ILLINOIS
POLLUTION CONTROL BOARD
February
24,
1983
IN THE MATTER OF:
)
CITY OE ROCHELLE:
)
R78-15
SITE SPECIFIC LIMITATION FOR
)
TOTAL SUSPENDED PARTICULATE MATTER
)
~jated
Rule.
Final Qpinion.
OPINION AND ORDER OF THE BOARD
(by
I.
G.
Goodman):
On November
13,
1978 the City of Rochelle (Rochelle)
filed
a petition to amend Rule 203(g)(l)
of Chapter
2:
Air Pollution
to include a particulate emission limitation for the emissions
exhausted from the stack at its Municipal Steam Power Plant,
located on South Main Street.
Specifically, Rochelle requested
a limitation of 0.6 pounds per million British thermal units
(lhs/mBtu)
of actual heat input.
When Rochelle proposed amending Rule 203(g)(l),
adoption
of the same had been vacated along with Rule 204(c)(1) (Common-
wealth Edison v.
Pollution Control Board,
62 Ill.2d 494,
343
N.E.2d 549 ai~Thsh1andChemical v.
Pollution Control Board,
64 Ill.
App.3d
169,
381 N,E,2d
56)..
Therefore, once docketed
this proposal was consolidated for hearing with R78—16,
a Board
inquiry reviewing the rules on total suspended particulates
(TSP).
On August 21,
1980,
R78—l6 was dismissed,
Other than this pro-
posal by Rochelle, no steps were taken to adopt particulate
li~ciitationsfor fuel combustion sources until
R82-1 was insti-
t~itedby the Board.
Since further action
in R82—l awaits receipt
of
an economic impact study,
Rochelle’s source
is not currently
subject to a specific TSP emission limitation.
Consolidated with R77—15,
R78—14, R78—l6 and R78—17, hear-
ings were held for R78—l5 on January 24,
1979 in Springfield,
January
30,
1979
in Chicago, February
7,
1979
in Peoria and
April
17,
1979
in Chicago.
After receiving the economic impact
study from the Department of Energy and Natural Resources
(then
the
Institute of Natural Resources) entitled “Economic Impact of
Sulfur Dioxide and Particulate Matter Regulations
in Illinois,
R77—l5,” Doc. No.
79—22, hearings were held on January
29,
1980
in Chicago, January
30,
1980 in Peoria and February
13,
1980 in
Chicago.
The record closed on March
17,
1980.
Rochelle proposed this site—specific regulation primarily
due
to
the Illinois Environmental Protection Agency’s
(Agency)
permitting policy in light of the Illinois Supreme Court decision
vacating Rule 203(g)(1).
This policy,
as set out
in “Guidelines
for the Performance of Air Quality Impact Analyses to he Used in
5 1-209
2
Support of Permit Applications,’ was to grant permits if sources
demonstrated either compliance with
the
terms
of
vacated
Rule
203(g) (1) or compliance
with
ambient, air quality standards
(Petition, pg.
2).
This
policy led
Rochelle to conduct stack
tests to determine compliance with vacated Rule 203(g)(i)(B)
and modeling studies to determine its contribution to ambient
air concentration levels of particulate matter.
The stack test
report, dated October, 1977, showed Rochelle’s contribution to
be an average emission rate of 0.418 lbs/mBtu or less.
Since
the
maximum
rate allowable
based
on Rule 203(g)(i)(B) is 0.18
lbs/mBtu, Rochelle is petitioning for a site-specific rate of
0.60 lbs/mBtu.
The city’s plant produces electric
power
for its 12,000
consumers and produces
process
steam
for
a
Swift
and Company
facility.
tts
two steam
boilers
vent to a
common
stack
and have
maximum rated capacities of 100,000 lbs/hour at 100 million Btu
per hour of heat input
(R.
376).
Particulate matter emissions
are presently controlled through the use of mechanical collectors
(western precipitator multiclones) having 90
efficiency, taken
together, when the boilers
are
operating at full loads
(R. 377,
393, 398, 405).
