ILLINOIS POLLUTION CONTROL BOARD
September
20,
1973
CPC INTERNATIONAL,
INC.
PCB 73—212
ENVIRONMENTAL PROTECTION AGENCY
JAMES
W.
GLADDEN,
JR.,
appeared for CPC
MICHAEL A.
BENEDETTO,
JR., ASSISTANT ATTOENEY
GENERAL,
appeared
for ENVIRONMENTAL PROTECTION AGENCY
OPINION AND ORDER OF THE BOARD
(by Mr. Dimelle)
A petition for variance was
filed by CPC International
(CPC)
on May 22,
1973, which sought permission
to deviate
for
a period
of one year from
the compliance
schedule CPC filed with the
Environmental
Protection Agency
(Agency)
pursuant to Rule
104
of
the Air Pollution Regulations of the Pollution Control Board
(Air Rules)
.
Petitioner requested this time extension
to study
the
feasibility of burning
the solid waste from the Chicago area
in its existing coal—fired boilers and
the use of
a baghouse
to
cont::nl particulate emissions
from boilers operated with coal
and w~threfuse
in combination with coal.
The Agency recommended
granting
the variance.
~C operates
a wet corn milling plant located
in Bedford
Park,
Illinois.
Five boilers produce steam for process and electric
power generation.
Two boilers are gas fired and three
are pulverized
dry bottom coal
fired boilers.
Each of the three coal fired boilers
has
a capacity
of 325,000,000 BTU input per hour and is equipped
with multicyclone dust collectors.
Particulate
emissions
from
the
three boilers are 0.484 lb/b6
BTU
(assuming a collection efficiency
of
90.2
on the multicyclones).
Rule
3-3.112 of
the Rules and
Regulations governing th~control
of Air Pollution allows particulate
emissions
of 0.48 lb./lO°BTU.
Pe?itioner
is required by Air
6
Rule
203
(g)
(3)
to reduce
its particulate emissions
to 0.1 lb/lO
BTU.
In order
to meet
this requirement,
Petitioner has filed
a
compliance schedule which anticipates purchase and installation of
electrostatic precipitations at
a total cost
of
$3,000,000.00.
If the variance
is not granted,
Petitioner can have
its boilers
in
compliance by May 30,
1975.
9
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297
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Particulate
monitoring,
by
the
Agency
In
the
Bedford
Park
area,
has
flown
levels
consistantly
above
the
primary
standard
of
75
pg/rn’
annual
geometric
mean
concentration
Rule
3Q7
(a) (1).
These levels have been generally improving since 1968
•
An
Agency air quality d~splaymodel showed t~atthe Petitioner
contributes 1.0 pg/rn
yearly
and
2.0 pg/rn
for 24 hours to the
air surrounding Bedford Park.
Testimony by the Donald C.
Douglas,
Chemist for the Bedford Park Environmental Quality Control Board,
showed
that
SO2
levels
in
the
area
have
been
below
federal
standard
for a long time
(R73—212, page 149).
Thus the synergistic effect
of high particulate and 502 levels should be absent in Bedford
Park.
S.0.R.E., a citizens’ group representing Bedford Park and
surrounding areas, appeared at the hearing and opposed the gran~ting
of the variance.
While S.O.R.E. was not
permitted
to intervene as
a party, it was given every opportunity to examine witnesses,
present testimony, and appear at a second hearing which was held
solely to accommodate S.O.R.E.
Their basic objection was that CPC
can meet the 1975 particulate standard by installing ESP and they
should not be allowed a year delay to “experiment” in an area
where the existing air quality is bad.
S.O.R.E. points out
that
CPC has not elaborated upon the local environmental effects of
CPC testing.
The Board feels that CPC has presented sufficient
evidence of the lack of the availability of such data due to the
special nature of the proposed concept of burning solid waste in
conjunction with coal in a pulverized suspension firing system.
While
the Board feels that S.O.R.E. has presented serious considerations,
we
are
of the belief that the variance should be granted with
conditions for the reasons to be set out below.
The one year delay that CPC seeks is to construct a baghouse
and firing equipment tc him
classified-shredded refuse alone or
in conjunction with coal in one boiler.
CPC prposes to divert
40 to 50
of the flue gas from one boiler through the baghouse
then back to the stack.
Remaining flue gas will pass through
the existing multicyclone emission control system.
Feasibility
tests would be run for approximately four months on a baghouse
system designed to control particulate emissions from their boilers.
Tests will show the effects of startup, shutdown, condensation and
maintenance problems on the bag filter system.
Additional testing
will be done to develop emissions data on the use of classified—
shredded municipal waste as a fuel supplement for an existing.coal
boiler, while burning refuse and coal in various combinations from
10 to 100.
These tests will be carried out on the boiler operating
at various stages up to 100
capacity.
CPC will buy the shredded refuse from Disposal, Inc. which
is currently constructing facilities to handle and process refuse
into an industrial fuel.
CPC will buy and test up to 250 tons/day
a—as
—3—
of shredded refuse whjch will
enable it to operate one boiler with
100
refuse
fuel when operating at full capacity.
The Board feels
that the data
to
be developed would be extremely helpful
in aiding
to solve such State and National environmental problems as solid
waste disposal, use of low sulfur fuel,
and energy consCrvation.
After the refuse has been shredded and
the
ferrous, non—ferrous,
and other
heavy components removed it consists primarily of
paper which has a ETU value of about 50
of coal and
is almost
equal
in ash content.
