ILLINOIS POLLUTION CONTROL BOARD

October

10,

1985

IN

THE MATTER OF:

AMENDMENTS TO 35

ILL.

ADM.

)

R84-26

CODF~214,

SULFUR LIMiTATIONS

PROPOSED RULE.

FIRST NOTICE,

PROPOSED OPINION AND ORDER OF THE BOARD

(by J.D.

Dumelle):

This matter comes before

the Board upon

a July

13, 1984

proposal

to amend

35

111.

Adm, Code

214,

Subpart

C:

Existing

Solid

Fuel Combustion Emission Sources,

filed

on behalf of the

Illinois Environmental Protection

Agency (Agency).

That proposal

w~samended

by the Central

Illinois Light Company

(CILCO)

on

hugust

23,

1984,

and further amended

by joint motion of

the

Agency and Caterpillar Tractor

Co. on September 10,

1985.

CILCO’S motion

to amend’ was

granted at hearing.

The joint motion

to amend

is hereby granted,

Hearings were held on August 30,

1984,

in Peoria;

September 25, 1984,

in Chicago;

and September

5,

1985,

in Peoria.

The Agency’s original proposal would establish

a new SubparL

G of Part 214 setting forth sulfur dioxide emission limitations

applicable

to sources located

in

the City of East Peoria and

in

Hollis Township (both

of which are located

in

the Peoria major

metropolitan area) which were equipped with flue gas

desulfurization

(FGD)

systems as of December

1,

1980.

Proposed

Section 2l4.XXX would

simply set forth

the scope of Subpart G.*

Proposed Section 214.XXY would establish

a one hour limitation

of

1.4 pounds

of sulfur dioxide per million Btu actual heat input

for

new or existing FGD sources

in East Peoria.

Proposed Section

214.XXZ would establish

a

0.6 pound standard

for new FGD sources

in louis Township.

It wou:Ld also modify the

5.5

pound standard

of

35

Ill. Adm. Code 214.141(b)

for sources located

in

Lhe City

of Peoria

which did not have FGD systems

as of December

1,

1980,

to make that standard contingent upon

a stack height of

47 meters

or more.

CILCO’s amendment would

add

subsection (c)

to Section

214.141 to provide

that Units

1

and

3

at CILCO’s

E.

D.

Edwards

Electric

Generating Station cannot emit more

than 6.6 pounds

of

sulfur dioxide per million Btu of actual heat

input.

Finally,

the

joint amended proposal filed by Caterpillar and

the Agency

*

The

Agency

did

not propose specific

section

numbers, but

rather proposed generi.c numbers 2l4,XXX, 214.XXY and 214.xxz and

left

it to the Board

to assign

specific numbers.

The placement

of

the

rules

is discussed

below.

214.XXX becomes

214.140,

2L4.XX~becomes

214.141(c)

and 214.XXZ becomes 214,141(d).

86-93

---

—2—

would modify

the originally proposed Section 2l4.XXZ

to allow

FGD—equipped sources

in Hollis Township to emit 1.1 rather

than

0.6 pounds per million

Btu.

The primary purpose of this rulemaking

is

to assure that

the

sulfur dioxide National Ambient Air Quality Standards

(NAAQS)

are

achieved and maintained

in the Peoria major metropolitan area

(MMA)

thereby allowing the state

to obtain federal approval for

its State Implementation Plan (SIP).

The Board had hoped

that

its present rules

(adopted under R80—22 on February 24,

1983,

at

51 PCB 217) would

result

in an approvable SIP.

That,

however,

has not happened.

Peoria, Hollis and Groveland Townships have

remained non—attainment for sulfur dioxide.

Therefore,

the

Agency has done additional modeling

of the Peoria MMA using

a

wider

and more detailed data base than was available

to the

Agency when similar rules were proposed

(and rejected by the

Board)

in the R80—22 proceeding.

This modeling, however,

continues to predict potential violations of

the

NAAQS

under

present rules,

Therefore,

the Agency analyzed

the predicted

violations

for culpability

arid identified

the critical

contributors.

The Agency’s original proposal

in this proceeding

was developed

to eliminate the potential violations.

