ILLINOIS POLLUTION CONTROL BOARD

August 30,

1973

DEERE & COMPANY,

)

(VERMILION DIVISION),

)

Petitioner,

vs.

)

PCB 73—88

ENVIRONMENTAL

PROTECTION AGENCY,

)

Respondent.

OPINION

AND

ORDER OF THE BOARD

(by Mr. Henss)

Deere & Company rec~uestsvariance until December 31, 1973

from the particulate emission standards of the Rules and Regu-

lations Governing the Control of Air Pollution issued by the

Illinois Air Pollution Control Board and from Rules

103 and 104

(permits and compliance programs) of Chapter

2, Air Pollution

Control Regulations.

The variance will be limited to the

operation of two air furnaces which are used in the manufacture

of malleable iron products

at

Deere’s Vermilion Division in

Hoopeston,

Illinois.

Deere’s Vermilion Division is a

60 year old foundry which

uses floor molding and two air furnaces for inciting.

It employs

200 persons and produces about 3800 tons of castings per year.

Each batch fed into one of the furnaces includes 22,800 lbs.

of

malleable scrap,

14,000 lbs.

of pig iron,

3,200 lbs.

of steel

scrap and 26,000

lbs.

of coal.

The melt cycle takes about

10

hours.

Therefore,

Deere calculates that the process weight rate

is 6,600 lbs. per hour per furnace.

On August 31, 1972 Deere applied for operating permits

using standard emission factors from AP-42, Compilation of Air

Pollutant Emission Factors.

Deere estimated that its total

particulate emissions

from the two furnaces combined came to

17.6 lbs. per hour which was under the 18.2 lbs. per hour allowed

in Chapter III, Table

1 of the Rules.

The Agency denied the permit request, at least in part,

because of the Agency belief that the standard emission factors

were not valid for these furnaces.

Petitioner resubmitted the

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permit applications along with an explanation for its use of

the emission factors.

The Agency denied the second permit

request.

Discussions between the two parties resulted in

a

stalemate.

Petitioner’s operating permit application filed in August

1972 was accompanied by a Compliance Plan and Project Completion

Schedule.

These documents reflected Petitioner’s belief that

the new air pollution control regulations will,

on December 31,

1973, reduce allowable emissions from 18.2 lbs. per hour to

14.2

lbs. per hour,

or about 25

below Petitioner’s estimated

emission rate of 17.6 lbs. per hour.

Petitioner’s Compliance Plan

essentially was to replace pulverized coal burners with low—

sulfur oil burners before December 31,

1973.

According to

Petitioner,

this would reduce particulate emissions to 9.0 lbs.

per hour,

as compared to a rate of 10.1 lbs. per hour allowed

for oil fired operations.

In formulating the Compliance Plan,

Deere proceeded under the belief that the furnaces were in com-

pliance with current emission standards.

It was the Agency’s position that Deere was in violation of

applicable Standards on the date of adoption of

the new Regulations

and therefore,

under Rule 203(c)

is required to meet the more

stringent requirements

of Rule 203(a),

the standard for

“New”

Process Emission Sources.

Using several calculations,

the Agency

estimated that particulate emissions from each air furnace were

53

to

74 lbs. per hour.

Some of the EPA calculations involved

use of emission factors, although the Agency later said “No

adequate emission factor is available for emissions from air

furnaces”

(Agency Amended Recommendation).

The EPA also contended that when using oil Petitioner’s

combined process weight rate would be about

4 tons per hour and

that Deere’s particulate emissions of 9.0

lbs. per hour while

burning oil would exceed the allowable rate of

5.33 lbs. per hour.

Accordingly,

the Agency rejected the Compliance Plan and Project

Completion Schedule and recommended that Deere petition for

variance.

Without conceding the validity of the Agency calculations,

Deere agreed to petition for a variance.

Initially the Agency recommended denial of the variance.

The

Agency stated that Deere’s program would not bring the Company

~nto compliance with tie Standards established in Rule 203(a).

The

Agency also said that citizens in the area complained

of soot,

sandy particulates and a dead fish odor allegedly coming from the

foundry.

The. Agency recommended use of distillate fuel oil instead

of residual fuel oil and further investigation of methods to

achieve compliance.

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Subsequently Deere filed an Amended Petition for Variance

reflecting major changes in accordance with the Agency

Recommendation.

Deere advised that it had stopped using the

two furnaces simultaneously and now plans to use only one furnace

at a time.

