ILLINOIS POLLUTION CONTROL BOARD
January 17, 1974
OLIN CORPORATION,
Petitioner,
vs.
PCB 73—450
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
Thomas B. Martin, Attorney, on behalf of Petitioner.
Thomas R. Casper, Attorney, on behalf of Respondent.
OPINION AND ORDER OF THE BOARD (by Mr. Seaman):
On October 25, 1973, Olin Corporation filed its
Petition for Variance, seeking variance from the provisions
of Section 9(a) of the Illinois Environmental Protection
Act and Rule 3-3.112 of the Rules and Regulations Governing
the Control of Air Pollution (establishing particulate
emission limitations) until March 31, 1974.
Petitioner operates a facility, consisting of an area
of approximately 1,732 acres at East Alton, Madison County,
Illinois, wherein it manufactures brass strip and fabricated
products, metallic and shot shell ammunition a’~doperates
a steam generating plant and a potable water treatment
plant. Approximately 5,700 employees are currently employed
at Petitioner’s East Alton facility.
Petitioner’s power plant consists of two 75,000 lbs/hr
boilers and two 150,000 lbs/hr boilers. The two 150,000
lbs/hr boilers are operated to supply the necessary steam
load during normal operations; the two 75,000 lbs/hr boilers
are maintained in wet lay up and are not operated Linless
there occurs an outage of one of the primary boilers.
All of the boilers have the capability of using either
natural gas or coal, or both, as a fuel supply. However,
one of the primary boilers must have 80 of its rated output
supplied by coal firing before natural gas can be used to
supplement the coal when both fuels are fired simultaneously.
10— 697
—2—
This is due to its pressurized continuous stag
tapping
wet bottom design.
Petitthner’ s natural gas supply can
be supplemented with propane-air mixtures up
to
125,000
CFH of natural gas equivalent by a Propane—Air Plant owned
and operated by Petitioner.
Petitioner alleges that it has made
every
possible
effort to insure that it will have adequate, clean fuel
supplies during the 1973-74 winter heating season to
sustain operation of its facility. However, Petitioner
states that factors completely beyond its control
—
the
recent, unexpected Federal embargo on propane; the uncertainties
regarding the amount of curtailment of natural gas; and the
shortage of l~w ash coal
-
have placed Petitioner
in a
position in which it is probable that it will be in violation
of the present particulate emission regulations during the
1973—74 winter season.
Petitioner’s natural gas suoply has been unexpectedly
curtailed for the first time. This curtailment was to levels
as low as 30 of the original contract demand of 10 million
cubic feet per day. On October 2, 1973, the Energy Policy
Office placed in effect the Mandatory Propane Allocation
Program. Petitioner asserts that this program may have a
severe affect on its estimated requirements of propane for
the 1973-74 heating session.
For example, Petitioner has been
required to sell 1,100,000 gallons of propane because it
was
being held in storage for Petitioner. Finally, Petitioner
has been able to acquire only 8,000 tons of low ash coal
for this season. Illinois coal having an ash content of 10.18,
a heating value of 11,286 BTU/lb, and a sulfur content of
3.18~ is expected to be available as required.
The Agency is of the minion that Petitioner has made a
good faith effort to obtain complying fuels. The Agency
recommends that should the quantities of natural gas, propane
and low ash coal obtained
be
insufficient
to meet Petitioner’s
requirements,
then Petitioner
should be permitted to use high
sulfur—high ash coal even
if the limitations of Rule 3-3.112 are
thereby exceeded.
As a result of the anticipated fuel shortage, Petitioner
has retained engineering consultants to determine the pollution
control equipment which will be required in order to achieve
compliance wIth the new particulate regulations (Rule 203(g)) when
high sulfur coal is employed. Petitioner’s new compliance
program indicates compliance by
May 30,
1975. During the Agency
Investigation, agents of Petitioner indicated that Petitioner
will
probably utilize flue gas scrubbing using a caustic
solution and Petitioner~s sewage
treatment plant to handle the
—3—
scrubbing solution. The Agency is of the opinion that
this program could achieve complaince with both Rules
203(g) and 204 and that the time schedule is reasonable.
The Agency has received no objections to the granting of
this variance from the public.
We are of the opinion that Petitioner has exercised
good faith in its efforts to obtain complying fuels under
extraordinary conditions and that its current problems are
not self-imposed. We note also that Petitioner has had
the foresight to develop a system of fuel use which will
keep violations to a minimum in the event that high sulfur-
high ash coal must be used. The variance will be granted.
However, Petitioner’s statements regarding environmental
impact are quite meager, and Petitioner is hereby put on
notice that a more substantial treatment of this area will
be necessary should Petitioner !equest an extension of the
instant variance.
This Opinion constitutes the findings of fact and
conclusions of law of the Board.
ORDER
IT IS THE ORDER of the Pollution Control Board that
Petitioner, Olin Corporation, be granted variance from Rule
3—3.112 until March 31, 1974 to operate the power plant at
its East Alton facility, subject to the following conditions:
1. Petitioner shall utilize gas, propane and
low ash coal as much as possible to maintain
compliance with Rule 3—3.112;
2. Petitioner shall report, in writing,to:
Illinois Environmental Protection Agency
Division of Air Pollution Control
Control Program Coordinator
2200 Churchill Road
Springfield, Illinois 62706
on February 1, 1974 and March 1, 1974 the amount
of propane, natural gas and coal burned in its
boilers and the amount of propane, natural gas
and coal available to Petitioner;
3. Should Petitioner seek an extension of this
Variance for the 1974-75 winter, Petitioner
shall submit a compliance program indicating
compliance with Rules 203 and 204 for its boilers
by
May 30, 1975,
—4—
IT IS SO ORDERED.
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, certify th~tthe thove Opinion and Order
was adopted on this
/ 1
day of
______________,
1974
by a vote of
~
.
(3
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