ILLINOIS POLLUTiON CONTROL BOARD
    October 1, 1987
    IBS, INC.,
    Petitioner,
    v.
    )
    PCB 87—143
    ILLINOIS ENVIRONMENTAL
    PROTECTION ACJENC~’,
    Respondent.
    OPINION AND ORDER OF Th~BOARD (by 3.D. Dumelle):
    This provisional variance request comes before the Board
    upon a September 30, 1967, Recommendation of the Illinois
    Environmental Protection Agency (Agency) and an October 1, 1987,
    addendum to that Recommendation. The Agency recommends that
    because of an arbitrary and unreasonable hardship, IBS, Inc., be
    granted a provisional variance to enable it to participate in a
    study funded by the Agency and the United States Environmental
    Protection Agency (USEPA). lBS seeks variance from Section 9(b)
    of the Illinois Environmental Protection Act (Act), which
    requires that no person shall operate an emission source in
    violation of any permit condition.
    One of the special permit conditions of the company’s
    current permit prohibits it from burning any PVC coated wire in
    its wire burning incinerator. lBS would like to participate in
    the study described above by burning assorted wires now on—site
    for the purposes of a 2~3 day trial burn. The Agency states
    that, while IBS, Inc. has visually identified wire which it
    believes to the best of its knowledge do not contain PVC
    material, it cannot completely guarantee that it will be
    complying with the special permit condition on its current
    permit. It is for this reason that lBS seeks the provisional
    variance.
    The Agency stated that it has recently become aware that
    burning PVC material in an oxygen—starved environment such as
    that found in a wire burning in incinerator may produce dioxins
    and furans which can be of concern to the environment. In an
    effort to study the problem, the Agency and the USEPA are funding
    projects designed for further study of this problem.
    The study is designed to two phases, as follows: Phase 1:
    lBS
    now
    seeks provisional variance for its participation
    in
    Phase
    1. Phase 1 involves site assessments to obtain operating data
    from wire reclaiming incinerators. The Agency and USEPA have
    requested that existing ash be cleaned out of the incinerators.
    82—111

    Pnase 1 requires that the incinerator be operated for a period of
    1—3 days. lBS believes that it will be burning wire with non—
    vinyl chloride insulation during the Phase 1 burn, but lBS will
    be burning wire which has the same combustion characteristics.
    During a test burn, it will be necessary to keep the soil around
    the wire burning incinerator unit dampened to avoid stirring up
    any dust. During Phase 1 of the study, an EPA contractor would
    set up temperature monitoring equipment and take gas samples
    throughout 1 or 2 operating cycles. This 2—3 day test burn would
    be conducted during the week of October 12, 1987. Because one
    company believes that PVC coated wire can be visually identified
    with certainty, Phase 1 of the study will also include a portion
    addressed to methods of identification of wires coated with PVC—
    containing insulation. Phase 2: The location of the Phase 2
    portion of this study has not yet been determined. However, the
    Phase 2 portion of this study would involve a stack emissions
    test for dioxin which would be performed using the parameters
    obtained during the Phase 1 portion of this study. Phase 2 would
    be conducted using ordinary and normal operating conditions,
    which might include burning wire with PVC insulation.
    The purpose of Phase 1 and Phase 2 of the study is to assess
    the quantity. if any, of dioxin likely to be emitted into the air
    from wire reclamation incinerators, and to identify conditions
    under which the units could be safely operated. As stated
    previously, the Agency has requested that existing ash be cleaned
    out of the lBS incinerator prior to operation of the
    incinerator. The Agency has made specific recommendations to lBS
    for the removal of the ash and has required proper disposal
    methods as set forth to the company in correspondence to them.
    Ash and soil samples were taken by the USEPA as part of the
    Tier Four of the National Dioxin Strategy. For analysis
    purposes, the Agencyts information regarding levels of concern
    for 2,3,7,8—TCDD dioxin equivalents would be one part. per billion
    in residential areas and 0.006 ppb’s (or six parts per trillion)
    in grazing areas. Levels of concern for non—residential areas
    are determined on a case—by—case basis, but the majority of
    levels of concern for non—residential sites fall in the range of
    5—15 parts per billion. lBS is located in a highly developed
    commercial and industrial area.
    As a result of the receipt of test results at lBS in the
    Tier Four National Dioxin Strategy, the Agency collected samples
    from 12 sites in Illinois. Some concentrations were found at all
    sites at which samples were taken; however, concentrations were
    less than levels of concern at all but five sites in Illinois.
    As a result of the ash samples taken by USEPA at IBS, USEPA
    determined that it would take soil samples of the soil
    surrounding the 155 wire burning incinerator.
    82—112

    —3—
    Upon receipt of the first results of sampling at the lBS
    incinerator, lBS was requested to and has ceased operation of the
    incinerator on site. Further, the incinerator and the process
    area have been secured by allowing no personnel in the secured
    area, preventing disturbance of the soil or anything else in the
    area, identifying ash on site and securing it, and identifying
    any recovered wire or other material processed through the
    incinerator on site. In addressing the expected emissions as a
    result of the test burn at the lBS site, the Agency stated that
    it believes that if the ash is properly removed from the
    incinerator and non—PVC containing wire is burned, it is
    extremely unlikely that any emissions of dioxins would ensue.
    Any emissions would likely be primarily particulates.
    However, lBS and other facilities have stated that while
    they believe they are able to visually identify wire coated with
    PVC insulation, they cannot be 100 certain that visual
    identification will identify such wire. If some PVC coated wire
    escapes detection and is charged into the incinerator, it is
    possible that some PCDC’s may be generated. Some small amount
    may escape destruction in the afterburner and be emitted into the
    atmosphere. To estimate the potential quantity of POLE that may
    be emitted, a comparison may be made to a somewhat similar unit
    that has been tested for PCDD emissions under a USEPA contract.
    This particular unit is allowed by its operating permit (issued
    by the State of Georgia) to burn up to 200 lbs/hour of PVC wire
    but typically only burns about 20 lbs/hr. An average of three
    test runs disclosed an average emission of 114 micrograms per
    hour of total PCDD’S. Currently USEPA is engaged in dispersion
    modeling and population risk assessment studies to attempt to
    determine the significance of wire reclaiming incinerators
    emissions to public health and welfare. However, since the
    purpose of the Phase 1 and Phase 2 testing by USEPA and IEPA is
    to assess the quantity, if any, of dioxin likely to be emitted
    into the air from wire reclamation, the Agency stated that it
    cannot state with certainty the expecteã amount of emissions. It
    is this which Phase 2 of the study will ultimately determine.
    Pursuant to Section 35(b) of the Act, the Board hereby
    grants the provisional variance as recommended.
    This Cpinion constitutes the Board’s findings of fact and
    conclusions of law in this matter.
    ORDER
    155, Inc., is hereby granted a provisional variance from
    Section 9(b) of the Illinois Environmental Protection Act, as
    recommended by the Illinois Environmental Protection Agency.
    IT IS SO ORDERED.
    Board Member M. Nardulli abstained.
    82—113

    —4—
    Board Members J. Anderson and R. Flemal were absent.
    I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Opinion and Order was
    adopted on the
    /A4’
    day of
    &~A.
    ,
    1987 by a vote
    of
    -
    .
    Dorothy M. dunn, Clerk
    Illinois Pollution Control Board
    82—1 14

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