ILLINOIS POLLUTION CONTROL BOARD
July 16,
1987
IN THE MATTER OF:
VOLATILE ORGANIC MATERIAL
)
R82-14
EMISSIONS FROM STATIONARY
)
SOURCES:
RACT III
PROPOSED RULE
FIRST NOTICE
OPINION AND ORDER OF THE BOARD (by
B.
Forcade):
This matter
comes before the Board on a series
of proposed
amendments
to 35
Ill. Adm. Code Par 215, Organic Material
Emission Standards and Limitations, for the control
of the
pollutant ozone.
All
of the proposed amendments address some
aspect of the existing regulations controlling volatile organic
material
(“VOM”)
emissions from coating operations.
Amendments
to
35 Ill. Adm. Code 215.204, 215.205 and 215.207 will be
considered
in the instant opinion and order.
Merit hearings on
the proposed amendments were held
on December 2—3,
1985;
March
20—21,
1986; August
4,
1986; August
7,
1987;
September
3—4,
1986;
October
30,
1986;
and November
7,
1986.
Hearings regarding the
Economic Impact Statement
(EcIS)
for Sections 215.204 and 215.207
were held on May
8 and 21,
1987.
Final merit evidence was also
accepted at these hearings.
The record closed on June
30,
1987.
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 stationary sources
in the non—attainment areas of those states needing an extension
from the 1982 deadline until
1987 to achieve the air quality
standard for ozone.
Illinois
is such
a state, having requested
the extension
in
its 1979 and 1982 SIP.
The definition of RACT
is contained in 40 CFR 51,
along with
the requirements for
a federally acceptable SIP.
However,
the
specific parameters of what constitutes reasonably available
controls,
and, therefore, the parameters which
the states must
The Board acknowledges the contributions
of David G. Mueller,
hearing officer,
in this proceeding.
79-210
—2—
adopt
to insure that
RACT
is implemented, are not.
Instead,
the
United States Environmental Protection Agency
(“USEPA”) publishes
a series of documents entitled “Control Technique Guidelines”
(“CTGs”).
Each of the CTGs, which are summaries of
industry
specific case studies, contains the means and the degree of
control which
the USEPA requires the state to adopt categorically
as part of its SIPs
in order
to have an acceptable SIP.
Failure
to adopt rules identical
to those presented in the CTGs, or other
ones demonstrated by the individual state as comparable, can mean
that the state will have an inadequate SIP, which in turn can
trigger the sanction provisions of the CAA found at Sections 110,
113 and 176
(42 U.S.C.A.
7410, 7413, 7506).
While the mandate
for sanctions
is contained
in the CAA, the mandate to adopt the
CTGs or otherwise demonstrate a state rule to be comparable is
not.
It
is not even contained
in the federal regulations,
but
instead is articulated in the “General Preamble for Proposed
Rulemaking and Approval of State Implementation Plan Revisions
for Non—Attainment Areas”
(44 FR 20372).
RACT
regulations controlling VOM emissions from coating
operations were adopted
in the first RACT proceeding, R78—3,4,
RACT I,
(35 PCB 35—75, July
12,
1979).
The rules at issue today,
Sections 215.204, 215.205 and 215.207, address Emission
Limitations from Manufacturing Plants, Alternative Emission
Limitations
and Internal Offset, respectively.
The proposed
amendments
to these sections are intended
to correct certain
alleged deficiencies
in the rules in order
to reflect RACT and,
in part,
to respond to new guidance from the USEPA.
Additionally,
in the course of the proceeding,
several site—
specific amendments were proposed by industrial facilities
in
response to the proposed amendments
to Section 215.204 and
215.207.
Proposed amendments to each section will be addressed
separately, below.
However,
certain conceptual elements of the
proposed amendments are interrelated.
Such interrelationships
will be noted where possible.
I.
Section 215.205:
Alternative Emissions Standards
The Illinois Environmental Protection Agency (“Agency”),
in
its original regulatory proposal initiating
the R82-14 proceed-
ing, sought to amend Section 215.205
as adopted
in R78—3,
4, RACT
I
(Ex. 1).
Section 215.205 provides alternatives to the VOM
limitations
for surface coating operations contained
in Section
215.204,
by specifying emission standards based on add—on control
equipment performance.
Section
215.205 specifies minimum
destruction efficiencies and overall control equipment
efficiencies.
Overall control efficiency
is the product of the
capture efficiency and the destruction efficiency.
When the
existing Section 215.205 was reviewed by USEPA as an amendment to
the SIP,
it found
the rule
to be possibly deficient.
The Agency
agreed
to undertake
a study evaluating achievable capture
efficiency and submit any necessary amendments to Section 215.205
79-211
—3—
to the Board,
thereby, acquiring conditional approval of that
portion of the SIP
(45 FR 1147 at 11482;
Ex.
2).
This study,
prepared by the Radian Corporation, was submitted as Exhibit No.
11.
The Agency’s proposed amendments to Section 215.205 are
based on this study.
Proposed Section 215.205 was inadvertently omitted from the
Board’s August 10,
1984, First Notice Order, due to a perceived
nexus between it and the anticipated amendments
to Section
215.207.
On May 30,
1985,
the Board proposed the Agency’s
amendments to Section 215.205 for first notice publication.
The
Agency further amended proposed Section 215.205 on November
22,
1985
(Ex. 87).
Additional hearings regarding this rule were held
on December
2,
1985, and March 20,
1986, at the request of the
Chicago Association of Commerce and Industry (CAd).
The amendments proposed by the Agency to Section 215.205 are
based on the Radian Study (Ex.
11).
The Agency proposes to
increase the overall control efficiency required at the process
equipment for all types of surface coating facilities regulated
under Section 215.204 from 75
to 81,
except for can coating.
No change is proposed for can coating operations using add—on
controls because the control efficiency at these sources remained
undetermined by the study.
The Radian Study found that
a
reasonably available collection efficiency ranged between 91 and
94 percent for paper coaters.
Based on this,
the 81 percent
overall control efficiency figure
is proposed for the remaining
surface coaters.
The Agency’s amended proposal of November 22,
1985,
adds language to make it clear that the overall emission
reductions to be achieved when afterburners are used are 75
percent for the can coating category and 81 percent for all other
categories
of sources subject
to Section 215.204.
The USEPA has indicated its willingness to accept
regulations consistent with the Radian Study
(Ex.
88,
49 FR
20522).
The USEPA Notice
of Proposed Rulemaking addressed
several “conditions relating to the Illinois SIP” including the
conditional approval of this regulation.
In that notice, USEPA
extended the date for satisfying this condition to July 31,
1984.
CACI opposes the proposed amendment and argues that the
Radian Study provides an insufficient factual basis
for adopting
the Agency’s proposal because the full spectrum of coating
operations were not studied.
CACI argues
that only the paper
coating category was studied and that not all Illinois paper
coaters were
included.
CACI asserts that this provides
an
insignificant sample size
(P.C.
73).
