1. CERTIFICATE OF SERVICE
      2. RESPONSE TO THE FIRST NOTICE PUBLIC COMMENT OF THE ILLINOIS EPA
      3. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
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 60601
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
RESPONSE TO THE FIRST NOTICE PUBLIC
COMMENT OF THE ILLINOIS EPA SUBMITTED BY ARCELORMITTAL USA, INC.
a copy of which is herewith served upon you.
Dated: July
7, 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:
Christina
L. Archer
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 20 * * * * *
CERTIFICATE OF SERVICE
I, Christina
L.
Archer, the undersigned, hereby certify that I have served the attached
RESPONSE TO THE FIRST NOTICE PUBLIC COMMENT OF THE ILLINOIS EPA
SUBMITTED
BY ARCELORMITTAL USA, INC.
upon:
Mr. John
T.
Therriault
Assistant Clerk
of the Board
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 6060 I
therriaj@ipcb.state.il.us
Gina Roccaforte, Esq.
John Kim, Esq.
Division
of Legal Counsel
Illinois Environmental
Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Gina.Roccaforte@iIIinois.gov
J ohn.Kim@iIIinois.gov
Kathleen C. Bassi, Esq.
Stephen
J. Bonebrake, Esq.
Schiff Hardin,
LLP
6600
Sears Tower
233 South Wacker Drive
Chicago, Illinois 60606-6473
kbassi@schiffhardin.com
sbonebrake@schiffhardin.com
Gerald
T. Karr
Senior Assistant Attorney General
Environmental Bureau
Office ofthe Attorney General
69 West Washington Street, Suite
1800
Chicago, Illinois 60602
gkarr@atg.state.il.us
by electronic mail on July 7,2009.
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@hdzlaw.com
Virginia
Yang. Esq.
Deputy Legal Counsel
Illinois Department
ofN atural Resources
One Natural Resources Way
Springfield, Illinois 62701-1271
Virginia. Yang@illinois.gov
Alec M. Davis, Esq.
General Counsel
Illinois Environmental Regulatory Group
215 East Adams Street
Springfield, Illinois 62701
adavis@ierg.org
Christina
L.
Archer
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 20 * * * * *
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)
)
)
)
RESPONSE TO THE FIRST NOTICE PUBLIC COMMENT BY
THE ILLINOIS EPA SUBMITTED BY ARCELORMITTAL USA, INC.
Pursuant to 35
III.
Adm. Code 102.l08(d), this Response to the First Notice Public
Comment by the llIinois EPA is respectfully being submitted by ArcelorMittal USA Inc. on
behalf
of ArcelorMittal Riverdale Inc. (ArcelorMittal). On July I, 2009, ArcelorMittal filed its
First Notice
Public Comment in this matter and on July 6, 2009, the Illinois EPA filed its First
Notice
Public Comment in this matter. In its July 6, 2009 First Notice Public Comment, the
Illinois
EPA raised a few issues regarding cost effectiveness and the appropriate NOx emission
limit for other sources that ArcelorMittal feels must be rebutted. Therefore, ArcelorMittal is
requesting the Hearing Officer and/or Board consider this Response timely filed pursuant
to 35
III.
Adm. Code 102.1 08( d) to prevent material prejudice to ArceiorMittal.
By way
of background, on March 23, 2009, ArcelorMittal filed its Post-Hearing
Comments in this matter and attached
an economic analysis of cost effectiveness for tunnel
furnace burner change for the Illinois
EPA's review. That economic analysis assumed a 5-year
equipment life and a contingency factor
of 20%. The Illinois EPA questioned both these factors
in its First Notice
Public Comment. However, ArcelorMittal used U.S. EPA published factors
for both the equipment life and contingency, which was duly noted on the analysis spreadsheet.
The economic equipment life factor is derived from
U.S. EPA's "Alternative Control Technique
Document -
NOx Emissions from iron and Steel Mills,"
EPAl4531R-94-065,
September 1994
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 20 * * * * *
and the contingency was derived from U.S. EPA "Cost Air" spreadsheets available on-line at
http://www.epa.gov/ttn.
