CLERK’S
OFR(~T’
OCT
10 20~
IN THE MATTER
OF:
THE PROPOSAL OF CENTRAL
ILLINIOS LIGHT COMPANY
FOR A SITE SPECIFIC RULEMAKING
AMENDING
35
ILL. ADM. CODE
§
214.561.
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State ofIllinois Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
Jon S. Faletto
Daina M. Jagiella
Howard & Howard Attorneys, P.C.
211
Fulton Street, Suite
600
Peoria, Illinois 61602-1350
STATE OF ILLINOIS
)
Pollution Control Board
)
)
R2-021
)
(Site Specific Rulemaking
—
Air)
)
)
John Knittle, Hearing Officer
Illinois Pollution Control Board
1717 Philo Road,
Suite 25
Urbana,
Illinois 61802
PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution
Control Board the TESTIMONY OF ROBERT J. KALEEL of the Illinois Environmental
Protection Agency, a copy ofwhich is herewith served upon you.
Date:
October 8, 2002
1021
North Grand Avenue East
P.O. Box
19276
Spring field, IL 62794-9276
217/782-5544
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
By:
Rachel L. Doctors
Assistant Counsel
Division ofLegal Counsel
THIS FILING IS SUBMITTED ON
RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
NOTICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
CENTRAL ILLINOIS LIGHT COMPANY
)
R 02-021
FOR A SITE SPECIFIC RULEMAKING
AI~ENDING35
IL
ADM
CODE S214.561
)
(Site Specific Rulemaking)
Testimony of Robert
J.
Kaleel
Manager, Air Quality Modeling
Air Quality Planning Section
Illinois Environmental Protection Agency
October
11,
2002
My name is Robert Kaleel.
I am the Manager of the Air
Quality Modeling Unit in the Division of Air Pollution Control,
Bureau of Air at the Illinois Environmental Protection Agency
(“Agency”).
I have been employed by the Agency for twenty-one
years in the areas of air quality modeling,
planning, and
regulatory development.
I have also worked for a private
consulting company in the fields of air pollution modeling and
permitting.
I have a Bachelor of Science degree in meteorology
from Northern Illinois University.
In my current position at the Agency,
I am responsible for
overseeing the development of dispersion modeling analyses to
support various regulatory proposals,
including the underlying
sulfur dioxide regulations affected by this request for site
specific rulemaking.
For the matter before us today,
I have
supervised the Agency’s review of the technical information
provided by the Central Illinois Light Company
(CILCO)
in support
of this request, including air quality modeling.
The purpose of my testimony today is to explain the basis
for the Agency’s recommendation in support of this request for
site specific rulemaking.
I have provided similar testimony to
the Board on March
9,
1999 explaining the Agency’s position on
CILCO’s related petition for a variance in PCB 99-80.
CILCO is requesting a site specific rule to amend Section
214.561 of 35
IL Adm. Code,
of the Board’s Air Pollution Control
requirements as they apply to the operation of Boiler No.
2 at
CILCO’s Edwards Station.
CILCO’s Edwards Station is located near
Pekin.
This facility is equipped with three coal-fired
electrical generating units.
Sulfur dioxide
(SO2)
emissions from
Units
1 and 3 are currently limited to 6.6 pounds per million
British thermal units
(lb/MMbtu)
of heat input, while the SO2
emissions from Unit
2 are limited to 1.8 lb/MMbtu.
These limits
are contained in Sections 214.141 and 214.561, respectively. Unit
2 is restricted to burning low sulfur coal, while Units
1 and 3
are allowed to burn coal with higher sulfur content.
The Edwards
Plant is also subject to a plant-wide SO2 emissions limit of
34,613 pound per hour
(lb/hr).
CILCO will continue to comply
with this current plant-wide
SO2
emissions limit,
so the proposed
rule change will not result in an increase in plant-wide
emissions.
In PCB 99-80, CILCO’s request for a variance,
the Agency
requested that CILCO prepare an analysis to evaluate the proposed
emission changes relative to the National Ambient Air Quality
Standards
(NAAQS)
for SO2.
The NAAQS for 502 were established to protect the health and
welfare of all citizens.
There are actually three such standards
for SO2, which are designed to provide protection from both long
and short-term exposures. The short-term limits are 365 and 1,300
micrograms per cubic meter for 24- and 3-hour averaging times,
respectively.
