ILLINOIS POLLUTION CONTROL BOARD
January
10, 1985
CHRYSLER CORPORATION,
)
Petitioner,
)
v.
)
PCB 84—127
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
MS. JACQUELINE A. SAVAGE APPEARED FOR PETITIONER;
MS. BOBELLA GLATZ, ATTORNEY-AT--LAW, APPEARED FOR RESPONDENT.
OPINION AND ORDER OF THE BOARD
(by J
D. Dumelle):
This matter comes before the Board on a variance petition
filed by Chrysler Corporation (“Chrysler”) on August 20,
1984.
Chrysler seeks
a variance from the topcoat material requirements
of
35 Iii. Adm.
Code 215.204(a)(2) for a period of three years
until August 31, 1987.
Section 215.204(a) (2) provides volatile
organic material limitations for coating materials at automobile
plants in Boone County.
The Illinois Environmental Protection
Agency (“Agency”)
initially objected to the variance on September
7,
1984.
The Agency subsequently supported grant of variance
subject to conditions in their recommendation and amended recom-
mendation filed October 23, 1984,
and
November
13,
1984, respec-
tively.
Hearing was held November 14,
1984, in Belvidere, Illinois.
No public comments were received.
Chyrsier owns and operates an automobile assembly plant in
Boone County, known as the Belvidere Assembly Plant.
The plant
occupies 248.86 acres near the Northwest Tollway 1—90, approxi-
mately two miles southwest of Belvidere.
Belvidere has a popu-
lation of 15,176.
The nearest resident is located approximately
one half mile south, southeast of the main production area
(Rec.
p.
5).
The plant currently employs approximately 4,200 people
and produces Omni and Horizon passenger cars
(Pet.
p.
2).
Volatile organic compounds
(VOCs) are emitted from the
topcoat operations as well as from other coating operations at
the plant.
Chrysler applies topcoats utilizing low voltage
electrostatic spray
(LVES)
equipment.
Chrysler met the
RACT
limit of 2.8
lbs. VOCIgallon water—borne coatings applied with a
30
transfer efficiency by installing
LVES
equipment by December
31, 1979.
The overall transfer efficiency is approximately 55
for topcoat operations
(Pet,
p.
3—4).
Utilizing production
62-279
2
figures supplied by Chrysler, the Agency has calculated 1984 year
emissions to be 870.7 tons VOC at an average of 4.45 pounds VOC
per gallon for topcoating.
Using similar techniques for year
1985,
emissions are predicted to be approximately 800.0 tons
(Rec.
p.
4—5).
Chrysler does not operate any VOC control equipment,
such as afterburners, at this facility.
Chrysler’s paint suppliers have been unable to provide production-
ready high solids topcoats at an acceptable quality level before
December 31,
1984
(Pet.
p.
4—5).
The requested variance would
allow the continued use of current topcoat materials containing
4.2 pounds of VOC/gallon of paint applied by LVES equipment with
an approximate 55
transfer efficiency.
The variance would allow
Chrysler
to maintain a competitive position while providing the
time necessary for further development of innovative high solid
topcoat materials
of
acceptable quality and appearance.
Chrysler
asserts that the quality and appearance of automobile topcoats
are an extremely
:Luriportant factor in maintaining a competitive
position in the market place.
Foreign competitors are not burdened
with RACT requirements and have developed durable and glossy low
solid topcoats.
Domestic paint suppliers are
in the process of
developing high solid coatings that have comparable appearance
and durability
(Pet.
p.
5).
Chrysler, in cooperation with
its paint and equipment suppliers,
has been directing its compliance efforts towards the successful
electrostatic application of high solids topcoats.
Chrysler has
expended substantial manpower and economic resources in this area
(Pet.
p.
7).
Chrysler believes that this method is the most
cost—effective way to achieve compliance.
To this end, Chrysler
is planning to install High Voltage Electrostatic Spray
(HVES)
equipment in 1986.
