of NYSDEC Regulation 212.7 [Appendix A].
Prior to the survey, NEIC and EPA Region II personnel inspected the
Lackawanna Plant to familiarize themselves with plant operations and
facilities layout.
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II. SUMMARY AND CONCLUSIONS
From October 23 through 27, 1978 and then again on November 29
and December 1, 1978, five NEIC certified* smoke readers observed visi-
ble emissions at the Bethlehem Steel Corporation, Lackawanna Plant.
The inspection team used EPA Region II procedures to observe charging,
pushing, door, topside and waste heat-stack emissions at the two opera-
ting coke oven batteries 8 and 9. Charging and pushing emissions
were determined by timing the duration of emissions >20% opacity, as
well as the duration of the charge or push. Door leak and topside
leak emissions were determined by first counting the leaking doors,
lids, or standpipes for a battery, then, using Method 9, performing
an observation of the two or three worst emitters. Battery stack
emissions were determined by Method 9. Compliance was determined by
summing without overlap the duration of emissions >20% during a 60-
minute period. A battery was considered to be in violation if the
sum exceeded 3 minutes (180 seconds), the allowable exemption of
NYSDEC Regulation 214.3.
The inspection team used Method 9 to observe fugitive and stack
visible emissions from the three operating blast furnaces C, H, and
J, the BOF shop, sintering plant and the 44-inch and 45 x 90-inch
scarfers. Compliance was determined by summing the individual 15-
second observations which exceeded the emission limitation.
Conclusions drawn from the visible emissions observation data
are as follows:
* Certified to perform visible emissions observations (VEO's) accor-
ding to EPA Method 9 contained in the Code of Federal Regulations,
Part 40, Title 60 - Standards of Performance for New Stationary
Sources, Appendix A, Reference Methods.
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1. Coke oven batteries 8 and 9 violated NYSDEC Regulation
214.3 on all seven days observed. Charging and pushing
emissions alone accounted for violations on most of the
days. When door, topside, and stack emissions were con-
sidered along with charging and pushing emissions, battery
8 exceeded the opacity limitation 28% of the time; battery
9 exceeded the opacity limitation 68% of the time. The
percentage of doors leaking ranged from 11 to 20% for bat-
tery 8 and 35 to 74% for battery 9. The percentage of lids
and standpipes leaking, respectively, on battery 8 ranged
from 0 to 3.1% and 0 to 13% and on battery 9 from 0.3 to
3.9% and 22 to 87%.
2. All other process sources violated NYSDEC Regulation 212.7
(<20% opacity) at least once during the survey. The most
significant violations were recorded at all three blast
furnace cast-house roof monitors and at the sintering plant
east line electrostatic precipitator stack.
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III. PLANT DESCRIPTION
The BSC Lackawanna Plant includes coke oven batteries, blast
furnaces, a basic oxygen furnace (BOF) shop, a sintering plant, and
scarfing operations [Figure 2]. Only coke oven batteries 8 and 9 are
currently operational. Both batteries have 76 ovens numbered 1 through
84, without zeroes. Battery 8 is numbered south to north; battery 9
is numbered north to south. Both batteries are charged and pushed by
the Koppers sequence (i.e. l's, 3's, 5's, 71s, 91s, 2's, 4's, 6's,
8's, l's, 3's, etc.).
Battery 8 is a 3.5 m battery; battery 9 is a 6 m battery. Both
have single collector mains on the pusher side. Battery 8 has 3 charg-
ing ports per oven; battery 9 has 4. Each battery has its own larry
car, quench car, cokeside door machine, and pusher machine; battery 8
has a spare larry car. The larry car for battery 9 has a wet scrubber
as the air pollution control device; the larry cars on battery 8 have
fixed jumper pipes and staged-charging is used. The jumper pipe connects
the adjacent lower numbered oven to the cokeside dropsleeve of the
larry car. Each battery has its own waste heat stack which exhausts
uncontrolled combustion gases.
Blast furnaces C, H and J are currently operational and have the
same production capacity. Each furnace is cast for about 40 minutes
every three hours. The casting schedule during the daylight hours of
the NEIC survey was:
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I
45 x 90 - inch Scarfer Stack
,o
Scrap Yard
,45 X 90 - INCH
SLABBING MILL
Scrubber Stack
COKE OVEN BATTERIES
Cooler Stack
:ntering plant
Scrubber Stacks
Bypass Stack
P ¦ -c
©
W zm
#6. #5
~ ~
#4 #3 #2
zzim—i
Quench Stations
i
BOF BLDG
BOF Bldg.
Roof Monitor
Reladling Station
Baghouse Stacks
BLAST FURNACES
J H G F
I ol lo I I ol lo I
Waste Heat Stacks
C
ESP Stacks
Bypass Stack
Scrubber Stacks
44
r
44-INCH
LOOMING MILL
•Motor Room
inch Scarfer Stack
Reladling Station Roof
Mom tors
Figure 2
i
BETHLEHEM STEEL - LACKAWANNA PLANT LAYOUT
cn
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7
Blast Furnace
Clock
Time
C
0700,
1000,
1300,
1600
H
0800,
1100,
1400,
1700
J
0900,
1200,
1500
Emissions from the blast furnace cast are uncontrolled and vent from
the roof monitor of the cast house.
The BOF shop contains three vessels. Two vessels usually operate
simultaneously, although at different stages, in the steel-making cycle.
Emissions during charging and oxygen blowing are captured by hoods
over the vessels, controlled by a wet scrubber system and exhausted
to the atmosphere through a stack. Fugitive emissions, escaping collec-
tion by the hoods, exhaust uncontrolled through a roof monitor. Re-
ladling emissions are captured by hoods above the two reladling stations,
controlled by a baghouse, and vented from the exhaust side of the
induced draft fans.
The sintering plant consists of identical east and west lines.
The air pollution control systems are identical, but separate for
each line. Windbox emissions are controlled by electrostatic precipi-
tators, and exhausted through a rectangular stack. The end discharge
and other transfer point emissions are controlled by wet scrubbers,
and exhausted through either one of two stacks. Emissions from the
sinter cooler system that services both lines are controlled by a wet
scrubber and exhausted through a stack.
The Lackawanna Plant has two operating scarfers; one is at the
44-inch blooming mill, and the other is at the 45 x 90-inch slab mill.
Emissions from the 44-inch scarfer are controlled by a spray chamber
before being exhausted to the atmosphere through a stack. Emissions
from the 45 x 90-inch scarfer are controlled by a wet scrubber before
being exhausted through a stack.
