ILLINOIS POLLUTION CONTROL BOARD
July
16,
1987
IN THE MATTER OF:
PROPOSED AMENDMENTS TO PART
)
R86-39
211 AND 215, LEAKS FROM SYNTHETIC
ORGANIC CHEMICAL AND POLYMER
)
MANUFACTURING EQUIPMENT
PROPOSED RULE.
FIRST NOTICE.
PROPOSED OPINION AND ORDER OF THE BOARD
(by
J.D.. Dumelle):
This matter comes before
the Board upon
a September
23, 1986
proposal
for
the adoption of
amendments
to
35
Ill.
Adm. Code 211
and 215 filed on behalf of
the Illinois Environmental Protection
Agency
(Agency).
The
proposal was accepted
and authorized for
hearing by order
of September 25,
1986.
Hearings were held on
February
25,
1967
in Springfield
and March
11,
1987
in Chicago.
The Agency filed
an amended proposal on April
13,
1987
and
a
second amended proposal
on May
4,
1987.
The Department of Energy
and Natural Resources filed a negative declaration on June
1,
1987
and
the
Economic and Technical Advisory Committee concurred
with that declaration on June 10,
1987.
The overriding
basis of
this proceeding
is to correct
deficiencies
in the
Illinois State Implementation Plan
(SIP)
which have been identified
by the United States Environmental
Protection Agency
(USEPA).
Section 172 of the Clean Air Act
requires the
state
to impose
the use
of reasonably available
control technology
(RACT)
on existing sources
in non—attainment
areas.
On hay 19,19Th USEPA gave notice
at
43
Fed.
Reg.
21673
that the SIP must include,
at least
for major
urban areas,
enforceable regulations
reflecting
the application of
RACT
to
those stationary sources
for which USEPA has published control
techniques guidelines
(CTGs)
since
1978.
In August
of
1981
a CTG
entitled “Control of Volatile Organic Compound Fugitive Emissions
for Syntnetic Organic Chemical, Polymer
and Resin Manufacturing
Equipment” was published
in draft form and subsequently made
final.
In
1982 the Agency proposed
regulations
in R82-l4
to
the
Board which were subsequently adopted
in
a revised
form and
submitted
to USEPA as a SIP revision.
USEPA reviewed the rules
and concluded
that the rules
regarding
leaks needed major
revision
in that the rules allowed
excessive emissions and do not represent
a quarterly leak
detection and repair program.
The present proposal
is intended
to remedy
the cited deficiencies.
79-255
—2—
No
adverse
comments
or
evidence
has
been
presented
regarding
the
bulk
of
the
proposed
rules.
Issues
have,
however,
risen
in
five areas:
the geographic coverage of
the rule,
the definition
of “Identification,” the inconsistency between Section 215.431(d)
and 215.432(i)
regarding the exemption for
ball
and plug valves,
and the requirement of Section
215.437(c)
of closed purge
or
closed vent systems
for sampling connections.
GEOGRAPHIC COVERAGE
Mr. Wierdak of Amoco Chemical Company testified that he
believed
that Will County should not be
included within the
geographic coverage of these rules because Will County
is an
ozone attainment area,
and that inclusion of Will County
is not,
therefore,
required by the Clean Air Act.
(R.
97—99).
Further,
upon
a motion of
Stepan Chemical Co.
at
the March
11,
1987
hearing,
the testimony of Mr. Erwin Kauper,
a certified
consulting meteorologist, which was presented
at the April
24,
1987,
hearing
in R86—l8, was incorporated into this record
in an
apparent attempt
to demonstrate that ~i11 County emissions do not
contribute
to ozone violations.
That testimony appears at 1034—
1106 of the April
24,
1987
hearing.
Mr.
Forbes
of the Agency,
however, testified that Will County should
be included since
it
is part of
the SIP area, that emissions from the County impact
the ozone air quality of the region,
and that the emissions
reductions from application of
RACT
to sources
in
S’~ill County
have been included
in previous analyses and are necessary to
demonstrate attainment of
the National Ambient Air Quality
Standards
(NAAQS).
(R.
15—16).
The
Board has considered
the geographic applicability of the
RACT rules
in several recent opinions: R82—14, April
19,
1987 at
4—5;
R82—l4, April
3u,
1987
at 21-22;
R85—2l(A), May
28,
1987 at
21-22;
and R86—12,
May
28,
1987 at
4.
In each of these,
the
Board indicated that it would
follow
the Agency’s proposal that
the RACT regulations
be applied
to Cook,
DuPage,
Kane,
Lake,
Macoupin, Madison,
McFienry,
Monroe,
St.
Clair
and ~il1
counties.
All except McHenry and Will are presently designated
as non-attainment for ozone.
The
fullest and most developed analysis
of this
issue
appears
in the April
30,
1987 Opinion
in R82-l4
at pp.
21—22:
Several
years
ago,
when
these
proceedings
were
completed
and
RACT
III
was
proposed,
much
of
the
state
was
designated
as
non-
attainment.
When
RACT
I
was
initiated,
25
counties
in
Illinois were non-attainment
for
ozone.
The
rationale
for
statewide
applicability
was
based
on
the
pervasive
statewide
ozone
problem,
the
atmospheric
transport
of
ozone
and
ozone
precursors
from
79-256
—3—
sources
in attainment areas
to non-attainment
areas,
and the need
to provide for growth
in
the
SIP
(R.
40-63).
At
present, many areas
of
the
state
have
achieved
attainment
for
ozone
and
the
major
non—attainment
areas,
with
one
exception,
are concentrated
in
the
Chicago
and
East
St.
Louis
major
urbanized
areas
(R.
3204-5).
Macoupin County
is
not
located
in
a
major
urbanized
area
but
continues
to
experience
violations
of
the
NAAQS
for ozone.
