ILLINOIS POLLUTION CONTROL BOARD
September 11, 1986
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 an August 26, 1985,
Illinois Environmental Protection Agency (“Agency”) motion to
reopen the record in this regulatory proceeding concerning the
internal offset rule (Section 215.207), coke manufacture and by-
product recovery (Part 215, Subpart U) and petroleum solvent dry
cleaners (Part 215, Subpart Z). That motion was granted and
hearings were authorized on September 20, 1985. This opinion and
order addresses the Agency’s regulatory proposal regarding
petroleum dry cleaners.
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
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 lfl 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
72-343
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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 Clean Air Act, the mandate to
adopt the CTG5 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).
This federal policy statement includes yet another
requirement which is relevant to this rulemaking. The USEPA
allows the states until the January after one year from the
finalization of a CTG to adopt either the “rules” contained
therein, or comparable rules, if sources covered by that
particular CTG are within a state’s non—attainment areas. A
final CTG for petroleum dry cleaners was issued in September of
1982 (Ex. 29(c))
The Agency amended its regulatory proposal on November 25,
1985. Hearings were held December 2 and 3, 1985, in Chicago and
March 20 and 21, 1986, in Bollingbrook. The Agency made final
amendments to its proposal on May 8, 1986, in response to
testimony and comments made at hearing by the Illinois Fabricare
Association (“IFA”). The Department of Energy and Natural
Resources (“DENR”) issued a letter of negative declaration of
economic impact, obviating the need for further economic analysis
of the proposed rules, on March 24, 1986. The concurrence of the
Economic and Technical Advisory Committee to the DENR was filed
on May 22, 1986. The record in this matter closed on June 12,
1986 (Hearing Officer Order, May 29, 1986).
The Board, in a prior opinion, declined to adopt rules
regulating petroleum dry cleaners as neither of the two
facilities known to exist in the state would have been subject to
the rules as proposed. One facility fell below the regulatory
quantity of emissions threshold and the other facility was
located in an attainment county and utilized a different process
than envisioned by the proposed rules (Board Opinion, August 22,
1984, pp. 39—40). At hearings held December 2 and 3, 1985, the
Agency identified two major stationary sources located in non—
attainment areas that would be regulated.
Petroleum solvent dry cleaning is a batch process in which
articles are washed and dried in separate operations. Articles
are sorted and placed in appropriate washers where they are then
agitated 4n the petroleum solvent. Heavily soiled articles may
go through two or more wash cycles; the first is with recycled,
soiled solvent and the second is with clean solvent. After
completion of the wash cycle, the articles are spun at high
speeds to remove excess solvent, usually in the same equipment
used for washing, but sometimes in a separate, high speed
centrifugal extractor. The soiled solvent extracted during the
72-3~
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spin cycle may be passed through a filter to remove insoluble
soils and/or passed to a vacuum still where the solvent is
purified. The distilled solvent is pumped to a holding tank or
is returned to the washer/extractor. When the spin cycle has
terminated, articles are transferred from the washer/extractor to
a dryer (tumbler) (R. 3194—95).
The CTG lists the major emission sources as the dryers,
solvent filtration systems and miscellaneous fugitive sources.
The nominal emission rate from a standard petroleum solvent dryer
is 14 kg to 18 kg volatile organic material (“VOM”) per 100 kg of
dry weight of articles cleaned. Proposed Section 2l5.607(a)(1)
would require this rate to be reduced to 3.5 kg VOM per 100 kg of
dry weight which amounts to a RACT control efficiency of 75 to 81
percent. The normal control method for achieving this reduction
would be to install recovery dryers in place of standard
dryers. A solvent recovery dryer has a condenser to remove
solvent vapor from the dryer exhaust by condensation (R. 3195).
The emissions from the solvent filtration system are those
released from the diatomite filter systems, which the CTG
estimates as 8 kg VOM per 100 kg of clothing throughput.
Proposed Section 216.607(b)(l) would require reduction to 1.0 kg
per 100 kg throughput for an average control efficiency of 88
percent. The CTG—recommended control method to achieve this
reduction would be to install cartridge filters in place of
diatomite filters. The emissions from cartridge filters are
derived from fugitive emissions due to leaks and cartridge filter
replacement, as well as from the solvent contained in the
disposed cartridge. The emissions were estimated by the CTG to
range from 0.35 to 0.75 kg VOM per 100 kg clothing throughput (R.
