ILLINOIS POLLUTION CONTROL BOARD
August 5, 1976
N & S WOOD & PAPER CORPORATION,
)
Petitioner,
v.
)
PCB 76—164
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION
AND
ORDER OF THE BOARD (by Mr. Goodman):
On May 26 1976, Petitioner M & S Wood and Paper Corporation
(M & S) filed a petition for variance before the Pollution Control
Board (Board). M & S seeks extension of a prior variance from
Rule 502(a) of the Air Pollution Control Regulations (Chapter 2)
in order to burn clean, untreated wood waste and landscape waste
in an air curtain destructor. The Environmental Protection Agency
(Agency) filed its recommendation on July 8, 1976.
N & S operates a paper recycling and wood reclaiming business
at a site in Boone County, one mile east of Belvidere, Illinois.
N & S originally obtained a variance to burn landscape waste
in an air curtain destructor during the latter part of 1972.
Since that time, N & S has sought and obtained several extensions
of the original variance and has gradually improved the operation
of its air curtain destructor. (See PCB 72-236, PCB 73-368,
PCB 74—243, and PCB 75—417.) N & S seeks to continue to burn
20 to 25 tons per day of wood waste which cannot be reused. All
wood to be burned will be clean, untreated and unpainted. M & S
plans to burn wood waste five days each week, from 8:00 a.m. until
3:00 p.m. The Agency recommendation indicates that a representa-
tive of the Agency observed the operation of the air curtain de—
structor and found it to be in a well maintained condition and
operating well.
The Agency recommendation suggests that emissions from burning
clean, untreated wood waste are quite similar to emissions from
burning landscape waste. The expected emissions from open burning
landscape waste as compared to using an air curtain destructor are
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as follows:
EMISSION FACTOR IN lbs/ton
Contaminant
Open Burning
With Air Curtain
Particulates
17
4.6
Carbon Monoxide
50
Not available
Hydrocarbons
4
0.25
Nitrogen Oxides
2
4.0
M & S has alleged that the financial costs of alternate
means of disposal are substantially higher now than they were in
the past, which creates an economic necessity for disposing of
the wastes in the air curtain destructor. The Agency has received
no complaints concerning N & S’s operations during the term of the
existing variance. The Board finds that the benefits from M & S’s
recycling operation outweigh any slight environmental damage
resulting from the grant of this variance and that, therefore
denial of the requested variance would impose an arbitrary and
unreasonable hardship upon Petitioner. Moreover, the Board adopts
the Agency’s recommendation that the variance from Rule 502(a)
be granted for a five-year period.
This Opinion constitutes the findings of fact and conclusions
of law of the Board in this matter.
ORDER
It is the Order of the Pollution Control Board that Peti-
tioner N & S Wood and Paper Corporation be and is hereby granted
variance from Rule 502(a) of Chapter 2 until July 1, 1981, in
order to burn clean, unpainted and untreated wood wastes in an
air curtain destructor, subject to the following conditions:
1. Petitioner shall maintain the housekeeping at its
facility so as to eliminate possibility of fires caused
by sparks igniting litter and nearby waste materials.
2. An operator must be in attendance at all times when
wood waste is being burned.
3. The feed to the air curtain destructor shall be adjusted
so as to prevent any visible emissions from the destructor
above 10 opacity.
4. Material used to promote combustion shall not be lower
in quality than #2 fuel oil.
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5. Burning shall be conducted only on days when the wind
velocity is between 8 and 40 kilometers per hour.
6. Burning shall be conducted only between the hours of
8:00 a.m. and 4:00 p.m.
7. The burning site shall be provided with adequate fire
protection and with such equipment as necessary to
control accidental fires.
8. The air curtain destructor shall be operated in accordance
with the manufacturer’s operating instructions.
9. Within 35 days of this Order, Petitioner shall execute
and forward to the
Control program Coordinator
Division of Air Pollution Control
220 Churchill Road
Springfield, Illinois 62706
a Certification of Acceptance and agreement to be bound
to all terms and conditions of the variance. The form
of said Certification shall be as follows:
CERTIFICATION
I (We), ___________________________________ having read and
fully understanding the Order of the Illinois Pollution
Control Board in PCB 76-164 hereby accept said Order and
agree to be bound by all the terms and conditions thereof.
Signed by
Title
Date
IT IS SO ORDERED.
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I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order were adopted on the
~
day of August, 1976 by a vote of ______________________
hristan L.
Illinois Pollution Coil Board
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