ILLINOIS POLLUTION CONTROL BOARD

April 20,

1995

IN THE MATTER OF:

)

15

ROP PLAN CONTROL

MEASURES

)

FOR VOM EMISSIONS-PART IV:

TIGHTENING SURFACE COATING

)

STANDARDS; SURFACE COATING OF

)

AUTOMOTIVE\TRANSPORTATION AND

BUSINESS MACHINE PLASTIC PARTS;

)

R94-21

WOOD FURNITURE COATING; REACTOR

)

(Rulemaking)

PROCESSES AND DISTILLATION

)

OPERATION PROCESSES IN SOCMI;

)

AND BAKERY OVENS; AMENDMENTS TO

)

35 ILL. ADM. CODE PARTS 211,

)

218 AND 219

)

AdoPted Rule. Final Order.

OPINION AND ORDER OF THE BOARD

(by G.

T.

Girard):’

On September

12,

1994,

the Illinois Environmental Protection

Agency

(Agency) filed this proposal for rulemaking.

Section

182(b) (1)

of the Clean Air Act (CAA),

as amended in 1990,

requires all moderate and above ozone nonattaininent areas to

achieve a 15

reduction of 1990 emissions of volatile organic

material

(VOM)

by 1996.

In Illinois,

the Chicago and Metro—East

St. Louis

(Metro—East)

areas are classified as “severe” and

“moderate” nonattainment for ozone, respectively, and as such are

subject to the 15

reduction requirement.

Also pursuant to

Section 182(b)

of the CAA,

Illinois is to submit a 15

Rate of

Progress Plan

(ROP) within three years

of the enactment of the

CAA amendments.

This rulemaking represents Part IV of the rules

proposed in Illinois’

15

ROP plan.2

The Board’s responsibility in this matter arises from the

Environmental Protection Act

(Act)

(415 ILCS 5/1 et seq.

(1992)).

The Board is charged therein to “determine, define and implement

the environmental control standards applicable in the State of

Illinois”

(415 ILCS 5/5(b)).

More generally,

the Board’s

The Board wishes to acknowledge the contributions of

attorney Marie Tipsord

in this matter.

2

See R94-12,

In the Matter of

15

ROP Plan Control

Measures for VON Emissions

-

Part

I, R94-15,

In the Matter of 15

ROP Plan Control Measures for VOM Emissions

-

Part II,

and R94-

16,

In the Matter of

15

ROP Plan Control Measures for VOM

Emissions

—

Part III.

---

2

rulemaking charge is based on the system of checks and balances

integral to Illinois environmental governance:

the Board bears

responsibility for the rulemaking and principal adjudicatory

functions;

the Agency has primary responsibility for

administration of the Act and the Board’s regulations.

The

latter includes administration of today’s new regulation.

The proposal includes several measures for reduction of

VON in various coating operations.

Specifically,

lower limits

for VOM content of coatings applied to the following categories

are proposed:

can, paper, coil,

fabric, vinyl, metal furniture

coatings, baked large appliance coatings and miscellaneous parts

and products.

The proposal also includes amendments requiring

automotive\transportation and business machine plastic parts

coating sources to meet specific pound per gallon VOM limitations

for coating operations which exceed the applicability threshold

set forth in the rule or which emit more than 15 pounds per day

of VON.

Finally, the proposal tightens the applicability levels

(from 100 tons per year to 25 tons per year)

for wood furniture

coating operations.

The proposal also includes provisions regulating synthetic

organic chemical manufacturing industry

(SOCMI) distillation and

reactor processes ~nd bakery oven VOM emissions.

SOCMI processes

regulated by this proposal will be required to apply control

technology to certain process vents which demonstrates 98

reduction of VON emissions or reduces VON to 20 parts per million

by volume on a dry basis corrected to 3

oxygen.

This proposal was filed pursuant to Section 285 of the Act

and was accepted for hearing.

Pursuant to the provisions of that

section the Board is required to proceed within set time—frames

toward the adoption of this regulation.

The Board has no

discretion to adjust these time—frames under any circumstances.

Today the Board acts to adopt this proposal and file it for final

notice.

PROCEDURAL HISTORY

On September 15,

1994,

the Board sent this proposal to first

notice under the APA without commenting on the merits of the

proposal.

The proposal was published in the Illinois Register on

October 14,

1994 at

18 Ill.

Req.

15192

(Part 211),

18

Ill.

Reg.

15211

(Part 218), and 18

Ill.

Reg.

15274

(Part 219).

Hearings

were held on November 4,

1994,

December 2,

1994 and December 16,

1994,

in Chicago, Illinois before hearing officer Marie Tipsord.

---

3

The comment period closed on January 4,

1995 and the Board

received 16~comments which are discussed in detail below.

On January 26,

1995, the Board adopted the proposal for

Second Notice with several changes which are discussed herein.

PROPOSAL

Section 182(b) (1)

of the CAA, as amended in 1990,

requires

all moderate and above ozone nonattainment areas to achieve

a 15

reduction of 1990 emissions of VOM by 1996.

This rulemaking is

Phase 4 of Illinois’

15

ROP plan to achieve that reduction.

The

proposal represents a group of measures which are presented to

reduce VON emissions in the Metro—East area (moderate

nonattainment) and the Chicago area (severe nonattainment).

As discussed above, the proposal includes four processes to

be controlled.

Those four types are:

1.

Coating of Automotive/Transportation and Business

Machine Plastic Parts

2.

Wood Furniture Coating

3.

Synthetic Organic Chemical Manufacturing Industry

(SOCMI) Distillation and Reactor Processes

4.

Bakery Ovens

(Prop.

at 5-8)~

In addition, the Agency has proposed minor Reasonably Available

Control Technology

(RACT) revisions in this prodeeding.

(Prop.

at 8.)

Coating Operations

The proposal would tighten the existing VON content

limitations for over 300 potentially affected sources, the

majority of which are in the Chicago area.

(Prop. at 5-6.)

The

categories of coatings which are affected by the proposal include

“can, paper,

coil,

fabric, vinyl, metal furniture,

baked large

appliances and miscellaneous metal parts and products”.

(Prop.

at 6.)

The Agency expects the proposed control measures to

~

The Board notes that on March 15,

1994 a comment entered

into the record as “P.C.

17” was filed by Solar Corporation.

The

Board is unable to consider the comment in this proceeding as the

record closed by statute (Section 28.5(1)

on January

4,

1995.

~

The statement of reasons filed by the Agency will be

cited as “Prop.

at

“;

public comments will be cited as “P.C.

—

at

“;

the transcript will be cited as “Tr.

at

_“;

prefiled

testimony will be cited as “Exh.

—

at

_“;

and attachments to the

Agency’s proposal will be cited as “Attach.

—

at

“.

---

4

reduce the VON emissions in the Chicago area by 10.16 tons per

day

(TPD)

and 0.39 TPD in the Metro-East area.

The proposal also adds a new method for compliance known as

cross—line averaging.

(Prop. at 6.)

Cross—line averaging will

allow a source to demonstrate, using mathematical equations, that

the aggregate of all emissions from all coating lines is less

than the daily allowable VOM emissions from the same group of

lines.

(Prop.

at 10.)

With regard to the technical feasibility and economic

reasonableness of the proposal, the Agency contracted for the

services of Science Application International Corporation

(SAIC),

an engineering consulting firm,

to assess the technical

feasibility and economic reasonableness of the proposed

amendments to the VON content limitations for coatings.

(Prop.

at 17.)

SAIC found that the existing coating standards were

being met by sources through the use of coatings which had a VOM

content that was only 77 percent of the current allowable VON

limit.

(Id.)

The Agency also notes that the technical

feasibility of the proposed amended VOM content limitations for

coatings is also being demonstrated by sources subject to the VOM

content limitations in California’s South Coast Air Quality

Management District (“South Coast”).

(~:

South Coast Air

Quality Management District, Rules and Regulations, Tit.

IX,

S1107

(1992); Attach.

17(b) (10).)

The general cost effectiveness of

alternativE

control

options under this proposal vary depending on the size of the

source.

(Prop. at 17—18.)

For control by means of waterborne

coatings, SAIC estimates that costs range from $310 to $680 per

ton of VOM reduced and for high solids coatings, SAIC estimates

that costs range from $650 to $1,560 per ton of VON reduced.

(Prop. at 18.)

Finally,

for add-on controls, SAIC estimates that

costs range from $3,450 to $12,570 per ton of VON reduced.

(Id.)

Coating of Automotive/Transportation and Business Machine Plastic

Parts

The proposal amends the coating requirements applicable to

seven potentially affected sources,

all in the Chicago area, with

coating operations for interior and exterior plastic parts for

automotive or other transportation equipment.

Such equipment

includes trucks

(light—, medium-,

or heavy-duty); construction

equipment; vans; buses; tractors; lawnmowers and other mobile

equipment intended for primary use on land; and housing and

exterior plastic parts for business and commercial machines,

including, but not limited to,

computers, monitors, printers,

facsimile machines, microfiche readers, copy machines, cellular

and standard phones, typewriters,

pencil sharpeners, medical

equipment,

and entertainment equipment.

(Prop.

at 6.)

This

proposal excludes coating operations for plastic parts coated on

---

5

the main (body)

paint line in automobile and light duty truck

assembly plants; coating operations for plastic parts coated

during refinishing of automobile,

trucks,

tractors,

lawnmowers

and other mobile equipment; watercraft and aircraft; and internal

electrical components of business machines.

(Prop.

at 6.)

These control measures are expected to reduce 1996 VOM

emissions by 0.28 TPD in Chicago, according to the Agency.

(Prop.

at 11.)

The cost-effectiveness of lower VOM content

coatings for Automotive/Transportation plastic parts are $606-668

per ton of VON reduced and the cost-effectiveness of lower VON

content coatings for Business Machine plastic parts are $470-480

per ton of VOM reduced.

(Prop.

at 18.)

Add-on thermal

incineration systems are an option that can be used to control

VON emissions instead of lower VON content surface coatings and

the costs vary depending on the plant size and volume of coating

required.

(Id.)

Wood Furniture Coating

This proposal includes amendments which will potentially

affect

19 facilities which have wood coating operations, all in

the Chicago area.

(Prop. at 7.)

Specifically, the Agency is

proposing to modify the applicability section to lower the

threshold from 100 tons per year of maximum theoretical emissions

to 25 tons per year potential to emit.

(Prop.

at 7.)

In effect,

then, the proposal is tightening the applicability of the wood

coating provisions; however, the~~~

Agency does not believe that the

proposed amendments will reduce VON emissions.

(Prop.

at 12.)

Rather, the Agency believes this provision is important to insure

that no increase in VON emissions occurs.

(Prop.

at 12.)

The technology for controlling VOM emissions from wood

furniture coating operations through add—on controls is

available,

and includes thermal or catalytic incinerators and

adsorption devices.

(Prop.

at 19.)

The cost estimates below

represent sources that emit from 50 TPY to 500 TPY of VON.

(Id.)

The capital costs for control devices range from $446,400 to

$8,115,600 while the operating costs for catalytic incinerators

range from $170,700 to $3,439,500 annually.

(Id.)

These costs

are based on a scheme where a single control device controls all

VON emissions from the source.

(Id.)

An enclosure over the

entire finishing line may be required for most wood furniture

coating sources to use a single control device with a capital

cost of range from $10,000 to $100,000, depending on the size of

the facility.

(Prop. at 19-20.)

SOCMI

The Agency has identified

2 sources which are potentially

affected by these proposed amendments.

One facility is in the

Chicago area and the second is in the Metro—East area.

---

6

Specifically, the proposal would apply to facilities that have

continuous chemical manufacturing process units that produce as a

primary product chemicals set forth in Appendix A of Parts 218

and 219.

(Prop.

at 7.)

Excluded from the applicability of this proposal are:

(1)

reactor processes or distillation operations that are designed

and operated in batch mode;

(2) reactor processes or distillation

operations that are part of a polymer manufacturing operation;

(3)

reactor processes or distillation operations in a process

unit with a total design capacity of less than 1,100 tons per

year for all chemicals produced within that unit;

(4) any vent

stream with a flow rate less than 0.0085 scm/mm

or total VON

concentration of less than 500 ppmv;

or

(5) any reactor or

distillation unit included within an Early Reduction Program

approved by USEPA.

(Prop.

at 12.)

Under the proposal,

applicability for all non-exempt process vents will be determined

by a total resource effectiveness

(“TRE”)

index calculation.

A

TRE index value of 1.0 or less subjects that process vent to the

control requirements in this rulemaking.

(Id.)

The control requirements of this proposal recommend a

presumptive norm for RACT of 98 percent reduction of VON

emissions or 20

ppinv, on a dry basis, corrected to 3 percent

oxygen, emission limit for affected vent stream(s).

(Prop. at

12—13.)

No vent stream with an existing combustion device

is

required to meet the 98 percent reduction requirement or 20 ppmv

emission limit until the combustion device

is replaced.

(Prop.

at 13.)

This proposal is based on USEPA’s control technology

guideline

(CTG)

for controlling VON process vent emissions from

SOCNI reactor processes and distillation operation, which was

formally announced on November 15,

1993.

(~

58 FR 60197,

November 15,

1993;

Prop.

at 13.)

According to the Agency, this

measure is not expected to reduce VON emissions in either the

Chicago or the Metro—East nonattainment area; rather,

this

measure is proposed in accordance with the State’s obligation to

adopt regulations implementing RACT,

as promulgated by USEPA

under Section 182(b) (2) (A)

of the CAA.

(Prop. at 13.)

Combustion is the primary control method used for VOM

emissions reduction for these processes.

Control options

include, but are not limited to, boilers,

flares,

afterburners,

or recovery.

USEPA estimates indicate that the cost

effectiveness of controlling VOM emissions from SOCNI

distillation and reactor processes ranges from $241 to $21,000

per ton of VOM reduced.

(Prop. at 20.)

The highest cost

effectiveness

is for low—flow and low—heat value sources

processing halogenated hydrocarbons.

An analysis prepared by the

State and Territorial Air Pollution Program Administrators and

Association of Local Air Pollution Control Officials

---

7

(STAPPA/ALAPCO)

indicates that the corresponding maximum cost of

control, for CTG exempt sources with a TRE index greater than

1.0,

is approximately $2,300 per ton.

(Id.)

Bakery Ovens

The proposal regulates bakery ovens for the first time.

Bakery ovens are defined as ovens which bake yeast—leavened bread

products.

The source must have a potential to emit 25 tons per

year before it is subject to the requirements.

However, the

proposal excludes ovens which are used to bake for on—site

consumption or on—site retail sale.

(Prop.

at 13.)

The proposal requires emission controls that achieve an

overall efficiency of 81

reduction in VON from bakery ovens.

(Prop.

at 13.)

This level includes VOM emissions from all

emission units at the source.

(Id.)

Sources with VOM emissions

limits below the applicability threshold of 25 tons per year are

required by this proposal to maintain records to establish their

annual emissions level and to certify that they are exempt from

the control requirements.

(Prop. at 13—14.)

The proposal states:

Afterburners, such as catalytic oxidizers or regenerative

oxidizers,

are the most effective devices for controlling

VON emissions from bakery ovens.

Catalytic oxidizers have

been used successfully at numerous bakeries in other states.

The costs vary depending on the age and size of the oven,

and the number of exhaust streams that must be routed to the

control device.

Capital costs range from $84,000 to

$205,000 for catalytic oxidizers and from $197,000 to

$295,000 for regenerative oxidizers.

Annual operating costs

range from $36,000 to $72,000 for catalytic oxidizers and

from $72,000 to $115,000 for regenerative oxidizers.

(~:

Item 16(e)

of the Table of Contents.)

(Prop. at 20-21.)

Minor RACT Amendments to Parts 218 and 219

The proposal amends Sections 219.926,

219.946, 219.966 and

219.986 dealing with permitting issues that have the potential to

affect many facilities.

(Prop.

at 8.)

Specifically, the

proposal adds the word “equivalent” to these sections before any

reference to an alternative control plan.

The proposal also

amends Section 218.980 and 219.980 to add polyethylene foam

packaging as a category of packaging not subject to the control

requirements in Sections 218.986 and 219.986.

The proposal also

corrects a list of criteria by which

a source determines

if it

is

able to fill aerosol cans by the “through—the—valve” method,

making it clear that satisfaction of any single criterion would

not require a source to fill aerosol cans through this method,

and the source may use another filling method.

(Id.)

The

---

8

amendment to Section 218.966(c)

adds the inadvertently omitted

compliance date of March 15,

1995,

to that subsection,

and

affects non—SOCNI sources

(i.e. miscellaneous organic chemical

manufacturing processes) with leaks

in the Chicago ozone

nonattainment.

(Id.)

The amendments to Section 218.106(e)

affect coating

operations on electromotive diesels in Cook County, Illinois

setting forth the date for compliance with the VON content limits

for coatings applied in this category,

consistent with USEPA’s

settlement in the litigation concerning the Federal

Implementation Plan

(~

55 FR 26814, June 29,

1990.)

The Agency has not identified any potential sources in the

Metro—East area and so anticipates no reduction in VON emissions

for that area.

In the Chicago area, the Agency expects the

control of VOM emissions will result in a 0.98 TPD reduction in

the Chicago area.

TESTIMONY AND COMMENTS

As stated previously,

the Board received 16 public comments

on this rulemaking.

Comments were received from the following:

1.

Linda Brand, Manager of Regulatory Flexibility Unit,

Illinois Department of Commerce and Community Affair

2.

Dietzgen Corporation submitted by Beth A.

Caylor,

Environmental Affairs Manager

3.

Connie Bradway, Administrative Code Division, Secretary

of State

4.

Interstate Brands Corporation submitted by Robert

E.

Stine

5.

V.

J. Dolan

& Co.

by Stepen J. Dolan

6.

City of Chicago by Henry L. Henderson, Commissioner,

Department of Environment

7.

USEPA by Stephen Rothblatt,

Chief,

Regulation

Development Branch

8.

American Bakers Association submitted by Anne G.

Giesecke, Ph.D.

9.

Interstate Brands Corporation submitted by Robert E.

Stine, Attorney

---

9

10.

Kraft General Foods submitted by Peggy L. Martin,

Director,

State Government Affairs and Deborah A.

Becker, Vice President,

Environmental Policy

11.

Harris Marcus Group by Jeffrey C. Fort

12.

Stepan Company submitted by Patricia F. Sharkey

13.

Illinois Environmental Regulatory Group submitted by

Whitney Wagner Rosen

14.

Outboard Marine Corporation submitted by Maribeth

Flowers

15.

S

& C Electric Company submitted by Kathleen Hodge

16.

