Definition of NCompOnenthl
COMPLIANCE DATE
ORDER

ILLINOIS POLLUTION CONTROL BOARD

October

15,

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.

 SECOND NOTICE.

PROPOSED OPINION AND ORDER OF THE BOARD

 (by J.D.

 Durnelle):

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,

1987

 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.

On July 16,

 1987,

 the Board proposed the amendments

to

35

Ill.

 Adm.

 Code

 211 and 215 for first notice.

 On August

6,

 1987,

the Board

 adopted two sets of corrections

 to the July 16,

1987

Order:

 (1) Sections 215.420 through 215.428 were recodified

to

become Sections 215.421 through 215.429,

and

(2)

 the July

16,

1987,

 Order

 was amended

 to reflect the recodification and three

definitions,

 inadvertently omitted from

 the July 16,

 1987,

 Order,

were added.

 The proposed amendments were published at

11

 Ill.

Reg.

13173

 and 13293 on August

14,

 1987.

 The statutory 45—day

comment period enaed

 on September

28,

 1987.

 Non—substantive

comments were received from

 the Secretary of State’s

Administrative Code Unit regarding

 form and format of the

proposed

 rules.

 Those changes have been made

 at second notice.

Three substantive comments were received during the first notice

period.

 The Agency filed

 its comments

 on September

28,

 1987.

The Stepan Company

 (Stepan)

 also filed comments on September

28,

1987.

 On October

1,

 1987,

 the Illinois Environmental Regulatory

 Group

 (ERG)

 filed

 its comments with

 a motion

 to file instanter.

The

 motion to file instanter was granted

 by Hearing Officer

Order.

 The comments focused on a number

 of issues, each

 of which

will

 be addressed

 in turn.

82—359

Definition

NCompOnenthl

All three commenters objected to the last sentence of the

definition of component proposed

 at first notice.

 In the

 first

notice order,

 the Board adopted

 the language

 from the Agency’s

Second Amended Proposal, which

 read

 as follows:

Except

 for Subpart

Q,

 this definition excludes

valves

 which

are

not

 externally

 regulated,

flanges

and

 equipment

in

 heavy

 liquid

service

•“

In

 its comments, the Agency suggested that

 the last sentence be

revised

to

 read:

For

 purposes

of

 Subpart

Q,

R,

and

U,

 this

definition

 excludes

 valves

 which

are

not

externally regulated,

 flanges and equipment

in

heavy liquid

 service.’t

ERG also argued that

 a revision would

be

 in order

and

suggested this language:

This

 definition excludes valves

 which

 are not

externally

 regulated,

 flanges,

 bleed

 ports

of

gear pumps

 in polymer service

 and equipment

in

heavy liquid

 service..”

(The language related

 to the bleed

 ports for gear pumps

is

addressed below.)

The Agency commented

 that the definition must be changed

because “incorporating

 the specific elements

...

 needed

 for the

SOCMI

 rule

 into the

 present definition of component, the Board

erred.”

 The Agency noted that the Control Techniques Guideline

(CTG)

 for this category

 (Ex.

 5) excludes from

 routine monitoring

flanges, connections,

 and equipment

 in heavy liquid service, but

stated that any component

 that appears

 to be leaking should

be

repaired.

 The Agency believes that the Illinois rule can and

should exclude those pieces

 of equipment which the CTG

excludes.

 In support of

 its suggested revision,

 the Agency

stated that particular subparts are specified because

it

is

necessary to have flanges, etc., considered components

for

certain other

 sections of the rules, such as Sections 215.581(d),

(e)

 215.583(d),

 (e),

 and 215.601(c).

In its comments,

 ERG opposed exempting Subpart

Q

from the

general

 exclusion of non—externally regulated

 valves,

 flanges and

equipment

 in heavy liquid

 service.

 ERG argued that flanges,

properly installed,

 have

 a very low possibility of leakage,

and

that the Board has recognized

 this by excluding flanges from

existing Subpart Q in RACT III

 (R82—14, Dockets A and B).