CILCO’s August

23,

1984,

proposed amendment was allowed into

this proceeding since

the Agency’s modeling which supports

the

Agency’s proposal also

serves to support CILCO’s request

for

a

relaxation of the sulfur dioxide limitation applicable

to Units

1

and

3 at

its

E.

B. Edwards Station

to 6.6 pounds per million

Btu.

In PCB 83—100

(57 PCB 417, April

19,

1984)

CILCO sought

similar

relief which was rejected

by the Board

based upon the

lack of modeling support

in that proceeding,

CILCO believes that

the present modeling and proposed rules fully support

its

request.

The September

10,

1985, joint motion to amend

the proposal

arose

as a result of

a

site—specific study conducted by

Caterpillar

for

its

Mapleton Plant.

Caterpillar believed that

the Agency’s modeling which supported the originally proposed

0.6

pounds per million

Btu standard was flawed with respect

to

revised data regarding topography,

background air quality and

plant boundaries,

Using

the Agency’s model

and this revised

data, Caterpillar

and the Agency believe that a

1.1 pound

standard

is appropriate

for Section 214.XXZ rather than

the 0.6

pound

standard.

RULE PLACEMENT

The proposal

includes amendments to 35

Ill. Adm. Code

214.141 and

the addition of new Subpart G,

Placement of these

rules as proposed runs counter

to

the format established

for Part

214.

Therefore,

the Board proposes

a placement of

the proposed

rules which

is consistent with that format.

68-94

---

—3—

Pursuant

to 35

Ill. Adm.

Code 214.120, Subparts

B through

F

of Part 214 are

to contain general rules

for sulfur emissions,

which

in turn are

to be modified by industry and site—specific

rules

in Subparts N,

et

seq.

CILCO’s proposal

to add

a

site—specific rule as a subsection of Section 214.141 is,

therefore,

inappropriate:

it is properly placed

in Subpart N,

et

seq.

The Board proposes to add CILCO’s proposed rule

to new

Subpart

X:

Utilities, which is proposed

to cover industry and

site—specific rules

for electric, gas and sanitary services.

A

section regarding

the scope of that Subpart will

be proposed as

new Section 214.560.

CILCO’s proposed rule will

be at Section

214.561.

Also,

present Section 214,141(c)

regarding

the Village

of ~Qinnetka’selectric utility plant will

be deleted,*

Adding

the remaining proposed rules as

a new Subpart G

is

also inappropriate.

Since those rules are more

in the

nature of

general rules rather

than industry or site—specific standards,

they are properly placed

in Subparts

B through F.

Subpart

C

is

clearly the appropriate subpart and Section 214.141

is the

appropriate section,

Since these rules will not be proposed as

a

new subpart, proposed Section 2l4.XXX regarding the scope of

the

rules will become 214.140.

Proposed Section 2l4.XXY regarding

sources

in East Peoria will become Section 214.141(c)

and

proposed Section 2l4.XXZ will become Section 214.141(d).

Some

non—substantive rewording of the proposed rules will be made

to

conform with the present structure of Section 214.141.

SECTION 214.141

The proposed changes to Section 214.141 include

“housekeeping” measures,

a stack height limitation on subsection

(b)

and

the proposed limitations

for FGD—equipped facilities

in

the Peoria MMA.

The “housekeeping” changes simply consist

of

converting

the present limitations, expressed

in kg/mw—hr

to

nanograms per joule which would make the rules consistent with

common practice.

(R,

I, pp~7779),**

The stack height

limitation of 47 meters

in subsection

(b)

is proposed

to be

added

to avoid possible NAAQS violations caused by Westinghouse Air

Brake Company (WABCO),

The Agency’s model shows

that due

to

downwash WABCO would

have to limit

its emissions

to 1.8 pounds

per million Btu

to avoid potential NAAQS violations based upon

*

That section exempted the Winnetka plant from the general

sulfur dioxide rules pending

final action

in R80—22 which has now

been completed.

This rule, therefore,

no longer serves any

purpose

and is proposed

to be deleted as unnecessary.

**

The transcripts of each hearing are numbered consecutively

beginning with page

1.

