NOTICE of Petition by Dynegy for an Adjusted Standard (AS 2024-004) before the Illinois Pollution Control Board

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NOTICE of Petition by Dynegy for an Adjusted Standard (AS 2024-004) before the Illinois Pollution Control Board

Dynegy Midwest Generation, LLC, Illinois Power Generating Company, and Kincaid Generation, LLC (collectively, “Dynegy”) filed a petition for an adjusted standard with the Illinois Pollution Control Board on August 14, 2023 (docket number AS 2024-004). Dynegy operates the following coal-fired power plants: Baldwin Energy Complex located at 10901 Baldwin Road, Baldwin, Randolph County, Illinois 62217; Kincaid Power Station, located on Route 104, approximately four miles west of Kincaid, Christian County, Illinois 62540; and Newton Power Station, located at 6725 North 500th Street, Newton, Jasper County, Illinois 62448.  Dynegy seeks an adjusted standard from opacity standards applicable to emissions from Dynegy’s coal-fired boilers during periods of startup, malfunction, and breakdown (“SMB”) (as codified in 35 Ill. Admin. Code §§ 212.122(a) and 212.123(a), except as allowed by §§ 212.122(b), 212.123(b), or 212.124, and with the requirement to comply with those standards during periods of SMB as governed by § 201.149). For its proposed adjusted standard, Dynegy proposes the following language apply:

  1. Pursuant to Section 28.1 of the Environmental Protection Act, the Board grants Dynegy an adjusted standard from the applicable opacity requirements (set forth at 35 Ill. Admin. Code Part 212, Subpart B, and Part 201, Subparts C and I (as amended July 25, 2023)) for coal-fired boilers 1 and 2 at the Baldwin Energy Complex, coal-fired boilers 1 and 2 at the Kincaid Power Station, and coal-fired boiler 1 at the Newton Power Station (collectively, the “Affected Units”).  
  1. The Adjusted Standard.

During times of startup of an Affected Unit, or of malfunction or breakdown of an Affected Unit or the air pollution control equipment serving the Affected Unit, when average opacity exceeds 20 percent (for Newton Affected Units) or 30 percent (for Baldwin or Kincaid Affected Units) for a six-minute period compliance with the applicable 20 or 30 percent opacity standard (as applicable pursuant to 35 Ill. Admin. Code § 201.149 and either § 212.122(a) (except as allowed by § 212.122(b) or 212.124) or § 212.123(a) (except as allowed by § 212.123(b) or 212.124)), may alternatively be demonstrated for that six-minute period as follows. 

  1. Alternative Averaging Period.

Compliance for that six-minute period may be determined based on a three-hour average of opacity, utilizing opacity readings for those six minutes and the immediately preceding 174 minutes.

  1. Recordkeeping and Reporting.
    1. Any person relying on the Alternative Averaging Period in Section 2.a) of this Adjusted Standard shall maintain records of such average opacity calculations and shall report such calculations to Illinois EPA as part of the next quarterly excess emissions report for the source.
    2. For periods of startup, such report shall include:
      1. The date, time, and duration of the startup.
      2. A description of the startup.
      3. The reason(s) for the startup.
      4. An indication of whether or not written startup procedures were followed. If any written startup procedures were not followed, the report shall include any departures from established procedures and any reason the procedures could not be followed.
      5. A description of any actions taken to minimize the magnitude or duration of opacity that requires utilization of the Alternative Averaging Period in Section 2.a) of this Adjusted Standard. 
      6. An explanation whether similar incidents could be prevented in the future and, if so, a description of the actions taken or to be taken to prevent similar incidents in the future.
      7. Confirmation of fulfillment of the requirements of Section 2.c) of this Adjusted Standard. 
    3. For periods of malfunction and breakdown, such report shall include:
      1. The date, time, duration (i.e., the length of time during which operation continued with opacity in excess of 20 or 30 percent, as applicable, on a six-minute average basis) until corrective actions were taken or the boiler was taken out of service.
      2. A description of the incident.
      3. Any corrective actions used to reduce the magnitude or duration of opacity that requires utilization of the Alternative Averaging Period in Section 2.a) of this Adjusted Standard.
      4. Confirmation of fulfillment of the requirements of Sections 2.b)(iv) and 2.c) of this Adjusted Standard.
    4. Any person who causes or allows the continued operation of a coal-fired boiler during a malfunction or breakdown of the coal-fired boiler or related air pollution control equipment when such continued operation would require reliance on the Alternative Averaging Period in Section 2.a) of this Adjusted Standard to demonstrate compliance with 35 Ill. Admin. Code Part 201 and 212 shall immediately report such incident to the Agency by telephone, facsimile, electronic mail, or such other method as constitutes the fastest available alternative, except if otherwise provided in the operating permit. Thereafter, any such person shall comply with all reasonable directives of the Agency with respect to the incident.
  2. Work Practices

Any person relying on the Alternative Averaging Period in Section 2.a) of this Adjusted Standard must comply with the following Work Practices.

  1. Operate the coal-fired boiler and related air pollution control equipment in a manner consistent with good engineering practice for minimizing opacity during such startup, malfunction or breakdown.
  2. Use good engineering practices and best efforts to minimize the frequency and duration of operation in startup, malfunction and breakdown.
  3. The Adjusted Standard is effective as of the date of this order.

Any person may cause a public hearing to be held in the above-described adjusted standard proceeding by filing a hearing request with the Illinois Pollution Control Board within 21 days after the date of the publication of this notice. The hearing request should indicate the docket number for the adjusted standard proceeding, as found in this notice. The hearing request must be mailed to the Clerk, Illinois Pollution Control Board, 100 W. Randolph Street, Suite 11-500, Chicago, Illinois 60601, or filed electronically through COOL, located on the Board’s website (www.ipcb.state.il.us).