ILLINOIS POLLUTION CONTROL BOARD
January 3, 1975
UNIROYAL, INC.,
Petitioner,
v.
)
PCB 74—371
ENVIRONMENTAL PROTECTION AGENCY,
Respondent.
Opinion and Order of the Board (by Dr. Odell)
On October 15, 1974, Uniroyal, Inc. sought a variance
from Rule 205(f) of the Air Pollution Regulations (Chapter
Two) until
May
31, 1975,
Petitioner had previously filed a Petition for Variance
from Rule 205(f) on June 14, 1974. The Pollution Control Board
(Board) granted a variance in that case until March 31, 1975,
subject to a number of conditions. See Uniroyal, Inc. v.
Environrnen~~Protec~o~Aency,PCB 74—222 (September 12, 1974).
~~ii~’Thner now requests that the earlier variance be withdrawn
and that the instant petition be substituted in its place.
Petitioner~s Chicago plant at 2638 North Pulaski Road
is one of a number of plants in Uniroyhl~sPlastic Products
Division. The principal business activity at the Chicago plant
is the fabrication of plastic items, principally for use as
interior components of automobiles, This petition pertains to
a final processing step wherein the fabricated item is spray-
coated with a selected pigment that is applied in a solution
consisting of various organic solvents, Spray coating is
carried out in two separate spray-coating lines, Spray-Coating
Lines Nos. 1 and 2. The step of spray coating is carried out
in a spray booth, following which the sprayed item is oven-
dried and then cooled in an air—cooled tunnel. All of these
steps result in the vaporization of organic solvents to some
degrees
Petitioner states that it uses 205 lbs/hr of spray-
coating materials on Line No. I and 500 lbs/hr on Line No. 2.
Hydrocarbon emissions are presently uncontrolled. In February,
1973, stack samplings were taken on Spray-Coating Lines Nos. 1
and 2. Total hydrocarbon emission rates (methane basis) were
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measured using the flame ionization technique, The following
emission rates were obtained~
Total hydrocarbon
lbs/hr
Spray booth
130.23
Oven
13,99
144, 22
Spray-Coating Line No. 2
Tot
~
lbs/hr
Spray booth A
90,10
Spray booth B
76.86
Oven
1.89
Cooling tunnel
6.46
175.31
The allowable emissions per source are 8
lbs/hr
of
hydrocarbons under Rule 205(f) of Chapter Two.
Petitioner
~s
present time schedule to achieve compliance
with Rule 205(f) is as follows:
May 14, 1974
-
Petitioner’s management committed funds
sufficient to insure compliance with Rule 205(f).
September 9, 1974
-
Request made to Peoples Gas, Light
and Coke Company for an initial fuel allocation of natural gas
(3600 CFH) for catalytic incinerator to be used
on Spray Booth
A on Line No.
1
and Spray Booth B on Line No. 2,
September 11, 1974
-
Final decision that full implementa-
tion of a water—based spray top coating system is not comrner—
cially feasible at this time
and
that an alternate form of con-
trol will therefore be required.
~
-
Begin preliminary engineering and
design for alternate control technique.
October 7, 1974
-
Begin final design engineering for
alternate control technique,
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~ecember 2, 1974
-
Complete final design engineering
and ordor direct flame thermal incinerator. Begin removing
catalytic incinerator from Providence, R,I, plant for ship-
ment to Chicago plant.
January 6,
1975
-
Begin installing catalytic incinerator
at Chicago plant.
~~anuary 15, 1975
-
Begin building and structural modi-
fication to building for direct thermal incineration.
February 3, 1975
-
Make catalytic incinerator at Chicago
plant o~F~I6na, thereby reducing organic emissions by at
least 5C~ percent.
Ma~~l2~
-
Receive delivery of direct thermal incin-
erator and begin installation,
May 31, 1975
-
Make
direct
thermal incinerator
operational.
Compliance with Rule 205(f) achieved.
Petitioner discovered in September, 1974, that imple-
mentation of a commercially acceptable water-based
spray system,
as~the compliance method scheduled in PCB
74-222, could not be
accomplished by September 30, 1974, for
two reasons. First, the
production equipment would require more extensive modification
than previously envisioned, Second, additional time to obtain
customer approval and acceptance of
the new product would be
required.
