ILLINOIS POLLUTION CONTROL BOARD

October

15,

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.

SECOND 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

Ill.

Adrn. 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 June

22,

1987 and the Board was informed of

concurrence

in that decision by the Economic and Technical

Advisory Committee on June

26,

1987.

On July 16,

1987,

the Board proposed regulatory amendments

to 35 Ill. Adm.

Code

211 and 215 for

first notice.

On August

16,

1987,

the Board adopted

an order

(1) changing the section numbers

proposed

in

the July

16 Order

to correspond

to the Subpart V

designation and

(2) noting that the definition proposed

for

“volatile organic material”

is the subject of

a concurrent Board

proceeding,

R86—37, and appears

in the

first notice order

for

purposes of notice only.

The proposed amendments

were published

at 11

Ill.

Reg.

13173 and 13293 on August

14, 1987.

The

statutory 45—day comment period ended on September

28,

1987.

Non—substantive comments were received from the Secretary of

State’s Administrative Code Unit regarding

form and format of the

proposed rules.

Those changes have been made at second notice.

The only comment received during

the 45—day comment period was

from the Stepan Company.

The Illinois Environmental Protection

Agency (Agency) had previously filed comments on April

15,

1987.

VENT

COVERAGE

Stepan’s comments expressed

its continued concern that the

regulations as proposed improperly expand

the coverage over

that

assumed

in the Control Techniques Guidelines

(CTG).

In

82—377

---

particular, Stepan requested

that

the Board

reconsider the

comments submitted on June

18,

1987 regarding the

definition of

process vent stream.

Stepan also argued that the definition

is

unclear

and

subject

to

a wide variation of interpretation by

Agency

personnel.

Finally,

Stepan argued that the definition

should exclude storage

tanks and material handling equipment.

The Board

is not persuaded

to alter

the definition of

process vent stream.

The Board believes that the language of the

definition

is sufficiently clear

for

the Agency and the regulated

community to determine what types of emission streams are

covered.

Further, the Board continues

to believe

that the scope,

i.e. the inclusion of all streams,

is reasonable.

REFERENCE METHOD 18

In response

to Board request, Stepan commented that the

Total Resource Effectiveness Index

(TRE)

in Appendix

E of Part

215 does not take

into account the costs associated

with

sampling.

Stepan suggested that language be added

to provide

a

flexible alternative

for facilities.

Stepan offered the

following language:

2)

D)

A

method

using

engineering

techniques

demonstrated

by

the

applicant

to

be

equivalent

to

Reference

Methods

and

approved by the Agency.

The Board

is not persuaded

to amend Appendix

E as

suggested.

First, the language proposed by Stepan is

imprecise.

The record

is insufficient

for

the Board

to

adequately consider Stepan’s proposed language.

Second, although

the Board does not believe

that affected facilities should be

required

to use

a test method which is not useful under certain

circumstances, the Board does not believe

that this record

supports the inclusion of such

an alternative as

a general

rule.

The Board

can only note

that facilities unable

or

unwilling

to use the test methods provided can petition the Board

for relief.

VOM DEFINITION

The

Board

noted

in

its

August

6,

1987

Order

that

the

definition

of

volatile

organic

material

is

the

subject

of

a

concurrent Board proceeding,

R86—37,

and that the definition was

included in the R86—40 proposal

for purposes of providing

notice.

As R86—37

is devoted entirely to the amendment of that

definition, the Board deems

it appropriate

to remove the

definition

from further consideration

in this proceeding.

The

definition of volatile organic material

is therefore, not

included in the second notice order.

82—3 78

---

INCORPORATIONS

BY REFERENCE

Within the text of the proposed amendments certain materials

are incorporated by reference.

Language was added

to indicate

that these materials are incorporated by reference

in Section

215.105.

In addition, materials not previously incorporated and

appearing

in Section 215.105 have been added

to that section

pursuan~tto Section 6.02(a)

of the Illinois Administrative

Procedure Act and

1

Ill.

Adm. Code 220.760.

These are not

substantive changes, but are necessary for second notice review

by the Joint Committee on Administrative Rules

(JCAR).

The proposed text also utilizes certain abbreviations.