CACI provides no evidence
that the level of control
in the Agency’s proposed amendment is
technically infeasible
or economically unreasonable.
Addition-
ally, CAd
points out the general problem of measuring capture
efficiency and criticizes certain collection efficiency
assumptions made
in the Radian Study regarding paper coaters
outside
of Illinois
(P.C.
73).
79-212
—4—
In response, the Agency presented additional evidence
regarding the propriety
of the 81 percent overall control
efficiency and clarified how efficiencies could be calculated and
measured
in the context
of
a stack test
(Ex.
95(a) and
(b),
Ex.
97(a)
and
(b)).
The Board is not persuaded by CAd’s arguments.
First,
the
results of the Radian Study support the “presumptive norm”
of
81
percent
in the earlier coating CTG.
Second, while
it may be
preferable to work from a state of perfect knowledge,
it
is not
always possible
in the context of
a regulatory proceeding.
It
is
true that the Radian Study did not examine every coating
operation throughout Illinois.
However, that
is not necessary
in
this context.
The Board
is presented with sufficient evidence
that for most coating operations,
81 percent is a reasonable
number.
The Board
is presented with no evidence to the
contrary.
Third, while CACI points out alleged defects
in the
Radian Study, these “defects” are not incorporated in the
proposed amendments
to Section 215.205.
For example, CACI
criticizes the 100 percent capture efficiency assumption in the
Radian Study’s review of non—Illinois coating facilities.
However, the proposed rule only requires 90 percent capture
efficiency.
Fourth, the proposed amendment
to Section 215.205
is
not even as
stringent as the results of the Radian Study could
support.
Focusing on the collection efficiency at Illinois paper
coating facilities,
the study determined that
a reasonably
available collection efficiency ranged between
91 and
94
percent.
The proposed amendment provides an added cushion
through the
81 percent overall efficiency requirement which
translates to only
a
90 percent capture requirement.
As a final
matter,
if there are facilities in Illinois that, due
to special
circumstances, cannot comply with the proposed amendment,
variance and site—specific regulatory relief are available under
Illinois
law.
The Board finds that the proposed amendments
to Section
215.205 constitute RACT and will therefore propose this rule for
first notice.
This action will also help to remedy any possible
SIP deficiencies and avoid sanctions under
the CAA.
II.
Section 215.204
—
Emission Limitations for Manufacturing
Plants
Section 215.204 prescribes VOM emission limitations for an
array of coating process categories.
The limitations of Section
215.204 are expressed
in terms of kg/i or lb/gal of VOM,
excluding water, delivered
to the coating applicator.
Some
of
the coating process categories specify
a transfer efficiency.
The Agency’s proposed amendments to Section 215.204 would require
the exclusion of certain organic solvents exempted from the
definition of VOM from the calculation of the emission
limitations.
This Agency proposal was filed on March 13,
1986,
79-213
—5—
and amended on July 25,
1986.
Hearings
regarding this proposal
were held on March 20,
1986; August
4 and 7,
1986;
September 3—4,
1986; October
30,
1986; and November 7,
1986.
The Department of
Energy and Natural Resources
(“DENR”)
filed
an Economic Impact
Study
(EcIS)
on March 13,
1987
(Ex.
142).
EcIS hearings were
held on May
8 and
21,
1987.
The rationale for the Agency’s proposal to exclude certain
compounds that are specifically exempted from the definition of
VOM involves some review of past RACT regulations and their
development over time.
The original language for Section 215.204
was adopted as part of the PACT
I proceeding (R78—3,4)
and the
definition of VOM at that time did not exclude any compounds
which are liquids at room temperature capable of being used as
solvents
in coatings.
In the original definition of VOM, only
methane and ethane, which are gases at room temperature, were
excluded
as being negligibly photochemically reactive
.
Their
exclusion had no effect on volume calculations under Section
215. 204.
However,
in the
RACT
II proceeding
(R80—5)
and this PACT III
proceeding
(R82-l4), other compounds which are liquids capable of
being used
as coating solvents have been exempted from the
definition
of VOM because they are negligably photochemically
reactive.
Methylene chloride and l,l,l,—trichloroethane were
excluded in RACT II and seven more compounds were excluded
in
RACT III.
The Agency contends that since
these compounds do not
contribute
to emissions of VOM,
it
is necessary to subtract their
volume from the volume of coating
in the same way that the volume
of water
is subtracted from the volume of coating under
the
present regulations.
It
is the Agency’s position that if
this
subtraction were not done,
then the numerical limitations of
Section 215.204 are circumvented.
An unintended inequity exists
which favors coatings using the excluded compounds relative to
water based coatings and high solids coatings
(Ex.
120,
132 and
135).
There are two basic methods by which exempt compounds can be
used to reformulate non—complying coatings,
i.e.,
1)
dilution,
and 2)
direct substitution for VOM.
In
the first method,
the
coating
is simply diluted by adding an exempt compound.
The
Agency contends that it does not make sense to allow greater
emissions from the additional gallons
of coating
applied when the
volume of solvent contributing to emissions of VOM
is the same.
Thus,
in simple dilution by adding an exempt compound,
the exempt
compound should be treated
as water,
i.e.,
as not contributing
to
emissions or coating volume.
In the second method,
exempt compounds are substituted for
solvents which would contribute emissions
of VOM.
Since
the
compounds substituted for original solvent do not contribute
to
emissions
of VOM the facility reduces its VOM emissions.
79-214
—6—
However,
the volume of exempt compounds must still be subtracted
in determining allowable emissions
in order
to achieve
equivalency with the numerical limitation.
The Agency argues
that the exempt compound should be treated as water since there
will be lower VOM emissions as well as lower coating volume.
To
the extent that the emissions have been reduced relative to the
coating volume,
this will
result in what the Agency calls the
proper PACT ratio.
In the case of complete substitution of the
original solvent with exempt compound, the PACT ratio will be
zero since
there are no volatile organic emissions which is again
equivalent with treating the exempt solvents as water.
It is the Agency’s position that retaining the volume of
“excluded” compounds
in the coating volume
is inconsistent with
the limits of Section 215.204,
as they represent the use of
RACT.
The limits of Section 215.204 reflect
a ratio between VOM
emissions and the solids contained in a coating.
For example, an
emission limit of
3.0 lb/gallon represents a coating with
approximately 40 percent VOM and 60 percent solids
for a PACT
ratio of
2:3.
When the volume
of exempt compounds
is included
in
the total volume of coating, the ratio of VOM to solids deviates
from the PACT ratio represented by the numerical limitation.
For
example,
a coating might contain only 40 percent VOM,
30 percent
solids,
and 30 percent exempt compounds.
In this case,
the ratio
of VOM to solids
is 4:3.
Another way of making the comparison
would be to say that for each gallon of solids
in the complying
coating,
2/3 gallon of VOM is allowed.
However, with the second
example,
for each unit of solids,
4/3 gallon of VOM
is allowed
which
is twice as much VOM relative to the solids than would be
allowed by the complying coating.
