ILLINOIS POLLUTION COi~TROLBOARD
    August
    6,
    1987
    IN THE MATTER OF:
    AMENDMENTS TO
    35 ILL.
    ADM. CODE
    )
    R86-lO
    211
    & 215 ORGANIC MATERIAL EMISSION
    STANDARDS AND LIMITATIONS FOR
    )
    SYNTHESIZED PHARMACEUTICAL
    MANUFACTURING PLANTS.
    PROPOSED RULE.
    FIRST NOTICE.
    ORDER OF THE BOARD
    (by J.D.
    Dumelle):
    Tnis matter comes
    before the Board
    upon
    a February
    26,
    1966,
    proposal
    for
    the adoption of amendments
    to
    35
    Ill. Adm. Code 211
    and 215 filed
    by the Illinois Environmental Protection Agency
    (Agency).
    The proposal was accepted and authorized
    for hearing
    by Order
    of
    February 26,
    1986.
    On April
    23,
    1987,
    the Agency
    submitted
    an amended proposal.
    Hearing was held on June
    9,
    1987,
    in Waukegan.
    The Agency filed
    a second amended proposal
    on July
    27,
    1987.
    A second hearing
    is scheduled
    for August
    25,
    1987,
    ano
    additional hearings may
    be necessary.
    However, certain deadlines imposed
    by the Clean Air Act
    require
    that the Board quickly teach
    a final disposition
    of this
    matter.
    The Board,
    accordingly,
    takes
    its action today
    to allow
    that
    the activities associated with first notice may proceed
    concurrently with
    the final submissions of
    information and
    comments which
    the interested entities are expected
    to make
    over
    the next several weeks.
    In taking this action, the Board
    believes
    tnat whatever
    the outcome,
    final disposition of
    tr1is
    matter will proceed
    in as timely
    a fashion
    as possible,
    to the
    benefit
    of all concerned.
    The Board cautions that this action
    in
    no way constitutes
    a determination
    by the Board
    on the ultimate
    merits
    of the proposed amendments.
    The overriding
    basis
    of the Agency’s proposal
    is to correct
    deficiencies
    in the Illinois State Implementation Plan
    (SIP)
    which have been
    identified
    by the United States Environmental
    Protection Agency
    (USEPA).
    Section 172 of the Clean Air Act
    requires the state
    to
    impose the use of reasonably available
    control technology
    (RACT)
    on existing sources
    in non—attainment
    areas.
    On May 19,
    1978,
    USEPA gave notice that the SIP must
    include,
    at least
    for major urban areas, enforceable regulations
    reflecting
    the application
    of RACT
    to those stationary sources
    for which USEPA has published control techniques guidelines
    (CTGs) since
    1978.
    In December,
    1978,
    a CTG was published
    80—211

    entitled “Control of volatile Organic Emissions from Manufacture
    of Synthesized Pharmaceutical Products.”
    On April
    3,
    1960,
    the Agency proposed
    in R80—5 regulations
    for
    the control of volatile organic materials from the
    manufacture
    of synthesized pharmaceuticals, together with other
    regulations generally known as the RACT II categories.
    On
    December
    30,
    1982,
    the Board
    adopted the proposed rules,
    but
    without provisions
    for the control
    of emissions from the
    manufacture
    of synthetic pharmaceuticals.
    On July 11,
    1985,
    USEPA proposed
    to disapprove Illinois’ Part D stationary source
    control strategy
    for
    failure
    to meet the RACT
    II control
    requirements, noting that the synthetic pharmaceutical sources
    were left unregulated.
    To remedy
    the deficiencies noted
    in USEPA’s proposed
    disapproval,
    the Agency filed
    its proposal
    of February
    26,
    1986.
    The proposal was amended on April
    23,
    1987,
    to remove the
    distinction between
    “synthesized’1 pharmaceuticals and non-
    synthesized pharmaceuticals.
    Although emission sources used in
    manufacturing synthesized pharmaceuticals were described in the
    CTG and those used in non—synthesized pharmaceuticals were not,
    the Agency
    found this distinction unimportant from
    a regulatory
    standpoint because both
    kinds of sources produce emissions that
    are reasonably controlled by
    similar equipment.
    The Agency’s second proposed amendment,
    filed July 27,
    1987,
    responded to concerns addressed at the June
    9,
    1987,
    hearing.
    This proposal incorporates the results of
    a study undertaken by
    Mr.
    Thomas
    C.
    Ponder, Jr.,
    of PEI Associates.
    Mr.
    Ponder
    determined that
    some sources emit more than 15 lbs/day when
    in
    operation,
    but only operate
    a
    few days each year.
    Believing
    that
    it would
    not
    be cost-effective to require such sources
    to add
    controls, Mr.
    Ponder concluded that an annualization of
    the 15
    lbs/day limit was necessary
    arid appropriate.
    Based
    on Mr.
    Ponder’s conclusions,
    the Agency amended the applicability of the
    proposed
    rules
    to sources emitting volatile organic material
    in
    amounts exceeding 2.5 tons/year
    (i.e.,
    the annual total
    of
    a
    15
    lbs/day limit).
    Thus,
    without rendering any opinion as
    to the merits
    of
    proposed amendments,
    the Board proposes for First Notice the
    language contained
    in the Agency’s second amended proposal.
    ORDER
    The Board hereby proposes the following amendments for first
    notice publication.
    The Clerk
    shall cause
    first notice
    publication
    of these proposed amendments
    in the Illinois
    Register.
    80—212

