ILLINOIS POLLUTION CONTROL BOARD
August 1,
1974
COMMONWEALTH
EDISON CO.
)
PETITIONER
)
~cj,
)
PCB 74-11
ENVIRONMENTAL PROTECTION AGENCY
)
RESPONDENT
)
ORDER OF THE BOARD
(by Mr. Marder)
Motion for Extension of Interim Variance was filed with the Board
July 22, 1974.
This request stems from the filing of a Petition to
extend a variance granted by the Board on October
4,
1973, in PCB
73—40
In that matter, Edison was granted variance from Rule 3—3.112 of
the Rules and Regulations Governing the Control of Air Pollution as
it pertains to both the station and unit particulate emission
limit-
ations, and Rule 203
(g)
of Chapter
2 of the Board~sRules and Reg-
ulations, to permit the continued burning of low sulphur coal at its
Sabrooke and Waukegan stations until April
4,
1974,
subject to the
following conditions:
“1.
With respect
to Sabrooke Station:
(a)
For Unit
#4
until that unit can be shut down
for conversion to oil firing on September 30,
1973;
(b)
For Units
#3,
2, and I, until those units can be
shut down for conversion
to oil firing on November
30, ~1973, February 28,
1974, and September 21, 1974,
respectively, on the condition that in the interim
these units will be operated oni’y after all other
available Edison capacity
(excluding Powerton Units
#1-4, the fast-start peaking units, and the Wauke-
gan Station above 315 megawatts) has been placed
in service, except that any one of the units may
be operated at the minimum level necessary to pro-
vide steam for water demineralizing and heating the
station,
or to prevent stack deterioration.
“2.
With respect to the Waukegan Station:
(a)
From the station particulate limit, Rule 3—3.112
of the Air Rules, and Rule 203
(g), to allow the
use of coal at the station having a sulphur content
of
less
than
3;
and
13 —235
—2—
(b)
From the single stack emission limit of 0.60
lbs/MBtu and the site emission limit of 0,24
lbs/MBtu, Rule 3-3.112 of the Air Rules, and
Rule 203
(g),
on the condition that the total
Waukegan Station not be operated above 315
megawatts
(one-third of total rated capacity),
unless all other available Edison capacity
(including the Sabrooke Station and the Pow-
erton Units
#1-4, but excluding the fast-start
peaking units)
has been placed in service.
All of the foregoing variances
as to the Waukegan
Station are subjec’t to the following terms and
conditions:
(1)
Emissions in excess of applicable
regulatory
site and unit limits shall be permitted only
when necessary to meet peak summer demands,
system demands when outages necessitate utili-
zation
of
such facilities and
to adequately ass-
ure necessary maintenance and repair within the
system.
(2)
Within
30 days from the
date hereof, Common-
wealth
Edison Company shall submit
to
the Board
and the EPA a definitive schedule setting forth
the steps that will be taken to bring its Wau-
kegan Station into compliance with the relevant
particulate regulations applicable to both the
station and the individual units comprising the
station.
(3)
Commonwealth Edison shall submit reports to the
Agency and the Pollution Control Board stating
when the facility has exceeded 315 megawatts,
and the circumstances existing necessitating
such use.
Such reports will be submitted within
two working days.
“3.
Edison is ~
establish
a nine station network of Hi-Vol
samplers and SO
monitoring devices.
Location of the
monitoring netw~rksand all other relevant details
shall be subject to Agency direction and approval.
Daily data is
to be furnished to the Agency.
“4.
Edison shall
prepare
a
detailed analysis
of the impact,
upon Edison~sgeneration system,
if the individual un-
its at
Waukegan were shut down until such time as they
comply with existing rules and regulations.
Such an-
alysis shall include
a listing of all planned outages
for maintenance shutdowns in the Edison system, both
as to dates
of
shutdown and output of the units; all
emergency shutdowns in the Edison system; and the im-
pact of Zion production upon Edison~ssystem output.
This analysis shall be provided to the Agency by Dec-
13
—
236
ember
4,
1973,
“5.
The Board retains jurisdiction for the entry of such
further
orders
as
may
be
appropriate
for
Waukegan
based
on the submissions directed to be filed by Edison.
In
addition to the foregoing, Edison shall continue with
experimentation in the use of additives
to achieve com~
pliance
by
its
electrostatic
precipitators
and
shall
report
to
the
Agency
and
to
the
Board
such
action
as
it
has
taken
with
respect
thereto
and
the
results
ach-
ieved.
“6.
