lL~lNuIS

POLLUTION

CONTROL

BOARD

Augi~st 2,

~984

~

(~jNT~NER

COMPANY

PCB

83~115

IL~I~I~ 1?NVIRONMIY

TAL

PL)Tx~lION

AGENCY,

C~TNI\1 AND

ORDER

01?

THE

BOARD

(by

J

Th~odora Meyer):

On

AuguFt

19,

1983,

American

6te~l

Container

Company

~er-

ice

3t~el)

filed

a

Petition

for

Varrance

for

its

pail

shop

opor~itJn.

Specifically

American

Steel

requests

variance

from

S~c~io~s

215~2O4(j

and

215~211 and

Appendix

C

found

in

35

~1l~

Adm.

Code

215

(former)y

Rules

205(n)(l)(Ji,

205(j)(l)

and

~(~i)(l),

respectiv4y

of

Chapter

2:

Air

PollutionL~

Those

regulat~tons

contcun

the

emissio:

limitation,

complianct

plan

requirements

and

a

co

jliance

date

of

December

31,

1983

for coating operatioi~

such as American Steel~s~With its Petition,

American

Stc~l

requ~tsuntil December 31,

1985 to corply~

On February 29

1984

A~nerican~,teelfiled

ar Amended Petition for Variances

The

lrn~i~~nvironmen al Protection Ag~ncy(Agency) filed its

Recornm

ilatior o~Nay

1984~.

Fear n

was held on May 11

984

in

Clii ~o

At hearing, Petitioner reserved right to an ev~dentiary

i~ariny ii ~‘ariancer~not granted in accordance with the Agency’s

~comm~.

ia

On,

(R. 6~

The Board notes that Petitioner i~not

a

titi~.

tc a h~irirgin addition to that already

held~

No

memb~ri~f ~

1ublic were present at that hearing, and no ~uburc

con

•~t~nave ‘een recei~iedby the Board in this

matters

can Steel ~mpi~oysapproximately forty’~fivepersons in

i

pan.

~hup ~

at 4445 Wect bt

Avenue Chicago,

Illirois

I

c

ci)

Pa~t ~f die operation at that shop is manu~acturing

an~i~

utio~ingm~talindustrial fity’~fivegallon drums~

Var

n~

ic~.t~atst~meritof its operation wa~discussed

a’id

i.

1t~B83~r14,Americ!~~~~l

Container

Corn

an

v~

iiii~

F

v~rnrnentalP~~ctionAencon August

2,

1984

New

jte~

p

•ls ar~also manufactured in that shop, and it is ~

coa~L:g ~1~ation of those pails which is the subject of this

var~.

~

tac drums manufactured by Petitioner,

the pa~ls

~re

~c

t~

~t~re paint,

oil, adhesives,

flammable liquids, aid

59~219

---

c’the~ r eterics

Those

produced

for

sh~p~inohazardous

materials

are

‘~ubect to

Vn±t~dStatca

Departmert

ot

Transportation

regula~

ticr;~

dive:.

rPoc~ recurremente~

lcr~g witi

lie

variety

of

cuStZJ~’.

specifcetio4s

Pct1ttcrer

La

not

teen

succesful

in

findini

accep~ablr

coatIngs

to

snbst

te

those

currently

used.

At

the

pail

slici

the

extaric~

c~

~r~trior

coatings

ar~

applied

by

spray,

foliowec

by

~‘ekrn

rhC

coatings

curren

I

sn

use

were devcioper’

£~

(Odf1~

~

Thr

a

5

301

of

35

II)

1dm,

Code

215:

Organic

~icLerial

Eai’s~c~

~

s

and

Limitations,

which

is

the

general

rule

adopted

in

19/2

by

the

Board

to

regulate

emissions

of

enutfr~

~r

oaf irked

as

uhotochemically

reactive.

Under

Seotion

2i5.l~~:~)

the

rule

adopted

ir

1982

to

reguiate

the

emiss~ons of

~

rile

organic

materials

(VOM)

from

coatrq

operations

~t.

:~cr~ris

required

by

December

31,

1983

to

use

ererro;,

wtlene

rerformance

coatings

containing

no

more

thaa

1.5

p~t;i

c,ehon

(lbs/ga’)

of

VOM

and

interior

coatings

contalning

sr’

~c~e

~Xan

4~3 lbs/gal

of

VON

(subparagraphs

and

(U,

respectivry,

of

Section

215.204(j).

