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Nos
2-12-0945
3-10-0128
a
d
2-086
were
den
d
oy
‘he
Agency
on
Feb
jary l~ 19~
In
order to
comply wit
tie
requirements of
Rule
205(f)
petitioner
or
August
12
1973
completed
a
‘
work necessary
tu
tefonma1ate its
soivets b~
replacing
photocherically
reactive organic materials
with
non—photochemically
reactive
organ’c materials
Petitioner
proposes
to
refonr
lax
its
solvent
called
aRheel
A205
solvent,”
so that it
contatns
81
ethyl
alcolol,
11
toluol,
and
8
xylol.
Petitioner
has
been
unable
to
implement this
otherwtse
satisfactory plar
due
to shortages of
exempt solvents.
Or
la
J
O’j
ljs.erflar
a-~
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art, seekrgtere-rvaitc
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e
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13—317
Petitioner states that as soon as petrochemical
stocks are replenished
and Petitioner is thereby able to purchase sufficient amounts of non-
photochemically reactive material to completely implement is solvent
refor,nuiation program, Petitioner will
be able to comply with Rule 205(f)
within thiry
to sixty days.
At the present time, Petitioner has been able
to acquire sufficient non~photochemicaflyreactive solvents to implement
approximately 62
of its reformulation program.
Petitioner states that by the reason
of the current wide-spread shortage
of
petrochemicals,
it has been unable, despite
its diligent efforts,
to
continue
to acquire sufficient amounts of non-photochemicaily reactive
solvents
to completely implement its~reformulation program.
Petitioner has
documented
its
inability to procure exempt solvents
by statements from
its suppliers
to
the effect that Petitioner’s requirements cannot be currently
met,
Petitioner alleges
that it
is exploring alternative technologies, such
as using water~hasedcoatings and high-solids paints,
to achieve compliance
under Rule 205(f)(2)(D).
It claims that such paints are unsatisfactory for
its use and that its experiment action is unlikely to be successful
before
sufficient quantities of non-photochemicaily reactive solvents are again
available.
During the interim period Petitioner will
continue to buy and
use as muh nor—photochemicaily reactive organic material
as
it
is able to
acquire.
Petitioner claims that no odor nuisance is attributable to
its
use of organic materials.
H~ever,nearby residents told an Agency in-
vestigator they smelled odors
at least once
a week, hut had no objection
to the grant of the requested variance, nor would they sign a complaint.
There have been no other citizen complaints.
The Agency recorrmiends that this Petition be denied,
or,
in the alternative,
that the variance be granted for a period of six months.
The Agency notes
that Petitioner has no control
program likely
to succeed
in complying with
Rule 205(f)
other than hoping sufficient supplies of non-photochemically
reactive solvents will soon become available,
Petitioner is not unique
in
this posture and we are satisfied that its problem is not self-imposed.
We suspect that the Agency’s
reservations are prompted by the relatively
high rate of emissions from Petitioner’s facility.
Certainly,
this is the
factor we find most disturbing.
Therefore, the relief requested will
be
limited to six months.
We would hope that t~ythe end of that period shortages
will have eased.
In any event, our policy
in the area of Rule 205(f)
variances must
be re-evaluated in the near future.
Large-scale emissions of organics
cannot be tolerated for prolonged periods.
This Opinion constitutes the findings of fact and conclusions of law
of the Board.
IT IS WE ORDER
of the Pollution Control Board that Rheem Manufadturing
Company be granted a variance from the provisions
of Rule 205(f)
of the
Air Pollution Control Regulations
for a period of six months from the date
of this Order,
subject to the following conditions;
13
—
318
1,
Petitioner shall
utilize as much exempt solvent~formulations
as can he furnished by
its suppliers.
2.
Petitioner shall
submit monthly reports
to:
Environmental Protection Agency
Division of Air Pollution Control
Control Program Coordinator
2200 Churchill
Road
Springfield,
Illinois
62706
The monthly reports shall include the total
amount of solvents used, the
nature and amount
of non-exempt solvents used, the nature and amount
of exempt solvents used,
the amount and
nature
of exempt solvents
purchased (indicating the supplier), the amount and
nature
of
non-exempt
solvents purchased (indicating the supplier),
and the amount and nature of
solvents
in inventory at the beginning of each month.
3.
Within
ninety
(90)
days
of
the
date
of
this
Order,
Petitioner
shall
submit
to
the
Agency
a
modified
compliance
plan
to
reDlace
that
which
has
been
nullified
by
shortages.
This
plan may:
I.
Achieve
compliance
at
the
expiration
of
the
variance
by
replacement
of
photochemicaily
reactive
solvents
with
non-reactive
solvents
demonstrated
to he
readily
available;
or
2.
Achieve
compliance
at
the
expiration
of
the
variance
by
qualification
under
the
Alternative
Standard
of
Rule
205(f)(l);
or
3.
Achieve compliance by May 30~i9~5under the
provisions of Rule 206(f)(2)(D).
I,
Christan
L.
Moffett, Clerk of the Illinois Poil~itionControl Board,
certify that the above Opinion and Order was
adopted on
this
-__________
day ~
1974 by
a vote of ~
13—
319