3195—3196).
The other sources, i.e., the vacuum still waste and the
miscellaneous fugitive sources are grouped in one general
category of fugitive emissions. The CTG states that improved
operation of equipment, good housekeeping practices and
inspection and repair of leaks should reduce emissions to 4.0 kg
solvent per 100 kg dry weight. Considering these control
measures as a whole, the reductions required by the proposed
rules would give emissions of 8.5 kg volatile organic material
per 100 kg of clothing processed (R. 3196).
The Agency conducted a field survey of petroleum dry
cleaning facilities in non—attainment areas. Six plants were
identified in Cook County. Four plants have emissions less than
100 tons/year and would be exempted by proposed Section
215.611. One of the two plants affected by the proposal, A.W.
Zengler, has already installed four recovery dryers and cartridge
filters. RACT compliance for this plant would require
installation of four more recovery dryers. The other affected
plant, Careful Cleaners, has seven standard dryers and would have
72.345
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to install five or six recovery dryers (depending upon size
chosen) and to replace four diatomite filters with 11 cartridge
filters. The anticipated reductions from A.W. Zengler would be
approximately 51 tons/year and from Careful 82 tons/year. These
reductions are based upon the assumption that installation of
RACT controls would reduce emissions to the level of 8.5 kg VOM
per 100 kg dry clothing from the 14.8 kg VOM for A.W. Zengler and
from 30.4 kg VOM from Careful (R. 3197—3199, Ex. 90).
Based upon the cost information provided by the CTG,
controls costs were developed for the two plants affected by the
proposed regulation. The resultant costs are $350 per ton for
A.W. Zengler and $650 per ton for Careful (R. 3199—3202). These
estimates are well within the ranges of control costs for other
RACT categories. Industry has not refuted these cost estimates.
At the December 2, 1985, and March 20, 1986, hearings, the
IFA presented oral and written comments on the Agency proposal
(R. 3208—3214, 3668—3670, P.C. 74). While expressing agreement
with the Board’s earlier decision not to regulate this segment of
the industry, they indicated that they had no real opposition to
the rule and, after review by their association technical staff,
suggested certain refinements and improvements to the Agency
proposal. These have been incorporated in the Agency’s most
recent amended proposal (Motion to Supplement the Record and to
Propose Adoption of Regulations Applying to Petroleum Solvent Dry
Cleaners, May 8, 1986).
The geographical applicability of the proposed rules is more
limited than the earlier 1982 proposal. The current proposal is
applicable in counties that are either non—attainment counties
for ozone or are part of the major urbanized areas associated
with the non—attainment counties. The Agency moved to amend
their proposal by adding Macoupin County on May 8, 1986 (Id.)
While no major petroleum dry cleaning facilities are located in
Macoupin County, 1985 air monitoring data indicates that Macoupin
County is non—attainment for ozone. The Agency’s proposal in
this subcategory is consistent with the recent scope of
applicability proposed for first notice by the Board in another
RACT proceeding, R85—2l.
The Board will propose rules regulating petroleum dry
cleaners for first notice as a final CTG for this category has
been issued, sources in non—attainment areas have been identified
and the rules constitute RACT. Cost effectiveness of RACT
reductions are within a reasonable range. A total of 133
tons/year of VOM emissions will be eliminated in the Chicago
area, a non-attainment area for ozone. This action will also
help fulfill the state’s legal obligations to demonstrate that
existing major stationary emission sources in non—attainment
areas are subject to regulations representing RACT.
72-346
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As a final note, the Board has concerns regarding the
legality and JCAR approvability of Section 215.612(b) which
provides that should an attainment county be redesignated as non—
attainment at some point in the future, that the regulations
shall be applicable to that county and contiguous counties.
Participants, and specifically the Agency, are requested to
comment on this issue and submit alternative language for
consideration by the Board.
