ILLINOIS POLLUTION CONTROL BOARD
November
29, 1988
IN THE MATTER OF:
)
PETITION TO AMEND 35
ILL. ADM.
)
R87—18
CODE PART
216, CARBON MONOXIDE
)
EMISSIONS
(Midwest Grain Products
)
of Illinois)
ADOPTED RULE
FINAL ORDER
OPINION AND ORDER OF THE BOARD
(by J.D.
Dumelle):
This matter
is before the Board upon
a regulatory proposal
filed
by Midwest Grain Products of Illinois (Midwest)
on June 12,
1987.
Through
its proposal, Midwest
is seeking relief for its
Pekin, Illinois
(Tazewell County) Alcohol Production Facility
from the requirements of
35 Ill.
Adm.
code 216.126, which sets
emission limits on carbon monoxide
(CO)
at no greater
then 200
ppm, corrected
to 50 percent excess air.
Midwest
is proposing
that
it be exempted from that standard and instead be subject to
an emission standard not
to exceed 700 ppm, corrected
to 50
excess air.
The Illinois Environmental Protection Agency
(Agency) took
no position on the proposal, neither supporting or
opposing Midwest’s proposal.
?~merit hearing on this proposal was held on November
23,
1987,
at the Pekin City Hall, Pekin, Tazewell County,
Illinois.
On February
16, 1988,
the Department of Energy and Natural
Resources
(DENR) filed
a negative declaration,
setting forth its
determination that the preparation of
a formal impact study was
unnecessary.
The negative declaration was based upon DENR’s
finding that the cost of making
a formal study
is economically
unreasonable
in relation to the value of
the study to the Board
in determining any adverse economic impact of the proposed
regulation.
On March 15,
1988, ,the Board received notification
that the Economic and Technical Advisory Committee
(ETAC)
concurred
in DENR’s negative declaration.
BACKGROUND
At its Pekin Facility, Midwest operates
its plant 24
hours/day,
7 days/week with
4 weeks/yr scheduled for regular
maintenance.
Pet.
5.
The plant, which has been modernized by
Midwest,
has a present capacity of 50,000 gallons/day; and
employs approximately 135 people.
Pet.
1.
The facility consists
of
a new 120,000
lb/hr bubbling—bed fluidized bed combustion
(FBC) boiler and
three natural gas fired boilers
retained for
emergency and standby services only.
R.
33, Pet.
3.
A high—
93—693
—2—
pressure topping—turbine generator was also installed,
generating
3000 KW of electricity for Midwest’s use.
Midwest has provided
the following data concerning
its new boiler:
ENGINEERING
DATA
~OR FLUIDIZED
BED
COMBUSTION 3)ILER
Manufacturer
Foster
Wheeler
Type
Fluidized
Bed
Steam Flow, pph
120,000
Steam Temperature, Degrees F
750
Steam Pressure, psig
685
Steam
Enthalpy,
Btu/lb
1377
Feedwater
Temperature,
Degrees F
228
Feedwater
Enthalpy,
Btu/lb
196
Boiler Efficiency,
83.5
Heat
Input,
MMBtu/hr
170
Coal
Feed
Rate,
lb/hr
16,100
Mass Flue
Gas
Flow Rate,
lb/hr
215,000
The electricity generation
is accomplished using high sulfur
Illinois coal, available
40 miles from the plant
site.
Pet.
3.
Midwest asserted that
the use of locally available Illinois coal,
transported
from nearby mines,
results
in lower
levels of air
pollution.
Pet.
3.
Midwest asserted that fluidized bed combustion technique
is
an efficient and environmentally safe method
for utilizing high
sulfur Illinois coal.
Nonetheless,
it
is asserted,
it
is not
technically possible
to operate the Midwest’s particular
bubbling—bed boiler
in an efficient manner, while simultaneously
meeting the carbon monoxide
limits set forth at 35
Ill. Mm Code
216.121.
Midwest submitted data from a similar Foster Wheeler
(FBC) Boiler currently operating at Georgetown University.
Performance
tests conducted indicate carbon monoxide emissions
(adjusted
to 50
excess air) were
630 ppm based upon wet flue
gas.
Likewise,
at Great Lakes Naval Training Center,
a fixed bed
FBC boiler was operating with carbon monoxide emissions between
1000
and
2000
ppm.
In August
of
1984,
Midwest, using Clear Air Engineering,
conducted emissions
testing on the boiler at
issue.
The results
showed average carbon monoxide emissions of 484 ppm, corrected to
50
excess air.
