The Group Against Smog and Pollution, Inc. v. United States Environmental Protection Agency, American Iron and Steel Institute, Intervenor

665 F.2d 1284, 214 U.S. App. D.C. 466, 11 Envtl. L. Rep. (Envtl. Law Inst.) 20982, 16 ERC (BNA) 1617, 1981 U.S. App. LEXIS 17458, 16 ERC 1617
CourtCourt of Appeals for the D.C. Circuit
DecidedSeptember 23, 1981
Docket78-1534
StatusPublished
Cited by15 cases

This text of 665 F.2d 1284 (The Group Against Smog and Pollution, Inc. v. United States Environmental Protection Agency, American Iron and Steel Institute, Intervenor) is published on Counsel Stack Legal Research, covering Court of Appeals for the D.C. Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The Group Against Smog and Pollution, Inc. v. United States Environmental Protection Agency, American Iron and Steel Institute, Intervenor, 665 F.2d 1284, 214 U.S. App. D.C. 466, 11 Envtl. L. Rep. (Envtl. Law Inst.) 20982, 16 ERC (BNA) 1617, 1981 U.S. App. LEXIS 17458, 16 ERC 1617 (D.C. Cir. 1981).

Opinion

*1286 SPOTTSWOOD W. ROBINSON, III, Chief Judge:

Petitioners, various environmental groups, 1 attack regulations, promulgated by the Environmental Protection Agency (EPA) under the Clean Air Amendments of 1970, 2 setting air pollution control standards for basic oxygen process furnaces (BOPFs) used in the production of steel. 3 Petitioners accuse EPA of arbitrariness in confining the scope of those rules to BOPF emissions which are captured and vented through a plant’s smokestacks, thus permitting other —“fugitive”—BOPF emissions to enter the atmosphere without treatment. EPA contends that petitioners’ bid for judicial review, implicating as it does a regulatory step four years old, is jurisdictionally out of time, and that in any event the agency action must be sustained on the merits.

We find that the instant challenge is in effect a petition to revise and broaden a preexisting BOPF standard on the basis of new information, and as such is not untimely. 4 We then conclude that EPA acted reasonably in responding to that application by resolving to conduct a separate rulemaking proceeding with a view to possible amendment of the regulations, instead of giving them that sort of consideration during the course of a proceeding earlier initiated for a much more limited purpose. 5 Accordingly, we affirm.

I. BACKGROUND

A. Fugitive Emissions

Basic oxygen process furnaces have become the principal means of raw steel production in the United States. Employing high-pressure oxygen during fabrication, they turn out steel more quickly and in greater quantities than was ever possible by the use of traditional furnaces. 6 These gains in higher yield, however, have not been achieved without some environmental losses. Enormous amounts of particulate matter and toxic gas are released as oxygen is forced into the furnace at sonic speeds. 7 Most are collected by a giant stationary control hood mounted above the furnace. 8 These so-called stack, or primary, emissions are then ducted away to the plant’s pollution control equipment, 9 where substantially all particulate matter is removed before the air thus cleaned is vented into the atmosphere through a smokestack. Other emissions, however — notably those which escape the furnace when it is tipped away from the hood during loading or pouring operations — never enter the pollution control system. Instead, these secondary, or “fugi *1287 tive,” emissions enter the atmosphere untreated, either through ventilation holes in the roof or other openings in the building housing the furnace. 10 Current nonregulation of these latter emissions is the matter lying at the heart of the controversy before us.

B. Administrative Action

By Section 111 of the Clean Air Amendments of 1970, Congress instructed EPA to identify categories of stationary sources of air pollution that endanger the public health or welfare, 11 and to promulgate regulations establishing standards of performance for new facilities within each category. 12 These standards, that section commands, must reflect what in EPA’s judgment is the best emission reduction technology available, taking cost and other factors into consideration. 13 Pursuant to these directives, EPA issued a notice on June 11, 1973, adding iron and steel plants 14 to the list of stationary pollution sources already found in need of regulation, 15 and simultaneously issued proposed performance standards for new steel mills employing basic oxygen process furnaces. 16

As proposed, the regulations were directed only to BOPF stack emissions; there was no provision curbing fugitive emissions. 17 EPA justified this difference on the ground that the best available technology for BOPF emission reduction dealt only with primary, not secondary, emissions, and consequently that development of a fugitive emission standard was unfeasible. 18 Additionally, the proposed rules contained two BOPF performance standards — one limiting the concentration of particulate matter released from the stack, 19 and the other measuring the opacity of stack emissions 20 —which were designed to supplement each *1288 other as enforcement tools. 21 Although the concentration, or mass, standard is the more precise of the two measurements, it also is considerably more expensive and time-consuming to utilize, 22 and thus is impracticable to implement on a permanent or even on a frequent basis. The opacity standard, on the other hand, although less accurate requires no more than mere on-site observation of a plant’s stack emissions by relatively untrained inspectors who can, periodically and .without advance warning, visit a facility and quickly conduct compliance reviews. 23

EPA invited comments on the proposed rules, and on March 8, 1974, promulgated final performance standards for basic oxygen process furnaces. 24 The final mass standard was virtually identical to the one that had been proposed, 25 but the opacity standard was withdrawn pending additional study of various technical problems. 26 EPA made known its intention, however, to devise another BOPF opacity standard as soon as practicable. 27 Petitioners did not then challenge either the exclusion of fugitive emissions or the absences of an opacity standard from the final regulations.

Three years later, EPA proposed a new opacity standard for BOPF stack emissions. 28

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Bluebook (online)
665 F.2d 1284, 214 U.S. App. D.C. 466, 11 Envtl. L. Rep. (Envtl. Law Inst.) 20982, 16 ERC (BNA) 1617, 1981 U.S. App. LEXIS 17458, 16 ERC 1617, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-group-against-smog-and-pollution-inc-v-united-states-environmental-cadc-1981.