Those abbreviations have been added

to the list

in Section

215.103.

DEFINITIONS

In the first notice order, several definitions were proposed

to be added

to Section 211.122.

Most of

the proposed definitions

(“Flow”,

“Full Operating Flowrate”,

“Hourly Emissions”,

“Net

Heating Value”,

and “Process Vent Stream”)

included the language

“F~or the purposes

of Part

215,

Subpart V.”

So as not

to

unnecessarily burden the general definitions section, Section

211.122,

the Board has created

a definition

section within

Subpart V and has moved

all the definitions thereto.

The

definitions are now located

in proposed Section 215.521.

This is

not a substantive change.

Finally,

the Board

notes that it has made other non—

substantive changes throughout the text of the proposed

amendments.

The equations

in Appendix

E have been rewritten

for

ease

in typing and reproduction.

Also,

the tables in Appendix

F

have been reformatted.

ORDER

The following amendments to 35

Ill. Adm.

Code 211 and 215

are directed

to

the Joint Committee on Administrative Rules for

second notice review.

SUBPART A:

GENERAL PROVISIONS

Section 215.103

Abbreviations and Conversion Factors

a)

(Add

the following

to the list:)

gram

g/mole

grams per mole

kcal

kilocalorie

MJ

megajoules

scm

standard

cubic

meters

82—379

---

—4—

(Source:

Amended

at

11

Ill.

Reg.

effective

Section 215.105

Incorporations by Reference

The following materials are incorporated by reference:

a)

American Society for Testing

and Materials,

1916 Race

Street,

Philadelphia,

PA

19103:

ASTM Dl644—59 Method

A

ASTM Dl475—60

ASTM Dl946—67

(reaoproved 1977)

ASTM D2369—73

ASTM D2382—76

b)

Federal Standard l4la, Method 4082.

C)

National Fire Codes, National Fire Prevention

Association, Battery March

Park,

Quincy, Massachusetts

02269

(1979).

d)

United States Environmental Protection Agency,

Washington,

D.C.,

EPA—450/2—77—026,

Appendix

A.

e)

Code of

Federal Regulations:

40

CFR

60,

Appendix

A

(1986)

f)

This Part incorporates no

later editions or

amendments.

-~Bee~d

r~e~e~The

ece~re~en

~y

refe~e~ee

~~ed

~e~t’e

een~e~

ne ~e~er ~endmen~

e~

(Source:

Amended

at

11

Ill.

Reg.

effective

SUBPART V:

AIR OXIDATION PROCESSES

Section

215.520

Applicability

This Subpart applies to plants using

air oxidation processes

which are located

in any of the following counties:

Will,

McHenry, Cook, DuPage,

Lake,

Kane, Madison,

St. Clair, Macoupin

and Monroe.

(Source:

Added

at

11 Ill.

Reg.

effective

82—380

---

—5—

Section

215.

521

Definitions

In

addition

to

the

definitions

of

35

Ill.

Adm.

Code

211,

the

following

definitions

apply

to

this

Subpart:

“Air

Oxidation

Process”:

any

unit

process

including

ammoxidation

and

oxychlorination

which

uses

air

or

a

combination

of

air

and

oxygen

as

an

oxidant

in

combination

with

one

or

more

organic

reactants

to

produce

one

or

more

organic

compounds.

“Cost

Effectiveness”:

the

annual

ex~ense for

cost

of

control

of

a

given

process

stream

divided

by

the

reduction

in emissions of organic material

of

that

stream.

“Flow

(F)”:

Vent

stream

flowrate

(scm/mm)

at

a

standard

temperature

of

20

C.

“Full Operating Flowrate”:

Maximum operating capacity

of the facility.

“Hourly Emissions

CE)”:

Hourly emissions reported

in

kg/hr measured

at

full operating

flowrate.

“Net Heating Value

(H)”:

Vent

stream

net

heating

value

(MJ/scm), where

the net enthalpy 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.”

“Process Vent Stream”:

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

this Subpart and

Appendices

E and

F.

(Source:

Added

at

11

Ill.

