ILLINOIS POLLUTION CONTROL BOARD
October
27,
1982
THE B F GOODRICH COMPANY,
Petitioner,
v.
)
PCB 82—88
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
MR.
THOMAS
F. HARRISON, ASSISTANT CORPORATE COUNSEL, APPEARED ON
BEHALF OF PETITIONER.
MS. MARY V.
REHMAN, STAFF ATTORNEY, APPEARED ON BEHALF
OF RESPONDENT.
OPINION AND ORDER OF THE BOARD (by
I.
G.
Goodman):
This matter is before the Board upon the petition of
B F
Goodrich Company
(Goodrich)
for variance from Rule 206(a)
of
Chapter
2:
Air Pollution for its General Chemical Plant located
in Henry, Marshall County,
Illinois.
Hearing
was held on
September
17,
1982 in this matter.
In addition to the parties,
one interested citizen took part.
Goodrich proposes to design, build and operate
a circu-
lating Fluidized Bed Combustion
(FBC) boiler,
an innovative
technology which allows the burning of a high—sulfur Illinois
coal while meeting the Board’s sulfur dioxide standards without
use of flue gas desulfurization.
The proposed installation
would be the first industrial application of FBC technology
in the United States.
Goodrich’s facility currently utilizes
two dual fuel—fired boilers burning both gas and oil with a
total generating capacity of 200,000 lb/hr of steam.
The pro-
posed FBC boiler would replace both existing boilers which would
he retained for stand—by and emergency use only.
Goodrich pro-
poses to install the FBC boiler to allow the use of less expensive
coal and to decrease dependence on the more expensive gas and oil.
In the FBC process,
coal
is burned
in the presence of lime-
stone
in a bed of small particles fluidized (suspended) by air.
Sulfur dioxide, produced by the combustion of the sulfur in the
coal,
reacts with calcium oxide produced from the limestone to
form calcium sulfate
(gypsum).
The gypsum, along with coal ash
and unreacted limestone, comes off as a dry particulate residue.
This dry residue is much more readily disposed of than the sludge
which characterizes the residue from most flue gas desulfurizaLiori
49.223
2
units.
The resultant flue gas from the FBC process meets environ-
mental standards
for sulfur dioxide and nitrogen oxide as well
as standards for Total Suspended Particulates when placed
in
tandem with appropriate dust collection equipment.
However,
actual
operating experience indicates that the inherent design
characteristics of the FBC boiler are such that the requirements
of Rule
206(a)9 carbon monoxide,
may not be achieved.
Rule 206(a) sets a 200 ppm limit on emission of carbon
monoxide, corrected to 50
excess
air, from any fuel combustion
source with actual heat input of greater than
10 million btu/hr.
Actual plant operation in Finland indicates that Goodrich can
expect a CO emission from the proposed boiler of approximately
400 ppm.
On September 15,
1982 Goodrich and the Illinois Envi-
ronmental Protection Agency (Agency)
filed a Stipulation of Facts
before the Board.
The Stipulation indicates that Goodrich con-
ducted an air quality impact analysis
of emissions from the
proposed new boiler,
the results
of which show the resulting
Co level to he at a range considered de minimus by the U.S.
Environmental Protection Agency for purposes of the Prevention
of Significant Deterioration program.
Based on this analysis,
it appears that although the FBC boiler will emit CO in concen-
trations greater than allowed by Rule 206(a), there
will be no
interference with the attainment and maintenance of the National
Ambient
Air
Quality Standard for CO and no adverse impact on
community health or on plant or animal
life may be expected from
the
proposed operation of the FBC boiler at the Goodrich facility.
It
is the opinion of the Agency that the proposed variance will
be fully consistent with all applicable provisions of the Clean
Air Act and federal regulations.
It further stated that the
proposed variance will be acceptable as a formal revision of
the Illinois State Implementation Plan
(SIP)
since it has been
demonstrated that the CO emissions from the proposed boiler will
not interfere with the attainment and maintenance of the Ambient
Air Quality Standard and will he consistent with the Prevention
of Significant Deterioration provisions of
the
Clean Air Act.
