BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
NITROGEN OXIDES EMISSIONS FROM)
V ARIOUS 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
(VIA ELECTRONIC MAIL)
Timothy Fox, Esq.
Hearing Officer
Illinois
Pollution Control Board
100 W. Randolph Street
Suite
11-500
Chicago, Illinois 60601
(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 COMMENTS OF UNITED
STATES STEEL CORPORATION, a copy of which is herewith served upon you.
Dated: July
6,2009
Katherine D. Hodge
Monica
T. Rios
HODGE DWYER
&
DRIVER
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217)
523-4900
Respectfully submitted,
UNITED STATES STEEL
CORPORATION,
By: IslKatherine D. Hodge
Katherine
D. Hodge
USSC:OO
I/FiIlR08-19/NOF-COS
-
us Steel First Notice Comments
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 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)
FIRST NOTICE COMMENTS OF
UNITED STATES STEEL CORPORATION
NOW COMES the UNITED STATES STEEL CORPORATION ("U.S. Steel"),
by and through its attorneys, HODGE DWYER
&
DRIVER, and submits the following
FIRST NOTICE COMMENTS OF UNITED STATES STEEL CORPORATION for
consideration in the above-referenced matter.
L
INTRODUCTION
Over the last several months, U.S. Steel has been actively participating in the
above-referenced rulemaking, which seeks
to establish NOx RACT requirements for a
variety
of affected sources, including U.S. Steel's Granite City Works ("GCW") facility
in Granite City, Illinois.
On November 25,2008, U.S. Steel submitted pre-filed
testimony
by Larry Siebenberger, Manager of Environmental Control at GCW. U.S.
Steel
also submitted pre-filed testimony by Blake Stapper, ofURS Corporation, on behalf
ofGCW.
Mr. Siebenberger stated that this proposed rulemaking would impact boilers, slab
reheat furnaces and galvanizing lines at GCW.
Prefiled Testimony of LaiTY G.
Siebenberger,
In the Matter of Nitrogen Oxides Emissions From Various Categories:
Amendments to
35
Ill. Adm. Code Parts
211
and
217, R08-19 at 5 (Ill.Pol.Control.Bd.
Nov. 25,
2008) (hereafter "Siebenberger Testimony"). Mr. Siebenberger set forth the
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
primary concems regarding the effect of the proposed mles upon GCW's slab reheat
fumaces and Boilers
11
and 12.
!d.
at 5-7. Mr. Siebenberger explained that Boilers 11
and 12, as well as the slab reheat fumaces, have a unique fuel mix.
Id.
at 6-7. Mr.
Stapper described how the unique fuel mix for these units impacts NOx emissions and
how those considerations, along with the operational and stmctural characteristics of the
units, affect potential control mechanisms. Prefiled Testimony
of Blake E. Stapper,
In
the Matter of Nitrogen Oxides Emissions From Various Categories: Amendments to 35
Ill. Adm. Code
Parts
211
and
217, R08-19 at 2-8 (Ill.PoI.ControI.Bd. Nov. 25, 2008).
Mr. Siebenberger's Pre-Filed Testimony set forth suggested alternative emission limits
that would be acceptable to GCW. Siebenberger Testimony at Exhibits A and
B.
Both Mr. Siebenberger and Mr. Stapper participated in the hearings on
December
10, 2008, in this proceeding. At that time, both witnesses answered questions
regarding their testimony.
On January 30, 2009, U.S. Steel provided additional materials
in response to requests at hearing for additional information concerning fuels,
NOx
emissions and potential NOx controls. On Febmary 2,2009, U.S. Steel submitted pre-
filed testimony for Mr. Stapper, for the Febmary
3,2009 hearing. Both Mr. Siebenberger
and Mr. Stapper participated
in the Febmary 3,2009 hearing. On March 23,2009, U.S.
Steel filed Post-Hearing Comments raising an issue related to unplanned outages or
upsets
of the desulfurization unit (see further discussion below). Post-Hearing Comments
of U.S. Steel,
In the Matter of Nitrogen Oxides Emissions From Various Categories:
Amendments to
35
Ill. Adm. Code
Parts
211
and
217, R08-19 (Ill.Pol.ControI.Bd.
Mar.
23,2009).
2
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
u.s. Steel worked closely with the Illinois Environmental Protection Agency
("Agency") to resolve issues related to the unique circumstances at GCW. After a series
of discussions, U.S. Steel and the Agency reached agreement on how to detennine the
NOx emission limits for Boilers 11 and 12, as well as slab fumaces 1 through 4, and
accordingly, U.S. Steel supported the Agency's proposed amendments to the rule as
described in the Agency's
Second Motion to Amend Rulemaking Proposal and Post-
Hearing Comments filed with the Board on March 23, 2009. However, as raised in its
Post-Hearing Comments, U.S. Steel wishes to provide clarification on the use of
desulfurized coke oven gas ("COG") and reiterate the need for revision to the proposed
emission averaging provisions to cover time periods when the desulfurization unit
is
shutdown due to unplanned outages or upsets. In addition, U.S. Steel requests revisions
to proposed
Section 217.157 in order to be consistent with its construction pennit for its
cogeneration boiler
II.
DESULFURIZA TION UNIT
As set forth in the Agency's amended proposal at new subsection 217.158(i),
calculations for determining
NOx limits during the averaging period will not include
those periods when the COG desulfurization unit is shut down for maintenance so long as
certain conditions are met, including advance notice of the shutdown and the shutdown
does not exceed
35 days per ozone season or calendar year, consistent with Condition
2(a)(i)
of existing Construction Permit No. 06070022. This provision will work very
well for "planned" maintenance. However, it does not address brief unplanned outages
and upsets of the COG desulfurization unit. Thus, U.S. Steel requests, as it did so in its
Post-Hearing Comments, that the Board include a revision
to the averaging provision to
3
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
accommodate such brief outages and upsets, as well as startups and shutdowns, of the
COG desulfurization unit. Such periods of time should be excluded from the averaging
calculations since, like planned maintenance shutdowns, the
COG desulfurization unit
will not be operating.
