ILLINOIS POLLUTION CONTROL BOARD

SUBPART D: EXISTING LIQUID OR MIXED FUEL COMBUSTION EMISSIO
(Source: Amended at _ Ill. Reg. _, effective _)
SUBPART Q: PRIMARY AND SECONDARY METAL MANUFACTURING
Section 218.105 Test Methods and Procedures
Section 218.112 Incorporations by Reference
SUBPART F: COATING OPERATIONS
SUBPART Z: DRY CLEANERS

April 21, 2005

IN THE MATTER OF:

CLEAN-UP PART III AMENDMENTS TO

35 ILL. ADM. CODE PARTS 211, 218, AND

219

)

R04-20

(Rulemaking - Air)

______________________________________

IN THE MATTER OF:

TECHNICAL CORRECTIONS TO

FORMULAS IN 35 ILL. ADM. CODE 214

“SULFUR LIMITATIONS”

)

R04-12

(Rulemaking - Air)

(Consolidated)

Proposed Rule. First Notice.

OPINION AND ORDER OF THE BOARD (by A.S. Moore):

In the consolidated rulemakings docketed as R04-20 and R04-12, the Board today

proposes rule amendments for first-notice publication in the

Illinois Register

. The proposed

amendments are designed to clarify, correct, streamline, and update numerous provisions of the

Board’s air pollution control rules in Parts 211, 214, 218, and 219 of Title 35 of the Illinois

Administrative Code. The Board is conducting this proceeding under the general rulemaking

provisions of the Environmental Protection Act (Act) (415 ILCS 5/27, 28 (2002)), the

Administrative Procedure Act (5 ILCS 100/5-40 (2002)), and the Board’s procedural rules (35

Ill. Adm. Code 102).

The Board previously consolidated these two rulemakings for hearing. The Board is

using docket R04-20 to address a rulemaking proposal filed by the Illinois Environmental

Protection Agency (IEPA). IEPA proposes amending the Board’s rules at 35 Ill. Adm. Code Part

211 (definitions and general provisions), Part 218 (organic material emission standards and

limitations for the Chicago area), and Part 219 (organic material emission standards and

limitations for the Metro East area). Among other things, these proposed amendments would

allow “alternative” methods for measuring the volatile organic material (VOM) “capture

efficiency” of various emission control equipment. These changes are designed to increase

regulatory flexibility, consistent with United States Environmental Protection Agency (USEPA)

requirements. The Board today is adopting for first notice IEPA’s proposed rule language, with

several exceptions discussed below.

Docket R04-12 is dedicated to a Board-initiated rulemaking proposal. The Board today

is proposing first-notice amendments to its rules at 35 Ill. Adm. Code Part 214 (sulfur

limitations). The Board’s proposed changes are needed to correct typographical errors in

formulas that appear to have occurred during re-codification of the Illinois Administrative Code.

In this opinion, the Board first provides the procedural history of this rulemaking and

addresses several procedural issues. Next, the Board discusses IEPA’s proposal in R04-20 and

the testimony and public comments that the Board received on the proposal. That is followed by

a discussion of the Board-initiated proposal in R04-12, on which the Board received no

testimony or public comments. The order following this opinion sets forth the Board’s proposed

first-notice amendments to Parts 211, 214, 218, and 219 of the Board’s air pollution control

rules.

PROCEDURAL MATTERS

Procedural History

On January 6, 2004, the Board received the proposal from IEPA to amend the Board’s air

pollution rules at 35 Ill. Adm. Code 211, 218, and 219. In a January 22, 2004 order, the Board

opened docket R04-20 for, and accepted for hearing, the IEPA proposal. In the same order, the

Board opened docket R04-12 for its proposed amendments to 35 Ill. Adm. Code 214, and

consolidated for hearing the IEPA proposal (R04-20) with the Board-initiated proposal (R04-12).

The Board held two public hearings in this consolidated rulemaking. The first took place

in Chicago on March 18, 2004. One person testified at the first hearing: Gary Beckstead,

Environmental Protection Engineer in the Air Quality Planning Section of IEPA’s Bureau of Air.

The second hearing took place in Springfield on May 6, 2004. The following persons testified at

the second hearing: Beckstead of IEPA; and David Bloomberg, Environmental Protection

Engineer in the Ozone Regulatory Unit of the Air Quality Planning Section of IEPA’s Division

of Air Pollution Control. Also participating at hearing were attorneys Charles Matoesian on

behalf of IEPA and LaDonna Driver of Hodge, Dwyer, and Zeman on behalf of the Illinois

Environmental Regulatory Group (IERG). IERG is a not-for-profit Illinois corporation affiliated

with the Illinois State Chamber of Commerce. IERG consists of 65 member companies, a

number of which are subject to Board air regulations at 35 Ill. Adm. Code 211, 214, 218, and

219. IERG Public Comment at 1.

The transcripts of the Chicago and Springfield hearings were received by the Board on

April 20 and May 17, 2004, respectively, and promptly placed in the Clerk’s Office On Line

(COOL) on the Board’s Web site at www.ipcb.state.il.us.

Many other documents from this

rulemaking are available through COOL, including Board opinions and orders, hearing officer

orders, and public comments.

As required by Section 27(b) of the Act (415 ILCS 5/27(b) (2002)), the Board made the

Department of Commerce and Economic Opportunity’s (DCEO) decision not to conduct an

economic impact study (EcIS) available to the public at least 20 days before the second hearing.

In letters of April 17, 2003, and April 2, 2004, DCEO declined to perform an EcIS, noting its

limited financial resources. No one testified about either of DCEO’s letters. Tr.2 at 40-41.

The Chicago hearing transcript is cited as “Tr.1 at _.” The Springfield hearing transcript is

cited as “Tr.2 at _.”

The Board hearing officer entered two exhibits into the record at hearing. Hearing

exhibit 1, which was entered on the hearing officer’s motion, is a group exhibit consisting of five

Board orders that bear upon proposed amendments to equations in the rules: (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. Hearing exhibit 2 was offered by

IEPA and consists of an “

Errata

Sheet” that shows proposed changes to the rule language

originally set forth in IEPA’s R04-20 proposal.

In a May 25, 2004 order, the hearing officer set a public comment filing deadline of June

18, 2004, for those who wished to ensure that the Board would consider their public comment

before proceeding to any first-notice decision. The Board received two public comments by the

June 18, 2004 pre-first-notice filing deadline and one public comment after that deadline. IEPA

filed a public comment on June 18, 2004, as did IERG. On July 30, 2004, the Jefferson Smurfit

Corporation (U.S.) (Smurfit) filed a public comment, along with a motion for the Board to

consider the public comment in making its first-notice decision. On August 16, 2004, IEPA filed

a response opposing Smurfit’s motion.

Filing Public Comments

First-notice publication in the

Illinois Register

of these proposed rule changes will start a

period of at least 45 days during which anyone may file public comments with the Board at:

Office of the Clerk

Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11-500

Chicago, Illinois 60601

The Board encourages persons to file public comments on these proposed amendments. The

applicable docket number (R04-20, R04-12, or both) should be indicated on the public comment.

Any person may file a public comment, regardless of whether the person has yet filed one.

Additionally, as part of the Board’s voluntary electronic filing pilot project, public

comments in this rulemaking may be filed through COOL at www.ipcb.state.il.us. Any

questions about electronic filing should be directed to the Clerk’s Office at (312) 814-3629.

The Board cites hearing exhibits as “Exh. # at _.”

IEPA’s public comment is cited as “IEPA PC at _.” IERG’s public comment is cited as “IERG

PC at _.”

Please note that all filings with the Clerk of the Board must be served on the hearing officer and

on those persons on the Service List for this consolidated rulemaking. Before filing any

document with the Clerk, please check with Sandy Wiley at (312) 814-3623 or

Smurfit’s Motion to Consider Its Public Comment

In Smurfit’s July 30, 2004 motion concerning its public comment, the company asks the

Board to “consider the attached comments prior to its First Notice.” Motion at 3. Smurfit states

that it learned of this rulemaking on June 30, 2004, during enforcement action settlement

discussions with IEPA concerning Smurfit’s flexible packaging facility in Schaumburg.

. at 1.

According to Smurfit, IEPA indicated during the settlement discussions that the agency’s

enforcement position concerning capture efficiency and the Emissions Reduction Market System

(ERMS), a position with which Smurfit disagrees, would be codified in this rulemaking.

Smurfit argues that it was not alerted of IEPA’s rulemaking proposal by the business

groups it belongs to because IEPA mischaracterized the proposal as non-substantive “clean-up,”

with any impacts benefiting emission sources. Motion at 2. Smurfit maintains that it “acted with

reasonable promptness after learning of the rulemaking” and that the circumstances of Smurfit’s

Schaumburg facility will demonstrate how proposed rule language “can have a clearly

substantive impact on the rights of regulated entities.”

IEPA opposes Smurfit’s motion. Relying on Section 102.108(d) of the Board’s

procedural rules (35 Ill. Adm. Code 102.108(d)), IEPA argues that Smurfit has not claimed, and

will not suffer, “material prejudice” if its motion is denied. IEPA Response at 1-2. IEPA states

that the “closest Smurfit comes to claiming material prejudice” is when Smurfit suggests that

IEPA’s labeling of the proposal as “clean-up” was “sufficient to discourage all interest by itself

or industry in the proposal and to dissuade further examination of the matter.”

. IEPA

maintains that regardless of the merits of Smurfit’s comment, Smurfit will not be materially

prejudiced when it “may still file comments during the First Notice’s 45 day public comment

period.”

. at 3.

In addition, IEPA asserts that Smurfit’s suggestion of a “substantial impact on regulated

facilities” from the capture efficiency changes disregards that IEPA has proposed an “additional

option” for measuring compliance that was “not previously available,” namely “the Data Quality

Objective/Lower Confidence Limit (‘DQO/LCL’) alternative testing for capture efficiency.”

IEPA Response at 1-2. According to IEPA, DQO/LCL would be an additional or “third option”

for major sources that use add-on controls, like Smurfit, which until now have had to meet

capture efficiency testing requirements through either a permanent total enclosure (PTE) or

temporary total enclosure (TTE).

. at 2-3. IEPA emphasizes that it is not “imposing”

DQO/LCL, but rather the “source retains the discretion to decide which method it will utilize to

demonstrate its capture efficiency.”

. at 3.

Lastly, relying on Section 101.400(a)(3) of the Board’s procedural rules (35 Ill. Adm.

Code 400(a)(3)), IEPA argues that Smurfit’s public comment was improperly filed by an

attorney who is not licensed to practice law in Illinois and who did not file a motion

pro hace

wileys@ipcb.state.il.us, the hearing officer, or the Clerk’s Office to verify the most recent

version of the Service List.

vice

with the Board to appear in this proceeding as an out-of-state attorney. IEPA Response at 4-

For the reasons below, the Board grant’s Smurfit’s motion to consider the company’s

public comment in arriving at today’s first-notice decision. The Board notes initially that,

according to IEPA, the Board’s procedural rule is “clear that comments may only be

filed

during

the prescribed period unless material prejudice will result.” IEPA Response at 2 (emphasis

added). However, Section 102.108(d) provides:

Comments that are not timely filed or properly served

will not be considered

except as allowed by the hearing officer or the Board to prevent material

prejudice. 35 Ill. Adm. Code 102.108(d) (emphasis added).

Likewise, the May 25, 2005 hearing officer order, which established the “pre-first-notice”

deadline for filing public comments, provided that “filing by June 18, 2004, ensures that your

comment will be

considered

by the Board before the Board adopts proposed rules for first-notice

publication.” (emphasis added).

Anyone can

file

a public comment with the Board up to at least 45 days after first notice

is published in the

Illinois Register

See

5 ILCS 100/5-40 (2002); 35 Ill. Adm. Code 102.604.

As the Board is proceeding today to first notice, no such publication has yet occurred. Smurfit

therefore was allowed to

file

its public comment when it did. The issue then is whether Smurfit’s

comment will be

considered

now. Under a “pre-first-notice” public comment deadline, as the

hearing officer’s order provided, if a person files a public comment on time, the commenter is

assured

that the Board will consider the comment in making its first-notice decision. Thus, the

deadline is simply a “safe harbor” for the filer. Missing the deadline does not mean that a late

comment

cannot

be considered by the Board in going to first notice—just that it

may

not be

considered if the Board lacks time to do so before first notice.

IEPA’s lengthy arguments about Smurfit’s claims of IEPA’s proposal being substantive

belie IEPA’s position that Smurfit has not sufficiently pled material prejudice. Of course,

between first and second notice, additional public comments may be filed, additional hearings

may be held, and proposed rule language may be changed. However, first notice is an important

stage of rulemaking. It is the first time that the Board may weigh in on the merits of the proposal

and the first time the proposed rules are published in the

Illinois Register

. Not considering

Smurfit’s comment now would, at this juncture, deprive Smurfit of any participation in this

phase of the rulemaking. In this context, the Board finds that Smurfit need not further

substantiate its claim of material prejudice.

The Board also finds that Smurfit promptly filed its public comment upon learning of this

rulemaking. The Board has had time to thoroughly consider Smurfit’s comment. Ultimately, the

Board wants the best-informed first-notice proposal it can fashion. Smurfit’s comment

represents the only active participation by industry in this rulemaking so far, besides IERG.

Moreover, when rulemaking, the Board acts in a quasi-legislative capacity, and therefore

generally allows items into the record more liberally than it does in adjudicatory proceedings.

See

Proposed Site Specific Regulation Applicable to Ameren Energy Generating Co., Elgin,

Amending 35 Ill. Adm. Code Part 901, R04-11 (June 3, 2004) (“the Board is generally more

liberal in adding to the record in a regulatory context than in an adjudicatory context”).

Lastly, Roy C. Cobb of Clayton, Missouri, attorney for Smurfit, filed and signed

Smurfit’s motion and public comment. IEPA challenges these filings as improper because they

were made by an attorney allegedly not licensed to practice law in Illinois and without a motion

to appear

pro hac vice

. However, the Board procedural requirement relied upon by IEPA, that

out-of-state attorneys must obtain Board permission to appear

pro hac vice

, is limited to

adjudicatory

proceedings.

See

35 Ill. Adm. Code 101.400(a)(3). Indeed, the Board’s procedural

rules explicitly provide that “[a]ny person may appear on behalf of himself or others in a

rulemaking proceeding.”

See

35 Ill. Adm. Code 101.400(d). Because this is a rulemaking, not

an adjudicatory proceeding, the Board finds that IEPA’s argument for barring the Smurfit public

comment because it was filed by Cobb is without merit.

Based on the above, the Board grants Smurfit’s motion and accordingly has considered

the company’s public comment in arriving at the Board’s first-notice proposal.

R04-20

IEPA Proposal

Overview

The Board’s first-notice proposal largely adopts the rule language set forth in IEPA’s

proposal. Where the Board has modified IEPA’s proposed language, the Board has done so only

for clarity and to better achieve the purposes of the rules as stated by IEPA.

IEPA’s proposal seeks to amend the Board’s air pollution rules at 35 Ill. Adm. Code 211,

218, and 219.

IEPA describes the proposed amendments as non-substantive corrections and

updates: “simply a ‘clean-up’” of current regulations that will “reduce the burden” of, and

“increase the flexibility” in, demonstrating compliance and “address minor typographical and

grammatical errors.” IEPA St. of Reas. at 1-2, 7.

According to IEPA, the proposed amendments focus on VOM emissions in the Chicago

ozone nonattainment area and Metro-East St. Louis ozone area, as designated under the federal

Clean Air Act, and as described in 35 Ill. Adm. Code 218.103 and 219.103, respectively. St. of

Reas. at 2, 6. IEPA states that any impacts to sources from its proposed amendments “will be

beneficial” because the proposal “reduces compliance burdens, clarifies terms and procedures,

and reduces recordkeeping requirements.”

. at 6.

The Board cites Smurfit’s public comment as “Smurfit PC at _.”

The Board cites the “Statement of Reasons” within IEPA’s January 6, 2004 rulemaking

proposal as “St. of Reas. at _.”

By way of background, IEPA notes that the federal Clean Air Act (42 U.S.C.

7511a(b)(1)) required all moderate, serious, severe, and extreme ozone nonattainment areas to

reduce VOM emissions 15% by 1996. St. of Reas. at 1. In Illinois, the Chicago area is classified

as a severe nonattainment area and, until recently, the Metro-East St. Louis area was classified as

a moderate ozone nonattainment area.

Accordingly, Illinois had to develop a plan to reduce

VOM emissions in the Chicago and Metro-East areas.

. In turn, Illinois, through Board

rulemaking, adopted a 15% Rate of Progress (ROP) plan. Many of the provisions at issue in this

rulemaking R04-20 were adopted as part of the 15% ROP plan.

. at 1-2.

IEPA states that its proposed R04-20 amendments are “emissions neutral” and do not

impact the overall plans or goals of the Chicago nonattainment area or Metro-East ozone area.

St. of Reas. at 2. IEPA asserts that its proposed changes will make the rules more “user friendly”

and “benefit the users without adverse economic or environmental impacts.”

. Specifically,

according to IEPA, its proposed amendments will:

•

Update the test methods for capture efficiency (CE);

•

Clarify the term “carbon adsorber”;

•

Clarify requirements for screen printers;

•

Clarify categories of sealers and topcoats;

•

Clarify provisions on monitoring, applicability, equations, recordkeeping, and reporting

for lithographic printing operations;

•

Clarify that sources may turn off their natural gas fired afterburners outside the ozone

season;

•

Delete the requirements applicable to perchloroethylene dry cleaning facilities;

•

Delete the requirement that auto finishing shops annually re-register with IEPA;

•

Delete the coating purchasing recordkeeping requirements; and

•

Correct miscellaneous grammatical and typographical errors.

Capture Efficiency (CE)

IEPA notes that CE test methods are required by the federal Clean Air Act and included

in the Chicago Federal Implementation Plan. IEPA states that measuring CE is critical to

determining the effectiveness of volatile organic compound (VOC) emission control systems.

St. of Reas. at 3.

USEPA has revoked the 1-hour ozone national ambient air quality standard (NAAQS),

effective June 15, 2005, which will result in the Chicago area being re-classified as a “moderate”

nonattainment area, based on the new 8-hour ozone NAAQS.

See

Amendments to 35 Ill. Adm.

Code 205, Emissions Reduction Market System, and 35 Ill. Adm. Code 211, R05-11 (Apr. 21,

2005).

USEPA uses the terminology “volatile organic compounds” or “VOCs.” Board rules use the

terminology “volatile organic material” or “VOM.” Both designations refer to the same matter

and can be used interchangeably for purposes of this opinion.

On January 9, 1995, USEPA issued a guidance document entitled

Guidelines for

Determining Capture Efficiency

(1995 Guidelines), which according to IEPA, “revised the

existing USEPA approved “gas/gas” and “liquid/gas” CE test methods and introduced two new

alternative CE test protocols.” St. of Reas. at 3. The next month, in February 1995, John S.

Seitz, Director, Office of Air Quality Control and Standards, USEPA, issued a memorandum

entitled

Revised Capture Efficiency Guidance for Control of Volatile Organic Compound

Emissions

(Seitz Memo) (

.), which transmitted the 1995 Guidelines to various USEPA regional

directors (Seitz Memo at 1). On June 16, 1997, USEPA published a final rule in the

Federal

Register

to update the CE test methods located in USEPA regulations at 40 C.F.R. 51, Appendix

M (62 Fed. Reg. 32500 (June 16, 1997)). St. of Reas. at 3.

The two new “alternative” CE methods are statistical “mass balance” approaches to

determining CE and are called the “Data Quality Objective” (DQO) and the “Lower Confidence

Limit” (LCL):

USEPA developed the two alternative methods in order to provide additional

regulatory flexibility and reduce compliance costs. *** These methods define

sets of approval criteria which, when met by the data obtained from the

measurement of applicable process parameters using USEPA approved

procedures and protocols, may be used to determine VOC capture system

compliance with a regulatory CE standard. St. of Reas. at 3.

The Seitz Memo generally described the DQO and LCL alternative methods:

[T]hese alternatives offer additional flexibility in that they do not require specific

testing procedures for measuring process parameters and for liquid and gas

analyses; but only specify a limited set of guidelines on the data quality. The

DQO and LCL methods are sets of approval criteria which, when met by the data

obtained with any given protocol of process parameter measurement procedures,

may be used to determine VOC capture system compliance with a CE standard.

Seitz Memo at 3.

The 1995 Guidelines described the two protocols in greater detail:

The DQO requires that the width of the 2-sided 95 percent confidence interval of

the mean measured value be less than or equal to 10 percent of the mean

measured value . . . . This ensures that 95 percent of the time, when the DQO is

met, the actual CE value will be ±5 percent of the mean measured value

(assuming that the test protocol is unbiased).

* * *

The purpose of the LCL approach is to provide sources, who may be performing

much better than their applicable regulatory requirement, a screening option by

which they can demonstrate compliance. The approach uses less precise methods

and avoids additional test runs which might otherwise be needed to meet the DQO

while still being assured of correctly demonstrating compliance. *** Because it

encourages CE performance greater than that required in exchange for reduced

compliance demonstration burden, the sources that successfully use the LCL

approach could produce emission reductions beyond allowable emissions. Thus,

it could provide additional benefits to the environment as well.

The LCL approach compares the 80 percent (2-sided) LCL for the mean measured

CE value to the applicable CE regulatory requirement. The LCL approach

requires that either the LCL be greater than or equal to the applicable CE

regulatory requirement or that the DQO is met.

* * *

[I]t is theoretically impossible to have a CE greater than 100 percent and the LCL

approach only looks at the lower end variability of the test results. This is

different from the DQO which allows average CE values up to 105 percent

because the DQO sets both upper and lower limits on test variability.] At any

point during testing when the results meet the DQO and the average CE is less

than 105 percent, the average CE can be used for demonstrating compliance with

the applicable regulatory requirement. Similarly, if the average CE is below 100

percent then the LCL can be used for demonstrating compliance with the

applicable regulatory requirement without regard to the DQO.

* * *

[For DQO or LCL, a] CE test shall consist of at least three sampling runs. Each

test run shall be at least 20 minutes long. The sampling time for each run shall

not exceed 24 hours. 1995 Guidelines at 10, 15-17, 20.

IEPA’s proposal seeks to amend Parts 218 and 219 to “add[] the option for sources to use

USEPA approved alternative CE test methods, also to be incorporated by reference” and also to

“reflect the use of USEPA revised CE testing methods which will be incorporated by reference

(and Appendix B will be deleted).” St. of Reas. at 3 (

see

Sections 218.105(c), 219.105(c),

218.112, and 219.112). IEPA states that its CE amendments also provide for “simultaneous

testing of multiple lines or emission units sharing a common control device.”

Among other miscellaneous items, IEPA proposes to replace the term “fugitive” VOM

with “uncaptured” VOM when referring to “VOM that escapes from a total temporary enclosure

or a building enclosure.” St. of Reas. at 3 (

see

Sections 218.105(c)(2)(A), (B), (C), (D) and

219.105(c)(2)(A), (B), (C), (D)). In addition, advance notice of CE testing must be given to

IEPA.

. at 3 (

see

Sections 218.105(c)(4) and 219.105(d)).

Carbon Adsorbers and Control Device Monitoring

IEPA states that industry was concerned that the term “carbon” in “carbon adsorbers”

would limit the media that could be used in adsorbers to carbon. St. of Reas. at 3. IEPA

proposes adding a definition of “carbon adsorbers,” which is based on the federally issued

Control Technique Guidelines (CTG) document, and which will “reflect the changing technology

in the field of adsorbers and the media used in them, such as aluminum and silicon oxides.”

(

see

Section 211.953). IEPA’s proposed definition “refers to adsorbers in general[,] not just

those using activated carbon as the adsorbent.”

. at 3-4. IEPA also seeks to require “a

continuous recorder on temperature monitoring devices.”

. at 4 (

see

Sections 218.105(d)(2)(B)

and 219.105(d)(2)(B)).

Screen Printers

In response to questions from industry, IEPA proposes to clarify that “screen printing on

paper falls under Subpart TT, Other Emission Units, rather than the paper coating regulations in

Subpart F.” St. of Reas. at 4 (

see

Sections 218.204(c) and 219.204(c)). IEPA also seeks to add a

definition of “screen printing on paper” to Part 211.

. (

see

Section 211.5880).

Wood Furniture

IEPA’s proposed amendments seek to clarify the descriptions for “topcoats” and

“sealers” used to coat wood furniture. Specifically, IEPA proposes language to better describe

the two categories of sealers and topcoats for purposes of applicable emission limits,

distinguishing between “acid-cured alkyd amino” and those that are not acid-cured alkyd amino.

St. of Reas. at 4 (

see

Sections 218.204(l)(2)(B) and 219.204(l)(2)(B)).

Lithographic Printing

IEPA proposes numerous changes regarding lithographic printing. First, based on

discussions with USEPA, IEPA proposes to correct the heatset web offset lithographic printing

VOM maximum theoretical emissions (MTE) equation. St. of Reas. at 4. (

see

Section

218.406(b)(l)(A)(ii) and 219.406(b)(l)(A)(ii)). Second, IEPA’s proposal seeks to amend the

required accuracy of fountain solution temperature monitors for refrigerated fountain solutions

from “0.3°C or 0.5°F” to “1°C or 2°F” because “there is not currently readily-available

equipment on the market to meet the more stringent limits.”

. (

see

Sections 218.410(a)(2) and

219.410(a)(2)). Third, IEPA proposes to add the word “lithographic” to describe printing lines

to clarify that only lithographic printing lines are to be counted in determining the number of

days of operation.

. (

see

Sections 218.411(a)(1)(B)(i) and 219.411(a)(1)(B)(i)).

Fourth, IEPA seeks to change the word “or” to “and” in Sections 218.411(d)(1) and

219.411(d)(1) to clarify that sources must have submitted a certification by March 15, 1996,

and

must submit one upon startup of any new line after that. St. of Reas. at 4-5. Fifth, IEPA’s

proposal specifies that when using an impervious substrate, such as plastic or metals, no

retention factor is used for inks in determining emissions for purposes of applicability.

. at 5

(

see

Sections 218.411(a)(1)(B)(iii) and 219.411(a)(1)(B)(iii)). Sixth, IEPA proposes to add

recordkeeping and reporting requirements for fountain solutions where the VOM is added with

automatic feed equipment—this was inadvertently left out of prior lithographic printing

rulemakings.

. (

see

Sections 218.410(b)(2), 219.411(c)(2)(D), 219.410(b)(2), and

219.411(c)(2)(D)).

Seventh, under the proposal, IEPA seeks to specify that sources may turn off their natural

gas fired afterburners outside the ozone seasons consistent with Sections 218.107 and 219.107.

St. of Reas. at 5 (

see

Sections 218.407(a)(1)(E) and 219.407(a)(1)(E)). Finally, IEPA proposes

to clarify recordkeeping and reporting language (

see

Sections 218.411(a)(1)(B)(iii) and

219.411(a)(1)(B)(iii)) and to correct typographical errors (

see

Sections 219.410 and 219.411).

Perchlorethylene Dry Cleaners

USEPA excluded perchloroethylene from the definition of VOC (61 Fed. Reg. 4588

(Feb. 7, 1996)) after determining the chemical had negligible photochemical reactivity. St. of

Reas. at 5. Based on this USEPA action, the Board, as required by Section 9.1(e) of the Act (415

ILCS 5/9.1(e) (2002)), excluded perchloroethylene from the definition of VOM in the Board’s

air pollution regulations.

. (

see

R96-16 and 21 Ill. Reg. 2461 (Feb. 6, 1997)). Because of these

regulatory actions, IEPA now proposes to repeal provisions of Parts 218 and 219 that regulate

the use of VOM at perchloroethylene dry cleaning facilities.

. (

see

Sections 218.601, 218.602,

218.603, 219.601, 219.602, and 219.603).

IEPA states that its 1990 baseline inventory for VOM was corrected in 1993 to reflect the

anticipated exclusion of perchloroethylene from the definition of VOM. St. of Reas. at 5. IEPA

therefore reasons that the perchlorethylene exemption from VOM will not affect any efforts by

IEPA to achieve the national ambient air quality standards (NAAQS) in the Chicago ozone

nonattainment area.

. IEPA adds that perchloroethylene continues to be regulated as a

hazardous air pollutant under Section 112 of the federal Clean Air Act (42 U.S.C. § 7412), and

that USEPA issued a national emission standard for hazardous air pollutants (NESHAP) for

perchloroethylene dry cleaners in 1993 (58 Fed. Reg. 49354 (Sept. 22, 1993)).

. IEPA, as the

delegated authority, implements this perchloroethylene NESHAP.

Motor Vehicle Refinishing

IEPA seeks to eliminate the requirement that all motor vehicle refinishing shops must

annually re-register with IEPA. IEPA maintains that the requirement “serves no useful purpose

and provides an unnecessary burden on regulated sources and on [IEPA].” St. of Reas. at 5.

IEPA also proposes to remove as unnecessary certain recordkeeping requirements

currently applicable to motor vehicle refinishing facilities. St. of Reas. at 5. IEPA states that the

federal rule limits the VOM content of coatings being

manufactured

to the same level the

Board’s rule limits the VOM content of coatings being

used

. at 5-6. According to IEPA

therefore, “the only coatings that should be available for purchase and for resale should

necessarily comply with the Illinois coating usage limits.”

. at 6. IEPA accordingly seeks to

eliminate requirements for tracking coating purchases (

see

Sections 218.790 and 219.790) and

notes that USEPA has approved rule amendments in other states striking these requirements.

Miscellaneous

IEPA’s proposal “corrects numerous typographical errors, grammatical mistakes, and

other minor inconsistencies,” which “should have no quantifiable effect on sources.” St. of Reas.

at 6. These changes occur throughout the sections cited above, plus Sections 218.112(d), (e), (f),

(h), (i), 218.405, and 219.405.

Testimony, Public Comments, Board Analysis

Testimony and public comments on IEPA’s proposal concentrated on two areas of

disagreement among the participants in this rulemaking: (1) the definition of “carbon adsorber”;

and (2) the use of the “alternative” CE protocols. Below the Board discusses the issues contested

in these two areas and the Board’s findings and conclusions for first notice. The Board also

discusses IEPA’s proposed definition of “screen printing on paper.”

“Carbon Adsorber” Definition

As set forth in IEPA’s original proposal, a definition of “carbon adsorber” would be

added to the Part 211 regulations at Section 211.953 and would read as follows:

Carbon Adsorber. A control device designed to remove and, if desired, recover

volatile organic material (VOM) from process emissions. Removal of VOM is

accomplished through the adherence of the VOM onto the surface of highly

porous adsorbent particles such as activated carbon. The term “carbon adsorber”

describes any adsorber technology used as a control device even though media

other than carbon may be used as the adsorbent, such as (but not limited to)

oxides of silicon and aluminum.

IERG states that the first sentence of this definition is too broad because it “would

encompass many more control devices than carbon adsorbers, including condensers, flares,

oxidizers,

etc

.” IERG PC at 5;

see also

Tr.2 at 35-36. According to IERG, the second sentence

of the definition “properly restricts the intent of the definition.” IERG PC at 5. IERG therefore

proposes that the first and second sentences of IEPA’s proposed definition be joined and

modified as follows: “. . . process emissions,. via rRemoval of VOM is accomplished through

the adherence . . . .”

. at 5-6.

In its public comment, IEPA recognizes IERG’s concern about the first sentence of the

definition being too inclusive. In response, IEPA also suggests combining the first two sentences

into one sentence, but by simply by replacing the period at the end of the first sentence with a

semi-colon, which would “make the definition more specific to the general technology of

adsorption that is being defined.” IEPA PC at 2.

The Board agrees with IERG that the first sentence of IEPA’s originally-proposed

definition of “carbon adsorber” is overbroad. IERG’s suggested “via removal” language,

however, is confusing because it would modify not only VOM removal but also recovery in the

definition. The Board believes that IEPA’s suggestion is closer to the mark, but that replacing

the period between the first and second sentences with the word “where” is more

straightforward. Accordingly, the Board proposes that the first sentence of the definition read as

follows:

“Carbon Adsorber” means a control device designed to remove and, if desired,

recover volatile organic material (VOM) from process emissions where removal

of VOM is accomplished through the adherence of the VOM onto the surface of

highly porous adsorbent particles, such as activated carbon.

IERG is also concerned that the term “carbon adsorber” is misleading, given that the last

sentence of IEPA’s proposed definition would include media in addition to carbon, such as

oxides of silicon and aluminum. IERG PC at 6;

see also

Tr.2 at 36-37. IERG states that it

appreciates IEPA’s desire to encompass all relevant media. However, according to IERG,

IEPA’s proposed definition could be “deceptive as to the types of devices covered.”

. IERG

notes that the term “carbon adsorber” is used throughout Parts 218 and 219 to impose substantive

requirements, and “wonders whether sources, reviewing monitoring requirements for ‘carbon

adsorbers’ in Subparts Q, T, and V, would understand that such requirements would also extend

to adsorbers with media containing oxides of silica and aluminum.”

. IERG therefore asks

that if IEPA “insists upon expanding the adsorber definition, the title of the definition should be

changed to more generally represent the media covered by the definition,” even though “this may

involve revising uses of the term ‘carbon adsorber’ in other subparts.”

. at 6-7.

In response, IEPA notes that the term “carbon adsorber” appears throughout Title 35 of

the Illinois Administrative Code and that “separating or altering this basic terminology could

have far reaching and unforeseen ramifications for the Illinois pollution control regulations.”

IEPA PC at 2. IEPA notes that carbon has been the “predominant media” for removing VOM

from process emissions by adsorption.

. at 3. Because of this, IEPA continues, the term

“carbon adsorber” has “become accepted as synonymous with adsorber control technology in

general, wherein VOM adheres to the surface of a porous adsorbent particle regardless of the

particle’s composition.”

IEPA explains that other materials have recently been introduced claiming to be a more

efficient adsorbent than carbon, though the “physical capturing of the VOM is the same basic

process.” IEPA PC at 3. IEPA states that these new materials include oxides of silicon and

aluminum in the form of “molecular sieves with engineered openings designed to adsorb

particular sizes of VOM molecules.”

. IEPA reports, however, from its enforcement

experience, that manufacturers of these new adsorbent materials maintain that “monitoring such

devices pursuant to the requirements of Sections 218.105(d) and 219.105(d) is not required

because these Sections refer only to ‘carbon’ adsorbers and not any other adsorber.”

Through its proposed definition, IEPA seeks to “close that unforeseen loop hole” without

causing any “undesired regulatory repercussions” that might arise from changing the term

throughout Title 35.

IEPA further argues that although a “casual reader” could misinterpret the term as

proposed, this should not be the case with “users of the rule.” St. of Reas. at 4. IEPA believes

that this approach is the best way to “keep the playing field level for all types of adsorbers and

the various media that might be used as the [adsorbent] in these control devices, now and in the

future.”

The Board understands IERG’s concern, but agrees with IEPA and will propose for first

notice the defined term “carbon adsorber.” Not only is this term commonly understood to refer

to adsorbent technology generally, but now the term will be defined explicitly to include these

other media.

Compare

35 Ill. Adm. Code 211. 4470 (definition of “paper coating” refers not

only to coatings applied to paper, but also to plastic film and metallic foil). Additionally, the

Board notes that the term “carbon adsorber” is not just used in other Suparts of Parts 218 and 219

that are not open in this rulemaking, but also in other Parts of Title 35, such as Part 215, none of

which are open in this rulemaking.

In the interest of proceeding most efficiently with this rulemaking, the Board declines to

expand IEPA’s proposal to include such a large number of additional regulatory provisions in an

effort to amend the term “carbon adsorber.” The Board, however, encourages IEPA to assess

whether this definitional solution works as intended when the rule is implemented. If it does not

work, the Board would invite IEPA to propose an omnimbus rulemaking to replace the term

“carbon adsorber” throughout Title 35 with a term more accurate on its face. As proposed for

first notice then, the definition of “carbon adsorber” at Section 211.953 reads in its entirety as

follows:

“Carbon Adsorber” means a control device designed to remove and, if desired,

recover volatile organic material (VOM) from process emissions where removal

of VOM is accomplished through the adherence of the VOM onto the surface of

highly porous adsorbent particles, such as activated carbon. The term “carbon

adsorber” describes any adsorber technology used as a control device even though

media other than carbon may be used as the adsorbent, such as oxides of silicon

and aluminum.

