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Motor Company has met the requirements for an adjusted standard. The Board grants the

requested relief from 35 Ill. Adm. Code 218.986, subject to conditions suggested by the parties.

 

Procedural History

 

On February 4, 2002, Ford filed a petition for an adjusted standard for its Chicago

Assembly Plant located at 12600 Torrence Avenue, Chicago, Illinois. Ford requests that the

Board revise the adjusted standard granted effective April 6, 2000 as it relates to volatile organic

material (VOM) limitations for the solvent clean up operations at the Chicago Assembly

enumerated within the applicable provisions of 35 Ill. Adm. Code 218. Subpart TT.

 

On February 15, 2002 Ford filed its certificate presented a certification of Public Notice

demonstrating the required publication of notice of its petition for adjusted standard in the

Chicago Tribune

on February 7, 2002. The Illinois Environmental Protection Agency (Agency)

filed its recommendation on April 22, 2002. The Agency recommends that the Board grant the

requested revision to 35 Ill. Adm. Code Part 218, Subpart TT entitled, “other Emissions units.”

 

On August 15, 2002, a hearing was held at Fords’ request; there was no public

participants or additional evidence presented.

 

Statutory and Regulatory Framework

 

The Board’s authority to grant adjusted standards derives from Section 28.1 of the Illinois

Environmental Protection Act (Act), 415 ILCS 5/28.1 (1998). Section 28.1(a) provides that a

petitioner may request, and the Board may impose, a standard different from that which would

otherwise apply to the petitioner as the consequence of the operation of a rule of general

applicability. The criteria for granting an adjusted standard are set forth in Section 28.1(c),

which provides:

 

c. If a regulation of general applicability does not specify a level of

justification required of a petitioner to qualify for an adjusted standard, the

Board may grant individual adjusted standards whenever the Board

determines, upon adequate proof by the petitioner, that:

 

1. factors relating to that petitioner are substantially and significantly

different from the factors relied upon by the Board in adopting the

general regulation applicable to the petitioner;

 

2. the existence of those factors justifies an adjusted standard;

 

3. the requested standard will not result in environmental or health

effects substantially and significantly more adverse than the effects

considered by the Board in adopting the rule of general

applicability; and

 

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4. the adjusted standard is consistent with any applicable federal

law.415 ILCS 5/28.1(c) (1998).

 

Background and History

 

Ford has operated the Chicago Assembly operation at its present location since 1924.

Chicago Assembly is composed of a plant body shop, paint shop, final assembly shop and waste

water treatment plant (Pet. at 3). A body shop assembles vehicle bodies using stampings,

frames, low VOM adhesives and welding operations.

Id.

The vehicle body is then conveyed into

a paint shop where the body is run through the following: a cleaning and chemical coating

process, electrodeposition coating (which is oven-dried), application of sealers to seams and

areas of the vehicle body, prime coating (which is oven-dried), and top coating (which is

ovendried). Pet. at 3-5. The painting operation uses automated paint application equipment and

high solids paint. Pet. at 3. Automated application equipment cannot reach all areas of the

vehicle body, however; some areas must be painted manually by workers using hand held

applicators. Pet. at 5.

 

Clean-up operations of various types are an integral part of Ford’s process. Vehicle

bodies pick up oils, grease and dust due to employee contact, ambient air, equipment contact and

materials used in manufacturing. Pet. at 3-4. Due to the high quality finishes demanded by

Ford’s customers, solvent clean-up operations are vital to Ford’s operations

. Id.

Also, inherent

in the paint operation is the need to clean up facility components associated with that operation.

 

In its previous decision in Petition of Ford Motor Company, AS 00-6, the Board found

that Ford presented sufficient evidence to justify an adjusted standard to allow 390 tons of VOM

emissions from its Chicago Assembly. The Board will not repeat the substance of its decision

here in detail, but will give a brief summary.

 

First, the Board found that reducing emissions to achieve compliance with Section

218.986 would cost approximately $45,500 per ton far exceeding the level generally found

economically reasonable.

 

Second, the Board found and the USEPA acknowledged that Ford’s proposed interim

compliance plan implemented as a result of the adjusted standard would result in the greatest

emission reduction possible using technologically and economically feasible controls.

 

Third, the adjusted standard granted had negligible impact on air quality and would not

result in environmental or health effects significantly more adverse than the effects considered

by the Board in adopting Subpart TT of 35 Ill. Adm. Code 218.

 

Fourth, the original petition for adjusted standard was consistent with federal law as

outlined within Section 110 of the Federal Clean Air Act, 42 U.S.C. § 7410.

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The Requested Revision

 

Ford now seeks to reduce the VOM emission maximums from 390 tons to 340 tons per

year as calculated on a 12 month rolling total basis for their clean-up solvent operations at

Chicago Assembly. Ford proposes no modifications in the record keeping, reporting

requirements, work practices or employee awareness progress. The proposed figure of 340 tons

per year represents a cap on allowable VOM emissions and is supported by the Illinois

Environmental Protection Agency. Agency Rec. at 7. Ford presented detailed records which

indicated actual emission averages far below the current 390 tons per year limit, 282 tons in 2000

and 240 in 2001. Agency Rec. at.7.

 

 

Both Ford and the Agency concur that since the petition is seeking a voluntary reduction

of 50 tons from a previously approved adjusted standard that the need for compliance

alternatives is not applicable and the documents referenced in the previous Board deliberation

should be sufficient.

