ILLINOIS POLLUTION CONTROL BOARD

September

16,

1971

IOWA-ILLINOIS GAS

AND

ELECTRIC

COMPANY

#71—165

V.

ENVIRON~NTAL PROTECTION AGENCY

RO~R

GANOBCIK, ATTORNEY FOR ENVIRONMENTAL PROTECTION AGENCY

CRAMPTON

& DALEY, ATTORNEY FOR PETITIONER

OPINION OF THE BOARD

(BY MR. LAWTON):

Petitioner filed a variance application with

the Board relative

to its Moline generating

station, seeking permission to exceed the

particulate emission regu”lations governing the control of air ~ollu-

tion as

a consequence of coal burning in six stoker-fired boilers

pending completion of the Quad-Cities Nuclear Power Station.

The petition and evidence set forth that Boilers

#16,

#17

and

#18 are spreader stokers burning both coal and natural gas.

Boilers

#19,

#20

and

#21 are underfeed stokers burning coal only.

The variance

request seeks permission to burn coal in Boilers

#19,

#20

and

#21

in an emergency capacity until Quad—Cities

Unit No.

1 becomes commer-

cially available

for service,

at which time these three boilers will be

permanently retired,

The variance further asks that Boilers

#16,

#17

and

#18 be permitted to burn coal to meet load demands until

Quad—Cities Unit No.

1 is in commercial service,

and thereafter,

to

pen~itburning of coal only in emergency situations until

July

1,

1974,

at

which time coal-firing will be eliminated.

The original recommendation of the Agency recommended allowance

of the variance

for

a one-year period which is the maximum we are

authorized by statute

to allow, retirement of Boilers

#19,

#20

and

#21

upon completion of Quad-Cities Unit No.

1,

use

of the coal-burning

boilers for emergency situations only

and upon completion

of Quad—

Cities Unit No.

1,

the remaining boilers subject to the petition

be

converted to burn No.

2 oil or residual

oil of 1,8

sulphur content,

or in the alternative,

that dry mechanical collectors having

75

efficiency

be installed by that date.

At

the close of the hearing,

discussion took place

(IR,45)

indicating

the possibility of agreement between petitioner and

the Agency with

“~egardto conditions

for the continued coal burning

in

Boilers

#16,

2

—

477

---

#17

and

#18 subsequent to the commercial operation

of Quad-Cities

Unit No.

1.

Following the hearing,

a supplemental affidavit was

filed by Richard B. Miller, Manager of

the Electric Engineering Depart-

ment of petitioner, proposing the following conditions

for the opera-

tion of Boilers #16,

#17 and

#18 after Quad-Cities No.

1 has been

placed in operation:

“Boilers

#16,

#17

and

#18, Moline Generating Station,

shall be limited on coal burning operation to meet the

emergency power requirements only, which shall not exceed

the equivalent of 31 days

or 744 hours

of operation

(31

days

x

24 hours

=

744 hours)

per boiler, per annum

(a

period of 12 consecutive months,)

An hour of operation shall be counted as having been

fired on coal when both

of the following conditions

are

met:

(a)

coal

is fired singly or

in combinations with

gas fuel and at

a rate such that the equivalent

steam generation rate for each boiler on coal is

25,000 pounds per hour

or greater,

and

(b)

the boiler on line generating steam.

The steam generation rate

at a level less than 25,000

pounds per hour is proposed to be exempted from the hours

of operation calculations.

The maximum continuous steam

generation rate of each of these stoker-fired boilers

is

100,000 pounds per hour.

The 25,000 pounds per hour level,

or less, would be approximately equivalent

in particulate

emission to

a pulverized coal facility operating at full

capacity and equipped with high grade mechanical

dust

collectors.

The calculation of the 25,000 pounds per hour level

or

less excludes periods when the boiler

is being started,

kept on hot standby or is banked in anticipation of

an emer-

gency, or to back

for gas

fuel firing

and during periods

when boiler gas contaminant appears imminent,

At these lower levels of firing rate,

the coal firing

operation

is steady and emissions standards are achieved

or closely approached.

The equivalent of

31 days

of coal operation,

as outlined

above, would permit one refueling of

a nuclear unit at

Quad-Cities Station

(estimated to require

21 days)

and

additionally, accommodate two one-week

(total of

10 days)

operating emergencies in any consecutive 12-month period.”

2

—

478

---

The Agency responded to this proposal stating

as follows:

“Petitioner has submitted

a proposal

for

such

agreement.

The Agency does not accept that oroposal,

in that

it

would authorize

the

generation

of

steam

b~coal—burning

in all three boilers

for more than

two

hours

per

day

every

day

of

the

year,

and

the

constant burning of coal

to the limited extent neces-

sary to keep these boilers on

~spinning’

standby

indefinitely,

This

would

go

well

beyond

1reserve

for

emergency

purposes’,”

The

Agency

proposes

the

following

limitation:

a)

After

Quad-Cities

Unit

#1

has

been

placed

in

commercial

operation,

coal

shall

be

burned

in

Boilers

#16,

#17

and

#18

(Moline

Generating

Station)

only

to

meet

emergency

requirements,

as

defined

in

the

Agency’s

recommendation,

such

use

to

be

limited

to

ten

days

per

year,

except

that;

b)

In

the

event

of

the

refueling

of

a

nuclear

unit

at

Quad—Citie~

#i,

which

refueling

renders

such

unit

temporarily

useless

as

a

source

of

power,

coal

may

be

burned

in

said

boilers

for

21

days,

which

days

shall

not

be

charged

against

the

ten

days

described

in

(a)

above.

c)

For

purposes

of

these

limitations,

a

day

shall

be

counted

if,

for

at

least

one

hour

during

that

day:

i.

