ILLINOIS POLLUTION CONTROL BOARD
August 8, 2002
IN THE MATTER OF:
PROPOSED HORWEEN LEATHER
COMPANY SITE-SPECIFIC AIR RULE,
35 ILL. ADM.CODE 218.112
35 ILL. ADM CODE 218.929
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R02-20
(Site–Specific
Rulemaking - Air)
Proposed Rule. First Notice.
OPINION AND ORDER OF THE BOARD (by M.E. Tristano)
This matter comes before the Board upon a proposal to amend the Board’s air quality
regulations for organic material emissions in the Chicago area. The proposal was filed by the
Horween Leather Company (Horween). Horween requests that the Board issue a site-specific
rule from 35 Ill. Adm. Code 218.112 and add a new section 218.929 to change the volatile
organic material (VOM) control requirements as applied to a small amount of new specialty
leathers that Horween plans to produce at its facility located at 2015 North Elston Avenue,
Chicago, Illinois. The requested rule change would allow Horween to continue to produce its
existing specialty leather pursuant to existing regulations, and develop new specialty leather
products in compliance with the modified regulation.
By today’s action the Board adopts the proposed amendments for the purpose of first
notice, pursuant to the Illinois Administrative Procedure Act (5 ILCS 100/1-1). Publication in
the Illinois Register will follow Board action, whereupon a 45-day pubic comment period will
begin during which interested persons may file additional public comments with the Board.
PROCEDURAL HISTORY
Horween filed its proposal for rulemaking on February 19, 2002. By order of March
7, 2002, the Board accepted the proposal for hearing. On March 10, 2002, the Board mailed a
request to the Department of Commerce and Community Affairs to perform an economic
impact study on the proposed rulemaking.
A public hearing was held before hearing officer William Murphy in Chicago on June
26, 2002. Horween presented the testimony of Mr. Arnold Horween III and Julie M.
Christensen, Director of Safety and Environmental Compliance. The Illinois Environmental
Protection Agency (Agency) presented the testimony of Mr. Gary E. Beckstead,
Environmental Protection Engineer.
Prior to testimony, Horween through its attorney Mr. Roy Harsch, acknowledged that
the Agency had rewritten the site-specific proposal submitted in February. Horween concurs
2
with the Agency revision with two exceptions and subsequently offered a joint motion for its
substitution for Horween’s original draft. Joint Mo.
BACKGROUND
Horween submitted a petition for relief from technical restraints associated with making
new types of specialty leather. The production requirements of leather that use higher solvent-
based finishes were the subject of Illinois’ original adoption of amendments to the generally
applicable Reasonably Available Control Technology (RACT) leather coating rule (35 Ill.Adm.
Code 218.926 and 211.6170).
In 1994, the Board, after thoroughly evaluating the required production need of
specialty leathers with a high grease, wax, and oil content, adopted a special subcategory for
this “specialty leather.” 35 Ill. Adm. Code 218.926 and 211.6170. The Board rule allows
emission of VOM in the amount of 38 pounds (lbs.) per 1,000 square feet and further provides
an exemption for the stains used on leather. 35 Ill. Adm. Code 218.96. Furthermore, the rule
specifically defines “specialty leather.” 35 Ill. Adm. Code 211.6170. This particular rule was
approved by the United States Environmental Protection Agency (USEPA) and included in the
Illinois State Implementation Plan (SIP). 59 Fed. Reg. 46567 (Oct. 11, 1994).
Horween has identified two types of what it believes to be other “specialty leathers”
that do not meet the current definition under 35 Ill. Adm. Code 211.6170. The first group of
leathers includes a minor change to Horween’s existing CHROMEXCEL specialty leather.
The second group, performance leathers, includes leather previously made by a closed tannery.
This leather is referred to by Horween as “GENTRY.” The Agency’s revision to the proposed
site-specific rule utilizes a more generic approach and does not specify particular names for the
new leathers Horween is planning to coat. Tr. at 59. By utilizing a generic approach, a new
site-specific regulation would not need filing each time the fashion emphasis changes in the
leather industry. Tr. at 59.
Horween evaluated the existing RACT rules to review potential impacts on future
environmental compliance should these new products be produced. Consequently, Horween
realized that, they would not be able to put these new leathers into production and continue to
comply with the existing Illinois RACT rules. Horween maintains that even though the
production of the newly proposed products cannot meet the current RACT rules, there is a
negligible environmental impact from producing these new products. The production of the
new specialty leathers at this facility will replace production that has been lost since 1995 and
would not exceed the VOM emissions from 1995 with an additional 20 ton per year (TPY) cap
on these new specialty leathers. Furthermore, Horween maintains it would not exceed current
emission limits already in place in the facility’s Title V permit and Emissions Reduction
Market System (ERMS) baseline.
