ILLINOIS POLLUTION CONTROL BOARD
    October
    1,
    1987
    IN THE MATTER OF:
    VOLATILE ORGANIC MATERIAL
    )
    R82—14
    EMISSIONS FROM STATIONARY
    SOURCES:
    RACT
    III
    PROPOSED RULE
    SECOND NOTICE
    OPINION AND ORDER OF THE BOARD
    (by
    B.
    Forcade):
    This matter
    conies before the Board on
    a series of proposed
    amendments
    to 35
    Ill.
    Adrn.
    Code Par
    215, Organic Material
    Emission Standards
    and Limitations,
    for the control of
    the
    pollutant ozone.
    All
    of
    the proposed amendments address
    some
    aspect of the existing
    regulations controlling volatile organic
    material
    (“VOM’T) emissions
    from coating operations.
    Amendments
    to 35
    Ill.
    Adm,.
    Code 211.122, 215.204, 215.205
    and 215.207 will
    be considered
    in the instant opinion
    and order.
    Merit hearings
    on
    the proposed amendments
    were held on December
    2—3,
    1985;
    March
    20—21,
    1986; August
    4, 1986~August
    7,
    1987;
    September
    3—4,
    1986;
    October
    30,
    1986;
    and November
    7,
    1986.
    Hearings
    regarding the
    Economic Impact Statement
    (EcIS)
    for Sections 215.204 and 215.207
    were held on May
    8 and 21,
    1987.
    Final merit evidence was also
    accepted at these hearings.
    The record closed on June
    30,
    1987.
    On July 16,
    1987,
    the Board proposed regulatory amendments
    to Section 211.122,
    215.204, 215.205 and 215.207 for
    first notice
    comment which were published
    at
    11
    Ill.
    Reg.
    12811
    and 12835,
    August
    7,
    1987.
    The statutory 45—day comment period ended on
    September
    21,
    1987.
    The Board posed additional questions
    for the
    participants
    to comment
    on through
    a hearing officer order,
    dated
    August
    27,
    1987.
    Four substantive
    comments were received
    regarding
    the proposed amendments.
    Additionally, non—substantive
    comments were received from the Secretary of State’s Adminis-
    trative Code Unit
    regarding form and format of the proposed
    rules.
    Those changes have been made
    at second notice.
    In a letter filed
    September
    22,
    1987,
    the Minnesota Mining
    &
    Manufacturing Company
    (3M)
    requested that the hearing officer
    extend the first notice comment period for the proposed
    amendments until October 10,
    1987.
    The Agency filed
    a motion to
    deny 3M’s request on September
    29,
    1987.
    The hearing officer
    referred this matter
    to the Board
    as
    it would impact the timing
    of
    the Board’s decision
    in this matter.
    The Board denies 3M’s
    request.
    First,
    the request
    is untimely,
    as
    the statutory 45—day
    comment period ended
    on September
    21,
    1987.
    Second,
    to allow 3M
    an additional opportunity to comment on not only the proposed
    amendments, but the Agency’s timely filed comments
    as well,
    would
    82—165

