ILLINOIS POLLUTION CONTROL BOARD

June 13, 1974

CALUMET STEEL DIVISION, BORG-

WARNER CORPORATION,

)

Petitioner,

)

vs.

)

P~R74-108

ENVIRONMENTAL PROTECTION AGENCY,

)

Respondent.

)

OPINION AND ORDER OF THE BOARD (by Mr. Seaman):

On March 22, 1974, Calumet Steel Division, Borg-Warner Corporation,

filed its Petition for Variance, seeking therein a one year variance from

the provisions of Rule 205(f) of the Air Pollution Control Regulations in

order to emit photochemically reactive hydrocarbons in excess of the

proscribed standard.

Petitioner operates a fence post manufacturing facility in Chicago

Heights, County of Cook, Illinois. Included in Petitioner’s operation

is a post painting operation which is the subject to its Petition for

Variance.

Rule 205(f), which became effective on December 31, 1973, limits

emissions of photochemically reactive hydrocarbons to 8 lbs/hr. Petitioner

alleges that it has been in compliance with Rule 205(f) since December,

1972 when it began substituting exempt solvents for non-exempt solvents

in its painting operations. Petitioner contends that it is now no longer

possible to obtain an adequate supply of exempt solvents.

The painting operation consists of a flow-coater and a natural gas—

fired bake oven. Emissions from the operation consist of organic material

in gaseous

form,

resulting from evaporation of solvents used in the

coating process. Petitioner estimates that when using non-exempt solvents

its emissions of photochemically reactive solvents are 21.35 lbs/hr. The

Agency estimates the emission rate at 32.96 lbs/hr.

Petitioner now plans to achieve compliance as soon as it is again

possible to obtain exempt solvents. In the meantime, Petitioner will adopt

the following measures:

12—525

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a. Continue to use as much exempt solvent as

it can obtain. Exempt and non-exempt solvents are com-

patible and can be mixed in the same storage tank.

b. Continue investigation of thermal incineration

and the possibility of switching to water base coatings.

Petitioner alleges that neither of these means of control

is presently feasible.

Petitioner’s facility is located in an industrial area. The

Agency has received no complaints from anyone living or working in the

vicinity of the plant regarding the granting of a variance, or the

excessive emissions.

The Agency is in agreement with Petitioner that denial of the

variance would cause a hardship.

The Agency also believes that due to the current shortage of natural

gas, thermal incineration is not, at this time, a viable means by which

Petitioner may achieve compliance with Rule 205(f).

3ue to the current nationwide shortage of non-pnotochemically reactive

solvents, Petitioner is not unique in its inability to obtain such solvents

and its request for relief will be granted.

This Opinion constitutes the findings of fact and conclusions of law

of the Board.

IT IS THE ORDER of the

Pollution

Controi~Board that Petitioner he

granted

a variance from the

provisions

of Rule 205(f) for a period of one

year from the date of this 3rder~,subject to

the following conditions:

a. Commencing 30 days from the date of this Order,

Petitioner shall submit monthly progress reports to the Agency

detailing:

I. total

amount

of solvents used during the month;

2.

nature and

amount of non-exempt solvents used;

3. nature and amount of exempt solvents used;

4. nature and amount of exempt solvents purphased

(indicating the supplier);

5. nature and amount of non—exempt soTvants purchased

(indicating the supplier);

6.

nature

and amount of solvents in inventory at the

beginning

of

each month.

Said

reports shall be

sent

to:

Environmental Protection Agency

Division of Air

Pollution Control

Cori~rol Program Coordinator

Z200 Churchill

Poad

Son nqfie~d, ii inois 62706

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b. Petitioner shall utilize as much exempt solvent

formulations as can be furnished by its suppliers.

c. Within one hundred and eighty days from the

date of this Order, Petitioner shall submit a compliance

planlto the Agency. This plan may:

1. Achieve compliance at the expiration

of the Variance by replacement of photochemically reactive

solvents with non-reactive solvents demonstrated to be

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 oy May 30, 1975 under the

provisions of Rule 2059(f)(2)(D).

I,

Christan L.

Moffett,

Clerk of the Illinois Pollution Control Board,

certify that the above Opinion and Order

was adopted on this

/J ‘~‘

day of

~

1974 by a vote of Y—O