ILLINOIS POLLUTION CONTROL BOARD
December 30,
1982
IN THE MATTER OF:
SULFUR DIOXIDE EMISSION
)
R80—22
LIMITATIONS:
RULE 204
)
OF CHAPTER
2
)
Proposed Opinion.
Second Notice0
OPINION 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—l5 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
on December
17,
1981.
R78—14 was an inquiry concerning Rule
204(c)(l)(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 ()uality
Standards program,
which would enhance the use of Illinois coal.
(Ill.
Rev.
Stat.
1981,
ch.
111½,
par. 1009.2).
On December
19,
1980 the Board docketed the Agency’s proposal
to amend Rules
204(c)(1)(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,
ENR Document No.
82/il, 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
is granted and the comments filed
50-217
2
by Winnetka on July 30,
1982 are 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 Ill.
Rev.
Stat.
1981,
ch.
127, par, 1005,01(a).
Since
such a hearing would inevitably delay the remainder of this rule-
making, two dockets were established by the Board on October
14,
1982.
Winnetka’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.
However, Granite City Steel
has since agreed to waive its hearing request, if the amendatory
language submitted by the Agency on December
3,
1982 is incorpo-
rated into the rules proposed for Second Notice,
Emission limitations for sulfur emitting sources were among
the first air regulations promulgated by the Board in 1972.
Since then the rules
for fuel combustion 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.
However,
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 history of the
Board’s regulations for sulfur dioxide
is lengthy.
Therefore,
a
brief summary precedes the analysis of the rules.
HISTORY
As stated 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.
50-218
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 so 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,
but 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.
______
___________
v.
Pollution Control Board,
25 Iii.
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~srecord
was insufficient as to whether simultaneous ~~iiance
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 Agency’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 R7l-23,
R74—2 and R75—5 and held two additional public hearings.
It
should be noted that just prior to the Supreme Court’s decision
the Environmental Protection Act was amended to require
1)
economic impact studies
(EcIS)
and hearings in future rulemakings
and 2) adoption of regulations by the Board prescribing conditions
for sulfur emission sources to use intermittent control systems
(ICS).
The Supreme Court’s
decision
acknowledged the ICS amendment,
but 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 consolidated record with its “wealth of information” was pre-
pared by Marder
& Associates,
On July
7,
1977 the Board validated
the remanded rules,
after reviewing the pertinent information in
the record and considering the issues identified by the Courts.
27 PCB 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,
50-219
4
and not an
analysis
of the merits of the
information.
Neverthe-
less, the
validation
of the rules
was
vacated.
Ashland_Chemical
Company v.
Pollution
Control
Board,
64 Ill,
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).
Both
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
hearings had
not
been complied with,
Validation
having
failed,
the Board instituted inquiry pro-
ceedings into the
remanded
sulfur
dioxide rules
(R78-14) and the
particulate rule
(R78—16),
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—15
was
taken on
December
17,
1982
and is still pending
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 R74~2and 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—lG
(particulate
rule inquiry)
was 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-l,
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
in the three
MMA5 was originally adopted at
1,8 pounds per mil-
lion British
thermal units
(lb/mBtu),
4 PCB 298,
Compliance
with this and the other
limitations
concurrently adopted antici-
pated that air quality
statewide would
be better than the national
levels established in
1971,
The
National Ambient Air Quality
Standard (NAAQS)
for
sulfur dioxide
inc~udestwo primary standards:
an annual standard of
0,03 ppm
(80 ug/m
)
and a
24 hour standard
5
of 0.14 ppm
(365 ug/m~);and a secondary standard based on 3 hours
of 0.5 ppm (1300 ug/m
).
Since
1975 no violations of the annual
primary standard have been recorded in any
of
the
three
MMAs.
The short—term primary standard has been violated
in all three
MMAs, but not since
1977 in Chicago and Peoria.
Violations of
the
secondary standard have occurred in East
St.
Louis
and
Peoria.
Monitoring alone neither can provide
a plan
to achieve air
quality in the St.
Louis MMA, nor determine
the
extent
the limit
may be relaxed
in the other two MMAs and the NAAQS
still
be
maintained.
Forecasting of this type must be developed through
air quality analysis.
Therefore, regional air quality analyses,
including base and strategy analyses, were prepared for each of
the three MMAs.
The modeling format used for each of the three
MMA5 was basically the same,
as were the data requirements.
The
data information, on the other hand, were geographically
specific.
