ILLINOIS
POLLUTION CONTROL BOARD
May 5,
1983
GEORGIA~-PACIFIC
CORPORATION,
)
Petitioner,
)
PCB 82—142
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
Respondent.
BEVERLY
V.
GHOLSON, APPEARED ON BEHALF OF GEORGIA-PACIFIC CORPORATION.
PETER E. ORLINSKY, APPEARED ON BEHALF OF THE ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY.
OPINION AND ORDER OF THE BOARD
(by W.J. Nega):
This matter comes
before the 3oard
upon
a December 14,
1982
petition for
variance
filed by the Georgia—Pacific Corporation
(Company);
as
amended March
7,
1983.
The
Company
has requested a
two year variance from Rule 205(n)(1)(C) of Chapter
2:
Air
Pollution Regulations
(Chapter 2)
to
allow
it
to delay compliance
with the emissionlimitation
for volatile organic compounds (VOCs)
discharged
from its paper coating lines.
On December 14,
1982,
Beverly V. Gholson, an attorney licensed in Georgia but not
in
Illinois,
filed a
Motion to Appear before the Board on behalf of
the Company,
which
was granted on December 16,
1982.
On January 7,
1983,
a letter of
objection to therequested
variance was filed by
Mr.
and
Mrs.
Charles
Mitchell
who live near the Petitioner’s
plant.
On
January 24, 1983,
the
Illinois Environmental Protection Agency
(Agency)
filed a recommendation that the
variance
be
granted
until
December
31,
1984,
subject to certain conditions.
A hearing was
held
on March
16,
1983.
The Company owns
a printing plant, originally
established
in 1901,
which is located at 201 West 6th Street
in
Lockport,
Will
County,
Illinois
in a mixed residential and industrial
area.
The plant, which is between the Illinois & Michigan Canal
and the Illinois Central
& Gulf
Railroad
rights-of—way,
is
located
along
a highly industrialized corridor near both a Texaco and
Union Oil refinery.
The nearest residents live about one block
south of the Petitioner’s facility.
The
Company’s printing
plant, which manufactures multi—colored paper labels used
primarily for canned
food
products, presently employs 16 full-
time
salaried employees and 103 hourly employees and produces
revenues of over
$13
million annually.
Included in its Lockport
facility
are
two 35-year old Christensen varnishers which are
used
to apply a
high-gloss protective varnish coating on the
52-137
—2—
printed
labels
to give the labels protection from the wear
and
tear,
rubbing, and scratching encountered in the shipping
and
handling of canned goods.
The varnish coating utilized by the Petitioner contains
VOCs which are emitted into the atmosphere through
5 separate
stacks located on the roof of the Company’s main building.
Rule 205(j)
of Chapter
2 requires that paper coating operations
must he
in
compliance wtih Rule 205(n)(1)(C) of Chapter
2 by
December
31,
1982. Rule 205(n)(1)(C) of Chapter
2 limits VOC
e~iss~onsto 2~9lb/gal.
In 1982,
the
Company used an estimated 12,600 gallons of
varnish
and
9,666 gallons
of apcolene
(i.e.,
a thinner)
in its
~:otective varnish coating.
The average VOC content of this
protective coating was 4.99 lb/gal.
Accordingly, VOC emissions
i:~ 1982 from the two Christensen varnishers were 55.6 tons.
I
Rule 205(n)(i)(C)
of Chapter
2 had been in effect in 1982,
the Cornpanyts
VOC emissions would have been limited
to 32.3 tons.
The Petitioner has indicated that it has been unable
to meet
the requisite compliance date because “at present, technology does
not exist for low solvent (high solids) and/or water—based coatings”
which will emit lower levels of volatile organic materials and can
he utilized on the Christensen varnishers.
However,
the Company
has been diligently working with its suppliers to develop an
appropriate reformulation of its varnish coating to a high solids
or water-based coating which will result
in
a product acceptable
to its customers.
The
Agency believes that the necessary
reduction in VOC
enissions can be achieved through the proposed reformulation
p~un.
Past
efforts
i-n
~‘hi~vc~
compliance
include numerous trial
rns
of
various reformulated coatings which have,
to date,
proven
u~isatisfactoryas substitute coatinqs during extensive tests.
A
bernate methods
of
meeting the emission limit which were
investigated by
the
Company include
the
possible installation of
a catalytic fume incinerator or carbon adsorption system,
The most economical of
the various available emission control
systems was determined to be catalytic fume incineration.
However,
the cost of a catalytic incinerator unit would be approximately
$503,000, with an annual operating cost of $80,000,
and the overall
efficiency of the capture and control system would only be 55
to
60
due to the questionable efftciency of the fume capture
system
on
the 35-year old Christensen varnishers.
Additionally,
it
is likely that the roof of the building would not he able
to support the weight of such an emission control device and
extensive,
expensive ducting would be required which would
significantly increase the initial capital cost.
52-138
—3—
The City of Lockport,
which has a population of approximately
10,000 people,
submitted a letter to the Agency on January
6,
1983
which stated that it does not
object
to the Petitioner’s variance
request provided that the Company:
(1)
continue to conduct
trial runs to find an acceptable
low solvent paper varnish coating
and
(2)
conduct air monitoring tests
in the immediate vicinity
of
their
discharge point to ascertain the ozone levels
in that
area.
(See:
Ex.
A).
At the hearing, Mr.
Frank Mitchell
(the son
cf,
and spokesman for,
Mr.
& Mrs.
Charles Mitchell) directed
various
questions
to
Mr.
Keith
M.
Bentley,
the
Company’s senior
onvironmental
engineer.
Mr.
