ILLINOIS POLLUTION CONTROL BOARD

May

25,

1978

 THE MATTER OF:

R75—5

PROPOSED AMENDMENTS

 TO CHAPTER

)

 R74-2

2,

 PART II, SULFUR DIOXIDE

EMISSIONS

ORDER OF THE BOARD

 (by Mr. Goodman):

The Board hereby orders

 that the BoarcPs Memorandum concern-

ing the Proposed Final Draft Order in these proceedings be made

available for public inspection.

Mr.

 Young abstains.

Christan

Moffc~tt,

C~crk

the

Iii

inois

PoT intl

Control

Board,

hereby

certify

the

above

Order

was

adopted

the~~~~day

1978

vote

of~

4~Df~

Christan

Mof

 Clerk

Illinois Pollution Control Board

—

~45

I LLINOIS

POLLUTION

CONTROL

BOARD

R75—5, R74—2

SULFUR DIOXIDE EMISSIONS

MEMORANDUM

This

memorandum

intended

highlight

and

explain

the

differences between the Board’s recent

proposed

 Final Draft Order

in R75—5,

 Sulfur Dioxide Emissions,

and

the

 Agency’s January

6,

1978 Proposal.

 The memorandum is not intended

 to constitute the

Board’s final Opinion

 in this matter.

The original Agency proposal called

for

deletion

the

6.0

lbs./MMBTU standard of Rule 204(c) (1) (B) (1)

The

Agency contended

that the degree of sulfur reduction achieved

by

coal washing did

not support this limitation.

 This contention,

 however, was not

substantiated in the record.

 The Board has decided to retain

a

lbs./MMBTU standard but to loosen it slightly,

 which will greatly

increase the percentage of Illinois coal which can be burned with-

out washing.

 Hence,

 a new standard of 6.8

ibs./MMBTU

 is proposed.

Coal washing remains a viable technique

for

reducing

total

emis-

sions.

 Furthermore,

 later versions of the Agency’s proposal

included a provision intended to operate as a

cap

 on existing

emissions.

 The intent was to prevent unnecessary increases

in

emissions.

 There

 is no cap provision

in

the

 oroposed Order.

Retention of a lbs./MMBTU standard will thus act as

 a gross cap

rule on emissions.

The mass emission limitation of Rule 204(e) (1)

 remains

basically as it was

 in the Agency’s proposal with

a

 few editorial

changes.

 The 204(e) (1)

 formula represents

the

state of the art

and is generally an improvement over the existing Rule 204(e)

formula.

 The input parameters

 in the formal a

have

been

 converted

the

Enqi

i sh

 ( ionL/ound/second)

 sysLeru.

Air

 iddenduru

Lachecl

the

Order

contains

the

oriqinal

formula

in

the

metric

system.

‘rho

formula

proposed

for

public

comment

 in both

systems

that

the

Board

can

incorporate

the

final

regulation

whichever

the

public

prefers.

—

346

—2—

Since the Rule 204(e) (1)

 formula limits the quantity of SO2

emissions,

 the Rule

has

 been modified to specify that the opera-

ting conditions

 to be used in calculating the emission limit are

those which would produce maximum emissions.

 The Agency testi-

fied that it intended the weighting factor,

P

 (the percentage of

total emissions), to be determined under operating conditions

which would lead to maximum emissions.

 This intention has been

incorporated into the rule,

 and the Rule has been changed to

specify that stack gas exit velocity

(V)

 and stack gas temperature

(T)

 input parameters should also be determined under those condi-

tions.

 This definition of input parameters would take into account

normal variations in sulfur content of fuel,

 the use of pollution

control equipment, and boiler firing capacity.

Proposed Rule 204(e) (2) was devised so that sources that had

made a good faith effort and come into cOmpliancewith the exist-

ing Rule

 204(e)

 or a Board Order but would not be in compliance

with proposed 204 Ce) (1) would not be penalized.

 Such sources are

given their choice of the existing Rule 204(e)

 formula or the

proposed Rule 204(e)(l).

 A recent past date

 (April

1,

 1978) was

chosen as the date for compliance so that only sources which had

complied in good faith and not at the last minute

 in order to

receive a lower standard would be eligible.

 Furthermore,

the

phrase “during peak periods resulting from normal cyclical vari-

ations” has been used to describe the conditions under which a

source must be unable to comply with the Rule 204(e) (1)

 formula

in order to qualify for

 Ce) (2).

 (NOTE:

 The Proposed Final Draft

Order entered on May

11,

 1975, read “normal cyclical operations”;

the phrase should have been “normal cyclical variations”.)

 Recog-

nizing that firing rate and, consequently, emissions vary within

any given year for many sources,

 the Board has included this

phrase

 in order to exclude peak emissions that may occur due to a

process upset or other abnormal operating conditions or due to an

effort by a source to increase its emissions in order to qualify

for a Rule 204(e) (2) emission limitation.

 The Board has also

added a requirement that any source which opts to comply with the

existing Rule 204(e)

 formula reapply to the Agency

 for its opera-

ting permit within

 60 days of the effective date of Rule 204 (e) (1)

The Board notes that, although a source may be allowed a looser

standard pursuant to this Rule 204(e) (2), it still may not cause

or contribute to a violation of any air quality standard.

Rule 204(e) (3) embodies the concept of what was Rule 204(e)

(2)

 in the Agency’s proposal, although the approach differs from

the Agency’s approach.

