ILLINOIS POLLUTION CONTROL BOARD

February 24,

1983

ir~THE MATTER OF:

SULFUR DIOXIDE EMISSION

)

R80—22

LIMITATIONS~

RULE 204

OF CHAPTER

2

)PINION OF THE BOARD

(by

I.

G.

Goodman):

On December

1,

1980

the

Board received the Illinois

Environmental Protection

Agency~s

(Agency) proposal

to adopt

emission limitations

for sulfur dioxide from fuel combustion

emission sources located within the three Major Metropolitan

Areas

(MMA)

of St.

Louis, Peoria, and Chicago.

Also proposed

was a reduction in the emission limitations for process emission

sources located in the St.

Louis and

Chicago

MMAs,

The Agency

filed its proposal in R77—15 and R78—14, two ongoing regulatory

proceedings which had been consolidated for hearings.

R77—l5 was

a site-specific rulemaking proposed by Ashland Chemical Company

(now Sherex Chemical Company,

Inc.)

to amend Rule 204(c)(l)(A) of

the Board’s

Chapter

2:

Air Pollution and finalized by Board Order

Ofl

December

17,

1981.

R78—14 was an inquiry concerning Rule

204(c)(1)(A)

instituted by the Board. and dismissed on January 8,

1981.

The Agency’s proposal was primarily a response

to the

legislative mandate that it review the sulfur dioxide emission

limits

for existing fuel combustion emission sources located

within these three MMAs and

thereafter propose

amendments, con-

sistent with the Clean

Air

Act’s National Ambient Air Quality

Standards program, which would enhance the use of Illinois coal.

(Iii.

Rev. Stat.

1981,

ch.

111½,

par. 1009.2).

On December 19,

1980 the Board docketed the Agency’s proposal

to amend Rules

204(c)(l)(A), 204(d),

204(f),

204(h)

and 204(i)

of Chapter

2

as R80—22.

The Agency submitted revisions

to the R80—22 proposal

on

February 26,

1981, January 25, 1982 and June

1,

1982.

Public

merit hearings were held in East St.

Louis, Peoria,

and Chicago

on February 26, March

10 and

12,

1981, respectively,

and again

on June

.1,

1982 in Chicago.

The Department of Energy and Natural

Resources

(ENR)

submitted the Economic Impact Study of the pro-

posed

sulfur dioxide amendments,

Et~~RDocument No.

82/11, on

April

26,

1982.

Economic impact hearings

were held in Chicago

and Peoria on June

1 and 22,

1982,

respectively.

The record was kept open for public comments until July 14,

1982.

The Village of Winnetka

(Winnetka) requested an extension

on July 12,

1982.

That motion was granted and the comments filed

5 1-229

---

2

by Winnetka on July 30, 1982 were accepted.

The rules proposed

by the Board for First Notice were published in the Illinois

Register on September 17, 1982.

Comments received during the

ensuing forty-five day

period

are discussed

below.

On October 1, 1982 Winnetka requested a public hearing pur-

suant to the Illinois Administrative Procedure

Act,

flll. Rev.

~

1981, ch.

127, par. 1005.01(a)).

Since such a hearing

wo~ffdinevitably delay the

remainder

of this rulemaking, two

dockets were established by the Board on October 14, 1982.

Tfinnetka’s request for a site specific rule was designated

as Docket B and hearings held on November 3, 1982 and December

15,

1982.

The rules proposed for First Notice were assigned to

Docket A, and it alone is the subject of this Opinion

and

Order.

On November

1, 1982 Granite City Steel Division of National

Steel

corporation

likewise

requested

an

additional

hearing

under

the

ILlinois Administrative Procedure

Act.

Id.

This request

was untimely

and

no hearing was held.

Nevertheless, the

Agency

agreed with Granite City Steel’s objection

that

the language

proposed to control its fuel combustion process emission source

was inappropriate.

On

December

3, 1982

the

Agency submitted

language amending Rule 204(j)(1) accordingly and consequently,

Granite City Steel waived its hearing request.

ftiission limitations for sulfur emitting sources were among

the first air regulations promulgated by the Board in 1972.

Since then the rules for fuel burning emission sources have

been contested

and

are even

now remanded

to the

Board.

Yet in

these

ten years

the original national ambient air quality stan-

dards for sulfur dioxide have remained substantially unchanged;

the primary annual standard

has

been attained statewide in

Illinois; the control technologies originally considered have

proven feasible; and compliance with the original Board emission

limits widely achieved.

Two new concerns impacting control of

sulfur dioxide have

developed

over the

ten

year span.

The need

to

utilize

more

domestic

fuel

has

become

apparent

for

a

healthy

economy.

This realization is especially important considering

Illinois’ reserves of high sulfur coal.

Bowever, it is also

probable that further reductions in sulfur dioxide emissions

are necessary for a healthy environment.

Cognizant of these

conflicting developments, it is the Board’s

intent to

reconcile

them as much as possible in establishing sulfur dioxide emission

limits to replace those voided by the Courts.

These limits

should also provide for the attainment and maintenance of the

air quality in Illinois for sulfur dioxide..

As noted, the his-

tory of the Board’s regulations for sulfur dioxide is lengthy.

51-230

---

3

HISTORY

As st:ated before,

the emission limitations for sulfur dioxide

produced by solid

fuel combustion

and process

emission

sources

were among

the

first air

pollution

regulations

promulgated by the

Board,

including those for

the

St.

Louis,

Peoria

and Chicago MMA.

In

the

Matter

of

Emission

Standards,

4

PCB

298 April

13,

1972.

Rule 204,

as adopted,

provided future compliance dates for both

types of emission source:

May,

1975

for

solid

fuel

combustion

sources

and December,

1973

for

the

process

emission

sources.

in

30

doing,

the Board acknowledged that the control

technologies

envisioned by these limits were only then rapidly developing.

For

this reason and because compliance alternatives included switching

from

high

sulfur coal

to

limited

reserves

of

low sulfur coal, oil,

or gas,

these emission limits were not

uniform

statewide, hut in-

stead geographic

and

source

determinative,

It

should be noted that

Rule 202:

Visual

Emissions and Rule

203:

Particulate

Emissions

were adopted concurrently

with

Rule

204:

Sulfur

Limitations.

The

adoption of Rules 203(g)(l),

204(a)(l) and 204(c)(l)(A)

was successfully appealed at the appellate and supreme court level.

Commonwealth Edison

Co!p~anl v.

Pollution

Control

Board,

25 Ill.

App.

3d

241,

323

N,E.2d 84

(1st Dist. 1974),

62

Ill.

2d 494,

343

N.E.2d

959

(1976),

These specific rules pertained to the

particulate

and

sulfur

dioxide

emissions

for

sources located

within the three largest

MMA,

In

its

remand,

the

appellate

court

instructed

the Board “either to validate these

rules

in

accordance

with

Section

27

of

the

Act

or

to

prepare proper

rules

as

substitutes.”

Id,

at

96~

In

affirming

the

Appellate

Court,

the

Supreme

Court

introduced

the

notion

that the

Board~s

record

was

insufficient

as

to

whether

simultaneous

co~~liance with

Rules

203

and

204

was

technically

feasible

and

economically

reasonable.

