ILLINOIS POLLUTION CONTROL BOARD
    August
    18,
    1988
    IN THE MATTER OF:
    PETITION TO AMEND
    35 ILL.
    ADM.
    )
    R87—18
    CODE PART 216,
    CARBON MONOXIDE
    )
    EMISSIONS
    (Midwest Grain Products
    )
    of Illinois)
    PROPOSED RULE
    SECOND NOTICE
    PROPOSED OPINION AND ORDER OF THE BOARD
    (by J.D.
    Dumelle):
    This matter comes before the Board upon
    a proposal
    for
    a
    site—specific rule change.
    The proposal seeks
    to amend 35
    Ill.
    Adm.
    code 216.122
    to exempt Midwest Grain Products
    of Illinois
    from the limitations set forth at
    35
    Ill. ~dm. Code 216.121,
    which prohibits carbon monoxide emissions
    in excess
    of 200 parts
    per million corrected
    to
    50 percent excess air.
    On May 19,
    1988
    the Board proposed for First Notice a
    rule which
    is substantially
    the same as that
    initially proposed.
    However,
    in noting several
    questions that remained outstanding, the Board’s Opinion
    included
    suggested alternative
    language and requested comments by Midwest
    Grain Products of Illinois (Midwest)
    and the Illinois
    Environmental Protection Agency
    (IEPA).
    Comments were submitted by both Midwest and
    the IEPA.
    Both
    contested the proposed alternative language
    ——
    but for different
    reasons.
    This opinion will address only the comments submitted
    by Midwest and IEPA.
    The Board’s rationale
    for proposing this
    rule
    is set forth
    in the Proposed Opinion of May
    19,
    1988.
    In its Opinion of May 19,
    1988 the Board set forth the
    following as possible alternative language:
    Section 216.122
    Exception, Midwest Grain Products
    a)
    Emissions
    of carbon monoxide from the bubbling—bed
    fluidized bed combustion boiler
    of Midwest Grain
    Products
    of Illinois, located
    in Pekin,
    Illinois, shall
    not exceed 700 ppm corrected to 50
    excess air during
    periods of load changes.
    No more than 12
    of
    the
    operation hours during any continuous 30—day period
    shall exceed
    the 200 ppm of CO corrected
    to 50
    excess
    air emission limitation of Section 216.121.
    On June
    2,
    1988, Midwest
    filed
    its response to the Board’s
    request
    for comment.
    Midwest states that
    it would be impossible
    to guarantee compliance wiLh the suggested alternative rule for
    91—427
    —2—
    two reasons.
    Initially,
    Midwest states that much
    of
    its recent
    reduction
    of carbon monoxide
    is the result of using
    “one specific
    type of coal”.
    Midwest further states that there
    is no guarantee
    that this coal will always be available:
    “we must have an
    alternate
    .
    .
    .
    supply
    if we are
    to continue operations
    .
    .
    .
    if
    it became necessary
    to use the alternate coal,
    it may be
    impossible to comply with the proposed alternate rule”.
    Secondarily, Midwest states
    that
    it
    is impossible to
    maintain low CO levels during load swings, when CO levels can
    rise above
    700 ppm for short periods of time.
    Midwest notes that
    load swings are mandated by several factors,
    including the
    f011owing:
    (a)
    the process using
    the boiler’s steam output
    (b)
    maintenance requirements
    (c)
    necessary shutdowns for cleaning
    (d)
    sales and production requirements
    In summary Midwest reaffirmed
    its stated intention to
    “do
    everything possible
    to minimize
    CO levels”
    and reaffirmed
    confidence
    in its ability to comply with the rule as originally
    requested.
    On August
    8, 1988 the IEPA filed
    its response to the Board’s
    May
    19,
    1988 Order.
    In responding
    to the suggested alternative
    language the IEPA stated as follows:
    “While the Agency is not
    opposed
    to the current wording
    .
    .
    .
    (it) suggests that a
    one—
    hour averaging time be applied
    to the 700 ppm CO limit
    so as
    to
    smooth out any short excesses over 700 ppm.
    The Agency’s comments noted
    some difficulty
    in determining
    what was or was not a “load change” as set forth in the suggested
    alternate rule.
    The comments stated that “even
    if the boiler
    were being held at
    a constant load,
    there would be some amount
    of
    fluctuation which would constitute a “load change”.
    Determining
    compliance with such
    a
    rule would be extremely difficult, ~ifnot
    impossible.”
