‘I
    Vice
    Pamela
    President
    F. Faggert
    and
    Chief
    Environmental Officer
    I
    D•mn•n®
    Dominion
    Resources Services, Inc.
    5000
    Dominion
    Boulevard,
    Glen Allen, VA
    23060
    Phone:
    804-273-3467
    December 15,2008
    DEC
    222008
    Mr. John
    Therriault
    ILLItq
    018
    Assistant Clerk
    T
    ‘ltrol
    Clerk’s
    Office
    Illinois
    Pollution Control
    Board
    100W.
    Randolph
    St., Suite 11-500
    Chicago, IL 60601
    Oi
    -J
    Re:
    RQ?f - Illinois
    Register,
    October 31, 2008 - Proposed
    Rule under Title
    35, Part 217,
    Nitrogen
    Oxides Emissions,
    Subpart
    Q
    of the Illinois Pollution
    Control Board
    Regulations
    — Stationary
    Reciprocating Internal
    Combustion
    Engines and Turbines
    Dear Mr. Therriault:
    Dominion
    owns
    and operates electric
    generating facilities
    in
    eleven
    states, including the
    1200
    megawatt coal-fired
    Kincaid Generation
    LLC power
    plant, located in Kincaid,
    Illinois. Dominion
    also
    owns
    a 50%
    interest
    in
    the
    1400-megawatt
    natural gas-fired
    Elwood Energy,
    LLC
    combustion turbine
    plant, lbcated in
    Will
    County,
    Illinois.
    Dominion
    supports regulations
    designed
    to
    facilitate attainment of
    the National
    Ambient Air
    Quality Standards
    and is supportive
    of the proposed
    nitrogen oxides restrictions
    for reciprocating
    internal
    combustion
    engines and turbines
    located in ozone nonattainment
    areas
    in the Chicago
    and
    Metro
    East areas of Illinois.
    Dominion’s
    Elvood
    facility
    was
    permitted under
    PSD (Prevention
    of
    Significant
    Deterioration)
    Permit ID
    No. 197808AAG in
    February 1999, which
    was amended
    in 2000 under PSD
    Permit
    ID
    No.
    19703 5AAH. In addition
    to the PSD
    permits,
    Elwood is
    subject to the
    federal Acid Rain
    Program under 40 CFR
    Parts
    75
    and
    76, the illinois Title
    V
    Clean Air Act Permit
    Program
    (CAAPP),
    the federal
    New
    Source
    Performance
    Standards
    (NSPS)
    under
    40
    CFR
    Part 60,
    Subpart
    GG, the
    Illinois
    NO
    Trading Program
    under
    35 IAC Part 217,
    Subpart
    W
    and
    the Illinois
    ERMS
    (Emissions
    Reduction
    Market
    System) for
    VOM
    (Volatile
    Organic
    Matter) emissions
    under
    35
    IAC
    Part 205.
    Under the PSD permits,
    the Elwood turbines
    are subject
    to year-round
    NO
    emissions limitations
    that are more
    stringent
    than
    the limits in the proposed
    Subpart
    Q
    regulations for
    Stationary
    Reciprocating
    Internal
    Combustion Engines
    and Turbines.
    The
    Subpart
    Q
    proposal seeks
    to
    limit
    N
    emissions
    from gas-fired turbines
    to 42
    ppm
    (parts
    per million).
    The Elwood
    permits limit
    NO
    emissions to 15 ppm
    for turbines 1 — 4
    and
    9
    ppm for turbines
    5
    — 9.
    The federal
    and state permit programs all have separate and
    distinct monitoring, reporting and
    recordkeeping requirements.
    The PSD and NSPS programs
    also require extensive testing of the
    turbines. The Acid Rain
    Program and the
    NO
    Trading Program
    require continuous emissions
    monitoring systems
    (CEMS) and periodic quality assurance
    procedures. Each of these programs
    requires
    emissions, deviation or allowance reports with
    the one or more of the following
    frequencies:
    annually, semi-annually, seasonally,
    quarterly, monthly or
    “promptly”.
    The proposed Subpart
    Q
    regulations would
    require additional monitoring,
    reporting and
    recordkeeping requirements, although
    sources with operational CEMS (like
    the
    Elwood
    facility)
    fully satisfy many of these requirements.
    Nevertheless, there are additional recordkeeping
    requirements associated with the proposed
    Maintenance Plan under §217.388(d) of the proposal.
    There are also requirements to maintain records of hours of
    operation, daily fuel use, monitoring
    deviations,
    a plan
    for inspection
    and
    maintenance,
    a log
    of all
    inspections and maintenance, and
    identification of any periods during which
    data were not
    collected,
    including the reasons and
    the
    corrective
    actions
    taken
    under proposed §217.396(a)).
    Given the extremely low
    NO
    emissions limitations already in
    effect at
    Elwood,
    coupled with the
    current level of monitoring, reporting and recordkeeping required
    by the other air quality
    programs
    to
    which Elwood is subject, there is no practical reason or environmental benefit
    to
    imposing yet another program on
    a
    facility like
    Elwood.
    Dominion
    urges the Illinois Pollution
    Control Board to adopt
    provisions
    as part of this rulemaking that specifically exclude facilities
    that
    are already well-controlled and adequately monitored, like Elwood, from additional
    regulation.
    Thank you for
    your consideration of these issues. If you have any questions, please contact Bob
    Asplund at
    (804)273-3012.
    Respectfully,
    ()
    Pamela F. Faggert

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