ILLIN~I~POLLUTION CONTROL BOARD

August 30, 1982

IN

THE MATTER OF:

)

SULFUR DIOXIDE EMISSION

R80—22

LIMITATIONS:

RULE 204

OF

CHAPTER 2

)

Proposed Opinion.

First Notice.

OPINION OF THE BOARD

(by

I

G~Goodman):

This Opinion supports the Board Order of August

188

1982 in

this matter.

On December

1,

1980 the Board received the Illinois

Environmental Protection Agency’s

(Agency)

proposal to adopt

emission limitations for sulfur dioxide from fuel combustion

emission sources located within the three Major Metropolitan

Areas

(MMA)

of

St. Louis,

Peoria, and Chicago,

Also proposed

was a reduction in the emission limitations for process emission

sources located in the

St.,

Louis and Chicago MMAs,

The Agency

filed its proposal

in R77-l5 and R78—14, two ongoing regulatory

proceedings which had been consolidated for hearings.

R77-15 was

a site-specific rulemaking proposed by Ashland Chemical Company

(now Sherex Chemical Company,

Inc.) to amend Rule 204(c)(1)(A) of

the Board’s Chapter

2:

Air Pollution and finalized by Board Order

on December 17,

1981.

R78—l4 was an inquiry concerning Rule

204(c)(l)(A)

instituted by the Board and dismissed on January

8,

1981.

The Agency’s proposal was primarily a response to the

legislative mandate that it review the sulfur dioxide emission

limits for existing fuel combustion emission sources located

within these three MMAs and thereafter propose amendments con-

sistent with the Clean Air Act~sNational Ambient Air Quality

Standards program, which would enhance the use of Illinois coal.

(Ille

Rev. Stat,

1981,

ch,

111½, par.

1009.2).

On December 19,

1980

the Board docketed the Agency’s proposal to amend Rules

204(c)(l)(A),

204(d),

204(f),

204(h) and 204(i) of Chapter 2

as R80—22.

The Agency submitted revisions to the R80~-22proposal on

February 26,

1981, January 25,

1982 and June

1,

1982.

Public

merit hearings were held in East St.

Louis,

Peoria,

and Chicago

on February 26,

March 10 and

12,

1981,

respectively, and again

on June

1,

1982 in Chicago.

The Department of Energy and Natural

Resources

(ENR)

submitted the Economic Impact Study of the pro-

posed sulfur dioxide amendments, ENR Document No, 82/11, on

April

26,

1982.

Economic impact hearings were held in Chicago

and Peoria on June

1 and

22,

1982,

respectively.

The record was kept open for public comments until July

14,

1982.

The Village of Winnetka (Winnetka)

requested an extension

on July 12,

1982.

That motion is granted and the comments filed

48-37

---

by

Winnetka

on

3u1~ 30,

:~:~i,

arc.

~0

A~rtt~

p~iL1ic comment

period

for

fortv~i9e

da~’o

~

ri:~o

~ ~n

th~ r~iLc~s

proposed

by

the

Board

are

pub~

sh~~d

:~n ~r~’

~

‘~t

~iecr~st

~r

~or

First

Notice.

Emission

1_~r~

:c~on~

::o~

~

~t;~’

e~ir~u~ sources

were

among

the

first

air

reg~ a~

prc~u~qato2

~y

:he

Board

in

1972

Since

then

the

rule~ tor

tuel

o~rrbu~

tion

erniss±on ~curces

have

been

contested

&nd

are

C~5li

now

remanded

to

the

BoarcL,

Yet

in

these

ten

years

the

original

national

ambient

air

guL~t:itystan-

dards

for

sulfur

Yioxith~ have

renamed

sub~tantia1

~y

unchanged;

the

primary

annuel

st~o3~r~

has

osen

attained

statewIde

in

Illinois;

the

control

teebuologres

originally

considered

have

proven

feasib1e~

~snd

n~rnlisnc

with

the

orrqinal

Board

enission

limits

widely

ach~evud

~3h~onr~~

ooncern~

impacting

control

of

sulfur

dioxide

ha~’edeveloped

o~er

the

ten

year

span

The

need

to

utilize

more

dr~es~ri~.

tu~

has

become

apparent

for

a

healthy

economy.

This

realization

Ic

~spec~.ally

important

considering

Illinois’

reserves

of

h~rt

c;u~.ic: coal,

However~ it

is

also

probable

that

further

te

i~hion~

:~nsulfur

dioxide

emissions

are

necessary

for

a

health’i

enviionment.

~~ognizant

of

these

conflicting

deve1opments~

it

is

the

Board’s

intent

to

reconcile

them

as

much

as

:possih!s

in

e$tabiish:Lng

sulfur

dioxide

emission

limits

to

replace

those

voided

h’~ the

Courts~

These

limits

should

also

provide

for

the

atto:Lnment

and

maintenance

of

the

air

quality

in

Illinois

for sulfur nioxicie,

he noted, the history of

the

Board’s

regulations for sulfur dIoxIde is lengthy.

Therefore,

a

brief

summary

precedes the analysis of the rules~

As

stated

before~the emission limitations

for sulfur

dioxide

produced

by

solid

fuel

cOrnbust~on and

process

emission

sources

were

among

the

first

a:r

poduticri

rc~u1ations

promulgated

by

the

Board,

including those for the ~

Louis,

Peoria

and

Chicago

MMA.

In

the

Matter

of Eetheion Standards,

4

PCB 298 April

13,

1972.

~

~,

asa~

~

ided~uturecompliance dates for

both types

of emission sources

Kay, 1975 for solid fuel combus-

tion sources and December,

1973 for the process emission

sources.

In so doing, the Board acknowledged that the control technologies

envisioned by these lirüts were only then rapidly developing.

