BEFORE THE
JAN
311995
ILLINOIS POLLUTION CONTROL BOARD
ST~~TE
O~
ILUNOIS
pOLLUTION CONTROL BO~J
—
IN THE MATTER OF:
15
ROP PLAN CONTROL MEASURES FOR VOM
)
R 94-33
EMISSIONS
-
PART VII:
BATCH OPERATIONS;)
(Rulemaking)
AIVIENDMENTS TO 35
IL. ADM.
CODE PARTS
211,
218
AND
219.
NOTICE
TO:
Dorothy Gunn,
Clerk
Audrey Lozuk-Lawless
Illinois Pollution Control
Illinois Pollution Control
Board
Board
State of Illinois Center
State of Illinois Center
100 W. Randolph
100 W. Randolph
Suite 11-500
Suite 11-500
Chicago,
Illinois 60601
Chicago, Illinois
60601
PLEASE TAKE NOTICE that
I have today filed with the Clerk of
the Illinois Pollution Control Board an original and nine copies
of the Comments of Stepan Company, copies of which are herewith
served upon you.
By
______
Patr cia
.‘
ha key
Dated:
January 30,
1995
Patricia F.
Sharkey
MAYER,
BROWN & PLATT
190 South LaSalle Street
Chicago,
IL
60603
312/782-0600
THIS
FILING
SUBMITTED
ON
RECYCLED
PAPER
ILLINOIS POLLUTION CONTROL BOARD
/~~E~VEtrj
JAN
311995
IN
THE
MATTER
OF:
)
STATE OF
ILLINOIS
POLLUTION
CONTROL
BOARD
15
ROP PLAN CONTROL MEASURES FOR VOM
)
R 94-33
EMISSIONS
-
PART VII:
BATCH OPERATIONS;)
(Rulemaking)
AMENDMENTS TO 35
IL. ADM.
CODE PARTS
211,
218
AND
219.
COMMENTS OF STEPAN COMPANY
Stepan Company
(“Stepan”)
owns and operates a manufacturing
facility located in Elwood,
Illinois which includes among its
processes a number of “batch process operations”
as defined in
the proposed rule in this matter.
As an owner and operator of a
number of complex batch process operations,
Stepan has had
extensive experience in both running batch processes and in
addressing the unique regulatory compliance issues associated
with batch processes.
Stepan’s efforts
to address batch
processes under the “generic rule approach” go back to the
Board’s initial “generic rule,” R 86-14,
and have continued
through the Federal Implementation Plan
(I~FIPIT)
“generic rule”
and currently pending state and federal site-specific RACT
proceedings.
As will be discussed later in these comments,
Stepan believes that this rulemaking will provide a more
reasonable regulatory approach for its batch processes than the
“generic rule approach,”
and,
thus,
allow Stepan to withdraw its
site-specific petitions.
Stepan was an active participant
in the hearing on January
4,
1994
(See Transcript,
pp.
19 to 43)
and, both prior to and
subsequent to the hearing, provided the Illinois Environmental
Protection Agency
(“Agency”) with comments on the proposed rule
and suggestions designed to clarify and improve the rule.
In response to Stepan’s comments and those of other affected
parties,
including the Illinois Environment Regulatory Group
(“IERG”),
the Agency has agreed to a number of interpretations
of
and revisions
to the proposed regulatory language which in
Stepan’s opinion will make this rule a workable regulatory
approach.
Stepan attempted to clarify interpretational issues
with the Agency in the hearing.
The agreed upon revisions to the
language of the proposal have been filed with the Agency’s
comments and are also attached hereto.
(Attachment A.)
Stepan’s
comments herein are offered in support of this revised language
and as an explanation of the concerns some of those revisions are
designed to address.
I.
APPLICABILITY TO STEPAN
Section
5oo~/
states that the proposed rule will apply to
batch operations at sources with the four-digit standard
industrial classification
(“SIC”)
codes.
Stepan has certain
batch operations,
e.g.
Stepan’s surfactants,
which do not fall
within the specified SIC codes but which are chemically and
operationally similar to those which do.
Therefore, the Agency
has agreed that regardless of SIC codes the rule should apply to
all of Stepan’s batch operations except as otherwise stated in
~/
For brevity’s sake,
Stepan will use only the three digit
section number for sections which may be proposed for either
Part 218 or 219.
-2-
Section 500 (b)
.
This is reflected in the First Notice proposal
in Section 500(a) (2).
II.
CONTROL
DEVICES
v.s.
PROCESS
OR RECOVERY DEVICES
Although several provisions
in the proposed rule reference
the use of condensers and other devices
as control devices,
the
Agency,
in response to questions in the hearing, made it clear
that in many instances these devices are not control devices but
rather process or recovery devices.
(Transcript pp.
23-25.)
For
example,
a condenser may be used primarily as a recovery device
or may function as an integral part of the process,
such as a
reflux condenser or a steam vacuum system.
The significance of
this point
is that when a device is functioning as a “control
device,” as opposed to a process or recovery device,
emissions
must be measured before the device.
When a device is used for
product recovery or is otherwise functioning as an integral part
of the process, emissions are appropriately measured at the
outlet of the condenser.
In Stepan’s experience,
ambiguity as to
where “uncontrolled total emissions” are to be measured can
result in significant disagreements in the permitting process.
Thus,
the Agency’s clarification on this point is very helpful.
The Agency’s testimony makes it clear that where emissions are
measured will be based on how an owner or operator chooses to
design and operate the device in a given chemical process.
(Transcript pp.
24-25.)
-3-
A.
Condensers
The Agency’s discussion of the principle of operation and
applicability of condensers in Section 3.1 of the Agency’s
November 1994
“Technical Support Document for Batch Processes”,
AQPSTR 94-10,
(“Agency TSD”)
further support this point.
(See
Agency TSD,
pp.
18-20.)
In that section, the Agency notes
“condensers servicing reactors and distillation columns often
function in refluxing material.
This refluxing
is an integral
part of the process,
and therefore these condensers are often not
considered to be emission control devices.”
(Id.
p.
18)
The
Agency also notes “shell and tube condensers are usually employed
as refluxing devices on batch distillation units.”
(Id.
p.
19)
In a Technical Support Document USEPA developed specifically
for Stepan’s batch processes,
“Stepan Company Millsdale Plant,
Elwood,
Illinois, Non-CTG RACT Evaluation Technical Support
Document,” March 1992
(“Stepan TSD”), USEPA discusses the concept
that a device may be “integral”
to an operation in the sense that
it contributes
to the efficiency of the operation.
(Attachment B
hereto.)
An example of a device which is necessary to efficient
operation is a condenser which condenses alcohol and which,
although not technically necessary to operate the process,
nonetheless is necessary for the operation to be run efficiently
and economically.
The recovery of material
is an integral step
in the overall operations.
This could even include material
recovered from one process which is then used in a different
process.
In some cases, the material recovered from the recovery
-4-
device may be further processed,
even off-site,
and then returned
to be used in the same or another process.
Whenever recovered
material
is used beneficially it contributes to the efficiency
and economy of the operation and reduces waste and redundancy.
Therefore,
recovery devices should generally be treated as
process devices rather than control devices, even though they do
help reduce emissions.
B.
Other Devices
Several of Stepan’s batch processes also include other
systems which function as an integral part of the process,
but
also provide some control.
For example, the primary function of vacuum systems and
eductor systems at the Milisdale facility is to allow
manufacturing and processing of Stepan’s products without
detrimentally affecting product quality.
For example,
in
Stepan’s Esters processes,
some products generate alcohols as by-
products which must be removed.
In certain processes, the alcohol is removed by vacuum
stripping,
e.g.
in Stepan’s Methyl Esters Esterifier.
In another
process,
the crude esters are purified by vacuum distillation.
If the stripping were carried out at atmospheric pressure,
the
temperature required to remove the alcohol efficiently would
degrade the product.
Therefore,
a vacuum eductor system is
necessary to reduce the pressure inside Esters reactors so that
the stripping operation can proceed at a temperature which
ensures product quality is not jeopardized.
Clearly, without the
-5-
vacuum producing equipment,
the process could not operate.
It
should be clear that
in this instance the vacuum eductor system
is part of the process and not a pollution control device.
The same degradation would occur with the product if the
distillation process were carried out at atmospheric pressure.
In that case,
a three stage vacuum system is necessary to operate
the process and ensure product quality.
It should be clear,
again,
that this vacuum system is an integral part of the
process, and not a pollution control device.
III.
