THIS FILING IS SUBMITTEDON RECYCLED PAPER
STATE OF ILLINOIS
COUNTYOFSANGAMON
CERTIFICATE OF SERVICE
SERVICE LIST 08-19

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

NITROGEN OXIDES EMISSIONS FROM

VARIOUS SOURCE CATEGORIES:

AMENDMENTS TO

35 ILL. ADM. CODE

PARTS 211 AND 217

)

R08-19

(Rulemaking - Air)

NOTICE

TO:

John Therriault

Assistant Clerk

Illinois Pollution Control Board

James

Thompson Center

100 West Randolph St., Suite 11-500

Chicago, IL 6060 I

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 POST-HEARING COMMENTS OF THE ILLINOS

ENVIRONMENTAL PROTECTION AGENCY, a copy

of which is herewith served upon you.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:~~

Gina Roccaforte

Assistant Counsel

Division

of Legal Counsel

DATED: November 5,2008

1021 North Grand Avenue East

O. Box 19276

Springfield,IL 62794-9276

217/782-5544

THIS FILING IS SUBMITTED

ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

NITROGEN OXIDES EMISSIONS FROM

VARIOUS SOURCE CATEGORIES:

AMENDMENTS TO 35 ILL. ADM. CODE

PARTS

211 AND 217

)

R08-19

(Rulemaking - Air)

POST-HEARING COMMENTS OF THE ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA"), by its

attorneys, and respectfully submits its post-hearing comments in the above rulemaking

proceeding. Though the Illinois EPA responded

to most every issue raised at the first hearing in

this matter on the record during that proceeding, some outstanding issues remain to be addressed

in these post-hearing comments.

Responses to Questions Raised During the October 14,2008, Hearing

Question:

Answer:

Question:

Answer:

Directed to Mr. Kaleel, Question

from the Illinois Environmental Regulatory

Group, inquiring about other

states'NOx RAeT emission limits that the Agency

considered whileformulating the rulemaking proposal.

Please see Attachments I through 5 to these comments.

Directed to Mr. Kaleel, a follow-up question to Question

from the Illinois

Environmental Regulatory Group, inquiring about heat recovery steam

generators.

a heat recovery steam generator recovering heatfrom the exhaust

of,

A, process, B, turban [sic], or

engine~

considered a boilerfor proposed-

for this proposed rule, then does the Agency intend to define the boiler's rated

heat input capacity as a direct heat input to the heat recovery steam generator

from combustion

offuel in the heat recovery steam generator

for example, from

a duct burner

or does it intend to also include the heat inputfrom the upstream

process in the rated capacity? (Transcript, p.

65)

The Illinois EPA reviewed the USEPA'sregulations to control NOx emissions

from combined cycle turbines where the exhaust from a turbine is captured in the

heat recovery steam generator (see, 40 CFR 60, Subparts GG and KKKK). For

the simplicity

ofthe testing and monitoring of the NOx emissions, the Illinois

EPA decided to treat a combustion turbine and heat recovery steam generator as a

single unit. The supplemental heat input

of the duct burner/heat recovery steam

generator will be added to the heat input

ofthe turbine. The combined heat input

will be subject to the applicable NQx emission limit for turbines under Subpart Q

ofPart 217. Therefore, the NOx emissions will be tested/monitored after the

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

Question:

Answer:

Question:

Answer:

Question:

Answer:

exhaust from the heat recovery steam generator and shall comply with the NOx

emission limit for a turbine. However, the heat input

ofthe duct burner/heat

recovery steam generator shall not be added to the heat input

of the turbine to

increase the rated capacity

ofthe turbine. Accordingly, the Il1inois EPA proposes

a revised definition

of the term "industrial boiler" to exclude a heat recovery

steam generator that captures waste heat from the upstream gas turbine as follows:

"Industrial boiler" means, for purposes

ofPart 217, an enclosed vessel in which

water is heated and circulated either as hot water

or as steam for heating or for

power,

or both. This term does not include a heat recovery steam generator that

captures waste heat from a combustion turbine and boilers serving a generator that

has a nameplate capacity greater than

25 MWe and produces electricity for sale,

ana eegeneFatiell units, as tflat term is aeHnea ill Seetien 225.130 afPart 225, if

such boilers aF eegeneratian units are sHbjeet ta meet the applicability criteria

under Subpart M

of Part 217 the CAIR

~IOl(

TFaaing PFagrams unaer Sullflart D

afPart 225.

(Please note this revised definition includes the amendatory provisions in

response to Midwest Generation's Question 20 directed to Mr. Kaleel.)