For

this reason and because c;ompl:Lance alternatives

included

switching

from high sulfur cea)

to limited reserves of low sulfur coal, oil,

or gas,

these emission limits were not uniform statewide, but in-

stead geographic and source determinative.

it should be noted that

Rule 202:

Visual Emissions and Rule 203~ Particulate Emissions

were adopted concurrently with Rule 204~ Sulfur Limitations.

The

adoption

of

Rules 203(g)(1),

204(a)(1)

and. 204(c)(l)(A)

was successfully appealed at the appellate and supreme court

level.

Commonwealth Edison Com~air v,

Pollution Control Board,

25 Ill.

~d

(Is

t~5T~t~T~flT

~I..

d 494,

48~38

---

3

343

N.E.2d 959

(1976),

These specific rules pert~lnedto the

particulate and sulfur dioxide emissions for sources

located

within the three

largest DMA.

In its rema~d,

the appellate court

instructed the Board “either to validate these

rules

in

accordance

with Sect~or 77 of

the Act or to prepare proper rules

as

substitutes.~1

I

at

96,

In affirmirg the Appellate Court,

the Supreme Court irtro(uced the notion that the Board’s record

was

insufficient as t

~hether simultaneous comp~ancewith Rules

203

and

204 was techn’cally feasible and economically reasonable,

The higher Court’s dec”is~onalso cited. the fact that “a weight of

new

evidence” had become irailable, presumab y a reference

to the

Board’s

inquiry hearirge into sulfur dioxide rules

(d74—2)

and

the Agency’s proposa~ f

r seltur dioxide rules

t75~~~5),

and like

the appellate deci~no

dire’~’tedthat the contested rules be

validated or appron late n~wrules adopted.

Thereafter the

ard

oisolidated the r cords in R7l—23,

R74~~2

and R75~~5

arid ie)d

wo add~tiona?public ~earings.

It

should be noted that

J v

rrlor to the Supreme Cour

‘s decision

the Environmental Pro ‘~‘cti~nAct was amended to require

I)

economic impact stulIe~

EelS) and hearings in future rulemakings

and 2) adoption of rec’ul&’ tons by the Board prescribing conditions

for sulfur emissior

~c r-~cto ccc intermittent control systems

(ICS).

The Supreme Co r~

decision acknowledgt.d the ICS

amendment,

but was silent on th

B IS amendment,

Consideration of ICS was

deferred until

final rulemaking in R74~2and R75~~’5to avoid intro-

ducing a new rulemaking

n the validation process.

No economic

impact statement w~ Irspated or hearings held.

An abstract of

the consolidated r~cii

i~lito ‘wealth of inforsation” was pre~

pared

by

Marder

Ass c ates

On July

7,

1977 the Board validated

the remanded rule~ atE

reviewing the pertinent information in

the record and corsidering tre issues identified by the Courts,

27 PCB 57,

Therein ~.heBoard decided that an economic impact

study was riot necessary for validation, and relied instead. on

the economic evideree a3ready in the record,

Furthermore, the

opinion stated that the

Matder report” served only as an aid,

and

riot an analysie of the merits of the information.

Neverthe~~~

less, the validation of the rules was vacated.

Ashland_Chemical

v,

Pollution (‘ontro~ Board,

64

Ill, App.

3d

169,

381 N.E.

2d 56

(3d Diet.

1978

and Illinois State Chamber v, Pollution

Control Board,

6’ 111.

hpp,

3d 839,

384 N.E.2d 922

(1st Dist.

1978),

Both courts declired ruling on the substantive validity

of the R71~23regulations and instead voided the Board’s validation

on procedural grounds

Miong other things, both Courts found

that

the Board’s use of the Marder report without public hearings on

the same violated due rr~cessrights and that Section

6 of the

Act, requiring an ecoromic impact study and accompanying public

hearings had not been complied with,

Validatior

havirg failed, the Board instituted inquiry pro-

ceedings into the remanded sulfur

dioxide

rules

(R78~l4)and the

particulate rule (R78~16),

On December

14,

1978, these regulatory

48~39

---

4

proceedings

were

consolidated with

R77~l5

(the

Ashland site-

specific proposal) and

R78~~’15(Rochelle site’-”specific proposal)

for hearing purposes.

Final action on R77~l5was taken on

December

17,

1982

and is still

pending on

R78-~l5,

On February 15,

1979, the issues

outstanding

from

the

combined

hearing

record

in

R71—23,

R74—2,

and R75~5were

resolved.

Sulfur

dioxide

emission

limits for rural

fuel combustion

sources including an adjudicatory

procedure and formula for site—specific limits were adopted in

the consolidated

order for R74—2

and R75—5.

ICS rules were not

adopted having been subsequently barred by amendment to the Clean

Air Act as a dispersion enhancement technique.

As stated above,

the Agency’s proposal for emission limits in the MMAs was

separately docketed

as R80—22,

R78—14

(sulfur dioxide inquiry)

was shortly thereafter dismissed,

R78-l6

(particulate rule inquiry)

was also dismissed.

with leave

to reopen should simultaneous com-

pliance with the

particulate

and sulfur dioxide emission limita--

tions become an

issue in R80~22.

It should be noted that R82-l,

another Board proceeding concerning Rule 203(g)(1),

has been

instituted, with

further action dependent on submittal of the

economic impact

study.

Therefore,

resolution of the

issues

involved in this

rulemaking

(R80—22) will hopefully conclude

the entangled regulatory history of sulfur dioxide since the

Commonwealth Edison

appeal.

ANALYSIS OF THE REGULATIONS

Fuel Combustion

Emission Sources

The

limit

for

sulfur

dioxide

emissions

for

existing

sources

in

the

three

MMAs

was

originally

adopted

at

1.8 pounds per mil-

lion

British

thermal

units

(lb/mBtu),

4

PCB

298.

Compliance

with this and the other limitations concurrently adopted antici-

pated that air quality

statewide

would

be

better than that

established by levels

the

national sulfur dioxide standards in

1971.

