ILLINOIS POLLUTION CONTROL

BOARD

January

1975

COMMONWEALTH

EDISON

CO~

PETITIONER

PCB 74—16

ENVIRONMENTAL PROTE CT ION

AGENCY

RESPONDENT

MESSRS. RICHARD H. POWELL and CHARLES H. WHALEN, ATTORNEYS, ISHAM,

LINCOLN & BEALE, in behalf of

COMMONWEALTH EDISON

MESSRS. MARVIN MEDINTZ and DELBERT HAS CHEMEYER, ATTORNEYS, in be-

half of the PEOPLE OF THE STATE OF ILLINOIS

MR.

MICHAEL 

GINSBERG, ATTORNEY,

in

behalf of the ENVIRONMENTAL PRO-

TECTION AGENCY

OPINION AND ORDER OF THE 

BOARD (by Mr. Marder)

This action involves a request for variance filed January 11,

~974, by Commonwealth Edison Co. (Edison), Petitioner, Relief is

requested from Rules 203 and 204 of Chapter 2 of the Board’s Rules

and Regulations as they apply to five Edison generating facilities.

A request is also filed for relief from Rules 103 and 104 as they

apply to project completion schedules and compliance plans. Edison

filed a motion on October 11, 1974, seeking to clarify its position.

The motion contended that, although it was not inherently clear in

the Petition, relief was also requested from Rule 3-3,112 for three

Edison stations until May 30, 1975. Said Motion asks that the plead-

ings in 74—16 be deemed to include a request for variance from Rule

3—3.ll2~. The Board finds that sufficient evidence has been generated

at hearings to rule on a 3—3.112 variance as well as a 203 variance,

and additional hearings would add nothing to 

our decision. The vari-

ance

pleading will thus be deemed amended as requested by Edison.

At least in part, this case dates back to August 8, 1972, at which

time the Board denied variance to Edison for its Waukegan and Sabrooke

generating plants.

Such denial was without prejudice and Edison re-

filed for variance on January 30, 1973. The Board at

that 

time grant-

ed variance for six months, conditioning the variance on plant load-

ing (variance granted until April 4, 1974) 

This was followed by the

filing of 74-11 on January 4, 1974, seeking a six~monthextension.

Such variance was granted on Septeirier 27, 1974. The present variance

seeks,

in part, to again extend variance for one additional year. Th

above deals only with the Sabrooke and Waukegan generating stations,

whereas 

PCB74-16

in total deals with 

five generating stations.

As”, 

further background the reader

is

referred to

the

following Board

—7

opinions:

Commonwealth 

Edison Co. v. Environmental Protection

Age~~

PCB 72—91, 5 PCB 101; PCB 72—491—492, 73—40, 9 PCB 367; PCB 74—li,

13 PCB 235, 13 PCB 241, and PCB 

74—li, Septer~ber27, 1974,

The instant Petition was filed on January 11, 1974. The separate

facilities were consolidated for hearing in a rather unique manner.

It was the Board~s feeling that much of

the

information to be generated

would be applicable to all facilities.

However, it was also mandatory

to hold hearings in the areas to

he affected by their variance requests.

This was done to allow the public the opportunity to participate at

hearing. Twenty days of hearings were held as follows:

April 2,3,5,8,9, 1974     

at Chicago

April 15, 16, 1974      

at Waukegan

April 18, 1974        

at Rockford

April 22, 1974        

at Joliet

April 25, 1974        

at Kincaid

April 29, 1974        

at Chicago

May 7,8, 10, 20, 1974     

at Chicago

June 

5,7,20, 

1974

at Chicago

July 9, 11, .1974        

at Chicago

At these hearings the Board feels that a complete record was entered

in this matter.

This Opinion will handle system—wide information first, and then

apply this evidence to individual plant evidence in making its decis-

ions. Before proceeding it: is imperative to tabulate as much data as

possible on the subject units. Table 1 includes such data as incorp-

orated in this Opinion.

Statement of Hardship: Edison contends that the hardship which

would be incurred should variance be denied would fall not only on it-

self but on its customers as well. This contention is based upon the

premise that should variance be denied, Edison would be compelled to

cease operations. This is not true, as pointed out by the Board and

reiterated many times over (e.g., Androck Corp. v, Environmental Pro-

tection Agency, PC3 74-3; 48 Insulation v, Environmental Protection

Agency, PCB 7 3-478 E.I. duPontv~ Environmental P~tect~Aency,

PCB 73-533), failure to grant variance is not a shutdown order but

rather a shield from prosecution. Thus Edison’s true hardship, should

variance be denied, is nothing more than being left open to an enforce-

ment action. Edison, of course, has the option of shutting down cer-

tain equipment to avoid prosecution, and this course of action would

cause hardship on Edison’s customers who depend on a steady flow of

electricity. To assess the potential hardship one must investigate

the Edison system as a unit, looking at total capacity as well as re-

quired maintenance outages.

The Edison system (in 1974) has a total capacity of 17,066 mw. This

breaks down as follows:

1. 14,016 mw of fossil and nuclear power.

2. 1,726

mw of fast start peakers.

3. 1,324

mw of purchased power.

15 —8

17,066 mw (Appelgren Ex. 3)

This capacity, due

to

ups and downs of

the various equipment and 

dif-

ferentials

in sales and purchases of power through diverse exchanges,

shifts almost constantly.

The above

figures are best used for a guide,

and items (1) and (2) above reflect actual installed capacity.

Edison projects growth in its peak demands 

well as growth in its

total system. Since these figures seem to change constantly, the Board

will not try to assess the validity of these numbers at some future date,

but will rather deal with the supply and demand in the period which this

variance request would cover. The peak load during 1975 (the area of

major concern to this proceeding) is projected at 14,900 mw. Projected

capacity for 1975 is 16,423 mw. All of these estimates lead to Edison~s

projections that, based on a 14 minimum reserve capacity, 1974 would

show a reserve of 909 mw, while 1975 would show a deficit of 392 mw

(Appeigren Ex. 4).

There is much discussion as to the validity of these numbers and

the Board concludes that if different bases are used, many different

estimates can be reached.

A typical example of this type of projection of numbers can be seen

from examination of Appelgren Ex. 

and 4, wherein growth in peak load

is given and projected. Edison projects growth in peak load between

1974 and 1977 as 6.05, 7.6, and 7.5 respectively. The following

history can be determined from simple mathematics on the above exhibits:

Year    

Actual Peak Load   

Growth in Peak Load

MW

Percent

1968

8950

1969

9265

3.5

1970

10,027           

7.6

1971

10,943          

9.1

1972

11,750           

6.9

1973

12,462           

5.7

1974

14,050          

12,7

1975

14,900           

6.1

1976

16,030           

7.6

1977

17,230           

7.5

The projected increase in peak load between 1973 and 1974 

is

thus pro-

jected at a very high 12.7. Mr. Appelgren (R. 75) states that the 1973-

1974 winter loads were 400 to 800 mw below what Edison anticipated,

therefore casting even greater

doubt 

on Edison~s projections.

While there are many other factors which must be considered when ass-

essing figures of this nature (e.g., purchases, sales, maintenance out-

ages), a detailed description of how these numbers were generated was

not afforded the Board. We can only go by past growth rates and actual

1974 load demand to project what future demands may require. The Board~s

conclusion on this

subject is that Edison~s estimates are significantly

above 

what will actually occur, and Edison~s fear of a serious hardship

on its customers should certain units be curtailed is simply unfounded.

15—9

P1~nt/enit

Jo3.ct 5    

~1,

1950

Joliet 6    

344

1959

J~iiet /      

617

1965

Jo1i~t 8   

617

196(

~abr~ ~e 1    

20

1949

R~ooke 2 

34

19~2

Sabroo1~ 3   35   

.1953

—-

Sdhrooke 4   57   

1961

Waikegan 5 

129

1931

Wautegari 6  

119

1952

-—~——

Waukegan 

~

338

1958

Waukega:: 8  360

Powe~ton 5  850

Kincaici 

616

Coal

Coal 11,481,952

Coal  49,700

Coal 113,052

Oil

N/A

Oil

N/A

1,540,214

Part.

Emiss-1 Comp

ions Plan

148k

148

148’

400’

336’

450’

450’

MW

TAW

‘

PCB74-16__Commonwealth Edison 

System Data

~Annua1

5ta~tup Date Fuel Fuel Usage1 Part.

Tons/Year  Cont.

~‘———H——

Coal ~341,398 

‘

ESP  0.081

Coal

502

Cont.

Comp.

Plan

330 ,646

~T5a3id~T

Comp.

Exp.

SoxIni,

Stack

Ht.

L.S .C

ESP

0.15

~SO~1nj.

L,S,CtlO/1/15 258’

ESP

LS C

.06l—.7~

LS C

SOX

Inj.

ESP

3/1/76 431’

LS C

.061— .7~

LS C  

10/76

SO

In~.

Mech.

550’

LSC

LS C

1.5

Oil

10/76

Oil

Oil

Mech.

On

Oil

550’

148

FEA

prob.

2.0

Oil

Oil

Oil

FEA

prob

On

Coal

Oil

338,850

Two

ESP

0.5 onSplit

l.6S$ ductwk.

coal SO.~Inj.

Coal

291,481

Coal 

981,055

LS C

ESP

ESP

LS C 

12/1/7

.29 on

2.4 ~  

Inj.

coal

TT,’5’~ 

off~’tNe~

Hot

LS coal~ ESP

196,

1~’72

1967

LS C

LSC

LS C

LS C

6/1/76

17/1/76

Coal

928,448

ESP

Coal 2,500,000 ESP

ccl

.1,316,616 FSP

0,4 on SO~In. LSC

LSC-SO3

.027 In corn.

.05

In corn.

In Corn.

None

Gas

G a~

Late

1980

1982

500’

500’

—4—

Thus, the Board finds that placing operational

constraints

on units

which impact on the environment will not create an

undue 

hardship,

and

in our final Order we

will 

do so,

Further complicating the situation of availability is the area of

maintenance, both planned and unexpected. Mr. Robert Engle (April 3,

Pg. 422-434, April 8, Pg. 436-499) testified 

in detail as to how

Edison

plans

for maintenance. Engle Exhibits 

1—4 were

entered as documenta-

tion 

as to Edison’s contentions on this subject.

Edison contends that

actual outages 

for its units are 41 (based on 1961-1973 data) greater

than its planned outages (R, 422), Although 

on the surface this seems

like horrendous planning, it must be understood that “unplanned” out-

ages are actually anticipated when developing the system strategy.

Engle Exhibit #2 then projects the expected outages for the 1974-

1975 maintenance period and anticipates a net capacity deficit for the

months of November, December, January, February, and March. This esti-

mated deficit is including the capacity under question 

in

the instant

Petition. Edison then contends that during the difficult months, Edi-

son would be forced to either institute voltage reductions or forestall

the least critical maintenance (R. 429).

In analyzing Exhibit 

2,

one finds

that the projected differences be-

tween estimated overhaul and projected total outages is very much great-

er than the 41 average depicted in Engle Exhibit 1. In fact, calcula-

tions during this period reveal the following:

Month    

Est. Overhaul   

Total Overhauled  Percent

MW

Dec. ‘74

1800

5600

211

Jan. 

‘75

2500

5600

124

Feb. ‘75     

2700

5600

107

On their face 

these figures

are completely out of context with Edi-

son’s historical averages. On the basis of information given 

to

the

Board, we can only conclude that these numbers cannot support Edison’s

contention that the capacity which is the subject of this Petition is

required to maintain the system’s integrity,

but rather we conclude

that this 

capacity would serve to increase the reserve capacity in the

total system.

The overriding conclusion that the Board must draw from Edison’s

hardship plea is 

that while true in part, it

is highly overexaggerated.

