ILLINOIS

POLLUTION

CONTROL

BOARD

April

19,

1984

CENTRAL ILLINOIS

LIGHT COMPANY

(Edwards Station),

)

Petitioner,

v.

)

PCB

83—100

ILLINOIS ENVIRONMENTAL

PROTECTION

)

AGENCY,

Respondent,

MR. SHELDON A.

ZABEL OF SCHIFF,

HARDIN

PETITIONER;

MS.

BOBELLA GLATZ,

ATTORNEY

AT LAW, APPEARED FOR

RESPONDENT;

OPINION AND ORDER

OF THE BOARD

(by B. Forcade):

This

matter comes

to the Board upon a Petition

filed July 28,

1983,

by Central

Illinois

Light

Company

(“CILCO”)

concerning the

E,D.

Edwards

(“Edwards”)

electric

generating

station,

That

petition seeks,

pursuant to

35 IlL

Adm,

Code

106.302(a), to have

the

sulfur

dioxide

(“SO2”)

emission

limitations

applicable to

Edwards

relaxed~

Hearing

was held October 19,

1983 at the Peoria

County Courthouses

On October 25,

1983 the

Environmental

Protec-

tion Agency

(“Agency”)

filed

its recommendation

opposing relax-

ation of Edwards

SO

limitation.

Post hearing

briefs

were filed

by CILCO

on Decembe~

27,

1983 and by the Agency

on January 27,

1984.

Six

public comments were received by the

Board.

On

March

19,

1984,

the Agency filed a motion for

leave

to

file

a

reply

brief.

On March 27,

1984, CILCO filed a

response

in

opposition.

The

Agency~smotion is granted,

the

brief is

accepted.

CILCO

seeks relief from the SO2 emission

limitations

of Old

Board

Rule

204(g) of Chapter

2

(Air Pollution) which,

since

codification,

is now

35

IlL Adm~Code 214.20L

The regulations

of

concern in

this proceeding

are as follows:

35 Ill. ~m,

Code

Section

Foimer

Rule

No.

Substance

106.301 et

seq.

Procedural Rules

Procedures

for

cbtaining

Rule

621

relaxed

SO2

~nission

limitations

214.141

Chapter

2

1.8

lbs. SO2/~4Btu ~nission

Rule

204(c)

limitation

57-417

---

2

214.201

th~tec2

StardardW ftr thta1niz~relaced

Rile 20~(g.

emastoti limitaticiw

243.122

thapter 2

&tsent SO) stmderds

Rule 30J

-

The ~actlity

The Edwards Stanoa is lorated on the Illinois River in the

Peoria Major Metropolitan arej~. It consists of three boilers

and

attendant electrtc ‘eneratisg urits.

Units 1,

2

and

3

have,

respectively, name -late ratings of 136 megawatts

(MW)

280 MW and

363

MW.

The

maxim

u~

heat

i~tpntof

each

of

the

units,

in

millions

of

Btus

per

hour (MMBtus/hr.)

is, respectively,

1258

MMBtus/hr.,

2605

MMBtus/hr.

and

3276 MMBtus/hr.

Units 1

and

2 dicharge

through a

common

stack 503 feet in height.

Unit

3

discharges

through a separate stack also 503 feet in height.

All three

units are coal—fired and c’srrently use exclusively non—Illinois

coal in order tc

if

eel.

thc. Board’s

cppltcable

sulfur dioxide

emission limitation of 1.8 p3unds/MMBtu

(Pet.

1

1).

CILCO proposes to replace approximately 850,000 tons of

non—Illinois coal

(c.pprci

Sante y 0 79

sulfur) with Illinois coal

(approximately 3.5

su.tu,

P.t

¶

10).

To accomplish this

CILCO reqt~estsa” SO

ras~.tnss.nitatson of 6.6 pounds/MMBtu for

Units 1

and

3,

leatA1

the

c.tc

t/rg

1 8

pounds/MMBtu

limitation

for Unit 2 unchanged.

CILfl ~lso proposes the

use

of a 30 day

roiling average for 1~ter..tang

oa

s,ariability.

To evaluate

the

en

ar

rtentsi

tmpac.t

of the requested

change,

CILCO

ac.c.cnp

.‘

ed

t)

-

e

‘c.esary

modeling and analytical

work.

The results of that study

Ex.

3)

show that with the

relaxed limitations the Edwards Station SO2 emissions would

contribute from

3

3

to 8.6

to 12 predtcted violations of the

24 hour

National

AnbieLt

Air

Qua

aity Standard

which

the Board

has

adopted

in Section 243 122(a)(2)

(Ix.

3, p.

