ILLINOIS POLLUTION CONTROL BOARD

January

3,

1975

COMMONWEALTH EDISON COMPANY,

)

Petitioner,

PCB 74~16

ENVIRONMENTAL

PROTECTION

AGENCY,

Respondent0

CONCURRING

OPINION

(by Mr.

Dumelle):

I concur with the grant of the variances

in

this case but for

reasons different from the majority.

My

fellow three Board Members

of

the majority seem to agree

that flue gas desulfurization techniques

(FGD)

are

not

yet proven.

disagree on this major point.

The successful operation

of the

lvlitsui Aluminum plant

in

Japan since March

1,

1972

is proof

that

american technology does

work

(at least in

Japan).

In

two months, Mitsui should have

36 months of successful

operation,

In addition,

in this country we have the excellent results

of

flue gas desulfurization at the Paddy~sRun power plant

in

Louisville and the

good experience

at

the Cholla plant in

Arizona.

If

it only takes the

sighting of

a single albino crow to

prove its

existence,

then these three

examples are more than enough

proof.

It

is

interesting

to see that Edison~sState Line plant began

working

on

FGD on January 1,

1972 and its Will County plant

on

February 23,

1972.

Both were started before Mitsui but have not

had the same successful experience

in the intervening years.

The question on this variance then boils down to “what

is

to be done now?”

The time has gone past.

Edison

did

try to make

FGD

work

(and may yet do

so)

but failed

(at

least to

date).

Had

Edison successfully brought in FGD by the end of

1972

it could have

then installed the process in all its other units in about

three

more years or by December,

1975.

The instant variances

are largely

until October, 1975

(or

sooner)

and the same end result, namely

early compliance,

is obtained.

15

—47

---

—2--

The later dates,until 1980,

for coal gasification

at Powerton

and Kincaid, are justified in the interest of encouraging alternative

technology to use Il1inois~ample coal supplies.

The conversion to low sulfur coal, wh~chis Edison’s own

choice,

is by this variance left to them,

I have some doubt that

Edison will in fact be able to secure the massive tonnage of

low sulfur coal that they need.

If it cannot be secured then an

early change

in the strategy is required lest more time be lost.

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

Board, hereby certify the above Concurring Opinion was submitted on

the ____day of

~~~,______________

,

1975,

Christan L, Moff

Cler~

Illinois Pollutio

ontrol Board