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 OF FILING
TO:
Mr. John T. Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 W. Randolph Street
Suite 11-500
Chicago, Illinois 60601
therriaj@ipcb.state.il.us
(VIA
ELECTRONIC FILING)
Timothy Fox, Esq.
Hearing Officer
Illinois Pollution Control Board
100 W. Randolph Street
Suite 11-500
Chicago, Illinois 6060
I
foxt@ipcb.state.il.us
(VIA
ELECTRONIC MAIL)
(SEE PERSONS ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board the
FIRST NOTICE PUBLIC COMMENT SUBMITTED
BY ARCELORMITTAL USA, INC. a copy of which is herewith served upon you.
Dated: July
1, 2009
Christina
L.
Archer
Associate General Counsel
ARCELORMITTAL
USA, INC.
1
South Dearborn, 19
th
Floor
Chicago, Illinois
60603
(312) 899-3865
Respectfully submitted,
By:
C:t'-~~L1_V
d
CtJ.e~
Christina L. Archer
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, July 1, 2009
* * * * * PC # 15 * * * * *
CERTlFlCATE OF SERVICE
I, Christina
L.
Archer, the undersigned, hereby certify that I have served the attached
FIRST NOTICE PUBLIC COMMENT SUBMITTED BY ARCELORMITTAL USA, INC.
upon:
Mr. Jolm T. Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 West Randolph Street, Suite
11-500
Chicago, Illinois 60601
therriaj@ipcb.state.il.us
Gina Roccaforte, Esq.
John Kim, Esq.
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand A
venile East
Post
Office Box 19276
Springfield, Illinois 62794-9276
Gina.Roccaforte@illinois.gov
John.Kim@illinois.gov
Kathleen
C.
Bassi, Esq.
Stephen J. Bonebrake, Esq.
Schiff Hardin, LLP
6600
Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
kbassi!aischiffhardin.com
sbonebrake@schiffhardin.com
Gerald T. Karr
Senior Assistant Attorney General
Environmental Bureau
Office of the Attorney General
69 West Washington Street, Suite
1800
Chicago, Illinois 60602
gkarr@atg.state.il.us
by electronic mail on July 1, 2009.
Timothy Fox, Esq.
Hearing
Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
foxt@ipcb.state.il.us
Katherine Hodge, Esq.
Monica Rios, Esq.
Hodge Dwyer
&
Driver
3150 Roland Avenue
POBox 5776
Springfield, Illinois 62705
khodge@hdzlaw.com
mrios!aihdzlaw.com
Virginia Yang. Esq.
Deputy Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, Illinois 62701-1271
Virginia.Yang@iIlinois.gov
Alec M. Davis, Esq.
General Counsel
Illinois Environmental Regulatory Group
215 East Adams Street
Springfield, Illinois
62701
adavis@ierg.org
Christina
L.
Archer
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)
)
)
)
FIRST NOTICE PUBLIC COMMENTS FOR THE ILLINOIS POLLUTION
CONTROL BOARD
SUBMITTED BY ARCELORMITTAL
USA,
INC.
Pursuant to 35
Ill.
Adm. Code 102.1 08 and 102.604, these First Notice Public Comments
for the Illinois Pollution Control Board (Board) are respectfully being submitted
by
ArcelorMittal USA Inc. on behalf of ArcelorMittal Riverdale Inc. (ArcelorMittal). On May 7,
2009, the Board published its Proposed Rule in this matter. On May 22,2009, the First Notice of
the Proposed Rule was published in the Illinois Register, triggering the forty-five (45) day
window for the filing
of public comments. ArcelorMittal previously submitted Pre-Filed
Comments for the Illinois Environmental Protection Agency (Illinois
EPA or Agency) on
November 25,
2008, and Post-Hearing Comments for the Illinois EPA on March 23,2009.