ERG

82—360

—j

—

argued that equipment

 in heavy liquid service

(1)

 is also

excluded by proposed Section 215.430,

(2)

 by its nature will not

leak volatile organic material

 to any extent and therefore does

not need monitoring,

and

(3)

 is not intended to be covered

 under

the leak detection program, as evidenced by the New Source

Performance Standard and

 the CTG.

As

 to valves not externally

regulated, ERG argued that

it

 is not

 logical

to

 require

 a test

for leaks

in

 a component which cannot leak

 unless the component

itself were cracked.

 ERG pointed out that

 a non—externally

controlled valve has no external stem or packing gland with which

to

 test.

ERG also opposed

 the Agency’s suggested

 revision.

ERG

argued

that

the

considerations

involved

adding

Subparts

and

U

to

 the exclusion are

 not a subject of this proceeding

 and are

not established

in

 the record.

The Stepan Company also suggested that

 the exception

for

Subpart

Q

in the last sentence of the definition

 of component be

eliminated.

 Stepan’s position was founded on

 its belief that

emissions

 from components,

 including

 flanges,

 in heavy liquid

service would

 be minimal.

In response

 to the comments,

 the Board

 has deleted

the

language

added

the

last

sentence

the

definitioii

component

proposed

first

notice.

The

Board

persuaded

that

valves

not

externally

regulated,

 flanges, and equipment

 in heavy

liquid

service

merit

the

general

exclusion.

The

Board

also

persuaded that the Agency’s suggested revision

 is not established

by the record

 and,

 furthermore,

 is not necessary.

 The definition

of “component” as

 it presently exists

 in Section 211.122 excludes

flanges, etc.,

 for purposes of all subparts.

 The Agency’s

specification of Subparts

Q,

 R, and

 U not only gives nothing more

to Subpart

Q

but also affects

 all the other

 subparts

in

 a manner

clearly not intended by this proceeding.

The Agency also suggested

 that

 a provision be added

to

conform to the CTG requirement of repairing leaks which are

otherwise excluded from the monitoring requirements of

the

rule.

 The Agency stated that the best place

 for the proposed

subsection would

be

 in proposed Section 215.432, after subsection

(f)

and

before

Subsection

(g),

new

Subsection

(g).

The

Agency suggested

 the following:

~

 Routine

 instrument

 monitoring

of

 valves

 which

are

not

 externally

 regulated,

flanges,

and

 equipment

in

 heavy

 liquid

service

is

not

 required.

 However,

any

valve

 which

is

 not externally

 regulated,

flange,

or

 piece

of

 equipment

in

 heavy

liquid service

 that appears to be leaking

on

the

 basis

of

 sight,

 smell

or

 sound

should be repaired

 as soon

 as possible.

82—36 1

—4—

The Board agrees

 in substance

 and has added language to

Section 215.432 for second notice.

The Stepan Company offered additional comment on the

definition

 of component.

 First,

 Stepan stated that process

drains should

 be deleted

 from the definition

“because

the

 regulations

 already

 require

capped sample

 lines and no leakage

 from pumps

which

 would

 minimize

the

 flows

 into

 process

drains

and

 thereby

the

 need

for

 leak

 testing

process drains.”

Also, Stepan

 states,

 if drains are capped, potentially explosive

vapors could

 accumulate

 in the closed pipe causing

 injury.

Finally, Stepan asserts that

the

 final USEPA CTG drops all

reference to process drains as

 a fugitive emission source.

The Board

 is not persuaded

 to delete the reference

to

“process drains”: Stepan’s comments are not supported by the

record.

Stepan

 also suggested

 that

 a comma be inserted after

the

word

“flanges”

the

last

sentence

the

definition

clarify

that flanges

 are excluded and not flanges

 in heavy liquid

service.

The Board has added

 the comma

in

 the definition proposed

for

second notice.

COMPLIANCE

DATE

The Board’s

 first notice order noted the concerns regarding

the date

 for compliance with the proposed

 rules and

requested

comment on this issue.

 The Stepan Company proposed

 that

compliance begin December

31,

1988

 or one year

 after the adoption

of

 the regulations, whichever

 is earlier.