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8
These process units, except the sinter plant and scarfers, operate
continually, 7 days/week, 24 hours/day. The sintering plant
does not operate the 8 hour day shift on Thursdays. The scarfers1
schedules are variable and intermittent.
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IV. SURVEY METHODS
COKE OVEN BATTERIES
Five inspectors simultaneously observed visible emissions each
day for one or two hour increments at one of the coke oven batteries,
and then repeated the process at the other. EPA Region II1s inspec-
tion procedures were used [Appendix B].
The five inspectors were:
1. charging observer
2. pushing observer
3. pusher side doors and battery stack observer
4. cokeside doors and quench tower observer
5. topsides (lids and standpipes) observer
Charging was observed from on top of the battery on the south
side of the larry car. Because battery 9 has a scrubbing system on
the larry car, the inspector observed the opacity of the emissions
after the water vapor dissipated from the two scrubber stacks. On
both batteries, the inspector observed emissions from the larry car
dropsleeve and charge port interfaces. The start time of the charge
was recorded. Charging emissions >20% opacity were timed with an
accumulating stopwatch. The number of seconds of charging emissions
>20% opacity and the maximum opacity were recorded. With another
stopwatch, the inspector timed the duration of the charge from the
time the first larry car dropsleeve gate was opened until the last
charge port lid was replaced (charge period).
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10
Pushing was observed from about 15 m (50 ft) west of the battery
in line with the oven being pushed. The sky was used as the back-
ground. The inspector recorded the start time and timed with an accu-
mulating stopwatch all pushing emissions >20% from the time the coke
began moving out of the oven until the edge of the quench car moved
past the oven being pushed (push period). The duration of the push
was timed with a second stopwatch. The inspector recorded the time
>20% opacity, the maximum opacity and duration of the push.
A door inspector on the pusher side, and another on the cokeside
conducted a two-step survey of door emissions, a leak and an opacity
segment, by proceeding along his side of the battery from south to
north. During the leak segment, the inspector recorded all doors
which leaked. At the completion of the leak segment, the inspector
made a return traverse along his side of the battery to determine the
two or three worst leaking doors based on the instantaneous opacities
of emissions at the lintel. The inspector positioned himself in a
safe position, as compatible as possible with Method 9, in line with
one of the worst leaking doors to conduct the opacity segment of the
survey. The inspector recorded the pertinent background data (e.g.
start time, oven number, etc.) before beginning a 15-second interval,
six-minute observation of door emissions at the lintel. After ob-
serving the first door, the inspector moved to the second door and
read the door emissions in a like manner. Each inspector then re-
peated both segments of the door survey. In determining the two or
three doors for subsequent six-minute oapcity observations, the in-
spector selected doors with the highest instantaneous emissions
opacities at the lintel, which were also leaking during the preceding
leak segment. Before or after a complete door survey, the pusher
side-door inspector, facing northerly, conducted Method 9 opacity obser
vations of the battery stack. On one day, the cokeside door inspector,
facing northerly, observed two quenches. The observation of quenches
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11
was discontinued because no visible emissions could be seen after the
water vapor cloud dissipated.
The topsides inspector observed lid and standpipe emissions in
the same two-step approach described above for the door inspector.
The leak segment for both lids and standpipes was conducted along the
battery centerline from south to north. The inspector recorded leaking
lids and standpipes. The oven number of an open standpipe or lids
was circled on the data sheet. Similar to a door survey, at the comple-
tion of the leak segment, the inspector selected the two worst leaking
standpipes and facing northerly, conducted two -six-minute, Method 9
opacity observations of emissions, using the sky* as the background.
The inspection procedures (leak segment followed by opacity observa-
tions) was repeated. Subsequent standpipe opacity segments were con-
ducted using the same selection criteria as described above for doors.
Three days into the survey, the hourly observation procedures
for the two door observers and the topsides observer were changed as
follows to minimize collection of overlapping VEO data:
0 to 6 minutes - pusher side door inspector (PSD) performs VEO1s
of battery stack; cokeside door inspector (CSD) and topsides
inspector (T) begin and CSD inspector also completes leak segment
traverse.
6 to 12 minutes - CSD performs opacity segment of worst leaking
door; PSD begins and T completes leak segment.
12 to 18 - T performs opacity segment of worst leaking standpipe;
PSD completes leak segment.
* It was necessary to use the collector main as the background at
some locations on battery 9.
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18 to 24 - PSD performs opacity segment of worst leaking door.
24 to 30 - CSD performs opacity segment of second worst leaking
door.
30 to 36 - T performs opacity segment of second worst leaking
standpipe.
36 to 42 - PSD performs opacity segment of second worst leaking
door.
42 to 48 - CSD performs opacity segment of third worst leaking
door; PSD begins the second leak segment.
48 to 54 - T performs opacity segment of third worst leaking
standpipe; CSD begins and PSD completes second leak segment.
54 to 60 - T begins and T and CSD complete second leak segment.
OTHER SOURCES
At the blast furnace cast house an inspector observed emissions
from the roof monitor at the point of greatest opacity during a cast.
The inspector positioned himself in a safe location, as compatible as
possible with Method 9. The inspector moved to the furnace next to
cast at the completion of the first furnace's cast.
At the BOF shop, two inspectors were positioned south of the
building; using Method 9 one inspector observed emissions from the
scrubber stack, and the other observed emissions from the building
roof monitor. The stack and roof monitor were observed for at least
one hour. Sometimes one observer observed both the stack and
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roof monitor, while the second observer observed visible emissions
from the reladling station roof monitors and/or baghouse outlet
stacks.
At the sintering plant, inspectors were located on the southeast
and southwest or west sides of the building. Using Method 9 each
inspector observed the windbox ESP stack and the operating scrubber
stack for his line, simultaneously. The sinter cooler stack was ob-
served once. No more than two stacks were read by one observer at
any one time.
One inspector, using Method 9 performed VEO's at either the
44-inch blooming mill or the 45 x 90-inch slab mill scarfer stacks.
Observations were made for at least one hour.
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V. SURVEY RESULTS
COKE OVEN BATTERIES
NYSDEC Regulation 214.3 allows a coke oven battery to emit >20%
opacity for no more than 3 minutes during any consecutive 60-minute
period.
Batteries 8 and 9 were each observed for 9 one-hour periods
during the 7 days. During those periods 5 inspectors were observing
visible emissions as discussed in Section IV. The individual observa-
tions by day for each inspector position are tabulated in Appendix C.
The daily summation of all inspectors' individual observations,
without overlap, are presented in Table 1.
For battery 8, the actual time of observation for each one-hour
period ranged from 24 minutes 45 seconds to 57 minutes [Table 1].