BATCH PROCESS TRAIN DETERMINATIONS
The proposed rule provides that both the emissions from a
“single unit operation” and the aggregated emissions from all
“single unit operations”
functioning as a part of a “batch
process train” must meet the stated “de minimis”
levels or be
subject to the control requirements of Section 501.
(See Section
500 (c) and
(d))
.
The Agency’ s TSD neither discusses the concept
of a “batch process train” nor provides guidance on the
aggregating of emissions for de minimis determinations and
control purposes.
While USEPA’s model batch process rule
contained in its “Control of Volatile Organic Compound Emissions
from Batch Processes”
(“CTG”)
(Nov.
1993,
Doc.
EPA-453/R-93-0l7)
defines “batch process train” very broadly,
it also provides
little guidance on applying this concept.
(See Appendix G to the
CTG.)
In fact,
many questions about aggregating emissions from a
“batch process train” arise when one tries
to apply this rule to
a sophisticated chemical manufacturing plant where a number of
-6-
products may be produced from a given feed stock using
overlapping configurations of equipment designed to maximize
efficiency.
The fundamental question is which “single unit
operations” are to be included in which “batch process train”?
Other related questions are:
Where does a “batch process train”
begin and end?
How does one account for a “single unit
operation”
that functions as a part of more than one “batch
process train”?
How can one actually aggregate for control
purposes emissions from chemically incompatible product lines?
These concerns drove Stepan and IERG to work with the Agency
to develop a definition of “batch process train” which to the
extent possible would delineate the key characteristics of a
“batch process train.”
That definition was included in the First
Notice Proposal.
Notwithstanding this new definition,
it
is
still difficult to determine what to include in a “batch process
train” for a complex chemical process,
such as Stepan’s
hydrotropes process.
A.
Multi-Train
Units
The Agency’s testimony in response to Stepan’s hydrotropes
process example
is instructive on several otherwise confusing
aspects of the “batch process train” concept.
(See Transcript
pp.
25-31 and Exhibit
3.)
Stepan’s hydrotropes process involves
four reactors,
each of which independently feed xylene sulfonic
acid to either an ammonia neutralizer or a sodium neutralizer.
Two distinct and incompatible products are produced.
In the
hearing, the Agency noted that in this case each reactor is a
-7-
part of two distinct “batch process trains” and each neutralizer
is a part of four distinct “batch process trains.”
Thus,
eight
“batch process trains” utilize these six “single unit
operations.”
(Transcript pp.
25-29.)
Based on this guidance,
it
is clear that a “single unit operation” can indeed participate in
more than one “batch process train.”
The Agency also testified
that the volume of emissions attributable to each “batch process
train” from such a unit should be only those generated during
“batch cycles” running through that particular “batch process
train”.
(Transcript pp.
29-31.)
Thus,
for aggregation purposes,
the emissions from a “multi-train” unit,
should be distributed
over the “batch process trains” involved.
B.
Product Produced
It
is important to note from this example, that while a
“batch process train” can be identified based on the product
produced,
not all units that make the same products are a part of
the same “batch process train”.
This
is clearest in the
situation where a plant has two distinct but parallel process
lines producing the same product.
These are clearly separate
“batch process trains,” not based on the end product, but because
they each operate independently of one another.
In order for the
aggregation regulatory approach to make sense,
a “train” must be
composed of units which are linked or dependent operations
from
which emissions can,
in fact,
be aggregated for control purposes.
-8-
C.
Dependent/Independent Operation
In response to a question in the hearing, the Agency
concurred that the independence of one “batch process train” from
other “batch process trains” or other “single unit operations”
is
fundamental to defining the “batch process train.”
The Agency
stated that if a “batch process train”
is operated independently
of another “batch process train,”
it is considered a separate
“batch process train”.
(Transcript pp.
29-30.)
This should be
true even though both trains may use some of the same individual
units and even though they may produce the same product.2/
D.
Geographic Proximity
Stepan notes that geographic proximity of units is obviously
a key consideration for determining whether emissions can be
aggregated for control purposes.
However,
it must be emphasized
that independent “batch process trains” even if they
simultaneously produce the same products and even if they are
located in the same geographical area,
are still separate and
distinct
“batch process trains”.
Although geographical proximity
is a key consideration for controlling emissions,
the units which
are included in a “batch process train” must,
in the first
instance, must be based on whether the units are independent or
interdependent.
~/
As the Agency noted in the record, any concern that one is
not accounting for all of the emissions that a single
“multi-train” unit is producing is taken care of by the
provision that each “single unit operation”
must itself also
either meet ~
minimis levels or be controlled.
(Transcript
pp.
30-31.)
-9-
E.
Compatibility
Another fundamental consideration must be the compatibility
of the materials being processed.
For example, Stepan’s blended
detergent area
(M Building)
has seven batch neutralizers of
different sizes capable of manufacturing the same or different
products.
Because each neutralizer may be processing different,
incompatible materials during any particular day,
separate vents
must be provided and those vent streams cannot be combined
without causing an adverse chemical reaction.
It should be noted
that each of these neutralizers also has a separate feed and
storage system which enables
it to operate independently of the
others.
At the Millsdale facility,
the type of chemical being
processed in a batch vessel may change from day to day.
Stepan
has several batch blenders or reactors in one building that are
capable of processing several products, but from batch to batch
and at any given time,
the contents of the vessels can be
different and incompatible.
If manifolded together,
this could
result in an adverse chemical reaction and/or product cross
contamination.
Also,
a reactor that provides the feed to a
blender one day may be producing an
incompatible feed for
another blender the next day,
and the tying together of the
reactor to the blender through a common vent manifold could
result in product contamination due to chemical residues.
-
10
-
F.
Can Emissions Be Vented Through A Coimnon Control Device?
It
is our understanding that the concept
of aggregating
emissions was included in the proposed rule on the assumption
that the “single unit operation” vents can be reasonably
manifolded together to feed a common pollution control device.
However, unless reasonably applied,
such manifolding may result
in adverse chemical reactions, product contamination,
and
unreasonable expense
(i.e.
to connect geographically distant
vents.)
The practical ability to physically aggregate and
control emissions must be considered a fundamental limitation on
any abstract requirement to aggregate.
G.
Continuous Process Units
In some instances at Milisdale,
several batch neutralizers
are fed by a continuous sulfonator.
Since a batch process
differs from a continuous process
in its operating
characteristics
(for example,
a batch vessel may be going through
a cleaning or maintenance cycle while the continuous process is
operating)
and continuous operations are covered under other
regulations,
the owner or operator of a “batch process train”
generally should not aggregate emissions from continuous units
with batch units.
Given the complexity of this issue and the lack of Agency or
USEPA written guidance on this point, Stepan requests that the
Board make it clear in its Opinion and Order that in aggregating
emissions from a process train,
owners and operators
(and Agency
permit writers) should consider the following factors:
1)
Is the
-
11
-
unit used in more than one train?
ii) Are the units
interdependent?
iii) Are the materials used chemically
compatible?
iv) Are the units geographically close and
accessible?
v)
Are the units operated as a process train
throughout the year?
vi) Are any continuous units involved?
and vii)
Can emissions be vented to a common control device?
IV.
USE OF TOTAL PRODUCTION DATA TO DETERMINE COMPLIANCE
As originally proposed by the Agency,
Section 502 (a) (2)
provides that uncontrolled total annual emissions can be
calculated based upon engineering estimates of uncontrolled VOM
emissions p~ batch cycle multiplied by the number of batch
cycles per year.
Stepan pointed out that this “batch cycle
approach” will work only for batch units or trains that have
uniform batch cycles.
(See Transcript pp.
31-33.)
In many of
Stepan’s batch operations,
the volume and duration of different
batch cycles vary, and the VOM emissions generated during each
batch cycle varies depending on the duration,
type and volume of
the product being produced,
as well as the conditions under which
it
is produced,
e.g.,
temperature and pressure.
Since the
pertinent parameters of Stepan’s batch cycles vary,
simply using
the number of batch cycles would yield an inaccurate emissions
estimate for Stepan.
The simplest example is batch cycles of
varying volumes.
Two 5,000
lb. batches may emit as much VOM as a
single 10,000 lb. batch.
Similarly,
two six hour batches may
emit as much as a single twelve hour batch.
-
12
-
A second problem for Stepan with the “batch cycle approach”
to estimating total emissions is the fact that Stepan does not
compile batch cycle data on an annual,
or even monthly basis, and
is not permitted on a batch cycle basis.
