ILLINOIS POLLUTION

CONTROL

BOARD

March 28, 1972

IMPERIAL SMELTING CORPORATION

v.

)

PCB 71—393

ENVIRONMENTAL PROTECTION AGENCY

MR. MAYNARD B. RUSSEL, of Maragos, Richter and Russel, appeared

on behalf of Imperial Smelting Corporation

MESSRS. DOUGLAS T. MORING and LEE CAMPBELL, Assistant Attorney

Generals, appeared on behalf of the Environmental Protection

Agency

OPINION OF THE BOARD (by Mi. Kissel):

Imperial Smelting Corporation (“Imperial”) operates a

secondary zinc processing facility in Chicago, Illinois. Imperial

filed its petition for variance on December 30, 1971 in which it

requested until June 30, 1972 before complying with particulate

emissions found in Rule 3-3.111 of the Rules and Regulations

Governing the Control of Air Pollution. In its petition, ImDerial

not only outlined the program which it alleged would brinq i~into

compliance with the existing regulations, but added that it would

operate its facility at a “reduced capacity with select rnaterial

and that it would not “operate at peak capacity until its pollu-

tion control programu is completed and operating in that “it can

handle such capacity without contaminating the environment.” The

Agency recommended that the variance be granted on certain condi-

tions, namely, that Imperial file bi-monthly reports, obtain per-

mits from the Agency, do stack testing after program conDietion

to insure that the Regulations would be met, and file a bond. A

hearing was held on the petition on February 15, 1972, before

Melvin Lewis, Hearing Officer.

In its Chicago operations, which constitute the subject of

the petition for variance, Imperial utilizes 14 furnaces. Two of

the units are rotary “sweat’1 furnaces and twelve are cast iron

kettle furnaces. Basically, the Imperial operation consists of

purchasing and receiving scrap metals which are melted down in

the various furnaces so that various metals are separated. These

metals are then sold for reuse by industry.

Presently, Imperial has some pollution control equipment

operating on its furnaces. There is a 95 efficiency wet scrubber,

which receives the off-gases from eight of the kettle furnaces. By

Jmperial’s own admission, this scrubber has not worked very well,

---

and

it

may

be that it will have to be replaced by a baghouse, or

some other device. One of the

rotary

furnaces (the newer one,

installed in 1969) has a baghouse which receives the off-gas. But

it too hasn’t worked very well. The bags were clogging up and,

as a result, the

amount

of air passing through the baghouse was

diminished. The other furnaces at Imperial’s plant contain no

pollution control equipment.

Imperial’s plan is to install new Dynaclone baghouses (which

are desinged to collect 99 of the particulate matter) on the two

rotary furnaces, to install after burners to burn off the hydro-

carbons and to provide a settling

chamber

to collect the larger

particles.

One

of the baghouse-after burner-settling chambers

will also receive the off-gas from three of the kettle furnaces.

Thus, when completed, Imperial’s operations will have the baghouse-

after burner-settling

chamber

receiving the off-gases from the

two

rotary furnaces til

and

three kettle furnaces, the wet scrub-

ber will continue to receive the off—gas from eight other kettle

furnaces,

and

the remaining kettle furnace will not be

As stated in the petition, Imperial will operate at a re-

duced rate of production until the control equipment is installed.

This will mean that Imperial will, use

less objectionable material,

and

that the amount of particulate emissions will be reduced.

It

is apparent from the emission factors used by the Agency

in calculating the emission rates of Imperial’ s furnaces that

Imperial is violating the particulate regulations. The calculations,

which

appeared as part of the

Agency

recommendation

and

were made

a

part of the record by stipulation of the parties, showed that

the combination of the

two

rotary furnaces will emit 34.64 pounds

of particulate per hour, and that the allowable enission rate is

28.12

pounds per

hour.

Similar

figures are

shown

for the kettle

furnaces. It is also apparent that if the

wet

scrubber were effi-

ciently operated and if the baghouse-after burner-settling chamber

worked up to snuff, (99 collection efficiency) Imperial will meet

the existing particulate regulations after the equipment is installed.

Based upon the record in this proceeding, we believe that

the variance should b&granted. Imperial is asking for a relatively

short period of tine (until June 30, 1972) to correct a problem

which, while it is in violation of the regulations, has not been

causinq a problem in the surrounding community. If we were to deny

Ill

The

present baghouse on the newer

rotary

furnace will

4—lie

---

the variance, Imperial, according to their testimony, would have

to close the faci,jy until the equipmi~ntis installed, thus

putting 70 peoplet

J

out of work for a period of tine, and the

benefit to the public in closing the plant is simply not worth

that

economic cost.

The Agency agrees that the

variance

be

granted, and asks

that

we impose

certain conditions as previously outlined, We

agree with those conditions

and

therefore will require the following:

1.

Reports be sent to the Agency every month until

the project is

completed.

This will insure the Agency’s right to

know how

2.

from the Agency.

This

will only be required where such

permits

have

not already been obtained. Exhibits

*1 and *2 in

the record

are permits

issued by the Agency to Imperial,

and are not modified

or cancelled

by

this

order.

3.

Stack

tests

will be

required by

Imoerial.

This is necessary so that the Agency and

Imperial know

whether

the equipment installed 1.s in

4.

A bond of $10,000 will be required.

Since most of the purchasing is complete,

the

bond will be small since the entire program cost is

$125,000.

11 Imperial employs 45 people at this plant and 25 at

another outside Chicago. Closing the Chicago operation would

4—lit

---

ORDER

Based upon the record and the exhibits in this proceeding,

the Board hereby grants to Imperial a variance from Rule 3-3.111

of the Rules and Regulations Governing the Control of Air Pollu-

tion until June 30, 1972, upon the following conditions:

1.

Imperial shall diligently pursue the installation

of the control equipment outlined in its petition for variance

and the record in this cause.

2.

Imperial shall operate at a reduced rate of pro-

duction as described in its petition and the record in this cause,

until the operation of the above described control equipment.

3.

Imperial shall submit written reports to the Agency

each month until the above described control equipment is installed

and operating. The first report shall be filed within twenty (20)

days of the date of this order. In addition, Imperial shall

submit a final report to the Agency within thirty (30) days after

the described control equipment is operable.

4.

Imperial shall perform stack tests on each piece

of control equipment after said equipment is operable. The

results of said tests shall be certified by an independent

testing firm and shall be made a part of the final report re-

ferred to in paragraph 3 of this order.

5,

Imperial shall file with the Environmental Protection

Agency a performance bond or such other security as the EPA may

deem appropriate in the sum of $10,000 to guarantee installation

and performance of its control equipment in compliance with this

Order.

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

certify that the Board adopted the above Opinion and Order this

_____

day of March, 1972, by a vote of

________

~1;

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