ILLINOIS

POLLUTION

CONTROL

BOARD

February 27, 1975

KOPPERS

COMPANY,

INC.

)

)

Petitioner,

)

vs.

)

PCB

74—325

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

OPINION AND

ORDER

0? TEE BOARD tby

Lit. D~mafl~)

t

Koppers Company filed its Amended Petition for Variance

seeking

a

one

year

extension

of

variances

previously

granted

by

this Board in PCB 73-365 and

PCB

74-63.

In those cases

Koppers was granted relief from Rules 103 (a) (5) (A) (con-

struction permits) and 206(c)

(carbon monoxide) of the Air

Pollution Control Regulations for its current operations and

a new addition to the facility.

In October 1974 the Board of Directors of Koppers Inc.

directed that a second addition be constructed at

its

Stickney,

Illinois site.

Construction of this second addition is

scheduled

to begin in May 1975 and

be

completed

within

about

12

months.

Variance

is

also

requested

for

the

second

addition.

Petitioner operates a manufacturing facility at Stickney,

Illinois for the production of phthalic anhydride and tar

products.

This facility is located on flat terrain in a

highly industrialized area surrounded by other industrial and

coamnercial facilities.

The nearest residence is approximately

3000’ to the northeast at which point there is a highly

populated

area.

tn the manufacturing operation phthalic anhydride is

produced

by

preheating

and

vaporizing

art

ortho-xylene

feedstock

and then passing the reactant gasses through a catalyst filled

tubular

reactor.

Carbon

monoxide

and

other

gasses

and

solids

are

produced

during

this

reaction.

After

scrubbing

with

water

to

remove

gaseous

hydrocarbons

and

solids

the

gasses

are

discharged

through

a

100’

stack.

The

existing

plant

exhausts

gases

containing

about

4000

ppm

of

carbon

monoxide

(2,382

lbs./hr.).

15—589

---

—2—

Carbon

monoxide

emissions

for

each

of

the

two

new

additions

have

been

estimated

at

794

lbs./hr.

When

the

new

additions

have

been

completed

the

combined

total

emissions

of

carbon

monoxide

will

be

3970

lbs.

per

hour.

Rule

206(c)

limits

the

emission of carlSc$n monoxide to no greater than 200 ppm

corrected

to 50

excess air.

Emissions from the phthalic anhydride process are

characterized

by

low concentrations of carbon monoxide

(0

•

3—0

•

4)

and

a

temperature

of

about

100° F.

Control

of

such

emissions

using

thermal

or

catalytic

incineration

is

hazardous

and

requires

high

fuel

consumption.

Three

techniques

using

thermal

or

catalytic

incineration

are

available

to

Petitioner

but

these

are

inherently

dangerous

or

require

high

fuel

consumption.

First

process:

Heat

exchange

and

incineration

methods

have

proved

dangerous

in

other

phthalic

anhydride

plants

because

explosions

and

fires

occur

in

the

heat

exchanger

when

phthalic

anhydride

dust

accumulates

in

sufficient

quantities.

Fuel

requirements

are

more

than

106

million

BTU per

hour.

This

would

mean

an

annual

consumption

of

924

million

cubic

feet

of

natural

gas

or

6.6

million

gallons

of

fuel

oil

and

is

enough

energy to supply the annual heating requirements of 6,000 to

9,000 homes.

Second process:

The wet scrubbing of emissions prior to

incineration alleviates the dust

problem.

Petitioner

now

utilizes

tuo

wet

scrubber

systems

operating

in

parallel

to

control

emissions.

Scrubbing

liquor

from

the

two

systems

is

incinerated

in

a

conunon

incinerator.

Fuel

requirements

are

high.

Third

process:

The

addition

of

a catalyst

bed

to

the in-

cinerator system will reduce fuel consumption.

Since the catalyst

would

have

to

be

protected

from

catalytic

poisoning,

natural

gas

is

the

only

feasible

fuel.

Natural

gas

is

not

currently

avail-

able

in

the

quantity

Petitioner

requires

and

may

not

be

available

for

some

time

in

the

future.

