BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
SECTION 27 PROPOSED RULES FOR
)
NITROGEN OXIDE (NOx) EMISSIONS
)
R07-19
FROM STATIONARY RECIPROCATING
) (Rulemaking-Air)
INTENRAL COMBUSTION ENGINES
)
AND TURBINES: AMENDMENTS TO
)
35 ILL. ADM. CODE PARTS 211 AND 217
)
NOTICE
TO:
John Therriault, Assistant Clerk
Timothy Fox, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
State of Illinois Center
State of Illinois Center
100 W. Randolph, Suite 11-500
100 West Randolph, Suite 11-500
Chicago, IL 60601
Chicago, Illinois 60601
Katherine D. Hodge
Kathleen C. Bassi
N. LaDonna Driver
Renee Cipriano
Hodge Dwyer Zeman
Joshua R. More
3150 Roland Ave.
Stephen J. Bonebrake
PO Box 5776
Schiff Hardin, LLP
Springfield, IL 62705-5776
6600 Sears Tower
233 S. Wacker Drive
Chicago, IL 60606-6473
PLEASE TAKE NOTICE that I have today filed with the Office of the Pollution Control
Board the attached TESTIMONY OF ROBERT KALEEL
and YOGINDER MAHAJAN of the
Illinois Environmental Protection Agency a copy of which is herewith served upon you.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
By: __/s/____________________
Rachel L. Doctors
Assistant Counsel
Division of Legal Counsel
DATED: March 26, 2008
P.O. Box 19276
Springfield, Illinois 62794-9276
217/782-5544
Electronic Filing - Received, Clerk's Office, March 26, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
)
)
SS
COUNTY OF SANGAMON
)
)
CERTIFICATE OF SERVICE
I, the undersigned, an attorney, state that I have served electronically the attached
TESTIMONY OF ROBERT KALEEL and YOGINDER MAHAJAN of the Illinois
Environmental Protection Agency upon the following persons:
John Therriault, Assistant Clerk
Timothy Fox, Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
State of Illinois Center
State of Illinois Center
100 W. Randolph, Suite 11-500
100 West Randolph, Suite 11-500
Chicago, IL 60601
Chicago, Illinois 60601
Katherine D. Hodge
Kathleen C. Bassi
N. LaDonna Driver
Renee Cipriano
Hodge Dwyer Zeman
Joshua R. More
3150 Roland Ave.
Stephen J. Bonebrake
PO Box 5776
Schiff Hardin, LLP
Springfield, IL 62705-5776
6600 Sears Tower
233 S. Wacker Drive
Chicago, IL 60606-6473
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
__________________________
Rachel L. Doctors
Assistant Counsel
Air Regulatory Unit
Division of Legal Counsel
Dated: March 26, 2008
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
SECTION 27 PROPOSED RULES FOR
)
NITROGEN OXIDE (NOx) EMISSIONS
)
R07-19
FROM STATIONARY RECIPROCATING
)
(Rulemaking-Air)
INTENRAL COMBUSTION ENGINES
)
AND TURBINES: AMENDMENTS TO
)
35 ILL. ADM. CODE PARTS 211 AND 217
)
TESTIMONY OF ROBERT KALEEL
My name is Robert Kaleel. I am the Manager of the Air Quality Planning Section,
Division of Air Pollution Control, Bureau of Air at the Illinois Environmental Protection Agency
(“Illinois EPA”), Springfield, Illinois. I have a Bachelor of Science degree in meteorology from
Northern Illinois University. I have worked at the Illinois EPA for more than 26 years, and have
been in my present position since 2004. Prior to that, I was the Manager of the Air Quality
Modeling Unit in the Air Quality Planning Section, a position that I held for more than 15 years.
I have also worked as a private consultant as a specialist in air quality modeling. As Manager of
the Air Quality Planning Section, my responsibilities include oversight of staff that provides
technical support for regulatory initiatives needed to address air quality issues in Illinois,
including the regulatory proposal before the Illinois Pollution Control Board (“Board”) at this
hearing. The Air Quality Planning Section also provides technical support to the Bureau of Air’s
permitting and enforcement functions, and is responsible for maintaining the Bureau’s emission
inventory system, including Annual Emission Reports. I have been closely involved with the
development of Illinois’ State Implementation Plans (“SIPs”) to address the PM
2.5
and ozone
nonattainment
areas in Illinois.
