ILLINOIS POLLUTION CONTROL BOARD

May 30,

1985

 THE MATTER OF:

)

VOLATILE ORGANIC MATERIAL

)

 R82—14

E~1ISSIONSFROM STATIONARY

)

 Dockets A

& B

SOURCES:

 RACT III

?ROPOSED

 ORDER:

 FIRST NOTICE.

OPINION AND ORDER OF

 TfiE BOARD

 (by B.

 Forcade):

 June 14 and August 10,

 1984,

the

 Board adopted first

notice orders,

 and on August 22,

 1984,

 an accompanying opinion

proposing amendments and new rules for the control of volatile

organic emissions from five industrial categories.

 One of these

categories, heatset web offset lithographic printing, has been

the

subject

 of great confusion and controversy.

 At first notice,

the

Board

proposed

rules

that

contained

elements

the

original

Illinois Environmental Protection Agency

 (“Agency”) proposal,

as

well

 draft version submitted by the heatset web offset

printing industry (“Industry”).

 Public comments received during

first notice cited many problems with the proposed rule

 (P.C.

54,

 & 62).

apparent,

upoii

review

the

 record and comments,

 that

the

rule

proposed

 first notice needs substantial revision.

It

 also apparent that the current record

 for this category

is

inadequate to develop satisfactory language and consequently

needs

 to be supp1emente~

 Therefore,

 the Board in its second

notice

 opinion and order dated

 today, withdraws the heatset web

offset

 rules

 in their present form,

 The instant opinion and

order

 proposes new draft rules

 for the purpose

 of generating

comments

 and criticisms.

 The record,

as

 exists

 today, does

not

 adequately support certain aspects of these new proposed

rules.

 The Board

 is not advocating

 this proposed language but

using this second first notice opinion and order

as

 a vehicle

for

reopening the record

in

this

 category and outlining the

unresolved issues.

The Board’s

first

 notice rule presented today

 is based on

the

now

“terminated”

 draft CTG for this category

 (Ex.

 24o).

While

the

effect

this

 “termination,” by letter dated March

22,

1982,

from

USEPA

Deputy

Administrator

John

Hernandez

somewhat

ambiguous,

the

draft

CTG

document

still

 useful

as

 a source of

64-1b~’

information and general guidance.*

 The new language will provide

a starting point to develop an achievable

 and reasonable

 rule

Consequently,

 a new hearing will be scheduled for

 this category

in order

 to supplement

 the existing record.

Before

 a discussion of the problems associated with the

i3oards proposed rule can proceed,

 it is necessary to review the

potential volatile organic material

 (“VOM”)

 emission sources from

the heatset web offset printing process

 (a more detailed

description

 is found on pp.

 11—17

of

 the Board’s August 22,

 1984,

Opinion).

 The two major

 sources

 of VOM are from the fountain

solution, which can contain between

 15 to

 25 percent isopropyl

alcohol

 and the ink solvents,

 It should be noted

 that Industry

contends that the ink solvent used

 in their process are exempt

from control under

 Subpart

 K, given

 the current definition of

photochemically reactive.materials.

 In support of this argument,

Industry presented three parts

of

 a five part study underway at

Sattelle concerning

 the reactivity .of the ink solvents used in

heatset web offset printing

 (Exs.

22,

39

 & P.C.

 54).

The

only

 evidence presented by the Agency

 in support of

their

 position that

 ink solvent emissions should be controlled as

ozone precursors

 is a series of letters and memos

 by the U.S.

Environmental Protection Agency (“USEPA”) which conclude that

ink

solvents are reactive

 (Ex.

 24 a and b).

 The draft CTG also calls

for the control

 of ink oil emissions

 (Ex,

 29e).

 The Agency

contends that these compounds should be controlled because they

are released into

 the atmosphere -as vapors as a result of being

heated

 in dryers during

 the printing process

 (P.C.

 57).

At

normal temperature and pressure they are not volatile.

The

com~1etedportions of

 the Battelle study indicate that even as

 vapors,

 representative ink solvents are about as reactive

 as or

slightly less reactive than ethane,

 a compound adjudged non-

reactive by USEPA

 (Exs.

