ILLINOIS POLLUTION CONTROL BOARD
November 2, 1978
STEPAN CHEMICAL CO.,
Petitioner,
v.
)
PCB 78—220
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
OPINION AND ORDER OF THE BOARD (by Mr. Goodman):
Stepan Chemical Company (Stepan) submitted a variance petition
on August 14, 1978. The Environmental Protection Agency (Agency)
submitted its recommendation on September 25, 1978. Stepan
waived its right to a hearing, and no hearing has been held.
The subject of Stepan’s variance petition is its Millsdale
Plant, a phthalic anhydride plant located in Will County near
Elwood, Illinois. The plant has been the subject of prior var-
iance proceedings before the Board, PC3 74—425 and PCB 76-161.
The phthalic anhydride process was described in the Board’s
Opinion in PCB 74-425. Byproducts of the process include hydro-
carbons, some in particulate form, carbon monoxide and carbon
dioxide, all of which are discharged to the atmosphere along with
excess air after condensing the phthalic anhydride.
In PCB 76—161, the Board granted Stepan a variance from Rules
203(a), 205(f), 205(g) (1) (C) and 206(c) of Chapter 2: Air Pollu-
tion Regulations, until August 15, 1978. Stepan’s compliance plan
consisted
of the installation of a catalytic reactor on the waste
gas stream of the plant. The reactor was to be installed and
debugged by August 15, 1978. However, although installation was
completed by August, 1978, a fire occurre~~in the exhaust stack
shortly after operation began, and the catalytic system was shut
down. To prevent further fires or explosions, Stepan plans to
change the damper design. Stepan estimates that redesign and
replacement of the dampers will be accomplished by November 15,
1978. Stepan, therefore, requests that its variance be further
extended until November 15. A variance from Rule 206(c), however,
is no longer necessary because of the Board’s modification of that
rule.
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At rated capacity, Stepan’s Milisdale Plant emits from the
condensers of its phthalic anhydride production process approxim-
ately 1,750 lbs./hr. of carbon monoxide, 267,000 lbs./hr. of
nitrogen, 6,000 lbs./hr. of carbon dioxide, 64,400 lbs./hr. of
oxygen, and an average of 1,000 lbs./hr. of hydrocarbons, of which
less than 100 lbs/hr. on the average are in particulate form. The
Agency indicates that one of two particulate monitors in the qen—
eral vicinity of the Milisdale plant recorded a violation in 1977
of the primary ambient air quality standard for particulate matter
on an annual geometric mean. The only Will County monitor for
ozone is in Joliet; it recorded 124 violations of the photochemical
oxidant standard in 1977.
Stepan’s use of the catalytic reactor it has installed
represents new application of this technology and will bring the
facility fully into compliance. Stepan has made satisfactory
progress toward compliance and has been unable to comply due to
circumstances beyond its control. Because the replacement dampers
need to be redesigned for the equipment, the three month variance
request is reasonable. The Board finds that denial of the
requested variance would result in an arbitrary and unreasonable
hardship to Stepan. We find that Stepan is unable to comply with
Rules 203(a), 205(f) and 205(g) (1) (C) until the catalytic reactor
is operating and hereby grant Stepan a variance from those rules
until November 15, 1978, subject to the conditions detailed in
our Order.
This Opinion constitutes the findings of fact and conclusions
of law of the Board in this matter.
ORDER
It is the Order of the Pollution Control Board that Stepan
Chemical Co. be and is hereby granted variance from Rules 203(a)
205(f) and 205(g) (1) (C) of Chapter 2 for its Milidale Plant until
November 15, 1978, subject to the following conditions:
1) Stepan shall design, fabricate and install dampers
for the catalytic reactor by November 1~, 1978.
Stepan shall start up and debug the catalytic reactor
by November 15, 1978. Until November 15, 1978,
Stepan shall minimize emissions as much as possible;
2) Stepan shall conduct stack tests for particulates
and organics within thirty-five (35) days after
installation of the dampers and completion of the
reactor;
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3) Within sixty (60) days of the date of this Order,
Stepan shall apply for and obtain all necessary
Agency construction and operating permits;
4) Stepan shall, on or about the 15th day of the month
subsequent to the entry of this Order, submit to the
Environmental Protection Agency a written report
detailing all progress towards compliance, such
report to be submitted to:
Environmental Protection Agency
Control Program Coordinator
2200 Churchill Road
Springfield, Illinois 62706
5) Stepan shall, within twenty-eight (28) days of the
date of this Order, continue in effect its perfor-
mance bond in the amount of Twenty—Five Thousand
Dollars ($25,000), in a form satisfactory to the
Environmental Protection Agency, to insure compliance
with the control program detailed in the accompanying
Opinion. Such bond shall be submitted to the Envir-
onmental Protection Agency at the address given in
subparagraph (4) above;
6) Stepan shall, within twenty-eight (28) days of the
date of the Order, execute and send to: Kathryn S.
Nesburg, Technical Advisor, 1701 South First Avenue,
Maywood, Illinois, 60153, a certification of acce~-
tance of this variance by which it agrees to be
bound by its terms and conditions. This twenty-
eight (28) day period shall be held in abeyance for
any period in which this matter is appealed. The
form of said certification shall be as follows:
I (We),
_____________________________
having read and
fully understanding the Order of the Illinois Pollution Control
Board in PCB 78-220 hereby accept the said Order and agree to
be bound by all terms and conditions thereof.
SIGNED
TITLE
DATE
-
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7) Final compliance must be achieved by July 1, 1979, or
Stepan will be subject to noncompliance penalties under
Section 120 of the Clean Air Act as amended in August,
1977 (42 U.S.C. 7401 et
I, Christan L. Moffett, Clerk of the Illinois Pollution
Control Board, he~p1~ycertify the ab ye Opi ion and Order were
adopted on the
~“
day of
________________,
1978 by
a vote of
~/~-c~
Christan L. Moffe
,
rk
Illinois Pollution
rol Board
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