ILLINOIS POLLUTION CONTROL BOARD
December 14, 1978
SOUTHERN ILLINOIS POWER COOPERATIVE,
Petitioner,
PCB 78—255
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF
THE
BOARD
(by Dr. Satcheil)
This matter comes before the Board upon a petition filed on
September
18,
1978
by
Southern Illinois Power Cooperative
(SIPC)
requesting a variance from
Rule 204(a) (1)
of the Chapter
2:
Air
Pollution Control Regulations
(Chapter
2) until December
31,
1978.
An amended petition was filed on October 19,
1978.
The Environ-
mental Protection Agency
(Agency)
filed
its recommendation on
November
6,
1978.
No hearing was held.
SIPC is
a public utility and operates three identical
cyclone-fired boilers,
rated at 33 megawatts each.
These boilers
exhaust through two stacks, each 210 feet tall.
Units
1 and
2
exhaust through stack number
1 and Unit number
3 exhausts through
stack number
2.
Unit number
4 is
a cyclone-fired boiler with
a
designed generating capacity of 175 megawatts which will exhaust
through
a stack 400 feet tall.
It
is Unit number
4
for which
a variance is sought.
This
unit has an SO2 scrubber which will bring the emissions
of the unit
into compliance;
however,
tile power wiring,
control wiring and
instrumentation are not yet convoletelv installed and the scrubber
is presently inoperable.
These components were originally scheduled
to be completed July
1,
1978 when the boiler commenced operations
and are now expected to be installed and complete by December
1,
1978.
The delay was because the contractor installed wiring with
insufficient
insulation and consequently had to reorder and rewire
the unit.
There was also
a delay in obtaining rubber coated fiber
pipes
from the factory.
The pipes leaked when pressure tested and
had to he remanufactured.
Petitioner currently forecasts its peak winter power demands
at 196 megawatts for 1978.
Without the fourth qeneratincr unit the
available capacity is 140 MW.
Petitioner~sUnits
1,
2 and
3 can
deliver 105
MW
and
35
MW
peaking power is available from South
Eastern Power Association
(SEPA)
Petitioner also has a contract
with Big Rivers Rural Electric Corporation for 100 MW from September
30,
1978 through September 15,
1979.
Thus to meet its own needs and
32—275
--2—
its contract obligations Petitioner will need to obtain the extra
megawatts
from Unit number
4.
Petitioner thus claims that compli-
ance with Rule 204 will prevent the use of Unit number
4 and would
impose an arbitrary and unreasonable hardship on Petitioner.
The SIPC facility
is located on the Lake of Eqypt, approxi-
mately eight miles south of Marion,
Illinois.
Marion has a popu-
lations
of approximately 12,000 and
is the major population center
of Williamson County.
The nearest permanent residences near the
facility are located at
a distance from one-fourth to one—half
mile from the plant.
The nearest ambient air quality reporting station monitoring
sulfur dioxide
levels is located at 2209 West Main Street in Marion,
Illinois, approximately eight miles north of
the
facility.
The 1977
Annual Air Quality Report indicates no violation of the primary or
secondary standards
for ambient air levels of SO2.
The hiqhest
3—hour average was recorded as
0.201 ppm as compared to the secondary
standard of
0.5 ppm.
The annual arithmetic mean was indicated as
0.014 ppm as compared to the primary standard of 0.03 ppm, and no
violations
of the primary standard 24—hour average in excess of
0.14 ppm were recorded.
At the time the recommendation was filed
the Agency had received no objections to the qrant of the variance.
The Agency does believe that SO2 emissions
from Unit number
4
in
combination with SIPC’s three existing units could cause violations
of the 24-hour SO~air quality standard of 0.14 ppm and the 3-hour
secondary standard of 0.5 ppm.
The possibility of such violations
could be minimized through continuous monitoring
of loads and
resulting boiler operations.
The Petitioner’s Unit number
4 is classified as a new source
and the facility is located in an attainment area for SO2.
Mod-
eling was done by the Agency’s Air Resources Analysis Section for
Unit number
4 and by Burns
& McDonnell Engineering Company, Pet-
itioner’s consultant.
The Agency’s conclusion was that the
modeling revealed no apparent future violations of the primary and
secondary standards
as long as
the .802 scrubbers performed to design
specifications.
The Agency’s study was conducted using maximum
boiler operations and worst case fuel.
If the scrubber is bypassed,
the dispersion characteristics
of emissions from Unit number
4 may
be somewhat improved because of the increased temperature of the
exhaust gases.
Petitioner’s
study reinforces the Agency’s conclu-
sions.
