Department

of

Energy

Argonne

Site

Office

9800 South Cass

Avenue

Argonne, Illinois

60439

0

6

JUL

2009

CLERK’s

OFF!CE

Clerk’s

Illinois Pollution

Office

Control

Board

JUL

08

2009

100

W. Randolph

Street,

Suite 11-500

STATE

OF

ILLINOIS

Chicago, Illinois

60601

Pollution

Control

Board

Attn:

Docket R08-19

Dear Sir/Madam:

SUBJECT:

COMMENTS ON THE

PROPOSED

NO

REASONABLY

AVAILABLE

CON

ROL

TECHNOLOGY

(RCT) RULE

The

U. S. Department of Energy

and the Argonne

National Laboratory

(Argonne)

submit the following

comments

on the proposed

amendments to

35

IAC Part

217

to address oxides

of nitrogen

(NO)

emissions

from industrial boilers

and other

emission

sources,

as published in the

May 22, 2009

Illinois

Register:

We have identified

a number of inconsistencies

with

respect to industrial

boilers (Subpart

E)

with a rated

heat input

capacity of less than

or equal to 100

mmbtu/hr. These

inconsistencies

relate to proposed

requirements

for

performance

testing, continuous

emission

monitoring systems

(CEMS), and

predictive

emission monitoring systems

(PEMS).

Industrial boilers at this

rating

are required

to meet

combustion

tuning

as

specified

in Section

217.166,

rather than

a numeric NOx emission

limit.

As currently

proposed, Section 217.154(a)

requires

performance

testing

for all industrial

boilers

regardless

of size, unless they

employ CEMS.

For

boilers less than

or equal to

100

mmbtu/hr

rated

heat

input

demonstrating compliance

through

an emissions averaging

plan and

not using

CEMS,

Section

217.157(a)(4)

requires

performance

testing,

but that section

does not address

boilers less than

or equal

to 100 mmbtu/hr rated

heat input where

emissions averaging

is not used.

Section 217.157(a)(5)

indicates

that boilers less than

or equal to

100 mmbtu/hr rated heat

input may

use

CEMS

in place

of emissions

averaging

under

Section 21

7.57(a)(4),

but since there

is no numeric

NOx limit

specified for

such boilers

in

Section 217.164, the use

of CEMS would

appear to be of little

value.

Similarly,

the

use of

PEMS

specified in Section

217.157(f)

for boilers

less than or equal

to

100 mmbtu/hr

rated

heat

input

to show

compliance to

a

non-numeric

limit (combustion

tuning)

would also

seem unnecessary.

We request

that

these inconsistencies

be clarified

prior

to issuance

of the final rule.

In addition,

Argonne

has

two suggested

revisions

to the

proposed rule for

industrial boilers

with

a rated heat

input less

than

or

equal to 100 mmbtu/hr,

where the various

entries of

the table

in Section

217.164

specify

that

combustion

tuning is required

(versus

e.g. the

0.08 lb/mmbtu

NO

limit for gas-fired

boilers greater

than 100

mmbtu/hr

rated heat input).

First,

Argonne

suggests that

performance testing

not

be required,

and second,

that the

use of

CEMS

or PEMS

also not be required (although

this

could

be

employed

at the

option

of the

facility,

e.g., if

the facility chose to

use emissions

averaging).

If you

have questions

regarding these

comments, please

contact

Ken

Chiu

of my staff

at

(630)

252-2376.

Sincerely,

Ronald J. Lutha

Site

Manager

cc:

G.

Barrett,

ANL/ESQ,

201

A component

of the Office

of

Science