ILLINOIS POLLUTION CONTROL BOARD
September
1, 1977
ELECTRIC
ENERGY,
INC.,
)
Petitioner,
V.
PCB 75—106
ILLINOIS ENVIRO&MENTAL
PROTECTION
AGENCY,
Respondent0
MR. JOHN W.
ROWE,
ISHAM, LINCOLN
& BEALE and JOHN
C.
LOVETT,
LOVETT,,
LEWIS, JOHNSON
& SHAPIRO, APPEARED ON BEHALF OF ELECTRIC ENERGY,
INCORPORATED;
MR. MICHAEL GINSBERG, APPEARED ON BEHALF OF THE ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY.
OPINION AND ORDER OF THE BOARD
(by Mr. Goodman):
This matter is before the Board on a Petition filed February
28,
1975 by Eiec:ric Energy,
Inc.,
(Electric Energy)
requesting
variance from Rule 204(e)
of the Board’s Air Pollution Regulations
(Chapter 2)
and
certain other
rules with respect to its steam—
electric generating
station
at Joppa,
Ililinois.
In its original petition Electric Energy proposed to use an
Intermittent Control
System
(ICS)
and to control plant operation
through short-term io~dreductions to prevent the Joppa Station
from causing violations of air
quality
standards for sulfur dio-
xide.
The Illinois Environmental Protection Agency
(Agency)
recommended that the
Detition
for variance be denied.
Hearings
were held in this
matter on
May
14 and May 15, 1975 and the issues
were briefed by
both Darties
in June,
1975,
Prior to final action
on this petition by the Board
and
in response to Agency objections
to the proposed lOS System,
Electric Energy filed an amendment to
its variance petition on May 6,
1977.
In its Amended Petition
~9T
—2—
~1ectric
Energy
proposes
to
~mpLement
a
fuel
b’ending
program
and
to
construct
c.nd
p~
~o i~ s~’~ice
three
new
tal’
stacks.
In
its
consideration o
:hth~
rnatte~,
ti~e
Board
will
acidness
only the
May
6,
1977 ~~nendcd Varthnoe ~ethtion
filed h~’
Electric Energy.
On May 27~19~7tI~eAgenc’ rl~d
IrS
~n~:nad
Recommendation
concerning
E1ecrr~~cE~srgy!sPothticr,
Toe A~n~ystates
that it
worked
closely
with
E~eotnic
Erxnyy
rn
the
devslopment
of the
proposed
compii~nce
plan
for
th~
~
2e~1
~nd that this
plan
will
achieve
compliance
w~th
~
smthsion
ii~1~
rile of
204(e)
of
Chapter
2
as
expeditious~y
as
po~sible
In
addition to
the
ICS
Con~ro~f~ste.
~
the
presently proposed
tall stack-fuel
b1end~ng
~r~jra~~
F
~
~tric
~nsrgy
has
examined
a
wide
range
of
alternlti~’ecc~plia~c’~.
c~nams inrlu~ing
flue
gas
desulfur-
ization,
use
of
low
sulfur
foe~
an~ IHinois
coal
beneficiation
by
intensive
washing,
Coal supplier experimenth indicate
that
Illinois
coal
is not
capabJe of
be~n3 bs~efic~a~ed
‘~
~oshing
processes to the
extent
that the
Illinois
sulfir
a~a~ion
regulation
can
be
met
at
the
Joppa
Station with the current
chimney
height.
The
use
of
low
sulfur
fuel was rejected since
te3ts
~onducted by
Electric Energy
in 1975
indicated a unit derating
of aboat
25,
precipitator per-
formance
degrading of about
18
5
redaction in
boiler effi-
ciency,
an
increase of
4E
ir,
the
qaantlty
of
coal
required per
KWH
generated and reduction o~
l~
in
c~pac~tyof a
coal pulverizer
to
support
the generation operation
would
result.
(Amended
Petition,
p.9).
Of
particular concern to Ei~otric’ Energy is the
derating of its
relatively new
(1972) preci~itatots
whose
p~formance
generally
would
determine
the
minrmum
s
iifor
~nterc
thtt
could
be
tolerated
by Joppa
Station without ser~us deraFin~
r~f
the
StatioiYs
genera-
ting
capacity.
Electric Energy~sEngineering Consultants,
Sargent
& Lundy,
reviewed possible
me’ns
of
~o~pe
sating for
the
reduced
precipitator
performance
in’-luc3ing
o~d~ficat~on
of
the
existing
cold
side
precipitators
to operate as hot side
precipitators,
replacing
existing precipitators
wthh
re~
hot
side
precipitators,
and
adding
flue gas condition~ing
to
the
existing
precipitators.
They
found
that
the existing pre~ipitatorscould
not
be
operated
as
hot
side
precipitators, not only from a structural
capability
and
integrity
standpoint,
but
alsD
from
the
saa~öpoint
of
physical
size
of existing
units
with
respect
to
the
qas
contact
times
necessary
for
proper
collection of
particulate
matter
(Amended
Petition,
p.13).
New
hot
side precipitators
were
rejected
due
to
the
physical
limi-
tations
of
the
Station
with
regard
to
the
size
of its
hot side pre-
cipitator.
-~~\
—3—
The
physical
situation
at
Joppa
also
was
the
reason
flue
gas
conditioning
was
rejected,
as the
area of injection and distribution
of
chemicals
is
relatively
small
as
the
Joppa
Station
configuration
now
exists.
In
addition,
Electric
Energy
alleges
that
the
cost
of
derating
the
Station~s
capacit~
would
be
prohibitive
(Amended
Petition,
p.11).
