ILLINOIS PJ3LLUTION CONTROL BOARD

November

10,

1976

WOODRUFF

& EDWARDS,

INC.,

Petitioner,

v.

)

PCB 75—355

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

OPINION

AND

ORDER

OF THE

BOARD

(by Mr.

Goodman):

This matter comes before the Board upon Petition by Woodruff

& Edwards, Incorporated

(Woodruff)

for a variance from Rule 206(e)

of Chapter 2 of the Pollution Control Board’s Rules and Regulations

(Regulations)

for the carbon monoxide discharge from a cupola

located

at Woodruff’s Gray Iron Foundry in Elgin,

Illinois.

Woodruff’s

first Petition requested a “long—term” variance in

order to allow it to pursue a recuperative type carbon monoxide

abatement program.

Results have shown this program to be unable

to meet the carbon monoxide limitations under Rule 206 (e).

Woodruff

is under a Board Order in a previous case, PCB 74—444, which requires

it to install after-burners in the event of the failure of its re-

cuperative abatement program.

Woodruff subsequently filed two

amended petitions,

the last of which includes installation of the

after-burner system as part of the compliance program.

The Illinois

Environmental ProtecLion Agency’ s

(Agency) Amended Recommendation

filed

May 10,

1976,

recommends that variance be granted until

January 31, 1977,

the date upon which Woodruff’s after-burner equip-

ment is to be in full operation.

Objections to the variance petition

were filed by more than

30 citizens, many of whom worked in the area

of the Woodruff Foundry.

A hearing was held in this matter on July

14,

1976, but no citizens were

in attendance.

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Because Woodruff has agreed to abandon its experimentation with

the recouperative method of converting carbon monoxide into carbon

dioxide and has agreed to install the accepted and well tested after-

burner method of carbon monoxide destruction,

and because of the

relatively short length of time that installation of this equipment

will entail,

the Board will grant Woodruff’s petition for extension

of variance until January

31, 1977, under certain conditions.

The

Board finds

it would be an arbitrary and unreasonable hardship to

deny Woodruff variance just as it is about to achieve compliance with

the Regulations after having conducted a long-term experiment which,

although a failure, had been ratified by the Board in a previous

variance case.

The Board is cognizant of the citizen objection and

interest in the problems of

the

Woodruff Foundry, and we feel that

final solution of the carbon monoxide problem by January 31,

1977 is

in the best interest of these citizens.

The Board will, therefore,

grant Woodruff variance

and

order it to install its after-burner

equipment so as to be ~n full compliance with the Regulations by the

January

31,

1977 date..

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 Woodruff

&

Edwards,

Incorporated

be

granted a variance from Rule 206(e)

of

Chapter 2 of the Regulations with respect to the carbon monoxide

emissions from a cupola located in the company’s plant at Elgin,

Illinois until January

31,

1977,

subject to the following conditions:

(a)

Woodruff

shall

submit written reports to the Agency

detailing all progress made toward final compliance with

Rule 206(e) on the 15th day of each month subsequent to

the receipt of the Board’s Order herein,

said reports

to

be sent

to:

Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Springfield, Illinois

62706

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194

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3!-

(b)

Within

45 days of the; date of this Order, Woodruff

shall post a performance bond in a form satisfactory to

the Agency in the amount of $50,000.00,

the purpose of

said bond to assure timely compliance with Rule 206(e)

of Chapter

2.

The bond shall be sent to the Control

Program Coordinator at the address indicated in

(a),

supra.

(c)

Within

90 days of the date of this Order Woodruff

shall obtain all necessary construction permits from the

Agency.

(d)

Within

90 days of the completion of installation of

the control equipment, Woodruff shall obtain all necessary

operating permits from the Agency.

(e)

Within

35 days of the completion of installation of

the control equipment Woodruff shall have a stack test

conducted in accordance with Rule 206(f)

of Chapter

2 by

an independent

te~:ing

company, and shall notify the Agency

in writing at

least.

7 days prior to the testing and shall

allow Agency personnel to witness all tests and review all

results.

Notification shall be made to:

ENVIRONMENTAL PROTECTION AGENCY

Division

of

Air Pollution Control

Field Operations Section

1701 South First Avenue

Maywood,

Illinois

60153

(f)

Within

35 days of the date of this Order Woodruff shall

execute and forward to the Control Program Coordinator a

Certification of Acceptance and agreement to be bound by all

terms and conditions of this 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 75-355 hereby accept said Order and

agree to be bound by all of the terms and conditions thereof.

SIGNED_____

TITLE______

DATE

______

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195

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The Certification shall be sent to the address specified in

paragraph

(a), supra.

I, Christan

L.

Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion and Order were adopted on

the

/p”.

day of/)~i~,,J$i~.

,

1976 by a vote

of~’-c

Th 0)44

Chr~stanL. MoffeL

Clerk

Illinois Pollutio

ontrol Board

24

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