BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ItIECEIVED
CLERK’S
OFFICE
IN ThE MATTER OF:
)
PROPOSED NEW
35
ILL.
ADM. CODE 217.
SUBPART V,
ELECTRICAL POWER GENERATION
)
)
)
)
JAN
0
5
2001
RO 1-16
(Rulemaking Air)
STATE OF ILUNQIs
Pollution Control Board
NOTICE
TO:
Dorothy Gunn, Clerk
Illinois Pollution
Control Board
James R. Thompson Center
100 WestRandolph
Suite
11-500
Chicago, IL
60601
Bobb A. Beauchamp, Esq.
Hearing Officer
flhinois Pollution Control Board
James R. Thompson Center
100 West Randolph
Suite
11-500
Chicago, IL
60601
SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that I have today filed with the Office ofthe ClerkofPollution Control Board
the Comments ofMidwest Generation, a copyofwhich is herewith served upon you.
Respectfully Submitted,..
Midwest Generation EME, LLC
By:
mey~~~
Dated:
January
5,
2001
Mary A. Gade
Cynthia
A. Faur
Sonnenschein Nath & Rosenthal
8000 Sears Tower
233
S. Wacker Drive
Chicago, IL
60606
312/876-8000
11147970
THIS FILING IS BEING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOAR~E
c
~
AV
~&D
CLERK’S OF~’~
~THEMATTEROF:
)
JANO52001
)
STATE OF ILLINOIS
PROPOSED NEW
35
ILL.
)
RO1-16
Pollution
Control Board
ADM. CODE 217. SUBPART
V, ELECTRIC
)
(Rulemaking Air)
POWER GENERATION
)
Comments ofMidwest Generation on the
Proposed Amendments to 35 Iii. Adm.
CodePart 217. Subpart V
Midwest
Generation EME,
LLC (“Midwest Generation”) hereby submits the following
comments on the proposed amendments to
35
Ill. Adm. Code Part 217, Subpart V for Electric
Generating Units (“EGUs”).
The purpose ofthese comments is to supplement the statements
made by Scott B. Miller at the Illinois Pollution Control Board’s (the “Board’s”) November 28,
2000 hearing on the proposed Subpart V rule.
As the Board is aware, Midwest Generation is a new company to Illinois with its
headquarters in
Chicago.
It is a subsidiary ofEdison Mission Energy, which is one ofthe largest
independent power producers in the world with an
installed capacity of over 27,000 megawatts
ofelectrical generation.
On December 15,
1999, Midwest Generation purchased the fossil fuel
fired assets of Commonwealth Edison (“CoinEd”).
These assets included coal-fired power
plants located in Chicago, Waukegan, Romeoville (Will County), Joliet, and Pekin (Powerton),
Illinois.
Midwest Generation also acquired from CornEd a gas/oil-fired powerplant near Morris,
Illinois and
several natural gas units.
Midwest Generation has an installed capacity of 10,000
megawatts in
Illinois.
It also has operations in Pennsylvania.
When Midwest Generation purchased CornEd’s fossil
assets, it made a commitment to
reduce nitrogen oxide emissions from those plants by 50
on both a rate based and annual
1
emissions basis by the end of2002.
This commitment was not based upon future regulatory
requirements orthe prospect of early reduction credits, but was based upon a desire to improve
air quality in Midwest Generation’s operating area.
Midwest Generation has begun work to fulfill its commitment.
Earlierthis year, Midwest
Generation retrofitted three tangentially fired boilers at its Joliet, Waukegan, and Will County
stations with low NOx burners that utilize both close-coupled
and separated overfire air ports
known as the ABB TFS-2000 system.
All three units have achieved NOx reductions as low as
0.130 lbs/mmBTU
and collectively will reduce NOx emissions by
4,500
tons in this year’s ozone
season and 9,000 tons annually.
The newly achieved emissions rate at all threeunits is greater
than a 50
emission reduction on those units.
In 2001, Midwest Generation plans to install NOx controls at five additional units.
These
controls will reduce NOx emissions by an additional 7,000 tons during the ozone season and
14,000 tons annually.
In addition to Midwest Generation’s coal-fired power plants, the Company also owns and
operates
12 small combustion turbines at two locations.’
The rated capacity for these 12 turbines
ranges from 25
MWe to 38 MWe.
Midwest Generation operates these turbines to meet peak
electricity demand, and the turbines only operate a few hundred hours per year.
In fact, the
operating hours for each ofthese small turbines were only in the range of 103 hours to 332 hours
during 1998 and
1999.
Midwest Generation’s actual NOx emissions from these 12 peaking units
were 223 tons in
1998 and only 100 tons in 1999.2
Eight of
the units
are located at Midwest Generation’s Fisk Generating
Station and four ofthe units are located at
its Waukegan Station.
2
Midwest Generationnotes that controlling NOx emissions from these peaking units would be cost prohibitive
given the fact they operate only a few hundred hours ayear.
For informationalpurposes the cost ofNOx
controls
for the Fiskpeakers (total of 8) range from $5.4 million
($27,000/ton) to $25.2 million ($62,800/ton).
The costof
NOx controls for the Waukegan peakers (total of 4) range from $3
million ($25,300)
to $12.6million ($62,800/ton).
These are in
1992
dollars.
2
Midwest Generation generally supports the proposed Subpart V rule.
As Mr. Miller
indicated in his questioning of the Agency at the November 28 hearing, however, Midwest
Generation was concerned that the rule, as originally proposed, would require the owners and
operators ofsmall combustion turbines, like the 12
ownedby Midwest Generation, to implement
costly and onerous monitoring and recordkeeping requirements that were not justified by amount
oftime those units are operated and their emissions.
