1987 Illinois Ozone ExcursionsAbove the N~AQSLevel of 120 ppb
79-295

ILLINOIS POLLUTION CONTROL BOARD

July 16, 1987

IN THE MATTER OF:

)

)

PROPOSED AMENDMENTS TO PART

)

 R86—40

211 AND 215, AIR OXIDATION

)

PROCESSES IN THE SYNTHETIC

)

ORGANIC CHEMICAL MANUFACTURING

)

INDUSTRY

PROPOSED RULE.

 FIRST NOTICE

PROPOSED OPINION AND ORDER OF THE BOARD:

 (by J.D. Dumelle):

This matter comes before the Board upon a September

23,

1986

proposal for the adoption of amendments to

 35 Iii.

 Adm. Code

211

and 215 filed on behalf of the Illinois Environmental Protection

Agency (Agency).

 The proposal was accepted and authorized for

hearing by Board Order

 dated September 25,

 1986.

 Hearings were

held on February 24,

 1987 in Springfield and March

10,

 1987 in

Chicago.

 The Agency filed an amended proposal on November

30,

1987 and

a

 second amended proposal on June

1,

 1987.

The

Department of Energy and Natural Resources

 (DENR) filed

a

negative declaration on June 22,

 1987 and the Board was informed

of concurrence

 in that decision by the Economic and Technical

Advisory Committee on June

26,

 1987.

The overriding basis of this proceeding 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 Reasonable Available

Control

 Technology

 (RACT)

 on existing sources in non-attainment

areas.

 On May

 19, 1978,

 the USEPA gave notice

 at 43 Fed. Reg.

21673 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.

 A final CTC for control

of emissions from air oxidation processes

 in the synthetic

organic chemical manufacturing industry was published

 in December

of 1984.

 (See Ex.

5).

Air oxidation processes are those which introduce one or

more oxygen atoms

 into

 a compound while removing hydrogen or

carbon atoms.

 The reaction includes one or more chemicals with

oxygen supplied as air or

 a combination of air with ammonia or

halogens as reactants.

 Processes which use pure oxygen are not

included

 in this category.

 The processes used to produce air

oxidation chemicals vent large quantities of

 inert material

79-275

-2-

(predominantly nitrogen) containing volatile organic material

(VOM) to the atmosphere.

The heart of the Agency’s proposal

 is contained

 in Sections

215.490 and 215.495.

 The former section sets forth the area of

geographic applicability of the rules.

 The latter section sets

forth the applicable emission limitations

 which,

 in general,

require process vent streams to be vented to

 a combustion device

that

 is designed and operated either to reduce the VOM emissions

by at least 98

 or to emit less than

 20 parts per million VOM.

These limitations only apply, however,

 if the vent streams have

a

Total Resource Effectiveness

 (TRE) of less than 1.0 and the vent

streams are not controlled by an existing combustion device.

Section 215.495

 is patterned after the CTC,

 including the

rather unusual mechanism of basing applicability upon

 the TRE.

The Agency states that such an approach

is

 necessary,

at

 least

in

 part,

 because

of

the large variation

 in reaction types used to

produce oxidation chemicals,

 a characteristic

of

 this

 category.

 Thirty-six

 chemicals fall

within

 this

 category

 these

are

 produced

nationally

by

 fifty-nine

 companies

(in

 non-

attainment

 areas),

 in differing amounts,

and

using

 different

 techniques

of

 production

The

 TRE index

 is established through the use

of

 a specific formula

as

 set forth in Section

215.495(b)

of

 the proposed regulations

and

corresponds

to

 a cost effectiveness of $1,600

per megagrarn of VOC destroyed.

 (June

1,

1987

Statement of Reasons at 15-16).

The only issues which have arisen

 in this proceeding regard

the geographic applicability of the rule,

 the types of vents

covered, whether methods for determining VOM content other than

Reference Method

 18 can

 be used, and the scope of the grandfather

clause.

GEOGRAPHIC COVERAGE

The question of geographic coverage in this proceeding

is

virtually the same question raised

 in R86-39 which is today also

being proposed for first notice.

 Upon motion of Stepan Chemical

Company at the March 10,

 1987 hearing,

 the testimony of Mr.

 Erwin

Kauper,

 a certified consulting meteorologist, which was presented

at the April 24,

 1987, hearing in R86-l8 was incorporated into

this record in

 an apparent attempt to demonstrate that Will

County emissions do not contribute to ozone violations.

 That

testimony appears

 at 1034-1106 of the April

 24 hearing.

79.276

-3-

The Board examined this issue

 in the R86-39 Proposed Opinion

at pages

 2-5,

 at which it stated as follows:

Mr.

 Forbes

of

 the Agency,

 however,

 testified

that Will

 County

 should be included since it

is part

of

 the SIP area,

 that emissions from

the

 County

 impact

the

 ozone

air

 quality

of

the region,

 and that the emissions reductions

from application

of

 RACT

 to sources

 in Will

County

 have

 been

 included

in

 previous

analyses

and

are

 necessary

to

 demonstrate

attainment

of

the

 National

 Ambient

Air

Quality Standards

 (NAAQS).

 (R. 15-16).

The

 Board

has

 considered

the

 geographic

applicability

of

the

 RACT

 rules

in

 several

recent opinions: R82-14, April

19,

1987

 at 4-

5;

 R82-14,

 April

30,

1987

at

 21-22;

 R85-

21(A), May 28,

 1987 at 21-22;

 and R86-12, May

28,

1987

at

4.

 In each of

 these,

 the Board

indicated

 that

it

 would

 follow

the

 Agency’s

proposal that the RACT regulations

 be applied

to

 Cook,

 DuPage,

 Kane,

 Lake,

 Macoupin,

Madison,

 McHenry,

 Monroe,

St.

 Clair

 and Will

counties.

All

 except

 McHenry

and

 Will

are

presently

 designated

as

 non-attainment

for

ozone.

The

 fullest

and

 most

 developed

 analysis

of

this

 issue

 appears

in

the

 April

30,

1987

Opinion

 in R82-14

 at pp.

 21-22:

Several

 years

 ago,

 when

 these

proceedings

 were completed

 and RACT III

was

 proposed,

 much

of

the

 state

was

designated as non-attainment.

 When RACT

I was initiated,

 25 counties

 in Illinois

were

 non-attainment

for

 ozone.

