ILLIWOlS POLLUTION CONTRUL BOARD

May 18, 1984

ALLIED HASTINGS BARREL

)

& DRUM SERVICE, INC.,

)

Petitioner,

)

V.

)

PCB 83~119

ENVIRONMENTAL PROTECTION AGENCY,

)

Respondent.

MR. ANTHONY J. VENTRELLA,

ATTORNEY AT LAW,

APPEAREb FOR

THE

PETITIONER;

MR. PETER

E. ORLINSKY, ATTORNEY AT LAW, APPEARED FOR THE

RESPONDENT.

OPINION AND ORDER OF THE BOARD

(by J.

D. Dumelle)

This matter comes to the Board on an August 22,

1983

Petition for Variance and January 5,

1984

Amended Petition for

Variance filed by Allied Hastings Barrel and Drum Service,

Inc.

(Allied). No objections

were received and no members

of

the

public testified at the March

2,

1984 public hearing in Chicago.

The Illinois Environmental Protection Agency (Agency)

filed a

recommendation on February 4,

1984 that variance be granted

subject to certain conditions,

Allied owns and operates a facility located in

the

Chicago

Metropolitan Area, within Air Quality Control Region 67, at 915

West 37th Street, Chicago. Allied produces reconditioned steel

drums to which coatings are applied as an integral part of the

manufacture.

The facility employs approximately 45 people and is

located in an industrial, commercial and residential area,

The

facility reconditions both open head and

tight

head

drums.

Open

head drum reconditioning involves removal

of

paint

and

residue

by

burning,

shotblast

cleaning,

and painting.

Tight

head

drum

reconditioning involves removal of

residue

by

washing

and

painting.

The

painting

process

utilizes

spray

booths

and,

uncontrolled

drying

ovens,

The

refurbished

drums

are

used

for

storage of

insecticides,

fungicides,

flammable

liquids,

poisons,

food products, and other materials

(Pet. ¶

1, Rec,

¶

3),

58413

---

JUL’eJ

h~5its

i’~is

inable

to

comply

with

Lbs

Volatile

Organi

~o~c

~VOC)

If

intations

of

35

111.

Mm.

Code

215.204

(j),

which

t&’aT~Cefis:tive

Decxanor

31,

1983.

Allied

requests

a

variance

trot

tiost

lrnstarions,

anc

ancillary

requations,

until

December

al,

19Q5,

The

rugulati~ns

from

wtich

‘s:iis~e

is

requested

ar~ as

follower

CJrzenL

Old

35

Ill.

Mm.

Code

th~ter2

Substance

215.204(j)

Rile

205(N)(1)(j)

Sets

maximuo

VOC

content

of

coatings

215

Appendli

Ruie

iU4ihhl)

Riquizes

Can

liance

Plan

215.211

Rile

205(j)(1)

~npliance

Date of

Decthber

31,

1983

Section

21S.204(j)

sets

limits

on

the

VOC

coatent

of

coatings

u-ed

by

Allied

as

follows:

exterior

(extreme

performance)

coatings

3.5

lbs

VOC/gal

interior

(clear)

~.oatings

4,3

The

VOC/gal

Allied

c’tilire.2

o~er

0

litiarent

types

of

coatings.

In

1983,

Allied

used

~0

/25

gallon.)

of

exterior

coatings

with

an

average

VOC

ccntent

of

4.26

lbs/gal

and

3425

gallons

of

interior

coatings

with

an

&erage

VO~content

ot

5.08

lbs/gal

(Rec.

7

5).

Thus,

Allied

a

pre~ent oper~~tlor a

e

not

in

compli&ce.

Ill

~s

~.

p

~es

t

ad

~e’e

Itimate

compliance

by

reform-

ulation

Cf

coatings~

It

is

likely

that

Allied’s

coatings

vendors

will

achieve

reductions

in

the

VOC

content

of

acceptable

exterior

coatings

~o

z~vels bob”

cn’rpliance

with

the

regulatory

limits

before

redactions

In

VOC

colteoL

of

acceptable

interior

coatings

to

acLfcv~ Lompli~nce with

ate

regulatory

limts.

Therefore,

allreh

~.

1xsez

tc

r~C~’is

..

VL~C content

of

the

exterior

ccat~nqs

A

nod’s

oragi~~l ?e~tion

and

the

;g°rcy

recommendation

request

vacia.ce

until

December,

~985.

Allied’s

Amended

Petition

reque”ts

~~iorce

until

Cs

~embei,

1983.

The

Bcard

presumes

the

December

s33

date

is

a

typographical

error,

sinc

the

rules

first

oecaie

cffe-t~va

on

that

cate,

2

~iUueh

Allied

~ecuas-ed

the

Variance

from

Section

215

Appendix

the

appiicse

Section

for

Compliarce

Plans

is

215. 212.

58414

---

to

levci~

e!ow

tJe

~egu~atc~rj

~eq’~iremsrit

of

~

th&/gal

by

the

end

of

~

xL~~ce

period

ard

nidmately

~cniP~

?U11

compliance

by

irtt~r.

~.l

c~f~acs~

Idied

anticipates

the

foi~c~nngcoatings

usage

cn’

~OC

i~iorn~ ~“o.