    not be evenhanded
    or
    fair.
    Finally,
    the additional two to three
    weeks delay that granting 3M~s request would cause
    is
    unacceptable
    to the Board.
    The Board
    is attempting
    to proceed
    with regulations controlling ozone precursors
    as quickly
    as
    fairness and the requirements of the Environmental Protection Act
    and
    the Administrative Procedures Act permit.
    The federal
    deadline
    for achievement of the National Ambient Air Quality
    Standard
    for Ozone
    is December
    31,
    1987,
    The Board
    and the
    Agency have expended considerable efforts
    to promulgate
    final
    rules
    by
    that date.
    Further delay in this proceeding could very
    well
    defeat that goal.
    The
    Board wishes
    to clarify that
    the
    instant Opinion and Order does not address
    the site—specific
    amendment proposed by
    3M
    for
    its Bedford Park
    facility.
    Today’s
    action addresses
    the proposed amendments
    to the rules
    of general
    applicability.
    The 3M site—specific
    is presently awaiting merit
    decision.
    The first commenter
    raises two issues
    regarding certain
    language in the Opinion of July
    16,
    1987
    (P.C.
    115).
    First,
    the
    commenter asserts
    that the United States Environmental Protection
    Agency’s
    (USEPA) position regarding defects
    in existing Section
    215.207
    is not
    as clear
    as the Board’s opinion may
    lead one
    to
    believe.
    The commenter suggests
    that
    the existing rule was
    approved
    in
    1980
    by USEPA without condition.
    However, even the
    commenter
    concedes
    that subsequent action by USEPA,
    in the form
    of testimony
    in Board proceedings
    and formal comment on the
    State’s RACT
    II
    package, does make USEPA’s position clear.
    The
    Board concedes
    that the issue has been debated
    in the context of
    this proceeding as well
    as
    in variances and permit appeals.
    While the
    issue may not have been crystal
    clear
    in the early
    1980’s,
    it certainly
    is clear
    today.
    The record
    in the
    proceeding supports both
    the wisdom and necessity of modifying
    Section 215.207.
    The commenter’s second issue
    is whether
    or not compliance
    plans based
    on Section 215.207
    need
    to be submitted to USEPA as
    State
    Implementation Plan
    (SIP)
    revisions under tJSEPA’s “bubble
    policy”
    (P.C.
    115).
    The Board,
    itself, was concerned with these
    issues and requested additional
    comments
    in the August 27,
    1987,
    Hearing Officer
    Order.
    It
    is apparent from the record before the
    Board
    that USEPA’s position has fluctuated wildly on
    this
    issue.
    The commenter accurately notes
    that rJSEPA’s policy “has
    not been
    as clear
    as
    the opinion might be
    read
    to suggest.”
    However, while this issue
    is obviously very important to
    facilities presently utilizing Section 215.207
    to achieve
    compliance with RACT coating limitations,
    it
    is tangential
    to the
    issues presently before the Board
    in this proceeding.
    The Board
    is in the process
    of amending
    its regulations.
    The issue
    of how
    the rule will
    be
    implemented by other agencies
    of government may
    or may not come before this Board.
    If and when such issues are
    presented to the Board
    for adjudication,
    the wisdom and legality
    of the rules’
    implementation
    can
    be appropriately addressed.
    82—166

    —3—
    The second commenter notes
    two typographical errors
    in the
    proposed amendments to Section 211,122,
    the definition
    of “Power
    Driven Fastener Coatings”
    (P.C.
    116).
    First,
    in line
    3 of
    the
    definition
    “0.254
    inch”
    should read “0.0254
    inch.”
    Second,
    in
    line
    14 of the definition “Counsel”
    should be “Council.”
    These
    corrections have been made at second notice.
    The third commenter responded
    to the questions posed
    in the
    August 27, 1987,
    Hearing Officer Order regarding the interpreta-
    tion of
    the internal offset rule, Section 215.207,
    and the
    applicability of
    the USEPA federal bubble policy.
    The commenter
    utilizes existing Section 215,207
    to achieve
    compliance with the
    RACT coating
    limitations.
    The proposed amendment
    to Section
    215.207 will not impact the commenter’s compliance status.
    However,
    the commenter
    is the subject
    of
    a USEPA enforcement
    action.
    The commenter’s Section
    215.207 compliance plan was
    never submitted as
    a SIP revision
    to USEPA.
    As previously noted,
    USEPA’s position on the necessity of
    submittal
    of such permits
    as
    SIP revisions has been confusing and inconsistent.
    The commenter
    urges that the Board
    not take any action
    to revoke or qualify the
    protections available under Section 215.207
    on which many
    companies have
    relied.
    The Board,
    by amending Section 215,207,
    does change
    the content of the rule.
    However,
    the principles,
    requirements and conditions embodied
    in the December
    6,
    1986,
    federal “bubble policy” are not expressly incorporated
    in the
    language of the amended
    rule.
    It may be argued that consistency
    with
    the federal
    “bubble policy” may be necessary to comply with
    federal law or policy.
    The Board,
    however, makes
    no such holding
    today.
    The Illinois Environmental Protection Agency
    (Agency) filed
    comments responding
    to questions posed both
    in the July 16,
    1987,
    first notice opinion and
    in the August 27,
    1987, Hearing Officer
    Order
    (P.C.
    119),
    The Agency also supplemented
    the record with
    various newspaper articles and documents regarding ozone
    attainment and
    the SIP process.
    The Agency responds
    to the Board’s request
    for justification
    of
    the proposed language
    in Section 215.207(a)
    that reads:
    “methods or procedures used
    to determine emission
    of VOM under
    this Section shall
    be approved by the Agency.”
    First,
    the Agency
    responds that
    this language was copied from Section 215.205
    for
    consistency and also because
    it has already been found acceptable
    by the Board
    for Section 215,205.
    Second,
    this language does not
    authorize the Agency
    to change existing test methods already
    adopted by the Board.
    Third, this
    language enables the Agency
    to
    review elements of compliance procedures not otherwise addressed
    by Board
    rules, and
    to formalize procedures
    to be followed or
    formalize Agency acceptance of procedures submitted by
    a company,
    in permit conditions.
    These procedures address items that the
    Agency must examine
    in the permitting process
    in order
    to
    determine
    the adequacy of the application and the compliance
    82—167

