ILLINOIS POLLUTION CONTROL BOARD
    February 28,
    1974
    )
    ALLEN
    INDUSTRIES,
    INC.
    )
    )
    v.
    )
    PCB 73-505
    )
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    ~1
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dumelle):
    The petitIon for variance
    filed
    by Allen
    Industries,
    Inc. (Allen)
    December
    3,
    1973 and amended December 19,
    1973,
    asks
    for a variance
    from Rules
    203(a),.
    203(b),
    and 205(f)
    of Chapter
    2, Air Pollution
    of the Rules and Regulations of the Pollution Control Board, for
    its manufacturing facility located in Herrin in Williamson
    County.
    The recommendation of the Illinois Environmental Protection
    Agency
    (Agency), received February 25, l97~,recommends that the
    petition be granted until May
    1,
    1974 subject
    to several conditions.
    Allen’s facility in Herrin manufactures resinated cotton
    products,
    such
    as insu1~torpads, molded dashliners, and other
    resinated roll goods
    used
    in the automotive
    industry.
    Raw
    materials used in the manufacturing processes include cotton,
    phenolic resins, plastoids,
    and solvents.
    The facility has been in existence for 16 years but within
    the last year
    a new operation,
    the manufacture
    of molded dash-
    liners was installed at the facility at
    a cost
    of $2,000,000;
    the operation using propane as
    the primary energy source.
    Pre-
    viously, propane supplied by Northern Propane
    Gas
    had been
    used at the facility for heating; plus natural gas supplied by
    Central Illinois Public Service Company for other processes.
    There are also eleven afterburners
    at the facility, eight using
    natural gas
    at
    a rate
    of 7,500
    cubic feet per hour, and three
    associated with
    the new dashliner process using
    19,100 cubic
    feet per hour of propane.
    The afterburners were installed and
    the boilers converted from coal
    to gas
    as part
    of Allen’s ACERP.
    To provide
    the propane necessary for its new dashliner
    process, Allen contracted on July
    18, 1973 with Petro-Tex to
    purchase 500,000 gallons of propane.
    The contract was cancelled
    11
    —395

    -2-
    subsequently as a result of the new Federal Mandatory Fuel
    Allocation Program.
    Thus Allen, assuming the other fuel suppliers
    do not interrupt their deliveries, has a shortage of approximately
    485,000 gallons of propane
    and
    says it would not be able to
    continue its manufacturing operation.
    Thjs in turn would put
    400 employees, having 585 dependents, out of work.
    Allen’s solution to this problem would be to shut off the
    eleven afterburners and divert this fuel, propane and natural
    gas, to the process operations.
    Their petition for variance from
    Rules 203(a),
    203(b),
    and 205(f) wpuld allow them to operate the
    facility without the afterburners until such time as additional
    propane becomes available,
    and
    not be in violations of these
    regulations.
    The emissions from the facility, without the afterburners
    operating, consist of cotton particulates, hydrocarbons, and
    phenol.
    The emission rate of cotton is not known but is
    characterized as being “small quantities and non-odoriferous”.
    The hydrocarbon emissions are characterized as “non-photochemically
    reactive” and are emitted at a rate of approximately 181 lb./hr.
    The phenol emission rate
    is not known but according to the
    Agency is a potential odor problem.
    According to the petitioner, no hazardous effects of
    nuisances were evidenced during the 10 years
    the plant operated
    prior to installing the afterburners.
    The Agency’s interviews
    with people in the neighborhood did not find strong opposition
    to the granting of a variance, however,
    few had lived in the area
    prior to the installation of the afterburners.
    From the facts presented in this case, it is unclear
    whether a variance from the rules cited
    is really needed.
    The
    burden is on Allen to show that compliance with the rules is im-
    possible.
    It is therefore necessary that Allen perform a stack
    test to determine the emission levels from the facility with and
    without the afterburners operating.
    This would resolve the
    uncertainty with regard to Rules 203 and 205(f).
    In addition, since
    compliance with Rule 205(f) depends in part on the presence or
    absence of an odor nuisance, and since the Agency feels that a
    potential odor problem could occur, it will also be necessary to
    record any citizen reaction while operating without the afterburners.
    All has made a good faith effort in attempting to solve their
    fuel shortage problem; they have petitioned the Federal Oil and
    Gas Board for a re-allocation so as to allow PetroTex to supply
    the needed propane;
    they have investigated and discarded the
    use of electric or coal-fired boilers and effluent gas scrubbing
    as being non-viable or too costly; and they are willing to
    investigate energy reuse
    (heat recovery)
    schemes such as afterburner
    heat exchangers.
    We will require them to continue their search
    for additional fuel and investigate the technical feasibility
    of heat recovery systems such as heat exchangers in the afterburners.
    11
    —~

    ORDER
    The variance petition of the Herrin facility of Allen
    Industries,
    Inc.
    is hereby granted with respect
    to Rules
    203(a),
    203(b)
    and 205(f) until July
    1,
    1974,
    subject to the following
    conditions:
    1.
    Petitioner shall perform
    a stack sampling test on their
    emission sources with and without
    the afterburners
    operating
    and report the results
    to the Agency by June
    15,
    1974.
    2.
    Petitioner shall
    study and report to the Agency by July
    1,
    1974 on the feasibility of energy recovery or reuse systems
    such
    as
    heat
    exchangers
    on
    the
    afterburners.
    3.
    Petitioner
    shall
    continue
    all
    reasonable
    efforts
    to
    obtain
    additional
    supplies
    of
    natural
    gas
    and
    propane.
    4.
    Petitioner
    shall
    operate
    the
    afterburners
    whenever
    fuel
    supplies
    or allocations permit.
    5.
    Petitioner shall post
    a $5,000 bond to be forfeited
    in the event
    of non-compliance with Conditions
    1 or
    2
    of this Order.
    IT
    IS SO ORDERED.
    I, Christan L.
    Moffett, Clerk of the Illinois Pollution Control
    Board, here~ certify the above Opinion and Order
    ere adopted
    on
    the
    .~
    day of February,
    1974 by
    a vote
    of
    —~
    od~fr•1
    ~Jgth~
    Christan
    L. Moffetf
    erk
    Illinois
    Pollution
    ntrol Board
    11
    397

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