ILLINOIS
POLLUTION
CONTROL
BOARD
February
21,
1974
~JOBNDEERE & COMPANY, EAST
)
MOLINE
WORKS,
)
Petitioner,
)
v.
)
PCB
73—497
)
ENVIRONMENTAL
PROTECTION
AGENCY,
)
)
Respondent.
OPIWIOli MiD ORDER
OP
THE
BOARD
Iby
Mr.
Benss)
Petitioner Deere
& Company filed Petition for Variance on
November 26, 1973 seeking variance from Rule 3—3.112 of the Rules
and Regulations Governing the Control of Air Pollution.
Specifically,
Petitioner seeks approval of its plan to burn coal in boiler
17
or
18 at its East Moline Works in the event oil and gas are unavail-
able in sufficient quantities to meet plant demand in excess of the
capacity of boiler 19, a controlled boiler.
Deeie’s East Moline Works employs about 5,000 people for the
assembly of combines.
Seven boilers are utilized at the facility
for process reanirements and heat.
Two
of
the
boilers
are
gas
or
oil-fired, three are gas or coal’ fired and two operate on coal
alone.
This variance concerns the operatiod of boilers
17,
18
and
19, all of which are gas or coal fired boilers.
Boilers 17 and 18
are uncontrolled travelling grate boilers with a steam capacity of
80,000 lb./hr.
each.
Boiler
19
is a multiclone equipped spreader
ctoker type boiler with a steam capacity of 130,000 lb./hr.
Fuels used at the facility vary on a daily basis according to
the availability of natural gas and the weather.
As an example,
Pctitioner states that fuel used during December 1972, a maximum
demand month, was:
Fuel
&wunt used
Percentage
Coal
60,301 x 106 Btu
36.5
Gas
96,706 x 106 Btu
58.6
Oil
4,255 x 106 Btu
2.6
Propane
3,823 x 106 Btu
2.3
Total
165,085 x 106 Btu
100.0
11-327
—2—
Propane
is not actually burned in the boilers but is used inter—
changeably with natural gas in the forge shop.
Petitioner states
that any curtailment in propane availability will result in
a require-
ment to divert additional natural gas from the boilers to the forge
shop thus causing
a fuel shortage for the boilers.
Petitioner
is unable to determine the extent to which coal will
have to be burned since the burning is dependent upon the weather
and possible gas curtailment, neither of which Petitioner can control
or predict.
However, based on 1972 records, Petitioner states that
the coal equivalent for the maximum monthly oil usage was 205 tons.
The 1972 records also reveal that 234 tons of •coal per month will be
required for each
5
curtailment in natural gas supplies or diversion
of natural gas to forge shop use.
Based on Public Health Service
Publication AP-42, Petitioner estimates the expected particulate
matter and sulfur dioxide emissions from boilers
#7 and #8
as follows:
Calculations
for
10,350
I3TU Coal
Lbs./Ton
Lbs./l06 BTU
Particulates
(13 x 7.5
Ash)
97.5
4.7
SO2
(38 x 2.35
sulfur)
89.3
4.3
Petitioner estimates that maximum emission rates
of 516 lbs./hr.
particulates and 474 lbs./hr.
sulfur dioxide would occur when either
boiler
#7 or
#8
is operating full capacity on coal.
If the boiler
is operated at less than
full capacity,
the emissions will of cour~e
be lower.
Petitioner contends that any injury to the public from the
grant of this variance would vary according to the capacity at which
the boiler would be operating,
and that this operating level depends
on weather conditions
and gas availability, factors which cannot be
estimated.
The possibility of injury to the public from the increased
emissions must be weighed against the consequences
of a variance
denial.
Petitioner states that a variance denial would result in
employee layoffs
(no figures cited)
and an inability to satisfy the
pressing demand for products needed in the food production industry.
Coal burned at Petitioner~sboilers has an average ash content
of 7.5
and an average sulfur content of
2.35.
The following Table
is the Agency’s estimate of Petitioner’s particulate matter and
sulfur dioxide emissions:
11 —328
—3—
Rule 3—3.112 Rule 203(g)
Allowable
Allowable
Allowable
Parti~ulates
SO2
SO2
Parti~u1atesParticulates
Boiler
lb/l0
BTU
lb/b6 BTU lb/b6 BTU lb/lO
BTU
lb/b6 BTU
I
Operates on gas or oil
2
Operates on gas or oil
5*
4.68
4.38
6.0
.6
0.32
6*
4.68
4.38
6.0
.6
0.32
4.68
4.38
6.0
.6
0.176
8
4.68
4.38
6.0
.6
0.176
9
.51
4.38
6.0
.6
0.141
*
Emergency stand—by only
Particulate emissions from the boilerhouse are currently regulated
under Rule 3-3.112.
After May 30, 1975 Petitioner must comply with
the particulate emission limitations of Rule 203(g)
of the Air Pollution
Control Regula~ions. As noted above, Petitioner~ssulfur dioxide
emissions are presently within the regulatory constraints
of
Rule 204,
Deere has proposed and partially implemented a comprehensive
compliance plan which encompasses not only boilers #7,~#8, and #9 but
the entire scope of energy requirements for its East Moline Works.
The
compliance plan shows the installation of electrostatic precipitators
on boilers
#7,
#8 and #9 by November 1,
1975,
Since the date of in-
stallation will not place Deere in compliance by the May 30,
1975
effective date of Rule 203 (g)
,
Deere plans to curtail coal burning
at the facility from May 30, 1975 until November 1,
1975 or such date
as the electrostatic precipitators may be placed in operation.
