Tonawanda Coke

Transcription

Tonawanda Coke

1
Tonawanda Community, Clean Air
Coalition, NYSDEC, USEPA and
Tonawanda Coke Corp.
AWMA February, 2016
Tonawanda Coke early 1900’s
TCC History
• First coke ovens put in service in 1917
• 60 ovens Semet-Solvay Design
• 1926 added second battery of 60 ovens
• Primary customers Wickwire-Spencer Steel and
Tonawanda iron
• Appx 30 million cubic feet of coke oven gas sold daily to
Iroquois Gas Company
• 1961, # 2 battery taken out of service and a new battery
consisting of 60 four meter ovens of Wilputte gun fired,
hairpin, cross-regenerative design constructed. This battery
is the one in operation today. The original 1917 battery
became inactive in 1972
• Allied chemical owned the facility.
• December 1977 fire of a large tar storage tank nearly
destroyed the facility.
• Jan 1978 J.D. Crane purchased the 188 acre
site and continued operation as Tonawanda
Coke co, (TCC)
• Operating as a merchant facility producing
foundry coke
• Tonawanda Coke supplies foundry coke to the
U.S. and Canadian foundry, insulation and
sugar beet industries
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NYS Department of Environmental Conservation
WYORK
Department of
1fR%NITY
Environmental
Conservation
Major Sources
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•
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Tonawanda Coke
NOCO Energy
Sunoco Terminal
Huntley Stream Generating
Plant
• 3M O-Cello
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•
Tonawanda GM
DuPont
Indeck Yerkes
Goodyear Dunlop
FMC Active Oxidants
Benzene alley
Applicable regulations
• 6NYCRR part 214 by-product coke oven batteries
• Effective 1984,, versions dating back to 1982
• Standards for coal charging, coke pushing and
transport, quench towers, waste heat stacks, oven
doors, charging hole lids and offtake piping, coke
oven gas sulfur recovery.
• Rule written to address PM nonattainment issues
• 1984 Consent order giving TCC alternate compliance
stds inlieu of pushing controls
• More stringent door leak, coal charging limitations.
• Facility limited to foundry coke production
Applicable federal regulations
• 40 cfr part 61, subpart V, June 6, 1984, national
emission stds for equipment leaks. Applicable to gas
containing >10% benzene. Fugitive emission of COG
from exhausters
• 40 cfr 61, subpart L, Sept 14, 1989, National emission
Stds for Benzene emissions from Coke-byproduct
recovery plants. Applicable to tar decanters-storage
tanks-sumps,flushing liquor circulation tanks, and in
benzene service valves exhauster lines etc.
-40 CFR 63 Subpart L NESHAP for Coke oven Batteries
10/27/1993. included definition of foundry coke producer
-40 cfr 63 subpart CCCCC NESHAP for coke oven pushing
quenching and battery stacks. Applicable to major sources
of HAP. Applicable to existing, major source of HAP,
facilities April 14, 2006.
-Requires shed for capture and control equipment for
particulate from pushing, pm 0.01 grains/dscf
-COMS on waste heat stack, 24 hour 15% opacity limit
-Limits on quench water total dissolved solids 1100 mg/l,
baffles, baffle wash, work plans etc
History
• Clean Air Coalition of Western NY
– July and August 2004
– Three separate “bucket” samples were
taken of VOCs & semi volatiles,
representing 5 to 15 minute samples
– Results - benzene ranged from five to ten
times higher than other statewide data
Initial Verification
• DEC collected one-hour samples on
6/21-23/05
checked wind data for summer months
for 5 years
• Coordinated Meteorological staff with
Regional staff for when to take samples
