ILLIr~OIS
POLLUTION CONTROL BOAT~D
January
19,
1978
IN
THE
MATTER
OF:
PROPOSED AMENDMENTS TO
R75—l0
RULE 207(a)
(4-5)
AIR POLLUTION
CONTROL REGULATIONS
OPINION AND PROPOSED ORDER OF THE BOARD
(by Dr. Satchell):
This regulatory proposal was filed on July
2,
1975 by the
Southern Illinois Power Cooperative
(SIPC); an accompanying
statement of reasons was filed
August.
13, 1975.
The original
petition included the requisite
200 :3ignatures needed for
authorization for hearing urder
~~cadural
Rule 204.
The pro-
posal requested additional
1angu~
:e added to Rule 207(a)
(4-5)
of the Chapter
2:
Air
POi~~fl Control Regulations
(Chapter
2)
which would exemrt
~r~n the nitrogen oxide emission
standards facilities burning lip~.~te.
or a solid fossil fuel
containing 25
by weight or m-r:’~ c~f coal refuse in combination
with gaseous,
liquid or other
~‘o~
c1
fuel.
The language of the ~~:hanq~
of
~ule 207(a)
(4-5)
of Chapter
2
as proposed
by SIPC
is as
follows:
(4)
for solid fossil fuel firing,
0.7 pounds per
million btu of actual heat input, except lignite
or a solid fossil fuel containing
25
by weight
or more of coal refuse; and
(5)
for fuel combustion emission sources burning
simultaneously any combination of solid, liquid
and gaseous fossil
fuels
an allowable emission
rate shall be determined by the following equation:
0.3
(P
+ P1)
+
0.7
(Ps) ~
E=(
g
)Q
Pg+Pi+Ps
where:
E
=
allowable nit -ogen oxides emission rate in
pounds per ho~r;
Pg
per cent of actual L~atinput derived from
gaseous fossil fuel;
29
—
107
P.= per cenL of actual heat input der
~
.1 from
liauid fos~ilfuel;
P5= per cent ~f actual heat input der ~ed from
solid
fossil fuel,
(e~ceptlignit~:
or a
solid
fossil fuel contaLa.~nq25
by wei
~.t or
more of coal refuse;)
Q
=
actual heat input derived from all fossil
fuels in million btu per hour.
Note:
(6)
When lignite or a solid
fossil fuel containing 25
by weight or more of coal refuse
is burned
in com-
bination with gaseous, liquid or other solid
fossil
fuel, the standard for nitrogen oxides does
not apply.
The proposal was published in Environmental Register #110,
September
25,
1975.
Hearings were held on December
8,
1976 in
Carbondale, Illinois and on December
9,
1976 in Springfield,
Illinois to hear testimony and comments on the proposal.
Economic impact hearings were held pursuant to Section
6 of the
Environmental Protection Act
(Act)
on February 23,
1977 in
Carbondale,
Illinois and February
24,
1977 in Springfield,
Illinois.
The economic impact study is IIEQ Document #76—26.
The purpose of this change
is to allow SIPC to burn coal
refuse from gob piles, refuse piles, and slurry deposits in
combination with coal
in a cyclone furnace.
This would allow
savings on fuel and would clean up some of the unwanted
coa-1
refuse present in southern Illinois as
a result of mining
activities.
This change has already been made in USEPA.’s
Standards of Performance for New Stationary Sources,
40 Fed.
Beg.
2803
(1975).
This change as stated in the Federal 1~egister
was made for purposes of clarification of the application of
standards and
is expected to apply only to one source
On two prior occasions the amount of NO~emissions from
SIPC’s electric power generating facility on the Lake of Egypt
has been before the Board.
In both cases,
Southern Illinois
Power Cooperative
v. E.P.A., PCB 75-352,
19 PCB 255
(197.5)
and
Southern Illinois Power Cooperative
v. E.P.A. PCB 76-216,
24 PCB 343
(1976), the Board granted variances to SIPC pending
the resolution of this regulatory proceeding.
