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ILLINOIS POLLUTION CONTROL BOARD

March.

10,

1983

THE

MEYERCORD

MP,

Petitioner,

v~

PCB 82-53

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

MS. MARY C. BRYANT, CHADWELL & KAYSER, LTD., APPEARED ON

BEHALF OF THE PETITIONER;

MR. PETER E. ORLINSKY, ATTORNEY AT

LAW,

APPEARED ON BEHALF

OF THE RESPONDENT.

OPINION

AND

ORDER OF

THE BOARD

(by D. Anderson):

This matter comes before the Board upon a petition for

variance filed April 22,

1982 by Meyercord Company

(Meyercord),

requesting a variance from the volatile organic compound

(VOC)

regulations of Rule 205(n) (1) (C)

of Chapter 2:

Air Pollution

for a surface coating operation in Chicago.

Because the

procedural history has become somewhat complex, the essential

items will be listed:

April 22, 1982

Variance petition

June

3, 1982

First amended. petition

July

12, 1982

Recommendation

August

12,

1982

Second amended petition

(with. separate

compliance plan)

December 15, 1982

Stipulation of fact

(Third amended

petition)

December 15, 1982

Hearing

December 29,

1982

Response to request for additional

information

(Fourth amended petition)

February

1, 1983

Amended Recommendation

The stipulation of facts and response to request for

additional information have been designated the third and

51-253

---

—2—

fourth amended petitions

(Order of January 13,

1983)

Addi-

tional factual information may be introduced by the petitioner

only by filing an amended variance petition pursuant to 35

Iii.

Adm, Code 104.181.

The July

12, 1982 recommendation was that

the

variance

be granted with conditions.

The Agency did not amend this

recommendation until after the hearing.

The main disagreement

was

the

length

of

the

variance

to

be

granted,

On February

1,

1983,

the

Agency

recommended

that the variance be granted

for three years with conditions,

The Board has received no

public comment.

The facility in question is situated at 1828-58 West

Hastings Street,

Chicago.

The plant employs 15 people in a

mixed residential and industrial area on the southwest side

of Chicago.

It manufactures udecalomania transfers~, also

known as decals, transfers or markers.

These generally con-

sist of a plastic film with an adhesive coating and a paper

backing which is removed before the decal is applied.

A number of coating operations involve the release of

VOC.

These include adhesive coating and application

of non-

stick coatings to backing paper,

The product passes to a

four—zone gas—fired dryer oven.

The emissions from the oven

are vented to the atmosphere through two stacks,

Solvents

include ethanol, isopropyl alcohol, ethyl acetate, n-propyl

acetate, methyl ethyl ketone, toluene

and

heptane~

Rule 205(n) (1) (C)

limits this paper coating operation to

0,35 kg/l VOC, effective December 31, 1982.

This amounts to

76.5 tons per year compared with actual emissions of 135~4

tons per year.

Compliance alternatives include installation

of

equipment

to capture and recycle solvents, equipment to burn solvent

fumes and product reformulation.

Solvent recapture has been

ruled out because the resulting liquid mixture cannot be

economically separated by distillation.

Burning would require

installation of equipment costing about $500,000

and

structural

modification of the building.

This would require a zoning

variance.

Meyercord has elected to proceed by way of product

reformulation.

The main thrust of this involves development

of high solids content and water based adhesives.

Meyercord

has already eliminated some operations emitting

VOC

and

reduced emissions in others.

It has achieved a 38

reduction

in VOC emissions since 1980

(R.

10).

51-254

---

—3—

Meyercord originally requested a one—year variance, but

upped this to

three years,

which the

Agency

opposed in the

July 12 recommendation,

The “stipulation~specifies that

within

12 to

18

months

an additional

40

reduction in

VOC

emissions

is

possible

through continued work with high-solids

vinyl solution adhesives and polyester emulsion

adhesives

and

new production methods.

These will not bring Meyercord into

compliance with Rule 205 (n) (1) (C).

