BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF :
)
R06- 21
ORGANIC MATERIAL EMISSION )
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST )
AREAS : PROPOSED AMENDMENTS )
TO 35 ILL. ADM . CODE 218 AND 219 )
Dorothy Gunn, Clerk
Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(Via Facsimile & First Class Mail)
Mathew Dunn
Illinois Attorney General's Office
Environmental Control Division
James R. Thompson Center
100 West Randolph Street, 12" i Floor
Chicago, Illinois 60601
(Via First Class Mail)
Tim Lindsey
Waste Management and Research Center
One East Hazelwood Drive
Champaign, Illinois 61820
(Via First Class Mail)
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board
the Supplemental Testimony of Gary E . Beckstead,
Errata Sheet Number
2, and Supplemental Statement Number 2 on behalf of the
Illinois Environmental Protection Agency, copies of which are herewith served upon you
.
NOTICE
William Richardson, Chief Legal Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
(Via First Class Mail)
John Knittle
Illinois Pollution Control Board
2125 South First Street
Champaign, Illinois 61820
(Via First Class Mail)
(Rulemaking Air)
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
CLERKS OFFICE
MAY 1 2 2006
Pollution
STATE OF
Control
ILLINOISBoard
1
ILLIN ENV 0 E
AL PROTECTION AGENCY
By:
/-1 ~l/~ .
Annet C. Godiksen
Assistant Counsel
Division of Legal Counsel
Dated: May 10, 2006
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF :
)
R06- 21
(Rulemaking Air)
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST
)
AREAS
: PROPOSED AMENDMENTS )
TO 35 ILL. ADM . CODE 218 AND 219 )
PRE-FILED SUPPLEMENTAL TESTIMONY
OF GARY E. BECKSTEAD
The Illinois Environmental Protection Agency would like to provide responses to
questions raised during the April 19, 2006, hearing in the matter of "Organic Material
Emission Standards and Limitations for the Chicago and Metro East Areas : Proposed
Amendments to 35 Ill Adm Code 218 and 219" concerning the following issues :
IPCB Question :
1 . What are the advantages of aqueous-based cleaning systems compared to solvent-
based systems? Why would the Agency steer new sources to aqueous-based
systems?
Agency Response to Question #1 :
The Illinois EPA has no preference regarding the type of volatile organic material
(VOM) emission control systems that are used by sources that are impacted by the
proposed revisions
. The primary assessment standard for any chosen control
system is the amount of VOM emissions that the environment experiences and the
impact that these emissions have on air quality in the Chicago and Metro East
ozone nonattainment areas when compared to using a 1 .0 mmHg vapor pressure
(VP) solvent
. The four impacted sources are currently releasing fewer VOM
emissions to the environment than if the sources were using a 1 .0 mmHg solvent
and no controls, as shown in Table 3 of the TSD
. The controlled VOM emissions
from the cold cleaning operations for the four impacted sources are estimated to
be 0.114
tons per year greater if a 1 .0 mmHg VP solvent were used in their
processes without add-on controls .
1
RECEIVED
CLERK'S OFFICE
MAY
1 2 2006
STATE OF ILLINOIS
Pollution Control Board
Similarly, for any new source planning to install cold cleaning operations, the
Agency's assessment would be made not on the basis of whether an aqueous or
solvent-based cleaning system is employed but on the basis of the amount of
VOM emissions that would be emitted to the atmosphere as compared to that of
using a 1 .0 mmHg vapor pressure solvent and with the assurance that at least 95
percent overall capture and control of VOM emissions from the cold cleaning
operations would occur if an add-on control were employed in the emissions
control plan. In regards to approving the control plan or in issuing permits to
operate the chosen control plan, the Agency would not request or require sources
to demonstrate cost effectiveness via studies
.
Generally, aqueous-based systems are more environmentally friendly as they
generate fewer or no hazardous materials, are safer for the workers, and are
generally less costly to the company than solvent-based cleaning . However,
choosing solvent-based versus aqueous-based cold cleaning is a business decision
that the company makes . Based on information provided by the impacted sources
in this rulemaking, cost effectiveness for their control systems and using solvents
greater than 1 .0 mmHg is in the range of $115 to $562 per ton of VOM removed
(See Section 4 .0 Economic Reasonableness of the TSD) . This is even less than
the cost effectiveness range of $238 to $779 per ton that was estimated for the
material requirement of lowering the solvent vapor pressure down to 1 .0 mmHg.