The petition for regulatory change was signed by four
petitioners, Southern Illinois Power Cooperative,. Egyptian
Electric Cooperative Association, Southeastern Illinois Electric
Cooperative and Southern Illinois Electric Cooperative.
.SI,PC
owns and operates an electric generating plant at the Lake of
Egypt
in Williamson County, Illinois.
The other three-petitioners
are distribution cooperatives and distribute the electricit~’
29
—
108
—3—
gen rated
by
SIPC
~roucthout
the
rural
areas
of
L~
southern
one~-third
of
the
State.
Currently
~
has
Three
cyclone
furnace
boiTh.~t
operating
ith
electrosta~.ic
p~acipitutor~,
~ch
is
a
33 n~
ojt~itt
(MW)
unit
(R.
7,
Ex.
2).
These
units
k~. e
been
in
exisLence
since
the plant
was
constructed,
A
fourTh
unit is now being built
with
a
rated
capacity
from
160
to
0
MW
(B.
7).
This
unit
will
also be
a
cyclone
furnace
boiler
with
an
electrostatic
preci-
pitator
(Ex.
2).
The unit is being built to allow the use of
a blend
of coal and no less than twenty—five pet cent coal
refuse
(R.
17, Ex.
3).
The purpose of using the coal refuse is
several
fold:
First, burning the refuse provides low cost
electricity;
the price of the coal refuse
is roughly one-third
the price
of good coal which resulti in a lower cost for generating
tne
electricity
(R.
16).
The coal with which the refuse
is
mixed
costs
(at the time of hearing)
$18.00 a ton f.o.b. the
plant
(R,
41).
SIPC in 1975 paid $5.50 per ton for refuse of
9,000
btu
(R.
41).
A
premium was paid for higher btu and a
deduction
was made for lower btu
(R.
41).
The refuse SIPC
has been
using has come from 20
to
30 miles from the plant
(B.
40).
Removing
the refuse would also clce
up numerous coal refuse
or gob
piles
that
are
now
scattered
throughout southern Illinois
(R
E).
Not
only
will
this
removol
improve the area esthetically
but as
pointed out by the Environmental Protection Agency
(Agency)
this
removal will help reduce
ac~
d runoff pollution of streams
and lakes
(R,
103).
Also,
as pointed out in PCB 75-352, use of
the refuse
will use energy that
would
otherwise not be used.
Refuse
piles can contain very high quality coal;
for example,
~steam
coal” was mined for use
in locomotives and all the fines
were dumped
(B.
35).
Some of the “chemical coal” refuse has a
btu value
per pound as high as 12,000
(R.
40).
Refuse
piles present a hazard other than possible contri-
bution to water pollution.
Under specific conditions they may
burn
without obvious surface manifestations and people, livestock
and other
animals may fall into the burning zone
(B.
9).
In
removing
the refuse, mining permits will be required.
Reexposure
of the
lower zones of the piles may permit
oxidation of reduced
sulfur
and contribute to acid drainage
(B.
109).
Rule
207(4)
as it now reads would require that the new
utit
of
SIPC meet the standard of 0.7 pounds per million btu of
actual
heat input.
Coal refuse mixed with coal cannot successfully
be burned
as
a
fuel in pulverized coal furnace boilers
(B.
103).
The Agency
pointed out that. if pulverized coal furnace boilers
~ould
burn
coal refuse, the new source performance standard of
0,7 pounds
of NO
per million btu could be met
(B.
103).
Coal
refuse
mixed wit~coal can only
bL. successfully burned in cyclone
furnace
boilers which, because of higher operating temperatures
within the
furnaces, are unable to meet the 0.7 pounds per
million
btu standard
(R.
103, 104).
29
—
109
SIPC
expects
u~
I
from 25
1~
40
per
cen~
i~efV1se coal
in
their
blend
(R.
61)
.
.
..
~
tes
s
were
run
b’
urns
and
McDonnell
for
SIPC
us
ous
a’
tures
of
gel
refuse
and
coal
(B.
54).
These
L
~re
wil
iessed
by
Mr.
Don
Goodwin
and
Mr.