When considering Edison’s compliance plan, the Board will thus 

not

hesi-

tate to order speedy compliance even if it requires prolonged shutdown

of individual units,

~ts

at Corn 

han

cc and Hconomic Imp

act

James Fancher described in detail what the history of Edison’s en-

vironmental control activities is, Edison alleges a total environmen-

tally—related expenditure of $733,000,000 since 1929. This includes an

estimate of expenditures up to 1977. Upon cross—examination it was

noted that much of the monies spent, while “technically” pollution abate-

15_

rent pro~iects, would have beep spent uor ~thor

reasons as ~e~1

ixanpie, ~he construction of smoke stacks and mach ash handling equip’~

aent ~s needed for tue safe and c~deriy ooerat~cn of a puartu

For

sta~’ce, one can not simply dusp ash on the p. ant ite iorever wiuhir

a short .Jme the plant Itself woula ~e huried

The anove ho ~evex

io~to irdicate that Edj son lac not spent corsideraule mcccv on oull

don abatement equinment. As early ~s 

29 Edison insta~.led and opeoa~

ted

an electrostafic

precipitator on one of its units

~i~on 

next details

its intended cospliance plan or tna a ~i iteS

in quest~n. Said compliance plan was sunmitted on March 1, 

~913

CR 243 ~iibit F-3

The compliance olan (see Tanle 1) detailed idi

Jon s rrtenoed method for each of the uniLs ir question,

Bas cally

~ve stirtegies have been considered:

Conversion to Oil: This is the compliance mode chosen for Sa—

~rooke 1—4. Units 3 and 4 

have

already been converted to fuel 

oil. 

Un-

its I and 2 are, as of this date, stil embroiled in a controversy be-

tween the F.E,A, and Edison, but to date conversion to oil iS still

the goal.

Had Edison chosen conversion to oil for all other units, the alleged

cost would have been about 

seven

billion dollars over the life of the

various plants.

II. Conversion to

Low-Sulphur Coal with New Electrostatic Precipi-

tator: 

This is the compliance mode chosen for Waukegan 7. This

alt-

ernate includes the installation of a hot ESP.

Should this option have been chosen for all units under considera-

tion, a

cost of $l.937 billion was alleged.

III. Conversion to Low-Sulphur Coal with Flue Gas Injection: This

compliance mode was chosen for Waukegan 5,6, and 8 and Joliet 5, 6, 7,

and 8. This option, if considered for all units, is alleged to cost

$1,546 billion.

IV. Gasification of Coal: This compliance mode was chosen for Pow—

erton 5 and 6* and Kincaid I and 2. Had this option 

been

picked for

all units, the alleged cost was $4,504 billion.

Edison has chosen the mixed strategy detailed above because of nuxr-

erous considerations which will be discussed further 

in this

Opinion.

The m~xedstrategy approach was estimated by Edison to cost $3,451

billion over the life of the plants, expressed as revenue required by

~

this~~~Ttsin~-

pact on future decisions, both from an environmental impact as well as

an economic point of v~ew,are very helpful 

an aid in formulating

our decision. Hovever, it must be remembered that this unit is not 

ifl

question ~n this proceeding. An~ucipated startup will be in late 1975.

fs such, it .~illin 

no way re affected

by Lhe decisions of the instant

Petition.

15—12

~disor this is equivalen.~to $594 000,000 carital costs Brief Pg. 

4).

Fanche~explained ~R, 254) that v’n~ie econo:~icswere considered,

hey were 

iOc an

overr~din9item in leve~opingthu mixed strategy. This

was dore ~or toe twin reauons ~-ha~ a detailea economic analysis done in

the past indicated that “order of aagnitud~ rankings

tie same and

seconely. because certain options wore sir~~lynot available on certain

units For example, snortage of 0ist~llat fuel oii precluded the total

system conversion to this fuel at any cos 

and severe problems exist 

burning low-sulphur coal on ~ertain cycloce ooil~rs

During consideration of eco~io~iicimuact Ediso r

utilized 

a number of

assuired costs

which stoun. he ruLed *

Cost of re.ouilding f5p**

New ESP*

Cost of L.S.C. over Ill, coal  ‘1 cents/mmBTU

Conversion to oil (Direct)    

$30/kw

F.G.D. (Dixect)          

$63/kw

Coal gasificatlo (Direct)    

$80/kw

Under cross—examination, the subject of economics was hotly disputed

(H.

30 3—412) 

Items of substantiai concern were cost of replacement

(A.

338) and a 15 figure for indirect

escalation

(H. 339)

Particular

concern was expressed over different figures given for identical costs

at different 

times of these proceedings (e.g.,

cost 

of coal gasification

capital).

Financial data are extremely difficult to analyze in that 

various

methods of estimation are possible. Mr. Busch (economic evaluation for

Agency) presented a “financial rebuttal” of Edison’s $3,451 billion com-

pliance estimate. Hr. Busch stated that the method of cost analysis was

not a generally accepted method and that total cost by his methodology

would be $347 

million. Also 

calculated by Busch is the 

total increase

in power production of $.001/kwh, or 3.2 of the 1983 kwn, production

cost. Under cross—examination of Mr. Busch, a number 

of potential areas

of

concern were uncovered (e.g., kwh growth rate projection and cost

of

capital estimates, A, 46-47) 

Again, methodology and 

assumptions play

a very significant part in 

the

final number generated as a total cost

projection.

Mr. Todd Bolen (Supervisor of Economic Research, Edison) 

was called

as a witness to reaffirm the background for Edison’s $3.451 billion

estimate for compliance. Mr. Bolen countered the Busch testimony by

stating that the method of financial analysis used was the “Revenue Re-

quirement” method, which is commonly accepted by the utility field. He

listee a number of 

textnooks

which address themselves to this method

CR, 129)

It must be noted that Mr. Bolen is saying that 

the “Total

revenue request to support the PCB 74-16 variance” is $3,451 billion

*This list is 

b’~

~h~h~read~r   

sr~ferred to~h~

record (4/3/74, Pg. 260 Ex. F-6,7) for a detailed 

description. Also

sue cross-examination.

**Diffjculty multipliers range from 1,1-2.7.

15 — 

—7

(A.

131). The 

thrust of Mr. Bolen’s testimony is that after adjusting

the

bases of Far(cher’s 

numbers, the original Fancher numbers and the Bus

number were similar. The key statement is found on Pg. 158:

“From his testimony (Busch) I have very few leads as to

how he developed that $113 million annual revenue require-

ment, but in my testimony I attempted by several different

methods to show or to reconcile our two numbers, and I think

rather successfully reconciled that we were definitely talk-

ing in the same order of magnitude, which leads me to believe

he was using a revenue requirement technique similar to

ours.”         

(7/9/74, Pg. 158)

The many, many pages of financial data and cross—examination on

these data serve to reaffirm our feeling, that depending on the bases

used and assumptions made, different numbers can be generated. Although

most numbers mean essentially the same thing, their impact seems vastly

different, depending on the vehicle used as a basis (e.g., total costs,

annualized costs, etc.), However, whichever way one chooses to look at

these figures, they represent a significant outlay of capital. The

Board, in reaching its final decision, is well apprised of the economic

impact of our decision and we will use this as a factor in reaching such

a decision.

The Options Available:

As mentioned above, Edison has submitted a compliance plan for the

units in question. Allegedly, this program encompasses the most prac-

tical 

selection of 

options and the most rapid time frame possible. How

realistic the time frame is will be discussed under 

the individual 

plan.t

sections oi this Opinion.

Thissection will deal with the reasonable-

ness and potential problem areas of each option.

I. Flue 

Gas

Desulphurization (F,G,D.) :   As a quick glance at Edi-

son’s 

compliance plan 

(sedTabI~T)~buldshow, Edison 

has opted not

to

use flue gas 

desulphurization in its plans. Edison 

has taken the pos-

ition 

that F,G.D, is not presently a 

viable technology which is worthy

of utilization at its plants, and has thus eliminated it from present

consideration. The Board must, as part 

of its consideration, determine

if Edison is making a good-faith 

effort 

to attain compliance in the

shortest practical time. However, we are not interested in

dictating

what type of compliance mode is used. Our main concern with the 

testimony

in this area is to determine whether Edison has rejected 

a viable method

which could bring about earlier compliance than could its submitted plan.

Mr. Donald 

C. Gifford (Project Engineer, Scrubber Installation*) de-

scribed Edison’s past attempt at utilizing F.G.D. Edison first initia-

ted an FGD project in the spring of 1970. Bechtel Engineering suggested

a wet scrubber operation and the contract 

for construction 

was let to Bab-

cock and Wilcox in September 1970. One-half of 

the

operation was put

in service on February 23, 

1972. 

The

system, commonly known as the Will

County scrubber, is guaranteed 

to remove 98 of fly ash and 75 of SO2.

~sentlyemployedbyEdison;nowaProjectDirectorwitUni-

versal Oil Products.

15—14

The sy~emwas retrofitted to the Will County Unit #1 shich is rated

at 1 ‘7 trw, It is a wet L.mestone scrubber, c~rrpIete ‘ith limestone

miiilng, two—module (A and B) scrubber, and sludge Lr-eatir~ent facilities.

The second stage (A) scrubber uscame operational on upril. 7, 1972.

The

record (4/5/74, A. 47—60) detail~ Pdison s ‘~rperience wish the system.

For various reasons the system lid not funtion anywhere near guarantee I

rati 

ig. Ivailability

of the scrutbrr systom was particularly

disappoir t

~ng.

Ihe longest qonsecutive run on the A scrubber was 21

days (H. 

48)

Availability

i.S

reported for A scrubbcr, 29 5c, and B scrubber, 25.2.

Edison decided on April 15, 1973, to disconti’rue work on the B scrubber

and concentrate on the ~ s~.rubber. rihe problems during the startup

phnse were many and varied.

Of major conccrr were denister pluggage,

rePeater pluggage and corrosior,

e~br~tion

Of

fans, an6 stress cracking.

Many problems cave been resolved, and the rain areas of concern at

pres-

ent

are.

1) Stress cracking of reheator tubes.

2) Limestone blinding of scrubbant.

Sulphate scale formation.

Sludge disposal.

Edison details the costs to date for this scrubber at $16.8 million

and operating costs at 9.4 mills/kwh 

at (35 capacity factor),

Under cross-examination, many of the facts and figures cited were

~ ilenged. The Board finds that, although there is a question as to

validity of the exact figures, the overriding impression is that

this system 

was

particularly troublesome. The fact that Will County I

may not

have been an ideal location for a scrubber installation (H. 70)

is of little value to the Board in that all plants considered

would be

retrofit operations with varying degrees of difficulty. 

Discussions of

closed 

loop 

control (R. 99)

or sludge handling problems 

(R. 137)

likewise do not 

answer the question

of why the system did 

not function

properly. 

While it is true that these techniques are being developed

every 

day, Edison was in 1972 put 

in

the position of having to develop

such a system. They simply were not readily available at the time.

Edison 

further detailed its experimentation 

with an 

$8 million, 22

nw pilot program at its State Line plant. 

This system, termed 

the sul-

fox~.l 

system, produces elemental 

sulphur. Problems with 

the catalyst

system 

have caused Edison to “mothball” the 

system, while 

consideration

of

future 

pilot plant runs 

is undertaken (H. 

69).

Edison, 

however, contends that its decision to 

not consider F.G.D.

is

not solely based on its rather dismal record, 

but also on the cur-

rent 

status of 

the

systems on other plants. 

This area was perhaps the

most 

hotly controversial subject in 

this matter, and 

one which has been

presented to the 

Board 

in other forums (CILCO v. 

Environmental_Protect-

ion Agency, PCB 73-65 

SO2

Inquiry 

Hearings, 

R74-2). In 

the instant

P~~Ton,weThi~

the two divergent views on availability 

and technology

presented by Mr. A. 

Slack

for

Edison 

and

by Dr. H.

Hesketh for the Agen-

The Board feels

it

would 

be useless to again

detail the testimony on

15

—

subject. The pages of the record which the reader is directed 

to,

.uld he wish a

detailed description of each plant, are May 

8, 1974,

1—151; 

June 5,

1974, H. 1—105; and June 20, 1974, 

R.

1—95. The follow—

£ng plants were discussed, along with their merits and disadvantages: Will

County, Lawrence, Mitsui, Duquesne, Paddy Run, Cholla, Reed Gardner,

Southern California Edison, Mohave, Boston Edison, and LaCygne.