Coal

is

fired

singly

or

in

coihbination

with

gas

fuel

at

a

rate

such

that

the

ecuivalent

steam

generation

rate

for

any

hoiter

on

coal

is

25,000

pounds

per

hour

or

preaner;

and

ii.

The

boile:

Is

“on

l~

generating

steom.

A

second

supplemental

sf1: Thavit.

was

received

from

petitioner

~ts

o

~

oroo~

~1

~Io~eter

~

do

non

acoe~t

oi.the:

proposa.

tuft

oo

grant

a

variance

for

a

one—year

Th

o~

~Et

fortn

i

tb~

~ci

~ta~

pc~:t1O~Of

:IiIi:

Grde~::

IThe

total

oaipaolty

of

all

faci.litIes

of

i~

o~r-~r

o~

~tt~

~:

r~

~i

~

i~c

~ ~

~:one

~enerates

aoon:ximat

ely

III

secrawatte

,

The

nenerating

caraci

cy

of

5

oIlers

#19,

#20

end

#21

is

10

moqawatta

and

of

toilers

#16,

f .27

end

#18

24

rnegewaf’:e.

An

stated

snore.

toilers

~19

#20

nod

#21

safle

coal—fired

and.

will

be

obased

out

complete..y

50.00

the

opera—

~von

of

Q

ad~

ion

Jolt

to

1.

BoiLers

•#15~

#17

and

#15

are

coal.

and

—~

i

~

~

~

_

m

—~

~

rr

1

---

Upon completion of Quad-Cities Unit No.

titled to

50

main the same when Unit No.

receiving 25

On February 7,

Program

(Acerp)

templated that Quad-Cities Unit No.

for service by June

1,

1970,

Cities in commercial use at the earliest possible date,

It is also

significant that Petitioner, by this variance request, is seeking

only

to

pursue

a

program

that

has

been

previously

approved

by

our

predecessor

state agency,

While the capacities

of the boilers in question are relatively

small, Petitioner asserts that it will be in

danger of not meeting

its

load ob~Ligationsor the 12

reserve requirements specified in the Iowa

Pool Agreement

if use of the boilers,

subject to the variance request,

is

denied.

A

load and capacity data

study

is in the

record.(Ex. A,

R.42),

indicating the system~s capacity including the

12

reserve

por-

tions

from other systems and petitioner’s

capacity with and without

the Quad-Cities Station in operation.

The study indicates that even

with Boilers

#19,

#20 and #21

in operation,

a

36

megawatt

deficiency

will occur in January,

1972, based upon its projected generation needs

before the operation of the Quad—Cities station,

Arrangements have

been made

for the purchase of

100 megawatts

of capacity for an 18—week

period beginning December

1,

1971, which according to petitioner will

lessen, but not eliminate,

the likelihood that coal will have to be

burned in some quantities

in the boilers in question.

The evidence

indicates the uncertainty of available gas and fuel oil as alternative

fuel

for use during the winter months,

Abatement equipment in the form of mechanical collectors will

cost in the range of $350,000

to $450,000

for Boilers

#16,

#17 and

#18

(R.37)

It is the Opinion of the Board that the circumstances demonstrated

by petition justify

a continuation of the existing Air Contaminant

Emission

Reduction

Program

(Acerp)

for

a

period

of

one

year

pending

the

commercial

operation

of

Quad—Cities

Unit

No,

I.

The consequences

of continued coal burning, subject to the emergency conditions we impose,

are less severe than

the hardship which would result to the community

in

curtailing of petitioner’s load capacities,

if use of the boilers

subject to the variance request

is denied.

Nor do the circumstances

of

the instant case warrant the expense of installation of abatement equip-

ment.

2—480

---

IT IS TH~

ORDER

of the Board that Petitioner be granted a

variance from the particulate emission regulations of the Rules

and

Regulations Governing the Control of Air Pollution until

September 15,

1972,

subject to the following terms and conditions:

1,

Prior to the time when Quad-Cities Station No. 1 is in

commercial operation, Petitioner shall be permitted to

burn coal in Units

#16,

#17,

#18,

#19, #20 and #21 in

order to meet its load requirements, providing it is unable

to meet such load requirements by the use of its other

facilities, is not capable of obtaining gas or oil to burn

in said boilers and is incapable of purchas~ingadditional

electric power from outside sources;

2.

Subsequent to the commercial operation of Quad-Cities Unit

No,

I,

coal burning in Boilers #16,

#17 and #18 shall

cease and coal burning in Boilers

#19, #20 and #21 shall

be permitted only in the event of severe emergency caused

by major equipment breakdown of petitioner’s

facilities,

and the inability to meet its load requirements from its

operating facilities

or by the purchase of electrical power

from outside sources.

“Coal burning” is defined

as in the

Agency recommendation quoted in this Opinion.

3.

Refueling of nuclear units shall take place when gas

supply is available unless Petitioner can demonstrate to

the Board within 30 days from the date hereof,

that such

refueling cannot be scheduled

at

a time when gas is avail-

able,

4.

Petitioner shall report to the Environmental Protection

Agency and to the Board the circumstances under which it has

been obliged to burn coal in any of the above-designated

boilers including the reasons why such coal burning was neces-

sary, the extent to which such boilers were used

and

the

unavailability of the alternatives hereinabove set forth.

5,

This variance shall not be extended beyond the date of its

expiration except upon a petition being

filed

Board, hearing held thereon and further order of the Board.

This Opinion constitutes the findings of fact and conclusions of

law

of the Board,

I,

Regina E. Ryan,

Clerk of the Pollution Control Board, certify

that the above Opinion was

adopted bv~theBoard on the j~day of

September,

1971.

2

—

481