“Alternative” CE Protocols

Background.

Industry participants disagreed with IEPA’s proposed language amending

subsections (c)(2) of Sections 218.105 and 219.105 to add “alternative” CE protocols. Part 218

applies to VOM emissions from stationary sources in the Chicago ozone nonattainment area,

while Part 219 applies to VOM emissions from stationary sources in the Metro-East ozone area.

Parts 218 and 219 are nearly identical, as are IEPA proposed amendments to the respective Parts.

When the Board refers in this opinion to a provision of Part 218, it is also referring to that

provision in Part 219, and

vice versa

Subsections (c)(2) of Sections 218.105 and 219.105 currently set forth the “standard” CE

protocols (in subsections (c)(2)(A), (B), (C), and (D)). The “alternative” CE protocols refer to

the proposed DQO and LCL statistical analysis methodologies. Under IEPA’s proposal, the

DQO/LCL method would appear in a new subsection (c)(2)(E). As discussed, USEPA in 1995

allowed these “alternatives” to the “standard” CE protocols of gas/gas and liquid/gas.

Subsections (c)(1) of Sections 218.105 and 219.105 state that the requirements of the

respective subsections (c)(2) (

i.e.

, the capture efficiency test protocols) apply to all VOM-

emitting process emission units employing capture equipment (

e.g.

, hoods, ducts), except in a

few cases, such as when an emission unit is equipped with or uses a permanent total enclosure

(PTE) that directs all VOM to a control device.

See

35 Ill. Adm. Code 218.105(c)(1)(A),

219.105(c)(1)(A). Other than these exceptions, the capture efficiency of an emission unit must

be measured using one of the CE protocols in subsection (c)(2). Subsection (c)(2) currently

provides the four “standard” CE protocols: (1) gas/gas method using a temporary total enclosure

(TTE); (2) liquid/gas method using TTE; (3) gas/gas method using the building or room

enclosure in which the affected emission unit is located; and (4) liquid/gas method or room

enclosure in which the affected emission unit is located.

See

35 Ill. Adm. Code

218.105(c)(2)(A), (B), (C), (D), 219.105(c)(2)(A), (B), (C), (D).

IEPA is now seeking to add the two USEPA-approved “alternative” CE protocols: DQO

and LCL, referred to sometimes as the DQO/LCL protocol. The DQO and LCL methods are

statistical “mass balance” approaches for determining CE. Beckstead of IEPA testified that the

DQO and LCL protocols “use a process parameter measuring it repeatedly to a confidence

level.” Tr.1 at 10; Tr.2 at 27. IEPA states that satisfying the DQO yields a result accurate to a

95% confidence level, and satisfying the LCL yields a result accurate to a 90% confidence level.

IEPA PC at 4, 5; Tr.1 at 10.

Regarding cost savings over the “standard” CE protocols, Beckstead testified that

because DQO/LCL “eliminates the need to construct or to test for total enclosure, cost savings

can be substantial.” Tr.2 at 11, 27-28. Among enclosures for the standard CE protocols,

building a TTE is the “most expensive,” but exact cost estimates would vary depending upon

such factors as the size of the structure, the materials used, and labor.

. at 10-12. Based on

IEPA field experience and costs, a general estimate for a TTE ranges from $12,500 to $50,000.

. at 12. According to Beckstead, if there is a “low degree of variability in the process

parameter that is being measured to determine capture efficiency, and the DQO/LCL criteria is

satisfied in the minimum of three [test] runs, optimal savings will result.” Tr. 2 at 11. These

savings, however, will diminish if there is a high degree of variability in the measured parameter

and more test runs are necessary before the DQO/LCL statistical criteria is satisfied.

Beckstead estimated that the cost of test runs ranges from $4,250 to $8,750 per run.

. at 13, 29.

As amended in IEPA’s

errata

sheet, IEPA proposed that Section 218.105(c)(2) read as

follows:

2) Capture Efficiency Protocols Specific Requirements

The capture efficiency of an emission unit shall be measured using

one of the four protocols given below. Appropriate test methods to

be utilized in each of the capture efficiency protocols are described

in Appendix M of 40 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 of a capture

efficiency test. If these techniques are not suitable for a particular

process, then an alternative capture efficiency protocol may be

used, pursuant to the provisions of Section 218.108(b) of this Part

provided that the alternative protocol is approved by the Agency

and approved by the USEPA as a SIP revision. For purposes of

determining 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 of this

Part. LCL can be used to establish compliance with capture

efficiency requirements. For purposes of establishing emission

credits for offsets, shutdowns, trading, and compliance

demonstrations arising in enforcement matters, the DQO must be

satisfied. Exh. 2 at 2.

IERG’s Comments.

IERG states that it supports “the proposal’s efforts to provide less

burdensome alternatives to the task of establishing capture efficiency.” IERG PC at 2.

However, IERG takes exception to the last sentence of IEPA’s proposed Section 218.105(c)(2),

quoted above. IERG has two main concerns. First, IERG is concerned with the IEPA language

“that requires meeting the DQO in order to establish emission credits for offsets, shutdowns and

trading.” IERG PC at 3. Specifically, according to IERG, IEPA testimony confirmed that

satisfying DQO to establish emission credits for offsets, shutdowns, and trading “necessarily

requires that physical testing occur before those credits can be granted by [IEPA].”

. (relying

on Tr.2 at 29). IERG interpreted the testimony of IEPA’s Beckstead as standing for the

proposition that “where a source has used DQO or LCL to establish its emissions and capture

efficiency, DQO criteria would have to be satisfied in order to establish emission credits.”

(relying on Tr.2 at 31).

IERG provides a hypothetical to illustrate its concern with IEPA’s “apparent approach”:

[A] unit that, when originally permitted, was required to establish capture

efficiency via testing, and the testing was conducted according to the DQO. For

years afterward, the source would report actual emissions based upon the capture

efficiency results from the original testing. Now, testing would again have to be

conducted when the unit is shut down to establish emission credits, without regard

for how historical emissions had been calculated and reported. IERG PC. at 4.

IERG believes that “such additional testing at the time of shutdown has not been uniformly

required in the past and is even inconsistent with historical practice.”

.; Tr.2 at 30-31.

According to IERG, the VOM Emission Reduction Market System (ERMS) regulations, for

example, do not include testing among the requirements for demonstrating emission reductions.

. (citing 35 Ill. Adm. Code 205.500(d)).

IERG argues that it is “unnecessary and confusing” to refer in Parts 218 and 219 to

requirements for establishing emission credits, because those Parts are “focused on setting

emission limits and standards.” IERG PC at 4. IERG asserts that it would be better to “let the

issues concerning emission credits remain within the regulatory Parts that deal specifically with

those issues.”

As for IERG’s second concern with the last sentence of IEPA’s proposed Section

218.105(c)(2), according to IERG, Beckstead of IEPA testified that the “onus is on the source to

demonstrate, in an enforcement case, . . . that they are in compliance. They would have to do so

to the DQO level.” IERG PC at 4 (quoting Tr.2 at 18, 19). IERG is concerned that this

testimony suggests an improper shift of the “burden of proof” to the respondent source in an

enforcement case. IERG notes that in IEPA’s original proposal, the language simply provided:

“In enforcement cases, LCL can not be used to establish non-compliance; sufficient tests must be

performed to satisfy the DQO.”

. Under IERG’s questioning, Beckstead added that the

complainant in an enforcement action would also have to prove the respondent source’s

noncompliance to the DQO level, and that the LCL would not be sufficient in that situation.

at 3;

see

also

Tr.2 at 33-34.

Based on these comments concerning emission credits and enforcement, IERG proposes

deleting the last sentence of Section 218.105(c)(2) in IEPA’s

errata

and replacing it as follows:

For purposes 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 noncompliance as sufficient tests must be performed to satisfy

the DQO. IERG at 5.

Smurfit’s Comments.

Smurfit also disagreed with IEPA’s proposed “alternative” CE

language in subsections (c)(2) of Sections 218.105 and 219.105. According to its public

comment, Smurfit and its affiliates operate 20 industrial facilities in Illinois, including two in the

Chicago area that use solvent-based printing and coating materials and control devices to reduce

VOM emissions. Smurfit PC at 1. The Chicago area facilities are a folding carton plant in Carol

Stream and a flexible packaging plant in Schaumburg. Smurfit states that it is “directly affected

by the capture-efficiency testing portion of the proposed rulemaking.”

Smurfit states that it “strongly supports amending the Illinois rules to allow full use of all

capture efficiency test protocols and methods already approved by U.S. EPA.” Smurfit PC at 3.

However, Smurfit believes that aspects of IEPA’s CE proposal are “inappropriate and might

have a substantial adverse impact on regulated facilities.”

Smurfit discusses USEPA’s 1995 Guidelines, which is one of the documents IEPA

proposes for incorporation by reference in the Board’s rules. Smurfit PC at 3. According to

Smurfit, the 1995 Guidelines include “alternative” protocols for CE testing “without a total

enclosure if the collected data meets either one of two statistical tests,”

i.e.

, the DQO or the LCL.

. at 3-4. Smurfit states that the DQO requires that both the upper and lower 95% confidence

limits be within 0.95 and 1.05 times the measured average CE. A CE test meeting the DQO,

Smurfit asserts, can be used “for all purposes, including demonstrating noncompliance (if the

measured DQO capture efficiency is less than that required by the applicable rule or permit

condition) and establishing emission credits.”

. at 4.

According to Smurfit, the LCL, as the name suggests, is used to establish a “lower bound

that is likely below the actual capture efficiency.” Smurfit PC at 4. For support, Smurfit quotes

from the Seitz Memo, which transmitted the 1995 Guidelines. The Board sets forth the entire

passage from the Seitz Memo for clarity, portions of which Smurfit quotes:

For the purpose of CE testing to determine compliance with VOC Reasonably

Available Control Technology (RACT) requirements, any of the CE testing

methods described in the attached document [which includes the LCL] are

acceptable to [US]EPA. Such testing includes initial compliance certification,

enforcement actions where noncompliance is suspected, and periodic testing as

may be required pursuant to [US]EPA’s enhanced monitoring rules. The LCL

should not be used, however, for enforcement purposes to confirm

noncompliance; sufficient test runs should be run to meet the DQO protocol.

* * *

In those situations where CE testing is done to determine emission reductions for

the purposes of establishing emission credits for offsets, shutdowns, and trading,

the LCL method is not appropriate for these applications. Sources who have used

the LCL method for CE compliance determinations, however, may use their same

testing procedures and perform sufficient test runs to meet the requirements of the

DQO method. Seitz Memo at 3; Smurfit PC at 4-5.

According to Smurfit, the reason the Seitz Memo limits using the LCL for enforcement

and establishing emissions credits is “quite clear” considering the very nature of the LCL:

[T]he LCL is the “lower confidence limit,” a capture efficiency that is a multiple

of the standard deviation below the average measured value. In other words,

there is little likelihood that the actual capture efficiency is lower than the LCL

and a very significant likelihood that it is higher. Since the LCL is the lower

bound for capture efficiency, by definition, an LCL higher than the required

capture efficiency demonstrates compliance, but an LCL lower than the required

capture efficiency does not demonstrate non-compliance. Similarly, Smurfit

believes the meaning of the last quoted sentence in the Seitz memo is to advise

that the baseline emissions for determining emission credits should not be based

on the LCL since this would overstate the baseline emissions and therefore give

the facility emission credits above what it should obtain. *** However, once the

baseline has been established, there is no reason why the facility should not be

able to use the LCL capture efficiency to determine its actual ERMS seasonal

emissions, especially since use of the LCL capture efficiency will overstate the

VOM emissions that must be accounted for. Smurfit PC at 5.

Restated, Smurfit argues that because the actual CE is very likely to be higher than the

LCL, a calculated LCL above the required CE is sufficient to demonstrate compliance.

However, a calculated LCL below the required CE does not demonstrate non-compliance

“because the LCL is merely the lower bound for capture efficiency.” Smurfit PC at 5.

As for IEPA’s proposed rule language on enforcement in subsection (c)(2), Smurfit

believes that “what constitutes ‘credible evidence’ of compliance or a violation should not be

addressed in this rulemaking.” Smurfit PC at 5, n.2. Smurfit argues that in some circumstances,

for example, “if there were three or more valid test runs, all of which were below the required

capture efficiency, the results might provide some credible evidence of a violation even though

the DQO was not met.”

. Likewise, Smurfit continues, an LCL lower than the required CE

“might provide credible evidence of compliance.”

. Smurfit further argues that IEPA

testimony indicating that the burden is on the source in an enforcement proceeding to

demonstrate compliance would be a “reversal of the normal burden of proof and certainly should

not be the basis for accepting the DQO language proposed by Illinois EPA.”

As for IEPA’s proposed rule language in subsection (c)(2) requiring either the DQO or

total enclosure testing for “establishing” emission credits for offsets, shutdowns, and trading,

Smurfit states that the language is consistent with the meaning of the LCL

the language is

limited to establishing a “baseline.” Smurfit PC at 7. Smurfit maintains, however, that IEPA’s

interpretation

of the related portion of the Seitz Memo regarding permissible uses of the LCL is

unduly restrictive. Smurfit states that IEPA’s position “outside the rulemaking” is that IEPA’s

proposed language would prohibit a source from using the LCL to determine its actual seasonal

emissions.

. Smurfit does not believe that a “plain reading” of IEPA’s proposed language

supports this purported IEPA position, but Smurfit argues that “such possible misinterpretations

support the recommendation of [IERG] and Smurfit . . . that most of the proposed language

relating to the use of the DQO and LCL be deleted.”

Smurfit states that it strongly supports giving IEPA and facilities in Illinois the “widest

range of methods to demonstrate capture efficiency without case-by-case SIP revisions.”

Smurfit PC at 7. Smurfit proposes the following changes to the language IEPA offered in its

errata

sheet for Section 218.105(c)(2):

2) Capture Efficiency Protocols

The capture efficiency of an emission unit shall be measured using

one of the protocols given referenced below. Appropriate test

methods to be utilized in each of the capture efficiency protocols

are described in Appendix M of 40 CFR Part 51 and in USEPA’s

“Guidelines for Determining Capture Efficiency” incorporated by

reference at Section 218.112. Any error margin associated with a

test method or protocol may not be incorporated into the results of

a capture efficiency test. If these techniques are not suitable for a

particular process or equipment configuration, then an alternative

capture efficiency protocol may be used, pursuant to the provisions

of Section 218.108(b) of this Part. For purposes of determining

capture efficiency using an alternative protocol in USEPA’s

“Guidelines for Determining Capture Efficiency,” but not in

Appendix M to 40 CFR Part 51, sources shall satisfy the data

quality objective (DQO) or the lower confidence level limit (LCL)

statistical analysis methodologies as presented in USEPA’s

“Guidelines for Determining Capture Efficiency” incorporated by

reference at Section 218.112 of this Part. LCL can be used to

establish compliance with capture efficiency requirements. For

purposes of establishing emission credits for offsets, shutdowns,

trading, and compliance demonstrations arising in enforcement

matters, the DQO must be satisfied.

. at 7.

Smurfit states that its purpose in suggesting these changes is two-fold. First, Smurfit

seeks to place the LCL and DQO on “equal footing” with those protocols that do use temporary

or permanent total enclosures. Smurfit PC at 8. According to Smurfit, “[t]here should be no

burden on a facility to prove that a temporary or permanent total enclosure is ‘unsuitable’ before

it can use another USEPA-approved method.”

. Second, Smurfit wishes to eliminate

statements delineating specifically when a particular test method can and cannot be used.

Smurfit argues that such statements “go beyond the announced scope of this rulemaking, which

is to incorporate those protocols already approved by U.S. EPA into Illinois rules by reference.”

. According to Smurfit, such statements are too easily misinterpreted.

IEPA’s Comments.

In its public comment, IEPA attempts to respond to the concerns

raised over its proposed “alternative” CE language in subsections (c)(2) of Sections 218.105 and

219.105. IEPA notes by way of background that USEPA determined that the standard gas/gas

and liquid/gas protocols are the most accurate and reliable methods for determining capture

efficiency. IEPA PC at 4; Tr.1 at 10; Tr.2 at 26. According to IEPA, these standard CE methods

can be very expensive, especially for building temporary total enclosures. Tr.1 at 10. IEPA

explains that in response to industry requests for less costly ways of determining CE, the

DQO/LCL alternative protocol was offered by USEPA. IEPA PC at 4; Tr.1 at 10; Tr.2 at 26-27.

USEPA considered the DQO/LCL alternative methodology acceptable. IEPA PC at 4, 5; Tr.1 at

10; Tr.2 at 27. In this rulemaking, IEPA seeks to provide this alternative protocol “at the

insistence of U.S.EPA and as a courtesy to the regulated community.” IEPA PC at 4, 5.

IEPA emphasizes that the DQO/LCL protocol “is not an added layer of testing” and that

it “need not ever be used,” but that “if a source chooses to use the LCL/DQO alternative

protocol, there are certain requirements that must be met.” IEPA PC at 4, 5. For example, “if

credits for offsets, shutdowns, or trading are being established based on data arrived at from

using the alternative protocol, the DQO must be satisfied.”

. at 4. IEPA states that satisfying

the DQO yields a result accurate to a 95% confidence level, but satisfying the LCL yields a result

accurate to only a 90% confidence level.

.; Tr.1 at 10. IEPA states that USEPA considered the

higher DQO confidence level to be necessary when establishing emission credits for offsets,

shutdowns, and trading and in enforcement. IEPA PC at 4-5; Tr.1 at 10-11, 13-14.

Based on these observations, IEPA proposes in its public comment to amend its

errata

sheet version of Section 218.105(c)(2) to read as follows (here showing changes to the IEPA

errata

sheet quoted above):

2) Capture Efficiency Protocols

The capture efficiency of an emission unit shall be measured using

one of the protocols given below. Appropriate test methods to be

utilized in each of the capture efficiency protocols are described in

Appendix M of 40 CFR Part 51, incorporated by reference at

Section 218.112. Any error margin associated with a test method

or protocol may not be incorporated into the results of a capture

efficiency test. If these techniques are not suitable for a particular

process, then an alternative capture efficiency protocol may be

used, pursuant to the provisions of Section 218.108(b) of this Part.

For purposes of determining 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 of this Part. LCL can be used to establish

compliance with capture efficiency requirements. For purposes of

establishing emission credits for offsets, shutdowns, trading, and

compliance demonstrations arising in enforcement matters, the

DQO must be satisfied.

If a sources [sic] chooses to use the LCL/DQO alternative

methodology, failure to satisfy the DQO in matters of enforcement

or for establishing credits for offsets, shutdowns, or trading shall

require capture efficiency to be determined using one of the

gas/gas or liquid/gas protocols described in subsections (c)(2)(A),

(B), (C), or (D). IEPA PC at 5-6.

IEPA concludes that this proposed language (

i.e.

, subsection (c)(2)) “should resolve

issues regarding proving compliance. The source that chooses the LCL/DQO alternative

methodology [

i.e.

, under subsection (c)(2)(E)] must satisfy DQO or test under one of the

standard protocols [

i.e.

, under subsection (c)(2)(A), (B), (C), or (D)].” IEPA PC at 7. As just

noted, IEPA’s proposed new subsection (c)(2)(E) sets forth the “alternative” CE protocol of

DQO/LCL. That subsection (

i.e.

, proposed Section 218.105(c)(2)(E)), in IEPA’s original

proposal as modified by its

errata

sheet, reads as follows:

E) 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 of 40 CFR Part 51, the

VOM content of the liquid input (L) shall be determined

using Method 204A or 204F in Appendix M of 40 CFR

Part 51. The VOM content of the captured gas stream (G)

to the control device shall be determined using either

Method 204B or 204C in Appendix M of 40 CFR Part 51.

The results of capture 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

Guidelines for Determining Capture Efficiency

incorporated by reference at 218.112 of this Part. Failure to

satisfy the DQO shall require capture efficiency to be

determined using one of the protocols described in

subsection (c)(2)(A), (B), (C), or (D) above. Exh. 2 at 1.

Board Analysis.

Initially, the Board notes that it makes no comment in this rulemaking

record on Smurfit’s described enforcement matters or other alleged IEPA positions taken

regarding Smurfit’s operations.

As for this rulemaking, the Board notes that IEPA proposes to add language to existing

subsection (c)(2) of Sections 218.105 and 219.105 that would spell out when the DQO/LCL

protocol can be used. For that matter, IERG likewise seeks to use subsection (c)(2) for that

purpose, but with different language. The Board finds that subsection (c)(2), however, merely

introduces the subject of measuring the CE of emission units pursuant to protocols described in

subsequent

subsections,

i.e.

, (c)(2)(A), (B), (C), (D), (E). Subsection (c)(2) does not currently,

and need not, contain language delving into the particulars of any specific protocol—that task is

best left to the subsequent subsections, which address each protocol specifically.

The Board also finds it redundant to state in subsection (c)(2) that the LCL can be used to

demonstrate compliance—that much is plain from subsection (c)(2)(E), which enumerates LCL

among the acceptable protocols, and from subsection (c)(2), which states: “The capture

efficiency of an emission unit shall be measured using one of the protocols given below.”

Accordingly, for first notice, the Board removes from IEPA’s proposed subsection (c)(2) the

detailed language regarding the use of DQO/LCL—and places language on the use of DQO/LCL

in the DQO/LCL provision,

i.e.

, subsection (c)(2)(E).

See

Tr.1 at 21-22.

The Board further finds that IEPA’s proposed enforcement language in subsection (c)(2)

suggests an improper shift in the burden of proof to respondent in an enforcement action.

IEPA’s proposed language reads: “For purposes of . . . compliance demonstrations arising in

enforcement matters, the DQO must be satisfied.” This language indicates that a respondent has

the burden to prove it is in compliance. In an enforcement action, however, it is the

complainant

that has the burden of proving the respondent is

not

in compliance. See 415 ILCS 5/31(e)

(2002). This problem is only exacerbated by the language IEPA proposes in its public comment

to add to subsection (c)(2):

If a sources [sic] chooses to use the LCL/DQO alternative methodology, failure to

satisfy the DQO in matters of enforcement . . . shall require capture efficiency to

be determined using one of the gas/gas or liquid/gas protocols described in

subsections (c)(2)(A), (B), (C), or (D). IEPA PC at 6.

There remains the question, however, of whether the rules themselves should specify the

applicability of DQO and LCL

at all

regarding emission credits and enforcement. The Board

finds that they should. Specifying the applicability of the DQO/LCL is well within the scope of

this rulemaking, and failing to do so could have negative repercussions. USEPA has issued

specific guidance on these very issues in the Seitz Memo. If the Board rule does not address the

use of the LCL consistent with the Seitz Memo, Illinois’ program may run the risk of being

considered inconsistent with and less stringent than the federal requirement. That may

jeopardize getting USEPA approval of Illinois’ implementation plan amendments, and may run

afoul of the General Assembly’s purpose articulated in the Act’s Section 9.1 to “avoid the

existence of duplicative, overlapping or conflicting State and federal regulatory systems.” 415

ILCS 5/9.1(a) (2002).

Moreover, the issue of the proper CE protocol could arise in the permit application

process. When IEPA denies a permit application, IEPA must identify which provision of the Act

or Board regulations would be violated if the requested permit issued.

See

415 ILCS 5/39, 39.5

(2002). The IEPA denial letter frames the issues in a permit appeal before the Board.

See

Panhandle Eastern Pipeline Co. v. IEPA, PCB 98-102 (Jan. 21, 1999). If the Board rule is silent

on CE applicability, IEPA would have no regulatory provision to point to in its permit denial

letter. Resolving the applicability issue therefore is not best left solely to the appeal process.

As evidenced in the record of this rulemaking, the potential for disagreement over

DQO/LCL applicability is high. The Board finds that the most prudent path is to track, explicitly

in the rule section on DQO/LCL, the USEPA language from the Seitz Memo as closely as

possible. This should help to ensure the Board rule is consistent with USEPA’s intent and to

most effectively put the regulated community on notice as to the limits on using LCL. This is

reinforced through the proposed incorporation of the Seitz Memo by reference, which neither

IERG nor Smurfit oppose.

See

Sections 218.112(bb), 219112(z); Tr.1 at 25-26. Therefore, for

first notice, the Board’s subsection (c)(2)(E) states:

Where capture efficiency testing is done to determine emission reductions for the

purpose of establishing emission credits for offsets, shutdowns, and trading, the

LCL protocol cannot be used for these applications. In enforcement cases, the

LCL protocol cannot confirm non-compliance.

The Board agrees with Smurfit that the LCL will tend to understate the actual CE.

Accordingly, a calculated LCL that meets or exceeds the required CE can be used to demonstrate

compliance, but a calculated LCL below the required CE cannot alone demonstrate non-

compliance with the required CE. The Board’s proposed language does not preclude introducing

LCL results as evidence in an enforcement action—if otherwise admissible, the Board can decide

what weight, if any, to give such evidence. The enforcement language does, however, make

clear that LCL results alone do not prove a CE violation.

As for the language on “establishing” emission credits for offsets, shutdowns, and

trading, the Board directs IEPA to specifically address Smurfit’s contention that the LCL could

be used to calculate actual seasonal emissions, just not the baseline for ERMS. The Board

further directs IEPA to specifically address IERG’s concerns over whether and when

additional

testing would be required. The Board strongly urges all of the participants to help develop a

clearer record in this rulemaking on these issues, but recognizes that some disputes over

interpretation may ultimately be resolved best on a case-by-case basis in adjudicatory matters

before the Board.

The Board agrees with Smurfit’s sentiment that the DQO/LCL should be on “equal

footing” with the standard (enclosure) protocols,

i.e.

, that DQO/LCL should be available without

the source having to first demonstrate that all standard protocols are “unsuitable.” The Board

believes, however, that Smurfit misconstrues IEPA’s proposed language. Test methods that may

be used for DQO/LCL

are

in 40 C.F.R. 51, Appendix M.

See

1995 Guidelines at 10; Section

218.105(c)(2)(E). Accordingly, IEPA’s reference to that C.F.R. provision is not meant to

exclude DQO/LCL. Smurfit offers no explanation for its other suggested changes to subsection

(c)(2), so the Board declines to make them.

At first notice, therefore, the Board has removed the extensive discussion of when the

DQO/LCL can and cannot be used from subsection (c)(2). Instead, the Board has addressed the

subject in subsection (c)(2)(E), the subsection on the DQO/LCL protocol. The Board agrees

with Smurfit that these “alternative” protocols (DQO and LCL), now adopted by USEPA, should

be on the same footing as the existing “standard” protocols, with the noted exceptions limiting

the use of the LCL. To refer to DQO/LCL as an “alternative,” as IEPA proposes, even though

the protocol will be codified and not require case-by-case approval for use, risks confusing it

with this subsection (c)(2) language: “alternative capture efficiency protocol may be used,

pursuant to the provisions of Section 218.108(b).” The Section 218.108(b) process is one by

which

other

protocols (

i.e.

, other than the codified enclosure and DQO/LCL protocols) may be

proposed and approved on a case-by-case basis.

IEPA’s proposed subsection (c)(2)(E) also states: “Failure to satisfy the DQO shall

require capture efficiency to be determined using one of the protocols described in subsection

(c)(2)(A), (B), (C), or (D) above.” This language is potentially misleading because the LCL can

be used to demonstrate compliance,

i.e.

, failure to satisfy DQO does not

necessarily

require an

enclosure—the LCL can be used. It is also readily evident from subsection (c)(2) that if one of

the CE protocols, say subsection (c)(2)(E), cannot be met, another protocol,

i.e.

, (A), (B), (C), or

(D), must be satisfied absent approval of an alternative under Section 218.108(b).

The Board therefore proposes the following as Sections 218.105(c)(2) and

218.105(c)(2)(E) for first notice:

2) Capture Efficiency Protocols Specific Requirements

The capture efficiency of an emission unit shall be measured using

one of the four protocols given below. Appropriate test methods to

be utilized in each of the capture efficiency protocols are described

in Appendix M of 40 CFR Part 51, incorporated by reference at

Section 218.112 of this Part. Any error margin associated with a

test method or protocol may not be incorporated into the results of

a capture efficiency test. If these techniques are not suitable for a

particular process, then an alternative capture efficiency protocol

may be used, pursuant to the provisions of Section 218.108(b) of

this Part provided that the alternative protocol is approved by the

Agency and approved by the USEPA as a SIP revision.

* * *

E) Mass balance using Data Quality Objective (DQO) or

Lower Confidence Limit (LCL) protocol. For a liquid/gas

input where an owner or operator is using the DQO/LCL

protocol and not using an enclosure as described in Method

204 of Appendix M of 40 CFR Part 51, incorporated by

reference in Section 218.112 of this Part, the VOM content

of the liquid input (L) must be determined using Method

204A or 204F in Appendix M of 40 CFR Part 51. The

VOM content of the captured gas stream (G) to the control

device must be determined using Method 204B or 204C in

Appendix M of 40 CFR Part 51. The results of capture

efficiency calculations (G/L) must satisfy the DQO or LCL

statistical analysis protocol as described in Section 3 of

USEPA’s “Guidelines for Determining Capture

Efficiency,” incorporated by reference at 218.112 of this

Part. Where capture efficiency testing is done to determine

emission reductions for the purpose of establishing

emission credits for offsets, shutdowns, and trading, the

LCL protocol cannot be used for these applications. In

enforcement cases, the LCL protocol cannot confirm non-

compliance.

“Screen Printing On Paper” Definition

IEPA proposed adding a definition of “screen printing on paper,” which would appear in

new Section 211.5880. IEPA’s proposed definition reads as follows:

“Screen Printing on Paper” means a process that would otherwise be paper

coating as defined in Section 211.4470 of this Part, except ink is passed through a

taut screen or fabric to which a refined form of stencil has been applied. The

stencil openings determine the form and dimensions of the imprint.

At hearing, Board Member Moore noted that IEPA’s proposed definition of “screen

printing on paper” refers to the definition of “paper coating” at 35 Ill. Adm. Code 211.4470, and

that the definition of “paper coating” includes not only coatings applied to paper, but also to

plastic film and metallic foil. Tr.1 at 18. Member Moore asked if “screen printing on paper”

would therefore include plastic film and metallic foil. IEPA responded that it would. Tr.2 at 21.

R04-12

R04-12 is a Board-initiated rulemaking proposal. The Board is proposing to correct

technical errors in formulas that are in the Board’s air pollution rules on sulfur limitations at 35

Ill. Adm. Code 214. The errors appear to have occurred when the Illinois Administrative Code

was re-codified.

By way of background, in R04-10, IEPA had proposed to correct a typographical error in

one section of Part 214. However, when the Board suggested that other similar errors in Part 214

be corrected, the Agency moved to withdraw its R04-10 proposal based on a lack of resources.

IEPA stated that it planned to later proceed with a general “clean-up” of Part 214, suggesting that

all of the errors could be corrected at that time. On December 18, 2003, the Board granted

IEPA’s motion to withdraw the R04-10 rulemaking proposal.

See

Clean-Up Amendments to 35

Ill. Adm. Code Part 214, R04-10 (Dec. 18, 2003).

In its December 18, 2003 order, the Board stated that “the public will be better served if

the rules are corrected sooner, rather than later when substantive changes are also proposed.”

Clean-Up Amendments, R04-10 (Dec. 18, 2003). To that end, the Board noted that it would

open a docket and propose amendments to correct the typographical and similar errors in Part

214.

. That docket is R04-12.

In its January 22, 2004 order consolidating R04-20 and R04-12, the Board proposed its

R04-12 amendments for public comment. The Board received no public comment or testimony

on the R04-12 proposal. Set forth in the order below are the Board’s proposed changes to Part

214 for first notice. These changes are narrowly-tailored to make only the described technical

corrections.

CONCLUSION

The Board proposes amendments for first notice to the following air pollution control

rules of the Board: Part 211 (definitions and general provisions); Part 214 (sulfur limitations);

Part 218 (organic material emission standards and limitations for the Chicago area); and Part 219

(organic material emission standards and limitations for the Metro East area).

These proposed changes are needed to clarify, correct, streamline, and update the Board’s

air pollution control rules, and are designed to be emissions neutral. The amendments include

changes to give sources more flexibility in meeting emission capture efficiency requirements.

The Board has made numerous clarifying changes to IEPA’s proposal. Many of those changes

are minor and do not merit discussion. Based on this record, the Board finds that the

amendments proposed today are technically feasible and economically reasonable and will not

have an adverse economic impact on the People of Illinois.

See

415 ILCS 5/27(a), (b) (2002).

Publication in the

Illinois Register

of the proposed amendments will start a period of at

least 45 days during which anyone may file public comments with the Clerk of the Board at the

address set forth at the outset of this opinion. Additionally, as noted above, public comments

may be filed through COOL at www.ipcb.state.il.us as part of the Board’s voluntary electronic

filing pilot project.

ORDER

The Board directs the Clerk to cause publication of the following proposed amendments

in the

Illinois Register

for first notice. Proposed additions are underlined; proposed deletions

appear stricken.