• Modeled predicted benzene impacts
Results of 1-hour Sampling
• Benzene samples obtained by Region 9 were 20
times higher than upwind site
• Sample concentrations ranged from:
0.7 ug/m3 - 2 miles from coke plant
to 10 ug/m3 - 0.5 miles from coke plant
Tonawanda Air
Monitoring Study
EPA Community Grant
Site Selection & Setup
EPA Community Toxic Grant Program
• Part of National Ambient Air Monitoring Strategy
and EPA's Urban Air Toxics Strategy
– Assist communities in identifying and profiling air
toxics sources
– Characterize the degree and extent of local-scale air
toxics problems
– Track progress of air toxics reduction activities
– Develop and assess emerging measurement
methods
• To address public complaints received by DEC from the
community regarding odors and an overall compromised quality of
life;
• Elevated short-term benzene concentrations in samples from
a community group;
• Evaluate effectiveness of the current State and Federal hazardous
air pollutant reduction strategies.
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Coke Oven Residual Risk Assessment prepared by EPA;
Maximum Individual Risk (MIR) for cancer estimated to range from 50 to
500 in a million
A decision was made that the cancer risk was acceptable due to
uncertainty and no further action was necessary. (FR 4/15/2005).
Tonawanda Application
Staff from BAQAR, BAQS, BOSS and Region 9
drafted a monitoring plan and completed the
application.
Goals
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Evaluate National Emission Inventory for Tonawanda
Evaluate EPA's modeling results at census tract level
Evaluate Residual Risk Assessment for Coke Oven NESHAP
Provide foundation for future community participation
Plan
• Collect monitoring data from 4 sites for 1 year
• Analyze pollutant specific data – min/max facility influence from
wind direction data
• Determine spatial variations – upwind versus downwind
Contaminants to be monitored
• 44 VOC compounds
– 11 are HAPs
• 11 Carbonyl compounds
– 2 are HAPs, formaldehyde & acetaldehyde
• PM2.5
• Sulfur dioxide
• Carbon disulfide
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Locating the Monitoring Sites
Benzene
12 month average
Concentration µg/m3
12.00
2007 State annual average
3
AGC - 0.13 µg/m
9.00
6.00
3.00
0.00
Beaver Island
Brookside
Grand Island
Sheridan Park
7/5/07
7/11/07
7/17/07
7/23/07
7/29/07
8/4/07
8/10/07
8/16/07
8/22/07
8/28/07
9/3/07
9/9/07
9/15/07
9/21/07
9/27/07
10/3/07
10/9/07
10/15/07
10/21/07
10/27/07
11/2/07
11/8/07
11/14/07
11/20/07
11/26/07
12/2/07
12/8/07
12/14/07
12/20/07
12/26/07
1/1/08
1/7/08
1/13/08
1/19/08
1/25/08
1/31/08
2/6/08
2/12/08
2/18/08
2/24/08
3/1/08
3/7/08
3/13/08
3/19/08
3/25/08
3/31/08
4/6/08
4/12/08
4/18/08
4/24/08
4/30/08
5/6/08
5/12/08
5/18/08
5/24/08
5/30/08
6/5/08
6/11/08
6/17/08
6/23/08
6/29/08
7/5/08
7/11/08
Concentration (ug/m3)
Benzene-Log Scale
BISP
100
GIBI
BTRS
SPWT
10
1
0.1
Date
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Community Involvement
• Three public meetings were held during the study period and the
community was invited to attend and ask questions.
- March 1, 2008 (Saturday morning)
- November 18, 2008 (Tuesday evening)
- June 12, 2009 (Friday evening)
• Media alerts about the public meetings were provided to the press
by DEC.
• During the entire study period a dialog with the Clean Air Coalition
of Western NY, University of Buffalo academics, community
residents, EPA & local elected officials was occurring.
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DEC Study Conclusion
•The results of the community air
