ILLINOIS
    POLLUTION CONTROL
    BOARD
    October
    1,
    1987
    IN THE MATTER
    OF:
    AMENDMENTS TO 35
    ILL. ADM.
    )
    R86—l2
    CODE
    211 AND 215, ORGANIC
    MATERIAL EMISSION STANDARDS
    AND LIMITATIONS,
    FOR POLYSTYRENE
    PLANTS
    ADOPTED RULE
    FINAL ORDER
    OPINION
    OF THE BOARD
    (by B.
    Forcac3e):
    This matter comes before the Board on
    a March
    11,
    1986,
    regulatory proposal by the Illinois Environmental Protection
    Agency (Agency)
    for the control
    of organic material emissions
    from polystyrene plants.
    Hearings were held on October
    15,
    1986,
    in Chicago and on October
    16,
    1986,
    in Joliet,
    Comments were
    received through January 23,
    1987.
    On January 16,
    1987,
    the
    Department
    of Energy and Natural Resources
    (DENR)
    filed
    a letter
    of negative declaration
    of economic impact, obviating the need
    for further economic study of
    the proposed rules.
    The Economic
    and Technical Advisory Committee of the DENR filed
    a concurrence
    on January 22,
    1987.
    The Agency filed
    an amended proposal on
    April
    6,
    1987, which entailed non—substantive codification
    changes.
    On May
    28,
    1987,
    the Board proposed regulatory language for
    first notice comment which was published
    at 11
    Ill.
    Reg.
    10985,
    June
    19, 1987.
    The statutory 45—day comment period ended on
    August
    3,
    1987.
    The Agency filed first notice comments, which
    were mailed on August
    3,
    1987
    (P.C.
    2).
    The Administrative Code
    Unit
    of
    the Secretary
    of State’s office also filed comments
    regarding non—substantive format changes.
    The Board proposed the
    rules
    for second notice review by the Joint Committee on
    Administrative Rules
    (JCAR)
    on August
    6,
    1987.
    The Adminis-
    trative Code Unit’s comments were incorporated
    in the second
    notice Order,
    Additionally,
    the Board deleted one of the
    incorporations by reference as unnecessary to this regulation.
    JCAR issued
    a Certification
    of No Objection on September
    23,
    1987.
    On September
    24,
    1987,
    the Board issued an Order directing
    the Clerk of the Board to file the rules with the Secretary of
    State’s office for final notice publication in the Illinois
    The Board acknowledges
    the contributions
    of David G. Mueller,
    hearing officer, in this proceeding.
    82—211

    —2—
    Register.
    This Opinion supports the Board’s Order of
    September
    24,
    1987,
    This
    is one of
    a series of
    Board actions directed at
    promulgating rules implementing Reasonably Available Control
    Technology
    (RACT)
    for the control
    of ozone precursors from
    existing major stationary sources
    (emissions greater
    than 100
    tons/year).
    The implementation of RACT
    in non—attainment areas
    for ozone is required as
    a part
    of
    a federally approvable State
    Implementation Plan
    (SIP)
    under
    the federal Clean Air Act
    (CAA)
    (42 U.S.C. 7401 et seq.).
    Section 172
    of the CAA requires that
    RACT be
    implemented
    at existing major stationary sources
    in the
    non—attainment areas
    of those states needing an extension from
    the 1982 deadline until
    1987 to achieve the air quality standards
    for ozone.
    Illinois is such
    a
    state,
    having requested the
    extension
    in its 1979 and 1982 SIP.
    The definition of RACT
    is contained in
    40 CFR 51,
    along with
    the requirements for
    a federally acceptable SIP.
    However,
    the
    specific parameter of what constitutes reasonably available
    controls and,
    therefore,
    the parameters which
    the states must
    adopt
    to ensure that RACT
    is
    implemented,
    are not.
    Instead,
    the
    United States Environmental Protection Agency
    (USEPA) publishes
    a
    series of documents entitled “Control Technique Guideline”
    (CTGs).
    Each of
    the CTGs,
    which are summaries of industries
    specific case studies, contains the means and the degree of
    control which
    the USEPA requires the states
    to adopt
    categorically as part of
    its SIP
    in order
    to have an acceptable
    SIP.