Reg.

effective

)

Section

215.525

Emission

Limitations

for

Air

Oxidation

Processes

a)

No

person

shall

cause

or

allow

the

emission

of

volatile

organic

material

(VOM)

from

any

process

vent

stream

unless the process vent stream

is vented

to a combustion

device which

is designed

and operated either:

8 2—38 1

---

—6—

b)

1)

To

reduce

the

volatile

organic

emissions

vented

to

it with an efficiency of at least ninety eight

percent

(98)

by

weight;

or

2)

To emit volatile

organic

material

at

a

concentration

less

than

twenty

parts

per

million

by

volume, dry basis.

c)

The limitations

of subsection

(a)

do not apply to any

process vent stream or combination of process vent

streams which has a Total Resource Effectiveness Index

(TRE) greater

than

1.0,

as determined

by the following

methods:

1)

If an air oxidation process has more

than one

process

vent

stream,

TRE

shall

be

based

upon

a

combination

of the process vent streams.

2)

TRE of

a process vent stream shall be determined

according

to the following

equation:

TRE

=

E~a

+

bF~

+

CF +dFH

+

e(FH)~

+

fF05

where:

n

=

0.88

TRE

=

Total

resource effectiveness index.

F

=

Vent

stream

flowrate

(scm/mm),

at

a

standard

temperature of

20

C.

E

Hourly

measured

emissions

in

kg/hr.

H

=

Net

heating

value

of

the

vent

stream

(MJ/scm),

where

the

net

enthalpy

per

mole

of

offgas

is

based

on

combustion

at

25

C

and

760

mm

Hg,

Air oxidation facilities for which an existing

combustion

device

is

employed

to

control

process

VOM

emissions are not required

to meet the 98 percent

emissions limit

until

the combustion device

is replaced

for other reasons.

The combustion device

is considered

to

be

replaced

when:

1)

All

of

the

device

is

replaced;

or

2)

When

the

cost

of

the

repair

of

the

device

or

the

cost

of

replacement

of

part

of

the

device

exceeds

50

of

the

cost

of replacing the entire device with

a device which complies.

82—382

---

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 obtained by use of

Appendix

F.

3)

For nonchlorinated process vent streams,

if the net

heating value,

H,

is greater

than 3.6 MJ/scm,

F

shall

be replaced by

F’

for purposes of calculating

TRE.

F’

is computed

as follows:

F’

=

FH

/

3.6

where

F

and

H

are

as

defined

in

subsection

(c)(2).

4)

The

actual

numerical

values

used

in

the

equation

described

in

subsection

(c)(2)

shall

be

determined

as

follows:

A)

All

reference methods and procedures

for

determining

the flow,

(F),

hourly emissions,

(E), and net heating,

(H), value shall

be

in

accordance with Appendix

E.

B)

All coefficients described

in subsection

(c)(2)

shall

be

in accordance with Appendix

F.

(Source:

Added

at

11

Ill.

Reg.

effective

Section 215.526

Testing and Monitoring

a)

Upon request

by the Agency,

the owner

or operator of an

air oxidation process shall

demonstrate compliance with

this Subpart by use

of the methods specified

in Appendix

E.

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.

(Source:

Added

at 11

Ill.

Reg.

effective

Section 215.527

Compliance Date

82—383

---

—8—

Each owner

or operator of

an emission source subject to this

Subpart

shall comply with the standards and limitations of this

Subpart by December 31,

1987.

(Source:

Added

at

11

Ill.

Reg.

effective

)

Appendix

E Reference Methods and Procedures

Introduction

This Appendix presents the reference methods

and procedures

required for implementing

Reasonably Available Control

Technology

(RACT).

Methods and procedures are identified

for two types of

RACT implementation:

a)

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

b)

Determination of offgas flowrate, hourly emissions and

stream net heating value

for calculating TRE.

All reference methods identified

in

this Appendix refer

to the

reference methods specified

at

40 CFR

60, Appendix

A,

incorporated by reference

in Section 215.105

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.

a)

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.

b)

Reference Methods

2,

2A,

2C or 2D as appropriate,

for

determination of

the volumetric flowrate.

c)

Reference Method

3 to measure oxygen concentration

of

the air dilution correction.

The emission sample shall

be corrected

to

3 percent oxygen.

d)

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.