    —4—
    status of
    the company, such
    as selected
    coating lines,
    calculation procedures,
    frequency of sampling,
    verification of
    control equipment efficiency, extent of material usage
    records,
    nature
    of documentation on coating VOM content, and availability
    of records.
    The nature of these procedures can vary greatly
    depending upon the particular circumstances of
    a company,
    e.g.,
    the margin of compliance,
    the equipment present, and the nature
    of existing production records.
    Fourth,
    in the absence of prior
    review by the Agency
    in the permitting process,
    a company could
    believe
    that
    it was satisfying
    the requirements of Section
    215.207.
    However,
    the Agency could consider
    the company not
    to
    be
    in compliance
    for failure
    to adequately address
    the
    requirements
    of Section 215.102, Section 215.207(a),
    Section
    215.207(c),
    or Section 215,208.
    The Agency’s proposed language
    protects
    a company by drawing attention
    to the fact that the
    methods
    and procedures must be presented
    to and approved by the
    Agency.
    The Agency reminds the Board
    that Agency determinations
    made
    in the permitting process are subject
    to appeal and review
    by the Board
    in
    a permit denial
    appeal.
    The Board finds
    the Agency’s justification persuasive.
    The
    implementation of Section 215,207
    as
    a compliance option varies
    with each and every facility.
    Section 215,207
    is intended to
    provide
    a flexible alternative
    to line—by—line compliance with
    the emission limitations
    of Section 215,204, with certain
    restrictions.
    Inherent
    in its approach
    is
    a requirement of
    flexibility
    in Agency review and implementation.
    It
    is not
    possible to write a coherent rule that envisions all
    contingencies and potential applications.
    Therefore,
    in the
    limited context of these
    rules,
    we believe
    that the “shall be
    approved by the Agency” language
    is appropriate and necessary.
    Concerning
    the Board’s request
    for clarification regarding
    the use of the language “selected coating
    lines”
    in proposed
    Section 215.207(a),
    the Agency responds that the selection of
    the
    coating lines
    is made by the permit applicant.
    The intended
    basis of
    the selection
    is for the company
    to demonstrate
    compliance with
    a minimum number
    of coating
    lines.
    The Board
    appreciates this clarification.
    In the July
    16,
    1987, Opinion,
    the Board suggested certain
    modifications
    in Section 215.207
    to the definitions of R~, EALL,
    EACTand S~. The Agency concurs with these suggested changes as
    they are consistent with the Agency’s intent and help clarify the
    rule.
    These changes are made at second notice.
    In response to questions posed in the August
    27,
    1987,
    Hearing Officer Order,
    the Agency states that
    56 permits based
    on
    Section 215.207 have been issued.
    Of these,
    46 are in ozone non—
    attainment areas
    and 10 are in attainment areas, including
    four
    in McHenry or Will County.
    The Agency has not submitted any of
    82—168