    —3—
    TITLE
    35:
    ENVIRONMENTAL PROTECTION
    SUBTITLE B:
    AIR POLLUTION
    CHAPTbR
    I:
    POLLUTION CONTROL BOARD
    SUBCHAPTER
    C:
    EMISSION STANDARDS AND LIMITATIONS
    FOR STATIONARY SOURCES
    PART 211
    DEFINITIONS AND GENERAL PROVISIONS
    SUBPART
    A:
    GENERAL PROVISIONS
    Section 211.122
    Definitions
    “In—Process Tank”:
    A container used for mixing,
    blending,
    heating, reacting,
    holding, crystallizing,
    evaporating,
    or cleaning operations in the manufacture
    of pharmaceuticals.
    “Pharmaceutical”:
    Any compound
    or mixture,
    other than
    food,
    used
    in the prevention,
    diagnosis,
    alleviation,
    treatment
    or cure of disease
    in man and animal.
    “~roduction Equipment
    Exhaust System”:
    A system for
    collecting
    and directing into the atmosphere emissions
    of
    volatile organic material from reactors, centrifuges
    and other process emission sources.
    “Reactor”:
    A vat, vessel
    or other
    device
    in which
    chemical
    reactions take place.
    “Surface Condenser”:
    A device which removes
    a substance
    from
    a gas stream by reducing the temperature
    of
    the
    stream, without direct contact between the coolant
    and
    the stream.
    Volatile Organic Liquid”:
    Any liquid which contains
    volatile organic material.
    “Volatile Organic Material”:
    any orgar~4en~ater~a3~
    wh4eh
    has
    a vapor
    presatire of ~
    kPa ~
    ps~a)~
    Of
    greater
    at 294~3—K~O-F+-
    For purposes of
    5 ~
    Adn~?ode
    ~57442
    through ~S74447
    vo3~at~eergan~ei~eterta~
    means
    any
    organ~e n’teterta~ wh~eh has
    a
    vapor
    pressure
    of
    ~9~4
    ~Pe -~3~5ps~e~at 2.947~-K~
    For purposes of
    5
    fl~ Adm~?ede ~
    through
    .?~?4y 2~5-445through
    ~-4S~
    2~5~O4through
    5~~9-,
    ~5~4G
    through
    5~345.~
    5-48~ through
    2~5~4O4~
    ~i5~46i
    through
    ~d5-~464
    and
    5~6O~
    through
    2~~6Oa7vo~at~e orgen~e
    ~~teter~e~
    ~eens
    any
    ergan~e ~tater~a~
    wh4eh
    has
    a
    vapor
    pressure
    greater
    than
    9~
    kPe
    ~83~
    ps~a~at
    ~94-~—K
    ~0~F~
    80— 213

