ILLINOIS POLLUTION CONTROL BOARD
    February 15,1979
    IN THE MATTER OF:
    PROPOSED AMENDMENT TO
    )
    R77-3
    RULE 205(g) (1)
    OF THE
    AIR POLLUTION CONTROL
    REGULATIONS
    PROPOSED OPINION OF THE BOARD
    (by Mr. Dumelle):
    This proceeding was initiated by
    a Petition from The
    Sherwin-Williams Company, Monsanto Company, The B.F. Goodrich
    Company, and Borg-Warner Corporation
    (Petitioners) which was
    filed with the Board on February
    15,
    1977 and published in
    Environmental Register #143 on March
    21,
    1977.
    An Amended Petition
    filed on August
    26,
    1977 served as the basis for all evidence
    received.
    The Amended Petition was summarized in Environmental
    Register #156 dated September 26,
    1977.
    Hearings were held
    on November
    30,
    1977 and January
    30,
    1978
    in Chicago and Janu-
    ary 12,
    1978 in Peoria.
    A study entitled “Economic Impact of
    the Proposed Change in the Hydrocarbon Emission Limitation for
    Petrochemical Manufacturing Processes
    (R77-3)”
    (INR Document
    #78/30)
    (Ex.
    14) was received by the Board from the Institute
    of Natural Resources on October
    31, 1978.
    Hearings were held on
    the study on December
    4,
    1978
    in Chicago and December 18, 1978
    in
    Ottawa.
    This Proposed Opinion supports
    a Proposed Order adopted
    by the Board on January
    4,
    1979.
    The Board has proposed to
    adopt this amendment in the form
    in which
    it appeared in the
    Amended Petition.
    NEED FOR THE REGULATION
    On December 18, 1975 the Board ruled that the organic
    emissions from a para—cresol manufacturing process were covered
    by Rule 2O5(g) (1) (C)
    of the Air Pollution Control Regulations
    (The Sherwin-Williams Company
    v. EPA, PCB 75-268,
    19 PCB 478).
    This decision meant that many petrochemical manufacturing processes
    whose organic emissions had been covered by Rule 205(f)
    (8 pounds
    per hour or 85
    removal for photochemically reactive material)
    would now be required to meet a standard of 100 ppm equivalent
    methane.
    Petitioners claimed that this would result in exorbitant
    expense with very little benefit.
    The Agency felt that the rule
    could not be applied equitably and that a concentration based
    standard was undesirable
    in this instance.
    Petitioners have proposed to allow affected sources to
    choose between the limitations
    of Rule 205(f)
    or the present
    limitation provided there
    is no increase
    in total organic emissions.
    New sources would have the same choice except all organic emissions,
    32—601
    —2—
    not just photochemically
    reactive emissions,
    would have
    to be
    controlled.
    EFFECT ON AIR QUALITY
    The Agency estimated that adoption of Petitioners’ proposal
    would forego control of 871.2 pounds of organic emissions per
    hour
    or 2200 tons per year
    (R.221).
    This estimate was based on
    a
    review of the permit files which disclosed 58 affected facilities
    with approximately 800 sources.
    (Ex.
    6).
    The Petitioners translated this amount of reduction through
    the Empirical Kinetic Modelling Approach (EKMA)
    to obtain
    a con-
    servatively high estimate of 0.5
    reduction
    in organic emissions
    and 0.25
    reduction in ozone formation which would be foregone
    if the proposal was adopted and all affected sources were located
    in the Chicago area.
    (R.288, Ex.
    11)
    This
    reduction amounts
    to
    one part per billion or less and could not be measured by any
    routine monitoring method.
    (R.290)
    The effect of the proposal
    on air qualiLy appears
    to be
    negligible.
    TECHNICAL FEASIBILITY AND ECONOMIC REASONABLENESS
    Petitioners and Northern Petrochemical Company showed that
    although they could comply with the present Rule 205(g)(1)(C), the
    cost to do so would be very high and quite variable
    (Ex.
    1,2,3,7,8).
    The wide variations confirm the Agency’s claim that the present
    rule
    is inequitable.
    ~1henthese costs
    are compared with the
    insignificant improvement in air quality,
    they are rendered
    unreasonable.
    ECONOMIC IMPACT
    The authors
    of the economic impacL study concluded that
    compliance with the present
    standard would require approximately
    $83 million in capital costs and $26 million in annualized opera-
    ting costs.
    These amounts can be translated
    to approximately
    $2750 per year per ton of hydrocarbon emissions eliminated.
    The
    study authors reviewed the literature on the health effects
    of
    exposure to ozone.
    They concluded that there was no way to
    measure any adverse effects from such
    a small increment.
    (Ex.14,
    p.38).
    Consequently the Board can conclude that adoption
    of the proposal will have no significant adverse impact on the
    people of the State of Illinois.
    32—602
    —3—
    I, Christan
    L. Moffett, Clerk of the Illinois Pollution
    Control Board, hereby certify the above Proposed Opinion was
    adopted on the
    _____________
    day of
    ‘~~~jj~)jj
    ,
    1979
    by a vote of
    _______________
    Christan L.
    Moffett, Cl~’±k
    /
    Illinois Pollution Control Board
    32—603

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