ILLINOIS POLLUTION CONTROL BOARD
October
1,
1987
IN THE MATTER OF:
VOLATILE ORGANIC MATERIAL
)
R82-14
EMISSIONS FROM STATIONARY
SOURCES:
RACT III
ADOPTED RULE
FINAL ORDER
OPINION OF THE BOARD
(by
B.
Forcade)
This matter
comes before the Board
as part
of
a regulatory
proposal
initially filed by the Illinois Environmental Protection
Agency (“Agency”)
on June
30,
1982,
for the control
of organic
material
emissions from selected
industrial categories
and
generic sources.
The particular proposal that
is the subject
of
today’s Opinion and Order regulates organic material emissions
from one of these
industrial categories,
heatset web offset
lithographic printing.
Thirty—three hearings have been held,
to
date,
regarding
the entire R82—14 regulatory proposal.
A number
of these hearings have specifically addressed
the heatset web
offset lithographic printing category.
An economic
impact study
(EcIS)
was prepared specifically addressing
this category
(Ex.
71)
On August
10
and 22, 1984,
the Board proposed regulatory
language and a supporting
opinion, respectively,
for First Notice
(hereinafter,
the first First Notice).
The first First Notice
contained elements
of the original Agency proposal,
as well as
language and modifications submitted
by the Printing Industry of
Illinois
(P11).
Public comments
received during the first First
Notice period cited many problems with the proposed rule and P11
specifically requested an additional
hearing
(P.C.
54,
57
&
62).
On May 30, 1985,
the Board,
noting the confusion and
controversy associated
with this category,
acknowledged that the
first First Notice rule needed revision and that the existing
record needed to be supplemented.
The Board proposed
a second
First Notice
(hereinafter the second First Notice)
for the
purpose of generating comments and criticisms and authorized
additional hearings.
Hearings solely addressing
the heatset web offset category
were held on April
1
and
2,
1986,
in Chicago.
On September
22,
The Board acknowledges
the contributions of David G. Mueller and
Dr. Harish Rao
in this proceeding.
82—179
—.,—
1986,
the Department
of
Energy and Natural Resources
(DENR)
filed
a letter indicating
that further economic impact assessment would
not
be undertaken by DENR for this particular category
of rules,
as
a heatset web offset EcIS was already a part of the Board’s
record
(P.C.
87).
Final comments were received through September
29,
1986.
On April
30, 1987,
the Board proposed regulatory language
for
a third First Notice
(hereinafter,
the third First Notice),
which was published at 11
Ill.
Reg.
10780,
June 12,
1987.
The
statutory 45—day comment period ended on July 27,
1987.
The U.S.
Environmental Protection Agency (USEPA)
filed comments on July
23,
1987
(P.C.
Ill).
The Agency filed
first notice comments,
which were mailed July
27,
1987
(P.C.
112).
The Administrative
Code Unit of the Secretary of State’s Office also filed comments
regarding non—substantive
format changes.
The Board proposed
the
rules
for second notice review by the Joint Committee
on Admin-
istrative Rules
(JCAR)
on August
6,
1987.
The Administrative
Code Unit’s comments were incorporated
in the second notice
Order.
JCAR
issued
a Certification of
No Objection on September
23,
1987,
By Board
order,
dated September 24,
1987, the rules
were directed to the Secretary of State
for final notice
publication
in the Illinois Register.
This Opinion supports the
September
24, 1987, Order.
This
is one of
a series of Board actions directed at
establishing emission controls
to achieve attainment of the
National Ambient Air Quality Standard
(NAAQS)
for
the pollutant
ozone
(03).
Ozone is not emitted
from tailpipes or smokestacks
like other pollutants,
but
is formed
in the atmosphere
by the
action of sunlight on nitrogen oxides
(NOx)
and hydrocarbons
(HC).
This mechanism, which leads
to ozone formation,
involves
a
series
of photochemical reactions.
NOx and
HC are, therefore,
called ozone precursors.
The amount of ozone formed in the
atmosphere
is
a function not only
of the concentration of NOx and
HC, but also
of the meteorology,
in particular
the amount and
intensity
of sunlight.
Ozone
is
a seasonal pollutant,
teaching
its highest concentrations
on warm,
sunny summer afternoons.
The
ozone season
in Illinois extends
from April through October.
The strategy for controlling ozone has been
to reduce
hydrocarbon emissions,
which are the primary ozone precursor,
to
the atmosphere.
These hydrocarbons
are termed “volatile organic
materials”
(VOM)
or “organic materials”
(OM)
in Board
regulations.
This regulatory proceeding
is one of
a series that
implements reasonably available control technology
(PACT)
for the
control
of hydrocarbons from existing major stationary sources
emitting greater than 100 tons per year.
The implementation
of
RACT
in non—attainment areas
for ozone is required as
a part of
a
federally approvable state implementation plan
(SIP)
under the
federal Clean Air Act
(CAA)
(42 U.S.C.
7401 et~!a.).
Section
172
of the CAA requires that RACT be implemented
at existing
82—180
—3—
stationary sources
in the non—attainment areas
of those states
needing
an extension from the 1982 deadline until 1987
to achieve
the air quality standard
for
ozone.
Illinois
is such
a state,
having requested the extension
in its 1979 and 1982 SIP.
The definition
of PACT
is contained in 40 CFR 51, along with
the requirements
for
a federally approvable
SIP.
However,
the
specific parameters of what constitutes reasonably available
controls,
and, therefore,
the levels
of control which the states
must adopt to insure that PACT
is implemented, are not contained
in federal regulations.
Instead,
the United States Environmental
Protection Agency
(USEPA) publishes
a series of documents
entitled “Control Technique Guidelines”
(CTGs).
Each
of the
CTGs,
which are summaries of industry specific case studies,
contains the means and the degree
of control which the USEPA
requires the state
to adopt categorically as part of its SIP
in
order
to have an acceptable SIP.
Failure to adopt
rules
identical
to those presented
in the CTGs,
or other
ones
demonstrated by the individual
state as comparable,
can mean that
the state will have an
inadequate SIP, which
in turn,
can trigger
the sanction provisions of the CAA found at Sections
110,
113 and
176
(42 U.S.C.A.
7410,
7413,
7506).
While the mandate
for
sanctions
is contained
in the CAA,
the mandate to adopt
the CTGs
or otherwise demonstrate
a state
rule
to be comparable
is
not.
It is not even contained in the federal regulations,
but instead
is articulated
in the “General Preamble for Proposed Rulemaking
and Approval of State Implementation Plan Revisions
for Non—
attainment Areas”
(44 FR 20372).
This federal policy statement includes yet another
requirement which
is relevant
to this rulemaking.
The USEPA
allows the states until
the January after one year from the
finalization of
a CTG
to adopt either
the
“rules” contained
therein,
or comparable
rules,
if sources covered by
that
particular CTG are within
a state’s non—attainment
areas.
Also
of interest
is the unstated policy
of the USEPA to publish draft
CTGs.
Draft CTGs are informally distributed
for the purpose of
generating comments.
These comments are often incorporated
in
final CTG publications.
Presumably,
state adoption of rules
comparable
to draft CTG5
is not mandatory.
A draft CTG has been
issued for the heatset web offset industrial category,
but was
withdrawn or terminated
by letter,
dated March
22,
1982,
from
USEPA Deputy Administrator John Hernandez
(Exs.
29(e),
24(o)).
The significance of this will be discussed further
in Section 1,
below.
The proposed regulation
of
the heatset web offset industrial
category has been one of
the most complex and controversial
regulatory proceedings
in recent memory.
This
is due
to the
multiplicity of technical and legal issues that have arisen
in
the course of
this,
now,
five—year proceeding.
Consequently,
it
is necessary
to separately address each issue in what is, hope—
82—181
—4—
fully,
a logical progression.
The general categories are as
follows:
1)
necessity and rationale for regulation
of the
heatset web offset category;
2) description of heatset web
offset printing process and potential emission sources;
3)
scope
of
regulation
—
fountain solutions and
ink solvents;
4) geo-
graphical applicability of the proposed regulations;
and
5)
content
of regulations
—
technical
and economic issues associated
with control options.
1.
Necessity and Rationale
for Regulation of the Heatset Web
Offset Industrial Category
As
a threshold matter,
P11 has argued that there
is no legal
necessity to regulate the heatset web offset industry,
as
no
final CTG exists and the draft CTG was specifically withdrawn
or
terminated by USEPA
(R.
3988).
Alternatively,
P11 argues that
the industry’s
emissions
are de minimus and,
consequently, do not
merit regulation
(R.
3989;
P.C.
82,
p.
6).
Much debate between
the P11 and the Agency occurred during earlier stages
of this
proceeding
as
to the legal effect
of
a withdrawn draft CTG and
the necessity for specific rules
for heatset web offset
printing.
There now appears
some degree of consensus among P11,
the Agency and USEPA that category specific rules
are not legally
required as
a consequence of the existence of
a final CTG
(R.
3984,
3988;
Ex.
102),
However,
this does not necessarily obviate
the need
to
impose RACT controls on this industrial category as
the CAA requires the application of PACT on all major
stationary
sources
of emissions in non—attainment areas
for ozone currently
on
a SIP extension.
Consequently,
all major stationary sources
must be controlled either by applicable CTG—based
rules, generic
RACT rules or category specific rules
that are not CTG—based but
are,
nonetheless, PACT.
The criterion
for determining whether
the heatset web offset
industry needs to be PACT regulated
is whether
or not sources
emitting
over 100 tons/year exist
in areas designated non—
attainment
for ozone.
Emissions
less than 100 tons/year would
be
below the strict legal threshold established
in the CAA.
Whether
or not such emissions are de minimus for the purposes of air
quality planning
for attainment
is
a separate issue.
There are two separate potential sources
of emissions from
the heatset web offset printing process:
VOMs
in the fountain
solution and organic material emission from heated
ink
solvents.
While
there
is disagreement between the Agency and P11
as
to whether ink solvent emissions should be regulated at all,
there
is no dispute
that VOMs
in the fountain solution are
legitimate subjects of regulation
if emitted
in sufficient
quantities.
