BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY
AVAILABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLATILE
ORGANIC MATERIAL
EMISSIONS FROM
GROUP
II CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO
35 ILL. ADM. CODE 211,218, and 219
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RI0-8
(Rulemaking-Air)
NOTICE
To:
John Therriault, Assistant Clerk.
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601-3218
SEE
ATTACHED
SERVICE
LIST
PLEASE
TAKE NOTICE that I have today filed with the Office of the Pollution Control
Board the
TESTIMONY OF DAVID BLOOMBERG and MOTION TO AMEND
RULEMAKING
PROPOSAL ofthe Illinois Environmental Protection Agency, copies of which
are herewith served upon you.
DATED: September 14,
2009
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-5544
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:C]);u...Q
Dana VetteT1lOffer
~
Assistant Counsel
Division
of Legal Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY
AVAILABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLATILE
ORGANIC
MATERIAL EMISSIONS FROM
GROUP
II CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35 ILL. ADM. CODE 211, 218, and 219
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)
)
)
)
)
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)
RlO-8
(Rulemaking-Air)
TESTIMONY OF DAVID BLOOMBERG
My name is David E. Bloomberg. I am employed by the Illinois Environmental Protection
Agency
("Illinois EPA" or "Agency") as the Compliance Unit Manager in the Compliance
Section within the Division
of Air Pollution Control. I have been at the Agency in this capacity
for over five years, and was previously an Environmental Protection Engineer in the Air Quality
Planning Section for twelve and a
half years.
My academic credentials include a Bachelor
of Science degree in ceramic engineering from the
University
of Illinois at Champaign-Urbana, as well as completion of all graduate coursework
required for a Master's degree in the same area
of study. I have also completed numerous
environmental courses over the years and provided training on air pollution compliance issues to
industry personnel and environmental consultants.
Among my duties, I wrote the technical support document
("TSD") and co-wrote the regulatory
language for this rulemaking proposal, and did likewise for previous rulemakings involving
lithographic printing and several coating categories. I have also been the Agency's main contact
for interpretations and questions involving these rules and other regulations covering printing
1
and coating for over 14 years.
In
that role and as part of my Compliance Unit Manager
responsibilities, I have also participated in both adjusted standard and enforcement hearings
involving sources engaged in the printing
of flexible packaging.
In
addition, I have been
involved in designing, writing, implementing, and enforcing a wide variety
of air pollution
regulations, including those for mercury,
NOx trading, the Clean Air Interstate Rule, and the
Emissions Reduction Market System.
My duties as the Compliance Unit Manager involve supervision
of the Bureau of Air staff who
review documents submitted
by sources, such as exceedance, semi-annual, and annual
compliance reports, as well
as those who review emissions tests, and I sign off on all such
reviews before they are finalized.
In
addition, I participate in decisions regarding enforcement of
the Board's air pollution regulations and oversee the process of sending out Violation Notices
and related activities.
I am here today to provide testimony and to answer questions pertaining to the Group II Volatile
Organic Materials ("V OM") Control Techniques Guidelines ("CTGs") regulations that the
Agency has proposed. A more extensive discussion
of these proposed modifications can be
found in the
TSD and Statement of Reasons, but I will summarize them briefly again here.
These proposals address the same categories as those covered
by the United States
Environmental Protection Agency ("USEPA") in what is known collectively as the Consumer
and Commercial Products, Group II, which includes lithographic printing, letterpress printing,
flexible packaging printing, flat wood paneling coating, and industrial cleaning solvents.
2
Section 172 of the Clean Air Act ("CAA") requires that state implementation plans ("SIPs") for
nonattainment areas, such as the Chicago and Metro-East St. Louis nonattainment areas
("NAAs") in Illinois, must include requirements for "reasonably available control technology"
("RACr") as it applies to emissions sources. Section I 82(b)(2)(A) of the CAA further requires
that SIPs be revised to include
RACr for YOM emissions sources that are covered by a CrG
document issued by USEPA after November 15, 1990, and before the area's date of attainment.
rhe USEPA defines RACr as "the lowest emission limitation that a particular source is capable
of meeting by the application of control technology that is reasonably available considering
technological and economic
feasibility."
In
developing the CrGs for the categories covered by
this rulemaking, USEPA evaluated the sources ofVOM emissions from the applicable industries,
the available control possibilities to address the associated emissions, and the cost
of such
control measures. Illinois
EPA based much of its proposal on these CrGs and on USEP A
research.
Lithographic
Printing
Proposed changes to the lithographic printing regulations involve modifications to control
requirements for heatset web offset lithographic printers as well
as changes to fountain solution
and cleaning solution limitations for all subject units.
In
addition, the requirements for cleaning
solutions and fountain solutions are being extended to sources with lower emissions. All
of these
3
Electronic Filing - Received, Clerk's Office, September 14, 2009
changes have been determined to be RACT by USEPA, and Illinois EPA's experience with
control devices on lithographic printing sources correlates with that determination.
In order to reduce the burden on smaller sources, and as a result
of discussions with industry
representatives, exclusions to the cleaning solution and fountain solution requirements have been
included in this proposal. Sources may make use
of such exclusions if they fall into the listed
categories. Specifically, the exclusions apply to sources that emit between
15 and 100 pounds per
day
ofVOM and include sheet-fed presses that print substrates no larger than 11 inches by 17
inches and any lithographic press with a fountain solution reservoir
of no larger than one gallon.
In addition, all sources in this emission range will
be able to use up to
110
gallons of cleaning
solution per year that do not
meet
either the YOM content or vapor pressure requirements.
Sources may choose to opt out
of these exclusions if they do not wish to make use of them, and
thus would not need to keep the records required
of those utilizing the exclusions.
In
addition,
discussions with industry led the Agency to propose a new method
of calculating applicability
based on material use, which may be easier for some sources.
Another change to the lithographic printing regulation that aids sources is the specification
of
YOM retention factors. The existing regulation recognizes that the substrate retains some of the
YOM present in the ink, and thus a retention factor of 0.95 is used when calculating emissions
from non-heatset inks, while a factor
of 0.20 is used when calculating emissions from heatset
inks. The proposed modification contains a factor recognizing that
YOM also remains on
solvent-laden rags that are stored and disposed
of properly. These factors continue to be allowed
for determination
of applicability. In addition, this proposal adds emission adjustment factors to
4
be used in other situations when not determining applicability (such as for Annual Emissions
Reports and permit limits). These factors take into account carryover
ofVOM from automatic
blanket wash and fountain solutions into the dryer and control device.
Letterpress Printing
While there are very few letterpress operations in Illinois NAAs, and apparently no heatset
letterpress units, the State is still required to promulgate the CTG regulations for this category.
Letterpress emission sources are similar to those for lithographic printing, with the exception that
letterpress operations do not use a fountain solution.
In
addition, letterpress printing presses are
often operated at the same source
as lithographic printing and many of the control options for
letterpress printing are the same as the control options for lithographic printing
as well. This is
especially true in terms
of cleaning solutions. As such, the proposed rule would adopt most of the
RACT recommendations
of the CTG.
It
should be noted that, unlike for larger lithographic
printing sources, the Agency is proposing to use the cleaning solution
70 percent YOM content
limit for all subject letterpress units, as letterpress operations have never been specifically
regulated in Illinois before and thus there are no concerns about loosening existing standards.
Flexible Packaging Printing
The modifications being proposed for flexible package printing appear in the sections that
currently cover all rotogravure and flexographic printing; however, these modifications only
apply to this specific subcategory
of printing operations.