Agency comments submitted by Bonnie Sawyer, Shelia

Kolbe and Kyle Davis, Assistant Counsels,

Legal

Division

In addition, several individuals testified at the Board’s

December 2,

1994, hearing including:

Deborah Becker for Kraft General Foods;

Dr. Anne Giesecke for American Bakers Association;

Mark Biel for Chemical Industry Council;

Gordon Nelson for Harris Marcus Group;

Greg Miller for Solar Corporation;

Elizabeth Steinhour for Illinois Environmental Regulatory

Group;

Robert Sullivan for S

& C Electric.

The discussion that follows will be organized by subject

matter and where possible by the public comment number.

We will

begin by discussing the testimony received at the December 2,

1994 hearing which was not followed by a public comment.

We will

then discuss the comments received.

PAINT AND COATING INDUSTRY MANUFACTURERS

Chemical Industry Council

Mr. Mark Biel testified on behalf of the Chemical Industry

Council (Council)

at the Board’s December 2,

1994,

hearing.

Mr.

Biel testified that implementation of a portion of these rules

would have a “dramatically negative effect on the paint and

---

10

coating industry manufacturers and, more importantly, their

customers and be at odds with state and federal requirements

relating to establishing VON emission control technologies for

existing surface coating processes.”

(Exh.

20 at 1—2.)

Specifically Mr. Biel made the following points:

1.

The Agency’s reliance upon southern California’s

coating industry and coating regulations as a technical

basis for emission limits set forth

in this proposal

is

inappropriate because the feasibility of applying lower

VON coatings that comply in southern California is

heavily dependent upon the existence of drier and

warmer weather conditions.

Also the emission limits

set forth in the southern California regulations go

beyond PACT and,

in fact,

rely upon future advanced

technology which is not currently available.

2.

Certain emission limits set forth in the Agency’s

proposal are technology forcing, and, therefore, go

beyond the PACT threshold allowed by the

CAA

to meet

the 15

POP plan control measures for VON emissions in

non—extreme areas of the country.

3.

The 2.2 lbs./gal.

emission limit set forth

in Subpart

F, Section 218.204(b) (1)

of the proposal cannot be met

by certain manufacturers of sheet basecoat and

overvarnish for can coating using current technology.

4.

The 1.7 lbs./gal. emission limit set forth

in Subpart

F, Section 218.204(d)

of the proposal goes well beyond

PACT and may be economically and technologically

infeasible with current add—on control technologies.

5.

The 2.3 lbs./gal.

emission limit set forth in Subpart

F,

Section 218.204(g) (2)

of the proposal for baked

coatings applied to metal furniture will cause

substantial reductions in the quality and performance

of these coatings which will make them unusable for

many applications in this category.

6.

The 3.0 lbs./gal.

emission limit set forth

in Subpart

F, Section 218.204(j) (2) (B)

of the proposal for baked

extreme performance coatings applied to miscellaneous

metal parts and products will extremely limit

applicability of these coatings due to reductions

in

viscosity, non—uniform film thickness and curing

problems.

Reductions

in spread rates of these coatings

at the proposed VON levels would also likely decrease

productivity tremendously.

7.

The 2.8 lbs./gal. emission limit set forth

in Subpart

F,

Section 218.204(j) (4) (A)

of the proposal for air

---

11

dried coatings applied to miscellaneous metal parts and

products cannot be met for the majority of applications

with current technology.

Reductions

in spread rates of

these coatings at the proposed VON levels would also

likely decrease productivity tremendously.

8.

The 2.3 lbs/gal. emission limit set forth in Subpart

F,

Section 218.204(j) (4) (B)

of the proposal for baked

coatings applied to miscellaneous metal parts and

products cannot be met with current technology.

Reductions in spread rates of these coatings at the

proposed VON levels would also likely decrease

productivity tremendously.

Agency Response to Council

The Agency and the Council have reached agreement on

proposed changes to the rulemaking and are recommending those

changes to the Board.

(P.C.

16 at 4.)

Specifically, changes are

being recommended for Sections 218/219.204(j) (2) and

218/219.204(j) (4), new subsections 218.204(j) (6) and

(7),

and

219.204(j) (5) and (j)(6).

(P.C.

16 at

4.)

The recommendation

for change would raise the VOM emission limit for extreme

performance coatings from 3.0 lb/gal as proposed to 3.3 lb/gal.

All other air dried coatings will also have

a limit of 3.3 lb/gal

and baked coatings will be limited to 2.8 lb/gal rather than 2.3

lb/gal.

(Id.)

The Agency also recommends adding a definition

for “Metallic Coating” with limits for this category at 3.5

lb/gal for air dried and 3.0 lb/gal for baked coatings.

(Id.)

Board Action

The Board accepts the recommendations for amendments as

proposed by the Council and the Agency.

Sections

218/219.204(j)(2)

and 218/2l9.204(j)(4)

new subsections

2l8.204(j)(6) and

(7) and 219.204(j) (5)

and (j)(6) will be

amended to read as follows:

Section 218.204

j)

Miscellaneous Metal Parts and

Products Coating

1)

Clear coating

0.52

(4.3)

0.52*

(4.3)*

2)

Air-dricd coating

0.42

~)

Extreme performance

u.L~..

coating

A)

Air

dried

0.42

(3.5)

---

12

j~:.~Air...Dried

•.

.

O.42.~

.~(3c.51

0.42*

.

(.5)

*

~

.;Eaked..

.

a,36

_____

.

0.36

.:

Definitions

~

For

purposes

of

subsection

218

2O4(1)(5~

of

this

Sect~on.

the

fol1owin~

terms

are

aeEfthed:.

;

jt~j~

Tésistant

bà~e~Oát~~

means.

•fo~~.

of

218.204(1)

(5~~B):..fii~

of

~

water—borne epoxy coating apDliec~via an

e1éctrôde~ositiorirn~ocèSs

.~

p.~~tp~j:

surface

~rior~

th~spray

at1ng~~forthe

purposé.~of enhancing

corrosion

res

istán~e.

.

.~fl,

“Electrodeposition

y~rocess”

means for

thepürpóses

of

~bseötiàn

218

204~i~5)

of~this ~

—..

-~

.~4.

.~

...

~

~

4

.

,,•~

4

.,~.

~

4.

~.,

tb; the

iii)

“Marine engine coating” means. for

...

••~rpo~s:•.of b~ectthn.2.18~:204(~)

(5:.~:f

this

Section

any

extreme

performance

protective,

decorative

or

functional

0.42*

(3.5)*

0.42

(3.5)

0,40*

______

0 52

(4

~)

0.52*

(4.3)*

B)

Baked

4~) Steel pail and drum

interior

coating

~-j)

All other coatings

~J..

Air Dried

~j

Baked

0.36

(3.03

0

42

(3

~.

(3~1*

0.36

(3.0)

~ 34*

______

---

13

3a)

Extreme performance

coating

A)

Air dried

B)

Baked

~4.) All other coatings

~

Air Dried

~j

Baked

0.42

(3.5)

0.42

0.42*

(3.5)

(3.5)*

0.42

(3.5)

0 40*

(3~3)*

0.36

(3.0)

0.42

(3.5)

~ 4~*

______

0.36

(3.9)

________

0.42

____

0.42*

(3.5)*

_____

0,36

_____

O~36*

:

.

(30~~

~i:

~~ó~s:..:of.:~bsection

219.204~i)(.~of:th:is

Section,

1~meta11ic

ôoating~means a

coating

which

cóntäins~indrethán1/4 lb/gal of metalparticIes.

as:applied.

.

.

SOLAR CORPORATION

Mr. Greg Miller testified on behalf of the Solar Corporation

at the Board’s December 2,

1994 hearing.

Mr. Miller explained

that Solar is a “job shop” making custom-made, painted— and

fabric— covered plastic decorative components

for original

equipment manufacturers of home entertainment and automotive

industries.

(Exh.

27 at 1.)

Solar does not specify the types of

coating applied to its product lines, according to Mr. Miller.

Section 219.204

j)

Miscellaneous Metal Parts and

Products Coating

---

14

(Id.)

Further, due to the nature of the products manufactured,

there are wide swings

in production and overlapping business

cycles

which

make

record

keeping

and

production

planning

difficult.

(Id.)

Mr. Miller testified that Solar, which

is located in

Libertyville,

Illinois,

anticipates

that

all

its

coatings,

with

the

exception

of

two,

will

comply

with

the

proposed

VOM

limitations.

(Exh.

27

at

2.)

Those

two

exceptions

are

an

adhesion

primer

used

to

coat

automotive

plastic

parts

made

from

polyolefinic, polyvinyl chloride or polyamide-based plastics and

a metal flake coating.

(Id.)

Solar has been in contact with the Agency to discuss

alternatives and was provided with a copy of the Alternative

Control Techniques Guidance Document which formed the basis for

the proposed emission limits.

(Exh.

27 at 4.)

Mr. Miller

states:

While that document does indicate that there are compliant

adhesion primers for use with sheet molded plastics,

those

plastics are physically and chemically different than the

plastics Solar applies adhesion primers to prior to

painting.

Solar uses,

among others, high impact styrenes,

polycarbonates,

ABS, Noryl and polyamides.

As different

plastics have different physical compositions, so do they

also have different chemical compositions.

Different

reactions, therefore, will occur between different plastics

and the solvents in different coatings.

Consequently,

it

does not follow that simply because one adhesion primer

formulated for one plastic will react

in the same way with

another plastic.

(sici

(Exh.

27 at 4.)

Mr. Miller asks that the Board consider amending the

proposal

to

include

a

specific

category and limit for adhesion

primers used to coat automotive plastic parts made from

polyolefinic, polyvinyl chloride or polyamide-based plastic

parts.

(Exh.

27 at 5.)

Mr. Miller asserts that since USEPA

“apparently

did

not consider the use of adhesion primers to coat

polyolefinic, polyvinyl chloride or polyamide-based plastic

parts” the request for amendment to the Board is warranted.

(Id.)

Solar suggests the following language to be added to

Sections

218/219.204:

ni

Plastic Parts Coating:

Automotive/Transportation

kg/l

lb/gal

***

~j

Specialty

---

15

F)

Adhesion primers used to coat

polyolefinic, polyvinyl

chloride or polyamide plastic

parts

.85*

(7.1)*

G)

Metal flake coat

•79*

(6.5)*

(Id.)

Agency Response to Solar

The Agency in its final comments indicated that after the

December

2,

1994, hearing in this proceeding,

the Agency

contacted USEPA regarding the issues raised by Solar.

According

to the Agency,

USEPA does not believe that the information

provided by Solar at the second hearing supports the need for

separate categories for these types of coatings.

(P.C.

16 at

23.)

“USEPA believes that compliant coatings are available.”

(Id.)

The Agency contacted several manufacturers of paints and

coatings

all

of

which

stated

that

there

are

adhesion

primers

available which meet the proposed levels.

(Id.)

Board Action

The Board will not adopt the changes suggested by Solar at

this time.

The Board notes that the Agency does not fully

address several of the concerns raised by Solar.

In fact,

the

Agency has reiterated the economic and technical support for the

proposal without addressing the specifics of Solar’s operation.

However,

Solar also fails to give sufficient technical and

economic support for a general rulemaking change.

Solar might

wish to examine the possibility of a site-specific rulemaking or

adjusted standard for its facility on this issue.

CAN COATING OPERATIONS

Agency Response to Comments of United States Can Company

The Agency indicated that,

in response to questions

presented at the November 4,

1994,

hearing, the Agency reexamined

the proposed limits for overvarnish coatings used in three—piece

can coating operations.

(P.C.

16 at 8.)

After reviewing the

limit,

the Agency recommends that the proposal be amended to

retain the current limit for overvarnish while lowering the

basecoat limits.

(P.C.

16 at 8-9.)

Board Action

The Board will accept the recommendation and amend the

proposal at Sections 218.204(b) (1)

and 219.204(b) (1)

to read:

Section 218/219.204 Emission Limitations

---

16

b)

Can

Coating

kg/l

lb/gal

1)

Sheet basecoat and

overvarnish

0.34

~

Sheet basecoat

0.34

(2.8)

0.26*

______

flj..

Overvarnish

0.34

_____

0.34

(2.8)*

GENERAL

PUBLIC COMMENTS

DCCA

(P.C.

1)

and Secretary of State

(P.C.

3)

The first comment was filed by the Illinois Department of

Commerce and Community Affairs which indicated that the rule

would not significantly impact small business.

(P.C.

1.)

A

comment was also received from the Secretary of State

Administrative Code Division which indicated minor changes

necessary for codification purposes.

(P.C.

3.)

Those changes

have been made in the proposed second notice.

Dietzcien Corporation

(P.C.

2)

Dietzgen Corporation’s comment centers around the use of

USEPA test Method 24 for determining the VON content of water-

based paper coating formulas used by Dietzgen.

(P.C.

2 at

1.)

Dietzgen is concerned that the Method 24 analysis is inaccurate

and that use of Method 24 will not give a correct VON level.

Dietzgen indicates that it will continue to seek alternatives and

welcome suggestions on the approach it has taken.

(Id.)

V.

3.

Dolan

& Co.,

Inc.

(P.C.

5)

V.

J. Dolan

& Co. comments that,

as

a coatings manufacturer,

the proposed limits set forth for “Miscellaneous Metal Parts

&

Products Coating’ are not feasible for a large number of coating

users

in the Greater Chicago area.”

(P.C.

5.)

The comment

“strongly” urges the Board to reconsider these limits and allow

for limits which are “both realistic and achievable”.

(Id.)

Henry L. Henderson, Commissioner,

Chicago Department of

Environment (CDOE)

(P.C.

6)

Mr. Henderson states that “CDOE supports the goals of this

rulemaking and urges the State to allow implementation in the

most flexible and cost effective manner as possible.”

(P.

C.

6

at 2.)

Specifically, CDOE supports interfacility trading and

seasonality components which would allow flexibility to meet the

lower VON emissions requirements.

(Id.)

CDOE also supports the

use of cross—line averaging.

(Id.)

---

17

Agency Response to Dietzgen Corporation, Dolan and CDOE

The Agency did not specifically respond to each of these

comments.

However, the Agency’s comments in general do address

the issues raised by the above mentioned commentors.

Board

Action

No formal Board action is necessary to address these

concerns.

BAKERY OVENS

United States Environmental Protection Agency

(USEPA)

(P.C.

7)

The USEPA provided specific comment on the proposal for

bakery ovens.

The USEPA has issued an “Alternative Control

Technique (ACT)” for bakery oven emissions.

(P.C.

7.)

The USEPA

indicates:

The ACT states that control efficiencies on ovens of 95

percent could be achieved at a reasonable cost using

catalytic oxidation.

The USEPA

is aware that in some States

bakeries have achieved reductions of

90 percent or more and

have not reported any problems in instituting a level of

control to achieve this.

Based in part on this information,

the USEPA believes that reasonably available control of VON

emission from bakery ovens is from 80 percent to 95 percent.

Illinois’ proposed regulations which require 81 percent

control of VON emissions from bakery ovens reflects USEPA’s

intent.

(P.C.

7.)

Interstate Brands Corporation (Interstate)

(P.C.

4 and

9)

Interstate Brands Corporation supported the comments made by

the American Bakers Association

(described below)

and also

initially commented that it urges:

an option be included to allow facilities to have a choice

to either control the total non—exempt emission units to the

percent reduction specified in the regulation or control all

non—exempt emission units to below 25 tons per year in

actual emissions as an alternative to the percent of control

level suggested.

(P.C.

4 at 1.)

Additionally, Interstate Brands Corporation asked that the

applicability section be more clearly worded and noted that the

recordkeeping requirements as proposed were unduly burdensome.

(Id.)

Interstate Brands Corporation states in its final comments

that it urges an exemption of all ovens with less than 15 tons

---

18

per year of actual emissions in all baking facilities.

(P.C.

9

at 1.)

Interstate Brands Corporation also states that it no

longer objects to the recordkeeping requirements after further

explanation of the requirements by the Agency.

(Id.)

American Bakers Association

(P.C.

8)

Dr. Ann Giesecke testified at the December

2,

1994,

hearing

on behalf of the American Bakers Association (Association).

In

addition,

several

bakers

from

the

Chicago area were present to

show support for the Association’s position as well as being

available to answer questions.

(Tr.

at 136—140.)

Dr. Giesecke

testified that bakers would like to do their part to see the

state

reach

the

15 percent goal; however,

he asserted that the

industry must also be able to maintain economic viability.

(Tr.

at 142—143.)

Dr.

Giesecke

points

out

that the bakery oven proposal is

regulating the emissions of “ethanol,

a non—toxic low reactive,

natural by—product of yeast fermentation that was captured under

the definition of VON because of the oxygen molecule.”

(Tr. at

143.)

Dr. Giesecke further states that “there

is minimal public

benefit and risk analysis benefit to eliminating ethanol

emissions from the atmosphere.”

(Id.)

Dr.

Giesecke requests

that the Chicago area have a 15 ton per year exemption rather

than 10 ton per year.

(Id.)

The cost differential for the

bakers in dollars per ton is “$8,000 per ton at the 15 ton level,

$14,000 per ton at the 10 ton level”.

(Tr. at 143.)

The Association in its final comments again requests that

the rule apply only to major sources,

i.e.

“sources with actual

emissions of 25 tons per year of VON in the Chicago area and

sources with actual emissions of 100 tons per year in the St.

Louis area.”

(P.C.

8 at 1.)

The Association suggests the

“definition of potential to emit be qualified to apply after

control equipment has limited emissions.”

(P.C.

8 at 2.)

The Association also agrees with the exemption for low

emitting

ovens and suggests that a 60 percent reduction

requirement is reasonable when actual emissions are less than 100

tons per year.

(P.C.

8 at

2.)

Kraft General Foods

(P.C.

10)

Deborah Becker testified on behalf of Kraft General Foods

(Kraft)

at the December

2,

1994, hearing.

Ms. Becker testified

concerning the control requirements and the emissions monitoring

requirements.

(Tr. at 126.)

Specifically,

Ms. Becker made four

recommendations in the area of control requirements to help

address cost-effectiveness.

(Tr. at 125-129.)

First, Ms. Becker

recommends that an exemption be included for small emitting ovens

with actual emissions of less than 15 tons per year.

(Tr.

at

---

19

127.)

Next,

Ms.

Becker recommends implementation of

the

emission

reduction requirement on a facility wide basis rather than on an

oven-by—oven basis.

(Id.)

Thirdly,

Ms. Becker suggests

establishing a facility-wide reduction of VOM at a 60 percent

level rather than 81 percent.

(Tr. at 128.)

Finally, Ms. Becker

recommends providing for innovative use of technology which would

encourage innovation in reducing emissions.

(Tr. at 128-129.)

Ms. Becker also testified that as an alternative to the

continuous monitoring requirement, compliance be verified through

calculation using the USEPA’s formula contained the ACT document.

(Tr. at 130; Attach.

25.)

Kraft’s final comments reiterate the position that

applicability of the VOM emission rates should be based on

actual, rather than potential emissions,

as well as the position

that the reduction should be 60 percent facility-wide.

