ILLINOIS POLLUTION

CONTROL BOARD

October

14,

1982

IN

THE

MATTER OF~

CITY OF ROCHELLE~:

)

R78—15

SITE

SPECIFIC

LIMJtTRTION FOR

TOTAL

SUSPENDED

PARTICULATE MATTER

Proposed

Rule~

First

Notice

PROPOSED

OPINION AND ORDER OF THE BOARD

(by I~

Goodman):

On November

13

1978 the City of Rochelle

(Rochelle)

filed

a petition to

amend

Rule

203(g~(1)

of Chapter

2:

Air Pollution

to include a

part::culate emission

limitation

for the emissions

exhausted

from

the stack at

its

Municipal

Steam Power Plant,

located on

South

Main

Street.~

Specifically, Rocheile requested

a limitation

of 0~

6

pounds

per

million British thermal units

(lbs/mBtu)

of

actual

heat input.

When Rochelie

proposed

amending Rule 203(g)(1),

adoption

of the same

had been

vacated

along

with Rule 204(c)(1)

(Common

wealth Edison

v~PCB,

62 IiL2d

494,

343 N,E.2d

549 and Ashland

Chemical v~

PCB~ 64 IlL

App~3d

169,

381 N~E~,2d56)~ Therefore,

once docketed

this proposal

was

consolidated for hearing with

R78—16,

a

Board

inquiry reviewing

the

rules

on total

suspended

particulates

(TSP)~

On August

21,

1980 R78—16 was dismissed.

Other

than

this

proposal

by

Rochelle,

no

steps

were

taken

to

adopt

particulate

limitations

for

fuel

combustion

sources

until

R82-1

was

instituted by :~bCEoard~ Since

further

action

in

R82—1

awaits

receipt

of

an economic impact study,

Rochelle’s

source

is

not currently

subject to a specific TSP emission

limitation.

Consolidated

with R77~15,

R78-~14,R78—16 and R78—17 for

hearing,

R78~15

was discussed

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

entitled

“Economic

Impact

of

Sulfur

Dioxide

and

Particulate

Matter

Regulations

in

:E:Llinois,

R77~i5~,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 (Agency)

permitting

policy in Light

of the Illinois

Supreme Court decision

49~~

185

---

2

vacating

Rule 203(g)(1)~

This policy,

as set

out

in “Guidelines

for

the

Performance of Air

Quality Impact Analyses

to

be

Used

in

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,

p,

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

be

an average emission rate of 0.418 lbs/mBtu or

less.

Since

the

maximum rate allowable based on Rule 203(g)(1)(B)

is

0.18

lbs/mBtu,

Rocheile

is

petitioning

for a site—specific

rate

of

0.60

lbs/mBtu~

The city~splant 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 of

heat input

CR.

376)~ Particulate matter

emissions are

presently

controlled through the use of mechanical

collectors

(multiclones)

having

90

efficiency, taken together,

when

the

l~oilers

are

operating at full loads

CR.

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

validity of such extrapolation

CR. 400—405,

415—416).

Using

the Point Source Diffusion Model

(PSDM)

Rochelle

further

determined the magnitude and 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

concentrations,

Sequential calculations

were made for

256 receptors

located at various points ranging from

0.5 to 25.0

kilometers

from the stack

CR.

387—388),

This

modeling

indicated

that

maximum TSP for the 24-hoar standard contributed

by the

Rochelle

facility is 1~.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

3

calculated

annual contribution of the Rochelle plant

is

2.3 9/m

,

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

CR.

388~389),

49~186

---

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,

arid 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

ESPs 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 DeKalb

and Mayfield

Townships,

have been

proposed for

redesignation

by the

Agency in January

1982.

Since

DeKaib 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 Rochell&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

Sam

lea

~

Sam les

Mean

Violations

~lS03

2603

75

60

ug/m

ug/m

ug/m

ug/m

Total

(Primary)

(Secondary)

1

2

3

4

(Primary)

(Secondary)

*1977

43

2

1

435

17’)

103

91

56

0

0

*1978

34

0

168

111

111

110

+

*j979

26

0

0

133

98

96

92

+

+

**1979

14

0

0

95

93

78

66

+

+

**1980

29

0

0

92

88

84

81

+

+

**1981

54

0

0

129

125

109

98

53

0

0

*

200 S.

4th

St.

**

650 N. 1st St.

+

lns~fficientdata to

determine

annual geometric mean

49487

---

4

Unfortunately,

the

statistical data for three of the five years

is insufficient to establish a geometric mean for eight consecu-

tive 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 recorded, Petitioner 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 0.6 lbs/mBtu, the combined data from the stack tests,

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 receiving an emission limit more relaxed than

that presumably required by other such sources, the Petitioner

would consume a portion of the Prevention of Significant Deter-

minations

(PSD) increments.

Therefore, Rochelle was directed

by the hearing officer to submit its estimation of the amount

of PSD increments to 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 facilities actual emission

rate.

Since the Rochelle source can only impact Class

II areas

and possibly the non—attainment area of DeKalb Township, only

those PSD limitations are applica~le.

The modeling predicted

a ma~imum24 average of 15.6 ug/m

and an annual average of 2.3

ug/m

,

whi~hare

well

w~thinthe corresponding Class II standards

of 37 ug/m3 and

19 ug/rn

.

The standards

for

n9—attainment areas

are 5 ug/m

for the 24~-houraverage, and

1 ug/m

for the annual

average.

TSP concentrations pr~dicted

13

kilometers east of the

sourse are between 1.3—2,2 ug/m

for the 24—hour average and 0.1

ug/m

for the annual average——again concentrations below the

allowable standards

(Ex. 35).

Furthermore, 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.

The Board

finds the evidence provided by Rochelle’s modeling

and monitoring sufficient,

despite the questionable practice of

extrapolating the stack tests 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.

The Board

is 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, and so the limitation of 0.60 lbs/mBtu is granted.

49-188

---

ORDER

The

following

language

is

hereby

proposed

for

adoption

into

Chapter

2:

Air

Pollution,

Part

II:

RULE 203:

Particulate Emission Standards and Limitations

(a)—(f)

Unchanged.

(g)

Fuel

Combustion Emission Sources

(1)

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)(1), any existing

fuel combustion

emission source using solid fuel exclusively, and

meeting the following conditions, may emit up to,

but not exceed, the

limits set out.

(i)

As of April

14,

1972 the emission source has

an emission rate based on original design or

equipment performance test conditions, which-

ever is stricter, which is less than 0.2 lbs/

mBtu of actual heat input, and the emission

control of such source is not 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

of actual

heat input

or

(ii)

As of April

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 to degrade more than

0.05 lbs/mBtu from original design or equip-

ment performance test conditions whichever

is stricter, the rate of emission shall not

exceed 0.2 lbs/mBtu

of actual

heat input

or

(iii)

As of

(the effective date of this Rule)

the rate of emissions from Boilers #1 and

#2

located at the Rochelle Municipal Stream Power

Plant,

South Main Street, City of Rochelle in

Ogle County,

Illinois shall not exceed 0.6

49-189

---

Board Chairman Dumelle and Board Member Werner concurred.

I, Christan

L.

Moffett, Clerk of the Illinois Pollution

Control board, hereb~er~~~that

the above Order was adopt~don

the

/‘/~

day of

___________________

______

_____

__________________

1982 by a vote of

~

~

Christan L.

Moffet’t

Illinois Pollution

o trol Board