ILLINOIS

POLLUTION

CONTROL

BOARD

June

14,

1984

MIDWEST SOLVENTS COMPANY OF ILLINOIS,

)

Petitioner,

V.

)

PCB 84~19

ILLINOIS ENVIRONMENTAL PROTECTION

)

~CENCY,

Respondent~.

OPINION

AND

ORDER OF THE

BOARD

(by W~J~

Nega):

This matter comes before

the Board

on the petition

for

variance

of

Midwest Solvents

Company of

Illinois

(MSC)

filed on

February

15,

1984~*

The

Petitioner

has requested a

three~year

variance from the 200

parts per million

(ppm) carbon

monoxide

(CO)

emission

limit

on

fuel

combustion

emission sources

delineated

in Rule 206(a)

of Chapter

2:

Air Pollution

Control

Regulations

(now 35 ilL Adm~Code 216~121)to allow

a temporary

emission

limitation of 700 ppm CO on emissions from

the

new

fluidized bed

combustion

(FBC) boiler that

is being installed

in

their Pekin

plant~

On April

2,

1984,

the

Illinois

Environmental Protection

Agency (Agency) filed its Recommendation

that variance be

granted

subject to certain conditions~

A

hearing was held on May

7,

1984~**

The Petitioner owns and operates an ethyl

alcohol

production

plant in the City of

Pekin,

Tazewell County,

Illinois which

occupies an irregularly~shapedparcel

of land on

the

south edge

of the city covering about 50

acres near the intersection of

South Front Street and Distillery

Road0

Pekin has a population

of 32,315 and the nearest town of

significantly greater size is

*On February 15,

1984,

MSC filed

an unnumbered document

entitled ~‘Petition for Variance~

Upon

filing, this document

was

docketed by the Board

as PCB 84~i9~However,

upon

subsequent

review, the Board noted that the filing appeared

to be an

amended

variance petition repsonding to the Board~s

January

26,

1984 more

information Order in the case docketed as PCB

84~9,

Midwest Solvents

C2!2~vofI1linoisv0IEPA

filed January 23,

1984~

To avoid

perpetuation of administrative confusion, the

Board

entered an

Order on February 22,

1984 dismissing docket PCB

84~9~

58~337

---

Peor~, i~I~n~:s

which

is located

approximately eight miles north

of

Pekir.

The’ Illinois River borders

MSC~sfacility on the

rthwe’st

side’

the nearest

residence is

.2 miles east of the

plant1

~nd ~

facility is served

by the Conrail Railroad.

(Pet0

:~3;1~c I~3;deticioner~sExhibit

1,

page V~1),

?t~C.

s f~~’ci1itjpiesently produces

ethyl alcohol for beverage

and

ind’i-strial purposes, anhydrous

fuel alcohol, distillers

feed,

and wheat. gluten/starch0

The

Petitioner~splant operates

24

hours per day,

‘

days per week and

employs about 75 people0

(Pete

~L

MSC~’sf~cilityhas three 80 000

pounds per hour

(lbs/hr)

natural

gas~fire’dho~1erswith

a total generating capacity

of

240

flIt

lbe’,l~. of ~nr.

The

Petitioner~splant is presently

being expandei from an ethyl

alcohol production capacity of

20,00J qallr”r~~r

day to

a capacity of 30,000 gallons per day0

Pet

~.

I

e c~iipTI ±~

ir

the process of

installing a fluidized bed

coiihust4on bo:er which

viill have

a total generating capacity of

120

0(0 lbs/hr of steam0

To generate approximately 3,000 kw of

electricity for use by

the process facility, the company

plans to

instni

a h.~gFpressure’ topping turbine

generator.

(Pet,

2).

