ILLINOIS POLLUTION CONTROL BOARD
    October
    4,
    1974
    CENTRAL ILLINOIS PUBLIC SERVICE
    )
    )
    v.
    )
    PCB 73-185
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    Mr. Thomas Cochran of Sorling, Catrone ~ Hardin, appeared for
    Central Illinois Public Service;
    Mr. Deibert
    B. Haschemeyer, Assistant Attorney General, appeared
    for Environmental Protection Agency.
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dume lie):
    Central
    Illinois Public Service
    (CIPS) filed
    a Petition
    for Variance with the Environmental Protection Agency
    (Agency)
    on May
    2,
    1973.
    The Agency filed
    a recommendation on June 21,
    1973,
    approving
    the variance subject
    to certain
    conditions.
    A
    hearing was held on July
    23,
    1973,
    at which time
    the parties
    submitted
    a stipulation.
    CIPS operates
    an electric power generating station known
    as
    the Meredosia Station located near Meredosia, Illinois.
    CIPS
    seeks
    a variance from Chapter
    2,
    Part
    II,
    Rule
    204(e)
    of the
    Pollution Control Board Rules
    and Regulations
    (Air Rules)
    to
    allow the continued use of high sulfur coal
    in its boilers.
    CIPS
    is currently in compliance with the 6.0 lb/MBTU emission
    standard
    (Rule
    204(c)(1)(B)(i)
    of
    the Air Rules).
    However,
    under an elevated temperature inversion,
    emissions from CIPS
    short stacks
    could
    result in
    a violation of Rule
    204(e)
    of the
    Air Rules
    in that the site emissions
    from the Meredosia Station
    could violate the
    1300 ug/m3 three-hour SO2 secondary standard.
    In order to achieve compliance, CIPS would have
    to spend
    $2,000,000
    to construct higher stacks for its boilers.
    CIPS
    is currently complying with the particulate emissions
    requirements
    of Rule
    3-3.112
    of the Rules
    and Regulations
    Governing th~Control of Air Pollution and has filed
    a compliance
    with Rule 203(g) (1) (c)
    of the Air Rules, which shows
    that
    it
    will meet the 1975 deadline on February
    1,
    1974.
    Thus
    the
    synergistic effects of SO2 and particulates
    should be
    at
    a
    minimum.
    The Agency has not received any public criticism con-
    cerning the operation of the Meredosia Station.
    9— 403

    -2-
    While
    the Petitioner has not come forth with
    a definite plan
    to bring the SO2 emission into compliance, the Board feels
    that the
    variance
    should
    be
    granted.
    The
    forecasted
    violation
    of
    the
    secondary standard will only occur when the station is
    at peak
    load,
    is
    burning
    3
    sulfur
    coal,
    and
    an
    elevated
    temperature
    inversion
    exists.
    The
    likelihood
    of
    all
    three
    occurring
    simultaneously
    is
    small.
    Moreover, both CIPS’
    and the Agency’s dispersion models,
    that predicted
    a violation of Rule 204(e),
    have not been calibrated
    to observed air quality,
    since no
    data
    is
    available
    at
    the
    Meredosia
    site.
    CIPS and the Agency have agreed to CIPS!
    establishing a
    sulfur dioxide monitoring program for its Meredosia Station, details
    of which were set out in the stipulation
    as follows:
    115
    CIPS will establish
    a sulphur dioxide
    (S02) monitoring
    program for its Meredosia Power Station, Meredosia,
    Illinois,
    to
    include
    the
    following
    equipment
    and
    procedures:
    a.
    Three
    continuous
    S02
    monitoring
    stations
    with
    instruments
    approved
    by
    the
    Agency.
    b.
    One
    meteorological station
    to measure wind speed
    arid direc-
    tion with continuous
    recording.
    This station
    is
    in existence and its
    equipment and location have been approved by the Agency.
    c.
    The equipment in a and h above will he maintained and cali-
    brated in accordance with methods acceptable
    to the Agency.
    The
    three S02 monitoring sites will be located in a northeasterly direction
    from Meredosia Power Station
    at approximately 1/4 mile,
    I
    to
    1-1/4
    miles and
    2
    to 2-1/2 miles from that station,
    The exact
    sites will
    be approved by the Agency after permission by property owners
    is
    secured by CIPS
    to allow utilization of their property for S02 monitoring.
    d.
    Necessary equipment,
    including the necessary monitoring
    devices, will be ordered within 10 working days
    after receipt
    of any
    Order from the Pollution Control Board granting the variance.
    e.
    Equipment wilil
    be installed and placed
    in service within
    10
    working days of receipt of all equipment,
    providing
    an approved site
    is available
    as in
    c above.
    f.
    Monitoring data from the stations mentioned in
    a and b above
    will be made available
    to the Agency on
    a monthly basis.’1
    This monitoring system should allow the comparison
    of the
    predicted levels with those actually occurring.
    This Opinion constitutes the findings
    of fact and conclusions
    of
    law of the Board.
    ORDER
    The Pollution Control Board hereby grants CIPS
    a variance from
    Rule
    204(e)
    of the Air Rules until
    October
    4,
    1974,
    subject to:
    9— 404

    -3-
    1.
    CIPS shall
    establish the agreed to SO2 monitoring
    program
    as
    set out
    above.
    2.
    CIPS
    shall
    post
    a
    $5,000
    bond
    with
    the
    Agency
    by
    November
    1,
    1973
    to
    guarantee
    its
    compliance
    with
    this Order.
    IT
    IS
    SO ORDERED.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control Board,
    certify that the abov
    Opinion and Order was adopted b
    the Board on
    the
    2/~
    day of
    ______________,
    1973, by
    a vote
    of
    ______
    to
    0
    (~Jt~t~~f7)
    9— 406

    .
    .

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