AUG-29-2008 10:23
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DLC LEGAL
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P•02
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARDCLERK'S
RECEIVED
OFFICE
IN THE MATTER OF:
?
)?
AUG 2 9 2008
)
STATE OF ILLINOIS
NITROGEN OXIDES EMISSIONS FROM
?
)?
R08-19
?
Pollution Control Board
VARIOUS SOURCE CATEGORIES:
?
)?
(Rulemaking – Air)
AMENDMENTS TO 35 ILL. ADM. CODE
?
)
PARTS 211 AND 217
?
)
NOTICE
TO: John Therriault
Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph St., Suite 11-500
Chicago, IL 60601
u r\
?
;
f; ;
SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board the
TESTIMONY OF ROBERT ICALEEL, VIR GUPTA, AND
JAMES E. STAUDT. Ph.D.,
a copy of which is herewith served upon you.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
?
Gina Roccaforte
Assistant Counsel
Division of Legal Counsel
DATED: August 29, 2008
1021 North Grand Avenue East
P. O. Box 19276
Springfield, IL 62794-9276
?
THIS FILING IS SUBMITTED
217/782-5544
?
ON RECYCLED PAPER
AUG-29-2008 10:23?DLC LEGAL
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P.03
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERKS OFF
ICE
IN THE MATTER OF:
NITROGEN OXIDES EMISSIONS FROM
VARIOUS SOURCE CATEGORIES:
AMENDMENTS TO 35 ILL. ADM. CODE
PARTS 211 AND 217
AUG 2 9
2008
R08-19?
Pollution
STATE OF
Control
ILLINOIS
Board
(Rulemaking – Air)
TESTIMONY OF ROBERT KALEEL
My name is Robert Kakel. I am the Manager of the Air Quality Planning Section in
the Bureau of Air at the Illinois Environmental Protection Agency ("Illinois EPA"). I have a
Bachelor of Science degree in meteorology from Northern Illinois University. I have worked
at the Illinois EPA for more than twenty-six 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 fifteen 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 to address the PM 2 5 and ozone nonattainment areas in Illinois.
My testimony will explain the purpose of this proposal, and highlight some of the
components of the proposed rule. I would like to note that the Illinois EPA performed
substantial outreach to stakeholders on the proposed rule. The Illinois EPA has participated
in meetings with interested stakeholders, and has posted a draft of the proposed rule on its
website for public comment. Illinois EPA received extensive comments on the draft rule,
and this proposal incorporates many of the concerns and suggestions put forth in these
comments.
The Illinois EPA's proposal is intended to control nitrogen oxides ("NOx") emissions
from various emission units located within the Chicago and Metro-East nonattainment areas
AUG-29-2008 10:24
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P.04
to meet certain obligations of the State of Illinois under the federal Clean Air Act ("CAA").
Specifically, the proposal is intended to satisfy Illinois' obligation to submit a State
Implementation Plan ("SW") to address the requirements under Sections 172 and 182 of the
CAA for major stationary sources of NO„ in areas designated
as
nonattainment with respect
to National Ambient Air Quality Standards ("NAAQS"). In addition, Section 110 of the
CAA requires that states submit for the United States Environmental Protection Agency's
("USEPA") approval state plans that provide for the attainment and maintenance of standards
established by USEPA through control programs directed to sources of the pollutants
involved through such requirements
as
reasonably available control measures ("RACM") and
reasonably available control technology ("RACT"). RACT is defined as the lowest emission
limitation that a particular source can meet by applying a control technique that is reasonably
available considering technological and economic feasibility. The Illinois EPA has
concluded that affected sources can meet the requirements of the proposed rule through a
number of control techniques such that compliance is both technically feasible and
economically reasonable.
In Illinois, there are two areas designated as nonattainment (moderate) for the 8-hour
ozone standard. The first is the Chicago-Gary-Lake County nonattainment area, which
includes Cook, DuPage, Kane, Lake, McHenry, and Will Counties, and portions of Grundy
and Kendall Counties in Illinois, as well
as certain
counties in northwest Indiana. The
second area is the St. Louis nonattainment area, which includes the Metro-East counties of
Jersey, Madison, Monroe, and St. Clair,
as
well as several counties in Missouri. NO. is
considered to be one of the primary precursors for the formation of ozone, so the CAA
requires that Illinois' SIP provide for the implementation of RACT controls for NO. for
ozone nonattainment areas classified as moderate and above.
