ILLINOIS POLLUTION CONTROL BOARD

March

6,

1975

WOODRUFF AND EDWARDS, INC.,

Petitioner,

v.

)

PCB 74—444

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

OPINION

AND

ORDER OF THE BOARD

(by Dr. Odell)

On November 25,

1974, Woodruff and Edwards,

Inc. filed

its Petition for Variance with the Pollution Control Board

(Board).

The Petitioner sought a variance from the carbon

monoxide limitations in Rule

206(e)

of the Air Pollution

Regulations

(Chapter Two)

from December

1,

1974,

until July 15,

1975.

Rule 206(e) requires that no cupola with a manu-

facturer’s rated melt rate in excess of 5 tons/hour emit more

than 200 ppm CO corrected to 50

excess air.

In Woodruff and

Edwards,

Inc.

v. Environmental Protection Agency PCB 74-112,

13 PCB 247

(August

1,

1974), the Board granted this Petitioner

a Variance from December

2,

1973,

until December 1,

1974,

to

enable it to operate its cupola while installing control equip-

ment to comply with Rule

206(e)

of Chapter Two.

The Board

made the grant of that Variance subject to certain conditions,

including:

“2.

Petitioner shall submit monthly progress reports

to the Environmental Protection Agency.

“3.

Within thirty days after completion of the ex-

perimental modification Petitioner shall per-

form a stack test.

Results of the stack test

shall be submitted to the Environmental Pro-

tection Agency.

“4.

If the stack test does not show compliance

with

Rule 206 (e), Woodruff and Edwards

Company shall proceed to install an after-

burner for control of carbon monoxide

emissions.

Appropriate permit procedures

shall be followed.”

In its Interim Order of December 5,

1974,

the Board

requested that Woodruff and Edwards agree to include the

record of PCB 74-112 into this cause.

Petitioner’s consent

was received by the Board on December 16, 1974,

the date from

which the 90-day decision period began to run.

16—31

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—2—

Petitioner operates a grey and ductile iron foundry

containing one cupola with

a process rate weight of 12 tons/

hour.

The facility is located along the west bank of the

Fox River in Elgin, Illinois.

There are other commercial

operations north and south of the plant.

The central down-

town shopping area is immediately across the Fox River to the

east.

On Petitioner’s west, across railroad tracks and a

highway,

is

a residential area.

Tests performed by EEC of Moline, Illinois on October

5,

1973,

showed Petitioner’s cupola to be emitting at the

charge door an average of 219,823 ppm CO corrected to 50

excess

air.

The concentration at the stack was 65,615 ppm.

Additional calculations were made by Petitioner

to show the

impact of these emissions on nearby areas.

The calculations

indicate that Petitioner’s CO emissions increase the ground

level concentrations of CO by 1.2 ppm.

To carry out the Board’s Order of August 1,

1974,

Woodruff and Edwards decided to use the top portion of the

cupola stack as a combustion chamber to convert the CO to

CO2.

The cooling nozzles were removed from the upper cupola.

This permitted the hot exhaust gases to ignite when they mixed

with the excess air entering through the charge door located

on the side of the cupola.

This method was intended to con-

serve energy by eliminating the need for an afterburner.

Petitioner alleged that the test results

sent to the Environ-

mental Protection Agency

(Agency)

establish that CO emissions

were controlled well within permissible limits during much of

the variance term granted in PCB 74-112.

The Agency in its

Recommendation did not dispute this conclusion of the Petitioner.

Woodruff and Edwards alleged, however, that since November

7,

1974,

the system has been experiencing difficulty with com-

bustion in the cupola.

The reasons for the problems were that:

“(a)

There

is

a shortage of coke,

so that we have

been unable to obtain a consistent quality or size

of coke from our suppliers.

As a consequence, we

have been forced in recent weeks to use coke of a

different size than we would normally accept.

With

the smaller size coke,

there

is substantially more

compaction of the melt, which reduces the amount of

air we are able to pull through the melt.

With the

reduced air flow, we have greater difficulty con-

trolling the operating temperatures, resulting in

occasional reductions of the temperatures below

what we require.

This not only creates tremendous

operating problems, but from time to time can

result in incomplete combustion of carbon monoxide

at the top of the cupola.

16—32

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—3—

“(b)

At the same time we have been having problems

with our coke, we have also been experiencing

difficulties with the new fan we installed at the

end of the bag house last spring.

Because the new

fan has not been producing the capacity the seller

promised

(30,000 cfm),

it could not overcome the

shortage of air resulting from the compaction of

the coke.

To meet the problem, we have temporarily

re-installed an old fan, until

a second new fan can

be installed to deliver the capacity we require.

Until a new fan is installed, we expect to continue

to have occasional failures in the burnover process,

resulting in some emission of carbon monoxide.”

