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Journal of the Air Pollution Control Association

ISSN: 0002-2470 (Print) (Online) Journal homepage: http://www.tandfonline.com/loi/uawm16

Air Pollution Equipment for Foundry Cupolas

Robert W. McIlvaine

To cite this article: Robert W. McIlvaine (1967) Air Pollution Equipment for Foundry
Cupolas, Journal of the Air Pollution Control Association, 17:8, 540-544, DOI:
10.1080/00022470.1967.10469015

To link to this article: https://doi.org/10.1080/00022470.1967.10469015

Published online: 16 Mar 2012.

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ROBERT W. MclLVAINE,
Vice President,
Air Pollution Equipment for
National Dust Collector Corp.,
Skokie, III. Foundry Cupolas
The choice of air pollution equipment best suited for a specific foundry cupola involves the consideration of a
number of factors.—They are: (1) The design of the cupola, including openings, door enclosures, height of
stack, etc. These features greatly affect the size, cost, and efficiency of control systems. (2) The con-
stituents of the effluent gas and the other properties, such as temperature and volume, are extremely im-
portant because corrosion, warpage, and low efficiency can result from these variables. (3) Four distinctly
different types of air pollution control equipment are available for cupolas. They vary widely in initial
cost, operating cost, and maintenance, but also vary widely in efficiency. (4) Local air pollution regulations
and community considerations dictate the choice of air pollution equipment. Those regulations now in force
are quite stringent in some localities, but quite lenient in others. An incremental approach to installation of
systems would make one economically feasible for the small foundry.

Vontrol of cupola (hist emissions typical control device on cupolas. ations of air pollution control require-
represents one of the greatest challenges More recently, companies have invested ments are necessary in order to make the
to our industry. Not only is there a large sums of money on much more best and most economical design. The
large quantity of sub-micron fume gen- sophisticated systems. As a result, a design of the cupola itself and the charg-
erated, but there can be a considerable great deal of experience has been ac- ing arrangement may have a great effect
amount of oil. Sulfur dioxide and/or cumulated in the field and much is now on the cost and performance of the
fluorides can make corrosion a problem. known about the effective control of cupola system.
In addition, the temperature of the gases these emissions. Some of this informa- The vertical height of the cupola is
may well exceed 2000 °F for extended tion is compiled below. important because if there is a sufficient
periods of time. It is, therefore, not stack height below the charge door, but
surprising that foundries have been slow Cupola Design
above the melting zone, it is possible to
to invest in the expensive equipment Within an existing cupola, there is consider an exhaust gas takeoff at this
necessary to effectively eliminate the little that usually can be done to change point utilizing the charge itself as a seal.
problem. its configuration without an impractical This is called the below-charge takeoff
For many years the wet cap was the expense. With a new cupola, consider- system. If, however, there is not suffi-
cient height between the tuyeres and
charge door, it is impossible to even con-
sider this type of design. The stack
height also affects the temperature of the
gases that are exhausted.
The height above the charge door in
above takeoff systems is also critical.
With the wet cap, the amount of air
which is pulled in through the charge
door and thus, the environmental condi-
tions around the charge door, are
affected directly by the height of stack
above the door. The height, plus the
difference in density between air in the
stack and ambient, determines the in-
filtrated air. The addition of a wet cap
to an unencumbered stack will reduce
the flow of infiltrated air, unless the
stack height is increased commensu-
rately.
The method of charging is also a fac-
tor because it dictates the amount of in-
filtrated air that is required. For in-
stance, in one installation in England a
vibrating feeder is used to charge the
raw materials into the cupola. The
opening in the cupola shell is quite small
and the amount of infiltrated air re-
quired is also low. In contrast, with a
Fig. 1. Air-cooled door enclosures reduced required air volume. crane-type charger and a large open