The

higher

Court’s

decision

also

cited

the

fact

that

“a

weight

of

new

evidence”

had

become

available,

presumably

a

reference

to

the

Board’s

inquiry

hearings

into

sulfur

dioxide

rules

(R74-2)

and

the

~gency’s

proposal

for

sulfur

dioxide

rules

(R75—5),

and

like

the

appellate

decision,

directed

that

the

contested

rules

be

validated

or

appropriate

new

rules

adopted,

Thereafter

the

Board

consolidated

the

records

in

R71-23,

R74-2

and

R75—5

and

held

two

additional

public

hearings.

It

snould

be

noted

that

just

prior

to

the

Supreme

Court’s decision

the

Envir3nmental

Protection

Act

was

amended

to

require

1)

economic

impact

studies

(EelS)

and

hearings

in future

rulernakings

and

2)

adoption

of

regulations

by

the

Board

prescribing

conditions

Eor

sulfur

emission sources to use intermittent control systems

(ICy).

The

Supreme

Court~s

decision

acknowledged

the

ICS amendment,

hut was silent on the EcIS amendment,

Consideration

of ICS was

deferred

until

final

rulemaking

in

R74~2 and

R75—5

to avoid intro-

ducing a

new

rulemaking

in

the validation process.

No economic

impact statement was prepared or hearings held,

An abstract of

the conso1 tdated record with its “wealth of information” was pre—

p±~red

by riarder

& Associates,

On

July

7,

1977

the

Board validated

51-231

---

th’~

remanded

rules,

after

reviewing

the

pertinent

information in

the

record

and

considering

the

issues

identified by the Courts.

27

PC.B 57.

Therein

the

Board

decided

that

an

economic

impact

study was not necessary

for

validation,

and relied instead

on

the economic evidence

already

in

the

record,

Furthermore,

the

opinion stated that the

“Marder

report”

served only as an aid,

and not an analysis

of

the

merits

of

the

information,

Neverthe-

less,

the validation

of

the

rules

was

vacated,

Ashland

Chemical

Corn~an~

V.

~

utin

olBoard,

64

Iii,

App~

3d 169,

381

N, E.

2d

56

(3d

Dist,

1978) and Illinois State_Chamber

v~Pollution

Control

Board,

67

Ill, App.

3d

839,

384

N.E,2d

922

(1st

Dist,

1978).

I3oth

courts

declined ruling on the

substantive validity

of the R71-23

regulations and instead

voided the Board’s

validation

on procedural grounds.

Among

other

things,

both Courts found that

the

Board’s

use

of

the

Marder

report

without

public

hearings

on

the

same

violated

due

process

rights

and

that

Section

6

of

the

Act,

requiring

an economic

impact

study

and

accompanying

public

hearing:~had not been

complied

with,

Validation having

failed,

the

Board

instituted

inquiry

pro-

ceedings on the remanded sulfur

dioxide

rules

(R78—l4)

and the

particulate rule

(R78—l6)~

On

December

14,

1978,

these regulatory

proceedings were consolidated

with R77—l5

(the

Ashland site—

specific proposal)

and R78—15

(Rochelle

site—specific proposal)

for hearing purposes~

Final

action

on

R77—l5

was taken on

December

17,

1982 and on

February

24,

1983 on R78—15.

On February

15,

1979, the issues outstanding from the combined hearing

record

in R7l-23,

R74—2,

and

R75—5

were

resolved~ Sulfur dioxide

emission

limits

for rural

fuel

combustion

sources

including an adjudicatory

procedure and

formulas for site—specific limits

were adopted in

the

consolidated order for R74-2 and R75-5,

ICS rules were

not

adopted, having been

subsequently

barred

by

amendment

to the Clean

Air

Act

as

a

dispersion

enhancement technique,

As stated

above,

the

Agency’s

proposal

for

emission limits in

the

MMAs

was

sepa-

rately

docketed

as

R80—22,

R78—l4

(sulfur

dioxide inquiry) was

shortly

thereafter

dismissed.

R78—16

(particulate rule inquiry)

Wa:3 also

dismissed

with leave to reopen

should simultaneous com-

pliance with the particulate

and sulfur

dioxide emission limita-

tions become an issue

in

R80—22.

It

should

be

noted that

R82~1,

another Board proceeding concerning

Rule

203(g)(l),

has been

instituted, with further action dependent on submittal of the

economic impact study.

Therefore, resolution of the issues

involved in this rulemaking (R80-22) will hopefully

conclude

the entangled regulatory

history

of

sulfur

dioxide

since

the

Commonwealth

Edison

appeal.

ANALYSIS

OF

THE

REGULATIONS

Fuel Combustion Emission

Sources

The limit

for sulfur dioxide emissions

for existing sources

th~ three

MMA5

was originally

adopted

at

1,8

pounds

per

mu—

lion

British

thermal

units

(lb/mBtu),

4 PCB

298,

Compliance

---

with

this

and

the

other

i

t

cc

~

irrently

adopted

antici-

pated

that

air

quality

sta

e

id

~i

I

be

better

than

the

national

levels ~sLablished

i

9

J

t

~al Athient Air

Quality

Standard

(NAAQS)

for

s

Lfu

1

~i

i

c~udes

two

primary

standards:

an

annual

standard

of 30

~l

80

u~

ii

~

aid

a

24

hour

standard

of 0,14

ppm (365 ug/m3

~on

y

ta~idardbased

on

3

hours

of 0,5 ppm

(1300 ug/u

o

olstions of the

annual

primary

standard

nave

bc

y

f

the

three

MMAs,

The

short-term

pr~m~y

L

r

d

i

ni

v~

lat~d

in

all

three

MMAs,

hub not

since

~9

7

i

a

aid

Peoria

Violations

of

tile

secondary standard

iv

ir~~d

East

St~

Louis

and

Peoria.

Monitoring aloie

ie ther cai p~oide a plan to

achieve air

quality

in

the

St.

J4oSib

1’b~

~iu~

i~ibe

~mine

the

extent

the

limit

may

be

relaxed

in

the

other

ti

MMAs

and

the

NAAQS still be

maintained,

Forecasting

ot

tb

s

type

must

be

developed

through

air quality analysis.

Tie~ef~c,regional air

quality analyses,

including

base

and

strategy

a~ialy~cs, wcre

prepared

for

each

of

the

three

MMAs.

The

modc I ing

tori.

t

used

for

each

of

the

three

MMAs

was

basically

the

sane

a.i

~ere

the

data

requirements,

The

data

information,

on

the

tne~

ad

were

geographically

specific.

Each

base

analy~

s

ir~v

red

the

RAM,

a

modeling

pro-

gram

having

both

a

rura

aid

Ia

v~r ior~

The

rural

version

was

inodt ~ied

to

coeforn

‘~

c

4

n~aIe1,

the

CRSTER,

which

was

used

to

account

for

is

I r~. I

ci

t

sloe

sources,

Modeling

is

intended

t

deror~r~te

that

should

the worst

meteorological

circumstar~c~a a~I

periods

of

maximum

emissions

coincide, the NAAQS

wou

d

1

e

~cc~ed.

Except

for

the

St.