Directed to Mr. Kaleel, a follow-up question to Question

from the Illinois

Environmental Regulatory Group, inquiring about heat recovery steam

generators.

the rated heat input capacity ofthe boiler is intended to include

energyfrom the exhaust

ofan upstream unit, then how does the Agency anticipate

resolving the NOx emissions

and controls from the unit andfrom the heat

recovery steam generator? (Transcript, p. 65)

See response, above.

Directed to Mr. Kaleel, a follow-up question to Question

from the Illinois

Environmental Regulatory Group, inquiring about heat recovery steam

generators. [I}n this situation where

you would have a heat recovery steam

generator, would that unit be regulated under this proposal? (Transcript, p. 66)

Would it perhaps be regulated under subpart

Would it be regulated here?

Would it be regulated both places? (Transcript, p. 67)

See response, above.

Directed to Mr. Kaleel, Question

from the Illinois Environmental Regulatory

Group, requesting Tables C-2

and D-1 ofthe Technical Support Document in

Microsoft Excel.

On October 16,2008, the Illinois EPA sent, via email, Tables C-2, D-I, E-I, F-I,

G-I, H-I, and I-I of the Technical Support Document in Microsoft Excel to the

Clerk

of the Il1inois Pollution Control Board. Persons interested in these tables in

Microsoft Excel format are directed to request them

by contacting the Clerk's

office, as indicated on the Board'sweb site.

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

Question:

Answer:

Question:

Answer:

Question:

Answer:

Question:

Answer:

Question:

•

Directed to Mr. Kaleel, from the Illinois Environmental Regulatory Group,

inquiring about modeling information

and what emission reductions were

included

in the model and

the reductions shown on the tables (Tables C-2 and

D-l) were included.

The attainment demonstration modeling accounted for NOx RACT reductions

through the use

of an emissions model. The emissions model approximates the

emission reductions

by identifying affected units through the use of Source

Classification Codes (SCC), and then multiplying the base emission rate

by a

control factor. This modeling process yields emission reductions that are

of the

appropriate magnitude for the nonattainment area, but may not reflect the

reductions shown in Table C-2

of the TSD for each emission unit. The details of

the modeled emission reductions are available on LADCO'swebsite:

www.ladco.org.

Directed to Mr. Kaleel, from the Illinois Environmental Regulatory Group,

requesting identification

ofother categories ofunits that do not exist in the

nonattainment areas. Specifically, could the Agency

identifY any other categories

or subcategories for which units do not currently exist in the non-attainment

areas? (Transcript, p. 114)

To confirm what was stated at hearing, cement kilns and aluminum furnaces are

the only two categories

of units that do not exist in the non-attainment areas.

Directed to Mr. Kaleel, from the Illinois Environmental Regulatory Group,

inquiring about whether the reductions in Table C-2

ofthe Technical Support

Document include units complying with the multi-pollutant standard

or combined

pollutant standards under Part 225.

The estimated NOx RACT reductions in Table C-2 of the Technical Support

Document are based upon a strict application

ofthe proposed RACT emissions

limitations for units in the non-attainment areas. Such reductions are not based

upon application

of the multi-pollutant standard or combined pollutant standards

under Part 225.

Directed to Mr. Kaleel, from the lllinois Environmental Regulatory Group,

requesting that all attachments to the Technical Support Document be made

available

for inspection at the Agency.

All attachments to the Technical Support Document are available for inspection at

the Illinois

EPA's Springfield office.

Directed to Dr. Staudt, Mr. Dennis, Archer Daniels Midland, questioned the

accuracy

ofthe response to Question

from Midwest Generation as it relates to

the boilers

in terms ofmmBtu heat input capacity, and the response has been

amended.

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

Answer:

Question:

Answer:

Question:

Answer:

So, 100-600 hp boilers are in the range

00,347,500 BtuIhr to about 20 million

Btu/hr. The specific reference you have identified is in the section on combustion

tuning (mostly

of interest for small boilers) and relates to the cost of oxygen trim

systems in the range

of $6000-$7000 for boilers of that size. And, as noted in the

TSD, for larger boilers the cost would be somewhat higher.

Of course, 100-600

hp boilers are well below the size

of boilers that are subject to emissions

limitations. However, small boilers may be subject to the combustion tuning

requirement, depending upon the emissions

of the boiler.

Directed to

Mr. Kaleel, from Midwest Generation, inquiring about the necessity

ofSection

217.141.

Section 217.141 was originally promulgated

by the Board in 1972 as Rule 207

and applied to both new and existing sources. (See, R71-23). The section has

been amended and was recodified

in 1983. The NOx limitations under Section

217.141 apply to any existing fuel combustion emission source with an actual

heat input equal to

or greater than 73.2 MW (250 mmbtulhr), located in the

Chicago or St. Louis (Illinois) major metropolitan areas. Currently, sources

meeting the heat input criteria and located in these areas are subject to these NOx

limitations. Accordingly, these limitations appear in sources' permits.

