BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
    iN THE MATTER OF:
    )
    )
    AS
    03-4
    PETITION OF ARGONNE NATIONAL
    )
    (Air
    —
    Adjusted Standard)
    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 ofAir.
    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 defmed in Title
    35,
    Subtitle B,
    Section 211.1310 as “the process
    ofcleaning 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, equipmentrequirements, 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 ofa 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 of Section 218.182 (a) and
    (b) are geared to this type ofcleaning equipment.
    These include requirements regarding
    the d~greaser
    cover, spray apparatus, and drainage device.
    The material requirements
    contained in Section 218.182(c), effective in March 2001,
    limitthe 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 218.182(d)(2) requires that records of
    solventpurchases 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 otherpollutants on warm sunny
    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 asthmaor bronchitis.
    The Illinois EPA estimates that VOM
    emissions in the Chicago area are 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 ofsample 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 performunder
    certain “high tech” cleaning requirements.
    The cleaning ofelectronic 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
    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, such as 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 ofthe
    flammable nature of solvents such as acetone, which may be classified as a non-VOM but
    have other deleterious characteristics.
    Argonne estimates that its method ofcleaning and the use of solvents exceeding
    the vapor pressure limits would result in a maximum increase in VOM emissions ofone
    (1) ton per year.
    In the
    1999 inventory of Chicago 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 standardbe granted, subject to the conditions included in
    the Recommendation.

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