To distinguish references to those

transcripts,

references

to

the August

30,

1984,

transcript will

be

in

the form of

(R.

I,

pp.

),

references

to the September

25,

1984

transcript will

be

(R,

II,

pp.

),

and references

to the

September

5,

1985,

transcript will b~~(R,III,

pp.

),

66-95

---

—4—

the Industrial Source Complex model.

However,

if the stack

height were raised to 47 meters,

a

5.5 pound standard would

assure acceptable

air quality,

(R.

I,

pp.

47—48 and 79—82).

Thus, WABCO (apparently the only affected facility) has the

option of meeting

the general 1.8 pound standard or

raising

its

stack

sufficiently to take advantage of

the relaxed standard.

~ABCO has not objected

to

this amendment and apparently has been

meeting

the

1.8 pound standard since

1973.

(R,

I, pp.

82).

Proposed Subsections 214,141(c)

and

(d), despite being

written as general rules,

are intended by the Agency

to

specifically limit sulfur dioxide emissions from the East Peoria

and Mapleton (Hollis Township) coal burning boilers of

Caterpillar.

As written, they

apply to

fuel combustion emission

facilities equipped with flue gas desulfurization systems

as

of

December

1,

1980.

Subsection

(c)

which

is applicable

to

facilities located in East Peoria establishes a sulfur dioxide

limitation of 1.4 pounds per million Btu.

Subsection

(d)

which

is applicable

to sources located

in Hollis Township was amended

to establish

a standard of

1.1 pounds per million Btu.

The levels originally proposed by the Agency were developed

through computer modeling

in an attempt

to assure attainment of

the

NA.AQS

for

sulfur dioxide and to evaluate possible sulfur

dioxide limitations that would enhance the use of Illinois

coal.

(See Exhibit 5),

The Agency used the RAMU and MPTER

models recommended by USEPA,

five years

of hourly meteorological

data from the Weather Service Station at the Greater Peoria

Airport, an emissions inventory including all major

sulfur

dioxide sources

in Peoria, Woodford and Tazewell counties (all

assumed to be operating at their currently allowed maximum rates)

and background concentrations determined

from continuous

monitoring

in

the Peoria area during 1976 and 1977.

(Cx.

5, pp.

3—12).

The first step

in analyzing the data was

to

identify

potential violations of the primary and secondary NAAQS.

(Cx.

5,

p.

12).

Next, culpability was investigated

to determine

the

primary sources which were responsible

for the potential

violations.

(Ex.

5,

p.

12),

Finally, the violation for each

such source which caused the most restrictive rate for

that

source which was necessary to assure compliance with the

standards was determined.

(Cx,

5, pp.

12—13),

As

a result of this analysis, the Agency reached several

conclusions which

it used as the basis

for

its original proposal:

——

The current emissions regulations are not sufficient to

ensure attainment of the SO2 national ambient air

quality standards

in all portions of the Peoria

area.

——

Violations

of the NAAQS for SO2 are possible north of

Caterpillar’s Mapletori facility at the current allowable

emissions limit of

1.8

lb11MBtu for boiler

1

and with

the

68-96

---

—5—

limit of 1.2 lb/NBtu for boilers 2 through 5.

The

violations are the result of plume impaction on the

bluffs north of the Illinois River Valley.

——

Emissions limits of 1.4 lb/MBtu as applied to the

coal—fired boilers at Caterpillar’s East Peoria facility

and 0.6 lb/NBtu as applied to Caterpillar’s Kapleton

facility would be sufficient to attain the NAAQS in the

vicinity of those facilities.

——

An emissions limit of 1.8 lb/MBtu at W&BCO would ensure

maintenance of the NMQS in the vicinity of that

facility.

——

The

so

emissions limit of 5.5 lb/MBtu for all

coal—dred industrial boilers, with the exception of

those Caterpillar and WABCO facilities already

mentioned, will ensure attainment and maintenance of the

SO2 NAAQS in the Peoria area.

(Ex.

5, p. 14)

While none of the participants in this proceeding have

questioned the Agency’s methodology used to develop its original

proposal, qUestions have been raised regarding some of the

underlying data.