In Illinois, there are two areas designated
as
nonattainment for the PM
2
.
5
standard, the
first being the Chicago-Gary-Lake County nonattainment area, which includes the same
northern Illinois counties
as the
8-hour ozone nonattainment area. The second nonattainment
area is the St. Louis nonattainment area, which again has similar, though not identical, area
boundaries as for ozone. For PM
2 . 5
, Jersey County is not part of the nonattainment area, but
Baldwin Township in Randolph County is included. NO. is considered a primary precursor
to the formation of PM
25
, so the promulgation of RACT controls for NO„ is appropriate.
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It should be noted that USEPA has in recent years completed reviews of the NAAQS
for both particulate matter and ozone. In October 2006, USEPA strengthened the 24-hour
PM2
5
standard, and in March 2008, USEPA strengthened the 8-hour ozone standard. It is
likely that the same areas in Illinois that are currently designated
as
nonattainment for the
present standards will soon be designated
as
nonattainment for one or both of these revised
standards. Reducing NO„ emissions in these areas will likely help Illinois to achieve the
newly revised NAAQS as well satisfying current CAA obligations.
Illinois EPA's regulatory proposal aims to achieve NO. reductions in Illinois from a
number of source categories while providing reasonable flexibility for the affected sources.
The regulatory proposal requires major stationary sources located in the nonattainment areas
in Illinois to comply with the emissions limitations set by the proposed rule beginning May 1,
2010. Major stationary sources include those that emit or have the potential to emit NO. in
an amount equal to or greater than 100 tons per year. The emissions limitations apply on an
ozone season basis and on an annual basis to industrial boilers, process heaters, glass melting
furnaces, cement kilns, lime kilns, iron and steel reheat, annealing, and galvanizing furnaces,
aluminum reverberatory or crucible furnaces, and fossil fuel-fired boilers that emit at least 15
tons of NO„ per year or at least five tons per ozone season and are located at major stationary
sources.
Flexibility is built into the regulations as they allow compliance to be demonstrated
through an emissions averaging plan. Sources may aggregate and then average the NO,
emissions from units at the same location in Illinois to comply with the emissions limitations
provided that each unit is covered by only one emissions avenging plan. The emissions
averaging option allows the owners or operators of affected sources more flexibility in
complying with the requirements of this proposal while achieving the same amount of
emission reductions at that location.
In addition, the proposed regulations provide for certain exemptions. Such
regulations do not apply to an emission unit operating under a federally enforceable limit of
NO. emissions from such units to less than 15 tons per year and less than five tons per ozone
season. In addition, the regulations do not apply to coal-fired boilers that are complying with
the multi-pollutant standards under Section 225.233 of Part 225, or the combined pollutant
3
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standards under Subpart F of Part 225 (i.e., control requirements and standards for emissions
of mercury, NO„ and SO2).
afrob/NOx RACT Testimony Kaleel (Aug 08)
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AUG-29-2008 10:24
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P . 07
IN THE MATTER OF
NITROGEN OXIDES EMISSIONS FROM
VARIOUS SOURCE CATEGORIES:
AMENDMENTS TO 35 ILL. ADM. CODE
PARTS 211 AND 217
TESTIMONY OF VIR GUPTA
RECEIVED
C
LERK'S
OFFICE
AUG 2 9
2008
poSITZEn
LrLoI
t
I
Board
(Rulemaking – Air)
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
R08-19
My name is Vir Gupta. My educational background includes a Master of
Engineering Degree in Chemical Engineering from Punjab University, Chandigarh, India,
in May 1973. From August 1971 to May 1979, I worked as a scientific officer at Bhabha
Atomic Research Center in Mumbai, India, where my job duties included research and
development work for the production of thorium compounds from thorium concentrates.
I joined the Illinois Environmental Protection Agency ("Agency") on November
1, 1979, and started my work in the Permit Section of the Bureau of Air. I reviewed
permits for electric utility boilers, industrial boilers, chemical process industries, bulk
gasoline plants and terminals, and sources emitting toxic and hazardous pollutants,
among others. I also attended several training courses and seminars on the control of
sulfur dioxide ("S0
2
"), nitrogen oxides ("NOx"), particulate matter, volatile organic
compounds and hazardous air pollutants.