    In recognizing
    the Board’s concerns regarding sporadic,
    temporary exceedances
    the Agency’s comments noted
    that use of the
    one—hour averaging period would
    be consistent with
    the modeling
    demonstrations, which relied upon one—hour averages
    in
    demonstrating no significant
    impact upon ambient air quality.
    Finally,
    the Agency’s comments recommended
    the following
    language as an alternative
    to the Board’s suggested alternative
    language:
    The standard
    for carbon monoxide of Section 216.121 does not
    apply
    to emissions from the fluidized bed combustion boiler
    of Midwest Grain Products of
    Illinois,
    located
    in Pekin,
    91—4 28
    —3—
    Illinois, where the emission of carbon monoxide shall not
    exceed 700 parts per million, corrected
    to
    50 percent excess
    air.
    Compliance shall
    be based upon a one—hour average.
    The Agency’s suggested language addresses
    the Board’s
    concerns about exceedances of the 700 ppm limitation without
    creating the difficulties referenced by Midwest
    in its June
    10,
    1988 finding.
    Therefore the Board adopts
    the proposed language
    from IEPA.
    ORDER
    The Board hereby proposes the following for Second Notice, which
    are to be filed with the Joint Committee on Administrative Rules.
    TITLE 35: ENVIRONMENTAL PROTECTION
    SUBTITLE B:
    AIR POLLUTION
    CHAPTER
    I:
    POLLUTION CONTROL BOARD
    SUBCHAPTER
    c:
    EMISSION STANDARDS AND LIMITATIONS
    FOR STATIONARY SOURCES
    PART 216
    CARBON MONOXIDE EMISSIONS
    SUBPART
    A:
    GENERAL PROVISIONS
    Scope and Organization
    Measurement Methods
    Abbreviations and Conversion Factors
    Definitions
    Incorporations by Reference
    SUBPART B:
    FUEL COMBUSTION EMISSION SOURCES
    Section
    216.121
    216.122
    Fuel Combustion Emission Sources
    Exception, Midwest Grain Products
    SUBPART C:
    INCINERATORS
    Section
    216.141
    216.142
    Section
    216.361
    216.362
    Incinerators
    Exceptions
    SUBPART N:
    PETROLEUM REFINING AND
    CHEMICAL MANUFACTURE
    Petroleum and petrochemical Processes
    Polybasic Organic Acid Partial Oxidation Manufacturing
    Processes
    Section
    216 .100
    216.101
    216.102
    216.103
    216.104
    91—429
    SUBPART 0:
    PRIMARY AND FABRICATED METAL PRODUCTS
    Section
    216.381
    Cupolas
    Appendix A
    Rule into Section Table
    Appendix B
    Section
    into Rule Table
    Appendix C
    Compliance Dates
    AUTHORITY:
    Implementing Section
    10 and authorized
    by Section
    27
    of the Environmental Protection Act (Ill.
    Rev.
    Stat.
    1981,
    ch.
    111 1/2, pars.
    1010 and 1027).
    SOURCE:
    Adopted as Chapter
    2:
    Air Pollution,
    Rule 206:
    Carbon
    Monoxide Emissions,
    R71—23,
    4 PCB 191, April
    13,
    1972, filed and
    effective April
    14,
    1972;
    amended at
    3
    Ill.
    Reg.
    47, p.
    92,
    effective November
    8,
    1979; amended
    at
    4
    Ill. Reg.
    24,
    p.
    514,
    effective June
    4,
    1980;
    codified at 7
    Ill.
    Reg.
    13579; amended
    in
    R87—l8 at
    ____
    Ill.
    Reg.
    ___________,
    effective
    ___________________
    SUBPART B:
    FUEL COMBUSTION EMISSION SOURCES
    Section 216.122
    Exception, Midwest Grain Products
    The standard for carbon monoxide of Section 216.121 does not
    apply
    to emissions from the fluidized bed combustion boiler of
    Midwest Grain Products of Illinois, located
    in Pekin, I1lin~ii,
    where the emission of carbon monoxide shall not exceed 700 parts
    per million,
    corrected
    to 50 percent excess air.
    Compliance
    shall
    be based upon a one—hour average.
    (Source:
    Added at
    ___
    Ill.
    Reg.
    ________
    effective
    _______________)
    IT
    IS SO ORDERED.
    I,
    Dorothy M.
    Gunn,
    Clerk of the Illinois Pollution Control
    Board, hereby certify
    that the above Proposed Opinion and Order
    was adopted on the
    ______________
    day of
    ~
    ,
    1988 by
    a
    vote
    of
    ______________.
    ~
    *
    Dorothy M. ~unn,
    Clerk
    Illinois Pollution Control Board
    91—430

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