ILLINOIS POLLUTION CONTROL BOARD

August 23, 1979

IN THE MATTER OF:

R78—3,4

EMISSIONS OF VOLATILE ORGANIC MATERIAL

OPINION OF THE

BOARD

(by Mr. Dumelle):

This consolidated proceeding

was initiated when the Agency

filed a proposal on May 19,

1978 to amend Rules

201 and 205 of

the Air Pollution Control Regulations.

The proposal

(R78—3)

dealt with volatile organic emissions from solvent metal clean-

ing and petroleum refineries and was published in Environmental

Register

#172 on May 22, 1978.

Hearings were held on R78—3

on July 10,

1978

in Chicago and July 12, 1978 in Springfield.

Further amendments

to Rules 201 and 205 were filed with the

Board on July 18,

1978.

These amendments

(R78—4) concerned

volatile organic emissions

from surface coating operations,

bulk gasoline plants,

bulk gasoline terminals,

liquid petroleum

storage vessels, gasoline service stations and cutback asphalt.

P38-4 was published in Environmental Register 4176 on ~3uly21,

1978.

The two proceedings were consolidated on August

3,

1978.

Additional hearings were held on August 28, 1978 and September

25,

1978 in Chicago and on August 30, 1978 in Springfield.

Amendments

to the Agency’s consolidated proposal were published

in Environmental Register #181 on October 16, 1978 and Environ-

mental Register #182 on October 27, 1978.

On January 29, 1979

the Board received a study from the Institute of Natural Resources

entitled Economic Impact of Incorporating RACT

I Guidelines for

VOC Emissions into the Illinois Air Pollution Control Regula-

~42ps,_R78—3

and R78—4

(INR Document No.

79/01).

Hearings were

held on the study on March

5,

1979 in Chicago, March

9,

1979

in Rockford and March

12,

1979 in Decatur.

The Agency presen—

tad an amended proposal at the March

5,

1979 hearing

(Ex.66)

which

combined all prior amendments

arid suggested additional

changes.

Exhibit

66 was corrected at the March 12, 1979 hear-

ing.

On March

29,

1979 the Board adopted a Proposed Order

which listed amendments

to Rules 103,

104,

201 and 205 of the

Air Pollution Control Regulations.

The Proposed Order was

published

in Environmental Register #192 on April

3, 1979.

On July 12,

1979 the Board adopted a final Order in this pro-

ceeding.

This Opinion is intended to support and explain the

Board’s

final Order.

35—243

---

—2—

NEED FOR THE REGULATION

Numerous violations of the ozone standard have been detec-

ted in various areas of

Illinois.

The highest ozone levels

generally occur in the Chicago and St. Louis areas

(R.102).

The highest one—hour concentration measured in 1977 was 0.266

ppm (R.98).

(For a description of the Illinois ozone monitor-

ing system,

see R.94—114 and Ex.8).

Non—attainment areas for

the old oxidant National Ambient Air Quality Standard

(NAAQS)

of 0.08 ppm consisted of the 23 following counties:

Adams,

Boone, Champaign,

Cook,

DeKaib, DuPage, Grundy,

Kane, Kankakee,

Kendall, Lake, LaSalle, Macon, Madison, McHenry, McLean,

Peoria,

Sangamon,

St. Clair, Tazewell, Will, Williamson and Winnebago

(R.25).

All other areas of the State were unclassified be-

cause no ozone monitors were located in those areas.

During the time frame of the hearings in this proceeding,

U.S. EPA revised the oxidant NAAQS based on new health effects

information.

The NAAQS was changed in the following respects:

1)

the ozone NAAQS was changed from a level

of 0.08 ppm to

0.12 ppm for both the primary and the secondary standard;

2)

the chemical designation was changed from photochemical

oxidant to ozone;

3)

a statistical rather than a determinis-

tic form of the standard has been adopted; and 4) the measur-

ing method has been changed from a single one hour period to

the highest one hour average on a given day (R.1294).

In order

for a particular site to be in compliance with the new stan-

dard, the number of days

in which the highest one hour average

ozone value exceeds

0.12 ppm must be

less

than or equal

to

once per year,

averaged over three consecutive years

(R.66).

The Agency re-evaluated the attainment versus non—attain-

ment status of Illinois

in light of the new standard and

classified 20 counties

as non—attainment.

They are:

Adams,

Boone,

Cook,

DeKalb,

DuPage, Grundy, Kane,

Kankakee, Kendall,

Lake, LaSalle, Madison, McHenry, Monroe,

Peoria,

Sangamon,

St.

Clair, Tazewell, Will and Williamson.

The counties of

Champaign,

McLean, Macon and Crawford have been reclassified

as attainment

(R.1298), while all the other counties have

been designated as unclassified

(R1299).

Part D of the Clean Air Act

(42 U.S.C. §~7501—7508)pre-

scribes actions which must be taken by all states

in which

the National Ambient Air Quality Standards

(NAAQS) have not

been achieved.

Since many areas in Illinois have failed to

meet the NAAQS for ozone

(see non—attainment discussion,

supra),

these provisions of the Clean Air Act

(CAA)

must be

addressed.

Section 172(b)

of CAA

42

U.S.C.

§7501(b)

states that

Illinois must “...(2) provide for the implementation

of all

reasonably available control measures as expeditiously as

practicable;

and

(3) require,

in the interim, reasonable

35—244

---

—3—

further progress

as

defined

in Section 171(1)

including

such reductions

in emissions from existing sources

in the

area as may he obtained through the adoption, at a minimum,

of reasonably available control technology;..

.“

Section 171

(1)

42

U.S.C.

§7501(1)

defines the term “reasonable further

progress”

as “...annual

incremental reductions of the applic-

able air pollutant.

.

.which are sufficient.. .to provide for

attainment of the applicable national

ambient air quality

standard by the date required

in Section 172(a).”

In this

proceeding the applicable air pollutant is ozone.

The date

required

in Section 172(a)

is December

31, 1982 unless Illinois

demonstrates

this date cannot be met

“.

.

.despite the implemen-

tation of all reasonably available measures.

.

.‘

In that case,

the date becomes December 31,

1987.

The Clean 7~irAct includes sanctions which may

be imposed

against Illinois

if these directives are not followed.

Section

176(a)

of CAA

42

U.S.C.

§7206(a)

provides that certain high-

way construction

funds must be withheld if Illinois does not

follow the mandate of Section 172 in a timely fashion.

Section

316 of CAA provides that grants for the construction

of sewage

construction works

in certain areas nay be withheld.

Section

110(a)(2)(I)

of CAA provides that Illinois must include

a

restriction in its State Implementation Plan

(SIP) that pro-

hibits the construction of any major stationary source in

a

non—attainment area after June 30, 1979 under certain condi-

tions.

This prohibition can he avoided if Illinois revises

its SIP to comply with the provisions of Part D of CAA.

Tht’

amendments

which

the

Board

has

adopted

in

this

pro-

ceeding

ar~~

part

of

illinois’ attempt

to satisfy the

require-

ments

of.

CAA,

avoid

iLn

sanctions,

and

bring

oxidant

levels

down

to

safe

levels.

On

February

24,

1978

the Administrator of U.S. EPA issued

a memorandum

(Ex.2) outlining the actions each state would

have

to take

before

a

revised

SIP

could

be

approved.

Carbon

monoxide

and

oxidant

issues

are

addressed

in

Exhibit

2

in

part

as

follows:

“Adequate

plans

must

provide

for

the

adoption

of

reasonably

available

control

measures

for

stationary

and

mobile

sources.

“For

stationary

sources

the

1979

oxidant

plan

submis-

sions for major urban areas must include,

as a minimum,

legally enforceable regulations to reflect the applica-

tion of reasonably available control technology

(RACT)

to those stationary sources for which EPA has published

a

Control

Techniques

Guideline

(CTG)

by January,

1978...

“For rural non—attainment areas,

the O~plan must provide

the necessary legally enforceable procedures for the con—

35—245

---

—4—

trol

of

large HC sources

(more than 100 ton/year poten-

tial emissions)

for which EPA has issued a CTG by January

1978...

The Final Order in this proceeding represents the Board’s

interpretation of what constitutes RACT for each category of

industry for which U.S.

EPA had published a CTG by January,

1978.

It should be noted that the Board is not limited to

adopting only RACT.

Sections 10 and 27 of the Environmental

Protection Act

(the Act) provide the Board with authority to

adopt emission standards and standards

for the issuance of

permits which promote the purposes of Title II of the Act.

This broader authority under the Act has enabled the Board to

deviate from some of the narrow restrictions of RACT to adopt

amendments

which are in fact more stringent than RACT and pro-

vide for a more equitable statewide approach to ozone non—

attainment.

OZONE FORMATION AND CONTROL

“All the evidence presently available

indicates that in

the urban centers and adjacent downwind areas where severe

oxidant problems occur,

the major cause by far is photochemi—

cal oxidant formation”

(Ex.37, p.4—l).

Photochemical oxidant

(0)

is

a mixture

of pollutants which are formed in the atmos-

phere rather than emitted directly from sources

of air pollu-

tion.

Reactions of volatile organic compounds

(VOC), oxides

of nitrogen

(NO~),and oxygen

in the presence of sunlight form

a mixture of photochemical oxidants which consists of ozone

(03)? nitrogen dioxide

(NO2), peroxyacetylnitrate

(PAN),

smaller amounts of other peroxy compounds, and other photo—

chemical products such as aldehydes, nitrous acid,

nitric

acid and formic acid

(Ex.26).

Although there are still many unanswered questions about

the formation of O~in the ambient atmosphere,

much informa-

tion exists on the stoichiometry, kinetics and mechanisms

of

these reactions.

Because of the need to simplify conditions

in order to facilitate research,

all the experiments on the

mechanism of 0

formation have been done in laboratory

smog

chambers.

How~ver, there are limits to the validity of extra-

polating research findings based on mixtures containing a

limited variety of VOC to actual ambient conditions with a

complex mixture of VOC.

Paisie testified that

all reactions

that occur in the laboratory probably also occur in the ambient

atmosphere, possibly with varying significance.

However,

there may also be reactions

in the ambient atmosphere which

have not been found

in laboratory conditions

(Ex.26).

.35—246

---

—5—

The ove~al.iphotochemical reactions process has two dis-

tinct stages which occur consecutively.

In the first stage,

nitric oxide

(NO)

is converted to NO2 without an appreciable

buildup of 03 or other non-NO2 oxidants.

The second stage

begins

when

almost

all

the NO has been converted to NO2 and

is characterized by a rapid buildup of 03 and other oxidant

and non—oxidant products.

