ILLINOIS POLLUTION CONTROL BOARD

September 6, 1973

REILLY TAP.

AND CHEMICAL CORPORAT ION,

Petitioner,

vs.

)

PCB 73—218

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

Max K.

Naegler, Attorney for Petitioner

Thomas Cengel, Assistant Attorney General for the EPA

OPINION AND ORDER OF

TIlE BOARD (by Mr. 

flenss)

Reilly Tar and Chemical Corporation requests a 3 month

variance from Rule 206(c) of the Air Pollution Control Regulations

which on December 31, 1973 will limit the emission of carbon

monoxide.

Petitioner has operated its coal tar distillation plant in

Granite City, Madison County, Illinois since 1932. It purchases

crude high temperature coal tar, a “waste’~ product of steel mills,

and distills it to produce various grades of coal tar pitch and

creosote. The crude coal tar is stored in tanks and transferred

to stills for the distillation process. Petitioner utilizes four

10,000 gallon stills and two 6,000 gallon stills to process about

520,000 lbs. of crude coal tar daily. The plant operates 5 days

per

week

and employs about 54 persons.

After each still is filled with crude, heat is applied, and

this distills off creosote oil vapor and various noncondensable

gasses. The distilled gas and vapors are passed through a condenser

to lic~uify the creosote, which is collected in receivinn pans.

The noncondensable gasses, includinq carbon monoxid~, exit to the

atmosphere throuch vents at the receivinq pan~

An independent test laboratory analyzed these gasses by gas

chromotography in 1972. The test revealed that Petitioner~s total

carbon monoxide release was 1.40 lbs,/hr, Using an air flow rate

of 7 cfm, the Agency estimated the 1.40 lhs./hr. emission rate was

equivalent to about 9,000 ppm. Rule 206(c) allows Petitioner to

emit a maximum of 200 ppm (adjusted to 50 excess air) after

December 31, 1973.

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Petitioner’s first three applications for operating permit

were denied by the Agency for “lack of information, lack of data,

and lack of compliance schedules’t. A fourth application was denied

on May 2, 1973 and Reilly Tar then filed the variance petition.

At this time, there are no control devices on the distillation

unit capable of reducing carbon monoxide emissions to acceptable

levels. Petitioner has submitted a Compliance Plan and Project

Completion Schedule for the installation of a low volume waste gas

burner, type D.F.S. Fumeabator. This device will burn the various

gasses which at the present time are emitted to the atmosphere, so

that the final emission will be essentially water vapor and carbon

dioxide. The installation of this control equipment will be on the

following schedule:

Part A 

July 1973 

Evaluation of the Fumeabator on

Petitioner’s new enamel plant (also located

in Granite City).

Part B 

October 1973 

Petitioner to apply for a construction

permit for the Fumeabator on its coal tar

refinery.

Part C 

November 1973 

Petitioner will enter into a

binding agreement to purchase the equipment.

Part D 

—

January 1974 

—

Petitioner expects delivery of the

equipment.

Part E 

March 1974 

Petitioner expects equipment to be

installed and operational and expects to

demonstrate compliance with Rule 206(c) of

the Air Pollution Control Regulations.

The record shows that a Fumeahator has been installed at

Petitioner’s new enamel plant which is located adjacent to the coal

tar refinery. William Justin, Petitioner’s Director of Environmental

Control, testified that the Fumeabator system at the enamel plant was

received with safety devices normally considered as standard components

of such equipment. However, because of the highly flammable nature of

the Reilly gasses, the Reilly engineering staff decided to devise an

additional protection system to insure that fire could not flash back

through the piping network and cause an explosion. The additional

safety devices include steam—jacketed flame arrestor, steam ejector

to move the gas stream and automatic valves. The presence of naphtha—

lene in the waste gas of the Reilly plant presented a special problem

in the design of the system. Naphthalene solidifies at normal ambient

temperatures and could accumulate at certain critical points in the

piping network thereby plugging the safety devices. These and other

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198

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operational difficulties have delayed start-up of the enamel plant,

but Petitioner advises that the delay probably would not affect the

Project Completion Schedule as submitted. Petitioner indicates

that the installed cost for the incinerator system at the distillation

plant would be about $20,000.

Although Reilly has similar onerations at other locations,

its Granite City facility was selected as the site for installation

and testing of the incinerator control system. Petitioner plans to

use this method of pollution control not only at Granite City but

at its other factories if the method proves satisfactory.

A company official testified that production capacity of

$40,000 to $70,000 per week would be lost if the plant were forced

to cease operations during the first three months of 1974. The

record indicates that Petitioner could install the incinerator

equipment at the distillation plant and have the equipment in

operation by the December 31, 1973 deadline. A back up incinerator

device has been located and is available in the event the first system

is found unsatisfactory.

Initially, the Agency recommended that we deny the variance.

This recommendation was changed after Petitioner demonstrated to

the Agency that, because of the potentially explosive nature of the

waste gas stream, complete testing was necessary to insure the safety

of Reilly’s employees and to protect the plant from fire. In its

Amended Recommendation, the EPA recommends granting the variance.

Petitioner’s carbon monoxide emissions, while above the allow-

able rate, are not alarmingly high. Testimony indicates that

Petitioner’s hourly carbon monoxide emissions are equivalent to

carbon monoxide emissions from 12 automobiles driving 10 miles.

We believe the primary concern in this case must be for the

safety of 

the

employees. Petitioner is testing the new incinerator

now. A back up device will 

available in the event the Fumeabator

system proves unsatisfactory,

The Project

Completion Schedule

indicates

that 

Petitioner will

achieve compliance within three months

of the deadline. We do not find this delay unreasonable in view of

the dangers inherent in installation of an untested system. We

shall grant the variance subject to conditions which will assure

installation of the control equipment.

ORDER

It is the order of the Board that:

1. Reilly Tar and Chemical Corporation is granted variance

from Rule 206(c) of the Air Pollution Control Regu-

lations at its Granite City tar distillation plant

until March 31, 1974.

9

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2. Variance is conditioned upon the submission to the

Agency of quarterly reports detailing progress or

lack of progress in installation of the Fumeabator

or other control equipment at the Granite City tar

distillation plant. Such reports shall commence

on October 1, 1973.

3. Petitioner shall, by October 1, 1973,. post a bond in

the amount of $10,000 in a form acceptable to the

Environmental Protection Agency, quaranteeing the

installation and operation of suitable carbon monoxide

control equipment by March 31, 1974. The bond shall

be mailed to: Fiscal ServicesDivision, Illinois EPA,

2200 Churchill Road, Springfield, Illinois 62706.

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

Board, he~ebycertify the above Opinion and Order was adopted

this 

(, ~

day of 

~Vr4k.w.6.4.&.~

1973 by a vote of 4/ to ~

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