ILLINOIS POLLUTION CONTROL BOARD
    December 6, 1973
    )
    STAUFFER CHEMICAL COMPANY
    )
    )
    )
    v.
    )
    PCB 73-340
    )
    )
    ENVIRONMENTAL PROTECTION AGENCY
    )
    SUPPLEMENTAL STATEMENT (by
    Mr.
    Dumelle)
    While I did vote to grant this variance I feel we must not
    lose sight of the two purposes For having an emission limit for
    organic materials (Rule 205 of the Air Pollution Regulations)
    As stated in the Opinion of the Board in the matter of R71-23
    Emission Standards:
    Rule 205: Organic Material Emission Standards serves both
    to achieve and maintain compliance with the federal air
    quality standard for photochemical oxidants (0.08 ppm
    for one hour not more than once per year.
    . .)
    and to prevent
    local nuisances.
    Thus there are controls both in terms of photochemical smog and
    nuisances such as odor. The Federal oxidant standard was adopted
    as an Illinois standard on May 3, 1973 (R. 72-7).
    In considering the impact of granting this variance on the
    surrounding citizens, therefore, the photochemical smog potential
    as well as the nuisance potential must be considered. The record
    is exceedingly sparse on both points stating only that no odor
    complaints have been received by the petitioner (the Agency
    surveillance personnel also reported the absence of an odor problem)
    and a conclusory statement that atmospheric conditions are not con-
    clusive to photochemical smog formation. The emissions of
    organics are approximately 25 lb/hr,
    of which
    60 is toluene,
    a photochemically
    reactive material (Affidavit of Stanley F. Ciesla),
    so
    that the emission of toluene alone is
    18
    lb/hr.
    It is
    generally agreed that no direct adverse effects
    on
    humans of gaseous hydrocarbons at ambient air levels have been
    demonstrated, but that photochemical oxidants (which do have
    10
    —
    245
    -2-
    adverse e:Ffects on humans) are direct functions of gaseous hydro-
    carbon concentrations. In fact, under certain conditions, a
    three hour concentration of hydrocarbons of 0.3 ppm as C has resulted
    in up to 0.1
    ppm concentrations of oxidants 2 to
    4 hours later;
    concentrations which exceed
    the Federal standard and the new
    Illinois standard.
    The problem then becomes
    one of calculating the dispersion
    of the toluene emitted into
    the atmosphere and relating that
    to ambient levels of nitrogen dioxide (NO7)
    and sunlight intensity;
    the other
    two
    ingredients
    necessary for pBotochemical smog production.
    Only then can the
    Board accurately assess the impact in terms of
    potential photochemical
    smog formation. The background level of
    oxidants should also be given so
    that it is known how much “clean
    air” remains before the standard is violated.
    We should require
    all of this information in future variations
    from this Rule 205.
    It is the petitioner’s burden
    to provide this information but
    o:E course Agency monitoring would be of help.
    C,
    TTh~b D. Dumelle
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Supplemental Statement was submitted
    on the
    /9’~#~
    day of December, 1973.
    Illinois
    Pollution
    rol Board
    10
    —
    246

    Back to top