ILLINOIS

POLLUTION

CONTROL

BOARD

January

24,

1985

NATIONAL CAN

CORPORATION

(ROCKFORD PLANT),

v.

PCB 84—108

PROTECTION AGENCY,

Se

spondent

OPINION AND

ORDER

Ot

PNE

BOARD

(by J. Marlin):

A petition for

~~.;;.riance

in

PCB

83—175

was filed November

21,

1983 by National. yan

Corp..

(National)

requesting extension

of the variance

grantcd

from

35

Ill..

Adm..

Code

215.204(b)

in

PCB 81—189,

concerninq: VOC

emissions

from

coating materials

used in the beverage

can manufacturing

process

in National

Can’s Rockford

plant..

An

Agency

recommendation

was filed

January

9,

1984. A waiver

of hearinq

was filed January

24,

1984.. The Board ordered

this

matter

to

hearing on February

3,

1984.

The hearing was not

immediat:ely

held.

Meanwhile,

docket 84-108

was

opened upon the filing on

July

27,

1984

of a document

captioned

“Amended Petition for

Variance

“,

bearing number PC383~175

This matter was

auth-

orized

for hearing August

2,

1984..

A

recommendation was filed

October

2,

1984

without

hearing

being

held..

Upon

examination

of

these

simi,Lar

metitions,

the

Board

dismissed

PCB

83—175

but

on its ocu motion

incorporated

the

record

in

now—defunct

PCB

83—175 into that

of

PCB

84—108

(PCB

83—175,

84—108,

Order, November

8

1984).

A

hearing was held in Rockfoi

illinois

on

December

5,

1984..

No

members

ci

the

public

attended..

As.

there

appears

to

be

an

outstanding

motion,

the

Board

grants

the

Agency’ s

motion

to

file

its

October

2,

1.994

recommendation

~istanter,

National

operates

a

can

rnabing

facility

in

Loves

Park

in

an

area

that

is

primarily indumt:cia:,

v:Lth

some

residential

housing.

The

plant manufactures metal

carts

utilized

by

the

food and

beverage

industries..

Included in the

equipment

lo-

cated at National’s

Loves Park facility are four

sanitary can

lines,

one 360

degree spray

beei: can line,

and

six end presses

which apply end

sealing

compound~

Each can

line has an inside

and outside

seam

stripe

and

the beer can

line

has

an

inside

---

spray.

The foregoing equipment utilizes several types

of

coatings which contain volatile organic compounds

(VOC).

The VOC emissions from the can coatings were to meet the

requirements of

Section 215.204(b)

by December 31,

1982.

The prior variance granted to National expired

on December

31,

1983.

National requests

a variance

extension until

December 31,

1985.

During the prior variance period, the end

sealing com-

pound was

reformulated

to a lower VOC content,

Its

use

ceased in June,

1984 as a result of

a customer

complaint

regarding inferior

seail.hility.

National

has now returned

to using

the higher VOC content end sealing

compound.. The

percentage

of

emissions at this facility is distributed

as follows:

Interior Body Spray

27,9

Side Seam Outside

1.9

Side Seam inside

.9

End Sealing

69.3

The end sealing compound operation has consumed,

since

1980,

approximately 67,000 gallons of coating material

annually..

During the first half of 1984, consumption

has

been 33,682 gallons.

The Agency calculates that

National

is exceeding the end sealing compound VOC

“emission limitation”

by 27.6 tons/yr.

(Ag..

Rec,

at

3).

However, there

is no

“emission limitation”..

Rather,

the rule limits the

VOC

content of the coatings themselves,

The 360 degree body spray operation h~sconsumed,

since

1980,

approximately 17,500 gallons

of coating material

annually.

Consumption during the first half of

1984 has

been 2,450 gallons..

The Agency calculates that National

is

exceeding the interior body spray VOC “emission limitation”

by

21 tons/yr.

(Ag..

Rec... at

2).

There are two differing estimates as to annual excess

VOC emissions..