Louis

MMA,

modeling

as

i~L.

the short—term

standards,

i.e.,

tne

2

ur

I

I

a

atandards,

This

was

considered

sufficient

sin~e

hu

si

rt—tern

standards

are

con-

sidered

more

stringent

thai

the

it

rary

annual

standard,

It

should be

noted

tint

rt

i

i

~

rr~i~

~

standard

has

already been

demonstrated

t

t

a

oni~orie~

The

emission

invent

r e~

nor

med the location,

magnitude,

fr~quency,

duration

and

relativ

nor tribubions

of

the

fuel

com-

bustion emission

source’-

~ach

arei

Generally,

only

point

soure~semitting

more

tlar

3

tore

of

sulfur

dioxide

per

year

(T/yr)

were included,

and

othnL

area

sources

were

accounted

for

in

the

background

levels

Pl’~ po~nt

sources

were

identified in

the

Agency’s

total

air

sy’-t~ri

1S

which

was

compiled

initially

in

1974

and

has

since

been

cintii

o

sly

updated.

In

calculating

the sources’

impacts

or

the

sod~l

recptors,

all

sources

were

assumed

to operate

at

tLei

~x

al

o~ab1e

rate

which

was

based on the

remanded

~mission

Ime~ a

To

determine the appropria

oackground levels

for each area

studied,

localized

r~onmtoringdata

r’as

natched with

localized

meteorological

data

for

the

same

hase

ycar.

As

it

turned

out,

the

base

year

and

the

nunier

o~ nor it

rs

used

for

each

area

varied.

Since

the

sulfur

d~oxid~ monitors

operate

continuously,

hourly

averages

were

achievea

ny

averaging

the

data

collected.

---

6

Lastly,

to accurately complete

the air

quality data,

exclusion

angles were uniformly calculated to eliminate sources upwind

frm monitors

from the background

totals.

Emission Limits for Fuel Combustion Emission

Sources

St.

Louis

MMA

Analysis of the annual air

quality standards for the East

St.

Louis

area was performed using the Climatological Dispersion

Model

(COM).

The meteorological data consisted of data collected

between

1973 and 1978 at Lambert Field and compiled by the

National

Climatic

Center,

and upper air observations were obtained from the

National

Weather

Service

at

Salem,

Illinois.

Even

after

potential

growth

was

considered, no violations of the annual

sulfur dioxide

standard were predicted.

However, violations of the short—term

standards were predicted.

Like the

other

two

MMAs,

an

analysis

of

the

short—term

standards

was

programmed.

The

hourly

meteorological data for

1973—1977

was

gathered

from

the~same sources

used

for

the

annual

analysis.

The

RAM

(urban)

was

used

in

those

areas

which

are

basically

urban

in

nature,

and

a modified version of

RAM

(rural)

was

used

for

the

rural

areas.

The

CRSTER

model,

which

does

not

have

the

capability

to

model

several

sources

at

separate

locations,

was

used

for

the

isolated power plant,

Illinois Power Baldwin.

The

maximum

allowable emission rates of all major sources in

Madison,

St. Clair,

and Monroe Counties were used in the model.

Individual Missouri emission sources were not used because the

maximum allowable emission rates

and

stack parameters were not

available.

These emissions were,

however, reflected in the

background

determination.

Emissions

due

to

growth

were

not

explicitly

modeled

in

this

analysis.

It

was instead assumed

that

any

additional

emissions

would

be

minor,

and

readily

absorbed

since

the

model

was

already

conservative

in

that

all

existing

sources

are

presumed

to

operate

at

maximum

allowable

rates.

Furthermore, any new major sources would be required

to show no significant impact on air quality pursuant to the

Prevention

of Significant Deterioration

(PSD) or New Source

Review

(NSR)

programs.

The short—term modeling predicted widespread violations of

the primary 24 hour standard and the secondary

3 hour standard

primarily in the industrial areas of East St.

Louis

(Ex.

3,

pp.

85-86).

Consequently, a culpability assessment was made,

using

the “worst

case” days of the five year period modeled.

The results, which included background concentrations, and

Illinois urban and rural sources of sulfur dioxide,

found the

sources

in the Alton Wood River Area to be varied; whereas in

Ea;t St.

Louis

and Granite City, the elevated sulfur dioxide

levels

were

more localized and source—oriented.

The two sources

identified,

however, were process sources as opposed to fuel

corn—

i)~l5tiOrI

sources.

51-234

---

7

Due

to

the number

of

violations

predicted,

no relaxation of

the emission limitation for fuel

combustion

sources

in

the

St.

Louis MMA is proposed.

Sulfur

dioxide

emissions from residential

and commercial sources are predicted to increase in the next

decade, but fuel combustion emission to remain constant from

industrial sources.

In an effort to achieve attainment in this

MMA, more stringent limitations for process

sources

were

proposed

by the Agency.

These will be discussed later in this Opinion.

Peoria Major Met~~tan Area

Neither the modeling done in 1978 nor recent monitoring

indicates violation of the annual standard in the Peoria MMA.

Thus, only short—term analyses were considered, on the assumption

that short—term standards are more restrictive than the

annual

standard and, therefore, any subsequent relaxation could not

jeopardize the annual attainment

status.

Furthermore,

local air

quality monitoring indicated annual sulfur dioxide concentrations

well below the national annual standard.

(R. 41.)

A five year

base analysis, using the RAM (urban and modified rural) and CRSTER

model, was developed to determine

if

the 1.8 lb/mBtu limitation

could be relaxed.

Five years

(1973—1977)

of meteorological data

from the Peoria National Weather

Service

Station was used in the

analysis.

Again, maximum allowable emissions based on the 1.8 lb/

mi3tu

standard were used along with appropriate background concen-

trations.

Terrain effects were not considered.

The results of

the base analysis predicted violations of the primary 24 hour

standard, which were isolated to

two

small areas,

and none

for

the secondary

3

hour standard

(Ex.

3,

pp. 25—26,)

A culpability analysis was then developed,

focusing on the

two receptors which had indicated violations in the short—term

base analysis.

This analysis associated these violations with

sources located at the Caterpillar Mossville Plant and Caterpillar

East Peoria Plant.

(R.

45,)

Both

of

these

Caterpillar plants

are already equipped with flue gas desulfurization equipment (FGD).

Therefore,

if the actual controlled emissions were used in the

base analysis, it is possible that violations of the primary

short—term standard would not be predicted, and relaxation of

the 1.8 lb/mBtu limit could be considered

fo.r some of the area’s

remaining existing sources.

Two strategy analyses were conducted by the Agency to deter-

mine the

extent relaxation would be possible without creating

violations of the NAAQS.

The first strategy analysis focused

on the violations predicted for

the two

Caterpillar plants

identified above.

While

it took into account the control pro-

vided by the FGDs, this analysis considered two twenty—four hour

periods,

one for the Mossvile plant and one for the East Peoria

plant.

The probability of violations occurring was confirmed.

(Ex.

3,

p.

29.)

51-235

---

8

The second strategy analysis studied relaxations of the emission

1.Unit for small sources in the Peoria

P04k.

CR. 192.)

The RAM

Curban) and the

MPTER

models were used.

The tOTER is a dispere

sion model which

can

simulate the dispersion of several sources’

pollutants in a moderate terrain.

Applying a data base consisting

of the relaxed emission inventory based on a 5.5 lb/miltu emission

limit, a modified receptor network, and five years of

meteoro-

logical data,

the

modeled

impacts

for all

urban

md rural sources,

and background concentrations to the MPTER, air quality

was

assessed.

