BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
NITROGEN OXIDES EMISSIONS FROM
VARIOUS SOURCE CATEGORIES:
AMENDMENTS TO
35 ILL. ADM. CODE
PARTS
211 AND 217
)
) R08-19
) (Rulemaking - Air)
)
)
)
NOTICE OF FILING
TO:
Mr. John
T.
Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100
w.
Randolph Street
Suite 11-500
Chicago, Illinois 60601
therriaj@ipcb.state.iLus
(VIA
ELECTRONIC FILING)
Timothy Fox, Esq.
Hearing Officer
Illinois Pollution Control Board
100
W. Randolph Street
Suite 11-500
Chicago, Illinois 60601
foxt@ipcb.state.iLus
(VIA
ELECTRONIC MAIL)
(SEE PERSONS
ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have today filed with the Office
of the Clerk of the
Illinois Pollution Control Board POST-HEARING COMMENTS FOR THE ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY SUBMITTED BY ARCELORMITTAL
USA, INC. a copy of which is herewith served upon you.
Dated:
"2, 1;).3
I~
Christina L. Archer
Associate General Counsel
ARCELORMITTAL USA, INC.
1 South Dearborn,
19
th
Floor
Chicago, Illinois 60603
(312) 899-3865
Respectfully submitted,
By:
G\~L)~k
Christina L. Archer
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, March 23, 2009
* * * * * PC # 10 * * * * *
CERTIFICATE OF SERVICE
I, Christina L. Archer, the undersigned, hereby certifY that I have served the attached
POST-HEARING COMMENTS
FOR THE ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY SUBMITTED
BY ARCELORMITTAL USA, INC. upon:
Mr. John T. Therriault
Assistant Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
therriaj@ipcb.state.il.us
Gina Roccaforte, Esq.
John Kim, Esq.
Division
of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Gina.Roccaforte@illinois.gov
John.Kim@illinois.gov
Kathleen
C. Bassi, Esq.
Stephen J. Bonebrake, Esq.
Schiff Hardin, LLP
6600 Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
kbassi@schiffhardin.com
sbonebrake@schiffhardin.com
Mathew
J. Dunn, Esq.
Chief, Environmental Bureau North
Office
of the Attorney General
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
mdunn@atg.state.il.us
by electronic mail on
':::'
I
d:)
J '"
q
Timothy Fox, Esq.
Hearing Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
foxt@ipcb.state.il.us
Katherine Hodge, Esq.
Monica Rios, Esq.
Hodge Dwyer
&
Driver
3150 Roland Avenue
PO Box 5776
Springfield, Illinois 62705
khodge@hdzlaw.com
mrios@hdzlaw.com
Virginia Yang. Esq.
Deputy Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, Illinois 62701-1271
Virginia. Yang@illinois.gov
Alec M. Davis, Esq.
General Counsel
Illinois Environmental Regulatory Group
215 East Adams
Street
Springfield, Illinois 62701
adavis@ierg.org
Christina
1.
Archer
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
NITROGEN OXIDES EMISSIONS FROM
VARIOUS SOURCE CATEGORIES:
AMENDMENTS TO
35 ILL. ADM. CODE
PARTS
211 AND 217
)
) R08-19
) (Rulemaking - Air)
)
)
)
POST-HEARING COMMENTS FOR THE ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY SUBMITTED BY ARCELORMITTAL USA, INC.
These comments are respectfully submitted as a follow-up to the Pre-Filed Comments for
the Illinois Environmental Protection Agency (Illinois EPA or Agency), filed on November 25,
2008, by ArcelorMittal USA Inc. on behalf
of ArcelorMittal Riverdale Inc. (ArcelorMittal), as
additional comments following several rounds
of hearings in this matter and based on informal
discussions with the Agency. ArcelorMittal's Riverdale, Illinois facility has a permitted roller-
hearth tunnel furnace equipped with ultra-low
NOx burners (ULNBs), which processes thin cast
steel slabs. ArcelorMittal previously demonstrated that the tunnel furnace cannot
be considered
as a reheat, annealing, or galvanizing furnace. At this time, ArcelorMittal reiterates that based
on the applicability provisions provided in the proposed regulation at
35 IAC 217.150, the tunnel
furnace is not subject to this rulemaking. With these comments, ArcelorMittal asserts that the
implementation
of additional NOx controls is technologically infeasible and economically
unreasonable.
