ILLINO~

POLLUTION CONTROL BOARD

Dcember

20,

1977

ENVIRONMENTAL PROTECTION AGENCY

Complainant,

v,

)

PCB 76-35

TRUMBULL ASPHALT, DIVISION OF OWENS—

CORNING FIBERGLASS CORPORATION,

)

Respondent,

MS. ANNE

K. MARKEY,

ASSISTANT ATTORNEY GENERAL, APPEARF~FOR

THE COMPLAINANT.

HALFPENNY, HAHN AND ROCHE

(Mr.

James F. Flanagan,

of

counsel),

ATTORNEYS AT LAW, APPEARED

FOR

THE RESPONDENT,

OPINION AND ORDER OF THE BOARD (h~~

Mr. Werner):

I.

LEGAL BACKGROUND

This matter comes before the Board on the February

6,

1976

Complaint brought by the Environmental Protection Agency

(Agency)

charging Trumbull Asphalt Company of Delaware

with violations of Rules

103(a)

and 103(b) (2)

of Chapter

2:

Air Pollution

(Chapter 2)

and Section 9(b)

of the Environmental

Protection Act

(Act), Hearings were held on September 30,

1976 and November 15,

1976.

The parties filed

a Stipulation

and Proposal for Settlement on November

7,

1977.

In the stipulation,

the parties have agreed to strike

Trumbull 1\sphalt Company of Delaware as

a party Respondent

and put Trumbull Asphalt, Division of Owens Corning

Fiberglass Corporation

(Trumbull-Owens)

in its place.

The Board hereby substitutes Trumbull-Owens as the party

Respondent.

II, FACTUAL BACKGROUND

Trumbull-Owens owns and operates an asphalt manufacturing

plant located about 14 miles southwest of Chicago’s Loop

area in Summit,

Illinois,

28

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423

---

The plar c

self and land to the sou1

zoned

I~2 “limited inJ~

while land to the no

‘ncluding

Summit Park)

is zc~e~

J

“light industriaL”

~o~s

Midway Airport is loc~

2 1/2 miles to the e~

~nd a large

industrial

area known a~ the Clearing District

etches out

along the Belt Railroad so~Lhens~from the plar

ite.

The Trumbull Summit Plant produces aithiow

~sphalt

for roofing, paving, and speci~Jt

r

~roducts.

The plant

is one or

the laLgest airbiown a~~a1toperatLos

in the

country, producing an average of 1,000 tons of asphalt a

day.

The plant employs a staff of

65 people, and operates

3—production shifts

(i.e.,

24 hours per day).

The asphalt production operation consists

~f

loadinq

flux

oil products into feed tanks.

A preheater ~after burner

warms the flux before it is sent to one of

9 vertical or’idation

stills~

Once in the still, air is then passed through the

flux, which dehydrogenates the crude material.

The oxygen

combines with hydrogen in the flux to form water vapor.

This

loss of hydrogen results

in polymerization

or condensation

of the flux into asphalt of the ~mired

consistency.

The

exothermic nature of tt

airblowing process liberates

a great amount of heat.

The pr ouct is continuously removed

and the vapors are run through

rnockout drum and then the

heat and remaining

off gases are circulated back to the preheater—after-

burner to be incinerated.

The off gases contain sulfur

com-

pounds and hydrocarbons

as gases and aerosols.

Once the desired consistency is obtained in the stills,

the asphalt is circulated to storage tanks until needed

for shipping.

Asphalts are delivered to large usage customers

by tank trailers or railroad cars which are loaded from

overhead racks,

The preheater—afterburner carries

on

several

functions.

Matoria

from

several of the storage tanks may be circulated

through uach of

the

preheater—afterburners

to

absorb

excess

heat.

The heated material

is then circulated back to the

storage

tanks,

This assists

in keeping the asphalts in a

liquid state.

There are four process areas in the Trumbull—Owens

plant that may be run independently of each other,

These

four systems are referred

tr-’

as Bulk Roofing Process

No.

1,

Bulk Roofing Process No.

2,

Specialty Roofing Process and

Paving Products Process,

The two areas that serve multiple

process lines contain feed and storage tanks only.

28

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424

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—3—

As an integral part of the aforesaid facility, Trumbull-

Owens operates

5 truck loading racks,

30 hot asphalt feed

and storage tanks, and

9 stills all of which are capable of

emitting odorous hydrocarbons.