~bfln~’ $55 ~

er w~i

use

limestone in the fluidized bed

to

control ~,ulfuxdioxide

(SO

)

emissions and will utilize

8,035

lb~

of ligh sulfur IlJi~ois

coal.

rem MSC purchased the plant from

American Distilling Company

in

In

of

9

0,

the previous coal

handling and storage equipment

ir ~ct

S

plans

to restore

and then use the

crushing

eq

iprert

eievtor, storage bins,

and

coal dump which are

already

in piace at the si~e

(Pet,

2—3)~ The new FBC boiler

~will

fire

high

si

fur

Illinois

coal

which

is locally available within

40

,r

les

ri

tIe

plant

si~e~

(Pet,

3),

ue

cc~pany ads

indicated

that

that this coal

~will

be

‘~r~

from

the

Midland

or

the

Peabody

mines to the plant

site~,

~~ct

~

The

three

natural

gas—fired boilers ~will be retained

O~Mac~n 16,

1984

the

Board

received a letter of

inquiry

r

~

t1r~0 WrAlia’n

Skarnikat

of

Pekin,

Illinois

in reference to

~

uar~’nce

reg~e~t0

The

Assistant

Clerk of the Board

notified

Mr~’

~karnikat

by

tel~phone

on

May

3,

1984 that the hearing was

ncieduled

for

May

7,

1984

and

gave

her

information as to the

time

and

~

‘e’

of

the

public

hearing0

Mrs.

Skarnikat apparently

did

rot

a’~f

end

this

hearing0

At

the

hearing,

it was indicated

that

init’~’

0

~

rhe’

parties

and

the

media

were present.

(R,2),

~

tie

end

of

the

hearing,

an unidentified member of

the

walked

in

and

was

asked

by

counsel

for the Agency

if

they

iad

‘:

quest’~ens to

ask0

This

unidentified

member of the

public

ee’p

u~cd

c’

and

tae

hearing

was subsequently terminated,

(H0

---

for standby and

emergency service only~.

(Pet,

2).

The company

has

decided

to

switch from natural

gas to Illinois

coal because

of

rising natural gas prices and because

it already

has

existing

coal handling

equipment

in place.

(Pet.

2—3).

The

new FBC

boiler:

(1)

is designed

to produce 120,000

pounds

per hour of

stean~

at 685 psig

and

750 degrees Fahrenheit;

(2)

has high combus-

tion efficiency;

and

(3) meets all current

environmental require-

ments pertaining to sulfur

dioxide and nitrogen oxide emissions.

(Rec,

2).

The Petitioner has indicated

that particulate levels

will

be controlled by a fabric filter

baghouse to 0.03 lb/MMBtu.

Similarly,

sulfur dioxide emission levels

will be controlled by a

limestone bed in the boiler

to 1.2 lb/MMBtu, while nitrogen oxide

levels will be controlled to

.6

lb/MtlBtu or less.

(Rec.

2).

However, given the present state

of technology in this

area,

the company’s engineering

consultants have ascertained that

it

is

not technically possible

to efficiently operate this new FBC

boiler and meet the

carbon monoxide emission limit set by 35

Ill.

Adm, Code 216.121 while at

the same time maintaining low

levels

of sulfur dioxide emissions,

nitrogen oxide emissions and

high

boiler efficiency.

(R.

7—16;

Rec.

2—3).

Thus, it is

anticipated

that the carbon monoxide emissions from

the new

FBC

boiler will

probably range between 620

ppm

to 630

ppm Co once the

boiler

comes into operation.

The Petitioner has carefully

considered various

methods to

reduce the level of carbon monoxide emissions,

The company

has

indicated that

the

freeboard area size

could bq increased

in

order to reduce carbon

monoxide emissions, since larger

freeboard

allows greater retention time of flue gas

(enabling carbon

monoxide

to be converted to carbon

dioxide).

However, since $SC is

using

an existing building to house the new FBC boiler

and

the FBC

boiler is the largest physical size which can be accomodated, a

changeover would. require a

much larger boiler and a

new

building

to

house the boiler, thereby adding at least

$1,000,000

extra to

the cost of the project in order to

achieve a moderate

reduction

in CO levels.

tRee.

