ILLINOIS POLLUTION CONTROL BOARD
November
25,
1987
IN THE MATTER OF:
PROPOSED AMENDMENTS TO PART
)
R86—40
211 AND 215, AIR OXIDATION
PROCESSES IN THE SYNTHETIC
)
ORGANIC CHEMICAL MANUFACTURING
INDUSTRY
ADOPTED RULE.
FINAL ORDER
OPINION AND ORDER OF THE BOARD:
(by J.D. Dumelle):
This matter comes before the Board upon
a September
23,
1986
proposal
for the adoption
of amendments
to 35
Iii. Adm.
Code
211
and 215 filed
on behalf of
the Illinois Environmental Protection
Agency (Agency).
The proposal was accepted and authorized
for
hearing by Board Order dated September
25,
1986.
Hearings were
held on February
24, 1987
in Springfield and March 10,
1987
in
Chicago.
The Agency filed
an amended proposal on November
30,
1987
and a second amended proposal on June
1,
1987.
The
Department
of Energy and Natural Resources
(DENR)
filed
a
negative declaration on June
22,
1987 and
the Board was informed
of concurrence
in that decision by the Economic and Technical
Advisory Committee
on June
26, 1987.
The overriding basis
of
this proceeding
is
to correct
deficiencies
in the Illinois State Implementation Plan
(SIP)
which have been identified
by the United States Environmental
Protection Agency (USEPA).
Section 172
of the Clean Air Act
requires the state
to impose the use of Reasonably Available
Control Technology
(RACT)
on existing sources
in non—attainment
areas.
On May 19,
1978,
the USEPA gave notice at
43
Fed.
Rey.
21673 that the SIP must include,
at least
for major
urban areas,
enforceable regulations reflecting
the application of RACT
to
those stationary
sources
for which USEPA has published control
techniques guidelines
(CTG5)
since 1978.
A final CTG for control
of emissions
from air oxidation processes
in
the synthetic
organic chemical manufacturing industry was published
in December
of 1984.
(See
Ex.
5).
Air oxidation processes are those which introduce
one
or
more oxygen atoms into a compound while removing hydrogen or
carbon atoms.
The reaction includes one or more chemicals with
oxygen supplied as air or
a combination
of air with ammonia or
halogens
as reactants.
Processes which use pure oxygen are not
included
in this category.
The processes used
to produce
air
oxidation chemicals vent large quantities
of
inert material
(predominantly nitrogen)
containing volatile organic material
(VOM)
to the atmosphere.
83—241
—2—
The heart of the Agency’s proposal
is contained in Sections
215.520 and 215.525.
The former section sets forth
the area of
geographic applicability of the rules.
The latter
section sets
forth the applicable emission limitations which,
in general,
require process vent streams
to be vented
to
a combustion device
that is designed and operated either
to reduce the VOM emissions
by at least 98
or
to emit less than
20 parts per million VOM.
These limitations only apply, however,
if the vent streams have
a
Total Resource Effectiveness
(TRE)
of less than 1.0
and the vent
streams are not controlled by an
existing combustion device.
Section 215.525
is patterned after the CTG,
including the
rather unusual mechanism of basing applicability upon the TRE.
The Agency stated that such
an approach
is
necessary,
at
least
in
part,
because
of
the large variation in reaction types used
to
produce oxidation chemicals,
a characteristic
of
this category.
Thirty—six chemicals
fall
within
this
category
——
these
are
produced
nationally
by
fifty—nine
companies
(in
non—
attainment
areas),
in differing amounts,
and
using
different techniques
of production
The TRE
index
is established
through
the use
of
a specific
formula as set forth
in Section
215.495(b)
of
the proposed regulations
and
corresponds to
a cost effectiveness of $1,600
per megagram of VOC destroyed.
(June
1,
1987
Statement of Reasons at 15—16).
ISSUES
The only issues which have arisen
in this proceeding regard
the geographic applicability of the rule, the types of vents
covered, whether methods for determining VOM content other
than
Reference Method
18 can be used, and
the scope of the grandfather
clause.
The Board adopted
a First Notice Opinion and Order on
July 16,
1987.
1.
Geographic Coverage
The question of geographic coverage
in this proceeding was
virtually
the same question raised
in R86—39 which was proposed
for first notice oN the same day.
Upon motion of Stepan Chemical
Company at the March 10,
1987 hearing,
the testimony of Mr.
Erwin
Kauper,
a certified consulting meteorologist, which was presented
at the April
24,
1987, hearing in R86—18 was incorporated
into
this record
in an apparent attempt
to demonstrate that Will
County emissions do not contribute
to ozone violations.
That
testimony appears at 1034—1106
of the April
24 hearing.