The Agency contends that any
coating with a ratio of VOM to solids greater than that of the
complying coating would not constitute PACT as defined by the
numerical
limitations in Section 215.204.
In the extreme case of pure dilution, exempt compounds might
be used
to dilute
a formerly non—complying coating so that
it
complies with
the numerical limit of Section 215.204 but with no
reduction in actual VOM emissions from the coating.
This
situation
is the same as that which
led
to the exclusion of water
from the coating volume for purposes of Section 215.204.
In
order
to assure that the limits of Section 215.204 do represent
a
coating equivalent to the RACT limitations, the volume of exempt
compounds must also be
excluded from the total volume
of coating.
The Agency contends that USEPA guidance on this subject is
“quite clear” and cites an article written by USEPA employees,
regarding the appropriate method of calculation, USEPA’s “VOC
Data Sheet
for Suppliers of Paints and Coatings” and an issue
of
USEPA’s “VOC PACT Clearinghouse Newsletter” which address this
issue
(Ex.
120).
It
is the Agency’s position that its proposed
amendment will not result
in any substantive change
in the
emission limitations of Section 215.204,
but merely provides
79-215
—7—
“clarification” on the appropriate method of calculation
(Agency
Response to Order, May 21,
1987).
The primary opposition
to the proposed amendments to Section
215.204 has come from the Duo Fast Corporation
(“Duo Fast”).
While Duo Fast and the Agency eventually came
to agreement re-
garding appropriate emission limitations for coatings for the
power driven fastener industry,
it
is worthwhile reviewing Duo
Fast’s arguments.
Essentially, Duo Fast contends that the
Agency’s proposal oversimplifies the realities of coating
chemistry and formulation.
The consequence
of emission
limitations based on this simplified view of coatings
is that
compliance coatings are technically infeasible to apply,
at least
in the power driven fastener industry.
More specifically, Duo
Fast contends that there
is no known coating chemistry that can
achieve compliance with the proposed change
(R.
3390).
The Agency proposal was criticized
for only “partially”
recognizing that water’s mass and volume should
be excluded from
the regulations pertaining
to organic materials.
Also, Duo Fast
contends that the Agency’s testimony
is flawed by stating a
“ratio”
of emissions to solids exists as
a part of RACT.
According
to the Duo Fast argument, the amendment ignores the key
term:
“delivered to the coating applicator.”
According to one
witness,
the Agency devised its ratio assuming that the coating
is delivered to the applicator
in
a solvent—free state.
“The
true
volume
of
the
solvated
polymer
is
physically
and
significantly
different
as
delivered
to
the
Coating
Applicator.
After
application to the substrate to be coated,
the
mechanism
of
solvent
release
occurs
and
solvent
release
continues
until
it
is
com-
plete.
In
a
coating
operation,
generally
a
film
is
formed
which
represents
both
volume
and
mass
of
solids.
It
is
critically
im-
portant
to be aware that for different organic
polymeric
resin
systems,
there
are differing
solvent release mechanisms and solvent release
rates.
How
is
it valid
to make an
‘after
the
fact’
assumption
regarding
volume
solids ap-
plied
in the state of
a solvent free condition
when
the
Rule
makes
a
very specific require-
ment
specifying
the
coating
condition
as
‘delivered
to
the Coating Applicator’.”
(R.
4659—4660).
Duo Fast also contends that the coating listed
in the
Miscellaneous Metal
Parts and Products
of 4.3 lb VOM per gallon
is impossible
to formulate and
to utilize on Duo
Fast equipment
or any other
known technology
of similar nature.
Since Duo Fast
is required
to use the cellulose ester
resin polymer system
in
79-216
—8—
its manufacturing process, the coating that would be required to
meet the Agency’s description would be impossible to apply
(R.
4660—4661).
Ultimately, Duo Fast and the Agency came
to agreement that
the power driven
fastener industry, and Duo Fast in particular,
presented
a unique situation that justified special emission
limitations.
Duo Fast and the Agency proposed
a further
amendment to Section 215.204, which provides RACT limitations for
power driven fastener coating.
This proposal will
be addressed
in Section III of this opinion, further below.
However,
the net
effect of this amendment
is to ameliorate any adverse impact to
Duo Fast as a result of the Agency’s proposal to exclude exempt
solvents from the calculation of emission limitations.
It appears from the record before the Board that
the
Agency’s proposal
to exclude exempt solvents from the calculation
of Section 215.204 emission limitations
is an appropriate method
of determining VOM emissions for
a particular coating.
The
proposed amendment will ensure that dilution with exempt solvents
will not be used as
a method of compliance,
just as dilution with
water
is currently prevented.
Direct substitution of VOM
solvents with exempt solvents will continue to be
a permissible
method of formulating compliant coatings.
Regarding Duo Fast’s conceptual arguments in opposition to
the proposed amendment,
the Board makes
the following
observations.
It appears that for Duo Fast’s specialized coating
process,
the Agency’s proposal would create serious compliance
problems
in terms of the practical realities of applying such
a
coating.
However, this appears to be a unique situation not
necessarily experienced by the majority of coaters.
It appears
that the unique circumstances of the power driven fastener
industry,
and Duo Fast in particular, will be adequately
addressed by the special PACT emission limitation jointly
proposed by Duo Fast and the Agency.
The record indicates that
only two facilities would have their compliance status affected
by the Agency’s proposal.
Both Duo Fast and Classic Finishing
Company have worked with the Agency and have formulated or are
in
the process of
formulating specialized emission limitations that
reflect PACT for their unique coating processes.
Consequently,
the Board believes that the Agency’s proposal
is generally a
sound and improved method of determining emissions from
coatings.
In limited circumstances,
it may create technical
feasibility problems for certain types of coating applications.
However, those rare situations are being addressed through
specific emission limitations tailored to the unique coating
process.
The practical effect of
the Agency’s proposal will be
to
change the emission limitations currently in Section 215.204 for
those coaters who utilize exempt solvents.
While the amendment
79-217
—9—
clarifies the calculation method,
it
is also apparent that some
of the applicable coating limitations are substantively
changed.
However, this substantive change only affects the
compliance status
of two facilities, which will
be the subject of
specialized limitations.
Therefore,
the actual economic impact
of the proposal, when viewed
in total,
is very limited.
The
proposed amendment clarifies and tightens the calculation of
emission limitations
for coaters.
It is hoped that this
amendment will close
a potential “loophole”
in determining
compliance under Section 215.204.
The Board finds that the proposed amendments to Section
215.204 constitute PACT and will therefore propose this rule for
first notice.
This action will help to remedy any possible SIP
deficiencies and avoid sanctions under
the CAA.
III. Section 215.204(j)
—
Power Driven Fastener Coating
During this proceeding, Duo Fast was
identified as
potentially adversely impacted by the Agency’s proposed amend-
ments to Sections 215.204 and 215.207.
Duo Fast participated
extensively in the hearings and presented testimony in opposition
to the general principles embodied in the Agency’s proposals,
as
well as testimony demonstrating that the proposal was not
technically feasible, economically reasonable or PACT for Duo
Fast.
