ILLINOIS

POLLUTION CONTROL BOARD

January 27,

1983

IN THE MATTER OF:

)

CITY OF ROCHELLE:

)

 R78-15

SITE SPECIFIC LIMITATION FOR

)

TOTAL SUSPENDED PARTICULATE MATTER

)

Proposed Rule.

 Second Notice.

OPINION AND ORDER OF THE BOARD

 (by I.

 G. Goodman):

On November

13,

 1978 the City of Rochelle (Rochelle)

 filed

a petition to amend Rule 203(g)(l) of Chapter 2:

 Air Pollution

to include a particulate emission limitation for the emissions

exhausted from the stack at its Municipal Steam Power Plant,

located on South Main Street.

 Specifically, Rochelle requested

a limitation of 0.6 pounds per million British thermal units

(lbs/mBtu) of actual heat input.

When Rochelle proposed amending Rule 203(g)(l), adoption

of the same had been vacated along with Rule 204(c)(l)

 (Common-

wealth Edison v. Pollution Control Board,

 62 Ill.2d

 494,

343

N.E.2d 549 and Ashland Chemical v. Pollution Control Board,

64 Ill. App.3d 169,

 381 N.E,2d 56).

 Therefore, once docketed

this proposal was consolidated for hearing with R78—l6,

 a Board

inquiry reviewing the rules on total suspended particulates

 (TSP),

On August 21,

 1980, R78—l6 was dismissed.

 Other than this pro-

 posal by Rochelle,

 no steps were taken to adopt particulate

limitations for fuel combustion sources until R82—l was insti-

tuted by the Board.

 Since further action in R82—l awaits receipt

of an economic impact study,

 Rochelle’s source is not currently

subject to a specific TSP emission limitation.

Consolidated with R77—l5, R78—l4,

 R78—l6 and R78—l7, hear-

ings were held for R78—15 on January 24,

 1979 in Springfield,

January 30, 1979 in Chicago, February

7,

 1979 in Peoria and

April

 17, 1979 in Chicago.

 After receiving the economic impact

study from the Department of Energy and Natural Resources

 (then

the Institute of Natural

 Resources) entitled “Economic Impact of

Sulfur Dioxide and Particulate Matter Regulations

 in Illinois,

R77—15,” Doc. No.

 79—22, hearings were held on January 29,

1980

in Chicago, January

30,

 1980 in Peoria and February 13,

 1980 in

Chicago.

 The record closed on March

17,

 1980.

Rochelle proposed this site—specific regulation primarily

due to the Illinois Environmental Protection Agency’s

 (Agency)

permitting policy in light of the Illinois Supreme Court decision

vacating Rule 203(g)(1).

 This policy, as set out in “Guidelines

for the Performance of Air Quality Impact Analyses to be Used

in

51-81

2

Support of Permit Applications,” was to grant permits

if

sources

demonstrated

either

compliance with the terms of vacated

Rule

203(g)(1) or compliance with ambient air quality standards

(Petition,

pg.

2),

 This policy led Rochelle to conduct

stack

tests to determine compliance with vacated Rule 203(g)(1)(B)

and modeling studies to determine its contribution

to ambient

air concentration levels

of

particulate matter,

 The stack test

report, dated October,

 1977,

 showed Rochell&s contribution to

he an average emission rate of 0.418 lbs/mBtu or less,

 Since

the maximum rate allowable based on Rule 203(g)(1)(13)

 is 0,18

lbs/mBtu,

 Rochelle

 is petitioning for a site—specific

rate of

0.60 lbs/mBtu.

The city’s plant produces electric power

 for its 12,000

consumers and produces process steam for a Swift and Company

facility.

 Its two steam boilers vent to a common stack and have

maximum rated capacities of 100,000

 lbs/hour at 100 million Btu

per hour of heat input

(R.

 376).

 Particulate matter emissions

are presently controlled through the use of mechanical collectors

(western precipitator multiclones) having 90

 efficiency, taken

 together, when the boilers are operating at full loads

(R.

 377,

393, 398,

 405).

Initially,

 Rochelle conducted six stack

 tests to determine

compliance with the 0.18

 lbs/mBtu limitation.

 All resulted

in

violations of that limit

 (Exhibit 5).

 The stack tests were then

averaged to provide a basis for modeling.

 Unfortunately, the

stack tests had not been conducted with the boilers operating

at full capacity, contrary to standard testing procedures.

Therefore the actual results were ratioed “up”

 in an effort to

characterize full

 load results.

 This was apparently done on the

assumption that a given increase

 in heat input produces another

given increase

 in steam and a corresponding increase in emission

rates.

 The record reflects contrary opinions as to the success

of such extrapolation

(R,

 400—405,

 415—416).

Using the Point Source Diffusion Model

 (PSDM) Rochelle

further determined the maximum concentrations of TSP contributed

to the ambient air solely by its source.

 Worst case emission

rates were utilized to predict conservative ground level TSP

concentratations.

