Section 215.204 Emission Limitations for Manufacturing Plants
kg/i (lbs/gal)
Compliance Plan
Section
(3.5)
Section
Section 2l5~.204 Emission Limitations for Manufacturing Plants
Section 215.211 Compliance Dates and Geographic Areas
Section 215.212 Conipliance Plan

ILLINOiS

POLLUTION

CCINTRCL

BOAFSD

October

1987

THE

MATTER

OF:

PROPOSED

AMENDMENTS

ILL.

)

R86’-36

ADM.

CODE

2i5.204,

215.211,

AND

215.212:

HEAVE

OFF—HIGH~AY

VEHICLE

PRODUCTS.

PROPOSED

RULE.

SECOND

NOTICE.

OPINION

AND

ORDER

Tr~E

BOARD

(By

R.C.

Flernal):

This matter comes before the Board upon proposals

 from

the

Illinois Environmental Protection Agency

 (“Agency”)

 and General

Motors Corporation,

 Electro—Motive

 Division (“END”)

 to amend

certain portions of

35

 Ill.

 Adm.

 Code 2~5pertaining

 to emissions

of volatile organic materials

 (“VON”)

 from facilities

manufacturing

 heavy off-highway vehicle

 (“HCHV”) products.

 Today

the Board

 sends the proposed amendments to

 second notice.

BACKGROUND

The origin of this proceeding

is

 rooted

 in the requirements

of the Clean Air Act (“CAA”)

 (42 U.S.C.A.

 Section 7401

et.

seq.).

 Pursuant to Section

109

 of the CAA,

 the USEPA aoopted

a

National Ambient Air Guality Standard

 (“NAAGS”)

 for ozone.

Attainment

of

 this NAA~Swas to have been demonstrated

 for all

areas of

 the State by December 31,

 1982,

 according

 to the

provisions

 of Section 172(a)(l)

 of the CAA~.

 However,

 Illinois

was unable

 to make such

 a demonstration.

 It therefore

 applied

for

 and received an extension

 of this deadline until December

31,

1987

 (pursuant

 to the provisions

 of Section 172(a) (2)

 of the

CAA).

As

 a prerequisite

 to obtaining this extension,

 Illinois

was required

 in the interim to

 include in its State

Implementation Plan

 (“SIP”)

 for areas which are nonattainment for

ozone

 “such reduction

 in emissions

 from existing sources

 in the

area

 as may be obtained through the adoption,

at

 a minimum,

of

reasonably available control technology”

 (Section

 172(b) (3)

of

CAA).

“Reasonably available control technology”

 (“RACT”)

 is not

defined

 in the CAA.

 However, USEPA

 has promulgated industry—

specific “Control Technology Guidelines”

 (“CTGs”) that are

intended to describe RACT for

 a given industry and assist states

in determining

RACT.

 USEPA has

 publisi-ied three groups

 of CTGs.

On December

 30, 1982,

 In the Matter

of

 RACT II Rules,

 R80—5,

the Board adopted rules

 intended

 to satisfy

 the RACT requirements

82—217

as specified

in

the

 second group

 of CTGs.1

 however,

 on July 11,

1985,

 the USEPA at

 50 Fed.

 Reg.

 28224 proposed

 to disapprove

certain of

 the rules adopted

by

 the Board

 in R80—5.

Included in the proposed disapproval

 are provisions relating

to coatings applied

 to HOHV products.

 Specifically,

 the rule

adopted in R80—5 allows

 a maximum of

 4.3 lbs VOM/gallori of

coating for air—dried extreme performance

 top coat and 4.8 lbs

VON/gallon

 for air—dried

 final repair coating.

 USEPA asserts

that th~presumptive norm

 for both of these

 categories is 3.5

1bs/gal~, and hence

 that the current

 Illinois limitations do not

represent

 RACT.

The basis

for

 the conclusion

 that tne presumptive norm for

the coatings

 in question

is

 3.5 lbs/gal derives

 from the CTG for

coating

 of miscellaneous metal

 parts

 and products

 (Ex.

3).

Although HOHV products are not identified

 by that name w~thin the

CTG,

 tney are presumed

 to be included within

 the “other”~

category identified

 in Figure 4.1

 of the CTG

 (Ex.

 3 at

 4—3).

Figure

 4.1 states

 in part that

 the presumptive norm of 3.5

lbs/gal applies

 to “other” parts

 and products which are:

Air

 or forced

 air—dried

 items:

 Parts too large or

too

heavy

 for practical size ovens and/or

 sensitive heat

requirements.

 Parts

 to which heat sensitive

materials are attached.

 Equipment assembled prior

to

top coating

 for specific performance

 or quality

standards.

Ex.

 3 at

 4—3

1 The second group of CTGs covered

 the following source

categories:

 factory surface coating

 of flatwood paneling;

petroleum refinery fugitive emissions; pharmaceutical

manufacturing;

 rubber tire manufacturing;

 surface coating

of

miscellaneous metal

 parts

 and products;

 graphic

 arts

 (printing);

dry cleaning perchloroethylene;

 leak prevention

 from gasoline

tank trucks and vapor collection systems; petroleum liquid

storage

 in external floating roof tanks.

2 Unless otherwise

 indicated,

 3.5 lbs/gal coatings are

hereinafter assumed

 to refer

 to the VON content of air—dried

extreme performance

 top coats

 and air-dried final

 repair coats.

3 Categories listed within the miscellaneous metal parts and

products CTG are can,

 coil,

 wire,

 auto and

 light duty truck,

metal furniture,

 large appliance,

 and “other”.

82—218

—3—

R86—36 PROCEDURAL HISTCR~

The Agency filed

 its proçosal

on

September

l9b6.

The

original Agency proposal addresses amendments

to

35

 Ill.

 Adm.

Code

 215.204 plus conforming

 amendments

 to 215.211.

 On March

30,

1987,

 the Agency filed

 an amended proposal

 in which

 it also

proposes technical amendments

 to Section 215.212

 to bring

 this

section

 into conformity with the amendments proposed

 to Sections

215.204

 and 215.211.

Concurrently with

the

 action, EMD oi~December

8,

 1986,

 filed

what

 it characterized as

 a site—specific

 exception

 to the

Agency’s proposed

 rule.

 This proposal was docketed

as

 R86—5l.

EMD’s proposal creates

 a new subsection within Section 215.204

with VOM limitations specific

 to diesel—electric

 locomotive

manufacturing plants.

 On the same date

 END also filed

 a motion

to consolidate

 the site—specific exception with the present

proceeding.

By

 Order of

 December

 18, 1987,

 the Board determined

that the

 END “site—specific” proposal can most reasonably

be

construed as

 an amendment to the Agency’s original proposal.

Accordingly,

 the Board

on

 the same date ordered

 that docket R86—

51

 be closed and

 the record

 of that proceeding

be

 incorporated

into

 the instant proceeding.