With such a low cost effectiveness, it is my technical opinion that it would be
very difficult for conversion to an aqueous-based cleaning system to be more cost
effective than the current designs used by the impacted sources, which use
solvent-based cleaning systems
.
The discussions in Section 4 .0 in the TSD delineate the various issues that make
the current designs advantageous and more efficient than using a 1 .0 mmHg
solvent or to converting to aqueous-based cleaning . The need for high quality
cleaning of parts used for fine printing (fonts of less than 5) and for surfaces that
need to be varnished (airplane components) is an element that cannot be
compromised by the impacted sources . The chemical composition of the solvents
being used provides the high quality cleaning required . Furthermore, these
solvents can be re-cycled and are compatible with the other operations in the
plants, whereas, aqueous or 1 .0 mmHg solvents are not
.
Therefore, in making a decision on which type of cleaning system is appropriate
for their operations, sources also need to carefully consider the
disadvantages/limitations of each type system . The following were identified as
limitations and/or disadvantages of aqueous cleaning in the Agency's review of
literature
t
:
'Pacific Northwest Pollution Prevention Resource Center, Aqueous Cleaning Technology Review, 1999
www pprc o g
2
•
Aqueous cleaning generates a wastewater stream that requires treatment and
discharge . In addition, many currently available aqueous cleaners contain non-
biodegradable components that make discharge to sewer systems or surface
waters more problematic . Some cleaners that are biodegradable when new are not
biodegradable once they have been used, leading to mistakes by users in how they
think they can treat or handle the used cleaning solutions .
•
Aqueous-cleaning solutions are much more limited in their ability to remove
contaminants by chemical action alone than their solvent counterparts . This leads
to the requirements for mechanical action and increased temperature . In cases
where the contaminants to be removed are especially thick or insoluble, large
amounts of mechanical action can be required . For delicate parts contaminated
with thick grease or other similar compounds, the usefulness of aqueous cleaning
systems can be significantly limited .
•
Spotting or corrosion of parts can be a problem with aqueous cleaning if adequate
rinsing and drying are not included as part of the aqueous cleaning system . This
requirement for additional process steps is a disadvantage when compared with
highly volatile cleaners .
•
While aqueous cleaning systems were shown repeatedly in the literature to equal
or even exceed the performance of solvent systems, the initial effort required to
correctly design, test, and install an aqueous-cleaning system is much greater due
to the increased complexity of the aqueous-cleaning process and the increased
reliance on equipment, as opposed to the cleaning solution. This limitation is very
significant for manufacturers that are very short on time or capital, and can lead to
a preference for "drop-in" replacements, where little time and effort is required
even though the operational savings may not be as great . Manufacturers may opt
for petroleum distillate or semi-aqueous cleaners in these cases
.
While aqueous-based cleaning does not fare well for the sources currently
impacted by the proposed revisions, this may not be true for new sources
.
Sources will need to evaluate factors that either save money or generate new
costs.
A review of the literature reveals a number of specific cases where the economics
associated with aqueous cleaning technology were compared with solvent
cleaning. In many cases, aqueous cleaning faired quite favorably
. Some of these
reports also examined the difference between using traditional cost estimating and
total cost assessment or other more comprehensive cost estimating approaches on
the results of the economic analysis . These methods try to take into account a
wider range of costs than those traditionally used to make an assessment,
sometimes even including intangibles such as future liability
. Generally, the
investment in aqueous cleaning became more economically beneficial as the cost
assessment methodology became more comprehensive
. This trend is an indicator
that this type of change to an aqueous method may be more beneficial than many
3
companies realize . The benefits of converting to an aqueous-cleaning system will
only become more favorable as costs for solvents and disposal of associated
wastes continue to increase .
Of the studies that evaluated economics, several were especially extensive and
made use of the financial data of manufacturers that had recently converted from
solvent to aqueous cleaning . Using a total cost assessment method to evaluate the
economics of conversion for eight projects at manufacturers, one study found that
operational costs were reduced by 75 percent in three cases and more than 95
percent in five cases. All the cases resulted in a positive net present value . Aside
from no add-on control costs, the next largest cost savings identified was the
reduction in chemical costs as solvent was no longer needed/purchased
. If
chlorinated solvents and chlorofluorocarbons are used, there is a high purchase
cost that is largely attributable to the taxes assessed on these solvents . One study
found that labor for maintenance generally increased for the aqueous system,
although this contradicts with the findings of other industry case studies in which
it was reported that less labor time was spent maintaining the aqueous-cleaning
system versus a vapor degreaser
.