On March
19, 2009, the Agency filed a Motion to Expedite with the Illinois Pollution
Control Board (Board) requesting that the Board proceed quickly
to First Notice in this matter
because
of the looming possibility of sanctions from the United States Environmental Protection
Agency (U.S. EPA). While ArcelorMittal does wish to delay this rulemaking or have the State
face sanctions, we can only support the legal implementation of Ozone Reasonably Available
Control Technology (RACT) requirements that do not impose additional and unneeded burdens
on Illinois manufacturers. Illinois and Cook County have been losing manufacturing jobs at an
alarming rate to global competitors with less costly regulatory environments. In the current
economic climate, it is not in the interest
of Illinois to increase regulatory burdens. This is
particularly true when actual monitoring data indicate that the Chicago area will achieve
attainment to the applicable 1997 Ozone standard without imposing such burdens as proposed by
R08-19. The Illinois EPA intends to request that U.S. EPA re-designate the Chicago area to
attainment
of the 1997 8-hour Ozone National Ambient Air Quality Standards (NAAQS) based
on ambient monitoring data from 2006 through 2008. Trends in air quality monitoring data for
Illinois and the Chicago area, plus
"on the book" controls hold promise for the re-designation
and maintenance of the Chicago area to attainment without installing additional NOx RACT
controls. Our comments respectfully request Illinois EPA reconsider the economic impact and
cost reasonableness for arbitrarily setting lower NOx emission standards, consider reducing its
economic impact on Illinois and that the Board act prudently on such a proposal, especially in
Chicago where the area is meeting the 1997 Ozone standards that
R08-l9 is intended to improve.
1.
A review of potentially applicable NOx emission control technologies reveals
technical infeasibility due to both operational and product quality issues. ArcelorMittal reviewed
the Technical Support Document (TSD) for Control
of Nitrogen Oxide Emissions from Industrial,
Commercial, and Institutional (ICI) Boilers and Small Electric Generating Unit (EGU) Boilers,
Process Heaters, Cement Kilns, Lime Kilns, Reheat, Annealing, and Galvanizing Furnaces used
at Iron and Steel Plants, Glass Melting Furnaces, and Aluminum Melting Furnaces, AQPSTR 07-
02, March 2008, prepared by Andover Technology Partners and the Illinois EPA. Appendix
21
of the TSD lists ten individual emission units within the steel industry that are currently applying
NOx controls; however, none
of these units are similar to tunnel furnaces. Changing tunnel
furnace burner configuration or using unproven technologies has the potential to harm or
irrepaI"ably affect slab quality, as there is no evidence to support successful continued use
without compromise
of product requirements.
There are three broad categories
of NOx emission reduction techniques: add-on or post-
combustion controls, process controls and pre-process controls. Add-on controls treat flue gases
to remove already formed NOx, process controls include combustion modifications which rely
on inhibiting the formation
of NOx in the production process, and pre-process controls
principally focus on product (or fuel) substitution. ArcelorMittal
is aware that other steel mills
have attempted
to utilize add-on controls. Although add-on controls typically provide the
highest potential level
of NOx reduction, they can only be applied on selective exhaust streams.
These streams must typically consist of steady state conditions with little or no variation in
stream characteristics (such as temperature and oxygen content). Outside
of these ranges, the
technologies are either ineffective or greatly compromised, sometimes resulting in the creation
of
. additional emissions or new air pollutants. The application of Selective Catalytic Reduction
(SCR) technology at another steel mill furnace proved to be technically infeasible in practice.
The application caused changes in the furnace operating characteristics, such as generation
of
varying back pressures, heat flows, and eddy channels, all of which negatively impacted slab
quality. Additionally, it was also fonnd that either the SCR must be by-passed or a significant
loss
of NOx reduction efficiency (and dramatic increase in ammonia slip) will occur during
different slab runs, idle times, hot-standby, start-up and shutdown, etc. Based on the reduced
oxygen content
of the tunnel furnace operation, exhaust temperatures, amongst other parameters,
add-on NOx controls are not feasible for retrofit. Importantly, the Agency has already testified
that it would be surprised
if sources were required to install post-combustion controls to achieve
the proposed emission limits.
See R08-19, Transcriptfrom October 14,2008 hearing, pp. 27,
116-117, 171.
Process controls include Flue Gas Recirculation (FGR), low NOx burners (LNBs) and
ULNBs. As previously stated, ArcelorMittal's tunnel furnace
is equipped with ULNBs. FGR
can be applied alone or in combination with other controls, but when applied with other controls
it
is typically used in conjunction with LNBs, not ULNBs. Due to a steel mill furnace chamber
design and operation, FGR cannot be applied with ULNBs.