Current spray booth design and layout will
not permit immediate installation of HVES equipment without major
facility reconstruction (Pet.
p.
7).
The Belvidere plant is
being considered as
a site for the introduction of a new product
line in 1986, which will provide the necessary planned downtime
for the installation and modification required for the EVES
equipment.
EVES
equipment can effectively apply high solid
coatings in compliance with the December 31, 1986 RACT require-
ments of 65
transfer efficiency
(Pet.
p.
7).
The only alter-
native to this approach is through add—on control equipment,
such
as afterburners, that would burn natural gas and become obsolete
with the full introduction of practical high solids topcoats
(Pet.
p.
7).
The environmental impact of granting variance appears to be
negligible and in the long run, compliance through reformulation
is
a sounder approach than afterburners.
The variance would
permit Chrysler to continue present operation until the planned
retooling of the facility in
1986.
The environmental harm during
this relatively short period will be minimal
(Rec.
p.
6).
The
only impacts during the requested variance period might be ozone
82-280
3
formation, visibility problems and odors,
Boone County is an
attainment area for all major pollutants and no ambient vio-
lations or citizen complaints have been registered
in the recent
past
(Rec.
p.
5-6).
VOC emissions would not be expected to
impact any attainment area.
The Board notes, however, that VOC
may be transported
100 miles or more and this could affect the
Chicago non—attainment area,
In addition to the installation of HVES equipment
in
1986,
Chrysler plans to ultimately comply with Board regulations through:
1)
continued development, evaluation and testing of high solids
topcoats,
2)
introduction of high solids coatings into production
as soon as these materials are reasonably available,
3) continued
research into
otlier
methods of reducing VOC emissions,
4)
sub—
mital
to the Agency of a more detailed compliance plan as
it
develops and
5)
submittal
of evidence of reasonable further
progress towards compliance.
Chrysler has
in the past diligently sought means to reduce
its VOC emissions at the Belvidere Assembly Plant.
In 1975,
Chrysler reformulated its coatings to nonphotochemical solvents
and achieved compliance with Rule 205(f)
(Rec.
p.
3).
Recently,
Chrysler converted its prime coat and prime surface coating
operations to a new “Uniprime” system which reduced emissions
approximately 130 tons
in excess of RACT requirements
(R.
7).
There is no reason to believe that Chrysler’s conduct in the
future will be any less diligent than in the past.
The Board will grant variance from §214.204(a)(2) until
August 31, 1987,
subject to conditions.
This three year period
will allow Chrysler to install
EVES
equipment as planned in 1986
and to develop and refine high solids topcoat material application.
Denial of the variance would cause an arbitrary and unreasonable
economic hardship when balanced with the minimal predicted environ-
mental harm.
Chyrsier
is moving diligently towards ultimate
compliance and requiring retrofit of incinerators or the immediate
installation of EVES equipment would be unreasonable in these
circumstances.
The Board will impose interim emission limitations
which Chrysler and the Agency have agreed upon at hearing as
being achievable and protective of air quality
(R.
4—6).
In order to avoid permitting problems for the Agency and
Chrysler
in 1987,
because intermediate requirements found in the
Board note
in 2l5.204(a)(2)
were not met, the Agency requests
that the Board state that the Board note is being changed for
purposes of this variance only to read as follows:
The coat limitation
shall not apply if by August
31,
1984 a limitation
of
0.52 kg/i
(4.3 lb/gal)
is
achieved and the top coat is applied with a trans-
fer efficiency of not less than 55,
if by December
31, 1986,
the same top coat is applied with a trans-
fer efficiency of not less than 65,
and if by
62-281
4
August
31, 1987 the top coat shall meet a limitation
of 0.43 kg/l
(3.6 lb/gal) at a transfer efficiency
of
65.
If two top coats are used the above limits
apply to the volume average.
The Board
shall grant this request
in the interests of adminis-
trative efficiency.