Pet.
6.
Notwithstanding,
it
is uncontested that
modern fluid
bed boilers are capable of meeting the 200 ppm
limitation.
However,
these newer boilers are
of a different
design which
results
in the lower emissions.
Pet.
8.
MIdwest’s
plant cannot avail itself of this design.
Although the petition referenced
484 ppm average emissions
for August of 1984, testimony at hearing indicated
that emissions
have been lowered such that Midwest
is
in compliance with the 200
93—694
—3—
ppm limitation fully 88
of its operating time.
Mr. Tony
Petricola, plant manager and chemical engineer
for Midwest,
explained the inconsistency between the data as follows:
“Quite
accidentally,
it was discovered
that
a
shift
in coal mix from
a 50/50 mixture of Coal
A and Coal B
to nearly 100
Coal A resulted
in
a
possible
decrease
in
carbon
monoxide
levels.
This
led
us
to
suspect
that
coal
fines
may
be
a
significant
factor
in
influencing
carbon
monoxide
levels
for
this
type
of boiler.
An explanation
is
that
coal
fines
are
carried
out
of
the combustion zone
before they are completely burned.
Incomplete
combustion
is
known
to
produce
carbon
monoxide.
Based
upon
this
finding
Midwest Grain Products now
uses virtually 100
per
cent
Coal
A,
even
though
it
is
more
expensive than Coal B.”
R.
21.
Thus, Midwest was able
to reduce its emission significantly by
altering the source of fuel used.
Mr. Petricola further stated
that carbon monoxide readings at the Midwest plant were not
corrected
for
50 percent excess air; this correction would lower
carbon monoxide data by approximately 15 percent.
R.
28.
Also
it was asserted that exceedances of
the 200 ppm are expected
mainly during load changes.
ENVIRONMENTAL
IMPACT
Although the Illinois Environmental Protection Agency
(Agency) took no official position on Midwest’s proposal,
at
hearing,
counsel for the Agency made the following statement:
“...
But
under
these
facts
that
have
been
presented by Midwest Grain, which are specific
to
Midwest
Grain
and
to
its
particular
FBC
Boiler
and
their
good
current
operating
practices,
and
we
have
studies
that
show
no
harmful effect to the environment.
The Agency
is
basically
taking
the
position
of
no
objection and no actual support
...“
R.
48.
It should be noted that the
studies referred
to were not made
a
part of this record, apparently because the Agency neither
supported nor opposed
the petition.
Additionally, Mr.
Petricola
testified
that the plant
is environmentally safe and meets all
requirements except
those
for carbon monoxide.
R.
15,
27,
28,
Pet.
5.
93—695
—4—
Midwest has sponsored
a study of
its carbon monoxide
emissions from its FBC Boiler, utilizing the industrial
source
complex short term (ISCST) dispersion model.
Pet.
8.
The
modeling was conducted using
1973 meteorological data and
a
carbon monoxide emission of 700 ppm.
A summary
of the results
and the allowable air standards
is set forth below:
Percent of
Averaging
Model
Significance
Significance
Percent
Period
Results
Level
Level
NAAQS
of
Limit
1
HR
l02.7ug/m3
2O00ug~n3
5.1
40,000ug/m3
0.25
8 HR
49.7ug/m3
575ug/ni3
8.6
lO,000ug/m3
0.50
From the data submitted above,
it
is clear that
establishment
of the proposed site specific standard will not
interfere with attainment and maintenance of National Ambient Air
Quality Standards for carbon monoxide.
Midwest’s pro rata
contribution
to the significance level
is
de minimus.
Additionally,
it should be noted that Pekin, Tazewell County is
an attainment area for carbon monoxide.
Based upon
the data
submitted
there will
be no community health impact from the
operation of Midwest’s FBC Boiler.
TECHNICAL FEASIBILITY
Midwest submitted substantial evidence regarding the
technical infeasibility of modifying its plant or boiler
operations.
Midwest undertook several studies
to identify the
causes of higher carbon monoxide levels and possible methods of
reducing them.
R.
19.
In the first study,
boiler
load,
limestone usage,
bed temperature and excess oxygen were varied
——
but no clear correlation was observable.
In most cases, higher
bed temperatures resulted in lower carbon monoxide levels
——
but
higher nitrogen oxide levels.
In a second study performed by
Midwest,
it was concluded that attempts
to lower carbon monoxide
emissions by manipulating operating conditions were useless and
invariably resulted
in inefficiencies and increases in nitrogen
oxide and sulfur dioxide.
R.