The variability in
Stepan’s batches make the information pertaining to individual
batches less useful than the overall production numbers,
and,
therefore,
Stepan’s documentation and permits are based on pounds
per hour and hours of operation which equate to total annual
production.
After considering Stepan’s comments on this point,
the Agency has agreed that,
as long as total production is
reflected in the data on which
a valid Agency permit
is based,
this approach is a workable alternative.
(Transcript
p.
32.)
The Board will note that the agreed upon revised language
does not delete the per batch cycle approach, but simply adds the
total production approach as an alternative both in Section 502
(emission determinations)
and Section 505
(reporting and
recordkeeping)
V.
ALTERNATIVE TEST PROCEDURES FOR
BATCH CYCLES OF GREATER
THAN
8
HOURS
A.
The Issue Posed
By Long Batch Cycles
As originally proposed,
Section 503 (f) provided that
emission testing using Method 25A or Method 18 when requested by
the Agency to demonstrate compliance would have to be performed
over the entire length of the batch cycle.
Stepan and IERG
pointed out that some batch operations may run as long as 18-36
hours.
The difficulty and expense involved in testing for the
full length of these very long batch cycles
is not justified if
-
13
-
the representative emission events within the batch cycle
(e.g.,
charging,
venting or vacuum distillation)
can be characterized
and measured by shorter tests.
The Agency and Stepan together discussed this matter with
Randy MacDonald of the United States Environmental Protection
Agency’s
(“USEPA”) Research Triangle Park.
Mr. MacDonald
is the
USEPA regulatory development engineer who was principally
responsible for the USEPA documents which form one of the basis
of this rulemaking,
the CTG and Alternative Control Techniques
Document
(“ACT”)
(Feb.
1994)
.
Mr. MacDonald is also currently
working on USEPA’s MACT standards for batch processes.
Mr.
MacDonald admitted that USEPA had not adequately addressed this
issue when it developed its model rule in the CTG.
(See CTG,
Appendix G.)
He agreed that
it was reasonable to test for less
than the full duration of a batch cycle of greater than
8 hours
as discussed in the CTG document itself.
(See CTG,
Section 7.3,
p.
7-10.)
In discussions with Randy MacDonald and the Agency,
the
variety and the variability of the emission events in a typical
batch process of the CTG were discussed.
Included in the
discussion was the reference to the high cost of sampling a batch
process as compared to
a continuous process and the need to take
periodic samples.
(See CTG,
p.
7-10.)
Mr. MacDonald and the
Agency indicated agreement that sampling a batch process is
considerably more expensive than sampling an equivalent
continuous process that emits the same annual amount of VOM and,
-
14
-
that the potential reduction in emissions that may be gained from
actual sampling is considerably less as well.
Mr. MacDonald
repeatedly emphasized that actual emission testing is not
routinely required under the CTG.
Rather,
engineering estimates
should form the basis of the owner’s or operator’s compliance
demonstration,
and be supplemented by testing only as necessary.
However,
testing remains
an issue because it may be necessary to
resolve disputes between the owner or operator and the permit
writer and to define unusual or unpredictable emission events.
B.
The Proposed Sampling Strateqy
To develop a reasonable approach to quantifying emissions
from a batch process,
such as a vacuum batch reactor,
it must be
understood that a typical batch process will go through a number
of discrete process steps,
although not every step generates or
vents emissions.
A typical process would be:
1)
Charging Raw Materials
2)
Heat up
3)
Reaction
4)
Apply vacuum
(evacuation)
5)
Vacuum distillation/stripping
6)
Cool down
7)
Pump out
8)
Clean up
During the initial process of developing a sampling strategy
for these longer emission events,
an engineering estimate of the
emissions from each emission event has to be made in order to
define the emission events that contribute the major amount of
the total emissions.
In many cases,
90
of the total emissions
will be obtained from one or two emission events in the batch
cycle.
The emissions from the batch process are then determined
-
15
-
by sampling the emissions from the significant emission events of
the cycle and then adding the engineering estimate of the
emissions from the least significant emission events of the
cycle.
The emissions from each emission event,
including the
engineering estimates,
are summed to determine the total
emissions per batch and finally the total emissions per batch is
divided by the total batch cycle to determine the average
emission rate for the process.
For emission events of
4 hours or less that are not
accurately represented by a constant emission rate
(for example,
vacuum stripping that utilizes an ever increasing vacuum to strip
off the volatile emissions),
it may be necessary to sample over
the entire period of the emission event in order to quantify the
emissions.
However,
for batch cycles of greater than 8 hours and
emission events of greater than
4 hours,
while the variability in
emissions
is likely to be the same as for shorter events,
the
emission event takes place over a longer period of time.
Therefore,
Stepan,
IERG,
and the Agency have agreed that
emissions from these long events can be accurately quantified
based on three one hour samples taken during the emission event.
C.
The Revised Proposed Language
To address the issue of testing these long batch cycles,
Stepan,
IERG and the Agency have developed revised language for
Section 503 (f)
(3) (A)
.
Section 503 (f) (3) (A) (i) provides for
continuous testing throughout the entire batch cycle for cycles
of less than
8 hours.
For cycles of
8 hours or more,
Section
-
16
-
503(f) (3) (A) (ii) provides for testing “only during those periods
of the emission event which define the emission profile of the
emission event.”
For these long batch cycles,
the owner or
operator must test continuously over every emission event
of less
than 4 hours.
But,
for emission events of greater than 4 hours,
the owner or operator has the option of either testing
continuously or performing three one hour tests.
To test
anything less than continuously,
the owner or operator must
provide a demonstration that the periods tested are those which
“define the emission profile for the emission event.”
Stepan believes this provision sets a very rigorous standard
for testing, when testing is required,
but at the same time will
be less onerous than continuous testing for long batch cycles or
developing a separate protocol for every stack test.
D.
Maximum Intervals In Testing
On a related point,
Stepan pointed out and the Agency agreed
at the hearing that the maximum 15 minute interval in the
continuous testing requirement was unworkable over batch cycles
where Method 18 must be used.
(Transcript pp.
36-37.)
Method 18
involves the use of an impinger containing absorbent material
which must be
“changed out” manually when it becomes saturated.
In Stepan’s experience,
the process of “changing out” the
impinger can require at least 30 minutes.
Mr. MacDonald of USEPA and the Agency have agreed that an
interval of
30 minutes in this situation will not adversely
affect the accuracy of the testing.
(See Transcript p.
37.)
-
17
-
Section 503(f) (3)
(A) (1)
of the revised proposal contains revised
language reflecting this agreement.
E.
“Emission Event” Definition
In order to address the above-referenced testing issues,
Stepan,
IERG and the Agency agreed it was necessary to define the
term “emission event.”
The agreed upon definition which appears
in Section 503(f) (3) (A) (iii)
of the revised proposal, was largely
taken from the definition of “emission event” provided in the
Batch Process CTG.
(See CTG,
Sec.
7.1,
p.
7-3.)
One significant
difference,
however,
is the last sentence of the revised proposed
subsection which is designed to address periods of zero flow.
Consistent with the CTG definition which defines an “emission
event”
as a “discrete venting episode,”
this language simply
clarifies the fact that zero flow periods do not involve venting
and,
thus,
are not “emissions events.”
VI.
CALENDAR
YEAR
As a point of clarification,
Stepan asked the Agency at the
hearing whether determinations of “uncontrolled total annul mass
emissions” and associated reporting and recordkeeping under this
rule were intended to be based on a calendar year or a rolling
12-month period.
Stepan notes,
for the record, that the Agency
unequivocally stated that the Agency intends that a calendar year
be used for all purposes under this rule.
(Transcript pp.
38-
39.)
Stepan requests that the Board make this point clear in its
Opinion and Order.
-
18
-
VII.
EFFECTIVE DATE
The Agency noted that although the compliance date for this
rule
is March 1996,
it is the Agency’s intent that this rule be
effective when the final rule is published in the Illinois
Register.
Stepan supports this position and urges the Board to make
these regulations effective upon publications.
VIII.
EFFECT OF
THIS RULE ON STEPAN’S
SITE SPECIFIC RULEMAKING DOCKETS
Stepan’s unique position was first brought to the Board’s
attention in R86-18,
the Board’s initial “generic rule”
proceeding.
In that proceeding, Stepan provided testimony as to
the unreasonable impact of the generic rule on its processes,
including its batch processes.
However, because the full
ramification of the rule did not become apparent until the
economic impact stage and the Board preferred not to address the
merits of the issue at that stage,
the Board recommended that
Stepan seek site-specific relief from the generic rule.