The long, 

detailed discussion on the above plants leads the Board to

a number of conclusions.

Much progress has

been made during the past few

years on F.G.D, The hard lessons learned at Will County I and 

in the

original injection processes have yielded new systems in which many 

the original problems are being solved. The chemistry 

of the systems is

becoming better understood, as is the necessity to closely control and

monitor specific parameters such as pH. However, many problems still ex-

ist. Corrosion scaling, vibration, reheaters, and sludge disposal are

among the problems which, while being solved, have not yet reached final

resolution. The Board can understand Edison’s hesitancy to 

install this

technology when, in its opinion, the chances for success are 

below those

compliance methods it has chosen.

The Board takes judicial notice of the document entitled “National

Public Hearings on power Plant Compliance 

with Sulphur Oxide

Air

Pollu-

tion Regulations,” published in January, 1974. Referring 

to Page 63 of

that report, time to install scrubbers 

is listed as between 27 to 60

months, depending 

on the source of information.

Vendor estimates ranged

stallationfrom

30 to

and36

monthsthe

size(obviously,of the unit),dependentThe

onmostdegreeobviousof

candidatesdifficulty

offor 

such systems are Powerton and Kincaid, Due to 

the fact that

both 

of these

units are large (850 mw and 1232 mw) and existing, a 36-month 

installation

time woul.d be expected. Thus, if one considered a jump-off date as 

the

time of decision in this action, compliance could be anticipated (should

scrubbers be opted for) by January 1978, Thus, 

if scrubbers were select-

ed, compliance could theoretically be accomplished earlier than Edison’s

plans for gasification.

The question of the Board’s position on the availability 

and

reliabil-

ity

of

scrubbers does not have to be determined 

in

the instant proceed-

ing, as once again the question is how will an extended compliance plan

(beyond the theoretical 1978 date) affect the environment and thereby the

citizens of the state. 

The function of the Board is not to support one

method of compliance over another, 

but rather to support the most rapid,

viable methodology consistent with environmental, economic,

and technol-

ogical considerations. Our decision

on Edison’s compliance plan is thus

made on its impact on 

the state.

II. Coal Gasification: Edison’s 

proposed compliance plan for Powerton

5 (850 mw) and Kincaid 1 and 2 (616 mw 

each) is the installation of a low

BTU coal gasification unit, using high-sulphur Illinois coal as a 

feed-

stock. Mr. 

J. Augosta (Research Engineer, Edison) explained Edison’s

history in this area, as 

well as the intended plans for the future (5/7/74,

1—133)

Edison first began investigation of coal 

gasification in 1966 and se~

15— 16

a task force in 1970. This task force was to determine

answers to

three questions: I) ability to produce gas from available coal, 2) en-

vironmental acceptability of the gas produced, 3) a timetable to install

a

commercial system.

As a 

result of this study, Edison reached the

con-

clusions that 

no technology

is presently developed 

to reliably supply

power generation

gas, that the 

potential for such a system is very good,

and that coal gasification offered the best option to meet Edison’s com-

pliance criteria on a relatively short—term basis.

Edison determined that before committing to a very large unit, a

smaller prototype should be built.

Powerton 4

was selected as the site

(119 mw)

On May 23, 1971, Edison entered into contract with Lurgi to

provide engineering and other services to Edison,

The cost of this (Pow-

erton 4) project is listed at about 19 million dollars, with Edison com-

mitted to $7.75 million and the Electric Power Research Institute con-

tributing $11.5 million. Groundbreaking is anticipated in late 1975, with

operation starting 30 to 36 months later.

Edison then contends that one

year of operation would be needed ~to shake down and test the system, at

wh.ich time (about 1977) design will start for Powerton 5 and Kincaid 1 and

2. A key point on technology is that Edison has had a 10,000-ton test run

on a Westfield, Scotland, Lurgi gasifier.

The results of this test were

encouraging, according 

to Edison. However, they allege that more work is

needed (H. 12).

Before moving to

the cross-examination, a 

brief description of how a

~~oal gasification plant operates is

in order.

The heart of such a system is the

Lurgi coal gasifier. This is a

high—pressure vessel into which coal (crushed and screened) 

is injected

via an air

lock. Air and steam are also injected 

with the

subsequent

generation 

of hydrogen, which combines with the coal, under high tempera-

ture and pressure, to form methane gas and various other gases.

The final

gas stream has a heat content of about 175 BTU/ft3*,

Ash is removed from

the gasifiers via 

ash lock. 

The resultant gas is then fed to a desulph-

urization process where hydrogen sulphide (H2S) 

is stripped out. The con-

centrated H2S

stream then passes through a Claus kiln (an acceptable 

and

reliable unit process) which produces elemental sulphur.

The intended Powerton gasifier is to consist of three 12-foot-diameter

Lurgi gasifiers (H. 44 and 88) 

It is assumed that any construction of

Powerton 

would be increased by multiples of the same size gasifiers. Ed-

ison predicts preoperation testing of this unit to commence during the

last two months of 1976.

The cross—examination essentially explored two points: 1) the state

the technology, and 2) the rationale for Edison’s extended compliance

dates. It would seem that from experimentation at the Westfield, Scot-

*Thls

is in contrast to high BTU gasification, which is considered as

potential source of pipeline quality gas 

1000 BTU/#3. Low BTU gasi-

fication is economically feasible for power plants because there is no

need to transport the resultant gas 

via

pipeline. Low BTU gasification

viates the need for the costly and rather intricate methanation step,

ch would boost the BTU value by reaction with excess hydrogen.

15— 17

land, plant, a ccnsiderabl? part 03 tn~ r~~xwas rerved;

indeed .r

substanrial amount of Ii1~r.ois coa was ga.~Fued successfuliy.

SO~

clear up ~quipment

~as preser t and at ~ized on site,

The Wes ~fr eld

operationgas

‘~o the

startedarea

resfdentsup

about

since1960 tnonand

has been supply~ng 240 BTJ/ft3

Another plant of 

interesL is the Sasol plant in South Afrrca. 13115

plant consists of about thirLee~ ~2iloot—oiaueter

oxygyn-blowr gasitera

used to produce feec for a petrochemiual ‘~peration.

‘h e tar cenerated

is not

~ecirculated’ 

there is no pollution a.oaterrert and a o~—qraae

coa~ 

is gasified

(R.

61)

However, upon an inspection of tro plant

Edisce

~ that the ope’~ation was relatthely reliahle

I~- wcrld seem that tne major point of technology which is untried

tire udaptataon of a utility boiler

to accept a low BTU gas 

feed. it

~sL be remembered that in using low

BT’J 

gas

as a feedstock, a much

~reat.er

volume of gas must be fed and the boiler must be adapted to

suit.

Taking all of the testimony into account, the Board finds that Fdi-

son

is embarking on a project which has an excellent potential for suc~

cess. Furthermore, 

promises 

to open a viable alternate to 502

re-

moval, one which can be economical, clean, and still use our abundant

supplies of high-sulphur coal. However, the Board finds that Edison’s

timetable is unduly extended. Edison proceeded slowly and cautiously

since its task force 

was formulated

in 1970, and as such, valuable

development time was lost. Attention is drawn to a memo (internal to

Edison) proposing one gasifier on Powerton by 1973, and 

five

gasifiers

oy 1975 (H. 84). There is no good reason why this program was not

pushed harder than it was. Therefore, the Board feels that every poss-

ible barrier should be removed to expedite this program. We further

feel that the 1980 date for Powerton 5 may be excessive. We do not

feel that 

it is

necessary to delay design of Powerton 5 until after one

full year of experience on Powerton 4, nor do we feel Kincaid 1 and 2

should be further delayed. We do feel that the bulk of construction

costs should not be spent until Powerton ~ is proven, but also feel that

construction should start as soon as Powerton 

4 is tested,

e.g., early

1777. This rationale will be applied to our Opinion concerning the in-

dividual stations.

III. Low-Sulphur

Coal: Switching from high—sulphur coal to 

low-sul-

phur coal 

the option dh~osenfor Waukegan 

5, 6,

7, and 8 and Joliet

5, 6, 7, and

8. However, Edison alleges certain problems exist in burn-

ing low—sulphur coal. Before exploring these problems it is necessary

to note

that Edison discounted the use of low—sulphur coal on Powerton

and Kincard 

and 2. This decision 

goes

in part to the alleged ur-

availability 

of low-sulphur coal.

Mr. G. Marcus (fuel agent, Edison) detailed

Edison’s attempts at

securing additional 1ow~sulphur 

coal (4/9/74 H 615—624)

It was ex-

plained that

almost 

all low-sulphur coal must be

imported from 

the West

because Illinois produces 

sucn coal 

for utrlity use,* An interest-

~

small amounts of fairly .Low-sulpnur coal (1.5)

are mined

nn Illinois,

it is used for making coke.

— 18

—

—

ing statistic quoted 

Marcus was that 

in 1969 the state of Montana

mined 500,000 tons of coal and 

in 1973

Edison utilized 5.5 million

tons from Montana. This figure was entered to point out the fact that

new mines will have to be opened 

to generate

more coal as 

is needed.

Marcus Exhibit #2, summarized below, shows Edison’s deficits in commit-

ted low-sulphur coal ranging from 0.5 million tons in 1974 to 11.6 mill-

ion tons in 1980, which indicates that new sources will have to be com-

mitted in 

the

near future.

Year Low Sulphur Coal Required Low Sulphur Coal Obtained Deficit

1974

9.35 

million

tons     

8.9 million tons  

0.45 million

tons

1975

11.7            

9.1

2.6

1976

12.0             

9.3

2.7

1977

13.4            

8.8

4.6

1978

15.4            

8.7

6.7

1979

13.5            

1.9

11.6

1980

13,5            

1,9

11,6

TOTAL DEFICIT 40.3 million

tons

Mr. Marcus then detailed Edison’s efforts to procure additional supplies

of low-sulphur coal (H. 618-620). Efforts to date have been very disap-

pointing (H, 621) as summarized below:

Date   

Number Bids Let  

Volume Coal   

Number Valid Volume Ob-

_______________

Required (Years) Bids Received tamed

March 73    

11

24 Million Tons     

2

6.9 Million

(1975—1978)             

Tons

Sept. 73     

21

16 Million Tons         

Bid under con

(1977—1987)           

sideration

(R 653)

Oct. 73     

17

72 Million Tons         

Bid rejected

1979—1989)             

(R 655)

Summing up this experience, Edison in 1973 was able to obtain only 14.3

million tons out of the 52 million tons required for the years 1974 to

1980 (R. 622). These deficits do not include the Powerton or Kincaid fac-

ilities where coal gasification is planned. If Powerton and Kincaid were

included to use low—sulphur 

coal, 

the yearly deficits would increase to

million tons 

in 1979 

and 1980 (Marcus Ex. 3). Because of the scarcity

of low-sulphur coal and the fact that the Kincaid plant is a mine mouth

operation, consideration of low-sulphur coal for these units (Powerton

and Kincaid) was 

rejected. The logistics and reliability problem in

transporting western coal was discussed by Edison in an attempt to 

rebut

the

Agency recommendation for coal blending at Powerton.

To acquire the

required low-sulphur 

coal (2.3 million tons per 

year) 

a new coal 

mine

would have to be opened, which would take 3 to 4 years; five sets of loc-

omotives and 500 railroad cars would be necessary. In addition existing

coal cars in Illinois could not withstand the rigors of a 2500 mile round

trip and thus could not be used (7/11/74, H. 24-25),

In 1970 Edison was the first midwestern user of unit train deliveries

15

—

of ~oc—s~’ nirur wes ..e’u ~oa

Dud .v ther~ ~ne

Ji)

ry austome~s :)r wester

oal, in the midwest rr.d uisn~he:~ ~nd .fiison uxprerTed cunccrn ahu’L

one abi Ii cy of tfi rafir ad~ ~o I unOle the ~r ~u r~a1~traffi

ef5in ~eno~

~y ani rfi ~auiy

part~e nrary surce ~fiao r reeds ~e. rile ~uil suu~iie~

ll/~4, R. 27

This oncerr ics expressed ii re.ards fi the 2.3

il1,iion t. irs per year of lo~’~sulphur

cc r~ jf rtel blenfi

at ?owcrton

as to occur.