540 Journal of the Air Pollution Control Association


charge door, large quantities of infil- Table I—In-Leakage Calculated from Gas Analyses3
trated air are required in order to pre-
vent puffing. Dilution
If the skip-type charger is used, it is Volume
Per Cent of
possible to shroud the charger and Date Time Cupola Burners Ch arge Door Blast Air
thereby form a hood which tends to
10/12/66 11:20 A North On Closed 181.
keep the contaminants in the cupola and 10/12/66 12:15 P North Off Closed 91.5
reduce the air volume requirements. 10/12/66 12.-15P North Off Closed 98.3
With either the crane or the skip-type 10/12/66 1:20 P North Off Open 553.
charger, enclosures can be placed over 10/12/66 1:50 P North Off Open 515.
10/13/66 2:05 P South Off Closed 43.4
the charge door opening to prevent es-
a
cape of fumes and reduce the air require- The cupola is 108 in. diam gray iron cupola with no control equipment.
ments. One of these is shown in Fig. 1. realistic evaluation of the emissions from Many cupolas operate on a continu-
There is some possible difference in a cupola, the melt rate, volume of infil- ous basis, with gas discharge tempera-
operation between the water-cooled and trated air, the total emissions/hr, and tures as low as 300°F except during
refractory lined cupola. If after-burn- the grains/std cu ft should be evaluated. burn-down. Other cupolas maintain
ing of the gases is desired, the refractory
temperatures above 1600°F a large por-
lined cupola creates a hotter contact Gaseous Emissions
tion of the time. During burn-down,
area and supports combustion of the car- Since the sulfur content of coke is gen- the temperature may exceed 2000 °F.
bon monoxide, oil vapor, and coke erally 0.6% or less, the quantity of SO2 Note the wide temperature variation
breeze. generated is considerably less than within less than 2 hrs on the cupola
Especially designed cupolas have en- would be found in a coal-fired steam shown in Table II. The exhaust gas
abled the reduction in air volume re- generator with 3-4% sulfur. However, temperature is greatly affected by the
quirements to as low as 20% of the blast there is a measurable amount of SO2 and quantity of infiltrated air. If the sys-
air. This is contrasted to the standard it should be taken into consideration as tem is designed using the stack tempera-
cupola which requires from 200 to 500% a contaminant. In one large cupola re-
of the blast air to be infiltrated through cently surveyed, the uncontrolled emis-
the charge door opening. sion of SO2 was approximately 74 lb/hr.
Constituents in the Effluent Gas The quantity is also large enough to be a
definite consideration from the stand-
The second factor affecting the choice point of corrosion of air pollution control
of a cupola dust control system is the equipment. There are a number of in-
composition of the contaminants. stances of rapid deterioration of dust
Quantity and composition vary between collectors on cupolas where corrosion
cupolas and even at intervals in the same protection was not considered.
cupola. Causes are changes in iron to Because fluorspar is often used as an
coke ratios, air volumes per ton melted, additive, the fluorine driven off can
stack height, and particularly in the cause a corrosion problem on dust collec-
quality of the scrap melted. tion equipment and its presence, there-
Where oily scrap is charged, the par- fore, should be noted. Fig. 2. A typical cupola cap.
ticulate emissions not only are greater in
quantity, but are much more visible.
Some emissions have contained as much
as 30% oil. The American Foundry-
men's Society, in a new manual on air
pollution to be released shortly, com-
piled a survey of cupola emissions and
found that an average emission of an
uncontrolled cupola was approximately
17 lbs of particulate/ton melted. Here
again, there is a wide variation for in-
dividual cupolas.
The evaluator of these emissions
should bear in mind that the stack ve-
locity has a great effect on the quantity
of emissions. The higher the stack ve-
locity, the more large particles which will
be emitted—thus the particle size dis-
tribution and quantity of emissions
change with stack velocity.
Since the amount of infiltrated air
varies widely, the grains/standard cu ft
emitted varies, even though the total
pounds emission/ton is the same in two
similar cupolas. In fact, in the stan-
dard uncontrolled cupola as shown in
Table I, there is a wide variation in in-
filtrated air during the course of the
day. The emissions/ton remain con-
stant, but the grains/std cu ft being
emitted would have gone up and down
as much as 50%. Therefore, to make a Fig. 3. Cupola control system.

