RECE~VED
ii~\I”’iFI1~-~\thiIIi
~,
CLERK’S OFFICE
ILLiNOIS
P4~113/A~4~A~RD
MAY
122004
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STATE
OF ILLINOIS
IN THE MATTER OF:
“1~
Pollution Control Board
)
CLEAN-UP PART III AMENDMENTS TO
)
R04-20
35
ILL. ADM. CODE PARTS 211, 218, AND
)
(Rulemaking
-
Air)
219
IN THE MATTER OF:
)
)
TECHNICAL CORRECTIONS TO
)
R04-12
FORMULAS
iN
35
ILL. ADM. CODE 214
)
(Rulemaking
-
Air)
“SULFUR LIMITATIONS”
)
(Consolidated)
HEARING EXHIBITS
First Hearing:
Chicago
March 18, 2004
Hearing Exhibit
1
Five Board orders that bear upon proposed amendments to equations:
(1) May
25,
1978,
in
R75-5,
R74-2;
(2) Dec. 14,
1978, in
R75-5,
R74-2; (3) Feb.
15,
1979, in
R75-5,
R74-2;
(4) Feb. 24,
1983, in R80-22; and
(5)
Apr. 20,
1995,
R94-31.
Second Hearing:
Springfield May
6.
2004
Hearing Exhibit 2
Illinois EPA’s “ERRATA Sheet,” showing proposed changes in underline/strikeout to the
rule language originally set forth in the R04-20 proposal.
(Fi’~f~)
ii (c~1
I
k\I
/A\
I
BEFORE
THE ILLINW
~
BOARD
MAY
122004
STATE OF ILLINOIS
IN
THE MATTER OF:
)
Pollution Control Board
)
CLEAN-UP PART
III
)
R04-20
AMENDMENTS
TO
35
ILL.
)
(Rulemaking
-
Air)
ADM. CODE PARTS 211, 218
AND
219
)
)
ERRATA SHEET
NOW COMES the Proponent, the ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY (“Illinois EPA”), by its attorney, Charles E. Matoesian, and submits this Errata
Sheet to
the Illinois Pollution Control Board (“Board”) in this matter to request the Board
to make modifications
to the original proposal.
Changes are marked with underlining and
strikeouts from the original proposal.
Part 218:
218.105(c)(2)(E):
The Illinois EPA proposes adding the language “using the
DQO/LCL alternativeprotocol and”
~)
Mass balance using DQO/LCL.
For a liquid/gas input
where an owner or operator is using the DQO/LCL
alternative protocol and not using an enclosure as described
in Method 204 of Appendix M of40 CFR Part
51,
the
VOM content ofthe liquid input (L) shall be determined
using Method 204A or 204F in Appendix M of40 CFR
Part
51.
The VOM content ofthe captured gas stream (G)
to the control device shall be determined using either
Method 204B
or204C in Appendix M of40 CFR Part
51.
The results ofcapture efficiency calculations (G/L) are to
be subjected to and shall satisfy the DQO or LCL statistical
analysis methodology as described in Section
3 of
USEPA’ s
Guidelinesfor Determining Capture Efficiency,
incorporated by reference at 218.112 of this Part.
Failure to
satisfy the DQO shall require capture efficiencyto
be
determined using one ofthe protocols described in
subsections (c)(2)(A), (B), (C), or (D)~gJ~p~1ye.
218.105(c)(2):
The Illinois EPA proposes striking the last sentence and
adding the
language “compliance demonstrations arising in enforcement matters,” to the new last
sentence.
E~X~Z
~
2)
Capture EfficiencyProtocols
The capture efficiency ofan emission unit shall be measured using
one ofthe protocols given below.
Appropriate test methods to be
utilized in each ofthe capture efficiency protocols are described in
Appendix M of40 CFR Part 51
incorporated by reference at
218.112. Any error margin associated with a test method or
protocol may not be incorporated into the results ofa capture
efficiency test.
Ifthese techniques
are not suitable for a particular
process, then an alternative capture efficiencyprotocol may be
used, pursuant to the provisions ofSection 218.108(b) of this Part.
Forpurposes ofdetermining capture efficiency using an alternative
protocol, sources shall satisfy the data quality objective (DQO) or
the lower confidence level (LCL) statistical analysis
methodologies as presented in USEPA’s “Guidelines for
Determining Capture Efficiency”
incorporated by reference at
Section 218.112 ofthis Part.
LCL can be usedto establish
compliance with capture efficiency requirements.