The Board is concur~ed auoui ld~sor ‘s anil:ty to obtaa~.

s uric ect

and reliable supply 

of low—sulpnur wes.~ern .oa. eased

o~..croading of

the

ord

in this 

case. We will therefore require at any fit ~re er~en

sions 

is variance firm ~ow.Lrgs

that ~‘dison 1, has o~tarncd r~.rn

coms ~m

for low—solilur coal, ~ has ibta~red abe

ao~

tv no ~rnns

~rt

su~r c~aa to ils plant site, 3’ nas ~orkcd out alternate o mpiirnce

inns ul ~uld the above two conditions be unfulfilled.

~‘dison next moved to detail the probleurs ercoantered in nurning low-

sulphur coal on existing units.

The problems center about two areas: first

the use 

of low—sulpaur

coal with conventional 

E.S.P.’s causes a degradation in the equipment s

capture efficiency. This consequence, 

first noticed a number of years

ago, is now a well-established fact The following table 

details the

loss of efficiency actually encouncered at Commonwealth Edison’s Wauk—

egan #8:

3

BTU Coal

10987

11069

10627

11371

9820

Sulphur   

2.79   

2,16

2.97

0.82

0.45

Coal

Outlet #/mm 0.067   

0.071  

0,060  

0.518  

0.335

BTU

Efficiency  

98.6   

98.4   

98.9   

87.2  

88.1

The table clearly shows the mentioned degradation and resultant em-

issions of large amounts 

of particulates to the atmosphere. There are

two possible solutions 

to this problum. One is the construction of ‘~Hot”

ESP’s 

which are 

units installed before the

air preheaters. At 

this

nigher temperature the resistivity of 

the ash is

such that ESP 

efficien-

cy increases to acceptable levels. It should be noted that 

at these high

temperatures the size of 

the

ESP must 

be significantly larger

so

as to

accept 

the

increased volume 

of the

gas. 

The retrofitting of such units

is a long-range project and would not be available

by May 

1975 (see dis-

c~1ssion cc Waukegac ~)

;

therefore, 

if low—sulphur coal was used, there

could be a trade-off of pollutants.

A second method of solving the ESP

degradation problem .s ‘flue gas conditioning.”

This project injects

sulphur trioxide direct~.y into the flue gas; the SO3 then precipItates

out

on

the partlculates,

which increases the migration velocity of tne

fly

ash and thus increases ESP efficiency.

15 —20

—

—

The second main area of con~’err i.n uti1izin~ low—sulphur coal is the

potenc..al i r fires or exp1o.~icrrs

.~r

cern

types of ooileru

Cyclone

filers

are particularly susceptJble t this type of problem. The

prob-

is es sentiaily caused by high ~ar~on c r

‘c

icr u~,eurned coal) which

c uld Lir~r be ignited outside of the boilcr,

‘ausing 5.amaae to the pre

heaters and LSP’s.

Information ger.e’~ated ly Bdis’n indicates that a

solution to the proble’~ is fortnco~rng.

ihe above problems are alleged ~r’ be the main reason why compliance

with both Rule~ 203 and 234 carrot he ..~cconpltshed sImultaneously.

The

ditt~ cu...ties as they relate to each sp~cif c p3 ant will be discussed

ater in this OpinIon.

IV. Supplemental Control 

Systems (Sc.S) : Altiough not a permanent

system, SCS has the advantage of allowing attainment 

the short-term

air quality standards

on an 

interIm basis,

Due to the reality that Ed~

ison 

will not be

in compliance 

with Rules 203 and 204 at many

locations

by 1975, it

is incumbent for 

the ~3oard to investigate methods which would

reduce the impact of such discharges on tire citizens of the state until

such time as permanent capture 

equipment (or fuel switching) can be in-

stalled.

A brief overview of

what an ideal SCS system is and how it would

function is given in the following paragraphs.

A supplementary control

system can be defined as “Systems where the

rate of emission from a

source is curtailed when meteorological 

condi-

tions conducive to high ground-level pollutant concentrations exist

or

are anticipated”

(Federal Register, Vol. 38, No. 178, p. 25698, Septem-

ber 14, 1973). 

is, in fact, a program

incorporating real time moni-

toring of stack emissions, meteorological conditions, and 

air quality

data with a numerical scheme for the determination 

current and fut-

ure ambient air quality in the vicinity of a specific source, such that

when selected levels of ambient air quality are obtained or forecast,

specific emission reduction activities can be taken.

As a practical matter, such 

controls can include:

I) fuel switching,

2) load shifting, or

3)

curtailment 

of the industrial

process to reduce

emissions during periods when air conditions are 

not optimum

for dis-

persing and diluting SO2. These systems, 

though

apnearing under dif 

f-

erent names, have been used by such diverse entities as the Tennessee

Valley Authority, at its Paradise plant, American Smelting and Refining

Company, 

its El Paso and Tacoma smelters, and Dow Chemical Company,

at Midland Michigan.

Though 

all

interim control strategies are somewhat different, the

basic elements

of these systems 

are fairly common,

The universal ele-

ments 

of all systems

are as follows:

1. Equipment to measure the actual recil time meteorologi-

cal conditions surrounding the plant.

This is

necessary

for both predictive functions 

and to keep the operator

aware 

the conditions 

at the actual time they

are hap-

pening;

15

—

21

—

15

—

2. A model 

based

on past meteorological and dispersion

data that will predict atmospheric conditions as to

both weather and as to conditions which would influ-

ence dispersion of contaminants;

3. Actual source emissions. This must be real time and

constant to the operator so as to be aware of what

the plant is discharging to the atmosphere;

4. Predicted emissions. This is necessary for the oper-

ator to know in advance what conditions he will be

operating under in the future so as to determine

whether the atmospheric conditions will be adequate

to disperse what will be emitted;

5. A dispersion 

model. This, of course, is necessary to

predict the concentration of contaminants, once em-

itted under certain atmospheric conditions, so as to

determine whether control strategies must be instituted.

6. Validation of model. This 

is

necessary to determine

whether the model is

in

fact reflecting actual condi-

tions and would be done through real time monitoring

of both contaminants in the ambient air and meteor-

ological conditions;

7, Indications and trends as to potential violations.

This is necessary in order to give the operator a

framework in which to make decisions as to when to

institute a control strategy;, and

8. A strategy to control emissions. This, of course,

is the ultimate function of the control system. Such

strategies can consist of load reduction, fuel switch-

ing, load shifting, and part-time use of permanent

controls when 

dispersion conditions would seem to in-

dicate.

It should be noted that there will be no standard supplementary control

system.

A supplementary control system must be developed for every plant

to which it is applied. Such factors as terrain, meteorology, process,

stack height, and congestion of the area are all factors which must be

considered.

Though all 

systems will not 

be alike, they will all have certain bas-

ic hardware in common.

These include monitors for the contaminants to

be measured. The number of such monitors 

would depend 

on the plant and

its location, and could range from just a few monitors to as many as

18 to 20, Also, the system would have to have certain weather monitoring

devices so as to measure the conditions surrounding the plant.

These

would all have to be on direct hookup back to a central operations point

where an operator of such a system could at any time get information

from the monitors and the meteorological equipment, A third element

would necessarily be a computer, which could be used to correlate all

real-time data with all predicted data in the models so as to determine

—

22

what the conditions are and wnat tire coneitions are liable

to

in

the

resr future.

Such data transmission r,i~ht also be hooked into the en-

aorcicg agency directly for eas~ of snfo~cemcnt

The most important

clement ~s not really a piece of ~ardwaie,

ot is, in fact, a plan which

woufi indicate that when certain levels

are

reached or are

predicted 

be reach~a bu~ing a time span in the fut~c.e, certalr set plans would co

nto cfiect at the plant to brIng emissicn~ ~niLo line wrth those which

would cot cause violaLior of any standard that applies to

the plant.

On September 14, 1973, the

Environmeila~ fiotecfion Agency

pub-

listen rules and gu.deiines for a

i~~i

mstntary ‘~ontrol anstems (38 Fed—

eralPegister

25698 September 14, 1fi3

ihese 

ruler nave never beec

is~aed as final, but they do glve insight into requirements

for an SCS

system that tire federai govern era tn~ugna wore minima~ at that

time.

It should be noted that even at this time the proposed guidelines

would

only 

allow

supplementary control systems to 

be used in situations where

their 

use was

necessary to augment constant emission limitation tech-

niques 

which were available to a specific source and

only until 

com-

pletely 

adequate, constant emission limitatron 

techniques became avail-

able. This could be summed 

up to mean that it would be allowed in sit-

uations where the sole alternatives

are either cutting back production

permanently or delaying 

the

attainment date 

for the national standards.

The basic requirement of the federal guidelines is reliability ir

the system. Before allowing SCS to be used, the federal government 

al-

so would require each user of 

SCS to support and participate in 

ap-

propriate research development 

and

engineering and a demonstration pro-

gram to 

insure

that the SCS system can 

be replaced by

constant emission

limitation techniques as soon 

possible. This would be expanded to

indicate that SCS would not be allowed on new or newly-modified sources,

but only on present existing sources.

One of the major concerns relates to 

the

enforceability of the regu-

lation for meeting the national ambient air quality standard if an SCS

system is instituted for a stationary source. 

is feared that citi-

zen enforcement of the Environmental Protection Act would 

be

discouraged

because of the difficulty of determining whether ambient air quality is

being 

met,

as compared to a simple determination of whether emission lim

itations are being met. Indications are that an SCS system is validly

enforceable under the regulatori scheme as exists today with certain mod

ifications. There are basically awo methods of enforceability. The

first, of course, is actual measurement of the ambient air quality to

determine whether the national standards are being violated. The second

method is by making the SCS control plan enforceable on its face, with

the regulatory determination that failure to comply with all terms of

the plan is a prima facie violation of the standards.

Mr. Melvin (Illinois EPA) testified 

that an SCS

would be applicable

to Kancaid (R. 81)

but

that it would be very difficult

in a major met-

ropolitan area (Powerton) 

Mr. Melvin further testified

that

he could

give no cost

estimates 

for such a system,

nor could he estimate the

time required 

to install such a system. The Board feels

that an SCS

system 

is needed in areas where extended

compliance 

plans

are to be un-

dertaken, 

but

fully aware that some tIme 

must be allowed

for a form—

—

23

—

—

ulation of a plan.

Our Order will require such planning and eventual

installation

of a 

viable permanent emission control system.

Environmental 

Impact and Compliance at Individual Power Stations

We will now turn to discussions of individual plants, detailing the

intended methods of compliance and the environmental impact of each

facility.

~

The Waukegan Station 

located 

Lake County, Ill-

inois, a part of the Chicago MMA. As such, Rule 203 dictates particu-

late levels of 0.1 by May 31, 1975, and Rule 204 dictates levels of

l,8#/mmBTU

~°2 by May 31, 1975.

Environmental Impact: The subject of environmental impact is of

critical interest in any decision the Board renders in this action.

The Waukegan station is located within the city limits of Waukegan at

Greenwood Drive near Lake Michigan.

On April 16, 1974, Mr. Jack Klingbeil (representative of CAP) test-

ified to the effect that they were concerned that Edison’s progress has

not

been good in complying with Board regulations. 

urged the Board

to put maximum pressure on Edison to insure speedy compliance.

The effect of Edison’s discharges was discussed by both Fancher

(4/15/74) and Melvin (7/11/74). Both witnesses discussed the results

of model data that had been generated.

Fancher’s data predicted the effect that the ~  

an ati2~* will

have 

on

ambient air quality by May 30, 1975~ Assumptions include the

following:

1, Edison’s proposed compliance plan is on 

schedule.

2. Full load operation.

3. Stability Class 2 conditions.

The results of this computer model reveal the following:

Unit

SO2

Rate 

Max.

24 Hr. Max. 3 

Hr. Part.

Rate Max. 24 Hr. 