83—242
—3—
The Board examined this issue
in
the First Notice Opinion at
pages
2—5.
That discussion need not be repeated here.
The Board
added
the same exhibits referred
to as Exhibits
10 and
11
in R86—
39
into this proceeding
as Exhibits 15 and 16.
As
in R86—39,
the
Board concluded that these
rules would
be applicable
to the ten
counties proposed by the Agency.
2.
Vent
Coverage
Dan Muno of Stepan argued
that the Agency’s proposal
improperly extends the universe of vents covered under the
Agency’s proposal beyond those vents covered by the CTG
in that
the proposal covers all process vents while
the CTG covers only
the main reactor vent and not the distillation vents
or any other
vents associated with the process.
(R.
70—71).
The Agency
disagreed, contending that “the CTG exempts only ‘process vents
that result from the product purification of
a reactor bottom
stream.’”
(Agency Comments, April
15,
1987, at
2).
Further,
the
Agency believed that
it is appropriate
to include
reactor bottom
streams in this rulemaking, since the technology to control them
is reasonably available,
the method
for controlling these streams
is included
in the CTG, and the method
is sound.
(Agency
Comments
at
4).
As proposed
by the Agency,
the rules require controls on
streams only if the cost of control
is $1,600/Mg or less.
The
Agency contended that the TRE
is applicable
to all streams which
may be covered by the proposal, and the record fails
to contain
any evidence to the contrary.
The Board
found reason for the
failure of the CTG
to be made applicable
to these streams other
than the fact that these streams were to be covered under another
CTG which has not been published.
That fact does not lead
to the
conclusion that it would
be inappropriate
to cover
those streams
here.
The reason may simply be that USEPA has preconceived
functional groupings to be covered by various CTGs,
that reactor
bottom streams could
fall within two or more of those functional
groupings,
and that USEPA simply decided they fit better within
another category.
That does not mean that future controls will
be any more or less stringent than
if they had been covered under
this CTG,
or that coverage under these rules
is inappropriate.
Given
the absence of any showing
to the contrary and the
apparent applicability of the TRE to
all streams,
the Board
concluded that the Agency had reasonably included all streams in
its proposal.
The Board, therefore,
proposed
the Agency’s
language for first notice.
3.
Reference Method 18
In the rules
as proposed by the Agency, Appendix A,
Section
A.3(b)(2)(i)
redesignated
in the first notice proposal
as
Appendix
E, Section
(b)(2)(A)
requires the use of Reference
83—243
—4—
Method
18
to measure the concentration of all organics,
including
those containing halogens.
Dan Muno testified,
however,
that
“there should be provision for alternative
test methods because
Method 18 will not determine compounds that
(1)
are polymeric
(high molecular weight),
(2) can polymerize before analysis or
(3)
have very low vapor pressures at stack
or instrument
conditions.”
(R.
71—72).
The Agency’s response was simply that
“Method
18, specified
in the proposed
rule
is
a good method of
wide applicability.
However,
if any company would like
to
propose another test method
to use for any particular chemical,
the Agency would
be happy to look at any such proposals to
determine whether
it
(sic)
would be acceptable.”
(P.C.
No.
1 at
5).
As proposed by
the
Agency,
affected facilities would
be
required
to use a test method which admittedly is not useful
under
certain conditions.
The Board did not believe that should
be required,
and revised
the rule to require that Method 18 be
used unless one or more or the circumstances noted
by Mr. Muno is
present
in which case Reference Method 25(a) must be used.
The
Board believed that Method 25(a) would
be appropriate
in such
circumstances.
4.
Grandfather Clause
Under Section 215.525(b)
a
facility otherwise required to
meet the limitations of Section 215.525(a)
need not meet those
limitations
if
it has
an existing combustion device until
that
device is
“replaced for other
reasons.”
The Agency stated its position as
follows:
The
Agency
believes
that
what
constitutes
“replacement
of
the
combustion
device”
will
probably need
to
be determined
on
a
case
by
case
basis.
Certainly,
the
Agency
believes
that
if replacement of the catalyst
is only
a
small
fraction
of
the
cost
of
replacing
the
incinerator,
then
IEPA’s
interpretation
of
the proposed
rule would not require a company
to
comply
with
the
emissions
limitation
of
the
rule
at
that
point.
Similarly,
it
is
IEPA.’s
interpretation
of
the
proposed
rule
that
if
the
cost
of
replacing
the
catalyst
is,
for
example,
over
half
of
the cost of
a
new
incinerator,
the
company
would
be
required
to
upgrade
its
incinerator
and come
into
compliance
when
it
replaced
a
catalyst.
(P.C.
No.
1 at 5).
