ILLINOIS POLLUTION CONTROL BOARD
December 6, 1973
)
COMMONWEALTH EDT SON COMPANY
)
)
)
v.
)
PCB 73-295
)
)
ENVIRONMENTAL PROTE CTTON AGENCY
)
)
MR. RICHARD E. POWELL and CHARLES E. WHALEN,
Isham, Lincoln and
Beale, appeared on behalf of Commonwealth Edison
MR. DELBERT
I). HASCHEMEYER, Assistant Attorney General, appeared
on
behalf of the Environmental Protection Agency
OPINION AND ORDER OF THE
BOARD (by Mr. Dumelle):
Edison filed a Petition for Variance on July 16, 1973 which
sought an extension of the variance originally granted on October 14,
1971, in PCB 71-129 and extended by operation of law in PCB 72-295
on December 31, 1972 when the Board lacked a quorum. On August 23,
1973, the Agency filed its Recommendation to deny the variance
petition. Three days of hearings were held on August 27, September
13 and September 14, 1973. On October 9, 1973, Edison filed a
Motion for Additional Time in order to file post hearing briefs,
sought an Interim Variance until November 19, 1973, and filed a
waiver until that date. The Board granted Edison’s motion on
October 11, 1973, and Edison’s and the Agency’s briefs were received
on October
‘73
and October 24, 1973. On November 8, 1973, the
Board ordered that Edison provide limited information clarifying
the current status of Z:ion Unit #1, which was not evident from the
record. Edison filed a Motion seeking an additional three weeks
to reply to this Board order and filed a Waiver until December 7, 1973.
The Board granted Edison an Interim Variance until December 7, 1973,
to allow Edison time to comply with its Interim Order.
On November 27, 1973, Edison filed a Petition for Modification
of Powerton Units 1-4 Operating Restrictions, a Motion for an Interini
Variance, and a waiver. Edison filed an Information in Response to
Board Order on November 30, 1973, which was requested by November 8,
1973 Order requesting additional information concerning Zion Unit 1.
-2-
The Board denies the Motion for interim variance because the
Board has decided to rule on the original variance petition.
Edison’s request for a modification of the Powerton Units 1-4
operating restrictions is granted because the Board’s ruling on
November 29, 1973, modifying its original order in PCB 73-40,
72-441, and 72-492, altered the operating sequence to allow Edison
to utilize all of its coal-fired capacity prior to utilizing
its peaking units. The Board has incorporated this operating
sequence in the present order which modifies the original variance
granted in PCB 71-129 to reflect the operational sequence
found in PCB 73-40.
Edison operates an electric power generating station, known
as the Powerton Station, located near Pekin, in Tazewell County,
Illinois. The Powerton Station contains five steam-electric
generators with a sixth under construction and scheduled for operation
in 1975. The units which are the subject of this variance request
are Units 1-4 with an aggregate winter capacity of 350 mw. from
twleve coal-fired steam generators without pollution control
equipment to limit emissions. Unit 5, which is not subject to
this variance proceeding, is an 850 mw. unit and is the largest
coal-fired unit in Illinois.
The variance (PCB 72-295 and PCB 71-129), which Edison seeks
to be extended, is subject to the following conditions:
(a) Powerton shall be the last unit on the Edison system
committed to service and the first taken off after the
daily peak period is passed. Powerton shall be
committed only with sufficient lead time to insure that
unit’s availability for the peak period. When
Powerton’s capacity is required to meet a predicted
daily load plus the operating reserve, the station
will be initially loaded to approximately 50 capacity.
Before the remaining capability of the Powerton units
will be utilized, all other units on the Edison system--
including the fast start peaking units--will be
brought to full operating load, exclusive of emergency
capability.
(b) The above shall not apply if weather conditions, which
may cause icing on transmission lines exist, or if
Edison’s projected daily peak load equals or exceeds
70 of the projected annual peak load.
