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

    Back to top