82—384

---

—9—

TRE DETERMINATION

The

following

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.

a)

Reference Method

1 or

1A,

as appropriate,

for selection

of

the sampling site.

The sampling site for the vent

stream flowrate and molar composition determination

prescribed

in

(b)

and

(c) 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 of 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 parameters

for

determining 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

process as defined

in

35 Iii.

Adm.

Code 211.122,

such

equipment shall

be bypassed by the vent stream while the

vent stream

is sampled, but shall

not be bypassed during

the measurement of the

initial value of the monitored

parameters

for determining compliance with Subpart

V.

b)

The molar

composition of the vent stream shall

be

determined

using

the following methods:

1)

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.

2)

ASTM D1946—67

(reapproved 1977),

incorporated

by

reference

in

Section

215.105,

to

measure

the

concentration

of

carbon

monoxide

and

hydrogen.

3)

Reference

Method

4

to

measure

the

content

of

water

vapor,

if

necessary.

c)

The

volumetric

flowrate shall

be determined

using

Reference

Method

2,

2A,

2C

or

2D,

as

appropriate.

82—385

---

—ID-

d)

The net heating value of the vent stream shall

be

calculated

using

the following equation:

H

=

K

CiHi

i=1

Where:

H

=

Net heating value

of the sample, MJ/scm, where

the net enthalpy 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

F

(vent stream flowrate)

below.

K

=

Constant,

1.740

x

l0~

(1/ppm)

(mole/scm) (MJ/kcal) where standard temperature

for mole/scm

is

20

C.

Ci

=

Concentration

of sample component

i, reported

on

a wet basis,

in ppm,

as measured by

Reference Method

18

or ASTM Dl946—67

(reapproved 1977),

incorporated by reference

in Section 215.105.

Hi

=

Net heat

of combustion of sample component

i,

kcal/mole based

on combustion

at 25

C and 760

mm Hg.

If published values are not available

or cannot be calculated,

the heats

of

combustion of vent stream components

are

required

to be determined

using ASTM D2382—76,

incorporated by reference

in Section 215.105.

e)

The emission rate

of total organic compounds

in the

process vent stream shall

be calculated using

the

following equation:

n

E

=

K’F ~

CiMi

i=l

Where:

E

=

Emission rate

of total organic compounds

(minus

methane

and

ethane)

in

the

sample

in

kg/hr.

K’

=

Constant,

2.494

x

10—6

(1/ppm)

(mole/scm)

(kg/g)

(xnin/hr), where standard temperature

for

(mole/scm)

is

20

C.

82—386

---

—11—

Mi

=

Molecular weight of sample component

i

(g/mole).

F

=

Vent stream flowrate (scm/mm),

at

a standard

temperature

of

20

C.

f)

The

total

vent

stream

concentration

(by

volume)

of

compounds

containing

halogens

(ppmnv,

by

compound)

shall

be

summed

from the individual concentrations

of

compounds containing halogens which were measured by

Reference Method 18.

(Source:

Added

at

11

111.

Req.

effective

APPENDIX

F:

COEFFICIENTS FOR THE TOTAL RESOURCE EFFECTIVENESS

INDEX

(TRE)

EQUATION

This Appendix contains values for the total

resource

effectiveness index

(TRE)

equation

in Subpart V.

If

a flow rate

falls exactly on the boundary between the

indicated ranges,

the

operator

shall

use the row in which the

flow rate

is maximum.

COEFFICIENTS FOR TRE EQUATION

FOR

CHLORINATED

PROCESS

VENT

STREAMS

WITH

NET

HEATING VALUE LESS THAN OR EQUAL TO 3.5 MJ/scm

FL~

RATE

(sc~/min)

Mm.

Max.

a

b

C

d

e

f

0.0

13.5

48.73

0.

0.404

—0.1632

0.

0.

13.5

700.

42.35

0.624

0.404

—0.1632

0.

0.0245

700.

1400.

84.38

0.678

0.404

—0.1632

0.

0.0346

1400.

2100.

126.41

0.712

0.404

—0.1632

0.

0.0424

2100.

2800.

168.44

0.747

0.404

—0.1632

0.

