ML19331B283
| ML19331B283 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 09/15/1977 |
| From: | Pribila L DOW CHEMICAL CO. |
| To: | |
| References | |
| NUDOCS 8007280883 | |
| Download: ML19331B283 (54) | |
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gd fiUCLEAR REGULATORY CCMMISSION
- y M [J Before the Atomic Safety and Licensing Board y 7
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CONSUMERS POWER CCMPANY ) Docket Nos. 50-329
) 50-330 (Midland Plant, Units 1 and. 2))
SUPPLEMENTAL RES'ONSES TO INTERRCGATORIES The Dow Chemical Company ("Dow") submits the folicwing supple-mental answers to Interrogatory 8 of Intervenors other than Dow and Interrogatory 1(k)oftheNRCStaff. Since these Interrogatories request similar information, the answers to both have been combined in the statement set forth below.
- 8. State in detail the present status of your current facili-ties for generating electricity or steam in light of each of the follow-ing:
(a) regulation, discussion, citation, demands or requests s by or from the United States Environmental Protection Agency regarding State or Federal air pollution requirements in Midland, Michigan. (b) regulation, discussion, citation, demands or requests i by or from the Michigan Air Pollution Authority regarding State or Federal air pollution requirements in Midland, Michigan. ) l l
, t 8007280 g t] THIS DOCUMENT CONTAINS POOR QUAUTY PAGES
. . ,- 2 Include within your answer to this interr.ogatory, separately for Federal and State regulatory authorities, whether you presently believe that each or both of them would permit you to operate your present generation facilities past 1980 and if so, under what circumstances, explaining in detail any costs or capital changes in connection with such circumstances.
- 1. With reference to Dow's " Presentation to Mich.igan Air Pollution Control Commission" of January 18, 1977:
- k. Please relate the substance of any meetings with the MAPCC and/or its Staff and/or the Environmental Protection Agency occurring after January 21, 1977 to the NRC Staff on a continuing basis.
Answer Attached hereto as Exhibit A are various ccrrespondence between Dow, the Staff of the Michigan Air Pollution Control Commission and the United States Environmental Protection Agency, relating to the Stip'ulation for Entry of Consent Order and the Final Order entered in conjunction therewith which was previously provided to you in Ocw's Supplemental Response to Interrogatories dated July 29, 1977., As a result of Dow's preposed conversion from coal to oil as a fuel as required by said Stipulation and Final Order, there have been various letters. exchanged between Dow and the Federal Energy Administra-tion (FEA). These letters are attached hereto as ' Exhibit B. l
.,' - . e5 3 Following this correspondence, a meeting was arranged by FEA in Washington, D.C. on September 13, 1977. Attached hereto as Exhibit C is a list of attendees at said meeting. Finally attached hereto as Exhibit 0 is the Dow presentation at said meeting.
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,N $6 '/6 4 /i d o L. W. Pribila, Attorney The Dow Chemical Company Legal. Department L. W. Pribila, being duly sworn, deposes and says that the foregoing Supplemental Responses to Interrogatories are true to the best of his knowledge and belief.
7 du, j >/?LluJ o - .. L. W. Pribila, Attorney The Dow Chemical Company Legal Department STATE OF MICHIGAN ) ss. COUNTY OF MIDLAND ) Suoscribed and sworn to before me, a Notary Public, this 15th day of September, 1977. s is W 11n 2 ConlTie X.' Miller ' Notary Public, Midland County, Michigan My Ccmmission Expires: August 16, 1981
RELATED COR."J.S?O CCC2
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UNITED STATES OF AMERICA '3 I1 l SEp NUCLEAR REGULATORY COMMISSION y . , , . g U 1977 13 9 s,d,DP J s & In the Matter of _ CONSUMERS POWER COMPANY Docket Nos. 50-329
) 50-330 (Midland Plant, Units 1 and 2) )
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CERTIFICATE OF SERVICE I hereby certify that copies of the attached " Supplemental Responses to Interrogatories" dated Septeinber 15, 1977 were served upon the individuals whose names appear on the attached Service List by deposit in the United States mail, postage prepaid and properly addressed, on the 15th day of Septemoer,1977. Connie K. Miller The Dcw Chemical Ccmpany Legal Department 47 Building Midland, Michigan 48640 1 September 15, 1977
Attachment:
Service List 9
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. Frederi J. Coufal, Esq. , Chairman R. Rex Renfrow, III, Esq.
Atomic Safety and Licensing Board David J. Rosso, Esq. U.S. fluclear Regulatory Commission Isham, Lincoln & Beale Washington, D.C. 20555 One First National Plaza Suite 4200 Dr. J. Venn Leeds, Jr. Chicago, IL Atomic' Safety and Licensing Board 10807 Atwell Atomic Safety and Licensing Board Houston, Texas 77096- Panel U.S. fluclear Regulatory Commission Dr. Emmeth A. Luebke Washington, D.C. 20555 Atomic Safety and Licensing Board U.S. iluclear Regulatory Commission Atcmic Safety and Licensing Appeal Washington, D.C. 20555 : Panel
, U.S. Nuclear Regulatory Ccamission Myron M. Cherry, Esq. -
Washington, D.C. 20555 1 IBM Plaza Chicago, IL 60511 ' Docketing and Service Section Judd L. Bacon, Esq. Office of the Secretary Consumers Power Company U.S. Nuclear Regulatory Ccmmission Washington, D.C. 20555 212 West Michigun Avenue Jackson, MI 49201 Ms. Mary Sinclair 5711 Summerset Street Midland, MI 48540 Harold F. Reis, Esq. Robert Lowenstein, Esq. - Lo.;enstain, Newman, Reis & Axelrad 1025 Connecticut Avenue Washington, D.C. 20036 . Mr. Steve Gadler 2120 Carter Avenue St. Paul, Minnesota 55108 Norton Hatlie, Esq.
' Attorney-at-Law P.O. Box 103 5 Navarre, Minnesota 55392 Richard K. Hoefling, Esq.