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSION STANDARDS AND LIMITATIONS FOR

STATIONARY SOURCES

PART 211

DEFINITIONS AND GENERAL PROVISIONS

SUBPART A: GENERAL PROVISIONS

Section

211.101 Incorporations by Reference

211.102 Abbreviations and Conversion Factors

SUBPART B: DEFINITIONS

Section

211.121 Other Definitions

211.122 Definitions (Repealed)

211.130 Accelacota

211.150 Accumulator

211.170 Acid Gases

211.210 Actual Heat Input

211.230 Adhesive

211.240 Adhesion Promoter

211.250 Aeration

211.270 Aerosol Can Filling Line

211.290 Afterburner

211.310 Air Contaminant

211.330 Air Dried Coatings

211.350 Air Oxidation Process

211.370 Air Pollutant

211.390 Air Pollution

211.410 Air Pollution Control Equipment

211.430 Air Suspension Coater/Dryer

211.450 Airless Spray

211.470 Air Assisted Airless Spray

211.474 Alcohol

211.479 Allowance

211.484 Animal

211.485 Animal Pathological Waste

211.490 Annual Grain Through-Put

211.495 Anti-Glare/Safety Coating

211.510 Application Area

211.530 Architectural Coating

211.550 As Applied

211.560 As-Applied Fountain Solution

211.570 Asphalt

211.590 Asphalt Prime Coat

211.610 Automobile

211.630 Automobile or Light-Duty Truck Assembly Source or Automobile or Light-Duty

Truck Manufacturing Plant

211.650 Automobile or Light-Duty Truck Refinishing

211.660 Automotive/Transportation Plastic Parts

211.670 Baked Coatings

211.680 Bakery Oven

211.685 Basecoat/Clearcoat System

211.690 Batch Loading

211.695 Batch Operation

211.696 Batch Process Train

211.710 Bead-Dipping

211.730 Binders

211.750 British Thermal Unit

211.770 Brush or Wipe Coating

211.790 Bulk Gasoline Plant

211.810 Bulk Gasoline Terminal

211.820 Business Machine Plastic Parts

211.830 Can

211.850 Can Coating

211.870 Can Coating Line

211.890 Capture

211.910 Capture Device

211.930 Capture Efficiency

211.950 Capture System

211.953 Carbon Adsorber

211.955 Cement

211.960 Cement Kiln

211.970 Certified Investigation

211.980 Chemical Manufacturing Process Unit

211.990 Choke Loading

211.1010 Clean Air Act

211.1050 Cleaning and Separating Operation

211.1070 Cleaning Materials

211.1090 Clear Coating

211.1110 Clear Topcoat

211.1120 Clinker

211.1130 Closed Purge System

211.1150 Closed Vent System

211.1170 Coal Refuse

211.1190 Coating

211.1210 Coating Applicator

211.1230 Coating Line

211.1250 Coating Plant

211.1270 Coil Coating

211.1290 Coil Coating Line

211.1310 Cold Cleaning

211.1312 Combined Cycle System

211.1316 Combustion Turbine

211.1320 Commence Commercial Operation

211.1324 Commence Operation

211.1328 Common Stack

211.1330 Complete Combustion

211.1350 Component

211.1370 Concrete Curing Compounds

211.1390 Concentrated Nitric Acid Manufacturing Process

211.1410 Condensate

211.1430 Condensible PM-10

211.1465 Continuous Automatic Stoking

211.1467 Continuous Coater

211.1470 Continuous Process

211.1490 Control Device

211.1510 Control Device Efficiency

211.1515 Control Period

211.1520 Conventional Air Spray

211.1530 Conventional Soybean Crushing Source

211.1550 Conveyorized Degreasing

211.1570 Crude Oil

211.1590 Crude Oil Gathering

211.1610 Crushing

211.1630 Custody Transfer

211.1650 Cutback Asphalt

211.1670 Daily-Weighted Average VOM Content

211.1690 Day

211.1710 Degreaser

211.1730 Delivery Vessel

211.1750 Dip Coating

211.1770 Distillate Fuel Oil

211.1780 Distillation Unit

211.1790 Drum

211.1810 Dry Cleaning Operation or Dry Cleaning Facility

211.1830 Dump-Pit Area

211.1850 Effective Grate Area

211.1870 Effluent Water Separator

211.1875 Elastomeric Materials

211.1880 Electromagnetic Interference/Radio Frequency Interference (EMI/RFI) Shielding

Coatings

211.1885 Electronic Component

211.1890 Electrostatic Bell or Disc Spray

211.1900 Electrostatic Prep Coat

211.1910 Electrostatic Spray

211.1920 Emergency or Standby Unit

211.1930 Emission Rate

211.1950 Emission Unit

211.1970 Enamel

211.1990 Enclose

211.2010 End Sealing Compound Coat

211.2030 Enhanced Under-the-Cup Fill

211.2050 Ethanol Blend Gasoline

211.2070 Excess Air

211.2080 Excess Emissions

211.2090 Excessive Release

211.2110 Existing Grain-Drying Operation (Repealed)

211.2130 Existing Grain-Handling Operation (Repealed)

211.2150 Exterior Base Coat

211.2170 Exterior End Coat

211.2190 External Floating Roof

211.2210 Extreme Performance Coating

211.2230 Fabric Coating

211.2250 Fabric Coating Line

211.2270 Federally Enforceable Limitations and Conditions

211.2285 Feed Mill

211.2290 Fermentation Time

211.2300 Fill

211.2310 Final Repair Coat

211.2330 Firebox

211.2350 Fixed-Roof Tank

211.2360 Flexible Coating

211.2365 Flexible Operation Unit

211.2370 Flexographic Printing

211.2390 Flexographic Printing Line

211.2410 Floating Roof

211.2420 Fossil Fuel

211.2425 Fossil Fuel-Fired

211.2430 Fountain Solution

211.2450 Freeboard Height

211.2470 Fuel Combustion Emission Unit or Fuel Combustion Emission Source

211.2490 Fugitive Particulate Matter

211.2510 Full Operating Flowrate

211.2530 Gas Service

211.2550 Gas/Gas Method

211.2570 Gasoline

211.2590 Gasoline Dispensing Operation or Gasoline Dispensing Facility

211.2610 Gel Coat

211.2620 Generator

211.2630 Gloss Reducers

211.2650 Grain

211.2670 Grain-Drying Operation

211.2690 Grain-Handling and Conditioning Operation

211.2710 Grain-Handling Operation

211.2730 Green-Tire Spraying

211.2750 Green Tires

211.2770 Gross Heating Value

211.2790 Gross Vehicle Weight Rating

211.2810 Heated Airless Spray

211.2815 Heat Input

211.2820 Heat Input Rate

211.2830 Heatset

211.2850 Heatset Web Offset Lithographic Printing Line

211.2870 Heavy Liquid

211.2890 Heavy Metals

211.2910 Heavy Off-Highway Vehicle Products

211.2930 Heavy Off-Highway Vehicle Products Coating

211.2950 Heavy Off-Highway Vehicle Products Coating Line

211.2970 High Temperature Aluminum Coating

211.2990 High Volume Low Pressure (HVLP) Spray

211.3010 Hood

211.3030 Hot Well

211.3050 Housekeeping Practices

211.3070 Incinerator

211.3090 Indirect Heat Transfer

211.3110 Ink

211.3130 In-Process Tank

211.3150 In-Situ Sampling Systems

211.3170 Interior Body Spray Coat

211.3190 Internal-Floating Roof

211.3210 Internal Transferring Area

211.3230 Lacquers

211.3250 Large Appliance

211.3270 Large Appliance Coating

211.3290 Large Appliance Coating Line

211.3310 Light Liquid

211.3330 Light-Duty Truck

211.3350 Light Oil

211.3370 Liquid/Gas Method

211.3390 Liquid-Mounted Seal

211.3410 Liquid Service

211.3430 Liquids Dripping

211.3450 Lithographic Printing Line

211.3470 Load-Out Area

211.3480 Loading Event

211.3483 Long Dry Kiln

211.3485 Long Wet Kiln

211.3487 Low-NOx Burner

211.3490 Low Solvent Coating

211.3500 Lubricating Oil

211.3510 Magnet Wire

211.3530 Magnet Wire Coating

211.3550 Magnet Wire Coating Line

211.3570 Major Dump Pit

211.3590 Major Metropolitan Area (MMA)

211.3610 Major Population Area (MPA)

211.3620 Manually Operated Equipment

211.3630 Manufacturing Process

211.3650 Marine Terminal

211.3660 Marine Vessel

211.3670 Material Recovery Section

211.3690 Maximum Theoretical Emissions

211.3695 Maximum True Vapor Pressure

211.3710 Metal Furniture

211.3730 Metal Furniture Coating

211.3750 Metal Furniture Coating Line

211.3770 Metallic Shoe-Type Seal

211.3780 Mid-Kiln Firing

211.3790 Miscellaneous Fabricated

Product Manufacturing Process

211.3810 Miscellaneous Formulation Manufacturing Process

211.3830 Miscellaneous Metal Parts and Products

211.3850 Miscellaneous Metal Parts and Products Coating

211.3870 Miscellaneous Metal Parts or Products Coating Line

211.3890 Miscellaneous Organic Chemical Manufacturing Process

211.3910 Mixing Operation

211.3915 Mobile Equipment

211.3930 Monitor

211.3950 Monomer

211.3960 Motor Vehicles

211.3965 Motor Vehicle Refinishing

211.3970 Multiple Package Coating

211.3980 Nameplate Capacity

211.3990 New Grain-Drying Operation (Repealed)

211.4010 New Grain-Handling Operation (Repealed)

211.4030 No Detectable Volatile Organic Material Emissions

211.4050 Non-Contact Process Water Cooling Tower

211.4055 Non-Flexible Coating

211.4065 Non-Heatset

211.4067 NOx Trading Program

211.4070 Offset

211.4090 One Hundred Percent Acid

211.4110 One-Turn Storage Space

211.4130 Opacity

211.4150 Opaque Stains

211.4170 Open Top Vapor Degreasing

211.4190 Open-Ended Valve

211.4210 Operator of a Gasoline Dispensing Operation or Operator of a Gasoline

Dispensing Facility

211.4230 Organic Compound

211.4250 Organic Material and Organic Materials

211.4260 Organic Solvent

211.4270 Organic Vapor

211.4290 Oven

211.4310 Overall Control

211.4330 Overvarnish

211.4350 Owner of a Gasoline Dispensing Operation or Owner of a Gasoline Dispensing

Facility

211.4370 Owner or Operator

211.4390 Packaging Rotogravure Printing

211.4410 Packaging Rotogravure Printing Line

211.4430 Pail

211.4450 Paint Manufacturing Source or Paint Manufacturing Plant

211.4470 Paper Coating

211.4490 Paper Coating Line

211.4510 Particulate Matter

211.4530 Parts Per Million (Volume) or PPM (Vol)

211.4550 Person

211.4590 Petroleum

211.4610 Petroleum Liquid

211.4630 Petroleum Refinery

211.4650 Pharmaceutical

211.4670 Pharmaceutical Coating Operation

211.4690 Photochemically Reactive Material

211.4710 Pigmented Coatings

211.4730 Plant

211.4740 Plastic Part

211.4750 Plasticizers

211.4770 PM-10

211.4790 Pneumatic Rubber Tire Manufacture

211.4810 Polybasic Organic Acid Partial Oxidation Manufacturing Process

211.4830 Polyester Resin Material(s)

211.4850 Polyester Resin Products Manufacturing Process

211.4870 Polystyrene Plant

211.4890 Polystyrene Resin

211.4910 Portable Grain-Handling Equipment

211.4930 Portland Cement Manufacturing Process Emission Source

211.4950 Portland Cement Process or Portland Cement

Manufacturing

Plant

211.4960 Potential Electrical Output Capacity

211.4970 Potential to Emit

211.4990 Power Driven Fastener Coating

211.5010 Precoat

211.5015 Preheater Kiln

211.5020 Preheater/Precalciner Kiln

211.5030 Pressure Release

211.5050 Pressure Tank

211.5060 Pressure/Vacuum Relief Valve

211.5061 Pretreatment Wash Primer

211.5065 Primary Product

211.5070 Prime Coat

211.5080 Primer Sealer

211.5090 Primer Surfacer Coat

211.5110 Primer Surfacer Operation

211.5130 Primers

211.5150 Printing

211.5170 Printing Line

211.5185 Process Emission Source

211.5190 Process Emission Unit

211.5210 Process Unit

211.5230 Process Unit Shutdown

211.5245 Process Vent

211.5250 Process Weight Rate

211.5270 Production Equipment Exhaust System

211.5310 Publication Rotogravure Printing Line

211.5330 Purged Process Fluid

211.5340 Rated Heat Input Capacity

211.5350 Reactor

211.5370 Reasonably Available Control Technology (RACT)

211.5390 Reclamation System

211.5410 Refiner

211.5430 Refinery Fuel Gas

211.5450 Refinery Fuel Gas System

211.5470 Refinery Unit or Refinery Process Unit

211.5480 Reflective Argent Coating

211.5490 Refrigerated Condenser

211.5500 Regulated Air Pollutant

211.5510 Reid Vapor Pressure

211.5530 Repair

211.5550 Repair Coat

211.5570 Repaired

211.5580 Repowering

211.5590 Residual Fuel Oil

211.5600 Resist Coat

211.5610 Restricted Area

211.5630 Retail Outlet

211.5650 Ringelmann Chart

211.5670 Roadway

211.5690 Roll Coater

211.5710 Roll Coating

211.5730 Roll Printer

211.5750 Roll Printing

211.5770 Rotogravure Printing

211.5790 Rotogravure Printing Line

211.5810 Safety Relief Valve

211.5830 Sandblasting

211.5850 Sanding Sealers

211.5870 Screening

211.5880 Screen Printing on Paper

211.5890 Sealer

211.5910 Semi-Transparent Stains

211.5930 Sensor

211.5950 Set of Safety Relief Valves

211.5970 Sheet Basecoat

211.5980 Sheet-Fed

211.5990 Shotblasting

211.6010 Side-Seam Spray Coat

211.6025 Single Unit Operation

211.6030 Smoke

211.6050 Smokeless Flare

211.6060 Soft Coat

211.6070 Solvent

211.6090 Solvent Cleaning

211.6110 Solvent Recovery System

211.6130 Source

211.6140 Specialty Coatings

211.6145 Specialty Coatings for Motor Vehicles

211.6150 Specialty High Gloss Catalyzed Coating

211.6170 Specialty Leather

211.6190 Specialty Soybean Crushing Source

211.6210 Splash Loading

211.6230 Stack

211.6250 Stain Coating

211.6270 Standard Conditions

211.6290 Standard Cubic Foot (scf)

211.6310 Start-Up

211.6330 Stationary Emission Source

211.6350 Stationary Emission Unit

211.6355 Stationary Gas Turbine

211.6360 Stationary Reciprocating

Internal Combustion Engine

211.6370 Stationary Source

211.6390 Stationary Storage Tank

211.6400 Stencil Coat

211.6410 Storage Tank or Storage Vessel

211.6420 Strippable Spray Booth Coating

211.6430 Styrene Devolatilizer Unit

211.6450 Styrene Recovery Unit

211.6470 Submerged Loading Pipe

211.6490 Substrate

211.6510 Sulfuric Acid Mist

211.6530 Surface Condenser

211.6540 Surface Preparation Materials

211.6550 Synthetic Organic Chemical or Polymer Manufacturing Plant

211.6570 Tablet Coating Operation

211.6580 Texture Coat

211.6590 Thirty-Day Rolling Average

211.6610 Three-Piece Can

211.6620 Three or Four Stage Coating System

211.6630 Through-the-Valve Fill

211.6650 Tooling Resin

211.6670 Topcoat

211.6690 Topcoat Operation

211.6695 Topcoat System

211.6710 Touch-Up

211.6720 Touch-Up Coating

211.6730 Transfer Efficiency

211.6750 Tread End Cementing

211.6770 True Vapor Pressure

211.6790 Turnaround

211.6810 Two-Piece Can

211.6830 Under-the-Cup Fill

211.6850 Undertread Cementing

211.6860 Uniform Finish Blender

211.6870 Unregulated Safety Relief Valve

211.6880 Vacuum Metallizing

211.6890 Vacuum Producing System

211.6910 Vacuum Service

211.6930 Valves Not Externally Regulated

211.6950 Vapor Balance System

211.6970 Vapor Collection System

211.6990 Vapor Control System

211.7010 Vapor-Mounted Primary Seal

211.7030 Vapor Recovery System

211.7050 Vapor-Suppressed Polyester Resin

211.7070 Vinyl Coating

211.7090 Vinyl Coating Line

211.7110 Volatile Organic Liquid (VOL)

211.7130 Volatile Organic Material Content (VOMC)

211.7150 Volatile Organic Material (VOM) or Volatile Organic Compound (VOC)

211.7170 Volatile Petroleum Liquid

211.7190 Wash Coat

211.7200 Washoff Operations

211.7210 Wastewater (Oil/Water) Separator

211.7230 Weak Nitric Acid Manufacturing Process

211.7250 Web

211.7270 Wholesale Purchase - Consumer

211.7290 Wood Furniture

211.7310 Wood Furniture Coating

211.7330 Wood Furniture Coating Line

211.7350 Woodworking

211.7400 Yeast Percentage

Appendix A Rule into Section Table

Appendix B Section into Rule Table

AUTHORITY: Implementing Sections 9, 9.1, 9.9 and 10 and authorized by Sections 27, 28 and

28.5 of the Environmental Protection Act [415 ILCS 5/9, 9.1, 9.9, 10, 27, 28 and 28.5].

SOURCE: Adopted as Chapter 2: Air Pollution, Rule 201: Definitions, R71-23, 4 PCB 191,

filed and effective April 14, 1972; amended in R74-2 and R75-5, 32 PCB 295, at 3 Ill. Reg. 5, p.

777, effective February 3, 1979; amended in R78-3 and 4, 35 PCB 75 and 243, at 3 Ill. Reg. 30,

p. 124, effective July 28, 1979; amended in R80-5, at 7 Ill. Reg. 1244, effective January 21,

1983; codified at 7 Ill. Reg. 13590; amended in R82-1 (Docket A) at 10 Ill. Reg. 12624, effective

July 7, 1986; amended in R85-21(A) at 11 Ill. Reg. 11747, effective June 29, 1987; amended in

R86-34 at 11 Ill. Reg. 12267, effective July 10, 1987; amended in R86-39 at 11 Ill. Reg. 20804,

effective December 14, 1987; amended in R82-14 and R86-37 at 12 Ill. Reg. 787, effective

December 24, 1987; amended in R86-18 at 12 Ill. Reg. 7284, effective April 8, 1988; amended

in R86-10 at 12 Ill. Reg. 7621, effective April 11, 1988; amended in R88-23 at 13 Ill. Reg.

10862, effective June 27, 1989; amended in R89-8 at 13 Ill. Reg. 17457, effective January 1,

1990; amended in R89-16(A) at 14 Ill. Reg. 9141, effective May 23, 1990; amended in R88-

30(B) at 15 Ill. Reg. 5223, effective March 28, 1991; amended in R88-14 at 15 Ill. Reg. 7901,

effective May 14, 1991; amended in R91-10 at 15 Ill. Reg. 15564, effective October 11, 1991;

amended in R91-6 at 15 Ill. Reg. 15673, effective October 14, 1991; amended in R91-22 at 16

Ill. Reg. 7656, effective May 1, 1992; amended in R91-24 at 16 Ill. Reg. 13526, effective August

24, 1992; amended in R93-9 at 17 Ill. Reg. 16504, effective September 27, 1993; amended in

R93-11 at 17 Ill. Reg. 21471, effective December 7, 1993; amended in R93-14 at 18 Ill. Reg.

1253, effective January 18, 1994; amended in R94-12 at 18 Ill. Reg. 14962, effective September

21, 1994; amended in R94-14 at 18 Ill. Reg. 15744, effective October 17, 1994; amended in

R94-15 at 18 Ill. Reg. 16379, effective October 25, 1994; amended in R94-16 at 18 Ill. Reg.

16929, effective November 15, 1994; amended in R94-21, R94-31 and R94-32 at 19 Ill. Reg.

6823, effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7344, effective May 22, 1995;

amended in R95-2 at 19 Ill. Reg. 11066, effective July 12, 1995; amended in R95-16 at 19 Ill.

Reg. 15176, effective October 19, 1995; amended in R96-5 at 20 Ill. Reg. 7590, effective May

22, 1996; amended in R96-16 at 21 Ill. Reg. 2641, effective February 7, 1997; amended in R97-

17 at 21 Ill. Reg. 6489, effective May 16, 1997; amended in R97-24 at 21 Ill. Reg. 7695,

effective June 9, 1997; amended in R96-17 at 21 Ill. Reg. 7856, effective June 17, 1997;

amended in R97-31 at 22 Ill. Reg. 3497, effective February 2, 1998; amended in R98-17 at 22 Ill.

Reg.11405, effective June 22, 1998; amended in R01-9 at 25 Ill. Reg. 128, effective December

26, 2000; amended in R01-11 at 25 Ill. Reg. 4597, effective March 15, 2001; amended in R01-17

at 25 Ill. Reg. 5900, effective April 17, 2001; amended in R04-20 at ___ Ill. Reg. ___________,

effective _______________.

BOARD NOTE: This Part implements the Illinois Environmental Protection Act as of July 1,

1994.

Section 211.953 Carbon Adsorber

“Carbon Adsorber” means a control device designed to remove and, if desired, recover volatile

organic material (VOM) from process emissions where removal of VOM is accomplished

through the adherence of the VOM onto the surface of highly porous adsorbent particles, such as

activated carbon. The term “carbon adsorber” describes any adsorber technology used as a

control device even though media other than carbon may be used as the adsorbent, such as

oxides of silicon and aluminum.

(Source: Added at _______________, effective ________________)

Section 211.5880 Screen Printing on Paper

“Screen Printing on Paper” means a process that would otherwise be paper coating as defined in

Section 211.4470 of this Part, except ink is passed through a taut screen or fabric to which a

refined form of stencil has been applied. The stencil openings determine the form and

dimensions of the imprint.

(Source: Added at _______________, effective ________________)

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSION STANDARDS AND LIMITATIONS FOR

STATIONARY SOURCES

PART 214

SULFUR LIMITATIONS

SUBPART A: GENERAL PROVISIONS

Section

214.100 Scope and Organization

214.101 Measurement Methods

214.102 Abbreviations and Units

214.103 Definitions

214.104 Incorporations by Reference

SUBPART B: NEW FUEL COMBUSTION EMISSION SOURCES

Section

214.120 Scope

214.121 Large Sources

214.122 Small Sources

SUBPART C: EXISTING SOLID FUEL COMBUSTION EMISSION

SOURCES

Section

214.140 Scope

214.141 Sources Located in Metropolitan Areas

214.142 Small Sources Located Outside Metropolitan Areas

214.143 Large Sources Located Outside Metropolitan Areas

SUBPART D: EXISTING LIQUID OR MIXED FUEL COMBUSTION

EMISSION SOURCES

Section

214.161 Liquid Fuel Burned Exclusively

214.162 Combination of Fuels

SUBPART E: AGGREGATION OF SOURCES OUTSIDE METROPOLITAN

AREAS

Section

214.181 Dispersion Enhancement Techniques

214.182 Prohibition

214.183 General Formula

214.184 Special Formula

214.185 Alternative Emission Rate

214.186 New Operating Permits

SUBPART F: ALTERNATIVE STANDARDS FOR SOURCES INSIDE

METROPOLITAN AREAS

Section

214.201 Alternative Standards for Sources in Metropolitan Areas

214.202 Dispersion Enhancement Techniques

SUBPART K: PROCESS EMISSION SOURCES

Section

214.300 Scope

214.301 General Limitation

214.302 Exception for Air Pollution Control Equipment

214.303 Use of Sulfuric Acid

214.304 Fuel Burning Process Emission Source

SUBPART O: PETROLEUM REFINING, PETROCHEMICAL AND

CHEMICAL MANUFACTURING

Section

214.380 Scope

214.381 Sulfuric Acid Manufacturing

214.382 Petroleum and Petrochemical Processes

214.383 Chemical Manufacturing

214.384 Sulfate and Sulfite Manufacturing

SUBPART P: STONE, CLAY, GLASS AND CONCRETE PRODUCTS

Section

214.400 Scope

214.401 Glass Melting and Heat Treating

214.402 Lime Kilns

SUBPART Q: PRIMARY AND SECONDARY METAL MANUFACTURING

Section

214.420 Scope

214.421 Combination of Fuels at Steel Mills in Metropolitan Areas

214.422 Secondary Lead Smelting in Metropolitan Areas

214.423 Slab Reheat Furnaces in St. Louis Area

SUBPART V: ELECTRIC POWER PLANTS

Section

214.521 Winnetka Power Plant

SUBPART X: UTILITIES

Section

214.560 Scope

214.561 E. D. Edwards Electric Generating Station

214.562 Coffeen Generating Station

Appendix A Rule into Section Table

Appendix B Section into Rule Table

Appendix C Method used to Determine Average Actual Stack Height and Effective Height of

Effluent Release

Appendix D Past Compliance Dates

AUTHORITY: Implementing Section 10 and authorized by Section 27 of the Environmental

Protection Act [415 ILCS 5/10 and 27].

SOURCE: Adopted as Chapter 2: Air Pollution, Rule 204: Sulfur Emission Standards and

Limitations, R71-23, 4 PCB 191, filed and effective April 14, 1972; amended in R74-2 and R75-

5, 32 PCB 295, at 3 Ill. Reg. 5, p. 777, effective February 3, 1979; amended in R74-2, R75-5, 38

PCB 129, at 4 Ill. Reg. 28, p. 417, effective June 26, 1980; amended in R78-17, 40 PCB 291, at 5

Ill. Reg. 1892, effective February 17, 1981; amended in R77-15, 44 PCB 267, at 6 Ill. Reg. 2146,

effective January 28, 1982; amended and renumbered in R80-22(A), at 7 Ill. Reg. 42204219,

effective March 28, 1983; codified 7 Ill. Reg. 1357913597; amended in R80-22(B), at 8 Ill. Reg.

6172, effective April 24, 1984; amended in R84-28, at 10 Ill. Reg. 9806, effective May 20, 1986;

amended in R86-31, at 12 Ill. Reg. 17387, effective October 14, 1988; amended in R86-30, at 12

Ill. Reg. 20778, effective December 5, 1988; amended in R87-31 at 15 Ill. Reg. 1017, effective

January 15, 1991; amended in R02-21 at 27 Ill. Reg. 12101, effective July 11, 2003; amended in

R04-12 at _____ Ill. Reg. ______, effective ________.

SUBPART D: EXISTING LIQUID OR MIXED FUEL COMBUSTION EMISSION

SOURCES

Section 214.162 Combination of Fuels

a) No person shall cause or allow the emission of sulfur dioxide into the atmosphere

in any one hour period from any fuel combustion emission source burning

simultaneously any combination of solid, liquid and gaseous fuels to exceed the

allowable emission rate determined by the following equation:

E = AX + BY + CZ

E = SSHS + SdHd + SRHR

b) Symbols in the equation mean the following:

E = allowable sulfur dioxide emission rate;

ASS = solid fuel sulfur dioxide emission standard which is applicable;

BSd = distillate oil sulfur dioxide emission standard determined from the

table in subsection (d);

CSR = residual fuel oil sulfur dioxide emission standard which is

applicable;

XHS = actual heat input from solid fuel;

YHd = actual heat input from distillate fuel oil;

ZHR = actual heat input from residual fuel oil;

c) That portion of the actual heat input that is derived:

1) From the burning of gaseous fuels produced by the gasification of solid

fuels shall be included in XHS;

2) From the burning of gaseous fuels produced by the gasification of

distillate fuel oil shall be included in YHd;

3) From the burning of gaseous fuels produced by the gasification of residual

fuel oil shall be included in ZHR;

From the burning of gaseous fuels produced by the gasification of any

other liquid fuel shall be included in ZHR; and,

From the burning of by-product gases such as those produced from a blast

furnace or a catalyst regeneration unit in a petroleum refinery shall be

included in ZHR.

Metric or English units may be used in the equation of subsection (a) as follows:

(Source: Amended at _ Ill. Reg. _, effective _)

SUBPART E: AGGREGATION OF SOURCES OUTSIDE METROPOLITAN AREAS

Section 214.183

General Formula

The general formula is:

Symbols used in the general formula mean the following:

E =

Total allowable emission of sulfur dioxide (in lbs/hr or kg/hr) into the

atmosphere in any one-hour period from all fuel combustion emission

sources owned or operated by such person and located within a 1.6 km (1

mile) radius from the center point of any such emission source.

XHA = Average actual stack height as determined by method outlined in

Appendix C.

YHE = Effective height of effluent release as determined by method outlined in

Appendix C.

The general formula may be used with either metric or English units as follows:

(Source: Amended at _ Ill. Reg. _, effective _)

Section 214.184

Special Formula

If the maximum total emissions of sulfur dioxide into the atmosphere in any one

hour period from all fuel combustion emission sources owned or operated by any

person and located within a 1 mile (1.6 km) radius from the center point of any

such fuel combustion emission sources exceed, during normal cyclical variations

in firing rate and fuel, the emissions allowed under Section 214.183 but, as of

April 1, 1978, were in compliance with either the formula detailed below or a

Pollution Control Board (Board) order, then the owner or operator of the emission

sources shall not cause or allow such emissions to exceed the emissions allowed

under Section 214.183 or the formula detailed below, whichever the owner or

operator of the emission sources determines shall apply.

P1 H1 + P2 H2 + ... Pn Hn

(Note: P1 + P2 ... Pn = 1)

As used in these equations, symbols mean the following:

E =

total emission of sulfur dioxide, (in pounds per hour,lbs/hr or kg/hr) into

the atmosphere in any one hour period from all fuel combustion emission

sources owned or operated by such person and located within a 1 mile (1.6

km) radius from the center point of any such emission source;

Pi, i = 1, 2,...,

n =

percentage of total emissions E emitted

from source I divided by 100, and

Hi, i = 1, 2,...,

n =

physical height in feet above grade of

stack i.

Pi= (for i=1, 2, . . ., n) percentage or total emissions E emitted from source i

expressed as decimal equivalents (e.g., 21% = 0.21), and

Hi= (for i=1, 2, . . ., n) physical height (in feet or meters) above grade of stack

(Source: Amended at _ Ill. Reg. _, effective _)

SUBPART Q: PRIMARY AND SECONDARY METAL MANUFACTURING

Section 214.421 Combination of Fuels at Steel Mills in Metropolitan Areas

a) Section 214.162 notwithstanding, no person shall cause or allow the emission of

sulfur dioxide into the atmosphere in any one hour period from any existing fuel

combustion emission source at a steel mill located in the Chicago or St. Louis

(Illinois) major metropolitan area burning any solid, liquid or gaseous fuel, or any

combination thereof, to exceed the allowable emission rate determined by the

following equation:

E = AW + BX + CY + DZ

E = SSHS + SdHd + SRHR + SGHG

b) Symbols in the equation mean the following:

E = allowable sulfur dioxide emission rate;

ASS = solid fuel sulfur dioxide emission standard which is applicable;

BSd = distillate oil sulfur dioxide emission standard determined from the

table in subsection (d);

CSR = residual oil sulfur dioxide emission standard which is applicable;

DSG = maximum by-product gas sulfur dioxide emissions which would

result if the applicable by-product gas which was burned had been

burned alone at any time during the 12 months preceding the latest

operation, on or before March 28, 1983, of an emission source

using any by-product gas.

WHS = actual heat input from solid fuel;

XHd = actual heat input from distillate fuel oil;

YHR = actual heat input from residual fuel oil;

ZHG = actual heat input from by-product gases, such as those produced

from a blast furnace.

c) That portion of the actual heat input that is derived:

1) From the burning of gaseous fuels produced by the gasification of solid

fuels shall be included in WHS;

2) From the burning of gaseous fuels produced by the gasification of

distillate fuel oil shall be included in XHd;

3) From the burning of gaseous fuels produced by the gasification of residual

fuel oil shall be included in YHR; and

4) From the burning of gaseous fuels produced by the gasification of any

other liquid fuel shall be included in ZHG.

d) Metric or English units may be used in the equation of subsection (a) as follows:

(Source: Amended at _ Ill. Reg. _, effective _)

APPENDIX C

Method used to Determine Average Actual Stack Height and Effective Height of

Effluent Release

QH (Btu/sec) = Heat emission rate (in btu/sec or Kcal/sec) as determined by method outlined

below.

∆

H (feet) = Plume rise (in feet or meters).

H = Physical height (in feet or meters), above grade of each stack, except that for purposes of

this calculation the value used for such stack height shall not exceed good engineering

practice as defined by Section 123 of the Clean Air Act and Regulations promulgated

thereunder, unless the owner or operator of the source demonstrates to the Agency that a

greater height is necessary to prevent downwash or fumigation conditions.

T (Degrees Rankine) = Exit temperature of stack gases (in degrees Rankine or degrees

Kelvin) from each source during operating conditions which would

cause maximum emissions.

V (feet/sec) =

Exit velocity of stack gases (in feet/sec or meters/sec) from each source

under operating conditions which would cause maximum emissions.

D (feet) =

Diameter of stack (in feet or meters).

P =

Percentage of total emissions expressed as decimal equivalents emitted from each source.

Example: 21% = 0.21. NOTE: The sum of P1 + P2 ... + Pn = 1. The emission values to be

used are those which occur during operating conditions which would cause maximum

emissions.

X HA = Average actual stack height (in feet or meters).

YHE = Effective height of effluent release (in feet or meters).

STEP 1:

Determine weighted average stack parameters utilizing the following formulae:

D =

P1 D1 + P2 D2 + ... + Pn Dn

V =

P1 V1 + P2 V2 + ... + Pn Vn

T =

P1 T1 + P2 T2 + ... + Pn Tn

HAX = P1 H1 + P2 H2 + ... + Pn Hn

NOTE: P1, D1, V1, T1, P1, D1, V1, T1, and H1 H1 are the percentage of total emissions, stack

diameter, exit velocity of gases, exit temperature of stack gases, and physical stack height,

respectively, for the first source; P2, D2, V2, T2, P2, D2, V2, T2, and H2 H2 are the respective

values for the second source; similarly, Pn, Dn, Vn, Tn, Pn, Dn, Vn, Tn, and Hn Hn are the

respective values for the nth source, where n is the number of the last source.