Edison
shall
post
a
$500,000
bond
with
the
Agency
by
November
4,
1973,
to
guarantee
its
performance
and
corn—
pliance with this Order.
Such bond shall be reduced
in
the following manner:
(a)
$100,000
for each unit at the
Sabrooke Station,
when it has been converted
to
oil subject to the
schedule contained
in
this order;
(b)
$50,000 when
the
duct work
modification
on Waukegan
Unit
#5
is complete;
(c)
$40,000 when the air monitoring equipment has been
installed and operated at the Waukegan Station,
and
(d)
$10,000 when the Agency receives the report required
by clause
4 of this variance order.”
On November 29,
1973, the Board issued a Supplemental Order amending
portions of the October 21,
1973, Order as follows:
“A.
By amending Section
2
(b)
relating to the Waukegan Station
to read:
~From the single stack emission limit of 0.60 lbs/MBtu and the
site emission limit of 0.24 lbs/MBtu, Rule 3—3.l12 of the Air
Rules, and Rule 203
(g),
on the condition that the total Waukegan
Station not be operated
above
355 megawatts
(the minimum loadings
not requiring the use of distillate oil) unless all other avail-
able Edison capacity (including the Sabrooke Station and Powerton
Units
#1-4 but excluding the fast—start peaking units) has been
placed in service.
“B.
By amending Subsection
3, one
of the paragraphs containing
terms and conditions
of
the Waukegan Station variance to read:
VEdison is to establish a nine station network
of
Hi-Vol samplers
and SO2 monitoring devices,
Locations of the monitoring networks
and all other relevant details shall be subject to Agency dir—
ection and approval.
Daily data
is to be furnished by the Agen-
cy.
Once the network of monitoring stations has been placed in
service, the limitation on the operation of the Waukegan station
herein specified shall be suspended to allow the accumulation
of
13
—
237
—4—
relevant
data
to enable the Board
to better evaluate the actual
effects
of
Waukegan
Station
emissions
on
ambient
air
quality.
If either 24 or
3 hour SO7 and particulate air quality standards
are
exceeded, Edison shall immediately notify the Agency and take
necessary steps
to
protect the surrounding citizens as Edison or
the Agency deem necessary.
This suspension only applies during
testing
periods.
“C.
By amending Section 1
(b)
relating to the Sabrooke Station to
read:
~For Units
#3,
2,
and 1,
until those units
can be
shut down for
conversion ~Eooil firing
on
January
1,
1974,
May
1,
1974, and
September 30,
1974, respectively,
on the condition that in the
interim these
units will be Operated only after all other avail-
able
Edison capacity
(excluding Powerton Units #1-4,
the
fast-
start peaking units, and the
Waukegan Station above 355
mega-
watts) has
been
placed in service, except that any one
of the
units may be operated
at
the minimum level necessary to
provide
steam for water demineralizing and heating the station, or
to
prevent stack deterioration.~
On January
4, 1974, Edison filed its petition in PCB 74-11, request-
ing extension of the variance granted in PCB 73-40 until October
15,
1974,
so a~to operate the units in question.
This matter was set for hearing and was
consolidated
with PCB 74-16
for hearing purposes.
On April 14, 1974, the Board issued an order
granting
an
interim var-
iance to Edison until May 29,
1974,
(1)
extending the variance
granted
in PCB 73-40 and amended on November 29, 1973, relating to the Waukegan
Station, and
(2) the variance granted for the
Sabrooke
Station and the
shutdown order for the Sabrooke Station.
On
May
29,
1974,
a
second
interim
va±-iance was
granted extending the
abovementioned
variance
until
August
4,
1974.
The
shutdown
date
for
the
Sabrooke
Station
was
also
moved
out
until
August
21,
1974,
In the
instant
motion
Edison
requests
another
interim
variance
for
Sabrooke
and
Waukegan.
Sabrooke
Unit
#4
has
been
converted
to
oil,
and
on
June
18,
1974,
the
Federal
Energy
Office
confirmed its oral permission for use of oil
in this unit,
The F.E.O. also authorized Edison
to proceed
with con-
version of Sabrooke Unit #3 to oil.
Edison has received no reply
to its latest request for permission
to
convert
Units
#1
and
#2
to
oil.
Edison estimates a shutdown of 12 weeks in
order to convert
Units
1,
2,
and 3 to oil.
Pertaining to Unit
#3 Edison alleges
it did not have
adequate time for conversion before the peak summer load period.