Recent
regulatory
proposals
have
focused
on
implementing
RACT
in
the
nine
counties
that
comprise
the Cnicago and East
St.
Louis major
urbanized regions and Macoupin County.
Eight
of
these
counties
are
currently
designated
non-attainment
for
ozone.
Will
and
Mdlienry
counties
are currently designated
attainment
for
ozone
but
are
part
of
the
Chicago
urbanized
area.
The SIP must,
in addition
to
imposing
RACT on major
stationary sources
in
non—attainment
areas,
provide
for
ultimate
attainment of
the ozone
NAAQS.
To
that end,
sources
in Will
and McHenry still
need
to
be
RACT
controlled
in
order
to
ensure
adequate
emission
reductions
because
of
the transport
of
ozone
and
ozone
precursors
from
these
geographically contiguous counties.
During
the
course
of
the
various
regulatory
proposals
for
the
heatset
web
offset
category,
no
participant
has
raised
the
issue
of
changing
the
geographic
applicability
in
light
of
the
current
SIP
strategy.
Consequently,
the
Board will
limit
the geographic applicability of RACT controls
to
the
ten
counties
designated
either
non—
attainment
for
ozone
or
that
are
a
part
of
the Chicago urbanized area.
As noted above,
the geographic coverage has been questioned
in
this proceeding.
The only evidence presented
in opposition
to
the Agency’s proposal
is contained
in the Kauper material which
has been incorporated by reference.
Mr.
Kauper concludes:
1.
That the EKMA model used to demonstrate approvability
of SIP submissions
is flawed;
2.
That urban traffic sources rather than point sources
are responsible
tor ozone exceedances;
and
79-257
—4—
3.
That proper
trajectory analysis generally rules out the
significance
of point sources
in Will,
Kane, McHenry
and DuPage counties as contributors to ozone
exceedances.
(K.
86—19, April
24,
1987,
R.
1045—1048
and
1059).
While
the Board
finds Mr. Kauper’s analysis
to be
interesting,
the Board
is not persuaded
of the validity of his
conclusions.
Mr.
Kauper bases his conclusions on the trajectory
analysis.
A
trajectory
is
constructed
by identifying
a specific
air
parcel
(i.e.
one
containing
an
ozone
concentration
in
excess
of
the
NAAQS
for
ozone)
and
tracing
the
locations
of
the
air
parcel
backward
in
time
using hourly wind data.
Trajectory
analysis
attempts
to
determine
the
source of the emissions
that
ultimately
led
to
the
exceedances.
Twenty—nine
(29)
separate
trajectories
were
presented
by
Mr.
Kauper
showing
the
paths
taken
by
the
air
parcels
that
led
to
ozone
violations
in
Illinois
and
Wisconsin
on
22
days
during
the
1985
and
1986
ozone
seasons.
These
trajectories
do
tend
to
pass
through
the
Chicago
metropolitan
area.
They
do
not,
however,
tend
to
pass
through
the
Chicago
urban
area
during
times
when
heavy
traffic
would
be
expected
-
Assuming
the
urban
area
to
be
defined
on
the
trajectory
maps
by
the
area
bounded
by
Evanston,
Des
Plaines,
ORD
(O’Hare),
Cicero, Midway,
S~ Pump,
Calumet
City
and
the
lake,
and
assuming
that heavy traffic would not be expected prior
to 5:30 a.m. CST,
only
8
of
the
29
trajectories
are
indicated
to
have
passed
through
the
urban
area
at
relevant
times.
On
the
other
hand,
at
least
15
of the
air
parcels were over Lake Michigan during the
time period after
5:30 a.m.
On this simplistic basis it appears
more
reasonable
to
assume
that
the
problem
stems
from
Lake
Michigan emissions rather
than urban traffic.
That,
of course,
is not
the case, however,
and
it appears most reasonable to
hypothesize
that
the
ozone
precursors
in
most
of
the
cited
cases
were
injected
into
the
atmosphere
at
some
point prior
to
the
last
plotted
point
of
most
of
the
trajectories.
Thus,
the
data
presented
is
of
limited
value
in
determining
the
sources
of
the
ozone exceedances studied,
and
is of even more limited value with
respect
to the
stated generalized conclusions.
Furthermore,
Mr.
Kauper indicated that short of extending
a complete analysis
farther back
in time,
the best guess
as
to the trajectories prior
to
the last plotted points would be based upon a presumed
movement similar
to that indicated by the last few plotted
points.
(id. at 1074).
If that
is done,
at least
20 of the
29
trajectories would
be expected
to pass near,
or
through, 1~ill
County.
It
is difficult to understand,
then,
how the Board
could
be expected
to conclude that Will County sources are not
contributing
to these ozone violations.
Other factors serve
to
further
undercut
Mr.
Kauper’s conclusions.
Mr.
Kauper
admitted
that he was not familiar with the location of stationary sources
79.258
—5—
in
the Chicago area and
that he
simply assumed,
based upon his
knowledge of other
cities,
that the Chicago urban area would be
dominated by mobile sources.
(id. at 1083).
Mr.
Kauper
further
admitted that there
is some uncertainty involved
in plotting air
parcel
trajectories, particularly over the
lake where there are
no wind velocity measurements.
(id.
at 1075—1079).
One such
uncertainty
is the presumption that wind speed
increases by 50
when the air parcel moves offshore due
to the reduction in
surface friction.
(id.
at 1079-1080).
Studies over oceans have
shown a 35
factor.
(id.
at 1080).
Over the distances involved,
this difference could
be significant, since the uncertainties
could be additive.
The Board simply cannot conclude that Mr. Kauper’s data
supports his conclusion regarding ozone exceedances being caused
by Chicago urban mobile sources.