Thereafter, Stepan filed a petition for an adjusted standard
(AS
88-2)
which has been pending before the Board since
1988 due to
the intervening imposition of a federal
“generic rule”
in the
Federal Implementation Plan
(“FIP”)
and Stepan’s subsequent FIP
appeal.
The state adjusted standard proceeding has been stayed
pending the outcome of the federal appeal and USEPA’s development
of a site-specific standard for Stepan.
Last year USEPA proposed
a site-specific rule for Stepan and Stepan provided extensive
-
19
-
comments on that rule; however, USEPA review of Stepan’s comments
has been repeatedly delayed.
Adopting the agreed upon language provided with the Agency’s
comments
(and attached hereto)
offers an opportunity to cut-
through several layers of site specific proceedings and finally
get a rule in place for these Stepan emission units.3/
Both
IEPA and USEPA agree that this procedural approach makes sense.
Although USEPA has not formally reviewed the IEPA proposed rule
and its application to Stepan,
Stepan has discussed this matter
with counsel for USEPA.
In response to that discussion,
USEPA
has filed a status report with the 7th Circuit Court of Appeals
in Stepan’s FIP appeal indicating
it will withhold further action
on the federal site specific rule until it has had an opportunity
to formally review a SIP revision for this rulemaking.
(Attachment C.)
CONCLUSION
Stepan urges the Board to adopt the revised language
provided by the Agency in its comments and to provide
3/
AS 88-2 and the federal proceeding address both Stepan’s
continuous reactors and distillation processes and Stepan’s
batch processes.
Stepan has made a request
to include
Stepan’s continuous reactor and distillation processes in
the pending rulemaking docket, R 94-21.
If both this
proposed rule and the R94-21 proposal are adopted by the
Board and federally approved, Stepan will be in a position
to move to withdraw both its pending adjusted standard
petition and its federal appeal and associated USEPA site
specific rulemaking.
-
20
-
clarification in the Board’s Opinion and Order as requested
herein.
Respectfully submitted,
Date:
January 30,
1995
~
STE~N ‘COMPA1~Y\
By O’~ie of Its Attorneys
Percy L. Angelo
Patricia F.
Sharkey
MAYER, BROWN & PLATT
190 South LaSalle Street
Chicago,
Illinois
60603
(312)
701-0600
THIS DOCUMENT IS FILED ON RECYCLED PAPER
-
21
-
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AMENDMENTS
TITLE 35:
ENVIRO~NENTALPROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
I:
POLLUTION CONTROL
BOARD
SUBCHAPTER
c:
EMISSIONS STANDARDS AND LIMITATIONS
FOR STATIONARY SOURCES
PART
218
ORGANIC MATERIAL EMISSION STANDARDS
AND
LIMITATIONS FOR THE
CHICAGO
AREA
SUBPART
A:
GENERAL
PROVISIONS
Section
218.100
218.101
218 .102
218.203
218.104
218,105
218.106
228 .107
218.108
218.109
218.110
218
.
111
218.112
218.113
218.114
Introduction
Savings Clause
Abbreviations and Conversion Factors
Applicability
Definitions
Test Methods and Procedures
Compliance Dates
Operation of Afterburners
Exemptions, Variations,
and Alternative Means of
Control or Compliance Determinations
Vapor Pressure of Volatile Organic Liquids
Vapor Pressure
of Organic Material or Solvents
Vapor Pressure of Volatile Organic Material
Incorporations by Reference
Monitoring for Negligibly-Reactive Compounds
Compliance with Permit Conditions
Separation Operations
Pumps and Compressors
Vapor Blowdown
Safety Relief Valves
ATTACHMENT A
SUBPART B:
ORGANIC EMISSIONS FROM STORAGE
AND
LOADING OPERATIONS
Section
218 .129
218 .121
218. 122
218
.
123
218.124
218.125
218.126
Applicability for VOL
Storage Containers
Loading Operations
Petroleum Liquid Storage Tanks
External Floating Roofs
Compliance Dates
(Repealed)
Compliance Plan (Repealed)
Section
216.141
218.142
218.143
228.144
SUBPART
C:
ORGANIC
EMISSIONS
FROM MISCELLANEOUS EQUIPMENT
JAN30
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SUBPART E:
SOLVENT CLEANING
Section
218.181
218.182
218.183
218.184
218.185
218.186
Section
~218.422
218.422
Solvent Cleaning in General
Cold Cleaning
Open Top Vapor Degreasing
Conveycrized Degreasing
Compliance Schedule
(Repealed)
Test Methods
SUBPART
F~ COATING OPERATIONS
Emission Limitations
Daily-Weighted Average Limitations
Solids Basis Calculation
Alternative Emission Limitations
Exemptions from Emission Limitations
Exemption from General Rule on
use
of
Organic.
Material
Compliance Schedule
Recordkeeping and Reporting
SUBPART
G:
USE
OF
ORGANIC
MATERIAL
Use of Organic Material
Alternative Standard
Fuel
Combustion
Emission
Units
Operations with Compliance Program
SUBPART
H:
PRINTING AND PUBLISHING
Flexographic and Rotogravure Printing
Applicability
Compliance Schedule
Recordkeeping and Reporting
Heatset-Web-Offset Lithographic Printing
SUBPART
Q:
LEAKS
FROM
SYNTHETIC
ORGANIC
CHEMICAL
AND
POLYMER
MANUFACTURING
PLANT
General Requirements
Inspection Program Plan
for Leaks
2
Section
218.204
218.205
218.206
218.207
218.208
218.209
218.210
218.211
Section
218.301
218.302
218.303
218.304
Section
216.401
218 .402
218.403
218.404
218.405
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SUBPART R:
PETROLEUN REFINING
AND
RELATED
INDUSTRIES;
ASPHALT
MATERIALS
Section
218.441
218.442
218.443
218.444
218.445
218.446
218.447
218.448
218.449
218.450
218.451
218 .452
218.453
Petroleum Refinery Waste Gas Disposal
Vacuum Producing Systems
Wastewater (Oil/Water)
Separator
Process Unit Turnarounds
Leaks:
General Requirements
Monitoring Program Plan for Leaks
Monitoring Program for Leaks
Recordkeeping for Leaks
Reporting for Leaks
Alternative
Pr’ogram for Leaks
Sealing Device Requirements
Compliance Schedule for Leaks
Compliance Dates
(Repealed)
SUBPART
S:
RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS
Sect±
on
218.461
218.462
218.463
218.464
218.465
218.466
Section
228.480
218.481
218.482
228.483
JAN 30
‘95 15:55
Manufacture of Pneumatic Rubber Tires
Green Tire Spraying Operations
Alternative
Emission
Reduction
Systems
Emission Testing
Compliance Dates
(Repealed)
Compliance Plan (Repealed)
SUBPART
T:
PHARMACEUTICAL
MANUFACTURING
ApplicabiJ.ity
Control of Reactors, Distillation tJnits~ Crystallizers,
Centrifuges and Vacuum Dryers
Control of Air Dryers,
Production
Eq-uiprnent
Exhaust
Systems and Filters
Material Storage and Transfer
3
ILLINOIS
REGISTER
POLLUTION
CONTROL
BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
218.423
Inspection Program for Leaks
218.424
Repairing Leaks
218.425
Recordkeeping
for Leaks
228.426
Report for Leaks
218.427
Alternative Program for Leaks
218.428
Open-Ended Valves
218.429
Standards for Control Devices
218.430
Compliance Date
(Repealed)
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218.484
218.485
218.486
218.487
218.488
218.489
In-Process Tanks
Leaks
Other Emission Units
Testing
Monitoring for Air Pollution Control Equipment
Recordkeeping
for
Air
Pollution
Control
Equipment
SUBPART
V:
BATCH OPERATIONS AND AIR OXIDATiON PROCESSES
•
Section
218.500
Applicability for Batch Operations
218.501
Control Requirements for Batch Operations
218.502
Determination
of
Uncontrolled
Total
Annual
Mass
Emissions and Average Flow Rate Values for Batch
Operations
• 218.503
Performance and Testing Requirements for Batch
Operations
Monitoring
Requirements
for
Batch
Operations
Reporting and Recordkeeping for Batch Operations
Compliance Date
Definitions
(Repealed)
Emission Limitations for Air Oxidation Processes
Testing and Monitoring
Compliance Date (Rep~a1ed)
SUBPART
W:
AGRICULTURE
Section
216.541
Section
218.561
218.562
218.563
Section
218.581
• 218.582
218.583
218.584
218.585
JAN 30
‘95 15:56
Pesticide Exception
SUBPART
X:
CONSTRUCTION
Architectural Coatings
Paving Operations
Cutback Asphalt
SUBPART
Y:
GASOLINE DISTRIBUTION
Bulk Gasoline Plants
Bulk Gasoline Terminals
Gasoline Dispensing Operations
-
Storage Tank Filling
Operations
Gasoline Delivery Vessels
Gasoline Volatility Standards
4
218.504
218.505
218.506
218.