By way of background, ArcelorMittal's Riverdale, Illinois facility has a roller-hearth
tunnel furnace equipped with ultra-low
NOx burners (ULNBs), which processes thin cast steel
slabs. The permitted
NOx emission limit for the tunnel furnace is 0.171 Ib/mmBTU. In its
original filing in this matter on
May 9, 2008, the Agency proposed a NOx emission limit for
reheat furnaces (recuperative, combusting natural gas)
of 0.05 Ib/mmBTU and indicated to
ArcelorMittal in subsequent conversations that the Agency believed ArcelorMittal's tunnel
furnace was subject to this emission limit for reheat furnaces.
Since that time, ArcelorMittal has
participated in the hearings in this matter and has had many conversations with the Agency
regarding the applicable emission limit and/or whether the tunnel furnace is subject to the
Electronic Filing - Received, Clerk's Office, July 1, 2009
* * * * * PC # 15 * * * * *
rulemaking.
In response, in its Post-Hearing Comments and Second Motion to Amend
Rulemaking Proposal on March 23,
2009, the Agency revised its proposed NOx emission limit
for reheat furnaces
to 0.09
Ib/mmBTU.
However, the Agency failed to provide any further
technical or economical justification for the proposed emission limit and also failed to
demonstrate the revised emission limit was based on Reasonably Available Control Technology
(RACT).
In contrast, ArcelorMittal believes it has successfully demonstrated in its previous
comments that the initial NOx emission limit proposed by the Agency was arbitrary,
technologically infeasible and economically unreasonable.
Our comments now respectfully
request the Board reconsider the proposed revised arbitrary emission limit
(0.09
Ib/mmBTU)
requested by the Agency based on economic reasonableness, technical feasibility and product
quality issues.
1.
In support thereof, ArcelorMittal must address a few preliminary issues raised by
the Board in its May 7,
2009 Notice of Proposed Rule. Throughout the Notice of Proposed Rule,
the Board states that the Agency and ArcelorMittal have reached concurrence on the revised
emission limit for reheat furnaces located
at proposed section 35 III. Adm. Code 217.244(a)(2).
See R08-J9, Proposed Rule. First Notice, May
7,
2009, pp.
6, 14,
20.
Unfortunately, that is not
the case. Despite numerous conversations with the Agency regarding the applicability
of this
rulemaking and/or the appropriate emission limit, ArcelorMittal and the Agency have been
unable
to reach concurrence. Indeed, the next-to-Iast substantive communication between
ArcelorMittal and the Agency was on March 17,
2009, wherein the Agency informed us via
voicemail that due to time constraints they could only revise the applicable emission limit
to 0.09
Ib/mmBTU,
but could not provide any justification for such. Then subsequently in its March 23,
2009 Post-Hearing Comments and Second Motion to Amend, the Agency revised its proposed
NOx emission limit for reheat furnaces to 0.09
Ib/mmBTU.!
Specifically, the Agency stated in
its Post-Hearing Comments that it was revising the NOx limit for reheat furnaces based on a
survey
of NOx emission limits for similar furnaces constructed in other states in recent years,
which we are assuming was supposed
to demonstrate technical feasibility. In preparation for
these First Notice Comments, we requested a copy of the summary prepared by the Agency,
which
is attached as Exhibit A.
2.
We have now reviewed the summary of NO x emission limits for similar furnaces
constructed in other states.
One of the sources listed by the Agency is Beta Steel in Porter
County, Indiana. The Agency provides a NOx emission limit for Beta Steel's natural gas fired
reheat furnace slab 2 as 0.0147
Ib/mmBTU.
Upon subsequent investigation, we were able to
determine that the 0.0147
Ib/mmBTU
limit cited by the Agency was the original permit limit
based on manufacturer's estimates, which the source subsequently could not consistently meet.
Beta Steel's current emission limit for its reheat furnace
is 0.77
Ib/mmBTU
(more than 5 times
greater than the emission limit cited by the Agency) based on a permit issued by the Indiana
Department
of Environmental Management (IDEM) on August 12, 2004. The applicable pages
from Beta Steel's
Part 70 Permit are attached as Exhibit
B.
