ILLINOIS POLLUTION CONTROL BOARD
February
5,
1981
I?RIN~TPACK, INC.,
Petitioner,
)
v.
)
PCB 80—148
tLLIMOIS ENVIRONMENTAL PROTECTION
)
AGFr’~ICY,
)
)
Respondent.
OPIr~~IONAND ORDER OF THE BOARD (by
I.
Goodman):
Printpack,
Inc. on August 11,
1980 filed a petition for
variance from Rule 205(j)
of the Board’s air pollution control
regulations, Chapter
2,
for three years.
Printpack amended
its
petition on November 12, 1980.
The Illinois Environmental Pro-
tection Agency’s
(Agency) January 26,
1981 motion to file recommend-
atiori instanter is granted.
Hearing was waived;
no public comment
has been received.
Printpack,
located in Elgin, Kane County, manufactures
flexible packaging for use primarily by the food industry.
The
manufacturing process produces 7,500,000 pounds of papers and films,
such as cellophane and polyester,
yearly.
The process utilizes
laminating adhesives of approximately 75
hydrocarbon-containing
solvent,
or about
6.5 lbs. of solvent per gallon of adhesive.
Printpack’s yearly use of 45,000 gallons of adhesive per year
results
in emissions of hydrocarbons of approximately 146 tons per
year after some reduction by processing ovens.
Under
Rule 205(n)
(1)(C),
Printpack’s allowable hydrocarbon emissions are 65 tons
per year.
Printpack seeks variance in order to use a lower—solvent
technology of 2.9 pounds of solvent per gallon of adhesive and
projects compliance of 50
of its coatings by the end of 1983 and
100
by the end of 1985,
The staged compliance dates are appar-
ently necessitated by variable adaptability of the technology to
the lines depending upon the porosity of the substrates.
The
Agency recommends grant of the variance.
Rule 205(n)(2),
an alternate limitation to Rule 205(n)(1)(C),
allows emissions at that hydrocarbon level resulting from the
use of either an afterburner
(under certain circumstances)
or
another system demonstrated to be at least as efficient either as
those controls achieving
2.9 lbs./gallon or as an afterburner
pursuant to Rule 205(n)(2)(A).
Printpack alleges that the use of an afterburner is econord-
cally unreasonable at a capital cost ranging from $200,000—700,000
and at yearly operating costs ranging from $50,000—150,000.
Print-
40—411
—2—
pack
alleges
that
other
USEPA—approved
technology
~or
hydrocarb)n
emission
reductions
is
technologically
infeasible
because
of
the
small
concentration
of
hydrocarbons
in
the
large
volume
of
exhaust
air
and
because
separation
of
the
lines
cannot
he
done
adequately
due
to
problems
with
separation
of
reaction
products.
Printpack alleges that USEPA has recognized that
the
use
of
lo~zsolvent technology is a reasonably available control methodo1o~y
to reduce hydrocarbon emissions,
although cites that
it can be
technology—forcing
in certain applications.
Printpack also alleges
that the USEPA recognizes that five years’ time to develop
these
applications, and additional time for retrofitting, is a reasonable
period
in which to require investigation, installation
and
opara-
tion of the technology.
The Board finds these to he sufficient
alieg~tionsof unreasonable hardship and will
allow Printpack
to
develop
and
use complying low—solvent adhesives.
Printpack alleges
that
the Board should use a bubble concept
(Rule
205(n) (4))
to evaluate its staged compliance plan.
Howevec,
the
concept is unrelated to the date of compliance of all
lines,
which
is the subject of Printpack’s variance request.
Printpack’s petition makes
no mention of the substance of
its
Compliance Plan required by Rule 205(m)(1)(A)
to have been filed
with
the Agency by January
1,
1980,
nor its Project Completion
Schedule, required by Rule 104(g)(4)
to have been filed with
the
Agency on or near February
1,
1980,
nor its six—month reports
from July
1,
1980 to date pursuant to Rule 205(m)(1)(B)(i), nor
the status of its operating permit.
