ILLINOIS POLLUTION CONTROL BOARD

November 22,

1974

STATE OF ILLINOIS

)

DEPARTMENT

OF

MENTAL

HEALTH

LINCOLN

STATE SCHOOL

)

PETITIONER

v.

)

PCB 74—348

ENVIRONMENTAL

PROTECTION

AGENCY

)

RESPONDENT

)

OPINION

AND

ORDER OF THE BOARD

(by Mr. Marder)

This action involves

a request for variance filed on September

24,

1974, by the Lincoln State School.

Relief is sought from Rule 203

(g) (1) (B)

of the Illinois Pollution Control Board’s Air Pollution

Regulations as it pertains to Petitioner’s two power plants.

The

Agency has interpreted this petition to include

a request for variance

from Rule 2-2.53 of the Rules and Regulations Governing the Control

of Air Pollution

as well

as

a 203

(g) (1) (B)

request.

Although a spec—

ific request for a Rule 2-2.53 variance was not requested,

the Board

will consider the 203

(g) (1) (B)

request to include both pleadings.

Petitioner owns and operates a State School

(residential facility)

for approximately 1900 mentally retarded and otherwise development-

ally disabled persons.

The major facilities

are divided into two

campuses known as main campus and annex campus.

The facilities are

located in proximity to the city of Lincoln, Illinois.

Separate power

plants are required in that these two campuses are approximately 2 1/2

miles apart from each other.

The main campus has as its power plant facility three

50 x 106 BTU/hr

boilers which utilize about 18,000 tons

of coal per year.

The plant

is

used for heating as well

as electric generation.

This facility services

1000 persons.

~‘heannex power plant

is comprised of two 38 x 106 BTU/hr

and one 28 x 10

BTU/hr boilers.

These boilers are used for heating

purposes; however,

no mention is made of electric generating capacity

in the Petition.

Petitioner contends that its discharges

of particulates are approx-

imately 0.82 pounds per million BTU.

Rule 2-2.53 has an allowable em-

ission rate of 0.80 pounds per million BTU.

Agency calculations

using

Compilation of Air Pollutant Emission Factors,

1½P-42, Table 1.1-1, re-

veal the following:

Main Campus Emissions

0.707#/1~6BTU

Annex Campus Emissions

1.41*/lU

BTU

Allowable 2—2.53

0.80*1106 BTU

Main Campus Allowable

203(g)

O.32#/l06 BTU

Annex Campus Allowable 203

(g)

0.38#/106 BTU

14

—

531

---

—2—

From the above,

it is

clear that only the annex power plant is in

need of a variance from Rule 2—2.53,

and both plants will require var-

iance from 203

(g).

Petitioner has undertaken

a compliance plan which will yield meeting

203

(g)

specifications by November 1,

1975.

Said compliance plan in-

cludes the installation of multi-clone devices at a cost of $260,000.

Petitioner offers the following compliance dates:

Project Approved by State

Sept.

11, 1974

Architectural Design

Oct.

1,

1974

Complete Design

Jan.

1,

1975

Start Construction

March 1,

1975

Compliance

Nov.

1,

1975

The Agency

(Reco Pg.

4)

states that the above compliance plan is

reasonable, and the Board concurs in this conclusion.

While on its face the compliance plan would indicate an undue lack

of initiative on Petitioner’s

part,

the past history of this facility

shows otherwise.

During 1972 plans were initiated to convert all boil-

ers to oil firing;

indeed,

funds were appropriated

($225,000)

in 1973

for such conversion.

However, due to the shortfall of

#2 oil,

this

compliance plan was abandoned.

The above compliance plan was then

drawn up to supplant that which was invalidated by factors beyond Pet-

itioner’s control.

Although information on the subject of environmental impact

is very

sparse, the Board takes note that the location of the subject facili-

ties are in an area which is not normally of high particulate readings.

The Agency also reports that

no

citizen

complaints

have

been

received

pertaining to nuisances

in the area.

Petitioner claims a hardship will occur should this variance be den-

ied.

It is alleged that services for the some

1900 persons

in their

care would be impossible without the heat and electricity generated by

these units.

The Board again states that failure to grant a variance

is

riot a shutdown order but merely subjects Petitioner to possible en-

forcement action.

However,

in this case the possible hardship generated

would

not

be

on

Petitioner

but

on.

those

not

able

to

care

for

themselves,

and

is

thus

more

severe.

In light of the reasonable attempt made at comoliance, the minimal

environmental impact, and the potential hardship, the Board will grant

the requested variance.

In closing,

the

Agency

noted

that

there

were soecific

operational

boiler

deficiencies

~hich

would

serve

to

reduce

the

already

low

part-

iculate

capture

efficiency.

The

Agency

has

pointed

out

that

weekly

settling

chamber

cleanouts

would

serve

to maintain

rated

efficiency.

This

cleanout

procedure

will

become

part

of our order.

14

532

---

—3—

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:

Variance

is

granted

from

Rule

2-2.53

of

the

Rules

and

Regulations

Governing the Control of Air Pollution for the Annex Campus boilers

until May 30,

1975.

Variance is granted from Rule 203

(g) for the Annex Campus boilers

from

May

30,

1975,

to

November

1,

1975.

Variance

is granted from Rule 203

(g)

for the Main Campus boilers

from May 30,

1975,

to November 1,

1975.

Variance is dismissed

as moot from Rule 2—2.53 of the Rules and

Regulations Governing the Control of Air Pollution for the Main Campus

boiler.

The above variances are granted subject to the following conditiions:

A)

Petitioner

shall apply for all necessary construction

and

operating

permits

for

its

coal—fired

boilers.

B)

Petitioner

shall

submit

quarterly

operating

reports

to

the:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Control

Program

Coordinator

2200 Churchill Road

Springfield,

Illinois

62706

Such

reports

shall

contain

at

a

minimum

a

detailed

time-

table

of

the

entire

control

program

and

progress

made

toward completing the installation

of

the

multi-clone

collection devices.

C)

Petitioner

shall

clean

fly ash from the existing chamber

on

the

Annex

Campus

boilers

at

least

once per week.

I,

Christan

L.

Moffett7

Clerk

of

th~ Illinois

Poilution

Control

Board,

certify

tha~ the

above

Opinion

and

Order

was

adotted

by

the

Board

on

the~~~

day

of

~

1974,

by

a

vote

of