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.
    74-235

    -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

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