On January

12,

 1967,

 the Agency filed

 a motion requesting

that the Board

 reconsider

 its incorporation of the EMD “site—

specific” proposal.

 That motion was denied

 by Board Order

of

Jany 22,

 1987.

 The Agency renewed

 the motion by filing

 of May

13,

 1987.

 The Board

 again denied the motion

in

 the first notice

Opinion and Order,

 June

25,

 1987.

Nerit hearings were held

 on December

9,

 1986,

in

Springfield,

 Illinois,

 and on February 26,

 1987,

 in Romeoville,

illinois.

 Testimony was presented by the Agency and

 by END at

both hearings,

and

 by Caterpillar,

 Inc.

 (“Caterpillar)

 at the

February

 26 hearing.

On hay

7,

 1987,

 the Illinois Department

 of Energy and

Natural Resources

 issued

 a “negative declaration”

 of economic

impact

in

 this proceeding.

 The Economic and Technical Advisory

Committee concurred

 in that determination on June

4,

 1987.

The Agency filed post—hearing comments

 on April

6,

 1987,

and

on May 13, 1987

 (hereinafter

 “Agency Comment”).

 A post—hearing

As proposed,

 the rule

 is properly characterized

as

a

 rule of

general applicability,

 in that it would apply to all

manufacturing facilities of

the

 type

 identified.

 However,

 as a

practical matter, there

 is only one such facility

 in Illinois,

and

to

 this end

 it would

 function as

 a site—specific rule.

82—219

—4—

comment was also filed

 on May

11,

 1967,

 by END (hereinafter

 “END

Comment”).

On June

 25, l9~7, the Board adopted

 a combination of the

Agency’s and EMD’s proposals for

 first

 notice.

 Publication

occurred

at

11

 Ill.

 Reg.

 12546,

 July

31,

 1967.

 Two public

comments

 (hereinafter “PC”)

 were filed

 on the last day

 of the

first notice comment period.

 These were from END (PC ~l) and

Caterpillar

 (PC #2).

EXISTING AND PROPOSED RULE

The principal existing regulations relating

 to VON emissions

from HOHV facilities are found

at

35

 Ill. Adm. Code

 Subpart

F,

Coating Operations,

 Section 215.204(k).

 These

 rules are

applicable

 throughout the

 State.

The Agency’s proposed amendments retain

 the present

 rule for

the majority of

 the State,

 but lower

 the maximum allowable

limitations

 in two coating categories, extreme performance

topcoat air—dried

 and final repair coat air—dried from current

limitations

 to 3.5 lbs/gal

in

 a ten—county

 area.

The

ten

counties

 are Cook,

 DuPage,

 Kane,

 Lake,

 Macoupin,

 t’ladison,

Mchenry, Monroe,

 St. Clair,

 and gill.

The complete Agency proposal

is

 a follows5:

Section 215.204

 Emission Limitations for Manufacturing Plants

No owner

 or operator of

a

 coating line shall cause

 or allow the

emission of volatile organic material

 to exceed

 the following

limitations on coating materials,

 excluding water, delivered

to

the coating applicator:

kg/i

 (lbs/gal)

k)

 Heavy Off—Highway Vehicle Products

1)

 In Cook,

 DuPage,

 Kane,

 Lake, Macoupin, Madison,

Mchenry, Monroe,

St.

 Clair

and

 Tr~i1l Counties

Extreme performance prime coat

 0.42

 (3.5)

The Board

 has made some minor form modifications to the

Agency’s proposal

 as presented

 here.

All

of

 these changes are

intended

 to conform the proposal

 to the proper format for

regulatory amendments and language.

 No substantive changes have

been made.

82—220

—5—

Extreme

performance

top

coat—air

dried

_____

______

Final repair coat—air dried

_____

______

In the remaining counties

Extreme performance prime coat

Extreme performance top coat—air

dried

 0.52

Final

repair

coat—air

dried

0.58

215.211

 Compliance Dates and Geographic Areas

Except as otherwise stated

 in subsection

 (b),

 every

major

 owner

 or operator

of

 an emission source subject

to

Section 215.204(j),

 (k), and

(1)

 shall comply with those

sections

 in accordance with the following dates:

1)

 For Section 215.204(j)

 and (k)(2) Extreme

performance prime coat and Final

 repair

 coat

—

air

dried,

 by December

31,

 1983.

For Section 2l5.204(k)(l),

 by December

31,

 1987.

For Section 215.204(k)(2) Extreme performance top

coat

—

 air dried,

 in accordance with Section

215.210.

3!)

 For Section 215.204(1),

 by December

31,

 1985.

215.212

 Compliance Plan

The owner

 or operator

 of an emission source subject to

Section 215.2l1(a)(l)

or

 (23) shall

 submit to

 the Agency

a compliance plan on or before August

19,

 1983.

b)

 The owner

or

 operator

 of an emission source subject

to

Section 215.2ll(a)(34)

 shall

 submit to the Agency

a

compliance plan on or before October

31,

 1985.

c)

 The owner

 or operator

 of an emission source subject

to

Section 215.21l(a)(2)

 shall submit

to

 the Agency

a

compliance

 plan no later

 than August

19,

 1987.

ed)

 The owner or

 operator

 of an emission source subject

to

Section 215.211(b)

 shall

 submit to the Agency

a

compliance

 plan no

 later

 than December

31,

 1986.

~e)

 The owner or operator

 of an emission source subject

to

Section

 215.211(c)

 shall submit

 a compliance plan within

2)

0.42

0.42

0.42

Section

(3.5)

(3.5)

(3.5)

(4,3)

(4.8)

2)

23)

Section

a)

82—221

90 days after

 the redesignation,

but

in

 no case

 later

than

December

31,

1986.

ef)

 The owner

 or operator

 of an emission source subject

to

Section 215.211(c)

 shall not be

 required

 to submit

a

compliance plan

 if redesignation occurs after December

31,

 1986.

~)

The

Plan

and

schedule

shall

meet

the

requirements

Ill.

 Adm.

 Code

 201.

The END proposal

 language,

 as adopted

 by the Board

 in the

first notice Opinion

 and Order,

 contained modifications

 from that

originally offered

by

 END.

 The modifications consisted

of

 change

the

suggested

placement

 the END rule within Section

215.204,

 change

 in the title

 of the subsection,

and

 the inclusion

of

 a limitation

 of 3.0 lbs/gal for “all other coatings”.

 These

changes were made partially on the recommendation

 of the Agency

(Agency Comment at 9—10)

 and partially

 on Board

 initiative.

The

Board additionally requested that

 the appropriateness of

 these

changes

 be addressed during the first notice comment period;

EMD

objected

 to the modification

in

the

 title

 (PC #1),

 for the

reasons discussed below.