ORDER
The following amendments to 35 Ill. Adm. Code 215 are
directed to first notice for publication in the Illinois
Register:
TITLE 35: ENVIRONMENTAL PROTECTION
SUBTITLE B: AIR POLLUTION
CHAPTER I: POLLUTION CONTROL BOARD
PART 215
ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS
SUBPART A: GENERAL PROVISIONS
Section
215.100 Introduction
215.101 Clean—up and 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
72-347
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215.144 Safety Relief Valves
SUBPART E: SOLVENT CLEANING
Section
215.181
215.182
215.183
215.184
215.185
Section
215.202
215. 204
215.205
215.206
215.207
215.208
215.209
215.210
215.211
215.212
215.213
Section
215. 301
215. 302
215.303
215.304
215.305
Section:
215. 340
215. 342
215. 344
215.345
215.346
215.347
Solvent Cleaning in General
Cold Cleaning
Open Top Vapor Degreasing
Conveyorized Degreasing
Compliance Plan
SUBPART F: COATING OPERATIONS
Compliance Schedules
Emission Limitations for Manufacturing Plants
Alternative Emission Limitations
Exemptions from Emission Limitations
Internal Offsets
Testing Methods for Solvent Content
Exemption from General Rule on Use of Organic Material
Alternative Compliance Schedule
Compliance Dates and Geographical Areas
Compliance Plan
Special Requirements for Compliance Plan
SUBPART K: USE OF ORGANIC MATERIAL
Use of Organic Material
Alternative Standard
Fuel Combustion Emission Sources
Operations with Compliance Program
Viscose Exemption (Repealed)
SUBPART N: VEGETABLE OIL PROCESSING
Hexane Extraction Soybean Crushing
Hexane Extraction Corn Oil Processing
Recordkeeping for Vegetable Oil Processes
Compliance Determination
Compliance Dates and Geographical Areas
Compliance Plan
SUBPART P: PRINTING AND PUBLISHING
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Section
215.401
215.402
215.403
215. 404
215.405
215. 406
215.407
Section
215.420
215.421
215.422
215.423
215.424
215.425
215.426
215.427
215.428
Section
215.441
215. 442
215. 443
215.444
215.445
215. 446
215.447
215.448
215.449
215.450
215.451
215.452
215.453
Flexographic and Rotogravure Printing
Exemptions
Applicability of Subpart K
Testing and Monitoring
Compliance Dates and Geographical Areas
Alternative Compliance Plan
Compliance Plan
SUBPART 0: SYNTHETIC ORGANIC CHEMICAL AND POLYMER
MANUFACTURING
General Requirements
Inspection Program Plan for Leaks
Inspection Program for Leaks
Repairing Leaks
Recordkeeping for Leaks
Reporting for Leaks
Alternative Program for Leaks
Compliance Dates and Geographical Areas
Compliance Plan
SUBPART R: PETROLEUM REFINING AND RELATED
INDUSTRIES; ASPHALT MATERIALS
Petroleum Refinery Waste Gas Disposal
Vacuum Producing Systems
Wastewater (Oil/Water) Separator
Process Unit Turnarounds
Leaks: General Requirements
Monitoring Program Plan for Leaks
Monitoring Program for Leaks
Recordkeeping for Leaks
Reporting for Leaks
Alternative Program for Leaks
Sealing Device Requirements
Compliance Schedule for Leaks
Compliance Dates and Geographical Areas
SUBPART S: RUBBER AND MISCELLANEOUS
PLASTIC PRODUCTS
Manufacture of Pneumatic Rubber Tires
Green Tire Spraying Operations
Alternative Emission Reduction Systems
Testing and Monitoring
Section
215.461
215.462
215.463
215.464
72.349
—8—
215.465 Compliance Dates and Geographical Areas
215.466 Compliance Plan
SUBPART U: COKE MANUFACTURE AND
BY-PRODUCT RECOVERY
Section
215.500
215.510
215.512
215.513
215.514
215.515
215.516
215.517
Exception
Coke By—Product Recovery Plants
Coke By—Product Recovery Plant Leaks
Inspection Program
Recordkeeping Requirements
Reporting Requirements
Compliance Dates
Compliance Plan
SUBPART W: AGRICULTURE
Section
215.541 Pesticide Exception
Architectural Coatings
Paving Operations
Cutback Asphalt
Section
215. 581
215. 5 82
215. 583
Section
215.601
215. 602
215.603
215.604
215.605
215. 606
215.607
205
.
