ILLINOIS POLLUTION CONTROL BOARD

August 1, 1974

WOODRUFF AND EDWARDS COMPANY, INC~

Petitioner,

vs~

)

PCB 74~ll2

ENVIRONMENTAL PROTECTION AGENCY,

Respondent~

OPINION AND ORDER OF THE BOARD (by Mr~Henss)

Woodruff and

Edwards

Company, Inca requests variance from

Rule 206

(e) of the ;Air Pollution Control Regulations for a period

of one year pending experiments, modifications of control equip~

ment, and testing on its foundry cupola~ Rule 206(e) prohibits

the emission of gasses containing carbon monoxide from any

cupola having a melt rate in excess of 5 tons per hour unless:

I) such gasses are burned in

an

afterburner so that

the resulting concentration of carbon monoxide is

less than or equal to 200 ppm corrected to 50

excess air, or

2) such gas streams are controlled by other equivalent

pollution control equipment approved by the Agency~

Petitioner operates a gray and ductile iron foundry (cupola

rating 12

tons/hour)

which is located along the west bank of the

Fox River in

Elgin,

Illinois~ West of the foundry is a residential

area~ There

are commercial

operations to the north and south and

the Elgin City Hall and Civic Center are across the River to the

east~ The cupola is equipped with a baghouse for particulate contro1~

Applications

for an

operating permit were apparently denied

by

the

Ager~cybecause of excessive carbon monoxide

emissione~ Shortly

thereafter Petitioner conducted stack tests

which showed the cupola

to

be emitting 219,823 ppm carbon

monoxide~ Carbon monoxide con~

cen~crationsat

the

stack

were shown to be 65,615 ppm~

Another series

of tests were conducted by Petitioner to

determine the effect of the carbon monoxide

emissions on nearby

areas~ Res~i1tsof these tests were reported as follows:

13~247

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1) In the path of the air stream directly from

the point source

(cupola and baghouse)

2,5 ppm

2) At property line of closest residence

2.5 ppm

3) Up—wind from point source for background0

.

2.5 ppm

To verify these test results, Petitioner performed a series of

calculations using the guidelines found in ~

~rsi2~stimates, U. S. EPA Document AP-26. These calculations

allegedly show that Petitioner~s carbon monoxide emissions increase

the ground level concentrations of carbon monoxide by 1.2 ppm.

Petitioner is *~il1ing to install an afterburner to control

carbon monoxide emissions but has been informed by Northern Illinois

Gas Company that additional quantities of natural gas for this

purpose are not available. Northern Illinois suggested that

Petitioner investigate the possibility of eliminating gas usage in

other parts of the foundry operation and transfer this gas to the

afterburner operation. However, Petitioner states that it would fall

short of the afterburner gas requirements by 20 using this method.

The alternative, according to Petitioner, is to use the upper

section of the cupola as a combustion chamber to convert the carbon

monoxide to carbon dioxide. This “recuperative” method requires the

introduction of additional air to the cupola through the charging door.

The additional air supply in the presence of heat from the melting

operation would allegedly cause spontaneous ignition of the carbon

monoxide. Tests using this procedure have shown that carbon monoxide

concentrations can be reduced to about 20 ppm in the exhaust stack of

the baghouse. Petitioner states that careful supervision was required

during these tests and “present conditions were not readily converted

to production procedures”.

Further modifications of the cooling system will allow combustion

of the carbon monoxide to take place in the cross-over duct between

the cupola and the cooling tower. This ph’ase of the operation will

be difficult since the gas stream must be sufficiently cool prior to

entering the baghouse to prevent the destruction of the collection

bags.

Based on information from its consulting engineering firm,

Petitioner estimates that equipment necessary for the experimental

procedure would require eight months for delivery and three months

for installation, The experimental method would, if

successful,

provide the dual reward of achieving compliance with the Regulations

and saving energy since it would not require auxiliary fuel.

Petitioner has applied for construction perm4ts for an afterburner

~in

the event the variance is not approved although doubts~are

expressed about the operational efficiency of the afterburner because

of inadequate natural gas supplies.

---

—3—

The Agency acknowledges Petitioner~s problem in obtaining

natural gas and recommends that Petitioner be given the oppor-

tunity to explore this new method of carbon monoxide control.

According to the Agency, fugitive particulate emissions which

Agency investigators observed coming from the furnace cap on

the cupola and the charging door should also be eliminated by

this proposed method of control.

Nearby residents have no objection to the granting of this

variance. The Agency believes that the foundry does not cause

a nuisance to the surrounding community.

Reasons for the delay in meeting the standard are not stated

definitely, however, the Agency recommends that Petitioner be

granted a three month variance. This recommendation apparently

stems from conversations in which Petitioner indicated that the

required alterations would be made during a July shutdown and that

testing would be performed shortly thereafter. In the absence of

any response from ;the Company, the Board concludes that equipment

required for the experimental modifications has already been

received and will be installed this month.

We shall grant this variance for four months since this is

the time Petitioner has indicated would be required for installation

of the modification equipment plus an additional month for testing.

Petitioner is to be commended for its efforts toward achieving

compliance without the need for auxiliary fuel.

ORDER

It is the Order of the Pollution Control Board that Woodruff

and Edwards Company, Inc. of Elgin, Illinoi~sbe granted a variance

from Rule 206(e) of the Air Pollution Control Regulations until

December 1, 1974 for the purpose of installing and testing cupola

modification equipment designed to achieve compliance with Rule

206(e). This variance is subject to the following conditions:

I. Petitioner shall apply for all necessary Agency

permits for the modification equipment.

2. Petitioner shall submit monthly progress reports

to the Environmental Protection Agency. Said

progress reports shall commence on August

15, 1974

and shall provide details of Petitioner~sprogress

toward completion of the experimental modification

program.

3. Within thirty days after completion

of

the experi-

mental modification Petitioner shall perform a

stack test. Results of the stack test shall be

13— 249

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—4—

submitted to the Environmental Protection Agency

within 5 days after they are available

to

Petitioner. Petitioner shall notify the Agency

five days prior

to

the stack test indicating the

time and place of said test and shall allow Agency

personnel to observe said test

if

they so desire.

4. If the

stack test does not show compliance with

Rule 206(e), Woodruff and Edwards Company shall

proceed to install an afterburner for control of

carbon monoxide emissions. ‘Appropriate permit

procedures shall be followed.

I, Christan L.

Moffett,

Clerk of

the Illinois

Pollution Control

Board, h~~ebycertify the above~Opinion and Order was adopted

this

J~~~day

of

~

1974 by a

vote of ____to ~

13

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250