 Also,

 Stepan urged

that language be added

 to each section stating “Compliance will

be demonstrated by the completion of at least one monitoring

period by that date.”

 Stepan argued that this

 language allows

facilities additional time

 for compliance while demonstrating

to

USEPA

(1)

 that regulated facilities are taking

 reasonable

progress toward compliance

and

(2)

 that

 Illinois is achieving the

attainment of the ozone standard with this SIP.

ERG, noting the Board’s “dilemma”

 in attempting to balance

the rigorous statutory deadlines imposed by USEPA with the

mandate

 in Section 27

 of the Illinois Environmental Protection

Act

 (Act)

 to adopt regulations which are technically feasible and

economically reasonable,

 proposed to define compliance

 as having

a modified leak

 inspection

 and repair program

 in place by

82— 362

—5—

December

31,

 1987,

 which program

 requires actual field inspection

and repair activities

 to begin

 no later

 than July

1,

 1988.

ERG

argued

 that this change would allow sufficient time for

facilities

 to comply with the proposed rule,

 as well

as

demonstrate that Illinois

 is making reasonable further progress

 towards attainment of the ozone standard.

The Agency objected

 to ERG’s suggested approach.

 The Agency

noted

 that the mere filing of

 a “compliance plan” does not change

the effective date of the rule for Clean Air Act purposes.

 Also,

the filing of the plan would add

 a “bureaucratic step”

 to the

process

without

giving

the

Agency

any

control

power

reject

sufficient

plans.

The

Agency

further

noted

the

Board’s

decision

this

issue

its

Second

Notice

Opinion

R85—2l

(Docket

which

stated:

The

CAA

 requires

 that

 RACT

 rules,

 including

that

 proposed

 here,

be

in

 place

by

 December

31,

 1987.

 Jefferson

 Smurfit

(PC

#4,

 #27—31)

and

 Printpack,

 Inc.

(PC

 #25)

 have

 questioned

whether

it

it

 realistic

to

 expect

 compliance

by

 this

 same

 date,

 given

its

 immediacy.

The

Agency

contends,

however,

that

many

facilities

have

 already

 begun

 implementing

 compliance

plans

(R.

657),

and

that

presumably

therefore

 compliance

by

 December

31

 will

not

constitute

general

hardship.

Jefferson

Smurfit

(PC

#4,

#12,

#28,

#29)

and

Printpack,

 Inc.

(PC

 *25)

 have

 suggested

as

a

remedy

 that

 there

be

a

 provision

in

 the rule

which

 allows

 facilities

 from

one

to

 three

years

after

USEPA

approval

come

into

compliance.

However,

the

Board

does

not

believe

that

this

viable

option

because

there

is

no

 apparent

 authority

for

the

 Board

to

 adopt

a

 rule

 which

 features

a

 compliance

extension

 beyond

the

CAA

 December

31,

 1987,

deadline.

The

 Board

can

 only

 note

for

the

record

 that

 facilities

 unable

to

 meet

the

compliance deadline can petition the Board

for

variance pursuant

to

 Ill.

 Rev.

 Stat.,

ch.

ill

1/2,

 par.

1035

et

 seq.

and

35

 Ill.

 Adm.

 code

104.

 However,

in

so

 saying,

the

 Board

cautions

 that

it

is

 uncertain

 that

 variance

can be granted

 under

 the CAA.

The Agency also noted that the issue of the deadline

 is somewhat

tempered by the fact that the rule imposes

 a quarterly

 inspection

program.

 If the rule

 is effective December

31,

 1987, the first

quarterly

report

 will not be due until March

31,

 1988.

82—3 63

—6—

The Board

 believes that the

 proper course

 is that outlined

in R85-21

 (Docket B):

 The Board

 will not adopt

 a rule which

includes a compliance extension beyond

 the CAA December

31,

 1987,

deadline.

 As in R85—2l,

 the Board notes that facilities unable

to meet the deadline can petition

 for variance; however,

 the same

caveat applies.

BLEED PORTS OF LEAK PUMPS

 IN POLYMER SERVICE

In

 its comments,

 ERG stated that

 it has recently become

aware that certain kinds of equipment

 in VOC service are

“designed”

 to “leak” safely,

 but cannot be economically retro-

fitted

 or repaired.