At the close
of the merit record,
the Agency proposed
amendments
to Section 215.204(j), which would provide special
emission limitations
for power driven fastener coating that
reflect PACT for this subcategory of miscellaneous metal coating
(Agency Motion to Further Amend, December
10,
1986).
Duo Fast,
in its final comments
in this matter, advocates adoption of the
Agency’s proposed 215.204(j)
limitations
in the event the Board
decides to adopt the Agency’s proposal
to exclude exempt solvents
from the calculation of emission limitations in 215.204 and
215.207
(Closing Statement of Duo Fast Corporation, June
30,
1987).
Duo Fast operates
a facility in Franklin Park
(Cook County),
which manufactures a multitude of power driven fasteners, nails
and power driven fastener tools.
Duo Fast employs approximately
1,100 people at this facility.
Duo Fast’s distinct and unique
coating operations are carried out on
a large number of
conventional staple making machines and five newer multi—wire
staple making machines.
(The term “staple” also includes certain
brad and finish nail fasteners.)
The conventional machines apply
small amounts (i.e.,
less than 1/2 pound of organic
emissions/hour,
total)
of bonding, lubricity and withdrawal
resistance coatings at
three separate stations.
The multi—wire
machines apply somewhat larger amounts of a single multi—purpose
coating.
The total organic emissions
of the conventional
machines are approximately 140 tons/year at present
(see Emission
Report from Duo Fast,
dated October
17,
1986, Attachment 10).
79-218
—10—
The total organic emissions of multi—wire machines are presently
about
50 tons/year and are limited to 80.3 tons/year by a permit
condition imposed
to establish non—applicability of
35
Ill. Adm.
Code Part
203.
In the absence of site—specific consideration for
Duo Fast,
the changes proposed by the Agency to Section 215.204
would result in non—compliance of certain Duo Fast coating
operations.
Duo Fast presently appears
to be in line—by—line compliance
with the current emission limitations of Section 215.204 through
the use of combination materials which perform both adhesive and
coating functions and reformulation by substituting non—photo—
chemically reactive solvents for VOMs (Closing Statement of Duo
Fast Corporation, June 30,
1987).
Before the development of
combination materials, Duo Fast relied on the existing internal
offset rule to achieve compliance.
Duo Fast presented evidence of its efforts,
over the years,
to reduce organic emissions by reformulation of its coatings, as
well as process changes
(Exs.
92, 93,
125).
The record also
contains considerable information on the uniqueness of Duo Fast’s
staple making equipment,
its coating operation and the functions
which the coatings serve,
as compared to other miscellaneous
metal parts and products coating operations.
Unique features
include the high degree of automation,
low rates of coating
application per applicator, high transfer efficiency,
limited
curing time,
lack of enclosure,
role of bonding coating and need
for immediate function,
end use of product, and specialization of
coating function
in end use of product.
Considering these
technological constraints, Duo Fast appears
to have made
substantial efforts
to reformulate coatings to comply with the
present Section 215.204(j)
by the principal means available,
use
of exempt organic compounds.
However, the limit of organic
emission reduction achievable with this means
also seems to have
been reached
(P.C.
99).
Duo Fast investigated compliance through
the use
of add—on
control equipment
as an alternative to further reformulation of
coatings to meet the new limitations that would be applicable
under
the Agency’s proposed amendment to Section 215.204.
Duo
Fast had a detailed “Control Equipment Evaluation” prepared by
Yates
& Auberle,
Ltd.
(Y&A).
The evaluation considered combined
and separate control
of conventional machines and multi—wire
machines using a catalytic oxidizer,
a thermal oxidizer with high
efficiency heat transfer and an adsorption—oxidizer system.
Y&A
estimated that the cost effectiveness of the control equipment
necessary to achieve
compliance would be $10,000/ton.
The Agency
and EcIS both adjusted this figure but still
came to the
conclusion
that the cost was well above the levels usually
79-219
—11—
accepted as RACT (approximately $2,000/ton)*
(P.C.
99,
Ex.
142).
Additionally,
there are uncertainties regarding the actual
technical feasibility of the control systems costed—out by Y&A
in
its study.
The emissions capture system may have to be revised
after
a pilot study, which could increase the cost of compli-
ance.
The extensive use of methylene chloride will
lower the
organic emissions cited
in the Y&A study.
Costs will also be
added to the Y&A estimates to account for scrubbing of hydrogen
chloride
in the gas stream following the afterburner.
The Agency and Duo Fast also looked to similar facilities
throughout the country
in order to determine what PACT might be
for this specialized industry.
Other major companies in the
power driven fastener industry appear to have been less
successful than Duo Fast in complying with PACT regulations and
are the subject of state and federal enforcement actions and
consent decrees setting stringent compliance deadlines (P.C.
99).
Many
of these compliance deadlines have been unattainable
(Closing Statement of Duo Fast Corporation, June 30,
1987).
The Agency has proposed
a revision to 35 Ill.
Adm. Code
215.204(j)
to specifically address organic material emissions
from Duo Fast’s coating operations.
(Agency Motion to Further
Amend 35
Ill. Adm. Code Sections 211.122 and 215.204, December
10,
1986.)
This revision proposed specific emission limits,
in
pounds of organic material per gallon of coating,
for four
distinct and unique coating operations at Duo Fast.
It also
includes
a reference for nail coating, Duo Fast’s other type of
operation, to present limits applicable
to miscellaneous metal
parts and products coating.
The proposal does not identify Duo
Fast by name,
but rather applied to “Power Driven Fastener
Coating.”
Duo Fast
is believed to be the only facility engaged
in such coating
in Illinois,
as the term is defined.
The Board will propose,
for first notice,
the proposed
amendments
to Section 215.204(j), which would provide special
limitations reflecting PACT for the power driven fastener
industry.
Duo Fast has made a sho~ingthat the limitations of
Section 215.204 as modified by the Agency’s proposal to exclude
exempt solvents would not be PACT for
the power driven fastener
industry in Illinois.
The Board believes that the
record
adequately supports special limitations that should be federally
approvable.
The Board notes that this RACT cost—effectiveness figure
is
a
rough estimate that does vary.
Cost—effectiveness
for RACT has
been expressed within the range
of $1,800
—
$2,500/ton by various
sources.
79-220
—12—
IV.
Section 215.204(c)
—
Specialty High Gloss Catalyzed Coating
Classic Finishing Company
(“Classic”) was
identified,
relatively late in this proceeding,
as having its compliance
status affected by the Agency’s proposal
to exclude exempt
solvents from the emission limitation calculations
in Section
215.204.
Classic operates a facility in Chicago
(Cook County)
which provides specialty finishes to preprinted products on a
job—shop basis.
These coating and lamination processes fall into
the category of paper
coating.
Classic operates four solvent—
borne top coating lines and two UV coating lines.
Classic has
achieved compliance with existing Section 215.204 through
reformulation of its solvent—borne top coating to contain 1,1,1—
trichioroethane,
an exempt solvent,
and through the use, where
possible,
of solventless
tJV coating.