Edison has taken steps to lessen the environmental impact
of operating Powerton Units 1-4, and alleges that the load factor,
percent of the time that the Powerton units are in operation,
has decreased from 42.3 in 1971 to 9.6 in 1972 to 6.5 in the
first half of 1973 (R. 254). Edison alleged that by burning low
10
— 228
—
sulfur
coa’
with
a
low
ash content
and
higher heating value, they
have instituted a 40 to 30 reduction in fly ash emissions per
kw-hour (R. 255). Edison alleged that when this
lower sulfur
coal is combined with the reduction in load factor it results
in an approxlmate 80 reduction in SO2 and particulate emissions
from the Powerton Units 1-4 (R. 255). While SO2 emissions are
not the actual subject of this variance request, SO2 emissions
are important due to the nuisance aspects of Powerton Units 1-4
operation and possible synergistic effects of SO2 and particulate
emissi ons.
The Agency presented information that showed Powerton Units 1-4
to have a capacity factor of between 12.6 and 2.5 with an
average of 7.5 for the first half of 1973 (EPA Ex. 13). The
percent of the days
that Edison operated
any of Powerton Units 1-4 was
shown to range between 23 and 81 of the days during the first
half of 1973 (EPA Ex. 11). Thus while the capacity factor is
low, Edison has felt it necessary to operate at least one of the
Four units at some level on an average of half of the days.
Citizen testimony presented at the hearing, graphically
illustrates that even with the limitations in the operation,
the continued operation of Powerton Units 1-4 produces a sub-
stantial nuisance and hardship to the nearby citizens (R. 455-477).
Mr. Billy Keen, who had testified in the prior hearing PCB 71-129,
his wife, and Mrs. Monk testified that emissions from the Power-
ton Station result in substantial interference with their right
to enjoy backyard outside activities such as picnics and swimming
in their swimming pools (R. 456, 468, 469, and 476) ; builds up
on window sills (R. 456) ; results in the need to continuously
clean
the
inside of their houses (R. 467) ; and soils and stains
the outside of their residences (R. 71, 475). They further
testified that the emission causes coughing and a burning in
their throats (R. 464, 476). They all testified that the
emissions are worse during the summer, and that during the month
of July the emissions are at their Worst (R. 465, 468, and 477).
Mr. Keen testified that the worst emissions were emitted from
the shorter stacks (R. 459). He presented a photograph (EPA Ex~19)
which shows emissions from the Powerton Station moving toward his
residence.
Edison presented data collected by the State, which shows
that annual particulate averages exceed the allowable level, and
that most of the time 24-hour standards are violated with
some frequency (R. 318). The Agency calculated that a 5,300 mw.
facility operating i~ithin the standards would produce the
same amount of emissions as the 350 mw. produced by Powerton
Units 1-4 while operating at the lower capacity factors from
January to June 1973 (R. 385). The record clearly shows and
the Board finds, that Powerton Units 1-4 result in air pollution
when they are operated.
10
— 229
-4-
Edison, as
in the original variance request, alleges that
it
needs
160
mw.
of
generating capability to provide “first
contingency
protection” For the Crawford sub-station serving
downtown and mid-town ChLcago on the 69
KV
line (R.
49).
Edison
defines “first contingency protection”
as
that generating capability
necessary to tolerate the loss of (a)
two
major generating units,
(b) one generating unit and one transmission line, or (c) one
major transmission line (R. 29)
.
Edison further alleges that
it needs the full generating capability of the Powerton Units
1-4
in order to provide power during necessary maintenance outages
and to meet the expected 1974 summer peak (R. 86). Edison has
been proceeding on schedule to make transmission system changes
to obviate the need to retain Powerton Units 1-4 to provide first
contingency protection, hut those changes will not be completed
until May 15, 1974 (R. 30). Edison alleges that it needs to
maintain the ability until mid August 1974 to utilize Powerton
Units 1-4 as zone protection in the event of an occurrence of
one of the above three mechanical breakdowns and a malfunction
in the new equipment which is to be installed prior to May 1974.
The Agency alleged that Edison does not need to provide first
contingency protection through the use of Powerton Units 1-4
(Recommendations, pp. 3-4) based upon the testimony of Dr.