Kraft

states that it is “encouraged by the willingness of the state to

address the need for flexibility for Illinois bakeries to meet

the requirements of the regulation.”

(P.C.

10 at 1.)

Kraft also

indicates support for the exemption of ovens which emit less than

15 tons per year.

(P.C.

at 2.)

Agency Response to Bakeries

The Agency,

in its final comments, has grouped its response

to the bakeries and states that:

The Agency believes that this proposal represents a

reasonable balance between the concerns of this industry and

Illinois’ need to reduce VON emission in the State’s

nonattainments.

(P.C.

16 at 25.)

Specifically, the Agency has agreed to request that the Board

amend the proposal to “extend the exemption to individual ovens

with actual emissions of 15 TPY or less, provided that total

emissions from all exempt ovens never exceed 25 TPY.”

(P.C.

16

at 28.)

In addition the Agency recommends “allowing for an

extended period of time for bakeries with emissions in the range

of

25 to 100 TPY to comply with the proposed control

requirements”.

(P.C.

16 at 31.)

Finally, the Agency is

recommending that the testing portion of the proposal be amended

to allow sources additional time to submit requested test results

to the Agency.

(P.C.

16 at 33.)

The Agency,

in response to comments regarding actual

emissions versus potential to emit,

noted that USEPA determines

that a source is a major source based on the potential to emit

rather than actual emissions.

(P.C.

16 at 26.)

A bakery may

limit its potential to emit through permit conditions to avoid

the applicability of the rule; however,

any change in the

definition of potential to emit or major source must come from

USEPA.

(P.C.

16 at 27.)

The Agency also states that the

---

20

proposed rule allows flexibility to bakeries for alternative

control as long as the overall emissions reduction goal is

achieved.

(P.C.

16 at 28.)

The Agency also responded to the comments requesting a

60

percent level of reduction versus

81 percent.

The Agency stated

that it was not convinced that a 60 percent facility-wide

reduction approach would be advantageous to many bakeries and the

Agency believes that 81 percent control

is achievable and cost

effective level of control.

(P.C.

16 at 30.)

In support of this

position, the Agency points to the USEPA’s comment

(~

P.C.

7).

The Agency has recommended that some flexibility be allowed in

this area and proposed a change

in the rulemaking which was

discussed above.

Board Action

The Board will accept the recommendation offered by the

Agency for amendments to the proposal on emission limits for

bakery ovens.

The Board appreciates the extensive comments

provided by the bakery industry; however, the remaining

suggestions for change offered by industry are not supported by

the record.

The USEPA clearly agrees with the Agency that 81

percent control is viable and achievable.

Further, many of the

provisions questioned by the industry such as recordkeeping and

monitoring have been further explained by the Agency, which

should alleviate these concerns.

The Board will amend the rules relating to bakery ovens at

second notice as follows:

Section 218/219.722 Control Requirements

~

~

~e~ufre~ae~its

of

th~

~

~ay

~1ect

1~e~e~ptf~

the

*~r~

quire~nt~

in,

subse~ti~)r~

(a~

(~

(a)

~1) or, (c~(2~pf

~

~eC~Qfl

afly ~ake~~y

ov~r~

~dth

acthal

VO~(

e

~si~ns

)~es~

~hafl~

~q~i

~rP~: ~

thpt th~~.ota1agtu~

~

~

~g~i

all

sq~1!exempt

bai~eryovens

never

e~eede

~

r

---

21

than .90,.7.:~4q.~10Qtons

of VON ~er.year

pr..are. limited

to less than 90.7 Mg

(100

tons)

of VOM emissions per

calendar

year... in.. the

absence

of

.

pir.. pollution, control

equip~uentt~ough production or capacit~yiimitat.ions

contained.’4n..federally.e.nf~rceablepermit conditions,.or

in a SIP revision:

fl

Operate

missions capture and ~ontr~1 eauipment

which..achiev~s.an overall. rethict.ion.. in

uncont~o1ledVON emissions ~

least

~O.percent

from each bakery oven with grated heat input

capacity of at least

2 mmbtu/hr or at least 586

KW; or

Z1

Provide an equivalent alternative control ~1an for

such bakery ovens at the source which h~sbeen

approved by the Agency

and

US~PAthrough

federally

enforceable permit conditions or

as

a

SIP

revision,

~

Any bakery oven that becomes subject to the

requirements of this Subpart at any time shall remain

subject to the requirements of this Subpart at all

times thereafter.

Section 218/219.728

Recordkeepinq and Reporting

~

Every owner or operator of ‘a’bakery oven which is

exempt from the control reguirements of this Subpart

because ~f the criteria specified in Section 218.722(b)

of this Subpart shall:

fl

Maintain records necessary to demonstrate, that the

actual VON emissions from exe~nptbakery evens are

less than or equal to

15 TP~1~or each bakery oven

and less than or equal to 25 TPY from a~lexempt

bakery. ovens combined... Such records shall.be

maintained for the most recent consecutive

3 year

period and shall be made available to the.A~en~

immediately upon request: and

21

Notify the Agency in writing if the actual VON

emissions from an exempt bakery. oven ever. exceed

15 TPY or the actual VOM emissions from p

combinatjon of exempt baker’~ovens.ever exceeds

25.

TPY. within 30 days after the exceedance occurs.

Such notice shall include a copy of

all’ records of

the

,

exceedance.

~

Every owner or operator of a bakery oven which is

controlling emissions as provided in Section 218.722cc.)

of this Subpart until March 15,

1998.

shall maintain

---

22

Section

218/219.730

Certification

~‘

On’or befoye March’ 15~•~996, or

u~çn

~.~tialst~rtup.

every. pwn~ror operator of a bakery oven which La

exempt from the control requirements of this Subpart

because .of.,the criteria specified

ir~

Section 2l8.722~bX

of this Subpart shall certify that actual VON ‘emissions

from any individual exempt bakery, oven never exceed .15

TPY and that VON emissions from all exempt bakery

ovens.

in the aggregate,

never exceed 25 PPY.

fl

On or before. March

15,

1996. or upon initial st~rtup.if

prior to March

15,

1998,

every owner or operator of ~

bakery oven which

is controlling emissions as provided

by Section’ 218.722(c)

of this SubDart. shall certif~!

that its maximum theoretical emissions as specified in

Section 218,722~c~are less than 90~7

Mci

(100

tons)

of

VO~!.,~eryear.

WOOD

FURNITURE

COATINGS

Harris Marcus Group

(P.C.

11)

Mr. Gordon Nelson testified on behalf of the Harris Marcus

Group

(Harris Marcus) at the Board’s December 2,

1994,

hearing.

(Exh.

22.)

Mr. Nelson indicated that he is Vice President of

Operations for Harris Marcus, which has a facility located at

3757 South Ashland in Chicago.

(Exh.

22 at 1.)

Harris Marcus is

a specialty manufacturer of portable lighting and promotional

furniture, originally founded in 1971.

(Exh.

22 at 2.)

Harris

Marcus employs approximately 500 people and produces 95

of its

product in Chicago.

(Id.)

The Harris Marcus facility is a

custom, made—to—order operation with over 15,000 finished goods

and end items with small quantity typical production runs of

12

to 36.

(Exh.

22 at 2—3.)

In these processes, use of a variety

of coatings is necessary.

In 1993 the facility used 40 different

wood coatings and 140 different coatings on its metal products.

(Exh.

22

at

3—4.)

Mr. Nelson testified that the estimated emissions of VOMs

from

the

facility in 1994

is “fifty—four

(54) tons per year,

thirty-two tons of which are attributable to wood furniture

coating operations,

fourteen

(14) tons to metal coating

operations,

and eight

(8) tons to other substrates.”

(Exh.

22 at

---

23

4.)

Mr. Nelson testified that Harris Marcus will be adversely

affected by the changes proposed in this rulemaking lowering the

threshold of applicability in wood furniture coatings from 100

tons

per year to 25 tons per year,

and the lowering of the VON

content applicable to the metal coating operations

at

the

Harris

Marcus facility.

(Exh.

22 at 5.)

Mr. Nelson testified that the Harris Marcus facility will

“be unable to meet the limitations of the proposed rules without

either severe restriction in its production or monetary burden.”

(Exh.

at

5.)

Mr. Nelson’s testimony indicates that the Harris

Marcus’ suppliers of wood and metal coatings have only recently

began to offer low VOM-content and water-based coatings.

(Id.)

Mr. Nelson states that the some of these coatings “while meeting

the

VON

limitations

of

the

regulations,

do not produce a saleable

product”.

(Exh.

22

at

5-6.)

Mr.

Nelson

further indicated that

the cost of add-on control equipment is estimated at an

annualized cost of VON emissions control ranging between $15,000

and $30,000 per ton with a cost for wood coating at $25,000 to

$50,000 per ton.

(Exh.

22 at 6.)

In its final comment, Harris Marcus suggests four options

which it

is requesting the Board consider to mitigate the

economic hardship the regulations as proposed will impose.

(P.C.

11 at 3—7.)

First, Harris Marcus suggests that the Board retain

the 100 ton per year VON applicability threshold for wood

furniture coating.

(P.C.

11 at 3.)

Harris Marcus points out

that

the

Agency

testimony indicated that the Agency does not

believe

any

wood

furniture

coating facilities in the Chicago

area

will be affected by the new applicability level.

(P.C.

11 at

3,

citing to Exh.

1 at 4 and Exh.

7 at 2.)

Further, the Agency is

“not required by USEPA to lower the applicability threshold for

wood

furniture

coating”

and USEPA has not issued a CTG for wood

furniture coating.

(P.C.

11 at 3,)

Harris

Marcus

argues

that the inclusion of the provision

lowering the wood furniture threshold is inappropriate as a part

of the Section 28.5 process.

(P.C.

1.

at 4.)

Harris Marcus

maintains that Section 28.5 allows adoption of “a rule that the

federal

Clean Air Act Amendments

(CAAA)

requires to be adopted

before December 31,

1996” and this proposal was init.iated to

fulfill requirements of Section 182(b) (1)

of

the

CAAA

relating to

reasonable further progress.

(Id.)

Harris Marcus points out

that

the

Agency

“conceded

that

it

has

not

relied

upon

lowered

applicability

threshold

to meet its 15

ROP obligations because

it has not expected any emission reductions from the proposed

rule change.”

(Id.)

The second suggestion from Harris Marcus is that the

proposal include an exemption for coatings used in small amounts.

(P.C.

11 at 5.)

Harris Marcus points to the agreement the Agency

made to allow an exemption for touch-up and repair coatings to

---

24

support its proposal.

(Id.)

Harris Marcus maintains that there

is no technical basis for limiting the exemption to touch—up and

repair coatings, when the operations at facilities like Harris

Marcus, where there are few if any production lines and coatings

are applied manually, also seem to fit the description.

(Id.)

Thirdly, Harris Marcus suggests that a separate category for

custom wood furniture and lamp manufacturing be established in

the proposed rule based on the language offered at hearing.

(P.C.

11 at 6.)

Finally, Harris Marcus suggests that use of

emission reduction credits be recognized.

(Id.)

Agency ResPonse to Harris Marcus

The Agency reiterates,

in its final comment, that the change

for wood coating will lower the applicability threshold;

however,

the Agency is not changing the VON content limits.

(P.C.

16 at

15.)

The Agency states that its proposal:

is a necessary part of the State’s 15

ROP Plan. If the

applicability level for this category is not lowered back to

the pre—FIP 25 TPY level,

it is possible for emissions from

this category to increase, creating a “backsliding” effect.

Those

increases

would

negatively impact the 15

ROP Plan and

make it difficult to obtain the necessary reductions.

(P.C.

16 at 16.)

The Agency concedes that there is no CTG for wood coatings

at the present time,

although USEPA anticipates publishing a CTG

in 1995.

(P.C.

16 at 17.)

The Agency maintains that, even

without the final

CTG, Illinois is required to regulate sources

above 25 tons per year because it is PACT.

(Id.)

Further, the

Agency states that Harris Marcus

is:

the only source objecting to the proposed changes to the

wood furniture coating regulations.

All other wood

furniture coating facilities identified by the Agency are

either already complying with the limits, which are not

changed by this proposal, or are emitting less than 25 TPY

of VOM.

(P.C.

16 at 20—21.)

The Agency also asserts that Harris Marcus should currently be

complying with current metal coating VON content limitations and

that Harris Marcus exceeds the 100 tons per year maximum

theoretical emissions for wood coatings as well.

(P.C.

16 at

18.)

With regard to the other suggested changes by Harris

Marcus, the Agency maintains that the record lacks sufficient

information to prdceed with those changes.

(P.C.

16 at 18-20.)

The Agency suggests that if Harris Marcus is a “unique” facility,

the changes are better addressed through an adjusted standard.

(P.C.

16 at 20.)

---

25

Board

Action

The Board will lower the applicability threshold for wood

furniture coating operations from 100 tons per year maximum

theoretical emissions

(NTE) to 25 tons per year potential to emit

(PTE)

as

requested

by the Agency in this proposal.

The Board

will make this change because the Agency has demonstrated that

the change in applicability level

is

a necessary part of the

Illinois 15

ROP Plan, and because the record shows that the

change in applicability is economically reasonable for the

majority of the sources in the Illinois wood furniture coating

industry.

The Board will also promulgate the VOM emission limits

for the different types of wood furniture coatings proposed by

the Agency at 218/219.204(1),

which represents no change from

current regulations.

The

CAA

requires all moderate and worse ozone nonattainment

areas to achieve by 1996 a 15

reduction of 1990 VON emissions.

The states are allowed to choose the control measures for the

nonattainment areas that will reduce VOM emissions to meet the

15

requirement, except that the

CAA

identifies the specific

measures that are not creditable towards the 15

reduction.

Further, the

CAA

requires states to account for any growth in

emissions after 1990

in developing the 15

ROP plan.

Therefore,

a state may develop a 15

POP plan which would require actual VON

emission reductions for certain categories of sources, and

maintenance of baseline emission levels for other source

categories to meet the 15

VOM

reduction

requirement.

For example,

if there are eight sources in a nonattainment

area with a 1990 baseline emission level of 100 tons per year,

a

15

ROP plan may require six of the sources to achieve reductions

totaling 15 tons per year

(15)

and require the remaining two

sources to maintain baseline emission levels.

Even though the

two sources are not required to reduce VON emissions,

they are an

integral component of the 15

ROP plan since they contribute

towards the 15

VON reduction by maintaining the 1990 baseline

emission levels.

The Agency notes that it developed a plan incorporating the

reduction measures for each nonattainment area (Chicago and East

St.

Louis) to reduce VON emissions to meet the 15

VON reduction

requirement.

(Prop. at 1-2.)

Further, the Agency states that

tightening the wood furniture coating applicability levels was

identified as a control measure for the 15

ROP plan for both

nonattainment areas.

(Prop. at 2-3.)

In this regard,

the Agency

states that while no reductions are expected from this category,

the proposed amendments are important because they ensure that

VON emission increases will not occur in wood furniture coating

operations

in comparison to the 1990 VOM emission level.

(Prop.

at 12.)

In effect, the proposed change of applicability level

for wood furniture coating operations from

100 tons per year MTE

---

26

to 25 tons per year PTE is an integral part of the Agency’s 15

ROP plan.

Therefore,

if the amendments to the wood furniture coating

requirements

are

not accepted by the Board as a part of the 15

POP plan, the Agency may have to identify other measures to

offset any increases in VOM emissions from wood coating

operations

above

the

1990 baseline levels to meet the 15

reduction requirement.

For these reasons the Board finds that

the inclusion of wood furniture coatings

in the proposed 15

POP

plan is necessary and this proposal was appropriately filed under

Section 28.5 of the Act.

The Board is also required by the Act to consider the

economic reasonableness and technical feasibility of rules before

promulgation.

The

Board

will

first

examine technical feasibility

and then the economic reasonableness of the proposed wood

furniture coating limitation.

As proposed, the amendments to the

wood coating requirements of Parts 218 and 219 do not change the

existing VON limits for wood furniture coatings.

The affected

facilities may comply with the proposed regulations

by: using

compliant coatings; adding emission control equipment; or

limiting emissions to less than 25 tons per year.

Regarding VON

limits for coatings, the Agency states that coatings with VON

content levels which meet the limitations are available and have

been used by numerous sources for several years.

(Prop.

at 19.)

Further, the Agency states that the coating applicators required

for wood furniture coaters in the proposed regulations are

available and used by most sources.

(Id.)

Regarding add-on

controls, the Agency notes that technology for controlling VON

emissions from wood furniture coating operations through add—on

control

is available and includes thermal or catalytic

incinerators and adsorption devices.

(Id.)

However, the Agency

admits that it could not find any instances of wood furniture

coating operations using add—on controls in Illinois

nonattainment areas.

(Attach.

16c at 3.)

In this regard, the

Agency states that it is

likely that any sources impacted by this

proposal

would

choose permit conditions to place them below the

applicability level or compliant coatings rather than add-on

controls as the method of compliance.

(Exh.7 at 3.)

Harris Marcus states that compliance with the proposed

regulations would result in severe restrictions on its production

or monetary burden because of the nature of its operation, which

involves

a custom made—to—order operation with over 15,000

finished goods end items.

Harris Marcus says that it used over

40 different coatings on its wood furniture products in 1993 of

which some coatings do not meet the proposed limitations.

(Exh.

5 at 4,

5.)

Further, Harris Marcus notes that its efforts to use

compliant coatings instead of high VOM-content coatings have not

resulted in the production of saleable products.

Thus,

Harris

Marcus contends that the only compliance alternative available

---

27

under the proposed regulations is add—on pollution control

equipment.

In this regard, Harris Marcus does not question the

availability of appropriate control technology,

but argues that

the costs associated with the installation of such controls are

unreasonable.

The Agency’s position on technical feasibility of the

proposed regulations is based on the fact that the proposed VON

limits on coatings are the same as existing limits and on the

observation that all existing sources are already in compliance

with the proposed regulations.

The Agency identified 19

potentially affected sources based on a review of its emission

inventory system (EIS).

(Attach.

16c at 6.)

The Harris Marcus

facility

was

not

a

part

of

this list of affected facilities.

The

record

indicates

that

the

19 existing sources identified by the

Agency are either complying by using compliant coatings or

emitting less than 25 tons per year of VON.

None of these 19

compliant sources are using add—on controls.

Harris Marcus

contends that the only compliance alternative available for its

facility is add—on controls.

The information in the record concerning economic

reasonableness includes a discussion by the Agency of the costs

of both reformulated coatings and add—on controls using the

information included in the USEPA’s draft CTG for wood furniture

coating operations.

The Agency has stated that one of the

reasons for USEPA not including the CTG for wood furniture

coating with other surface coating CTGs is due to the

complexities involved in this industry.

(Attach.

16c at 3.)

