ILLINOIS POLLUTION CONTROL BOARD
September 27, 1974
COMMONWEALTH
EDISON
COMPANY
PETITIONER
PCB
74—11
ENVIRONNENTAL
PROTECTION
AGENCY
RESPONDENT
RICHARD POWELL, ATTORNEY,
ISHAM,
LINCOLN
&
BEALE,
in
behalf
of
COMMON—
WEALTH EDISON COMPANY
MICHAEL GINSBERG, ATTORNEY,
in behalf of the ENVIRONMENTAL PROTECTION
AGENCY
MARVIN MEDINTZ, ATTORNEY, representing the PEOPLE OF THE STATE OF ILL-
INOIS, INTERVENOR
OPINION AND ORDER OF THE BOARD
(by Mr. Marder)
This action involves a request for variance filed January
4,
1974,
by Commonwealth Edison, seeking relief from Rule 3-3.112 of the Rules
and Regulations Governing the Control of Air Pollution and Rule 203
(g)
of chapter
2, Air Pollution Regulations.
The variance request pertains
to Edison~sWaukegan and Sabrooke power generating facilities.
This matter was consolidated for hearing with PCB 74-16, which is a
one-year request for Variance for Edison~sfive facilities.
The combined
record is very comprehensive, and a complete opinion on this matter will
be incorporated within the Board~sopinion on 74-16,
A brief discussion of each unit at the two stations is in order at
this time.
Sabrooke #3 and #4 have either been converted to oil or are presently
down for such conversion.
Thus no variance is required for these units.
Sabrooke #1 and #2 were also scheduled for conversion to oil.
How-
ever, on November 27, 1973,
the Federal Government published regulations
forbidding the use of oil in units which were presently coal-fired. Ed-
ison~sappeal of this regulation was denied when the State Environmental
Protection Agency did not certify that the conversion of Units
1 and 2
to oil was needed to maintain the primary air quality.
Edison has now
appealed to the Federal Government, and that appeal is
still pending.
Large sums of money have already been spent by Edison in preparation
for
conversion
of
Sabrooke
Units
1 and 2.
This sudden turn of events
was certainly beyond Edison~scontrol, and variance will be granted.
13
—
681
—2—
Waukegan
#8 is presently running with
a flue gas conditioning system.
The purpose of this system is to allow the burning of low sulphur coal
while retaining top efficiency of the electrostatic precipitator, This
concept utilizes liquid SO~flue gas injection.
Although it is hoped
that Unit #8 is presently in compliance, the novelty of the technology
and the recent startup of the process would suggest that
a variance
would be in order.
Because this technique
(SO.~injection)
is a major part of Edison’s
future compliance plans, the ~oard would encourage the running and test-
ing of Unit
#8 so as to expedite future compliance plans.
Waukegan #7,
6,
5:
Unit
#5 was planned for a shutdown by about September
15
(R. 4/15/74
Pg.
10).
This shutdown was anticipated to facilitate duct work modifi—
cations between the ~xisting Unit
5
ESP and the unused Unit 1,2, and 3
ESP (Units
1,2, and 3 had been previously retired by Edison),
This shut-
down was to ~encompass
the
approximate
period
of
September
15 to November
15.
According to efficiency tests on this unit,
the modifications will
increase capture efficiency from about 65
to about 90
or from 2,0#/xm~
ETU to 0.5*/mm BTU,
(See Ex. W—l.)
Unit
#6
is presently controlled by an ESP which allows emissions of
from 0.402
-
0.181 #/mm BTU while running on 2.4
sulphur
coal
(See Ex.
W-2).
Compliance plans
call for SO3 injection to be completed by June
1976.
Unit
#7 is
presently
controlled
by
an
ESP.
The unit, when burning low
sulphur coal
(1.9),
has a very low capture ef~ficiencyand a high rate
of particulate escape
(from 1.27 to 1.87*/mm BTU).
~Unit #7 is a fair-
ly large
(338 mw)
unit and will therefore contribute a total load in ex-
cess of 3720#/day of particulates at full load.
Compliance
for this unit is the installation of a new “hot” ESP with
a shutdown date
(for installation)
of October 1976.
As
mentioned
above
the
instan.t
matter
has
been
consolidated
with
PCB
74-16.
Because of the complexity of the situation and the need for
lengthy hearings in the combined matters, the Board has previously grant-
ed interim variances
(at the Petitioner’s request)
up to and including
October
4,
1974.
Therefore this order can only grant variance from
October
4, 1974,
to October 15,
1974,
The Board has in the past expressed serious concern
over the impact
upon the citizens of Edison’s emissions in the Waukegan area.
In an
attempt to get a firmer grip on the actual air quality surrounding the
Waukegan station, the Board ordered the establishment of a nine—station
air monitoring network.
Edison informed the Board that this network was
put into operation on April 17, 1974.
When the last interim extension was granted by this Board
(see August
13—682
—3—
.1,
1974,
Order)
,
we expressed concern
as to the lack of data from the
monitoring network and stated:
“The Board again emphasized that the availability of
air
quality
data
was
a
key
consideration
in
the
original
varianc~grant.
This provision was specifically included
to allow for public notification of high pollutant levels,
and to allow the Agency and Edison ~o take immediate cor-
rective actions.
By not supplying such information Edison
made this decision much more difficult
for the Board.
This
Board will carefully review
thb
complete record on PCB 74-il
to ascertain why such data was not available,”
(PCB
74—li, August
1,
1974,
Pg.
