ILLINOIS POLLUTION CONTROL BOARD
    May 15,
    1975
    PROPOSED AMENDMENTS TO CHAPTER
    2,
    )
    AIR POLLUTION REGULATIONS FOR
    )
    R72-18
    GRAIN
    HANDLING
    AND
    GRAIN DRYING OPERATIONS
    )
    INTERIM
    ORDER
    OF
    THE
    BOARD
    (by
    Dr.
    Odell)
    On January 28,
    1975, the Illinois Pollution Control Board
    (Board) published on pages 21 to 33 of Environmental Register
    No.
    97 a proposal
    in the above matter for public comment.
    That
    proposal was based upon a previous draft proposal by Joint IEPA-
    Grain Industry Task Force and evidence submitted during hearings.
    On the basis of comments concerning the proposal published
    in Environmental Register No.
    97 and further study of the record,
    the Board hereby publishes for further public comment three pro-
    posed changes in language in this proposed Regulation.
    Change
    1.
    Add the Galesburg
    MPA
    because of large emissions
    from
    two grain ha~Tingoperations and air quality considerations
    which
    are discussed below.
    Insert the following statement on page
    ~3
    of
    Environmental Register No.
    97, under “Major Population Area”,
    ~:fter
    the description of the “Rock Island, Moline area.”
    “The area within the municipalities of Galesburg and
    East Galesburg, plus a zone extending two miles beyond
    the boundaries of said municipalities”.
    Amendments to the original Task Force proposal were submitted
    by
    the
    Illinois Environmental Protection Agency
    (Agency)
    on July 9,
    1974,
    during the hearing at Galesburg, Illinois.
    These Agency
    amendments included mandatory controls, irrespective of complaints,
    in major metropolitan areas
    (MMA’s)
    as defined in the Illinois Air
    Pollution Regulations, Chapter
    2.
    The intent was to minimize the
    air quality impact of grain handling emissions in areas where the
    quality of the air
    is of concern and where the population is most
    dense
    (R.
    464—467).
    It was estimated that between
    90
    and 100
    elevators would be subjected to the mandatory controls based on
    their size being greater than
    2 million bushels yearly throughput
    and their location being within a MMA
    (R.
    503).
    During the next hearing on July 17, l97A, near LaSalle-Peru,
    Illinois, the Agency refined the MMA’s
    to more concentrated major
    population areas
    (MPA’s) with smaller geographic areas.
    The manda-
    tory controls are imposed on elevators whose annual throughput is
    greater than
    2 million bushels per year and which are located in
    major population areas
    (MPA’s).
    The MPA’s are defined in Rule 201
    and are shown on Exhibits 27,
    44,
    and 45.
    Their configurations
    are intended, according to the Agency,
    to “protect those areas
    containing major population centers of the state, and where we had
    17—65

    —2—
    air quality problems or potential air quality problems”
    (R.
    1044
    August
    5,
    1974).
    The refinement was intended to include the
    majority of the people within the
    MMA’s
    without including rural
    areas where mandatory controls may, not be necessary.
    In partic-
    ular,
    the Agency cited situations of grain elevators located
    30
    miles away from cities that would be included in the MMA’s, which
    are county-wide designations, but whose air pollution impact on
    the cities would not be
    a problem
    (R.
    831).
    Therefore,
    the
    Agency devised the MPA’s which,
    in most cases outside of Chicago
    and St. Louis Metro-east, were city limit plus one—mile buffer
    zone designations.
    The locations of the major grain elevators,
    those greater than
    2 million bushels annual throu~hput,are ~hown
    on Exhibit 28 as green circles for locations outside city limits
    but within
    MMA’s.
    There are
    30 elevators indicated on Exhibit 28
    which would not be subjected to mandatory controls using the
    MPA
    concept that would be using MMA’s.
    With the further refinement at the final hearing on August
    5,
    1974,
    in Chicago, the percentages of people within NMA’s that
    include MPA’s are as follows
    (R. 828—830, 1138—1139)
    Major Population
    Percentage of
    Area
    (MPA)
    population protected
    Chicago
    98
    Rockford
    65
    Rock Island-Moline
    80
    Peoria
    73
    Pekin
    70
    Bloomington-Normal
    64
    Champaign-Urbana
    58
    (Ex.
    27)
    Decatur
    75
    Springfield
    63
    St. Louis Metro-east
    88
    The air quality concern within the MPA’s is justified based
    on an examination of 1973 air quality data.
    Exhibit 50 shows the
    1973 annual average particulate levels for 136 locations within
    Illinois
    (58 within Cook County)
    as reported by the Agency.
    At 56
    locations
    (30 within Cook County), the annual mean primary air
    quality standard of 75 ).lg/m3 was exceeded.
    Of these locations
    where the air quality violated the standard in 1973, only 4 are
    not within the designated MPA’s.
    The four locations are Galena,
    Quincy
    (2 sites), and Metropolis.
    Based on current sampling
    locations,
    the MPA’s do include areas where air quality is of con-
    cern and where emissions from grain handlign facilities should be
    minimized.
    The reduction in geographic area from MMA’s to MPA’s reduces
    the number of elevators subjected to mandatory emission controls.
    Exhibit 53 includes the Task Force inventory of grain handling
    facilities larger than
    2 million bushels annual throughput located
    in MPA’s.
    According to this information there are 33 of these
    grain handling facilities,
    of which 16 will be required to install
    emission controls according to the Agency.
    The other 17 are con-
    sidered by the Agency to already have adequate controls.
    17—66