83—244
—5—
Stepan, however, requested that language be added
to the
rule to clarify that catalyst replacement would not constitute
replacement of the device “for other reasons.”
Stepan’s view
appeared
to be
in general accord with the intent of the
grandfather clause and the Agency’s proposed language.
The
intent of
the provision appears
to be
to allow facilities which
have made
a relatively recent investment
in
a combustion control
device
to avoid having
to replace that device during
its useful
life.
The Board does not believe,
in general, that the
replacement of
a catalyst should be equated with the replacement
of
the device: replacement of
a catalyst
is more in the realm of
operation and maintenance.
On the other
hand,
it makes
little
sense to allow a device
to continue
to be grandfathered
if
a new
compliant device would cost little more than the replacement of
the catalyst in
a non—compliant device.
The Agency did not believe that “replacement” needed
to be
further defined.
However, the Agency suggested
the following
additional language as acceptable
if the Board were to determine
clarification to be necessary:
The
combustion
device
is
considered
to
be
replaced when
all of
the device
is
replaced,
or
when
the
cost
of
replacement
of
part
of
the device
equals
50
or more
of the cost of
replacing the entire device.
(Agency Response at 4).
The Board believed that clarification was appropriate.
The
concept
of replacement for the other reasons
is vague, and
to
the
extent
it can be clarified,
it should
be.
The Board,
therefore,
added language generally in line with the Agency’s suggestion
except that
it added the concept that significant repairs can be
considered as replacement and further
clarified
that the 50
provision
is based upon the relationship of the cost of
replacement and
the cost of
a compliant device rather than the
cost of replacement and the cost of
a grandfathered device as
Stepan appears
to assume.
FIRST NOTICE HISTORY
On July 16,
1987,
the Board proposed these amendments
to 35
Ill. Mm. Code 211 and 215 for First Notice.
On August
16,
1987,
the Board adopted an order
(1)
changing the section numbers
proposed
in the July 16 Order
to correspond to
the Subpart V
designation and
(2) noting that the definition proposed for
“volatile organic material” is the subject of
a concurrent Board
proceeding,
R86—37, and appeared
in the first notice order
for
purposes of
notice only.
The proposed amendments were published
at
11 Ill.
Reg.
13173 and 13293
on August 14,
1987.
r2he
statutory 45—day comment period ended
on September
28,
1987.
83—245
—6—
Non—substantive comments were received from the Secretary of
State’s Administrative Code Unit regarding form and format of the
proposed rules.
Those changes have been made at second notice.
The only comment received during the 45-day comment period was
from the Stepan Company.
The Illinois Environmental Protection
Agency (Agency)
had previously filed comments on April
15,
1987.
1.
Vent
Coverage
Stepan’s comments expressed
its continued concern that the
regulations as proposed improperly expand the coverage over that
assumed
in the Control Techniques Guidelines
(CTG).
In
particular,
Stepan requested that the
Board reconsider the
comments submitted on June 18,
1987 regarding
the
definition of
process vent stream.
Stepan also argued that the definition
is
unclear and subject to
a wide variation of interpretation by
Agency personnel.
Finally,
Stepan argued that the definition
should exclude storage tanks and material handling equipment.
The Board was not persuaded to alter the definition of
process vent stream.
The Board believed that the language of the
definition
is sufficiently clear
for
the Agency and the regulated
community to determine what types of emission streams are
covered.
Further,
the Board continued to believe that the scope,
i.e. the inclusion of all streams,
is reasonable.
2.
Reference
Method
18
In response
to Board request, Stepan commented that the
Total Resource Effectiveness
Index
(TRE)
in Appendix
E of Part
215 does not take into account the costs associated with
sampling.
Stepan suggested
that language be added
to provide
a
flexible alternative for facilities.
Stepan offered the
following language:
2)
D)
A method
using engineering techniques
demonstrated
by
the
applicant
to
he
equivalent
to
Reference
Methods
and
approved by the Agency.
The Board was not persuaded to amend Appendix
E as
suggested.
First,
the language proposed by Stepan
is
imprecise.
The record was insufficient for
the Board
to
adequately consider
Stepan’s proposed language.
Second, although
the Board did not believe
that affected facilities should
be
required
to use
a test method which is not useful
under certain
circumstances,
the Board did not believe
that the record
supported the inclusion of such an alternative as
a general
rule.
The Board noted that facilities unable or unwilling to use
the test methods provided can petition for relief.
83—246
—7—
3.
VON Definition
The Board noted in its August
6,
1987 Order that the
definition of volatile organic material was the subject
of
a
concurrent
Board proceeding, R86—37, and that the definition
was
included
in the R86—40 proposal
for purposes of providing
notice.