Additionally, as raised in the
Post-Hearing Comments, since construction on the
COG desulfurization unit at GCW has not been completed, the proposed emission
limitations are based on desulfurized COG having an estimated concentration of
hydrogen cyanide or HCN
of 130 ppm or less. The limitations associated with the use of
desulfurized COG will have to be revisited once construction of the COG desulfurization
unit is complete, if the actual concentration ofHCN is greater than 130 ppm. U.S. Steel
understands that a rule change may be involved at that time.
III.
EMISSIONS MONITORING
Proposed Section 217.l57(a)(1), as published in the Illinois Register, requires that
owners or operators of industrial boilers that are greater than 250 mmBtu/hr install and
operate a continuous emissions monitoring system ("CEMS") to measure NOx emissions
in accordance with 40 C.F.R. Part 75. Proposed 35 Ill. Admin. Code § 217.157(a)(l).
U.S. Steel is constructing a blast furnace gas cogeneration boiler with a heat input
capacity
of 505 mmBtu/hr.
See
Condition 3.1.2, Construction Pernlit No. 06070023,
attached hereto as Attachment A. Thus, U.S. Steel's cogeneration boiler will be subject
to the
CEMS requirement in proposed Section 217.157(a)(1) should the rule be adopted
as proposed. However, the proposed rule conflicts with the construction permit issued by
the Agency to
U.S. Steel for the cogeneration boiler.
See
Attachment
A.
Condition
3.1.8-1(a) provides as follows:
4
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
The Pennittee shall install, calibrate, operate, and maintain NOx and CO
continuous monitoring system(s) on the affected unit within one year after
the initial emission testing required by this pennit unless this testing or
further testing conducted by the
Permitee demonstrates that the unit
nonnally complies
by a margin of at least 5 percent with the NOx and CO
emission limit in this permit or the Illinois EPA approves further time for
the
Permittee to achieve this level of perfonnance.
Condition 3.1.8-1(a), Attachment
A. Accordingly, proposed Section 217. 157(a) should
be revised to include language exempting
U.S. Steel's cogeneration boiler from the
requirements in Section 217.157(a) so long as U.S. Steel complies with the tenns of the
construction pemlit issued for such boiler.
U.S. Steel respectfully requests that the Board consider revising the proposed rule
by adding the following paragraph to proposed Section 217.157(a), as published in the
IIlinois Register:
The owner or operator of an industrial boiler combusting blast furnace gas
subject to Subpart E of this Pati with a rated heat input capacity greater
than
500 mmBtulhr located at a source that manufactures iron or steel
must install, calibrate, operate, and maintain continuous monitoring
systems on the emission unit within one year after the initial emission
testing required by the state construction pennit issued by the Agency for
the emission unit, unless this testing or further testing conducted by the
owner
or operator of the emission unit demonstrates that the emission unit
nonnally complies
by a margin of at least 5 percent with the NOx
emission limit in the state construction pemlit issued by the Agency for
the emission unit or the Agency approves further time for the owner or
operator to achieve this level of perfonnance.
In addition, in order to correspond
to the new section above, subsection 217.157(a)(1)
should be revised
as follows:
1)
Except as provided in subsection (a)(insert new paragraph
number), the owner or operator
of an industrial boiler subject to
Subpart E
of this Part with a rated heat input capacity greater than
250 mmBtu/hr
must install, calibrate, maintain, and operate a
continuous emissions monitoring system on the emission unit for
5
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
the measurement of NO x emissions discharged into the atmosphere
in accordance with
40 CFR 75, as incorporated by reference in
Section 217.l04.
IV.
PROPOSED SECTION 217.164(e)
The proposed rule in Board's First Notice Order differs from the proposed rule
published
in the Illinois Register on May 22,2009.
See
Board Order,
In the Matter of
Nitrogen Oxides Emissions From Various Categories: Amendments to
35
Ill. Adm. Code
Parts
211
and
217, R08-19 at 2-8 (Ill.Pol.Control.Bd. May 7, 2009); 33 IlL Reg. 6921
(May 22,
2009). Section 217 .164( e) provides the formula for determining the NOx
emission limit for an "industrial boiler combusting a combination of natural gas, coke
oven gas, and blast furnace
gas." Proposed 35 IlL Admin. Code § 217.164(e). The
formula in the Illinois Register version fails to include the sUbscript
"BFG" on the last
BTU in the divisor of the formula. The "BFG" is necessary since BTUBFG is the "heat
input of blast furnace gas in BTU over that period." Proposed 35 Ill. Admin. Code §
217.164(e). In addition, a closed parenthesis should follow the
BFG subscript in order to
complete the equation.
U.S. Steel requests that the fornmla be corrected in the final,
published version
of the proposed rule.
V.
CONCLUSION
U.S. Steel appreciates the Agency's willingness to discuss the issues raised for its
facility
by the proposed rulemaking and thanks the Agency for its continued cooperation.
U.S. Steel, however, requests that the Board include a provision in the emissions
averaging section
ofthe proposed rule to cover times when the desulfurization unit is
shutdown due to unplanned outages or upsets, as well as include the suggested revision to
proposed
Section 217.1S7(a), as discussed above, in order to be consistent with the
6
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
requirements of the construction permit issued by the Agency for U.S. Steel's
cogeneration boiler. U.S. Steel further requests that proposed Section 217.164(e) be
corrected as described above.
U.S. Steel reserves the right to supplement these First Notice Comments.