5
The proposedchanges focus on reducing YOM emissions from inks and cleaning operations. Ink
emissions must
be reduced either through a lower YOM content or by a control device, where
the percentage reduction required
of an add-on control varies depending on when the press and
control were constructed at the site. The approach to reducing
YOM emissions from cleaning
materials focuses on work practices, and thus there is no specific numeric limit that applies;
however,
the applicability level for such work practices is much lower, at 15 pounds per day, as
compared to the applicability thresholds
of 25 tons per year potential to emit or 100 tons per year
maximum theoretical emissions for the remainder
of the rule.
Industrial
Cleaning Solvents
The industrial cleaning solvents category encompasses many products and cleaning styles that
are used to clean dirt, soil, oil, and grease, as well as remove adhesives, paints, and inks. The
proposed rule thus covers a wide range
of cleaning activities. The proposal follows USEP A's
CTG in the applicability threshold of 15 pounds per day ofVOM emissions and in most of the
required
YOM limits. The CTG recommends a content limit of 50 grams YOM per liter (0.42
Ib/gal)
of cleaning material for those industries that are not already covered, and are not to be
covered,
by a CTG. However, there are some cases where the Illinois EPA has received USEPA
permission to use higher limits - or indeed to exempt the type of operation entirely - in response
to industry representatives' comments regarding issues specific to certain categories
of cleaning.
In addition, there is an alternate vapor pressure limit
of 8 mm Hg at 20 degrees Celsius that may
be used in place of the 50 gram limit. Furthermore, cleaning solvent emissions can also be
6
reduced by add-on controls, modifying equipment, or changing the method of cleaning such that
an overall control efficiency
of 85 percent reduction in emissions of cleaning solvent YOM is
achieved.
In
addition to the limits discussed above, aU subject sources must make use of certain work
practices to reduce emissions. General work practices include keeping solvent containers and
used applicators covered; properly storing and disposing
of spent solvents and used cleaning
rags; minimizing air circulation around all cleaning operations; and implementing equipment
practices that reduce emissions, e.g., leak detection and repair practices.
Flat Wood Paneling Coating
The category of flat wood paneling coating has not been previously covered in Illinois'
regulations (though some products that will now be defined as flat wood paneling
may have been
previously covered under the wood furniture coating regulations). As with most coating
categories, the two main options for compliance are the use
of lower-yOM coatings or add-on
controls. Illinois
EPA is using the YOM content limits and control efficiencies that USEPA
determined in the eTG to be RACT.
In
addition, work practices related to cleaning operations will apply to this category. Some of
these requirements are already in place within the existing regulations for wood furniture coaters.
Under the Agency's proposal, these will apply to flat wood paneling coaters as well, as will
several other specific requirements.
7
Conclusions
The Agency believes these proposed changes to be largely non-controversial, as they stem from
USEPA's determination ofRACT that applies to these categories of sources nationwide. The
Agency agrees with USEPA that all the proposed changes are technically feasible and
economically reasonable. Furthermore, as noted earlier, incorporating these additions and
modifications to existing Illinois regulations is required
by the CAA and USEPA; specifically,
Section 182(b )(2)(A)
of the CAA requires that Illinois revise its SIP to include RACT for YOM
emissions sources that are covered by a Group II CTG.
The Illinois EPA engaged in multiple rounds of outreach efforts in relation to this proposed
rulemaking. The first was accomplished electronically, with the second involving follow-up calls
from the Agency to sources that had submitted comments as well as extensive, detailed
discussions between the Agency and industry group representatives. Such communication
resulted in the Agency making numerous changes to the proposed rule between the original draft
sent out for comments and the fmal proposal submitted to the Board, with almost all
such
changes being in response to industry concerns.
In
addition, the Agency has had frequent
discussions with
USEP A personnel in both the regional office and headquarters, and has
gathered information from other states. Even after the Agency submitted its proposal to the
Board, communication with these parties continued, resulting in the Motion to Amend
Rulemaking Proposal that is being submitted along with this prefiled testimony.
In
responding to
8
Electronic Filing - Received, Clerk's Office, September 14, 2009
industry, the Agency has been as agreeable as possible to recommendations while still adhering
to
USEPA requirements and maintaining the integrity of the rules.
9
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER
OF:
REASONABLY AVAILABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLATILE
ORGANIC MATERIAL
EMISSIONS FROM
GROUP II CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35 ILL. ADM. CODE 211, 218, and 219
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RI0-8
(Rulemaking-Air)
MOTION TO AMEND RULEMAKING PROPOSAL
The Proponent, the Illinois Environmental Protection Agency ("Illinois EPA"), by its
attorney, and pursuant to 35 Ill. Adm. Code 101.500 and 102.402, moves that the Illinois
Pollution Control Board
("Board") amend Parts 218 and 219 of this rulemaking proposal. In
support of its Motion, the Illinois EPA states as follows:
1.
On July 9, 2009, the Illinois EPA filed a proposal with the Board to amend 35
III.
Adm.
Code
Parts 211, 218, and 219 to control the emissions of volatile organic materials ("V OM")
from Group II Consumer and Commercial Product categories. The proposal implements
reasonably available control technology for such categories in response to control techniques
guidelines issued by the United States Environmental Protection Agency (''USEPA''). The
Illinois EPA proposes the following amendments
to its proposal.
Industrial Cleaning Solvents
2.
The USEPA recently informed the Illinois EPA that the Illinois EPA may exempt digital
printing from the control requirements set forth in Section
2181219.187
of its proposal. The
Illinois EPA therefore recommends amending Section 218/219.l87(a) by adding digital printing
to the list of exclusions, and Section 218/219.l87(b) by removing digital printing from the YOM
content limitations.
Electronic Filing - Received, Clerk's Office, September 14, 2009
Section 2181219. 187(a)(2)(C)(xv) and (xvi):
C)
The following cleaning operations shall be exempt from the requirements
of subsections (b), (c), (f), and (g) of this Section:
xv)
Cleaning of numismatic
dies~,
(xvi) Cleaning operations associated with digital printing.
Section 2181219. 187(b)(1)(C)(ii) and (iii):
C)
Cleaning of ink application equipment:
ii)
Screen printing and digital priHtiHg
iii)
Ultraviolet ink and electron beam
ink application equipment, except
screen printing
and digital priHtieg
0.50
4.2
0.65
5.4
3.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending
Section 2181219.l87(e)(J)(B) by removing the requirement that a source include in its
notification to the Illinois
EPA calculations showing an exceedance of the applicability
threshold.
Section 2181219. 187(e)(1)(B):
B)
Notify the Agency of any record that shows that the combined emissions
ofVOM from cleaning operations at the source ever equal or exceed 6.8
kg/day (15 lbs/day), in the absence of air pollution control equipment,
within
30 days after the event
occurs~.
8116fl HetifieatieH shall iHslHde
saleHlatieHs sfiewiHg the daily emissiells ef YOM ffeHi eleaniHg
eperatiells at the
seHree fer the dayEs) ill whieh eHiissiells etIHaied er
eKeeeded
B.8
k~ay
(15
lllstda)~;
4.
In response to a request by industry representatives, the Illinois EPA proposes amending
Section
2181219.187(e)(2)
by deleting the requirement that a subject source certify the limitation
with which each subject cleaning operation will comply. The Illinois
EPA also proposes
2
Electronic Filing - Received, Clerk's Office, September 14, 2009
deleting the requirement that a source notify the Illinois EPA at least 30 days in advance of
changing its method of compliance between the YOM content limitation and vapor pressure
limitation.