22,

39,

 P.C.

 54).

Volatile isopropyl alcohol emissions are predominantly

released from press

 units and dryers.

 The draft

CTG

 estimates

that

 50 percent of emissions are released

 in the pressroom and 50

percent:

 are released through the dryer exhaust

 (Ex.

 29e,

&

Section

 4,~L).

 Ink solvent vapors

 are emitted primarily from the

dryer

 ~approximate1y 80 percent)

and

to

 a lesser extent from the

00011fl9

 roller process.

 Various control options include:

1)

reduction or elimination

 of isopropyl alcohol

 in the fountain

solution;

2)

 use of direct flame

or

 catalytic afterburners on the

dryer exhaust

 (a process that oxidizes both isopropyl alcohol and

Thk solvent emissions);

 3) use

of

 a condensor system on

 the dryer

*The ambiguity regarding whether this category is still

“covered”

 by a CTG

 or not

 is compounded by

 a public comment from

USEPA received after first notice.

 P.C.

 60, dated October

22,

1984,

 implies that heatset web offset

 is still within

 the CTG

prograt~and that rules

 are still required for

 this category.

64-168

—3—

exhaust (a process that selectively controls ink solvent

emissions but not isopropyl alcohol); and 4) reformulation of

printing inks to high solid/low solvent mix.

 The economic

reasonableness, practicality and availability of these various

options are subject to debate.

 Additionally,

 the factual

determination of whether or not ink solvents are photochemically

reactive will affect which control option or combination of

options should be implemented.

The draft

CTG

outlines what USSPA considers RACT for this

industrial category (Ex.

 29e).

 section 4.1 states that:

NA reduction in VOC emissions to 0.3 kilograms per

kilogram of ink consumed is considered

representative of reasonably available control

technology

 (RACT)

 for full—web process—color

heatset web—offset lithographic printing presses.

This emission limit is based on elimination of high

volatility organic compounds from the fountain

solutions; however,

 it could also be achieved

through the use of other control techniques.

Incineration of the exhaust gases discharged from

the dryer and reduction in the concentration of

 high volatility organic compounds in the fountain

solutions to 12 percent or less by weight, or

condensation of ink solvent from the exhaust gases

discharged from the dryer and reduction in the

concentration of high volatility organic compounds

in the fountain solutions to 7 percent or less by

weight,

 for example, could also achieve this

reduction in VOC emissions.’

The

CTG

describes three basic alternative control strategies

to achieve RACT:

 1) Total elimination of VON’s in the fountain

solution; or

 2) Reduction of VON concentration to 12 percent and

tncineration; or 3) Reduction of VON concentration to 7 percent

and condensation of ink solvents.

 No version of the rule,

whether proposed by the Board, Agency or Industry, is consistent

with the draft CTG’s definition of RACT.

 This infirmity alone,

would not be fatal if there existed an adequate record to support

any ~f these versions.

 However, no present version of the rule

is totally supported in the record.

The Board’s rule proposed at first notice in August, 1984,

applies to facilities whose emissions of VON exceed 25 tons per

year.

 The rule requires one of three options:

 1) installation

of an afterburner system which oxidizes 90 percent of captured

non-methane VON (no capture efficiency is provided);

 or 2)

reduction of VON concentration in the fountain solution to no

more than five percent and installation of a condensation

 recovery system which removes at least 75 percent of VON’s from

the airstream or reformulation of the ink to a high solid/low

solvent;

 or 3) an alternative control system demonstrated to have

an equivalent emission reduction efficiency equal to either of

64169

—4~-

the

 first two control options.

The Board’s original proposed rule presents

 a number

of

conceptual problems.

 First,

 the Board

 rule only attempts

to

controL

 volatile organic material emission yet controls

ink

solvents which do not fall within the current definition of

VO~.

 The ink solvents are

 in fact non—volatile organic material

which

are

 vaporized through a drying process.

 This

is

a

separate

 issue than whether

or

 not they are ozone precursors.