Even though not required to do so under U.S. EPA authority, taking the
Illinois EPA's comments into consideration, ArcelorMittal prepared a revised economic analysis
for burner change using
15 year economic equipment life and a 10% contingency. That analysis,
which
is attached hereto as Exhibit A, indicates a cost-effectiveness of
$1O,348/ton
of NOx
reduced for a next-generation 1500 burner and a cost-effectiveness of $17,84I1ton of NOx
reduced for a 1550 burner, still well in excess of the Illinois EPA's established range of $2,500 -
$3,000 per ton of emission reduction, U.S. EPA's determination of less than $2,000 per ton and
the Technical Support Document for this rulemaking's reference
of$I,OOO per ton.
The Illinois EPA also attempts
to dismiss ArcelorMittal's argument regarding the
appropriate
NOx emission limit for other sources. In our First Notice Public Comment, we
stated that the Beta Steel facility in Porter County, Indiana current emission limit for its reheat
furnace was
0.077 Ib/mmBTU based on a permit issued by the Indiana Department of
Environmental Management on August 12, 2004 (whereas, the Illinois EPA had provided the
Board with
NOx emission limit of 0.0147 Ib/mmBTU for this source).1 The Illinois EPA stated
in its First Notice Public Comment that the permitted limit for the Beta Steel facility is lower
than the proposed emission limit they propose for reheat furnaces
of 0.09 Ib/mmBTU; however,
the Illinois EPA misses the point that the permitted emission limit is more than 5 times greater
than the emission limit they thought applicable for that facility. This certainly calls into question
the arbitrary limit proposed by the Illinois EPA for reheat furnaces, which they have not
demonstrated
is based on Reasonably Available Control Technology (RACT).
1 ArcelorMittal inadvertently cited to the Beta Steel emission limit as O.77lb/nnnBTU in its First Notice Public
Comment and apologizes for any confusion caused.
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 21 * * * * *
Rulemaking R08-19 is supposed to be based on RACT and the Illinois EPA is required to
demonstrate
to the Board that its proposal is both economically reasonable and technically
feasible. The Illinois
EPA has failed to do that for the category of reheat furnaces located at
proposed section 35
m.
Adm. Code 217.244(a)(2). ArcelorMittal again requests the Board make
a decision based on RACT and retain the current, permitted emission limit
of 0.171
Ib/mmBTU
for ArcelorMittaI's tunnel furnace located at its facility in Riverdale, Illinois and conserve the
time and resources
of all parties involved by not requiring ArcelorMittal to initiate a proceeding
for subsequent regulatory relief when the Board
in
its discretion is able to provide the relief
requested in this rulemaking for all parties based on economic reasonableness and technical
feasibility.
Dated: July
7, 2009
Christina
L.
Archer
Associate General Counsel
ARCELORMITTAL
USA, INC.
1
South Dearborn, 19
th
Floor
Chicago, Illinois
60603
(312) 899-3865
Respectfully submitted,
ARCELORMITTAL
USA, INC.
By:--=C_L,,-_..:_L-C.-c
---'"J"'----"-C~___=_'
J.v_, _
Christina
L.
Archer
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 20 * * * * *
ArcelorMittal RIverdale Tunnel Furnace NOx RACT Analysis
Estimated Cost Effectiveness
for Burner Change (see note below)
3/1612009
CALCULATION fOR THE ANNUALIZED COST PER TON NOx REMOVED BASED ON CHANGING BURNERS FROM SERIES 1430 TO 1500 (Scenario
1) orto 1550 (Scgnario 2), see references and notes below.