The basis forMidwest Generation’s concern was that under
§
217.710, as originally
proposed, small combustion units would havebeen required to comply with the monitoring and
recordkeeping requirements of40 CFR Part
75.
While these small units would not have been
required to install continuous emission monitors (“CEMs”), under the rule as originally
proposed, these small peaking units would have been requiredto use an alternative monitoring
method that was equivalent to the use ofa CEM.
These small peaking units would also have
been required to satisfy the recordkeeping requirements of40 CFR Part
75.
40 CFR Part 75
requires extensive records to be kept in a specific electronic format
-
even forsmall units.
Midwest Generation estimates the costs ofinstalling the Part 75 monitoring at its
12
small combustion turbines, at approximately $200,000, or approximately $100,000 per site.
More specifically, Midwest Generation estimates that purchasing data loggers and DANS
computers, and configuring that equipment would cost approximately $60,000 per site, and it
estimates that the cost of installing the computers and the necessary wiring from the turbines to
the computer system would cost approximately $40,000 per site.
While most ofthe costs would
be for wiring fuel and operating signals from thepeakers to the Part 75 computer and software
upgrades to the Part 75
computer, Midwest Generation also estimates that the annual costs
3
associated with maintainingthe equipment
and compiling the required information would range
from $10, 000 to $20,000 for all
12 units.
On December 21, 2000, the Agency proposed an amendment to the proposed rule which
would provide alternative monitoring and recordkeeping requirements for certain small
combustion turbines.
See Motion to Amend, dated December 21, 2000.
Specifically, the
Agency proposed that owners or operators ofsmall combustion turbines that operate less than
350 hours during the ozone season be able to determineNOx emissions using certain default
emission factors and a heat input derived from either metered fuel usage or a calculation based
upon the turbiness maximum hourly heat input and its hours ofoperation. ~
Proposed
35
Ill.
Adm. Code
§
217.7 10(c) (as amended).
The Agency further proposed amendments to the
rccordkeeping provisions ofSubpart V consistent with the proposed revisions to the monitoring
requirements.
~
Proposed 35 Ill. Adm.
Code
§
217.712(b) (as amended).
Midwest Generation strongly supports the Agency’s proposed revisions
to Subpart V.
discussed above.
The use ofconservative default factors will tend to overestimate emissions
from the smaller peaking units
and require other units in an averaging plan with the small
peaking units to
meet more stringent emission levels than would be required if the smaller units
used Part 75 monitoring data.
The use of the default emission factorsproposed by the Agency,
however, will enable smaller sources to demonstrate compliance with the requirements of
Subpart V in a cost-effectivemanner.
In conclusion, Midwest Generation supports the proposed Subpart V rule, as amended by
the Agency on December 21,
2000.
As the owner of 12 ofthe
14 existing small combustion
turbines affected by
Subpart V, Midwest Generation believes that the proposed revisions to
§§
217.710 and 217.712 ofthat proposed rule will enable it and the other owners ofsmall
4
combustion turbines to comply with the emission limitations ofthe proposed Subpart V rule in a
cost-effective manner.
Accordingly, Midwest Generation requests that the Board adopt the
Agency’s proposed revisions to 35
III. Adm. Code
§
217.710 and
§
217.712.
Midwest Generation thanks theBoard forthe opportunity to comment on this
rulemaking.
Respectfully Submitted,
Midwest Generation EME, LLC
By:
ne
its
11227100
5
CERTIFICATE OF SERVICE
The undersigned, an attorney,
certify that I have served upon the individuals named
below true and
correct copies ofComment ofMidwest Generation by Messenger, as indicated or
First Class Mail, postage prepaid on January 5,2001.
Service List
RO1-16
Bobb Beauchamp, Hearing Officer
Illinois Pollution Control Board
State of Illinois Center
100
West Randolph Street, Suite 11-500
Chicago, IL 60601
Karen Bernoteit
Brooke Peterson
Illinois
Environmental Regulatory Group
215
East Adams Street
Springfield, IL 62701
Amy Clyde
Dynegy Midwest Generation, Inc.
2828 North Monroe Street
Decatur, IL 62526
Lenny Dupis
Dominion Generation
5000 Dominoin Boulevard
Glen Allen, VA 23060
James T. Harrington
David L. Rieser
Brian Marzquez
Ross & Hardies
150 North Michigan Avenue
Suite 2500
Chicago, IL 60601
Kevin Haynes
Gabriel M. Rodriquez
SchiffHardin & Waite
6600 Scars Tower
Chicago, IL 60606
Katherine Hodge
Hodge &
Dwyer
3150 Roland Avenue
P0 Box 5776
Springfield, IL 62705-5776
Alan Jirik
Corn Products
6500 Archer Road
Bedford Park, IL 60501
Bryan Keyt
Bell Boyd & Lloyd
70 West Madison Street
-
Ste. 3300
Chicago, IL 60602
Scott Miller
Kent Wanninger
Midwest Generation EME, LLC
One Financial Place
440 S. LaSalle Street
-
Ste 3500
Chicago, IL 60605
William Murray
Office ofPublic Utilities
800 East Monroe
Springfield, IL 62757
Nancy Rich
Katten Muchin & Zavis
525 West Monroe
Suite 1600
Chicago, IL 60661-3693
Mary Schoen
ENRON
Corporation
1400 Smith Street
P0 Box
1188
Houston,TX 77251-1188
Steven Whitworth
Ameren Services
1901 Chouteau
P0 Box66149,MC 602
St. Louis,MO 63166-6149
11235578