The length of time the opacity was >20% ranged from 10 minutes to 40
minutes [Table 1]. On the average, the number of minutes the opacity
was >20% was 47% of the length of observation time [Table 2]. Battery
8 was not in compliance with NYSDEC Regulation 214.3 28% of the time
[Table 2].
For battery 9, the actual time of observation for each one-hour
period ranged from 36 minutes 45 seconds to 57 minutes 30 seconds
[Table 1]. The length of time the opacity was >20% ranged from 26
minutes 45 seconds to 56 minutes 45 seconds [Table 1]. On the average,
the number of minutes the opacity was >20% was 88% of the length of
observation time [Table 2]. Battery 9 was not in compliance with
NYSDEC Regulation 214.3 68% of the time.
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Visible emission observation (VEO) results for charging [Table
3], pushing [Table 4], doors [Table 5], and topsides [Table 6] are
reviewed below.
Charging
Battery 8 - NYSDEC Regulation 214.3 was exceeded for charging on
October 23 and 24, 1978 [Table 3]. Opacity >20% for an individiual
charge varied between 12 and 84 seconds. The maximum opacity for an
individual charge varied between 30 and 100%. Thirty-seven charges
were observed on 7 different days.
Battery 9 - NYSDEC Regulation 214.3 was exceeded for charging
alone twice on both October 25 and 26, 1978 and once on both October
27 and December 1, 1978 [Table 3]. Opacity >20% varied between 7 and
155 seconds. The maximum opacity for an individual charge varied
between 35 and 100%. Thirty charges were observed over 7 days.
Pushing
Battery 8 - NYSDEC Regulation 214.3 was exceeded for pushing on
October 24 and 25, and on November 29, 1978 [Table 4]. Opacity >20%
for an individual push varied between 22 and 52 seconds. The maximum
opacity for 36 pushes was 100%; the maximum opacities for the other 4
pushes were 45, 75, 80 and 95%. Forty pushes were observed on the 7
different days. On the average, the number of seconds the opacity
was >20% was 78% of the duration of the push period. On October 26
and 27, and on December 1, 1978 the total duration of the push period
for all pushes during any one-hour period was less than 3 minutes,
thus NYSDEC Regulation 214.3 could not have been exceeded for pushing.
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16
Battery 9 - NYSDEC Regulation 214.3 was exceeded for pushing
twice on October 25 and 26, 1978 and once on October 23 and 27, and
December 1, 1978 [Table 4]. Opacity >20% varied between 42 and 88
seconds. The maximum opacity for all 40 pushes observed was 100%.
On the average, the number of seconds the opacity was >20% was 91%
of the duration of the push period. On October 24 and November 29
the total duration of the push periods for all pushes observed during
the two one-hour observation periods was less than 3 minutes, thus
NYSDEC Regulation could not have been exceeded for pushing alone.
Doors
Battery 8 - The number of doors leaking for an individual tra-
verse ranged form 5 to 19 on the pusher side and from 9 to 18 on the
cokeside [Table 5]. The percentage of all doors leaking ranged from
11 to 20%. Sixteen and 19 door observation traverses were conducted
on the pusher side and on the cokeside, respectively.
Battery 9 - The number of doors leaking for an individual traverse
ranged from 28 to 60 on the pusher side and from 25 to 54 on the
cokeside [Table 5]. The percentage of all doors leaking ranged from
35 to 74%. Eighteen and 19 door observation traverses were conducted
on the pusher side and on the cokeside, respectively.
Topsides
Battery 8 - Seventeen topside (lid leaks and standpipe leaks)
observation traverses were conducted. Percent lid leaks and stand-
pipe leaks for an individual traverse ranged from 0 to 3.1% and from
0 to 13%, respectively [Table 6].
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17
Battery 9 - Eighteen topsides observation traverses were conducted
[Table 8]. Percent lid leaks and standpipe leaks ranged from 0.3 to
3.9 percent and from 22 to 87 percent, respectively [Table 6],
OTHER SOURCES
VEO results for emissions from the blast furnaces, BOF shop,
sintering plant, and scarfers are also presented in Table 1 and 2.
NYSDEC Regulation 212.7 allows <20% opacity from any process sources,
with no time exception for >20% opacity. However, data for the
individual process sources [Table 1] have been reduced to no longer
than 60-minute observation periods, even when the observation period
was longer than an hour.
No source was always in compliance with NYSDEC Regulation 212.7.
However, the BOF shop reladling station roof monitor and both sets of
sintering plant scrubber stacks were in compliance on at least one
occasion [Table 1]. In addition, the BOF shop reladling station bag-
house exhausts, and sintering plant west line ESP stack were out of
compliance <5% of the observation time on at least one occasion
[Table 1].
Blast furnace cast-house roof monitor emissions were observed
>20% opacity 50 to 60% of the time observed [Table 2]. The BOF shop
scrubber stack, building roof monitors, reladling station roof moni-
tors, and reladling station baghouse exhausts were observed to be
>20% opacity 16%, 12%, 6% and 10%, respectively, of the time they
were each observed [Table 2]. At the sintering plant, the east line
ESP stack was >20% opacity 61% of the time observed, whereas the west
line ESP was >20% only 31% of the time [Table 2]. Both sets of
scrubber stacks were >20% opacity less than 1% of the time observed
[Table 2]. The cooler scrubber stack was >20% opacity for 7% of the
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18
time it was observed October 25, 1978 [Tables 1 and 2]. The 44-inch
scarfer stack was >20% opacity 32% of the time observed; the 45 x
90-inch scarfer stack was >20%, 19% of the time [Table 2].