Max.3Hr~

2,70#/MBTU

2.70

27.3ug/m50.6  3 

143.277.2

ug/m3

0.28O.50#/MBTU 5.25.0

ug/m3

14.814.3ug/m3

7   2.70    

37.5   

106.2    

1.87   

26.0    

73.5

8   2.70    

38.6   

109.3    

0.07   

1.0

2.8

Total

134.0

379.1

37.2

105.0

Standards    

365

1300

260

*ft must be noted that these 

figures, as well as Melvin’s figures, 

de-

tail the effect of plant emissions 

on the ambient 

air, NOT the 

projected

air quality in the area as a 

result of all emissions. Of further

import-

emittersance

is that(overin

200the

tons/yr.)

immediate

WaukeganOf

these four,area

thereEdisonareaccountsonly fourformajorabout SO2

87.5 of the total load. 

Therefore, Edison should have the dominant 

in-

fluence on 

ambient

air quality as it pertains to SO2. This discussion

— 24

—

—

Upon cross—examination, a 

number of weaknesses in the model were

pointed out.

Most notably, the model does not take into account fumi-

gation or inversior effects.

Fum~gatior is particularly

important in

this case 

in that the plant is rocated directly adjacent to the lake

In addition, certain topographical conditions are not considered. Some

of the omissions

in the model presented cause 

the Board to conclude that

the data are given slanted 

low, However, the fact that 100 load was

used to generate the model would tend to overestimate the results. Be-

fore drawing any firm conclusions we will turn to Melvin’s testimony.

Mr. G. Melvin (Ill. EPA 

Episode Unit) entered Melvin Ex. #2, whicn

is an analysis of Edison’s contribution to the air quality in the sub-

ject areas.

Mr. Melvin’s data was intended to predict concentrations

at the 

worst conditions, as well as other conditions.

The following is

the result of his study.

I. Under trapping conditions, Waukegan will not cause (in it-

self) a violation of tie 3-hr. SO2 standard (Pg 13, Ex.

11.

2).

2. Lnder fumigation conditions, thukegan has the potential

for vlolat~ng the o.5 ppm. 3-hr. secondary standard

(see 

Ex. M—2 Table 12)

3. Estimates of daily (24—hr.) concentrations

under nor-

mal meteorological conditions 

show both SO2 and part-

iculates belov the standards (sea I’1-2, Table 

18, e.g.,

S02--.04 vs. Standard of 

0.14, part.

vs. Standard

260)

The conclusion would be that under adverse conditions the Waukegan

plant has the potential to exceed the short-term (24—hr. 

and

3-hr.)

standards 

for 302

and particulates. 

This is best pointed out by Ex.

M-2, Tables 

21 and 22, which give maximum short—term concentrations

under adverse meteorological conditions,

Under cross-examination, many 

the assumptions (e.g., plume rise

equations) were questioned, as were Fancher’s assumptions.

In studying all data presented, the 

Board

feels that a potential ex-

ists for violation of short—term standards. To protect against excess

violations and yet allow the use of equipment which is needed for pow-

er generation, our Order will dictate operation loading for W-7, and

early shutdown for W-6.

Unit 

5 is a 129 mw unit fired by a pulverized coal, wet—bottom boil-

er.

The boiler 

utilizes 1.3 sulphur coal

and is anticipated to still

utilize coal with this sulphur content on May 31, 1975. Emissions while

burning this coal are expected to be 

0.5#/mmBTU

until December 1,

1975,

at which time an SO3 injection system will be installed. Edison states

that the duct work on Unit 5 will be modified to incorporate two ESP’s

and this will 

thereby

reach

the aforementioned 0.5#/mmBTU. 

This work

~~not  consider st~kheighE~nd its effect on dispersion. This in-

formation is from the

Illinois EPA emission inventory.

15—

25

—

snould be accomplished by December 9’4,

Tino coard finds thaL

this 

elan is .ceasonaele aria will endorse It.

Variance will be granted from O~tober .5, ~974, to October 15, 1975,

rub~ect to conditions of particulate discharge and sulphur content of

toe coal to be burned.

Tariance will also be granted to allow 502

emissions over

the

l.8#/mnr~BTU Level front May 31, 1975, to October la,

19/5, subject

conditions 

of maximum emissions tied to sulphur com-

tent of the coal. 

The provisions for monitoring and reporting of PCB

74-11 will also be required.

Unit 6  

an 119 mw unit fired by a cyclone coal-fired bo...lei’ The

hoilert~

~za~ 

and will continue to utilize a fend of coal of about

suaph r.

Emissions are presently in tne range of 0.3#/mmBTU (run

2.6

c’u.~phur coal)

Edison contends that when burning low-sulpiur

deterioration of the system is encountered due 

to high carbon

us ‘yover.

This problem will be attacked by boiler modifications as

suggested by Babcock and Wilcox. 

Parts for

this modification were to

be delivered by November 1974, and Edison proposes a shutdown for mod-

ifications during the second quarter of 1975 (H. 12) 

Edison then pro-

posed to 

start design of a flue gas injection system with eventual com-

pliance by June 

1976.

Under cross—examination the element of time was examined. In re-

sponse to a question as to whether the modifications could be moved up

to begin as soon 

as the 

part arrived, Mr. Holyoak replied: 

“I believe

might be possible, but it is a function of what else is going on

the system.” (H. 

51,

4/15/74)

The Board feels that particulates are a problem 

the residents of

the area and should be controlled in as short a time as possible. In

line with our above reasoning in regards 

to the system availability and

maintenance requirements, we will not grant variance any longer 

than

needed to start boiler modifications. In relation to the SQ3 injection

system, the

Board must 

differ with Mr. Holyoak’s statements that flue

gas conditioning technology is

still in 

the infant stage (R, 23)

and

that design of these systems should be staggered. The Board takes jud-

icial notice of the article,

entitled “The Performance of Electrostatic

Precipitators in Relation to Low-Sulphur Fuels,’~*

in which reports 

the commercial use of this technique date back to 1963. We find no rea-

son for Edison to defer the design 

and installation of this equipment.

Variance 

will be granted until October 15, 1975, subject to Edison in-

itiating

design and installation of its SO3 system as soon as 

Unit 6 is

modified and on stream.

Unit 7 Is a 617 mw unit fired by a dry-bottom boiler which 

utilizes

pulirerized 

1.6 sulphur coal. This 1.6 coal

is

intended for use after

May

31, 1975 (H. 139, 4/15/74).

Sulphur dioxide emissions from this

unit will thus be approximately 3.2#/mmBTU (based

on

10,000 BTU/# coal)

but will tary with the heat value of the coal.

Unit 7 is equipped with

an ESP which was originally rated at 98

efficiency on high-sulphur coal.

an

attempt to increase the ESP efficiency.

Edison undertook testing

*By K. Ja

and C. Win its

a.d,Second Internat ional Clean Air

Cbn’-

gress, pg. 

911 to 922.

15

—26

with an additive known as Mopper K (testing about July 1971), Such

testing did not increase efficiency and was discontinued. Upon inspect-

ion of the

ESP, it was noted that the plates were coated with fly ash

and Kopper K. This situation decreased the efficiency of 

the ESP

so

that further stack tests revealed 

outlet of 

l.27#/rnBTU.

(Test run

7/20/71, see 4/15/74 Ex. G,M,—2,)

The projected repair bill was set

at $4.8 million, with no assurance that low—sulphur coal may

be used

and compliance achieved. Edison then contacted Sargent and Lundy and

contracted for the installation

of a hot side ESP which would allow

compliance with Rule 203 while burning low-sulphur coal. The antici-

pated completion date for this project is December 1976. The reader

is referred to 4/15/74, H. 15—17, and Ex. 

11-3

and

4 for details on

this plan. Edison contends that 

the length of time required for

com-

pletion is necessitated by the location (120 feet in the 

air)

the

new unit. Edison also contends that a recent experience with a retro-

fit ESP installation on Will County 3 dictates this length of time. Cap-

ital cost 

is estimated

at $19

million (Exhibit F-7 a)

Upon cross-examination, the 

reasons for the delay were explored (H.

56-59,

H. 75-78) 

Although the

Board 

feels that some excess may be

built into the schedule, Edison’s recent experience with Will County

3 leads us

to believe that the proposed schedule is realistic. We

will allow the proposed timetable subject to review of progress at any

further proceedings. Variance will be granted subject to many of the

conditions detailed in the discussion of the Waukegan 5 and 6 units.

However, due to the excessive particulates generated by this unit, its

use will be curtailed,

Unit 8 is a 360 mw generator fired by a dry-bottom boiler burning

pulverized 1.6 sulphur coal. Very little discussion is needed on

this unit. A long series of testing has been undertaken by Edison in

the use of SO3 injection (details H. 18-21) 

The system should now be

in operation. It is noted that in Petitioner’s Motion for Modification

(October 18, 1974) further delays to November 1, 1974, were anticipated.

This Board has no sympathy in this regard. The operation of this sys-

tem is an integral part of Edison’s compliance plan and must be pursued

with all possible vigor. The Petition will be denied.

Sabrooke Station: This is a small (146 mw) generating station loc-

ated in Rockford, Illinois. The plant was purchased by Edison from

Central Illinois Electric and Gas Co. in 1966. The plant is located

on the east side of the Rock River in the southern part of the City

of Rockford.

Units 3 and 4 are presently oil-fired; therefore, they are in com-

pliance and will not be considered further.

Units 1 and 2 represent a rather unique problem. Edison’s original

prayer for relief was as follows:

“...and in the event that Edison is not able to proceed

with its plans to convert the Sabrooke Station to oil fir-

ing by the end of 1974, to such dates beyond May 30, 1975,

as may be established by a compliance plan to be submitted

15—27

to the Board by July 15, 1974.” (Pet. 74-il, Pg. 50)

As Fancier’s testimony of July Il reveals, Edison~has not yet re-

ceived final word on its appeal to the Federal Energy Office regard-

ing its request

burn oil on Units I and 2. Neither has Edison sup-

plied the Board with 

an alternate compliance plan. The first indica-

tion that Edison

wishes 

to change its prayer for relief is revealed in

Edison’s closing brief as follows:

“Accordingly, Edison requests a variance for Sabrooke

Units 1 and 2 for one year, provided that within 60

days of a ruling by the FEO on Edison’s request to burn

oil in these units, Edison will submit to the Board and

Agency a specific program for bringing these two units

into compliance.”

(Brief of Petitioner,

Pg. 42)

If the Board granted such a prayer for relief, it would condone a

variance granting leave to 

file a compliance plan hinging on actions

of a third party (FEQ),

This we cannot do. Furthermore, the unortho-

dox manner in which Edison chose to amend its prayer for relief is

highly questionable (in a closing brief)

The record, as it pertains

to Sabrooke,

fairly complete and may be used in any future proceed-

ings.

The

Board in particular takes

note of the testimony of Weeks,

Reeder, Estes,

and Galinsk,

all citizens of Rockford

who

attested 

the nuisance generated by this facility.

The Board, however, realizes that Edison’s attempt to achieve com-

pliance was made in good faith and the failure of such compliance plan

was not Petitioner’s fault. We 

will thus grant a short variance to

allow protection (subject to cOnditions)

while a resolution of the

FEO dilemma can be worked out.

It is realized that

by January

30,

1975, Edison can, if necessary, reinstitute

proceedings in the Sabrooke

matter and rely on the record generated in this proceeding.

Joliet Station:

This consists of 

two

separate facilities which lie

on opposite sides of the Des Plaines River,

Will County, Illinois.

Units 5 and 6 are located on one side, while Units 7 and 8 are on the

opposite side of the river. The two complexes 

are connected by an

overhead suspension bridge used to transport coal from the unloading

facilities

located on the Units 5-6 side of the river.

The plant is

about one mile

from

the

city 

of Joliet and Units 7 and 8 adjoin the

community of

Rockdale,

Environmental_Impact:

As in the case of the Waukegan plant,

modeling data was discussed by both Fancher (Edison) and Melvin (Ill.

