ILT1IMOIS

 POLLUTION CONTROL BOARD

May

1984

MEYER STEEL

 DRtfli,

 INC.,

)

MILLARD

STREET

PLANT,

)

Petitioner

)

v.

)

 PCB 83—117

ILLINOIS

ENVIRONMENTAL

PROTECTION

)

AGENCY,

Respondent.

MR.

MICHAEL

 3. KRALOVEC OF FEIWELL, GALPER

 & LASKY, LTD., APPEARED

ON BEHALF OF MEYER STEEL DRUM INC., MILLARD STREET PLANT.

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

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY.

OPINION AND ORDER OF THE

BOARD

 (by 3.

 Anderson):

This matter comes before the Board upon an August 22,

 1983,

petition for variance

 fi1?czi

by Meyer Steel Drum,

 Inc., Millard

Street Plant

 (“Meyer”)

 as amended on December

23,

 1983.

An

amendment to bhe Amended Petition for Variance was filed on

February

6,

 1984.

 Meyer

ha~

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 compliance with the emission

limitation for Volatile organic compounds (“VOCs~)discharged

 from its steel drum

 coating

 lines.

 The variance has been re-

quested until December 31,

 1985.

The recent codification of applicable rules to 35 Illinois

Administrative 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’s) filed a recommendation that variance be granted.

Hearing was held on February 6,

 1984.

Section 215.204(j)

 requires that effective December 31,

1983, VOCs contained in the coatings utilized by Meyer for miscel-

laneous metals parts and products coatings shall have the

following upper limits:

58-09

Section 215.211(a)

 establishes

 the compliance date, and Section

215.212 requires Ilanufacturers to submit a compliance plan to the

Agency.

Meyer

owns

and

operates

several

facilities

Chicago.

The

facility

which

the

subject

this

 petition is located at

3201 South Millard Avenue, Chicago, Illinois

 60623.

 New steel

drums are manufactured and several coatings are applied.

The

coatings are applied in spray booths to interior and exterior

drum surfaces and dryed in uncontrolled ovens.

 The drums are

built to meet customer specifications and are used for storing

and transporting foods,

 adhesives,

 oils and liquids.

ENVIRONMENTAL

IMPACT

The 1982 usage figures are as follows

 (Rec.

p.

3):

Emissions

\.OC Content

 ‘SOC &nissions*

Allowable

Emissions

99,196.2 lb/yr

262,258.3 lb/yr

Interior

Exterior

19,604 gal/yr

56,889 gal/yr

 141.7 tons

\XJC/yr

4.3

lb/gal

3.5 lb/gal

84,297.2 lb/yr

199,111.5 lb/yr

283,408.7 lb/yr

Interior

Date

 Content

Exterior

W)C

 Content

\7~

 Emissions in lb/yr differ from Agency calculations by

approximately 0.06,

 The difference arises from the Board’s use

of only two significant decimal digits

 in the VOC content.

exterior

(extreme

 ierf~~rmance)

coating

interior

(clear)

 coating

3.5 lb/gal

4.3 lb/gal

oating

Type

Interior

Exterior

Gallons Used

19,604 gal/yr

 56,889 gal/yr

180.73

tons

VOC/yr

5.06 lb/ga.

4.61 lb/gal

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.

 The reductions proposed are as follows

(R.

p.

 16):

7/1/84

12/84

7/85

12/85

S lb/gal

lb/gal

5 lb/gal

Reduction

0.06 lb/gal

0.0 lb/gal

0.0

lb/gal

0.0

lb/gal

4 lb/gal

3.8 lb/gal

3.3 lb/gal

2.99 lb/gal

Reduction

0.61 lb/gal

0.2 lb/gal

0.5 lb/gal

0.31 lb/gal

58-10

As shown above, the VOC content of the exterior coating will

meet the Ract II standard

 (3.5

lb/gal)

 by July 1985.

 By December,

1985,

 the VOC content of the Interior coating will remain

higher

than the Ract It standard of 4.3 lb/gal.