~et~

p~ 25)

d:~ricg tho

Variance

period:

Gal.ons

VOC

984

Units

~n

content

F~nissi~

I~terior

306,000

21,550

4~13lbs/gal

89,000

Interior

52,000

3,635

5~08lbs/gal

J~Q~

~Ibta1

107,290

1985

~cterior

318,000

20,000

3~7lbs/gal

74,000

Interior

59,000

4,105

5~0lbs/gal

~91Q~

~bta1

94,530

Allied

has evaluated coatings

in

the past that have

lower VOC

content

(P0

11—13,

Am0 Pet0

~

39~58)and

intends to continue

such

efforts0

Allied

has

evaluated

other

potential methods

of

compL~snce

includin~

fume

incineration,

carbon

adsorption,

condensation,

electrostatic

painting

and

afterburners

(Am0

Pet0

pp0

26~38~

Allied

clairas

each

of

these

options

is unworkable

due

to

extremely

high

costs,

technoloqica!

problems,

or lack of

space0

Coating

reformulation

is

the

only

practical

solution0

Based upon the relatively low level

of

total VOC emissions

(about

50 tons per year~,the lack of

complaints

from

area

resider~’

tha

Agency

r

bei~e~that

the

granting

of

variance

~should

r~t

cause

any

ir~ereased health

effects,

and

the

fact

that

Allied

must

compiy

with

its

ozone

episode

action

plan,

the

Board.

finds

that

the

adverse

environmental

impact

of

the

grantina

of

variance

should

he

minimal

(see

Pee0

~

13—i5)~

The

Boara

tnerefore,

Iinw~ chat

immediate

complianr~e with

Sectioa~

2~5

212,

215~21i,

and

2L50204(j)

would

a~apc~e

an

arhitra~v

~nd

an~nasonabe

ha~d~hipon

Allie~L

Thc

Board

will

impo~

a~ eonciticns

of

ths

variance

Allied’s

astamated

VOC

content ~

rep;~ting

and

permit

conditions

requested

by

the

Agency0

Dtt~

~~fl1O!L

~ons~itutea

the

Board’s

findingo

of

facts

and

conclus

~rn;

_f

l~twin

this

rt~ne~

Ailici

dn5~ings

darrth

and

Drum

Service,

Irio

~s

hereby

granted

a

va~:ianoe

froni

35

IlL

Adm0

Code

215~2ii,

215~212,

and

215e204~J~,

s:thject

to

the

following

conditions:

---

1.

This

;ariane

wilL

e~pi_e on

December

3’,

1985.

7,

~ring

the term of thrs variance the annual

average

Loatthgs

VOC

content

shall

not

exceed

the

following:

1984

1985

~cterior

4,13

lbe,gal

3.7

lbs/gal

Interior

5,08

lbs/gal

5.0

lbs/gal

3,

Within

45

days

of

the

Board’s

final

Order

herein,

and

every third month

thereafter,

Allied shall

submit writ-

ten reports

to the Agency detailing all

progress made

in achieving compliance

with

Section

215.204(j).

Said

reports shall include

informatior

on the

names of re-

placement coating and the manufacturers specifications

including per cent solids

by

volume

and

weight,

per

cent

VOC by volume

and

weight,

per

cent

water by volume

and

weight,

density

of

coating,

and

recommended oper~

ating

parameters:

detailed

description

of

each test

conducted

including

test

protocol,

number

of runs, and

complete

original

test

results:

the

quantities

and

VOC

content

of

all

coatings

utilized

during

the

reporting

period;

the

quantity

of

VOC

reduction

during

the

reporting

period’

and

any

other

information

which

may

be

requested

by

the

Agency.

The

reports

shall be sent

to

the

following

iddresses:

Environmental

Protection

Agency

Division

of

Air

Pollution

Control

Control

Prqrams

Coordinator

~200

rharchid

Road

Springtield,

IL

62706

Environmertal

Protection

Agency

Division

of

I

r

Poll

ition

Control

Region

1,

FLeld

Operations

Section

1701

South

First

Avenue

Suite

600

Maywood

IL

60153

4,

Within

45

days

of

tie

Board’s

final

Order

herein,

Alliea

shall

aoply

to

the

Agency

for

all

requisite

operating

permits

pcrsuant

to

Section

201,160(a),

5,

Within

45

days

of

the

Board’s

final

Order

herein,

Allied

shall

ex~cate

a

Certification

of

Acceptance

arid

Agreement

to

be

hoand

to

all

terms

nd

conditions

of

the

variance,

Sad

Certification

shall

be

submitted

t

both

the

Agency

at

the

addresses

specified

in para-

graph

4,

The

45

day

period

shall

be

held

in

abeyance

during

any

period

that

this

matter

is

being

appealed.

58~

116

---

I,

(~1

e)

________________________________________

having

read

the

Order

of

the

Iliino~s

Pollotion

Control

Board

in PCB

83—119

dated

May

18,

1~84~~

understand

and

accept

said

Order,

realizing

that

such

acceptance

renders

all

berms

and

conditions

thereto

binding

and

Petitioner

By:

Authorized Agent

Title

Date

IT IS SO

ORDERED.

Board Member Bill Forcade concurred.

I, Chr~stsnL.

Moftett, Clerk of the Illinois Pollution

Control

BO&Td~

hereby certify

that

the

above

Opinion

and

Order

was

adopted

on

the

L~~dayof

~

1984

by

a

vote

of

Christan L. Moff~’~,

Clerk

Illinois

Pollution

Control