If applied with LNBs, the NOx
reduction efficiency is either equal to or less than the use
of ULNBs alone. Since ULNBs are
already used in the tunnel furnace, the application
of the other burner and FGR options would
not result in a reduction
of NO x emissions.
Pre-combustion controls mainly concern fuel switching. ArcelorMittai already fuels the
tunnel furnace with pipeline grade natural gas, therefore, no other fuel sources for this type
of
operation are known to further reduce the formation ofNOx.
2.
Illinois EPA anticipates a NOx reduction of 60% from ArcelorMittal's tunnel
furnace. The Agency allegedly developed this limit based on the RACT provisions which apply
to existing sources in areas that are not attaining the NAAQS. However, as previously described
in this rulemaking, the U.S. EPA considers emissions reductions
of 30% to 50% sufficient to
meet NOx RACT.
See R08-19, Transcript from December
9,
2008 hearing, pp. 84-85
(referencing
70 Fed. Reg.
71657,
Hearing Exhibit
6). Simply put, RACT is based on the
implementation
of "reasonable" controls. As indicated by the August 29, 2008 Pre-Filed
Testimony
of Robert Kaleel, Manager ofthe Air Quality Planning Section in the Bureau of Air at
the Illinois EPA, "RACT is defmed as the lowest emission limitation that a particular source can
meet by applying a control technique that is reasonably available considering teclmological and
economic feasibility."
See R08-19, Pre-Filed Testimony o/Robert Kaleel, August 29,2008, p. 2.
The resultant emission rate by the application of RACT may be different for each source.
However, there
is no pollutant tonnage reduction that represents RACT, rather a control method
application and resultant emission rate (i.e., lbslhr or
Ibs/mmBtu)
reduction. The ULNB
technology that
is typically considered to represent RACT is already in use at ArcelorMittaL
ArcelorMittal currently utilizes Bloom Engineering Series 1430 ULNBs. Based on
previous oral conversations between ArcelorMittal and Illinois EPA, the Agency has requested
that ArcelorMittal pursue the installation
of "next generation" ULNBs.
To this effect,
ArcelorMittal has participated in oral conversations with both Bricmont and Bloom. Bloom has
provided information regarding burner upgrades, including
NOx emission guarantees and cost
estimates; however Bricmont has not guaranteed product quality aspects associated with the
burner change.
A review
of the provided oral and written information indicates that
implementation
of a burner upgrade for the tunnel furnace is infeasible based on the
overwhelming economic cost, the effect on the tunnel furnace operation, and the impact on
product quality.
3.
Illinois EPA has established a range of cost effectiveness of $2,500 - $3,000 per
ton
of emissions reduced.
See R08-19, Transcript from October
14,
2008 hearing, pp. 165-166,
173-174; Transcript from February
3,
2009 hearing, p.
75. In addition, the TSD states that
"$5000IMMBtu/hr
is towards the high end of the capital cost of combustion controls, for the
. levels
of NOx reduction envisioned in most cases, costs in
$/ton
of NOx are typically under
$1000Iton." TSD, Section
6.4,
p.
99.
In
the preamble to the 8-hour Ozone implementation rule
u.s. EPA states that a cost of $160 to $1,300 (in 1994 dollars) per ton of NOx removed is
considered reasonable for purposes of RACT (70 Fed. Reg. 71652, November 29, 2005).
Furthermore, U.S EPA states that in the 1998 NOx SIP Call Rule they reviewed all major NOx
source categories, and the NOx SIP Call controls cost less than $2,000 per ton
(Id. at 71654).
In
light of these control cost determinations, ArcelorMittal prepared an economic analysis for the
Agency to review, which provides the estimated cost effectiveness for burner change. The
analysis has been developed for two separate burners models and are based on ArcelorMittal' s
incremental cost
of reducing NOx emissions. The analysis is attached hereto as Exhibit A.I
Scenario 1 of the analysis for a "next generation" Bloom Series 1500 burner indicates an
actual emissions reduction
of 25 tons per year (tpy), with a conservative cost effectiveness of
$22,895 per ton of NO x removed. Scenario 2 for a "next generation" Bloom Series 1550 burner
indicates an actual emissions reduction
of 29 tpy, with a conservative cost effectiveness of
$39,472 per ton. For either scenario, the calculated cost effectiveness of the burner upgrade well
exceeds the Agency's established range of $2,500 - $3,000 per ton
of emission reduction, U.S.
