ILLINOIS POLLUTION CONTROL BOARD
September 26,
1991
IN THE MATTER OF:
)
PM-lO EMISSION LIMITS FOR THE
)
PORTLAND CEMENT MANUFACTURING
)
R9l-6
PLANT AND ASSOCIATED QUARRY
)
(Rulemaking)
OPERATIONS LOCATED SOUTH OF
)
THE ILLINOIS RIVER IN LASALLE
COUNTY, ILLINOIS.
ADOPTED RULE
FINAL NOTICE
OPINION AND ORDER OF THE BOARD by
(B. Forcade):
This matter comes before the Board on a regulatory proposal
filed on January
10, 1991 by the Illinois Environmental
Protection Agency
(“Agency”)
to establish the PM-b
emission
limits for the portland cement manufacturing plant and associated
quarry operations located in LaSalle County,
Illinois.
The
proposed regulations are applicable to a single facility owned
and operated by Lone Star Industries
in Oglesby, Illinois.
The
proposed regulatory changes would amend 35
Ill. Adm.
Code
212,
Visible and Particulate Matter Emissions,
35 Ill.
Adm.
Code
212.110, 212.423, and 212.424, and Part 211, Definitions General
Provisions,
35 Ill.
Adm.
Code 211.122.
The Agency has certified,
and the United States
Environmental Protection Agency
(“USEPAtt)
has confirmed and
certified,
that the proposed rule is a federally required rule as
defined in Section 28.2(a)
of the Illinois Environmental
Protection Act (“Act”).
Section 28.2 was amended by P.A.
86-
1409,
effective January
1,
1991,
requiring the Board to accept or
reject an Agency certification within 45 days.
The Board
accepted the certification on February
7,
1991.
On February 28,
1991 the Board determined that an Economic Impact Study
was
not
necessary and adopted the First Notice Opinion and Order
in this
proceeding.
The Board wishes to acknowledge the contributions of attorney
Margaret Dolan Fuss who acted as Hearing Officer and assisted in
preparation of the First Notice Opinion and Order during the
course of her former employment at the Board; of staff attorney
Marie Tipsord who assisted in the drafting of the Second Notice
and Final Opinion and Order in this matter; and the contributions
of Dr. Harish Rao who provided technical assistance.
126—39 1
2
The First Notice appeared in the Illinois Register on March
29,
1991.
15 Ill.
Reg.
4668 and 4573.
On April
17,
1991,
a
public hearing was held in Chicago,
Illinois and on April
19,
1991,
a second public hearing was held in Oglesby,
Illinois.
On August 22,
1991,
the Board voted to send the proposal to
Second Notice.
During the Second Notice period the Joint
Committee on Administrative Rules
(“JCAR”) suggested and the
Board agreed to make some minor non—substantive changes to the
rule.
The changes were of a grammatical nature and do not affect
the meaning of the proposal.
On September 17,
1991,
JCAR issued
a Certification of No Objection to this proposal.
BACKGROUND
USEPA established the National Ambient Air Quality Standards
(“NAAQS”)
for PM—b
in 1987.
The 24—hour PM-lU standard is 150
ug/m3 and the annual PM—b
standard is 50 ug/m3.
See 52 FR 24634
(July
1,
1987).
These standards were authorized pursuant to
Sections 108 and 109 of the Clean Air Act,
42 U.S.C.
7408,
7409.
Section 110 of the Clean Air Act requires that a state have an
approved State Implementation Plan
(“SIP”)
to achieve federal air
quality standards.
42 U.S.C.
7410.
The 1990 Clean Air Act
Amendments require submission of
a PM-b
SIP by Illinois by
November
15,
1991.
The proposed rule before the Board is
intended to satisfy
the federal requirements for an approveable PM-b
SIP for the
Oglesby, Illinois area,
which area is designated as a “moderate”
or Group II nonattaininentt area, based on past air quality
violation.
See 55 FR 45799.
On May
16,
1990, the USEPA directed
that the Oglesby area
in LaSalle County also be subject to a
Group
I analysis.
55 FR 20265.
A Group
I area for PM-b
is so
designated by USEPA if that area has a 95
or greater probability
of not attaining the PM-lU NAAQS.
The Board notes that on August
8,
1991,
the USEPA published
a list of nonattainmentt areas for
PM-b.
The list included Oglesby, with the following comments:
The Governor of Illinois submitted
information to EPA requesting that an
additional section be added to that portion
of Oglesby designated nonattainmentt for PM-
10 Consistent with the definition of
nonattainmentt area in section
107d)1)AJi),
EPA has added the section
and announces that the Oglesby PM-lU
nonattainmentt area
is as described in Table
I.
In the January 28,
1991 correspondence to the
126—392
3
Governor of Illinois, the Regional
Administrator of EPA Region V had initiated
the process to redesignate as nonattainmentt
this portion of LaSalle County.
That process
has been mooted by the action announced
in
today’s notice.
(56 FR 37662)
As previously stated, these proposed regulations are
applicable to
a single facility owned and operated by Lone Star
Industries
in Oglesby, Illinois.
Lone Star operates a Portland
Cement m’anufacturing plant.
Mr. John Krolak,
a field engineer
testified as to the process used by Lone Star.
(Tr.
1 pp. 80-
81).
Portland Cement is a material which
is mixed with sand or
gravel and water to make concrete.
Portland cement is produced
by burning a finely ground mix’ture of limestone and shale to the
fusion point and then grinding the resulting clinker with a small
percentage
of gypsum.
Limestone and shale are obtained from
a quarry known as the
Lehigh quarry owned by Lone Star in Deer Park Township, LaSalle
County,
located adjacent to the northern boundary of Oglesby.
The quarrying operation begins with the clearing of the
land.
Unused band
is farmed.
Lone Star presently has contracts with
another company specializing
in earth moving to carry out the
clearing or stripping operations.