According to the Agency, the total annual cost of switching from

existing coatings to reformulated coatings range from:

$85,330 to

$1,128,860 for waterborne coating systems; $38,280 to $644,915

for hybrid waterborne coating systems; $144,170 to $1,083,480 for

polyester/polyurethane (pe/pu)

system;

and $162,040 to $1,606,960

for hybrid pe/pu system.

(Attach.

l6c at 10-13.)

These costs

consider material storage, drying capabilities, paint

circulation, and the need for clean room environment.

The cost

break—downs for the four types of reformulated coatings are

provided in Exhibit 23.

Regarding add-on controls, the Agency notes that the costs

vary with the size of the source and the type of equipment used.

(Prop.

at 19.)

Information presented by the Agency indicates

that for sources emitting 50 TPY to 500 TPY, the capital costs

for control devices range from $446,400 to $11,393,400.

The

operating costs range from $170,700 to $3,439,500.

(Attach.

16c

at 9.)

These costs are based on a scheme where a single control

device controls all VOM emissions from the source.

The costs for

different types of control equipment are presented in the

proposal.

(Id.)

---

28

Harris Marcus also

presented

a

preliminary

estimate

of

annualized cost of VON control for its coating processes.

According to this information, the total direct annual costs for

operating a thermal regenerative incinerator would be $414,079

and for a thermal recuperative incinerator would be

$1,873,000.

(Exh.

23.)

In addition, Harris Marcus expects equipment and

engineering costs to exceed $1,500,000.

These estimates cover

all coating operations, which include metal and wood coating

lines.

The cost information provided by Harris Marcus is

presented in Exhibit 23.

In summary, the Agency has requested that the Board lower

the applicability level for wood furniture coating operations

from 100 tons per year MTE to 25 tons per year PTE.

The Agency

states that the change is part of the state’s 15

ROP Plan, and

the change is economically reasonable and technically feasible

because 19 potentially affected facilities can be in compliance

at no cost.

Harris Marcus contends that they are adversely

affected because lowering the VON emission applicability level

would require them to use unreasonably expensive add—on equipment

to control VON emissions.

After careful consideration of the

record, the Board finds that the change

in applicability level is

economically reasonable and technically feasible for the majority

(19 out of 20)

of wood-furniture coating operations

in Illinois,

and therefore the Board will adopt the proposed changes at

Sections 218.208(b)

and 219.108(b).

There

is not enough specific

information in the record about Harris Marcus’ operations to

determine whether or not a different VON emission applicability

level should apply to it.

Harris Marcus might wish to consider

other relief as provided for in the Act such as filing a proposal

with the Board for possible site-specific rulemaking or adjusted

standard relief.

In reviewing the other requests for changes by Harris

Marcus, the Board agrees with the Agency that the record lacks

sufficient information to proceed at this time.

The Board again

encourages Harris Marcus to review the possibility of a site—

specific rulemaking or adjusted standard to address its remaining

concerns.

SOCMI

Stepan Company

(P.C.

12)

Stepan Company

(Stepan) requests in its comment that the

proposed rule regulating SOCNI be extended to include Stepan’s

non-SOCMI processes.

(P.C.

12 at 1-2.)

Stepan maintains that

its processes are virtually identical to the processes which

would be covered by the Agency’s proposal, and in fact those

units can produce either SOCMI or non-SOCNI products.

(Id.)

Stepan argues that the approach proposed in Subpart V is more

appropriate than the provisions of the general rule,

and

---

29

inclusion

of

Stepan’s

processes

in

this rulemaking might

alleviate the need for site-specific relief being sought by

Stepan in two proceedings, one before the Board

(AS 88-2)

and one

rule before USEPA.

(P.C.

12 at 2,

8—10.)

Stepan points out that the Agency,

in response to

questioning,

agreed

that

the

approach

proposed

for

SOCNI

sources

is “technically appropriate for Stepan’s continuous non—SOCNI

distillation and reactor processes”.

(Tr.

at 44-46; P.C.

12 at

2.)

Stepan also provides discussion of three of its processes

and points out similarities between the non—SOCMI processes and

the SOCMI processes.

Stepan notes that “some of Stepan’s

products are listed as SOCMI chemicals in the Federal CTG list

but not in the State’s Appendix A list.”

(P.C.

12 at 6.)

Based

on the comments filed and the testimony of the Agency, Stepan

urges the Board to adopt amendatory language which will include

Stepan’s processes at its Millsdale Plant in Subpart V of the

proposal.

(P.C.

12 at

9 and 12.)

Agency Response

The Agency agrees that the VOMs produced in Stepan’s

continuous reactor and distillation operations

in Stepan’s

Nillsdale facility “have characteristics similar to SOCNI

chemicals that are manufactured as a primary product.”

(P.C.

16

at 38.)

The Agency states that it “believes that inclusion of

these processes is reasonable”.

(Id.)

Therefore, the Agency has

recommended an amendment to include Stepan’s processes in the

proposal.

(P.C.

16 at 38—39.)

Board Action

The Board finds that the record supports the inclusion of

Stepan’s processes in the rule to be subject to the SOCMI

regulations.

Therefore the Board will amend Section 218.431 by

adding subsection

(a) (2) which will read:

ZL

All continuous distillation and reactor process

emission units not sublect to Section 218.520 throucih

218.527 of this Part, and located within Stepan

Company’s Nillsdale manufacturing facility, Elwood,

Illinois.

TOUCH-UP AND REPAIR COATINGS, MARINE ENGINE COATINGS

AND

CROSS-LINE AVERAGING

1.

Illinois Environmental Regulatory Group

(IERG)

(P.C.

13)

IERG, in its final comment, notes that IERG has met with the

Agency to discuss concerns about the regulatory proposal.

Specifically,

those concerns include marine engine manufacturing

industry’s ability to comply with the coating standards, the

---

30

necessity of an exemption from the coating standards for touch—up

or repair coating and the availability of cross—line averaging

provisions to show compliance with the coating standards.

(P.C.

13 at 1.)

IERG also expressed support for the consensus reached

between S

&

C Electric and the Agency for cross—line averaging,

which is discussed in detail below.

(P.C.

13 at 2.)

Ms. Elizabeth Steinhour testified on behalf of IERG

regarding

touch—up

and

repair

coatings

(Exh.

30).

Ms.

Steinhour

testified that scratches or nicks may occur during the

manufacturing process and repair is made using a limited amount

of coating.

(Exh.

30 at 2.)

Ms. Steinhour states:

It

is my understanding that generally, but not in all

instances, the application of touch-up coatings which would

meet the emissions limitations dictated by the proposed

Sections 218/219.204

is inappropriate in that such coatings

are either not readily available,

inadequate for the purpose

intended, or would require a substantial revision of the

application processes currently utilized for touch—up

operations.

(Id.)

Ms. Steinhour also testified that “the inclusion of such

a touch-

up exemption within the regulations would not constitute a

loosening for the Federal Implementation Plan.”

(Exh.

30 at 6.)

IERG provided proposed amendments to the proposal which

would exempt touch—up and repair coatings.

(P.C.

13 at 3-6.)

IERG states that it and the Agency agree that “the adoption of

the proposed exemption would place necessary, yet practical,

limitations on the use of touch—up and repair coatings.”

(P.C.

13 at 6.)

IERG also states

in its final comment that it supports

the adoption of cross—line averaging provisions including the

revisions proposed by S

& C Electric

(~

P.C.

15,

as discussed

above).

(Id.)

Agency ResPonse to IERG

The Agency agrees that a higher VOM content for marine

engine coatings is necessary.

Therefore,

the Agency is

recommending an amendment to the proposal which would raise the

limit to 3.5 lb/gal for as-applied coating for baked

applications.

(P.C.

16 at 11.)

The Agency notes that of

significant importance is the fact that various gaskets and

plastic parts used in the paints sub—assemblies are subject to

failure at higher baking temperatures that are employed to

accommodate lower VON content coatings.

(Id.)

Failure of these

gaskets and parts could create loss of torque control, which has

potential serious product reliability and safety ramifications.

(Id.)

---

The

Acenc~ ±~a,sc

reccmmendinc

a

chance

in

cross’~~ine

averacinc

as

discussed

:r.

detail

ne,Low

with

the

comments

filed

by

S

& c

lectric,

Board

~.ctH~on

The Boarct accepts the recommendathons

for amenamenth

as

Droposed

by

the

ERC~and

the

Agency,

The

Board

will

amend

Section

~~S.204(~~

to read.

~

Air

Dril.d

0.4.2

(3.5.~

0.42*.

______

~

Baked

~J

Primer/Topcoat

0.42

(3.5)

9,42*

______

il;

Corrosion

0.42

(3.5)

resistant

0.28*

(2.3)~

basecoat

~

Clear Coating

0.52

(4.3)

0.52*

(4~3)*

II

Definitions

~j

For

purposes of subsection 218.204(i)(5)

of

this

Section, the following terms are

defined:

il

“Corrosion resistant basecoat~ means,

for purposes of subsection

2l8.204(~?i)(5)(B~iflof this Section,

a

water—borne epoxy coating applied via an

electrodeposition process to a metal

surface prior to spray coating, for the

purpose

of enhancing corrosion

resistance.

~Jj,

“Electrodeposition process” means for

the purposes

of

subsection.2l8.204(i) (5)

of this Section,

a water—borne dip

coating process

in which opposite

electrical

charoes are

applied

to

the

substrate and the coating.

Thecoating

is attracted to the substrate due to the

electrochemical potential difference

that

is created.

---

‘Marine encjr~ecoating” means, for

p~r~osesof subsection 218.204(j) (5)

01

isSection.

any extreme performance

~rotective,

decorative or functional

~

to

an engine that is

used to propel watercraf~

~~urposes

of subsection ~l8.2O4(1j~6~

of

this

Section

‘metallic_coating” means a

coating which contains more than

1/4 lb/gal

of moti

particles,

as app1ie~

Thc board

~i1l

also amend Secticn 218/219.208

to include:

c

~nanc_after

March

16

10C~t~ limitations of this

Subpart shall not apPly to touch—up and repair coatings

used

by

a coating source described by subsections

218.204(h)

(d)

,

(f)

,

(g)

(1),

())

,

(n~

and ~

of

this Subpart; provided

that

the source-wide volume of

such coatings used does not exceed 0.95

1

(1

quart) per

ei.g.ht-hour

period

or exceed 209 1/yr

(55 gal/yr)

for

any rolling twelve month period.

PecordkeePing and

reporting for touch-j~pand repair coatings shall be

consistent with Section 2~8.211(b)(4) of this subpart.

d’~

On and after March 15,

1996,

the owner or operator of

a

coating line or

a groun

of coating lines using touch—up

and repair coatin~sthat are exempted from the

limitations of Section

218.204

(b)

,

(d)

,

(f)

•

(g)

,

(1).~

(1).

(n)

and

(0)

of this

Subpart because of the

provisions

of Section 213.208(c)

of this Subpart shall:

~j

Collect and record the name,

identification

number, and volume used of each touch—up and

~pair

coating, as applied on each coating line,

per eight—hour period and per month

~

Perform calculations

on

a d~i1ybasis.~ arid

maintain at the source records

of such

calculations

of the combined volume of touch—up

and repair coatings used source—wide for each

eight—hour period

~

Perform calculations

on

a monthly basis,

arid

maintain at the source records

of such

calculations

of the combined volume of touch-up

and repair coatings used source-wide for the month

and the rolflng twelve month period.

~‘

Prepare and maintain

at the source an annual

summary of the information regu~red to be compiled

p~rsuant to subsection (c~4)(A) and (c)(~4)(B)of

---

33

tL:~Section on or be±crsJanuary 31

of the

following year~

~j.

~intain

at the source for a minimum period of

three years all records required to be

kept

under

this

subsection

and

make

such

records available tc

the Agency upon request

~

Notify the Agency in writing

if the use of touch—

j~pend repair coatinas at the source ever exceeds

a

volume of

0.95

1

(1 quart) per eight—hour period

or exceeds 209 1/yr

(55 gal/yr)

for any rolling

twelve month period wk~in 30 ~

after ~nv such

exceedanc.e.

Such notification shall

jpclu6e

a

copy of any records of such exceedance; and

~‘j~

“Touch-up

and

repair

coatings”

rieans,

for

purposes

of

35

111.

Adrn.

Code

218.208,

any

coating

used

to

ggy~rminor

scratches

and

nicks

that

occur

during

manufacturj~q

and

assembly

processes.

Section

218.431

will

read:

F

The

provisions

of

Sections

~18

~21

through

213

436

of

this

subpart

shall

apply

to

~j

Every

owner

or

operator

of

any

chemical

manufacturing

process

unit

that

manufactures,

as

a

primary

product,

one

or

more

of

the

chemicals

listed

in

Appendix

A

of

this

Part

and

that

chemical manufacturing process unit causes or

allows

any

reactor

or

distillation

unit,

either

individually

or

in

tandem~

to

~,isch~rge

o~e~r

more process vent streams either directly to the

atmosphere

or to

a recovery system,

and

Section 219.431 will

be amended to read:

~j

Toe provisnons

of

Sections

219

431

through

219 436 of this

Subpart shall apply to every owner

or operator of any

chemical manufacturing process unit that manufactures,

as

a

primary product,

one or more of the chemicals listed

in

appendix A of this Part and that chemical manufacturing

process unit causes

or allows any reactor or distillation

unit,

either individually

or in tandem., to discharge one or

more process vent streams either directly to the atmosphere

or to

a recovery system.

2~ Outboard Marine Corporation

(P.C.

14~

Outboard Marine Corporation

(Outboard)

filed

a comment in

support of two specific revisions initially proposed

in the

---

34

~estimonv

of

Elizabeth

Steinhour

of

~ERG

(which was discussed in

detail

above)

Outboard

supports

a

separate

category

under

Section

218.204(j)

regulating

miscellaneous

metal

parts

and

product

coatings

for

marine

engine

coatings.

(P.C.

14

at

1—2.)

Outboard

maintains

that

coatings

that

meet

the

limits

proposed

are

not

available

for

marine

engine

coatings,

so

a

specific

section

addressing marine engine coatings

is necessary.

(P.C.

14

Ft

2.)

Outboard

also

supports

an

exemption

for

touch—up

coating.

Outboard

points

out

that

it

is

critical

that

it

be

allowed

to

touch—up

any

scratches,

nicks,

or other minor paint defects which

ini~bt

occur

during

manufacturing

and

the

assembly

process.

(Id.)

Low

VOM

coatings

are

not

viable

and

Outboard

is

not

aware

of

an

alternative

low-VOM

technology

that

could

be

used.

(P.C.

14

at

3-~•’

outboard

does

ask

that

the

Board

consider

a

daily

limit

for

touch—up

coatings

rather

than

the

eight

hour

limit

proposed

by IERG.

(P.C.

14

at

3.)

Outboard

argues

that

recordkeeping

for

an eight hour period would be burdensome and impractical.

(P.C.

14

at

3—4.)

~enc~

RespQ.nse

to

Out~o.~i:~

The

~.gency

did

not

specifica11~’

respond

to

the

comments

of

Outboard.

Rather

the

Agency

responded

to

IERG

comments

which

were

similar

to

the

comments

by

Outboard.

Those

comments

and

the

response

are

discussed

above.

Board

Action

The Board finds that the record lacks sufficient information

to support the adoption of

a daily limit

for touch-up coatings

recommended

by

Outboard.

3.

s&CEigctrjq,,Compa~y

(P.C.

15)

Mr.

Robert

Sullivan

testified

on

behalf

of

the

S

&

C

Ellectric

Company

at

the

Board’s

December

2,

1994

hearing.

Mr.

Sullivan

testified

that

the

S

&

C

Electric

Company

owns

and

operates

a

facility

in

Chicago

which

manufactures

as

one

of

its

products

a

high-voltage

metal

enclosed

switch

gear.

(Exh.

33

at

1.)

Mr.

Sullivan

testified

in

support

of

the

adoption

of

the

cross-line

averaging

proposal.

(Exh.

33

at

2.)

S

&

C Electric

notes

in

its

final

comment

that

the

cross—

line averaging provision

in this proposal does not “anticipate

the actual situation at

S

&

C’~.

(P.C.

15 at

3.)

That situation

is that

S

& C has spent to date about $10 million developing and

implementing the use of powder coatings prior to this rulemaking.

~xd.

As

a result1

S

&

C has reduced

its emissions over 15,

but

at

this time

is unable to convert any additional

lines to powder

coatings.

(P.C~

15

at

3.)

Therefore,

S

&

C

and

the Agency have

---

35

developed

proposed

language

which

would

allow

cross—line

averaging

using

coating

lines added after July

1,

1988 under very

limited circumstances.

(PC

15 at

4-5.)

s

&

C

indicates

in its final comment that it supports the

exemption for touch-up and repair coatings proposed by IERG.

(P.C.

15 at

6.)

~~c~7Re~pQflSe

tq ~

&c

The Agency,

in its

final

comments

recommends

a change

in

the proposal which would allow credit to be given to facilities

which

were

making the change to

powder

coatings

even before there

was

a great

incentive.

(P.c.

16 at

15.)

The change

is being

suggested to Sections 218/219.212 and 218/219.213.

Board AcLi.Qfl

The Board accepts the recommendations

for amendments

as

proposed

by

S

&

C and the Agency.

The Board will

amend Sections

216.212.,

218.213,

219.212 and 219,213

to

read:

Section

218/219.222

Cross-Line

Averaging

to

Establish

Compliance

for

Coating

Lines

~:

Notwithetandina

subsection

(a)

of this Section.

any

owner

or operator of a co~in

line subi~ctto

the

limitations set forth

in Section 218.204 Of this

Subpart

and electing to rely on this Section

j~o

demonstrate

compliance

with

this

Subpart, may also

include

as

a participating coating

line,,

until December

31,

1999,

only,

any replacement line that satisfies all

~f the following conditions:

~J

The replacement line is operated as a powder

coating line

2)

The replacement l~ne~as

added after July

1.. 1988

and

~

The owner

or operator also includes as

a

participating coating line one or more coating

lines that satisfy the

criteria

of

a

replacement

line,

as described

in subsection

(a)

of this

Section.

~

To

demonstrate

compliance

with

this

Section,

a

source

shall establish the following:

~

An alternative dail17 emission

limitation shall be

determined for all

participating

coating

lines

at

the source according to subsectior’

(dj (2)

of this

---

36

Section.

~

facto~d in

.

~adh:

day

to..: detho~•tràte

:.dpLiahc~i.~.:

Provided

com~1ianco

is

~tgbihed.ia~t~itb~the

~ec~ui~±emént.s.

ih

this

subsect.

ion,.

bdthin~hin:::t.hi:~s

Section:reguir~s.dai.Iyo.p~àtibli:ofteàdh

~rticipatihq.

inc..

•.