The

rationale

for

 statewide

 applicability

was

 based

on

the

 pervasive

 statewide

ozone problem,

 the atmospheric transport

of

 ozone

and

 ozone

 precursors

 from

sources

in

 attainment

 areas

to

 non-

attainment

 areas,

and

the

 need

to

provide

for

 growth

in

the

SIP

(R.

40-

63).

At

 present,

 many

 areas

of

the

state have achieved attainment

 for ozone

and the major non-attainment areas,

 with

one

 exception,

are

 concentrated

in

the

Chicago

and

 East

 St..

 Louis

 major

urbanized

 areas

(R.

 3204-5).

 Macoupin

County

is

not

 located

in

a

 major

79-277

—4—

urbanized

 area

but

 continues

to

experience

 violations

of

the

 NAAQS

for

ozone.

Recent regulatory proposals have focused

on

 implementing

 RACT

in

the

 nine

counties

 that

 comprise

the

 Chicago

and

East

St.

 Louis

 major

 urbanized

 regions

and

 Macoupin

 County.

 Eight

of

 these

counties

are

 currently

 designated

 non-

attainment

 for ozone.

 Will and McHenry

counties

are

 currently

 designated

attainment for ozone but are part

 of the

Chicago

 urbanized

 area.

The

 SIP must,

in

 addition

to

 imposing

 RACT

on

 major

stationary

 sources

in

 non-attainment

areas,

 provide

for

 ultimate

 attainment

of

the

 ozone

 NAAQS.

To

 that

 end,

sources

in

 Will

 and McHenry

 still

 need

to be RACT controlled

 in order to ensure

adequate

 emission

 reductions

 because

of

the

 transport

of

 ozone

and

 ozone

precursors

 from

 these

 geographically

contiguous counties.

During

the

 course

of

the

 various

regulatory proposals

 for the heatset web

offset

 category,

no

 participant

has

raised

the

 issue

of

 changing

the

geographic applicability in light of the

current

 SIP strategy.

 Consequently,

the

Board

 will

 limit

the

 geographic

applicability

of

 RACT

 controls

to

the

ten

 counties

 designated

 either

 non-

attainment

 for ozone

or

 that are

 a part

of the Chicago urbanized area.

As

 noted

 above,

the

 geographic

 coverage

has

been questioned

 in this proceeding.

 The only

evidence

 presented

in

 opposition

to

the

Agency’s proposal

is

 contained

in

 the Kauper

material

 which

has

 been

 incorporated

by

reference.

Mr.

 Kauper concludes:

1.

 That

 the EKMA model used

 to demonstrate

approvability

of

SIP

 submissions

is

flawed;

2.

 That

 urban

 traffic

 sources

 rather

 than

point

 sources

 are responsible

 for ozone

exceedances;

and

79-278

—5—

3.

 That

 proper

 trajectory

 analysis

generally

 rules

 out the significance of

point

 sources

 in Will, Kane,

 MeHenry and

DuPage counties

 as contributors to ozone

exceedances.

(R.

 86-19,

 April

24,

 1987,

R.

 1045-1048

and

 1059).

While

the

 Board

 finds

Mr.

 Kauper’s

 analysis

to be

 interesting,

 the Board

 is not persuaded

of

the

 validity

of

his

 conclusions.

Mr.

Kauper

 bases

his

 conclusions

on

the

trajectory

 analysis.

A

 trajectory

is

constructed

by

 identifying

a

 specific

air

parcel

 (i.e.

one

 containing

an

 ozone

concentration

in

 excess

of

the

 NAAQS

for

ozone)

 and tracing

 the locations

of

the

air

parcel

 backward

in

 time

 using

 hourly

 wind

data.

 Trajectory

 analysis

 attempts

to

determine

the

 source

of

the

 emissions

 that

ultimately led

to

 the exceedances.

 Twenty-

nine

 (29)

 separate

 trajectories

 were

presented

by

Mr.

 Kauper

 showing

the

 paths

taken

by

the

air

 parcels

 that

led

to

 ozone

violations

in

 Illinois

and

 Wisconsin

on

22

days

 during

the

1985

and

1986

 ozone

seasons.

 These trajectories

 do tend

to

 pass

through

 the Chicago metropolitan area.

 They

do

 not,

 however,

 tend

to

 pass

 through

the

Chicago

 urban

 area

 during

 times

 when

 heavy

traffic would be expected.

Assuming

 the urban area

to

 be defined on the

trajectory

 maps

by

the

 area

 bounded

by

Evanston,

 Des Flames,

ORD

 (O’Hare),

 Cicero,

Midway,

SW

 Pump,

 Calumet

 City

and

the

 lake,

and assuming that heavy traffic would not be

expected

 prior

to

 5:30

 a.m.

 CST,

 only

8

of

the

29

 trajectories

are

 indicated

to

 have

passed

 through

the

 urban

 area

at

 relevant

times.

 On the other hand, at least

 15 of the

air

 parcels

 were

 over

 Lake

 Michigan

 during

the

 time

 period

 after

 5:30

am.

On

 this

simplistic

 basis

it

 appears

 more

 reasonable

to

 assume

 that

the

 problem

 stems

 from

 Lake

Michigan

 emissions

 rather

 than

 urban

traffic.

 That,

of

 course,

is

not

the

 case,

however,

and

it

 appears

 most

 reasonable

to

hypothesize that the ozone precursors

 in most

of

the

 cited

 cases

 were

 injected

 into

the

atmosphere

at

 some

 point

 prior

to

the

 last

79-279

—6—

plotted

 point

of

 most

of

the

 trajectories.

Thus,

 the data presented

 is of limited value

in

 determining

the

 sources

of

the

 ozone

exceedances

 studied,

and

is

of

 even

 more

limited

 value

 with

 respect

to

the

 stated

generalized

 conclusions.

 Furthermore,

Mr.

Kauper

 indicated

 that

 short

of

 extending

a

complete

 analysis

 farther

 back

in

 time,

the

best

 guess

as

to

the

 trajectories

 prior

to

the last plotted points would be based upon

a

presumed movement

 similar

to

 that

 indicated

by

the

 last

few

 plotted

 points.

 (id.

at

1074).

If

 that

 is done,

at

 least

20

 of the

29

 trajectories

 would

be

 expected

to

 pass

near,

or

 through,

 Will

 County.

It

is

difficult

 to understand,

 then,

how

 the Board

could

be

 expected

to

 conclude

 that

 Will

County sources

 are not contributing to these

ozone

 violations.