    —4—
    a)
    any organic material which participates
    in
    atmospheric photochemical reactions
    or
    is
    measured
    by the applicable reference methods
    specified
    under
    Part
    230, Appendix
    A,
    unless
    specifically exempted from this definition.
    b)
    For purposes of
    this definition,
    the following
    are not volatile organic materials:
    Methane
    Ethane
    1,1,1, Trichioroethane
    Methylene chloride
    Trichlorofluoromethane
    Dichlorodit luoromethane
    Chiorodifluoromethane
    Tn
    fiuoromethane
    Trichlorotr ifluoroethane
    Dichlorotetrafluoroethane
    Chloropentafluoroethane
    (Source:
    Amended
    at
    Ill.
    Reg.
    ________,
    effective
    ___________
    PART 215
    ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS
    Section 215.102
    Testing Methods
    a)
    The total organic material concentrations
    in an effluent
    stream shall
    be measured by
    a flame ionization detector,
    or
    by other methods approved by the Illinois
    Environmental Protection Agency
    (Agency) according
    to
    the provisions of
    35
    Ill. Adm.
    Code
    201.
    b)
    Measurement of Vapor Pressures
    1)
    For
    a single component,
    the actual vapor pressure
    shall
    be obtained from Boublik,
    T.,
    V.
    Fried,
    and
    E.
    Hala,
    the Vapor Pressure of Pure Substances,
    Elsevier Scientific Publishing Company,
    New York
    (1973),
    Perry’s Chemical Engineer’s Handbook,
    McGraw-Hill Book Company
    (1984), CRC Handbook of
    Chemistry and Physics, Chemical Rubber
    Publishing
    Company (l9~6-87),Lange’s Handbook
    of Chemistry,
    John A.
    Dean, editor, McGraw-Hill Book Company
    (1985),
    or
    as determined by ASTM (American Society
    of Testing and Materials
    )
    Method D—2879-83.
    2)
    For
    a mixture, the actual
    vapor
    pressure shall
    be
    taken as either:
    80—2 14

    —5—
    i)
    The lesser
    of
    the sum of
    the actual vapor
    pressure of each component
    or each volatile
    organic material component,
    as determined
    above, weighted
    by
    its mole
    fraction,
    or
    ii)
    If
    the vapor pressure of the volatile organic
    material
    is specified,
    the sum of the actual
    vapor pressure
    of each volatile organic
    material component as determined above
    weighted
    by its mole fraction.
    (Source:
    Amended
    at
    Ill. Reg.
    _________,
    effective
    _______________
    Section 215.104
    Definitions
    ~Vo~at~ie Organ~eMater4e3~ P~nyorgan4e n’tater~a~wh4eh
    has
    a vapor pressure of ~~24
    hPa .~-5ps~a~or greater
    at 294~—Kf79~F~ For purposes of this defin~t~ien7the
    fe~ew4n~are net vo~et~eorgen~emater~a~ts~
    Methane
    Ethene
    ~7~7~—trteh~ereethene
    Methy~eneeh~er-ide
    0hierod~fiaeremethane
    ~r~f~ueremethane
    Tr4eh~eretr~fluereethene
    ?h~erepente~iuereethane
    Fer purposes e~the foHewing Seet4ons7 ve3eti~e organie
    ~ateria~s
    are any erganie mater4a~shaving the
    corresponding vapor pressures at 294~-K~
    Seetions
    Vapor Pressure
    2~.5~84
    0-9i~kPa
    ~ ~0019 psia~
    ~5~04
    2~S~99
    0~0~3
    kPa
    ~-
    ~00~9 peia~
    ~5~340
    0-9~3
    kPa
    ~ ~00i9 psia~
    ~5~40~
    2~~40B
    0~0~3kPa
    ~ ~99~9 psia~
    ~4~29
    ~5~-428
    070~3kPa
    ~ ~90~9 ps4e~
    2~5-44i
    ~5-444
    ~0~4
    kPa
    (.i-5
    2~5-45~
    9~0~kPa
    ~ ~00~9 ps4e+
    ~5746~
    ~5~464
    0~0i hPa
    ‘~
    ~0O~9 psia~
    2~5~~0
    070i3 kPa
    ~f
    ~00~9 psie~
    ~5~60i
    0~9~3hPa
    ~ ~00~9 psia~
    (Source:
    Amended at
    ___
    Ill.
    Reg.
    ________,
    effective
    _______________
    80—215