Actual

daily

emissions

from

ci

:

partidi~ati~qcoating

lines (~jshall

never

exceed the alternative daily emission limitation

L~L

and shall

be

calculated

by

use

of

the

following

equation:

Section

218

219.213

Recordkeepinc

and

Reporting

for

Cross—Line

Averaging Participating Coating Lines

‘-iv

owner

or operator of

a coating

line that elects to comply by

~nsof

Section 218,212 of this Subpart shall establish the

~i1o~in~

a’

By~he

date

consistent

with

Section

218.210(f)

of

this

Subpart,

or

upon

initial

start—up

of

a new coating line

replacing

a pre-existing coating line,

as defined

in

Section 218.212

of this Subpart,

or upon changing the

method

of compliance for

a pre-existing coating line

from

the

requirements

of

Section

218.204

or

Section

218.207

of

this

Subpart

to

the

requirements

of

Section

218.212

of

this

Subpart,

the

owner

or

operator

of

the

source

shall

certify

to

the

Agency

that

each

p~xticipatinqcoating

line,

as determined

in accordance

with

Section

218.212

of

this

Subpart,

will

be

in

compliance with Section 218.212

of this Subpart

on and

after

a date consistent with Section 218.210(f)

of this

Subpart,

or on and after the initial start—up date

of

such participating coating

lines.

Such certification

shall

also

include:

~j.

The method by which the owner or operator has

calculated

K,

for the equation contained in

Section

218,222(.d)~..2:)(B).:of this Subpart,

if

applicable.

CONCLUSION

The Board carefully considered all public comments,

as well

as the testimony and exhibits

in this matter.

Although areas of

controversy still exist, the majority

of the proposal

is

supported

by the regulated community.

Where controversy remains

in the areas of bakeries and plastic parts coatings,

the Board

found at second notice that the record supported proceeding with

those :proPOSed amendments as modified by suggestions from the

Aaency.

In the area of wood furniture coatings,

the Board has

found that the Agency—proposed amendments

to the wood furniture

---

37

coatings regulations are appropriate for a Section 28.5

rulemaking and therefore,

those provisions also proceeded to

second notice.

The Board accepted all agreed upon requested changes as

those changes were supported by the record before the Board.

The

Board found that the proposed rules are technically feasible and

economically reasonable, and that the rules are necessary to meet

the requirements of the Clean Air Act.

The Board found that the

record supported proceeding with the proposed rules,

as amended,

to second notice.

The Joint Committee on Administrative Rules issued

a

certificate of no objection to the proposed rules at the March

14,

1995 meeting.

JCAR had requested and the Board agreed to

nonsubstantive typographical changes.

Thus,

the proposal may now

proceed to final adoption.

The Board finds that the record

supports proceeding to final notice with the proposal as amended

at second notice and in this opinion.

The Board hereby adopts

this proposal for final notice.

ORDER

The Board directs the Clerk to cause the filing of the

following proposal for final notice with the Secretary of State

Code Unit for publication in the Illinois Register:

TITLE 35:

ENVIRONMENTAL PROTECTION

SUBTITLE B:

AIR POLLUTION

CHAPTER

I:

POLLUTION CONTROL BOARD

SUBCHAPTER

C:

EMISSION STANDARDS

AND

LIMITATIONS

FOR STATIONARY SOURCES

PART 211

DEFINITIONS AND GENERAL PROVISIONS

SUBPART

B:

DEFINITIONS

Section

211.660

211.670

211.680

211.820

211.980

211.1780

211.1880

211.1900

211.2290

211.2360

211.2365

211.2630

Automotive/Transportation Plastic Parts

Baked

Coatings

BakerY Oven

Business Machine Plastic Parts

Chemical Manufacturing Process Unit

Distillation Unit

Electromagnetic Interference/Radio Frequency

Interference

(EMI/RFI)

Shielding Coatings

Electrostatic PreP Coat

Fermentation Time

Flexible Coating

Flexible

Operation

Unit

Gloss Reducers

---

211.4055

Non—Flexible Coating

211.4740

Plastic

Part

211.5065

Primary Product

211.5480

Reflective Arcrent Coating

211.5600

Resist

Coat

211.6060

Soft Coat

211.6140

Specialty Coatings

211.6400

Stencil Coat

211.6580

Texture Coat

211.6880

Vacuum Metallizing

211.7400

Yeast Percentage

AUTHORITY:

Implementing Sections 9,

9.1 and 10 and authorized by

Section 27 and 28.5 of the Environmental Protection Act

(Ill.

Rev.

Stat.

1991,

oh.

111’s,

parc.

1009,

1009.1,

1010 and 1027),

(P.A.

07—1213, effective September 26,

1992)

415

ILCS 5/9,

9.1,

10,

27 and 28.5).

SOURCE:

Adopted as Chapter 2:

Air Pollution,

Rule 201:

Definitions, R71—23,

4 PCB 191,

filed and effective April

14,

1972; amended in R74—2 and R75—5,

32 PCB 295, at

3 Ill. Reg.

5,

p.

777, effective February

3,

1979;

amended in R78—3 and

4,

35

PCB 75 and 243,

at

3

Ill.

Reg.

30,

p.

124, effective July 28,

1979; amended in R80-5, at

7

Ill.

Reg.

1244, effective January

21,

1983; codified at

7

Iii. Req.

13590;

amended in R82—1

(Docket

A)

at 10 Ill. Reg.

12624, effective July 7,

1986; amended in

R85—21(A)

at

11 Ill. Reg.

11747, effective June 29,

1987; amended

in R86—34 at

11 Ill. Reg.

12267, effective July 10,

1987; amended

in R86—39 at

11 Ill. Reg.

20804,

effective

December

14,

1987;

amended in R82—14 and R86—37 at 12 Ill. Reg. 787, effective

December 24,

1987; amended in R86—18 at 12

Ill.

Reg.

7284,

effective April

8,

1988; amended in R86—10 at 12 Ill.

Reg.

7621,

effective April

11,

1988; amended in R88—23 at

13 Ill. Reg.

10862, effective June 27,

1989; amended in R89—8

at

13 Ill. Req.

17457, effective January

1,

1990; amended in R89-16(A) at 14

Ill.

Reg.

9141, effective May 23,

1990;

amended in R88—30(B) at 15

Ill.

Reg.

5223, effective March 28,

1991; amended

in R88—14 at

15

Ill. Reg.

7901, effective May 14,

1991; amended in R91—10 at

15

Ill. Reg.

15564,

effective October

11,

1991; amended in R91-6 at

15

Ill. Reg.

15673,

effective October 14,

1991; amended

in R91—22

at 16 Ill. Req.

7656, effective May

1,

1992; amended in R91-24 at

16 Ill.

Reg.

13526, effective August 24,

1992;

amended in R93-9

at 17 Iii. Reg.

16504, effective September 27,

1993; amended in

R93-11 at 17 Ill. Reg.

21471, effective December 7,

1993; amended

in R93—14 at

18

Ill.

Reg.

1253, effective January

18,

1994;

amended in R94-12 at 18 Ill. Reg.

14962, effective September 21,

1994; amended in R94-14 at 18

Ill.

Reg.

15744, effective

October

17,

1994; amended in R94—15 at 18

Ill.

Req.

16379, effective

October 25,

1994;

amended in R94—16 at

18

Ill.

Reg.

16929,

effective

November

14,

1994;

amended

in

R94—21

at

19

Ill.

Reg.

____

effective

.

BOARD NOTE:

This Part implements the Environmental Protection

Act as of July 1,

1994.

SUBPART B:

DEFINITIONS

---

39

Section 211.660

Automotive/Transportation Plastic Parts

“Automotive/transportation plastic parts” means the interior and

exterior plastic components of automobiles, trucks, tractors,

lawnmowers, and other like mobile eguipment intended for primary

use on land, with the exception of the following:

plastic carts

coated on the main (body)

paint line in automobile and light duty

truck assembly plants, and plastic parts coated during

refinishing of automobile,

trucks,

tractors, lawnmowers and other

like mobile equipment.

(Source:

Added at

_____

Ill.

Reg.

_________,

effective

____

Section 211.670

Baked Coatings

“Baked coatings” means any coating which is cured or dried in an

oven where the oven air temperature exceeds 9OQC (l94QF)~-,or anY

coating

which

is

cured

in

any

manner

that

does

not

otherwise

fit

into the definition of “air dried coatings,” as defined in

Section 211.330 of this Part.

Section 211.680

Bakery Oven

“Bakery

oven”

means

an

oven

used

at

any

time

for

the

purpose

of

baking yeast—leavened products,

including,

but not limited to,

breads.

rolls

and

buns.

(Source:

Added at

_____

Ill.

Reg.

_________,

effective

____

Section 211.820

Business Machine Plastic Parts

“Business machine plastic parts” means the plastic housings and

other exterior plastic components of electronic office equipment

and of medical and musical equipment,

including, but not limited

to the following:

computers, monitors, printers and keyboards,

facsimile

machines,

copiers, microfiche readers, cellular and

standard phones, and pencil sharpeners. This definition excludes

internal electrical components of business machines.

(Source:

Added at

_____

Ill.

Reg.

__________,

effective

____

__________________________________________________________)

Section 211.980

Chemical Manufacturing Process Unit

“Chemical manufacturing process unit” means the equipment

assembled and connected by pipes or ducts to process raw

materials and to manufacture an intended product.

For purposes

of 35 Ill. Adm.

Code 218.431 through 218.436, and 219.431 through

219.436, the chemical manufacturing process unit includes

reactors

and

their

associated

product

separators

and

recovery

devices, distillation units and their associated distillate

receivers,

and recovery devices.

A chemical manufacturing

---

40

process unit includes, but is not limited to, any combination of

pumps.

compressors, agitators,

pressure relief devices, sampling

connection

systems,

open

ended

valves

or

lines,

valves,

connectors,

instrumentation

systems,

and

control

devices

or

systems.

A chemical manufacturing process unit is identified by

its primary product,

as defined in Section 211.5060 of this Part.

(Source:

Added at

_____

Ill.

Reg.

_________,

effective

____

Section 211.1780

Distillation Unit

“Distillation unit” means a device or vessel in which one or more

feed streams are separated into two or more exit streams,

each

exit

stream

having

component

concentrations

different

from

those

in

the

feed

stream(s).

Separation is achieved by

a

redistribution of the components between the liquid and the vapor

phases by vaporization and condensation as they approach

equilibrium

within

the

distillation

unit.

A

distillation

unit

includes,

but

is

not

limited

to,

the distillate receiver,

reboiler, vacuum pump,

steam let and any associated recovery

system.

(Source:

Added at

_____

Ill. Reg.

_________,

effective

____

___________________________________________________________)

Section 211.1880

Electromagnetic Interference/Radio Frequency

Interference

(EMI/RFI)

Shielding Coatings

“Electromagnetic

mt

erference/radio frequency interference

(EMI/RFI) coatings” means coatings used on busmess machine

plastic housings to attenuate electromagnetic and radio frequency

interference signals that would otherwise pass through the

plastic housing.

at

Ill.

Reg.

)

Electrostatic Prep Coat

effective

(Source:

Added

Section 211.1900

“Electrostatic

prep

coat”

a

-i~

that is applied to a

plastic part solely to provide conductivity for the subsequent

~

of a prime coat,

a topcoat, or other coating through

the use of electrostatic application methods.

An electrostatic

prep coat is clearly identified as an electrostatic prep coat on

its accompanying material safety data sheet.

(Source:

Added at

_____

Ill. Reg.

_________,

effective

____

‘a

p..

#a.......j_~,aa

—

—

Section 211.2290

Fermentation Time

---

41

“Fermentation

time”

means

the

time

elapsed

between

adding

yeast

to

the

dough

and

placing

the

product

into

the

oven,

expressed

in

hours to the nearest one-tenth hour.

(Source:

Added at

Ill. Reg.

,

effective

Section 211.2360

Flexible Coating

“Flexible

coating”

means

a

taint

with

the

ability

to

withstand

dimensional changes.

(Source:

Added

at

_____

Ill.

Req.

,

effective

____

Section 211.2365

Flexible Operation Unit

“Flexible operation unit” means a chemical manufacturing process

unit that manufactures different chemical products periodically

by alternating raw materials or operating conditions.

(Source:

Added at

_____

Ill.

Reg.

,

effective

____

__________________________________________________________)

Section 211.2630

Gloss Reducers

“Gloss

reducers”

means

a

low—gloss

coating

formulated

to

eliminate glare for safety purposes on interior surfaces of a

vehicle, as specified in the U.S. Department of Transportation

Motor Vehicle Safety Standards.

(Source:

Added at

Ill.

Req.

__________,

effective

Section 211.4055

Non-Flexible Coating

“Non—flexible coating” means a paint without the ability to

withstand dimensional changes.

(Source:

Added at

_____

Ill. Reg.

,

effective

____

__________________________________________________________)

Section 211.4740

Plastic Part

“Plastic tart” means a product, or piece of

a product, made from

a substance that has been formed from resin through the

application

of

pressure

or

heat

or

both.

(Source:

Added at

_____

Ill. Reg.

,

effective

____

Section 211.5065

Primary Product

---

42

“Primary Product” means a product of a chemical manufacturing

process unit that shall be determined according to the procedures

specified as follows:

~

If a chemical manufacturing process unit produces more

than one intended chemical product, the Product with

the greatest annual design capacity on a mass basis

determines the primary product of the process.

~j

If a chemical manufacturing process unit has two or

more products that have the same maximum annual design

capacity on a mass basis and

if one of those chemicals

is listed in 35 Ill. Adm. Code 218.ApPendix A or

219.Appendix A, then the listed chemical is considered

the Primary product.

If more than one of the products

is listed in Appendix A of 35

Ill. Adm. Code 218 or

219, then the owner or operator may designate as the

primary product any of the listed chemicals.

~

For a chemical manufacturing process unit that is

designed and operated as

a flexible operation unit and

is used predominantly to produce one or more of the

listed chemicals in 35

Ill.

Adm. Code 218.AiDpendix A or

219.Appendjx A, the primary product shall be determined

based on the expected utilization for the five years

following promulgation for existing sources and based

on the expected utilization for the first five years

after initial start—up for new sources.

fl

If the flexible operation unit produces one

product for the greatest annual operating time,

then that product shall represent the Primary

product of the flexible operation unit.

21

If the flexible operation unit produces multiple

chemicals

e~uallv

based

on

operating

time,

then

the product with the greatest annual production on

a mass basis shall represent the primary product

of the flexible operation unit.

(Source:

Added at

_____

Ill.

Reg.

__________,

effective

____

Section 211.5480

Reflective Arcient Coating

“Reflective argent coating” means a silver—colored coating that

will reflect light.

(Source:

Added at

_____

Ill. Reg.

_________,

effective

____

__________________________________________________________)

Section 211.5600

Resist Coat

---

43

“Resist

coat”

means

a

coating

that

is applied to a plastic part

before metallic platinci to Prevent deposits of metal on

portions

of the plastic part.

(Source:

Added at

Ill.

Reg.

_________,

effective

____

Section 211.6060

Soft Coat

“Soft coat” means any coating that provides

a soft tactile feel

similar to leather and a rich leather-like appearance when

applied to plastic interior automotive parts and exterior

business machine parts.

(Source:

Added at

_____

Ill.

Reg.

__________,

effective

____

Section 211.6140

Specialty Coatings

“Specialty coatings” means,

for the purposes of 35 Ill.

Adm. Code

218 and 219, plastic parts coatings used for unusual job

performance requirements.

These products include adhesion

primers, resist coatings, soft coatings, reflective coatings,

electrostatic prep coatings, headlamp lens coatings,

ink pad

printing coatings, stencil coatings. vacuum metallizing coatings,

gloss reducers. plating resist coatings, and plating sensitizer

coatings.

(Source:

Added at

_____

Ill.

Reg.

__________,

effective

____

___________________________________________________________)

Section

211.6400

Stencil

Coat

“Stencil coat” means

a coating that is ap~1iedover

a stencil on

a plastic cart at a thickness of

1 mil or less of coating solids.

Stencil coats are most frequently letters, numbers,

or decorative

designs.

(Source:

Added at

_____

Ill.

Reg.

_________,

effective

____

)

Section 211.6580

Texture Coat

“Texture coat” means a coating applied to a plastic part which.

in its finished form, consists of discrete raised spots of the

coating.

(Source:

Added at

_____

Ill. Reg.

__________,

effective

____

Section 211.6880

Vacuum Metallizing

“Vacuum metallizing” means

a process whereby metal is vaporized

and deposited on a substrate in a vacuum chamber.

---

44

(Source:

Added at

_____

Ill.

Reg.

,

effective

____

__________________________________________________________)

Section 211.7400

Yeast Percentage

“Yeast percentage” means lbs of yeast per hundred lbs of total

flour in the recipe. expressed as

a percentage.

(Source:

Added at

_____

Ill. Reg.

__________,

effective

____

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

218.106

Compliance

Dates

Emission Limitations

Daily-Weighted Average Limitations

Alternative Emission Limitations

Exemptions from Emission Limitations

Compliance Schedule

_______

Cross-Line Averaging to Establish Compliance for

Coating Lines

218.213

Recordkeeping

and

Reporting

for

Cross—Line

Averaging

Participatina Coating Lines

218.214

Changing

Compliance

Methods

SUBPART Q:

LEAY~SFROM SYNTHETIC

ORGANIC CHEMICAL AND POLYMER

MANUFACTURING PLANT

Section

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

F:

COATING OPERATIONS

Section

218.204

218.205

218.207

218. 208

218.210

218.212

SUBPART DD: AEROSOL CAN FILLING

---

45

Section

218.686

Control Requirements

SUBPART FF:

BAKERY OVENS

Section

218.720

Applicability

218.722

Control Requirements

218.726

Testing

218 .727

Monitoring

218.728

Recordkeeping and Reporting

218.729

Compliance Date

218.730

Certification

SUBPART PR:

MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING

PROCESSES

Section

218.966

Control Requirements

SUBPART TT:

OTHER EMISSION UNITS

Section

218.980

Applicability

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

AUTHORITY:

Implementing Section 10 and authorized by Section

28.5 of the Environmental Protection Act

(Ill.

Rev.

Stat.

1991,

ch.

111-½, par.

1010)

(P.A.

87-1213, effective September 26,

1992)

415

ILCS 5/10 and 28.5).

SOURCE:

Adopted at R91-7

at 15 Ill.

Reg.

12231, effective August

16,

1991; amended in R91—23 at

16 Ill.

Reg.

13564,

effective

August 24,

1992;

amended in R91-28 and R91—30 at 16

Ill.

Req.

13864,

effective August 24,

1992; amended in R93—9 at 17

Ill.

Req.

16636, effective September 27,

1993; amended in R93—14 at 18

Ill. Req. 1945, effective January 24,

1994; amended in R94-12 at

18

Ill.

Req.

14973, effective September 21,

1994; amended in R94—

15 at 18

Ill. Reg.