PROPOSAL OVERVIEW
Section 218.929- Cementable and Dress or Performance Shoe Leathers
3
Horween has proposed adding Section 218.929 to the Board’s Organic Material
Emission Standards and Limitations for the Chicago Area that sets forth the specific
requirements applicable to certain other specialty leathers outlined within the Section caption.
The Agency has suggested some revisions that are generally agreeable to both parties.
Section 218.929(a) outlines a number of criteria which must be met. Subsection (a) sets
forth:
1) The applicability of the rule that limits all exemptions and volume emission
modification to Horween’s leather manufacturing facility located at 2015 North
Elston Avenue, Chicago, Illinois;
2) VOM emission limits for production of cementable shoe leather with a percent
content of wax, grease, polymer and oils between 12 and 25% by weight that
cannot meet the definition of specialty leathers of 35 Ill. Adm. Code 211.6170;
3) VOM emission limits for production of dress or performance shoe leather finished
with water emulsified coating materials that cannot meet the definition of 35 Ill.
Adm. Code 211.6170;
4) No exemption from the annual 10-ton VOM cap applicable to stains pursuant to
Section 218.926(b)(2)(i).
Section 218.929(b) provides numeric limitations on emissions from the production of
the new leather products. They are 14 lbs. VOM/1,000 square feet for non-water resistant
leathers; 24 lbs. VOM/1,000 square feet of leather produced for water resistant leather; and a
total annual VOM emission limit of 20 tons.
Section 218.929(c) requires compliance with the company’s approved standard
operating and maintenance procedures (SOMP).
Section 218.929(d) outlines reporting and record keeping requirements which are
consistent with the Subpart and Section 39.5 of the Act (415 ILCS 5/39.5) and allows for use
of an equivalent alternative plan if approved by the Agency and the USEPA.
Section 218.112(a)(26) also incorporates by reference ASTM D2099-00 Standard Test
Method for Dynamic Water Resistance of Shoe Upper Leather by the Maeser Water
Penetration Tester as referenced in 218.929(b)(1).
Horween agreed with the Agency revisions to the proposed rulemaking with two
exceptions: 1) the use of high volume low pressure spray guns; and 2) the requirement to
record and report VOM content and gallons of all coatings by category and by batch.
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THE USE OF HIGH VOLUME LOW PRESSURE SPRAY GUNS
To be consistent with the full RACT provisions as approved by USEPA for the Maine
facility, the Agency proposed specific language at Section 218.929(c)(4) which would require
Horween to either convert to HVLP spray guns or document the lack of feasibility or cost
effectiveness for its conversion to the USEPA. Section 218.929(c)(4) sets forth:
A procedure to install and use high volume low pressure (HVLP) spray guns for
the coating of these leathers within one-year after USEPA approves this rule as
a SIP revision or the Company shall document why HVLP spray guns are not a
technically feasible or cost-effective method for applying coating at this facility.
The Agency, through the testimony of Mr. Beckstead, offered that Horween did not
provide sufficient documentation in support of its assertion that they cannot use HVLP spray
guns in their operation. Tr. at 61. Horween argues that Section 172(c)(1) of the Clean Air
Act, 42 USC 7505(c)(1), requires that the State Implementation Plans (SIP) for non-attainment
areas provide for the implementation of reasonably available control measures (RACM)
including emission reductions obtained through the adoption of RACT. The USEPA has
historically defined RACT 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.
See
44 Fed. Reg. 53762 (September 17, 1979).
By
regulation, the Pollution Control Board has adopted the USEPA’s historical definition of
RACT.
See
35 Ill. Adm. Code 211.5370.
Further, Mr. Horween III testified that a brief test was conducted using the HVLP
spray guns suggested by the Agency. Tr. at 65. The results indicated that the specialty leather
produced would not be of sufficient quality to satisfy customer requirements. Mr. Horween
also indicated that the use of the HVLP spray guns would cause the specialty leather to become
a different product which customers would not purchase. Tr. at 66-69. Mr. Beckstead
conceded that the spray technology recommended by the Agency for testing by Horween
currently did not meet the criteria for HVLP spray guns listed in 211.2990 but that the
manufacturer would like to have it classified as such. Tr. at 63-65.
Based upon the evidence presented, the Board finds that HVLP spray guns are not
technically feasible for the specific Horween Company production of specialty leather allowed
by this site-specific rulemaking. Failing to meet the RACT criteria for technological and
economic feasibility contained within 35 Ill. Adm. Code 211.5370, the Board has removed the
corresponding language at Section 218.929(c)(4) from the proposed rule.
