ILLINOIS POLLUTION CONTROL BOARD

January 

31,

1974

BORG~WARNERCOR.1 ORATION,

Petitioner,

PCB 73RD56

ENVIRONMENTAL PFOTECTION AGRDCY,

Respondent

Joseph

S~ Wright,Jr~ Attorney for Borg~Warner Corporation

FredricJ.

Entin,

Assistant Attorney General for the EPA

OPINION AND ORDER OF THE BOAPD (by Mr. Henss)

On July 26, 1973 we granted Borg~Warner a short term variance

from ceri~ain air pollution control regulations in the operation

of its ~Linmar Chemical Plant iihich is located 5 miles cart of

Ottawa, I1iino.is~ The plant currently produces about 220 million

lbs of ABS (acrylonitrilethutadiene~styrene)

resin per year and

Petitioner plans to boos the plant output to 270 million lbs~ per

year~ The manufacturing process involves use of drying units which

em..it styreneath. acrylonitrile

in a monomeric form and particulate

matter~ The oroanic enlissions were in excess of standards, and

therefore Borgtharner after con.siderahle research, had proposed a

control program to achieve a more. complete convers.ion of monomer

to poliner and thereb y come into compliance with the Regulations

Rule 205 (f) of the Air Pollution Control Regulations is

effective Decenber 31, 1973 and limits total emissions of organic

material to 8 lbs. per hour or in the alternative

requires an 85

reduction of organic emissions.

Our grant of variance was for a short term since the EPA

contended that Bcrgtharn er had failed to adequately analyze other

alter. .n.ntives in the control of acrylonitri,le~

The purpose of the

short

variance

was to allow the parties to “prepare aiditional

information for

us”

(Opinion page 5)

We ordered 3orgtharner

re view other emission control methods which had lean suggested by

th.e A,gency no ~d neport to thn Board and the ITA rmgarding those

noo s

~cper n~n o ~ ~

cc sc ne conmer 

thc thai ~r

a~facc~ ~ ~

t~ car ~e r~tLcn~

coir ez~z 

~te

area o~ the Linmar plant,

—2—

The Agency was ordered to submit its final Recommendation

within 15 days after receiving the Borg-Warner report. 

We

re-

tained jurisdiction for entering further orders.

Borg-Warner filed its report on September 20, 1973 as

scheduled. However, the Agency has not to this date commented

on

the

merits of Borg-Warner’s report. Instead, the EPA contends

that a new variance petition should have been filed by Borg—

Warner, completely disregarding the fact that in making the

report Petitioner was only complying with our July 26 Order. A

reading of that Order should have made it obvious to the Agency

that 

we

had not made a final disposition of the matter and were

retaining jurisdiction for the entry of a final Order. We had

requested information from both parties, but now must render our

final decision without having a final comment from the EPA

regarding Borg-Warner’s method of compliance.

When we previously considered this matter two rotary resin

dryers, dryers A and B, were in operation and a third, dryer C

was under construction. The plan was to have dryer C in operation

by October 15, 1973. The control equipment installed on dryer C

was to provide the engineering data for the design of control

equipment for dryers A and B. Each of Petitioner’s lines, A, B

and C, contain in addition to the dryers a coagulation unit and a

dewatering unit. Each of the coagulation units and each of the

~watering units is a source of organic materials to the atmosphere.

Borg—Warner now requests variance from Rule 205(f) of the A~:

Pollution Control Regulations for the A and B dryers, coagulation

units and dewatering units until September 1, 1974 and dryer C

until April 30, 1974.

Petitioner advises that a temporary control strategy known as

“post polymerization” was tested on dryer C resulting in a 75

reduction in hydrocarbon emissions. Rule 205(f) requires an 85

reduction. A more efficient and permanent post-polymerization

system has just been completed and placed in operation. Borg—Warner

claims that the new system will gradually increase the control

efficiency to a minimum of 85 through “fine tuning”

A Compliance Plan which was submitted with the application for

permit on dryer C showed that compliance would be achieved on dryer

C by December 31, 1973. Compliance is now planned for April 30, 1974.

Petitioner states that this delay will not affect the schedules for

installation of the “post-poly” system on dryers A and B. The

control systems will be installed on dryers A and B by September 1,

1974.

11

—80

—3—

A favorable feature of the post-poly system has been the

removal of organic materials upstream from the coagulation units,

the dewatering units and the dryer. While the system has not yet

achieved the necessary 85 reduction in emissions from dryer C,

it has had the effect of reducing by 90 or more the organic

materials from coagulation unit C and dewatering unit C. This

reduction has been accomplished with the expenditure of little or

no additional fuel.

In this respect the post-poly method is to b’~preferred over

incineration as a control method. Incinerati” would require six

million Btu’s per hour of natural gas ~  

is not available.

We believe the ~ost_~~ 

~iieiization

process is similar to that

which was described  our prior opinion on page 2 and is not a

“new ~ 

tacts” as the Agency contends.

The record shows that Borg-Warner has developed a method whereby

compliance with 205(f) should be achieved within a reasonable period

of time. In our prior Opinion we concluded that it would be a

hardship for Petitioner to immediately comply with the emission

standard. Petitioner claims that, at current emission rates, the

acrylonitrile will not be detrimental to health of persons living

nearby. “The maximum allowable concentration (MAC) for acrylonitrile

is more than 2,000 times higher than the current annual average acrylo—

nitrile concentration predicted by the dispersion model at the

nearest receptors. The emission reductions planned for the future

will increase the margin of safety still further.”

Compliance by September 1, 1974 seems reasonable to us and we

shall grant a variance to that date.

ORDER

It is the Order of the Board that:

Borg—Warner Corporation be granted a variance from

Rule 205(f) of the Illinois Air Pollution Control

Regulations until September 1, 1974 for the operation

of dryers A and B, coagulation units A and B and

dewatering units A and B and until April 30, 1974

for the operation of dryer C at Petitioner’s Marbon

Division Plant near Ottawa, Illinois. During the term

of the variance Petitioner shall install the necessary

control equipment as outlined in this proceeding, to

achieve compliance with Rule 205(f).

11 —81

—4—

Christan L. Moffett, Clerk of the Illinois Pollution Control

Board, hereby certify the above Opinion and Order wat adopted

this ~ 4~day of?fl~sa. 

1974 by a vote of 

toa..