Section 2181219.187(e)(2)(A)(iii):
A)
By April I, 2011, or upon initial start-up of the source, whichever is later,
submit a certification
to the Agency that includes:
iii)
The limitatieH with vfflieh eaeh sW9j eet eleanillg aperatiaH will
eSHlflly (i.e., the emissislls samral system reEtHifement, YOM
salltsm limitatisH, Sf viIjlsr pressure limitatiall), aBEl ifIf complying
with the emissions control system requirement, what type
of
emissions control system will be used;
Section 2181219.187(e)(2)(B):
B)
At least 30 calendar days before changing the method of compliance
between subsections (b )(1)
or, (b )(2), and subsection (b )(3) of this Section,
notify the Agency in writing
of such change. Such notification shall
include a demonstration of compliance with the newly applicable
subsection;
5.
The Illinois EPA proposes amending Section 2181219.187(g) by clarifying when testing
pursuant
to such Section shall be performed.
Section
218.
187(g)(1) and (2):
g)
Testing Requirements.
I)
Testing to demonstrate compliance with the requirements of this
Section shall be conducted by the owner or operator within 90 days
after a request by the Agency, or as otherwise specified in this
Section. Such testing shall be conducted at the expense
of the
owner or operator and the owner or operator shall notify the
Agency in writing 30 days in advance of conducting such testing to
allow the Agency to be present during such testing;
2)
Testing to demonstrate compliance with the
YOM content
limitations in Section 218.187(b)(l) ofthis Subpart, and to
determine the YOM content of cleaning solvents and cleaning
3
solutions, shall be conducted HpaR TeEtHest afthe AgeRsy, as
follows:
Section 219.187(g)(1)
and (2):
g)
Testing Requirements.
I)
Testing to demonstrate compliance with the requirements
of this
Section shall be conducted by the owner or operator within 90 days
after a request by the Agency, or as otherwise specified
in this
Section. Such testing shall be conducted at the expense
of the
owner
or operator and the owner or operator shall notify the
Agency in writing
30 days in advance of conducting such testing to
allow the Agency to
be present during such testing;
2)
Testing to demonstrate compliance with the
YOM content
limitations in Section 219.l87(b)(1)
of this Subpart, and to
determine the
YOM content of cleaning solvents and cleaning
solutions, shall be conducted
HpaR TeEtHes! aftlle Ag8RSY, as
follows:
Flexible Packaging Printing
6.
In
response to a request by industry representatives, the Illinois EPA proposes amending
Section
218/219.404(b)(1)(B)
and (d)(l)(D) by deleting references to instruments by which
owner or operators
may calculate the volume or weight of coatings and inks as applied each day
on subject coating lines, as such instrumentation is not currently available to sources.
Section 218/219.404(b)(1)(B):
B)
Calculations which demonstrate that total maximum theoretical emissions
ofVOM from all flexographic and rotogravure printing lines at the source
never exceed 90.7 Mg (100 tons) per calendar year before the application
of capture systems and control devices. Total maximum theoretical
emissions
ofVOM for a flexographic or rotogravure printing source is the
sum
of maximum theoretical emissions ofVOM from each flexographic
and rotogravure printing line at the source. The following equation shall
be used to calculate total maximum theoretical emissions
ofVOM per
calendar year before the application
of capture systems and control
devices for each flexographic and rotogravure printing line at the source:
Ep
=
A x B + 1095 (C x D x F)
4
Electronic Filing - Received, Clerk's Office, September 14, 2009
where:
Ep
=
Total maximum theoretical emissions ofVOM from one
flexographic
or rotogravure printing line in units ofkglyear
(lbs/year);
A
=
Weight ofVOM per volume of solids of the coating or ink with the
highest
YOM content as applied each year on the printing line in
units
of kg VOM/I (Ibs YOM/gal) of coating or ink solids;
B
=
Total volume of solids for all coatings and inks that can potentially
be applied
each year on the printing line in units of lIyear
(gal/year). The
instrument aaEliar method by which the owner or
operator accurately measllred sr calculated the volume of each
coating and ink as applied and the amount that can potentially
be
applied each year on the printing line shall be described in the
certification to the Agency;
C
=
Weight ofVOM per volume of material for the cleanup material or
solvent with the highest YOM content as used each year on the
printing line in units
ofkgll
(Ibs YOM/gal) of such material;
D
=
The greatest volume of cleanup material or solvent used in any 8-
hour period and
F
=
The highest fraction of cleanup material or solvent which is not
recycled
or recovered for offsite disposal during any 8-hour period.
Section 2181219.404(d)(1)(D):
D)
The instFllHleHt sr method by which the owner or operator will accurately
HleasllFe ar calculate the volume, or weight of solids, as applicable, of
each coating and ink as applied each day on each printing line.
7.
In
response to a comment by industry representatives, the Illinois EPA recommends
amending Section 218/219.404(f)(2)
by removing the requirement that a source include in its
notification to the Illinois
EPA calculations showing an exceedance of the applicability
threshold.
Section 2181219.404(j)(2):
2)
Notify the Agency in writing if the combined emissions ofVOM from all
flexographic and rotogravure printing lines (including inks and solvents
5
Electronic Filing - Received, Clerk's Office, September 14, 2009
used for cleanup operations associated with the flexographic and
rotogravure lines) at the source ever equal or exceed 6.8 kg/day (15
Ibs/day), in the absence
of air pollution control equipment, within 30 days
after the event occurs.
Slleh netilieatien shall ineilH'le ealelliatiens
shewing the daily
emissisns sf VOM frem all fleJ[sgflll3hie and
retegravllre printing lines
at the SSllfee fer the day(s) in whieh emissisns
eEtllaled sr exeeeded 8.8 kg/day (1 § l13s/day).
Lithographic Printing
8.
The Illinois EPA proposes amending Section 218/219.405(c) by deleting references to
Section
2181219.408
that were inadvertently left in the rule, as the Illinois EPA is proposing to
repeal Section
2181219.408.
Section 218.405(c):
c)
On and after May 1, 2010:
1)
The requirements in Sections 218.407(a)(I)(B) through (a)(I)(E)
and 218.407(b) and all applicable provisions in Sections
218.40~&
through 218.411 ofthis Subpart shall apply to all owners or
operators
of heat set web offset lithographic printing line(s), if the
combined emissions
ofVOM from all lithographic printing !ine(s)
at the source (including solvents used for cleanup operations
associated with the lithographic printing
line(s» ever exceed 45.5
kg/day
(100 Ibs/day), calculated in accordance with Section
218.411(b)(2)(B), before the' application
of capture systems and
control devices;
2)
The requirements in Sections
21S.407(a)(I)(A) and 218.407(a)(2)
through (a)(5) and all applicable provisions in Sections
21S.402&
through 218.411 of this Subpart shall apply to all owners or
operators oflithographic printing line(s)
ifthe combined emissions
ofVOM from all lithographic printing !ine(s) at the source
(including solvents used for cleanup operations associated with the
lithographic printing
line(s» ever equal or exceed 6.8 kg/day (15
lbs/day), calculated in accordance with Section 21S.411(b)(1)(B),
before the application
of capture systems and control devices;
Section 219.405(c):
c)
On and after May 1,2010:
6
1)
The requirements in Sections 219.407(a)(1)(B) through (a)(I)(E)
and 219.407(b) and all applicable provisions in Sections
219.402&
through 219.411 of this Subpart shall apply to all owners or
operators
of heat set web offset lithographic printing line(s), if the
combined emissions
ofVOM from all lithographic printing line(s)
at the source (including solvents used for cleanup operations
associated with the lithographic printing !ine(s)) ever exceed 45.5
kg/day
(100 lbs/day), calculated in accordance with Section
219.411 (b)(2)(B), before the application of capture systems and
control devices;
2)
The requirements in Sections 2l9.407(a)(I)(A) and 219.407(a)(2)
through (a)(5) and all applicable provisions
in Sections 219.402&
through 219.411 of this Subpart shall apply to all owners or
operators of lithographic printing line(s) if the combined emissions
ofVOM from all lithographic printing line(s) at the source
(including solvents used for cleanup operations associated with the
lithographic printing line(s)) ever equal
or exceed 6.8 kg/day (15
lbs/day), calculated in accordance with
Section 219.411(b)(1)(B),
before the application of capture systems and control devices;
9.