Second,

the

 Board1s August 22, 1984, Opinion appears to view the

fin~.ugs

of

 the ~3atteilestudy favorably,

 finds

 a paucity of

.~c supporting

 the Agency’s position and yet provides for

car

~-.~ls

 of ink solvent emissions.

 While this issue may never

be

r;o~~dto all parties’ satisfaction,

it

 necessary to make

a

choicc

 and imp:Lement the logical extensions of that choice.

Thir’~

tne

 alternative control strategies

 are not equivalent.

The

first

 alternative,

 an afterburner system on the dryer

exhaust,

 leaves pressroom emissions totally uncontrolled while

controlling most

 ink solvent and isopropyl alcohol dryer

cti~ions.

The

 second alternative requires reduction of VOM in

:;~e

t~)unta1fl

solution combined with one of two alternate

approaches

 for controlling

 ink solvent emissions.

 These

ink

solvent control approaches are very difficult

 to compare, and do

not

 seem well supported in the record,

~dditional concerns with the Board’s proposed rule were

raised by public commenters.

 Industry challenged the feasibility

of reducing VOM

 in the fountain solution to

5

 percent while still

maintaining acceptable print quality

 (P.C.

 62).

 The use of non—

~JOM

isopropyl alcohol substitutes,

 which the Board presumed

 to be

acrailable~.

 was also questioned.

 While substitutes

 do exist,

all

but

 ethyLene glycol

 are VOM’s themselves,

 Ethylene glycol can

oni~b~used satisfactorily in one of

 the three

 commonly used

~-~n~nq

 orocesses

 (P.C.

 62),

 The Agency pointed out that no

ca~~:u~.

 efficiency was designated

for

the

 afterburner

 system,

r~de~:ing

the

 90 percent

 oxidation requirement meaningless

 (P.C.

57).

 The Agency also pointed out that the

 75 percent recovery

efi~:iciency for VOM for the condensation system does not

~itfterentiatebetween VOM from the fountain solution and organic

ec~.iss1orts

from the

ink

 solvents.

 Condensation systems are not

desi-~riedto recover

 isopropyl alcohol

 in an economical fashion

~c,

57).

Ueither

the

 Agency1s proposed language nor Industry~sdraft

rule

are

 consistent with the draft CTG definition of RACT.

The

Aconcy draft rule requires:

1)

 use of

 an afterburner

 system that

oi~iizesat

 least.

 90 percent

 of organic materials;

or

2)

the

fountain

 solution contain no more than

 5 percent VOM and use of

a

con&~nsation

 recovery system that removes

 75 percent of the

crqan~c

 materials

 in the air stream;

or

 alternative

emission control system demonstrated to be equivalent to either

o~ J~e

firot

 two alternatives.

 This rule suffers

 from similar

~.c1orru~as does the Board’s proposed rule as

 It fails to combine

.-.,on

 VOM concentration in the fountain solution with

64-170

—5—

condensation or

 oxidation.

 It also controls the non—VOM ink

solvents,

 an issue yet to be

 resolved.

 Industry’s draft rule

requires~

 1) use of

 an afterburner system which oxidizes

90

percent

 of captured VOM; or

2)

 reformulation of

 the fountain

solution

 to no more than

 8 percent VOM;

or

3)

 an alternative

emission control system demonstrated

 to be equivalent to either

~

the

first

 two alternatives.

 This rule

 is consistent with

Industry~S

position that only VOM’s and not ink solvents should

be

controlled.

Industry also submitted the third task of the ongoing

Bat:telle study as P.C.

54.

 This task tested used ink solvents

to

see

 if the photochemical reactivity of

 the solvents were

influenced by

 the printing process.

 The results indicated that

t~oe

properties of the ink solvents were not altered by the

printing

process when compared with virginor raw ink solvents

(P.C.

54).

Because

 of the many problems associated

with

drafting

satisfactory

rules,

the

Board

 will conduct an additional hearing

for

rhe

heatset web offset category only.

 For purposes

of

generat:ing

 a sufficient record,

 the Board proposes

 a new rule for

first notice,

 As previously noted,

 the Board does not

necessarily advocate this

 rule nor

is

 it presently based on an

adequate

 record.