Information prepared and submitted by the P11
in
post—hearing comments shows both isopropyl alcohol
(isopropanol)
usage
and emissions
(the primary VOM
in fountain solutions)
and
ink solvent usage and emissions
for heatset web offset printing
82—182
—5—
facilities
in non—attainment areas
(P.C.
82, Table
A—C).
Table A
of this survey shows
two facilities
in non—attainment
areas with
isopropanol emissions greater than
100 tons/year.
Thus, even
if
the Board proposed regulatory scope only
included fountain
solution VOM emissions, major stationary sources exist
in
non—
attainment areas.
These figures do not take into account the use
of
isopropanol substitutes which are also VOM,
Consequently,
some form of RACT regulation
is an absolute requirement under the
CAA.
The regulatory choices that remain are generic controls now
proposed
in R86—l8 or rules specific to the heatset web offset
industry.
At this stage
in the proceeding,
the Board believes
that
it
is best to propose category specific rules
in this
R82—l4
docket
for imposition
of PACT,
rather
than subject
this category
to generic controls.
As
a general matter,
category specific
rules
that account
for unique aspects
of an industrial process
are preferable
to generic regulations.
Comments are specifically
requested on this issue.
A second,
correlative
issue,
is whether
the levels
of
control prescribed
in the terminated draft CTG constitutes PACT
for
the heatset web offset industry.
This
is
a separate issue
from whether
category specific
rules are legally required as
a
consequence of
the CTG.
The Board’s
second First Notice and the
Agencyts most current proposal are based on the terminated draft
CTG.
However,
as the Board stated
in the May 30,
1986, Opinion
proposing the second First Notice:
“The
Board
is
not
advocating
this
proposed
language but
is using this second First Notice
opinion
and
order
as
a
vehicle
for
reopening
the record
in
this category and outlining
the
unresolved
issues...The
new
language
will
provide
a
starting
point
to
develop
an
achievable
and
reasonable
rule.”
(P82—14,
RACT
III, Opinion, May 30,
1985,
at
pp.
1—2)
The Board
finds
that the regulations based
on the withdrawn draft
CTG are not necessarily RACT
for this category and that
the Board
is not bound
to promulgate regulations equivalent
to those
contemplated
in this document.
The Board must promulgate
rules
that,
based on the record,
represent PACT and are technically
feasible and economically reasonable pursuant to Section
27
of
the Act.
The issue of whether
ink solvents will be included
in
these PACT controls will be addressed further in Section
3,
below.
2.
Heatset Web Offset Lithography
—
Process
and Emission Sources
“Heatset”
refers to
a class
of web—offset lithography which
uses
a heated dryer
to solidify or set the printing inks by
driving
off excess solvents from a printed surface.
“Offset”,
as
used in
the lithographic printing industry,
refers
to the blanket
82—i83
—6—
cylinder which transfers
ink from the plate
to the surface
to be
printed.
“Web”
refers to the continuous roll—fed printed
substrate or paper.
Each printing unit of
a press has a series of vertically
arranged rollers and cylinders above and below the web.
These
roller/cylinder systems draw either water—based fountain solution
or solvent based
ink from wells.
Maintaining the distinction
between
image and non—image areas to
be printed
is done through
chemical means.
The non—image areas are receptive
to water,
or
fountain solution.
The image areas are water repellent and oil
or solvent receptive,
so that the ink stays on the image areas.
The fountain solution and the inks are transferred by complexly
arranged rollers to the plate cylinder.
The image
is then
transferred from the image plate
to
a
rubber covered blanket
cylinder and then
to the web.
The infeed section of the press
allows the rolls of paper
to be mounted, aligned, unwound and fed
through the press.
In
a typical process—color heatset web offset lithographic
printing press, each printing unit simultaneously applies
a
single color to both sides of the web.
Together all printing
units can overlay colors
for
a full color
image without drying
between printing units.
After
the printing web leaves the last
printing unit,
it enters the dryer,
The most common type
of
dryer
is
a high velocity,
hot air blower.
Air temperatures
can
be
as high as
500
F.
Much
of the heated air
is recirculated,
with only enough being discharged
to prevent
the buildup of
explosive solvent vapors.
The web leaves the dryer with surface
temperatures between
266 F and 329
F and travels over an assembly
of driven steel drums with chilled water circulating through them
which cool the web to
a maximum 86
F.
This cooling,
in
combination with the evaporation of the ink
in the dryers,
prevents the ink from transferring to adjacent sheets when the
printed web is
cut,
folded and stacked
(R.
667—668,
2713;
Ex,
29(e)).
There are
two types of materials,
fountain solutions and ink
solvents, used
in heatset web offset printing that result
in
organic emissions from the process.
The fountain solutions used
are typically composed of an etchant, such as phosphoric
acid,
gum arabic,
a dampening solution,
such as
isopropanol, and
water.
The etchant is often purchased
in
a premixed concentrate
that contains the etchant, gum arabic,
mineral salts and a very
small quantity of solvent.
These solvents are VOM
(P.
4044).
Isopropanol, which
is
a VOM,
is
a commonly used dampening
agent.
High print quality is often attributable to the level
of
isopropanol used.
Generally,
a higher
level of isopropanol
in
the fountain solution results
in better print quality.
Typical
isopropanol usage ranges from 15—25 percent of the fountain
solution.
Automatic dampening systems usually maintain
a 20
percent
level, while manual make—up systems range from 15—25
82—184
—7—
percent.
While alcohol substitutes are available,
these
substitutes are all VOM.
However, the alcohol substitutes are
generally less volatile than
isopropanol
(P.
4046;
P.C.
62).
The
feasibility of replacing isopropanol with lower volatility
substitutes
is limited and
a minimum
five percent isopropanol
is
necessary
for dampening systems using
older,
less flexible
rollers
(R. 666—671,
4001;
P.C.
62).
Ink solvents,
or ink oil,
are hydrocarbons comprised of
mixtures of narrow cut petroleum fractions having an average
molecular weight of about
206.
Cli
and C22 hydrocarbons have
been identified
in ink solvents an~ a commonly used solvent has
C12 and C16 hydrocarbons.
The composition of the hydrocarbons
could
include saturated alkanes,
unsaturated olefins and
aromatics.
The solvents boil within limited temperature
ranges.
Frequently,
the boiling
ranges identify the
ink
solvent.
For example, Magie
470 oil has a boiling
range of 462
F
to 516
F,
Most
ink formulations contain
35 to 43 percent,
by
weight, hydrocarbons
(R.
4030—4032,
4040).
Two major types
of
ink solvents are used
in heatset
inks.
One series
of solvents
is
a severely hydrotreated variety of the other.
Magie Sol 47
is
the hydrotreated version of
the Magie
470 oil.
Hydrotreatment
results
in converting
the unsaturated olefins
and aromatics into
saturated compounds.
The ink solvents used
in the heatset web offset industry do
not fall within the current regulatory definition
of VOM, as the
solvents have vapor pressures less than 0.0019 psia
at
70
F.
35
Ill.
Adm.
Code 211.121 and 215.104.
Neither
do they fall within
the regulatory definition
of “photochemically reactive material”
at 35 Ill.
Adm,
Code 211.122,
The heatset web offset industry
switched to these
ink solvent formulations
in order
to
be
exempted from the applicability of the existing generic organic
emission limitation of
8 lbs/hour
at
35
Ill. Adm. Code 215.301
(P.
3990),
Emissions from
the heatset web offset printing process
emanate from the printing unit
(i.e., the fountains and the
roller/cylinder
system)
and the dryer.
The terminated draft CTG
estimates that
50 percent of the fountain solution emissions
occur
in the pressroom from the press unit and
50 percent occur
in the dryer.
However,
the Agency believes that emissions from
the press
unit occur
in the range
of 0.8 to
25 percent, while 75
to 99.2 percent
of the emissions evolve off
of the web
in the
dryer
(Ex,
28(g)).
The emission factor
for fountain solution
VOMs
is 100 percent,
i.e., virtually
all VOMs
in the fountain
solution volatilize and are emitted
to the atmosphere
from both
the printing unit
(i.e.
pressroom emissions)
or the dryer
vent.
No
ink solvents are emitted
from the printing unit because
of their low volatility at standard temperature and pressure.
The vast majority of the ink solvent organic emissions that occur
82—185
—8—
evolve
in the dryer, which volatilizes
the ink solvents through
high heat.
These emissions are emitted
to the atmosphere via
a
stack from the dryer.
The Agency contends that all
of the ink
solvent emissions
that occur, occur
in the dryer
(P.
3957).
However,
a very small amount
of emissions may come off the web as
it exits
the dryer
and travels on the cooling rollers.
Some
secondary outgassing may occur
from an extremely hot web
(P.
3959).
Some portion of
the ink solvents
is retained on the
printed web,
or product,
and is never released
to the
atmosphere.
Emission factors for
the
ink solvents
are difficult
to
quantify.
The terminated
draft CTG estimates
that
20 percent of
the ink solvents remain
in the web,
or product,
which would
result
in an emission factor
of 80 percent.
P11 contends that
emission factors vary depending
on the type of product being
printed.
Product variables
that affect emissions
include:
the
relative absorbency
of different
types of paper, the ratio of
printed to unprinted surface,
the number
of colors used and the
thickness
of the printed
ink layer
(P.
4042),
These variables
can result in emission factors ranging from 50 percent to 80
percent
(R,
4041,
4043).
Results of
a long—term study conducted
by World Color Press,
Inc.,
involving
37
printing jobs using
a
wide variety of press configurations
and web paper,
found that
the web typically retains 19.96 percent
of the ink solvent
applied which corresponds
to an emission factor
of approximately
80 percent
(P.C.
84,
p.
13).
P11
in its emission survey used
an
average emission factor figure
of
70 percent
(P.C.
82).
Because
of the variability of products produced,
there
is variability in
the amount of emissions,
which are dependent
on
the absorbency
of
the paper and the amount
of ink applied.
Because
of the
variability
in emissions
it
is very difficult
to quantify the
emissions with precision.