Caterpillar’s amended proposal, which

establishes a 1.1 pound per million Btu standard for sources

located in Sollis Township rather than the originally proposed

0.6 pound standard is premised upon disagreement with the

Agency’s data concerning the terrain elevations, base elevations

of the stacks, and background levels, as well as inclusion of

receptors located on Caterpillar property.

CR. In, p.

29).

At

Caterpillar’s request, ETA,

Inc. performed dispersion modeling in

the vicinity of the Mapleton plant using corrected factprs and

taking into consideration the mandated derating of boilers 2

through 5 to 249.9 million Btu maximum rated heat input,

CR.

In, pp. 29—30 and Ex. 15).*

other than these changes,. the

methodology and data used were the same as those used by the

Agency.

Background levels were established using the Agency’s

Pekin Derby Street monitor data from 1982

and

1983.

CR. III, p.

34).

This monitor was chosen due to its proximity to the

Napleton plant.

CR. III, p. 34).

Survey data was used to

establish stack height and topography.

CR. III, pp. 31—32).

using this corrected data, ETA concluded that Caterpillar

could assure attainment of the sulfur dioxide standards by

reducing its emission by 6.94

of the modeled 1.2 pounds

per

*

Caterpillar entered into a consent decree with USEPA

CaterQillar

Tractor Co., v. Adamkus, Central District of

Illinois, Civil Action No. 83—lO8Uf1985)) which requires this

derating and physical changes to the boilers to insure that the

maximum rated heat input is not exceeded.

---

—6—

million Btu.

CR.

III, p.

35).

As Alan Junk, Manager of

Environmental Services for ETA, testified,

“an appropriate way to

do this would be to reduce the allowable sulfur dioxide emission

rate to 1.1 pounds per million Btu

for boilers 2, 3, 4, and 5.”

CR.

III, pp. 35—36).

•

The Agency, through the testimony of John

Schrock of the Air Quality Planning Section of the Division of

Air Pollution Control, found ETA’s “modeling methodology to be

correct and consistent with USEPA’s modeling guidelines as well

as prior IEPA studies.”

CR.

III, pp. 40—41).

Be concluded that

the Agency concurs with Caterpillar’s conclusions that the

proposed SO~limits for Mapleton’s boilers will not cause or

contribute to an air quality violation.”

CR.

III, p. 42).

The Board càncludes that the amendments to Section 214.141

are justified by the record and will propose the amendments as

submitted, and amended, except that the reference to “new or

existing” sources will be deleted from Section 214.141(c).

Since

these terms have caused confusion in the past, they have been

deleted in the amended proposal to Section 214.141(d),

and

they

do not appear to be necessary.

SUBPART X

In the Agency’s model the CILCO Edwards boilers 1 and 3 were

assumed to be operating at 6.6 pounds per million Btu, as

requested in PCB 83—100, since that proposal had not been acted

upon by the Board at the time the study was done.

CEx.

5, p.

13).

The Agency made the following findings regarding that

facility:

Although the CILCO Edwards facility at the proposed rate of

6.6 lb/MBtu interacts with the

CAT

East Peoria and WABCO

facilities to produce violations on some days,

it is not a

significant factor during the critical violations.

In other

words, the CILCO proposal does not affect the emissions

limits computed to meet the standard for

CAT

East Pporia or

WABCO.

Bowever,

if CILCO would have been allowed the 6.6

lb/MBtu for boilers 1 and 3 as per their petition to the

Illinois Pollution Control Board, it would have required the

rate at the Bemis facility to be lowered to 5.0 lb/MBtu

instead of the limit presently allowed by the IPCB of 5.5

lb/MBtu.

A rate of 3.8 lb/MBtu for the CILCO Edwards boilers

1 and 3 would protect the NAAQS and would not affect the

emissions limit at Bemis.

(Ex.

5, p. 13)

CILCO

disagreed

with

the

Agency,

and

it also prepared a new

study to investigate the sulfur dioxide emissions rate which

would have to be met by boilers 1 and

3 of its Edwards Station to

meet

the

NAAQS.

