ILLINOIS POLLUTION CONTROL BOARD
    December 30,
    1982
    IN THE MATTER OF:
    )
    SULFUR DIOXIDE EMISSION
    )
    R80—22
    LIMITATIONS:
    RULE 204
    OF CEJAPTER
    2
    CONCURRING OPINION (by J.D. Dumelie and N.E. Werner):
    We concur in this proceeding and point out the failure of
    the Illinois Environmental Protection Agency (“Agency”)
    to ad-
    equately study possible
    looser sulfur dioxide limits
    in the
    Chicago area.
    The Agency is under a statutory duty to study this possibili-
    ty.
    Section 9.2 of the Environmental Protection Act
    is quite
    explicit about this duty.
    The Agency’s comments of July 14,
    1982
    (filed July 19,
    1982) indicate that setting emission limits
    for more than 40 coal burning sources using air dispersion modell.iny
    would
    be “mind—boggling” and could cost “well over $100,000” for
    computer time
    (pp.
    3—4).
    No notation appears that these funds were ever requested
    from the Illinois Department of Energy and Natural Resources
    which funds exactly these types of environmental
    arid energy
    studies.
    Furthermore,
    it is possible that cheaper and simpler
    “roll—back” modelling could be used.
    The Board Opinion itself
    lists two examples where the Agency used “rollback methodology”
    to compute recommended limits for two Caterpillar plants and the
    Sherex plant in the Peoria area
    (p.
    8).
    An examination of the air quality data in the Agency’s
    1980
    Annual
    Air
    Quality
    Report
    shows
    that
    the 24-hour primary
    standard is the limiting one.
    The second highest reading in 1980
    was 0.089 ppm at the Chicago Heights monitor.
    The standard
    is
    0.14 ppm.
    Thus the 0.089 ppm could rise about 57
    to reach
    0.14 ppm.
    If we use a 50
    increase to be conservative, the 1.8 lbs. sulfur
    dioxide standard could then be loosened to 2.7 lbs.
    Furthermore, the 1.8
    lbs.
    or the suggested 2.7 lbs.
    figures
    apply only to “existing” plants.
    New plants must meet
    a
    1.2 lbs.
    limit or tighter.
    Thus the Board could have provided for even
    looser levels in say 1987 and 1992 as
    “existing plants” get retired.
    The intent of Section 9.2 of the Act was to “enhance the use
    of Illinois coal” consistent with federal standards.
    We feel
    that the 1.8 lbs. sulfur dioxide emission limit in the Chicago
    area is unnecessarily tight.
    We agree with the July 16~ 1982
    50-249
    2
    and October 27,
    1982 comments of CPC International, Inc. which go
    to this subject and raise the possiblilty of a national “freeze”
    on sulfur dioxide emissions.
    A national
    “freeze” would perma-
    nently damage Illinois industry in the Chicago area.
    I, Christan L.
    Moffett, Clerk of the Illinois Pollution
    Control Board, hereby ,certify that tke above Concurring Opinion
    was filed on the
    _day
    of________________
    ___
    1983.
    • (1~
    —
    Christan L. Moff~tt~1~~
    Illinois Pollution C6ritrol Board
    rman
    50-250

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