The nature of the printing business
is
such that printers cannot control the type of product produced,
as
it
is done on a job—shop basis
(R.
4043, 4047),
Many heatset web offset dryer vents are controlled
in some
manner,
either by afterburners or
condensers.
These controls are
necessary,
in some circumstances,
because of opacity and odor
regulations.
Plumes
of condensed
ink solvent vapors can cause
opacity violations, absent
controls.
Odor controls are often
necessary
in urban areas.
Consequently, most
of the presses
located
in urbanized non—attainment areas have some form of
control device
(P.C.
82).
3.
Scope of Regulation
The main focus of controversy and disagreement
in this
proceeding has been whether or not the organic emissions from ink
solvents should
be regulated.
P11 contends that:
1)
these
emissions are de minimus
2)
the ink solvents are not VOMs as
defined
in current Board regulations;
3)
a large portion of the
82—186
—9—
dryer
vent emissions quickly condense and are therefore not
available
for gas—phase photochemical reactions
in the
atmosphere;
and 4)
the ink solvent emissions are not
photochemically reactive and should not be regulated.
The Agency
contends that:
1)
emissions are not
de minimus but are
approximately 2000 tons/year
in non—attainment areas and over
5500 tons/year
in attainment
areas;
2)
ink solvents are emitted
to the atmosphere by heat volatilization
in the dryer;
3)
the
results of the various studies
are inconclusive regarding
reactivity; and 4)
unless specifically excluded from regulation
by USEPA,
ink solvents should be regulated.
In support
of these
arguments,
P11 and the Agency have presented testimony and
exhibits regarding volatility,
condensation and reactivity of
ink
solvents and
ink solvent emissions.
P11 presented
the results of
a study conducted
by Battelle
Columbus Laboratories
(“Battelle Study”) concerning the
volatility and reactivity of commonly used
ink solvents
in
environmental chamber
irradiation experiments
(Exs.
22,
39,
101(b);
P.C.
54).
This project was contracted
for by the Graphic
Arts Technical Foundation,
a printing industry research
organization.
The first part evaluated the volatility
of heatset
printing ink solvents and the feasibility of conducting
tests
within smog chambers
to determine
their photochemical reactivity
(Ex.
22).
The second part evaluated
ink solvents reactivity
in
comparison with
the hydrocarbon ethane
(Ex.
39).
A third part
compared recondensed
ink solvents with “fresh” ink solvents in
order
to determine
if the printing and drying process alters
their composition in such
a way as
to increase or decrease
reactivity
(P.C.
54; Ex.
101(b)).
Additionally,
the third part
extended the work performed
in the previous two parts and
included experiments on the reactivity of isopropanol, Magie 500
oil and toluene
(P.C.
54;
Ex.
101(b)),
Task
1 of the Battelle Report investigated the volatility
of
heatset printing solvents
in order
to determine the portion that
would be available
for participation
in the gas—phase reactions
important
in the photochemical production of ozone.
Two
solvents, MagieSol
47 and Magie
470 oil, were used
in the
study.
Various methods of volatilization were used,
one method
being
found most appropriate.
Task
1 demonstrated
that
it was
technically feasible
to proceed and evaluate the relative
reactivity of different materials
under
ratios of hydrocarbons
to
nitrogen oxides known to lead
to ozone formation
(R. 755—758).
Task
1 also found
that the solvents were sufficiently volatile
that “virtually
all
of the oil constituents
are available to
participate
in gas—phase photochemical reactions”
(Ex.
22),
However, results from Task
1 do not rule out the possibility that
condensation can occur under certain conditions.
Condensation
is
experienced
in the field and is evidenced
by visual smoke
(Ex.
111(a)).
Condensation
is primarily
a function of concentration
of oils
in the stack and particulates
in the atmosphere that
82—187
—10—
provide
a locus
for condensation.
Stack gas temperature
and
atmospheric conditions also influence condensation.
Unfortunately,
the question of exactly how much of the solvent
is
available
for gas—phase reactions remains unanswered.
The Task
1
experiments do
not cover
this aspect adequately
to support
quantification
of how much ink solvent
is available in
a gaseous
state and how much condenses.
Task
1 also focused
on possible photochemical aerosol
formation during chamber
irradiations.
The formation of
a
photochemical aerosol would
indicate that
the test materials are
reactive and contribute
to the formation of ozone.
The
environmental chamber background air
contained
a high ratio of
hydrocarbons
to nitrogen oxides
(NOx).
After approximately two
hours of
irradiation,
a photochemical aerosol appeared during the
experiments with Magie 470 oil,
but did not with those conducted
with MagieSol
47.
The authors concluded
that this was due
to the
aromatic content
of the 470 oil, which was assumed to be 10
percent.
Based
on this assumption,
they calculated that
20
percent of the oil
is converted
to aerosol during the two hour
irradiation.
However,
in
a subsequent analysis of MagieSol
47
and Magie 470 oil using gas chromatograph/mass spectrometer
(GC/MS), ultra violet
(UV) absorption
and NMP techniques,
it was
found
that the
47 oil had no detectable
level
of aromatic and
that 470 oil contained,
at most, one percent aromatic
(Ex.
110),
In light of this new understanding of
the aromatic content
in these oils,
it must now be assumed
that all
of the aromatics
and some additional component
of the 470 oil
is photochemically
reactive.
Using the one percent aromatic content assumption and
carrying out a calculation similar
to the one performed in the
Battelle Study,
100 percent
of the aromatic and
a portion of the
aliphatic component of the 470 oil would be converted
to aerosol
through photochemical reactions.
There
are
a variety of parameters
that can be used
to
evaluate photochemical reactivity.
The Battelle Study identified
eight and chose one, maximum ozone concentration,
to be used as
the yardstick
for the Task
2.
One series of experiments was
conducted to compare
the reactivities of
the two ink oils
to that
of ethane.
In some experiments, concentrations were expressed on
a mass basis,
that
is parts per million as carbon, while
in
others molar concentrations were employed, that is parts per
million by volume.
In both cases,
the oils produced
a higher
ozone concentration than ethane within the first twelve hours
of
irradiation, although ethane eventually generated more ozone when
compared by mass.
It must be noted that the ratio
of hydro-
carbons
to nitrogen oxide was 5:1,
much higher than normally
found
in an urban mixture.
HC/NOx
ratios of 1.5
to 2.0 are
typical
in urban atmospheres.
In another series of
experiments,
ink solvents or ethane was
added
to
a typical atmospheric hydrocarbon mixture composed of
82—188
—11-
seventeen hydrocarbons.
Recalling that part
of the purpose of
the second part was
to compare
the oils’
reactivity
to ethane’s,
in approximately half of this series of experiments,
the oils
were substituted
in place of the ethane used in the other half.
When ethane was replaced by MagieSol 47,
the maximum ozone
concentration dropped
5 percent.
When
it was replaced with Magie
470 oil,
it dropped about 13 percent.
So
this series
demonstrated
that replacing ethane with either of
the ink oils
results
in a reduction
in the maximum concentration of ozone
formed
in the first twelve hours
(Ex.
39).
In response to comments by Dr. Basil Dimitriades of USEPA,
Research Triangle Park,
additional
studies were performed
to
gather data under conditions
that were more realistic
in terms
of
hydrocarbons
to NOx ratios that exist
in the atmosphere.
This
report, which contains the results of Task A and B,
also extended
the work
of Task
1 and
2.
This further investigation of
reactivity was also performed by Battelle.
This
report used the
data from the Task
2 Battelle Study
in the analysis.
Task A also
included experiments
on the reactivity of
isopropanol, Magie
500
oil and toluene.
Task B involved performing three experiments to
determine whether printing oils are modified by the printing
process in
a manner that would affect their photochemical
reactivity.
Task A experiments assumed
that synergistic and inhibitory
effects
in rnulticomponent mixtures can best be represented by
utilizing
a matrix of atmospheric organic compounds and that such
a procedure
is
a realistic method
for comparing the reactivity
of
a test compound such as
the heatset oils with
a reference
compound
(ethane).
Smog chamber experiments were carried out at
non—methane organic compounds/nitrogen oxides
(NMOC/NOx)
ratios
of 1.5,
2.8 and
5.
The authors concluded that the three repre-
sentative
ink oils, namely MagieSol
47,
470 and
500 “.,.are
generally no more reactive than an unreactive reference compound
(ethane).
One exception
is the
470 oil
at NMOC/NOx of 1,5, where
reactivity of the oil exceeds that of ethane”
(Ex,
101(b)).
Task
B experiments investigated whether
the heatset web
offset printing process alters the ink oil
in such
a way that the
oil’s reactivity would
be affected.
The experiments show that
the reactivity
of oil emitted from an actual press run was equal
to the reactivity
of the same oil which had not been exposed to
the printing process
(Ex.
101(b)).
The USEPA contracted with William P.L. Carter
to conduct a
computer modeling study of the photochemical reactivity
of
heatset printing oils
(Carter Report).
This study was carried
out at the Statewide Air Pollution Research Center
(SAPRC)
of the
University
of California
in Riverside
(Ex.
101(d)).
The purpose
of the Carter Report was
to use a mathematical modeling approach
to study the mechanistic aspects of heatset
ink oil reactivity
in
light of the data obtained from the Battelle experiments.
82—189
—12—
The study consisted of
two major
tasks.
The first was
to
simulate the results
of the Battelle chamber experiments based
on
current understanding of the chemical reaction
mechanisms
of the
higher alkanes and thus determine the most appropriate way to
represent the oils
in model simulations.
The second task
is
strongly dependent on the outcome of the first task.
In the
second task, box—type airshed model calculations were carried out
to assess the relative contributions to 03 formation from the
addition of heatset oils.
In carrying out the first
task,
a number of major
assumptions were involved.
First,
a choice of 0.6 ppb for the
chamber dependent proportionality factor was made.
The authors
indicate that this was a best
fit.
However,
a look at Table
2
shows
that the model calculated values for O~maximum are very
much lower
(about 40)
than the O~maximum obtained
experimentally
(Puns
2—16 and 2—fl.
Several
other chamber—
dependent parameters are assumed by the authors
to be appropriate
for simulating
the Battelle experiments.