    —5—
    the permits based
    on existing Section 215.207
    to the USEPA
    as
    formal amendments
    or revisions
    to the Illinois SIP for ozone.
    The Agency contends that the proposed amendments to Section
    215,207 are “pending” before USEPA.
    Commenting generally about
    the language of Attachment
    3 and
    the federal Emissions Trading Policy,
    the Agency reminds
    the
    Board
    that Section 215.207 was conditionally approved by USEPA
    in
    1980.
    As
    an approved rule that
    is part of
    Illinois’
    SIP, any
    company can avail themselves
    of the regulation.
    The Agency’s
    proposed Section 215.207 was sent
    to USEPA for parallel
    processing
    as
    a SIP revision on September
    5,
    1985.
    If the
    Agency’s proposed Section
    215.207
    is adopted
    by the Board, USEPA
    should approve
    it since
    it corrects
    the flaw
    in the regulation
    (volumetric calculations) which has been identified by USEPA.
    Companies should continue
    to be able
    to avail themselves of
    this
    regulation in the future.
    The Agency concedes that the amendments
    to Section 215.207
    presently pending do not conform to the federal
    “bubble policy”
    of December
    6,
    1987.
    However,
    the Agency does not suggest that
    Section 215,207
    be further modified at this
    time.
    The Agency
    contends that the amendments presently pending will correct
    a
    long—standing deficiency and will
    be responsive to USEPA’s
    present concerns.
    The Agency suggests
    that Section 215.207 may,
    at some future time,
    need
    to be further modified
    to be consistent
    with federal policy.
    The Agency believes that the amendments
    to
    Section 215,207 pending before the Board will be approved by
    USEPA.
    If and when the Agency receives
    a SIP deficiency notice
    from USEPA regarding consistency with the federal “bubble
    policy”,
    it will
    consider further amendment.
    The Board believes
    that the Agency’s suggested course
    of
    action
    is
    a prudent one under
    the circumstances.
    The Board notes
    that the federal “bubble policy”
    is relatively new and its
    incorporation or implementation
    in presently pending amendments
    to Section 215.207
    is not presently at
    issue
    in this
    proceeding.
    The proposed amendments will help fulfill the
    state’s obligations
    under
    the Clean Air Act and avoid federal
    sanctions.
    The Board will,
    therefore, direct the Clerk
    of the
    Board to submit the proposed amendments
    to Sections 211.122,
    215,204, 215.205 and 215.207 for second notice review by the
    Joint Committee on Administrative Rules.
    ORDER
    The following amendments
    to
    35 Ill. Adm.
    Code Parts 211 and
    215 are directed
    to the Joint Committee
    on Administrative Rules
    for second notice review.
    82—169

    —6—
    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 A:
    GENERAL PROVISIONS
    Section
    211.101
    Incorporations by Reference
    211.102
    Abbreviations and Units
    SUBPART
    B:
    DEFINITIONS
    Section
    211.121
    Other Definitions
    211.122
    Definitions
    Section 211.122
    Definitions
    “Power Driven Fastener Coating”:
    The coating
    of nail,
    staple, brad and finish nail fasteners where such
    fasteners are fabricated from wire or rod of 0.0254
    inch
    diameter or greater, where such fasteners are bonded
    into coils or strips,
    such coils
    and strips containing
    a
    number of such fasteners, which fasteners are manufac-
    tured
    for use
    in power
    tools,
    and which fasteners must
    conform with formal standards for specific uses estab—
    lished
    by various federal
    and national organizations
    including Federal Specification FF—N—lOSb of the General
    Services Administration, Bulletin UM—25d
    of the U.S.
    Department
    of Housing
    and Urban Development
    Federal
    Housing Administration and
    the Model Building Code of
    the Council
    of American Building Officials,
    and similar
    standards.
    For
    the purposes
    of
    this definition,
    the
    terms “brad”
    and “finish nail”
    refer
    to single leg
    fasteners fabricated
    in the same manner
    as staples.
    The
    application of coatings
    to staple, brad, and finish nail
    fasteners may be associated with the incremental forming
    of such fasteners
    in
    a cyclic or
    repetitious manner
    (incremental fabrication)
    or with the forming
    of strips
    of
    such fasteners
    as
    a unit from a band of wires
    (unit
    fabrication).
    “Specialty High Gloss Catalyzed Coating”:
    commercial
    contract finishing of material prepared for printers and
    lithographers where the finishing process uses
    a
    solvent—borne coating,
    formulated with
    a catalyst,
    in
    a
    82—170