Heavy equipment is used to
remove the top soil and subsoibs; these are used or set aside for
later reclamation work.
The shale is set aside for use
in the
process.
Stripping continues until the usable limestone bedrock
is exposed.
As limestone
is needed,
a group of 6—inch diameter holes are
drilled into the stone to a depth of about 30 feet
in an area
adjacent to the working face
(where rock has previously been
removed), explosive charges are set
in the holes and detonated to
fracture and dislodge about 8,000 tons of rock.
According to Mr. Chris Romaine, Manager of the New Source
Review Unit with the Agency, Lone Star has undertaken a full
scale modernization program in an attempt to comply with this
proposed regulation.
Changes at the facility include raising
stack heights and “replacement of the raw mill department,
installation of new feed for the kiln,
and replacement of the
separator in the finish department”
(Tr.2
p.
32).
DISCUSSION
In the Board’s First Notice Opinion and Order
(February 28,
1991),
the Board made a number of non-substantive changes
in
preparation for review of the proposed rule by the Administrative
Code Division of the Secretary of State’s Office and by JCAR.
The Board made particular efforts to clarify any references to
applicable standards
or limitations to satisfy JCAR concerns for
126—393
4
specificity and to use a format for incorporation by reference
which JCAR recently approved in R87-3l.
The Board attempted to
preserve the intent of the Agency’s proposal while anticipating
probable revisions that could otherwise pose delays
in adopting
the final rule well
in advance of the Agency’s November 1991
deadline.
In addition, the Board changed certain terminology and
sections were reorganized at First Notice.
The Agency proposed
Section 212.108, Test Methods for PM-lU Emissions, but the Board
instead proposed amendment to the current Section 212.110,
Measurement Methods,
as a preferred long—term organizational
structure.
Similarly,
the Board repositioned the tests proposed
by the Agency for placement in Section 212.423(f)
to Section
212.110.
Also at First Notice, the Board deleted references to
“fugitive dust”
as this term is not defined in Part 211,
and
instead used the term “particulate matter”, which is found
in
Part 211.
Revisions were also made to clarify the sections on
recordkeeping and reporting.
The Board also asked that the participants comment on
specific language in the Agency’s proposal.
The Board asked that
the participants discuss the following:
1)
The reference in Section 212.110(i)
to USEPA’s
continuing,
independent authority.
2)
The reference in Section 212.424(b)
to Subpart K of
this Part.
3)
The sentence in Section 212.424(e) (5) which states,
“This report shall include those times when subsection
(e)
of this Section is involved.”
4)
The reference in Section 212.423(a)
to the
applicability of Sections 212.321 and 212.322 and the
impact these sections may have on the requirement of no
visible emissions found
in Section 212.423(c)
5)
The reference in Section 212.423(a)
to the
applicability of Section 201.149.
At the hearings held during the First Notice period,
the
Agency presented testimony by several of the Agency’s experts
in
support of the Agency’s proposal.
Mr. Dave Kolaz, Manager of the
Air Systems Management Section for the Division of Air Pollution
Control, described the PM-b
monitoring which was conducted in
Oglesby.
The actual monitoring point was located in Oglesby
north of the Lone Star facility.
The monitoring indicated that
126—394
5
the Oglesby area had exceeded the 24—hour standard numerous times
and the annual standard had been exceeded four times.
(Tr.
1 p.
29 and 39).
Mr. Kolaz testified that:
One technique that
is useful in the analysis
of particulate matter
is the generation of
a
wind direction frequency table or wind rose.
This establishes the frequency of time that
the wind blows from a particular set of
directions on days when particulate levels
are high.
(Tr.
1
p.
35).
Mr. Kolaz further testified that the data used in developing the
wind rose was obtained from an Agency monitoring site in Peoria
and the data indicated that the most frequent directions
associated with the high PM-lU values were from the sector to the
southwest.
(Tr.
1 p.
37-38).
Mr.
Kolaz also stated:
This type of analysis provides
a good
indication of the general geographical area
from which the high values are generated.
The sources of the high PM-b
are most likely
within the cross-hatched areas which includes
the Lone Star Industries’
facility,
located
approximately
.5 kilometers south-southwest
of the monitoring site.
The fact that light winds were associated
with the high PM-la
levels
is an indication
that wind-blown fugitive dust is not a major
contributor; however, mechanically—induced
fugitive emissions are a possible
contributor.
(Tr.
1 p.
38).
In studying the air quality in the Oglesby area, the Agency
used dispersion modeling in an effort to develop a control
strategy for achieving and maintaining PM-lU air quality
standards.
(P.C.
3
p.
4).
The Agency presented testimony from
Robert Kaleel and Jeffrey Sprague regarding the dispersion
modeling used in this proceeding.
According to Mr.
Sprague,
the
Agency’s modeling indicated that with the modernization program
and control technologies being added to the Lone Star facility,
the area would meet the ambient air quality standards for PM-lU.
(Tr.2
p.
155).
The Agency believed that the initial proposal submitted to
the Board was agreed to by Lone Star.
However,
at hearing, Lone
Star enunciated several concerns with the proposal.
126—395
6
Specifically, Lone Star questioned both the monitoring at the
Oglesby site and the modeling which took place to determine what
control strategies would be necessary to achieve compliance.
In
addition, Lone Star expressed concern and continues to be
concerned with Method 2U2, which the Agency is proposing for the
measurement of condensible PM-b,
would make it unlikely that
Lone Star could meet the PM-lU standards set forth in the
proposal.
Lone Star at hearing questioned the Agency’s witness
regardint~wind direction and the location of the monitoring
equipment.
Lone Star was concerned that other sources might also
contribute to the high PM-lU values recorded in Oglesby.
Lone
Star raised questions which were an attempt to elicit from the
Agency that another cement manufacturer in LaSalle County,
as
well as the nearby LaSalle County landfill, were also major
sources for PM-lU
in Oglesby.
