ILLINOIS POLLUTION CONTROL
BOARD
January
3~
1975
COMMONWEALTH
EDISON
CO~
PETITIONER
PCB 74—16
ENVIRONMENTAL PROTE CT ION
AGENCY
RESPONDENT
MESSRS. RICHARD H. POWELL and CHARLES H. WHALEN, ATTORNEYS, ISHAM,
LINCOLN & BEALE, in behalf of
COMMONWEALTH EDISON
MESSRS. MARVIN MEDINTZ and DELBERT HAS CHEMEYER, ATTORNEYS, in be-
half of the PEOPLE OF THE STATE OF ILLINOIS
MR.
MICHAEL
GINSBERG, ATTORNEY,
in
behalf of the ENVIRONMENTAL PRO-
TECTION AGENCY
OPINION AND ORDER OF THE
BOARD (by Mr. Marder)
This action involves a request for variance filed January 11,
~974, by Commonwealth Edison Co. (Edison), Petitioner, Relief is
requested from Rules 203 and 204 of Chapter 2 of the Board’s Rules
and Regulations as they apply to five Edison generating facilities.
A request is also filed for relief from Rules 103 and 104 as they
apply to project completion schedules and compliance plans. Edison
filed a motion on October 11, 1974, seeking to clarify its position.
The motion contended that, although it was not inherently clear in
the Petition, relief was also requested from Rule 3-3,112 for three
Edison stations until May 30, 1975. Said Motion asks that the plead-
ings in 74—16 be deemed to include a request for variance from Rule
3—3.ll2~. The Board finds that sufficient evidence has been generated
at hearings to rule on a 3—3.112 variance as well as a 203 variance,
and additional hearings would add nothing to
our decision. The vari-
ance
pleading will thus be deemed amended as requested by Edison.
At least in part, this case dates back to August 8, 1972, at which
time the Board denied variance to Edison for its Waukegan and Sabrooke
generating plants.
Such denial was without prejudice and Edison re-
filed for variance on January 30, 1973. The Board at
that
time grant-
ed variance for six months, conditioning the variance on plant load-
ing (variance granted until April 4, 1974)
.
This was followed by the
filing of 74-11 on January 4, 1974, seeking a six~monthextension.
Such variance was granted on Septeirier 27, 1974. The present variance
seeks,
in part, to again extend variance for one additional year. Th
above deals only with the Sabrooke and Waukegan generating stations,
whereas
PCB74-16
in total deals with
five generating stations.
As”,
further background the reader
is
referred to
the
following Board
15
—7
opinions:
Commonwealth
Edison Co. v. Environmental Protection
Age~~
PCB 72—91, 5 PCB 101; PCB 72—491—492, 73—40, 9 PCB 367; PCB 74—li,
13 PCB 235, 13 PCB 241, and PCB
74—li, Septer~ber27, 1974,
The instant Petition was filed on January 11, 1974. The separate
facilities were consolidated for hearing in a rather unique manner.
It was the Board~s feeling that much of
the
information to be generated
would be applicable to all facilities.
However, it was also mandatory
to hold hearings in the areas to
he affected by their variance requests.
This was done to allow the public the opportunity to participate at
hearing. Twenty days of hearings were held as follows:
April 2,3,5,8,9, 1974
at Chicago
April 15, 16, 1974
at Waukegan
April 18, 1974
at Rockford
April 22, 1974
at Joliet
April 25, 1974
at Kincaid
April 29, 1974
at Chicago
May 7,8, 10, 20, 1974
at Chicago
June
5,7,20,
1974
at Chicago
July 9, 11, .1974
at Chicago
At these hearings the Board feels that a complete record was entered
in this matter.
This Opinion will handle system—wide information first, and then
apply this evidence to individual plant evidence in making its decis-
ions. Before proceeding it: is imperative to tabulate as much data as
possible on the subject units. Table 1 includes such data as incorp-
orated in this Opinion.
Statement of Hardship: Edison contends that the hardship which
would be incurred should variance be denied would fall not only on it-
self but on its customers as well. This contention is based upon the
premise that should variance be denied, Edison would be compelled to
cease operations. This is not true, as pointed out by the Board and
reiterated many times over (e.g., Androck Corp. v, Environmental Pro-
tection Agency, PC3 74-3; 48 Insulation v, Environmental Protection
Agency, PCB 7 3-478 E.I. duPontv~ Environmental P~tect~Aency,
PCB 73-533), failure to grant variance is not a shutdown order but
rather a shield from prosecution. Thus Edison’s true hardship, should
variance be denied, is nothing more than being left open to an enforce-
ment action. Edison, of course, has the option of shutting down cer-
tain equipment to avoid prosecution, and this course of action would
cause hardship on Edison’s customers who depend on a steady flow of
electricity. To assess the potential hardship one must investigate
the Edison system as a unit, looking at total capacity as well as re-
quired maintenance outages.
The Edison system (in 1974) has a total capacity of 17,066 mw. This
breaks down as follows:
1. 14,016 mw of fossil and nuclear power.
2. 1,726
mw of fast start peakers.
3. 1,324
mw of purchased power.
15 —8
17,066 mw (Appelgren Ex. 3)
This capacity, due
to
ups and downs of
the various equipment and
dif-
ferentials
in sales and purchases of power through diverse exchanges,
shifts almost constantly.
The above
figures are best used for a guide,
and items (1) and (2) above reflect actual installed capacity.
Edison projects growth in its peak demands
as
well as growth in its
total system. Since these figures seem to change constantly, the Board
will not try to assess the validity of these numbers at some future date,
but will rather deal with the supply and demand in the period which this
variance request would cover. The peak load during 1975 (the area of
major concern to this proceeding) is projected at 14,900 mw. Projected
capacity for 1975 is 16,423 mw. All of these estimates lead to Edison~s
projections that, based on a 14 minimum reserve capacity, 1974 would
show a reserve of 909 mw, while 1975 would show a deficit of 392 mw
(Appeigren Ex. 4).
There is much discussion as to the validity of these numbers and
the Board concludes that if different bases are used, many different
estimates can be reached.
A typical example of this type of projection of numbers can be seen
from examination of Appelgren Ex.
1
and 4, wherein growth in peak load
is given and projected. Edison projects growth in peak load between
1974 and 1977 as 6.05, 7.6, and 7.5 respectively. The following
history can be determined from simple mathematics on the above exhibits:
Year
Actual Peak Load
Growth in Peak Load
MW
Percent
1968
8950
1969
9265
3.5
1970
10,027
7.6
1971
10,943
9.1
1972
11,750
6.9
1973
12,462
5.7
1974
14,050
12,7
1975
14,900
6.1
1976
16,030
7.6
1977
17,230
7.5
The projected increase in peak load between 1973 and 1974
is
thus pro-
jected at a very high 12.7. Mr. Appelgren (R. 75) states that the 1973-
1974 winter loads were 400 to 800 mw below what Edison anticipated,
therefore casting even greater
doubt
on Edison~s projections.
While there are many other factors which must be considered when ass-
essing figures of this nature (e.g., purchases, sales, maintenance out-
ages), a detailed description of how these numbers were generated was
not afforded the Board. We can only go by past growth rates and actual
1974 load demand to project what future demands may require. The Board~s
conclusion on this
subject is that Edison~s estimates are significantly
above
what will actually occur, and Edison~s fear of a serious hardship
on its customers should certain units be curtailed is simply unfounded.
15—9
P1~nt/enit
Jo3.ct 5
~1,
1950
Joliet 6
344
1959
J~iiet /
617
1965
Jo1i~t 8
617
196(
~abr~ ~e 1
20
1949
0
R~ooke 2
1
34
19~2
Sabroo1~ 3 35
.1953
—-
Sdhrooke 4 57
1961
Waikegan 5
1
129
1931
Wautegari 6
119
1952
~
-—~——
Waukegan
~
1
338
1958
Waukega:: 8 360
Powe~ton 5 850
Kincaici
1
616
Coal
Coal 11,481,952
Coal 49,700
Coal 113,052
Oil
N/A
Oil
N/A
1,540,214
Part.
Emiss-1 Comp
ions Plan
0
148k
U,
148
148’
400’
336’
450’
450’
MW
TAW
‘
PCB74-16__Commonwealth Edison
System Data
~Annua1
5ta~tup Date Fuel Fuel Usage1 Part.
Tons/Year Cont.
~
~‘———H——
~
Coal ~341,398
‘
ESP 0.081
Coal
502
Cont.
Comp.
Plan
330 ,646
~T5a3id~T
Comp.
Exp.
SoxIni,
Stack
Ht.
L.S .C
ESP
0.15
~SO~1nj.
L,S,CtlO/1/15 258’
ESP
LS C
.06l—.7~
LS C
SOX
Inj.
ESP
3/1/76 431’
LS C
.061— .7~
LS C
10/76
SO
In~.
Mech.
550’
LSC
LS C
1.5
Oil
10/76
Oil
Oil
Mech.
On
Oil
550’
148
FEA
prob.
2.0
Oil
Oil
Oil
FEA
prob
On
Coal
Oil
338,850
Two
ESP
0.5 onSplit
l.6S$ ductwk.
coal SO.~Inj.
Coal
291,481
Coal
981,055
LS C
ESP
ESP
LS C
12/1/7
.29 on
2.4 ~
Inj.
coal
TT,’5’~
off~’tNe~
Hot
LS coal~ ESP
196,
1~’72
1967
LS C
LSC
LS C
LS C
6/1/76
17/1/76
Coal
.
928,448
ESP
Coal 2,500,000 ESP
ccl
.1,316,616 FSP
0,4 on SO~In. LSC
LSC-SO3
.027 In corn.
.05
In corn.
In Corn.
None
None
Gas
G a~
Late
1980
1982
500’
500’
—4—
Thus, the Board finds that placing operational
constraints
on units
which impact on the environment will not create an
undue
hardship,
and
in our final Order we
will
do so,
Further complicating the situation of availability is the area of
maintenance, both planned and unexpected. Mr. Robert Engle (April 3,
Pg. 422-434, April 8, Pg. 436-499) testified
in detail as to how
Edison
plans
for maintenance. Engle Exhibits
1—4 were
entered as documenta-
tion
as to Edison’s contentions on this subject.
Edison contends that
actual outages
for its units are 41 (based on 1961-1973 data) greater
than its planned outages (R, 422), Although
on the surface this seems
like horrendous planning, it must be understood that “unplanned” out-
ages are actually anticipated when developing the system strategy.
Engle Exhibit #2 then projects the expected outages for the 1974-
1975 maintenance period and anticipates a net capacity deficit for the
months of November, December, January, February, and March. This esti-
mated deficit is including the capacity under question
in
the instant
Petition. Edison then contends that during the difficult months, Edi-
son would be forced to either institute voltage reductions or forestall
the least critical maintenance (R. 429).
In analyzing Exhibit
2,
one finds
that the projected differences be-
tween estimated overhaul and projected total outages is very much great-
er than the 41 average depicted in Engle Exhibit 1. In fact, calcula-
tions during this period reveal the following:
Month
Est. Overhaul
Total Overhauled Percent
MW
Dec. ‘74
1800
5600
211
Jan.
‘75
2500
5600
124
Feb. ‘75
2700
5600
107
On their face
these figures
are completely out of context with Edi-
son’s historical averages. On the basis of information given
to
the
Board, we can only conclude that these numbers cannot support Edison’s
contention that the capacity which is the subject of this Petition is
required to maintain the system’s integrity,
but rather we conclude
that this
capacity would serve to increase the reserve capacity in the
total system.
The overriding conclusion that the Board must draw from Edison’s
hardship plea is
that while true in part, it
is highly overexaggerated.