521
218.925
218.526
218 .527
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218.586
Section
228.620
218.621
218.623
218.624
218.625
218.626
218.628
218.630
218.636
218.637
Gasoline Dispensing Operations
-
Motor Vehicle Fueling
Operations
SUBPART
Z:
DRY
CLEANERS
Perchioroethylene Dry Cleaners
Applicability
Leaks
Compliance Dates
(Repealed)
Compliance
Plan
(Repealed)
Exception to Compliance Plan (Repealed)
Standards for Petroleum Solvent Dry Cleaners
Operating Practices for Petroleum Solvent Dry Cleaners
Program for Inspection and Repair of Leaks
Testing
and
Monitoring
Applicability for Petroleum Solvent
Dry
Cleaners
Compliance Dates
(Repealed)
Compliance Plan
(Repealed)
SUBPART
AA:
PAINT AND INK MANUFACTURING
Applicability
Exemption for Waterbase Material and Heatset-Offset Ink
Permit Conditions
(Repealed)
Open Top Mills, Tanks, Vats
or Vessels
Grinding Mills
Storage
Tanks
Leaks
Clean Up
Compliance Schedule
Recordkeeping and Reporting
SUBPART
BB:
POLYSTYRENE PLANTS
Applicability
Emissions Limitation at Polystyrene Plants
Emissions Testing
SUBPART
CC:
POLYESTER
RESIN
PRODUCT
MANUFACTURING
PROCESS
Section
218.660
218.666
Applicability
Control Requirements
JAN 30
‘95 15:55
5
Section
218.602
218
.
602
218.603
218.604
218.605
218.606
218.607
218. 608
218.609
218.610
218
.
611
218. 622
218. 613
Section
218.640
218
.
642
218 .644
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Compliance Schedule
Testing
Recordkeepirig and Reporting
f,or Exempt Emission Units
Recordkeeping and Reporting for Subject Emission Units
SUBPART DD: AEROSOL
CAN
FILLING
Applicability
Control Requirements
Testing
Recordkeeping and Reporting
for Exempt Emission Units
Recordkeeping and Reporting for Subject Emission Units
SUBPART GG:
MARINE TERMINALS
Applicability
Control Requirements
Compliance Certification
Leaks
Testing and Monitoring
Recordkeeping and Reporting
Applicability of Subpart BB
(Renumbered)
Emissions Limitation at
Polystyrene Plants (Renumbered)
Compliance Date
(Repealed)
Compliance Plan
(Repealed)
Special Requirements for Compliance Plan
(Repealed)
Emissions Testing (Renumbered)
SUBPART
PP:
MISCELLANEOUS
FABRICATED
PRODUCT
MANUFACTURING
•
PROCESSES
Section
218.920
218.923
218.926
218.927
218.928
SUBPART
QQ:
MISCELLANEOUS FORMULATION MANUFACTURING PROCESSES
i••j
218.667
218.668
218.670
218.672
Section
218.680
218.686
218.688
218.690
218.692
Section
218.760
218.762
218.764
218.766
218.768
218.770
218.875
218.877
218.879
218.881
218.883
218.886
Applicability
Permit Conditions
(Repealed)
Control Requirements
Compliance Schedule
Testing
Section
218.940
218.943
218.946
218.947
Applicability
Permit Conthtions
(Repealed)
Control Requirements
Compliance SChedule
6
JAN30
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218.948
Testing
SUBPART RR:
MISCELLANEOUS ORGANIC CHEMICAL MANUFACTURING
PROCESSES
I
Section.
218.960
Applicability
218.963
Permit Conditions
(Repealed)
218.966
Control Requirements
218.967
Compliance
Schedule
218.968
Testing
•
SUBPART TT:
OTHER EMISSION UNITS
Section
218.980
Applicability
218.983
Permit Conditions
(Repealed)
218.986
Control Requirements
218.987
Compliance Schedule
218.988
Testing
SUBPART
tflj
RECORDKEEPING
AND
REPORTING
Section
218.990
Exempt Emission Units
218.991
Subject Emission Units
Section 218.Appendix A;
List of Chemicals Defining
Synthetic
Organic Chemical and Polymer
Manufacturing
Section 228.Appendix B:
VOM Measurement Techniques for
Capture
Efficiency
Section 218.Appendix C~ Reference Test Methods for Air
Oxidation
Processes
Section 218.Appendix D:
Coefficients for the Total Resource
Effectiveness Index
(TRE)
Equation
Section 218.Appendix E:
List of Affected Marine Terminals
AUTHORITY:
Implementing Section 10 and authorized by Section
28.5 of the Environmental Protection Act
(Ill.
Rev. Stat.
1991,
I ch. 111~,par.
1010)
(P.A.
87-1213,
effective September 26,
2992)
415
ILCS 5/10 and 28.5).
SOURCE:
Adopted at R91-7 at 15 Ill.
Reg.
12231, effective August
16.
2991; amended in R91-23 at 16
Ill. Reg.
13564,
effective
August
24, 1992;
amended in R91-28 and R9l-30 at 16 Ill.
Reg.
7
JAN30
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NOTICE OF PROPOSED AMENDMEN’IS
13864, effective August
24,
1.992;
amended in P.93-9 at
17 Ill.
Reg.
16636,
effective September 27,
1993; amended in R93-14 at
18
Ill. Reg.
at 1945,
effective January 24, 1994; amended in P.94-12
at
18
Iii.
Reg.
14973,
effective September 21,
1994;
amended in
P.94-15 at 18
Ill. Reg.26379, effective November
4,
1994; amended
in R94-_
at
______
Ill.
Reg.
________,
effective
_______________
SUBPART V:
BATC~-IOPERATIONS AND AIR OXIDATION PROCESSES
Section
218.500
Applicability for Batch Operations
a)
The control requirements set forth
in Section 218.501
of this Subpart shall apply
to:
1)
Process vents associated with batch operations
at
sources identified by any of the following four-
digit
standard
industrial
classification
(“SIC”)
codes,
as defined in the 1987 edition of the
Federal Standard Industrial Classification Manual:
SIC 2821,
2833, 2~34,2861,
2865,
2869, and 2879;
and
2)
All
batch operations
at
Stepan
Company’s
Milisdale
•
manufacturing facility,
Elwood,
Illinois.
b)
The
requirements
of
Sections
218.500
through
218.506
shall
not
apply
to~
1)
Any
emission
unit
included
within
the
category
specified in
35 Ill.
Adm.
Code Part
218,
Subparts
B or T;
2)
Any
emission unit included
within the category
specified in Sections 218.520 through 218.527 of
this Subpart; and
3)
Any
emission unit included within an Early
Reduction Program, as specified in 40 CFR Part 63,
and published in 57 Fed.
Reg.
61970
(December 29,
2992), evidenced by a timely enforceable
commitment approved by
USEPA.
c)
The following single unit
operations and batch process
trains are subject to
this Subpart but are considered
to be de rninimis and are,
therefore,
exempt from the
8
JAN30
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control requirements
of Section 216.501 of this
Subpart.
However,
the
recordkeeping and reporting
requirements in Section 218.505 of this Subpart shall
apply to such de minimis single unit operations and
batch process trains:
1)
Within a batch operation,
any single unit
operation with uncontrolled total annual mass
•
emissions of less than or
equal
to 500 lb/yr of
VON.
Such
single unit operations are also
excluded from the calculation of the total annual
mass emissions for a batch process train.
If the
uncontrolled total annual mass emissions from such
exempt single unit operation exceed 500 lb/yr of
VON in any subsequent year,
the source shall
calculate applicability in accordance with
subsection
(d)
of this Section for both the
individual single unit operation and the batch
process train containing the single unit
operation;
and
2)
Any
batch process train containing process vents
that have,
in the aggregate, uncontrolled total
annual mass emissions,
as determined in accordance
with Section 218.502 (a)
of this Subpart,
of less
than 30,000 lb/yr of VON for all products
manufactured in such batch process train.
d)
The applicability equations in subsection
(e)
of this
Section, which require the calculation of uncontrolled
total annual mass emissions and flow rate value,
shall
be used to determine whether a single unit operation or
a batch process train is subject to the control
requirements set forth in Section 218.501 of this
Subpart. The applicability equation shall be applied to
the following:
1)
Any
single unit operation with uncontrolled total
annual mass emissions that exceed 500 lb/yr and
with a VON concentration greater than 500 ppmv.
