ILLINOIS POLLUTION CONTROL BOARD
    May 31, 1973
    )
    JOHNSON ~ JOHNSON
    )
    •1
    )
    v.
    PCB 73-71
    )
    )
    ENVIRONMENTAL PROTECTION AGENCI
    )
    OPINION AND ORDER OF THE BOARD
    (by
    Mr. Dumelle)
    This
    is
    a petition for variance
    from
    Rule
    203 of the Air Regulations
    concerning particulate emission standards
    and
    limitations,
    Hearing
    was held on April
    13,
    1973.
    Johnson operates
    a film coating line
    at its plant
    in Bedford Park,
    The operation consists of applying a liquid coating to carrier paper
    and then curing
    it in an oven.
    They filed an operating permit appli-
    cation with the Agency on November 30,
    1972.
    In the application,
    Johnson calculated the process weight rates by including the weight
    of
    the carrier paper because they believed that the definition
    of that
    rate
    in Rule
    201 included all but liquid and gaseous fuel
    and combus-
    tion
    air.
    On January
    8,
    1973, Johnson received a letter from the Agency
    stating that
    it should recalculate the process weight rates
    excluding
    the weight of the carrier paper.
    On January
    17,
    in reply to further
    inquiries
    seeking clarification, Johnson received a letter from the
    Permit Division of the Agency stating again that carrier paper could
    not be included in the calculation of process weight rate.
    Excluding
    the carrier paper
    from the process weight reduces Johnson~sallowable
    emissions from
    2.31 pounds/hour to 1,45 pounds/hour.
    Since stack
    te5ts have shown the particulate emissions
    from this source to be
    2.07
    pounds/hour, exclusion of the carrier paper places the process
    in
    violation of Rule
    203.
    Rule
    201 defines process weight rate as
    “the actual weight or
    engineering approximation thereof of all materials except liquid and
    gaseous
    fuels
    and combustion air, introduced into any process per
    hour”.
    Thus,
    the only materials which are not to be included in the
    weight are liquid and gaseous fuels
    and combustion air.
    We cannot accept
    8— ~42

    -2-
    the Agency’s interpretation so
    as
    to exclude any other materials,
    We interpret the Rule to exclude only what
    is expressly excludes.
    We find nothing before us
    to support any other definition.
    Consequently,
    there
    is no need
    for a variance
    in this
    case since
    Johnson
    is in compliance with the regulation.
    We do, however, commend
    Johnson for its good faith and diligence in upgrading
    the quality of
    their emissions by installing additional control equipment.
    This opinion constitutes the Board’s findings
    of fact and
    conclusions of
    law.
    ORDER
    The petition for variance is
    dismissed.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Opinion and Order were adopted on
    the
    ~
    day
    of
    May,
    1973
    by
    a
    vote
    of
    ‘f—
    :~
    4.~
    Y ~
    Christan
    L. Moffett, ‘Cl~r~
    Illinois
    Pollution
    Control
    Board
    8
    150

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