EPA)

The cross-examination

and assumptions used by both witnesses

followed the same lines as in Waukegan and they will not be detailed

in this section.

One major point, however, must be raised: Edison

bases its statistics

on Units 5 and 6 burning 3,5

sulphur coal and

Units 7 and 8 burning low-sulphur coal by May 31, 1975 (4/22/74, H.

84)

Melvin Ex. 2 seemingly uses the same assumption (see Ex. 2, TahIa

The following are results geherated by Edison’s study:

(uq/rn3) 

24—hr.

~1r. Melvin’s study reveals

the

following:

Under fumigation conditions,

the plant has the potential

to violate the 0.5

secondary ~

standard (see

M-2 Table

14)

2. Under fumigation conditions,

rj1~~t~

7 and 8 have the pot-

ential to violate

the short-term particulate standards (see

M—2 Table 17).

3. Under normal conditions, the

expected 

contribution to the

24-hr. 

air quality with wind direction aligning Units 5

and 6 with Units

7 and 

as foi:Lows:

0.06 ppm ~ 

(Standard 0.14)

30 ug/ra3 part. (Standard 260 

ag/in5)

Table 17

from 

Melvin Exhibit 2 has been included in

this 

Opinion so

that the method of presenting data is available for 

examination (Fig. 2:.

*Once again,.

the reader is

reminded that

this series

ot studies re-

flects

the

contribution of the plant or:

the air

quality.

In the Joliet

area, the

oercent of

load 

from

Edison is not as great 

was

in

Wauke—

qan. There are about 11

majo:r SO2 sources

in the 

general Joliet area

(200+ tons SO;,’yr.) between Lemont on the north and Channahan

on

the

south. Total emissions from Edison are

srojected 

at 153,113 tons/yr..;

~son’s

contributions

are

57.5.

~ must also be noted

that these fig-

are from the Ill, EPA emission inventory and reflect

emissions

prior ~ 

:1975.

It is quite possible 

~in

the case of Edison reduction 

pur-

suant ~ compliance plan) that both the total emissions and Edison’s 

con—

Unit.    

Emission

Rate #/:nBTU

Average

Cone.

s--ar

5 (1

i (1

stack)

Part.SO2

502

Part.

6.60

0.08

6.60

0.19

3515

4.4

357.9

10.5

1.6

126.5

3,7

502

Part.

6.60

0.12

243.. 3

4.2

86.1

1.5

~°2

Part.

2.10

0.90

74,3

32.3

26.3

11.3

502

Part.

2.10

0.90

74.3

32.0

26.3

11.3

Total

SOPart,2

7:15.9

73,0

253.0

25.7

Standards

SO~

Pa~t.

1300

365

260

15— 29

SWINARY OF 

CALCULATRO CONTRIBUTION

TO Asm:EuT

MS OJJITY

•~,

V~’~r~~0LOGICALcONDITIONS

FACILITF .Joliet Units 7 & 8

FIGURE ~2

POLLUTANT Particulates 

(ugsr3)

5Three”hour average

Wind~peed Class (Knots)

Cumulative Frequency Distribution of axheum Rourly

Particulate Concentr~tion~fot the

Atmospheric

..‘~,..~ •~-

1—3   

4—6   

7—10   

11—16   

17—21   

21

94

128

Stability A

2

a*************s ****s**a*****sa**********ss**sa*s*54*****a*,***a**s****,**a,

34

68

85

Stability 3

11.5   

5.3

3.7

1.110 

•

2.233  

1.575

s****~,s******* ***k*~’’*****a*****as*s****s*a**a*a***********s*s*s***a*****

26

43

60

68

68

68

Stability C      

15  13.5   

8.6

6.1

4.9

4.4

1.055  2.472  

6.232   

.952    

.034    

.021

*,.,*,****s****

~*****s*************,a*s**a***a*aa*****ss****ss*,**a*s*aa*ss

9

9

9

17

17

17

Stability D    

15

15

15

15

15

15

1.657  9.705  20.868  

19.382   

2.438    

.555

****,*********s

**********a*5**a*~*********5****,********s*********,’**aa,ss*~

00

0

Stabi1ityE&~ 

——

7,082 15.862  

6.061

**a*a*********e s****a*****s*****a**aaa*a****aaaaaaa*ae**~*a~****,**a***aa**#

196

222

Trapping          

3.~

2,8

Stability ~B       

——

a****a******s*a 

*********************5*a****5****,.~*****,s**5*Ca*****5****.’.

63

68

Trapping

15

15

Stability 0                             

——

seas assess aces 

* *******~***** ***********a*e* *5*5*55*5*5*5*5*

sassass,esasesas 

554

264

Fumgation 

2

.3

Stability 8          

—

s*s****s*a***s,

~a***s***a,***se****as****s***aa**sa*aa*a*****a***e***a**a**

100

80

40

20

0

1_±11

0

KEY

60

90

120

Particulate Conceat~atjons (u~~~’3)

Wiudapeed

Class (Knots)

Atmospheric

Class

—

Naxicum

Concentration

—

Location of Maxis~asConcentration (Kilometers)

—

Frequency of Occurrence (Pcr~.ent)

150

!\BLE 17

From a review of the data oresented,

it

us clear to the Board that

tna short-term SO standard may be violated.

Edison itself projects

s maximum of itJ,~ ug/m3 at worst conditiors

This is ~out

69,5

tIe 365 ag/rn3, 24-hr. standard.

When considering the length of

Edison’s

compliance pan for

SO2

reduction at this pl’3n~.., shis potential viola-

ton iill be kept ~irrnlv in mind,

At hearing cn this faciiity,

Mrs John Keigoer datailed the huis-

ance generated by the Joliet plart.

Mrs. keiqher lived in the neigh-

nor: ood for 13 years and contends that t~e problem has gotten worse

a cry year.

She feels that Edison Is no.: wothing quickly eiough to

solve the problem.

Mrs. Keugher reg.Lstexed cc plaints as .~o how the

air q’ality affects her children, one of

whom is an asthmatic (H. 

139).

The complaints registered nave all tne chara~teristics of a Section

9(a)

~omplaint and, 

as such,

portray a serious nuisance problem. This sit-

uation further prompts the Board to expedite aoy proposed compliance

niar

A discussion of the individual units at Joliet will now follow.

Joliet S is a 117 mm unit fired by two cyclone boilers burning 3.5

sulphur coal.

It is anticipated that this

3.5

coal will be used

aft-

er May 31, 1975, thereby necessitating

a variance from Rule 204. Part-

iculate data 

indicate that no variance from Rule 203 (g) is required

~‘ancher 

Ex.

J—1).

Edison’s proposed compliance plan calls for the installation

an

SO3 injection system on both boilers to be installed during October

1975. Edison has recently completed installation of

new boiler tubes

on both boilers (see discussion on 

Waukegan) to solve the problems

of

carbon carryover.

Modifications are also in progress to upgrade

the

coal crushing equipment.

The Board feels that this compliance

plan is

reasonable and will

endorse

it.

is therefore anticipated that Jol-

iet 5 will be in full

compliance

with both Rules 203 and 204

mid-

October 1975.

Joliet6

is a 344 mw unit fired by a cyclone boiler burning 3.5

sul~r coal. It

is anticipated 

that the 3.5 sulphur coal will be

in

use after

May 31,

1975. 

Emission of about 6.64t/rnBTU will

necessitate

variance from Rule 204. Particulate

testing indicates that no variance

from Rule

204 (g) is required 

(Fancher Ex. J-l)

Edison’s proposed compliance plan calls for installation of a flue

gas injection system with design starting in January 1975 and complet-

ion in March 1976. All parties agree that this compliance plan

is a

viable one, and the plan would bring anout compliance in the shortest

possible time.

The question facing the Board is the reasonableness of

the

time frame.

Under cross—examination, a long exchange was undertaken

detailing why the March 1976 deadline was reasonable.

We will not de-

tail the exchange, but refer to 4/22/74, R. 33-48, H. 58-75.

-~-~-

~-~-

—~

ibutron will change drasticaliy

by l97~. Tru~~snote simply reveals

status prior to 1975.

15—

31

—

After careful deliberation 

on the above exchange, the Board feels

that Edison’s proposed timetable is excessive. While it would be ben-

eficial to Edison 

from a cost standpoint to delay design work, it is

evident that this work must be done and the major components 

will be

the same, no matter what the result of the design work. 

The Board sees

no justification for not starting work on 

this program immediately,

with a target startup 

date of December 1975.

Joliet 7 and 8 

are

617 mm units fired 

by dry-bottom boilers burning

puliT~c~l~ 

Both

units burn low-sulphur coal with emissions cal-

culated to be no higher than 

2.l#/m.BTU and, with the

coal 

used, should

meet the l.8#/rnBTU standard 

the majority of

the time. A 

variance is

thus needed to allow the slight abridgement and will be granted. Part-

iculate data show a 0.9#/mBTU level, which would require variance.

Edison’s compliance 

plan again calls for the installation of a flue

gas injection system on both units. Work is scheduled 

to commence in

June 

1975, with compliance brought

about by October 1976. 

Once more,

discussions centered on the time 

frame rather than the method of compli-

ance. The 

references detailed above (4/22/74, R, 33-48, R. 58-75) are

the point 

in the record in question.

Once again, the Board finds that

Edison’s compliance schedules are unduly exaggerated, 

and therefore we

will condition our variance on a shorter time frame. The Agency has sug—

gested (Brief Pg. 38) June 1976 as a reasonable 

date. The intervenor

has suggested (Brief Pg. 33) December 

31, 1975. In light of the amount

of work required and the size of the units involved, and being cogniz-

ant of the environmental impact of these units, the Board must agree

the Agency that June 1976 is a reasonable date.

Powerton

Station:

The Powerton Station i-s located about one mile

sou~~TP~in,

Illinois.

It is located on the southeast bank

of the Illinois

River.

At this time, there is only one unit in opera-

tion 

(P.

5)

This unit burns high-sulphur Illinois coal which 

washed down to about 

3.7 sulphur. The unit is equipped with an ESP

which was rated at

99,5 efficiency. Testing shows that 

the unit meets

the

1975 particulate regulations when burning

the

3.7

sulphur coal.

However, compliance with Rule 204

is not anticipated

1975.

Environmental Impact: As mentioned 

under

the Waukegan Station,

the subject of environmental impact was covered by Fancher (Edison) and

Melvin (Ill, EPA). The results of

their studies follow:

15

—

32

Fancher Ex. P—i:

_________________________*Unjt

Emission  

Emission#/MBTURate  

Average3-hr.Conc.

24-hr.ug/m3

5

SO

6.8

230.35    

81.4

Pa~t.    

0.05      

1,7

0.6

SO2

6.8

230.35    

81,4

Part.

0.05

1.7

0.6

Total

So2

460.7

162.8

Part.

3.4

1.2

Standards

SO2

1300

365

Part.                     

260

Melvin Ex.—2 draws the following conclusions:

1. Under trapping conditions, Powerton 5 and 6 indicate violations

(Pg. 13) of the 3 hr. standard.

Under normal conditions

there will be no violation of the 24-hr.

SO2 standard.

3, In a study conducted to determine the effect of a large point

source in a major metropolitan area (Peoria) it was found

that Powerton 5 could be anticipated to contribute a signifi-

cant portion of the S02 in the area, for example, at the maxi-

mum receptors.

Receptor   

Total Expected Read.   

Powerton 

Cont.

Mr. Jay

2

Norco also

testified

1000565

569 ug/m

ug/m

ug/m3

3

3as

to the effect of252

309

525each

ug/m

ug/mug/mEdison

3

33

plant

on air quality. Norco Exhibit #2 was entered to show the difference 

the air quality 

if Edison were to be in compliance

vs.

they were not

in compliance by 1975. The validity of the assumptions was challenged

upon cross—examination, and again distracted from its credibility. How-

ever, the Board feels that the exhibit has much value as an indication

of what Edison’s contributions

to the total contaminant loading would

be, and has used this as part

of its consideration on all stations. The

Norco Exhibit 2 will

be included in this Opinion as Fig. 3.