Edi-
son feels that the three Sabrooke units should be allowed to continue
through the peak summer
months,
in order
to
insure adequate capacity.
13
—
238
—5—
Therefore
Edison
is
requesting
the
shutdown
date
for
Units
1,
2,
and
3
and
variance
be
~fl~~ed
until
October
4,
1974.
On April 17, 1974,
Edison
placed into operation its
Waukegan
Air
Monitoring
network,
as
per
Board Older
of
October
4,
1973.
Edison
all-
eges
and
submits
as
proof
monitoring
results
which
show
that
there
have
been
no
violations
of
the
primary
and
secondary
502
antient
air
stand-
ards.
Data
on particulates
are
not
yet
available.
The
hearing
record in
this
case,
as
well
as
the
record
in
PCB
74-16,
will
be
available
to
the
Board
no
later
than
August
15,
1974.
The
Board has
grave
doubts
about
granting
this
variance
•
First,
it
should
be
noted
that
the
Board
is
very
much
concerned
over
the
fact
that
there
has
been
no
data
submitted
on
particulate
emissions
•
One
~f
the
major
factors
in
granting
the
original
variance
was
the
indicatio.
that
we
would
have
this
data
available
for
the
Agency
and
the
Board’s
information
during
the
period
of
this
variance
and
thereafter.
The
Board
fully
expected
to
receive
this
data.
The
instant
Motion
nowhere
gives
any
facts
that
would mitigate
Edison’s
failure
to
have
this
data
available.
Secondly,
the
Board is
very
concerned
with
the
delay
in
completing
the,
record
in this
matter.
When
matters
are
con-
solidated,
it
is
to
provide
a
more
expeditious
resolution
of
the
pro-
ceedings.
The
Board is
not
pleased
with
the
practice
of
granting in-
terim
variances
without
a
proper
record
as
a
condition
for
a waiver
of
the
90-day
requirement,
and this
practice
will
be
greatly
limited
in the near future.
The
Board will
grant
Edison’s
request
for
interim
variance.
This
decision
is
based
on
two
main
facts:
1.
The
Board notes
the
delay
and difficulty
Edison
has
en-
countered
in
attempting
to
gain
approval
from
the
F
•
E
•
0.
to
convert
Sabrooke
to
oil.
We
are
also
cognizant
of
the
peak
load
season
which
is
presently
upon
us.
2
•
The
Board
does
not
have
available
a
complete
record of
the
proceedings,
and
as
such
is
precluded
frqm
rendering
a
reasoned
decision
as
to
the
ultimate
disposal
of
this
action.
This
Board
action
is
then
based
on
our
desire
to
provide
Edison
an
opportunity
to
submit
full
inform-
ation
for
our
consideration.
The
Variance
granted
herein
is
an
extension
of
Variance
from the
substantive regulation until October
4,
1974,
for
Rules
3-3.112
and
203
(g)
as
they
apply
to
the Sabrooke and Waukegan Stations.
The
shut-
down
date
for
the
Sabrooke
units
in
question
will
also
be
extànded
un-
til
October
4,
1974.
All
other
conditions
ordered .in
PCB
73-40
and
last
extended
on
May
29, 1974, are still in full force.
If evidence
were
to
indicate
that
Edison
has
failed
to
comply with
conditions
to
13—239
—6—
PGB 73—40 from which variance was never extended
(e.g., operation
and
submittal
of
particulate
data)
Edison
would
be
subject
to
enforce-
ment
action.
The
Board
again
emphasized that the
availability
of
air
quality
data
was
a key consideration in the original
variance
grant.
This
pro-
vision was specifically included to allow for public notification of
high pollutant levels, and to allow the Agency and Edison to take im-
mediate corrective actions.
By not supplying such information Edison
made this decision much more difficult for the
Board.
This Board will
carefully
review
the
complete
record
in
PCB
73—li
to
ascertain
why
such
data
was
not
available.
ORDER
IT
IS THE ORDER of the Pollution Control Board that interim variance
is granted from Rule
3-3.112
of
the Rules and Regulations Governing the
Control of Air Pollution and Rule 203
(g)
of Chapter 2, Air Pollution
Regulations,
until October
4,
1974, and the shutdown date for Sabrooke
Units
#1,
2, and 3 is extended until October 4,
1974.
Mr. Dum?;lle dissents.
I, Christan L. Moffett,
Clerk of the Illinois Pollution Control
Board,
certify
that
the
above
Order
was
adopted
by
the
Board
on
the
1st day of August, 1974, by a vote of
4-1.
kcL~
13—240