VanNess, an Agency witness, in PCB 72-295, that it would be
possible to prevent overloads on the 69 KV system by switching
power from another source, through the Powerton Station and
then to the 69 KV system (R. 262, PCB 72-295). The Board
finds that the Agency did not rebut Edison’s testimony that
only 70 mw. could be transferred through the Powerton Station
(R. 184) and that 160 mw. was needed to provide the necessary
protection (R. 159, 160). The Board recognizes that Edison will
have to utilize Powerton Units 1-4 to provide first contingency
protection. For this reason, the Board grants Edison an extension
of the variance to operate Powerton Units 1-4 up to 160 mw. in order
to provide first contingency protection for the
69 KV system
until such time as the modifications to the transmission system
are completed in mid-May 1974, and the need for first contingency
protection has passed.
The Board also grants Edison a variance
to allow it to maintain Powerton Units 1-4 in order to provide
additional protection against the overload 0:1 the 69 KV system
from May 1974 until August 15, 1974.
This additional insurance,
in the event of a system breakdown and
a malfunction in the new
equipment, should be an extremely unl:ikely occurrence (R. 134).
Because the Board has recognized Edison’s need to operate
Powerton Units 1-4 in order to provide first contingency protection
this winter, Edison must be allowed to
operate Powerton Units 1-4
for dc-icing purposes to ensure that the necessary transmission
lines remain in service. Consequently, the Board grants
Edison a variance to operate Powerton Units 1-4 in order to
dc-ice the
transmission lines between Powerton and Crawford
Stations.
10 —230
-~-
The Board agrees with the Agency that the failure to
present evidence
concerning the computer study of the probability
of two units
being
out at the same time is a major oversight
by
Edison,
however, the Board does not think it warrants denial
of the variance. The Board’s granting of the variance should
not be taken as an approval of Edison’s decision not to use
overtime labor in complying with the previous Board order.
Ilowever, little would now be gained by ordering overtime labor
in the light of the testimony that equipment delays are the
controlling time factor at the present time (R. 46).
The Board is next Faced with the question of whether or
not to extend the variance in order to allow Edison to utilize
Powerton Units 1-4 to meet system demands during maintenance
and summer peak load periods. Edison has alleged that they need
Powerton Units 1-4 until October 15, 1974, when the four units
will be retired from coal-fired service (R. 99). The Agency
alleges that Edison has failed to meet its burden to show that
it in Fact needs Powerton Units 1-4 to meet system demands
during both maintenance and peak periods. When deciding
whether or not to grant an extension of the present variance,
the Board must weigh the environmental degradation resulting
from such operations versus the hardship placed upon Edison by
the denial of the variance petition. An integral part of Edison’s
hardship is that hardship that would be placed upon Edison’s
customers in
the event that Edison could not meet the demand
for power.
Edison and the Agency have conducted monitoring studies
in order to estimate the environmental impact in the surrounding
area which would be caused by operating Powerton Units 1-4.
Edison
retained Argonne National Laboratory to perform modeling
studies (Air Quality Display Model .(AQDM)) to estimate the effects
of the emission from Powerton Units 1-4 on long-term or annual
ambient air quality. The model included a recently-updated
inventory of all major emission sources (202 in number) in the
Peoria area and an estimate of the total emissions from all the
smaller sources in the region (R. 198). Edison alleged Argonne’s
AQDM model was used extensively by the Agency and by the Board
in considering the recently adopted emission regulations (R. 195,
96, 200). Edison presented evidence concerning two sets of
predictions: Impact on annual ambient air quality in the area
and short term impact (24-hrs. or less) (Edison Ex. 8 and 9).
