ILLINOIS POLLUTION CONTROL BOARD
May 15,
1975
PROPOSED AMENDMENTS TO CHAPTER
2,
)
AIR POLLUTION REGULATIONS FOR
)
R72-18
GRAIN
HANDLING
AND
GRAIN DRYING OPERATIONS
)
INTERIM
ORDER
OF
THE
BOARD
(by
Dr.
Odell)
On January 28,
1975, the Illinois Pollution Control Board
(Board) published on pages 21 to 33 of Environmental Register
No.
97 a proposal
in the above matter for public comment.
That
proposal was based upon a previous draft proposal by Joint IEPA-
Grain Industry Task Force and evidence submitted during hearings.
On the basis of comments concerning the proposal published
in Environmental Register No.
97 and further study of the record,
the Board hereby publishes for further public comment three pro-
posed changes in language in this proposed Regulation.
Change
1.
Add the Galesburg
MPA
because of large emissions
from
two grain ha~Tingoperations and air quality considerations
which
are discussed below.
Insert the following statement on page
~3
of
Environmental Register No.
97, under “Major Population Area”,
~:fter
the description of the “Rock Island, Moline area.”
“The area within the municipalities of Galesburg and
East Galesburg, plus a zone extending two miles beyond
the boundaries of said municipalities”.
Amendments to the original Task Force proposal were submitted
by
the
Illinois Environmental Protection Agency
(Agency)
on July 9,
1974,
during the hearing at Galesburg, Illinois.
These Agency
amendments included mandatory controls, irrespective of complaints,
in major metropolitan areas
(MMA’s)
as defined in the Illinois Air
Pollution Regulations, Chapter
2.
The intent was to minimize the
air quality impact of grain handling emissions in areas where the
quality of the air
is of concern and where the population is most
dense
(R.
464—467).
It was estimated that between
90
and 100
elevators would be subjected to the mandatory controls based on
their size being greater than
2 million bushels yearly throughput
and their location being within a MMA
(R.
503).
During the next hearing on July 17, l97A, near LaSalle-Peru,
Illinois, the Agency refined the MMA’s
to more concentrated major
population areas
(MPA’s) with smaller geographic areas.
The manda-
tory controls are imposed on elevators whose annual throughput is
greater than
2 million bushels per year and which are located in
major population areas
(MPA’s).
The MPA’s are defined in Rule 201
and are shown on Exhibits 27,
44,
and 45.
Their configurations
are intended, according to the Agency,
to “protect those areas
containing major population centers of the state, and where we had
17—65
—2—
air quality problems or potential air quality problems”
(R.
1044
—
August
5,
1974).
The refinement was intended to include the
majority of the people within the
MMA’s
without including rural
areas where mandatory controls may, not be necessary.
In partic-
ular,
the Agency cited situations of grain elevators located
30
miles away from cities that would be included in the MMA’s, which
are county-wide designations, but whose air pollution impact on
the cities would not be
a problem
(R.
831).
Therefore,
the
Agency devised the MPA’s which,
in most cases outside of Chicago
and St. Louis Metro-east, were city limit plus one—mile buffer
zone designations.
The locations of the major grain elevators,
those greater than
2 million bushels annual throu~hput,are ~hown
on Exhibit 28 as green circles for locations outside city limits
but within
MMA’s.
There are
30 elevators indicated on Exhibit 28
which would not be subjected to mandatory controls using the
MPA
concept that would be using MMA’s.
With the further refinement at the final hearing on August
5,
1974,
in Chicago, the percentages of people within NMA’s that
include MPA’s are as follows
(R. 828—830, 1138—1139)
Major Population
Percentage of
Area
(MPA)
population protected
Chicago
98
Rockford
65
Rock Island-Moline
80
Peoria
73
Pekin
70
Bloomington-Normal
64
Champaign-Urbana
58
(Ex.
27)
Decatur
75
Springfield
63
St. Louis Metro-east
88
The air quality concern within the MPA’s is justified based
on an examination of 1973 air quality data.