When considering Edison’s compliance plan, the Board will thus
not
hesi-
tate to order speedy compliance even if it requires prolonged shutdown
of individual units,
~ts
at Corn
han
cc and Hconomic Imp
act
James Fancher described in detail what the history of Edison’s en-
vironmental control activities is, Edison alleges a total environmen-
tally—related expenditure of $733,000,000 since 1929. This includes an
estimate of expenditures up to 1977. Upon cross—examination it was
noted that much of the monies spent, while “technically” pollution abate-
15_
rent pro~iects, would have beep spent uor ~thor
reasons as ~e~1
~
ixanpie, ~he construction of smoke stacks and mach ash handling equip’~
aent ~s needed for tue safe and c~deriy ooerat~cn of a puartu
For
sta~’ce, one can not simply dusp ash on the p. ant ite iorever wiuhir
a short .Jme the plant Itself woula ~e huried
The anove ho ~evex
3
io~to irdicate that Edj son lac not spent corsideraule mcccv on oull
don abatement equinment. As early ~s
i
29 Edison insta~.led and opeoa~
ted
an electrostafic
precipitator on one of its units
~i~on
next details
its intended cospliance plan or tna a ~i iteS
in quest~n. Said compliance plan was sunmitted on March 1,
~913
CR 243 ~iibit F-3
.
The compliance olan (see Tanle 1) detailed idi
Jon s rrtenoed method for each of the uniLs ir question,
Bas cally
~ve stirtegies have been considered:
1,
Conversion to Oil: This is the compliance mode chosen for Sa—
~rooke 1—4. Units 3 and 4
have
already been converted to fuel
oil.
Un-
its I and 2 are, as of this date, stil embroiled in a controversy be-
tween the F.E,A, and Edison, but to date conversion to oil iS still
the goal.
Had Edison chosen conversion to oil for all other units, the alleged
cost would have been about
seven
billion dollars over the life of the
various plants.
II. Conversion to
Low-Sulphur Coal with New Electrostatic Precipi-
tator:
This is the compliance mode chosen for Waukegan 7. This
alt-
ernate includes the installation of a hot ESP.
Should this option have been chosen for all units under considera-
tion, a
cost of $l.937 billion was alleged.
III. Conversion to Low-Sulphur Coal with Flue Gas Injection: This
compliance mode was chosen for Waukegan 5,6, and 8 and Joliet 5, 6, 7,
and 8. This option, if considered for all units, is alleged to cost
$1,546 billion.
IV. Gasification of Coal: This compliance mode was chosen for Pow—
erton 5 and 6* and Kincaid I and 2. Had this option
been
picked for
all units, the alleged cost was $4,504 billion.
Edison has chosen the mixed strategy detailed above because of nuxr-
erous considerations which will be discussed further
in this
Opinion.
The m~xedstrategy approach was estimated by Edison to cost $3,451
billion over the life of the plants, expressed as revenue required by
~
this~~~Ttsin~-
pact on future decisions, both from an environmental impact as well as
an economic point of v~ew,are very helpful
as
an aid in formulating
our decision. Hovever, it must be remembered that this unit is not
ifl
question ~n this proceeding. An~ucipated startup will be in late 1975.
fs such, it .~illin
no way re affected
by Lhe decisions of the instant
Petition.
15—12
~disor this is equivalen.~to $594 000,000 carital costs Brief Pg.
4).
Fanche~explained ~R, 254) that v’n~ie econo:~icswere considered,
hey were
iOc an
overr~din9item in leve~opingthu mixed strategy. This
was dore ~or toe twin reauons ~-ha~ a detailea economic analysis done in
the past indicated that “order of aagnitud~ rankings
~
tie same and
seconely. because certain options wore sir~~lynot available on certain
units For example, snortage of 0ist~llat fuel oii precluded the total
system conversion to this fuel at any cos
~,
and severe problems exist
ir
burning low-sulphur coal on ~ertain cycloce ooil~rs
During consideration of eco~io~iicimuact Ediso r
utilized
a number of
assuired costs
which stoun. he ruLed *
Cost of re.ouilding f5p**
New ESP*
Cost of L.S.C. over Ill, coal ‘1 cents/mmBTU
Conversion to oil (Direct)
$30/kw
F.G.D. (Dixect)
$63/kw
Coal gasificatlo (Direct)
$80/kw
Under cross—examination, the subject of economics was hotly disputed
(H.
30 3—412)
.
Items of substantiai concern were cost of replacement
(A.
338) and a 15 figure for indirect
escalation
(H. 339)
.
Particular
concern was expressed over different figures given for identical costs
at different
times of these proceedings (e.g.,
cost
of coal gasification
capital).
Financial data are extremely difficult to analyze in that
various
methods of estimation are possible. Mr. Busch (economic evaluation for
Agency) presented a “financial rebuttal” of Edison’s $3,451 billion com-
pliance estimate. Hr. Busch stated that the method of cost analysis was
not a generally accepted method and that total cost by his methodology
would be $347
million. Also
calculated by Busch is the
total increase
in power production of $.001/kwh, or 3.2 of the 1983 kwn, production
cost. Under cross—examination of Mr. Busch, a number
of potential areas
of
concern were uncovered (e.g., kwh growth rate projection and cost
of
capital estimates, A, 46-47)
.
Again, methodology and
assumptions play
a very significant part in
the
final number generated as a total cost
projection.
Mr. Todd Bolen (Supervisor of Economic Research, Edison)
was called
as a witness to reaffirm the background for Edison’s $3.451 billion
estimate for compliance. Mr. Bolen countered the Busch testimony by
stating that the method of financial analysis used was the “Revenue Re-
quirement” method, which is commonly accepted by the utility field. He
listee a number of
textnooks
which address themselves to this method
CR, 129)
.
It must be noted that Mr. Bolen is saying that
the “Total
revenue request to support the PCB 74-16 variance” is $3,451 billion
*This list is
b’~
I
~h~h~read~r
sr~ferred to~h~
record (4/3/74, Pg. 260 Ex. F-6,7) for a detailed
description. Also
sue cross-examination.
**Diffjculty multipliers range from 1,1-2.7.
15 —
13
—7
(A.
131). The
thrust of Mr. Bolen’s testimony is that after adjusting
the
bases of Far(cher’s
numbers, the original Fancher numbers and the Bus
number were similar. The key statement is found on Pg. 158:
“From his testimony (Busch) I have very few leads as to
how he developed that $113 million annual revenue require-
ment, but in my testimony I attempted by several different
methods to show or to reconcile our two numbers, and I think
rather successfully reconciled that we were definitely talk-
ing in the same order of magnitude, which leads me to believe
he was using a revenue requirement technique similar to
ours.”
(7/9/74, Pg. 158)
The many, many pages of financial data and cross—examination on
these data serve to reaffirm our feeling, that depending on the bases
used and assumptions made, different numbers can be generated. Although
most numbers mean essentially the same thing, their impact seems vastly
different, depending on the vehicle used as a basis (e.g., total costs,
annualized costs, etc.), However, whichever way one chooses to look at
these figures, they represent a significant outlay of capital. The
Board, in reaching its final decision, is well apprised of the economic
impact of our decision and we will use this as a factor in reaching such
a decision.
The Options Available:
As mentioned above, Edison has submitted a compliance plan for the
units in question. Allegedly, this program encompasses the most prac-
tical
selection of
options and the most rapid time frame possible. How
realistic the time frame is will be discussed under
the individual
plan.t
sections oi this Opinion.
Thissection will deal with the reasonable-
ness and potential problem areas of each option.
I. Flue
Gas
Desulphurization (F,G,D.) : As a quick glance at Edi-
son’s
compliance plan
(sedTabI~T)~buldshow, Edison
has opted not
to
use flue gas
desulphurization in its plans. Edison
has taken the pos-
ition
that F,G.D, is not presently a
viable technology which is worthy
of utilization at its plants, and has thus eliminated it from present
consideration. The Board must, as part
of its consideration, determine
if Edison is making a good-faith
effort
to attain compliance in the
shortest practical time. However, we are not interested in
dictating
what type of compliance mode is used. Our main concern with the
testimony
in this area is to determine whether Edison has rejected
a viable method
which could bring about earlier compliance than could its submitted plan.
Mr. Donald
C. Gifford (Project Engineer, Scrubber Installation*) de-
scribed Edison’s past attempt at utilizing F.G.D. Edison first initia-
ted an FGD project in the spring of 1970. Bechtel Engineering suggested
a wet scrubber operation and the contract
for construction
was let to Bab-
cock and Wilcox in September 1970. One-half of
the
operation was put
in service on February 23,
1972.
The
system, commonly known as the Will
County scrubber, is guaranteed
to remove 98 of fly ash and 75 of SO2.
~sentlyemployedbyEdison;nowaProjectDirectorwitUni-
versal Oil Products.
15—14
The sy~emwas retrofitted to the Will County Unit #1 shich is rated
at 1 ‘7 trw, It is a wet L.mestone scrubber, c~rrpIete ‘ith limestone
miiilng, two—module (A and B) scrubber, and sludge Lr-eatir~ent facilities.
The second stage (A) scrubber uscame operational on upril. 7, 1972.
The
record (4/5/74, A. 47—60) detail~ Pdison s ‘~rperience wish the system.
For various reasons the system lid not funtion anywhere near guarantee I
rati
ig. Ivailability
of the scrutbrr systom was particularly
disappoir t
~ng.
Ihe longest qonsecutive run on the A scrubber was 21
days (H.
48)
Availability
i.S
reported for A scrubbcr, 29 5c, and B scrubber, 25.2.
Edison decided on April 15, 1973, to disconti’rue work on the B scrubber
and concentrate on the ~ s~.rubber. rihe problems during the startup
phnse were many and varied.
Of major conccrr were denister pluggage,
rePeater pluggage and corrosior,
e~br~tion
Of
fans, an6 stress cracking.
Many problems cave been resolved, and the rain areas of concern at
pres-
ent
are.
1) Stress cracking of reheator tubes.
2) Limestone blinding of scrubbant.
3)
Sulphate scale formation.
4)
Sludge disposal.
Edison details the costs to date for this scrubber at $16.8 million
and operating costs at 9.4 mills/kwh
at (35 capacity factor),
Under cross-examination, many of the facts and figures cited were
~ ilenged. The Board finds that, although there is a question as to
validity of the exact figures, the overriding impression is that
this system
was
particularly troublesome. The fact that Will County I
may not
have been an ideal location for a scrubber installation (H. 70)
is of little value to the Board in that all plants considered
would be
retrofit operations with varying degrees of difficulty.
Discussions of
closed
loop
pH
control (R. 99)
or sludge handling problems
(R. 137)
likewise do not
answer the question
of why the system did
not function
properly.
While it is true that these techniques are being developed
every
day, Edison was in 1972 put
in
the position of having to develop
such a system. They simply were not readily available at the time.
Edison
further detailed its experimentation
with an
$8 million, 22
nw pilot program at its State Line plant.
This system, termed
the sul-
fox~.l
system, produces elemental
sulphur. Problems with
the catalyst
system
have caused Edison to “mothball” the
system, while
consideration
of
future
pilot plant runs
is undertaken (H.
69).
Edison,
however, contends that its decision to
not consider F.G.D.
is
not solely based on its rather dismal record,
but also on the cur-
rent
status of
the
systems on other plants.
This area was perhaps the
most
hotly controversial subject in
this matter, and
one which has been
presented to the
Board
in other forums (CILCO v.
Environmental_Protect-
ion Agency, PCB 73-65
SO2
Inquiry
Hearings,
R74-2). In
the instant
P~~Ton,weThi~
the two divergent views on availability
and technology
presented by Mr. A.
Slack
for
Edison
and
by Dr. H.
Hesketh for the Agen-
The Board feels
it
would
be useless to again
detail the testimony on
15
—
15
t
.
subject. The pages of the record which the reader is directed
to,
.uld he wish a
detailed description of each plant, are May
8, 1974,
1—151;
June 5,
1974, H. 1—105; and June 20, 1974,
R.
1—95. The follow—
£ng plants were discussed, along with their merits and disadvantages: Will
County, Lawrence, Mitsui, Duquesne, Paddy Run, Cholla, Reed Gardner,
Southern California Edison, Mohave, Boston Edison, and LaCygne.