All of this equipment was

operational prior to April 14,

1972 and has been operated

continuously without an Agency Operating permit.

Trumbull-Owens in the stipulation admits to a violation of

Rule 103(b) (2)

of Chapter 2 and Section 9(b)

III. STIPULATION AND SETTLEMENT

Trumbull-Owens agrees to undertake compliance measures

in strict accordance with all the terms and conditions of

the detailed compliance plan delineated in the Stipulation

and Proposal for Settlement.

This detailed compliance plan contains 22 specific steps

to be taken pertaining to Trumbull-Owens’

asphalt converter

stills,

loading docks and asphalt storage tanks in order

Compliance measures concerning its

9 asphalt converter

stills include:

(a)

Strict numerical temperature

controls

on

preheaters

#1,

2,

and

3 when

batch

and

tinuous stills are in operation;

(b)

Zero opacity will be maintained

on

all

pre-heater stacks at all times;

(c)

A preventive maintenance program which in—

Ci

u(1eS

per

i

odi

c

i n:•;pec t:

i

on of

t

he’

e’xpl

osi on

lid~

on

the conver

I err;

k)r

o::~:

i

hi

e

“break

—

Lhroughsu or

defects

(as

well as

a

point—by—point

log

on all activities) will be submitted to

the Agency within 60 days after the acceptance

of the settlement stipulation by the Board;

(d)

Trumbull-Owens will maintain a log of all

complaints received concerning asphalt related

odor.

The log will be available for inspection

by representatives of the Agency.

Trumbull-Owens

agrees to make an investigation on any odor

complaint and report back to the complainant;

and

28

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425

---

—4—

(e)

The

Agency

will

be

notified

fo~.anyinc~.~se

in

production

using

current equ4.pmen.t.

In

the

event

of

~

further

increase ~.n.

load

on

the

converters,

Trumbull

agrees to~~forn~

a

stack

test

to

determine

compliance.

Compliance

measures

concerning

the

5

truck

loading

racks

include:

(a)

Installation

and

use(within

two

months

~f

the

BOard

Order

approving

th*S

Settlèfltftflt~

of

a

specialized

loading

dock

strueture1tg

combine

the

two

loading

racks

~ocáted.~etwsen

tanks

#17

and

#40,

Its

usewi.l

re4~cetr~ick

loading

time

from

25

minutes

to

app~oxima~ely

6

minutes.

This

time

reductiofl,alqn9Wj.th

an

increased

updraft,

will.

greatly ~dUc

the

venting

of

fumes

to

the

atinOsphér~,

Fumes

from

loading

operations

will~dueted

to

the

afterburner-incinerator;

(b)

The

fume

recovery

system

for

the

,1o.~put

rack

on

stills

#6,

#7,

#8

and 4~

modified

to

increase

the

suction~pressure

•and

to

control

adequately

fugitive

emissjons.during

loading

operations;

Cc)

Trumbull

will

notify

the Agenc~y~of.~n~

complaints

concerning

asphalt

re1atë4~’odor

at

times

when

the

emergency

lo4~out:;r~ck

for

stills

#1

and

#2

is

used...

U

the

~g~ncy

determines

that

the

use

of

thi~

l~ad’p’~it:rack

creates

an

odor

problem,

then

.~ithcr

Trumbull

will

install

c~n

incineration

or vapoJz~çO9very

system

that

is

adequate

to

control

fu~tive

emissions,

or

it

will

cease

tOuse

the:

1.oad

out

rack

for

stills

#1

and

#2at.àny

timà;and

(d)

The

afterburner-incinerator

for vapor recovery

will

be

equinped

with

a

control syst~m:~nd~.

a

stack

test

will

be

performed

in; t~e eE~er’

burner to determine its

conversiori~ffia.ie~cy.

This will be performed within:3•.monthS

of

the

Board’s approval

of

this

settlement..

and th.

Agency will be informed prior:tothe’t~est.

28

—

426

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—5—

Moreover, the afterburner-incinerator wilL

nave a

retention

time of one—half second at 1200°F,

Trumbull

will modify

the incinerator if necessary to insure that the retention

time,flow rate, and temperature are adequate to treat all

vapor recovery systems connected to the incinerator.