3).

Another alternative that

the company

has

considered is

increasing the excess air rate

from

20

to 40.

klthough

this

method would result in a greater

reduction

in

carbon monoxide

emissions,

it would also

reduce boiler

efficiency by about

1.5.

According to engineering

estimates by the firm’s environmental

consultants, it would

require

about

2.5 Mt4Btu/br of fuel to save

less than

.5 MMBtu/hr.

of potential energy from the combustion CO.

tRee.

3-4).

Additionally, extra

coal and limestone would be

utilized,

additional energy would

be required to

power

both

the

forced draft fans and

induced fans, and larger

quantities

of

residue would be produced which

would require disposal.

(Rec.

4).

The Petitioner~sfacility is

located in an area

that

has

been classified as an

attainment area for carbon monoxide.

Accordingly, MSC~splan is subject to review

under the Prevention

of Significant Deterioration

(PSD) program.

The air qualitj

58-339

---

ar~y5~

~ft4~r

wq~s~j

ucted.

by

the

Petition~

h~salready been

~ecerved.

tb~~gency,

The Agency has issued a PSD

~)

the

c~~a-~y’wn1c~

autilorizes

the

conbtruction of the

srie

~b64~)~(k~:

~

~

that :eli~newFBCb~i~er~wil.~

not

b~ ~

-~

mori~~àe

emissions

since the

hic

J~i~j.1~1

qi~a1it~’4á~aly~is

was

5cf.~

~

~impa~t.s

is

~.

.b~r~veh~tg~a~r~ti~ng

tbe

Ltena~ce

pf

t.he

reUiri~e

Ltd

.(~AQS)

f~

c~D~on

bb

~theP~ti~tione~ha~

assertdd

t’hat

no

~adversb

impabt

on

community

health and no adverse

envirormental.

i~?a~tpnan~imai

~Qr

p~ant~,J~~in

th~art~a

will

o~c1xr±

si!ce

t~

i~o~ccted eriissions

of

its ~C

bofler wi)~lmeet

the

qpireme~imposed

~by. the

~

~

t)~

The

A~

4$

$t~~d~

hy

Abe

compa1i.y~~are

~en~y

h~~~e.~ve4i~ts ~~u~dgrnent

~on

tthet her

‘4.

~e~r~o~rmanqe

chaxacte~ist,tc~”

Qf

the

1re~boil.

l~b~ecq~?r~1.~technoogy

for

a

b

bhli

~

er~th~ie

d~e~m~nat~on

cap

best

be

made

after

HE~

boilet

has

been

operated and CO ernis~ons,

have

been

ewluated

based

on

actual

performance.~

(Rec,

5),

The

Agency

~cints

out

ttht~ “the.

~C

boiler

technology ,was

unknQwn

uheh~t~-e~

~r

Tmop~ctdç~tandards;in

19~72,~no

protren1

pra~tig~~l

ç~lcroi~t~oltecbnology

exists

for

c~rculating

f~uidr~rd bed

d~l~i~t.JonJDoI~lers

to

a~h~evean emission rate of

200 p~r

A

four

~qr~

diDx~idu

~

~eed

ll~

-

~

)

aew~FR~

J~oi~rwil~

have

~

.áulfur

Le.

~

l~st~4

in

the.

~s~ack~

M8C

~

boiler

$taçlc

to

a

~

..twa

air.

gua~ity

reporting

..±±..~nois

(one

monitors

suspended

particu~lat~s

~

oon~to~ssulfir

dioxide),

The

nearest

carbon

monoxide

spot

ug

~

~

Pgpr~a~,

Illinois

and.

&s

fourteen,

m~Jes

~(~ea.

~

~Qwever,mOdellng

;~oc~a?~es,

Imc.,

the

P~titioner

a

~r,ated.

that

emi

iqn~ of.

L~Tpf.