quality monitoring study and data
analysis indicates there is a need for a
focused effort to reduce the burden of
air toxics in the Tonawanda area.
•Measured benzene levels around 3.0
ug/m3
inspections
• 3/2009- 6 day inspection DEC/EPA and NEIC
included off site monitoring
• 5/2010 5 day inspection DEC/EPA DIAL test and
mobile monitoring equipment off site
• 10/2010 3 day inspection DEC/EPA and NEIC Leak
detection equipment
violations
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Section 113 of the Clean Air Act
Section 301 of the Clean Water Act
Section 313 of the Emergency Right to Know Act
Part 201 and TV
specifics
• Violations of the general duty requirements in part
61.12(c)
• NESHAP for Benzene waste operations
Civil Enforcement
• Joint civil action EPA/DOJ, AG/ DEC
• Involved initial injunctive relief order to address
Dilapidated tar storage tanks remediation
• Repair COG leaks, remove, rebuild replace
equipment from the byproduct area, enhanced LDAR,
replace ammonia still
• Final civil order added installation of shed to control
pushing emissions, capture and controls.
• Limitations on coke production, coke time,
• Meet requirements of NESHAP CCCCC
• 4 million dollar fine, half towards environmental
benefit projects
• Order filed in Federal district Court 10/28/15 final
October 2015
Federal Criminal Action
• US district court criminal trial March 2013, 4 weeks
long resulting in jury criminal conviction for 15 out of
19 counts
• Obstruction of justice for directing an employee to
conceal a source of air pollution
• Failure to install baffles in quench tower, operating an
unpermitted emission point
• Illegal storage and disposal of hazardous waste
without a permit
-Case represents the only second criminal prosecution
nationally under the CAA involving airborne pollutants
-One year jail sentence for the Environmental Engineer
-12.5 million dollar fine
-TCC ordered to fund 11.5 million dollar health study
-TCC ordered to fund a 750,000 soil study
-appeals for fines denied, appeals for study ongoing.
Current Air Monitoring Locations
4
WYORK
Department of
1fR%NITY
Environmental
Conservation
1.8
Annual Ave. Conc. (ppb)
1.6
Study Period (7/07-6/08)
1.4
-38%
1.2
-10%
1.0
+7%
1st Year Post Study (7/08-6/09)
-16%
2nd Year Post Study (7/09-6/10)
-10%
0.8
0.6
3rd Year Post Study (7/10-6/11)
-19%
-22% -6 % +11%
-34%
0.4
-22%
-35% -3%
-41% -21%
0.2
0.0
Formaldehyde
Benzene
Benzene/Toluene
Acetaldehyde
Toluene
Contaminant
Study Year and Subsequent Years Concentrations - Residential Site (BTRS)
0.35
0.30
0.25
+21%
-43%
0.20
0.15
-12%
-6%
0.10
-36%
0.05
+20%
-47%
+23%
-45%
-26%
+3%
-21%
-6%
-44%
-10% +20%
-41%
-32%
-46%
-58%
-12%
-14%
+8%
-46%
0.00
Acrolein
1,3 Butadiene
m,p-Xylene
o-Xylene
Carbon Disulfide
Contaminant
Ethylbenzene
Carbon Tetrachloride Total Xylenes (mixed)
4.0
3.5
3.0
2.0
1.5
-39%
2.5
-74%
1.0
-36%
-57%
-18% +2%
-21%
-48% -38%
0.5
-35% -9 %
-29% -18%
-22%
-3%
0.0
Formaldehyde
Benzene
Benzene/Toluene
Acetaldehyde
Toluene
Contaminant
Study Year and Subsequent Years Concentrations - Industrial Site (GIBI)
0.6
0.5
0.4
0.3
0.2
0.1
-45%
+20%
-37%
+2%
-25%
-34%
-41% +26%
-34%
-51%
-59%
-34%
0.0
Acrolein
1,3 Butadiene
m,p-Xylene
-44%
+3%
+1%
-34%
o-Xylene
-42% +17%
-42%
Carbon Disulfide
Contaminant
+22%
-36%
Ethylbenzene
+5%
-21%
-5%
Carbon Tetrachloride Total Xylenes (mixed)
Things to consider
• Data used in reports and statements, risk
management
• Environmental Audit incentive policy- return to
compliance

Tonawanda Coke

Transcription

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