ILLINOIS POLLUTION CONTROL BOARD

January 17, 1974

OLIN CORPORATION,

Petitioner,

vs.

PCB 73—450

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Thomas B. Martin, Attorney, on behalf of Petitioner.

Thomas R. Casper, Attorney, on behalf of Respondent.

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

On October 25, 1973, Olin Corporation filed its

Petition for Variance, seeking variance from the provisions

of Section 9(a) of the Illinois Environmental Protection

Act and Rule 3-3.112 of the Rules and Regulations Governing

the Control of Air Pollution (establishing particulate

emission limitations) until March 31, 1974.

Petitioner operates a facility, consisting of an area

of approximately 1,732 acres at East Alton, Madison County,

Illinois, wherein it manufactures brass strip and fabricated

products, metallic and shot shell ammunition a’~doperates

a steam generating plant and a potable water treatment

plant. Approximately 5,700 employees are currently employed

at Petitioner’s East Alton facility.

Petitioner’s power plant consists of two 75,000 lbs/hr

boilers and two 150,000 lbs/hr boilers. The two 150,000

lbs/hr boilers are operated to supply the necessary steam

load during normal operations; the two 75,000 lbs/hr boilers

are maintained in wet lay up and are not operated Linless

there occurs an outage of one of the primary boilers.

All of the boilers have the capability of using either

natural gas or coal, or both, as a fuel supply. However,

one of the primary boilers must have 80 of its rated output

supplied by coal firing before natural gas can be used to

supplement the coal when both fuels are fired simultaneously.

10— 697

—2—

This is due to its pressurized continuous stag 

tapping

wet bottom design.

Petitthner’ s natural gas supply can

be supplemented with propane-air mixtures up

to

125,000

CFH of natural gas equivalent by a Propane—Air Plant owned

and operated by Petitioner.

Petitioner alleges that it has made 

every

possible

effort to insure that it will have adequate, clean fuel

supplies during the 1973-74 winter heating season to

sustain operation of its facility. However, Petitioner

states that factors completely beyond its control 

—

the

recent, unexpected Federal embargo on propane; the uncertainties

regarding the amount of curtailment of natural gas; and the

shortage of l~w ash coal

have placed Petitioner

in a

position in which it is probable that it will be in violation

of the present particulate emission regulations during the

1973—74 winter season.

Petitioner’s natural gas suoply has been unexpectedly

curtailed for the first time. This curtailment was to levels

as low as 30 of the original contract demand of 10 million

cubic feet per day. On October 2, 1973, the Energy Policy

Office placed in effect the Mandatory Propane Allocation

Program. Petitioner asserts that this program may have a

severe affect on its estimated requirements of propane for

the 1973-74 heating session.

For example, Petitioner has been

required to sell 1,100,000 gallons of propane because it 

was

being held in storage for Petitioner. Finally, Petitioner

has been able to acquire only 8,000 tons of low ash coal

for this season. Illinois coal having an ash content of 10.18,

a heating value of 11,286 BTU/lb, and a sulfur content of

3.18~ is expected to be available as required.

The Agency is of the minion that Petitioner has made a

good faith effort to obtain complying fuels. The Agency

recommends that should the quantities of natural gas, propane

and low ash coal obtained

be

insufficient

to meet Petitioner’s

requirements,

then Petitioner

should be permitted to use high

sulfur—high ash coal even 

if the limitations of Rule 3-3.112 are

thereby exceeded.

As a result of the anticipated fuel shortage, Petitioner

has retained engineering consultants to determine the pollution

control equipment which will be required in order to achieve

compliance wIth the new particulate regulations (Rule 203(g)) when

high sulfur coal is employed. Petitioner’s new compliance

program indicates compliance by 

May 30,

1975. During the Agency

Investigation, agents of Petitioner indicated that Petitioner

will

probably utilize flue gas scrubbing using a caustic

solution and Petitioner~s sewage 

treatment plant to handle the

—3—

scrubbing solution. The Agency is of the opinion that

this program could achieve complaince with both Rules

203(g) and 204 and that the time schedule is reasonable.

The Agency has received no objections to the granting of

this variance from the public.

We are of the opinion that Petitioner has exercised

good faith in its efforts to obtain complying fuels under

extraordinary conditions and that its current problems are

not self-imposed. We note also that Petitioner has had

the foresight to develop a system of fuel use which will

keep violations to a minimum in the event that high sulfur-

high ash coal must be used. The variance will be granted.

However, Petitioner’s statements regarding environmental

impact are quite meager, and Petitioner is hereby put on

notice that a more substantial treatment of this area will

be necessary should Petitioner !equest an extension of the

instant variance.

This Opinion constitutes the findings of fact and

conclusions of law of the Board.

ORDER

IT IS THE ORDER of the Pollution Control Board that

Petitioner, Olin Corporation, be granted variance from Rule

3—3.112 until March 31, 1974 to operate the power plant at

its East Alton facility, subject to the following conditions:

1. Petitioner shall utilize gas, propane and

low ash coal as much as possible to maintain

compliance with Rule 3—3.112;

2. Petitioner shall report, in writing,to:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Springfield, Illinois 62706

on February 1, 1974 and March 1, 1974 the amount

of propane, natural gas and coal burned in its

boilers and the amount of propane, natural gas

and coal available to Petitioner;

3. Should Petitioner seek an extension of this

Variance for the 1974-75 winter, Petitioner

shall submit a compliance program indicating

compliance with Rules 203 and 204 for its boilers

May 30, 1975,

—4—

IT IS SO ORDERED.

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

Control Board, certify th~tthe thove Opinion and Order

was adopted on this 

/ 1

day of

______________,

1974

by a vote of 

—

700