ILLINOIS POLLUTION CONTROL BOARD
December
5,
1986
IN THE MATTER OF:
)
)
PETITION FOR SITE-SPECIFIC
)
REGULATIONS APPLICABLE TO
)
PARTICULATE EMISSIONS FROM
)
R84-48
LTV STEEL COMPANY’S
)
CHICAGO WORKS HOT SCARFING
)
MACHINES (35 Iii.
Adm. Code
)
212.451)
)
ADOPTED RULE.
FINAL ORDER.
ORDER OF THE BOARD
(by
3.
Theodore Meyer):
This matter comes before the Board on the petition of LTV
Steel Company for site-specific relief from 35 Iii. Adm. Code
212.451 which provides that emissions from hot scarfing machines
shall not exceed
69 milligrams per dry standard cubic meter
(mg/dscm)
(0.03 grains per dry standard cubic
foot
(gr/dscf))
during hot scarfing operations.
LTV seeks to increase this
limitation to 138 mg/dscm (0.06 gr/dscf) for its hot scarfing
machine located at its
“Chicago Works” plant.
Hearing was held
on June
7,
1985.
The Department of Energy and Natural Resources
(DENR)
issued
a negative declaration for this rulemaking on
October
15,
1985 and the Economic Technical Advisory Committee
concurred with this finding at its October
17,
1985 meeting.
On
March
27, 1986 the Board proposed regulatory language for first
notice comment which was published at
10 Illinois Register 5695
on April 11,
1986.
During the first notice comment period the
Board received one comment from the Illinois Environmental
Protection Agency (Agency) suggesting a modification in the
regulation so that
it would apply not only to the hot scarfing
machine but to the related pollution control equipment as well.
The Agency also commented that
a change
in the respirable
particle ambient air quality standard might necessitate
additional control on the hot scarfing machine.
The Board
declined to change the proposed language at second notice.
The Board proposed this rule for second notice review by the
Joint Committee on Administrative Rules
(JCAR) on September
11,
1986.
The statutory second notice period expired on November
6,
1986.
However,
the regulation was not considered by JCAR until
its November
19,
1986 meeting.
JCAR determined that no objection
would be issued to this proposed rule provided certain language
modifications were made to enhance clarity.
The Board has agreed
to make these modifications which will be discussed below.
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-2-
LTV owns an integrated
steel mill known
as the Chicago Works
plant located roughly between 112th Street and 130th Street
between the Calumet River and Burley Avenue on the south side of
Chicago.
This area is designated as primary and secondary non-
attainment for particulates.
The plant occupies approximately
790 acres.
It presently employs about
3,800 people with a
payroll of $98 million.
The plant manufactures semi-finished
steel bars which are used for axles,
springs, and other load-
bearing applications.
As an integrated steel mill,
it has a coke
plant, blast furnace,
an electric furnace, an oxygen furnace,
melting shop and various rolling and finishing facilities.
Production of the steel bars begins with the reduction of
iron ore in the blast furnace with coke to liquid iron.
The iron
is then refined in the oxygen furnace to produce steel.
The
steel
is poured into molds
where
it solidifies to form ingots.
Each ingot weights approximately
94 tons.
The ingots proceed
through
a
series
of rolling systems,
the first being known as the
44-inch rolling mill.
However, before proceeding to the rolling
mill the ingots go through
a reheating step called the soaking
pits.
During this process the ingots form a layer of oxides
referred to as
“scale”.
For certain types
of steel the scale is
detrimental to the finished product and therefore,
it must be
removed.
Removal takes place
after the ingots go through the
rolling mill
in
a machine known as the 44-inch mill hot scarfing
machine.
At this point the ingots are roughly 2,000 °F. Gaseous
oxygen is blown against them to burn off the oxide deposits.
This process results
in the formation of iron oxide which
is
emitted as particulate matter.
Approximately
70 percent of the
steel produced at the Chicago Works plant
is treated in the
scarfing machine.
