ILLINOIS POLLUTION CONTROL BOARD
    August 22,
    1984
    IN THE MATTER OF~
    )
    VOLATILE ORGANIC MATERIAL
    )
    R82~l4
    EMISSIONS FROM STATIONARY
    )
    Dockets
    A & B
    SOURCES; RACT III
    )
    DISSENTING OPINION
    (by
    J.
    D.
    Dumelle and W.
    J. Nega):
    Our reasons for
    dissenting on the August 10,
    1984 order
    have
    to do with the lack of foundation of a need to regulate the heat~
    set web offset industry and the synthetic organic and polymer
    manufacturing industry (Opinion, pp. l1~24).
    The heatset web offset industry regulation appears to be a
    de
    minimus one.
    The majority opinion indicates that only 12
    presses in Illinois will be affected by this rule
    (p.
    17). No
    estimates are given by the majority as to the reductions
    in
    volatile organic materials to the atmosphere that will be
    achieved,
    Without these data a rule should not be enacted.
    Secondly,
    it
    is possible that this rule will have little
    effect upon ozone generation if the VOM reductions, even if
    significant in quantity, are far removed in location from
    non—attainment areas.
    The EcIS on this category
    (Doc,
    No.
    83/32)
    contains a map on p.
    42
    (Fig,
    21) showing all of the
    17 plants
    affected by the original proposal.
    Of the 17,
    a total
    of
    8 are
    in
    attainment counties,
    Seven of these eight are not adjacent to
    non~attainmentcounties,
    Thus,
    if the VOM reductions achieved
    are
    largely in plants in these non-adjacent counties then
    little
    improvement in ozone levels will occur,
    Put another way, the
    rule will then have little effect and be largely useless and
    a
    waste of money for all.
    A third point of concern is the competition between roto-
    gravure plants and heatset web offset plants.
    The former have a
    1,000 ton/yr. exemption;
    the proposed rule gives the heatset web
    offset plants only a 25 ton/yr.
    exemption.
    What does this do to
    business costs and competition (see R0
    735)?
    The synthetic organic and polymer manufacturing industry
    proposed rule is far tighter than the IEPA original proposal.
    The 1,500 component cutoff level
    in the rule includes plants with
    about
    45 valves not of the ball
    and plug type.
    This
    45 valve
    limit if far below the 100 valve exemption level proposed by
    IEPA,
    A better component cutoff level would be about 3,300
    instead of 1,500.
    At this number of components,
    about
    100 valves
    which are not~balland plug type would exist in the plant.
    Again, as in the heatset web offset press
    rule, the majority
    does not give estimates of VOM reductions
    to be achieved by this
    rule.
    Is this a de_minimus rule or is the Va~reduction in
    59~555
    2
    emissions significant?
    We do not know,
    How then can we make a
    considered decision?
    In conclusion, the proposed rules for these two industries
    have a
    poor data base, may be demi~us, and may not be of
    significant help to reduce ozone levels,
    Every new rule carries its own cost
    of permits to apply
    for
    —
    of inspections to be made
    of records to be kept.
    If the
    very basis for the rule is absent, as detailed above, why be
    in a
    rush to regulate?
    ~
    “p
    ~ç-~
    /
    ~alter J.Neg’~42~ember
    (I
    I,
    Dorothy M. Gunn, Clerk of the Illinois Pollution Control
    Board,
    hereby certify that
    the above
    Dissenting Opinion was sub-
    mitted on the
    ~~___
    day of
    1984.
    ~~hy
    M. ~n,
    Clerk
    Illinois P~lutionControl Board
    rman
    59~556

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