ILLINOIS POLLUTION CONTROL BOARD

September

2~),1977

IN THE MATTER OF:

PARTICULATE EMISSIONS

)

R76-5

FROM AIR FURNACES

OPINION OF THE BOARD

(by Mr. Goodman):*

The Proposal for Regulatory Amendm~::

~in

this matter was filed

by Deere

& Company

(Deere)

on February

204

1976, accompanied by the

signatures of

niore than 200 citizens requesting its consideration

and adoption.

Ill.

Rev.

Stat.,

Cl-i.

111—1/2,

§1028

(1977);

Iii. PCB

Regs.,

Ch.

1,

§204(a)(1977).

The Board authorized hearings on Deere

& Company~sProposal at its regular meeting of February 26, 1976.

In addition the Board Ordered publication of R76—5 in Environmental

Register #120, published February 27,

1976.

On July 12,

1977,

the

Board was notified by Deere

& Company that Deere had sold the foundry

formerly called the John Deere Vermilion Works to the Vermilion

Iron

Corporation.

Inasmuch as the Proposed Regulatory Miendment in this

matter concerns only the air furnaces

located in Hoopeston,

Illinois,

the Board hereby accepts the Vermilion Iron Corporation as Alternate

Petitioner in this matter.

The Board conside::s this proposal to be

site—specific.

As such,

only two hearings were held,

one on the

merits of the proposal in general and one on the economic impact

study, both in Hoopeston.

At the first hearing on this proposal held in Hoopeston,

Illinois

on June

8,

1976, Petitioner proposed certain changes in the Amendment

Petition.

Because these changes resulted

in

a more restrictive stand-

ard, the Board did not provide for notice of the proposed changes and

will hereinafter address itself to the proposal as presented at the

June

8,

1976 hearing.

The Petitioner herein proposes

to amend Rule 203(d)

of Chapter

2, Air Pollution Control Regulations, by adding a new Part 9.

Part

*The Board wishes to thank Roberta Levinson-Sirota, Attorney, Hearing

Officer in this matter,

for her assistance in the preparation and

drafting of this Opinion.

~2G

—

C55—

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—2—

(d)

of

Rule 203 lists exceptions

to Rule 203(a),

203(b)

and 203(c),

Particulate

Emission Standards and Limitatlons~ Petitioner asks that

Rule 203(d)

be amended as follows:

(9)

Certain Small_Iron—Melting Air Furnaces.

Rules

203(a),

~

to iron-melting air

furnaces if all the following conditions are met:

(A)

The air furnace was in existence prior to April

15, 1967; and,

(B)

The air furnace process weight rate is less than

or equal to 5,000 lb/hr;

and,

(C)

The air furnace as of

_____

(the effective date oT~Iss~pa~rapFi37eitier~

Ci)

is in compliance with the following Table

2.2.1;

or

(ii)

is

in compliance with the terms and conditions

of a variance granted by the Pollution Control

Board, and construction has commenced on equip-

ment or modifications sufficient to achieve

compliance with Table 2.3,l~

Table 2.3.1

Allowable Emissions From Small Iron-Melting

Alr Furn~~overedb

Rul

03(d)(9)~

Process Weight Rate

Allowable Average

Pounds

Emission Rate

Per Hour

Pounds Per_Hour

1,000

6~10

2,000

9~40

3,000

12.70

4,000

5,000

The average emission rate

is computed by dividing

the sum of the emissions during operation by the

number of hours of operation, excluding any time

during which the equipment is idle.

---

For

process weight rates listed in

La ?

2.3.1,

straight line interpolation betweei two consecu-

tive process weight rates shall be use

to determine

allowable average em scion rates.

The

particulate emission~ r

t

~

air furnace melting facili—

ties located

in Hoopeston,

ll~~

~‘

~-eenthe subject of

a number

of variance

petitions filed before Ue ~oard, starting in

1973.