EPA's determination
of less than $2,000 per ton and the TSD's reference of $1,000 per ton.
Furthermore, the costs are solely estimates for materials and labor associated with the burner
upgrade and additional furnace modifications. These estimates assume rigid customer product
quality specifications can be satisfied and, conservatively,
do not include yield cost impacts and
the associated cost
of production downtime to convert the furnaces, both which would be
substantial.
An
expenditure of over $22,000 per ton of NOx controlled is unreasonable for a
1
As stated in previous conunents, the current, permitted emission factor for the tunnel furnace is O.171Ib/rnmBTU and the
guaranteed emission factor as shown in Exhibit A is O.1651b/mmBTU (the difference being a safety margin). Upon receiving
ArcelorMittal's economic analysis on March 16,2009, the Agency indicated that they would be willing to consider a revised
emission limit
of 0.09
Ib/mmBTU, but stated that, due to time constraints, they could provide no additional reasoning for the
proposed revised limit other than the alleged need to show further NOx reductions and being under the threat of sanctions from
U.S. EPA. ArcelorMittal strongly disagrees with this arbitrary limit (which isn't based on RACT), but is committed to
continuing to work with the Agency to demonstrate why no additional reductions are required.
point source that contributes a meager 0.016% of the total Chicago area NOx inventory on a
daily basis
of 812 tons NOxiday for 2006.
4.
Although the estimated total cost of a burner upgrade is overwhehning, the effect
on the operation
of the tunnel furnace is of greater concern. Steel tunnel furnace burner designs
are very particular to the furnace structure and slab type, so altering the burners or heat system
can have significant effect on the slab quality. Based on Scenario
1, burners and gas orifice
plates would need to be removed and replaced. Primary air cycle valves would also need
to be
replaced for Scenario 2. Additionally, air and gas piping modifications would need to be made at
all of the burner connections and modifications would need to be made to shell plate and
insulation to accommodate new block sizes and shapes.
The anticipated flame geometry with either
of the new burner models would be slightly
longer and smaller in diameter than the flame generated with the existing burner. When the
flame becomes less focused, heat cannot reach the bottom
of the slab, which may require the
installation
of additional burners on the bottom side of the furnace. Changes in flame geometry
can also result in burnt roof sections and tie beams (cross-overs). Most importantly, flame length
is related to turbulence and a specific flow pattern within the furnace. Modification of the flame
changes the flow pattern and impedes the ability to evenly heat the slab. Gas is combusted more
slowly with ULNBs and can result in unburned fuel contacting the slab.
In addition, the gas pressure requirement for the new models
is significantly higher and
would necessitate changes
to the
main
gas trains. Modification of the main gas trains has not yet
been evaluated. Any precise physical changes to the mains, or the ability to make these changes,
have not been evaluated; therefore the feasibility
of these changes and the associated economic
costs are not known.
Conversations with the manufacturer of the tunnel furnace have revealed that retrofitting
tunnel furnaces is extremely difficult due to the increased number
of burners within the furnace
and the increased surface area
of the slab per pound of steel (due to the thin slab casting). The
increased surface area results in the need for tighter atmospheric control and an increased focus
on maintaining surface quality.
Due to the continuous nature
of the steel-making process and the lack of redundancy in
the operation, the tunnel furnace must operate optimally at all times. As previously indicated,
the tunnel furnace receives slabs directly from the continuous caster. Unlike a traditional caster
which produces a slab that is stored prior
to processing, there is no place to store the slabs and no
way to "reheat" a slab from ambient temperature. The entire compact strip production (CSP)
process operates as one continuous process and all sections must be operating optimally to
produce a quality finished product. Unlike other facilities that operate tunnel furnaces, the
Riverdale facility does not have a second tunnel furnace or shuttle furnace that can be used
to
divert product between furnaces; nor does the Riverdale facility have any downstream finishing
operations (such as pickling)
to remove scale.
5.
As outlined above, each of the effects on the furnace operation directly impacts
product quality. ArcelorMittal's Riverdale facility produces both high and low carbon grades
and carbon alloy grade steel. Many
of these grades (including high carbon grades with up to
0.95% carbon; carbon alloy grades with specific additions
of chromium, nickel, molybdenum,
and vanadium; and carbon grade steels with boron additions) are not typically produced at other
facilities. ArcelorMittal has invested a great deal
of time and effort in order to produce a unique
product mix that is either breakout sensitive or ultra-light gauge. These two niches differentiate
our facility from other steel-making facilities throughout the country.