Several mechanisms exist for the

formation of photochemical oxidants.

The following are the

main reactions in the

formation

of

ozone:

UV

NO2

NO+O

(1)

Light

03 ÷M

(2)

03

+

NO

NO2

+

02

(3)

X02

+

NO

NO2

+

XO

(4)

2N0

+

°2

2N02

(5)

where:

X is hydrogen

(H) or organic radicals

(R or

RCO), and M

is any third molecule which

is available to

carry off excess energy.

In step

(3), the NO product from photolysis

of NO2

(step 1)

reacts rapidly with and consumes 03

to regenerate NO2.

If

it were not for other processes which convert NO into NO2,

ozone would not accumulate to significant levels.

However,

as shown in steps

(4) and

(5), other conversion processes

exist.

The reaction of NO with X02

(step

4)

is considered to

occur to

a greater degree than the reaction with molecular

oxygen

(0.))

shown in step

(5).

In step

(4) the reaction of

NO with Ra

occurs only in the presence of photochemically

reactive o~ganiccompounds.

If these compounds are present,

the reaction can proceed rapidly enough to cause an atmos-

pheric accumulation of significant levels of ozone;

if reactive

organics are not present, significant levels

of ozone do not

accumulate.

Recent research, based on computer simulation techniques,

has led

to the current theory that the hydroxyl radical

(H0)

rather than atomic oxygen and ozone may be the most active

chemical

in the consumption of hydrocarbon

(HC)

and aldehyde

reactants and thus be of major significance

in the oxidation

of organic and inorganic reactants.

“The

radicals 0H,

and R02

have also been identified as having major roles

in

the oxidation of NO into NO2”

(step 4)(Ex.37,

p.4—8).

Even though oxidants can be formed from natural sources

of hydrocarbons

or be due

to stratospheric ozone intrusion,

35—247

---

—6—

most photochemical oxidant

is formed from reactions of anthro—

pogenic VOC and NOR.

Research by Buffalini has indicated that

although ozone may be produced

in rural areas from natural

sources of

VOC,

the amount produced would not he sufficient

to cause vioiat~onsof the ozone standard.

Violations

of the

ozone standard which have occurred in rural areas have been

attributed to pollution transport

(R.1140).

Meteorological factors play an important role in the for-

mation

of photochemical oxidants.

Atmospheric mixing and

diffusion are important

in the transport and dispersion of

oxidant precursors which have been emitted.

Atmospheric sta-

bility, wind speed,

and topography determine the rate and

extent of atmospheric dispersion.

Since some of

the precur-

sor reactions are photodissociations,

sunlight and temperature

affect the rate and extent of oxidant formation.

Temperature

has been found to have a significant positive effect.

It has

been suggested that at temperatures less than 55°to 60°F(13°

to 16°C), concentrations of photochemical oxidants will not

exceed 0.08 ppm

(Ex.37, p.4—36).

In recent years,

several studies of

long range oxidant

transport

(“oxidant transport” refers to the transport of

either oxidant/ozone or oxidant precursors) have been per-

formed and found to occur on three geographical

scales.

“1) The urban scale transport,

as a result of which the peak

oxidant concentrations develop in the suburbs some miles down-

wind from the city—core area where the oxidant/ozone and their

precursors originated;

2) The mesocale transport that encom-

passes

land— and sea—breeze circulation, and the formation of

urban oxidant plumes that create oxidant problems as far as

100 miles or more downwind from the source city; and 3) The

synoptic

scale

transport,

a

much

longer

and

broader

range

of

transport associated with high pressure systems”

(Ex.

37,

p.4—38).

Results

from

the

urban

scale

transport

studies

indicate

• .that conditions at the center of source—intensive areas

are not the most conducive conditions for oxidant accumulation,

mainly because of the strong scavenging effect of oxidant pre-

cursors, especially nitric oxide.

At higher elevations

or at

horizontal distances downwind from the sources, where the pre-

cursor scavenging effect

is

less

important, oxidant concentra-

tions are,

in general, greater, and their levels are determined

primarily

by

the

intensity of the photochemical activity and

ambient

dilution.”

Peak

oxidant

concentrations

for several

cities

have

been

measured

at distances between 5 to 85 miles

downwind

of

the

city’s

center

(Ex.36,

p.4—38).

Numerous

studies

of

mesocale

and

synoptic

scale

trans-

port of urban oxidant plumes have concluded “that many cities

produce urban oxidant plumes that cause elevated oxidant con-

centrations in downwind areas as far as 300 km

(190 miles) or

35—248

---

—7—

more from the source city”

(Ex.37,

p.39—40).

A study of an

episode of wide—spread haze with elevated ozone, concentra-

tions in

southern Florida reported that

“.

.

.The source region

appeared

to

be

the

industrial

area

among

the

states

south

of

the Great Lakes making

a transport distance of over 1000 miles

(1600 km) of

which

400

miles

(640 km) were over the Gulf of

Mexico.

Both the haze and the ozone of its precursors may

have been augmented along the route”

(Ex.37,

p.4—42).

Such

long range transport can only occur

in an air layer aloft

since ground level ozone would be destroyed by reactions with

NO and VOC and reactions on surfaces.

Dr. Arnott

from

the

Wisconsin

Department

of

Natural

Res-

ources testified on ozone transport from Illinois into Wisconsin.

It

is his belief that Wisconsin cannot achieve the new ozone

standard

unless Illinois adopts and enforces state—wide VOC

regulations

(R.1574—5).

Aerial

monitoring

for ozone done in

1976

found

that

ozone

laden

air

enters

Wisconsin from Illinois

with

higher

concentrations

above

the

ground than at ground—

level

(R.1571).

Levels

in

excess

of

0.2

ppm

were

measured

above

Belvidere

and

Rockford,

Illinois

(R.1572).

Based

on

studies

of

urbanized

areas

which

have

indicated

that

reduction

of

NO

would

be

counter—productive

due

to

the

current

HC

to

NO~ratios,

it

has

been

concluded

that

control

of

organic

compounds

is

necessary

in

order

to

reduce

the

am-

bient

levels

of photochemical oxidants

(R.1138).

A ten—year

trend study of photochemical oxidant formation in the Los

Angeles basin indicated that an 18

reduction in hydrocarbons

was accompanied by a 19

reduction in ozone throughout the

basin

(R.1124).

Another

trend

study

of

six

cities

with

Con-

tinuous Air Monitoring Program

(CAMP)

stations

indicated

that

a reduction in hydrocarbons was accompanied by a reduction

in

ozone

(R.1125).

Lamping

(from Standard Oil Company of

Indiana

on

behalf

of

the

Illinois

Petroleum

Council)

tried

to

refute

the

need

for

hydrocarbon

control.

He

cited

a

study

of

five

American

cities

in

which

hydrocarbon

emissions

reductions

occurred.

In

three

of

those

cities

ozone

levels

increased;

and

in

a

fourth

there

were

no

obvious

changes

in

ozone

levels

(R•954—5).

However,

one

must

be

careful

in

interpreting

short—term

trend

studies

such

as

the

one

cited

by

Lamping

because

of

several

problems:

1)

The

impact

of

meteorological

phenomena

is

very

significant,

and

at

the

present

time

it

is

almost

impossible

to

normalize

out

the

impacts

of

meteorology

and

just

look

at

the

chemistry

(R.1148).

2)

The

emission

inventories

that

accompany

such

studies

are

crude

estimates

of

actual

varia—

Lions

of

hydrocarbon

emissions

from

one

year

to

the

next

(R.1l49).

3)

Problems

inherent

in

monitoring

location

and

technlque

can

influence

the

ozone

levels

measured.

For

example,

if

the

monitor

is

placed

near

a

source

of

NO,

the

0.~ could be scavenged by the NO which could affect the

levels

or ozone monitored at that site

(R•1150).

35—24 9

---

—8—

Based on

information

in the record, the Board finds that

a reduction in hydrocarbon emissions

is necessary in order to

reduce ambient air ozone concentrations.

This reduction will

occur through the implementation of this rulemaking,

RACT

2

and RACT

3

(still to come),

the Federal Motor Vehicle Control

Program,

and vehicle inspection and maintenance

(if necessary

and adopted in Illinois).

The Board also finds that positive material reduction

rather than substitution of

less photochemically reactive

hydrocarbons

for

more

photochemically

reactive

hydrocarbons

is needed for the following reasons:

1)

Many organic compounds previously considered to have

low

reactivity

have

been found to be moderately or highly reactive

in an urban atmosphere

(R.34).

Most early studies of reactiv-

ity have been done in chambers using a limited variety of or-

ganic compounds.

Hence, possible interactions of organics with

a complex mix of compounds would not have been studied (R.1147).

2)

Compounds of low reactivity can form appreciable amounts

of O~under rnultiday stagnation periods

(R.34).

Many of the

initial reactivity studies were done

in smog chambers with

irradiation times of about six hours.

Information obtained

since those studies indicates that longer periods of time than

six hours should be examined

(R.1144).

3)

Some compounds of

lower or negligible reactivity may have

other adverse effects

-

including adverse health effects

(R.34).

STATEWIDE CONTROL

The adopted regulations are not limited to non-attainment

areas.

The regulations cover a wider geographic area than

mandated by U.S. EPA

(R.1300,

Ex.2).

Several

reasons support

this choice.

Urban emissions may extend beyond urban non—

attainment boundaries and emissions of volatile organic com-

pounds in the rural attainment areas will exacerbate ozone

levels in these and other areas.

Conversely,

rural emissions

may be transported into urban non—attainment areas resulting

in increased ozone

levels.

These transport issues are dis-

cussed more specifically elsewhere in this Opinion.

There

are additional reasons for statewide applicability.

U.S.

EPA

has indicated that

it will not require offsets from non-urban

new sources

if an ozone SIP requires RACT on a statewide basis

(P.C.#102, Attachment A).

Statewide controls now will cause

a greater improvement in air quality and thus allow future

increases in emissions to be accommodated more easily.

For

example, unclassified areas throughout the state could conceiv-

ably become reclassified non—attainment on the basis of PSD

monitoring data; however,

the probability of this happening

is less with statewide controls since air quality in the un-

classified areas will

be improving.

35—250

---

—9—

Statewide

controls

prevent

industries

located

in

one

area

of

the

state

from

gaining

a competitive advantage over the

same

industries

in

another

area

of

the

state

by

virtue

of

not

having

to

expend

funds

on

controls.

The

Board

notes

that

the

previous

Rule

205

of

Chapter

2 applied statewide.