STEP 2:

Calculate heat emission rate utilizing the following formula and the weighted

average stack parameters obtained in Step 1:

Q + 7.54D2V (T - 515)

Calculate plume rise utilizing the appropriate formula given below and the total

heat emission rate obtained in Step 2:

(in English Units for QH

(in Metric Units for QH

(in English Units for QH< 6000 btu/sec)

()

∆

(in Metric Units for QH< 1500 kcal/sec)

STEP 4:

Calculate the weighted average facility effective height of effluent release

utilizing the plume rise obtained in Step 3, the average stack height obtained in

Step 1 and the formula given below:

Calculate the total facility hourly emission limitation utilizing the weighted actual

stack height obtained in Step 1, the effective stack height given in Step 4, and the

(Source: Amended at _ Ill. Reg. _, effective _)

TITLE 35: ENVIRONMENTAL PROTECTION

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 Introduction

218.101 Savings Clause

218.102 Abbreviations and Conversion Factors

218.103 Applicability

218.104 Definitions

218.105 Test Methods and Procedures

218.106 Compliance Dates

218.107 Operation of Afterburners

218.108 Exemptions, Variations, and Alternative Means of Control or Compliance

Determinations

218.109 Vapor Pressure of Volatile Organic Liquids

218.110 Vapor Pressure of Organic Material or Solvent

218.111 Vapor Pressure of Volatile Organic Material

218.112 Incorporations by Reference

218.113 Monitoring for Negligibly-Reactive Compounds

218.114 Compliance with Permit Conditions

SUBPART B: ORGANIC EMISSIONS FROM STORAGE AND LOADING

OPERATIONS

Section

218.119 Applicability for VOL

218.120 Control Requirements for Storage Containers of VOL

218.121 Storage Containers of VPL

218.122 Loading Operations

218.123 Petroleum Liquid Storage Tanks

218.124 External Floating Roofs

218.125 Compliance Dates

218.126 Compliance Plan (Repealed)

218.127 Testing VOL Operations

218.128 Monitoring VOL Operations

218.129 Recordkeeping and Reporting for VOL Operations

SUBPART C: ORGANIC EMISSIONS FROM MISCELLANEOUS

EQUIPMENT

Section

218.141 Separation Operations

218.142 Pumps and Compressors

218.143 Vapor Blowdown

218.144 Safety Relief Valves

SUBPART E: SOLVENT CLEANING

Section

218.181 Solvent Cleaning in General

218.182 Cold Cleaning

218.183 Open Top Vapor Degreasing

218.184 Conveyorized Degreasing

218.185 Compliance Schedule (Repealed)

218.186 Test Methods

SUBPART F: COATING OPERATIONS

Section

218.204 Emission Limitations

218.205 Daily-Weighted Average Limitations

218.206 Solids Basis Calculation

218.207 Alternative Emission Limitations

218.208 Exemptions from Emission Limitations

218.209 Exemption from General Rule on Use of Organic Material

218.210 Compliance Schedule

218.211 Recordkeeping and Reporting

218.212 Cross-Line Averaging to Establish Compliance for Coating Lines

218.213 Recordkeeping and Reporting for Cross-Line Averaging Participating Coating

Lines

218.214 Changing Compliance Methods

218.215 Wood Furniture Coating Averaging Approach

218.216 Wood Furniture Coating Add-On Control Use

218.217 Wood Furniture Coating Work Practice Standards

SUBPART G: USE OF ORGANIC MATERIAL

Section

218.301 Use of Organic Material

218.302 Alternative Standard

218.303 Fuel Combustion Emission Units

218.304 Operations with Compliance Program

SUBPART H: PRINTING AND PUBLISHING

Section

218.401 Flexographic and Rotogravure Printing

218.402 Applicability

218.403 Compliance Schedule

218.404 Recordkeeping and Reporting

218.405 Lithographic Printing: Applicability

218.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to March

15, 1996

218.407 Emission Limitations and Control Requirements for Lithographic Printing Lines

On and After March 15, 1996

218.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996

218.409 Testing for Lithographic Printing On and After March 15, 1996

218.410 Monitoring Requirements for Lithographic Printing

218.411 Recordkeeping and Reporting for Lithographic Printing

SUBPART Q: SYNTHETIC ORGANIC CHEMICAL AND POLYMER

MANUFACTURING PLANT

Section

218.421 General Requirements

218.422 Inspection Program Plan for Leaks

218.423 Inspection Program for Leaks

218.424 Repairing Leaks

218.425 Recordkeeping for Leaks

218.426 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)

218.431 Applicability

218.432 Control Requirements

218.433 Performance and Testing Requirements

218.434 Monitoring Requirements

218.435 Recordkeeping and Reporting Requirements

218.436 Compliance Date

SUBPART R: PETROLEUM REFINING AND RELATED INDUSTRIES;

ASPHALT MATERIALS

Section

218.441 Petroleum Refinery Waste Gas Disposal

218.442 Vacuum Producing Systems

218.443 Wastewater (Oil/Water) Separator

218.444 Process Unit Turnarounds

218.445 Leaks: General Requirements

218.446 Monitoring Program Plan for Leaks

218.447 Monitoring Program for Leaks

218.448 Recordkeeping for Leaks

218.449 Reporting for Leaks

218.450 Alternative Program for Leaks

218.451 Sealing Device Requirements

218.452 Compliance Schedule for Leaks

218.453 Compliance Dates (Repealed)

SUBPART S: RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS

Section

218.461 Manufacture of Pneumatic Rubber Tires

218.462 Green Tire Spraying Operations

218.463 Alternative Emission Reduction Systems

218.464 Emission Testing

218.465 Compliance Dates (Repealed)

218.466 Compliance Plan (Repealed)

SUBPART T: PHARMACEUTICAL MANUFACTURING

Section

218.480 Applicability

218.481 Control of Reactors, Distillation Units, Crystallizers, Centrifuges and Vacuum

Dryers

218.482 Control of Air Dryers, Production Equipment Exhaust Systems and Filters

218.483 Material Storage and Transfer

218.484 In-Process Tanks

218.485 Leaks

218.486 Other Emission Units

218.487 Testing

218.488 Monitoring for Air Pollution Control Equipment

218.489 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

218.504 Monitoring Requirements for Batch Operations

218.505 Reporting and Recordkeeping for Batch Operations

218.506 Compliance Date

218.520 Emission Limitations for Air Oxidation Processes

218.521 Definitions (Repealed)

218.522 Savings Clause

218.523 Compliance

218.524 Determination of Applicability

218.525 Emission Limitations for Air Oxidation Processes

218.526 Testing and Monitoring

218.527 Compliance Date (Repealed)

SUBPART W: AGRICULTURE

Section

218.541 Pesticide Exception

SUBPART X: CONSTRUCTION

Section

218.561 Architectural Coatings

218.562 Paving Operations

218.563 Cutback Asphalt

SUBPART Y: GASOLINE DISTRIBUTION

Section

218.581 Bulk Gasoline Plants

218.582 Bulk Gasoline Terminals

218.583 Gasoline Dispensing Operations - Storage Tank Filling Operations

218.584 Gasoline Delivery Vessels

218.585 Gasoline Volatility Standards

218.586 Gasoline Dispensing Operations - Motor Vehicle Fueling Operations

SUBPART Z: DRY CLEANERS

Section

218.601 Perchloroethylene Dry Cleaners (Repealed)

218.602 Applicability (Repealed)

218.603 Leaks (Repealed)

218.604 Compliance Dates (Repealed)

218.605 Compliance Plan (Repealed)

218.606 Exception to Compliance Plan (Repealed)

218.607 Standards for Petroleum Solvent Dry Cleaners

218.608 Operating Practices for Petroleum Solvent Dry Cleaners

218.609 Program for Inspection and Repair of Leaks

218.610 Testing and Monitoring

218.611 Applicability for Petroleum Solvent Dry Cleaners

218.612 Compliance Dates (Repealed)

218.613 Compliance Plan (Repealed)

SUBPART AA: PAINT AND INK MANUFACTURING

Section

218.620 Applicability

218.621 Exemption for Waterbase Material and Heatset Offset Ink

218.623 Permit Conditions (Repealed)

218.624 Open Top Mills, Tanks, Vats or Vessels

218.625 Grinding Mills

218.626 Storage Tanks

218.628 Leaks

218.630 Clean Up

218.636 Compliance Schedule

218.637 Recordkeeping and Reporting

SUBPART BB: POLYSTYRENE PLANTS

Section

218.640 Applicability

218.642 Emissions Limitation at Polystyrene Plants

218.644 Emissions Testing

SUBPART CC: POLYESTER RESIN PRODUCT MANUFACTURING

PROCESS

Section

218.660 Applicability

218.666 Control Requirements

218.667 Compliance Schedule

218.668 Testing

218.670 Recordkeeping and Reporting for Exempt Emission Units

218.672 Recordkeeping and Reporting for Subject Emission Units

SUBPART DD: AEROSOL CAN FILLING

Section

218.680 Applicability

218.686 Control Requirements

218.688 Testing

218.690 Recordkeeping and Reporting for Exempt Emission Units

218.692 Recordkeeping and Reporting for Subject Emission Units

SUBPART FF: BAKERY OVENS (REPEALED)

Section

218.720 Applicability (Repealed)

218.722 Control Requirements (Repealed)

218.726 Testing (Repealed)

218.727 Monitoring (Repealed)

218.728 Recordkeeping and Reporting (Repealed)

218.729 Compliance Date (Repealed)

218.730 Certification (Repealed)

SUBPART GG: MARINE TERMINALS

Section

218.760 Applicability

218.762 Control Requirements

218.764 Compliance Certification

218.766 Leaks

218.768 Testing and Monitoring

218.770 Recordkeeping and Reporting

SUBPART HH: MOTOR VEHICLE REFINISHING

Section

218.780 Emission Limitations

218.782 Alternative Control Requirements

218.784 Equipment Specifications

218.786 Surface Preparation Materials

218.787 Work Practices

218.788 Testing

218.789 Monitoring and Recordkeeping for Control Devices

218.790 General Recordkeeping and Reporting (Repealed)

218.791 Compliance Date

218.792 Registration

218.875 Applicability of Subpart BB (Renumbered)

218.877 Emissions Limitation at Polystyrene Plants (Renumbered)

218.879 Compliance Date (Repealed)

218.881 Compliance Plan (Repealed)

218.883 Special Requirements for Compliance Plan (Repealed)

218.886 Emissions Testing (Renumbered)

SUBPART PP: MISCELLANEOUS FABRICATED PRODUCT

MANUFACTURING PROCESSES

Section

218.920 Applicability

218.923 Permit Conditions (Repealed)

218.926 Control Requirements

218.927 Compliance Schedule

218.928 Testing

218.929 Cementable and Dress or Performance Shoe Leather

SUBPART QQ: MISCELLANEOUS FORMULATION MANUFACTURING

PROCESSES

Section

218.940 Applicability

218.943 Permit Conditions (Repealed)

218.946 Control Requirements

218.947 Compliance Schedule

218.948 Testing

SUBPART RR: MISCELLANEOUS ORGANIC CHEMICAL

MANUFACTURING PROCESSES

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 UU: 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 218.Appendix B: VOM Measurement Techniques for Capture Efficiency (Repealed)

Section 218.Appendix C: Reference Methods and Procedures

Section 218.Appendix D: Coefficients for the Total Resource Effectiveness Index (TRE)

Equation

Section 218.Appendix E: List of Affected Marine Terminals

Section 218.Appendix G: TRE Index Measurements for SOCMI Reactors and Distillation

Units

Section 218.Appendix H: Baseline VOM Content Limitations for Subpart F, Section 218.212

Cross-Line Averaging

AUTHORITY: Implementing Section 10 and authorized by Sections 27, 28, 28.5 of the

Environmental Protection Act [415 ILCS 5/10 and 28.5].

SOURCE: Adopted at R91-7 at 15 Ill. Reg. 12231, effective August 16, 1991; amended in R91-

24 at 16 Ill. Reg. 13564, effective August 24, 1992; amended in R91-28 and R91-30 at 16 Ill.

Reg. 13864, effective August 24, 1992; amended in R93-9 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 R94-12 at 18 Ill. Reg. at 14973, effective September 21, 1994; amended in R94-15 at

18 Ill. Reg. 16392, effective October 25, 1994; amended in R94-16 at 18 Ill. Reg. 16950,

effective November 15, 1994; amended in R94-21, R94-31 and R94-32 at 19 Ill. Reg. 6848,

effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7359, effective May 22, 1995;

amended in R96-13 at 20 Ill. Reg. 14428, effective October 17, 1996; amended in R97-24 at 21

Ill. Reg. 7708, effective June 9, 1997; amended in R97-31 at 22 Ill. Reg. 3556, effective

February 2, 1998; amended in R98-16 at 22 Ill. Reg. 14282, effective July 16, 1998; amended in

R02-20, at 27 Ill. Reg 7283, effective April 8, 2003; amended in R04-20 at __ Ill. Reg.

_________, effective _______________.

BOARD NOTE: This Part implements the Environmental Protection Act as of July 1, 1994.

SUBPART A: GENERAL PROVISIONS

Section 218.105 Test Methods and Procedures

a) Coatings, Inks and Fountain Solutions

The following test methods and procedures shall be used to determine compliance

of as applied coatings, inks, and fountain solutions with the limitations set forth in

this Part.

1) Sampling: Samples collected for analyses shall be one-liter taken into a

one-liter container at a location and time such that the sample will be

representative of the coating as applied (i.e., the sample shall include any

dilution solvent or other VOM added during the manufacturing process).

The container must be tightly sealed immediately after the sample is taken.

Any solvent or other VOM added after the sample is taken must be

measured and accounted for in the calculations in subsection (a)(3) of this

Section. For multiple package coatings, separate samples of each

component shall be obtained. A mixed sample shall not be obtained as it

will cure in the container. Sampling procedures shall follow the

guidelines presented in:

A) ASTM D3925-81 (1985) standard practice for sampling liquid

by reference in Section 218.112 of this Part.

B) ASTM E300-86 standard practice for sampling industrial

chemicals. This practice is incorporated by reference in Section

218.112 of this Part.

2) Analyses: The applicable analytical methods specified below shall be used

to determine the composition of coatings, inks, or fountain solutions as

applied.

A) Method 24 of 40 CFR 60, Appendix A, incorporated by reference

in Section 218.112 of this Part, shall be used to determine the

VOM content and density of coatings. If it is demonstrated to the

satisfaction of the Agency and the USEPA that plant coating

formulation data are equivalent to Method 24 results, formulation

data may be used. In the event of any inconsistency between a

Method 24 test and a facility's formulation data, the Method 24 test

will govern.

B) Method 24A of 40 CFR Part 60, Appendix A, incorporated by

reference in Section 218.112 of this Part, shall be used to

determine the VOM content and density of rotogravure printing

of the Agency and USEPA that the plant coating formulation data

are equivalent to Method 24A results, formulation data may be

used. In the event of any inconsistency between a Method 24A

test and formulation data, the Method 24A test will govern.

C) The following ASTM methods are the analytical procedures for

determining VOM:

i) ASTM D1475-85: Standard test method for density of

paint, varnish, lacquer and related products. This test

method is incorporated by reference in Section 218.112 of

this Part.

ii) ASTM D2369-87: Standard test method for volatile content

of a coating. This test method is incorporated by reference

in Section 218.112 of this Part.

iii) ASTM D3792-86: Standard test method for water content

of water-reducible paints by direct injection into a gas

chromatograph. This test method is incorporated by

reference in Section 218.112 of this Part.

iv) ASTM D4017-81 (1987): Standard test method for water

content in paints and paint materials by the Karl Fischer

method. This test method is incorporated by reference in

Section 218.112 of this Part.

v) ASTM D4457-85: Standard test method for determination

of dichloromethane and 1,1,1, trichloroethane in paints and

coatings by direct injection into a gas chromatograph. (The

procedure delineated above can be used to develop

protocols for any compounds specifically exempted from

the definition of VOM.) This test method is incorporated by

reference in Section 218.112 of this Part.

vi) ASTM D2697-86: Standard test method for volume non-

volatile matter in clear or pigmented coatings. This test

method is incorporated by reference in Section 218.112 of

this Part.

vii) ASTM D3980-87: Standard practice for interlaboratory

testing of paint and related materials. This practice is

incorporated by reference in Section 218.112 of this Part.

viii) ASTM E180-85: Standard practice for determining the

precision data of ASTM methods for analysis of and testing

of industrial chemicals. This practice is incorporated by

reference in Section 218.112 of this Part.

ix) ASTM D2372-85: Standard method of separation of

vehicle from solvent-reducible paints. This method is

incorporated by reference in Section 218.112 of this Part.

D) Use of an adaptation to any of the analytical methods specified in

subsections (a)(2)(A), (B), and (C) of this Section may not be used

unless approved by the Agency and USEPA. An owner or

operator must submit sufficient documentation for the Agency and

USEPA to find that the analytical methods specified in subsections

(a)(2)(A), (B), and (C) of this Section will yield inaccurate results

and that the proposed adaptation is appropriate.

3) Calculations: Calculations for determining the VOM content, water

content and the content of any compounds which are specifically

exempted from the definition of VOM of coatings, inks and fountain

solutions as applied shall follow the guidance provided in the following

documents:

A) “A Guide for Surface Coating Calculation”, EPA-340/1-86-016,

incorporated by reference in Section 218.112 of this Part.

B) “Procedures for Certifying Quantity of Volatile Organic

Compounds Emitted by Paint, Ink and Other Coatings” (revised

June 1986), EPA-450/3-84-019, incorporated by reference in

Section 218.112 of this Part.

C) “A Guide for Graphic Arts Calculations”, August 1988, EPA-

340/1-88-003, incorporated by reference in Section 218.112 of this

Part.

b) Automobile or Light-Duty Truck Test Protocol

1) The protocol for testing, including determining the transfer efficiency of

coating applicators, at primer surfacer operations and topcoat operations at

an automobile or light-duty truck assembly source shall follow the

procedures in: "Protocol for Determining the Daily Volatile Organic

Compound Emission Rate of Automobile and Light-Duty Truck Topcoat

Operations" ("topcoat protocol"), December 1988, EPA-450/3-88-018,

incorporated by reference in Section 218.112 of this Part.

2) Prior to testing pursuant to the topcoat protocol, the owner or operator of a

coating operation subject to the topcoat or primer surfacer limit in

Sections 218.204(a)(2) or 218.204(a)(3) shall submit a detailed testing

proposal specifying the method by which testing will be conducted and

how compliance will be demonstrated consistent with the topcoat protocol.

The proposal shall include, at a minimum, a comprehensive plan

(including a rationale) for determining the transfer efficiency at each booth

through the use of in-plant or pilot testing, the selection of coatings to be

tested (for the purpose of determining transfer efficiency) including the

rationale for coating groupings, the method for determining the analytic

VOM content of as applied coatings and the formulation solvent content

of as applied coatings, and a description of the records of coating VOM

content as applied and coating's usage which will be kept to demonstrate

compliance. Upon approval of the proposal by the Agency and USEPA,

the compliance demonstration for a coating line may proceed.

c) Capture System Efficiency Test Protocols

1) Applicability

The requirements of subsection (c)(2) of this Section shall apply to all

VOM emitting process emission units employing capture equipment (e.g.,

hoods, ducts), except those cases noted below.

A) If an emission unit is equipped with (or uses) a permanent total

enclosure (PTE) that meets Agency and USEPA specifications,

and which directs all VOM to a control device, then the emission

unit is exempted from the requirements described in subsection

(c)(2) of this Section. The Agency and USEPA specifications to

determine whether a structure is considered a PTE are given in

Method 204 Procedure T of Appendix M of 40 CFR Part 51,

incorporated by reference in Section 218.112 of this Part.

Appendix B of this Part. In this instance, the capture efficiency is

assumed to be 100 percent and the emission unit is still required to

measure control efficiency using appropriate test methods as

specified in subsection (d) of this Section.

B) If an emission unit is equipped with (or uses) a control device

designed to collect and recover VOM (e.g., carbon adsorber), an

explicit measurement of capture efficiency is not necessary

provided that the conditions given below are met. The overall

control of the system can be determined by directly comparing the

input liquid VOM to the recovered liquid VOM. The general

procedure for use in this situation is given in 40 CFR 60.433,

incorporated by reference in Section 218.112 of this Part, with the

following additional restrictions:

i) Unless otherwise specified in subsection (c)(1)(B)(ii)

below, the owner or operator shall obtain data each

operating day for the solvent usage and solvent recovery to

permit the determination of the solvent recovery efficiency

of the system each operating day using a 7-day rolling

period. The recovery efficiency for each operating day is

computed as the ratio of the total recovered solvent for that

day and the most recent prior 6 operating days to the total

solvent usage for the same 7-day period used for the

recovered solvent, rather than a 30-day weighted average as

given in 40 CFR 60.433 incorporated by reference at

Section 218.112 of this Part. This ratio shall be expressed

as a percentage. The ratio shall be computed within 72

hours following each 7-day period. A source that believes

that the 7-day rolling period is not appropriate may use an

alterative multi-day rolling period not to exceed 30 days,

with the approval of the Agency and USEPA. In addition,

the criteria in subsection (c)(1)(B)(iii) or subsection

(c)(1)(B)(iv) below must be met.

ii) The owner or operator of the source engaged in printing

located at 350 E. 22nd Street, Chicago, Illinois, shall obtain

data each operating day for the solvent usage and solvent

recovery to permit the determination of the solvent

recovery efficiency of the system each operating day using

a 14-day rolling period. The recovery efficiency for each

operating day is computed as the ratio of the total recovered

solvent for that day and the most recent prior 13 operating

days to the total solvent usage for the same 14-day period

used for the recovered solvent, rather than a 30-day

weighted average as given in 40 CFR 60.433, incorporated

by reference in Section 218.112 of this Part. This ratio

shall be expressed as a percentage. The ratio shall be

computed within 17 days following each 14-day period. In

addition, the criteria in subsection (c)(1)(B)(iii) or

subsection (c)(1)(B)(iv) below must be met.

iii) The solvent recovery system (i.e., capture and control

system) must be dedicated to a single coating line, printing

line, or other discrete activity that by itself is subject to an

applicable VOM emission standard, or

iv) If the solvent recovery system controls more than one

coating line, printing line or other discrete activity that by

itself is subject to an applicable VOM emission standard,

the overall control (i.e. the total recovered VOM divided by

the sum of liquid VOM input from all lines and other

activities venting to the control system) must meet or

exceed the most stringent standard applicable to any line or

other discrete activity venting to the control system.

2) Capture Efficiency Protocols Specific Requirements

The capture efficiency of an emission unit shall be measured using one of

the four protocols given below. Appropriate test methods to be utilized in

each of the capture efficiency protocols are described in Appendix M of

40 CFR Part 51, incorporated by reference at Section 218.112 of this Part.

Any error margin associated with a test method or protocol may not be

incorporated into the results of a capture efficiency test. If these

techniques are not suitable for a particular process, then an alternative

capture efficiency protocol may be used, pursuant to the provisions of

Section 218.108(b) of this Part provided that the alternative protocol is

approved by the Agency and approved by the USEPA as a SIP revision.

A) Gas/gas method using temporary total enclosure (TTE). The

Agency and USEPA specifications to determine whether a

temporary enclosure is considered a TTE are given in Method 204

Procedure T of Appendix M of 40 CFR Part 51, incorporated by

reference in Section 218.112 of this Part. Appendix B of this Part.

The capture efficiency equation to be used for this protocol is:

CE = Gww/(Gww + Fww)

where:

CE = Capture efficiency, decimal fraction;

Gww = Mass of VOM captured and delivered to control device

using a TTE;

Fww = Mass of uncaptured fugitive VOM that escapes from

a TTE.

Method 204B or 204C Procedure G.2 contained in Appendix M of

40 CFR Part 51 Appendix B of this Part is used to obtain Gww.

Method 204D Procedure F.1 in Appendix B in Appendix M of 40

CFR Part 51 of this Part, is used to obtain Fww.

B) Liquid/gas method using TTE. The Agency and USEPA

specifications to determine whether a temporary enclosure is

considered a TTE are given in Method 204 Procedure T of

Appendix M of 40 CFR Part 51, incorporated by reference in

Section 218.112 of this Part. Appendix B of this Part. The capture

efficiency equation to be used for this protocol is:

CE = (L - Fww) /L

where:

CE = Capture efficiency, decimal fraction;

L = Mass of liquid VOM input to process emission unit;

Fww = Mass of uncaptured fugitive VOM that escapes from

a TTE.

Method 204A or 204F Procedure L contained in Appendix B of

this Part. Appendix M of 40 CFR Part 51 is used to obtain L.

Method 204D Procedure F.1 in Appendix M of 40 CFR Part 51

Appendix B of this Part is used to obtain Fww.

C) Gas/gas method using the building or room (building or room

enclosure), in which the affected coating line, printing line or other

emission unit is located, as the enclosure as determined by Method

204 of Appendix M of 40 CFR Part 51, incorporated by reference

in Section 218.112 of this Part, and in which "FB" "F" and "G" are

measured while operating only the affected line or emission unit.

All fans and blowers in the building or room must be operated as

they would under normal production. The capture efficiency

equation to be used for this protocol is:

CE = G/(G +FB)

where:

CE = Capture efficiency, decimal fraction;

G = Mass of VOM captured and delivered to control

device;

FB = Mass of uncaptured fugitive VOM that escapes from

building enclosure.

Method 204B or 204C Procedure G.2 contained in Appendix B of

this Part Appendix M of 40 CFR Part 51 is used to obtain G.

Method 204E Procedure F.2 in Appendix B of this Part Appendix

M of 40 CFR Part 51 is used to obtain FB.

D) Liquid/gas method using the building or room (building or room

enclosure), in which the affected coating line, printing line or other

emission unit is located, as the enclosure as determined by Method

204 of Appendix M of 40 CFR Part 51, incorporated by reference

in Section 218.112 of this Part, and in which "FB" "F" and "L" are

measured while operating only the affected line or emission unit.

All fans and blowers in the building or room must be operated as

they would under normal production. The capture efficiency

equation to be used for this protocol is:

CE = (L - FB) /L

where:

CE = Capture efficiency, decimal fraction;

L = Mass of liquid VOM input to process emission unit;

FB = Mass of uncaptured fugitive VOM that escapes from

building enclosure.

Method 204A or 204F Procedure L contained in Appendix B of

this Part Appendix M of 40 CFR Part 51 is used to obtain L.

Method 204E Procedure F.2 in Appendix B of this Part Appendix

M of 40 CFR Part 51 is used to obtain FB.

E) Mass balance using Data Quality Objective (DQO) or Lower

Confidence Limit (LCL) protocol. For a liquid/gas input where an

owner or operator is using the DQO/LCL protocol and not using an

enclosure as described in Method 204 of Appendix M of 40 CFR

Part 51, incorporated by reference in Section 218.112 of this Part,

the VOM content of the liquid input (L) must be determined using

Method 204A or 204F in Appendix M of 40 CFR Part 51. The

VOM content of the captured gas stream (G) to the control device

must be determined using Method 204B or 204C in Appendix M

of 40 CFR Part 51. The results of capture efficiency calculations

(G/L) must satisfy the DQO or LCL statistical analysis protocol as

described in Section 3 of USEPA’s “Guidelines for Determining

Capture Efficiency,” incorporated by reference at 218.112 of this

Part. Where capture efficiency testing is done to determine

emission reductions for the purpose of establishing emission

credits for offsets, shutdowns, and trading, the LCL protocol

cannot be used for these applications. In enforcement cases, the

LCL protocol cannot confirm non-compliance.

3) Simultaneous testing of multiple lines or emission units with a common

control device. If an owner or operator has multiple lines sharing a

common control device, the capture efficiency of the lines may be tested

simultaneously, subject to the following provisions:

A) Multiple line testing must meet the criteria of Section 4 of

USEPA’s “Guidelines for Determining Capture Efficiency,”

incorporated by reference at Section 218.112 of this Part;

B) The most stringent capture efficiency required for any individual

line or unit must be met by the aggregate of lines or units; and

C) Testing of all the lines of emission units must be performed with

the same capture efficiency test protocol.

4)3) Recordkeeping and Reporting

A) All owners or operators affected by this subsection must maintain a

copy of the capture efficiency protocol submitted to the Agency

and the USEPA on file. All results of the appropriate test methods

and capture efficiency protocols must be reported to the Agency

within sixty (60) days of the test date. A copy of the results must

be kept on file with the source for a period of three (3) years.

B) If any changes are made to capture or control equipment, then the

source is required to notify the Agency and the USEPA of these

changes and a new test may be required by the Agency or the

USEPA.

C) The source must notify the Agency 30 days prior to performing

any capture efficiency or control test. At that time, the source must

notify the Agency which capture efficiency protocol and control

device test methods will be used. Notification of the actual date

and expected time of testing must be submitted a minimum of 5

working days prior to the actual date of the test. The Agency may

at its discretion accept notification with shorter advance notice

provided that such arrangements do not interfere with the

Agency’s ability to review the protocol or observe testing.

D) Sources utilizing a PTE must demonstrate that this enclosure meets

the requirements given in Method 204 Procedure T (in Appendix

M of 40 CFR Part 51, incorporated by reference in Section

218.112 of this Part, Appendix B of this Part) for a PTE during any

testing of their control device.

E) Sources utilizing a TTE must demonstrate that their TTE meets the

requirements given in Method 204 Procedure T (in Appendix M of

40 CFR Part 51, incorporated by reference in Section 218.112 of

this Part, Appendix B of this Part) for a TTE during testing of their

control device. The source must also provide documentation that

the quality assurance criteria for a TTE have been achieved.

F) Any source utilizing the DQO or LCL protocol must submit the

following information to the Agency with each test report:

i) A copy of all test methods, Quality Assurance/Quality

Control procedures, and calibration procedures to be used

from those described in Appendix M of 40 CFR Part 51,

incorporated by reference in Section 218.112 of this Part;

ii) A table with information on each sample taken, including

the sample identification and the VOM content of the

sample;

iii) The quantity of material used for each test run;

iv) The quantity of captured VOM for each test run;

v) The capture efficiency calculations and results for each test

run;

vi) The DQO and/or LCL calculations and results; and

vii) The Quality Assurance/Quality Control results, including

how often the instruments were calibrated, the calibration

results, and the calibration gases used.

d) Control Device Efficiency Testing and Monitoring

1) The control device efficiency shall be determined by simultaneously

measuring the inlet and outlet gas phase VOM concentrations and gas

volumetric flow rates in accordance with the gas phase test methods

specified in subsection (f) of this Section.

2) An owner or operator:

A) That uses an afterburner or carbon adsorber to comply with any

Section of Part 218 shall use Agency and USEPA approved

continuous monitoring equipment which is installed, calibrated,

maintained, and operated according to vendor specifications at all

times the afterburner or carbon adsorber control device is in use

except as provided in subsection (d)(3) of this Section. The

continuous monitoring equipment must monitor the following

parameters:

i) For each afterburner which does not have a catalyst bed,

the combustion chamber temperature of each afterburner.

ii) For each afterburner which has a catalyst bed, commonly

known as a catalytic afterburner, the temperature rise

across each catalytic afterburner bed or VOM concentration

of exhaust.

iii) For each carbon adsorber, the VOM concentration of each

carbon adsorption bed exhaust or the exhaust of the bed

next in sequence to be desorbed.

B) Must install, calibrate, operate and maintain, in accordance with

manufacturer’s specifications, a continuous recorder on the

temperature monitoring device, such as a strip chart, recorder or

computer, having an accuracy of ± 1 percent of the temperature

measured in degrees Celsius or ± 0.5

C, whichever is greater.

CB) Of an automobile or light-duty truck primer surfacer operation or

topcoat operation subject to subsection (d)(2)(A) above, shall keep

a separate record of the following data for the control devices,

unless alternative provisions are set forth in a permit pursuant to

Title V of the Clean Air Act:

i) For thermal afterburners for which combustion chamber

temperature is monitored, all 3-hour periods of operation in

which the average combustion temperature was more than

C (50

F) below the average combustion temperature

measured during the most recent performance test that

demonstrated that the operation was in compliance.

ii) For catalytic afterburners for which temperature rise is

monitored, all 3-hour periods of operation in which the

average gas temperature before the catalyst bed is more

than 28

C (50

F) below the average gas temperature

immediately before the catalyst bed measured during the

most recent performance test that demonstrated that the

operation was in compliance.

iii) For catalytic afterburners and carbon adsorbers for which

VOM concentration is monitored, all 3-hour periods of

operation during which the average VOM concentration or

the reading of organics in the exhaust gases is more than 20

percent greater than the average exhaust gas concentration

or reading measured by the organic monitoring device

during the most recent determination of the recovery

efficiency of a carbon adsorber or performance test for a

catalytic afterburner, which determination or test

demonstrated that the operation was in compliance.

3) An owner or operator that uses a carbon adsorber to comply with Section

218.401 of this Part may operate the adsorber during periods of

monitoring equipment malfunction, provided that:

A) The owner or operator notifies in writing the Agency within, 10

days after the conclusion of any 72 hour period during which the

adsorber is operated and the associated monitoring equipment is

not operational, of such monitoring equipment failure and provides

the duration of the malfunction, a description of the repairs made

to the equipment, and the total to date of all hours in the calendar

year during which the adsorber was operated and the associated

monitoring equipment was not operational;

B) During such period of malfunction the adsorber is operated using

timed sequences as the basis for periodic regeneration of the

adsorber;

C) The period of such adsorber operation does not exceed 360 hours

in any calendar year without the approval of the Agency and

USEPA; and

D) The total of all hours in the calendar year during which the

adsorber was operated and the associated monitoring equipment

was not operational shall be reported, in writing, to the Agency and

USEPA by January 31st of the following calendar year.

e) Overall Efficiency

1) The overall efficiency of the emission control system shall be determined

as the product of the capture system efficiency and the control device

efficiency or by the liquid/liquid test protocol as specified in 40 CFR

60.433, incorporated by reference in Section 218.112 of this Part, (and

revised by subsection (c)(1)(B) of this Section) for each solvent recovery

system. In those cases in which the overall efficiency is being determined

for an entire line, the capture efficiency used to calculate the product of

the capture and control efficiency is the total capture efficiency over the

entire line.

2) For coating lines which are both chosen by the owner or operator to

comply with Section 218.207(c), (d), (e), (f), or (g) of this Part by the

alternative in Section 218.207(b)(2) of this Part and meet the criteria

allowing them to comply with Section 218.207 of this Part instead of

Section 218.204 of this Part, the overall efficiency of the capture system

and control device, as determined by the test methods and procedures

specified in subsections (c), (d) and (e)(1) of this Section, shall be no less

than the equivalent overall efficiency which shall be calculated by the

following equation:

E = ([VOMa - VOM1]/VOMa) x 100

where:

E = Equivalent overall efficiency of the capture system and control

device as a percentage;

VOMa = Actual VOM content of a coating, or the daily-weighted

average VOM content of two or more coatings (if more

than one coating is used), as applied to the subject coating

line as determined by the applicable test methods and

procedures specified in subsection (a) of this Section in

units of kg VOM/l (lb VOM/gal) of coating solids as

applied;

VOM1 = The VOM emission limit specified in Section 218.204 or

218.205 of this Part in units of kg VOM/l (lb VOM/gal) of

coating solids as applied

f) Volatile Organic Material Gas Phase Source Test Methods. The methods in 40

CFR Part 60, Appendix A, incorporated by reference in Section 218.112 of this

Part delineated below shall be used to determine control device efficiencies.

1) 40 CFR Part 60, Appendix A, Method 18, 25 or 25A, incorporated by

reference in Section 218.112 of this Part as appropriate to the conditions at

the site, shall be used to determine VOM concentration. Method selection

shall be based on consideration of the diversity of organic species present

and their total concentration and on consideration of the potential presence

of interfering gases. Except as indicated in subsections (f)(1)(A) and (B)

below, the test shall consist of three separate runs, each lasting a minimum

of 60 min, unless the Agency and the USEPA determine that process

variables dictate shorter sampling times.

A) When the method is to be used to determine the efficiency of a

carbon adsorption system with a common exhaust stack for all the

individual adsorber vessels, the test shall consist of three separate

runs, each coinciding with one or more complete sequences

through the adsorption cycles of all the individual absorber vessels.

B) When the method is to be used to determine the efficiency of a

carbon adsorption system with individual exhaust stacks for each

absorber vessel, each adsorber vessel shall be tested individually.

The test for each absorber vessel shall consist of three separate

runs. Each run shall coincide with one or more complete

adsorption cycles.

2) 40 CFR Part 60, Appendix A, Method 1 or 1A, incorporated by reference

in Section 218.112 of this Part, shall be used for sample and velocity

traverses.

3) 40 CFR Part 60, Appendix A, Method 2, 2A, 2C or 2D, incorporated by

reference in Section 218.112 of this Part, shall be used for velocity and

volumetric flow rates.

4) 40 CFR Part 60, Appendix A, Method 3, incorporated by reference in

Section 218.112 of this Part, shall be used for gas analysis.

5) 40 CFR Part 60, Appendix A, Method 4, incorporated by reference in

Section 218.112 of this Part, shall be used for stack gas moisture.

6) 40 CFR Part 60, Appendix A, Methods 2, 2A, 2C, 2D, 3 and 4,

incorporated by reference in Section 218.112 of this Part, shall be

performed, as applicable, at least twice during each test run.

7) Use of an adaptation to any of the test methods specified in subsections

(f)(1), (2), (3), (4), (5) and (6) of this Section may not be used unless

approved by the Agency and the USEPA on a case by case basis. An

owner or operator must submit sufficient documentation for the Agency

and the USEPA to find that the test methods specified in subsections

(f)(1), (2), (3), (4), (5) and (6) of this Section will yield inaccurate results

and that the proposed adaptation is appropriate.

g) Leak Detection Methods for Volatile Organic Material

Owners or operators required by this Part to carry out a leak detection monitoring

program shall comply with the following requirements:

1) Leak Detection Monitoring

A) Monitoring shall comply with 40 CFR 60, Appendix A, Method

21, incorporated by reference in Section 218.112 of this Part.

B) The detection instrument shall meet the performance criteria of

Method 21.

C) The instrument shall be calibrated before use on each day of its use

by the methods specified in Method 21.

D) Calibration gases shall be:

i) Zero air (less than 10 ppm of hydrocarbon in air); and

ii) A mixture of methane or n-hexane and air at a

concentration of approximately, but no less than, 10,000

ppm methane or n-hexane.

E) The instrument probe shall be traversed around all potential leak

interfaces as close to the interface as possible as described in

Method 21.

2) When equipment is tested for compliance with no detectable emissions as

required, the test shall comply with the following requirements:

A) The requirements of subsections (g)(1)(A) through (g)(1)(E) of this

Section above shall apply.

B) The background level shall be determined as set forth in Method

21.

3) Leak detection tests shall be performed consistent with:

A) “APTI Course SI 417 controlling Volatile Organic Compound

Emissions from Leaking Process Equipment”, EPA-450/2-82-015,

incorporated by reference in Section 218.112 of this Part.

B) “Portable Instrument User's Manual for Monitoring VOC

Sources”, EPA-340/1-86-015, incorporated by reference in Section

218.112 of this Part.

C) “Protocols for Generating Unit-Specific Emission Estimates for

Equipment Leaks of VOC and VHAP”, EPA-450/3-88-010,

incorporated by reference in Section 218.112 of this Part.

D) “Petroleum Refinery Enforcement Manual”, EPA-340/1-80-008,

incorporated by reference in Section 218.112 of this Part.

h) Bulk Gasoline Delivery System Test Protocol

1 The method for determining the emissions of gasoline from a vapor

recovery system are delineated in 40 CFR 60, Subpart XX, Section

60.503, incorporated by reference in Section 218.112 of this Part.

2) Other tests shall be performed consistent with:

A) “Inspection Manual for Control of Volatile Organic Emissions

from Gasoline Marketing Operations: Appendix D”, EPA-340/1-

80-012, incorporated by reference in Section 218.112 of this Part.

B) “Control of Hydrocarbons from Tank Truck Gasoline Loading

Terminals: Appendix A”, EPA-450/2-77-026, incorporated by

reference in Section 218.112 of this Part.

i) Notwithstanding other requirements of this Part, upon request of the Agency

where it is necessary to demonstrate compliance, an owner or operator of an

emission unit which is subject to this Part shall, at his own expense, conduct tests

in accordance with the applicable test methods and procedures specific in this

Part. Nothing in this Section shall limit the authority of the USEPA pursuant to

the Clean Air Act, as amended, to require testing.

j) Stage II Gasoline Vapor Recovery Test Methods

The methods for determining the acceptable performance of Stage II Gasoline

Vapor Recovery System are delineated in "Technical Guidance-Stage II Vapor

Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline

Dispensing Facilities," found at EPA 450/3-91-022b and incorporated by

reference in Section 218.112 of this Part. Specifically, the test methods are as

follows:

1) Dynamic Backpressure Test is a test procedure used to determine the

pressure drop (flow resistance) through balance vapor collection and

control systems (including nozzles, vapor hoses, swivels, dispenser piping

and underground piping) at prescribed flow rates.