Menke, et al
. economically analyzed the conversion to an aqueous-cleaning
system from a TCA vapor degreaser within an automotive radiator manufacturing
line and found the payback to be 2.4 years when using a "hybrid" cost analysis
(similar to total cost assessment) 2. In this analysis labor costs for daily
maintenance were $87,500
on an annual basis for the vapor degreaser versus
$5,400 for the aqueous system . For the same process change, the payback value
increased to 11 .6 years when using a traditional cost analysis that ignored many of
the less obvious costs related to both the old and new process . This example
highlights the large difference that can be seen when using different cost
accounting methods and reinforces the concept that aqueous cleaner investments
will often appear more favorable as the economic analysis becomes more detailed .
Gavaskar's 3
economic evaluation comparing automated aqueous rotary washing
with perchloroethylene (PCE) vapor degreasing for steel caplets showed a
payback of 7 years, much too long to be considered a favorable investment for
most manufacturers
. However, an examination of the analysis shows a chemical
cost comparison of
$1,795 for vapor degreasing versus $2,711 for aqueous
cleaning on an annual basis
. The vapor degreasing chemical cost figure may be
based on currently outdated lower costs for PCE, which brings forward another
limitation of economic analyses reported in the literature .
a Menke, Dean M ., et al ., Demonstration ofAlternative Cleaning Systems, Washington, D .C., U.S. EPA,
August 1995 . (U.S. EPA report number EPA/600/R-95/120 .)
3
Gavaskar, Amn, et al
., "An Automated Aqueous Rotary Washer for the Metal Finishing Industry," in
Pollution Prevention Possibilities for Small and Medium-Sized Industries -
Results of the WRITE Projects,
Washington, D .C., U.S . EPA, May 1995 . (U .S . EPA report number EPA/600/R-95/070 .)
4
The economic analyses verify that there have been a number of cases where
aqueous cleaning has been economically viable and this trend will continue in the
future as the costs for add-on equipment and installation and solvent costs
increase .
The Agency found that most of the available literature addresses the conversion of
solvent-based cleaning to aqueous-based and little is devoted to designing a new
aqueous system . Following are three websites that address the subject of aqueous
versus solvent-based cleaning that provide a basic overview as well as insight into
the various parameters that need to be considered in determining which system is
the better choice :
www.pprc.orq/pubs/techreviews/aqueous
http://www.p2pays .org/ref/01 /00898 .pdf
http://www.p2pays.orp/ref/23/22342
.pdf
IPCB Question :
2
. How would the waste streams from anew source using an aqueous-based
system compare to a solvent-based system using add-on controls? (Seepage
22 of transcript)
Agency Response to Question#2
In regards to waste streams from the impacted sources, using solvents other than
the current ones or converting to aqueous cleaning would create a distinct waste
stream that would need to be handled differently by the impacted sources . This
would necessitate process changes and additional costs with a possible final result
of poorer cleaned parts . However, for new sources choosing aqueous-based
cleaning systems at initial start-up, the waste stream would be handled in a more
cost efficient manner to minimize volume and assure, if possible, that it is
biodegradable and not a hazardous waste .
Minimizing the hazardous waste stream is always desirable in any process, since
disposing of it only adds to the overall costs of the cleaning process as well as to
the adverse environmental impacts . For the sources impacted by the proposed
revisions, converting to aqueous-based cleaning would probably increase the
volume of the waste stream, since more volume of cleaning solution would be
needed to attain the desired surface cleanliness compared to solvent-based
cleaning. In the information provided by Diversapack for this rulemaking, they
indicated that a waste stream of 71,920 gallons in 2003 and 60, 450 gallons in
2004 would have been generated if their current system was abandoned and a
solvent with 1 .0 mmHg vapor pressure was utilized (Reference TSD Attachment
1 -Exhibit 4). If aqueous cleaning were employed, the waste stream volume
would probably be as large if not larger
. Determining the comparative increase in
5
volume and the characteristics of the waste stream is difficult to assess, since it
would depend highly on the degree of surface cleaning desired by the source and
the type of dirt and grease on the parts being cleaned .