As R86—37 was devoted entirely to the amendment of
that
definition,
the Board deemed
it appropriate
to
remove the
definition from further consideration
in this proceeding.
The
definition of volatile organic material was, therefore, not
included
in the second notice order.
4.
Incorporations By Reference
Within the
text of the proposed amendments certain materials
were incorporated by reference.
Language was added
to indicate
that these materials are incorporated by reference
in Section
215.105.
In addition, materials not previously incorporated
and
appearing
in Section 215.105 have been added
to that section
pursuant to Section 6.02(a)
of
the Illinois Administrative
Procedure Act and
1
Ill. Mm. Code
220.760.
These are not
substantive changes, but are necessary for second notice review
by the Joint Committee on Administrative Rules
(JCAR).
The proposed text also utilized certain abbreviations.
Those abbreviations have been added
to the list
in Section
215.103.
5.
Definitions
In the first notice order, several definitions were proposed
to be
added
to Section 211.122.
Most of the proposed definitions
(“Flow”,
“Full
Operating Flowrate”,
“Hourly Emissions”,
“Net
Heating Value”,
and “Process Vent Stream”)
included the language
“For
the purposes of Part 215, Subpart V.”
So
as not
to
unnecessarily burden the general definitions section,
Section
211.122,
the Board
created
a definition section within Subpart V
and moved
all the definitions thereto.
The definitions are now
located
in proposed Section 215.521.
Finally,
the Board noted that it made other non—substantive
changes throughout
the text of the proposed amendments.
The
equations
in Appendix
E were rewritten
for ease
in typing
and
reproduction.
Also,
the
tables
in Appendix
F were reformatted.
SECOND NOTICE CHANGES
On October 15,
1987,
the Board
adopted an opinion and order
sending the proposed amendments to Second Notice
for review by
the Joint Committee on Administrative Rules
(JCAR).
The Second
Notice period commenced on October 22,
1987.
The JCAR staff
suggested several non—substantive changes,
all of which have been
83—247
—8—
incorporated at final notice.
At its November
29,
1987 meeting,
JCAR formally objected
to the amendments
to Part 215 insofar
as
the regulatory flexibility analysis
is concerned.
The JCAR
objection was based
on its belief that “not applicable” was an
inappropriate response
to the regulatory flexibility analysis
question.
The Board, by Resolution also adopted today, has declined to
modify the rulemaking
so
as to comply with the JCAR objection.
Although “not applicable” may not be
an appropriate response, the
Board believes that the response will have no adverse effect and,
further, that final
action must be taken
to comply with deadlines
imposed by the Clean Air Act
(42 U.S.C.
7401 et seq.).
Notice
of
the refusal
to modify will be submitted
to JCAR and
to the
Secretary of
State
for publication
in the Illinois Register.
All
of the non—substantive changes recommended by JCPIR have
been adopted at Final Notice.
Specific changes are as follows:
Section
215.105:
The amendments to this Section proposed at
Second Notice have been deleted because, according
to JCAR,
amendment at Section Notice
to
a section not proposed at First
Notice
is not consistent with the Illinois Administrative
Procedures Act.
JCAR suggested making the revisions to Section
215.105
as part of the Board’s proceeding docketed P86—10:
Organic Material Emission Standards and Limitations
for
Pharmaceutical Manufacturing Plants.
The Board will make the
necessary changes
in
the
P86—10
proceeding.
Section
215.525:
In subsection
(b), the language “which shall
include but not be limited to,
normal maintenance, malfunction,
accident,
and obsolescence” was added after “other
reasons.”
Section
215.526:
In subsection
(a), the language “during
the
permitting process” was
added
after
“upon request by the
Agency.”
Also,
a sentence was added
to subsection
(a)
clarifying
that this section does not limit
(JSEPA’s authority.
Appendix E:
The language “the recommended
PACT”, was replaced
with “Sections 215.520 through 215.527.”
Also, where reference
methods are specified,
the language “as appropriate” was deleted.
ORDER
The Clerk
of the Pollution Control Board
is hereby directed
to submit the following adopted amendments
to 35 Ill.
