ILLINOIS POLLUTION CONTROL BOARD
October 18,
1979
IN THE MATTER OF:
)
EMISSIONS OF VOLATILE
)
R78—3,4
ORGANIC MATERIAL
SUPPLEMENTARY OPINION AND ORDER OF THE BOARD
(by Mr.
Dumelle):
On July 12,
1979 the Board retained jurisdiction in
this proceeding
in case changes were needed to secure approval
of the Illinois Implementation Plan or to clarify the Board’s
intent in the Opinion adopted on August 23,
1979.
On August 1, 1979 Dow Chemical Company
(Dow)
asked the
Board to reconsider its decision not to exempt 1,1,1-trichloro—
ethane
(methyl chloroform)
or methylene chloride from the
definition of volatile organic material. Dow asked for an
additional hearing to discuss this issue. The Board’s decision
is discussed at length on pages
11-13
of the Opinion.
The
Board sees no reason to reopen the record on this issue.
On August
7, 1979 the Agency asked the Board to include
the definition of open top vapor degreasing contained on
page 28 of the Board’s Proposed Order adopted on March 29,
1979.
The omission of this definition was inadvertent, and
it shall
be inserted in Rule 201.
On October 2,
1979 the Agency asked the Board to reconsider
and clarify the explanation of Rule 205(n)(2)(A) on pages
21
and 22 of the Opinion.
Rule 205 (n)(2)(A) provides for compliance with the
applicable emission limitations through the use of afterburners.
This rule requires that at least 75
of the VOC emissions
from a coating line be captured and oxidized by an afterburner
that
is at least
90
efficient in oxidizing VOC, measured as
total combustible carbon,
to carbon dioxide and water.
It is
necessary to require an overall
level of control,
as well
as
an afterburner efficiency requirement to ensure that emissions
are captured and controlled.
“If
there
is no capture
requirement,
then setting a requirement for oxidation in the
afterburner may be meaningless because there would be no
assurance that emissions would ever reach the afterburner to
be oxidized.”
(Public Comment 74)
By requiring an overall
efficiency of 75
in the control
system,
a source
is allowed
flexibility to capture a greater or lesser amount of VOC
emissions depending on the efficiency of the afterburner.
For example,
if source A’s afterburner is 90
efficient,
84
35—5
55
—2—
of that source’s emissions will need to be captured to
achieve an overall
75
reduction;
but
if source B’s afterburner
is 99
efficient,
source
B will only need to capture 76
of
the VOC emissions.
The Board believes that these capture
efficiencies will
he achievable by the compliance date
because at least one plant is already capturing 73
(Ex.17).
The Board hereby adopts
its Opinion dated August 23,
1979 and this Supplementary Opinion as its Opinion in this
proceeding.
ORDER
1.
Dow Chemical Company’s motion for reconsideration or
additional hearings
is hereby denied.
2.
The Agency’s motion to reconsider and clarify the
Board’s Opinion is hereby granted.
3.
The following definition is hereby added to Rule 201 of
Chapter 2:
Air Pollution:
Open Top Vapor Degreasing:
The batch process of
cleaning and removing soils from surfaces by
condensing hot solvent vapor on the colder metal
parts.
4.
The Board’s decision to retain jurisdiction
in this
proceeding
is hereby vacated.
IT IS SO ORDERED.
I, Christan L. Moffett,
Clerk of the Illinois Pollution
Control Board, hereby certify the a~~oveSupplementary Opinion
~~~~jere_adopted
on the
day
Christan L. Moffe
lerk
Illinois Pollution
ntrol Board
35—556