THIS FILING IS SUBMITTED ON RECYCLED PAPER

.a.—S ~

CLERKS

OFMCE

JUN

ZUO2

StALE

LLLIP~OIS

)

Pollution

Control Board

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PROPOSED

SITE-SPECIFIC

MR POLLUTION REGULATIONS

APPLICABLE TO HORWEEN LEATHER

COMPANY

OF CHICAGO,

ILLINOIS

35111.

Adm. Code 211.6170

)

R02-20

)

(Site-Specific Rulemaking

Air)

)

NOTICE OF FILING

TO:

Rachel L. Doctors, Assistant Counsel

IEPA, Division of Legal Counsel

1021

North Grand Avenue East

P.O.

Box

19276

Springfield,

IL 62794-9276

Deborah Connelly

JCAR

70 Stratton Office Building

Springfield,

62706-4700

Linda Brand

DCCA

620

Adams Street

Springfield,

62701

Matthew J. Dunn

Chief Environmental Bureau

Office ofthe Attorney General

188

W. Randolph

St. 20t~~

Floor

Chicago, IL

60601

PLEASE TAKE NOTICE

today th

ave filed with the Clerk ofthe Illinois Pollution

Control Board Testimony of Julie M.

ristens

and Arnold Horween

III,

copy ofwhich

is herewith served upon you.

Dated:

June

19, 2002

Roy M. Harsch

GARDNER, CARTON & DOUGLAS

321

North Clark Street

Suite 3400

Chicago, Illinois

60610-4795

(312) 644-3000

ner

THIS FILING IS SUBMITTED ON

RECYCLED

PAPER

KECC1iV~D

(~iERRS QFF

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

2002

~LL.iIM0~

INTHE MATTER OF:

)

IBoard

pollution

LonIro

PROPOSED SITE-SPECIFIC

)

R02-20

AIR POLLUTION REGULATIONS

)

(Site-Specific Rulemaking

Air)

APPLICABLE TO HORWEEN LEATHER

)

COMPANY OF CHICAGO,

ILLINOIS

Ill. Adm. Code 211.6170

)

TESTIMONY OF JULIE M. CHRISTENSEN

ON BEHALF OF HORWEEN LEATHER

My name is Julie M.

Christensen.

After six years of experience in a corporate regulatory affairs

department and

completing my BS Degree in Environmental

Science from Roosevelt University,

I was employed as the Director ofSafety

and Environmental Compliance at Horween Leather

Company on August

10,

1998.

My responsibilities at Horween involve gathering and maintaining all data regarding

environmental

and safety issues, completing

all regulatory compliance

reports and permitting

under the direction ofArnold Horween Jr.

and Arnold Horween III.

As shoemakers

in the U.S.

have decreased, and

tanneries in the U.S. have closed, Horween has

continuously tried to expand the specialty leather production to be

able to

remain a viable

business.

Over two years ago, we began working on this rulemaking to enable us to pick up

business from a closed tannery in Wisconsin.

a consequence of the very slow regulatory

process, leather was produced overseas to

replace this leather.

This

leather is not the same

quality, but it will be

acceptable to the majority of customers,

and it is less expensive.

So this

market may no

longer be open

to us.

We will only know when we actually produce the leather

and try to sell

it.

Because ofthe nature ofour business, it is more important now than ever to be

able to

respond quickly with

samples and new leathers

for customer’s requests.

Therefore, we

are urgently requesting a broader description ofspecialty leather so we can respond quickly

meet the demands ofcustomers

and fill

voids

in the industry.

A lengthy turnaround time is never

acceptable for our customers; they will go

elsewhere, generally, overseas.

explained by Mr. Horween, we have attempted to obtain the approval ofthe Illinois

Environmental Protection Agency (IEPA) to

arrive at an agreeable change to the specialty

‘eather exemptions originally enacted by the Pollution Control

Board in

PCB R93-14.

We have

had numerous meetings

and telephone conversations, responded to a number ofinformation

requests and answered

many questions that IEPA posed (Attachment 2

Testimony).

Having

reached a point of impasse

in terms ofmaking additional progress, Horween elected to

file the

Site

Specific Rule Petition earlier this year.

