ILLINOIS
POLLUTION
CONTROL
BOARD
April
5,
1984
OLIN
CORPORATION,
Petitioner,
v.
)
PCB 83—46
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
siR. JEFFREY
C.
FORT, MARTIN CRAIG, CHESTER
& SONNENSCHEIN, AND
MR. GEORGE H.
PAIt’~, OLIN CORPORATION, APPEARED FOR THE
PETITIONER;
!~R.PETER E.
ORLINSKY, ATTORNEY AT LAW, APPEARED FOR THE RCSPONDENT.
OPINION AND ORDER OF THE BOARD
(by B. Forcade):
On March
31,
1983,
Olin Corporation
(“Olin”)
initiated this
proceeding with a petition seeking an alternative sulfur dioxide
(“502”) emission limitation
for its Joliet Plant.
At the same
time,
Olin filed
a variance request, PCB 83—44,
seeking a tem-
porary alternative SO2 emission limitation until this proceeding
is decided.
On August 18,
1983 the Board denied Olin’s variance
petition.
On June 8,
1983, the Illinois Environmental Protection
Agency (“Agency”)
filed a recommendation supporting the alternative
c~riissionlimitation requested by Olin in this proceeding.
On
June 16,
1983,
a hearing was held in Joliet, covering both the
variance proceeding and this proceeding.
In addition to witnesses
for Olin and the Agency,
six members of the public testified.
On
August
18,
1983,
in an Interim Order, the Board required
~n additional hearing to obtain information concerning maximum
qround
level concentrations of SO2, prevention of significant
deterioration
(“PSD”)
increments, and to allow Dr.
Herman Sievering
the opportunity to testify.
On January 20,
1984, the additional
hearing was held.
Olin filed a memorandum supporting the alter-
native limitations on February 15,
1984.
On February 8,
1984,
the Agency waived additional filings.
The F~i~
Olin’s Joliet Plant produces sodium phosphates,
fertilizer,
and sodium florides.
Olin produces sodium phosphate by the wet
57-327
acid process.
This requires ev
ut
approximately 600
gallons of water per minute
(R
~i.
p.
28).
*1
Approximately one half of the water is evaporated by direct
contact with heated air, and one half
is evaporated by indirect
contact with steam,
The steam needed
for this process (225,000
pounds per hour)
is generated by
3 coal—fired boilers.
Boiler
No.
1 has its own stack,
Boilers No.
2 and No.
3 have a common
stack.
Relevant information is presented below:
Boiler
#1
Boiler
#2
Boiler
#3
TYPE
Babcock and Wilcox Chain Gate Stoker with
4 drum sterling design
Max.
Steam Load
80,000
100,000
100,000
lbs ./hr.
Max.
Heat Input
104.0
141.7
141.7
I3TU/hr.
Common Stack
Stack Diameter
6,0 ft.
9.0 ft.
Stack Height
125 ft.
150 ft.
The three coal-fired boilers were designed to burn Illinois
coal containing approximately 3.5
sulfur.
Illinois coal was
burned until
1972
(R
#1
p.
32),
At that time, the boilers were
converted to burn low—sulfur coal, and presently burn coal from
I~entuckyand Indiana which has a 1
maximum sulfur content
(Pet.
p.
5).
Olin has requested an alternative SO
emission limitation
so that they may return to burning Illinois goal.
Olin has
stated that the switch to Illinois coal will not increase
particulate emissions
(R #1 p. 33).
Regulatory Framework
Emissions from Olin’s facility are presently governed by 35
Ill.
Adm. Code 214,141, which limits
SO2 emissions to 1.8 lbs./MM
*/ The record and transcript of the variance petition
(PCB
83-44) were admitted by stipulation into the record of this pro-
ceeding at the June
16,
1983,
hearing.
Thus, there are three
transcripts with no consecutive pagination.
For clarity the
transcripts will he cited as follows:
(1)
R #1
—
June
16,
1983
variance hearing, PCB 83—44;
(2)
R #2
—
June
16,
1983 site—specific
hearing, PCB 83—46;
(3)
R #3
—
January 20,
1984 site specific
hearing, PCB 83—46.
57-328
3
Btu.
Pursuant to Section 214.201, facility owners or operators
may petition
the
Board
for alternate emission limitations of up
to 6.8 lbs./MM Btu, provided they can demonstrate that the proposed
emission rate will not,
under predictable worst case conditions,
cause or contribute to a violation of any applicable primary or
secondary SO~ambient air standard or applicable PSD increment.
The regulatiMns o~concern in this proceeding are as follows:
35 Ill. Mm. Code
____
Section
Substance
106.301 et seq.
Procedures for obtaining relaxed
SO2 emission limitations
214.141
1.8 lbs.
S02/mm btu emission
limitation
214.201
Standards for obtaining relaxed
SO2 emission limitations
243.122
Ambient 502 standards
Olin
has
requested
an
emission
limitation
of
6.1)
lbs
SO,/M~
Btu.
Since this
is below the 6,8 limitation of Section 214.~01
and would enhance
the
use
of Illinois coal,
the emphasis shifts
to the impact of the requested emissions.
ENVIRONMENTAL IMPACT
In
March,
1983,
an air quality assessment was prepared for
Olin to determine the impact of burning coal with a
higher sulfur content.
The model
in this assessment was based on
an Agency model which was approved by TJSEPA to demonstrate
attainment for
SOS, in the Joliet area.
The Agency used a worst
case model meteor~iogicalyear (1975),
and an Olin emission rate
of 1.8 lbs.
