ILLINOIS POLLUTION CONTROL BOARD

May 3, 1984

MEYER STEEL DRUM, INC.,         

)

Petitioner,

)

v.

)

PCB 83—116

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY,

Respondent.

MR. MICHAEL 

3.

KRALOVEC OF FEIWELL, GALPER 

&

LASKY, LTD., APPEARED

ON BEHALF OF MEYER STEEL DRUM, INC., KEELER AVE. PLANT.

MR. PETER ORLINSKY, ATTORNEY AT LAW, APPEARED ON BEHALF OF THE

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY.

OPINION AND ORDER OF THE BOARD (by B. Forcade):

This matter comes before the Board upon an August 22, 1983

petition for variance filed by Meyer Steel Drum, Inc., Kee.er

Ave. Plant (°Meyer”)as amended on December 23, 1983. Meyer has

requested a variance from Rule 104(h)(1), Rule 205(j)(1) and Rule

205(n)(1)(j) of Chapter 2: Air Pollution, to allow delayed com-

pliance with the emission limitation for volatile organic compounds

(“VOCs~’) discharged from its steel drum coating lines. Meyer*s

Keeler Avenue Plant is scheduled to cease operation by April 30,

1984. The entire operation will be moved to another Chicago

location. Therefore, although variance has been requested until

December 31, 1985, the only applicable period is from 

January 

1,

1984, to April 30, 1984.

The recent codification of applicable rules to 

35

Ill. 

Adm.

Code is as follows:

Rule              

Section

104 (h)(1)              

215.212

205 (j)(1)             

215.211 (a)

205 (n)(1)(j)           

215.204 (j)

On January 31, 1984, the Illinois Environmental Protection

Agency (“Agency”) filed a recommendation that variance be granted.

Hearing was held on February 

1984.

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Section 215.204(j) requires that effective December 31, 1983,

VOCs contained in the coatings utilized by Meyer for miscellaneous

metal parts and products coatings, shall have the following upper

limits:

exterior (extreme performance) coating   

3.5 lb/gal

interior (clear) coating           

4.3 lb/gal

Section 215.211(a) establishes the compliance date, and Section

215.212 requires Manufacturers to submit a compliance plan to the

Agency.

Meyer owns and operates several facilities in Chicago. The

facility which is the subject of this petition is located at 5303

South Keeler Avenue, Chicago, Illinois 60632. New steel drums

are manufactured and several coatings are applied. The coatings

are applied in spray booths to interior and exterior drum surfaces

and dried in uncontrolled ovens. The drums are built to meet

customer specifications and are used for storing and transporting

foods, adhesives, oils and liquids. The Plant is located in an

area which is industrial, commercial and residential.

ENVIRONMENTAL IMPACT

Meyer utilizes approximately twenty different types of

coatings. The 1983 usage figures are as follows: (Am. Pet. p. 39)

Emissions

Gallons Used

~.OCContent   

‘~OC~nissions

Interior     

2,765 

gal/yr

5.05

lb/gal    

13,963.3 

lb/yr

Exterior

16,830

gal/yr    

4.55 lb/gal    

76,576.5 lb/yr

Total    

19,595 gal/yr              

90,539.8 

lb/yr

45.3 

tons \~OC/yr

Allowable Emissions

Interior    

2,765 gal/yr    

4.3 lb/gal     

11,889.5 lb/yr

Exterior    

16,830 

gal/yr

3.5 lb/gal     

58,905 lb/yr

Total    

19,595 gal/yr             

70,794.5 lb/yr

35.4 tons VOC/yr

The figures submitted in the amended variance petition are

estimates and have been rounded off. For purposes of comparison

with the current and allowable emissions presented in this Opinion,

the difference is only 0.10.

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Meyer’s amended petition contains a compliance plan which

involves a gradual reduction in the VOC content of various coatings

over a two year period and reaches compliance levels through

internal offsets. However, if the Keeler plant ceases operation

on April 30, 1984, as scheduled, 

this would

negate the necessity

for a long term plan of action.

HARDSHIP

In formulating its Recommendation, the Agency met with

Petitioner several times, spoke with various consulting engineers,

and contacted coating manufacturers. In addition, on December 13,

1983, the Agency had a meeting with representatives of the United

States Environmental Protection Agency (“USEPA”) and the drum and

barrel manufacturing industry. At that meeting, the USEPA expressed

its opinion that currently there is no practical means of achieving

compliance with interior coatings (Rec. p. 2).

For several years, Meyer has been working both internally

and with its coating suppliers to develop the necessary technology

to reduce VOC emissions. To date, the efforts have been partially

successful, but have not produced great enough reductions to

achieve compliance with Section 215.204(j) by December 31, 1983.

Among the options studied by

Meyer 

are: 

use of high solids,

water-based, and powder coatings, electrostatic

spray, install-

ation or 

afterburners, and carbon

adsorption. Some of the op-

tions were rejected because the resultant product was unaccept-

able, installation and maintenance costs

were prohibitive, and

space Itmitations prevented additional equipment from being

installed (Pet, p. 9).

The internal offset plan proposed by Meyer would achieve

compliance, minimize harmful environmental impact, and be cost

effective, but would require until December, 1985, to 

complete.

The Board finds that granting of variance will have minimum

adverse environmental impact and that immediate compliance with

Rules 215.212, 215.211 (a), and 215.204(j), would impose an

arbitrary and unreasonable hardship.

This opinion constitutes the Board’s findings of fact and

conclusions of law in this matter.

ORDER

Meyer Steel Drum, Inc., Keeler Avenue Plant is hereby granted

a variance from 35 Ill. Adm, Code 215.212, 215.211(a), and 215.204(j)

subject to the following conditions:

1.  The variance covers the period from January 1, 1984,

to April 30, 1984.

2.  The variance applies only to the Keeler Avenue facility.

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3.  Within 45 

days

of the date of this Order, Meyer Steel

Drum, Inc., Keeler Avenue Plant shall execute a

Certification of Acceptance and Agreement to be bound

to all terms and conditions of 

this 

variance. Said

Certification shall he submitted to the Agency at 2200

Churchill Road, Springfield, Illinois 62706. The

45-day period shall he held in 

abeyance 

during any

period that this matter is being appealed. The form of

said Certification shall he as follows:

CERTIFICATION

I,

(We) 

_______________________________,

having read the

Order of the Illinois Pollution Control Board in PCB 83—116 dated

April 19, 1984, understand and accept said Order, realizing that

such acceptance renders all terms and conditions thereto binding

and enforceable.

Petitioner

By: Authorized Agent

Title

Date

IT IS

SO ORDERED.

I, Christan L.

Moffett, Clerk of the Illinois Pollution

Control Board, hereby ~rtify that the above Opinion and Order

was adopted on the 

“3

day of /7)     

1984 by a vote of

~‘pC)

Illinois Pol        

Board

58-08