 Other

 factors

 serve

to

further

 undercut

Mr.

 Kauper’s

 conclusions.

Mr.

 Kauper admitted that he was not familiar

with

the

 location

of

 stationary

 sources

in

the Chicago area and that

 he simply assumed,

based

 upon

his

 knowledge

of

 other

 cities,

that

the

 Chicago

 urban

 area

 would

be

dominated by mobile

 sources.

 (id.

at

 1083).

Mr.

 Kauper

 further

 admitted

 that

 there

is

some

 uncertainty

 involved

in

 plotting

air

parcel

 trajectories,

 particularly

 over

the

lake

 where

 there

are

no

 wind

 velocity

measurements.

 (id.

at

 1075-1079).

One

 such

uncertainty

is

the

 presumption

 that

 wind

speed

 increases

by

50

 when

the

air

 parcel

moves

 offshore

due

to

the

 reduction

in

surface

 friction.

 (Id.

at

 1079-1080).

Studies

 over

 oceans

 have

 shown

a

35

factor.

 (id.

at

 1080).

 Over the distances

involved,

 this

 difference

 could

be

significant,

 since

 the uncertainties

 could be

additive.

The

 Board

 simply

 cannot

 conclude

 that

Mr.

Kauper’s

 data

 supports

his

 conclusion

regarding

 ozone

 exceedances

 being

 caused

by

Chicago

 urban

 mobile

 sources.

 While

the

Board

is

 inclined

to

 agree

 that

the

 EKMA

model may have shortcomings

as

 a predictor of

ozone exceedances near Lake Michigan and that

a

 substantial

 majority

of

the

 studied

exceedances

are

 impacted

by

 lake

 effect

winds,

 insufficient

 information

has

 been

provided to demonstrate that Will County does

7 9.280

—7—

not

 contribute

to

 those

 exceedances

 even

assuming

the

 accuracy

of

the

 plotted

trajectories.

The state

 is required to have an approved SIP

for

 ozone,

and

it

is

 already

 late

in

 that

effort.

On

the

one

 hand,

the

 Agency’s

proposal

 appears

to

be

 federally

 approvable;

on

the

 other

 hand,

 there

are

 serious

questions

as

to

 whether

an

 attainment

demonstration

 could

be

 made

if

 Will

 County

were

not

to

be

 subject

to

the

 proposed

rules.

As

set

 forth

by

 Steve

 Rothblatt,

Chief,

 Air and Radiation branch of

 1JSEPA,

in

order

to

 exclude

 Will

 County

 from

the

proposal,

 “USEPA

 would

 have

to

 be convinced

that

 emissions

 from

 Will

 County

do

not

contribute to the emissions which lead to

the

violations of the ozone standard found

 in and

downwind

of

 the Chicago area.

In

 addition,

it

 would

be

 necessary

for

the

 state

to

prepare,

 adopt

and

 submit

a

SIP

 revision

which

 includes

a

new

 EKMA analysis

 which

would have

to

 reflect

 new values

 for various

parameters

 which

 would

be

 affected

by

the

reduction

in

 analysis

 area.

 (Attachment

to

Agency

 comments,

 Rothblatt

 letter

at

2),

Furthermore,

if

 Will County

is

 excluded

 from

coverage,

a

 “completely revised

 set of

 input

data would

be

 required”

and

the

 delay

 which

would

be

 required

for

 such

an

 analysis

and

review

by

 USEPA

may

 well

 subject

 Illinois’

program

 “to

 various

 additional

 requirements

currently

 under

 development

by

 USEPA.”

(id.)

 That

is,

by

the

 time

 such

a

reanalysis’s

 could

be

 completed,

 USEPA

may

well

 have

 revised

its

 procedures

for

approval,

 thus requiring additional support.

Finally,

 ozone

 levels

 recorded

 during

the

1987

 ozone

 season

 appear

to

 demonstrate

the

prudence

of

 including

 some

 attainment

counties

 under

the

 coverage

of

 these

 rules.

Dr.

Rao

of

 the Board’s

 Scientific/Technical

Staff

has

 introduced

 two exhibits

at

a

 June

30,

1987

 hearing

in

 R86-37

 containing

preliminary

 details

of

the

1987

 exceedances

of

the

 NAAQS

 for ozone

 based upon monitored

 data.

The

 Board,

on

its

own

 motion,

 hereby

makes

 those

 same documents

 exhibits

in

 this

proceeding.

79-281

—8-

The

 first

 document

 (Exhibit

 10),

 entitled

“1987

 Illinois

 Ozone

 Excursions

 Above

the

NAAQS Level

of

 120 ppb,”

 consists

of

 a table

showing

the

 date

and

 location

 (city

and

county)

of

 monitoring

 sites

 along

 with

measured

 values

of

the

 ozone

 concentration.

This

 table

was

 complied

by

the

Scientific/Technical Section

 (STS), using the

information

 provided

by

Bob

 Swinford

and

Will Flowers

 from the

 Illinois

 Environmental

Protection Agency

 (Agency).

 Dr. Rao from the

STS has spoken with the Agency personnel on

a

number of occasions to update the table which

includes data up to July 15,

 1987.

Bod

 Swinford

 provided

the

 second

 document

(Exhibit

 11),

 which

is

a

 summary

 report

generated

by

 the Agency using data

 from the

ozone

 monitoring

 sites

in

 Illinois.

 This

report,

 updated June

22,

 1987,

 is similar

to

the earlier

 described

 table, but

 in addition

also

 shows

1)

the

 number

of

 excursions

 that

have

 taken

 place

at

 each

 location;

2)

the

date

and

location

sites

with

measured

ozone

concentrations

between

120

and

125

ppb

which have been labeled unhealthful pollution

standard

 index

 (PSI)

 days;

and

3)

 dates

and

regions

 where

 ozone

 advisories

 were

 issued

along

 with

the

 monitor

 which

 triggered

the

event.

It

is

 interesting to note that several of the

1987

 exceedances

 occur

in

 counties

 that

are

presently classified

 as attainment for ozone

(Will, McHenry, and Peoria).

 Obviously,

 this

may

 have

a

 bearing

on

 whether

the

 Board

should

applying

RACT

controls

counties

presently

 designated

as

 attainment.

The

Board requests comment on the significance of

these exhibits.

