ILLINOIS POLLUTION CONTROL BOARD
July
24,
1975
OTTAWA SILICA COMPANY,
)
Petitioner,
vs.
)
PCB 75—99
ENVIRONMENTAL PROTECTION AGENCY,
)
Respondent.
MICHAEL REAGAN,
Attorney for Petitioner
WILLIAM ERDMAN, Attorney for Respondent
OPINION AND ORDER OF THE BOARD
(by Mr. Henss):
Ottawa Silica Company filed its Petition for Variance
seeking relief from Rules
203(g) (1) (B)
(particulate emissions)
and 203(i) (4)
(compliance dates)
of the Illinois Air Pollution
Control Regulations
from May 30, 1975 until December
31, 1975.
Variance
is sought in order to continue operating five coal—
fired boilers pending completion of a new operating system
which includes replacement of the coal—fired boilers.
A public
hearing was held in this matter in May 1975.
No members of the
public were in attendance at this hearing.
Petitioner operates a facility near Ottawa,
Illinois for
the mining,
cleaning, drying, sizing,
and grinding of silica
sand.
Products from this facility are marketed nationally and
internationally
in the glass,
foundry, chemical,
oil well,
construction and transportation industries.
Petitioner’s
Ottawa facility is one of the largest industrial and producing
facilities
in the United States.
Approximately 210 persons are
employed at this facility.
Five coal—fired boilers are used at this facility in order
to produce steam heat for sand drying,
space heating and other
miscellaneous purposes.
Four of the five boilers are identical
Bros boilers with rated heat inputs of 82.25 million Btu’s per
hour.
Particulate emissions from these boilers are controlled
by settling chambers which are estimated to be 50
efficient.
Operating permits for these boilers expired on May 30,
1975.
The remaining boiler
is a Babcock and Wilcox boiler with a rated
heat input of 138 million Btu’s per hour.
Particulate emissions
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from this boiler are controlled by a mechanical collector with
an estimated efficiency of 88.
The operating permit for this
boiler expired on March 21,
1975.
During normal operations Petitioner operates
two or three
of the five boilers simultaneously.
Analysis of the Illinois
coal used at this facility shows
that it contains 7.5
ash,
3
sulfur and that it has a heat content of 13,250 Btu’s/lb.
Emissions from the four Bros boilers are vented to a common
stack while the Babcock and Wilcox boiler vents
to a separate
stack.
The calculated particulate emission rate from
a Bros
boiler
is 0.70 lbs. per million Btu’s.
A particulate emission
rate of 0.17 lbs. per million Btu’s has been calculated for the
Babcock and Wilcox boiler.
Rule 203 (g) (1) (B) requires the four
smaller boilers
to meet a 0.29 lb.
per million Btu particulate
emission rate after May 30,
1975.
The larger Babcock and Wilcox
boiler
is required to meet a particulate emission rate of 0.15
lbs.
per million Btu after that date.
Petitioner is currently engaged in a compliance program
that involves the construction of
a completely new process system.
Planning for the new system began in January 1971 because of a
recognized need to reduce noise and air pollution.
One feature
of the program will be the replacement and retirement of all
five coal-fired boilers. Fluidized bed oil—fired sand drying
systems will be utilized in the new process and two small boilers
will be installed to meet t’~espace heating requirements.
Once
the new facility is in operation the coal-fired boilers will be
dismantled and sold.
Preliminary engineering for this compliance program was
completed in March
1973.
The contractor for this project,
Hunter Corporation, estimated that the entire project would be
completed on or before November 30,
1974.
Shortly after con-
struction commenced,
the contractor began to encounter difficulty
with
the
purchase and delivery of the 1400 tons of structural
steel required for the project.
Testimony by Hunter’s Project
Manager indicates that the steel shortage was nation-wide.
Orders placed with the major steel producers were returned
cancelled, causing Hunter to search for the steel at various
warehouses around the country.
A premium price was paid for
the “off-the-shelf”
steel
in order
to keep the project going
CR.
62).
In addition, a six week strike at the construction site in
1974 caused problems for Hunter,
and this delayed issuance of
a
revised completion date until October 1974.
Driers scheduled
for delivery in October 1974 were not received on site until
April 1975 according to the Project Manager.
Hunter now estimates
that it can complete the project by August 15,
1975 barring any
unforeseen delays.
Correspondence between Hunter and Petitioner
confirmed that problems had been encountered
in steel procurement.
(Agency Recommendation, Attachment 2).
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According •to terms of the construction contract, Hunter
will not be penalized for the delays in completing the project.
However,
testimony indicates that Hunter has incurred costs
of
$1.2 million
in excess of anticipated costs
(R.
93).
Robert Lacke, Petitioner’s Director and Vice President of
Operations, testified that the incentive to complete the project
rests with Ottawa Silica because of the cost on borrowed money.
It now costs Ottawa Silica between $140,000 and $170,000 in
carrying costs for each month the project
is extended
CR.
91).
Upon completion of the construction phase of the project,
Petitioner will immediately implement its start—up procedure
in order
to bring the new operation on line as quickly as
possible.
