ILLINOIS POLLUTION CONTROL BOARD
September 27, 1974
COMMONWEALTH
 EDISON
 COMPANY
PETITIONER
PCB
 74—11
ENVIRONNENTAL
 PROTECTION
 AGENCY
RESPONDENT
RICHARD POWELL, ATTORNEY,
 ISHAM,
 LINCOLN
 &
BEALE,
in
 behalf
 of
 COMMON—
WEALTH EDISON COMPANY
MICHAEL GINSBERG, ATTORNEY,
 in behalf of the ENVIRONMENTAL PROTECTION
AGENCY
MARVIN MEDINTZ, ATTORNEY, representing the PEOPLE OF THE STATE OF ILL-
INOIS, INTERVENOR
OPINION AND ORDER OF THE BOARD
 (by Mr. Marder)
This action involves a request for variance filed January
 4,
 1974,
by Commonwealth Edison, seeking relief from Rule 3-3.112 of the Rules
and Regulations Governing the Control of Air Pollution and Rule 203
 (g)
of chapter
 2, Air Pollution Regulations.
 The variance request pertains
to Edison~sWaukegan and Sabrooke power generating facilities.
This matter was consolidated for hearing with PCB 74-16, which is a
one-year request for Variance for Edison~sfive facilities.
 The combined
record is very comprehensive, and a complete opinion on this matter will
be incorporated within the Board~sopinion on 74-16,
A brief discussion of each unit at the two stations is in order at
this time.
Sabrooke #3 and #4 have either been converted to oil or are presently
 down for such conversion.
 Thus no variance is required for these units.
Sabrooke #1 and #2 were also scheduled for conversion to oil.
 How-
ever, on November 27, 1973,
 the Federal Government published regulations
forbidding the use of oil in units which were presently coal-fired. Ed-
ison~sappeal of this regulation was denied when the State Environmental
Protection Agency did not certify that the conversion of Units
 1 and 2
to oil was needed to maintain the primary air quality.
 Edison has now
appealed to the Federal Government, and that appeal is
 still pending.
Large sums of money have already been spent by Edison in preparation
for
 conversion
 of
 Sabrooke
 Units
 1 and 2.
 This sudden turn of events
was certainly beyond Edison~scontrol, and variance will be granted.
13
—
 681
—2—
Waukegan
 #8 is presently running with
 a flue gas conditioning system.
The purpose of this system is to allow the burning of low sulphur coal
while retaining top efficiency of the electrostatic precipitator, This
concept utilizes liquid SO~flue gas injection.
 Although it is hoped
that Unit #8 is presently in compliance, the novelty of the technology
and the recent startup of the process would suggest that
 a variance
would be in order.
Because this technique
 (SO.~injection)
 is a major part of Edison’s
future compliance plans, the ~oard would encourage the running and test-
ing of Unit
 #8 so as to expedite future compliance plans.
Waukegan #7,
 6,
 5:
Unit
 #5 was planned for a shutdown by about September
 15
 (R. 4/15/74
Pg.
 10).
 This shutdown was anticipated to facilitate duct work modifi—
cations between the ~xisting Unit
 5
 ESP and the unused Unit 1,2, and 3
ESP (Units
 1,2, and 3 had been previously retired by Edison),
 This shut-
down was to ~encompass
 the
 approximate
 period
 of
 September
 15 to November
15.
 According to efficiency tests on this unit,
 the modifications will
increase capture efficiency from about 65
 to about 90
 or from 2,0#/xm~
ETU to 0.5*/mm BTU,
 (See Ex. W—l.)
Unit
 #6
 is presently controlled by an ESP which allows emissions of
from 0.402
-
 0.181 #/mm BTU while running on 2.4
 sulphur
 coal
 (See Ex.
W-2).
 Compliance plans
 call for SO3 injection to be completed by June
1976.
Unit
 #7 is
 presently
 controlled
 by
 an
 ESP.
 The unit, when burning low
sulphur coal
 (1.9),
 has a very low capture ef~ficiencyand a high rate
of particulate escape
 (from 1.27 to 1.87*/mm BTU).
 ~Unit #7 is a fair-
ly large
 (338 mw)
 unit and will therefore contribute a total load in ex-
cess of 3720#/day of particulates at full load.