Petitioner

has

been

involved

in

testing

an

alternative

method

of

controlling

carbon

monoxide

emissions

for

some

time.

According

to

Petitioner,

tests

using

cold

catalytic

oxidation

have

shown that

this

method

has

the

best

potential

of

any

tested

for bringing the carbon monoxide emissions into compliance.

This

method

involves

the

catalytic

oxidation

of

carbon

monoxide

by

metal

salts

at

a

temperature

of

about

100° F.

The

energy

saving

features

of

the

cold

catalytic

oxidation

method

are

particularly

attractive.

15—590

---

—3—

The importance of Petitioner~sinvestigations in basic

air

pollution control research were noted by the Board in its Opinion

in

PCB

73-365.

If

the cold catalytic oxidation method proves

successful, similar industries will undoubtedly benefit directly

from the program Koppers

is pursuing.

ifl

the event this method

does not prove successful, Hoppers will need

to

install an in-

cineration system.

The company has designed and engineered

a

suitable incineration system for both the existing plant and the

new addition.

Condition

3 of the Order in PCB 73-365 requires

Koppers to complete construction permit applications for a thermal

incinerator within the time frame of the variance.

Hoppers states

that the incinerator system has been engineered

to a point short

of equipment purchase.

The Agency reports,

in its Amended Recom-

mendation,

that the application

for

a construction permit for the

thermal incinerator system has been received.

Based upon recent pilot plant studies Hoppers is now com-

mitted to develop~sorneform of catalytic technology

to control the

carbon monoxide emissions.

Petitioner?s Exhibit J and paragraphs

11,

12 and 13 of the Agency~sRecommendation describing these pilot

plant studies have been afforded non—disclosure status pursuant

to Board Procedural Rule 107

(See:

Board Order, January 23, 1975).

Thermal oxidation has now been rejected as

a control method.

This decision to use catalytic oxidation had been made several

months

before

the

agreed

decision

date

according

to

Hoppers.

However, Hoppers requires additional time for more pilot plant

evaluation

in

order

to

determine which of several catalytic

processes will be used.

Depending on test results Koppers expects

to make its decision

on

the

catalytic

process

between

March

30

and

May

30,

1975.

This

means

that

Koppers

will

fall

behind

several

months in its compliance schedule.

Meanwhile,

a larger pilot

plant will be built and operated, and the design work on

a com-

mercial installation will proceed.

Hoppers asserts that denial of this variance will cause

arbitrary and unreasonable hardship due to

a production cost

increase of about 20

to cover the capital and operating costs

for thermal incineration.

Competitive plants representing

85

of the total

U.

S. phthalic anhydride capacity would not incur

such

increases

since

they

operate

in

states

having

different

pollution

regulations.

A

20

increase

in

production

costs

would

place

Hoppers

at

a

disadvantage

with

these

competitive

plants

particularly

since

more

suitable

technology

can

be

developed

in

a

reasonable

period

of

time.

Such

hardship

would

be

aggravated

if Hoppers were required to use thermal oxidation to control

emissions

from

the

second

addition

in

light of its expenditures

and progress on catalytic technology.

Hoppers claims that the

combined carbon monoxide emissions from the facility and other

sources will have no significant effect on ambient air quality

and will not be harmful.

Hoppers claims that it has met all

---

—4—

provisions of the prior variances.

Air

quality

monitoring

data

has

beel)

supplied

in

order

that

the

Board

may

evaluate

the

effect

of

Kopper’s

emissions

upon

the

ambient

air.

This

data

shows

that

the

air

quality

in

the

area

is

within

the

National

Ambient

Air

Quality

Standard

for

carbon

monoxide.

The

data

are

fran

1973.

Petitioner’

s

Exhibit

F

shows

that

the

catalytic

oxidation

program will

be

completed

by

about

September

1976.

Petitioner

states

that

construction

of

the

second

addition

will

not

sub-

stantially alter the compliance schedule submitted for the

existing

plant

and

the

addition

now

under

construction.