    —3—
    The major grain handling emitters of particulates
    should
    also be checked in relation to the MPA’s.
    Exhibit 17
    is the
    Agency emission inventory which is
    a state-wide ranking of
    emitters of pollutants.
    The Agency was asked to investigate
    whether the largest emissions of particulates
    from grain handling
    facilities would be subjected to mandatory controls.
    Their res-
    ponse is included in Exhibit 53, and it shows that only 21 of the
    50 largest (2
    million bushels annual throughput) grain handling
    emitters are within MPA’s as then defined.
    The other
    29 large
    emitters, each with estimated emissions greater than 1,000 lbs/hr
    (Exhibit 17), would be controlled only of complaints occurred.
    In
    particular, the second and fourteenth largest emitters of parti-
    culates from grain are located in Galesburg and together emit an
    estimated 1,443 lbs/hr particulates.
    A citizen has objected to
    these particulate emissions for several years
    (R.
    690-693).
    These emissions probably contributed sig~ificantlyto the 1973
    annual mean particulate level of 66 ,~ig/m
    in Galesburg, which
    places it 36th among
    78 in the state-wide ranking
    (outside of
    Cook County
    -
    Exhibit 50).
    This indicates that Galesburg should
    be included as an MPA for the purposes of this Regulation.
    Gales-
    burg is larger
    (approximately 36,000) than Kankakee (approximately
    31,000)
    and its 1973 annual particulate level
    (66 jig/mi)
    also ex-
    ceeded that of Kankakee
    (60
    jig/m3 based on the Bradley reading).
    With our addition of Galesburg to the MPA’s, we believe that proper
    protection of air quality in populated areas will be achieved.
    Change 2.
    Change the zone of one mile to two miles beyond
    the mu~6~alitiesincluded in the respective MPA’s
    (as defined
    on pages
    23 and 24 of~EnvironmentalRegister No.
    97)
    to increase
    the protection of residents within the densely populated municipal-
    ities so specified.
    Measured emissions from a large grain elevator
    and calculations from these data indicate that more than a one-
    mile buffer zone around municipalities in MPA’s is needed to ade-
    quately protect residents of such areas from particulate emissions
    from large grain handling facilities around the perimeter of these
    municipaliti~.
    Long-term emissions were measured for seven operations at a
    Kansas City terminal elevator using weekly totals over a 6—month
    period (Exhibit 43).
    The seven operations are: rail car unload-
    ing, truck unloading, rail car loading, cleaning, transferring
    (gallery belt), transferring
    (tunnel belt)
    and the headhouse.
    Short-term emissions were measured at the same elevator for indivi-
    dual operations of truck unloading, car unloading, and car loading.
    The emissions measured were those collected by the baghouse emis-
    sion contro’ systems and the results are conservative since not
    all emissions from the various operations were captured.
    The
    elevator handled various mixes of four grains
    (milo, wheat, corn,
    and soybeans) during the 6-month testing period, and while the
    long-term results did not show a dependence on type of grain
    handled, the short-term results did.
    Emission factors
    (particulate emissions per weight of grain
    handled) were calculated using the throughput records kept by the
    elevator.
    The weekly results varied significantly from week to
    17 —67