The National Ambient Air Quality Standard

(NAAQS)

for

sulfur dioxide includes two p~imarystandards:

an annual

standard ~f 0,03 ppm

(80 ug/m

)

and a 24 hour standard of 0,14 ppm

(365 ug/m ~

and a secondary standard based on

3 hours of 0.5 ppm

(1300 ug/m

).

Since

1975 no violations of the annual primary

standard have been recorded in any of the three MMAs.

The short-

term primary standard has been violated in all three MMAs, but

not since

1977 in Chicago and Peoria,

Violations of the secondary

standard have occurred in East St.

Louis and Peoria.

Monitoring alone can neither provide a plan to achieve air

quality in the St. Louis MMA, nor can

it determine the extent

the limit may be relaxed and the NAAQS

in the other two MMAs

still maintained.

Forecasting of this type must be developed

through

air

quality

analysis.

Therefore,

regional

air

quality

analyses, including base

and

strategy analyses, were prepared

for each of the three MMAs.

The modeling format used for each

48-40

---

5

of the three MMAs was basically the same, as were the data re-

quirements.

The data information, on the other hand, were geogra-

phically specific.

Each base analysis involved the Rural Area

Model

(RAM), which was modified to provide modeling for both

urban and rural sources.

The RAM was further modified to conform

with a second model, the CRSTER, which was used to account for

isolated emission sources.

It should be noted that modeling

is intended to demonstrate

that even under the worst meteorological and maximum emission

situation, violations of the NAAQS do not occur.

Exept

for the

St. Louis MMA, modeling was done only to evaluate the short-term

standards,

i.e., the

24 hour and 3 hour standards.

This was con-

sidered sufficient since attainment of the annual had already been

demonstrated, and the short-term standards are considered more

stringent than the primary annual standard.

The emission inventories contained the location, magnitude,

frequency, duration and relative constributions of the fuel com-

bustion emission sources in

each

area.

Generally, only point

sources emitting more than 100 tons of sulfur dioxide per year

(T/yr) were included, and area sources were accounted for in the

background levels.

The point sources were identified in the

Agency’s total air system (mS), which was compiled initially in

1974 and has since been continuously updated.

In calculating

the sources’ impacts on the model’s receptors, all sources were

assumed to operate at their maximum allowable rate, based on

the

remanded emission limits.

The air quality data consists of the monitored values.

Sulfur dioxide monitors operate continuously and the data

gathered is averaged to obtain hourly values.

Each study had

a different number of monitors involved and

a different base year.

The monitoring date was used to develop the background levels

for each area studied, by matching it with the meteorological

data for the same base year.

Exclusion angles were uniformly

calculated to eliminate “downwind” sources from the background

St.

Louis MMA

An annual analysis was performed for the East St. Louis area

using the Climatological Dispersion Model

(CDM).

The meteor-

ological data consisted of data collected between 1975 and 1978 at

Lambert Field and the National Climatic Center, and upper air

observations were obtained from the National Weather Service

at Salem, Illinois.

Even after growth was considered,

no viola-

tions of the annual sulfur dioxide standard were predicted.

48-41

---

6

Like the

other

two

$U4As, an analysis of the short—term

standards was programmed.

The meteorological data for 1973-1977

was gathered from the same sources used for the annual analysis.

The RAM was used in those areas which are basically urban

in

nature, and a modified version used for the rural

areas.

The

CRSTER model, which does not have the capability- to model several

sources at separate locations, was used for the isolated power

plant,

Illinois Power Baldwin.

The maximum allowable emission

rates of all major sources in Madison,

St.

C.air,

and Monroe

Counties was used in the model.

The sulfur dioxide sources for

Missouri were not used because the maximum allowable emission

rates and stack parameters were not available for these sources.

These emissions were, however, reflected

in the background

determination.

Emissions due to growth were not explicitly

modeled in this analysis.

It was instead assumed that any

additional emissions would be minor, and readily absorbed since

the model was already conservative in that all existing sources

operate at maximum allowable rates.

Furthermore, any new major

sources would be required to show no significant impact on air

quality pursuant to the Prevention of Significant Deterioration

(PSD)

or New Source Review

(NSR) programs.

The short—term modeling predicted widespread violations of

the primary 24 hour standard and the secondary

3 hour standard

primarily in the industrial areas of East St. Louis

(Ex.

3,

pp.

85-86).

Consequently, a culpability assessment was made,

using the “worst case” days of the five year period modeled.

The results, which included background concentrations, and

Illinois urban and rural sources of sulfur dioxide,

found the

sources in the Alton Wood River Area to be varied; whereas in

East St. Louis and Granite City,

the elevated sulfur dioxide

levels were more localized and source—oriented.

The two sources

identified, however, were process sources as opposed to fuel com-

bustion sources.

Due to the number of violations predicted,

no relaxation of

the emission limitation for fuel combustion sources

in the St.

Louis MMA is proposed.

Sulfur dioxide emission limits are

predicted to increase from fuel combustion sources in the next

decade

—-

but from residential and commercial sources

--

and

remain constant from industrial sources.

In an effort to achieve

attainment in this MMA, more stringent limitations for process

sources were proposed by the Agency.

These wil.

be discussed

Peoria Major Metropolitan Area

Neither the modeling done in 1978 nor recent monitoring

indicates violations of the annual standards in the Peoria MMA.

Thus, only short—term analyses were considered, on the assumption

48-42

---

7

standards

and,

therefore,

any

subsequent relaxation could

not

jeopardize the annual attainment status.

A five year base

analysis,

using

the

RAM and CRSTER model, was developed to

determine if the

1.8

lb/mBtu

limitation could be relaxed,

Five

years

(1973—1977) of meteorological data from the Peoria

National Weather Service Station was used in the analysis.

Again, maximum allowable emissions based on the 1.8 lb/mBtu

standard

were

used

along with appropriate background concentra-

tions.