The proposal was actually filed with the Board on

February

19,

2002, containing a

detailed discussion ofHorween’s operations including

the

circumstances that gave rise to the need for producing additional types of specialty leather.

Testimony

Julie

Christensen

Page 2

also provided 16 attachments to the Petition

to support ourrequest forrelief

Basically, the

agreement we reached with IEPA was embodied in our draft, with the understanding that U.S.

Environmental Protection Agency (USEPA) told IEPA it was acceptable.

The basis for this

agreement was the application of a

limitation derived by the State ofMaine and approved by

USEPA

as RACT for Prime Tanning Company located in Berwick, Maine.

We included the

proposed limitations of24 pounds ofVOM per

1000 sq.

ft.

for water-resistant leather and

pounds per 1000 sq.

ft.

for non-water-resistant leather based on

12-month rolling average.

These limitations

are consistent with our understanding of the Maine RACT determination for

Prime Tanning Company.

It is our understanding that this

RACT limitation was established

through the Title V permitting process.

We have included as Attachment

to our Site Specific

Rulemaking the Prime Tanning Company Part 70 Air Emission License or CAAPP

Permit.

Attachment

is the April

18, 2000 Federal Register document approving this Maine RACT

limitation.

Following the filing ofour Site Specific Petition in

February, there has been a flurry of activity

as the hearing date was established and drew near.

We have had

a series ofdiscussions with

IEPA

and with

representatives ofRegion

USEPA concerning

the appropriate limitations.

Also,

complicating

the situation, USEPA has adopted a National Emission Standards for Hazardous

Air Pollutants (NESHAP) that applies to

leather coating which I will discuss

later.

a result of this activity,

it is

our understanding that IEPA will today submit proposed revised

Site-Specific Rulemaking language for consideration by the Board

as an alternative to what we

originally proposed.

Horween had

a limited

opportunity to

review this proposal.

We generally

find

it to be

acceptable with two major reservations.

These two exceptions

concern changes to

the recordkeeping and reporting obligations

and a requirement to utilize high volume low

pressure (HVLP) spray guns.

I will first address the reporting and recordkeeping requirements

that IEPA included in Section

218.929(d) oftheir Rule.

Our differences of opinion concern the reference to

the words “by

batch” in

subpart

We believe that the inclusion of this language would

require a substantial

modification to the recordkeeping and reporting procedures that Horween currently

follows.

March 4,

1996, Horween submitted an amendment to

its RACT Certification describing a more

efficient method of recordkeeping and demonstrating compliance with 35

III. Admin. Code

21 8.926(b)2(B).

A copy ofthis

submittal is found as Attachment ito this Testimony.

Horween

has been using this recordkeeping process since 1996 with the Agency’s full knowledge.

This

same recordkeeping process is found in

our CAAPP Permit in Section 5.6 General

Recordkeeping Requirements and 7.0 Unit Specific

Conditions.

It has therefore been approved

by both IEPA and USEPA

to demonstrate compliance with the existing RACT rules.

new

regulations have been promulgated, the records have been expanded to meet the new standards,

i.e., seasonal emissions of VOMs (ERMS) and HAP emissions (NESHAP).

in the past, the

recordkeeping will be

expanded again to document

the leathers that are addressed in

this Site

Specific Rulemaking.

I truly believe this is the most accurate and by far the most efficient

method ofrecordkeeping

to demonstrate compliance with

all of the RACT rules.

Testimony

Julie M.

Christensen

Page 3

Briefly, Horween’s recordkeeping process involves inventory records and production records

that are maintained in the specific departments,

i.e., Finishing,

Cordovan, Pasting, and

Maintenance.

These departments record their chemical usage and report this usage

to the office

a weekly basis.

This data is entered into the computer monthly

forcalculations of total VOM

and

HAP emissions.

Because we do not have specific point emission sources (stacks) for

measurement in

the various departments, we assume all VOM and HAYs

from the finishes are

emitted

to the atmosphere.

The production records are also

forwarded to the office on

a weekly

basis.

The square

footage ofthe

side leather is determined by

a three-year rolling average of

leather measured in the Shipping Department.

Calculations are then completed for square

footage ofthe various leathers

finished, categorized by the correct

category of leathers, i.e.,

Specialty, Standard Non-Stain,

Standard Stain, Water-resistant, or Nonwater-resistant leathers,

and VOMs

and RAPs per

1000 sq.

ft.

are extrapolated.