    —4—
    week but it
    is felt that the long-term averages give
    a true in-
    dication of the emissions.
    The long-term average emission
    factors and their comparison with AP-42 “Compilation of Air Pol-
    lution Emission Factors”
    (Exhibit 24) are listed below:
    Emission factors
    (lbs/ton)
    Exhibit 43
    AP—42
    Truck unloading
    0.64
    1
    Car unloading
    1.30
    1
    Car loading
    0.27
    1
    Corn cleaner
    5.78
    5
    Gallery belt
    0.11
    Tunnel belt
    1.40
    2*
    Headhouse
    1.49
    *
    Value is for transferring, conveying, etc.
    In actual elevator operation several operations occur sequentially.
    For example, unloading a truck would be followed by elevation of
    the grain to the headhouse,
    and transfer onto the gallery for
    storage,
    so that the overall emission factor for this activity
    would be 0.64
    +
    1.49
    +
    0.11
    2.24 lbs/ton.
    Short term emission factors show a dependence on the type
    of grain and whether loading or unloading, as
    is shown below:
    Truck unloading
    Car unloading
    Car loading
    (lbs/ton)
    ‘(lbs/ton)
    (lbs/ton)
    Soybeans
    1.63
    1.51
    0.44
    Milo
    0.95
    1.08
    0.29
    Corn
    0.47
    0.62
    0.28
    Wheat
    0.25
    0.50
    0.17
    Evidence presented during the hearings indicated the impact
    on air quality, including adverse health effects
    (Exhibit 3), of
    particulate emissions from grain handling facilities.
    The Agency.,
    in Exhibit 55, used dispersion modeling to estimate the contribution
    to the ambient particulate level from a typical grain elevator.
    The
    elevator was assumed to have an annual throughput of 2 million
    bushels, and particulate emissions
    (uncontrolled) based on the
    Kansas City study, Exhibit 43.
    Hourly and daily maximum ground
    level particulate concentrations were calculated for points at
    various distances from the elevator for various combinations of
    atmospheric stability and windspeed.
    The following table summarizes
    the results of
    the calculations:
    17
    68

    —5—
    Distance
    Maximum hourly
    Average 24—hou:~
    from elevator
    concentration
    concentration
    miles
    jig/mi
    pg/mi
    0.50
    2,547
    425
    0.75
    2,061
    290
    1.00
    1,621
    208
    1.25
    1,327
    150
    1.50
    1,125
    117
    Notes:
    1.
    The 24-hour primary standard is 260 pg/m3.
    2.
    The concentrations calculated are contrib-
    utions from a single source and do not
    include background levels.
    These results show that uncontrolled elevators may have
    a signif-
    icant impact on air quality at distances greater than a mile, and
    thus we must question the use of a one—mile buffer zone in the
    designations of MPA’s as prc~posedby the Agency.
    As pointed out
    in Exhibit 55, the ground level concentrations are directly pro-
    portional to the emissions, and via the emission factors
    to the
    size of the grain handling facility.
    For example, uncontrolled
    emissions from an elevator having an hourly rate of 20,000 bushels
    (roughly equivalent to an annual throughput
    of
    4 million bushels)
    would result in a 24—hour ground level concentration of 300 ~ig/m3
    (which exceeds the primary standard)
    at 1.25 miles, and 234
    jig/rn3
    at 1.5 miles.
    One way of analyzing the potential impact of elevators is
    to calculate the distances one would have to be located from
    elevators
    of certain sizes
    such that the 24—hour primary standard
    of 260 pg/rn3 was not violated.
    The following table uses the in-
    formation and assumptions of Exhibit
    55 to show the spatial impact
    of large elevators:
    Annual grain throughput
    Distance to meet
    of elevator
    primary standards
    millions of bushels
    miles
    2.0
    0.83
    2.5
    1.0
    4.4
    1.5
    9.0
    2.0
    15.0
    2.9
    20.0
    3.5
    Since the above calculations do not include background pollution
    levels, the distances should be considered minimums in terms of
    protecting people from the potential health effects
    (at the 260
    pg/rn3 24—hour primary standard)
    of emissions from these large
    uncontrolled grain elevators.
    Based on the above analysis, the
    one-mile buffer zone specified in the designations
    of MPA’s by
    the Agency is not sufficiently large since it will only offer
    17 —69