The

Agency’s

“Rules

For

Issuance

of

Permits

To

New

Or

Modified

Air

Pollution

Emission

Sources

Affecting

Non—attain-

ment Areas”

(Ex.73) provide additional support for statewide

applicability of controls.

In those rules the Agency allows

offsets for emissions

of organic material to come from exis-

ting sources

located within 100 miles of the new or modified

source.

For these existing sources to function as offsets,

they must currently he negatively affecting air quality in

the

non—attainment

areas;

statewide

controls

are

consistent

with

this.

The

Agency

also

indicated

that

models

used

to

predict

emission

control

requirements

are

less

accurate

at

ozone

levels

approaching

the

standard.

These

uncertainties

help

explain

the

difficulties

in

determining

why

some

areas

in

Illinois

are

attainment

and

others

are

not

(R.1303—4).

This

modeling

un-

certainty must be considered

in determining the geographic

applicability

of

control

requirements.

The Board recognizes that

a statewide program will pre-

vent some individual sources from realizing pecuniary gain

through later transfer of offsets

(R.1728—30; P.C.#102).

However,

the

Board

finds

that

the

above—mentioned

reasons

are

sufficient

to

support

the

decision

to

have

statewide

applic—

abillty.

In

order

to

determine

the

amount

of

hydrocarbon

emission

reduction

that

would

be

needed

to

attain

the

ozone

standard,

the

Agency

utilized

the

Empirical

Kinetic

Modeling

Approach

(EKMA)

and

did

a

city—specific

analysis

for

the

major

urban

non—attainment

areas

in

Illinois

(R.1341).

Although

the

SAl

Grid

Model

may

be

a

“more

realistic

computer

model”

than

EKMA

(R.950),

the

Agency

was

unable

to

use

it

because

they

do

not

have

the

time

or

the

necessary

input

to

operate

the

SAl

Grid

Model

(i.35).

The use of

other

oxidant

modeling

methodologies

was

also

investigated

by the

Agency.

However,

they

testified

that

“the

EKMA

estimation

technique

is

based

on

sound

fundmen—

tal

relationships

and

is

able

to

consider

many

of

the

parameters

that

only

the

most

sophisticated

Lagrangian

or

Euclerian

models

can

incorporate”

(R.36).

(EKMA

was

discussed

further

in

the

record

by

Sherman

on

R.36—40,

Matheny

on

R.115-137

and

Larnping

on

R.949—50).

Based

on

EKNA,

the

maximum

emissions

reductions

required

to

meet

the

new

ozone

NAAQS

are:

53

for

the

Chicago

area

(R.1343),

60

for

the

St.

Louis

area,

and

no

additional

reduc-

tions

for

Peoria

which

is

expected

to

meet

the

standard

by

3S—251

---

—10—

reductions

in

transportation-related

pollution

(R.1343).

In

order

to

achieve

these

emission

reductions,

it

will

be

neces-

sary to implement Reasonably ~\vailableControl Technology

(RACT) on stationary sources throughout Illinois, transporta-

tion control measures and possibly vehicle inspection and

maintenance

in the St. Louis and Chicago Major Metropolitan

Areas,

and continued implementation of the Federal Motor Ve-

hicle Control Program (FMVCP)

(R.1284).

However,

FMVCP, trans-

portation control measures and vehicle inspection and main-

tenance are not the subject of

this proceeding and will not

he

discussed

here.

COMPLIANCE

SCHEDULES AND DEADLINES

As

part

of

this

rulemaking,

the Board has adopted amend-

ments

to

Rules

104

and

205(j)

and

a

new

Rule

205(m).

When

read together these amendments show the “reasonable further

progress” called for

in Section 172 of the CAA.

These amend-

ments

call

for

compliance

schedules

which

may

be

prepared

individually for each source under Rule 104 or a source may

choose

to follow the categorical compliance schedules pro-

vided in Rule 205(m).

These schedules are designed to satis-

fy the requirements of

40 C.F.R.

§51.15.

The schedules follow

the

suggestions

from

U.S.

EPA

which

may

be

found

in

Group

Exhibit

33

and

in

Public

Comment

49.

They

represent

a

balance

between

“reasonable

further

progress”

and

economic

capabili-

ties

(R.l791).

By requiring reports of increments

of progress,

the Agency can keep abreast of problems which may arise in the

development

of

new

technologies

such

as

the

availability

of

low

solvent

technologies

and

the

like

(R.1792).

Compliance

schedules

and

project

completion

schedules

do

not

provide

a

means

to

delay

compliance

beyond

the

deadlines

stated

in

Rule

205(j).

Any

source

which

cannot

meet

a

205(j)

deadline

will

be

required

to

seek

a

variance

under

Title

IX

of

the

Act

and

Part

IV

of

the

Procedural

Rules.

Section

35

of

the

Act

states

that

any

such

variance

granted

by

the

Board

must

be

consistent

with

the

requirements

of

CAA

(see

Sections

110(a)(3),

110(i)

and

113(d)

of

CAA

and

Public

Comment

49)

and

will

he

subject

to

review

by

U.S.

EPA

(see

Section

113(d)

(2)

of

CAA).

RELATIONSHIP

TO

OLD

RULE

205

The

amendments

to

Rule

205

were

adopted

as

additional

emission

controls

—

not

as

substitutes

for

existing

require-

ments.

This

is

being

done

to

keep

the

existing

Rule

205

enforceable

in

case

any

of

the

amendments

are

overturned

by

court

order

or

disapproved

as

SIP

revisions

(R.234—5).

3 5—252

---

—11—

All users of organic material covered by Rule 205(f) are

required to stay in compliance with that rule unless they are

covered by the new Rule 205(n)(1).

Once these sources have

complied with the applicable standards

in

205(n)(1),

they

will no longer be covered by 205(f).

This relief

is necessary

to avoid conflicts between overlapping regulations.

The relief

does not apply to sources which elect to pursue alternative

compliance under 205(n)(2)

or are exempt under 205(n)(3).

Sources which comply through the use of internal offsets in

205(n)(4) will qualify for this relief.

RACT AND THIS PROCEEDING

RACT has been defined as “the lowest emission limit that

a particular source is capable of meeting by the application

of

control technology that is reasonably available considering

technological and economic feasibility”

(R.43).

In response

to the 1977 Clean Air Act Amendments,

U.S. EPA has published

Control Technique Guidelines

(CTG)

for fifteen emission source

categories that were determined to be sources that could be

further controlled by RACT

(R.44).

The purpose of this pro-

ceeding is

to consider the implementation of RACT on these

fifteen emission source categories.

RACT

is based on control-

ling emissions through reduction rather than through substitu-

tion.

These reductions are to be achieved by retrofitting

add—on control equipment, by changing to water—borne or high

solids coatings

in place of organic materials (R.44) or by

converting to low—solvent coatings

(R.50).

VOLATILE ORGANIC MATERIAL

As part of this proceeding,

many definitions were either

added or changed in order to clarify the rule changes.

Most

of

these definitions are self explanatory and need no further

discussion;

others became issues during hearing.

Nearly all

of the latter group of definitions are discussed with the

related rule.

The definition of “volatile organic material”

applies to several

rules and consequently is discussed here.

The reference to Rules

205(o) and

(p), which were in the Agency

Proposal,

were left out of the final definition because the

term “volatile organic material” is not used in either of Rules

205(o)

or

(p).

A major issue which arose during hearing was whether to

exempt 1,1,1—trichioroethane

(methyl chloroform)

and trichloro-

trifluoroethane from the definition of volatile organic mater-

ial as the Agency originally proposed.

Dow Chemical proposed

exempting methylene chloride also.

The debate did not center

on the photochemical reactivity of these solvents in the tro-

posphere

(the

layer of the atmosphere in which we live) since

data from studies done by U.S. EPA and Dow Chemical show that

35—

253

---

—12—

methylene chloride and methyl chloroform do not react to form

ozone there

(R.1593); trichlorotrifluoroethane has been shown

to be quite stable and does not form photochemical oxidants

either

(R.1534).

Rather,

the debate centered on the possibil-

ity that these solvents might cause adverse health effects

due to human exposure to these solvents and/or due to deple-

tion of ozone in the stratosphere, which begins at a height

of about

6 miles above Earth

(ozone in the stratosphere helps

shield against some wavelengths of

sunlight that have been

associated with increased rates of skin cancer).

Numerous

exhibits

(group exhibits

29,

56,

80,

84 and 85)

and much tes-

timony

(R.182—199,

299—340,

471—477 and 1588—1674)

centered

on

the health effects and stratospheric ozone

issues.

Testi-

mony was presented that the amount of methyl chloroform in the

atmosphere was increasing at an alarming rate.

However,

upon

examination of the supporting evidence,

one finds that this

statement is based on only a few atmospheric measurements

taken two years apart,

by two different researchers, presum-

ably at different locations;

the levels were 65 ±17 pptv in

1974 versus

89

+

9 pptv and 100

+

10 pptv in 1976

(Group Ex.29).

In short, the Board finds the evidence presented on the issue

that these solvents may deplete the stratospheric ozone

layer

to be inconclusive and largely based on speculation without

solid scientific support.

Based on the information submitted on the health effects

of exposure

to either methyl chloroform or methylene chloride,

it seems unlikely that exposure to either of these solvents

in

concentrations that are likely

to occur in the ambient atmos-

phere would result

in adverse human health effects.

However,

there are still many uncertainties regarding health effects.

It should also be noted that the Occupational Safety and Health

Administration has standards for exposures to both these sub-

stances.

The standards are 350 ppm for methyl chloroform

(R.1626) and 500 ppm for methylene chloride

(R.1640).

Hence,

even without these regulations,

exposure to these substances

in the occupational setting would be limited.

Very little information was submitted regarding trichioro—

trifluoroethane except for a statement that it

is persistent in

the

atmosphere (R.1534) and a statement that it is so expensive

that when it

is used for degreasing that it will be controlled

anyway in order to prevent loss.

The Board has decided not to exempt methyl chloroform

(1,1,1-trichloroethane), methylene chloride,

or trichlorotri—

fluoroethane from the definition of volatile organic material

because these solvents have not been well tested for their

toxicological properties and too many uncertainties exist

regarding potential depletion of the stratospheric ozone

layer.

Due to the expense of these solvents,

in many cases control

of these solvents would have been implemented anyway

(R.1611,

1612,

1664).

Indeed,

one witness stated that the majority of

industries that he has seen are already controlling emissions

and would be

in compliance

(R.191).