IPCB Question
:
3. Are there re-use options (for used solvent) similar to those used by the sources
using add-on controls? (See page 24 oftranscript)
Agency Response to Question #3
The extraction of solvent that is in the waste stream is always desirable ; however,
the cost effectiveness in extracting it will always be a business consideration . If
the extracted solvent is re-useable and compatible with the other processes in the
plant, it becomes more valuable to the source . For aqueous-based cleaning
systems, the only solvent in the waste stream would be from the cleaning of the
parts ; therefore, re-claiming such a small quantity of solvent would be expensive
and consequently probably not cost-effective
. Diversapack and Printpack have
indicated that the solvents that make-up a commercially available and suitable
cleaning material with 1 .0 mmHg vapor pressure (e .g., HCS 402 Ink Remover)
are not re-useable in their process . Diversapack indicated in their cost analysis
data that they would prefer to employ a firm specializing in handling hazardous
waste at a cost of $2 .50 per gallon than to deal with extracting any solvents or
treating the waste stream to make it biodegradable and non-hazardous . However,
the re-claimed solvents from the currently used 55
.19 mmHg vapor pressure
material are re-useable, are found in greater volume in the waste stream, and are
compatible with other processes in their facility, which makes them highly
valuable and very cost effective to recover . Thus, only the solids from the
cleaning operation need to be disposed .
It should also be noted that for Printpack and Diversapack nearly a third of the
VOM going to their control oxidizers is from their cold cleaning operations (over
500 tons per year for Diversapack in 2004) . If an aqueous system were employed,
this VOM would no longer go through the oxidizer's combustion process for
destruction and, therefore, would require the addition of supplemental natural gas
to maintain the desired temperature ranges to assure proper destruction of VOM
collected from the printing processes.
For a new source that finds that an aqueous cleaning system is technically
feasible, a change will not be implemented without a full understanding of all the
costs and benefits . The re-usability of solvents in the waste stream and the cost
effectiveness of extracting it is a factor that a new source would need to consider
.
Unfortunately, it is impossible to generalize about the overall economics in
choosing an aqueous cleaning system, because the values and methods that go
into making such an analysis are very company specific .
The largest capital expenditure in the decision of choosing solvent-based versus
aqueous-based cleaning is the comparative control system equipment costs . In the
6
case of Printpack and Diversapack, there would not be an initial capital
expenditure for an add-on control, since the control equipment already exists to
handle VOM emissions from the printing processes and ducting to it is the only
additional costs incurred
. Eliminating this capital investment for the add-on
control equipment is the major cost factor favoring aqueous over solvent-based
cleaning
. If add-on controls had to be purchased to handle the solvent-based
cold cleaning emissions exclusively, the estimated costs would be in the range of
$1 .2 MM for Printpack and $600,000 for Diversapack, which would obviously
favor a decision toward an aqueous-based solution .
Annual operating costs for add-on controls for FY2005 for Printpack and
Diversapack was $210,000 and $289,900 respectively . Printpack routed 1830
tons of uncontrolled VOM emissions to their control device, and Diversapack sent
1,599 tons of VOM to theirs . Therefore, the cost effectiveness of these controls
was $115 and $181 per ton of VOM removed
.
The higher cost of the solvent-based versus aqueous-based cleaning solutions is
also an often cited advantage for aqueous-based cleaning, but for Diversapack and
Printpack this advantage does not hold true
. According to company provided data
from Diversapack the cost of their currently used solvent, which has a vapor
pressure of 55
.19 mmHg, is $4 .82 per gallon . This compares with a 1 .0 mmHg
vapor pressure solvent that cost $23
.00 per gallon and aqueous-based cleaners that
cost $28 .50 per gallon .
IPCB Question :
4.
Should the rule be adopted, how would the Agency require the source to
examine alternative control measurers to promote pollution prevention? (See
page 26 of transcript)
Agency Response to Question #4
The Agency will assess pollution prevention control measures on equal footing
with any other proposed equivalent alternative control measures
. If VOM
emissions to the atmosphere are equal to or less than using 1 .0 mmHg vapor
pressure materials, the proposed pollution prevention control measure will be
approvable by the Agency
. There is no formal requirement in the proposed
revisions that pollution prevention control measures be evaluated
. The Agency's
role is in setting the environmental standard that must be met
. The decision
regarding how this standard is met is left with the source .
IPCB Question
:
5. Does the Agency require sources to demonstrate cost effectiveness via
studies? (Seepage 26 of transcript)
° U .S. Navy, Chemical Cleaning as a Solvent Alternative, 1999
http ://p2library.nfesc.navy .mil/P 2
Opportunity Handbook/8 1_l .html
7
Agency Response to Question #5
The Agency does not require sources to demonstrate cost effectiveness via studies
for control measures that they are planning to implement . The Agency assesses
the sources' compliance with the Agency's regulations and determines if the
source is meeting the proposed emission limits
.