Recordkeeping for these new specialty leathers would be set

up with their own category, i.e.,

Specialty II Leathers,

fui-ther broken down into water-resistant and non-water-resistant leathers

(as they are listed

under NESHAP),

and all finishes would be tracked separately and applied

the square

footage of these leathers

(Attachment 2).

Horween submitted comments

to USEPA

regarding the proposedNESHAP.

One ofour

comments regarded the complexity ofrecordkeeping under the proposed rule.

We requested

simply adding the HAP information to our current recordkeeping.

In the final rule,

Section

our concerns were

addressed by “already maintained purchase and usage records

are all that will

be needed to demonstrate

compliance.”

On March

13,

2002, I spoke with Bill Schrock,

USEPA’s technical person who developed the NESHAP, to confirm that our existing

recordkeeping would be satisfactory to

the USEPA.

He reiterated that the way we document our

finishes with

inventory usage records

and production records is fine.

The recordkeeping shown

in the NESHAF standard was meant only

as an example.

Furthermore, In Prime Tanning/s Air

Emission License, the Recordkeeping/Reporting section describes the same basic process that we

currently

use.

In summary, we are

in agreement with IEPA

Section 21 8.929(d)( I) draft with the removal ofthe

language “by batch” and would

therefore ask the Board to delete these two words as unnecessary

assure compliance.

The second issue I want

to address stemming from IEPA’s proposal is the request by Region

USEPA that the relief for these two new specialty leathers be predicated on Horween’s

employing the use of HVLP spray guns.

During discussions with IEPA and USEPA, concerns were

raised regarding HVLP

spray guns

for our spray finishing machines.

After discussing this

issue with

many finish providers and

tanners, we are all in

agreement that these spray guns will not

work for our leathers.

Problems

arise because there would be less

atomization of the finishes and less penetration into the

leather.

The finishes would lay-up on the surface ofthe leather, and our facility does not have

the

space capacity for longer drying runs.

The leather would stick together as it is stacked after

spraying,

and the finishes would be ruined on

all ofthe leather.

HVLP

spray guns are generally

Testimony

Julie

M. Christensen

Page 4

used for garment and upholstery leathers; not shoe leather.

However, we are borrowing a

spray

gun

to try our various

finishes on our leather in our sample booth today, June

19, 2002.

addition, we have contacted the salesman that Gary Becksteadt,

IEPA, suggested we contact for

the new technology spray guns.

However, as Mr. Becksteadt

stated, these are not

HVLP spray

guns.

Our spray machines use Binks model

AR automatic air spray guns with ratchet needle

adjustments.

The two

air compressors for the big

spray machine and small spray machine are

100 psi

and

115 psi

respectively.

The actual spraying pressure is adjusted to approximately

psi depending on the finish.

Both our spray machines are

set up with water curtains and

electronic eyes to reduce the amount of finish

overspray.

Our aniline finishes are sprayed on

with multiple, extremely light coats rather than high volume (HV) coats.

Horween is a very small tannery that

finishes leathers on

all the lines that are available.

We only

have two spray machines and we need to be able to spray

all of our leathers on either ofthese

machines.

We cannot dedicate one entire spray machine to

only these types ofleather.

Not to

mention that the HVLP

spray guns would only work on the stain coats which we already brush

on in many cases.

Spraying,

even with HVLP

spray guns, would produce more atomization and

emissions than using our brush finishing machines and swabbing the stain coats.

Therefore,

we request that

IEPA Section

21 8.929(c)(4) regarding the HVLP

spray guns be

removed from the draft.

There are several other points that I would like

to make regarding the proposed alternate Site-

Specific Rulemaking language submitted by IEPA.

In Section

2 18.929(c), IEPA proposes that

Horween have standard operating and maintenance procedures or SOMPs in

place.

As we stated

in our April 22,

2002,

letter to Mr. Dick Forbes of IEPA, Horween has no objection to the

inclusion of SOMPs in the Rulemaking although we feel that

is redundant as these would be

required as part ofthe Title V Permit requirement.

Horween has always had procedures in

place

minimize the volatilization of solvents as set forth

in Attachment 2

the Testimony.

