ILLINOIS POLLUTION CONTROL BOARD

August 22, 1984

STAUFFER

CHEMICAL

COMPANY,

)

)

Petitioner,

PCB

84—36

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY,

Respondents

HR~. RICHARD

H~SANDERS AND MR~STEVEN

M~

HARTMAN

OF

VEDDER,

PRICE,

KAUFMAN & KAMMHOLZ APPEARED ON BEHALF OF STAUFFER

CHEMICAL

COMPANY

MR~ PETER

E~ORLINSKY, ATTORNEY—AT-LAW,

APPEARED ON BEHALF OF THE

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY~

OPINION AND ORDER OF THE BOARD

(by J,D~

Dumelie):

This matter comes before the Board upon a March 23,

1984,

petition for a site—specific sulfur dioxide limitation applicable

to Stauffer Chemical Company~s(Stauffer~s) Chicago Heights

Piant~

On May 29,

1984, the Illinois Environmental Protection

Agency (Agency)

filed a recommendation that the request be

granted~

Fiearing

was held on July 6,

1984,

in Chicago Heights~

The

Facility

Stauffer

Chemical owns

and

operates

a plant

at 11th and

Arnold

Streets in Chicago Heights, which is located within the

Chicago

Major Metropolitan Area as defined

in

35

Ill~Adm~

Code

211~i22~The plant is a major producer

of

calcium,

sodium

and

ammonium phosphates, phosphoric acid, and sodium bicarbonate~

The

phosphates are produced from burning elemental phosphorus

in

~

iurnace

and hydrating the combustion product to phosphoric

acid~

The acid is then reacted with the corresponding alkali

to

produce

calcium,

sodium

or

arnmonium

phosphates.

The sodium

bicarbonate

is produced from very pure soda

ash,

water and carbon

dioxide.

The products are used

in

the food and drug,

detergent,

fertilizer,

paper, petroleum and plastics industries.

The

process includes the

use

of a coal—fired boiler

with

a

stack

diameter of over 13 feet and a height

of

180 feet~ The

59-417

---

2

exit

gas

has

a

volume

of

about

50,000

actual

cubic

feet per

minute

at

an

averace velocity

of

5.0 feet per second and a

teoperature

of

3500

F~

The

facility

controls

its

particulate

emissiuns

by

use

of

a

Zurn

Type

5—MBSA~144—8~300

baghouse

with

an

area

c;f

37:700

square

feet

of

fiberglass

cloth,

divided

into

5

compartments.

The

unit

was

installed

in

1979

at

a

cost

of

$750,000

and

was

guaranteed

by

Zurn

to

operate

at

an

emiss:Lon

rate

of

2.0 pounds per hour of particulates and was measured

at

1~

4

pounds

per

hour

in

the

acceptance

test,

at

a

peak

load

of

3~,(~OO

pounds per hour of steam.

Regulato~~~m~or1c

Emissions

from Stauffer~sfacility are presently governed

by

35Iil~Adm. Code 214~141,which limits

SC~.

emissions to

1.8

lbs./mEtu,

Pursuant

to Section 214.201, f~cilityowners

or

operators

may

petition

the Board for

alternate

emission

limitations

of

up

to

6.8

lbs./mBtu,

provided

they

can

demonstrate

that

the

proposed

emission rate will not, under

predictable

worst

case

conditions, cause or contribute to a

violation of any applicable

primary

or secondary SO2 ambient

air

standard

or

applicable

PSD

increment.

The

Envjro~~alIm

act

Stauffer

has requested a sulfur

dioxide

emission

limitation

of

6.8

lbs./mBtu and

has

presented modeling results to support

its

claims

that if its

current

sulfur

dioxide emission limitation

of

1.8

ibs,/mBtu is raised to 6.8 lbs./mBtu,

there would

be

no

resuit:Lng

violations

of the National

Ambient

Air

Quality

Standards

(NA3~QS), nor

would there be any significant impact on the

Agency’s

February,

1982 sulfur dioxide model

of the Chicago area.

The

Agency

has analyzed the data

presented

by Stauffer and concluded

“that

the allegations

have

been

substantiated

and

that

a.

6~8

lb,/million Btu standard for

the

boiler in question

would

not

cause

an ambient air quality violation~ (Rec, p.3)~

In its

modelling

Stauffer relied

upon

1975 meteorological

data

identified

by the Agency as

the

~worst

case~’

year and

utilized

the

MPTER

and

RAM dispersion

models

recommended

by

the

United

States

Environmental Protection Agency

for

use

in

urban

areas,

Ninety~six

receptors were used in the

air

quality assessment,

located

1 kilometer apart in

a grid pattern covering approximately

144

square

kilometers around

the

Chicago

Heights

plant,

and nine

additional

receptors

were

included to ensure

that

the

maximum

im~act of

the plant’s emissions would

be detected.

The

site—specific

so

emission

rate

requested

for

the

Ch:Lcaqo

Heights plant wil’ have no significant adverse impact on

air

quality

in the vicinity of the plant.

The

modeling verifies

that

the incremental

sulfur

dioxide increase from the plant will

59-418

---

3

not

rusuit

in

concentrations

exceeding

88

of

the

NAAQS.

Even

when

increases

in

SO

concentrations

attributable

to

an

emission

limitation

to 6,8

lb~/mBtuare added to the contributions from

other

sources

within a 15 kilometer radius

and

Agency

determined

baseline concentrations, the aggregate receptor concentrat~ons

at

the

second3highest

concentration level are only

390.3 ug/m~and

225.7

na/m~

,

respe~tively,which are substantially below 1040

uq/rn~

and 292 ug/m

(80

of the

3 and

24—hour maximum NAAQS).