 An additional hearing will help supplement

the

existing record and provide an opportunity

 for more detailed

scrutiny and examination of the Battelle study’s new findings.

As

 a final matter,

 the Board

 is proposing,

 for first notice

Section 215.205, which was inadvertently omitted from the August

10,

 1985, Order due to an improperly perceived nexus with Section

2.15.207.

 The Agency’s p~.~b1iccomments submitted during first

 notice served

 to distinguish these two sections

 (P.C.

 57).

Because

 entire

 rule was not included

 in the August

10,

 1984,

first: notice order,

it

 is necessary

to

submit

Section 215.205 for

first notice publication.

With

 its original proposal

 in this matter

 (Ex.

1),

the

Agency sought to amend Section 215.205

 as adopted

 in R78—3,

4:

RACT

1.

That

 Section contains emission standards,

 based on

capture

and

destruction

efficiencies,

alternatives

the

volatile

organic material limitations

 for surface coating

operations contained in Section 215.204.

 When reviewing Section

215.205,

amendment

the

State

Implementation

Plan

(SIP),

the

United

States

Environmental

 Protection Agency (USEPA)

 found

to

possibly

deficient.

The

Illinois

Environmental

Protection Agency (“Agency”) agreed to undertake

 a study and

submit

 any necessary amendments to

 the Board;

 the State, thereby,

gained

conditional

approval

 of that portion

 of the SIP

 (45 FR

11472,

11482;

Ex.

2).

The

Board

 takes official notice that

based

the

Agency’s

study

(described

below)

the

USEPA

now

requires

that

the

control

efficiency

percentages

 revised

 to conform with its Control

64~

171

—6—

Technique Guideline

 (CTG)

 in order

 to cure

 the conditional

approval

 for that portion of the SIP (49FR 20521

 at 20522).

The

amendments

proposed

the

Agency

Section

215.205

are

based on the agreed study,

 which was submitted as Exhibit

11

in

the

rulemaking.

 The Agency proposed to increase the control

efficiency required at the process equipment for all types of

surface coating facilities regulated under Section 215.204,

except for •the can coating processes, from 75 percent to 81

 percent.

 No change was proposed

 for can coating operations

 using

add—on controls ~ecause the control efficiency at these sources

remained urtdeter~inedby the study.

 (The USEPA found that 75

percent control efficiency currently required represents

reasonably available control technology for can coating.)

Focusing on the collection efficiency at Illinois paper coating

facilities,

was

determined

that

reasonably

available

collection efficiency ranged between 91 and

 94 percent.

 Based on

this,

the

 81 percent figure was proposed for the remaining

surface coaters.

The

 proposed amendments

 to Section 215.205 were unopposed at

hearing and no public comments were received

 on the issue.

To

rectify any possible SIP deficiencies and avoid sanctions under

the Clean Air Act,

 the Board will adopt

 the amendment as proposed

for

 Section 215.205.

 Therefore, at all surface coating

operations regulated under Section 215.204, using

 the alternative

control mechanisms provided under Section 215.205,

 81 percent of

the emissions from the coating line are

 to be captured and 90

percent of the nonmethane vokatile organic material captured

is

to be oxidized.

 This option would not be available for can

coating operations.

 The alternative control mechanisms provided

under Section 215.205 entail utilizing capture and destruction

equipment as opposed

 to compliance coating.

ORDER

The Board adopts for

 first notice language further amending

35 Ill.

 Adm.

 Code 215:

 Organic Emission Standards and

Limitations.

 Section 215.205, Alternative Emission Standards,

is

ac~endedand Subpart P:

 Printing and Publishing

 is amended to

include new rules regulating heatset web offset lithographic

printing.

 A hearing shall be scheduled regarding the new

proposed rules

 for this industrial category.

 The new language

shall

 read

 as follows:

SUBPART F:

 COATING OPERATION

Section 215.205

 Alternative Emissions Standards

Owners or operators of coating lines subject to Section 215.204

may

comply with this Section,

 rather than with Section 215.204.

The methods or procedures used

 to determine emissions of organic

material

under this ~ Section shall

 be approved by the Agency.