It is our

understanding that the SOMP provisions

found at subparagraph (c) subparts

1, 2

and

do not

require any additional

steps beyond those

currently in place

at Horween.

The

first date for compliance

as far as recordkeeping with the NESHAP is February

28, 2005.

Combining our various leathers, while

adjusting

our finishes, may enable Horween to meet the

NESHAP regulations that are

5.6 pounds per 1000

sq.

ft.

for water-resistant leathers and 3.7

pounds per 1000 sq.

ft.

for non-water-resistant leathers, provided this

Site Specific Rule change

is adopted and USEPA modifies its reference

to specialty leathers.

During 2001

our HAYs averaged 6.75 pounds per 1000 sq.

ft.

for water-resistant leathers and

4.39 pounds per 1000 sq.

ft.

for non-water-resistant leathers.

In January through May of this

year we are averaging 4.98 pounds per

1000 sq.

ft.

for water-resistant leathers and 2.34 pounds

per 1000 sq.

ft.

for non-water-resistant leathers.

As this

shows, Horween is

continuously

adjusting finish components to try to

reduce both

VOM and HAP emissions, while maintaining

our high standards of finished

leather.

Testimony

Julie M. Christensen

Page

As an

explanation ofour limits, we are allowed the following VOM emissions in our Title V

CAAPP Permit:

EMISSION

SOURCE

VOM EMISSIONS

Specialty Leather

Not

to exceed 38

lbs./1000 sq.

ft.

Standard Stain

Not

to exceed

10 tons per year.

Standard Non-Stain

Not

to exceed 3.5

lbs/gallon as applied.

Specialty Leather,

Standard Stain,

Miscellaneous (including cleanup)

Not

to exceed 8 lbs./hour from individual units.

Cordovan

Not

to exceed 8

lbs/hour,

3 tons/year, and

tonlyear/source.

Cordovan, Miscellaneous

(excluding cleanup)

and Pasting

Not

exceed

5 tons/year combined.

Pasting Room Dryer

Not to

exceed 0.25

tons/year.

Source-Wide Emissions

Not

exceed 99.12

tons/year.

Through the ERMS program, the total baseline emissions

for Horween are 28.1

tons per season

or 281

Allotment Trading Units (ATU5).

As you can see by our recent usage of ATUs, we will

hopefully be

able to sell or retire 300 ATUs this year:

YEAR

ATUs

ATUs

TOTAL

ATUs

USED

ATUs

BALANCE

RETIRED

FINAL

BALANCE

2000

281

281

 -192

89

0

89

2001

—

281+89

370

 -158

212

0

212

2002

 281+212

493

The last point that I want

to address is the issue ofNESHAP recently enacted by USEPA.

The

NESHAP was enacted on February 27, 2002, and is

found at 4OCFR Part 63.

As previously

stated, we worked closely with Bill Schrock of USEPA during the formulation of this standard.

We supplied USEPA with

a series ofcomments and answered

a number of technical

questions.

USEPA’s consultants, in fact, physically visited the Horween tannery.

a result ofour

involvement, USEPA has included recognition that Horween’s operations are unique.

Basically,

USEPA has combined all of Horween’s specialty coatings into the water-resistant category in

order to provide Horween with

a higher allowable HAP content for specialty coatings.

Notwithstanding,

this effort by USEPA, Horween was unable to comply.

Accordingly, Horween

filed a Petition

for Review ofthe Leather NESHAP Standards to

address the specialty leather

issues

and the limits

assigned to water-resistant and non-water-resistant leathers.

Our lawyers

have entered into

settlement discussions with USEPA, which resulted

in USEPA petitioning the

Appellate Court to

stay filings

in this proceeding while we attempt

to resolve our differences.

We are hopefUl USEPA will agree to

modify the NESHAP to refer to specialty leathers as

regulated by the Pollution Control Board,

including the two

new categories of specialty leather

we are seeking approval for in this proceeding, rather than referencing the 25

percent oils,

fats

and grease content

as currently contained in

the NESHAP.

We are

also hopeful USEPA will

Testimony

Julie

Christensen

Page 6

determine to proceed with the delisting of ethylene glycol monobutyl

ether acetate

(EGBE)

(CAS No.