Pur-

suant to

Board Orders in PCB

73 88 and PU3

14~

19, granting

variance

from Rule

203,

Deere

& Compary spent substanfial sums for

conversion

from coal

to oil-firing, ins~aLlatior~f afllrburners,

experimentation

with various

baffles,

and experirenta~~i

r

‘~i

firing rates

of the air

furnaces

in

an effort to comply with tnc Iec~ulations.

As

a result of

the Board

Order in the tnird variance pr

ting,

PCB 74-469,

addi-

tional

substantial sums were spent upon

-~

search and

Development

Program

conducted by A

T.

Kearney,

Inco ~ rated.

A fourth

variance

proceeding,

PCB 75-506,

is now pending before the Board.

Exhibit

8

contains the A,T. Kearney,

incorporated, Air

Furnace

Emission

Control Research and Development Program final

report.

The

report

concludes that particulate

a. i~sionrates

in excess

of the

levels allowed

under Rule 203(a)

are the result of variations

in

certain

parameters that cannot be readily controlled or

predicted.

These

parameters include charge composition, heat size,

melting cycle

time, firing

rate, and alloy and other additions.

Kearney

investi-

gated possible

changes in furnace design and operation

to determine

2G-~~7

The

subject of this Petit~o. is the melting facility

of the

malleable

iron foundry located in Hoopeston

illinois, known as

the

Vermilion

Iron Corporation.

This faciill

consists of two

air

fur-

naces used

for melting in the production c~mall

ble iron

castings,

with current

practice dictafing the uss

each ~urnace on

alternate

weeks.

Due

to the unique operational ~

er stics of air

furnaces,

there is grave

doubt as t~the ability

nt

I the emissions

to meet

Rule 203 and at the same time

it

i

the metallurgical

requirements

of the melting proce~s. A

u.

gh

aced extensively

to

produce

malleab’le iron in the past, a~

ir furnace today is

a rela-

tively rare

hot metal producing piece o

equipment.

As

such, there

is very

little abatement technology wh

n can be directly

applied to

the air

furnace~srather u usual Opei~

.g characteristics.

Unfortu-

nately

the metallurgical control of

~u~nace is

dependent upon

control of

the air flow within the

ta

e,

wnich makes

a direct

connection

to the normal furnace a~

cnt

equipment

very

difficult

(R. 105).

---

their

effect on

the rate of ernss~ocsprcJn~dduring melting.

It

is

the company~sbelief that roae ~f the possibie changes would have

sufficient

effect in

lower~rg

tie earission fates so as to meet

thee

requirements

of

Rule

233(a),

The report

further concludes

that

a

dry

centrifugal

collector

-iould

r

cult

in

collec.ion

of

a

sufficient

percentage

of

the

particulat~

mi~sions

to

rcduc-~. the

level

to

an

acceptable amount

but

would

rave

an

estimated

cost

of

$159,000.

In

addition,

it

is

estimated

tia

-

the

centrifugai

collector

would

in--

crease

the

cost

of

produllng

~-astJrgs

by

an

amount

estimated

to be

$58.00 per

ton,

a

very

signifi

art

increase

in

t~ital

cost

of

produc--

tion.

The

cost

of

installing

alternati

-

melting

equipment

such as

induction or

electric

arc

~ureaces

was

~o~~-acito

be

too

high

to

justify

at the present

level

of

,

oductron,

In

illusion

the

report

suggests

that, because

achieving

onpiiance

siti

~

e

203(a)

would

require the

expenditure of a

very

large

can

of

monej

to

collect

about

50

pounds

of

particulate

~emissions

per

3oy

and

bc~ause the

ose

of

an

air

furnace

in

an

iron

foundry

is

very

rare

and

is

not

governed

by

the

same

considerations

governing

oticr

sources,

tiis

operation

should

be

regu-

lated

under

an

appropriate

anerage

dail~

emission

level

rather

than

under the

hourly

peak

requiremerts

ixppos~d by

Rule

203(a).