The Illinois EPA proposes amending Section 2181219.409(a) and (c) by clarifying when
testing pursuant
to such Section shall be performed. The Illinois EPA also proposes amending
subsection (c)
by correcting an internal cross-reference.
Section 21B.409(a) and (c):
a)
Testing to demonstrate compliance with the requirements of Section
218.407 of this Subpart shall be conducted by the owner or operator
within
90 days after a request by the Agency. or as otherwise specified in
this SUbpart. Such testing shall be conducted at the expense of the owner
or operator and the owner or operator shall notify the Agency in writing
30 days in advance of conducting such testing to allow the Agency to be
present during such testing.
c)
Testing to demonstrate compliance with the
YOM content limitations in
Section 218.407(a)(I)(A), (a)(2), (a)(3) and (a)(4)(A) ofthis Subpart, and
to determine the
YOM content of fountain solutions, fountain solution
additives, cleaning solvents, cleaning solutions, and inks (pursuant to the
requirements
of Section 2l8.411(a)(I)(B). (b)(1)(Bt or (b)(2)(B) ofthis
Subpart, as applicable), shall be conducted upon request of the Agency, or
as otherwise specified in this Subpart, as follows:
7
Section 219.409(a) and (c):
a)
Testing to demonstrate compliance with the requirements of Section
219.407 ofthis Subpart shall be conducted by the owner or operator
within 90 days after a request by the Agency, or as otherwise specified in
this Subpart. Such testing shall be conducted at the expense
of the owner
or operator and the owner or operator shall notify the Agency in writing
30 days in advance of conducting such testing to allow the Agency to be
present during such testing.
c)
Testing to demonstrate compliance with the
YOM content limitations in
Section 219.407(a)(1)(A), (a)(2), (a)(3) and (a)(4)(A)
of this Subpart, and
to determine the YOM content offountain solutions, fountain solution
additives, cleaning solvents, cleaning solutions, and inks (pursuant to the
requirements
of Section 219.411(a)(I)(B), (b)(1)(B), or (b)(2)(B) of this
Subpart, as applicable), shall
be conducted upon request of the Agency, or
as otherwise specified in this Subpart, as follows:
10.
The Illinois EPA proposes adding, and amending, Section 218/219.410 to the ru1emaking
proposal. In response to a comment from industry representatives, the Illinois EPA has
discovered several incorrect internal cross-references within the current Section
2181219.410.
The Illinois EPA therefore proposes amending subsections (b)(I), (b)(2), (e)(I)(B), and (e)(2) to
correct the cross-references. As 218/219.410 is an existing section, only the Illinois
EPA's
proposed amendments are underlined below.
Section
218.410
Monitoring Requirements for Lithographic Printing
a)
Fountain Solution Temperature.
I)
. The owner or operator of any lithographic printing line(s) relying on the
temperature of the fountain solution to demonstrate compliance shall
install, maintain, and continuously operate a temperature monitor of the
fountain solution in the reservoir or fountain tray, as applicable.
2)
The temperature monitor must be capable of reading with an accuracy of
IOe or 2°e, and must be attached to an automatic, continuous recording
device such as a strip chart, recorder, or computer, with at least the same
accuracy, that is installed, calibrated and maintained in accordance with
8
the manufacturer's specifications. Ifthe automatic, continuous recording
device malfunctions, the owner or operator shall record the temperature of
the fountain solution at least once every two operating hours. The
automatic, continuous recording device shall be repaired or replaced as
soon as practicable.
b)
Fountain Solution YOM Content. The owner or operator of any lithographic
printing line(s) subject to Section 218.407(a)(1)(A), (a)(2) or (a)(3)
of this
Subpart shall:
I)
For a fountain solution to which YOM is not added automatically:
A)
Maintain records
of the YOM content of the fountain solution in
accordance with Section
218.411~)(2)(C);
or
B)
Take a sample ofthe as-applied fountain solution from the fountain
tray or reservoir, as applicable, each time a fresh batch of fountain
solution is prepared or each time
YOM is added to an existing
batch of fountain solution in the fountain tray or reservoir, and
shall determine compliance with the YOM content limitation of the
as-applied fountain solution by using one
of the following options:
i)
With a refractometer or hydrometer with a visual, analog,
or digital readout and with an accuracy
of 0.5 percent. The
refractometer or hydrometer must be calibrated with a
standard solution for the type ofVOM used in the fountain
solution, in accordance with manufacturer's specifications,
against measurements performed to determine compliance.
The refractometer or hydrometer must be corrected for
temperature at least once per 8-hour shift or once per batch
of fountain solution prepared or modified, whichever is
longer; or
ii)
With a conductivity meter
if it is demonstrated that a
refractometer and hydrometer cannot distinguish between
compliant and noncompliant fountain solution for the type
and amount
ofVOM in the fountain solution. A source
may use a conductivity meter if it demonstrates that both
hydrometers and refractometers fail to provide significantly
different measurements for standard solutions containing
95 percent, 100 percent and 105 percent ofthe applicable
YOM content limit. The conductivity meter reading for the
fountain solution must be referenced to the conductivity of
the incoming water. A standard solution shall be used to
calibrate the conductivity meter for the type ofVOM used
9
Electronic Filing - Received, Clerk's Office, September 14, 2009
in the fountain solution, in accordance with manufacturer's
specifications;
2)
For fountain solutions to which YOM is added at the source with
automatic feed equipment, determine the YOM content of the as-applied
fountain solution based on the setting
of the automatic feed equipment
which makes additions
ofVOM up to a pre-set level. Records must be
retained of the YOM content of the fountain solution in accordance with
Section
21S.411(~)(2)(D)
of this Subpart. The equipment used to make
automatic additions must be installed, calibrated, operated and maintained
in accordance with manufacturer's specifications.
c)
Afterburners For Heatset Web Offset Lithographic Printing Line(s).
If an afterburner is used to demonstrate compliance, the owner or operator of a
heatset web offset lithographic printing line subject to Section 2IS.407(a)(I )(C)
of this Subpart shalJ:
1)
InstalJ, calibrate, maintain, and operate temperature monitoring device(s)
with an accuracy of 3° C or 5° F on the afterburner in accordance with
Section 21S.105(d)(2)
of this Part and in accordance with the
manufacturer's specifications. Monitoring shalJ be performed at
alJ times
when the afterburner is operating; and
2)
InstalJ, calibrate, operate and maintain, in accordance with manufacturer's
specifications, a continuous recorder on the temperature monitoring
device( s), such as a strip chart, recorder or computer, with at least the
same accuracy as the temperature monitor.
d)
Other Control Devices for Heatset Web Offset Lithographic Printing Line(s). If a
control device other than an afterburner is used to demonstrate compliance, the
owner or operator
of a heatset web offset lithographic printing line subject to this
Subpart shall instalJ, maintain, calibrate and operate such monitoring equipment
as set forth in the owner or operator's plan approved by the Agency and USEP A
pursuant
to Section 21S.407(b) ofthis Subpart.
e)
Cleaning Solution.
