ILLINOIS POLLUTICN CONTROL BOARD
December 5, 1986
PETITION FOR SITE—SPECIFIC
VOLATILE ORGANIC MATERIAL
)
EMISSION LIMITATIONS FOR
)
R85—28
NATIONAL CAN CORPORATION
Proposed Rule. Second Notice.
OPINION AND ORDER CF THE BOARD (by 3. Theodore Meyer):
This matter comes before the Board on a November 8, 1985
petition for site—specific relief filed by National Can
Corporation (National). National requests site—specific relief
from 35 Ill. Adm. Code 2l5.204(b)(3) which provides that interior
can body spray coating materials contain no more than 4.2 lbs of
volatile organic material (VOM) per gallon. National seeks to
increase this limitation to 5.8 lbs of VOM per gallon for the
interior can body spray coating materials used at its Rockford
plant. This increase would be accomplished by amending 35 Ill.
Adm. Code 215.206 “Exemptions from Emission Limitations” to add a
new subsection (c) applicable to the Rockford plant.
Hearing in this matter was held on February 4, 1986. Briefs
were filed by National and the Illinois Environmental Protection
Agency (Agency) on March 25 and 26, 1986, respectively. National
submitted a reply brief on March 31, 1986. The Department of
Energy and Natural Resources issued a negative declaration on
June 9, 1986 and the Economic Technical Advisory Committee
concurred with this finding at its June 20, 1986 meeting.
First notice was proposed on September 25, 1986 and
published at 10 Ill. Beg. 17959, Cctober 17, 1986. Two comments
were received by the Board during the first notice comment
period.
One comment was received from the Secretary of State
concerning incorrect labelling of the subsections in proposed
Section 215.206. These ccrrections have been made at second
notice. Additionally, a comment was received from the Agency in
response to a Board request at first notice that the purpose and
effect of subsection (c)(2) be clarified. The Agency has
indicated that National must demonstrate compliance under Section
215.207 using the applicable limitation contained in Section
215.204 (4.2 lbs/gal), in addition to complying with the
limitation in subsection (c)(1) of 5.8 lbs/gal. The Board has
proposed substitute language in subsection (c)(2) to clarify the
intent of that provision.
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The details of this proposal were extensively treated in the
Board’s first notice opinion and order in this matter of
September 25, 1986 and will not be repeated here. At issue,
essentially, is National’s manufacture of three—piece steel beer
cans which must be coated with an “interior body spray” to insure
that no adverse reactions take place between the cans and their
contents. VOMs are emitted during the coating process. Because
National has the only three—piece steel beer can plant in the
nation and because flavor preservation is so critical, National
has been unable to secure an acceptable compliant coating. It
was estimated that the cost of control technology would be
approximately $6500 per ton of VCM controlled. The facility is
located in an area which has been classified by USEPA as “cannot
be classified or better than national standards” for ozone. The
Board found at first notice that no measurable environmental
benefit would accrue by requiring the addition of control
technology since National demonstrated that its excess VOM
emissions amount to no more than thirteen pounds per day over
less than forty—five days per year.
Thus, the Board concluded that while compliance with 35 Ill.
Adm. Code 215.204(b) (3) was technically feasible it was not
economically reasonable in light of the minimal environmental
impact. Accordingly, with the substitution of language in
subsection (c)(2) and labelling changes, the Board hereby
proposes National’s amendment to 35 Ill. Adir. Code 215.206 for
second notice.
ORDER
The Board directs that second notice of the following
proposed amendment be submitted to the Joint Committee on
Administrative Rules:
Title 35: ENVIRONMENTAL PROTECTION
SUBTITLE B: AIR POLLUTION
CHAPTER I: POLLUTION CONTRCL BOARD
SUBCHAPTER
C:
EMISSION STANDARDS AND
LIMITATIONS FOR STATIONARY SOURCES
PART 215
ORGANIC MATERIAL EMISSION STANDARDS
AND LIMITATIONS
SUBPART F: COATING OPERATIONS
Section 215.206 Exemptions from Emissions Limitations
The limitations of this Subpart shall not apply to:
a) Coating plants whose emissions of volatile organic
material as limited by the operating permit will not
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exceed 22.7 Mg/year (25 T/year), in the absence of air
pollution control equipment; or
b) Sources used exclusively for chemical or physical
analysis or determination of product quality and
commercial acceptance provided that:
1) The operation of the source is not an integral
part of the production process;
2) The emissions from the source do not exceed 363 kg
(800 lbs) in any calendar month; and,
3) The exemption is approved in writing by the
Agency.
c) Interior body spray coating material for three—piece
steel cans used by National Can Corporation at its
Rockford can manufacturing plant in Loves Park,
Illinois, provided that:
1) The emission of volatile organic material from the
interior body spray coating line shall not exceed
0.70 kg/l (5.8 lb/gal) of coating material,
excluding water, delivered to the coating
applicator; and
2) The emission of volatile organic material shall
comply with the provisions of Section 215.204 by
use of the internal offset provisions of Section
215.207 computed on a weekly weighted average
basis.
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Opinion and Order was
adop~edon the ~
day of
-~&---‘
,
1986, by a vote
of (~C
I:
7
/
~
Dorothy M. G~nn, Clerk
Illinois Pollution Control Board
74-244