‘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