THE REQUIREMENT TO RECORD AND REPORT VOM CONTENT AND GALLONS
OF ALL COATINGS BY CATEGORY AND BY BATCH
The current record keeping requirements for application of coatings to specialty leather
require VOM emissions to be tracked by category of leather produced. 35 Ill. Adm. Code
5
218.926(b)(2)(B). Equivalent alternative control plans may be used if approved by the Agency
and USEPA in a federally enforceable permit or as a SIP revision. 35 Ill. Adm. Code
218.926(c). Horween’s current specialty leather production does use an alternative plan. The
alternative plan was submitted in 1996 and approved by the Agency and USEPA. Tr. at 34.
Horween proposes to continue its alternative record keeping practices in this manner for
the new categories of leather proposed in this rulemaking. Tr. at 24-25. Horween proposes to
record the total amount of VOM-containing material “used in a month and divide it amongst
the production of standard leather.” Tr. at 75. Using a percentage based on the square
footage of each category of leather produced in that month, the VOM emissions produced from
each category are estimated. Tr. at 75.
The Agency proposed specific language which would require Horween instead to report
and record VOM content, gallons, and pounds of coatings by each batch of leather
manufactured during each month. The Agency did so based on USEPA’s indication that in
light of the additional categories of leathers, dress or performance water-resistant, dress or
performance non-water-resistant, cementable water-resistant, and cementable non-water-
resistant, that the current procedures were not adequate to verify compliance. Horween objects
to the Agency’s proposed record keeping and reporting requirements, arguing that the existing
system which Horween uses is adequate and has been accepted by both the Agency and
USEPA. Horween argues that under the Agency’s proposal there would be a substantial
modification to the record keeping and reporting procedures that it already follows. Tr. at 33,
37, 60, 61.
Further, Horween maintains that a substantial increase in record keeping would be
required by a batch recording system for a relatively limited amount of VOM compounds and
maximum actual emissions for those compounds per year. Tr. at 73, 79-80. Horween points
out that only two compounds are used on multiple types of leathers manufactured at the
facility, eukesolar dyes and unithane 9107. Tr. at 79-80.
By allowing modification of the finish formulation in this rulemaking, the ability of
Agency and USEPA field inspectors to verify Horween’s monthly estimates of all VOM
containing materials used for each of the new categories of specialty leather becomes of
increasing importance. The Agency’s suggest record keeping requirements “by batch” would
assist in this effort. To the extent that other means may be used to reach this goal of
demonstrating compliance, the Agency’s suggested wording at 218.929(d)(3) provides
Horween the opportunity to propose alternative record keeping procedures to the Agency and
USEPA for approval. Tr. at 60. This is consistent with the Board’s current specialty leather
provisions where the Board has designated that alternative plans are to be approved by the
Agency and the USEPA. 35 Ill. Adm. Code 218.926(c).
The Board finds that the Agency’s request to record and report VOM content and
gallons of all coatings by category and by batch are acceptable and will be included.
6
ECONOMIC IMPACT
The impetus for the Horween proposal is that the adoption of the amendments would
have a beneficial economic impact by allowing them to compete in additional specialty leather
markets. Horween has experienced a significant loss in revenue over the last ten years from
sales of $32 million to $20 million. Tr. at 124-25. They have decreased employment from
almost 200 employees in 1992 to about 140 employees at present. Tr. at 125. The anticipated
increase in sales associated with production of specialty leathers permitted by this site-specific
rule is $2 to $2.5 million per year. Tr. at 125.
CONCLUSION
Based on the record developed to date in this matter, the Board finds that adoption of
the following amendments, as requested by Horween and modified by the Illinois
Environmental Protection Agency, with the exclusion of the Agency’s proposal for the HVLP
spray gun, for the purposes of first notice is warranted. Accordingly, the Board will so order.
ORDER
The Board directs the Clerk to cause the filing of the following with the Secretary of
State for first-notice publication in the
Illinois Register
.
