1LL:cNoIs

POLLUTION

CONTROL BOARD

February

10,

ALL—STEEL,

INC.,

Petitioner,

PCB 82—110

ILLIt~TOIS

ENVIRONMENTAL PRO~CT1ON

AGENCY,

Resp~dent.

ANTHONY

P.

FERRUCCI,

JR~ ENVIRONMENTAL ENGINEER, CHROMETRICS

LABORATORIES,

INCORPORA~IEDFAPPEARED

ON BEHALF OF PETITIONER.

PETER E. ORLINSKY,

TECHNICAL

ADVISOR, APPEARED ON BEHALF OF

RESPONDENT.

OPINION AND ORDER

OF THE BOARD

(by

I.

G.

Goodman):

This

matter

is before the Board upon the September

9,

1982

Petition by

All—Steel,

Inc.

(All—Steel) for variance

from

Rule

205(n)(1)(G)

of

Chapter

2~i

Air

Pollution

(Regulations) for its

facility located

in

Montgomery,

Illinois.

Hearing was held on

January 17,

1983 pursuant to the September

15,

1982 Board Order

herein; there

was

rio citizen

testimony at the hearing and the

Board has received no

public comment

in this matter.

All—Steel owns

and operates

a

metal office furniture manu-

facturing facility

which

includes

6

paint

spray booths and

3

paint dip tanks

which apply

surface coatings to its products.

All—Steel utilizes

in

excess of 100 types and colors of indus-

trial finishes

which are

subject to the limitations

of Rule

205(n)(1)(G), which

Rule

requires compliance by December 31,

1982.

It is the intention of All—Steel

to achieve compliance

with the Regulations

with

the use of high solids,

low VOC coatings

by December 31, 1983~ This compliance plan

is

associated only

with the spray booths

since

A11—Steel~sdip tanks were apparently

in compliance by the December 31,

1982 deadline.

All—Steei~soriginal compliance plan (instituted

in January,

1980 pursuant to

the Regulations)

contemplated total compliance

by the deadline,

but

unforeseen problems necessitate an additional

year in which

to achieve

compliance,

All—Steel alleges that by

December 31,

1983

it will correct the deficiencies

it

has

exper-

ienced with

respect to the quality of the reformulated paints

and the inadequacy

of punning and

recirculating paint systems

and the electrostatic spray equipment.

The

Illinois Environrnental

Protection Agency

(Aqeocy)

in its Recommendation

states that the

51-129

---

2

additional one—year

perioa

of time requested by All—Steel to com-

plete conversion of its

stem is reasonable.

The Agency notes

the

problems

associated tith reformulation of coatings where

customer approval tests and equipment modification is necessary.

All-Steel s faci ity

s located in an industrial area with

the nearest residerce o~proximatelyone mile distant.

The Agency

has

received

no

conpta

r

t

oncerning

the

petition

but

has

received

a

letter

frau

tie

Za

e

County

Environmental

Department

which

the

Agency

characterires

as

‘a

formal

objection’

to

the

variance

request

Tte

Agency

states

that

attempts

to

ascertain

the

nature of the obec.tion

have thus far been unsuccessful.

The Agency belie~esthat the extension requested in the

instant petition will rot cause any increased health effects

and

that compliance with its episode plan by All—Steel will

result in a reduction of emissions during

any

period of high

ozone concentration

A1—Steel’s facility is located in an area

which is classified as

Non

attainment for ozone, apparently

based upon the prior

State

Ambient Air Quality Standard of

0.08

ppm.

In 1981

the 0 12 ppm Federal Ambient

Air

Quality

Standard

was not

exceedeo

at the nearest monitor

ip Glen Ellyn.

In 1979, a high production year, All-Steel emitted 1500 tons of

VOC.

Under

Rule 205 n(1)(G), All—Steel would have been limited

to 978 tons in 1979.

The Agency recommends grant of the variance based

upon

the

fact that All—Steel Las been diligently seeking a means to reduce

its

VOC

emissions

its episode action plan provideS sufficient

safeguards during periods of high ozone concentrations, and the

proposed period of non- C.

up iance is only one year

•

In addition,

the Agency notes

that the alternative to the variance would be

the costly installation of

thermal

incineration controls and the

usage of a non—reaewab4e

:esource.

The Agency believes that the

variance, if grated

a

a4- Me

aubaitted

to

the

U.S.

Environmental

Protection

Agency

as

a

revision

to

the

State

Implementation Plan

and

states

its

intention

to

so

proceed.

The

Agency

therefore

recommends

a

grant

of

variance

subject

to

certain

conditioffs.

As

the

Agency

states

i’t

its

Recommendation,

when

the

Board

adopted

the

VOC

ems sato’i

jimitations

in

1979,

it

recognized

that

the

regulations

woul I

be

technology

forcing

and

anticipated

the

use

of

the

variance

procedure

for

relief,

if

necessary.

Consider-

ing

the

evidence

pre°ent

and

the

lack

of

apparent

environmental

harm,

the

Board

will

grant

the

proposed

variance

subject

to

certain

conditions.

This Opinion constitutes the finding of facts

and

conclusions

of law of the

Board

in

this

matter.

51-130

---

3

ORDER

I.

All—Steel,

Inc.

is

hereby

granted variance from

Rule

205(n)(l)(G)

of chapter

2:

Air Pollution from January

1,

1983 till December 31,

1983 subject to the following

conditions:

a.

Starting

March

1,

1983 and

every

three

months

thereafter,

All—Steel shall submit written reports to the Illinois

Environmental Protection

Agency

reporting

progress

made

in achieving compliance with the Regulations.

These

reports

shall include information concerning the quantity

arid

VOC

content

of all coatings utilized during the

reporting period, the status of the reformulation program,

and any other information which may be requested by the

Agency.

b.

Within

forty~five

days

of

the

date

of

this

Order,

All—

Steel,

Inca shall execute and forward to the Illinois

Environmental Protection Agency,

2200 Churchill Road,

Springfield,

Illinois 62706,

a Certificate of Acceptance

and Agreement

to be bound to all terms and conditions of

this Order,

This forty-five 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 82—110,

dated

_____________________________

understand

and accept the said 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,

hreby ce~ifytha~the above Opinion and Order

was adopte4\on the

/~

day of

~Jy’uL~—

,

1983 by a

vote of

~

Christan

L.

Moffe~1(~~’C1erk

Illinois

Pollution

Control

Board