ILLINOIS POLLUTION CONTROL BOARD
November 15, 1973
MEDUSA CORPORATION,
Petitioner,
V.
)
PCB 73—337
ENVIRONMENTAL PROTECTION AGENCY,
Respondent
William H. Wallace, Attorney for Petitioner
Lee Campbell, Assistant Attorney General for the EPA
OPINION AND ORDER OF THE BOARD (by Mr. Henss)
Nedusa Corp~ration filed a Petition for Variance requesting
relief from Rules 202(b) (visual emission standard), 203(b) and
203(d) (3) (particulate standards) and 203(1) (compliance dates)
of the Air Pollution Control Regulations until March 31, 1975,
pending installation of air pollution control equipment at its
cement manufacturing plant located near Dixon, Illinois. A public
hearing was held on October 4, 1973.
At this plant, one of seven cement plants in the Medusa
cement division, Petitioner manufactures 10 different types of
cement and cement products. The plant began operations in l9fil
and currently has a manufacturing capacity of 3.2 million barrels
per year. Petitioner’s Dixon plant produces 30 of the cement
manufactured in Illinois and 15 of all cement consumed in
Illinois (R.89). An average of 183 persons are employed at the
plant which ooerates 24 hours a day year around.
Petitioner uses a dry manufacturing process for producing
portland cement. Limestone, clay, sand, power house slag and
gypsum are the principle ingredients. After being crushed,
dried and ground, the raw feed material is introduced into ~ne
of the four rotary cement kilns. The kiln heats the raw feed to
about 27000 F. by the combustion of coal and/or gas to convert
the calcium carbonate (limestone) to calcium oxide, a process
known as limestone calcining. The calcium oxide then combines
with the other raw feed ingredients to form “clinker”, the basic
component of cement.
The clinker is discharged to clinker coolers which, in this
case, are oscillating grates through which ambient air is passed
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to absorb heat from the clinker. Part of the heated air is
returned to the kilns for use as preheated combustion air.
Excess heated air is vented through dust collectors to the
atmosphere. The clinker coolers for kilns 1, 2 and 3 are
equipped with Buell L-R settling chamber type collectors. The
clinker cooler for kiln 4 is equipped with a Western—Precipi-
tation inulticlone.
Charles L. Howlett, Vice President of Operations, Cement
Division of Medusa Corporation, testified that the emission
control devices on the 4 clinker coolers provide efficient
control during normal operations but could not meet the regu-
latory limits during periods of kiln upset or control equipment
malfunction. Howlett testified that such upsets occur when
there are changes in the chemistry of the raw materials or fuel
or when the ratio of coal to gas is changed. The upsets result
in the raw material being “overburned” or “underburned”. When
overburning occurs, the clinker becomes molten and “goes over
the end of the kiln”. If the raw material is underburned, “the
raw mix doesn’t clinker and comes over the nose of the kiln in
the form of dust.. .tliat’s only partially calcined”. Howlett
estimated that such upsets occur during less than 3 of the
annual operating period.
Petitioner stated that emissions from the clinker coolers
“may exceed the Board’s emission standards” during periods of
kiln upset, but that measurement of emissions is impossible
during these brief periods. Using standard emission factors and
information from Petitioner’s operating permit applications, the
Environmental Protection Agency calculated Petitioner’s emissions
from the clinker coolers to be 433.6 lbs./hr. We were unable to
determine whether the Agency represented this figure to be emissions
during normal operations or during upset periods or the average
emission for all operations. Under Rule 3—3.111 of the Rules and
Regulations Governing the Control of Air Pollution, Petitioner is
allowed 112.58 lbs./hr. from the clinker coolers until December 31,
1973. After that date, Petitioner’s aggregate allowable emission
rate under Rule 203(b) of the Rules will be 47.37 lbs./hr.
Because the excessive emissions could not be controlled
before the December 31, 1973 compliance date, Petitioner’s appli-
cation for operating permits was denied by the Agency on April 2,
1973.
Petitioner previously held a variance while baghouses were
installed on the three preheater kilns (kilns 1, 2 and 3)
.
Some-
time during the Fall of 1972 Petitioner decided that baghouses
would also be required to control emissions from the clinker coolers
(R. 80) and $600,000 was budgeted for the project. Preliminary
engineering investigations began immediately and manufacturers of
control equipment were contacted in March 1973. The original
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proposal called for the installation of separate haghouses for
each clinker cooler to be located on top of the “burner building”
(R. 74)
.
Bids received in April 1973 caused Petitioner to re-
evaluate the project and to change the location and basic design
of the baghouses.
Petitioner
decided
to
install
one large bag-
house outside the burner buildinq and use duct work capable of
moving 185,000
cubic feet
of air per minute.
The large baghouse
will have two chambers for each clinker cooler,
so that one
chamber for each cooler can be in operation while the other is
being cleaned or repaired.
Revised proposals were sent out in September 1973 and
several bids have been received. Although Petitioner has not
yet made a final decision on
the
bids
the Meduse Corporation has
authorized the expenditure of $1,203,000 for thc project (Petitioner
Exhibit Jl-J2)
An EPA engineer investigating Petitioner’s plant on August 22,
1973 observed the startup of kiln ~l which had been down for
removal of a
mud ring.