2) Pressure Decay/Leak Test is a test procedure used to quantify the vapor

tightness of a vapor collection and control system installed at gasoline

dispensing facilities.

3) Liquid Blockage Test is a test procedure used to detect low points in any

vapor collection and control system where condensate may accumulate.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.112 Incorporations by Reference

The following materials are incorporated by reference and do not contain any subsequent

additions or amendments.

a) American Society for Testing and Materials, 100 Barr Harbor Drive, West

Conshohocken, PA 19428-9555:

1) ASTM D2879-86

2) ASTM D323-82

3) ASTM D86-82

4) ASTM D-369-69 (1971)

5) ASTM D-396-69

6) ASTM D2880-71

7) ASTM D-975-68

8) ASTM D3925-81 (1985)

13) ASTM D4017-81 (1987)

20) ASTM E-168-67 (1977)

25) ASTM D323-82 (approved 1982)

26) ASTM D2099-00

b) Standard Industrial Classification Manual, published by Executive Office of the

President, Office of Management and Budget, Washington, D.C., 1987.

c) American Petroleum Institute Bulletin 2517, "Evaporation Loss From Floating Roof

Tanks", Second ed., February 1980.

d) 40 CFR 60 (July 1, 1991) and 40 CFR 60, Appendix A, Method 24 (57 FR 30654, July

10, 1992).

e) 40 CFR 61 (July 1, 1991).

f) 40 CFR 50 (July 1, 1991).

g) 40 CFR 51 (July 1, 1991) and 40 CFR Part 51 Appendix M, Methods 204-204F (July 1,

1999).

h) 40 CFR 52 (July 1, 1991).

i) 40

CFR 80 (July 1, 1991) and 40 CFR Part 80 Appendixes D, E, and F (July 1, 1993).

j) "A Guide for Surface Coating Calculation", United States Environmental Protection

Agency, Washington, D.C., EPA-340/1-86-016.

k) "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by Paint,

Ink and Other Coating", (revised June 1986), United States Environmental Protection

Agency, Washington, D.C., EPA-450/3-84-019.

l) "A Guide for Graphic Arts Calculations", August 1988, United States Environmental

Protection Agency, Washington, D.C., EPA-340/1-88-003.

m) "Protocol for Determining the Daily Volatile Organic Compound Emission Rate of

Automobile and Light-Duty Truck Topcoat Operations", December 1988, United States

Environmental Protection Agency, Washington, D.C., EPA-450/3-88-018.

n) "Control of Volatile Organic Emissions from Manufacturing of Synthesized

Pharmaceutical Products", United States Environmental Protection Agency, Washington,

D.C., EPA-450/2-78-029.

o) "Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and Vapor

Collection Systems", Appendix B, United States Environmental Protection Agency,

Washington, D.C., EPA-450/-78-051.

p) "Control of Volatile Organic Compound Emissions from Large Petroleum Dry Cleaners",

United States Environmental Protection Agency, Washington, D.C., EPA-450/3-82-009.

q) "APTI Course SI417 Controlling Volatile Organic Compound Emissions from Leaking

Process Equipment", United States Environmental Protection Agency, Washington, D.C.,

EPA-450/2-82-015.

r) "Portable Instrument User's Manual for Monitoring VOC Sources", United States

Environmental Protection Agency, Washington, D.C., EPA-340/1-86-015.

s) "Protocols for Generating Unit-Specific Emission Estimates for Equipment Leaks of

VOC and VHAP", Unites States Environmental Protection Agency, Washington, D.C.,

EPA-450/3-88-010.

t) "Petroleum Refinery Enforcement Manual", United States Environmental Protection

Agency, Washington, D.C., EPA-340/1-80-008.

u) "Inspection Manual for Control of Volatile Organic Emissions from Gasoline Marketing

Operations: Appendix D", United States Environmental Protection Agency, Washington,

D.C., EPA-340/1-80-012.

v) "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals: Appendix A",

United States Environmental Protection Agency, Washington, D.C., EPA-450/2-77-026.

w) "Technical Guidance-Stage II Vapor Recovery Systems for Control of Vehicle Refueling

Emissions at Gasoline Dispensing Facilities", United States Environmental Protection

Agency, Washington, D.C., EPA-450/3-91-022b.

x) California Air Resources Board, Compliance Division. Compliance Assistance Program:

Gasoline Marketing and Distribution: Gasoline Facilities Phase I & II (October 1988, rev.

November 1993) (CARB Manual).

y) South Coast Air Quality Management District (SCAQMD), Applied Science &

Technology Division, Laboratory Services Branch, SCAQMD Method 309-91,

Determination of Static Volatile Emissions.

z) South Coast Air Quality Management District (SCAQMD), Applied Science &

Technology Division, Laboratory Services Branch, SCAQMD Method 312-91,

Determination of Percent Monomer in Polyester Resins.

aa) “Guidelines for Determining Capture Efficiency,” Office of Air Quality Planning and

Standards, United States Environmental Protection Agency, Research Triangle Park, NC.

January, 1995.

bb) Memorandum “Revised Capture Efficiency Guidance for Control of Volatile Organic

Compound Emissions,” John S. Seitz, Director, Office of Air Quality Planning and

Standards, United States Environmental Protection Agency, February, 1995.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

SUBPART F: COATING OPERATIONS

Section 218.204 Emission Limitations

Except as provided in Sections 218.205, 218.207, 218.208, 218.212, 218.215 and 218.216 of this

Subpart, no owner or operator of a coating line shall apply at any time any coating in which the

VOM content exceeds the following emission limitations for the specified coating. Except as

provided in Section 218.204(l), compliance with the emission limitations marked with an asterisk

in this Section is required on and after March 15, 1996, and compliance with emission

limitations not marked with an asterisk is required until March 15, 1996. The following emission

limitations are expressed in units of VOM per volume of coating (minus water and any

compounds which are specifically exempted from the definition of VOM) as applied at each

coating applicator, except where noted. Compounds which are specifically exempted from the

definition of VOM should be treated as water for the purpose of calculating the "less water" part

of the coating composition. Compliance with this Subpart must be demonstrated through the

applicable coating analysis test methods and procedures specified in Section 218.105(a) of this

Part and the recordkeeping and reporting requirements specified in Section 218.211(c) of this

Subpart except where noted. (Note: The equation presented in Section 218.206 of this Part shall

be used to calculate emission limitations for determining compliance by add-on controls, credits

for transfer efficiency, emissions trades and cross-line averaging.) The emission limitations are

as follows:

a) Automobile or Light-Duty Truck Coating

(Note: The primer surface coat limitation is in units of kg (lbs) of VOM

per l (gal) of coating solids deposited. Compliance with the limitation

shall be based on the daily-weighted average from an entire primer

surfacer operation. Compliance shall be demonstrated in accordance with

the topcoat protocol referenced in Section 218.105(b) and the

recordkeeping and reporting requirements specified in Section 218.211(f).

Testing to demonstrate compliance shall be performed in accordance with

the topcoat protocol and a detailed testing proposal approved by the

Agency and USEPA specifying the method of demonstrating compliance

with the protocol. Section 218.205 does not apply to the primer surfacer

(Note: The topcoat limitation is in units of kg (lbs) of VOM per l (gal) of

coating solids deposited. Compliance with the limitation shall be based on

the daily-weighted average from an entire topcoat operation. Compliance

shall be demonstrated in accordance with the topcoat protocol referenced

in Section 218.105(b) of this Part and the recordkeeping and reporting

requirements specified in Section 218.211(f). Testing to demonstrate

compliance shall be performed in accordance with the topcoat protocol

and a detailed testing proposal approved by the Agency and USEPA

specifying the method of demonstrating compliance with the protocol.

Section 218.205 of this Part does not apply to the topcoat limitation.)

Sheet basecoat and overvarnish

Exterior basecoat and overvarnish

Interior body spray coat

End sealing compound coat

(Note: The paper coating limitation shall not apply to any owner or operator of

any paper coating line on which flexographic or rotogravure printing is performed

if the paper coating line complies with the emissions limitations in Subpart H:

Printing and Publishing, Section 218.401 of this Part. In addition, screen printing

on paper is not regulated as paper coating, but is regulated under Subpart TT of

Metal Furniture Coating

Large Appliance Coating

(Note: The limitation shall not apply to the use of quick-drying lacquers

for repair of scratches and nicks that occur during assembly, provided that

the volume of coating does not exceed 0.95 l (1 quart) in any one rolling

Miscellaneous Metal Parts and Products

Extreme performance coating

Steel pail and drum interior

ii) Corrosion resistant

A) For purposes of subsection 218.204(j)(5) of this Section, the

following terms are defined:

i) "Corrosion resistant basecoat" means, for purposes of

subsection 218.204(j)(5)(B)(ii) of this Section, a water-

borne epoxy coating applied via an electrodeposition

process to a metal surface prior to spray coating, for the

purpose of enhancing corrosion resistance.

ii) "Electrodeposition process" means, for purposes of

subsection 218.204(j)(5) of this Section, a water-borne dip

coating process in which opposite electrical charges are

applied to the substrate and the coating. The coating is

attracted to the substrate due to the electrochemical

potential difference that is created.

iii) "Marine engine coating" means, for purposes of subsection

218.204(j)(5) of this Section, any extreme performance

protective, decorative or functional coating applied to an

engine that is used to propel watercraft.

B) For purposes of subsection 218.204(j)(6) of this Section, "metallic

coating" means a coating which contains more than 1/4 lb/gal of

metal particles, as applied.

Heavy Off-Highway Vehicle Products

Coating

kg/l lb/gal

Extreme performance prime coat

Extreme performance topcoat (air

Final repair coat (air dried)

4) All other coatings are subject to the emission limitations for miscellaneous

metal parts and products coatings in subsection (j) above.

l) Wood Furniture Coating

Limitations before March 15,

F) Semi-transparent stain

(Note: Prior to March 15, 1998, an owner or operator of a wood

furniture coating operation subject to this Section shall apply all

coatings, with the exception of no more than 37.8 l (10 gal) of

coating per day used for touch-up and repair operations, using one

or more of the following application systems: airless spray

application system, air-assisted airless spray application system,

electrostatic spray application system, electrostatic bell or disc

spray application system, heated airless spray application system,

roller coating, brush or wipe coating application system, dip

coating application system or high volume low pressure (HVLP)

application system.)

2) On and after March 15, 1998, wood furniture sealers and topcoats must

comply with one of the limitations specified in subsections (l)(2)(A)

Sealers and topcoats with

the following limits:

iii) Acid-cured alkyd

C) Meet the provisions of Section 218.215 of this Subpart for use of

an averaging approach;

D) Achieve a reduction in emissions equivalent to the requirements of

subsection (l)(2)(A) or (B) of this Section, as calculated using

Section 218.216 of this Subpart; or

E) Use a combination of the methods specified in subsections

(l)(2)(A) through (D) of this Section.

3) Other wood furniture coating limitations on and after March 15, 1998:

B) Non-topcoat pigmented

D) Semi-transparent stain

4) Other wood furniture coating requirements on and after March 15, 1998:

A) No source subject to the limitations of subsection (l)(2) or (3) of

this Section and utilizing one or more wood furniture coating spray

booths shall use strippable spray booth coatings containing more

than 0.8 kg VOM/kg solids (0.8 lb VOM/lb solids), as applied.

B) Any source subject to the limitations of subsection (l)(2) or (3) of

this Section shall comply with the requirements of Section 218.217

of this Subpart.

C) Any source subject to the limitations of subsection (l)(2)(A) or (B)

of this Section and utilizing one or more continuous coaters shall,

for each continuous coater, use an initial coating which complies

with the limitations of subsection (l)(2)(A) or (B) of this Section.

The viscosity of the coating in each reservoir shall always be

greater than or equal to the viscosity of the initial coating in the

reservoir. The owner or operator shall:

i) Monitor the viscosity of the coating in the reservoir with a

viscosity meter or by testing the viscosity of the initial

coating and retesting the coating in the reservoir each time

solvent is added;

ii) Collect and record the reservoir viscosity and the amount

and weight of VOM per weight of solids of coating and

solvent each time coating or solvent is added; and

iii) Maintain these records at the source for a period of three

years.

m) Existing Diesel-Electric Locomotive

Coating Lines in Cook County

kg/l lb/gal

Extreme performance prime coat

Extreme performance top-coat (air

Final repair coat (air dried)

4) High-temperature aluminum

Plastic Parts Coating:

Automotive/Transportation

Exteriors (flexible and non-

ii) Primer non-flexible

iv) Color coat (others)

0.61*

(5.1)*

3) Specialty

A) Vacuum metallizing

basecoats, texture

basecoats

0.66* (5.5)*

Black coatings, reflective

argent coatings, air bag

cover coatings, and soft

0.71* (5.9)*

coatings

Gloss reducers, vacuum

metallizing topcoats, and

texture topcoats

0.77* (6.4)*

Stencil coatings, adhesion

primers, ink pad coatings,

electrostatic prep coatings,

and resist coatings

0.82* (6.8)*

Head lamp lens coatings

0.89*

(7.4)*

Plastic Parts Coating: Business Machine

Color coat (non-texture coat)

0.28*

(2.3)*

Color coat (texture coat)

0.28*

(2.3)*

4) Electromagnetic interference/radio

frequency interference (EMI/RFI)

shielding coatings

0.48* (4.0)*

5) Specialty Coatings

C) Plating sensitizer

0.85*

(7.1)*

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.405 Lithographic Printing: Applicability

a) Until March 15, 1996, the limitations of Section 218.406 of this Subpart apply to

all heatset web offset lithographic printing lines (including solvents used for

cleanup operations associated with the heatset web offset lithographic printing

line(s)) at a source subject to the requirements of this Subpart. All sources with

heatset web offset lithographic printing lines are sources subject to the

requirements of this Subpart unless:

1) Total maximum theoretical emissions of VOM from all heatset web offset

lithographic printing lines (including solvents used for cleanup operations

associated with the heatset web offset lithographic printing line(s)) at the

source never exceed 90.7 Mg (100 tons) per calendar year in the absence

of air pollution control equipment; or

2) A federally enforceable permit or SIP revision for all heatset web offset

lithographic printing line(s) at a source requires the owner or operator to

limit production or capacity of these printing line(s) to reduce total VOM

emissions from all heatset web offset lithographic printing line(s) to 90.7

Mg (100 tons) per calendar year or less in the absence of air pollution

control equipment.

b) Any owner or operator of any heatset web offset lithographic printing line that is

exempt from the limitations in Section 218.406 of this Subpart because of the

criteria in subsection (a) of this Section shall be subject to the recordkeeping and

reporting requirements in Section 218.406(b)(1) of this Subpart.

c) On and after March 15, 1996, every owner or operator of lithographic printing

line(s) is subject to the recordkeeping and reporting requirements in Section

218.411 of this Subpart.

d) On and after March 15, 1996, Sections 218.407 through 218.410 218.411 of this

Subpart shall apply to:

1) All owners or operators of heatset web offset lithographic printing line(s)

unless:

A) Total maximum theoretical emissions of VOM from all heatset

web offset lithographic printing lines (including solvents used for

cleanup operations associated with heatset web offset lithographic

printing lines) at the source never exceed 90.7 Mg (100 tons) per

calendar year before the application of capture systems and control

devices. To determine a source's total maximum theoretical

emissions of VOM for the purposes of this subsection, the owner

or operator shall use the calculations set forth in Section

218.406(b)(1)(A)(ii) of this Subpart; or

B) Federally enforceable permit conditions or SIP revision for all

heatset web offset lithographic printing line(s) at the source

requires the owner or operator to limit production or capacity of

these printing line(s) to total VOM emissions of 90.7 Mg/yr (100

TPY) or less, before the application of capture systems and control

devices;

2) All owners or operators of heatset web offset, non-heatset web offset, or

sheet-fed offset lithographic printing line(s), unless the combined

emissions of VOM from all lithographic printing line(s) at the source

(including solvents used for cleanup operations associated with the

lithographic printing line(s)) never exceed 45.5 kg/day (100 lbs/day), as

determined in accordance with Section 218.411(a)(1)(B), before the

application of capture systems and control devices.

e) If a lithographic printing line at a source is or becomes subject to one or more of

the limitations in Sections 218.406 or 218.407 of this Subpart, the lithographic

printing line(s) at the source are always subject to the applicable provisions of this

Subpart.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to

March 15, 1996

a) Emission Standards and Limitations. No owner or operator of a heatset web

offset printing line at a source that meets or exceeds the applicability levels in

Section 218.405(a) of this Subpart may cause or allow the operation of such

heatset web offset printing line(s) unless the owner or operator meets the

requirements in subsections (a)(1) or (a)(2) of this Section and the requirements in

subsections (a)(3) and (a)(4) of this Section. The owner or operator shall

demonstrate compliance with this Section by using the applicable test methods

and procedures specified in Section 218.105(a), (d), and (f) of this Part and by

complying with the recordkeeping and reporting requirements specified in

subsection (b) of this Section.

1) An afterburner system is installed and operated that reduces 90 percent of

the VOM emissions (excluding methane and ethane) from the dryer

exhaust; or

2) The fountain solution contains no more than 8 percent, by weight, of

VOM and a condensation recovery system is installed and operated that

removes at least 75 percent of the non-isopropyl alcohol organic materials

from the dryer exhaust; and

3) The control device is equipped with the applicable monitoring equipment

specified in Section 218.105(d)(2) of this Part and the monitoring

equipment is installed, calibrated, operated and maintained according to

manufacturer's specifications at all times when the control device is in use;

and

4) The control device is operated at all times when the printing line is in

operation.

b) Recordkeeping and Reporting. The VOM content of each fountain solution and

ink and the efficiency of each control device shall be determined by the applicable

test methods and procedures specified in Section 218.105 of this Part to establish

the records required under this subsection.

1) Any owner or operator of a lithographic printing line which is exempted

from the limitations of subsection (a) of this Section because of the criteria

in 218.405(a) of this Subpart shall comply with the following:

A) By a date consistent with Section 218.106 of this Part, the owner or

operator of a heatset web offset lithographic printing line to which

subsection (b)(1) of this Section is applicable shall certify to the

Agency that the heatset web offset lithographic printing line is

exempt under the provisions of Section 218.405(a) of this Subpart.

Such certification shall include:

i) A declaration that the heatset web offset lithographic

printing line is exempt from the limitations of subsection

(a) of this Section because of the criteria in Section

218.405(a) of this Subpart; and

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 of

air pollution control equipment. Total maximum

theoretical emissions of VOM for a heatset web offset

lithographic printing source is the sum of maximum

theoretical emissions of VOM from each heatset web offset

lithographic printing line at the source. The following

equation shall be used to calculate total maximum

theoretical emissions of VOM per calendar year in the

absence of air pollution control equipment for each heatset

web offset lithographic printing line at the source:

Ep = (R x A x B) + [(C x D) + 1095 (Fx Gx H)]

100

where:

Ep = Total maximum theoretical emissions of VOM from

one heatset web offset printing line in units of kg/yr

(lb/yr);

A = Weight of VOM per volume of solids of ink with

the highest VOM content as applied each year on

the printing line in units of kg/1 (lb/gal) of solids;

B = Total volume of solids 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 of each 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 of VOM per volume of fountain solution

with the highest VOM content as applied each year

on the printing line in units of kg/l (lb/gal) The

weight percent VOM of the fountain solution with

the highest VOM content;

D = The total volume of fountain solution that can

potentially be used each year on the printing line in

units of 1/yr (gal/yr). The instrument and/or

method by which the owner or operator accurately

measured or calculated the volume of each 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 of VOM per volume of material for the

cleanup material or solvent with the highest VOM

content as used each year on the printing line in

units of Kg/l (lb/gal) of such material;

G = The greatest volume of cleanup material or solvent

used in any 8-hour period; and

H = The highest fraction of cleanup 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

retained in the substrate being used. For paper, R =

0.8. For foil, plastic, or other impervious substrates,

R = 1.0.

B) On and after a date consistent with Section 218.106 of this Part, the

owner or operator of a heatset web offset lithographic printing line

to which subsection (b)(1) of this Section is applicable shall collect

and record all of the following information each year for each

printing line and maintain the information at the source for a

period of three years:

i) The name and identification of each fountain solution and

ink as applied on each printing line; and

ii) The VOM content and the volume of each fountain solution

and ink as applied each year on each printing line.

C) On and after a date consistent with Section 218.106 of this Part, the

owner or operator of a source exempted from the limitations of

subsection (a) of this Section because of the criteria in Section

218.405(a) of this Subpart shall notify the Agency of any record

showing that total maximum theoretical emissions of VOM from

all heatset web offset lithographic printing lines exceed 90.7 Mg

(100 tons) in any calendar year in the absence of air pollution

control equipment by sending a copy of such record to the Agency

within 30 days after the exceedence occurs.

2) Any owner or operator of a printing line subject to the limitations of

subsection (a) of this Section and complying by means of subsection (a)(1)

of this Section shall comply with the following:

A) By a date consistent with Section 218.106 of this Part, or upon

initial start-up of a new printing line, or upon changing the method

of compliance for an existing printing line from subsection (a)(2)

to (a)(1) of this Section, perform all tests and submit to the Agency

the results of all tests and calculations necessary to demonstrate

that the subject printing line will be in compliance with subsection

(a)(1) of this Section on and after a date consistent with Section

218.106 of this Part, or on and after the initial start-up date;

B) On and after a date consistent with Section 218.106 of this Part, or

on and after the initial start-up date, collect and record the

following information each day for each printing line and maintain

the information at the source for a period of three years:

i) Control device monitoring data;

ii) A log of operating time for the control device, monitoring

equipment and the associated printing line; and

iii) A maintenance log for the control device and monitoring

equipment detailing all routine and nonroutine maintenance

performed including dates and duration of any outages;

C) On and after a date consistent with Section 218.106 of this Part,

notify the Agency in the following instances:

i) Any violation of subsection (a)(1) of this Section shall be

reported to the Agency, in writing, within 30 days

following the occurrence of the violation;

ii) Any record showing a violation of subsection (a)(1) of this

Section shall be reported by sending a copy of such record

to the Agency within 30 days following the occurrence of

the violation; and

iii) At least 30 calendar days before changing the method of

compliance with subsection (a) of this Section from

subsection (a)(1) to (a)(2) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(3)(A) of this Section. Upon changing the method of

compliance with subsection (a) of this Section from

subsection (a)(1) to (a)(2) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(3) of this Section.

3) Any owner or operator of a printing line subject to the limitations of

subsection (a) of this Section and complying by means of subsection (a)(2)

of this Section shall:

A) By a date consistent with Section 218.106 of this Part, or upon

initial start-up of a new printing line, or upon changing the method

of compliance for an existing printing line from subsection (a)(1)

to (a)(2) of this Section, perform all tests and submit to the Agency

and the USEPA the results of all tests and calculations necessary to

demonstrate that the subject printing line will be in compliance

with subsection (a)(2) of this Section on and after a date consistent

with Section 218.106 of this Part, or on and after the initial start-up

date;

B) On and after a date consistent with Section 218.106 of this Part, or

on and after the initial start-up date, collect and record the

following information each day for each printing line and maintain

the information at the source for a period of three years:

i) The VOM content of the fountain solution used each day

on each printing line;

ii) A log of operating time for the control device and the

associated printing line; and

iii) A maintenance log for the control device detailing all

routine and non-routine maintenance performed including

dates and duration of any outages;

C) On and after a date consistent with Section 218.106 of this Part,

notify the Agency in the following instances:

i) Any violation of subsection (a)(2) shall be reported to the

Agency, in writing, within 30 days following the

occurrence of the violation;

ii) Any record showing a violation of subsection (a)(2) of this

Section shall be reported by sending a copy of such record

to the Agency within 30 days following the occurrence of

the violation; and

iii) At least 30 calendar days before changing the method of

compliance with subsection (a) of this Section from

subsection (a)(2) to (a)(1) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(2)(A) of this Section. Upon changing the method of

compliance with subsection (a) of this Section from

subsection (a)(2) to (a)(1) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(2) of this Section.

c) Compliance Schedule. Every owner or operator of a heatset web offset

lithographic printing line shall comply with the applicable requirements of

subsections (a) and (b) of this Section in accordance with the applicable

compliance schedule specified in subsections (c)(1), (c)(2), or (c)(3) of this

Section:

1) No owner or operator of a heatset web offset lithographic printing line

which is exempt from the limitations of subsection (a) of this Section

because of the criteria in Section 218.405 (a) of this Subpart shall operate

said printing line on or after a date consistent with Section 218.106 of this

Part, unless the owner or operator has complied with, and continues to

comply with, Sections 218.405(a) and 218.406(b)(1) of this Subpart.

2) No owner or operator of a heatset web offset lithographic printing line

complying by means of subsection (a)(1) of this Section shall operate said

printing line on or after a date consistent with Section 218.106 of this Part,

unless the owner or operator has complied with, and continues to comply

with, subsections (a)(1), (a)(3), (a)(4) and (b)(2) of this Section.

3) No owner or operator of a heatset web offset lithographic printing line

complying by means of subsection (a)(2) of this Section shall operate said

printing line on or after a date consistent with Section 218.106 of this Part,

unless the owner or operator has complied with, and continues to comply

with, subsections (a)(2), (a)(3), (a)(4) and (b)(3) of this Section.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.407 Emission Limitations and Control Requirements for Lithographic Printing

Lines On and After March 15, 1996

a) On and after March 15, 1996, no owner or operator of lithographic printing line(s)

subject to the requirements of this Subpart shall:

1) Cause or allow the operation of any heatset web offset lithographic

printing line unless:

A) The total VOM content in the as-applied fountain solution meets

one of the following conditions:

i) 1.6 percent or less, by volume;

ii) 3 percent or less, by volume, and the temperature of the

fountain solution is maintained below 15.6

C (60

F),

measured at the reservoir or the fountain tray; or

iii) 5 percent or less, by volume, and the as-applied fountain

solution contains no alcohol;

B) The air pressure in the dryer is maintained lower than the air

pressure of the press room, such that air flow through all openings

in the dryer, other than the exhaust, is into the dryer at all times

when the printing line is operating;

C) An afterburner is installed and operated so that VOM emissions

(excluding methane and ethane) from the press dryer exhaust(s) are

reduced by 90 percent, by weight, or to a maximum afterburner

exhaust outlet concentration of 20 ppmv (as carbon);

D) The afterburner is equipped with the applicable monitoring

equipment specified in Section 218.105(d)(2) of this Part and the

monitoring equipment is installed, calibrated, operated, and

maintained according to manufacturer's specifications at all times

when the afterburner is in use; and

E) The afterburner is operated at all times when the printing line is in

operation, except the afterburner may be shut down between

November 1 and April 1 as provided in Section 218.107 of this

Part;

2) Cause or allow the operation of any non-heatset web offset lithographic

printing line unless the VOM content of the as-applied fountain solution is

5 percent or less, by volume, and the as-applied fountain solution contains

no alcohol;

3) Cause or allow the operation of any sheet-fed offset lithographic printing

line unless:

A) The VOM content of the as-applied fountain solution is 5 percent

or less, by volume; or

B) The VOM content of the as-applied fountain solution is 8.5 percent

or less, by volume, and the temperature of the fountain solution is

maintained below 15.6

C (60

F), measured at the reservoir or the

fountain tray;

4) Cause or allow the use of a cleaning solution on any lithographic printing

line unless:

A) The VOM content of the as-used cleaning solution is less than or

equal to 30 percent, by weight; or

B) The VOM composite partial vapor pressure of the as-used cleaning

solution is less than 10 mmHg at 20

C (68

F);

5) Cause or allow VOM containing cleaning materials, including used

cleaning towels, associated with any lithographic printing line to be kept,

stored or disposed of in any manner other than in closed containers.

b) An owner or operator of a heatset web offset lithographic printing line subject to

the requirements of subsection (a)(1)(C) of this Section may use a control device

other than an afterburner, if:

1) The control device reduces VOM emissions from the press dryer

exhaust(s) by at least 90 percent, by weight, or to a maximum control

device exhaust outlet concentration of 20 ppmv (as carbon);

2) The owner or operator submits a plan to the Agency detailing appropriate

monitoring devices, test methods, recordkeeping requirements, and

operating parameters for the control device; and

3) The use of the control device with testing, monitoring, and recordkeeping

in accordance with this plan is approved by the Agency and USEPA as

federally enforceable permit conditions.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.410 Monitoring Requirements for Lithographic Printing

a) Fountain Solution Temperature.

1) The owner or operator of any lithographic printing line(s) relying on the

temperature of the fountain solution to demonstrate compliance shall

install, maintain, and continuously operate a temperature monitor of the

fountain solution in the reservoir or fountain tray, as applicable.

2) The temperature monitor must be capable of reading with an accuracy of

C or 2

C 0.3

C or 0.5

F, and must be attached to an automatic,

continuous recording device such as a strip chart, recorder, or computer,

with at least the same accuracy, that is installed, calibrated and maintained

in accordance with the manufacturer's specifications. If the automatic,

continuous recording device malfunctions, the owner or operator shall

record the temperature of the fountain solution at least once every two

operating hours. The automatic, continuous recording device shall be

repaired or replaced as soon as practicable.

b) Fountain Solution VOM Content. The owner or operator of any lithographic

printing line(s) subject to Section 218.407(a)(1)(A), (a)(2) or (a)(3) of this

Subpart shall:

1) For a fountain solution to which VOM is not added automatically:

A) Maintain records of the VOM content of the fountain solution in

accordance with Section 218.411(c)(2)(C); or

B) Take a sample of the as-applied fountain solution from the fountain

tray or reservoir, as applicable, each time a fresh batch of fountain

solution is prepared or each time VOM is added to an existing

batch of fountain solution in the fountain tray or reservoir, and

shall determine compliance with the VOM content limitation of the

as-applied fountain solution by using one of the following options:

i) With a refractometer or hydrometer with a visual, analog,

or digital readout and with an accuracy of 0.5 percent. The

refractometer or hydrometer must be calibrated with a

standard solution for the type of VOM used in the fountain

solution, in accordance with manufacturer's specifications,

against measurements performed to determine compliance.

The refractometer or hydrometer must be corrected for

temperature at least once per 8-hour shift or once per batch

of fountain solution prepared or modified, whichever is

longer; or

ii) With a conductivity meter if it is demonstrated that a

refractometer and hydrometer cannot distinguish between

compliant and noncompliant fountain solution for the type

and amount of VOM in the fountain solution. A source

may use a conductivity meter if it demonstrates that both

hydrometers and refractometers fail to provide significantly

different measurements for standard solutions containing

95 percent, 100 percent and 105 percent of the applicable

VOM content limit. The conductivity meter reading for the

fountain solution must be referenced to the conductivity of

the incoming water. A standard solution shall be used to

calibrate the conductivity meter for the type of VOM used

in the fountain solution, in accordance with manufacturer's

specifications;

2) For fountain solutions to which VOM is added at the source with

automatic feed equipment, determine the VOM content of the as-applied

fountain solution based on the setting of the automatic feed equipment

which makes additions of VOM up to a pre-set level. Records must be

retained of the VOM content of the fountain solution in accordance with

Section 218.411(c)(2)(D) of this Subpart. The equipment used to make

automatic additions must be installed, calibrated, operated and maintained

in accordance with manufacturer's specifications.

c) Afterburners For Heatset Web Offset Lithographic Printing Line(s).

If an afterburner is used to demonstrate compliance, the owner or operator of a

heatset web offset lithographic printing line subject to Section 218.407(a)(1)(C)

of this Subpart shall:

1) Install, calibrate, maintain, and operate temperature monitoring device(s)

with an accuracy of 3

C or 5

F on the afterburner in accordance with

Section 218.105(d)(2) of this Part and in accordance with the

manufacturer's specifications. Monitoring shall be performed at all times

when the afterburner is operating; and

2) Install, calibrate, operate and maintain, in accordance with manufacturer's

specifications, a continuous recorder on the temperature monitoring

device(s), such as a strip chart, recorder or computer, with at least the

same accuracy as the temperature monitor.

d) Other Control Devices for Heatset Web Offset Lithographic Printing Line(s). If a

control device other than an afterburner is used to demonstrate compliance, the

owner or operator of a heatset web offset lithographic printing line subject to this

Subpart shall install, maintain, calibrate and operate such monitoring equipment

as set forth in the owner or operator's plan approved by the Agency and USEPA

pursuant to Section 218.407(b) of this Subpart.

e) Cleaning Solution.

1) The owner or operator of any lithographic printing line relying on the

VOM content of the cleaning solution to comply with Section

218.407(a)(4)(A) of this Subpart must:

A) For cleaning solutions that are prepared at the source with

equipment that automatically mixes cleaning solvent and water (or

other non-VOM):

i) Install, operate, maintain, and calibrate the automatic feed

equipment in accordance with manufacturer's specifications

to regulate the volume of each of the cleaning solvent and

water (or other non-VOM), as mixed; and

ii) Pre-set the automatic feed equipment so that the

consumption rates of the cleaning solvent and water (or

other non-VOM), as applied, comply with Section

218.407(a)(4)(A) of this Subpart;

B) For cleaning solutions that are not prepared at the source with

automatic feed equipment, keep records of the usage of cleaning

solvent and water (or other non-VOM) as set forth in Section

218.411(d)(2) of this Subpart.