In this individual determination, no applicability
analysis shall be performed for any single unit
operation with a VON concentration of less than or
equal to 500 ppmv; and
2)
Any
batch process train containing process vents
9
JAN 30
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NOTICE OF PROPOSED
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which,
in
the
aggregate,
have
uncontrolled
total
annual mass emissions of 30,000 lb/yr or more of
VOM from all products manufactured in the batch
process train.
Any
single unit operation with
uncontrolled
total
annual
mass
emissions
exceeding
500 lb/yr,
regardless of VOM concentration,
shall
be included in the aggregate applicability
analysis.
e)
Applicability equations
1)
The
applicability
equations
in
this subsection are
specific to volatility.
2)
For purposes of
this subsection,
the following
abbreviations apply:
A)
FR
Vent stream flow rate,
scfm;
B)
UTANE
=
Uncontrolled total annual mass
emissions of
VON,
expressed as
lb/yr;
C)
WAV
=
Weighted average volatility;
D)
NVOM~
=
Mass
of VOM component
1;
and
E)
MWVOM~~
Molecular weight of VON component
1;
and
F).
VP~
=
Vapor pressure of VON component
i.
3)
Weighted average volatility shall be calculated as
follows:
nt
(MVOM)
•
E
(VP1)x
i=.
(
(MWVOM~)
WAV
=
n
I
(!~VOM~)
I
I
1=1
1
(MWVOM~)
)
4)
For purposes of determining applicability,
flow
rate values shall be calculated as follows:
10
JAN30
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NOTICE OF PROPOSED AMENDMENTS
A)
Low
WAV
has
a
vapor
pressure
less than or
equal
to
75
mmHg
at
20°C
(68°F)
,
and
shall
use the following equation:
FR
=
0.07
(UTAME)
-
1,821
B)
Moderate WAV has a vapor pressure greater
than
75
mmHg
but less than
or
equal
to
150
mmHg
at
20°C
(68°F),
and shall use the
following equation:
FR
=
0.031
(UTAME)
-
494
C)
High WAV has a vapor pressure greater than
150
mmHg
at
20°C
(68°F),
and
shall
use
the
following
equation:
FR
=
E0.013
(UTAME)
-
301
5)
To
determine
the
vapor
pressure
of
VON,
the
applicable methods and procedures in Section
218.111
of
this
Part
shall
apply.
(Source:
Added at
_____
Ill.
Reg.
_______,
effective
Section
216.501
Control
Requirements
for
Batch
Operations
a)
avery
owner or operator of
a
single
unit
operation
with
•
an
average
flow
rate,
as
determined in accordance with
Section 218.502(b)
of
this Subpart,
below
the flow rate
value calculated
by the applicabij.ity equations
contained in Section 218.500(e)
of this Subpart,
shall
reduce uncontrolled VON emissions from such single unit
operation by an overall efficiency,
on average,
of at
least
90 percent,
or 20 ppmv, per batch cycle.
b)
Every owner or operator of a batch process train with
an average flow rate,
as
determined in accordance with
Section 218.502(b)
(2)
of this Subpart, below the flow
rate value calculated by the applicability equations
contained in Section 218.500(e)
of this Subpart, shall
reduce uncontrolled VOM emissions from such batch
process train by an overall efficiency, on average,
of
at
least
90
percent,
or
20
ppmv,
per
batch
cycle.
For
purposes
of
demonstrating
compliance
with
the
emission
11
~
I_~
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NOTICE
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PROPOSED
AMENDMENTS
limitations set forth in this Section, any control
device meeting the criteria in subsection
(c)
of this
Section shall
be deemed
to
achieve a control efficiency
of 90 percent,
or 20
pprnv, per batch cycle, as
applicable.
c)
Notwithstanding subsections
(a)
or
(b)
of this Section,
any
source
that
has
installed
on
or
before
March
15,
1995, any control device which is demonstrated to the
Agency’s satisfaction to be unable to meet the
applicable
control
requirements
of
this
Section,
scrubber,
or
shell
and
tube
condenser
using
a
non-
refrigerated cooling media,
and such device achieves
at
least 81 percent control efficiency of VON emissions,
is required to meet the
90 percent emission limitation
or 20 ppmv VOM concentration set forth in subsections
(a)
or
(b)
of this Section,
as
applicable,
upon the
earlier
to
occur
of
the
date
the
device
is
replaced
for
any reason,
including,
but not limited to, normal
maintenance,
malfunction,
accident,
and obsolescence,
or
December
31,
1999.
A
scrubber,
shell
and
tube
condenser
using
a
non-refrigerated
cooling
media,
or
other control device meeting the criteria of this
subsection
is
considered
replaced
when:
1)
All of the device is replaced;
or
2)
When either the cost to repair the device or the
cost to replace
part of the device exceeds 50
percent of the cost of replacing the entire device
with
a
control
device
that
complies
with
the
90
percent emission limitation or 20 ppmv VOM
concentration level in subsection
(a)
of this
•
Section,
as applicable.
d)
If a boiler or process heater is used
to comply with
this Section,
the vent stream shall be Introduced into
the flame zone of the boiler or process heater.
e)
If a flare is used to comply with this Section,
it
shall comply with the requirements of 40 CFR 60.18,
incorporated by reference at Section 218.112 of this
Part.
The flare operation requirements of 40 CFR G0.28
do not apply if a process, not subject to this Subpart,
vents an emergency relief discharge into a common flare
header and causes the flare servicing the process
12
JAN30
‘95
15:59
PAGE.13
JAN—30—1995
16:55
FROM
IEPA/APC/AQPS
TO
913127017711
P.14
ILLINOIS REGISTER
POLLUTION CONTROL BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
subject to this Subpart to not comply with one or more
of the provisions
of 40 CFR 60.18.
(Source:
Added
at
_____
Ill.
Reg.
______,
effective
Section 218.502
Determination of Uncontrolled Total Annual
Mass Emissions and Average Flow Rate Values
for Batch Operations
a)
Uncontrolled total annual mass emissions shall be
determined by the following methods;
1)
Direct process vent emissions measurements taken
prior to any re1~aseto the atmosphere,
following
•any recovery device and prior
to any control
device, provided such measurements conform with
the requirements of measuring the mass flow rate
of VON incoming to the s-i~gleun-it opcration
control device as set forth in Section
218.503(f) (2),
(f) (3) (A)
and
(f) (3) (B)
of this
Subpart; or
2)
Engineering estimates of the uncontrolled VON
emissions from a process vent or process vents,
in
the aggregate, within a batch process train, using
either mu-ltipl~d~
the potential or permitted
number of batch cycles per year or tot~al
production as represented in the source’s
•pperating~pe~rmitas follows:
A)
Engineering estimates of the uncontrolled VON
emissions shall be based upon
accepted
chemical engineering principles,
measurable
process parameters,
or physical or chemical
laws and their properties.
Examples of
methods include, but are not limited to,
the
following:
i)
Use of material balances based on
process stoichiometry to estimate
maximum VOM concentrations;
ii)
Estimation
of maximum flow rate based on
physical equipment design such as pump
or blower capacities; and
13
JAN 30
‘95 16:00
PAGE. 14
JAN—30—1995
16:56
FROM
IEPA/APC/AQPS
TO
913127017711
P.15
ILLINOIS REGISTER
POLLUTION CONTROL BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
iii)
Estimation
of
VON
concentrations
based
on saturation conditions.
B)
All data,
assumptions and procedures used in
any engineering estimate shall be documented.
b)
Average flow rate shall be determined by any of the
following methods:
1)
Direct process vent flow rate measurements taken
prior to any release to the atmosphere,
following
any recovery device and prior
to any control
device,
provided such measurements conform with
the
requirements
of
measuring
incoming
volumetric
flow rate set forth in Section 218.503(e) (2)
of
this Subpart;
2)
Average flow rate for a single unit operation
having multiple emission events or batch process
trains shall be the weighted average flow rate,
calculated as follows:
n
E ~
x
ADEJj.
i~1
WAF
=
__________________
n
~
iADE~1
i=J.
where:
WAF
=
Actual weighted average flow
rate for a single unit
operation or batch process
train;
AFR~
=
Average flow rate per emission
event;
=
Annual
duration of emission
event;
and.
n
Number of emission events.