August 1967 / Volume 17, No. 8 541


Table II—Volume of Cupola Stack Gases by Pitot Traverse11 300°F. One exception would be fabric
filters which do not use glass bags.
Volumes by
Charge Temp., Pitot Traverse Types of Dust Collection Equipment
Date Time Cupola Burners Door °F A.C.F.M. S.C.F.M.
Five types of dust collection equip-
10/13/66 9:30 A South On Closed r>80. 70,300. 30,400. ment being purchased are:
10/13/66 10:00 A South On Open 400. 58,700. 30,600.
10/13/66 11:15 A South Off Open 80. 74,400. 61,800. 1. Wet caps
a
The cupola is 108 in. diam gray iron cupola with no control equipment. 2. Fabric filters
3. Low-pressure drop wet scrubbers
Table III—Methods of Evaluating Collector Performance 4. High-pressure drop wet scrubbers
5. Multi-tube cyclones
Participate Emission -—Per Cent Efficiency—- These basic types differ widely in effi-
grains/scf High Stack Low Stack
500% 50% Velocity Velocity ciency, maintenance, and cost.
Infil. Infil. Performance of Types1 of 17 lb/ton 12 lb/ton Evaluating the efficiency of these
Ib/hr Air Air Cupola Collectors' Inlet Inlet collectors necessitates the evaulation of
a number of factors. To consider one
0 0 0 100% 100% yardstick alone may greatly distort a
fair comparison between units. The
17 0.02 0.09 95 93 best theoretical comparison is on the
0.05 basis of efficiency of various particle
34 0.19 90 86
sizes. The fabric filter and high-energy
scrubbers operating at 70-in. water
85 0.12 0.48 67 gauge are capable of removing particles
as small as W - The low-energy scrub-
bers are highly efficient on particles 5/x
and larger. The multitube cyclones are
highly efficient on particles 10/x and
larger. The wet caps are efficient only
170 0.24 0.96 50 29 on particles above 44^i.
No collection Comparisons and evaluations are
340 0.48 1.92 o% often made on percentage efficiency, on
For 14,000 scfm, blast air melt rate of 20 tph anil emission of 17 lbs per ton with no collection and grains/std cu ft, or on a proce.-s weight
h stack velocity. basis. The dangers of using only one of
these yardsticks are illustrated in Table
hires prior to the installation of emission of the cupola. Tts purpose is to prevent III. The first column contains the
control equipment and with high quan- the escape of dust during operation of pounds emission/hr with 340 lb at the
tities of infiltrated air, the system may the dust control system and, in the case bottom representing no collection, based
be undersized. When the system is in- of an emergency shutdown of the dust on emission of 17 lb/ton, and 20 tons/hr
stalled and the quantity of infiltrated air control system, to open and allow the melted.
reduced, the stack temperature rises. dust to by-pass to the atmosphere. Column 2 shows the emission/std cu
The stack temperature is also greatly The design of these doors is quite diffi- ft with 500% infiltrated air for the
affected by the use of after-burners. cult because of the excessive tempera- pound emission shown in Column 1.
This is also illustrated in Table II. tures that arc encountered and the diffi- Column 3 shows the grains/std cu ft for
culty of maintaining a tight seal. A the pounds shown in Column 1, but with
Control Systems typical cap is shown in Fig. 2. Al- 50% infiltrated air. For instance, with
The third dimension is the emission though the static pressure at this point 50% collection, or 170 lb/hr being
control system itself. The first consid- is negative, the caps will puff because emitted, the grain loading would be 0.24
eration in the design of the system is the velocity pressure of the air, which is grains from a stack with 500% infiltra-
selection of the proper air volume. The positive, is greater than the static pres- tion, but 0.96 grains from a stack with
system obviously has to be able to sure which is negative, causing a positive 50% infiltrated air and 50% collection
handle the blast air, but it also must in- total pressure at any openings. Thus, efficiency. Since wet caps are generally
filtrate enough air through any openings nearly all systems puff small quantities used for large quantities of infiltrated
to minimize the outward leakage of dust of dust into the atmosphere. air, outlet loadings from wet caps may
and CO. One working figure that has The next consideration is the takeoff be low in comparison to other types of
been used has been a minimum in-draft duct which brings the gas down to the dust collectors, which use less infiltrated
of 300 ft/m through all openings. Us- dust collector. The temperature and air. The same statement could be also
ing this criterion, the next step is to corrosion possibilities should definitely made for the multitube cyclone which
minimize the opening area as much as be considered in the design of this sec- in general uses more infiltrated air than
possible. This can be accomplished by tion. Most dust collection systems in- other types of equipment.
charge door enclosures. Many of these corporate some method of gas cooling at Even percentage efficiency can be mis-
have been tried in the past and only a some point very close to the cupola. leading. Columns 5 and 6 show why
few have been successful. Warpage This can take the form of sprays in the this is so. Where high-stack velocities
and mechanical problems have been the ductwork, a quench tower, or in the case are encountered, large particles are
cause of the failure, but well designed of some dry collectors, a long run of carried out the stack along with the
doors can greatly reduce the cost of the ductwork to obtain sensible cooling. smaller ones. Therefore, the particle
emission control system and are, there- For wet collector systems, the evapora- size distribution will not be the same.
fore, highly practical. The proper de- tive cooling is the most economical and The 17 lb emitted is shown in Column 5,
sign can minimize the maintenance on practical approach. For most wet versus the 12 lb/ton emitted from the
these items. and/or dry systems, it is not necessary cupola with the low-stack velocity as is
With the air volume selected, the next to reduce the temperature entering the shown in Column 6. The same collector
consideration is a seal or cap on the top dust collection equipment to below would have a different percentage effi-