Compliance measures concerning the

30

hot asphalt

feed and storage tanks include:

‘a)

Vapor emissions from tank #33 are bubbled into

a 55 gallon drum filled with water.

If this arrangement

is inadequate to control odor emissions from tank #33,

then

Trumbull will install

a fume scrubber similar to the scrubber

on tank #15.

Prior to reactivation of tanks #46,

#47,

#48,

and #49,

they will be provided

with

an adequate vapor re-

covery or incineration system;

(b)

The fume scrubber controlling the fumes from tank

#15 will be operated at all

times

when asphalt products are

loaded or unloaded;

(c)

Tank #11

is used

to store #63 oil and is heated

to a temperature of 450°F.

Trumbull will install an

automatic temperature control device and a vapor recovery

system on this tank;

(d)

Tanks

#9,

#10,

#12,

#13 and #14 are raw material

storage tanks for the specialty roofing process and are

normally maintained at temperatures below 325°F. Storage

tanks

#1,

2,

3,

4,

5,

6,

7 and

8 are currently used

for fuel oil shortage.

Therefore, none of these tanks

currently need vapor control systems.

However, if Trumbull

at any time desires to use any of these tanks for hot products,

it will provide an adequate vapor recovery or

incinerati.on

system for each tank

so used.

Other provisions of the compliance plan include

the following requirements:

(a)

Trumbull will apply to the Agency for construction

and operating permits for

any

modifications

to its

afterburner -incinerator or vapor recovery systems that it

is making currently or that it plans to make in the

future.

and,

28

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427

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—6—

(b)

Within 12 months after

the

Board’s approval

of

this

set~1ement,

Trumbull

will

have

completed

all

the

requirements

of

this

Compliance

Plan

and

will

have

obtained

all

necessary

permits

from

the

Agency.

If

Trumbull

js

unable

to

comply

with

any

time

limit

in

the

compliance

plan

due

to

circumstances

beyond

its

control,

an

extension

of

that

time

limit

may

be

allowed

by

agreement

of

the

parties

and approval

by

the

Board.

Parenthetically, the Board has noted that the Stipulation

and

Proposal

for

Settlement

appears

to

have

two

typographical

errors.

Paragraphs

7

and

8

of

the

Stipulated

Background

Facts

refer to the

“equipment described

in paragraph 7.”

Since no

equipment has,

in fact, been described in paragraph

7, the

phrase “the equipment described in paragraphs

5 and

6” was

obviously intended.

Moreover, on the last page of the settle-

ment proposal, the address to which penalty payment shall

be made is hereby corrected to read

“State of Illinois, Fiscal

Services Division, Illinois Environmental Protection Agency,

2200 Churchill Road, Springfield,

Iii.

62706.”

The Board accepts the Stipulation and Proposal for

Settlement and finds Trumbull-Owens in violation of Rules 103(a)

and 103(b) (2)

of Chapter

2 and Section 9(b) of the Act from

February

1, 1973 until February 6,

1976.

The Board imposes

the stipulated penalty of $5,000.00.

This Opinion and Order constitute the findings of

fact and conclusions of law of the Board.

28

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428

---

—7—

ORDER

It

is

the

Order

of

the

Pollution

Control

Board

that:

1.

Trumbull-Owens

has

violated

Rules

103(a)

and

103(b)

(2)

of

Chapter

2

and

Section

9(b)

of

the

Act

from

February

1,

1973

until

February

6,

1976.

2.

Within

30

days

of

the

date

of

this

Order,

Trumbull-

Owens

shall

pay

the

stipulated

penalty

of

$5,000~00,

payment

to

be

made

by

certified

check

or

money

order

to:

State

of

Illinois

Fiscal

Services

Division

Illinois

Environmental

Protection

Agency

2200

Churchill

Road

Springfield,

Illinois

62706

3.

Trumbull-Owens

shall

comply

with

all

terms

and

conditions

of

the

Stipulation

and

Proposal

for

Settlement

filed

November

7,

1977,

which

is

incorporated

by

reference

as

if

fully

set

forth

herein.

I,

Christan

L.

Moffett,

Clerk

of

the

Illinois

Pollution

Control

Board,

hereby

certify

the

above

Opinion

a

d

Order were adopted on the

e~c~t

day

of

—,

1977

by a vote of

______

Christan L. Moffe~JClerk

Illinois Pollutiofr~ontro1Board

28

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429