Given

the

 Board’s

 findings

 concerning

the

sufficiency

of

the

 Kauper

 testimony,

the

Board

 concludes

 that

 there

is

 no reasonable

likelihood

 of demonstrating attainment

 based

upon

 reanalysis

of

the

 ozone

SIP

 without

including Will County.

 Since

 the failure

to

demonstrate

 attainment

 would

 result

in

disapproval

of

the

SIP

and

the

 state

is

required

to

 have

an

 approved

 SIP,

the

 Board

proposes

 that

 these

 rules

be

 applicable

to

the ten counties proposed.

79-282

—9—

The Board has added

 the same exhibits referred to above as

Exhibits

 10 and 11 into this proceeding as Exhibits

 15 and

16.

As

 in R86-39,

 the Board concludes that it will propose that these

rules be applicable to the ten counties proposed by the Agency.

VENT COVERAGE

Dan Muno of Stepan argues that the Agency’s proposal

improperly extends the universe of vents

 covered under the

Agency’s

proposal

beyond

those

vents

covered

the

CTG

that

the

proposal

covers

all

process

 vents while the CTG covers only

the

main

reactor

vent

and

not

the

distillation

vents

any

other

vents

associated

with

the

process.

(R.

70-71).

The

Agency

disagrees, contending that

 “the CTG exempts only ‘process vents

that

result

from

the

product

purification

reactor

bottom

stream.’”

(Agency

Comments,

April

15,

1987,

2).

Further,

the

Agency believes that it

 is appropriate to include

 reactor bottom

streams

in

 this rulemaking,

 since

 the technology to control them

is reasonably available,

 the method for controlling these streams

is

 included

 in the CTC, and the method is sound.

 (Agency

Comments at

4).

As proposed by the Agency the rules require controls on

streams only if the cost of control

 is $1,600/Mg or less.

The

Agency has contended that the TRE is applicable to all streams

which

may

covered

the

proposal,

and

the

record

fails

contain any evidence to the contrary.

 The Board can discern no

reason

for

the

failure

the

 CTG to be made applicable to these

streams other than the fact that these streams were to be covered

under another CTG which has not been published.

 That fact does

not lead to the conclusion that it would be inappropriate to

cover those streams here.

 The reason may simply be that USEPA

has preconceived functional groupings to be covered by various

CTGs, that reactor bottom streams could

 fall within two or more

of those functional groupings, and that USEPA simply decided they

fit better within another category.

 That does not mean that

future controls will

 be any more or less stringent than

 if they

had been covered under

 this CTG,

 or that coverage under these

rules

 is inappropriate.

Given

 the absence of any showing

 to the contrary and the

apparent applicability of the TRE to all streams,

 the Board

concludes that the Agency has reasonably included all streams

in

its proposal.

 The Board will,

 therefore, propose the Agency’s

language for first notice.

REFERENCE METHOD

18

In the rules as proposed by the Agency, Appendix A, Section

A.3(b)(2)(i) redesignated

 in this proposl as Appendix E,

 Section

(b)(2)(A)

 requires the use of Reference Method

18

 to measure the

concentration of all organics,

 including those containing

79.283

-10-

halogens.

 Dan Muno testified,

 however, that “there should be

provision

for

 alternative test methods because Method

 18 will not

determine

compounds

 that

(1)

are

polymeric

(high

molecular

weight),

(2)

can

polymerize

before

analysis

(3)

have

very

low

vapor

pressures

stack

instrument

conditions.”

(R.

71-

72).

The

Agency’s

response

simply

that

“Method

18,

specified

the

proposed

rule

good

method

wide

applicability.

However,

any

company

would

propose

another

test

method

use

for

any

particular

chemical,

the

Agency

would

happy

look

any

such

proposals

determine

whether

(sic)

would

acceptable.”

(P.C.

No.

5).

Mr.

Muno

has

properly

set

forth

the

limitations

Reference

Method

and

the

Agency’s

willingness

look

 other methods

does

not

remedy

the

problem

the

present

proposal.

proposed

the

Agency,

affected

 facilities would be required to use

a

test

method

which

admittedly

not

useful

under

certain

conditions.

The

Board

does

not

believe

that

should

required,

and

has

rewritten

the

rule

require

 that Method

used

unless

one

the

circumstances

noted

Mr.

Muno

present

 which case Reference Method 25(a) must be used.

The

Board believes that Method 25(a) would be appropriate

 in such

circumstances,

but

requests

comment

its

propriety.

GRANDFATHER CLAUSE

Under

 Section 215.495(b)

 a facility otherwise required to

meet

the

limitations

Section

215.495(a)

need

not

meet

those

limitations

has

existing

combustion

device

 until that

device

“replaced

for

other

reasons.”

The

Agency

stated

its

position

follows:

The

Agency

 believes

 that

 what

 constitutes

“replacement

the

combustion

device”

will

probably

need

 determined on

a

 case

by

case

basis.

Certainly,

the

Agency

believes

that

 if replacement of the catalyst

 is only

a

small

 fraction

of

 the cost

 of replacing

the

incinerator,

then

IEPA’s

interpretation

the

proposed

rule

 would not require

 a company

comply

with

the

emissions

limitation

the

rule

that

point.

Similarly,

IEPA’s

interpretation

the

proposed

 rule

that

if

the

 cost

 of replacing

the

 catalyst

is,

for

example,

over

half

the

cost

new

incinerator,

the

company

would

required

upgrade

its

incinerator

and

come

into

compliance

 when

it

 replaced

a

catalyst.

(P.C.

No.

1

5).

79-284

—11—

~tepan,

however,

requests

that

language

added

the

rule

clarify

that

catalyst

replacement

would

not

constitute

replacement

 the device “for other reasons.”

 Stepan’s view

appears

general

accord

with

the

intent

the

grandfather

clause

and

the

Agency’s

proposed

language.

The

intent

the

provision

appears

allow

 facilities which

have

made

relatively

recent

investment

combustion

control

device

avoid

having

replace

that

device

during

its

useful

life.

 The Board does not believe,

 in general,

 that the

replacement

catalyst

should

 equated with the replacement

the

device:

replacement

catalyst

the

 realm of

operation

and

maintenance.

the

other

hand,

makes

little

sense

allow

device

continue

 grandfathered

if

new

compliant device would cost little more than the replacement of

the catalyst in

 a non-compliant device.

The Agency does not believe that “replacement” needs

 to be

further defined.