 At that time, the

variance will have expired and Ueyer will have several options

for demonstrating compliance:

 (1) Interior coatings may be

available at the Ract II Standard of 4.3 lb/gal;

 (2) alternative

control

 strategy; or

(3)

 internal offset.

HARDSHIP

formulating

its

Recommendation,

the

Agency

met

with

Meyer

several

times,

spoke

with

various

 consulting engineers,

and

contacted

coating

manufacturers.

addition,

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 ex-

pressed 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 of afterburners, and carbon adsorption.

 Some of the options

were rejected because the resultant product was unacceptable,

installation

and

 maintenance costs were prohibitive,

 and space

limitations prevented additional

 equipment

 (Pet.

p.

9).

The internal offset plan proposed by Meyer would achieve

compliance, minimize harmful environmental impact,

 and be cost

effective.

 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.

The Agency

recommended

that

the

interim

“milestone”

dates

not be included as

 a variance condition

(R.

 10).

 However, the

Board feels that, short of imposing an emission “cap” during

non-compliance,

 interim dates should be a condition of the

variance.

 Although the Board has recognized that variances from

its December 31,

 1983 tight deadline might be necessary, the

Board, consistent with its reasons for establishing a tight

deadline,

 feels that continuing progress towards reducing

VOC

content must be demonstrated,

 However,

 the Board will delay

 the interim dates contained in the petition by two months to

provide more flexibility.

58-11

4

This opinion constitutes the Board’s

 findings of fact and

conclusions of

law

in this matter.

ORDER

Meyer Steel Drum,

 Inc.,

 Millard Street Plant is hereby

granted a variance from 35 Iii. ~dm. Code 215.212, 215.211

 (a),

and 215.204

(j)

 subject to the following conditions:

1.

 The variance expires on December 31,

 1985.

2.

 The variance applies only to the Millard Street Plant.

3.

 On June

 17, and every

 third month thereafter, Petitioner

shall

 submit written reports

 to the Agency detailing all

progress made

 in achieving compliance with this Order.

Said reports shall include information on the names of

replacement coatings and the manufacturers specifications

including per cent solids by volume and weight,

 per cent

VOC by volume and weight, per cent water by volume and

weight,

 density of coating,

 and recommended operating

parameters;

 detailed description of each test conducted

including test protocol, number of runs, and complete

original

 test results; the quantities and VOC content of~

all coatings utilized during the reporting period; the

quantity of VOC reduction during the reporting period;

 and any other information which may be requested by the

Agency.

 The reports shall

 he sent to the following

addresses:

Environmental Protection Agency

Division

of

Air Pollution Control

Control Programs Coordinator

2200 Churchill Road

Springfield,

IL

62706

Environmental Protection Agency

Division of Air Pollution Control

Region

 1, Field Operations Section

1701 South First Avenue

Suite 600

Maywood,

IL

60153

4.

 No later than June 17,

 1984 Petitioner

 shall apply to

the Agency for all requisite operating permits pursuant

to Section 201.160(a).

5.

 The VOC content of coatings used shall not exceed

the following schedule:

58-12

5

Interior

 Exterior

Date

‘XX~Content

SX)C Content

9/1/84

 5 lb/gal

4

 lb/gal

2/28/85

 5 lb/gal

 3.8 lb/gal

9/30/85

 5 lb/gal

 3.3 lb/gal

12/31/85

 5 lb/gal

 2.99 lb/gal

6.

 Within 45 days

 of the date of this Order, Meyer Steel

Drum,

Inc.,

Millard

Street

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 be held in abeyance during

any period that this matter is being appealed.

CERTIFICATION

I,

 (We) _______________________________,

 having read the

Order of the Illinois Pollution Control Board in PCB 83-117 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

Bill Forcade concurs.

IT IS SO ORDERED.

58-13

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby certify that the above Opinion and Order

was adopted on the

~

 day of ~

 1.984 by a vote

of

~

J.~.,

/_.,..._,y

Christan L. Moffett, C~erk

Illinois Pollution Control Board

58-14