TITLE 35: ENVIRONMENTAL PROTECTION
SUBTITLE B: AIR POLLUTION
CHAPTER I: POLLUTION CONTROL BOARD
SUBCHAPTER c: EMISSIONS STANDARDS AND
LIMITATIONS FOR STATIONARY SOURCES
PART 218
ORGANIC MATERIAL EMISSION STANDARDS AND
LIMITATIONS FOR THE CHICAGO AREA
SUBPART A: GENERAL PROVISIONS
Section
218.100 Introduction
218.101 Savings Clause
218.102 Abbreviations and Conversion Factors
218.103 Applicability
218.104 Definitions
218.105 Test Methods and Procedures
218.106 Compliance Dates
218.107 Operation of Afterburners
218.108 Exemptions, Variations, and Alternative Means of Control or Compliance
Determinations
218.109 Vapor Pressure of Volatile Organic Liquids
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218.110 Vapor Pressure of Organic Material or Solvent
218.111 Vapor Pressure of Volatile Organic Material
218.112 Incorporations by Reference
218.113 Monitoring for Negligibly-Reactive Compounds
218.114 Compliance with Permit Conditions
SUBPART B: ORGANIC EMISSIONS FROM STORAGE AND LOADING
OPERATIONS
Section
218.119 Applicability for VOL
218.120 Control Requirements for Storage Containers of VOL
218.121 Storage Containers of VPL
218.122 Loading Operations
218.123 Petroleum Liquid Storage Tanks
218.124 External Floating Roofs
218.125 Compliance Dates
218.126 Compliance Plan (Repealed)
218.127 Testing VOL Operations
218.128 Monitoring VOL Operations
218.129 Recordkeeping and Reporting for VOL Operations
SUBPART C: ORGANIC EMISSIONS FROM MISCELLANEOUS
EQUIPMENT
Section
218.141 Separation Operations
218.142 Pumps and Compressors
218.143 Vapor Blowdown
218.144 Safety Relief Valves
SUBPART E: SOLVENT CLEANING
Section
218.181 Solvent Cleaning in General
218.182 Cold Cleaning
218.183 Open Top Vapor Degreasing
218.184 Conveyorized Degreasing
218.185 Compliance Schedule (Repealed)
218.186 Test Methods
SUBPART F: COATING OPERATIONS
Section
218.204 Emission Limitations
218.205 Daily-Weighted Average Limitations
218.206 Solids Basis Calculation
218.207 Alternative Emission Limitations
218.208 Exemptions from Emission Limitations
218.209 Exemption from General Rule on Use of Organic Material
8
218.210 Compliance Schedule
218.211 Recordkeeping and Reporting
218.212 Cross-Line Averaging to Establish Compliance for Coating Lines
218.213 Recordkeeping and Reporting for Cross-Line Averaging Participating Coating
Lines
218.214 Changing Compliance Methods
218.215 Wood Furniture Coating Averaging Approach
218.216 Wood Furniture Coating Add-On Control Use
218.217 Wood Furniture Coating Work Practice Standards
SUBPART G: USE OF ORGANIC MATERIAL
Section
218.301 Use of Organic Material
218.302 Alternative Standard
218.303 Fuel Combustion Emission Units
218.304 Operations with Compliance Program
SUBPART H: PRINTING AND PUBLISHING
Section
218.401 Flexographic and Rotogravure Printing
218.402 Applicability
218.403 Compliance Schedule
218.404 Recordkeeping and Reporting
218.405 Lithographic Printing: Applicability
218.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to March
15, 1996
218.407 Emission Limitations and Control Requirements for Lithographic Printing Lines
On and After March 15, 1996
218.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996
218.409 Testing for Lithographic Printing On and After March 15, 1996
218.410 Monitoring Requirements for Lithographic Printing
218.411 Recordkeeping and Reporting for Lithographic Printing
SUBPART Q: SYNTHETIC ORGANIC CHEMICAL AND POLYMER
MANUFACTURING PLANT
Section
218.421 General Requirements
218.422 Inspection Program Plan for Leaks
218.423 Inspection Program for Leaks
218.424 Repairing Leaks
218.425 Recordkeeping for Leaks
218.426 Report for Leaks
218.427 Alternative Program for Leaks
218.428 Open-Ended Valves
218.429 Standards for Control Devices
218.430 Compliance Date (Repealed)
9
218.431 Applicability
218.432 Control Requirements
218.433 Performance and Testing Requirements
218.434 Monitoring Requirements
218.435 Recordkeeping and Reporting Requirements
218.436 Compliance Date
SUBPART R: PETROLEUM REFINING AND RELATED INDUSTRIES;
ASPHALT MATERIALS