Nuclear Regulctory Cammission Washington, D.C. 20555 -
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, 'RE: Dow Cheaicci Company -
Department of Natural Resources G.' ' Consent Order APC No. 10-1977 :
Dear l'r. Jager:
Thank you for the transmittal of the July 21, i977, Consent Order AFC No. ' 10-1977. The United States Environmental Protecticrr Agency (U.S. EPA) policy regarding State compliance schedules which provide for fina! . cc pliance with emission limitations at some date beyond an applicable , .
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attainment date, is that such schedules must conform -to the requirements . . of the Clean Air Act and 40 CFR Part 51 and be eccompanied by a contro! s-et. de. m '- et ien . !! su:h ecurent demc st ates i;mt th c .. ni ta.nce , senesuie wiii not interfere with tne attainment cc maintenance of national a6ient air quality standards, the schedule' will be approved as a revision to tno 3 rate implementation Plen, see 4'l FR 18510 G4ay 15, 1975), Train
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- v. r!I';~ et el', 421 U.S. 60 ( 1975) . The typical strategy demonstration . ..V contains The latest available comprehensive data regarding air c:ualitif,- -
emissions and background levels unich influence that air quality, the - regulations which control the emissions, and the procedures which ensure ' " that the national standards will be maintained in the future. . - W Please note that the 14I'chigan implementation Plan currently sets out a.. compliance schedule specifically for Dow Chemical Company at 40 CFR Section ' ~ - 52.!!75(e), which requires final compliance with emission limitations by '.; April 1, 1975. If the State of f-lichigan wishes to grant Dow Chemical - - - '
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Company a Consent Order which delays compliance beyond this final date, ' . 'I' . then a control strategy demonstration must be submitted. . Until such tin'a .?f es the Mew Consent Order is approved by U.S. EPA as a ' revision to the - "" State Implementation Plan, the source is subject to Federal enforcement ' action and citizen suit under the current implementation Plan. . '
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Due to the utilization by the subject source of a supplemental contro! '
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system, .1t shoutd be spectfica!Iy noted thal, in order to obtain U.S. EPA -
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3 . t. AUG 101977 2 . approval, any Consent Order must conform to the U.S. EPts Tall Stack-
- Supple = ental Control System Policy set out at 41 FR 7450 (February 18, 1975) and the Sixth Circuit's decision in Bio Riversi et ci v. EPA, 523 F. 2d 15 (CAG, 1975).
This of fice has received a copy of a letter frca l': . Robert !. Han fling, - Deputy Assistant Ad.:Inistrator of the Federal Energy Administration to Mr. Zoltan Merszel, President of the Dow Chemical Company, expressing - concern that the proposed conversion of coal fired bo!!ers to oil utili- , zation is contrary to National energy policy. _ Has this recommendati~on of - the. Federal Energy Administration that "all potential alternatives" to . . .
- conversion cut be considered in your Consent Order?af fected the conve. sion compliance strategy set Consistent with ths above, will you please supply this office with a controi. '
strategy deecastration for Michigan Consent Order APC Mo. 10-1977 in order that an . implementation Plan revision analysis can be.perforniad. If you have any . questions or desire additional information, please contact i.'r. Michael Smith of my staff.at (312) 353-2086. ' Sincarely yours, [ - e R. Alexander, Jr. -
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nichigan Division s. The Dow Chemical Company I g.C_ gj 77 fY i AUG 2 41977 4e Bu11 din 3
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Dear Mr. Henry:
c, / w t tr , I am enclosing for your information a copy of a letter which was recentiv received Trom Mr. George Alexander, Regional Administrator, U.S. EnvironInental Proteculcn Agency, concerning your company's program for abatement of air pollution a copy ofemissions my rsply. Trom your coal burning power plants and also enclosing I vnsh to call your attention to the two issues raised in Mr. Ale::ander's letter. . First, Mr. Alexander has required that a " control strategy demonstration" ccyst acccapany the compliance schedule. Ua have asked EPA to furnish us.
';n to an example or, a " typical strategy demonstratic," and intend to c :t
.c; cner i pecaage or, tne reque-tad infomtic1. In ord2:- tc de cals a sp.is7actory ar.d time'.y submittal, it is likely that s:.ne o,= the mat'e rial w i have to be prepared by Dow.
in{uh your starr, in the near future to discuss this. Staff of this agen The seccnd issue concerns the apparent opposition of the Federal Energy-Administration to the burning of additional oil in your boilers. It is ' requested that ycu submit to this office a positive assurance, including a brler or the company's legal arguments, that this oil will be available. i.'e ask that this information be submitted not later than November 1,1977. -
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Ue thisalso askat matter that anDow earlyseek date.an official reply from FEA on their position in 5 If you have any questier.s on these catters, please contact me at (517) 373-7573. -
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Very truly yours, , s
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LEJ :ma.h Lee E. Jaced Coief c.$ 3 Enclosures (2) Air Quality Divisica tai:Ti h 's .
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. nagional Administrator & . -
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Chicago, Illinois 60504 4 ut
Dear I;r. Alexander:
om . This is in reply to your letter dated August 10, 1977 and receiva'd in this office on August 17, 1977 concerning Consent Order, APC 110. 10-1977, , .' issued by tha flichigan Air Pollution Control Comaission to the Cow Chamical Company of fiidland iiichigan. In your letter you state that ' l this compliance program as c,ontained in that Ccasent Order can only be approved as an amendment to the flichigan State Implementation Plan and, - th:re?c.ca, the ccmliance sch; :12 r.m t t.c accnirplaia:"!.y a "cocb ol 1.,y. t2g ;!.u Ons bra ?.icll". Quoting further from your letter, "The typical strategy demonstration - contains the latest available comprehansive data regarding air quality, emissicas and background levels which influence that air quality, the regulations which control the emissicas, and the procedures which ensure ' , that the national standards will be maintained in the future." It - appears to me that the regional EPA office has all of the information , ! that is being requested, specifically the regional office receives regular , ! recorts from our air quality monitoring network and should by this time b2 in data. receipt of our most recent published Air Quality Data Report covering. 1976 Additionally, EPA regularly receives emissions data from ali . ! sources in the State of Ilichigan, including the Dow Chemical Company. - - EPA is,-of course, aware of our regulations and procedures which ensure
- that national standards will ba maintained in the future, since thes' .
