ILLINOIS
POLLUTION CONTROL
BOARD
October
1,
1987
IN THE MATTER
OF:
AMENDMENTS TO 35
ILL. ADM.
)
R86—l2
CODE
211 AND 215, ORGANIC
MATERIAL EMISSION STANDARDS
AND LIMITATIONS,
FOR POLYSTYRENE
PLANTS
ADOPTED RULE
FINAL ORDER
OPINION
OF THE BOARD
(by B.
Forcac3e):
This matter comes before the Board on
a March
11,
1986,
regulatory proposal by the Illinois Environmental Protection
Agency (Agency)
for the control
of organic material emissions
from polystyrene plants.
Hearings were held on October
15,
1986,
in Chicago and on October
16,
1986,
in Joliet,
Comments were
received through January 23,
1987.
On January 16,
1987,
the
Department
of Energy and Natural Resources
(DENR)
filed
a letter
of negative declaration
of economic impact, obviating the need
for further economic study of
the proposed rules.
The Economic
and Technical Advisory Committee of the DENR filed
a concurrence
on January 22,
1987.
The Agency filed
an amended proposal on
April
6,
1987, which entailed non—substantive codification
changes.
On May
28,
1987,
the Board proposed regulatory language for
first notice comment which was published
at 11
Ill.
Reg.
10985,
June
19, 1987.
The statutory 45—day comment period ended on
August
3,
1987.
The Agency filed first notice comments, which
were mailed on August
3,
1987
(P.C.
2).
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
Administrative Rules
(JCAR)
on August
6,
1987.
The Adminis-
trative Code Unit’s comments were incorporated
in the second
notice Order,
Additionally,
the Board deleted one of the
incorporations by reference as unnecessary to this regulation.
JCAR issued
a Certification
of No Objection on September
23,
1987.
On September
24,
1987,
the Board issued an Order directing
the Clerk of the Board to file the rules with the Secretary of
State’s office for final notice publication in the Illinois
The Board acknowledges
the contributions
of David G. Mueller,
hearing officer, in this proceeding.
82—211
—2—
Register.
This Opinion supports the Board’s Order of
September
24,
1987,
This
is one of
a series of
Board actions directed at
promulgating rules implementing Reasonably Available Control
Technology
(RACT)
for the control
of ozone precursors from
existing major stationary sources
(emissions greater
than 100
tons/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 seq.).
Section 172
of the CAA requires that
RACT be
implemented
at existing major stationary sources
in the
non—attainment areas
of those states needing an extension from
the 1982 deadline until
1987 to achieve the air quality standards
for ozone.
Illinois is such
a
state,
having requested the
extension
in its 1979 and 1982 SIP.
The definition of RACT
is contained in
40 CFR 51,
along with
the requirements for
a federally acceptable SIP.
However,
the
specific parameter of what constitutes reasonably available
controls and,
therefore,
the parameters which
the states must
adopt
to ensure that RACT
is
implemented,
are not.
Instead,
the
United States Environmental Protection Agency
(USEPA) publishes
a
series of documents entitled “Control Technique Guideline”
(CTGs).
Each of
the CTGs,
which are summaries of industries
specific case studies, contains the means and the degree of
control which
the USEPA requires the states
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 provision
in CAA found at
Section
110,
113 and 176
(42 USC 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 contain
in the federal
regulations,
but instead,
is articulated
in the “general preamble
for proposed rulemaking and approvable
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 “rule” contained
therein or comparable
rule,
if sources covered by that particular
CTG are within
a state’s non—attainment areas.
A final
CTG for
the manufacture
of high—density polyethylene, polypropylene and
polystyrene resins was published in November
of
1983
(Ex.
3).
The CTG defines RACT
for
the manufacture of high—density
polyethylene, polypropylene and polystyrene resin.
However,
a
search was made of the Agency’s emission inventory system (Total
82—212
—3—
Air System
—
TAS) which found no manufacturers of polypropylene
or high—density polyethylene.
All of the Illinois plants
manufacture polystyrene.
Consequently,
the Agency’s proposed
amendments only cover
this process,
rather than the full scope
of
the CTG.
The
CTG
used
a bulk polymerization plant as
a basis
for its
flow diagram for polystyrene manufacture, but its model plant was
an all—liquid—phase continuous process.
On page
4—1 of
the CTG,
the subparagraph number
3, contains the RACT limitation which
applies
to
the continuous processes.