Discussion

tn Section

9.2

of the

V.

varonmental Protection Act

(‘Act’)

the General Assembly iroviled for tte review,

and

where

necessary

the revision, of SO

emassion linitations, ‘to enhance the use of

Illinois coal, conshtent witt the need to attain

and

maintain’,

ambient

SO,

standards

In

Se*

:o~~

214

•

201 the Board

provided

for

~lternativ*SO, e’nssion

tin

ttions where the applicant demon-

strates that, “the propose6 eussion rate will not,

under

pre-

dictable worst case coqditi~r’~,cause or contribute to a violation

of

any

applicable

primary

,t

‘ascot

dary sulfur dioxide ambient air

quality standard

oi.

of

an,

app

ticable

prevention of significant

deterioration incremnt.’

Since the emission rate requested

by

CILCO

(6.6

pounds

SO

/MMBtu)

i3

below the maximum authorized in

the rule

(6.8), th. ~oarct

tao?

:.cas on the impact of the requested

emissions.

1

418

---

3

CILCO’s modeling of the impact of emissions from Edwards at

the requested emission levels showed no violations of the 3—hour

SO2 ambient standards.

However,

that modeling showed a total

of

17 violations of the 24-hour SO2 ambient standard

(Ex.

3,

p.

ii).

Edwards made no contribution to five of the violations

(R.

27).

Edward~scontribution to the remaining 12 violations ranged from

3.3 to 86

of the predicted concentration

(R.

28).

CILCO asserts

that:

(1) Edwards is a minor contributor to the 12 violations,

WABCO Construction and

Bernie

Company are the primary contributors,

(2) predicted violations will occur even if Edwards remains at

existing emission levels, and

(3) four predicted violations would

occur even if Edwards did not exist

(R.

28).

While the Agency generally concurs that the requested emis-

sions would cause or contribute to violations,

they claim the

modeling inadequately assesses the impact

(R.

160).

Specifically

the model used the lower emission limits set in new

permits for two Caterpillar facilities, but Caterpillar has

appealed those permits

(R.

159),

also,

the model used an incorrect

emission limitation for CILCO’s Wallace Station, one substantially

lower than currently allowable

(R.

102 b)

CILCO agrees this

could produce additional predicted violations

if factored into

the modeling

(R.

198).

Based on these undisputed facts, the

Board finds that the emission limitation requested by CILCO would

cause or contribute to violations of the 24—hour ambient air

quality standard for SO, and would prevent the attainment and

maintenance of the Natiônal Ambient Air Quality Standards for

502.

CILCO argues that the proposed Edwards contribution to the

predicted violations is so small

it should be ignored and that

the failure of the State of Illinois to correct the air

quality

problems

in

the Peoria area is an inadequate justification for

denying CILCO relief to which it would otherwise be entitled

(Post Hearing Brief,

p.

12—13,

19).

Both arguments must be

rejected.

The Board holds that a contribution of from 3.3

to

8.6

to 12 predicted violations is not de

minimus.

Any

other holding could jeopardize correcting a problem caused by

many minor contributors.

Secondly, the violation of ambient air

quality standards in the Peoria area is a complex problem with

major economic overtones.

The fact that a problem is complex and

solutions are expensive

is

very

poor

justification

for

actions

that will exacerbate that problem.

Having decided that CILCO’s

request fails the statutory and

regulatory

standard, the Board

need not reach the

averaging issue.

The Board

is

aware that granting this petition would likely

result in increased Illinois coal usage of about 850,000

tons

annually, creating direct benefits to the State

of 200 to 300 new

jobs and additional

revenues of over $20 million

(Illinois Coal

Assn

Comment,

p.

3).

However, these facts do not

remove the

undisputed predictions of violations of ambient air quality.

The

statute and regulations forbid such violations.

This proceeding

57-419

---

4

has clearly raised problems associated with the Peoria area SO

situation that cannot be resolved in this case.

Both sides made

assertions concerning existing or potential inequities and

problems of future growth resulting from the permit process,

Board regulations, air allocations,

attainment vs. non-attainment,

etc.

The Board, even if it accepted the merits of these assertions,

would not solve the problems by exacerbating existing air violations.

Proposals for solutions

from

industry and the Agency, singly or

together, would be welcomed by the Board.

As the facts

found by the Board are not consistent with the

statutory or regulatory requirements, CILCO’s request for

a

site—specific regulation of SO2 emissions under Sections 106.301

and 214.201 will, be denied.

ORDER

Central Illinois Light Company’s request for site—specific

sulfur dioxide emission limitation of 6.6 pounds of S02/MMBtu for

the E.D. Edwards Station is hereby denied.

IT IS SO ORDERED.

I,

Cl-tristan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby ~ertify that t~,eabove Opinion and Order

w~sadopted on the

~q

day of

___________,

1984 by a vote of

Christan L. Moffet~)~JClerk

Illinois Pollution Control Board

57-420