    —6—
    Section 215.l~5
    incorporations
    by Reference
    The following materials are incorporated
    by reference:
    a)
    American Society
    for Testing
    and Materials,
    1916
    Race
    Street,
    Philadelphia, PA 19103:
    1) ASTM D 1644-59 Method A
    2) ASTM D 1475—60
    3) ASTM D 2369—73
    4) ASTM D
    2879—83
    (Approved 1983)
    5)
    ASTM D 323—82 (Approved 1982)
    6)
    ASTM D 86—82
    (Approved
    1982)
    7)
    ASTM E 260—73
    (Approved 1973), E
    168—67
    (Reapproved
    1977),
    E 169-63
    (Reapproved 1981),
    E
    20
    (Approved
    1985)
    8)
    ASTM
    0
    97—66
    b)
    Federal Standard l4la, Method 4082.1
    c)
    National Fire Codes, National Fire Prevention
    Association,
    Battery March Park,
    Quincy,
    Massachusetts
    02269
    (1979)
    d)
    United States Environmental Protection Agency,
    washington, D.C.,
    EPA—450/2—77—026, Appendix
    A.
    e)
    United States Environmental Protection Agency,
    Washington, D.C., EPA—450/2—78—051 Appendix A and
    Appendix B
    (December 1978).
    f)
    United States Environmental Protection Agency,
    Washington,
    D.C.,
    EPA—450/2—78—04l, Chapter
    7
    (1978).
    ~jj
    Boublik, T.,
    Fried,
    V., and Hala,
    E.,
    The Vapor Pressure
    of Pure Substances,
    Elsevier Scientific Publishing
    Company, New york
    (1973).
    h)
    Perry’s Chemical Engineer’s Handbook, McGraw—Hill Book
    Company
    (1984).
    1)
    CRC Handbook of Chemistry and Physics, Chemical Rubber
    publishing Company
    (1986—87).
    80—216

    —7—
    jj_
    Lange’s Handbook
    of Chemistry,
    John
    A.
    Dean,
    editor,
    McGraw-Hill Book Company
    (1985).
    (Board Note:
    The incorporations by reference listed above
    contain
    no later amendments
    or editions.)
    (Source:
    Amended
    at
    Ill. Reg.
    ,
    effective
    ______________
    SUBPART T:
    PHARMACEUTICAL MANUFACTURING
    Section 215.480
    Applicability of Subpart T
    a)
    The rules of
    this Subpart,
    except
    for Sections 215.483
    through 215.485, apply
    to all emission sources
    of
    volatile organic material, including but not limited
    to
    rea.ctors, distillation
    units,
    dryers, storage
    tanks
    for
    volatile organic
    liquids, equipment for
    the transfer
    of
    volatile organic liquids,
    filters, crystallizers,
    washers, laboratory hoods,
    coating operations,
    mixing
    operations and
    centrifuges used in manufacturing,
    including
    packaging,
    of pharmaceuticals,
    and emitting
    more than 6.8 kg/day
    (15 lbs/day) of volatile organic
    material and more
    than 2268 kg/year
    (2.5 tons/year)
    of
    volatile organic material, or,
    if less than 2.5
    tons/year,
    these sections
    still apply
    if emissions from
    one
    or
    more sources exceed 45.4 kg/day
    (100 lbs/day).
    b)
    Sections 215.483 through 215.465
    apply
    to
    a plant having
    one
    or more emission sources
    that:
    1)
    are used
    to manufacture pharmaceuticals;
    and
    2)
    emit more than 6.8 kg/day
    (15
    lbs/day)
    of volatile
    organic material and more than 2268 kg/year
    (2.5
    tons/year)
    of volatile organic material,
    or,
    if
    less than 2.5 tons/year, these
    sections still apply
    if emissions from one
    or more sources exceed
    45.4
    kg/day
    (100 lbs/day).
    c)
    No person
    shall violate any condition in
    a permit when
    the condition results
    in exclusion of an emission source
    from this Part 215, Subpart
    T.
    (Source:
    Added
    at
    Ill. Reg.
    ________,
    effective
    ___________
    )
    Section 215.481
    Control of Reactors, Distillation Units,
    Crystallizers, Centrifuges and Vacuum Dryers
    a)
    The owner
    on operator shall control all reactors,
    distillation units,
    crystallizers, centrifuges and
    80—217

