ILLINOIS POLLUTION CONTROL BOARD
    December 11,
    1975
    CENTRAL ILLINOIS LIGHT
    COMPANY,
    Petitioner,
    v.
    )
    PCB 75—177
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    Mr. William B.
    Woinbacher and Mr. Randall W. Moon, O’Hern,
    O’Hern and Wombacher, appeared on behalf of Petitioner,
    William A.
    Erdrnan appeared on behalf of Respondent.
    OPINION
    AND
    ORDER OF THE BOARD
    (by Mr.
    Goodman):
    This matter comes before the Pollution Control Board
    (Board)
    upon the June 23,
    1975, Amended Petition of Central
    Illinois Light Company
    (CILCO).
    The Amended Petition seeks
    variance from Rule 3-3.112 of the Rules and Regulations
    Governing the Control of Air Pollution until May 30,
    1975,
    and from Rules 203
    (g) (1) (B)
    and 204
    (c) (1) (A)
    of the Air
    Regulations until October
    1,
    1975,
    for Boilers #5 and *6 at
    its RS. Wallace Generating Station.
    The station is located
    in East Peoria,
    Tazewell County, Illinois,
    and has ten steam
    boilers,
    six fueled with natural gas and four fueled with
    pulverized coal.
    Boiler #5 was installed in 1939 and has
    a rated heat
    imput of 323
    MMBTU
    per hour.
    Boiler #6 was installed in
    1941 and has a rated heat imput of 420 MMBTU per hour.
    Both
    boilers were originally coal—fired but in 1949 they were
    converted to burn natural gas
    as well.
    Each have mechanical
    dust collectors.
    Calculated at 85
    efficiency for the
    collectors,
    the boilers, when using pulverized coal, emit
    1.5
    lb per MMBTU per hour
    (R 140).
    However, the collectors
    are probably less than 85
    effective
    (R 164).
    Rule 3-3.112
    of the Rules and Regulations Governing the Control of Air
    Pollution set
    a limit of 0.6
    lb. per MMBTU and Rule 203
    (9) (1) (B)
    of the Air Regulations prohibits particulate
    emission rates from exceeding 0.1 lb. per NMBTU.
    Due to a curtailment of natural gas supply, Boilers
    #5
    and #6 were operated, intermittantly from April 28 and
    April
    21,
    respectively, with pulverized low sulfur coal
    (R 83-4).
    These Boilers provided CILCO with 70 megawatts
    (Pet.
    X—4).
    The first time CILCO had knowledge of the
    impending gas shortage was in
    1971
    (R 27).
    In 1972 CILCO
    19
    -
    436
    —2—
    experienced a
    3 month curtailment;
    in 1973,
    a
    7 month cur-
    tailment; and 1974,
    a 12 month curtailment
    (R 28).
    In 1974
    CILCO’s natural gas allocation was curtailed 27
    and through
    April,
    1975,
    34
    (R 29).
    CILCO never approached other power
    companies to obtain firm purchase power.
    CILCO states that
    it considered various supplementary devices to control its
    particulate emissions and comply with the Air Regulations.
    However,
    no device could be installed before October when
    they intended to take the Boilers off the line
    (R 144-50).
    Petitioner also rejected converting to oil as the time was
    too short
    (R 49).
    Therefore, CILCO, considering this to be
    an emergency, began operating the subject boilers on a last
    on first off basis
    (R 63).
    Indeed, CILCO asks that this
    variance be granted for emergency purposes
    (Pet.
    5).
    The parties stipulated to the admission of the follow-
    ing air quality data for the Peoria area:
    (a)
    the 24 hour
    primary particulate standard was exceeded one day at a
    monitor one half mile northeast of CILCO;
    (b)
    the annual
    geometric mean of 75 ugm/m3 was exceeded at the Pekin sta-
    tion some ten miles southwest of CILCO
    CR 130-32).
    Peti-
    tioner submitted a Battelle study which monitored the Peoria
    Air Quality from four stations during the period of April,
    1974,
    through March,
    1975.
    At first glance this report states
    that Peoria is meeting the primary ambient air quality
    standards.
    Battelle arrived at this conclusion by averaging
    the monitor reports.
    Actually the report shows that Peoria
    exceeded the annual geometric mean at one monitor
    (R 154—
    66)
    Petitioner states on page
    5 of its November 21,
    1975,
    “Proposed Findings of Fact and Order”
    that it
    is meeting the
    emission limitations for SO2.
    Therefore a variance from
    Rule 204
    (c) (1) (A)
    is not needed and one will not be granted.
    The Board has often stated that it will not grant
    variances for use in emergency situations, Galesburg State
    Research Hospital
    v.
    EPA, PCB 75-198
    (1975);
    State of
    Illinois, Department of Mental Health, Manteno State Hospital
    v.
    EPA, PCB 74-352
    (1974);
    Stein Hall and Company
    V.
    EPA,
    PCB 73-561.
    In addition, the record reflects the failure of
    the area to meet the ambient air quality standards.
    The
    Board also notes that Petitioner has failed to provide
    a
    compliance plan even though there appears
    to be a good
    chance of a gas shortage for next year
    (Pet.
    X
    1—3).
    The
    Board holds that CILCO has failed to meet its burden and,
    therefore,
    the Board must deny the relief sought.
    19
    -
    437
    —3--
    This Opinion constitutes the Board’s findings of fact
    and conclusions of
    law in this matter.
    ORDER
    It is the Order of the Pollution Control Board that
    CILCO’s petition for variance from Rule 3-3.112 of the Rules
    and Regulations Governing the Control of Air Pollution and
    Rules 203(g) (1) (B) and 204(c) (1) (A) of the Air Regulations
    be and is,
    hereby, denied.
    IT IS SO ORDERED.
    I, Christan
    L. Moffett, Clerk of the Illinois Pollution
    Control Board, hereby certify the above Opini n and
    rder
    were adopted on the
    //l”~t
    day of
    _____________
    1975 by a vote of
    ~
    ~
    Illinois Pollution C
    ol Board
    19
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