~ZT~

iOL~DTION

CONTROL

BOARD

Auqust

2,

1984

AMERICM~STEEL

CONTkINER

COMPANY,

Drum

Shop,

)

Petitioner,

)

v~

PCB 83-~114

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY,

Reondent~

OPINION

AND

ORDER

OF

¶i~hE BOARD

(by

J~ Theodore

Meyer)~

On

August

19,

1953,

American

Steel

Container

Company

(ATrt~r-

ican

Steel)

filed

a

Petition

for

Variance

for

its

drum

shop

operations

Specifically

American

Steel

requests

variance

from

Sections

215~2O4(j)

and

215~2i1 and

Appendix

C

found

in

35

Il1~

Adm,

Code

215

(formerly

Rules

205(n)(l)(J),

205(j)(l)

and

~~4(h)(l),

respectively,

of

Chapter

2:

Air

Pollution),

Those

regulations

contain the emission limitation, compliance plan requirements

and

compliance date

of

December

31,

1983 for coating operations such

as

American

Steel~s,

With

its Petition, American Steel

requests

until

December

31,

1985

to

comply,

On March 5, 1984

American

Steel

filed

an

Amended

Petition

for

Variances

The

Illinois

Environmental

Protection

Agency (Agency)

filed

its

Recommendation

on

May

9, 1984~

Hearing

was

held on May 11,

1984 in Chicago~

At

hearing,

Petitioner

resorved

right

to

an evidentiary

hearing

‘~f

variance is not

granted

in

accordance

with the Agency’s Reco~uenda~

tion,

to

which

the

Respondent

agreed~

(R~6)~ The Board

notes

that

Petitioner

is

not

encitled

to

a

hearing

in addition

to

~h~t

already

held,

No

members

of

the

public

were present at that

meeting, and

no

public comments have been received by the

Board

in

this

matter,

American

Steel

employs

approximately

forty~five

persoL ~

in

its

pail

shop

located

at

4445 West 5th Avenue Chicago,

Illi’~c~

(Cook

County)~

Part

of

its

pail shop operation include

the

manufacturing

and

reconditioning of metal

industrial

fifty~fi

~u

gallon drums,

The

residue

on those drums to be refurbished is

removed

by

incineration,

They are then shot blasted and

dents

and

other

defects removed before testing~ Exterior

coatinc~

for

weatherability

and

interior coatings which act as chemical

barriers

between the product

and

steel package are applied by

spray,

followed

by

bakinq,

The

coatings

used must meet various

customer

59~213

---

~nd

refurbished

drums are used

for

~

paint,

o~l, a0~::~~

~lammahle

liquids,

food

producls

a~c ntther

mater~~~ Those

nsncl

to

store

hazardous

material

are

al~

subject

tt

iederai

i~eguiation

(Title

49

of

the

Code

of

Federa

ReguJ at Lone)

in

1981,

American

Stool

~uoduceci

400,0~0 drums;

in

1982,

410,000

drums~ and

in

!9&~, 4~.7,30Gdrums,

The

company

predicts

that

over

the

nexF t~~ee

~.

i

~s production

rate

should

increast

by

approximately

2~L3

d~o~:

~Am.

‘et,,

Table

1).

In

producing

these

drums,

Ao~’~

forty

different

types

of

coating,

which

currently

ar~

~ul~’~:

to

comply

with

Section

215.301,

the

general

rub

~:

~

cr

controlling

emissions

of

photochemicall~

~

The

average VOM content

of

the

exterior

c~

;~&~

was

4,88

pounds

per

gallon

(1bs/ga1)~

~

2i~5,234(j)

the

VOM

content

of

exterior

extreme

p~:~o~

d

be

no

greater

than

3,5

lbs/gal.

The

Age~icy

4::i~.

~n a~i~g

29,~330gallons

of

exter~or

coatings

in

:~S~Y

‘u~c~nterrLssions

were

71~55tons

per

year

(t/yr)~.

Eu:;~ on

‘~33

u~aqe,the allowable emissions

would

have

been

os~iy3~’

1:.

average

VOM

content

of

the

interior

coatings

used

hv

$uu~.i in.