IPCB Question :
6. Are the solvent retailers aware of the proposal and were they part of the
Bureau's outreach?
Response to Question #6 :
The outreach for the proposed revisions included the four impacted sources, in
addition to the Illinois Environmental Regulatory Group (IERG), Illinois
Manufacturers Association (IMA), and the Chemical Industry Council of Illinois
(CICI) .
Retailers were not contacted in the initial outreach process
. However, it is the
Agency's understanding that potentially impacted sources from this rulemaking
are larger users of cold cleaning chemicals that buy at the wholesale level directly
from industrial suppliers
. Furthermore, they do not buy an off-the-shelf product
but buy the various ingredients needed and formulate the desired cleaning
solutions at their facilities . Therefore, a cold cleaning solution with a vapor
pressure of 55 .19 mmHg as used by Diversapack or 19 .12 mmHg as used by
Pechiney, does not exist at a retailer or a wholesaler per se . From an enforcement
perspective, the documentation required to allow the use of solvents greater than
1 .0 mmHg VP would be the federally enforceable permit held by the user of the
chemicals . However, the retailers still have a responsibility under the regulations .
Illinois EPA is planning to contact retailers and is compiling a contact list for
outreach. This outreach will take place before the close of the final comment
period .
IPCB Question :
7.
Does the Agency want to set an actual date in (c)(3)(C) [now (c)(4)(C)]
versus using the effective date of the adopted rule?
Response to Question#7:
218 .182 (c)(3)(C) will now be 218 .182 (c)(4)(C)
.
The Agency is proposing that
the effective date for existing operations be established as November 30, 2006 .
Existing sources that are using add-on controls must be tested by March 1, 2007 .
New sources using add-on controls or an equivalent alternative control plan that
8
begin operations after November 30, 2006, shall be tested within 90 days after
initial start-up .
IPCB Question :
8. How often should records be done/do we need a time requirement to avoid
violations going unnoticed/unreported? See (d)(3),(4), and (6)?
Response to Question #8 :
As specified in 218 .182 (c)(4)(C), recordkeeping for add-on controls and
equivalent alternative control plans are to be performed pursuant to Sections
218 .105 (c), (d), (e), and (f). In Section 218 .105(d)(2), it is required that an owner
or an operator that uses an afterburner to comply shall use Agency and U .S.EPA
approved continuous monitoring . Records must be kept that verify that a source
is in compliance on a continuous hourly basis in the ozone nonattainment areas of
Chicago and Metro East St. Louis
; therefore, consistent with these requirements,
daily record keeping is being proposed where appropriate in the Section
218.182(d)(3), (4), and (6).
9
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVED
IN THE MATTER OF :
)
MAY
1
2 2006
R06- 21
(Rulemaking Air)
PollutionSTATE
Control
OF
ILLINOIS
Board
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST )
AREAS : PROPOSED AMENDMENTS )
TO 35 ILL . ADM . CODE 218 AND 219 )
ERRATA SHEET NUMBER2
THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY ("Agency" or
"Illinois EPA") submits this ERRATA SHEET NUMBER 2 for the above-titled matter to
the Illinois Pollution Control Board ("Board") and the participants listed on the Service
List
. The revisions proposed below are to the Agency's original proposal filed with the
Board on December 22, 2005, and include revisions proposed in Errata Sheet Number 1
submitted to the Board at the hearing on Apri119, 2006, as Hearing Exhibit Number 3 .
In support of the these changes are Gary Beckstead's pre-filed supplemental testimony
and Supplemental Statement Number 2, both of which were also served on the Board and
the Service List.
Section 218 .182 Cold Cleaning
c)
Material and Control Requirements :
2)
On and after March 15, 2001, no person shall :
A)
Cause or allow the sale of solvent with a vapor pressure
which exceeds 1 .0 mmHg (0.019 psi) measured at 20° C
(68° F) in units greater than five (5) gallons, for use in cold
cleaning degreasing operations located in the area covered
by Section 218 .103 of this Part .
THIS FILING SUBMITTED ON RECYCLED PAPER
I
B)
Operate a cold cleaning degreaser with a solvent vapor
pressure which exceeds 1 .0 mmHg (0 .019 psi) measured at
20° C (68° F) .
NOTE - The language in (c)(2) has been returned to its current state, with the
exception of a numerical indicator
. The language from the originally proposed
(c)(2) and (c)(3) is now found in
(c)(3) and
(c)(4)
.