i are tha same regulations and procedures that t.2re accepted by the EPA . i in their approval of tha flichigan State Implementation Plan. ' This office .is willing to prepare a reasonable package of information i
.partaining to the specific situat-ion in Midland; however, it is not '
clear to us frca your latter hcw extensive this package shculd be and .. that the format of such a submittal should be. Your letter refers to e C. 3.;.n .-
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August 22, 1977 - Pag: 2, - a " typical strategy demonstration" and it would be greatly appreciated if you could send- to this office'an example of a typical strategy demnstra-tion so tn, at no may have some guidance in tha preparation of our submittal. In ycIrr letter you note that the Supplementary Control Syste:a cust he - consistent with U.S. EPA tall stack policy. To the best of'our know - . ledge, the SCS program being implemented by Dow Chemical Company .s ' totally consistent enth that policy and is an interim program to protect ' ' air quality prior to full compliance with caission standards, which - ! according to tne Consent Order v;ill occur in 1980. ' Your letter also notes that the Federal Energy Mninistration has raised - quas,ulon as to whether the' proposed conversion of thase coal-fired boilers . ' to oil utilization is contrary to the national energy policy. The use of additional oil in lieu of coal at the Dow Chemical Company and the consis-tency or that action with the national enargy policy has been discussed ' batween the Co:maission and the Company. The Company legal repi csentativas have assured the Connalssion that there are no legal barriers to this ~ ancreased use or, all in their boilers. If EPA differs with. that lenal position, arguments. tnis agency would greatly appreciate receiv-ino those legaY ' If the Company is not legally entitled to use oil as will be required under this Consent Order, of course, we will ir.ediately renegotiate the terms of the Consent Order with the Co.npany. -
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e:cmcAn civisoN August 29, 1977- MotA*- ":CSCA" '88" Mr. Lee E. Jager, Chief Air Q M ity Divisica State of Michigan Depa&L..ent of Natural Rescurces' - Box 30028 Lansing, MI 48909
Dear Mr. Jager:
This letter is in response to your letter of A,ucust 22, 1977. With respect to the' U.S. Environmental Protection Agency's rcquest for a control strategy derecnstration, I have asked Mr. Jack Brown to be preparyl to provide your staff with whatever assistance is reg *ed in preparing a satisfactory and timely respcase. Since a significant . improvement in
- cuality in the Midland area has been ' achieved during the tire Dow has operated its version of a Supplemental Control System, -
conclusive data shculd be available to de:cnstrate to the EPA that the Federal system. arbient air.cuality standards can he ditained with this With respect to the U.S. Federal Energy AfL%tration's position en - fuel conversica fran ccal to oil, I am enclosing a copy of a letter frcm Mr. Paul Oreffice to Mr. IObert F. Hanfling in reply to the latter's letter of July 22, 1977 to Mr. Zoltan Merzei, President of The Dc1 Chemical Conpany. . As a result of Mr. Oreffica's letter, a meeting to discuss this matter has been scheduled with the EEA atits offices in Washington, D.C. on Septc=ber 13, 1977. It is ry understanding that representatives of the EPA and the State of Michigan will be ~ invited by the FFA to attend. At this meeting it is my ' intention to provide a with infor:ation regarding the cost and timing of alternatives to . fuel conversien in order to alleviate any concerns FFA cay have in this regard. bbreover, I uculd suggest deferring any decision on the assur- - ' ances pu recpested in your penultirate paragrach until after the a has had an opportunity to evaluate the infonration provided and to - clarify its positica. Please contact ne if I may be of any further assistance on this rntter. Sincerely, Y H, W. Eenry
- General Manager :
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MICHIGAN OMSiON September 15, 1977 wote.o. wcmcAs 4mo Mr. Fred Khedouri U.S. House of Representatives .'N. g:= 4 Longworth Butiding, Rocm 1021 ., g Washington, D.C. 20515 /[ q,# f Michael G. Smith, Esq. 8- o N11 7 -2 ' t_ .
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U.S. Environmental Protection Agency S N }O - Enforcement Division Region V g q qs* y 230 South Dearborn Street g r Chicaga, IL 60604 'c1 William J. Olmstead, Esq. Counsel for NRC U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. A. M. Vaitekunas Energy Resource Development Federal Energy Administration Federal Building 12th and Pennsylvania Room 6119 Washington, D.C. 20461 Gentlemen: , Enclosed as requested are copies of the presentations given by Messrs. Henry and Brown during our meeting in Washington, D.C. on September 13, 1977. Also enclosed is a copy of the Black and Veatch report which was discussed during said meeting. , Please make whatever distribution of this information within your organization as you deem appropriate. Very truly yours,
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L. W. Pribila Attorney. attachments C & #US l [h1 A A8 CPERATING UNIT OF THE OCW CNEMICAL CCMPANY I*%
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Dear Mr. Merszei:
I have recently learned of the circumstances involving - Dow Chemical with respect to compliance with the Clean Air Act at its South and West Side Power Plants in Mid-land, Michigan, and of Dou's plans to convert those coal burning facilities to oil. Conversion of large ; existing coal-fired plants to oil is of great concern during a period uhen this Nation is att5mpting to achieve energy self-sufficiency through greater coal utilization. As you Know g reater ccal utilizatica is a cornorstone of the Administration's Energy Plan. President Carter, for example, stated to the Nation in his address of April 18, 1977, with regard to the use cf coal in place of oil:
"We must conserve the fuels that are scarcest and make the most of those that are plent{ ful. >
We can' t continue to use oil and gas for 75 f percent of our consumption, as we do now, when j they cnly make up 7 percent of'our domestic h reserves. He neec to shift to plentiful coal, while taking care to protect the environment ..."