The END proposal, modified as noted

 above

and

 as adopted

at

first

notice,

would

add

the

following

subsection

 Section

215.204:

m)

 Existing Diesel—Electric

 Locomotive Coating Lines

in

Cook County

1)

 Extreme performance prime

 coat

 0.42

 (3.5)

2)

 Extreme performance top coat—air

dried

 0.52

 (4.3)

3)

 Final

 repair coat—air dried

 0.58

 (4.8)

High—temperature

aluminum

coating

0.72

(6.0)

5)

All

 other coatings

 0.36

 (3.0)

The

Board

also

noted

 at first notice

that

adoption

the

EMD proposal would require

 a conforming modification

 to Section

21521l,

 similar

 to that proposed

as

 an accompaniment

 to the

Agency’s proposal.

 The Board will not fully write out that

change here,

 but rather

 notes

that

consists

identification

of Section 215.204(m)

 within the Agency’s proposed Section

215.2l1(a)(2).

This

change

made

the

Order

herein.

parallel modification

 to Section

 215. 212

 is not required given

the structure of the Agency’s proposed modifications

 to Section

215.211 and 215.212.

82—222

—7

RATIONALE

FOR

PROPOSED

 AMENDMENTS

Cverview

As noted above,

 the purpose

 of the proposed amendments

is

to

overcome

 the objections

 of the USEPA to certain rules promulgated

by the Board

 in the original RACT

 II proceeding,

 R80—5.

The

basis of the USEPA’s objection

 is that the existing limitations

for coatings

in

 the HOHV category do

 not represent RACT

 in that

coatings meeting

 3.5 lb/gal are presently available

and

in

commercial

use

(H.

 at 43).

In

 order

 for Illinois

 tu overcome

the

TJSEPA’s

objection

without changing

 the present rule,

 it would be necessary

to

demonstrate

the

USEPA

that

 3.5 lbs/gal

 coatings are

not

reasonably available

 to HOUV manufacturers.

 However,

 the Board

does

not

believe

that

this

demonstration

can

made.

Ample

evidence exists that

 3.5 lbs/gal coatings are available,

 and that

at least

 some fraction of

 the HOHV industry can and does

use

 them

(see following).

 For this reason the Board will today

 send

to

second notice

 those

 amendments proposed

by

 the Agency which would

limit HOHV air—dried

 extreme performance top coatings and final

repair

coatings

3.5

lbs/gal.

This

not

say,

however,

that

the

Board

believes

that

3.5

 lbs/gal coating

 are necessarily available

 for all HOHV

products

for

all

facilities

within

the

HOHV

category.

The

miscellaneous metals parts and products CTG in

 fact contemplates

this circumstance,

 noting:

It must be cautioned

 that the limits reported

in

 this

report

 are necessarily based

 on a general

consideration of the capabilities and problems

 of the

hundreds

industries

which

coat

their

products.

(sic)

will

not

applicable

every

plant

even

every industry within

 the many industries which

 coat.

For example, the

 level

 of control which

 is herein

recommended

for

 a particular

 source may be based

on

a

type

 of coating

which

cannot

 meet.

 the specifications

required of another product

 from

 a similar

 source.

Ex.

 3 at

iv

 (emphasis added)

The CTG further

 notes:

Current technology does not provide

 low—polluting

coatings which

 can successfully replace conventional

coatings

 for all

 the specialty items coated by the

 many industrial categories covered

by

 this

 CTGJ...

There

 will

be

...

 situations where low—polluting

coatings may never

 be applicable...

Ex.

3

at

4—2

82—223

—t~

The CTG thus allows

that

the

State

 may demonstrate that 3.5

lbs/gal coatings are not reasonably available

 for some portion of

the industries,

 plants,

 or products

 included within

 the HOHV

category.

 The Board

 believes that END has made

 a satisfactory

demonstration that 3.5 lbs/gal coatings are not reasonably

available

 for certain of

 its products

 (see following),

and

accordingly,

 the Board

 will send

 to second notice special

limitations for EMD’s locomotive coating

 line.

Finally,

 the Board believes that the present amendments need

be applied only

 to those

 areas within which there

is

a

demonstrated

need

for

 further

 reductions

 in VON.

 Accordingly,

the Board will

 send

 to first notice the proposal

 of the Agency

that

 the amendments

 apply only in

 a ten—county area

 (see

following).

Availability

 of Coatings to the HCHV industry

 in General

A central

 issue

in

 the instant matter

 is whether 35

 lbs/gal

coatings constitute

 RACT

for

 the HOHV industry.

 A coating

is

RACT

if

it

 is reasonably available

to

 a manufacturer.

 Reasonable

availability apparently means not only that

 formulations which

meet

 the 3.5 lbs/gal limitation exist,

 but also that the

formulations

(1)

are

commercially

available,

(2)

are

not

prohibitively

expensive,

and

(3)

are

capable

meeting

the

specifications

 for particular

 jobs and products.

In addition

to

the

documentation

provided

the

CTG,

the

Agency

 has provided independent documentation that

 3.5 lbs/gal

coatings are

RACT

for

 the HOHV industry in general.

The

principal

portion

this

evidence

provided

study

jointly

commissioned

the

USEPA

and

 the Agency and conducted

 by Pacific

Environmental Services

(Ex

2;

 hereinafter

 “PES”

 Study)6.

 The PES

Study consists principally of

 surveys

 of coatings suppliers and

of HOHV manufacturing facilities.

 The conclusion of the study

is

that

 3.5 lbs/gal coatings are both available

 to and are being

used

segments

the

Illinois

HOHV

industry

 (Id. at 6—1).

evidence

availability,

the

PES

Study

cites

variety

of

 3.5 lbs/gal

 coatings which

 are commercially available from

6 The PES study was commissioned

 in September

 1985.

 A draft copy

of the study was submitted

 to the Agency

 in October

 1985.

 This

draft

 ~as reviewed

 by and comment solicited from the USEPA,

the

Agency,

 coating suppliers,

 and members of the regulated community

(R.

at

44;

Ex.

4

to

8;

Ex

 l3b to

 13h;

Ex.

 15, attachment

4).

A

final draft was then composed by PES and submitted

 to the Agency

in January 1986 under

the

 title “Study of Low—VOC Coatings

Available

 for Use

in

 the Illinois Heavy—Duty Off—Highway Vehicle

Manufacturing

Industry”

(Dx.

2).

82—224

—9—

eight different suppliers

 (Id.

 at 3—2).

 The Study also cites

27

coating suppliers who are “investigating

 low—VOC coatings”

 (Id.

at

 3—3),

 as apparent evidence of

 suppliers’

 interest

in

developing

 additional compliant coatings.

As evidence

of

 use,

 the PBS Study cite~six HOHV facilities

that currently use 3.5 lbs/gal

 top coatings

 (Id.

at

 3—5).

 These

include some Illinois facilities

 which would not be required

to

use 3.5 lbs/gal coatings because they are not located

 in the ten—

county area within which th~proposed rule would

 be applicable.

