ILLINOIS

POLLUTION

CONTROL

BOARD

October

3,

1972

ENVIRONMENTAL

PROTECTION

AGENCY

v.

)

PCB

72-54

UNION

CARBIDE

CORPORATION

OPINION

&

ORDER

OF

THE

BOARD

(by Mr.

Dumelle)

This

is

an

enforcement

action

filed

February

9,

1972

involving

the

allegation

that

Union

Carbide

Corporation

(Carbide),

in the

operation

of its

Films

-

Packaging

Division

in Bedford

Park,

caused

the

discharge

of

gaseous

emissions,

including

hydrogen

sulfide

and

carbon

disulfide,

thereby

causing

air

pollution

as

defined

in Section

3(b)

of

the

Environmental

Protec-

tion

Act

(Act)

in violation

of

Section

9(a) of

said

Act.

The

plant

produces

sausage

casings

and

other

products

composed

of

cellulose

and

empios

1, 300 people.

Hearings

were

first

held

on

May

23

and 24,

1972.

Another

hearing

was

held on

July

18..

lf)72

at which

time

the

parties

presented

a

Stipulation

and

Proposal

for

Settlement

to

the

public.

The hearing

officer1s

report

indicates

that

about

fifty

persons

were

in

attendance.

At

the

conclusion

of

the hearing

the representative

of

a local

citizens

organization

thanked

the parties

for

the

agreement.

The

hearing

was

concluded

with

applause.

No

transcript

was

made

of

the

July

18

hearing.

Carbide

purchased

the

1)1 ant

in

1956,

The

area

immediately

to the

north,

northwest

and

northeast

of

the

plant

is

predominantly

residential.

The

plant

operates

around

the

clock

every

day

of

the year.

The

emission

volume

from

the

two

140—foot

stacks

is

192, 000

cubic feet

per

minute.

The

most

recent

stacks

tests

(during

1971)

showed

the

concentrations

of hydrogen

sulfide

and

carbon

disulfide

to be

25

and

35 parts

per

million

respectively

at

73 percent

of

capacity.

Until

1964,

the

Bedford

Park

plant,

as

was

the practice

in the

industry,

vented

the

gaseous

emissions

of

each

process

line

thru

roof

vents

in the

immediate

vicinity

of each

line.

At

the

present

time

these

individual

emission

sources

are

brought

together

in a

central

ventilating

system

and

discharged

through

the

two aforementioned

140—foot

stacks.

This

system

was

completed

in early

1971

at

a

cost

of

$450,000.

---

—9—

In

the

fall

of

1970

Carbide

began

to

investigate

and

study

its

problem

on

its

own.

In

the

spring

of

1971

they hired

an independent

consultant.

In

July,

1971

the

consultant

rendered

a report

in

which

it

recommended

an

experimental

unit

to

test

the

carbon

adsorption

process

to remove

the

H7S

and

CS9.

The

unit

was

installed

by

January

1,

1972

but

proved

inadequate.

The

complaint

in

this

case

was

filed

in

February,

1972.

As

stated

above,

hearings

were

held

in

May

and

July,

1972.

In

June

and

July,

1972,

Carbide

conducted

experiments

with

an

alkaline

scrubbing

unit

for

applications

of

the

‘Cataban

chemical

reagent

process

and

also

caustic

scrubbing

using

different

caustic

concentrations.

Carbide

estimates

that

it

has

spent

S200,

000

since

the fall

of

1970

on research

and

development

of

treatment

alternatives,

Carbides

agreed

program

is

as

follows:

PHASE

I

A.

Subject

to

the

qualifications

herein

stated,

on or

before

June

1,

1973,

Carbide

agrees

to have

installed

and

commence

operation

of

a

scrubbing

unit

for

H2S

removal

capable

of utilizing

the

Cataban

process

which

will

have

capacity

for

a

gas

stream

of at least

60, 000

cubic feet

per

minute.

Car-

bide

agrees

to file

applications

for permits

for

this

unit

with

the

ERA

and all

other

governmental

pollution

control

agencies

asserting

jurisdiction

not

later

than

August

24,

1972,

assuming

the

Board

has

approved

this

stipulation

on

or

before

August

18.

If

such

approval

should

occur

after

August

18,

1972,

application

shall

be

made

not

later

than

on the

fourth

business

day

following

the

date

of

such

approval.

Carbide

agrees

to

diligently

pursue

such

applica-

tions.

