ILLINOIS POLLUTION CONTROL BOARD

April

14,

1971

Sandoval

Zinc Commany

V.

)

~CB 71—10

Environmental Protection Agency)

Opinion of the Board

(by Mr.

Kissel):

Sandoval

Zinc Co

(Sandoval)

requests

a variance

to onerate its

rotary kiln

in violation

of

Sec.

9(a)

of the Environmental Protection

Act and

Rule 3—3.111 of

the Rules and

RecTulations ~o~ternin’~the

Control of Air Pollution, until July

27,

1971.

Sandoval admits to

a narticulate emission

rate of

23

lbs/br;

the allowable rate

is

4

lbs/hr.

The

Environmental

Protect±o~

Armnov

(Aaency)

o~nosedthe

~rant

of

the

variance

on

the

ctrounds th~t

Sancioval

was

dilatory

in

filinc

its

Letter

of

Intent

under

the

~ir

Cor.taminant

Emis~.on

Reduction

ProcTram

(ACERP)

and

that

crantinc

the

varinnce

will im~ose

substantial

hardshin

on the nearb~’residents.

Sandoval

is

enqaqed

in

the

manufacture

of

zinc oxide.

The cemnany

purchases

secondary

zinc

residue

nroduced

by

steel. como~-injes

and

calvanizer.c;

it

demetalizes

this

combination o~zinc riatallic,

zinc

oxide,

and

chlorides

by cr’ishinr~and

screenincr.

(fl~

20)

The

material

is then

s~elted

in

the

rotary

bun

at a

tem~erature

of

over

a

thousand

decrees

in order to

drive

the

chlorides

out.

After the smeltina, the

zinc

oxide

remains

and

it

is 1~ail

milled

and then

sold

as

a fertilizer additiv~

(P.

42)

The zinc skimminas ~rocessed

in the olant cont’~inbetween

65 and

85

ner cent

zinc, from

1 to 9 ~or cent chlorides,

•1)2

aluminum,

.1

to

.2

Lead,

with

any remainder silica and oxvoen.

(P.,

62)

Sandoval estimated

that

its fume was

92 ~er cent

zinc

oxide,

8

ncr cent zinc chloride.

(P.

69)

Albert

Haas,

~res:Lcient

of

Sandoval,

:Lndicated

that

he

h~id hecUn

to

search

~er

nro~er

control e~~uinmentin

1960;

after examinine ~rarirus installations

throuc’hout the country, Sandoval decided en an e~ectrost.atic

nrecinitator,

In Sentember,

1969, Sandoval entered into

a co~tract

with Precinitair

(a subsidiary of Advznce

Ro,~s) for the rental of

a scale model unit cuarantoed

to remove 08.5

of the emissions.

(R.

28)

U’non receint of the unit in January,

1070,

Sandoval

filed

a letter of intent with

the

~\irPollution Contr~it~oard,

On

rday 27,

197(1,

the

~PC~

anoroved

a

14—rtonth nerLrxl

for Sandoval

to

imniement i~Air Contaminant Emission Peductien PrecTram

(lCT~PP)

usinc an electrostatic orecinitator.

In Auriust,

1970,

after

1 ---453

---

several months of encineer±nciwork

on the epuimment, Precimitair

concluded that,

clue to the high resistivity

of

Sandoval’s emissions,

the electrostatic orecinitator was not the mromer control device

and recommended instead installation of

a

wet

nrecimitator.

(P,

31,

89)

Paas

arTain

commenced

his

search

For

control

ecuimment;

in

.7~hron,

Ohio,

he

discovered

a secondary aluminum

skimr’inos

~‘roeessor suc—

cessfullv

usinc’

a wet—wash scrubber to control

chloride

fumes.

(P,

33)

6ando~Tal adantocl the ~iet—wash scruhhe’~-to its ~~cii

ities

and.

has

already hecun the

$35,000

~‘roc’ram.

Oniw $15,000

remains

to be

snent;

the

majority

of

that

for

a

blower

on

which

Sandoval

has contracted

for exmeditecl deliver~’,

(“.

3cc,

4(1)

The

Acency

as)~s

ur-

te

deny

the

var~nmco

since

Sandoval

was

dilatory

in

su1,mittino

its

orieinal

~CE~P,

~\nArrenov

encrineer

testified

that

the

control

teehnelooy

for

the

secondary

meta1~

industry

was

avaiiahl0

in l~67. (P.

159)

Any

dilatoriness

on the mart

of

Sandoval,

however,

was

excused

by the APCB when

it

ciranted the orirTinal 7~CEPP.

In EP~v.

