ILLINOIS POLLUTION CONTROL BOARD
January
4,
1979
IN THE MATTER OF:
PARTICULATE EMISSION
)
R77-5
STANDARDS FOR COMBUSTION
OF LOW CARBON WASTES
)
OPINION AND ORDER OF THE BOARD
(by Mr. Dumelle):
This proceeding to amend Rule 203(e)
of the Board’s Air
Pollution Control Regulations was initiated by
a Petition filed
with the Board on March
3,
1977.
The Petition was published
in Environmental Register 4~l45dated April
11, 1977.
Hearings
were held on August
30,
1977
in Charleston, Illinois and October
18,
1978
in Chicago.
A document entitled An Economic Impact Study
of Low Carbon Wastes
(R77—5)
(IIEQ Document 78/06)
(Ex.
L) was
submitted to the Board pursuant to
§6(d)
of the Environmental
Protection Act.
Hearings on the document were held on July 28,
1978
in Streator,
Illinois and August
7,
1978 in Chicago.
At the first hearing the Petitioner, Addressograph-Multi-
graph Corporation,
presented an Amended Petition
(Ex.
A) which served
as the basis
for all subsequent proceedings.
This Opinion references the record with roman numerals
(RI-b,
Rh—iS,
etc.).
This system was used because the page numbering
was not continuous.
The roman numerals refer to individual hearing
transcripts.
NEED FOR THE REGULATION
Petitioner’s dilemma is best described on pages 12-17 of
Exhibit L.
Under the present Rule 203(e) (4) Petitioner must
meet a particulate emission standard of 0.1 grains per standard
cubic foot of effluent gases corrected to 12
carbon dioxide.
Exhibit
2
(summarized in Table
1.1 on page
13 of Ex.
L)
shows
that as the percent of carbon dioxide in the exhaust gas decreases,
the corrected particulate emissions increase.
Since Petitioner’s
exhaust gas averages
0.0146
carbon dioxide, corrected emissions
are exaggerated by calculation to 74.25 grains per standard cubic
foot.
As an alternative Petitioner proposes a correction of 50
excess air for new incinerators burning not more than 2000 pounds
of waste per hour containing dry basis volume concentrations of
less than 1.2
carbon dioxide from the waste alone.
The 2000 pound limitation includes Petitioner’s
incinerator.
The 1.2
limitation represents ORSAT measurement limits
(R..II-24).
The Agency contends that Petitioner cannot comply with the
32—40.3
—2—
present Rule
203(e)
because of the aqueous nature of its waste
(R.III-63)
.
Mr. Moore testified that the 12
carbon dioxide
correction should be retained because
it is appropriate for patho—
gen burners cornbusting waste high in hydrogen
(R.II—64).
This
conclusion conflicts with Exhibit E which states that a 50
excess
air correction would be sufficient for all incinerators.
Since
the record
is limited
to an analysis of Petitioner’s incinerator,
and the request for relief is narrow, the Board will limit its
decision to the relief requested.
EFFECT ON AIR QUALITY
Exhibits H,
I, and K indicate that although this regulation
would have statewide effect, Petitioner’s incinerator
is the only
known affected source.
Particulate emissions from this source
have been calculated at 1.163 pounds per hour
(R.I-29).
The
nearest air monitoring
site
is
50 miles away in Champaign and it
shows compliance with the particulate air quality standard and
no upward trend
(R.II-22)
.
Chapter
4, Section 4.1 of Exhibit L
concludes that air quality within the vicinity of Petitioner’s
incinerator is
“.
.
.
safely within the applicable air quality
standards.”
Complete elimination of Petitioner’s emissions would
at most lower the local 24-hour air quality level by about 0.5
micrograms per cubic meter and the annual level by a maximum of
0.14 micrograms per cubic meter
(p.66)
.
These effects can best be
described as negligible.
TECHNICAL FEASIBILITY AND ECONOMIC
REASONABLENESS
Exhibit F contains a copy of the ten feasibility studies
which were done by Petitioner before
it decided to install its
present incinerator.
All of the alternatives to the present system
either had problems with the nature or the volume of the waste,
were unreliable,
or were not adaptable to the climate of the
Charleston area.
Chapter
3 of Exhibit L estimates the costs for various
control options which are assumed to be sufficient to result
in
compliance with the present Rule 203(e).
Table 3.5 shows a range of
total additional annual costs from $14,419
to $137,280.
Table
5.1
shows that all of these options greatly exceed a conservatively
high estimate of benefits which would accrue from the reduced
emissions.
The
range here was $6,717 per year to $129,578 per year.
consequently, the Board concludes that adoption of this
proposal will have no adverse economic impact on the people of
the State of Illinois.
This Opinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
32—404
—3—
ORDER
Rule 203(e) (4)
of the Board’s Air Pollution Control
Regulations
is hereby amended by the addition of
a new section
which shall
read as follows:
(A)
Rule
203(e) (4)
shall not apply to aqueous waste
incinerators which, when corrected
to 50 per cent
excess air for combined fuel and charge incineration,
produce stack gas containing carbon dioxide dry-basis
volume concentrations of less than 1.2 per cent from the
charge alone;
if all the following conditions are met:
(i)
The emissions of particulate matter
into the atmosphere from any such new
or existing incinerator does not exceed
0.1 grains per standard cubic
foot,
dry
basis, when corrected to 50 per cent
excess air for combined fuel and charge
incineration.
(ii)
The waste charge to the incinerator does
not exceed 2000 pounds per hour.
IT
IS SO ORDERED.
Mr. Werner concurs.
I, Christan
L. Moffett,
Clerk of the Illinois Pollution
Control Board, hereb
certify the above Opinion and Order were
adopted on the ______________day of
,
1979 by
I??
Christan L. Moffet ,~Q~erk
Illinois Pollution ~~trol
Board
32—405