Petitioner’s request for “an
extended compliance plan as presented on our permit application”
essentially seeks variance from rules relating to the Compliance
Plan and Project Completion Schedule.
The Board will grant variance from Rules 104(a),
104(g)(4),
205(n)(1)(C), and 205(m)(1), under certain conditions herein
specified,
in order for the Agency to grant revisions to the Com-
pliance Plan and Project Completion Schedule pursuant to Rule
104(d).
Should Printpack fail
to meet any of its compliance date.~
as contained in the Compliance Plan or Project Completion Schednl.e~
it will be subject to an enforcer~entaction under the Act
arid
the
Board’s Rules.
This Opinion constitutes the findings of fact and conclusions
of law of the Board
in this matter.
ORDER
It is the order of the Illinois Pollution Control Board
that
Priutpack,
Inc. he and hereby is granted variance from Rules
104(a),
104(g)(4),
205(n)(1)(C), and 205(m)(1)
of Chapter
2,
Air Pollution
Control Rules and Regulations, subject to the following terms and
conditions.
40—4 12
—3—
1.
Printpack.
Inc.
shall
achieve compliance
with
Rule 20~
(n)(i)(C)
as follows.
a.
at least
20
of all coating lines by December 31,
1981;
b.
at least
30
of all coating lines by December
31,
1982;
c.
at least 50
of all coating lines by December 31,
1983;
d.
at least 75
of all coating lines by December 31,
1984;
and
e.
100
of all coating lines by December
31,
1905.
2.
Printpack,
Inc.
shall continue research and developmen4~
of low—solvent adhesives and coatings and all technology enablin~j
the
use oE such adhesives and coatings.
3.
On or before April
1,
1981 Printpack,
Inc.
shall
suUi~it
a revised Compliance Plan and Project Completion Schedule
to
the
Illinois Environmental Protection Agency,
Division of Air Pollutiur,
Permit Section,
2200 Churchill
Road,
Springfield, Illinois 62706,
which
is consistent with the terms of this variance and which
coinports with the requirements of Rule 104(b) of Chapter 2,
Air
Pollution Control Rules and Regulations.
4.
On or before
April
1,
1981 Printpack,
Inc. shall
apply
te
the Illinois Environmental Protection Agency at the address in
Paragraph
3 of this Order for all necessary operating permits.
5.
Beginning on July
1,
1981 and semiannually thereafter,
Printpack,
Inc.
shall
submit written reports to the Illinois Envi-
ronmental Protection Agency,
Control Program Coordinator, at
the
address in Paragraph
3 of this Order which detail the results of
its research and development efforts.
Such reports shall include
the emissions from all adhesives and coatings used and shall state
the percentage of adhesives and coatings meeting
the limitation
in
Rule 205(n)(1)(C)
o.f Chapter
2,
Air Pollution Control Rules and fle~-
ulations.
6.
Within 45 days of
the date of this Order,
Printpack,
Inc.
shall execute and forward to the Illinois Environmental Protection
Agency, Variance Section,
at the address in Paragraph
3 of
thi.~
Order,
a Certification of acceptance and agreement to be
bound by
all conditions of this variance.
The forty—five day period
shall.
be stayed
if Petitioner seeks
judicial review of this variance
pursuant
to
Section
41
of
the
Environmental
Protection
Act.
The
form
of
said
Certification
shall
he
as follows:
CERTIFICATION
I,
(We,)
________—_____________
___,
having read
the Order of the Illinois Pollution Control Board in PCB 80—14~3
dated
——_____
__________,
understand and accept the Order and
agree to be bound by all
of its terms and conditions.
40—4 13
—4—
____
Petitioner
____
,
Authorized
Agent
____,
Title
__,Date
I, Christan
L.
Moffett, Clerk of the Illinois Pollution
Control Board, hereby certify that the above Opinion and Order
were
adopted
on
the
-
day
of
_____~~_~__~~~
,
1981
by
a
vote
of
Christan
L. Moffett~Clerk
Illinois Pollution Control Board
40—414