The long,
detailed discussion on the above plants leads the Board to
a number of conclusions.
Much progress has
been made during the past few
years on F.G.D, The hard lessons learned at Will County I and
in the
original injection processes have yielded new systems in which many
of
the original problems are being solved. The chemistry
of the systems is
becoming better understood, as is the necessity to closely control and
monitor specific parameters such as pH. However, many problems still ex-
ist. Corrosion scaling, vibration, reheaters, and sludge disposal are
among the problems which, while being solved, have not yet reached final
resolution. The Board can understand Edison’s hesitancy to
install this
technology when, in its opinion, the chances for success are
below those
compliance methods it has chosen.
The Board takes judicial notice of the document entitled “National
Public Hearings on power Plant Compliance
with Sulphur Oxide
Air
Pollu-
tion Regulations,” published in January, 1974. Referring
to Page 63 of
that report, time to install scrubbers
is listed as between 27 to 60
months, depending
on the source of information.
Vendor estimates ranged
stallationfrom
30 to
and36
monthsthe
size(obviously,of the unit),dependentThe
onmostdegreeobviousof
candidatesdifficulty
offor
ii
such systems are Powerton and Kincaid, Due to
the fact that
both
of these
units are large (850 mw and 1232 mw) and existing, a 36-month
installation
time woul.d be expected. Thus, if one considered a jump-off date as
the
time of decision in this action, compliance could be anticipated (should
scrubbers be opted for) by January 1978, Thus,
if scrubbers were select-
ed, compliance could theoretically be accomplished earlier than Edison’s
plans for gasification.
The question of the Board’s position on the availability
and
reliabil-
ity
of
scrubbers does not have to be determined
in
the instant proceed-
ing, as once again the question is how will an extended compliance plan
(beyond the theoretical 1978 date) affect the environment and thereby the
citizens of the state.
The function of the Board is not to support one
method of compliance over another,
but rather to support the most rapid,
viable methodology consistent with environmental, economic,
and technol-
ogical considerations. Our decision
on Edison’s compliance plan is thus
made on its impact on
the state.
II. Coal Gasification: Edison’s
proposed compliance plan for Powerton
5 (850 mw) and Kincaid 1 and 2 (616 mw
each) is the installation of a low
BTU coal gasification unit, using high-sulphur Illinois coal as a
feed-
stock. Mr.
J. Augosta (Research Engineer, Edison) explained Edison’s
history in this area, as
well as the intended plans for the future (5/7/74,
H.
1—133)
Edison first began investigation of coal
gasification in 1966 and se~
15— 16
a task force in 1970. This task force was to determine
answers to
three questions: I) ability to produce gas from available coal, 2) en-
vironmental acceptability of the gas produced, 3) a timetable to install
a
commercial system.
As a
result of this study, Edison reached the
con-
clusions that
no technology
is presently developed
to reliably supply
power generation
gas, that the
potential for such a system is very good,
and that coal gasification offered the best option to meet Edison’s com-
pliance criteria on a relatively short—term basis.
Edison determined that before committing to a very large unit, a
smaller prototype should be built.
Powerton 4
was selected as the site
(119 mw)
.
On May 23, 1971, Edison entered into contract with Lurgi to
provide engineering and other services to Edison,
The cost of this (Pow-
erton 4) project is listed at about 19 million dollars, with Edison com-
mitted to $7.75 million and the Electric Power Research Institute con-
tributing $11.5 million. Groundbreaking is anticipated in late 1975, with
operation starting 30 to 36 months later.
Edison then contends that one
year of operation would be needed ~to shake down and test the system, at
wh.ich time (about 1977) design will start for Powerton 5 and Kincaid 1 and
2. A key point on technology is that Edison has had a 10,000-ton test run
on a Westfield, Scotland, Lurgi gasifier.
The results of this test were
encouraging, according
to Edison. However, they allege that more work is
needed (H. 12).
Before moving to
the cross-examination, a
brief description of how a
~~oal gasification plant operates is
in order.
The heart of such a system is the
Lurgi coal gasifier. This is a
high—pressure vessel into which coal (crushed and screened)
is injected
via an air
lock. Air and steam are also injected
with the
subsequent
generation
of hydrogen, which combines with the coal, under high tempera-
ture and pressure, to form methane gas and various other gases.
The final
gas stream has a heat content of about 175 BTU/ft3*,
Ash is removed from
the gasifiers via
an
ash lock.
The resultant gas is then fed to a desulph-
urization process where hydrogen sulphide (H2S)
is stripped out. The con-
centrated H2S
stream then passes through a Claus kiln (an acceptable
and
reliable unit process) which produces elemental sulphur.
The intended Powerton gasifier is to consist of three 12-foot-diameter
Lurgi gasifiers (H. 44 and 88)
.
It is assumed that any construction of
Powerton
5
would be increased by multiples of the same size gasifiers. Ed-
ison predicts preoperation testing of this unit to commence during the
last two months of 1976.
The cross—examination essentially explored two points: 1) the state
of
the technology, and 2) the rationale for Edison’s extended compliance
dates. It would seem that from experimentation at the Westfield, Scot-
*Thls
is in contrast to high BTU gasification, which is considered as
a
potential source of pipeline quality gas
at
1000 BTU/#3. Low BTU gasi-
fication is economically feasible for power plants because there is no
need to transport the resultant gas
via
pipeline. Low BTU gasification
viates the need for the costly and rather intricate methanation step,
ch would boost the BTU value by reaction with excess hydrogen.
15— 17
land, plant, a ccnsiderabl? part 03 tn~ r~~xwas rerved;
indeed .r
substanrial amount of Ii1~r.ois coa was ga.~Fued successfuliy.
SO~
clear up ~quipment
~as preser t and at ~ized on site,
The Wes ~fr eld
operationgas
‘~o the
startedarea
resfdentsup
about
since1960 tnonand
has been supply~ng 240 BTJ/ft3
Another plant of
interesL is the Sasol plant in South Afrrca. 13115
plant consists of about thirLee~ ~2iloot—oiaueter
oxygyn-blowr gasitera
used to produce feec for a petrochemiual ‘~peration.
‘h e tar cenerated
is not
~ecirculated’
there is no pollution a.oaterrert and a o~—qraae
coa~
is gasified
(R.
61)
.
However, upon an inspection of tro plant
Edisce
~ that the ope’~ation was relatthely reliahle
I~- wcrld seem that tne major point of technology which is untried
tire udaptataon of a utility boiler
to accept a low BTU gas
feed. it
~sL be remembered that in using low
BT’J
gas
as a feedstock, a much
~reat.er
volume of gas must be fed and the boiler must be adapted to
suit.
Taking all of the testimony into account, the Board finds that Fdi-
son
is embarking on a project which has an excellent potential for suc~
cess. Furthermore,
it
promises
to open a viable alternate to 502
re-
moval, one which can be economical, clean, and still use our abundant
supplies of high-sulphur coal. However, the Board finds that Edison’s
timetable is unduly extended. Edison proceeded slowly and cautiously
since its task force
was formulated
in 1970, and as such, valuable
development time was lost. Attention is drawn to a memo (internal to
Edison) proposing one gasifier on Powerton by 1973, and
five
gasifiers
oy 1975 (H. 84). There is no good reason why this program was not
pushed harder than it was. Therefore, the Board feels that every poss-
ible barrier should be removed to expedite this program. We further
feel that the 1980 date for Powerton 5 may be excessive. We do not
feel that
it is
necessary to delay design of Powerton 5 until after one
full year of experience on Powerton 4, nor do we feel Kincaid 1 and 2
should be further delayed. We do feel that the bulk of construction
costs should not be spent until Powerton ~ is proven, but also feel that
construction should start as soon as Powerton
4 is tested,
e.g., early
1777. This rationale will be applied to our Opinion concerning the in-
dividual stations.
III. Low-Sulphur
Coal: Switching from high—sulphur coal to
low-sul-
phur coal
is
the option dh~osenfor Waukegan
5, 6,
7, and 8 and Joliet
5, 6, 7, and
8. However, Edison alleges certain problems exist in burn-
ing low—sulphur coal. Before exploring these problems it is necessary
to note
that Edison discounted the use of low—sulphur coal on Powerton
5
and Kincard
1
and 2. This decision
goes
in part to the alleged ur-
availability
of low-sulphur coal.
Mr. G. Marcus (fuel agent, Edison) detailed
Edison’s attempts at
securing additional 1ow~sulphur
coal (4/9/74 H 615—624)
.
It was ex-
plained that
almost
all low-sulphur coal must be
imported from
the West
because Illinois produces
no
sucn coal
for utrlity use,* An interest-
~
small amounts of fairly .Low-sulpnur coal (1.5)
are mined
nn Illinois,
it is used for making coke.
15
— 18
—
12
—
ing statistic quoted
by
Marcus was that
in 1969 the state of Montana
mined 500,000 tons of coal and
in 1973
Edison utilized 5.5 million
tons from Montana. This figure was entered to point out the fact that
new mines will have to be opened
to generate
more coal as
it
is needed.
Marcus Exhibit #2, summarized below, shows Edison’s deficits in commit-
ted low-sulphur coal ranging from 0.5 million tons in 1974 to 11.6 mill-
ion tons in 1980, which indicates that new sources will have to be com-
mitted in
the
near future.
Year Low Sulphur Coal Required Low Sulphur Coal Obtained Deficit
1974
9.35
million
tons
8.9 million tons
0.45 million
tons
1975
11.7
9.1
2.6
1976
12.0
9.3
2.7
1977
13.4
8.8
4.6
1978
15.4
8.7
6.7
1979
13.5
1.9
11.6
1980
13,5
1,9
11,6
TOTAL DEFICIT 40.3 million
tons
Mr. Marcus then detailed Edison’s efforts to procure additional supplies
of low-sulphur coal (H. 618-620). Efforts to date have been very disap-
pointing (H, 621) as summarized below:
Date
Number Bids Let
Volume Coal
Number Valid Volume Ob-
_______________
Required (Years) Bids Received tamed
March 73
11
24 Million Tons
2
6.9 Million
(1975—1978)
Tons
Sept. 73
21
16 Million Tons
Bid under con
(1977—1987)
sideration
(R 653)
Oct. 73
17
72 Million Tons
Bid rejected
1979—1989)
(R 655)
Summing up this experience, Edison in 1973 was able to obtain only 14.3
million tons out of the 52 million tons required for the years 1974 to
1980 (R. 622). These deficits do not include the Powerton or Kincaid fac-
ilities where coal gasification is planned. If Powerton and Kincaid were
included to use low—sulphur
coal,
the yearly deficits would increase to
15
million tons
in 1979
and 1980 (Marcus Ex. 3). Because of the scarcity
of low-sulphur coal and the fact that the Kincaid plant is a mine mouth
operation, consideration of low-sulphur coal for these units (Powerton
and Kincaid) was
rejected. The logistics and reliability problem in
transporting western coal was discussed by Edison in an attempt to
rebut
the
Agency recommendation for coal blending at Powerton.
To acquire the
required low-sulphur
coal (2.3 million tons per
year)
,
a new coal
mine
would have to be opened, which would take 3 to 4 years; five sets of loc-
omotives and 500 railroad cars would be necessary. In addition existing
coal cars in Illinois could not withstand the rigors of a 2500 mile round
trip and thus could not be used (7/11/74, H. 24-25),
In 1970 Edison was the first midwestern user of unit train deliveries
15
—
19
of ~oc—s~’ nirur wes ..e’u ~oa
.
Dud .v ther~ ~ne
Ji)
ry austome~s :)r wester
oal, in the midwest rr.d uisn~he:~ ~nd .fiison uxprerTed cunccrn ahu’L
one abi Ii cy of tfi rafir ad~ ~o I unOle the ~r ~u r~a1~traffi
ef5in ~eno~
~y ani rfi ~auiy
part~e nrary surce ~fiao r reeds ~e. rile ~uil suu~iie~
ll/~4, R. 27
This oncerr ics expressed ii re.ards fi the 2.3
il1,iion t. irs per year of lo~’~sulphur
cc r~ jf rtel blenfi
ic
at ?owcrton
as to occur.
