e

.1

,

C-

5

flA.,°t~C’

“SN

isbC

e~,n

t

.i

RU

-

~E

F

~

ut

en’

r°~r

ee Brorr~r, parr

s

•

qc.~an

~

~

.t

o

t ant.-

ROcjtc~

s.

‘3a.

~

s.~e

troa~4to ~

is

rq.

.is

to

Pt

ffofl.Vt’

a

f

.~‘

~e-j

s.d

a

a

F

“_

a.. see ~

r.~

p.

cc

f

‘i~

___y~

.

r

t•”~flt~.

~o~tro

eg 1ation~±ra

ret

d 0±

e

ear

r

orde~to ~ont...is

praratiyq

ste

B

~“~o

La

perdi’~g

,,Tpltic.n

~t

c

tutie:

ana

quioment

corr...,t:ons

C’r

e con’ro

3!

ecca’

“C

carzoa

monoxide

..TtSoLOflS.

au:e

2C6 e

L.aLts PetLtanaac s

~oac,x.de

LSJiO

s to 40”

~

orre~-edto

.,

excess ~ir

‘ie

curia

proc

uses

brween

cd

9)

ton

of

ra

mate

tal

oer

lay.

Ra

nateraaas

consist

0±retira

.astings

steel

and ion

sccap,

.oice

fluxano

comp

unds

a..r

and

ccrtat

aditives

Par’

ate

emics~ons tro.m

the

c ipola

are

adequate..

:~ttrosid by

a

Wt.~

sccaaber.

The

faci’itv

aousrtq

~e

cupola

~S i’

a~industrias

area

with

the

nearest

residence

neing

sore

500

ft.

distant.

T’e’.tiontr’a capola is

equipped

wit?

an

afterburner

wh~ch

ias

tailed

to efficiently “ontrol the

carbon

tononde

discharges.

Several

reasons

are

given

for

the

inefficiency

of

the

afterbarner:

1.

The

afterburner

is

occasionally

snuffed

out.

This

is

to

be

corrected

by

vendor

2.

The

size

of

the

charging

opening

aLlows

a

retention

time

of

only

0.01

second,

winch

is

too

low.

This

will probably be corrected by modifying

the charging mechanism,

and

13—129

---

2~

3~

The afterburner is causing the firebrick

lining of the cupola stack to

erode.

This

is

to be corrected, but we have not

been

told

details

of

the

correction

program.

In 1972 Petitioner filed its application for an operating

permit.

The

application

was

timely but the permit was denied

due to excessive carbon monoxide emissions.

Thereafter, Petitioner

attempted to prove compliance by conducting

a series of stack

tests in January, August, October and November,

1973.

These

tests, which indicated emissions ranging from 11 ppm to 1296

ppm,

failed to show compliance.

In February 1974 Petitioner completed its “Statement of

Problem”.

In the event corrective action on the afterburner

fails to bring the operation into compliance, Petitioner proposes

to investigate several alternatives by July

1,

1974 and implement

the alternative which provides the “most effective least cost”

method of cOntrol.

The refractory problem will be solved by

creating adequate temperatures for the conversion of carbon

monoxide to carbon dioxide, either by obtaining additional

supplies of natural gas or by obtaining a”firm”

supply of an

alternate fuel,

There will be an investigation into the cost

and effectiveness of:

a catalytic method of carbon monoxide

conversion, increasing the residence time at high temperatures

for carbon monoxide conversion,

and changing the solution in the

scrubber for absorption of carbon monoxide.

In addition, there

will be studies on:

1) eliminating the “B” Foundry and purchasing

castings from outside

suppliers;

2)

expanding the “A” Foundry

with

a controlled electric furnace to produce castings.

As

the Agency noted, the Petitioner failed to discuss the

arbitrary or unreasonable hardship which might be incurred if

variance is denied.

However, Petitioner~sstatement that pro~

duction

is divided into 37

for internal use and 63

for outside

customers does provide the Board with some insight along these

lines.

The most obvious impact of a variance denial would be that

Petitioner would have to operate in violation of the law or reduce

or cease operations.

Petitioner claims that part of its problem

is caused by insufficient quantities

of natural gas to operate its

afterburner efficiently.

Petitioner has no control over the

natural gas supplies it receives.

Therefore,

in addition to

attendant internal losses, Petitioner~scustomers would also

suffer for lack of goods and services now supplied by Petitioner.

13

—

130

---

There are a number of factors in Petitioner~sfavor.

The

Agency believes that the carbon monoxide emissions will not

pose a health hazard to Petitioners~neighbors

Substantial

good faith has been shown by Petitioner through the years as

evidenced by many efforts

to control emissions.

Two coal fired

boilers have been converted to dual fuel boilers

(oil and gas).

A wet scrubber was installed on the cupola to control particulate

emissions.

Even the troublesome afterburner indicates Petitioner~s

good faith efforts to control its carbon monoxide emissions.

The Agency claims that Petitionervs plight is self~imposed

because Petitioner failed to investigate its “alternatives”

during 1973 and that a request for variance should have been

submitted no later than January 1974.

Pe~apsPetitioner could

have

proceeded

more

rapidly,

but

this

is too speculative to

justify a denial of the variance.

The Agency recommends denial

or in the alternative the granting of a short variance only until

June 30,

1974.

The

Agency

asserts that the strategy to be selected by the

Petitioner is unknown now and it would be unreasonable

to arbi-

trarily set the variance for one year since different control

strategies

require

different

time

periods.

However, we believe

that Petitioner should have the rest of this year in which to

select its control program and

attempt

to place the control

program into operation.

Therefore, we shall grant

a one year

variance commencing with January

1,

1974.

This Opinion constitutes the findings of fact and conclusions

of law of

the Pollution Control Board.

ORDER

it is the Order of the Pollution Control Board that Greenlee

Brothers and Company of Rockford,. Illinois be granted

a variance

from Rule 206(e)

of the Air Pollution Control Regulations from

January

1,

1974 to December 31, 1974 for the purpose of correcting

cupola afterburner deficiencies and evaluating and selecting an

alternative control strategy designed to achieve

compliance

with

Rule 206(e).

This variance is subject to the following conditions:

1.

Petitioner shall file monthly reports with the

Environmental Protection Agency commencing September

1,

1974 advising the Agency of its progress in achieving

compliance.

2.

Petitioner shall continue to operate its after-

burner at the rate of 2.4 MBTU/hr.

except during such

time as action pursuant to the deficiency correction

program described in this Opinion shall prohibit such

13—

131

---

operation.

Petitioner

shall

advise

the

Agency

in

writirç,

sa~d

ioooerat~e

perioas

an~ r.~. aoy

~r~nt

ratur~

gas

‘-Ive

~es

Petitioner

sna~i

secure

appropriate

construction

permits

prior

to

the

construction

or

installation

of

any

air

pollution

control

eoulpment.

I,

Christan

I.

Moffett,

Clerk

of

the

i:Liinoi~

Pollution

Control

Board,

he~eby certify

the

above

Opinion

and

Order

was

adopted

thi~

~~day

of

1974

by

a

vcte

of

~S

to

o

13

—

132