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ra
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icr
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-,
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i
tv
c~trul
-~
ra
c an~y 1
~.
ap~J~
c ~~uc
nr~the o~h~
apr~ic~
~a~aet c~aL~nga t~
~.
kick
a
rgan~ s~_~1t~
r l3~3
t
oner
ea l9~ 8
l~cn~~
t ard the Aper~v
c ~ir~s
Lath
38 ~
3
682 ga~ons~of
ha so so
t
was photo
o enicall
rca~ti
ifte~an~
cc ~or~
F
tb o~
ad LcatJr y
tbs ort ~s o en drith and tne
~
r cooled
ir
a tunro
Lath
of the above descriced steI~resuths an cLgan
c eT~ssaor~
A stack test conducted ~r February l9~3show that
line
#1 was
enitting J5O~68 lbs
organics/~ourand that iin~#2 ~as emittinu
168~85lbs. organics/hour
The Agency calculated
eirissiona fran
lane #1
at 157
8 lbs~/hr~and line
#2 at 385 lbs~/hr
The Agency
states that the stack test or
thne #~was probably conducted at a
time wnen the organic corcentrat~onswere different from the average
13—593
concentration figures used by the Agency
in
its calculations.
Rule 205(f)
allows Uniroyal to
emit
8 lbs. organics/hour.
Neither
of
the two coating lines is presently equipped
with control equipment.
Uniroyal claims that until December
3,
1973 it believed that the organic emissions were in compliance
with Rule 205(f).
In a letter dated December 3,
1973 Uniroyal~s
consultant, Polytechnic Inc., was advised 1~ythe Agency that
Uniroyal~sexemption from Rule 205(f) was doubtful.
After
meeting with Agency representatives in January 1974 Uniroyal
concluded that it had been mistaken
in its
position and corrective
action would have to be taken.
Petitioner has been engaged in developing
a water based
spray system
as
a means of reducing the level of organic emissions.
in May 1974 Uniroyal conducted a trial run in which full production
equipment was used with a water based spray system which had
already been successfully used on polyvinyl chloride
(PVC)
plastic
materials.
Although the two plastics are dissimilar, Uniroyal
reports that the testing on ABS plastic was successful to the
extent that the company now believes that its use of organic
solvents can be reduced 62
by September 1974.
During the period from September 1974 to December 31, 1974
Uniroyal will evaluate two options for control of the remaining
38
organics—-total conversion
to water based coatings or installation
and operation of
a carbon adsorption system.
If research continues
to
be successful,
total conversion to water based coatings could
be achieved by March 31,
1975.
If the research is unsuccessful
the carbon adsorption system would be ordered and placed into
operation by September 29,
1975.
Petitioner has already ordered permanent production scale
spray equipment at a cost of about $10,000.
Final testing was
expected by mid--September 1974.
in February 1974 Uniroyal
completed testing of various samples of its emissions using
a
carbon adsorption system.
As
a result of these tests Petitioner
concluded that the carbon adsorption system would be an appropriate
solution to the problem,
Other tests to determine composition
and volumetric flow rates have also been completed.
Denial of this variance would,
according to Petitioner, have
several undesirable effects.
Uniroyal states that it would be
forced to accelerate the design and ordering of the carbon adsorption
system.
Design is
to begin by October
7,
1974 under the present
plan.
It
is
claimed that acceleration would result in waste of
those developmental costs already incurred, and any anticipated
success in achieving
a water based coating would be superfluous since
Petitioner would be
committed under
an enforceable timetable to a
13~594
—3—
“noncompatible~carbon adsorption system.
Cost for the carbon
system at present emission rates would be $333,990, but a
carbon system to remove the organics after the initial
62
organic reduction would cost only $130,040.
Continuing, Uniroyal states that success in developing the
water base spray system without the variance would result in
the “needlessly incurred engineering and design cost’1
for the
carbon adsorption system.
In addition, Petitioner would be
unable to quickly incorporate a successful water based spray
into its design without seeking approval from the Board for a
revision of the then existing compliance plan and timetable.
The Agency recommends granting this variance but only until
May
30, 1975 subject to conditions of bond,
use of water based
coatings to the extent possible, monthly progress reports, sub-
mission of
a final compliance plan by January 30,
1975, restrictions
on organic emissions after September 30,
1974 and the acquisition
of all necessary construction and operating permits.