Directed to Mr. Kaleel, Question

from Midwest Generation, inquiring about

the placement

ofthe second sentence ofSection 217.152(b) to another Section.

The Illinois EPA is in agreement that it

may be more appropriate to place the

sentence in another section, e.g., in each respective subpart'semissions

limitations section.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:~~-

Gina Roccaforte

Assistant Counsel

Division

of Legal Counsel

DATED: November

5,2008

1021 North Grand Avenue East

O. Box 19276

Springfield, IL 62794-9276

2171782-5544

THIS FILING IS SUBMITTED

ON RECYCLED PAPER

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

NOx RACT Limits for Industrial Boilers in Illinois and Other States

TSD/NOx RAeT Regs-other states.x1s11Q.10-200a

The limits apply to boilers>100 mmbtu/hour (Vnless otherwise specified)

WIIr'"

State

\Vl~

(E1i!ling

OH"'''''''

HoustowGa.lv

South Coast

San Jonquin

II.

(Const. after

(St.Louis

N.J

unilll)

2/1/2001)

NOxRACT

NOllRACf

Anllinment

SCAQ1\-ID

Valley - PbllSe l

0, NAA)

(Ozone Senson)

",,"0

Etleclive

Adopted:

Amended

Filed

Effective:

Filed:

Jan

2001,

Jan 2001,

July 2007,

12/1212007.

4127/2005.

9/13/2003.

8/26/05.

5/1311996.

3123/1998, final

Effective:

Dec. 20, 1993

t/19/94.

Date of

Proposed

Amcnded

Rule Effective June

Effective

1111712000

Amended

Effective

Errata:

10-31-02

Operative:

Efective:

Regulations

18,2001

Feb.I,2001 Feb.t, 2001

Aug.2007

t2/2212007

5/t 9/2005

3117/2005

5/30/06

12112,2002

Jan. 23. 1994

2118/94

RuleIReg.

217 Subpal1

NR428.05

NR428.04 NR428.22(a) 3745-110-03

117.206c

1146

10CSRtO- 326tACtO-I-

129.91-129.95

Eov-A 1211.05

Chapter 27

4306

227-2-4

Number

5.510

(d)

t97:27-19.7

,,'lie!

Unit Type

NO" Limit (or ICI Boiie".lb/mmBtu

0.036

0.011

Sourc~

Speclfh::

0.10

0.20

GlIS Fired

0.08

0.10

O.O!

0.08

0.10

0.02

.,40

0.20

(Tangential)

mmbtulhr)

(>20 mmbtulhr

RACT

orl.ND

(Gas Only)

(Gas Onl).)

0.036

0.052

Source Spedfk

0.30

(I)

0.2S(W)

0.20 (1) 0.28{W)

0.25-0.30

Distillate Fuel

0.10

0.12

0.09

0.10

0.12

...{I.013

(>40

(>20 mmbtulhr

OJO

0.20

RACT

(Oil or O+G) or

(OilorO+G)

mmbtufhr)

LNB

vane!>

wfsize

Other Liquid

0,036

0.O!'i2

Sounc Specific

O.lO

(T)

O.2S(W)

0.20 (1) O.28(W}

0.25-0.30

Fuels (Rcsldunl

0.15

0.20

0.t5

0.15

0.2l

...{I.Ot4

(>40

O,lO

0.30

(Oil or

0+0)

(Oil or

O~G)

(OilorO+G)

Fudetc.)

mmbtulhr)

(>20 mmbtufbr

RACT

LNB

varies

w/size

Solid Fucl-Wall

0.15-0,17

0.057

0.036

Source Specific

0.50

fired 100-250

0.25

0.30

0.20

(J)epelld,oll

0.30

(>40

0.50

0.45

0."

IlRR)

(coke)

mmbl1llhr)

RACT

(Coal or Conl-l-Oil

Solid Fuel-Wall

0.10-0.17

0.057

0.036

Source Spedflc

fired >250

0.18

OJO

0.15

(Depend.! on

0.30

(>40

O~O

0."

0.45

mmbtulhr

HRR, Size)

(eok~)

mmbtulhr)

RACT

(Cool orCoal+Oil)

Solid Fuel

0.057

0.036

Source SpecJnc

Circulating

FBe

0.10

0.20

0.10

0.30

(coke)

(>40

mmbtullJr)

RACT

Solid Fuel

Ste Umlts ror

0.20_0.25

0.057

0.Ol6

Source Specific

0.l3

SpreJlder Stoker

Solid Fuel Wall-

None

0.20

{Oepends 011

0.30

.,40

0.50

0."