Lone Star also raised specific questions with regard to the
modeling done by the Agency.
The first question raised was
whether the meteorological data from Peoria used in the modeling
was representative of the meteorological conditions in Oglesby.
(P.C.
3 p.
4).
The Agency states that:
The purpose of the modeling study performed
by the Agency is not to replicate the
conditions on a specific day or year.
Rather,
the objective is to evaluate the
ability of the emission limits proposed in
the regulations to protect the ambient
standards in future years under
meteorological conditions that are typical of
the area.
(P.C.
3
p.
5).
The Agency indicates that the weather conditions in Peoria
are similar to those occurring in Oglesby in that the mean annual
precipitation varies by less than two inches, temperatures vary
by less than
1 degree
F, and wind directions show little
variation.
(P.C.
3 p.
5).
Thus,
the use of the meteorological
data from Peoria
is appropriate.
Lone Star also raised the issue of the size of the modeling
domain and the emissions sources included in the analysis.
The
Agency points out that the air quality problem in Oglesby is of a
long standing nature and is not a problem evidenced in other
portions of LaSalle County.
(P.C.
3
p.
5—6).
The Agency
specifically referred to the absence of complaints by residents
who did not live in the Oglesby area as an indicator that the
remainder of the County does not have a significant PM-lU
problem.
Mr. Kolaz presented testimony which indicated that the Lone
126—396
7
Star facility is located such that the monitoring equipment
reflects Lone Star as the major contributor to the air quality
problem.
Further, Mr. Kaleel and Mr. Spragu~testified that
other possible contributors to the air quality for PM-lU were
considered when the modeling took place and included as
“background concentrations”.
(P.C.
3
p.
6).
The Agency stated:
Emissions from the Lone Star Cement Plant are
the primary reason that the particulate
matter air quality standards have been
violated every year since
1976, the year the
Agency first installed air quality samplers
in Oglesby.
Reasonable emission controls at
the Lone Star facility are necessary to
achieve attainment of the air quality
standards.
(P.C.
3
p.
6-7)
Therefore,
the Board feels that the monitoring and modeling
performed by the Agency appropriately considered other sources of
possible emissions.
Further, the Board believes that the record
clearly supports the Agency’s position that Lone Star is the
major contributor of PM-b
emissions
in Oglesby.
Lone Star near the close of the second hearing and in its
post—hearing comments raised two issues
in the proceeding.
With
regards to the first issue, Lone Star informed the Board and the
Agency at the April
19, 1991 hearing that there was a significant
issue remaining with regards to the proposal.
Lone Star has
serious concerns regarding measurement of condensible PM-b
using
the USEPA proposed test Method 202 for the measurement of PM-b.
Mr. Daniel Goodwin testified on behalf of Lone Star and stated
the following:
We do not know if the Lone Star process sources
can comply with the proposed emission limits
if
condensibles are included,
and the proposed test
method
2U2J
for condensibles is not suitable.
(Tr.2 p.
199).
Mr. Goodwin further testified that he had been in contact with
USEPA and that “significant changes in the test method are being
incorporated in response to the identified problems with ammonium
chloride and ammonium sulfate.”
(Tr.
2 p.
197).
The Agency, upon cross-examination,
elicited the fact that
Lone Star was aware that condensibles would be included
in the
measurement for PM-lU
(Tr.
2 p.
205).
Lone Star asked for
additional time to perform stack tests and measure the
condensible PM-lU levels at the facility.
126—3 97
8
After the hearings were concluded in this matter, the Agency
and Lone Star filed comments to further elaborate on points
raised at hearing.
The Agency stated in its post-hearing
comments that it “recognizes the necessity of further addressing
the measurement of condensible PM-lU”.
(P.C.
3
p.
9).
The
Agency offered a resolution of the issue to the Board.
The
Agency recommends “excluding the clinker cooler and the finish
mill high efficiency air separator from the requirement of
testing with Method 202 while lowering the allowable limits
in
the Propbsed Rule to account for any possible condensible
emissions.”
(P.C.
3 p.
10).
The Agency further stated that the
“newly developed proposed language” allows Lone Star to exclude
anmionium chloride from the Method 202 measurement.
(P.C.
3
p.
10)
The Agency’s comments were received by the Board on July 25,
1991.
Lone Star submitted comments on July 26,
1991,
which
requests that the Board “defer final action with respect to
proposed Method 202 until the technical issues raised” are
resolved.
(P.C.
4
p.
2).
Lone Star included several supporting
documents detailing the technical issues with its comment.
In
addition, USEPA filed comments which state that “there
should
be some indication that Method 202
is the test method for
‘Condensible particulate matter’.”
(P.C.
5 p.2).
The second major issue raised by Lone Star in its post—
hearing comments is that Lone Star
is requesting
“a compliance
date of April
30,
1992 be included in the rube.”
(P.C.
4
p.
1—
3)
.
As this issue had not been discussed on the record and
further elaboration on Method 202 seemed appropriate, on July 30,
1991 the Hearing Officer asked for additional comments from the
participants elaborating on the issue of Method 202 and on the
issue of a later compliance date.
In addition, the Hearing
Officer asked for specific comments on certain suggested
language.
On August
19,
1991,
the Board received comments from the
Agency, USEPA,
and Lone Star addressing the issues raised by the
Hearing Officer Order of July 30,
1991.
With regards to the
issue of a later compliance date,
the Agency and USEPA agreed
that the date suggested by Lone Star was acceptable.
(P.C.
6
P.
2; P.C.
7
P.
2).
The USEPA indicated that compliance must be
achieved under the 1990 Clean Air Act Amendments by December 10,
1993; therefore, the later compliance date of April 30,
1992
is
acceptable.
(P.C.
7 P.
2).
