BEF

F:

NITROGEN OXIDES EMISSIONS FRO

Mr. John T. Therriault

A ssistant Clerk of t

is Pollution

Coi

100 W. Randolph Street

ois 6060

Suite 11-500

R08-19

g-A

Timothy Fox, Esq.

ing Officer

Illinois Pollution Control

100 W. Randolph Street

11-500

Dated:

By:

/sfh,adwrine D.

Killletine

rine D. (lodge

Rios

HODGE DWYER & DRI

3150 Roland Avenue

Box

(217) 523-4900

C NPH:OI 1 /H/R08-l

S UBMITTED ON

RECYCLED

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *

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VARIOUS

SOURCE CATE

AMENDMI

PARTS 211

RIN

R08-19

(Rulemaking - Air)

OCOPHILLIPS COMPANY

y and

g POST-

ion in the move-referenced matter.

ophilli

tyh,b_

of sourcer_

including

man o` : ie ben',

j i

I

:,.,ioated in the above-

Process heaters located at the Refinery would require

on in an averaging strategy in order to meet the NO

tection Agency ("

rule.

orf o<lrncnts to 35

o f David W. Dunn, In the

Matter

Of:

and seventeen

controls

or

n oxia', _

r

lolls

8-19

I costs that would be incurred by ConocoPhillilas to install certain coat

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *

---

d concluded that the

cost per ton of NOx

controlled is well beyond the cost per ton

that the Agency used to determine NOx R

ition, Mr. Dunn's

testimony commented on the proposed

averaging

100

cy's requirement that all

boilers and process heaters over

to/hr install

GEMS.

Id.

at 12-15.

ber 9, 2008, Mr. Dunn presented his testimony to

the Illinois Pollution

t of the proposed rule on the Refi

09, Conocophillips

K '"Wing for additonal

Lip the Ag(,,c

I Ltlon

of the iss

and meetings, GonocoP

the issues

ti

ry. Therefore,

11 continue to work with the Agency

it.

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *

---

ains that the installation

of CEMs at the Refinery for compliance

the Agency's proposed rule will cost an estimated $12,600,000.

Id. at 15.

as noted in

allat

complicated because many of

cess heaters

"do not have exhaust stacks designed for easy installation."

cordingly, Conoco

quests that the Agency and

Board consider lira

ly those units greater than 2

ddition, in regards

to emission control

ded in circumstances

where, during planning and

s

available control t( f

ý-,E

I'', I

I

I Ips

must have the ability to

ConocoPhillips appreciates the Agency's cooperation and willingness to discuss

for the Refinery by the proposed rulemaking. ConocoPhillips intends to

arts the Agency's proposed

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *

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ConocoPhillips reserves the right to supplement

these post hearing

comments.

Respectfully

submitted,

CONOCOPHILLIPS

COMPANY,

Dated: March 23, 2009

By:

Katherine D. Hodge

DGE DWYER & DRIVE

Post

Office

Box

5776

nois 62705-5776

/s/Katherine

D. Hodge

Katherine D. Hodae

CNPH:o 1 I /Fi «Raa-19/Pose

H ear

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *

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TE OF SERVICE

I, Katherine D. Hodge, the

undersigned, h

NY,

upon:

Mr. John T. Therriault

Assistant

Clerk

of the Board

ion Control Board

Illinois

Environmental Regulatory Group

100 West Randolph Street, Suite 11-500

is 60601.

Sprindield, Illinois 6270

10()

C1ýic,tc Tllinois

i

i ýý,

Il

,., Late.

G i

;1.a

1'.c kcal

Chief,

Environmental

Bureau North

Office of the Attorney

General

Street, Suite 1800

)2

rrrd ttýlýý ý ýriýtrg,ý tate.i

S ý-hill

f h l"{ti,. l

I'P

ýlýlrl.rkII Protection : etc

600 `,.;:r,

Deputy

Legal Counsel

( 'l I(;00-

ý ttcilil

.ý_Om

Christina L. Archer, Esq.

Department of Natural Resources Arcelorm

, Illinois 62702-1271

Chicago,

Christina. Archer a@a.rcelormittal.co

/s/Katlict

ine

D. Hodge

h,_ nine D. Hodge

Electronic Filing - Received, Clerk's Office, March 23, 2009

* * * * * PC # 14 * * * * *