.FEA recommends that Dow consider all potential alterna-tives.to converting any of its Midland, Michigan, units -
from coal-to oil firing. We would welcome the opportun-ity to meet with you and the interested State and Federal environmental protection agencies to discuss this situa-tion. I el
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2 By copy of this letter I am informing relevant State and Federal environmental protection agencies of FEA's concerns relating to Dow's proposed coal-to-oil ~ conver-sions. Should you wish to pursue this matter, please
. feel free to contact me or Mr. Walter Romanek, Director, Office of Coal U~ilization, c (202)366-7941. -
Sincerely, i
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Deputy Assistant Administrator - Energy Resource Development cc : - George R. Alexander, Jr. Regional' Administrator
. EPA Region V ,
M. Allen Andersen i Regional Administrator FEA Region V Lee E. Jaeger Acting Executive Secretary Michigan Air Pollution Control Commission L e g 1 1 i
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<31'G-"v 70W CHEMICAL L 5.A. . g,yt.HEMR s August 5, 1977 R ~e C EI y g 9 m cw m na 2020 DOV,* CENTEit G 2 5 g.pctino. c.::c>ircan so Mr. Robert I. Hanfling Deputy Assistant Administrator t,;;cgfg,:3 mt,'E,,,
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Washington, D.C. 20451 Q,g'D . j- SL:2g7377)r%} im ...g..,s,,,,,,,
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Dear'Mr. Hanfling:
g # is Your. lette;r of July 22, 19.77, to Mr. Zoltan Merszei, . President . ~ of The Dow Chemical Company, has been received; and I am answering it on behalf of the Company.
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Let me assure you that we enthusiastically support the President's position that the Nation cust. increase its ' utilization of coal by shif ting away from oil and natural gas; and we, at Dow, are moving in this direction as rapidly' as we can at our Gulf Coast locations. However, our situation a.t our Midland location is uniquely different in that environ-mental laws are forcing us to switch from coal to oil. I have attached a document that doscribes the particular situation re fae: in iiidla.nd. In order to acquaint your office on a firsthand' basis with that situb tion, I asked Mr. H. W. Henry, General Managei of our Michiga.n Division, where the' plants referred to in your letter are located, to contact your office to determine if we can- arrange a meeting with 'the FEA. He has advised me that he has He talked contacted with Mr. you and others in your office for this purpose. Romanek. I i that conversation, Fred She~ap, Administrative Aide to Mr. Mr. She.:ap advised that he ' s;ould have Mr. Anthony Vaitekunas, the Direc tor of the Industrial Division for.; Coal Utilization, contact Mr. in order to make arrangemants for a meeting where we c, Henry ould fully describe to you our capabilities and restrictions. . We look forward to getting together with you because we strongly . believe in solvingthat the increased coal utilization Country's energy problems.is a. significant step Further, we.believe we can demenstrate that burning oil on a 100% basis provides only marginal benefits in the air quality.here 11 Midland. We wish to.,ccoperato with you in any way possible. ~ I Sin /corelv l ll.,
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[.'. . [ .:,. sFDF~sUTILI."ATION PLANS *
,- _ The Dow Chemical Conpany has cogeneration facilities for the production-of power and process steam at its manufacturing c.omplex in MidTand, Michigan. These facilities are antiquated'and cannot be made to operate with productive reliability after 1984 at the latest. It was .
originally planned to retire these facilities in the mid-l'g70's dhen Co'nsumers Power Company was scheduled to b,egin supplying Dow with power and process ' steam .frcm a: nuclear plant it. is 'construedpg a't a lac' ation - adjacent to Dow's manufacturipg complex.. Repeated delays in' construc-tion of the nuclear plant have. caused the estimated date:thap consumer will supply Dcw viith process steam to slip'to March 1982. Dow's present plans are .to retire its cogeneration facilities at that title, but in any
.r:ent even if there is further delay in the nuclear plan't by 1984 at the .
latest.- , E- ' Dow presently burns coal, oil and natural, gas' in 1,ks existipg . co;;an$ation facilities. . Al though the operating econcmics.s,i.gnificantly . favor. the use of coal, .Dow cannot use this fuel exclusiv'ely because its pollution control e'quipment is inadequate to meet the' state emission ' regulations and thds on' occasion the federal ambienf. air / quality ' standards . could be exceedad in the Midland area. Dow recpgnize'd'the potential for air pollution problems and yet.it pas anxinus to maximize the use of i ' coal as .ars ene.rgy source. These factors prcmpted Dev; to , agree to a '
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Consent Order with 'the'lliciigan l Ai.r Pollution Control. Corra.ission CMPCC) '.. on May 17,1974. .This Order provided that Dou would. operate a Supple-mentary Control' System (SCS) which would enable it to. meet the federal
. ambient air quality standards for sulfur dioxide.' ' CS S are systecs which '
limit the rate of pollutant emissions duripg periods when meteorologi'ai
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. conditions are conducive to ground level concentrations in excess of federal ambi'ent, air c;uality standards. In other words, when there is a potential for a' violation,of the federal ambient air quality's.tandards for sulfur dioxide, Dow burns low-sulfur oil or natural gas in its boilers; otherwise, Dow burns coal.
The 1974. Consent Order further provided that sollong as the federal ambient air quality. standards for sulfur dioxide were met, and they haite been' met s-ince the incept. ion of . . SCS on July 1,1975, Dow was g' ranted a variance until July l,1980 from
, Michigan's emission regulations for air po71utants. .
. At the time tne"1974 Order wis' negotiated, the parties antici- '
l pated Consumers' nuclear plant would be operati,ng and the Dow $ facilities retired before July l,1980. When it became apparent that .the naclear plant would not. be available by that time, the (4APCC, through its staff, l pressed Dow to co=iit itself as to how it.would meet the Michigan emission ~ regulations upon the expiration or its varianc2 c.a. July 1,1930 until
!-: arch 1982 when prccess steam from the nuclear plant would be available. -
i \ As a result, on July:21, 1977
. a new Consent Order.between Dow and the . '
I i iMPCC became effective. This consent Order provided that Dow would con-tinue to operate an SCS until. July 1, .1980 after which time 'it uou i eliminate coal as.a fuel in its power plants. D,uring the negotiations L l leading up to the'1977 Order, Dow demonstrated to the satisfaction of' ' l the IMPCC that the only constant emission reduction technology 1easona- . i bly available to Dow and econcaically feasible to install on its antiquated facilities is fuel conversion from coal to Ics-sulfur oil.
