ILLINOIS POLLUTION CONTROL BOARD
March 27,
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.
First Notice.
PROPOSED OPINION AND ORDER OF THE BOARD
(by J. 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)(O.03 grains per dry standard cubic
foot
(gr/dscf))
during 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 in this
matter 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 based on the statutory criteria
at
Ill.
Rev. Stat.
Ch.
96-’/2, par.
7404
(1985).
The Economic
Technical Advisory Committee concurred with this finding during
its October
17,
1985 meeting.
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.
*As the result of
a merger between Republic Steel Company and the
LTV Corporation,
the petitioner is now known as LTV Steel
Company.
-2-
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 rnown
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-5O.
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
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
-3-
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
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
—4-
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. Schuize
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 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,
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:
—5-
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. Schuize 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/ma as
a 24-hour average
and
1 u/ma 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
minimis”
emissions
is
not
“reasonably
achievable.”
(See
Exh.
15).
—6—
Based on all the foregoing,
the Board
finds
that compliance
with
35 Ill.
Adm.
Code 212.451 although technically achievable
is
not economically feasible and would impose an unreasonable
financial hardship on LTV Steel Company without measurable
reductions
in particulate concentrations around the plant.
Thus,
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 SIP the Board
is proposing to
include
language limiting emissions
to 0.01 gr/dscf as an hourly average
as being consonant with the RACT-based guidelines.
Petitioner
has provided evidence that
it
is able
to meet this limitation
even during its peak historical hour,
but
it
is welcome
to
comment on this addition during the first notice period.
ORDER
The Clerk of the Board is directed to cause first notice
publication
in the Illinois Register of the following amendment
to
35 Ill.
Adm.
Code 212.451:
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.~+51
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 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
exceeding 23 mg/dscm
(0.01 gr/dscf)
as an hourly
average.
IT IS SO ORDERED.
—7-
R.
Flemal dissented.
J.
Dumelle concurred.
I Dorothy M.
Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Proposed Opinion and Order
was adopted
on the
~
day of ______________________,
1986,
by
a vote
of
~-~/
.
Dorothy
M. Gu~, Clerk
Illinois Pollution Control Board