ILLINOIS POLLUTION CONTROL

BOARD

September 1, 1977

SNTRAL

ILLINOIS

PUBLIC SERVICE

)

COMPANY,

)

Petitioner,

cVrPOITMENTAL

PROTECTION

AGENCY,

)

Respondent.

MIt.

THOMAS

It

COCHRAN,

OF

SORLING,

NORTHRUP,

HANNA,

CULLEN

AND

COCHRAN,

REPRESENTED PETITIONER;

HONORABLE

WILLIAM

J.

SCOTT,

ATTORNEY

GENERAL,

BY

JOHN

VAN

VRANKEN~

REPRESENTED

RESPONDENT.

OPINION

AND

ORDER

OF

THE

BOARD

(by

Mr.

Goodman):

On

May

31,

1977,

Central

Illinois

Public

Service

Coepany

(CIPS)

filed

a

Petition

for

Variance

before

the

Board

seeking

temporary

relief from

the

sulfur

dioxide

removal

requirements ordered

by

the

Board

in a prior

case, PCB 75-~382.

CIPS filed

supplemental

in~for~

nation

on

June 6,

1977.

The Environmental

Protection

Agency

(Agency)

filed its

recommendation on

June

29,

1977,

A

hearing

was

held

on July

6,

1977,

in Newton,

Illinois.

No citizen

witnesses

testified.

cIps owns

and operates an electric

generating

facility

known

as

the Newton Power

Station in

Jasper County.

Newton

Unit

I

is

rated at 550 MW

and is scheduled for

commercial

operation

on

December 1,

1977.

Newton Unit

2 will also be

rated

at

550

MW

and

is

scheduled for

service

in 198L

On January

14, 1976, the Board

found

that

CIPS

had

violated

conditions of a

construction permit and

Section 9(b)

of

the

Act

by

allowing

construction

work

to

be done toward

erection

of

a

coal~

fired

boiler whose

emissions

would

violate

Rule 204(a) (1)

of

the

Air

~451-

~7-363

---

Pollution Regulations.

The

Board ordered

CIPS

to

comply

with

the

terms of the

Settlement Proposal submitted by the parties.

Item 17

through Item 21

of that Proposal

set

forth the conditions

from which

CIPS now seeks a

variance,

Generally,

the order

required

CIPS to

have a SO2

removal system instaJ

led and fully

operational

by the

time Unit

1 at Newton begins serv~ce.

It was the

intention of CIPS

at the time to install

either

a

lime scrubbing system

or

a double

alkali scrubbing

system.

CIPS

agreed that the

system

chosen would

treat the flue gas

to meet the 1,2

lbs./106 BTU

sulfur

dioxide

emission standard.

CIPS chose

and began construction

o:~ double

alkali flue gas

desulfurization system

on

Newton Unit

1,

:~PSstates

and the

Agency agrees

that the double alkali

system is

a “second generation”

type of SO~remdval

system and shows

marked

advances

in performance

and reliability over

~first generation”

lime/limestone

FGD systems.

The

FGD system to

be applied to Newton

Unit I

is the

first appli-

cation of the

double alkali system

on a ‘arge

utility

boiler.

CIPS

alleges and the Agency

agrees that,

because

this

application is the

first of its

kind on a large utility

boiler,

cost and

construction

schedules forecasted in

August,

1975 were not

accurate.

The original

cost projection was

$47 million, and

the

anticipated

completion date

was December

1,

1977.

CIPS now

contemplates

completion

of the FGD

system by November,

1979,

In its petition,

CIPS outlines the major design

changes and

significant increases

in

cost which preclude

it

from

adhering to

the original target

date,

The project

is

now

anticipated to cost

$108 million

more

than double the original cost

estimate.

Studies

undertaken at the beginning

of the project resulted

in a major

process change

in the regenerated liquor loop affecting

seven major

components and their

associated piping and instrumentation.

CIPS

indicates that, because

this system is

the

first

of

its

kind,

redundant and conservative

design

have been built

into the system.

CIPS also indicates that

this past severe winter

weather and man-

power shortages have

served to further delay

completion of the

project.

Load projections and

economics dictate

that the generating

unit

be commercially

available

on

the

December

1

schedule.

However,

CIPS alleges that early

completion of the FGD system

is

not a viable

option.

During the

period of the requested variance, CIPS

calculates

that its uncontrolled

SO2 emissions,

assuming Newton

Unit

1 will

burn 230 tons per

hour of

2.8

sulfur content coal,

will be 4.6 lb/

MM BTU.