The Board is concur~ed auoui ld~sor ‘s anil:ty to obtaa~.
s uric ect
and reliable supply
of low—sulpnur wes.~ern .oa. eased
ir
o~..croading of
the
ord
in this
case. We will therefore require at any fit ~re er~en
sions
of
is variance firm ~ow.Lrgs
that ~‘dison 1, has o~tarncd r~.rn
coms ~m
for low—solilur coal, ~ has ibta~red abe
ao~
.~
tv no ~rnns
~rt
su~r c~aa to ils plant site, 3’ nas ~orkcd out alternate o mpiirnce
inns ul ~uld the above two conditions be unfulfilled.
~‘dison next moved to detail the probleurs ercoantered in nurning low-
sulphur coal on existing units.
The problems center about two areas: first
the use
of low—sulpaur
coal with conventional
E.S.P.’s causes a degradation in the equipment s
capture efficiency. This consequence,
first noticed a number of years
ago, is now a well-established fact The following table
details the
loss of efficiency actually encouncered at Commonwealth Edison’s Wauk—
egan #8:
12
3
45
BTU Coal
10987
11069
10627
11371
9820
Sulphur
2.79
2,16
2.97
0.82
0.45
Coal
Outlet #/mm 0.067
0.071
0,060
0.518
0.335
BTU
Efficiency
98.6
98.4
98.9
87.2
88.1
The table clearly shows the mentioned degradation and resultant em-
issions of large amounts
of particulates to the atmosphere. There are
two possible solutions
to this problum. One is the construction of ‘~Hot”
ESP’s
-
which are
units installed before the
air preheaters. At
this
nigher temperature the resistivity of
the ash is
such that ESP
efficien-
cy increases to acceptable levels. It should be noted that
at these high
temperatures the size of
the
ESP must
be significantly larger
so
as to
accept
the
increased volume
of the
gas.
The retrofitting of such units
is a long-range project and would not be available
by May
1975 (see dis-
c~1ssion cc Waukegac ~)
;
therefore,
if low—sulphur coal was used, there
could be a trade-off of pollutants.
A second method of solving the ESP
degradation problem .s ‘flue gas conditioning.”
This project injects
sulphur trioxide direct~.y into the flue gas; the SO3 then precipItates
out
on
the partlculates,
which increases the migration velocity of tne
fly
ash and thus increases ESP efficiency.
15 —20
—
34
—
The second main area of con~’err i.n uti1izin~ low—sulphur coal is the
potenc..al i r fires or exp1o.~icrrs
.~r
cern
in
types of ooileru
Cyclone
filers
are particularly susceptJble t this type of problem. The
prob-
fn
is es sentiaily caused by high ~ar~on c r
‘c
icr u~,eurned coal) which
c uld Lir~r be ignited outside of the boilcr,
‘ausing 5.amaae to the pre
heaters and LSP’s.
Information ger.e’~ated ly Bdis’n indicates that a
solution to the proble’~ is fortnco~rng.
ihe above problems are alleged ~r’ be the main reason why compliance
with both Rule~ 203 and 234 carrot he ..~cconpltshed sImultaneously.
The
ditt~ cu...ties as they relate to each sp~cif c p3 ant will be discussed
ater in this OpinIon.
IV. Supplemental Control
Systems (Sc.S) : Altiough not a permanent
system, SCS has the advantage of allowing attainment
of
the short-term
air quality standards
on an
interIm basis,
Due to the reality that Ed~
ison
will not be
in compliance
with Rules 203 and 204 at many
locations
by 1975, it
is incumbent for
the ~3oard to investigate methods which would
reduce the impact of such discharges on tire citizens of the state until
such time as permanent capture
equipment (or fuel switching) can be in-
stalled.
A brief overview of
what an ideal SCS system is and how it would
function is given in the following paragraphs.
A supplementary control
system can be defined as “Systems where the
rate of emission from a
source is curtailed when meteorological
condi-
tions conducive to high ground-level pollutant concentrations exist
or
are anticipated”
(Federal Register, Vol. 38, No. 178, p. 25698, Septem-
ber 14, 1973).
It
is, in fact, a program
incorporating real time moni-
toring of stack emissions, meteorological conditions, and
air quality
data with a numerical scheme for the determination
of
current and fut-
ure ambient air quality in the vicinity of a specific source, such that
when selected levels of ambient air quality are obtained or forecast,
specific emission reduction activities can be taken.
As a practical matter, such
controls can include:
I) fuel switching,
2) load shifting, or
3)
curtailment
of the industrial
process to reduce
emissions during periods when air conditions are
not optimum
for dis-
persing and diluting SO2. These systems,
though
apnearing under dif
f-
erent names, have been used by such diverse entities as the Tennessee
Valley Authority, at its Paradise plant, American Smelting and Refining
Company,
at
its El Paso and Tacoma smelters, and Dow Chemical Company,
at Midland Michigan.
Though
all
interim control strategies are somewhat different, the
basic elements
of these systems
are fairly common,
The universal ele-
ments
of all systems
are as follows:
1. Equipment to measure the actual recil time meteorologi-
cal conditions surrounding the plant.
This is
necessary
for both predictive functions
and to keep the operator
aware
of
the conditions
at the actual time they
are hap-
pening;
15
—
21
—
15
—
2. A model
based
on past meteorological and dispersion
data that will predict atmospheric conditions as to
both weather and as to conditions which would influ-
ence dispersion of contaminants;
3. Actual source emissions. This must be real time and
constant to the operator so as to be aware of what
the plant is discharging to the atmosphere;
4. Predicted emissions. This is necessary for the oper-
ator to know in advance what conditions he will be
operating under in the future so as to determine
whether the atmospheric conditions will be adequate
to disperse what will be emitted;
5. A dispersion
model. This, of course, is necessary to
predict the concentration of contaminants, once em-
itted under certain atmospheric conditions, so as to
determine whether control strategies must be instituted.
6. Validation of model. This
is
necessary to determine
whether the model is
in
fact reflecting actual condi-
tions and would be done through real time monitoring
of both contaminants in the ambient air and meteor-
ological conditions;
7, Indications and trends as to potential violations.
This is necessary in order to give the operator a
framework in which to make decisions as to when to
institute a control strategy;, and
8. A strategy to control emissions. This, of course,
is the ultimate function of the control system. Such
strategies can consist of load reduction, fuel switch-
ing, load shifting, and part-time use of permanent
controls when
dispersion conditions would seem to in-
dicate.
It should be noted that there will be no standard supplementary control
system.
A supplementary control system must be developed for every plant
to which it is applied. Such factors as terrain, meteorology, process,
stack height, and congestion of the area are all factors which must be
considered.
Though all
systems will not
be alike, they will all have certain bas-
ic hardware in common.
These include monitors for the contaminants to
be measured. The number of such monitors
would depend
on the plant and
its location, and could range from just a few monitors to as many as
18 to 20, Also, the system would have to have certain weather monitoring
devices so as to measure the conditions surrounding the plant.
These
would all have to be on direct hookup back to a central operations point
where an operator of such a system could at any time get information
from the monitors and the meteorological equipment, A third element
would necessarily be a computer, which could be used to correlate all
real-time data with all predicted data in the models so as to determine
15
—
22
what the conditions are and wnat tire coneitions are liable
to
be
in
the
resr future.
Such data transmission r,i~ht also be hooked into the en-
aorcicg agency directly for eas~ of snfo~cemcnt
The most important
clement ~s not really a piece of ~ardwaie,
ot is, in fact, a plan which
woufi indicate that when certain levels
are
reached or are
predicted
Lo
be reach~a bu~ing a time span in the fut~c.e, certalr set plans would co
nto cfiect at the plant to brIng emissicn~ ~niLo line wrth those which
would cot cause violaLior of any standard that applies to
the plant.
On September 14, 1973, the
5.
Environmeila~ fiotecfion Agency
pub-
listen rules and gu.deiines for a
i~~i
mstntary ‘~ontrol anstems (38 Fed—
eralPegister
25698 September 14, 1fi3
.
ihese
ruler nave never beec
is~aed as final, but they do glve insight into requirements
for an SCS
system that tire federai govern era tn~ugna wore minima~ at that
time.
It should be noted that even at this time the proposed guidelines
would
only
allow
supplementary control systems to
be used in situations where
their
use was
necessary to augment constant emission limitation tech-
niques
which were available to a specific source and
only until
com-
pletely
adequate, constant emission limitatron
techniques became avail-
able. This could be summed
up to mean that it would be allowed in sit-
uations where the sole alternatives
are either cutting back production
permanently or delaying
the
attainment date
for the national standards.
The basic requirement of the federal guidelines is reliability ir
the system. Before allowing SCS to be used, the federal government
al-
so would require each user of
an
SCS to support and participate in
ap-
propriate research development
and
engineering and a demonstration pro-
gram to
insure
that the SCS system can
be replaced by
constant emission
limitation techniques as soon
as
possible. This would be expanded to
indicate that SCS would not be allowed on new or newly-modified sources,
but only on present existing sources.
One of the major concerns relates to
the
enforceability of the regu-
lation for meeting the national ambient air quality standard if an SCS
system is instituted for a stationary source.
It
is feared that citi-
zen enforcement of the Environmental Protection Act would
be
discouraged
because of the difficulty of determining whether ambient air quality is
being
met,
as compared to a simple determination of whether emission lim
itations are being met. Indications are that an SCS system is validly
enforceable under the regulatori scheme as exists today with certain mod
ifications. There are basically awo methods of enforceability. The
first, of course, is actual measurement of the ambient air quality to
determine whether the national standards are being violated. The second
method is by making the SCS control plan enforceable on its face, with
the regulatory determination that failure to comply with all terms of
the plan is a prima facie violation of the standards.
Mr. Melvin (Illinois EPA) testified
that an SCS
would be applicable
to Kancaid (R. 81)
but
that it would be very difficult
in a major met-
ropolitan area (Powerton)
Mr. Melvin further testified
that
he could
give no cost
estimates
for such a system,
nor could he estimate the
time required
to install such a system. The Board feels
that an SCS
system
is needed in areas where extended
compliance
plans
are to be un-
dertaken,
but
is
fully aware that some tIme
must be allowed
for a form—
15
—
23
—
17
—
ulation of a plan.
Our Order will require such planning and eventual
installation
of a
viable permanent emission control system.
Environmental
Impact and Compliance at Individual Power Stations
We will now turn to discussions of individual plants, detailing the
intended methods of compliance and the environmental impact of each
facility.
~
The Waukegan Station
is
located
in
Lake County, Ill-
inois, a part of the Chicago MMA. As such, Rule 203 dictates particu-
late levels of 0.1 by May 31, 1975, and Rule 204 dictates levels of
l,8#/mmBTU
~°2 by May 31, 1975.
Environmental Impact: The subject of environmental impact is of
critical interest in any decision the Board renders in this action.
The Waukegan station is located within the city limits of Waukegan at
Greenwood Drive near Lake Michigan.
On April 16, 1974, Mr. Jack Klingbeil (representative of CAP) test-
ified to the effect that they were concerned that Edison’s progress has
not
been good in complying with Board regulations.
He
urged the Board
to put maximum pressure on Edison to insure speedy compliance.
The effect of Edison’s discharges was discussed by both Fancher
(4/15/74) and Melvin (7/11/74). Both witnesses discussed the results
of model data that had been generated.
Fancher’s data predicted the effect that the ~
an ati2~* will
have
on
ambient air quality by May 30, 1975~ Assumptions include the
following:
1, Edison’s proposed compliance plan is on
schedule.
2. Full load operation.
3. Stability Class 2 conditions.
The results of this computer model reveal the following:
Unit
SO2
Rate
Max.
24 Hr. Max. 3
Hr. Part.
Rate Max. 24 Hr.