112-07-2) which

is the principal HAP solvent that subjects Horween to the NESHAP.

Horween has proven

itself to be very proactive in trying to

reduce and eliminate emissions of

VOMs and RAPs.

However, because this is a specialty job shop, we need to expand our

definition of specialty leathers by

adding this Site

Specific Rulemaking.

Through these proposed

additional categories, Horween will have the ability

to produce new leathers to meet

customer

demands, while complying with Federal and State Regulations.

CHO 1/12 232320.

JLtl—17—2002

16:24

F-IORt,JEEN

LEATHER

CD.

773

772

92~

02’03

GARDNER,

CARTON

DOUGLAS

SUITE

3400-QUAKER

TOWER

321

NORTkCLARK

tTREET

WRI?Ew$

PIRECT

UJAL

NUMSER

C~.fiCAG0,

ILLINOIS

60C

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WASNINIOTON.

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544.3000

ROBERTA M.SAIELLI

TEL!X;

25•3628

QI2) 2454769

TELECOPICR:

3 IZI

b44~3Sl

•

~g96

March

1996

LLtNC~

Mr. Bharat Mathur

Division of Air Pollution Control

Illinois Environmental Protection

Agency

1340 North 9th Street

Springfield, Illinois

62702

Re:

Recordkeeping for VOM Emissions

Dear Mr. Mathur:

Pursuant to

111. Admin.

Code ~2l8.99l(b)(l),

1-lorween Leather

Company

(“Horween”) previously submitted its certification ofcompliance with RACT regulations

pertaining

to VOM emissions from

its leather coating openitions.

Over

the past year. Horween

has kept records in

accordance with that certification.

the course of keeping those records.

Horween has developed

a more

efficient method ofrecordkeeping and demonstrating compliance

with 35

II!. Adinin.

Code §218.926(b)(2)(B)(Speóialty

Leather).

Therefore, by this letter.

1-fonveen

is amending its

RACT Certification with respect

recordsrequired by

 III. Admin.

Code

218.99l(d)(2)(D).

Horween will demonstrate compliance with the limit

set forth

in Section

21 8.926(b)(2)(B)

(33 IbVOM/l

000

ft2)

and will

calculate the area ofspeciuity leather flnished as

described in this letter.

1-lorween will caleülatc.an average side size, bused upon data gathered

over thepreceding five

(5)

years.

The square footage measurements are

made at the time of

shipment, after trimming the leather, when Horween measures each side

with an electronic

measuring device.

The average side size will

be adjusted annually each January by recalculating

the average based upon the immediately preceding five years of data.

Each month, Horween will count the number ofspecialty leather sides finished.

Horween

will multiply the number of specialty leather sidestinished

per month

by the calculated average

square

footage to obtain the total square footage finished per month.

Sides at shipment

are smaller than

sides at the time finishing is completed because excess

leather is

trimmed

from the sides after finishing and prior to shipment.

Using the

size of sides at

PAGE

213

RCVD

6117?2002 4:03:15

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/ /

‘Mr. Bharat Mathur

,‘

 March4,l996

Page 2

time ofshipment to calculate the avenge side

size

wi!

result

conservative estimate of the

pounds ofVOM

per

1000

square feet.

other words,

because

the

square

footage of

sides

actually

 finished is larger than the square footage ofsides shipped, the pounds ofVOM

per

1000

square

feet will be recorded as higher than

 it would be

if the

finished sides were individually

measured.

 Thus, this method of demonstrating compliance

will ensure that

emissions ofVOM

containing material

will

remain

well within the

limit

set

Section

21

S.926(bX2)(B).

Finally, to demonstrate compliance, Horween will take the total pounds ofVOM as

applied to specialty leather permonth

and

divide that

by the

total

sqwire footage calculated to

determine compliance with the 38 1bVOM/1000ft2 limit. Horween will continue to keep the

records of VOM usage as specified

its previously submitted RACT C’-~riificaüon.

Horween believes thai

this amendment of its RACT

Certification will result in more

efficient recordkeeping, while allowing Horween

tocontinue

to demonstrate compliance with the

leather coating RACT rules.

Horween will also submit under separate cover,

an Amendment to

its Clean Air Act

Permit Program permit application, setting forth this method ofrecordkeeping.