The

average

W

I

content

of

‘~1e

~xteLir

coatings

applied

in

1983

by

Petino

er

was

4,93

lbr,gai,

and

the

average

for

the

clear

coating

anc

interior

lining

was

5.93

lbs/gal.

(Pet.

4),

Petitioner’s

pail

coating

operation

alb

includes

applying

to

some

of

the

pai~s

marufacturec

a

rt~t

innibitor

orior

to

tIe

interior

coatir

which

is

kno’n

~ne

underlining

Since

the

underlining

clear

coat,

hr

ns

iterior

coatrng.

VOP

content

is

~imrtc

to

4~u lbs/gas.

Sn

398~,

Jc.

~tvr

manufactured

1,212

358

pails;

in

19

‘

,00~~J~0paU

e~

~r’er

the

next

ttrw’

yaars

Petitione

j

~ts

that

tee

produn.

an

;:oe

will

cort~~e

~c

dt~c.tne,

possibh

990,000

pails

in

1966.

(Am.

Pet.

Tare

—

.

Using

1983

pr.

notion

rates

and

coatIng

~eage,

the

Agency

calculated

and

compared

the

actual

emissicas

to

the

emissions

allowaLle

under

Section

2~.204(j).

In

app!yn;

11

0~J’

~lions

of

exterior

coatings

Petitioner

~mrtted

11.97

tons

;‘

p~c.

~aereas

only

17

~l

:ons

per

year

woull

~avs

.oten

allowed.

~.n

~1zing

7,091

gallons

of

interior

coatings,

“etitionera-~

o;~

~sOfl? emitted

4i~0

rons

that

year,

wher~~

~nly

1,05

tans

~~er

~

mId

4~avebean

a~owed

Combined,

the

a

tual

emissions

amoannd

ic

63

00

tons

~ha~

yea;,

while

only

22.33

tons

wiuld

‘aavo

tce~. al~nnl

if

Sectcon

213

~

jg

had

been

in

efUct,

Rec,

2-..’.

It

~y

t’olatile

otg

nrc

emissions

would

have

to

:e

reduced

h~ 53.4

am

the

exteri”.

rutlega,.

and

by

73.9

Thom

Ito

::,terior

con::

.jc

or

:n

other

rods3

achieve

a

combined

reduct~on

of

61

21

For

both

its

?ntertor

and

extenur

coatLng

operations,

tierican

St~.~al

nas

.~nn‘stigated

achie.uicg

compliance

with

its

costing

supriins.

~cader

coat.In-a

car

led

tu.

date

were

unaccept-

able

because

they

p;o~”ed insufficient..y

cesintant

to

the

harsh

chemical

ex;ssze

au~eptaale

watenrr

ad

coatings

are

also

not

let

available

as

subscicutes

for

tnre~

nscone~

The

equipma:t

uece~sary,

the

curirg

time

and

tempentore

required

and

the

odor

associated

with

available

water—based

coatings,

prohibits

their

59~22J

---

use at this

time..

Substitute coatings containing

1,1,1—trichioro—

ethane and methylene chloride, which are exempt

VOl.1,

are not

possible since direct exposure of these materials

to the necessary

baking temperatures produces hydrochloric acid,

arid possibly

phosgene gas, which are toxic and corrosive.

New

ovens would be

necessary in order to switch to these exempt

halogenate.d solvents,

Afterburners proved economically unreasonable to

install and

operate..

Vapor recovery was not feasible due

to

the various

blends of solvents needed for the wide variety

of coatings~

Carbon adsorption was also not feasible due to

the high volume of

air used by

the

equipment,

and due to insufficient

space

ton: such

a system.

Electrostatic spray equipment was not

economically

reasonable due to high installation and maintenance

costs

asia ive

to marginal reduction in emissions.

American

Steel,

alc::

vnith

its suppliers,

is still investigating powder

coatings and

ultra-

violet curing systems.

(Pet.

11—14).

Until

either of nhescn

or

other low solvent coatings are developed and tested,

Ainier:Lcan

Steel claims that implementation of any of the

other alt.eanatives

listed above would impose an arbitrary and

unreasonable hardsh:Lp.

Petitioner’s operation is too small to persuade

coating

vendors to develop compliance coatings for its

operation.

Its

two principal

suppliers, both national concerns,

indicate difficulty

in developing high solids or water—borne coatings

satisin’iny

its

needs,

In 1983, Petitioner did undertake three

tests with experi~

mental exterior coatings

from three different

suppliers.

nil

proved unacceptable primarily due to the need to

increase curing

time which was incompatible with the existing baking

systar..

Nevertheless, Petitioner is remaining actively

involved ía soaking

and testing other experimental exterior coatings.