35—254

---

—13—

There

was

some

discussion

that

methyl

chloroform

and

rnethylene

chloride

are

safer

than

many

of

the

less

costly

chemicals

for

which

they

are

substituted

(R.1595,

1609—10,

1614)

and

that

without

the

exemption,

the

more

hazardous

sub-

stances might be preferred.

In response,

it should be noted

that

the

Board’s

decision

does

not

prevent

the

use

of

methyl

chloroform

and

methylene

chloride.

These

compounds

simply

must

be

controlled

like

any

other

volatile

organic

material.

AMENDMENTS

TO

RULE

205

The

following

is

a

discussion

of

new

Rules

205(k),

(1),

(rn),

(ri),

(o),

(p),

(q)

and

(r)

which

are

a

result

of

this

proceeding.

These

rules

cover

the

following

fifteen

RACT

cate-

gories for which CTG’s have been developed:

1.

Petroleum

Refinery

Sources

2.

Solvent

Metal

Cleaning

3.

Bulk

Gasoline

Terminals

4.

Bulk

Gasoline

Plants

5.

Fixed

Roof

Storage

Tanks

6.

Cutback

Asphalt

7.

Service

Stations,

Stage

I

Control

8.

Surface

Coating

of

Large

Appliances

9.

Surface

Coating

of

Cans

10.

Surface

Coating

of

Metal

Coils

11.

Surface

Coating

of

Paper

12.

Surface

Coating

of

Fabric

13.

Surface

Coating

of

Auto

and

Light

Duty

Trucks

14.

Surface

Coating

of

Metal

Furniture

15.

Surface

Coating

of

Magnet

Wire

Insulation

Rule

205(k)_Solvent_Cleani~

Solvent

Cleaning,

or

degreasing,

is

a

method

of

cleaning

metal

or

other

surfaces,

such

as

electronic

circuit

boards

(R.1539)

with

organic

solvents

in

order

to

prepare

those

sur-

faces

for

painting,

plating,

repair,

inspection,

assembly,

heat

treatment,

or

machining.

During

the

course

of

the

hearings

on

the

Agency

proposals,

the

Agency

recommended

removing

the

word

“metal”

from

“solvent

metal

cleaning”

(R.1539,

Ex.82).

The

intent

was

to

clarify

that

the

cleaning

of

circuit

boards

would

be

covered

(R.1548).

The

focus

of

this

regulation

is

on

the

organic

solvents

and

type

of

equipment

used,

and

not

the

sub-

strate being cleaned.

This rule

is not meant to cover the

situation

in

which

a

substrate

is

coated

with

a

component,

then

certain

areas

of

the

component

are

selectively

removed

by

a

solvent

(R.1549).

The

three

types

of

degreasing

operations

are:

cold

cleaning,

open-top

vapor

degreasing

and

conveyorized

degreas—

:35—255

---

—14—

ing (R.141-4).

The degreasing solvents include petroleum and

petroleum

distillate

derivatives,

chlorinated hydrocarbons,

ketones and alcohol

(R.141).

It

has

been

estimated

that

in

the United States,

emissions from degreasers contribute 725,000

metric tons of VOC annually, which amounts to 4

of the total

VOC emitted (R.144).

The U.S. EPA has calculated the average emission rate for

cold cleaners to be 0.3 metric tons

(0.33 tons) per year per

unit

(R.145).

Waste solvent evaporation from solvent dumped

on the ground and open containers

is the greatest source of

emissions

from

cold cleaners.

Emissions from cold cleaners

are also due to bath evaporation,

solvent carryout,

agitation

and spray evaporation

(R.144).

Open top vapor degreasers have emissions from

(1) diffu-

sion and convection, which

is the largest source;

(2)

carry—

out;

(3) the roof vent;

and

(4) waste solvent

(R.146).

Accor-

ding to U.S. EPA calculati~ns, the average open—top vapo~de-

greaser emits 2.5 kg/hr./m

of opening

(0.5 lbs./hr./ft.

(R. 146).

Solvent

loss from conveyorized degreasers

is associated

with

large and continuous work loads.

Emissions per unit due

to bath evaporation and waste solvents is less than with other

degreasing methods.

However,

the total amount of emissions

is significant due to the high volume of work

(R.146).

Since emission standards for degreasers are not practical,

Rule

205(k)

requires specific control equipment and operating

procedures which were developed to minimize emissions.

Many

industries already have these controls

in place to prevent

loss

(R.193) and because the high cost of halogenated solvents

makes

it economical

to recover the solvent by distillation

and recycling

(R.146).

It has been estimated that compliance

with Rule 205(k)

as compared to no controls would result

in

a reduction in emissions from open—top vapor degreasers of

8,250 to 10,975 metric tons/year (9,150 to 12,200 tons/year);

the

reduction

for

cold

cleaners would be 6,250 to 6,600 metric

tons/per

year

(6,700

to

7,350

tons/year)

(R.154).

Since many

of these controls are already

in place,

the actual emission

reduction to be expected will be somewhat

less.

Small cold cleaning operations with less than 6.8 kg

(15

lb.)

of emissions per day are exempt from the requirements

of

Rule 205(k).

Although larger cold cleaners

do not have

to

obtain an operating permit from the Agency,

they must still

comply with this rule.

Vapor and conveyorized degreasers are

required to obtain an operating permit.

Since this rule is

self explanatory,

no further discussion is necessary.

Rule 103(i) has been amended to include cold cleaning

degreasers

among the classes

of equipment which do not require

35—256

---

—15—

operating permits.

This was done to avoid the administrative

burden the Agency would face

in processing approximately 40,000

permit applications from relatively small pollution sources

(R.656).

These sources will still be required to comply with

the

requirements

of 205(k)(2)(A)

and (3)(A)

unless they are

exempt under 205(k)(1).

The Agency will enforce these opera-

ting requirements through the inspection procedure

(R.657).

Rule

205(1)

Petroleum

Refineries

Refineries

include

facilities

which

produce

gasoline,

kerosene,

distillate

fuel

oils,

residual

fuel oil,

lubricants

or other products by distillation, cracking,

extraction or

reforming

of unfinished petroleum derivatives.

This rule, which

includes

equipment

specifications

and

monitoring

techniques

for

vacuum

producing

systems,

wastewater

(oil/water) separa-

tors,

and process unit turnarounds,

represents Reasonably

Available

Control

Technology

(R.169).

In Rule 205(l)(2), Wastewater

(oil/water) Separator,

it

is specified that wastewater separators have equipment to

control emissions of organic material unless an odor problem

does not exist.

If there

is no odor problem, only volatile

organic material

needs

to be controlled.

The reason for this

differential between organic material and volatile organic

material

is the possibility that some compounds would fit the

first

definition

and create an odor problem,

but have a low

enough vapor pressure that they would not be covered by the

second

definition.

At the present time,

all nine refineries in Illinois have

control equipment for vacuum producing systems which meet RACT

and follow the specified procedures for process unit turn—

arounds.

Four out o~

the

nine

refineries

already have covers

on

the

oil/water separators which comply with this

rule.

For

the other

five,

it

is believed that the organic compounds are

less than 1.5 psia, which will exempt them from control under

the volatility criterion,

unless they create an odor problem.

If the oil/water separator causes an odor problem,

controls

will he needed

(Ex.62,

p.B—3).

Rule 205(n) Surface Coating

Rule 205(n) (1)(A) Surface Coating at Automobile or Light Duty

Truck

Manufacturing

Plants

This rule applies

to surface coating of the body,

fenders,

chassis,

small parts,

wheels,

etc.

of automobiles and light

duty

trucks.

The term

“automobile” refers to passenger cars

or their derivatives which are capable of seating no more than

twelve passengers.

“Light duty trucks” means motor vehicles

35—257

---

—16—

or derivatives which are rated at 8,500 pounds or less gross

vehicle

weight

and which are designed for transportation of

property

(e.g. pickups, vans, etc.)

(R.588).

Several methods of reasonably available control technology

were discussed.

They include:

1)

Electrodeposition of water borne primer, which can only

be applied directly over metal

(R.590);

2)

Low solvent primer and topcoat, which would require the

fewest changes

in operating requirements;

3)

Carbon adsorption which,

although technically feasible,

requires large amounts of electricity (R.591);

4)

Incineration for spray booths and primer and topcoat ovens,

also technically feasible, but which requires high energy

consumption;

5)

Water borne top coats, which would require major process

modification for retrofit at the two Illinois plants.

The rules for surface coating of automobiles and light

duty trucks take into account the problems of the two plants

in Illinois.

The compliance plans for these plants reflect

Ford’s and Chrysler’s schedules

for bringing all their plants

in the U.S. into compliance

(R.1277).

Exact adherence to U.S.

EPA RACT guidelines would require

the

equivalent

of electrodip prime and water base topcoat

(R.385).

Even though the technology

is

in use at two Califor-

nia plants,

the costs associated with meeting these limitations

are very high.

The high costs are associated with the use of

water as

a basis for the coatings.

Flash tunnels and ovens

would have

to be lengthened to allow longer drying times.

The

oven temperature would have to be raised and humidity would

have to be controlled.

Incoming spray booth air would have

to be filtered to remove dust which might adhere to the slower

drying

surfaces.

Measures

to prevent corrosion and rusting

of equipment during shutdowns and process changes would have

to be implemented

(R.594—5).

Both Ford and Chrysler made their own recommendations for

methods

of compliance

(Ex.41,75,71,79).

Both methods would

allow only slightly higher emissions, but the cost differen-

tial

is significant

(R.783).

One of the coatings Ford expects

to use is not fully developed yet

(R.790).

However, Ford has

already spent $15 million to install an E—coat system which

will upgrade corrosion protection on cars.

Reduction of VOC

emissions was a secondary consideration

(R.791).

This amount

is

included in Ford’s estimate that it would cost them $32

million to comply

(R.791).

35—258

---

—17—

Chrysler considers changing to water—base topcoats to be

too

expensive.

Uowever,

they do

support and will follow a

program to achieve

a higher solids content in their coatings

(R.388).

They consider the final repair guidelines to be

reasonable and obtainable and plan to comply with them by 1982

(R.389).

In order to reduce the amount of overspray and emis-

sions,

electrostatic paint facilities will be installed in the

Belvidere plant by 1982

(R.389).

Changing to 50

solids top-

coat and 35

solids for final repair will reduce VOC emissions

by approximately 57,

which is more than 700 tons of emissions

per year

(R.389).

Rule

205( n)

(~icL~cQa~r~9

Can coating includes the application of coating material

to two- or three-piece cans by spraying or roll—coating and

the use of side seam sprays

(in three—piece cans) and end—

sealing compounds.

Due to the wide range

in products for which

cans are used,

a variety of compounds must be used to meet all

the coating requirements.