In

response

to

a

Boarf

Order

-n

~

74ll69,

Deere

submitted

evidence

indicating

compliance

o~

~te

Illopeston

area

with

the

national

ambient

air

quality

standards

n

tic

~osence

of

monitoring

data for

Hoopeston,

Deere~s

approach

i-as

rceptei

by

the

Board

as

a

sufficient

showing

in that case.

Altl’oug

~-eires methoc of determination of the

ambient air quality in PCB 74—4

9 was crude and inconclusive, the

rural nature of the Hoopeston

~ea and the

esalts from the nearest

monitors

indicate that there

s not a significant air quality problem

(Ex,

6).

Since there does not appear to me other air furnace iron

melting

equipment in

the State of Illinois and since

this Regulation

will be confine

to

the Hoopest

r. area

in any event

the Board finds

that promulgation

of

the pr~posedregulatinrn would have no signifi-

ôant environmental

effect-

on

the

3tate

P

184).

That

the

citizens

in

the Hoopeston

area

support

~he

continued

operation

of

the

foundry

is

sufficiently established

tne reco~—d

ii PC~3 74-469, wherein a

Petition signed by

over i,llO oersons and ~ome

350 letters

from resi-

dents of

Hoopeston were received bj the Board.

Although

the Agency

attended

both hearings herein and cross-~examinedPetitioner~s

witnesses,

there has been no chaleage

my the Agency to the evidence

presented by

Petitioner

in this proc~eding.

On

July 26,

1917

tt~second hearing in thrs proceeding was

held

to consider

the Economic Impuc

Study of tne 2roposal and to

receive

testimony by Mr.

Ronald Sut—herland,

the autnor of the Study.

The

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—5—

Economic Impact Study concludes that closing the foundry would entail

an economic cost of some $13,000,000 due to unemployment, foregoing

purchase of raw materials,

and reduced property sales and income

taxes.

The

cost of installing and operating the most feasible pollu-

tion control device was estimated at $225,000.

The benefits of

improved ambient air quality due either to shutting down the foundry

or to using pollution control equipment was estimated at between

$64,000 and $83,000.

In the case of the air pollution control equip-

ment,

the presumption was made that compliance could be achieved

without destroying the air furnace’s capability to produce

a usable

product.

The opinion of the Economic Technical Advisory Committee

(ETAC)

of the Illinois Institue for Environmental Quality suggests the esti-

mation of benefits are highly uncertain due to the relatively sparse

information ava~i1ab1eas to particulate concentration in the area.

ETAC estimated that the dollar benefit estimate might go as high as

$1,200,000, depending upon the actual Hoopeston area particulate

concentration.

The Board agrees with ETAC’s evaluation of the

situation but, after consideration of the evidence presented in

this proceeding,

finds that the probability of anything near the

higher benefit figure is extremely small.

The Board

finds that the Amended Regulation as proposed in

this proceeding should be adopted with minor changes.

decision

is based upon the following factors:

1.

The apparent lack of harm to the environment which would

2.

The relatively high cost of compliance should the Propo-

sal not be adopted.

3.

The distinct possibility that the air furnaces would not

remain viable producers of a useful product should control of

the particulate emissions be attempted.

4.

The very narrowly defined limits of both the

emissions

and the qeographical area under the proposed regulation.

5.

The demonstrated support of the Proposal by residents

in the area and the Illinois Environmental Protection Agency.

The Board therefore adopts

as its Proposed Final Draft in this

matter the Proposal

as presented by Petitioner in Exhibit

2, with

minor changes.

The Board orders publication of its Proposed Final

Draft in the Environmental Register.

A public comment period shall

be allowed for

26~8~

---

6—

This Opinion consLibutes

Uie

findings

mi.

fact and

conclusiQns

of law of the Board in

this matter.

I,

Christan

L: Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion

wa,s adopted on the

day

of ~

,

1977 by

a vote

of

~

_________

Christan

L. Moffet~

erk

Illinois Pollution

rol Board

~±~_

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