Dated: July 6,
2009
Katherine D. Hodge
Monica T. Rios
HODGE DWYER
&
DRIVER
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
USSC:OO IlFiIlR08- [9!US Steel First Notice Comments
Respectfully submitted,
UNITED
STATES STEEL
CORPORATION,
By:
IslKatherine D. Hodge
Katherine D. Hodge
7
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
217/782-2113
United States Steel
Attn: Larry S
600 Grant Street
This Permit is
ATTACHMENT
A
CONSTRUCTION PERMIT -- NSPS SOURCE
15219
ect
Street, Granite
to the above-des
11, 2006
to CONSTRUCT
emission source! ) and/or ir
ution control
consi
of a
blast furnace gas (BFG) fired cogeneration boiler, a flare, and cool
tower, as described
the above-referenced
ication. This Permit is
ect to standard conditions attached hereto and the
condition (s) :
If you have any
7/782-211
on this
Edwin C. Bakowski,
.E.
Date
Manager, Permit Section
Division of Air Pollution Control
ECB:JMS:psj
cc:
3
Lotus Notes
CES
tact Jason Schnepp at
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 2
1.0
2.0
3.0
TABLE OF CONTENTS
LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED
GENERAL CONDITIONS
2.1
General
icable Provisions
2.2
General Non-Applicabil
2.3
General
2.4
General
.5
2.6
2.7
Authorization to Operate
UNIT SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS
3.1
Cogeneration Boiler
3.2
BIas Furnace Gas Flare
Cool
Water Tower
4.0
ATTACHMENTS
1
2
is
t Conditions
3
4
10
4-1
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 3
1.0
LIST OF ABBREVIATIONS AND ACRONYMS COMMONLY USED
BFG
Blast FUl:nace Gas
CAAPP
Clean Air Act Permit Program
CFR
Code of Federal Regulations
CO
Carbon Monoxide
dscf
Dry standard cubic feet
gr
Grains
HAP
Hazardous Air Pollutant
H
2
SO
4
Sulfuric Acid
hr
Hour
lAC
Illinois Administrative Code
1.
D. No.
Identification Number of Source, assigned by Illinois EPA
Illinois EPA Illinois Environmental Protection Agency
Lb
Pound
mg
t~illigram
Mo
l~onth
mmBtu
l~illion
British Thermal Units
MSSCAM
Major Stat
Sources Construction and
t~odification
( 35
Part
03) ,
also
known
as
Nonattainment New Source Review
(NA
NSR)
NESHAP
National Emission Standards for Hazardous Air Pollutants
NO"
Nitrogen
Oxides
NSPS
NevJ
Source
Performance Standards
Pr1
Parti.culate Matter
Pfvl ]()
Parti
Ilat
(tt,
lith
:odynami,
di
d:.,
1
than
to
nominal 10
microns
as
measured
test
or
monitoring methods
Ptvl
2
. "
Particulate matter
with an
,rod:
lami,
diameter less than
equal to
I:
• J
measured
icable
test
or monitoring methods
ppm
Parts Per Million
PSD
Prevention of Significant
Deterioration ( 40 CFR 52.21 )
scf
Standard Cubic
Feet
scm
Standard Cubic Meter
S02
I
Sulfur
Dioxide
USEPA
I
United
Stat~,s
Environmental Protection Agency
VOM
Volatile Organic Material
Yr
Year
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 4
2.0
OVERALL SOURCE CONDITIONS
2.1
2.1.1
2.1.
.2
2. .1
ect are
as set forth in Section 3
fic Emission Units) of this
In addition, these emission units are
ect to the
of
icabi
a.
No person shall cause or allow the emission of
matter from any process,
any
material handl
that is visible
an observer
overhead at a
beyond
the property line of the source unless the wind
i
greater than 40. kilometers per hour (25 miles per
hour), pursuant to 35 lAC
.301
21 .314.
b.
(a), no person shall cause or
ssion
smoke or other particulate matter,
greater than 30 percent, into the
any emission unit other than those
ect to the
f 35
11K
allowed
(b)
PSD/NAA NSR
The Permittee has addressed the
icability of 40 CFR
. I, PSD, and 35 lAC Part 03,
or
Sources
Construction and Hodification (MSSCAM).
this permit are intended to ensure
Boiler
ect addressed in this
construction
does not constitute a
or
modification of the source pursuant to these rules
also Condition 2.6
For the purpose of
address
is a
0.1' modification
for emissions
under NSSCAN,
us
Steel did not
emission data for the
ect and
is shows that
would not be
a significant net increase in
emissions is conducted in terms of emissions of PH
10
, the
limits for emissions PN
10
established
this
are
al
cable to emissions of PM
2
.
S'
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 5
2.3
2.3.1
. 4
.4.
a.
Program
Pursuant to 35 lAC 212.309, emission units that are
ect to a
rement in 35 lAC 12.304 through
21 .308 or 212.316 shall be operated under the
of an
program, consistent with the
set forth in 35 lAC 212.310 and 212.312, and
the Permittee and submitted to the Illinois EPA for its
review.
Such
program shall be
to
s
particulate matter
emissions.
i.
At a minimum the ope rat
program shall
ii.
the information and elements
fied
12.310,
(1) a detailed de
of
the best management
utilized to control
ive dust; ( ) estimated frequency of
ion of dust suppressants
location;
such other informat
as may
facilitate the III
s EPA's review of the
program.
This program shall al
control measures
certain
1imi
identi
the
fic
be needed to ensure that
with the
iii. Pursuant to 5 lAC 12.
,this operat
program
shal be amended from time to
the Permittee
that
program is
current~
Such
amendments shall be consistent with
lAC Part
t K and shal be submitted to the II inois
EPA for its review .
Retention and
of Records
a.