Initially, Rochelle conducted six stack tests to determine
compliance with the 0.18 lbs/mBtu limitation.
All resulted in
violations of that limit (Exhibit 5).
The stack tests were then
averaged
to
provide
a
basis
for
modeling.
Unfortunately,
the
stack tests
had
not been conducted
with
the boilers operating
at
full
capacity,
contrary
to
standard
testing
procedures.
Therefore
the
actual
results
were
ratioed
‘up’
in
an
effort
to
characterize full
load
results.
This was apparently done on the
assumption
that
a given increase in heat input produces
another
given increase in steam and a corresponding increase in emission
rates.
The record reflects contrary opinions as to the success
of such extrapolation
(R.
400—405, 415—416).
Using
the
Posnt
Source Diffusion Model (PSDM) Rochelle
further
determined
the
maximum
concentrations
of
TSP
contributed
to
the
ambient
air
solely
by
its
source.
Worst
case
emission
rates were utilized
to
predict
conservative
ground
level
TSP
concentratations.
Sequential
calculations
were
made
for 256
receptors located at various points ranging from 0.5 to 25.0
kilometers from the stack
(R.
387—388).
This modeling indicated
that
maximum
TSP
for
the
24_ho!r
standard
contributed
by
the
Rochelle
facility
is
13.6
ug/m
,
less
than
11
of the secondary
standard
of
150.0
ug/m
.
This
impact
was
predicted
to
occur
within
1.5
kilometers
southwest
of
the
plant.
The
maximum
ca&—
culated annual contribution of the Rochelle plant is 2.3 ug/m1,
which is
about
4
of the secondary annual standard of 60 ug/m’.
This
impact
was
predicted
to
occur
within
1
•
5 kilometers north
of the plant
(R. 388—389).
51-210
3
To further qualify the modeling results, Rochelle conducted
a
monitoring
program,
intended
primarily
to
determine
background
values in the plant impact area.
Monitoring at the modeled
northern
impact
point
resulted
in
no
violations
of
the
annual
anbient air quality standards for TSP, and only one violation
of the 24-hour standard.
The latter was attributed to
nearby
road
construction.
Rochelle conceded that control technology, either electro-
static precipitors (ESP) or baghouses, were available and
that
installation would facilitate compliance with the 0.18 lbs/mBtu
limitation.
Installation of baghouses was not considered by
Rochelle as a means to comply with the limit
(R. 394—5); instal-
lation of ESP’s was considered, not as a substitute control mech-
anism,
but
instead as a means of further controlling Petitioner’s
existing cyclones
(R.
421).
The capital cost to install ESP’s was
estimated at $1.4 million in 1977 dollars, or at a minimum average
cost of $100 per customer.
These figures do not appear to be off—
set by monetary contribution by Swift and
Company as the primary
industrial user in the area.
The Rochelle facility is located in Ogle County
which
is
designated attainment for
TSP
at 40 CFR 81.314.
The surrounding
counties,
Lee
and Boone, are likewise listed.
However, the coun-
ties of DeXalb, Winnebago, specifically Rockford Township, are
listed as non—attainment for the secondary standard.
In January,
1982
the
Agency
proposed
that Rockford Township
and
the Dexalb
County
townships,
except
Dexalb
and Mayfield
townships,
be
redesig-
nated
as
attainment
for
the
TSP
secondary
standard.
Redesignation
of
Rockford
Township
was
based
on monitoring done in that township,
whereas
redesignation
of
the
DeEalb
County
townships
was
based
on
monitoring
and
modeling
done
in
nearby
townships.*
During
hearings,
DeTcaib Township, which did not then qualify for redesignation, was
of particular interest since it is twenty miles directly
east of
the Rochelle plant.
Petitioner refuted any contribution by the
Rochelle facility to the non-attainment status stating that it
is
‘obvious
that if no violations are predicted at 10 kilometers...
there would be no excursion for a receptor 20 kilometers away
(Exhibit 35, Part 1, pg.
