ILLINOIS POLLUTION CONTROL BOARD
    October 27, 1982
    ENGINEERED COATED PRODUCTS,
    INC..
    )
    )
    Petitioner,
    )
    v.
    )
    PCB 82—2
    )
    ILLINOIS ENVIRONMENTAL PROTECTION
    )
    AGENCY,
    Respondent.
    MR.
    VILNIS GAGAINIS APPEARED ON BEHALF OF PETITIONER.
    MR.
    PETER E. ORLINSKY APPEARED ON BEHALF OF RESPONDENT.
    OPINION AND ORDER OF THE BOARD
    (by
    I.
    G.
    Goodman):
    Engineered Coating Products,
    Inc.
    (ECP) petitioned for
    variance from Rule 205(n)(1)(C)
    of Chapter 2:
    Air Pollution
    of the Board Rules and Regulations on January 14,
    1982.
    The
    petition was twice amended on March
    2,
    1982 and May
    3,
    1982.
    Hearing was waived by ECP on June
    22,
    1982.
    On July 1,
    1982
    the Board ordered this matter to hearing to expedite the review
    of the U.S. Environmental Protection Agency should the variance
    be granted and subsequently presented as an amendment to the
    State Implementation Plan.
    Hearing was held on August 16,
    1982.
    No citizens were at the hearing and the Board has received no
    public comment.
    In its petition ECP requests an additional year
    to comply with the
    (2.9 lb/gal)
    3.5 kg/i limitation of volatile
    organic materials, excluding water,
    delivered to the coating
    applicator,
    as contained in Rule 205(n)(l)(C), Paper Coating.
    Rule 205(j)
    of Chapter
    2 requires ECP to comply no later than
    December 31,
    1982.
    ECP is located at 2800 Shermer Road, Northbrook,
    Illinois
    in an industrial park near Glenview Naval Air Station, with
    residential areas west and southeast of the facility.
    Employing
    approximately 22 persons,
    ECP operates one pressure sensitive
    coating line, which includes an oven with three uncontrolled
    exhaust stacks.
    ECP estimates that approximately 5,300,000
    square yards of film,
    foils, paper, and miscellaneous custom
    materials are coated with 532,000 pounds of pressure sensitive
    adhesives.
    The higher performance sensitive adhesives,
    including
    double-faced tapes, aluminum foil tape and transfer films are
    pri-
    marily for use in automotive and major appliance product assembly.
    Twelve suppliers furnish as many as twenty-one different pressure
    sensitive adhesives, which average approximately 53
    solvent and
    47
    solids, for an average weight of 7.3 lbs/gal.
    Based on these
    49-213
    2
    figures,
    ECP estimates that it discharges 282,000 pounds of sol-
    vent or 141 tons of volatile organic compounds per year.
    In efforts to comply with Rule 205(n)(l)(C), ECP has begun
    working with suppliers to reformulate the adhesives it uses.
    Initial attempts with water—based coatings failed because the
    existing production equipment rusted.
    ECP is
    still actively
    seeking water based and high solids coatings which are com-
    patible with existing equipment or which will require limited
    equipment modification.
    ECP investigated using both solvent
    recovery systems and afterburners.
    Normally, the former would
    only involve activated charcoal and steam recovery.
    Since some
    of the adhesives used at ECP contain water soluble solvents,
    distillation would also be required.
    The cost of the energy
    required for steam production and distillation would be pro-
    hibitive.
    Afterburners also proved too expensive, the cost
    approximated to be the same as that invested on the coating
    and laminating equipment——approximately $300,000.
    ECP proposes to reduce the total volatile organic compounds
    it emits by reformulating some of the adhesives used to either
    high solids or water-based materials.
    All of the adhesives used
    will not be reformulated by late 1983, however ECP intends to
    gain sufficient reductions from those that are to enable the
    implementation of an alternative control strategy.
    ECP is pre
    sently working with nine suppliers to develop compliance adhe-
    sives.
    Its compliance program projects that half of the coatings
    used by December, 1983 will be either water—based or high solids
    adhesives,
    and additional conversions to reformulated adhesives
    will occur in 1984 and 1985.
    The Illinois Environmental Protection Agency
    (Agency)
    surveyed the residential area surrounding ECP and found no
    complaints of odor or otherwise.
    ECP is, however,
    located
    in a non—attainment area for ozone and three violations of
    the 0.12 ppm standard have been recorded at the nearby Skokie
    monitor in 1980.