Page 2
My testimony will explain the purpose of this proposal, and describe the components of
the proposed rule. Included in this proposal are amendments to 35 Ill. Adm. Code Section
201.146, and Parts 211 and 217. Adoption of the proposed rules will reduce emissions of
nitrogen oxides (“NO
x
“) from stationary reciprocating internal combustion engines and turbines
located in the Chicago and Metro-East ozone and PM
2.5
nonattainment areas. This proposal is
intended
to address, in part, Illinois’ obligation to meet certain requirements under the federal
Clean Air Act (“CAA”), specifically the requirements for reasonably available control
technology (“RACT”) for these source categories.
On July 18, 1997, United States Environmental Protection Agency (“USEPA”)
promulgated revised primary and secondary ozone National Ambient Air Quality Standards
(“NAAQS”) that increased the averaging period for the ozone standard from 1-hour to 8-hour
and lowered the concentration for violations from 0.12 to 0.08 parts per million (“ppm”). It has
long been recognized that volatile organic material (“VOM”) and NO
x
are the primary precursors
responsible for the formation of ground level ozone. Illinois has two areas (greater Chicago and
Metro East/St. Louis), consisting of 12 counties or partial counties, that were designated as
nonattainment areas for the 8-hour ozone standard. The designations were effective on June 15,
2004. The two areas in Illinois are classified as moderate nonattainment areas.
On July 18, 1997, USEPA also added a new 24-hour and a new annual NAAQS for fine
particles
, using as the indicator particles with aerodynamic diameters smaller than a nominal 2.5
micrometers, termed PM
2.5
. In October 2006, USEPA subsequently completed another review
of the NAAQS for particulate matter, and as a result, strengthened the 24-hour standard
(hereinafter “PM
2.5
2006”). 71
Fed. Reg.
61144 (October 17, 2006).
USEPA has determined that, in addition to direct particulate matter, that NO
x
, sulfur
Page 3
dioxide (“SO
2
”), VOCs, and ammonia are precursors to the formation of PM
2.5
. States are
required to address NO
x
, SO
2
, and direct emissions of PM
2.5
in their attainment plans to address
the 1997 PM
2.5
NAAQS. USEPA designated two areas in Illinois (greater Chicago and Metro
East/St. Louis), consisting of 12 counties or partial counties within Illinois, as not attaining the
PM
2.5
standard. The designations became effective on April 5, 2005. The attainment
demonstration
is due April 5, 2008, and the attainment date for most areas is April 5, 2010.
This proposed rulemaking is intended to meet certain obligations of the State of Illinois
under the CAA, 42 U.S.C. § 7401
et seq
.; specifically, to satisfy Illinois’ obligation to submit a
SIP to address the requirements under Sections 172 and 182 of the CAA for major stationary
sources of NO
x
in areas designated as nonattainment with respect to the NAAQS.
See
, 42 U.S.C.
§§ 7502 and 7511a. Under Section 110 of the CAA and related provisions, states are required to
submit for USEPA’s approval, SIPs that provide for the attainment and maintenance of standards
established by USEPA through control programs directed to sources of the pollutants involved.
42 U.S.C. §7410. The CAA also provides for the State to address emissions sources on an area-
specific basis through such requirements as reasonably available control measures (“RACM”)
and RACT.
See
, 42 U.S.C. §§7502 and 7511a. For each nonattainment area, the CAA requires
the State to demonstrate that it has adopted “all reasonably available control measures as
expeditiously as possible (including such reductions in emissions from existing sources in the
area as may be obtained through the adoption, at a minimum, of reasonably available control
technology) and shall provide for attainment of the national primary ambient air quality
standards.” 42 U.S.C. § 7502(c)(1).