Therefore,
the Board will add to the
rulemaking language indicating that the rule as it applies to
Lone Star will not be effective until April 30,
1992.
As to the issue of whether Method 202
is appropriate for
condensible PM-lU as opposed to condensible particles,
USEPA
states:
126—398
9
The Board questioned if Method 202
is an
appropriate method for measuring PM less than
10 microns alone
(without also measuring
other sizes).
The answer is yes.
All
condensible PM is considered to be PM less
than 10 microns.
(P.C.
7 P.
2).
The Agency states,
in part,
that:
“Method 202
.
.
.
is the
appropriate method for measuring condensible PM—b.
.
Furthermtre, there is no acceptable alternative test method for
measuring condensible PM-lU at this time.”
(P.C.
6
P.
2).
Further the Agency and the USEPA both attached a letter from
Candice Sorrell to Mr. Goodwin dated July 18,
1991, which states:
To summarize,
USEPA
believes that none of
the issues raised in your letter indicate
that Method 202 may not be appropriate for
Portland cement kilns or that the test data
collected a Lone Star are invalid.
(P.C.
6
Attachment
1;
P.C.
7 Attachment).
Lone Star continues to state that it “does not believe
USEPA’s proposed Method 202
is technically sound as a test method
for measuring condensible PM-lU from some categories of sources,
including those at Portland cement manufacturing plants.”
(P.C.
8
P.
7).
Lone Star asks that the Board either defer action on
Method 202 or incorporate by reference any future changes to
Method
202.
(P.C.
8
P.
8).
Lone Star’s concerns may or may not be valid; however, both
the Agency and USEPA have indicated that Method 202
is jj~test
method for measuring condensibbe PM-lU.
Additionally, USEPA has
stated in a letter to Lone Star that USEPA does not believe the
concerns enunciated by Lone Star are valid.
The Agency has
offered a compromise regarding Method 202 which
is acceptable to
USEPA.
Lone Star also agrees that the compromise would be
acceptable and would alleviate some of Lone Star’s concerns.
Therefore, the Board will adopt Method 202 by reference and will
add the additional language recommended by the Agency regarding
Method 202.
The Board notes that the Board cannot incorporate
future amendments to Method 2U2 under the Illinois Administrative
Procedure Act.
(Ill. Rev.
Stat.
1990 supp.,
ch.
127, par.
1006.02).
However,
after the USEPA has taken final action on
Method 202 Lone Star or the Agency could propose an amendment to
this rule to incorporate the new Method 202.
The Agency’s comments included several suggested language
changes to the proposal.
Except for issues outlined in the
foregoing discussion,
Lone Star agreed with the comments made by
the Agency.
Lone Star also requests that Section 212.424(c) (1)
be modified so that it shall not apply after the roadway is
126—399
10
paved.
(P.C.
4 p.
1-3).
In addition to the aforementioned comments,
the comments
filed by TJSEPA included the fo)bowing:
b.
The definition for “Condensible particulate
matter”
in Section 211.122 does not refer to
a test method in Section 212.110.
The phrase
“Condensible particulate matter”
is not
spelled out in Section 212.110.
There should
be some indication that Method 202
is the
test method for “Conclensible particulate
matter.”
*
*
*
3.
It is USEPA’s understanding that the unpaved
road,
where calcium chloride was going to be
used as
a dust suppressant,
is going to be
paved.
Paving the road is a more effective
control measure and could more easily
demonstrate a specific level of control
efficiency.
USEPA is concerned about the
control efficiency of calcium chloride as a
dust suppressant.
If the road remains
unpaved, than there needs to be some
justification for the control efficiency of
the calcium chloride.
*
*
*
5.
To reduce potential ambiguity,
we recommend
that Section 212.423(c)
state than “No person
shall cause or allow ~
visible
emissions...”.
6.
Section 212.110(d) must indicate that
40 CFR,
Appendix A, Method 22 will be used for both
stack emissions and fugitive emissions even
though Method 22 states that it
is not to be
used for stack emissions.
7.
As to Section 212.423(e) (2), the quarterly
reporting requirements for malfunctions are
vague.
Reporting should be required promptly
following the start of the malfunction.
*
*
*
(P.C.
5 p.2)
126—400
11
The Hearing Officer’s July 30,
1991 Order also asked that the
participants comment on the use of Method
22 for stack emissions.
All of the comments received on August
19,
1991 indicate that
Method 22 is appropriate for the visual determination of stack
emissions when the standard for such emissions
is
“no visible
emissions”.
(P.C.
6 P.4;
P.C.
7
P. 2~P.C.
8,
P.
2).
The last issue which the participants have not agreed on
relates to reporting of malfunctions of the pollution control
equipment.
The Board proposal, as sent to First Notice by the
Board, r~quiresthat the owner or operator deliver quarterly
reports on malfunctions.
Lone Star objected to quarterly reports
and the Agency suggested annual reports as an alternative.
The
Hearing Officer Order of July 30, 1991,
asked that the
participants provide justification for not requiring prompt
reporting.
The Agency responded that permit conditions of the
Agency require prompt reporting of malfunctions and therefore,
annual reporting would be sufficient.
(P.C.
6
P.
6).
Lone Star
submitted information on the costs of quarterly reports and again
requested that the provision be deleted.
(P.C.
8
P.
5).
The
USEPA stated that its position is that there must be prompt
reporting following the start of a malfunction.
(P.C.
7 P.3).
The Agency has indicated that permit conditions will require
prompt reporting of malfunctions.
Further, under language
submitted in the initial proposal, Lone Star would be required to
prepare records documenting such malfunctions.
Lone Star has not
objected to any of these requirements.
Thus,
Lone Star’s
information regarding the costs of reporting would be necessary
expenses.
Submission of annual and even quarterly reports are not
unusual in Board regulations.