    Failure to adopt rules identical to those presented in the
    CTGs,
    or other
    ones demonstrated
    by
    the individual state as
    comparable,
    can mean that the state will have an inadequate SIP,
    which
    in turn, can trigger
    the sanction provision
    in CAA found at
    Section
    110,
    113 and 176
    (42 USC 7410, 7413, 7506).
    While the
    mandate for
    sanctions
    is contained in the CAA,
    the mandate
    to
    adopt
    the CTGs or otherwise demonstrate
    a state
    rule to be
    comparable
    is
    not.
    It
    is not even contain
    in the federal
    regulations,
    but instead,
    is articulated
    in the “general preamble
    for proposed rulemaking and approvable
    State Implementation Plan
    revisions for non—attainment areas”
    (44 FR 20372).
    This federal policy statement
    includes yet another
    requirement which
    is relevant to this rulemaking.
    The USEPA
    allows
    the states until the January after one year from the
    finalization of
    a CTG
    to adopt either the “rule” contained
    therein or comparable
    rule,
    if sources covered by that particular
    CTG are within
    a state’s non—attainment areas.
    A final
    CTG for
    the manufacture
    of high—density polyethylene, polypropylene and
    polystyrene resins was published in November
    of
    1983
    (Ex.
    3).
    The CTG defines RACT
    for
    the manufacture of high—density
    polyethylene, polypropylene and polystyrene resin.
    However,
    a
    search was made of the Agency’s emission inventory system (Total
    82—212

    —3—
    Air System
    TAS) which found no manufacturers of polypropylene
    or high—density polyethylene.
    All of the Illinois plants
    manufacture polystyrene.
    Consequently,
    the Agency’s proposed
    amendments only cover
    this process,
    rather than the full scope
    of
    the CTG.
    The
    CTG
    used
    a bulk polymerization plant as
    a basis
    for its
    flow diagram for polystyrene manufacture, but its model plant was
    an all—liquid—phase continuous process.
    On page
    4—1 of
    the CTG,
    the subparagraph number
    3, contains the RACT limitation which
    applies
    to
    the continuous processes.
    This limitation
    is given as
    0.12 kg
    of volatile organic material per 1000 kg
    of polystyrene
    resin produced.
    The CTG process description
    is for
    a “fully
    continuous co—polymerization process
    for the manufacture
    of
    pelletized polystyrene
    resin from styrene monomer
    and
    polybutadiene” rubber.
    The process
    is described as follows:
    Styrene,
    rubber,
    a
    catalyst
    (in
    some
    cases),
    recycle
    styrene,
    and
    other
    ingredients
    are
    dissolved in feed dissolver tank and pumped to
    a
    reactor,
    where
    a
    polymerization
    takes
    place.
    Polymer
    melt
    still
    contains
    some
    unreacted
    styrene
    and
    by—products,
    so
    it
    is
    pumped
    to
    a
    devolatilizer
    where
    these
    are
    separated
    and
    sent
    to
    a
    styrene
    recovery
    unit.
    Polymer melt
    is
    then pumped through an
    extrusion
    dye
    where
    it
    is
    solidified
    in
    the
    form
    of
    strands,
    which
    are
    pelletized
    and
    stored.
    In
    the
    styrene
    recovery
    unit,
    the
    unreacted
    styrene
    monomer
    is
    separated
    by
    distillation
    and
    recycled
    to
    the
    feed
    dissolver
    tank,
    Noncondensibles
    are
    vented
    through
    a vacuum system.
    The heavy components
    from the distillation
    (the fractions
    from
    the
    bottom
    of
    the
    distillation
    column)
    are
    often
    used as
    a fuel supplement
    in boilers.
    The
    CTG
    lists
    four VOM
    sources
    of
    importance
    in
    its model
    plant process.
    They are:
    1.
    The
    Feed
    Dissolver
    (FD),
    where
    the
    styrene
    monomer
    and
    the
    polybutadiene
    rubber are dissolved
    and mixed.
    The VOM
    emissions come chiefly during filling and
    washing
    and
    normally
    are
    vented
    to
    the
    atmosphere;
    2.