21.
(It was during this study that
Midwest discovered that using coal from one of
its suppliers
substantially reduced emissions).
Midwest examined three means
of reducing carbon monoxide:
First,
utilizing
a larger freeboard area above
the bed; second,
increasing excess
air;
and third,
using baffles
in the combustion
chamber.
These have been rejected
as
inordinately expensive,
incapable of significantly reducing carbon monoxide emissions or
simply impractical
and inapplicable
to Midwest’s facility.
R.
22—25.
Although Midwest has examined the problem and studied
many
alternatives,
the plant technology
is such
that
it
is not
93~696
—5—
possible to operate the Foster Wheeler Bubbling Bed Boiler
and
continuously meet the 200 ppm standard for carbon monoxide while
simultaneously maintaining low sulfur dioxide and nitrogen oxide
emissions.
R.
27.
Midwest’s engineers stated they know of
no
available technology to reduce carbon monoxide without decreasing
combustion efficiency and increasing nitrogen oxide emission.
ECONOMIC REASONABLENESS
Midwest introduced testimony that its facility is in
compliance approximately 88
of the
time.
Additionally the
current boiler was obtained
at
a cost of roughly 12.5 million
dollars.
R.
33.
This does not include research costs paid to
Bradley University.
As noted
above, there
is,
as yet,
no known
methodology or technology available that would prevent Midwest’s
facility from exceeding the
200 ppm limitation
——
especially
during load changes.
For Midwest,
this would mean two things:
A
loss of its
$12.5 million investment
in the current boiler
and
additional costs of $20 million
to obtain
a new, modern boiler.
R.
32.
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 and IEPA.
Comments were submitted by both Midwest and the
IEPA.
Both
contested the proposed alternative language
——
but for different
reasons.
In its First Notice Opinion and Order 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,
l’ocated 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 stated that it would be impossible
to guarantee compliance with the suggested alternative
rule
for
two reasons.
Initially,
Midwest stated
that much of
its
recent
reduction of carbon monoxide
is the result of using “one specific
type of coal”.
Midwest further stated that there
is no guarantee
that this coal will always be available:
“we must have
an
93—697
—6—
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 stated that it
is impossible
to
maintain low CO levels during load swings; because CO levels can
rise above 700 ppm for short periods of time.
Midwest notes that
load swings are mandated by several factors, including
the
following:
(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,
if not
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,
Illinois, where
the emission of carbcm monoxide
shall not exceed
700 parts per million,
corrected
to
50
percent excess
air.
Compliance
shall
be based
upon
a
one—hour average.
93—698
—7—
The Agency’s suggested language addressed both the Board’s
concerns about exceedances of the 700 ppm limitation and
Midwest’s concerns about temporary exceedances during load
changes.
Thus the language that “compliance shall
be based upon
an one—hour average” was added at Second Notice.
On August
18,
1988 the Board
issued
its Second Notice
Opinion and Order.
This Order addressed action which occurred
subsequent
to the First Notice Order and prior
to August
18,
1988.
Subsequent
to the Second Notice Opinion and Order
this Board
submitted its Second Notice package
to the Joint Committee on
Administrative
rules.
On November
18,
1988 the Joint Committee
filed
its Certificate Of No Objection To Proposed Rulemaking;
thus there was no need
to amend
or modify language of the
regulation.
The text
of the rule adopted today
is
identical to
the language proposed
at Second Notice on August 18,
1988.
ORDER
The Board hereby adopts,
as final,
the following amendments
to be filed with the Secretary of State.
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
Section
216.100
Scope and Organization
216.101
Measurement Method~s
216.102
Abbreviations and Conversion Factors
216.103
Definitions
216.104
Incorporations by Reference
SUBPART B:
FUEL COMBUSTION EMISSION SOURCES
Section
216.121
Fuel Combustion Emission Sources
216.122
Exception, Midwest Grain Products
SUBPART
C:
INCINERATORS
Section
93—699
—8—
216.141
Incinerators
216.142
Exceptions
SUBPART N:
PETROLEUM REFINING AND
CHEMICAL MANUFACTURE
Section
216.361
Petroleum and Petrochemical Processes
216.362
Polybasic Organic Acid Partial Oxidation
Manufacturing
Processes
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, R7l—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 Pekiri,
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.
(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
Opinion
and
Order
was
adopted
on
the
______________
day
of
~
1988
by
a
vote
of
-7—O
93 -7
nfl
—9—
~
/~
Dorothy M.~unn, Clerk
Illinois Pollution Control Board
93—701