3)
On and after Nove her 302006 M-- ` person shall:
Cause o_r_allow thesale
of solvent with a vapor pr se sure
which exceeds 1 mmH.0
.019it measured at20° C
6
) in units grea er than five
51 gallons, for use in cold
cleaning degreasing operations located in the area covered
b ection2 8 .103 f this Part- unless the purchaser
provides
a
copv of a valid state or federal construction or
operating permit or a copy of the Federal Register
demo stratine that they are in compliance with the control
requirements-of subsection (c)(4) , of this Section or
are exempt under subsection (f) or (g)
ofthis Section.
p
Operate a cold cleaning degreaser with a solvent valor
pressure which exceeds 1
.0 mHg (0 .019 psi) measured t
20° C (68° F). unless y_are in compliance with he
contr re uirements of subsection (c)(41( Fadof this
Section or are exem t under subset ion f orr (g of this
Section.
4_4j
Control Requirements :
B)
An equivalent alternative control plan ac icyin l 95
maybe used to meet the control
requirements of this Section pursuant to Section 218 .108of
this Part
. Pursuant to the material requirements of
subsection(.e)I3fB) (94444)of
this Section, a solvent
with a vapor pressure of 1 .0 mmHg (0
.019 psi) measured at
20° C (68° F) shall be the basis for assessment of
equivalent emissions from any equivalent alternative
control
plan. If used as an equivalent alternative control
lamn,_anadd-on control must demonstrate at least a 95
percent overall capture and control efficient A control
plan approved by the Agency shall be effective only when
included in a federally enforceable permit or approved by
the U.S . EPA as a SIP revision pursuant to Section 218 .108
of this Part.
THIS FILING SUBMITTED ON RECYCLED PAPER
2
C)
Add-on controls operating at a source prior to November
2006,"-- -" a°'-
-"`i-m-
1,
shall be tested by
March 1, 2007
.
Add-on controls constructed after
No mber 30 2006
the
o"-
d &-k-h-4-4-4-46-shall
tested within 90 days of initial startup . Testing
^beprocedures
and recordkeeping for add-on controls and equivalent
alternative controls subject to subsections (c)f4)(A)and (B)
'°een )( of
this Section are to be performed
pursuant to Section 218 .105(c), (d),(e)
and(()of
this Part.
d)
Recordkeeping an ReportingRequirements: On and after March 15,
1999 :
NOTE - The new language from Errata Sheet
#1 in subsection (d)'s heading has
been rearranged .
1)
All persons subject to the requirements of subsections
(c)(1)(A),
(c)(2)(A)
.
and(c)(3)(A)
of this Section must maintain records
which include for each sale :
A)
The name and address of the solvent purchaser
;
B)
The date of sale ;
C)
The type of solvent;
D)
The unit volume of solvent ;
E)
The total volume of solvent ; and
F)
The vapor pressure of the solvent measured in mmHg at
20° C (68° F) .
2)
All persons subject to the requirements of subsections (c)(1)(B),
a (c)(2)(B)and (c 3 B of this Section must maintain records
which include for each purchase :
A)
The name and address of the solvent supplier ;
B)
The date of purchase ;
C)
The type of solvent; and
D)
The vapor pressure of the solvent measured in mmHg at
20° C (68° F).
THIS FILING SUBMITTED ON RECYCLED PAPER
3
E~
For any mixture of solvents, the vapor
pressure of the
mixture as
used measured in mmHP at 2 68° F)
3)
All ersons subject to the re uirements of subsection (41
of this Section must maintain records, which include for each
purchase:
•
The name and address of the solvent supplier
;
•
The date of purchase ;
•
The type of solvent ;
D)
The unit volume of solvent;
•
The total volume of solvent; and
•
The vapor pressure of the solvent measured in mmHg at
20° C (68° F) .
C or
any mixture of solvents, the vapor pressure i f the
fixture as used meal in mmHg at 20° C (68° F)
4j
All persons subject to the requirements of subsection
!c)(4)(
of this Section shall maintain records documenting the use of good
operating practices consistent with the equipment manufacturer's
specifications for the cold cleaning degreasers and add-on control
equipment
. At a minimum these records shall include :
A)
Records for periodic inspection of the cold cleaning
degreasers and add-on control equipment with date,
individual performing the inspection, and nature of
inspection;
•
Records for repair of malfunctions and breakdowns with
identification and description of incident, date identified,
date repaired, nature of repair, and the amount of VOM that
escaped into the atmosphere as a result of the incident;
•
Control device monitoring and recording data; and
•
A
ails log of operating time for the control device,
monitoring equipment, and all associated degreasers
.