16392, effective October

25,

1994; amended in

R94—l6 at 18

Ill.

Req.

16950, effective November 15,

1994;

amended in R94-21 at

19 Ill.

Reg.

_____,

effective

BOARD NOTE:

This Part implements the Environmental Protection

Act as of July 1,

1994.

SUBPART A:

GENERAL PROVISIONS

Section 218.106

Compliance Dates

---

46

a)

Except as otherwise provided in this Section 210.106

(c)

below or as otherwise provided in a specific

Subpart of this Part,

compliance with the requirements

of all rules

is required by July 1,

1991,

or September

1,

1991, for all sources located in Cook, DuPage, Kane,

Lake, McHenry or Will Counties, consistent with the

appropriate provisions of Section 218.103 of this Part

Subpart.

b)

Except as otherwise provided in this Section 218.106

(a)

below or as otherwise provided in a specific

Subpart of this Part, compliance with the requirements

of this Part is required by November 15,

1993,

for all

sources located in Aux Sable Township or Goose Lake

Township in Grundy County or

in Oswego Township in

Kendall County.

c)

All emission units which meet the applicability

requirements of Sections 218.402(a) (2), 218.611(b),

218.620(b),

218.660(a),

218.680(a),

218.920(b),

218.940(b),

218.960(b)

or 218.980(b)

of this Part,

including emission units at sources which are excluded

from the applicability criteria of Sections

218.402(a)(l),

218.611(a),

218.620(a),

218.920(a),

218.940(a),

218.960(a),

or 218.980(a)

of this Part by

virtue of permit conditions or other enforceable means,

must comply with the requirements of Subparts H,

Z,

AA,

CC,

DD,

PP,

QQ,

PR or TT of this Part,

respectively, by

March

15,

1995.

Any owner or operator of an emission

unit which has already met the applicability

requirements of Sections 218.402(a) (1),

218.611(a),

218.620(a),

218.920(a),

218.940(a),

218.960(a),

218.980(a)

of this Part on or by the effective date of

this subsection is required to comply with all

compliance dates or schedules found

in Sections

218.106(a)

or 218.106(b)

above,

as applicable.

~j

Any owner or operator of

a source with an emission unit

sublect to the requirements of Section 218.204(’m)(2) or

(m) (3)

of this Part shall comply with those

requirements by March 25,

1995.

(Source:

Amended at

_____

Ill.

Reg.

,

effective

—

SUBPART

F:

COATING OPERATIONS

Section 218.204

Emission Limitations

Except as provided in Sections 218.205, 218.207 ~8

218.208

and 218.212 of this Part Subpart,

no owner or operator of a

coating line shall apply at any time any coating in which the VOM

content exceeds the following emission limitations for the

specified coating.

Compliance with the emission limitations

---

47

marked with an asterisk

in this Section is required on and after

March 15,

1996.

Compliance with emission limitations not marked

with an asterisk is required until March 15,

1996. The following

emission limitations are expressed in units of VON per volume of

coating

(minus water and any compounds which are specifically

exempted from the definition of VOM)

as applied at each coating

applicator,

except where noted.

Compounds which are specifically

exempted from the definition of VON should be treated as water

for the purpose of calculating the “less water” part of the

coating composition.

Compliance with this Subpart must be

demonstrated through the applicable coating analysis test methods

and procedures specified in Section 218.105(a)

of this Part and

the recordkeeping and reporting requirements specified in Section

218.211(c)

of this Part Subpart except where noted.

(Note:

The

equation presented in Section 218.206 of this Part shall be used

to calculate emission limitations for determining compliance by

add—on controls, credits for transfer efficiency, emissions

trades and cross—line averaging.)

The emission limitations are

as

follows:

a)

Automobile or Light-Duty

kg/i

lb/gal

Truck Coating

1)

Prime

coat

0.14

(1.2)

0.14*

(1.2)*

2)

Primer surface coat

1.81

(15.1)

1.81*

(15.1)*

(Note:

The primer surface coat limitation

is in

units of kg

(ibs)

of VON per

1

(gal)

of coating

solids deposited.

Compliance with the limitation

shall be based on the daily-weighted average from

an entire primer surfacer operation.

Compliance

shall be demonstrated in accordance with the

topcoat protocol referenced in Section 218.105(b)

and the recordkeeping and reporting requirements

specified in Section 218.211(f). Testing to

demonstrate compliance shall be performed in

accordance with the topcoat protocol and a

detailed testing proposal approved by the Agency

and USEPA specifying the method of demonstrating

compliance with the protocol. Section 218.205 does

not apply to the primer surface limitation.)

kg/i

lb/gal

3)

Topcoat

1.81

(15.1)

1.81*

(15.1~*

(Note:

The topcoat limitation is

in units

of kg

(lbs)

of VON per

1

(gal)

of coating solids

deposited.

Compliance with the limitation shall

be based on the daily-weighted average from an

entire topcoat operation.

Compliance shall be

---

48

1)

Sheet basecoat and

overvarnish

~j

Sheet basecoat

~j

Overvarnish

2)

Exterior basecoat and

overvarnish

3)

Interior body spray coat

lb/gal

(4.8)

(4.8)*

lb/gal

0.34

(2.8)

0.34

0.26*

(2.8)

(2.2)

*

0.34

0.34

(2.8)

(2.8)

*

0.34

0.25*

(2.8)

(2.1)

*

0.51

(4.2)

6)

End sealing

compound coat

demonstrated in accordance with the topcoat

protocol referenced in Section 218.105(b)

of this

Part and the recordkeeping and reporting

requirements specified

in Section 218.211(f).

Testing to demonstrate compliance shall be

performed in accordance with the topcoat protocol

and

a

detailed

testing

proposal

approved

by

the

Agency and USEPA specifying the method of

demonstrating

compliance

with

the

protocol.

Section 218.205 of this Part does not apply to the

topcoat limitation.)

kg/i

4)

Final repair coat

0.58

0.58*

______

b)

Can Coating

kg/i

A) Two piece

B) Three piece

4)

Exterior end coat

5)

Side seam spray coat

____________

0.51

(4.2)

0.44*

(3.7’j*

_______________

0.51

(4.2)

0.51*

(4.2)*

0.51

(4.2)

0.51*

(4.2)*

0.66

(5.5)

0.66*

(5.5)*

0.44

(3.7)

0.44*

(3.7)*

kg/i

lb/gal

c)

Paper Coating

0.35

(2.9)

0.28*

(2.3)*

(Note:

The

paper

coating

limitation

shall

not apply to

any owner or operator of any paper coating line on

---

49

which printing is performed if the paper coating line

complies with the emissions limitations in Subpart H:

Printing and Publishing,

Section 218.401 of this Part.)

kg/i

lb/gal

d)

Coil Coating

0.31

(2.6)

0.20*

(1.7)*

e)

Fabric Coating

0.35

(2.9)

0.28*

(2.3)*

f)

Vinyl Coating

0.45

(3.8)

0.28*

(2.3)*

g)

Metal Furniture Coating

(3.0)

1)

Air dried

0.36

(3.0)

0.34*

(2.8)*

2)

Baked

0.36

(3.0)

0.28*

(2.3)*

h)

Large Appliance Coating

0.34

1)

Air dried

0.34

(2.8)

0.34*

(2.8)*

2)

Baked

0.34

(2.8)

0.28*

(2.3)*

(Note:

The limitation shall not apply to the use of

quick—drying lacquers for repair of scratches and nicks

that occur during assembly, provided that the volume of

coating does not exceed 0.95

1

(1 quart)

in any one

rolling eight-hour period.)

kg/i

lb/gal

i)

Magnet Wire Coating

0.20

(1.7)

0.20*

(1.7’J*

j)

Miscellaneous Metal Parts and

Products Coating

1)

Clear coating

0.52

(4.3)

0.52*

(4.3)*

2)

Air-dried coating

0.42

(3.~

32)

Extreme performance

coating

A)

Air dried

0.42

(3.5)

0.42*

(3.5)*

---

50

B)

Baked

0.42

(3.5)

0.40*

(3.3)*

4~)

Steel pail and drum

~0.52*

(4.3)

interior coating

0.52*

(4.3)*

~j)

All other coatings

(3.0)

Al

Air Dried

0.42

(3.5j

0.40*

(3.3)*

~1

Baked

0.36

(3.0)

0.34*

(2.8)*

~

Marine engine coating

Al

Air Dried

0.42

(3.5)

0.42*

(3.5)*

flj...

Baked

j~

Primer/Topcoat 0.42

(3.5)

0.42*

(3.5)*

iii.

Corrosion

0.42

(3.5)

resistant

0.28*

(2.3)*

basecoat

~j

Clear Coating

0.52

(4.3)

0.52*

(4.3)*

~j.. Metallic coating

~j

Air Dried

0.42

(3.5)

0.42*

(3.5)*

~j

Baked

0.36

(3.0)

0.36

(3.0)*

21

Definitions

Al

For purposes of subsection 218.204(1) (5) of

this Section, the following terms are

defined:

jj..

“Corrosion resistant basecoat” means,

for purposes of subsection

218.204(1) (5) (B) (ii) of this Section,

a

water—borne epoxy coating applied via an

electrodeposition process to

p

metal

surface prior to spray coating,

for the

purPose of enhancing corrosion

resistance.

---

51

Lii..

“Electrodeposition process” means a

water—borne dip coating process in which

opposite electrical charges are applied

to the substrate and the coating.

The

coating is attracted to the substrate

due to the electrochemical potential

difference that is created.

iii)

“Marine engine coating” means any

extreme performance protective,

decorative or functional coating applied

to an engine that

is used to propel

watercraft.

~j

For purposes of subsection 218.204(1) (6)

of

this Section,

“metallic coating” means a

coating which contains more than 1/4 lb/gal

of metal particles,

as applied.

k)

Heavy Off-Highway Vehicle

kg/i

lb/gal

Products Coating

1)

Extreme performance

0.42

(3.5)

prime coat

0.42*

(3.5)*

2)

Extreme performance top- 0.42

(3.5)

coat

(air dried)

0.42*

(3.5)*

3)

Final repair coat

0.42

(3.5)

(air dried)

0.42*

(3.5)*

4)

All other coatings are subject to the emission

limitations for miscellaneous metal parts and

products coatings in subsection

(j)

above.

1)

Wood Furniture Coating

kg/l

lb/gal

1)

Clear topcoat

0.67

(5.6)

0.67*

(5.6)*

2)

Opaque stain

0.56

(4.7)

0.56*

(4.7)*

3)

Pigmented coat

0.60

(5.0)

0.60*

(5.0)*

4)

Repair coat

0.67

(5.6)

0.67*

(5.6)*

5)

Sealer

0.67

(5.6)

0.67*

(5.6)*

6)

Semi—transparent stain

0.79

(6.6)

0.79*

(6.6)*

---

52

7)

Wash coat

0.73

(6.1)

0.73*

(6.1)*

(Note:

An owner or operator of a wood furniture

coating operation subject to this Section shall

apply all coatings, with the exception of no more

than 37.8

1

(10 gal)

of coating per day used for

touch—up and repair operations, using one or more

of the following application systems:

airless

spray application system, air—assisted airless

spray application system, electrostatic spray

application system, electrostatic bell or disc

spray application system, heated airless spray

application system, roller coating, brush or wipe

coating application system, dip coating

application system or high volume iow pressure

(HVLP) application system.)

m)

Existing Diesel-Electric Locomotive Coating Lines

in

Cook County

kg/i

lb/gal

1)

Extreme performance prime

coat

0.42

(3.5)

0.42*

(3.5)*

2)

Extreme performance top-

coat

(air dried)

0.42

(3.5)

0.42*

(3.5)*

3)

Final repair coat

(air dried)

0.42

(3.5)

0.42*

(3.5)*

4)

High-temperature aluminum

coating

0.72

(6.0)

0.72*

(6.0)*

5)

All other coatings

0.36

(3.0)

0.36*

(3.0)*

fli..

Plastic Parts Coating:

Automotive/Transportation

kg/i

lb/gal

fl..

Interiors

Al

Baked

j).

Color coat

0.49*

(4.1)*

~1

Primer

0.46*

(3.8)*

~

Air Dried

---

53

j)..

Color coat

0.38*

(3.2)*

jjj

Primer

0.42*

(3,5)*

21

Exteriors (flexible

and non-flexible)

Al

Baked

LL

Primer

0.60*

(5.0)*

jjI

Primer non—

0.54*

(4.5)*

flexible

iii)

Clear coat

0.52*

(4.3)*

j~j Color coat

0.55*

(4.6)*

~l

Air Dried

j)

Primer

0.66*

(5.5)*

jJ1

Clear coat

0.54*

(4.5)*

iii)

Color coat

0.67*

(5.6)*

(red

& black)

jy)..

Color coat

(others)

0.61*

(5.1)*

.~J

Specialty

Al

Vacuum metallizing

0.66*

(5.5)*

basecoats, texture

basecoats

~1

Black coatings,

0.71*

(5.9)*

reflective argent

coatings, air

bag cover coatings,

and soft coatings

~j.. Gloss reducers,

0.77*

(6.4)*

vacuum metaiiizing

topcoats, and

texture topcoats

~j

Stencil coatings,

0.82*

(6.8)*

adhesion primers,

ink ~ad coatings,

electrostatic prep

coatings, and resist

coatings

---

54

.~j

Head lamP lens

0.89*

(7.4)*

coatings

~

Plastic Parts Coating:

Business Machine

kg/i

lb/gal

fl..

Primer

0.14*

(1.2)*

21

Color coat

(non—

0.28*

(2.3)*

texture coat)

~j

Color coat (texture

0.28*

(2.3)*

coat)

~j.

Electromagnetic

0.48*

(4.0)*

interference/radio

frequency interference

(EMI/RFI) shielding coatings

~

Specialty Coatings

Al

Soft coat

0.52*

(4.3)*

~j

Plating resist

0.71*

(5.9)*

.ci

Plating sensitizer

0.85*

(7.1)*

(Source:

Amended at

_____

Iii. Reg.

_________,

effective

Section 218.205

Daily-Weighted Average Limitations

No owner or operator of a coating line subject to the limitations

of Section 218.204 of this PartSubpart and complying by means of

this Section shall operate the subject coating line unless the

owner or operator has demonstrated compliance with subsection

(a),

(b),

(c),

(d),

(e)~

e~

(f),

(ci)

(h)

or

(1)

of this Section

(depending upon the category of coating) through the applicable

coating analysis test methods and procedures specified in Section

218.105(a)

of this Part and the recordkeeping and reporting

requirements specified in Section 218.211(d)

of this PartSubpart:

a)

No owner or operator of

a coating line subject to only

one of the limitations from among Section

218.204 (a) (1),

(a) (4),

(c)

,

(d)

,

(e)

,

(f)

,

(g)

,

(h)

,

or

(1)

of this PcirtSubpart shall apply coatings on any

such coating line, during any day, whose daily-weighted

average VOM content exceeds the emission limitation to

which the coatings are subject.

b)

No owner or operator of a miscellaneous metal parts and

products coating line subject to the limitations of

Section 218.204(j)

of this PartSubpart shall apply

---

55

coatings to

miscellaneous metal parts or products on

the subject coating line unless the requirements in

subsection

(b) (1) or

(b) (2) belowof this Section are

met.

1)

For each coating line which applies multiple

coatings, all of which are subject to the same

numerical emission limitation within Section

218.204(j)

during the same day

(e.g., all coatings

used on the line are subject to 0.42 kg/i

3.5

lbs/gal)),

the daily—weighted average VON content

shall not exceed the coating VON content limit

corresponding to the category of coating used,

or

2)

For each coating line which applies coatings

subject to more than one numerical emission

limitation in Section 218.204(j)

aboveof this

Subpart, during the same day, the owner or

operator shall have a site—specific proposal

approved by the Agency and approved by the tJSEPA

as a SIP revision.

To receive approval, the

requirements of USEPA’s Emissions Trading Policy

Statement (and reiated policy)

51 Fed. Reg. 43814

(December 4,

1986), must be satisfied.

c)

No owner or operator of

a can coating line subject to

the limitations of Section 218.204(b)

of this

PartSubpart shall operate the subject coating line

using a coating with a VON content in excess of the

limitations specified in Section 218.204(b)

of this

PartSubpart unless all of the following requirements

are met:

1)

An alternative daily emission limitation shall be

determined for the can coating operation,

i.e.

for

all of the can coating lines at the source,

according to subsection

(C)

(2) belowof this

Section.

Actual daily emissions shall never

exceed the alternative daily emission limitation

and shall be calculated by use of the following

equation.

n

Ed

=

E

V1

C~

1=1

where:

Ed

=

Actual VON emissions for the day in

units of kg/day

(lbs/day);

i

=

Subscript denoting a specific coating

applied;

---

56

n

=

Total number of coatings applied in the

can coating operation,

i.e. all can

coating lines at the source;

V1

=

Volume of each coating applied for the

day in units of 1/day

(gal/day) of

coating

(minus water and any compounds

which are specifically exempted from the

definition of VOM);

C.

=

The VON content of each coating as

applied in units of kg VOM/1

(lbs

VOM/gal)

of coating

(minus water and any

compounds which are specifically

exempted from the definition of VON).

2)

The alternative daily emission limitation

(Ad)

shall be determined for the can coating operation,

i.e.

for all of the can coating lines at the

source,

on a daily basis

as follows:

n

E

V1

L1

(D1

—

C1

1

i=1

(D1

—

L1)

where:

Ad

=

The VOM emissions allowed for the day in

units of kg/day (lbs/day);

i

=

Subscript denoting a specific coating

applied;

n

=

Total number of surface coatings applied

in the can coating operation;

CI

=

The VOM content of each surface coating

as applied in units of kg VON/i

(lbs

VON/gal)

of coating

(minus water and any

compounds which are specifically

exempted from the definition of VON);

=

The density of VON in each coating

applied.

For the purposes of

calculating Ad, the density is

0.882 kg VOM/l VOM

(7.36 lbs VOM/gal

VOM);

VI

=

Volume of each surface coating applied

for the day in units

of

1

(gal)

of

coating

(minus water and any compounds

which are specifically exempted from the

definition of VOM);

---

57

L1

=

The VON emission limitation for each

surface coating applied as specified in

Section 218.204(b)

of this PartSubpart

in units of kg VOM/l

(lbs VON/gal)

of

coating

(minus water and any compounds

which are specifically exempted from the

definition of VOM).

d)

No owner or operator of a heavy off—highway vehicle

products coating line subject to the limitations of

Section 218.204(k)

of this PartSubpart shall apply

coatings to heavy off-highway vehicle products on the

subject coating line unless the requirements of

subsection

(d) (1)

or

(d) (2)

belowof this Section are

met.

