1. ILLINOIS POLLUTION CONTROL BOARD
      2. June 26~ 1975
      3. Complainant,

ILLINOIS POLLUTION CONTROL BOARD
June 26~ 1975
ENVIRONMENTAL PROTECTION AGENCY,
Complainant,
V.
ILLINOIS NITROGEN CORPORATION,
Respondent,
and
)
PCB 73-517 and PCB 74-169
Consolidated
ILLINOIS
NITROGEN
CORPORATION,
1,
ThVIRONMENTAL
PROTECTION
AGENCY,
Respondent.
iPINION
AND
ORDER
OF
THE
BOARD
(by
Mr.
Goodman):
This matter comes before
the Pollution Control Board
)Board)
upon stipulation of facts
and proposed settlement
netween
Complainant-Respondent,
the
Environmental Protection
Apency
(Agency.)
of the
State
of
Illinois,
and Respondent—
Petitioner,
Ilitnols
Nitrogen
Corporation
(Illinois
Nitrogen).
The
Agency
filed
a complaint against Illinois Nitrogen
on December
7,
1973, PCB 73—517,
alleging
that Illinois
Nitrcgen~s
fertilizer
and.
nitric
acid plant located at
Marseilles,
Illinois, LaSaile County, has been operating
without
an Agency
operating
permit
thereby violating Rule
103(b)
of
the Air
Regulations
and Section 9(b)
of the Environ-
mental Protection Act
(Act).
In
addition the Agency alleges
that Illinois
Nitrogen
is
allowing emissions of contaminants
into the environment of the State so as to tend to cause air
pollution in Illinois in violation of
Section
9(a)
of the
Act.
An appeal from permit denial
was filed with the Board
on
May
1,
1974, by Illinois Nitrogen, PCB 74-169,
alleging
that the
Agency had denied a permit for Illinois Nitrogen~s
nitric acid plant which, they alleged, had
been demonstrated
to be in compliance
with applicable regulations.
On May 9,
1974,
upon motion to consolidate by Illinois Nitrogen,
the
Board ordered
the two cases, PCB 73-517
and PCB 74-169,
to
be consolidated.
On June
6,
1974, Illinois Nitrogen filed
an open waiver against the requirement of Section 40 of the
17
371

—2—
Act, which waiver was amended on July
1,
1974 by Illinois
Nitrogen to extend until
60 days after the close of the
record.
A hearing was held April
30,
1975,
at which time both
parties indicated that the matter had been settled and that
a stipulation of fact and proposed settlement would be
forthcoming.
The aforementioned stipulation of facts and
proposed settlement was filed with the Board May 1,
1975.
On May 20,
1975, the Agency filed with the Board
a proposed
Order for the Board’s consideration in the case.
Stipulation of Facts
Illinois Nitrogen operates a nitrogen fertilizer manu-
facturing plant located on the Illinois River approximately
one mile east of the city of Marseilles, LaSalle County,
Illinois.
This is the company’s only manufacturing facility.
The basic products of the plant are liquid nitrogen fertilizer
solutions and solid ammonium nitrate prilled fertilzer.
The
plant also trans-ships anhydrous ammonia for fertilizer use.
The fertilizer from the plant is sold solely for agricultural
purposes in Illinois and other midwestern states.
The basic raw material used at the plant is anhydrous
ammonia.
This material is received by barge and stored in
two large refrigerated tanks with capacities
of 20,000 and
22,000 tons respectively.
The anhydrous ammonia is piped to
a 350 ton per day
(rated capacity) nitric acid plant which
produces a 55
concentration of weak nitric acid.
The weak
nitric acid
is then reacted in a neutralizer to produce an
83
ammonium nitrate solution.
This ammonium nitrate is
stored in a 17,000 ton stainless steel storage tank,
and is
fed,
as required,
to either the solutions plant for the
production of liquid fertilizer or to the prilling tower for
the production of solid fertilizer.
These operations produce
atmospheric emissions of nitrogen oxide, ammonia gas, and
particulate.
The stipulation indicates that Illinois Nitrogen has
equipped its nitric acid plant with
a control system known
as the MASAR system for the abatement of NO~emissions.
The
MASAR system has reduced visible emissions from the nitric
acid plant stack to near zero opacity, and it is concluded
that the nitric acid plant:
(a)
is
in compliance with the
NO~emissions limits;
and
(b)
is entitled to an operating
permit.
(Stipulation, page
4)
The prilling operation at the Illinois Nitrogen facility
causes some particulate emissions of very small particle
size, mostly being in the 0.05 to 0.4 micron range.
These
particulate emissions are caused during the production of
solid arnmonium nitrate from the liquid ammonium nitrate
solution generated by the nitric acid plant, the transformation
17