In the

event

the

Board

does

not

approve

this

stipulation

until

after

August

18,

1982,

or

in the

event

all

necessary

permits

are

not

issued

within

a period

of

two

weeks

following

the

submission

of a

complete

permit

appiica~

tion,

or

both,

the time

for performance

under

this

Paragraph

A

shall

he

extended

for

a period

of time

identical

in length

to the

amount

of

each

such

delay.

A

complete

permit

application

is understood

to

include

information

required

by

law

to the

satisfaction

of

the

EPA.

B.

Carbide

agrees

to

construct

the

scrubbing

unit

so

that

it

shall

also

he

capable

of operating

as

an

alkaline

scrubber

utilizing

a

caustic

soLution

~of

a

concentration

of its

choice) or

some

other

alkaline

mediu:m

of

choice

and

that

it

shall

he

~n

option

of

Carbide

in

its

sole

discretiun

u~~n~nv:nce

operations

with

such

unit

utilizing

an

alkaline

scrubbing

process

oi

rather

than

the

Catahan

process,

Provided,

that

such

operation

sistent

with

the

provisions

of

the

EPA

permit

heretofore

mentionuL.

5

558

---

-3-

PHASE

U

C.

(1)

If the

Cataban

process

alone or

if the

Cataban

and another

process

is

utilized,

following the

start

up of the Phase

I unit,

there shall

be

a period

of no

more

than

four months

(“test period”)

in

which the per-

formance of the unit shall be

observed,

analyzed

and evaluated by responsible

engineering personnel of both parties.

A test period is

necessary because

this

will be the first

commercial

size

operation of its

kind using the

Cataban process

and

its

successful operation

cannot be assured.

(2)

If Carbide elects to use

an

alkaline

scrubbing process

at the

start

up

of the Phase

I unit,

it shall

have

a period of up to

3

months

in which

the performance of the unit shall

be observed,

analyzed

and

evaluated by

responsible

engineering

personnel of both parties.

Thereafter

it

shall

proceed

with Option

2

of Phase

II as

described

in

paragraph F(2) below.

D.

If the Cataban process is utilized,

at such time

during

said test

period as the EPA

and

the

Vice President-Engineering

of Carbid’s

Films-

Packaging

Division

shall

agree that the performance of the

unit

indicates

that it has

a practical

capability of removing

no less

than

75 percent of

the H9S

in

that

part of Carbide’s stream

which it has

the

capacity to

handle,

then

Carbide shall,

within

the time

specified

in

Paragraph

C below,

con-

struct either Option

1

or Option

2 of Phase

II as defined

In Paragraph F

below.

If

Carbide

contends

that

the operation is

not

practical,

ft will

supply

EPA

a

detailed written

statement of its

reasons,

specifying the

actual

or

projected costs

or test results

upon

which it relies.

E.

Should

the

Cataban process

not meet

the criteria

stated in

Paragraph

D above,

by the end oti the “test period,”

if

and only If,

at

that time there is

a

lawful,

technologically

and

economically reasonable

means available

for

disposal of the liquid

effluent

from

alkaline

scrubber

equipment of the capacity able to handle the entire

gas

stream

of Carbide,

Carbide

agrees to install

Option

2

of

Phase U

as described

in

Paragraph F(2)

herebelow.

It Is specifically

agreed that any disposal method

which

requires

discharge

Into the Metropolitan Sanftary

District

and which is found un-

acceptable to the District as

evidenced in

a

writing

by its

General Superin-

tendent shall

not be

deemed

available

for purposes

F.

Definition of

Phase

U:

(I)

Option

1:

Construction of scrubbing equipmeqt

capable of

utilizing the

Cataban process with

sufficient

capacity to remove

1125

from

the

remainder of the

entire gas

stream of Carbide,

the

entire system to

operate

at a

removal efficiency

not less

than the level

as determined

in

Paragraph D hereinabove.

5—569

---

-4-

(2)

Option

2:

Construction

of

alkaline

scrubbing

equipment,

not

designed

to

utilize

the

Cataban

process,

with

sufficient

capacity

to remove

H9S

from

the

remainder

of

the

entire

gas

stream

of Carbide,

all

alkaline

s6~rubbingequipment

to

operate

at

a removal

efficiency

of

not

less

than

90 percent.

(3)

In the

event

that

the

conditions

herein

specified

giving

rise

to

either

Option

1

or

Option

2

do

not

occur

in the time

herein

specified,

Carbide

agrees

to use

its

best

efforts

to find,

install,

and operate

an acceptable

treatment

method.