1982

was

5,15

lbs/gal;

the

maximum

limit

bet.

~

E/~lrursuint

to

Section

215~204(j),

Again based eu 1~t~

~

fi.~n~esthe

Agency

calculated

that

~n

applying

~

~

~±

interior

coatinqe~

30,04

t/yr

of

VOM

were

ewitted~ th~ ~

emiss~c~ns

would

have

been

only

~8

68

t/yr~

Thus,

entn~:n’

attributable

to

the

oxteiior

coatings

n~ed

to

cc

reduced

by

I

~,

and

~y

‘~3

at

the

interior

coating

op~at~n,

Combined

emissions

~~oedto

he

reduced

by

53

in

order

to

be

in

compliance,

(Rec~

3)

American

Steel

has

investigated

achieving

compliance

vn~tl.

its

coating

~upplioi~

Powder

coatings

tested

to

date

were

unacceptable

because

they

proved

insufficiently

resistant

to

th~

haraf

chemical

eposure~

Acceptable

watar~based coatings

are

also

not

yet

available

as

substitutes

for

~h:cee reasons,

Th

equipment

necessary,

the

cuting

time

and

temperature

requirec

and

the

odor associated with available

water~based coatings~

prohibits

their

use

at

this

time,

Substitute

coatings

contø. r~

,

1,

~trichioroethane

vid

methylene

chloride,

which

are

exemp~

VOM,

are

not

possibe

since

direct

exposure

of

these

materiais

4~-~

the

necessary

baking

temporatures.produces

hydrochloric

acid,

~nd

possibly

phosgene

gas~ which

are

toxic

and

corrosive,

New

ovens

would

be

necessary

in

order

to

switch

to

these

exempt

halogt

ic

solvents,

Afterburners

proved

economically

unreasonable

to

install

and

operate.

Vapor

recovery

was

not

feasible

due

to

~te

various

blends

of

solvents

needed

for

the

wide

variety

of

coatingc,

Carbon

adsorption

was

also

not

feasible

due

to

the

high

volume

cf

air

used

by

the

equipment,

and

due

to

insufficient

space

for

such

a

system~

Electrostatic

spray

equipment

was

not

economically

reasonable

due

to

high

installation

and

maintenance

costs

relative

to

marginal

reduction

in

e~iseton~s.

Aennican

Steel,

along

with

its

suppliers,

is

still

in~ostigating

powd~~r

coatings

and

ultra~

59~214

---

violet

curing

systems,

(Pete

il~14)

Until either of these,

or

other

low

solvent

coatings

are developed

and tested,

American

Steel

claims

that

implementation

of

any

of the other

alternatives

1isted

above

would

impose

an

arbitrary

and unreasonable

hardship,

In

its

Recommendation,

the

Agency agreed that until

reformu~

lated

coatings

are available, compliance

can only

be

achieved

by

the

installation of afterburners~

In

addition to

agreeing

that

the

costs

and

fuel

consumption

are

high,

the Agency

noted

tb

t

afterburners

would

only

be

used

during

the ozone season

pur:

ic

ft

to

Section 215,106,

Therefore,

annual

emissions would

be

further

reduced

if

lou’

solv~nt coeti~’0s are

developed and

used

as

opno3ed

to afterburners,

(Rec,

4)~

The

Board

agrees

that annua’

~nissions

would thus be reduced, but finds this

not as relevant

as

reluctions

in

daily

emissions

American Steel highlighted three

test runs it

undertook

with

high solids coating.

Each proved unacceptable, first, because

they did not meet

its

quality standards and

secondly,

beca.’ so

they required increased baking time.

To accommodate

inc~oa~

0.

curing

extensive modification would

have to

be made

at

its

facility~

(Am,

Pet,, 2~~3)American

Steel anticipates

tha

in

will

test coatings from its suppliers

in the near

future

whi~h

will

allow

it

to comply.

It also

acknowledges

that switching v~

the same will require some equipment

modification.

By

Decer

~t

1984 it expects to reduce the average

VOM

contents

of the

ex~e~::

coatings

to

4,2

bs/gal,

and

of

the

interior coatings

to

5

lbs/gal.