It should be noted

that

the

two

Caterpillar sources

already modeled were

not

included

in the

inventory,

but

its other

two

Peoria plant sources, Mapleton and Morton, were.

CR.

192.)

Violations of the short—term standards were predicted.

CR.

194.)

Yet another culpability analysis was performed.

Caterpillar’s

Mapleton Plant, despite an emission limit of 1.8 lb/mBtu, and the

Sherex Chemical Company

were

identified as the sources of violation.

After considering these analyses together, the following

conclusions

were

made

by

the

Agency:

(1)

The cause of Caterpillar Mapleton and Sherex’s pre-

dicted violations were the Mapleton bluffs;

(2)

using roll back methodology, emission limits of 1.0 lb/

mBtu for

the

mBtu for the Caterpillar Mossville plant would be

sufficient to maintain NAAQS;

(3)

again using roll back methodology, Sherex’s emission

limit

could

be

relaxed

from

1.8

lb/mBtu

to

3.3

lb/mBtu

without

jeopardizing

the

NAAQS;

and

(4)

with

the

exceptions

of

the

Caterpillar

and

Sherex

facilities, the emission limit could

be

relaxed

from

1.8 lb/mBtu to 5.5 lb/motu for industrial boilers with

a generating capacity of less

than

250 mfltu.

CR. 195—

196.)

ft should be noted that the industrial facilities with a

generating capacity of greater than 250 mBtu still subject to the

1.8 lb/mBtu limitation were

CPC

International

Cnow Pekin Energy,

Inc.), and possibly Caterpillar sources already

equipped

with

FGDs.

Throughout the proceedings,

the

squrces

located

at

the

four

Caterpillar plants in the Peoria Milk were a subject of contçoversy.

At first a limit for the Mapleton sources was proposed.

It was

later rescinded because they were consi4ered to be new sources

and

subject

to

regulation

for

the

same

not

yet

proposed

by

the

Agency.

CR.

98.)

Furthermore,

boilers

4

and

5

at

this

facility

were not initially included in the TAS inventory because they

were under construction during this rulemaking

CR. 176),

and

they

were

not

51-288

---

9

Boilers

4 and 5 of the Mossville facility, although also new

sources, were included in

the

inventory

and

in the modeling.

CR. 176, pg.

12,

Sc.

3.)

Initially, a limit of 1.6 lbs/mBtu was

proposed for this facility, but later modeling indicated that

emissions up to 1.8 lbs/mBtu would not jeopardize air quality.

CR.

570.)

The Morton facility was modeled at 1.8 lbs/mBtu

and

no

violations predicted.

The

Agency

even said

that

a limit somewhere

between 1.8 and 5.5 lbs/mBtu was possible without causing problems,

assuming no new sources were constructed in the vicinity.

(R.

125.)

As for the East Peoria facility’s sources, 1.0 lbs/mBtu

was originally proposed and later relaxed to 1.1 lbs/mfltu.

(R.

208,

571.)

During the merit segment of the

Tune

1, 1982 hearing,

a third strategy analysis was presented.

The emissions inventory

for the modeling was revised to include the Caterpillar plants

emitting at their actual limit of 1.8 lb/mBtu, small industrial

boilers (less than 250 mBtu) emitting at 5.5 lb/mfltu, and CPC

International boiler

(rated at 330 mBtu) assessed at 5.5 lb/mstu.

The

Sherex boiler was modeled at an assumed stack height of 200

feet, which would allow Sherex to emit up to 5.5 lb/mBtu without

causing NAAQS violations due to the Mapleton bluffs.

Throughout

the rulemaking the Agency argued that the limits proposed for the

Caterpillar

sources

were

in

fact

the actual emissions after cone

trol

with

the

FGD5

and

that

Caterpillar

was

already

using

Illinois

coal.

Therefore,

site—specific

limits

for

three

of

Caterpillar’s

Peoria facilities would not affect their operation.

Therefore,

after the third modeling strategy was completed,

Mapleton was

excluded as being a new source; two sources, Mossville and Morton,

were limited to 1.8 lbs/mfltu, and the East Peoria facility was

limited to 1.1 lbs/mBtu.

These limitations were intended to

maintain compliance with the NAAQ standards for sulfur dioxide.

During the First Notice period, Caterpillar renewed its

objections

Cl) that it was being singled out for site—specific

rulemaking, and

C2) that its sources should be considered

existing sources.

Caterpillar also objected that as rules were

proposed, it was excluded from the exception procedure proposed

in Rule 204(c)(4)(Now Rule 204(g)).

Upon reconsideration, the specific emission limits originally

proposed

for

three

of

the

four

Caterpillar

facilities

located

in

Peoria

are

deleted.

The

site—specific

limits

of

1.8

lbs/mBtu

pro-

posed

for

Mossville

and

Morton

sources

are

unnecessary

since

they

were redundant.

Both

facilities’ sources are already restricted

to

that

limit pursuant to Rule 204(b) or Rule 204(f).

The emis-

sion limit for the East Peoria sources is also deleted.

Like the

aforementioned Caterpillar sources, those located at this factlity

are subject to the 1.8 lb/mBtu limit contained in Rule 204(b) or

Rule 204(f).

However, the Board notes, as it did in the Opinion

adopting site-specific particulate limitations for these Cater-

pillar sources, R79—ll, October 8, 1981, that some of these

sources may be subject to the USEPA’s new source performance

51-237

---

As

stated

above,

the

Agency

sought

a

1.1

Ibs/mEtu limit

for

the

East

Peoria Caterpillar sources.

In proposing

this limit,

the Agency relied

on

its

third

strategy

analysis.

(Ex.

10,)

This

analysis

was

based

on

an

emissions

inventory revised since

the base analysis

and

the

first

two

analyses

for

the

Peoria area

were completed.

Some

industrial

coal~fired

boilers

were modeled

to be operating at

5,5

lbs/mBtu

and

other

restricted

to 1.8

lbs/rnBtu;

for

example,

Sherex

Company

was

modeled

at

5.5

lbs/mBtu

to reflect its

commitment to raise the sources~ stack,

and

the

Caterpillar

sources

were

modeled

at

1,8

lbs/mBtu.

Out

of

100

receptors

identified by the previous three analyses,

29

were

chosen

for

this third strategy analysis.

These

twenty—nine were

chosen

because

their second—highest concentrations

for

the

1975

model year were

at least two-thirds of the air

quality

standard.

The

Agency

stated that this technique was conservative.

As it

turned out,

only those receptors with completed

concentrations

of

at

least

80 percent of the standard in

1975 were

ultimately

indicated

to have violations of the NAAQS in any of

the

other

tour modeled

years,

and apparently only East Peoria

and Mapleton

were

identified as possible problems.

The violations

predicted

at the Mossville

facility disappeared because

of

the

inventory

changes.

Having finally reached this point,

the Agency

computed

several

emission limits for the East Peoria Caterpillar

facility

to assure attainment

of

the

NAAQ

standard.

For

all

the

boilers,

a 1.1

lbs/mBtu

limit was determined to be necessary.

The

Agency

also computed

an

average

limit

for

the

Mapleton

sources.