Adm. Code
215
to the Secretary of state
for Final Notice:
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER c:
EMISSIONS STANDARDS AND LIMITATIONS FOR
83—248
—9—
STATIONARY SOURCES
PART
215
ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS
SUBPART A:
GENERAL PROVISIONS
Introduction
Clean—up and Disposal Operations
Testing Methods
Abbreviations and Conversion
Factors
Definitions
Incorporations by Reference
Afterburners
Determination of Applicability
Section 215.103
Abbreviations and Conversion Factors
barrels
(42 gal)
degrees Celsius or centigrade
cubic inches
degrees Fahrenheit
foot
gram
grams per mole
gallon
hour
inch
degrees Kelvin
kilocalorie
kilogram
kilograms per hour
kilopascals;
one thousand newtons per
Section
215.100
215.101
215. 102
215.103
215.104
215.105
215.106
215.107
a)
The
following abbreviations are used
in this Part:
bbl
C
Cu
lfl
F
ft
I
g/mole
gal
hr
in
K
kcal
kg
kg/hr
kPa
square meter
1
lb
lbs/hr
lbs/gal
m
Mg
mm
MJ
mm Hg
ml
ppm
ppmv
psi
psia
liter
pound
pounds per hour
pounds per gallon
meter
Megagram, metric ton or tonne
minute
megajoules
millimeters of mercury
milliliter
parts per million
parts per million by volume
pounds per
square
inch
pounds per square inch absolute
83—249
—10—
psig
pounds per square inch gauge
____
standard cubic meters
English ton
(Source:
Amended
at
Ill.
Req
________
effective
____________)
SUBPART
V:
AIR
OXIDATION
PROCESSES
Section
215.520
215. 521
215.525
215.526
215.527
Appendix
E
Appendix F
Applicability
Definitions
Emission
Limitations
for
Air
Oxidation
Processes
Testing and Monitoring
Compliance
Date
Reference Methods and Procedures
Coefficients
for
the
Total
Resource
Effectiveness
Section 215.520
Applicability
This Subpart applies to plants using
air oxidation processes
which
are
located
in
any
of the following counties:
Will,
McHenry,
Cook, DuPage, Lake,
Kane, Madison, St. Clair,
Macoupin
and
Monroe.
(Source:
Added at
Ill.
Peg.
________
effective
___________
Section
215.521
Definitions
In addition
to the definitions of
35 Ill.
Adm. Code 211, the
following definitions apply
to this
Subpart:
“Air Oxidation Process”:
any unit process including
ammoxidation and oxychiorination which uses air or
a
combination of air and oxygen as an oxidant
in
combination
with
one
or
more
organic
reactants
to
Rroduce one or more organic compounds.
“Cost Effectiveness”:
the annual expense for cost of
control_of_a
given
process
stream
divided
by
the
reduction
in
emissions
of
organic
material
of
that
stream.
“Flow
(F)”:
Vent stream flowrate (scm/mm)
at
a
standard
temperature of
20
C.
“Full Operating Flowrate”:
Maximum operating capacity
of the facility.
scm
T
83—250
—11—
“Hourly Emissions
(E)”:
Hourly emissions reported
in
kg/hr measured
at
full operating
flowrate.
“Net Heating
Value
(H)”:
Vent stream net heating value
(MJ/scm)
,
where
the net enthalpy per mole of offgas
is
based on combustion at 25
C
and 760 mm Hg,
but the
standard
temperature
for
determining
the
volume
corresponding
to one mole
is
20
C,
as in the definition
of “Flow.”
“Process Vent Stream”:
An emission stream resulting
from
an air oxidation process.
“Total
Resource
Effectiveness
Index
(TRE)”:
Cost
effectiveness
in
dollars
per
megagram
of
controlling any
gaseous
stream
vented
to
the
atmosphere
from
an
air
oxidation
process
divided
by
$1600/Mg,
using
the
criteria
and
methods
set
forth
in this Subpart and
Appendices
E
and
F.
(Source:
Added
at
Ill.
Peg.
________,
effective
___________
Section
215.525
Emission
Limitations
for
Air
Oxidation
Processes
a)
No
person
shall
cause
or
allow
the
emission of volatile
organic
material
(VON)
from any process vent stream
unless
the
process vent stream
is vented
to
a
combustion
device which
is designed and operated either:
1)
To
reduce
the volatile organic emissions vented
to
it with
an efficiency of at least ninety eight
percent
(98)
by
weight;
or
2)
To
emit
volatile
organic
material
at
a
concentration less than twenty parts per million by
volume,
dry basis.
b)
Air oxidation facilities
for which an existing
combustion device
is employed
to control process VON
emissions are not required
to meet the
98 percent
emissions limit until
the combustion device
is replaced
for other reasons, which shall
be considered
to
include,
but not be limited to, normal maintenance, malfunction,
accident,
and
obsolescence.
The
combustion
device
is
considered
to
be
replaced when:
1)
All
of
the
device
is
replaced;
or
2)
When
the
cost of
the
repair
of
the
device
or
the
cost of replacement of part of the device exceeds
83—25 1
—12—
50
of the cost of replacing
the entire device with
a device which complies.
c)
The
limitations
of
subsection
(a)
do
not
apply
to
any
process vent stream or combination of process vent
streams which has
a Total Resource Effectiveness index
(TRE)
greater
than 1.0,
as determined by the following
methods:
1)
If an
air
oxidation
process
has
more than one
process vent stream, TRE shall
be based upon
a
combination of the process vent
streams.