Finally by December of

1985, the exterior

coatinc~

average VOM content should

be

reduced

to 3.0 lbs/gal

and

c~n

interior coatIngs average

to

5~8

lbs/gal.

Use of the

inter

offset

provision

contained

in

Section 215.207 should

allcw

r

compliance

with

the

Board’s

rules,

The

Agency

requested

condition to variance that American Steel be required

to

an

..

operating

permit

applications

by

October

1,

1985

which

dem~

cmpliance

pursuant

to the internal offset provision.

The

I

~i

will

not

condition

the

variance in this manner since PetiU

is

required

to

apply for operating

permits

no

later

than

l~I

date

pursuant

to Section 201.162, and

because Petitioner na

choose

to

demonstrate compliance by

a means other than

the

i

offset

provision

at

that future date,

The

Board

agrees that coating reformulation

is

the

mos~

ewironmentally

sound

means

of

ultimate

compliance.

It

finii

smeriean Steel

has

adequately demonstrated that compliance ~:

o.

the

other alternative methods at this

time would

impose

arbet.~

and

unreasonable

hardship

at

its

drum

operation.

Any

envi~o~e~.

or

health

danger

should

be

alleviated

as necessary under

P~

~

s

Foisode Action Plan.

Variance from

Section 215.204(j),

and

tk~

attendant

compliance rules

is, therefore, qranted subject

to

tte

conditions

set

out

in

the

Order,

This

Opinion

constitutes

the

Board~sfindings

of

fact

and

conclusions

of

law

in

this

matter,

59~215

---

ORDER

Petitioner,

American Steel Container

Company

is hereby

granted a variance for its drum shop coating

operation at its

facility

at

4445

West

5th

Avenue,

Chicago,

Illinois

from

January

1,

1984 until

December

31,

1985

from

Sections

215,204(j)(1)

and

(3),

215.211

and

Appendix

C

at

35 III. Adm.

Code

215,

subject to

the following conditions.

1.

Petitioner shall submit written

reports to the

Agency

by November

1,

1984,

and

every

third month

thereafter,

detailing

all

progress

made

in achieving compliance

with Section

215.104(j).

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

volatile

organic

material

(VOM)

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

VOM

content

of

all

coatings utilized during the

reporting

period;

the

quantity

of VOM reduction during the reporting

period;

and

any

other

information which may be requested by the

Agency.

The

reports

shall

be

sent

to

the following addresses:

Environmental Protection Agency

Division of Air Pollution Control

Manager,

Permit Section

2200 Churchill Road

Springfield,

Illinois

62706

Environmental

Protection

Agency

Division

of

Air

Pollution

Control

Manager,

Field

Operations

Section

1701

South

First

Avenue

Suite

600

Ma~ood, Illinois

60153

2.

Petitioner

shall

apply

to

the

Agency

for

all

requisite

operating

permits

by

September

15,

1984

pursuant

to

Section

201,160(a),

3.

Petitioner

shall reduce

the

average

VOM

content

of

its

interior

and

exteiior

coatings

by

December

31,

1984

as

follows:

Coat~~

Exterior

4,2

lbs/gal

Interior

5.0

lbs/gal

---

4.

Within

45

days of the date of this Order, the Petitioner

shall execute and forward

to the

Illinois Environmental Protection

Agency, Division of Air Pollution Control, Compliance Assurance

Section,

2200 Churchill Road,

Springfield, Illinois 62706,

a

Certificate 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

83~114

dated

______

,

understand

and

accept

the

said

Order,

realizing that such acceptance renders all terms and conditions

thereto binding and enforceable.

American Steel Container Company

By:

Authorized Agent

Title

Date

IT IS SO ORDERED.

B.

Forcade

concurred,

I,

Dorothy

M.

Gunn,

Clerk

of

the Illinois Pollution Control

Board, hereby certify that the above Opinion and Order was

adopted

on the

~

day of

~,

1984

by

a

vote

of

~

Dorothy M. Gunn,

Clerk

Illinois Pollution Control Board