Apparently, the Agency’s analysis (Ex.

5)

predicted

violations

to

which

CILCO

contributed

based

upon

presently

allowable emissions rather than on emissions which

would be allowed under the Agency’s present proposal.

Since the

86-88

---

proposal

is more restrictive than the present

limitations, CILCO

argues that the Agency’s modeling would establish that it could

be allowed

to emit 6.6 pounds per million Btu without causing

NAAQS violations

if the modeling took into consideration the

proposed regulatory changes.

CILCO

commissioned Enviroplan to perform such

a study.

(R,

II,

p.

64).

Mr. Howard Ellis, President of Enviroplan,

testified

concerning

that study.

Enviroplan reviewed

the Agency~smodeling

and adjusted

the maximum emission rates

to reflect the proposed

limits.

(R.

II,

pp.

64—66

and Exs~8—11),

This analysis showed

“that

all violations are eliminated with Edwards Units

1

and

3

at

6.6 pounds SO2 per million Btu and other sources at

the IEPA

proposed emission limits.”

(R.

II,

p.

66),

A second analysis

was conducted

to review all predicted NAAQS violations from

Enviroplan’s earlier studies of CILCO to determine whether

those

violations would also be eliminated.

The study found

that they

are eliminated when the new standard applicable

to WABCO is

included and corrected stack location co—ordinates are used for

Bemis.

(R.

II,

pp.

67—68).

Furthermore, allowing a relaxed

standard

of 6.6 pounds per million Btu

for CILCO was found

to

have

no effect on the appropriate standards for

other facilities

affected by

this proceeding.

(R.

II,

pp.

71—77).

None of the

other participants disagreed with these conclusions.

The Board finds

that the record supports

a

6.6 pound per

million Btu standard for CILCOes E.

D, Edwards Station Units

1

and

3,

and

it will propose the amendment as submitted as new

Section 214.561,

The Board also proposes

to add new Section

214.560 which will indicate the scope of new Subpart

X:

Utilities, which will include industry and site—specific

exceptions

to the otherwise applicable sulfur dioxide rules.

ECONOMIC IMPACT

No economic impact statement has been prepared

for

this

proceeding and

it appears that none may be necessary.

On

September 27,

1985 the Board received a letter from

the Agency to

the Department of Energy & Natural Resources

(DENR)

requesting

that the DENR issue a negative declaration,

CILCO and

Caterpillar

are represented

to be

in concurrence with

the

request.

Therefore,

no further hearings are expected

to be

necessary.

However, should the DENR determine that a study

is

necessary,

the Board will conduct hearings on that study as soon

as possible after

it is forwarded to the Board,

There was no testimony at hearing regarding any adverse

economic impact:

i.e.,

there

is no compliance cost,

Each of

the

affected facilities are presently emitting below the proposed

emission limits,

(See Ex, l1)~ This also demonstrates that

meeting

the limitations

is technically feasible.

In addition,

the proposed rules will give support for the redesignation of the

Peoria-Pekin area as attainment

for purposes

of

the Clean Air

Act,

thereby avoiding any federal sanctions,

and benefitting

the

---

state’s economy.

Finally,

as the Board recognized

in PCB 83—100,

granting the requested relief

to CILCO

“would likely result

in

increased coal usage of about 85,000 tons annually,

creating

direct benefits to the state of

200

to 300 new

jobs

and

additional

revenues of over

$20 million.”

(57 PCB 418).

Mr.

Gerald Hawkins,

legislative director

for

the United Mine Workers

in

the State

of Illinois testified that the UMW strongly

supported these proposed rules

in order

to aid the Illinois

mining industry.

(R,

II, pp~8—10).

The Board hereby proposes

for First Notice

the following

amendments

to:

TITLE

35:

ENVIRONMENTAL PROTECTION

SUBTITLE

B:

AIR POLLUTION

CHAPTER

I:

POLLUTION CONTROL BOARD

SUBCHAPTER c:

EMISSION STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART 214

SULFUR LIMITATIONS

SUBPART

C:

EXISTING SOLID FUEL

EMISSION SOURCES

Section

214.140

Scope

This Subpart contains rules which establish general sulfur

emissions standards for

existing solid fuel emission sources.