    —6—
    vacuum dryers that are used to manufacture pharmaceu-
    ticals with surface condensers operated such that the
    condenser outlet gas
    temperature does not exceed:
    1)
    248.2
    K (-l3~F) when condensing volatile organic
    material
    of vapor pressure greater than 40.0 kPa
    (5.8 psi)
    at 294.3
    K
    (70CF);
    or
    2)
    258.2 K (5~F)when condensing volatile organic
    material of vapor pressure greater
    than 20.0 kPa
    (2.9 psi)
    at 294.3 K (70°F); or
    3)
    273.2
    K (32°F) when condensing volatile organic
    material of vapor pressure greater than 10.0 kPa
    (1.5 psi) at 294.3
    K
    (70Z)F);
    or
    4)
    283.2
    K (50~F)when condensing volatile organic
    material
    of vapor pressure greater than 7.0
    kPa
    (1.0 psi)
    at 294.3
    K
    (70
    );
    or
    5)
    298.2
    K (77~F)when condensing volatile organic
    material of vapor pressure greater
    than 3.45 kPa
    (0.5 psi)
    at 294.3
    K
    (70F).
    b)
    The owner
    or operator
    shall enclose all centrifuges used
    to manufacture pharmaceuticals and that have
    an exposed
    volatile organic
    liquid surface,
    where
    the volatile
    organic material
    in
    the volatile organic liquid has
    a
    vapor pressure of
    3.45 kPa
    (0.5 psi)
    or more
    at
    294.3 K
    (70~F).
    (Source:
    Added
    at
    Ill.
    Reg.
    _________,
    effective
    _______________
    Section 215.482
    Control of Air Dryers, Production Equipment
    Exhaust Systems and Filters
    a)
    The owner
    or operator
    of an air dryer
    or production
    equipment exhaust system used to manufacture pharma-
    ceuticals_shall_control the emissions of volatile
    organic material from such emission sources by air
    pollution control equipment which reduces by
    90 percent
    or more the volatile organic material that would other-
    wise be emitted into the atmosphere.
    b)
    The owner
    or operator shall enclose
    all rotary vacuum
    filters and other filters used to manufacture pharma-
    ceuticals and that have an exposed volatile organic
    liquid surface, where the volatile organic material
    in
    the volatile organic liquid has
    a vapor pressure
    of 3.45
    kPa
    (0.5 psi)
    or more at 294.3
    K
    (700F).
    80—218

    —9—
    (Source:
    Amended
    at
    Ill. Reg.
    ,
    effective
    _______________
    Section 215.483
    Material Storage and Transfer
    The owner
    or
    operator of
    a pharmaceutical manufacturing plant
    shall:
    a)
    Provide
    a vapor balance system
    or equivalent control
    system that
    is
    at least
    90.0 percent effective in
    reducing volatile organic material emissions from truck
    or
    railcar deliveries to storase tanks with capacities
    equal
    to or greater than 7.57m
    (2,000 gallons)
    that
    store volatile organic liquids with vapor pressures
    greater than
    28.0 kPa
    (4.1 psi)
    at 294.3
    K
    (700F);
    and
    b)
    Install pressure/vacuum conservation vents set at
    0.2
    kPa
    (0.03 psi)
    on all storage tanks that store volatile
    organic
    liquids with vapor pressures greater
    than
    10 kPa
    (1.5 psi) at 294.3 K (700F),unless
    a more effective
    control system
    is
    used.
    (Source:
    Added
    at
    Ill. Reg.
    ________,
    effective
    _______________
    Section 215.464
    In—Process Tanks
    The owner
    or operator
    shall
    install
    covers on all in—process
    tanks used
    to manufacture pharmaceuticals
    and containing
    a
    volatile organic liquid
    at any time.
    These covers must remain
    closed, except when production,
    sampling, maintenance,
    or
    inspection procedures
    require operator access.
    (Source:
    Added
    at
    Ill. Reg.
    ,
    effective
    _______________
    Section 215.485
    Leaks
    The owner
    or operator
    of
    a pharmaceutical manufacturing plant
    shall repair
    any component from which
    a leak of volatile organic
    liquid
    can
    be observed.
    The repair
    shall
    be completed
    as soon as
    practicable
    but no later
    than 15 days after
    the leak
    is found
    unless
    the leaking component cannot
    be repaired until
    the process
    unit is shut down, and the leaking component must then
    be
    repaired before
    the unit
    is restarted.
    (Source:
    Added
    at
    Ill.
    Reg.
    _________,
    effective
    _______________
    Section 215.486
    Other Emission Sources
    80—219