(Wood

0'0

fir~d

Sin)

(coke)

mmbtulhr)

RACT

Wood+Oil)

Solid Fuel

See L1mUs for

0.20-0.25

0.057

0.0:J6

Source Specific

0.3l

D.lO

Ov~rfeC'd

Stoker

SolId

B,of

Fuel Wall-

None

0.20

(Dependli

Siz~)

0.30

(coke)

mmbtuthr)

(>40

0.50

0.40

RACT

Wood-+Qil}

(Wood or

OverfeedStoker

Solid Fue'

Ste I.imi[1l (or

0.20-0,25

0.057

0.036

O.ll

Underfeed

Solid Fuel

Willi.

Non~

(Depends on

OJO

(>40

0.50

SOllrc~

Specific

(Wood

O.lO

Stoker

flred

Size)

(coke)

mmbtlllbr)

RACT

Wood+Oil)

Solid

Fu~l-

See Limits for

0.10-0.15

0.057

0.036

0.50 <250; 0.42

Solid Fuel Wall-

D.lO

0.20

{depell.lb on

0'0

(>40

0.4S

0.40

Source Speclflc

0.38

Tpngentilllfired

0.38

>250

fired

Size)

(cok~)

mmbtulhr)

RACT

(Coal or Conl+OiJ)

~bruIh,

ease rate. O=Oil. G -

Gas

Texas NOx limits for oil are translated into IbfmmBIll for comparison

• Applicable to Non.Atlainment counties. Existing units. Ozone season only. Boilers:; or >100 mmBtUlhr. 3O-<lay rolling average

"New units constructed after Feb. 1. 2001. Non-Attainment Counties. Applies an year. For fuel oil or gaseous fuel fired bollers limlt applies to = Of > 25 mmblulhr

•• Applies 10 NAAs Only

Attachment 1

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

NOx RACT Limits for Process Heaters in Illinois and Other States

TSD/NOx RAeT Regs-other states.xlsl1D-1D-20Q8

Houston! Galv

Snn Joaquin

State

(Propo~al)

SCAQMD

Valley-

Attainment

Phase3

Demo

Effective Date

1117/2003

Amended

Adopted:

11/1712000

9/13/2003

12/2011993

2/18/94

July 2007

Applicable Rule

217 Subpart

117.206

1146

4306

197:27-

19.7

227-2.4

NR 428.04(1)

Source Catel!orv

Fuell Unit Type

Draft TYlle

NOx Limit, Ib/mmbtu

Process Heaters >100

0.025

0.036

0.011

Soul"(:e Specific

Gas Fired

Na.uul Draft

0-07

(>20

0.20

0.10

mmBtu/hr

(>40 mmbtulhr)

(>40 mmhtulh...

mmbtuJhr)

RACT

Process Heaters >100

0.025

0.036

0.011

Source Specific

Gas Fired

Mech. Draft

0.07

(>20

0.20

0.10

mmBtulhr

(>40 mmblulhr) (>40 mmbtu/hr)

mmbtulhr)

RACT

Process Heaters >100

0.025

0.036

0.052

Source Spct:ific

0.18

Re!;ldual Fuel

Natural Draft

0.10

(>20

0.20

mmBtu/hr

(>40 mmbtulhr) (>40 mmbtulhr)

mmbtu/hr)

RACT

(>65 mmlltu/hr)

Process Hcaters >100

0.025

0.036

0.052

Source Specific

0.18

Rcsldual

Io'uel

Mech. Draft

0.15

(>20

0.20

mmBtu/hr

(>40 mmbtu/hr)

(>40 mmbtuJhr

mmbtu/hr)

RACT

(>65 mmBtu/hr)

Process Heaters >100

0.025

0.036

0,052

SourCe. Specific

Other Liquid Fuels

Natural Drart

0.05

(>20

0.20

0.12

mmBtu/hr

(>40 mmbtu/hr)

(>40 mmbtu/hr

mmbtu/hr)

RACT

Process Heaters >100

0.025

0.036

0.052

Source

Specific

Other Liquid Fuels

Mech. Draft

0.08

(>20

0.20

0.12

mmBtulbr

(>40 mmbtu/hr)

(>40 mmbluJhr)

mmbtulhr)

RACT

Attachment 2

Electronic Filing - Received, Clerk's Office, November 5, 2008

* * * * * PC #1 * * * * *

NOx

RAeT

Limits for Glass Melting Furnaces in Illinois aud Other States

TSD/NOx RACT Regs-other states.xls/1 0-1 0-2008

State

SJVUAPCIl

SCAQMIl

DAAQMIl

Effective Date

Proposed

July 2007

3/14/1995

1213112004

[/[12001

5131/[995

Proposed

5/1/2002

Reg. Number

217 Subpart F

428.22 (d)

4354

1117

Reg. 9,

Rule 12

220-174-22

7:27-19.10

10CSR 10-5.5[0