0.0490

2800.

3500.

210.47

0.758

0.404

—0.1632

~5

0.0548

82—387

---

—12—

COEFFICIENTS

FOR

TRE

EQUATION

FOR

CHWRINkTED

PRCXESS

VENT

STREAMS

WITH

NET

HEATING

VALUE

GREATER

THAN

3.5

MJ/scm

FTJ~7

RATE

(sctV’min)

Mm.

Max.

a

b

C

d

e

f

0.

13.5

47.76

0.

—0.292

0.

0.

0.

13.5

700.

41.58

0.605

—0.292

0.

0.

0.0245

700.

1400.

82.84

0.658

—0.292

~

0.0346

1400.

2100.

123.10

0.691

—0.292

0.

0.0424

2100.

2800.

165.36

0.715

—0.292

0.

0.

0.0490

2800.

3500.

206.62

0.734

—0.292

0.

0.

0.0548

COEFFICIENTS

FOR

TRE

EQUATIQ~

FOR

NONCHWRIF~TEDPRCXESS

VENT

STREAMS

WITH

NET

HEATING

VALUE

LESS

THAN

OR

EQUAL

~

0.48

MJ/scnrt

FLL~RATE

(sciVmin)

Mm.

Max.

a

b

c

d

e

f

0.

13.5

19.05

0.

0.113

—0.214

0.

0.

13.5

1350.

16.61

0.239

0.113

—0.214

0.0245

1350.

2700.

32.91

0.260

0.113

—0.214

0.

0.0346

2700.

4050.

49.21

0.273

0.113

—0.214

0.

0.0424

COEFFICIENTE

FOR

TRE

EQUATIC~

FOR

NOt~CHLORINTED PR(XESS

VENT

STREAMS

WITH

NET

HEATING

VALUE

GREATER

THAN

0.48

AND

LESS

THAN

OR

EQUAL

‘10

1.9

MJ/sc’n

FL~ RATE

(scnVmin)

Mm.

Max.

a

b

c

d

e

f

0.

13.5

19.74

0.

0.400

—0.202

0.

0.

13.5

1350.

18.30

0.138

0.400

—0.202

0.

0.0245

1350.

2700.

36.28

0.150

0.400

—0.202

0.

0.0346

2700.

4050.

54.26

0.158

0.400

—0.202

5

0.0424

82— 388

---

—13—

COEFFICIENTS

FOR

THE

EQUATION

FOR

~3~HWRINATED

PROESS

VENT

STREAMS

WITH

NET

HEATING

VALUE

GREATER

THAN

1.9

AND

LESS

THAN

OR

EQUAL

‘10

3.6

MJ/scm

FL~

RATE

(scm/mm)

Mm.

Max.

a

b

C

d

e

f

0.

13.5

15.24

0.

0.033

0.

0.

0.

13.5

1190.

13.63

0.157

0.033

5T

0.

0.0245

1190.

2380.

26.95

0.171

0.033

0.

0.

0.0346

2380.

3570.

40.27

0.179

0.033

0.

0.

0.0424

COEFFICIENTS

FOR

THE

EQUATI~

FOR

NONO~WRfl~TED

PRCXESS

VENT

STREAMS

WITH

NET

HEATING

VALUE

GREATER

THAN

3.6

MJ/scm

FL~ RATE

(sciVmin)

Mmn.

Max.

a

b

c

d

e

f

0.

13.5

15.24

0.

0.

0.0090

0.

0.

13.5

1190.

13.63

0

0.0090

0.0503

0.0245

1190.

2380.

26.95

5

0.0090

0.0546

0.0346

2380.

3570.

40.27

T5T

0.0090

0.0573 0.0424

(Source:

Added

at

11

Ill.

Reg.

,

effective

IT

IS SO ORDERED.

I,

Dorothy

M.

Gunn, Clerk

of the

Illinois

Pollution

Control

Board,

hereby

certify

that

the

above

Propos~5

0

inion

and

Order

was

adopted

on

the

______________

day

of

~

~

,

1987

by

a

vote of

~~~—()

~

£~

Dorothy

M.

,~unn,

Clerk

Illinois

Pollution

Control

Board

82—389