Exhibit 50 shows the
1973 annual average particulate levels for 136 locations within
Illinois
(58 within Cook County)
as reported by the Agency.
At 56
locations
(30 within Cook County), the annual mean primary air
quality standard of 75 ).lg/m3 was exceeded.
Of these locations
where the air quality violated the standard in 1973, only 4 are
not within the designated MPA’s.
The four locations are Galena,
Quincy
(2 sites), and Metropolis.
Based on current sampling
locations,
the MPA’s do include areas where air quality is of con-
cern and where emissions from grain handlign facilities should be
minimized.
The reduction in geographic area from MMA’s to MPA’s reduces
the number of elevators subjected to mandatory emission controls.
Exhibit 53 includes the Task Force inventory of grain handling
facilities larger than
2 million bushels annual throughput located
in MPA’s.
According to this information there are 33 of these
grain handling facilities,
of which 16 will be required to install
emission controls according to the Agency.
The other 17 are con-
sidered by the Agency to already have adequate controls.
17—66
—3—
The major grain handling emitters of particulates
should
also be checked in relation to the MPA’s.
Exhibit 17
is the
Agency emission inventory which is
a state-wide ranking of
emitters of pollutants.
The Agency was asked to investigate
whether the largest emissions of particulates
from grain handling
facilities would be subjected to mandatory controls.
Their res-
ponse is included in Exhibit 53, and it shows that only 21 of the
50 largest (2
million bushels annual throughput) grain handling
emitters are within MPA’s as then defined.
The other
29 large
emitters, each with estimated emissions greater than 1,000 lbs/hr
(Exhibit 17), would be controlled only of complaints occurred.
In
particular, the second and fourteenth largest emitters of parti-
culates from grain are located in Galesburg and together emit an
estimated 1,443 lbs/hr particulates.
A citizen has objected to
these particulate emissions for several years
(R.
690-693).
These emissions probably contributed sig~ificantlyto the 1973
annual mean particulate level of 66 ,~ig/m
in Galesburg, which
places it 36th among
78 in the state-wide ranking
(outside of
Cook County
-
Exhibit 50).
This indicates that Galesburg should
be included as an MPA for the purposes of this Regulation.
Gales-
burg is larger
(approximately 36,000) than Kankakee (approximately
31,000)
and its 1973 annual particulate level
(66 jig/mi)
also ex-
ceeded that of Kankakee
(60
jig/m3 based on the Bradley reading).
With our addition of Galesburg to the MPA’s, we believe that proper
protection of air quality in populated areas will be achieved.
Change 2.
Change the zone of one mile to two miles beyond
the mu~6~alitiesincluded in the respective MPA’s
(as defined
on pages
23 and 24 of~EnvironmentalRegister No.
97)
to increase
the protection of residents within the densely populated municipal-
ities so specified.
Measured emissions from a large grain elevator
and calculations from these data indicate that more than a one-
mile buffer zone around municipalities in MPA’s is needed to ade-
quately protect residents of such areas from particulate emissions
from large grain handling facilities around the perimeter of these
municipaliti~.
Long-term emissions were measured for seven operations at a
Kansas City terminal elevator using weekly totals over a 6—month
period (Exhibit 43).
The seven operations are: rail car unload-
ing, truck unloading, rail car loading, cleaning, transferring
(gallery belt), transferring
(tunnel belt)
and the headhouse.
Short-term emissions were measured at the same elevator for indivi-
dual operations of truck unloading, car unloading, and car loading.
The emissions measured were those collected by the baghouse emis-
sion contro’ systems and the results are conservative since not
all emissions from the various operations were captured.
The
elevator handled various mixes of four grains
(milo, wheat, corn,
and soybeans) during the 6-month testing period, and while the
long-term results did not show a dependence on type of grain
handled, the short-term results did.
Emission factors
(particulate emissions per weight of grain
handled) were calculated using the throughput records kept by the
elevator.