The Nucor Steel facility in Tuscaloosa, Alabama and V &M Star facility in Mahoning
County,
Ohio are also not similar to the Riverdale facility. Nucor has an equalizing furnace and
1
ArcelorMittal recognizes that it did not file a response to the Agency's Second Motion to Amend pnrsuant to 35
Ill. Adm. Code I 01.500( d) and the Board appears, at least in part, to rely
on the fact that no party filed a response to
the motion as evidence that all parties were in agreement with the proposal. However, as noted in Section
10 1.500( d), a waiver of objection does not subsequently bind the Board in its disposition of the motion.
In
addition,
ArcelorMittal was confident that the Board would have recognized onr arguments regarding economic
reasonableness and technical feasibility contained in onr Post-Hearing Comments notwithstanding the
Agency's
position. Finally, as will be addressed herein supta, the Agency relied on a survey of NO x emission limits from
other states to support lowering the emission limit for reheat furnaces, but no documentation was provided.
ArcelorMittal required additional time to review and provide comments on the subsequently-obtained
documentation
of NO x
limits and did not wish to waste the Board's resources requesting an extension
of time
to
respond to the Agency's motion, especially in light of the fact the Agency had already requested the Board expedite
the rulemaking. Unfortunately, ArcelorMittal is now left trying to defend its position dnring First Notice period.
V &M Star has a billet furnace, both which operate much differently that the tunnel furnace at
Riverdale. In addition, the Nucor facility produces slabs with a thickness of over 5 inches;
whereas,
as explained in our November 25, 2008 Pre-Filed Comments, the Riverdale facility
produces thin slabs with a thickness
of only 2 inches. Two of the facilities, New Steel
International, Haverhill,
Ohio and Minnesota Steel Industries LLC, Itasca County, Minnesota,
have not been constructed
to date. Finally, the Severstal Columbus, Mississippi facility is
similar to the Riverdale facility, except the Severstal facility has two tunnel furnaces (which, as
will be explained further herein in paragraph 4, can have an affect on the applicable emission
limit), but has not yet been issued a final Title
V permit. Therefore, achievement of the
emissions limits for these facilities have not been demonstrated. The Agency's reliance on
outdated, erroneous or never-applied-in-practice emission limits for 'similar sources" certainly
calls into question the Agency's arbitrary determination that
0.09
Ib/mmBTU
is technically
feasible and the appropriate RACT-based limit for reheat furnaces.
3.
As set forth in our Post-Hearing Comments and as will be briefly reiterated
herein, ArcelorMittal believes it has established that the initial emission limit for reheat furnaces
was not economically reasonable and the Agency's proposed revised emission limit does not
change the analysis. The Illinois
EPA's range of cost effectiveness of$2,500 - $3,000 per ton of
emissions reduced.
See R08-19, Transcript from October
14,
2008 hearing, pp.
165-166, 173-
174; Transcript from February
3,
2009 hearing, p.
75. In addition, the Technical Support
Document (TSD) for this rulemaking states that
"$5000IMMBtuIhr is towards the high end of
the capital cost of combustion controls, for the levels of NO x reduction envisioned in most cases,
costs in
$Iton
of NO x are typically under
$lOOOlton." TSD, Section
6.4,
p.
99. In the preamble
to the 8-hour Ozone implementation rule U.S. EPA states that a cost of$160 to $1,300 (in 1994
dollars) per ton
of NO x removed is considered reasonable for purposes of RACT (70 Fed. Reg.
71652, November 29,2005). Furthermore, U.S EPA states that in the 1998 NOx SIP Call Rule
they reviewed all major
NOx source categories, and the NOx SIP Call controls cost less than
$2,000 per ton (Id. at 71654). In light of these control cost determinations, ArcelorMittal
prepared an economic analysis for the Agency
to review, which provided the estimated cost
effectiveness for burner change based on the
"next-generation" ULNBs currently available. The
analysis was previously submitted to the Board in our Post-Hearing Comments. The cost
effectiveness ranged from $22,895 - $39,472 per ton
of NOx removed, well in excess of the
Agency's established range of $2,500 - $3,000 per ton of emission reduction, U.S. EPA's
determination
of less than $2,000 per ton and the TSD's reference of $1,000 per ton.
