ILLINOIS POLLUTION CONTROL BOARD
    April
    25,
    1974
    )
    MONSANTO COMPANY
    )
    )
    PCB 74-57
    )
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    )
    )
    OPINION AND ORDER OF THE BOARD
    (by Mr. Dumelle):
    Monsanto filed a Petition for Variance from the Air Pollution
    Regulations
    on February 4,
    1974.
    The Agency filed
    a Recommendation
    to grant
    the variance subject
    to certain conditions
    on March
    13,
    1974.
    No hearing was held.
    Monsanto operates an industrial
    chemical plant
    located in Sauget,
    St. Clair County,
    Illinois, where
    it produces
    4-nitrodiphenylamine
    (4-NDPA) which
    is
    a raw material
    used
    in the manufacture of rubber chemicals.
    Monsanto requests
    a variance until April
    30,
    1974 from Rule
    206(c)
    of the Air Pollution
    Regulations which pertains to carbon monoxide emissions.
    The
    compliance date of Rule
    206(c) was December 31,
    1973.
    Monsanto
    states that it will have installed equipment and achieve compliance
    with Rule 206(c)
    by April
    30,
    1974.
    Monsanto previously requested
    a variance from Rule
    206(g) (2)
    of the Air Regulations for this same discharge of
    carbon monoxide.
    The
    Board
    denied
    without
    prejudice
    this
    previous
    request
    on
    1)ecembcr
    20,
    1973
    in
    Monsanto
    Company
    v.
    EPA,
    PCI3
    73-413,
    because
    Monsanto
    failed
    to provide
    the Board with the quantity and environmental
    impact of its carbon monoxide emission.
    Monsanto states that it has “agreed to follow the interpretation
    applied
    by
    the
    Agency
    and
    to
    treat
    emissions
    from
    (their)
    process
    as
    if
    they
    were
    being
    emitted
    by petroleum or petrochemical processes
    covered
    by
    Rule
    206(c)’t
    (Monsanto’s
    Variance Petition, page
    3).
    Monsanto has provided the Board with the information necessary to
    properly grant
    a variance.
    Monsanto’s emission of carbon monoxide
    averages 176 pounds per hour
    arid
    is discharged from an 88-foot
    stack.
    Monsanto’s
    plant
    is
    located
    in
    aa
    industrial
    area,
    with
    the
    nearest resident approximately 500 feet from the 4-NPDA facility.
    Monsanto
    calculated
    that
    the
    ambient
    air
    quality
    concentration
    at
    a
    point
    on
    the
    ground,
    five
    hundred
    feet
    down
    wind
    from
    the
    12
    —
    166
    -2-
    stack, would be approximately
    1 ppm (hourly average).
    The
    Agency agrees with this
    calculation.
    The national and Illinois
    one-hour standard
    is
    35 ppm and the maximum eight hour concen-
    tration
    is
    9 ppm, not to be exceeded more than once per year.
    Both
    Monsanto
    and
    the
    Agency
    state
    there
    have
    been
    no
    complaints
    regarding
    the
    facility
    and
    Monsanto’s
    plant
    is
    located
    in
    a
    highly
    industrial
    area
    vith
    no
    other
    known
    major
    stationary
    sources
    of
    CO
    nearby.
    However,
    CO
    is
    odorless
    and
    not
    detectable
    without
    instruments.
    Monsanto
    is
    disposing
    of
    the
    waste
    carbon
    monoxide
    by
    incinerating
    it
    in
    a
    gas-fired
    boiler.
    Orders
    were
    placed
    in
    jUflO,
    1073 for
    a flame arrestor to prevent flashbacks
    from the
    boilers
    into
    the
    4-NPI)A
    process.
    The
    Agency
    approved
    operating
    and
    construction
    permits
    in
    July,
    1973.
    Monsanto
    began
    construc-
    tion
    of
    the
    project
    in
    September,
    1974,
    Due
    to
    equipment
    delays
    Monsanto
    was
    unable
    to
    install
    the
    equipment
    necessary
    to complete
    the
    project
    in
    order
    to
    come
    into
    compliance
    with
    Rule
    206
    by
    December
    31,
    1973.
    Because
    Monsanto
    has
    proceeded
    in
    good
    faith
    to
    achieve
    compli
    axice
    with
    Rule
    206 Ic)
    of
    the
    Air
    Pollution
    Regulations
    and
    the
    minimal
    degree
    of
    environmental
    degradation,
    the
    Board
    has
    decided
    to
    grant
    the
    requested
    variance
    subject
    to
    the
    conditions
    recommended
    by
    the
    Agency.
    This
    Opinion
    constitutes
    the
    Board’s
    findings
    of facts and
    conclusions
    of
    law.
    ORDER
    The
    Board
    hereby
    grants
    Monsanto
    Company
    a
    variance from
    Rule
    206(c)
    until
    April
    30,
    1974
    subject
    to
    the
    following conditions:
    1.
    Monsanto
    shall
    report to the Agency upon completion of the
    incinerator;
    2~
    Monsanto
    shall
    stack
    test
    the
    incinerator
    to
    insure
    compliance
    with
    Rule
    206(c).
    Such
    tests
    shall
    be
    performed
    with
    Agency
    representatives
    notified
    in
    advance
    and
    within
    30
    days
    after
    April
    30,
    1974,
    A
    coav
    of
    the
    stack
    test
    report
    shall
    be
    forwarded
    to
    the
    Agency
    within
    30
    days
    of
    the
    completion
    of
    the
    test.
    IT
    IS
    SO
    ORDERED.
    I, Christan L. Moffert,
    Clerk of the Illinois Pollution Control
    Board,
    hereby
    certify
    the
    above
    Opinion
    and
    Order were adopted on
    the
    ~~1
    day
    of
    April,
    1974
    by
    a
    vote
    of
    ~
    ~‘~oTTett,~
    Illinois
    Pollution
    Cou~ol
    Board

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