I)
The owner or operator of any lithographic printing line relying on the
YOM content ofthe cleaning solution to comply with Section
21S.407(a)(4)(A)
of this Subpart must:
A)
For cleaning solutions that are prepared at the source with
equipment that automatically mixes cleaning solvent and water (or
other non-YOM):
10
Electronic Filing - Received, Clerk's Office, September 14, 2009
i)
Install, operate, maintain, and calibrate the automatic feed
equipment in accordance with manufacturer's specifications
to regulate the volume
of each ofthe cleaning solvent and
water (or other
non-YOM), as mixed; and
B)
ii)
Pre-set the automatic feed equipment so that the
consumption rates
ofthe cleaning solvent and water (or
other
non-YOM), as applied, comply with Section
218.407(a)(4)(A) of this Subpart;
For cleaning solutions that are not prepared at the source with
automatic feed equipment, keep records
of the usage of cleaning
solvent and water (or other
non-YOM) as set forth in Section
218.411(fd)(2) ofthis Subpart.
2)
The owner
or operator of any lithographic printing line relying on the
vapor pressure
of the cleaning solution to comply with Section
218.407(a)(4)(B) of this Subpart must keep records for such cleaning
solutions used on any
such line(s) as set forth in Section 218.411(fd)(2)(C)
of this Subpart.
(Source: Amended at _
III.
Reg. __ , effective
)
Section 219.410
Monitoring Requirements for Lithographic Printing
a)
Fountain Solution Temperature.
1)
The owner or operator of any lithographic printing line(s) relying on the
temperature
ofthe fountain solution to demonstrate compliance shall
install, maintain, and continuously operate a temperature monitor
of the
fountain solution in the reservoir
or fountain tray, as applicable.
2)
The temperature monitor must be capable of reading with an accuracy of
1°C or 2°F and must be attached to an automatic, continuous recording
device such
as a strip chart, recorder, or computer, with at least the same
accuracy, that is installed, calibrated and maintained in accordance with
the manufacturer's specifications.
If the automatic, continuous recording
device malfunctions, the owner or operator shall record the temperature
of
the fountain solution at least once every two operating hours. The
automatic, continuous recording device shall
be repaired or replaced as
soon as practicable.
b)
Fountain Solution
YOM Content. The owner or operator of any lithographic
printing line(s) subject to
Section 219.407(a)(I)(A), (a)(2) or (a)(3) of this
Subpart shall:
11
I)
For a fountain solution to which YOM is not added automatically:
A)
Maintain records
of the YOM content ofthe fountain solution in
accordance with Section
219.411(~6)(2)(C);
or
B)
Take a sample
ofthe as-applied fountain solution from the fountain
tray or reservoir, as applicable, each time a fresh batch
of fountain
solution is prepared or each time
YOM is added to an existing
batch
of fountain solution in the fountain tray or reservoir, and
shall determine compliance with the
YOM content limitation of the
as-applied fountain solution by using one of the following options:
i)
With a refractometer or hydrometer with a visual, analog,
or digital readout and with an accuracy of 0.5 percent. The
refractometer or hydrometer must be calibrated with a
standard solution for the type ofVOM used in the fountain
solution, in accordance with manufacturer's specifications,
against measurements performed to determine compliance.
The refractometer or hydrometer must
be corrected for
temperature at least once per 8-hour shift or once per batch
of fountain solution prepared or modified, whichever is
longer; or
ii)
With a conductivity meter
if it is demonstrated that a
refractometer and hydrometer cannot distinguish between
compliant and noncompliant fountain solution for the type
and amount ofVOM in the fountain solution. A source
may use a conductivity meter
if it demonstrates that both
hydrometers and refractometers fail to provide significantly
different measurements for standard solutions containing
95 percent, 100 percent and 105 percent of the applicable
YOM content limit. The conductivity meter reading for the
fountain solution must
be referenced to the conductivity of
the incoming water. A standard solution shall be used to
calibrate the conductivity meter for the type
of YOM used
in the fountain solution, in accordance with manufacturer's
specifications;
2)
For fountain solutions
to which YOM is added at the source with
automatic feed equipment, determine the YOM content of the as-applied
fountain solution based on the setting of the automatic feed equipment
which makes additions ofVOM up to a pre-set level. Records must be
retained of the YOM content ofthe fountain solution in accordance with
Section
219.411~)(2)(D)
of this Subpart. The equipment used to make
automatic additions must
be installed, calibrated, operated and maintained
in accordance with manufacturer's specifications.
12
c)
Afterburners For Heatset Web Offset Lithographic Printing Line(s).
If an afterburner is used to demonstrate compliance, the owner or operator of a
heatset web offset lithographic printing line subject to Section 219.407(a)(1)(C)
of this SUbpart shall:
1)
Install, calibrate, maintain, and operate temperature monitoring device( s)
with an accuracy
of 3°C or SOF on the afterburner in accordance with
Section 219.10S(d)(2)
of this Part and in accordance with the
manufacturer's specifications. Monitoring
shall be performed at all times
when the afterburner is operating; and
2)
Install, calibrate, operate and maintain, in accordance with manufacturer's
specifications, a continuous recorder on the temperature monitoring
device(s), such as a strip chart, recorder
or computer, with at least the
same accuracy as the temperature monitor.
d)
Other Control Devices for Heatset Web Offset Lithographic Printing Line(s). If a
control device other than an afterburner is used to demonstrate compliance, the
owner
or operator of a heatset web offset lithographic printing line subject to this
Subpart shall install, maintain, calibrate and operate such monitoring equipment
as set forth
in the owner or operator's plan approved by the Agency and USEP A
pursuant to Section 219.407(b)
of this Subpart.
.
e)
Cleaning Solution.
1)
The owner or operator of any lithographic printing line relying on the
YOM content of the cleaning solution to comply with Section
219.407(a)(4)(A)
of this Subpart must:
A)
For cleaning solutions that are prepared at the source with
equipment that automatically mixes cleaning solvent and water (or
other non-YOM):
i)
Install, operate, maintain, and calibrate the automatic feed
equipment in accordance with manufacturer's specifications
to regulate the volume
of each ofthe cleaning solvent and
water (or other non-YOM), as mixed; and
ii)
Pre-set the automatic feed equipment so that the
consumption rates
of the cleaning solvent arid water (or
other non-YOM), as applied, comply with Section
219.407(a)(4)(A)
ofthis Subpart;
13
Electronic Filing - Received, Clerk's Office, September 14, 2009
B)
For cleaning solutions that are not prepared at the source with
automatic feed equipment, keep records
ofthe usage of cleaning
solvent and water (or other non-YOM)
as set forth in Section
219.41 I (fd)(2) of this Subpart.
2)
The owner
or operator of any lithographic printing line relying on the
vapor pressure
of the cleaning solution to comply with Section
219.407(a)(4)(B) of this Subpart must keep records for such cleaning
solutions used on any such line(s) as set forth in Section 219.41
I
(fd)(2)(C)
of this Subpart.
(Source: Amended at _
TIl.
Reg. __ , effective
)
11.
The Illinois
EPA recommends amending Section 218/219.411(a)(1)(C) by deleting
references to instruments
by which owners or operators may calculate the volume of inks as
applied each day
on subject printing lines, as such instrumentation is not currently available to
sources.