Furthermore, the emission guarantees for the burner changes submitted with our Post-Hearing
Comments were
0.068
Ib/mmBTU
and 0.054 Ib/rnmBTU. While the Agency's proposed revised
emission limit is
0.09
Ib/mmBTU,
this does not change the analysis that ArcelorMittal would
have to install one
of the two next-generation burners to meet the proposed revised limit, to
which the cost effectiveness argument is stilI applicable. These cost estimates also assumed that
rigid customer product quality specifications could be met and, conservatively, did not include
yield cost impacts and the associated cost
of production downtime to convert the furnace, both
which would be substantial. ArcelorMittal continues
to believe that an expenditure of over
$22,000 per ton of NOx controlled is economically unreasonable for a point source that
contributes a meager
0.016% of the total Chicago area NOx inventory on a daily basis of 812
tons
NOx/day
for 2006.
4.
The effect of changing burners on the operation of the tunnel furnace is also of
great concern. Steel tunnel furnace burner designs are very particular to the furnace structure
and slab type, so altering the burners or heat system can have significant effect on the slab
quality. Burners, gas orifice plates and potentially primary air cycle valves would need to be
replaced. Additionally, air and gas piping modifications would need to be made at all of the
burner connections and modifications would need to be made to shell plate and insulation to
accommodate new block sizes and shapes.
Due to the continuous nature
of the steel-making process and the lack of redundancy in
the operation, the tunnel furnace must operate optimally at all times. Unlike other facilities that
operate tunnel furnaces, the Riverdale facility does not have a second tunnel furnace or shuttle
furnace that can
be used to divert product between furnaces; nor does the Riverdale facility have
any downstream finishing operations (such
as pickling) to remove scale.
ArcelorMittal's Riverdale facility produces both high and low carbon grades and carbon
alloy grade steel. Many
of these grades (including high carbon grades with up to 0.95% carbon;
carbon alloy grades with specific additions
of chromium, nickel, molybdenum, and vanadium;
and carbon grade steels with boron additions) are not typically produced at other facilities.
ArcelorMittal has invested a great deal
of time and effort in order to produce a unique product
mix that is either breakout sensitive or ultra-light gauge. These two niches differentiate our
facility from other steel-making facilities throughout the country.
5.
In summary, these First Notice Comments are intended as a supplement to the
information previously provided in our Pre-Filed Comments dated November
25,2008, our Post-
Hearing Comments dated March 23, 2009 as well as follow-up to the several rounds of hearings
in this matter and informal discussions with the Agency. ArcelorMittal asserts that operationally
and functionally, it is inappropriate to compare the Riverdale tunnel furnace to other reheat
furnaces and/or attempt to utilize inappropriate, outdated or never-applied-in-practice emission
limits for those reheat furnaces to extrapolate the emission limit for ArcelorMittal's tunnel
furnace. ArcelorMittal remains committed
to working with the Board throughout this
rulemaking proceeding; however, we request that the Board revisit its Proposed Rule and for
Second Notice allow a source to be exempt from the proposed NOx emission limits upon an
adequate demonstration that additional
NOx controls would be economically unreasonable.
ArcelorMittal believes it has met this burden and requests the utilization
of the emission limit
currently applicable and permitted for the tunnel furnace at ArcelorMittal' s Riverdale, lllinois
facility
Dated: July
1,
2009
Christina
L.
Archer
Associate General Counsel
ARCELORMITTAL
USA, INC.
1 South Dearborn,
19
th
Floor
Chicago, lllinois
60603
(312) 899-3865
Respectfully submitted,
ARCELORMITTAL USA, INC.
Christina
L.
Archer
Electronic Filing - Received, Clerk's Office, July 1, 2009
* * * * * PC # 15 * * * * *
Exhibit A - R08-19 First Notice Comment of
ArcelorMittal USA, Inc.
Table: Summary of NOx Emissions from Reheat Furnaces
Note: Some data was taken directly from state contact
RBLC, Companv Name,
Furnace 10 and Size
Permit Issuance
Permit Limits: Ib/mjllion
Location, Permit #
Date
Btu or Ib/hr or gas usage
rate
or
Hours/Vr
RBLC 10# AL.0218
EQF-01
RBlC: Permit Date: June 6,
NOx-O.075Ib/mmBtu (NOx=30
2006
Ib/hr NOx)
Nucer Steel Tuscaloosa, Inc.