Therefore the Board will require
Lone Star to photocopy and mail these already prepared documents
to the Agency on a quarterly basis.
However, the Board does not
see a need for reports on malfunctions
if none occur.
Therefore,
the Board will amend the language in Section 212.423(e) (2)
to
mirror the original proposal filed with the Board.
In addition,
the Board will require the filing of one copy of the documents
during any quarter in which a malfunction occurs.
At Second Notice,
after consideration of the comments
received and based on the prior discussion,
the Board amended the
proposal to incorporate certain of the language changes suggested
by the participants.
A break down of the specific language
changes made in the proposal for Second Notice are as follows.
Section 212.110(a) by deleting the American Society of
Mechanical Engineers (ASME)
Power Test Code and replacing it with
a reference to
40 C.F.R.
60 Appendix A Method
5.
Section 212.110(d) will be amended to make clear that Test
126—401
12
Method 22 is to be used for both stack and fugitive emissions
testing.
Section 212.110(e)
delete all references to Method 202 and
create a new subsection
(f)
incorporating Method 202.
Section 212.110(f) will be relettered
(g)
and last line will
be changed to allow for an agreed alternative time for submittal
of test results.
Section 212.110(g) and
(h) will be relettered
(h)
and
(i)
and minor changes added.
Section 212.110(1) will be relettered
(j)
and the words
“recordkeeping,
inspections,
monitoring,
and entry” will be
deleted.
Section 212.113 by deleting the reference to the ASME test
and adding Method 202.
Section 212.423(a)
and 212.424(a)
the last sentence will be
deleted and minor corrections made.
Section 212.423(b) will be amended so that the Clinker
Cooler and Finish Mill High Efficiency Air Separator are separate
from the Raw Mill Roller Mill and the Kiln.
Section 212.423(e) (2) the last sentence will be deleted and
a requirement for prompt reporting will be inserted.
Section 212.423(f)
will be amended to reflect the exclusion
of anunonium chloride from the measurement of condensibbe PM—la.
Section 212.424(c) (1)
a sentence reflecting that the section
will not apply
if the road is paved will be added.
Section 212.424(e) (2) (D),.(e) (2) (B)
and(e)(5)
will be amended
to read as in the Agency’s proposal.
Today,
the Board acts to adopt this proposal as the PM-b
standard for Oglesby, Illinois and the Lone Star plant.
The
Board will direct the Clerk to file this regulation with the
Administrative
Code Division of the Secretary of State’s Office.
126—402
13
ORDER
The Board hereby adopts the following amendments to 35
Ill.
~din.Code,
Subtitle B:
Air Pollution,
Chapter I, Pollution
Control Board,
Subchapter
C:
Emissions Standards and Limitations
for Stationary Sources Part 211, Section 211.122 and Part 212,
Sections 212.110,
212.423, and 212.424.
The Clerk of the Board
is directed to file these adopted amendments with the
Administlative Code Division of the Secretary of State’s Office.
126—403
14
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
SUBPART B:
DEFINITIONS
Section 211.122
Definitions
“Condensible PM-b”:
PM-b
formed
immediately
or
shortly after
discharge
to
the atmosphere,
as measured by the
applicable test
method
specified
in
35
Ill.
Adm.
Code
212.110.
Condensible
particulate matter exists
in gaseous
and/or vapor
form prior
to
release
to
the
atmosphere,
e.g.,
in
the
stack,
and
forms
particulate matter upon condensation when sub-lect to conditions of
cooling and dilution in the atmosphere.
“PM—lO”:
particulate matter with an aerodynamic diameter
less than or equal to a nominal
10 micrometers,
as measured by the
applicable test methods specified in 35 Ill. Mm.
Code 212.110.
“Portland Cement Manufacturing Process Emission Source”:
any items
of
process
equipment
or
manufacturing
processes
used
in
or
associated with the production of portland cement,
including, but
not limited
to,
a kiln,
clinker
cooler,
raw mill
system,
finish
mill
system,
raw material dryer,
material storage bin or system1
material conveyor belt or other transfer system, material conveyor
belt transfer point, bagging operation, bulk unloading station, or
bulk loading station.
“Portland Cement Process” or “Portland Cement Manufacturing
Plant”:
Any facility or plant manufacturing portland cement by
either the wet or dry process.
TITLE 35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
C:
EMISSION STANDARDS AND
LIMITATIONS FOR STATIONARY SOURCES
PART
212
VISIBLE AND PARTICULATE MATTER EMISSIONS
126—404
15
SUBPART Q:
STONE,
CLAY,
GLASS AND CONCRETE MANUFACTURING
212.423
Emission Limits for the Portland Cement Manufacturing
Plant Located in LaSalle County, South of the Illinois
River
212.424
Fugitive Particulate Matter Control for the
Portland
Cement
Manufacturing
Plant
and
Associated
Quarry Operations Located in LaSalbe County, South of
the Illinois River
SUBPART A:
GENERAL
Section 212.110
Measurement Methods
~j
Particulate Matter
Measurement.
Particulate matter
emissions from stationary emission sources subject to
this Part shall be conducted in accordance with 4U CFR
60 Appendix A Method
5 as incorporated by reference in
Section 212.113 determined by the procedures described
in the American Society of Mechanical Engineers Power
Test Code 27-1057
(Determining Dust Concentration
in
a
Gas Stream)
as revised from time to time,
or by any
other equivalent procedures approved by the Illinois
Environmental Protection Agency (Agency).
~j
Flow Rate and Gas Velocity Measurement.
The volumetric
flow
rate
and
gas
velocity
shall
be
determined
in
accordance with 40 CFR 60, Appendix A, Methods
1,
bA,
2,
2A,
2C,
2D,
3 and
4,
incorporated by reference
in
Section 212.113.
~j
Opacity Measurement.