These may

be modified by industry and site—specific rules

in

Subparts N,

et seq.

Section 214.141

Sources Located

in Metropolitan Areas

P~ssee~e~app~4es~e ex~st4ng~fueleemb~s~4ense~ees~eea~e~

4~~e

?h~eage7S~v~et~s

e~s~e~Peefia ma~eemetfepe~~a~

e~eas~Except as otherwise provided in this Part See~e~,no

person

shall cause

or allow the emission of sulfur dioxide into

the atmosphere

in any one hour period

from any existing

fuel

combustion source, burning solid fuel exclusively,

located

in the

Chicago,

St. Louis

(Illinois)

or Peoria major metropolitan areas,

to exceed

~T~9

k~

~~nds

of sulfur dioxide per MW hf

miii Btu

of actual heat input ~

a.

Sources located in Kankakee

or McHenry Counties shall

not exceed 6.8 pounds of sulfur dioxide per mm ~ Etu of

actual heat input (~8~E

kg/MW Hf) (j~anorams~

b.

Existing

industrial sources, not equipped with flue gas

desulfurization systems as of December

1,

1980,

located

in

the Peoria major metropolitan area,

shall

not exceed

5~5pounds of sulfur dioxide per mm b Btu of actual heat

---

—9—

input

~

kg/MW bf)

~

~

the

~

ssions

from

an

sh

source located

I

n

~t~eo

r

i

a

ax it

f

roma

stack

which

is

at

least

154

feet

(47,~inh~9h~,

e~ Pb~

See~4o~wi~~

~

apply

~e ~he Village

of W~~e~ka

B~4l~yPleab ~n~l

f~alae~e~on R89—2~7

Beeke~

B7 ~s taken by the Pollat~en?e

i~elBoae~

c.

l4.l22sllltnfueicomhust

ion

—

emi

~

i

fisdesulfuriza

tion

s1~~s

asot December

1,

1980

and located_in

the

~

of

Eas

~riaa

he cit

boundaries wereth

en

~

is s

ion of

u 1 fur

diox ide

into

the__at~

nanho

u

r

~2d

from an

such sources to exceed l.4d

S

of

~

02

~amsoer~oule~

d.

~

___

~

fuel

j~in~

nn~re

nl25mrn~~r

hour

(36.6

~tts)

and which as

of December

1,

1980 are

~

are

located

in

~sTownshi,Peoria~ount,asthetownshi

boundaries were then defined,

No

erson shall

cause

or

allow

t

e emission of sul ur dioxide

into the

~g~p

T~~oneour~iodroman

such source

to exceed

~

sulfur

dioxide

er mm

Btuo

actual heat

~p~3nanorams~j~e).

SUBPART

X:

UTILITIES

Section

214.560

Scope

a.

b.

This Subpart contains rules which modify

the

general

~r

emission

rules

of

Sub

arts

Athr ough Mas_applied

~~1venindustrorataivensjt~,G~alru

I as

include:

1.

SubpartsBthroughl:Fue 1 combustion emission

Sources and incinerators;

2.

Subpa r ts K throuhM:

P

miss i

0

nsourees,

These

rules have been

rou ed for the convenience of

the

~

and histor

,

Rules

laced in this Sub~~Jnc1udethos~

~peartoberimarjlditected~fol1owin

---

—10—

Section

214.561

E.

ID.

Edwards Electric Generating Station

Units

1 and

3

at

the

E.

D.

Edwards Electric Gener~~~tion

shall not exce

undsof sulfur dioxide per mm Btu of

actual

heat

~

emissions

from the

E.

D. Edwards Electric Generatin~jStation, on

a

~

sulfur

~xideerhour.

IT IS SO ORDERED.

I,

Dorothy

M. Gunn, Clerk of the

Illinois Pollution Control

Board, hereby certify that the above Opinion and Order was

adopted on

the ~

day of

________________

, 1985 by a

vote of

7—c

—,

Dorothy

M.

Gunn,

Clerk

Illinois Pollution Control Board