Equalizing Furnace
Permit Issuance Date:
8760 hrs/yr
Tuscaloosa, Al35404
400 mmBtu/hr
Aug. 13, 2008 ,
(replaces original)
N Gas-Fired
Permit # 413-0033
Originallv Installed: 1996
Burners Replaced:
2008.
ULNB (new Burners)
RBle 10#:
OH-0315
2 Tunnel Furnaces
Permit IssuanCe Date:
NOx -O.07Ib/mmBtu ,
P029-411, P030-#2
May 6, 2008
NOx=13.09Ib/hr each,
New Steel International.
187 mmBtu/hr
N Gas-Fired Furnaces and
57.33
tpv 12 month rolling
Haverhill, QH 45005
Heaters
average.
Permit
#:
07--00587
N G. Fired tunnel furnaces
8760hrs/yr
RBlC
10#:
OR-I, 124 mmBtu/hr
an. 15, 2009,
NOx-0.09Ib/mmBtu,
Gallatin Steel, Ghent, KY
Construction started in
N Gas-fired
7.26Ib/hr NOx
~pril1993,
8760 hrs/vr
Permit
#:
V03--031~R2
Data from state contact
N Gas use limitation:
tate Contact: Hossein
ULNB
1086
mmscf/vr
Rukhshan
RBLC 10#
Tunnel Furnace (I),
200s/August 2007
NOx _ 0.10 Ib/mmBtu
160 mmBtu/hr
Severstal Columbus, Columbus, Data from state contact
MS
State Contact:
Bonnie Morgan
Tunnel
Furnace (2),
601-961-5784
130 mmbtu/hr
Formerly. SeverCorr
338 tons/hour steel
RBLC 10#: IN-0040,
Reheat Furnace Slab 2 ,
Date Entered: 10/20/1992 NOx: 0.0147Ib/mmBtu,
Beta Steel, Porter County, IN
264.6 mmBtu/hr
NOx; 14.7 Ib/mmscf,
46368
3.13
Ib/hr (13.7 tpy)
Permit
#;
CP 127-2326
lNB+sCR
Date Modified:
NGas-fired
10/28/2002
RBLC 10#: OH-0316,
Billet Reheat Furnace, Th'put:
9/23/2008
NOx = 0.07Ib/mm Btu
V & M
Star (Mahoning County), 0.18 mmscf/hr
NOx: 12.6 Ib/hr
OH 44510
Permit #; POlO3660
ULNa
NOx
= 30.4
tons/vr
(12 months Rolling)
RBlC JD#:MN-007Q Minnesota
Tunnel Furnace,
9/7/2007
NOx: 0.03
lb/mmbtu,
Steel Industries, LlC, Itasca
(165
mmbtu/hour)
(4.9Ib NOx/hr)
County, MN 55769
205 tons steel/hr
0.0240 LBIT
(Essar SteeILtd.)
Perrnit# 06100067-001
Applicability
Rule 335-3-24-.04(9)
PSO/BAIT
OAC 374s-31-0s(A)(3)
PsD/BAIT
401 KAR 51:017
PsO/BAIT
BAIT/PsO
PSO/8ACT
PsO/BAIT
Exhibit B - R08-19 First Notice Comment of
ArcelorMittal
USA,
Ille.
Mitchell E. Daniels, Jr.
Governor
Thomas W Easterly
Commissioner
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT
We make Indiana a cleaner. healthier place to live.
100 North Senate A venue
Indianapolis, Indiana 46204-2251
(317) 232-8603
(800) 451-6027
www.IN.gov/idem
PART 70 OPERATING PERMIT
OFFICE OF AIR
QUALITY
Beta Steel Corporation
6500 South Boundary Road
Portage, Indiana 46368
(herein known as the Permittee) is hereby authorized to operate subject to the conditions contained
herein, the source described
in Section A (Source Summary) of this permit.