The Board feels that Powerton has the potential to exceed 

the short-

~standardsandwilltai1oritsOrdertoreducethis

impact.

*Once again, 

it is

noted that this is the contribution of the plant. 

Ed-

ison contributed about 65 of the SO2 in the Peoria area. Subject to change

after

1975.

**Unit 6 is not a subject of this Petition. However, it is anticipated

—

FIGURE

3

~.NNTALAVCB~P.IR QU1~LITYCONCE2~TPATICNS

POINT OF MAXI?dJM CrNTRIBUTICN FRCM EDISON SOU21ES

May

30, 1975

Commonwealth •Edisor

PCB 74—16

Norco Exhthit

~iegan

5-8

:11th 5—8

r~mrton5

0-maid 1

_________

1975

EX~~TEID

~

~nC~

(ug/m3)

P21. STD,*   

(up/rn3)

ppj, ma.

40.46

1.31

1.96

2.45

40.45

1.29

7.65

9.56

40.12

.34

6.9

8.62

40.1

.29

7.21

9.01

_________

1975 1~LIL~V\BLE

______

5p3c-—-oTusrnaTr

r~~zmm~mmr

(ug/rn3)

P21, SID,

(ug/rn3)

PRI.SID~

40.16

.46

1.30

1.63

—

2.14

2.68

—

1.83

2.29

—

3,64*5

455

Ccerparisons ~2 oniy

Conc, D~~’5iI3T7~5

.66

.82

5.51

6.88

5.07

6.33

357

4.46

* For per ticulates, the assumed background is 40 ug/rn3 Geometric Mean. The ~x,ntribution

of Edison sources is,

therefore, calculated

as the

of th~difference bstween the

standard (75) and ths backgrcund (40),

35.

“~

Exhibit

Edison’s Petition had assumed a 6,0 1.bs/M3t~sulfur dioxide croission

limitation; with

the

current

stack height of the

Kincaid Station, Rule

204

Ce) limits

sulfur

dioxide emissions to

4.34

lbs/NBtu. This Ethibit reflects the lca.’er

limitation.

Primary

.‘tinual

Air Quality

Standards:

Particulates

—

ug/rn3 (gecreatric mean)

Sulfur Dioxide

-‘

ug/m3 (arit1inetic mean)

—

26

(Discussions below on SCS and blending reflect this,)

As mentioned in the previous section of this Opinion dealing with

coal gasification, the Board feels that 

while

the program for 

compliance

suggested by Edison is a good one, the timetable may be excessive. In

answer to a question raised in the section of this Opinion of F.G,D. (e.g.

will Edison’s rejection of F,G,D, lead to undue delay and environmental

damage?), the Board feels that in light of the problems of F,G,D. sys-

tems, the potential for development of a viable alternate (coal gasifi-

cation), and the possibility of an SCS system to “shave the peaks” of

short—term excursions over the standards, Edison’s compliance plan is

acceptable.

The date for completion and what interim steps are to be

taken are the

only questions 

left to be answered.

Supplementary Control Systems: No long discussion of this item is

needed. Th ulk of this subject was covered earlier in this Opinion.

The Board finds that an S.C.S. system is potentially a viable approach

to

be followed on

an interim basis. Our Order will condition variance

upon the undertaking of a

cooperative effort~betweenEdison and the

Illinois EPA with the expected end result the operation of a workable,

enforceable S.C.S. system.

~~l~i~fls:  

Certainly another option open to Edison is the blend-

ing of coal to achieve a reduction of SO2 until permanent controls can

be installed. Mr. Hoffman (IEPA Electric Utility Specialist) testified

as to the feasibility of this option (5/10/74). Mr. Hoffman pointed

~aut that the methods of segregation of coal and conveyor belt mixing,

or layering coal, 

could be used

(R,

31). It was also pointed out that

such 

methods are now in use by Edison at the

Waukegan and State Line

facilities (R. 33)

Mr. Ramey (7/11/74) was called by Edison to discuss the problems in-

volved with coal blending. The major points center around the diffi-

culty of securing additional supplies of low-sulphur coal. Further com-

plicating 

the matter is the subject of

contracts for coal which Edison

now has for Powerton.

In its Brief, 

the Agency asks the Board to condition any grant of a

variance on (among other things) a study of coal blending at Powerton.

The evidence elicited 

at hearing 

indicates that

coal blending is not a

feasible alternate and that conducting such a study would serve no

use-

ful purpose.

Date of Compliance: The Agency suggests (Brief

Pg. 41) that a compli-

ance date

early 1980 would be reasonable for a coal gasification

plant.

The Board agrees.

There is no justification

for the delay pro-

posed by Edison.

Much design work can begin earlier than proposed by

Edison. Compliance by 1980 is a reasonable date, and we 

will so

condi-

tion our Order.

to start in late 1975. 

If it were to

start 

up uncontrolled as

to SO2,

the above predicts 

the combined 

impact on air quality.

—

Kar~caid Station

The Kincaid Stat~on is located approximately four

mil~~h~town

of Kincaid, christia~ Coonty, Illinois

The pia~t

is located on the chores of Lake Sar~gchris, which was impounded ~or the

use of this plant,

The station consists of t-~o 616 mx coal-fired units,

each fired by a B &

W

cyclone boiler.

Each bo~1er is equipped with a

cual Research-Cottreil

ISP and discharges through twin 500’ stacks

ESP

efficiency

tests while 

burning high-sulphur (4.1 sulphur) coal showea

results well within

Rule 203 specitscations

Thus, no varianco from

Rule 

203 is required.

CoaJ is supplied by Peabody Coal Co. from Mine #10, which .:s 1ocated

adjacen~ t

he station.

The plant is cons dered a mine—mo~th tacil’ty.

otd in

e reduction of sulphur, ddison has contracted

w.tn 

Peabody

~avu all of the coal washed,

Washing facilities are expected 

co cost

n~illion and will be

paid for 

by Teabody

These facilities

are expect-

operable by November 

1975. The following results are expected

a.~..terwashing at a 25 volume loss:

Moisture

Ash

Sulphur

BTU/#

Raw coal     

14.5  

15.7

4,2

9,730

Washed doal

17.5

8.7

3.5

10,340

When analyzing Rule

204 it

is apparent that Rule 204 (e) 

is the most

restrictive (comparison with 6.0#/mBTU). Allowable emissions are

4.34#/mBTU as per Rule 204 (e) 

one assumes an average heat value

of 10,000 BTU/#, it is apparent that Kincaid ~o2 emissions will be 8.4#/

ruBTU

until November 1975 and 

7,0#/mBTU after November 1975. Thus, a

variance is required.

Environmental Impact: Due to 

the relatively isolated location of

the~I’~aidplant, its environmental impact can be considered as a sin-

gle entity rather than 

as one 

source among many. This situation allows

for more accurate predictions as to effect, less complicated impact ass-

essment, and lends

itself to an S.C.S. system which would predict

and

prevent short-term violations.

Once again,

Fancher (Edison)

and Melvin

(IEPA) entered evidence as to the potential impact of Kincaid’s dischar-

ges on the environment.

Questions as to assumptions used were similar

to those raised in Waukegan and will not be reiterated.

The following

results were reported by Fancher:

Unit

____

Emission

Emission#/mBTURate

Average3-Hr.Cone, ug/m24-Hr._________3

SO2

8.60      

373.7    

132.1

Part.

0.05

2.2

0.8

2

502

8.60

373.7

132.1

Part.

0.05

2.2

0,8

Total

SO2

747.5

264.2

Pirt.

1,5

Standards

SO2

1300

365

Part

260

(Fancher Exhibit K—I)

15—36

Melvin Exhibit

#2

projects the following:

1. Under trapping conditions, Kincaid indicates violation of the

3-hr. SO2 standard (indicates 0,74 ppm

M. Ex.-2, Pg. 13).

2. Under fumigation conditions, violations of the 3-hr. SO2 stand-

ard are also projected.

3. No 24-hr. violations have been projected, although worst case

analysis was not made.

it is the Board’s opinion that adverse environmental impact can

be

kept to an absolute minimum at this station by the installation and 

op-

eration of a viable S.C.S. system~

Edisn’s compliance plans for this Station call for the installation

of coal gasification units, with anticipated completion dates of 1982

and 1983. Other considerations included: building a taller smoke-

stack to reduce the limitations of Rule 204 (e). This was rejected

because of the fact

that 

the 6#/nBTU level could still not be

obtained.

Edison again alleges that low—sulphur coal could cause damage to the

cyclone boilers, and also that such a supply is not available.

The

problems with transportation and logistics were also cited. (Kincaid

burns about 3 x 106 tons of coal per ydar 

from Melvin Ex. 2,)

There is very little argument that coal gasification

is a viable

~echno1ogy

to pursue at Kincaid.

The questions again center around

the length of the compliance plan.

Edison proposed to defer work

K-i and K-2 until P-5

is well underway. There is no doubt that this

conservative methodology is preferable from Edison’s point of view,

but we

must balance the delay against the potential adverse environmen-

tal

impact. We must also not

lose sight of the enornious projected

costs for

these units, according

to Edison’s figures:

Powerton 4

$19,000,000

Powerton 5       

$65,895,000    

UNIT Investment

Kincaid I

$48,415,000

(Fancher Ex.

6 Ed,)

Kincaid 2        

$48,415,000

The Board at

this time feels the compliance dates can be moved up

significantly. We again express our feeling that preliminary design

work can start before massive funds are committed, We will, however,

not tie our variance 

to a 

firm 

date at 

this time, but will 

rather use

the condition of an S.C.S. system to insure maintenance of the air

quality in the area.

Summary: The

Board will issue a very complex Order in this matter.

T1.i~~ue 

the extremely complex nature of the system involved.

writing this Order the Board has very carefully considered all of

the evidence presented.

We have then weighed all

of

the

aspects in-

volved in

this case. The environmental impact, technology, economics,

good faith efforts

have all been considered. The Board finds that

ile Edison has indeed been the forerunner 

in new technology (e.g.,

ill County scrubber, Powerton gasification),

this leadership is re-

quired so as to meet

the mandate of the citizens of Illinois 

as voiced

15—37

—

by the State

Legislature when they adopted the Environmental Protect-

ion

Act. Such 

efforts are, in fact, to be expected of a major utili-

ty company, and Edison is indeed by far the 

largest electric utility

in the

State.

The Board further finds that in many instances delay

was a tool used to forestall the installation

of equipment when technol-

ogy could have been pushed. It is mainly

for this reason that the

Board has trimmed the dates on the various compliance plans.

We are

also very much aware of the enormous sums of money which will be ex-

pended to bring about compliance. We are further aware that this cost

will 

eventually be borne by the consumer in the form of increased elec—

tric bills. This cost to the consumer is the price for the clean air

he ordered when supporting the Environmental Protection Act and the

Federal Clean Air Act.

In many instances compliance plans run beyond

the one—year term

granted in this variance. It

the intent of the Board to carefully

review the facts in any future proceeding and act accordingly. It is

also the intent of this Board

to do everything it can to

insure the

viability of these compliance plans.

To allow undue delay, to not fol-

such delay, would truly be to turn our back on our

responsibil-

ities.

This Opinion constitutes the findings of fact and conclusions of law

of the Board.

ORDER

IT IS THE ORDER of the Pollution Control Board 

that:

1. With respect to the Waukegan Station, Unit 5:

a) Variance is granted from Rule 3-3.112 from October 15, 

1974,

to May 31, 1975.

b) Variance 

is granted

from Rule 203 (g) from May 31, 1975,

October 

15,

1975.

