ILLINOIS POLLUTION CONTROL BOARD
May 11,
1989
NIINNESOTA MINING AND
~4ANUFACTURING COMPANY,
Petitioner,
v.
)
PCB 88—14
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
ORDER OF THE BOARD
(by B.
Forcade):
On March
8,
1989, Minnesota Mining and Manufacturing Company
(“3M”)
filed
a Motion
for Reconsideration or Clarification
in
this matter.
That motion identified certain potential problems
with the Board’s February
2,
1989, Opinion and Order.
On March
27,
1989,
the Illinois Environmental Protection Agency
(“Agency’1)
timely responded.
The Board granted reconsideration,
but ordered
additional memoranda on the matter.
On May
3,
1989,
in response to the request
for additional
memoranda,
3M and the Agency filed a joint response
to the
Board’s Order
of April
6,
1989.
In order
to clarify
their
intent,
and
to ensure that VOM emissions are minimized during the
period
of April
1,
1989 through April
1,
1990,
3M and the Agency
agreed that the Board’s February
2,
1989 Order
in this matter
should
be modified by adding
a new subparagraph
(c)
to Condition
No.
2.
The Board will adopt the requested modification.
The Board
now repeats
its entire Order,
including
the new subparagraph
(c)
to Condition No.
2.
The Board will require
3M to sign and return
a copy of
the new certification.
ORDER
The Board hereby grants the Minnesota Mining and
Manufacturing Company
(“3M”)
a variance from
35 Ill.
Adm.
Code
215.204(c)
and 215.207,
as amended at
12 Ill.
Req.
815,
840—42
(Jan.
8, 1988),
for the period from December
24, 1987 until April
1,
1989,
provided
it fulfills the following conditions:
1.
Compliance
for
Line
6H will
be
determined
according
to
Section 215.204(c).
99—15
—2—
2.
Ninety days after
installation
of new control equipment
on
any
of
Lines
2G,
3G,
4G,
211
and
311
or
upon normal
operation
of
the
new control
equipment
on any
of
Lines
2G,
3G,
4G,
211
and
311,
whichever occurs
first
for each
line:
a.
Volatile
organic
material
from
the
“adhesive
coating” will not by—pass the thermal oxidizers
and
the
thermal oxidizers will achieve 95
destruction
efficiency
on
the
captured
volatile
organic
material,
except
during
malfunction
and breakdown
as authorized by the IEPA operating permit.
b.
Lines
2G,
3G,
4G,
211
and
311
shall
be
operated
to
achieve
at
least
equivalence
with
2.9
lb.
VOM/gallon using
the formulas contained
in
Section
215.207
for
each
product
manufactured,
except
during
malfunction
and
breakdown
as
authorized
by
the IEPA operating permit.
C.
However,
nothing
in
this
Order
shall
be construed
to
require
that
lines
211
and
311
achieve line—by-
line
compliance
with
the
2.9
lbs.
VOM/gallon
limitation
using
the
formulas contained
in Section
215.207
until April
1,
1990 by which time
3M shall
install
a
single
thermal
oxidizer
to
control
solvent
not
trapped
by
the
carbon
absorbers
on
lines
211
and
311
and
to
act
as
a
backup
when
the
solvent recovery units
are down for maintenance.
3.
Control
efficiency
of
the
carbon
absorption
units
on
Lines
211
and
311
will
be
documented
on
a
daily
basis.
The
thermal
oxidizer
to
be installed on Lines
211 and
311
shall
have
a
destruction
efficiency
of
90,
except
during
malfunction
or
breakdown
as
authorized
by
the
IEPA operating permit.
4.
3M
shall
submit
to
IEPA
every
quarter
a
report
describing
in
detail
the progress
made
in
the previous
three
months
in
the
design
and
construction
of
the
thermal
oxidizers
and
the
improvements
made
to
the
carbon absorption units.
5.
a.
Quarterly
reports
shall
be submitted
to the
IEPA’s
regional
office
in Maywood
and
the Permit
Section
in
Springfield
within
20
days
of
the
end
of
the
quarte r~.
99—16
—3—
Illinois Environmental Protection Agency
Division of Air Pollution Control
The Intercontinental Center
1701 First Avenue
Maywood,
IL 60153
Illinois Environmental Protection Agency
Division of Air Pollution Control
Permit Section
2200 Churchill Road
Springfield, IL 62702
b.
The quarterly report shall include
a summary of
the
daily
operations
of
the
coating
lines
operating
pursuant
to
Section
215.207
and
include
the
following information:
1.
Weighted
average
VOM
content
of
coating
(lb/gallon,
less water);
ii.
c~7eighted average
control
efficiency
for
VOM
(percent);
iii
Actual VOM emissions
(lb/day),
iv.
Allowable VOM
emissions
(lb/day)
pursuant
to
Section 215.207;
and
v.
Actual
VOM
emissions expressed
as
percent
of
allowable,
i.e.,
(actual divided by allowable)
times 100.
c.
The
quarterly
report
shall
include
a
summary
of
afterburner
and
carbon
absorption
malfunctions,
with
the
nature
and
duration
of
the
malfunction,
and
a
description
of
measures
taken
to
prevent
future occurrences.
6.
Within
45
days
after
the
date
of
this Order,
3M shall
execute and send to:
Illinois Environmental Protection Agency
Attention:
Susan Schroeder
Enforcement Programs
2200 Churchill Road
Springfield,
IL 62794—9276
a
Certificate
of
Acceptance
and
Agreement
of
this
variance
by
which
it agrees
to be bound by the terms
and
conditions contained herein.
This variance will
be void
if
3M
fails
to
execute
and
forward
the
certificate
within the 45—day period.
The 45—day period shall be
in
99—17
—4—
abeyance
for
any
period
during
which
the
matter
is
appealed.
The
form
of
the
certification
shall
be
as
follows:
CERTIFICATION
I,
(We)
having
read the Order
of the Illinois Pollution Control Board in PCB 88—
14,
dated
May
11,
1989,
understand
and
accept
the
said Order,
realizing that such acceptance
renders
all
terms
and
conditions
thereto binding and enforceable.
Petitioner
Authorized Agent
Title
Date
IT IS SO ORDERED.
I,
Dorothy M.
Gunn, Clerk
of
the Illinois Pollution Control
Board,
hereby
certify
that
the
above
Order
was
adopted
on
the
//~Z~
day
of ____________________________,
1989,
by a vote
of
7-0.
/2
~L
~
~
~
Dorothy
M. qunn,
Clerk
Illinois Pollution Control Board
99—18