Robert
Walsh
fror” USLI
rst
four
tests
were
run
with
25
coal
and
75
gob
refus~
trogen
oxides
emitted
were
determined)
:
No.
1
-
discardeU
~ults
low-probably
because
of
low
absorption
time;
No.
2
7
lbs.
NO7/lO6btu;
No.
3
—
1.171
lbs.
NO2/lO6btu;
o.
4
—
1.162
lbs.
N02/lO6btu.
The next tests
(5
and
6)
were
ru~~
ing
a
50/50
mixture
and
gave
the
following
emission
values
)f N02/l06btu:
5
-
1.193 and
6
—
0.973
(B.
54—57)
SIPC
has
run
tests
usLni
lüflV
~efuse
coal,
but
states
it
becomes
dangerous
to
handle
beca~
it
is
wet and sticky
(B.
60)
Also refuse coal is lower
in
volatiles
(3
to
5 per cent)
than
regular
coal
and
therefore
requires
a
higher
temperature
to
keep
it
lit
(R.
75).
From
these
tests
it
is not
iat
NO
emissions
do
not
increase
significantly
with
I
ng
us~ of
coal
refuse;
rather
it
is
the
higher
temper~
needed
that
appear
to
cause
the
increase.
Implicit
in
a
rule
change
~
re
assumption
that
control
methods
are
not
available.
es
nology
to
control
NO~
from
utility
boilers
involves
two b
Ic
ipproaches:
(1)
techniques
to
modify
the
combustion
prncess
ed
(2)
processes
which
remove
NOx
from
the
combustion
products.
Current
technology
falls
in
the
first
category
above
and
involves:
(1)
low
excess
air
firing,
(2)
two
stage
combustion,
(3)
Flue
gas
recirculation
and
(4)
furnace
design
modification
(R.
150—151).
SIPC
uses
the
first
technology
(low
excess air
firing)
which
probably explains the values of NO~emission
obtained
in
the
tests
(about
1.05)
compared
to
predicted
values
of
1.2
to
1.6
lbs.
of
NOx/lO6btu
(R,
149).
The
two
stage
combustion has been the most successful with up to
50
per
cent
reduction for coal firing in some type units.
It
is the only
currently available effective means of lowering coal—fired NO,~
emissions
(R.
151-152).
This method has not been applicable to
cyclone type furnaces because of the furnace configuration
(B.
152).
Other experimental stage technologies show promise.
For
example,
gas
phase
reduction
of
NOx
by
injecting
small
quantities
of
ammonia
into
product
gases
at
temperatures
of
1300
to
20flfl0F
has
reduced
NOx
by
90
per
cent
(R.
151).
Testimony
was
given
that
many
of
the
processes
which
remove
SO2
also
tend
to
remove
NOx
(B.
~74).
The
new
unit
(Unit
4)will
be
equipped
with
a
limestone
scrubber
supplied
by
Babcock
and
Wilcox.
It
is
called
a
“TCA”
system
which
was
believed
to
stand
for
“Turbulent
Contact
Adsorbant”
(B.
201).
Dr.
Kenneth
Noll
made
estimates
of
NOx
removal
of
30
to
60
per
cent
for
this
site
by
the
SO2
scrubber
with
a
good
probability
that
at
least
30
per
cent
would
be
removed
(B.
181-182).
By
using
low
exeess
29
—
110
—5—
air
(test resuies
s
~l
~y over 1U
lbs.
NO~/lU6
~
and with
a NOx removal of
ao
m~--thirdby the S02 scrshTh~,S1PC’s
Unit
4 should be op~r
a~or very near the 0.7 lbs.
NOx/lO6btU emis Ion
r
ement for new coal fired
~outces.
The Agency performed
mc
ug study at Si~?C~ssite to
determine the impact on a~ ~
that would
be caused by NO2
emissions from the additIonal t~ U
unit.
The results of this
study were specIfically 11mm
~his site by the Agency
(B.
104).
The result of the study was a
iO
ig of minimal
impact upon
ambient
NO2 air
quality near the
te
(B.
104).
Two
simulations
were
performed.
