.
    .
    .
    .
    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
    ~
    156

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