ILLINOIS POLLUTION CONTROL BOARD
May 8, 1975
ILLINOIS BRICK COMPANY, a Division
of Old Fort Industries, Inc.,
)
Petitioner,
)
vs.
)
PCB 74—241
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
PATRICK PHILLIPS, Attorney for Petitioner
KATHRYN NESBURG, Attorney for Respondent
OPINION AND ORDER OF THE BOARD (by Mr. Henss):
On June 25, 1974 Illinois Brick filed Petition for Variance
seeking relief from Sections 9(a) and 9(b) of the Environmental
Protection Act and Rule 103(b) (2) of the Air Pollution Control
Regulations. The Board found that petition to be inadequate
because there was no data regarding ambient levels of hydrogen
sulfide both upwind and downwii-id of Petitioner’s plant. Illinois
Brick was ordered to supply such additional data.
In August 1974 Petitioner advised the Board that it had
made arra~gementsfor testing of the air around the plant, and
sought approval of the test method proposed by its testing firm.
The Board approved the proposed testing method and allowed
Illinois Brick until September 25, 1974 to file the required test
results.
The hydrogen sulfide test results were timely filed. Two
tests were conducted during separate blow-down periods. The
first test shàwed an average hydrogen sulfide concentration of
30 parts per billion (ppb) downwind and 4 ppb upwind. On the
second test, downwind and upwind concentrations each averaged
5 ppb.
Subsequently Illinois Brick filed an Amended Petition re-
questing variance to March 1, 1975 and a motion seeking the grant
of such relief without a public hearing. The Board denied the
motion for decision without hearing. On March 18, 1975 Illinois
16— 561
2—
Brick filed its Second Amendment to Petition for Variance
seeking relief until May 1, 1975. Public hearing on the
Second Amendment to Petition for Variance was conducted on
March 19, 1975.
Petitioner owns and operates a concrete block manu-
facturing facility in Broadview, Cook County, Illinois. In
the block making process, Petitioner mixes slag, limestone
screenings, cement, silica flour and water to form “green”
building blocks. Slag for the blocks is obtained from the
mills of U. S. Steel Company. The quantities of raw materials
used daily at the plant are as follows:
Material
Fine slag
560,000 lbs.
Coarse slag
140,000 lbs.
Limestone screenings
140,000 lbs.
Cement
50,400 lbs.
Silica flour
50,400 lbs.
Water
60,000 gallons
Once formed, the blocks are then cured for about 4 1/2
hours in one of four heated autoclaves (high pressure steam curing
vessel) by application of 150 psig steam to the blocks. In the
final 30 to 40 minutes of the curing process, steam and other
gasses, including hydrogen sulfide, are released. U. S. Steel
analysis of the steel mill slag and Petitioner’s blocks showed
a sulfur content of 0.76 in the slag and 0.70 in the cured
blocks, This means that 0.06 sulfur is lost during the curing
process.
In 1970 Illinois Brick determined that the volume of odor
producing gasses could be reduced if the steam were condensed
and not released to the atmosphere. A condensing system installed
in November 1971 worked satisfactorily until sections of the
condenser corroded and began to leak. Petitioner kept the system
in operation until late 1973 or early 1974 by replacing corroded
parts but eventually had to abandon the whole condenser system
because of excessive corrosion.
A new system utilizing a stainless steel air—cooled condenser
was ordered on October 26, 1973. Piping changes were made to route
all liquid and gaseous wastes to~a single retention basin.
16~562
—3—
Delivery of the air cooled condenser was expected by July 1,
1974.
In the meantime, in December 1973, Illinois Brick applied
tothe Agency for an operating permit. This was denied because
the Agency believed Petitioner’s discharges were causing air
pollution. A per~nitfor installation of the new condenser system
was granted by the Agency in August 1974.
The $45,000 project was delayed because the condenser was
not actually delivered until September 17, 1974. On October 15,
1974 the new condenser was given its first trial CR. 19)
.
With-
in a few days Petitioner began to experience minor problems
which appeared to be corrected by calibration of certain asso-
ciated equipment. Problems continued, however, and Petitioner
sought to correct the problems by making certain modifications
tc the piping in an effort to supply a greater quantity of
steam to the condenser.
When these modifications failed to solve the operational
problems, the condenser was partially dismantled and found to
he clogged with scale. Several of the clogged pipes had rup-
tured during freezing weather. Further modifications were made
to provide a high pressure water backflush system to clear the
scale and to provide a steam line to heat the unit between blow-
downs and on weekends during freezing weather.
As the system now stands, blow-down steam and gasses are
piped to the air condenser where the steam is condensed to water.
Some of the gasses are dissolved in the condensed water prior to
discharge of the water to a sump inside the plant. Although the
sump is open, doors and windows of the room in which the sump is
located are not normally open. From the sump, the water flows to
a vented retention basin where treatment chemicals are added
prior to discharge of the water to a sanitary sewer system. A
bypass on the system has been used several times in the past to
vent steam and gasses to the atmosphere during periods of mal-
function.
Petitioner’s Vice President in charge of concrete operations,
Clyde Stewart, testified that he did not know if any odorous
emissions were released through the retention basin vent (R. 31).
