ILLINOIS POLLUTION CONTROL BOARD

August 22,

1984

ENGINEERED COATED PROEUCTS, INC.,

Petitioner,

v,

)

PCB 84~5O

ILLINOIS

ENVIRONMENTAL

PROTECTION

AGENCY,

)

Respondent.

OPINION AND ORDER

OF THE BOARD

(by J.

Theodore Meyer):

On April

2,

1984, Engineered

Coated Products,

Inc.,

(Engineered)

filed a Petition

for Variance

for

its facility which coats and

laminates high

performance, pressure

sensitive

adhesive

tapes for

use

in the automotive and major appliance industries.

Specifically,

Engineered

requests variance from 35

Ill. Adm.

Code 215.204(c)

(formerly

Rule

205(n)(1)(C)

of Chapter

2)1

until

November

15,

1984.

That

regulation contains the

emission limitation for

operations such

as Engineered~s.

Attendant to that

rule

are

Sections 215.211

and

215.212 which contain

the relevant

compliance

plan requirements and

compliance date of December 31,

1983.

Variance from

these regulations was

already granted by the Board

in ~4neered

Coated product~~Inc,

V.

Illinois Environmental

~

(PCB

82~2;

49 PCB 213) on October 28,

1982

until April

1,

1984.

Engineered

is now seeking to extend variance

until November

15,

1984.

On May

3,

1984,

the Board ordered Petitioner to file additional

information,

On

May 29,

1984,

Petitioner filed

an

Amended Petition

for Variance with

the

Agency.

The amended petition

requested

the

incorporation of the prior record in the case of PCB ~82-~2~

Coated Products Inc.,

v.

Illinois Environmental Protection ~

The Illinois Environmental Protection Agency filed its Recommendation

on June

27, 1984.

A hearing

was

held on July 9,

1984.

No members

of the public were present

and

no

public comments

have

been

received by the

Board in

this matter,

Petitioner

owns and

operates a facility at 2800 Shermer

Road, Northbrook

which

coats and laminates high performance,

pressure sensitive

adhesive

tapes

for use

in the automobile and

major appliance industries,

Included

in Petitioner~s

facility

is

one coater/laminator machine which applies adhesives

to paper,

foil,

film, and other miscellaneous materials.

After application

of the adhesives,

the

materials are dried in a

gas—fired oven.

Petitioner utilizes

in excess of 40

different

adhesives which

contain volatile

organic material

(hereinafter,

~VOM~).

59~425

---

2—

215~2O4(c)

requires that the VOM content in Petitioner’s

adhesives

be limited to

2.9 lb/gal

(0.35 kg/I).

:L9@3,

Petitioner applied 670,616

pounds of

adhesives.

The resultant

VOM emissions were 332,869

lb/yr or

166 ton/yr~

Petitioner’s

allowable VOM emission rate

for 1983

was 135 ton/yr.

Thus,

the

1983 emissions exceeded

the allowable

limitation by

approximately

23,

(Am.

Pet,)

The

compliance plan envisioned

by Petitioner

during its

previous variance

sought to replace

its high VOM

adhesives

with

other adhesives

having

lower VOM contents.

To

date, Petitioner~s

reformulation

program has been only

partially

successful,

Since

1981,

it has

reduced the average VOM

content of its

adhesives

from

3~9

lb/gal

to 3.56 lb/gal.

Petitioner

does

not believe,

however, that

it will be able

to

further

reduce to

the required

2.9

lb/gal

limitation in the immediate

future.

For

that

reason,

Petitioner is

now planning to achieve

compliance in

accordance

with

Section

215.205, Alternative

Emission

Limitations, by install-

ing a

catalytic

afterburner with

a

destruction

efficiency of

at

least 95.

The specifics of Petitioner’s compliance program are

as

follow~

May

15,

1984

Place purchase order

JUne

15,

1984

Commence

construction

October

15,

1984

Complete construction

November

15,

1984

Demonstrate compliance

The cost

of the controls will be

approximately

$164,000.

The

Agency

is of the opinion that

Petitioner~s

compliance

program will bring

it

into

compliance

in an

expeditious

manner.

The Agency

does

not

necessarily

believe,

however,

that

the

installa—

tion of an

afterburner

is

the

most

environmentally

sound

means

of

achieving compliance.

in addition to being

extremely

costly

to

install and

operate, afterburners also

consume

vast

amounts of

sometimes

scarce natural gas.

Afterburners

also

produce emissions

of nitrogen oxides which are a major factor in

the

formation

of

ac:Ld rain

and ozone.

Moreover, pursuant

to the

provisions

of

Section 215.106,

the afterburners would

only have

to

be

operated

seven months

a year.

Thus the annual VOM emissions are likely

to

be

greater if

afterburners are utilized

to

achieve compliance

than

if

reformulation

is

utilized,

For

that

reason,

the

Agency

believes that

efforts

to

develop

low

solvent

coating

technology

should he encouraged.