'Podification t'o these facilities, 'if physically possible, to enable Dcw to burn coal and meet emission limitations would rcqd. ire at.least three i ,
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l l years lead time and cost as much as $100 million. Sucii expenditures are l unreasonable in view of tho' limited. time Dcw will continue to operate its facilities.
. Compliance with the emission r,egulations through complete fuel conversion to 1cw-sulfur oil will require over titirteen thousand barrels
- per day of fuel oil.
The'present operation.of the SCS' requires approxi- . mately three thobsand barrels .per day of fuel oil and an equivalent - amount of nat' ural, gas. . This dxcessive use of a scarce resource could be averted if the'MAPCC.would, grant Dow a.further variance from the'S' tate emission regulations for the period followipg July h 1980 and thus
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allow Dow to continue to operate its' SCS in the present fashion'. ' Dow has informad .the.1%PCC that it may seek such a variance at some time in the' future. . Since neither the IMPC.C'nor the Environmental Protection
, Agency have demonstratied that Dcw.is causing violations of the' federal e:6ient air y:ality standards, s;ch a variance cou$ be, granted uit'.aut ,
endangeri,ng the health or. welfare of the citizens of Midland,' Michigan. The grantipg of a variance fobthe interim period bsjond July .1,1980 -
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would result in a savi,ngs of seven thousand barrels per day of fuel oil. - 1
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s' C, r 2nank you for your lottar of Au.]ust 5,1977 in which you s a e4 pressed Ocu Chemical Company's supcort of incransed coal ! u;o and your interest in meeting to discuss Don's initiatives i in the matter of coal utili::ation. js. Per yccc sug.,;estion, my staff hc3 arranged to ::act with - I
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Environmental Protection Agency Regica V, Chicago Offics ~ and the dichigan State Energy Office to join us cince the subject of 'our discussion ic of vital importance to each of those organizations. f
;ie appreciate your cooperation and conc 2rn in this catter.
Please call if I may os of further acsistance. f 1 Gim:or e ly, . . -
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'C:.2 12,T" g PRESEflTATI0fl TO FEA Oft SEPTEMBER1977 13, 9 wm My name is Hunter Henry. ' Ia
. am the General Manager of the Michigan Division of Dow Chemical, U.S.A.
In this position a portion of my responsibilities include management of a large chemical manufacturing plant located in Midland Michigan. , This plant employs 7,500 people and annually produces goods with a worth in excess.of $1,000 000 000 00 In conjunction with our manufacturing at this location, we operate two power plants for the cogenerati on of power and process steam. Today these power plants are generating 100 MW of electric power and 2.5 million pounds per hour of process steam. We presently burn coal, oil and natural gas in our existing cogeneration facilities Although . the opera ting economics significan tly favor the use of coal, we cannot use this fuel exclusively because our . pollution. control equipment is inadequate to meet the State of Michigan's emission regulations and thus on occasion the federal ambient air quality standards could be exceed e n di the Midland area. We recognized the potentia'l for air pollution problems and yet we were anxious to maximize the use of coal as an energy source. These factors prompted us to agree te a Consent Order with the Michigan Ai . r Pollutio,n Control Commission (MAPCC) on May 17, 1974. The 1974 Consent Order provided that Dow would operate a Supplementary ontrol C System (SCS) which would enable in to meet the federal
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ambient air quality standards for sulfur dioxide. SCS a're
-systems which limit the rate of pollutant emissions during periods when meteorological conditions are conducive to ground level concen trations in excess of federal ambient air quality s tandards. In other words, when there is a potential for a violation of the federal ambient air quality standards for sulfur dioxide, we burn low-sulfur oil or natural, gas in the boilers; otherwise, we burn ~ coal. Jack Brown wil.1 describe the operation of the SCS for you in more detail later. The 1974 Consent Order further.provided that so long as the federal ambient air qualiti standards for sulfur dioxide were met, and they have been met since the inception of SCS on July 1, 1975, Dow was. granted a variance until July 1, 1980 from the emission regulations for air pollutants.
The boilers , turbines and auxilia ry equipment l oc a ted' in our power plants are antiquated and cannot be made to operate with productive reliability af ter 1984 at the latest. Jack Brown will also be providing you with the specific age and condition of this equipment as well as the current programs we have underway to extend its productive reliability until 1984. Because of the age of th.is equipment, it was or.iginally planned to retire our power plants in the mid-70's when Consumers power Company was scheduled to begin
*l supplying Dow with electric power and process steam frca a
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nuclear plant it is constructing at a location adjacent to our chemical plant. Repeated delays in the'.co'nstruction of 9
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the nuclear plant however have caused this facility to be unavailable for commercial operation until March 1982. At the time the' 1974 Consent Order was n.egotiated, we anticipated the nuclear plant would be operating and our power plants retired before July 1,1980. When it became ' apparent that the nuclear . plant would not be available by - that time, the MAPCC, through its staff, pressed us for a commitment as to how we would meet the emission regulation,s upon the expiration of the variance on July 1, 1980 until March 1982 when process steam from the nuclear piant would be available. As a result, on July 21, 1977 a new Co'nsent Order between Dow and the MAPCC became effective.
~ The 1977 Consent 0rder provided that we would continue to operate an SCS until July 1,1980 af ter which time we would eliminate coal as a fuel in our power plants. During the negotiations leading up to the 1977 Consent Order, we demonstrated to the '
4 satisfaction of the MAPCC that the only constant emission reduction technology reasonably available to Dow and econom-ically feasible to install on our antiquated power facilities ' is fuel conversior from coal to low-sulfur oil. - ( Jack Brown will be discussing the alternatives to
. fuel conversion that we considered in order to meet the emis -
s t an regula tions. I think that you will agree after his presentation that if Dow must comply with these regulations fuel conversion is our only viable alternative.