    —7—
    quantity of
    no more than 12,000 gallons/year
    as
    supplied, where the coating machines are sheet
    fed and
    the coated sheets are brought
    to
    a minimum surface
    temperature of 190
    F.
    ,
    and where
    the coated sheets are
    to achieve
    the minimum specular reflectance index of 65
    measured at
    a
    60 degree angle with
    a gloss meter.
    (Source:
    Amended at
    Ill.
    Reg.
    ,
    effective
    )
    TITLE
    35:
    ENVIRONMENTAL PROTECTION
    SUBTITLE
    B:
    AIR POLLUTION
    CHAPTER
    I:
    POLLUTION CONTROL BOARD
    SUBCHAPTER
    c:
    EMISSION STANDARDS AND
    LIMITATIONS FOR STATIONARY SOURCES
    PART 215
    ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS
    SUBPART
    F:
    COATING OPERATIONS
    Compliance Schedules
    Emission Limitations
    for Manufacturing Plants
    Alternative Emission Limitations
    Exemptions from Emission Limitations
    ~
    eff~e~
    Compliance by Aggregation
    of Emission
    Sources
    Testing Methods
    for Solvent Content
    Exemption from General Rule on Use of Organic Material
    Alternative Compliance Schedule
    Compliance Dates and Geographical Areas
    Compliance Plan
    Special Requirements for Compliance Plan
    Section 215.204
    Emission Limitations
    for Manufacturing Plants
    No owner
    or operator
    of
    a coating line shall cause
    or allow the
    emission of volatile organic material to exceed the following
    limitations
    on coating materials,
    excluding water and any
    compounds which
    are specifically exempted from the definition
    of
    volatile organic material pursuant to this Part,
    delivered to the
    coating applicator:
    a)
    Automobile or Light Duty Truck Manufacturing Plants
    1)
    In Cook County
    kg/i
    lb/gal
    Prime coat
    0.14
    (1,2)
    Prime surfacer coat
    0.34
    (2,8)
    Section
    215,202
    215,204
    215.205
    215.206
    215.207
    215.208
    215.209
    215.210
    215.211
    215.212
    215.213
    82—171

    —8—
    (Board Note:
    The prime surfacer coat limitation
    is
    based upon a transfer efficiency
    of
    30 percent.
    The prime surfacer coat limitation shall not apply
    until December
    31,
    1982.)
    Top coat
    0,34
    (2,8)
    (Board Note:
    The limitation
    is based upon
    a
    transfer efficiency of
    30 percent.
    The top coat
    limitation shall not apply until December
    31,
    1985.)
    Final
    repair coat
    0.58
    (4.8)
    (Board Note:
    The limitation shall not apply until
    December
    31,
    1985)
    2)
    In Boone County
    Prime Coat
    0.14
    (1.2)
    Prime coat surfacer
    0,34
    (2.8)
    Top coat
    0,34
    (2.8)
    (Board Note:
    The top coat limitation shall not
    apply if by December
    31, 1984,
    a limitation of 0.43
    kg/l
    (3.6 lb/gal)
    is achieved and the top coat
    is
    applied with
    a transfer efficiency of not less than
    55 percent and by December
    31,
    1986,
    the top coat
    is applied with
    a transfer efficiency of not less
    than 65 percent)
    Final repair coat
    0,58
    (4,8)
    3)
    In the remaining counties
    Prime
    coat
    0.14
    (1.2)
    Prime surfacer coat
    0.34
    (2.8)
    Top coat
    0.34
    (2,8)
    Final repair coat
    0.58
    (4.8)
    b)
    Can Coating
    1)
    Sheet basecoat and
    Overvarnish
    0,34
    (2.8)
    2)
    Exterior basecoat
    and overvarnish
    0.34
    (2.8)
    3)
    Interior body spray
    coat
    0,51
    (4.2)
    4)
    Exterior end coat
    0.51
    (4.2)
    5)
    Side seam spray coat
    0.66
    (5.5)
    82—172

    —9—
    6)
    End sealing
    compound coat
    0.44
    (3.7)
    c)
    Paper Coating
    1)
    All paper coating except
    as provided
    in sub
    section
    (c)(2)
    0.35
    (2.9)
    2)
    Specialty High Gloss
    Catalyzed Coating
    0.42
    (3.5)
    (Board Note:
    The These limitations shall not apply
    to
    equipment used for both printing and paper coating)
    d)
    Coil Coating
    0.31
    (2.6)
    e)
    Fabric Coating
    0.35
    (2.9)
    f)
    Vinyl Coating
    0.45
    (3.8)
    g)
    Metal Furniture Coating
    0,36
    (3.0)
    h)
    Large Appliance Coating
    0.34
    (2.8)
    (Board 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 liters
    (1 quart)
    in any one eight—hour
    period)
    i)
    Magnet Wire Coating
    0.20
    (1.7)
    j)
    Miscellaneous Metal Parts
    and Products Coating
    1)
    Clear coating
    0.52
    (4.3)
    2)
    Air dries coating
    0.42
    (3.5)
    3)
    Extreme performance
    coating
    0.42
    (3.5)
    4)
    Power driven fastener coating
    A)
    Nail coating
    Refer
    to limits
    in
    (j)(l),
    (2),
    (3)
    and
    (5)
    82—173