The
first simuls
n~onwas
run
using stack
emissions data supplied by SIPC.
~ae second simulation utilized
theoretical
maximum
stack emIssi~
rates
which the Agency
computed,
based
on
emission facto~.s,
to
represent
the
most
con-
servative conditions,
Conservative conditions would
be
associated
with the highest ambient N02 levels
(B.
104).
The three existing units, as ording to the modeling,
would
contribute a maximum concentratlo
of
8 micrograms per cubic
meter
(B.
105).
Adding
t”e fou
‘~
mit
to
the
first
three
produces
a
predicted
maximum
cot
~tration
of
9
micrograms
per
cubic
meter
(B.
105).
The
ambi
P02
air
quality
in
the
region,
according
to
the
Agency’s
197r
a
tal
Air
Quality
Report,
is
22
micrograms
per
cubic
meter
105).
Thus
the
maximum
NO2
concentration,
taking
into
a
~o
all
four
units
and
the
ambient
air
quality,
is
31
rn.
:~~ams per
cubic
meter
(B.
105).
The
national
health
relared
staidard
is
100
micrograms
per
cubic
meter
of
NO2.
The
31 ug/m3
0±
NO2
is
substantially
below
the
health
related
figure.
The
Agency
agreed
(B.
171-172)
with
Dr.
Kenneth
Noll’s
statement
made
at
the
first
Economic
Impact
Hearing
that
it
would
be
difficult
to
establish
a
damage
function
for
either
the
background
or
the
elevated
NO~ level
since
both
are
below
the
level
at
which
a
damage
response
to
humans
or
the
natural
environment
can
be
measured
with
presently
available
methods
(B.
150)
The
economic
impact
of
the
regulation
is
essentially
all
positive.
In
addition
to
the
aforementioned
benefits
of
refuse
coal
removal
to
the
environment,
at
$3.50
per
ton
of
refuse
coal
an
annual
fuel
cost
saving
of
1.6
million
dollars
is
anticipated
(B.
153).
The
economic
impact
study
was
done
by
Dr.
Kenneth
Noll,
Air Resources Engineering consultant, and was published as
“Technical
and
Economic
Ev luation of NOx Control for
Coal—Fired
Cyclone
Furnaces”,
IIEQ
Document
No.
76-26.
The
Agency
does
not
oppose
tnis
rule
change
to
allow
SIPC
to
burn
coal
refuse;
however,
the
Agency
did
make
three
specific
recommendations:
first,
that
a
definition
of
coal
refuse
be
included
as
part
of
Chapter
2;
second,
that
all
the
references
to
lignite
be
removed;
and
third,
that
the
proposal
be
made
site
specific.
29
—
111
—6—
The
Agency
proposed
that
a
definition
be
.~
P to Rule 201
of Chapter
2:
Air Pollution Control
Regu1atio~s
The
definition
proposed by
the
Agency is
the same
as that used
i.ì
Chapter
4:
Mine Related Pollution with deletions of refer~nce
co other than
coal mining.
The
Agency proposed definition
reads:
Coal refuse:
Gob, coal,
rock, slate,
shale,
till
tailings and other sludge or slurry material intended
to be discarded, which
is connected with
the
cleaning,
screening and preparation of mined coal.
The Board agrees that a definition of coal
refuse
is desirable.
The definition used by USEPA
(R.
122, 40 Fed.
Reg.
2803
(1975))
states:
“Coal refuse” means waste products of coal
mining,
cleaning
and
coal
preparation
operations
(e.g.
cairn,
gob, etc.)
containing coal, matrix material, clay
and other organic or inorganic material.
The
Board
finds
that
the
second
definition
(absent
the
examples
of
cuim,
gob,
etc.)
is
simpler
and
more
precise.
The
regulation
proponents
had
no
objection
to
either
definition.
The
proposal
before
the
Board
tracks
the
language
used
by
USEPA
which
includes
lignite.
SIPC
indicated
that
this
inclusion
was
for
power
companies
in
North
Dakota
and
South
Dakota
and
not
at
the
request
of
SIPC
(R.