 However,

 the Agency has suggested the following

additional language as acceptable

 if the Board were to determine

clarification to be necessary:

The

 combustion

 device

is

 considered

to

be

replaced when all

of

 the device

 is replaced,

or

 when

the

 cost

of

 replacement

of

 part

of

the device equals

50

 or more of the cost of

replacing the entire device.

(Agency Response at

4).

The Board believes that clarification

 is appropriate.

The

concept of replacement for the other reasons

 is vague,

 and to the

extent

 it can be clarified,

 it should be.

 The Board has,

therefore,

 added language generally in line with the Agency’s

suggestion

except

that

 it has added the concept that significant

repairs

can

considered

replacement

and

further

clarifies

that

the

provision

based

upon

the

relationship

the

cost

of replacement and the cost of

 a compliant device rather than the

cost of replacement and the cost of

 a grandfathered device as

Stepan appears

 to assume.

With

 the exception of the noted changes

and

 a few minor non-

substantive changes,

 the Board will propose for first notice the

rules

proposed

the

Agency.

ORDER

The Board hereby proposed the following rules for first

notice publication

 in the Illinois Register.

79-285

-12-

TITLE 35:

 ENVIRONMENTAL PROTECTION

SUBTITLE

B:

 AIR POLLUTION

CHAPTER

I:

 POLLUTION CONTROL BOARD

SUBCHAPTER

c:

 EMISSION STANDARDS AND LIMITATIONS

FOR STATIONARY SOURCES

PART 211

DEFINITIONS AND GENERAL PROVISIONS

Section 211.122

 Definitions

“Air Oxidation Process”:

 any unit process including

ammoxidation or oxychiorination that uses air

or

a

combination of air and oxygen as an oxidant

in

combination with one or more organic

 reactants to

produce_on_or_more organic compounds.

“Cost Effectiveness”:

 the annual expense for cost of

control of

 a given process stream divided

 by the

reduction in emissions of organic material of that

stream.

“Flow”:

 For the purposes of Part 215, Subpart

 V, vent

stream flowrate (scm/mm),

at

 a standard temperature of

20°C.

“Full Operating Flowrate”:

 For the pur~osesof Part

215,

 Subpart

 V, maximum operating capacity of the

facility.

“Hourly Emissions”:

 For the purposes of Part 215,

Subpart V,

 hourly emissions reported in kg/hr measured

at full operating flowrate.

“Net Heating Value

 (Hr)”:

 For the purposes of Part

 215,

Subpart V,

 vent stream net heating value

 (MJ/scm), where

the net enthalpy of per mole of offgas

 is based on

combustion at 25° C and 760 mm

 Hg, but the standard

temperature for determining the volume corresponding

to

one mole is 20°C,as

 in the definition of

 “Flow” in this

Section.

“Process Vent Stream”:

 For the purposes of Part 215,

Subpart

V,

 an emission stream resulting from an air

oxidation process.

“Total Resource Effectiveness Index

 (TRE)”:

 Cost

effectiveness

 in dollars per megagram of controlling any

gaseous stream vented to the atmosphere from an air

oxidation process divided by 1600$/mg,

 using the

criteria and methods

 set forth in Part 215,

 Subpart

 V of

these regulations

 and Appendices thereto.

79-286

—13—

“Volatile Organic Material”:

 Any ergan±ema~ei’~a~

 w1~eh

1~asa vapor p~esst~eof ~~24

kPa

42TS

 p5~48-

O!~

gI~ea~ei

a~294z3~K479Qp4.

 Fe~pt~pesesof

5

~

 Adm- Ge~e

2157442

~oug1’~

21S~444; ve1a~i~1eo1~gaw~ema~e~a~

means

any o~gan~ema~e~a1wh~eh1’~as a vapor p~essu~eof ~9~34

kPa 41~Sps~a~a~

294~3’~K

 ~F4~

 Fof p~pesesof 35

~

 A~m~

 cede 215T181

~1ifeugl~

215184T

 2157445 ~1’Lre~gh

5~451~

5T294

 ~hi’eug1~2157299w ~T49~

 ~K~ough

215V494T

2157461

th~eugk

21S7464

an~ 21576~1 ~hrettg~

2157693 vo1a~1eoigan~ema~ei~a1~eens any o~gen~e

ma~e~a1wh~e1~

I~as

a

 vapei” pressure g~ea~e~

 than

9T913

kPa 4~9919

psi~a~

a~294~3~14~9~F4T

Any

organic

materials

which

participates

atmospheric photochemical reactions or is measured

by the applicable reference methods specified under

Part 230, Appendix A

 (40 CFR

 60, Appendix A) unless

specifically exempted from this definition.

b)

 For purposed of this definition, the following are

not volatile organic materials:

Methane

Ethane

1,1,1 trichioroethane

Methylene chloride

Trichiorofluoromethane

Dichlorodifluoromethane

Chiorodifluoromethane

Trifluoromethane

Trichlorotrifluorethane

Dichiorotetrafluoroethane

Chloropentafluoroethane

TITLE

35:

ENVIRONMENTAL

PROTECTION

SUBTITLE

B:

 AIR POLLUTION

CHAPTER

I:

 POLLUTION CONTROL BOARD

PART

215

ORGANIC MATERIAL EMISSION STANDARDS

AND

LIMITATIONS

SUBPART V:

 AIR OXIDATION PROCESSES

Section 215.490

 Applicability

The provisions

 of this Subpart shall apply to plants using air

oxidation processes and which are located

 any of the following

counties: Will,

 McHenry, Cook, DuPage,

 Lake,

 Kane, Madison,

St.

Clair,

 Macoupin and Monroe.

79.287

—14—

Section 215.495

 Emission Limitations of Air Oxidation

Processes

a)

 No person shall cause or allow the emissions of

volatile organic material from any process vent stream

unless the process vent stream

is

 vented to

a

combustion

device

that

designed

 and operated either:

1)

 to reduce the volatile organic emissions vented to

with

efficiency

least

ninety-eight

(98) percent by weight,

or

2)

 to emit volatile organic material

at

a

concentration

less

than

twenty~arts

per

million

by volume, dry basis.

Air

oxidation

facilities

for

which

existing

combustion device is employed to control process VOM

emissions

are

not

required

meet

the

percent

emissions

 limit

 until the combustion device

 is replaced

for

other

reasons.