 

Environmental Impact

 

The intent of the regulations promulgated under 35 Ill. Adm. Code Par 218 is to

implement Reasonably Available Control technology (RACT) for VOM sources in the Chicago

ozone non-attainment area. Agency Rec. at 10. The petition’s control plan significantly reduces

emission of VOM from the clean-up operations and, reduces the cap to 340 tons per year. Ford

maintains and the Agency agrees, that the voluntary reduction of 50 TPY from the adjusted

standard in Petition of Ford Motor Company, AS 00-6 will have a positive impact on air quality

despite the continued infeasibility of Ford’s complying with Subpart TT. Agency Rec. at 10.

The Board finds that the environmental impact of the proposed revision is positive, as it

represents a 50 TPY emissions reduction.

 

  

Consistency with Federal Law

 

Section 110 of the federal Clean Air Act, 42 U.S.C. § 7410, grants individual states the

authority to promulgate a plan for implementation, maintenance and enforcement of air quality

standards, subject to approval by USEPA. A state may revise its State Implementation Plan,

again subject to USEPA approval.

Id.

The Agency has indicated that this revision to the

adjusted standard will be submitted as a SIP revision. Agency Rec. at 12. We note that the

terms of this previously granted revision have already been thoroughly discussed with the

USEPA. The Board finds that this criterion is satisfied.

 

Conclusion

 

 

In granting Ford the original adjusted standard in Petition of Ford Motor Company, AS

00-6, the Board found that Ford complied with all requirements of Section 28.1 of the Act. Since

2000, Ford has determined that it can reduce emissions by 50 tons. The Board is pleased to

amend the prior adjusted standard to accommodate this voluntary reduction.

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Order

 

Ford Motor Company (Ford) is hereby granted a revision to the adjusted standard from

35 Ill. Adm. Code 218.986 insofar as that regulation applies to VOM emissions from Ford’s

solvent clean-up operations listed below, subject to its previous conditions and terms as

presented below:

 

1. Applicability. The provisions of this adjusted standard apply to the following

clean-up operations at the Ford’s Chicago Assembly Plant (the facility):

 

a. Paint booth wall/grate and paint floor cleaning operations;

 

b. Automated paint application cleaning (external);

 

c. Manual paint application equipment and associated hoses;

 

d. Floor cleaning;

 

e. Purge system for automated paint application equipment;

 

f. Ultra filter cleaning and paint supply system cleaning; and

 

g. Vehicle body cleaning.

 

2. Emission Control Requirements.

 

a. Emissions of VOM from the cleaning operations may not exceed 340 tons

per year as calculated on a 12 month total rolling basis.

 

b. The facility may not use spray equipment to apply any cleaning solvent

containing in excess of 3.5 pounds VOM per gallon (minus water and

exempt compounds) for cleaning paint booth walls, grates, or the exteriors

of paint application equipment.

 

c. The facility may not utilize VOM-containing materials to remove paint

from paint booth grates. This restriction does not prohibit the use of VOM

containing grate coatings which reduce adhesion of uncured paint to grate

surfaces.

 

d. The facility may not store waste solvent or soiled rags from cleaning

operations in open containers when not in use except as necessary to

prevent a fire hazard.

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3. Record Keeping and Reporting.

 

a. For each VOM-containing material utilized in a cleaning operation, the

facility must record the following information on a monthly basis:

 

i. The name and identification of the VOM-containing material;

 

ii. A listing of the operations in which the VOM-containing material

was used;

 

iii. The pounds of VOM per gallon of the VOM-containing material,

calculated using 40 C.F.R. 60, Appendix A, Method 24

(incorporated by reference at 35 Ill. Adm. Code 218.112(d));

 

iv. The total gallons of VOM-containing material used; and

 

v. The total gallons of solvent recovered for disposal as calculated in

accordance with paragraph (c) below.

 

b. The facility must also record the following facility-wide information on a monthly

basis:

 

i. The monthly calculated usage of VOM from each cleaning

material used in each operation specified in section (1) above;

 

ii. The monthly calculated emissions of VOM utilizing the

information in subparagraph (i) above, and VOM credit as

calculated in accordance with paragraph (c) below; and

 

iii. The 12 month rolling total of VOM emissions calculated in

accordance with paragraph (d) below.

 

c. For each shipment of waste solvent from the purge reclaim tank to a solvent

reclaimer, the facility must obtain the weight percent solids, weight percent water,

density, total volume in gallons, pounds of VOM per gallon, and pounds of VOM

credit. Ford must ensure that the solvent reclaimer utilizes USEPA Method 24 for

determining VOM content, weight percent solids, weight percent water, and

density.

 

d. Compliance with the emissions limit of 340 tons per year as calculated on a 12

month rolling total basis is determined by calculating VOM emissions for the

previous month and adding emissions for the preceding 11 months, for a 12

month total.

 

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e.

Compliance calculations for the emission limit of 340 tons per year as calculated

on a 12 month rolling total basis must be performed within 15 days of the end of

each month.

 

f.

By April 1 of each year, the facility must obtain from each of its cleaning

material suppliers a listing of each VOM-containing cleaning material, its VOM

content, and the quantity of cleaning material delivered to the facility during the

previous calendar year.

 

g.

Records required by this section must be retained at the facility, available for

inspection by IEPA during regular business hours, for a period of three years.

 

h.

Ford must notify IEPA in writing within 15 days of finding that the total VOM

emission limitation of 340 tons per year has been exceeded. In any such

notification Ford must identify the suspected cause of the exceedance and any

measures taken to prevent any future exceedance.

 

4.

Employee Awareness. Ford must make a copy of the requirements of this adjusted

standard available to paint shop cleaning personnel and paint shop area managers.

 

IT IS SO ORDERED.

 

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control Board, certify that the Board

adopted the above opinion and order on November 21, 2002, by a vote of 6-0.

  

 

  

  

  

  

  

  

 

Dorothy M. Gunn, Clerk

Illinois Pollution Control Board