The Permittee must comply with
all conditions of this permit. Noncompliance with any provisions of this
permit
is grounds for enforcement action; permit termination, revocation and reissuance, or modification;
or denial of a permit renewal application. Noncompliance with any provision of this permit, except any
provision specifically designated as not federally enforceable, constitutes a violation
of the Clean Air Act.
It shall not be a defense for the Permittee
in an enforcement action that it would have been necessary to
halt
or reduce the permitted activity in order to maintain compliance with the conditions of this permit. An
emergency does constitute an affirmative defense in an enforcement action provided the Permittee
complies with the applicable requirements set forth
in Section B, Emergency Provisions.
This permit is issued
in accordance with 326 lAC 2 and 40 CFR Part 70 Appendix A and contains the
conditions and provisions specified
in 326 lAC 2-7 as required by 42 U.S.C. 7401, et. seq. (Clean Air Act
as amended
by the 1990 Clean Air Act Amendments), 40 CFR Part
70.6,
IC 13-15 and IC 13-17.
Operation Permit No.:
T127-9691-00036
Issued by:
Issuance Date: August 12, 2004
Janet G. McCabe, Assistant Commissioner
Office of Air Quality
Expiration Date: August 12,2009
1" Administrative Amendment No.: T127-24021-00036
Issued by:
Issuance Date:
January
30, 2007
Original document
signed by
Nisha Sizemore, Branch Chief
Expiration Date: August 12,
2009
Office
of Air Quality
Recycled Paper
®
An
Equal Opportuniiy Employer
Please Recycle
0
Beta Steel Corp.
Portage,
Indiana
Pennit Reviewer: Gail McGarrity
SECTION 0.2
1
st
Administrative Amendment: 127-24021-00036
Amended by Pam K. Way
FACILITY OPERATION CONDITIONS
Facility Description [326 lAC 2-7-5(15)]:
Page 41 of 58
T 127.9691.00036
Hot Strip Mill Operations with a maximum capacity of 1.16 MM ton per year steel production, comprised
of the following:
(a)
One (1) 264.6 MMBtu/hour natural gas fired Reheat Furnace identified as unit 10, constructed
in 1992, equipped with low NOx burners and a Selective Catalytic Reduction (SCR) Unit
(CE-l), exhausting to Reheat Furnace Stack (S-1).
(b)
One (1) 60-inch Hot Strip Mill consisting of unit 11 (Hot Rolling Mill), unit 12 (Strip Cooling
Line) and unit
13 (Coiler), constructed in 1991, having a maximum capacity of 170 tons per
hour.
(The information describing the process contained
in this facility description box is descriptive
information and does not constitute enforceable conditions.)
Emission Limitations and Standards [326 lAC 2-7-5(1)]
0.2.1 Particulate Matter (PM/PM 1 0) - Best Available Control Technology [326 lAC 2-2-3]
(a)
Pursuant to CP 127-2326-0003, issued February 24,1992, (as amended in A127-9642-
00036, issued May 30, 2003) and 326 lAC 2-2-3 (PSO - Control Technology Review;
Requirements), the
PM/PM10 (where PM10 includes filterable and condensible
components) emissions from
the Slab Reheat Furnace shall not exceed 16.3 pounds per
MMscf of natural gas burned and 4.2 pounds per hour (18.5 tons per year).
(b)
Pursuant to CP 127-2326-00036 issued February 24,1992, (as amended in A127-9642-
00036, May 30, 2003 ) and 326 lAC 2-2-3 (PSO • Control Technology Review;
Requirements) the
PM and PM-10 from the hot strip mill shall be limited by using
recirculated high pressure water descalers and water cooling sprays. Any particulate
matter,
In solid or liquid form shaH be collected in flumes and transported to the scale pit.