    The
    Styrene
    Condenser
    Vent
    (SCV),
    where
    unreacted
    styrene
    monomer
    is
    separated
    from
    the
    polystyrene
    in
    the
    vacuum
    de—
    volatilizer.
    The
    styrene
    is
    vented
    to
    the
    atmosphere.
    If
    a
    vacuum
    system
    is
    82—213

    —4—
    used
    (rather
    than,
    for example, steam jet
    ejectors),
    and
    a
    suitable condenser fol-
    lows
    the
    vent,
    emissions
    are
    lower.
    The
    CTG states that this point is the largest
    VOM source.
    3.
    The
    Styrene
    Recovery Unit Condenser Vent
    (SRtJCV),
    where
    noncondensible components
    are
    vented
    from
    the
    styrene
    recovery
    unit.
    4.
    The
    Extruder
    Quench Vent
    (EQV)
    is
    not
    a
    large
    source.
    Traces
    of
    styrene
    vapor
    are
    emitted
    as
    the
    polystyrene
    is
    being
    extruded into strands.
    These are usually
    removed by
    a demister
    or
    an electrostatic
    precipitator.
    Recently, USEPA has published additional RACT guidance
    to
    clarify the sources
    to be covered
    in this category
    (Ex, 4).
    To
    make certain that the proper sources are covered,
    the Agency has
    added definitions to Section 211.122 which describe and define
    the continuous process,
    material recovery section, styrene
    devolatilizer unit and styrene recovery unit.
    The geographical applicability of the proposed rules
    includes eight counties designated non—attainment for ozone, as
    well as two counties contiguous
    to the Chicago non—attainment
    area.
    These
    two counties, Will and McHenry,
    are considered part
    of the Chicago urbanized air quality planning region by the
    Agency and the
    (JSEPA.
    Organic emission sources within this
    urbanized area are believed to contribute
    to the Northern
    Illinois—Southwest Wisconsin ozone non—attainment problem.
    The Agency conducted
    a
    review of
    its permit files and field
    operation inspections in order
    to
    identify potentially affected
    facilities.
    It was determined that two presumably affected
    facilities were producing polystyrene by
    a batch—suspension
    process and thus would not be affected
    by the Agency’s
    proposal,
    Four potentially regulated facilities were identified;
    three facilities are located
    in Will County and one facility
    is
    in Cook County.
    Cosden Oil and Chemical
    (Calurnet City, Cook County)
    uses a
    conventional process as described in the CTG.
    Cosden’s poly-
    styrene lines have dissolving vessels without controls,
    styrene
    vent condensers
    (SCV) which are attached
    to the vacuum system and
    extruder quench vents
    (EQV) with hoods,
    The styrene from the
    styrene vent condenser
    is recycled
    through the dissolving vessel
    so that there
    is no styrene recovery unit vent.
    The finished
    polystyrene is made
    into pellets which are flash—dried rather
    than vacuum—devolatjlized.
    Cosc5en
    is planning
    to close
    its
    facility and cease operations in 1988
    (R.
    58).
    82—214

    —5—
    Permits from the Amoco facility
    (Joliet, Will County)
    indicate that there
    is
    a styrene condenser vent at the
    devolatilizer which
    is controlled by a condenser and vacuum
    system and
    a flow dissolver.
    There
    is also
    a Styrene Recovery
    Unit Condenser Vent
    in the form of
    a condensate recovery tower
    with
    a condenser and vacuum system.
    The permits do not specify
    if
    an Extruder Quench Vent exists,
    Dow Chemical (Joliet, Will County)
    has flow dissolvers
    in
    the form of dissolver tanks,
    styrene vent condensers in the
    form
    of
    a monomer separators,
    extruder quench vents
    in
    the form of
    exhaust hoods on the nozzles and dies which are fed
    a demister
    and
    a styrene recovery unit condenser vent that sends heavy
    material
    to the heaters as
    fuel.
    Mobil Chemical
    (Joliet, Will County) has flow dissolvers
    (FD),
    styrene condenser vents
    (SCV) with condensers and vacuum
    systems,
    a styrene recovery unit condenser vent (SRUCV)
    in the
    form of
    an oligomer stripper and extruder quench vent with
    electrostatic precipitators,
    All four plants
    are within the limitation of
    0.12 kg
    emissions per 1000 kg
    of production from the styrene condenser
    vent and the styrene recovery unit condenser vent as proposed
    in
    Section 215.877 as specified by the CTG.