Section
218.441 Petroleum Refinery Waste Gas Disposal
218.442 Vacuum Producing Systems
218.443 Wastewater (Oil/Water) Separator
218.444 Process Unit Turnarounds
218.445 Leaks: General Requirements
218.446 Monitoring Program Plan for Leaks
218.447 Monitoring Program for Leaks
218.448 Recordkeeping for Leaks
218.449 Reporting for Leaks
218.450 Alternative Program for Leaks
218.451 Sealing Device Requirements
218.452 Compliance Schedule for Leaks
218.453 Compliance Dates (Repealed)
SUBPART S: RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS
Section
218.461 Manufacture of Pneumatic Rubber Tires
218.462 Green Tire Spraying Operations
218.463 Alternative Emission Reduction Systems
218.464 Emission Testing
218.465 Compliance Dates (Repealed)
218.466 Compliance Plan (Repealed)
SUBPART T: PHARMACEUTICAL MANUFACTURING
Section
218.480 Applicability
218.481 Control of Reactors, Distillation Units, Crystallizers, Centrifuges and Vacuum
Dryers
218.482 Control of Air Dryers, Production Equipment Exhaust Systems and Filters
218.483 Material Storage and Transfer
218.484 In-Process Tanks
218.485 Leaks
218.486 Other Emission Units
218.487 Testing
218.488 Monitoring for Air Pollution Control Equipment
218.489 Recordkeeping for Air Pollution Control Equipment
10
SUBPART V: BATCH OPERATIONS AND AIR OXIDATION
PROCESSES
Section
218.500 Applicability for Batch Operations
218.501 Control Requirements for Batch Operations
218.502 Determination of Uncontrolled Total Annual Mass Emissions and Average Flow
Rate Values for Batch Operations
218.503 Performance and Testing Requirements for Batch Operations
218.504 Monitoring Requirements for Batch Operations
218.505 Reporting and Recordkeeping for Batch Operations
218.506 Compliance Date
218.520 Emission Limitations for Air Oxidation Processes
218.521 Definitions (Repealed)
218.522 Savings Clause
218.523 Compliance
218.524 Determination of Applicability
218.525 Emission Limitations for Air Oxidation Processes
218.526 Testing and Monitoring
218.527 Compliance Date (Repealed)
SUBPART W: AGRICULTURE
Section
218.541 Pesticide Exception
SUBPART X: CONSTRUCTION
Section
218.561 Architectural Coatings
218.562 Paving Operations
218.563 Cutback Asphalt
SUBPART Y: GASOLINE DISTRIBUTION
Section
218.581 Bulk Gasoline Plants
218.582 Bulk Gasoline Terminals
218.583 Gasoline Dispensing Operations - Storage Tank Filling Operations
218.584 Gasoline Delivery Vessels
218.585 Gasoline Volatility Standards
218.586 Gasoline Dispensing Operations - Motor Vehicle Fueling Operations
SUBPART Z: DRY CLEANERS
Section
218.601 Perchloroethylene Dry Cleaners
218.602 Applicability
218.603 Leaks
218.604 Compliance Dates (Repealed)
11
218.605 Compliance Plan (Repealed)
218.606 Exception to Compliance Plan (Repealed)
218.607 Standards for Petroleum Solvent Dry Cleaners
218.608 Operating Practices for Petroleum Solvent Dry Cleaners
218.609 Program for Inspection and Repair of Leaks
218.610 Testing and Monitoring
218.611 Applicability for Petroleum Solvent Dry Cleaners
218.612 Compliance Dates (Repealed)
218.613 Compliance Plan (Repealed)
SUBPART AA: PAINT AND INK MANUFACTURING
Section
218.620 Applicability
218.621 Exemption for Waterbase Material and Heatset Offset Ink
218.623 Permit Conditions (Repealed)
218.624 Open Top Mills, Tanks, Vats or Vessels
218.625 Grinding Mills
218.626 Storage Tanks
218.628 Leaks
218.630 Clean Up
218.636 Compliance Schedule
218.637 Recordkeeping and Reporting
SUBPART BB: POLYSTYRENE PLANTS
Section
218.640 Applicability
218.642 Emissions Limitation at Polystyrene Plants
218.644 Emissions Testing
SUBPART CC: POLYESTER RESIN PRODUCT MANUFACTURING
PROCESS
Section
218.660 Applicability
218.666 Control Requirements
218.667 Compliance Schedule
218.668 Testing
218.670 Recordkeeping and Reporting for Exempt Emission Units
218.672 Recordkeeping and Reporting for Subject Emission Units
SUBPART DD: AEROSOL CAN FILLING
Section
218.680 Applicability
218.686 Control Requirements
218.688 Testing
218.690 Recordkeeping and Reporting for Exempt Emission Units