Ifyou have any questions, please contact me.

Very truly

yours,

S~flLSS/~

RobertaM, Saielli

cc:

Arnold Horween Jr.

Tom Culliton

Chrirtop1-.~r

Ronmine

Roy

Harsch

PAGE

313

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CHICAGO,

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Aptil 22, 2002

Mr.

Di*Fottes

IU~Is

Enàormrntnl Pxtt~tion

Agaicy

Air

Quality Planning Section

POBox 19276

Springfield. iltiS

62794-9276

Dear Mr.

Forbes:

During the

cac&rencc call on

Apr11 12,2002, the lISt

Emiromrtntai pn,tcctiàn Agency

(“Agcticfl requested

Horween

to respond lnwtb$ag to potts ‘we

raised

re~cvtht

to the taft

nile

prepared by

Mt Doctors~This letter is

WTIUCII

WOVIdC

the nquesWd itthrni&n.

Sedion2lt929(a)

we discussed, only a

portion

ofS ne* lçather Ron~tes

wilt produce L~ofIS

xit

au~d

~tegory.

The ~4Qezitrf

f1.sc,tjxal~t

stuffed, is c&oine tamed,Sk/po~rncr

retannal leather that

ii finished with coatingmaterik containing n~er-entukffied

ngtaiak usingwata-mictic solventiflatthWsto protect the teatherand pigmented

coating.

ApIn~

I would l&e

te~

Urn

weited both the

“Cementabl, Shoe Leather”

and

the “Dress orPerfrrmanct

Shoe LearhW’

categories ofleather accepted.

The

Mactar flexes can test on!y the water-resistant leather.

The other leaThers will be

identified by:

finishing

wth water e iutád

niaseclals to meet

path

LUXaSO

soaking and franlig;

2) a

flit,

dressy

or 3) usb~

a mass

P*laneethnnut for

addkioa

ofwax,

grease, polymer, and ails.

Horwee~

 ccnttuse the pcoposedtestnrhod forhot

stu~dleather.

Horwccn adds a

specific quantity o’fwet kattc’, withknown mobtwe eantent, to

the

ljaaiS nil

and

adds a

spai& quantity

ofwax, greaie, po~yre,and oils

to be beaten

lizo the leatha.

Tic ntcnal

leather may or may

itt

haw

.IMt4nnal wax, gr~sc,polynn, aix! oils

edded

tube

equentlxt

roller.

Horwe~t

docs nothave the ability

weigh the leather befl,re

after the lubrication stqm. tzrcfoxc

Hvrwcaz pruposcsto continue to t~ethe

natnlsl haute

approach

con~w1ng

Ut weight

leatJ~

dxy-wdjht haS

the

weight

of’wwc,

cease, po’ymer,

and

oils

added.

LL~’r.~=rn!

nFc-22—2222

14:

~‘?

R~W~N

CD,

‘773

‘772 S2~

P. 03/09

Mr.

DickForbes

Apnl2Z2002

Page

Twv

Mass ~1nt

fixnila fir wax, gree.

polymers, nth oils, adde&

12PCS

Whn:

P~W1Lx1QO

P-Percait content

ofwax, pease,Miner,

end oils

L0xy weight ofleather

bethre addidonofwax

grease, poser,

and

oils

W-Weigbt ofwaiç gretta,

pobwth,

and oils th pounds added to leather

Section2l&929 (1,)

Testing

ofLeather:.

As we explained,

S is not physically poaSble to test

the leasher as water-rasSant in the

COlOr

Dcper~aent,

The leather is still wtt: Honn

proposes that sar*s oftim leather

will

be tested ftfttr it has been

firletS

according to ASTM StandsdD2O99-O0~

meet

the definition of water-resistant, the results‘mn~

be grater thanor equal

to 5,000

Meeser

a side issue,

IIQrVQCCn explained that ifs particular lCch

wetcr-rcsis~nt

lcat&r in

thet fblbl this lest, the batch wvuld have to be recorded and the

VOM applied to the

non~ter-

resistant accounting records.

In reviewing the Priar T—’dng Company

ir Emission Liccz~c.watcrptoofleather is

Mdn~sar

inthe cobring room.

This

data not

mean it

is tested at this locatiàn.

