ILLINOIS POLLUTION CONTROL BOARD
August 5, 1976
LINDBERG CORPORATION,
Petitioner,
v.
)
PCB 76—91
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by Mr. Goodman):
On April 2, 1976, Petitioner Lindberg Corporation (Lindberg)
filed a variance petition before the Pollution Control Board
(Board) requesting variance
from
Rules 103(b) and 203(a) of the
Air Pollution Regulations (Chapter 2). On May 4, 1976, Lindberg
submitted an amended petition in response to an Interim Order of
the Board. The Environmental Protection Agency filed its
recommendation on July 20, 1976. Lindberg has filed a waiver of
the 90—day rule until August 12, 1976. No hearing has been held
in this matter.
Lindberg operates a facility in Melrose Park which heat
treats a wide variety of metal items per customer specifications.
Lindberg’s operations include a salt heat treating operation con-
sisting of three lines. Lindberg is requesting variance from the
permit requirement of Rule 103(b) and the particulate emission
limitation of Rule 203(a) of Chapter 2 for its salt heat treating
operation.
Stack tests conducted for Lindberg by National Loss Control
Service Corporation in November 1975 indicate the following average
emission rates from the three lines:
neutral salt lines
2.04 lb./hr.
cyanide salt line
0.95 lb./hr.
Tufftride line
0.78 lb./hr.
Total
3.77 lb./hr.
Rule 203(a) of Chapter 2 limits emissions from the salt heat
treating operation to 0.55 lb./hr. Lindberg’s plan for achieving
compliance is two-fold. Lindberg is currently evaluating a proto-
type Universal Oil Products multiclone system which has been in—
23
—
237
—2—
stalled. If the niulticlone achieves 85 compliance efficiency,
an order will immediately be placed for a permanent installation,
with final compliance scheduled for September, 1977. If, however,
the test results of the multiclone are not favorable, Lindberg
will then install a prototype Flex-Kleen dust collector utilizing
bag filters. Assuming that the dust collector is found to be ac-
ceptable, a permanent dust collector would be installed by February,
1978.
As an interim measure, Lindberg indicates it will keep par-
ticulate emissions at the lowest possible levels by maintaining a
graphite layer on the cyanide salt pots to blanket particulate
emissions. When quenching Tufftride loads, Lindberg will attempt
to air quench the work before water quenching, which will
reduce particulate drive—off. Lindberg also intends to pre-
clean work whenever possible to reduce oil burn-off during
preheat cycles.
Lindberg’s facility is located in a highly industrialized
area. The nearest residences are located approximately one—half
mile to the south. The total suspended particulates in the
vicinity are below the primary ambient air quality standard of
75 ug/m3, as indicated by the following 1975 air quality data
for the nearest
testing
stations:
Annual
Station
Distance
Direction
Geo. Mean
Franklin Park
4 miles
North
70 ug/m3
River Forest
2 miles
East
67 ug/m3
Hillside
3 miles
Southwest
68 ug/m3
Apparently, Lindberg’s delay in compliance is due to technical
difficulties it has faced. The Agency recommendation indicates
that Lindberg’s operation was previously controlled by a scrubber,
but the scrubber had to be discontinued due to contamination of
the scrubber effluent with cyanide.
The Board agrees with the Agency’s conclusion that, due to the
technical difficulties Lindberg has faced and the solution it has
now seemingly reached, denial of the variance from Rule 203(a) would
constitute an arbitrary and unreasonable hardship.
Lindberg requests variance through March, 1978. However,
the variance will only be granted until September 1, 1977
-
the
date that the first alternate control program is due to be com-
pleted. If Lindberg finds that it must utilize the second alter-
nate control program, it can then petition the Board for an extension
of the variance granted herein.
23
— 238
—3—
The Board denies Lindberg’s request for variance from the
operating permit requirement of Rule 103(b). Rule 103(b) (6) (a)
specifically provides for the granting of a permit to applicants
who have received a variance from the Board. Lindberg is hereby
granted variance from Rule 203(a) until September 1, 1977.
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:
1) Petitioner Lindberg Corporation is hereby denied variance
from Rule 103(b) of Chapter 2.
2) Petitioner is hereby granted variance from Rule 203(a)
of Chapter 2 until September 1, 1977, subject to the
following conditions:
a) Within 14 days of this Order and monthly before
the 15th day of each month thereafter, Petitioner
shall submit written reports to the Agency de-
tailing all progress made toward final compliance
with Rule 203(a) of Chapter 2. Said reports shall
be sent to:
ENVIRONMENTAL PROTECTION AGENCY
Division of Air Pollution Control
Control Program Coordinator
2200 Churchill Road
Springfield, Illinois 62706
b) Within 120 days of this Order Petitioner
shall obtain all necessary construction
permits for control equipment and all necessary
operating permits for the salt heat treating
lines and associated control equipment.
c) Within 35 days of the installation of the
control equipment, Petitioner shall have a
stack test conducted in accordance with U.S. EPA
Method 5 (State of Illinois Stack Sampling Memo,
filed with the Secretary of State, July 1, 1975),
by an Agency approved independent testing
company. Petitioner shall notify the Agency
in writing at least 7 days prior to the test-
ing and shall allow Agency personnel to witness
23
—
239
—4—
all tests and review all results. Written noti-
fication shall be made to:
ENVIRONMENTAL PROTECTION AGENCY
Division of Air Pollution Control
Field Operations Section
1701 South First Avenue
Maywood, Illinois 60153
d) During the period of the variance, Petitioner shall
adhere to its project completion schedule as specified
in its original Petition for Variance, dated March 30,
1976, which is incorporated by reference as if
fully set forth herein, and shall follow all interim
measures specified in the variance petition.
f) Within 35 days of this Order Petitioner shall
execute and forward to the Control Program
Coordinator, 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 76-91 hereby accept
said Order and agree to be hound by all of the terms
and conditions thereof.
Signed by
_____________________
Title
_______________________
Date
_________________________
The Certification shall be sent to the address
specified in paragraph 2(a)
,
supra.
Mr. Dumelle Dissented.
23
—
240
—5—
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
4 -i
Illinois Pollution Cont
23
—
241