However,

as mentioned above,

these

are

now

sources

which

will be subject

to

future

regulations.

As acknowledged by the Agency,

the third strategy

analysis

was

conservative,

and it was derived from previous

conservative

analyses.

All the sources included in the inventory

were

at

their

highest allowable rates, and all were assumed to

be so

operating at

all times.

Indication as to the dates,

times

or

number of predicted violations

at

the

East

Peoria

facility are

not

specifically

contained

in

the

record.

There

is

no

analysis

as

to

how

the

1.1

lb/mBtu

limit

was

arrived

at,

or any explana-

tion

of

how

the

relaxed

emission

limits

for

other

sources

impact

this

Caterpillar

facility.

Given

the

conservative

modeling,

and

the

absence

of

monitored

violations

in

the

Peoria

MMA

since

1977,

adoption

of

a

rule

which

would

in

effect

cap the East Peoria

sources

at

a

level

below

that

now

applicable

or

based

on

its

actual

omissions

is

not

warranted,

Durin,g

First

Notice,

Caterpillar

requested

that

the

exemp—

tion

procedure

contained

in

Rule

204(g)

be

made

available

to

its

sources.

In

eliminating

the

site-specific

limits

for the Cater—

pillar

sources,

the

proposed

rules

have

been

restructured,

and

consequently the

exemption

procedure

is

available

to

those

Cater—

piJiar sources qualifying

under

subparagraph

(g).

51~238

---

Chicagpflajpr

.‘StLLJ_

e

A

The air qualtt

Late

in

1981

an)

(sc.

11)

Ic ba

areas identifi

tif

Led

as

rura

strata

the

sir

q

o

tt

logical data for

c

National Weathe

c

provided the

upper

a

r

to

Lake

Michigan

were

.

sites

continuously

ope...a

c

available dispersion eo

ci.

ru

effects into account.

I

e. cii s

sources considered to

lavd

-

g

than

lOt)

V/year,

locat~.c

1

0

DuPage

Counties.

The

maxi

z

-

throughout; this way the p0.,

“

be

identified,

with

the

add- t,

or

be

specifically

constiered

The base anal4sts

it’

t

-

standards.

For the 2

h

r

a

Cook

County,

and

ore

in V

three

violations

were

r

ad

c-

d

The

Chicago

YIP

ulp’

out the Chicago area the

:

I

ic

be

exceeded.

In Coo

Co’

ficantly contributing

ft~.

i ‘t.

a

was identified in rill C

fore, its actual emiasi nb

-

0’

remaining sources iden

r

enissions

near

the

axi.

a

model.

Therefore,

rathe

Lw

i

a

that

relaxation

is not us..

is

b

£

realize4 that individual..y

tte...

that increased emissiot

ata

the

surround ing

vicinit)

I

cr&. prepared

T

tearing

d

)

Cor

those

ar as

iden—

o

demon—

.~.

eteoro—

C

cago

Midway

-

..i

her Service

tc.al

effects

due

1

eteorological

-

no

readily

a

il.

o

ake

the

Lake

1.

i’

i

r

included

point

.t

t

i

pa

t..

that

is

greater

t

i

I

“4cUenry,

Kane

and

abi.~

e

-

ton rate was used

v

olat.ors

o~vie

NAAQS

could

o

Eft

ha

rowth

need

not

itt

short—term

r

-t

~.dicted

in

ry

tt’

3 rur standard,

t~u.t

R

562.)

cdi

e

that through—

d

‘

to’

..tandards

would

c

-

ra

£deaified

as

signi—

t

ie

r

s

S

One

source

ailed,

there—

a -d

Similarly, the

c.

r~t.ibuting

-

‘1

rits

sedinthe

J

a

a

Y2t

b..termination

an

ta’.s,. a

~

it

should be

.5

lay

k~cable to prove

E.

~ar1

it

the

NAAQS

in

Unlike

tne

analyses

tor

t.

~

t.

-r

t

a

a

rs

tie

background

areas

to

be

included

ti

he

t

c.

o

a

.ad

P

be

limited

because

of

the

size

and

c

up e

y

f

th

aeog.raphtc

locale.

Pour

areas

were

identified

a’

eed

~

oac

gro

d

value

deter-

mination:

Will

County

e ~

e

‘oo

County and

northern

Cook

Coutty

a

‘c

und

levels,

actual

data

gathereC

a

di.

r

?

ronitors,

as

recorded

in

19

‘

aid

31

-

.

-

t~

honly

meteoro-

logical

data

for

1976

a

d

r

I

ii

.

ors

were

discounted

through the use of

exclu

i

n

SI

---

12

In

addition

to

the

base

and

culpability

analyses,

four

strategy

analyses

were

conducted

to

determine

which sources

could

he

granted

relaxed

emission limits.

Two of the four analyses were

site—specific,

and

two

looked

initially

to

the

geographic

areas

to

determine

if

any

sources

located

therein

could

profit

from

relaxed

1 i~mitations,

The

first

strategy

evaluated

the

emission

sources

in

Kankakee

and McHenry Counties to determine if the

limitation

could

be

relaxed from

1,8

lb/mBtu to 6.8 lb/mBtu without jeopardizing

the

attainment status,

Each county has one coal burning facility

and

one oil

and/or gas burning facility which is unaffected by any

relaxation.

Nevertheless, these facilities had

to

be

included

in the modeling since they each contribute more

than

two-thirds

of the total sulfur dioxide emissions per year

in

their respective

county.

The CRSTER model indicated that the

coal

burning

sources

could emit

up to 6.8 lbs/mBtu without jeopardizing the air

quality

in

these attainment areas.

The Shapiro facility in Kankakee County was individually

modeled.

It had not been included in the

Kankakee

study

since

its boilers are equipped to operate on natural

gas.

It

does

have

a single coal—fired boiler which,

if

utilized

with the

relaxed emission limit of 6.8 lb/mBtu, would not

adversely

impact

air quality

in Kankakee.

Furthermore, should Shapiro decide

to

switch

to

Illinois

coal,

results

of

the

CRSTER

model

indicate

that

the

other

coal—fired

facility

in

Kankakee

would

not be

affected,

and

the

attainment

status

would

not

be

jeopardized.

The

second

geographic

area

considered

was the areas

of

the

Chicago

MMA which were outside the areas

designated

non—attain-

ment

for the short—term standards.

Only five sources, which are

currently burning non—Illinois coal, were modeled

as

potential

candidates

for a relaxed emission limit of 5.5 lbs/mBtu.

These

emission

sources, meteorological data

from 1973

(the “worst

cas&’

year),

and previously identified receptor locations

were

input

into the RAM (urban) and MPTER model.

Background

data

for

Lake,

Will and Cook Counties were also programmed.

Only

two

sources

were identified

as

not

causing

violations

of the short—term

standards if allowed to emit up to 5.5 lbs/mBtu.

However,

as

was

the

case

for

two

sources

in

the

Peoria

MMA,

modeling

to

determine

possible

terrain and downwash problems

is

necessary

before

a

relaxation could

be

granted

to

these

sources,

They

therefore

are

potential candidates

for the site—specific adjudi-

catory procedure also proposed in this rulemaking.

Lastly, the Caterpillar facility in Kendall

County

was

modeled to determine

if the emission limitation could be relaxed

to

6.8

lbs/mBtu.