 Sequential calculations were made for 256

receptors located at various points ranging from 0.5 to 25.0

kilometers from the stack

(R.

 387—388),

 This modeling indicated

that maximum TSP for the 24—ho~rstandard contributed by the

 Rochelle facility is l~.6ug/m

 less than 11

 of the secondary

standard of 150.0 ug/m

 This impact

 was predicted to occur

within 1.5 kilometers southwest of the plant.

 The maximum ca~—

culated annual contribution of the Rochelle plant is 2.3 ug/m3

which is about 4

 of the secondary annual

 standard of

 60 ug/m

This impact was predicted to occur within 1.5 kilometers north

of the plant

(R.

 388-389),

51-82

3

To further qualify the modeling results, Rochelle conducted

a monitoring program, intended primarily to determine background

values in the plant impact area.

 Monitoring at the modeled

northern impact point resulted in no violations of the annual

ambient air quality standards for TSP,

 and only one violation

of the 24 hour standard.

 The latter was attributed to nearby

road construction.

Rochelle conceded that control technology, either electro-

static precipitors

 (ESP) or baghouses,

 were available and that

installation would facilitate compliance with the 0.18 lbs/mBtu

limitation.

 Installation of baghouses was not considered by

Rochelle as

 a means to comply with the limit

(R.

 394—5); instal-

lation of ESP5 was considered, not as a substitute control mecha-

nism, but instead as a means of further controlling Petitioner’s

 existing cyclones

(R.

 421).

 The capital cost to install ESPs was

estimated at $1.4 million in 1977 dollars, or at a minimum average

cost of $100 per customer.

 These figures do not appear to be off—

set by monetary contribution by Swift and Company as the primary

industrial user in the area.

Ogle County is designated attainment for TSP at 40 CFR

81.314.

 The surrounding counties,

 Lee and Boone are likewise

listed.

 However,

 the counties of DeKalb, Winnebago, specifically

Rockford Township, are listed as non—attainment for the secondary

standard.

 Rockford Township and all the townships in DeKalb,

except DeKaib and Mayfield Townships, have been proposed for

redesignation by the Agency in January 1982.

 Since DeKalb Town-

ship is twenty miles directly east of the Rochelle plant, its

non—attainment designation was questioned during this proceeding.

Petitioner stated that it is “obvious that

 if no violations are

predicted at 10 kilometers...there would be no excursion for a

receptor 20 kilometers away (Exhibit 35,

 Part 1, pg. 2).

Additionally, the Illinois Environmental Protection Agency

(Agency) stated that it did not consider Rochelle’s source to

significantly contribute to ambient air concentrations, and that

the rural area of Ogle County is not bothered by an air quality

problem

(R.

 424).

 In post hearing public comments the Agency

stated that the relaxed limitation “would not cause an air

 quality problem.”

Over the course of the years two monitoring stations have

been operated in DeKaib Township.

 The monitoring results

 (Annual

Air Quality Reports 1977—1981) are set out in the chart below.

Annual Geometric

 Annual Statistics

No. of Samples

 Highest Samples

 Mean

 Violations

1503

2603

75

60

ug/m

 ug/m

 ug/m

 uglm

Total

 (Primary)

 (Secondary)

1

2

3

4

 (Primary)

 (Secondary)

*j977

*1979

34

1

0

168

iii

iii

110

*1979

26

0

0

133

98

96

92

**1979

14

0

0

95

93

78

66

**1980

S.

4th

St.

~!:1~t ~

 51-83

4

Unfortunately, the statistical data for three of the five

years is insufficient to establish a geometric mean for eight

consecutive quarters, which is necessary for DeKalb Township to

be proposed for redesignation.

 Nevertheless, the monitoring

results indicate that this area has probably not experienced a

TSP air quality problem since

 1977.

 Since the Rochelle facility

has been operating at or near the proposed emission limit and no

violations of the standards have been monitored,

 Petitioner’s

statement that its source does not impact DeKalb appears valid,

The Rochelle stack

 is the only major fuel combustion emission

source

 in Ogle County emitting particulates

(R.

 396).

 Keeping in

mind that the modeling performed was conservative and premised on

a limit of 0.60 lbs/mBtu, the combined data from the stack teats,

the PSDM and site—specific monitoring indicates that should the

limitation requested be granted, violations of the ambient air

quality standard will not result.

However,

 in granting Rochelle emission limit more relaxed

than that presumably required by other such sources,

 the Peti-

tioner will consume

 a portion of the Prevention of Significant

Determinations

 (PSI)) increments.

 Therefore, Rochelle was

directed by the hearing officer to submit its estimation of the

amount of PSD increments would be used up by this regulation

(R.

 411).

 The estimation was to be based upon the emission rate

used as input in the PSDM rather than the facility’s actual

emission rate.

 This information

 is contained in Exhibit

35.

Nevertheless,

 since no baseline has been established for any

areas affected by the Rochelle source,

 PSD increment consumption

is not sufficient reason to deny Rochelle a relaxed site—specific

limitation.