The weekly results varied significantly from week to
17 —67
—4—
week but it
is felt that the long-term averages give
a true in-
dication of the emissions.
The long-term average emission
factors and their comparison with AP-42 “Compilation of Air Pol-
lution Emission Factors”
(Exhibit 24) are listed below:
Emission factors
(lbs/ton)
Exhibit 43
AP—42
Truck unloading
0.64
1
Car unloading
1.30
1
Car loading
0.27
1
Corn cleaner
5.78
5
Gallery belt
0.11
Tunnel belt
1.40
2*
Headhouse
1.49
—
*
Value is for transferring, conveying, etc.
In actual elevator operation several operations occur sequentially.
For example, unloading a truck would be followed by elevation of
the grain to the headhouse,
and transfer onto the gallery for
storage,
so that the overall emission factor for this activity
would be 0.64
+
1.49
+
0.11
2.24 lbs/ton.
Short term emission factors show a dependence on the type
of grain and whether loading or unloading, as
is shown below:
Truck unloading
Car unloading
Car loading
(lbs/ton)
‘(lbs/ton)
(lbs/ton)
Soybeans
1.63
1.51
0.44
Milo
0.95
1.08
0.29
Corn
0.47
0.62
0.28
Wheat
0.25
0.50
0.17
Evidence presented during the hearings indicated the impact
on air quality, including adverse health effects
(Exhibit 3), of
particulate emissions from grain handling facilities.
The Agency.,
in Exhibit 55, used dispersion modeling to estimate the contribution
to the ambient particulate level from a typical grain elevator.
The
elevator was assumed to have an annual throughput of 2 million
bushels, and particulate emissions
(uncontrolled) based on the
Kansas City study, Exhibit 43.
Hourly and daily maximum ground
level particulate concentrations were calculated for points at
various distances from the elevator for various combinations of
atmospheric stability and windspeed.
The following table summarizes
the results of
the calculations:
17
—
68
—5—
Distance
Maximum hourly
Average 24—hou:~
from elevator
concentration
concentration
miles
jig/mi
pg/mi
0.50
2,547
425
0.75
2,061
290
1.00
1,621
208
1.25
1,327
150
1.50
1,125
117
Notes:
1.
The 24-hour primary standard is 260 pg/m3.
2.
The concentrations calculated are contrib-
utions from a single source and do not
include background levels.
These results show that uncontrolled elevators may have
a signif-
icant impact on air quality at distances greater than a mile, and
thus we must question the use of a one—mile buffer zone in the
designations of MPA’s as prc~posedby the Agency.
As pointed out
in Exhibit 55, the ground level concentrations are directly pro-
portional to the emissions, and via the emission factors
to the
size of the grain handling facility.
For example, uncontrolled
emissions from an elevator having an hourly rate of 20,000 bushels
(roughly equivalent to an annual throughput
of
4 million bushels)
would result in a 24—hour ground level concentration of 300 ~ig/m3
(which exceeds the primary standard)
at 1.25 miles, and 234
jig/rn3
at 1.5 miles.
One way of analyzing the potential impact of elevators is
to calculate the distances one would have to be located from
elevators
of certain sizes
such that the 24—hour primary standard
of 260 pg/rn3 was not violated.
The following table uses the in-
formation and assumptions of Exhibit
55 to show the spatial impact
of large elevators:
Annual grain throughput
Distance to meet
of elevator
primary standards
millions of bushels
miles
2.0
0.83
2.5
1.0
4.4
1.5
9.0
2.0
15.0
2.9
20.0
3.5
Since the above calculations do not include background pollution
levels, the distances should be considered minimums in terms of
protecting people from the potential health effects
(at the 260
pg/rn3 24—hour primary standard)
of emissions from these large
uncontrolled grain elevators.
Based on the above analysis, the
one-mile buffer zone specified in the designations
of MPA’s by
the Agency is not sufficiently large since it will only offer
17 —69
—6—
protection to people from uncontrolled elevators not larger than
2.5 million bushels annual throughput.