Second,
a detailed
mechanism
for the NOx—air reactions of ethane, propane,
n—butane,
n—pentane,
iso—octane,
toluene, m—xylene and
their oxygenated
reaction products was assumed
to represent the reactions
of
ethane and the components
of the urban surrogate used
in the
Battelle experiments.
The authors have included comments
in
Table
1 on why such
a representation of the surrogate mix was
used.
A third
and more controversial assumption
is the
representation of the ink oils.
The authors used n—pentadecane,
which has a molecular weight close
to the average molecular
weight of the ink oils,
A probable set of reactions for this
compound are included,
In addition, m—xylene
(2—10)
was added
to the model
to represent the reactivity
of the oils and
to
better fit the data from the single oil component experiments
(Table 2),
The following discussion relates
to this last
assumption.
The aromatics
in the oils are represented by varying
the
amounts of m—xylene added
to the n—pentadecane.
It was believed
by the authors
that both Magie 470 and Magie 500 oils contain
approximately 10—12
aromatics,
However, as stated earlier and
presented
in Exhibit
110,
these oils may contain no more than 1
aromatics.
If this is really the case,
the use of m—xylene
to
represent the reactivity
is probably not appropriate.
Then the
addition of m—xylene would simply be an artifact
to raise
the 03
concentrations predicted
by the model.
The fact that maximum 03
concentrations obtained in the chamber experiments using the 47
and 470 oils are not too far apart does suggest
that the aromatic
content of the 470 oil
is not too large.
From the results of the
model simulations
of the urban surrogate—NOx experiment and the
urban surrogate with added ethane or printing oils
(shown in
Table
3,
Exhibit
101(d))
the author’s conclusion that the
representation of the printing oils as n—pentadecane plus
variable m—xylene
(2—5
for the 47 oil and 5—10
for the 470 oil)
82—190
—13—
is not justified
by
the data.
In particular
the m—xylene
percentage
(5)
that demarcates the 47 oil from the 470 oil
is
not clearly seen
in the data.
Thus the use of
this representa-
tion can at best be described as qualitative.
Quantitatively,
the model requires more refinement.
The second task
in the Carter Study deals with the assess-
ment
of the relative reactivities
of ethane and the mixtures
of
compounds thought
to represent
the printing oils.
This has been
done
by measuring
the change
in O-~ concentration caused
by the
addition of known small amounts
of the test compounds
(ethane,
mixtures representing the
printing oils
or the urban surrogate)
to
the assumed existing emissions.
Two Empirical Kinetic Model
Approach
(EKMA)
scenarios and two multi—day with stagnation
or
transport scenarios were used
for modeling the relative
reactivities.
Based on results
of the modeling,
the author
states
that:
“under
practically
all
conditions
except
the
highest
HC/NOx
ratios,
then
n—pentadecane,
5—
10
m—xylene
mixtures,
which,
based
on
the
chamber simulations,
is taken
to represent the
reactivity
of
the
two printing
oils
most ex-
tensively
studied
by
Battelle,
are
signifi-
cantly more reactive than ethane,”
Further, Carter notes that the
“mixture
(sic)
taken
to represent the printing
oils are
less
reactive than
the mixture taken
to
represent
emissions
from
other
sources
in
urban
areas,
indicating
that
these
oils
are
probably
less
reactive
relative
to
03
forma-
tion
than
most
pollutants
emitted
into
urban
areas.”
The authors conclude with
a discussion
of
some of the
weaknesses of their assumption of
a n—pentadecane and m—xylene
mixture to represent the ink oils,
Of note
is the statement that
such
a representation
is
“our best estimate of
a chemical model”
and that
it
is
“necessarily highly approximate, and
it contains
a
number of uncertainties.”
The reaction mechanism for n—penta—
decane
is based
on
an extension of models for C4—C9 alkanes
because limited data exist
for reaction mechanisms
for alkanes
with more than four carbons.
These points
in their conclusion
suggest
a need
to quantify the uncertainty wherever possible.
The
results do indicate that the reduction
in the aromatic
content of ink oils can reduce the reactivity
to that of ethane.
Another important result from the modeling study was the
effect of hydrocarbon to nitrogen oxide
(HC/NOx) ratios on
predicted daily maximum 03 concentrations.
The maximum increase
82—19 1
—14—
in O~above
that predicted
in the base case is seen to occur
at
the low to moderate HC/NOx ratios
(4
to
8).
However
the absolute
predicted 03 concentrations are lower
at the low HC/NOx ratios.
HC/NOx ratios
of 1.5
to 2.0 are typical
in urban atmos-
pheres.
The ratio
of concentrations
of ink oils
to NMOC
is also
expected to be low in the atmosphere.
Not having carried out
computer runs
at HC/NOx ratios
below
6,
the authors extrapolate
from the available data to state that the 03 production
is less
sensitive
to added organics
at low HC/NOx ratios
(i.e., below
6).
Thus,
evidence of any increase
in ozone production due to
ink solvents
is likely to
be obscured.
P11 contends that the quantity
of ink solvent emissions are
de minimus and should not be regulated as
a significant source of
ozone precursors.
This contention
is not supported by the
record.
As previously discussed,
the CAA provides
a legal
threshold
for regulation
of 100 tons/year for stationary
sources.
P11’s own survey on
isopropanol and ink solvent usage
in non—attainment areas shows that ink solvent emissions are
in
the area of 2000 tons/year from the industrial category with
approximately nine facilities emitting over 100 tons/year
of
isopropanol and ink solvents
(P.C.
82).
Ink solvent emissions
in
attainment areas are approximately 5500 tons/year.
The estimate
of
ink solvent emissions
is based on
a
70 percent emission
factor,
which is favored by P11.
The record indicates that
higher emission factors are appropriate
in some circumstances
(Ex.
29(e); P.C.
84).
Even with
this possibly low estimate,
there are major stationary
sources
in non—attainment areas,
thus
necessitating regulation purely based on quantity
of emissions.
P11 also argues that not all
of
these emissions are available
in
the gas—phase and that those that are available are non-
reactive.
However, assuming for the moment that ink solvent
emissions are appropriately subject to regulation as ozone
precursors, from
a pure quantity of emissions standpoint,
the ink
solvents are not de minimus.
P11’s second major
argument
is that
a large portion of
the
ink solvent emissions from the dryer condense from the gas—phase
back
to the liquid phase
and are,
consequently, not available for
photochernical reaction in the atmosphere.
The record shows that
condensation of
ink solvent emissions does occur
to some degree
in the industry.
Condensation can result
in visible plumes
of
smoke
(Ex.
23,
111(a)).
As a
consequence, many heatset web
offset presses are controlled either by afterburners
or
condensers
in order
to avoid violations
of the Board’s opacity
regulations
(R.
3989—3990,
4151;
P.C.
82),
However, industry
witnesses admit
that this condensation plume formation
is not an
automatic occurrence and 1tin many instances,
there are presses
in
different plants where
the concentrations that we are able
to
account for are not adequate to form
a condensate”
(P.
773).
Condensation
is dependent on the concentration of oil emissions
82—192
—15—
in the stack,
ambient temperature
and ambient particulates
in the
atmosphere, which provide a locus
for condensation.
Additionally, even when condensation does occur,
it
is unclear
what portion of the emissions remain
in the gaseous state.
Task
1
of
the Battelle Study demonstrated that
ink solvents volatilize
when subjected to heat and “virtually all of the oil constituents
are available to participate
in gas—phase photochemical
reactions”
(Ex.
22).
Task
1 left unanswered the question of how
much of the solvent emissions are available for ozone
formation.
One industry witnesses indicated that there are no
numbers
in existence quantifying
the
condensation phenomenon,
in
part because the quantity constantly changes depending on
production factors
and atmospheric
conditions
(P.
4121—4122).
In summation, while the record shows that the phenomenon or
condensation of
ink solvent emissions does occur
in some
circumstances,
there
is
little factual support for P11’s position
that
a significant portion of ink solvent emissions are not
available in
a gaseous state for photochemical
reaction.
By
P11’s own evidence condensation does not occur
automatically, the
quantitative aspect
of condensation is totally unknown and its
occurrence
is dependent on fluctuating meteorological and
emission conditions,
Based on this record,
the Board cannot
accept P11’s argument that
a significant portion of the emissions
are not
available for ozone formation.
The evidence before the
Board indicates
that under certain conditions,
all
of the ink
solvent emissions remain
in
a gaseous state and are available for
photochemical reaction
in the atmosphere
(Ex,
22).
P11 argues that ink solvents,
as presently constituted, are
not VOMs
as defined
in Board regulations
at
35 Ill. Adm. Code
211.122 and 215.104.
P11
is absolutely correct that heatset ink
solvents do not fall within the current regulatory definition of
VOM, which
is written
in terms
of volatility at
a specified
standard temperature
and pressure.
This argument might be
persuasive
if this was an adjudicatory proceeding construing
existing regulatory language.
See DuPage Publications v.
IEPA,
PCB 85—44, 85—70 and 85—130,
____
P.C.B.
____,
May
9,
1986;
P.C.B.
___,
August
14,
1986,
However,
the purpose of
the instant
proceeding
is
to first determine whether this industrial category
should be regulated,
and then,
if regulation
is necessary, what
level of control
is PACT.
The Board is at liberty in this
proceeding
to fashion regulatory language that will address the
issue of whether
or not ink solvents should
be
controlled.
In
response to this issue,
the Agency proposed
an amendment
to the
definition of VOM that would include ink oils,
Because of
potential impact beyond the scope of
the heatset web offset
industrial category,
this proposed amendment was separately
docketed as
a new regulatory proceeding,
P86—37.
Regardless of
the current definition of VON, the real issue
is whether the
ink solvents are emitted
to the atmosphere
in the
82—193
—16—
course of the heatset web offset printing process.
Regarding
this particular
issue, there
is little factual dispute that the
high temperature dryers, which
“set”
the inks, volatilizes
a
large portion of the
ink solvents.
These volatilized
solvents
are emitted through dryer stacks to the atmosphere.
