ILLINOIS POLLUTION CONTROL BOARD

January 24,

1985

AMERICAN CAN CCMPANY,

)

(HOOPESTON PLANT)

Petitioner,

PCB 84—106

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

OPINION AND ORDER OF THE BOARD

 (by J. Marlin):

On July 27,

 1984, American Can Company (American)

filed

a

petition for

Variance extension

 from

35

 Iii. Mm.

Code 201~243, 215.204(b)

 and 215

 Appendix C old

 Rules

103(c),

205

(m)

(1)

 (B), and 205(n)(l)(B)

 of Chapter 2,

volatile organic material

 (VOM).

 On October

5,

 1984,

the

Illinois Environmental Protection Agency (Agency) moved to file

its recommendation instanter which the Boar~granted on October

12,

 L984~

 Hearing was held inHoopeston, Illinois on December

12,

:L984.

 American has waived the decision date until January 25,

1985.

The former VOM variance in PCB 80-213,

 granted for three

y ars, expLed

 on October

 1, 1984

 (40 PCB

433,

February

5,

1981).

American1s Hoopeston plant is located on commercially

zoned

nn~~y

 at: 316—328 West Main Street,

 Hoopeston,

 Illinois,

and

•~y~

 t55 people.

At

the

 plant sheets of metal are coated and

sealing

 compounds are applied to pre-formed ends.

 These components

are then used to manufacture cans.

 The processes include the

application of sideseam spray coating and end sealing compounds;

which contain VOM~s,

 Approximately ninety percent of American’s

VOM emissions are generated

 by end—sealing compounds

 (Ag. Rec.

 at 4).

After application the coating and compound materials are cured

in

dryers

 and ovens which exhaust VOM through stacks into the

atmosphere

American is required to comply with 35

 Iii. Adm. Code

 215.204(b),

215.2O2~,and

 35 Iii.

 Adm,

 Code Part

 215, Appendix C,

which provide

that

on

 December

 31, 1982 the VOM content of the

coatings

utilized by American shall be limited as follows:

side seam spray coat

 5.5 lb/gal

end sealing compound coat

 3.7 lb/gal

Americans total side seam spray and end sealing compound coats

usage in 1983 was 67,563 gallons

 (Pet.

at

9).

 Total VOM

em-nissions have been reduced from 340 tons

 in 1980 to 145 tons

in

1983

 (Pet.

at

3).

 Excess VOM emissions were 80.8 tons

 in 1983

(Pet.

at

 12).

62-399

Reductions in VOM emissions were accomplished by moving the

interior

and exterior base coating operations to Indiana,

 installing

two

welded can lines ~t a cost of two million dollars, and reformulatinq

three

of

 seven side seam sprays and one of five end sealing compounds

to lower VOM content

 (Pet. at 4,5).

 American cites a total cost of

over three million dollars for its efforts at compliance

 (Pet.

at

5,

Gere Aff.,

 par.13).

American has evaluated alternate control strategies such as

carbon

adsorptionand catalytic incineration.

 The plant structure

would

need major structural changes

in

addition to extensive hooding

and duct work

 (Pet. at 16).

 Because the solvent-based materials

are air dried and the VOM concentrations low per unit of air,

carbon adsorption and catalytic incineration would not achieve

efficient economical VOM destruction

 (Id.).

 The only

 other

compliance mechanism is to

offset

the VOM emissions from one process

 with lower than allowable emissions from another process.

 However,

there are no other prccesses

at

the Hoopeston plant which could

generate an offset

 (Pet.

at

17),

During the term of the variance extension, American plans

to

gradually introduce a multi-purpose sanitary end sealing compound

and

correct two additional soldered can lines to welded technology

(Id..)

Low solvent materials will

be introduced into the lines

as

 they

i~~ome

available.

 American thus plans to have all VOM sources in th

plant,

 other than the high fat resistant end sealing

 compound,

in

corc~piiance.

 American, as well as can manufacturers and suppliers,

conclude

that finding a low solvent replacement for this compound

I

 a national problem and the solution will not be forthcoming in

ta

 foreseeable future

 (Pet.

 at 20~Gere Aff,,

 par. 20).

 American

plans to

either develop a control technology for this compound or

t-~

‘d~aina revision in the VOM

 limitations

for

 these

~

 (Gere Aff., par.

 15).

American is located

in Vermillion County, Grant Township, an

 attainment

area for ozone.

 VOM~sare

precursors of ozone which can

have

adverse

 health effects on

the elderly

and on persons with

respiratory

and cardiac

problems.

 Acme Barrel

v.

