ILLINOIS POLLUTION CONTROL BOARD
    November 15, 1973
    MEDUSA CORPORATION,
    Petitioner,
    V.
    )
    PCB 73—337
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent
    William H. Wallace, Attorney for Petitioner
    Lee Campbell, Assistant Attorney General for the EPA
    OPINION AND ORDER OF THE BOARD (by Mr. Henss)
    Nedusa Corp~ration filed a Petition for Variance requesting
    relief from Rules 202(b) (visual emission standard), 203(b) and
    203(d) (3) (particulate standards) and 203(1) (compliance dates)
    of the Air Pollution Control Regulations until March 31, 1975,
    pending installation of air pollution control equipment at its
    cement manufacturing plant located near Dixon, Illinois. A public
    hearing was held on October 4, 1973.
    At this plant, one of seven cement plants in the Medusa
    cement division, Petitioner manufactures 10 different types of
    cement and cement products. The plant began operations in l9fil
    and currently has a manufacturing capacity of 3.2 million barrels
    per year. Petitioner’s Dixon plant produces 30 of the cement
    manufactured in Illinois and 15 of all cement consumed in
    Illinois (R.89). An average of 183 persons are employed at the
    plant which ooerates 24 hours a day year around.
    Petitioner uses a dry manufacturing process for producing
    portland cement. Limestone, clay, sand, power house slag and
    gypsum are the principle ingredients. After being crushed,
    dried and ground, the raw feed material is introduced into ~ne
    of the four rotary cement kilns. The kiln heats the raw feed to
    about 27000 F. by the combustion of coal and/or gas to convert
    the calcium carbonate (limestone) to calcium oxide, a process
    known as limestone calcining. The calcium oxide then combines
    with the other raw feed ingredients to form “clinker”, the basic
    component of cement.
    The clinker is discharged to clinker coolers which, in this
    case, are oscillating grates through which ambient air is passed
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    to absorb heat from the clinker. Part of the heated air is
    returned to the kilns for use as preheated combustion air.
    Excess heated air is vented through dust collectors to the
    atmosphere. The clinker coolers for kilns 1, 2 and 3 are
    equipped with Buell L-R settling chamber type collectors. The
    clinker cooler for kiln 4 is equipped with a Western—Precipi-
    tation inulticlone.
    Charles L. Howlett, Vice President of Operations, Cement
    Division of Medusa Corporation, testified that the emission
    control devices on the 4 clinker coolers provide efficient
    control during normal operations but could not meet the regu-
    latory limits during periods of kiln upset or control equipment
    malfunction. Howlett testified that such upsets occur when
    there are changes in the chemistry of the raw materials or fuel
    or when the ratio of coal to gas is changed. The upsets result
    in the raw material being “overburned” or “underburned”. When
    overburning occurs, the clinker becomes molten and “goes over
    the end of the kiln”. If the raw material is underburned, “the
    raw mix doesn’t clinker and comes over the nose of the kiln in
    the form of dust.. .tliat’s only partially calcined”. Howlett
    estimated that such upsets occur during less than 3 of the
    annual operating period.
    Petitioner stated that emissions from the clinker coolers
    “may exceed the Board’s emission standards” during periods of
    kiln upset, but that measurement of emissions is impossible
    during these brief periods. Using standard emission factors and
    information from Petitioner’s operating permit applications, the
    Environmental Protection Agency calculated Petitioner’s emissions
    from the clinker coolers to be 433.6 lbs./hr. We were unable to
    determine whether the Agency represented this figure to be emissions
    during normal operations or during upset periods or the average
    emission for all operations. Under Rule 3—3.111 of the Rules and
    Regulations Governing the Control of Air Pollution, Petitioner is
    allowed 112.58 lbs./hr. from the clinker coolers until December 31,
    1973. After that date, Petitioner’s aggregate allowable emission
    rate under Rule 203(b) of the Rules will be 47.37 lbs./hr.
    Because the excessive emissions could not be controlled
    before the December 31, 1973 compliance date, Petitioner’s appli-
    cation for operating permits was denied by the Agency on April 2,
    1973.
    Petitioner previously held a variance while baghouses were
    installed on the three preheater kilns (kilns 1, 2 and 3)
    .
    Some-
    time during the Fall of 1972 Petitioner decided that baghouses
    would also be required to control emissions from the clinker coolers
    (R. 80) and $600,000 was budgeted for the project. Preliminary
    engineering investigations began immediately and manufacturers of
    control equipment were contacted in March 1973. The original
    10
    — 100