Classic presented evidence of its research and development
efforts to date which demonstrate that little further VOM
emission reductions are possible through further coating
reformulation or switching to UV coating.
Water—borne coatings
have been investigated but are not available for this specialized
category of paper coating
(R.
4840—4845).
Add—on controls were
investigated but even preliminary engineering costs would exceed
the rough benchmark of
$2,000/ton which
is commonly used as
a
PACT guideline
(R.
4935).
Add—on controls would reduce VOM
emissions by approximately three tons/year at a minimum cost of
$8,000 to $10,000 tons/year
(R. 4928—4931).
The Agency’s
proposal
to exclude exempt solvents from the calculation of
Section 215.204 limitations would mean that over 40
of Classic’s
coating operations would be out of compliance with no realistic
method available to continue operations
(P.
4843—44).
Because of the specialized nature of Classic’s coating
operations and job—shop business, recent significant VOM
reductions through reformulation and UV coating,
the limited
prospect
of further significant emission reductions,
the high
cost
of add—on controls and the relatively small amount of
emissions at issue
the Agency proposed special VOM emission
limitations for “Specialty High Gloss Catalyzed Coating”
(Agency
Motion to Further Amend, December
10,
1986).
Classic
is believed
to be
the only facility engaged
in such coating
in Illinois, as
this term is defined.
The Agency and Classic both agree that
these proposed amendments to Section 215.204(c)
better reflect
PACT for this special subcategory of paper coating.
The Board will propose, for first notice,
the amendments
to
Section 215.204(c). which would provide special limitations
reflecting RACT for
the specialty high gloss catalyzed coating
industry.
Classic has made a showing that the limitations of
Section 215.204
as modified by the Agency’s proposal to exclude
exempt solvents would not be RACT for this special category of
79-221
—13—
paper coating
in Illinois.
The Board believes that the record
adequately supports special
limitations that should be federally
approvable.
V.
Section 215.207
—
Aggregation of Emission Sources
The Agency proposes to amend existing Section
215.207,
Internal Offsets, by changing the method
of calculation
of VOM
from a volumetric basis to a solids basis,
as well as
to
generally revise the rule.
The Agency proposes to amend Section
215.207
by:
1) changing
the heading of the section to make
it
more descriptive of the actual intent and to avoid confusion with
offsets under Part 203 and the Prevention of Significant
Deterioration
(“PSD”) program;
2)
substituting language parallel
to Section 215.205
in paragraph
(a)
in order
to reference the
emission limitations of Section 215.204;
3) clarifying language
and use of abbreviations;
4)
including
a formula for converting
from lb/gal
(from Section 215.204) to lb/gal solids,
for the
purposes of calculating compliance to Section 215.207; and 5)
amending the definition of the symbols B and
n as used
in the two
formulae.
It
is worthwhile to briefly review the history of Section
215.207 and the genesis of the Agency’s proposal.
The internal
offset rule was adopted in the PACT
I (R78—3,4) proceeding and
was conditionally approved by USEPA as
a SIP revision
(45 FR
11482,
Ex.
2).
However, USEPA subsequently proposed
to
disapprove the rule after
finding an error
in the specified
equation
(50 FR 28226,
Ex.
89, Attachment
1).
The Agency
originally proposed to revise Section 215.207 in the original
proposal which initiated the instant proceeding on June 29,
1982
(Ex.
1).
The amendments to Section 215.207 were originally
proposed to make the Illinois regulation consistent with federal
policy.
IJSEPA guidelines indicated a problem in calculating
equivalence when control equipment,
rather than high solids or
water—based coatings, was used to achieve compliance.
Therefore,
the amendments required calculation of emissions expressed in
terms of the mass of VOM per volume of solids consumed.
Early
in the proceeding,
the Agency found no plants using
Section
215.207 as
a basis for compliance that would exceed the
limitations based on the revised calculation.
However, sub-
sequently the Agency determined that there might be plants which
would not comply with
the amended rule,
if adopted.
Consequent—
ly,
the Agency recommended
in its comments on the Board’s First
Notice Order of August,
1984,
that the Board defer action on this
section until the data on affected plants was reviewed
(P.C.
57).
On August 23,
1985,
the Agency filed
a motion to reopen the
record concerning,
among
other sections, Section 215.207, after
the Agency’s search for affected plants had
been completed
(Ex.
86).
On November
22,
1985, the Agency further amended proposed
79-222
—14—
Section 215.207
(Ex. 87).
Hearings were held on the Agency’s
amended proposal on December
2,
1985;
March 20—21,
1986; August
4
and
7,
1986; September
3—4, 1986;
October
30, 1986;
and November
7,
1986.
The DENR filed an EcIS addressing,
in part,
proposed
amendments to Section 215.207 on March
13,
1987
(Ex.
142).
EcIS
hearings were held on May
8 and 22,
1987.
Section 215.207, both existing and as proposed to be
amended, provides an alternative means of compliance with the
emission limitations of Section 215.204 by offsetting overcomply—
ing VOM emission sources with undercomplying VOM emission
sources.
For the purposes of illustration, suppose a coating
facility operates two coating lines.
The first line is able to
“overcomply,” i.e.,
it not only achieves, but surpasses the
applicable VOM emission limits and thus generates an emissions
credit.
The second coating line is not
in compliance but
operates
in excess of the applicable VOM standards.
Under an
offset,
bubble or aggregation rule, the facility may be able to
come into compliance by balancing its “credits”
for overcom—
pliance against the excess VOM emissions from its undercomplying
coating line.
Section 215.207 allows an alternative means of
compliance with Section 215.204 by aggregating emissions across
different coatings and coating lines at each facility.
Section 215.207 provides the framework, restrictions and
equations for calculating compliance through offsetting or
aggregating sources.
Emission credits can be generated from
overcomplying coatings, add—on control equipment or even
elimination of certain VOM emission ge.nerating sources within
a
facility.
Section 215.207 affects
a variety of sources and
is
implemented
in a unique way at each facility.
The rule allows
a
certain flexibility in complying with the emission limitations of
Section 215.204 and represents a compromise between line—by—line
compliance and technical and economic feasibility.
At the state
level, Section 215.207 relates back
to the limitations
in Section
215.204 which represent
PACT
for various coating categories.
At
the federal level,
the USEPA considers compliance under Section
215.207
to be within the scope of the federal Bubble Policy.
Compliance plans
and permits for facilities located in areas
designated as non—attainment for ozone which are based on Section
215.207 must be submitted as SIP amendments to IJSEPA.
The
general rule itself
is also a part of the SIP and any amendment
to the general rule requires amending the SIP.
The Agency,
in support of its proposal, contends that USEPA
has found existing Section 215.207 to be deficient because of
the
way in which the determination of allowable emission is made,
The present rule contains a mathematical formula based on the
total—volume of
coating used, as distinguished from solids
present in the coating.