 During the hearing process,

 it was pointed

30

—

—3—

out that the Rule 204(e) (1)

 formula might not be the most appro-

priate formula

 for all sOurces, due to differences

 in plume rise

and/or meteorology.

 Hence,

 the Aqeh~yamended its proposal to

provide a means by which a source could obtain an emission limit-

ation based on the specific characte~istics of its site.

The

Agency proposed that this

 “alternate emission standard” be

determined through the permit process.

 However,

 the Board pro-

poses

 that such a determination be accom~li~hed’througha petition

and adjudicative hearing before th~Boàrd, with the Agency

 a party

to such proceeding.

 A hearing and decision by the Board satisfies

several concerns expressed by variOus qroups during the hearings:

it allows for full public input: intothC determination before the

decision is made;

 it satisfies

 U.S.’ EPA’s requi±ement that any

grant of an “alternate emission standard”

 fulfill the federal

hearing requirements and be submitted

 as a SIP revision; and it

 is consistent with the policy.in the Environmental Protection

Act that the Board carry out standard-se’üting functions.

Since

 it is recognized that’the 204(e) (3) alternate emission

limit will most likely be less stringent than the limit under

204(e) (1),

 204 (e) (3)

 requires that a source prove that it will

not,

 under worst case conditions,

 cause or contribute to a viola-

tion of air quality standards.

 Such proof shall include modeling

and monitoring of air quality

 in the area surrounding the source,

both

 in order to obtain

 the standard and for one year after the

standard is granted.

 The Board intends

 to promulgate Part

 X. of

the Procedural Rules which will join

 the Agency

 as a party, pro-

vide for the possibility of an Agency Recommendation, require

the

source to meet certain requirements

 in submitting its petition

including much of what was in the Agency4 s proposed guidelines

(Exhibit 64), and set out other applicable procedures.

Rule 204(f) (1) (D)

 is modified as was suggested in the Agency’s

proposal.

 The Board has chosen not to prOpose the modification to

Rule 204(g) (3) which was suggested in the :Agency~sproposal because

it is no longer relevant.

‘

Rule

204 (h)

Compliance

Dates,

‘remains

‘basically

was

the Aqcncv’

proposal.

The

sections

-allowinq

sources

iii

compliance

with

the

existing

Rule

204(e)

three

years

~to

comply

with

either

204

(e) (1)

 or an alternate emission standard under 204(e) (3)

 have been

modified

 to clarify that,

 in order to qualify for this delayed

compliance date,

 compliance with the existing 204(e) must be con-

tinuously maintained until the stricter limit is

 reached.

The

Board notes that our intent is that no source, even

 a source which

30

—

348

is in compliance with the existing 204(e)

 and applies for and

obtains

an

 (e) (3) alternate standard, be allowed to emit more than

that allowed under Rule 204(e) (1)

 once three years from the effect-

ive date of that’Rule has passed,

 unless the source

is

 in compli-

ance with

 204(e) (2)

 or 204(e) (3).

The Board has incorporated Rule 204(i),

 Intermittent Control

Systems

 (ICS),

 as proposed by the Agency with two modifications.

The version of this Rule contained in the Agency’s latest proposal

 would have applied to all sources, while the ICS Rule

 in the

Agency’s previous versions of the proposal would have only applied

to sources outside the Chicago,

 St. Louis and Peoria Major Metro-

politan Areas

 (MMA’s).

 The Board has limited the ICS Rule to

sources outside these MMA’s because it is only these sources which

would have had notice of the proposed rule and,

 therefore, would

have had an opportunity to participate in the hearings.

 Further-

more, requiring an ICS in an urban area with

multiple

sources

would

not appear to be viable because of the difficulty of determining

liability for air quality violations.

 Also,

 the Rule has been

modified to specify that the Agency may only require installation

of an ICS as a permit condition

 if necessary to prevent the source

from causing or contributing

 to an air quality violation.

Rule 204(j),

 Dispersion Enhancement Techniques,

 has also been

slightly modified both editorially

and

substantively

 in the Board’s

proposed Order.

 As proposed by the Agency,

 this Rule could have

precluded a source from receiving credit in Rule 204(e)

 for ~

increase in stack height.

 Several sources complained during the

hearings that such a rule is more restrictive than Section 123 of

the Clean Air Act Amendments,

 which would appear to allow credit

 for an increase in stack height up to good engineering practice.

The Board has, therefore,

 redrafted this Rule to provide that only

increases

 in stack height in “excess of good engineering practice

necessary to prevent downwash or fumigation conditions”

 shall be

considered a dispersion enhancement technique and,

 therefore,

not

a permissable means

 of attaining compliance with Rule

 204 Ce).

Also,

 the Phrase

“

OXCOJ)

L ~~

 pr(’)VJ de(1 in

 ~C’C

‘3

 the Ci nan

Air Act” has been included to specify that any inconsistency be-

tween this Rule and the Clean Air Act be,,resolved in favor of the

Clean Air Act.

Finally, the Board has proposed to adopt the Agency’s modi-

fication of the definition of “Air Pollution Control Equipment”

in Rule 101 to include intermittent control systems.

 Defining

ICS as air pollution control equipment means that any source

ordered

 to install an ICS must apply to the Agency for construct-

ion and operating permits

 for such system.

—

349