Science
By KRISTINE SUNDBERG

Reduced S0₂ levels may permit more coal to be burned

ILLINOIS' sulfur dioxide (SO₂) emission standards, it has been charged, are too stringent and have discouraged industrial growth in the state. The fact is, however, that the federal emission standards adopted by Illinois for large industries have also been adopted by surrounding states. And it now appears that Illinois may actually be able to relax standards in areas which have consistently maintained SO₂ levels within federal limits. Currently, the Illinois Environmental Protection Agency (IEPA) is studying the possible relaxation of standards permitted under the Prevention of Significant Deterioration (PSD) Program.

To understand the PSD Program, one must go back to the federal Clean Air Act of 1970 in which Congress established the National Ambient Air Quality Standards (NAAQS). The Clean Air Act is the "granddaddy" of air quality control and was the first effective step taken nationally to protect citizen health, property and vegetation from the effects of serious air pollution. The 1970 amendments to the Clean Air Act also put teeth in the air quality control standards by authorizing the U.S. Environmental Protection Agency (USEPA) to establish emission limits for large stationary sources of pollution built after August 1971. These standards primarily affect large industry and utilities with coal-fired boilers. Emission limits for those sources were intended to insure that the discharge of pollutants such as SO₂ will not cause a violation of the NAAQS. The Clean Air Act, as amended in 1970, also required each state to develop and submit for USEPA approval emission standards at least as stringent as the federal New Source Performance Standards. Illinois and surrounding states adopted the federal SO₂ standards rather than develop more stringent ones. In 1977 when the Clean Air Act was amended to make emission standards even more rigorous, the states were again required to adopt standards at least as stringent. Once more, Illinois and all surrounding states adopted the federal standards. With such uniformity, it seems clear that "Illinois [SO₂] emission rules are not the primary reason for Caterpillar, for example, leaving the state," according to Jim Maloney of the IEPA.

Should a state lessen any air quality or emission standard below the limits set by NAAQS or USEPA, the federal standards would automatically preempt the relaxed state standards. This is exactly what happened to Ohio. The state didn't match standards acceptable to the USEPA; consequently the federal standards prevailed. This instance, Maloney explained, was "in effect, a nationalization" of the Ohio air quality program. When given the regulatory authority, however, Illinois has demonstrated a willingness to relax SO₂ standards if there will be no violation of the mandatory NAAQS.

One area where the states are free to set standards is for existing industry (construction begun before August 17, 1971) and industry with small coal-fired boilers. At present, Illinois allows existing sources to set their own SO₂ emission limits in all parts of the state except the Chicago, Peoria and East St. Louis areas, where the state sets the limits. After receiving complaints from industry that the SO₂ standards were too stringent in those state-regulated metropolitan areas, the Illinois General Assembly required the IEPA (P.A. 81-1023) to study the possibility of relaxing the standards. That study is not complete, but the possibility of relaxing SO₂ standards in those areas is slight. An air quality analysis done in these metropolitan areas in late 1978 and early 1979 "indicate[d] there was marginal compliance with air quality standards [NAAQS]," according to Maloney. If present tests have similar results, there will probably be very little room to relax the Illinois emission standards for small and existing coal-fired generating facilities in those three metropolitan areas.

A survey of Illinois and the surrounding states shows a wide range of SO₂ emission standards for existing and small coal-fired boilers. Except for Kentucky, Illinois SO₂ standards for both pre-1971 and small generating facilities are more stringent than any of the other surveyed slates. However, it is difficult to make a comparison of state emission standards since some states may have more air quality problems than others.

A new realm of state regulatory authority was granted to Illinois in February. The IEPA was the first state agency in the USEPA Region V area to be granted the delegation of authority of the Prevention of Significant Deterioration (PSD) Program. The policy of this new authority is to encourage economic development in the state by relaxing air quality standards in the clean air areas and still protect those areas from excessive increases in pollution. Since most of Illinois has clean air conditions in respect to SO₂, the IEPA could relax air quality standards in a significant number of areas under this new authority. When additional pollution can be tolerated as a result of relaxed standards, there can also be an expected growth of industry in that area.

Statewide SO2 pollution levels have decreased dramatically since emission control standards were established in 1970

The first regulatory stipulation under PSD is that only the areas with SO₂ pollution levels less than the NAAQS (attainment areas) can be considered a PSD area. Since nonattainment areas already exceed the NAAQS, they cannot be considered for any additional pollution increases under PSD.

The PSD program sets up a three-class system with each class allowing a predetermined quantity of pollution increase in attainment areas. A Class I PSD area would allow the least amount of additional SO₂ pollution (annual mean increase of 2 micrograms/cubic meter), while Class II allows substantially more (annual mean increase of 20 micrograms/cubic meter, and Class III allows the greatest amount (annual mean increase of 40 micrograms/cubic meter). The air quality in any of the three classifications is never allowed to exceed the established limit of the NAAQS. Most of the attainment or clean air areas in the

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Science
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nation are automatically given PSD designation as Class II by USEPA regulation. Except for the Peoria area where SO₂ levels violate NAAQS, all of Illinois is designated as Class II.

The 1977 ammendments to the Clean Air Act allow redesignation of Class II areas after the delegation of PSD authority has been granted to the state. Most attention will be given to re-classifying them to Class III which could potentially double the SO₂ pollution allowable in these areas. According to John McEwen of the IEPA, a redesignation from Class II to Class III would "allow for economic growth" by allowing new industry to locate in the area, would possibly encourage the burning of Illinois coal in new boilers and would still insure a healthy environment.

There may be many areas in the state that would qualify for a redesignation to a Class III. Statewide SO₂ pollution trends have decreased dramatically since the first emission control standards of 1970; SO₂ pollution levels have dropped approximately 36 percent from 1970 through 1978. Therefore, the IEPA expects to find many Class II areas with SO₂ levels low enough to allow a change to Class III.

The IEPA has already begun its first redesignation study in Madison, Monroe and St. Clair counties. This is part of the East St. Louis metropolitan area where SO₂ pollution is a problem, but redesignation can be considered in scattered areas as small as a township. A coalition of businesses and unions petitioned the governor to redesignate the qualifying areas in those counties to Class III. The coalition feels that redesignation would attract new industry to the area. The IEPA is presently testing air quality in the three counties to determine which townships have achieved attainment status. After this determination is made, a study similar to an environmental impact statement will be conducted in those attainment areas to assess the economic, health, social and energy effects of redesignation. The final impact analysis and Class III recommendations are expected to be completed by the end of June.

This column will report policy developments concerning science and technology in Illinois. Support for this column is provided in part by a National Science Foundation grant to the Illinois Legislative Council Science Unit, where Kristine Sundberg is a science intern.

22/June 1980/Illinois Issues