Such

efforts

shall

be

described

to

the

EPA

in

writing

no less

than

30

days

from

the

end of the test

period

and the progress

achieved

upon

the performance

of

such

efforts

shall

be reported

in writing

monthly

to

the

EPA by

Carbide.

G.

From the

date of

agreement

under

Paragraph

D,

or

Carbides

written

determination

within that

period

to adopt

Option

2

if it

chooses,

Carbide

shall,

within

three

weeks,

apply

for permits

for

the

Phase

Ii

equipment

from

the

EPA and all

other

governmental

pollution

control

agencies

asserting

jurisdiction.

Carbide

agrees

to

complete

all

Phase

II

construction

within

nine

months

from

the

date

all

necessary

permits

are

issued.

We

are troubled

by the

lack

of

assurance

of

an

adequate

program

for

removal

of

the

H25 nuisance.

Dr.

Howard

E,

Hesketh,

in

a letter

and

calculations

dated

August

24,

1972

points

out

that

his

assumed

nuisance

level

of

H7S

(0. 007 ppm)

will

be

just

met

at

75

H25

control

and atawind

speed

of

uT

mph

and neutral

stability.

Since

the

average

wind

speed

in the

Chicago

area

is

about

11

mph this

means

that

approximately

50

of the

time

or

more

wind

speeds

will

be

below

11

mph

and

ground

evel

H2S

consequently

above

0.

007 ppm.

Since

only half

of

the

wind

directions

will

cause

an

impingement

upon

residences

we

can

say that

the

nuisance

will

continue

to

exist

about

25

of

the time

(half

of a half),

Furthermore

nothing

is

being

done

about

carbon

disulfide

and in

fact

Dr.

Hesketh

points

out

that

this

pollutant

will

help

mask

the

H2S.

The

Agency

is

still

free,

of

course,

to

bring

an action

on

CS2

if

it

computes

dangerous

ground

level

concentrations

and

we

urge

that

they look

closely

at this

pollutant.

But

we

feel

that

75

control

of

112S

is better

than

no

control

as

is

the

present

situation.

And if the

Cataban

process

is

not

used~the

alternate

alkaline

scrubber

can

remove

up

to

90

of the

H2S.

Tt

is

further

stipulated

that

Carbide

will

post

a performance

bond

of

~1, 500. 000

and will

pay a

civil

penalty

not

to

exceed

$10,

000,

---

-5-

We

find

the

settlement

to

be

acceptable.

The

May transcripts

show

severe

air

pollution

and

annoyance

to

residents

but there

appears

to

have been

steady

progress

made

by

Carbide

during

the

past

two

years.

According

to

the

settlement

agreement,

there

will

be

even more

achievement

within

the

new

few

~‘ears.

We

also

understand

that

since

the

Cataban

process

is

somewhat

new,

the

progress

of

its

application

may proceed

less

quickly

than

desirable.

We

do,

however,

expect that

all

efforts

be

made

to

move

forward

as

rapidly

as

possible

under

the

circumstances.

Furthermore,

the

citizens

who

attended

the hearing

and who are

the

ones

most

directly

affected

by

the problem

seemed

to be pleased

with the

settlement.

This

opinion

constitutes

the

BoardTs

findings

of

facts

and

conclusions

of

law.

OR DER

i.

The

Stipulation

and

Proposal

for

Settlement

are

accepted.

2.

Carbide

shall

post

a performance

bond

of

$1, 500,

000 according

to

the

terms

of

said

Settlement.

3.

Carbide

shall

pay

to the

State

of Illinois

by

October

27,

1972

the

sum

of

$10,

000

as

a

civil

penalty.

Penalty

payment

by

certified

check

or

money

order

payable

to the

State

of

Illinois

shall

be made

to:

Fiscal

Services

i)ivision,

Illinois

Environmental

Protection

Agency,

2200

Churchill

Drive,

Springlield,

illinois

62706,

4,

This

order

does

not

protect

Carbide

from

action

by

the

Agency

if

the

program

still

results

in

air

pollution.

1,

Christan

L.

Moflett,

Clerk

of

the

Illinois

Pollution

Control

Board,

hereby

certify

the

above

Opinion

and Order

were

adopted

on

the ~

~

day of

October,

1 ~)72

by

a

vote

of

/)

:h~’~d~~

Christah

L.

Moffett,

~1~k

Illinois

Pollution

Control

Board

5

—

561