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    BLUE SKY ENVIRONMENTAL LLC
    July 1, 2008
    Mr. John Therriault, Assistant Clerk
    lllinois Pollution Control Board
    State
    of lllinois Center
    100 West Randolph, Suite 11-500
    Chicago, IL 60601
    Subject:
    R2007-19 (Rulemaking - Air)
    Section
    27 Proposed Rules for Nitrogen Oxide (NOJ Emissions from Stationary
    Reciprocating Internal Combustion Engines and Turbines: Amendments to
    3S ILL.
    Adm. Code Section 201.146
    and Part 217
    Dear Mr. Therriault:
    Please accept these comments regarding Section 27 Proposed Rules for Nitrogen Oxide
    (NOx)
    Emissions from Stationary Reciprocating Internal Combustion Engines and Turbines:
    Amendments to 35 ILL. Adm. Code Section 201.146 and Part 217.
    It
    is understood that the
    deadline for filing comments regarding this proposed rule via R2007-019 has not yet been set but
    comments can presently be submitted.
    It
    is recommended that the definition of emergency or standby unit in Section 211.1920 be
    amended to include the operation during PJM's Emergency Load Response Program ("ELRP").
    The ELRP exists in order to prevent brownouts and blackouts. Numerous states now allow
    emergency engines to participate during such times (as opposed to waiting for a blackout),
    principally because studies prove that
    it is better to prevent a blackout by using a subset of
    emergency generators for a short period of time as opposed to losing the grid, which would mean
    all emergency generators in the state operating for many hours or possibly days. Generators
    operating in the ELRP will not be synchronized with the grid. The engines will simply be turned
    on when PJM declares an emergency under the PJM Program, thereby lessening the need for more
    power on the grid.
    The ELRP is activated according to the procedures in the
    PIM Manual 13 Emergency Operations
    for a PJM Declared Emergency. A "PJM Declared Emergency" means a condition that exists
    where the PJM Interconnection LLC notifies electric distributors than an emergency exists or may
    occur and it is necessary to implement the procedures in the PJM Manual
    13 Emergency
    Operations. The ELRP has rarely been declared - it is truly reserved for emergency situations.
    105 Chestnut Street - Suite 37 - Needham, MA - 02492
    Telephone 781-453-1150 - Cell 617-834-8408
    -Fax 781-453-1142
    Electronic Filing - Received, Clerk's Office, July 1, 2008
    * * * * * PC #5 * * * * *
    Mr. John Therriault
    Dlinois Pollution Control Board
    July 1,2008
    Page 2
    This declaration should not be confused with other PlM programs that are enacted for economic
    reasons (e.g., economic demand response or "peak shaving"). In the past five years, the ELRP has
    only been called five times for a total
    of 20 hours. A summary of the ELRP Event Hours is as
    follows:
    Year
    Events
    Duration (Hours)
    2003
    0
    0
    2004
    0
    0
    2005
    July 27
    4
    August 4
    3
    2006
    August 2
    4
    August 3
    5
    2007
    August 8
    4
    Section 211.1920(a)
    of the lllinois air regulations (amended at 31 DI. Reg. 14271, effective
    September 25, 2007) defines "emergency
    or standby unit" as a stationary gas turbine or a
    stationary reciprocating combustion engine that
    Supplies power for the source at which it is located but operates only when the normal
    supply of power has been rendered unavailable by circumstances beyond the control of the
    owner or operator
    of the source and only as necessary to assure the availability of the
    engine or turbine.
    I interpret this definition to mean that emergency engines should only be operated after "lights
    out." The PJM ELRP is the last panic button that can be pushed before voltage reductions and
    brownoutslblackouts. Therefore, engines participating in the ELRP would be operated
    just before
    "lights out." I recommend that the following be added to Section 211.1920
    An engine that operates during an emergency condition according to the procedures in the
    PlM Emergency Operations Manual for a PJM Declared Emergency. A PJM Declared
    Emergency means a condition that exists where the PJM Interconnection, LLC, or its
    successor, notifies electric distributors that an emergency exists
    or may occur and it is
    necessary to implement the procedures in the PJM Manual
    13 Emergency Operations, as
    revised.
    Operation
    of emergency engines in the ELRP has been discussed with IEP
    A.
    In response to a
    letter to Mr. Ray Pilapil, the IEPA Compliance Manager, Mr. Charles Zeal verbally responded
    105
    Chestnut Street - Suite 37 - Needham, MA - 02492
    Telephone 781-453-1150 - Cell 617-834-8408 -Fax 781-453-1142
    Electronic Filing - Received, Clerk's Office, July 1, 2008
    * * * * * PC #5 * * * * *
    Mr. John Therriault
    Dlinois Pollution Control Board
    July 1,2008
    Page 3
    that emergency engines could operate in the ELRP. It is requested that this be formalized
    in
    the
    regulations with the above proposed change
    1
    •
    If
    you have any questions or require additional information, please do not hesitate to contact me at
    617-834-8408.
    Sincerely,
    Blue Sky Environmental LLC
    Don C. DiCristofaro, CCM
    President
    I
    The Maryland Department of the Environment is currently proposing a similar change to its regulations in COMAR
    26.11.09 Relating to NOx Emissions for Fuel Burning Equipment and Emergency Generators via a stakeholder
    process. The regulation has not yet been formally proposed.
    105 Chestnut Street - Suite 37 - Needham, MA - 02492
    Telephone 781-453-1150 - Cell 617-834-8408
    -Fax 781-453-1142
    Electronic Filing - Received, Clerk's Office, July 1, 2008
    * * * * * PC #5 * * * * *

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