542 Journal of the Air Pollution Control Association


ciency for these two conditions. Table IV—Cupola System—Comparison
The high-stack velocity is often ac- (Two no. 8 cupolas—7800 cfm blast air alternate usage—1 gr/scf dust load)
companied by the high percentage of in-
filtrated air. This tends to make col- Initial Cost Outlet
lectors using this combination decep- Installed M & O Cost/year Emission, Connected
Equipment in $1000'sa in $1000'sb gr/scf° Horsepowerd
tively attractive, with regard to percent-
age efficiency and grains/std cu ft out- Wet cap 50 3 0.5 20
let. The more efficient and expensive Multitube cyclone 150 10 0.3 100
6 in. AP scrubber 150 10 0.2 100
collectors tend to minimize the air re- 70 in. AP scrubber 225 25 0.05 325
quirement for economical purposes and, Fabric filter 250 Wide variations <0.02 100
therefore, have lower stack velocities, a
and lower quantities of infiltrated air. b
With water clarification system and ductwork, electrical, etc.
Maintenance and operating cost per year, including power costs for 16 hr/day opera-
The efficiency levels shown on the tion, but not depreciation.
0
chart are for maximum performance. Outlet emission also dependent on particle size distribution, which in turn is dependent
It is well to keep in mind that some col- ondscrap quality, etc.
lectors consistently perform at the max- Connected horsepower, including pump for wet units.
imum level, whereas other types very
seldom perform at the maximum level.
The fabric filter, for instance, is the most
efficient of the collectors, but only where Cost with extremely low maintenance. The
there are no broken or torn bags. Sev- Table IV tabulates the approximate difference may lie in the equipment fur-
eral baghouses in operation on cupolas installed cost of cupola systems on each nished, in the conditions within the in-
are performing below their maximum of the types of collectors described. In dividual cupolas, or in the quality of
capability for this reason. Worn ele- general, it can be assumed that the more maintenance. In several instances, ex-
ments in the scrubbers or cyclones can efficient the collection equipment, the treme corrosion on wet scrubbers of mild
also lower performance. Warpage of more expensive the installation. But steel construction has occurred. Severe
the cone of the wet cap will reduce its beyond this, any specific assumptions corrosion of several dry units has also
efficiency. have to take into account a number of been experienced.
Another dimension in comparing the variables. The cost per cfm for any of Fans are potentially high maintenance
efficiency on the different types of collec- the types can vary widely, depending on equipment. The high-pressure drop
tors is the stack appearance. The fab- the cupola size, blast volume tempera- scrubbers use expensive large fans, de-
ric filter and the high-energy scrubber at tures, physical location, etc. veloping very high pressures. Some
70-in. drop will emit very little dust, but As an example, it might be necessary sort of cleaning device is often necessary
unless the vapor from the high-energy to add a substantial section to the cupola to prevent build-up on the blades.
scrubber is condensed in an after-cooler, stacks in order to obtain the proper When the build-up does occur, the main-
there will be a vapor plume. stack effect for the wet caps. The addi- tenance expense can be substantial.
The wet cap, and to a lesser extent tional support required for the wet caps Temperature is another big factor in
the multitube cyclone, have little effect might entail a very expensive installa- the maintenance and operating expense.