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Dow's present energy plans are 'predica ted on
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Consumers Power's nuclear: plant co'mmencing' commercial on ope
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on or before March 1982. At tha t time our power' plants will be retired and we will purchase our electric power and process steam from Consumers Power Company. I would be remiss however if I did not point out to you that there may be further delays in the completion of the nuclear plant. The issuance of the original co'nstruction license was~ challenged in the courts and as a result the Nuclear R,egulatory Commis-sion has been ordered to reopen the licensing proceedings. As.a result'of these reopened proceedings, the construction license for the nuclear plant could be either continued as is, modified or temporarily or permanently suspended. I mention these possibilities only to emphasize the uncertainty which surrounds Dow's future energy supply. As a result of this uncertainty, I would summarize our energy situation as this: (1) At the present time, we still intend to purcha's e our power and process steam from Consumers Power when its nuclear plant commences commercial operation in 1982. (2) Since the nuclear plant will not be available until 1982 and perhaps longer, we must continue to operate our present f acilities in the interim. (3) Under the terms of both our 1974 and 1977 . Consent Orders, our. power plants must meet all emission regulations after July 1, 1980. (4) We are in no position to commit to significant expendi tures of capital for the' co'ns truction of new s team
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generation facilities until~ the future of the nuclear plant is resolved. (5) Dow's entire energy situation must be clarified in sufficient time in order tha t we may construct and put into operation appropriate replacements for our present facilities if this is-required prior to the'end of 1984. As I said earlier, we have no confidence in the productive reliability of our power plants beyond that date. At this point, I would like to defer to Jack Brown who will provide you specific information on the age and condition- of our existing cogeneration facilities and the alternatives we considered to fuel conversion. In addition, I have asked him to discuss air quality in the Midland area and to give you some idea of the anticipated improvement in tir quality which will occur when tie a re '9-cad to meet the emission regulations. (AT THE CONCLUSION OF JACK BROWN'S PRESENTATION) As I hope you can now see, we have no viable alternatives available to us other than conversion from coal to oil if we are to ipeet the emission reg.,ulations. Yo.u should also recognize at this point that the anticipated improvement in air quality in the Midland area will be slight and yet the cost, as Jack has demonstrated, will be significant. '. The cost in depletion of natural resources will also be significant. Compliance with the emission regulations through complete fuel convers' ion to .l ow-s ul fu r oil will require over thirteen thousand barrels per day of fuel oil.
.6 The present operation of the SCS requires approximately three thousand barrels per day of fuel oil and an equivalent amount of' natural gas. Thus we will be burning an additional seven thousand barrels per day of fuel oil in order to satisfy emission regulations.
In view of the sl.ight environmental improvement which will be achieved from this conversion, Dow is reluctant to proceed in this manner, but unless the MAPCC will' extend our variances from the' emission regulations beyond July 1, 1980 we have no other choice. We have informed the MAPCC that we may seek such an extension at some time in th'e future. Since neither the MAPCC nor the Environmental Protection Agency have claimed that Dow is responsible for violations of the federal ambient air quality s tandards, such.an-extension could be granted without endangering the'
-health or welfare of the citizens of Midl.and, Michigan. The granting of a variance for the interim period beyond July 1, 1980 would result in a savings of seven thousand barrels per day of fuel oil.
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REMARKS OF JACK M. BROWN As Mr.' Henry indicated, we originally expected to shut down our cogeneration facilities in 1975. When it became apparent that the Midland Huclear Plant would not be on stream by 1975, we developed an SCS, (Supplementary Control
~
System) to enable us to meet the Federal Ambient Air Quality Standards for Sulfur Dioxide. SLIDE 1 - Permit me briefly to explain how this SCS program operates.SCS depends on the ability to fcrecast the weather conditions that will cause 50 buildup. 2 The Division has employed Environmental Research & Technology, Inc. (ERT) of Concord, Massachusetts, as round-the-clock consultants to assist in this effort. A computer in the Dow plant provides ERT with hourly data an planned and actual boiler loads, current meteorological readings, and ambient S02 levels. . Thiee times each day, the shift meteorol_ogist at ERT prepares a weather forecast for the Midland area. This forecast, together with the. current data mentioned previously, is put into a computer model which predicts resultant 50 2 levels at 89 points scattered throughout the entire Midland area. Whenever these forecasted levels equal or exceed Federal standards, ERT will evaluate the pre-determined options or " supplementary steps" as we call them, provided by D and reccmmend an operating mode that will reduce the power house emissions s keep the air quality in Midland within allowable limits. Such an operating mode might include switching one or more boilers frem coal to oil or reducing load. Changes in expected weather conditions or planned boiler operations may necessit an immediate re-evaluation. . SCS, then, is designed to maximize our coal use without offending the environment The scaice, clean burning fuels, low sulfur oil and gas, are only used when adverse meteorological conditions are present and the potential exists for violating the federal ~ standards.
. ,, - s SLIDE 2 After an in depth review of our SCS, the Michigan Air Pollution Control Commission (MAPCC) granted us a variance through July 1,1980 from the Michigan emissien requirements as long as the Federal ambient air quality standards for S02 were met.
SLIDE 3 To insure compliance with these standards,we maintain, throughout the City of Midland, an extensive network of continuous monitors for S0 and 2 Hi-Vol ("High Volume") samplers for suspended particulates. All of our monitors and samplers are operated under the supervision of the State of Michigan and the results are reported to them on a daily basis. Additionally, the State operates their own units, independent of our network. The results of this moni.toring is compared against the Federal standards to determine the _ performance of our SCS system. Since the inception of our SCS program on July 1, 1975, these Federal standards for S02 have not been violated. SLIDE 4 This graph shows how our fuel mix has been varied to help improve the Midland air quality. The projected result of the 1977 Consent Order is also shown. SLIDE 5 The emission reductions resulting from the change in fue1 mix and SCS is shown on this chart. Our projections through the mid 1980's are also ind uded. Prior to 1975, 24-hour running averages for S02 as high as .34 ppm had been recorded. Since February,1976, no 24-hour trailing average for . S02 has exceeded .12 ppm. The maximum annual average recorded at any site has dropped from 0.034 ppm in 1974 to 0.021 ppm in 1975 and to 0.016 ppm in 1976. The average of all sites in 1976 for S0 was 0.009 ppm while the 2 annual standard is 0.03 ppa. The record on suspended particulates is also
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impressive. Even with a sampling method that indiscriminantly measures the results aof dusty roads, light construction, and grain elevator dust as well as industrial boiler emissions, the Federal primary or health related standard has likewise not been exceeded in Midland since the start of our SCS. The highest annual gecmetric mean for any site in 1976 was 62 micrograms / cubic meter which is well within the Federal standard of 75 micrograms / cubic meter. At this point, I believe that some background on the configuration, age and general condition of our boilers would prove helpful. SLIDE 6 On this slide, I have shown the boiler configuration by powerhouse, each boiler's fuel capability, and its age. All but two of our units have the capability to burn oil. One of those, Boiler 18, is currently being converted and will be capable of oil firing by mid-1978. Boiler 19 is scheduled for gas to oil conversion in 1979. The package boilers are the youngest of our units, but they only produce _ low prersure steam and are used primarily to handle peak demands. The bulk of our steam load, then, is carried by those 10 boilers, which range in' age
.c from 11 years to 43 years -- the average age being 26.