Electric
Energy
has rejected flue gas desulfuri—
zation
as
a
viable
a:’,ternative
due
to the estimated expenditure of
$80,000,000
for
a
rower
olant whose
useful life might be as short
as
12
years
with
a 15
to
20
million
dollar annual operating cost
(Amended
Petition,
u.
8).
Althouh
the
Board
does
not
necessarily agree with Electric
Energy~sconclusions
concerning
the program proposed in the Amended
Petition,
the
proposed
program
appears suitable.
The projected
results of the
~rogram
not
only
indicate the achievement of compli-
ance
with Rule
204
(e),
but
the
projection
used
a
stack
height
of
407.3 feet, which
is
the
sugaested
guideline of two and
a half times
the height
of
adjacent
structures,
The
actual stacks, however, are
programmed to be 550 feen tall,
thus
injecting
a conservative factor
in
the
projected
results,,
In
addition
Electric Energy will establish
and
maintain
an
ambient
air
quality
monitor within two to three
miles
of
the
Poppa
Station
at
a
site
agreed upon between the Agency
and
Electric
Energy.
This
new
monitor,
along
with
existing
monitors,
will
provide
data
which
the
Agency
and
Electric
Energy
may
use
to
verify their
expectations
and models,
Electric Energy will,
of
course,
continue
to
follow
developments
with
respect
to
sulfur
dio-
xide
emission
control
although
they do
not believe.a research
program can
be
justified
considering
the
advancing
age
of
the
Joppa
installation.
There
was
~onsIderable
testimony
presented
at
the hearings held
pursuant
to
the
origin~.l
variance
petition
concerning
the
effect
of
emissions from
Jo~Pa
Station
on
the
area’s
air
quality.
Electric
Enerqy~scase
primari:Ly
nests on
modeling
done
by
Sargent
&
Lundy,
its
Consulting
Engineers
~p~1ectric
Energy Exhibits
1 through 20).
That modeling
shows
present
compliance,
using
2.7
sulfur
content
coal,
for
the
Joppa
Station,
on
both
the
three
hour
(secondary)
and
twenty-four
hour
(prinary~
standards
(Exhibit
5,
12,
and
20).
The
Agency,
at
t.hat time recommending
denial
of
the
variance,
presented
much
evidence,
by
way
of
cross-examination,
attacking the validity
of
Electric
Energy~s
modeling,
although apparently never stating that
Electric
Energy
was
causing
or
contributing to a violation of the
ambient
air
quality
standards,
The
Agency~
s
oriqana~
allegations
concerning violations of
twenty—four
hour
and
three
hour
standards in the area were based
primarily
upon
theoretical
meteorological
conditions which testimony
and
exhibits
indicate
are
unlikely
to
occur
(R.72).
In response to
the
questions
raised
by
the
Agency,
Electric
Energy
repeatedly
ppinted
to
the
conservative
nature
of
its
model
and
showed
the
unlike—
lihood
that
the
effects
of
Electric
Energy
and
another
nearby
power
plant
could
work together to produce any of the
violations
that
were
shown.
The Board finds that the weight of the evidence
indicates
that
it is not likely that Electric Energy
IS
now causing or
contribu-
ting
to
violations
of
the
air
quality
stanoards
in
the
area,
The Board
finds
that
Elerurac
Energy
h~.s made
a
good
faith
effort
in
attempting to develop a methoc wllLreby Joppa
Station
may
achieve
compliance with Rule
2~4~e),
A~t~n~
investigating
many
different methods of compliance, especia~yw~thregard to
the age
and physical configuration of tne Joppa Station, they
have
developed
a relatively economical and
efficIent
~cgrara
thdt
should culminate
in
compliance by October,
l2~i6.
The
Board
~inds
that
denial of this
variance
would
subject Electric Energy to an arbitrary
and unreason-
able
hardship
and will therefore grant
the
variance
requested
for
the
Joppa
Station
until
October
31,
1978,
under
certain
conditions.
This
Opinion
constitutes
the
findin~s
of fact
and conclusions
of
law
of the Board in this matter,
OPDEF.
It
is
the Order of the Illinois Pollution Control
Board
that
Electric
Energy,
Inc., be granted variance
from
Rules
103,
104
and
204(e)
of Chapter
2 of the Board~sRegulations
(Air Pollution)
for
its Joppa
Station until October
31,
1973
under
th~
following condi-
tions:
1.
Electric Energy shall execute the
compliance
program
contained
on
page
9,
10, and II of
Exhibit
9 of
its May
6,
1977
Amended Variance Petition
which
Petition is hereby incorporated by reference
as
if
fully
set forth herein,
2.
Electric Energy shall purchase and install
an
ambient air monitoring station at
a location
approved
by the Agency no later
tian
October
31,
1978.
3.
Within
30
days
of
the adoption of this
Order,
Electric
Energy
shall
execute
and
forward
to both
the
Illinois Environmental Protection Agency,
2200
Churchill
Road,
Springfield, Illinois 62706 and the
Pollution
Control Board a
Certification
of
Acceptance and
Agreement
to be bound to
all terms
and conditions of this
Order.
c7
—5—
The form
of
caid
certificatior
shall
be
ac
toYo~
I
(We)
fully
understai~iding~he Orderoft~flinoi~o~
o
t
Board
in PCB 75-106 hereby accept said Order ano
~ound to
all of the terms and conditions thereof.
Si GNB)
TITLI
I, Christan
L. Morfett, Clerk of the Illj
s
Ic
~ion Control
Board, hereby certify the above Opinion and Orce~
e acopted on
the
day
~
,
1977
by
a
~o
e
leo.
Christan
L.
Mo
Illinois P~
~or(-~6ntroi Board