Section 2J8/219.4JJ(a)(J)(C):
C)
Either a declaration that the source, through federally enforceable permit
conditions, has limited its maximum theoretical emissions
of YOM from
all heatset web offset lithographic printing lines (including solvents used
for cleanup operations associated with heatset web offset printing lines) at
the source to no more than
90.7 Mg (100 tons) per calendar year before
the application
of capture systems and control devices or calculations
which demonstrate that the source's total maximum theoretical emissions
of YOM do not exceed 90.7 Mglyr (100 TPY). Total maximum
theoretical emissions
of YOM for a heatset web offset lithographic
printing source is the sum
of maximum theoretical emissions of YOM
from each heatset web offset lithographic printing line at the source. The
following equation shall be used to calculate total maximum theoretical
emissions
of YOM per calendar year in the absence of air pollution control
equipment for each heatset web offset lithographic printing line at the
source:
Ep
=
(R x A x B) + (C x D) + 1095 (F x G x H)
Where:
Ep
=
Total maximum theoretical emissions ofVOM from one heatset
web offset printing line
in units ofkglyr (lb/yr);
14
A
=
Weight ofVOM per volume of solids of ink with the highest YOM
content as applied each year on the printing line in units of kg/I
(Ib/gal)
of solids;
B
=
Total volume of solids for all inks that can potentially be applied
each year on the printing line in units
of l/yr (gal/yr). The
instrument ar method by which the owner or operator accurately
mea5lH'ee ar calculated the volume of each ink as applied and the
amount that can potentially be applied each year on the printing
line shall be described in the certification to the Agency;
C
=
Weight ofVOM per volume offountain solution with the highest
YOM content as applied each year on the printing line in units of
kg/I (Ib/gal);
D =
The total volume of fountain solution that can potentially be used
each year on the printing line in units
of J/yr (gal/yr). The
instrliHleBt amller method by which the owner or operator
accurately
mea5lH'ee ar calculated the volume of each fountain
solution used and the amount that can potentially be used each year
on the printing line shall be described in the certification to the
Agency;
12.
The Illinois
EPA proposes amending Section
2181219
.411 (b) by changing the material
use thresholds for lithographic printing lines.
USEP A previously recommended that material use
thresholds for such lines be conservatively based
on 50 percent of the pound per day
applicability threshold.
USEPA has now determined that a 90 percent emission equivalency
level is acceptable for both lithographic and letterpress printing operations. The following
amendments reflect the
90 percent equivalency level for lithographic printing lines.
Section 218/219.4JJ(b)(J)(C)(i) and (b)(J)(C)(ii):
C)
As an alternative to the calculations in subsection (b)(1 )(B), above, a
statement that the source uses less than the amount
of material specified in
subsections (b)(1 )(C)(i)
or (ii), below, as applicable, during each calendar
month. A source may determine that it emits below
6.8 kg/day (15
lbs/day)
ofVOM based upon compliance with such material use
limitations.
If the source exceeds this amount of material use in a given
calendar month, the owner
or operator must, within 15 days of the end of
that month, complete the emissions calculations of subsection (b )(I)(B) to
determine daily emissions for applicability purposes.
If the source ever
15
exceeds this amount of material use for six consecutive calendar months, it
is no longer eligible to use this subsection as an alternative to the
calculations in subsection (b)(I)(B).
Ifa source has both heatset web offset
and either nonheatset web offset
or sheetfed lithographic printing
operations, or has all three types
of printing operations, the owner or
operator may not make use of this alternative and must use the
calculations in subsection (b)(I )(B).
i)
The sum
of all sheetfed and nonheatset web offset lithographic
printing operations at the source:
242.3~
liters ((Lill gallons)
of cleaning solvent and fountain solution additives, combined; or
Ii)
The sum of all heatset web offset lithographic printing operations
at the source:
204.l+H4 kg
(45~
lbs) of ink, cleaning solvent,
and fountain solution additives, combined.
13.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending
Section 2ISl2l9.411(b)(I)(E) by removing the requirement that a source include in its
notification to the Illinois EPA calculations showing an exceedance
ofthe applicability
threshold.
Section 218.411(b)(J)(E):
E)
For sources complying with subsection (b)(I)(B)
ofthis Section, notify the
Agency in writing if the combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines)
at the source ever equal
or exceed 6.S kg/day (IS lbs/day), before the use
of capture systems and control devices, within 30 days after the event
occurs.
Slleh HstifieatisH shall iaeillee ealelliatisas jlllTSllaHt ts Seetisa
218.411Eb)(1)(B) shswiHg tbe eaily
emissisHs efVOM fFem all
lithsgHlflhie jlflHtillg lillss at ilie seUf€S fer the mellth ill whish emissislls
equalee
ST eJ,eeeeee e.8Iq;ifeay (IS las/eay). If such emissions ofVOM
at the source equal or exceed 6.S kg/day (IS lbs/day) but do not exceed
45.5 kg/day
(100 lbs/day), the source shall comply with the requirements
in subsection (b)(2)
of this Section.
Section 219.411(b)(1)(E):
E)
For sources complying with subsection (b)(I)(B)
of this Section, notify the
Agency in writing
if the combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines)
16
Electronic Filing - Received, Clerk's Office, September 14, 2009
at the source ever equal or exceed 6.8 kg/day (IS lbs/day), before the use
of capture systems and control devices, within 30 days after the event
occurs.
Sasa netifisatien saall inslade ealsalatiells pllfsaaHt te Sestien
219.411(b)(I)(B) saewing fue daily emissiens
efYOM fFem aJl
litaegrapaie printing lines at fue seaFse reF fue FIIenfu in '),<hiea eFIIissiells
eEJ:llaled eF eJ(eeeded e.8
k~ay
(15 les,lday). If such emissions ofVOM
at the source equal or exceed 6.8 kg/day (IS lbs/day) but do not exceed
45.5 kg/day (100 lbs/day), the source shall comply with the requirements
in subsection (b )(2)
of this Section.
14.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending Section 218/219.41
I (b)(2)(D) by removing the requirement that a source include in its
notification to the Illinois
EPA calculations showing an exceedance ofthe applicability
threshold.
Section 218.4J1(b)(2)(D):
D)
Notify the Agency in writing if the combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines)
at the source ever exceed 45.5 kg/day
(100 lbs/day), before the use of
capture systems and control devices, within 30 days after the event occurs.
Suea nstifisatien saall inslude ealsulatiens pllFsaaHl te Sestien
218.411(b)(2)(B) saewing
fue daily emissiens efYOM fFem all
lifuegrapaie printing lines at tae seame {eF fue FIIenfu
ill
wflisa emissiens
el(eeeded45.s kWd&)' (199 les/day).
Section 219.411(b)(2)(D):
D)
Notify the Agency in writing if the combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines)
at the source ever exceed 45.5 kg/day (100 lbs/day), before the use
of
capture systems and control devices, within 30 days after the event occurs.
Sueh netifieatien saall ineillde salslliatiens pUFsaaHt te Seetien
219.411(e)(2)(B) shewing fue daily emissiens efVOM £rem all
lifuegrapflie printing lines at fue seaFse reF the FIIeHtfl in , .... hiea eFllissiens
ellseeded 45.5
kwday (199 leslda-)0.
15.
In
response to a request by industry representatives, the Illinois EPA proposes amending
Section 218/219.41
I (f)(2)(B) and (f)(2)(C) by specifying that, for cleaning solutions used as-
17
Electronic Filing - Received, Clerk's Office, September 14, 2009
purchased, sources may use manufacturer's specifications to determine YOM content and YOM
composite partial vapor pressure.