218.692 Recordkeeping and Reporting for Subject Emission Units
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SUBPART FF: BAKERY OVENS (REPEALED)
Section
218.720 Applicability (Repealed)
218.722 Control Requirements (Repealed)
218.726 Testing (Repealed)
218.727 Monitoring (Repealed)
218.728 Recordkeeping and Reporting (Repealed)
218.729 Compliance Date (Repealed)
218.730 Certification (Repealed)
SUBPART GG: MARINE TERMINALS
Section
218.760 Applicability
218.762 Control Requirements
218.764 Compliance Certification
218.766 Leaks
218.768 Testing and Monitoring
218.770 Recordkeeping and Reporting
SUBPART HH: MOTOR VEHICLE REFINISHING
Section
218.780 Emission Limitations
218.782 Alternative Control Requirements
218.784 Equipment Specifications
218.786 Surface Preparation Materials
218.787 Work Practices
218.788 Testing
218.789 Monitoring and Recordkeeping for Control Devices
218.790 General Recordkeeping and Reporting
218.791 Compliance Date
218.792 Registration
218.875 Applicability of Subpart BB (Renumbered)
218.877 Emissions Limitation at Polystyrene Plants (Renumbered)
218.879 Compliance Date (Repealed)
218.881 Compliance Plan (Repealed)
218.883 Special Requirements for Compliance Plan (Repealed)
218.886 Emissions Testing (Renumbered)
SUBPART PP: MISCELLANEOUS FABRICATED PRODUCT
MANUFACTURING PROCESSES
Section
218.920 Applicability
218.923 Permit Conditions (Repealed)
218.926 Control Requirements
218.927 Compliance Schedule
13
218.928 Testing
218.929 Cementable and Dress or Performance Shoe Leather
SUBPART QQ: MISCELLANEOUS FORMULATION
MANUFACTURING PROCESSES
Section
218.940 Applicability
218.943 Permit Conditions (Repealed)
218.946 Control Requirements
218.947 Compliance Schedule
218.948 Testing
SUBPART RR: MISCELLANEOUS ORGANIC CHEMICAL
MANUFACTURING PROCESSES
Section
218.960 Applicability
218.963 Permit Conditions (Repealed)
218.966 Control Requirements
218.967 Compliance Schedule
218.968 Testing
SUBPART TT: OTHER EMISSION UNITS
Section
218.980 Applicability
218.983 Permit Conditions (Repealed)
218.986 Control Requirements
218.987 Compliance Schedule
218.988 Testing
SUBPART UU: RECORDKEEPING AND REPORTING
Section
218.990 Exempt Emission Units
218.991 Subject Emission Units
Section 218.Appendix A: List of Chemicals Defining Synthetic Organic Chemical and
Polymer Manufacturing
Section 218.Appendix B: VOM Measurement Techniques for Capture Efficiency
Section 218.Appendix C: Reference Methods and Procedures
Section 218.Appendix D: Coefficients for the Total Resource Effectiveness Index (TRE)
Equation
Section 218.Appendix E: List of Affected Marine Terminals
Section 218.Appendix G: TRE Index Measurements for SOCMI Reactors and Distillation
Units
Section 218.Appendix H: Baseline VOM Content Limitations for Subpart F, Section 218.212
Cross-Line Averaging
14
AUTHORITY: Implementing Section 10 and authorized by Section 28.5 of the Environmental
Protection Act [415 ILCS 5/10 and 28.5].
SOURCE: Adopted at R91-7 at 15 Ill. Reg. 12231, effective August 16, 1991; amended in R91-
24 at 16 Ill. Reg. 13564, effective August 24, 1992; amended in R91-28 and R91-30 at 16 Ill.
Reg. 13864, effective August 24, 1992; amended in R93-9 at 17 Ill. Reg. 16636, effective
September 27, 1993; amended in R93-14 at 18 Ill. Reg. at 1945, effective January 24, 1994;
amended in R94-12 at 18 Ill. Reg. at 14973, effective September 21, 1994; amended in R94-15
at 18 Ill. Reg. 16392, effective October 25, 1994; amended in R94-16 at 18 Ill. Reg. 16950,
effective November 15, 1994; amended in R94-21, R94-31 and R94-32 at 19 Ill. Reg. 6848,
effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7359, effective May 22, 1995;
amended in R96-13 at 20 Ill. Reg. 14428, effective October 17, 1996; amended in R97-24 at 21
Ill. Reg. 7708, effective June 9, 1997; amended in R97-31 at 22 Ill. Reg. 3556, effective
February 2, 1998; amended in R98-16 at 22 Ill. Reg. 14282, effective July 16, 1998; amended in
R02-20, at_______Ill. Reg____,effective_______.
BOARD NOTE: This Part implements the Environmental Protection Act as of July 1, 1994.