Kendall

County

is

currently

an

attainment

area

for

sulfur

dioxide.

Should

the

emission

limit

he

relaxed,

however,

the

CRSTER

model

predicts

significant

violations

of the

short—term

standards,

hut

no

violation

of

the

annual

primary

standard.

Relaxation

is

denied

at

this

time

because

the

CRSTER

model

did

51-240

---

13

not take into account background levels, terrain,

or building

downwash effects..,

During the First Notice, Caterpillar argued

that these same effects were not considered

for sources

in Kan—

kakee and McHenry Counties, and therefore should not be considered

in evaluating Kendall County.

However, modeling of McRenry and

Kankakee sources did not predict violations of any air quality

standards, whereas modeling for the Kendall County facility did.

Although denied relaxation at this time, this facility, like many

others, can utilize the proposed exemption procedure.

The overall effect of the relaxations proposed is that an

additional

220,000 tons of Illinois coal can be burned annually

in addition to the 120,000 tons burned annually by Sherex, Bemis

and Celotex pursuant to R77—15.

Conversions by sources in the

Peoria MMA and Kankakee and McHenry Counties from oil or natural

gas will also increase Illinois coal usage.

At this time, however,

the amount is not certain (R.648).

The increased usage of high—

sulfur coal has been adequately demonstrated, primarily on a

source—by—source basis, not to jeopardize current air quality.

In addition to the specific limitations adopted for fuel

combustion emission sources in the three MMAs,

an exemption pro-

cedure is proposed much like that available to rural

sources

pursuant

to, Rule 204(g)

(former Rule 204(e)).

Adopting the

adjudicatory format, petitioning sources are required to demon-

strate that the relaxed emission limit sought will not jeopardize

air quality.

This procedure should be readily available to

sources since they can merely premise air quality modeling on

that already completed by the Agency for each of the MMAs.

At the June

1, 1982 hearing, Winnetka sought a relaxed

emission limit for its utility company.

It submitted modeling

studies premised on the Agency’s studies, to demonstrate that

air quality would not be jeopardized if it was allowed to emit

up to 6.8 lbs/mBtu.

At First Notice, site—specific rulemaking

was denied Winnetka because the public had been insufficiently

notified of such a possibility.

The Opinion noted that Winnetka’s

source was

a likely candidate for the proposed exemption procedure..

Nevertheless, Winnetka sought a public hearing pursuant to the

Administrative Procedures Act.

Docket B was therefore established

by Board Order on October 14, 1982 to ensure that adoption of the

remainder would not be delayed.

As mentioned above, two hearings

have been held.

Docket B will be concluded as soon as transcripts

of the same are received and the record is closed.

However, with

the final adoption of the general emission limit for fuel combus-

tion sources in the Chicago MMA, Rule 204(f)

is arguably applic-

able to Winnetka’s source despite the ongoing status of Docket B.

To avoid this consequence,

a footnote is included which exempts

this source from Rule 204(f) until action on Docket B is final.

Aside from amending the rules

for fuel combustion sources

51-241

---

14

is proposed.

(Rule 204(i).)

The numerical limitation for dis-

tillate oil sulfur dioxide emissions is eliminated as a specific

component in the present formula.

The

new formula regulating com-

bustion of combination fuels at steel mills is self—explanatory.

At First Notice, the definition for the formula’s component

H1,,

included a reference to catalyst regenerators at petroleum refin-

eries.

Since this formula is applicable only to steel mills,

Process Emission Sources

Sulfur compounds are emitted into the atmosphere from fuel

burned at process sources or from the process itself.

As noted

in the St.

Louis

MMA discussion, the process sources’ emissions

in that area contribute significantly to the non—attainment

demonstration.

Consequently, revised and new emission limits

are proposed which reflect these sources’ current actual emis-

sions and control capabilities.

These regulations, which impose

no immediate obligations on the regulated facilities, will not

necessarily improve air quality.

Instead these revisions will

enhance the air quality demonstration, which will in turn reflect

a larger margin for health and growth purposes.

The amendments

will also ir~surethat localized atmospheric sulfuric loading is

not inadvertently increased by area sources.

It should be noted

at the outset that the rules for process sources are reorganized

and amended into two subparts:

process emission sources and fuel

burning process sources.

The present general emission limit for process emission

sources is 2000 parts per million

(ppm).

This limit represents

a concentration standard as opposed to a mass limitation standard.

Although the concentration standard is appropriate for a general

limit,

it has its drawbacks.

For instance, correction factors

necessary to compensate

for excess air introduced into the exhaust

flow are difficult to develop.

Therefore,

wherever possible a

mass limitation standard is proposed for the emissions associated

with the ft~elburned at process emission sources.

Three processes are already exempted from the 2000 ppm

limit: processes designed to remove sulfur compounds

from fuel

combustion emission sources’ flue gas,

i.e., FGDs; existing

processes designed to remove sulfur compounds from petroleum

and petrochemical processes’

flue gas; and qualified existing

hydrogen sulfide flares at chemical manufacturing plants.

Five additional sources are proposed for exemption from the

general concentration limit:

(1) sodium aluminum sulfate manu-

facturing process;

(2)

sodium sulfite manufacturing process;

(3) secondary lead smelting process;

(4) glass melting furnaces;

and

(5) glass heat treating with sulfur dioxide process.

Of

these

five categories only two, secondary lead smelting and glass

melting furnaces, are found to significantly contribute to the

Chicago MMA non-attainment status for sulfur dioxide.

51-242

---

15

This

is

reflected

in

that

the

rules

proposed

are

geographically

specific.

The

differences

between

the

emissions

allowed,

based

on

the

2000

ppm

standard,

and

the

actual

emissions

contributed

are

significant.

Review

of

the

processes

themselves

makes

it

evident

that these differences are inappropriate and unneeded by the pro-

cess facilities.

For example,

under the general rule, the glass

heat treating with sulfur dioxide process could emit up to 21

pounds of sulfur dioxide per ton of product.

Yet, the raw

materials as a whole used in this process can only generate one

pound of sulfur dioxide per ton of product produced.

Instead of the process—specific emission limits, these five

categories are exempted from the general concentration standard.

Exemption,

as opposed to specific limits,

will allow the indi-

vidual sources emission limits

for sulfur dioxide that are appro-

priate and readily achievable at the individual facility.

It

should be noted that none of these sources use control equipment

for sulfur dioxide.

The Agency has requested this regulatory

format in an amended proposal.

A specific emission limit is proposed for new process emis-

sion sources in the St. Louis MMA which are designed to remove

sulfur compounds from the flue gases of petroleum and petro-

chemical process, commonly known as the Claus process.

This

process is

a recovery unit intended to recapture sulfur from

the acid or sour gases at petroleum refineries.

The sulfur

dioxide emissions from this recovery process are usually more

than 9000 ppm, much greater than the 2000 ppm limit.

Therefore,

secondary recovery is required to control the tail gas emissions

of sulfur dioxide.

In-plant studies indicate that secondary

recovery units can reduce sulfur dioxide emissions to 11-13.9

pounds of sulfur dioxide produced.

This corresponds to 646 ppm

to 834 ppm, which is far below the 2000 ppm allowed by the

general rule.