Subparagraphs (a) and (b) above 

are

conditioned on the use 

of

both

the Unit 5 and the Units 1, 2, and 3 electrostatic precipitators at all

times that Unit 5 is operating. Subparagraphs (a) and (b) are further

conditioned on the conducting of stack tests to be performed within

60 days from the date of this Order. Said stack tests shall be per-

formed in the presence of Agency personnel, if the Agency desires. Re-

sults of said stack tests shall be submitted to the Agency and the

Board within fifteen days 

of

the completion of such tests.

c) Variance from Rule 204 is granted from May 31, 1975, to

October 15, 1975, subject to 

the

following conditions:

i) Edison shall not emit sulphur dioxide in excess of

3.0#/MBTU.

ii) The installation of an SO3 injection system no later

than December 31, 1975.

d) This entire Order I is further conditioned upon the followin~

15—38

—

30

—

i) Within 30 days from the

date 

of this Order, Petitioner

shall submit to the Agency a detailed schedule for in-

stalling a flue gas conditioning system on Unit

5. Said

schedule shall include 

as a minimum: dates

for obtaining

contracts, date of beginning design, date of

completing

design, date 

of scheduled delivery, date of

outage for

installation, and date of completion of said system.

ii)

Petitioner shall

submit quarterly reports to the Agency

detailing work performed and progress made during the

previous quarter and 

work to be performed in

the follow-

ing quarters.

iii) Within fifty 

(50)

days of 

the date of this Order Petit-

ioner shall submit a 

performance bond to

the Agency 

in

the amount

of

$35,000.

Said bond shall insure completion

of the flue gas conditioning system by the date detailed

above in Order 1 (c) (ii),

iv) Edison shall continue to maintain and operate the 

moni-

toring system as ordered in PCB 73-40. All data generated

by said system shall be submitted to 

the Board and the

Agency as soon as it is available, but in no event later

than six weeks after the last day of any month.

v) Edison shall apply for all necessary construction and op-

erating permits.

2.

With 

respect to the Waukegan Station Unit 6:

a) Variance is granted 

from Rule 

3-3.112 from October 15, 1974,

to a maximum of 30 days after Petitioner receives the fabri-

cated furnace tubes from Babcock and Wilcox, but not later

than June 30, 1975.

b) Variance is granted from Rule 203 (g) from May 31, 1975, to

October 15, 1975, subject to the following condition:

i) Edison shall operate Unit 6 only after boiler modifications

are completed, which would consist of as a minimum the

installation of the new specially fabricated furnace tubes,

c) Variance is granted from Rule 204 from May 31, 1975, to Oct-

ober 15, 1975, subject to the following conditions:

i) Order 1 (c) 

Ci) ,

1(d) (i) 

, 1

(d) (ii) 1(d) (iv) and 

(d) (v)

shall 

reapplied 

Unit 6.

ii) The installation of an 

SO3

injection 

system no later than

February 1976.

iii) Within 

fifty

(50) days from the date of this 

Order, Pet-

itioner shall 

submit a performance bond to the Agency in

the

amount of $20,000, Said bond shall insure completion

—

—

31

—

of the flue gas conditioning system by the date detailed

above in Order 2 (b)

(ii).

3. With respect to the 

Waukegan Station Unit 7:

a. Variance is granted from Rule 3-3.112 from October 15, 

1974,

to May 31, 1974.

b. Variance is granted for Rule 203 (g) from May 31, 

1974, to

October 15, 1974.

c. Subparagraphs (a) and (b) above are conditioned in 

that Wauke-

gan Unit 7 shall

be operated above 153 mw only after

all

other

available Edison capacity has been

utilized except Edison’s

fast start

peakers and Sabrooke Units

and 2.

d. Variance 

from Rule 

204 is granted from May 31, 1975, to

October

15, 1975, subject to the following 

conditions:

Orders 1(c) (1) , 1(d) (ii)

1(d) (iv) ,

and

1(d) (v) shall be

reapplied to Unit 7.

ii)

Petitioner shall install a hot electrostatic

precipitator

no later than December 1976.

iii)  Within 30 days from the date of this Order, Petitioner

shall submit to the Agency a detailed compliance program

and project completion schedule for the installation

a new hot 

ESP. The schedule shall include estimated

dates of ordering equipment, delivery of equipment, 

inst~-

ation of equipment, and startup of equipment.

iv)

Within fifty (50)

days 

of the date of this Order, Petitioner

shall submit a performance bond

to the Agency in the amount

of $150,000. Said bond shall insure completion of the hot

ESP.

4. With respect to Waukegan Unit 8, the Petition for Variance is dis-

missed.

5. With respect to the Sabrooke 

Station Units 1 and 2, variance is

granted from Rule 3-3.112 until January 30, 1975, subject to

the

following conditions:

Sabrooke Units 1 and 2 shall be operated only after all avail-

able Edison capacity has been utilized,

including Waukegan

However, one of the Sabrooke units (1 or 2) may be operated at

the minimal level necessary to provide steam for water deminer—

alizers, heating the station, or to prevent stack deterioration

in the event that Units 3 or 4 cannot be used for such purposes.

6. With respect to the Joliet Station Unit 5:

a) Variance from Rule 203 is dismissed.

15 —40

—

32

—

b) Variance from Rule 3-3.112 

dismissed.

c) Variance from Rule 204 is granted from May 31, 1975, to Oct-

ober 15, 1975, subject to the following conditions:

i) The installation of a 

flue gas conditioning system

no

later than October 

15,

1975.

ii) Within 30 days from the date 

this Order, Petitioner

shall submit to the Agency a detailed schedule for in-

stalling a flue gas conditioning system. Said schedule

shall include as a minimum:

dates for contracts, begin-

ning design, completing design, date of scheduled deliv-

ery, date of outage of equipment, and date of completion

of said system.

iii)

Petitioner shall submit quarterly reports

to the Agency

detailing work performed and progress made during the

previous quarter and work to be performed in the following

quarter.

iv)

Within fifty

(50) days 

from the date of this Order, Pet-

itioner shall submit a performance bond to the Agency in

the amount of $35,000. Said bond shall insure completion

of the flue

gas

conditioning system by the date detailed

above in Order 6(c) (i)

v) Edison shall apply 

for all necessary construction and op-

erating permits.

7.

With respect to the Joliet Station Unit 6:

a) Variance from Rule 203 is dismissed.

b) Variance from Rule 3-3.112 is dismissed.

c) Variance 

granted from Rule 204 from May 31, 1975, to October

15, 1975, subject to the following conditions:

i)  The installation of a flue gas conditioning system no

later than December 15, 1975.

ii)  Within 30 days from the date of this Order, Petitioner

shall submit to the Agency a detailed schedule for in-

stalling a flue gas conditioning system. Said schedule

shall include as a minimum: dates for contracts, begin-

ning design, completing design, date of scheduled deliv-

ery, date of outage of equipment, and date of completion

of said system.

iii)  Petitioner shall submit quarterly reports to the Agency

detailing work performed and progress made during the

previous quarter and work 

to be

performed 

the follow-

ing quarter.

15—41

iv) Within fifty (50) days from the date of this

Order,

Petitioner shall submit a performance bond to the Agency

in the amount of $65,000. Said bond shall insure com-

pletion of the flue gas conditioning system by the date

detailed above in Order 

7 (c) (i)

Edison shall apply for all necessary construction and

operating

permits.

8. With respect to the 

Joliet Station Units 7 and 8:

a) Variance

from 

Rule 3-3.112 is granted from October 15, 1974,

to May 31, 1975,

b) Variance from Rule 203 is granted

from May 31, 

1975, to October

15, 1975.

c) Variance from Rule 204 is granted from May 31, 1975, 

to October

15, 1975, 

to allow

sulphur dioxide emissions 

up to

2.l#/14BTU.

The above Orders 8(a) 

(b)

, and

(c) are conditioned upon the 

following:

The installation 

a flue gas conditioning system on 

Un-

its 7 and 8 no 

later than June 6,

1976.

ii) Within 30 days from the date 

of

this Order, Petitioner

shall submit to the Agency a detailed schedule for install-

ing a flue gas conditioning system. Said schedule shall

include as a minimum: dates for contracts, beginning 

de-

sign, completing design, date of scheduled delivery, date

of outage of equipment, and date of completion of said

system.

iii) Petitioner shall submit quarterly reports to the Agency

detailing work performed and progress made during the prev-

ious quarter and work to be performed in the following

quarter.

iv) Within fifty 

(50) 

days from the date of this Order, Pet-

itioner shall 

submit 

a performance bond to the Agency in

the amount 

of

$200,000. Said bond 

shall insure completion

of the flue gas conditioning system by 

the date 

detailed

above in Order 8 Cc) (i)

v) Edison shall apply for all necessary construction and op-

erating 

permits.

9.

With respect 

to the Powerton Station 

Unit 5:

a)

Variance from Rule 

3-3.112 and Rule 203 is dismissed.

b) Variance 

from Rule

204 is granted 

from May

31, 1975, to October

15, 1975, subject

to the 

following

conditions:

15 —42

—

34

—

The installation 

of a low BTU coal gasification plant

to

fuel Powerton 5 by May 1980,

ii) Within thirty (30) days from the date 

this Order, 

Ed-

ison shall begin a 

study

regarding the installation and

use of a supplementary control system at the Powerton

plant. Such study shall seek 

to

conform to the general

guidelines of Federal Register, Vol. 38, No. 178, P.

25698, September 

14,

1973. Edison shall seek the aid

of the Agency in this matter and shall file a report of

its findings with the Agency and the Board within four

(4) months of the date of this Order.

iii) The Board retains jurisdiction to reopen hearings on the

subject of S.O.S. on 

its

own motion, or the motion of

any other party during the term of this variance. Such

hearings may result in further orders regarding the in-

stallation and operation of such 

S.O.S. 

systems. The

Board may also issue any further orders regarding the

proposed S.C.S, without holding hearings 

if

it deems nec-

essary.

iv) Within 30 days of the date of this Order, Edison shall

submit to the Agency a detailed compliance plan, Said

plan shall detail the proposed steps and dates for in-

stallation of a pilot gasification plant for Powerton 4,

showing compliance no later than October 1976. Said com-

pliance plan shall also detail the expected dates and

steps to be undertaken towards installation of the coal

gasification plant for Powerton 5.

v) Edison shall 

submit 

quarterly reports detailing its pro-

gress completed during the previous quarter and its ex-

pected progress during the following quarter.

vi) Within fifty (50) days from the date of this Order, Edi-

son shall submit a bond in the amount of $1,000,000.

Said bond is to insure the installation of the Powerton

4 pilot unit by October 1976, and the Powerton 5 gasifi-

cation plant by 1980.

vii) Edison shall apply for all necessary construction and

operating permits.

10. With respect to the Kincaid Station Units 1 and 2:

a) Variance from Rule 3—3.112 and Rule 203 is dismissed,

b) Variance from Rule 204 is granted from May 31, 1975, to Oct-

ober 15, 1975, subject to the following conditions:

i) Plans to burn only washed coal at the Kincaid Station

shall be continued, 

with

its use commencing by 

i~ovember

1975.

15

—43

ii)

Edison shall within six (6) months of the date of this

Order file a compliance plan with the Agency for the in-

stallation of a coal gasification

unit for Kincaid I and

2.

Said plan shall inclade an a.iticipated date fcr com-

pletion of this project,

Such date will be reviewable

by the Board at any future requests for variance as re-

gards these units.

iii) Within sixty (60) 

days from the date of this Order, Edi-

son shall submit to the Board and the Agency a he-ailed

proposal

for

implementing a supplemental control system

at the 

Kincaid generating statior. Such plan snail fol-

low the general guidelines of Federal Register, Vol. 38,

178, P25698, September 14, 1973. The Agency shall with-

in 30 days of the receipo of such proposal submit to the

Board its comments 

on said proposal. The Board shall

maintain jurisdiction in this matter and may schedule add-

itional hearings at the 

request 

of any party 

or

upon its

own motion on 

the

proposed 

S.O.S. The 

Board may also 

is-

sue any 

further Orders regarding the proposed S.O.S. 

with-

out holding hearings if 

it deems 

necessary.

iv) Within 

fifty (50)

days 

from the date of this

Order 

Edi-

son shall submit to 

the

Agency a performance bond 

in the

amount of $100,000 to 

insure 

compliance with Order 10

(b) (i) above.

Mr. Henss dissents.

I, Chrastan L. Moffett, Clerk of the Illinois Pollution Control

Board, certify that the above Opinion and Order was adopted by 

the

Boand on the 3rd day of January, 

1975,

by a vote of 4 to I.

15 —44