The results of the base analysis predicted violations

of the

primary

24 hour standard, which were isolated to two

small

areas,

and none for the secondary

3 hour standard

(Ex,

3,

pp.

25—26).

A culpability analysis was also developed, using the two

receptors which had indicated violations

in the short—term base

analysis.

The culpability analysis associated these violations

with sources located at the Caterpillar Mossville Plant and

Caterpillar East Peoria Plant.

Both of these Caterpillar plants

are already equipped with flue gas desulfurization equipment

(FGD).

Therefore,

if the actual emissions were used in the base analysis,

it can be assumed that violations of the primary standard would

not be predicted.

For this reason,

Rule 204(c)(5)(C)

is proposed.

The specific emission limitations set out therein reflect the

actual emissions for three sources at these two Caterpillar

facilities,

With these limitations in place and enforceable,

the base analysis would no longer indicate violations of any

standards,

so relaxation of the 1.8 lb/mBtu limit can be con-

sidered for some of the area’s remaining existing sources,

Two strategy analyses were conducted by the Agency to

determine the extent relaxation possible without creating vio-

lations of the NAAQS,

The first strategy analysis focused on

the violations predicted for the two Caterpillar plants as dis-

cussed above..

It considered the effects, of the FGDs,

The second

strategy analysis utilized an MPTER model,

The MPTER is a disper-

sion model which can simulate the disper~1ionof several sources’

pollutants in a moderate terrain.

Applyin~a data base consisting

of the relaxed emission inventory,

a modified receptor network,

and five years of meterological data, the modeled impacts for all

urban and rural sources, and background concentrations to the MPTER,

air quality based on a 5.5 lb/mBtu emission limit was determined.

Violations of the short—term standards were predicted.

Therefore,

a second culpability analysis was performed.

Caterpillar’s Mapleton

Plant, despite an emission limit of 1.8 lb/mBtu,

and the Sherex

Chemical Company were identified as the sources of violation.

Based on this analysis,

the following conclusions were made:

(1)

The cause of Caterpillar Mapleton and Sherex’s pre-

dicted violations were the Mapleton bluffs;

48-43

---

8

(2)

the emission limits of 1.0 lb/mBtu for the Caterpillar

East Peoria

Plant

and

1.6

lb/mBtu

for

the

Caterpillar

Mossville plant would be sufficient to maintain NAAQS;

(3)

Sherex~semission limit could be relaxed from 1.8

lb/mBtu to 3.3 lb/mBtu without jeopardizing the NAAQS;

and

(4)

with the exceptions of the Caterpillar and Sherex

facilities,

the

emission

limit

could

be

relaxed

from

1.8

lb/mBtu to

5,5

lb/mBtu for

industrial boilers with

a

generating

capacity

of

less

than

250

mBtu.

It should be noted

that

only

one

industrial

facility

with

a generating capacity of greater than 250 mBtu remained subject

to the 1.8

lb/mBtu limitation

——

CPC

International

(now Pekin

Energy,

Inc.).

During the

merit segment of

the June

1,

1982 hearing,

a

third strategy analysis

was

presented.

The emissions inventory

for the modeling

was

revised to include the Caterpillar plants

emitting at their

actual limit of

1.8 lb/mBtu,

small industrial

boilers (less

than 250 mBtu) emitting

at 5.5

1.b/mBtu, and CPC

International boiler

(rated

at 330 mBtu) assessed at 5.5 lb/mBtu.

The Sherex boiler

was

modeled at an assumed stack height of 200

feet, which would allow Sherex to

emit

up to 5.5 lb/mBtu without

causing NAAQS

violations

due to the Mapleton bluffs.

This

analysis

indicated

that emission limits for the Caterpillar

Mapleton and East

Peoria

facilities must be further reduced to

assure compliance

with the

NAAQS,

An emission

limit of 0.8

lb/mBtu at

the

Mapleton facility and

1.1 lb/mBtu at the

East

Peoria facility

would eliminate any possibility of

violation.

Chicago Major

Metropolitan Area

The

air quality analyses for

the

Chicago

MMA were prepared

in 1981 and

presented at the

June 1st merit hearing

(Ex.

11).

The base analysis

utilized

the

RAM

model for those areas iden-

tified as urban,

the MPTER model for

those

areas identified as

rural, and

the CRSTER model was later used to

demonstrate the air

quality near

two isolated

areas.

The meteorological data for the

models was provided

by

the Chicago Midway National Weather Service

and the Peoria

National

Weather

Service

provided the upper air

soundings.

The

meteorological

effects due to Lake Michigan were

not considered

since

(1)

no meteorological sites continuously

operate near the

Lake, and

(2)

no readily available dispersion

modeling is available to take the Lake effects into account.

The emission

inventory

included point sources considered to have

significant

impacts, that

is greater than 100 T/year,

located in

Cook, Lake, Will, McRenry, Kane and DuPage Counties.

The maximum

allowable emission

rate

was used throughout;

this way the possible

48-44

---

9

violations of the NAAQS could be identified, with the additional

benefit that growth need not be specifically considered.

Unlike the analyses for the other two MMAs,

the background

areas to be included in the Chicago study had to be limited

because of the size and complexity of the geographic locale.

Four areas were identified as needing background value determination:

Will County, Lake County, southern Cook County and northern Cook

County.

In estimating these background levels, actual data

gathered at nine continuous sulfur dioxide monitors, as recorded

in 1976 and 1977, was coupled with the hourly meteorological

data for 1976 and 1977.

Downwind sources were discounted through

the use of “exclusion ang1es~”

The base analysis identified violations

of both short—term

standards,

For the 24 hour standard, four were predicted

in

Cook County, and one in Will County.

For the

3 hour standard,

three violations were predicted in Will County.

The Chicago MMA culpability analysis predicted throughout

the Chicago area exceed the 24 hour and the

3

hour

standards.

In Cook

County

ten

sources were identified as significantly con-

tributing for five days studied in

1975.