However,

 of the five active0

 facilities located within the ten—

county area,

 3.5 lbs/gal coatings are reported

 to be

 in use by

two and

 in partial

 use by

 a third

(H.

at

52,

 135,

 140).

 This

information

 is summarized

in

 the following

 table, which includes

the facilities and their location,

 compliance status relative

to

the

 3.5 lbs/gal limit

 as purported

 to by the Agency,

 and types

of

products:

“Compliance”

with 3.5 lbs/

Facility/Location

 gal limitation

 Types of Products

Allis—Chalmers Industrial

In

 Industrial

 forklifts

Truck Division Matteson

 Compliance

(Cook County)

International Harvester

In

 6—cylinder diesel

Melrose Park

 (Cook Co)

 Compliance

 engines

 for agricul-

tural

and

construction

equipment

 and trucks

Dresser Industries

 Partial

 Heavy—duty tractors

&

Libertyville

 (Lake

00)

 Compliance

 construction equipment

Caterpillar,

 Inc.

Not

in

 Components

to

heavy—

Joliet

 (hill Co)

 Compliance

 duty equipment;

 e.g.,

hydraulic valves,

bulldozer blades, push

arms,

 and scrapers

It

 is not clear

 from

 the PBS Study that 3.5 lbs/gal final

repair coatings are also available

 to and used by these

facilities.

Additionally,

one

the

 six facilities was later

indicated to have given up use of

 3.5 lbs/gal

 top coatings

(H.

at

46;

Ex.

5).

8 The PES Study identified

 a sixth

 facility within the ten—county

area,

 Allis—Chalmers Engine Division, Harvey and Phoenix

 (Cook

County).

The

 record indicates that this facility subsequently

ceased operations

 in May 1986

~R.

 at 50,

67;

Dx.

11).

82—225

~.i

—

General Motors,

 Electro—

Not

in

 Llectro—motive engines

Motive Div LaGrange

 Compliance

 and locomotives

(Cook County)

Modified9

from

Ex.

Of

 the five facilities,

 testimony was presented

 in the

instant record

 on behalf of only the latter

 two, Caterpillar and

END.

 The Agency asserts

 that Dresser, which did not appear at

hearing, currently uses some 3.5 lbs/gal

 coatings

(H.

at

48,

140),

 but that the Dresser

 facility “is not now in daily

compliance

with

the

present

regulation

and

that

this

 non-

compliance

 status will certainly

not

 improve

if

 the facility

 uses

paints

that

are

above

the

3.5

pounds

per

VOC

gallon

limit”

(H.

at

 49).

 The Agency opines that Dresser’s failure

 to present

opposition

 to the Agency’s proposal signifies that Dresser has

the ability to comply and is not presently complying

 simply

because

it

 is not required

 to comply

 (Agency Comment

at

 7-8).

the

 basis of

 the above,

 the Board concludes

 that there

are

generally

available,

although

not

necessarily

 universally

available,

 3.5 lbs/gal coatings

for

use

 in the HGHV

 industry.

For

 this

 reason,

 3.5 lbs/gal coatings constitute

 the general RACT

for HOHV facilities.

Special

 rules for END’s Locomotive Coating

 Line

As noted above,

 the CTG allows that

 3.5 lbs/gal

 RACT

coatings may not exist

for

 all miscellaneous metals parts and

products.

 The Board believes that END has successfully

 demonstrated

 that this

 is the case

 for the diesel locomotives

produced

at

 its facility.

 END produces products other than

diesel locomotives at

 its LaGrange facility,

 including non—

locomotive

 engines and generators

(H.

at

 268; END Comment at

5).

 However,

 the discussion

 in this section, unless otherwise

This table

 was originally presented at

 2—4

 of the PES Study

(Ex.

2).

 A modified version was presented during the testimony

of

 Dr. John Reed

of

 the Agency

(R.

at

47)

as

Ex.

 15, Attachment

1.

 The version presented

 here

 is modified further based

on

information present

in

the

 record.

 The latter modifications

include change

 in ownership of the Dresser Industries facility,

which was previously owned

 by International Harvester

 (H. at

47,

67;

Dx.

 4); change

 in “compliance status” of the Dresser

Industries facility from

 “in compliance”

to

 “partial compliance”

(H.

135);

change

name

the

Caterpillar

facility

from

Caterpillar Tractor Company to Caterpillar,

 Inc.

(R.

 at 216);

and

addition of “scrapers”

 to the list of Caterpillar products

 (Ex.

5

at

2).

82—226

—11—

noted,

 as well

 as the rule proposed

for

 the END facility,

 goes

specifically

 to just the diesel locomotive operations.

Discussion

 of the non—locomotive engines

 and generators

 follows

this

section.

The

END position that 3.5 lbs/gal coatings do not constitute

RACT

 is based

 on several characteristics associated

 with its

product, method

 of production,

 production specifications,

and

coating

 availability.

 Major elements include the large

 size and

complex configuration

of

 the locomotives, difficulty

 of access

to

painted surfaces,

 and complex paint patterns and large variety of

colors which are required.

Locomotives are fully assembled when they are painted

(H.

at

194).

 This occurs because each locomotive must be painted

according

to

 the color

and

 logo specifications

of

 the individual

railroad which has purchased

it

CR.

at

 190;

Ex.

 C2 to C4, C36—

40).

 Purchasers

 include

 both domestic

 and foreign railroads

(R.

at 189—192),

 each of which

 has special

 color

 and pattern

specifications.

Because

 locomotives are

 fully assembled when they are

painted,

 a large variety of surfaces

 are encountered

 (H. at 194),

including cut—ins, doors, hinges,

 grilles,

 fans,

 ducts, etc.

(H.

at 202,

 212).

 This,

 in combination with the complex paint

pattern required

 by the purchasers, additionally requires that

all locomotives be painted manually.

 Painters wearing protective

“moon

 suits”

(H.

at

 201)

 must stand

 on and move around the

locomotive or

 special scaffolding during the painting operation

(R.

at

 194—5);

 some surfaces must be sprayed from distances

of

six

 to eight feet

(H.

at

 195).

All painting occurs

 in one

 of two confined paint booths

(H.

at

 200).

 To assist drying, heated air enters through filters at

the top of the paint booth

 and flows down along

the

 sides of the

locomotive

and

 is exhausted through filters at the lower walls

(H.

at

 200).

 The velocity

 of air flow

 is maintained

at

approximately 150

 feet per minute, pursuant

 to OSHA regulations,

which results

in

 a total exhaust volume of one million cubic

 feet

per minute

(H.

 at 195).

 The breezes

 thus created

 in the paint

booths

 present further difficulties

 in spray painting

to

specification.

 The complexity of painting patterns also requires

that portions of the locomotive

 be masked before additional

coatings and colors can

 be applied

(H.

 at 205).

 This

 in turn

requires

that

previously

applied

coatings

dry

that

they

are

not damaged

 by the masking

(H.

 at 205).

