IN THE MATTER OF:
    PETITION OFARGONNE NATIONAL
    LABORATORY FOR AN ADJUSTED
    STAN)ARD FROM
    35
    ILL. ADM. CODE 218.182
    TO:
    Dorothy Guim, Clerk
    Illinois Pollution Control Board
    James R.
    Thompson Center
    100 W. Randolph Street, Suite 11-500
    Chicago, Illinois 60601
    William D. Luck
    Assistant General Counsel
    Argonne National Labortory
    9700 5.
    Cass Avenue
    Argonne, Illinois 60439
    SEP
    042003.
    STATE OF
    ILL’rs401s
    AS
    03-04
    PO!/Utjofl Control Board
    (Adjusted Standard
    -
    Air)
    Bradley Halloran, Hearing Officer
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street, Suite 11-500
    Chicago, Illinois 60601
    Gloria Walach, Counsel
    U.S. Department ofEnergy.
    9800 5.
    Cass Avenue
    Argonne, Illinois 60439
    PLEASE
    TAKE NOTICE that I have today filed with the Office ofthe Pollution
    Control Board the TESTIMONY OF MICHAEL D. ROGERS ofthe Illinois Environmental
    Protection Agency, a copy ofwhich is herewith served upon you.
    Date:
    September 2, 2003
    1021 North Grand Avenue East
    P.O.
    Box
    19276
    Spring field, IL 62794-9276
    217/782-5544
    •
    ILLINOIS ENVIRONMENTAL
    PROTECTION AGENCY
    By:
    Rachel L.
    octors
    Assistant Counsel
    Division ofLegal Counsel
    THIS FILING IS SUBMITTED ON
    RECYCLED PAPER
    BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
    R~cs
    Qr’i~r,-~
    )
    )
    )
    )
    )
    )
    NOTICE
    BEFORE THE
    ILLINOIS POLLUTION CONTROL
    BOARD
    CLERK’S OFF~~’p
    SEP
    0
    4
    2003
    INTHE MATTER OF:
    )
    )
    AS 03-4
    STATE OF
    ILLINOIS
    PETITION OF ARGONNE NATIONAL
    )
    (Air
    —
    Adjusted
    Standâ~fd~t10fl
    Control Board
    LABORATORIES FOR AN ADJUSTED
    )
    STANDARD FROM
    )
    35
    ILL. ADM~
    CODE 218.182
    )
    Testimony ofMichael D. Rogers
    Illinois Environmental Protection Agency
    September 2003
    Good morning.
    My name is Mike Rogers and I am in the Illinois Environmental
    Protection Agency’s Bureau of Air.
    I was involved in the development ofthe regulation
    establishing the maximum vapor pressure limits for solvents used in cold cleaning and in
    conversations with Argonne concerning this adjusted standard petition.
    Cold cleaning is defined in Title
    35,
    Subtitle B, Section 211.1310 as “the process
    of cleaning and removing soils
    from surfaces by spraying, brushing, flushing, or
    -
    immersion while maintaining the organic solvent below its boiling point.
    Wipe cleaning
    is not included in this definition.”
    Section 218.182 contains requirements for operating
    procedures, equipment requirements, material requirements, and recordkeeping
    requirements.
    Cold
    cleaning is primarily conducted to clean metal parts.
    Such cleaning likely
    takes place at all manufacturing operations, as well as at auto repair facilities, machine
    shops and metal fabrication and finishing operations.
    Cold cleaning degreasers range in
    size but typically consist of a small sink or vat where components are sprayed and
    brushed clean,
    connecting hoses, and a holding tank containing from five to 30 gallons of
    solvent. The solvent is usually used at ambient temperatures, but if it is heated, the
    temperature is.kept below the solvent’s boiling point.
    Solvent degreasing equipment and
    degreasing solvents are typically supplied by the same companies.
    The operating procedures and equipment requirements ofSection 218.182
    (a) and
    (b) are geared to this type ofcleaning equipment.
    These include requirements regarding
    the degreaser cover, spray apparatus, and drainage device.
    The material requirements
    contained in Section 2 18.182(c), effective in March 2001, limit the sale or use ofsolvents
    in cold cleaning to those with a maximum vapor pressure of 1.0 millimeter ofmercury
    (mm Hg), measured at 20°C (68°F).