Technically, this deficiency causes the
rule to give results
in certain circumstances which are not
equivalent to
the emission limitations of Section 215.204.
This
79-223
—15—
is because the total—volume calculation does not consider the
two—fold effect of the limits of Section 215.204.
Not only do
these limits reduce the amount of organic material
in each gallon
of coating,
but they also may reduce the total gallons of coating
which must
be
used.
The less organic material
or solvent
contained in
a coating, the more pigment,
resin, binders,
etc.,
commonly known as solids.
Thus, fewer actual gallons of
a
compliance coating will probably be needed than were used before.
The substantive change
in the proposed rule
is intended to
correct this deficiency in calculation method.
This correction
also necessitates the addition of a formula
to convert the limits
of Section 215.204 into equivalent solids—basis limits,
and
development of the recordkeeping requirement to include data on a
solids—basis.
Section 215.207 has been considered deficient by USEPA for
some period of time.
The
rule was originally submitted to the
USEPA
in
1979,
as part of Rule 205(n).
Upon submission of the
rule
(now codified as 215.207)
as a part of proposed PACT II, the
USEPA clarified the true deficiency of the rule:
the equation
concerning the internal offset provision contained the error
previously discussed.
Hence,
in order for the rule to be
approved as
a SIP revision,
it must conform with
the consistently
endorsed method of solids—based calculations.
A further justification of the proposed amendment is that
the volume—based calculations now
in place may lead to emissions
levels which are also potentially inequitable.
The solids—based
calculations provide allowable emissions which are fixed and do
not change with differing compliance options
(reformulation,
control equipment,
etc.).
However,
it may be the case that the
total—volume method will yield emissions limits which are not
equivalent
to those specified
in Section 215.204, depending upon
the compliance option chosen.
Hence, the potential
for inequity
is present,
in that facilities choosing certain compliance
options may be allowed higher emissions than similar facilities
choosing less “advantageous” options.
Many facilities use Section 215.207 throughout the state.
However, only a handful of
facilities were identified as possibly
having their compliance status affected by the proposed change
from volumetric to solids calculation.
During
the course of
these proceedings, Allied Tube and Conduit of Harvey, which had
been identified as having its compliance status affected by the
proposed rule change, achieved
a technological breakthrough that
results
in line—by—line compliance.
Consequently, this facility
is no longer affected by the proposed change.
Duo Fast utilized
existing Section 215.207
to achieve compliance and would have
been affected by the proposed change.
However,
through a com-
bination of
a technological break
in the area of
“cornbi—cerrients”
and the special proposed emission limitations
for power driven
79-224
—16—
fastener coating, Duo Fast
is no longer affected by the proposed
amendment.
The Minnesota Mining and Manufacturing Company
(3M) utilizes
Section 215.207 to achieve compliance at its Bedford Park
facility.
3M believes it can comply with
the solids—basis calcu-
lation but has proposed a site—specific rule as an alternative to
proposed Section 215.207
(Ex. 98).
By joint motion dated June
30, 1987,
the Agency and 3M have requested that the record remain
open until July 30, 1987, regarding the 3M site—specific
proposal.
Consequently, the Board will defer action on 3M’s
proposal pending further informational development by the Agency
and 3M.
The impact of proposed Section 215.207 on the 3M will
not be addressed
in the instant opinion and order, but will be
similarly deferred.
The primary argument against the solids—basis type of
calculation
is made by Duo Fast regarding the nature of polymer
coatings wherein the solids are inextricably tied
in with the
solvent
(either VOM or exempt).
Based on this,
the Duo Fast
testimony of D.J. Kurr
(R.
4659—4660)
poses the question:
“How
is
it valid
to make an
‘after
the fact’
assumption
regarding volume
solids
applied
in
the state of
a solvent free condition when the
Rule
makes
a
very
specific
requirement
specifying
the coating condition as
‘delivered
to the Coating Applicator’?”
Duo Fast has presented
a compelling point,
as the solids based
calculation would apply to
its unique polymer coatings.
However,
the proposed special power driven fastener emission limitations
proposed today appear to take this uniqueness into account.
There is no evidence in the record that the other facilities that
utilize Section 215.207 will
be similarly affected by the
proposed change.
The record does indicate that since the solvent
is finally released from the substrate on curing or drying, the
Agency’s arguments
for
a solids—based calculation are still
valid.
In terms of emission of VOM, the solids—based
calculations appear preferable to the existing volumetric method.
The Board finds that the proposed amendments to Section
215.207 corrects an error
in the existing rule and results
in an
accurate calculation of RACT limitations.
The Board proposes
this rule for first notice comment.
This action will help to
remedy any possible SIP deficiencies and avoid sanctions under
the CAA.
In reviewing the Agency’s proposal,
the Board wishes to
note certain potential problems
in the current drafting of the
rule.
In the proposed Section 215.207(a),
it states that
“methods or procedures used to determine emissions of VOM under
this Section shall be approved by the Agency.”
These methods and
79-225
—17—
procedures are not specified and need to be addressed by the
Agency.
The Board has concerns regarding the JCAR approvability
of this language.
Section 215.207(a) also uses the term
“selected coating
lines” to replace the term “all coating
lines.”
It
is not clear what the basis of the selection is or
who selects the lines that will be subjected to the limitations
of the section.
This topic needs
to be addressed as well by the
Agency.
Based on the May 20,
1987, Agency Response to Hearing
Officer Order,
the definition for the term R~in Section
215.207(c)
should be changed as follows
to be consistent with the
proposed interpretation of gallon of coating
in Section 215.204:
R1
=
the applicable volatile organic material
emission
limit
pursuant
to
Section
215.204,
for
a coating
in Kg/l (lb/gal)
Additionally, the Board believes that adding “volatile
organic material” before the word “emissions”
in the definitional
terms EArl, ~
R~and S~would help to clarify those terms
in
Section 215.2U7tc).
The Board solicits comments
on these
issues.
ORDER
The following amendments
to 35 Ill. Adm. Code Parts 2ll.and
215 are directed to the Secretary of State for First Notice
publication
in the Illinois Register.
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
C:
EMISSION STANDARDS AND LIMITATIONS
FOR STATIONARY SOURCES
PART 211
DEFINITIONS AND GENERAL PROVISIONS
SUBPART A:
GENERAL PROVISIONS
Section
211.101
Incorporations by Reference
211.102
Abbreviations and Units
SUBPART
B:
DEFINITIONS
Section
211.121
Other Definitions
211.122
Definitions
79-226
—18—
Section 211.122
Definitions
“Power Driven Fastener Coating”:
The coating of nail,
staple,
brad and finish nail fasteners where such
fasteners are fabricated from wire or rod of 0.254 inch
diameter or greater, where such fasteners are bonded
into coils or strips,
such coils and strips containing
a
number
of such fasteners, which fasteners are manufac-
tured_for_use_in power
tools,
and which fasteners must
conform with formal standards for specific uses estab—
lished by various federal and national organizations
including Federal Specification FF—N—lO5b of the General
Services Administration, Bulletin UM—25d of the U.S.