6)
A
review
of
the
74-il,
16
record,
including
final
briefs,
shows
the
record
to
be
silent
on
the
subject.
However,
on
September
24,
1974,
Edison
filed
with
the
hearing
officer
a
Motion
to
Include
Data.
This
Motion
would
have
included
said
data
with
the
record
of
74-11.
The
hear-
ing
officer
did
not
rule
on
this
motion
prior
to
our
final
action
in
this
matter,
and
it
thus
could
not
be
considered
in
our
deliberations.
Fur-
thermore
it
was
found
that
Edison
had
indeed
filed
monthly
reports
with
the
Board,
and
the
reports
were
filed
under
PCB
73-40.
The
Board
still
maintains
that
the
proper
course
of
action
would
have
been
to
file
the
data
in
the
record
during
hearing,
and
discuss
on
the
record
whether
such
data
would
have
aided
the
Board
in
its
decision.
Lacking
this
data
the
Board
has
no
way
of
using
real
time
information
to
assess
the
impact
on
the
community,
and
must
turn
to
modeling
data
in-
stead.
Were it not for the very short duration of this variance, the
Board would deny Edison’s request for a variance regarding Waukegan on
this
point
alone.
However,
in
light
of
the
short
duration
of
this
vari-
ance, we feel it better to grant the variance and condition the same on
a clear definitive order regarding the submission of all available data
to the Board as well
as the Agency.
In making this decision the
Board
has
relied
on
the data provided by
the Agency and Edison regarding projected
air
quality.
Melvin
Exhibit
#2 was instrumental in this decision.
Table 13 of such exhibit relates
Edison’s
predicted
contribution
to
air
quality
from
the
Waukegan
station.
A
review
of
this
table
shows
potential
violations
of
the
three
hour
stan-
dard about once every three years under fumigation conditions.
However,
these predictions are based upon emission data which are somewhat higher
than one would expect to exist on October
4,
1974.
Unit
#8 was projected
at 0.427#/mm BTU, while with flue gas conditioning the figure is more
likely 0.07*/mm BTU.
Unit
#5 is projected at 1.27*/mm BTU, while there
is an excellent possibility that the unit will be shut down on October
4,
1974, and thus will generate no particulates.
Taking all into account the Board will grant conditional variances
for Waukegan units
6,
7 and
8.
No variance will be granted to Unit
#5.
13—683
—4—
Although the lack of variance will not force Edison to shut down Unit
#5,
it is the intent of the Board by this denial to prod the conversion
of Unit #5 to
a dual ESP system. We are aware that this unit may already
be
down, and as such a variance would not be required.
In writing this Order, the Board is aware that Powerton 1-4 will be
retired during October 1974.
However, we do not know the exact shutdown
date, and for purposes of this Order we will assume that Powerton l—4
will be running up until October 15, 1974.
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.
Variance for Sabrooke Units
#3 and #4
is dismissed as moot.
2.
Variance is granted for Sabrooke Units
#1 and #2 until October
15, 1974, from Rules 203
(g) and 3—3.112.
3.
Variance for Waukegan Unit
#5 is denied.
4,
Variance is granted for Waukegan Units
#6,
7, and
8 until October
15, 1974,
from Rules 203
(g)
and 3—3.112.
The above variances are conditioned on the following:
A)
Waukegan Unit #8 shall
run
in the normal sequence of Edison’s
system
capacity,
provided
that
Edison
make
every
reasonable
effort
to
continually
operate
its
SO3
injection
system.
B)
Data
as
to
the
effectiveness
of
the
SO3
injection
system
shall
be
supplied
to
the
Agency
and
the
Board
by
October
15,
1974,
C)
Waukegan
Unit
#6
shall
be
operated
only
after
all
available
Ed-
ison capacity has been utilized (including Waukegan #8), but be-
fore Powerton Units
1 to
4, Sabrooke 1 and 2, Waukegan
7, and
Edison’s
fast
start
peakers
are
utilized.
D)
Sabrooke Units
#1 and 2 shall be operated only after all available
Edison capacity has been utilized, including Waukegan 8 and 6,
but
before
Powerton
Units
1
to
4,
Waukegan
7,
and
Edison’s
fast
start
peakers
are
utilized.
However,
one
of
the
Sabrooke
units
(1 or
2)
may be operated at the minimal level necessary to provide
steam for water demineralizers, heating the station, or to prevent
stack deterioration in the event that Units
3 or
4 cannot be used
for this purpose.
E)
Waukegan Unit
#7 shall be operated only after all available Edison
capacity
has
been
utilized,
including
Waukegan
8
and
6,
Sabrooke
1 and 2, but before Powerton 1
to
4
and
Edison’s
fast
start
peak-
ers are utilized,
13—684
—5—
F)
Edison
shall
continue
to
maintain
and
operate
its
nine—station
network
of
air
quality
monitors
as
ordered
in
PCB
73-40.
All
data
generated
to
date
shall
be
submitted
to
the
Board
by
October
15,
1974.
Data
submitted
during
the
period
of
this
variance
shall
be
submitted
to
the
Agency
and
the
Board
by
November
1,
1974
G)
The
bond
required
in
Condition
6
of
the
Board’s
Order
in
PCB
73-40
(Opinion
date
October
4,
1973)
shall
remain
in
full
force
and
effect
for
the
duration of this Variance,
I,
Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board,
certify
that
the
above
Opinion
and
Order
was
adopted
by
the
Board
on
the
~“7”~
day
~
1974,
by
a
vote
of
____
to
~
13—
685