The Board will grant Petitioner’s requested variance subject
to conditions
in order to meet the requirements of Section 35 of
the Enivronmental Protection Act and Section
113(d)
of the Federal
Clean Air Act.
The Board finds that Petitioner
is currently unable
32—276
—3—
to comply with the SO7 standards and would suffer an arbitrary
and unreasonable hardship if denied the variance.
Environmental
damage is unlikely while Petitioner would suffer financial hard-
ship.
Compliance will he met by December 31,
1978.
This
Opinion constitutes the Board’s findinqs of fact and
conclusions of law in this matter.
ORDER
It
is the Order of the Pollution Control Board that Southern
Illinois Power Cooperative is granted
a variance from Rule 204
(a) (1)
of the Chapter
2:
Air Pollution Control Regulations for
its steam electric generating Unit number
4 until December
31,
1978 subject to the following conditions:
1.
That SIPCO utilizes its 175 megawatt unit
(Unit number
4)
to its capacity in conjunction with the maximum obtain-
able power from its
35 megawatt tie in line before
commencing operation of any one of its existing
33
megawatt units.
The remaining units will be operated
only to the extent of supplying the system’s specific
power needs.
2.
If at any time during the period of variance, the
Marion air sampling station indicates a violation of
the 24—hour sulfur dioxide air quality standard, or
the 3-hour secondary sulfur dioxide air quality
standard,
the Petitioner shall restrict or reduce
its total sulfur dioxide emission rate as soon as
possible.
3.
The Petitioner shall submit monthly reports
to the
Agency summarizing the operation
of all power pro-
ducing units at its Lake of Egypt facility and the
amount of power received through the
35 megawatt tie
in line for each day of operation.
The report should
also indicate the status of completion of construction
of the SO2 scrubber for Unit number
4.
4.
Within thirty days
of the granting of the variance, the
Petitioner should make application for an Operating
Permit from the Agency for the generating Unit number
4.
32—27 7
—4—
5.
Within thirty days of commencement of scrubber
operations,
the particulate matter concentrations
in the effluent stream should be measured by an
approved independent testing service.
The measure-
ments to be conducted using the procedures described
in the “Stack Sampling Manual Methods and Procedures,”
as filed by the Agency, pursuant to PCB Regulations,
Chapter
2, Part
I, Rule 106(h), with the Secretary
of
State’s Office on June 16, 1975 and revised from time
to time.
The results of these tests, in triplicate,
should be forwarded to the Agency’s Regional Office
immediately after the test results are compiled and
finalized.
The address of the Agency’s Regional
Office
is:
Illinois Environmental Protection Agency,
Division of Air Pollution Control,
ll5A West Main
Street, Collinsville, Illinois 62234.
6.
The Agency should be allowed to witness the tests and
should be notified a minimum of thirty days prior to
the expected date of the tests, and further notification
of a minimum of five working days prior to the test of
the exact date,
time and place that the test will he
performed.
7.
Within thirty days
of commencement of scrubber operation,
the sulfur dioxide concentration in the effluent stream
shall be measured, using the procedures described in
Rule 204(g) (1)
of Chapter
2 of the Illinois Air Pollution
Control Regulations,
by an approved independent testing
service.
The results
of these tests should be forwarded
in triplicate
to the Agency’s Collinsville Office
(see
address above)
immediately after the test results are
compiled and finalized.
The Agency should also be
allowed to witness these tests and should be notified
a minimum of thirty days prior
to the expected date of
these tests and further notified a minimum of five
working days prior
to the test of the exact date,
time
and place of the tests.
8.
The Petitioner shall, within forty—five days of the date
of this Order,
execute and send to John D.
Williams,
Technical Advisor, Enforcement Programs, Illinois Environ-
mental Protection Agency, 2200 Churchill Road, Springfield,
Illinois
62706, a Certification of Acceptance of this
variance
by which it agrees to be bound by its terms and
conditions.
This forty-five day period shall be held in
abeyance for any period
in which this matter is appealed.
The form of said Certification shall be as follows:
32—278
—5—
CERTIFICATION
I,
(We)
,
______________________________,
having read and
fully understanding the Order of the Illinois Pollution Control
Board in PCB 78—255 hereby accept said Order and agree to be
bound by all terms and conditions
thereof.
TITLE
DATE
Final
compliance must be achieved by December 31,
1978 or the
Petitioner may be subject to noncompliance penalties under
Section 120 of the Clean Air Act as amended August,
1977.
I,
Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify the ahoy
Opini
n and Order were
adtopted on the
~
—
day of
______________
1978 by a
vote of
~
Christan
L. Mof
,
Clerk
Illinois Polluti
Control Board
32—279