I began working in the Air Quality Planning Section of the Bureau of Air in June
1992 and since that time I have been involved in various projects including preparation of
the 1990 ozone season weekday emissions inventories, draft NOx Reasonably Available
Control Technology ("RACT") regulations for Chicago and Metro-East non-attainment
areas, clean up of existing air pollution control regulations, NOx SIP Call regulations,
general conformity regulations
as
applicable to federal facilities, conducting a feasibility
AUG-29-2008 10:25
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P.08
study for multi-pollutant controls for electric utility boilers, and preparing summary
reports on new electric utility turbines and boilers permitted by the Agency. I also
attended several seminars and workshops for the control of NOx, SO
2, particulate matter,
and mercury emissions.
My involvement in the development of this regulatory proposal includes
identification of potentially affected sources located in the Chicago and Metro-East non-
attainment areas and estimation of emissions reductions expected from the proposed
emission limits.
For this purpose, I reviewed the Agency NOx inventory for the year 2005 for
major sources of NOx emissions. I also reviewed several federal Alternative Control
Techniques Documents for NOx emissions from industrial/commercial/institutional
boilers, utility boilers, process heaters, cement kilns, iron and steel plants, and glass
melting furnaces, a STAPPA/ALAPCO document on controlling nitrogen oxides under
the Clean Air Act, and the federal AirControlNet's Documentation Report. These and
other documents are referenced in the Technical Support Document ("TSD") that is filed
with this rulemaking.
Based on my review of the literature, other state regulations, and the Agency's
inventory, I recommended the following source categories for NOx controls: Industrial
and electric utility boilers, process heaters, cement and lime kilns, reheat, annealing and
galvanizing furnaces at iron and steel plants, glass melting furnaces, and aluminum
melting furnaces. These source categories are discussed in further detail in the TSD.
Based on the proposed NOx emissions limits, I prepared a summary of anticipated
NOx reductions in Chicago and Metro-East non-attainment areas which is listed in
2
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Section 10, Table 10-1 in the TSD. This table shows the number of units in each source
category affected by the proposed rule, year 2005 NOx emissions, controlled NOx
emissions, and NOx reductions from the application of the proposed limits. In summary,
this table shows a total of 196 units emitting 44,625 tons of NOx emissions in 2005, and
NOx reductions of 20,666 tons, or a 46.3% reduction, by the application of the proposed
limits.
3
AUG-29-2009 10:25
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P.10
BEFORE THE ILLINOIS
POLLUTION CONTROL
BOARDRECEIVED
CLERK'S OFFICE
IN THE MATTER OF:
)
AUG 2 9
2008
NITROGEN OXIDES EMISSIONS FROM
)
R08-19
STATE OF ILLINOIS
VARIOUS SOURCE CATEGORIES:
)
(Rukmaking _ Rfitiution Control Board
AMENDMENTS TO 35 ILL. ADM. CODE
)
PARTS 211 AND 217
)
TESTIMONY OF JAMES K STAUDT,
Ph.D.
I, James E. Staudt, have been retained by the Illinois Environmental Protection Agency
("Illinois EPA")
as an
expert in this nitrogen oxides ("NOx") rulemaking addressing various
source categories and Reasonably Available Control Technology ("RACY).
The purpose of my testimony is to describe how NOx emissions from industrial facilities
impacted by the proposed NOx RACT rule can be controlled and what those controls are
expected to cost for affected facilities. These source types include Industrial Boilers and
Electrical Generating Unit Boilers, Process Heaters, Cement Kilns, Lime Kilns, Reheat,
Annealing, and Galvanizing Furnaces used at Iron and Steel Plants, Glass Melting Furnaces, and
Aluminum Melting Furnaces that meet the size and other criteria to be subject to the proposed
rule.
1. BACKGROUND AND QUALIFICATIONS
I am currently the president of Andover Technology Partners ("ATP"). As president of
ATP, I have advised power plants, industrial facilities, equipment suppliers and government
agencies on different means of complying with emissions regulations in cost-effective ways. For
over twenty years, I have focused on pollutant control technologies, including NOx, sulfur
dioxides ("S0
2
") and mercury emissions control. For the past eleven years (since 1997), I have
been a consultant with my own business — Andover Technology Partners. My primary area of
business as a consultant is associated with my expertise relating to the performance
and
cost of
AUG-29-2008 10:25
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air pollution control on power plants and industrial facilities. Clients have included the United
States Environmental Protection Agency ("USEPA"), power plant owners, industrial plant
owners, technology suppliers, and others. I have published several papers and reports, including
papers in peer-reviewed journals and reports issued by the USEPA, on NOx control and control
of other pollutants. Several of these papers have been coauthored with staff of the USEPA. For
most of the period from 1988 to 1997, I was employed by companies that provided air pollution
control technology (Research Cottrell and Fuel Tech) or power plant and refinery gas analyzers
(Spectrum Diagnostix, a subsidiary of Physical Sciences that was acquired by Western
Research). Over this period,
as an
employee of these companies, I sold, designed, and
commissioned air pollution control technology at numerous power plants and industrial facilities.