Shell

Oil Company objected to this reduced emission limita-

tion for two reasons..

It had just recently installed a SCOT

(Shell Claus Off Gas Treating) process at its sulfur recovery

plant in St.

Louis.

It stated that the 1979 stack test results

obtained there and relied on by the Agency in developing the

revised limit could not be generalized since design and installa-

tion at other facilities might produce different results.

Secondly, due to increased recovery efficiency of the SCOT unit,

the primary recovery unit

is subjected to increased sulfur

loadings which result in increased emissions.

(R.l08.)

The second fear would seem unjustified based on the 1979

stack tests.

These were taken at the Claus plant, and therefore

reflect these increased emissions.

As for the first,

the revised

limit is intended to encourage the use of a secondary recovery

process as efficient as the SCOT unit at new sulfur recovery

51-243

---

16

facilities

as

opposed

to

low

temperature

Claus

processes.

In

proposing this limit,

it is understood that individual

facilities

might

experience problems due to design, installation or

other

facility specifications.

However, as

is the case in

adopting

all

regulations

solutions to these possible quirks must be

remedied

as

needed.

An emission limit of

14

pounds of sulfur dioxide per

ton of sulfur for new sulfur recovery processes

is proposed.

A 500 ppm limit is proposed for sulfuric acid manufacturing

plants

in the City of Chicago.

The one such plant affected

is

equipped with a WellmanLord sulfur dioxide recovery system

with

96.3

percent

efficiency.

This control equipment was designed to

meet

the

City of Chicago’s 500 ppm limit for sulfur dioxide.

(R.636),

Based on this,

the Board finds that the technology to

achieve

this reduction is feasible and economically reasonable,

This

limit is therefore proposed to achieve and maintain

the

NAAQS

for

sulfur dioxide in the Chicago MMA,

As

stated

earlier,

mass

emission

limits based on the

fuel

combustion capabilities of process sources located in the Chicago

or St.

Louis

MMAs

are

proposed.

(A typographical error

in

the

Second

Notice printing of Rule 204(j) has been corrected,

reinserting

the MMA5

language.)

Also

proposed are specific rules

for three

such

sources.

One

is

sourcespecific;

the second involves a type

of

process

source;

and the third is an exemption.

The

source

specific

limitation

is applicable

to

a

process

source

located

in the St.

Louis MMA which burns tea leaves as

a

solid

fuel.

The

proposed

emission

limit of 0~7Olb/mBtu

will

not

require

any

additional control equipment or investments by the

affected source, and will allow it to utilize its waste product

tea

leaves

in a manner more resourceful than landfilling.

Secondly,

lime kilns as a fuel burning process source are

exempted

from

both the 2000 ppm limit for process sources

and

the

1.8 lb/mBtu

limit for solid fuel combustion sources,

Lime

kilns

are

only

located

in the Chicago MMA and rural

areas and primarily

burn highsulfur coal,

Subsequently, it should be subject

to

the

1.8

lb/mBtu

applicable to other similarly located sources

burning

coal.

However,

the lime involved in the process itself

reacts

with the

sulfur to reduce the sulfur dioxide emissions to levels

below

the 1.8 lb/mBtu and therefore well below the 2000 ppm.

In

exempting

these

kilms as a fuel combustion source and a process

emission

source, the emission attributed to these sources will

be

their

actual

emissions, as opposed to their allowable under a

Board

rule.

An

exemption is provided for those sources which can

be

classified as either

fuel burning process sources or fuel

combustion emission sources.

The slab furnaces at the Granite

City

Steel

Corporation are the only known such sources since

the

furnaces

are directly fired,

The oil burned there

is too high

in sulfur

content

to

meet

the limits applicable to fuel

combustion

51~-244

---

17

sources,

However, it does meet the 2000 ppm limitation.

The

exemption proposed in Rule 204(j)(l) allows these sources to meet

either

limitation without switching to

fuel oil

with

lower

sulfur

content,

At First Notice, the rule was phrased in general terms which

limited emissions to the maximum amount emitted by a fuel—burning

process emission source between March,

1981 and

March,

1982.

It

was

only intended that the rule be applicable to slab reheat

furnaces,

and the proposed limit was not

intended

to

cause

any

fuel switching.

Granite City Steel commented that the limit was

inappropriate

and

the

Illinois Petroleum Council commented that

as

phrased

the

rule

was

possibly

applicable

to

petroleum

refineries.

The rule has been changed in response to these comments.

Rule 204(j)(1) now specifically names slab reheat furnaces——

eliminating the Petroleum

Council’s

concern.

Furthermore, the

emission limit is now a specified amount,

730 lbs/hr, eliminating

Granite City Steel’s concerns.

The

mass

emission

limit was calcu-

lated based on the total

fuel burning capacity of three of four

slab reheat furnaces——since only three of four currently permitted

can be operated at one time——and multiplying the percentage of

total heat input obtained from the fuel oil by the sulfur content

and the emission factor for residual fuel oil,

This calculation

was

agreeable

to

both the Agency and Granite City

Steel.

(Public

Comments received December

3

and

13,

1982,

respectively.)

Before concluding the

discussion

of the individual segments

of proposed Rule 204, the reader should note that the Rule has

again been reorganized,

This was done with the hope that addi-

tional

lettered subsections would facilitate understanding.

For

instance, the formulas found in the Rule entitled Fuel

Combustion

Emission Sources Located Outside the Chicago,

St. Louis

(Illinois)

and Peoria Major Metropolitan Area has been returned

to subsection

(e).

In so doing it follows directly after the rules containing

the emission limits for such sources,

This also means that any

site—specific limits already granted pursuant to this subsection

remain in effect.

This reorganization also means that the

exemption procedure

(Rule 204(g)) proposed in this rulemaking now

follows the specific

limits set out for fuel combustion sources.

In this way it should be

clear

that the procedure is

available

to

fuel

combustion

emission

sources

regulated

by Rule 204(c)—(f).

Economic Evaluation

At the March 12,

1981 hearing, an economist with the Agency

discussed the possible compliance costs should the emission limits

then proposed for fuel combustion sources be adopted.

The

Agency’s

permit files identified 113 coal burning facilities to which these

limitations would apply.

Only one of these,

Sherex, was out of

compliance with the limits proposed,

Therefore, the cost of

compliance

would

be

only

the

amount

Sherex

would

be

required

to

expend

to

achieve

the

3.3

lb/mBtu

then

proposed

for

its

source.

51-~245

---

18

Having concluded

that

adoption of the proposed regulations

would

result in little or no economic effects on the capital

investment of the affected facilities, the Agency then considered

the

economic ramifications should the proposed regulations not

be

adopted.

Fuel switching from low-sulfur coal to high—sulfur

Illinois

coal

has

obvious economic benefits,

but only for a

limited

number

of

facilities,

Forty—eight

Peoria

sources

were

already burning high—sulfur coal,

The permitted coal consumption

for the remaining sixty-five facilities

is primarily attributable

to

electric utility companies.

Since these facilities are

committed

to

long-term

western

coal

contracts,

fuel

switching

is

not a viable

alternative.