    —10—
    The owner
    or operator
    of
    a washer,
    laboratory hood,
    capsule
    coating operation,
    mixing operation,
    or any other process
    emission source not subject
    to Section 215.481 through 215.485 of
    this
    Subpart, and used
    to manufacture pharmaceuticals shall
    control the emissions of volatile organic material from such
    emission sources
    by:
    a)
    Air pollution control equipment which reduces by 81
    percent or more the volatile organic material that would
    otherwise be emitted
    to the atmosphere,
    or
    b)
    A surface condenser which captures all the volatile
    organic material which would otherwise be emitted
    to the
    atmosphere
    and which meets
    the requirements
    of Section
    215.481(a)
    of this Subpart.
    (Source:
    Added
    at
    Ill. Reg.
    effective
    _______________)
    Section 215.487
    Testing
    a)
    The owner
    or operator
    of any volatile organic material
    emission source subject to this Subpart
    shall,
    at his
    own expense, demonstrate compliance by methods or
    procedures listed
    in Section 215.487(c).
    b)
    All tests pursuant to Section 215.487(a)
    shall
    be
    performed
    in conformance with
    the procedures
    set forth
    in
    35
    Ill. Adm.
    Code
    283.
    c)
    Test procedures
    to determine operation and maintenance
    compliance with this Subpart shall
    be consistent with
    EPA—450/2—78—04l.
    Procedures for testing air pollution
    control equipment
    to determine compliance with this
    Subpart shall
    use Part 230, Appendix A Method
    25
    (40 CFR
    60, Appendix A Method
    25).
    (Source:
    Added at
    Ill.
    Reg.
    ________,
    effective
    ___________
    Section 215.488
    Monitors for Air Pollution Control Equipment
    a)
    At
    a minimum,
    continuous monitors
    for
    the following
    parameters shall be installed
    on air pollution control
    equipment subject
    to this Subpart:
    1)
    Destruction device combustion temperature
    2)
    Temperature rise across
    a catalytic afterburner
    bed
    80—220

    —11—
    3)
    Breakthrough of volatile organic material
    on
    a
    carbon adsorption
    unit.
    b)
    Each monitor
    shall
    be equipped with
    a recording device.
    c)
    Each monitor shall
    be calibrated quarterly.
    d)
    Each
    monitor
    shall
    operate
    at
    all
    times
    while
    the
    associated control equipment
    is operating.
    (Source:
    Added
    at
    Ill.
    Reg.
    ________,
    effective
    _______________
    Section 215.489
    Compliance Schedule
    a)
    The owner
    or operator
    of an emission source subject
    to
    this Subpart,
    the construction or modification of which
    has
    commenced prior
    to
    (effective date
    of rule) must
    complete on-site construction or installation of the
    emission control
    or process equipment,
    or both,
    so
    as to
    operate
    in compliance with this Subpart by December
    31,
    1987.
    b)
    The owner
    and operator
    of any emission source subject to
    this Subpart,
    the construction or modification of which
    has not commenced prior
    to
    (effective date of rule),
    shall construct such source so that it will operate
    in
    compliance with this Subpart.
    (Source:
    Added
    at
    Ill.
    Reg.
    ,
    effective
    ____________
    IT
    IS
    SO
    ORDERED
    I,
    Dorothy
    M. Gum,
    Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Proposed Rule,
    First Notice
    Order
    was
    adopted
    on
    the
    ~
    day
    of
    ~
    1987,
    by
    a
    vote
    of
    ~‘°
    .
    Dorothy
    M. Gdnn,
    Clerk
    Illinois Pollution Control Board
    80—221

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