Cans that contain food must meet

FDA requirements for odor and taste as well as

leak resistance.

At the present time,

American Can Company uses more than 40

different compounds at its two plants

in Illinois.

Approxi-

mately

90

of the compounds are solvent based.

Some,

such as

the coatings used on cans for paint thinner or oil—packed fish,

are water based

(R.741).

One problem with water—based com-

pounds

is that they require heated ovens or dryers

(R.742).

Four types of control technology have been determined

to be RACT for can coating.

A list follows:

1)

Incineration would be most applicable for sheet coaters,

two—piece can coaters and three—piece interior body spray

coaters because of the relatively high drying oven

tem-

perature and

the concentration of organics in the oven

gases.

Side seam spray coat and end sealing compound

applications are not as well suited to incineration be-

cause they are usually air dried.

Due to air drying,

the

gas

volume

is

large,

usually

at

ambient

temperatures,

and contains relatively low concentrations of organics

(R.616).

An additional

problem with incineration is that

significant amounts of energy may be required

(R.618).

2)

Water—borne/high—solids/powder coatings.

a)

Low solvent coatings are available

for some uses

but are not available to replace all coatings at

the present time

(R.618).

b)

Water—borne coatings are presently in use for various

applications.

However,

in order to expand their use,

it may be necessary to replace some existing facili-

ties

(R.619).

35—259

---

—18--

c)

High

solids

coatings

are

highly

viscous

since

they

contain only 20 to 30

volatile solvent by volume.

Hence,

the coatings may need to be heated before

application

(R. 619).

d)

Powder coatings approach 100

solids.

A major

change in the coating application equipment would

most

likely be needed

to switch to powder coatings

(R. 620)

3)

Carbon adsorption is most readily used as a control method

on low temperature processes which use a limited number of

solvents

(R.620).

If a single solvent is captured,

it

could be recovered for reuse during regeneration of the

carbon bed.

If numerous solvents are captured,

it may be

more economical to use the recovered solvents

as boiler

fuel than to distill them for reuse

(R.621).

4)

Ultraviolet curing involves the use of coatings which

cure almost instantaneously in the presence

of ultra-

violet light.

Hence, only a small amount of organic

emissions are produced

(R.621).

Although

it has been

shown to be successful on some formulations, many coat-

ings are still

in the developmental stage and need FDA

approval

(R.622).

With the application of RACT in Illinois,

the estimated

5,864 tons of VOC emitted annually from can coating operations

would be reduced by 4,847 tons/year (R.623).

The internal offset provisions, which are discussed in

more detail

later, were originally developed for the can coating

industry because of various problems the industry might have

in meeting RACT limitations by the compliance dates.

These

problems include:

(1) The possible decline of three—piece can

side seam technology,

in which case

it would probably be more

cost beneficial to put the research effort into two—piece

technology;

(2) Twenty-five percent of the coating materials

in use represent a large number of coatings, each of which

is

used in small amounts.

Hence,

the cost of developing a low—

solvent coating for a small volume use may outweigh the bene-

fit;

(3) As mentioned before,

some of the coatings are used to

coat cans

in which food is packed.

Reformulation of these

coatings may take several years due to the need for FDA appro-

val and the necessity of long term testing programs to deter-

mine

if food contamination occurs

(R.819).

Testimony by various suppliers of can coating compounds

indicated that they expect that the can coating industry,

through the use of internal offsets, will be able to comply

by the specified compliance dates

(R.829,

1510—16,

743).

~c—9’;n

---

—19—

In Rule 205(n)(1)(B) the Board has adopted six limitations

on the emission of volatile organic material from can coating

lines.

In Rule

201 the Board has adopted eight new definitions

to clarify the terms in 205(n)(1)(B).

The Board has adopted

these changes so that a specific emission limitation can be

applied to each coating operation which

is typically found in

a can coating plant.

This degree of detail

is not intended to

exempt any can coating operation which does not fit a narrow

construction of any definition.

Rule 205(n)(1)(C) Paper Coating

Paper coating refers to the application of a surface

coating to paper,

metal

foil, plastic films,

pressure sensi-

tive tapes,

etc.

This rule does not cover operations

in

which a material,

such as plastic,

is obtained in sheets and/or

rolls and converted into

a package

(R.1526—7).

Rotogravure is

considered to be printing in this case and therefore will be

covered by

a different rule

(R.517) since equipment that is

used for printing and paper coating

is excluded from this

rule.

Examples of paper coating products include adhesive

tapes; adhesive labels; decorated,

coated and glazed paper;

book coverings; office photocopier paper;

carbon paper; type-

writer ribbons and photographic film

(R.515).

Methods of compliance include incineration, carbon adsorp-

tion and substitution of low solvent or water—based coatings

(R. 273).

Witnesses

from

paper

coating

industries

testified

that

they

would

prefer

to

work

with

water—based

coatings because

they

are

safer

and

more

economical

in the long run (R.460) and

have

production

advantages

(R.294).

One company is planning

to

switch

to

solventless

technology

regardless

of

these

regula-

tions

unless

they

would

be

forced

to

install

add—on

control

equipment

first

(R.294).

However,

they

have

experienced

prob-

lems

with

these

coatings

(R.462).

The

main

problems associated

with

coating

plastics

and

metal

foils

with

water—based

coatings

is

that

the

surface

of

these

two

substrates

is

hydrophobic.

Hence,

solvent

is

needed

in

the

coating

material

to

improve

wettability

and

adhesion

(R.749).

A particular problem that

one

manufacturer

has

is

that

he

must

obtain

FDA

and

customer

approval

for

his

product

since

it

is

used

in

medical

devices

(R.347,464).

Therefore,

he

may

not

be

able

to

meet

the

1982

deadline

(R.464).

However,

this

manufacturer

can

still

use

the

internal

offset

provision

or

apply

for

a

variance

(R.1160—1).

Rule

205(n)(l)(D)

Coil

Coating

The

surface

coating

of

metal

coils

refers

to

the

coating

of

flat

metal

sheets

or

strips

that

come

in

coils.

These

metal

~S—2h1

---

—20—

coils have many uses such as

cans,

appliances,

roof decks,

shelving and gutters

(R.539).

Nine coil coating plants are

located

in

Illinois;

eight

of

them

in

the

Chicago

area

(R.540).

Approximately

90

of the VOC emissions come from the drying

ovens.

Several

control

options

are

available:

incinerators,

water-borne coatings and high solids coatings

(R.540).

Incin-

eration with heat recovery appears to be the best control op-

tion

(R.545).

At the present

time, high

solids coatings have

application problems;

and water—borne coatings do not meet

performance requirements

(R.443).

With the internal offset

provision,

the

coil coating industry should be able to achieve

the RACT limitation

(R.764).

Rules 205(n)(1)(E) Fabric Coating and

(F) Vinyl Coating

In these processes,

a coating substrate is applied to

fabric or vinyl by using a knife,

roll or rotogravure.

The

coating adds qualities

such as increased strength,

stability,

water or acid repellency, or appearance.

All seven facilities

in Illinois are located in the Chicago area

(R.600).

One man-

ufacturer who has not yet installed any VOC controls

is respon-

sible for 83

of the 1,659 tons of VOC per year emitted by

fabric and vinyl coaters in Illinois

(R.608).

Sixty—five to

seventy-five percent of the solvent emissions from the coating

line are emitted from the oven (R.600—602).

Reasonably avail-

able control technology includes incineration with possible

heat recovery, carbon adsorption with solvent recovery, and

low organic solvent coatings such as high solids and water—

borne coatings

(R.605—606).

Rule 205(n)(1)(G)

Metal Furniture Coating

This rule covers the application of a surface coating to

metal furniture or metal parts of furniture.

The coatings

are applied by spraying, dipping or flowcoating and are used

to protect against corrosion.

In order to do this,

the coat-

ing must he durable to withstand use and have good adhesion

properties to avoid peeling and chipping.

It must also be

acceptable aesthetically (R.577).

There are six methods of controlling VOC from metal fur-

niture coating operations.

They are:

1)

use of powder coatings;

2)

application of water-borne coatings by electrodeposition;

3)

application of water—borne coatings by spraying, dipping

or flowcoating;

4)

use of high solids coatings;

5)

removing VOC emissions by carbon adsorption;

6)

removing VOC emissions by incineration

(R.580).

35—262

---

—21—

Add—on control devices

(carbon adsorption and incineration) are

the least cost effective

(R.585).

The metal furniture indus-

try is

an example of another industry for whom the internal

offset provision may be essential

(R.263,404) since the water—

borne coatings currently available for dipping do not meet

certain quality standards

(R.260)

and the technology does not

exist to apply 70-80

volume solids paint under production

conditions

(R.255—6).

If the required technology is not

developed and in use by the required time,

at least one source

may need to apply

for a variance

(P.C.#100).

Of

27 facilities in Illinois,

14 would be exempted from

these rules due to the 25 ton/per year size exemption

(R.1527).

Rule 205(n)(1)(H) Large Appliance Coating

Doors,

cases,

lids,

panels and interior support parts of

residential and commercial washers, dryers,

ranges,

air condi-

tioners and other large appliances are coated by spraying,

dipping or flowcoating techniques.

In addition to serving an

aesthetic purpose,

coatings must protect metal

from corrosion

due to moisture,

heat,

detergent and occasionally weather

(R.534).

Usually 50

of the emissions are from the coating

and flashoff area with the rest coming from the oven area.

The exact amount depends on the coating application

(R.534).

Three coatings suppliers support the emission limitation of

0.34 kg/i

(2.8 lb./gal.) for large appliance coating

(R.404,

443,764).

Rule

205(n)(1)(I)

Magnet

Wire

Coating

Magnet wire coating

is the coating of aluminum or copper

wire with an electrically insulating varnish or enamel

in pre-

paration for use

in

electrical machinery.

All five magnet

wire insulation facilities in Illinois meet RACT.

The most

common form of compliance is incineration since most emis-

sions are from the drying oven.

Hence, the gases are already

at

a high temperature and contain moderate to high solvent

loads

(10—25

LEL)

so that little additional

fuel is necessary

(R. 548).

Rule 205(n)(2)(A)

Rule 205(n)(2)(A) provides for compliance with the emis-

sion limitations

in

Rule 205(n)(1) through the use of after—

burners.

It

is necessary to specify a capture efficiency as

well

as

a combustion efficiency to insure that emissions are

captured and are vented to an afterburner

(P.C.74).

The Board

believes that a capture efficiency on coating

lines of 75

is

RACT based on information in Exhibit 17 which cites an existing

35— 263

---

—22—

coating line from which 73

of the emissions are captured.