Department of Housing and Urban Development
—
Federal
Housing Administration and the Model Building Code of
the Counsel
of American Building Officials,
and similar
standards.
For the purposes of this definition,
the
terms
“brad”
and “finish nail”
refer to single leg
fasteners fabricated
in the same manner as staples.
The
application of coatings to staple, brad,
and finish nail
fasteners may be associated with the incremental forming
of such fasteners
in
a cyclic or repetitious manner
(incremental fabrication)
or with the forming
of
strips
of such fasteners as
a unit from a band
of wires
(unit
fabrication).
“Specialty High Gloss Catalyzed Coating”:
commercial
contract finishing of material prepared for printers and
lithographers where
the finishing process uses
a
solvent—borne coating, formulated with
a catalyst,
in a
quantity of no more than 12,000 gallons/year
as
supplied, where
the coating machines are sheet fed and
the coated sheets are brought
to a minimum surface
temperature of 190
F., and where the coated sheets are
to achieve the minimum specular reflectance index of
65
measured at
a
60 degree angle with
a gloss meter.
(Source:
Amended at
Ill.
Reg.
,
effective
TITLE
35:
ENVIRONMENTAL PROTECTION
SUBTITLE
B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL BOARD
SUBCHAPTER
C:
EMISSION STANDARDS AND
LIMITATIONS FOR STATIONARY SOURCES
PART 215
ORGANIC MATERIAL EMISSION STANDARDS
AND
LIMITATIONS
SUBPART A:
GENERAL
PROVISIONS
79-227
—19—
Section
215.100
Introduction
215.101
Clean—up arid Disposal Operations
215.102
Testing Methods
215.103
Abbreviations and Conversion Factors
215.104
Definitions
215.105
Incorporations by Reference
215.106
Afterburners
SUBPART B:
ORGANIC EMISSIONS FROM STORAGE
AND
LOADING OPERATIONS
Section
215.121
Storage Containers
215.122
Loading Operations
215.123
Petroleum Liquid Storage Tanks
215.124
External Floating Roofs
215.125
Compliance
Dates
and
Geographical
Areas
215.126
Compliance
Plan
SUBPART C:
ORGANIC EMISSIONS FROM
MISCELLANEOUS EQUIPMENT
Section
215.141
Separation
Operations
215.142
Pumps
and
Compressors
215.143
Vapor
Blowdown
215.144
Safety
Relief
Valves
SUBPART
E:
SOLVENT CLEANING
Section
215.181
Solvent
Cleaning
in
General
215.182
Cold Cleaning
215.183
Open Top Vapor Degreasing
215.184
Conveyorized Degreasing
215.185
Compliance Plan
SUBPART F:
COATING OPERATIONS
Section
215.202
Compliance Schedules
215.204
Emission Limitations for Manufacturing Plants
215.205
Alternative
Emission
Limitations
215.206
Exemptions
from
Emission
Limitations
215.207
~rt~ern~
Off~e~ Compliance
by
Aggregation
of
Emission
Sources
215.208
Testing
Methods
for
Solvent Content
79-228
—20—
215.209
Exemption
from
General
Rule
on
Use
of
Organic Material
215.210
Alternative
Compliance
Schedule
215.211
Compliance
Dates
and
Geographical
Areas
215.212
Compliance
Plan
215.213
Special
Requirements
for
Compliance
Plan
Section 215.204
Emission Limitations for Manufacturing Plants
No owner or operator
of
a coating line shall cause or allow the
emission of volatile organic material to exceed the following
limitations
on coating materials, excluding water and any
compounds which are specifically exempted from the definition of
volatile organic material pursuant to this Part, delivered to the
coating applicator:
a)
Automobile
or
Light
Duty
Truck Manufacturing Plants
1)
In
Cook
County
kg/i
lb/gal
Prime
coat
0.14
(1.2)
Prime
surfacer
coat
0.34
(2.8)
(Board
Note:
The prime surfacer coat limitation is
based
upon
a
transfer
efficiency
of
30
percent.
The
prime
surfacer
coat
limitation
shall
not apply
until
December
31,
1982.)
Top
coat
0.34
(2.8)
(Board
Note:
The
limitation
is
based
upon
a
transfer
efficiency
of
30
percent.
The
top
coat
limitation
shall not apply until December 31,
1985.)
Final
repair
coat
0.58
(4.8)
(Board
Note:
The limitation shall not apply until
December
31,
1985)
2)
In
Boone
County
Prime
Coat
0.14
(1.2)
Prime
coat
surfacer
0.34
(2.8)
Top
coat
0.34
(2.8)
(Board
Note:
The
top
coat
limitation
shall
not
apply
if
by
December
31,
1984,
a
limitation
of
0.43
kg/i
(3.6
lb/gal)
is
achieved
and
the
top
coat
is
applied
with
a
transfer
efficiency
of
not less than
55 percent and by December
31,
1986,
the top coat
is applied with
a transfer efficiency of not less
than 65 percent)
79-229
—21—
Final
repair coat
0.58
(4.8)
3)
In the remaining counties
Prime
coat
0.14
(1.2)
Prime
surfacer
coat
0.34
(2.8)
Top
coat
0.34
(2.8)
Final
repair coat
0.58
(4.8)
b)
Can Coating
1)
Sheet basecoat and
Overvarnish
0.34
(2.8)
2)
Exterior basecoat
and overvarnish
0.34
(2.8)
3)
Interior body spray
coat
0.51
(4.2)
4)
Exterior end coat
0.51
(4.2)
5)
Side seam spray coat
0.66
(5.5)
6)
End sealing
compound coat
0.44
(3.7)
c)
Paper Coating
1)
All paper coating except
as provided
in sub
section
(c)(2)
0.35
(2.9)
2)
Specialty
High
Gloss
Catalyzed Coating
0.42
(3.5)
(Board Note:
PI’te These limitations shall not apply to
equipment used
for both printing and paper coating)
d)
Coil Coating
0.31
(2.6)
e)
Fabric Coating
0.35
(2.9)
f)
Vinyl Coating
0.45
(3.8)
g)
Metal
Furniture Coating
0.36
(3.0)
h)
Large Appliance Coating
0.34
(2.8)
(Board Note:
The limitation shall not apply to the use
of
quick—drying
lacquers
for
repair
of
sàratches
and
nicks
that occur during assembly, provided that the
volume of coating does not exceed 0.95 liters
(1 quart)
in any one eight—hour period)
79-230
—22—
i)
Magnet Wire Coating
0.20
(1.7)
j)
Miscellaneous Metal Parts
and Products Coating
1)
Clear coating
0.52
(4.3)
2)
Air dries coating
0.42
(3.5)
3)
Extreme performance
coating
0.42
(3.5)
4)
Power driven fastener coating
A)
Nail coating
Refer to limits
in
(j)(l),
(2),
(3)
and
(5)
B)
Staple, brad and fin-
ish nail unit fabri-
cation bonding
coating
0.64
(5.3)
C)
Staple, brad and fin-
ish nail incremental
fabrication lubri-
city coating
0.64
(5.3)
D)
Staple, brad and fin-
ish nail incremental
fabrication withdrawal
resistance coating
0.60
(5.0)
E)
Staple,
brad and fin-
ish nail unit fabri
cation coating
0.64
(5.3)
45)
All other coatings
0.36
(3.0)
(Board
Note:
The
least
restrictive limitation shall
apply
if
more
than
one
limitation
pertains
to
a
specific
coating)
k)
Heavy
Off—highway
Vehicle
Products
1)
Extreme
performance
prime
coat
0.42
(3.5)
79-231
—23—
2)
Extreme performance
top coat—air dried
0.52
(4.3)
3)
Final
repair coat—
air dried
0.58
(4.8)
1)
Wood Furniture Coating
1)
Clear topcoat
0.67
(5.6)
2)
Opaque stain
0.56
(4.7)
3)
Pigmented coat
0.60
(5.0)
4)
Repair coat
0.67
(5.6)
5)
Sealer
0.67
(5.6)
6)
Semi—transparent stain
0.79
(6.6)
7)
Wash coat
0.73
(6.1)
(Board Note:
The repair coat has overall transfer
efficiency of
30 percent;
all others have an overall
transfer efficiency of
65 percent.)