All records and
this
shall be
retained for at least five years from the date of entry
is
fied
the
sion herein"
shall be
at a location at the source that is readi
accessible to
the Illinois EPA or USEPA, and shall be made available
for
and
the Illinois EPA or USEPA
upon request.
b.
The Permittee shall retrieve and
, on paper
normal source office hours, any records retained in an
electronic format (e.g., computer) in response to an
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 6
Illinois EPA or USEPA request for records
the
course of a source
2.5
2.5.1
Report
and Notifications Associated with Emissions Tests
a.
The Illinois EPA shall be notified prior to
red
emissions tests to enable the Illinois EPA to observe
these tests. Notification of the expected date of
shall be submitted a minimum of 30 days
to
date. Notification of the actual
time of testing shall be submitted a
minimum of 5
to the actual date of the
test. The Illinois EPA may at its discretion accept
notifications with shorter advance notice
that
the Illinois EPA will not accept such notifications if it
interferes with the Illinois EPA's abil
to observe
b.
At
60
prior Lo the actual date
emis
, a written test
shall be submitted
to the Illinois EPA for
This
the
fic
at a
minimum:
i.
The
ii.
emissions and the means
parameters for the emission unit
will be determined.
iii.
fic determinations of emissions and
, which are intended to be made,
and moni
locations.
iv.
The test method(s) that will be used, with the
specific
is method, if
method can be used
with different analysis methods.
minor
s in standard
proposed
to accommodate the
fic circumstances of
f
with justification.
vi.
ty observations du
of
of the Final Reports(s) for
emissions
tests shall be submitted to the Illinois EPA within 30
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 7
.5.2
after the test results are
led and finalized.
The Final Report shall include at a minimum:
i.
A summary of results.
ii.
General information.
iii.
and test
iv.
Detailed
ion of test conditions,
A.
Process information.
B.
v.
Data and calculations,
calculations, and
Notification and Report
of Deviations
e.g.
f
parameters
of all raw
records and
provision of this
for
ion
t shall include at
the date and time of
the
of
a
ion of any
preventati
occurrences .
measures
prevent future
. 6
Provi
a.
This
relies upon the emissions decreases established
the Emission Reduction Projects (Construction Permit 0607002 ).
For this purpose, exis
Boilers 1
10 shall be
shut down within 180
of the initial start up
of the new
boiler or upon
of shakedown
of the boiler, whichever occurs first, unless the Illinois EPA
authori
an extended transition
between the
boiler and exis
boilers to address the
shakedown of the new boiler, in which case the
operation of the new and exist
boilers
the extended
transition
shall be coordinated so that their combined
emissions do not exceed the annual emiss
limits set
thi
for the cogeneration boiler.
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 8
b.
This
t relies upon the
permanent shutdown of the
No. 6 Galvan
Line.
Once the line is
shutdown,
restart of the line would
t from
the Illinois EPA.
Note: The
ion indicates an annual decrease of 10.36
tons of CO, 38.48 tons of NO
x
,
0.94 tons of PM/PM
10
, 0.07 tons
of S02, and 0.68 tons of VOM from the shutdown of No.6
Galvaniz
Line. These values represent the actual emissions
attributable to natural gas combustion in No. 6 Galvani
Line. As these
are unrelated to the
ect,
are
considered contemporaneous emission decreases as addressed in
the Attachment to this
t.
This
relies upon the
permanent shutdown of the
No.
COG Booster Pump (natural gas fired).
This natural gas
fired pump
is
by an electric pump.
Note: The
tion indicates an annual decrease of 117.97
tons of CO, 77.30 tons of NO
x
,
0.64 tons of PM/PM
10
, 0.02 tons
of
,and 0.99 tons
VOM from the shutdown of No.4 COG
Booster Pump (natural gas fired). These values rep.resent the
actual emissions attributable to natural gas combustion in the
No.
COG Booster Pump (natural gas fired).
As these
are unrelated to the
ect, they are considered
contemporaneous emission
as
sed in the
attachment to this
1..
Emissions attributable to the
associated with
station
tion of natural
(Construction Permit
04110018) shall not exceed the
limits fter the
ion boiler initial
tarts
the annual limits shall be
termined from
total of 12 months of data. This Condition supersedes
Condition 3 of Construction Permit 04110018, issued
4,
005.
Emis s i()l1s
Pollutant
(Tons/Month)
(Tons/Year)
NO
x
2.80
17.22
CO
0.84
5.17
Pt1
0.12
0.7}
Pt1
10
0.11
0.62
VOM
0.06
0.34
S02
0.01
0.04
ii.
The Permittee shall continue to
with the other
of Construction Permit 04110018,
limitations,
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 9
2.7
The new emission units
may be
under this
have been
into the
source's issued CAAPP
t,
that the Permittee submits
t
and
application for such CAAPP
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 10
3.0
UNIT-SPECIFIC CONDITIONS FOR SPECIFIC EMISSION UNITS
3.1
Cogeneration Boiler
3.1.1
. 1.
. 1.3-1
3.1.3-2
Under the source's current
iOD, twelve boilers at the
source (Boilers 1-12) fire BFG as well as coke oven gas and
natural gas. This
ect involves construction of a new
boiler and the shutdown of Boilers 1-10 (Also
addressed by Emission Reduction Project, Construction Permit
06070022).
BFG
burned in Boilers 1-10 would be sent
to the new
boiler under the
The new boiler would be used for
, as it would
pressure steam to a steam turbine which would
for use at the source. Low-pressure steam
from
turbine would then
used for
operations at the source.
The
boUer
Uy fed with
natural gas would be used for
flame and also for
combust
control .
a.
The "affected unit" for the purpose of these unit-
fic condi ions, is the EFG Boiler described in
Conditions 3.1.1 and 3.1.2 .
The affected unit is
ect to the NSPS for Industrial-
Commercial-Institutional Steam
Units, 40 CFR 60
t
Db.