The

combustion

 device

 is considered

to be replaced when all of the device is replaced or

when

the

cost

the

repair

the

device

the

 cost

of replacement of part of the device exceeds

50

 of the

cost of replacing the entire device with

 a compliant

device.

The

limitations

subsection

(a)

above

shall

not

apply

to any process vent stream or combination of process

vent streams which has

 a Total Resource Effectiveness

(TRE)

 Index greater than 1.0,

 as determined by the

following

methods:

air

oxidation

process

has

than

one

process vent stream,

 the Total Resource

Effectiveness

 (TRE)

 Index shall be based upon

a

combination of the process vent streams.

2)

 The TRE

index

 of a process vent stream shall be

determined according to the following equation:

TRE

(FLOw)°•88

c(FLOW

d(FLOW)(H~)

e(FLOW)O.SS) (H°O.8)

f(FLOW)°°~5~

where:

TRE

 Total resource effectiveness index

value.

79-288

-15—

FLOW

 Vent stream flowrate (scm/mm),

at

a standard temperature

 of 20°C.

Hourly measured emissions in Kg/hr.

Ht

 Vent stream net heating value

(NJ/scm), where the net enthalpy

per mole of offgas

 is based on

combustion at 25°Cand 760 mm Hg,

but the standard temperature for

determining the volume

corresponding to one mole

 is 20°C,

as

 in the definition of FLOW.

a,b,c,d,e,and

f

 coefficients.

The

coefficients shall

 be obtained by

use of Appendix

 F to this Subpart.

(Board

Note:

For

nonchiorinated

 process vent streams,

if

 3.6 is

less than net heating value, designated

 a H~

 FLOW shall

be

replaced by “FLOW

x

TL~

 /3.6” for purposes

 of calculating TRE.)

3)

 The actual numerical values used

 in the equation

described in subsection

 (2) above

 shall

be

determined as follows:

A)

 All reference methods and procedures for

determining the flow,

 hourly emissions

and net heating value,

 shall be in

accordance with Appendix E to this

Subpart,

B)

 All coefficients described in Subsection

(2)

 shall be

 in accordance with Appendix

F to this Subpart.

Section

215.1+96

Testing

and

Monitoring

~on

request

the

Agency,

the

owner

operator

air oxidation process shall demonstrate compliance wit1~

this Subpart or any portion thereof by use of the

methods specified in Appendix E to this Subpart.

b)

 A person planning to conduct

 a volatile organic

material emissions test to demonstrate compliance with

this Subpart

 shall notify the Agency of that intent not

 less than

 30 days before the planned initiation of the

tests

 so that the Agency may observe the test.

In

addition, the test procedure shall follow all stack

test procedure specifications filed in accordance with

the Administrative Procedure Act.

79-289

—16-

Section 215.497

 Compliance Date

Every owner

 or operator of an emission source subject to this

Subpart shall comply with

 its standards and limitations by

December

 31, 1987.

APPENDIX

E:

 REFERENCE METHODS

AND

PROCEDURES

INTRODUCTION

This appendix presents the reference methods and procedures

required for implementing RACT.

 Methods and procedures are

identified for two types of RACT implementation:

(1)

determination of VOC destruction efficiency

 for evaluating

compliance with the 98-weight percent VOC reduction or 20 ppmv

emission limit

 specified in the recommended RACT;

and

(2)

determination of offgas flowrate, hourly emissions, and stream

net heating value for calculating

a

TRE

 index.

 All reference

methods identified in this appendix refer to the reference

methods specified at

 40 CFR Part

60

 Appendix A.

a.

 VOC DESTRUCTION EFFICIENCY DETERMINATION

The following reference methods and procedures are

required for determining compliance with the percent

destruction efficiency specified in the recommended

RACT.

1)

 Reference Method

1

or

1A,

 as appropriate,

for

selection of the sampling site.

 The control

device inlet sampling site for determination of

vent stream molar composition or total organic

compound destruction efficiency shall

 be prior to

the inlet of any control device and after all

recovery devices.

2)

 Reference Methods

2,

2A,

 ZC, or

 2D as appropriate,

for determination of the volumetric flowrate.

3)

 Reference Method

 3 to measure oxygen concentration

of the air dilution correction.

 The emission

sample shall be corrected

to

 3 percent oxygen.

4)

 Reference Method

 18 to determine the concentration

of total organic compounds

 (minus methane and

ethane)

 in the control device outlet and total

organic compound reduction efficiency of the

control device.

b.

 TRE INDEX DETERMINATION

79-290

—17—

The followin~reference methods and procedures are required

for determining the offgas flowrate, hourly emissions,

and

the net heating value of the gas combusted to calculate the

 vent stream TRE index

 value.

1)

 Reference Method

 1 or

 lÀ,

 as appropriate,

for

selection of the sampling site.

 The sampling site

for the vent stream ~lowrate and molar composition

determination prescribed

in

 (b)(2) and

 (3) shall

be prior to the inlet of any combustion device,

prior

 to any post-reactor dilution of the stream

with air, and prior to any post-reactor

introduction o~halogenated compounds into the

vent stream.

 Subject

 to the preceding

restrictions on the sampling site,

 it shall be

after the final recovery device.

 If any gas

stream other

 than the air oxidation vent stream

is

normally conducted through the recovery system of

the affected facility,

 such stream shall be

rerouted or turned off while the vent stream is

sampled, but shall be routed normally prior to the

measuring of the initial value of the monitored

parameter(s)

for

determinin~

compliance

with

the

recommended RACT.

 If the air oxidation vent

stream is normally routed through any equipment

which

 is not

 a part of the air oxidation facility

as defined in Chapter

4,

 such equipment shall

be

~ypassed

 by the vent stream while the vent stream

is sampled,

 but shall not be bypassed durin~the

measurement of the initial value of the monitored

parameter(s)

 for determining compliance with

subpart V.

2)

 The molar comyosition of the vent stream shall

be

determined using the following methods:

A)

 Reference Method

 18 to measure the concentration

of all organics, including those containing

halogens, unless

 a significant portion of the

compounds of interest are polymeric

 (high

molecular weight),

 can polymerize before analysis

or have low vapor pressures,

 in which case

Reference Method

 25(a)

 shall be used.

B)

 ASTM D1946-67 (reapproved

 1977)

 to measure the

concentration of carbon monoxide and hydrogen.

C)

 Reference Method

4

 to measure the content of water

vapor,

 if necessary.