Each base analysis involved the
RAM,
a modeling
pro-
gram having both a rural and urban version,
The rural version
was modified
to conform with a second model,
the CRSTER, which
was used to account for isolated emission sources.
It should be noted that modeling
is intended to demonstrate
that should the worst
meteorological
circumstances and periods
of maximum
emissions coincide,
the
NAAQS would not be exceeded,
Except for the St. Louis MMA, modeling was done only
to evaluate
the short-term
standards,
i.e., the
24 hour and
3 hour standards.
This was
considered sufficient since the short—term standards
are
considered
more stringent than
the primary annual standard,
It
should be noted that attainment of the annual standard has already
been demonstrated
through monitoring.
The
emission inventories
contained the location, magnitude,
frequency, duration and relative contributions of the fuel com-
bustion emission sources
in each area.
Generally, only point
sources emitting more than 100 tons of sulfur dioxide per year
(T/yr)
were included,
and other area sources were accounted for
in the background levels.
The point sources were identified in
the Agency’s total
air system
(TAS), which was compiled initially
in 1974 and has since been continuously updated.
In calculating
the sources’
impacts on the model’s receptors,
all
sources were
assumed to operate at their maximum allowable rate,
which was
based on the remanded emission limits.
To determine the appropriate background levels
for each area
studied, localized monitoring data was matched with localized
meteorological data for the same base year,
As
it turned out,
the base year and the number of monitors used for each area
varied.
Since the sulfur dioxide monitors operate continuously,
hourly averages were achieved by averaging the data collected,
Lastly,
to accurately complete the air quality data, exclusion
angles were uniformly calculated
to eliminate sources upwind
from monitors from the background totals.
50-221
6
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
(CDM).
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
East
St. Louis and Granite City, the elevated sulfur dioxide
levels weremore
localized
and
source—oriented.
The two sources
identified,
however, were
process
sources
as opposed
to
fuel com-
bustion
sources.
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
50-222
7
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 he
discussed
later
in this Opinion.
Peoria Major Metropolitan Area
Neither the
modeling done in 1978 nor
recent monitoring
indicates violation of the annual standards in the Peoria MMA.
Thus, only short—term analyses were considered, on the assumption
that short—term standards are more restrictive than
the annual
standards 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 limitatjon
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
lh/
mBtu 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 emissions were used
in the base analysis,
it is possible that violations of the primary short—term standard
would not be predicted.
Furthermore,
if these limitations were
in place and enforceable, the base analysis would no longer indi-
cate
violations
of any standards, so relaxation of the 1.8
lb/mBtu
limit can be considered for 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
as
discussed 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.)
50-223
8
The
second strategy
analysis studied
relaxations of
the
emission
limit for small sources
in the Peoria MMA,
(R.
192.)
The RAM
(urban)
and the MPTER models were used.
The
MPTER is a
disper-
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/mBtu emission
limit,
a modified
receptor
network,
and five
years
of meteoro-
logical data, the
modeled impacts
for all urban
and
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 with
capacities greater
than
250
ml3tu
were.
(R,
192,)
Violations of the short-term standards were
predicted.
(R.
194.)
Yet another culpability analysis was per-
formed.
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 hack
methodology,
emission
limits
of
1,0
lb/
mBtu
for
the
Caterpillar
East
Peoria
Plant
and
1.6
lb/
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/mBtu for industrial boilers with
a generating capacity of less than 250 mBtu.
(R.
195—196.)
It 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
(now Pekin
Energy, Inc.),
and Caterpillar
sources
already equipped with FGDs.
During the merit segment of the June
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/mBtu,
and CPC
International boiler (rated at 330 mBtu) assessed at 5.5 lb/mBtu,
The Sherex boiler was modeled at an assumed stack height of 200
feet, which would allow Sherex to emit u~pto 5,5 lb/mBtu without
causing NAAQS violations due to the Mapleton bluffs.
This
50-224
9
analysis
indicated that emission limits
for the Caterpillar
Mapleton and East Peoria facilities must be further reduced to
assure compliance with the NAAQS.
An emission limit of 0.8
lb/mBtu
at the Mapleton facility and Li lb/mBtu at the East
Peoria facility would eliminate any possibility of air quality
violations
Throughout
the
proceedings,
the
four
Peoria
Caterpillar
sources were a subject of controversy.
At first a limit for the
Mapleton
sources was proposed.
It was later rescinded because
they
were
considered to be new sources and subject to regulation
for the
same
not yet proposed by the Agency.
(R.
98.)