Note: While the affected unit meets the
of 40
eFR Part 60
Db, it is not
ect to the emission
standards of this rule.
a.
The affected unit is
ect to 35 lAC 212.122(a), which
that no person shall cause
allow the emission
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 11
3. l. 3-3
. l.4
of smoke or other
matter into the atmosphere
from any fuel combustion emission unit for which
construction or modification commenced on or after
1 14, 1972, with actual heat
greater than 73.2
MW (250 mmBtu/hour), having an
greater than 0
percent.
a.
The affected unit is
ect to 35 lAe 216.121, which
that no person
or allow the emission
f carbon monoxide (CO)
from a fuel
combustion unit with a heat
of 10 million
Btu per hour or more
percent excess air .
a.
The affected unit is not
to the NSPS
Utility Steam
Units (40 eFR 60,
because the affected unit is not an electric
steam generat
t
the term is defined
0.4
b.
The affected uni is not
ect
40 CFR 60,
D
because the affected unit meets the applicabilit
d.
sunder 40 CFR 60.40b(a)
[40 CFR 60.40b(j)].
affected
standards of
unit meets the
The affected unit is not
standards of 40 CFR 60,
unit has an annual
percent or less and is
that limits
the sulfur dioxide
Db because the affected
at 40 eFR 60.42b(k) (2).
t to the nitrogen oxides
Db because the affected
ty factor for natural gas of 10
ect to a federal
enforceable
of the facil
to an
ty factor of 10 percent or less for natural
gas (See also Condition 3.1.6(a)).
e.
The affected unit is not
ect to the particulate
f.
matter standards of 40 CFR 60,
Db because these
standards do not
to gaseous fuel boilers.
1.
is issued based on the affected unit
ect to emission standards or other
rements pursuant to the NESHAP for Industrial,
Commercial, and Institutional Boilers and Process
Heaters, 40 CFR 63,
DDDDD.
This is because
this NESHAP has been vacated
a court mandate,
pursuant to a request by USEPA, and is no
in
effect.
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 12
.
1.
Note: Had this rule not been vacated, the affected
unit would have met the BFG fuel fired boiler
exclusion at 40 CFR 63.7491(0).
gaseous fuel units," under this NESHAP would
have been limited to CO emissions of no more than
400 ppm,
basis at 3 percent oxygen, 3
roll
average,
periods of startup,
shutdown, malfunction, and low-load operation,
which is less s
t than the standard set
35
IAC 216.121 (See Condition 3.1.3-3).
ii.
This
t is issued based on the affected unit
i .
not
a
source of HAPs for purposes of
Section 112(g) of the Clean Air Act so that a case-
by-case determination of Maximum Achievable Control
(MACT) is not
red for the affected
unit pursuant to Section 1 2(g) and 40 CFR 63
This is because the affected unit is
constructed at a developed site and the
potential annual emissions of HAPs from the
affected unit are less than 10 tons of any
individual HAP and less than 25 tons of any
combination of HAPs.
affec
termination made by
the affected unit.
Permittee
1
Permittee shall comply
ions
l1ACT
ies
submi t ted
t~o
Illi.nois
pursuant
to Section 1
(j)
f the Clean Air Act to support
case-by-case determination of MACT for the boilers
at the source.
g.
The affected unit is not
ect to
lAC 217. 1
because the affected unit is not fossil fuel-fired as
defined
5 IAC 211. 4 5 .
a.
Emissions of Pr1 and PM
10
from the affected unit shall be
controlled
the
BFG
system, which
entails treatment
wet scrubbers.
i.
The PM content of the BFG burned in the affected
unit shall not exceed 0.01
/dscf.
ii.
Emissions of PM from the ffected unit, as measured
IJSEP]I, t1ethod 5,
shall not
0.03 Ib/mmBtu
of exhaust.
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 13
3.1.6
b.
BFG and natural gas shall be the only fuels fired in the
affected unit.
c.
The affected unit shall be operated for the
a.
b.
purpose of
steam and elect
to the source
with no more than 219,000 MW-hour of excess elect
sent to any utility power distribution system for sale in
any calendar year from the electrical generator
associated with the unit.
1.
11,.
B.
The maximum des
rate of the
affected unit shall not exceed 505
mmBtu/hour.
The maximum des
unit shall not
of the affected
mmBtu/hour.
ii.
Fuel usage for the affected unit and the new BFG
flare
1 not exceed the fol
limits
(roll
1 -month basis) :
Natural gas:
341,666
B.
fuel usage combined:
4,51 ,4
Emissions from the
the
limits.
shall be determined as
continuous emissions
which
iance shal
average (24
Pollutant
unit shall not exceed
iance with these limits
unless
is conducted,
be determined as a dai
hours) ;
!Vlode
BFG*
Natural
Gas
(Lbs/rmnBtu)
(Lbs/mmBtu)
NO
x
0.05
0.12
CO
0.15
0.0824
VQj\1
---
0.0054
PM/PM
lO
0.101
0.0075
30
2
HAPF
0.20
0.0006
Indiv. Metal
0.00066
0.00066
Total HAPs
0.0053
0.0053
*
BFG mode entails firing a mix of BFG with up
to 10 percent natural gas.
ii.
Emissions from the affected unit and the new BFG
flare shal not exceed the fol
limits:
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 14
3.1.7
Pollutant
Emissions
Tons/Month
Tons/Year
NO
x
12.5
124.74
CO
33.9
33S.36
VOM
0.1
0.92
PM/PM
1O
22.9
22S.39
S02
45.2
451.14
Indiv. !'letal HAP
0.2
1.5
Total HAPs
1.2
12.0
c.
iance with annual limits shall be determined on a
monthly basis from the sum of the data for the
month
the
11
(
total), unless otherwise
condition.