2) The owner or operator of any lithographic printing line relying on the

vapor pressure of the cleaning solution to comply with Section

218.407(a)(4)(B) of this Subpart must keep records for such cleaning

solutions used on any such line(s) as set forth in Section 218.411(d)(2)(C)

of this Subpart.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.411 Recordkeeping and Reporting for Lithographic Printing

a) An owner or operator of lithographic printing line(s) exempt from the limitations

of Section 218.407 of this Subpart because of the criteria in Section 218.405(d) of

this Subpart shall comply with the following:

1) By March 15, 1996, upon initial start-up of a new lithographic printing

line, and upon modification of a lithographic printing line, submit a

certification to the Agency that includes:

A) A declaration that the source is exempt from the control

requirements in Section 218.407 of this Part because of the criteria

in Section 218.405(d) of this Subpart;

B) Calculations which demonstrate that combined emissions of VOM

from all lithographic printing lines (including inks, fountain

solutions, and solvents used for cleanup operations associated with

the lithographic printing lines) at the source never exceed 45.5

kg/day (100 lbs/day) before the use of capture systems and control

devices, as follows:

i) To calculate daily emissions of VOM, the owner or

operator shall determine the monthly emissions of VOM

from all lithographic printing lines at the source (including

solvents used for cleanup operations associated with the

lithographic printing lines) and divide this amount by the

number of days during that calendar month that

lithographic printing lines at the source were in operation;

ii) To determine the VOM content of the inks, fountain

solution additives and cleaning solvents, the tests methods

and procedures set forth in Section 218.409(c) of this

Subpart shall be used;

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 of 0.80 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 emission adjustment factor is used. The

VOM content of the 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

iv) To determine VOM emissions from fountain solutions and

cleaning solvents used on lithographic printing line(s) at the

source, no retention factor is used;

C) Either a declaration that the source, through federally enforceable

permit conditions, has limited its maximum theoretical emissions

of VOM from all heatset web offset lithographic printing lines

(including solvents used for cleanup operations associated with

heatset web offset printing lines) at the source to no more than 90.7

Mg (100 tons) per calendar year before the application of capture

systems and control devices or calculations which demonstrate that

the source's total maximum theoretical emissions of VOM do not

exceed 90.7 Mg/yr (100 TPY). To determine the source's total

maximum theoretical emissions for the purposes of this subsection,

the owner or operator shall use the calculations set forth in Section

218.406(b)(1)(A)(ii) of this Subpart; and

D) A description and the results of all tests used to determine the

VOM content of inks, fountain solution additives, and cleaning

solvents, and a declaration that all such tests have been properly

conducted in accordance with Section 218.409(c)(1) of this

Subpart;

2) On and after March 15, 1996, collect and record either the information

specified in subsection (a)(2)(A) or (a)(2)(B) of this Section for all

lithographic printing lines at the source:

A) Standard recordkeeping, including the following:

i) The name and identification of each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line, recorded each month;

ii) A daily record which shows whether a lithographic printing

line at the source was in operation on that day;

iii) The VOM content and the volume of each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line, recorded each month;

iv) The total VOM emissions at the source each month,

determined as the sum of the product of usage and VOM

content for each fountain solution additive, cleaning

solvent, and lithographic ink (with the applicable ink VOM

emission adjustment) used at the source, calculated each

month; and

v) The VOM emissions in lbs/day for the month, calculated in

accordance with Section 218.411(a)(1)(B) of this Subpart;

B) Purchase and inventory recordkeeping, including the following:

i) The name, identification, and VOM content of each

fountain solution additive, lithographic ink, and cleaning

solvent used on any lithographic printing line, recorded

each month;

ii) Inventory records from the beginning and end of each

month indicating the total volume of each fountain solution

additive, lithographic ink, and cleaning solvent to be used

on any lithographic printing line at the source;

iii) Monthly purchase records for each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line at the source;

iv) A daily record which shows whether a lithographic printing

line at the source was in operation on that day;

v) The total VOM emissions at the source each month,

determined as the sum of the product of usage and VOM

content for each fountain solution additive, cleaning

solvent, and lithographic ink (with the applicable ink VOM

emission adjustment) used at the source, calculated each

month based on the monthly inventory and purchase

records required to be maintained pursuant to subsections

(a)(2)(B)(i), (a)(2)(B)(ii) and (a)(2)(B)(iii) of this Section;

and

vi) The VOM emissions in lbs/day for the month, calculated in

accordance with Section 218.411(a)(1)(B) of this Subpart;

3) On and after March 15, 1996, notify the Agency in writing if the

combined emissions of VOM from all lithographic printing lines

(including inks, fountain solutions, and solvents used for cleanup

operations associated with the lithographic printing lines) at the source

ever exceed 45.5 kg/day (100 lbs/day), before the use of capture systems

and control devices, within 30 days after the event occurs. Such

notification shall include a copy of all records of such event.

b) An owner or operator of a heatset web offset lithographic printing line(s) subject

to the control requirements of Section 218.407(a)(1)(C) or (b)(1) of this Subpart

shall comply with the following:

1) By March 15, 1996, upon initial start-up of a new printing line, and upon

initial start-up of a new control device for a heatset web offset printing

line, submit a certification to the Agency that includes the following:

A) An identification of each heatset web offset lithographic printing

line at the source;

B) A declaration that each heatset web offset lithographic printing line

is in compliance with the requirements of Section 218.407 (a) (1)

(B), (a) (1) (C), (a) (1) (D) and (a) (1) (E) or (b) of this Subpart, as

appropriate;

C) The type of afterburner or other approved control device used to

comply with the requirements of Section 218.407(a)(1)(C) or

(b)(1) of this Subpart;

D) The control requirements in Section 218.407(a)(1)(C) or (b)(1) of

this Subpart with which the lithographic printing line is complying;

E) The results of all tests and calculations necessary to demonstrate

compliance with the control requirements of Section

218.407(a)(1)(C) or (b)(1) of this Subpart, as applicable; and

F) A declaration that the monitoring equipment required under

Section 218.407(a)(1)(D) or (b) of this Subpart, as applicable, has

been properly installed and calibrated according to manufacturer's

specifications;

2) If testing of the afterburner or other approved control device is conducted

pursuant to Section 218.409(b) of this Subpart, the owner or operator

shall, within 90 days after conducting such testing, submit a copy of all

test results to the Agency and shall submit a certification to the Agency

that includes the following:

A) A declaration that all tests and calculations necessary to

demonstrate whether the lithographic printing line(s) is in

compliance with Section 218.407(a)(1)(C) or (b)(1) of this

Subpart, as applicable, have been properly performed;

B) A statement whether the lithographic printing line(s) is or is not in

compliance with Section 218.407(a)(1)(C) or (b)(1) of this

Subpart, as applicable; and

C) The operating parameters of the afterburner or other approved

control device during testing, as monitored in accordance with

Section 218.410(c) or (d) of this Subpart, as applicable;

100

3) On and after March 15, 1996, collect and record daily the following

information for each heatset web offset lithographic printing line subject

to the requirements of Section 218.407(a)(1)(C) or (b)(1) of this Subpart:

A) Afterburner or other approved control device monitoring data in

accordance with Section 218.410(c) or (d) of this Subpart, as

applicable;

B) A log of operating time for the afterburner or other approved

control device, monitoring equipment, and the associated printing

line;

C) A maintenance log for the afterburner or other approved control

device and monitoring equipment detailing all routine and non-

routine maintenance performed, including dates and duration of

any outages; and

D) A log detailing checks on the air flow direction or air pressure of

the dryer and press room to insure compliance with the

requirements of Section 218.407(a)(1)(B) of this Subpart at least

once per 24-hour period while the line is operating;

4) On and after March 15, 1996, notify the Agency in writing of any

violation of Section 218.407(a)(1)(C) or (b)(1) of this Subpart within 30

days after the occurrence of such violation. Such notification shall include

a copy of all records of such violation;

5) If changing its method of compliance between subsections (a)(1)(C) and

(b) of Section 218.407 of this Subpart, certify compliance for the new

method of compliance in accordance with subsection (b)(1) of this Section

at least 30 days before making such change, and perform all tests and

calculations necessary to demonstrate that such printing line(s) will be in

compliance with the requirements of Section 218.407(a)(1)(B), (a)(1)(C),

(a)(1)(D) and (a)(1)(E) of this Subpart, or Section 218.407(b) of this

Subpart, as applicable.

c) An owner or operator of a lithographic printing line subject to Section

218.407(a)(1)(A), (a)(2), or (a)(3) of this Subpart, shall:

1) By March 15, 1996, and upon initial start-up of a new lithographic

printing line, certify to the Agency that fountain solutions used on each

lithographic printing line will be in compliance with the applicable VOM

content limitation. Such certification shall include:

101

A) Identification of each lithographic printing line at the source, by

type, e.g., heatset web offset, non-heatset web offset, or sheet-fed

offset;

B) Identification of each centralized fountain solution reservoir and

each lithographic printing line that it serves;

C) The VOM content limitation with which each fountain solution

will comply;

D) Initial documentation that each type of fountain solution will

comply with the applicable VOM content limitation, including

copies of manufacturer's specifications, test results, if any,

formulation data and calculations;

E) Identification of the method that will be used to demonstrate

continuing compliance with the applicable limitation, e.g., a

refractometer, hydrometer, conductivity meter, or recordkeeping

procedures with detailed description of the compliance

methodology; and

F) A sample of the records that will be kept pursuant to Section

218.411(c)(2) of this Subpart.

2) On and after March 15, 1996, collect and record the following information

for each fountain solution:

A) The name and identification of each batch of fountain solution

prepared for use on one or more lithographic printing lines, the

lithographic printing line(s) or centralized reservoir using such

batch of fountain solution, and the applicable VOM content

limitation for the batch;

B) If an owner or operator uses a hydrometer, refractometer, or

conductivity meter, pursuant to Section 218.410(b)(1)(B), to

demonstrate compliance with the applicable VOM content limit in

Section 218.407(a)(1)(A), (a)(2), or (a)(3) of this Subpart:

i) The date and time of preparation, and each subsequent

modification, of the batch;

ii) The results of each measurement taken in accordance with

Section 218.410(b) of this Subpart;

iii) Documentation of the periodic calibration of the meter in

accordance with the manufacturer's specifications,

102

including date and time of calibration, personnel

conducting, identity of standard solution, and resultant

reading; and

iv) Documentation of the periodic temperature adjustment of

the meter, including date and time of adjustment, personnel

conducting and results;

C) If the VOM content of the fountain solution is determined pursuant

to Section 218.410(b)(1)(A) of this Subpart, for each batch of as-

applied fountain solution:

i) Date and time of preparation and each subsequent

modification of the batch;

ii) Volume and VOM content of each component used in, or

subsequently added to, the fountain solution batch;

iii) Calculated VOM content of the as-applied fountain

solution; and

iv) Any other information necessary to demonstrate

compliance with the applicable VOM content limits in

Section 218.407(a)(1)(A), (a)(2) and (a)(3) of this Subpart,

as specified in the source's operating permit;

D) If the VOM content of the fountain solution is determined pursuant

to Section 218.410(b)(2) of this Subpart, for each setting:

i) VOM content limit corresponding to each setting;

ii) Date and time of initial setting and each subsequent setting;

iii) Documentation of the periodic calibration of the

automatic feed equipment in accordance with the

manufacturer’s specifications; and

iv) Any other information necessary to demonstrate

compliance with the applicable VOM content limits in

Sections 218.407(a)(1)(A), (a)(2) and (a)(3) of this Subpart,

as specified in the source’s operating permit.

ED) If the owner or operator relies on the temperature of the fountain

solution to comply with the requirements in Section

218.407(a)(1)(A)(ii) or (a)(3)(B) of this Subpart:

103

i) The temperature of the fountain solution at each printing

line, as monitored in accordance with Section 218.410(a);

and

ii) A maintenance log for the temperature monitoring devices

and automatic, continuous temperature recorders detailing

all routine and non-routine maintenance performed,

including dates and duration of any outages;

3) Notify the Agency in writing of any violation of Section 218.407 of this

Subpart within 30 days after the occurrence of such violation. Such

notification shall include a copy of all records of such violation; and

4) If changing its method of demonstrating compliance with the applicable

VOM content limitations in Section 218.407 of this Subpart, or changing

the method of demonstrating compliance with the VOM content

limitations for fountain solutions pursuant to Section 218.409 of this

Subpart, certify compliance for such new method(s) in accordance with

subsection (c)(1) of this Section within 30 days after making such change,

and perform all tests and calculations necessary to demonstrate that such

printing line(s) will be in compliance with the applicable requirements of

Section 218.407 of this Subpart.

d) For lithographic printing line cleaning operations, an owner or operator of a

lithographic printing line subject to the requirements of Section 218.407 of this

Subpart shall:

1) By March 15, 1996, and or upon initial start-up of a new lithographic

printing line, certify to the Agency that all cleaning solutions, and the

handling of cleaning materials, will be in compliance with the

requirements of Section 218.407(a)(4)(A) or (a)(4)(B) and (a)(5) of this

Subpart, and such certification shall also include:

A) Identification of each VOM-containing cleaning solution used on

each lithographic printing line;

B) The limitation with which each VOM-containing cleaning solution

will comply, i.e., the VOM content or vapor pressure;

C) Initial documentation that each VOM-containing cleaning solution

will comply with the applicable limitation, including copies of

manufacturer's specifications, test results, if any, formulation data

and calculations;

D) Identification of the method that will be used to demonstrate

continuing compliance with the applicable limitations;

104

E) A sample of the records that will be kept pursuant to Section

218.411(d)(2) of this Subpart; and

F) A description of the practices that assure that VOM-containing

cleaning materials are kept in closed containers;

2) On and after March 15, 1996, collect and record the following information

for each cleaning solution used on each lithographic printing line:

A) For each cleaning solution for which the owner or operator relies

on the VOM content to demonstrate compliance with Section

218.407(a)(4)(A) of this Subpart and which is prepared at the

source with automatic equipment:

i) The name and identification of each cleaning solution;

ii) The VOM content of each cleaning solvent in the cleaning

solution, as determined in accordance with Section

218.409(c) of this Subpart;

iii) Each change to the setting of the automatic equipment, with

date, time, description of changes in the cleaning solution

constituents (e.g., cleaning solvents), and a description of

changes to the proportion of cleaning solvent and water (or

other non-VOM);

iv) The proportion of each cleaning solvent and water (or other

non-VOM) used to prepare the as-used cleaning solution;

v) The VOM content of the as-used cleaning solution, with

supporting calculations; and

vi) A calibration log for the automatic equipment, detailing

periodic checks;

B) For each batch of cleaning solution for which the owner or

operator relies on the VOM content to demonstrate compliance

with Section 218.407(a)(4)(A) of this Subpart, and which is not

prepared at the source with automatic equipment:

i) The name and identification of each cleaning solution;

ii) Date and time of preparation, and each subsequent

modification, of the batch;

105

iii) The VOM content of each cleaning solvent in the cleaning

solution, as determined in accordance with Section

218.409(c) of this Subpart;

iv) The total amount of each cleaning solvent and water (or

other non-VOM) used to prepare the as-used cleaning

solution; and

v) The VOM content of the as-used cleaning solution, with

supporting calculations;

C) For each batch of cleaning solution for which the owner or

operator relies on the vapor pressure of the cleaning solution to

demonstrate compliance with Section 218.407(a)(4)(B) of this

Subpart:

i) The name and identification of each cleaning solution;

ii) Date and time of preparation, and each subsequent

modification, of the batch;

iii) The molecular weight, density, and VOM composite partial

vapor pressure of each cleaning solvent, as determined in

accordance with Section 218.409(e) of this Subpart;

iv) The total amount of each cleaning solvent used to prepare

the as-used cleaning solution; and

v) The VOM composite partial vapor pressure of each as-used

cleaning solution, as determined in accordance with Section

218.409(e) of this Subpart;

D) The date, time and duration of scheduled inspections performed to

confirm the proper use of closed containers to control VOM

emissions, and any instances of improper use of closed containers,

with descriptions of actual practice and corrective action taken, if

any;

3) On and after March 15, 1996, notify the Agency in writing of any

violation of Section 218.407 of this Subpart within 30 days after the

occurrence of such violation. Such notification shall include a copy of all

records of such violation; and

4) If changing its method of demonstrating compliance with the requirements

of Section 218.407(a)(4) of this Subpart, or changing between automatic

and manual methods of preparing cleaning solutions, certify compliance

106

for such new method in accordance with subsection (d)(1) of this Section,

within 30 days after making such change, and perform all tests and

calculations necessary to demonstrate that such printing line(s) will be in

compliance with the applicable requirements of Section 218.407(a)(4) of

this Subpart.

e) The owner or operator shall maintain all records required by this Section at the

source for a minimum period of three years and shall make all records available to

the Agency upon request.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

SUBPART Z: DRY CLEANERS

Section 218.601 Perchloroethylene Dry Cleaners (Repealed)

The owner or operator of a dry cleaning operation which uses perchloroethylene shall:

Vent the entire dryer exhaust through a properly designed and functioning carbon

adsorption system or equally effective control device; and

Emit no more than 100 ppmv of VOM from the dryer control device before

dilution, or achieve a 90 percent average reduction before dilution; and

Immediately repair all components found to be leaking liquid VOM; and

Cook or treat all diatomaceous earth filters so that the residue contains 25 kg (55

lb) or less of VOM per 100 kg (220 lb) of wet waste material; and

Reduce the VOM from all solvent stills to 60 kg (132 lb) or less per 100 kg (220

lb) of wet waste material; and

Drain all filtration cartridges in the filter housing or other sealed container for at

least 24 hours before discarding the cartridges; and

Dry all drained filtration cartridges in equipment connected to an emission

reduction system or in a manner that will eliminate emission of VOM to the

atmosphere.

(Source: Repealed at 29 Ill Reg. ________, effective ________________)

Section 218.602 Applicability (Repealed)

The provisions of Section 218.601 of this Part are not applicable to perchloroethylene dry

cleaning operations which are coin-operated or to dry cleaning operations consuming less than

30 gal per month (360 gal per year) of perchloroethylene.

107

(Source: Repealed at 29 Ill Reg. ________, effective ________________)

Section 218.603 Leaks (Repealed)

The presence of leaks shall be determined for purposes of Section 218.601(c) of this Part by a

visual inspection of the following: hose connections, unions, couplings and valves; machine door

gaskets and seatings; filter head gasket and seating; pumps; base tanks and storage containers;

water separators; filter sludge recovery; distillation unit; diverter valves; saturated lint from lint

baskets; and cartridge filters.

(Source: Repealed at 29 Ill Reg. ________, effective ________________)

SUBPART HH: MOTOR VEHICLE REFINISHING

Section 218.790 General Recordkeeping and Reporting (Repealed)

On and after the compliance date specified in Section 218.791 of this Subpart, every owner or

operator of a motor vehicle refinishing operation shall maintain the following records for the

most recent consecutive 3 years. Such records shall be made available to the Agency

immediately upon request:

The name and manufacturer of each coating and surface preparation product used

at the source each month;

The volume of each category of coating, as set forth in Section 218.780 of this

Subpart, purchased by the source each month;

The coating mixing instructions, as stated on the container, in literature supplied

with the coating, or otherwise specified by the manufacturer, for each coating

purchased by the source each month;

The VOM content, expressed as weight of VOM per volume of coating, minus

water and any compounds that are specifically exempted from the definition of

VOM, recorded on a monthly basis for:

Each coating as purchased, if the coating is not mixed with any additives

prior to application on the substrate; or

Each coating after mixing according to manufacturer's instructions as

collected pursuant to subsection (c) of this Section;

The weighted average VOM content of the coating, as specified in Section

218.780(d)(1), (d)(2) or (d)(3) of this Subpart, for each basecoat/clearcoat, and

three or four stage coating system purchased by the source, recorded on a monthly

basis;

108

The total monthly volume of all specialty coatings purchased and the percentage

specialty coatings comprise in the aggregate of all coatings purchased by the

source each month;

The volume of each category of surface preparation material, as set forth in

Section 218.786 of this Subpart, purchased by the source each month; and

The VOM content, expressed as weight of VOM per volume of material,

including water, of each surface preparation material purchased by the source,

recorded on a monthly basis.

(Source: Repealed at 29 Ill Reg. ________, effective ________________)

Section 218.792 Registration

a) Every owner or operator of a motor vehicle refinishing operation shall register

with the Agency on or before the date specified in Section 218.791 of this Subpart

and re-register no later than 45 days following the end of each subsequent

calendar year. The following information shall be included in this registration:

1) The name and address of the source, and the name and telephone number

of the person responsible for submitting the registration information;

2) A description of all coating operations of motor vehicles, mobile

equipment, or their parts or components, and all associated surface

preparation operations at the source;

3) A description of all coating applicators used at the source to comply with

Section 218.784(a) of this Subpart, if applicable;

4) A description of all cleanup operations at the source, including equipment

used to comply with Section 218.784(b) of this Subpart, if applicable;

5) A description of all work practices at the source used to comply with

Section 218.787 of this Subpart;

6) If a source claims to be exempt from the equipment requirements in

Section 218.784 of this Subpart because it uses less than 20 gallons of

coating per year, the owner's or operator's certification that the annual

usage is below this level;

7) A written declaration stating whether the source is complying with this

Subpart by using coatings that comply with the applicable VOM content

limits in Section 218.780 of this Subpart or by control equipment as

specified in Section 218.782; and

109

8) A description of any control devices used to comply with Section 218.782

of this Subpart and the date(s) the device was installed and became

operational.

b) At least 30 calendar days before changing the method of compliance to or from

Sections 218.780 and 218.782, the owner or operator of a motor vehicle

refinishing operation shall notify the Agency and certify that the source is in

compliance with the applicable requirements for the new method of compliance.

(Source: Amended at 29 Ill Reg. ________, effective ________________)

Section 218.Appendix B VOM Measurement Techniques for Capture Efficiency (Repealed)

Procedure G.1 - Captured VOM Emissions

INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the volatile organic materials

(VOM) content of captured gas streams. It is intended to be used as a segment in the

development of liquid/gas or gas/gas protocols for determining VOM capture efficiency (CE) for

surface coating and printing operations. The procedure may not be acceptable in certain

site-specific situations, e.g., when: (1) direct fired heaters or other circumstances affect the

quantity of VOM at the control device inlet; and (2) particulate organic aerosols are formed in

the process and are present in the captured emissions.

1.2 Principle. The amount of VOM captured (G) is calculated as the sum of the products of the

VOM content (CGj), the flow rate (QGj), and the sample time (TC) from each captured

emissions point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

captured or fugitive emissions point as follows: QGj = 5.5 percent and CGj =



5.0

percent.

Based on these numbers, the probable uncertainty for G is estimated at about



7.4

percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

110

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow rate control valve and

rotameter must be heated to prevent condensation. A control valve may also be located on the

sample pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the

flame ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If captured or fugitive emissions

are to be measured at multiple locations, the measurement system shall be designed to use

separate sampling probes, lines, and pumps for each measurement location and a common

sample gas manifold and FIA. The sample gas manifold and connecting lines to the FIA must be

heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than



3.0

percent of the span value.

2.1.7.2 Calibration Drift. Less than



3.0

percent of the span value.

2.1.7.3 Calibration Error. Less than



5.0

percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

111

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to



1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than



2 percent

from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane or

carbon equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Captured Emissions Volumetric Flow Rate.

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

DETERMINATION OF VOLUMETRIC FLOW RATE OF CAPTURED EMISSIONS

3.1 Locate all points where emissions are captured from the affected emission unit. Using

Method 1, determine the sampling points. Be sure to check each site for cyclonic or swirling

flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

DETERMINATION OF VOM CONTENT OF CAPTURED EMISSIONS

112

4.1 Analysis Duration. Measure the VOM responses at each captured emissions point during

the entire test run or, if applicable, while the process is operating. If there are multiple captured

emission locations, design a sampling system to allow a single FIA to be used to determine the

VOM responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA according to the

procedure in Section 5.1.

4.2.2 Conduct a system check according to the procedure in Section 5.3.

4.2.3 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct,

and is sealed tightly at the stack port connection.

4.2.4 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position.

4.2.5 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.6 Verify that the sample lines, filter, and pump temperatures are 120



NC.

4.2.7 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple captured emission locations are sampled using a single FIA, sample at each location for

the same amount of time (e.g., 2 minutes) and continue to switch from one location to another for

the entire test run. Be sure that total sampling time at each location is the same at the end of the

test run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the measurements at each sampling location until two times the response time

of the measurement system has elapsed. Continue sampling for at least 1 minute and record the

concentration measurements.

4.3 Background Concentration.

4.3.1 Locate all NDO's of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO's,

choose 6 sampling points evenly spaced among the NDO's.

113

4.3.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3. NOTE: This sample train shall be a

separate sampling train from the one to measure the captured emissions.

4.3.3 Position the probe at the sampling location.

4.3.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.4 to 4.2.7.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOC concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the captured emissions for conducting the drift checks. Introduce the zero and

calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate and

pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct the system drift checks at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before and after each test run.

5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

total area of all NDO's in the enclosure, ft2;

CBi

corrected average VOM concentration of background emissions at point i, ppm

propane;

average background concentration, ppm propane;

CGj

corrected average VOM concentration of captured emissions at point j, ppm

propane;

CDH

average measured concentration for the drift check calibration gas, ppm propane;

CD0

average system drift check concentration for zero concentration gas, ppm

propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average background VOM concentration measured at point i,

ppm propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of captured emissions, kg;

1.830 x 10-6 kg/(m3-ppm);

number of measurement points;

QGj

average effluent volumetric flow rate corrected to standard conditions at captured

emissions point j, m3/min;

total duration of captured emissions sampling run, min.

7. CALCULATIONS

7.1 Total VOM Captured Emissions.

? (CGj - CB ) QGj TC K1

Eq. 1

j=1

115

7.2 VOM Concentration of the Captured Emissions at Point j.

7.3 Background VOM Concentration at Point i.

7.4 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure G.2 - Captured VOM Emissions (Dilution Technique)

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the volatile organic materials

(VOM) content of captured gas streams. It is intended to be used as a segment in the

development of a gas/gas protocol in which fugitive emissions are measured for determining

VOM capture efficiency (CE) for surface coating and printing operations. A dilution system is

used to reduce the VOM concentration of the captured emission to about the same concentration

as the fugitive emissions. The procedure may not be acceptable in certain site-specific situations,

e.g., when: (1) direct fired heaters or other circumstances affect the quantity of VOM at the

control device inlet; and (2) particulate organic aerosols are formed in the process and are

present in the captured emissions.

1.2 Principle. The amount of VOM captured (G) is calculated as the sum of the products of the

VOM content (CGj), the flow rate (QGj), and the sampling time (TC) from each captured

emissions point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

captured or fugitive emissions point as follows: QGj =

on these numbers, the probable uncertainty for G is estimated at about



7.4 percent.

116

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Dilution System. A Kipp in-stack dilution probe and controller or similar device may be

used. The dilution rate may be changed by substituting different critical orifices or adjustments

of the aspirator supply pressure. The dilution system shall be heated to prevent VOM

condensation. Note: An out-of-stack dilution device may be used.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow control valve and rotameter

must be heated to prevent condensation. A control valve may also be located on the sample

pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the

flame ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If captured or fugitive emissions

are to be measured at multiple locations, the measurement system shall be designed to use

separate sampling probes, lines, and pumps for each measurement location and a common

sample gas manifold and FIA. The sample gas manifold and connecting lines to the FIA must be

heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

117

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than



3.0

percent of the span value.

2.1.7.2 Calibration Drift. Less than



3.0

percent of the span value.

2.1.7.3 Calibration Error. Less than



5.0

percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to



1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than



2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas and Dilution Air Supply. High purity air with less than 1 ppm of organic

material (as propane or carbon equivalent) or less than 0.1 percent of the span value, whichever

is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.9.4 Dilution Check Gas. Gas mixture standard containing propane in air, approximately half

the span value after dilution.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Captured Emissions Volumetric Flow Rate.

118

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

DETERMINATION OF VOLUMETRIC FLOW RATE OF CAPTURED EMISSIONS

3.1 Locate all points where emissions are captured from the affected facility. Using Method 1,

determine the sampling points. Be sure to check each site for cyclonic or swirling flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

DETERMINATION OF VOM CONTENT OF CAPTURED EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each captured emissions point during

the entire test run or, if applicable, while the process is operating. If there are a multiple

captured emissions locations, design a sampling system to allow a single FIA to be used to

determine the VOM responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA according to the

procedure in Section 5.1.

4.2.2 Set the dilution ratio and determine the dilution factor according to the procedure in

Section 5.3.

4.2.3 Conduct a system check according to the procedure in Section 5.4.

4.2.4 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct,

and is sealed tightly at the stack port connection.

4.2.5 Inject zero gas at the calibration valve assembly. Measure the system response time as the

time required for the system to reach the effluent concentration after the calibration valve has

been returned to the effluent sampling position.

4.2.6 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.4. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.7 Verify that the sample lines, filter, and pump temperatures are 120



NC.

119

4.2.8 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple captured emission locations are sampled using a single FIA, sample at each location for

the same amount of time (e.g., 2 minutes) and continue to switch from one location to another for

the entire test run. Be sure that total sampling time at each location is the same at the end of the

test run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the measurements at each sampling location until two times the response time

of the measurement system has elapsed. Continue sampling for at least 1 minute and record the

concentration measurements.

4.3 Background Concentration.

4.3.1 Locate all NDO's of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO's,

choose 6 sampling points evenly spaced among the NDO's.

4.3.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.4.

4.3.3 Position the probe at the sampling location.

4.3.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.4 to 4.2.8.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

the dilution system and adjust the back- pressure regulator to the value required to achieve the

flow rates specified by the manufacturer. Inject the zero- and the high-range calibration gases

and adjust the analyzer calibration to provide the proper responses. Inject the low- and

mid-range gases and record the responses of the measurement system. The calibration and

linearity of the system are acceptable if the responses for all four gases are within 5 percent of

the respective gas values. If the performance of the system is not acceptable, repair or adjust the

system and repeat the linearity check. Conduct a calibration and linearity check after assembling

the analysis system and after a major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the diluted captured emissions for conducting the drift checks. Introduce the

zero and calibration gas at the calibration valve assembly and verify that the appropriate gas flow

120

rate and pressure are present at the FIA. Record the measurement system responses to the zero

and calibration gases. The performance of the system is acceptable if the difference between the

drift check measurement and the value obtained in Section 5.1 is less than 3 percent of the span

value. Conduct the system drift check at the end of each run.

5.3 Determination of Dilution Factor. Inject the dilution check gas into the measurement system

before the dilution system and record the response. Calculate the dilution factor using

Equation 3.

5.4 System Check. Inject the high range calibration gas at the inlet to the sampling probe while

the dilution air is turned off. Record the response. The performance of the system is acceptable

if the measurement system response is within 5 percent of the value obtained in Section 5.1 for

the high range calibration gas. Conduct a system check before and after each test run.

5.5 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

percent.

NOMENCLATURE

area of NDO i, ft2;

total area of all NDO's in the enclosure, ft2;

actual concentration of the dilution check gas, ppm propane;

CBi

corrected average VOM concentration of background emissions at point i, ppm

propane;

average background concentration, ppm propane;

CDH

average measured concentration for the drift check calibration gas, ppm propane;

CD0

average system drift check concentration for zero concentration gas, ppm

propane;

actual concent ration of the drift check calibration gas, ppm propane;

uncorrected average background VOM concentration measured at point i,

ppm propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

121

measured concentration of the dilution check gas, ppm propane;

dilution factor;

total VOCM content of captured emissions, kg;

1.830 x 10-6 kg/(m3-ppm);

number of measurement points;

QGj

average effluent volumetric flow rate corrected to standard conditions at captured

emissions point j, m3/min;

total duration of capture efficiency sampling run, min.

CALCULATIONS

7.1 Total VOM Captured Emissions.

G = ? CGj QGj TC K1

Eq. 1

j=1

7.2 VOM Concentration of the Captured Emissions at Point j.

CGj = DF (Cj - CD0) CH

7.4 Background VOM Concentration at Point i.

CBi = (Ci - CD0) CH

Eq. 4

CDH - CD0

7.5 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure F.2 - Fugitive VOM Emissions from Building Enclosures

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the fugitive volatile organic

materials (VOM) emissions from a building enclosure (BE). It is intended to be used as a

segment in the development of liquid/gas or gas/gas protocols for determining VOM capture

efficiency (CE) for surface coating and printing operations.

1.2 Principle. The total amount of fugitive VOM emissions (FB ) from the BE is calculated as

the sum of the products of the VOM content (CFj) of each fugitive emissions point, its flow rate

(QFj), and time (TF).

1.3 Measurement Uncertainty. The measurement uncertainties are estimated for each fugitive

emissions point as follows: QFj =

percent. Based on these numbers,

the probable uncertainty for FB is estimated at about



11.2 percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

123

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow rate control valve and

rotameter must be heated to prevent condensation. A control valve may also be located on the

sample pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the

flame ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If emissions are to be measured at

multiple locations, the measurement system shall be designed to use separate sampling probes,

lines, and pumps for each measurement location and a common sample gas manifold and FIA.

The sample gas manifold must be heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than



3.0 percent of the span value.

2.1.7.2 Calibration Drift. Less than



3.0 percent of the span value.

2.1.7.3 Calibration Error. Less than



5.0 percent of the

calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to



1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than



2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

124

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (propane or carbon

equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Fugitive Emissions Volumetric Flow Rate.

2.2.1 Flow Direction Indicators. Any means of indicating inward or outward flow, such as light

plastic film or paper streamers, smoke tubes, filaments, and sensory perception.

2.2.2 Method 2 or 2A Apparatus. For determining volumetric flow rate. Anemometers or

velocities are present. Vane anemometers (Young-maximum response propeller), specialized

pitots with electronic manometers (e.g., Shortridge Instruments Inc., Airdata Multimeter 860) are

commercially available with measurement thresholds of 15 and 8 mpm (50 and 25 fpm),

respectively.

2.2.3 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.4 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

DETERMINATION OF VOLUMETRIC FLOW RATE OF FUGITIVE EMISSIONS

3.1 Preliminary Determinations. The purpose of this exercise is to determine which exhaust

points should be measured for volumetric flow rates and VOM concentrations.

3.1.1 Forced Draft Openings. Identify all forced draft openings. Determine the volumetric flow

rate according to Method 2.

3.1.2 NDO's Exhaust Points. The NDO's in the roof of a facility the building or room in which

the emission unit is located are considered to be exhaust points. Determine volumetric flow rate

from these NDO's. Divide the cross-sectional area according to Method 1 using 12 equal areas.

Use the appropriate velocity measurement devices, e.g., propeller anemometers.

125

3.1.3 Other NDO's.

3.1.3.1 This step is optional. Determine the exhaust flow rate, including that of the control

device, from the enclosure and the intake air flow rate. If the exhaust flow rate divided by the

intake air flow rate is greater than 1.1, then all other NDO's are not considered to be significant

exhaust points.

3.1.3.2 If the option above is not taken, identify all other NDO's and other potential points

through which fugitive emissions may escape the enclosure. Then use the following criteria to

determine whether flow rates and VOM concentrations need to be measured:

3.1.3.2.1 Using the appropriate flow direction indicator, determine the flow direction. An NDO

with zero or inward flow is not an exhaust point.

3.1.3.2.2 Measure the outward volumetric flow rate from the remainder of the NDO's. If the

collective flow rate is 2 percent, or less, of the flow rate from Sections 3.1.1 and 3.1.2, then these

NDO's, except those within two equivalent diameters (based on NDO opening) from a VOM

emitting point, may be considered to be non-exhaust points.

3.1.3.2.3 If the percentage calculated in Section 3.1.3.2.2 is greater than 2 percent, those NDO's

(except those within two equivalent diameters from a VOM emitting point) whose volumetric

flow rate total 2 percent of the flow rate from Sections 3.1.1 and 3.1.2 may be considered as

non-exhaust points. All remaining NDO's shall be measured for volumetric flow rate and VOM

concentrations during the CE test.

3.1.3.2.4 The tester may choose to measure VOM concentrations at the forced exhaust points

and the NDO's. If the total VOM emissions from the NDO's are less than 2 percent of the

emissions from the forced draft and roof NDO's, then these NDO's may be eliminated from

further consideration.

3.2 Determination of Flow Rates.

3.2.1 Measure the volumetric flow rate at all locations identified as exhaust points in Section

3.1. Divide each exhaust opening into 9 equal areas for rectangular openings and 8 for circular

openings.

3.2.2 Measure the velocity at each site at least once every hour during each sampling run using

Method 2 or 2A, if applicable, or using the low velocity instruments in Section 2.2.2.

DETERMINATION OF VOM CONTENT OF FUGITIVE EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each fugitive emission point during the

entire test run or, if applicable, while the process is operating. If there are multiple emissions

locations, design a sampling system to allow a single FIA to be used to determine the VOM

responses at all sampling locations.

126

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3, respectively.

4.2.2 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct,

and is sealed tightly at the stack port connection.

4.2.3 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position.

4.2.4 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform drift checks

during the run not to exceed one drift check per hour.

4.2.5 Verify that the sample lines, filter, and pump temperatures are 120



NC.

4.2.6 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple emission locations are sampled using a single FIA, sample at each location for the same

amount of time (e.g., 2 minutes) and continue to switch from one location to another for the

entire test run. Be sure that total sampling time at each location is the same at the end of the test

run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the response measurements at each sampling location until two times the

response time of the measurement system has elapsed. Continue sampling for at least 1 minute

and record the concentration measurements.

4.3 Alternative Procedure The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

127

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the captured emissions for conducting the drift checks. Introduce the zero and

calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate and

pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct a system drift check at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before each test run.

5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

percent.

NOMENCLATURE

CDH

average measured concentration for the drift check calibration gas, ppm propane;

CD0

average system drift check concentration for zero concentration gas, ppm

propane;

CFj

corrected average VOM concentration of fugitive emissions at point j, ppm

propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of fugitive emissions from the building, kg;

1.830 x 10-6 kg/(m3-ppm);

number of measurement points;

QFj

average effluent volumetric flow rate corrected to standard conditions at fugitive

emissions point j, m3/min;

128

total duration of capture efficiency sampling run, min.