Ouring the period 1967 through 1972, cur plan was to shut down our cogeneration facilities in 1975 when the Midland fluclear Plant was to begin supplying our process steam and power. Our boiler maintenance efforts were limited to that which-was necessary to meet the 1975 shut down. As a result of the delays in m
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the Nuclear ' Plant startup and our postponement of some preventative maintenance, we are now involved in a major boiler rehabilitation program. SLIDE 7 As you can see from this integrated maintenance schedule, every boiler is involved. Each boiler is unique as to the actual work to be performed, but the type of tasks underway include replacement of the
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furnace wall tubes, superheater banks, air heaters, and in some cases, new furnace bottoms. Many of the steam generating tubes have been patched so oft'e n that the original tube wall is. ccmpletely' gone. We have been literally patching the patches. Throughout this rehabilitation program, we must continue to provide process steam and power to our chemical complex. The schedule must be tight enought to minimize both the number of boilers off-line at one time and the length of time each boiler is out of service. The extreme' harshness of the Michigan winter also makes it imperative that, in so far as possible, all boilers be available during the mcnths of Dacember
~
through February. Thus, the program will extend over a five year period and cost m. ore than $31R. The reliable productive life of the boilers will only
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be extended through 1984 SLIDE 8 Although our engineers felt quite strongly about the estimated life of the boilers, we asked Black & Veatch, an independent boiler engineering firm, to review our equipment and our maintenance program. As you can see, their findings concur that we cannot expect to safely and reliably operate - our boilers past 1984. Continued delays in the nuclear plant start up date and pressure from the MAPCC to provide cur plans to meet the Michigan emission requirements by
. .S.
1980-caused us to intensify the search for an acceptable method of constant emission control for our coal fired boilers. SLIDE 9 This ~ slide shows what we believe to be the complete list of options potentially available to us. I will review the results of our studies so that you will have a better understanding of why we feel that none of these options are viable for us. SLIDE 10 Our stacks are relatively short - our powerhouses are 100 ft. high and the stacks are only 177 ft. high. This combination tends to cause downwash, or plume entrapment, in high winds. This could result in high concentrations of 502at ground level. The meteorological. parameters involved with this downwash phenomena were defined after extensive wind tunnel tests of our powerhouse configuration conducted by Mount Auburn Research Associates, Inc., of Newton, Massachusetts. These parameters have been included in the model used by ERT in our SCS program. Hence, our SCS program prevents S02 buildup N due to downwash. physically overcoming"this downwash by increasing the existing stacks is not possible due to old and inadequate stack and building foundations. A new tall stack (400 ft.) at each powerhouse, with all of the necessary breeching and electrostatic precipitator, would require more than e ( _ three years to construct and an investment of over $35M. This construction time does not include the time-necessary to secure regulatory approval or , i company authorization. However, if we assume that regulatory approval could be . . secured in time for us to commence work by March,1978, we would not be able to meet the July 1, 1980 deadline. The structure would only be used as short as one year,:but no more than.four years. Most significantly, we would still not meet Michioan emission standards for 502 ' L
SLIDE 11 Low sulfur coal was another option we considered. In 1975 we tested.
. several rail car loads of Western coal (< 1% sulfur) in our boilers. Due to excessive fouling of the superheater section, we were unable to continuously fire
.a boiler for more than 4 days. These tests identified the areas' listed here as requiring major modifications or replacement. Even after completing these modifi-cations, the combustion chamber o[1 our boilers would still be too small to allcw sufficient residence time for this low BTU, low sulfur coal to completely combust.
, Hence, boiler operability would be seriously impaired or restricted. At least four years and $50A would be required to complete these changes. Again, assuming that the regulatory process allows us to start by March,1978, we would not be completed until March 1982 - one month prior to the scheduled startup of the nuclear plant. We would be operating on Western coal as little as one month and no more than three years. Due to market pressures, environmental requirements
.for strip mining, and tremendous transportation costs, we project this coal to cost twice that of Eastern ccal. Further, it is presently only available on long-term contracts. Fi.ially, there would be no extension of the reliable productive life of our boilers.
SLIDE 12 Flue gas desulfurization, or scrubbers, is another option we reviewed. The tall stacks an'd precipitators mentioned earlier would also have to be included. After reviewing the extremely limit.ed space availabl D jacent to our powerhouses, the very tight boiler rehabilitation program I mentioned earlier, and the age of the powerhouses themselves, our engineering consultants are not even sure that i this is physically possible. But if further study determined that it is possible,, then they estimate four years and $618 would be required for construction. As -l I said earlier, this time is after regulatory approval and company authorization. However, if construction were to start immediately, the operating life of these units would be no more than three years and as little as one month. This, of course, is based on-the fact that there would be no extension of the reliable o productive life of our boilers.