A futher

 facet

 of the requirement

 upon END of painting

 each

locomotive

 individually

 to the color specifications

 of the

purchaser

 is that there

 be available

 a broad

 range of colors

(H.

at 187).

 END presently uses six different prime coatings and

fourteen top coats

 in approximately

 75 colors

(R.

at

 194,

 216).

82—227

—12—

END contends that paint suppliers are reluctant

 to attempt

to

develop compliant formulations

 in this broad

 range of required

colors given

 the small

 usage of

 the paints

(H.

at

 264).

END has achieved compliance with existing Section

 215.204(k)

for all

 of the top and final

 repair coatings

(H.

at

 184—5).

END

has also converted

all

of

its

 prime coatings

 to 3.5 lbs/gal

paints, pursuant to existing Section 215.204(k)

(H.

 at 201).

END

contends,

 however,

 that the latter change has presented problems,

including

 increase

 in film

 thickness from

 1 to

 2 rnils

to

2

to

4

mils on

 flat surfaces and

 to as much as

 6 mils on non—flat

surfaces

(R.

at

 202).

 Moreover, prime coating usage has

increased by

a

 factor of

 1.5,

 so that the expected reduction

in

VON emissions has not occurred

(R.

at

 202).

END concedes that

 3.5 lbs/gal coatings are available,

 in the

sense

 that they can

 be purchased

(H.

at

 203).

 However, END

contends that they are not “available”

 to locomotive

manufacturers because the existing coatings

 can not

be

successfully applied

 (Id.).

 As evidence thereto, END draws on

experience from “extensive

 tests of

 3.5 pound

 coatings both on

test panels and fully assembled locomotives”

 (Id.).

END

contends that

the

 tests have

 sho~.’n that

 there

are

 four

primary reasons why high—solids coatings can not

 be used on

locomotives.

 These

are

(1)

 film builds are excessive,

 (2) finish

appearance

 is unsatisfactory,

 (3) dry—to—tape times are

unacceptably

long,

and

(4)

sprayable

pot

life

too

short

enable painting an entire locomotive

(K.

 at 203—13).

 These

problems remain

 in spite

 of END’s efforts

 to modify application

methods

 to accommodate high—solids coatings

(H.

 at 217—20).

END

also

contends

that

 it has explored waterbourne

 coatings,

but

opines

that

the

only

available

waterbourne

coatings

durable

enough

 for use

on

 a locomotive

 require baking

 rather

 than

 air—

drying

(H.

216).

However,

fully

assembled

locomotive

can

not

 be baked

 both because

of

 its size

and

 because

 the presence

of

electrical wiring

 and rubber parts which can not withstand

extremely high temperatures

(H.

 at 216—7).

Finally,

 END has explored achieving compliance via add—on

controls

(H.

 at 225—35).

The

principal problem

 is that the

amount

 of reduction

 in VON emissions required from END

 is small’0

so

that

even

moderately

costly

 control system produces

 a very

large cost per

 ton of reduction.

 Costs

 for various possible

 add—

10 The Agency estimates the required reduction

to

 be 5.62

 tons

per

year

(H.

111).

the

time

the

hearing

END

estimated

it be be

16

 tons per

 year

 (Dx.

 H), which was later

 corrected

to

34

 tons per year

 (EMD Comment at

5).

82—228

—13—

sjstems

cited

tIC

 range upward

 from $b9,000

per

ton

(K.

at

 233—4),

 based on

its

own

estimates

that

its

required

reduction

is

tons

per

year

(K.

at

 233).

END—LaGrange

 is the only diesel locomotive manufacturer

in

Illinois,

and

 is one of only two

 in the United States

(H.

at

 187,

245).

 The second

 is the General Electric facility

 in Erie

County,

Pennsylvania

(Id.).

Erie

County

nonattainment

for

ozone

 (END Comment

at

2).

The

Pennsylvania

 RACT

 rules provide

for

 a 4.3 lbs/gal

 limit on

 top coats

 for locomotives

 (Dx.

 B at

129.52),

the

 same limitation here

 requested

by

 END.

The

Pennsylvania SIP has been approved

 by the USEPA

(H.

at

 246;

END

Comment at

3).

The preceding

 discussion

 has focused

on

the

 top coatings and

final repair

 coatings available

 to END.

END

also raises the

issue of

 a specialty coating

 used

in

 small quantity.

 That

is

the

high—temperature

 (“Hi—Temp”) aluminum coating

 used to paint the

turbo exhaust duct and adapter

 screen assembly used on

the

locomotives

(H.

 at 199).

 Both components must withstand

temperatures

up

 to 1,000

 degrees Fahrenheit.

END

contends that

because

use

the

Hi—Temp

aluminum

coatings

small,

 gallons

less

per

year,

suppliers

have

interest

developing

compliant coating

(H.

at

 214).

EMD

further

contends

that

has

been

unable

obtain

Hi—Temp

aluminum

coating

with

VON

content below

 6.0 lbs/gal, and that this

 situation

 is not

expected

 to change (Id.).

 The Agency itself accedes

 that END has

“made

 the necessary case

for

 the higher VOM level

in

 its high—

temperature aluminum coating”

 (Agency Comment

at

9).

The

Board

has

faced

 the matter

of

 use of

 Hi—Temp aluminum

coatings

 EtID’s facility betore.

 This occurred

 in the

proceeding PCB 86-195,

 in which END sought and

 the Board granted

a variance

 for use

 of the 6.0

 lbs/gal Hi—Temp aluminum coating

until

December

31,

 1987,

 or until

 the Board makes

 a final

determination

in

 the instant

 rulemaking, whichever occurs first

(General Motors Corporation

 (Electro—Motive Division)

v.

 IEPA,

PCB ~6—l95,

 February 19,

 1987).

 The record

of

 the POE 66—195

proceeding

 has been incorporated

 into that of

 the instant matter

(H.

214).

In PCB 86-195

 the Board was impressed with

 the arbitrariness

which would

 be associated with requiring

 END to comply with

existing regulations given

 the unavailability

of

 a compliant Hi—

Temp

aluminum

coating,

and

the

minimus

environmental

impact

associated with continued use

 by END of

 the existing 6.0 lbs/gal

Hi—Temp aluminum coating.

 As regards

 the latter,

 the Board notes

that

the

total

VON

emissions

 END’s Hi—Temp aluminum

coating operation

 in 1986 was 0.195

 tons or 391 pounds,

and

that

the

anticipated

1987

emissions

are

0.12

tons

240

pounds

(PCB

66—195,

 February

19,

 1987,

at

5).

 The Board believes that the

instant record continues

 to support

 special

 consideration of

the

use

 of Hi-Temp aluminum coatings by

 END.

82—229

—14—

For all

the

 reasons discussed

 above,

 the Board believes that

END has successfully demonstrated that RACT

 for its locomotive

operations consists of

 the rule

 as proposed herein.

