ILLINOIS POLLUTION CONTROL BOARD

November 7, 1974

THE MEVERCORD COMPANY,

)

Petitioner,

)

vs.

)

PCB 74-220

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

)

Mr.

George

R.

Hooper,

on behalf of Petitioner;

Mr.

Gregory Arenson and Kathryn

S.

Nesburg, Assistants Attorney General

on behalf of Respondent.

OPINION

AND

ORDER OF THE BOARD

(by Mr.

Seaman):

This

is

a petition for a variance filed by the Meyercord Company

(hereinafter Petitioner)

with the Environmental Protection Agency

(hereinafter Agency)

on June 13,

1974.

The Petitioners, Hastings

Division Plant,

is

located in Chicago.

Petitioner manufactures decalcomania and tax stamps.

It has two

plants,

one in Carol Stream and the Hastings Division plant in Chicago.

The plant

in Chicago, for which Petitioner is requesting

this Variance,

manufactures backing paper.

This paper

is then shipped to the Carol

Stream plant where the design is imprinted.

A variance from Rule 205(f)

was requested May 21, 1974 for the Carol

Stream plant,

PCB 74—184.

Petitioner requests

a Variance for one year from Illinois Pollution

Control Board Regulations Chapter

2, Part II, Rule 205(f)

for the

purpose of reformulating the solvents

it uses and acquiring such exempt

solvents.

Petitioner submitted information for an operating permit on

May 31,

1974.

The emission source at Petitioner~sChicago plant

is

a coater-dryer-

laminator.

First

a resinous material,

used for its adhesive properties,

is

applied to natural kraft clay coated paper

in

a reverse

roll coater.

Next,

the coated paper goes through

a duct where air is circulated to

remove solvents.

Flue gases from this operation exit through stack

#2.

Then the material

is dried by passing through

a hot air oven operated

at 100°F.

Gases containing hydrocarbons exit from the oven through stack

#4.

After leaving the oven,

a Mylar coating is applied to the paper.

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Petitioner’s operation

is completely uncontrolled.

Emissions

of photochemically reactive organic compounds from both stacks

together are 115.5 lbs/hour based on the process weight of the

non-exempt solvents.

Petitioner estimates that about 10

of the

total emissions come from Stack #2.

Petitioner proposes to comply with Rule 205(f)

in one year

by reformulating its solvents to substitute exempt solvents

as soon

as

it can get exempt solvents from its suppliers.

It

has no plans

to

install pollution control

equipment.

Petitioner claims

a denial

of a Variance would result

in 83

reduction in out put with

a corresponding reduction in revenues.

It

also claims that

5 or 6 people would have their wages and hours

reduced by about 80.

At a public hearing held on August 26, 1974, testimony was

offered by several

of the Petitioner’s witnesses

in an attempt

to

show that Petitioner was taking steps

to come into compliance.

Petitioner did not have

a compliance program when it filed

its

original variance petition.

The program referred to at the hearing

(Petitioner’s Exhibit #1) was drawn up

in August

1974.

The program

consists,

in part,

of farming out some of the work to other companies

(R 25—26).

It

includes raising the height of Stack

#4 (R 27-28).

But the most important part of the plan

is to obtain exempt solvents,

and this

is something Petitioner cannot be certain

of doing.

Thus,

the plan has a weakness which renders Petitioner’s control

program

inadequate.

The public suffers harm in two ways as

a result of emissions

from Petitioner’s plant.

Those persons who live near the plant suffer

from the odors which are sometimes emitted from the plant.

Other

persons who live and work in Chicago suffer from ozone, which

is caused

in part by chemical reactions involving hydrocarbons

in the atmosphere.

Mrs.

Rosie McCutcheon testified at the hearing.

She lives

at

1849 West 13th Street.

Petitioner’s plant

is located at 1838 West

Hastings Street,

across the alley to the south from Mrs. McCutcheon’s

building.

Mrs. McCutcheon testified that she sometimes smelled an

unpleasant odor coming from outside of her apartment

(R

81).

She

testified that the odor had

a strong, solution-like smell

and that

it took her breath away (R 81).

She suffers from emphysema and has to

bury her face

in a pillow so she can breathe when the odor comes

(R 82).

She testified that the odors came from the west and south

(R 82), and

she testified that there

is

a large building behind her house to the

south and west (R 83).

She said that the building has one story on

the back, but that there are more stories on the Hastings Street side

(R 84).

Mr. Knopf testified that he has detected an odor “principally

at

the fountain of the double reverse roll

cord (sic).”

(R 19)

He

further testified

that

the

odor

is

“vented

out

in

the

roof

and

during

a

great

deal

of

the

summer

we

have

windows

open

on

the

second,

third,

and fourth floors

(R 22).

Steven Rosenthal testified that the stacks

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-3-

were about the same level

as the residential houses which were located

across the alley to the north of Petitioner’s plant (R 92).

Mr.

Rosenthal detected solvent odors coming from the two stacks on the

roof (R 93).

Mr.

Rosenthal,

the Agency engineer, also testified that

“hydrocarbons play

a key role

in the formation of ozone,

photochemical

oxidants) or whatever,

and it’s for this reason they are restricted.”

(R 94)

He then pointed out that Petitioner’s facility ranks eleventh

out of those facilities

in Chicago which emit photochemically reactive

hydrocarbons

in excess of 90 lbs/hr

(R 99).

The Agency contends that Petitioner has failed

to prove that

denial

of the Petition for Variance would result in

an arbitrary or

unreasonable hardship. We agree.

This Opinion constitutes the findings

of fact and conclusions

of law of the Board.

IT

IS THE ORDER of the Pollution Control Board that the Petition

for

a Variance from Illinois Pollution Control

Board Regulations,

Chapter 2, Part

II, Rule 205(f)

be and is hereby denied.

I, Christan L.

Moffett, Clerk of the Illinois Pollution Control

Board, certify that the above Opinion and Order was adopted

on this

___________

day of

~

,

1974 by a vote of

9~ø

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