The

Board

notes

that VOM

emissions

in

non-

ozone season

months

are

not

a

relevant

issue,

Petitioner’s

facility

is

located

in a mixed

commercial/resi—

dentia:i area,

The

nearest

residences

are

approximately

800

feet

west of the

facility.

The

Agency

has

received no

complaints

from

area residents

concerning

Petitioner’s

variance

request.

59-426

---

rhe

emissions in question are volatile organic materials

which

~ontribute to the formation of ozone,

High levels of ozone

cci

nc~veadverse health effects on the elderly and persons with

respixauoiy and cardiac problems.

The Agency believes, however,

that t~e extension of the compliance deadline sought

by

Petitioner

~ nt. cause any increased health effects.

During the period

of th~variance, Petitioner will be expected to

comply

with its

eptsode action plan which requires reductions of emissions during

pe~ivisof high ozone concentration.

~ioner’s

facility is located in ar area which has been

cuts~

ied as nonattainment for ozone,

The closest ozone monitoring

st~tr~isare located in Arlington Heights which is approximately

ei~htmiles to the southwest and in Skokie which is approximately

seven a’

es to the southeast,

In 1983 the primary ambient air

quality standard for ozone of 0.12 ppm was not exceeded at either

monit r

For the following reasons, the Board agrees that a denial of

th~requested variance would constitute an arbitrary and un~

rec sortable hardship:

a,

Petitioner has been diligently working to reduce its

VON emissions for several years.

vi

The Agency believes that Petitioner’s present efforts

to achieve compliance will

be

equally as diligent.

r

During the variance period, the facility would stiL

be

tr~jectto the episode regulations contained in Section 244

iring periods of high ambient ozone

levels,

~$e

Aciency does not disagree with any factual allegation

as.

in Petitioner’s Petition for Variance or

in the Amendments

accordance with the provisions of Section 35 of the Act,

~i:

amended August

2,

1978, by P.A, 80~1299, Ill. Rev. Stat.,

Chaptc~111½,

Section 1035,

the Board may grant variances only if

viey crc consistent with the provisions of the Clean Air Act 42

U.S.C

~IO1, et.

seq.

In the present case,

Petitioner’s control

ioc’rarr

is identical to one that Petitioner has agreed to implement

~.

~r:u~

to a Consent Order entered into with the United States

Environmental Protection Agency.

(See ~Exhibit 1”)

(Rec.

4)

1~’orthat reason, the Board grants Petitioner variance from

S~cvioovi5.204(c) and the attendant compliance rules, subject to

conaiviors set out in the order,

Variance

is granted

until

December 15,

1984 although Petitioner expects to achieve compliance

on or Tho~tNovember 15, 1984,

The additional month is allowed

~v th~tarty unanticipated difficulties can be corrected during

The ~r

‘~

of the variance,

59-427

---

This opinion constitutes the Board’s findings of

fact and

conclusions of law in this matter.

Petitioner, Engineered Coated Products,

Inc.,

is hereby

granted

a variance for its coating and laminating facility located

in Northbrook,

Illinois, from April

1,

1984 until December 15,

1984 from

35

Ill Adm. Code 215, Section 215,204(c)

(formerly Rule

205(n)(i)(C)

of

Chapter

2)

and

Sections

215.211 and 215.212

subject to the following conditions:

a.

On or before November 15,

1984, Petitioner shall per~

form a stack test on its afterburner in accordance with the

special condition set forth in Construction Permit #84050016.

Petitioner shall notify the Agency of the date of said stack

test at least 14 days prior to the test, and the Agency

shall be allowed to witness the test and review all test

data,

Notification shall be made to the Agency at the

following addresses:

Environmental Protection Agency

Division of Air Pollution Control

Control Programs Coordinator

2200 Churchill Road

Springfield,

Illinois

62706

Environmental Protection Agency

Division of Air Pollution Control

Region

1,

Field Operations Section

1701 South First Avenue

Maywood,

Illinois 60153

vi

On or before December 15,

1984,

Petitioner shall apply

to the Agency for all requisite operating permits.

C.

Within 45 days of the Board’s Final Order herein,

Petitioner 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 the addresses specified in Paragraph (a),

~

The 45 day period shall be held in abeyance during any

period that this matter is being appealed.

The form of

Certification shall

be as follows:

CERTIFICATE

I,

(We),

___

,

having

read the Order of the Illinois Pollution Control Board in PCB

84~50,dated August 22,

1984, understand and accept the said

Orders

realizing that such acceptance renders all t~r~s

and

59-428

---

conditions

thereto binding and enforceable.

Engineered Coated

Products,

Inc.

By:

Authorized

Agent

Title

Date

IT

IS SO ORDERED.

I,

Dorothy M.

Gunn, Clerk of the Ill:Lnois Pollution Control

Board, hereby certify that the above Opinion and Order was adopted

on the ~

~

~‘-z~~?

day of

________________,

1984 by a vote

of

~

(~)

)

Dorothy

M~ unn,

Clerk

Illinois

~Pollution

Control Board

59-429