Modeling and

monitoring studies conducted by

CIPS as well

as a dispersion

modeling study conducted by the Agency

conclude that

emissions from Newton

Unit

I

will not cause or contribute

to a

i3~

---

—3—

violation of the National Primary and Secondary Ambient Air

Quality Standards for SOD.

The Board notes, however, that the

information on these stuaies submitted by CIPS and by

the Agency

was rather incomplete.

Should the Board deny the requested variance, CIPS would be

forced to burn low sulfur coal

until

start-up of its FGD system.

CIPS indicates

in its petition that the total increased expense

to the Company for burning out—of-state low sulfur coal as opposed

to high sulfur Illinois coal until November, 1979, would be

$20,978,000.00.

An additional cost would likely be incurred in

order to restore the efficiency

of

the electrostatic precipitator,

which could be degraded because of the high ash resistivity normally

associated with low sulfur coal.

One possible solution to this

problem would be injection of sulfur trioxide into the gas stream of

the precipitator, which could cost from

$2

to $10 per kilowatt.

CIPS

indicates that in addition to degraded precipitator performance,

other technical difficulties could result from

the use

of low sulfur

coal

in

a

unit

designed to burn high sulfur coal.

The Company is

concerned about the pulverizer mill capacity affected by the coal’s

grindability and changes

in heat transfer affected by

ash slagging

characteristics.

CIPS furthermore alleges that completion and start-up of

the

FGD system earlier than November, 1979,

is not feasible because of

cash flow difficulties, difficulties in retaining sufficient con-

struction craft labor in the Newton area,

and the risk of problems

created by the accelerated completion of this first-of-its-kind

installation.

Because of

the

lack of experience in this type of

installation, CIPS has already encountered several unanticipated

problems resulting in delay.

CIPS indicates that completion of the

FGD system is scheduled for June

1,

1979,

but that during the period

from June to November,

1979,

the system will be operated

in a start-

up and shake-down mode.

Therefore, CIPS indicates,

the 1.2 lb/MM

BTU will be met during part of this

period,

and partial emission

reduction will occur during a siqnificant portion of this period.

The Board finds that

a denial of CTPS

wiriance request would

impose an arbitrary and unreasonable hardship upon

the company.

The Board agrees that CIPS has proceeded diligently

in its

construc-

tion program and that, considering that this

is the first

application

of this type of FGD system to a large utility boiler,

the delay has

been reasonable.

Because of the apparent lack of a threat to ambient

air quality and the costs and technical difficulties associated

with

---

burning

low sulfur

cc~a1, a

vari)a:I~s

~s

~

~t.u1

The

Board

also

finds

that,

due

to

the

manpow~r..shurtag~

in,

the

Newton

area

and

the

need

for

more

time

to

instal.~’

this first~’of~~its

k~1.n~system

than

would ordinarily be needed,, the

full~,variance

recuested is warranted.

In

addition,

we

find

that

the

two

yeaas~ experience

SIPS

will have

in operation of Unit

I

prior

t

start-up of

the

FOD

system

will

be

beneficial to the smooth

operatio~’i.of the system.

The Board, there-

fore, grants CIPS

a variance fromPCB 75—382

until November

3,

1979,

subject to the conditions belQw.

This Opinion consti~tutes~

~

Board~

findings

of

facts

and

conclusions of law in this matter.

ORDER

It is the Order of the Poliuti~nC~nti~ol

Board that SIPS

be

granted a variance from the Board

~G~der

~n

PCB

75-382

in order to

operate Newton Unit

1

in violation ci whe

.L2 lb/MM

BTU SO~emis-

sion standard until November

3,

1.9~9, subject to the following

conditLns:

1.

CIPS will

subi’nit

quarterly

repoits

until

June

1, 1979 describing the ~oqress

being made

toward the completion of the DAFGD: Systen..

2.

CIPS will submit monthly

~reports

from

June

1,

1979 until November

3,

1979, de’~cribingthe progress

being made in making the DAFG~System commercially

operational.

3.

CIPS

will

subrriit

‘to

th~ Agencv~ on

or

before

November

3,

1977,

,ar’opecat~ng

erm’~ttrapplicatcon for

Newton Unit 1, said application to. include the

re-

quisite stack testing data and infqr~nation.

Mr.

Dumelle

dissents,

I,

Christan

L.

Moffett,

,C1erk~of”th~

lllino3s

Pollution

Control

Board,

hereby

certify

t

e

ab~ove’

Opin±on’and

Order

were

~dopted

on

the

/~

day

of~

.

,

l977~y.

a

vote

of

‘j—/

Christan

It

Moffe&~t7J~1erk

Illinois

Poilutiotr-1~Sntrol

Board

~2/

:C~’