ILLINOIS POLLUTION CONTROL BOARD
July
8, 1976
SALEM GRAVURE, DIVISION OF WORLD
)
COLOR PRESS,
INC.,
)
)
Petitioner,
v.
)
PCB 76—51
)
ENVIRONMENTAL PROTECTION AGENCY,
)
)
Respondent.
OPINION AND ORDER OF THE BOARD
(by Dr. Satchell):
This matter comes before the Pollution Control Board
(Board)
as a petition for variance from Rule 205(f)
of the
Chapter
2: Air Pollution Control Regulations.
The original
petition was filed February 26,
1976.
Additional information
was filed by Salem Gravure
(Salem)
on March 26,
1976.
The
Environmental Protection Agency
(Agency)
filed its Recommenda-
tion on June 8,
1976.
No hearing was held in this matter.
Salem is requesting a variance from Rule 205(f)
of the Air
Pollution Regulations
to allow the running of three rotogravure
printing presses until October
1,
1976.
At this time, Petitioner
will have installed and operating the solvent recovery systems
necessary to be
in compliance with all the Regulations.
The
controlling regulation is deemed to be Rule 205(f) (1) (B)
and
in the Agency’s opinion Petitioner should not encounter any
problem in meeting the 85
required control efficiency with the
installation of the control system.
Salem’s failure to complete the solvent recovery system
with the rest of its new plant was caused by cancellation of
its contract with the original supplier who because of poor
financial condition might not have been able to complete the
system.
Failure to obtain this variance is alleged by Petitioner
to impose an unreasonable hardship because of long term,
multi-million dollar contracts to print weekly and monthly
publications when missed deadlines could result in defaulted
contracts and possible litigation.
The economic impact of the placing of the new plant in
Marion County is extremely favorable to the area.
Petitioner
states that the area had an unemployment figure of 16.6
in
February of 1976.
Salem would employ about 2
of the total
—2—
work force
(about 425)
in the county.
By January
1, 1982,
Salem estimates
it will be employing over 1,000 people with
an average wage rate of $8.50 per hour.
The Agency granted a construction permit
(No.
C 512020)
on March
4,
1976 which included five printing presses,
copper
and chrome plating tanks, three boilers, four cyclones, five
binders,
and an activated carbon solvent recovery system which
includes five carbon beds each containing 25,000 pounds of
activated carbon.
The Agency estimates the cost of the
activated carbon units at about $1.3 million.
The initial
start-up of the solvent recovery system is scheduled for
August 15, 1976.
Petitioner states that the three presses being built
at this time
(No.
301,
a proof press, Nos. 302,
303, produc-
tion presses) will use about 1,216 pounds of solvents per hour:
Roto Solvent (composition not given)
961.44
Naphtha
(largely pentanesand hexanes)* 188.70
Toluene
(methyl benzene)*
55.08
Xylene
(dimethyl benzene)*
10.72
Total
1215.94
*Merck Index 8th Ed. Naphtha listed as “petroleum benzin”.
It is estimated five per cent of the solvent would be con-
sumed.
In conference with Agency personnel,
Mr. Littlejohn, chief
corporate engineer, World Color Press, stated #302 commenced
operation in April,
1976;
#303 will be operative about July 1,
1976 and #301 may be operative before October 1,
1976.
The
solvent usage values supra are for full production rates.
The Salem facility immediately borders the Salem Texaco
Oil production area which the Agency would expect to be a
major source of organic material emissions.
Since Petitioner’s
facility is new, the Agency cannot reliably estimate the degree
of unreasonable interference this plant may cause to members
of the public.
The known chemical emissions
(toluene, xylene
and naphtha)
all have a relatively low level of toxicity but
are explosive in sufficient concentration.
As with other
organic chemical emissions,
~phb~ochemical smog and ozone
production could be enhanced.
The consideration of the effect of Petitioner’s emissions
on ambient air quality with regard to applicable standards
is not easily solved.
The report submitted by P
& W Engineers,
Inc., titled “Addenda to the Variance Petition
(PCB 76—51)
for
—3—
World Color Press,
Inc., Salem Gravure Division”
(hereinafter
Report)
states that at the present time, 1,752 tons/year
(hydrocarbons) are being emitted by various industrial pro-
cesses in Marion County,
of which 194.5 tons/year are emitted
in the city of Salem.
To determine the effects of Salem’s
emissions, an atmospheric dispersion model was selected and
the Pasquill equation used to calculate ground level concen-
trations.
The results are given in Table
1 of the Report:
Table
1.
Maximum Hydrocarbon Ground Level Concentrations
Distance
Hydrocarbons
Hydrocarbons
Hydrocarbons
Total
Downwind
from 301
from 302
from 303
Hydrocarbons
0.1 KM
0.00089
mg/l
0.0187
mg/i
0.0187
mg/l
0.0383
mg/i
0.5 KM
0.000088 mg/l
0.00184 mg/i
0.00184 mg/l
0.00377 mg/i
1.0 KM
0.000023 mg/i
0.00048 mg/l
0.00048 mg/l
0.00098 mg/l
Presumably based on this table, the Agency states the Report
predicts a worst condition hydrocarbon concentration of about
3,770 micrograms per cubic meter
(~ug/m3)of air at a distance
of one kilometer from the point of emission.
