ILLINOIS POLLUTION CONTROL BOARD

February 15,

1979

IN THE MATTER OF:

R75—5

PROPOSED

A!~ENDMENTS

TO CHAPTER

)

R74’-2

2, PART II, SULFUR DIOXIDE

)

CONSOLIDATED

EMISSIONS.

CONCURRING OPINION

(by Mr.

Dumelle):

My reason for concurring in this Opinion is my preference for

retention of a simple numerical pounds—per—million BTU emission limit

for large sources.

Such

a numerical standard has the advantages

of

saving time and money for affected parties and of being easily under-

stood.

In addition, such a standard would tend to keep in use the inex-

pensive procedure of coal washing to remove large amounts of sulfur.

It would also prevent large increases in sulfur dioxide emissions.

The Boardvs initial proposal in this proceeding contained my

recommendation of a 6.8 lbs./MBTU to replace the old 6.0 lbs./MBTU

rule. A later Board proposal dropped the 6.8 rule proposal completely

but retained it for small sources. At that time

I suggested an even

looser 7.5 lbs./MBTU level for large sources but it was not accepted

by the Board.

Rule

204(e) (3)

as now adopted provides for alternative site-

specific determinations before the Board. These case—by—case pro-

ceedings

are time consuming and require expensive meteorological ex-

perts. A

rule of the Board should distill from a proceeding the common

attributes for a class of sources. To adopt a case—by—case approach

is to say that this cannot be done.

This rule revision contains many points with which

I fully agree.

The “grandfatherinq

ins’ of sources through retention of old Rule 204(e)

as Rule 204(e) (2)

is important.

If power companies have entered into

long term coal supply contracts in reliance upon the old rule they

should not now have to change.

The new formula, Rule 204(e) (1),

is clearly an improvement over

what is now 204(e) (2). The Board should always update the scientific

basis for a regulation when better information becomes available.

The non—enactment of

a sulfur dioxide limit to a site

(the

‘~cap”

proposal)

is important.

Some power plant sites may have been developed

with cooling lakes or coal handling facilities designed for additional

power generating capacity. These plants should not now be prevented

from expansion as planned by a

Itcap~t rule.

:32—593

---

—2—

This proceeding generally loosens

a regulation adopted by the

Board in 1972. At that time much of the Board’s information was

modeled from 1969 data. A re-examination of the need and basis

of a

regulation should be done periodically in order that current infor-

mation is considered.

I agree with this revision and for the reasons

noted above concur in it

1~

/

j

/

I•

~‘.‘

/

Jacob

D.

Duinelle

I, Christan

L. Moffett, Clerk of the Illinois Pollution Control

Board do hereby certify th

t

a1~,~e above Concurring Opinion was sub-

_________

1979

mitted this ~

day

~

Illinois Pollution Cc54~ol

32—594