ILLINOIS POLLUTION CONTROL BOARD
March
28, 1974
ABEX
CORPORATION,
AMSCO
DIV.,
Petitioner,
vs.
)
PCB 74—1
ENVIRONMENTAL PROTECTION AGENCY,
)
Respondent.
)
OPINION
AND
ORDER OF THE BOARD
(by Mr.
Seaman):
This
is
a Petition for Variance filed with the Environmental
Protection Agency (hereinafter “Agency1)
on January
2,
1974.
The Petition was filed by the .Abex Corporation, Amsco Division
(hereinafter “Petitioner”) which
is located in Chicago Heights,
County of
Cook,
Illinois.
This Petition for Variance was originally filed with the Agency
on January
2,
1974.
Petitioner submitted
a new petition on
January 22,
1974, proposing an alternate compliance program.
Petitioner requests a variance from Rule 203(b)
arid
(c)
of Chapter 2, Part II of the State of Ill~noisAir Pollution Control
Regulations.
Petitioner operates
a welding rod manufacturing facility which
includes melting furnaces, tube forming and flux coating machinery,
sand molds,
crushers, and finish grinders.
Two types of welding
rod are manufactured
at this facility:
cast and tube type.
Both
types are used specifically for hard facing applications requiring
application of wear resistant surfaces.
The two types of welding
rods are manufactured utilizing completely different processes.
The tungsten carbide
arc furnace
is
the only source of
excessive emissions
in the tube type welding
rod manufacturing
process.
Here an electric arc furnace
is used to produce tungsten
carbide ingots which are subsequently quenched and then crushed
and screened to size.
The cast type welding rods are manufactured in another area
of
the plant utilizing two melting furnaces
and sand casting techniques
to
produce solid tungsten electrodes of various lengths and diameters.
Petitioner
utilizes
two
types
of
furnaces
to
melt
the
tungsten
alloys.
One
is
an
induction
type
furnace
and
the
other
is
an
electric
arc
11
—701
—2—
furnace.
Emissions from both of
these furnaces
presently
exhaust through a roof ventilator uncontrolled.
Molten
metal
is subsequently poured
into sand molds where, after
the metal solidifies, the rod ends
are cut off and the rods
are shaken out of the sand molds.
The castings subsequently
go to finishing operations
for grinding to size.
Emissions
from thepouring and shake-out operations
are presently
uncontrolled.
Petitioner requests time,
until
May 31,
1974, to complete
installation of control
equipment
to bring emissions from
the electric arc furnaces
into compliance with the appropriate
rules.
Petitioner states that emissions from the shake—out
area will
be eliminated by July
15,
1974, through substitution
of an alternate molding technioue.
Therefore,
the total
length
of time requested by the Petitioner
is approximately
6 months
or until July
15,
1974.
Petitioner acknowledges that particulate emissions from
the tungsten carbide arc furnace, electric arc -Furnace, metal
pouring, and shake-out are
in excess of that allowed.
Total
emissions are presently 5.72 lbs/hr. with
a total
allowable
of 3.48 lbs/hr.
Particulates consisting of metallic oxides,
primarily tungsten, cobalt, and chromium emanate from the
melting furnaces.
Particulates consisting of sand dust emanate
from the shake—out operation.
Stated emissions arc based on
tests conducted on 9/11
through 9/15/72 by George
0.
Clayton
Associates,
25711
Southfield Road, Southfield, Michigan.
The
following emission data was obtained:
Tungsten carbide arc furnace
1.9 lbs/hr
Metal
pouring
0.22 lbs/hr
Electric arc furnace
1.3 lbs/hr
Shake—out
2.3 lbs/hr
Emissions from the pouring and shake~outoperations will
be
essentially eliminated by substitution of new process equipment.
Total
emissions from the furnaces
is
3.2
lbs/hr compared with an
allowable 1.4 lbs/hr.