Emissions from
the
clinker cooler appeared
to have an opacity of 100
at 10:30 a.m., but this had been reduced
to about 50
by 2:00 p.m.
Particulate
emissions from the other
operating clinker coolers appeared negligible.
Emissions from a
307’ stack venting the gasses from preheaters
#1,
2
and 3 were
observed to vary from 30~ to 50 opacity.
The Agency investigator
was informed that some of the bags in the baghouse were torn and
that this caused the high opacity readings.
The torn bags are
being
replaced.
The Anency has recommended grant of the variance but only
until September 1, 1974. Although the Agency is of the opinion
that Petitioner’s proposed program will bring the plant into com-
pliance with the
Regulations,
the Agency contends that Petitioner’
s
Project
Completion Schedule is unreasonably long. The Agency
position was based on a time table contained
in a
draft
copy
of
a U. S. EPA publication.
rl~hiS
draft publication
indicated that a
haghousc installation on a cement kiln could reasonably be expected
to take about 68 weeks.
Robert Goldberg, Manager of EPA’s Variance Section testified
that the proposed 9 month
period
for ectuipment fabrication and
delivery was excessive.
Goldberg stated that 26
weeks would be a
more realistic
time period (P. ill)
.
Four bids introduced
Lnto
evidence
support Goldberg’s contention and
in fact, show six months
as the maximum delivery period anticipated by any of the four
companies submitting bids. However, Goldberg added that
the Agency
had not been provided certain information when drafting
the
Recommendation which, if now considered,
could possibly alter
the
Agency position.
The missing information
pertained to electrical
hardware for which delivery was not as
predi ctable.
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The Agency presented two letters from citizens who felt
that Medusa should not
receive the variance. The letters
describe the soiling and damage to property experienced as a
result of the cement dust emissions. Mrs. Ralph C. Davis
stated that she dreaded to think what it would be like if
Medusa were granted a variance “which would increase their
emissions”. The variance, however, will not allow Petitioner
to increase emissions but only to continue emissions at the same
or lower rate pending installation of control equipment. We
would also advise Mr. L. H. Petersen that, contrary to his
understanding, Medusa was not asking until March 3, 1975 to begin
the project. One witness at the public hearing testified
about his experiences with the cement dust emissions. While he
opposed the granting of a variance, he stated that his problem
would not justify closing the plant.
Testimony and letters in favor of granting the variance
caine from the Illinois State Toll Highway Authority, the mayor
of Dixon, the Dixon Chamber of Commerce, managers of Ready—Mix
Concrete plants, the Union secretary representing workers at
the plant, employees and others. A summary of this testimony
would show that the loss of cement produced by Medusa at its
Dixon plant would severely damage the road construction industry
in Illinois, On the whole, Medusa was characterized as a good
industry and good neighbor for the Dixon community and as an
industry that has shown good faith over the years in trying to
control its emissions.
Petitioner also introduced several documents which purport
to show cement dust is not a lung irritant and that inhalation
of cement dust is harmless to the lungs and to general health.
The Agency did not respond to this point.
Petitioner did not request variance from Rule 3-3.111 of
the Rules and Regulations Governing the Control of Air Pollution,
which Rule is applicable to the plant’s operations until
December 31, 1973. The Company is allowed higher emissions under
Rule 3-3.111 than will be allowed under Rule 203(b).
From the entire record, we believe Petitioner should have a
variance. A denial of variance could cause substantial hardship
to Medusa and others in the State far outweighing environmental
damage caused by plant operations. We shall grant the variance
but only until November 15, 1974, since that is the limit allowed
by Statute. If additional time is required, Medusa should file
another variance request at least 90 days prior to the expiration
date of this variance. An extension of this variance should not
be considered automatic. Petitioner shall have to prove to this
Board that it has diligently pursued the compliance plan and
project completion schedule that we approve today.
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ORDER
It is
the
order of the Board that:
1. Medusa Corporation is granted variance from Rules
202(b), 203(b), 203(d) (3) and 203(i) of the Air
Pollution Control Regulations for four (4) clinker
coolers at its Dixon cement manufacturing plant
until November 15, 1974 pending installation of a
haghouse to control particulate
emissions from the
four clinker coolers.
2.
Medusa shall, by December 20, 1973, post a bond in
the amount of $100,000 in a form acceptable to the
Environmental
Protection
Agency, such bond to be
forfeited
in the event the baghouse control device
is not installed
as described during these proceedings.
The bond shall be mailed to Fiscal Services Division,
Illinois
EPA, 2200 Churchill Road, Springfield,
Illinois
62706.
3. Beginning January 1, 1974, Medusa shall subiait
quarterly progress reports to the Variance Section
of the Environmental Protection Agency. Such reports
shall detail all progress toward comaletion of the
clinker cooler baghouse project.
4. Medusa shall attempt to expedite completion of the
baghouse project and shall renort such efforts in
its quarterly report to the Agency.
5. Medusa shall apply for all necessary construction
and operating permits for its Dixon plant.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control Board,
hereby certify the above Opinion and Order was adopted this
J~~’ day of
_______
1973 by a vote of ~ to ~
/
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