ILLINOIS POLLUTION CONTROL BOARD
    August 8,
    1974
    LUDLOW CORPORATION,
    OPIN.ION AND ORDER OF THE BOARD (by
    Mr. Seaman):
    On May 24, 1974, Ludlow Corporation filed its Petition
    For
    Variance, seeking therein variance from the provisions
    of Rule 205(f)
    of
    the Illinois Pollution Control Board
    Regulations, Chapter 2, Part
    Ii for
    the period between June
    1,
    1974 and September
    1,
    1974.
    Petitioner operates a plant in Chic~gowhich manufactures
    pressure sensitized paper.
    During the manufacturing process
    hydrocarbons
    are
    released and subsequently discharged to the atmosphere through two stacks.
    Hydrocarbon emissions are 36 ibs,/hour from one stack and 27.lbs./hour from
    the other stack.
    Rule 205(f)
    limits Petitioner to
    a
    total
    of
    8 lbs./hour of
    hydrocarbon emissions after December
    31,
    1973.
    In
    1971 Petitioner installed two fume incinerators at its
    facility after receiving assurance from the manufacturer that the units would
    achieve the 95 per cent hydrocarbon reduction required by the City of
    Chicago.
    However, the two incinerators functioned improperly and caused
    the emission
    of smoke from the stacks and ~thepresence of
    011
    fumes
    in the
    plant.
    Repeated attempts to
    5O1VC
    the problems failed,
    Petititoner then
    retained Arthur
    0.
    Little and Company to recommend a solution.
    After extensive investigation, Petitioner elected to replace
    the existing incinerators ~withtwo new Air Preheater incinerators at
    a cost
    of $209,400.
    The Air Preheater Company has guaranteed 95 per cent removal
    of hydrocarbon emissions,
    which will
    reduce Petitioner~semission to 1.8
    lbs,/hour from the first stack and 1.35 lbs./hour from thE second stack.
    The total
    plant emission of 3.15 lbs./hour will
    then be well within our
    standard
    Air Preheater estimated that it would take six months for
    fabrication, delivery, and installation of
    the equipment and training of
    Petitioner~semployees.
    The actual operating date was projected to be
    near the end of May, 1974.
    Based upon this information we granted Petitioner~s
    request for a variance from Rule 205(f)
    until June 1,
    1974.
    (PCB 73~444).
    13~321
    In
    the instant cause, Petitioner is seeking additional
    time (until September 1,
    1974)
    to complete the installation of the
    two Air Preheater Incinerators.
    Petitioner states that it has encountered
    unforseeable delays
    in obtaining the necessary permits from the Building
    Department of the City of Chicago for the installation of the subject
    equipment.
    The delays were allegedly caused when the Department required
    the submission of revised structural
    and electrical
    plans.
    These building permits were obtained on May 16, 1974, and
    the demolition which
    is
    a prerequisite to installation of the equipment
    has now begun.
    The incinerators
    themselves, the major component of the
    equipment, have been purchased and are being stored
    in
    a warehouse in
    Chicago.
    Both the construction site at Petitioner~splant and the
    incinerators are available for inspection as evidence of Petitioner~sgood
    faith effort to bring itself into compliance with state regulations.
    Petitioner~srevised constructin schedule now calls for completion of
    installation and~testingby the end of August.
    An Agency construction
    permit was granted on February 13,
    1974.
    Petitioner was granted an Agency
    operating permit, #031600 AUI,
    on March 20,
    1973 to run through March 15,
    1978..
    Petitioner~sfacility is located
    in
    a heavily~populated
    residential
    area.
    Petitioner~sneighbors have
    indicated that they are
    sometimes bothered by
    odors from Petitioner~splant, but they are not
    opposed to the granting of the variance.
    The Agency is of the opinion that Petitioner has shown good
    faith
    in
    its
    attempts to comply with Rule 205ff)
    and that the revised
    compliance schedule
    is reasonable,
    We agree.
    This Opinion constitutes the findings of fact and conclusions
    of law of the Board.
    IT IS THE ORDER of the Pollution Control
    Board that Ludlow
    Corporation
    be granted
    a variance from Rule 205(f)
    of the Illinois Air
    Pollution Control
    Regulations for the period between June
    1, 1974 and
    September
    1,
    1974 for the purpose of installing two Air Preheater incinerators
    at
    its Chicago manufacturing plant.
    This variance is subject to the
    following conditions:
    1.
    Petitioner shall
    notify the Agency
    immediately if any
    deviation from the compliance timetable occurs.
    2.
    Petitioner shall
    notify the Agency upon completion
    of
    its control program.
    3.
    Petitioner shall conduct
    a stack test after installation
    of the subject incinerators and shall notify the Agency at least five days
    in advance of
    the test so that Agency personnel may be present to observe
    test procedures and operating conditions.
    The notification should be sent to:
    13
    —
    322
    Environmental
    Protection Agency
    Illinois Naval Armory
    East Randolph and the Lake
    Chicago,
    Illinois
    60602
    I,
    Christan
    L. Moffett, Clerk of~the Illinois Pollution Control
    Board, certify that the above ORinion and Order was adopted on this
    ~
    ______
    day ~
    1974 by
    a vote of
    4~)
    13
    —
    323

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