ILLINOIS POLLUTION CONTROL BOARD
September 11,
1986
IN THE MATTER OF:
)
PETITION FOR SITE—SPECIFIC
)
REGULATION APPLICABLE TO
)
PARTICULATE EMISSIONS FROM
)
R84—48
LTV STEEL COMPANY’S
CHICAGO WORKS HOT SCARFING
)
MACHINES
(35 Ill.
Adm. Code
212.451)
Proposed Rule.
Second Notice.
OPINION AND 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
Ill.
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.
First Notice was adopted on March 27,
1986 and published at
10
Illinois Register 5695, April
11, 1986.
During the first
notice commend period,
the Board
received a comment from the
Illinois Environmental Protection Agency (Agency).
The Agency
suggested that the language proposed
at First Notice be modified
by
including a reference that the exception not only applies to
the hot scarfing machine but also
to the related pollution
control equipment.
The Agency also commented that
if the
respirable particle
ambient air quality standard proposed by
USEPA replaces the
total suspended particulate standard,
additional controls may be needed on LTV’s hot scarfing machine.
In response to these comments, the Board believes that a
change
to the proposed standard
for LTV which
is based upon
a
possible change of the National Ambient Air Quality Standard
(NAAQS)
for particulate matter would be premature.
If the Board
were
to accept this methodology,
it would place the Board
in the
untenable position of not being able
to grant adequate relief
from a standard which
is currently under
review.
The Board also
believes that the language modification suggested by the Agency
72-362
—2—
is unnecessary as the language proposed by the Board
in its First
Notice Opinion and Order adequately describes the equipment to
which the exception applies.
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
irigots 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
72-363
—3—
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 3.
Harlan, Jr., Environmental
Management Engineer
at LTV, calculated standard deviations for
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
72.364
—4—
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
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 Schulze, 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 mpst
conditions
to be caught in its wake.
(R.
at 102).
Because Mr.
Schuj.ze was uncertain as to whether, under USEPA 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,
72.365
—5—
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).
The
results of Mr.
Schulze’s calculations are
as follows:
Maximum Off 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 minim4m amount of ambient
impact considered “significant” is
5 u/m’~as a 24—hour average
and
1 u/mi 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 fl.
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).
72.366
—6—
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).
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.
The
Board proposes
to grant LTV’s petition
for site—specific
relief.
However, since this revision must be approved by USEPA
for inclusion
in the State Implementation Plan the Board
is
proposing
an emission limitation of 0.01 gr/dscf as an hourly
average
to be consistent with the RACT-based guidelines.
LTV has
provided evidence that
it
is able to meet this limitation even
during its peak historical hour and was afforded an opportunity
to comment on this addition but no
response was received.
Therefore, the Board proposes for Second Notice LTV’s proposal
for site—specific relief from the emission standard
of
35 Ill.
Adm.
Code 212.451 as
it appeared at first
notice.
ORDER
The Board directs that second notice of the following
proposed rule be submitted
to the Joint Committee on
Administrative Rules:
Title
35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER:
EMISSION STANDARDS AND
LIMITATIONS FOR STATIONARY SOURCES
SUBPART R:
PRIMARY AND FABRICATED
METAL PRODUCTS AND MACHINERY MANUFACTURE
Section 212.451
Hot Scarfing Machines
All
hot scarfing machines shall
be controlled by
pollution control equipment.
Emissions from said
~ollution control equipment shall not exceed 69 mg/dscm
(0.03 gr/dscf) during hot scarfing operations.
Provided, however, that the existing hot scarfing
machine operated by the LTV Steel Company,
Inc., at its
Chicago Works, which employs wet scrubbers, may emit
particulate matter
in amounts not exceeding 138 mg/dscm
(0.06 gr/dscf)
during hot scarfing operations and not
72-367
—7—
exceeding 23 mg/dscin (0.01 gr/dscf)
as
an hourly
average.
IT
IS SO ORDERED.
Board Member
R.
Flemal dissented.
I, Dorothy
M.
Gunn, Clerk of the Illinois Pollution Control
Board, hereby cert~fy,thatthe above Opinion and Order was
adopted on the
//~Z-
day ~
,
1986 by a vote
of
____________
(7i~Z~
/7.
Dorothy
M.
Ginn,
Cletk
Illinois Pollution Control Board
72-368