    —6—
    protection to people from uncontrolled elevators not larger than
    2.5 million bushels annual throughput.
    In order to provide increased protection to citizens from
    large uncontrolled elevators,
    it is therefore necessary to in-
    crease the spatial coverage in defining MPA’s beyond that propos-
    ed by the Agency.
    We do this by increasing the buffer zone
    around the municipalities included in the definition of MPA from
    one mile to two miles. This will then, according to the above
    table, protect people from the uncontrolled emissions from grain
    elevators of up to
    9 million bushels annual throughput in size
    rather than 2.5 million bushels annual throughput.
    Change
    3.
    Rule 203(d) (9) (3) (iv) (c) (3)
    on page
    28 of
    Environmental Register No.
    97.
    In
    a letter received by the
    Board on February 25,
    1975,
    from the Chicago Regional Port
    District it was indicated that the trimming machine portion of
    their two lessees’ operations which convey grain to the corners
    of vessels could not comply with this Rule.
    Closure of the
    hatches of such vessels while filling them with trimming machines
    would create combustion hazards for men and property.
    Until tech-
    nology
    is shown to be available to load such ships by improved
    methods, the removal efficiency requirement of particulates from
    trimming machines will be reduced below 98.
    On the bottom of
    page
    28, at the end of Rule
    203(d) (9) (B) (iv) (c) (3), add after
    “atmosphere”;
    “except for the portion of grain loaded by trimming
    machines for which particulate matter emission reductions,
    at a
    minimum,
    shall equal the reduction achieved by compliance with
    subpart
    (iv) (c) (2) herein.”
    Public comment will be received until June
    5,
    1975, concern-
    ing the three changes proposed herein.
    ORDER
    The Illinois Pollution Control Board hereby proposes the
    following changes in R72-18, Proposed Amendments to Chapter
    2,
    Air Pollution Regulations for Grain Handling and Grain Drying
    Operations:
    1.
    On page 23 of Environmental Register No.
    97, add the
    following “Major Population Area”:
    “The area within the municipalities of Gales-
    burg and East Galesburg,
    plus a zone extending
    two miles beyond the boundaries of said
    municipalities.
    2.
    On pages
    23 and 24 of Environmental Register No.
    97,
    in the definitions of each appropriate “Major
    Population Area”, change “one mile beyond the
    boundaries
    of said municipalities”
    to “two miles
    beyond the boundaries of said municipalities.”
    17
    70

    —7—
    3.
    On
    the
    bottom
    of
    page
    28,
    at the end of Ri~e
    203(d) (9) (B) (9v) (c) (3)
    ,
    add after “atmosphere”;
    “except for the portion of grain loaded by
    trimming machines for which particulate matter
    emissions,
    at a minimum, shall equal the reduct~
    achieved by compliance with subpart
    (iv) (c) (2)
    1
    ~r~in.
    4.
    Comments concerning these proposed changes will
    ~
    received by the Board until June
    5,
    1S75.
    IT IS SO ORDERED.
    I,
    Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Opinion and Order was adopted
    on the /,.r~dayof May,
    1975,
    by a vote of
    h-cD
    ~
    Christan L. Mo~f~tt,Cthrk
    Illinois Pollu&i~onConticl :oa~J
    17 —71

    R72—18
    GRAIN
    HANDLING
    &
    GRAIN
    DRYING
    OPERATIONS
    Mr.
    Herbert
    Hoemann
    Executive
    Vice
    President
    Grain
    & Feed Assoication
    1035
    Outer
    Park
    Drive
    Suite
    104
    Springfield,
    Illinois
    62704
    Mr.
    L.
    Carlton
    Anderson
    Cargill,
    Inc.
    P.O.Box 189
    Tuscola, Illinois 61953
    Mr.
    John
    Troyer
    Farmers
    Grain
    Company
    Chestnut, Illinois 62518
    Mr. Lyndel Johnson
    The Pillsbury Company
    P.O. Box 12
    Springfield, Illinois 62705
    Mr.
    Ron Linnick
    Environmental Protection Agency
    200 West Washington Street
    Springfield, Illinois 62706
    Mr. W.J. Krupps
    Consumers
    Grain
    &
    Supply
    Company
    75 Maple
    Galesburg,
    Illinois 61401
    Mr.
    John Beatty
    Route
    1
    Waverly, Illinois 62692
    Mr. Royce
    Huss
    Huss
    & Schlieper
    2230 N.
    Brush College Road
    Decatur,
    Illinois 62525
    17
    72

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