on coloration of the plume. This is be- tion cost, so in this specific instance, the The cones on wet caps may have to be
cause the fine sub-micron particles with cost of the low-pressure drop scrubber or regularly replaced because of tempera-
most of the surface area are still passing multitube cyclone might be comparable. ture problems. The ductwork, inter-
through these units. Misconceptions Another complication is that many of nals of the dust collectors, and the fan
regarding the abilities of these units to the costs do not vary with the size of the can be easily damaged with a system
reduce the Ringelmann number of the system. Such things as control panels failure which does not allow by-pass of
stack are caused by several other and quench systems are approximately the hot gases.
factors: the same price, regardless of the system The wet cap has no moving parts
size. Other items such as caps, collec- other than a pump and is very likely to
1. After-burners are often installed at tors, and ductwork show a lower be quite low on maintenance. The
the time the dust collection equip- cost/cfm as the size increases. There- multitube cyclone and the low-pressure
ment is, and this may make a sub- fore, a comparison on small cupolas may drop scrubber should also cause few
stantial contribution to the visible be considerably different from compari- maintenance problems and should cer-
reduction. son of the same types of equipment for tainly not need a full-time operator or
2. Many cupolas have No. 1 or No. 2 large cupolas. observer. The high-energy scrubber
Ringelmann plumes without any Another big cost variable is the dust consumes large quantities of horsepower.
control equipment. When a wet removal system. Elaborate screw con- For instance, at 325 hp x 3000 hr/yr, at
cap or multitube cyclone is applied veyor and transporting systems in bag- 1 f£/hp hr, the hp would be $9,750. Be-
to this equipment, the image collectors and complex water clarifica- cause of the number of more complex
created is that the plume has been tion systems for the wet collectors can units in the system, such a system would
reduced by virtue of the equip- add substantially to the total cost of the require periodic inspection throughout
ment. The only effect the wet cap installation. The installation cost is the day, if not a full-time operator.
has on the appearance of the plume also inconstant. Erection, including The fabric filter would also require
is to add water vapor to it, tending piping and wiring and ductwork, may either periodic inspection during the
to make it whiter. range from 50 to 150% of the equipment day, or a full-time operator. The big-
cost. gest maintenance item will be the bags,
High efficiency on gaseous contami- which may last anywhere from a few
nants can be accomplished in wet scrub- Maintenance and Operating Cost weeks up to several years in operation,
bers. The use of a caustic scrubbing More extreme deviation exists in the depending upon the conditions. These
slurry allows capture of as much as 90% maintenance and operating costs of the bags are also a relatively expensive por-
of the SO2. Equal efficiencies can be equipment. Some installations, both tion of the system. In one system re-
obtained on fluorides. The dry collec- wet and dry, have incurred maintenance placement bags cost approximately 15%
tors and the wet cap have little effect on costs so high that they have actually of the total installed cost of the system.
the gaseous emissions. been abandoned. Others are running The maintenance and operating costs of