64.172

—7—

Emissions

 of volatile organic material from sources subject

to

Section 215.204, are allowable, notwithstanding the limitations

in Section 215.204,

 if ~teh the emissions a~eeentf~e~d~ed

~

 erte

o~the

 ~ew~t~g me~he~e:

a)

For

 those sources subject to Section 215.204(b)

are

controlled b~A an afterburner system, provided that

75

percent

 of the emissions from the coating line and 90

percent of the nonmethane volatile organic material

(measured

 as total combustible carbon) which enters

the

afterburner

 are oxidized to carbon dioxide and water;

or

b

For

all

 o~ii;er sources subject

 to 215.204 are controlled

by an afterburner

 system, provided that 81 percent of

the emissions from~the coating line and

 90 percent of

the nonmethane volatile organic material

 (measured

as

total combnstible carbon) which enters

 the afterburner

are oxidized to carbon dioxide and water;

or

h~ c

 A The system used to control such emissions

is

demonstrated

 to have control efficiency equivalent

 to or

greater

 than that provided under

 the applicable

provision of Section 215.204 or

 subsections

(a)

or

 (b).

~p~Ye~

 ~y the Aget~eyT

(Source:

 Amended at

9

 Ill. Reg.

_____,

 effective

_________,

 1985)

SUBPART

P:

 PRINTING AND PUBLISHING

Section 215.402

 Exemptions

The limitations of this Subpart Bhall not apply

to:

a

eny facility whose aggregate uncontrolled rotogravure

and/or flexographic printing press emissions of

 volatile

organic material are ~.imitedby operating permit

conditions to 907 M9

 (1000

 tons) per year

 or less

 in the

absence of air pollution control equipment or whose

actual emissions in the absence

 of air pollution control

equipment would be

 less than

or

 equal to 907 Mg

 (1000

tons) per year w~tenaveraged over the preceding three

calendar years; or

b)

 Any facility whose aggregate uncontrolled heatset web

offset lithographic printing press emissions of volatile

2~9anicmaterial are 100 tons per year

 or less

 in the

absence of air pollution control equipment,

or

so

limited

 by operating permit conditions.

(Source:

Amended

 9 Ill.

 Reg.

effective

________,

 1985)

Section

215.405

Compliance

Dates

and

Geographical

Areas

~4-173

—8—

a)

 Except as otherwise stated

 in subsection

 (b), every

owner or operator

 of an emission source subject

to:

 th4s

~

 Section 205.401 shall comply with its standards and

limitations by December

31,

 1983.

~j

 Section 215.408 shall comply with its standards and

limitations by December

31,

 1985.

b~

If

 an emission source

 is not located

 in one of

the

counties listed below e~d~s ~cse ne~~eeated

~et~ty ee~gtie~sthe~ete,the owner

 or operator

 of the

emission source shall comply with, the requirements

of

this Subpart no later than December

31,

 1987:

Bond

 Madison

Clinton

 McHenry

Cook

 Monroe

DeKaib

 Montgomery

DuPage

 Morgan

Franklin

 Pope

Greene

 Randolph

Jackson

 Saline

Jersey

 Sangamon

Johnson

St.

 Clair

Kane

 Union

Kendall

 Washington

t~ake

 Will

Macoupin

 Williamson

f3e~~rte~e~These ee~rt~4es~e

 pfepeee~~e be

~s

 i~mer~

 ~y the USBPA ~-4’~

 Reg~

~S88~

 ~3t~y2~7~98~)~

(Board note:

 The USEPA noted

 in its redesignation

rulemaking,

 that

 it will publish

 a rulemaking notice

on

Williamson County’s attainment status,

 (45 Fed.

 Reg.

21849, May

 16, 1983)

 Should Williamson County be

redesignated as attainment prior

 to October

 31, 1985,

it

and the counties contiguous

to

 it will

 be considered

deleted from the above

 list.)

c)

 Notwithstanding subsection

 (b),

 if any county

is

de~te~

 redesignated as nonattainment by the USEPA at

any time subsequent to the effective date of this

Subpaft Section, the owner

 or operator

 of an emission

source located

 in that county or any county contiguous

to that county who would otherwise

 be subject

 to the

compliance date

 in subsection

(b)

 shall comply with the

requirements of this Subpart within one year from the

date of redesignation but

 in no case later

 than December

31,

 1987.

