ILLINOIS POLLUTION CONTROL BOARD
    January 3, 1975
    UNIROYAL, INC.,
    Petitioner,
    v.
    )
    PCB 74—371
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    Opinion and Order of the Board (by Dr. Odell)
    On October 15, 1974, Uniroyal, Inc. sought a variance
    from Rule 205(f) of the Air Pollution Regulations (Chapter
    Two) until
    May
    31, 1975,
    Petitioner had previously filed a Petition for Variance
    from Rule 205(f) on June 14, 1974. The Pollution Control Board
    (Board) granted a variance in that case until March 31, 1975,
    subject to a number of conditions. See Uniroyal, Inc. v.
    Environrnen~~Protec~o~Aency,PCB 74—222 (September 12, 1974).
    ~~ii~’Thner now requests that the earlier variance be withdrawn
    and that the instant petition be substituted in its place.
    Petitioner~s Chicago plant at 2638 North Pulaski Road
    is one of a number of plants in Uniroyhl~sPlastic Products
    Division. The principal business activity at the Chicago plant
    is the fabrication of plastic items, principally for use as
    interior components of automobiles, This petition pertains to
    a final processing step wherein the fabricated item is spray-
    coated with a selected pigment that is applied in a solution
    consisting of various organic solvents, Spray coating is
    carried out in two separate spray-coating lines, Spray-Coating
    Lines Nos. 1 and 2. The step of spray coating is carried out
    in a spray booth, following which the sprayed item is oven-
    dried and then cooled in an air—cooled tunnel. All of these
    steps result in the vaporization of organic solvents to some
    degrees
    Petitioner states that it uses 205 lbs/hr of spray-
    coating materials on Line No. I and 500 lbs/hr on Line No. 2.
    Hydrocarbon emissions are presently uncontrolled. In February,
    1973, stack samplings were taken on Spray-Coating Lines Nos. 1
    and 2. Total hydrocarbon emission rates (methane basis) were
    15
    89

    measured using the flame ionization technique, The following
    emission rates were obtained~
    Total hydrocarbon
    lbs/hr
    Spray booth
    130.23
    Oven
    13,99
    144, 22
    Spray-Coating Line No. 2
    Tot
    ~
    lbs/hr
    Spray booth A
    90,10
    Spray booth B
    76.86
    Oven
    1.89
    Cooling tunnel
    6.46
    175.31
    The allowable emissions per source are 8
    lbs/hr
    of
    hydrocarbons under Rule 205(f) of Chapter Two.
    Petitioner
    ~s
    present time schedule to achieve compliance
    with Rule 205(f) is as follows:
    May 14, 1974
    -
    Petitioner’s management committed funds
    sufficient to insure compliance with Rule 205(f).
    September 9, 1974
    -
    Request made to Peoples Gas, Light
    and Coke Company for an initial fuel allocation of natural gas
    (3600 CFH) for catalytic incinerator to be used
    on Spray Booth
    A on Line No.
    1
    and Spray Booth B on Line No. 2,
    September 11, 1974
    -
    Final decision that full implementa-
    tion of a water—based spray top coating system is not comrner—
    cially feasible at this time
    and
    that an alternate form of con-
    trol will therefore be required.
    ~
    -
    Begin preliminary engineering and
    design for alternate control technique.
    October 7, 1974
    -
    Begin final design engineering for
    alternate control technique,
    15 —90