Petitioner’s Division Manager, Lester Richards,
testified that the start-up procedure will require a minimum of
14
weeks
thus
pushing
the
actual
start-up
date
for
the
new
process
to
late
November
1975.
Serious
problems
encountered
during start-up could result in delays totalling 59 weeks
CR.
44).
Variance
is sought only until December
31,
1975 in the belief that
no serious problems will develop during start-up.
Hunter’s
Project Manager testified that the December
31,
1975 date re-
flects
a very optimistic view on Petitioner’s behalf
CR.
63).
The coal-fired boilers could be brought into compliance by
the installation of additional particulate collecting devices.
James Caselton, Petitioner’s Chief Engineer,
testified that such
a project could be completed in
7 to
9 months
(R.
81)
at an
estimated cost of $200,000
(R.
80).
Since the coal-fired
boilers will not be used in the new process, none of these
control devices would be of serviceable value once the new
system is placed on line.
Caselton testified that Ottawa
Silica agrees with the Agency on maximizing use of the Babcock-
Wilcox boiler during the variance period sought because of its
lower particulate emission rate.
Data obtained from the Agency’s Ottawa monitoring station
show that for the period fr~mAugust 1974 through March 1975
a geometric mean of 41 ug/m
was achieved.
Monthly geometric
means during this period ranged from 27 to
66 ug/m~. The highest
reading during this period, 139 u.g/m3, occurred one day during
August 1974.
Petitioner was operating its coal-fired boilers
during the sampling period.
Petitioner has not received any
complaints about emi~ionsfrom the, facility for the last
operating year
CR.
41).
Petitioner calculates that particulate emissions from its
Babcock and Wilcox boiler exceed the allowable emission rate by
2.77 lbs./hr.
An excess emission rate of 23.88 lbs./hr.
is
calculated for each of the Bros boilers.
Petitioner operates
eight months of the year using the Babcock-Wilcox boiler and
one of the Bros boilers.
Based on theoretical calculations,
18—
177
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Ottawa Silica submits that operation of the coal-fired boile~s
during the variance period sought would result in a 4.6 ug/m~
burden on the air at its property line and 0.79 ug/m3 at the
Agency’s Ottawa monitor.
The Agency questions whether Petitioner could accurately
predict the plume rise from the stacks on the basis of only
five observations and whether the wind speed used in the cal-
culations,
5 miles per hour, was accurate.
The Agency suggests
that Petitioner should have used information from the National
Climatic Center showing a “most common wind speed” of 8.0
to
11.5 mph for all major weather reporting stations in Northern
and Central Illinois.
In the Agency’s opinion,
a sampling
period of eight months may not be sufficient upon which to
base conclusions concerning the annual geometric mean for
particulates in the Ottawa area.
Both the primary and secon-
dary ambient air quality standards for particulates are
expressed in annual geometric means and 24-hour
maximum
con-
centrations.
However,
the Agency does not
totali.y reject
Petitioner’s calculations and recommends that the variance be
granted, subject to certain conditions, until December 31,
1975
(R.
97)
It is the finding of the Pollution Control Board that
Petitioner has met its burden of proof.
Delay
in completion
of construction on the new system was beyond the control of
Petitioner.
The Board is satisfied that Petitioner has made
and will continue to make every reasonable effort to complete
the project as quickly as possible.
The evidence indicates
that ambient air quality standards will not be violated by the
grant of variance in this case.
The Babcock and Wilcox boiler at Petitioner’s facility
exceeds the allowable emission rate only slightly.
Each of
the Bros boilers emits particulate matter considerably in
excess of the allowable rate.
Petitioner admits that it could
bring the coal-fired boilers into compliance.
However, to
require control devices
to be installed on the boilers at this
time would clearly be an unreasonable measure and it is most
doubtful whether the boilers could be brought into com-
pliance before they reach the end of their useful life.
Ottawa Silica is near the end of a major project which
will bring the activity into compliance with the particulate
emission limitations.
The Company,
its employees and neighbors
will benefit considerably from this project.
In consideration
of the fact that Petitioner began planning this compliance
program at a time preceeding many environmental regulations,
the Board commends Petitioner for its foresight and diligence.
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This Opinion constitutes the findings of fact and con-
clusions of law of the Illinois Pollution Control Board.
ORDER
It is
the Order of the Pollution Control Board that
Ottawa Silica Company be granted variance from Rule 203(g) (1) (B)
and Rule 203(i) (4) of the Illinois Air Pollution Control
Regulations
from May 30,
1975 until December 31,
1975 for its
Ottawa Silica plant.
Variance is granted subject to the
following conditions:
1.
During the period of this variance, Petitioner
shall make every effort to maximize use of the Babcock
and Wilcox boiler and minimize use of the Bros boilers.
2.
Petitioner shall submit monthly progress reports
to the Environmental Protection Agency.
Said progress
reports shall commence on August 15,
1975 and shall pro-
vide details of Petitioner’s programs toward completion
of the fluidized bed drying system.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the
bove Opinion and Order was
a opted
the
p4~
day of
___________,
1975 by a vote of
-c:~
Christan L. Moffe
,
erk
Illinois Pollution
ntrol Board
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