24).
To
burn
the
lignite
the
cyclone
furnace
must
be
designed
for
that
purpose
(B.
24,
25).
There
are
no
lignite
deposits
in
Illinois
(B.
107)
Considering
these
facts
there
appears
to
be
no
need
for
lignite
to
be
included
in
the
language
of
the
regulation.
The
Agency
recommended
that
the
proposal
be
made
site
specific.
The
proponents
do
not
oppose
this
modification.
The
evidence
presented
by
SIPC
in
support
of
this
regulation
referred
only
to
the
effects
of
the
change
in
the
vicinity
of
the
Lake
of
Egypt.
The
Agency’s
modeling
study
is
applicable
only
to
SIPC’s
facility.
The
economic
impact
study
was
also
site
specific
(R.
179).
The
testimony
further
indicates
that
it
is
probably
not
feasible
for
others
to
use
this
same
process.
Trucking
more
than
50
miles
makes
the
use
of
refuse
uneconomical
(B.
27).
Since
only
“dry”
refuse
coal
can
be
accepted1
a separate
large
bunker
is
required
(B.
47).
In
addition,
dual
fuel
mixing
methods
must
be
used
(R.
80-81).
Provisions
to
accept
both
rail
and
truck
shipments
are
necessary.
Coal
refuse
mixed
with
coal
cannot
successfully
be
burned
in
pulverized
coal
furnace
boilers,
and
can
only
be
successfully
burned
in
cyclone
furnace
boilers
(B.
103—104).
Because
of
the
many
site
specific
aspects
of
this
proceeding
the
Board
sees
no
problem
with
adopting
the
regulation
as
limited
to
the
site
of
SIPC’s
Lake
of
Egypt
plant.
29—112
PROPOSED ORDER
It is the
order
o.
~hc Poard
that:
1.
The following def~
.itcot
for “Coal Refu:
?
be
added to Rule
201,
of
~,heBoard’s
Chaptcc
2:
Air Pollution Control Regulations:
Coal Refuse:
Waste
products of
coat
mining, cleaning and coal preparation
operations
containing
coal, matrix
material,
clay and other organic and
inorganic material.
2.
Rule 207(a)
(4—5)
of the Board’s Chaptc’r
2:
Air Pollution Control Regulations shall
be
amended to
read as
follows:
(4)
for solid fossil
fuel firing,
0,7
pounds per million btu of actual heat
input except the standard for nitrogen
oxides does net cpply when solid fossil
fuel containing
25
by weight or more
of
coal
refuse
is burned in Southern
Illinois Power Cooperative’s Unit
No.
4 at
its
‘Take
of Egypt Power
Plant; and
(5)
for
fuel emission sources burning
simultaneously any combination of
solid,
liquid and gaseous fossil fuels,
(A)
an allowable emission rate
shall
be
determined
by
the
following
equation:
E =~0•3(Pg+ P1)
+
0.7(Ps)~Q
Pg+Pi+Ps
where:
E
=
allowable
nitrogen
oxides
emission
rate in pounds per hour,
P
=
per cent of actual heat input
g
derived from gaseous fossil fuel,
~i= per cent of actual heat input
derived from liquid fossil fuel,
P~=per cent of actual heat input
derived from solid fossil
fuel,
and
Q
=
actual heat input derived from all
29—
113
—8—
fossil fuels in
mi~iIonbtu per
hour.
Note:
Pi+P5+PglOOsO
(B)
the standard
for
nitrogen oxides
does
not
apply
when solid
fossil fuel
containing
25
by weight or more of
coal
refuse
is burned
in combination
with
gaseous,
liquid or other solid
fossil fuel in Southern Illinois Power
Cooperative’s Unit No.
4 at
its Lake
of Egypt Power Plant.
I, Christan L. Moffett, Clerk of the Illinois
Pollution
Control,.j3oard~hereby certify
the
above Order was adopt d on
the
_____
day of
______________,
1978 by a vote of
____
Christan
L.
Moffe~
erk
Illinois Pollution
trol Board
29
—
114