ILLINOIS POLLUTION CONTROL BOARD
    January 18,
    1991
    JEFFERSON SMtJRFIT CORP.,
    Petitioner,
    PCB 91—8
    v.
    )
    (Provisional Variance)
    )
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY,
    )
    )
    Respondent.
    DISSENTING OPINION
    (by J.D. Dumelle):
    The Petitioner had been burning coal of about 1.5 lbs per
    MMBtu sulfur dioxide emission potential.
    The standard
    is 1.8.
    The
    “average” expected 502 emission rate
    is 1.87.
    The maximum
    permitted under the majority’s grant of this provisional variance
    is
    2.0 lbs. of 502 per MMBtu.
    Nowhere in the IEPA’s Recommendation or in the Petitioner’s
    materials
    is there any statement about the ambient levels of sulfur
    dioxide.
    Is the AAQS (ambient air quality standard)
    for
    a one—hour
    period exceeded using coal which causes an emission of 2.0 lbs.
    SO2
    per MMBtu?
    We do not kno~i. No one in Illinois has had an opportunity to
    ask
    for a public hearing or
    to comment on this variance from the
    existing 1.8 standard.
    The difference of 0.2 lbs per MMBtU between the standard and
    the permitted rate represents an 11
    increase in sulfur dioxide
    emissions.
    Is the Alton area right at the air quality standard or
    is
    it well below?
    If periods of fumigation occur
    in high winds
    will the AAQS be exceeded under the variance?
    We are told nothing.
    This Board’s first duty is to safeguard the health of its
    citizens.
    We don’t know if
    this variance protects Illinoisans’
    health.
    The Board’s second duty is not to violate USEPA standards.
    To
    do so repeatedly
    (more than once a year on average) will make
    portions of Illinois liable to designation as “non—attainment
    areas”.
    That designation may bring with it a construction ban on
    new or expanded industry
    in the Metro East area.
    The IEPA on p.
    2 of its Recommendation states “...the average
    expected sulfur dioxide emission rate
    is 1.87
    lb/MMBtu...”.
    But
    IEPA does not give the period over which that “average” is
    figured.
    The
    maximum
    one—hour ambient air quality level resulting
    118—121
    from the burning
    (at the 2.0 lbs level actually granted) has to be
    computed arid checked against the USEPA standard.
    It appears this
    was never done because all of the materials submitted are silent.
    ~
    ~ciL~/~k,
    JØcob
    D. Dumelle, P.E.
    LCDR-CEC-USNR
    (Ret)
    Board Member
    IT IS SO ORDERED.
    I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above
    senting Opinion was
    submitted on the
    _________
    day of
    _______________,
    1991.
    ~42’L.
    Dorothy M.
    G,~?n,
    Clerk
    Illinois Po1~,XutionControl Board
    118—122

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