Edison Exhibit 8 shows the result of the computer modeling
program to predict the annual particulate and sulfur dioxide
ambient concentrations in the Peoria Major Metropolitan Area as
predicted by the AQDM. Edison Exhibit 8 is based upon the
result of Edison Exhibits 12-A thru 12-B; which are computer
10 —231
-6-
determ:inations For all emissions in the Peoria reg:i.on
excluding Powerton Station, and a senarate determination
for each emission from the four individual stacks at the
Powerton Station (Edison Ex. 12 A-B). The AQUM was based
upon 1970 Peoria meteorological data (R. 201). The
model predicted SO2 and particulate levels for some 237 grid
point locations (R. 207) based upon a seven kilometer grid
system (R. 311). The results of the AQDM, presented in Edison
Exhibit 8, purport to show that at the grid point of maximum
ambient concentration resulting from emissions from all other
sources that the SO2 level would be as follows:
Excluding
Including
Powerton
Period
Powerton 1-4
Powerton 1-4
Contribution
8/70
-
7/71
135.48 pg/m3
139.00 pg/rn3
2.5
8/71
-
7/72
135.85 ~g/m3
137.48 pg/rn3
1.2
8/72
-
7/73
136.96 ~ig/m3
137.34 pg/m3
0.2
Edison Exhibit 8 also shows that at the point of maximum
Powerton Contribution, the ambient SO2 concentration would be:
Excluding
Including
Powerton
Period
Powerton 1-4
Powerton 1-4
Contribution
8/70
-
7/71
51.48 pg/m
66.34 pg/m3
22.6
8/71
-
7/72
52.53 ~g/rn3
57.55 pg/m3
9.7
8/72
-
7/73
55.74 ~g/m3
57.55 pg/m3
3.1
Edison Exhibit No. 8 also shows the maximum particulate
matter levels predicted by the AQDM as follows:
Excluding
Including
Powerton
Period
Powerton 1-4
Powerton
1-4
Contribution
8/70
-
7/71
162.94 pg/rn3
166.43 pg/rn3
2.10
33
8/71
-
7/72
162.94 fig/rn
163.66 pg/m~
0.40
8/72
-
7/73
162.95 pg/rn3
163.36 pg/rn3
0.25
Edison Exhibit No. 8 shows also that at the point of maximum Powerton
Contribution, the particulate levels would be
Excluding
Including
Powerton
Period
Powerton 1-4
Powerton 1-4
Contribution
8/70
-
7/71
79.43 ~g/rn3
101.29 pg/rn3
21.6
10
—
232
-7-
Excluding
Including
Powerton
Period
Powerton 1-4
Powerton 1-4
Contribution
8/71
-
7/72 79.44 ug/m3
84.5 ug/m3
6.0
8/72
-
7/73 79.47 ug/m3
81.85 ug/m3
2.9
Edison Exhibit 9 is a listing of the three points within
the Peoria-Pekin vicinity that had the highest reported particulate
level concentrations from 1967 thru 1971. At all three points, for
all five years, the annual geographic mean value has exceeded
the pri1~aryannual ambient air quality particulate st~ndards of
75 ug/m
.
The 1971 values ranged from 93 to 101 ug/m3, and the
maximum values ranged from 256 to 398 micrograms per cubic meter.
The maximum 24-hr. concentrations, which is not to be exceeded
more than once per year, is 260 micrograms per cubic meter.
Edison Exhibit No. 9 clearly shows,and the Board so finds, that
the ambient air quality in the Peoria-Pekin vicinity exceeds
the primary air quality standard for both the annual geographic
mean and the maximum 24-hr. concentration. Edison’s monitoring
sites included high-vol samplers for particulate monitoring
and 14 lead candle and 2 continuous SO2 monitoring devices (R. 209).
The Agency alleged Edison’s systems did not include a
value for the terrain of the vicinity (R. 209) and did not
consider short-run effects (R.2l0). The Agency also pointed
out that Edison’s values are based upon grid location points
which do not necessarily coincide with the point at which the
maximum level of the pollutant would occur and therefore does
not include the worst 24-hr. period’or the greatest annual value
(R. 276). The Agency further alleged that Edison’s modeling
did not include a frequency factor for the occurrence of
adverse meteorological conditions (R. 305) and did not calculate
values for an inversion (R. 322). Edison alleges that Exhibit 8
and 9 show that emissions from Powerton Units 1-4 have had
little impact on annual ambient air quality in the Peoria-Pekin
area (P. 14 of Edison’s brief).
Edison also modeled the short-term (24-hr. or less) effect
of the operation of Powerton Unit 1-4 upon ambient air quality
in the area (R. 258)
.