While
the Board
is inclined
to
agree that the EKMA model may have shortcomings as a predictor of
ozone exceedances
near
Lake Michigan and that
a substantial
majority of the studied exceedances are impacted by lake effect
winds,
insufficient information has been provided
to demonstrate
that Will County does not contribute to those exceedances even
assuming
the accuracy of the plotted trajectories.
The state
is required
to have an approved SIP for ozone,
and
it
is already late
in that effort.
On the one hand,
the Agency’s
proposal appears
to be federally approvable;
on the other
hand,
there are serious questions as
to whether
an attainment
demonstration could
be made
if Will County were not to
be subject
to the proposed rules.
As set forth by Steve Rothblatt, Chief,
Air and Radiation branch of USEPA,
in order
to exclude Will
County from
the proposal, “USEPA would have
to
be convinced that
emissions from Will
County
do not contribute to the emissions
which
lead to
the violations of the ozone standard found
in
arid
downwind of the Chicago area.
In addition,
it would be necessary
for the state
to prepare, adopt and submit
a SIP revision which
includes a new EKMA analysis
which
would have
to reflect new
values for various parameters which would be affected
by the
reduction
in analysis area.
(Attachment to Agency comments,
Rothblatt letter
at
2),
Furthermore,
if Will County
is excluded
from coverage, a “completely revised set of input data would
be
required” and the delay which would be required for
such an
analysis and review by USEPA may well subject Illinois program
“to various
additional requirements currently under development
by USEPA.”
(id.)
That is,
by the time such a reanalysis’s could
be completed, USEPA may well have revised
its procedures
for
approval,
thus requiring additional support.
Finally, ozone levels recorded during
the 1987 ozone season
appear
to demonstrate the prudence of including some attainment
counties
under
the
coverage
of
these
rules.
Dr.
Rao
of
the
Board’s Scientific/Technical Staff has
introduced two exhibits at
a June
30,
1987
hearing
in R86—37
containing preliminary details
79-259
—6-
of the
1967 exceedances
of the NAAQS
for ozone
based
upon
monitored data.
The Board,
on
its own motion,
hereby makes
those
same documents exhibits
in this proceeding.
The first document
(Exhibit 10), entitled
“1987 Illinois
Ozone Excursions Above the NAAQS Level
of
120 ppb,”
consists of
a
table showing the date and location
(city and county)
of
monitoring
sites
along with measured values of the ozone
concentration.
This table was complied by the
Scientific/Technical Section
(STS), using
the information
provided by Bob Swinford and Will Flowers
from the Illinois
Environmental Protection Agency (Agency).
Dr.
Rao from the STS
has spoken with the Agency personnel on a number
of occasions to
update
the table which includes data
up
to July 15,
1987.
Bod Swinford provided the second document
(Exhibit 11),
which
is a
summary report generated
by the Agency
using data from
the ozone monitoring sites
in Illinois.
This report,
updated
June
22,
1987,
is similar
to the earlier
described table,
but
in
addition
also
shows
1)
the number of excursions that have taken
place
at
each
location;
2)
the date and location of sites with
measured ozone concentrations between 120 and 125 ppb which have
been labeled
unhealthful pollution standard
index
(PSI)
days;
and
3) dates
and regions where ozone advisories were
issued along
with the monitor which triggered the event.
It
is interesting
to note that several of the
1987
exceedances
occur
in counties that are presently classified as
attainment
for ozone
(Will,
Mdlienry, and Peoria).
Obviously,
this may have
a bearing on whether
the Board
should
be applying
RACT controls
in counties presently designated as attainment.
The Board
requests comment on the significance of these exhibits.
Given the Board’s findings concerning
the sufficiency of the
Kauper testimony,
the Board concludes that there
is
no reasonable
likelihood
of demonstrating attainment based
upon reanalysis of
the ozone SIP without including ~ill
County.
Since
the failure
to demonstrate attainment would result
in disapproval of the SIP
and
the state
is required
to have an approved SIP, the Board
proposes that these rules be applicable
to the ten counties
proposed.
Definition of Identification
Section 215.431 requires development of an inspection
program plan which is
to include
a description of the methods
to
be used to identify all components under
the plan “such that they
are obvious and can be located by both plant personnel
performing
monitoring
and Agency personnel performing
inspections.”
(Section 215.431(d)).
Mr. Wierdak of Amoco testified that the
proposed wording
is unclear
and
he
is apparently concerned
that
it may be interpreted
to require field markings.
(K.
99).
Mr.
79-260
‘-7—
Wierdak proposed language
to ensure
that
a listing
of all
components
and locations,
accompanied
by appropriate piping flow
diagrams showing the components would be acceptable.
(id).
The
Agency responded
in
its comments that it believes that present
wording
is sufficiently clear.
(Agency Comments
at
2).
The Board agrees with the Agency that the proposed language
is sufficiently clear.
Actual tagging
is not required
by the
proposed rule:
any identification system which allows
for readily
locating
any individual
component meets the
requirement.
While
Amoco’s proposed language would clarify the acceptability of one
method
of compliance,
it could
be interpreted
to limit
other
methods.
The Board will,
therefore, propose the Agency’s
language.
Ball and Plug Valves
Mr. Wierdak also pointed out
a conflict between Section
215.431(d)
and 215.432(i).
(R.
101—102).
He correctly notes
that
the former
section states that “ball and plug valves
are
exempted under Section 215.432(i),” whereas the latter section
contains
no such exemption.
He,
therefore,
recommends that
the
latter section be revised
to
be consistent with the former
section.
The Agency has amended its proposal
to make the
two sections
consistent
in
its Second Amended Proposal.
It has done
so
by
eliminating
the reference
to
a ball and plug valve exemption
in
Section
215.431(d)
rather
then revising 215.432(i).
