ILLINOIS POLLUTION CONTROL BOARD
May
19,
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
FIRST NOTICE
PROPOSED OPINION AND ORDER OF THE BOARD
(by J.D.
Dumelle):
This matter comes before the Board upon
a regulatory
proposal
filed
by Midwest Grain Products
of
Illinois
(Midwest)
on
June 12,
1987.
Through
its proposal,
Nlidwest
is seeking relief
for
its Pekin, Illinois
(Tazewell County)
alcohol production
facility from the requirements of
35 111. Adm.
Code 216.121,
which establishes an emission limitation on carbon monoxide
(CO)
of
no greater
than 200 ppm, corrected
to 50 percent excess air.
Midwest
is proposing that
it
be exempt from that standard and
instead be subject
to
an emission standard not
to exceed 700 ppm,
corrected
to 50 percent excess air.
The Illinois Environmental
Protection Agency takes
no position on
this proposal,
neither
supporting
nor opposing Midwestts proposal.
A 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.
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—
pressure topping—turbine generator was also installed,
generating
3000 k~of electricity for Midwest’s
use.
Midwest has provided
the following data concerning
its new boiler:
89—381
—2--
ENGINEERING
DATA
FOR
FLUIDIZED
BED
COMBUSTION
BOILER
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,
M?vlBtu/hr
170
Coal Feed Rate,
lb/hr
16,100
Mass Flue Gas Flow Rate,
lb/hr
215,000
The above referenced co—generation
is accomplished using
high sulfur Illinois coal,
available 40 miles from the plant
site.
Pet.
3.
Midwest asserts
that the use of
locally available
Illinois coal,
transported
from nearby mines, results
in lower
levels of air pollution.
Pet.
3.
Midwest asserts
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. Adm Code
216.121.
Midwest included 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
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
89—382
—3—
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
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 present 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.
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:
89—383
—4—
Percent of
Averaging
Model
Significance
Significance
Percent
Period
Results
Level
Level
NMQS
of Limit
1 HR
102.7ug/m3
2000ug/m3
5.1
40,000ug/m3
0.25
8 HR
49.7ug/rn3
575ug/m3
8.6
lO,000ug/rn3
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 has proffered substantial evidence
regarding
the
technical
infeasibilty 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
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.
89—384
—5--
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.
However, newer, more modern fluidized bed
combustion boilers are capable of operating with
the
limitation.
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.
In tendering
the proposed language
for the Amendment,
Midwest has proposed that
it
be granted
a general 700 ppm
emission standard.
This, however,
is not entirely consistent
with
the evidence presented at hearing.
At
hearing,
evidence was
introduced
that Midwest
is capable of complying with
the 200 ppm
standard 88
of
the
time;
and that exceedances occurred mainly
during load changes.
Additionally, on those occasions when
Midwest exceeded
the
200 ppm standard, emissions experienced were
in excess of
(the
requested standard of)
700 ppm.
This
is
inconsistent with the proposed Amendment which would
limit
Midwest’s emissions
to no greater
than 700 ppm.
In reviewing
the data,
the Board’s Scientific and Technical
Staff has proposed the following Amendment language
——
rather
than the language originally proposed by Midwest:
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 operating
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.
The Board requests comments from Midwest regarding
the
language set forth
above.
CONCLUSION
Notwithstanding
the inherent dangers of excessive carbon
monoxide emissions and the importance
of complying with
environmental regulations,
it would be unreasonable
to order
Midwest to forsake
its earlier
$12.5 million
investment and incur
an additional
$20 million
in costs to eliminate emission
exceedances which occur mainly during
load change and have no
significant environmental impact.
89—385
—6—
ORDER
The Board hereby proposes
to adopt
the following
rule and
instructs
the Clerk
of the Board
to cause
its publication
for
First Notice
in the Illinois Register.
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 Methods
216l02
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
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
89—386
—7—
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;
as amended
in R87—18
at
____
Ill.
Reg.
___________
effective
___________________
SUBPART
B: FUEL COMBUSTION
EMISSION SOURCES
Section 216.122
Exception,
Midwest Grain Products
a.
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 emissions of carbon monoxide
shall
not exceed 700 parts per million, corrected
to
50
percent excess air.
(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
/9ZZ
day of
~
,
1988 by
a
vote
of
7—0
Dorothy
M. G
nfl,
Clerk
Illinois Pollution Control Board
39—387