Because of the restrictions that had been
placed upon Edison’s operation of Powerton Units 1-4, Edison
assumed as the “worst case” that the units would be operated for
an extended period to prevent the formation of ice on the transmission
lines (R. 258-59). Edison Exhibit No. 11 supports Edison’s
choice of an operational level of 60 as being the worst
case on record since the use restrictions, as it shows that during
December, 1972, Edison operated Powerton Units 1-4 on a daily
average 5,167 mw. hours. Operation at 100 capacity for a
24-hr. period would equal 8400 mw. hours. Edison’s short term
10—233
-8-
model was further based upon the wind blowing from the same
direction and at the same speed during the entire 3 or 24-hr.
averaging period (R. 261). Edison alleges that with the above
“very conservative assumptions”, the operation of Powerton
Units 1-4 would not result in violations of the short term
primary or secondary air quality standard (R. 260, Edison
Lx. 10)
.
Edison Exhibit 10 shows the estimations of
the
short
term concentrations of particulate and SO levels for various
unit loadings and stability classificatio~s as follows:
Part i cu late
Estimate of
Maximum Ground
Level
Load
Stability
Time (hrs.)
Concentration
215215
UnstableNeutral
2424
12390
fig/rn~mg/rn~3
3
350
Unstable
3
503 pg/rn
Sulfur Dioxide
Estimate of
Maximum Ground
Level
Load
Stability
Time (.hrs.)
Concentration
215215
NeutralUnstable
2424
145196 pg/rnpg/rn~3
The350 primary
Unstableand
secondary ambient air3 quality standards are:808
1ig/m3
Time (hrs.)
~
Secondary
Particulate
3
3
24
260
pg/m~
130 pg/m
SO
-,
3
2
24
365
pg/rn~
260
3
1300 pg/rn3
10
—
234
-9-
Edison alleges that continuing operation of Powerton
Units 1-4 under the current operating restrictions (see page
2 of this opinion for a listing of the operating restrictions)
will not have a significant affect on the air quality in the area
(Edison Lx. 8, page 14 Edison’s Brief and Argument).
The Agency calculated a particulate emission rate of
4.83 lbs./M Btu’s for Units 2, 3, and 4 and 6.31 lbs./M Btu’s
for Unit 1, and calculated a SO emission rate of 6.43 lbs./M Btu’s
for all four units (EPA Ex. 8).2 The Agency emphasized, and it should
be pointed out, that Powerton Units 1-4 are the only investor owned
plant in Illinois without any particulate control equipment (EPA
Ex. 7).
The Agency characterized Edison’s Exhibit 8, which shows
that Powerton Units 1-4 caused a 3.1 increase at the point of maxi-
mum concentration in particulate levels for August 1972 thru
July 1973, as occurring during intermittent low capacity
operation. The Agency alleges that the only logical conclusion
that can be drawn is that whefl Powerton Units 1-4 operate, they
cause a much higher and truly significant impact on air quality
(Page 5, Agency Post Hearing Brief). The Agency characterized
Edison’s modeling as comparing a dispersion model to approximately
25 selected monitor readings taken at specific locations.
Stability class frequency distributions were not taken into
consideration, nor were topographical feastures and certain
meteorological conditions. The Agency also pointed out the
relatively short stack heights at Powerton Units 1-4 of between
300 and 350 feet (EPA Ex. 8).
The Agency modeling evidence (EPA Ex. 21 thru 25) was refused
by the Hearing Officer based upon Edispn’s objections that it
assumed at a 24-hr.
,
365 day operation; the Agency used the
maximum sulfur content in the fuel rather than the average content;
and that there was no foundation for the particulate level
(R. 570, 571). However, Exhibit 21 thru 25 were accepted as
pointing out the predicted location and direction of the point
o:F maximum concentration (R. 583)
The Board overturns the ruling of the Hearing Officer and admits
Agency Exhibits 21 thru 23 into evidence without the qualification.
The objections raised by Edison should go to the weight to be
given the computer modeling, not to its admissibility. The Exhibits
were discussed, offered into evidence, cross-examined, and should
have been admitted.
Mr. David Kolaz, testified concerning the results of Agency
computer modeling studies using the air quality display model for
(Iiffcyent combinations of the Powerton Units (R. 311). The
Agency’s air quality display model is a derivative of the Federal
government air quality display modell (R. 513)
.
The model allows
10
—
235
-10-
one to compute the annual average concentration of particulates
and SO9 and uses a statistical analysis to compute short-term
concentrations, based on the average annual concentration (R. 514).