RACT

for END’s Non—locomotive Engines

 and Generators

As the

 final matter

 relating

 to the END proposal,

 END has

contended throughout this proceeding

 that the non—locomotive

engines

 and generators which

 it produces should,

 along with its

locomotives,

 be excluded from the 3.5 lbs/gal

 coating limitation

(e.g., END Comment

 at 5—6).

 However, at first notice the Board

proposed

exception

only

for

the

locomotive

coating

line.

This

was effected by

 titling the section containing

 the END exception

“Existing Diesel—Electric

 Locomotive Coating

 lines

Cook

County”

 (emphasis added; see p.

 6 herein),

 as was recommended by

the Agency

 (Agency Comment

at

9).

 The Board

 based

 its first

notice

decision

the

following

argument:

END

contends

that

its

engines

and

generators,

its

locomotives,

 have complex configurations which makes

them difficult to coat evenly,

 that they are painted

“job

shop”

mode,

 that

 their appearance

is

important

 to customers,

and

 that they require extreme

performance coatings

END

 Comment at

 5—6.

 However,

the Board

 does not believe

 that these features alone

are sufficient for

 a finding that

 3.5 lbs/gal coatings

do not constitute RACT

for

 the engines

and

generators.

 Clearly, difficulty

 of coating evenly,

complexity

 of configuration,

 appearance,

 and the need

for

 extreme performance coating are not attributes

peculiar

 to END’s engines

 and generators,

but

 rather

attributes held by many miscellanous metal parts and

products

 for which compliant coatings are

demonstratively available.

 Similarly,

 END has made

no

demonstration

that

the

job shopping

products

itself sufficient

 to determine RACT.

 Conversely,

 some

of

 the elements that the Board

 finds compelling

for

excepting the locomotive line,

 including the

complexity

painting

patterns

and

surfaces,

 dry—to—

tape

 times

(H.

 at 278),

 and the

 lack of available

coatings, have not been demonstrated

 here.

 The Board

accordingly believes that there

 is insufficient

justification

for

exception

other

than

for

the

locomotive line.

First Notice Opinion and Order,

 June

25,

 1987,

at

17

In

 its first notice comment

 (PC U)

 END contests parts of

this analysis.

 EMD opines that:

EMD’s special RACT limitations thus seems to be based

on

 the following assumptions:

 1) END’s engines and

82—230

-15-

generators,

 as opposed

to

 its painted locomitive body

surfaces,

 are not different

 from other

 heavy off—

highway vehicle products,

and

2)

 compliant coatings,

i.e.,

coatings

with

VOC

content

3.5

lbs./gallon

are “demonstratively available”

for

 these

 other

products.

PC.

#1,

at

2

END thereafter

 attempts to show that its non—locomotive engines

and

generators

are

different

from

 other

 off—highway vehicle

products,

 that compliant coatings are not demonstratively

available

 for non-locomotive products,

 and that

 all END products

locomotive

 and non—locomotive

-—

 are painted with the same

painting process

 (PC il).

The Board

 finds much of EMS’s public comment argument

misplaced.

The

Board

has

not

premised

any

its

decisions

this matter

on

 the assumption

 that all HOHV products are

the

same.

Quite

 to the contrary,

 the Board

 has diligently attempted

sort

out

the

distinctions

among

the

many

different

products

covered

 in the HOHV category.

It

only

due

this

action

that

the

Board

has

been

able

distinguish

 the particular

characteristics of END’s locomotives which cause

 the Board

to

propose

special

 HACT

rules

for

the

locomotives.

Moreover,

the

above

citation

from

the

first

notice

Opinion

and

Order

clearly

indicates,

 the Board placed weight on END’s

 own failure

 to make

the same compelling

 argument

for

 the unique character

 of the non—

locomotive

engines

and

generators

that

did

for

its

locomotives.

 The Board

notes

that

END

still

does

not

contend

that its non—locomotive engines require the

 large number

of

different coatings,

 the extensive masking and complexity

of

painting patterns,

 the long dry—to—tape

 times,

 nor the need

to

paint within the existing paint

 tunnel that constitute compelling

arguments

 for alternative RACT

for

 the locomotive

 line.

The Board

 is aware

 that compelling

 arguments,

 should they

exist,

 for excepting

 the non—locomotive engines

 and generators

may not be the same arguments

 upon which

 a locomotive exception

is justifiable.

 However,

 the Board

 notes that

EMS

presented very

limited testimony regarding

 the non—locomotive engines and

generators, preferring

 instead

 to concentrate

 its testimony on

its

locomotive

coating

problems.

 END would apparently wish the

Board

 to presume

 that

the

non—locomotive

engines

and

generators

have the same coating limitations as do the locomotives, and thus

have

the

demonstration

made

for

 the locomotives also suffice

for

the other products.

 This

 is a presumption which

 the Board can

not make,

 and one which seemingly flies in the face of END’s own

admissions regarding

 the differences between coatings of

locomotives and

 its other products.

 In fact,

 the Board

is

at

a

loss

 to understand END’s contention

 that “all

 END’s products

——

locomotive

 and non—locomotive

——

 are painted

with

the

same

painting

process”

(PC

U

at

 5), when END also admits that coating

82—23 1

—16—

of the non—locomotive products occurs outside

 the paint tunnel

and that there,

 among

 other differences,

 the dry—to—tape and

short

pot

life

problems

not

 exist.

The critical matter,

 therefore,

 is not whether the non—

locomotive

engines

and

generators

 are different

 from other

 Hc~HV

products,

 but rather whether the differences are such

as

to

support

 an alternative RACT.

 The Board does not believe

 that END

has made this demonstration.

On the matter

of

 the availability of compliant coatings,

END

contends that

 3.5 lbs/gal

 top coatings are not available

to

several manufacturers of particular products,

or

 in one cited

case

availability,

that

the

product

differs

from

END’s

to

 be make

 the availability of this

 coating

 irrelevant

(PC

 #1 at

2—5).

 The Board

also

finds

this

 argument misplaced.

END

is

reminded

 that 3.5 lbs/gal top coatings are the USEPA’s

presumptive norm for

 the HOHV category.

It

 is therefore

incumbent upon

 the Boarà

 to find, and upon

 END to show before

the

Board,

 that END’s product can not be coated with 3.5 lbs/gal top

coating

if

 an alternative

RACT

 is to

 be successfully

demonstrated.

 To this end

it

 is irrelevant that compliant

coatings may

 be unavailable

 to some other manufacturing plants

and products,

 or that one specifically available coating will not

suffice

for

END’s

 non—locomotive engines

 and generators.

final

argument

 for excepting non—locomotive engines

and

generators, END points out that,

 the Board having found

 that RACT

for Hi—Temp

Aluminum

coatings

6.0

lbs/gal,

it

would

illogical

 to have

 the exception

 apply only to parts destined

for

locomotive

use

and

not

also

for

END’s

other

products.