All persons subject to the requirements of subsection (c) of this
Section shall notify the Agency at least 30 days before changing
THIS FILING SUBMITTED ON RECYCLED PAPER
4
Section 219
.182 Cold Cleaning
the method of compliance between subsection c
3
(e44
and
(c)(4) (.@"of this Section
. Such notification shall include a
demonstration of compliance with the newly applicable subsection
.
c)
Material and Control
Requirements :
2)
On and after March 15, 2001, no person shall :
A)
Cause or allow the sale of solvent with a vapor pressure
which exceeds 1 .0 mmHg (0.019
psi) measured at 20° C
(68° F) in units greater than five (5) gallons, for use in cold
cleaning degreasing operations located in the area covered
by Section 219
.103 of this Part .
B)
Operate a cold cleaning degreaser with a solvent vapor
pressure which exceeds 1 .0 mmHg (0.019
psi) measured at
20° C (68° F) .
fromNOTEthe
-The
originally
language
proposedin(c)(2)(c)(2)has
andbeen (c)(3)returned
is nowto
its
found
current
in(c)(3)stateand
. The
(c)(4)language
.
3j
On and after November 3
2006 Mare no
person shall :
A)
Cause or allow the sale
of solvent with a va or
essure
which exceeds 1
.0 mmHg (0.019 psi) measured at 20°
68° F in units greater than five
5) gallons, for use in cold
caning degreasing operations 1 in
the area covered
b Sec1n 219.103
of this Part unle the purchaser
provides a copy of a valid state or federal construction or
o i ermit
a co of the Federal Re iste
that the
a e in c m 'ance with the con of
rr uirements of subsection c)(41
of this Section or
are exempt under subsection (f)or
(g) of this Section
demonst a I
BB)
Operate a cold cleaning degreaser with a solvent vapor
pressure which exceeds 1 .0
mHe (0.019 psi) measured at
20'C(68' F) nless they are in compliance with the
control
requirements of subsection (c)(4)
(
of this
Section or are exempt under subsection (f) or
(g) of this
Section.
THIS FILING SUBMITTED ON RECYCLED PAPER
5
4_4)
Control Requirements
:
I3
An equivalent alternative control plan at
co
may be used to meet the control
requirements of this Section pursuant to Section 219.108
of
this Part
. Pursuant to the material requirements of
subsection (p)(3_)fR (c)(
of this Section a solvent
with a vapor pressure of 1
.0 mmHg (0.019 psi) measured at
20° C (68° F) shall be the basis for assessment of
equivalent emissions from any equivalent alternative
ntrol
plan. If-used a an
equivalent
alternative controj
planan add-on control must demonstrate at least a 95
e cent overall ca d con efficienc
A control
plan approved by the Agency shall be effective only when
included in a federally enforceable permit or approved by
the U.S
. EPA as a SIP revision pursuant to Section 219.108
of this Part.
Add-on controls operating at a source prior to November
302006
.
shall be tested by
March 1, 2007
.Add-on controls constructed after
November 30, 2006, shall
be
tested within 90 days of initial startup . Testing procedures
and recordkeeping for add-on controls and equivalent
alternative controls subiect to subsections (cj4)(A) and (B)
of this Section are to be performed
pursuant to Section 219 .105(c), (d),(e)
and (f) of this Part .
d)
Recordkeeping
and Reporting Requirements : On and after March 15,
1999 :
NOTE -
The new language from Errata Sheet #1 in subsection (d)'s heading has
been rearranged .
1)
All persons subject to the requirements of subsections
(c)(1)(A)z
e (c)(2)(A) and
(,
c)(3)(A) of this Section must maintain records
which include for each sale
:
A)
The name and address of the solvent purchaser ;
B)
The date of sale;
C)
The type of solvent ;
D)
The unit volume of solvent ;
THIS FILING SUBMITTED ON RECYCLED PAPER
6
E)
The total volume of solvent ; and
F)
The vapor pressure of the solvent measured in mmHg at
20° C (68° F) .
2)
All persons subject to the requirements of subsections (c)(1)(B),
apAl=(c)(2)(B) and
c 3 B of this Section must maintain records
which include for each purchase :
A)
The name and address of the solvent supplier ;
B)
The date of purchase ;
C)
The type of solvent ; and
D)
The vapor pressure of the solvent measured in mmHg at
20° C (68° F) .