Max.3Hr~
56
2,70#/MBTU
2.70
27.3ug/m50.6 3
143.277.2
ug/m3
0.28O.50#/MBTU 5.25.0
ug/m3
14.814.3ug/m3
7 2.70
37.5
106.2
1.87
26.0
73.5
8 2.70
38.6
109.3
0.07
1.0
2.8
Total
134.0
379.1
37.2
105.0
Standards
365
1300
260
*ft must be noted that these
figures, as well as Melvin’s figures,
de-
tail the effect of plant emissions
on the ambient
air, NOT the
projected
air quality in the area as a
result of all emissions. Of further
import-
emittersance
is that(overin
200the
tons/yr.)
immediate
.
WaukeganOf
these four,area
thereEdisonareaccountsonly fourformajorabout SO2
87.5 of the total load.
Therefore, Edison should have the dominant
in-
fluence on
ambient
air quality as it pertains to SO2. This discussion
15
— 24
—
18
—
Upon cross—examination, a
number of weaknesses in the model were
pointed out.
Most notably, the model does not take into account fumi-
gation or inversior effects.
Fum~gatior is particularly
important in
this case
in that the plant is rocated directly adjacent to the lake
In addition, certain topographical conditions are not considered. Some
of the omissions
in the model presented cause
the Board to conclude that
the data are given slanted
low, However, the fact that 100 load was
used to generate the model would tend to overestimate the results. Be-
fore drawing any firm conclusions we will turn to Melvin’s testimony.
Mr. G. Melvin (Ill. EPA
Episode Unit) entered Melvin Ex. #2, whicn
is an analysis of Edison’s contribution to the air quality in the sub-
ject areas.
Mr. Melvin’s data was intended to predict concentrations
at the
worst conditions, as well as other conditions.
The following is
the result of his study.
I. Under trapping conditions, Waukegan will not cause (in it-
self) a violation of tie 3-hr. SO2 standard (Pg 13, Ex.
11.
2).
2. Lnder fumigation conditions, thukegan has the potential
for vlolat~ng the o.5 ppm. 3-hr. secondary standard
(see
Ex. M—2 Table 12)
3. Estimates of daily (24—hr.) concentrations
under nor-
mal meteorological conditions
show both SO2 and part-
iculates belov the standards (sea I’1-2, Table
18, e.g.,
S02--.04 vs. Standard of
0.14, part.
28
vs. Standard
260)
The conclusion would be that under adverse conditions the Waukegan
plant has the potential to exceed the short-term (24—hr.
and
3-hr.)
standards
for 302
and particulates.
This is best pointed out by Ex.
M-2, Tables
21 and 22, which give maximum short—term concentrations
under adverse meteorological conditions,
Under cross-examination, many
of
the assumptions (e.g., plume rise
equations) were questioned, as were Fancher’s assumptions.
In studying all data presented, the
Board
feels that a potential ex-
ists for violation of short—term standards. To protect against excess
violations and yet allow the use of equipment which is needed for pow-
er generation, our Order will dictate operation loading for W-7, and
early shutdown for W-6.
Unit
5 is a 129 mw unit fired by a pulverized coal, wet—bottom boil-
er.
The boiler
utilizes 1.3 sulphur coal
and is anticipated to still
utilize coal with this sulphur content on May 31, 1975. Emissions while
burning this coal are expected to be
0.5#/mmBTU
until December 1,
1975,
at which time an SO3 injection system will be installed. Edison states
that the duct work on Unit 5 will be modified to incorporate two ESP’s
and this will
thereby
reach
the aforementioned 0.5#/mmBTU.
This work
~~not consider st~kheighE~nd its effect on dispersion. This in-
formation is from the
Illinois EPA emission inventory.
15—
25
—
19
-
snould be accomplished by December 9’4,
Tino coard finds thaL
this
elan is .ceasonaele aria will endorse It.
Variance will be granted from O~tober .5, ~974, to October 15, 1975,
rub~ect to conditions of particulate discharge and sulphur content of
toe coal to be burned.
Tariance will also be granted to allow 502
emissions over
the
l.8#/mnr~BTU Level front May 31, 1975, to October la,
19/5, subject
to
conditions
of maximum emissions tied to sulphur com-
tent of the coal.
The provisions for monitoring and reporting of PCB
74-11 will also be required.
Unit 6
an 119 mw unit fired by a cyclone coal-fired bo...lei’ The
hoilert~
~za~
and will continue to utilize a fend of coal of about
.~
suaph r.
Emissions are presently in tne range of 0.3#/mmBTU (run
2.6
c’u.~phur coal)
.
Edison contends that when burning low-sulpiur
~,
deterioration of the system is encountered due
to high carbon
us ‘yover.
This problem will be attacked by boiler modifications as
suggested by Babcock and Wilcox.
Parts for
this modification were to
be delivered by November 1974, and Edison proposes a shutdown for mod-
ifications during the second quarter of 1975 (H. 12)
.
Edison then pro-
posed to
start design of a flue gas injection system with eventual com-
pliance by June
1976.
Under cross—examination the element of time was examined. In re-
sponse to a question as to whether the modifications could be moved up
to begin as soon
as the
part arrived, Mr. Holyoak replied:
“I believe
it
might be possible, but it is a function of what else is going on
in
the system.” (H.
51,
4/15/74)
The Board feels that particulates are a problem
to
the residents of
the area and should be controlled in as short a time as possible. In
line with our above reasoning in regards
to the system availability and
maintenance requirements, we will not grant variance any longer
than
needed to start boiler modifications. In relation to the SQ3 injection
system, the
Board must
differ with Mr. Holyoak’s statements that flue
gas conditioning technology is
still in
the infant stage (R, 23)
and
that design of these systems should be staggered. The Board takes jud-
icial notice of the article,
entitled “The Performance of Electrostatic
Precipitators in Relation to Low-Sulphur Fuels,’~*
in which reports
of
the commercial use of this technique date back to 1963. We find no rea-
son for Edison to defer the design
and installation of this equipment.
Variance
will be granted until October 15, 1975, subject to Edison in-
itiating
design and installation of its SO3 system as soon as
Unit 6 is
modified and on stream.
Unit 7 Is a 617 mw unit fired by a dry-bottom boiler which
utilizes
pulirerized
1.6 sulphur coal. This 1.6 coal
is
intended for use after
May
31, 1975 (H. 139, 4/15/74).
Sulphur dioxide emissions from this
unit will thus be approximately 3.2#/mmBTU (based
on
10,000 BTU/# coal)
but will tary with the heat value of the coal.
Unit 7 is equipped with
an ESP which was originally rated at 98
efficiency on high-sulphur coal.
In
an
attempt to increase the ESP efficiency.
Edison undertook testing
*By K. Ja
and C. Win its
a.d,Second Internat ional Clean Air
Cbn’-
gress, pg.
911 to 922.
15
—26
with an additive known as Mopper K (testing about July 1971), Such
testing did not increase efficiency and was discontinued. Upon inspect-
ion of the
ESP, it was noted that the plates were coated with fly ash
and Kopper K. This situation decreased the efficiency of
the ESP
so
that further stack tests revealed
an
outlet of
l.27#/rnBTU.
(Test run
7/20/71, see 4/15/74 Ex. G,M,—2,)
The projected repair bill was set
at $4.8 million, with no assurance that low—sulphur coal may
be used
and compliance achieved. Edison then contacted Sargent and Lundy and
contracted for the installation
of a hot side ESP which would allow
compliance with Rule 203 while burning low-sulphur coal. The antici-
pated completion date for this project is December 1976. The reader
is referred to 4/15/74, H. 15—17, and Ex.
11-3
and
4 for details on
this plan. Edison contends that
the length of time required for
com-
pletion is necessitated by the location (120 feet in the
air)
of
the
new unit. Edison also contends that a recent experience with a retro-
fit ESP installation on Will County 3 dictates this length of time. Cap-
ital cost
is estimated
at $19
million (Exhibit F-7 a)
Upon cross-examination, the
reasons for the delay were explored (H.
56-59,
H. 75-78)
.
Although the
Board
feels that some excess may be
built into the schedule, Edison’s recent experience with Will County
3 leads us
to believe that the proposed schedule is realistic. We
will allow the proposed timetable subject to review of progress at any
further proceedings. Variance will be granted subject to many of the
conditions detailed in the discussion of the Waukegan 5 and 6 units.
However, due to the excessive particulates generated by this unit, its
use will be curtailed,
Unit 8 is a 360 mw generator fired by a dry-bottom boiler burning
pulverized 1.6 sulphur coal. Very little discussion is needed on
this unit. A long series of testing has been undertaken by Edison in
the use of SO3 injection (details H. 18-21)
.
The system should now be
in operation. It is noted that in Petitioner’s Motion for Modification
(October 18, 1974) further delays to November 1, 1974, were anticipated.
This Board has no sympathy in this regard. The operation of this sys-
tem is an integral part of Edison’s compliance plan and must be pursued
with all possible vigor. The Petition will be denied.
Sabrooke Station: This is a small (146 mw) generating station loc-
ated in Rockford, Illinois. The plant was purchased by Edison from
Central Illinois Electric and Gas Co. in 1966. The plant is located
on the east side of the Rock River in the southern part of the City
of Rockford.
Units 3 and 4 are presently oil-fired; therefore, they are in com-
pliance and will not be considered further.
Units 1 and 2 represent a rather unique problem. Edison’s original
prayer for relief was as follows:
“...and in the event that Edison is not able to proceed
with its plans to convert the Sabrooke Station to oil fir-
ing by the end of 1974, to such dates beyond May 30, 1975,
as may be established by a compliance plan to be submitted
15—27
to the Board by July 15, 1974.” (Pet. 74-il, Pg. 50)
As Fancier’s testimony of July Il reveals, Edison~has not yet re-
ceived final word on its appeal to the Federal Energy Office regard-
ing its request
to
burn oil on Units I and 2. Neither has Edison sup-
plied the Board with
an alternate compliance plan. The first indica-
tion that Edison
wishes
to change its prayer for relief is revealed in
Edison’s closing brief as follows:
“Accordingly, Edison requests a variance for Sabrooke
Units 1 and 2 for one year, provided that within 60
days of a ruling by the FEO on Edison’s request to burn
oil in these units, Edison will submit to the Board and
Agency a specific program for bringing these two units
into compliance.”
(Brief of Petitioner,
Pg. 42)
If the Board granted such a prayer for relief, it would condone a
variance granting leave to
file a compliance plan hinging on actions
of a third party (FEQ),
This we cannot do. Furthermore, the unortho-
dox manner in which Edison chose to amend its prayer for relief is
highly questionable (in a closing brief)
.
The record, as it pertains
to Sabrooke,
is
fairly complete and may be used in any future proceed-
ings.
The
Board in particular takes
note of the testimony of Weeks,
Reeder, Estes,
and Galinsk,
all citizens of Rockford
who
attested
to
the nuisance generated by this facility.
The Board, however, realizes that Edison’s attempt to achieve com-
pliance was made in good faith and the failure of such compliance plan
was not Petitioner’s fault. We
will thus grant a short variance to
allow protection (subject to cOnditions)
,
while a resolution of the
FEO dilemma can be worked out.
It is realized that
by January
30,
1975, Edison can, if necessary, reinstitute
proceedings in the Sabrooke
matter and rely on the record generated in this proceeding.
Joliet Station:
This consists of
two
separate facilities which lie
on opposite sides of the Des Plaines River,
in
Will County, Illinois.
Units 5 and 6 are located on one side, while Units 7 and 8 are on the
opposite side of the river. The two complexes
are connected by an
overhead suspension bridge used to transport coal from the unloading
facilities
located on the Units 5-6 side of the river.
The plant is
about one mile
from
the
city
of Joliet and Units 7 and 8 adjoin the
community of
Rockdale,
Environmental_Impact:
As in the case of the Waukegan plant,
modeling data was discussed by both Fancher (Edison) and Melvin (Ill.
EPA)
The cross-examination
and assumptions used by both witnesses
followed the same lines as in Waukegan and they will not be detailed
in this section.
