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