(Source:
Amended at
Ill. Peg.
_______,
effective
___________)
Section 215.205
Alternative Emission Limitations
Owners or operators
of coating lines subject
to Section 215.204
may comply with
this Section,
rather than with Section 215.204.
The methods or procedures used to determine emissions of organic
material under this eSection shall be approved by the Agency.
Emissions of volatile organic material from sources subjec.t to
Section 215.204,
are allowable, notwithstanding the limitations
in Section 215.204,
if st~eI~e
4eri~ere eentre33ed by er~eef
~e
~e3~ wtrig methods:
a)
For those sources subject to Section 215.204(b), the
emissions are controlled by Aan afterburner system which
provides:
-,
pre~4dedthe~~5 pe~’eei~o?
the em4~ss4erts
?rem
the
eoe~rtg
3~4rte end
99 pereem~of
the
nonmethente
or~en~eme~er4e3 ‘(-mee,~redes ~
eembtis~b~e
eerbent+ w~eI~ent~ersthe e?~erb~mnerere oxtdt~ed~e
cerboni d~ox4deend we~ertor
1)
75
reduction
in the overall emissions of volatile
organic material from the coating line,
and
79-232
—24—
2)
Oxidation
to carbon dioxide and
wate.r
of
90
of
the nonmethane volatile organic material (measured
as total combustible carbon) which enters the
afterburner.
b)
For all other sources subject to 215.204, the emissions
are controlled by an afterburner system which provides:
1)
81
reduction in the overall emissions of volatile
organic material from the coating line,
and
2)
Oxidation
to
carbon
dioxide
and
water
of
90
of
the
nonmethane
volatile
organic
material
(measured
as
total combustible
carbon) which enters the after-
burner.
~c)
A The system used to control such emissions
is
demonstrated to have control efficiency equivalent to or
greater than that provided under
the applicable pro-
vision of Section 215.204 or subsections
(a) or
(b)
es
ep~ro~ed
by the Agentey.
(Source:
Amended at
Ill. Reg.
,
effective
)
Section 215.207
~*~erne~ ef?se~eCompliance by
Aggregation of Emission Sources
a)
No
person
s~e~ ee~se or
e~ew
~i~e
em~ss~onof vo~e~~e
orgent~em
er~e3~
from enty eee~ngi~ne~o exceed any
m~~e~ont
eort~e4~nted
~#nt
See~4ort~~94
~nt3~ese
Owners
or
operators
of coating lines subject to Section 215.204
may comply with this Section rather than with Section
215.204.
The methods or procedures used to determine
emissions
of volatile organic material under this
Section shall
be approved by the Agency.
Emissions of
volatile organic material
from sources subject to
Section 215.204 are allowable, notwithstanding the
limitations
in Section 215.204,
if
the combined actual
emissions re~efrom ei~selected coating
lines at the
coating plant, but not including coating lines or other
emission sources constructed or modified after July 1,
1979,
is less than or equal
to the combined allowable
emissions re~eas determined by the following equations:
79-233
—25—
EALL
=
.~
~
(A1B~)~
j=l
1=1
EACT
=
(C~Bi(l
—
Di))j
j=l
i=l
b)
A~shall be determined by the following
formula:
R~
1
—
_______
~c)
As used
in subsection
(a), symbols mean the following:
EALL
=
the allowable emission re~efrom the coating
plant
in k~ogremsper day kg/day
(pot~ntdsper
day lb/day).
A~
=
the allowable emission re~elimit
for eeeI~a
coating pursuant to Section 215.204 expressed
in kg/i
(lbs/gal)
of coating solids7 exe~&~nt~
we~er7de~vered ~o the eea~ngepp~ee~er.
=
the volume of eee1~~coating solids
in 1/day
(gal/day)7 exe~d~ngwa~er7in
a coating as
delivered to the coating epp~ee~orline.
m
=
the number of coating lines included in
the
combined emission rate.
n
=
the number
of ~ypes of different coatings
delivered to the a coating epp3~ee~orline.
EACT
=
the actual emissions re~efrom the coating
plant
in kg/day (lbs/day)
Cj
=
the weight
of volatile organic material per
volume of eoa~nt~solids
in kg/i
(lb/gal)
for
eeel’i a coating epp3~ed.
D1
=
the control efficiency by which emissions of
volatile organic material from the
a coating
are reduced through the use of control
equipment.
=
the applicable emission limit pursuant to
Section 215.204, for
a coating,
in kg/l
(lb/gal)
of coating,
excluding water.
79-234
—26—
=
the density of the volatile organic material
in a coating
in kg/l
(lb/gal).
ed)
The owner or operator of the coating plant shall
maintain records of the density of the volatile organic
material
in each coating, the quantity and se~vent~
volatile organic material and solids content of each
coating applied and the line to which ~
coating
is
applied,
in such
a manner so as
to eee~redemonstrate
continuing compliance with the combined allowable
emissions re~e.
de)
Except
for emission sources subject to Sections 215.301
or
215.302, credits for effae~sfrom emission sources at
the coating plant that are subject to this Part,
other
than coating lines,
may
be given7 b~ ont~yto the extent
that they repreeent~red~et~ene
emissions are reduced
from the allowable emission limits
for such emission
sources contained in either this Part,
or any existing
operating permit, whichever
limit is less.
(Source:
Amended at
Ill. Reg.
_______,
effective
)
IT IS SO ORDERED
I,
Dorothy M. Gum, Clerk of the Illinois Pollution Control
Board, hereby certify that the above Proposed Rule, First Notice
Opinion and Order was adopted on the
~
day
of ______________________,
1987, by
a vote of
________
U
/
Dorothy M. ~‘Gunn,Clerk
Illinois Pollution Control Board
79-235