2)
TRE of
a process vent stream shall
be determined
according
to the following equation:
TRE
=
E~a
+
bF’~
+
cF +dFH
+
e(FH)n
+
fF0•51
where:
n
=
0.88
TRE
=
Total
resource
effectiveness
index.
F
=
Vent
stream
flowrate
(scm/mm),
at
a
standard
temperature
of
20
C.
E
=
Hourly
measured
emissions
in
kg/hr.
H
=
Net
heating
value
of
the
vent stream
(MJ/scm),
where
the
net
enthalpy
per
mole
of
offgas
is based
on
combustion
at
25
C
and
760
mm
Hg,
but the standard temperature for
determining the volume corresponding
to one mole
is
20
C, as
in the
definition
of
“Flow”.
a,b,c,d,
e
and
f
=
Coefficients
obtained
by
use
of
~ppendix
F.
3)
For
nonchlorinated
process vent streams,
if
the
net
heating value,
H,
is
greater
than
3.6
MJ/scm,
F
shall
be
replaced
by
F’
for
purposes
of
calculating
TRE.
F’
is
computed
as
follows:
F’
=
FH
/
3.6
where
F
and
H
are
as
defined
in
subsection
(c)(2).
4)
The
actual
numerical
values
used
in
the
equation
described
in
subsection
(c)(2)
shall
be
determined
as
follows:
83—252
—13—
A)
All reference methods and procedures
for
determining
the
flow,
(F), hourly emissions,
(E), and net heating,
(H), value shall
be
in
accordance
with
Appendix
E.
B)
All
coefficients
described
in
subsection
(c)(2)
shall
be
in
accordance with Appendix
F.
(Source:
Added
at
Ill.
Peg.
_______,
effective
__________
Section
215.526
Testing and Monitoring
a)
Upon
request
by
the
Agency
during
the
permitting
process
under
Section 39
of
the
Act,
the
owner
or
operator of
an
air oxidation process shall demonstrate compliance with
this Subpart by use of the methods specified
in Appendix
E.
This Section does not limit the USEPA’s authority,
under
the Clear
Air Act,
to
require demonstrations of
compliance.
b)
A person planning to conduct
a volatile
organic
material
emissions test to demonstrate compliance with this
Subpart shall
notify the Agency of that intent not less
than 30 days before the planned initiation of the tests
so that the Agency may observe the test.
(Source:
Added
at
Ill. Peg.
________,
effective
___________)
Section 215.527
Compliance Date
Each
owner
or
operator
of
an
emission
source
subject
to
this
Subpart
shall
comply
with
the standards and limitations of this
Subpart
by
December
31,
1987.
(Source:
Added
at
Ill.
Peg.
_______,
effective
__________)
Appendix E Reference Methods and Procedures
Introduction
This
Appendix presents the reference methods and procedures
required
for implementing Reasonably Available Control Technology
(PACT).
Methods and procedures are
identified
for two types
of
ACT implementation:
a)
Determination
of
VOC
destruction
efficiency
for
evaluating
compliance
with
the
98
weight
percent
VOC
reduction
or
20
ppmv
emission
limit
specified
in
Sections 215.520 through 215.527; and
83—253
—14—
b)
Determination of offgas flowrate, hourly emissions and
stream net heating value
for calculating TRE.
All
reference
methods
identified
in
this
Appendix
refer
to
the
reference
methods
specified
at
40
CFR
60,
Appendix
A,
incorporated
by
reference
in
Section
215.105
VOC
DESTRUCTION
EFFICIENCY
DETERMINATION
The
following
reference
methods
and
procedures
are
required
for
determining compliance with the percent destruction efficiency
specified
in Sections 215.520 through 215.527.
a)
Reference Method
1 or lA
for selection of the sampling
site.
The control device inlet sampling site for
determination
of
vent
stream
molar
composition
or
total
organic compound destruction efficiency shall
be prior
to
the
inlet
of
any
control
device
and
after
all
recovery devices.
b)
Reference
Methods
2,
2A,
2C
or
2D
for
determination
of
the
volumetric
flowrate.
c)
Reference Method
3 to measure oxygen concentration of
the
air
dilution
correction.
The
emission
sample
shall
be
corrected
to
3
percent
oxygen.
d)
Reference Method
18
to
determine
the
concentration
of
total organic compounds
(minus methane and ethane)
in
the control device outlet and total organic compound
reduction efficiency of the control device.
TRE DETERMINATION
The following reference methods and procedures are required for
determining
the offgas flowrate, hourly emissions, and the net
heating
value of the gas combusted to calculate the vent stream
TRE.
a.)