 As an example, ERG cited bleed ports of gear

pumps commonly employed

 in manufacturing polymers,

 such as

polystyrene.

 ERG described this

 type of equipment as

 follows:

The

 shaft

 seals

 for these

 gear

 pumps

use

the

viscous

 polymer

 solution

for

 lubricating

the

shaft,

and

this

 lubricating

 fluid

 flows out of

the

seal

through

ports.

Upon

exposure

atmosphere,

the

polymer

solution

freezes

and

extrudes

out

the

port

strands.

the

exit

 port,

VOM

 concentrations

may

 exceed

10,000

ppmv.

The shaft seals

 on these gear pumps

in

polymer

service

are

an

 integral

 part

of

the

 pump

configuration.

 The manufacturer

of

 the pump

has stated that

 it is not possible

 to retrofit

another

 seal

 design.

 Moreover,

 simply

plugging the bleed ports will eventually cause

severe

 damage

to

the

 pumps

and

 reduce

 their

reliability.

(Note:

IERG

members

have

consistently

 achieved

98

 annual

 service

factor

with

this

design.)

Each

 pump

 would

cost

 more

 than

 $200,000

to

 replace,

and

at

least

one

 IERG

 member

has

 eight

 affected

pumps;

another

member

has

three

affected

pumps.

 One member

 estimates

 that the cost

of

exhaust

system

capture

and

control

these

emissions

its

facility

would

approximately

$200,000.

IERG

believes

that

inappropriate

for

capital

expenditure

$200,000

$1,600,000

stop

 these leaks

at

a

 plant

 whose

 total

 annual VOM emissions

are

less

 than 40 tons per year.

(Comments

 of Illinois Environmental Regulatory

Group,

 filed October

1,

 1987,

p.

 4—5).

ERG argued that “in

 these circumstances

it

 is not

appropriate even

 to monitor equipment, such as

 these gear pumps,

82— 364

—-7—

where

 the leaks

 are built

 into

 the design of

 the equipment, the

equipment operates safely,

 and the cost of control is clearly not

reasonable.”

 ERG stated

 that

 it met with representatives

 of the

Agency to discuss this issue,

 and the Agency requested more

information upon which

 to base its position.

The Agency’s comments noted the discussions

 with

 ERG and

stated that

 if the information

 it requested

 is included

in

 ERG’s

comments and

 if the information establishes ERG’s assertions,

then

 the Agency would believe

 it appropriate that this narrow

class of components not be considered

 to be “leaking”

for

purposes of this rule.

 Further the Agency suggested

 that

if

ERG’s information merits the exemption,

 the best solution would

be

 to simply state

 that these

 are not leaks,

 rather than state

that they are not components.

 The Agency suggested adding such

a

sentence

Section

215.430.

ERG,

however,

proposed

that

the

language

addressing

this

issue

included

the

definition

“Component”

Section

211.122.

ERG’s

reasoning

was

that

facilities

other

than

 those

identified

ERG,

 and possibly located

 in attainment counties,

may

have

similar

gear

pumps

polymer

service.

Initially,

the

Board

notes

that

issues

such

that

presented

here

are

best

discovered

 and addressed early

 in the

proceeding.

The

first

notice

public

comment

process

not

well

suited

permit

the

introduction

new

issues.

However,

the

Board

 will

 address itself to this issue because the emissions

from

 this equipment “designed

 to leak” appear

 to be de minimis

and the cost of replacement prohibitive.

The

Agency

has

informed

the

Board

comments

filed

October

15,

1987,

that

although

the

information

submitted

ERG

was

not

entirely

adequate,

too

viewed

these

emissions

minimis

and

the

cost

replacement

unreasonable.

The

Agency,

therefore,

supported

the

exemption.

The Board agrees that this type of equipment merits

exemption from the proposed regulations.

 The Board

 is persuaded

that

 the proper location for this exemption

is

in

 the definition

of “Component”

 in Section

 211.122.

 Located

 in this definition,

this equipment will

 be excluded from coverage

 in both attainment

and rionattainment areas.