However,

some systems can be designed to capture more than

this.

If

not,

facilities can utilize the internal offset pro-

visions to attain compliance

(P.C.74).

Rule

205(n)(4)_Internal_Offsets

As

mentioned previously,

the emphasis

in determining

reasonably available control technology was on retrofitting

add—on control equipment or changing to water borne or low

solvent coatings

(R.44).

During the hearings,

several coating

suppliers testified on the availability of surface coatings

that would meet RACT limitations

(R.376—83,398—408,438—57,

758—68,813—22,1502-5),

There are some coatings such as water-

based electrodeposition, powder coatings, new resin systems,

high

solids and existing

resin systems which are capable of

meeting RACT at the present time

(R.398).

In addition, one

supplier predicts that by 1982—83,

75-80

of the coatings

necessary to meet RACT will be available

(R.376).

However,

these technologies are not necessarily applicable to all seg-

ments of

industry (R.399).

Examples of problem areas include:

auto coating,

due to the high costs

of converting to water—

borne coatings; millwork production in wood,

since water has

a detrimental effect on wood substrate; precoated architectur-

al finishes on metal coil

stock,

where low—solvent technology

may not find an early breakthrough

(R.378-9); and some can

coatings which must also meet regulations of other agencies

such as the Food and Drug Administration

(R.815).

The Board agrees that in the long run, substitution of

coatings which meet RACT for coatings which do not meet RACT

is preferable

to retrofitting coating lines with add—on con-

trol equipment.

However,

the Board is also cognizant of the

possibility that not all of the required coatings will

be

available by the required date.

Therefore,

in order to pro-

vide incentive for the development and utilization of low

solvent or solventless technology,

an internal offset provi-

sion

(“bubble”)

is included in Rule 205(n)(4).

The “bubble”

concept should allow the facilities the flexibility to over-

comply on the lines where it

is possible and use this over—

compliance as

an offset on the lines where the technology to

comply either does not exist

or is very expensive

(R.1096).

For the most part,

the formulas

in Rule 205(n)(4)(A) are

self-explanatory.

Essentially this rule states that the sum

of the VOC emissions that actually come from the “bubbled”

coating lines can not exceed the sum of the allowed emissions

from those

lines.

Rule 205(n)(4)(C)

limits the internal offset provision

to include only those sources which are covered by RACT

(R.1115).

Control

of fugitive emissions from distribution lines,

valves,

etc. will not be allowed as offset credit

(R.1788).

A daily

35—264

---

—23—

averaging

period

is

used

since

a longer averaging period, such

as

one

month,

could

load

to

the

frequent

shutdown

of

low

sol-

vent coating lines while still taking credit under the internal

offset

provision

(R.1789).

Rule

205(o)

Bulk

Gasoline

Plants,

Bulk

Gasoline

Terminals,

and Petroleum Liquid Storage Tanks and Rule 205(p) Gaso-

line

Dispensing

Facility

Rules

205(o)

(1)

and

(2)

and

205(p)

require

vapor

recovery

at.

certain

hulk

gasoline

plants,

hulk

gasoline

terminals

and

during

transfer

of

gasoline

from

delivery

vessels

into

station-

ary

storage

tanks

at

gasoline

dispensing

facilities, respec-

tively.

These rules apply to gasoline only and not to other

VOC’s which are used for fuel,

such as fuel oil.

Essentially,

vapor recovery involves capturing vapors which would otherwise

escape

to the atmosphere during gasoline transfer operations

and recovering those vapors by condensation.

The condensate

is

then available for use.

Leakage

from the transport vessels

would reduce

the amount of gasoline available for recovery.

Hence,

rules to minimize leakage are included.

Several vapor balance

(or vapor recovery) systems were

discussed.

They include the Wiggins

tank wagon vapor balance

system

(R.842—44,85—76),

the Houston—Galveston system

(R.850—

76),

and other systems

(R.879—84,662—90).

Aside from the costs

involved, which will be discussed

later,

the major problems with vapor recovery are the method

of detecting when

the transports or tank trucks are full and

the emergency shut off systems

(R.977—88).

Malfunction of

these systems may result

in a fire and explosion hazard

(R.864,

977-88) which would have the potential to cause more severe

injuries than spill and discharges from non—pressurized sys—

terns

(R.1008).

However, proper operation of these systems

should not result in any greater hazard than if these systems

were not

in use.

Submerged fill

is required in order to minimize the

amount of vapors which would arise during splash loading.

Vapor balance for shipments of gasoline from vessels

into

storage tanks at bulk plants works without problems

(R.876).

The terms

“bulk gasoline plant” and “bulk gasoline terminal”

reflect the distinction between the two based on relative

position in the chain of distribution and the manner in which

gasoline is received at the facility (R.1270).

Bulk gasoline

terminals are required to utilize vapor recovery during trans-

fer operations state—wide because,

due to their size,

they

are

larger sources of emissions.

In addition, most terminals

are located

in

or near large metropolitan areas.

Out of 34

terminals state—wide,

12 are in the Chicago area and 7 are in

35—265

---

—24—

the East St. Louis area.

It

is believed that most terminals

are already equipped with vapor recovery systems or floating

roofs

(R.571).

The required vapor balance systems should be-

come cost effective as through-put

increases

(R.574).

Stage

I vapor control

at service stations involves VOC

control during gasoline loading of

storage tanks from trans-

port vessels

(R.643).

Emissions are controlled by collecting

the vapors which are displaced from the storage tank and

returning them to the tank truck by the use of hoses and coup-

lings to provide a “closed loop.”

The vapors are then taken

back to the bulk plant or terminal

for processing by a vapor

recovery system or are routed to an on—site vapor recovery

system

(R.645).

Approximately half of the state—wide emis-

sions from the 8,000 service stations in Illinois are in the

six—county Chicago area

(R.645).

Vapor recovery for these two types

of sources is required

only

in those counties which have or are near

large metropoli-

tan areas for economic reasons.

About half of the gasoline

dispensing facilities

in Illinois are located within the thir-

teen counties

listed below.

Most bulk plants are located

in

rural areas

of the state

(R.841).

When the probable improve-

ments in air quality which would result from requiring vapor

recovery

in

the rural areas

of the state are compared with the

relative cost of control and economic burden on

a significant

number

of relatively small sources,

it appears that vapor

recovery at bulk gasoline plants and Stage

I vapor recovery

at gasoline dispensing facilities

is RACT only in the listed

counties

(R. 1791).

Unlike the rest

of the rule changes

in this proceeding,

the rules

on

vapor recovery at bulk gasoline plants and gaso-

line dispensing facilities do not apply state-wide.

They are

required only in the following counties:

Boone, Cook,

DuPage,

Kane,

Lake, Madison, McHenry, Peoria, Rock Island,

St.

Clair,

Tazeweil,

Will and Winnebago.

Size exemptions for bulk gasoline plants and gasoline

dispensing facilities are included so that small operators

who are not a major source of emissions will not have to util-

ize vapor recovery which would have provided relatively little

return.

Storage tanks with a capacity less than 2,000 gallons

are exempt

as recommended

(R.1025).

Since most,

if not all,

existing tanks on farms have a capacity less than 2,000 gallons

and 575 gallons

is the maximum size for an exemption for new

farm storage tanks,

(560 gallons

is considered to be standard

size

(R.933)),

it

is unlikely that any farm storage tanks

would be subject to these

rules.

35—26 6

---

—25—

Rule

205(o)(3)

Petroleum

Liquid

Storage

Tanks

This rule requires certain equipment and operating pro-

cedures to minimize leakage of volatile petroleum liquid from

large

stationary

storage

tanks.

The

exemptions

are

listed

in

Rule

205(o)(3)(A).

Crude

oil

storage

tanks

used

to

store

produced

crude

oil

and

condensate

prior

to

custody

transfer

with

a

capacity

less

than

442,675

gallons

(10,540

barrels

or

1,600,000

liters)

are

exempt

due

to

economic

consideration.

If

a

petroleum

liquid

storage

tank

is

used

to

store

crude

oil

or

condensate

in

crude

oil

gathering,

the

size

cutoff

for

an

exemption

is

9,000

barrels.

A

representative

from

Union

Oil

Company

stated

“the

in-

stallation of internal floating roofs

in existing tanks having

a capacity of 10,000 barrels or more are proven emission reduc-

tion tools and over many years save enough valuable petroleum

to pay for their installation (R.1690).

However,

retrofitting

existing tanks which will be in use for only a few years may

not be economical.

“Virtually all new storage tanks incorpor-

ate floating roof technology”

(R.1691).

Data on emissions

from crude storage tanks indicates that 10,000 barrel tanks

emit 100 tons per year

of volatile petroleum liquids

(R.1540).

Hence, 10,000 barrel

tanks are not an insignificant source.

Fixed roof storage tanks are cylindrical

steel tanks with

permanent roofs which vary from being flat to cone—shaped.

Emissions are controlled by an internal

floating roof cover

and routine inspections of the cover.

Internal floating roofs

are

90

efficient in reducing emissions from fixed roof stor-

age tanks

(R.564).

Since the seals frequently last 20 years

and the seal can be inspected for holes without emptying the

tank, routine inspections can be made through roof hatches

(R.1024) and emptying of the tank

is not required.

Emptying

a tank and freeing the gas for safety reasons would take at

least three days

(R.1024).

Rule 205 (q) Cutback Asphalt

Cutback asphalt is asphalt which has been diluted or

“cutback” with petroleum solvents such as naphtha,

kerosene or

gasoline

(R.630) to form

a liquid.

Road paving accounts for

most emissions from cutback asphalt.

VOC emissions also occur

during manufacturing, mixing and storage of cutback asphalt.

Emissions from the use of

asphalt total

64,200 tons of VOC per

year with most emissions occurring during the warmer months.

The substitution of emulsified asphalt for cutback will control

hydrocarbon emissions since the diluent in emulsified asphalt

consists of 98

water and 2

non—VOC emulsifier

(R.633).

Since

emulsified asphalt cannot he used at cold temperatures

it

freezes

at temperatures below 32°F (R.906)1

and ozone is not

formed at cold temperatures, the use of cutback asphalt is

35—267

---

—26—

allowed

between

October

1st

of

one

year

and

April

30th

of

the

next year.

Although

the

work

crews

have

to

be

more

organized

to

apply

emulsified

asphalt

(R.917—8),

there

are

few

differences

in procedures or equipment needed to apply the two types of

asphalt

(R. 637,917).

