ILLINOIS POLLUTION CONTROL BOARD

January 3, 1974

GENERAL TIRE AND RUBBER COMPANY   

)

(MOUNT VERNON TIRE PLANT),

Petitioner,

v.

)

PCB 73—371

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Don Musick and William Henrick, Attorneys for Petitioner

Fred Hopper, Assistant Attorney General for the EPA

OPINION AND ORDER OF THE BOARD (by Mr. Henss)

General Tire and Rubber Company is in the final phase of

construction of a $40 million radial tire manufacturing plant

in Mt. Vernon, Illinois. Plant heat and process steam require-

ments for the plant are to be supplied by two 70 million Btu/hr.

Murray-Trane boilers.

On July 23, 1973, Petitioner applied to the Environmental

Protection Agency for a construction permit for the oil fired

boilers. At that time, Petitioner specified that *6 fuel oil

with a sulfur content of 0.74 would b~used for fuel. Satisfied

that Petitioner’s emissions would he in compliance with all Rules

and Regulations, the Agency granted the construction permit on

September 12, 1973.

After making application for the construction permit but

before the Agency approval, Petitioner discovered that it was

unable to secure any firm commitment for the low sulfur fuel

oil. General Tire then filed a request for variance from Rule 204

of the Illinois Air Pollution Control Regulations in order to

temporarily allow the burning of #6 fuel oil containing 3 maximum

sulfur content (2.5 typical).

In the Petition for Variance, Petitioner stated that the plant,

designed to produce 2,000 radial tires per day, was scheduled for

startup in

mid-November 

1973. Attached to the Petition were copies

of letters from 9 major oil

companies which substantiate

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Petitioner’s claim that extensive efforts to secure low sulfur

fuel oil have been fruitless. Adding to Petitionerts fuel

problem is the present fuel allotment program which is based on

1972 fuel usage.

Petitioner was not in operation during 1972

and thus 

did not establish a base allotment on which to secure

fuel for 1973.

General Tire maintains that the requirement for

variance

will exist until the Company can

1) secure adequate commitment

for supplies of #2 fuel oil, #5 low sulfur fuel oil, or #6 low

sulfur fuel oil, or 2) select, design, engineer and install a

flue gas desulfurization unit on the plant’s single stack.

General

Tire has already initiated efforts to

control sulfur oxide and

estimates that a flue gas

desulfurization control program will

cost from $300,000 to $1 million.

If the variance is allowed, General Tire agrees to

1) con-

tinue to seek low sulfur fuel oil, 2) seek a long—term contract

for low sulfur fuel oil, or, 3) in the event such fuel oil contracts

are not secured by August 1, 1974, install sulfur oxide removal

equipment by May 30, 1975.

The Agency states that Petitioner has made a serious attempt

at compliance and should be granted the variance subject to certain

conditions. An Agency representative visited the plant site on

September 4, 1973 where he discussed the proposed variance with

several area residents. They made no objection to the granting

of the variance.

A public hearing on the variance request was held on November 20,

1973. Petitioner’s plant engineer, John Cappellin, testified that

the plant is now scheduled for startup in mid-December 1973. During

the design phase of the plant, General Tire had originally considered

natural gas, #2 fuel oil and *6 fuel oil for the plant boilers.

Natural gas was quickly eliminated from further consideration when

it was learned that supplies of this fuel were not available for

commercial establishments in the Mt. Vernon area.

After filing the variance petition, General Tire was able to

secure 550,000 gallons of #6 fuel oil from a local supp1ier~ The

fuel oil, thought to have a sulfur content of 0.96, was tested

and found to have a sulfur content of 1.07. About 35,000 gallons of

#2 fuel oil was obtained during this time. Petitioner plans to

start its boilers on #2 fuel oil (low sulfur) and then switch to

the #6 fuel oil when sufficient heat has been applied to the more

viscous #6 oil to allow a smooth flow to the boilers (R. 17).

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Once the plant achieves maximum capacity, approximately 5

million gallons of fuel oil will be required annually (R. 10).

A commitment for an additional 1 million gallons from the local

supplier has been obtained (R. 15) and should last through the

startup phase or until early fall of 1974. Sulfur content of

the additional fuel was not revealed in the record.

Petitioner has already obtained preliminary cost figures

for its proposed flue gas desulfurization system. William Lang,

Manager of Chemical Engineering and Chairman of the Corporate

Environmental Control Committee, testified that the Chemical

Construction Corporation roughly estimated $1.1 million as the

construction cost of the proposed system (R. 36). The system

wou~Erequire about 24 months for construction.

General Tire has

investigated the feasibility of constructing

additional facilities at Mt. Vernon to remove the sulfur from high

sulfur fuel oil prior to burning and is now investigating the

possibility of gaining proprietary access to low sulfur fuel oil

by investing money in an oil refinery (R. 44).

Robert J. Schreiher, Jr., an Agency engineer, testified that

Petitioner’s sulfur dioxide emissions would be about 3,388 lbs.

per day if the plant were operating in compliance with the Regu-

lations. He estimated that the burning of 1.07 sulfur fuel oil

would add an additional 372 lbs. of sulfur dioxide per day over

the allowable rate. Schreiber testified that there were no large

(5,000 lbs./day) sulfur dioxide emission sources in the Mt. Vernon

area presently. Schreiber also testified that it was his opinion

that the sulfur dioxide emissions from the plant would not pose

any serious health hazard for the area (R. 54). If fuel with a

higher sulfur content is ultimately used, of course the sulfur

dioxide emissions would be higher.

We believe Petitioner has proven’its need for a variance.

The attempt to secure adequate supplies of low sulfur fuel oil

was exhaustive and fruitless. Time will be needed to obtain a

low sulfur fuel supply or install flue gas desulfurization equipment.

By using present fuel oil supplies Petitioner will add about 10

more sulfur dioxide to the Mt. Vernon atmosphere than the Company

would emit if it were operating in compliance, but the Agency does

not believe this quantity of additional emissions will create any

serious health hazards in the area. Petitioner has indicated that

it is willing to comply with the conditions requested by the Agency.

General Tire has invested $40 million in an area which needs

the stimulus of industry. Ultimately Petitioner will employ 450

to 1,000 persons. The Company has expended a great deal of effort

in its attempt to comply with the Regulations. It has committed

itself to the installation of sulfur dioxide control equipment in

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the event it is unable to secure contracts for adequate supplies

of low sulfur fuel oil. From the record we believe that the

Company will continue with its efforts until compliance is achieved.

The variance will be granted subject to those conditions suggested

by the Agency.

ORDER

It is the Order of the Pollution Control Board that:

General Tire and Rubber Company be granted a variance

from Rule 204 of the Illinois Air Pollution Control

Regulations for its Mt. Vernon tire plant until

December 20, 1974. The variance is subject to the

following conditions:

a) Petitioner shall continue good faith negotiations

for securing an adequate supply of low sulfur fuel

oil and immediately use such oil upon its avail-

ability regardless of any other date set forth in

this order.

b) Petitioner shall submit quarterly progress reports

to the Environmental Protection Agency.

Said

progress reports shall commence on January 15, 1974

and shall provide details on the characteristics

and usage of fuel oil, progress in choosing a

control option, and negotiations for long term

contracts guaranteeing an adequate supply of low

sulfur fuel oil.

c) Petitioner shall reapply to the Board for any

extension of this variance by September 20, 1974

if compliance with Rule 204 of the Air Pollution

Control Regulations has not been achieved by that

date.

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

Board, hereby certify the above Opinion and Order was adopted

this 

.3~

day ~

1974 by a vote of ~ to

O_.

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