While there
is variability
in the emission factors,
a reliable range is 70
to
80 percent
(P.C.
82,
84).
As previously discussed, some portion
of these emissions can condense under certain conditions but that
portion cannot be reliably quantified.
Thus,
regardless of the
current VOM definition most commonly used in PACT regulations,
organic emissions are volatilized
into the gaseous state and are
emitted
to the atmosphere
in significant quantities.
The Board
is not limited
to using the existing VOM definition
in the
context of these rules
and can certainly use the term “organic
materials”
if appropriate.
The undisputed facts show that
volatilized organic material emissions do result from the heatset
printing process.
P11’s final argument
is that the heatset
ink solvents are
not photochemically reactive and should not be regulated.
The
Agency contends that ink solvents are photochemically reactive
and that there
is an insufficient factual basis
for excluding
them from regulations as ozone precursors.
The Agency and USEPA
view the evidence generated on photochemical reactivity as
inconclusive,
At the outset of
this discussion,
it
is apparent
from the studies performed
to date that the relative
photochemical reactivity of heatset
ink solvents
is close to that
of ethane.
Ethane
is exempted from regulations as an ozone
precursor by both USEPA and the Board because it
is negligibly
photochemically reactive and, therefore,
not of regulatory
concern.
Whether
ink solvents are more or less reactive than
ethane
is uncertain.
Under certain environmental conditions,
ink
solvents are less reactive and,
under other conditions,
they are
more reactive
(Exs.
39,
101(b)).
Another point that is apparent
from a review of
the record
is
that both ethane and ink solvents
are photochemically reactive,
i.e.,
they generate ozone under
atmospheric conditions
(Ex.
22).
Very nearly all organic
compounds that are in the gas—phase react
in the atmosphere to
ultimately form ozone.
P11’s assertion that the ink solvents are
not photochemically reactive is clearly an overstatement.
For
regulatory purposes, organic compounds have been
categorized both in terms
of volatility and reactivity.
The
volatility classification is premised on the concept that only
organic materials that are volatile at standard temperature and
pressure enter the atmosphere as gases
and are, therefore,
available for photochemical reaction,
Of course, organic
materials can be volatilized through heat or pressure
in the
course
of an industrial process.
This aspect has already been
discussed as
it relates
to the heatset
ink solvents.
Organic
compounds have been classified
in terms of the rate at which they
photochemically
react.
Organic materials that react slowly over
82—194
—17—
time have been classified
as low reactive;
organic materials that
react more quickly
are classified as reactive.
Very few
materials are totally non—reactive or inert.
The choice of
ethane as
a benchmark for regulation is not
a purely scientific
or technical decision but
is,
in fact,
a regulatory decision
which is based on the best data available along with other
planning and policy considerations.
Ethane and certain other
selected materials are excluded from regulation because they
react
so slowly as
to have
a negligible impact on air quality.
The decision whether
or not to regulate ink solvents
is likewise
a regulatory decision which encompasses
a review of the available
scientific data,
the reliability and certainty of that data, an
analysis of the potential air quality impact of the emissions
and
the regulatory framework
for
regulation.
The issue can
be
distilled to
this:
Are the data presented sufficiently
conclusive
to support
a finding that heatset ink solvent
emissions have
a negligible
impact on air quality due to their
extremely low photochemical reactivity?
The P11
relies primarily on the results
of the Battelle
Study
in support of its position that ink solvents are non-
reactive
(Exs.
22,
39,
101(b)).
P11 argues that the Battelle
Study
is the only credible evidence
in the record on ink solvent
reactivity and that this evidence shows
that they are equivalent
to or
less
reactive than ethane.
P11
criticizes
the findings of
the Carter Report based on alleged errors
in certain key
assumptions
and methods.
The Agency maintains that ink oils
participate
in photochemical reactions in the atmosphere and
that, unless specifically excluded from regulation by
a final
rulemaking
action by USEPA,
they should
be controlled.
The
Agency and P11 agree that the USEPA
is undecided on the issue
of
whether
ink solvents are significantly photochemically reactive
and whether they should be excluded from regulation.
USEPA views
the current data as
“inconclusive.”
USEPA continues
to view ink
solvents as ozone precursors subject to regulation in the absence
of conclusive data.
No formal decision has been made on the
issue of whether or
not
to exclude them from regulation.
The results
of the Battelle Studies do provide some
of the
best evidence presently available on ink solvent reactivity under
certain conditions.
However,
the results and conclusions that
can properly
be drawn are limited.
Task
I
of the Battelle Study
shows that
ink oils can be volatilized with heat and will remain
in
a gaseous state.
Task
1 also demonstrates the ink solvents’
ability to photochemically
react,
i.e.,
formation of
a
photochemical aerosol after
irradiation.
Battelle Tasks
2,
A and
B
results show that under various simulated environmental
conditions,
ink
solvent reactivity varies in relation to
ethane.
Under most of
the simulated conditions,
the solvents
appeared less reactive than ethane.
Magie 470 oil
at NMOC/NOx of
1.5 was more reactive than ethane.
82—195
—18—
In reviewing the Battelle data,
the Board must consider the
reliability of the data and the conclusions drawn from that
data.
Statistically speaking,
there were relatively few
replicate samples from which
a comparison of the reactivities of
the solvents
to ethane could be made.
Except at the NMOC/NOx
ratio of
5,0 which had two runs each
for isopropanol and the ink
solvents and
four
runs for ethane,
there
is essentially just one
run f~oreach compound tested at the other NMOC/NOx ratios.
Conclusions drawn from such limited data should be viewed with
caution.
Additionally, certain of the test conditions were not
standard
throughout
the tests comparing ethane with ink
solvents.
At the NMOC/NOx ratio of
2.8, the
ratio of test
compound
(ethane)
to NMOC was 0.11 while all other experiments
were run at equal molar concentrations of
test compound and
surrogate urban mixture,
Because
of
this,
a
rather high value
(509 ppb)
occurs
for the maximum ozone obtained for
run A—2 with
ethane and the urban mix.
The tests using
ink solvents
(Run 2—8,
2—9, A—b)
resulted
in lower ozone values.
This comparison to
ethane
tends to make the solvents look as
if they are less
reactive.
In fact,
the test conditions were not comparable.
On
the other hand, when equal molar concentrations of ethane and
surrogate urban mixture are used,
at the same NMOC/NOx
ratio
of
2.8, the maximum 03 produced
is 378 ppb (Run A—l3).
If the ink
solvents had also been tested
under these conditions,
it
is
possible that they might have produced
a maximum 03 concentration
in excess of 378 ppb;
in which case,
the conclusion would have
been that the ink solvents were more reactive than ethane,
In
fact,
this latter conclusion is plausible based on the
observation that ethane reactivity decreases faster than that of
the ink oils for reductions in the NMOC/NOx ratio from 5.0
to
1.5.
The results of
the relative reactivity are presented in
figure
4 of the Summary Report Task A and B
(Ex,
101(b)).
Conclusions from this data regarding the reactivity of
ink
solvents are possible only
if the conditions of the experiment
are also stated.
The conditions
are necessary for reasonable
interpretation since the solvents are more reactive than ethane
under some conditions and
less reactive under
other conditions.
The only conclusion that can be drawn from the summary results
is
that the reactivities of
the solvents are not very different from
that of ethane under test conditions.
It also appears from the
data that
a reduction in the ratio of test compound to NMOC
increases the reactivity
of the
ink solvent test compounds with
respect
to ethane.
Since the actual concentrations of
the
heatset ink solvents
in the atmosphere
is low compared to the
urban mix,
the data suggests that the oils might be more reactive
than ethane and,
therefore, produce more ozone than ethane would
under likely environmental conditions.
In summary, there
is ambiguity in some of the Battelle Study
results and inherent limitations to drawing broad conclusions
82—196
—19—
from environmental chamber test results.
It
is not possible
to
exactly simulate actual ambient atmospheric conditions in
environmental chamber experiments.
The Battelle results show
that ink solvent reactivity
is dependent on the experimental
conditions.
Additionally,
it
is not practical to simulate,
in
environmental chamber studies, the full range of reaction
conditions which
occur
in the atmosphere,
and which affect the
relative reactivity
of the materials being compared.
The Carter Report was intended to help fill
in these
informational gaps through computer modeling based on Battelle
Study
data.
The Carter
Report,
first,
explored the chemical
reaction mechanisms
of the higher alkanes
in order
to accurately
represent the ink solvents
in model
simulation.
Second, Carter
conducted box—type air—shed model calculations
to assess the
relative contributions
to ozone formation.
Carter made
a number
of conservative assumptions regarding chamber—dependent para-
meters,
the mechanisms
for NOx to air reactions representing
the
Battelle ethane to urban surrogate reactions, and the
representation of the
ink solvents.
This last assumption
is
the
most controversial and, in light of subsequent data,
perhaps
erroneous
(Ex.
110).
The actual aromatic content
of
the test ink
solvents
is much lower
than presumed by either Carter
or
Battelle.
Thus,
in the case of the Carter
Report,
the choice
of
m—xylene
to
represent the reactivity
is probably not appropriate
and could artificially raise
the ozone concentrations predicted
by the model.
Only limited conclusions
can be drawn from the Battelle and
Carter reports.
The experimental data does not conclusively
settle the reactivity
issue.
The assumptions about
the reaction
mechanisms are flawed because of the current lack
of knowledge.
GC/MS analysis of sample
ink solvents
indicate extremely low
levels of aromatics,
much less than previously believed
(Ex.
110).
The Battelle Study concluded that the photochemical
reactions that did occur during chamber
irradiations were
attributable to the assumed 10 percent aromatics.
The findings
of
Ex.
110 undercut this conclusion,
Some component of
the ink
solvent,
other than the aromatics, must be reacting at rates
higher than previously attributed
to the higher alkanes.
The
assumptions
of
the Carter Report
ink solvent surrogate are also
undercut by
Ex,
110.
Part of the problem
is due to the fact that
ink solvents are not pure compounds,
but are comprised of various
components.
The exact composition of these complex solvent
formulations can vary from lot
to lot
(P.C.
84).
