ILLINOIS POLLUTION CONTROL BOARD

September 27, 1974

DEERE AND COMPANY

)

Plow and Planter Works,

)

Petitioner,

)

vs.

)

PCB 74-249

ENVIRONMENTAL PROTECTION AGENCY,

)

Respondent.

OPINION AND ORDER OF THE BOARD (by Mr. Seaman):

On July 2, 1974, Deere and Company filed its Petition For Variance,

seeking therein a one-year variance from the provisions of Rule

2O4(f)(2) of the Board’s Air Pollution Regulations. Petitioner

operates a modern farm equipment assembly facility in Moline, Rock

Island County, Illinois, and employs approximately 3,000 persons.

Petitioner’s facility is located in a primarily industrial area with

residences approximately 300 feet to the south.

The subject of this Petition For Variance is a sulfuric acid

dip tank, part of a nickel chrome plating system presently being

constructed by Petitioner. Petitioner is requesting a one-year Variance

from Rule 204(f)(2) as applied to the installation of control equipment

for this nickel chrome plating system.

Petitioner’s assembly facility includes the following major

emissions sources: 2 cupolas, sand handling equipment, metal grinding

operations, sand blasting operations, cleaning and plating operations,

and surface coating and dipping operations. Petitioner has operating

permits for the above-mentioned sources. The application for a

construction permit for the nickel chrome plating line in question was

denied on June 19, 1974. The new plating line, including the sulfuric

acid dip operation, consists of 14 tanks, 3 scrubbers for control,

associated ducting and other equipment.

Raw material useage for the sulfuric acid dip operation is 1500

gallons of 21 H2S04 for six weeks of operation. Only water is added

to the tank to maintain levels during the six week period. At the end

of six weeks the tank will be dumped and fresh acid added. The spent

acid will be disposed of at a landfill. The emissions from sulfuric acid

dip operations in plating lines are in the form of a sulfuric acid

mist composed of vapors and small droplets. Agency calculations indicate

acid mist emissions from the scrubber stack will be 5.0 lb/Ton (average)

and 6.7 lb/Ton (maximum), This exceeds the allowable of .15 lb/Ton

specified by Rule 204(f)(2).

13—697

---

The Petitioner does not question the action of the Agency in

denying its permit application, but does question the appropriateness

of the involved regulation. Petitioner

submits

that this position

is supported by the fact that the Agency has submitted a proposal

for amending the regulation now pending as PCB R73~~l7. Petitioners

proposed control system for this installation will limit its acid

mist emissions to below 0.1 lb./hr., which Petitioner believes will

not have any measurable affect on the environment in the Quad City

area.

Petitioner believes that there is

no method yet developed to meet

Rule

204(f)(2) as now written. This is because Petitioner is attempting

to reduce acid use and total acid emissions by plastic tube tank

covers to minimize the escape of acid mist into the collector, so that

the use of acid is very small and essentially all that is used goes

to the collector. However, to comply with the current regulation, the

acid mist collection efficiency would have to be:

L

20000.15 lbs.lb.

acidaciddischargedused

~

(100) 99.9925

Petitioner states that acid mist collectors do not operate in this

efficiency range, leaving the Petitioner without remedy. Petitioner

alleges that it needs this installation in order to plate parts such

as those used in~hydrau1icsystems on Petitioners agricultural and

industrial equipment products.

This plating system will give Petitioner capacity to plate long

hydraulic cylinder rods which must now he sent to an outside concern.

Under current procedures, Petitioner machines

and hardens the rods,

which must then

he hauled under very carefully controlled conditions,

to prevent

rust

and damage, to

an

outside plater. The rods are then

returned to

Petitioner and fed back into the manufacturing process.

Petitioner

has experienced considerable difficulty with the quality

control of outside platers and has been unable to find

platers with

adequate capacity to handle its requirements. Petitioner alleges that if

it is unable to operate the proposed installation and still continues

to use its outside vendor, Petitioner will not be able to meet its

minimum needs of plated hydraulic cylinder rods after Deceiiber, 1974.

Petitioner states that it has searched unsuccessfully for Iowa

platers capable of picking up this plating load and that to go further

than Iowa or Illinois would not only result in considerable increase

in hauling expense, but also would use extra energy to complete the

transportation process and use extra resources to compensate for the

cylinder rods inadequately protected against weathering while in transit.

13

693

---

-3-

Petitioner states that the proposed installation represents

the hi~estlevel of air pollution control that can be achieved

under present technology. At-source control is provided by the

use

of bath covers, and a scrubber is used to reduce sulfuric acid

emissions. Scrubber efficiency is improved by also including

fume control of the NaOH bath to approach a neutral pH condition

in the scrubber and achieve a higher efficiency than if only the

sulfuric acid tank emission were controlled.

We are disposed to grant the variance requested until March

31, 1975, or until thirty days from the date the Board takes final

action on R 73-17, whichever first occurs. Thereafter, the Board

will be in a better position to assess Petitioner’s problem if such

still exists. Haiever, we will, during the period of this variance,

require that Petitioner limit its emissions of acid mist not to

exceed 0.1 lbs/hr.

This Opinion constitutes the findings of fact and conclusions

of law of the Board.

IT

IS ThE ORDER of the Pollution Control

Board

that Deere and

Company

be granted a variance from the provisions of Rule 204(f)(2)

of the Air Pollution Rugulations until March 31, 1975, or until thirty

days from

the date that this Board takes final action on R 73-17,

whichever

first

occurs, subject to the condition that Petitioner shall

limit

its emissions of acid mist to less than 0.1 lbs/hr. for the

period of this variance.

I, Christan 1. Moffett, Clerk of the Illinois Pollution Control

Board, cçrtify that the above

Opini n an Order

was

adopted on this

0)”

day of’~A$

,

1974 by a vote

of

SeC

.

6’