 Exclusionary language therefore

is

included

 in the definition

 of component

 at second notice.

The Stepan Company commented

 on several other aspects

 of the

first notice order.

 First,

 Stepan suggested

 that

 a section be

added either

 in the definition of “component”

or

 in Section

215.430

 to indicate that the leak inspection requirements

 cover

only those components involved

 in the SOCMI manufacturing areas

which process more than 4033 tons of gaseous and/or light liquid

VOM’s per year,

 and not all

 other light liquid components within

82—3 65

—8—

the plant.

 Also, Stepan commented that equipment handling heavy

liquid

 chemicals should be exempt from the definition since

the

low pressure of these chemicals should allow for collection and

processing through wastewater treatment facilities or

as

a

 solid

waste.

The Board

 is not persuaded that the record establishes

justification for amendment

 to the definition of “component”

beyond

 that discussed above.

Second, Stepan suggested that

 a definition of

 “Light

Liquids”

added

Section

211.122.

Stepan’s

only

justification for such

 a definition was that USEPA’s CTG for

control of VOC

 leaks

 from

 SOC.MI includes such

 a definition.

The

Board

not

persuaded.

The

Board

not

required

adopt

regulations

 identical

 in substance

 to the USEPA CTG for control

VOC

leaks

from

SOCMI.

Third, Stepan suggested

 that the definition

 of heavy liquid

include

 a vapor pressure limit, such as 0.0019 psi, below which

materials would not be regulated.

 Stepan asserts that such

a

limit is necessary to reduce the cost burden on regulated

facilities, since very low vapor pressure liquids would have no

significant

impact

air

quality.

 The Board does not find the

record sufficient

 to justify Stepan’s assertions.

 Stepan has not

provided any estimates to demonstrate

 the anticipated

 cost burden

on regulated facilities.

 Further, Stepan offers no evidence

to

establish what impact low vapor

 pressure liquids will have on air

quality.

Fourth,

Stepan

suggested

that

amendments

made

proposed

Section

215.421

define

leak

instrument

reading

and

exclude process units at

 a facility which do not manufacture

synthetic organic chemicals or polymers,

 Stepan’s only

justification

for

defining

leak

instrument

reading

was

assert that under the regulation

 as proposed,

 “a leak detection

instrument

would

(1)

have

calibrated

for

each

organic

compound

(2)

require

response

factor

derived

for

each

compound relative

 to the calibration gas and each instrument

reading

subsequently

multiplied

that

factor

determine

the

hydrocarbon concentration, which is confusing and time consuming,

 could delay compliance and may make compliance difficult to

determine.”

 Stepan offered

 no justification for

 the exclusions

proposed.

The Board finds

 little support

 in the record

 for Stepan’s

assertions.

 Therefore,

 the Board cannot accept Stepan’s proposed

changes.

 The Board

 can only note that

 a facility unable or

unwilling to comply with the proposed regulations has the option

petition

for

variance

seek

site—specific

rule.

82—366

—9—

Fifth,

Stepan

proposed

amendments

Section

215.432

follows:

Test

quarterly

e~he~

~re~t~e

~

serv~ee

pumps

light

liquid

 service,

 valves

light

liquid

~erv~ee

and

~n

gas

 service,

and

compressors.

Test

any

pressure

relief

valve

initially

and

thereafter

within

hours

after

has

vented

the

atmosphere.

Any

component

that

vacuum

service,

pressure

 relief devices connected

to

an

operating

flare

header,

vapor

recovery

devices

open—ended

valves

are

 exempt

 from

the

 monitoring

 devices

in this Section.

Stepan

argued

that

the

requirement

that

workers

monitor

and

annually

test

components

which

are

“unsafe”

monitor

routinely,

unnecessarily

exposes

employees

hazardous

situations

and

exposes

employers

unreasonable

liabilities.

Stepan

argued

that because of

 the small

 number

such

“unsafe”

components

annual testing

 is unnecessary, and

 if required at

 all should

be

conducted

when

monitoring

safe.

the

deletion

the

 quarterly testing requirement

 for pressure relief valves in

gaseous service, Stepan argued that

if

 a pressure

 relief valve

is

tested initially and found

not

 to leak there

is

 a substantial

likelihood

 that the valve will not leak until

 it relieves and

does not properly reset.