This modification will change the allowable particulate

emission rate to 3.7 lbs. per hour

(Rule 203(a).

Using distillate

fuel oil

(#2 fuel oil)

in place of pulverized coal or residual

fuel oil as first proposed, Deere estimated that particulate

emissions would be reduced to 3.4 lbs. per hour.

Deere also

proposed to install an after burner on each furnace which it

estimated would further reduce particulate emissions to 2.28 lbs.

per hour.

Petitioner estimated that conversion

of the first

furnace would be completed by August 6,

1973 and the second

furnace by December 31,

1973.

Deere said the odors mentioned by the Agency “do not relate

to the air furnaces.

Rather, we suspect this odor

is due to the

catalyst

(DMEA) used in making special cores at Vermilion....

The problem appears to arise when the scrubbant of the core machines

bubbling column gelatinizes and becomes ineffective due to over—

gassing the core’ machine with DMEA.”

The Company said it would

install

a more reliable metering device to control-the amount of

catalyst used in the operation.

Deere believes that the improved

metering will eliminate this odor.

Equipment and installation costs to convert both furnaces will

be about $66,600.

Other types of control would be far more

expensive

(high energy scrubber

-

$260,000,

electrostatic precipitator

—

$200,000).

From an economic viewpoint the method of compliance

proposed by Deere is certainly to be preferred.

Deere concluded that all points at issue between Petitioner

and the Agency except past emission levels had been resolved and

asked the Agency to reconsider its Recommendation.

The Agency

did so and now recommends grant of the variance subject to:

use of

only one furnace at a time, conversion

to

#2 low sulfur fuel oil,

stack testing, and ultimate compliance with Rule 203(a).

It is our belief that the record in this case is sufficient to

allow Petitioner

a variance until December

31, 1973 without further

proceedings.

We grant a variance from the particulate standards

(Rule 3-3.111)

of the Rules and Regulations Governing the Control

of Air Pollution,

if

a variance is needed.

Neither party has been

entirely convincing in establishing emission levels from past

operations of the air furnaces.

No stack tests have been submitted

and the calculations by the Agency and by the Company appear to

involve a bit of speculation and conjecture regarding emission

factors.

Fortunately,

the case may

be~

decided without resolving

the dispute over past emissions.

The stack test will provide the

information necessary to show future compliance.

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It appears.that Deere has now adopted a program which will

be completed prior to the December 31, 1973 deadline and will

probably bring the Company into compliance with the emission

standards of Rule 203 (a).

Both the Company and the Agency appear

satisfied that the Compliance Program will work satisfactorily.

Under those circumstances we would expect the Agency to approve

the Compliance Program and issue an operating permit.

No further

variance beyond the variance from Rule 3—3.111 should be needed

since the Company will be in compliance by the effective date

of Rule 203(a).

However, we will remove all doubt by also

allowing the variance from Rules 103 and 104

as requested.

The

EPA has twice denied an operating permit and the grant of

variance from Rule 103 and 104 will eliminate the need to debate

that issUe

a third time during the term of this variance.

We

commend both parties for their cooperation and the practical way

they have gone about

resolving their differences.

ORDER

It is the order of the Board that:

1.

Deere and Company is granted a variance from

January

1,

1973 until December

31, 1973 from

Rule 3-3.111 of the Rules and Regulations

Governing the Control of Air Pollution and

from Rules 103 and 104 of Chapter

2 Air Pollution

Control Regulations for the purpose of modifying

two air furnaces at the Vermilion Foundry as

described in this Opinion.

2.

During the period of the variance Deere shall

operate only one of the two furnaces at a time.

3.

By September 15, 1973 Petitioner shall convert

one air furnace to

#2 fuel oil and shall install

~tsuitable after burner.

4.

By September 30, 1973 Petitioner shall perform

a stack test on the converted furnace.

Agency

personnel shall be given

5 days notice of the

stack test and shall be allowed to observe the

test.

Results of the test shall be submitted to

the Agency within 30 days after it is conducted.

5.

If the stack test shows compliance with Rule 203(a),

Petitioner shall complete conversion of its second

air furnace by December 31,

1973.

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6.

If the stack test results do not show compliance

with Rule 203(a), Petitioner shall apply for a

variance indicating what control methods will be

used and the time schedule for bringing the air

furnaces into compliance.

I, Christan L. Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion and Order was adopted

this

~3&”

day of August,

1973 by a vote of

~.3

to

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