The
exemption of
ball and plug valves was
a cited deficiency of the
present rules, and the Agency’s revision is consistent with the
intent of proposal, while
Mr.
Wierdak’s
suggested
revision
is
not.
Other than citing the need for consistency,
no
testimony
has been presented
in this record
in support of retaining
a ball
and plug valve exemption.
The Board will,
therefore, propose the
Agency’s amended
language.
Sampling Connections
Mr. ~ierdak also testified against the adoption of Section
215.437(c)
concerning sampling connections.
(K.
101—102).
He
testified that
“the difficulty and costs associated with
retrofitting existing process sample points with these systems”
does not warrant
regulation.
The Agency disagrees
stating that
“while
it
is true that the CTG does not,
in fact, contain the
requirements included
in proposed
rule 215.437(c),
the Agency
believes that
215.437(c)
constitutes
RACT”
in that the cost of
compliance
is
reasonable.
(Agency Comments
at
3—4).
Using federal background information, the cost
o.f compliance
is
stated
to
be $535/ton
in 1980 dollars
for
new
systems
and
$869/ton
for retrofitting.
(Agency Comments at
3-4
and see
79.261
—8—
Attachments A and
B to Agency Comments).
Using
an inflation
adjustment
factor of 1.34,
the cost effectiveness
in 1986 dollars
for retrofitting
is
$1,165/ton with total
reductions
in Illinois
of 263 tons/year.
(Agency Comments
at
4 and Ex.
5, Tables 2—1,
2-2 and 4-1).
The Agency argues that the cost of control
is
reasonable and that its proposal should be
adopted.
The Board agrees.
The only cost figures
in this proceeding
are those cited by the Agency above.
Wierdak’s testimony is
really nothing more than an argument that since
the CTG does not
cover sampling connections,
the proposed rule should not be
adopted.
The Board, however,
is not constrained
to adopt only
those regulations contemplated by the CTG.
Given the difficulty
the state
faces
in achieving timely compliance with the ozone
standard, where, as here,
unrebutted testimony
is presented
showing that significant reductions
in VOC’s can
be obtained
at
a
reasonable cost to the regulated community,
the Board would be
remiss
in not proposing
the adoption of such
a
rule.
The Board
will,
therefore, propose the rule as submitted by the Agency.
Compliance Date
Mr. wierdak’s
final point
is that it may take
up to
six
months after adoption of the proposed rules
for Amoco
to
implement the new requirements
to achieve compliance.
(K.
103—
104).
Since
the proposed compliance date
is December
31,
1987,
if final
rules are adopted
after July
1,
1987,
Amoco may not be
able to achieve timely compliance.
He, therefore,
recommends
that “some provision be incorporated into
Section
215.436
to
account for reasonable progress
in complying with the rules by
December
31,
1987,
despite
the
fact
that full compliance may not
yet be demonstrated.
Obviously,
final
rules will not
be adopted before July
1,
1987.
In all likelihood
it will
be near the end of the year
before they will
be adopted, which will certainly give rise to
some difficulties
in compliance by December
31.
The variance
mechanism could be used
to remedy
this
difficulty
while
retaining
the proposed
compliance date.
However,
to rely on that mechanism
is to
a large extent elevating form over substance in that the
likelihood of receiving
a variance prior
to achieving compliance
is rather
low.
Instead,
the Board has considered adding
language
to proposed Section
215.438
to allow
a facility until July
1,
1988
to achieve full compliance
as
long as reasonable progress
toward compliance
is being made.
While this appears reasonable,
the Board
is concerned that
such an extension may be viewed with
disapproval by the USEPA and will
not at this time propose such
additional
language.
However, the
Board requests comment on this
issue.
Thus,
the Board proposes
for
first notice the language
contained
in the Agency’s Second Amended Proposal.
79-262
—9—
ORDER
The Board hereby proposed for first notice the following
proposed
rules:
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
Section
211.122
Definitions
“Component’1:
Any piece
of petfo~eumte~neryequipment
which has the potential
to leak volatile organic
material
including,
but not limited
to, pump seals,
compressor seals,
seal oil degassing vents,
pipeline
valves, pressure relief devices,
process drains and
open ended pipes.
Except
for Subpart
~,
Tthis
definition excludes valves which are not externally
regulated, flanges and equipment
in heavy
liquid
service.
TITLt~ 35:
ENVIRONMENTAL PROTECTION
SUBTITLE
B:
AIR POLLUTION
CHAPTER
I:
PCILLUT
ION
CONTROL
BOARD
PART 215
ORGANIC
MATERIAL
EMISSION
STANDARDS
AND
LIMITATIONS
Section
215.104
Definitions
li?emponey~~lt.~Any
p4eee
o~ equipMent
wMeh has the
poten~Aa3~o ‘eek veIa~t3eergan~tema~efiaI
eiud~n~-~
~ut ne~
m~tedto7 pump seals7
eempressot seals7 seal o~ldegess~ng~ents7
p4pel4ne valves7 pressure rel4e~devtees7 preeess
drains and open ended p4pes7
Th4s de~n4t~en
exeludes va~~eswh~eha~enot externally
~‘egt1leted7?ian~es7 and equ~pment4n heavy l~qu~id
serv~ee-
For purposes o~Subpart Q~-th~s
de~n4t~enalso exeludes bell end plug valves
Section 215.4291
General Requirements
The owner
or operator of
a plant which
has more than 1,500
components
in gas
or
light
liquid service, which components
are
79-263
—10—
used
to
manufacture
the
synthetic
organic
chemicals
or
polymers
listed
in Appendix D, shall conduct leak inspection and
repair
programs
in accordance with this Subpart for that equipment
containing more than 10 percent volatile organic material
as
determined
by
ASTM
method
E-20260,
E-l68,and
E-169.