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SLIDE 13 Sometimes, a portion of _the sulfur content of coal can be removed by washing the coal. Our coal comes from two sources; 60% from Powhatan and 40% from Nelms #2 - both mines in Eastern Ohio. Our contracts with both run through 1981. Neither mine currently has washing facilities available or planned. The coal cannot be washed at an intermediate location since all northern Ohio coal washing facilities are projecting capacity operations through the mid-80's. Construction of a new facility would require 30 months and $58. Coal washing facilities are usually located at the mine mouth. The operator can than use played out portions of the mine for disposal of the run-off. Hence, due to the disposal and water treatment problems, as well as the short usable life, we concluded that installation of a coal washing facility in Midland was impractical. Powhatan coal could be' washed from 3.75% sulfur to about 3.05. However, the mine is expected to play out by 1982. Hence, installation of a washing facility with a projected life of less than two years is not gractical. Nelms #2 could
, be washed from 3% to 25. But, since Nelas is only 40% of our coal supply, it would have the effect of lowering our average sulfur content less than ti of 15.
Hence, we would still be unable to meet the Michigan emission standards for S0 # 2 suspended particulate. SLIDE 14 Another option considered was a complete replacement of our facilities. Such a new facility would, of course, be coal fired, and meet all of the NewN Source Performance Scandards. However, it could not be completed in less than five years and would require in excess of $3003. The Midland Nuclear Plant is scheduled for startup before such a plant could be built. - l l l l
, SLIDE 15 I We -havt. also looked to new technology, primarily fluidized bed c.om- ;
bustion and coal gasification. We and others are actively pursuing these processes However, much work remains before either process can be considered commercially j reliable. Our research indicates that commercial units will not be in the planning stage before the mid-198,0's. SLIDE 16 I gave you a lot of information on several constant emission control
- methods.
This slide lists the options and the reasons each was rejected. Tall stacks and precipitators and washed coal acccmp.lish nothing - we would still not meet the emission standards. Western coal would require an investment of
$50A dith a useful life of no more than three years. Boiler operations would be seriously impaired and fuel supplies may be totally unavailable due to the short term nature of the project. It may not be possible to even fit scrubbers and their associated hardward onto our powerhouses. If it is, $61A would have to be invested for a usable life of no more than three years. A new compliance facility could not be built prior to nuclear startup and mere than $3000 would be needed.
Most important, none of these options could be oper-tional in time for us to meet the July 1,1980 deadline of our Consent Order. Finall'y, new technr. logy processes are simply not ready for commercial operation at this time. Our conclusion was that conversion to 100% oil was the only practical and reasonable alternative for us to meet the Michigan e' mission regulations by N July 1,1980. SLIDE 17 This slide shows the quantities of oil that we are talking about. ' Operating on SCS, current oil consumption averages 6000 BBL / day - adding
$12M/ year to our fuel costs. Conversion to 100% oil will require an additional 7000 BBL / day or a total of 13,000 BBL / day. If we are forced to continue on this
' path our fuel penalty will then be $25A/ year.
SLIDE 18 To demonstrate the improvement to be _ expected from burning 100% oil, we plotted the observed 50 2 during a period last winter that was particularly conducive to a buildup of ground level pollutants. We asked
' .ERT, our SCS consultants, to model the expected results had we been on 100%
oil during the same period. ' SLIDE 18 OVERLAY The red line shows those resul ts. In terms 'of the Federal ambient standard for S02 , with SCS, there is no problem. An additional 125,000 barrels of oil would have been needed during this period to displace the coal burned and would have represented only a .01 ppm improvement in ambient S02 . In ther words, 125,000 barrels of oil would have been used to solve a non-existent problem. SLIOE 19 We did the same thing for a period this summer when oar coal burn was high with very little impact on air quality. As you can see, ambient S02 levels during this period were extremely low. This time <a quarter of a SLIDE 19 OVERLAY million barrels of oil-would be required and the improvement is nearly non-existant. g -N 9-12-77
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C0fiSTAflT EMISSION CONTROL l'.ETHODS EXISTIllG TECHNOLOGY o TALL STACKS AIID PRECIPITATORS O 1l ESTER!! COAL O FLUE GAS DESULFURIZATIC'l O ':.' ASHED COAL O NEli COMPLIANCE FACILITY
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NEW TECHNOLOGY . O FLUIDIZED EED COMBUST 10'l N O C0AL GASIFICATION 1 1 L i .
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>3 YEARS + $35ii
-USEFUL LIFE: MINIMUM 1 YEARS MAXIMUM 4 YEARS CD STILL NOT MEET MICHIGAN EMISSION STANDA 2
WESTERN C0AL (<1% SULFUR) c TESTED IN DOW BOILERS IN.1975 o MODIFICATIONS REQUIRED C0AL HANDLING - SCOT BLOWERS (DOUBLE) C0AL FEEDERS - BREECHING & FANS AIR HEATERS -- ELECTROSTATIC PRECIPITATORS 0 OPERABILITY SERIOUSLY IMPAIRED 0 FOUR YEAR INSTALLATION 8 INVESTMENT OF OV USEFUL LIFE: MINIMUM IMONTH MAXIMUM 3 YEARS 0 DOUBLE FUEL COST 0 AVAILABILITY UNCERTAIN O NO EXiENSION OF RELIABLE PRODUCTIVE USE l
FLUE GAS DESULFURIZATION O FOUR YEAR LEAD TIME USEFUL LIFE: MINIMUM 1~ MONTH < MAXIMUM 3 YEARS. e61+IIINVESTMENT BREECHING AND FANS LIMESTONE HANDLING AND STORAGE SULFATE. DISPOSAL TALL STACK AND ELECTROSTATIC PRECIPITATOR O NO EXTENSION OF RELIABLE PRODUCTIVE USE O
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NEITHER HAS C0AL WASHI.4G FACILITY !
- l C0liTRACTS ilITH BOTH RUN TO 1981 !
i 0 0H10 i! ASHING FACILITIES AT CAPACITY - O NEil FACILITY REQUIRES 30 MONTHS CONSTRUCTIONi
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l:0T EET EiilSSIO!! STA1!DARDS O 12 STER:1 C0AL
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HICHIGAllDIVISIO?t
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TO iint AIR QUALITY STAi!DARDS
- 1. TO :',EET FEDERAL PRIMARY 6,'000 BBllDAY 8 SICC.'lDARY K131Elff STA!?DARDS (USI':G S C S)
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- 2. TO !!EET STATE EHISSIO!!
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