 Stepan proposed exemption of open—ended

valves

“due

the

fact

that

open

ended

valves

 are required

 to be

capped or plugged.”

 Stepan asserted that leakage around

the

valve seated surface

 is unlikely and,

 if at all, de minimis.

Based

 on the existing

 record, the Board cannot adopt

Stepan’s

suggestions.

Stepan

has

not

adequately

justified

its

assertions.

previously

noted,

facility

unable

unwilling

comply

with

the

proposed

regulations

 may seek relief through

other means.

Finally, the Board notes

 that

 it has made non—substantive

typographical

changes

throughout

the

 text of the proposed

amendments.

 Also, proposed

 Sections 215.420 and 215.430

incorporated certain materials by reference.

 Language was added

to indicate that

 the materials are formally incorporated,

pursuant

 to Section 6.02(a)

 of the Illinois Administrative

Procedure Act and

 1 Ill. Adm. Code 220.760,

 in Section 215.105.

82—367

-10-

ORDER

The following amendments to

35

 Ill.

Adm.

Code

 211 and 215

are directed

 to the Joint Committee on Administrative Rules for

second notice review.

DEFINITIONS AND GENERAL PROVISIONS

Section 211.122

 Definitions

“Component”:

 Any piece of pe~e~r~fef4t~e~yequipment

which

has

the

potential

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.

This

 definition excludes valves which are

not externally regulated,

 flanges, and equipment

in

heavy liquid service.

 For purposes of Subpart

Q,

 this

definition

also

excludes

bleed

ports

gear

pumps

polymer

service.

Section 215.104

 Definitions

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~

 p~p ee~i~7eeMpres~e~see~87 ~

e~ ~e~r~g

 ven~7 ~pe~ne

 ~e~ve~7 p~es~refeef

~ev~ee~- p~eee~

~

 e~dopen em~edp4pe~- P1’~~

defn~~e~exe~t~e~

 ve~ve~wh~4e~tere ne~ex~efrteHy

fe~e~ed~7f~enge~en~~

 ~n l~eevy~

eefv4ee~

 For ~rpeses

of

S~bor~

~4S

~iso

 e,~e~t~dee

~

 e~ ~

 ve~vee~

“In Vacuum Service:”

 For the purposes of Subpart

Q,

Sections 215.430 through 215.438 equipment which is

operating at an internal pressure that

 is at least

 5 kPa

(0.73

 psia) below ambient pressure.

“Open—Ended/Valve”:

 Any valve,

 except pressure relief

devices,

having

one

side

 the valve

 in contact with

process

fluid

and

one

side

open

the

atmosphere,

either

directly

through

open

piping.

“Repaired”:

 For the purposes of Subpart

Q,

 Sections

215.430 through 215.438 equipment component which

is

adjusted,

 or otherwise altered,

 to eliminate

 a leak.

SUBPART

 LEAKS FROM SYNTHETIC ORGANIC CHEMICAL

AND POLYMER MANUFACTURING EQUIPMENT

Section 215.420

 Applicability

82—368

—11—

The provisions of Sections

 215.421 through 215.429 of this

subpart

 shall apply to all plants

 in the State of

 Illinois which

manufacture synthetic organic chemicals and polymers,

 except

those located

 in any of the following counties:

 Will,

 McHenry,

Cook,

 DuPage,

 Lake,

 Kane,

 Madison,

St.

 Clair, Macoupin, and

Monroe.

 The provisons of Section

 215.430 through 215.438 shall

apply to the counties specifically enumerated above.

In addition,

 if any county is redesignated as nonattainment by

the USEPA subsequent to December

31,

 1987, the owner

 or operator

of

 a plant located

 in that county shall comply with the

requirements of Sections 215.430 through 215.438 upon the

effective date of the redesignation.

(Source:

 Added at

 Ill.

 Reg.

 effective

)

Section 215.421

 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

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—~260, E—l68,and E—l69~, incorporated

by reference

 in Section 215.105.