A
Component
shall
be considered
to be leaking
if the volatile organic
material concentration exceeds 10,000 ppm when measured at
a
distance of
0 cm from the component.
The provisions of this
Subpart are not applicable
if the products listed
in Appendix D
are made from natural fatty acids
for the production of hexadecyl
alcohol.
Section 215.4212
Inspection Program Plan
for
Leaks
The owner or operator of a synthetic organic chemical or polymer
manufacturing
plant
subject
to
Section
215.420
shall
prepare
an
inspection program plan which contains,
at
a minimum:
a)
An identification of all components and the period
in
which
each
will
be
monitored
pursuant
to
Section
215.4223;
b)
The format
for
the monitoring
log
required by
Section 215.4235;
C)
A description
of the monitoring equipment
to be
used pursuant
to Section 215.4223;
and
d)
A description of the methods
to be used
to
identify all pipeline valves, pressure relief
valves
in gaseous service, all leaking components,
and
the ball
and plug valves and pumps exempted
under Section 215.4223(h)
such that they are
obvious and can be located by both plant personnel
performing monitoring
and Agency personnel
performing inspections.
Section
215.4223
Inspection
Program
for
Leaks
The
owner
or
operator
of
a
synthetic
organic
chemical
or
polymer
manufacturing
plant
subject
to
Section
215.4201
shall,
for
the
purposes of detecting leaks,
conduct
a component inspection
program consistent with the
following provisions.
a)
Test annually those components operated near
extreme
temperature
or
pressure
such
that
they
would be unsafe to routinely monitor,
and those
components located more than two meters above
or
away from permanent worker access
structures or
surfaces;
79.264
—11-
b)
Test
all
other
pressure
relief
valves
in
gaseous
service,
pump
seals,
pipeline
valves,
process
drains and compressor
seals not earlier
than March
1 or later than June
1 of each year;
C)
If more
than
2
percent
of
the components tested
pursuant
to subsection
(b)
are found
to leak,
again
test all pressure relief valves in gaseous
service, pipeline valves
in gaseous service and
compressor
seals by methods and procedures
approved by the Agency not earlier
than June
1 or
later
than September
1 of each year;
d)
Observe visually all pump seals weekly;
e)
Test immediately any pump seal from which liquids
are observed dripping;
f)
Test any relief valve within
24 hours
after
it has
vented
to the atmosphere;
and
g)
Test immediately after
repair any component
that
was found leaking.
h)
Ball and plug valves, inaccessible valves,
storage
tank valves, pumps equipped with mechanical seals,
pressure
relief
devices
connected
to
an
operating
flare header or vapor recovery device are exempt
from the monitoring requirements
in this Section.
Section 2l5.424
Repairing Leaks
All leaking components must be repaired
and
retested
as
soon
as
practicable but
no later
than 21 days after
the leak
is found
unless the leaking component cannot be
repaired until
the process
unit
is shutdown or the repair part
is received.
Records of
repairing and
retesting must be maintained
in accordance with
Sections 215.424 and 215.425.
Section 215.4245
Recordkeeping
for Leaks
a)
The owner or operator of a synthetic organic
chemical
or polymer manufacturing plant shall
maintain
a leaking components monitoring
log which
shall contain, at
a minimum, the
following
information:
1)
The name of the process
unit where
the
component is located;
2)
The type of component
(e.g., valve,
seal);
79-265
—12—
3)
The identification number
of the component;
4)
The date on which a leaking component is
discovered;
5)
The date on which
a leaking
component
is
repaired;
6)
The date and instrument reading
of the
recheck procedure after
a leaking component
is repaired;
7)
A record
of the calibration of the monitoring
instrument;
8)
The identification number of leaking
components which cannot be
repaired until
process unit shutdown;
and
9)
The total number
of components
inspected and
the total number
of components found
leaking
during that monitoring period.
b)
Copies of the monitoring
log shall
be retained
by
the owner
or operator for
a minimum of two years
after
the date on which the record was made
or the
report prepared.
c)
Copies of the monitoring
log
shall
be made
available
to the Agency, upon verbal or written
request,
at any reasonable
time.
Section 215.4256
Report
for Leaks
The owner
or operator of
a synthetic organic chemical or polymer
manufacturing plant subject
to
Section
215.4201 shall:
a)
Submit
a report
to the Agency prior
to the 1st day
of July and October
listing all leaking components
identified pursuant
to Section 215.4221 but not
repaired within
21 days,
all leaking components
awaiting process unit shutdown, the total
number
of components inspected and the total number of
components
found leaking;
b)
Submit
a signed statement with the report
attesting that all monitoring
and repairs were
performed
as required under Sections 215.4201
through 215.4267.
Section 215.4267
Alternative Program for Leaks
79.266
—13—
The Agency shall approve
an alternative program of monitoring,
recordkeeping,
and/or
reporting to that prescribed
in Sections
215.4201 through
215.4256 upon
a demonstration by the owner
or
operator of such plant that the alternative program will provide
plant personnel and Agency personnel with an equivalent ability
to identify and repair leaking components.
The owner or operator
utilizing an alternative monitoring program shall submit to the
Agency
an alternative monitoring program plan consistent with the
provisions of Section 215.421.