One major point, however, must be raised: Edison
bases its statistics
on Units 5 and 6 burning 3,5
sulphur coal and
Units 7 and 8 burning low-sulphur coal by May 31, 1975 (4/22/74, H.
84)
.
Melvin Ex. 2 seemingly uses the same assumption (see Ex. 2, TahIa
The following are results geherated by Edison’s study:
(uq/rn3)
24—hr.
~1r. Melvin’s study reveals
the
following:
1.
Under fumigation conditions,
the plant has the potential
to violate the 0.5
secondary ~
standard (see
M-2 Table
14)
2. Under fumigation conditions,
rj1~~t~
7 and 8 have the pot-
ential to violate
the short-term particulate standards (see
M—2 Table 17).
3. Under normal conditions, the
expected
contribution to the
24-hr.
air quality with wind direction aligning Units 5
and 6 with Units
7 and
8
is
as foi:Lows:
0.06 ppm ~
(Standard 0.14)
30 ug/ra3 part. (Standard 260
ag/in5)
Table 17
from
Melvin Exhibit 2 has been included in
this
Opinion so
that the method of presenting data is available for
examination (Fig. 2:.
*Once again,.
the reader is
reminded that
this series
ot studies re-
flects
the
contribution of the plant or:
the air
quality.
In the Joliet
area, the
oercent of
load
from
Edison is not as great
as
it
was
in
Wauke—
qan. There are about 11
majo:r SO2 sources
in the
general Joliet area
(200+ tons SO;,’yr.) between Lemont on the north and Channahan
on
the
south. Total emissions from Edison are
srojected
at 153,113 tons/yr..;
~son’s
contributions
are
57.5.
~ must also be noted
that these fig-
are from the Ill, EPA emission inventory and reflect
emissions
prior ~
:1975.
It is quite possible
~in
the case of Edison reduction
pur-
suant ~ compliance plan) that both the total emissions and Edison’s
con—
Unit.
Emission
Rate #/:nBTU
Average
Cone.
s--ar
.
5 (1
i (1
stack)
stack)
Part.SO2
502
Part.
6.60
0.08
6.60
0.19
3515
4.4
357.9
10.5
1.6
126.5
3,7
6
502
Part.
6.60
0.12
243.. 3
4.2
86.1
1.5
~°2
Part.
2.10
0.90
74,3
32.3
26.3
11.3
S
502
Part.
2.10
0.90
74.3
32.0
26.3
11.3
Total
SOPart,2
7:15.9
73,0
253.0
25.7
Standards
SO~
Pa~t.
1300
-
365
260
15— 29
SWINARY OF
CALCULATRO CONTRIBUTION
TO Asm:EuT
MS OJJITY
~p
•~,
V~’~r~~0LOGICALcONDITIONS
FACILITF .Joliet Units 7 & 8
FIGURE ~2
POLLUTANT Particulates
(ugsr3)
5Three”hour average
Wind~peed Class (Knots)
Cumulative Frequency Distribution of axheum Rourly
Particulate Concentr~tion~fot the
Atmospheric
C
..‘~,..~ •~-
1—3
4—6
7—10
11—16
17—21
21
94
128
Stability A
2
a*************s ****s**a*****sa**********ss**sa*s*54*****a*,***a**s****,**a,
34
68
85
Stability 3
11.5
5.3
3.7
1.110
•
2.233
1.575
s****~,s******* ***k*~’’*****a*****as*s****s*a**a*a***********s*s*s***a*****
26
43
60
68
68
68
Stability C
15 13.5
8.6
6.1
4.9
4.4
1.055 2.472
6.232
.952
.034
.021
*,.,*,****s****
~*****s*************,a*s**a***a*aa*****ss****ss*,**a*s*aa*ss
9
9
9
17
17
17
Stability D
15
15
15
15
15
15
1.657 9.705 20.868
19.382
2.438
.555
****,*********s
**********a*5**a*~*********5****,********s*********,’**aa,ss*~
00
0
Stabi1ityE&~
——
7,082 15.862
6.061
**a*a*********e s****a*****s*****a**aaa*a****aaaaaaa*ae**~*a~****,**a***aa**#
196
222
Trapping
3.~
2,8
Stability ~B
——
——
a****a******s*a
*********************5*a****5****,.~*****,s**5*Ca*****5****.’.
63
68
Trapping
15
15
Stability 0
——
seas assess aces
* *******~***** ***********a*e* *5*5*55*5*5*5*5*
sassass,esasesas
*
554
264
Fumgation
*
2
.3
Stability 8
—
s*s****s*a***s,
~a***s***a,***se****as****s***aa**sa*aa*a*****a***e***a**a**
100
80
S.
U
0a
a
40
20
0
.
,~
~-
1_±11
0
KEY
30
60
90
120
Particulate Conceat~atjons (u~~~’3)
Wiudapeed
Class (Knots)
Atmospheric
Class
—
Naxicum
Concentration
—
Location of Maxis~asConcentration (Kilometers)
—
Frequency of Occurrence (Pcr~.ent)
150
!\BLE 17
From a review of the data oresented,
it
us clear to the Board that
tna short-term SO standard may be violated.
Edison itself projects
s maximum of itJ,~ ug/m3 at worst conditiors
This is ~out
69,5
of
tIe 365 ag/rn3, 24-hr. standard.
When considering the length of
Edison’s
compliance pan for
SO2
reduction at this pl’3n~.., shis potential viola-
ton iill be kept ~irrnlv in mind,
At hearing cn this faciiity,
Mrs John Keigoer datailed the huis-
ance generated by the Joliet plart.
Mrs. keiqher lived in the neigh-
nor: ood for 13 years and contends that t~e problem has gotten worse
a cry year.
She feels that Edison Is no.: wothing quickly eiough to
solve the problem.
Mrs. Keugher reg.Lstexed cc plaints as .~o how the
air q’ality affects her children, one of
whom is an asthmatic (H.
139).
The complaints registered nave all tne chara~teristics of a Section
9(a)
~omplaint and,
as such,
portray a serious nuisance problem. This sit-
uation further prompts the Board to expedite aoy proposed compliance
niar
A discussion of the individual units at Joliet will now follow.
Joliet S is a 117 mm unit fired by two cyclone boilers burning 3.5
sulphur coal.
It is anticipated that this
3.5
coal will be used
aft-
er May 31, 1975, thereby necessitating
a variance from Rule 204. Part-
iculate data
indicate that no variance from Rule 203 (g) is required
~‘ancher
Ex.
J—1).
Edison’s proposed compliance plan calls for the installation
of
an
SO3 injection system on both boilers to be installed during October
1975. Edison has recently completed installation of
new boiler tubes
on both boilers (see discussion on
Waukegan) to solve the problems
of
carbon carryover.
Modifications are also in progress to upgrade
the
coal crushing equipment.
The Board feels that this compliance
plan is
reasonable and will
endorse
it.
It
is therefore anticipated that Jol-
iet 5 will be in full
compliance
with both Rules 203 and 204
by
mid-
October 1975.
Joliet6
is a 344 mw unit fired by a cyclone boiler burning 3.5
sul~r coal. It
is anticipated
that the 3.5 sulphur coal will be
in
use after
May 31,
1975.
Emission of about 6.64t/rnBTU will
necessitate
variance from Rule 204. Particulate
testing indicates that no variance
from Rule
204 (g) is required
(Fancher Ex. J-l)
Edison’s proposed compliance plan calls for installation of a flue
gas injection system with design starting in January 1975 and complet-
ion in March 1976. All parties agree that this compliance plan
is a
viable one, and the plan would bring anout compliance in the shortest
possible time.
The question facing the Board is the reasonableness of
the
time frame.
Under cross—examination, a long exchange was undertaken
detailing why the March 1976 deadline was reasonable.
We will not de-
tail the exchange, but refer to 4/22/74, R. 33-48, H. 58-75.
-~
-~-~-
~-~-
,
—~
ibutron will change drasticaliy
by l97~. Tru~~snote simply reveals
status prior to 1975.
15—
31
—
24
—
After careful deliberation
on the above exchange, the Board feels
that Edison’s proposed timetable is excessive. While it would be ben-
eficial to Edison
from a cost standpoint to delay design work, it is
evident that this work must be done and the major components
will be
the same, no matter what the result of the design work.
The Board sees
no justification for not starting work on
this program immediately,
with a target startup
date of December 1975.
Joliet 7 and 8
are
617 mm units fired
by dry-bottom boilers burning
puliT~c~l~
Both
units burn low-sulphur coal with emissions cal-
culated to be no higher than
2.l#/m.BTU and, with the
coal
used, should
meet the l.8#/rnBTU standard
the majority of
the time. A
variance is
thus needed to allow the slight abridgement and will be granted. Part-
iculate data show a 0.9#/mBTU level, which would require variance.
Edison’s compliance
plan again calls for the installation of a flue
gas injection system on both units. Work is scheduled
to commence in
June
1975, with compliance brought
about by October 1976.
Once more,
discussions centered on the time
frame rather than the method of compli-
ance. The
references detailed above (4/22/74, R, 33-48, R. 58-75) are
the point
in the record in question.
Once again, the Board finds that
Edison’s compliance schedules are unduly exaggerated,
and therefore we
will condition our variance on a shorter time frame. The Agency has sug—
gested (Brief Pg. 38) June 1976 as a reasonable
date. The intervenor
has suggested (Brief Pg. 33) December
31, 1975. In light of the amount
of work required and the size of the units involved, and being cogniz-
ant of the environmental impact of these units, the Board must agree
the Agency that June 1976 is a reasonable date.
Powerton
Station:
The Powerton Station i-s located about one mile
sou~~TP~in,
Illinois.
It is located on the southeast bank
of the Illinois
River.
At this time, there is only one unit in opera-
tion
(P.
5)
.
This unit burns high-sulphur Illinois coal which
is
washed down to about
3.7 sulphur. The unit is equipped with an ESP
which was rated at
99,5 efficiency. Testing shows that
the unit meets
the
1975 particulate regulations when burning
the
3.7
sulphur coal.
However, compliance with Rule 204
is not anticipated
by
1975.
Environmental Impact: As mentioned
under
the Waukegan Station,
the subject of environmental impact was covered by Fancher (Edison) and
Melvin (Ill, EPA). The results of
their studies follow:
15
—
32
Fancher Ex. P—i:
_________________________*Unjt
Emission
Emission#/MBTURate
Average3-hr.Conc.
24-hr.ug/m3
5
SO
6.8
230.35
81.4
Pa~t.
0.05
1,7
0.6
SO2
6.8
230.35
81,4
Part.
0.05
1.7
0.6
Total
So2
460.7
162.8
Part.
3.4
1.2
Standards
SO2
1300
365
Part.
260
Melvin Ex.—2 draws the following conclusions:
1. Under trapping conditions, Powerton 5 and 6 indicate violations
(Pg. 13) of the 3 hr. standard.
2.
Under normal conditions
there will be no violation of the 24-hr.
SO2 standard.
3, In a study conducted to determine the effect of a large point
source in a major metropolitan area (Peoria) it was found
that Powerton 5 could be anticipated to contribute a signifi-
cant portion of the S02 in the area, for example, at the maxi-
mum receptors.
Receptor
Total Expected Read.
Powerton
5
Cont.
Mr. Jay
2
31
Norco also
testified
1000565
569 ug/m
ug/m
ug/m3
3
3as
to the effect of252
309
525each
ug/m
ug/mug/mEdison
3
33
plant
on air quality. Norco Exhibit #2 was entered to show the difference
in
the air quality
if Edison were to be in compliance
vs.
if
they were not
in compliance by 1975. The validity of the assumptions was challenged
upon cross—examination, and again distracted from its credibility. How-
ever, the Board feels that the exhibit has much value as an indication
of what Edison’s contributions
to the total contaminant loading would
be, and has used this as part
of its consideration on all stations. The
Norco Exhibit 2 will
be included in this Opinion as Fig. 3.
The Board feels that Powerton has the potential to exceed
the short-
~standardsandwilltai1oritsOrdertoreducethis
impact.