Forpurposes of
establishing emission credits for offsets, shutdowns, trading, and
compliance demonstrations arising in enforcement matters, the
DQO must be satisfied. In emorcement cases, LCL can not be used
to establish compliance.
Sufficient tests must be performed to
satisfy the DQO.
21 8.406(b)(1 )(A)(ii):
The Illinois EPA proposes to correct the formula to read,
“E,~,”
ii)
Calculations which demonstrate that total maximum
theoretical emissions ofVOM from all heatset web
offset lithographic printing lines at the source never
exceed 90.7 Mg (100 tons) per calendar year before
the application ofair pollution control equipment.
Total maximum theoretical emissions ofVOM for a
heatset web offset lithographic printing source is the
sum ofmaximum theoretical emissions ofVOM
from each heatset web offset lithographic printing
line
at the source.
The following equation shall be
used to
calculate total maximum theoretical
emissions ofVOM per calendar year in the absence
ofair pollution control equipment for each heatset
web offset lithographic printing line at the source:
~
=(RxAxB)+(CxD)+1095(FxGxH)
where:
=
Total maximum theoretical emissions of
VOM from one heatset web offset printing
line in units ofkg/yr (lb/yr);
A
=
Weight ofVOM per volume of solids ofink
with the highest VOM content as applied
each year on the printing line in units of
kg/i (lb/gal) ofsolids;
B
=
Total volume ofsolids for all inks that can
potentially be applied each year on the
printing line in units of 1/yr (gal/yr).
The
instrument or method by which the owner or
operator accurately measured or calculated
the volume ofeachink as applied and the
amount that can potentially be applied each
year on the printing line shall be described
in the certification to the Agency;
C
=
Weight ofVOM per volume of fountain
solution with the highest VOM content as
applied each yearon the printing line in
units ofkg/i (lb/gal);
D
=
The total volume offountain solution that
can potentially be used each year on the
printing line in units of1/yr (gal/yr).
The
instrument and/or method by which the
owner oroperator accurately measured or
calculated the volume ofeach fountain
solution used and the amount that can
potentially be used each year on the printing
line shallbe described in the certificationto
the Agency;
F
Weight ofVOM per volume ofmaterial for
the cleanup material or solvent with the
highest VOM content as used each year on
the printing line in units ofKg/l (lb/gal) of
such material;
G
=
The greatest volume ofcleanup material or
solvent used in any 8-hour period; and
H
=
The highest fraction ofcleanup material or
solvent which is not recycled or recovered
for offsite disposal during any 8-hour
period.
R
=
The multiplier representing the amount of
VOM not retainedin the substrate being
used.
For paper, R
=
0.8.
For foil, plastic,
or other impervious substrates, R
=
1.0.
218.411 (a)(1 )(B)(iii):
The Illinois EPAproposes to replace the word “retention” with
“emission adjustment”.
iii)
To determine VOM emissions from inks used on
lithographic printing line(s) at the source, an ink
emission adjustment factor of 0.05 shall be used in
calculating emissions from all non-heatset inks
except when using an impervious substrate, and a
factor of0.80 shall be used in calculating emissions
from all heatset inks to account for VOM retention
in the substrate except when using an impervious
substrate.
For impervious substrates such as metal
or plastic, no retention emission adjustment factor is
used.
The VOM content ofthe ink, as used, shall be
multiplied by this factor to determine the amount of
VOM emissions from the use ofink on the printing
line(s); and
Part 219:
219.105(c)(2)(E):
The Illinois EPA proposes adding the language “using the
DQO/LCL alternative protocol and”
~
Mass balance using DQO/LCL.
For a liquid/gas input
where an
owneror operator is using the DQO/LCL
alternative protocol and not using an enclosure as described
in Method 204 ofAppendix M of40 CFR Part
51,
the
VOM content of the liquid input (L) shall be determined
using Method 204A or 204F in Appendix M of40 CFR
Part 51. The VOM content ofthe captured gas stream (G)
to the control device shall be determined using either
Method 204B or 204C in Appendix M of40 CFR Part 51.
The results ofcapture efficiencycalculations (G/L) are to
be subjected to and shall satisfy the DQO or LCL statistical
analysis methodology as described in Section
3 of
USEPA’s
Guidelinesfor Determining Capture Efficiency,
incorporated by reference at 218.112 ofthis Part.
Failure to
satisfy the DQO shall require capture efficiency to be
determined using one ofthe protocols described in
subsections (c)(2)(A), (B), (C), or (D) above.
