ILLINOIS POLLUTION CONTROL
    BOARD
    October
    4,
    1979
    ALLIED CHEMICAL CORPORATION,
    )
    Petitioner,
    v.
    )
    PCB 79—101
    )
    ENVIRONMENTAL PROTECTION AGENCY,
    )
    Respondent.
    OPINION OF THE BOARD
    (by Dr. Satchell):
    This matter comes before the Board upon a petition for
    variance filed April 26, 1979 and amendments filed June
    1 and
    August 29,
    1979 by Allied Chemical Company
    (Allied).
    The
    petition and amendments request a variance from the requirements
    of Rule 105(c),
    204(f) (1) (A)
    and 204(f) (2) (A)
    of Chapter
    2:
    Air
    Pollution.
    Rule 105(c)
    provides for operation of an emission
    source during malfunction, breakdown or startup.
    The sub-
    sections of Rule 204(f)
    set emission limits of 2000 ppm for
    sulfur dioxide and 0.15 pounds of sulfuric acid mist per ton of
    acid
    manufactured.
    Allied waived its right to a hearing and
    the Environmental Protection Agency
    (Agency)
    filed
    a recommendation
    on July 19,
    1979 and an amended recommendation on September 18,
    1979.
    The latter recommended that the variance be granted with
    conditions.
    On September 20, 1979,
    pursuant to Allied’s motion
    for expedited consideration, the Board entered an Order granting
    the variance with conditions similar to those recommended by the
    Agency.
    Allied operates a three—unit sulfuric acid plant at its Calumet
    Works in a mixed industrial and residential area south of Chicago.
    The plant produces
    a waste gas stream which is passed through a
    Weilman—Lord sulfur dioxide recovery system which is designed to
    handle 35,000 scfm with 3000 to 5000 ppm sulfur dioxide and 2100
    mg/rn3 acid mist and which recovers
    sulfuric acid and converts
    the sulfur dioxide to
    a useable byproduct.
    When oper4ting, the
    system emits 20 to 500 ppm sulfur dioxide and 15 mg/ma acid mist
    through
    a 120 foot stack
    (Amended Rec.
    2).
    The system has been
    in service for six years and is in need of major repairs which are
    scheduled for the month of October,
    1979.
    Rather than shut the
    plant down for this period, Allied proposes to duct its emissions
    directly to the atmosphere through a fifty-five foot stack.
    Air
    Rule 105(c)
    provides for continued operation to prevent injury to
    35—463
    —2—
    persons,
    severe damage to equipment or to provide essential
    services.
    Even if this were
    a malfunction or breakdown, the
    Agency could not grant permission under Rule 105(c)
    to operate
    in violation of standards solely for the economic benefit of the
    operator.
    The Agency figures the uncontrolled average emissions at
    2700 ppm or 866
    lbs/hr sulfur dioxide and 2100 mg/rn3 or 236
    lbs/hr acid mist.
    Maximum emissions could amount to 1284 and
    642
    lbs/hr,
    respectively.
    The Agency has predicted the results
    of the uncontrolled emissions on air quality for 400 points
    in
    a 20 x 20 kilometer area by means of an Air Quality Short Term
    Model--Running Average Version.
    The results of this modeling
    indicated that
    the
    24—hr averaging time was the most constraining
    and that,
    after eliminating the single highest value,
    the second
    highest 24-hr average ambient air concen~rationresulting from
    uncontrolled emissions would be 604 mg/rn
    .
    Adding the background
    concentration, the Agency arrived at a predicted maximum 24—hr
    average concentration of 624 mg/rn3 sulfur dioxide.
    The attain-
    ment status of the area around the plant for the sulfur dioxide
    National Ambient Air Quality Standards
    (NAAQS)
    is listed as
    “Cannot Be Classified”
    43
    Fed.
    Reg.
    8987
    (1978)).
    The 24—hr
    NAAQS is
    365 mg/rn3 sulfur dioxide.
    The Agency model also predicted that excursions above the
    NAAQS
    for sulfur dioxide will occur from the
    fifty—five foot
    stack only when the wind blows in excess of fifteen knots
    in one
    direction for more than three hours and the sulfur dioxide
    emission rate is
    in excess of 736 lbs/hr.
    Accordingly, the
    Agency recommended that the variance be conditioned on a wind
    and sulfur dioxide monitoring program.
    The Board also required
    that Allied limit its emissions when the wind exceeded fifteen
    knots
    in one direction for more than three hours.
    Allied will
    be expected to reduce its process rate
    if necessary to achieve
    this.
    Bringing the plant to
    a cold shutdown may cause layoffs and
    damage to equipment and will result in a startup with high energy
    consumption and emissions.
    The Board finds that there would be,
    under the particular circumstances of this case,
    an arbitrary and
    unreasonable hardship in requiring compliance with the emission
    standards during the maintenance shutdown of the waste gas recov-
    ery system.
    This variance may be granted only if consistent with
    the Federal Clean Air Act
    (42 U.S.C.
    §7401 et seq.
    and
    §
    35 of
    the Environmental Protection Act).
    Since it
    wilT
    extend beyond
    July 1,
    1979,
    it will be submitted to the U.
    S. Environmental
    Protection Agency as an amendment to the State Implementation
    Plan.
    35—4
    64
    —3—
    This Opinion, supporting the Order of September
    20,
    1979,
    constitutes the Board’s findings of fact and conclusions of
    law in this matter.
    Mr. Werner concurs.
    I, Christan L.
    Moffett, Clerk of the Illinois Pollution
    Control Board, hereby
    e tify the above Opinion was adopted
    on the
    ~
    day of
    _________,
    1979 by
    a vote of
    ______
    Christan
    L. Moff
    i-~yrC
    erk
    Illinois Pollution ~e’ontro1Board
    35—465

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