ILLINOIS POLLUTION CONTROL BOARD

August 30, 1973

BELDEN CORPORATION,

Petitioner,

v.

)

PCB 73—230

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Richard A. Zachar and Thomas 3. Regan on behalf of Petitioner;

John E. Slattery, Assistant Attorney General, on behalf of

Respondent.

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

Belden Corporation,operator

of a magnet wire manufacturing

facility

in Chicago, seeks a variance from the provisions of Section

9(a) of the Environmental Protection Act

to

the extent said

pro-

vision prohibits odorous emissions to enable the Petitioner to

obtain an operating permit previously denied because of likely

violation of said section. The original Petition for Variance

filed May 30, 1973 sets forth that the facility is located on a

three and one-half acre tract adjacent to the Belt Railroad where

it has been since 1918, and presently employs 296 people~. The

permit application aforesaid was denied by letter of the Agency

written February 7, 1973, which letter stated inter alia as follows:

~The Agency cannot grant your request for an operating

permit for these operations where such operations may

?cause or threaten or allow the discharge or emission

of any contaminant into the environment in any State so

as

to

cause or tend to cause air

pollution in Illinois,

either alone or in combination with contaminants from

other sources, or so as

to

violate regulations or stand-

ards adopted

by

the Board under this Act

~Environmental

Protection Act) Section 9 (a)

Petitioner proposes to install an emission reducticn program

which it represents when completed will bring the company into

compliance with the hydrocarbon emission standards cecently adopted

by the Board, and to take effect December 31, 1973, and will

at

the same time reduce its odor emissions to an extent that Section

9(a)

will

no longer be violated.

9

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161

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Paper and textile covered copper and aluminum wire and enamel

coated copper and aluminum wire are manufactured at the facility.

The discharged contaminants which are responsible for the

hydrocarbon and odorous emissions result from the wire enameling

processes which are detailed in Exhibit C attached to the Petition.

Over the last three years, tests have been conducted on the

various machines and equipment to ascertain the extent of emis-

sions and the degree of abatement achieved by the installation

of various control equipment. The tests indicate that under the

best average conditions, the projected uncontrolled emissions from

each emission source would not exceed regulatory limits set forth

in Rule 205(f) of Chapter 2, whereas under what has been character-

ized “worst case conditions”, three machine types

,

the H, M and

K machines, would exceed allowable hydrocarbon emissions.

Accordingly, as set forth in the original Petition, the following

emission reduction program is proposed:

Machine No. of

Emission Reduction Program

Type

Machines

H

1

Replace one (1) catalytic afterburner with

a direct flame afterburner.

K

3

Replace three (3) catalytic afterburners

with direct flame afterburners.

M

6

(A) Replace four (4) catalytic units

with direct flame afterburners.

(B) Change Engineering and Operating

Instructions on two machines

limiting operation to lowest

solvent load insulation (i.e.,

Heavy Armored Polythermaleze, see

Summary Sheet 3).

Based upon the proposed abatement program, Petitioner represents

that its total plant emission abatement efficiency would be 73.4

deemed of a sufficient degree to achieve both regulatory limits and

adequately minimize odor emissions so as to no longer violate. Section

9(a) of the Act. Essentially what the emission reduction program

calls for is the installation of afterburner equipment which has been

designed to be used in conjunction with its enameling machines and pos-

sesses the capability of continuous operation at 1400°F. The

contemplated dates of installation for the equipment, both that which

has been installed and to be installed was set forth in the original

Variance Petition as follows:

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162

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—3—

Machine No.

Date Installed

Date to be Installed

1—4

2/25/73

M—1

11/9/72

K—2

3/2/73

K—i

1/30/73

H—i

3/30/73

M—2

4/6/73

M—3

5/4/73

M—4

6/15/73

K—3

7/15/73

Assuming that this schedule was followed, all the foregoing

installation would have already been accomplished. The installa-

tion cost is represented to be $30,000. Petitioner asserts that

denial of the variance and resulting denial of operating permits

would constitute an undue hardship disproportionate with the

burden on the community in permitting odors to be emitted during the

period for which the variance is sought. Petitioner further

repre-

sents

that upon completion of the emission reduction program, the

discernible odor from the plant will not be of such level or dura-

tion as to unreasonably interfere with enjoyment of life or property

in the area involved. Variance is sought to permit the installation

of abatement equipment and to enable the issuance of operating

permits.

