ILLINOIS POLLUTION CONTROL BOARD
December 19,
1974
STATE OF
ILLINOIS
DEPARTMENT OF MENTAL HEALTH
JACKSONVILLE STATE HOSPITAL,
Petitioner
PCB 74-356
vs.
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION
AND
ORDER
OF THE BOARD (by Mr.
Dumelle):
On October 1,
1974, Jacksonville State Hospital
filed
its Petition
For Variance, seeking therein permission
to operate its four coal-fired
boilers beyond the particulate limits prescribed by this Board until
October
1,
1975,
during which period mechanical
collectors
will
be designed and installed.
Although not specifically cited
in the Petition
For Variance, Petitioner’s general
request would entail
variance from
the provisions of Rule 2—2.53 of
the Rules and Regulations Governing
the Control
of Air Pollution and from the compliance date of May 30,
1975
contained
in Rule 203(g)
of Chapter 2, Part
II
of the Pollution Control
Board Regulations.
Petitioner is
a state owned medical facility rendering service
to
persons
in need of mental
treatment.
Petitioner’s facility, located
in the City of Jacksonville, County of Morgan, Illinois,
is comprised of
fifteen separate buildings.
Steam heat, hot water and electricity for
the entire facility are produced in Petitioner’s power plant, which includes
four coal-fired boilers.
The boilers, with chain and travelling grate
stokers
and forced draft fans,
have the following specifications:
Rate
Heat Input
Manufacturer
Number
Year Installed
(lbs per million BTU)
Lbs.
of Steam
Springfield
3
1946
59
40,000
Lasker
1
1968
66
45,000
The flue gases from Petitioner’s
boilers are discharged from a 200
foot stack.
All
of the boilers are presently equipped with gravity—fed
fly-ash collectors
and no more than two boilers are operated simultaneously.
Petitioner utilized 20,800
tons
of coal during fiscal year 1974.
Analysis of that coal
is
as follows:
14— 759
-2-
Ash
5.82
Sulfur
2.91
BTU
11,269
Total Moisture
16.32
The Agency has
calculated Petitioner’s present particulate emission
rate to
be 1.29 pounds
per million
BTIJ.
The Agency
is
of the opinion
thatto achieve compliance with Rule 203(g), Petitioner must reduce
its emissions
78
for its Springfield boilers and 80
for its Lasker
boiler.
Petitioner proposes to achieve compliance with the installation of
multi-clone fly—ash collection devices
on each of the •four coal-fired
boilers.
The project
is estimated to cost $180,000.
Petitioner
has
not
obtained construction permits from the Agency for these devices.
Petitioner proposes to install
the multi-clone collection devices
under the following schedule:
Agreement made with architect
-
October
1, 1974
Design complete
—
January
1, 1975
Construction started
-
March
1,
1975
Construction complete
-
October
1,
1975
Construction of the control
devices will be accomplished while two
boilers are operating.
Tie—in of the devices will be made alternatively
while boilers are shut down for maintenance.
The Agency is
of the opinion
that
a properly designed multi-clone collection device is capable of
achieving compliance with the regulations.
We are disposed to grant this variance as requested; however, certain
comment
is
in order.
Paragraph VI
of the Petition For Variance is,
in pertinent part,
as follows:
‘1VI.
Consequences of Variance Denial
Denial
of variance to permit operation of boilers
during the planned design and installation of the
mechanical
precipitators would force
a complete
shut down of Hospital.
This would have far reaching
implications
including:
A.
Dismissal
of
a 670 person work force
with
a resulting loss of
a $6,831,300
annual
payroll.
B.
Deny the people of the State of Illinois
mental
treatment at
a regional
facility.
C.
Increase the mental
treatment burden of
other state hospitals.”
14
—
760
-3-
The Board has often stated that the denial of a petition for
variance
is not tantamount to shut-down;
a denial merely subjects
the petitioner to possible enforcement action.
Short of a denial,
this Board has the authority to require accelerated compliance
schedules, with possible increased cost attendant thereto.
The Agency has noted two items which are dificient in Petitioner’s
schedule for achieving compliance.
First,
no mention
is made of the
date upon which the control devices will be purchased.
Second,
no
indication
is made of
the date upon which compliance will be achieved.
The Agency’s observations are well
taken and will
be incorporated into
our Order.
This Opinion constitutes the findings of fact and conclusions of
law.
ORDER
IT
IS THE ORDER of the Pollution Control
Board that Jacksonville
State Hospital
be granted a variance until October
1,
1975, from
the provisions of Rule 2-2.53 of the Rules and Regulations Governing
the Control of Air Pollution and from Rule 203(g)
of Chapter
2, Part II
of the Pollution Control
Board Regulations during which period the
subject control devices will
be installed, subject
to the following
conditions:
1.
Within thirty
(30) days of the date of this Order,
Petitioner
shall
submit
a detailed compliance plant to:
Illinois Environmental
Protection Agency
Division of Air Pollution Control
Control Program Coordinator
2200 Churchill
Road
Springfield,
Illinois
62706
Said compliance program shall
contain the following dates:
1.
Petitioner’s request for bids
ii.
Time required for consideration of bids
iii.
Letting contract
iv.
Shop drawing preparation time
v.
Fabrication by supplier time
vi.
Shipment time
vii.
Tie-in time
viii.
De-bugging time
ix.
Final
completion date.
14
—
761
-4-
2.
Petitioner shall submit quarterly reports to:
Illinois Environmental Protection Agency
Division of Air Pollution Control
Control Program Coordinator
2200 Churchill Road
Springfield,
Illinois
62706
outlining progress made toward completing installation
of the multi-
clone collection devices.
3.
Petitioner shall apply for all
necessary construction and
operating permits from the Agency.
I,
Christan
L.
Moffett, Clerk of the Illinois Pollution Control
Board,
do hereby certify that thp abov~Opinjon and Order was
adopted on this~4/i
day of
A
~
~
~
,
1974 by
a vote of
1/
(
~1.
~‘t~J/c/J(~i’)
14—762