One source was identi-

fied in Will County, which has been mothballed; therefore,

its

actual emissions have been eliminated.

Similarly, the ten sources

identified may not actually he contributing emissions near the

maximum

allowable emission limits

used

in

the

model,

Therefore,

rather than making

a blanket determination that relaxation is not

permissible

in these areas,

it should be realized that individually

these sources may be able to prove that increased emission

rates

may not jeopardize the NAAQS in the

surrounding

vicinity.

In addition to the base and culpability analyses,

four

strategy analyses were conducted to determine which sources could

be

granted

relaxed emission limits,

Two of the four analyses were

site-specific, and two looked initially to the geographic areas

to determine if any sources located therein

could

profit

from

relaxed limitations.

The first strategy evaluated the emission sources in Kankakee

and McRenry Counties to determine if the limitation could be

relaxed from 1.8 lb/mBtu to 6,8 lb/mBtu without jeopardizing the

attainment

status.

Each county has one coal burning facility and

one oil and/or gas burning facility which is unaffected by any

relaxation.

Nevertheless, these facilities had to be included

in the modeling since they each contribute more than two—thirds

of the total sulfur dioxide emissions per year in their respective

county.

The CRSTER model indicated that the

coal

burning sources

could emit up to 6.8 lbs/mBtu without jeopardizing the air quality

in these attainment areas,

The Shapiro facility in Kankakee County

was

individually

48-45

---

to

modeled.

tt

had not been

included in the Kankakee study since

its

boilers are

equipped

to operate on natural

gas

•

It does

have a single

coal-fired

boiler which, if utilized

with

the

relaxed emission limit of 6.8 lb/matu, would not adversely impact

air quality in Kankakee.

Furthermore, should Shapiro decide to

switch

to

Illinois

coal,

results

of

the

CRSTER

model

indicate

that

the

other

coal-fired

facility

in

Kankakee

would

not

be

affected,

and

the

attainment

status

would

not

be

jeopardized.

The

second

geographic

area

considered

was

the

areas

of

the

Chicago

Milk

which

were

outside

the

non-attainment

areas.

Only

five

sources,

which

are

currently

burning

non-Illinois

coal,

were

modeled

as

potential

condidates

for

a

relaxed

emission

limit

of

5.5

lbs/mBtu.

These

emission

sources,

meteorological

data

from

1973

(the

worst

case’

year),

and

previously

identified

receptor

locations

were

input

into

the

RAM

(urban)

and

MPTSR

model

•

Back-

ground

data

for

Lake,

Will

and

Cook

Counties

were

also

processed.

Only

two

sources

were

identified

as

not

causing

violations

of

the

short-term

standards

if

allowed

to

emit

up

to

5.5

lbs/matu.

However,

as

was

the

case

for

two

sources

in

the

Peoria

Milk,

modeling

to

determine

possible

terrain

and

downwash

problems

is

necessary

before

a

relaxation

could

be

granted

to

these

sources.

They

therefore

are

potential

candidates

for

the

site-

specific

adjudicatory

procedure

also

proposed

in

this

rulemaking.

Lastly,

the

Caterpillar

facility

in

Kendall

County

was

modeled

to

determine if

the

emission

limitation

could

be

relaxed

to

6.8

lbs/mBtu.

Kendall

County

is

currently

an

attainment

area

for sulfur dioxide.

Should the e’aission limit

be

relaxed,

however,

the

CRSTER

model

predicts significant

violations

of

the

short—term

standards,

but

no violation of the

annual

primary

standard.

Relaxation

is

denied

at

this

time

because

the

CRSTER

model

did

not take

into

account

background

levels,

terrain,

or

building

downwash effects.

The

overall

effect

of

the

relaxations

proposed

is

that

an

additional 220,000 tons of Illinois coal

can

be burned annually in

addition to the 120,000 tons burned annually by Sherex,

Bernie

and

Celotex

pursuant to R77-l5.

Conversions by sources in the Peoria

Milk

and

Kankakee

and

Mcflenry

Counties

from

oil

or

natural

gas

will

also

increase

Illinois

coal

usage.

At this

time,

however,

the

amount

is not certain (R.648)

•

The

increased

usage

of high—sulfur

coal

has

been

adequately

demonstrated,

primarily

on

a

source—by-

source

basis,

not

to jeopardize current air quality.

In

addition

to

the

specific

limitations

adopted

for

fuel

combustion

emission

sources

in

the

three

Milks,

an

exemption

procedure

is

proposed

much

like

that

available

to

rural

sources

pursuant

to Rule 204(g)

(former Rule

204(e)).

Adopting the

adjudicatory format, petitioning

sources

are

required

to

demon-

strate

that

the

relaxed

emission limit sought will

not

jeopardize

air quality.

This

procedure

should be readily available to

4&46

---

sources

since they can

erely p a

c~

it~

mode~ingon

that

already

completci

b!

th~

Agan

‘

1~

of

ti~

NMAs

At the June

1

J82 hc~r

g

irn~

k

ought

a

relaxed

emission

limit

for

ts

utility

compan

~

bmtttei.

modeling

studies

ba~ed

i

~h

cc

-y~i stuc

o

d

ronstrtte

that

air

quality

would

no’

b~

je

~a

I

zed

~f

it

as

c)lowed

to

emit

up

to

6.8

lbs/mBtu.

~innetka

s

e

thcnce

i~ impressive,

but

untimely.

The

public

waj

not

~fci~.r

~y

no~i’ea

t.

R8O~2 would

consider

the

Winnetka

power

p1

i

~‘h~refo~e,

Wina

ka

is

not

included

in

this

rulerr9king.

Ht~,

a

aPc~

01

th

doe

~ientation

completed

to

demonstrate p

s

a

rc

x

on

it

i~

~‘o

~dered

a

candidate

for the new exempt~

0

e

Aside from

ira~

iii

j

I

n las for fuel

~ombustion sources

burning solid fuel s

~1i~

~e formula for those burning

combination

of

fucl~’

i

rc~

~d

~

s new formula for steel mills

is proposed.

dhe

it.

r

~

t

i

n for distilla

oil

sulfur

dioxide

emissions is

ci. n aa~. I

a

a speci~iccomponent in the

present

formula.