For purposes of this_formula, the t.erm “emission
event”
~h~*Lbe
defined as
a discrete period ~f venting that
is associated with a
sii-igie
unit
cpe~aticn.
For
exam~le,
a_~splacementof vap~~resultin~from the
14
JAN30
‘95 16:00
PAGE.15
JAN-30—1995
16:56
FROM
IEPA/APC/PQPS
TO
913127017711
P.16
ILLINOIS REGLSTER
POLLUTION
CONTROL
BOARD
NOTICE OF PROPOSED
AMENDMENTS
charging of
a single unit operation with VOM will
result in a discrete emission ey~entthat will last
throu~hthe duration
of
‘cjie
char~e
and
will
have
an
a~e,rage
flow rate egual
to the rate of the charge.
Th~
expu_lsion of expanded vapor space when the single unit
o~~a~tjon
is heated is als6 an_emission event.
Both of
these examples of emission events and others may occur
in the same single unit operation durin~the course pf
•
the batch cycle.
If the flow rate measurement
for a~y
emission event
is zero,
according to Section
218.503(f) (2)
of this Subpart, then such event is not
an
emission
event
for
purposes
of
this
Seg~.ion.
3)
Engineering estimates calculated in accordance
with
the
requirements
in
subsection
(a)
(2)
of
this
Section.
c)
For purposes of determining the average flow rate for
steam
vacuuming
systems,
the steam flow shall be
included in the average flow rate calculation.
(Source:
Added
at
_____
Ill.
Reg.
_______,
effective
______
Section 218.503
Performance and Testing Requirements for
Batch Operations
a)
Upon the Agency’s request, the owner or operator of a
batch operation shall conduct testing to demonstrate
compliance with Section 218.501 of this Subpart.
The
owner or operator shall,
at its own expense, conduct
such tests in accordance with the applicable test
methods
and procedures specified in Section 218.503(d),
(e), and
(f)
of this Subpart.
b)
Notwithstanding subsection
(a)
of this Section,
flares
and process boilers used to comply with control
requirements of Section 218.501 of this Subpart shall
be exempt from performance testing requirements.
c)
When a flare is used to comply with the control
requirements of Section 218.501 of this Subpart, the
flare shall comply with the requirements of 40 CFR
60.18,
incorporated by reference at Section 218.112 of
this Part.
15
JAN 30
‘95
16:01
PAGE. 16
JAN—30—1995
16:57
FROM
IEPA/APC/AQPS
TO
913127017711
P.17
IL1LTNOIS REGISTER
POLLUTION CONTROL
BOARD
NOTICE OF PROPOSED AMENDMENTS
d)
The owner or operator of a batch operation that is
exempt from the control requirements of Section 218.501
of this Subpart shall demonstrate, upon the Agency’s
request,
the absence of oversized gas moving equipment
in any manifold.
Gas moving equipment shall be
considered oversized if it exceeds the maximum
requirements
of
the
exhaust
flow
rate
by
more
than
30
percent.
e)
For the purpose of demonstrating compliance with the
control requirements in Section 218.501 of this
Subpart,
the
batch
operation
shall
be
run
at
representative
operating
conditions
and
flow
rates
during
any
performance
test.
f)
The following methods in 40
CFP. 60, Appendix A,
incorporated by reference at Section 218.112 of this
Part,
shall
be
used
to
demonstrate
compliance
with
the
reduction
efficiency
requirement
set
forth
in
Section
218.501
of
this
Subpart:
1)
Method 1 or 1A,
as appropriate,
for selection of
the sampling sites if the flow measuring device
is
not a rotameter.
The control device
inlet
sampling site for determination of vent stream VON
composition
reduction
efficiency
shall
be
prior
to
the
control
device
and
after
the
control
device;
2)
Method 2,
2A,
2C,
or 2D, as appropriate,
for
determination of gas stream volumetric flow rate
flow measurements, which shall be taken
continuously.
No traverse is necessary when the
flow measuring device is an ultrasonic probe;
3)
Method 25A or Method
18,
if applicable,
to
determine the concentration of VOM in the control
device inlet and outlet;
A)
16
The sampling time for each run shall be as
follows:
wi-I-I
bc—the
entire J.cngth
o~f thc
batch cycle in which ~ocLdingooh~llbe t&cc~
eontinuouoly,
if
Mothod
25A
ic
ucod,
or
as
e~-t~en—i-c---po~-o4blcucin-g---Method
1-8--—with~
max-imurr~
of l~minute i~iterv~l-sbc~wccn
mo~suromont~o
t~ro~igho~t
the—b3tc-h--ay-ci-e--
JAN 30
‘95
16:01
PAGE. 17
-
JAN—30—1995
16:57
FROM
IEPA/APC/AQPS
TO
913127017711
P.18
ILLINOIS REGISTER
POLLUTION
CONTROL
BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
jj..
For
batch
cycles
less
than
eight
hours
in length,
readings shall be_taken
continup_usly over_the entire length of
the batch cycle with a maximum of
15-
in~.nuteintervals
between
measurements
if
using
Method
25A.
Lf
using Method 18.
readings
shall
be
taken
continuously
with
a
maximum
Qf
15-minute
intervals
between measurements throughout the
batch
cvcLe.
unless
it
becomes
necessary
to change the imp~nge~t~aj.n.
in which
ca~e_a30-minute interval shaU not be
exceeded.
~
For
batch
cycles
of
eight
hQurs
and
greater ~n ~.ength~the owner or operator
may either test in •accordance_~i_ththe
test procedures defined in subsection
~(f)(3) (A) (i)
Qf this Section or the
pwner
or
operator
m~elect
to
perform
tests,
p
suant to either Method 2~Aor
Method 18,
only during those portions of
each
emission
event
which
dfine_the
emission
profile_of
each
emission
event
~cc~xring within the batohcycle.
For
.~achemissi~~_~y~nt
of
less that~fou~
hours in duration,
the owner or operator
.~1iall
test continuousjy over the entire
emission
event
as
set
forth
in
subsection
(f) (3) (A) (1)
of this Section.
~or
each
emission
event
of
greater
than
four
ho_u~s
in
duration.
t1e_o~zier
or
operator
shaU
elect
either
to
perfoxm
a
rrth~irnum
of
three
one
hour
test
run~
during
the emission
event
or shall test
contmnuously oyer the entire
jss~.on
even within each single unit operation
in the batch process train.
To
demonstrat~_thptthe portign gf the
emission event to be tested define the
ejniss.ion profile
for
the_emission
event.
the
owner
or ooerator electing to rely
an_this option shall
deveJ.op
an emission
profile
~x_the
entire emission event.
such emission
profile
shall be based
upon either_process knowledge or test
17
JAN 30
‘95
16:02
PAGE. 18
JAN—30—1995
16:58
FROM
IEPA/APC/AQPS
TO
913127017711
P.19
ILLINOIS REG1$TER
POLLUTION CONTROL
BOARD
NOTICE OF PROPOSED AMENDMENTS
data collected.
Examples of ix~formation
that could constitute process knowledge
include,
but
are
riot
limited
to~
calculatiQns based on mat_erial balances
and process stoichiometrv.
Previous
test results may be used p~pvidedsuch
results are still relevant to the
current process vent stream conditions.
.iii) For purposes of subsection
Lf)
(~)
of
thisSectioii~
the
term
“emission
event”
shall
be
defined
as
a
discrete
p_e~j.od
of
venting that is associated with a single
unjt_operation.
For example,
a
d~.splacernentof vapor resulting
from
the
charging
of
a single
unj.t operation
with
VON
will
result
in
a
discrete
emission event that will last through
the duration of the charge and will have
an average flow rate equal to the rate
o~the charge.
The expulsion
of
expanded
sin~1eunit operation vapor
space. when the vessel is heated is also
an emission event.
Both of these
examples of emission events and others
n~ayoccurin_the
same
ng~l&
unit
oPeration during the course of the batch
cycle.