I received my B.S. in Mechanical Engineering from the U.S. Naval Academy in 1979. I
received my M.S. (1986) and Ph.D. (1987) in Mechanical Engineering from the Massachusetts
Institute of Technology. In 2001, I was awarded the Chartered Financial Analyst designation
from the CFA Institute. From 1979 to 1984, I served as a commissioned officer in the U.S. Navy
in the Engineering Department of a nuclear-powered aircraft carrier.
IL SUMMARY OF TESTIMONY
The purpose of my testimony is to describe how NOx emissions from industrial facilities
impacted by the proposed NOx RACT rule can be controlled and what those controls are
expected to cost for affected facilities. By reference, my testimony includes the TECHNICAL
SUPPORT DOCUMENT ("TSD") for CONTROL OF NITROGEN OXIDE EMISSIONS from
Industrial Boilers and Electrical Generating Unit Boilers, Process Heaters, Cement Kilns, Lime
Kilns, Reheat, Annealing, and Galvanizing Furnaces used at Iron and, Steel Plants, Glass
Melting Furnaces, Aluminum Melting Furnaces (AQPSTR 07-02). I cooperated with the Illinois
EPA in the preparation of that document, which supports the proposed rule, as well
as
the
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RUG-29-2008 10:26
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preparation of the proposed rule itself. My cooperation includes contributions to the document
and proposed rule. My contribution to the TSD was to provide updated information on the
available technologies for control of emissions from these sources, their capabilities in terms of
reduction of NOx emissions, and the costs associated with employing these technologies.
NOx Emissions from Combustion Sources
Many industrial processes rely on high temperatures and combustion of fuels to produce
those temperatures. Oxides of nitrogen, called NOx, are produced during combustion of fuel
with air. NO and NO
2 , the components of NOx, are formed as a result of oxidation of nitrogen.
The nitrogen may be available in the fuel, is available from the nitrogen present in the
combustion air, or may be present in feed materials. NOx is formed at high temperatures when
there is excess oxygen available for the oxidation reactions, which are also typical conditions
during combustion or during some high temperature manufacturing processes. Depending upon
the source of nitrogen and the chemical pathway to form the NOx, NOx is generally called "Fuel
NOx," "Thermal NOx" or "Prompt NOx." For industrial processes that treat materials at high
temperatures, such as glass furnaces, there can also be NOx formed from oxidation of nitrogen in
feed materials, and this may be called "Feed NOx."
Because NOx emissions are undesirable, methods have been developed to minimize the
amount of NOx that is produced during combustion of the fuel. These methods are called
combustion controls, and combustion controls are often, but not always, the least expensive
approach to control NOx. However, because complete combustion of the fuel relies upon having
adequate temperature and availability of oxygen, good combustion is normally at odds with low
NOx emissions. Therefore, combustion controls can be limited in their ability to reduce NOx
while also maintaining good combustion performance. For this reason, post-combustion controls
have been developed. Post-combustion controls reduce the NOx emissions that remain after
combustion, most often by reacting a chemical reagent with the NOx to convert the NOx and
reagent into benign products — typically nitrogen and water. It is also possible to reduce NOx
emissions through Process Modifications. Process Modifications reduce NOx by changing the
process in a way to reduce combustion requirements. The TSD provides detailed descriptions of
the various technologies available for each source category as well as the performance and cost
of these technologies. What follows is a very general description of the technologies.
3
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Combustion Controls
Combustion controls reduce the amount of NOx that is formed, and they are available for
each source category that is affected by this proposed rule. Because combustion controls are
usually (but not always) less expensive than post-combustion controls, extensive research has
been performed to advance low NOx combustion controls for industrial facilities. Since
combustion controls are available for each source type affected by this proposed rule, for most
affected facilities combustion controls are expected to be adequate for meeting the requirements
of the proposed rule. Each type of industrial source has its own unique characteristics.