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19
Table 1
DAILY EMISSIONS SUMMARY
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
(1978)
Range of
Start
End
Minutes of
Readi ngs
No. Of Mil
Source
Time
Time
Observation
(%)
> 20% Opai
Battery 8
1531
1631
53.00
0-100
35.00
Battery 9
1427
1527
49.75
15-100
48.25
BF Cb
1554
1654
60.00
0-35
14.25
1654
1700
6.00
0-35
5.75
Battery 8
0832
0932
50.75
0-75
19.25
Battery 9
1044
1144
50.75
5-100
44.00
BF C
1611
1635
18.75
0-35
8.00
BF H
1356
1453
57.00
5-40
48.50
BF J
1507
1552
45.00
20-100
45.00
BOF SSC
1003
1103
60.00
0-65
7.00
1103
1111
8.00
0-25
1.25
1334
1434
60.00
0-100
11.00
1438
1538
60.00
0-100
16.00
BOF BRM
1439
1539
60.00
0-75
13.25
1550
1650
60.00
0-100
9.75
BOF RLSRMe
1620
1645
25.00
0-80
8.50
SPE ESPf
1341
1441
60.00
5-45
9.00
1456
1556
60.00
5-40
16.00
1614
1626
12.00
10-20
1.00
SPE SSg
1341
1441
60.00
0-20
0.75
1456
1556
60.00
0-10
0.00
1614
1626
12.00
5-10
0.00
SPW ESP
1336
1436
60.00
0-40
15.00
1455
1555
60.00
5-40
2.25
1614
1631
17.50
5-50
1.00
SPW SS
1336
1436
60.00
5
0.00
1455
1555
60.00
5-20
1.50
u
1614
1631
17.50
5-15
0.00
44" SSn
1019
1119
60.00
0-40
19.50
1350
1450
60.00
0-60
3.25
Battery 8
1335
1435
57.00
5-100
40.00
1435
1535
44.75
0-100
19.50
Battery 9
1530
1630
53.25
5-100
49.50
1630
1730
55.50
10-100
54.25
BF C
0952
1052
60.00
0-50
28.25
1052
1106
13.50
0-100
8.25
1311
1353
42.25
0-100
4.50
BF H
0810
0910
60.00
0-100
45.25
10-23
10-24
10-25
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20
Table 1 (Cont'd.)
DAILY EMISSIONS SUMMARY
BETHLEHEM STEEL - LACKAWANNA PLANT
Range of
Date Start End Minutes of Readings No. of Minutes
(1978) Source Time Time Observation (%) > 20% Opacity
BOF SS
0810
0910
60.00
0-25
5.00
0910
1010
60.00
0-30
17.75
1010
1110
60.00
0-45
9.75
1110
1124
14.50
0-25
1.25
BOF BRM
0815
0915
60.00
0-40
0.50
0915
1015
60.00
0-100
6.25
1015
1115
60.00
0-45
6.25
BOF RLSRM
0941
1011
30.00
0
0.00
1023
1123
60.00
0-5
0.00
BOF RLSB1
1040
1131
51.00
0-100
1.00
SPE ESP
0817
0917
60.00
15-50
59.75
0930
1030
60.00
20-100
60.00
1042
1132
50.25
0-80
15.00
SPE SS
0817
0917
60.00
0-5
0.00
0930
1030
60.00
0-10
0.00
1042
1110
29.00
0
0.00
SP CSSJ
1116
1127
11.25
0-25
0.75
SPW ESP
0822
0922
60.00
5-20
3.50
1005
1105
60.00
0-20
1.25
44" SS
1425
1525
60.00
0-100
23.25
1532
1632
60.00
0-100
25.75
1638
1716
38.00
0-80
13.00
Battery 8
0940
1040
24.75
0-100
10.00
1513
1613
44.75
0-100
16.25
Battery 9
0830
0930
52.00
0-100
34.00
1330
1430
57.50
15-100
56.75
BF H
0807
0848
40.50
5-35
18.00
1436
1449
13.00
5-30
7.75
BF J
0918
1005
47.00
5-95
16.50
1415
1428
12.50
5-45
3.75
1553
1621
18.75
0-50
8.25
BOF SS
1353
1424
31.00
0-20
0.50
BOF RLSB
1450
1550
60.00
0-100
7.25
44" SS
1325
1406
41.00
0-100
17.00
Battery 8
1000
1100
38.50
0-100
12.75
Battery 9
0830
0931
53.50
0-100
44.75
BF C
1035
1135
60.00
10-100
57.00
1323
1351
28.00
10-45
17.75
-------
21
Table 1 (Cont1d.)
DAILY EMISSIONS SUMMARY
BETHLEHEM STEEL - LACKAWANNA PLANT
Range of
Date Start End Minutes of Readings No. of Minutes
(1978) Source Time Time Observation (%) > 20% Opacity
BF H
0815
0915
60.00
0-50
15.25
BF J
0918
0954
30.00
0-80
23.00
1207
1301
54.25
0-100
29.00
BOF SS
1140
1240
60.00
0-100
8.25
1247
1347
60.00
0-100
9.25
BOF BRM
1142
1242
60.00
0-55
8.00
1242
1342
60.00
0-100
6.00
BOF RLSRM
1142
1242
60.00
0-5
0.00
1242
1342
60.00
0-100
5.25
BOF RLSB
1307
1347
40.00
0-100
7.00
SPE ESP
1130
1222
52.00
20-45
52.00
1236
1241
6.25
25-45
5.75
SPE SS
1130
1223
53.00
5-20
2.25
SPW ESP
1135
1235
60.00
10-80
56.75
1300
1330
30.00
15-90
28.50
SPW SS
1135
1235
60.00
0-20
0.75
1300
1330
30.00
0-5
0.00
45x90" SSK
1155
1255
60.00
0-40
12.75
1255
1340
45.00
0-30
7.25
Battery 8
1520
1620
33.50
0-100
12.25
Battery 9
1410
1510
36.75
10-100
26.75
Battery 8
1353
1453
31.25
0-100
13.00
Battery 9
1500
1600
41.75
5-100
36.50
a - To the nearest 15 seconds Cs minute)
b - BF C = Blast Furnace C
c - BOF SS = BOF Shop Scrubber Stack
d - BOF BRM = BOF Shop Building Roof Monitor
e - BOF RLSRM = BOF Shop Reladling Station Roof Monitor
f - SPE ESP = Sinter Plant (Eastline) Electrostatic Precipitator Stack
g - SPE SS = Sinter Plant (Eastline) Scrubber Stack
h - 44" SS = 44 inch Blooming Mill Scarfer Stack
i - BOF RLSB = BOF Shop Reladling Station Baghouse
j - SP CSS = Sinter Plant Cooler Scrubber Stack
k - 45 x 90" SS = 45 x 90 inch Slab Mill Scarfer Stack
-------
22
Table 2
SOURCE EMISSIONS SUMMARY
BETHLEHEM STEEL - LACKAWANNA PLANT
Minutes3 of No. of Minutes3 % of Time .