One problem which did arise

is that due to differences

in the amount of residual material in the two asphalts, one

user must apply 33

more emulsified asphalt than cutback

(R.1757).

Another user also testified that he must use more

emulsified asphalt than cutback

(R.1767—8).

However,

a third witness testified that ultimately emulsi-

fied asphalt will produce better roads

(R.939).

Besides reducing VOC,

there are several benefits from

using emulsified asphalt.

If the U.S. converted entirely to

emulsified asphalt from cutback asphalt,

the amount of energy

saved annually would equal a five day through-put of the

Alaskan pipeline operating at maximum efficiency

(R.919).

The

energy savings would result from the use of fewer petroleum

distillates and

less energy needed to heat the asphalt since

emulsified

is applied at a lower temperature (120—180°F)than

cutback (250—300°F).

This temperature difference also makes

emulsified safer for worker use

(R.921).

In addition,

there

is also less of a flammability hazard

(R.939)

and fewer odors

are associated with emulsions

(R.923).

Availability of emulsified asphalt should not be a problem

(R.940).

Allowing the use of cutback asphalt from a long—life

stockpile for repairing potholes and similar jobs after April

30th will avoid wasting cutback

(R.1308).

Cutback must be

used for patches during winter

as emulsions would freeze and

break

(R.1042).

This exception applies to stock mixed with

aggregate,

but not raw liquid cutbacks

(R.1308).

Prime coat essentially acts as an adhesive

(R.906,910)

and is used to prepare a surface such as raw concrete or raw

rock for a seal coat

(R.910).

At the present time,

no suit-

able emulsified prime coat materials exist

(P.C.26).

However,

since the prime coat is usually applied immediately before

paving, VOC emissions are trapped beneath the paving material

and do not cause significant emissions to the atmosphere (P.C.26).

AFTERBURNER SHUT-OFF

Rule 205(r) specifies under what circumstances afterbur-

ners need not be operated.

The Agency’s monitoring data mdi—

35—268

---

—27—

cates

a

distinct

ozone

season

in

Illinois

which

lasts

from

April

through October; no values in excess of the new Federal

standard

of

0.12

ppm

have

been

observed

in

Illinois

from

November through March for the last four years

(R.1309).

The Board agrees with the Agency that this exemption, as writ-

ten,

will

not adversely affect public health.

This exemption

will result

in both

a dollar and energy savings during these

months.

The

original

Agency

exemption

applied

only

to

natural

gas

fired

afterburners.

An

industry

representative

suggested

(R.1364)

that

the

exemption be expanded

to

include

oil-fired

afterburners;

the Agency concurred with this

(R.1794).

The

Board agrees that this exemption should apply to oil-fired

afterburners.

It should be clear that this exemption does not

apply to flares,

such as those found at petroleum refineries

(R.1310).

The U.S. EPA supported seasonal curtailment of afterbur-

ner use under somewhat more limited circumstances

(R.1308,

Ex.17).

The Board

finds that a statewide exemption is consis-

tent with statewide controls.

The exemption contains a require-

ment that these afterburners be operated

if an ozone Advisory,

Alert

or Emergency is declared;

this requirement will ade-

quately safeguard against excessive volatile organic emissions

from these sources which might occur during the period Novem-

ber 1 through April

1.

ECONOMIC IMPACT

The Institute of Natural Resources submitted a study

entitled Economic Impact of Incorporating RACT

I Guidelines

for VOC Emissions into the Illinois Air Pollution Control Reg-

ulations

(INR Document No.

79/01)

(hereinafter “Study”)

(Ex.62).

The Study examined the air quality consequences of the proposed

regulations; considered benefits in terms

of changes

in health

effects,

crop damage and materials

deterioration; estimated

control costs to the regulated industries;

and analyzed some

secondary economic impacts.

The consulting organization of

Booz,

Allen

&

Hamilton prepared a report for U.S.

EPA entit-

led “Economic Impact of Implementing RACT Guidelines

in the

State

of Illinois”

(hereinafter

“BAli Report”)

(Ex.65).

The

objective of the BAH Report was to determine the costs of

controls needed to implement the RACT guideline limitations

(R.1252).

In a number of instances the BAH Report was used

as

a source by the Study authors for those portions of the

Study dealing with control costs; however,

the two are not

identical.

This

is discussed below.

The Study,

the BAH

Report and testimony developed at hearings provided the Board

with a great deal of information with which

to determine the

economic reasonableness and to gauge the economic impact of

the various proposals.

The Board concludes

that the regula—

35—269

---

—28—

tion

adopted

is

an

economically

reasonable

method

of

reducing

ozone pollution.

There will be some adverse economic impacts

on the People of the State of Illinois;

these adverse impacts

must be compared with the alternative, which

is continued

ozone

levels

in excess of the NAAQS and vulnerability to the

economic sanctions of the Clean Air Act.

The

Study provided an estimate of total capital costs of

$15.6 million to bring bulk terminals into compliance

(Ex.62,

p.47).

This estimate included costs

for conversion from top—

submerged loading to bottom loading for 90

of the bulk ter-

minals

in Illinois (P.C.75),

totaling $5.7 million.

Vapor

recovery units were presumed added for all bulk terminals at

a cost of $9.9 million.

These cost estimates were based on

industrial experience

(Ex.62,

p.47; P.C.75).

Annualized

costs,

not including gasoline credit, were put at $3.6 million

(Ex.62,

p.49).

The economic value of the recovered vapors

was calculated to provide an overall net savings of $27 per

ton of

reduction in VOC emissions

(Ex.62,

p.48).

The estimates above were contested at hearings and through

comment.

The underlying emissions inventory,

which affects cost

effectiveness, was challenged

(R.1216—21).

Unit costs of con-

version to bottom loading and control efficiencies were ques-

tioned (R.1774,

Ex.89;

P.C.71).

The Board recognizes that the

cost/effectiveness ratios can vary substantially depending on

which estimates are used.

Individual terminals may also vary

from standardized estimates.

The record contains representa-

tive estimates for a range of installations.

Differing degrees of control of VOC by bulk plants are

required depending on geographic location and yearly through-

put.

The Study presented unit costs of control, estimated

the number of affected installations, and combined these two

to present a statewide impact

(Ex.62,

p.48—53).

The addition

of Boone County to Rule 203(o)(1)(G) would alter somewhat

the statewide estimate; unit estimates are,

of course, unaffec-

ted.

Industry testimony indicated that the unit costs for con-

version of bulk plants may be somewhat understated, but gener-

ally are comparable to industry estimates

(R.1743).

These

sources are

among

the

few

that

are

not control led statewide.

The Agency’s proposals and the Board’s Order recognize the

economic burden of these controls.

The rule applies

to sig-

nificant sources

in areas where control of VOC is most needed;

concerns of economy and efficiency have mandated that smaller

sources be exempted.

The Agency proposal and the Board’s Order contained

requirements for storage tanks used to store crude oil or con—

densate in crude oil gathering

See

203(o)(3)(A)(4) and

203(o)(3)(B).

Concerns for economy and efficiency have

35—270

---

—29—

caused the Board to agree that a cutoff

level of 9,000 barrels

storage capacity

is appropriate.

The Illinois Petroleum Coun-

cil has indicated that this will exempt 69 out of 101 existing

tanks

storing crude oil or condensate in crude oil gathering

(Ex.87).

The Illinois Petroleum Council and others had urged

a higher exemption level; however,

the Board finds that while

retrofit costs on tanks this size may be substantial

(Ex.86),

so are the emission reductions gained

(Ex.82).

Thus,

the

9,000 barrels exemption level

is

adopted.

Requirements for certain storage tanks remain unchanged;

hence,

no economic impact to those sources

is attributable to

this regulation.

Petroleum refineries

in Illinois currently comply with

Rules 205(l)(1) and

(2).

Hence, the adoption of these rules

only requires continued operation in the current manner and

no additional control costs nor emission reductions

are an-

ticipated.

Rule 205(l)(3) may require some minor additional

record—keeping requirements.

Rule 205(p) requires Stage

I vapor control at gasoline

dispensing facilities

located in 13 counties

of the State.

The Agency estimated total conversion costs to be $2,000 per

service station, exclusive of any gasoline recovery credit

(R.648).

The Study estimated typical capital costs of con-

version to range from $600 to $2,000,

depending on the system

chosen

(Ex.62, p.58).

The geographic scope of this rule follows that of the

rule governing bulk plants;

the reasoning is consistent.

The

limited coverage, combined with the size exemptions, will

result

in emission reductions where they are needed most in

an economically efficient manner.

Rule 205(n)(1)(B) specifies numerical emission limits of

VOC for can coating.

Four types of control were discussed

above.

However,

it is clear that the preferred and anticipated

control method

is water—borne or low solvent coating compounds

(H. 1510,723).

The exact economic impact on the can manufacturing indus-

try

is

difficult to estimate due to the interplay of several

factors.

The first

is that development of low solvent coating

compounds cannot be guaranteed.

The second factor is Rule

205(n) (4), the provision on internal offsets.

The third fac-

tor is Rule 205(n)(2),

the provision on alternative compliance.

The compliance method of

a given source will probably be

unique, depending on how these factors apply to the source.

For example, sources using end seal compounds may not be able

to use low solvent coatings to comply by 1982

(R.1517);

the

method chosen for compliance will depend on the peculiar

operating characteristics of that source.

The Study

(Ex.62,

35—27 1

---

—30—

p.66-71)

estimated

compliance

costs

based

on

a

combination

of

water

borne

coatings

and

incineration.

An

addendum

to

the

Study

(P.C.75)

states that the BAli Report indicated an expec-

ted decrease

in

future incineration installation.

Neither the

Study

(R.1200)

nor the BAli Report

(R.1254) considered the in-

ternal offset provision for can coating; hence the total cost

estimates

provided

are

of

limited

use.

The

Board

agrees

with

the

Can

Manufacturers

Institute

that

the

approach

taken

is

cost

effective

(R.1516).

Compliance

by

paper

coaters

is

expected

to

be

achieved

through

a

combination

of

control

equipment

(incinerators

or

carbon

adsorption

units)

and

low

solvent

or

water—based

coat-

ings.

Neither

the

BAll

Report

(R.1254)

nor

the

Study

(R.1200)

were

able

to

include

the

impact

of

the

internal

offset

pro-

vision

in their estimates.

Both the BAli Report and the Study

estimate

control

equipment

to

cost

three

to

four

times

that

indicated

in

the

CTG

document

(Ex.62,

p.75;

R.1377;

P.C.75).

The amount of control equipment necessary may also vary from

source

to

source

due

to

differences

in

exhaust

stream

organic

concentrations.