Although the hardship claimed by Goodrich
if the proposed
variance
is not granted is primarily economic, the Board notes a
number of environmental and economic benefits which will accrue
to the State should the variance be granted.
Sludge generated
from the current, most widely utilized flue gas desulfurization
technology poses a significant environmental problem in its dis-
posal.
The proposed FBC system produces
a product which is sig-
nificantly less difficult to handle from the standpoint of dis-
posal.
Since the control of the sulfur and nitrogen oxides are
inherent in the combustion process itself, there
is little possi-
bility of excursion in emissions
of these pollutants due to
breakdown of auxiliary equipment such as a flue gas desulfurization
unit.
The process creates
a market for both Illinois coal and
Illinois limestone, both in very great supply in the State.
In
addition, the process conserves oil
and gas.
49-224
3
The Agency recommends granting of the variance subject to
certain conditions.
Considering the lack of apparent environ—
rnentaj
hartn~ the great potential benefit accruing to the State
from this innovative process,
and the economic hardship on
Goodrich if the variance were not granted,
the Board agrees
with the Agency’s evaluation and shall grant the variance
requested.
The question of the future of the FBC process and
its relationship with the limitations of Rule 206(a)
will need
to be addressed after data from the proposed facility is avail-
able.
The Board shall therefore impose certain conditions on
the variance recognizing the need to evaluate the carbon monoxide
situation as it develops.
The concerned citizen who attended the hearing,
Bev Loser,
indicated concern with respect to the effect of carbon monoxide
on her small children since their home
is located in close prox-
imity to the Goodrich facility.
After listening to the testimony
presented at the hearing and asking questions,
Ms. Loser indi-
cated that she believed she understood the situtation and was
“fairly satisfied.”
This Opinion constitutes the findings of fact and conclusions
of law of the Board in this matter.
ORDER
The B F Goodrich Company is hereby granted variance from
Rule 206(a)
of Chapter
2:
Air Pollution for its General Chemical
Plant located in Henry, Marshall County,
Illinois subject
to the
following conditions:
1.
Carbon monoxide emissions from the Fluidized Bed Combustion
boiler shall not exceed 400 ppm.
2.
Variance is granted until October
1,
1987 or until the
facility is no longer subject to Rule 206(a), whichever
first occurs.
3.
The B
F Goodrich Company shall, within two years of com-
pletion of the facility,
submit a report to the Illinois
Environmental Protection Agency addressing carbon monoxide
emissions with respect to minimizing carbon monoxide emis-
sions and optimizing combustion efficiency and shall recom-
mend a carbon monoxide emission limitation which represents
best available control technology for Circulating Fluidized
Bed Combustion boilers.
4.
The
B F Goodrich Company shall
develop a program to study
the control of carbon monoxide
in Circulating Fluidized Bed
Combustion boilers and shall report the status of the program
to the Illinois Environmental Protection Agency annually.
49-225
4
5.
Within forty-five days of the date of this Order, Petitioner
shall execute and forward to the Illinois Environmental Pro-
tection Agency,
2200 Churchill Road, Springfield, Illinois
62706,
a Certificate of Acceptance and Agreement to be bound
to all terms and conditions of this variance.
This forty—
five day period shall be held in abeyance for any period
this matter is being appealed.
The form of the certificate
shall be as follows:
CERTIFICATE
I,
(We),
,
having read
the Order of the Illinois Pollution Control Board in PCB 82—88,
dated _________________________, understand and accept the said
Order, realizing that such acceptance renders all terms and con-
ditions thereto binding and enforceable.
Petitioner
By:
Authorized Agent
Title
Date
IT IS SO ORDERED.
Board Member Werner concurred.
I, Christan
L. Moffet, Clerk of the Illinois Pollution
Control Board, hereby qertify that t~eabove Opinion and Order
was adopte~4on the
~T~’
day of
~
,
1982 by a
vote of
~_c
L.
Illinois Pol
ol Board
49-226