Bentley testified that the Company
is
‘~going
to
meet
the
standard
by
changing our formulations for the
varnishes
we’re going to put on,
Those varnishes are not available
right
now.
The suppliers are working on it...Alternate emission
control technologies are just prohibitively expensive.,.The
overall emission reductions we’re going to receive will be
at
least
equivalent to what we would get with the add on
control
equipment.
It will probably be greater.”
(R.
11-12).
Mr.
Bentley also indicated that the Company performed at least
9 trial
runs in the last year to test various varnish reformulations and
wa~firmly committed to further testing.
(R.
13—14).
In its petition,
the Company has pledged that when appropriate
test varnishes are developed,
it will perform at least four to
five
trial runs on its equipment per year at its own expense.
Each trial run costs the Company about $1,500.00 including time,
labor and materials.
After
such testing, the Petitioner will
submit periodic test reports to the Agency for review.
Concerning ozone,
as aforementioned,
the Company’s printing
plant
is
located
in a highly industrialized corridor area in
Lockport
and is about
1 block away from the nearest residents.
The
ciosest ozone monitoring station
is located about 1½ miles
south
of
the facility.
The 1981 Illinois Annual Air Quality
Report on ozone levels
in the Lockport area indicates that only
28 days were reported in which the ozone
level
exceeded 0.08 ppm,
0.11 ppm was the highest level reported;
and in no cases was the
0.12 ppm ozone standard exceeded.
The nearest ozone monitoring
station has shown that the ambient ozone standards have not been
exceeded in Will County for the last two years, and the Agency has
proposed to redesignate
the area as an ozone attainment area.
VOCs contribute to the formation of ozone.
High levels of
ozone may have adverse health effects, particularly
on
the
elderly
and on individuals with cardiac or respiratory problems.
However,
the Agency believes that the extension of the compliance deadline
sought by the Petitioner should not cause any increased adverse
health effects.
Thus,
the Agency further believes that
it is
unlikely that the Petitioner’s discharges would cause
or contribute
to
a violation of the ozone stand~rdand its episode action
plan
should provide sufficient safeguards during periods of high ozone
concentration.
52-139
—4—
The
Board
notes
that
the
VOC
emission
limitations
adopted
in
1979
in
R78—3,—4
were
intended to he “technology forcing”
and
it
was originally contemplated that the more restrictive standards
that c~ame
into
effect in 1982 might necessitate
some facilities
to seek variances until
the standards could be met.
it would
I~aunreasonable for the Board to impose substantial costs upon the
P.~:titioner
to
atta~n
immediate
compliance when there
is a sub—
stantial probability of new technology being developed during
the
v~árianceperiod which would allow compliance to he attained
at
a
much
lower
cost,
since
any
increase in health risks would he
nealiqihie.
The
Board
will condition this variance upon the use
of
coating materials
which
have
a
VOC
content less than or equal to
the
presently used materials.
A preferable technique would be
to impose
a limitation upon the total emissions of VOCs as well,
Unfortunately, the information presented in the record is
insufficient
to establish such a limitation.
The
only
figures
giver~are for the
198.1 and 1982 emission levels.
No indication
is given as
to potential,
or even expected,
levels, despite the
fact that an increase
in production
(as may be expected
in a
period of economic recovery)
will result
in increased emissions.
In the future,
such petitions should include historical monthly
emission levels
(for the last five
years, especially during the
ozone season of May to October,
if possible), projections of
emission levels during the period of variance, and potential
emissions based upon production capacity.
Therefore, the Board finds that denial of the requested
variance would cause an arbitrary or unreasonable hardship
upOn the Petitioner and concludes that variance should be granted
~nibjectto
the conditions recommended by the Agency,
which were
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This Opinion constitutes
the Board’s
findings of fact and
conclusions
of
law
in
this
matter.
ORDER
Georgia—Pacific Corporation
is hereby granted a variance from
Rule 205(n)(1)(C)
of Chapter
2:
Air Pollution Regulations until
December 31,
1984,
subject
to
the following conditions:
:1.
The Company shall expeditiously proceed with reformulation
of its varnish coatings
in
the manner outlined
in its
December 14,
1982 Petition.
During the period of this
variance,
VOC emissions
shall. not exceed 4.99 pounds
per
gallon
of
varnish
used.
52-140
—5—
2.
No later than June
1,
1983 and every third month thereafter,
Georgia-Pacific Corporation shall submit written reports
to the Agency detailing all progress made
in achieving
compliance with Rule 205(n)(1)(C)
of Chapter
2.
These reports shall
include information concerning
the quantity and VOC content of all coating
utilized
during
the reporting period,
a description of the status
of the reformulation program,
and any other information
which may reasonably be requested by the Agency.
The reports shall be sent to 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
3.
Withifl
45
days of the date of this Order, Georgia-
Pacific Corporation 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 2200 Churchill Road,
Springfield,
Illinois
62706.
The 45-day period shall
be held
in aheya~i.ceduring any period that this matter
is being appealed.
The form of said Certificaton shall
be
as follows:
CERTIFICATIOr~~I
I, (We)~~_,
hereby accepts and agrees
to be hound by all terms and conditions
o~the Order of the Pollution Control Board in PCB 82—142,
May
5,
1983.
Pet.itioner
Authorized Agent
Title
Date
52- 14 1
—6-
IT IS SO ORDERED.
I, thristan L. Moffett, Clerk of
the
Illinois Pollution
Control
Board,
hereby Cçrtify that the above Opinion and Order
was adopted on the
..“~__day of
___
_________
___
t983byavoteofj4.i_-
.
-2,•
~
—
thrtstan L. Motfe¼t, Clerk
Illinois Pollution Control Board
es-ia