    Section 218.1 82(d)(2) requires that records of
    solvent purchases be maintained in order to verify the purchase ofcompliant
    solvents.
    All of these requirements
    are intended to reduce the evaporation ofthe solvent
    being used.
    The evaporation ofhydrocarbon-based solvents releases volatile organic
    material (VOM) into the atmosphere.
    The higher the vapor pressure ofa substance the
    more readily it evaporates.
    These emissions react with other pollutants on warm sfinny
    days to produce ozone.
    Elevated ozone concentrations in the lower atmosphere can
    impair breathing function especially in the young, the elderly,
    and those with existing
    respiratory diseases such as asthma or bronchitis.
    The Illinois EPA estimates that VOM
    emissions in the Chicago areaare being reduced by approximately 22 tons per day from
    1998 levels due to the implementation ofthe regulation.
    Although technically cold cleaning, the research and development testing and
    analysis activities performed by Argonne are not the typical activities intended to
    be
    affected by the cold cleaning regulations.
    Argonne has requested relief for its
    operations
    that involve preparation of sample material and the associated apparatus used for research
    and development testing and analysis stating that such testing “requires sample surface
    areas completely free ofresidual contamination.”
    The Agency has been made.aware that
    solvents complying with the vapor pressure limits may not adequately perform under
    certain “high tech” cleaning requirements.
    The cleaning of electronic components is one
    example that was brought to light during the rulemaking development and accordingly
    addressed in the regulation.
    The Agency acknowledges that Argonne’s specified
    activities and cleanliness requirements are unique from typical cold cleaning operations.
    In addition, Argonne’s activity does not utilize the typical cold cleaning apparatus
    c
    described above, using milliliters of solvent rather than gallons, and laboratory beakers
    rather than a sink.
    Argonne states that it has researched the use of alternative solvents either
    complying with the specified vapor pressure limits or consisting ofnon-volatile organic
    material, suchas acetone,
    but that no suitable complying solvent could be found.
    The
    Agency is aware that cleaning solvents have their limitations especially in circumstances
    that require such a high degree ofcleanliness.
    The Agency is also aware of the
    flammable nature ofsolvents such as acetone, which may be classified as a non-VOM but
    have other deleterious characteristics.
    Argonne estimates that its method of cleaning and the use ofsolvents exceeding
    the vapor pressure limits would result in a maximum increase
    in VOM emissions ofone
    (1) ton per year.
    In the 1999
    inventory ofChicago nonattainment area ozone precursor
    emissions the Illinois EPA estimates that approximately 660 tons ofman-made VOM
    emissions are generated each summer day in the six-county region.
    Therefore, the
    Illinois EPA believes that the additional emissions resulting from Argonne’s research and
    development testing and analysis activities and requested use ofsolvents exceeding the
    vapor pressure limits is negligible and will not negatively affect Chicago area air quality.
    Based on the above, I support the Agency’s recommendation to the Board that
    Argonne’s Petition for adjusted standard be granted, subject to the conditions included in
    the Recommendation.
    STATE OF ILLINOIS
    COUNTY OF SANGAMON
    )
    )SS.
    )
    PROOF OF SERVICE
    I, the undersigned, on oath state that I have served the attached Testimony ofMichael D.
    Rogers upon the person to
    whom it is
    directed, by placing it in an envelope
    addressed to:
    TO:
    Dorothy Gunn, Clerk
    Illinois Pollution Control Board
    James R. Thompson Center
    100 W. Randolph Street, Suite 11-500
    Chicago, Illinois
    60601
    William D. Luck
    Assistant General Counsel
    Argonne National Labortory
    9700 5.
    Cass Avenue
    Argonne, Illinois 60439
    Bradley Halloran, Hearing Officer
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street, Suite 11-500
    Chicago, Illinois 60661
    Gloria Walach, Counsel
    U.S. Department ofEnergy
    9800 S. Cass Avenue
    Argonne, Illinois 60439
    and mailing it by First Class Mail from Springfield, Illinois on September 2, 2003, with
    sufficient postage affixed.
    SUBSCRIBED AND SWORN TO BEFORE ME
    this
    2uid
    day ofSeptember, 2003
    Notary Public
    SEAL
    -
    ~.
    NOTARy
    PUBLIC
    STATE
    OF
    ILLINOIS
    COMMISSION
    EXPIRES
    I ~-I4-2OQ5?

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