3)

 The volumetric flowrate shall be determined using

Reference Method

2,

2A,

 2C, or

2D,

 as appropriate.

79-291

-18-

4)

 The net heating value

 of the vent stream shall be

calculated using the following equation:

n

Ht

K1

 S C1 H1

1=1

H~.

 Net heating value of the sample, NJ/scm, where the

net enthalpy per mole

 of offgas

 is based on

combustion at 25°Cand 760 mm Hg,

 but the standard

temperature for determinin~the volume

corresponding

 to one mole is 20°C,as

 in the

definition of

Q~

(offgas Elowrate).

K1

 Constant, 1,740 x lO~

1

 g riole

NJ

ppm

scm

 kcal

where

standard temperature for g-rnole/scm is 20°C.

C1

 Concentration of sample component

 I, ppm,

as

measured

Reference

Method

 18 and A$TM D1946—67

(reapproved

 1977),

 reported on

 a wet basis.

H1

 Net heat

of combustion of sample component

i,

kcal/g-mole based on combustion at 25°Cand 760 mm

Hg.

 The heats of combustion of vent stream

components

 would be required

 to be determined

using ASTM

D2382—76

published

values

are

not

available or cannot be calculated.

5)

 The emission rate of total organic compounds

 in the

process

 vent stream shall be calculated using the

following equation:

n

Et0c

K2

(S

 C1 N1)

Qs

1=1

 TOC emission rate

of total organic compounds

(minus methane and ethane)

 in the sample,

kg/hr.

Constant,

 2.494 x

io6

 (1/ppm)

 (g-mole/scm)

(kg/g)

 (min/hr), where standard temperature

for

 (g-mole/scrn)

 is 20°C.

Molecular weight of sample component

i,

g/g-

mole.

Vent stream flowrate (scm/mm),

at

 a standard

temperature

 of 20°C.

79-292

—19—

The

total

vent

stream

concentration

(by

volume)

compounds

containin~

halogens

(ppmv,

compound)

shall

be summed from the individual concentrations of

compounds containing halogens which were measured by

Reference Method

18.

APPENDIX

COEFFICIENTS

THE

TOTAL

 RESOURCE-EFFECTIVNESS

(TRE)

INDEX

EQUATION

3.5

FOR

CHLCRINATFI)

PROCESS

VENT

SIREANS,

NET

HEATING

VALUE

(NJ/scm)

W

STREAM

FL~RATE(scm/mm)

b

d

f

13.5

48.73

0.404

—0.1632

13.5

W

700

 42.35

0624

 0.404

 -0.1632

U

0~0245

700

W

1400

 84.38

 0.678

0.404

 -0.1632

U

 0.0346

1400

W

2100

 126.41

 0.712

 0.404

 —0.1632

U

 0.0424

2100

W

2800

 168.44

 0.747

 0.404

 —0.1632

0

 0.0490

2800

W

3500

 210.47

 0.758

 0.404

 —0.1632

U

 0.0548

FOR

CHLCRINATE)

PROCESS

VENT

SIREAMS,

3.5

NET

HEATING

VALUE

(NJ/scm):

w

 Vent Stream Flowrate

(scm/mm)

a

b

c

d

e

f

W

13.5

 47.67

0

 —0.292

0

0

0

13.5

W

700

 41.48

 O~6O5

 -0.292

U

U

 0b245

700

W

1400

 82.84

 0.658

 —0.292

U

U

0.0346

1400

W

2100

 123.10

 0.691

 -0.292

U

U

0.0424

2100

W

2800

165.36

0.715

-0.292

U

U

0.0490

2800

W

3500

 206.62

 0.734

 -0.292

U

U

 0.0548

FOR

~)NCHUiUNAT~)PROCESS

VENT

STREAMS,

NET

HEATING

VALUE

(MJ/scm)

0.48:

W

Vent

Stream

Flowrate (scnVmin)

a

b

c

d

e

f

W

 13.5

13.5

W

1350

19.05

16.61

32.91

49.21

0

0T239

0.260

0.273

0.113

0.113

0.113

0.113

-0.214

—0.214

-0.214

-0.214

0

U

U

U

0

0~0245

0.0346

0.0424

1350

W

_2700

2700

4050

79-293

-20-

d)

R)R

NUNeFLwIUNAra)

ii(0C~S VF1~4T SIREAMS,

0.48

 NE!’

HEATING

VALuE

(NJ/scm)

1.9:

Vent

Stream

Flowrate

(scnVmin)

a

b

c

d

e

f

13.5

19.74

 0.400

 —0.202

0

0

13.5

W

1350

 18.30

0138

 0.400

1350

W ~z2700

 36.28

 0.150

 0.400

2700

W

4050

54.26

0.158

 0.400

-0.202

U

00245

-0.202

U

0.0346

-0.202

U

0.0424

FOR

N.)NCHWRINATF)

 PROCESS VENT

STREAMS,

1.9

NET

HEATING

VALUE

(MJ/scm)

3.6:

Vent

Stream

Flowrate

(scm/mm)

a

b

c

d

e

f

W

 13.5

 15.24

0

 0.033

0

0

0

13.5

W

1190

13.63

0157

0.033

1190

W

2380

26.95

0.171

0.033

2380

3570

 40.27

 0.179

 0.033

5

U

0:0245

U

U

 0.0346

U

U

 0.0424

FOR

NGNCHLORINATED

R~0CESSVENT

SIREANS,

3.6

NET

HEATING

VALUE

(NJ/scm):

w

 Dilution Flowrate (scnvmin)

a

b

c

d

e

f

W

 13.5

 15.24

0

0

0.0090

0

0

13.5

W

1190

 13.63

U

U

1190

W

2380

 26.95

U

U

2380

W

3570

 40.27

U

U

0.0090

0Th503

oTo24s

0.0090

 0.0546

 0.0346

0.0090

0.0573

b.0424

IT IS SO ORDERED.