This value would
indicate the plant would “cause a serious air quality problem”
(Agency Rec. at 6).
Examination of the Table does not validate
the quoted figure.
The actual figure is believed to be
0.00098 mg/l minus the contribution of #301
(0.000023 mg/l)
(since it would not be on stream)
or 0.000957 mg/i which
on conversion becomes 957 ~.iug/m3
when presses Nos.
302 and
303 are operated 75
of the time.
In a document submitted
July 2,
1976 by P
& W Engineers,
Inc. entitled,
“Supplementary
Information for Variance Petition,” the actual operation of the
one press at this time is given as 50
of the time so that the
emissions would be less than one-half of 957 ,ug/m3.
An ambient air quality standard of 160 ~ug/m3maximum
3-hour concentration has been established for non—methane
hydrocarbons which is not to be exceeded more than once a
year.
(Chapter 2, Part III, Rule 309).
The Agency states
that the Report would indicate short term violations of
ambient air quality for hydrocarbons, but that “the Agency
believes that the report was too poorly constructed to give
the projection any credence.
Indeed, no reliable hydrocarbon
dispersion model exists at this time.”
—4—
The Agency recommends that either the variance be denied
or be granted subject to a number of conditions.
The Board
is disposed to grant the variance subject to the conditions
stated in the Order for the following reasons:
1.
The environmental damages or hazards are believed
to be insignificant if the ozone
level is monitored
and the plant shut down when levels of 0.17 ppm
(1-
hour averaging time)
are reached for three consecutive
days.
2.
The information gathered during the variance period
would be very valuable in considering hydrocarbon
dispersal in the future.
This Opinion constitutes the Board’s findings of fact
and conclusions of law in this matter.
ORDER
It is the Order of the Pollution Control Board that
Salem Gravure, Division of World Color Press,
Inc., be
granted variance from Rule 205(f) (1) (B) of the Board’s
Chapter 2: Air Pollution Control Regulations until October 1,
1976 or until such time as the activated carbon recovery
system is operational, whichever date comes first;
and
subject to the following conditions:
1.
Petitioner shall submit monthly progress reports
to the Agency on the first business day of each
month until the project is completed.
Reports shall
be sent to the following address:
Program Control Coordinator
Illinois Environmental Protection Agency
Division of Air Pollution Control
2200 Churchill Road
Springfield, Illinois 62706
2.
No later than twenty-one
(21)
days after the date
on which Petitioner completes construction and
installation of its activated carbon recovery
system, Petitioner shall submit to the Agency an
application for an operating permit for said
system and the printing presses which it controls;
within ninety
(90) days after the date said
application for an operating permit is submitted
to the Agency, Petitioner shall obtain an operating
permit for both the presses and the activated carbon
recovery system.
—5—
3.
Proximate to its printing facility, Petitioner shall
maintain, and operate for a period not less than one
year from the date of this Order both in-stack and
ambient air monitoring equipment to measure concen-
trations of both ozone and hydrocarbons.
Petitioner
shall seek and obtain approval from the Agency re-
garding the type and location of said equipment no
later than twenty-eight
(28)
days from this Order.
The Agency shall have the right to inspect Petitioner’s
ambient air monitoring equipment and require operation
of said equipment in accordance with methods approved
by the Agency.
During the variance period, Petitioner
shall cease all operations which cause hydrocarbon
emissions on the third consecutive day that ambient
air monitors indicate an ozone level of 0.17 ppm or
higher using a 1-hour averaging time and will not
resume these operations until the day after the afore-
mentioned monitors indicate an ozone level of 0.07 ppm
or less using a 2-hour averaging time through one
full day.
4.
Petitioner shall keep record charts to document
emissions measurements from its stack monitoring
equipment and ambient air monitoring equipment de-
scribed in condition
(3)
above.
Such records shall
be kept on the premises of Petitioner’s facility
available for Agency inspection for a period not
less than one year from the date the record charts
are made.
Such records shall include emission
measurements for each monitoring unit expressed in
micrograms per cubic meter of air, time of measure-
ment, and wind direction.
5.
To insure compliance pursuant to Section
36 of the
Illinois Environmental Protection Act, Petitioner
shall file with the Agency’s Control Program Coordinator
at the address above a performance bond in the amount
of $50,000 and in a form acceptable to the Agency no
later than twenty-eight
(28) days from this Order.
6.
Within thirty-five
(35)
days of this Order herein,
Petitioner shall execute and forward to the Control
Program Coordinator, a Certification of Acceptance
and Agreement to be bound to all terms and conditions
of the Board Order.
The form of said Certification
shall be as
follows,:
—6—
CERTIFICATION
I
(We),
,
having
read and fully understanding the Order of the Illinois
Pollution Control Board in PCB 76-51 hereby accept said
Order and agree to be bound by all the terms and conditions
thereof.
Signed by
Title
Date
Mr. Jacob D. Dumelle dissents.
I, Christan
L. Moffett, Clerk of the Illinois Pollution
Control Board here~y~ertifythe abov
Opinion and Order were
adopt~don the
_________
day of
______________,
1976 by a vote
of
I4~
llinois Pollution