(Am. Pot.

2—4).

Development of acceptable interior coatings

and liners

apparently more difficult, especially in the case of

the underliners.

Since these are intended to inhibit rust, water—borne

coatiups

are

not

an

alternative.

Secondly,

due

to

the

epoxy

and ~phertoiic

resins,

use

of

certain

solvents

is

inhibited..

Finally,

high

solid content is not an alternative since a very

thin light

coverage is required.

The

underliner

used

by

Petitioner,

which

weights about 7.0 lb/gal, contains only 0.3 lb/gal

of solids by

weight.

To avoid this problem, Petitioner is

purchasing

recoated

cover materials, thereby eliminating the lining

operation at

tiLO

facility.

(Pet.

6,

11).

When

low solvent coatings become availab1e~

Petitioners

acknowledge that minor equipment changes will be

necessary~

possibly in the area of $10,000.

The new formulations will

aJ~c

cost more, possibly 25 to 50 percent more than

present coatiago

cost.

Annua.y,

this could range between $40,000 and $50,000.

American Steel

is agreeable to such modifications and

additional

costs once commercially viable materials are available.

(Pot.,

12).

In the costs once meanwhile,

Petitioner intends to

continue searching

for compliance coatings or new coating processes,

such

as

ultra-

violet curing, along with its

suppliers..

59-221

---

—4—

iri

its Recommendation,

the

Agency

agreed

that

until

reformu-

lated coatings

axe

available,

compliance

can

only

be

achieved

by

the

installation of afterburners.

In

addition

to

agreeing

that

~

costs and

fuel consumption are high, the Agency noted that

afterburners would only be

used during the ozone season pursuant

to

Section

215.106..

Therefore,

annual emissions would be further

reduced

if

low solvent coatings are developed and used as opposed

to afterburners..

(Rec.

4,

5)

The Agency’s Recommendation also

outlined

a

compliance

schedule

it

alleged

to

be

acceptable

to

the

Petitioner.

By

December

of

1984,

the

average

volatile

organic

material

content

of

the

exterior

coatings

should

be

reduced

to

4.2

lbs/gal,

and

by

December

of

1985,

it

should

be

reduced

to the

compliance maximum limit of

3.5

lbs/gal.

The

average

VOt’I

content

of the interior coatings should be reduced to 5.6 lbs/gal by

December of 1984, and to 5.4 lbs/gal by December of 1985.

(Rec,

4).

Since this schedule does not anticipate an interior compliance

coating being available at the expiration of variance,

it is

assumed that an alternative method, such as the internal offset

provision contained in Section 215.207, will

be used by

the

Petitioner to demonstrate compliance at that time.

The Agency requested as a condition to variance that American

Steel be required to submit operating permit applications by

October

1,

1985 which demonstrate compliance pursuant to the

internal offset provision,

The

Board will not condition the

variance in

this

manner since Petitioner is required to apply for

operating permits no later than that date pursuant to Section

201.162, and because Petitioner may choose to demonstrate compli-

ance

by

a means other than the internal offset provision

at that

future

date.

The Board agrees that coating reformulation is the most

environmentally

sound

means of ultimate compliance,

it

finds.

American Steel has adequately

demonstrated that compliance through

the

other

alternative

methods

at

this

time

would

impose

arbitrary

and

unreasonable

hardship

at

its

pail

operation..

Any

environmental

or

health

danger

should

be

alleviated

as

necessary

under

~

I~piscde Action

Plan,

Variance

from

Section

215,204(j),

and the

attendant

compliance

rules

is,

therefore,

granted

subject

to

th~

conditions

set

out

in

the

Order.

This

Opinion

constitute8

the

Board’s

findings

of

fact

and

conolusionø

of

law

in

this

ORDER

Petitioner,

American

Steel

Container

Company

is

hereby

granted

a

variance

for

its pail shop coating operation at

its

facility

at

4445

West

5th Avenue, Chicago,

Illinois from July 1,

1984

until

December 31,

1985 from Sections 215,204(j)(i) and

(3),

215.211

and Appendix C at 35 iii. Mm, Code 215, subject to the

following

conditions.

5~-222

---

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 percent

solids by volume and weight, percent volatile organic material

(VOM) by volume and weight, percent 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

Maywood, 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 exterior coatings by

December

31,

1984 as follows:

~eVOMcontent

Exterior

4,2

lbs/gal

Interior

5.6

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:

59-223

---

—6—

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..

unn,

Clerk

Illinois Pollution

Control

Board

59-224