ILLINOIS POLLUTION CONTROL BOARD
    October 18,
    1979
    IN THE MATTER OF:
    )
    EMISSIONS OF VOLATILE
    )
    R78—3,4
    ORGANIC MATERIAL
    SUPPLEMENTARY OPINION AND ORDER OF THE BOARD
    (by Mr.
    Dumelle):
    On July 12,
    1979 the Board retained jurisdiction in
    this proceeding
    in case changes were needed to secure approval
    of the Illinois Implementation Plan or to clarify the Board’s
    intent in the Opinion adopted on August 23,
    1979.
    On August 1, 1979 Dow Chemical Company
    (Dow)
    asked the
    Board to reconsider its decision not to exempt 1,1,1-trichloro—
    ethane
    (methyl chloroform)
    or methylene chloride from the
    definition of volatile organic material. Dow asked for an
    additional hearing to discuss this issue. The Board’s decision
    is discussed at length on pages
    11-13
    of the Opinion.
    The
    Board sees no reason to reopen the record on this issue.
    On August
    7, 1979 the Agency asked the Board to include
    the definition of open top vapor degreasing contained on
    page 28 of the Board’s Proposed Order adopted on March 29,
    1979.
    The omission of this definition was inadvertent, and
    it shall
    be inserted in Rule 201.
    On October 2,
    1979 the Agency asked the Board to reconsider
    and clarify the explanation of Rule 205(n)(2)(A) on pages
    21
    and 22 of the Opinion.
    Rule 205 (n)(2)(A) provides for compliance with the
    applicable emission limitations through the use of afterburners.
    This rule requires that at least 75
    of the VOC emissions
    from a coating line be captured and oxidized by an afterburner
    that
    is at least
    90
    efficient in oxidizing VOC, measured as
    total combustible carbon,
    to carbon dioxide and water.
    It is
    necessary to require an overall
    level of control,
    as well
    as
    an afterburner efficiency requirement to ensure that emissions
    are captured and controlled.
    “If
    there
    is no capture
    requirement,
    then setting a requirement for oxidation in the
    afterburner may be meaningless because there would be no
    assurance that emissions would ever reach the afterburner to
    be oxidized.”
    (Public Comment 74)
    By requiring an overall
    efficiency of 75
    in the control
    system,
    a source
    is allowed
    flexibility to capture a greater or lesser amount of VOC
    emissions depending on the efficiency of the afterburner.
    For example,
    if source A’s afterburner is 90
    efficient,
    84
    35—5
    55
    —2—
    of that source’s emissions will need to be captured to
    achieve an overall
    75
    reduction;
    but
    if source B’s afterburner
    is 99
    efficient,
    source
    B will only need to capture 76
    of
    the VOC emissions.
    The Board believes that these capture
    efficiencies will
    he achievable by the compliance date
    because at least one plant is already capturing 73
    (Ex.17).
    The Board hereby adopts
    its Opinion dated August 23,
    1979 and this Supplementary Opinion as its Opinion in this
    proceeding.
    ORDER
    1.
    Dow Chemical Company’s motion for reconsideration or
    additional hearings
    is hereby denied.
    2.
    The Agency’s motion to reconsider and clarify the
    Board’s Opinion is hereby granted.
    3.
    The following definition is hereby added to Rule 201 of
    Chapter 2:
    Air Pollution:
    Open Top Vapor Degreasing:
    The batch process of
    cleaning and removing soils from surfaces by
    condensing hot solvent vapor on the colder metal
    parts.
    4.
    The Board’s decision to retain jurisdiction
    in this
    proceeding
    is hereby vacated.
    IT IS SO ORDERED.
    I, Christan L. Moffett,
    Clerk of the Illinois Pollution
    Control Board, hereby certify the a~~oveSupplementary Opinion
    ~~~~jere_adopted
    on the
    day
    Christan L. Moffe
    lerk
    Illinois Pollution
    ntrol Board
    35—556

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