Within 60
after
the maximum
rate at which the affected unit will be
than ISO days after initial startup of
unit, the Permittee shall conduct
and
furnish the Illinois EPA
wri
report of the
such test( ).
These
shal be
CO,
,P!'llO, PM and
under conditions which
NO,,,
mode
of
maximum
ss
ii.
These tests shall also include measurements of
emissions of metal if the Permittee elects
conduct emissions test
to verify
iance
th
the limits for metal HAPs, as an alternative to
data for the metal HAP content of material
collected dur
provided for
pretreatment of the BFG, as
Condition 3.1.S-2(b).
The fol
USEPA test methods shall be used for
of emissions, unless another method is approved
Illinois EPA.
Refer to 40 CFR 51,
M, and
40
60,
A, for test methods.
Location
of
Points
Method 1
Gas
Flow
and
Velocity
Method
Flue
Gas
Method
Moisture
Method
4
Method 6
NO
x
l'lethod
7
CO
!'lethod 10
Pl'l]o
[vjethods
2011V
&
202
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 15
3.1.8-
PM
VOM
Metals
Method 5
Method 18 or 25A
Method 29
*
The Permittee may also use Method 5 as an alternative
to Method 201A, provided that the measured results shall
be considered PM10.
d.
The Permittee shall submit a plan, notifications and a
report for these emissions tests as
Condition
.5.1. For this purpose, in addition to other
information, the test report shall include data for the
sulfur and PM content of BFG and the metals content of
the material removed from raw BFG
the pretreatment
system, as determined pursuant to Condition 3 .. 8-2.
a.
The Permittee shall instal, calibrate, operate, and
b.
maintain NO
x
and
continuous moni
system(s) on
the affected unit within one year after the initial
emission test
this
unles this
or further tes
the Permittee
demonstrates that the unit normal
ies
of at least 5 percent with the NO
x
and CO emiss
th
t or the Illinoi EPA approves
the Permittee to
this level of
i.
These
shall be operated
of the affected boiler
maintenance, brea
ii.
maintain records for the
continuous moni
system,
recorded
emission concentrations and records of maintenance,
calibration, and
activity associated
with the system.
iii. The Permittee shall submit
reports to the Illinois EPA for these emission
moni
system(s) in accordance with relevant
rements of the NSPS for continuous
emi sions monitoring systems.
c.
NO
x
or CO continuous emission
may be
d.
discontinued if a
plan is approved
by the Illinois EPA in a revised construction
or
the
for the plant.
The
for a NO
z
revised or waived in the
system may be
for the source
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 16
3.1.8 2
.1. 9
if the Illinois EPA determines that
with
for NO
x
or CO emissions is not facilitated
such moni
a.
The Permittee shall
and
cleaned BFG after
b.
a.
b.
the pretreatment system for sulfur content (lb/mmBtu),
ASTM methods or other
measurements shall be conducted
test
red
Condition 3.1.7
and on at least a
The
records for this
also include
data for the blast furnaces and the BFG pretreatment
system at the time of
The Permittee shall
after the pretreatment
and
Condition
biennial basis thereafter. The
the cleaned BFG
PM content (
scf)
pretreatment system
basis, for individual
us
ASTM
the emission
and on at least
for this activity
shall also include
data for the blast
the BFG pretreatment system at the time of
Unl
for
in
the
for PM emissions to calculate emissions of metals
of
iance
the
The Permittee shall maintain the fol
the BFG pretreatment system:
records for
1.
Records for pressure
and water flow;
ii.
Operat
iii. Maintenance
The Permittee shall maintain the fol
records:
i.
A file which contains
which demonstrates the maximum
emission
of the affected unit (mmBtu/hour), the maximum
BFG
of the affected unit, and the
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 17
. 0
c.
manufacturer's guarantees for the emission rates of
the natural gas burners in the affected unit.
ii.
Amounts of fuel burned
type (mmBtu/month and
rrunBtu/year) for the affected unit.
iii.
Emissions of NO
x
,
CO, VOM,
, S02 and HAPs
(tons/month and tons
) from the affected unit.
iv.
Amounts of fuel burned for the affected unit and
the new BFG flare, combined,
type (wnBtu/month
and
) .
v.
Summation of the emissions of NOv CO, VOM, PM/PM
10
,
S02 and HAPs from the affected unit and the new BFG
flare (tons/month and tons
) .
The Permittee shall
with the
rements of the NSPS,
40 eFR 60.7(b) and 60.49b,
icable
fied in
d.
The Permittee shall maintain records of
fur
b.
content of the fuels burned in the affected unit,
records for the
and
is of BFG
.1.8-2(a). Records may consist of
fications for the sulfur content
of natural gas.
the 1llinoi EPA
with the
(Section 3.1). Reports
shall describe
cause of such deviations, and
any corrective actions or preventive measures taken,
i.
Emissions or operation f the affected unit in
excess of the limits
fied
Condition .1.6
shall be
within 30
of such
occurrence.
ii.
Other deviations shall be
report.
The Permittee shall
ts of the NSPS, as
60.49b.
in a
icable reporting
fied in 40 eFR 60.7 and
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 18
Flare
3.2.1
3.2.2
. .4
.2.5
A new BFG flare would be installed to safely combust excess BFG
that cannot be
used at the source as fuel.
Al
the primary
ition of BFG is the new cogeneration
boiler, exi
Boilers 11 and 12, and the blast furnace
stoves, there may be
of time when the existing BFG
flare system is unable to handle all of the excess BFG (e.g.,
when the BFG boiler is down for maintenance) .
these
, the excess BFG would be routed to the new BFG flare.
The "affected unit"
the purpose of these unit-
is the flare
in Conditions
b.
14.301, which
process emi
a.
1.
B.
ar
set
and
des
The affected uni shall be des
for
of BFG.
low
from
The affected unit shall be des
for and
operated with no visible emissions as
to
determined
the methods
fied in 40 eFr<.