Complaints from nearby residents about the hydrogen sulfide odor
are handled by Stewart. He testified that he had received
complaints from the residents over a period of years, and the
Company reacted to these complaints with its efforts, beginning
in 1970. Stewart has not detected any hydrogen sulfide odors
near the plant since the modified air condenser was placed in
operation (R. 41).
16—563
Nine citizens,mostly nearby residents, testified about the
impact of the “rotten egg odor~’, Clares
Danek,
Village Manager
for Westchester, testified that, accordinq to Village records,
the odors had been prevalent in Westchester since 1961 (R. 51).
Witnesses testified to having been awakened at night CR.
58,
60, 79) and to having suffered physical effects such as labored
breathing, allergic reactions, headaches and tearing of eyes
(a. 57, 63, 73 and 79), Kenneth Kirkham, a school principal,
testified that the odor interferes with study at his school
rhich is located about one block from the plant.
Only one of the citizen
witnesses
noticed the odor in the
last several weeks. Suzanne Lag testified that she has noticed
toe odor recently while jogging in the morning hours but the
odor did not seem as heavy as before CR. 74). Several citizens
expressed concern over how long Illinois Brick would take to
control the odorous emissions if the new air condenser system
failed.
Illinois Erich believes it has solved its odor discharge
problem. Another test program will be conducted on April 15,
1975, Nearby residents will be consulted when the modified
system is evaluated
(~.
33)
Early in this proceeding Petitioner advised that several
alternative systems were being reviewed in the event the air
condenser system failed to adequately control the odors, These
secondary systems included: a) burning Qf the waste gasses in
the plant’s boilers, b) a scrubbing system, c) treatment with
activated carbon, d) reformulation of the block mixture, e) the
addition of chemicals to eliminate the odors.
Stewart testified that Illinois Brick had tried neutralizing
agents and chemical masking agents without success CR, 14).
Reformulation of the block mixture has also been ruled out be-
cause of economics (R. 40). Without specifying which system
would be used, Stewart testified that the secondary system would
take from 30 to 60 days for design and the ordering of materials,
and from three to six months for delivery.
No Agency witness testified at the public hearing. Although
the Agency believes Illinois Brick has made a good faith effort
to control its emissions, the Agency recommends denial of this
variance.
The Agency is reluctant to recommend variance from Section
9(a)
of the Act because
it
would “preclude
aggrieved citizens
from bringing an enforcement action”.
Uncertainty about the
condenser operation is cited as the reason why variance from
Section 9(b) of the Act and Rule 103(b) (2) is not recommended by
the Agency.
16—564
—5—
According to the Agency, hydrogen sulfide is both an
irritant and asphyxiant. At concentrations from 20 ppm to 150
ppm it can cause irritation of the eye. Based on the number
and Content of complaints the Agency has received, the Agency
believes that nearby residents have endured unreasonable inter-
ference with life and property for a number of years. Inter-
views with these citizens did not reveal any objections to
allowing Illinois Brick until January 1, 1975 to implement its
control program.
The record does not show what action Illinois Brick took
to alleviate the odorous emissions prior to 1970, but does
indicate that Illinois Brick has been responsive to the complaints
since 1970. Illinois Brick believes that its steam condensing
system is now capable of eliminating the hydrogen sulfide
emissions and that it will not be necessary to implement any
further control procedures.
The April 15, 1975 tests and citizen comments should be
a good indicator of the effectiveness of this system. Citizen
testimony leads us to believe that most of the odors have
already been eliminated, The record does not show that any of
Petitioner’s neighbors object to the granting of this variance,
The first ambient sampling tests reveal considerably less
than the 20 ppm to 150 ppm which has been cited by the Agency as
capable of causing eye irritations. It is apparent from citizen
testimony, however, that Petitioner1s emissions have been of
sufficient concentrations in the past to interfere with the
enjoyment of life and property, For this reason, the Agency
will be keenly interested in reviewing the data and results of
the April 15, 1975 test, especially that part of the test in-
volving citizen comments.
It is the opinion of the Board that Illinois Brick has met
the requirements for the grant of variance. Variance will be
conditioned upon submission of the April 15, 1975 test data
and a report of citizen comments about the effectiveness of the
control program.
This Opinion constitutes the findings of fact and con-
clusions of law of the Illinois Pollution Control Board.
0BIDE
R
It is the Order of the Pollution Control Board that Illinois
Brick Company be granted variance from Section 9(a) and Section
9(b) of the Environmental Protection Act and Rule 103(b) (2) of
16 —565
—6—
the Air Pollution Control Regulations from June 25, 1974
until May 1, 1975. This variance is subject to the
following conditions:
1.
As soon as data from the April 15, 1975
air quality test is available to Illinois Brick,
the Petitioner shall submit copies to the Agency.
2. Illinois Brick shall submit a report to the
Agency discussing all citizen comments obtained
during and immediately after the April 15, 1975
test project. This report shall be submitted
along with the air ciuality test data.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order were adopted
on the __________day of May, 1975 by a vote of ~
Christan L. Moffe t/jçlLerk
Illinois Pollution ~~ñtrol Board
16 —566