Measurement of opacity shall be
conducted
in accordance with
40
CFR
6U,
Appendix
A,
Method
9 and 40 CFR 60.675(c)
and
(d), incorporated by
reference in Section 212.113.
Visible
Emissions
Measure.
Detection
of
visible
emissions
from
all
process
emission
sources
and
fugitive particulate matter emission sources required
to meet
a
“no visible
emissions”
standard shall
be
conducted in accordance with
40 CFR
60,
Appendix
A,
Method
22,
incorporated
by
reference
in
Section
212.113.
Test Methods for PM—lU Emissions.
Emissions of PM—lU
126—405
16
shall
be measured by any of the following methods
at
the option
of the
owner
or operator of
an emissions
source.
fl
40 CFR
51,
Appendix N, Method
201,
incorporated
by reference in Section 212.113.
2J.
40 CFR 51, Appendix M, Method 2U1A,
incorporated
by reference in Section 212.113.
~j
40 CFR 60, Appendix A, Method
5, incorporated by
reference
in Section
212.113, provided that all
Particulate Matter measured by Method
5 shall be
considered to be PM—lU.
Lfl
Test
Methods
for
Condensible
PM—lU
Emissions.
Emissions of condensible PM-lU shall be measured by 55
FR
41546
Method
202
incorporated
by
reference
in
Section 212.113.
g)
Upon a written notification by the Agency,
the owner
or operator of a PM—b
emission source subject to this
Part shall
conduct the applicable testing
for PM-lU
emissions,
condensible
PM—b
emissions,
opacity,
or
visible emissions
at
such
person’s
own
expense,
to
demonstrate
compliance.
Such
test results
shall
be
submitted to the Agency within
30 days of conducting
the test unless
an alternative time for submittal
is
agreed to by the Agency.
~fl
A
person
planning
to
conduct
testing
for
PM-lU
or
condensible PM-lU emissions to demonstrate compliance
shall give written notice to the Agency of that intent.
Such notification shall be given at least 30 days prior
to the
initiation of
the test unless
a shorter pre-
notification period is agreed to by the Agency.
Such
notification shall state the specific test methods from
this Section that will be used.
1)
The owner or operator of an emission source subject to
this Part shall retain records of all tests which are
performed.
These
records
shall
be retained
for
at
beast three years after the date a test is performed.
jj..
This Section
shall
not affect the authority
of
the
United
States
Environmental
Protection
Agency
under
Section 114 of the Clean Air Act
(42 U.S.C.A. par. 7401
et seq.
(1990)).
Section 212.111
Abbreviations and Units
126—406
17
a)
The following abbreviations are used in this Part:
btu
British
thermal
units
(60¼F)
dscf
dry standard cubic foot
ft
foot
fpm
feet per minute
gr
grains
gr/scf
grains per standard cubic foot
gr/dscf
grains per dry standard cubic foot
J
Joule
kg
kilogram
kg/MW-hr
kilograms
per
megawatt-hour
km
kilometer
1
liter
lbs
pounds
lbs/hr
pounds
per
hour
lbs/mmbtu
pounds
per
million
btu
m
meter
mph
miles
per
hour
mg
milligram
mg/scm
milligrams
per
standard
cubic
meter
mg/dscm
milligrams per dry standard cubic meter
mg/l
milligrams
per
biter
Mg
megagram, metric tone or tonne
mi
mile
mmbtu
million
British
thermal
units
mmbtu/hr
million
British
thermal
units
per
hour
NW
megawatt;
one
million
watts
MW-hr
megawatt-hour
ng
nanogram;
one
billionth
of
a
gram
ng/J
nonograms
per
Joule
scf
standard cubic foot
scfm
standard cubic feet per minute
scm
standard
cubic
meter
T
English
ton
b)
The
following
conversion
factors
have
been
used
in
this
Part:
English
Metric
2.205
lb
1
kg
1
T
0.907
Mg
1
lb/T
0.500
kg/Mg
mmbtu/hr
0.293
MW
1
lb/mmbtu
1.548
kg/MW-hr
or
430
ng/J
1
mi
1.61
km
1
gr
64.81
mg
1
gr/scf
2289
mg/scm
1
square
foot
0.0929
square
meter
1 foot
0.3048 m
126—407
18
Section 212.113
Incorporations by Reference
The
following materials
are
incorporated
by
reference.
These
incorporations do not include any later amendments or editions.
a)
ACME
Power
Tcst
Code
27
1057,
Determining
Dust
Concentration
in
a
Gas
Stream,
American
Society
of
Mechanical
Engineers,
United Engineering
Center,
345
E.
47th Street, New York,
NY
10017.
b~) Ringelmann Chart,
Information Circular
833
(Revision
of
IC7718),
Bureau
of
Mines,
U.S.
Department
of
Interior, Nay 1,
1967.
eb)
40
CFR
60,
Appendix
A
(1037)
(l99U)--:
fl
Method
1:
Sample.
and
Velocity
Traverses
for
Stationary Sources;.
~
Method
1A:
Sample
and Velocity
Traverses
for
Stationary Sources with Small Stacks or Ducts~
fl
Method
2:
Determination
of
Stack
Gas
Velocity
and Volumetric Flow Rate
(Type
S pitot tube)
4j
Method
2A:
Direct
Measurement
of
Gas
Volume
Through Pipes and Small Ducts
~J
Method
2C:
Determination
of
Stack
Gas
Velocity
and Volumetric Flow Rate in Small Stacks or Ducts
(Standard Pitot Tube)
~j
Method
2D:
Measurement
of Gas Volumetric
Flow
Rates
in Small Pipes and Ducts
21
Method
3:
Gas
Analysis
for
Carbon
Dioxide,
Oxygen,
Excess Air, and Dry Molecular Weight
~j.
Method
4:
Determination of Moisture Content
in
Stack Gases
.~j
Method 5:
Determination of Particulate Emissions
From Stationary Sources
J~Q1.
