ILLINOIS POLLUTION CONTROL

BOARD

November 29,

1973

FORD MOTOR COMPANY,

Petitioner,

vs.

)

PCB 73—265

ENVIRONMENTAL

PROTECTION

AGENCY,

Respondent.

Allan

W.

Masters

and

Sheldon

A.

Zabel,

Attorneys,

on

behalf

of

Petitioner,

John E.

Slattery, Assistant Attorney General,

on behalf of

the Environmental Protection Agency.

OPINION AND ORDER OF THE BOARD

(by Mr. Seaman):

On June 26,

1973,

Petitioner, Ford Motor Company,

filed its Petition for Variance in the captioned cause.

On September 24,

1973, Petitioner filed an Amended

Petition for Variance.

Petitioner operates an automobile

assembly plant located in Chicago, County of Cook,

Illinois.

The subject facility includes,

inter alia,

a painting

operation consisting of paint spray booths, bake ovens

and a flow coating operation.

Petitioner seeks a variance

from Section

9

(a)

of the Environmental Protection Act

until October

1,

1974, during which time a course of

corrective action for odor abatement would be implemented

and evaluated at the subject facility.

Studies of

the

extent

and

nature of odors and control

techniques

would

be

conducted

simultaneously.

Petitioner

states

that

if

the

proposed

control

program

does

not

achieve compliance an additional program will be developed

by December

1,

1974.

Petitioner states

(Amended Petition for Variance,

p.

1)

that the extent of odor emissions from assembly

plant operations

is unknown, both in quantity and quality.

However,

in paragraph 5 of its Recommendation,

the Agency

alleges that

the presence

in the atmosphere of these odors

causes air pollution a~defined in Section

3

(b)

of the

Environmental Protection Act.

10—151

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—2—

Agency calculations indicate the following solvent

emission rates from the subject facility:

Material

Emission Rate

(lb/hr)

Primer solvents

321

Enamel solvents

551

Sealer and deadener

solvents

120

Small parts flow coat

solvents

11

Petitioner

is in the process of converting from

photo—chemical to non—photochemically reactive solvents

and expects the conversion to be completed by December

31,

1973.

The Agency states that this conversion will

lead to compliance with Rule 205

(f)

of Chapter

2, Part II

of the Pollution Control Board Regulations.

However, the

Agency notes that an odor problem may still remain due

to the Small Parts Flow Coat operation, which utilizes

non-photochemically reactive solvents and still contributes

to the objectionable odor surrounding Petitioner’s facility.

Petitioner utilizes water spray curtains to control

particulate emissions from the paint spray booths.

Recent

inspections by Agency surveillance personnel revealed

that the water spray curtains are being operated at optimum

levels of efficiency and are controlling particulate

emissions to within the orescribed standards.

Petitioner has organized

a paint odor reduction

task force to study odors which emit from its various

paint operations throughout the country.

The study

is

being conducted during the period of the Variance sought

and results will be available in early 1974,

If the

conversion

to non—photochemically reactive solvents and the

proposed control program in the Small Parts Flow Coat

operation is not successful

in eliminating an odor nuisance,

then Petitioner will utilize the results from the paint

odor reduction task force and submit an additional odor

abatement control program after the completion of the control

program for the Small Parts Flow Coat operation.

Petitioner believes that the primary source of odors

at this plant emanates from the Small Parts Flow Coat

operation.

Petitioner proposes an odor abatement control

program

for the Small Parts Flow Coat operation, which

includes

the

following:

10—

158

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—3—

1)

Revision of the exhaust duct system

to improve air flow.

2)

Installation of an afterburner for the

exhaust gas streams which have been

identified

as

conveying

odors.

Tentative

plans call for

a

direct

gas—fired

afterburner

to operate at approximately 1400°F. Heat

exchangers and other measures will be in-

corporated in the system’s design to

minimize fuel consumption.

3)

As an alternative to the afterburner,

Petitioner

is also investigating the use

of a wet scrubber utilizing specific chemical

solutions to control the odors.

Regardless of what system Petitioner utilizes

(a scrubber

or an afterburner)

the control program on the Small Parts

Flow Coat operation will be completed by October

1,

1974.

