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

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