ILLINOIS POLLUTION CONTROL BOARD

June 27, 1985

~4OOREAMERICAN

GRAPHICS,

INC.,

Petititioner,

)

V.

)

PCB 83—241

1LLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

)

)

Respondent.

3A~4UELT. LAWTON, JR., ESQ., ALTBEIMER & GRAY, APPEARED ON BEHALF

OF PETITIONER.

PETER E. ORLINSKY, ESQ., APPEARED ON BEHALF OF RESPONDENT.

OPINION AND ORDER OF THE BOARD (by J. Theodore Meyer):

This matter comes before the Board on a December 30, 1983

petition filed by Moore American Graphics, Inc. (Moore)

requesting extension of a variance from 35 Ill. Mm. Code

215.204(c) (formerly Rule 205(n)(l)(c)) until December 31,

1985. On January 12, 1984 the Board ordered Petitioner to submit

additional information and an amended petition was filed on

February 7, 1984. By order of February 9, 1984 the Board again

requested additional information and set the matter for

~iearing. The Illinois Environmental Protection Agency (Agency)

filed its recommendation that variance be granted subject to

conditions on May 23, 1984. Hearing was held on May 16, 1985.

Moore owns arid operates a facility in Bridgeview, Illinois

which coats and laminates paper book and magazine covers. The

facility includes four coating machines and four laminating

machines (R. at 23). These machines have associated drying ovens

~‘ihichvent directly to the atmosphere. The coatings used by

Moore contain volatile organic compounds (VOC) which are emitted

during production. Section 215, Appendix C requires that paper

coating operations must be in compliance with Section 215.204(c)

by December 31, 1982. Section 215.204(c) limits

VOC

emissions to

0.35 kg/i (2.9 lb/gal).

By letter filed on February 24, 1984 Moore indicated that in

1982 its VOC emissions from its laminating lines were 131,600 lbs

and in 1983 the level had decreased to 111,600 lbs. Emissions

from the coating lines were constant for both years at 91,000

lbs. In the previous variance~ Moore indicated that in 1982 its

laminating adhesive had an average VOC content of 4.7 lb/gal and

its coating material had an average content of 4.3 lb/gal. PCB

93—1, April 21, 1983 at 2.

84-457

---

—2—

The previous variance from Section 215.204(c) required Moore

to pursue a reformulation program to reduce VOC emissions to

permissible levels by December 31, 1983. Because of an

unanticipated set—back in the reformulation process, Moore was

unable to comply by the required date and now requests an

extension to December 31, 1985.

The delay in the reformulation program was principally due

to the fact that the experimental coatings formed hydrochloric

acid when exposed to high temperatures in the drying ovens. This

acid was damaging to Moore’s equipment arid thus, Moore was forced

to develop a means of preventing the acid formation or develop

replacement low VOC coatings. The Agency states that while it is

disappointed with this inability to achieve compliance it

believes Moore has been diligent in its efforts (Rec. at par.

10).

while the petition indicated that Moore intended to achieve

compliance by using new coatings, at hearing Mr. Ashmead

testified that no commercially acceptable alternatives had been

found CR. at 10). Owners or operators of coating lines unable to

comply with Section 215.204 may, as an alternative, demonstrate

compliance by adding on a control device in accordance with

Section 215.205. Because no new. sources for chemicals to try

could be identified, Moore decided to install a solvent recovery

system which is expected to be operational by December 31,

1985. The system consists of an activated charcoal bed over

which all captured air from the coaters and laminators is

passed. The carbon absorbs the solvents. When the bed is

saturated, steam is used to remove the captured solvent which is

then delivered to a holding tank for reclamation.

In the interim, Moore is continuing to test any water—base

coatings that become available. Moore is also experimenting with

pre-coated film which is activated by heat and then applied

without any solvent emissions (R. at 17—18).

To date, Moore has expended approximately $500,000 on new

laminating equipment. capable of running the water-base adhesives

and for running the requisite tests. The solvent recovery system

is expected to cost between three and four hundred thousand

dollars (R. at 19—20).

Moore has not conducted a formal assessment of the

environmental impact should this variance be granted. The

facility is located in an industrial area with the nearest

residences located approximately one half mile south. The Agency

states that it has received no complaints from area residents.

At hearing, however, two citizens stated that they had smelled

odors in the area, although they were uncertain about their

source CR. at 33—40). Mr. Altar, in particular, was concerned

about the health effects of Moore’s emissions (R. at 37—39).

64-458

---

—3--

Volatile organic compounds contribute to the formation of

ozone. Ozone is a criteria pollutant for which there are

identical national and state air quality standards (0.12 ppm

(235 ug/m3)). Moore’s facility is located in an area designated

non—attainment for ozone. The closest monitoring station is

located at 8010 South Kostner in Chicago which is approximately

four miles to the northeast. In 1982 and 1983, the air quality

standard was not exceeded at this station.

The Board finds that to deny Moore a variance from Section

215.204(c) would constitute an arbitrary or unreasonable

~iardship. Moore has historically been diligent in seeking a

means to reduce its VOC emissions and expects to achieve

compliance through installation of a solvent recovery system by

December 31, 1985. Moore’s efforts constitute sufficient

satisfactory progress to warrant a variance extension. However,

the Board will condition this variance upon the use of coating

materials which have a VOC content less than or equal to the

presently used materials. Unfortunately, the information

necessary to set a precise level is lacking as figures are

available only for 1982.

Because Section 215.204(c) was approved by USEPA as part of

the State Implementation Plan (SIP), grant of this variance will

necessitate a SIP revision. The Agency has opined that grant of

this variance, consistent as it is with their recommendation,

should be approvable as a SIP revision. Accordingly, variance is

granted from 35 Ill. Adm. Code 215.204(c) from December 31, 1983

until December 31, 1985, subject to conditions.

This Opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

ORDER

Moore American Graphics, Inc. is hereby granted a variance from

35 Iii. Adm. Code 215.204(c) from December 31, 1983 until

December 31, 1985 subject to the following conditions:

1. Moore shall use laminating and coating materials which

have a VOC content less than or equal to those presently

used.

2. Moore shall continue to submit quarterly written

reports, to the Agency until December 31, 1985 detailing all

progress made in achieving compliance with 35 Ill. Adm. Code

215.204(c) and 215.205.

3. Within 30 days of the date of this Order, Moore shall

apply to the Agency for all requisite operating permits

pursuant to Section 201.160(a).

4. Within 45 days of the Board’s Order herein Petitioner

84-459

---

—4—

shall execute a Certification of Acceptance and Agreement to

be bound to all terms and conditions of the variance. Said

certification shall be submitted to the Agency at:

Environmental Protection Agency

Division of Air Pollution Control

Control Programs Coordinator

2200 Churchill Road

Springfield, Illinois 62706

This 45 day period shall be held in abeyance during any

period that this matter is being appealed. The form of the

certification shall be as follows:

CERTIFICATION

Moore American Graphics, Inc. hereby accepts and agrees to be

bound by all terms and conditions of the Order of the Pollution

Control Board in PCB 83—241, dated June 27, 1985:

MOORE AMERICAN GRAPHICS, INC.

By ____________________________

As Authorized Agent

Title

Date

IT

IS

SO ORDERED.

B. Forcade concurred.

I, Dorothy N, Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify that the above pinion and Order was

adopted on the

~

day of

__________________,

1985, by a

vote of ~~-O

~,

Dorothy M. unn, Clerk

Illinois Pollution Control Board