1)

For each coating line which applies multiple

coatings, all of which are subject to the same

numerical emission limitation within Section

218.204(k)

aboveof this Subpart, during the same

day

(e.g.,

all coatings used on the line are

subject to 0.42 kg/i 3.5

lbs/gal),

the

daily-weighted average VOM content shall not

exceed the coating VON content limit corresponding

to the category of coating used,

or

2)

For each coating line which applies coatings

subject to more than one numerical emission

limitation in Section 218.204(k)

aboveof this

Subpart, during the same day, the owner or

operator shall have a site specific proposal

approved by the Agency and approved by the USEPA

as a SIP revision.

To receive approval, the

requirements of USEPA’s Emissions Trading Policy

Statement (and related policy)

51 Fed. Reg.

43814

(December 4,

1986), must be satisfied.

e)

No owner or operator of a wood furniture coating line

subject to the limitations of Section 218.204(1)

of

this PartSubpart shall apply coatings to wood furniture

on the subject coating line unless the requirements of

subsection

(e) (1)

or subsection

(e) (2) bclowof this

Section,

in addition to the requirements specified in

the note to Section 218.204(1) of this PartSubpart, are

met.

1)

For each coating line which applies multiple

coatings, all of which are subject to the same

numerical emission limitation within Section

218.204(1)

aboveof this Subpart, during the same

day

(e.g.,

all coatings used on the line are

subject to 0.67 kg/i

5.6

lbs/gal),

the

daily—weighted average VON content shall not

---

58

exceed the coating VON content limit corresponding

to the category of coating used,

or

2)

For each coating line which applies coatings

subject to more than one numerical emission

limitation in Section 218.204(1)

aboveof this

Subpart, during the same day, the owner or

operator shall have a site specific proposal

approved by the Agency and approved by the USEPA

as a SIP revision.

To receive approval, the

requirements of USEPA’s Emissions Trading Policy

Statement

(and related policy)

51 Fed. Reg.

43814

(December 4,

1986), must be satisfied.

f)

No owner or operator of an existing diesel—electric

locomotive coating line in Cook County,

subject to the

limitations of Section 218.204(m)

of this PartSubpart

shall apply coatings to diesel—electric

locomotives on

the subject coating line unless the requirements of

subsection

(if) (1)

or

(if) (2)

of this Section are met.

1)

For each coating line which applies multiple

coatings, all of which are subject to the same

numerical emission limitation within Section

218.204(m)

aboveof this Subpart, during the same

day (e.g.,

all coatings used on the line are

subject to 0.42 kg/i

(3.5

lbs/gal),

the

daily-weighted average VON content shall not

exceed the coating VON content limit corresponding

to the category of coating used,

or

2)

For each coating line which applies coatings

subject to more than one numerical emission

limitation in Section 218.204(m)

abovcof this

Subpart, during the same day, the owner or

operator shall have a site specific proposal

approved by the Agency and approved by the USEPA

as a SIP revision.

To receive approval, the

requirements of USEPA’s Emissions Trading Policy

Statement

(and related policy) must be satisfied.

gI

No owner or operator of a plastic Parts coating line,

subiect to the limitations of Section 218.204(n) or

(0)

of this Subpart shall apply coatings to business

machine or automotive/transportation plastic parts on

the subiect coating line unless the requirements of

subsection

(ci) (1)

or

(g)

(2)

of this Section are met:

~

For each coating line which applies multiple

coatings. all of which are subiect to the same

numerical emission limitation within Section

218.204(n)

or

(o)

of this Subpart, during the same

day (e.g., all coatings used on the line are

sublect to 0.42 kg/i

13.5 lbs/gal)), the

---

59

daily-weighted average VON content shall not

exceed the coating VON content limit corresponding

to the category of coating used; or

21

For each coating line which applies coatings

subiect to more than one numerical emission

limitation in Section 218.204(n)

or

(0)

of this

Subpart.

durinci the same day, the owner or

operator shall have a site specific ~ro~osal

approved by the Agency and a~Provedby the USEPA

as a SIP revision.

To receive ai~~rova1.the

requirements of USEPA’s Emissions Trading Policy

Statement

(and related policy) must be satisfied.

~j

No owner or operator of a metal furniture coating line.

sublect to the limitations of Section 218.204(g)

of

this Subpart shall apply coatings on the subiect

coating line unless the requirements of subsection

(h) (1)

or

(h) (2) of this Section are met:

~j.. For each coating line which applies multiple

coatings,

all of which are subiect to the same

numerical emission limitation within Section

218.204(g)

of this Subpart, during the same day

(e.g..

all coatings used on the line are subject

to 0.34

kci/l

12.8 lbs/gal),

the daily—weighted

average VON content shall not exceed the coating

VON content limit corresponding to the category of

coating used;

or

21

For each coating line which applies coatings

sublect to more than one numerical emission

limitation in Section 218.204(g)

of this Subpart,

during the same day, the owner or operator shall

have a site specific ~ro~osal a~~rovedby the

Aciency and a~Provedby the USEPA as a SIP

revision.

To receive ap~rovai,the requirements

of USEPA’s Emissions Trading Policy Statement (and

related policy)

must be satisfied.

j~.

No owner

or oPerator of

a

larcie appliance coating line,

subiect to the limitations of Section 218.204(h)

of

this_SubPart shall apply coatings on the sublect

coating line unless the requirements of subsection

(1) (1)

or

(i) (2)

of this Section are met:

fl

For each coating line which applies multiple

coatings, all of which are sublect to the same

numerical emission limitation within Section

218.204(h)

of this Subpart, during the same day

(e.g..

all coatings used on the line are sublect

to_0.34

kci/l

12.8 lbs/gall),

the daily-weighted

average VON content shall not exceed the coating

---

60

VON content limit corresponding to the category of

coating used,

or

21

For each coating line which applies coatings

sublect to more than one numerical emission

limitation in Section 218.204(h)

of this Subpart.

during the same day. the owner or operator shall

have a site specific ~ro~osa1 approved by the

Agency and approved by the USEPA as a SIP

revision.

To receive approval. the requirements

of USEPA’s Emissions Trading Policy Statement

(and

related policy) must be satisfied.

(Source:

Amended at

_____

Ill. Reg.

_________,

effective

________________________________________________________________)

Section 218.207

Alternative Emission Limitations

a)

Any owner or operator of a coating line subject to

Section 218.204 of this PartSubpart may comply with

this Section, rather than with Section 218.204 of this

PartSubpart,

if a capture system and control device are

operated at all times the coating line

is in operation

and the owner or operator demonstrates compliance with

subsection

(c)

,

(d)

,

(e)

,

(if)

,

(g),..

e~

(h)

(i)

(1)

or

jJ~of this Section

(depending upon the source

category) through the applicable coating analysis and

capture system and control device efficiency test

methods and procedures specified in Section 218.105 of

this Part and the recordkeeping and reporting

requirements specified in Section 218.211(e)

of this

PartSubpart; and the control device is equipped with

the applicable monitoring equipment specified in

Section 218.105(d)

of this Part and the monitoring

equipment is installed,

calibrated, operated and

maintained according to vendor specifications at all

times the control device is

in use.

A capture system

and control device, which does not demonstrate

compliance

with

subsection

(c),

(d),

(e),

(if),

(g).,~e~

(h),

(i).

(1) or

(k) of this Section may be used as an

alternative to compliance with Section 218.204 of this

PartSubpart only if the alternative is approved by the

Agency and approved by the USEPA as a SIP revision.

b)

Alternative Add-On Control Methodologies

1)

The coating line is equipped with a capture system

and control device that provides 81 percent

reduction in the overall emissions of VON from the

coating line and the control device has

a 90

percent efficiency, or

2)

The system used to control VON from the coating

line is demonstrated to have an overall efficiency

---

61

sufficient to limit VON emissions to no more than

what is allowed under Section 218.204 of this

PartSubpart.

Use of any control system other than

an afterburner, carbon adsorption, condensation,

or absorption scrubber system can be allowed only

if approved by the Agency and approved by the

USEPA as a SIP revision.

The use of transfer

efficiency credits can be allowed only if approved

by the Agency and approved by the USEPA as a SIP

revision.

Baseline transfer efficiencies and

transfer efficiency test methods must be approved

by the Agency and the USEPA.

Such overall efficiency

is to be determined as

follows:

A)

Obtain the emission limitation from the

appropriate subsection

in Section 218.204 of

this PartSubpart;

B)

Calculate “5” according to the equation in

Section 218.206 of this Par-tSubpart;

C)

Calculate the overall efficiency required

according to Section 218.105(e)

of this Part.

For the purposes of calculating this value,

according to the equation in Section

218.105(e) (2)

of this Part,

VON, is equai to

the value of “5” as determined above in

subsection

(b) (2) (B)

of this Section.

c)

No owner or operator of a coating line subject to only

one of the emission limitations from among Section

218.204 (a) (1),

(a) (4),

(c)

,

(d)

,

(e)

,

(if),

(g)

,

(h)~or

(i)

of this PartSubpart and equipped with a capture

system and control device shall operate the subject

coating line unless the requirements

in subsection

(b) (1)

or

(b) (2) aboveof this Section are met.

No

owner or operator of a coating line subject to Section

218.204(a) (2)

or 218.204(a) (3)

and equipped with a

capture system and control device shall operate the

coating line unless the owner or operator demonstrates

compliance with such limitation in accordance with the

topcoat protocol referenced

in Section 218.105(b).

d)

No owner or operator of a miscellaneous metal parts and

products coating line which applies one or more

coatings during the same day, all of which are subject

to the same numerical emission limitation within

Section 218.204(j)

of this PartSubpart

(e.g., all

coatings used on the line are subject to 0.42 kg/i

3.5

lbs/gal),

and which

is equipped with a capture system

and control device shall operate the subject coating

---

62

line unless the requirements in subsection

(b) (1) or

(b) (2)

abovcof this Section are met.

e)

No owner or operator of a heavy off-highway vehicle

products coating line which applies one or more

coatings during the same day, all of which are subject

to the same numerical emission limitation within

Section 218.204(k)

of this PartSubpart

(e.g., all

coatings used on the line are subject to 0.42 kg/i 3.5

lbs/gal),

and which is equipped with a capture system

and control device shall operate the subject coating

line unless the requirements in subsection

(b) (1) or

(b) (2) abovcof this Section are met.

f)

No owner or operator of an existing diesel—electric

locomotive coating line in Cook County which applies

one or more coatings during the same day, all of which

are subject to the same numerical emission limitation

within Section 218.204(m)

of this partSubpart

(e.g.,

all coatings used on the line are subject to 0.42 kg/i

3.5

lbs/gal),

and which is equipped with a capture

system and control device shall operate the subject

coating line unless the requirements in subsection

(b) (1)

or

(b) (2) abovcof this Section are met.

g)

No owner or operator of a wood furniture coating line

which applies one or more coatings during the same day,

all of which

are

~ubject to the same numerical emission

limitation within Section 218.204(1)

of this

PartSubpart

(e.g.,

all coatings used on the line are

subject to 0.67 kg/i 5.6

lbs/gal),

and which is

equipped with a capture system and control device shall

operate the subject coating line unless the

requirements in subsection

(b) (1)

or

(b) (2)

of this

Section are met.

If compliance is achieved by meeting

the requirements in subsection

(b) (2) of this

PartSection, then the provisions in the note to Section

218.204(1)

of this partSubpart must also be met.

h)

No owner or operator of a can coating line which is

equipped with a capture system and control device shall

operate the subject coating line unless the

requirements in subsection

(h) (1)

or

(h) (2) be~lowp~

this Section are met.

1)

An alternative daily emission limitation shall be

determined for the can coating operation,

i.e.

for

all of the can coating lines at the source,

according to Section 218.205(c) (2)

of this

PartSubpart.

Actual daily emissions shall never

exceed the alternative daily emission limitation

and shall be calculated by use of the following

equation:

---

63

n

Ed

=

E

V~

C.

(1—F1

i=1

where:

Ed

=

Actual

VON

emissions

for the day in

units of kg/day

(lbs/day);

I

=

Subscript denoting the specific

coating applied;

n

=

Total number of surface coatings as

applied

in the can coating

operation;

V~

=

Volume of each coating as applied

for the day in units of i/day

(gal/day)

of coating

(minus water

and any compounds which are

specifically exempted from the

definition of VON);

C.

=

The VOM content of each coating as

applied in units of kg VOMf1

(lbs

VON/gal)

of coating

(minus water

and any compounds which are

specifically exempted from the

definition of VON) and

F1

=

Fraction, by weight,

of VON

emissions from the surface coating,

reduced or prevented from being

emitted to the ambient air. This is

the overall efficiency of the

capture system and control device.

2)

The coating line is equipped with a capture system

and control device that provide 75 percent

reduction in the overall emissions of VON from the

coating line and the control device has a 90

percent efficiency.

j~

No owner or operator of a plastic parts coating line

which applies one or more coatings during the same day,

all of which are sublect to the same numerical emission

limitation within Section 218.204(n)

or

(o)

of this

Subpart

(e.g.. all coatings used on the line are

subiect to 0.42 k~Jl13.5 lbs/gal)),

and which

is

equipped with a capture system and control device,

shall operate the subiect coating line unless the

requirements in subsection

(b) (1)

or

(b) (2)

of this

Section are met.

---

64

IL

No owner or operator of a metal furniture coating line

which applies one or more coatings during the same day,

all of which are subject to the same numerical emission

limitation within Section 218.204(g)

of this Subpart

~.g.,

all coatings used on the line are sublect to

0.34 kci/i

2.8

lbs/gall), and which is eguimped with a

caPture system and control device,

shall operate the

sublect coating line unless the requirements in

subsection

(b) (1)

or

(b) (2)

of this Section are met.

~j

No owner or operator of a large appliance coating line

which applies one or more coatings during the same day,

all of which are subiect to the same numerical emission

limitation within Section 218.204(h)

of this Subpart

(e.g., all coatings used on the line are subject to

0.34 k~/l2.8

lbs/gail),

and which

is equipped with a

capture system and control device, shall operate the

subject coating line unless the requirements

in

subsection

(b) (1)

or

(b) (2)

of this Section are met.

(Source:

Amended at

_____

Ill. Reg.

_________,

effective

Section 218.208

Exemptions From Emission Limitations

a)

Exemptions for all coating categories except wood

furniture coating.

The limitations of this Subpart

shall not apply to coating ~

a source, that

otherwise would be subject to the same subsection of

Section 218.204

(because they belong to the same

coating category,

e.g. can coating) provided that

combined actual emissions of VON from all lines at the

source subject to that subsection never exceed 6.8

kg/day

(15 lbs/day) before the application of capture

systems and control devices.

(For example, can coating

lines within a source would not be subject to the

limitations of Section 218.204(b)

of this PartSubmart

if the combined actual emissions of VON from the can

coating lines never exceed 6.8 kg/day

(15 lbs/day)

before the application of capture systems and control

devices.)

Volatile organic material emissions from

heavy off-highway vehicle products coating lines must

be combined with VOM emissions from miscellaneous metal

parts and products coating lines to determine

applicability.

Any owner or operator of a coating

source shall comply with the applicable coating

analysis test methods and procedures specified in

Section 218.105(a)

of this Part and the recordkeeping

and reporting requirements specified in Section

218.211(a)

of this PartSubpart if total VON emissions

from the subject coating lines are always less than or

equal to 6.8 kg/day

(15 lbs/day) before the application

of capture systems and control devices and, therefore,

are not subject to the limitations of Section 218.204

---

65

of this PartSubpart.

Once a category of coating lines

at a source is subject to the limitations in Section

218.2047 of this PartSubpart the coating lines are

always subject to the limitations

in Section 218.204 of

this PartSubpart.

b)

Applicability for wood furniture coating

1)

The limitations of this Subpart shall apply to a

source’s wood furniture coating lines

if the

source contains process emission units,

not

regulated by Subparts B,

E,

F

(excluding Section

218.204(1)

of this PartSubpart), H

(excluding

Section 218.405 of this Part),

Q,

R,

S, T

(excluding Section 218.486 of this Part),

V,

X,

Y,

or BB of this Part, which as a group both:

A)

Have maximum theoretical emissions of 91 Mg

(100 tons)

or more per calendar year of VON

if no air pollution control equipment were

used,

and

B)

Are not limited to less than 91 Mg

(100 tons)

of VOM per calendar year if no air pollution

control equipment were used,

through

production or capacity limitations contained

in a federally enforceable permit or SIP

revision.

21

The limitations of this Subpart shall apply to a

source’s wood furniture coating lines.

on and

after March

15,

1996,

if the source contains

process emission units,

which as a group,

have a

potential to emit 22.7 Mg

(25 tons)

or more of VOM

per calendar year and have not limited emissions

to less than 22.7 Mg

(25 tons)

of VOM per calendar

year through production or capacity limitations

contained in a federally enforceable operating

permit or SIP revision, and which:

Al

Are not regulated by Subparts B,

E,

F

(excluding Section 218.204(1)

of this

Subpart),

H,

0,

R,.S,

T

(excluding Section

218.486 of this Part),

V,

X,

1,

Z or BB of

this Part;

and

~j

Are not included in any of the following

categories:

synthetic organic chemical

manufacturing industry

(SOCMI) distillation,

SOCMI_reactors,

plastic parts coating

(business machines), plastic parts coating

(other), offset lithography,

industrial

wastewater, autobody refinishing,

SOCNI batch

---

66

processing, volatile organic liquid storage

tanks and clean—un solvents operations.

~3)

If a source ceases to fulfill the criteria of

subsection

(b) (1)

or

(b) (2)

of this Section, the

limitations of Section 218.204(1)

of this

PartSubpart shall continue to apply to any wood

furniture coating line which was ever subject to

the limitations of Section 218.204(1)

of this

PartSubpart.

j)

For the purposes of subsection

(b)

of this

Section,

an emission unit shall

be considered ~g

~

regulated by a Subpart if it

is subject to the

limitations of that Subpart.

An emission unit is

not considered regulated by a Subpart if

it is not

subject to the limits of that Subpart, e.g.,

the

emission unit is covered by an exemption in the

Subpart or the applicability criteria of the

Subpart are not met.

4~)

Any owner or operator of a wood furniture coating

line to which the limitations of this Subpart are

not applicable due to the criteria in subsection

(b) of this Section shall, upon request by the

Agency or the USEPA, submit records to the Agency

and the USEPA within

30 calendar days from the

date of the request that document that the coating

line is exempt from the limitations of this

Subpart.

gI

On and after March 15, 1996,

the limitations of this

Subpart shall not apply to touch-up and repair coatings

used by a coating source described by subsections

218.204(b)

.

(d)

,

(if),

(ci)

,

(I)

,

(1)

,

(n) and

(0)

of

this Subpart; provided that the source-wide volume of

such coatings used does not exceed 0.95

1

(1 quart)

per

eight-hour period or exceed

209 1/yr

(55 gal/yr) for

any rolling twelve month period.

Recordkeeping and

reporting for touch-up and repair coatings shall be

consistent with Section 218.211(b) (4)

of this Subpart.