The Agency’s model also utilizes various meteorological conditions
or classes, in the form of a percent frequency o:F occurrence
for six wind speed classes, sixteen wind directions, and five
stability classes (R. 514). The model is setup so as to allow
the calculation of a
concentration at every half a kilometer
in a square grid pattern and 12 non-grid receptors (R. 515).
The closest receptor to the Powerton station was located 1/2
kilometer east and north of the Powerton station (R. 521).
The Agency’s model was based upon particulate and SO2 emission
rates contained in EPA Exhibit 8 (R. 523). Based upon the
Agency’s modeling, the point of maximum particulate concen-
tration would occur 7 kilometers north of the power station
(R. 528). The Agency’s calculation of maximum concentrations
for Powerton’s Units 1-4, including Powerton Unit 5, would be
6 micrograms per cubic meter for particulates and 4 micrograms
per cubic meter for SO2 excluding background levels
(R. 529, EPA Ex. 21).
As pointed out by Edison’s cross-
examination of Mr. Kolaz the Agency’s modeling was based upon the
assumption that Powerton Units 1-4 operated 24-hrs. a day seven
days a
week at 100 capacity (R. 532).
Jack Coblenz, the Agency Manager of the Division of Air
Pollution
-
Technical Services Section, testified that a down
washing ef:Fect could occur at the Powerton station site (IL 544).
This could result in higher than
predicted levels since dispersion
models assume a flat surface and assume no down-wash (IL 541)
Mr. Coblenz Further testif:ied that dispersion modeling is accurate
within 50 or that the numbers the Agency or that Edison calculated
could be in error from one half to double the actual value (II. 545)
Edison’s model showed that at the point of maximum concentra-
tion Powerton would contribute 0.3 in 1971, 0.3 in 1972,
and 0.2 in 1973 of the pollution level IR. 547, 548). The
point Edison showed as the point of maximum concentration is
located in the heart of Peoria where emissions :From other
sources, closer in relationship than the Powertion station,
would have had a very large affect (R. 547). In examining receptor
#66 of the Edison data, Mr. Cobienz testified that there was
in fact another contributor whose actual emissions were much less
than Powerton, but were so close to the receptor that they had
a greater effect than Powerton (II. 548)
Because the Agency’s model contains some 196 grid points in
the area represented as one grid in the Edison data, the Agency’s
model should predict the theoretical point of maximum concentration
with a greater degree of accuracy (R.
549).
Mr. Coblenz further
testified that because Powerton Units are located in a river valley,
10
—
236
-11-
the effect would be that winds would tend to follow the valley
so that the frequency of winds from the Powerton Station to Pekin
and Peoria would be much greater than the wind frequency direction
as given by a weather station located outside the valley (R. 552).
Mr. Coblenz testified that wind direction from the south, south-
east, and southwest occurred at a 40 frequency, but along the
river valley would occur at a greater frequency so that instead
of the plume dispersing east and west, the pollution would generally
go up the valley summer and spring and in the winter time would
go down the valley to the south (R. 553).
Based upon the modeling evidence presented, the Board finds
that Powerton Units 1-4 contribute a significant amount of
particulate and SO~pollution to the Pekin-Peoria area. Such
pollution must be ~eighed against any request for an extension
to meet peak loads.
Edison alleges that they need the power from Powerton Units
1-4 in order to meet the 1974 summer and maintenance period
peaks. Edison presented testimony that their planned reserve for
1974 would be 2,839 megawatts which includes Zion Unit 1 at
1,100 megawatts, Zion Unit 2 at 935 megawatts (85 capacity), Powerton
Units 1-4 at 350 megawatts, and Waukegan and Sabrooke Units at
1,092 megawatts (R. 75). Edison alleges that the loss of Powerton
Units 1-4 would reduce their summer peak to 2,489 or l9~ (R. 77, 144).
Edison further alleges that because they are burning low sulfur
coal they have a 375 megawatt power peak reduction (R. 82). Edison
has always stated that because of their great degree of inter-
connection with other systems that they must maintain only a 14
planned reserve (R. 145). They testifiod that they have an
additional 1600 to 1800 megawatts available in the event of
an emergency (R. 146). Edison has contracted to sell 410 megawatts
during the summer of 1974 (R. 143). Edison~s“planned reserve”
is a long-range planning concept which does not include the
actual reserve that might exist on a given day. As Edison
points out the actual daily reserve available at a given point
and time determines whether or not Edison can meet a system demand.