The re~~o~cwa

regulating combustion of com~

bination fuels at sttal mil ~

lf-explanatory.

Process_Emission

Source’

Sulfur ~ompouru~ ~c

ei~ctedinto me atmosphere from fuel

burned at proces~souxces or

iron

the process itself.

As noted

in the St.

Louis

1~flAdi’

~rn,

t~eprocess sources~emissions

in that area cor

~bu

~fr~ant

c

ti.e non~atainment

demonstration,

~onac te

y

ravied ard new emission limits

are proposed whi h

r

‘1

h

re

s

rc~s~current actual emis-

sions and cortr

ap

1.

ie

ie’e regulations, which impose

no immediate obl gatio~

or t a regulated facilities, will not

necessarily improve air

jua

it

n’tead these revisions will

enhance

the air

0~

1

y

~en~on’

c*t

1,

which will

in turn

reflect

a larger margin

~or ~

~

gro’~tIpurposes.

~e

amendment

will also insure that 1o~a1i~d

itsospheric sulfuric loading

is

not inadvertently ircreaoed by area sources,

It should be noted

at the outset that t~rru~esf

process sources are reorganized

and amended into two sub a t~’ oroc~ssemission sources and fuel

burning process soure

The present genera

emi’~ionlimit for process emission

sources is 2000 parts pe

rvl ~oa (ppm).

This

limit represents

a

concentration

standard

as

pposed

to

a

mass

limitation

standard.

Although

tie

concentrat

~n

standard

s

appropriate

for

a

general

limit, it has its drawbacks

For instance, correction

factors

necessary to compensate for excess air introduced into the exhaust

flow are difficult to develoo.

Therefore, wherever possible a

mass limitation standird

is

proposed.

Three

prcesses

are

already

exempted

from

the

2000

ppm

limit:

---

1.2

processes designed to remove sulfur compounds from fuel combustion

emission sources’ flue gas, i,e~,FGDs; existing processes designed

to

remove

sulfur compounds from petroleum and petrochemical pro-

cesses’ flue gas;

and qualified existing hydrogen sulfide flares

at chemical manufacturing plants.

Five additional sources are

proposed for exemption from the general concentration limit:

(1) sodium aluminum sulfate manufacturing process;

(2) sodium

sulfite manufacturing process;

(3) secondary lead smelting process;

(4) glass melting furnaces; and

(5) glass heat treating with

sulfur dioxide process.

Of these five categories only two,

secondary lead smelting and glass melting furnaces, are found

to significantly contribute to the Chicago

MMA

non—attainment

status for sulfur dioxide (R635).

This is reflected in that

the rules proposed are geographically specific.

The differences between the emissions allowed, based on

the 2000 ppm standard, and the actual emissions contributed are

significant.

Review of the processes themselves makes it evident

that these differences are inappropriate and unneeded by the pro-

cess facilities.

For example, under the general

rule,

the glass

heat treating with sulfur dioxide process could emit up to 21

pounds of sulfur dioxide

per

ton of product.

Yet, the raw

materials as a whole used in this process

can

only generate one

pound of sulfur dioxide per ton of product produced.

Instead of the process—specific emission limits,

these five

categories are exempted from the general concentration standard.

Exemption,

as opposed to specific limits, will allow the indi-

vidual sources emission limits for sulfur dioxide that are appro-

priate and readily achievable at the individual facility.

It

should be noted that none of these sources use control equipment

for sulfur dioxide,

The Agency has requested this regulatory

format in an amended proposal.

A specific emission limit is proposed for new process emis-

sion sources in the St. Louis MMA which are designed to remove

sulfur compounds from the flue gases of petroleum and petro-

chemical process, commonly known as the Claus process.

This

process is a recovery unit intended to recapture sulfur from

the acid or sour gases at petroleum refineries.

The sulfur

dioxide emissions from this recovery process are usually more

than 9000 ppm, much greater than the 2000 ppm limit.

Therefore,

secondary recovery is required to control the tail gas emissions

of sulfur dioxide.

In-plant studies indicate that secondary

recovery units can reduce sulfur dioxide emissions to 11—13.9

pounds of sulfur dioxide produced.

This corresponds to 646 ppm

to 834 ppm, which is far below the 2000 ppm allowed by the

general rule.

Shell Oil Company objected to this reduced emission limita-

tion for two reasons.

It had just recently installed a

SCOT

48-48

---

13

plant

in St~Louise

It stated that the 1979 stack test results

obtained

there and relied on by the Agency in developing the

revised

limit could not

be

generalized

since

design

and installa-

tion at other facilities might produce different results.

Secondly, due to

increased

recovery

efficiency

of

the

SCOT

unit,

the

primary recovery

unit

is

subjected

to increased

sulfur

loadings

which

result

in

increased emissions (R~lO8)~

The second fear would seem unjustified based on the 1979

stack

tests~

These

were

taken at the Claus plant, and therefore

reflect

these

increased

emissions,

As

for

the

first,

the

revised

limit is intended

to

encourage

the

use

of a secondary recovery

process

as efficient

as

the

SCOT

unit

at new

su1f~ir recovery

facilities as opposed

to

low

temperature

Claus

processes0

In

proposing

this

limit,

it

is

understood

that

individual

facilities

might experience

problems

due

to

design, installation or other

facility

specifications0

However, as is the ease in adopting

other

regulations which are technology forcing, solutions to

these

possible

quirks

also

are

likely

to

become

available

as

needed,

An

emission

limit

of

14

pounds

of

sulfur

dioxide

per

ton

of

sulfur for new sulfur recovery processes

is

proposed0

A 500 ppm limit is proposed for sulfuric acid manufacturing

plants

in the City of Chicago,

The one such plant affected is

equipped with a Wellman-Lord sulfur dioxide recovery system with

96.3

percent efficiency0

This

control

equipment was designed to

meet the City of

Chicag&s

500

ppm

limit for sulfur dioxide,

(R,636),

Based on this,

the Board finds that the technology to

achieve

this reduction is feasible and economically reasonable.