60.l8(f), except for
total of 5 minutes
hours.
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 19
3. .6
3. .7
. 8
C.
The affected unit shall be
wi th a
flame present at all times when BFG may be
sent to the affected unit.
D.
The presence of a
flame shall
monitored us
a
or any other
device to detect the presence of a
flame.
ii.
Emissions of PM and PM
10
from the affected unit
shall be controlled
the exi
BFG
pretreatment system, which entails treatment
dust catchers and wet scrubbers.
iii. BFG and natural gas shall be the
combusted in the affected unit.
fuel
b.
The Permittee shall not vent any gas stream
b.
reduced sulfur
concentrations
the affected
unit that would cause the sulfur dioxide emissions into
the
from any affected unit to exceed ,000
ppm.
imit ensures that the affected unit meets the
emission limi in 35
214. 01.
Within 180
after initial startup of the affected
unit or otherwise the first
ty
normal
hours of environmental staff when the unit is
for a
of at least 10
hours, the
Permittee shall conduct observations for visible
emissions from the affected unit and furnish the Illinois
EPA a written report of the results of such test(s).
The test shal be des
measure the presence of
visible emissions from the affected unit.
c.
The Permittee shall submit reports for these tests as
Condition 2.5. (c) .
a.
The presence of a flare
lot flame shall be monitored
us
a
or any other
device to
detect the presence of a flame.
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
PaCJe 70
3.2.9
3. .10
a.
The Permittee shall maintain records of the fol
items related to the pilot flame:
a.
i.
Date and duration of any time when the pilot flame
mon
of the affected unit was not
in
ii.
Date and duration of any time when there was no
at the affected unit, with
iii. The Permittee shall maintain records of the
fol
items for each exceedance f the limits
in Conditions 3.2.3, 3.2.5, or 3.1.6, which shall
include:
of
1
that may have
Duration of
C.
An estimate of the amount of emissions in
excess
standard.
D.
ion of the
of the
E.
iance
reestablished.
The Permittee
1 maintain
items for the affected unit:
of
fol
1.
Amount of gas burned
type (mmBtu/month and
) .
ii.
Emissions of NO)" CO,
vorvr,
PM/PtvIll!l and S02
(tons/month and tons
) .
of Deviations
The Permittee shall
noti
the Il inois EPA of
deviations of the affected unit with the
of this section (Section 3.2). Reports
shall include information
fied in Condition
3.2.10(a) (i).
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page
1
i.
Within 30
of exceedance of the limits in
Conditions 3.2.3 and 3.2.5 the notification shall
include:
ii.
A.
Identification of the limit that may have
been exceeded.
B.
Duration of the
exceedance.
C.
An estimate of the amount of emissions in
excess of the
icable standard.
D.
A de
ion of the cause of the possible
exceedance.
E.
When
iance was reestablished.
Other deviations shall be
iance report.
in a
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 22
Cool
3.3.1
. 3.2
3
. .4
.3.6
Water Tower
A
tower would be installed with the new
boiler and associated turbine.
The
tower would be a source of
matter
because of minerals contained in the water, which would be
emitted if a water
evaporates in the cool
tOIo/e.[ .
a.
b.
1m
affected unit" for
a
. . I
purpose of
vlater tower
.3.2.
uni
scribed in
Pursuant to 40
chromium-based water
unit.
.402, the Permittee
chemicals in the
of Concern
The affec
because the
t
Lo 35 lAC 219.98 (d),
not
process water.
Practices
The des
from the drift eliminator on the
affected unit shall not exceed 0.001 percent.
1.
i1.
Limitations
The
ty of the affected unit, expressed in
terms of des
water circulation rate, shall not
exceed 42,000
Ions per minute,
average.
The total dissolved solids content of water
circulating in the affected unit shall not exceed
4,190 ppm on a
basis.
b.
Emissions of
from the affected unit shall not
exceed 0.3 tons/month and 3.86 tons
Compliance
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
Page 23
•
'"
I
:3. .8
. .10
a.
with the annual limit shall be determined from a
total of 12 months of data.
The Permittee shall
and
circulated in the affected unit on at least a
basis for the total dissolved solids content.
b.
Upon written request
the Illinois EPA, the Permittee
shall
have the water
in the affected
unit
and
for the presence of hexavalent
chromium in accordance with the
of 40 CFR
63.404(a) and (b).
c.
The Permittee shall
records for this sampling and
ctivity, including documentation for sampl
is as well the resul
data that is
collected.
Upon written request
shall test the percent
eliminator pursuant
Test
The Permi
shall
the Illinois EPA, the Permittee
drift
the drift
/minute, hour
maximum
drift loss rate f the affected unit with support
documentation.
b.
The Permittee shall keep records of emissions of PM/P['1
10
,
vii th
calculations (tons/month and tons
) .
The Permittee shall
the Illinois EPA of
deviations of the affected unit with the
t
rements of
this section (Section 3.3). Reports shall include information
a.
fied in Condition 3.3.10(a).
Emissions or
the limits
such occurrence.
of the affected unit in excess of
in Condition 3.3.6 within 30
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
I
4.0
ATTACHMENTS
Project Emissions
Si(;;rnificance Threshold:
Greater Than
Significant?
Con temporaneous
a
Increases
NG Enrichment (04110018)
Slab Furnaces (06070022)
Contemporaneous. Decreases
Boilers
1
thru 10
(06070022)
COG
Desulf (06070022)
Slab Furnaces
(06070022)
No. 6 Galv. Line
(06070023)
No. 4 COG
Pump
(06070023)
NET EMISSIONS
CHANGE
Significance
Threshold:
Greater
Than
Significant?
Notes:
a.
Based on the
Date
2/2005
D
0
D
0
b
is
2008.