Reference Method
1
or lA for selection of the sampling
site.
The
sampling
site
for
the
vent
stream
flowrate
and molar composition determination prescribed
in
(b)
and
(c)
shall
be prior
to the inlet of any combustion
device, prior
to any post—reactor dilution of the stream
with air
and prior to any post—reactor introduction of
halogenated
compounds
into
the vent stream.
Subject
to
the
preceding
restrictions
on
the
sampling
site,
it
shall
be
after
the
final
recovery
device.
If
any
gas
stream
other
than the air oxidation vent stream
is
normally
conducted
through the recovery system of the
affected
facility,
such
stream
shall
be
rerouted
or
83—
254
—15—
turned off while the vent stream
is sampled, but shall
be
routed
normally
prior
to
the
measuring
of
the
initial
value
of
the
monitored
parameters
for
determining
compliance with the recommended
PACT.
If
the
air
oxidation vent stream
is normally routed through any
equipment which
is not
a part of the
air oxidation
process as defined
in 35 Ill. Adm.
Code 211.122,
such
equipment shall
be bypassed by the vent stream while the
vent
stream
is
sampled,
but
shall
not
be
bypassed
during
the
measurement
of
the
initial value of the monitored
parameters
for
determining compliance with Subpart V.
b)
The
molar
composition
of
the
vent
stream
shall
be
determined
using
the
following
methods:
1)
Reference
Method
18
to
measure
the
concentration
of
all
organics,
including
those
containing
halogens,
unless
a
significant
portion
of
the
compounds
of
interest
are
polymeric
(high
molecular
weight),
can
polymerize
before
analysis
or
have
low
vapor
pressures,
in
which
case
Reference
Method
25(a)
shall
be
used.
2)
ASTM
Dl946—67
(reapproved
1977),
incorporated
by
reference
in Section 215.105, to measure the
concentration of carbon monoxide and hydrogen.
3)
Reference
Method
4
to
measure
the
content
of
water
vapor,
if
necessary.
c)
The
volumetric
flowrate
shall
be
determined using
Reference
Method
2,
2A,
2C
or
2D,
as
appropriate.
d)
The
net
heating
value
of
the
vent
stream
shall
be
calculated
using
the
following
equation:
H=K~
CiHi
Where:
H
=
Net
heating
value
of
the
sample,
MJ/scm,
where
the
net
enthalpy
per
mole
of
offgas
is
based
on
combustion
at
25
C
and
760
mm
Hg,
but
the
standard
temperature
for
determining
the
volume
corresponding
to
one
mole
is
20
C,
as
in
the
definition
of
F
(vent
stream
flowrate)
below.
K
=
Constant,
1.740
x
iO~
(1/ppm)
(mole/scm)
(MJ/kcal)
where
standard
temperature
for
mole/scm
is
20
C.
83— 255
—16—
Ci
=
Concentration of sample component
i, reported
on
a wet basis,
in ppm,
as measured by
Reference Method
18
or ASTM Dl946—67
(reapproved
1977),
incorporated
by
reference
in Section 215.105.
Hi
=
Net heat of combustion of sample component
i,
kcal/mole based on combustion at 25 C and 760
mm
Hg.
If
published
values
are
not
available
or
cannot
be
calculated,
the
heats
of
combustion of vent stream components are
required
to
be
determined
using
ASTM
D2382—76,
incorporated by reference in Section 215.105.
e)
Whe r e:
F
=
Emission
rate
of
total
organic
compounds
(minus
methane
and
ethane)
in
the
sample
in
kg/hr.
K’
=
Constant,
2.494
x
10—6
(1/ppm)
(mole/scm)
(kg/g)
(min/hr),
where
standard temperature
for
(mole/scm)
is
20
C.
Mi
=
Molecular
weight
of
sample
component
i
(g/mole).
F
=
Vent
stream
flowrate
(scm/mm),
at
a
standard
temperature
of
20
C.
f)
The
total
vent
stream
concentration
(by
volume)
of
compounds
containing
halogens
(ppmv,
by
compound)
shall
be
summed
from
the
individual concentrations of
compounds
containing
halogens
which
were
measured
by
Reference
Method
18.
(Source:
Added
at
Ill.
Peg.
effective
)
APPENDIX
F:
COEFFICIENTS
FOR
THE
TOTAL
RESOURCE
EFFECTIVENESS
INDEX
(TRE)
EQUATION
This
Appendix
contains
values
for
the
total
resource
effectiveness
index
(TRE)
equation
in
Subpart V.
The emission rate
of total organic compounds in the
process
vent
stream
shall
be
calculated
using
the
following
equation:
E
=
K’F
CiMi
1=
83—256
—17—
If
a flow rate falls exactly on the boundary between the
indicated ranges,
the operator
shall
use the row in which the
flow rate
is maximum.