Further-
more,
boilers
4
and
5 at this facility were initially neither
included in the
TAS inventory because
they were under construction
during
this
rulemaking
(R.
176),
nor
part
of
the
modeling
until
the
final
analysis.
Boilers
4
and
5
of the
Mossville facility,
although also new sources, were included in the inventory and in
the modeling
(R.
176, pg.
12,
Ex.
3),
Initially,
a limit of 1.6
lbs/mBtu was proposed for this facility, but later
modeling
indi-
cated that emissions up to 1.8 lbs/mBtu would not jeopardize air
quality,
(R.
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 ibs/mBtu was possible without
causing problems, assuming no new sources were constructed in the
vicinity.
(R. 125,)
As
for
the East Peoria faci1ity~s
sources,
1,0
lbs/mBtu was
originally proposed and later rolled back to 1.1
lbs/mBtu.
(R.
208,
571,)
Throughout the rulemaking the Agency
argued that the limits proposed for the Caterpillar sources were
its
actual emissions after control with the FGDs and that Cater-
pillar was already using Illinois coal.
Based on this,
site—
specific limits were proposed for three of Caterpi11ar~sPeoria
facilities;
Mapleton was excluded
as being a new source,
Two
sources, Mossville and Morton, were limited to
1.8 lbs/mBtu,
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
(1) that it was being singled out for site—specific
rulemaking, and
(2) 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),
upon reconsideration,
these specific limits are deleted froi~
the proposed rules,
The Mossville and Morton sources are still
restricted to the 1.8 lbs/mBtu emission limit, but now pursuant to
proposed Rule 204(d),
Secondly,
limiting the East Peoria sources
to 1.1
lhs/mBtu is deemed unnecessary.
If necessary,
this limit
can be imposed
and enforced pursuant to the Agency~spermitting au-
thority, as can
an
emission limit of less than
1.8 lbs/mBtu for
the
Mapleton sources.
In addition, Caterpillar~ssources are no
5O~225
10
longer
classified
as
new
and
existing
sources.
While
R80—22
was
under
consideration,
relaxed
limits
for
total
suspended
particu—
lates emissions were granted for all sources equipped with FGDs.
(Amendments to Chapter
2:
Rule 203(g),
R79—ll,
October
8,
1981.)
Such
relief
was
necessary
due
to
the
difficulties these controlled
sources
have
in achieving simultaneous compliance with Rules
203(g)
and
204.
Therein
sources
were
not
distinguished
between
existing
and
new,
other
than sources equipped
with
scrubbers
as
of
the
effective
date
of
that
Order.
Caution
was
noted
that
such
indus-
trial
sources
may
become
subject
to
tJSEPA’s
new source performance
standard
when
and
if
promulgated
(Opinion
at
9).
The same caution
is again offered,
However, to now regulate these sources as other
than existing would be incongruous.
Lastly,
since site—specific
limits are not being imposed, Caterpillar
is free
to exercise the
exception procedure,
if
in the future it deems it desirable.
The proposed rules have been accordingly restructured.
Chicago Major Metropolitan Area
The air quality analyses for the Chicago MMA were prepared
late in 1981
and presented at the June
1,
1982 merit hearing
(Ex. 11).
The base analysis utilized the RAM (urban) for those
areas identified as urban,
the MPTER model
for those areas iden-
tified as rural, and the CRSTER model was later used
to demonstrate
the air quality near two isolated areas.
The meteorological data
for the models was provided by the Chicago Midway National Weather
Service and the Peoria National Weather Service provided the upper
air soundings.
The meteorological effects due to Lake Michigan
were not considered
since
(1)
no meteorological sites continuously
operate
near
the
Lake,
and
(2)
no readily available dispersion
modeling
is
available
to
take
the
Lake
effects
into
account.
The emission inventory included point sources considered
to have
significant impacts, that is greater than
100 T/year,
located in
Cook,
Lake,
Will,
McHenry, Kane and DuPage Counties.
The maximum
allowable emission rate was used throughout; this way the possible
violations of the NAAQS
could he identified,
with the additional
benefit that growth need not he specifically considered.
Unlike the analyses for the other two MNA5, the background
areas to be included
in the Chicago study had to be limited
because of the size and complexity of the geographic
locale.
Four areas were identified as needing background value deter-
mination: Will County,
Lake County,
southern Cook County and
northern Cook County.
In estimating these background levels,
actual data gathered at nine continuous sulfur dioxide monitors,
as recorded in
1976
and 1977,
was coupled with the hourly meteoro-
logical data for 1976 and 1977.