This limitation
is given as
0.12 kg
of volatile organic material per 1000 kg
of polystyrene
resin produced.
The CTG process description
is for
a “fully
continuous co—polymerization process
for the manufacture
of
pelletized polystyrene
resin from styrene monomer
and
polybutadiene” rubber.
The process
is described as follows:
Styrene,
rubber,
a
catalyst
(in
some
cases),
recycle
styrene,
and
other
ingredients
are
dissolved in feed dissolver tank and pumped to
a
reactor,
where
a
polymerization
takes
place.
Polymer
melt
still
contains
some
unreacted
styrene
and
by—products,
so
it
is
pumped
to
a
devolatilizer
where
these
are
separated
and
sent
to
a
styrene
recovery
unit.
Polymer melt
is
then pumped through an
extrusion
dye
where
it
is
solidified
in
the
form
of
strands,
which
are
pelletized
and
stored.
In
the
styrene
recovery
unit,
the
unreacted
styrene
monomer
is
separated
by
distillation
and
recycled
to
the
feed
dissolver
tank,
Noncondensibles
are
vented
through
a vacuum system.
The heavy components
from the distillation
(the fractions
from
the
bottom
of
the
distillation
column)
are
often
used as
a fuel supplement
in boilers.
The
CTG
lists
four VOM
sources
of
importance
in
its model
plant process.
They are:
1.
The
Feed
Dissolver
(FD),
where
the
styrene
monomer
and
the
polybutadiene
rubber are dissolved
and mixed.
The VOM
emissions come chiefly during filling and
washing
and
normally
are
vented
to
the
atmosphere;
2.
The
Styrene
Condenser
Vent
(SCV),
where
unreacted
styrene
monomer
is
separated
from
the
polystyrene
in
the
vacuum
de—
volatilizer.
The
styrene
is
vented
to
the
atmosphere.
If
a
vacuum
system
is
82—213
—4—
used
(rather
than,
for example, steam jet
ejectors),
and
a
suitable condenser fol-
lows
the
vent,
emissions
are
lower.
The
CTG states that this point is the largest
VOM source.
3.
The
Styrene
Recovery Unit Condenser Vent
(SRtJCV),
where
noncondensible components
are
vented
from
the
styrene
recovery
unit.
4.
The
Extruder
Quench Vent
(EQV)
is
not
a
large
source.
Traces
of
styrene
vapor
are
emitted
as
the
polystyrene
is
being
extruded into strands.
These are usually
removed by
a demister
or
an electrostatic
precipitator.
Recently, USEPA has published additional RACT guidance
to
clarify the sources
to be covered
in this category
(Ex, 4).
To
make certain that the proper sources are covered,
the Agency has
added definitions to Section 211.122 which describe and define
the continuous process,
material recovery section, styrene
devolatilizer unit and styrene recovery unit.
The geographical applicability of the proposed rules
includes eight counties designated non—attainment for ozone, as
well as two counties contiguous
to the Chicago non—attainment
area.
These
two counties, Will and McHenry,
are considered part
of the Chicago urbanized air quality planning region by the
Agency and the
(JSEPA.
Organic emission sources within this
urbanized area are believed to contribute
to the Northern
Illinois—Southwest Wisconsin ozone non—attainment problem.
The Agency conducted
a
review of
its permit files and field
operation inspections in order
to
identify potentially affected
facilities.
It was determined that two presumably affected
facilities were producing polystyrene by
a batch—suspension
process and thus would not be affected
by the Agency’s
proposal,
Four potentially regulated facilities were identified;
three facilities are located
in Will County and one facility
is
in Cook County.
Cosden Oil and Chemical
(Calurnet City, Cook County)
uses a
conventional process as described in the CTG.
Cosden’s poly-
styrene lines have dissolving vessels without controls,
styrene
vent condensers
(SCV) which are attached
to the vacuum system and
extruder quench vents
(EQV) with hoods,
The styrene from the
styrene vent condenser
is recycled
through the dissolving vessel
so that there
is no styrene recovery unit vent.
The finished
polystyrene is made
into pellets which are flash—dried rather
than vacuum—devolatjlized.
Cosc5en
is planning
to close
its
facility and cease operations in 1988
(R.
58).
82—214
—5—
Permits from the Amoco facility
(Joliet, Will County)
indicate that there
is
a styrene condenser vent at the
devolatilizer which
is controlled by a condenser and vacuum
system and
a flow dissolver.