The

economic

benefits

available

by

switching

from

liquid

or

combination

fuel

to

Illinois

coal

are

similarly attractive, but only if the conversion costs can be

amortized over a long period,

The ENR economic impact study (Exhibit 17) reviewed separately

the relaxed limits for fuel combustion emission sources and the

reduced limits

for process emission sources,

Since cost of

compliance was not at issue

for either coal combustion sources or

process sources,

the study assessed the cost savings for the first

and the

economic consequences of the second,

It also examined the

probable

economic

impact

on

the

Illinois

fuel

markets,

which

along

with

cost

savings,

could

be

expressed

in

real

dollars.

The

study

considered

the

consequences

to

the

health

and

welfare

of

the

affected public and property.

Assigning dollar values to this

proved difficult.

Five

industrial

facilities equipped with coal

combustion

boilers were identified in the

Peoria

MMA which could

benefit

from

the

adoption of a

5.5

lb/mBtu limitation,

It

should

be

noted

that

three

of

the

five,

Celotex,

Bemis,

and

Sherex,

have

already obtained this relief pursuant to R77-15.

Al.

five

facilities,

however,

are

briefly

discussed

here,

The

Westinghouse

Airbrake

Company

(WABCO) currently utilizes

4,500

tons

of

Kentucky

low—sulfur

coal

per

year

at

an

approximate

cost

of

$55.15

per ton

(1981 dollars),

Converting to Illinois

coal,

costing

approximately

$31.42

per

ton,

should

save

WABCO

nearly $108,450 per year in

fuel costs,

Additionally, WABCO

indicated that conversion costs would

be negligible.

Pursuant

to

R77—l5,

Celotex

currently

burns

approximately

45,000

tons

of

Illinois

coal,

Therefore,

no

cost

savings

is

attributable

to

reaffirmation

of

the

5.5

lb/mBtu

limit.

~However,

if

forced

to

use

blended

coal,

costs

would

increase

by

$727,000

per

year.

Sherex,

the original proponent in R77—15,

is operating

with

the

same

relief,

It

currently

burns

only

Illinois

dbal

in

its

boilers which have two stacks,

If forced to instead use blended

coal,

fuel costs

could

increase

by

$708,000

per

year,

or

as

much

as $1,060,000

per

year

if low—sulfur Kentucky

coal

is

required.

These increased cost figures do not include any equipment costs

associated with converting

to

blended

coal

because

Sherex

claims

51-.246

---

19

that would not be technologically feasible,

In allowing a

maximum

emission limit of 5.5 lb/rnBtu, aerodynamic downwash from its

facility posed a problem.

Sherex has corrected this by heightening

its

stack

at

an

approximate

cost

of

$235,000,

The same

situation

holds true for Bemis Corporation which burns an estimated

31,000

tons of Illinois coal per year at a fuel cost savings of $499,000

per year.

Bemis incurred

no

significant

conversion

costs.

In

1980

Pekin

Energy Company,

formerly CPC International,

consumed

63,000

tons

of

Illinois coal and 123,000

tons

of

western

coal for a blend costing an

average

of $45.40

per

ton,

or

$8,380,000.

Pekin Energy testified that, if permitted,

it could

instead consume 191,000 tons of Illinois coal at a total cost of

$5,600,000

and thereby

save $2,830,000.

These savings, however,

are partially offset by the estimated annualized cost of $125,000

for a fifty foot stack extension.

Without such an extension,

emissions

ranging

up

to

the

5.5

lb/mBtu limit could have caused

aerodynamic downwash, which

would

result

in air quality violations.

Based on the proposed

relaxation

in McHenry

and Kankakee

Counties in the Chicago MMA, cost

savings were

found to be avail-

able to one

Kankakee facility~

Other facilities were not studied

since they indicated they would not utilize a relaxed emission

limit of 6.8 lb/mBtu.

The Rankakee facility, Roper Company,

indicated that it could switch

from

using natural gas to Illinois

coal,

saving approximately

$134,000

per year.

No relaxed limit is proposed for existing fuel combustion

sources located in the

St. Louis MMA,

so no economic consequences

were considered by the ENR study.

In adopting the two relaxed standards, total cost fuel

savings

for the facilities considered

is

estimated

at

$4,972,000.

If the conversion costs,

i.e., the

stack

extension costs,

are

considered,

the net savings

is

estimated

at

$4,612,000.

As noted

above,

relaxing the emission limits

will only moderately increase

usage

of Illinois

coal by

approximately 0.35

of the current annual

production.

Consequently,

secondary

impacts

on

the Illinois coal

industry were determined to be

modest.

An additional

$6 to $7.4

million per annum

will be

generated,

and

seventy to ninety

additional new jobs created.

Using a

regional economic theory

previously developed by ENR, the authors extrapolated the effect

of the estimated annual increase to determine the overall effect

on the State’s gross product.

Assuming that an income multiplier

of two was reasonable for small

regions, the $6 to $7.4 million

generated could possibly boost income in Illinois

by

$12 to $14.8

million,

The study considered whether increased use of Illinois coal

could disrupt the residual

fuel oil market.

It concluded that

such a possibility was unlikely.

Not

only is

the number of

sources

switching

from

out—of—state coal

to

domestic

coal few,

but

since

the

supply

of Illinois coal

is subject to the same

51-247

---

20

uncertainty as outofstate coal,

it is likely that they will

have

to

continue

maintaining

reserves

of

fuel

oil,

Even

if

such

an

impact

was

to

occur, the economic ramification would be minimal

since it would be a transfer of income rather than a direct

loss.

In

studying

the

effects

of

the

proposal

for

the process

emission

sources,

estimates

for

control

costs

or

cost savings

were

not

developed.

The

revisions

of

the

present

standard

are

intended only to more accurately reflect what is actually

being

emitted; no additional control

is

envisioned

by

the

amendments.

The

study

did

note

that

in

modifying

the

existing

rules,

the

margin of operating error at the affected facilities is reduced,

which has possible economic ramifications,

The study also

concluded that offsetting credits possibly envisioned by the

affected facilities were eliminated.

The economic impact study also examined the costs to the

health and welfare of persons and property.

A

cost

of

$1,032 to

$2,434

million

per

year

was

estimated.

In

proposing these amend-

ments, the Board recognizes that a certain segment of the public

is rendered less protection from sulfur dioxide,

and

that

property is possibly subjected to increased deterioration froni

sulfur dioxide,

However, the relaxations proposed are limited

primarily to the Peoria MMA, and

modeling

for

that locality has

adequately demonstrated that downwash and atmospheric loading

problems should not occur.

The

remaining

amendments

should

not cause

any increase

in

sulfur dioxide emissions, but rather more accurately reflect

the

actual

emissions

from

process

sources,

These

should therefore

not cause any impact on the health and welfare of the people

of

Illinois,

Hopefully,

the

proposed

amendments

suffice

to

enhance

the use of Illinois coal to the greatest extent

possible,

while

attainment of the NAAQS for sulfur dioxide

is

furthered

statewide.

This Opinion supports the rule

adopted

pursuant to the

Attached Order,

J.

Dumelle and N.

Werner

concurred,

I,

Christan

L.

Moffett,

Clerk

of

the

Illinois

Pollution

Control Bo~d,hereby certify that

the

above

Opinion

was

adopted

on

the

4

day

of

~

1982 by a

vote

of

~

Christan L. Mo f~ ~ Clerk

Illinois Pollution~ControlBoard

51-248