Nevertheless, all combustion controls rely on at least one, if not several, of the following
principles:
• Low excess air –
Reducing the available air to the burner will generally reduce the NOx
level by reducing available oxygen to react with the nitrogen and form NOx. However,
alone this approach is very limited because combustion will become poor
if
combustion
air is reduced too far.
• Staging of air –
Air staging achieves low NOx emissions by slowly admitting the air to
the flame and delaying the mixing of fuel and air such that most of the fuel is consumed
in an oxygen deficient environment where NOx does not form. Staging of air is
performed in nearly all low NOx burners that have turbulent, diffusion flames, which is
the most common sort of flame for the sources affected by this proposed rule. Air
staging is also performed with overfire air and tertiary air, where burnout air is admitted
downstream of the primary combustion zone in a boiler. Oscillating combustion,
described in the TSD, is also a form of air staging, with alternating fuel-rich and fuel-lean
zones.
• Staging offuel –
Fuel staging is when fuel is admitted in more than one zone, typically in
a primary zone and in a secondary, downstream zone. This allows for less intense
combustion in the primary zone and can also enable there to be an oxygen-deficient
secondary combustion zone where NOx from the primary combustion zone is reduced.
Technologies such as reburning use fuel staging. Some low NOx burners – particularly
for gaseous fuels - employ fuel staging. Mid-kiln firing for cement kilns is also a form of
fuel staging.
4
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•
Lean premixed combustion —
This is an option only for low nitrogen, volatile fuels, such
as
natural gas. Such burners are capable of extremely low NOx levels because they
address all forms of combustion NOx — Fuel NOx, Thermal NOx and Prompt NOx. Such
burners are most often employed in mechanical draft boilers and heaters.
• Flue gas recirculation —
Flue gas recirculation enables reduction of flame oxygen level
and reduction of peak flame temperature by recirculation of a portion of flue gas back to
the combustion zone. Many low NOx burners for gas-fired applications (both diffusion
flame and premixed flame burners) utilize this principle. External flue gas recirculation
relies on ductwork from the exhaust back to the burner, which is effective but increases
cost. Internal flue gas recirculation, available on some burners for heaters and furnaces,
permits use of flue gas recirculation without the need for additional ductwork.
•
Nitrogen depletion —
Reducing the available nitrogen for oxidation can be performed by
reducing nitrogen in the fuel (or feed materials) through fuel substitution with lower
nitrogen fuel (or feed materials) or by reducing nitrogen in the combustion air by using
oxygen enriched combustion. For high temperature manufacturing processes that can
produce NOx from oxidation of nitrogen in feed materials, NOx may be reduced through
substitution of low-nitrogen feed materials for high-nitrogen feed materials. Nitrogen in
the combustion air can also be reduced. Oxy-combustion is one method that uses this
approach by using oxygen rich-combustion air. Besides lower NOx emissions, another
benefit of oxy-combustion is that it can also improve efficiency and will reduce the
necessary gas flow-rate by reducing the largest component of combustion air and flue gas
— nitrogen.
The costs of combustion controls are typically under $2,500 per ton of NOx removed.
Therefore, for the majority of units affected by this proposed rule, combustion controls will
provide adequate reduction for compliance at a reasonable cost.
Post-Combustion Controls
Because combustion controls may not reduce NOx to adequately low levels, there are
post-combustion controls that reduce the NOx formed in the combustion process. The most
widely
used
post-combustion controls are Selective Catalytic Reduction ("SCR") and Selective
Non-Catalytic Reduction ("SNCR"). Both processes reduce NOx by reacting it with ammonia or
5
RUG-29-2008 10 27
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P.15
urea to form harmless nitrogen and water. Both processes may be used alone or in combination
with combustion controls for even higher reduction of NOx. There are other approaches
available that are less widely used.
• SCR —
SCR is a very well established technology that can provide very high reduction of
NOx — in the range of 90%. It has been widely used on utility boilers, turbines, diesel
engines as well as industrial facilities. SCR is usually more expensive to install than
other controls that provide less effective control of NOx because it is necessary to install
a catalyst reactor in the ductwork. SCR also entails an ongoing cost of ammonia or urea
and also periodic replacement of catalyst. Therefore, most facility owners will prefer to
install other controls that provide adequate NOx reduction to comply with the rule at a
lower cost. I do not expect SCR to be used to a great extent to comply with this rule,
except perhaps in an averaging approach with other, uncontrolled units, because SCR is
more expensive than other approaches. However, SCR can and has been installed to
provide NOx reductions at costs below $2,500/ton, and such costs are typical for facilities
that are not otherwise controlled to low NOx levels.