A variance from Rule 205(f) until May
31,
1975, will
permit Petitioner to install an incineration system to oxidize
organic emissions from Spray-Coating Lines No. 1 and No. 2 as
completely as possible. This incineration system will be
utilized until a satisfactory water-spray coating system
is
developed at which time the water-spray system may be substit-
uted.
Petitioner estimates that it will spend $43,200 for the
transfer, repair, and reinstallation of the catalytic inciner-
ator from its Providence plant, and $163,000 for the acquisition
and installation of a new thermal incinerator, Total cost of
installed equipment is estimated to be $206,200. Besides the
expenditures for incineration equipment, Petitioner expects to
invest $116,000 to improve and modify the spray-coating lines
to enable them to utilize the water—based top coat solutions
and thus eliminate the use of organic—based materials for the
top coat portion of its production by early
1976.
Petitioner
does not expect to be able to change to water-based coatings
for both top and bottom coats until a much later date.
Petitioner~s plant is located in
an industrial/commer-
cial area, There have been no citizen complaints.
15—91
The Environmental Protection Agency (Agency) filed its
Recommendation on December 17, 1974. The Agency recommended
that the Petition for Variance from Rule 205(f) of Chapter
Two be granted until May 31, 1975, subject to certain con-
ditions. The Agency agreed that it would constitute an ar-
bitrary and unreasonable hardship to deny the Petition for
Variance when the Petitioner is planning to achieve com-
pliance through interim control measures. The amount of time
requested is reasonable considering the magnitude of the work
that needs to be done to install both the catalytic and direct
thermal incinerators,
We deny the Petitioner~srequest to withdraw its
Petition for Variance in PCB 74-222. Final Board action has
already taken place on that request. We construe this case
before us as a Petition for Variance from April 1, 1975,
through May 31, 1975, and as to such Orders in the Order in
PCB 74-222 that cannot be implemented because of changes in
the compliance plan.
We grant Petitioner~srequest for a Variance subject
to certain conditions spelled out in our Order. Uniroyal is
making good-faith efforts to abate its pollution source with
a definite program for compliance. Large sums are being spent
The two-month delay is not self-imposed. On these facts, it
would be an unreasonable hardship to deny the Petitioner the
additional time to meet the requirements of Rule 205(f) of
Chapter Two.
ORDER
IT IS THE ORDER of the Pollution Control Board that
Uniroyal, Inc. be granted a Variance from Rule 205(f) of the
Air Pollution Regulations for its Chicago plant until May 31,
1975, subject to the following conditions:
1. Petitioner shall continue to carry out, where
applicable, the Order in PCB 74-222 (September 12, 1974),
2. Petitioner shall apply for and obtain all nec-
essary permits for the installation and operation of new
equipment.
3. For the provisions of this Variance, Petitioner
shall, by February 1, 1975, post a performance bond in the
amount of $10,000 in a form acceptable to the Agency. Such
bond shall be forfeited in the event Petitioner fails to ad-
here in the most practicable manner to the timetable set out
above in the Opinion. The bond shall be mailed to:
Fiscal Services
Environmental Protection Agency
2200 Churchill Road
Springfield, lolinois 62706
15 —92
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4. Petitioner shall continue in its efforts to
develop a water—based
spray-coating
system so that it may
complete the conversion of Lines Nos. I and 2 as
soon as
possible.
5. Petitioner shall reduce its
solvent emissions no
less than 50 by February 3, 1975, By May 31, 1975,
Petitioner shall control all solvent emissions by at least
85 to comply with Rule 205(f) (1) (A).
6. Petitioner shall submit monthly
reports to the
Agency through June, 1975. The reports shall follow the
form and include the information set out in Order #5 of
PCB 74—222.
7. Petitioner shall submit its final compliance plan,
with dates included, to the Agency by March 31, 1975.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify that he above Opinion and Order was
adopted on the
~
day
~
1974, by a vote of
Christam L.
~tt
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