64-174

—9—

(Sources

 Amended

at

9

 Ill.

 Reg.

____,

 effective

_________,

 1985)

Section 215.407

 Compliance Plan

a)

The

 owner

operator

of

an

emission

source

subject

to

Section 215.405(a)

 (1) shall submit

 to the Agency a

compliance plan, ps~a~ ~e

S ~

 A~m~eede ~O~7

~ubpe~t

e~~i~ga

p~e~ee~

eemp~et4o~•sehe~u~ewhere

4cab~eyno later than April

21,

 1983.

b)

 The owner or operator of an emission source subject

to

—

 Section 2l5.405(a)(2)

 shall submit

 to the Agency

a

compliance plan no later

 than December

 31, 1985.

c~1

 The owner

 or operator of

 an emission source subject

to

Section 215.405(b)

 shall submit to the Agency

a

compliance plan,

e~rr~

 a p~e~eeteemp~et4e~sehed~e

~he~e

 p~±eab~e~

 no later than December

31,

 1986.

~1- d)

 The owner

 or operator of an emission source subject

to

Section 215.405(c)

 shall submit

 a compliance plan,

including

 a project completion schedule plan,

 including

a project completion schedule within

 90 days after

the

date of redesignation, but

 in no case later than

December

 31, 1986.

4~

 ~3ess

the

 bm4~e&eemp~a~eep3ai~e~’seheth~e~s

speeve~ by the Agei’tey7 the ew~et~e~epe~’a~eee?

a

~ae4~4ty e~em~es4enee~ee

 b~ec~~e the ~a~ces

ape~e~ ~

S

+a+7

 ~-S~e~fe~

ina~j’

epera~ethe

em~s~e~

 eet~eeaeeee~4i~g

tt&

 the p~car~at~sehe~d~eas

~tthm4tte~.

The owner

 or operator

 of an emission source subject

to

Section 215.407(d)

 shall not

 be required to submit

a

compliance plan

 if redesignation occurs

 after December

31,

 1986.

e+

1)

 The plan and schedule shall meet the requirements

of

35

Ill. Adm.

 Code 20l~. 5~bpaftH7

 e~tid~g ee~f~e

dates as

35

 Adm-

 eede ~O~42~

(Source;

 Amended at

9

 Ill. Reg.

_____,

 effective

_________,

 1985)

Section 215.408

 Heatset Web Offset Lithographic Printing

No owner

 or operator

of

 a heatset web offset lithographic

printing press subject

 to this rule may cause

 or allow the

operation of such press unless:

a)

 The fountain solution contains no volatile organic

materials;

or

64-175

—10—

b)

 The fountain solution contains no more than 12 percent,

—

 by weight,

 of volatile organic material,

 and an

afterburner

 system

is

 installed and operated which

captures and oxidizes at least

 90 percent

 of the organic

materials

 (measured as total combustible carbon)

to

carbon dioxide and water;

or

c)

 The fountain solution contains no more than

 7 percent,

by weight,

 of volatile organic material, and

a

condensation recovery system

 is installed and operated

that removes

 at least

 75 percent

of

the

 organic

materials from the airstream;

or

d)

 An alternative emission control system demonstrated

to

—

 have

 a total reduction efficiency equal

 to that required

 Subsection

 (a)(b)

or

(C)

 above.

(Sourcet

 Added

at

9

 Ill,

 Reg.

_____,

 effective

 1985)

Chairman ~T.D.

 Durnelle concurred.

IT

 IS SO ORDERED

I, Dorothy M.

 Gunn, Clerk

 of the Illinois Pollution Control

Board, hereby certify that the above Proposed Order/First Notice

was adopted on the

 ~3O~1~~-day

 of ________________________,

 1985,

by a vote of

.

Dorothy M.

 unn, Clerk

Illinois Pollution Control Board/

64-176