6.
The Chicago Ozone monitoring and modeling data indicate attainment of the
1997 Ozone NAAQS is imminent without additional NOx RACT emission reductions from the
manufacturing sector. Even without factoring in regulations with future effective dates, the
Ozone monitoring data indicates attainment to the 1997 Ozone NAAQS. Illinois EPA
acknowledges this condition in their November 14, 2008 public notice
of the Ozone status where
it states, "The Illinois EPA intends to request that U.S. EPA re-designate the Chicago area to
attainment
of the 1997 8-hour Ozone NAAQS based on ambient monitoring data from 2006
through 2008." NOx RACT should not be implemented
if the Chicago area achieves attainment.
While we recognize that Illinois EPA is obligated to submit its SIP and the NOx RACT rules to
U.S. EPA this summer and appreciate the threat
of sanctions, the rules should recognize the
actual improvement in Ozone monitoring data, the modeling results and continuing improvement
in ambient air quality trends in the Chicago area and stay on course with "on the book controls"
as a means
of demonstrating reasonable further progress and maintenance to the 1997 Ozone
NAAQS. This approach is encouraged and is consistent with U.S EPA's Clean Data Policy,
which enables reduced regulatory requirements for areas that attain the standards, but have not
yet been re-designated as attainment. We respectfully request Illinois EPA not develop and the
Board not adopt
NOx RACT rules that further burden manufacturers as another means
of
"leapfrogging" into other SIP initiatives that have longer timelines (e.g., PM 2.5 or 2008 Ozone
standard SIP rules) without allowing
"on the book" controls to take hold to further improve
ambient air quality.
In summary, these comments are intended as a supplement to the information previously
provided in our Pre-Filed Comments, dated November 25,
2008 as well as follow-up to the
several rounds
of hearings in this matter and informal discussions with the Agency.
ArcelorMittal asserts that operationally and functionally the tnnnel furnace cannot be compared
to, or considered to be a reheat furnace (or even compared to other tnnnel furnace facilities for
that matter). ArcelorMittal remains connnitted to working with the Agency throughout this
rulemaking proceeding; however, should the Agency deem that ArcelorMittaI's tnnnel furnace
requires regulation under the proposed rule, ArcelorMittal requests that Illinois
EPA allow a
case-by-case determination for the applicability
of this rule to the tnnnel furnace. This would
include the provision
of a specific definition or separate category for tnnnel furnaces and
utilization
of the emission factor currently utilized and permitted for the tnnnel furnace at
ArcelorMittal's Riverdale, Illinois facility, recognizing the unique nature
of the operation and the
advanced NOx control technologies already in use.
In the alternative, ArcelorMittal would request the Agency's support and joint filing in an
adjusted standard proceeding. Mr. Kaleel
is quoted in the proceedings from the October hearings
(specifically when talking about boilers and the possible need for SCR, but the same general
concept applies
to furnaces) as follows "I think an argument couId be made that if the costs for a
particular unit greatly exceed the range
we have in mind for RACT, the unit would qualify or at
least we couId support an adjusted standard type
of a proceeding."
See R08-19, Transcript from
October
14,
2008 hearing,
p.
128. However, given the overwhelming evidence delineated above,
ArcelorMittal believes that it has already established that its current burner configuration meets
RACT and
no additional regulatory proceeding is necessary, thereby saving both the Agency and
Pollution Control Board valuable time and resources.
Respectfully submitted,
ARCELORMITTAL USA, INC.
By:
CAv~\.J><,'J.
~
Christina
L.
Archer
Christina
L.
Archer
Associate General Counsel
ARCELORMITTAL USA, INC.
1 South Dearborn, 19
th
Floor
Chicago, Illinois 60603
(312) 899-3865
Exhibit A to Post.Hearing Comments
ArcelorMlttal Riverdale Tunnel Furnace NOx RAeT Analysis
Estimated Cost Effectiveness
for Burner Change (see note below)
3/1612009
CALCULATION FOR THE ANNUALIZED COST PER TON
NO~
REMOVED BASED ON CHANGING BURNERS FROM SERIES
1430
TO
1500
(Scenario
1)
or to
1550
(Scenario
21.
see references and notes below.