0.2.2 Nitrogen
Oxides (NOx) Best Available Control Technology [326 lAC 2-2-3]
(a)
Pursuant to A 127-9642-00036, issued May 30, 2003 (an amendment to CP 127-
2326-00036, issued February 24, 1992) and 326 IAC2-2-3(2), Best Available Conirol
Technology (BACT), only natural gas shall be burned in the slab reheat furnace and the
(b)
Pursuantto A 127-9642-00036, issued May 30, 2003 (an amendment of CP 127-2326-
00036 issued February 24, 1992) and 326 lAC 2-2-3 (PSO - Control Technology Review;
Requirements) the
NOx emissions from Slab Reheat Furnace shall be controlled by NOx
control technology consisting of low NOx burners and a Selective Catalytic Reduction
(SCR) Unit (CE-l).
(c)
NOx emissions shall not exceed 77.06 Ibs/MMscf (0.077 Ib/ MMBtu) of natural gas burned
and 18.88 pounds
per hour on a three (3) operating hour average basis except during
periods
of startup and shutdown.(82.69 tons/year)
(d)
The following shall apply during periods of startup and shutdown:
(1)
Startup is defined as the duration from the first firing of burners in the Reheat
Furnace to the time when the exhaust gas temperature is within the optimum
ranges
of the operation of the control device for NOx emissions.
Electronic Filing - Received, Clerk's Office, July 1, 2009
* * * * * PC # 15 * * * * *
Beta Steel Corp.
Portage, Indiana
1
st
Administrative Amendment: 127.24021.00036
Amended by Pam K. Way
Page
42
of
58
T
127.9691-00036
Permit Reviewer: Gail McGarrity
(2)
Shutdown is defined as the duration from first curtailment of fuel input to the
Reheat Furnace burners with the intent of full shutdown to the final complete stop
of fuel input and complete cessation of combustion in the Reheat Furnace.
(3)
The Reheat Furnace shall be operated
in a manner consistent with good air
pollution control and work practices to minimize emissions during startup and
shutdown
by operating in accordance with written procedures developed and
maintained by the Permittee, which shall include at a minimum the following
measures:
(A)
Review of operating parameters ofthe unit during startup, or shutdown as
necessary to make adjustments to reduce or eliminate excess emissions;
(B)
Operate emission control equipment as soon as the Reheat Furnace
exhaust gas temperature reaches the lower value
of the optimum
temperature range for the control equipment. This operation shall
continue
until the time the Reheat Furnace shutdown sequence is
initiated with the intention of shutdown of the unit; and
(C)
Implementation of inspection and repair procedures for the Reheat
Furnace and the emissions control equipment prior to attempting startup
to ensure proper operation.
0.2.3 Carbon Monoxide (CO) Best Available Control Technology [326 lAC 2-2-3J
Pursuant to A 127-9642-00036 (an amendment of CP 127-2326-00036 issued February 24, 1992)
and 326
lAC 2-2-3 (PSO - Control Technology Review; Requirements), the CO emissions from
the Reheat FurnaCe shall not exceed 40 Ib/MMscf of natural gas burned and 8.5 pounds per hour
(37.2 tons/year).
0.2.4 Volatile Organic Compounds (VOC) Best Available Control Technology [326 lAC 2-2-3J
Pursuant to CP 127-2326-00036 issued February 24,1992 (as amended in A127-9642-00036)
and 326 lAC 2-2-3 (PSO - Control Technology Review; Requirements), the VOC emissions from
the Reheat Furnace shall not exceed 1.7 Ib/MMscf of natural gas burned and 0.4 pounds per hour
(1.6 tons/year).
0.2.5 Preventive Maintenance Plan [326 lAC 2-7-5(13)J
A
Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of
this pennit, is required for the Reheat Furnace (unit 10) and the SCR unit (CE-1).
Compliance
Determination Requirements
0.2.6 Testing Requirements [326 lAC 2-7-6(1), (6)J [326 lAC 2-1.1-11J
(a)
Within a period of one (1) year from the date of the latest valid compliance demonstration,
the Permittee shall perform PM/PM 1 0 testing on the Reheat Furnace Stack (S-1), utilizing
methods as approved by the Commissioner, in accordance with Section C - Performance
Testing. PM10 includes filterable and condensible PM10. This test shall be repeated
annually from the date
of this valid compliance demonstration. In addition to these
requirements, 10EM may require compliance testing when necessary to determine if the
facility is
in compliance.