Section
215.4278
Compliance
Dates and Geegreph4eel Areas
a)
Exeept as otherwise stated ~n subseet4on ~b-)7
eEvery owner
or operator
of
a synthetic organic
chemical
or polymer manufacturing plant subject
to
Sections
215.4201 through 215.4267 shall comply
with the standards and limitations of those
Sections beginning Getober
3i7lO8SDecember
31,
1987.
if a plant ~s not loeated ~n one
of the eount’ies
ltsted below7 the owner er operator of the plant
shall eemply w±ththe requtrements of Seet4ens
2l5~420through 2l5~426no later than Beeember ~
198~
-~
Bend
Mad~sen
Elthton
MeHenry
eook
Monroe
BeKaIb
Montgomery
BuPage
Morgan
Frenhi-in
Pope
Greene
Randolph
~aekson
Bal~ine
aersey
Sangemon
dohnsen
St~?lMr
Kane
Un’ien
bake
Maeoup~n
W~li4~emsen
~Beard nete--
?eunt4es are destgnated as
ettatnntent or nonette4nment for ozone by
the
Hn~tedStates Env4renmerttal Proteet4en Ageney
+USEPA-)~- The ~SEPA noted
in 4ts redeMgrtat4on
ruierrtak~ng7that ‘~twill publish a ruleniek±ng
net4ee en W4ll’~amsen?ounty-’-s atta~rtmentstatus--
~4S Fed-- Reg~-219497 May 16~1983~ Should
WHl~iamsen
Oeunty
be redes~ignatedas atta4~rtment
prier to Getober 317 l985~4t end
the
eeunt~es
eent4guous to 4~twill
be eenMdered deleted from
the above l-ist~-~
79-267
—14—
e~
Netw’ithstend’ing subseet’ion ‘fb-~7 ‘if any county
‘is
redes’ignated
as nenetta’inment by the ~SEPA at any
time subsequent to the effeettve date of thts
Seet’ion7
the
owner or operator
of
a plant located
-in that county who would otherwtse by subject to
the
eompl’ianee date
‘in subseet’iort ~
shall comply
wtth
the
requtremertts of Seettens 215-420 through
~l5-~426w-ithtn one year from the date of
redes’ignet-iert but
‘in no ease later than December
317 198~
Section 215.4289
Compliance Plan
a)
The owner
or operator
of
a synthetic organic
chemical or polymer manufacturing plant subject to
Section 2l5.42~8~a-~
or
+b~)- shall submit to the
Agency a compliance plan,
no
later than December
31,
19857.
b~
The owner
or operator
of
a plant subject to
Sect-ten 2l5-~427-(-e~shall
subm’it a eernplenee plan
wtthrt 90 days after the date of redes’ignat~ion7
but
‘in no ease later than December 317 1986-
e-~
The owner or operator of a plant subject to
Seet’ion 2l5~-42~-~e-~
shell not be required to submit
a eemnpl’ienee plan
‘if redes4gnet’ion occurs after
December 317 1986-
db)
The plan and schedule shall meet the requirements
of
35 Ill.
Admn. Code 201.
Section 215.430
General Requirements
The
owner
or
operator
of
a
plant
which
processes
more
than
3660
Mg/yr
(4033 tons/year)
gaseous and/or light liquid volatile
organic material,
and whose components are used to manufacture
the
synthetic
organic
chemicals
or
polymers
listed
in
Appendix
D,
shall
conduct
leak
inspection
and
repair
programs
for
that
equipment
in accordance with this Subpart.
Leak inspection and
repair
programs
shall
be
conducted
for
that
equipment
containing
10
percent
or
more
by
weight
volatile
organic
material
as
determined
by ASTM method
E-168, E-l69 and E-260.
A component
shall
be considered
to
be leaking
of the volatile organic
material
is equal
to,
or
is greater
than 10,000 parts
per million
by volume
(ppmv)
as methane or hexane as determined
by USEPA
Reference Method
21,
indication
of liquids dripping,
or
indication
by
a
sensor
that
a
seal
or
barrier
fluid
system
has
failed.
The provisions of this Subpart are not applicable
if the
equpment
components
are
used
to
produce
heavy
liquid
chemicals
only from heavy liquid feed
or
raw materials.
79.268
—15—
Section 215.431
Inspection Program Plan
for Leaks
The owner
or operator
of
a
synthetic
organic
chemical
or
polymer
manufacturing plant subject
to Section 215.430
shall prepare an
inspection program plan which contains,
at
a minimum:
a)
An identification of all components and the period
in
which each will
be monitored pursuant
to Section
215. 432.
b)
The
format
for the monitoring
log
required
by Section
215.434.
c)
A description of the monitoring equipment to
be used
pursuant to Section 215.432,
and
d)
A description
of the methods
to
be used to
identify all
pipline valves, pressure relief valves
in gaseous
service, all leaking components,
and components
exempted under
Section 215.432(1)
such that they are
obvious and can
be located
by both plant personnel
performing
monitoring
and
Agency
personnel
performing
inspections.
Section
215.432
Inspection Program for Leaks
The owner
or operator
of
a synthetic organic chemical
or polymer
manufacturing plant subject
to Section 215.430 through 215.438,
shall
for
the purposes of detecting leaks,
conduct
a component
inspection program consistent with the following provisions:
a)
Test annually those components operated near extreme
temperature of pressure such that they would be unsafe
to routinely monitor, and
those components located more
than two meters above permanent worker access
structures or surfaces
b)
Test quarterly all other pressure
relief valves
in gas
service,
pumps in light liquid service, valves
in light
service and
in. gas service, and compressors.
c)
If less than or equal
to
2 percent of the valves
in
light liquid service and
in gas service tested pursuant
to subsection
(b)
are found
not to leak for
5
consecutive quarters,
no leak tests
shall
be required
for
three consecutive quarters.
Thereafter,
leak tests
shall resume
for the next quarter.
If that test shows
less than or
equal
to
2 percent of the valves in light
liquid
service
and
in gas service are leaking,
then no
tests
are
required
for
the Next
3 quarters.
If more
than
2 percent are leaking,
then
tests are required for
the next
5
quarters.
79.269
—16—
d)
Observe
visually
all
pump
seals
weekly.
e)
Test immediately any pump seal from which liquids are
observed dripping.
f)
Test any relief valve within
24 hours
after
it has
vented to
the atmosphere.
