~onire
    1
    3t~
    ~zc~
    -~
    acL
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    ~
    a
    pl~. ~
    ra
    s
    an
    c~tc
    ~c
    icr
    a
    -,
    the
    o
    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

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