SO
/MM
F3tu including background concentrations.
The
Olin model usea this data as a basis to determine the additive
effects of incremental
emission increases from the boilers using
higher sulfur coal,
Operating parameters were obtained from the
permits on
file with IEPA ~Pet,
Ex.
A,
p.
3).
The
Agency
testified that Olin’s model was
“more
conservative
than would
normally
be
required”
(R,
#1
p.
117),
and that the air
quality
study adequately
demonstrates that the boilers operating
at a 6.0 lbs SO
/MM T3tu emission
rate would not cause a violation
of either the 2~hour primary or the 3 hour secondary National
Ambient Air Quality Standards
(‘~NAAQS”)established by Section
243.122
(Rec.,
p.
2).
The model predicted,
for a worst case situation, maximu~
3—hour and
24—hour
concentrations of 1091.~2and 316.94 ug/m
SO2, respectively.
Olin
made no contribution to those levels
(Ex.
25,
Table
1),
since they occur upwind of Olin’s facility.
57-329
Prior to
1975,
the
Olin
boilers
were
equipped
to
burn and
did
burn Illinois coal
(R #1,
p.
32).
Pursuant to 40 C.F.R.
par.
51.24
(h)(2)(iii)(e),
Olin’s
switch between coals with different
sulfur contents
is not
a
major
modification,
and
is
exempt
from
the PSD regulations.
However, qlin’s maximu~3—hour and 24—hour
incremental
increases
(232 ug/m
and
75
uq/m
,
respectively) ~re
well below ~he standards
that
otherwise might apply
(512 ug/m
and
91 ug/m
,
respectively
(Ex.
23)).
The Board finds
that
the
requested emission rates for Olin’s
Facility
will
not
cause
or
contribute
to
violations
of
ambient
air
quality
nor
exceed
any
PSD
incre!r~ents
that
might
otherwise
apply.
Prior
to
the
August
18,
1983 Order,
the Board received a
public
comment
from
Dr. Herman Sievering concerning severe adverse
environmental consequences
of relaxed emission limits.
At the
January
20,
1984
hearing Dr. Sievering testified and was cross—
examined.
At
hearing,
Dr.
Sievering
admitted
that
he
had
assumed
several
Facts
to
be
true7
and that given these were incorrect,
he
would
change
his
opinion
(R.
48-50,
55—57,
61).
A key assumption
was the degree
of
exposures
His
original statements were based
on
an exposure of
220 uq/m
302
to 300,000 people for a time
period of one year
(R.
#3,
21,
35).
This
exposure
is far
in
excess
o~ actual.
The
maximum
single
24-hour
SO
level ~‘esulting
from
Olin’s
increased
emissions
is
estimated
at
~32
ug/rn
SO2.
The affected population
~.s~inproximately2000
(R.
84).
After revising the assumptions
Dr. Sievering testified
that
any
increase
in
the
probability
of
premature
death
would
he
so
small
as
to be masked b~the level
of
uncertainty in the calcu-
lations
(R #3,
p.
60).
The
Board
finds that granting
Olin
a
relaxed SO
emission
limitation
will
not
have
~ui
adverse environmental ef~ect. The
Board
notes
that
the
maximue
pre~icted
24—hour
concentration
to
which
Olin contributes
(232
ug/m
)
is3wel.l
below
the
maximum
~~~cted
SO.,
concentration
(316
ug/rn
)
to
which
Olin
does
not
contribute
(Ex.
25,
Tahi:
1),
Section
9,2
of
the
~ct
allows
relaxed
SO
emission
limitations
to
encourage
the
use of
11 1:inois
Coal.
Olin
~as
repeatedly
stated
its
intention
to
purchase
Illinois
Coal
if
this
petition
is
granted
(Pet,
¶ 2(a(2);
R
#1,
p.
13;
R
#2,
p.
24;
Pet.
Br.,
p.
1),
usage
is expected
to he
about
100,000
tons
per
year
(R
#1,
p.
55).
Mr.
Gerald
Hawkins
of
the
United
Mine
Workers
testified
that
granting
Olin
a
higher
emission
limitation
for
SO~would
result
in
approximately
30
laid-off
coal
miners
being
re—employed,
30
new
supporting
jobs
and
over
$3,500,000
contributed
to
the
Illinois
economy
(R
#1,
p.
51),
The
Board
will,
grant
Olin
the
requested
emission
limitation
oF
6.0
lbs.
SO2!fl~1Btu.
The
Hoard
intends
compliance
to
he
57-330
5
measured by 35
Iii.
Adm,
Code 214.101(c).
This Opinion constitutes
the Board’s findings of fact and conclusions of
law in this
matter.
ORDER
Olin Corporation is hereby granted an alternative
limitation
for sulfur dioxide emissions from its three coal—fired boilers at
the Joliet, Illinois facility of 6.0 pounds per million British
Thermal Units of heat input pursuant to 35
Ill. Mm. Code 214.201,
subject to the following condition:
Within 30 days of the date of this Order,
Olin
Corporation shall
apply to the Illinois Environmental
Protection Agency for a revision of its operating
permit for its Joliet facility’s boilers consistent
with
this
Opinion
and
Order.
IT
IS SO ORDERED.
I, Christan L.
Moffett, Clerk of the Illinois Pollution
Control Board,
hereby certify that ~he above Opinion and Order
was ~do~ted on
the
~
day of
___________,
1984 by a vote of
QAct~4~it
Christan L. Mo
~Jt,
Cleric
—
Illinois Pollution Control Board
57-331