ILLINOIS POLLUTION CONTROL BOARD

January 30, 1973

WESTERN ILLINOIS POWER COOPERATIVE, INC. 

)

Petitioner,

V.

)

PCB72—441

ENVIRONMENTAL PROTECTION AGENCY,    

)

Respondent.

Theodore Rammelkamp, Esq., of Jacksonville, Illinois, for Petitioner;

Delbert Haschemeyer, Esq., Assistant Attorney General, for Respondent.

OPINION AND ORDER OF THE BOARD (by Mr. Lawton):

On November 13, 1972, Western Illinois Power Cooperative,

Inc. (“WIPCO”) filed a petition for variance from Rule 2-2.53

of the Rules and Regulations Governing the Control of Air

Pollution, remaining in effect pursuant to Section 49 (c) of

the Environmental Protection Act. This particulate emissions

regulation remains in effect until May 30, 1975, when it will

be superseded by Rule 203 (g) of the Pollution Control BOard

Air Pollution Regulations.

WIPCO is an Illinois not-for-profit corporation engaged in

the business of producing, generating and selling electric power

at its Pearl station generating plant located in Pike County

near the town of Pearl. The plant is a 22 megawatt coal burning

steam turbine power plant consisting of one unit fired by four

burners, and is equipped with a mechanical multiple cyclone

dust collector. The boiler unit exhausts into one stack which

is 203 feet in height (Petitioner’s Exh. 1).

WIPCO is organized under the rules and regulations of the

Rural Electrification Administration (REA) of the United States

Department of Agriculture (R. 10-11). WIPCO was formed in 1960

by 7 electric distribution cooperatives in western Illinois to

provide electric energy to them on a wholesale basis, which they

would then distribute to the ultimate consumer (R. 11). WIPCO

serves 19 or 20 counties in a predominantly rural portion of

Illinois (R. 11). Under the Rural Electrification Act, WIPCO is

prohibited from serving urban areas over 1,500 in population unless

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that area does not have central generating station service

(R. 12). WIPCO serves no industrial customers; the majority

of its customers are farmers and a few small grain elevators

(R. 11, 112, 113).

The Pearl facility, designed in 1964, includes a mechanical

dust collector to remove particulates from the exhaust gases

(R. 13) 

The facility, with the dust collector, became commer-

cially operable early in 1967 (R. 13). The computed efficiency

of the collector was either 85 (Petitioner’s Exh. 1) or 90

(R. 13), and using the 90 computed efficiency, WIPCO’s calcula-

tions indicated that it would meet the particulate regulations

of the Air Pollution Control Board (R. 13)

The Environmental Protection Agency indicated to WIPCO in

April of 1972 that it believed WIPCO was not in compliance with

the particulate emission rule (R. 15) 

WIPCO then arranged to

have stack tests performed by Burns and McDonnell Engineering

Company, which tests, performed June 5 and 6, 1972, confirmed

that the Petitioner was probably in violation of Rule 2-2.53

(R. 15; Petitioner’s Exh. A) 

WIPCO’s feasibility studies indi-

cated that installation of a wet scrubber, rather innovative

equipment for coal fired electrical generating plants (R. 17, 70)

at the Pearl station would reduce particulate emissions to a level

below both Rule 2-2.53 and Rule 203 (g). The wet scrubber will

provide the additional benefit of reducing SO2 emissions (R. 17).

On October 16, 1972, WIPCO received approval of the project from

REA (R, 16). The stack tests also indicated that the mechanical

collector had an operating efficiency of 74.8 (Petitioner’s

Exh. 1).

Even before being informed of possible violations by the

Agency, WIPCO had begun serious discussions with REA for money to

upgrade the Pearl facility to meet the tightened requirements of

Rule 203 (g) (R. 13-14). On December 11, 1972, REA informed

WIPCO that $1,000,000 would be available to WIPCO to proceed with

its pollution control program (R. 16) 

At the time of hearing,

WIPCO was preparing specifications for bids on the equipment, and

hoped to have its specifications approved by REA by February of

1973 at which time the bidding process would begin (R. 65,66)

Contracts to purchase and install the equipment are expected to

be entered into by May, 1973 (Petitioner’s Exh. L) 

The total

estimated capital cost of the wet scrubber is approximately $600,000

(R. 18) 

and the estimated additional operating cost to WIPCO for

the wet scrubber is $67,400 (R. 19, Petitioner’s Exh. G).

the

same time that WIPCO is pursuing its long term control

program,

it

is attempting to

reduce particulate emissions by blend-

ing low ash petroleum coke with coal,

They have been so blending

fuels since August of 1972. Burns and McDonnell Engineering

Company estimated that this process will reduce the particulate

emission rate of 1.960 lbs. per million BTtJ of heat input to

1.51 lbs., and will reduce the SO~emission rate from 8.235 lbs.

per million BTU of heat input to ~.5 lbs. This estimated reduc-

tion of approximately 25 has not been verified by stack testing,

and the emissions will still be in excess of the .8 lbs. of parti—

culates per million BTTJ of input allowed by Rule 2—2.53.

Alternative methods

of complying with Rule 2-2.53 have been

investigated by WIPCO, and were deemed unsuitable.

Mr. Donald B.

Bringman, General Manager of WIPCO, stated that use of gas or

oil is not a feasible alternative because gas is not available to

WIPCO, and oil is impracticable as the Pearl facility cannot be

fired with oil (R,

19)

To modify the boilers to fire with oil

would cost approximately $250,000 for capital improvements and

approximately $600,000 for operating costs (R. 20)

WIPCO also investigated the possibility

of purchasing power

from Springfield,

Illinois.