August 1967 / Volume 17, No. 8 543


the high-energy scrubbers and fabric gland foundryman, who is being be- steps prior to making the initial installa-
filters can greatly be reduced by proper sieged by his neighbors to clean up his tion. If this is not done, the foundry-
design. cupola. He has contacted various offi- man may find that in order to comply
cials who cannot give him any definite with the new requirements, he may have
Cupola Systems and Legislation answers regarding what level of effi- to completely scrap what he has already
At the present time there are less than ciency will satisfy the eventual legal installed. It is, therefore, worthwhile
50 each of baghouses, wet scrubbers, and requirements. In order to comply to spend the money initially to investi-
multiclones installed on cupolas. There with his neighbors and local city request, gate and determine the location and de-
are, however, hundreds of wet caps. he is going to install some equipment. sign of the ultimate system, as well as
Contrast this to the several thousand With the incremental approach he can the initial system to be installed.
cupolas which are in operation. The install the first and least expensive in- In conclusion, although the cupola
situation is changing quite rapidly, how- crement and then when the laws for the emission is one of our more complex air
ever. Last year alone, approximately state and county are evolved, he can pollution problems, it is one that can be
30 to 40 dust collection systems were then increase the efficiency by adding solved from an engineering standpoint.
purchased in the U. S. In the next sev- the additional steps required to comply The maintenance and operating costs
eral years, this rate will certainly accel- with the new legislation. can be minimal if the systems are de-
erate, in large part due to the legislation In order to take advantage of the in- signed properly. If approached on an
which is now being passed. cremental approach, it is necessary to incremental basis, it is one which is
A number of laws have been passed plan the possible additional steps and in economically possible for use in the
which require cupolas to be supplied most cases, to engineer the additional smallest foundries.
with the most highly efficient dust col-
lection equipment, with no exception for
the smaller foundries. As discussed
earlier, this means a disproportionate in-
vestment for the small foundry. The CONTROL RECOMMENDATIONS ISSUED
capitalization of many of these foundries
is such as to make such a sudden large FOR LEWISTON-CLARKSTON AREA
investment nearly impossible.
One solution to this dilemma has been
to allow the smaller foundries to install Recommendations for control of inter- installation and employment of methods
less expensive equipment and to comply state air pollution in the Lewiston, to control pollution. The recommenda-
with a less stringent requirement. An- Idaho— Clarkston, Washington area were tion stipulates that the plans must be
other alternative, which certainly bears issued June 14 by Secretary of Health, approved by the air pollution control
consideration, is the incremental ap- Education, and Welfare John W. agency of Idaho and the controls must
proach to the problem. It is possible Gardner. be in operation by Dec. 31, 1967.
with designs offered by several manu- The recommendations, effective im- Secretary Gardner also recommends
facturers to just purchase the wet cap mediately, were proposed unanimously the prohibition, within six months, of
and, in the instance shown, spend the at a federal abatement conference held waste disposal by burning in open dumps
$50,000 for installation. At some later in Clarkston, Wash., Mar. 1 and 2. or in single chambered incinerators in
date, the 6-in. pressure drop unit could Official participants at the conference Lewiston, North Lewiston, Lewiston
be installed. The additional cost would represented the Department of Health, Orchards, Clarkston, Clarkston Heights,
not be $120,000, but possibly as low as Education, and Welfare, both states, and and nearby developed areas in both
$80,000. This is because the water the local governments involved. Indus- States. Teepee-type burners, now oper-
clarification equipment, water piping, trial representatives and citizens from ated by area lumber mills, must be
and possibly even the cap itself, could Whitman and Asotin Counties, Wash., properly equipped and operated to
be utilized in the new system. It is also and Nez Perce County, Idaho, partic- minimize smoke emissions or aban-
possible to expand a standard wet scrub- ipated in the proceedings. doned.
bing system to the high-energy scrub- The two-day conference focused on John T. Middleton, Director of the
bing system. Here again, the original hazards to health and welfare due to air Public Health Service's National Center
system that started with the wet cap pollution emitted from a pulp mill near for Air Pollution Control, has for-
and was expanded to the low-pressure Lewiston and the burning of refuse in warded the Secretary's recommenda-
drop scrubbing system could be ex- the three-county interstate area. tions to Governor Donald W. Samuelson
panded to the high-pressure drop scrub- The principal recommendation calls of Idaho, Governor Daniel J. Evans of
bing system with an additional cost low for legislation to create an interstate Washington, and the heads of state and
enough so that the total installed cost to regional agency which would establish municipal agencies who participated in
date, of all equipment, would only be and enforce regulations for the preven- the abatement conference last March.
slightly more than the $175,000 shown tion and control of air pollution. As prescribed by the Clean Air Act,
on the chart for the initial installation of Secretary Gardner recommended that the Secretary must allow a period of at
the high-energy scrubber. If the foun- the federal government be represented least six months for action to be taken on
dryman were allowed to approach the in the regional agency and have the same his recommendations. If adequate
problem on this incremental basis, it vote as each state delegation. He progress is not made, he may appoint a
would allow him to spread his capital in- recommended that the state delegations board of five or more persons to hold a
vestment over a much longer period and include appropriate representation of public hearing following which he will
at the same time, would allow increasing local governments in the region. forward the board's findings and rec-
degrees of collection efficiency. Two other recommendations call for ommendations to the states involved
This type of approach is even more specific action to control malodorous and to parties responsible for alleged
desirable in localities that are uncertain gases and smoke. sources of interstate air pollution.
about future legislation. Many areas Potlach Forests, Inc., the operator of Then, if recommended abatement ac-
are discussing legislation but are not the kraft-process pulp mill located east tion is not taken within a period of at
able to tell foundrymen whether the of Lewiston which is the major source of least six months, he may ask the At-
laws will be extremely severe or very pollution in the area, is required to sub- torney General to initiate action in
lenient. Take the case of one New En- mit within 30 days plans for equipment United States courts

544 Journal of the Air Pollution Control Association

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