DirectCapilal Costs (DCC):
Purchased EquipmentCosts:
Equipment Costs (EC):
Sales Tax (0.03EC):
Total Purchased Equipment Costs (PEC)
Installa~on
Costs (IC), Including instrumentation,
Freigh~
Engineering, Startup Consultancy
Total PurChased Equipment and Installation Cost (ICC=PEC + IC):
Other Indirect Capital Costs (OCC)
Lost Production:
Total Other Indirect Capital Costs (OCC);
Contingency (CONT, 0.20 DCC+OCC]):
Total Capital Cos!
(TCC"ICC+OCC+CONn:
Annualized Capital Cos! (ACC=TCcxCFR)
Capital Recovery Factor (CRF):
DirectAnnual Costs (DAC):
Operation
(0)
Maintenance
(M)
Replacement MateMals
Utilfties
Waste Disposal
Chemicals
Other
Total DirectAnnual Costs (DAC):
Indirect Annual Costs (lAC):
Overhead (0.60(O+M)
Administrative (O.OITCC)
Property Tax
(o.oncC)
Insurance (0,02 TCC)
Total Indirect Annual Costs
MC):
Total Annual Cost (TAC=ACC+DAC+IAC):
Cap.rtal Recovery Faclor (CFR)
~
I = 10 % - inlerest rate
!.i1±...!r'
(1 +
I)n_l
n'"
5 years- economic equipment life
CFR=
0.254
Baseline
Existing Bumer (Bloom 1430) Emission Guarantee
(Ib NOxIMMBtu)
Natural Gas
Tunnel Furnace Natural Gas Consumption with Series 1430 (Actual 2005 MMBtu)
NO:: Emissions
NOx Emissions
w~h
Series 1430 (Actual tons
NO~jn
2005)
Surner Upgrade Scenarios
Burner Series (Model)
Burner Upgrade Emission Guarontee (Ib NOxIMMBtu)
Natural Gas
Tunnel Furnace Natural
Gas Consumption (MMBtufyr)
NOx Emissions
NOx Emissions = EmiSSion Guarantee' NG usageJ2000 (TPY)
Scenario
1
Scenario
2
1500
Burner
1550
Burner
$1,230,000
$2,710,000
$36,900
$81,300
$1.266,900
$2,791,300
$300,000
$300,000
$1,566,900
$3,091,300
$0
SO
$313,380
$0
$618,260
"
$I,B80,2BO
$3,709,560
$496,013
$97B,573
$0
$0
$0
$0
SO
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$18,B03
$37,09<0
$IB,so3
$37,096
$37,606
$74,191
$75,211
$148.382
$571.224
$1,126,955
0.165
0.165
514430
514430
42.4
42.4
Model 1500
Model 1550
0.06B
0,054
514430
514430
17.5
13.9
Incremental Emisslons Reduction (tonsJyr):
25
29
"'(2005 NG
usage. 0.1651b NOxIMMBtuI2000). (NG usage. emission factor for replacement burnersl2000)
Cost-Effectiveness ($!ton):
$22,895
$39.472
References;
Reference
(1)
'"
(3)
(4)
(5)
see below
(6)
0)
I'>
In
IS)
'"
2005 NG Usage
calculafion
'"
Furnace NG
calculation
calculation
Note: Vendors were unable to guarontee product quality aspects associated with a bumerchange, therefore a bumer change is technically
infeasible for Riverdale's Tunnel Furnace, Cost information is provided for informational purposes only.
(1)
Bloom cost estimate (see email dated March 5, 2009 from
Dave
Church).
(2)
"EPA Pollution Control Cost Manual,
Sixth Edftion,. EPAl45218---n2-001, January, 2002, Table 2.4, Page 2-27.
(3)
Conservative Cost Estimate
(4)
Does not include downtime for installation or product yield consequences, which could be sl,gnificanl (not included as a conservative measure)
(5)
From EPA "Cost-Air" spreadsheets available on.line at http://Www.epa.govlttn.
(6)
"EPA Pollution Control Cos! Manual, Sixth Edftion," EPN452JB.02-001, January, 2002, Section 2.5.5.B
m
Riverdale cost of capital
(8)
"Alternative Control Techniques
Document. NOxEmisslonsfrom Iron and Steel Mills," EPAl4531R-94.065, September, 1994,
Section 6.1.3 for costs
of low-NOx burners applied to reheat furnaces.
.
(9)
Bloom provided NOx emission guarantees for changing
SeMes 1430 burners to Series 1500 and 1550.