*Once again,
it is
noted that this is the contribution of the plant.
Ed-
ison contributed about 65 of the SO2 in the Peoria area. Subject to change
after
1975.
**Unit 6 is not a subject of this Petition. However, it is anticipated
15
—
33
FIGURE
3
~.NNTALAVCB~P.IR QU1~LITYCONCE2~TPATICNS
POINT OF MAXI?dJM CrNTRIBUTICN FRCM EDISON SOU21ES
May
30, 1975
Commonwealth •Edisor
PCB 74—16
Norco Exhthit
2
~iegan
5-8
:11th 5—8
r~mrton5
0-maid 1
&
2
_________
1975
EX~~TEID
~
~nC~
(ug/m3)
P21. STD,*
(up/rn3)
ppj, ma.
40.46
1.31
1.96
2.45
40.45
1.29
7.65
9.56
40.12
.34
6.9
8.62
40.1
.29
7.21
9.01
_________
1975 1~LIL~V\BLE
______
5p3c-—-oTusrnaTr
r~~zmm~mmr
(ug/rn3)
P21, SID,
(ug/rn3)
PRI.SID~
40.16
.46
1.30
1.63
—
—
2.14
2.68
—
—
1.83
2.29
—
—
3,64*5
455
Ccerparisons ~2 oniy
Conc, D~~’5iI3T7~5
3)
.66
.82
5.51
6.88
5.07
6.33
357
4.46
* For per ticulates, the assumed background is 40 ug/rn3 Geometric Mean. The ~x,ntribution
of Edison sources is,
therefore, calculated
as the
of th~difference bstween the
standard (75) and ths backgrcund (40),
or
35.
“~
Exhibit
10
of
Edison’s Petition had assumed a 6,0 1.bs/M3t~sulfur dioxide croission
limitation; with
the
current
stack height of the
Kincaid Station, Rule
204
Ce) limits
sulfur
dioxide emissions to
4.34
lbs/NBtu. This Ethibit reflects the lca.’er
limitation.
Primary
.‘tinual
Air Quality
Standards:
Particulates
—
75
ug/rn3 (gecreatric mean)
Sulfur Dioxide
-‘
80
ug/m3 (arit1inetic mean)
—
26
(Discussions below on SCS and blending reflect this,)
As mentioned in the previous section of this Opinion dealing with
coal gasification, the Board feels that
while
the program for
compliance
suggested by Edison is a good one, the timetable may be excessive. In
answer to a question raised in the section of this Opinion of F.G,D. (e.g.
will Edison’s rejection of F,G,D, lead to undue delay and environmental
damage?), the Board feels that in light of the problems of F,G,D. sys-
tems, the potential for development of a viable alternate (coal gasifi-
cation), and the possibility of an SCS system to “shave the peaks” of
short—term excursions over the standards, Edison’s compliance plan is
acceptable.
The date for completion and what interim steps are to be
taken are the
only questions
left to be answered.
Supplementary Control Systems: No long discussion of this item is
needed. Th ulk of this subject was covered earlier in this Opinion.
The Board finds that an S.C.S. system is potentially a viable approach
to
be followed on
an interim basis. Our Order will condition variance
upon the undertaking of a
cooperative effort~betweenEdison and the
Illinois EPA with the expected end result the operation of a workable,
enforceable S.C.S. system.
~~l~i~fls:
Certainly another option open to Edison is the blend-
ing of coal to achieve a reduction of SO2 until permanent controls can
be installed. Mr. Hoffman (IEPA Electric Utility Specialist) testified
as to the feasibility of this option (5/10/74). Mr. Hoffman pointed
~aut that the methods of segregation of coal and conveyor belt mixing,
or layering coal,
could be used
(R,
31). It was also pointed out that
such
methods are now in use by Edison at the
Waukegan and State Line
facilities (R. 33)
Mr. Ramey (7/11/74) was called by Edison to discuss the problems in-
volved with coal blending. The major points center around the diffi-
culty of securing additional supplies of low-sulphur coal. Further com-
plicating
the matter is the subject of
contracts for coal which Edison
now has for Powerton.
In its Brief,
the Agency asks the Board to condition any grant of a
variance on (among other things) a study of coal blending at Powerton.
The evidence elicited
at hearing
indicates that
coal blending is not a
feasible alternate and that conducting such a study would serve no
use-
ful purpose.
Date of Compliance: The Agency suggests (Brief
Pg. 41) that a compli-
ance date
of
early 1980 would be reasonable for a coal gasification
plant.
The Board agrees.
There is no justification
for the delay pro-
posed by Edison.
Much design work can begin earlier than proposed by
Edison. Compliance by 1980 is a reasonable date, and we
will so
condi-
tion our Order.
to start in late 1975.
If it were to
start
up uncontrolled as
to SO2,
the above predicts
the combined
impact on air quality.
15
—
3b
Kar~caid Station
The Kincaid Stat~on is located approximately four
mil~~h~town
of Kincaid, christia~ Coonty, Illinois
The pia~t
is located on the chores of Lake Sar~gchris, which was impounded ~or the
use of this plant,
The station consists of t-~o 616 mx coal-fired units,
each fired by a B &
W
cyclone boiler.
Each bo~1er is equipped with a
cual Research-Cottreil
ISP and discharges through twin 500’ stacks
ESP
efficiency
tests while
burning high-sulphur (4.1 sulphur) coal showea
results well within
Rule 203 specitscations
Thus, no varianco from
Rule
203 is required.
CoaJ is supplied by Peabody Coal Co. from Mine #10, which .:s 1ocated
adjacen~ t
he station.
The plant is cons dered a mine—mo~th tacil’ty.
P
otd in
e reduction of sulphur, ddison has contracted
w.tn
Peabody
~avu all of the coal washed,
Washing facilities are expected
co cost
n~illion and will be
paid for
by Teabody
These facilities
are expect-
be
operable by November
1975. The following results are expected
a.~..terwashing at a 25 volume loss:
Moisture
Ash
Sulphur
BTU/#
Raw coal
14.5
15.7
4,2
9,730
Washed doal
17.5
8.7
3.5
10,340
When analyzing Rule
204 it
is apparent that Rule 204 (e)
is the most
restrictive (comparison with 6.0#/mBTU). Allowable emissions are
4.34#/mBTU as per Rule 204 (e)
.
If
one assumes an average heat value
of 10,000 BTU/#, it is apparent that Kincaid ~o2 emissions will be 8.4#/
ruBTU
until November 1975 and
7,0#/mBTU after November 1975. Thus, a
variance is required.
Environmental Impact: Due to
the relatively isolated location of
the~I’~aidplant, its environmental impact can be considered as a sin-
gle entity rather than
as one
source among many. This situation allows
for more accurate predictions as to effect, less complicated impact ass-
essment, and lends
itself to an S.C.S. system which would predict
and
prevent short-term violations.
Once again,
Fancher (Edison)
and Melvin
(IEPA) entered evidence as to the potential impact of Kincaid’s dischar-
ges on the environment.
Questions as to assumptions used were similar
to those raised in Waukegan and will not be reiterated.
The following
results were reported by Fancher:
Unit
____
Emission
Emission#/mBTURate
Average3-Hr.Cone, ug/m24-Hr._________3
1
SO2
8.60
373.7
132.1
Part.
0.05
2.2
0.8
2
502
8.60
373.7
132.1
Part.
0.05
2.2
0,8
Total
SO2
747.5
264.2
Pirt.
1,5
Standards
SO2
1300
365
Part
260
(Fancher Exhibit K—I)
15—36
Melvin Exhibit
#2
projects the following:
1. Under trapping conditions, Kincaid indicates violation of the
3-hr. SO2 standard (indicates 0,74 ppm
-
M. Ex.-2, Pg. 13).
2. Under fumigation conditions, violations of the 3-hr. SO2 stand-
ard are also projected.
3. No 24-hr. violations have been projected, although worst case
analysis was not made.
it is the Board’s opinion that adverse environmental impact can
be
kept to an absolute minimum at this station by the installation and
op-
eration of a viable S.C.S. system~
Edisn’s compliance plans for this Station call for the installation
of coal gasification units, with anticipated completion dates of 1982
and 1983. Other considerations included: building a taller smoke-
stack to reduce the limitations of Rule 204 (e). This was rejected
because of the fact
that
the 6#/nBTU level could still not be
obtained.
Edison again alleges that low—sulphur coal could cause damage to the
cyclone boilers, and also that such a supply is not available.
The
problems with transportation and logistics were also cited. (Kincaid
burns about 3 x 106 tons of coal per ydar
,
from Melvin Ex. 2,)
There is very little argument that coal gasification
is a viable
~echno1ogy
to pursue at Kincaid.
The questions again center around
the length of the compliance plan.
Edison proposed to defer work
on
K-i and K-2 until P-5
is well underway. There is no doubt that this
conservative methodology is preferable from Edison’s point of view,
but we
must balance the delay against the potential adverse environmen-
tal
impact. We must also not
lose sight of the enornious projected
costs for
these units, according
to Edison’s figures:
Powerton 4
$19,000,000
Powerton 5
$65,895,000
UNIT Investment
Kincaid I
$48,415,000
(Fancher Ex.
6 Ed,)
Kincaid 2
$48,415,000
The Board at
this time feels the compliance dates can be moved up
significantly. We again express our feeling that preliminary design
work can start before massive funds are committed, We will, however,
not tie our variance
to a
firm
date at
this time, but will
rather use
the condition of an S.C.S. system to insure maintenance of the air
quality in the area.
Summary: The
Board will issue a very complex Order in this matter.
T1.i~~ue
to
the extremely complex nature of the system involved.
In
writing this Order the Board has very carefully considered all of
the evidence presented.
We have then weighed all
of
the
aspects in-
volved in
this case. The environmental impact, technology, economics,
~d
good faith efforts
have all been considered. The Board finds that
ile Edison has indeed been the forerunner
in new technology (e.g.,
ill County scrubber, Powerton gasification),
this leadership is re-
quired so as to meet
the mandate of the citizens of Illinois
as voiced
15—37
--
29
—
by the State
Legislature when they adopted the Environmental Protect-
ion
Act. Such
efforts are, in fact, to be expected of a major utili-
ty company, and Edison is indeed by far the
largest electric utility
in the
State.
The Board further finds that in many instances delay
was a tool used to forestall the installation
of equipment when technol-
ogy could have been pushed. It is mainly
for this reason that the
Board has trimmed the dates on the various compliance plans.
We are
also very much aware of the enormous sums of money which will be ex-
pended to bring about compliance. We are further aware that this cost
will
eventually be borne by the consumer in the form of increased elec—
tric bills. This cost to the consumer is the price for the clean air
he ordered when supporting the Environmental Protection Act and the
Federal Clean Air Act.
In many instances compliance plans run beyond
the one—year term
granted in this variance. It
is
the intent of the Board to carefully
review the facts in any future proceeding and act accordingly. It is
also the intent of this Board
to do everything it can to
insure the
viability of these compliance plans.
To allow undue delay, to not fol-
ow
up
on
such delay, would truly be to turn our back on our
responsibil-
ities.
This Opinion constitutes the findings of fact and conclusions of law
of the Board.
ORDER
IT IS THE ORDER of the Pollution Control Board
that:
1. With respect to the Waukegan Station, Unit 5:
a) Variance is granted from Rule 3-3.112 from October 15,
1974,
to May 31, 1975.
b) Variance
is granted
from Rule 203 (g) from May 31, 1975,
to
October
15,
1975.