If the flow rate measurement
for
any_emission event is
zero-,
in
accordance with Section 218.503(f) (2)
of
this
Subpart~then_such
event
is not
an
emission event for ~ur~oses of this
B)
The mass emission rate from the process vent
or inlet to the control device shall be
determined by combining concentration and
flow rate measurements taken simultaneously
at sampling sites selected in accordance with
subsection
(f) (1)
of this Section throughout
the batch cycle;
C)
The mass emission rate
froTr~
the control
device outlet shall be obtained by combining
concentration and flow rate measurements
taken simultaneously at sampling sites
18
JAN 30
‘95 16:02
PAGE. 19
JAN—30—1995
16:58
FROM
IEPA/APC/AQPS
TO
913127017711
P.20
ILLINCI$ REGISTER
POLLUTION
CONTROL
BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
selected in accordance with subsection
(f) (1)
of this Section throughout the batch cycle;
and
D)
The efficiency of the control device shall be
determined by integrating the
mass emission
rates obtained
in subsections
(c) (3) (A~-
(f) (3) (BI and
-(c)-~3)(3)
(f)
(3) (C)
of this
Section,
over
the
time
of
the
batch
cycle
and
dividing the difference
in inlet and outlet
mass flow totals by the inlet mass flow
total.
g)
Upon request by the Agency to conduct testing, an
owner
or operator of a batch operation which has installed
a
scrubber,
a
shell
and
tube
condenser
using
a
non-
refrigerated
cooling
media,
or
any
other
control
device
which
meets
the
criteria
of
Section
218.501(c)
of
this
Subpart,
shall demonstrate that such device achieves
the
control
efficiency
applicable
within
Section
218.501 of this Subpart upon the earlier to occur of
the
date
the
device
is
replaced
or
December
31,
1999.
h)
The
owner
or
operator
of
a
batch
operation
may
propose
an
alternative
test
method
or
procedures
to
demonstrate
compliance
with
the
control
requirements
set
forth
in
Section 218.501 of this Subpart.
Such method or
procedures
shall
be
approved
by
the
Agency
and
USEPA
as
evidenced
by
federally
enforceable
permit
conditions.
.iJ~
In the absencs_Qf_a reguest
by th~~gencyto conduct
performance testing in accordance with
the
provisions
of
this
Section.
a
source
may
demonstrate
compliance
by
the
use
of enqineering es_tj~atesor process
stoichiometry.
(Source:
Added at
Ill. Reg.
_______,
effective
_______
Section
218.504
Monitoring
Requirements
for
Batch
Operations
a)
Every owner or operator using an afterburner to comply
with Section 218.501 of this Subpart, shall
install,
calibrate, maintain and operate, according to
manufacturer’s specifications, temperature monitoring
devices with an accuracy of
.±
1 percent of the
19
JAN
30
‘95
16:03
PAGE.20
JAN—30—1995
16:58
FROM
IEPA/APC/AQPS
TO
913127017711
P.21
ILL~INQIS
REGISTER
POLLUTION CONTROL BOARD
NOTICE OF PROPOSED AMENDMENTS
temperature
being
measured
expressed
in
degrees
Celsius,
equipped
with
continuous
recorders.
1)
Where
a catalytic afterburner is used,
temperature
monitoring devices shall be installed in the gas
stream immediately before and after the catalyst
bed.
2)
Where an afterburner other than a catalytic
afterburner
is
used,
a
temperature
monitoring
device shall be installed in the combustion
chamber.
b)
Every
owner
or
operator
using
a
flare
to
comply
with
Section 218.501 of this Subpart,
shall
install,
calibrate,
maintain
and
operate,
according
to
manufacturer’s specifications,
a heat sensing device,
such as an ultra-violet beam sensor or thermocouple,
at
the pilot light to indicate continuous presence of a
flame.
c)
Every owner or operator using a scrubber to comply with
this
Section
218.501
of
this
Subpart,
shall
install,
calibrate, maintain, and operate,
according to
manufacturer’s specifications, the following:
1)
A
temperature
monitoring
device
for
scrubbant
liquid
having an accuracy of
±
1 percent of the
temperature
being
monitored
expressed in degrees
Celsius and a specific gravity device for
scrubbant
liquid,
each
equipped
with
a
continuous
recorder;
or
2)
A
VOM monitoring device used to indicate the
concentration of VOM exiting the control device
based on a detection principle such as infra-red
photo±onization, or thermal conductivity, each
equipped
with
a
continuous
recorder.
d)
Every owner or operator using a condenser to comply
with
Section
218.501 of
this Subpart,
shall install,
calibrate, maintain, and operate,
according to
manufacturer’s specifications, the following:
1)
A condenser exit temperature monitoring device
equipped with a continuous recorder and having
an
20
JAN 30
‘95 16:03
PAGE.21
JAN—30—1995
16:59
FROM
IEPA/APC/AQPS
TO
913127017711
P.22
ILLINOIS
REGISTER
POLLUTION CONTROL
BOARD
NOTICE OF PROPOSED AMENDMENTS
accuracy
of
±1
percent
of
the
temperature
being
monitored expressed in degrees Celsius; or
2)
A VON monitoring device used
to
indicate
the
concentration of VON such as infra-red,
photoionization,
or thermal conductivity, each
equipped with a continuous recorder.
0)
Every
owner or operator using
a carbon adsorber to
comply with this Subpart shall install,
calibrate,
maintain,
and operate, according to the manufacturer’s
specifications the following equipment:
1)
An integrating regeneration
8e~c~am
steam flow
monitoring device having an accuracy of ±10
percent, and a carbon bed temperature monitoring
device having an accuracy of
±i percent of the
temperature being monitored expressed in degrees
Celsius,
both
equipped
with
a
continuous
recorder;
or
2)
A VON monitoring device used to indicate the
concentration level e~gj. VOM exiting such device
based on a detection principle such as infra-red,
photoionization, or thermal conductivity, each
equipped with a continuous recorder.
f)
Every owner or operator using a boiler or process
heater with a design heat input capacity less than 44
Nw to comply with Section 218.501 of this Subpart,
shall
install, calibrate,
maintain,
and operate,
according to the manufacturer’s specifications,
a
temperature monitoring device in the firebox with an
accuracy of ±1 percent of the temperature being
measured expressed in degrees Celsius,
equipped with a
continuous recorder.
Any
boiler or process heater in
which all process vent streams are introduced with
primary fuel is exempt from this requirement.
g)
The owner or operator of a process vent shall be
permitted to monitor by an alternative method or may
monitor parameters other that those listed in
subsections
(a)
through
(f)
of
this
Section,
if
approved by the Agency and tJSEPA.
Such alternative
method or parameters shall be contained in the source’s
operating
permit
as
federally
enforceable
permit
21
JAN 30
‘95 16:04
PAGE.22
JAN—30—1995
16:59
FROM
IEPA/APC/RQPS
TO
913127017711
P.23
ILLINOI$ REGISTER
POLLUTION
CONTROL
BOARD
NOTICE
OF
PROPOSED
AMENDMENTS
conditions.
h)
Notwithstanding subsections
(a)
through
(g)
of this
Section,
sources
using
a
scrubber,
shell
and
tube
condenser using a non-refrigerated cooling media, or
other control device meeting the criteria of Section
218.501(c)
of this Subpart, are required to monitor
compliance with the requirements of this Subpart
on
and
after the earlier to occur
of
the
date
such
device
is
replaced for any reason or December 31,
1999.
(Source:
Added at
_____
Ill. Reg.
,
effective
_______
Section 218.505
Reporting and Recordkeeping for Batch
Operations
a)
Every owner or operator of
a de minirnis single unit
operation or batch process train exempt under Section
218.500(c) (1)
or
Cc) (2)
of this Subpart,
shall keep
records of the uncontrolled total annual mass emissions
for any do minimis single unit operation or batch
process train,
as applicable,
and documentation
verifying these values or measurements.
The
documentation shall include the engineering
calculations, any measurements made in accorda~icew±th
Section
218.503 of tbis Subpart, and the potential or
perrnitted
number
of
batcii
cycles
per
ve~x Qr,
in
the
alternative,
total production as represented in the
source’s_operating perrnit_.—or mca~urcmcnt~’
coupled pith
the potcntial -or pcrm-it~-tcd
n.iurnbcr
of bitch cyc1e~pc-r
yc~r
if the uncontrolled tot-al annupl m~asc~mi-ooion~
i-c
obtained from ~ea-ourcmcnt~ madc
in accord~ncc
with
~cction
218.503
of
this
£ubpart.
b)
Every owner or operator of a single unit operation
exempt under Sections 218.500(b) (3)
or
(-d)
of this
Subpart shall keep the following records:
1)
The uncontrolled total annual mass emissions and
documentation verifying these values or
measurements.
The documentation shall include ai~y
engineering calculations, any measurements made
in
accordance with Section 218.~P3_ofthis Suboart~
and the pqtential pr
perrnitted
number of batch
c.y~clesper year,
g~
ji~the
alternative
otal
22
JAN 30
‘95 16:04
PAGE.23