Although
a collection efficiency of only
56
is
required to achieve compliance,
Petitioner proposes to
install
a
baghouse
with
a
collection
efficiency
exceeding
99.
Petitioners facility is
located in
an area of heavy
industry, and the Agency has
received no citizen complaints or
objection
to
the grant of this Variance.
il
--
702
—3—
The Recommendation of the Environmental
Protection Agency
states,
in pertinent part,
as
follows:
The Agency recommends that the Variance be
denied,
or
in the alternative,
that it be granted
subject to the following conditions:
2.
Petitioner should exert maximum effort
to obtain an outside supply.of tungsten carbide
to eliminate usage of the tungsten carbide
electric furnace during the term of
the
requested
variance.
3.
Petitioner should be required to dis-
continue use of the electric furnace
in the cast
rod production area until
control equipr~entis
installed.
Paragraph
15
(p.5)
of the Agency Recommendation
is
as follows:
15.
Petitioner could purchase tungsten
carbide for use in the manufacture of tube-
type welding electrodes instead of producing
it on-site.
This would eliminate emissions
from the tungsten carbide electric furnace.
The availability of tungsten carbide, and the
cost penalty to the company
is unknown.
As
both the induction furnace and electric arc
furnace are used. in the manufacture of cast—
type rod,
it is possible the Petitioner could
refrain from using the electric arc furnace
until
control equipment
is installed.
There
is
no known short term alternative
to eliminate
emissions from the pouring and shake—out opera-
tions.
(Emphasis added).
In
an Order dated March
7,
1974, we stated:
In order
to reach
a reasoned decision,
the
Board will
require additional
information regarding the
availability of tungsten carbide
and the cost
penalty and/or feasibility
of its use in
Petitioner’s
operation.
Further,
the Board
will
require
an
analysis of the effect of discontinuing the use
of the subject electric furnace,
since,
from what
little
information
we
have
before
us,
Petitioner’s
operation appears to
be highly integrated.
11
—703
—4-
Petitioner has supplied the information requested.
As
regards
the subject electric arc furnace, Petitioner states:
Although
this specific electric arc
furnace
is
a component of
a highly integreted
process used for the production
of cast
welding electrodes,
its use can be discontinued
for the term of time involved
in the Petition
for Variance.
Petitioner states that it knows
of no producer of cast tungsten
carbide supplying,
on
the open market, the specific type of tungsten
carbide required.
Therefore, Petitioner contacted its direct competitors
in
the hardsurfacing electrode market to determine their capability
to supply Petitioner’s needs.
Two competitors have that capacity.
Petitioner has supplied data regarding the cost penalty of
tungsten carbide purchases
from
competitors.
However, Petitioner
emphasizes
that the proffered costs and production volumes are
confidential
and proprietary
in nature and requests that we treat
the information accordingly.
iije
see no reason,
in this particular
situation, why Petitioner’s request should not be respected.
From the data submitted by Petitioner,
we are satisfied that
the substantial increased expense resulting from purchases from
competitors
is not justified by the magnitude of emission reduction.
The Agency indicated agreement.
This Opinion constitutes the findings of fact and conclusions
of law of the Board.
IT
IS THE ORDER of the Pollution Control Board that Petitioner
be granted
a variance from the provisions of Rule 203(b)
and
(c)
of Chapter
2,
Part II
of the Air Pollution Control
Regulations
until
July 15,
1974,
provided:
that Petitioner
shall
discontinue use of
the electric arc furnace used
in
the reclamation
of metallics from
the centerless grinding operation until
control
eauipment
is installed
thereon, bringing its emissions into compliance.
The data contained
in Petitioner’s report of additional
information, dated March
14,
1974,
is, hereby, deemed confidential
and not subject to disclosure by
the
Agency or this Board.
I,
Christan
L.
Moffett, Clerk of the Illinois Pollution Control
Board, certify that the abo e Opinion and Order was adopted
on
this
~“
day of__________________
1974 by
a vote of
‘~?—
0
—
704