Method 9:
Visual Determination of the Opacity of
Emissions from Stationary Sources
~j
Method
22:
Visual
Determination
of
Fugitive
Emissions
from
Material
Sources
and
Smoke
Emissions from Flares.
126—408
19
C)
40
CFR 51 Appendix N
(1990):
~.j. Method 201:
Determination of PM—ba Emissions
~j
Method
2U1A:
Determination
of
PM-lU
Emissions
(Constant
Sampling
Rate Procedure).
40
CFR
60.672
(b),
(c),
(d)
and
(e)
(1990).
e)
40
CFR
60.675(c)
and
(d)
(1990).
~f)
ASAE
Standard
248.2,
Section
9,
Basis
for
Stating
Drying
Capacity
of
Batch
and
Continuous-Flow
Grain
Dryers,
American
Society
of
Agricultural
Engineers,
2950 Niles Road,
St. Joseph,
MI
49085.
eg)
U.S.
Sieve
Series,
ASTM-Ell,
American
Society
of
Testing Materials,
1916 Race
Street,
Philadelphia,
PA
19103.
inis
Part
.1ncorr~r~rates no
tur’cner
eaitions
or
~ m
~
ii
m~ n
h)
55
FR
41546,
(October
12,
1990),
Method
202:
Determination of Condensible Particulate Emissions from
Stationary Sources.
(Source:
Amended at
Ill.
Reg.
____,
effective
_____________)
SUBPART
Q:
STONE,
CLAY, GLASS AND CONCRETE MANUFACTURING
Section 212.423
Emission Limits for Portland Cement the
Manufacturing Plant
Located
in
LaSalle
County,
South of the Illinois River.
~j
Applicability.
This
Section
shall
apply
to
the
portland cement manufacturing plant in operation before
September
1,
1990 located in LaSalle County, south
of
the Illinois River.
This Section shall not alter the
applicability
of
Sections
212.321
and
212.322
to
portland
cement
manufacturing
processes
other
than
those for which alternate emission limits are specified
in
subsection
(b).
This
Section
shall
not
become
effective until April 30,
1992.
b
Prohibitions.
1 26—4U9
20
jj
No person shall cause or allow emissions of PM—b
to exceed the emission
limits set forth below for
each process.
PM—b
Emission Limits
Rate
Concentration
kg/hr
(bb/hr)
mg/scm
(gr/scf)
~
Clinker Cooler 4.67
(10.3)
28.147
(0.012)
~
Finish Mill
High Efficiency
Air Separator
2.68
(5.9)
26.087
(0.011)
21
No person shall
cause or allow emissions of PM-b
including condensible PM-lU
to exceed the emission
limits set forth below for each process.
PM-lU
Emission
Limits
Including Condensible PM-b
Rate
Concentration
kg/hr
(lbs/hr)
mg/scm
(gr/scf)
~
Raw Mill
Roller
Mill
(RMRM)
6.08
(13.4)
27.5
(0.012)
~
Kiln
without
RNRN
Operating
19.19
(42.3)
91.5
(0.U4U)
ç~
Kiln with
RNRN
11.43
(25.2)
89.2
(0.039)
,gj
No person shall cause or allow any visible emissions
from any portland cement manufacturing process emission
source not listed
in subsection
(b).
~j
Maintenance
and Repair.
The
owner
or operator
of any
process emission source subject to subsections
(b)
or
(c)
shall maintain and repair all air pollution control
equipment in
a manner that assures that the applicable
emission limits and standards in subsections
(b)
or
Cc)
shall
be met
at
all
times.
Proper maintenance shall
include at least the following requirements:
fl
Visual
inspections
of
air
pollution
control
126—4 10
21
equipment shall be conducted:
21
An
adequate
inventory
of
spare
Parts
shall
be
maintained:
fl
Prompt
and
immediate repairs
shall
be made
upon
identification of the need:
j)
Written records
of
inventory and documentation
of
inspections,
maintenance,
and repairs
of
all
air
pollution
control
equipment
shall
be
kept
in
accordance with subsection
Ce).
~j
Recordkeeping of Maintenance and Repair.
fl
Written
records
shall
be
kept
documenting
inspections,
maintenance1
and repairs
of
all
air
pollution
control
equipment.
All
such
records
required
under
this
Section
shall
be
kept
and
maintained for at beast three
(3)
years,
shall
be
available for inspection by the Agency,
and, upon
request,
shall
be
copied and
furnished to
Agency
representatives during working hours.
21
The
owner
or
operator
shall
document any
period
during
which
any process
emission
source
was
in
operation when the air pollution control equipment
was not in operation or was not operating properly.
These records shall include documentation of causes
for pollution control equipment not operating or not
operating properly, and shall state what corrective
actions were taken and what repairs were made.
In
any guarter during which such
a malfunction should
occur, the owner or operator shall mail one copy of
the documentation to the Agency.
~j
A written record of the inventory of all spare parts
not readily available from local suppliers shall be
kept and updated.
~j.
UPon written reguest by the
Agency,
the
owner
or
operator
shall
submit
any
information
required
pursuant
to
Subpart
0,
for
any
period
of
time
specified in the request.
Such information shall
be submitted within ten
(10) working days from the
date on which the request is received.
fl
Testing to determine compliance with the emission limits
specified for PM-lU, condensible PM-b1
and detection of
visible
emissions
shall
be
in
accordance
with
the
measurement methods specified in Section 212.110 (d),
(e),
and
(f).
Ammonium chloride shall be excluded from the
126—4 11
22
measurement of condensible PM-lU.
(Source:
Added at
—
Ill, Reg.
,
effective
___________
)
Section 212.424
Fugitive
Particulate Matter
Control
for
the
Portland
Cement
Manufacturing
Plant
and
Associated Quarry Operations Located in LaSalle
County,
South of the Illinois River.