The Agency
has not received any complaints about this operation and no
objections were received to the granting of this variance.
The Agency questions the authority of the Board to grant a
variance beyond May 30, 1975 from Air Pollution Regulations which
are part of the implementation plan approved by the U.
S.
EPA.
In support of this contention,
the Agency cites four recent cases
involving the Natural Resources Defense Council Inc. and the U.
S.
Environmental Protection Agency.
It is not necessary to face that particular issue in deciding
this case since we have determined that the variance should
terminate even sooner than the date recommended by the Agency.
Uniroyal is optimistic that it can complete development of
a
water based coating which can be substituted for 100
of the
organic solvents.
We believe Uniroyal should be given this oppor-
tunity and shall grant the variance until March
31,
1975.
Several reasons can be given for granting this variance.
The
Board encourages in-process changes that result in compliance.
Compliance through this method enables companies to avoid unneeded
and costly control equipment and this results in
a saving of
natural resources
(i.e. steel and other
construction
materials,
fuel
to produce the adsorbing medium, fuel to regenerate
this
medium, power to run the equipment,
etc.)
and the freeing of
control equipment for those industries which actually need the
equipment.
Improvements in technology relating to water based coatings
could be made available to other manufacturers in similar circum-
stances, and this would result in even greater savings of resources
as well as
a cleaner environment.
13—595
Finally, Uniroyal requests that the Board grant
this variance
without imposing any but the most minimal bond or other
s,ecurity
to assure compliance.
Petitioner asserts that, slnce failure to
now be in compliance resulted solely from a misunderstanding
and not from a willful delay or avoidance,
there is no reason to
believe Petitioner will not make all due progress in accordance
with its intended timetable.
The Agency does not contest Uniroyal!s
contention but nevertheless we feel that more than a minimal
threat of penalty, should exist in this matter and we will therefore
require a $10,000 bond.
It is the ,Order of the Pollution Control Board that Uniroyal
Inc.
be granted a variance from Rule 205(f)
of the Air Pollution
Control Regulations for its Chicago plant until March
31,
1975.
I.
Petitioner shall apply for and obtain all necessary
permits for the installation and operation of new equipment.
2,
Petitioner shall, by October 15, 1974 post a bond in
the amount of $10,000 in a form acceptable
to the
Environmental Protection Agency, such bond to be for~
feited in the event Petitioner fails to adhere in the
most practicable manner to the timetable for achieving
an approximate 62
reduction in the leveI of organic
solvent usage or fails to attempt the elimination of
the remaining 38
organic solvent usage either through
replacement with water based coatings or installation
and operation of a carbon adsorption system.
The bond
shall be mailed to Fiscal Services Division, Illinois
EPA,
2200 Churchill Road,
Springfield, Illinois 62706.
3.
Petitioner shall utilize as much water based coatings
as possible in its process during the time of
this
variance.
4.
Petitioner shall immediately notify the Agency if any
deviation from the compliance timetable occurs or is
required.
5.
Petitioher shall submit monthly progress reports to
the Environmental Protection Agency.
Said progress
reports shall commence on October
1, 1974 and shall
state the total amount of solvents used,
the nature
and amount of nonexempt solvents used,
the nature and
amount of exempt solvents used,
the nature and amount
of nonexempt solvents purchased (indicating the
supplier), the nature and amount of solvents purchased
(indicating~the supplier)
,
the nature and amount of
13—5
water
based
solvents
purchased
(indicating
the
supplier)
,
and
the
nature
and
amount
of
solvents
in
inventory
at
the
beginning
of
each
month.
6.
Petitioner
shall
not
allow
the
discharge
of
photo~
chemically
reactive
materials
into
the
atmosphere
of
more
than
60
lbs./hr.
from
coating
line
#1
and
of
more
than
146,3
lbs./hr.
from
coating
line
#2
after
September
30,
1974
and
during
the
term
of
this
variance.
7.
Petitioner
shall
submit
a
final
compliance
plan
to
the
Environmental
Protection
Agency
by
January
30,
1975.
I, Christan
L.
Moffett,
Clerk
of
the
Illinois
Pollution
Control
Board, hereby certify thq ab~oveOpinion and Order was adopted
this
~
day of
974 by a vote of~~to~
13—597