In

fact,

the

report by ETA Engineering,

Inc.

(which

is attached to

the

petition

for site—specific regulatory

relief

as

Appendix

A

and

which documents the modeling) concludes

that

the

proposed

emission

limitation increase “would not cause the concentration

of

any

receptor analyzed to be within 65

of

the

NAAQS

for

sulphur

diox:Ld&’

(App.

A,

p.

24), and that “the Stauffer—Chicago Heights

facility

will not cause any PSD

Prevention

of Significant

Deterioration

air increments to be exceede&

(App.

A,

pp.~

14,

i7~18).3The applicab~eallowable limits*

(3

and

24—hour)

are

512

ug/m

and 91 ug/m

,

respectively,

while the maximu~increases

for

the

~orst

cases’ conditions modeled

are

193.3

ug/m

and

56.8 ug/m

,

respectively

(App.

A, pp.

14,

17).

Based

on the record before

it, the Board

finds that

the

requested

emission rates for Stauffer~s

facility

will

not

cause

or

contribute to violations of ambient air

quality

standards nor

exceed any PSD increments that might otherwise apply, and

that

granting

a relaxed SO~emission limitation

will

not have an

adverse

environmental~effect.

Based

on those findings, the Board concludes that

Stauffer

has

made

a sufficient demonstration

pursuant

to

Section

214.201

to

justify

a relaxed

sulfur dioxide emission standard,

However,

the

Board

cannot

conclude that an emission

level

of

6.8

ibs.JmBtu

has

been

lustified.

In its recommendation, the Agency notes that

Stauffer~s.

“description of the coal

it is planning to burn specifies

that

the

sulfur

content will not exceed

3.6

and

the heating

value

will

be

12,500 Btu/lb,

The Agency

has calculated that coal

with

such

characteristics will yield emissions of 5.47 lb/million

btu

of

actual

heat input.

The Agency believes, therefore,

that

Petit

acer

should clarify its purpose in seeking

a 6.8

lb/million

Eta

limitation”

(Rec,

p.

3

Sta~iffer~s

only response

to

this

was presented through

the

testimony

of Howard Perrault,

a

Technical

Manager

for

Stauffer,

*

Stauffer

correctly contends that

PSI) analysis

is

inapplicable

to its petition

since its boiler

was equipped prior to 1975

to

burn

Illinois coal,

and

in fact

did so,

A

switch

between

coals

of differing coal content is

exempt

from the definition

of

“major

modification” under the

PSI)

rules,

and thus

these

rules

do not apply.

40 C.F,R,

59-419

---

4

who stated that “the standard is the state standard.

And by

having that standard set for us,

it will allow us to search for

the most

the best coal for our purposes and also allow for the

possible variation

in the sulfur content of the coal”

(R.

12).

The only other relevant

information

concerning

the

necessary

emission standard is that when Mr. Perrault was asked what sort

of coal was currently being tested for use, he responded that

Stauffer recently concluded tests on coals with “a sulfur content

of ~

(R

•

11),

Based upon this limited evidence, the Board can not find

that Stauffer has justified an emission standard of greater than

6.Oibs./mBtu.

Illinois coal which will meet that standard is

clearly available, there is no showing that variability requires

a higher standard,

and it is in the public interest to limit

emissions of sulfur dioxide as much as is reasonable, The Board

notes

in this regard that culpability modeling shows a potential

“hot spot” at one receptor assuming maximum emissions from the

American Brick facility in Dolton (which

is not currently in

operation

and which there is

no

reason

to

believe will operate

in

the near future).

While it

is alleged that Stauffer’s contribution

to the modeled violation

is below the level

of significance,*

that modeling serves to demonstrate that care should be taken in

allowing relaxed limitations to minimize the potential for such

“hot spots” and that the Board should not grant relaxations

beyond levels which have

been

justified.

Section 9.2 of the Illinois Environmental Protection Act

allows

for the relaxation

of

sulfur dioxide limitations in order

to encourage the use of Illinois coal where such use is consistent

with achievement of the ambient air quality standards,

This

action is consistent with the legislative intent expressed therein.

The Board, therefore, will grant an alternative limitation

of 6~0lbs.

SO,/mBtu, with compliance to be measured by 35

Ill.

Adm. Code 214.101(c).

This Opinion constitutes the Board’s

findings of fact and conclusions of law in this matter,

ORDER

Stauffar Chemical Company is hereby granted an alternative

emission limitation

for sulfur dioxide emissions applicable to

its boiler at its Chicago Heights facility of 6.0 pounds per

million British Thermal Units of heat input pursuant to 35

III. Adm.

Code 214.201, subject to the following condition:

*

Data supporting this allegation

is lacking, but there is no

evidence to rebut it,

See App.

A,

p.

23.

59-420’

---

5

Within 30 days of the date of this Order,

Stauffer

Chemical Company shall apply to the Illinois Environmental

Protection Agency for a revision of its operating

permit for its Chicago Heights faci1ity~sboiler con~

sistent with this Opinion and Order.

I, Dorothy H.

Gunn, Clerk of the Illinois Pollution Control

Board, her~7certify that the above Opinion and Order was adopted

on the ~

day of

~

1984 by a vote of

H.

unn

,

Ciark

Illinois Pollution Control Board

59-421