    The Board notes that the Arlington Heights
    monitor, also nearby, recorded one violation of the 0.12 ppm
    standard in
    1981, and that the Skokie monitor in 1981, again,
    recorded three violations of that standard.
    The Agency believes
    that ECP’s episode action plan is sufficient to safeguard against
    periods of high ozone concentrations.
    The Agency estimates that
    ECP is required to reduce
    its volatile organic compound emissions
    by 56,195 pounds per year in order to comply with Rule 205(n)(l)(C)
    and considers reformulation, and the twelve to eighteen months
    it
    will require,
    the most efficient means of achieving compliance.
    Installation of thermal incineration or a recovery system
    is too costly to warrant ECP compliance with Rule 205(n)(1)(C)
    by December 31,
    1982, when compared with the cost and energy
    savings a reformulation program would provide.
    ECP has dili-
    gently pursued developing such a program and indicates that
    sufficient compliance coatings will
    be available no later than
    a year after December 31,
    1982 as required by Rule 205(j).
    49-214
    The potential environmental harm during the single ozone season
    between December,
    1982 and 1983 is minimized by the episode
    action plan.
    Furthermore, compliance by means of coating reformulation
    warrants additional time
    in this situation.
    Although ECP anti-
    cipates it will provide sufficient emission reductions for com-
    pliance with Rule 205(n)(l)(C)
    in 1983,
    the progress achieved
    should provide for development and use of even more water—based
    and high solids coatings.
    The Board finds that installation of
    conventional capture equipment would impose an arbitrary and
    unreasonable hardship for
    ECP,
    and therefore grants variance
    from Rule 205(n)(l)(C)
    so that ECP may pursue and convert to
    the use of water—based and high solids adhesive coatings no
    later than April
    1,
    1984.
    This Opinion constitutes the findings of facts and conclusions
    of law of the Board in this matter,
    ORDER
    Engineered Coated Products,
    Inc.
    is hereby granted variance
    from Rule 205(n)(l)(C)
    of Board Rules and Regulations Chapter 2:
    Air Pollution for
    its
    facility at Northbrook,
    Illinois until
    April
    1,
    1984 subject to the following conditions:
    1.
    Within 28 days of this Order, and every three months
    thereafter,
    Engineered Coated Products,
    Inc.
    shall submit
    written reports to the Illinois Environmental Protection
    Agency detailing all progress made in achieving compliance
    with Rule 205(n)(IHC)
    of Chapter 2.
    Said reports shall
    include information on the quantity and VOC content of all
    coatings utilized during the reporting period,
    a descrip-
    tion of the status of
    the
    reformulation program, and any
    other information ~thichmay be requested by the Illinois
    Environmental Protection Agency.
    2.
    At least
    180 days before the expiration date of this variance,
    Engineered Coated Products,
    Inc.
    shall file a permit applica-
    tion with the Agency which details a plan to,
    and proof that
    the plan will achieve compliance with Rule 205(n)(l)(C)
    of
    Chapter 2 by December 3l~1983.
    3.
    Within forty—five days
    of
    the date of this Order,
    Engineered
    Coated Products, Inc.
    shall execute and forward to the Illi-
    nois Environmental Protection Agency,
    2200 Churchill Road,
    Springfield,
    Illinois
    62706,
    a Certificate of Acceptance
    and Agreement to be bound to
    al.
    terms and conditions of
    this variance.
    This forty—five day period shall be held
    in abeyance for any period this matter is being appealed.
    The form of the certificate shall he as follows:
    49-215
    4
    CERTIFICATE
    I,
    (We),
    ____________________
    _________,
    having read
    the Order of the Illinois Pollution Control BoarUin PCB 82—2,
    dated
    _____________________
    ___________,
    understand and accept
    the said Order, realizing that such acceptance renders all terms
    and conditions thereto binding and enforceable.
    Petitioner
    By:
    Authorized Agent
    Title
    Date
    IT IS SO ORDERED.
    I, ~hristan L.
    Moffett,
    Clerk of the Illinois Pollution
    Control Board,
    hereby certify that tJ~eabove Opinion and Order
    was adopted on the .?‘Y~’
    day of
    ~
    —,
    1982 by a
    vote of
    ~
    ~‘_~~—•~
    ____
    Christan L. M~
    ,
    Clerk
    Illinois Poll t
    n Control Board
    49-216

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