Edison’s estimated total peak load for the summer of 1974 is 14,170
megawatts (R. 72). Edison’s planned reserve for the summer of
1974 equals 22.1 (R. 73). Edison has testified that 14.0
planned reserve is adequate to meet system-wide demands. Edison’s
planned reserve of 14 is based upon a design that will allow
Edison to meet the peak loads in the event of system-forced outages.
Edison’s planned reserve figures assume that Zion Unit 1 will
provide 1,100 mw. or 100 capacity (R. 75) and that Zion Unit 2
will provide 935 mw. or 85 capacity (R. 75, 76). Zion Unit 1
is currently licensed at 935 mw. (85) capacity by the Atomic
Energy Commission; but it has not operated above 688 mw. due to
mechanical operating restrictions (Edison Information in Response
10
—
237
-12-
To Board Order, November 30, 1973).
Edison will shut down
Zion Unit 1 before February 3,
1974, to eliminate the mechanical
operating restriction,
and will return the Unit to service by
April 28, 1974 (Edison Information, November 30, 1973).
Once
the modifications have been completed, Zion Unit 1 will be tested
at 75 capacity (Edison Information, November 30, 1973). Once
the 75
testing
has been completed in early June, 1974, Edison
will operate Zion Unit 1
at
85
or 935 mw. (Edison Information,
November 30, 1973).
Edison further assumed that Zion Unit 2
will provide 935 mw. of capacity (85 of its
design capacity)
for the summer of 1974, but the record shows that construction
of the unit will not be completed until I)ecernber, 1973 (R. 75, 76).
Consequently, 2839 megawatts of the estimated reserve includes
2,035
mw. of capacity from two nuclear units that have not yet
demonstrated their total reliability
and 935 mw of that planned
reserve are from a unit that is still being constructed. Edison
points out that without 2,035 mw. from these units, Edison’s
planned reserve would only be 804 mw., or 5.6,
which
is totally
inadequate to protect against forced outages (II. 79, 80).
The Board in its Order in PCB 73-40, as modified on
November 30, 1973, issued a priority of operation order that
requires Waukegan Station above 355 mw. be the last coal-fired
facility in the Edison system to go on line. The Board thus
changed its previous Order in PCB 71-129 which required that Power-
ton Units 1-4 above 50 be the last coal-fired unit to go on line.
The Board’s Order, as modified in PCB 73-40, also recognizes
that, there existed a need to conserve oil and gas. The Board
ordered that Waukegan above 355 mw. and the Powerton Units above
50 capacity be operated prior to the fast-start peaking units.
The change in operating sequence represents a substantial
change in the Board’s position as to the operating sequence
of Edison capacity. It would tend to change the figures presented
in the record that show the daily load factor at the Powerton
Units 1-4 as being substantially below 20. The Board points
out, however, that the variance granted in the Waukegan case
was a short-term six month variance that requires Edison to
submit monitoring data before the variance will be extended
(Order of the Board, PCB 73-40, October 4, 1973). The Board
hopes that as a result of that monitoring data, Edison will be
allowed to operate Waukegan ahead of Powerton Units 1-4. However,
the Board finds that Edison and the Agency have failed to present
substantial evidence to warrant the modification of the October 4,
1974 Order. Testimony as to the adverse health effects of the com-
puted Waukegan Power Plant emissions was the basis of the Board’s
order ordering the priority schedule in Edison’s system. The
Board notes, however, that this variance and the operational se-
quence is subject to being changed pending the result of monitoring
data,concerning the Waukegan emissions.
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The Board examined the Monthly Load and Capacity Schedule
(EPA Lx. 10) by subtracting the restricted output and outage
of
Z:ion Unit 1 (Edison Information, November 30, 1973); by
subtracting the output of Waukegan above 355 mw. ; by subtracting
Powerton Units 1-4 350
mw. production; and
by removing the
1726 mw. of peak production. This series of mathematical
calculations resulted in the following excess capacity over the
monthly projected peak load estimates:
Dec.
Jan.
Feb.
Mar.