Subsequent to the filing of the original petition, a series of

amendments was filed. The first amendment set forth that because

of the additional availability of natural gas, the Petitioner was

installing two additional direct flame afterburners for use on two

I-type machines. In order to enable installation of the necessary

equipment, variance is sought through December 31, 1973. The third

amendment to the petition sets forth a modified compliance program

which, in addition to the installation of afterburners as above set

forth in the original petition, and the first amended petition

provides for the installation of three additional direct flame after-

burners on the I-machines to be completed by April 15, 1974, the

retirement of six of the twelve F—type machines and nine of the

twelve A-type machines prior to December 31, 1973, and the initiation

of a comprehensive odor survey consisting of stack tests to obtain

information concerning the level and type of odor being discharged

under various operating conditions. In addition, Petitioner would

conduct odor tests at the property lines to check on the effective-

ness of the emission reduction program and establish procedures

to preclude creation of odor emissions through failure or mal-

function of the afterburners. The time schedule proposed including

equipment already installed would be modified as follows:

9

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163

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—4—

Machine No.

Date Installed

Date to

be Installed

1—4

2/25/72

M-l

11/9/72

K—2

3/2/73

K—i

1/30/73

H—i

3/30/73

M—2

4,/6/73

M—3

5/4,/73

M—4

6/15/73

K—3

7/28/73

1-3

December, 1973

1-5

January, 1974

I—I

February, 1974

1—2

March,

1974

1—6

April, 1974

Lastly, the Petitioner represents that total plant discharges

of hydrocarbons will be reduced 45 and total plant discriarges of

cresylic acid believed to be the cause of creosol odor will be

reduced an estimated

85.

Hearing was held on

the

petition in Chicago on July 23, 1973.

The testimony of witnesses for the Petitioner substantiated the

allegations of the Variance Petition as amended.

We

believe the

proposed compliance program to be an exceptionally good one, and its

implementation

will serve the dual purpose

of bringing Petitioners

operation into compliance

with the relevant hydrocarbon regulations

at or close to the date

when

compliance is

mandated

and

at the same

time lessen the odor emissions to a degree

that nuisance attributes

will

no longer be present.

The variance, however, does not go to

the hydrocarbon regulations, but is only with

respect to the 9 (a)

odor potential which served

as a basis

for the Agency’s permit denial.

We will require that the Petitioner adhere

to the time schedule that

it has proposed

and pursue the survey, testinf, and maintenance

procedures that

it

has already embarked upon.

This Opinion constitutes the findings

of fact and conclusions

of

law

of

the Board.

IT IS

THE ORDER of the

Pollution Control Board that Belden

Corporation be granted a

variance from ~ provisions

of

Section 9 (a)

of the Environmental Protection Act with respect to odorous emissions

until April 15, 1974 in order to enable Belden to make installation

ci

afterburner and other equ:Lpment un its

H, ,

1

and H

machines

as set

forth

i~ it~

Pet~~~n

for ~‘arianc~ a~ a~uaed

I~ ~ddsti~’n

thereto, PetItioner shall pursue its program of odor survey and

testing as set forth in i.ts Petition to ascertain the characteristics

of odors

detectaule ati

t~ property lines

and

shall set forth a

definitive procedure to preclude creation of odors through mal-

functioning of

afterburners,

together

with maintenance instructic;ns

and procedures.

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—5—

Petitioner shall report to the Environmental Protection Agency

on the 30th day of September and on the 30th day of each month

thereafter through April 30, 1974

the

status of its installation

and abatement program and the test results observed pursuant to the

foregoing procedures.

I, Christan L.

Moffett~ Clerk

of

the Illinois

Pollution Control

Board, certify

that the above

Opinion and Order

was

adopted ny

the

Board on the~~

day of

~

1973, by a

vote

of

~3

to

0

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