ILLINOIS POLLUTION CONTROL BOARD
June
3,
1993
GENERAL
CHEMICAL CORPORATION,
)
(Chemical Manufacturing Plant),
)
)
Petitioner,
)
v.
)
PCB 92—217
(Variance)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
ORDER OF THE BOARD
(by B. Forcade):
This matter comes to the Board on a Motion to Reconsider
filed on May
7,
1993 by General Chemical Corporation, Chemical
Manufacturing Plant
(GCC).
GCC seeks reconsideration of the
Board’s April
8,
1993 order.
The Environmental Protection Agency
(Agency)
has not filed a response to the motion for
reconsideration.
The Board in its April
8,
1993 order, granted GCC a variance
from the provisions of 35 Ill. Adm. Code 201.141 and 212.322 (a)
regarding air pollution and emissions of particulate matter for
its facility located in Fairmont City,
Canteen Township,
St.
Clair County,
Illinois.
The Board granted the variance with the
conditions requested by the Agency.
GCC had previously filed a motion for reconsideration on
April
16,
1993.
The Board on April 22,
1993,
denied the motion
for reconsideration because it did not clearly specify what
portions of the order GCC was requesting the Board to reconsider.
The Board noted that it did not consider the response filed by
GCC on April
9,
1993,
because it was received after the Board had
issued its order granting the variance and further it was not
filed within the time permitted by the Board’s procedural rules.
The Board further noted that GCC could file a second motion for
reconsideration clearly stating the requested changes.
GCC
is requesting the Board to reduce the maximum allowable
emission rates of 84.23 lbs/hour of particulate matter
(PM) to a
rate of 40 lbs/hour PM.
GCC is also requesting an amendment to
the construction schedule and the completion schedule.
GCC notes that it did not request a specific level of
allowable particulate emissions in its variance petition.
The
Agency suggested a limit of 84.23
lbs/hour of PM.
Stack tests
conducted in January of 1993 revealed that the plant could be
operated at an expected maximum particulate emission rate of
34.75 lbs/hour.
GCC is requesting a maximum allowable emission
rate of 40 lbs/hour to allow for unforeseen upsets.
GCC notes
0
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2
that the requested level
is approximately half the level
suggested by the Agency and previously allowed by the Board.
The schedule as set forth
in the variance was established
from information submitted to the Agency by GCC.
After preparing
specifications and seeking bids,
GCC discovered that additional
time was needed to prepare additional engineering documents.
Due
to the additional time required GCC is unable to meet the
proposed schedule.
GCC states that the amendments to the
construction schedule are relatively minor especially considering
the reduced level of PM emissions.
GCC also notes that the Agency recommendation refers to
particulate emission limit as 8.16 lbs/hr.
GCC contends that
this a typographical error and that the limit required by its
permit
issued on November 18,
1992
is 8.17 lbs/hr allowable
particulate matter.
The Board will correct the emission limit to
8.17 lbs/hr.
The Board grants the motion for reconsideration and issues a
new order is this matter incorporating the changes as requested
by GCC.
ORDER
Petitioner General Chemical Corporation
(Chemical
Manufacturing Plant) (GCC)
is hereby granted a variance from the
provisions of
35
Ill.
Adm. Code 212.322(a)
for its facility
located in Fairmont City,
Canteen Township, St. Clair County,
Illinois subject to the following conditions:
1.
This variance shall expire on December
1,
1993.
2.
The allowable emissions during the variance period shall be
40 pounds per hour of particulate matter, with the same process
weight rate
(2.8 tons per hour)
and the same operating hours as
currently permitted (6,384 hours per year), until thirty
(30)
days after the fabric baghouse dust collector and related
components are installed or October 1,
1993, whichever occurs
first.
Thereafter,
the allowable emissions rate shall be 8.17
pounds per hour of particulate matter, with the same process
weight rate and operating hours as currently permitted, until the
expiration of this variance.
3.
Petitioner shall comply with the following conditions:
a.
A fabric baghouse dust collector, with appropriate
modifications to the stack and hardware components, shall be
installed on the SAS roaster on or before August 28,
1993.
b.
An emergency quench system with an alarm system shall
be installed on the stack on or before August 28,
1993
01
L~3-UQ58
3
c.
A manometer shall be installed as part of the fabric
baghouse dust collector to monitor a pressure drop across
the fabric baghouse dust collector on or before August 28,
1993.
d.
GCC shall submit progress reports to the Agency at the
beginning of each month detailing all progress made towards
installing and testing the fabric baghouse dust collector
and other items required to be installed and listed above.