April
May
Excess
Mw, 553
113
-555 -345
255
210
Operation of Waukegan without any operating restrictions during
the air quality testing program would supply an additional
590 mw.
which would offset the negative values for February and March.
Thus, even if the Board grants Edison a variance to operate
Powerton Units 1-4 to meet peak loads during December through
May; Edison should not have to operate Powerton Units 1-4 (or
Waukegan above 355 mw. when not conducting air monitoring studies)
unless a mechanical malfunction occurs. Operation of Powerton
Units 1-4 to provide “first contingency protection” and during dc-icing
periods would tend to increase the
excess capacity figures.
The Board is faced with a decision as to whether or not to
grant Powerton a variance to operate during
peak periods. Edison’s
own testimony that their planned reserve equals 2,839 mw. (22.1)
would normally be
sufficient as to deny the variance request to meet
the summer peak period.
However, in light of Edison’s inclusion
of power from Zion Unit 2 and from Zion Unit 1 above the level
at which it is currently operational, the Board has decided to
grant Edison the right to use Powerton Units 1-4 to meet system
demand both as to maintenance and peak period until October
15, 1974 at which time Powerton Units 1-4 will be shut down.
The
Board notes
that
Edison has evidently contracted to sell
410 megawatts in the summer of 1974 (R. 143). Because Edison
has
been granted variances to operate Powerton Units 1-4 and Waukegan
above 355 mw. as the last coal-fired units to be placed on line
before use of the peaking units, the sale of 410 mw. during the
peak period would subject the citizens surrounding the two power
plants to potentially dangerous pollution levels.
Operation of
pollution sources to provide energy to people outside Edison grid
system may be unreasonable. It is one thing to subject the citizens
to air pollution in order to protect fellow citizens on the same
Edison system from blackouts; but, it is quite different to subject
citizens to air pollution merely to satisfy a contractual obligation
to deliver power outside the 3ystem.
Edison has failed to provide
any information regarding the ultimate consumption of that power or
necessity of supplying the power. The present record is woefully
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239
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lacking of any information regarding the contract to to sell
the 410 mw. at a time Edison is seeking variance to operate four
units that lack any pollution abatement equipment. The Board
does not make any ruling on the propriety o:F this contract in
granting this variance request. However, the Board will again
be faced with this question when ruling on any extension of the
variance that Waukegan Station is currently operating under
(including any system operation sequence changes). Edison has the
burden of establishing
the
need to operate its units while supplying
power (excess capacity) to systems outside Edison’s own grid.
This Opinion constitutes
the
findings of fact and conclusions
of law of the Board.
ORDER
The Board hereby grants to Commonwealth Edison a variance
to emit particulate matter in excess of regulation limits
until October 15, 1974, subject to
the following conditions.
1. Powerton Units 1-4 shall be the next to last coal-fired
Units on the Edison system committed to service and the
second coal-fired unit taken o:Ff after the daily peak
period is passed. Powerton Units 1-4 shall be committed
only with sufficient lead time to insure that unit’s
availability
for the peak period.
When
Powerton Unit 1-4
capacity is required to meet a predicted daily load plus
the operating reserve,
the
station will he initially
loaded to approximately 50 capacity. Before the remaining
capability of
the Powerton Units 1-4 will he utilized, all
other coal-fired units on the Edison system--except Waukegan
above 355 mw.
-
-will be brought to Full operating load, exclusive
of emergency capability. Coal- f:i red units shall be operated
prior to the operation of fast-start peaking uni.ts.
2. The above shall not apply if weather conditions, which
may cause icing on transmission lines exist or if
Edison’s projected daily peak load equals or exceeds
70 of the projected annual peak load.
3. This Order is subject to further Board Orders in the event
that Edison or the Agency demonstrates to the Board that
operation of Powerton Units 1-4 present a greater health
risk than operation of Waukegan Station.
IT IS SO ORDERED.
I, Christan L. Mo:Ffett, Clerk of the I llinois Pollution Control
Bo4rd, hereby certify the above Opinion and Order were adopted on the
~)_day of December, 1973 by a vote of ______________________________
Christan L. Moflet ~/‘lerk
I,—
Illinois Pol1ution~bntroi Ooard
10 —240