I,

 Dorothy

 N. Gunn,

 Clerk

Board, hereby certify ~

the

adopted

the

(-i~-~

of

_____________

the

Illinois

 Pollution Control

above Opi~ionand Order was

day of

1987

 by a vote

79-294

1987

 Illinois Ozone Excursions

Above the N~AQSLevel

of

 120 ppb

Date

 Pbnitoring

Site

(County)

 Concentration (ppb)

4/18/87

 Lisle, IL

 (Cook)

139

6/13/87

 Chicago

 Edgewater

(Cook)

156

6/13/87

 Chicago

—

 South Water Filtration Plant (Cook)

135

6/13/87

Chicago

 Taft High

School

(Cook)

138

6/13/87

Deerfield,

(Lake)

130

6/13/87

 Waukegan,

(Lake)

126

6/14/87

 Chicago

—

 Edgewater (Cook)

140

6/14/87

 Chicago

 South-East Police Station

 (Cook)

144

6/14/87

 Chicago

—

South

 Water Filtration Plant

 (Cook)

135

6/14/87

 t~vanston,1L

 (Cook)

 l’d

6/14/87

 Waukegan, IL (Lake)

140

6/16/87

 c~aterloc, IL

 (Monroe)

14o

6/17/87

 Cary, IL (McHenry)

129

6/17/87

 DesPlaines,

 IL (Cook)

127

6/17/87

Evanston,

 IL (Cook)

132

6/i8/67

 Calu~TetCity,

IL

 (Cook)

139

6/18/87

 Chicago

 Edgewater (Cook)

162

6/18/67

 ~hicagc

—

 South—East Police Station (Cook)

165

6/18/87

 Chicago

—

 Taft High

School

(Cook)

148

6/18/87

 Cicero,

 IL (Cook)

146

6/18/87

 Deerfield, IL

 (Lake)

150

6/18/87

 DesPlaines,

IL

 (Cook)

129

6/18/87

 Evanston,

(Cook)

149

6/18/67

Libertyville,

IL

 (Lake)

164

6/18/87

Waukegan,

(Lake)

178

6/19/87

Evanston,

(Cook)

133

6/19/87

 Libertyville, IL

 (Cook)

144

6/19/87

WauKegarl,

(Lake)

141

6/20/87

 Chicago

—

 Taft High

School

 (Cook)

129

6/23/87

Lemont,

 IL (Cook)

129

6/23/87

 South

Lockport

(Will)

133

6/24/87

 Chicago

 Taft High

School

(Cook)

125

6/24/87

 Deerfield,

(Lake)

177

6/24/6~/

Evanston,

(Cook)

127

6/24/87

 Libertyville,

IL

 (Lake)

173

6/24/67

~aukegan,

IL

 (Lake)

162

6/24/67

 Peoria Heights, IL

 (Peoria)

126

79-295

‘-~

 EX(tR~

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OZONE

AAQS

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 (J;ONE

 Ex(:(:Ps1o~

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value

 125)

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6/22/87

FOR FURIHER

 I NFO1~!’1ATJ

CONrACT

 )30B

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‘/~

41 *4*4*

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F\CUF?S iONS

I°AO

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*****I******,

1**

LOCATION

Apr

18,

1987

 Lisle

 139 ppb

 *i~tExrnrsion

Jun 1~,

19~

7

 Chicago

Edg~ater

 156 pph

 list Fx~’urs~r’n

Jun

13,

1987

Chicago

—

SWFP

135

ppb

 list Excursion

Jun

 l~4, 1987

 Chicago

 Taft

HS

138

ppb

 list Excursion

Jun

13,

1987

 1)eerfield

 130 pph

 *1st Excursion

Jun

13,

1987

 Waukegan

 126 ppb

 *1st Excursion

J~n14,

1987

 Chicago

Edgewater

14U

pph

*t2nd

 Excursion

Jun

14,

1987

 Chicago

—

SE

Police

 144 pph

 *1st F:xcursion

Jun

14,

3987

Chicago

 SWFP

 135 ppb

 **2nd Excursion

Jun

13,

1987

 Evanston

 141 ppb

 list

 Excursion

Jun

14,

1987

 Waukegan

 140 ppb

 **2nd Excursion

Jun

16,

1987

 S~at.er1oo

 1~ ppb

 *1st Excursion

Jun

17,

1987

 Cary

129

pph

 *1st.

Excursion

Jun

17,

1987

Des

 Plaines

 127 ppb

 *1st Excursion

J~

 ;7, 1~7

:\a~tc~

 ~22 pph

 2nc3

F~ic~i~i

Jun

18,

1987

 (2aluric’t

City

 1:49 ppb

1st

 Excursioi

Jun

18,

1987

 Chicago

 Edgewater

 162 ppb

*1*3rd

Excur’3inn

Jun

18,

1987

 Chicago

—

 Po’ice

 165 pph

 4*2nd

 ExcurF.ion

Jun

18,

 1YFT

 Chicago

 Taft

HS

148

ppb

 4*2nd

 Excursion

Jun

18,

1q87

 Cicero

146

pph

 *1st Excursion

Jun

18,

1987

 Deerfie1~i

150

pph

 *2nd

 Excursion

Jun

18,

1987

 Des Na

i

nos

1

2~4

pph

*2ttr4

Excursi

.Jun

18,

 19~7

 Evanston

 139 ppb

 14*3rd

 E’:curElnn

Jun

18,

1987

 Libert y’.il

le

164

pph

1~t Excursion

Jun

12,

1957

 WauLogan

178

pph

 *1*3rd Exrurs~on

Jun

19,

1987

 Fvanston

 13:4 ppb

 1*4*4th

 1-xcursion

Jun

19,

1987

 Liberty’~ilIr

134

pph

 1*2nd

 Excursion

Jun

19,

1987

 ~nnuk~n

141

ppb

 *14*4th

 ixcurFinri

Jun

~Q,

1987

 Uhioago

—

 laft

115

 1~9 pph

 **13rd

 E-~:cursjcn

May

19,

1987

 F.di~ard~vile

 121 pph

Jun 1~, 1987

Champn~n

12:~

ppl-~

Jun i~, 1987

 Peoria

122

pph

.Jun

15,

1987

 Ch~cagn

—

 Pump

121

ppb

Jun

19,

1987

 Cary

124

ppl

OZONE

ADVISORiES

ISSUED

Jun

13,

1987

Chicago

 Northside

 3pm CDT

 Chicago

 Taf’t. 13~ pph

Jun

13,

1987

 Chicago

 Snuthside

 3pm CDr

 Chicago

—

 SWFP

126

ppb

Jun

13,

1987

 Lake

County

3pm

CDT

 Deerfield

 131)

 ppl)

Jun

17,

1987

Chi

~go—West

South

2pm

t’iyr

 Cary

129

ppl

Jun

17,

1987

 Chicago

—

 Northside

5pm

CDT

 J~vanston

 126 ppb

79-296