Source Observation > 20% Opacity > 20% Opacity
Battery 8
378.25 (540)C
178.00 (151.00)d
47 (28)
Battery 9
450.25 (540)C
394.75 (367.75)d
88 (68)
BF Cf
288.50
143.75
50
BF H
230.50
134.75
58
BF J
207.50
125.50
60
B0F SS9
533.50
87.00
16
B0F BRMh
420.00
50.00
12
B0F RLSRM1
235.00
13.75
6
B0F RLSBJ
151.00
15.25
10
SPE ESPk
360.50
218.50
61
SPE SS1
334.00
3.00
1
SPW ESP
347.50
108.25
31
SPW SS
227.50
2.25
1
SP ccsm
11.25
0.75
7
44" SSn
319.00
101.75
32
45 x 90" SS°
105.00
20.00
19
a To the nearest 15 seconds (k minute)
b (Number of minutes > 20% -r number of minutes process observed) x 100
c Actual number of minutes the battery was observed followed by the number of
total minutes for the 9 one-hour observation periods in ( ).
d Actual number of minutes the battery emissions were > 20% opacity followed
by the number of minutes the battery emissions exceeded the State regulation
in ( ). The value in ( ) is 27 minutes less than the preceding value
because the State regulation exempts 3 minutes > 20% for each consecutive
60 minute period.
e (Number of minutes battery exceeded the State regulation r number of total
minutes for the 9 one-hour observation periods) x 100.
f BF C = Blast Furnace C.
g B0F SS = B0F Shop Scrubber Stack,
h B0F BRM = B0F Shop Building Roof Monitor,
i B0F RLSRM = B0F Shop Reladling Station Roof Monitor,
j B0F RLSB = B0F Shop Reladling Station Baghouse.
k SPE ESP = Sinter Plant (Eastline) Electrostatic Precipitator Stack.
1 SPE SS = Sinter Plant (Eastline) Scrubber Stack,
m SP CSS = Sinter Plant Cooler Scrubber Stack,
n 44" SS = 44-inch Blooming Mill Scarfer Stack,
o 45 x 90" SS = 45 x 90-inch Slab Mill Scarfer Stack.
-------
Table 3
CHARGING DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
Oven
Charge
Duration3
No. of Seconds
Maximum
(1978)
Number
Start
(Mi n:Sec)
>20% Opacity*5
Opacity (%)
BATTERY 8
10-23
858
1531
5:34
48
80
868
1548
6:16
71
100
878
1607
5:11
42
100
801
1624
6:02
34 (195)
70
10-24
838
0818
6:57
31
85
848
0832
4:47
42
80
858
0846
3:59
40
75
868
0903
5:59
59 (172)
65
878
0919
4:27
33
75
801
0931
5:09
79
100
811
0943
4:55
48
95
821
0954
5:06
84 (244)
100
10-25
842
1335
4:58
39
50
852
1344
4:29
12
80
862
1410
4:42
17
60
872
1422
4:31
21 (89)
50
882
1436
5:48
12
70
804
1506
5:48
35
80
814
1517
4:49
26 (73)
80
10-26
884
0942
4:34
14
30
806
0955
4:07
12
30
816
1006
5:15
27 (53)
35
871
1513
5:27
15
80
881
1529
6:41
17
100
803
1547
5:22
12 c
80
813
1609
6:29
12 (56)
80
10-27
873
0959
5:38
34
45
883
1020
5:07
17
65
805
1036
4:54
41
65
815
1051
4:44
22 (114)
65
11-29
833
1536
6:08
36
50
843
1549
6:00
24
50
853
1606
5:01
34
60
863
1618
6:10
40 (134)
60
12-1
846
1400
3:40
57
60
856
1413
3:30
57
80
866
1425
3:10
45 (159)
55
-------
24
Table 3 (Cont'd.)
CHARGING DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
Oven
Charge
Duration3
No. of Seconds
Maximum
(1978)
Number
Start
(Mi n:Sec)
>20% Opacity'3
Opacity (%)
BATTERY 9
10-23
903
1421
3:36
7
40
913
1434
3:26
97
60
923
1513
4:49
49 (153)
50
10-24
923
1030
2:50
29 (29)
65
10-25
952
1535
2:55
56
80
962
1546
3:10
56
80
976
1559
2:42
52
80
982
1611
3:03
54 (218)
100
904
1643
2:40
46
60
914
1653
2:50
42
60
924
1706
2:53
38
80
934
1719
3:01
97
100
944
1729
2:51
73 (296)
80
10-26
979
0831
3:15
153
70
912
0855
3:07
135
60
922
0909
2:41
106
60
932
0922
2:34
100 (494)
50
906
1402
4:37
155
100
916
1415
3:31
47
100
926
1425
3:51
64
80
936
1443
2:52
23 (289)
40
10-27
926
0843
2:29
108
80
946
0903
3:00
124
80
956
0918
3:09
45
45
966
0929
2:36
51 (328)
35
11-29
974
1504
3:15
61 (61)
70
12-1
975
1506
2:40
54
40
907
15 22
2:26
140
100
917
1543
2:37
118
60
927
1559
2:38
117 (429)
60
a Duration of charge period: the time period between when the first
larry car hopper gate is opened and when the last charge port lid is
replaced.
b Discrete 60 minute totals in ( ); State regulation allows 180 seconds
per consecutive 60 minutes,
c Total is for longer than 60 minutes.
-------
Table 4
PUSHING DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
Oven
Push
Duration3
No. of Seconds
Maximum
(1978)
Number
Start
(Min:Sec)
>20% Opacity'3
Opacity (%)
BATTERY 8
10-23
878
1537
0:57
34
100
801
1558
0:49
38
100
811
1610
0:57
37
100
821
1629
0:47
32 (141)
100
10-24
858
0826
0:55
41
100
868
0831
0:59
33
100
878
0850
0:52
41
100
801
0912
0:53
47
100
811
0924
0:53
41 (203)
100
821
0936
0:51
38
100
831
0948
0:53
41
100
841
0959
1:02
41 (120)
100
10-25
862
1350
0:42
35
100
872
1359
0:28
27
100
882
1414
0:40
33
100
804
1429
0:41
38
100
814
1438
0:59
52
100
824
1449
0:58
52 (237)
100
834
1510
0:54
39
100
844
1525
1:04
39 (78)
75
10-26
816
0950
0:41
35
100
826
1002
0:37
29 (64)
100
881
1505
0:41
37
100
803
1521
0:40
36
100
813
1537
0:39
28
100
823
1552
0:40
32 (133)
100
833
1606
0:42
35 (35)
100
10-27
873
0942
0:32
30
100
883
0952
0:25
23
100
805
1007
0:30
29
100
815
1027
0:32
30 (112)
100
11-29
833
1518
0:49
49
100
843
1529
0:36
22
45
853
1544
0:40
30
100
863
1556
0:42
27
100
873
1607
0:39
22
95
883
1617
0:48
39 (189)
100
-------
Table 4 (Cont1d.)