 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 215.428

 Compliance Dates emd Geegre~h~ee~

 Arees

e-)

 Exee~ ee etherw~ee~e~ed

~

 see~4e~-(b-ti eEvery

owner or operator of

 a synthetic organic chemical or

polymer manufacturing plant subject

 to Sections

 215.421

through

 215.427 shall comply with the standards and

limitations of those Sections beginning Oe~eber33~7~98S

December

31,

 1987.

 e p~e~4e ~

 ~eee~e~

 4t~one of

the

 eeün~es ~e~ed

be~ow7

the owner or e~ere~orof the ~et~

~

 eem~y

with

the

 re~4remen~e? See~ene

 5~429 through

5-4~6

no ~e~er ther~Beeey~ber3~

Bend

MeHenry

eeok

 Monroe

BeKe~h

 Mon~gon~ery

BuPege

 Morgen

82—369

—12—

Pe~e

6reene

Se~ne

~ersey

Sengamort

~ehneon

 S~ e~e4r

bake

Maeoup4n

~Board

no~e~ eoun~es

are

dea~gna~edae

a~e~nmen~of

nona~e~nmen~

 for o2erie by the ~n4~ed S~e~es

Env~renmenth~Pro~ee~onAgency +USBPA+~-

The

 ~SBPA

noted

 4n ~s

 redee4gne~on ru~emek4ngythe~4~w4H

p~4eh a ru~emek~ngno~4ee on W4

 ~em~en eeun~y.Le

ath~u~ ~

 Ped~Reg-~~949~’ May i~6y

&~--)

 Shou~dW4H4emeon eeun~y~e redes4gne~ed as

~e-inmen~ pr4er

 ~o Oe~ober

3~r

~9857

and the

eoun~es eon~guous th ~ w4~ be eons~deredde~e~ed

from the ebeve

 s~-~

e-3~

 No~w~hsthnd~ngsubsee~on~b3~

 ~f any eoun~y ~s

redes4gne~edas nona~e~nmen~

 by the ~SEPA a~any ~4e

subseguen~~o the effee~ve date of

~h~S

 See~en7 the

owner

 or e~era~orof a ~em~

 ~cee~ed

 4n the~eeun~ywho

weu~d

otherw4se by sub~ee~~o the eomp~enee de~ei~n

~see~on

 +b~she~ eomp~yw4th the reg~remen~sof

See~ons ~5~-4~9

 through ~5-4~&

 w4th~none

 year from

the de~eof redes~gne~4onbu~~n no ease ~a~er

then

Beeember ~

(Source:

 Amended at

11

 Ill.

 Reg.

___,

 effective

___________

Section 215.429

 Compliance Plan

a)

 The owner or operator of

 a synthetic organic chemical

or

polymer manufacturing plant subject

 to Section

2l5.428~(-e+or ~

 shall

 submit to the Agency

a

compliance plan,

 no later

 than December 31, l98S7.

b~

 The owner or opere~erof

 a p~en~sub~ee~~o See~on

5~4~+e-3ehe~ subm~ a eom~~enee~en

 w~h~n~G days

ef~erthe da~eof redes4gne~on7 bu~~n no ease ~e~er

than Beeember 3~7~9&6~-

e~

The

owner

o~era~orof

p~an~

sub~ee~~o See~on

~-4~+e-~

sha~

no~ be

regu~4red ~o

subm~

eem~~enee

~f redes~gne~enoccurs after Becember 3~7~9&6~-

db)

 The plan and schedule shall meet the requirements of

35

Ill. Adm. Code

 201.

(Source:

Amended

Ill.

Reg.

___,

 effective

__________)

82—370

Section 215.430

 General Requirements

The owner or operator of

 a plant which processes more than 3660

Mg/yr

 (4033 tons/year)

 gaseous 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—l68,

 E—l69 and

 E—260,

 incorporated by

reference

Section

215.105.

component

shall

considered

be leaking

 if the volatile organic material

 is equal

to,

or

is

 greater

 than 10,000 ppmv

 as methane or

 hexane as determined

by

USEPA Reference Method

21,

 as specified at

 40 CFR 60, Appendix

A,

incorporated by reference

 in Section 215.105, 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 equipment components are used

to

produce heavy liquid chemicals only from heavy liquid feed

 or raw

materials.