Compliance will require

development

of

an

emulsion

adhesive

which

is

an

adequate

substitute for the highest use vinyl acrylic solution adhesive.

In the February 1 recommendation the

Agency

agreed that

three

years would be needed to develop the coatings.

The

Agency believes

that Meyercord will be able to come

into compliance through

development

of new

adhesives,

but

notes that Meyercord has

committed itself to the installation

of an afterburner should it fail (Amended

Recommendation,

paragraph 6).

VOC emissions are thought to cause elevated ozone levels

in the atmosphere.

The nearest air quality

monitoring

station

is about four

and

one-half miles northeast

of

the plant

at

Lincoln Park Zoo,

During 1981 no readings exceeded the ambient

air quality standard of 0.12 ppm.

The Agency noted that Meyer-

cord has an episode action plan which provides sufficient

safeguards

during

periods of high ozone concentration

(Amended

Recommendation, paragraph 12).

The Agency is of the

opinion

that the grant

of

a variance

would require amendment

of

the

State

Implementation

Plan

(SIP)

and

that

the

variance

would

be

approvable

as

such,

The

Agency

will

submit

it

as

a

SIP

revision,

The

Board

finds

that,

considering

Meyercord~s progress

toward

compliance,

its

episode

action plan and the technical

and

zoning

difficulties

in

installing

control

equipment,

Meyercord

would

suffer

arbitrary

or

unreasonable

hardship

if

required

to

comply

with

Rule

205(n)

(1)

(C)

immediately.

The

Board

will

grant

the

variance

for

three

years,

subject

to

conditions

similar

to

those

recommended

by

the

Agency

on

February

1,

1983.

The

Board

will

also

condition

the

variance

on

a

cap

equal

to

present

emissions,

This

Opinion

constitutes

the

Board~s findings

of

fact

and

conclusions

of

law

in

this

matter,

ORDER

Petitioner,

Meyercord

Company,

is

granted

a

variance

from

Rule

205(n)

(1)

(C)

of

Chapter

2:

Air

Pollution

for

its

plant

at

1838-58

West

Hastings

Street,

Chicago,

subject

to

the

following

conditions:

51-255

---

—4—

1.

This

variance

will

expire

January

31,

1986~

2.

Petitioner

shall

not

emit

more

than 135 tons of

volatile

organic

compounds

(VOC)

during

any

calendar

year

ending

during

the

term of this

variance.

3.

On or before April 30,

1983,

and

every

three

months thereafter, Petitioner shall

submit

a written report to the Illinois Environmental

Protection Agency detailing all progress

made

in achieving compliance with Rule 205(n)

(1) (C)

during the preceding calendar quarter.

This

report

shall include information on the quantity

and

VOC

content of all coatings utilized during the quarter

and a description of

the

status of the reformula-

tion program.

The report shall be sent

to

the

following addresses:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Control Programs Coordinator

Springfield, Illinois

62706.

Illinois Environmental Protection Agency

Division of Air Pollution Control,

Reqion

1

1701 South First Avenue

Maywood, Illinois

60153.

4.

Within forty-five days of the date of this Order,

Petitioner shall apply to the Agency

for

all

opera-

ting permits required pursuant to Rule

103(b)

(6)

(A)

of Chapter 2.

5.

Within forty-five days of the date of this Order,

Petitioner shall execute and forward to

the

Illinois

Environmental Protection Agency, Variance 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 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:

CE1~i?IFICATION

I,

(We,)

_____________________________

having

read

and fully understanding

the

51-256

---

—5—

hereby

accept

that

Order

and

agree

to

be

bound

by

all

of

its

terms

and

conditions,

SIGNED

____________________

TITLE

_____________________

DATE

_______________________

IT IS SO ORDERED.

Board Member Nega abstained.

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

Control Board, hereby certify that the abpve Opinion and Order

were adopt~edon the

/O~

day of

/)7.~/~

,

1983 by a

vote of

~/-D

~ ~

,~j4~f.(

Chris~aniL. Nöff

Clerk

Illinois Pollutioft Control Board

51-257