    —10—
    B)
    Staple,
    brad
    arid fin-
    ish nail unit fabri-
    cation bondir~g
    coating
    0.64
    (5.3)
    C)
    Staple,
    brad and fin-
    ish nail incremental
    fabrication lubri-
    city coating
    0.64
    (5.3)
    D)
    Staple, brad and fin-
    ish nail incremental
    fabrication withdrawal
    resistance coating
    0.60
    (5.0)
    E)
    Staple,
    brad and fin-
    ish nail unit fabri
    cation coating
    0.64
    (5.3)
    45)
    All other coatings
    0.36
    (3.0)
    (Board Note:
    The least restrictive limitation shall
    apply
    if more than one limitation pertains
    to
    a specific
    coating)
    k)
    Heavy Off—highway Vehicle
    Products
    1)
    Extreme performance
    prime coat
    0.42
    (3.5)
    2)
    Extreme performance
    top coat—air dried
    0,52
    (4.3)
    3)
    Final
    repair coat—
    air dried
    0.58
    (4,8)
    1)
    Wood Furniture Coating
    1)
    Clear topcoat
    0.67
    (5,6)
    2)
    Opaque stain
    0.56
    (4.7)
    3)
    Pigmented coat
    0.60
    (5.0)
    4)
    Repair coat
    0.67
    (5.6)
    5)
    Sealer
    0.67
    (5.6)
    6)
    Semi—transparent
    stain
    0.79
    (6.6)
    82—174

    -Il-
    7)
    Wash coat
    0.73
    (6.1)
    (Board Note:
    The repair coat has overall transfer
    efficiency of
    30 percent;
    all others have an overall
    transfer efficiency
    of 65 percent.)
    (Source:
    Amended
    at
    Ill.
    Reg.
    ________,
    effective
    Section 215.205
    Alternative Emission Limitations
    Owners or operators of coating
    lines subject
    to Section 215.204
    may comply with this Section,
    rather than with Section 215,204.
    The methods or procedures used
    to determine emissions of organic
    material under
    this sSection shall be approved by the Agency.
    Emissions of volatile organic material from sources subject to
    Section 215.204, are allowable, notwithstanding
    the limitations
    in Section 215.204,
    if ~t~ehem
    s~ort~ere eon
    o3~e~by one of
    the fo3~ow4ng
    methods:
    a)
    For those sources subject to Section 215,204(b),
    the
    emissions are controlled by Aan afterburner
    system which
    provides:
    ~ p~ov4~ed~he~
    Th ~e~een~
    of the em~s~one
    from the eoo~4n~~ne
    on~9~~ereen~
    of the nonmethene
    vo~3e
    o~gen~emer~a~+meast~e~e~~e’~ei~
    eombt~s~4b~e
    eathon)-
    w~4ehen~er~the
    ef~e~b~ne~
    ~e
    o~4d4~ed~o
    carbon d4ox4~ean~wa~eri or
    1)
    75
    reduction
    in the overall emissions
    of volatile
    organic material from the coating
    line, and
    2)
    Oxidation
    to carbon dioxide and water
    of 90
    of
    the nonmethane volatile organic material
    (measured
    as total combustible
    carbon)
    which enters
    the
    afterburner.
    b)
    For all other
    sources subject
    to Section 215,204, the
    emissions are controlled by an afterburner system which
    provides:
    1)
    81
    reduction
    in the overall emissions of volatile
    organic material from the coating line,
    and
    2)
    Oxidation
    to carbon dioxide and water
    of 90
    of
    the
    nonmethane volatile organic material
    (measured as
    total combustible carbon) which enters the after-
    burner.
    bc)
    1~The system used to control such emissions
    is
    demonstrated
    to have control efficiency equivalent
    to or
    greater than that provided under
    the applicable pro-
    vision of Section 215.204
    or subsections
    (a)
    or
    (b)
    ae
    a~preve~by the Ageney.
    82—175

