ILLINOIS POLLUTION CONTROL BOARD

January

14

1976

M & S WOOD AND PAPER CORPORATION,

Petitioner,

v.

)

 PCB 75—417

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

OPINION AND ORDER OF THE BOARD

 (by Mr. Young):

Petitioner, N

&

 S Wood and Paper Corporation

(N

&

 5), seeks

a one-year extension of

 a variance granted in PCB 72—236 on

October 10, 1972,

 and extended by PCB 73—76 and PCB 74-243, from

the provisions of Rule 502 of the Air Pollution Regulations

(Chapter

 2) which prohibits open burning except as otherwise

provided by Part V:

 Open Burning,

 of Chapter

2.

N &

 S operates

a paper recycling and wood reclaiming business which processes

from 20

to

 25 tons of trade wastes daily at a site in Boone County,

Illinois, one mile east of Belvidere, Illinois, and outside of any

landscape waste open burning restricted area,

 as such areas are

defined in Rule 503(c) (4) of Chapter

2.

 Boone County is not in-

cluded in any major metropolitan area In Illinois or any adjacent

state.

The wood portion of the waste consists of wood pallets, divi-

ders and crating lumber; however,

 chipping of these materials for

recycle is not practical because of the presence of nails, wire

 and metal

strapping which would damage the chipping equipment.

Consequently, pursuant to the prior variances granted by the Board,

M

&

 S burns such material on site with the emissions controlled by

utilization of an air curtain destructor.

 The alternatives to use

of the air curtain destructor in this instance are disposal

 of the

wood by landfill at a cost of $25.00 per truckload

 (of two tons)

as

opposed to the current method of burning at

 a cost of about $6.00

per truckload.

 The second alternative to the air curtain destructor

would be installation of a substantially more expensive incinerator

capable of meeting the requirements of Rules 202(b),

 203(e) (5), and

206(b).

 The manufacturer of the air curtain destructor states that

smoke emission from the control device

 is Ringelmann #1

(20

 opacity)

or less;

 the requirement of Rule 202(b)

 is Ringelmann 1.5 or 30

opacity.

The Agency recommends the granting of the variance.

 On November

4, 1975,

 an Agency representative visited the site of the air curtain

—

891

—2—

destructor and observed the destructor

to

be well maintained and

operating properly.

 Complaints were not received by the Agency

 concerning Petitioner’s operation from the Boone County Sheriff’s

Office,

 the Chief of the Boone County Rural Fire Protection Dis-

trict #2, or from Farm and Fleet,

 the closest commercial operation

to the site.

The Board feels the variance should be extended because the

benefits from the Petitioner’s recycling operations outweigh the

slight negative environmental impact.

 The grant of this variance

is conditioned upon the

 fact that Petitioner continue to operate

the site in a safe and proper manner.

 By limiting operation to

daylight hours when dispersion conditions are favorable any adverse

smoke effects, however slight, will be further minimized.

We would note that the Chapter

 2 Open Burning Rules, specifi-

cally Rule 504, provides for open burning permits from the Agency

in certain instances.

 Rule 504(a) (4)

 provides that an Agency open

burning permit may be granted for the open burning of landscape

wastes with the aid of an air curtain destructor if such burning

does not occur within 1,000 feet of any residential or other popu-

lated area.

 It is further noted that landscape wastes are included

within the general definition of trade wastes.

In the initial variance to N

&

S

(N

&

 S Wood and Paper Corpora-

tion v. EPA, PCB 72-236,

 5 PCB 637,

 1972),

 the Board granted the

variance “as an experiment to determine the adequacy of the air

 curtain destructor as

 a substitute for more expensive incinerators

in the burning of clean wood that does not qualify as landscape

waste.

 If the experiment proves successful, we shall be pleased

entertain

proposal

the

Agency

amend

the

regulations

allow

such

burning,

 outside critical areas,

upon

permit

from

the

Agency.”

After three years of operation of air curtain destructors

at M

&

 S and other sites throughout the State,

 sufficient informa-

tion to justify an amendment to Rule 504(a) (4)

 should be now available

and we would again entertain such

 a proposal rather than require

M

&

 S and others similarly situated to petition for renewals of their

variance.

This Opinion constitutes the findings of fact and conclusions

of law by the Board in this matter.

ORDER

IT IS THE ORDER OF THE POLLUTION CONTROL BOARD than M &

S

Wood and Paper Corporation be granted variance from the Air Pollu-

tion Control Regulations until September 19,

1976

 to burn certain

wood wastes at its Boone County site,

 subject to renewal on an

annual basis upon application and proper proof and subject to the

following conditions:

—

892

—3—

1.

 Only landscape waste and clean unpainted lumber shall be

disposed of

in the air curtain destructor.

 All other lumber and

debris shall be separated prior to burning and disposed of by some

other means.

 Under no circumstances shall Petitioner conduct any

open burning or incineration of materials not in the air curtain

destructor.

Petitioner shall conduct the housekeeping at its facility

so as

 to eliminate the possibility of illegal fires caused by sparks

igniting litter and nearby waste materials.

3.

An

operator must be in attendance at all times when wood

wa~te is being burned.

4.

 The feed to the air curtain destructor shall be adjusted

prevent

any

visible

emissions

from

the

destructor

above

10

 opacity.

5.

 Material used to promote combustion shall not be lower in

quality than #2

 fuel oil.

6.

 Burning shall be conducted only on days when the wind

velocity

 is between 5 and 25 miles per hour.

7.

 shall be conducted only between the hours of

8:00 a.m.

ana

4:00

 p.m.

8.

 The burn~nqsite shall be provided with adequate fire

protection and wit.H

 such equipment as necessary to control accidental

fires.

9.

 The air curtain destructor shall be operated in accordance

with the manufacturer’s operating instructions.

10.

 Petitioner shall be subject to the Agency’s standard con-

ditions

 for open burning

 (APC-171 as revised 7/73).

11.

 Within 30 days of the date of the adoption of this Order,

Petitioner shall complete and submit to the Environmental Protection

Agency, at the following address,

 the following certification:

Environmental

Protection

Agency

Division

Air

Pollution

Control

Program

Coordinator

2200 Churchill Road

Springfield, Illinois

62706

I,

 (We),

____________________________

 having read

the Order of the Illinois Pollution Control Board in

PCB 75—417, understand and accept said Order, realizing

that such acceptance renders all terms and conditions

thereto binding and enforceable.

—

893

—4—

SIGNED

TITLE

DATE

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby c~tify the above Opinion and Order

were adopted on the

 /‘I~’~ day of

1976

by a vote of

‘/-~

QL~49/r)

Christan L. Moffet

erk

Illinois Pollution

 trol Board

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694