    These emission data are
    all based upon engineering calculations which were supplied by
    letters
    to the Agency.
    While
    the Agency does not anticipate the
    need for testing
    to determine compliance,
    to have an enforceable
    regulation
    a testing method must be specified.
    Section 215.886
    specified Method
    25 which
    is the standard volatile organic
    material control equipment efficiency testing method used
    in
    other sections
    of the Board’s regulations and was used as
    the
    test method
    in emission data cited
    in the CTG
    (Ex.
    3,
    pp.
    10—14)
    and
    is cited
    as one of the appropriate testing method
    in the
    USEPA memorandum,
    dated September
    14,
    1984
    (Ex.
    8),
    Because all four
    sources appear
    to be currently
    in
    compliance with the proposed Section 215.877,
    it
    is expected that
    there will be no emission reductions
    or cost of control to comply
    with the limitations.
    The CTG, on page 5—25,
    states that
    “....current industry control
    is
    in
    a transitional period
    in which
    vacuum pumps
    are replacing steam eductors
    to produce the required
    vacuum
    ...“.
    The plants
    in major urbanized areas
    of Illinois
    have already made
    this transition and are thus in compliance with
    the RACT standard.
    This finding of no economic impact
    is
    supported by the Department of Energy and Natural Resources’
    letter of negative declaration.
    The Agency,
    in its first notice comments, noted that there
    are currently pending proposed amendments to the definition of
    “volatile organic material”
    (VOM)
    in
    a separate docket, R86—37.
    These proposed amendments would delete the vapor—pressure based
    82—215

    definition of VOM and would modify the definition proposed
    in the
    instant docket.
    The Agency recommended deleting the definition
    contained
    in the Board’s proposed rule
    in
    the R86—l2 docket and
    replace
    it with the proposed definition in R86—37.
    At second
    notice,
    the Board found that the best course of action was
    to
    retain
    the existing definition of VOM proposed at Section 215.104
    in this proceeding and address
    the proposed redefinition of VOM
    in the R86—37 docket.
    First,
    there
    is no record established
    in
    the instant proceeding supporting such
    a change.
    Second,
    the
    Board had not yet substantively ruled on the merits regarding the
    proposed redefinition of VOM pending
    in R86—37,
    as the record
    still remains open.
    (See R86—37, Proposed Redefinition of VOM,
    Opinion
    and Order,
    July
    16,
    1987.)
    During
    the second notice JCAR review,
    the Board agreed to
    make
    the
    following modifications:
    (1)
    In Section 215.881(a),
    the
    phrase “if applicable” was deleted from the last line;
    (2)
    In
    Section 215.88l(c),
    the phrase
    “and Section 215.883” was added
    to
    the end of the sentence;
    (3)
    In Section 215.883(a),
    the word
    “complete” was deleted from the first line;
    (4)
    In Section
    215.883(d),
    the citation “(Section 215.877)” was added
    to the
    third line;
    and
    (5)
    In Section 215.886, the full title of Method
    25 was added and the sentence “The incorporation by reference
    contains no
    later amendments and editions”
    was added.
    The Board adopts rules regulating organic material emissions
    from polystyrene manufacturing plants, as
    a
    final CTG for this
    category has been issued,
    sources
    in urbanized non—attainment
    planning areas have been identified and the rules constitute
    RACT.
    This action will help fulfill the state’s legal obligation
    to demonstrate that existing major stationary emission sources
    in
    non—attainment areas are subject
    to regulations
    representing
    RACT,
    as well as
    in regions
    that impact non—attainment areas.
    IT
    IS SO ORDERED
    I,
    Dorothy
    M. Gunn,
    Clerk of the Illinois Pollution Control
    Board, hereby certify
    tha~4 the above Opinion was adopted on
    the
    /~-‘
    day of _________________________,
    1987,
    by
    a vote
    of
    (~—~‘
    /~L~
    Dorothy M.’Gunn, Clerk
    Illinois Pollution Control Board
    82—216

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