These progress reports shall be signed by an authorized
officer of GCC, certifying that the progress report in
question is true,
correct and complete, to the best of such
officer’s knowledge.
e.
On or before May
1,
1993, CCC shall submit to the
Agency a copy of an appropriately executed and delivered
purchase contract for a fabric baghouse dust collector,
manometer, water quench system and related items necessary
to install and operate the fabric baghouse dust collector.
The contract shall be certified by an authorized officer of
GCC to be true,
correct and complete,
and in full force and
effect,
to the best of such officer’s knowledge.
f.
On or before May
1,
1993, GCC shall submit to the
Agency a copy of an appropriately executed and delivered
construction or engineering contract for a fabric baghouse
dust collector,
manometer, water quench system and related
items necessary to install and operate the fabric baghouse
dust collector.
The contract shall be certified by an
authorized officer of GCC to be true, correct and complete,
and in full force and effect, to the best of such officer’s
knowledge.
g.
Items listed in subparagraphs
(d) through
(f) above
shall be sent addressed as follows:
State of Illinois EPA
Division of Legal Counsel
2200 Churchill Road
P.O. Box 19276
Springfield, Illinois
Attention:
IEPA #734-92
State of IllinoisfEPA
Regional Manager/Bureau of Air
2009 Mall Street
Collinsville, Illinois
62234
Attention: John Justice
4.
In addition to the standard permit conditions, and any other
special permit conditions the Agency may specify, CCC shall
operate the Plant during the term of the variance under the
U
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4
following special permit conditions:
a.
GCC shall maintain records of the following items, and
such other items as may be appropriate, to allow the Agency
to review compliance with the emission limits in Paragraph 2
above:
(i)
SAS liquor flow rate (gal/mm)
to the SAS
Evaporation and Roasting Process;
(ii)
SAS liquor specific gravity for each shift;
and
(iii)
The hourly process weight rate for the SAS
Evaporation and Roasting Process based on the
SAS liquor flow rate and specific gravity.
b.
The records listed in subparagraph
(a) above shall be
retained for two years and shall be available for inspection
by the Agency.
c.
On or before August 31,
1993, the particulate matter
and SO2 emissions of the SAS Evaporation and Roasting
Process shall be measured by an approved testing service
during conditions that are representative of maximum
emissions,
and a final report of the results of the tests
shall be submitted to the Agency on or before September 22,
1993.
d.
The following methods and procedures shall be used for
testing of emissions, unless another method is approved by
the Agency
(Refer to 40 CFR 60, Appendix A for USEPA test
methods):
Location of Sample Points
USEPA Method
1
Gas Flow and Velocity
USEPA Method
2
Particulate Matter
USEPA Method
5
Sulfur Dioxide
34 Ill.
Adm. Code
214.101 (a) (USEPA Method
6)
As part of the measurement of particulate matter emissions,
CCC shall measure and report both the inorganic and organic
condensable particulate matter in the USEPA Method 5
impinger catch.
e.
During the above—referenced tests, the following
process information shall be determined:
(1)
Process liquor flow rate,
concentration and
process weight rate:
01 L~.3-QQ6O
5
(ii)
Process operating temperatures; and
(iii)
Pressure drop across the baghouse.
Process liquor feed rate, concentration, process weight
rate,
and process operating temperatures shall be determined
based on the SAS operating log and SAS concentration feed
rate record sheet.
Pressure drops across the baghouse shall
be measured with a permanently installed manometer as part
of the particulate matter collection system.
f.
At least thirty
(30) days prior to the actual date of
testing, CCC shall submit a written test plan to the Agency
for review and approval.
This plan shall describe the
specific procedures for testing, including at a minimum:
(i)
The person(s) who will be performing sampling
and analysis and their experience with
similar tests;
(ii)
The specific conditions under which testing
will be performed,
including a discussion of
why these conditions will be representative
of maximum emissions and the means by which
the operating parameters for the source and
any control equipment will be determined;
(iii)
The specific determinations of emissions and
operation which are intended to be made,
including sampling and monitoring locations;
(iv)
The test method(s) which will be used, with
the specific analysis method,
if the method
can be used with different analysis methods
(v)
Any minor changes in standard methodology
proposed to accommodate the specific
circumstances of testing, with justification;
(vi)
Any proposed use of an alternative test
method, with detailed justification; and
(vii)
The format and content of the Source Test
Report.
g.
The SAS Evaporation and Roasting Process shall be
operated during testing in accordance with normal operating
practices.
Process or pollution control equipment
modifications prior to the tests shall be documented.