Additionally,
not much
is known about
the photochemical mechanisms of the
higher alkanes, above 010, which comprise
a large component of
the ink solvents,
Because of these informational uncertainties,
it
is difficult to draw conclusions with
a high level
of
confidence.
82—197
—20—
It
is necessary to review the regulatory strategy for
control
of ozone precursors in light of the uncertainty
surrounding
the composition and photochernical reactivity
of the
ink solvents,
Early
federal and state efforts
at ozone control
focused on controlling higher reactive organic materials and
allowed exemptions for low
(slow)
reacting organic materials.
This approach,
initially adopted
in California’s “Rule
66”, was
adopted by the Board and is now found
at
35 Ill. Adm. Code
211.122 (definition of
“photochemically reactive material”)
and
215.301.
USEPA regulations
in this area also allowed
for
a
control strategy of:
1)
reducing organic material emissions
generally;
and
2)
replacing highly reactive material with lesser
reactive material.
40 CFR Part
51 Appendix B.
Under this
regulatory scheme,
ink solvents are presently exempt from the
8
lbs/hour level of control under
215.301.
effort
at ozone control,
the
USEPA’s guidance
to the states
concept was useful
as an interim
considered a reduction
in emissions
for purposes of estimating attainment
of
the ambient air quality
standard for ozone.
USEPA severely reduced the category of
materials deemed not of regulatory concern due
to their extremely
low reactivity from what was previously excluded under the “Rule
66” strategy.
42 FR 35314
(July
8,
1977).
Only four materials
were excluded from regulation,
one of which
is ethane.
This
listing has been expanded
to include eleven compounds,
to date.
Illinois adopted this approach
in its definition of VOM,
which
excludes the eleven federally excluded compounds.
USEPA analysis of available data and information showed
that
very few VOMs are of such low photochemical reactivity that they
can be ignored
in ozone control programs.
USEPA found that many
VOMs that were previously designated as low reactivity materials
are now known to be moderately or highly
reactive in urban
atmospheres.
Second, even compounds that are presently known
to
have low reactivity can form appreciable amounts of ozone under
multi—day stagnation conditions as can occur
in summer,
42 FR
35314.
The Board
finds that the scientific data presented to date
is
inadequate
to justify exclusion of ink solvents from
regulation as ozone precursors.
While
the data presented does
show that ink solvent reactivity
is close to that of ethane,
it
is so only under certain conditions.
Additionally,
the data is
too limited
to draw broad conclusions on ink solvent reactivity
throughout
the spectrum
of atmospheric conditions.
This limited
data,
in combination with the present lack
of knowledge on the
photochemical behavior
of the
ink solvents,
cannot support
regulatory exclusion since
ink solvents are emitted to the
atmosphere
and they are photochemically reactive.
While
the
ink
solvents are generally slower
reacting,
their emission to the
Subsequent to this first
regulatory strategy changed.
indicated that the reactivity
measure only and would not be
82—198
—21—
atmosphere contributes
to the formation of atmospheric ozone and
is
of special concern during multi—day stagnation scenarios.
Under atmospheric conditions experienced
in Illinois and
southeast Wisconsin,
gaseous ink solvent emissions slowly react
to form ozone.
Under
the current regulatory strategy adopted by
Illinois,
it
is appropriate and necessary to control ink solvent
emissions.
Where the record before
the Board demonstrates that a source
category has substantial emissions
of hydrocarbons
to the
atmosphere and that those particular hydrocarbons are
photochemically reactive and will probably lead
to the formation
of ozone
under usual atmospheric conditions,
the Board
is
justified
in adopting technically feasible and economically
reasonable regulations
to control
those emissions.
The Board
finds
that during the heatset printing process,
ink solvents are
volatilized and emitted
to the atmosphere
in
a gaseous state and
in quantities that are of
regulatory concern.
While condensation
can occur,
it has not been shown
to significantly reduce the
gaseous emissions,
Data presented
to date shows
that ink
solvents are photochemically reactive.
Their rate
of reactivity
is close to that of ethane but varies depending on experimental
conditions.
It
is unclear how reactive
ink solvents are under
actual atmospheric conditions as the existing test data
is
limited
and little is known
about
the reaction mechanisms
of the
higher alkanes, which are principal components of
ink solvents,
Test data does indicate that greater
reactivity is exhibited
under conditions approaching probable atmospheric concentrations
of
ink solvents.
Because the data does not show that
ink
solvents are of such low reactivity to warrant exclusion based on
limited impact on air quality, especially during prolonged
irradiation under multi—day stagnation conditions,
the Board will
establish RACT controls for both fountain solutions and
ink
solvents.
4.
Geographic Applicability
When the first regulations controlling heatset web offset
printing were proposed as part of the PACT III regulatory
package,
they were intended
to apply
on
a statewide basis.
This
was consistent with the strategy undertaken
in the PACT
I
(P 79—
2,
3)
and PACT II
(P 80—5)
proceedings.
Several years ago, when
these proceedings were completed and PACT III was proposed, much
of the state was designated
as non—attainment.
When RACT
I was
initiated,
25 counties in Illinois were non—attainment for
ozone,
The rationale for statewide applicability was based on
the pervasive statewide ozone problem,
the atmospheric transport
of ozone
and ozone precursors from sources
in attainment areas to
non—attainment areas,
and
the need to provide for growth
in the
SIP
(P.
40—63).
At present, many areas of the state have
achieved attainment
for ozone and the major non—attainment areas,
with one exception,
are concentrated
in the Chicago and East St.
82—199
—22—
Louis major urbanized areas
(P.
3204—5).
Macoupin County
is not
located in
a major urbanized area but continues to experience
violations of the NAAQS for
ozone.
Recent regulatory proposals have focused on implementing
PACT
in the nine counties that comprise the Chicago and East St.
Louis major urbanized regions and Macoupin County.
Eight of
these counties are currently designated non—attainment for ozone.
Will
and McHenry counties are currently designated attainment for
ozone but are part of the Chicago urbanized area.
The SIP must,
in addition to imposing PACT
on major stationary sources
in non—
attainment areas, provide for ultimate attainment of the ozone
NAAQS,
To that end,
sources
in Will and McHenry still need
to be
RACT controlled
in order
to ensure adequate emission reductions
because of the transport of ozone and ozone precursors from these
geographically contiguous counties.
During
the course
of the various Agency, Board and P11
regulatory proposals for the heatset web offset category, no
participant has raised
the issue
of changing the geographic
applicability in light of the current SIP strategy.
Consequent—
ly,
the Board will
limit the geographic applicability of
RACT
controls
to the ten counties designated either non—attainment for
ozone or
that are
a part
of
the Chicago urbanized area.
The
Board
is cognizant that this action will greatly decrease the
economic impact of emission reduction contemplated
in previous
proposals.
World Color Press Inc. was identified
in the EcIS as
potentially bearing 62
of the
total statewide cost of
the
regulation at four
of its facilities located
in attainment areas
(Ex. 71).
These facilities will not be subject
to PACT
limitations that require the installation of add—on pollution
control equipment.
However,
the Board will require some level
of
control of fountain solution VOM on a statewide basis,
This
level of control will be something less than full PACT controls
but will nonetheless limit VOM emissions.
The rationale for requiring some level
of statewide control
is based on,
first,
the need
to maintain the current attainment
status throughout most of the state.
Approximately eight major
stationary
sources are located
in areas that are currently in
attainment
(excluding Will and McHenry counties which are
considered part
of the Chicago urbanized non—attainment area).
Total estimated organic emissions
from these facilities
range
from 2600 tons/year
to 5200 tons/year
(Ex.
71).
Many of these
facilities are extremely large sources
of organic emissions to
the atmosphere.
Second, emissions from these facilities,
although located
in attainment areas,
can contribute to ozone in
non—attainment areas through atmospheric transport
of ozone and
ozone precursors.
One facility, located
in Randolph County,
is
contiguous to the East St.
Louis major urbanized non—attainment
area.
Emission reductions on
a statewide basis will help reduce
the ambient ozone and ozone precursor concentration loadings that
can impact non—attainment areas.
82—200
—23—
5.
Content of Regulation
—
Level of Control
The PACT control options for heatset web offset printing
that can be prescribed
in
a regulation are summarized as
follows:
(1)
reduction of VOM
in the fountain solution through
reformulation;
(2)
installation and operation of
a thermal
or
catalytic incinerator
to control dryer
emissions; and
(3)
installation and operation of
a condenser/filter system that
selectively removes ink
solvents and other
low volatility
materials such as isopropanol substitutes,
but does not
effectively remove isopropanol.
Ink reformulation
is not
currently
a PACT option
(P.C.
62),
During
the course of this proceeding,
there have been
numerous regulatory proposals for the control
of the heatset web
offset printing process.
At least four separate proposals merit
discussion:
(1)
the Agency’s proposal which was analyzed in the
EcIS;
(2) the Board’s
first First Notice proposal of August 10,
1984;
(3)
the P11’s proposal
(P.C.
62);
and
(4)
the Board’s
second First Notice proposal
of May
30,
1985,
based on the
terminated draft CTG.
This proposal has been adopted, with
modifications,
by the Agency as
its current proposal
(Ex,
103),
Certain elements
of these various proposals are not technically
feasible or economically reasonable,
Many of these deficiencies
have been raised at hearing or
in public comments and will be
discussed further below.
The Agency’s proposal, which was analyzed
in the EcIS,
called
for statewide regulation of facilities emitting 100
tons/year
or more of
organic material.
Three control options
were prescribed:
(1)
installation and operation of an
afterburner which oxidizes 90 percent of the organic material;
or
(2)
the fountain solution contain no more than five percent of
volatile organic material and
a condensation recovery system
is
installed and operated that removes at least 75 percent of the
organic materials from the airstream;
or an alternative control
system equivalent to either
of the previous control options.
The
major problem with this rule is that a limitation of
five percent
VOM
in the fountain does not appear
to be technically feasible
for many heatset web offset presses.
The Board’s first First Notice rule proposed on August 10,
1984, applied statewide
to facilities whose emissions of VOM
exceeded 25 tons/year.