The short-term limits can be exceeded once per
year at any given location without violating the standard,
The
long-term limit, which is expressed as an annual average,
is
80
micrograms per cubic meter.
The annual limit can never be
exceeded.
In support of its variance petition,
CILCO submitted an air
quality analysis that demonstrated that air quality in the Peoria
region will not be adversely affected by the proposed emissions
changes.
CILCO employed QST Environmental,
Inc.
of Gainesville,
~‘loridato perform the air quality analysis.
The air quality
analysis,
entitled Air Quality Demonstration in Support of a
Variance to Burn Higher Sulfur Coal in Unit
2 of the Edwards
station was submitted in December 1998 as part of the petition
for variance.
The Agency reviewed the modeling analysis provided by CILCO
and determined that the study adequately demonstrated that the
SO2 emissions changes requested by CILCO will not cause or
contribute to violations of the National and State air quality
standards. QST Environmental used a State and Federally approved
regulatory model to address the impacts from the facility. All
modeling inputs utilized in the study were consistent with Agency
and USEPA guidance, including the use of five continuous years of
local meteorological data recorded by the National Weather
Service at the Peoria Airport.
The study incorporated emissions
from other industrial facilities
in the area, based on data
provided by the Agency. The modeling also addressed the impacts
from upwind sources, using background concentrations which were
based on ambient monitoring data collected by the Agency at its
monitoring station in Pekin.
The modeling analysis shows that under certain
meteorological conditions,
the proposed emission changes at the
Edwards Station can potentially cause short-term impacts that the
Agency considers to be significant.
For example,
the change in
emisthions at Edwards is shown by the study to potentially cause
a
net increase of ground level,
3-hour average
SO2 concentrations
as high as
93 micrograms per cubic meter.
However, this impact,
when added to the impacts of all other sources in the area,
results in a total concentration of 376 micrograms per cubic
meter, which is well below the 3-hour standard of 1,300
micrograms per cubic meter.
Thus,
the air quality standard is
still protected even during potential, worst case conditions.
It
is the Agency’s conclusion that the air quality
demonstration provided by CILCO in support of the original
variance request
is still adequate to demonstrate that the air
quality standards for SO2 will not be exceeded as a result of the
proposed emission changes at the Edwards Station.
It is important to consider that the Acid Rain Program has
resulted in substantial reductions of SO2 emissions from the
Edwards Station from the time that the initial variance petition
was submitted. According to USEPA’s Acid Rain database,
the
Edwards Station emitted approximately 72,000 tons per year of S02
in 1999,
which is the year that the Board granted CILCO’s
variance.
By 2001,
the Edwards Station emitted about 50,100 tons
per year of S02,
a reduction of about 20,000 tons per year in
response to the requirements of Phase II of the Title IV
-
Acid
Rain Program.
In light
of modeling demonstrating minimal air quality
impact, the fact that there have been no violations of the SO2
NAAQS in the Peoria area in more than 20 years,
and that the
requested rule change sought by CILCO does not result in an
overall increase of S02 emissions above those currently adopted
in Illinois’
SIP, the Agency therefore agrees that the proposed
site specific rule change is appropriate.
This concludes my testimony.
STATE OF ILLINOIS
)
COUNTY
OFSANGAMON
)SS.
)
PROOF
OF SERVICE
I, the undersigned, on oath state that I have
served the
attached Testimony ofRobert J.
Kaleel upon the person to whom
it is
directed, by placing in
an envelope addressed to:
TO:
Dorothy
Gunn,
Clerk
Illinois Pollution Control Board
State of Illinois Center
100
W. Randolph Street, Suite
11-500
Chicago, Illinois 60601
Jon S. Faletto
DainaM. Jagiella
Howard
& Howard
Attorneys, P.C.
211
Fulton Street,
Suite 600
Peoria, Illinois 61602-1350
John
Knittle,
Hearing Officer
Illinois Pollution Control Board
1717 Philo Road, Suite 25
Urbana, Illinois
61802
andmailing
it by First Class Mail from Springfield, Illinois on October 8, 2002,
with sufficient
postage affixed.
SUBSCRIBED AND SWORN TO BEFORE ME
this
8th
day ofOctober, 2002
/~/A)(~J~
iL~c~
OFFICIAL
SEAL
CYNTHIA L. WOLFE
NOTARY
PUBLIC,
STATE
OF
ILLINOIS
~
MY
COMMISSION
EXPIRES
3.30-2003 1’
~
,.—1
Notary Public
0