A seven and one-half month variance was sought to enable

Petitioner to install

a new fan and conduct tests.

The

Petitioner did not indicate whether the new fan has been

ordered, but based on its allegation that delivery takes

26

weeks from the time of order,

it would seem that Petitioner

has ordered the equipment.

The Agency filed its Recommendation on February

4,

1975.

The Agency recommended that the variance be granted, subject

to certain conditions.

The Agency noted that coke of the

desired size should be more plentiful now that the coal strike

is over.

It considered the July date for completion reason-

able and stated that Petitioner should be allowed to continue

its proposed system, because

a successful system will control

CO and conserve energy.

It was not stated whether any citizens

were opposed to the grant of this variance.

Several potential

problems with Petitioner’s proposed system were noted:

1110.

The Agency does not know whether Petitioner’s

proposed system will work.

That determination must await the

stack test which should be made after the new equipment is

installed and adjusted.

Petitioner’s previous experiments

were performed on production equipment which

is no longer in

use,

so the earlier test information

is out of date.

.

“11.

The Agency believes that Petitioner also has a

problem with fugitive emissions from the charge door of its

cupola.

On December

4,

1974,

an Agency investigator observed

emission levels from the charge door of the cupola

.

.

.

in

possible violation of Rule 203(f)(l).

This problem may be

solved when Petitioner restricts

the area of the charge door

which

is opened to the atmosphere.

This is part of Petitioner’s

control program,

so both the carbon monoxide and particulate

problems may be solved at the same time.

“13.

There

is

a potential problem with the safety valve

cap on the top of the cupola.

.

.

.

This cap on top of the

furnace will open if insufficient cooling occurs as the gases

pass from the cupola through the quench system into the bag

house.

When the cap is open,

particulates escape to the ambient

air, rather than being captured in the bag house. There

is the

danger that the high temperatures needed to incinerate carbon

16

—

33

---

—4—

monoxide will make the existing particulate control system

ineffective.

After the carbon monoxide control system is

completed,

stack tests should be performed for both carbon

monoxide and particulate emissions.”

We agree with the Agency that although problems exist,

Petitioner should be given the opportunity to install its

proposed control system.

Petitioner has made good faith

efforts

in the past to achieve compliance.

Also, we encourage

methods of compliance which involve energy conservation.

Based

on the facts in this case,

it would be an unreasonable hard-

ship to deny Petitioner’s request here.

This Opinion constitutes the findings of fact and con-

clusions of law of the Board.

ORDER

IT IS THE ORDER of the Pollution Control Board that

P’~titionerbe granted

a Variance from the carbon monoxide

limitations of Rule 206(e)

of Chapter Two from December 1,

1974,

until July 15,

1975, subject to the following conditions:

(a)

By March

15,

1974, Petitioner shall submit proof

to the Agency at its office listed in

(b) below of having

ordered the fan needed for its compliance program.

(b)

Petitioner shall continue to send written reports

to the Agency on or before the tenth of each month beginning

April

10,

1975, detailing all progress made toward compliance

during the reporting period.

The reports

shall include any

purchase orders and notices of delays.

The reports shall

also state how much time the cap on top of the furnace

is

open during the reporting period.

Reports shall be sent to:

Environmental Protection Agency, Control Program Coordinator,

2200 Churchill Road, Springfield, Illinois 62706.

(C)

Petitioner shall apply to the Agency for all

necessary construction permits.

(d)

Within twenty-eight

(28)

days of the adoption of

this Order, Petitioner shall execute

a performance bond in

the amount of $10,000 and in a form acceptable to the Agency.

The purpose of said bond

is to assure timely compliance.

Said bond shall be sent to:

Environmental Protection Agency,

Fiscal Services,

2200 Churchill Road, Springfield, Illinois

62706.

(e)

~‘7ithinthirty-five

(35)

days after completion of

the modifications, Petitioner shall perform a stack test for

carbon monoxide and particulates.

Within seven

(7)

days after

they are available to Petitioner, results of the stack test

shall be submitted to:

Environmental Protection Agency,

Control Program Coordinator,

2200 Churchill Road, Springfield,

Illinois 62706.

Petitioner shall provide written notification to

16—34

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—5—

the Agency seven

(7) days prior to the stack test, indicat-

ing the time and place of said test and shall allow Agency

personnel to observe said test if they so desire.

Notifica-

tion of the test shall be submitted to: Environmental Pro-

tection Agency, Illinois Naval Armory, East Randolph and the

Lake,

Chicago, Illinois 60601.

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

Board, hereby certify that the ab ye Opinion and Order was

adopted on the

(~‘

day of

______________,

1975, by a vote of

L~ to~

q~ta~L.’ett