On an equal BTU basis
the refuse fuel would
produce slightly less than twice the ash and about 40
the sulfur
compared to low sulfur coal.
(low sulfur coal
is l.0~while refuse
has a 0.2
sulfur content).
The Board feels that the one year delay
in CPC compliance
with Rule 203(g)
(3)
and the four month testing program is far
outweighed by the information that will be obtained by Petitioner’s
experiment.
Petitioner’s testing program will be carried out during
the summer months of 1974 which is at a time when particulates from
other combustion sources
such
as heating are at their lowest point.
Since bag filters are normally more efficient than multicyclones
(99
v.
90),
Petitioner’s testing of bag filters on coal alone
should improve its emissions from one boiler.
The Board
is satisfied that the short testing program will not
significantly effect the air quality in the Bedford Park area.
The Board finds
thaf: Petitioner would suffer an undue economic
hardship if the variance were denied since Petitioner would have
tc spend $3,000,000.00 to abate a proljlem that might be capable
of solution by the use of
less expensive bag filters if control
data were available.
In addition Petitioner would be faced with
not
being
able to develop a new fuel source which could have substantial
economic and environmental benefits.
This opinion constitutes the Board’s findings of fact and
conclii~ions of law.
ORDER
The Illinois Pollution Control Board hereby grants to
CPC International,
Inc.,
a variance from Rule
104 of the Air
Pollution Rules and Regulations until September 20,
1974, provided
the following conditions are met:
1.
Within thirty
(30) days of the date of an order by the
Pollution Control Board in this
case, Petitioner shall submit a
new compliance program to the Agency indicating alternatives it
will choose to meet the May 1975 particulate standard contained
in Rule 203(g) and indicating compliance with said Rule by May 30, 1976;
9— 299
—4—
2.
Petitioner shall submit progress reports to the Agency
at bi-monthly intervals beginning the month after an order by
the Pollution Control Board in this case.
Said reports shall be
submitted to:
Variance Section
Division of Air Pollution Control
Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois
62706
and shall contain at a minimum:
a.
all reports and studies developed
by
CPC or its
agents concerning
the feasibility of burning solid waste
in its coal-fired boilers;
b.
all reports or studies prepared by CPC or its agents
concerning the methods of controlling particulate emissions
from coal—fired boilers when burning solid waste and refuse;
c.
a complete description of progress towards
the
installation and development of a solid waste processing plant;
d.
a complete description of progress made toward the
decision of whether or not to burn solid waste in its boilers;
e.
all tests developed by CPC or used by CPC in deciding
what type of control would be feasible for burning coal and
solid waste.
3.
Petitioner shall institute
a pilot program using a haghouse
as a control device on its coal fired boilers.
During the period
of study,
Petitioner shai~supply the Agency with all studies and
reports concerning this project.
Petitioner shall perform a stack
test
on the fabric filter project and shall notify the Agency at least
five
(5)
days
in
advance of any test.
Notice of any test shall be
given to:
Environmental Protection Agency
Division of Air Pollution Control
Illinois Naval Armory
East Randolph and The lake
Chicago,
Illinois
60602
Petitioner shall submit
a complete report of any tests to the Agency
as
soon as the results are available
to Petitioner.
4.
Petitioner shall allow access to Agency personnel during the
period of the study to its hoilerhouse facility and shall make
available all reasonable information requestrd pertinent to this
Variance request.
9
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300
—5—
5.
Regardless of the decisions Petitioner makes during the
one year program, Petitioner shall be in compliance with Rule
203(g) by May 30,
1976.
Petitioner
shall perform a stack test
on its boiler facility to determine compliance with Rule 2O3(g).
The Agency shall be notified of any test.
Notice shall be given
to:
Environmental Protection Agency
Division of Air Pollution Control
Illinois Naval Armory
East Randolph and The Lake
Chicago, Illinois
60602
Petitioner shall allow Agency observations if desired and shall
make available to the Agency results of said tests as soon as
they are available to Petitioner;
6.
Petitioner shall apply for and receive
from the Agency any
necessary permits that pertain to this program;
7.
Within thirty-five
(35)
days of the date of an order by
the
Pollution Control Board, Petitioner shall submit a performance
bond
in
a form approved by the Agency and in the amount of
$500,000.00.
Said bond shall ensure completion
of the following
items
and shall be reduced in an appropriate amount as the state
is completed:
a.
completion of the test fabric filter program at
the Bedford Park plant,
$150,000 reduction;
b.
obtaining of construction permits on
a control
device chosen by Petitioner
to meet the standard set forth
in
Rule 203(g)
$150,000 reduction;
c.
completion of the program and stack test showing
compliance with Rule 203(g), $200,000 reduction.
8.
If at any time during the one year test period Petitioner
makes
a decision to scrap the proposed refuse burning project, the
Agency and the Board shall be immediately notified, and Petitioner
shall immediately order a control device to meet the standard contain
in Rule 203 (g).
Petitioner shall make an immediate application to
the Board for a new Variance and submit
a revised compliance program
to the Agency.
9.
At all times during the variance,
the existing control
equipment shall be maintained and operated at existing efficiencies.
9
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301
—6—
10.
The
emissions from the plant shall not cause
a violation
of the Federal
24 hour particulate standard.
IT
IS SO ORDERED.
I,
Christan
Moffett,
Clerk
of
the Illinois Pollution
Control Board,
hereby certify
the above Order was adopted
on
the
__________
day
of
____________,
1973 by a vote of
_________
to
9
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302