ILLINOIS POLLUTION CONTROL BOARD

October 10, 1972

M & S WOOD AND PAPER CORP.     

)

v.

)

72—236

ENVIRONMENTAL PROTECTION AGENCY

William B. Powell, Attorney, for M & S Wood and Paper

Corp.

Dennis R. Fields, Assistant Attorney General, for the

Environmental Protection Agency

Opinion of the Board (by Mr. Currie):

M & S petitions for permission to utilize an air-curtain

destructor, outside of any restricted area, to burn not only

landscape wastes, as authorized by PCB Regs., Ch. 2, Rule

504(a) (4), but also other clean wood wastes such as lumber,

crates, and boxes. The evidence is clear that landfill dis-

posal has not proved a satisfactory alternative in this

case, and chipping for further use is impracticable because

of nails in the material that would harm the chipping equip-

ment. The testimony of the supplier is, as we found in

adopting the regulation, that a well-operated air-curtain

destructor burning material such as is here involved will

eliminate visible emissions except for brief and light smoke

during startup or loading. It is not known whether the

destructor can comply with the otherwise applicable

particulate emission standard for wood incineration of 0.2

grains per standard cubic foot of exhaust gas, PCB Regs.,

Ch. 1, Rule 203(e) (5), so we cannot very well require that

standard be met as the Agency requests; this is precisely

why a variance is requested. The ot1~rconditions recommended

by EPA have been accepted by M & S. 

Against the background of many cases indicating that

regulations forbidding open burning of wood refuse have been

all too often ignored, we find the ~esent proposal a healthy

one that promises substantial relief from the pollution of

uncontrolled open burning, As in Nickel v. EPA, ~7l-392,

4 PCB 105 (Mar. 28, 1972) 

we will grant the present variance

as an experiment to determine the adequacy of the air-curtain

destructor as a substitute for more expensive incinerators

in the burning of clean wood that does not qualify as landscape

wasted If the experiment proves successful, we shall be

pleased to entertain a proposal by the Agency to amend the

1   We note the Agency recommends allowing burning unless the

wind speed exceeds 25 m.o,h. We invite the Agency to reassess

this upper limitation and to inform us in future cases as to

its basis for concluding that opeiation at such hiqh wind

speeds will not create a fire hazard.

5

— 637

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the regulations to allow such burning, outside critical areas,

upon permit from the Agency. The Agency is invited to monitor

the emissions to determine whether or not the destructor proves

adequate for this purpose.

ORDER

Variance is hereby granted to M & S Wood & Paper Corp.

to burn certain wood wastes not constituting landscape waste

in an air—curtain destructor at its Boone County site until

October 10, 1973, subject to renewal on an annual basis upon

reapplication and proper proof, and subject to the follow-

ing conditions:

1. Only landscape wastes and cleaned unpainted lumber shall

be incinerated; all other lumber and debris shall be

separated prior to burning and disposed of by some other

fashion.

2. Petitioner shall notify the Agency’s Regional Office

(Rockford Regional Office, 4302 North Main Street, Rockford,

Illinois 61103, telephone 815/877—8051) prior to the

initial operation of the air curtain destructor to allow

Agency observation.

3. An operator must be in attendance at all times when trade

waste is being burned,

4. The feed to the destructor shall be adjusted so as to pre-

vent any visible emissions’from the destructor during

burning.

The material used to promote combustion shall be of no

lesser quality than number 2 fuel oil.

6. Burning shall be conducted only on days when the wind

velocity 

between 5 

and

25

miles

per hour.

Burning shall be conducted only between the hours of

8:00 A,M. and 4:00 P.M. (Central Standard Time).

Quantities of materials to be burned shall be restricted

to an amount which can be consumed within these hours.

8. The burning site shall be provided with adequate fire

protection and with such equipment as necessary to control

accidental fires,

Materials to be burned shall be limited to trade wastes.

10. The air curtain clestructor shall be operated in accordance

with the manufacturer s operating instructions.

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53R

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11, Petitioner shall within 35 days after receipt of this

order post a bond or other security in the amount equal

to the cost of the air curtain destructor, to be for-

feited upon violation by Petitioner of any condition

of the variance.

I, Christan Moffett, Clerk 

of the

Pollution Control Board~

cert Lv that ~rieBoard 

ad~ooted t-~ieabove

Ooinaor this________

day of October, 1972, by a vote of

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