The Illinois EPA has formulated a thorough regulatory approach to comply with the
State’s requirements under the CAA, and as such, is proposing reasonable and cost effective NO
x
Page 4
controls on various source categories. Control of engines and turbines is one element of Illinois
EPA’s regulatory approach to implement RACT in ozone and PM
2.5
nonattainment areas. In
addition, the Illinois EPA has developed a regulatory proposal that will be addressed in a
separate Board rulemaking to implement RACT affecting other major stationary source
categories, such as industrial boilers, process heaters, glass melting furnaces, cement kilns, lime
kilns, furnaces used in steel making and aluminum melting, and fossil fuel-fired stationary
boilers.
The NO
x
control approach in this proposal for engines and turbines is consistent with the
Board’s
recently adopted rulemaking affecting large engines subject to Phase II of the NO
x
SIP
Call.
See
, R07-18,
In the Matter of: Fast-Track Rules Under Nitrogen Oxide (NO
x
) SIP Call
Phase II: Amendments to 35 Ill. Adm. Code Section 201.146 and Parts 211 and 217
. The Illinois
EPA has proposed in this rulemaking that turbines and engines not subject to Phase II of the NO
x
SIP Call be subject to NO
x
emissions limits at the same level as that required by R07-18 which
met the State’s obligations under Phase II of the NO
x
SIP Call. As demonstrated in the Technical
Support
Document submitted with this proposal, the NO
x
SIP Call emission limits are cost
effective and technologically feasible for the emission units affected by this proposal.
The geographic region subject to “Subpart Q: Stationary Reciprocating Internal
Combustion Engines and Turbines” are the counties, or portions thereof, that are designated as
nonattainment of the ozone and PM
2.5
NAAQS. Emissions of NO
x
from stationary internal
combustion engines are not currently regulated in the State of Illinois. The proposed regulations
will affect existing and new units. The Illinois EPA estimates that there are approximately 63
stationary engines, and about 58 turbines that may be affected by this proposal. The estimated
reduction of NO
x
emissions from the affected units is about 1,020 tons per ozone control season,
Page 5
and 2,155 tons annually.
The Illinois EPA has determined that affected engines and turbines can meet the
requirements of proposed Subpart Q through a combination of control techniques such that
compliance is both technically feasible and economically reasonable. Based on USEPA’s
Alternative Control Techniques document there are a number of control options available which
achieve the control levels proposed in this rulemaking in the range of unit sizes affected. In
addition, the Illinois EPA found that the levels proposed in this rule were consistent with rules
promulgated in other states. The Illinois EPA considers the control requirements of this proposal
to be technically feasible and economically reasonable.
The proposal being considered today is the result of an extensive stakeholder process.
Throughout the development of the rule, the Illinois EPA has sought and received comments
from interested parties. The Illinois EPA held three general meetings (August 25, 2005,
October 5, 2005, and November 14, 2005) to which owners and operators of affected units and
environmental groups were invited. At least three additional meetings were held at the request of
particular groups or companies affected by this proposal. The Illinois EPA’s proposal was
amended several times in response to comments provided by stakeholders. It is my
understanding that the parties have reached agreement on the major components of the proposal.
The Illinois EPA is amending Subpart Q: Stationary Reciprocating Internal Combustion
Engines and Turbines to Part 217. The rule is intended to apply to stationary reciprocating
internal combustion engines rated 500 brakehorsepower and above, and turbines rated 3.5 MW
and above. The Illinois EPA is proposing separate concentration limits for different types of
engines and turbines, and based on the kind of fuel used.
Page 6
The Illinois EPA recognizes that some of the engines and turbines in use in Illinois
operate only intermittently and may not be cost-effective to control. To reduce compliance costs,
the proposal provides a number of exemptions and compliance options. Proposed exemptions
are offered for emergency and standby units, units used for research or performance verification,
units that are used primarily to control gas from landfills, units used for agricultural purposes,
and portable units. The Illinois EPA is also proposing special requirements for low usage units
where the potential to emit from all engines and turbines at a source is below 100 ton per year of
NO
x
emissions. Low usage units may also be exempt from the requirements to meet the
emission
limits if the aggregate usage of all the uncontrolled affected units are below specified
thresholds.