—3—
taking place
in what is known as a prilling tower.
Stack
tests indicated particulate emissions of approximately
42
pounds per hour at
a prilling tower process weight rate of
8.7 tons per hour.
The allowable emissions under Rule
203(b)
of Air Regulations for a process~weightrate of 8.7
tons per hour is 17.3 pounds per hour.
Illinois Nitrogen concedes that its prilling tower
particulate emissions exceed the limit set for either new or
existing sources.
Illinois Nitrogen further concedes that
it is operating its prilling tower without an operating
permit issued by EPA.
The stipulation proposes that Illinois Nitrogen proceed
to install
a newly developed system for particulate control
at
a capital cost of
$1,015,000.
In addition they propose
a
compliance schedule which would achieve
final compliance by
July,
1977.
Illinois Nitrogen agrees to pay a penalty in
the amount of $2,500 for operating the prilling tower without
an operating permit issued by the Illinois Environmental
Protection Agency.
The stipulation further states that no significant
quantities of ammonia gas are emitted to the atmosphere at
Illinois Nitrogen as
a result of normal manufacturing opera-
tions.
Varying amounts of ammonia gas can be emitted,
however, from storage tank relief valves, railroad tank
cars,
barge unloading and pump seals if such pump seals are
defective.
Illinois Nitrogen agrees to take a number of
steps to improve housekeeping and to change
a number of
minor handling procedures
in order to eliminate any ammonia
emissions on their property.
Illinois Nitrogen also agrees
that in the event that a leak, spill, or equipment malfunction
occurs, which releases any significant amount of ammonia
into the atmosphere,
it will notify the Agency Emergency
Action Center,
and that they will work together with the
Agency to prevent or minimize any adverse environmental
effects or impact caused by said occurance.
Considerations
The Board accepts the stipulation of facts and proposed
settlement as submitted by the parties.
There was no comment
by the public at the hearing and the solutions to the issues
proposed by the parties appear to be in the best interest of
the public and the environment.
The Agency agrees that the
nitric acid plant
is
in compliance with the emission limits
and is entitled to an operating permit and Illinois Nitrogen
concedes its prilling tower particulate emission exceeds the
limits set for new or existing sources and accepts the
proposed penalty of $2,500 for operating the prilling tower
without an operating permit issued by the Agency.
Illinois
Nitrogen in addition agrees to install equipment to correct
the emissions from the prilling tower and to improve its
17 —373

—4—
ammonia handling procedures.
The total cost of the project
to be undertaken by Illinois Nitrogen to abate the prilling
tower emissions is $1,015,000 and the project completion
date is projected to be July,
1977.
The Board, having
thoroughly considered the stipulation of facts and proposed
settlement, hereby adopts the terms of that settlement as
though fully set forth herein.
This Opinion constitutes the Board~sfindings of fact
and conclusions of law.
ORDER
It is the Order of the Pollution Control Board that:
I.
Illinois Nitrogen is found to have operated their
ammonia nitrate prilling plant
in violation of
Rule 103(b)
of the Air Regulations,
Rule 3-3,2512
of the Rules and Regulations governing the control
of air pollution
(Air Rules),
and Section 9(a)
of
the Act, and is ordered to pay a penalty of $2,500
for said violations, payment to be made by certi-
fied check or money order payable to the State of
Illinois, Environmental Protection Agency, Fiscal
Services Division,
2200 Churchill Road, Springfield,
Illinois
62706, payment to be made within
35 days
of the adoption of this Order.
2.
Illinois Nitrogen is hereby ordered to:
a,
Commence on—site construction and installation
of emission control equipment for their
prilling tower no later than October
31,
1976; and
b.
Complete on—site construction and installation
of emission control equipment including
process modifications
for the prilling tower
no later than January
31,
1977;
and
c.
Achieve final compliance with Rule 203(a)
of
the Air Pollution Regulations no later than
April
30,
1977;
and
d.
Complete all testing necessary for determining
final compliance of prilling tower by July
31,
1977.
3.
Illinois Nitrogen shall apply to the Environmental
Protection Agency by July 31, 1975,
for all nec-
essary permits based on the then available information,
4.
The Agency shall issue an operating permit for
Illinois Nitrogen~snitric acid plant located in
17
374

—5—
Marseilles, Illinois,
on or before September
1,
1975.
5.
Illinois Nitrogen shall post
a performance
bond without surety to the E~-ivironmenta1Protection
Agency in the amount of $100,000 within 35 days of
this Order.
6.
Illinois Nitrogen shall submit quarterly written
reports to the Agency setting forth its progress
in the implementation of this Order.
IT
IS
SO ORDERED.
I,
Christan L. Moffett, Clerk of the Illinois Pollution
Control
Board,
hereby
cert,ify the above,,,~Opinionand Order
were
adopted
~n
the
~
day of
~
1975 by
avoteof
~
.
Illinois
Pollution
17
—375

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