The
electrostatic precipitator program is on schedule, but Petitioner
states that the schedule is already so tight that it cannot be signifi-
cantly accelerated.
The second phase of Deere~scompliance program was officially
enatiated on May 16,
1973.
In view of the many commendable aspects
of this program, the Board feels that the program should be here
repeated as an example and informative aid to other companies experiencing
similar fuel allocation problems.
The first program called for:
1.
A conscientious attitude on the part of Deere employees
arising at least in part from a Company presentation
showing the need for fuel conservation.
2.
Reduced preheat of forge furnaces 1/2 hour, saving
61.4 x 106 BTU/day.
3.
All unnecessary machines and lights are turned off.
Discovery of failure to do this results in notification
to the department supervisors.
11—329
—4—
4.
All light switches have been identified and labelled
to facilitate more selective use of lighting.
5.
The power house efficiency has improved as it
approaches its design capacity.
Having realized a
6.5
reduction in fuel usage from the above
program,
Deere embarked on additional fuel saving measures for fiscal
year
1974 that are designed to reduce fuel usage by an additional
5.5.
These additional measures are:
Action
Status
1.
Lower factory building temperatures
from 70°to 65°F.
50
complete
2.
Reduce office temperatures
to 68°F.
100
complete
3.
Shut down heat and vent unit in the
work—in-process
area of Building V.
100
complete
4.
Install automatic controls on Dept.
902 paint conveyors so that wash
system pumps and burners will
automatically shut down when there
are no parts going through the system. Investigation Started
5.
Develop alternate methods of heating
forging billets and eliminating
various hot processes.
Investigation Started
6.
Continue employees awarer4ess program,
including posters and letters to
employees describing energy situation
and methods for conservation at home
and on the job.
Continuing Process
7.
Recycle weld fume exhausts
in Bldg.
R-9 through approved air cleaning
devices reducing heated makeup air
requirements by
16 February 1974.
Contract Let
8.
Install 1-1/2”
of urethane insulation
on walls of Bldg.
V and V-2 by
22 December 1973.
Material Delivered
Because of these measures, Deere is hopeful that there will ha no
need
to use the coal burning variance even if grailted.
Deere
al:;o
states that it does not plan to burn any coal unless absolutely
—5—
necessary nor does it plan to burn any more coal than necessary
to sustain minimum working conditions.
The Agency commended Deere’s fuel savings program and recommended
the variance be granted subject to certain conditions.
The Board
joins the Agency in commending Deere for its comprehensive fuel
savings program.
The corporate attitude thus shown convinces this
Board that Deere is sincere in its commitment to minimize any coal
burning in boilers
#7 or
#8.
Deere is committed to installing
electrostatic precipitators on the coal burning boilers on
a time
schedule that is acceptable to the Agency.
The fuel savings
program represents an excellent example of what can be accomplished
through corporate foresight and determination.
We believe Deere
has satisfied the prerequisite for a variance and we shall grant
the variance requested subject to certain conditions.
Finally, the Agency recommends
that the Board require
a stack
test to insure compliance with Rule
203(g).
However, very high
collection efficiencies are ordinarily achieved with electrostatic
precipitators,
and
we
have
not
been
presented
any
information
showing
that
Petitioner’s
program
might
fail
to
provide
the
degree
of control r~quiredto meet the emission limitations.
The electro-
static precipitators will not be operational during the one year
term
of
this
variance.
If
Deere
petitions
for
an
extension
of
this
variance, or if the Agency can reasonably question the efficiency
of Deere’s control program, then we would like
to hear arguments
as to whether such testing should be required.
However, we shall
not
at
this
time
require
a
stack
test.
ORDER
It is the Order of the Bo3rd that Deere
&
Company be granted
a
variance from Rule 3-3.112 of
the Rules and Regulations Governing
the Control of Air Pollution for
its East Moline Works until
February 14,
1975 for the purpose of burning coal
in boiler #7
or *8
in the event that oil and gas are unavailable in sufficient quantities
to meet the plant demand in excess of the capacity of boiler #9.
This
variance is subject to the following conditions:
1.
Petitioner shall utilize boiler
#9 on coal and
available gas prior to operating boiler
*7 or
*8.
Petitioner shall make quarterly reports of all
operations involving boiler #7 or #8, demands
required during the operations of boiler *7 or
*8,
and available gas during the period of operation.
These
reports
Shall
be
submitted
to:
The
Illinois
Environmental
Protn~nn
Aqency,
Divi~Hon
of
Aix
Pollution
Control,
Reqion
1
Office,
4332
North
Main
Street,
Rockford,
Illinois
61103.
11
—331
—6—
2.
Petitioner
shall
include
in
its
quarterly
report,
progress
made
toward
completing
its
anticipated
reduction of energy demand.
3.
Petitioner
shall
apply
for
all necessary construction
and operating permits
for the electrostatic pre-
cipitator control units
for boilers
#7,
#8, and #9.
4.
Petitioner
shall,
by March 29,
1974 post
a bond
in
theamount
of
$100,000
in
~
form
acceptable
to
the
Environmental
Protection Agency,
such bond
to ~e
forfeited
in the event Petitioner fails to install
the pollution control
on boilers
#7,
#8
and
#9 as
specified
in
its Compliance Plan
or any amendments
thereto.
Bond
shall
be mailed to:
Fiscal
Services
Division,
Illinois
EPA,
2200 Churchill
Road,
Springfield,
Illinois
62706.
I,
Christan L.
Moffett, Clerk
of
the Illinois
Pollution Control
Board, hereby certify the
above Opinion and Order was adopted this
~f~~day
of
~
1974 by
a vote of ___too
ii
—
332