    —3—
    proposal called for the installation of separate haghouses for
    each clinker cooler to be located on top of the “burner building”
    (R. 74)
    .
    Bids received in April 1973 caused Petitioner to re-
    evaluate the project and to change the location and basic design
    of the baghouses.
    Petitioner
    decided
    to
    install
    one large bag-
    house outside the burner buildinq and use duct work capable of
    moving 185,000
    cubic feet
    of air per minute.
    The large baghouse
    will have two chambers for each clinker cooler,
    so that one
    chamber for each cooler can be in operation while the other is
    being cleaned or repaired.
    Revised proposals were sent out in September 1973 and
    several bids have been received. Although Petitioner has not
    yet made a final decision on
    the
    bids
    the Meduse Corporation has
    authorized the expenditure of $1,203,000 for thc project (Petitioner
    Exhibit Jl-J2)
    An EPA engineer investigating Petitioner’s plant on August 22,
    1973 observed the startup of kiln ~l which had been down for
    removal of a
    mud ring.
    Emissions from
    the
    clinker cooler appeared
    to have an opacity of 100
    at 10:30 a.m., but this had been reduced
    to about 50
    by 2:00 p.m.
    Particulate
    emissions from the other
    operating clinker coolers appeared negligible.
    Emissions from a
    307’ stack venting the gasses from preheaters
    #1,
    2
    and 3 were
    observed to vary from 30~ to 50 opacity.
    The Agency investigator
    was informed that some of the bags in the baghouse were torn and
    that this caused the high opacity readings.
    The torn bags are
    being
    replaced.
    The Anency has recommended grant of the variance but only
    until September 1, 1974. Although the Agency is of the opinion
    that Petitioner’s proposed program will bring the plant into com-
    pliance with the
    Regulations,
    the Agency contends that Petitioner’
    s
    Project
    Completion Schedule is unreasonably long. The Agency
    position was based on a time table contained
    in a
    draft
    copy
    of
    a U. S. EPA publication.
    rl~hiS
    draft publication
    indicated that a
    haghousc installation on a cement kiln could reasonably be expected
    to take about 68 weeks.
    Robert Goldberg, Manager of EPA’s Variance Section testified
    that the proposed 9 month
    period
    for ectuipment fabrication and
    delivery was excessive.
    Goldberg stated that 26
    weeks would be a
    more realistic
    time period (P. ill)
    .
    Four bids introduced
    Lnto
    evidence
    support Goldberg’s contention and
    in fact, show six months
    as the maximum delivery period anticipated by any of the four
    companies submitting bids. However, Goldberg added that
    the Agency
    had not been provided certain information when drafting
    the
    Recommendation which, if now considered,
    could possibly alter
    the
    Agency position.
    The missing information
    pertained to electrical
    hardware for which delivery was not as
    predi ctable.
    10—101

    —4—
    The Agency presented two letters from citizens who felt
    that Medusa should not
    receive the variance. The letters
    describe the soiling and damage to property experienced as a
    result of the cement dust emissions. Mrs. Ralph C. Davis
    stated that she dreaded to think what it would be like if
    Medusa were granted a variance “which would increase their
    emissions”. The variance, however, will not allow Petitioner
    to increase emissions but only to continue emissions at the same
    or lower rate pending installation of control equipment. We
    would also advise Mr. L. H. Petersen that, contrary to his
    understanding, Medusa was not asking until March 3, 1975 to begin
    the project. One witness at the public hearing testified
    about his experiences with the cement dust emissions. While he
    opposed the granting of a variance, he stated that his problem
    would not justify closing the plant.
    Testimony and letters in favor of granting the variance
    caine from the Illinois State Toll Highway Authority, the mayor
    of Dixon, the Dixon Chamber of Commerce, managers of Ready—Mix
    Concrete plants, the Union secretary representing workers at
    the plant, employees and others. A summary of this testimony
    would show that the loss of cement produced by Medusa at its
    Dixon plant would severely damage the road construction industry
    in Illinois, On the whole, Medusa was characterized as a good
    industry and good neighbor for the Dixon community and as an
    industry that has shown good faith over the years in trying to
    control its emissions.
    Petitioner also introduced several documents which purport
    to show cement dust is not a lung irritant and that inhalation
    of cement dust is harmless to the lungs and to general health.
    The Agency did not respond to this point.
    Petitioner did not request variance from Rule 3-3.111 of
    the Rules and Regulations Governing the Control of Air Pollution,
    which Rule is applicable to the plant’s operations until
    December 31, 1973. The Company is allowed higher emissions under
    Rule 3-3.111 than will be allowed under Rule 203(b).
    From the entire record, we believe Petitioner should have a
    variance. A denial of variance could cause substantial hardship
    to Medusa and others in the State far outweighing environmental
    damage caused by plant operations. We shall grant the variance
    but only until November 15, 1974, since that is the limit allowed
    by Statute. If additional time is required, Medusa should file
    another variance request at least 90 days prior to the expiration
    date of this variance. An extension of this variance should not
    be considered automatic. Petitioner shall have to prove to this
    Board that it has diligently pursued the compliance plan and
    project completion schedule that we approve today.
    10
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    —5—
    ORDER
    It is
    the
    order of the Board that:
    1. Medusa Corporation is granted variance from Rules
    202(b), 203(b), 203(d) (3) and 203(i) of the Air
    Pollution Control Regulations for four (4) clinker
    coolers at its Dixon cement manufacturing plant
    until November 15, 1974 pending installation of a
    haghouse to control particulate
    emissions from the
    four clinker coolers.
    2.
    Medusa shall, by December 20, 1973, post a bond in
    the amount of $100,000 in a form acceptable to the
    Environmental
    Protection
    Agency, such bond to be
    forfeited
    in the event the baghouse control device
    is not installed
    as described during these proceedings.
    The bond shall be mailed to Fiscal Services Division,
    Illinois
    EPA, 2200 Churchill Road, Springfield,
    Illinois
    62706.
    3. Beginning January 1, 1974, Medusa shall subiait
    quarterly progress reports to the Variance Section
    of the Environmental Protection Agency. Such reports
    shall detail all progress toward comaletion of the
    clinker cooler baghouse project.
    4. Medusa shall attempt to expedite completion of the
    baghouse project and shall renort such efforts in
    its quarterly report to the Agency.
    5. Medusa shall apply for all necessary construction
    and operating permits for its Dixon plant.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control Board,
    hereby certify the above Opinion and Order was adopted this
    J~~’ day of
    _______
    1973 by a vote of ~ to ~
    /
    10— 103

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