In order to provide increased protection to citizens from
large uncontrolled elevators,
it is therefore necessary to in-
crease the spatial coverage in defining MPA’s beyond that propos-
ed by the Agency.
We do this by increasing the buffer zone
around the municipalities included in the definition of MPA from
one mile to two miles. This will then, according to the above
table, protect people from the uncontrolled emissions from grain
elevators of up to
9 million bushels annual throughput in size
rather than 2.5 million bushels annual throughput.
Change
3.
Rule 203(d) (9) (3) (iv) (c) (3)
on page
28 of
Environmental Register No.
97.
In
a letter received by the
Board on February 25,
1975,
from the Chicago Regional Port
District it was indicated that the trimming machine portion of
their two lessees’ operations which convey grain to the corners
of vessels could not comply with this Rule.
Closure of the
hatches of such vessels while filling them with trimming machines
would create combustion hazards for men and property.
Until tech-
nology
is shown to be available to load such ships by improved
methods, the removal efficiency requirement of particulates from
trimming machines will be reduced below 98.
On the bottom of
page
28, at the end of Rule
203(d) (9) (B) (iv) (c) (3), add after
“atmosphere”;
“except for the portion of grain loaded by trimming
machines for which particulate matter emission reductions,
at a
minimum,
shall equal the reduction achieved by compliance with
subpart
(iv) (c) (2) herein.”
Public comment will be received until June
5,
1975, concern-
ing the three changes proposed herein.
ORDER
The Illinois Pollution Control Board hereby proposes the
following changes in R72-18, Proposed Amendments to Chapter
2,
Air Pollution Regulations for Grain Handling and Grain Drying
Operations:
1.
On page 23 of Environmental Register No.
97, add the
following “Major Population Area”:
“The area within the municipalities of Gales-
burg and East Galesburg,
plus a zone extending
two miles beyond the boundaries of said
municipalities.
2.
On pages
23 and 24 of Environmental Register No.
97,
in the definitions of each appropriate “Major
Population Area”, change “one mile beyond the
boundaries
of said municipalities”
to “two miles
beyond the boundaries of said municipalities.”
17
—
70
—7—
3.
On
the
bottom
of
page
28,
at the end of Ri~e
203(d) (9) (B) (9v) (c) (3)
,
add after “atmosphere”;
“except for the portion of grain loaded by
trimming machines for which particulate matter
emissions,
at a minimum, shall equal the reduct~
achieved by compliance with subpart
(iv) (c) (2)
1
~r~in.
4.
Comments concerning these proposed changes will
~
received by the Board until June
5,
1S75.
IT IS SO ORDERED.
I,
Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was adopted
on the /,.r~dayof May,
1975,
by a vote of
h-cD
~
Christan L. Mo~f~tt,Cthrk
Illinois Pollu&i~onConticl :oa~J
17 —71
R72—18
GRAIN
HANDLING
&
GRAIN
DRYING
OPERATIONS
Mr.
Herbert
Hoemann
Executive
Vice
President
Grain
& Feed Assoication
1035
Outer
Park
Drive
Suite
104
Springfield,
Illinois
62704
Mr.
L.
Carlton
Anderson
Cargill,
Inc.
P.O.Box 189
Tuscola, Illinois 61953
Mr.
John
Troyer
Farmers
Grain
Company
Chestnut, Illinois 62518
Mr. Lyndel Johnson
The Pillsbury Company
P.O. Box 12
Springfield, Illinois 62705
Mr.
Ron Linnick
Environmental Protection Agency
200 West Washington Street
Springfield, Illinois 62706
Mr. W.J. Krupps
Consumers
Grain
&
Supply
Company
75 Maple
Galesburg,
Illinois 61401
Mr.
John Beatty
Route
1
Waverly, Illinois 62692
Mr. Royce
Huss
Huss
& Schlieper
2230 N.
Brush College Road
Decatur,
Illinois 62525
17
—
72