Compliance
 for this unit is the installation of a new “hot” ESP with
a shutdown date
 (for installation)
 of October 1976.
As
 mentioned
 above
 the
 instan.t
 matter
 has
 been
 consolidated
 with
 PCB
74-16.
 Because of the complexity of the situation and the need for
lengthy hearings in the combined matters, the Board has previously grant-
ed interim variances
 (at the Petitioner’s request)
 up to and including
October
 4,
 1974.
 Therefore this order can only grant variance from
October
 4, 1974,
 to October 15,
 1974,
The Board has in the past expressed serious concern
 over the impact
upon the citizens of Edison’s emissions in the Waukegan area.
 In an
attempt to get a firmer grip on the actual air quality surrounding the
Waukegan station, the Board ordered the establishment of a nine—station
air monitoring network.
 Edison informed the Board that this network was
put into operation on April 17, 1974.
When the last interim extension was granted by this Board
 (see August
13—682
—3—
.1,
 1974,
 Order)
 ,
 we expressed concern
 as to the lack of data from the
monitoring network and stated:
“The Board again emphasized that the availability of
air
 quality
 data
 was
 a
 key
 consideration
 in
 the
 original
varianc~grant.
 This provision was specifically included
to allow for public notification of high pollutant levels,
and to allow the Agency and Edison ~o take immediate cor-
rective actions.
 By not supplying such information Edison
made this decision much more difficult
 for the Board.
 This
Board will carefully review
thb
complete record on PCB 74-il
to ascertain why such data was not available,”
(PCB
 74—li, August
 1,
 1974,
Pg.
 6)
A
 review
 of
 the
 74-il,
 16
 record,
 including
 final
 briefs,
 shows
 the
record
 to
 be
 silent
 on
 the
 subject.
 However,
 on
 September
 24,
 1974,
Edison
 filed
 with
 the
 hearing
 officer
 a
 Motion
 to
 Include
 Data.
 This
Motion
 would
 have
 included
 said
 data
 with
 the
 record
 of
 74-11.
 The
 hear-
ing
 officer
 did
 not
 rule
 on
 this
 motion
 prior
 to
 our
 final
 action
 in
 this
matter,
 and
 it
 thus
 could
 not
 be
 considered
 in
 our
 deliberations.
 Fur-
thermore
 it
 was
 found
 that
 Edison
 had
 indeed
 filed
 monthly
 reports
 with
the
 Board,
 and
 the
 reports
 were
 filed
 under
 PCB
 73-40.
The
 Board
 still
 maintains
 that
 the
 proper
 course
 of
 action
 would
 have
been
 to
 file
 the
 data
 in
 the
 record
 during
 hearing,
 and
 discuss
 on
 the
record
 whether
 such
 data
 would
 have
 aided
 the
 Board
 in
 its
 decision.
Lacking
 this
 data
 the
 Board
 has
 no
 way
 of
 using
 real
 time
 information
 to
assess
 the
 impact
 on
 the
 community,
 and
 must
 turn
 to
 modeling
 data
 in-
stead.
 Were it not for the very short duration of this variance, the
Board would deny Edison’s request for a variance regarding Waukegan on
this
 point
 alone.
 However,
 in
 light
 of
 the
 short
 duration
 of
 this
 vari-
ance, we feel it better to grant the variance and condition the same on
a clear definitive order regarding the submission of all available data
to the Board as well
 as the Agency.
In making this decision the
 Board
 has
 relied
 on
 the data provided by
the Agency and Edison regarding projected
 air
 quality.
 Melvin
 Exhibit
#2 was instrumental in this decision.
 Table 13 of such exhibit relates
Edison’s
 predicted
 contribution
 to
 air
 quality
 from
 the
 Waukegan
 station.
A
 review
 of
 this
 table
 shows
 potential
 violations
 of
 the
 three
 hour
 stan-
dard about once every three years under fumigation conditions.
 However,
these predictions are based upon emission data which are somewhat higher
than one would expect to exist on October
 4,
 1974.
 Unit
 #8 was projected
at 0.427#/mm BTU, while with flue gas conditioning the figure is more
likely 0.07*/mm BTU.
