ILLINOIS POLLUTION CONTROL BOARD
    THE MEYERCORD COMPANY,
    Petitioner
    V.
    POB 74~184
    ENVIRONMENTAL PROTECTION AGENCY,)
    Respondent.
    OPINION AND ORDER OF THE BOARD (by Dr. Odell)
    Petitioner,
    which
    operates a facility engaged in the
    business cf printing
    government tax stamps, filed on May
    20.
    1974, a Variance request from Rule 205(f) of the Air Poilut:Lon
    Regulations
    (Chapter Two).
    Petitioner
    is located in a strictly
    industrial area of
    Carol Stream, Illinois.
    Meyercord requested
    a one—year Vari~ance to enable it to
    switch
    from photochemicailv
    reactive solvent systems to
    photochemically
    non—reactive solvent
    systems, Industry—wide shortages of exempt
    solvents was alleged
    as the cause for delayed compliance.
    Petitioner did not indicate
    whether alternati~7e methods had been investigated to achieve com-
    pliance with Rule 205(f) of Chapter Two, Petitioner alleged that
    failure to grant the Variance would mean curtailment of
    plant
    operations and thus ~jeopardize the employment of 535 plant and
    sales personnel,
    Rule 205(f) of
    Chapter
    Two limits the discharge of any
    organic material into the atmosphere to no
    more than 8 pounds per
    hour from any single emission source. The amounts
    of
    photo—
    chemically reactive solvents presently discharged
    by
    Meyercord are:
    Per Press Total
    lbs/hr
    _____
    Roto Press (Vent A)
    11,6
    Roto Press (Stack B)
    11.6
    23.2
    Barta Press (Stack H)
    20,1
    20.1
    2 Barta Presses (Stack I)
    20.1
    40.2
    General Press #6 (Stack P)
    22.1
    22.1
    General Press
    -
    Jumbo (Stack Q)
    80.2
    80.2
    Total
    13
    —
    313
    —2—
    The Environmental Protection Agency (EPA) filed a
    Motion to Consolidate this action with PCB 74-220 (The Meyercord
    Company~v. Environmental Protection Agency) on July 18, 1974.
    This was denied by Board Order on July 25, 1974. The EPA filed
    its Recommendation in this case on July 30, 1974. EPA recommended
    that the Variance be denied or, in the alternative, be granted
    only for six months and be subject to certain reporting and
    planning conditions. EPA admitted that there were no citizen
    objections to
    the Variance grant but agreed for Variance denial
    in that:
    1. Petitioner did not give any evidence or support
    for
    its allegation that it is financially incapable
    of installing such
    equipment.
    2. Petitioner applied for neither an operating permit nor
    a Variance until May 1974,
    five months after Rule
    205(f) became
    effective.
    He are unable to find in Meyercord~s petition
    any allegation
    that
    Petitioner is financially
    incapable
    of
    installing alternative
    equipment..
    There is ro
    information
    in Petitioner’s
    Variance request
    suggesting that alternative
    means of compliance with Rule 205 (f)
    have been investigated.
    The second argument of EPA has some merit.
    Failure to apply for a permit until May 1974 may be some evidence
    bha~P~tit~nor ~
    4cot faith
    i~
    seek ing
    ri
    ~a’iance at tnis t~ine
    However, we have
    no evidence that Petitioner needed a Variance be—
    fori
    ~ts Ma~ L974 application ~Aiso varian~e cannoc be den~ea
    because of
    a
    nossible past violation
    of the law.
    He
    or
    ant
    Meyercord a
    variance
    until November 1974.
    We
    generally agree with the Agency that the
    Petition does not
    fully
    comply with Rule 401
    of
    our Procedural Rules.
    The lack of any
    investigation into alternative methods cf control is particularly
    troublesome,
    However, there is
    no citizen objection, and the
    Board
    is aware of the shortages of exempt solvents in the industry.
    On these facts, it
    would
    be an unreasonable hardship to deny
    Meyercord this brief reprieve.
    ORDER
    Petitioner is
    granted a variance from Rule 205(f) of
    Chapter Two until November 1, 1974,
    subject to the following
    conditions:
    (a) Petitioner shall utilize as much exempt solvent
    formulations as can be furnished by its suppliers.
    (b) Petitioner shall submit reports for the months of
    August, September and October to:
    13
    —
    314
    Environmental Protection Agency
    Division of Air Pollution Control
    Control Program Coordinator
    2200 Churchill Road
    Springfield, Illinois 62706
    The monthly reports should include the total amount
    of solvents used, the nature and amount of non—
    exempt solvents used, the nature and amount of
    exempt solvents used, the amount and nature of
    exempt solvents purchased (indicating the supplier),
    the amount and nature of non~exempt solvents pur~
    chased (indicating the supplier), and the amount
    and nature of solvents in inventory at the beginning
    of each month.
    Cc) Within 2 months from the date of this Board Order,
    Petitioner shall submit to the Agency a modified
    compliance plan to replace that which has been
    nullified by shortages. This plan may:
    i. Achieve compliance at the expiration
    of the Variance by replacement of
    photochemically
    reactive solvents
    with non—reactive solvents demon-
    strated to be readily available; or
    ii, Achieve compliance at the expiration
    of the Variance by qualification under
    the Alternative Standard of Rule 205(f)
    (I); or
    iii. Achieve compliance by May 30, 1975 under
    the provisions of Rule 205(f) (2) CD),
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, h~rebycertify that the above Opinion and Order was adopted
    on the ~ day of
    ~,
    1974, by a vote of
    to
    Christan L. Moff~
    13
    —
    315

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