Section 218.112 Incorporations by Reference
The following materials are incorporated by reference and do not contain any subsequent
additions or amendments.
a) American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA 19103:
1) ASTM D2879-86
2) ASTM D323-82
3) ASTM D86-82
4) ASTM D-369-69 (1971)
5) ASTM D-396-69
6) ASTM D2880-71
7) ASTM D-975-68
8) ASTM D3925-81 (1985)
9) ASTM E300-86
10) ASTM D1475-85
11) ASTM D2369-87
12) ASTM D3792-86
13) ASTM D4017-81 (1987)
14) ASTM D4457-85
15) ASTM D2697-86
16) ASTM D3980-87
17) ASTM E180-85
18) ASTM D2372-85
19) ASTM D97-66
20) ASTM E-168-67 (1977)
21) ASTM E-169-87
22) ASTM E-260-91
23) ASTM D2504-83
15
24) ASTM D2382-83
25) ASTM D323-82 (approved 1982)
26) ASTM D2099-00
b) Standard Industrial Classification Manual, published by Executive Office of the
President, Office of Management and Budget, Washington, D.C., 1987.
c) American Petroleum Institute Bulletin 2517, "Evaporation Loss From Floating Roof
Tanks", Second ed., February 1980.
d) CFR Part 60 (July 1, 1991) and 40 CFR 60, Appendix A, Method 24 (57 FR 30654, July
10, 1992).
e) CFR Part 61 (July 1, 1991).
f) CFR Part 50 (July 1, 1991).
g) CFR Part 51 (July 1, 1991).
h) CFR Part 52 (July 1, 1991).
i) CFR Part 80 (July 1, 1991) and 40 CFR Part 80 Appendixes D, E, and F (July 1, 1993).
j) "A Guide for Surface Coating Calculation", United States Environmental Protection
Agency, Washington, D.C., EPA-340/1-86-016.
k) "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint,
Ink and Other Coating", (revised June 1986), United States Environmental Protection
Agency, Washington D.C., EPA-450/3-84-019.
l) "A Guide for Graphic Arts Calculations", August 1988, United States Environmental
Protection Agency, Washington D.C., EPA-340/1-88-003.
m) "Protocol for Determining the Daily Volatile Organic Compound Emission Rate of
Automobile and Light-Duty Truck Topcoat Operations", December 1988, United States
Environmental Protection Agency, Washington D.C., EPA-450/3-88-018.
n) "Control of Volatile Organic Emissions from Manufacturing of Synthesized
Pharmaceutical Products", United States Environmental Protection Agency, Washington,
D.C., EPA-450/2-78-029.
o) "Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor
Collection Systems", Appendix B, United States Environmental Protection Agency,
Washington, D.C., EPA-450/-78-051.
p) "Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners",
United States Environmental Protection Agency, Washington, D.C., EPA-450/3-82-009.
q) "APTI Course SI417 Controlling Volatile Organic Compound Emissions from Leaking
Process Equipment", United States Environmental Protection Agency, Washington, D.C.,
EPA-450/2-82-015.
r) "Portable Instrument User's Manual for Monitoring VOC Sources", United States
Environmental Protection Agency, Washington, D.C., EPA-340/1-86-015.
s) "Protocols for Generating Unit-Specific Emission Estimates for Equipment Leaks of
VOC and VHAP", Unites States Environmental Protection Agency, Washington, D.C.,
EPA-450/3-88-010.
t) "Petroleum Refinery Enforcement Manual", United States Environmental Protection
Agency, Washington, D.C., EPA-340/1-80-008.
u) "Inspection Manual for Control of Volatile Organic Emissions from Gasoline Marketing
Operations: Appendix D", United States Environmental Protection Agency, Washington,
D.C., EPA-340/1-80-012.
16
v) "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals: Appendix A",
United States Environmental Protection Agency, Washington, D.C., EPA-450/2-77-026.
w) "Technical Guidance-Stage II Vapor Recovery Systems for Control of Vehicle Refueling
Emissions at Gasoline Dispensing Facilities", United States Environmental Protection
Agency, Washington, D.C., EPA-450/3-91-022b.
x) California Air Resources Board, Compliance Division. Compliance Assistance Program:
Gasoline Marketing and Distribution: Gasoline Facilities Phase I & II (October 1988,
rev. November 1993) (CARB Manual).
y) South Coast Air Quality Management District (SCAQMD), Applied Science &
Technology Division, Laboratory Services Branch, SCAQMD Method 309-91,
Determination of Static Volatile Emissions.
z) South Coast Air Quality Management District (SCAQMD), Applied Science &
Technology Division, Laboratory Services Branch, SCAQMD Method 312-91,
Determination of Percent Monomer in Polyester Resins.