The proposal includes alternate compliance options which provide companies with
flexibility in reducing their compliance costs. The proposal allows owners and operators the
option to comply with an emissions averaging plan in lieu of meeting the specified concentration
limit for each affected unit. Units located in Illinois that commenced operation before January 1,
2002, and are owned by the same company or parent company, can in most cases be included in
an averaging plan. An averaging plan must insure that the total mass of actual NO
x
emissions
from
all affected units included in the emissions averaging plan must be less than the total mass
of allowable NO
x
emissions for the same units. The proposal contains specific formulas for
making the calculations needed to demonstrate compliance. This option will allow owners to
control units that are most cost effective to control, and reduce or avoid control costs for units
that are more expensive to control.
Another compliance option proposed in the rule allows owners and operators to use NO
x
SIP Call allowances to meet the compliance requirements if they meet certain criteria. This
Electronic Filing - Received, Clerk's Office, March 26, 2008
Page 7
option is intended to provide flexibility to owners and operators when noncompliance is due to
unforeseen circumstances. An owner or operator can use this option up to two times in any five-
year rolling period. The applicable type of NO
x
allowances must be used, that is, annual
allowances must be used for exceedances of an annual limit and ozone season allowances must
be used for exceedances of a seasonal limit. This option is included in the proposal at the
suggestion of stakeholders and will again provide increased operating flexibility and will reduce
compliance costs.
The Illinois EPA is proposing a compliance date of May 1, 2010. The proposal also
provides a flexible approach for meeting the requirements for testing and monitoring. In general,
affected units must conduct a compliance test by the applicable compliance date. Affected units
that operate intermittently do not need to be tested until after they have operated at least 876
hours in a year. Units that operate less than 876 hours per calendar year can be tested at the
owner’s or operator’s choosing any time within the first five years after the applicable
compliance date. In years in which a compliance test is not performed, the proposal requires that
an inexpensive portable NO
x
monitor be used annually to verify continued compliance. For units
that
operate less than 876 hours per calendar year, monitoring is required only once every five
years.
Electronic Filing - Received, Clerk's Office, March 26, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
SECTION 27 PROPOSED RULES FOR
)
NITROGEN OXIDE (NOx) EMISSIONS
)
R07-19
FROM STATIONARY RECIPROCATING
) (Rulemaking-Air)
INTENRAL COMBUSTION ENGINES
)
AND
TURBINES: AMENDMENTS TO
)
35 ILL. ADM. CODE PARTS 211 AND 217
)
TESTIMONY OF YOGINDER MAHAJAN
Good Morning. My name is Yoginder Mahajan. I am employed as an Environmental
Protection Engineer in the Air Quality Planning Section in the Bureau of Air of the Illinois
Environmental Protection Agency (Illinois EPA). I have been employed in this capacity since
March 1992. Prior to my employment with the Illinois EPA, I worked for various metal
fabrication industries for nine (9) years. My educational background includes a Bachelor of
Engineering Degree in Mechanical Engineering from Bhopal University at Bhopal, India.
As part of my regular duties in the Air Quality Planning Section, I have been involved
with preparing emissions estimates for various source categories used in the development of the
1990 ozone season weekday emissions inventories; evaluating control technologies applicable to
volatile organic material (VOM) emissions sources utilized in the preparation of the Rate-of-
Progress plans for the greater Chicago and Metro/St. Louis ozone nonattainment areas; and
assisting in the development of regulations for the control of VOM emissions from the source
categories included in the Rate-of-Progress plans. Regarding the proposal before you today, I
have been involved in the development of the regulations to control nitrogen oxides (NOx) from
stationary reciprocating internal combustion engines (RICE) and turbines. I provided the list of
2
affected sources for the proposal and technical feasibility of NOx controls for the Technical
Support Document (TSD) for the proposal.
RICE and turbines are used throughout the United States to drive compressors, pumps,
electric generators and other equipment. In Illinois, a prominent use of large engines is to drive
natural gas pipeline compressors. Emissions of NOx are the result of combustion of fuel at high
temperatures and pressures in the RICE and turbines, which cause the nitrogen and oxygen in the
air that sustains the combustion to unite and form the various oxides of nitrogen that constitute
NOx.