    ~ecember 2, 1974
    -
    Complete final design engineering
    and ordor direct flame thermal incinerator. Begin removing
    catalytic incinerator from Providence, R,I, plant for ship-
    ment to Chicago plant.
    January 6,
    1975
    -
    Begin installing catalytic incinerator
    at Chicago plant.
    ~~anuary 15, 1975
    -
    Begin building and structural modi-
    fication to building for direct thermal incineration.
    February 3, 1975
    -
    Make catalytic incinerator at Chicago
    plant o~F~I6na, thereby reducing organic emissions by at
    least 5C~ percent.
    Ma~~l2~
    -
    Receive delivery of direct thermal incin-
    erator and begin installation,
    May 31, 1975
    -
    Make
    direct
    thermal incinerator
    operational.
    Compliance with Rule 205(f) achieved.
    Petitioner discovered in September, 1974, that imple-
    mentation of a commercially acceptable water-based
    spray system,
    as~the compliance method scheduled in PCB
    74-222, could not be
    accomplished by September 30, 1974, for
    two reasons. First, the
    production equipment would require more extensive modification
    than previously envisioned, Second, additional time to obtain
    customer approval and acceptance of
    the new product would be
    required.
    A variance from Rule 205(f) until May
    31,
    1975, will
    permit Petitioner to install an incineration system to oxidize
    organic emissions from Spray-Coating Lines No. 1 and No. 2 as
    completely as possible. This incineration system will be
    utilized until a satisfactory water-spray coating system
    is
    developed at which time the water-spray system may be substit-
    uted.
    Petitioner estimates that it will spend $43,200 for the
    transfer, repair, and reinstallation of the catalytic inciner-
    ator from its Providence plant, and $163,000 for the acquisition
    and installation of a new thermal incinerator, Total cost of
    installed equipment is estimated to be $206,200. Besides the
    expenditures for incineration equipment, Petitioner expects to
    invest $116,000 to improve and modify the spray-coating lines
    to enable them to utilize the water—based top coat solutions
    and thus eliminate the use of organic—based materials for the
    top coat portion of its production by early
    1976.
    Petitioner
    does not expect to be able to change to water-based coatings
    for both top and bottom coats until a much later date.
    Petitioner~s plant is located in
    an industrial/commer-
    cial area, There have been no citizen complaints.
    15—91

    The Environmental Protection Agency (Agency) filed its
    Recommendation on December 17, 1974. The Agency recommended
    that the Petition for Variance from Rule 205(f) of Chapter
    Two be granted until May 31, 1975, subject to certain con-
    ditions. The Agency agreed that it would constitute an ar-
    bitrary and unreasonable hardship to deny the Petition for
    Variance when the Petitioner is planning to achieve com-
    pliance through interim control measures. The amount of time
    requested is reasonable considering the magnitude of the work
    that needs to be done to install both the catalytic and direct
    thermal incinerators,
    We deny the Petitioner~srequest to withdraw its
    Petition for Variance in PCB 74-222. Final Board action has
    already taken place on that request. We construe this case
    before us as a Petition for Variance from April 1, 1975,
    through May 31, 1975, and as to such Orders in the Order in
    PCB 74-222 that cannot be implemented because of changes in
    the compliance plan.
    We grant Petitioner~srequest for a Variance subject
    to certain conditions spelled out in our Order. Uniroyal is
    making good-faith efforts to abate its pollution source with
    a definite program for compliance. Large sums are being spent
    The two-month delay is not self-imposed. On these facts, it
    would be an unreasonable hardship to deny the Petitioner the
    additional time to meet the requirements of Rule 205(f) of
    Chapter Two.
    ORDER
    IT IS THE ORDER of the Pollution Control Board that
    Uniroyal, Inc. be granted a Variance from Rule 205(f) of the
    Air Pollution Regulations for its Chicago plant until May 31,
    1975, subject to the following conditions:
    1. Petitioner shall continue to carry out, where
    applicable, the Order in PCB 74-222 (September 12, 1974),
    2. Petitioner shall apply for and obtain all nec-
    essary permits for the installation and operation of new
    equipment.
    3. For the provisions of this Variance, Petitioner
    shall, by February 1, 1975, post a performance bond in the
    amount of $10,000 in a form acceptable to the Agency. Such
    bond shall be forfeited in the event Petitioner fails to ad-
    here in the most practicable manner to the timetable set out
    above in the Opinion. The bond shall be mailed to:
    Fiscal Services
    Environmental Protection Agency
    2200 Churchill Road
    Springfield, lolinois 62706
    15 —92

    —5—
    4. Petitioner shall continue in its efforts to
    develop a water—based
    spray-coating
    system so that it may
    complete the conversion of Lines Nos. I and 2 as
    soon as
    possible.
    5. Petitioner shall reduce its
    solvent emissions no
    less than 50 by February 3, 1975, By May 31, 1975,
    Petitioner shall control all solvent emissions by at least
    85 to comply with Rule 205(f) (1) (A).
    6. Petitioner shall submit monthly
    reports to the
    Agency through June, 1975. The reports shall follow the
    form and include the information set out in Order #5 of
    PCB 74—222.
    7. Petitioner shall submit its final compliance plan,
    with dates included, to the Agency by March 31, 1975.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify that he above Opinion and Order was
    adopted on the
    ~
    day
    ~
    1974, by a vote of
    Christam L.
    ~tt
    15
    93

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