ILLINOIS POLLUTION t ‘1

)L B

‘Is

August 18

-

8

oIl-

RPORATION, Joliet Pint

)

Petitioner,

v

PC3

3-44

ILLINOIS ENVIRONNE! Tfl PROTSCTION AGENCY

)

Respondent.

OPINTO!

AND OPDIR

F

IRE

BO~

by

The doze Veyer

OrMarch3l

1

3,OlirCo~

atrl

fl

f’d’tPettrn

r Vat

ce

fcm

tic.

cn

.sson

I

tatt

i

tm~ ,ct

by

Rule

204

1

now of

he Board’s Cl’apter 2

Aix Polluti

‘~

lule.

and Regul*tio

.

Tia

r

le

establishes

a

1

at

f

8

pount~

0~

sulfur

d

oxidt.

million

British

Thermal

Unit

heat

input

(1.8

ibs/aBtu)

on

Olin

s

boilers

unless

an

alternative

lint

is

set by the Board in a

site-specific

exemption proceeding.

Our

filed an exemption

prceeding

(PCB

83—46)

pursuant

to

Rule

204

)

r t e saiie date.

he

vat

ance

requested

in

thi° ~ro

c~.in

MS

.0

five

sears

Or

t.ti.

the

site—specif

enis

i.

i.

t

t.

‘1

F oi April 14,

383 to Apr 1 21, 1383, a

..ata.

1 6

objectiors

to

the variance c°zefiled by vano

°

residents near

the Joliet plant.

tin Jut’s 16, P83 a reaztrg r~ted

n tue

Joust YNCA, JoUst, tllinoi’.

Olti s

rief

a’ fi ed

n S ly 20,

1983; the Illinois Environmental Protection Aceicy (?gency) filed

a Recoumtendation on June 8, 1983, and a Brief

a Augubt 3,

1983.

This variance pet tion and the

compan~

on

.xemption

proceeding were instituted by Olin to seek periassior to increa3e

the al oiabl~SO

enissiorc

eor

t

bo~e

a

i-

Jo tet plant

from 1.8 to 6 0 Ibs/nBtu.

Tt~sincrease wou ~ alto” Olin to

burn Illinois coal.

It is clear

tI’a’

t e

ara.c

pets

r

fas

intended to stay the c~~evt

of th

neiy

3a

zc’a

cu’s~y,

until a determinatiot was maCe or t e s

~

ot

~f3c

£

toil

1initatioa.

At its Joiiet plant,

Olir.. prod

zceo

induc

al sdtum phos-

phates, including orthophosphates and condensed phosphates.

It

also produces sodium silica fluoride and sodium fluoride.

To

produce the sodium plo: lates Olin uaes a wet acid process.

To

reduce this pro uct to a granular or powder form

the plant must

evaporate abou” 600 gallons of water per minute

Falf of this

53-231

---

2

water is evaporated by direct contact with

air

heated by natural

gas, and the other half is evaporated by indirect contact with

steam.

The steam necessary, approximately 225,000 pounds per

hour,

is generated primarily by three coal~firedutility boilers.

Each is equipped with chain grate stoker boilers,

(R,26~29)

Boiler No.1 has a rated capacity of 104.0 of a million Btu per

hour

(mBtu/hour); Boiler No.2, 141,7 mBtu/hour;

and Boiler No.3

141.7 mBtu/hour.

(Pet,

at page 4)

Their combined heat input is

387.4 mBtu/hour.

Boilers Nos,

2 and

3 are vented through a com~

mon stack.

Boiler

1 which operates as a reserve is vented through

another stack.

All three are equipped with multiclones to control

particulates.

By burning low sulfur coal, Olin previously met a mass emis-~

sion limit of

1.8

lbs/mBtu for SO, and

.2 lbs/mbtu for particu~

lates,

emitting no more than 697.~2pounds of SO2 and 77.48

pounds of particulate per hour.

(R,33).

All three boilers

were originally designed to use coal containing approximately

3,5

sulfur.

(R,32)

As stated before Olin seeks to burn coal of

a higher sulfuric content, therefore it requests variance from

the 1,8 lbs/mBtu emission limit,

Given a new, higher emission

rate of 6,0 lbs/mBtu, Olin estimates that the three boilers will

collectively emit a maximum of 2,324.4 lbs of SO2 per hour.

The

record

is not clear as to the annual coal usage used

by Olin,

However estimated cost savings should Olin is allowed

to burn medium sulfur coal

(Illinois coal)

are consistently

based on 100,000 tons per year figure.

(R,36,51)

(R.33).

Olin

estimates that it can obtain coal with a sulfuric content to meet

the 6.0 lbs/mbtu limit at $35 per ton.