Petitioners state that scarfing is necessary
in order to meet the quality specifications of their customers.
It takes approximately 20 seconds to scarf one ingot.
At present
production, approximately 13 ingots per hour are scarfed.
The hot scarfer emissions are presently controlled by an
exhaust hood, duct work,
venturi scrubber, mist eliminator and an
induced draft fan which releases the cleaned emissions to the
atmosphere.
However,
despite these controls, Petitioner is
unable to meet the 0.03 gr/dscf standard.
The scarfing operation has twice been tested for emission
concentrations.
The first test was conducted by Interlake,
Inc.,
Technical Center
in October of 1975 by a method called WP-50.
Three runs were conducted on October
14,
16, and
20.
Emissions
in gr/dscf during these runs were:
0.0413, 0.0339, and 0.0194 for
an average of 0.0315.
(Pet. Exh.
6).
The second set of tests
was run by Mostardi-Platt Associates on April 23 and
24,
1981
utilizing USEPA’s method
No.
5.
The results of three test runs
in gr/dscf were: 0.0411,
0.1063 and 0.0442 for
an average of
0.0639.
(Pet.
Exh.
5).
Tom J.
Harlan, Jr., Environmental
Management Engineer at LTV, calculated standard deviations for
74-236
-3-
each test which indicated that the second set
of tests were not
as precise.
(R.
at 73).
When expressed in terms of
standard
error,
the first test run had a standard error of approximately
30 percent and the second test run had
a standard error of
approximately 50 to
55 percent.
(R.
at
83).
He accounts for the
considerably higher result on the second run of the Mostardi—
Platt test as
an artifact of the sampling.
Thus,
it
is his
estimate that the average of emissions is probably closer to
0.04 gr/dscf based
on an average of all six runs which comes
to
0.0477 gr/dscf, with a standard deviation of 0.0336.
(R. at
74)
Mr. Harlan then calculated the excess pounds of particulate
emissions emitted per scarf.
(Pet.
Exh.
7).
Using the 0.03
gr/dscf standard of
35
Ill. Adm.
Code 212.451, he calculated the
estimated allowable emissions per scarf to be 0.1 pounds.
Then
using the Mostardi-Platt results, Mr.
Harlan calculated that 0.2
pounds of particulates were actually being emitted per scarf.
Thus,
at the historical average of
10 scarfs per hour,
particulates would be emitted
at the rate of two *pounds
per hour
which is one pound per hour over the allowable limit.
Although
the scarfer is capable of more than 10 scarfs
per hour,
and is
indeed presently operating at
13 scarfs per hour,
as the number
of scarfs per hour increases both the actual and allowable
emissions
in pounds per hour increase proportionately.
Mr.
Harlan testified that the maximum number of ingots through the
scarfing machine
in the historical peak hour was
33.
However, he
guessed that the
70 percent scarfing rate would probably apply to
this figure meaning that only 23 ingots were actually scarfed.
Although the scarfing operation is not limiting on production,
the facility could probably not operate at the historical maximum
rate over any lengthy period of time since other
steps
in the
production process limit
the amount
of
steel that can go through
the scarfer.
(R.
at
78).
Technical Feasibility and Economic Reasonableness
Petitioner argues that to upgrade the existing control
equipment to meet the 0.03 gr/dscf standard would impose an
arbitrary or unreasonable financial burden without resulting in
any significant improvement
in air quality.
Petitioner obtained
an estimate of the cost
in 1981 to obtain compliance of $1
million.
Based on standard escalation factors,
Petitioner now
estimates the actual cost to be closer to $1.2 million.
(R.
at
23).
This plan would require upgrading the present equipment to
provide approximately 20 inches more differential pressure across
the venturi scrubber.
Kenneth R.
Basciani, Works Engineer at
LTV,
testified that the actual cost of the necessary equipment
was approximately $165,000.
The balance of the $1.2 million cost
represents labor and material to be supplied by LTV.