Compliance through add—on equipment is not an inexpen-

sive proposition;

low solvent or water—based coatings may also

entail substantial capital costs

(R.1201).

The emission reduc-

tions achievable are also substantial, however;

a single large

plant in Illinois will provide emission reductions

in excess

of

8,000 tons/year

(R.1376; Ex.62,

p.B—15; Ex.82).

The com-

bination of extended compliance dates,

internal offsets and

developing technology will insure that the emission reductions

are obtained in

a

manner economically feasible for industry.

One

major

fabric

coating

installation

was

identified

in

the

BAIl

Report

(Ex.65,

p.6—18)

and

the

Study

(Ex.62,

p.78).

Subsequent

data

identified additional sources

(Ex.82).

Com-

pliance eventually will be by water borne or low solvent coat-

ing;

add—on equipment may be required

in the interim.

Strict adherence to U.S. EPA RACT numbers for surface

coating of automobiles and light duty trucks would have re-

duced emissions at

a prohibitive cost.

The regulation as

adopted is tailored to the two automobile manufacturing plants

located in Illinois.

With some exception

(R.1406)

the affec-

ted companies have generally indicated that the regulation as

written represents acceptable,

obtainable limitations.

The

requirements

of

the

regulation

will

be

met

through

high

solids

topcoats, rather than water borne topcoats.

The Board has

concluded that retrofitting these existing plants to handle

water-borne topcoats

is not economically feasible; the

regulation as adopted, combined with the internal offsets

provision,

is

an economically reasonable method of obtaining

emission

reductions

from

these

automobile

plants.

35—272

---

—31—

Compliance

by

large

appliance

coaters

can

be

achieved

by

the

use

of

existing

coatings.

Some

plant

modifications

will

be

necessary

(Ex.65,

p.10—10).

The

BAli

Report

(Ex.65,

p.lO—17)

and the Study addendum

(P.C.75) estimated annualized costs for

all affected industry to total

$800,000.

The

BAli Report cal-

culated that a “direct cost pass—through” would increase the

price of

a $311 appliance by 15~(Ex.65,

p.10—17).

Rule

205(k)

prescribes

certain

operating

procedures

and

equipment requirements for solvent cleaning operations.

Equip-

ment retrofit cost estimates were formulated in both the

BAli

Report

and

the

Study;

differing

estimates

of

the

number

of

solvent

cleaners

(compare

Ex.62,

p.103

with

Ex.65,

p.11—19)

produced disparate totals.

Unit costs were fairly comparable.

Small emission sources do not provide

an

economically feasible

source

of

emission

reductions

and

are

exempted

see

Rule

205(k)

(1)

(A).

Testimony

at

hearing

indicated

that

there

are

several

related

production

and

labor

costs

that

were

not

included

in

the

estimates

of

compliance

costs

(R.1431-48,

1459—79).

Sub-

sequent comment

(P..C.86)

indicated these costs are not neglig-

ible.

Including costs of this nature does not alter the

Board’s

conclusion

that

these

controls

are

economically

reason-

able.

The nine coil coaters

in Illinois were described by the

Agency

as

currently

meeting

RACT

emission

limitations

(Ex.39).

This

led

both

the

Study

(Ex.62,

p.72)

and

the

BAli

Report

(Ex.65, pp.4-iD to 4—12)

to conclude that adoption of RACT for

these sources would have no economic impact; the Board agrees.

Surface

coaters

of

metal

furniture

are

expected

to

comply

by modifying existing equipment to handle high solids or water-

borne coatings

(Ex.65, p.8—li).

Advances

in coating technology

are

needed

in

some

areas,

for

example,

water

borne

coatings

for

dipping

(R.260,

P.C.100).

In

these

instances,

the

internal

offsets

provision

and/or

the

Board’s

variance

mechanism

may

be

essential

in

order

to

insure

that

no

unreasonable

economic

burden

is

placed

on

the

sources.

Both

the

BAli

Report

(Ex.65,

pp.8—12 to 8—17)

and the Study

(Ex.62,

pp.87—92) indicate

reasonable

costs for the use of high solids and water—borne

coatings.

The five identified surface coaters of magnet wire in-

sulation currently control emissions with afterburners and

incinerators.

The

BAli Report

(Ex.65, p.9—i) and the Study

(Ex.62,

p.92)

concluded that promulgation of the RACT emis-

sion

limitations

would

have

no

economic

impact

on

these

sources; the Board agrees.

The substitution of emulsified asphalt for cutback will

result

in

substantial

emission

reductions.

Total

statewide

35—273

---

—32—

costs for retrofit of equipment and retraining of employees

were estimated to total $229,000

(Ex.62, p.ill; Ex.65, p.17—13).

Neither the BAH Report

nor

the Study predicted any con-

tinuing annual costs.

However,

the Board notes

the testimony

of

some witnesses that increased application

rates are neces-

sary with emulsified asphalt

(R.1757,1767—8).

This may cause

some economic impact, but it should be offset in the future

since

the

price

of

emulsified

depends

less

on

the

higher

price

of

petroleum

distillates

than

does

cutback

(R.923).

Other

in-

cidental benefits include increased worker morale

(R.923), in-

creased worker safety

(R.92i) and considerable energy savings

(R. 919—20).

Although

impossible

to

quantify

for

all

surface

coaters,

the

economic

benefit

of

the

internal

offsets

must

be

considered

when analyzing the economic impact of the regulation.

Its

obvious impact will be to allow the most economically efficient

blend of emission reductions to be used.

It is of particular

importance to those coaters who must await advances in coat-

ing compound technology.

Similarly,

the Board’s variance mechanism must also be

considered, particularly when analyzing compliance dates

in

terms of

developing technology.

Although its

impact is im-

possible to quantify,

its effect is clearly to relieve unreas-

onable economic hardship.

Promulgation of these regulations should result in an im-

provement in human health.

The adverse health effects

of high

oxidant levels which will

he reduced are:

sore throat, short-

ness

of

breath,

cough,

headache,

hoarseness,

wheezing,

conges-

tion,

chest tightness, pain on deep inspiration,

and throat

tickle.

The major improvements will take place

in Lake, Cook

and Madison counties

in Illinois

(Ex.62, p.29—30) since the

largest

reductions

in

ozone

levels

will

occur

in

those

areas.

Based

on

IEPA

predictions,

the

second

highest

one—hour

ozone

reading

will

be

reduced

from

0.261

ppm

to

0.132

ppm

in

Lake

County

(Ex.62,

p.24).

Residents

of

neighboring

states,

such

as

Wisconsin,

should

also

show

improvements

in

health

due

to

lesser amounts of ozone transported into those states.

An

exact

quantification

of

the

improvement

in

health

is

not possible at this time due to the

limited amount of

infor—

mation on dose—response relationships at ozone

levels

less

than 0.20 ppm.

A Japanese epidemiology study and the environ-

mental chamber study by DeLucia and Adams indicate that ozone—

induced symptoms develop at levels of 0.15 ppm.

On the other

hand,

another epidemiology study carried out in Los Angeles by

Schoettlin and Landau found that 0.25 ppm was the level at

which asthmatics developed adverse health effects.

A limited

number

of

chamber

studies

seem

to

indicate

that

symptoms

and

pulmonary

decrements

develop

in

humans

at

ozone

levels

in

the

---

—33—

0.25

to

0.37

ppm

range

(Ex.62,

p.28—9).

However,

it

appears

that

individuals

who

live

in

high

ozone

areas,

such

as

Los

Angeles, may adapt to ozone

(R.1241).

Hence

it may be mis-

leading to try to quantify changes

in the health of Illinois

residents

based

on

studies

performed

on

Los

Angeles

residents.

Illinois residents may show adverse health effects at lower

concentrations of ozone than Los Angeles residents.

As with the health effects information,

a meager amount

of

information

exists

on

the

effects

of

ozone

on

Illinois

crops.

Since many other factors such as precipitation; tem-

perature; soil

fertility,

texture,

and drainage; and cultiva-

tion and planting methods can affect crop yield,

it

is diffi-

cult to predict what changes

in crop yield can be attributed

to ozone

(Ex.62,

pp.31-34).

However,

it appears that no in-

creased yields in corn,

soybeans, and possibly wheat will

result from changes in ozone

levels

(Ex.62,

p.35).

However,

it

should be noted that the most significant changes in ozone

levels will occur in metropolitan areas,

while most farming

occurs

in areas where ozone

levels already meet the NAAQS.

The

Study

also

attempted

to

produce

an

estimate

of

the

benefit

in

Illinois

attributable

to

the

implementation

of

RACT

I in terms

of decreased materials damage

(Ex.62, p.36-8;

Appendix E).

The authors of the Study calculated this annual

benefit

to

be

$16.4

million

which

was

described

by

the

authors

as “very uncertain”

(Ex.62, p.38)

and “a very rough estimate

at best”

(Ex.62, p.E—7).

All references to “An Act Concerning Administrative Rules”

in Rules 103(a)(2),

(b)(3),

(c),

(d),

(e)(2) and 104(b)(3) have

been deleted because the requirements

of the Illinois Adminis-

trative Procedure Act

(Ill.

Rev.

Stat.,

ch.127,

§1001 et

~

now apply automatically to all rulemaking by the Agency,

as well

as the Board.

Rule

103(1)

has

been

deleted

since

Section

39(a)

of

the

Act now states that a bond or other security shall not be

required

as

a

condition

for

the

issuance

of

a

permit.

The

Board

has

elected

to

retain

jurisdiction

in

this

pro-

ceeding for two reasons.

First,

specific portions

of the

Board’s

Final

Order

may

have

to

be

revised

in

order

to

obtain

Federal approval

of the Illinois implementation plan.

Second,

the Board’s intent in adopting these amendments may require

clarification.

The

record

in

the

proceeding

is

not

open

for

the

addition

of

any

new

evidence.

If

substantive

changes

in

the

Final

Order

are necessary for Federal approval and can be justified by the

record in its present form,

additional amendments may be made

without further hearings or economic impact analysis.

Any

change

in

the

Final

Order

will

require

compliance

with

the

35—275

---

—34—

provisions

of the Illinois Administrative Procedure Act

(Ill.

Rev.

Stat.

ch.l27,

§1001

et

,jJ.

Messrs.

Young and Werner dissent.

I, Christan

L. Moffett, Clerk of the Illinois Pollution

Control Boa,~,hereby cer ify th

above Opinion was adopted

on the

~23

day of

~~744~.k

,

1979 by a vote

Christan L. Moffett/,A4.~k

Illinois Pollution C&f*Iol Board

35—276