~
219.105(c)(2):
The Illinois
EPAproposes striking the last1~sentencefand
adding the
language “compliance
demonstrations arising in enforcement matters,” to the new last
sentence.
2)
Capture EfficiencyProtocols
The capture efficiency ofan emission unit shall be measured using
one ofthe protocols given below.
Appropriatetest methods to be
utilized in each ofthe capture efficiencyprotocols are described in
Appendix M of40 CFRPart 51
incorporated by reference at
218.112.
Any error margin associated with a test method or
protocol may not be incorporated into the results ofa capture
efficiencytest.
Ifthese techniques are not suitable for a particular
process, then an alternative capture efficiencyprotocol maybe
used, pursuant to the provisions ofSection
2 18.108(b) of this Part.
For purposes ofdetermining capture efficiency using an alternative
protocol, sources shall satisfy the data quality objective (DQO) or
the lower confidence
level (LCL) statistical
analysis
methodologies as presented in USEPA’s “Guidelines for
Determining Capture Efficiency” incorporated by reference at
Section 218.112 ofthis Part.
LCL can be used to establish
compliance with capture efficiencyrequirements.
Forpurposes of
establishing emission credits for offsets, shutdowns,
trading, and
compliance demonstrations arising in enforcement matters, the
DQO must be satisfied. In enforcement cases, LCL can not be used
to establish compliance.
Sufficient tests must be performed to
satisfy the DQO.
219.406(b)(1)(A)(ii):
The Illinois EPA proposes to correct the formula to read, “Er”
ii)
Calculations which demonstrate that total maximum
theoretical emissions of VOM from all heatset web
offset lithographic printing lines at the source never
exceed 90.7 Mg (100 tons) per calendar year before
the application ofairpollution control equipment.
Total maximum theoretical emissions ofVOM for a
heatset web offset lithographic printing source is the
sum ofmaximum theoretical emissions ofVOM
from each heatset web offset lithographic printing
line at the source.
The following equation shall be
used to calculate total maximum theoretical
emissions ofVOM per calendar year in the absence
ofair pollution control equipment for each heatset
web offset lithographic printing line at the source:
~Eu
(RxAxB)+(CxD)+1095(FxGxH)
where:
~1E~
=
Total maximum theoretical emissions of
VOM from one heatset web offset printing
line in units ofkg/yr
(lb/yr);
A
=
Weight ofVOM per volume ofsolids ofink
with the highest VOM content as applied
each year on the printing line in units of
kg/i (lb/gal) ofsolids;
B
=
Total volume ofsolids for all inks that can
potentially be applied each year on the
printing line in units of 1/yr (gal/yr).
The
instrument ormethod by which the owner or
operator accurately measured or calculated
the volume ofeach ink as applied and the
amount that can potentially be applied each
year on the printing line shall be described
in the certification to the Agency;
C
Weight ofVOM per volume offountain
solution with the highest VOM content as
applied each year on the printing line in
units ofkg/i (lb/gal);
D
=
The total volume offountain solution that
can potentially be used each year on the
printing line in
units of1/yr (gal/yr).
The
instrument and/or method by which the
owner or operator accurately measured or
calculated the volume ofeach fountain
solution used and the amount that can
potentially be used each year on the printing
line shall be described in the certification to
the Agency;
F
=
Weight ofVOM per volume ofmaterial for
the cleanup material or solvent with the
highest VOM content as used each year on
the printing line in units ofKg/l (lb/gal) of
such material;
G
=
The greatest volume ofcleanup material or
solvent used in any 8-hourperiod; and
H
=
The highest fraction ofcleanup material or
solvent which is not recycled or recovered
foroffsite disposal during any 8-hour
period.
R
=
The multiplier representing the amount of
VOM not retained in the substrate being
used.
For paper, R
=
0.8.
For foil, plastic,
or other impervious substrates, R
1.0.
219.411 (a)(1 )(B)(iii):
The Illinois
EPAproposes to replace theword “retention” with
“emission adjustment”.
iii)
To determine VOM emissions from inks used on
lithographic printing line(s) at the source, an ink
emission adjustment factor of0.05 shall be used in
calculating emissions
from all non-heatset inks
except whenusing an impervious substrate, and a
factor of0.80 shall be used in calculating emissions
from all heatset inks to account for VOM retention
in the substrate except when using an impervious
substrate.
For impervious substrates such as metal
or plastic, no retention emission adjustment factor is
used.
The VOM content ofthe ink, as used, shall be
multiplied by this factor to determine the amount of
VOM emissions
from the use of ink on the printing
line(s); and