While the
modifications to the scrubbing equipment
are relatively minor,
extensive modification of the ductwork is necessary because of
the present low operating pressures.
Mr. Basciani testified that
74-237
—4—
the existing fan would have
to be replaced with a 2500 horsepower
induced draft fan and that the largest part of the overall job
cost was attributable to the installation of this fan and the
associated electrical work.
He stated that the great expense was
due to the placement
of the present equipment within
a very
confined area.
Specifically, the tight confines limit the
ability to use heavy construction equipment causing the
construction period to be much longer.
(R.
at 45-6).
In fact,
installation of the new equipment would necessitate a shutdown of
the scarfing operation for several months.
LTV did consider other alternatives such as the use of
electrostatic precipitators and baghouses but determined that
because of space constraints the equipment would have to be
located remotely from the scarfing machine.
Consequently,
although no formal estimates were made,
it was determined that
these alternatives would be more costly than revamping the
existing equipment.
(R.
at
26-7).
Environmental Impact
In support
of its contention that upgrading the scrubbers
will cause no significant improvement
in air quality, petitioner
supplied modeling studies performed by Richard Hans Schuize, an
environmental engineer and president
of Trinity Consultants.
Trinity Consultants specializes
in the field of dispersion
modeling.
Mr.
Schulze testified that he ran two models.
Each was
based on surface meteorological data collected in Chicago and on
mixing height data collected
in Peoria for the years 1970 through
1974 as recommended by the Agency.
It was determined to use the
Industrial Source Complex
(ISC)
short term model because there
are wake effects attributable to
a roof ridge.
Mr. Schulze
testified that the roof ridge will cause the emissions under most
conditions to be caught in its wake.
(R.
at
102).
Because Mr.
Schulze was uncertain as
to whether, under
IJSEPA guidelines,
the
area would be designated urban or rural he decided to run both
the rural and urban options
of the ISC model.
The model calculated concentrations of particulates on
a
“grid” with receptor points
100 meters apart.
In addition,
concentrations at three “discrete” receptors located at the sites
of three schools in the vicinity of LTV were calculated.
(R.
at
113-14).
Although LTV has estimated that it emits approximately
one pound of particulates per hour over the allowable amount,
Mr. Schulze assumed an emission rate of 100 pounds per hour or
100 times the excess emission rate.
Mr.
Schulze stated that he
selected this emission rate simply because he wanted some larger
numbers
to show up
in the printouts
as
it is easier
to multiply
by
a factor of 100 than keep track of small numbers with many
decimal places.
(See Exhs.
8,
9,
10,
11,
12).
74-238
—5-
The results
of Mr.
Schuize’s calculations are
as follows:
Maximum Of f Property Concentrations
Maximum Annual and Highest
-
2nd high 24-hour average
(1970-1974)
(micrograms per cubic meter)
Rural
Urban
Annual
24 hour
Annual
24 hour
Maximum off property
0.14
1.9
0.12
1.7
Washington School
0.05
0.5
0.05
0.4
Adams School
0.02
0.2
0.02
0.2
Bright School
0.01
0.2
0.01
0.2
(See Petition for Rule Change, Exh.
2)
Based on these results, Mr.
Schulze concluded that the
scarfing operation has
an insignificant air quality impact based
on the emission rate of one excess pound per hour.
(R. at
130).
Mr.
Schulze testified that the basis for this conclusion
was
a USEPA determination that the minim~mamount of ambient
impact co9sidered
“significant” is
5
u/rn
as
a 24-hour average
and
1
u/rn
as an annual average.
43 Fed.
Reg. 26398 (1978).
The
values generated by the models are one-seventh to one-eighth of
these significance levels depending on whether the urban or rural
model
is used.
The Agency has pointed out that
35 Ill. Adm. Code 212.451
is
a RACT-based emission limitation and that any rule change must be
approved by USEPA for inclusion
in the State Implementation Plan
(SIP).