(Source: Amended at
, effective
)
Section 218.929 Cementable and Dress or Performance Shoe Leathers
a) The rule requirements of this Section apply to a leather manufacturing facility
located at 2015 North Elston Avenue, Chicago, Illinois. The VOM emission
limits set forth in this Section shall only apply to the following types of select
grade of chrome tanned, bark/polymer retanned specialty leathers:
1) Cementable Shoe Leather is leather which is:
A) Hot stuffed without the presence of water, fat liquored or wet
stuffed by direct contact with wax, grease, polymers and oils in
liquefied form at elevated temperatures. The content of wax,
grease, polymers and oils embedded into the leather shall be over
12 percent but less than 25 percent by weight, measured on a dry
weight basis. Applicable leathers shall be determined using the
equation below:
12% < P < 25%
Where:
P = W\L x 100
P = percent content of wax, grease, polymer, and oils
W = weight of wax, grease, polymers and oils in pounds added to
the leather
L = dry weight of the leather in pounds before addition of wax,
greases, polymers and oils.
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B) Finished with coating materials which adhere to the leather surface
that feels oily; and
C) Used primarily for manufacture of shoes and cannot meet the
definition for specialty leather pursuant to 35 Ill. Adm. Code
Section 211.6170.
2) Dress or Performance Shoe Leather is leather which is:
A) Finished with coating materials containing water emulsified
materials using water miscible solvent materials to protect the
leather and pigmented coating; and
B) Used primarily for manufacture of sewn shoes where the leather
must be capable of soaking with a fine, dressy finish that cannot
meet the lbs. per gallon VOM limitations set forth in Section
218.926 of this Subpart and cannot meet the definition for
specialty leather pursuant to 35 Ill. Adm. Code Section 211.6170.
3) The requirements of this Section do not apply to the production of those
specialty
leathers that meet the definition of specialty leathers pursuant to
35 Ill. Adm. Code 211.6170 or to the production of leathers that can meet
the control requirements of Section 218.926 of this Subpart.
4) The 10-ton exemption for stain pursuant to Section 218.926(b)(2)(i) of
this Subpart does not apply to leathers produced pursuant to the
requirements of this Section.
b) The production of specialty leather as defined in subsection (a) of this Section is
subject to the following limitations:
1) For both water resistant and non-water resistant leathers, the leather will
be designated as water resistant or non-water resistant in the shipping
room by using ASTM D 2099-00, as incorporated by reference in Section
218.112 of this Part.
2) For non-water resistant leathers, the total VOM emissions shall not exceed
14.0 lbs VOM/1,000 square feet of leather produced on a 12-month rolling
average basis.
3) For water resistant leathers, the total VOM emissions shall not exceed
24.0 lbs VOM/1,000 square feet of leather produced on a 12-month
rolling average basis.
4) The total emissions of VOM from leathers produced pursuant to the
emission limits in this Section shall not exceed 20 tons per year.
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c)
The owner or operator shall comply with their approved standard operating and
maintenance procedures (SOMP). The SOMP will contain the following
elements:
1)
A procedure to minimize the volatilization of solvents during the
measuring of coating proportions and/or mixing of coatings.
2)
A procedure to minimize VOM fugitive losses from the coating and
solvent storage rooms. Procedures should include methods of securely
sealing containers and methods to clean up accidental spills.
3)
A procedure to minimize solvent usage or VOM losses during equipment
cleanup and during transport (including the transferring of coatings from
the mixing areas to the coating lines).
d )
Owner or operator shall perform the reporting and record keeping consistent with
the requirements of Section 218.929 of this Subpart and Section 39.5 of the Act
(415 ILCS 5/39.5), and shall include at a minimum the following:
1)
The VOM content and gallons of each coating and the total pounds of
VOM of all coatings applied to each category of leather, e.g., cementable
non-water resistant, dress water resistant, by batch during each month; and
2)
The total area of each category of leather produced during the month
based on the number of items produced and the area of such items,
measured or established in accordance with procedures set forth in a
federally enforceable permit.
3)
Notwithstanding the requirements of subsections (d)(1) and (d)(2) of this
Section, the owner or operator may comply with an equivalent alternative
plan for reporting and record keeping that has been approved by the
Agency and the USEPA in a federally enforceable permit or as a SIP
revision
IT IS SO ORDERED.
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control Board, hereby certify that
the Board adopted the above opinion and order on August 8, 2002, by a vote of 7-0.
Dorothy
M.
Gunn,
Clerk
Illinois
Pollution
Control
Board
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