(R,36)

Using the dispersion model,

MPTER, Olin sought to determine

the impact on air quality should its boilers be allowed to emit

up to 6.0 lbs/mBtu of sulfur dioxide.

This anaysis used as

a

base the Agency’s modeling analysis of the Chicago major metro~

politan area,

The Agency’s analysis used worst case meteorology

(i.e.

1975 data) and included Olin’s three Joliet boilers at 1,8

lbs/mBtu.

Therefore,

in its analysis the incremental increase of

4.2 lbs/mBtu was added to the Agency’s modeled concentrations.

Olin concluded that no concentrations greater than 80

of the either

3 hour or 24 hour SO, ambient air quality standard would result

at any of the modeled receptors.

Olin also performed two sup~

plemental analyses.

The first considered fifty~ninereceptors

that the Agency~sstudy had not; the second considered the pos~

sible wake effects of buildings,

In the latter only one build~

ing was found to possibly effect the stack’s emissions and

further analysis found its effects to be of a minimal percentage

increase.

On June 2,

1983,

Dr. Herman Sievering wrote a letter to the

hearing officer in the Olin proceeding with copies to the Olin

attorney, the Agency attorneys and the Board Chairman,

Enclosed

was a copy of a report authored for the Department of Energy and

53~232

---

3

Natural

Resources entitled “Risk Assessment for Energy Management:

A Case Study of Fuel Switching at Illinois Power Plants”, Document

No, 82/14.

Dr. Sievering requested that his letter be included

in the Olin variance proceeding record.

On its own motion,

the

Board orders that Dr.

Sievering’s letters and report be

included

in the record for this case.

The Agency Recommendation found the modeling analysis

performed by Olin to be accurate.

However, it qualified its

recommendation that Olin could be granted a relaxed emission

limit.

Noting

that

Olin was in an industrial area with at least

nine

other

major

sources

of

SO,,

any

relaxation

of

these

sources

emission

limits

pursuant

to

th~ Rule

204(g)

process

could

cause

problems in maintaining the ambient air quality standards.

Board regulations at 35 111, Mm.

Code Section 104.121,

specify the required contents of

a variance petition.

Sub-

section

(g) requires:

An assessment, with supporting factual

information,

of the environmental impact that the variance will

impose on human, plant and animal

life in the af-

fected area,

including, where applicable,

data des-

cribing the existing air and water quality which the

discharge may affect.

Olin has not provided information on the maximum calculated

ground level concentrations of SO2 whould the variance be granted.

Nor has Olin provided information on where

such

maximums would

occur or how human, plant and animal life in that area would be

affected.

A bare assertion by Olin that granting the variance

would not cause a violation of applicable air quality standards

is inadequate to fulfill the requirements

of

Section 104,121(g).

Furthermore, Olin did not include a plan or schedule to

achieve compliance with Rule 204(f).

This is

because

Olin

is

not requesting a period of time to make progress towards com-

pliance.

Rather

it is seeking to go

out

of

compliance to save

money and possibly increase the use of Illinois Coal.

Title IX of the Act provides for relief from compliance

with

the Act or Board regulations in order to avoid a Petitioner suf-

fering arbitrary or unreasonable hardship.

Since variances

under the Act are limited to five years,

a Petitioner must demon-

strate that timely compliance would impose hardship unique to

its facility, that

is, not by sources likewise regulated.

Olin

has failed to demonstrate that if not now granted variance the

resulting hardship, primarily characterized as financial,

is

unique to its facility.

Finally, Olin seeks variance in order to burn Illinois coal

until such time as the concurrently filed alternate standard

petition is decided,

The relief sought therein

is consistent

53-233

---

4

with Section 9.2 of the Act, not Title

XI.

The Board therefore

finds that Olin’s petition or a site—specific rulemaking

is the

more appropriate forum for the relief Olin is seeking.

The

request for variance is denied for of the three reasons set out

above.

This Opinion constitutes the Board’s findings of fact

and conclusions

of law in this matter.

ORDER

1.

Dr.

Herman Sievering~stwo letters dated June

2,

1983

and the

Department of Energy and Natural Resources

Document No

82/14 is incorporated into this record.

2.

The Olin Corporation Petition for Variance for boilers

1,

2,

and

3 at its Joliet facility from Rule 204(f)

of

Chapter 2:

Air Pollution is hereby denied,

IT

IS

SO ORDERED.

Chairman Dumelle concurred,

I,

Christan L.

Moffett, Clerk of the Illinois Pollution

Control Board, hereby q~rtifythat the abov

Opinion and Order

was adopted,oji the _______day of

~lLt

,

1983 by

avoteof

~

7

Christan

L.

Moffet’t42lerk

Illinois Pollution Control Board