CALCULATIONS

7.1 Total VOM Fugitive Emissions From the Building.

FB = & CFj QFj TF K1

Eq. 1

j=1

7.2 VOM Concentration of the Fugitive Emissions at Point j.

CFj = (Cj - CD0) CH

Eq. 2

CDH - CD0

Procedure F.1 - Fugitive VOM Emissions from Temporary Enclosures

INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the fugitive volatile organic

materials (VOM) emissions from a temporary total enclosure (TTE). It is intended to be used as

a segment in the development of liquid/gas or gas/gas protocols for determining VOM capture

efficiency (CE) for surface coating and printing operations.

1.2 Principle. The amount of fugitive VOM emissions (F) from the TTE is calculated as the

sum of the products of the VOM content (CFj), the flow rate (QFj), and the sampling time (TF)

from each fugitive emissions point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for

each fugitive emission point as follows: QFj =

these numbers, the probable uncertainty for F is estimated at about



7.4

percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

129

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow control valve and rotameter

must be heated to prevent condensation. A control valve may also be located on the sample

pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the

flame ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If emissions are to be measured at

multiple locations, the measurement system shall be designed to use separate sampling probes,

lines, and pumps for each measurement location and a common sample gas manifold and FIA.

The sample gas manifold and connecting lines to the FIA must be heated to prevent

condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than



3.0

percent of the span value.

2.1.7.2 Calibration Drift. Less than



3.0

percent of the span value.

2.1.7.3 Calibration Error. Less than



5.0

percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

130

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to



1 percent of the

tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than



2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane or

carbon equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Fugitive Emissions Volumetric Flow Rate.

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

2.3 Temporary Total Enclosure. The criteria for designing a TTE are discussed in Procedure T.

DETERMINATION OF VOLUMETRIC FLOW RATE OF FUGITIVE EMISSIONS

3.1 Locate all points where emissions are exhausted from the TTE. Using Method 1, determine

the sampling points. Be sure to check each site for cyclonic or swirling flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

DETERMINATION OF VOM CONTENT OF FUGITIVE EMISSIONS

131

4.1 Analysis Duration. Measure the VOM responses at each fugitive emission point during the

entire test run or, if applicable, while the process is operating. If there are multiple emission

locations, design a sampling system to allow a single FIA to be used to determine the VOM

responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3, respectively.

4.2.2 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct,

and is sealed tightly at the stack port connection.

4.2.3 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position.

4.2.4 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.5 Verify that the sample lines, filter, and pump temperatures are 120



NC.

4.2.6 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple emission locations are sampled using a single FIA, sample at each location for the same

amount of time (e.g., 2 minutes) and continue to switch from one location to another for the

entire test run. Be sure that total sampling time at each location is the same at the end of the test

run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the response measurements at each sampling location until two times the

response time of the measurement system has elapsed. Continue sampling for at least 1 minute

and record the concentration measurements.

4.3 Background Concentration.

4.3.1 Determination of VOM Background Concentration.

4.3.1.1 Locate all NDO's of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO's,

choose 6 sampling points evenly spaced among the NDO's.

4.3.1.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3.

132

4.3.1.3 Position the probe at the sampling location.

4.3.1.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.3 to 4.2.6.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas concentration that most closely

approximates that of the fugitive gas emissions to conduct the drift checks. Introduce the zero

and calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate

and pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct a system drift check at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before each test run.

5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

percent.

NOMENCLATURE

area of NDO i, ft2;

total area of all NDO's in the enclosure, ft2;

133

CBi

corrected average VOM concentration of background emissions at point i, ppm

propane.;

average background concentration, ppm propane;

CDH

average measured concentration for the drift check calibration gas, ppm propane;

CDO

average system drift check concentration for zero concentration gas, ppm

propane;

CFj

corrected average VOM concentration of fugitive emissions at point j, ppm

propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average background VOM concentration measured at point i,

ppm propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of captured emissions, kg;

1.830 x 10-6 kg/(m3-ppm);

number of measurement points;

QFj

average effluent volumetric flow rate corrected to standard conditions at fugitive

emissions point j, m3/min;

total duration of fugitive emissions sampling run, min.

7. CALCULATIONS

7.1 Total VOM Fugitive Emissions.

F = ? (CFj - CB ) QFj TF K1

Eq. 1

j=1

7.2 VOM Concentration of the Fugitive Emissions at Point j.

7.3 Background VOM Concentration at Point i.

CBi = (Ci - CD0) CH

Eq. 3

CDH - CD0

7.4 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure L - VOM Input

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the input of volatile organic

materials (VOM). It is intended to be used as a segment in the development of liquid/gas

protocols for determining VOM capture efficiency (CE) for surface coating and printing

operations.

1.2 Principle. The amount of VOM introduced to the process (L) is the sum of the products of

the weight (W) of each VOM containing liquid (ink, paint, solvent, etc.) used and its VOM

content (V). A sample of each VOM containing liquid is analyzed with a flame ionization

analyzer (FIA) to determine V.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

VOM containing liquid as follows: W = 2.0 percent and V =



12.0

percent. Based on these

numbers, the probable uncertainty for L is estimated at about

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

APPARATUS AND REAGENTS

135

2.1 Liquid Weight.

2.1.1 Balances/Digital Scales. To weigh drums of VOM containing liquids to within 0.2 lb.

2.1.2 Volume Measurement Apparatus (Alternative). Volume meters, flow meters, density

measurement equipment, etc., as needed to achieve same accuracy as direct weight

measurements.

2.2 VOM Content (Flame Ionization Analyzer Technique). The liquid sample analysis system is

shown in Figures 1 and 2. The following equipment is required:

2.2.1 Sample Collection Can. An appropriately sized metal can to be used to collect VOM

containing materials. The can must be constructed in such a way that it can be grounded to the

coating container.

2.2.2 Needle Valves. To control gas flow.

2.2.3 Regulators. For carrier gas and calibration gas cylinders.

2.2.4 Tubing. Teflon or stainless steel tubing with diameters and lengths determined by

connection requirements of equipment. The tubing between the sample oven outlet and the FIA

shall be heated to maintain a temperature of 120



NC.

2.2.5 Atmospheric Vent. A tee and 0- to 0.5-liter/min rotameter placed in the sampling line

between the carrier gas cylinder and the VOM sample vessel to release the excess carrier gas. A

toggle valve placed between the tee and the rotameter facilitates leak tests of the analysis system.

2.2.6 Thermometer. Capable of measuring the temperature of the hot water bath to within 1NC.

2.2.7 Sample Oven. Heated enclosure, containing calibration gas coil heaters, critical orifice,

aspirator, and other liquid sample analysis components, capable of maintaining a temperature of

120



NC.

2.2.8 Gas Coil Heaters. Sufficient lengths of stainless steel or Teflon tubing to allow zero and

calibration gases to be heated to the sample oven temperature before entering the critical orifice

or aspirator.

2.2.9 Water Bath. Capable of heating and maintaining a sample vessel temperature of 100



NC.

2.2.10 Analytical Balance. To measure



0.001 g.

2.2.11 Disposable Syringes. 2-cc or 5-cc.

2.2.12 Sample Vessel. Glass, 40-ml septum vial. A separate vessel is needed for each sample.

136

2.2.13 Rubber Stopper. Two-hole stopper to accommodate 3.2-mm (1/8-in.) Teflon tubing,

appropriately sized to fit the opening of the sample vessel. The rubber stopper should be

wrapped in Teflon tape to provide a tighter seal and to prevent any reaction of the sample with

the rubber stopper. Alternatively, any leak-free closure fabricated of non-reactive materials and

accommodating the necessary tubing fittings may be used.

2.2.14 Critical Orifices. Calibrated critical orifices capable of providing constant flow rates

from 50 to 250 ml/min at known pressure drops. Sapphire orifice assemblies (available from

O'Keefe Controls Company) and glass capillary tubing have been found to be adequate for this

application.

2.2.15 Vacuum Gauge. 0- to 760-mm (0- to 30-in.) Hg U-Tube manometer or vacuum gauge.

2.2.16 Pressure Gauge. Bourdon gauge capable of measuring the maximum air pressure at the

aspirator inlet (e.g., 100 psig).

2.2.17 Aspirator. A device capable of generating sufficient vacuum at the sample vessel to

create critical flow through the calibrated orifice when sufficient air pressure is present at the

aspirator inlet. The aspirator must also provide sufficient sample pressure to operate the FIA.

The sample is also mixed with the dilution gas within the aspirator.

2.2.18 Soap Bubble Meter. Of an appropriate size to calibrate the critical orifices in the system.

2.2.19 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.2.19.1 Zero Drift. Less than



3.0 percent of the span value.

2.2.19.2 Calibration Drift. Less than



3.0 percent of span value.

2.2.19.3 Calibration Error. Less than



5.0 percent of the

calibration gas value.

2.2.20 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.2.21 Chart Recorder (Optional). A chart recorder or similar device is recommended to provide

a continuous analog display of the measurement results during the liquid sample analysis.

2.2.22 Calibration and Other Gases. For calibration, fuel, and combustion air (if required)

contained in compressed gas cylinders. All calibration gases shall be traceable to NIST

standards and shall be certified by the manufacturer to



1 percent of the tag value.

Additionally,

137

the manufacturer of the cylinder should provide a recommended shelf life for each calibration

gas cylinder over which the concentration does not change more than



2 percent from the certified

value. For calibration gas values not generally available, alternative methods for preparing

calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.2.22.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.2.22.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane) or

less than 0.1 percent of the span value, whichever is greater.

2.2.22.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards

with nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.2.22.4 System Calibration Gas. Gas mixture standard containing propane in air,

approximating the undiluted VOM concentration expected for the liquid samples.

DETERMINATION OF LIQUID INPUT WEIGHT

3.1 Weight Difference. Determine the amount of material introduced to the process as the

weight difference of the feed material before and after each sampling run. In determining the

total VOM containing liquid usage, account for: (a) the initial (beginning) VOM containing

liquid mixture; (b) any solvent added during the test run; (c) any coating added during the test

run; and (d) any residual VOM containing liquid mixture remaining at the end of the sample run.

3.1.1 Identify all points where VOM containing liquids are introduced to the process. To obtain

an accurate measurement of VOM containing liquids, start with an empty fountain (if

applicable). After completing the run, drain the liquid in the fountain back into the liquid drum

(if possible), and weigh the

drum again. Weigh the VOM containing liquids to



0.5 percent of the total weight (full) or



0.1

percent of the total weight of VOM containing liquid used during the sample run, whichever is

less. If the residual liquid cannot be returned to the drum, drain the fountain into a preweighed

empty drum to determine the final weight of the liquid.

3.1.2 If it is not possible to measure a single representative mixture, then weigh the various

components separately (e.g., if solvent is added during the sampling run, weigh the solvent

before it is added to the mixture). If a fresh drum of VOM containing liquid is needed during the

run, then weigh both the empty drum and fresh drum.

3.2 Volume Measurement (Alternative). If direct weight measurements are not feasible, the

tester may use volume meters and flow rate meters (and density measurements) to determine the

weight of liquids used if it can be demonstrated that the technique produces results equivalent to

138

the direct weight measurements. If a single representative mixture cannot be measured, measure

the components separately.

DETERMINATION OF VOM CONTENT IN INPUT LIQUIDS

4.1 Collection of Liquid Samples.

4.1.1 Collect a 100-ml or larger sample of the VOM containing liquid mixture at each

application location at the beginning and end of each test run. A separate sample should be taken

of each VOM containing liquid added to the application mixture during the test run. If a fresh

drum is needed during the sampling run, then obtain a sample from the fresh drum.

4.1.2 When collecting the sample, ground the sample container to the coating drum. Fill the

sample container as close to the rim as possible to minimize the amount of headspace.

4.1.3 After the sample is collected, seal the container so the sample cannot leak out or evaporate.

4.1.4 Label the container to identify clearly the contents.

4.2 Liquid Sample VOM Content.

4.2.1 Assemble the liquid VOM content analysis system as shown in Figure 1.

4.2.2 Permanently identify all of the critical orifices that may be used. Calibrate each critical

orifice under the expected operating conditions (i.e., sample vacuum and temperature) against a

volume meter as described in Section 5.3.

4.2.3 Label and tare the sample vessels (including the stoppers and caps) and the syringes.

4.2.4 Install an empty sample vessel and perform a leak test of the system. Close the carrier gas

valve and atmospheric vent and evacuate the sample vessel to 250 mm (10 in.) Hg absolute or

less using the aspirator. Close the toggle valve at the inlet to the aspirator and observe the

vacuum for at least one minute. If there is any change in the sample pressure, release the

vacuum, adjust or repair the apparatus as necessary and repeat the leak test.

4.2.5 Perform the analyzer calibration and linearity checks according to the procedure in Section

5.1. Record the responses to each of the calibration gases and the back-pressure setting of the

FIA.

4.2.6 Establish the appropriate dilution ratio by adjusting the aspirator air supply or substituting

critical orifices. Operate the aspirator at a vacuum of at least 25 mm (1 in.) Hg greater than the

vacuum necessary to achieve critical flow. Select the dilution ratio so that the maximum

response of the FIA to the sample does not exceed the high-range calibration gas.

4.2.7 Perform system calibration checks at two levels by introducing compressed gases at the

inlet to the sample vessel while the aspirator and dilution devices are operating. Perform these

139

checks using the carrier gas (zero concentration) and the system calibration gas. If the response

to the carrier gas exceeds



0.5

percent of span, clean or repair the apparatus and repeat the check.

Adjust the dilution ratio as necessary to achieve the correct response to the upscale check, but do

not adjust the analyzer calibration. Record the identification of the orifice, aspirator air supply

pressure, FIA back-pressure, and the responses of the FIA to the carrier and system calibration

gases.

4.2.8 After completing the above checks, inject the system calibration gas for approximately 10

minutes. Time the exact duration of the gas injection using a stopwatch. Determine the area

under the FIA response curve and calculate the system response factor based on the sample gas

flow rate, gas concentration, and the duration of the injection as compared to the integrated

response using Equations 2 and 3.

4.2.9 Verify that the sample oven and sample line temperatures are 120



NC and that the water

bath temperature is 100



NC.

4.2.10 Fill a tared syringe with approximately 1 g of the VOM containing liquid and weigh it.

Transfer the liquid to a tared sample vessel. Plug the sample vessel to minimize sample loss.

Weigh the sample vessel containing the liquid to determine the amount of sample actually

received. Also, as a quality control check, weigh the empty syringe to determine the amount of

material delivered. The two coating sample weights should agree within



0.02

g. If not, repeat

the procedure until an acceptable sample is obtained.

4.2.11 Connect the vessel to the analysis system. Adjust the aspirator supply pressure to the

correct value. Open the valve on the carrier gas supply to the sample vessel and adjust it to

provide a slight excess flow to the atmospheric vent. As soon as the initial response of the FIA

begins to decrease, immerse the sample vessel in the water bath. (Applying heat to the sample

vessel too soon may cause the FID response to exceed the calibrated range of the instrument, and

thus invalidate the analysis.)

4.2.12 Continuously measure and record the response of the FIA until all of the volatile material

has been evaporated from the sample and the instrument response has returned to the baseline

(i.e., response less than 0.5 percent of the span value). Observe the aspirator supply pressure,

FIA back-pressure, atmospheric vent, and other system operating parameters during the run;

repeat the analysis procedure if any of these parameters deviate from the values established

during the system calibration checks in Section 4.2.7. After each sample perform the drift check

described in Section 5.2. If the drift check results are acceptable, calculate the VOM content of

the sample using the equations in Section 7. Integrate the area under the FIA response curve, or

determine the average concentration response and the duration of sample analysis.

CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

140

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. After each sample, repeat the system calibration checks in Section

4.2.7 before any adjustments to the FIA or measurement system are made. If the zero or

calibration drift exceeds



3 percent of the span value, discard the result and repeat the analysis.

5.3 Critical Orifice Calibration.

5.3.1 Each critical orifice must be calibrated at the specific operating conditions that it will be

used. Therefore, assemble all components of the liquid sample analysis system as shown in

Figure 3. A stopwatch is also required.

5.3.2 Turn on the sample oven, sample line, and water bath heaters and allow the system to

reach the proper operating temperature. Adjust the aspirator to a vacuum of 380 mm (15 in.) Hg

vacuum. Measure the time required for one soap bubble to move a known distance and record

barometric pressure.

5.3.3 Repeat the calibration procedure at a vacuum of 406 mm (16 in.) Hg and at 25-mm (1-in.)

Hg intervals until three consecutive determinations provide the same flow rate. Calculate the

critical flow rate for the orifice in ml/min at standard conditions. Record the vacuum necessary

to achieve critical flow.

NOMENCLATURE

area under the response curve of the liquid sample, area count;

area under the response curve of the calibration gas, area count;

actual concentration of system calibration gas, ppm propane;

1.830 x 10-9 g/(ml-ppm);

total VOM content of liquid input, kg;

mass of liquid sample delivered to the sample vessel, g;

flow rate through critical orifice, ml/min;

liquid analysis system response factor, g/area count;

141

total gas injection time for system calibration gas during integrator

calibration, min;

VFj

final VOM fraction of VOM containing liquid j;

VIj

initial VOM fraction of VOM containing liquid j;

VAj

VOM fraction of VOM containing liquid j added during the run;

VOM fraction of liquid sample;

WFj

weight of VOM containing liquid j remaining at end of the run, kg;

WIj

weight of VOM containing liquid j at beginning of the run, kg;

WAj

weight of VOM containing liquid j added during the run, kg.

CALCULATIONS

7.1 Total VOM Content of the Input VOM Containing Liquid.

L = ? VIj WIj = VFj WFj + ? VAj WAj R

Eq. 1

j=1

7.2 Liquid Sample Analysis System Response Factor for Systems Using Integrators,

Grams/Area Counts.

RF = CS q TS K

Eq. 2

7.3 VOM Content of the Liquid Sample.

V = AL RF

Eq. 3

Procedure T - Criteria for and Verification of a Permanent or Temporary Total Enclosure

INTRODUCTION

1.1 Applicability. This procedure is used to determine whether a permanent or temporary

enclosure meets the criteria of a total enclosure.

142

1.2 Principle. An enclosure is evaluated against a set of criteria. If the criteria are met and if all

the exhaust gases are ducted to a control device, then the volatile organic materials (VOM)

capture efficiency (CE) is assumed to be 100 percent and CE need not be measured. However, if

part of the exhaust gas stream is not ducted to a control device, CE must be determined.

DEFINITIONS

2.1 Natural Draft Opening (NDO) -- Any permanent opening in the enclosure that remains open

during operation of the emission unit and is not connected to a duct in which a fan is installed.

2.2 Permanent Total Enclosure (PTE) -- A permanently installed enclosure that completely

surrounds an emissionunit such that all VOM emissions are captured and contained for discharge

through a control device.

2.3 Temporary Total Enclosure (TTE) -- A temporarily installed enclosure that completely

surrounds an emissionunit such that all VOM emissions are captured and contained for discharge

through ducts that allow for the accurate measurement of VOM rates.

CRITERIA OF A TEMPORARY TOTAL ENCLOSURE

3.1 Any NDO shall be at least 4 equivalent opening diameters from each VOM emitting point.

3.2 Any exhaust point from the enclosure shall be at least 4 equivalent duct or hood diameters

from each NDO.

3.3 The total area of all NDO's shall not exceed 5 percent of the surface area of the enclosure's

four walls, floor, and ceiling.

3.4 The average facial velocity (FV) of air through all NDO's shall be at least 3,600 m/hr (200

fpm). The direction of air through all NDO's shall be into the enclosure.

3.5 All access doors and windows whose areas are not included in Section 3.3 and are not

included in the calculation in Section 3.4 shall be closed during routine operation of the emission

unit.

CRITERIA OF A PERMANENT TOTAL ENCLOSURE

4.1 Same as Sections 3.1 and 3.3 - 3.5.

4.2 All VOM emissions must be captured and contained for discharge through a control device.

PROCEDURE

5.1 Determine the equivalent diameters of the NDO's and determine the distances from each

VOM emitting point to all NDO's. Determine the equivalent diameter of each exhaust duct or

143

hood and its distance to all NDO's. Calculate the distances in terms of equivalent diameters.

The number of equivalent diameters shall be at least 4.

5.2 Measure the total area (At) of the enclosure and the total area (AN) of all NDO's of the

enclosure. Calculate the NDO to enclosure area ratio (NEAR) as follows:

NEAR = AN/At

The NEAR must be < 0.05.

5.3 Measure the volumetric flow rate, corrected to standard conditions, of each gas stream

exiting the enclosure through an exhaust duct or hood using EPA Method 2. In some cases (e.g.,

when the building is the enclosure), it may be necessary to measure the volumetric flow rate,

corrected to standard conditions, of each gas stream entering the enclosure through a forced

makeup air duct using Method 2. Calculate FV using the following equation:

FV = [QO - QI]/AN

where:

the sum of the volumetric flow from all gas streams exiting the enclosure through

an exhaust duct or hood.

the sum of the volumetric flow from all gas streams into the enclosure

through a forced makeup air duct; zero, if there is no forced makeup air into the enclosure.

total area of all NDO's in enclosure.

The FV shall be at least 3,600 m/hr (200 fpm).

5.4 Verify that the direction of air flow through all NDO's is inward. Use streamers, smoke

tubes, tracer gases, etc. Strips of plastic wrapping film have been found to be effective. Monitor

the direction of air flow at intervals of at least 10 minutes for at least 1 hour.

QUALITY ASSURANCE

6.1 The success of this protocol lies in designing the TTE to simulate the conditions that exist

without the TTE, i.e., the effect of the TTE on the normal flow patterns around the affected

emission unit or the amount of fugitive VOM emissions should be minimal. The TTE must

enclose the application stations, coating reservoirs, and all areas from the application station to

the oven. The oven does not have to be enclosed if it is under negative pressure. The NDO's of

the temporary enclosure and a fugitive exhaust fan must be properly sized and placed.

6.2. Estimate the ventilation rate of the TTE that best simulates the conditions that exist without

the TTE, i.e., the effect of the TTE on the normal flow patterns around the affected emission unit

144

or the amount of fugitive VOM emissions should be minimal. Figure 1 may be used as an aid.

Measure the concentration (CG) and flow rate (QG) of the captured gas stream, specify a safe

concentration (CF) for the fugitive gas stream, estimate the CE, and then use the plot in Figure 1

to determine the volumetric flowrate of the fugitive gas stream (QF). A fugitive VOM emission

exhaust fan that has a variable flow control is desirable.

6.2.1 Monitor the concentration of VOM into the capture device without the TTE. To minimize

the effect of temporal variation on the captured emissions, the baseline measurement should be

made over as long a time period as practical. However, the process conditions must be the same

for the measurement in Section 6.2.3 as they are for this baseline measurement. This may

require short measuring times for this quality control check before and after the construction of

the TTE.

6.2.2 After the TTE is constructed, monitor the VOM concentration inside the TTE. This

concentration shall not continue to increase and must not exceed the safe level according to

OSHA requirements for permissible exposure limits. An increase in VOM concentration

indicates poor TTE design or poor capture efficiency.

Monitor the concentration of VOM into the capture device with the TTE. To limit the effect of

the TTE on the process, the VOM concentration with and without the TTE must be within



percent. If the measurements do not agree, adjust the ventilation rate from the TTE until they

agree within 10 percent.

(Source: Repealed at 29 Ill Reg. ________, effective ________________)

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSIONS STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART 219

ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS FOR

THE METRO EAST AREA

SUBPART A: GENERAL PROVISIONS

Section

219.100 Introduction

219.101 Savings Clause

219.102 Abbreviations and Conversion Factors

219.103 Applicability

219.104 Definitions

219.105 Test Methods and Procedures

219.106 Compliance Dates

219.107 Operation of Afterburners

219.108 Exemptions, Variations, and Alternative Means of Control or Compliance

145

Determinations

219.109 Vapor Pressure of Volatile Organic Liquids

219.110 Vapor Pressure of Organic Material or Solvent

219.111 Vapor Pressure of Volatile Organic Material

219.112 Incorporations by Reference

219.113 Monitoring for Negligibly-Reactive Compounds

SUBPART B: ORGANIC EMISSIONS FROM STORAGE AND LOADING

OPERATIONS

Section

219.119 Applicability for VOL

219.120 Control Requirements for Storage Containers of VOL

219.121 Storage Containers of VPL

219.122 Loading Operations

219.123 Petroleum Liquid Storage Tanks

219.124 External Floating Roofs

219.125 Compliance Dates

219.126 Compliance Plan (Repealed)

219.127 Testing VOL Operations

219.128 Monitoring VOL Operations

219.129 Recordkeeping and Reporting for VOL Operations

SUBPART C: ORGANIC EMISSIONS FROM MISCELLANEOUS

EQUIPMENT

Section

219.141 Separation Operations

219.142 Pumps and Compressors

219.143 Vapor Blowdown

219.144 Safety Relief Valves

SUBPART E: SOLVENT CLEANING

Section

219.181 Solvent Cleaning in General

219.182 Cold Cleaning

219.183 Open Top Vapor Degreasing

219.184 Conveyorized Degreasing

219.185 Compliance Schedule (Repealed)

219.186 Test Methods

SUBPART F: COATING OPERATIONS

Section

219.204 Emission Limitations

219.205 Daily-Weighted Average Limitations

219.206 Solids Basis Calculation

219.207 Alternative Emission Limitations

219.208 Exemptions From Emission Limitations

146

219.209 Exemption From General Rule on Use of Organic Material

219.210 Compliance Schedule

219.211 Recordkeeping and Reporting

219.212 Cross-Line Averaging to Establish Compliance for Coating Lines

219.213 Recordkeeping and Reporting for Cross-Line Averaging Participating Coating

Lines

219.214 Changing Compliance Methods

219.215 Wood Furniture Coating Averaging Approach

219.216 Wood Furniture Coating Add-On Control Use

219.217 Wood Furniture Coating Work Practice Standards

SUBPART G: USE OF ORGANIC MATERIAL

Section

219.301 Use of Organic Material

219.302 Alternative Standard

219.303 Fuel Combustion Emission Units

219.304 Operations with Compliance Program

SUBPART H: PRINTING AND PUBLISHING

Section

219.401 Flexographic and Rotogravure Printing

219.402 Applicability

219.403 Compliance Schedule

219.404 Recordkeeping and Reporting

219.405 Lithographic Printing: Applicability

219.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to March

15, 1996

219.407 Emission Limitations and Control Requirements for Lithographic Printing Lines

On and After March 15, 1996

219.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996

219.409 Testing for Lithographic Printing On and After March 15, 1996

219.410 Monitoring Requirements for Lithographic Printing

219.411 Recordkeeping and Reporting for Lithographic Printing

SUBPART Q: SYNTHETIC ORGANIC CHEMICAL AND POLYMER

MANUFACTURING PLANT

Section

219.421 General Requirements

219.422 Inspection Program Plan for Leaks

219.423 Inspection Program for Leaks

219.424 Repairing Leaks

219.425 Recordkeeping for Leaks

219.426 Report for Leaks

219.427 Alternative Program for Leaks

219.428 Open-Ended Valves

219.429 Standards for Control Devices

147

219.430 Compliance Date (Repealed)

219.431 Applicability

219.432 Control Requirements

219.433 Performance and Testing Requirements

219.434 Monitoring Requirements

219.435 Recordkeeping and Reporting Requirements

219.436 Compliance Date

SUBPART R: PETROLEUM REFINING AND RELATED INDUSTRIES;

ASPHALT MATERIALS

Section

219.441 Petroleum Refinery Waste Gas Disposal

219.442 Vacuum Producing Systems

219.443 Wastewater (Oil/Water) Separator

219.444 Process Unit Turnarounds

219.445 Leaks: General Requirements

219.446 Monitoring Program Plan for Leaks

219.447 Monitoring Program for Leaks

219.448 Recordkeeping for Leaks

219.449 Reporting for Leaks

219.450 Alternative Program for Leaks

219.451 Sealing Device Requirements

219.452 Compliance Schedule for Leaks

219.453 Compliance Dates (Repealed)

SUBPART S: RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS

Section

219.461 Manufacture of Pneumatic Rubber Tires

219.462 Green Tire Spraying Operations

219.463 Alternative Emission Reduction Systems

219.464 Emission Testing

219.465 Compliance Dates (Repealed)

219.466 Compliance Plan (Repealed)

SUBPART T: PHARMACEUTICAL MANUFACTURING

Section

219.480 Applicability

219.481 Control of Reactors, Distillation Units, Crystallizers, Centrifuges and Vacuum

Dryers

219.482 Control of Air Dryers, Production Equipment Exhaust Systems and Filters

219.483 Material Storage and Transfer

219.484 In-Process Tanks

219.485 Leaks

219.486 Other Emission Units

219.487 Testing

219.488 Monitoring for Air Pollution Control Equipment

148

219.489 Recordkeeping for Air Pollution Control Equipment

SUBPART V: BATCH OPERATIONS AND AIR OXIDATION PROCESSES

Section

219.500 Applicability for Batch Operations

219.501 Control Requirements for Batch Operations

219.502 Determination of Uncontrolled Total Annual Mass Emissions and Actual

Weighted Average Flow Rate Values for Batch Operations

219.503 Performance and Testing Requirements for Batch Operations

219.504 Monitoring Requirements for Batch Operations

219.505 Reporting and Recordkeeping for Batch Operations

219.506 Compliance Date

219.520 Emission Limitations for Air Oxidation Processes

219.521 Definitions (Repealed)

219.522 Savings Clause

219.523 Compliance

219.524 Determination of Applicability

219.525 Emission Limitations for Air Oxidation Processes (Renumbered)

219.526 Testing and Monitoring

219.527 Compliance Date (Repealed)

SUBPART W: AGRICULTURE

Section

219.541 Pesticide Exception

SUBPART X: CONSTRUCTION

Section

219.561 Architectural Coatings

219.562 Paving Operations

219.563 Cutback Asphalt

SUBPART Y: GASOLINE DISTRIBUTION

Section

219.581 Bulk Gasoline Plants

219.582 Bulk Gasoline Terminals

219.583 Gasoline Dispensing Operations - Storage Tank Filling Operations

219.584 Gasoline Delivery Vessels

219.585 Gasoline Volatility Standards

219.586 Gasoline Dispensing Operations - Motor Vehicle Fueling Operations (Repealed)

SUBPART Z: DRY CLEANERS

Section

219.601 Perchloroethylene Dry Cleaners (Repealed)

219.602 Exemptions (Repealed)

219.603 Leaks (Repealed)

219.604 Compliance Dates (Repealed)

149

219.605 Compliance Plan (Repealed)

219.606 Exception to Compliance Plan (Repealed)

219.607 Standards for Petroleum Solvent Dry Cleaners

219.608 Operating Practices for Petroleum Solvent Dry Cleaners

219.609 Program for Inspection and Repair of Leaks

219.610 Testing and Monitoring

219.611 Exemption for Petroleum Solvent Dry Cleaners

219.612 Compliance Dates (Repealed)

219.613 Compliance Plan (Repealed)

SUBPART AA: PAINT AND INK MANUFACTURING

Section

219.620 Applicability

219.621 Exemption for Waterbase Material and Heatset-Offset Ink

219.623 Permit Conditions

219.624 Open-Top Mills, Tanks, Vats or Vessels

219.625 Grinding Mills

219.626 Storage Tanks

219.628 Leaks

219.630 Clean Up

219.636 Compliance Schedule

219.637 Recordkeeping and Reporting

SUBPART BB: POLYSTYRENE PLANTS

Section

219.640 Applicability

219.642 Emissions Limitation at Polystyrene Plants

219.644 Emissions Testing

SUBPART FF: BAKERY OVENS (REPEALED)

Section

219.720 Applicability (Repealed)

219.722 Control Requirements (Repealed)

219.726 Testing (Repealed)

219.727 Monitoring (Repealed)

219.728 Recordkeeping and Reporting (Repealed)

219.729 Compliance Date (Repealed)

219.730 Certification (Repealed)

SUBPART GG: MARINE TERMINALS

Section

219.760 Applicability

219.762 Control Requirements

219.764 Compliance Certification

219.766 Leaks

219.768 Testing and Monitoring

150

219.770 Recordkeeping and Reporting

SUBPART HH: MOTOR VEHICLE REFINISHING

Section

219.780 Emission Limitations

219.782 Alternative Control Requirements

219.784 Equipment Specifications

219.786 Surface Preparation Materials

219.787 Work Practices

219.788 Testing

219.789 Monitoring and Recordkeeping for Control Devices

219.790 General Recordkeeping and Reporting (Repealed)

219.791 Compliance Date

219.792 Registration

219.875 Applicability of Subpart BB (Renumbered)

219.877 Emissions Limitation at Polystyrene Plants (Renumbered)

219.879 Compliance Date (Repealed)

219.881 Compliance Plan (Repealed)

219.883 Special Requirements for Compliance Plan (Repealed)

219.886 Emissions Testing (Renumbered)

SUBPART PP: MISCELLANEOUS FABRICATED PRODUCT

MANUFACTURING PROCESSES

Section

219.920 Applicability

219.923 Permit Conditions

219.926 Control Requirements

219.927 Compliance Schedule

219.928 Testing

SUBPART QQ: MISCELLANEOUS FORMULATION MANUFACTURING

PROCESSES

Section

219.940 Applicability

219.943 Permit Conditions

219.946 Control Requirements

219.947 Compliance Schedule

219.948 Testing

SUBPART RR: MISCELLANEOUS ORGANIC CHEMICAL

MANUFACTURING PROCESSES

Section

219.960 Applicability

219.963 Permit Conditions

219.966 Control Requirements

219.967 Compliance Schedule

151

219.968 Testing

SUBPART TT: OTHER EMISSION UNITS

Section

219.980 Applicability

219.983 Permit Conditions

219.986 Control Requirements

219.987 Compliance Schedule

219.988 Testing

SUBPART UU: RECORDKEEPING AND REPORTING

Section

219.990 Exempt Emission Units

219.991 Subject Emission Units

APPENDIX A: List of Chemicals Defining Synthetic Organic Chemical and Polymer

Manufacturing

APPENDIX B: VOM Measurement Techniques for Capture Efficiency (Repealed)

APPENDIX C: Reference Methods And Procedures

APPENDIX D: Coefficients for the Total Resource Effectiveness Index (TRE) Equation

APPENDIX E: List of Affected Marine Terminals

APPENDIX G: TRE Index Measurements for SOCMI Reactors and Distillation Units

APPENDIX H: Baseline VOM Content Limitations for Subpart F, Section 219.212 Cross-

Line Averaging

AUTHORITY: Implementing Section 10 and authorized by Section 27, 28 and 28.5 of the

Environmental Protection Act [415 ILCS 5/10, 27, 28 and 28.5].

SOURCE: Adopted at R91-8 at 15 Ill. Reg. 12491, effective August 16, 1991; amended in R91-

24 at 16 Ill. Reg. 13597, effective August 24, 1992; amended in R91-30 at 16 Ill. Reg. 13883,

effective August 24, 1992; emergency amendment in R93-12 at 17 Ill. Reg. 8295, effective May

24, 1993, for a maximum of 150 days, amended in R93-9 at 17 Ill. Reg. 16918, effective

September 27, 1993 and October 21, 1993; amended in R93-28 at 18 Ill. Reg. 4242, effective

March 3, 1994; amended in R94-12 at 18 Ill. Reg. 14987, effective September 21, 1994;

amended in R94-15 at 18 Ill. Reg. 16415, effective October 25, 1994; amended in R94-16 at 18

Ill. Reg. 16980, effective November 15, 1994; emergency amendment in R95-10 at 19 Ill. Reg.

3059, effective February 28, 1995, for a maximum of 150 days; amended in R94-21, R94-31 and

R94-32 at 19 Ill. Reg. 6958, effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7385,

effective May 22, 1995; amended in R96-2 at 20 Ill. Reg. 3848, effective February 15, 1996;

amended in R96-13 at 20 Ill. Reg. 14462, effective October 28, 1996; amended in R97-24 at 21

Ill. Reg. 7721, effective June 9, 1997; amended in R97-31 at 22 Ill. Reg. 3517, effective

February 2, 1998.; amended in R04-20 at ___ Ill. Reg. _______, effective _______.

BOARD NOTE: This Part implements the Illinois Environmental Protection Act as of July 1,

1994.

