ILLINOIS POLLUTION CONTROL BOARD
June
6,
1974
ENVIRONMENTAL PROTECTION AGENCY,
)
)
Complainant,
)
vs.
)
PCB 72—285
)
ILLINI
BEEF
PACKERS
INCORPORATED,
)
)
Respondent.
Larry R. Eaton,
Assistant
Attorney General for the EPA
William R. Carney, Attorney for Respondent
OPINION
AND
ORDER
OF
THE
BOARD
(by Mr. Henss):
On December 13, 1913 this Board ordered Illini Beef Packers
Incorporated to investigate its Joslin operation to determine
whether methods of operation, or maintenance practices might
be causing periodic odorous emissions,
and to report to thc EPh
and this Board.
If such emissions were found Illini Beef
w~g
to
propose a program to correct the problem.
Illini Beef was
further ordered to implement a
program
to
handle
odor
complaints
from nearby residents.
Illini Beef has complied with all parts of the Decera..er
1973 Order and the
Agency
has
submitted
its
comments
on
the
company’s proposed control program.
With respect to the inedible rendering system, Illini Beef
reports that its air scrubber and afterburner are installed and
operating under Agency permit.
Both devices are operating
successfully.
In addition, Illini Beef proposes to clos:D most of the doors
which lead to the rendering process area.
The 30,000 CE? air
movement of the scrubber creates a negative pressure in the
inedible rendering process portion of the building and ti~erefora,
it
is necessary for the west door to be partially open.
This will
allow the scrubber to operate at designed efficiency and keep the
inside temperature at a reasonable level for ororator comfort.
:dl
other
doors
are
to
remain closed during operating hours and all
doors including the west door will be closed during nonoperatin~
hours.
12—416
—2—
All exhaust openings which were originally designed into
the inedible rendering process area have been sealed.
This
will insure that all air from the rendering area will pass
through the scrubber prior to being released to the atmosphere.
Daily checks are to be made on the scrubber and the afterburner.
Routine
maintenance
will
be
performed
during
the
daily
checks.
Necessary
repair
parts
will
be
stocked
in
case
of
mechanical
failure.
Employees working in the inedible rendering area have been
taught
the
proper
operation
of
all
equipment
including
the
control devices.
They have been instructed to be aware of
seemingly minor items which could cause an odor problem.
Illini
Beef’s “early detection crew” consists of 24 hour security per-
sonnel,
24 hour shift operators, the waste treatment operator,
all management and supervisory personnel and all persons working
in the inedible rendering process area.
This would appear to
provide adequate coverage and we shall not require further action
in this respect.
All areas including the inedible processing areas are to be
thoroughly cleaned on a regular basis under the scrutiny of the
USDA.
This includes a complete wash down of cattle holding pens
each
day.
The
Agency
requests
that
the
local,
district
or
regional
office
of
the
Agency
be
notified
immediately
upon
discovery
of
any
malfunction
in
the
pollution
control
devices
or
unusual
operating
conditions related to the processing plant or the
wastewater treatment system.
Illini Beef states
that
it
has
no
objection to such a requirement and it shall be ordered.
With respect to the waste treatment system, Illini Beef
reports
that
it has a full-time waste treatment system operator
with
proper
industrial
license
issued by the EPA.
As part of
his
duties
the
operator
makes
daily
maintenance
checks
of
all
system
equipment,
checks
for
any
noticeable
odors
and
checks
the
natural
cover
on
two anaerobic cells.
No
odors
have
been
noticed
around
the waste treatment system since the cover formed over these cells.
Several precast concrete covers have been delivered and are
scheduled to be placed over the concrete structures between the
anaerobic cells and the aerated cell.
These concrete covers
should reduce the chance that odors might come from the lagoon
area.
The Agency requests that the covers be caulked into
position and all sample ports covered.
Illini Beef did not object
to this request and it shall be ordered.
The only major area of disagreement between Illini Beef and
the Agency concerns the method by which the Company proposes to
12—415
—3—
handle citizen complaints.
On December
23,
1973 Illini Beef
issued a notice to personnel as
to the procedure to be followed
when an odor complaint is received.
The procedure, if followed,
should constitute compliance with Part B of our prior Order.
However,
the Agency requests that the initial phase of
the
complaint program include a notification
by
direct mail to all
residents within a five mile radius of the facility of
the plant
telephone number and its “intended use”.
The Agency wants this
direct mailing to~besupplemented by advertisements in a local
newspaper or announcements on the radio of the existence of the
complaint program.
Illini Beef protests that such notification
would place them in a position of “advertising for complaints”
which they consider a “totally extreme position by the EPA”.
Illini Beef points out that the designated telephone number will
be the plant’s primary number which is listed in the area telephone
book, easily accessible to any of the area residents.
It is the
Board’s opinion that Illini Beef has provided a reasonable tele-
phone program in compliance with our Order and that the measure
proposed by the Agency
is above and beyond that required to
resolve the problem.
This Order shall he the final order of the
current proceeding.
This Opinion constitutes the Board’s findings of fact and
conclusions of law.
ORDER
It is the Order of the Pollution Control Board that the
proposed odor control program submitted by Illini Beef Packers
Incorporated is hereby accepted as proposed with the following
modifications:
1.
All doors
in the inedible rendering process area
except the “west door”
shall be kept closed.
The
“west door” may be opened but only to the extent
necessary to maintain the designed efficiency of
the scrubber and to provide operator comfort.
2.
In the event Illini Beef experiences any malfunctions
in the pollution control devices or unusual
operating conditions which could lead to the
emission of odors, Illini Beef shall immediately
notify the Environmental Protection Agency’s
Regional Office in Rockford, Illinois
(telephone 815/987-7576),
If
such malfunction
or
unusual operating condition occurs during other
than normal business hours,
the regional office
shall be notified as soon as possible on the next
regular business day.
12
467
—4—
3.
All concrete covers placed over the structures
between the anaerobic cells and the aerated cells
shall be caulked into place and all sample ports
shall be covered.
::,
Chr~stanJ~. T4of~ett,
Clerk
of
the
Illinois Pollution Control
Board
hereby
certify
the
above
Opinion
and
Order
was
adopted
t~iis
~
day
of
~
,
1974
by
a
vote of
~/
to
0