WIPCO presently has a 15 megawatt

line to the City of Springfield (R. 23). Because WIPCO

generates

approximately 25 megawatts for its customers, it could not get

all the power necessary

from 

the 15 megawatt transmission line

from Springfield

(R. 23), even if Springfield had the capacity

available to transmit continuously 15 megawatts to WIPCO. Bringman

doubted that Central Illinois Light Company would

sell power to

Springfield for Springfield in turn to sell to WIPCO (R. 24).

Bringman also doubted that Central Illinois Public Service Company

would interconnect with WIPCO as long as WIPCO was interconnected

with Springfield (R. 25).

He

further stated that even if those

utilities

would sell power, the negotiations would take as long as

one year, and construction of necessary transmission facilities

least six months (R. 61)

WIPCO also considered

the use 

of its two other small generating

facilities,

a three megawatt diesel electric generating plant

near

Winchester, Illinois,

and an eight megawatt diesel electric generating

plant near Pittsfield,

Illinois.

The units on these plants range

from 18 to 35 years old, and are used on a peak basis or emergency

basis only (R. 27).

These facilities,

although having the capability

of firing on gas, would have to be oil fired because of the

gas short-

age (H. 28). Mr. Bringman estimated that the additional cost of

using these two diesel facilities for their total 11 watt capacity,

assuming their reliability (which he believed very questionable

(R.28)), would increase costs approximately 

per kilowatt hour (R,28)

Mr. Bringroan testified

that 

the principal impact on WIPCO

and its customers of obtaining power from some other source would

be the additional cost to WIPCO of approximately $1,250,000 per year

(H. 29).

He also stated that if WIPCO could purchase all the

power for 

its

customers rather than continuing to generate 

it,

the Pearl facility would be closed down. Closure would render

the facility’s 21 employees unemployed, resulting in a payroll

loss to 

the

community of nearly $250,000 CR. 29).. If the Pearl

facility were closed down, WIPCO would also be unable to pay its

debt obligations on it to REA, an amount of $280.000 per year

(R. 30)

The environmental consequences of the Pearl facility appear

minimal. The facility is located in a sparcely populated area

with no towns in excess of 500 people within a 10 mile radius

(Petitioner’s Exhibit 0). Mr. Bringman testified that he knew of

no other particulate emission sources in the area except

automobiles, agricultural operations, and field and trash fires (R.33).

He also had received no complaints regarding the Pearl facility (R.66).

Ambient air quality in the vicinity of the Pearl facility is

well within federal ambient air quality standards CR. 79-80,

Petitioner’s Exhibit G). The Petitioner’s consulting engineer

stated that the same is true for SO2 concentrations in the area of

the Pearl facility CR. 81). However, the ambient air quality

levels for particulates and 302 were calculated by WIPCO on the

basis of contribution of those contaminants solely by the Pearl

facility and did not consider any other emission sources CR. 81).

Balancing the hardships to WIPCO and its customers, the

minimal environmental impact of the Pearl facility, and WIPCO’s

diligence in pursuing a solution to its problems, we believe that

WIPCO 

is entitled to a variance from 2-2.53 of the Rules and

Regulations Governing the Control of Air Pollution. The only

issue remaining is the length of time needed by WIPCO to bring the

Pearl facility into compliance. WIPCO requested a variance until

Nay

30, 1975, yet its own Exhibit L indicates WIPCO expects the

scrubber to be operational by July, 1974. WIPCO’s witnesses

testified that the project could be complete by the end of 1974

(R. 41, 51, 105). The Agency recommended that a variance be granted

for

one

year subject to extension to April, 1974, stating that the

Petitioner can install the necessary control equipment by that date.

Since the Board is restricted by law to granting variances not to

exceed one year, WIPCO would have to seek extension of whatever

variance this Board grants. The evidence on the length of time

necessary to install the equipment is conflicting, but does

indicate that the equipment should be operational well before May

30, 1975. We feel that July 31, 1974 should be considered a dead-

line, and that WIPCO should continue to expedite the installation

of the control equipment. In order to keep apprised of the

progress that WIPCO will be making, we will require progress reports~

regarding completion of its control program.

This opinion constitutes the findings of fact and conclusions

of law of the Board.

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IT IS THE ORDER of the Pollution Control Board:

1. WIPCO’s petition for variance from Rule 2-2.53 of the

Rules and Regulations Governing the Control of Air

Pollution as respects its Pearl facility is granted to

January 30, 1974, pending installation of abatement equipment

to bring its operation into compliance with the relevant

air regulations by July 31, 1974.

2. The variance granted in paragraph 1 above is subject

to the following conditions:

(a) WIPCO shall submit quarterly reports to the Agency

indicating its progress towards completion of its control

program, said progress reports to begin not more than 30

days from the date of this Order;

(b) WIPCO shall continue to blend fuels to minimize

emissions from the Pearl facility, and shall include in its

quarterly reports the types of fuel 

used and the percentages

of each;

Cc) WIPCO shall post, within 30 days from the date of

this Order, a performance bond with the Agency in a form

acceptable to the Agency, in the amount of $250,000 to

guarantee installation of the abatement equipment by July 31,

1974. Provision shall also be made for the forfeiture of

$10,000 to the State of Illinois in the event WIPCO is not

in compliance with the relevant regulations with respect to

particulate emissions by.said date. Bond shall be filed

with the Illinois Environmental Protection Agency, Fiscal

Services Division,2200 Churchill Drive, Springfield, Illi-

nois 62706.

Cd) This variance may be extended upon the filing of a

petition and demonstration by petitioner that it is pursuing

its abatement program pursuant to this Order.

I, Christan Moffett, Clerk of the Illinois Pollution Control Board,

certify that the above Opinion and Order was adopted on the ~

day of January, 1973, by a vote of 

to

o

QLJ~~ _

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