This rule was published for First Notice on November 19,

1982 in 6 Illinois Register 14456

—

 14458.

 On January

6,

1983

the Agency filed comments raising three issues,

 which Roche.ie

responded to on January 10,

 1983.

 No other public comments were

filed.

 At the outset the Agency questions whether the record

which the Board based its decision on was sufficiently current,

Primarily the Agency is concerned that the supporting documenta-

tion offered by Rochelle at hearing may now be insufficient to

support a revision of the State Implementation Plan (SIP) by the

United States Environmental Protection Agency (USEPA).

 Acknow1~

edging that a SIP revision is necessary after a rule change,

 this

proceeding, however, need only justify a site-specific rulemaking

by the Board.

 The analyses and documentation necessary for a SIP

revision,

 in this instance, can be provided to the Agency and the

USEPA during the SIP revision process.

 In its response, Rochelte

agreed that any additional information needed pertaining to the

SIP petition will be provided.

Lastly, the Agency retracts its support for the proposed

limitation of 0.60 lbs/mfltu because

 it is greater than the plant’s

51-84

5

actual emissions, and again because

it

 is not sufficiently docu~

mented for the purpose of a SIP revision.

 As stated above, any

deficiencies

 in the SIP demonstration can be cured at that time.

In support of the more restrictive limit proposed

 in its comments,

the Agency relies on undocumented permit information and further

analysis of the stack test results.

 The Board~sdecision to

grant 0.60 ibs/mBtu was likewise premised on the stack tests, hut

it was also premised on the modeling performed by Rochelle.

The

modeling demonstrated that emissions up to 0.60 lbs/mBtu would not

jeopardize air quality,

 This documented limitation is retained.

The Board finds the evidence provided by Rochelle’s modeling

and monitoring sufficient, despite the questionable practice of

extrapolating the stack test results to full

 load capacity, to

demonstrate that this proposed regulation will not degrade the

attainment status of Ogle County or other nearby attainment areas.

The economic evidence indicates that although the technology is

available,

 it is costly.

 Swayed by evidence that the air quality,

and therefore the health or welfare of persons

 in the immediate

vicinity,

 is not jeopardized by the emission amount Rochelle seeks,

the limitation of 0.60 lbs/mBtu is granted.

ORDER

The following language is hereby proposed for adoption into

Chapter

2:

 Air Pollution,

 Part II:

 Emission Standards and

Limitations

 for Stationary Sources:

RULE 203:

 Particulate Emission Standards and Limitations

(a)~(f)

 Unchanged.

(g)

 Fuel Combustion Emission Sources

(I)

 Using Solid

 Fuel Exclusively

(A)

 Existing Sources Located

 in the Chicago Major

Metropolitan Area——Reserved

(B)

 Existing Sources Located Outside the Chicago

Major Metropolitan Area——Reserved

(C)

 Exemptions for Existing Controlled Sources

Notwithstanding sub-paragraphs

 (A) and

(B)

of this Rule 203(g)(l),

 any existing fuel

combustion emission source using solid

 fuel

exclusively, and meeting the following con-

ditions, may emit up to, but not exceed,

the

limits set out.

(i)

 As of ~~i1

 14~1972 the emission source

has an emission rate based on original design

or equipment performance test conditions,

whichever is stricter, which is

 less than

0,2

 lbs/tnBtu of actual heat input, and the

emission control of such source is not

51-85

(

allowed

 to degrade more than 0.05 lbs/mBtu

from such original design or acceptance

performance test conditions,

 the rate of

emissions shall not exceed 0.2 lbs/mBtu

~~ljJ~p~t;

or

(ii)

 As of

~a~a

14

 1972 the source

 is in full

compliance with the terms and conditions of~

a variance granted by the Board sufficient

to achieve an emission rate less than 0.2

lbs/mBtu, and construction has commenced on

equipment and modification prescribed under

that program;

 and emission control of

 such

sources is not allowed

degrade

 more than

0.05 lbs/mBtu from original design or equip~

ment performance test conditions whichever

is stricter,

the

rate

emission

 shall not

exceed 0,2 lbs/mBtu

 of actual heat inp~utor

(iii)

 As of (the effective date

this

 Rule)

the rate of emissions from Boilers

 #1 and

#2

located at the Rochelle M~~ialSteam Power

Plant

 South Main

Street

Cit

 Rochelle

oun y,

 inois

s a

 no?~~dd~ed

0.6lbs/mBtu of actual heat

IT IS

ORDERED.

Board Chairman Dumelle and Board

Member

Werner

 concurred.

I, Christan L.

 Moffett, Clerk of the Illinois Pollution

Control

Board,

 hereby c~rtifythat

the

above

Opinion

and

Order

was

adopted

the

~7’

day

~~&~-_

1983

vote

_~~

~

~___~

Christan

L.

 Moffê~,t’t’~Clerk

Illinois Pollutio’n’~ControlBoard

51-86