~j
Test immediately after
repair any component that was
found
leaking.
h)
Within
1 hour of
its detection,
a weatherproof and
readily visible tag bearing
an identification number
and the date
on which
the leak was detected must be
affixed on the leaking component and remain
in place
until
the
leaking
component
is
repaired.
i)
Any
component
that
is
in
vacuum
service,
pressure
relief
devices
connected
to
an
operating
flare
header
or
vapor
recovery
devices
are
exempt
from
the
monitoring requirements
in this Section.
Section 215.433
Repairing Leaks
All leaking components must
be repaired and retested
as soon
a
practicable but no later
than 15 days after
the leak
is found
unless
the leaking component cannot be repaired until
the process
unit is shutdown
Records of repairing and retesting must be
maintained
in accordance with Section 215.434 and 215.435.
Section 215.434
Recordkeeping
for Leaks
a)
the owner or operator of
a synthetic organic chemical
or polymer manufacturing plant
shall maintain
a leaking
components monitoring
log which shall contain,
at
a
minimum,
the following information:
1)
the name of the process unit where the component
is located.
2)
The
type of component
(e.g., valve,
seal).
3)
The identification number
of
the component.
4)
The date on which
a leaking
component
is
discovered.
5)
The date on which
a leaking component
is repaired.
6)
The date
and
instrument reading of the recheck
procedure after
a leaking component
if repaired.
79-270
—17—
7)
A record
of the calibration of the monitoring
instrument.
8)
the identification number of leaking components
which cannot be repaired until process
unit
shutdown; and
9)
The total number
of valves
in light liquid service
and
in gas service inspected, the total
number and
the percentage of these valves found leaking
during
the monitoring period.
b)
Copies
of the monitoring log
shall
be retained
by the
owner
or operator
for
a minimum of two years after
the
date
on which the
record was made
or
the report
prepared.
c)
Copies of
the monitoring
log shall
be made available
to
the Agency upon verbal
or written request,
at any
reasonable
time.
Section 215.435
Report for
Leaks
The owner
or operator of
a synthetic organic chemical
or polymer
manufacturing plant subject
to Section 215.430 through 215.384
shall:
a)
Submit
a report
o
the Agency quarterly,
including prior
to
the
1st day of July listing all leaking components
identified
pursuant
to Section 215.432
but not repaired
within 115 days,
all leaking components
awaiting
process unit shutdown, the
total number
of components
inspected,
the type of components inspected, and the
total
number of components found leaking,
the total
number of valves inspected and the number
and
percentage of valves found leaking.
b)
Submit
a
signed statement with the report
attesting
that all monitoring
and
repairs were preformed
as
required under
Section 215.430 through
215.436.
Section 215.436
Alternative Program for
Leaks
The Agency shall
approve an alternative program of monitoring,
recordkeeping, and/or
reporting to that prescribed
in Sections
215.430 through 215.438, upon
a demonstration
by the owner
or
operator
of such plant
that the alternative program will provide
plant personnel
and Agency personnel with
an equivalent ability
to identify and repair
leaking components.
The owner
or operator
utilizing
an alternative monitoring program shall
submit to
the
Agency an alternative monitoring program plan consistent with the
provisions
of Section
215.431.
79~271
—18—
Section
215.437
Open—Ended Valves
a)
Each open-ended valve
shall
be equipped with
a cap,
blind flange,
plug,
or
a second valve, except during
operations requiring fluid flow through the open—ended
valve.
b)
Each open-ended valve equipped with
a second valve
shall be operated
in
an manner such that the valve on
the process fluid
end
is closed before
the second valve
is closed.
C)
Open-ended valves which serve
as
a sampling connection
shall
be equipped with a closed purge system or closed
vent system such that:
1)
Purged process fluid be
returned
to the
process line with
zero VOM emissions to
atmosphere,
or
2)
Purged process fluid
be
collected and recycled
to the process line with zero VOM emissions to
atmosphere.
Section
215.438
Compliance Date
The owner
or operator
of
a synthetic organic
chemical or polymer
manufacturing plant subject
to Sections 215.430 through 215.438
shall
comply with the standards and limitations of those Sections
no later
than December
31,
1987.
IT
IS
SO ORDERED.
I,
Dorothy
M.
Gunn, Clerk of the Illinois Pollution Control
Board,
hereby certify,th~tthe above Op~nionand Order was
adopted
on the
/C~
~
day of
J.~.J
,
1987
by
a vote
of
_____________.
7
Dorothy
M. ,Gunn,
Clerk
Illinois Pollution Control Board
79.272
1987
Illinois Ozone
Excursions.