PUSHING DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date Oven Push Duration3 No. of Seconds Maximum
(1978) Number Start (Min:Sec) >20% Opacity'3 Opacity (%)
12-1 856 1353 0:37 27 80
866 1403 0:41 32 100
876 1427 0:38 28 (87) 100
BATTERY 9
10-23
10-24
10-25
10-26
10-27
913
1415
1:01
52
100
923
1425
0:59
52
100
933
1435
1:04
58
100
943
1446
0:58
51 (213)
100
923
1014
0:51
46
100
933
1025
0:59
50
100
943
1136
0:57
44 (140)
100
962
1531
0:59
43
100
976
1542
0:59
51
100
982
1604
1:00
53
100
904
1624
0:56
46 (193)
100
914
1638
0:57
47
100
924
1649
1:00
54
100
934
1702
0:57
47
100
944
1711
0:57
54
100
954
1724
0:58
42 (244)
100
912
0843
0:53
53
100
922
0851
0:56
52
100
932
0907
1:00
53
100
942
0919
0:51
51
100
952
0932
0:57
55 (264)
100
906
1354
1:03
60
100
916
1409
1:00
53
100
926
1418
0:56
53
100
936
1425
0:57
53
100
946
1434
0:55
52 (271)
100
926
0825
1:03
63
100
936
0836
0:53
53
100
946
0848
1:10
57
100
956
0859
0:50
49
100
966
0911
0:52
52
100
976
0924
0:49
45 (319)
TOO
-------
27
Table 4 (Cont1d.)
PUSHING DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date Oven Push Duration3 No. of Seconds Maximum
(1978) Number Start (Min:Sec) >20% Opacity'3 Opacity (%)
984
1414
0:51
50
100
906
1429
0:57
57
(107)
100
907
1503
0:49
48
100
967
1515
1:25
83
100
917
1529
0:54
54
100
927
1540
1:03
48
100
937
1558
1:28
88
(321)
100
947
1606
0:52
47
(47)
100
a Duration of push period: the time period between when the coke
begins moving out of the oven and when the edge of the quench car
moves past the oven being pushed,
b Discrete 60 minute totals in ( ); State regulation allows 180 seconds
per consecutive 60 minutes.
-------
I
Table 5
DOOR DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
PSa Leak Survey
CSb Leak
Survey
(1978)
Start Time
End Time
A
B
C
D
E
Start Time
End Time
F
G
H
I
BATTERY
8
10-23
1535
1538
0
11
1
12
16
1532
1539
17
22
29
19
1602
1605
0
10
1
11
14
1606
1611
16
21
27
18
10-24
0821
0825
0
10
1
11
14
0819
0827
12
16
23
15
0905
0910
1
14
4
19
25
0847
0855
12
16
31
20
0917
0923
11
14
0945
0950
13
17
10-25
1331
1334
9
2
0
11
14
1327
1332
18
24
29
19
1400
1403
10
0
2
12
16
1350
1355
16
21
28
18
1410
1414
15
20
1428
1431
6
2
1
9
12
1435
1439
13
17
22
14
1459
15Q2
6
2
1
9
12
1506
1511
12
16
21
14
10-26
0957
1001
0
10
0
10
13
0945
0952
9
12
19
13
1500
1508
9
12
1549
1553
6
0
1
7
9
1554
1603
9
12
16
11
10-27
1010
1015
2
8
4
14
18
1000
1007
15
20
29
19
1050
1054
1
3
2
6
8
1033
1038
18
24
24
16
11-29
1510
1514
3
10
1
14
18
1510
1512
10
13
24
16
1620
1624
4
9
0
13
17
1621
1623
15
20
28
18
12-1
1357
1400
1
4
1
6
8
1355
1400
11
14
17
11
1443
1445
3
1
1
5
7
BATTERY
9
10-23
1415
1419
6
29
8
43
57
1415
1428
48
63
91
60
1509
1512
5
32
4
41
54
1450
1500
41
54
82
54
10-24
1003
1010
6
27
14
47
62
1015
1021
39
51
86
57
1046
1051
6
31
10
47
62
1040
1046
39
51
86
57
1128
1135
6
28
5
39
51
1115
1121
49
64
88
58
10-25
1510
1516
12
16
11
39
51
1538
1544
14
12
14
40
53
1528
1535
44
58
84
55
1609
1553
1558
49
64
16]4
8
21
8
37
49
1624
1630
40
53
77
51
1641
1645
16
19
9
44
58
1647
1655
38
50
82
54
1720
1725
41
54
-------
Table 5 (Cont'd )
DOOR DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Date
(1978)
PSa Leak
Survey
A
B
C
0
E
CSb Leak
Survey
F
G
H
I
Start Time
End Time
Start Time
End Time
10-26
0843
0849
1
35
7
43
57
0829
0842
34
45
77
51
0920
0926
2
36
9
47
62
1330
1336
48
63
1418
1426
14
24
8
46
61
1418
1422
47
62
93
61
10-27
0840
0850
5
37
9
51
67
0830
0839
54
71
105
69
0920
0925
1
38
21
60
79
0929
0937
53
70
113
74
11-29
1425
1430
12
12
4
28
37
1410
1414
25
33
53
35
1455
1500
10
25
3
38
50
1457
1459
30
39
68
45
12-1
1510
1513
9
18
1
28
37
1502
1510
46
61
74
49
1558
1601
21
8
0
29
38
1555
1603
50
66
79
52
a PS = pusher side
b CS = coke side
A = number of PS leaks (door only)
B = number of PS leaks (chuck door only)
C = number of PS leaks (both door and chuck door)
D = total PS leaks, l e A + B + C
E = percent PS leaks, l e 0 r 76
F = number of CS leaks
G = percent CS leaks, i e F - 76
H = total leaks, i e D +¦ F
I = percent total leaks, l e H - 152
-------
30
Table 6
TOPSIDES DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
Leak Survey
Lid
Leaks
Standpipe Leaks
(1978)
Start Time
End Time
No.
%a
No.