    —12—
    (Source:
    Amended
    at
    Ill.
    Reg.
    _______,
    effective
    Section 215.207
    ~n~erne~ êffse~ Compliance by
    Aggregation
    of
    Emission
    Sources
    a)
    No
    per~en
    ~ha~
    eat~e
    or
    a~ow
    the em4~4on of vo~a~43e
    organ~e
    ma~er4a~ from
    any
    eoa~4ng
    ~4ne
    ~o
    e~eeed
    any
    ~m4~a~en
    eon~a4ne~~n See~4en~5T2g4
    t~n~e~
    Owners
    or
    operators of coating
    lines subject
    to Section 215.204
    may comply with this
    Section rather than with Section
    215.204.
    The methods
    or procedures used
    to determine
    emissions of volatile organic material
    under
    this
    Section shall
    be approved by
    the Agency.
    Emissions of
    volatile organic material from sources subject
    to
    Section 215.204 are allowable, notwithstanding the
    limitations
    in Section 215.204,
    if
    the combined actual
    emissions ra~efrom aH
    selected coating lines at the
    coating plant,
    but not including coating
    lines
    or other
    emission sources constructed
    or modified after July
    1,
    1979,
    is less
    than or equal
    to the combined allowable
    emissions re~eas determined
    by the following equations:
    BALL
    =
    ~
    (A~B1)~
    j=l
    i=l
    EACT
    ~
    (CiBj(l
    j=l
    i=l
    b)
    A1 shall be determined by the following formula:
    A
    =
    ____________
    1
    1
    -
    ______
    bc)
    As used in subsection
    (a),
    symbols mean the following:
    BALL
    =
    the allowable volatile organic material
    emissions ra~efrom the coating plant
    in
    k4~ogram~per ~ay kg/day
    (pounds per ~ay
    lb/day).
    A1
    the allowable emission rate limit
    for eae~a
    coating pursuant
    to Section 215,204 express~d
    in
    kg/l
    (lbs/gal)
    of coating solids7 e~e~a~ng
    wa’~er7 de~vered
    ~e
    the
    eoa~ng
    app~4ea~or.
    82—17 6

    —13—
    =
    the volume of
    eee~’t coating solids
    in 1/day
    (gal/day),- exe~~ng
    wa~er~in
    a coating as
    delivered
    to the coating app~4ea~orline.
    m
    =
    the number
    of coating lines included in the
    combined emission rate.
    n
    =
    the number
    of ~ype~ of different coatings
    delivered
    to
    the
    a
    coating
    epp~4ea~orline.
    EACT
    =
    the actual volatile organic material emissions
    rate from the coating plant
    in kg/day (lb/day)
    =
    the weight
    of volatile organic material per
    volume
    of
    eoa~ng
    solids
    in kg/l
    (lb/gal)
    for
    eaelrt
    a coating app~4e~.
    D~
    =
    the control efficiency by which emissions of
    volatile organic material from the a coating
    are reduced through the use of control
    equipment.
    =
    the applicable volatile organic material
    emission limit pursuant
    to Section 215.204,
    for
    a coating
    in kg/l
    (lb/gal).
    =
    the density of
    the volatile organic material
    in
    a coating
    in kg/l
    (lb/gal).
    ed)
    The
    owner
    or
    operator
    of
    the
    coating
    plant
    shall
    maintain records of the density of
    the volatile organic
    material
    in each coating,
    the quantity and ~o~ven~
    volatile organic material and solids content of each
    coating applied
    and the line to which ~i coating
    is
    applied,
    in such
    a manner so
    as
    to a~st~redemonstrate
    continuing compliance with the combined allowable
    emissions
    re~e.
    ~e)
    Except
    for emission sources subject to Sections 215.301
    or 215.302, credits for offse~e from emission sources at
    the coating plant
    that are subject to this Part,
    other
    than coating lines, may be given7 b~ oni~yto the extent
    that they repre~en~re~e~4ensemissions
    are reduced
    from the allowable emission limits for such emission
    sources contained
    in either this Part,
    or any existing
    operating permit, whichever
    limit is less.
    (Source:
    Amended at
    Ill.
    Reg.
    ________,
    effective
    IT
    IS SO ORDERED
    82—177

    —14—
    I,
    Dorothy M.
    Gunn, Clerk
    of the Illinois Pollution Control
    Board, hereby certify that the above Proposed Rule,
    Second Notice
    Opinion and Order was adopted on the /~~* day
    of ______________________,
    1987,
    by a vote of
    ~O
    *
    Dorothy M. X~unn,Clerk
    Illinois Pollution Control Board
    82—178

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