2-O,Q ppn~

w~-Ungt

;.

ip.Itrinoi5

ap~

the~

~tit~ipn

and-the

engineer~s

;T.~e~gei~c~y h~.no

a

~omplai,4i

,-

4gair~.

-t~laPetiti9ner,

~nd

it

wiac~eptable

~

that

night

poe$lbiy

oricu~o~e

~

operat,iori.

would

ha

irnmeda~atelydetected

aT~d‘co~rb’~cte”I’,. ~ec~

6

0

-

-

-

,0_~

$

~‘

•

The

~

recommended

th~

under the facts

and

circum—

-

-~

.~&~q0

-

-~

~,

,,

,•.

~L

a

0)

~r•

a-~

~.

,0Q~l:~

lI)~tLE~i

~co;

Qual

---

stances of this case,

a variance is appropriate given the current

limitations of present technology and the

likelihood of

no adverse

effect on air quality0

Since the “bubbling-bed” FEC boiler technology was unknown

when the Board adopted the carbon

monoxide standards in

1972,

it

is conceivable that

a variance from the

200 ppm CO standard

might

not be necessary in the instant case,

However, to protect the

Petitioner from a possible enforcement

action based on a violation

of 35 Ill, Adm, Code 216,121, the Board

deems it appropriate

to

grant the requested variance,

Accordingly, the Board finds that denial

of

variance

would

impose

an

arbitrary or unreasonable hardship

upon the

Petitioner

and will grant the requested relief,

subject

to the

conditions

delineated in the Order,

This Opinion constitutes the Board’s

findings of

fact and

conclusions of law in this matter,

ORDER

The Petitioner, Midwest Solvents

Company of Illinois,

is

hereby granted a variance from 35

Ill, Adm.

Code 216.121

to

all-ow

a temporary emission limitation of

700 parts per million

of

carbon monoxide on emissions from the

new fluidized bed

combustion

boiler that is being installed in its Pekin, Illinois plant,

subject to the following conditions:

1.

This variance shall expire on June

14,

1987.

2,

The Petitioner shall develop and implement a program

to study and evaluate any technical advances

in the

control

of

carbon monoxide in fluidized bed combustion boilers,

30

The Petitioner shall develop a

program to

evaluate the

operating characteristics of its FBC boiler.

This program shall

include the periodic testing of the FBC boiler for carbon monxide

emissions so that the operation of the boiler can be optimized to

minimize the emissions of carbon monoxide while maintaining the

design efficiency.

4.

The

Petitioner

shall

submit to the Agency every six

months a written report describing the progress of the aforemen~’

tioned programs delineated in items

#2 and

#3,

5.

Within 45 days of the date of this

Order, the

Petitioner

shall execute and fox~ardto the Illinois

Environmental

Protection

Agency, Division of Air Pollution Control,

2200 Churchill

Road,

Springfield,

Illinois

62706,

a Certificate of

Acceptance

and

Agreement to be bound to all the terms and

conditions of

this

58-341

---

—6--

variance.

This

45~-day

period

shall

be

held

in

abeyance

for

any

period

this matter

is

being

appealed.

The

form

of

the

certificate

will

be

as

follows:

CERTIFICATE

I,

(We),

________________,

having

read

the

Order

of

the

Iil:Lnois Pollution Contrcl Board

in

PCB 84—19 dated June

14,

1984,

understand and accept the said Order, realizing that such

accept-

ance renders all terms

and

conditions thereto binding and enforce-

~fdwest Solvents Company of Illinois

By:

Authorized

Title

ate

IT IS

SO ORDERED~-

Chairman Dumelle

concurred.

I,

Dorothy M.

Gunri,

Clerk of the Illinois Pollution

C..ntroL Board, hereby

certify

that

the

above

Opinion

and

Order

wuadopte

on the

/~day ~

1984 by

a

vote

0oc~~j~4cp~

~

~orothy

M.

inn, Clerk

illinois

Pollution

Control

Board