Section 218.411(j)(2)(B)(v), (j)(2)(C)(iii), and (j)(2)(C)(v):
B)
For each batch of cleaning solution for which the owner or operator relies
on the
YOM content to demonstrate compliance with Section
2IS.407(a)(4)(A) ofthis Subpart, and which is not prepared at the source
with automatic equipment:
v)
The YOM content of the as-used cleaning solution, with
supporting calculations. For cleaning solutions that are used as
purchased, the manufacturer's specifications for YOM content may
be used if such manufacturer's specifications are based on results
of tests of the YOM content conducted in accordance with methods
specified in Section 2IS.105(a) of this Part;
C)
For each batch of cleaning solution for which the owner or operator relies
on the vapor pressure
of the cleaning solution to demonstrate compliance
with Section 218.407(a)(4)(B)
ofthis Subpart:
iii)
The molecular weight, density, and
YOM composite partial vapor
pressure
of each cleaning solvent, as determined in accordance
with Section 218.409(e) ofthis Subpart. For cleaning solutions
that are used as purchased, the manufacturer's specifications for
YOM composite partial vapor pressure may be used if such
manufacturer's specifications are based on results of tests
conducted in accordance with methods specified in Sections
2IS.105(a) and 21S.l10 of this Part;
iv)
The total amount of each cleaning solvent used to prepare the as-
used cleaning solution; and
v)
The YOM composite partial vapor pressure of each as-used
cleaning solution, as determined
in
accordance with Section
2IS.409(e) of this Subpart. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM composite
partial vapor pressure may
be used if such manufacturer's
specifications are based on results
oftests conducted in accordance
with methods specified in Sections 21S.105(a) and 218.110 of this
Part;
IS
Section
219.411
(f)(2)(B)(v), (f)(2)(C)(iii), and (f)(2)(C}(v):
B)
For each batch of cleaning solution for which the owner or operator relies
on the
YOM content to demonstrate compliance with Section
219.407(a)(4)(A) of this Subpart, and which is not prepared at the source
with automatic equipment:
v)
The
YOM content ofthe as-used cleaning solution, with
supporting calculations. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM content may
be used if such manufacturer's specifications are based on results
of tests of the YOM content conducted in accordance with methods
specified
in Section 219.105(a) of this Part;
C)
For each
batch of cleaning solution for which the owner or operator relies
on the vapor pressure of the cleaning solution to demonstrate compliance
with Section
219.407(a)(4)(B) of this Subpart:
iii)
The molecular weight, density, and
YOM composite partial vapor
pressure
of each cleaning solvent, as determined in accordance
with Section
219.409(e) of this Subpart. For cleaning solutions
that are used as purchased, the manufacturer's specifications for
YOM composite partial vapor pressure may be used if such
manufacturer's specifications are based on results
of tests
conducted in accordance with methods specified
in Sections
219.l05(a) and 219.ll0 of this Part;
iv)
The total amount
of each cleaning solvent used to prepare the as-
used cleaning solution; and
v)
The
YOM composite partial vapor pressure of each as-used
cleaning solution, as determined in accordance with Section
219.409(e) of this Subpart. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM composite
partial vapor pressure
may be used if such manufacturer's
specifications are based on results
of tests conducted in accordance
with methods specified in Sections
219.l05(a) and 219.110 of this
Part;
19
Electronic Filing - Received, Clerk's Office, September 14, 2009
16.
In
response to a request by industry representatives, the Illinois EPA proposes amending .
Section
2181219.41 I (g)(2)(A) to correct a grammar mistake.
Section
218/219.411
(g)(2)(A)(ii):
ii)
The amount of cleaning materials used on lithographic printing lines at the
source that does not comply with the cleaning material limitations in
Section 218.407(a)(4)
of this Subpart.
17.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending Section
218/219.41
I
(g)(2)(B) by removing the requirement that a source include in its
notification to the Illinois EPA calculations showing an exceedance
of the applicability
threshold.
Section
218.411
(g)(2)(B):
B)
Notify the Agency in writing ifthe combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines) .
at the source ever exceed 45.5 kg/day
(100 lbs/day), before the use of
capture systems and control devices, within 30 days after the event occurs.
SlIeh HetifieatisH shall iHehule ealelilatiaHs PlIfSlIaat te SeetieH
218.411E!J)(2)(B) shawiHg
tAe saily eHlissiaHs efVOM weHl all
lithegFilfll1ie pRHtiHg Imes at the sallfee fer the HleHtA iH v.bieh eHlissieHs
elleeeses 43.3 ktifsay
(100
les/day).
Section
219.411
(g)(2)(B):
B)
Notify the Agency in writing if the combined emissions ofVOM from all
lithographic printing lines (including inks, fountain solutions, and solvents
used for cleanup operations associated with the lithographic printing lines)
at the source ever exceed 45.5 kg/day
(100 lbs/day), before the use of
capture systems and control devices, within 30 days after the event occurs.
SlIsh HatifieatieH shall iHsllise salelilatieHs plIrsliaHt te SeetieH
219.411 E!J)(2)(B) shewiHg the saily eHlissieHs ef'lOM waHl all
lithegFilfll1ie priHtiHg liHes at tAe sellfee fer the HlentA iH whieh 8H1issiens
8lfseeses 43.3 ktifsay
(100
leslsQ)0.
20
\
,
Letterpress Printing:
18.
In
response to a request by industry representatives, the Illinois EPA proposes amending
Section 218/219.415(a) and (c) by clarifying when testing pursuant to such Section shall be
performed.
Section 218.415(a) and (c):
a)
Testing to demonstrate compliance with the requirements of Section
218.413 of this Subpart shall be conducted by the owner or operator
within
90 days after a request by the Agency, or as otherwise specified in
this Subpart.
Such testing shall be conducted at the expense of the owner
or operator, and the owner or operator shall notify the Agency in writing
30 days in advance of conducting such testing to allow the Agency to be
present during such testing.
c)
Testing to demonstrate compliance with the YOM content limitations in
Section 218.413(a)(2)(A) of this Subpart, and to determine the YOM
content of cleaning solvents, cleaning solutions, and inks (pursuant to the
requirements
of Section 218.417(b)(I)(B) of this Subpart), shall be
conducted upon request
of the Agency, or as otherwise specified in this
Subpart,
as follows:
Section 219.415(a) and (c):
a)
Testing to demonstrate compliance with the requirements of Section
219.413 of this Subpart shall be conducted by the owner or operator
within 90 days after a request by the Agency, or as otherwise specified in
this Subpart.
Such testing shall be conducted at the expense of the owner
or operator, and the owner or operator shall notify the Agency in writing
30 days in advance of conducting such testing to allow the Agency to be
present during such testing.
c)
Testing
to demonstrate compliance with the YOM content limitations in
Section 219.413(a)(2)(A) of this Subpart, and to determine the YOM
content of cleaning solvents, cleaning solutions, and inks (pursuant to the
requirements
of Section 219.417(b)(I)(B) of this Subpart), shall be
conducted upon request
of the Agency, or as otherwise specified in this
Subpart, as follows:
21
Electronic Filing - Received, Clerk's Office, September 14, 2009
. 19.
The Illinois EPA proposes amending Section
2181219.417(b)(I)
by changing the material
use thresholds for letterpress printing lines. USEP A previously recommended that material use
thresholds for lithographic printing lines be conservatively based on
50 percent ofthe pound per
day applicability threshold. USEP A has now determined that a
90 percent emission equivalency
level is acceptable for both lithographic and letterpress printing operations. The following
amendments reflect the
90 percent equivalency level for letterpress printing lines.
Section 218/219.417(b)(l)(D)(i) and (b)(J)(D)(ii):
D)
As an alternative to the calculations in subsection (b )(1 )(B), above, a
statement that the source uses less than the amount of material specified in
subsections (b)(I)(D)(i) or (b)(l)(D)(ii), below, as applicable, during each
calendar month. A source may determine that it emits below
6.S kg/day
(15Ibs/day)
ofVOM based upon compliance with such material use
limitations.
If the source exceeds this amount of material use in a given
calendar month, the owner or operator must, within 15 days of the end of
that month, complete the emissions calculations of subsection (b)(l)(B) to
determine daily emissions for applicability purposes. If the source ever
exceeds this amount of material use for six consecutive calendar months, it
is no longer eligible to use this subsection as an alternative
to the
calculations in subsection (b)(1 )(B). If a source has both heatset web and
either nonheatset web or sheetfed letterpress printing operations, or has all
three types
of printing operations, the owner or operator may not make use
of this alternative and must use the calculations in subsection (b)(1)(B).
i)
The sum of all sheetfed and nonheatset web letterpress printing
operations at the source:
242.3~
liters
(6~
gallons) of
cleaning solvent; or
ii)
The sum
of all heatset web letterpress printing operations at the
source: 204.1.J+h4 kg
(45~
lbs) of ink and cleaning solvent.