National calcu1ai~esthat the excess VOC

levels declined in 1983 from 67 to six tons per year, but

now

have returned to 67 tons excess VOC per year

(Am.

Pet.

at

2)..

The Agency calculates the excess to be

48

tons VOC per year

(Ag..

Rec. at 2-3).

Extensive testing is still needed for a reformulation

of

both the inside spray coating and the end sealing

materials

to

a low VOC content.

National believes that these

reformu—

lations will not be developed prior to December 31,

1985.

Upon

the failure of National to comply with the reformulation

of

the inside spray coat to RACT levels by that date,

National

will

purchase and install a control device or devices for

all

noncomplying VOC emissions

(Am.

Pet, at 2-3).

The

capital

cost of this equipment is $300,000 with an

annual

operating

cost of

$47,000..

~o control equipment

is

available

---

for the sealing process; coatings must be reformulated

to

a lower VOC content.

National alleges that to immediately

comply

with the Board~sregulations would be to impose

an

arbitrary

or unreasonable hardship pursuant

to

Section

35

of the Act.

The Board notes that the Rockford area is an attainment

area for ozone..

The highest recorded ambient ozone

concentration

in 1983 was 0,108

ppm..

National cites the Agency VOC

emission

inventory which places total VOC emissions in the Rockford

area at 13,426 tons per year..

National~sexcess VOC

emissions

of

67 tons per year would then represent

0.5 percent of

the total

Rockfc:.:S emissions.

Assuming a direct

relationship

between VOC emissions and ozone ambient air quality,

the

national ambient air quality standard would be exceeded

if an

additional. 1,492 tons VOC per year were emitted

in

the Rockford area

(Am.

Pet.

at

3)..

The Board recognizes

that transport of ozone precursors over distance may

cause

ozone

problems in other areas.

The Board finds that the granting of variance extension

until December 31,

1985 will not significantly impact the

environment and that to require immediate compliance

would

impose an arbitrary or unreasonable hardship on petitioner.

The Board therefore grants National Can Corporation a

variance

extension from

35

Ill.

Adm.. Code 215,204(b)

from December

31,

1983 until December

31,

1985..

This Opinion constitutes the Board~sfindings of fact

and conclusions of

law in this matter..

National

Can Corporation,

Rockford Plant,

is

hereby

granted variance from 35

III. Adm. Code

215..204(b)

subject

to the conditions below:

I.

This variance shall begin on December 31, 1983

and expire on December

31,

1985..

2..

During this variance period, National Can Corporation

shall supply written quarterly updates to the Agency detailing

the amounts of coating material used, the VOC content,

the percentage over RACT for the period, all new coatings

tested and their VOC content, whight, and RACT percentage.

3..

National Can Corporation shall begin procedures

for construction of a control device(s)

on the body

spray

operation by the third quarter of the variance period

i.f

a compliance coating is not imminent at that time.

---

4

4.

Within 45 days of the date

of this Order,

petitioner

shall

execute and forward to the Illinois Environmental

Protection Agency, Air Pollution Control Division,

2200

Churchill Road,

Springfield,

Illinois 62706, a Certifi-

cate

of

Acceptance and Agreement to be bound to all terms

and

conditions of this variance..

This

45 day

period shall

be

held in abeyance for any period this matter

is

being

appealed..

The form of the certificate shall

be

as

follows:

CERTIFICATE

I,

(We),

____

____

having read the

Order of the

Illinois Pollution

Control

Board

in PCB 84-108,

dated

______

_____________

understand. and accept the said conditions

thereto

binding and

enforceable..

Petitioner

By:

Authorized

Agent

Title

Date

IT IS SO ORDERED..

Board

Member Bill

S..

Forcade dissented.

I, Dorothy

M..

Gunn, Clerk of the Illinois Pollution

Control

Board,

hereby certify that the above Opinion and Order was

adopted

on the

~

of

,

1985 by a vote of

___________

~

~

Illinois Pollution

Control Board

62~4O8