I don’t know if there is a limit, but as a work-around until you figure it out you could put the emails into a collection and use a for each loop to send each one individually.

Yeah, I know...I was trying to avoid doing that. I even considered breaking it down into 3 emails. Because dealing with these emails wasn't a requirement, I was trying to deal with the REAL requirements and deal with this issue later. I have a lot of other fires on the stove that are more important.

Another option is you could ask your admins to create a security group in AD with an email address.  It has to be a security group to show up in SharePoint.  Then you could add users to that group like a regular distribution group.  In the workflow you'd only have to put the group name in the To field.  You could manage the people in the group through Outlook.