 IEPA, May 18,

198

PCB 83-118.

The

closest

ozone monitor located at

606 East Grove,

Champaign,

 Illinois recorded

no excursions from the

0.l2ppm primary

and secondary national

ambient air quality standard for

ozon~in

1982

 (Ag..

 Rec. at

7).

American asserts

and

the Board finds

that the granting of

variance extension will result

in a

continued

 reduction of VOM

emissions and thus

~ ~inima1 advetse environmental impact.

American asserts and the Board finds that to deny the varianc?

extension and mandate immediate compliance

would impose an

arbitrary or unreasonable hardship on American for the reasons

above,

fl\1~

3

The Board will grant

American a

variance extension

for

its Hoopeston plant from 35

 Iii,

 Adm.

 Code 215 Appendix

215.204(b)

 (5) and

 (6),

 and Section

215.202 subject

to

the conditions

 below.

This Opinion constitutes

the Board~s

findings of fact

and

conclusions of

 law in this

matter.

ORDER

American Can Company (Hoopeston plant),

 is granted

a

variance extension from 35

 Ill. Mm.

 Code 215 Appendix

C~

215.202,

 and 215.204(b)

(5)

and

 (6) subject to the conditions

below:

1.

 This variance shall begin on October

1,

 1984 and expire

on December 31,

 1987.

2~

 American shall continue to submit quarterly written

reports

to

the

 Agency until December

 31, 1987 detailing

all

progress made in achieving compliance with the

VOM

 limitations of

35

 Ill. Adm.

 Code 215.204(b).

Such

reports shall contain information on the quantity

and

solvent content of all end-sealing compounds and solvent

sprays

utilized during the reporting period, as well as

a description of the efforts made to develop compliant

 end—sealing compounds and sideseam sprays during the preceding

three

months.

 The progress reports shall also describe

in detail the status of negotiations between CMI and the

USEPA

 to revise the VOM

 limitation for high fat

resistant end—sealing compounds.

All

such information

shall

 be submitted to the

Agency at the

following addresses:

Illinois

 Environmental ProtectiQn Agency

Division of Air

Pollution

Control

Field Operations

Section

2200 Churchill Road

Springfield,

 Illinois

62706

Illinois Environmental Protection Agency

Division of Air

Pollution

Control

lISA West Main Street

Collinsville, Illinois

62234

3.

 Prior to installation

of any welding

equipment

 which

utilizes compliant sideseam

materials,

 American shall time1~

apply

 for,

 and receive,

 construct:ion permits from the Agency

pursuant to

 35 Ill. Adm. Code

201.142.

4.

On

or before January

1,

 1987,

 Petitioner American

shall submit to the Agency at

the

addresses provided in

condition

 above a program to

install

available contrpl

technology which will bring the Hoopeston plant into compliance

with the applicable rule

if

 it does

not reasonably expect

to achieve final compliance with those

 limitations

by December

 31, 1987 through

its

reformulation program.

82~401

4

This alternate

compliance program shall provide for final

compliance with the applicable rule by

December

31,

1987

and shall provide for

the submittal

of quarterly written

reports detailing

progress made in

installing alternative

control technology.

 American shall comply with all applicable

rules

 of the Illinois Pollution Control Board,

 including,

but not limited to 35

 Iii..

 Adm,

 Code 201.142,

in

satisfying

this permit condition.

5.

 Within forty-five

 (45) days

 of the

Board’s final Order

herein, the Petitioner shall execute and send to:

Mr. Joseph

R.

 Podlewski,

Jr.

~nforcement Attorney

Illinois Environmental Protection Agency

2200

Churchill

Road

Springfield

 Illinois 62706

a certification of acceptance

 of this variance by which

it agrees to be bound by its

terms and conditions.

 This

forty-five

 (45) day

peniod shall be held in

abeyance for

any period which this

matter

is

appealed.

 The form of

the certification shall be as follows:

CERTIFICATION

American

Can Co. hereby accepts

and

agrees to be bound

by all terms and conditions of the Order

 of the Pollution

Control Board in PCB 84-106 dated

__________,

 1984.

AMERICAN CAN CO.

BY:

_________________

~utflorizeU

 Agent

Title

Date

IT IS SO

ORDERED

Board Member Bill S.

 Forcade dissented,

I, Dorothy M. Gunn, Clerk of the

Illinois Pollution Control

Board, hereby certify that

the above

Opinion and Order

were ado/ted on the

 day ~

 1985 by a vote

Dorothy

M,/Gunn, clerk

Illinois Pollution

Control

 Board

62-402