The rule required one of three options:
(1)
installation
of
an afterburner system which oxidizes
90
percent of captured non—methane VOM;
or
(2)
reduction of VOM
concentration in the fountain solution
to no more than five
percent and installation of
a condensation recovery system which
removes at least
75 percent of VOMs from the airstream or
reformulation of the ink
to
a high solid/low solvent;
or
(3) an
alternative control system demonstrated to have
an equivalent
82—201
—24—
emission reduction efficiency equal
to either
of the first two
options.
This proposal presented
a number of conceptual problems.
First,
the proposed rule attempted to regulate only VOM emissions
yet prescribed control
of
ink
solvents.
The various control
strategies were not equivalent.
Certain options were not
technically feasible,
such as the VON content
of the fountain
solution and the ink reformulation option.
The P11 proposal provided
for statewide regulation
at
a
40
tons/year VON threshold
(P.
4119).
Alternatively,
P11 requested
a
40
tons/year/press threshold
(P.C.
82),
No justification for
this level has been provided.
The P11
rule would require use
of
an afterburner which oxidizes
90 percent of the VON emissions
presented to the control equipment;
or
(2)
a VOM limitation of
8
percent
in the
fountain solution; or
(3)
an equivalent
alternative control system.
The main problems with this proposal
were
the exclusion of
ink
solvents from regulation and control
and the forty tons/year/press
threshold.
The Board’s second First Notice provided statewide
regulation
of sources emitting over 100 tons/year of VON.
The
proposal provided four alternative
control
strategies:
(1)
total
elimination of VOMs
in the fountain solution;
or
(2)
reduction of
VOM concentration in the fountain solution
to
12 percent and
installation and operation
of an incinerator;
or
(3)
reduction of
VOM concentrations in the fountain solution
to seven percent and
installation and operation
of
a condenser/filter system;
or
(4)
an alternative emission control
system equivalent to any
of the
first three options,
This proposal had
a number of problems
associated with
it.
First,
total elimination of VON
in the
fountain solution is not technically feasible,
nor
is
a
limitation
of seven percent.
Second,
the structure
of the
regulation favored the incineration control
option.
Third,
the
various levels of fountain solution VON which corresponded to and
triggered application
of add—on controls were arbitrary.
All of the regulatory proposals
to date have allowed an
unspecified alternative equivalent control strategy.
Preliminary
comments from USEPA indicate that such an option
is probably not
federally approvable
(R.
3898—3901;
Ex,
110).
As discussed in Section
1
of
this Opinion, while
the Board
is required to adopt PACT regulations controlling the heatset web
offset category,
the specified level of control
that
is PACT has
not been federally defined,
Thus,
the Board
is at liberty to
define a level of control that
is PACT, based
on the regulatory
record.
The regulatory controls must also be technically
feasible and economically reasonable
as
a matter of state law.
Reconciling what
is PACT and what is technically feasible and
economically reasonable
is possible, as the concept of PACT
82—202
—25—
incorporates elements of reasonableness,
cost effectiveness and
technical feasibility and availability of control options.
The Board adopts regulations
that
it believes meet these
federal
and state standards,
based on the regulatory
record.
The
threshold for regulation will
be 100
tons per year of
organic
material,
This threshold
is consistent with the CAA definition
of major stationary source.
This will include organic materials
that are considered volatile at standard temperatures and
pressures,
as well
as non—volatile organic materials, such
as the
ink solvents,
that are volatilized during the printing process.
As a first control alternative, Section 215.408(a)
(1) will
require installation and operation of an incinerator
that
oxidizes at least
90 percent of
the organic material present
in
the airstream from
the dryer.
This approach will control nearly
all
of the volatilized
ink solvent emissions.
A majority
of the
fountain solution VOMs will also be controlled through the use
of
an incinerator.
While the terminated draft CTG estimates
that
half
of the fountain solution VON emission occur
in the
pressroom,
the Agency has presented evidence that from 75
to 99,2
percent of the fountain solution VON emissions occur
in the dryer
(Ex.
28).
Thus,
even if higher levels
of VON are used under this
control option,
a large fraction of
the fountain solution VON
emissions will
be captured and controlled.
This option will
provide flexibility
in the printing process
to accommodate high
quality printing jobs while ensuring
a high level of
control.
Because the process involves
a high heat dryer that volatilizes
the vast majority of fountain solution and ink solvent emissions
directly into the dryer
vent,
no capture efficiency is needed or
specified.
The Board envisions
a situation where
the control
device
is directly connected to receive the dryer vent airstream,
thus obviating the need for
a capture device.
This will also
obviate the practical problems of specifying
a capture efficiency
for this particular application of
control technology.
The second alternative control option, Section 215.408(a)
(2), will include control of VON
in the fountain solution
to
eight percent and the installation and operation of
a
condenser/filter system that captures and removes at least 75
percent of the rion—isopropanol organic emissions from the dryer
airstrearn,
Condensation recovery systems can effectively remove
ink solvents and,
possibly,
low volatility isopropanol
substitutes, but will not effectively control
isopropanol.
Consequently,
it is necessary to reduce VOMs in the fountain
solution in order
to control their emission
to the atmosphere,
The record
indicates that fountain solution VOM can feasibly be
reduced
to eight percent without negatively impacting print
quality.
Once again,
no capture efficiency
is needed
or
specified for the condensation control system as
it
is envisioned
that dryer
vent emission will be directly routed
to the control
device.
A removal efficiency of
75 percent of non—isopropanol
82—203
—26—
organic emission from the dryer airstream appears reasonable as
nearly all
of the organic emissions will be ink solvents and,
therefore,
recoverable.
As
a separate control requirement, proposed Section
215.408(b) will provide an eight percent VOM limitation
for
fountain solution at facilities located outside the ten counties
designated either as non—attainment or part
of the Chicago
urbanized area.
This limitation
is technically feasible,
according to P11,
and will cost industry nothing.
The level
of
control required by Section 215,408(b)
is less stringent than
PACT and should
be easily met by the eight impacted facilities.
No unspecified alternative equivalent control option
is
provided as
it would probably not be federally approvable.
P11 has objected to most of the regulations proposed to date
as being economically unreasonable and technically infeasible.
First,
the Board believes
that the rules adopted today are
technically feasible.
Many concepts and levels of control
advocated by P11 have been incorporated in the rule such as
the
eight percent limitation on fountain solution VOM and the use
of
afterburners without
a specified capture efficiency,
Second,
regarding economic reasonableness,
the Board believes that the
rule provides flexibility
in the choice of control options either
through incinerators or
fountain solution reformulation and
a
condensation system.
Both these options are cost effective and
are compatible with existing industry controls
(P.
4124—4127),
Condensation recovery systems are identified as the most cost
effective control option because of the revenue derived from the
sale or combustion of
recovered solvent
(Ex.
71).
Reduction of
expensive isopropanol and other fountain solution VOM5 will
reduce costs
to printers.
The incineration option allows higher
VON fountain solution,
if needed for print quality,
but still
results
in effective
control.
Additionally, there are other
factors
that support
the economic reasonableness
of the rule
proposed today.
The levels of control specified
in the adopted rule are very
close to the Agency rule that was analyzed
in the EcIS.
The EcIS
found
that, even on a statewide basis,
the cost of controls
ranged from $808 to $1,738 per
ton,
which was
in a reasonable
cost effectiveness range.
Revised and updated cost estimates for
the incinerator control option were
$300 to $1,300.
Revised cost
estimates for the condenser/filter option were $170
to $450
(Ex,
107),
The rule will have
a much smaller economic impact than
that envisioned by the EcIS.
First,
the geographic applicability
of Section 215.408(a)
is limited
to ten counties which will
exclude the four World Color Press
Inc.
facilities from add—on
control requirements.
The EcIS found
that World Color Press Inc.
would bear 62 percent of
the statewide cost of control
as
a
result of add—on control costs.
Second,
the approximately nine
82—204
—27—
facilities and sixty—four presses that will
be controlled under
251.408(a)
are already controlled
by either incinerators or
condensers
(P.C.
82).
These controls are believed to be already
in place because
of smoke
and odor regulations.
The record
indicates that the control options are compatible with control
equipment now in
use.
This will further reduce the cost of
regulation from that estimated
in the EcIS as
initial purchase
and installation capital costs will not be incurred.
Calculating emissions and potential emission reductions
under the adopted rule involves
a number
of assumptions.
Because
of
the variability
in emission factors and the lack
of data on
current VON content of fountain solutions,
especially isopropanol
substitutes,
the emission and emission reduction figures are best
estimates,
As such,
the values are rounded off
to two
significant figures.
Based on data supplied by the P11
for major
stationary sources
in non—attainment areas,
it appears that
approximately 2400 tons/year of
ink oils are used at nine
facilities
that would be regulated under Section 215.408(a)
and
(b)
(P.C.
82).
Depending on the emission factor used,
this would
result in an emission range of
1,700 tons/year
(at 0.70 emission
factor)
to 1,900 tons/year
(at 0.80 emission factor),
P11 only
provided data on IPA usage at these nine facilities.
As noted
earlier,
there are other VOM constituents
in fountain solutions
other than isopropanol and, according
to P11 witnesses,
there
is
a trend in the industry towards replacing isopropanol with lower
volatility VOMs.
Consequently,
it
is necessary to estimate
fountain solution VON.
P11
estimated an emission distribution
ratio
for
the entire printing process
of 60:40
at current
fountain solution VON concentrations between
15—25 percent
(Ex.
24(k)).
In other words,
at present ink and isopropanol—based
fountain solution usage,
60 percent of the VON emissions are from
the fountain solution and 40 percent
of the VON emissions are
attributable
to the
ink solvents
(Ex,
24(k),
Ex.
71).
Based on
this ratio and
the ink solvent data,
the estimated fountain
solution VOMs
is 2,800 tons/year
at
a 0.80 emission factor
for
ink solvents,
Combining ink solvent and fountain solution VON
emissions results
in estimated total emissions from the nine
potentially regulated facilities
of 4700 tons/year.
