ILLINOIS POLLUTION CONTROL BOARD
January 17, 1974
LUDLOW CORPORATION,
Petitioner,
v.
)
PCB 73—444
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
John D. Donlevy, Attorney for Petitioner
Lee A. Campbell, Assistant Attorney General for the EPA
OPINION AND ORDER OF THE BOARD (By Mr. Henss)
Ludlow Corporation requests variance from Rule 205(f) of
the Illinois Air Pollution Control Regulations until June 1,
1974, pending installation of replacement incinerators. Petitioner
operates a plant in Chicago which manufactures pressure sensitized
paper. During the manufacturing process hydrocarbons are
released and subsequently are discharged to the atmosphere through
two stacks. Hydrocarbon emissions are 36 lbs. per hour from one
stack and 27 lbs. per 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 the
facility after receiving assurance from the manufacturer that
the units would achieve the 95 per cent hydrocarbon reduction
required by the Chicago Environmental Control Board. However,
the two incinerators functioned improperly and caused the
emission of smoke from the stacks and the presence of oil fumes
in the plant. Repeated attempts to solve the problems failed.
Petitioner then retained Arthur D. Little and Company to
recommend a solution.
After extensive investigation, petitioner elected to replace
the existing incinerators with two new Air Preheater incinerators
10—693
—2--
at a cost of $209,400. The Air Preheater Company has
guaranteed 95 per cent removal of hydrocarbon emissions,
which will reduce petitioner’s emission to 1.8 lbs. per hour
from the first stack and 1.35 lbs. per hour from the second
stack. The total plant emission of 3.15 lbs./hr. 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 the Ludlow employees. The actual operating
date will be near the end of May, 1974.
Petitioner stated that if it did not obtain a variance
it might be forced to shut down its operation for three
months. Cessation of operation for a three month period would
constitute an unreasonable hardship. We question whether it
would be necessary to completely close petitioner’s operation
if variance is denied, but we do agree with Ludlow that injury
to the public will be minimal during this brief period of
noncompliance.
EPA employees questioned petitioner’s neighbors and
found some indication that odors from the plant were bothersome
at times. None of petitioner’s neighbors opposed the variance.
The Agency recommended granting the variance subject to certain
conditions.
It is our opinion that Petitioner has made a good faith
effort to control its emissions and has shown a need for the
variance. Petitioner has already ordered two new incinerators
which should reduce the hydrocarbon emissions to an acceptable
level. We will grant this variance subject to those conditions
recommended by the Agency.
ORDER
It is the order of the Board that Ludlow Corporation be
granted a variance from Rule 205(f) of the Illinois Air
Pollution Control Regulations until June 1, 1974 for the purpose
of installing two Air Preheater incinerators at its Chicago
manufacturing plant. This variance is subject to the following
conditions:
A. Petitioner shall notify the Environmental Protection
Agency upon completion of its control program.
—3—
B. Petitioner shall obtain all required permits from
the Environmental
Protection
Agency.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify
that the above order was adopted on
the
/
7~1
day
of
January,
1974 by a vote of
~
Christan
~~z2~aL
L. Moffett, C
k
Illinois Pollution Cotit bl Board