Above the
NAAQS
Level
of 120 ppb
Date
~knitoring
Site
(County)
Concentration (ppb)
4/18/87
Lisle,
IL (Cook)
139
6/13/87
Chicago
—
Edgewater
(Cook)
156
6/13/87
Chicago
—
South
Water
Filtration
Plant
(Cook)
135
6/13/67
Chicago
—
Taft
High
School
(Cook)
138
6/13/87
Deerfield,
IL (Lake)
130
6/13/87
Waukegan,
IL
(Lake)
126
6/14/87
Chicago
—
Edgewater
(Cook)
140
6/14/87
Chicago
-
South—East Police Station
(Cook)
144
6/14/87
Chicago
-
South Water Filtration Plant
(Cook)
135
6/14/87
~vanston,1L
(Cook)
11
6/14/87
Waukegari,
IL
(Lake)
140
6/16/87
~Qaterloc,
IL
(Monroe)
14o
6/17/87
Cary,
IL (McHenry)
129
6/17/87
DesPlaines,
IL (Cock)
12~
6/17/87
Evanston, IL (Cook)
132
6/18/87
Calumet
City,
IL
(Cook)
139
6/18/87
Chicago
—
Edgewater (Cook)
162
6/18/67
~hicagc
—
South—East
Police
Station
(Cook)
165
6/18/87
Chicago
—
Taft High School (Cook)
148
6/16/87
Cicero, IL
(Cook)
146
6/18/87
Deerfield, IL (Lake)
150
6/16/87
DesPlaines,
IL (Cook)
129
6/18/87
Evanston, IL (Cook)
149
6/18/67
Libertyville,
IL
(Lake)
164
6/18/87
Waukegan, IL (Lake)
178
6/19/87
Evanston, IL (Cook)
133
6/19/87
Libertyville, IL (Cook)
144
6/19/87
WauKegan, IL (Lake)
141
6/20/87
Chicago
-
Taft High School
(Cook)
129
6/23/87
Lemont,
IL
(Cook)
129
6/23/87
South Lockport (Will)
133
6/24/87
Chicago
-
Taft High School
(Cook)
125
6/24/87
Deerfield,
IL
(Lake)
177
6/24/87
Evanston, IL (Cook)
127
6/24/87
Libertyville,
IL
(Lake)
173
6/24/67
~aukegan,IL (Lake)
162
6/24/87
Peoria
Heights,
IL
(Peoria)
126
79.273
*22*2
2*4
*42*4
~1-~
I~\tY~
L
(
)N
)~-
OZONF
A
AQS REF
b’~
* 1*
*44*244
2i
*
4 * *44*2*4*2
i4
*
4*4
* 2*4*4*4*
19~TO/_ONF
F\(’URS
IONS
I I~\S
I 25PPB
* *14*4*4*444
* *****i**4***~
2
LOCAl
IO~
(‘ONt iNTRATION
* 44*2
* *
*
44**zi
*
* 2*4
*
4
UNHE;LTHFVI, P~1 LA\S ~JTHLU
r
~ONE
EXCt~HS1ON (1 2J
Va
I
~jp
125)
***************1****X***4**2**1
*t*1*******i**********4*********
***1*****Z4
*
~PI)ATED 6/22/ST
FON FURFHEN
I N
FOI?NATJ
ON
CONiAC~J’ 1308 S~
I N ~
ui::~
‘~
~—
Apr
18,
1987
Lisle
139 ppb
*1st
E’ursi~n
Jun
13,
19~’7
Lhica~c
—
Edge~~’ater
156
pph
*1st
Fxr’urs~nn
Jun
13,
1987
Chicago
—
.S~~FP
135
ppb
*1st
E:;cursinn
Jun
13,
1987
Chic-ago
—
Taft
HS
138
ppb
*1st
Fxrursion
Jun
13,
1987
Deerfield
130
ppb
*1st Excursion
Jun
13,
1987
Waukegan
126
ppb
*1st
Excursion
Jun
14,
1987
Chic-age
-
Edgewater
140
pph
*t2nd
Excursion
Jun
1~,
1987
Chicago
—
SE
Police
144
ppb
*1st
Excursion
Jun
14,
1987
Chicago
-
SWFP
135
ppb
**2nd
Excursion
Jun
13,
1987
Evanston
141
pph
*s~
Excursion
Jun
14,
1987
~aukegan
140
ppb
4*2nd
Excursion
Jun
16,
1987
~ater1oo
1~
ppb
*1st
E’;c-ursion
Jun
17,
1987
Cary
129
pph
*1st.
Excursion
Jun
17,
1987
Des
Flames
127
pph
*1st
Excursion
J~
I
,
1~~7
:van~~
‘~2 pph
**“nd
F~~iirCin
-Jun
18,
1987
t2alurnc-t
C~y
139
ppb
*
1st
Excursior,
Jun
18,
1987
Chicago
-
Edge~ater
162 ppb
*4*3rd Excur-~inn
Jun
IS,
198T
Chicago
-
SE
Police
165 pph
4*2nd
Excursion
Jun
18,
1~487
Chic-ago
-
Taft
HS
148
ppb
4*2nd
Excursion
Jun
1~,
1987
Cicero
146
ppt~
*1st
Exc-ursior
Jun
18,
1987
Deerfie~
15’)
pph
*22nd
Excursion
Jun
8,
1987
Des
Pla
inc’s
12~pph
2 *
2nd
~
j
.~
Jun
18,
19)~7
Evanston
149
pph
~~*3rd
E’;cursir-,n
Jun
IS,
1987
Libortyvillc
164
pph
*I~t
Excursion
Jun
12,
1987
Wauhegan
178
ppb
2*43rd Excursion
Jun
19,
1987
Evanston
133 ppb
2*224th
Fxc-jr~ion
Jun
19,
1987
Libertyvill
144
pph
4*2nd
Excursion
Jun
19,
1987
Waukpgan
141
ppb
*2*24th
Excursion
Jun ~O,
1987
Chicago
—
laft
115
l~9
pph
4*23rd
E-:cursicn
May
19,
1987
F’.di~-ardcvi1e
121
pph
Jun
UI,
1987
ChAmpnigri
123
ppE
Jun
UI,
1987
Peoria
122 ppb
Jun
35,
1987
Chicago
-
S1~ Pump
121 ppb
Jun
19,
1987
Cary
124
ppli
OZO~JEADViSORiES ISSUED
Jun
13,
1987
Chicago
—
Northside
3pm CDT
Chic-ago
—
Taft.
136 P1~1~
Jun
13,
1987
Chicago
-
Snuthside
3pm CDF
Chicago
—
SWEP
126
ppl
Jun
13,
1987
Lake
County
3pm
CDT
D~rfie1d
l3~)
ppl~
Jun
17,
1987
Vhi~go—West
&
South
2pm
(1)1’
Cnry
129 ppL
Jun
17,
1987
Chicago
—
Northside
5pm
CDT
Evanston
12G
pp1~
79-274