The

Agency

recommends

the

grant

of

variance

from

Rule

206 (c)

until

December

6,

1975

for

both

the

existing

facility

and

the

first addition and from Rules 103(a) (5)

(A)

and

206(c)

until

December 6, 1975 for the second addition, subject to certain

conditions.

Since

a

construction

permit

for

the

first

addition

has

been

granted,

the

Agency

recommends

that

the

request

for

variance

from

Rule

103(a)

(5) (A)

for

the

first

addition

be

dis-

missed

as

moot.

For

the

record

the

Board

notes

receipt

of

two

formal

objections

to

the

granting

of

this

variance.

The

first

objection

states that

damage

was done to the finish of automobiles parked

on

a

nearby

lot.

The

signers

of

this

letter

allege

that

the

damage

was

caused

by

emissions

from

the

Koppers

facility.

As

proof,

they

show

that

Koppers

reimbursed

them

for

damage

done

on

one

of

the

three

‘~ates.

The

objectors

worty

not

only

about

their automobiles but also about possible health effects.

The

second

objection

comes

from

a

citizen

who

indicates

that

Koppers

increases

its

emissions

on

weekends

when

it

knows

that

air

pollution

inspectors

are

not

on

duty.

Emissions

allegedly

force

his

family

to

remain

indoors

with

windows

closed

on hot,

humid

summer

days.

After

walks

with

his

grandson

he

returns

home

with

“red

swollen

eyes

because

of

the

toxic

poison

fumes”

from

the

Koppers

facility.

We

are

in

sympathy

with

those

who

suffer

from

environmental

pollution

and

we wish

to

maintain

an

open

forum

to

hear

such

citizen

complaints.

However,

the

current

variance

request

does

not

apply

to

any

component

of

the

Kopper’s

exhaust

stream

other

than

carbon

monoxide.

The

record

is

inadequate

to

establish

the

cause

of

the

paint

damage

and

the

burning

of

the

eyes.

We

cannot

conclude from the record that such damage was caused by carbon

monoxide.

The Agency should investigate these citizen

complaints

and

take

appropriate

action

if

it

can

establish

the

type

of

contaminant

involved,

indentify

the

source

and

if

the

Agency

believes

the

law

has

been

15— 592

---

—5—

From our review of the entire record,

the Board finds that

Koppers is moving diligently

to solve its emission problem.

These efforts have involved considerable research into new

technology which appears at last to be on the road to providing

a solution to a complex problem.

The Agency notes that

Petitioner has shown good faith in its actions during the

term of the prior variance.

We grant the variance as detailed in the Order below.

This Opinion constitutes the Board’s findings of fact

and conclusions of law.

Mr. Henss dissents.

ORDER

It is the Order of the Pollution Control Board that Koppers

Company,

Inc. be granted variance from Rule 206(c) of the Air

Pollution Control Regulations from December

6,

1974 to and

including December

6,

1975 for its existing facility and first

addition and from Rules 103(a) (5) (A)

and 206(c)

of the Air

Pollution Control Regulations to and including December

6,

1975

for the second addition at its Stickney, Illinois plant.

This variance is subject to the following conditions:

1.

Koppers Company shall apply to the Environmental

Protection Agency for all necessary construction and operating

permits no later than May 30,

1975.

2.

Koppers Company shall submit bi-monthly progress

reports to the Agency.

Said progress reports shall commence

on March

30, 1975 and shall provide details of progress

towards completion of the catalytic oxidation program.

3.

Koppers Company shall diligently pursue completion

of its research involving catalytic oxidation and shall report

to the Agency in its May 30, 1975 progress report its decision

on type of catalytic process finally selected.

4.

Koppers Company shall cause the bond required in

cases PCB 73-365 and continued in PCB 74-63 to apply to

the variance in this matter.

Said bond shall guarantee

performance with this Order.

The request that variance be granted from Rule 103(a) (5) (A)

for the first addition at the Stickney Plant is hereby denied

as moot.

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, herçby certify the above Opinion and Order were

adopted on the

~

‘

day of February, 1975 by a vote of

3.. 1

QAuL~m

~Idt

Christan L. Mof~,

Clerk

15