Direct Capilal Costs (DCC):
Purchased Equipment Costs
Equipment
Costs (EC):
Sales Tax (O.03EC):
Total Purchased Equipment Costs (PEC):
Installation Costs (IC),
In~luding
instrumentation,
Freight,
Engineering, Startup Consultancy
Total Purchased
Equipmert art! Installation Cost (ICO:PEC + IC):
Other Indirect Capital Costs (oce)
Lost Production
Total Other Indirect Capital Costs (OCC)
Contingency (CONT, 0.10 [ICC+OCC]):
Total capital Cost (TCC=ICC+OCC+CONT)
Annualized Capital
Cost (ACC=TCCxCFR):
Capital Recovery Factor
(CRF):
Direct Annual
Costs (DAC):
Operation (0)
Maintenance (M)
Replacement Materials
Util~ies
Waste Disposal
Chemicals
Other
Total Direct Annual Costs (DAC)
Indirect Annual Costs (lAC);
Overhead (0.60(O+M»
Administrative (o.oncC)
Property Tax (o.oncC)
Insurance (0.02 TCC)
Total Indirect Annual Costs (lAC):
Total Annual Cost (TAC"ACC+DAC+IAC):
Capital
Recovery Factor (CFR) "
I "
7 % - interest rate
ill±...!!
(1 + I)" - 1
n" 15 years _ eoonomic equipment life
CFR"
0.110
Scenario
1
1500 Burner
$1,230.000
$36,900
$1,286.900
$300,000
$1.566,9{)0
'0
$0
$156,690
$1,723.590
$189,241
$0
$0
'0
'0
$0
$0
$0
$0
'0
$17,236
$17.236
$34.472
$68,944
$258,185
Scenario 2
1550 Burner
$2.710,000
$81.300
$2.791,300
$300,000
$3,091,300
$0
,0
$309.130
$3.400.430
$373.349
$0
,0
$0
,0
,0
$0
$0
$0
$0
$34,004
$34,0{)4
$68,009
$136,017
$509,366
Reference
(1)
I')
I')
I')
(5) Assumed com
see
below
I')
Ie)
I')
In
(8)
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 20 * * * * *
Baseline
Existing Burner (Bloom 1430) Emission Guarantee (tb NOxlMMBtu)
0.165
0.165
")
Naturat Gas
TUnnel Fumace Natural Gas Consumption with Senes 1430 (Actual 2005 MMBtu)
514430
514430
2005 NG Usage
~g: ~;;:i~~~~~~~h
Series 1430 (Actual tons NOx in 2005)
42.4
42.4
calculation
Burner Upgrade Scenarios
Bumer Series (Model)
Model 1500
Model 1550
Burner Upgrade Emission Guarantee (Ib NOxlMMBtu)
0.068
0,054
,'>
Natural Gas
Tunnel Furnace Natural Gas ConsumptTon (MMBtllfyr)
514430
514430
Furnace NG
NOx Emissions
NOx Emissions = Emission Guarantee' NG usage/2000 (TPY)
17.5
13.9
calcUlation
Incremental Emissions Reduction (tonsfyr):
25
"
calculation
=(2005 NG usage' 0.165 Ib NOxlMMBtul2000) - (NG usage' emission factor for replacement bumers/2000)
Cost-Effectrveness ($/IOn):
$10,348
$17,841
References:
Note: Vendors weill unable to guarantee product quality aspects aSSoCiated with a burner change, therefore a burner change is technically
Infeasible
for
Riverdale's Tunnel Furnace. Cost Information is provided for informational purposes only.
(1)
Bloom cost estimate (see email dated March 5, 2009 from Dave Church)
(2)
"EPA Pollution Control Cost Manual, Sixth
Ed~ion,"
EPA/4521B-02_001, January, 2002, Table 2,4, Page 2-27.
(3)
Conservative Cost Estimate
(4)
Need to determine downtime for installation and inctude
w~h
cost (IlDt inclUded as a conservatTve measure)
(5)
from EPA "Cost-Air" spreadsheets available on-line at http://www.epe.gov/!!n
(5)
"EPA Pollution Control Cost Manual, Sixth
Ed~ion,"
EPAl4521B-02-001, January, 2002, Section
2.5.5.B
(7)
Riverdale cost of
cap~at
(8)
"Alternative Control Techniques Dncument - NOx Emissions from Iron and Steel Mitts." EPAl45S/R-94-055, September. 1994,
Section 6.1.3 for costs of 10w-NOx burners applied to reheat furnaces.
(9)
Bloom provided NOx emission guarantees for changing Series 1430 burners to Series 1500 and 1550.
Electronic Filing - Received, Clerk's Office, July 7, 2009
* * * * * * * * * * PC # 21 * * * * *

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