~j

On and after March

15,

1996, the owner or operator of

a

coating line or a group of coating lines using touch—up

and repair coatings that are exempted from the

limitations of Section 218.204(b),

(d).

(if),

(ci).

(i),

(1).

(n) and

(o)

of this Subpart because of the

provisions of Section 218.208(c)

of this Subpart shall:

fl

Collect and record the name,

identification

number, and volume used of each touch—un and

repair coating, as applied on each coating line,

per eight-hour period and per month

---

67

21

Perform calculations on a daily basis,

and

maintain at the source records of such

calculations of the combined volume of touch-up

and repair coatings used source—wide for each

eight-hour period~

.~j

Perform calculations on a monthly basis,

and

maintain at the source records of such

calculations of the combined volume of touch—up

and repair coatings used source—wide for the month

and the roiling twelve month period;

41

Prepare and maintain at the source an annual

summary of the information required to be compiled

pursuant to subsections

(c) (4) (A) and

(c) (4) (B)

of

this Section on or before January

31 of the

following year

.~j.

Maintain at the source for a minimum period of

three years all records required to be kept under

this subsection and make such records available to

the Aciencv upon request

~j

Notify the A~encvin writing if the use of touch-

up and repair coatings at the source ever exceeds

a volume of 0.95

1

(1 quart) per eight-hour period

or exceeds 209 1/yr

(55 cial/yr)

for any rollinci

twelve month period within 30 days after any such

exceedance.

Such notification shall include a

copy of any records of such exceedance; and

21

“Touch—up and repair coatings” means,

for purposes

of 35 Ill. Adm. Code 218.208, anY coating used to

cover minor scratches and nicks that occur during

manufacturing and assembly processes.

(Source:

Amended at

Ill. Reg.

,

effective

________________________________________________________________ )

Section 218.210

Compliance Schedule

Every owner or operator of a coating line

(of a type included

within Section 218.204 of this Subpart)

shall comply with the

requirements of Section 218.204,

218.205, 218.207 or 218.208 and

Section 218.211 of thi2 Part or Sections 218.212 and 218.213 of

this Subpart in accordance with the appropriate compliance

schedule as specified in subsection

(a),

(b),

(c)~e~ (d)

.

(e)

or

(if)

below:

a)

No owner or operator of a coating line which

is exempt

from the limitations of Section 218.204 of this

PartSubpart because of the criteria in Section

218.208(a)

of this PartSubpart shall operate said

coating line on or after a date consistent with Section

---

68

218.106 of this Part, unless the owner or operator has

complied with,

and continues to comply with,

Section

218.211(b)

of this PartSubpart.

Wood furniture coating

lines are not subject to Section 218.211(b)

of this

PartSubpart.

b)

No owner or operator of a coating line complying by

means of Section 218.204 of this PartSub~artshall

operate said coating line on or after a date consistent

with Section 218.106 of this Part, unless the owner or

operator has complied with, and continues to comply

with,

Sections 218.204 and 218.211(c)

of this

PartSubpart.

c)

No owner or operator of a coating line complying by

means of Section 218.205 of this PartSubpart shall

operate said coating line on or after a date consistent

with Section 218.106 of this Part,

unless the owner or

operator has complied with, and continues to comply

with, Sections 218.205 and 218.211(d)

of this

PartSubpart.

d)

No owner or operator of a coating line complying by

means of Section 218.207 of this PartSubpart shall

operate said coating line on or after a date consistent

with Section 218.106 of this Part,

unless the owner or

operator has complied with, and continues to comply

with, Sections 218.207 and 218.211(e)

of this

PartSubpart.

gI

No owner or operator of a coating line subiect to one

or more of the emission limitations contained in

Section 218.204 of this Subpart on or after March 15,

1996, choosing to comply by means of Section 218.204,

218.205 or 218.207 of this Subpart,

shall operate said

coating line on or after March

15.

1996,

unless the

owner or operator complies with and continues to comply

with.

respectively,

the applicable requirements in

Section 218.204,

or the alternative control options in

Sections 218.205 or 218.207 and the requirements of

Section 218.211.

fl

No owner or operator of

a coating line sublect to one

or more of the emission limitations contained in

Section 218.204 of this Subpart on or after March 15,

1996, choosing to comply by means of Section 218.212 of

this Subpart,

shall operate said coating line on or

after March

15,

1996. unless the owner or operator

complies with and continues to comply with the

requirements of Sections 218.212 and 218.213 of this

Subpart.

(Source:

Amended at

Ill.

Reg.

__________,

effective

—

---

69

Section 218.212

Cross-Line Averaging to Establish Compliance

for Coating Lines

~j

On and after March 15,

1996,

any owner or operator of

a

coating line sublect to the limitations set forth

in

Section 218.204 of this Subpart, and with coating lines

in operation prior to January

1,

1991

(“pre—existing

coating lines”). may,

for pre—existing coating lines

only,

elect to comply with the requirements of this

Section,

rather than complying with the applicable

emission limitations set forth in Section 218.204,

if

an operational change of the type described below has

been made after January

1.

1991.

to one or more pre-

existing coating lines at the source.

An operational

chancie_occurs when a pre—existinci coating line is

replaced with

a line using lower VON coating for the

same purpose as the replaced line (“replacement line”).

A source electing to rely on this Section to

demonstrate compliance with the requirements of this

Subpart shall operate pursuant to federally enforceable

permit conditions approved by the Agency and USEPA.

~j

An owner

or operator of pre—existing coating lines

subiect to a VON content limitation

in Section 218.204

of this. Subpart and electing to rely on this Section to

demonstrate compliance with this Subpart must

establish,

by use of the equations in subsection

(d)

of

this Section, that the calculated actual daily VON

emissions from all ~artici~ating coating lines, as

defined below,

are less than the calculated daily

allowable VOM emissions from the same group of coating

lines.

For any pre—existing coating line to be

aggregated for the purposes of Section 218.212,

218.213,

or 218.214 of this Subpart (“participating

coating lines”),

the source must establish that:

~

All coatings applied on the participating coating

line shall,

at all times, have

a VON content less

than_or_equal to the applicable VOM content

limitation for such coating listed in Appendix H

of this Part; and

21

On the date the source elects to rely on this

Section to demonstrate compliance with this

Subpart,

all coatings applied on the participating

coating line are not already

in compliance with

the VON content limitation for such coating

effective on or after March 15,

1996;

or the

participating coating line is a replacement

line,

as defined in subsection

(a)

of this Section with

an operational change occurring on or after

January

1,

1991.

---

70

gj

Notwithstanding subsection

(a)

of this Section, any

owner or operator of a coating line sublect to the

limitations set forth in Section 218.204 of this

Subpart and electing to rely on this Section to

demonstrate compliance with this Subpart, may also

include as a participating coating line, until December

31,

1999,

only,

any replacement line that satisfies all

of the following conditions:

fl..

The replacement line

is operated as a powder

coating line

21

The replacement line was added after July 1, 1988

and

,~J..

The owner or operator also includes as a

participating coating line one or more coating

lines that satisfy the criteria of a replacement

line,

as described in subsection

(a)

of this

Section.

4j

To demonstrate compliance with this Section.

a source

shall establish the following:

.11

An alternative daily emission limitation shall be

determined for all participating coating lines at

the source according to subsection

(d) (2) of this

Section.

All participating coating lines shall be

factored

in each day to demonstrate compliance.

Provided compliance is established pursuant to the

requirements in this subsection,

nothing in this

Section requires daily operation of each

participating line.

Actual daily emissions from

all participating coating lines

(Ed)

shall never

exceed the alternative, daily emission limitation

~)

and shall be calculated by use of the

following equation:

n

Ed

=

E

V1

C1

i=1

where:

~

Actual daily VOM emissions from participating

coating lines in units of kg/day (lbs/day)

j~

Subscript denoting a specific coating

applied

n=

Total number of coatings applied by all

participating coating lines at the source

---

71

~

Volume of each coating a~~1iedfor the day in

units of 1/day

(gal/day)

of coating (minus

water and any compounds which are

specifically exempted from the definition of

VON); and

~

The VON content of each coating as applied in

units of kg VON/i

(lbs VOM/gal) of coating

(minus water and any compounds which are

specifically exempted from the definition of

VON).

21

The alternative daily emission limitation

(A,,j

shall be determined for all participating coating

lines at the source on a daily basis as follows:

~

A,

+

A~

where

A, and A~are defined

in subsections

(2) (A)

and

(2) (B)

of this Section.

Al

The portion of the alternative daily

emissions limitation for coating operations

at a source using non—powder coating

(A,.)..

shall be determined for all such

participating non—powder coating lines on a

daily basis as follows:

n

A,

=

E

V1L1

~1-c~

i=l

(D1

—

L1)

where:

A,

=

The VON emissions allowed for the day in

units of kg/day

(lbs/day);

i=

Subscript denoting a specific coating

applied;

n=

Total number of coatings applied

in the

participating coating lines

C,.~ The VOM content of each coating as

applied in units of kg VOM/l

(lbs

VOM/~ai)of coating (minus water and any

compounds which are specifically

exempted from the definition

of VON)

D~

The density of VOM in each coating

applied.

For the purposes of

calculating

A,, the density is 0.882 kg

VOM/l VON (7.36 lbs VON/gal VON)

---

72

V,.~ Volume of each coating applied for the

day in units of 1

(gal)

of coating

(minus water and any compounds which are

specifically exempted from the

definition of VOM); and

L,.~ The VON emission limitation for each

coating applied,

as specified in Section

218.204 of this Subpart, in units of kQ

VON/i

(lbs VON/cial)

of coating

(minus

water and any compounds which are

specifically exempted from the

definition of VON).

~j

The portion of the alternative daily emission

limitation for coating operations at

a source

using powdered coating

(A,,)

shall be

determined for all such participating powder

coating lines at the source on a daily basis

as follows:

m

n

A,,

=

~

~

D)

Kh

h=1 j=l

(D~

—

L~)

where:

The VON emissions allowed for the day

in

units of k~/dav (lbs/day)

~

Subscript denoting a specific powder

coating line

j~

Subscript denoting a specific powder

coating applied

m=

Total number of participating powder

coating lines;

n=

Total number of powder coatings applied

in the participating coating lines;

The assumed density of VON in liquid

coating.

0.882

kci VON/l VON

(7.36 lbs

VOM/cial VOM);

Volume of each powder coating consumed

for the day in units of

1

(gal)

of

coating;

and

~

The VON emission limitation for each

coating applied,

as specified in Section

218.204 of this Subpart.

in units of kg

---

73

VON/i

(lbs VON/gal) of coating

(minus

water and any compounds which are

specifically exempted from the

definition of VON); and

K=

A constant for each individual coating

line representing the ratio of the

volume of coating solids consumed on the

liquid coating system which has been

replaced to the volume of Powder coating

consumed on the replacement line to

accomplish the same coating lob.

This

value shall be determined by the source

based on tests conducted and records

maintained pursuant to the requirements

of Section 218.213 of this Subpart

demonstrating the amount of coating

solids consumed as both liquid and

powder.

Test methods and recordkeepinci

requirements shall be a~~rovedby the

Agency and USEPA and shall be contained

in the source’s operating permit as

federally enforceable permit conditions,

subject to the following restrictions:

jj

K cannot exceed 0.9 for non—

recycled powder coating systems;

or

jjj..

K cannot exceed 2.0 for recycled

powder coating systems.

(Source:

Added at

_____

Ill.

Reg.

__________,

effective

Section 218.213

Recordkeeping and Reporting for Cross-Line

Averaging Participating Coating Lines

AnY owner or oPerator of a coating line that elects to com~lvby

means of Section 218.212 of this Subpart shall establish the

following:

~J..

BY the date consistent with Section 218.210(f)

of this

Subpart,

or upon initial start-up of a new coating line

replacing a pre—existing coating line,

as defined in

Section 218.212 of this Subpart,

or upon changing the

method of compliance for a Pre—existing coating line

from the requirements of Section 218.204 or Section

218.207 of this Subpart to the requirements of Section

218.212 of this Subpart, the owner or operator of the

source shall certify to the Agency that each

participating coating line,

as determined

in accordance

with Section 218.212 of this Subpart, will be in

compliance

with

Section

218.212

of

this

Subpart

on

and

after a date consistent with Section 218.210(f)

of this

---

74

Subpart, or on and after the initial start-up date of

such participating coating lines.

Such certification

shall also include:

fl

The name and identification number

of each

participating coating line

21

The name and identification number of each coating

as applied on each participating coating line

~j

The weight of VOM per volume of each coating and

the volume of each coating

(minus water and any

compounds which are specifically exempted form the

definition of VON) as applied each day on each

participating coating line

41

The instrument or method by which the owner or

operator will accurately measure or calculate the

volume

of

each

coating

as

applied

each

day

on

each

participating coating line

.~l

The method by which the owner or operator will

create and maintain records each daY as required

in subsection

(b)

of this Section

~j

An example of the format

in which the records

required in subsection

(b)

of this Section will be

kept

21

A statement that all coatings used on

participating coating lines have a VON content

less than or equal to the applicable VON

limitation for such coating set forth within

Appendix H of this Part,

and that all lines

either:

Al

Underwent a change in operations

incorporating a lower VON coating on each

applicable participatinq coating line after

the date of JanuarY

1,

1991;

or

~1

Are not in compliance and continued

compliance with the coating limitations in

Section 218.204 of this Subpart, compliance

with which is required on or after March 15.

1996.

~j

The method by which the owner or operator has

calculated K.

for the eguation contained in

Section 218.212(d) (2) (B)

of this Subpart,

if

applicable.

~j

On

and

after

a

date consistent with Section 218.210(fI

of

this

Subpart,

or

on

and

after

the

initial

start-up

---

75

date, the owner or operator of a source electing to

com~lvwith the requirements of this Subpart by means

of Section 218.212 of this Subpart shall collect and

record the following information on a daily basis for

each participating coating line and maintain the

information at the source for a period of three years:

~j

The name and identification number of each coating

as applied on each participating coating line

21

The weight of VON per volume and the volume of

each coating

(minus water and any compounds which

are specifically exempted from the definition of

VON)

as applied on each participatina coating line

on a daily basis; and

fl

The daily weighted average VON content of all

coatings as applied on each coating line as

defined at

35

Ill. Adm. Code 211.1230.

gj

On and after a date consistent with Section 218.210(f)

of this Subpart,

the owner or operator of participating

coating lines

shall:

fl

Notify the Agency within 30 days following an

occurrence of a violation of Section 218.212 of

this Subpart;

and

2.1

Send to the Agency any record showing

a violation

of Section 218.212 of this Subpart within 30 days

following the occurrence of a violation.

(Source:

Added at

_____

Ill.

Reg.

_________,

effective

____

__________________________________________________________ )

Section 218.214

Changing Compliance Methods

~j

At least

30 calendar days before changing the method of

compliance with this Subpart from Section 218.212 of

this Subpart to Section 218.204 or Section 218.207 of

this Subpart, the owner or operator of

a source relying

on Section 218.212 to demonstrate compliance with this

Subpart for one or more pre—existinci coating lines

shall comply with all requirements of Section 218.211

(c) (1) or

(e) (1)

of this Subpart, respectively.

~j

Upon changing the method of compliance with this

Subpart from Section 218.212 to Section 218.204 or

Section 218.207 of this Subpart, the owner or operator

of a source shall comply with the requirements of

Section 218.211(c)

or

(e)

of this Subpart,

respectively.

---

76

~

The owner or operator shall certify that all remaining

participating coating lines,

if any, comply and

continue to comply with the requirements of Section

218.212 of this Subpart.

(Source:

Added at

_____

Ill.

Reg.

,

effective

____

__________________________________________________________ )

SUBPART Q:

LEAKC

FROM

SYNTHETIC

ORGANIC

CHEMICAL

AND

POLYMER

MANUFACTURING PLANT

Section 218.431

Applicability

~j

The provisions of Sections 218.431 through 218.436 of

this Subpart shall apply to:

IL

Every owner or operator of any chemical

manufacturing process unit that manufactures,

as a

Primary product, one or more of the chemicals

listed in Appendix A of this Part and that

chemical manufacturing process unit causes or

allows any reactor or distillation unit,

either

individually or in tandemL

to discharge one or

more process vent streams either directly to the

atmosphere or to a recovery system; and

21

All continuous distillation and reactor process

emission units not sublect to Section 218.520

through 218.527 of this Part,

and located within

Stepan Company’s Njilsdale manufacturing facility.

Elwood,

Illinois.

~

Notwithstanding subsection

(a)

of this Section, the

control requirements set forth within Section 218.432

of this Subpart shall not a~~1v

to the following:

~

Any process vent stream with a total resource

effectiveness

(TRE)

index value greater than 1.0.

However, such process vent stream remains sublect

to the performance testing requirements contained

in Section 218.433 of this Subpart and the

reporting and recordkeeping requirements contained

in Section 218.435 of this Subpart

21

Any reactor or distillation unit that is designed

and operated as a batch operation

~j

Any reactor or distillation unit that is part of a

polymer manufacturing operation

41

AnY reactor or distillation unit that is part of

the chemical manufacturing process unit with a

total design capacity of less than

1 gigagram

---

77

(1,100

tons)

per

year

for

all

chemicals

produced,

as a primary product, within that process unit.

However,

such operations remain subiect to the

reporting and recordkeepincz requirements contained

in Section 218.435(d)

of this Subpart

~j

Any vent stream with a flow rate less than 0.0085

scm/mm

or

a total VON concentration of less than

500 ppmv,

less methane and ethane. as measured by

Method 18,

or a concentration of VON of

less than

250 ~pmv as measured by Method

25A.

However, such

operations remain sublect to the performance

testing requirement listed in Section 218.433 of

this Subpart, as well as the reporting and

recordkeepirig requirements contained in Section

218.435 of this Subpart; or

~J..

Any reactor or distillation unit included within

an Early Reduction Program, as specified in 40 CFR

63. and published in 57

Fed.

Reg.

61970

(October

22,

1993), evidenced by

a timely enforceable

commitment approved by USEPA.

(Source:

Added at

_____

Ill. Reg.

,

effective

____

___________________________________________________________)

Section 218.432

Control Requirements

~j

Every owner or operator of

a source sublect to the

requirements of this Subpart,

as determined by Section

218.431 of this Subpart,

shall either:

fl

Reduce emissions of VON,

less methane or ethane,

by 98 weight-percent,

or to 20 ppmv,

on a dry

basis,

corrected to 3 percent oxygen. whichever is

less stringent

2.1

If a boiler or process heater is used to comply

with this Subpart, the vent stream shall be

introduced into the flame zone of the boiler or

process heater; or

fl

If a flare is used to comply with this Subpart,

it

shall comply with the requirements of 40 CFR

60.18,

incorporated by reference at Section

218.112 of this Part.

The flare operation