ILLINOIS POLLUTION CONTROL BOARD
December 6, 1973
STAUFFER CHEMICAL COMPANY,
Petitioner,
v.
)
PCB 73—340
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
Richard H. Sanders, Attorney for Stauffer Chemical Company
Lee Campbell, Assistant Attorney General for the EPA
OPINION AND ORDER OF THI BOARD (by Mr. Henss)
Stauffer Chemical Company operates a plant in Aurora,
Illinois for the production of pressure sensitive vinyl films.
During the process, an organic solvent adhesive is applied to
a polyethylene clad kraft paper. The treated paper is then
passed through a forced air drying tunnel where excess solvent
is evaporated by heated air. The air from the tunnel is vented
to the atmosphere at the rate of about 25 lbs. solvent per hour.
Approximately 60 of the solvent which is discharged to the
a tmosphere is toluene (a photochemically reactive material) and
the remaining 40 is ethyl acetate.
As part of its application for operating permit, submitted
in the Fall of 1972, Stauffer told the Agency that it would
achieve compliance with applicable regulations by installing a
natural gas fired incinerator to incinerate the organic vapors.
The Agency then granted Petitioner an operating permit for
that portion of the system responsible for the emissions.
While negotiating the purchase of an incinerator, Petitioner
made a routine check with its natural gas supplier, Northern
Illinois Gas Company. Petitioner was advised by the Gas Company
that it could not increase its consumption of natural gas to the
level required to operate the incinerator. Petitioner filed a
request for additional delivery of natural gas but was placed on
a waiting list with no indication of when such delivery could be
obtained.
10
—
241
—2—
Because of this setback, Petitioner could not carry through
with the Compliance Plan and Project Completion Schedule it had
submitted to the Agency. Petitioner notified the Agency and
the Board of this development on August 14, 1973 and requested a
variance from Rules 103(b) (2), 103(b) (6) (E)
,
104 and 205(f) of
the Air Pollution Control Regulations.
In its Amended Petition filed September 1973, Petitioner
stated that it had investigated several techniques for removing
organic vapors. Three of the most promising techniques are
carbon adsorption, condensation and incineration. Each of these
methods would require increased energy from natural gas or #2
fuel oil, increased supplies of which are allegedly not available.
Petitioner estimated that only 10 or 15 of the plant could
operate without using the dryer which is involved. Closing down
the dryer would, according to Petitioner, place an arbitrary and
unreasonable hardship on Petitioner, its 40 employees, the local
economy and dependent industries.
Petitioner stated that a variance would not affect the
general public since the closest, residence was more than 1/2
block from the plant, and wind conditions and the general nature
of the atmosphere would not be conducive to the formation of
photochemical smog. No formal complaints from citizens or
governmental agencies concerning odors had been received by
Petitioner.
EPA surveillance personnel have reported that no odor problem
existed outside the plant. The Agency recommends granting the
variance subject to certain conditions. Petitioner has agreed to
comply with each condition called for in the Agency Recommendation.
Under the variance, Stauffer will be required to investigate
the possibility of diverting some of the present natural gas allot-
ment for the purpose of incinerating the organic vapors, and then
recirculating the combustion gasses back through the tunnel dryer.
It seems that Petitioner has possible alternative methods for
achieving compliance. Petitioner has not told the Board exactly how
it proposes to achieve compliance but makes this statement: “Based
on statements from its fuel suppliers and from its knowledge of the
proprietary processes involved, its dryer will be brought into
compliance with Rule 205(f) by December 31, 1974”.
We will allow a one year variance. A denial, we think could
restrict plant operations and cause economic and personal loss
far outweighing environmental damage which might result from the
discharge of the vapors.
The variance means
that
Stauffer will be discharging about
17 lbs~per hour of organic vapors over that allowed by Regulation,
a situation which will be corrected in 1974.
10 —
242
—3—
ORDER
It is the order of the Pollution Control Board that:
l~ Stauffer Chemical Company is granted a variance
until December 6, 1974 from Rules 103(b) (2),
103(b) (6) (B), 104 and 205(f) of the Air Pollution
Control Regulations in order to operate its gas-
fired, forced air dryer pending installation of
control equipment or alteration of process
sufficient to achieve compliance with the above
cited Rules.
2) Stauffer Chemical Company shall explore the
possibility of using existing natural gas allot-
ments to incinerate the tunnel dryer organic
vapor emissions and recirculating part of the
combustion gasses back to the tunnel dryer.
3) Within 4 months of the date of this Order, Petitioner
shall notify the Variance Section of the Agency of
its new control program and Project Completion
Schedule.
4) Petitioner shall submit quarterly progress reports
to the Agency1s Variance Section, 2200 Churchill
Road, Springfield, Illinois 62706. Such reports
shall commence one month after the date of this
Order.
5) Petitioner shall apply for all necessary construction
and operating permits.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certi the above Opinion and Order was adopted
this ~4’~ day of
________
1973 by a vote of
~(
to 0