.
.
.
.
ILLINOIS POLLUTION CONTROL BOARD
April
25,
1974
.
.
AMF INCORPORATED,
)
Petitioner,
)
vs.
)
PCB 74—8
ENVIRONMENTAL PROTECTION AGENCY,
.
Respondent.
)
.
Mr. John
V.
Hayes, attorney, on behalf of Petitioner;
Mr. Thomas
R.
Casper, Attorney,
on behalf of the Environmental
Protection
Agency.
.
.
OPINION
1\ND ORDER OF
THE
BOARD
(by
Mr. Seaman):
.
.
On January 4,
1974, AMF Incorporated filed
its Petition for Variance
seeking therein variance from the provisions of Rule 205(f)
of Chapter 2,
U
Part
II
of the Air Pollution Regulations.
The variance would apply
to four operating permits previously qra,~tedto Petitioner’s AMF Wheel
Goods Division located near Olney, County of Richland,
Illinois.
.
The operating permits
involved
are:
.
Permit
No.
Operation of
.
.
03010550
Bicycle Paint
03010552
Flow Coating
03010553
Car and Tractor Paint
03010554
Velocipede Paint
.
.
Petitioner’s Olney facility
is engaged
in the manufacture of bicycles
and children’s wheel
goods.
The Petitici relates
to the use of photochemicafly
reactive solvents
in Petitioner’s
bicycle paint, flow coating, car and
tractor paint,
and velocipede
paint operations.
U
In
1972, Petitioner employed
an engineering consulting firm to determine
its
facility’s compliance with Illinois air po.llutLn regulations.
This
data was subsenuently utilized in filing the facility’s operating permit
applications.
The study
revealed, inter
alia,
that the four assembly
line
oainting processes detailed above were each discharging more than 8 lbs/hr
of organic material
into the atmosphere,
in violation of Rule 205(f).
In December 1972, Petitioner filed operE~tingpermit applications
for
•
these emission sources specifying compliance through change of solvents.
On January
1,
1973,
Petitioner made the change to exempt solvents
(allegedly
U
at
a 50% continuous operating cost penalty over non-exempt solvents) and
the operating permits were granted
in March of
1973.
Petitioner now asserts
U
that
a variance
is necessary because major shortages of exempt solvents
U
.
U
J2
—
153
.
U
.
U
-2—
have recently developed in the marketplace due to the worldwide
shortage of petrochemical
products and that Petitioner has been
unable to procure sufficient exempt solvents to achieve continued
compliance.
The raw materials processed through the subject facility
and their emission sources are the solvent based paints and the
metal bicycle and wheeled toy frames.
The combined weight of
all
materials processed
is approximately 13,100
lbs./hr..
The paint
pigment solids and solvents constitute about
630 lbs./hr.
of the
combined process weight rate,
the remainder consisting
of metal
parts.
The following are Petitioner’s estimates of the quantity and
type for the uncontrolled emission of contaminants
by each of the
subject emission sources:
Permit No.
Quantity
(lbs.
per hour)
Type
03010550
18.6
Hydrocarbons
as CH4
03010552
15.4
Hydrocarbons
as CH4
03010553
26.5
Hydrocarbons
as CH4
03010554
8.0
Hydrocarbons
as
CH4
The Agency, however,
takes issue with the above rates and computes
the rates
to
be:
Permit No.
Quantity (lbs.
per hour~
Type
O 3010550
20 lbs/hr.
Hydrocarbons
as CH4
O 3010552
15 lbs/hr.
Hydrocarbons
as CH4
O 3010553
33 lbs/hr.
Hydrocarbons
as CH4
O 3010554
28 lbs/hr.
Hydrocarbons
as CH4
Petitioner,
in its response to the Agency Recommendation, mentions
but takes no issue with the Agency computations.
Petitioner asserts that the marketability of wheeled toys and
bicycles
is substantially influenced by the cosmetic appeal
of glossy
finishes provided by solvent based paints and that at the present time
the existing technology of painting processes offers glossy finishes
only for solvent based paints.
The Agency notes for our consideration that Ford Motor Company and
General
Motor have had some success with water-based paint for automobiles,
and have achieved cosmetic glosses.
It appears,
however, that the major
automotive manufactures
have restricted their use of water reducible
watings
to electro-deposition and dip applications
of primers and shop
coats
in browns, grays and blacks, where cosmetic appearance of the
finished product is not
a factor.
General Motors has 200 units
in field
service,
finished with water reducible acrylic enamel
in solid
(non—metallic)
colors.
However,
this
is
strictly in the experimental
stages.
(See
Petitioner’s Response to Respondent’s Recommendation,
p.9.).
12—
154
—3—
The Agency suggests that Petitioner might use water-based paint
as an undercoating.
Petitioner replies that it has determined that
such
a procedure is not feasible, based on the technical consideration
that the aluminum particles, used in and essential
to the undercoat
paint, hydrogenate
in the presence of water.
Such hydrogenation,
it
is argued, destroys the desired qualities and,
indeed,
the objective
of the undercoat paint which
is primarily to enhance the appearance of
the final
product.
(See Petitioner’s Respon~eTo Respondent’s
Recommendation, p.8.).
The Agency notes
that thermal incineration afterburners would
require 20,00Q cubic feet of natural
gas per hour and that it
is
unlikely that Petitioner could obtain natural gas
in such quantities.
Although the Agency recommends that
a variance be granted,
subject
to certain conditions,
its primary concern appears
to be that
Petitioner has too lightly dismissed the possibility of compliance by
the installation of a solvent recovery system.
The Agency notes that
a solvent recovery system has been installed at Petitioner’s Lawville,
New Jersey plant,
although there are major differences between the two
operations.
Petitionerh~saddressed this point in
its Response To Respondent’s
Recommendation.
Although it appears that installation of
a
solk’ent
recovery system at the subject facility may well
be impractical, we
are of the opinion that our decision
in the matter would be facilitated
by
a more thorough and detailed exposition by Petitioner and further
enlightened by
an Agency response thereto.
Petitioner’s request for
variance will be granted
in the interim.
This Opinion constitutes
the findings of fact and conclusions of
law of the Board.
IT
IS THE ORDER of the Pollution Control
Board that Petitioner be
granted
a variance from the provisions of Rule 205(f)
of Chapter 2, Part
II
of
the Mr Pollution
Regulations until
September 30, 1974, subject
to the
followoing conditions:
1.
On or before June 30, 1974, Petitioner
shall
submit
to the
Agency and this Board
a report regarding feasibility
and practicality
of installing
a solvent recovery system at the subject facility.
2.
On or before July 31, 1974 the Agency shall submit
to this
Board and
to Petitioner such comment on Petitioner’s report as
is deemed
appropri ate.
3.
On or before August 31, 1974, Petitioner shall
submit
to this
Board and the Agency any pertinent information regarding the Agency comment.
4.
During the period of this variance, Petitioner shall
continue
to seek out sources of exempt solvents, and use same whenever available.
12
—
155
-4..’
I,
Christan
L.
Moffett,
Clerk of the Illinois Pollution Control
Board, certify that the above Opinion and Order was adopted on this
~
day of
~
,
1974 by
a vote of
~
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156