(Source:

 Added at

 11 Ill.

 Reg.

____,

 effective

___________

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.

 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

pipeline valves,

 pressure relief valves

 in gaseous

service, all leaking components, and components exempted

under Section 215.432(i)

 such that they are obvious

and

can be located

 by both plant personnel performing

monitoring

 and Agency personnel performing inspections.

(Source:

 Added at

11

 Ill.

 Reg.

___,

 effective

__________

Section 215.432

 Inspection Program for Leaks

82—371

—14—

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

 or 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

liquid

 service and

 in gas service, and compressors.

c)

If

less

 than or equal

to

 2 percent of the valves

in

light 1iguid 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 lighE

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.

d)

 Observe visually all pump seals weekly.

e)

 Test immediately any pump seal from which liquids are

observed drippin~g.

f)

 Test any relief valve within 24 hours after

 it has

vented

 to the atmosphere.

~j

 Routine

 instrument monitoring

 of valves which are not

externally regulated, flanges, and equipment

 in heavy

liquid

 service,

 is not required.

 However, any valve

which

 is not externally regulated,

 flange,

 or piece of

equipment

 in heavy liquid service

 that

 is found

 to be

leaking on the basis of sight,

 smell or sound

 shall

be

repaired as soon as practicable but

 rio later than

30

days after

 the leak

is

 found.

h)

 Test immediately after

 repair

 any component that was

found leaking.

i)

 Within

 1 *lour

 of its detection,

 a weatherproof and

readily visible ta2 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.

82—372

-15-

jj

 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.

(Source:

 Added

at

11

 Ill.

 Reg.

___,

 effective

__________

Section 215.433

 Repairing Leaks

All leaking components must be repaired and retested

 as soon

as

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.

(Source:

 Added

at

11

 Ill.

 Reg.

___,

 effective

Section

 215.434

 Recor.dkeeping

 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

 The type of component

 (e.g., valve, seal)

3)

 The identification number

 of the component

 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

The

total

number

valves

light

liquid

service

and

 in gas service

 inspected, the total number and

the percentage

 of these valves

 found

 leaking during

the monitoring period.

82—373

—16-

 Copies of the monitoring log shall be retained by the

owner or o~erator for

 a minimum

 of two years after

the

date on which

 the record was made

 or the report

p~pared.

c)

 Copies of the monitoring

 log shall

 be made available

to

the Agency upon verbal or written request, at any

reasonable

 time.

(Source:

 Added

at

 11 Ill. Reg.

___,

 effective

__________)

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 215.438

shall:

a)

 Submit

 a report to 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 15 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.

 Submit

 a signed statement with the report attesting that

all monitoring

 and repairs were preformed

 as required

under Section 215.430 through 215.436.

(Source:

 Added

 at 11

 Ill.

 Reg.

___,

 effective

Section 215.436

 Alternative Program

 for Leaks

The Agency shall

 approve an alternative program of monitoring,

recordkeeping,

 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.

(Source:

 Added

at

 11 Ill.

 Reg.

___,

 effective

)

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.

82—374

—17—

 Each open—ended valve equipped with

 a second valve shall

be operated

in

 a 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:

 Purged process

 fluid

 be returned

 to the process

line with zero VOM emissions

 to atmosphere,

or

 Purged process

 fluid be collected and recycled

to

the process

 line with zero VOM emissions to

atmosphere.

(Source:

 Added

 at 11

 Ill.

 Reg.

___,

 effective

___________

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.

(Source:

 Added at

11

 Ill.

 Reg.

 effective

IT

 IS SO ORDERED.

I, Dorothy

M.

 Gunn, Clerk

of

 the Illinois Pollution Control

Board,

 hereby certify that the above Propos~ Opinion and Order

was adopted

 on the

/..5~

 day of

c~J~~_c~

 1987 by

a

vote of

_________________

Do

Illino

 Pollut

 Control Board

82—375