ILLINOIS POLLUTION CONTROL BOARD
September 27, 1974
DEERE AND COMPANY
)
Plow and Planter Works,
)
Petitioner,
)
vs.
)
PCB 74-249
ENVIRONMENTAL PROTECTION AGENCY,
)
Respondent.
OPINION AND ORDER OF THE BOARD (by Mr. Seaman):
On July 2, 1974, Deere and Company filed its Petition For Variance,
seeking therein a one-year variance from the provisions of Rule
2O4(f)(2) of the Board’s Air Pollution Regulations. Petitioner
operates a modern farm equipment assembly facility in Moline, Rock
Island County, Illinois, and employs approximately 3,000 persons.
Petitioner’s facility is located in a primarily industrial area with
residences approximately 300 feet to the south.
The subject of this Petition For Variance is a sulfuric acid
dip tank, part of a nickel chrome plating system presently being
constructed by Petitioner. Petitioner is requesting a one-year Variance
from Rule 204(f)(2) as applied to the installation of control equipment
for this nickel chrome plating system.
Petitioner’s assembly facility includes the following major
emissions sources: 2 cupolas, sand handling equipment, metal grinding
operations, sand blasting operations, cleaning and plating operations,
and surface coating and dipping operations. Petitioner has operating
permits for the above-mentioned sources. The application for a
construction permit for the nickel chrome plating line in question was
denied on June 19, 1974. The new plating line, including the sulfuric
acid dip operation, consists of 14 tanks, 3 scrubbers for control,
associated ducting and other equipment.
Raw material useage for the sulfuric acid dip operation is 1500
gallons of 21 H2S04 for six weeks of operation. Only water is added
to the tank to maintain levels during the six week period. At the end
of six weeks the tank will be dumped and fresh acid added. The spent
acid will be disposed of at a landfill. The emissions from sulfuric acid
dip operations in plating lines are in the form of a sulfuric acid
mist composed of vapors and small droplets. Agency calculations indicate
acid mist emissions from the scrubber stack will be 5.0 lb/Ton (average)
and 6.7 lb/Ton (maximum), This exceeds the allowable of .15 lb/Ton
specified by Rule 204(f)(2).
13—697
The Petitioner does not question the action of the Agency in
denying its permit application, but does question the appropriateness
of the involved regulation. Petitioner
submits
that this position
is supported by the fact that the Agency has submitted a proposal
for amending the regulation now pending as PCB R73~~l7. Petitioners
proposed control system for this installation will limit its acid
mist emissions to below 0.1 lb./hr., which Petitioner believes will
not have any measurable affect on the environment in the Quad City
area.
Petitioner believes that there is
no method yet developed to meet
Rule
204(f)(2) as now written. This is because Petitioner is attempting
to reduce acid use and total acid emissions by plastic tube tank
covers to minimize the escape of acid mist into the collector, so that
the use of acid is very small and essentially all that is used goes
to the collector. However, to comply with the current regulation, the
acid mist collection efficiency would have to be:
L
20000.15 lbs.lb.
acidaciddischargedused
~
(100) 99.9925
Petitioner states that acid mist collectors do not operate in this
efficiency range, leaving the Petitioner without remedy. Petitioner
alleges that it needs this installation in order to plate parts such
as those used in~hydrau1icsystems on Petitioners agricultural and
industrial equipment products.
This plating system will give Petitioner capacity to plate long
hydraulic cylinder rods which must now he sent to an outside concern.
Under current procedures, Petitioner machines
and hardens the rods,
which must then
he hauled under very carefully controlled conditions,
to prevent
rust
and damage, to
an
outside plater. The rods are then
returned to
Petitioner and fed back into the manufacturing process.
Petitioner
has experienced considerable difficulty with the quality
control of outside platers and has been unable to find
platers with
adequate capacity to handle its requirements. Petitioner alleges that if
it is unable to operate the proposed installation and still continues
to use its outside vendor, Petitioner will not be able to meet its
minimum needs of plated hydraulic cylinder rods after Deceiiber, 1974.
Petitioner states that it has searched unsuccessfully for Iowa
platers capable of picking up this plating load and that to go further
than Iowa or Illinois would not only result in considerable increase
in hauling expense, but also would use extra energy to complete the
transportation process and use extra resources to compensate for the
cylinder rods inadequately protected against weathering while in transit.
13
693
-3-
Petitioner states that the proposed installation represents
the hi~estlevel of air pollution control that can be achieved
under present technology. At-source control is provided by the
use
of bath covers, and a scrubber is used to reduce sulfuric acid
emissions. Scrubber efficiency is improved by also including
fume control of the NaOH bath to approach a neutral pH condition
in the scrubber and achieve a higher efficiency than if only the
sulfuric acid tank emission were controlled.
We are disposed to grant the variance requested until March
31, 1975, or until thirty days from the date the Board takes final
action on R 73-17, whichever first occurs. Thereafter, the Board
will be in a better position to assess Petitioner’s problem if such
still exists. Haiever, we will, during the period of this variance,
require that Petitioner limit its emissions of acid mist not to
exceed 0.1 lbs/hr.
This Opinion constitutes the findings of fact and conclusions
of law of the Board.
IT
IS ThE ORDER of the Pollution Control
Board
that Deere and
Company
be granted a variance from the provisions of Rule 204(f)(2)
of the Air Pollution Rugulations until March 31, 1975, or until thirty
days from
the date that this Board takes final action on R 73-17,
whichever
first
occurs, subject to the condition that Petitioner shall
limit
its emissions of acid mist to less than 0.1 lbs/hr. for the
period of this variance.
I, Christan 1. Moffett, Clerk of the Illinois Pollution Control
Board, cçrtify that the above
Opini n an Order
was
adopted on this
0)”
day of’~A$
,
1974 by a vote
of
SeC
.
6’
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