ILLINOIS POLLUTiON CONTROL BOARD
October 1, 1987
IBS, INC.,
Petitioner,
v.
)
PCB 87—143
ILLINOIS ENVIRONMENTAL
PROTECTION ACJENC~’,
Respondent.
OPINION AND ORDER OF Th~BOARD (by 3.D. Dumelle):
This provisional variance request comes before the Board
upon a September 30, 1967, Recommendation of the Illinois
Environmental Protection Agency (Agency) and an October 1, 1987,
addendum to that Recommendation. The Agency recommends that
because of an arbitrary and unreasonable hardship, IBS, Inc., be
granted a provisional variance to enable it to participate in a
study funded by the Agency and the United States Environmental
Protection Agency (USEPA). lBS seeks variance from Section 9(b)
of the Illinois Environmental Protection Act (Act), which
requires that no person shall operate an emission source in
violation of any permit condition.
One of the special permit conditions of the company’s
current permit prohibits it from burning any PVC coated wire in
its wire burning incinerator. lBS would like to participate in
the study described above by burning assorted wires now on—site
for the purposes of a 2~3 day trial burn. The Agency states
that, while IBS, Inc. has visually identified wire which it
believes to the best of its knowledge do not contain PVC
material, it cannot completely guarantee that it will be
complying with the special permit condition on its current
permit. It is for this reason that lBS seeks the provisional
variance.
The Agency stated that it has recently become aware that
burning PVC material in an oxygen—starved environment such as
that found in a wire burning in incinerator may produce dioxins
and furans which can be of concern to the environment. In an
effort to study the problem, the Agency and the USEPA are funding
projects designed for further study of this problem.
The study is designed to two phases, as follows: Phase 1:
lBS
now
seeks provisional variance for its participation
in
Phase
1. Phase 1 involves site assessments to obtain operating data
from wire reclaiming incinerators. The Agency and USEPA have
requested that existing ash be cleaned out of the incinerators.
82—111
Pnase 1 requires that the incinerator be operated for a period of
1—3 days. lBS believes that it will be burning wire with non—
vinyl chloride insulation during the Phase 1 burn, but lBS will
be burning wire which has the same combustion characteristics.
During a test burn, it will be necessary to keep the soil around
the wire burning incinerator unit dampened to avoid stirring up
any dust. During Phase 1 of the study, an EPA contractor would
set up temperature monitoring equipment and take gas samples
throughout 1 or 2 operating cycles. This 2—3 day test burn would
be conducted during the week of October 12, 1987. Because one
company believes that PVC coated wire can be visually identified
with certainty, Phase 1 of the study will also include a portion
addressed to methods of identification of wires coated with PVC—
containing insulation. Phase 2: The location of the Phase 2
portion of this study has not yet been determined. However, the
Phase 2 portion of this study would involve a stack emissions
test for dioxin which would be performed using the parameters
obtained during the Phase 1 portion of this study. Phase 2 would
be conducted using ordinary and normal operating conditions,
which might include burning wire with PVC insulation.
The purpose of Phase 1 and Phase 2 of the study is to assess
the quantity. if any, of dioxin likely to be emitted into the air
from wire reclamation incinerators, and to identify conditions
under which the units could be safely operated. As stated
previously, the Agency has requested that existing ash be cleaned
out of the lBS incinerator prior to operation of the
incinerator. The Agency has made specific recommendations to lBS
for the removal of the ash and has required proper disposal
methods as set forth to the company in correspondence to them.
Ash and soil samples were taken by the USEPA as part of the
Tier Four of the National Dioxin Strategy. For analysis
purposes, the Agencyts information regarding levels of concern
for 2,3,7,8—TCDD dioxin equivalents would be one part. per billion
in residential areas and 0.006 ppb’s (or six parts per trillion)
in grazing areas. Levels of concern for non—residential areas
are determined on a case—by—case basis, but the majority of
levels of concern for non—residential sites fall in the range of
5—15 parts per billion. lBS is located in a highly developed
commercial and industrial area.
As a result of the receipt of test results at lBS in the
Tier Four National Dioxin Strategy, the Agency collected samples
from 12 sites in Illinois. Some concentrations were found at all
sites at which samples were taken; however, concentrations were
less than levels of concern at all but five sites in Illinois.
As a result of the ash samples taken by USEPA at IBS, USEPA
determined that it would take soil samples of the soil
surrounding the 155 wire burning incinerator.
82—112
—3—
Upon receipt of the first results of sampling at the lBS
incinerator, lBS was requested to and has ceased operation of the
incinerator on site. Further, the incinerator and the process
area have been secured by allowing no personnel in the secured
area, preventing disturbance of the soil or anything else in the
area, identifying ash on site and securing it, and identifying
any recovered wire or other material processed through the
incinerator on site. In addressing the expected emissions as a
result of the test burn at the lBS site, the Agency stated that
it believes that if the ash is properly removed from the
incinerator and non—PVC containing wire is burned, it is
extremely unlikely that any emissions of dioxins would ensue.
Any emissions would likely be primarily particulates.
However, lBS and other facilities have stated that while
they believe they are able to visually identify wire coated with
PVC insulation, they cannot be 100 certain that visual
identification will identify such wire. If some PVC coated wire
escapes detection and is charged into the incinerator, it is
possible that some PCDC’s may be generated. Some small amount
may escape destruction in the afterburner and be emitted into the
atmosphere. To estimate the potential quantity of POLE that may
be emitted, a comparison may be made to a somewhat similar unit
that has been tested for PCDD emissions under a USEPA contract.
This particular unit is allowed by its operating permit (issued
by the State of Georgia) to burn up to 200 lbs/hour of PVC wire
but typically only burns about 20 lbs/hr. An average of three
test runs disclosed an average emission of 114 micrograms per
hour of total PCDD’S. Currently USEPA is engaged in dispersion
modeling and population risk assessment studies to attempt to
determine the significance of wire reclaiming incinerators
emissions to public health and welfare. However, since the
purpose of the Phase 1 and Phase 2 testing by USEPA and IEPA is
to assess the quantity, if any, of dioxin likely to be emitted
into the air from wire reclamation, the Agency stated that it
cannot state with certainty the expecteã amount of emissions. It
is this which Phase 2 of the study will ultimately determine.
Pursuant to Section 35(b) of the Act, the Board hereby
grants the provisional variance as recommended.
This Cpinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
ORDER
155, Inc., is hereby granted a provisional variance from
Section 9(b) of the Illinois Environmental Protection Act, as
recommended by the Illinois Environmental Protection Agency.
IT IS SO ORDERED.
Board Member M. Nardulli abstained.
82—113
—4—
Board Members J. Anderson and R. Flemal were absent.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was
adopted on the
/A4’
day of
&~A.
,
1987 by a vote
of
-
.
Dorothy M. dunn, Clerk
Illinois Pollution Control Board
82—1 14