The
report shall include any changes that may enhance
particulate matter control efficiency or reduce emissions
through changes
in operating conditions.
01 i~3-0O6
I
6
h.
Prior to carrying out these tests, CCC shall notify the
Agency’s regional office and the Agency’s Source Emission
Test Specialist,
at the addresses for notice set forth
below,
a minimum of thirty
(30) days prior to the expected
date of these tests and a minimum of five
(5) working days
prior to the test of the exact date, time and place of these
tests,
to enable the Agency to witness these tests.
Illinois Environmental Protection Agency
Division of Air Pollution Control
—
Regional Office
2009 Mall Street
Collinsville, Illinois
62234
Illinois Environmental Protection Agency
Attn:
Source Emission Test Specialist
Division of Air Pollution Control
Intercontinental Center
1701 First Avenue
Maywood,
Illinois
60153
i.
CCC shall submit three
(3)
copies of the Final
Report(s) to the Agency within fourteen (14)
days after the
test results are compiled and finalized.
j.
GCC shall submit a copy of the Summary of Results,
General Information and Conclusions,
as contained in the
Final Report, to the Source Emission Test Specialist.
k.
The Final Report shall include at a minimum:
(i)
A summary of results;
(ii)
General information;
(iii)
Description of test methods(s),
including
description of sampling points, sampling
train, analysis equipment,
and test schedule;
(iv)
Detailed description of test conditions;
(v)
Process information,
i.e., mode(s) of
operation,
process rate,
e.g. fuel or raw
material consumption;
(vi)
Control equipment information,
i.e.,
equipment condition and operating parameters
during testing;
(vii)
A discussion of any preparatory action taken,
i.e.,
inspections, maintenance,
repair,
etc.;
01 L~.3-QO62
7
(viii)
Data and calculations, including copies of
all raw data sheets and records of laboratory
analysis, sample calculations,
and data on
equipment calibration; and
(ix)
An explanation of any discrepancies among
individual tests or anomalous data.
1.
CCC shall,
in accordance with the manufacturer(s)’
and/or vendor(s)’ recommendations, perform periodic
maintenance on the pollution control equipment such that the
pollution control equipment shall be kept in proper working
condition and not cause a violation of the Act or
regulations promulgated thereunder.
m.
GCC shall maintain an operating log for the SAS
Evaporation and Roasting Process air pollution control
system for the dryer, which at a minimum includes status of
the SAS particulate matter control system at least one per
shift,
adjustments of the baghouse operating parameters, the
results of inspections, and maintenance and repair activity.
n.
CCC shall perform daily inspections on the SAS
Evaporation and Roasting Process and the new SAS air
pollution control system for the dryer to assure proper
operation of equipment.
o.
GCC shall maintain maintenance records at the Plant and
the maintenance records shall be subjected to inspections by
the Agency as specified in Condition Number
8 of the
Agency’s Standard Conditions for Operation Permits.
5.
Within forty-five
(45) days after the date of this order,
CCC shall execute a certification of acceptance of this variance,
by which it agrees to be bound by its terms and conditions,
and
send it to:
L.L. Kroack
Assistant Counsel
Bureau of Air
Illinois Environmental Protection Agency
P.O. Box 19276
Springfield,
Illinois
62794—9276
This forty-five
(45) day period shall be held in abeyance for any
period during which this matter
is appealed.
The form of the
certification shall be as follows:
01 ~.3-0O$3
8
CERTIFICATION
General Chemical Corporation, having read the Order of the
Illinois Pollution Control Board in PCB 92—217, understands and
accepts said order, realizing that such acceptance renders all
terms and conditions thereto binding and enforceable.
General Chemical Corporation
By:
As Authorized Agent
TITLE
DATE
Failure to execute and forward the Certification within 45—days
renders this variance void and of no force and effect as a shield
against enforcement of rules from which this variance is granted.
IT IS SO ORDERED.
Section 41 of the Environmental Protection Act,
(415 ILCS
5/41
(1992)), provides for appeal of final orders of the Board
within 35 days.
The Rules of the Supreme Court of Illinois
establish filing requirements.
(See also 35 Ill.
Adia.
Code
101.246, Motion for Reconsideration.)
I,
Dorothy M. Gunn,
Clerk of the Illinois Pollution Control
Bo4rd,
hereby cert
that the above order was adopted on jthe
day of
£~~-.--&~
,
1993,
by a vote of
~
/
~
)~.
Dorothy M. c~I~n,Clerk’
Illinois Pc4jution Control Board
Ut
L~.3-0O61~.