,~J.
Applicability.
This section shall apply to the portland
cement manufacturing plant in operation before September
1,
1990
and
associated
quarry
operations
located
in
LaSalle County, south of the Illinois River.
Associated
quarry
operations
are
those
operations
involving
the
removal and disposal of overburden,
and the extraction,
crushing,
sizing,
and transport of
limestone and shale
for
usage
at the Portland cement manufacturing
plant.
This Section shall not become effective until April
30,
1992.
~j
Applicability of Subpart K of this
Part.
This Section
shall not alter the applicability of Subpart K:
Fugitive
Particulate Matter.
~j
Fugitive Particulate Matter Control Measures For Roadways
at the Plant.
fl
For
the
unpaved
access
roadway
to
the
Illinois
Central Silos Loadout,
the owner or operator shall
spray a 30 percent solution of calcium chloride once
every 16 weeks at an application rate of at least
1.58
liters
per
square
meter
(0.35
gallons
per
square yard) followed by weekly application of water
at
a rate of at least 1.58 liters per square meter
(0.35
gallons per square
yard).
This subsection
shall not apply after the roadway is paved.
21
The
owner
or
operator
of
the
Portland
cement
manufacturing plant shall keep written records
in
accordance with subsection
(e).
~j
Fugitive
Particulate
Matter
Control
Measures
for
Associated quarry Operations.
~j
For the primary crusher, the primary screen, the #3
conveyor from the primary screen to the surge pile,
and the surge pile feeders to the
#4 conveyor, the
owner or operator shall spray a chemical foam spray
of at least
1 percent solution of chemical foaming
agent
in water continuously during operations at
a
126—412
23
rate
of
at
beast
1.25
liters
per
megagram
(0.30
gallons per ton)
of rock processed.
21
The
owner
or
operator
shall
water
all
roadways
traveled by trucks to and from the primary crusher
in the process
of transporting raw limestone
and
shale
to the crusher at an application rate of at
least
0.50
liters per square meter
(0.10
gallons
per square yard)
applied once every eight hours of
operation
except
under
conditions
specified
in
subsection
(d) (3).
Watering shall begin within one
hour of commencement of truck traffic each day.
~j
Subsection
Cd) (2)
shall
be followed at
all
times
except under the following circumstances:
~j
Precipitation is occurring such that there are
no
visible
emissions
or
if
precipitation
occurred during the previous 2 hours such that
there are no visible emissions
~j
If the
ambient temperature
is
less
than
or
equal to 0°C(32°F);or
~j
If
ice
or
snow
build-up
has
occurred
on
roadways
such
that
there
are
no
visible
emissions.
j)
The
owner
or
operator
of
the
associated
quarry
operations shall keep written records in accordance
with subsection
(e).
~j
Recordkeeping and Reporting
1J
The
owner
or
operator
of
any
portland
cement
manufacturing
plant
and/or
associated
quarry
operations
subject
to
this
Section
shall
keep
written daily records relating to the application
of each of the fugitive particulate matter control
measures required by this Section.
21
The
records
required
under
this
Section
shall
include at beast the following:
~
the name and address of the ølant
~j.
the name and address of the owner or operator
of the plant and associated quarry operations
çj.
a map or diagram showing the location of all
fugitive particulate matter sources controlled
includingthe location, identification, length,,
12 6—4 13
24
and width of roadways
Qj
for each application of water or calcium
chloride
solution,
the
name
and
location
of
the
roadway
controlled,
the
water
capacity
of
each truck,
application rate
of each truck,
frequency of each application, width of each
application,
start
and
stop
time
of
each
~ppjjg~j~jgj~,
identification of each water truck
used,
total
quantity
of
water
or
calcium
chloride used for each application, including
the concentration of calcium chloride used for
each application
~
for
application
of
chemical
foam
spray
solution,
the application rate and frequency
of
application,
name
of
foaming
agent,
and
total quantity of solution used each day
fi
name and designation
of
the person
applying
control measures; and
~j
a
log recording all failures
to use control
measures
required
by
this
Section
with
a
statement
explaining
the
reasons
for
each
failure and,
in the case of a failure to comply
with
the
roadway
watering
requirements
of
subsection
(d) (2),
a record showing that one
of the circumstances for exceptions listed in
subsection
(d) (3) existed during the period of
the failure.
Such record shall
include,
for
example, the periods of time when the measured
temperature
was
less
than
or
equal
to 0°C
(32°F)
~j
Copies of all records required by this Section shall
be submitted to the Agency within ten
(10) working
days of
a written request by the Agency.
j)
The records required under
this Section
shall
be
kept and maintained
for at
least
three
(3)
years
and shall be available for inspection and copying
by Agency representatives during working hours.
~j
A quarterly report shall be submitted to the Agency
stating the following:
the dates required control
measures were not implemented, the required control
measures, the reasons that the control measures were
not implemented, and the corrective actions taken.
This
report
shall
include
those
times
when
subsection
(e)
is
involved.
This report shall
be
submitted to the Agency
30 calendar days from the
126—414
25
end of a quarter.
Quarters end March 31, June
3U,
September
30, and December 31.
(Source:
Added
at
Ill.
Reg.
____,
effective
_______________
IT
IS
SO
ORDERED.
Sections
29 and 41 of the Environmental Protection Act
(Ill.
Rev.
Stat.
1990 supp.,
ch.
111 1/2,
pars.
1029 and 1041)
provide
for appeal of Final Orders of the Board “within 35 days after entry
of
the order or other final action complained of”.
The Rules of
the Supreme Court of Illinois establish filing requirements.
I,
Dorothy N.
Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify that th
above Opinion and Order was adopted
on
the
~
day of
_________________,
1991,
by
a
vote
of
~.
Dorothy
M.
9~n,
Clerk
Illinois
Poa.2’ution
Control
Board
12 6—4 15