2).
Additionally, the Illinois Environ-
mental Protection
Agency
(Agency)
stated that
it
did
not
consider
Rochelle’s source to significantly contribute to ambient air
concentrations, and that the rural area of Ogle County is not
bothered by an air quality problem
(R. 424).
In post hearing
public
comments
the
Agency
stated that the relaxed limitation
‘would
not cause the air quality problem.’
Over
the course of the years
two
monitoring
stations
have
been operated in DeRaIb Township.
The monitoring results (Annual
Air Quality Reports 1977-1981) are set out in the chart below.*
51-211
4
Annual
Geometric
Annual
Statistics
lea
!~Sa!~es
Mean
Viol
ations
~1503
2603
75
60
ugim
ugim
ug/m
ug/m
Total
(Primary)
(Secondary)
1
(Primary)
(Secondary)
1977
43
1
435
103
91
56
0
0
1978
34
1
0
168
111
110
+
1979
26
0
0
133
96
92
+
+
1979
14
0
0
95
78
66
+
+
1980
29
0
0
92
84
81
+
+
1981
54
0
0
129
109
98
53
0
0
200
S.
4th
St.
650
N.
1st St.
Insufficient
data to determine annual geometric mean
Unfortunately, the statistical data for three
of
the
five
years
was insufficient to establish a geometric mean for eight
consecutive quarters, which is necessary for DeKaib
Township,
and
nearby Mayfield Township to be proposed for redesignation.
Since this annual report,
additional monitoring
data has
been
gathered which supports redesignation.
In January of 1983 DeKalb
Township and Mayfield Townships were proposed for redesignation.*
Since
the Rochelle facility has been operating at or near the
proposed emission limit and no violations of the standards have
been monitored,
Petitioner’s statement that its source does not
impact DeKaIb appears valid.
The Rochelle stack
is the only major fuel combustion emission
source in Ogle County emitting particulates
(R,
396),
Keeping
in
mind
that the modeling performed was conservative
and premised
on
a limit of 0,60 lbs/mBtu,
the combined data from the
stack tests,
the PSDM and site~specificmonitoring indicates that
should the
liriitation requested be granted, violations of the
ambient air
quality
standard will not result.
However, in granting Rochelle emission limit more
relaxed
than
that presumably required by other such sources, the Peti-
tioner
will consume a portion of the Prevention
of Significant
Determinations
(PSD) increments.
Therefore,
Rochelle
was
directed by the hearing officer to submit its estimation of the
amount of
PSt) increments would be used up by this regulation
(R.
411).
The estimation was to be based upon the
emission rate
used
as input
in the PSDM rather than the facility~sactual
emission rate.
This information is contained in Exhibit 35.
Nevertheless, since no baseline has been established for
any
areas affected by the Rochelle source,
PSD increment
consumption
is
not sufficient reason to deny Rochelle a re~axed
site—specific
limitation~
*This information is taken from Agency publications
unavail-
able at hearings in this proceeding.
The Board takes
official
notice of these publications
in order to update air quality
information pertinent to this petition.
51-212
5
This rule was published for First Notice on November
19,
1982
in
6 Illinois ~~~ster
14456
—
14458.
On January
6,
1983
the Agency filed comments raising three
issues, which Rochelle
responded
to on January
10,
1983.
No other public comments were
filed.
i~t
the outset the Agency questions whether the record
which the Board based
its decision on was sufficiently current.
Primarily the Agency is concerned that the supporting clocumenta—
tion offered by Rochelle at hearing may now be insufficient to
support a revision of the State Implementation Plan
(SIP) by the
tinited States Environmental Protection Agency (USEPA).
Acknowl-
edging that a SIP revision is necessary after a rule change,
this
proceeding, however,
need only justify a site—specific
rulemaking
by the Board.