This

point

is well

 taken

to

 the extent that the amendments

 as previously

proposed are inconsistent with

 respect to Hi—Temp Aluminum

coatings.

 However,

 the Board fails

 to see how this matter

is

in

any way relevant to the

 issue of RACT

 for top coats and final

repair

 coats.

 The appropriate

 resolution

is

 to provide

 that the

Hi—Temp Aluminum exception applies

 to all

END

products,

rather

than

that

the

top

coat

and

final

repair

coat

exceptions

extended

 to all END

products.

This

readily

accomplished

moving previously proposed Section

 215.204(rn)(4)

to

2l5.204(k)(1), such that

 the latter section would

 read:

kg/i

 (lbs/gal)

k)

 Heavy Off—Highway Vehicle Products

1)

In

 Cook,

 DuPage,

 Kane,

Lake,

 Macoupin,

 Madison,

McHenry, Monroe,

St.

 Clair

 and bill Counties

Extreme performance prime coat

 0.42

 (3.5)

Extreme performance

 top coat—air

dried

 0.42

 (3.5)

82—232

—17—

Final

 repair coat—air dried

 0.42

 (3.5)

High—temperature aluminum coating

used at existing diesel—electric

locomotive manufacturing plants

 0.72

 (6.0)

This alteration

 to the amendments as proposed at

 first notice

is

made

in

 the accompanying order.

 A conforming alteration

 to the

final

 item

 in Section 215.204(m)

 is also required to delineate

that

 “all

 other

 coatings” does not include

 the high—temperature

aluminum coating; this alteration is also made

 in the

accompanying order.

RACT at Caterpillar

—

Joliet

Caterpillar

 also contends that 3.5 ‘bs/gal coatings do not

constitute

 RACT

 for its Joliet facility1

 The Agency contends

that

it

 has explored with Caterpillar

 the grounds upon which the

Agency might support Caterpillar’s contention

(H.

at

 51; Dx.

 12d,

l2e,

 121,

 l2j,

 17),

 but that

 it has received only “very limited

information”

 from Caterpillar

(H.

at

 51).

 On this basis the

Agency believes that Caterpillar

 has not made

 a demonstration

sufficient

 to meet the test of alternative RACT

 (H. at

 137,

 155—

6;

Ex

 17).

The Caterpillar

 situation differs

 in one critical

 regard

from that faced by END,

 in that Caterpillar currently uses only

one coating which does not meet

 the 3.5 lb/gal limitation

(H.

at

357).

 Thus,

 Caterpillar would

 seemingly need

 to identify only

one compliant coating

 to meet the requirements

 of the proposed

rule.

The Agency’s principal observation

 relative

 to Caterpillar

is

 an alleged admission by Caterpillar

 that

 it has

 in fact been

supplied with

a

 3.5 lbs/gal compliant

 coating that meets

Caterpillar’s specifications

(H.

at

 317)

 and that various other

compliant coatings are undergoing

 tests

(H.

at

 317).

 The Agency

therefore contends that the question of whether

 3.5 lbs/gal

coatings constitute RACT

 for Caterpillar

 is moot

 (Agency Comment

at

6).

 The Agency further contends that Caterpillar’s testimony

regarding

 the cost

 of add—on control equipment

is

 irrelevant

 “in

light

 of the fact that Caterpiller has located

 a compliant

coating, obviating tne need

 for add—on control”

 (Id.

at

7).

Caterpillar,

 conversely, contends that 3.5 lbs/gal coatings are

not actually available

to

it

(R.

 at 340—50), given that

it

requires

 up to two years

 to test and to obtain approval

 for use

of

 a paint

 after

 it has

 been supplied

 (R. at 313).

11 Unless otherwise

 indicated, discussion

of

 the Caterpillar

facility refers

 to the Caterpillar plant at Joliet.

82—233

—is-

The Board believes that

 the principal shortcoming

in

Caterpillar’s argument

 is that

 it has not countered the

observation

 that other HCHV manufacturers which produce products

similar

 to those of Caterpillar

 are currently using compliant

coatings

 (see PBS Study;

K.

at

 391—3).

 Therefore,

 the Board does

not believe that Caterpillar

 has successfully demonstrated that

compliant RACT coatings for its facility and products are other

than

 3.5 lbs/gal coatings.

 In the context,

 the Board notes that

Caterpillar argues that

 it made

 such

 a demonstration

 as part of

the record developed

 in the R80—5 proceeding.

 However,

 such

earlier demonstration

 is irrelevant

to

 the matter

 at hand,

 since

it

 is the current availability of

 3.5 lbs/gal coatings which

is

at issue.

Geographic Applicability

The Agency proposal would have

 the amended VON limitations

apply within

 a specified ten counties.

 These consist of one

county

 (Macoupin)

 which

 is included solely because

 of its

nonattainment status,

 and nine counties which are included

because they are nonattainment

on

 their own account and/or are

part of major urbanized areas which are nonattainment.

The

latter

 includes the

 six counties which comprise the Chicago urban

area

 (Cook, DuPage,

 Kane,

 Lake, Mchenry,

 and hill)

 and the three

counties which comprise

 the Illinois portion of the St.

 Louis

urban

 area

 (Madison, Monroe,

 and St. Clair).

The Board believes that the Agency proposal

 represents

an

appropriate

 scope of geographic applicability.

 The Board

so

concludes fully mindful o~the questions that have been raised

regarding why pill County

2,

 an attainment county,

 should be

included within

 the scope

 of the proposed

 rule

(H.

at

 294—301,

304—6,

335—7).

required,

minimum,

that

 RACT

rules

 be applied

within counties which are nonattainment for ozone.

 However,

there

 are compelling

 reasons

 that

 the rules also apply

 in some

counties

 in addition

 to those which are classified as

nonattainment.

 The Board believes that

 the most important of

these

 is that emissions in certain attainment counties can impact

on ozone air quality

 in adjacent nonattainment counties due

to

atmospheric

transport

VON

into

nonattainment

areas.

The

significance of the transport phenomenon

 has been extensively

developed

in

 the instant record

(H.

at

16,

 29—40,

 45; Agency

Comment, April

6,

 1987),

well

 prior Board RACT

12 ~1dHenry County

is

 a second attainment county

 in which the

currently proposed rules would

 apply.

 There are no affected

facilities within McHenry County.

 The Caterpillar

 facility is

located

 in hill County.

82—234

—19-

proceedings.

The

Board

does

not

see

that

anything

new

has

been

presented

the

instant

record

which

would

justify

change

the Board’s prior determinations regarding

 the significance

of

transport.

This notwithstanding,

 the Agency advances several additional

reasons for including hill

 County within the list of counties

to

which

the

proposed

rule

would

apply.

These

are

that

‘v~ill County

part

the

Chicago

urbanized

area

(H.