This Opinion constitutes the Board’s findings of fact and
conclusions of law in this matter.
ORDER
The Chrysler Corporation
is hereby granted a variance from
35
Ill.
Adm. Code 215.204(a)(2) for its Belvidere Assembly Plant,
subject to the following conditions:
1.
This variance shall be in effect from January
1, 1985
to August
31, 1987.
2.
Chrysler shall meet interim emission specifications as
follows:
Coating Materials
Basecost
Clearcoat
Transfer
(lb./gal)
Solids
(lb./gal)
Solids
Efficiency
Date
Maximum
~
Maximum
Minimum
Minimum
8/31/84
4.3
38
3.6
46
55
12/31/86
4.3
38
3.6
46
65
8/31/87
3.7
48
3.4
54
65
*Average of all colors.
3.
For the term and purposes of this variance only,
the
Board note in 35
111, Adm. Code 2l5,204(a)(2) shall
be replaced by the following:
The coat limitation
shall not apply if by August 31,
1984 limitation of 0.52 kg/i
(4.3 lb/gal)
is achieved
and the top coat is applied with a transfer efficiency
of not less than 55,
if by December
31, 1986,
the same
top coat
is applied with a transfer efficiency of not
less than 65,
and
if
by August 31, 1987 the top coat
shall meet a limitation of 0.43 kg/i
(3.6 lb/gal) at a
transfer efficiency of
65.
If two top coats are used
the above limits apply to the volume average.
4.
Chrysler shall begin use of any high solids basecoat
materials which become available prior to the dates
specified above in Item
1.
62-282
5
5.
Chrysler shall continue with development, evaluating and
testing of high solids basecoat/clearcoat materials and
shall
submit quarterly reports summarizing its progress
in development, evaluation and testing of these materials.
The reports shall be submitted to the following address
within 15 days of the end of each quarter, beginning
January 15, 1985,
The reports, beginning January 15,
1986,
shall include progress on the installation of a
High Voltage Electrostatic Spray, and shall be mailed to:
Control Program Coordinator
Division of Air Pollution Control
Illinois Environmental Protection Agency
2200 Churchill Road
Springfield, Illinois 62706
6.
Chrysler shall continue to study methods of reducing other
sources of volatile organic material emissions,
and
monitor methods for reducing such emissions.
A summary
of its progress in investigation of such methods shall
be included
in the quarterly reports as described
above in Item
3.
7,
Chrysler shall obtain construction permits for the new
surface coating operations before it begins its plant
retooling
-
8.
Chrysler will operate all other sources in compliance
with 35
Ill. Adm, Code 215.202(A)(2).
9.
Chrysler shall provide the Illinois Environmental
Protection Agency with a detailed plan illustrating
how Chrysler will comply with the top coat require-
ments
in 35 Ill. Adm, Code 215.204(a)(2) by
March 31,
1987.
10.
Within 45 days of the date of this Order, Chrysler
shall execute a Certificate of Acceptance and Agree-
ment to be bound to all terms
and
conditions of
this variance.
Said Certification shall be sub-
mitted to the Agency at 2200 Churchill Road, Spring-
field,
Illinois 62706.
The 45—day period shall be
held
in abeyance during any period that this matter
is being appealed.
The form of said Certification
shall be
as follows:
62-283
6
CERTIFICATION
I,
(We)
,
hereby
accept and agree to be bound by all terms and conditions of the
Order of the Pollution Control Board in PCB 84—127,
January 10,
1985.
Petitioner
Authorized Agent
Title
Date
Board Member Bill Forcade concurred.
IT IS SO ORDERED.
I, Dorothy M~. Gunn, Clerk of the Illinois Pollution Control
Board,
hereby certify
that t
above Opinion and Order was adopted
on the
/~2~ day of
_________________,
1985 by a vote of
o
.
Dorothy M.
9tinn, Clerk
Illinois Pollution Control Board
62-284