Today’s proposal is to control NOx emissions from sources in the nonattainment areas
(NAA) of National Ambient Air Quality Standards for eight-hour ozone and PM
2.5
that have a
potential
to emit 100 tons or more per year of NOx and have RICE of 500 brake horse power
(bhp) capacities and above, and stationary turbines of 3.5 megawatt (MW) capacities and above.
As part of evaluation of the control of NOx from RICE and turbines, the Illinois EPA
identified several sources of guidance. The United States Environmental Protection Agency
(U.S. EPA) published two Alternative Control Techniques (ACT) documents - NOx Emissions
from Stationary Reciprocating Internal Combustion engines, and NOx Emissions from
Stationary Gas Turbines. Another source that was utilized was Controlling Nitrogen Oxides
Under the Clean Air Act: A Menu of Options, a document published by State and Territorial Air
Pollution Program Administrators/Association of Local Air Pollution Control Official. These
documents contain detailed information on the description of sources of NOx emissions, various
techniques of controlling NOx, and the costs of various controls. The Illinois EPA relied upon
the information contained in these documents for the proposed level of NOx controls, costs and
economic impacts for this proposal.
3
For reciprocating engines and turbines, both combustion controls and post-combustion
catalytic reduction have been developed. For reciprocating engines, air/fuel ratio adjustments,
low emission combustion, and prestratified charge all function by modifying the combustion
zone air/fuel ratio, thus influencing oxygen availability and peak flame temperature. Ignition
timing retard lowers the peak flame temperature by delaying the onset of combustion. For
turbines, water/steam injection and dry low NOx combustors are the combustion control
techniques to control NOx emissions. Selective catalytic reduction and non-selective catalytic
reduction are the two post-combustion control strategies that destroy NOx once it has been
formed for reciprocating internal combustion engines and turbines.
After reviewing the U.S. EPA’s guidance documents, the Illinois EPA determined that
there are cost effective NOx control techniques available to reduce NOx emissions from RICE
and turbines. Lean burn spark-ignited RICE may install low emission combustion, rich burn
spark-ignited RICE may use non-selective catalytic reduction, and compression ignited diesel
RICE may use electronic injection techniques to cost-effectively comply with this proposal. For
turbines, water/steam injection for oil/gas-fired turbines, and low NOx combustors for gas-fired
turbines are available to cost-effectively comply with the proposal.
As shown in the table 7-1 of the TSD, the Illinois EPA’s 2004 NOx inventory of sources
in the greater Chicago and Metro-East/St. Louis NAAs contains 541 RICE. Also, the Illinois
EPA estimated that there are 79 RICE greater than 500 bhp but less than 1,500 bhp
capacities
which are not included in the inventory. In total, there are 620 RICE (541 + 79) that are
potentially affected by this proposal. The Illinois EPA applied an exemption of approximately
100 tons NOx per year from all RICE at a facility and estimated that out of 541 RICE, 55 were
actually impacted by this proposal. In addition, the, Illinois EPA estimated that eight RICE out
4
of 79 of greater than 500 bhp capacity are not included in the Illinois EPA’s inventory and may
be impacted by this proposal. In total, 63 RICE are expected to be impacted by this proposal.
The Illinois EPA’s 2004 NOx inventory of sources in the greater Chicago and Metro-
East/St. Louis NAAs contains 220 turbines at industrial and electricity generating facilities that
are potentially affected by this proposal. The Illinois EPA applied an exemption of
approximately 100 tons NOx per year from all turbines at a facility and estimates that out of 220
turbines, 58 will be impacted by this proposal.
The Illinois EPA estimates that this proposal will provide a reduction of NOx emissions
of 1,469 tons per year and 639 tons per ozone season from 63 RICE. The estimated cost
effectiveness of NOx controls for RICE will be $319 to $2,575 per ton of NOx (in 2004 dollars),
depending on the type and size of RICE.
The Illinois EPA estimates that this proposal will provide a reduction of NOx emissions
from gas turbines by 686 tons per year and 381 tons per ozone season from 58 affected turbines
at a cost effectiveness of $314 to $3,005 per ton of NOx (in 2004 dollars) depending on the type
and size of the turbine.