COEFFICIENTS
FOR
TRE
EQUATION
FOR CHLORINATED PROCESS VENT STREAMS WITH
NET HEATING VALUE
LESS THAN OR EQUAL TO 3.5 M.J/scm
FLOW
PATE
(scm/rn in)
Mm.
Max.
a
b
c
d
a
f
0.0
13.5
48.73
0.
0.404
—0.1632
0.
0.
13.5
700.
42.35
0.624
0.404
—0.1632
0.
0.0245
700.
1400.
84.38
0.678
0.404
—0.1632
~
0.0346
1400.
2100.
126.41
0.712
0.404
—0.1632
~T
0.0424
2100.
2800.
168.44
0.747
0.404
—0.1632
i5T
0.0490
2800.
3500.
210.47
0.758
0.404
—0.1632
~T
0.0548
COEFFICIENTS
FOR
TRE
EQUATION
FOR
CHLORINATED
PROCESS
VENT
STREAMS
WITH
NET
HEATING
VALUE
GREATER
THAN
3.5
NJ/scm
FLOW
RATE
(scm/mm)
Mm.
Max.
a
b
C
d
a
f
0.
13.5
47.76
0.
—0.292
0.
0.
0.
13.5
700.
41.58
0.605
—0.292
0.
0.0245
700.
1400.
82.84
0.658
—0.292
0.0346
1-400.
2100.
123.10
0.691
—0.292
0.0424
2100.
2800.
165.36
0.715
—0.292
0.0490
2800.
3500.
2.06.62
0.734
—0.292
0.0548
COEFFICIENTS
FOR
TRE
EQUATION
FOR
NONCHLORINATED
PROCESS
VENT
STREAMS
WITH
NET
HEATING
VALUE
LESS
THAN
OR
EQUAL
TO
0.48
MJ/scm
FLOW
RATE
(scm/min~
Mm.
Max.
a
b
c
d
a
f
0.
13.5
19.05
0.
0.113
—0.214
0.
0.
13.5
1350.
16.61
0.239
0.113
—0.214
0.0245
1350.
2700.
32.91
0.260
0.113
—0.214
0.0346
2700.
4050.
49.21
0.273
0.113
—0.214
0.
0.0424
COEFFICIENTS FOR TRE EQUATION FOR NONCHLORINATED PROCESS
VENT
STREAMS
~~ITH
NET
HEATING
VALUE
GREATER
THAN
0.48
AND
LESS
THAN
OR
EQUAL
TO
1.9
NJ/scm
83— 257
—18—
FLOW PATE
(scm/mm)
Miri.
Max.
a
b
C
d
a
f
0.
13.5
19.74
0.
0.400
—0.202
0.
0.
13.5
1350.
18.30
0.138
0.400
—0.202
~0
0.0245
1350.
270.0.
36.28
0.150
0.400
—0.202
~T
0.0346
2700.
4050.
54.26
0.158
0.400
—0.202
~T
0.0424
COEFFICIENTS FOR TRE EQUATION FOR NONCHLORINATED PROCESS
VENT
STREAMS
WITH
NET
HEATING
VALUE
GREATE~RTHAN
1.9
A~DLESS
THAN
OR
EQUAL
TO
3.6
NJ/scm
FLOW RATE
(scm/mm)
Mm.
Max.
a
b
c
d
a
f
0.
13.5
15.24
0.
0.033
0.
0.
0.
13.5
1190.
13.63
0.157
0.033
-~
0.0245
1190.
2380.
26.95
0.171
0.033
15T
0.0346
2380.
3570.
40.27
0.179
0.033
0.0424
COEFFICIENTS FOR TRE EQUATION
FOR NONCHLORINATED PROCESS VENT STREAMS WITH
NET HEATING VALUE GREATER THAN 3.6 NJ/scm
FLOW RATE
(scm/mm)
Mm.
Max.
a
b
c
d
a
f
0.
13.5
15.24
0.
0.
0.0090
0.
0.
13.5
1190.
13.63
0.0090 0.0503
0.0245
1190.
2380.
26.95
0.0090
0.0546
0.0346
2380.
3570.
4G.27
0.0090 0.0573
0.0424
Source:
Added
at
___
Ill. Reg.
_______,
effective
__________
IT
IS
SO
ORDERED.
I, Dorothy
N. Gunn,
Clerk o~ the Illinois Pollution Control
~oard, hereby certify that the above Opinion
and
Order
was
tdopted
çri
the
~
day-
of 7~,—zø~~
,
1987
by a vote
Illinois Pollution Control Board
83—258