There
is also
a Styrene Recovery
Unit Condenser Vent
in the form of
a condensate recovery tower
with
a condenser and vacuum system.
The permits do not specify
if
an Extruder Quench Vent exists,
Dow Chemical (Joliet, Will County)
has flow dissolvers
in
the form of dissolver tanks,
styrene vent condensers in the
form
of
a monomer separators,
extruder quench vents
in
the form of
exhaust hoods on the nozzles and dies which are fed
a demister
and
a styrene recovery unit condenser vent that sends heavy
material
to the heaters as
fuel.
Mobil Chemical
(Joliet, Will County) has flow dissolvers
(FD),
styrene condenser vents
(SCV) with condensers and vacuum
systems,
a styrene recovery unit condenser vent (SRUCV)
in the
form of
an oligomer stripper and extruder quench vent with
electrostatic precipitators,
All four plants
are within the limitation of
0.12 kg
emissions per 1000 kg
of production from the styrene condenser
vent and the styrene recovery unit condenser vent as proposed
in
Section 215.877 as specified by the CTG.
These emission data are
all based upon engineering calculations which were supplied by
letters
to the Agency.
While
the Agency does not anticipate the
need for testing
to determine compliance,
to have an enforceable
regulation
a testing method must be specified.
Section 215.886
specified Method
25 which
is the standard volatile organic
material control equipment efficiency testing method used
in
other sections
of the Board’s regulations and was used as
the
test method
in emission data cited
in the CTG
(Ex.
3,
pp.
10—14)
and
is cited
as one of the appropriate testing method
in the
USEPA memorandum,
dated September
14,
1984
(Ex.
8),
Because all four
sources appear
to be currently
in
compliance with the proposed Section 215.877,
it
is expected that
there will be no emission reductions
or cost of control to comply
with the limitations.
The CTG, on page 5—25,
states that
“....current industry control
is
in
a transitional period
in which
vacuum pumps
are replacing steam eductors
to produce the required
vacuum
...“.
The plants
in major urbanized areas
of Illinois
have already made
this transition and are thus in compliance with
the RACT standard.
This finding of no economic impact
is
supported by the Department of Energy and Natural Resources’
letter of negative declaration.
The Agency,
in its first notice comments, noted that there
are currently pending proposed amendments to the definition of
“volatile organic material”
(VOM)
in
a separate docket, R86—37.
These proposed amendments would delete the vapor—pressure based
82—215
definition of VOM and would modify the definition proposed
in the
instant docket.
The Agency recommended deleting the definition
contained
in the Board’s proposed rule
in
the R86—l2 docket and
replace
it with the proposed definition in R86—37.
At second
notice,
the Board found that the best course of action was
to
retain
the existing definition of VOM proposed at Section 215.104
in this proceeding and address
the proposed redefinition of VOM
in the R86—37 docket.
First,
there
is no record established
in
the instant proceeding supporting such
a change.
Second,
the
Board had not yet substantively ruled on the merits regarding the
proposed redefinition of VOM pending
in R86—37,
as the record
still remains open.
(See R86—37, Proposed Redefinition of VOM,
Opinion
and Order,
July
16,
1987.)
During
the second notice JCAR review,
the Board agreed to
make
the
following modifications:
(1)
In Section 215.881(a),
the
phrase “if applicable” was deleted from the last line;
(2)
In
Section 215.88l(c),
the phrase
“and Section 215.883” was added
to
the end of the sentence;
(3)
In Section 215.883(a),
the word
“complete” was deleted from the first line;
(4)
In Section
215.883(d),
the citation “(Section 215.877)” was added
to the
third line;
and
(5)
In Section 215.886, the full title of Method
25 was added and the sentence “The incorporation by reference
contains no
later amendments and editions”
was added.
The Board adopts rules regulating organic material emissions
from polystyrene manufacturing plants, as
a
final CTG for this
category has been issued,
sources
in urbanized non—attainment
planning areas have been identified and the rules constitute
RACT.
This action will help fulfill the state’s legal obligation
to demonstrate that existing major stationary emission sources
in
non—attainment areas are subject
to regulations
representing
RACT,
as well as
in regions
that impact non—attainment areas.
IT
IS SO ORDERED
I,
Dorothy
M. Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify
tha~4 the above Opinion was adopted on
the
/~-‘
day of _________________________,
1987,
by
a vote
of
(~—~‘
/~L~
Dorothy M.’Gunn, Clerk
Illinois Pollution Control Board
82—216