The analyses and documentation necessary for a
SIP
revision,
in this instance, can be provided to the Agency and the
USEPA during the SIP revision process.
In
its response, Rochelle
agreed that any additional
information needed pertaining
to the
SIP petition will he provided.
Lastly,
the Agency retracts its support for the proposed
limitation of 0,60 lbs/mBtu because
it is greater than the plant’s
actual emissions,
and again because it is not sufficiently docu-
mented for the purpose of a SIP revision.
As stated above,
any
deficiencies
in the SIP demonstration can be cured at that time.
In support of the more restrictive limit proposed
in its comments,
the Agency relies on undocumented permit information and further
analysis of the stack test results.
The Board’s decision to
grant
0.60 lhs/mBtu was
likewise premised on the stack tests,
but
it was also premised on the modeling performed by Rochelle.
The
modeling demonstrated that emissions up to 0.60 lbs/mBtu would
not
jeopardize air quality.
The Board finds the evidence provided by Rochelle’s modeling
and monitoring sufficient,
despite the questionable practice of
extrapolating the stack test results to full
load capacity, to
demonstrate that this proposed regulation will not degrade the
attainment status of Ogle County or other nearby attainment areas,
The economic evidence indicates that although the technology
is
available,
it is costly.
Swayed by evidence that the air quality~
and therefore the health or welfare of persons
in the immediate
vicinity,
is not jeopardized by the emission amount Rochelle
seeks,
the limitation of 0,60 lbs/mBtu is granted.
ORDER
The following language
is hereby proposed for adoption into
Chapter
2:
Air Pollution,
Part
II:
Emission Standards and
Limitations for Stationary Sources:
RULE 203:
Particulate Emission Standards and Limitations
(a)—(f)
Unchanged.
51-213
6
(g)
Fuel Combustion Emission Sources
(1)
Using Solid Fuel Exclusively
(A)
Existing Sources Located in the Chicago Major
Metropolitan Area——Reserved
(B)
Existing Sources Located Outside the Chicago
Major Metropolitan Area——Reserved
(C)
Exemptions for Existing Controlled Sources
Notwithstanding sub-paragraphs
(A) and
(B)
of this Rule 203(g)(l),
any existing fuel
combustion emission source using solid
fuel
exclusively, and meeting the following con-
ditions, may emit up to, hut not exceed,
the
limits set out.
(i)
As of ~p~il 14,
1972 the emission source
has an emission rate based on original design
or equipment performance test conditions,
whichever is stricter, which is less than
0,2
lbs/rnBtu of actual heat input,
and the
emission control of such source
is not
allowed to degrade more than 0.05 lbs/mBtu
from such original design or acceptance
performance test conditions, the rate of
emissions shall not exceed 0.2 lb~7ii~Eu
of actual heat input
or
(ii)
As of A~p~il
14,
1972 the source is
in full
compliance with the terms and conditions of
a variance granted by the Board sufficient
to achieve an emission rate less than 0.2
lbs/mBtu, and construction has commenced on
equipment and modification prescribed under
that program;
and emission control of such
sources
is not allowed to degrade more than
0.05 lbs/mBtu from original design or equip-
ment performance test conditions whichever
is stricter,
the rate of emission shall not
exceed
0.2
lbs/mBtu_2f
actual
heat
input
or
(iii)
As of
(the effective date of this Rule)
the rate of emissions_from Boilers
#1 and #2
located at the Rochelle Municipal Steam Power
Plant,
South Main Street, City of Rochelle
in Ogle County,
Illinois shall not exceed
0,6
lbs/mBtu of actual heat input.
51-214
7
IT
IS SO ORDERED.
Chairman Dumelle and Board Member Werner concurred.
I,
Christan
L, Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify tha~~he above Opinion and Order
was adopted on the
~fj~
day of
~7
t--&-~-’~-~-
,
1983 by a
vote of
~
I:!
/
~4p
~~___
Christan L. Moffett’,(~1erk
Illinois Pollution Control
Board
51-215