ILLINOIS POLLUTION CONTROL

BOARD

February 14, 1974

KOPPERS COMPANY, INC.,

Petitioner,

vs.

PCB 73—494

ENVIRONMENTAL

PROTECTION

AGENCY,

Respondent.

OPINION AND ORDER

OF THE BOARD (by Mr.

Seaman):

On November 19,

1973, Koppers Company, Inc. filed

its Petition seeking therein a variance from Rule 205(f)

of the Air Pollution Control Regulations.

Petitioner has a

manufacturing facility

located

at

Stickney, County of Cook,

Illinois, for the

production

of phthalic anhydride

and tar products. Petitioner~s

plant employs 150 persons

with an annual payroll of

$1,700,000 and has

been manufacturing at this location

since 1920. The environmental

control systems installed

at Petitioner’s facility

represent a capital investment

in excess of

$1,500,000 and have an annual operating

cost of approximately

$500,000.

The tar saturation

plant has an annual production of

approximately

15,000,000 lbs. of tarred felt. Tarred

felt is a basic

component in residential and commercial

roofing. Petitioner

is a major supplier of roofing

materials to the

building industry,

Petitioner is

seeking a 14-month Variance from Rule

205(f)

of

the Air

Pollution Control Regulations during which

time

it

plans to

install control equipment necessary to

achieve compliance.

Emissions from Petitioner~s

facility consist

of

heavy

hydrocarbons which are

in part photochemically reactive,

but probably contain less

than 5 non-condensables. Stack

tests conducted at the

facility indicate that total emissions

are approximately

21 lbs/hr as compared to an allowable

limit of 8 lbs/hr

(Rule 205(f),

Petitioner proposes

to install a Johns-Manville High

Energy Air Filter

System (HEAF) to control the emissions.

In terms of costs

and operating reliability, this control

11 ~-269

---

—2—

method appears to be superior. This choice is furth~er

reinforced by the fact that this system is operating

satisfactorily on similar processes

at

several locations

in

Illinois.

Briefly, the equipment

consists of

a high static

pressure fan, a heavy fiberglass mat, and a mist separator.

The mat is movable so that a fresh surface is constantly

being

exposed. As

the hydrocarbon particles

collect

on the

mat,

they

impinge upon each other

to

form

larger

droplets,

which

are disengaged from the mat

by the high

velocity of

the

air stream. These droplets

are then

removed from the air stream in

the

low velocity

mist

separator,

and collected and

drained

off

as a liquid.

Petitioner estimates that the cost

to install

the HEAP

will

be approximately $85,000

and that annual

operating

costs will be approximately $12,000, Petitioner

alleges

that it will require 14 months to install the

equipment.

The Agency agrees with Petitioner that the

proposed

control program wii.l

).jC

adequaI.~e to .brinq the facility

into compliance with Rule .2 05 f)

The Agency does question,

however, the l4~month t.ime perTh•d pioposed

y Petitioner.

U. S. Environmental Protection ~~crenc~/ technical

guidelines

for review

of

compliance p rograms indicate that 42 weeks

is a reasonable period for tRu installation

of a HEAF.

Earring unforeseen ~e1a

Rue sency he~aaes that Petitioner

should be able to have its HEAF functional within one year.

Petitioner indicates that i yeas on for

non—compliance

with Rule 205(f)

is

based upon unawareness of the quantity

of its emissions.

initial tests conducted by

Petitioner

in 1972 indicated that emissions were on the

borderline

between compliance and non~-compliance. Since

the

test results

were

not

conclusive,

Petitioner conducted

additional tests

in early 1973, at which time it dete~ined that its emissions

were in excess of Rule 205(f)

.

Following tie determination

of

r~on~-comp1iance,Petitioner hired a consultant,

conducted

studies of

various

possible control orograrns, and submitted

its Petition

for

Variance.

We

are disposed to grant the variance

sought for one

year and subject to certain conditions. We feel that

Petitioner may well

have been misled by the

initial

stack

test mentioned above and that Petitioner is now committed

to an abatement plan which will achieve

compliance.

This

Opinion

constitute the findings of

fact and

conclusions of law of the Board,

11 ~27O

---

—3—

IT IS THE ORDER of the Pollution Control Board

that Koppers Company, Inc. be granted a variance from

the provisions of Rule 205(f) for a period of one year

from the date of this Order, subject to the following

conditions:

1. Commencing thirty (30) days from the date

of this Order and continuing quarterly thereafter,

Petitioner shall submit progress reports to:

illinois Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Spr,ingfield, Illinois 62706

Said reports shall detail Petitioner’s progress toward

achieving compliance.

2. Petitioner shall apply for all necessary construction

and operating permits from the Agency.

3. Within fifty

(50)

days of the date of this Order,

Petitioner shall post a Performance Bond in a form acceptable

to the Agency and in the amount of $50,000.00, Said bond

shall be posted with:

Illinois Environmental Protection Agency

Fiscal Services

2200 Churchill Road

Springfield, Illinois 62706

Said bond shall be designed to insure installation of the

subject control equipment.

IT

IS

SO ORDERED.

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, certify that the

abovç

Opinion and Order

was adopted on this ~

day of

~

1974

by a vote of,.