The RACT guidance document for iron and steel making
entitled
“Steel Industry Particulate Emissions Limitations
Generally Achievable on
a Retrofit Basis” was submitted by the
Agency as Public Comment
#1.
The RACT emission limits given by
this document are 0.022 gr/dscf during scarfing operations or
alternatively, 0.01 gr/dscf as
an hourly average.
Although the
Illinois rule is based on emissions during scarfing operations,
Petitioner did calculate the emissions as
an hourly average based
on
70 percent of the peak historical
33 scarfs per hour.
This
yielded
a calculated maximum emission concentration of 0.008
gr/dscf as
an hourly average,
a value below the alternate RACT-
based limit
of 0.01 gr/dscf.
(P.C.
#2,
R.
at 155—156).
Petitioner also calculated the maximum emissions
at the peak rate
to be 4.5 lbs/hr or
19.5 tons/yr assuming the scarfer were
operating 24 hours/day over 365 days/yr.
Based on these values
the Board finds
that the expenditure of
$1.2 million and ceasing
operation of the scarfing machine for
a few months to control
these
“de minimus” emissions is not “reasonably achievable.”
(See Exh.
15).
74-239
—6-
Based on all the foregoing, the Board finds that compliance
with 35
Ill.
Adm. Code 212.451 although technically feasible is
not economically reasonable and would impose an unreasonable
financial hardship on LTV Steel Company without measurable
reductions in particulate concentrations around the plant.
JCAR has made several requests for language modifications
in
the proposed rule.
These include
a request that the Board be
more specific as to the time of the hot scarfing machine’s
existence.
Thus,
language has been inserted to clarify that the
rule applies to the hot scarfing machine existing on LTV’s
premises as of the approximate date of adoption by striking the
reference to “the existing hot scarfing machine” and substituting
“the hot scarfing machine existing on January
1,
1987.”
Concerning the RACT-based limitation of 23 mg/dscm of
particulates
as an hourly average, JCAR has suggested that
language be inserted to provide that “so long
as emissions do not
exceed”
as
a substitute for “and not
to exceed.”
JCAR has also
requested the addition of language to indicate that the hourly
average
is to be calculated on an hour by hour basis.
In other
words, were LTV to exceed the hourly limitation during one 60-
minute period that exceedance could not be offset by averaging in
an hour in which the machine was idle or operating substantially
under the limitation.
Thus, language providing that the hourly
average of 23 mg/dscm is not to be exceeded
“as measured per
hour” has been added.
In addition JCAR has requested that the Board update its
statutory authority to the 1985 edition of the Illinois Revised
statutes.
With these modifications, the Board hereby adopts the
following amendment to
35 Ill. Adm. Code 212.451:
Title
35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
C:
EMISSION STANDARDS AND LIMITATIONS FOR
STATIONARY SOURCES
PART 212
VISUAL AND PARTICULATE MATER EMISSIONS
Section 212.451
Hot Scarfing Machines
All hot scarfing machines shall be controlled by
pollution control equipment.
Emissions from said
pollution control equipment shall not exceed
69 mg/dscm
(0.03 gr/dscf) during hot scarfing operations.
Provided, however, that the hot scarfing machine
existing on January
1,
1987 and operated by the LTV
Steel Company,
Inc.,
at its Chicago Works, which employs
74-240
—7—
wet scrubbers, may emit particulate matter in amounts
not exceeding 138 mg/dscm
(0.06 gr/dscf) during hot
scarfing operations
so long as emissions do not exceed
23 mg/dscm (0.01 gr/dscf)
as an hourly average, as
measured per hour.
IT IS SO ORDERED.
Board Member
R.
Flemal dissented.
I, Dorothy M. Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify ~hat the above Order was adopted on
the
~
day of
/1J~-t-t~
,
1986, by a vote of
~—/
L2(-/’ ~
~
Dorothy
M.
G~inn, Clerk
Illinois Pollution Control Board
74-241