Downwind monitors were discounted
through the use of “exclusion angles.”
50-226
11
The
base
analysis
identified
violations of both short—term
standards.
For the 24 hour standard, four were predicted in
Cook County, and one
in Will County.
For the
3 hour standard,
three violations were predicted
in Cook County.
(R.
562.)
The
Chicago
MMA
culpability
analysis predicted that through-
out the Chicago
area
the
24
hour
and
the
3
hour
standards
would
be exceeded,
In Cook County ten sources were identified as signi-
ficantly contributing for five days studied in 1975.
One source
was identified
in Will County, which has been mothballed; there-
fore,
its actual emissions have been eliminated.
Similarly,
the
remaining sources identified
may not actually be contributing
emissions near the maximum allowable emission limits used
in the
model.
Therefore,
rather
than
making
a
blanket
determination
that
relaxation
is
not
permissible
in
these
areas,
it
should
be
realized
that
individually
these sources may be
able
to
prove
that increased emission rates may not jeopardize the NAAQS in
the surrounding vicinity.
In addition to the base and culpability analyses,
four
strategy analyses were conducted to determine which sources could
be 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 limitations.
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/ml3tu 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
50-227
12
candidates
for a relaxed emission limit of 5.5
lbs/mBtu.
These
emission
sources,
meteorological
data
from
1973
(the
“worst
case”
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
be
relaxed,
however,
the CRSTER model predicts significant violations of the short-term
standards, but no violation of the annual primary standard.
Relaxation
is
denied
at
this
time
because
the
CRSTER
model
did
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 McHenry 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—l5.
Conversions
by
sources
in
the
Peoria MMA and Kankakee and Mdllenry 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 MMA5, 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
50-228
13
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
l4,
1982 to ensure that
adoption
of
the
remainder would
not
be delayed.
As mentioned
above, two hearings
have been held,,
Docket
B
will
he
concluded
as
soon
as
transcripts
of the
same are received and the record
is
closed.
Aside from amending the rules for fuel
combustion sources
burning
solid fuel exclusively,
the formula for
those burning
combination of fuels is amended and a new
formula for steel mills
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
He.,
included a reference to
catalyst regenerators at petroleum re~in-
eries.
Since
this formula
is
applicable only to
steel
mills,
that
language
has been deleted.
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 amendment
will also insure that 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.
50-229
14
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.,
FGD5; existing processes designed
to remove sulfur compounds from petroleum and petrochemical pro-
cesses’
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 manufacturing process;
(2)
sodium
sulfite manufacturing process;
(3) secondary
lead smelting pro-
cess;
(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 (R.635).
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
50-230
15
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
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 Weilman-Lord 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, emission limits based on the fuel com-
bustion capabilities of process sources are proposed.
Three
categories of such sources are affected.
One is source specific;
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 0.70 lb/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 high-sulfur 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.
50-231
16
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
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)(l) 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).
50-232
17
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.
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
lh/mBtu limitation.
It should he
noted
that
three
of
the
five,
Celotex,
Bemis,
and
Sherex,
have
already
obtained
this
relief
pursuant
to
R77—l5.
All
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.
50-233
Pursuant
to R77-45,
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
coal
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 $l~060,000per 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 that would
not
be
technologically
feasible.
In allowing
a
maximum
emission
limit
of
5.5
lh/mBtu,
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
S499,00D
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 Kankakee 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 he generated,
and seventy to ninety
50-234
18
Pursuant
to
R77—15,
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 coal
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
that would not be technologically feasible.
In allowing a maximum
emission
limit
of
5.5
lb/mBtu,
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
lh/mBtu
limit
could
have
caused
aerodynamic
downwash,
which
would
result
in
air
quality
violations.
Based
on
the
proposed
relaxation
in
Mcflenry
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
Kankakee
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
50-235
19
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
mi 11ion.
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 cut—of—state coal
to domestic coal few,
but since the supply of Illinois coal is subject to
the same
uncertainty as out—of-state 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 emis-
sion 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
addi-
tional 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 from 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
rules
proposed
for
Second
Notice
in
the
Attached
Order.
Board Chairman Dumelle and Board
r’lemher Werner concurre~1.
I,
Christan L.
rloffett,
Clerk of the Illinois Pollution
Control Board, hereby certify that the. above Opinion ‘gas adopted
on the
~
day
of
‘~4e~i~
~
~
,
1982 by
a vote
of
~
(~j~
~
Christan
L. Moffë~?jClerk
Illinois
Pollutior~
~Control
Board
50-236