13—15;

21—22;

45);

that emissions reductions

 from hill County have already been

included

 in previous SIP analyses and are necessary

to

demonstrate ozone

 attainment

(H.

at

16;

 23—26;

 45);

 that controls

as proposed are necessary

 to maintain V~illCounty’s attainment

status

(R.

at

 19);

and

 that exclusion of ~ill

 County would place

an even greater burden on the adjacent nonattaininent counties

to

reduce

VON

 emissions in order

to

 reach attainment

 of the ozone

NAASQ

 (Agency Comment, April

6,

at

2).

ENVIRONMENTAL BENEFIT

The first—order environmental benefit which would follow

upon adoption of the proposed

 regulation

is

 a reduction

in

atmospheric loading of VON.

 However,

it

 is difficult

 to exactly

quantify the amount of

 reduction which would be

 expected.

 This

occurs

 for several

 reasons, including uncertainty as

how

many

gallons

 of coating will

 be required by a given facility

 in its

future production,

 the degree

 to which coating

 use will

be

affected by a change

 in coating availability, and the possibility

that

 a given

 facility will achieve compliance

by

 a method other

than use of low—VON coatings.

To

 the best

 judgernent

of

 the Agency emission reductions

expected from Caterpillar

 amount to approximately

 29 tons per

year

(H.

at

 Ill); Caterpillar

 estimates

 this reduction

 to be

 17.9

tons per year

(H.

at

 308;

PC

 #2).

 Reductions to

 be expected from

Dresser

are

significantly

less

certain.

The

Agency

estimates

that

for

various

days

September

1986

Dresser’s

emissions

 exceeded that allowable

 under

 the proposed rule

 at rates from 33

to

 98 tons

 per year

 (Ex.

 15, Attachment

6).

 However, these

emissions apparently include some exceedances

 of the present rule

(H.

at

 49),

 so that

 their elimination could

not

 be fully

attributed

 to adoption of

 the proposed

 rule.

Promulgation of the proposed rule would also provide

a

safeguard against those facilities

 which currently use 3.5

lbs/gal coatings from reverting

 to higher—VON coatings.

 However,

there

 is nothing

 in the record which allows the Board

 to estimate

what atmospheric loadings would

 thus be prevented

 by adoption of

the

proposed

rule.

82—235

—20-

ORDER

The Board hereby directs

 that.

 second notice

of

 the following

proposed amendments be

 submitted

 to the Joint Committee on

Administrative Rules.

TITLE

35:

 ENVIROflMEi~TALPROTECTION

SUBTITLE

AIR

POLLUTION

CHAPTER

POLLUTION

CONTROL

BOARD

SUBCHAPTER

EMISSION

STANDARDS

AND

LIMITATIONS

FOR

STATIONARY

SOURCES

PART 215

ORGANIC

MATERIAL

EMISSION

STANDARDS

AND

LIMITAiIOL~S

SUBPART F:

 COATING OPERATIONS

Section 2l5~.204

 Emission Limitations

 for Manufacturing Plants

No

owner

 or operator

of

 a coating line shall cause

 or allow the

emission of volatile organic material

 to exceed the following

limitations

 on coating materials,

 excluding water, delivered

to

the

coating

applicator:

kg/l

 (lbs/gal)

k)

 Heavy Off—Highway Vehicle Products

1)

 In Cook,

 DuPage,

 hane,

 Lake,

 Macoupin,

 t’ladison,

McHenry, Monroe,

St.

 Clair and will Counties

Extreme performance prime coat

 0.42

 (3.5)

Extreme performance

 tqp coat—air

dried

 0.42

 (3.5)

Final

 repair

 coat—air dried

 0.42

 (3.5)

High—temperature aluminum coating

used at existing diesel—electric

locomotive manufacturing plants

 0.72

 (6.0)

2)

 In the remaining counties

Extreme

performance

prime

coat

0.42

(3.5)

 Extreme performance top coat—air

dried

 0.52

 (4.3)

 Final

 repair coat—air dried

 0.56

 (4.8)

in)

 Existing Diesel-Electric Locomotive Coating Lines

in

Cook County

82—236

1)

 Extreme performance prime coat

 0.42

 (3.5)

2)

 Extreme performance

 top coat—air

—

 dried

 0.52

 (4.3)

Final

repair

coat—air

dried

 0.58

 (4.8)

All

other

coatings,

except

high—

temperature aluminum coating

 0.36

 (3.0)

Section 215.211

 Compliance Dates and Geographic Areas

a)

 Except as otherwise stated

 in subsection

 (b),

 every

major

 owner

 or operator of

 an emission source subject

to

Section 215.204(j),

 (k), a~ (1),

and

(m)

 shall comply

with those sections

 in accordance with the following

dates:

1)

 For Section 215.204(j)

and

 (k)(2) Extreme

performance prime coat and Final repair coat

—

air

dried,

 by December

31,

 1983.

2)

 For Section 2l5.204(k)(l) and

 (m),

 by December

31,

1967.

23)

 For Section 2l5.204(k)(2) Extreme performance

top

coat

—

air

dried,

 in accordance with

 Section

215. 210.

~4)

 For Section 215.204(1),

 by December

31,

 1985.

Section 215.212

 Conipliance Plan

a)

 The owner

or

 operator of an emission source subject

to

Section 2l5.2ll(a)(l)

or

 (23)

 shall

 submit to the Agency

a compliance

 plan on or before August

19,

 1983.

b)

 The owner

 or operator of

 an emission source subject

to

Section 2l5.21l(a)(34)

 shall submit

 to the Agency a

compliance plan on or before October

31,

 1985.

c)

 The owner

 or operator

 of an emission source subject

to

Section 215.211(a)(2)

 shall

 submit

 to the Agenc~~

compliance plan

no

 later

 than August

19,

 1987.

ed)

 The owner

 or operator of

 an emission source subject

to

Section 215.211(b)

 shall submit

 to the Agency

a

compliance plan no

 later

 than December

31,

 1966.

de)

 The owner

 or operator

 of an emission source subject

to

Section 215.211(c)

 shall submit a compliance plan within

90 days after

 the redesignation, but

 in no

 case later

than December 31,

 1986.

82—237

—22—

ef)

 The owner

 or operator

of

 an emission source subject

to

Section 215.211(c)

 shall

not

 be required

 to submit

a

compliance plan

 if redesignation occurs after

 December

31,

 1986.

~)

 The Plan and schedule shall meet the requirements

of

35

Ill.

 Adm. Code

 201.

ORDERED.

Board

 t4embers Jacob D.

 Dumelle and J.

 Theodore Meyer

dissented;

 Board Member Michael Nardulli abstained.

I,

 Dorothy

N.

 Gunn,

 Clerk

of

 the Illinois Pollution Control

Board,

 hereby certify that the above Opinion and Order was

adopted

 on the

/-~

 day of

 l9~7, by

 a vote

of

~‘~2

Dorothy MI Gunn,

 clerk

Illinois Pollution Control Board

82—238