The availability of gas to operate the afterburner will

be

the determining factor in Petitioner’s decision of whether

or not to install an afterburner or a scrubber.

Petitioner

estimates that the cost of the control devices on the Small

Parts Flow Coat operation could exceed $500,000.

The

Agency is of the

opinion

that

a properly designed afterburner

or scrubber would eliminate the effluent

which

contributes

to the odor nuisance emanating from Petitioner’s facility.

The Agency is not able to evaluate what the exact

effect will be when Petitioner switches from photochemically

reactive solvents to non—photochemically reactive solvents

on its paint spray booths.

The Agency is of the opinion

that photochemically reactive solvents from the paint

spray booths and bake ovens will be eliminated.

These

solvents emit fumes which~oftenare the source of odors.

It

is likely that the new solvent will not contain fumes

which contribute to the odor problem that exists around

Petitioner’s plant.

it is possible,

therefore,

that switching

to non—photochemically reactive solvents and the installation

of

a properly designed afterburner or scrubber in the Small

Parts Flow Coat operation could significantly reduce

emissions from Petitioner’s facility to a level where it

would not cause air pollution as defined in Section

3

(b)

of the Environmental Protection Act.

However,

it is possible that upon completion

of this

project,

odors could emanate from Petitioner’s plant which

10—159

---

—4—

do

constitute

a

violation

of Section

9

(a)

of the Environmental

Protection Act and cause air pollution as defined in

Section

3

(b)

of the Environmental Protection Act.

If

at that time an odor problem continues to exist, Petitioner

states it will develop a new program for the abatement

of any remaining odors, based upon the results of the

paint odor reduction task force.

The Agency recommends that the subject variance

be granted.

We feel that Petitioner’s proposed odor

abatement plan,

and the expense attendant thereto, manifest

a resolve to abate the problem and a good likelihood of

achieving same in the near future.

Accordingly,

the

variance is granted,

subject to conditions.

Finally, we feel that a bond in the amount of $100,000

is appropriate

to insure completion of the conversion

to non-photochemically reactive solvents by December 31,

1973,

and the completion of the installation of an afterburner

or

a scrubber on the Small Parts Flow Cost operation by

October

1,

1974.

However, we feel that Petitioner is

in

a position to furnish its own bond,

and no surety will be

required.

This Opinion constitutes the findings of fact and

conclusions of law of the Board.

ORDER

IT IS THE ORDER of the Pollution Control Board

that Petitioner, Ford Motor Company, be granted

a Variance

from Section

9

(a)

of the Environmental Protection Act

as regards its painting operation at the subject facility

until October

1,

1974,

subject to the following conditions:

1,

Petitioner shall complete the conversion

to non-photochemically reactive solvents by

December

31,

1973;

2.

Petitioner shall have operational

a

properly designed afterburner or scrubber on

the Small Parts Flow Coat operation by October

1,

1974.

Petitioner shall obtain all necessary

construction and operating permits for this control

device;

3.

Petitioner shall submit to the Agency

during the period of this Variance all applicable

reports or documents of the p~.intodor reduction

task force;

10—160

---

—5—

4.

Petitioner shall submit,

in

writing,

to:

Illinois Environmental Protection Agency

Division of Air Pollution Control

Control Program Coordinator

2200 Churchill Road

Springfield, Illinois

62706

progress reports indicating progress towards completion

of the control program;

5.

Within thirty-five

(35)

days of

the date of

this Order, Petitioner shall post a Performance

Bond in the amount of $100,000 in

a form satisfactory

to the Agency.

Said bond shall be submitted to:

Illinois Environmental Protection Agency

Fiscal Services

2200 Churchill Road

Springfield, Illinois

Said bond shall insure completion of the conversion

to non-photochemically reactive solvents by

December 31,

1973 and the completion of the

installation of an afterburner or

a scrubber on the

Small Parts Flow Coat operation by October

1,

1974.

I, Christan

L. Moffett, Clerk of the Illinois

Pollution Control Board, certify that the above Opinion

and Order was adopted this

~

day of

/)

~

~,

1973 by a vote of

~

to

c.,

.