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
    ~3-UO57

    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
    L~3-OO59

    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~.

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