ILLINOIS POLLUTION CONTROL BOARD
    May 19, 1988
    THE DOW CHEMICAL COMPANY,
    Petitioner,
    PCB 88—86
    ILLINOIS ENVIRONMENTAL
    PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD (by J.D. Dumelle):
    This provisional variance request comes before the Board
    upon a May 16, 1988, Recommendation filed by the Illinois
    Environmental Protection Agency (Agency). The Agency recommends
    that because of an unreasonable hardship, the Petitioner, Dow
    Chemical Company, be granted a provisional variance from the
    requirements of 35 I11~. Adm. Code 215.438, as it relates to the
    first quarter leak testing, inspection and repair requirements of
    Section 215.430, 215.432(b)(c)(f)(h) and (i), 215.433, 215.434
    and 215.435 for a period of 35 days from and including March 31,
    1988 to and including May 4, 1988.
    Dow operates a polystyrene plant in Will County, Illinois
    and employs approximately 140 people. The facility is located at
    the junction of 1—55 and Arsenal Road in Channahon, Illinois.
    The closest residences are located about two miles northwest of
    the facility in Channahon, Illinois. Dow manufactures high—
    impact polystyrene pellets, expanded polystyrene (styrofoam)
    insulation board, and vinyl ester resins. Approximately 235,000
    pounds of raw material is used each year; of that material, 95
    is styrene and ethyl benzene, and the remainder is mineral oil,
    rubber, and anti—oxidants. The specific activity for which a
    variance is requested is the process by which polystyrene is
    produced
    -
    A number of similar volatile organic material emission
    sources are also located in the area surrounding the facility.
    Based on the State’s Geographic Designation of Attainment Status
    of Criteria Pollutants dated February, 1985, Will County is an
    attainment area for ozone. The nearest ambient air quality
    monitoring station was previously located in Braidwood,
    Illinois. For the 1985 ozone season, the two highest readings at
    this station were as follows: highest reading, 0.117 ppm; second
    highest reading, 0.107 ppm. Currently, the closest ozone monitor
    is in Lockport, Illinois. For 1985, the two highest readings
    89— 295
    —2--
    were as follows: highest reading 0.109 ppm; second highest
    reading, 0.093 ppm.
    The Agency states that Agency personnel have conducted
    routine inspections of the facility. The only current permit in
    force is Permit Number 76020210. It covers Dow’s polystyrene
    manufacturing process and will expire on January 20, 1990. One
    previous variance has been filed by Dow (PCB 88—2). No
    enforcement actions have been filed by the Agency against the
    company.
    The Agency further states that the only estimate of emission
    was provided by Dow in connection with its previous variance
    petition (PCB 88—2). Dow estimates that the organic emissions
    from sample ports at the plant are less than 0.5 tons per year.
    This figure is based on 8 ounces of purge per sample, one minute
    exposure to atmosphere per sample, and the following sample
    taking schedule:
    Sampling
    Sample
    Sample ID Description
    Frequency
    Size
    Disposal Method
    10715 TV—155 Styrene
    l,4qeek
    2 Oz. Recycle for
    Storage Tank
    Energy Recovery
    Sampling Valve (2)
    In Furnace
    10809 TV—1l4 Styrene
    1/Week
    2 Oz. Recycle for
    Storage Tank
    Energy Recovery
    Sampling Valve (2)
    In Furnace
    12000 Recycle “In”
    6/Day
    1 Oz. Recycled for
    Sampling Valve (2)
    Energy Recovery
    In 4t#?Furance
    13000 1st Stage
    6/Day
    2 Oz~. Incinerated In
    Partial Polymer
    Dow Facility
    13525 2nd Stage
    2/Day
    2 Oz Incinerated In
    Partial Polymer
    Dow Facility
    15600 Recycle “Out”
    6/Day
    1 Oz. Incinerated In
    Sampling Valve (2)
    Dow Facility
    After reviewing the application the Agency recommends that
    the provisional variance be granted. The Agency states that its
    review indicated the following:
    1. The short time frame of the variance, the fact that Dow
    is in an attainment area for ozone, the fact that there
    have been few complaints from the public regarding plant
    odors, and Dow’s continuing efforts to comply with the
    regulations, minimize any injury that the grant of the
    variance would impose on the public.
    89—29 6
    —3—
    2. Since Dow is located in an area that has attainment
    status and since the period of this variance is for only
    35 days, the Agency believes that any SIP revision
    regarding this variance would be approved by USEPA.
    3. Compliance on a short term basis would impose an
    unreasonable hardship on Dow.
    Pursuant to Section 35(b) of the Illinois Environmental
    Protection act, the Board hereby grants the provisional variance
    as recommended.
    This Opinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    Dow Chemical Company, Petitioner, is hereby granted a
    provisional variance from the requirements of 35 Ill. Adm. Code
    215.438, as it relates to the first quarter leak testing,
    inspection and repair requirements of Sections 215.430,
    215.432(b)(c)(f)(h) and (i), 215.433, 215.434, 215.435, for a
    period of thirty—five (35) days from March 31, 1988 through May
    4, 1988.
    IT IS SO ORDERED.
    I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Opinion and Order was
    adopted on the
    /9~~ day of
    ~?‘?ct4.7
    ,
    1988 by a vote
    of
    7-O
    __________.
    /
    ~1
    ‘~~/
    ~, ~
    Dorothy M/ Gunn, Clerk
    Illinois Pollution Control Board
    89—297

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