Subparagraphs (a) and (b) above
are
conditioned on the use
of
both
the Unit 5 and the Units 1, 2, and 3 electrostatic precipitators at all
times that Unit 5 is operating. Subparagraphs (a) and (b) are further
conditioned on the conducting of stack tests to be performed within
60 days from the date of this Order. Said stack tests shall be per-
formed in the presence of Agency personnel, if the Agency desires. Re-
sults of said stack tests shall be submitted to the Agency and the
Board within fifteen days
of
the completion of such tests.
c) Variance from Rule 204 is granted from May 31, 1975, to
October 15, 1975, subject to
the
following conditions:
i) Edison shall not emit sulphur dioxide in excess of
3.0#/MBTU.
ii) The installation of an SO3 injection system no later
than December 31, 1975.
d) This entire Order I is further conditioned upon the followin~
15—38
—
30
—
i) Within 30 days from the
date
of this Order, Petitioner
shall submit to the Agency a detailed schedule for in-
stalling a flue gas conditioning system on Unit
5. Said
schedule shall include
as a minimum: dates
for obtaining
contracts, date of beginning design, date of
completing
design, date
of scheduled delivery, date of
outage for
installation, and date of completion of said system.
ii)
Petitioner shall
submit quarterly reports to the Agency
detailing work performed and progress made during the
previous quarter and
work to be performed in
the follow-
ing quarters.
iii) Within fifty
(50)
days of
the date of this Order Petit-
ioner shall submit a
performance bond to
the Agency
in
the amount
of
$35,000.
Said bond shall insure completion
of the flue gas conditioning system by the date detailed
above in Order 1 (c) (ii),
iv) Edison shall continue to maintain and operate the
moni-
toring system as ordered in PCB 73-40. All data generated
by said system shall be submitted to
the Board and the
Agency as soon as it is available, but in no event later
than six weeks after the last day of any month.
v) Edison shall apply for all necessary construction and op-
erating permits.
2.
With
respect to the Waukegan Station Unit 6:
a) Variance is granted
from Rule
3-3.112 from October 15, 1974,
to a maximum of 30 days after Petitioner receives the fabri-
cated furnace tubes from Babcock and Wilcox, but not later
than June 30, 1975.
b) Variance is granted from Rule 203 (g) from May 31, 1975, to
October 15, 1975, subject to the following condition:
i) Edison shall operate Unit 6 only after boiler modifications
are completed, which would consist of as a minimum the
installation of the new specially fabricated furnace tubes,
c) Variance is granted from Rule 204 from May 31, 1975, to Oct-
ober 15, 1975, subject to the following conditions:
i) Order 1 (c)
Ci) ,
1(d) (i)
, 1
(d) (ii) 1(d) (iv) and
1
(d) (v)
shall
be
reapplied
to
Unit 6.
ii) The installation of an
SO3
injection
system no later than
February 1976.
iii) Within
fifty
(50) days from the date of this
Order, Pet-
itioner shall
submit a performance bond to the Agency in
the
amount of $20,000, Said bond shall insure completion
15
—
39
—
31
—
of the flue gas conditioning system by the date detailed
above in Order 2 (b)
(ii).
3. With respect to the
Waukegan Station Unit 7:
a. Variance is granted from Rule 3-3.112 from October 15,
1974,
to May 31, 1974.
b. Variance is granted for Rule 203 (g) from May 31,
1974, to
October 15, 1974.
c. Subparagraphs (a) and (b) above are conditioned in
that Wauke-
gan Unit 7 shall
be operated above 153 mw only after
all
other
available Edison capacity has been
utilized except Edison’s
fast start
peakers and Sabrooke Units
1
and 2.
d. Variance
from Rule
204 is granted from May 31, 1975, to
October
15, 1975, subject to the following
conditions:
1)
Orders 1(c) (1) , 1(d) (ii)
1(d) (iv) ,
and
1(d) (v) shall be
reapplied to Unit 7.
ii)
Petitioner shall install a hot electrostatic
precipitator
no later than December 1976.
iii) Within 30 days from the date of this Order, Petitioner
shall submit to the Agency a detailed compliance program
and project completion schedule for the installation
of
a new hot
ESP. The schedule shall include estimated
dates of ordering equipment, delivery of equipment,
inst~-
ation of equipment, and startup of equipment.
iv)
Within fifty (50)
days
of the date of this Order, Petitioner
shall submit a performance bond
to the Agency in the amount
of $150,000. Said bond shall insure completion of the hot
ESP.
4. With respect to Waukegan Unit 8, the Petition for Variance is dis-
missed.
5. With respect to the Sabrooke
Station Units 1 and 2, variance is
granted from Rule 3-3.112 until January 30, 1975, subject to
the
following conditions:
a)
Sabrooke Units 1 and 2 shall be operated only after all avail-
able Edison capacity has been utilized,
including Waukegan
7.
However, one of the Sabrooke units (1 or 2) may be operated at
the minimal level necessary to provide steam for water deminer—
alizers, heating the station, or to prevent stack deterioration
in the event that Units 3 or 4 cannot be used for such purposes.
6. With respect to the Joliet Station Unit 5:
a) Variance from Rule 203 is dismissed.
15 —40
—
32
—
b) Variance from Rule 3-3.112
is
dismissed.
c) Variance from Rule 204 is granted from May 31, 1975, to Oct-
ober 15, 1975, subject to the following conditions:
i) The installation of a
flue gas conditioning system
no
later than October
15,
1975.
ii) Within 30 days from the date
of
this Order, Petitioner
shall submit to the Agency a detailed schedule for in-
stalling a flue gas conditioning system. Said schedule
shall include as a minimum:
dates for contracts, begin-
ning design, completing design, date of scheduled deliv-
ery, date of outage of equipment, and date of completion
of said system.
iii)
Petitioner shall submit quarterly reports
to the Agency
detailing work performed and progress made during the
previous quarter and work to be performed in the following
quarter.
iv)
Within fifty
(50) days
from the date of this Order, Pet-
itioner shall submit a performance bond to the Agency in
the amount of $35,000. Said bond shall insure completion
of the flue
gas
conditioning system by the date detailed
above in Order 6(c) (i)
v) Edison shall apply
for all necessary construction and op-
erating permits.
7.
With respect to the Joliet Station Unit 6:
a) Variance from Rule 203 is dismissed.
b) Variance from Rule 3-3.112 is dismissed.
c) Variance
is
granted from Rule 204 from May 31, 1975, to October
15, 1975, subject to the following conditions:
i) The installation of a flue gas conditioning system no
later than December 15, 1975.
ii) Within 30 days from the date of this Order, Petitioner
shall submit to the Agency a detailed schedule for in-
stalling a flue gas conditioning system. Said schedule
shall include as a minimum: dates for contracts, begin-
ning design, completing design, date of scheduled deliv-
ery, date of outage of equipment, and date of completion
of said system.
iii) Petitioner shall submit quarterly reports to the Agency
detailing work performed and progress made during the
previous quarter and work
to be
performed
in
the follow-
ing quarter.
15—41
iv) Within fifty (50) days from the date of this
Order,
Petitioner shall submit a performance bond to the Agency
in the amount of $65,000. Said bond shall insure com-
pletion of the flue gas conditioning system by the date
detailed above in Order
7 (c) (i)
v)
Edison shall apply for all necessary construction and
operating
permits.
8. With respect to the
Joliet Station Units 7 and 8:
a) Variance
from
Rule 3-3.112 is granted from October 15, 1974,
to May 31, 1975,
b) Variance from Rule 203 is granted
from May 31,
1975, to October
15, 1975.
c) Variance from Rule 204 is granted from May 31, 1975,
to October
15, 1975,
to allow
sulphur dioxide emissions
up to
2.l#/14BTU.
The above Orders 8(a)
,
(b)
, and
(c) are conditioned upon the
following:
i)
The installation
of
a flue gas conditioning system on
Un-
its 7 and 8 no
later than June 6,
1976.
ii) Within 30 days from the date
of
this Order, Petitioner
shall submit to the Agency a detailed schedule for install-
ing a flue gas conditioning system. Said schedule shall
include as a minimum: dates for contracts, beginning
de-
sign, completing design, date of scheduled delivery, date
of outage of equipment, and date of completion of said
system.
iii) Petitioner shall submit quarterly reports to the Agency
detailing work performed and progress made during the prev-
ious quarter and work to be performed in the following
quarter.
iv) Within fifty
(50)
days from the date of this Order, Pet-
itioner shall
submit
a performance bond to the Agency in
the amount
of
$200,000. Said bond
shall insure completion
of the flue gas conditioning system by
the date
detailed
above in Order 8 Cc) (i)
v) Edison shall apply for all necessary construction and op-
erating
permits.
9.
With respect
to the Powerton Station
Unit 5:
a)
Variance from Rule
3-3.112 and Rule 203 is dismissed.
b) Variance
from Rule
204 is granted
from May
31, 1975, to October
15, 1975, subject
to the
following
conditions:
15 —42
—
34
—
i)
The installation
of a low BTU coal gasification plant
to
fuel Powerton 5 by May 1980,
ii) Within thirty (30) days from the date
of
this Order,
Ed-
ison shall begin a
study
regarding the installation and
use of a supplementary control system at the Powerton
plant. Such study shall seek
to
conform to the general
guidelines of Federal Register, Vol. 38, No. 178, P.
25698, September
14,
1973. Edison shall seek the aid
of the Agency in this matter and shall file a report of
its findings with the Agency and the Board within four
(4) months of the date of this Order.
iii) The Board retains jurisdiction to reopen hearings on the
subject of S.O.S. on
its
own motion, or the motion of
any other party during the term of this variance. Such
hearings may result in further orders regarding the in-
stallation and operation of such
S.O.S.
systems. The
Board may also issue any further orders regarding the
proposed S.C.S, without holding hearings
if
it deems nec-
essary.
iv) Within 30 days of the date of this Order, Edison shall
submit to the Agency a detailed compliance plan, Said
plan shall detail the proposed steps and dates for in-
stallation of a pilot gasification plant for Powerton 4,
showing compliance no later than October 1976. Said com-
pliance plan shall also detail the expected dates and
steps to be undertaken towards installation of the coal
gasification plant for Powerton 5.
v) Edison shall
submit
quarterly reports detailing its pro-
gress completed during the previous quarter and its ex-
pected progress during the following quarter.
vi) Within fifty (50) days from the date of this Order, Edi-
son shall submit a bond in the amount of $1,000,000.
Said bond is to insure the installation of the Powerton
4 pilot unit by October 1976, and the Powerton 5 gasifi-
cation plant by 1980.
vii) Edison shall apply for all necessary construction and
operating permits.
10. With respect to the Kincaid Station Units 1 and 2:
a) Variance from Rule 3—3.112 and Rule 203 is dismissed,
b) Variance from Rule 204 is granted from May 31, 1975, to Oct-
ober 15, 1975, subject to the following conditions:
i) Plans to burn only washed coal at the Kincaid Station
shall be continued,
with
its use commencing by
i~ovember
1975.
15
—43
ii)
Edison shall within six (6) months of the date of this
Order file a compliance plan with the Agency for the in-
stallation of a coal gasification
unit for Kincaid I and
2.
Said plan shall inclade an a.iticipated date fcr com-
pletion of this project,
Such date will be reviewable
by the Board at any future requests for variance as re-
gards these units.
iii) Within sixty (60)
days from the date of this Order, Edi-
son shall submit to the Board and the Agency a he-ailed
proposal
for
implementing a supplemental control system
at the
Kincaid generating statior. Such plan snail fol-
low the general guidelines of Federal Register, Vol. 38,
178, P25698, September 14, 1973. The Agency shall with-
in 30 days of the receipo of such proposal submit to the
Board its comments
on said proposal. The Board shall
maintain jurisdiction in this matter and may schedule add-
itional hearings at the
request
of any party
or
upon its
own motion on
the
proposed
S.O.S. The
Board may also
is-
sue any
further Orders regarding the proposed S.O.S.
with-
out holding hearings if
it deems
necessary.
iv) Within
fifty (50)
days
from the date of this
Order
Edi-
son shall submit to
the
Agency a performance bond
in the
amount of $100,000 to
insure
compliance with Order 10
(b) (i) above.
Mr. Henss dissents.
I, Chrastan L. Moffett, Clerk of the Illinois Pollution Control
Board, certify that the above Opinion and Order was adopted by
the
Boand on the 3rd day of January,
1975,
by a vote of 4 to I.
di
__
15 —44