608
215. 609
Bulk Gasoline Plants
Bulk Gasoline Terminals
Gasoline Dispensing Facilities
SUBPART Z: DRY CLEANERS
Perchloroethylene Dry Cleaners
~xemptions
Testing and Monitoring
Compliance Dates and Geographical Areas
Compliance Plan
Exception to Compliance Plan
Standards for Petroleum Solvent Dry Cleaners
Qperating Practices for Petroleum Solvent Dry Cleaners
Program for Inspection and Repair of Leaks
Section
215.561
215.562
215. 563
SUBPART X: CONSTRUCTION
SUBPART Y: GASOLINE DISTRIBUTION
72.350
—9—
215.610
215.611
215.612
215.613
Testin2 and Monitoring
Exemption for Petroleum Solvent Dry Cleaners
Compliance Dates and Geographical Areas
Compliance Plan
Appendix A Rule into Section Table
Appendix B Section into Rule Table
Appendix C Past Compliance Dates
Appendix D List of Chemicals Defining Synthetic Organic
Chemical and Polymer Manufacturing
PART 215
ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS
SUBPART A: GENERAL PROVISIONS
Section 215.104 Definitions
“Volatile Organic Material”: Any organic material
which has a vapor pressure of 17.24 kPa (2.5 psia) or
greater at 294.3 K (70°F). For purposes of this
definition, the following are not volatile organic
materials:
Methane
Ethane
1,1 ,l—trichloroethane
Methylene chloride
Tr ichlorofluoromethane
Dichlorod ifluoromethane
Chlorodifl uoromethane
Trifluoromethane
Tr ichlorotrifl uoroethane
Chloropentafluoroethane
For purposes of the following Sections, volatile
organic materials are any organic materials having the
corresponding vapor pressures at 294.3 K (70°F):
Sections
215.181
—
215.184
215.104
—
215.209
215.340
—
215.345
215.401
—
215.408
215.420
—
215.428
215.441
—
215.444
215.445
—
215.451
215.461
—
215.464
215.510
—
215.513
215.601
—
215.69313
psi a)
Vapor Pressure
0.013 kPa
(
.0019 psia)
0.013 kPa
(
.0019 psia)
0.013 kPa
(
.0019 psia)
0.013 kPa
(
.0019 psia)
0.013 kPa
(
.0019 psia)
10.34 kPa (1.5 psia)
0.013 kPa
(
.0019 psia)
0.013 kPa
( .0019
psia)
0.013 kPa
0.013
( .0019
psia)
kPa( .0019
(Source: Amended at
Ill. Reg.
_______,
effective
_________)
72-351
—10—
SUBPART Z: DRY CLEANERS
Section 215.607 Standards for Petroleum Solvent Dry Cleaners
a) The owner or operator of a petroleum solvent dry
cleaning dryer shall either:
1) Limit emissions of volatile organic material to the
atmosphere to an average of 3.5 kilograms of
volatile organic material per 100 kilograms dry
weight of articles dry cleaned, or
2) Install and operate a solvent recovery dryer in a
manner such that the dryer remains closed and the
recovery phase continues until a final solvent flow
rate of 500 millilitersper minute is attained.
b) The owner or operator of a petroleum solvent filtration
system shall either:
1) Reduce the volatile organic material content in all
filtration wastes to 1.0 kilogram or less per 100
kilograms dry weight of articles dry cleaned,
before disposal, and exposure to the atmosphere, or
2) Install and operate a cartridge filtration system,
and drain the filter cartridges in their sealed
housings for 8 hours or more before their removal
(Source: Added at
____
Ill. Reg.
_______,
effective
___________)
Section 215.608 Operating Practices for Petroleum Solvent Dry
Cleaners
The owner or operator of a petroleum solvent dry cleanin~
facility shall employ good housekeeping practices to minimize
fugitive solvent emissions including, but not limited to, the
following:
a) General Housekeeping Requirements
1) Equipmentextractors containingand
filters)solventshall
(washers,remain
closeddryersat1 all
times except during load transfer and
maintenance. Lint filter and button trap covers
shall remain closed except when solvent—laden
material is being removed.
2) Cans, buckets, barrels and other containers of
solvent or of solvent—laden material shall be
covered except when in use.
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3) Solvent—laden material shall be exposed to the
atmosphere only for the minimum time necessary for
load transfer.
b) Installation and operation of equipment
1) All cartridge filters shall be installed and
operated in accordance with the procedures and
specifications recommended by the manufacturer for
the cartridge filter.