•
Fo an mi
u e of solvents, the vapor pressure of the
m
measured in mmHg
at
20°
C (68° Fl
3)
All persons subject to the requirements of subsection c 4) (o* 34
of this Section must maintain records, which include for each
purchase :
•
The name and address of the solvent supplier ;
•
The date of purchase ;
•
The type of solvent ;
DD)
The unit volume of solvent ;
•
The total volume of solvent ; and
•
The vapor pressure of the solvent measured in mmHg at
20° C (68° F) .
•
For any mixture_of solvents the vapor pressure of the
mix ure as used measured i mmH at 20° 68° F
4)
All persons subject to the requirements of subsection (c)(41(
of this Section shall maintain records documenting the use of good
operating practices consistent with the equipment manufacturer's
specifications for the cold cleaning degreasers and add-on control
equipment . At a minimum these records shall include :
THIS FILING SUBMITTED ON RECYCLED PAPER
7
• Records for periodic inspection of the cold cleaning
degreasers and add-on control equipment with date,
individual performing the inspection, and nature of
inspection ;
•
Records for repair of malfunctions and breakdowns with
identification and description of incident, date identified,
date repaired, nature of repair, and the amount of VOM that
escaped into the atmosphere as a result of the incident ;
•
Control device monitoring and recording data ; and
•
A daily log ofoperating time for the control device,
monitoring equipment, and all associated degreasers .
All persons subject to the requirements of subsection (c) of this
Section shall notify the Agency at least 30 days before changing
the method of compliance between subsection(c)(3)j
,
and
(c)f4) ) of this Section. Such notification shall include a
demonstration of compliance with the newly applicable subsection .
THIS FILING SUBMITTED ON RECYCLED PAPER
8
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
MAY 12 2006
R06- 21
(Rulemaking Air)
STATE
OF ILLINOIS
IN THE MATTER OF :
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST )
AREAS : PROPOSED AMENDMENTS )
TO 35 ILL. ADM . CODE 218 AND 219 )
Pollution Control Board
SUPPLEMENTAL STATEMENT NUMBER2
NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA") by
and through one of its attorneys, Annet C . Godiksen, and submits the following
SUPPLEMENTAL STATEMENT NUMBER 2 in the above-titled matter to the Illinois
Pollution Control Board ("Board") and the participants on the Service List .
This SUPPLEMENTAL STATEMENT NUMBER 2 addresses two issues raised
during the April 19, 2006, hearing in the above-titled matter . The Agency would like to
correct and clarify the previous testimony regarding the retroactivity of certain portions
of the proposed rulemaking
. The Agency does not intend for this proposed rulemaking to
be retroactive and the amended language as found in ERRATA SHEET NUMBER 2
reflects this position . Concerning the compliance status of the four affected sources
between 1999 and the effective date of this proposed rulemaking, the Agency reserves the
right to exercise its enforcement discretion
.
THIS FILING SUBMITTED ON RECYCLED PAPER
I
ILLINOIS ENVIRONMENTA PROTECTION AGENCY
By:
Annet C . Godiksen
Assistant Counsel
Division of Legal Counsel
Dated: May 10, 2006
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER
2
STATE OF ILLINOIS
)
)SS .
COUNTY OF SANGAMON
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Supplemental Testimony
of Gary E
. Beckstead, Errata Sheet Number 2 and Supplemental Statement Number 2 upon the
person to whom it is directed, by placing it in an envelope addressed to :
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
(Via Facsimile & First Class Mail)
John Knittle, Hearing Officer
Illinois Pollution Control Board
2125 South First Street
Champaign, Illinois 61820
(Via First Class Mail)
Tim Lindsey
Waste Management and Research Center
One East Hazelwood Drive
Champaign, Illinois 61820
(Via First Class Mail)
and mailing it by First Class Mail from Springfield, Illinois on May 10, 2006, with sufficient
postage affixed .
SUBSCRIBED AND SWORN TO BEFORE ME
this 10th day of May, 2006
Notary Public
Matthew Dunn
Illinois Attorney General's Office
James R. Thompson Center
100 West Randolph Street, 12 th Floor
Chicago, Illinois 60601
(Via First Class Mail)
William Richardson Chief Legal Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
(Via First Class Mail)
OFFICIAL SEAL
CYNTHIA L
. WOLFE
<
':
NOTARY PUBLIC, STATE OF ILLINOIS
MY COMMISSION EXPIRES 3
.20 .2007
THIS FILING IS SUBMITTED ON RECYCLED PAPER