Our

leather is

dSgaateif’ in the Splitting Depétment by

a sorter as to what quality and type

ofleather ft struM produce.

I might add

—

our teather Is me~ured

afior It tins goit

through

nIl processing, daying, shrinking, fimW,iv_

Ui..s.s~

when it is ready

ship.

Section 21t929(c) Standard opetuting

and

~Senanee

procedures (SOMP)

Bnodujc

owdiacu~n,

we ux4erstsn

US.

EPA

would

preferto sees

SOMP

included inthe Me.

Horweentat

ol*xtkmto

briuslunof a SOMP.

Horween has

alw’qs had procedures

th m~nin4.e

lbs volatilithbu of solvezis.

The plant’s

jt,.n,4~d

operatingproce&es inrjude ...t.1...b4ng

~Ses

VOli4s by keepingcoztainers closed

during storaze.wben act adding

or rtniovinè materials, and keeping coating containers

securely ck,sed dw*~g

tranpoil and use.

BOrween Leather utilix~s

electS

ayea,

spay

gn~and water

aflii~e

Onotr

two ~

mSbives to rrthiintht VOM losse&

Thsaa

procedures serve two

purposes: rn~m~ing.YOM

anhissioth,

8114

saving ntncy.

Solvent

cleanup

kept at a

.........

withthe MlacWieous

Emission Units In the

Title V

Penrit

and

lnndling

of ucivents

is covered bow Fire Prevention

Plan 53

El-Cl

PPR—22—2~2

1417

-~taEENLEPTI-ER

CO.

‘Tn

772 92~

P.04/89

Mr. Dick Forbes

April 22, 2002

Page

Three

order to

use the high vohinr low-prewat (HVLP) spray guns, our complete spraying

system

would

haveto be eSiged, 4~~’&ng

kltent

aft co~

~~aofl

~r ott

Hit.

Tine

spray gunswould

ixil

work fir

dmi~ii

a and on

nil ofow lShem.

lit

finish

would be

too thick

some leatirn and the HVLP spray guns would phyaally ~n

the

lightweight leathn

SectIon 218.929(d)

Horween has no

objection to incorporatingiS

~andard recordlceepirig aid compiinnce

ccrti&aSn process izzto~tbe

rule.

we4l.ninM,

(-lorween has in place a

.rtcm

that

believes complies with recordkeepbg requkementt

To detnonstrate :on~Enz.

addklonal ~w

categories of leathers midfiSts

will be addedas production begins using

Micady mabtalnal purchase and use~e

redords (us acceptedby the USEPA NESHAP

Final Rule, 40 CER 63. under F. RFA,

9161

in the

FednWRqIW).

liorween will

record the

rwv—

of leathers andthe jroducts used to finIsh them will be designated ~

category.

The Finishing Depart~rtInventorlesthe product used and the leather

produced

during the month,

This inrth

on istrwarded to the

office.

The

office Ins inventory booksthat are checked against purchase and usagn records and

usage inlbrmnfinnis entered

~,reidabeet.The flAPS

and VOMMaiza

contains

the product ~nt

gaflons used monthb’, sèearnafly, and snnually nrkWedl~

the

demslly flies

pounds ofproduct used.

This multiplied thin the percent VOM In

the

product gives the pounds

VOM emitted monthb’.

seasonalbt and )tart,’.

The “as

applied?’ without waxer ctulation

for

the

rodncts is only documentedfor the product

used

Standard

Non-Stain

1ea~s. The ipeei& products arc used only on certain

leathers and

are ciateacSed accot~,

Qnreutbr there arc

45

Jcathei,

dim

rettw

Standard Stain aM/or Standard Non-Stain

5thhes~and

Specialty lesthen.

Inthnn.tlr.sxfrom

the FlnIsthg Deportment

is entered

into several spreadsheets

(HIPS

wadJDMMzne’,

Lea/bc hothtfion,

ieciaity

Leathersand

VOids

per

1(100

514

Stain Coat

Jo1Th~g

Awmge,

and

&an~4

Ncn&nln

Coatings)

to document compliance.

With

a1d.in~

very little 4ditio~l

htmngt

itt:

~vc

j~~j

rli.ny.iJ

to also

provide docwnontatlon for NESHAP. flea