20.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending Section 21S/219.417(b)(2)
by removing the requirement that a source include in its
notification to the Illinois EPA calculations showing an exceedance
of the applicability
threshold.
Section 218.417(b)(2):
22
Electronic Filing - Received, Clerk's Office, September 14, 2009
2)
For sources complying with subsection (b )(1 )(B) of this Section, notify the
Agency in writing
if the combined emissions of YOM from all letterpress
printing lines (including inks and solvents used for cleanup operations
associated with the letterpress printing lines) at the source ever equal or
exceed 6.8 kg/day
(IS Ibs/day), in the absence of air pollution control
equipment, within
30 days after the event occurs. SlIefl netifieatien sRall
ineillee ealeHlatiens pllrsllaHt
te Seetien 218.417(ll)(1 )(B) sRewing tRe
eaily emissiens ef'lOM frem all letterpress printing lines at tee sellf6e fer
the mentR in wilieh enHssisns eEtllalee sr e)[eeeeee a.8 kweay (15
Ills/eay).
Section 219.417(b)(2):
2)
For sources complying with subsection (b)(l)(B) of this Section, notify the
Agency
in writing if the combined emissions of YOM from aJlletterpress
printing lines (including inks and solvents used for cleanup operations
associated with the letterpress printing lines) at the source ever equal
or
exceed 6.8 kg/day (15 Ibs/day), in the absence of air pollution control
equipment, within
30 days after the event occurs. SHeR nstifieatisn sRall
ineiHee ealeHiatisns
pllfSHaHt te Seetisn 219.417(8)(1)(B) sRewing tee
eail)' emissiens efVOM frem all letterpress printing lines at tRe seHree fer
tRe ffientR in whieh emissiens eEtHalee sr eJ[eeeeee a.8 k§fday (15
Ibslda)}
21.
In
response to a comment by industry representatives, the Illinois EPA proposes
amending
Section 218/21 9.41 7(e)(2)(B) and (e)(2)(C) by specifying that, for cleaning solutions
used as-purchased, sources
may use manufacturer's specifications to determine YOM content
and
YOM composite partial vapor pressure.
Section 218.417(e)(2)(B)(v), (e)(2)(C)(iii), and (e)(2)(C)(v):
B)
For each batch of cleaning solution for which the owner or operator relies
on the
YOM content to demonstrate compliance with Section
218.413(a)(2)(A) ofthis Subpart, and which is not prepared at the source
with automatic equipment:
v)
The
YOM content ofthe as-used cleaning solution, with
supporting calculations. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM content may
be used
if
such manufacturer's speci fications are based on results
23
Electronic Filing - Received, Clerk's Office, September 14, 2009
of tests of the YOM content conducted in accordance with methods
specified in Section 218.105(a)
ofthis Part;
C)
For each batch of cleaning solution for which the owner or operator relies
on the vapor pressure
of the cleaning solution to demonstrate compliance
with Section 218.413(a)(2)(B)
ofthis Subpart:
iii)
The molecular weight, density, and
YOM composite partial vapor
pressure of each cleaning solvent, as determined in accordance
with Section 218.415(e)
of this Subpart. For cleaning solutions
that are used as purchased, the manufacturer's specifications for
YOM composite partial vapor pressure may be used if such
manufacturer's specifications are based on results of tests
conducted in accordance with methods specified in Sections
2l8.105(a) and 218.110
of this Part;
iv)
The total amount of each cleaning solvent used to prepare the as-
used cleaning solution; and
v)
The
YOM composite partial vapor pressure of each as-used
cleaning solution, as determined in accordance with Section
2l8.4l5(e) of this Subpart. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM composite
partial vapor pressure may be used
if such manufacturer's
specifications are based on results
oftests conducted in accordance
with methods specified in Sections 218.105(a) and 218.110 of this
Part;
Section 219.417(e)(2)(B)(v), (e)(2)(C)(iii), and (e)(2)(C)(v):
B)
For each batch of cleaning solution for which the owner or operator relies
on the YOM content to demonstrate compliance with Section
219.413(a)(2)(A)
of this Subpart, and which is not prepared at the source
with automatic equipment:
v)
The
YOM content of the as-used cleaning solution, with
supporting calculations. For cleaning solutions that are used as
purchased, the manufacturer's specifications for
YOM content may
be used if such manufacturer's specifications are based on results
of tests of the YOM content conducted in accordance with methods
specified in Section 219.105(a) of this Part;
24
C)
For each batch of cleaning solution for which the owner or operator relies
on the vapor pressure ofthe cleaning solution to demonstrate compliance
with Section 219.413(a)(2)(B)
of this Subpart:
iii)
The molecular weight, density, and
YOM composite partial vapor
pressure
of each cleaning solvent, as determined in accordance
with Section 219.415(e) ofthis Subpart. For cleaning solutions
that are used
as purchased, the manufacturer's specifications for
YOM composite partial vapor pressure may be used if such
manufacturer's specifications are based on results of tests
conducted in accordance with methods specified in Sections
219.105(a) and 219.110
of this Part;
iv)
The total amount of each cleaning solvent used to prepare the as-
used cleaning solution; and
v)
The YOM composite partial vapor pressure of each as-used
cleaning solution, as determined in accordance with Section
219.415(e)
of this Subpart. For cleaning solutions that are used as
purchased, the manufacturer's specifications for YOM composite
partial vapor pressure may be used
if such manufacturer's
specifications are based on results
of tests conducted in accordance
with methods specified in Sections 219.1
05(a) and 219.110 ofthis
Part;
WHEREFORE, for the reasons set forth above, the Illinois EPA moves that the Board
amend
Parts 218 and 219 as set forth herein.
DATED: September 14,
2009
1021 N. Grand Ave. East
P.O. Box 19276
Springfield,
IL
62794-9276
(217) 782-5544
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
an 0LJ
.'{ttlh~
Dana Vetterhoffer
Assistant Counsel
Division
of Legal Counsel
25
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY
AVAILABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLATILE
ORGANIC MATERIAL
EMISSIONS FROM
GROUP
II CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35
ILL.
ADM. CODE 211, 218, and 219
)
)
)
)
)
)
)
)
RI0-8
(Rulemaking-Air)
CERTIFICATE
OF SERVICE
I, the undersigned, an attorney, state that I have served electronically the attached
TESTIMONTY OF DAVID BLOOMBERG and MOTION TO AMEND RULEMAKING
PROPOSAL upon the following person:
John Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph, Suite 11-500
Chicago, lllinois 60601-3218
and electronically to the following persons:
SEE ATTACHED SERVICE LIST.
DATED: September 14, 2009
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-5544
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:C2}?h:),
~¢
.
Dana Vetterhoffer
Assistant Counsel
Division
of Legal Counsel
Electronic Filing - Received, Clerk's Office, September 14, 2009
Timothy J. Fox
Hearing
Officer
Illinois Pollution Control Board
100 W. Randolph St., Suite 11-500
Chicago,
IL
6060 I
foxt@ipcb.state.il.us
Virginia Yang
Deputy Legal Counsel
Service List RIO-8
Illinois Department of Natural Resources
One Natural Resources Way
Springfield,
IL
62702-1271
virginia.yang@illinois.gov
Matthew Dunn, Chief
Division
of Environmental Enforcement
Office of the Attorney General
69
W. Washington St., Suite 1800
Chicago,
IL
60602
mdunn@atg.state.il.us
Electronic Filing - Received, Clerk's Office, September 14, 2009