• SNCR —
SNCR is also a well established technology that can provide significant
reduction of NOx — the exact amount depending upon the application. SNCR has been
used on a wide range of industrial source types, including boilers, kilns, process heaters,
and furnaces. The only requirement is to have access to inject ammonia or urea reagent
into the gas at the proper temperature range. SNCR has the advantage of being less
expensive to install than SCR and frequently less expensive to install than combustion
controls. SNCR does entail an ongoing cost of ammonia or urea. Therefore, many
facility owners will prefer to install other controls that provide adequate NOx reduction
to comply with the rule at a lower cost. However, in general, SNCR is capable of
providing NOx reductions for a wide range of sources at costs — measured in $/ton of
NOx removed — well below the cost of SCR and sometimes less than the cost of
combustion controls. As a result, SNCR can be applied to many sources affected by the
proposed rule to provide NOx reductions at reasonable costs that are typically below
$2500/ton, and in some cases well below $2500/ton.
6
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Process Modifications
Process modifications reduce NOx by changing the process in a way to reduce
combustion requirements. These could be energy-efficiency measures, such
as
modifying a long
kiln to a preheater or precalciner kiln. Or, they could be other approaches, such
as
electric boost
that reduce the need for heat generation by combustion. Electric boost would not be used in
boilers or cement kilns, but could be used in some manufacturing processes to heat materials.
The costs of process modifications will be specific to the process and would typically be
employed if determined to be less expensive than other approaches that are available.
III. SUMMARY
This proposed NOx RACT rule affects several source categories. Fortunately, for each of
the source categories affected there are available controls that can be used to provide the NOx
reductions required by the rule at costs envisioned to be within the expectations for RACT. The
TSD that is included in my testimony by reference describes in detail each of the technologies
and expected costs for each source type.
7
AUG-29-2008 10:27
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P.17
STATE OF ILLINOIS
COUNTY OF SANGAMON
)?
SS
RECEIVED
CLERK'S
OFFICE
AUG 2 9 2008
P
STATE
ollution
OF
Control
ILLINOIS
Board
CERTIFICATE OF SERVICE
I, the undersigned, an attorney, state that I have served via approved facsimile the
attached TESTIMONY OF ROBERT ICALEEL, VIR GUPTA. AND JAMES E.
STAUDT, Ph.D., upon the following person:
John Therriault
Assistant Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph St., Suite 11-500
Chicago, IL 60601
and mailing it by first-class mail from Springfield, Illinois, with sufficient postage affixed
to the following persons:
SEE ATTACHED SERVICE LIST
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Gina
cy,
Roccaforte
Assistant Counsel
Division of Legal Counsel
Dated: August 29, 2008
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
AUG-29-2008 10:27?DLC LEGAL
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P.18
SERVICE LIST
08-19
Timothy J. Fox
Heating Officer
Illinois Pollution Control Board
100 W. Randolph St., Suite 11-500
Chicago, IL 60601
Virginia Yang
Deputy Legal Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, IL 62702-1271
Katherine D. Hodge
Monica T. Rios
Hodge Dwyer Zeman
3150 Roland Ave.
P.O. Box 5776
Springfield, IL 62705-5776
Matthew Dunn
Chief
Environmental Bureau North
Office of the Attorney General
69 W. Washington St., Suite 1800
Chicago, IL 60602
Kathleen C. Bassi
Sheldon A. Zabel
Stephen J. Bonebrake
Schiff Hardin LLP
6600 Sears Tower
233 S. Wacker Drive
Chicago, IL 60606-6473
Alec M. Davis
General Counsel
Illinois Environmental Regulatory Group
215 E. Adams St.
Springfield, IL 62701
TOTAL P.18
AUG-29-2008 10:23
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P.01
DATE.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
DIVISION OF LEGAL COUNSEL
1021
NORTH GRAND AVENUE EAST, POST OFFICE BOX
19276
SPRINGFIELD, ILLINOIS
62794-9276
TELEPHONE (217) 782-5544 FACSIMILE (217) 782-9807
RECEIVED
CLERK'S
OFFICE
11
2-1
og?
AUG 2 9
2008
FACSIMILE TRANSMITTAL SHEET
Pollution
STATE OF
Control
ILLINOIS
Board
PLEASE DELIVER THE FOLLOWING PAGES TO:
PARTY'S NAME:
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