NO
x
NO
x
(NA NSR)
(PSD)
SO"
VOM
PM
.5
Lead
I
H
2
SO
4
124.74
124.74
338.36
451.14
0.92
232.25
232.25
---
---
40
40
100
40
40
25
15
0.6
7
Yes
Yes
Yes
Yes
No
Yes
Yes
No
No
17.22
17.22
5.17
0.04
0.34
0.73
0.62
---
---
---
---
26.77
---
I.
75
43.43
43.43
---
---
-278.89 -278.89
-313.61
-789.43
-1. 22
-228.06
-228.06
---
---
---
---
---
-2,107.95
---
-94.15
-94.15
---
-63.11
-427.94
-427.94
---
-174.15
---
---
---
---
---
-38.48
-38.48
-10.36
-0.01
-0.68
-0.94
-0.94
---
---
-77.30
-77.30
-117.97
-0.02
-0.99
-0.64
-0.64
---
---
-680.65
-680.65
-71. 64 -2,620.44
0.12
-47.38
-47.49
---
-63.11
40
40
100
40
40
25
15
0.6
7
No
No
!
No
No
No
No
No
No
No
initial startup of the proposed cogeneration boiler, the contemporaneous time
1 2002
200. The contemporaneous time period for NA NSR pollutants
b.
Future emissions decrease. The decrease in emissions from existing Boilers 1 thru 0, which the project
replaces, will
when the new boiler initial
starts up diverting BFG from the existing boilers and will be
after the shakedown and any transition
for the new boiler, when the exis
boilers must be
shut down.
1
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
STANDARD CONDITIONS FOR CONSTRUCTION/DEVELOPMENT PERMITS
ISSUED
BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
The Illinois Environmental Protection Act (Illinois Revised Statutes,
111-1/2, Section 1039) authorizes the Environmental Protection Agency to
conditions on
s, which it issues.
The fol
condition(s) .
conditions are
cable unless
1.
Unless this permit has been extended or it has been voided by a
issued
, this
will
one year from the date of
issuance, unless a continuous program of construction or
this project has started
such time.
on
Protection
Control Board.
shall be done in
Illinois Environmental
Illinois Pollution
4.
shall
no
ions from the
ficat
written request for modification,
, shall have
submitted to the Illinois
EPA and a
written permit issued.
d.
e.
low any duly authorized agent of the III
of credent
s, t
times:
enter the Permittee' property whe
effluent, emi sion or noise sources
actual
potential
i
to be conducted pursuant
have acces
and
any
under the terms and conditions of
any hours of
constructed or operated under this
to be
, used,
maintained under this
To obtain and remove
pollutants, and
of any
4-2
or
t,
and
or emissions of
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
5.
The issuance of this permit:
b.
7.
a.
Shall not be considered as in any manner affect
the title of
the
upon which the
facilities are to be
located,
b.
Does not release the Permittee from any
1
for damage to
c.
person or property caused
or result
from the construction,
maintenance, or
of the proposed facilities.
Does not release the Permittee from
icable statutes and
State of Illinois,
tions.
iance with other
the United States, of the
local laws, ordinances and
d.
Does not take into consideration or attest to the structural
e.
stabil
of any units or parts of the
ect, and
no manner
officers, agents
for
maintenance,
ies or suggests that the Illinois EPA (or its
) assumes any liability,
to
, installation,
the proposed
or faci
Unless
joint
tion
has been issued, a
perrr~t
for operation shall
from the Illinois EPA before the
covered
into operation.
testing, unless
by
may
The
III
EPA may file a
with the Board
modi
b.
of
Upon discovery that the
contained
mis
misinformation or false statement or that al
relevant facts were not disclosed, or
Upon
violated, or
that any standard or
conditions have been
c.
Upon any violations of the Environmental Protection Act or any
tion effective thereunder as a result of the construction
authorized
this
t.
JMS:06070023:
4
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
CERTIFICATE OF SERVICE
I, Katherine D. Hodge, the undersigned, hereby certify that I have served the
attached
FIRST NOTICE COMMENTS OF UNITED STATES STEEL
CORPORATION,
upon:
Mr. John T. Therriault
Assistant Clerk of the Board
Illinois
Pollution Control Board
100 West Randolph Strcet, Suite 11-500
Chicago, Illinois 60601
Timothy Fox, Esq.
Hearing
Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
foxt@ipcb.state.il.us
Gina Roccaforte, Esq.
John
J. Kim, Esq.
Division
of Legal Counsel
Illinois Environmental
Protection Agency
1 1 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
gina.roccaforte@illinois.gov
John.J.Kim@illinois.gov
Virginia
Yang, Esq.
Deputy Legal Counsel
Illinois Department
of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
Virginia. Yang@Illinois.gov
via electronic mail on July
6, 2009.
Alec M. Davis, Esq.
General Counsel
Illinois Environmental Regulatory Group
215 East Adams
Street
Springfield, Illinois 62701
adavis@ierg.org
Matthew
J. Dunn, Esq.
Chief, Environmental Bureau North
Office of the Attorney General
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
mdunn@atg.state.i1.us
Kathleen
C. Bassi, Esq.
Stephen J. Bonebrake, Esq.
Schiff Hardin, LLP
6600 Sears Tower
South Wacker Drive
Chicago, Illinois 60606-6473
kbassi@schiffhardin.com
sbonebrake@schiffhardin.com
Christina
L. Archer, Esq.
Associate General Counsel
Arcelormittal
USA, Inc.
I South Dearborn, 19th Floor
Chicago, Illinois
60603
Christina.Archer@arcelormittal.com
IslKatherine D. Hodge
Katherine D. I-lodge
Electronic Filing - Received, Clerk's Office, July 6, 2009
* * * * * * PC # 19 * * * * * *