A) After installation, the cartridges shall be
inspected, monitored and maintained in
accordance with the manufacturer’s
recommendations, and
B) Operators shall be thoroughly familiar with
the filtration system’s performance, safety
and maintenance requirements.
2) Vents on containers for new solvent and for
solvent—containing waste shall be constructed and
maintained so as to minimize solvent vapor
emissions.
(Source: Added at
Ill. Reg.
,
effective
___________)
Section 215.609 Program for Inspection and Repair of Leaks
a) The owner or operator of a petroleum solvent dry
cleaning facility shall conduct the following visual
inspections on a weekly basis:
1) Washers, dryers, solvent filters, settling tanks,
vacuum stills and containers and conveyôrs of
petroleum solvent shall be inspected for visible
leaks of solvent liquid.
2) Pipes, hoses and fittings shall be inspected for
active dripping or dampness.
3) Pumps and filters shall be inspected for leaks
around seals and access covers.
4) Gaskets and seals shall be inspected for wear and
defects.
5) All other potential sources of fugitive emissions
shall be inspected for evidence of leaks.
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b)
Leaks of petroleum solvent liquid and vapors shall be
repaired within three working days of detection, unless
iiecessary replacement parts are not on site.
1) If necessary, repair parts shall be ordered within
Three working days of detection of the leak.
2) The leak shall be repaired within three days of
delivery of necessary parts.
(Source: Added at
Ill. Reg.
_______,
effective
_)
Section 215.610 Testing and Monitorir~,g
a) Compliance with Sections 2l5.607(b)(2), 215.608 and
215.609 shall be determined by visual inspection; and
b) Compliance with subsections 2l5.607(a)(2) and (b)(l)
shall be determined by methods described in EPA—45073—
82—009 or by procedures approved by the USEPA.
c) If a control device is used to comply with subsection
2l5.607(a)(l), then compliance shall be determined
using 40 CFR 60 Appendix A, Method 25 (1984).
(Source: Added at
Ill. Reg.
,
effective
___________
Section 215.611 Exemption for Petroleum Solvent Dry Cleaners
The provisions of Sections 215.607 through 215.610 shall not
apply to petroleum solvent dry cleaning facilities whose
emissions of volatile organic material do not exceed 91 megagrarns
(100 tons) per year in the absence of pollution control equipment
or whose emissions of volatile organic material, as limited by
the operating permit, will not exceed 91 megagrams (100 tons) per
year in the absence of pollution control equipment.
(Source: Added at
____
Ill. Reg.
_______,
effective
___________)
Section 215.612 Compliance Dates and Geographical Areas
a) Owners and operators of emission sources located in the
counties listed below shall comply with the
requirements of Sections 215.607 through 215.609 as
expeditiously as practicable but no later than December
31, 1987:
Cook
Madison
DuPage
McHenry
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Kane
Monroe
Lake
St. Clair
Macoupin
Will
b) Notwithstanding subsection (a), if any county is
designated as non—attainment by the USEPA at any time
subsequent to the effective date of this Section, the
owner or operator of an emission source located in that
county or any county contiguous to that county, who
would not otherwise be subject to the compliance date
in subsection (a), shall comply with the requirements
of Sections 215.607 through 215.610 within one year
from the date of redesignation but in no case later
than December 31, 1987.
(Source: Added at
Ill. Reg.
_______,
effective
___________)
Section 215.613 Compliance Plan
a) The owner or operator of an emission source subject to
Section 215.610(a) shall submit to the Agency a
compliance plan, including a project completion
schedule where applicable, no later than December 31,
1986.
b) The owner or operator of an emission source subject to
Section 215.610(b) shall submit a compliance plan,
including a project completion schedule, within 90 days
after the date of redesignation.
C)
The owner or operator of an emission source subject to
Section 215.610(b) shall not be required to submit a
compliance plan if redesignation occurs after December
31, 1986.
d) The plan and schedule shall meet the requirements of 35
Ill. Adm. code 201.
(Source: Added at
Ill. Reg.
_______,
effective
________
)
IT IS SO ORDERED.
Chairman 3D. Dumelle and Board Member 3. Theodore Meyer
dissented.
72-355
—14—
I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control
Board, hereby certify that the bove Opinion and Order was
adopted on the /Pr~ day of
_____________,
1986, by a vote
of
.~
.
Dorothy M.l~inn, Cler~k
Illinois Pollution Control Board
72-356