 Unit
 #5 is projected at 1.27*/mm BTU, while there
is an excellent possibility that the unit will be shut down on October
4,
 1974, and thus will generate no particulates.
Taking all into account the Board will grant conditional variances
for Waukegan units
 6,
 7 and
 8.
 No variance will be granted to Unit
 #5.
13—683
—4—
Although the lack of variance will not force Edison to shut down Unit
#5,
 it is the intent of the Board by this denial to prod the conversion
of Unit #5 to
 a dual ESP system. We are aware that this unit may already
be
 down, and as such a variance would not be required.
In writing this Order, the Board is aware that Powerton 1-4 will be
retired during October 1974.
 However, we do not know the exact shutdown
date, and for purposes of this Order we will assume that Powerton l—4
will be running up until October 15, 1974.
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.
 Variance for Sabrooke Units
 #3 and #4
 is dismissed as moot.
2.
 Variance is granted for Sabrooke Units
 #1 and #2 until October
15, 1974, from Rules 203
 (g) and 3—3.112.
3.
 Variance for Waukegan Unit
 #5 is denied.
4,
 Variance is granted for Waukegan Units
 #6,
 7, and
 8 until October
15, 1974,
 from Rules 203
 (g)
 and 3—3.112.
The above variances are conditioned on the following:
A)
 Waukegan Unit #8 shall
 run
 in the normal sequence of Edison’s
system
 capacity,
 provided
 that
 Edison
 make
 every
 reasonable
effort
 to
 continually
 operate
 its
 SO3
 injection
 system.
B)
 Data
 as
 to
 the
 effectiveness
 of
 the
 SO3
 injection
 system
 shall
 be
supplied
 to
 the
 Agency
 and
 the
 Board
 by
 October
 15,
 1974,
C)
 Waukegan
 Unit
 #6
 shall
 be
 operated
 only
 after
 all
 available
 Ed-
ison capacity has been utilized (including Waukegan #8), but be-
fore Powerton Units
 1 to
 4, Sabrooke 1 and 2, Waukegan
 7, and
Edison’s
 fast
 start
 peakers
 are
 utilized.
D)
 Sabrooke Units
 #1 and 2 shall be operated only after all available
Edison capacity has been utilized, including Waukegan 8 and 6,
but
 before
 Powerton
 Units
 1
 to
 4,
 Waukegan
 7,
 and
 Edison’s
 fast
start
 peakers
 are
 utilized.
 However,
 one
 of
 the
 Sabrooke
 units
(1 or
 2)
 may be operated at the minimal level necessary to provide
steam for water demineralizers, heating the station, or to prevent
stack deterioration in the event that Units
 3 or
 4 cannot be used
for this purpose.
E)
 Waukegan Unit
 #7 shall be operated only after all available Edison
capacity
 has
 been
 utilized,
 including
 Waukegan
 8
 and
 6,
 Sabrooke
1 and 2, but before Powerton 1
 to
 4
 and
 Edison’s
 fast
 start
 peak-
ers are utilized,
13—684
—5—
F)
 Edison
 shall
 continue
 to
 maintain
 and
 operate
 its
 nine—station
network
 of
 air
 quality
 monitors
 as
 ordered
 in
 PCB
 73-40.
 All
data
 generated
 to
 date
 shall
 be
 submitted
 to
 the
 Board
 by
 October
15,
 1974.
 Data
 submitted
 during
 the
 period
 of
 this
 variance
 shall
be
 submitted
 to
 the
 Agency
 and
 the
 Board
 by
 November
 1,
 1974
G)
 The
 bond
 required
 in
 Condition
 6
 of
 the
 Board’s
 Order
 in
 PCB
73-40
 (Opinion
 date
 October
 4,
 1973)
 shall
 remain
 in
 full
 force
and
 effect
 for
 the
 duration of this Variance,
I,
 Christan
 L.
 Moffett,
 Clerk
 of
 the
 Illinois
 Pollution
 Control
 Board,
certify
 that
 the
 above
 Opinion
 and
 Order
 was
 adopted
 by
 the
 Board
 on
 the
~“7”~
 day
 ~
 1974,
 by
 a
 vote
 of
 ____
 to
 ~
13—
685