%b
BATTERY
8
10-23
1527
1533
1
0.4
2
2.6
1554
1600
2
0.9
6
7.9
10-24
0920
0925
3
1.3
4
5.3
0945
0949
4
0.9
3
3.9
10-25
1327
1338
7
3.1
10
13
1400
1408
5
2.2
9
12
1449
1456
5
2.2
7
9.2
1519
1524
6
2.6
6
7.9
10-26
0941
0950
1
0.4
3
3.9
1459
1504
5
2.2
4
5.3
1606
1611
2
0.9
4
5.3
10-27
1000
1006
6
2.6
6
7.9
1101
1106
7
3.1
7
9.2
11-29
1525
1530
2
0.9
3
3.9
1602
1609
6
2.6
3
3.9
12-1
1346
1350
1
0.4
0
0
1431
1434
0
0
0
0
BATTERY
9
10-23
1415
1425
2
0.7
22
29
1445
1453
2
0.7
23
30
10-24
1015
1023
5
1.6
43
57
1045
1055
10
3.3
47
62
1120
1127
12
3.9
48
63
10-25
1531
1542
8
2.6
41
54
1544
1602
4
1.3
43
57
1617
1625
5
1.6
49
64
1644
1654
1
0.3
51
67
-------
31
Table 6 (Cont'd)
TOPSIDES DATA
BETHLEHEM STEEL - LACKAWANNA PLANT
(1978)
Leak Survey
Lid
Leaks
Standpipe Leaks
Start Time
End Time
No.
%a
No.
%b
10-26
0830
0844
4
1.3
50
66
1330
1377
6
2.0
52
68
1433
1440
11
3.6
52
68
10-27
0830
0838
5
1.6
62
82
0932
0938
3
1.0
66
87
11-29
1410
1418
3
1.0
17
22
1447
1451
3
1.0
18
24
12-1
1500
1507
8
2.6
55
72
1543
1555
2
0.7
57
75
a [No. of lid leaks -r (76 x 3)] x 100 for battery 8;
[No. of lid leaks -r (76 x 4)] x 100 for battery 9.
b [No. of standpipe leaks t 76] x 100.
-------
APPENDICES
APPENDIX A - NYSDEC REGULATIONS 214.3 AND 212.7
APPENDIX B - EPA REGION II COKE OVEN BATTERY INSPECTION PROCEDURES
APPENDIX C - OBSERVATION SUMMARIES BY INSPECTOR POSITION FOR COKE
OVEN BATTERIES
-------
APPENDIX A
NYSDEC REGULATIONS 214.3 AND 212.7
-------
NYSDEC Regulation 214.3:
"Smoke emissions. After December 31, 1974, or
such later date as determined by an order of
the Commissioner, no person shall operate a
by-product coke oven battery which emits a
smoke equal to Ringelmann No. 1 or 20% opacity,
(b) Such person who operates a by-product coke
oven battery shall be allowed an emission of
smoke from the battery of greater than Ringleman
No. 1 or 20% opacity if such emission continues
for a period or periods aggregating no more
than three minutes of any consecutive 60 minute
period.
NYSDEC Regulation 212.7:
"Opacity of emissions limited. No person shall
cause or allow emissions having an opacity of
20% or greater from any process or exhaust
and/or ventilation system to be emitted to the
atmosphere, except only the emission of uncombined
water."
-------
APPENDIX B
EPA REGION II COKE OVEN BATTERY INSPECTION PROCEDURES
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
DAT*
MAY j iJ/d
sub;ect
FROM
TO-
Region II Method for Evaluating By-Product Coke Oven
Battery Compliance With New York. State Visible Emissions
Regulations
Richard Craig
Environmental tngin
Air Facilities Branch
Robert N. Ogg, P.E., Chief
New York/Virgin Islands Section
Air Facilities Branch
The following is a description of the procedures this Region uses when
inspecting coke oven batteries for compliance with the existing New York
State "three minute rule", NYCRR Part 214.3(b). The procedures are based
on NSPS Reference Method 9 (40 CFR 60, Appendix A) and conform to Method 9
requirements whenever possible. However, as you know, due to the nature
of the source and its several types of emission points, certain modifications
to Method 9 — notably the accumulating stopwatch — have been made.
cc: K. Eng
W. Mugdan
EPA FORM 1 320-C 'nSV. 3-7*1
-------
U.S. EPA Region II
Coke Oven Visible Emissions
Compliance Determination Procedures
Used in New York State
Part 214 of Title 6 of The Official Compilation of Codes Rules and Reculations of t?
State of New York provides for the control of air pollution from by-product
coke oven batteries by regulating the allowable opacity of visible emissions
from a battery. The regulation states, in relevant part:
3(b) Such person who operates a by-product coke oven battery
shall be allowed an emissi'on of smoke from the battery of
greater than Ringlemann ft 1 or 20% opacity if such emission
continues for a period or periods aggregating no more than
three minutes of any consecutive 60 minute period.
The following procedures are presently used by Region II to determine
compliance with this regulation.
An inspection team consisting of a minimum of 3 inspectors (one each for the
coke, top and push sides) shall perform visible emissions evaluations as
specified below. The entire inspection shall be performed in a period of
time totaling at least 60 consecutive minutes. Prior to commencing the
inspection, the inspectors will synchronize their watches and record necessary
environmental parameters, e.g. wind direction, cloud cover, sun angle, temperature
and relative humidity.
I. Topside
A. Charging
The inspector shall assume a position compatible with Method 9 requirements
for sun angle and to the extent possible, wind direction, viewing single
plumes, etc., approximately five to ten ovens from the oven being charged.
The opacity of emissions shall be evaluated against the background with
the greatest available contrast.
Observations of the opacity of emissions from charging shall be made continuously
from the time the first larry car hopper gate is opened until the last topside
port lid is replaced.
The duration of emissions with an opacity greater than 20£ shall be recorded
on at accumulating stopwatch which shall be started wnenever the observer
reads emissions of such opacity and shall be stopped whenever emissions of
such opacity are no longer present.
The observer will evaluate the opacity of emissions from the charging
operation at the point of greatest opacity. Switching observation
from one charging emission to another is permissible.
-------
2
In this manner the stopwatch will accumulate the total length of time
the opacity of emissions exceeded 20% during the charge.
The maximum opacity observed shall also be recorded.
Both the starting and ending times of the period of observation of the
charge shall be recorded.
B. Charging Port Lids and Standpipes
The inspector shall first proceed down the center of the battery looking
left and right for leaking lids and standpipes. The total numbers
of lids and standpipes found leaking visible emissions of any opacity
shall be recorded. Standpipes being decarbonized will be included.
As time permits, the inspector shall return to individual lids and
standpipes and evaluate the opacity of their emissions.
When observing individual lid or standpipe emissions, the inspector shall
assume a position compatible with Method 9 requirements for sun angle,
and to the extent possible, wind direction, viewing single plumes, etc.
Opacities shall be evaluated against the background with the greatest
available contrast.
Readings shall be taken and recorded at 15-second intervals.
Both the starting and ending times of the observation period for each lid
or standpipe shall be recorded.
II. Coke Side
A. Pushing
The inspector shall assume a position compatible with Method 9 requirements
(as above) approximately AO to 60 feet from the base of the battery. Opacities
shall be evaluated against the sky immediately above the battery.
