ILLINOIS POLLUTION CONTROL BOARD
    January
    4,
    1979
    IN THE MATTER OF:
    PARTICULATE EMISSION
    )
    R77-5
    STANDARDS FOR COMBUSTION
    OF LOW CARBON WASTES
    )
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dumelle):
    This proceeding to amend Rule 203(e)
    of the Board’s Air
    Pollution Control Regulations was initiated by
    a Petition filed
    with the Board on March
    3,
    1977.
    The Petition was published
    in Environmental Register 4~l45dated April
    11, 1977.
    Hearings
    were held on August
    30,
    1977
    in Charleston, Illinois and October
    18,
    1978
    in Chicago.
    A document entitled An Economic Impact Study
    of Low Carbon Wastes
    (R77—5)
    (IIEQ Document 78/06)
    (Ex.
    L) was
    submitted to the Board pursuant to
    §6(d)
    of the Environmental
    Protection Act.
    Hearings on the document were held on July 28,
    1978
    in Streator,
    Illinois and August
    7,
    1978 in Chicago.
    At the first hearing the Petitioner, Addressograph-Multi-
    graph Corporation,
    presented an Amended Petition
    (Ex.
    A) which served
    as the basis
    for all subsequent proceedings.
    This Opinion references the record with roman numerals
    (RI-b,
    Rh—iS,
    etc.).
    This system was used because the page numbering
    was not continuous.
    The roman numerals refer to individual hearing
    transcripts.
    NEED FOR THE REGULATION
    Petitioner’s dilemma is best described on pages 12-17 of
    Exhibit L.
    Under the present Rule 203(e) (4) Petitioner must
    meet a particulate emission standard of 0.1 grains per standard
    cubic foot of effluent gases corrected to 12
    carbon dioxide.
    Exhibit
    2
    (summarized in Table
    1.1 on page
    13 of Ex.
    L)
    shows
    that as the percent of carbon dioxide in the exhaust gas decreases,
    the corrected particulate emissions increase.
    Since Petitioner’s
    exhaust gas averages
    0.0146
    carbon dioxide, corrected emissions
    are exaggerated by calculation to 74.25 grains per standard cubic
    foot.
    As an alternative Petitioner proposes a correction of 50
    excess air for new incinerators burning not more than 2000 pounds
    of waste per hour containing dry basis volume concentrations of
    less than 1.2
    carbon dioxide from the waste alone.
    The 2000 pound limitation includes Petitioner’s
    incinerator.
    The 1.2
    limitation represents ORSAT measurement limits
    (R..II-24).
    The Agency contends that Petitioner cannot comply with the
    32—40.3

    —2—
    present Rule
    203(e)
    because of the aqueous nature of its waste
    (R.III-63)
    .
    Mr. Moore testified that the 12
    carbon dioxide
    correction should be retained because
    it is appropriate for patho—
    gen burners cornbusting waste high in hydrogen
    (R.II—64).
    This
    conclusion conflicts with Exhibit E which states that a 50
    excess
    air correction would be sufficient for all incinerators.
    Since
    the record
    is limited
    to an analysis of Petitioner’s incinerator,
    and the request for relief is narrow, the Board will limit its
    decision to the relief requested.
    EFFECT ON AIR QUALITY
    Exhibits H,
    I, and K indicate that although this regulation
    would have statewide effect, Petitioner’s incinerator
    is the only
    known affected source.
    Particulate emissions from this source
    have been calculated at 1.163 pounds per hour
    (R.I-29).
    The
    nearest air monitoring
    site
    is
    50 miles away in Champaign and it
    shows compliance with the particulate air quality standard and
    no upward trend
    (R.II-22)
    .
    Chapter
    4, Section 4.1 of Exhibit L
    concludes that air quality within the vicinity of Petitioner’s
    incinerator is
    “.
    .
    .
    safely within the applicable air quality
    standards.”
    Complete elimination of Petitioner’s emissions would
    at most lower the local 24-hour air quality level by about 0.5
    micrograms per cubic meter and the annual level by a maximum of
    0.14 micrograms per cubic meter
    (p.66)
    .
    These effects can best be
    described as negligible.
    TECHNICAL FEASIBILITY AND ECONOMIC
    REASONABLENESS
    Exhibit F contains a copy of the ten feasibility studies
    which were done by Petitioner before
    it decided to install its
    present incinerator.
    All of the alternatives to the present system
    either had problems with the nature or the volume of the waste,
    were unreliable,
    or were not adaptable to the climate of the
    Charleston area.
    Chapter
    3 of Exhibit L estimates the costs for various
    control options which are assumed to be sufficient to result
    in
    compliance with the present Rule 203(e).
    Table 3.5 shows a range of
    total additional annual costs from $14,419
    to $137,280.
    Table
    5.1
    shows that all of these options greatly exceed a conservatively
    high estimate of benefits which would accrue from the reduced
    emissions.
    The
    range here was $6,717 per year to $129,578 per year.
    consequently, the Board concludes that adoption of this
    proposal will have no adverse economic impact on the people of
    the State of Illinois.
    This Opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    32—404

    —3—
    ORDER
    Rule 203(e) (4)
    of the Board’s Air Pollution Control
    Regulations
    is hereby amended by the addition of
    a new section
    which shall
    read as follows:
    (A)
    Rule
    203(e) (4)
    shall not apply to aqueous waste
    incinerators which, when corrected
    to 50 per cent
    excess air for combined fuel and charge incineration,
    produce stack gas containing carbon dioxide dry-basis
    volume concentrations of less than 1.2 per cent from the
    charge alone;
    if all the following conditions are met:
    (i)
    The emissions of particulate matter
    into the atmosphere from any such new
    or existing incinerator does not exceed
    0.1 grains per standard cubic
    foot,
    dry
    basis, when corrected to 50 per cent
    excess air for combined fuel and charge
    incineration.
    (ii)
    The waste charge to the incinerator does
    not exceed 2000 pounds per hour.
    IT
    IS SO ORDERED.
    Mr. Werner concurs.
    I, Christan
    L. Moffett,
    Clerk of the Illinois Pollution
    Control Board, hereb
    certify the above Opinion and Order were
    adopted on the ______________day of
    ,
    1979 by
    I??
    Christan L. Moffet ,~Q~erk
    Illinois Pollution ~~trol
    Board
    32—405

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