This limit

is therefore proposed to achieve and maintain the

NAAQS for sulfur dioxide in the Chicago MMA,

As stated earlier, emission limits based on the fuel com-

bustion capabilities of

process

sources

are proposed0

Three

categories of such

sources

are

affected,

One is source specific;

the second involves a type of process source;

and the third is

an exemption0

The source specific limitation is applicable to a process

source located

in the St. Louis MMA which burns tea leaves as a

solid

fuel,

The proposed emission limit of 0,70 lb/mBtu will not

require any additional control equipment or investments by the

affected source, and will allow it to utilize its waste product

——

tea leaves

in

a

manner

more

resourceful than landftiling.

Secondly,

lime kilns as a fuel burning process source are

exempted from both the 2000 ppm limit for process sources and the

1.8 lb/mBtu limit for solid fuel combustion sources,

Lime kiins

are only located

in

the Chicago MMA and rural areas and primarily

burn

high~~sulfurcoal,

Subsequently,

it

should

be

subject

to

the

1.8

ib/mBtu applicable

to other similarly located sources

burning

coal.

However,

the

lime

involved

in

the

process

itself

reacts

48~49

---

with the sulfur to

~

q

cc

n

t)

levels

below the 1,8 lb/mBtu

0

~prn

In exempting

it as

a

a jrace’~,e~uis~

sion source,

eiri~s~

zai

~1it

~

I

U

dverc3e

indi~

vidual

kilts

cd~t

C

ii

An

exerptr~n

i

pxcv

~

LOt

se

‘ea

‘h

~

can

be

classified as c tI

but

r~ ~

o i~cc~~r

~uel con~

bustion

emis~ior

~

r

~1~b

fUtflc~

at

the

Grinite

City

Steel Corporat~on

arc

th~

r

y

k o~

ich

urces since the

furnaces

are

di

cc

I

i

d

I

a~

farre~

ttcrs

U

too

high

in sulfur

contert

o

a

i

sources0

However

a

2

exemption

propose

a

I

either

limitation

~

,

t

content,

Economic

Evaluat

~or

At

the

March

discussed the po~sial

then

propoccd

f

I

I

permit fi1e~ida

limitation~wou~I a

compliance

cith t

a.

I

pliance

gould be

i~i

to achieve

the

3

limited number

I ~a iIit~s

y eigtt Peoria sources were

already

burning higr ~su I

it

The permitted coal consumption

for the remaining

ixty

I

a. facilit ~a is primarily attributable

to electric utility

om~aic~

irca. thece facilit es are com-

mitted

to 1ong~tcra~ieterr

ci

-

tracts

f~e

a itching is

not a viable alt~

1i~.L~

fits wailable by

switching from 1i~

~on

a.~. ~o

11 nois coal are

similarly attractive

L

y

i

the con er ion costs can be

amortized over

a

I a

I.

The

ENR

ccurori

ii~i

~

Lxiathit.

±7

reviewed

separately

the relaxed

1imi~

for

~ue1

corrbuat~on enission

sources

and

the

reduced

limits

for

p

o

ss

cuission

aourceg,

~ince

cost

of

com-

pliance

was

no

at

i.~aut. for

either

coal

combustion

sources

or

process

sources

the

study a~saeed he cost sav~ngsfor the

first

and the economic conac

a nc~ of

e second,

It also examined the

probable eeonornth

imfa’

n

ti~

U

flOiS

fuel markets, which along

a1

c

b

a.

I

ccl

combustion

pp

ir

tab.

The

o~

c~e ~

urces

to

meet

fuel

nI

v~ith

~.

wer

sulfur

Having

cone

J

d

would

result

ir

U

vestment

o

Ire

aft

ct

the economic

ramificat

be adopted.

ue

~w

Illinois

coal

h

s

r

a~ ecoromist

~ith

the

Agency

o~lI

the

emission

limits

c

s

a. a~ptec

The Agency’s

Ui

ti

U

Utics

to

which these

~.

c

us

,

~ter

x

~as

out

of

~ U

U

ct

~,

~

cost

of

corn—

I

cx

wo

Id

Uc

r’~qucred to

expend

Ft

F

c

U

r

issorce.

t

at

f

h

propcscd

rc3ulations

r

a.

cc

c

ía.

U

or

he

c

~ital

in—

~s

the

Ajcn

the

considered

01)5

~Uo

11

tie

proposed

regulations

not

it w

alt

ir

cos

to

high—sulfur

r

UI.

s

but

only

for

a

---

15

with cost savings, could be expressed in real dollars,

The study

considered the consequences to the health and welfare of the

affected

public and property,

Assigning dollar values to this

proved difficult,

Five industrial facilities equipped

with

coal combustion

boilers were

identified

in

the

Peoria

MMA

which

could

benefit

from the adoption

of

a

5,5

lb/mBtu

limitation,

It should be

noted

that three of the five,

Celotex, Bemis,

and Sherex, have

already

obtained

this

relief pursuant to R77—l5,

All five facil-

ities, however,

are

briefly

discussed here,

The Westinghouse Airbrake Company (WABCO)

currently utilizes

4,500 tons of Kentucky low—sulfur coal per year at an approximate

cost

of

$55.15 per

ton

(1981

dollars),

Converting

to Illinois

coal, costing approximately $3l,42 per ton, should save WABCO

nearly $108,450 per year in fuel costs,

Additionally, WABCO

indicated that conversion costs would be negligible,

Pursuant to R77—15,

Celotex currently burns approximately

45,000 tons of Illinois coal,

Therefore, no

cost

savings

is

attributable to reaffirmation of the 5,5 ib/mBtu limit,

However,

if

forced

to

use

blended

coal,

costs

would

increase

by

$727,000

per year,

Sherex,

the

original

proponent

in R77—l5,

is operating

with the same relief,

It

currently burns only Illinois coal

in

its

boilers which

have

two

stacks,

If

forced to instead use

blended coal,

fuel costs could increase by $708,000 per year,

or

as much as $1,060,000 per year

if

low—sulfur

Kentucky

coal

is required,

These

increased

cost

figures

do

not

include

any

equipment

costs

associated

with

converting

to blended coal

because Sherex

claims

that

would

not

be technologically feasible.