Observations of the opacity of emissions from pushing shall be made
continuously from the time the coke begins moving out of the oven
until the edge of the quench car moves past the oven being pushed.
The duration of emissions with an opacity greater than 20%. shall be
recorded on an accumulating stopwatch as described above for charging
emissions.
-------
3
In this manner, the stopwatch will accumulate the total length of time the opacit
of emissions exceeded 20% during the push. The maximum opacity observed shall
be recorded.
Both the starting and ending times of the observation of the push shall be
recorded.
B. Coke Side Doors
The inspector shall first proceed along the side of the battery and record
the identity of doors leaking visible emissions of any opacity.
As time permits, the inspector shall return to individual doors and evaluate
the opacity of their emissions.
When observing individual doors, the inspector shall assume a position
compatible with Method 9 requirements, as above, approximately 40 to 60
feet from the battery. If both the emissions and the observer are well
inside the shadow of the battery, no consideration for sun angle is
necessary during observation.
The opacity of emissions from leaking doors shall be read against the* lintel
above the door regardless of the point of origin around the door.
The opacity of emissions read against the lintel should be evaluated as near
to directly above the oven door of origin as possible. Care should be taken
to observe individual plumes only.
Readings shall be taken at 15-second intervals.
Both the starting and ending times of the observation of each door shall
be recorded.
III. Push Side
A. Pushing
Emissions from pushing are not read from the push side of the battery.
B. Doors
Door leaks on the pushing side of the battery shall be treated in the same
manner as those on the coke side of the battery. (See II.B above)
This shall apply to both oven and leveling or chuck doors.
IV. Waste Heat Stack
The opacity of emissions from the waste heat stack shall be read and recorded
- ¦¦ star tin ?. and ending times of the observation shal.1
-------
4
V. Quench Towers
The opacity of emissions from the quench tower is read continuously and recorded
with an accumulating stopwatch technique as described above.
The opacity of quenching emissions shall be evaluated only when emissions are
clearly visible after the dissipation of condensed water vapor.
The starting and ending times of the quench shall be recorded.
VI. Data Reduction
Our policy is that the duration of emissions greater than 20% opacity for
all sources of emissions observed during a sixty minute period shall be
summed without overlap.
A battery shall be found in violation of NYCRR Part 214.3(b) if this total
exceeds three minutes.
In the event of overlapping (i.ereadings taken during the same time period)
sets of readings, the procedures listed below have been followed.
a. For sets of readings all recorded by the accumulating stopwatch
method and whose observation periods overlap, retain only the set of readings
showing the longest time of violation.
b. For overlapping sets of readings all recorded at 15-secand intervals,
retain the individual reading showing the highest opacity for each such
15-second interval where overlap occurs.
This shall be done whether the two 15-second intervals coincide or only
partially overlap. However, each reading may only count for one 15-second
interval.
c. In the event of overlapping sets of readings recorded by the tvo
different methods, all readings of the sets showing the shorter period(s)
of violation are discarded, except that readings recorded at 15-second
intervals shall only be discarded up to the total length of the accumulating
stopwatch method observation period with which they overlap.
No averaging of individual readings is employed.
-------
APPENDIX C
OBSERVATION SUMMARIES BY INSPECTOR POSITION FOR COKE
OVEN BATTERIES
-------
OBSERVATION SUMMARIES BY INSPECTOR POSITION FOR COKE
OVEN BATTERIES
Charts C-l and C-7 are graphic displays of daily visible emissions
data acquired at the Bethlehem Steel Coporation, Lackawanna Plant coke
batteries 8 and 9. The charts contain both Method 9 data for door,
topside, and stack observations and accumulative stopwatch data for
charging and pushing. Following is a description of how to read the
charts.
1. Inspector positions are listed along the left-hand column
of the chart. Each position is allotted ten vertical spaces,
consisting of five pairs.
2. Clock times which circumscribe the battery observation period
for the day are listed along the bottom of the chart; each
horizontal space represents a 15-second interval. Running
time can be constructed by placing each 2 (vertical) by 140
(horizontal) matrix end to end.
3. Each Method 9 opacity observation was placed in two vertical
spaces, one space wide. Thus, a typical 6-minute, Method 9
opacity observation is represented by a 2 (vertical) by 24
(horizontal) matrix. For example, four 15-second interval
opacity observations of 90, 65, 5 and 100% would be recorded
9 6 0
as:
0 5 5 0
-------
4. Each accumulative stopwatch observation was placed between
two vertical lines 2 spaces high. The number of seconds
the opacity was >20% is recorded, followed by the battery
number in parentheses, between the vertical lines. The
duration of the charge or push is represented by the number
of horizontal spaces (each one represents 15 seconds)
between the two vertical lines. The start of the charge
or push is represented by the left-hand side vertical
line.
5. The 10 (vertical) by 140 (horizontal) matrix just above
the clock times represents a composite profile of the
battery. It contains either the highest opacity reading
for each 15-second interval from any of the 6 inspector
positions or the number of seconds the opacity was >20%.
When a choice needed to be made between opacity observations
or time >20%, all opacity observations >20% were converted
to equal 15 seconds, and the greatest amount of time >20%
for the observation period was selected (example follows).
EXAMPLE (See attached excerpt from Chart 1)
BATTERY: 9 [See A]
TIME: 1433:00 to 1438:00 [See B]
TOTAL: 1433:00 - 65 comes from Topsides position as it is higher
than the 55 from the Pusher Side Doors position and the 30
from the Cokeside Doors position [See C].
1434:00 to 1437:00
a. Pusher Side Doors - 4 opacity observations >20%
[See D], thus 60 seconds >20%.
b. Charging - 97 seconds >20%.
c. Topsides - 10 opacity observations >20% [See E],
thus 150 seconds >20%.
-------
d. Pushing - 58 seconds >20%.
e. Cokeside doors - none [See F].
f. Stacks - none [See G].
To avoid overlap, the number of seconds >20% opacity is reviewed
for each inspector position to determine the set of readings which
gives the highest total. In this case, it is the Topsides position.
So, the 10 individual Topsides observations are brought down to the
Total [See H], Also, 2 of the 4 Pusher Side Door observations are
brought down to the Total, since they do not overlap with the 10 Top-
sides observations [See D and I].
1433:00 to 1438:00 - 18 of the 20 spaces in the Total
are filled with values >20%; the other 2 spaces are
blank, because no Method 9 observations took place during
those 30 seconds. Thus, the battery exceeded >20% for
4.50 minutes (18 x 15 seconds = 270 seconds).
-------
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