Commonwealth Edison,

~CT370—4,

the Poard

ruled

that

an T~CFRPcould

lerially have been

oranted

oni

for

a

~eried

of

a

year,

The

Board.

has

also

annroved

a

variance

for

a

cemmany

mroceedincc

to

imnl.ement

its

~CEPP,

es~pci

al~y

T~7hefl

it was

omm1o~ipo

mere

efficient

control

equinment,

“edusa

Portland

Cement

v,

‘~‘P7~,

PCB 70—27,

In the instant case,

~

by

the

oricinal

deadline, July

27,

1)71,

also usine

a more efFc~tivecontrol

device

than

that

oriciinally

pronosed,

~

would note, however, that

the

orders

or

nrorcra!s

amnrovecl

by

our

nredecessor

Boards

remain

in

effect

only

until

superseded

by

actions

of

this

Board,

(See

Section

49(d)

of

the

Environmental

Protection

Act,)

Thus,

lust

because

a

mart’7

is

omeratinci

under

an

~CFRP

or

similar

immlementation

nroerarn

amoroved

by

one

of

our

nredecessor

Boards

does

rot

mrevent

this

Board

from

donvino

the

variance

recuest

even

thouch

it

is

for

the

same

or

lesser

‘~eriod

of

time,

Section

49(d)

c~uarantees

the

Board

‘

s

ricbt

to

re—examine

and

to

revoice,

if

necessary,

~‘7e are

coni~inced

that

immediate

commliance

with

the

amnlicable

rules

and

reoulations

would

imnoso

an

arbitrary

and

unreasonable

hardshim

poem

5-andoval,

The

sorino

of

the

year

is

the

meal~ season

~or

this small comman,

(R,

39)

Due

to

the

nature

of

its

market,

it wouild

stand

to

lose

its

customers,

(P.

54,

56)

Sandoval

draws

cost

of

its

nineteen

emmloyees

prom

the

local

area;

to

deny

the

17ariance

would

mean

the virtual cessation

of

omerations

at

Sandoval,

~7ith

its

oroeryn

chic

to

he

comoleted

within,

four

months,

Sandoval

is

well

on

the

way

toward

comnliance,

1

—

454

---

In

grantinc’

the

variance

the

Board

is

admittedly

irr’osin~

a

hardshin

upon

the

residents

of the community,

Tue c-everal

residents

who testified and the numerous re9idents who entered

written objections to the

arant of the variance all smoke

to the obnoxious nature of the fumes emitted

Frem the olant,

The testimony indicated that it was often difficult

to

drive

without

headlights

or

to sit outside when

the

fume. was mourina

forth.

A mother indicated that her children could not olay

at

school recess because the smelter smoke was so thick they

could not breathe well.

The commany itself shuts

clown on halF—

hour notice whenever the neic’hhorinci outdoor mo~rietheater

is omen

and the wind is from the south,

(‘1,

129)

The United States

Denartment of Health, Education,

and welfare renort,

the

so—called Litton study,

Preliminary Air Pollution Survey

of Zinc and

its Comnounds,

indicates that health hazards may

occur from the inhalation

of zinc oxide fumes,

resultincr in

metal fume fever, and of zinc chloride fumes,

resultinci in

irritation and damage to mucous membranes,

The threshold

limit

values

(TIN)

for zinc oxide has been set at 5000 uq4n3

averacied

over

the

eight—hour

work

day

by

the

American

Con~erenoe

of

Covernrient

Industrial

TyrTienistsl

a

tentative

TLV

~or

zinc

chloride

has

been

set

at

1900

na/rn3,

The larco amount of

zinc

discharoed

ma’,

also

he

toxic

to

vecetation

near

Sando’TaJ,,

Sinc”

the

comoac’.?

is nroceeding

with

an

irnmlementaion

oroorno.

a’~’

that

-~rociram

will

be

comnleted

within

four

months,

the

Peard

believes

th.’~t

the variance should be qrantecl,

F3andoval,

thonr-h,

is

no sm~li

nolluter,

Therefore,

we

will

recuire

stack

tests

to

he conducted

noon

the

installation

and omeratien

of

the

‘70t—wash

ccrubher,

The

testimony

also

established

that

there

rev he ether sources

of

air

oollutjon

within

the

niant.

The

~nrmace

For

the.

lils and

the

milling orocess also may be cmittino oart5culat.cs

to th’~~t—

rnosnhere in violation

of the conlicable

reonl,etiens,

(P.

(3~, 77)

Sandoval should undertake

to study and

control

those

“oss4bl,e

sources

of contaminants

if they are

in

‘rini-ati

on

tho

Rules

and

Pegulations,

The above constitutes

the i3oard’s ~

o~f’et

,~pd

comcl~v~ie-’s

of

law,

1

—

455

---

Order

1.

Sandoval shall not operate its rotary kiln after July

27,

1971,

without

the

wet

scrubber

installed

and

in

operation;

the

emissions

from

the

kiln

shall

be

in

compliance

with

the

applicable

Rules

and

Regulations

Governing

the

Control

of

Air

Pollution.

2.

Sandoval,

for

the

period

of

the

variance,

shall

not

exceed

the

monthly

rated

capacity

of the kiln.

3.

Sandoval shall post with the Environmental Protection Agency

by April

30,

1971,

in

a form agreeable to the latter,

a bond or other

security in the sum of $15,000,

to assure compliance with

this order.

4,

Sandoval shall submit

to the Agency within

60

days of

the entry

of this order plans

to control other sources

of emissions at

its

Sandoval plant.

5.

Sandoval shall furnish tothe Environmental Protection Agency

progress reports

60

days from the entry of

this order and upon

the

completion of the installation.

6.

Within 30

days

of

the installation and operation of the wet

scrubber, Sandoval shall conduct

a stack test for

zinc oxides and

zinc

chlorides

and furnish said results to the Agency.

7.

Failure to adhere to any of the conditions of this variance

shall terminate the variance.

I,

Regina

E.

Ryan, Clerk of the Pollution Control Board, certify

that the Board adopted the above opinion and order this

14th

day of

April,

1971.

1

—