Emission reductions under Section 215.408(a)(l),
the
incinerator option,
are estimated by multiplying the removal
efficiency
(RE)
by the quantity of emissions,
The RE for
fountain solutions is calculated by multiplying the fraction of
the fountain solution VOM presented to the incinerator by the
destruction efficiency of that incinerator.
Emission factor
estimates
for the fraction of fountain solution VON presented
to
the incinerator,
via the dryer, range
from 0.5
to
0,99.
Multiplying these figures by the 0.90 destruction efficiency of
the incinerator results
in a RE range
of 0.45
to 0.89.
Multiplying these PE5 by the estimated fountain solution VON
usage results in
a range
of emission reductions
of 1,300
tons/year to
3,500 tons/year.
82—205
—28—
The RE
for the
ink solvents
is calculated
by multiplying the
emission factor by
the destruction efficiency.
The RE for the
ink
solvents
is 0.72 at 0.80 emission factor.
Multiplying this
RE by the total
ink solvent usage results in an ink solvent
emission reduction
of 1,700 tons/year.
Combining
the reductions
in fountain solution VON and ink solvent emission results
in
a
range of potential emission
reductions from 3,000 tons/year to
4,200
tons/year.
Actual emission reductions would vary within
this range.
Emission reductions under Section 215,408(a)(2),
i.e.
the
fountain solution reformulation and condensation option, are
estimated somewhat differently
than for 2l5.408(a)(l).
Section
215.408(a)(2) calls
for
a reduction
in fountain solution VOM from
current usage levels
of
15
to 25 percent down to eight percent.
In this circumstance, emission reductions must be estimated
through the use of emission distribution ratios.
A reduction of
fountain solution VON from 25 percent to eight percent would
change the emission distribution ratio of fountain solution
to
ink solvents from 60:40
to 32:68,
A reduction of fountain
solution VOM from 15 percent
to eight percent would change the
emission distribution ratio of fountain solution
to ink solvents
from 60:40
to 44:56.
These
ratios can
be used
in combination
with known ink solvent usage to estimate the quantity of VOMs in
the fountain solution at an eight percent level.
While
it
is
impossible
to determine what level fountain solution VOMs are
actually presently being used,
a range of reductions can be
estimated.
A reduction from 25 percent to
8 percent VON in the
fountain solution would
result
in a
68
reduction
in VOM usage.
This corresponds
to
a 1,900
tons/year reduction in fountain
solution VON.
A reduction from 15 percent
to
8 percent VOM
in
the fountain solution would result
in
a 47
reduction
in VOM
usage.
This corresponds
to
a 1300 tons/year reduction
in
fountain solution VON.
Ink solvent emission reductions achievable through
the use
of a condenser/filter
are calculated
by multiplying the quantity
of emissions presented
to the control equipment by the RE,
The
RE
for the condenser/filter
is determined by multiplying the
emission factor of 0,80 by the capture and removal efficiency of
the condenser/filter, which
is
0.75.
The RE
is,
thus,
0.6.
The
RE
is then multiplied
by the total
ink solvent usage
at the nine
facilities of 2,400
tons/year.
This results
in 1,400 tons/year
of
ink solvent emission reductions
in the condenser/filter.
Total emission reductions under Section 2l5.608(a)(2), which
includes both fountain solution VOM reductions and reductions
from the condenser/filter
option, range from 2,700 tons/year to
3,300 tons/year.
There are eight facilities located
in attainment areas
(and
not considered part of the Chicago urbanized area) that would be
subject
to Section 215,408(b), the fountain solution VON
82—206
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limitation of eight percent.
Total organic emissions
(fountain
solution VON and ink solvents)
from these facilities range
from
2,700
to 5200 tons/year
(Ex.
71).
Assuming
the 60:40
distribution between fountain solution VON and
ink solvents when
traditional
fountain solution
is used results
in total fountain
solution VON emissions of 1500 to 3100
tons/year.
A reduction of
fountain solution VON from 25 percent
to eight percent results
in
removal of 1,100
to 2100 tons/year.
A reduction of
fountain
solution VOM from
15 percent
to eight percent results
in removal
of 750
to 1,500 tons/year.
While it
is impossible
to determine
the actual present fountain solution VON content,
these figures
provide
a reasonable estimated range
of reduction.
The estimates of potential organic material emission
reductions under
the two PACT alternatives, that involve the use
of add—on controls,
demonstrate that
the alternatives are roughly
comparable.
Because the actual emission reductions at any one
facility can only be estimated,
it is not possible
to demonstrate
exact equivalency either
in terms of reduced emission or cost.
However,
the potential emission reductions and costs
do appear
to
be
in
at
least
a
comparable
range.
Comments received from the Agency and USEPA during
first
notice raised two substantive issues.
First, the coinmentors
raised
a concern that Section 2l5,408(a)(l) which requires the
use of an incinerator
connected to the dryer stack, contains no
caps or upper
limit
on the percentage
of VON
in the fountain
solution.
The commentors recommended
a 12 percent cap be
imposed.
Second,
the commentors maintained
the cap for fountain
solution VON in Section 215.408(a)(2) should be seven percent
rather
than eight percent.
In the second notice Opinion,
dated
August
6,
1987,
the Board rejected the modification proposed by
the Agency and USEPA
as they were unsupported by the record.
A
more complete discussion of
the issues raised and rationale of
the Board’s disposition
is found
in the August
6,
1987,
Opinion
in this matter,
The
rule adopted today is substantively
unchanged from that proposed for
first notice on April
30,
1987.
No comments were received from P11 regarding the rule
during
the comment period.
The Board believes that the adopted rule represents
PACT,
Fountain solution VON
reduction through reformulation, as
required under
Section 2l5.408(a)(2)
and
(b) are essentially no
cost options and,
in
fact, will save printers money through
overall reduction in isopropanol
and isopropanol substitutes,
The eight percent limit
is considered technically feasible by the
P11.
The add—on control options required under either
215.408(a)
(1)
(afterburners)
or 2l5.408(a)(2)
(condenser/filter) are
clearly available control technology,
as the record indicates
that such controls are already in place at the regulated
facilities.
Costs
for the afterburner option have been estimated
in the range
of $300
—
$1300 per ton of VON removed.
Costs
for
a
82—207
—29—
limitation of eight percent.
Total organic emissions (fountain
solution VOM and
ink solvents)
from these facilities
range from
2,700
to 5200 tons/year
(Ex. 71).
Assuming the 60:40
distribution between fountain solution VOM and ink solvents when
traditional fountain solution is used results
in total
fountain
solution VOM emissions of 1500 to 3100 tons/year.
A reduction of
fountain solution VOM from 25 percent
to eight percent results
in
removal
of 1,100
to 2100 tons/year.
A reduction of fountain
solution VOM from 15 percent to eight percent results
in removal
of 750
to 1,500 tons/year.
While it
is impossible
to determine
the actual present fountain solution VON content,
these figures
provide
a reasonable estimated
range of reduction,
The estimates of potential organic material emission
reductions under
the two RACT alternatives, that involve the use
of add—on controls, demonstrate that the alternatives
are roughly
comparable.
Because the actual emission reductions at any one
facility can only be estimated,
it
is not possible
to demonstrate
exact equivalency either
in terms
of reduced emission
or cost.
However,
the potential emission reductions
and costs do appear to
be
in at least
a comparable range.
Comments received from the Agency and USEPA during first
notice raised
two substantive
issues,
First, the commenters
raised
a concern that Section 215.408(a)(l) which requires the
use of an incinerator connected
to the dryer
stack, contains no
caps or upper limit on the percentage of VOM
in the fountain
solution,
The commenters recommended
a 12 percent cap be
imposed.
Second, the commenters maintained
the cap for fountain
solution VOM
in Section 2l5.408(a)(2) should be seven percent
rather
than eight percent.
In the second notice Opinion, dated
August
6,
1987,
the Board rejected the modification proposed by
the Agency and USEPA as they were unsupported by the record,
A
more complete discussion of the issues raised and rationale
of
the Board’s disposition
is found
in the August
6,
1987, Opinion
in this matter.
The rule adopted today
is substantively
unchanged from that proposed for first notice on April
30,
1987,
and
for second notice on August
6,
1987.
No comments were
received from P11 regarding the rule during
the comment period.
The Board believes that the adopted rule represents PACT.
Fountain solution VON reduction through reformulation, as
required under Section 2l5,408(a)(2) and
(b)
are essentially no
cost options
and,
in fact, will save printers money through
overall reduction in isopropanol and isopropanol substitutes.
The eight percent limit
is considered technically feasible by the
P11.
The add—on control options required under either
215.408(a)
(1)
(afterburners)
or 215.408(a)(2)
(condenser/filter) are
clearly available control technology,
as the record indicates
that such controls are already in place at the regulated
facilities,
Costs for
the afterburner option have been estimated
in the range of $300
—
$1300 per
ton of VON removed.
Costs
for
a
82—208
—30—
condenser/filter are estimated
in the range of $170
—
$450 per
ton
of VON removed
(Ex.
107).
These costs are clearly within
a
reasonable range.
The potential emission reductions from today’s
adopted
rule are large when compared with many other PACT
industrial
categories.
The additional emission reductions that
will occur due to the attainment area fountain solution VON
reduction are justified by the record.
While
this level
of
control
is not as stringent as
the application
of PACT
in non—
attainment counties,
the emission reductions are achieved at
essentially no cost.
General background ambient BC
and ozone
levels will
be reduced,
This will
help maintain ozone attainment
throughout much of the state and also reduce the quantity of
ozone and ozone precursors available for atmospheric
transport
to
non—attainment areas.
At least one major
facility in Randolph
County
is contiguous
to the East
St. Louis Metropolitan ozone
non—attainment
region.
Cost effective controls in such
circumstances are,
therefore,
prudent and justified.
IT
IS SO ORDERED
Board Member J. Theodore Meyer concurred.
I, Dorothy
M, Gunn, Clerk of
the Illinois Pollution Control
Board, hereby certify
that
th
bove Opinion was adopted
on
the
/A*
day of _________________________,
1987,
by
a vote
of
‘~—o
Dorothy
M. dunn, Clerk
Illinois Pollution Control Board
82—209