In

allowing

a

maximum

emission

limit

of

5,5

lb/mBtu,

aerodynamic

downwash

from its facility posed a problem.

Sherex has corrected

this by

heightening

its

stack

at

an approximate cost of $235,000.

The same situation holds true for Bemis Corporation which burns

an

estimated

31,000

tons

of

Illinois

coal

per

year

at

a

fuel

cost

savings of $499,000

per

year,

Bemis

incurred

no

significant

conversion

costs,

In 1980 Pekin Energy Company, formerly CPC International,

consumed

63,000

tons

of

Illinois coal and 123,000 tons

of western

coal

for a blend costing an average of $45,40 per ton,

or

$8,380,000,

Pekin

Energy testified that,

if permitted,

it could

instead consume 191,000 tons of Illinois coal at a total cost of

$5,600,000 and thereby save $2,830,000,

These savings, however,

are

offset

by the estimated annualized cost of $125,000 for a

fifty foot stack extension,

Without such an extension, emissions

ranging

up

to

the 5,5

lb/mBtu

limit

could

have

caused

aerodynamic

downwash,

which would result in air quality violations0

Based on the proposed relaxation in McHenry and Kankakee

Counties

in

the Chicago MMA, cost savings were found to be avail—

48~5

I

---

16

able to one Kankakee facility.

Other facilities were not

studied

since they indicated they would not utilize a relaxed emission

limit of 6,8 lb/mBtu.

The Kankakee facility,

Roper Company,

indicated that

it could switch from using natural gas to Illinois

coal,

saving approximately $134,000 per year,

No relaxed limit is proposed for existing fuel combustion

sources

located in the St.

Louis MMA,

so no economic consequences

were considered by the ENR study.

In adopting the two relaxed standards,

total

cost fuel

savings

for the facilities considered is estimated at

$4,972,000.

If the conversion costs,

i.e., the stack extension costs, are con-

sidered, the net savings

is estimated at $4,612,000,

As noted

above,

relaxing the emission limits will only moderately increase

usage of Illinois coal by approximately 0,35

of the current annual

production.

Consequently, secondary

impacts

on the Illinois

coal

industry

were determined to be modest,

An additional

$6 to $7.4

million per annum will be generated, and seventy to ninety addi-

tional new jobs created,

Using a regional economic theory pre-

viously developed by ENR, the authors extrapolated the effect of

the estimated annual increase to determine the overall effect on

the State’s gross product.

Assuming that an income multiplier of

two was reasonable for small regions, the $6 to $7.4 million

generated could possibly boost income

in Illinois by $12 to $l4,8

million,

The

study

considered

whether

increased

use

of

Illinois

coal

could disrupt the residual fuel oil market,

It concluded

that

such a possibility was unlikely,

Not only is the number of

sources switching from out—of-state coal to domestic coal few,

but since the supply of Illinois coal

is subject

to the

same

uncertainty

as out—of—state coal,

it

is likely that

they

will

have

to

continue

maintaining

reserves

of

fuel

oil,

Even

if

such

an

impact

was

to

occur,

the

economic

ramification

would

be

minimal

since

it would be a transfer of income rather

than

a

direct

loss,

In studying the effects of the proposal for the

process

emission

sources, estimates for control costs or cost savings

were not developed,

The revisions of the present standard are

intended only to more accurately reflect what is actually being

emitted;

no additional control

is envisioned by the amendments.

The study did note that in modifying the

existing

rules,

the

margin of operating

error

at

the

affected

facilities

is

reduced,

which

has

possible

economic

ramifications.

The

study

also

con-

cluded

that

offsetting

credits

possibly

envisioned

by

the

affected

facilities were eliminated,

The

economic

impact study also examined the costs to the

health and welfare of persons and property.

A cost of $1,032

to $2,434 million per year was estimated,

In proposing these

48~52

---

17

amendments,

the

Board

recognizes

that

a

certain

segment

of

the

public

is

rendered

less

protection

from

sulfur

dioxide,

and

that

property

is

possibly

subjected

to

increased

deterioration

from

sulfur dioxide.

However,

the

relaxations

proposed

are

limited

primarily to

the Peoria MMA,

and

modeling

for

that

locality

has

adequately

demonstrated

that

downwash

and

atmospheric

loading

problems

should

not

occur,

The

remaining

amendments

should

not

cause

any

increase

in

sulfur dioxide

emissions,

but rather more accurately reflect the

actual

emissions from

process

sources.

These should therefore

not cause

any

impact

on

the

health

and welfare

of

the

people of

Illinois,

Hopefully,

the

proposed

amendments

suffice

to

enhance

the use of

Illinois

coal

to the greatest extent possible, while

attainment

of

the

NAAQS

for

sulfur

dioxide

is

furthered

statewide.

IT IS

SO

ORDERED.

Board chairman

Dumelle

and

Board Member Werner concurred,

I, Christan

L,

Moffett,

Clerk

of the Illinois

Pollution

Control Board,

hereby

certify

that

the

above

Opinion

was

~dopted

on the

~

day

of

___,

1982

by

a vote of

~S

-

C

Christan

L,

Mof.

,

Clerk

:llinois

Pollutio

ontrol Board

48-53