152

SUBPART A: GENERAL PROVISIONS

Section 219.105 Test Methods and Procedures

a) Coatings, Inks and Fountain Solutions

The following test methods and procedures shall be used to determine compliance

of as applied coatings, inks, and fountain solutions with the limitations set forth in

this Part.

1) Sampling: Samples collected for analyses shall be one-liter taken into a

one-liter container at a location and time such that the sample will be

representative of the coating as applied (i.e., the sample shall include any

dilution solvent or other VOM added during the manufacturing process).

The container must be tightly sealed immediately after the sample is taken.

Any solvent or other VOM added after the sample is taken must be

measured and accounted for in the calculations in subsection (a)(3) of this

Section. For multiple package coatings, separate samples of each

component shall be obtained. A mixed sample shall not be obtained as it

will cure in the container. Sampling procedures shall follow the

guidelines presented in:

A) ASTM D3925-81 (1985) standard practice for sampling liquid

by reference in Section 219.112 of this Part.

B) ASTM E300-86 standard practice for sampling industrial

chemicals. This practice is incorporated by reference in Section

219.112 of this Part.

2) Analyses: The applicable analytical methods specified below shall be used

to determine the composition of coatings, inks, or fountain solutions as

applied.

A) Method 24 of 40 CFR 60, Appendix A, incorporated by reference

in Section 219.112 of this Part, shall be used to determine the

VOM content and density of coatings. If it is demonstrated to the

satisfaction of the Agency and the USEPA that plant coating

formulation data are equivalent to Method 24 results, formulation

data may be used. In the event of any inconsistency between a

Method 24 test and a facility's formulation data, the Method 24 test

will govern.

B) Method 24A of 40 CFR Part 60, Appendix A, incorporated by

reference in Section 219.112, shall be used to determine the VOM

content and density of rotogravure printing inks and related

153

coatings. If it is demonstrated to the satisfaction of the Agency

and USEPA that the plant coating formulation data are equivalent

to Method 24A results, formulation data may be used. In the event

of any inconsistency between a Method 24A test and formulation

data, the Method 24A test will govern.

C) The following ASTM methods are the analytical procedures for

determining VOM:

i) ASTM D1475-85: Standard test method for density of

paint, varnish, lacquer and related products. This test

method is incorporated by reference in Section 219.112 of

this Part.

ii) ASTM D2369-87: Standard test method for volatile content

of a coating. This test method is incorporated by reference

in Section 219.112 of this Part.

iii) ASTM D3792-86: Standard test method for water content

of water-reducible paints by direct injection into a gas

chromatograph. This test method is incorporated by

reference in Section 219.112 of this Part.

iv) ASTM D4017-81 (1987): Standard test method for water

content in paints and paint materials by the Karl Fischer

method. This test method is incorporated by reference in

Section 219.112 of this Part.

v) ASTM D4457-85: Standard test method for determination

of dichloromethane and 1,1,1, trichloroethane in paints and

coatings by direct injection into a gas chromatograph. (The

procedure delineated above can be used to develop

protocols for any compounds specifically exempted from

the definition of VOM.) This test method is incorporated by

reference in Section 219.112 of this Part.

vi) ASTM D2697-86: Standard test method for volume non-

volatile matter in clear or pigmented coatings. This test

method is incorporated by reference in Section 219.112 of

this Part.

vii) ASTM D3980-87: Standard practice for interlaboratory

testing of paint and related materials. This practice is

incorporated by reference in Section 219.112 of this Part.

154

viii) ASTM E180-85: Standard practice for determining the

precision of ASTM methods for analysis of and testing of

industrial chemicals. This practice is incorporated by

reference in Section 219.112 of this Part.

ix) ASTM D2372-85: Standard method of separation of

vehicle from solvent-reducible paints. This method is

incorporated by reference in Section 219.112 of this Part.

D) Use of an adaptation to any of the analytical methods specified in

subsections (a)(2)(A), (B), and (C) of this Section may not be used

unless approved by the Agency and USEPA. An owner or

operator must submit sufficient documentation for the Agency and

USEPA to find that the analytical methods specified in subsections

(a)(2)(A), (B), and (C) of this Section will yield inaccurate results

and that the proposed adaptation is appropriate.

3) Calculations: Calculations for determining the VOM content, water

content and the content of any compounds which are specifically

exempted from the definition of VOM of coatings, inks and fountain

solutions as applied shall follow the guidance provided in the following

documents:

A) "A Guide for Surface Coating Calculation", EPA-340/1-86-016,

incorporated by reference in Section 219.112 of this Part.

B) "Procedures for Certifying Quantity of Volatile Organic

Compounds Emitted by Paint, Ink and Other Coatings" (revised

June 1986), EPA-450/3-84-019, incorporated by reference in

Section 219.112 of this Part.

C) "A Guide for Graphic Arts Calculations", August 1988, EPA-

340/1-88-003, incorporated by reference in Section 219.112 of this

Part.

b) Automobile or Light-Duty Truck Test Protocol

1) The protocol for testing, including determining the transfer efficiency of

coating applicators, at primer surfacer operations and topcoat operations at

an automobile or light-duty truck assembly source shall follow the

procedure in: "Protocol for Determining the Daily Volatile Organic

Compound Emission Rate of Automobile and Light-Duty Truck Topcoat

Operations" ("topcoat protocol"), December 1988, EPA-450/3-88-018,

incorporated by reference in Section 219.112 of this Part.

2) Prior to testing pursuant to the topcoat protocol, the owner or operator of a

coating operation subject to the topcoat or primer surfacer limit in

155

Sections 219.204(a)(2) or 219.204(a)(3) shall submit a detailed testing

proposal specifying the method by which testing will be conducted and

how compliance will be demonstrated consistent with the topcoat protocol.

The proposal shall include, at a minimum, a comprehensive plan

(including a rationale) for determining the transfer efficiency at each booth

through the use of in-plant or pilot testing, the selection of coatings to be

tested (for the purpose of determining transfer efficiency) including the

rationale for coating groupings, the method for determining the analytic

VOM content of as applied coatings and the formulation solvent content

of as applied coatings, and a description of the records of coating VOM

content as applied and coating's usage which will be kept to demonstrate

compliance. Upon approval of the proposal by the Agency and USEPA,

the compliance demonstration for a coating line may proceed.

c) Capture System Efficiency Test Protocols

1) Applicability

The requirements of subsection (c)(2) of this Section shall apply to all

VOM emitting process emission units employing capture equipment (e.g.,

hoods, ducts), except those cases noted below.

A) If an emission unit is equipped with (or uses) a permanent total

enclosure (PTE) that meets Agency and USEPA specifications,

and which directs all VOM to a control device, then the emission

unit is exempted from the requirements described in subsection

(c)(2) of this Section. The Agency and USEPA specifications to

determine whether a structure is considered a PTE are given in

Method 204 Procedure T of Appendix M of 40 CFR Part 51,

incorporated by reference in Section 219.112 of this Part Appendix

B of this Part. In this instance, the capture efficiency is assumed to

be 100 percent and the emission unit is still required to measure

control efficiency using appropriate test methods as specified in

subsection (d) of this Section.

B) If an emission unit is equipped with (or uses) a control device

designed to collect and recover VOM (e.g., carbon adsorber), an

explicit measurement of capture efficiency is not necessary

provided that the conditions given below are met. The overall

control of the system can be determined by directly comparing the

input liquid VOM to the recovered liquid VOM. The general

procedure for use in this situation is given in 40 CFR 60.433,

incorporated by reference in Section 219.112 of this Part, with the

following additional restrictions:

156

i) The source owner or operator shall obtain data each

operating day for the solvent usage and solvent recovery to

permit the determination of the solvent recovery efficiency

of the system each operating day using a 7-day rolling

period. The recovery efficiency for each operating day is

computed as the ratio of the total recovered solvent for that

day and the most recent prior 6 operating days to the total

solvent usage for the same 7-day period used for the

recovered solvent, rather than a 30-day weighted average as

given in 40 CFR 60.433 incorporated by reference in

Section 219.112 of this Part. This ratio shall be expressed

as a percentage. The ratio shall be computed within 72

hours following each 7-day period. A source that believes

that the 7-day rolling period is not appropriate may use an

alternative multi-day rolling period not to exceed 30 days,

with the approval of the Agency and USEPA. In addition,

the criteria in subsection (c)(1)(B)(ii) or subsection

(c)(1)(B)(iii) below must be met.

ii) The solvent recovery system (i.e., capture and control

system) must be dedicated to a single coating line, printing

line, or other discrete activity that by itself is subject to an

applicable VOM emission standard, or

iii) If the solvent recovery system controls more than one

coating line, printing line or other discrete activity that by

itself is subject to an applicable VOM emission standard,

the overall control (i.e. the total recovered VOM divided by

the sum of liquid VOM input from all lines and other

activities venting to the control system) must meet or

exceed the most stringent standard applicable to any line or

other discrete activity venting to the control system.

2) Capture Efficiency Protocols Specific Requirements

The capture efficiency of an emission unit shall be measured using

one of the four protocols given below. Appropriate test methods to

be utilized in each of the capture efficiency protocols are described

in Appendix M of 40 CFR Part 51, incorporated by reference in

Section 219.112 of this Part. Any error margin associated with a

test method or protocol may not be incorporated into the results of

a capture efficiency test. If these techniques are not suitable for a

particular process, then an alternative capture efficiency protocol

may be used, pursuant to the provisions of Section 219.108(b) of

this Part provided that the alternative protocol is approved by the

Agency and approved by the USEPA as a SIP revision.

157

A) Gas/gas method using temporary total enclosure (TTE).

The Agency and USEPA specifications to determine

whether a temporary enclosure is considered a TTE are

given in Method 204 Procedure T of Appendix M of 40

CFR Part 51, incorporated by reference in Section 219.112

of this Part Appendix B of this Part. The capture efficiency

equation to be used for this protocol is:

CE =GwW/(GwW+ FwW)

where:

CE = capture efficiency, decimal fraction;

GwW = mass of VOM captured and

delivered to control device using a

TTE;

FwW = mass of uncaptured fugitive VOM

that escapes from a TTE.

Method 204B or 204C Procedure G.2 contained in

Appendix M of 40 CFR Part 51 Appendix B of this Part is

used to obtain GwW. Method 204D Procedure F.1 in

Appendix B in Appendix M of 40 CFR Part 51 this Part is

used to obtain FwW.

B) Liquid/gas method using TTE. The Agency and USEPA

specifications to determine whether a temporary enclosure

is considered a TTE are given in Method 204 Procedure T

of Appendix M of 40 CFR Part 51, incorporated by

reference in Section 219.112 of this Part Appendix B of

this Part. The capture efficiency equation to be used for

this protocol is:

CE =(L - FwW)/L

where:

CE = capture efficiency, decimal fraction;

L = mass of liquid VOM input to

process emission unit;

FwW = mass of uncaptured fugitive VOM

158

that escapes from a TTE.

Method 204A or 204F Procedure L contained in Appendix

M of 40 CFR Part 51 Appendix B of this Part is used to

obtain L. Procedure F.1 in Appendix M of 40 CFR Part 51

Appendix B of this Part is used to obtain FwW.

C) Gas/gas method using the building or room (building or

room enclosure), in which the affected coating line,

printing line or other emission unit is located, as the

enclosure as determined by Method 204 of Appendix M of

40 CFR Part 51, incorporated by reference in Section

219.112 of this Part and in which "FB" "F" and "G" are

measured while operating only the affected line or emission

unit. All fans and blowers in the building or room must be

operated as they would under normal production. The

capture efficiency equation to be used for this protocol is:

CE = G/(G + FB)

where:

CE = capture efficiency, decimal fraction;

G = mass of VOM captured and

delivered to control device;

= mass of uncaptured fugitive VOM

that escapes from building enclosure.

Method 204B or 204C Procedure G.2 contained in

Appendix M of 40 CFR Part 51 Appendix B of this Part is

used to obtain G. Method 204E Procedure F.2 in Appendix

M of 40 CFR Part 51 Appendix B of this Part is used to

obtain FB.

D) Liquid/gas method using the building or room (building or

room enclosure), in which the affected coating line,

printing line or other emission unit is located, as the

enclosure as determined by Method 204 of Appendix M of

40 CFR Part 51, incorporated by reference in Section

219.112 of this Part and in which "FB" "F" and "L" are

measured while operating only the affected line emission

unit. All fans and blowers in the building or room must be

operated as they would under normal production. The

capture efficiency equation to be used for this protocol is:

159

CE = (L - FB)/L

where:

CE = capture efficiency, decimal fraction;

L = mass of liquid VOM input to

process emission unit;

= mass of uncaptured fugitive VOM

that escapes from building enclosure.

Method 204A or 204F Procedure L contained

in Appendix M of 40 CFR Part 51 Appendix B of this Part

is used to obtain L. Method 204E Procedure F.2 in

Appendix M of 40 CFR Part 51 Appendix B of this Part is

used to obtain FB.

E) Mass balance using Data Quality Objective (DQO) or

Lower Confidence Limit (LCL) protocol. For a liquid/gas

input where an owner or operator is using the DQO/LCL

protocol and not using an enclosure as described in Method

204 of Appendix M of 40 CFR Part 51, incorporated by

reference in Section 219.112 of this Part, the VOM content

of the liquid input (L) must be determined using Method

204A or 204F in Appendix M of 40 CFR Part 51. The

VOM content of the captured gas stream (G) to the control

device must be determined using Method 204B or 204C in

Appendix M of 40 CFR Part 51. The results of capture

efficiency calculations (G/L) must satisfy the DQO or LCL

statistical analysis methodology as described in Section 3

of USEPA’s “Guidelines for Determining Capture

Efficiency,” incorporated by reference at Section 219.112

of this Part. Where capture efficiency testing is done to

determine emission reductions for the purpose of

establishing emission credits for offsets, shutdowns, and

trading, the LCL protocol cannot be used for these

applications. In enforcement cases, the LCL protocol

cannot confirm non-compliance.

3) Simultaneous testing of multiple lines or emission units with a

common control device. If an owner or operator has multiple lines

sharing a common control device, the capture efficiency of the

lines may be tested simultaneously, subject to the following

provisions:

160

A) Multiple line testing must meet the criteria of Section 4 of

USEPA’s “Guidelines for Determining Capture

Efficiency,” incorporated by reference at Section 219.112

of this Part;

B) The most stringent capture efficiency required for any

individual line or unit must be met by the aggregate of lines

or units; and

C) Testing of all the lines of emission units must be performed

with the same capture efficiency test protocol.

4)3) Recordkeeping and Reporting

A) All owners or operators affected by this subsection must

maintain a copy of the capture efficiency protocol

submitted to the Agency and the USEPA on file. All

results of the appropriate test methods and capture

efficiency protocols must be reported to the Agency within

sixty (60) days of the test date. A copy of the results must

be kept on file with the source for a period of three (3)

years.

B) If any changes are made to capture or control equipment,

then the source is required to notify the Agency and the

USEPA of these changes and a new test may be required by

the Agency or the USEPA.

C) The source must notify the Agency 30 days prior to

performing any capture efficiency or control test. At that

time, the source must notify the Agency which capture

efficiency protocol and control device test methods will be

used. Notification of the actual date and expected time of

testing must be submitted a minimum of 5 working days

prior to the actual date of the test. The Agency may at its

discretion accept notification with shorter advance notice

provided that such arrangements do not interfere with the

Agency’s ability to review the protocol and/or observe

testing.

D) Sources utilizing a PTE must demonstrate that this

enclosure meets the requirement given in Method 204

Procedure T (in Appendix M of 40 CFR Part 51,

incorporated by reference in Section 219.112 of this Part,

Appendix B of this Part) for a PTE during any testing of

their control device.

161

E) Sources utilizing a TTE must demonstrate that their TTE

meets the requirements given in Method 204 Procedure T

(in Appendix M or 40 CFR Part 51, incorporated by

reference in Section 219.112 of this Part, Appendix B of

this Part) for a TTE during any testing of their control

device. The source must also provide documentation that

the quality assurance criteria for a TTE have been achieved.

F) Any source utilizing the DQO or LCL protocol must

submit the following information to the Agency with each

test report:

i) A copy of all test methods, Quality

Assurance/Quality Control procedures, and

calibration procedures to be used from those

described in Appendix M of 40 CFR Part 51,

incorporated by reference in Section 219.112 of this

Part;

ii) A table with information on each sample taken,

including the sample identification and the VOM

content of the sample;

iii) The quantity of material used for each test run;

iv) The quantity of captured VOM for each test run;

v) The capture efficiency calculations and results for

each test run;

vi) The DQO and/or LCL calculations and results; and

vii) The Quality Assurance/Quality Control results,

including how often the instruments were

calibrated, the calibration results, and the calibration

gases used.

d) Control Device Efficiency Testing and Monitoring

1) The control device efficiency shall be determined by simultaneously

measuring the inlet and outlet gas phase VOM concentrations and gas

volumetric flow rates in accordance with the gas phase test methods

specified in subsection (f) of this Section.

2) An owner or operator:

162

A) That uses an afterburner or carbon adsorber to comply with any

Section of Part 219 shall use Agency and USEPA approved

continuous monitoring equipment which is installed, calibrated,

maintained, and operated according to vendor specifications at all

times the afterburner or carbon adsorber control device is in use

except as provided in subsection (d)(3) of this Section. The

continuous monitoring equipment must monitor the following

parameters:

i) For each afterburner which does not have a catalyst bed,

the combustion chamber temperature of each afterburner.

ii) For each afterburner which has a catalyst bed, commonly

known as a catalytic afterburner, the temperature rise

across each catalytic afterburner bed or VOM concentration

of exhaust.

iii) For each carbon adsorber, the VOM concentration of each

carbon adsorption bed exhaust or the exhaust of the bed

next in sequence to be desorbed.

B) Must install, calibrate, operate and maintain, in accordance with

manufacturer’s specifications, a continuous recorder on the

temperature monitoring device, such as a strip chart, recorder or

computer, having an accuracy of ± 1 percent of the temperature

measured, expressed in degrees Celsius or ± 0.5

C, whichever is

greater.

C)B) Of an automobile or light-duty truck primer surfacer operation or

topcoat operation subject to subsection (d)(2)(A) above, shall keep

a separate record of the following data for the control devices,

unless alternative provisions are set forth in a permit pursuant to

Title V of the Clean Air Act:

i) For thermal afterburners for which combustion chamber

temperature is monitored, all 3-hour periods of operation in

which the average combustion temperature was more than

28° C (50° F) below the average combustion temperature

measured during the most recent performance test that

demonstrated that the operation was in compliance.

ii) For catalytic afterburners for which temperature rise is

monitored, all 3-hour periods of operation in which the

average gas temperature before the catalyst bed is more

than 28° C (50° F) below the average gas temperature

163

immediately before the catalyst bed measured during the

most recent performance test that demonstrated that the

operation was in compliance.

iii) For catalytic afterburners and carbon adsorbers for which

VOM concentration is monitored, all 3-hour periods of

operation during which the average VOM concentration or

the reading of organics in the exhaust gases is more than 20

percent greater than the average exhaust gas concentration

or reading measured by the organic monitoring device

during the most recent determination of the recovery

efficiency of a carbon adsorber or performance test for a

catalytic afterburner, which determination or test that

demonstrated that the operation was in compliance.

3) An owner or operator that uses a carbon adsorber to comply with Section

219.401 of this Part may operate the adsorber during periods of

monitoring equipment malfunction, provided that:

A) The owner or operator notifies in writing the Agency and USEPA,

within 10 days after the conclusion of any 72 hour period during

which the adsorber is operated and the associated monitoring

equipment is not operational, of such monitoring equipment failure

and provides the duration of the malfunction, a description of the

repairs made to the equipment, and the total to date of all hours in

the calendar year during which the adsorber was operated and the

associated monitoring equipment was not operational;

B) During such period of malfunction the adsorber is operated using

timed sequences as the basis for periodic regeneration of the

adsorber;

C) The period of such adsorber operation does not exceed 360 hours

in any calendar year without the approval of the Agency and

USEPA; and

D) The total of all hours in the calendar year during which the

adsorber was operated and the associated monitoring equipment

was not operational shall be reported, in writing, to the Agency and

USEPA by January 31st of the following calendar year.

e) Overall Efficiency

1) The overall efficiency of the emission control system shall be determined

as the product of the capture system efficiency and the control device

efficiency or by the liquid/liquid test protocol as specified in 40 CFR

164

60.433, incorporated by reference in Section 219.112 of this Part, (and

revised by subsection (c)(1)(B) of this Section) for each solvent recovery

system. In those cases in which the overall efficiency is being determined

for an entire line, the capture efficiency used to calculate the product of

the capture and control efficiency is the total capture efficiency over the

entire line.

2) For coating lines which are both chosen by the owner or operator to

comply with Section 219.207(a), (d), (e), (f), or (g) of this Part by the

alternative in Section 219.207(b)(2) of this Part and meet the criteria

allowing them to comply with Section 219.207 instead of Section 219.204

of this Part, the overall efficiency of the capture system and control

device, as determined by the test methods and procedures specified in

subsections (c), (d) and (e)(1) of this Section, shall be no less than the

equivalent overall efficiency which shall be calculated by the following

equation:

E = ([VOMa - VOMl]/VOMa) x 100

where:

E = Equivalent overall efficiency of the capture system

and control device as a percentage;

VOMa = Actual VOM content of a coating, or the daily-

weighted average VOM content of two or more

coatings (if more than one coating is used), as

applied to the subject coating line as determined by

the applicable test methods and procedures

specified in subsection (a)(4)(i) of this Part in units

of kg VOM/1 (1b VOM/gal) of coating solids as

applied;

VOMl = The VOM emission limit specified in Sections

219.204 or 219.205 of this Part in units of kg

VOM/1 (1b VOM/gal) of coating solids as applied.

f) Volatile Organic Material Gas Phase Source Test Methods

The methods in 40 CFR Part 60, Appendix A, incorporated by reference in

Section 219.112 of this Part delineated below shall be used to determine control

device efficiencies.

1) 40 CFR Part 60, Appendix A, Method 18, 25 or 25A, incorporated by

reference in Section 219.112 of this Part as appropriate to the conditions at

the site, shall be used to determine VOM concentration. Method selection

165

shall be based on consideration of the diversity of organic species present

and their total concentration and on consideration of the potential presence

of interfering gases. Except as indicated in subsections (f)(1)(A) and (B)

below, the test shall consist of three separate runs, each lasting a minimum

of 60 min, unless the Agency and the USEPA determine that process

variables dictate shorter sampling times.

A) When the method is to be used to determine the efficiency of a

carbon adsorption system with a common exhaust stack for all the

individual adsorber vessels, the test shall consist of three separate

runs, each coinciding with one or more complete sequences

through the adsorption cycles of all the individual adsorber vessels.

B) When the method is to be used to determine the efficiency of a

carbon adsorption system with individual exhaust stacks for each

adsorber vessel, each adsorber vessel shall be tested individually.

The test for each adsorber vessel shall consist of three separate

runs. Each run shall coincide with one or more complete

adsorption cycles.

2) 40 CFR Part 60, Appendix A, Method 1 or 1A, incorporated by reference

in Section 219.112 of this Part, shall be used for sample and velocity

traverses.

3) 40 CFR Part 60, Appendix A, Method 2, 2A, 2C or 2D, incorporated by

reference in Section 219.112 of this Part, shall be used for velocity and

volumetric flow rates.

4) 40 CFR Part 60, Appendix A, Method 3, incorporated by reference in

Section 219.112 of this Part, shall be used for gas analysis.

5) 40 CFR Part 60, Appendix A, Method 4, incorporated by reference in

Section 219.112 of this Part, shall be used for stack gas moisture.

6) 40 CFR Part 60, Appendix A, Methods 2, 2A, 2C, 2D, 3 and 4,

incorporated by reference in Section 219.112 of this Part, shall be

performed, as applicable, at least twice during each test run.

7) Use of an adaptation to any of the test methods specified in subsections

(f)(1), (2), (3), (4), (5) and (6) of this Section may not be used unless

approved by the Agency and the USEPA on a case by case basis. An

owner or operator must submit sufficient documentation for the Agency

and the USEPA to find that the test methods specified in subsections

(f)(1), (2), (3), (4), (5) and (6) of this Section will yield inaccurate results

and that the proposed adaptation is appropriate.

166

g) Leak Detection Methods for Volatile Organic Material Owners or operators

required by this Part to carry out a leak detection monitoring program shall

comply with the following requirements:

B) The detection instrument shall meet the performance criteria of

Method 21.

D) Calibration gases shall be:

E) The instrument probe shall be traversed around all potential leak

interfaces as close to the interface as possible as described in

Method 21.

2) When equipment is tested for compliance with no detectable emissions as

required, the test shall comply with the following requirements:

B) The background level shall be determined as set forth in Method

21.

B) "Portable Instrument User's Manual for Monitoring VOM

Sources", EPA-340/1-86-015, incorporated by reference in Section

219.112 of this Part.

1) Leak Detection Monitoring

A) Monitoring shall comply with 40 CFR 60, Appendix A, Method

21, incorporated by reference in Section 219.112 of this Part.

C) The instrument shall be calibrated before use on each day of its use

by the methods specified in Method 21.

i) Zero air (less than 10 ppm of hydrocarbon in air); and

ii) A mixture of methane or n-hexane and air at a

concentration of approximately, but no less than, 10,000

ppm methane or n-hexane.

A) The requirements of subsections (g)(1)(A) through (g)(1)(E) of this

Section above shall apply.

3) Leak detection tests shall be performed consistent with:

A) "APTI Course SI 417 controlling Volatile Organic Compound

Emissions from Leaking Process Equipment", EPA-450/2-82-015,

incorporated by reference in Section 219.112 of this Part.

167

C) "Protocols for Generating Unit-Specific Emission Estimates for

Equipment Leaks of VOM and VHAP", EPA-450/3-88-010,

incorporated by reference in Section 219.112 of this Part.

D) "Petroleum Refinery Enforcement Manual", EPA-340/1-80-008,

incorporated by reference in Section 219.112 of this Part.

B) "Control of Hydrocarbons from Tank Truck Gasoline Loading

Terminals: Appendix A", EPA-450/2-77-026, incorporated by

reference in Section 219.112 of this Part.

h) Bulk Gasoline Delivery System Test Protocol

1) The method for determining the emissions of gasoline from a vapor

recovery system are delineated in 40 CFR 60, Subpart XX, Section

60.503, incorporated by reference in Section 219.112 of this Part.

2) Other tests shall be performed consistent with:

A) "Inspection Manual for Control of Volatile Organic Emissions

from Gasoline Marketing Operations: Appendix D", EPA-340/1-

80-012, incorporated by reference in Section 219.112 of this Part.

i) Notwithstanding other requirements of this Part, upon request of the Agency

where it is necessary to demonstrate compliance, an owner or operator of an

emission unit which is subject to this Part shall, at his own expense, conduct tests

in accordance with the applicable test methods and procedures specific in this

Part. Nothing in this Section shall limit the authority of the USEPA pursuant to

the Clean Air Act, as amended, to require testing.

j) Stage II Gasoline Vapor Recovery Test Methods

The methods for determining the acceptable performance of Stage II Gasoline

Vapor Recovery System are delineated in "Technical Guidance-Stage II Vapor

Recovery Systems for Control of Vehicle Refueling Emissions at Gasoline

Dispensing Facilities," found at EPA 450/3-91-022b and incorporated by

reference in Section 219.112 of this Part. Specifically, the test methods are as

follows:

1) Dynamic Backpressure Test is a test procedure used to determine the

pressure drop (flow resistance) through balance vapor collection and

control systems (including nozzles, vapor hoses, swivels, dispenser piping

and underground piping) at prescribed flow rates.

2) Pressure Decay/Leak Test is a test procedure used to quantify the vapor

tightness of a vapor collection and control system installed at gasoline

dispensing facilities.

168

3) Liquid Blockage Test is a test procedure used to detect low points in any

vapor collection and control system where condensate may accumulate.

(Source: Amended at _______________, effective ________________)

Section 219.112 Incorporations by Reference

The following materials are incorporated by reference and do not contain any subsequent

additions or amendments:

a) American Society for Testing and Materials, 1916 Race Street, Philadelphia, PA

4) ASTM D369-69 (1971)

6) ASTM D2880-71

7) ASTM D975-68

8) ASTM D3925-81 (1985)

13) ASTM D4017-81 (1987)

20) ASTM E168-87 (1977)

21) ASTM E169-87

23) ASTM D2504-83

24) ASTM D2382-83

25) ASTM D323-82 (approved 1982)

b) Standard Industrial Classification Manual, published by Executive Office of the

President, Office of Management and Budget, Washington, D.C., 1987.

c) American Petroleum Institute Bulletin 2517, "Evaporation Loss From Floating

Roof Tanks", Second ed., February, 1980.

169

d) 40 CFR Part 60 (July 1, 1991).

e) 40 CFR Part 61 (July 1, 1991).

f) 40 CFR Part 50 (July 1, 1991).

g) 40 CFR Part 51 (July 1, 1991) and 40 CFR Part 51 Appendix M, Methods 204-

204F (July 1, 1999).

h) 40 CFR Part 52 (July 1, 1991).

i) 40 CFR Part 80 (July 1, 1991) and 40 CFR Part 80 Appendixes D, E, and F (July

1, 1993).

j) "A Guide for Surface Coating Calculation", United States Environmental

Protection Agency, Washington, D.C., EPA-340/1-86-016.

k) "Procedures for Certifying Quantity of Volatile Organic Compounds Emitted by

Paint, Ink and Other Coating", (revised June 1986), United States Environmental

Protection Agency, Washington D.C., EPA-450/3-84-019.

l) "A Guide for Graphic Arts Calculations", August 1988, United States

Environmental Protection Agency, Washington D.C., EPA-340/1-88-003.

m) "Protocol for Determining the Daily Volatile Organic Compound Emission Rate

of Automobile and Light-Duty Truck Topcoat Operations", December 1988,

United States Environmental Protection Agency, Washington D.C., EPA-450/3-

88-018.

n) "Control of Volatile Organic Emissions from Manufacturing of Synthesized

Pharmaceutical Products", United States Environmental Protection Agency,

Washington, D.C., EPA-450/2-78-029.

o) "Control of Volatile Organic Compound Leaks from Gasoline Tank Trucks and

Vapor Collection Systems", Appendix B, United States Environmental Protection

Agency, Washington, D.C., EPA-450/2-78-051.

p) "Control of Volatile Organic Compound emissions from Large Petroleum Dry

Cleaners", United States Environmental Protection Agency, Washington, D.C.,

EPA-450/3-82-009.

q) "APTI Course SI417 Controlling Volatile Organic Compound Emissions from

Leaking Process Equipment", United States Environmental Protection Agency,

Washington, D.C., EPA-450/2-82-015.

170

r) "Portable Instrument User's Manual for Monitoring VOM Sources", United States

Environmental Protection Agency, Washington, D.C., EPA-340/1-86-015.

s) "Protocols for Generating Unit-Specific Emission Estimates for Equipment Leaks

of VOM and VHAP", United States Environmental Protection Agency,

Washington, D.C., EPA-450/3-88-010.

t) "Petroleum Refinery Enforcement

Manual", United States Environmental

Protection Agency, Washington, D.C., EPA-340/1-80-008.

u) "Inspection Manual for Control of Volatile Organic Emissions from Gasoline

Marketing Operations: Appendix D", United States Environmental Protection

Agency, Washington, D.C., EPA-340/1-80-012.

v) "Control of Hydrocarbons from Tank Truck Gasoline Loading Terminals:

Appendix A", United States Environmental Protection Agency, Washington,

D.C., EPA-450/2-77-026.

w) "Technical Guidance-Stage II Vapor Recovery Systems for Control of Vehicle

Refueling Emissions at Gasoline Dispensing Facilities", United States

Environmental Protection Agency, Washington, D.C., EPA-450/3-91-022b.

x) California Air Resources Board, Compliance Division. Compliance Assistance

Program: Gasoline Marketing and Distribution: Gasoline Facilities Phase I & II

(October 1988, rev. November 1993) (CARB Manual).

y) “Guidelines for Determining Capture Efficiency,” Office of Air Quality Planning

and Standards, United States Environmental Protection Agency, Research

Triangle Park, NC. January, 1995.

z) Memorandum “Revised Capture Efficiency Guidance for Control of Volatile

Organic Compound Emissions,” John S. Seitz, Director, Office of Air Quality

Planning and Standards, United States Environmental Protection Agency,

February, 1995.

(Source: Amended at _______________, effective ________________)

Section 219.204 Emission Limitations

Except as provided in Sections 219.205, 219.207, 219.208, 219.212, 219.215 and 219.216 of this

Subpart, no owner or operator of a coating line shall apply at any time any coating in which the

VOM content exceeds the following emission limitations for the specified coating. Except as

provided in Section 219.204(l), compliance with the emission limitations marked with an asterisk

in this Section is required on and after March 15, 1996, and compliance with emission

limitations not marked with an asterisk is required until March 15, 1996. The following

emission limitations are expressed in units of VOM per volume of coating (minus water and any

171

compounds which are specifically exempted from the definition of VOM) as applied at each

coating applicator, except where noted. Compounds which are specifically exempted from the

definition of VOM should be treated as water for the purpose of calculating the "less water" part

of the coating composition. Compliance with this Subpart must be demonstrated through the

applicable coating analysis test methods and procedures specified in Section 219.105(a) of this

Part and the recordkeeping and reporting requirements specified in Section 219.211(c) of this

Subpart except where noted. (Note: The equation presented in Section 219.206 of this Part shall

be used to calculate emission limitations for determining compliance by add-on controls, credits

for transfer efficiency, emissions trades and cross-line averaging.) The emission limitations are

as follows:

a) Automobile or Light-Duty Truck Coating

(Note: The primer surface coat limitation is in units of kg (lbs) of VOM

per l (gal) of coating solids deposited. Compliance with the limitation

shall be based on the daily-weighted average from an entire primer surface

operation. Compliance shall be demonstrated in accordance with the

topcoat protocol referenced in Section 219.105(b) and the recordkeeping

and reporting requirements specified in Section 219.211(f). Testing to

demonstrate compliance shall be performed in accordance with the topcoat

protocol and a detailed testing proposal approved by the Agency and

USEPA specifying the method of demonstrating compliance with the

protocol. Section 219.205 does not apply to the primer surface limitation.)

(Note: The topcoat limitation is in units of kg (lbs) of VOM per l (gal) of

coating solids deposited. Compliance with the limitation shall be based on

the daily-weighted average from an entire topcoat operation. Compliance

shall be demonstrated in accordance with the topcoat protocol referenced

in Section 219.105(b) of this Part and the recordkeeping and reporting

requirements specified in Section 219.211(f). Testing to demonstrate

compliance shall be performed in accordance with the topcoat protocol

and a detailed testing proposal approved by the Agency and USEPA

specifying the method of demonstrating compliance with the protocol.

Section 219.205 of this Part does not apply to the topcoat limitation.)

Interior body spray coat

Sheet basecoat and overvarnish

Exterior basecoat and overvarnish

End sealing compound coat

(Note: The paper coating limitation shall not apply to any owner or operator of

any paper coating line on which flexographic or rotogravure printing is performed

if the paper coating line complies with the emissions limitations in Subpart H:

Printing and Publishing, Section 219.401 of this Part. In addition, screen printing

on paper is not regulated as paper coating, but is regulated under Subpart TT of

Metal Furniture Coating

Large Appliance Coating

(Note: The limitation shall not apply to the use of quick-drying lacquers for

repair of scratches and nicks that occur during assembly, provided that the volume

of coating does not exceed 0.95 l (1 quart) in any one rolling eight-hour period.)

Miscellaneous Metal Parts and Products

Extreme performance coating

Steel pail and drum interior

6) For purposes of subsection 219.204(j)(5) of this Section, "metallic

coating" means a coating which contains more than 1/4 lb/gal of metal

particles, as applied.

Heavy Off-Highway Vehicle Products

Coating

kg/l lb/gal

Extreme performance prime coat

Extreme performance topcoat (air

Final repair coat (air dried)

4) All other coatings are subject to the emission limitations for miscellaneous

metal parts and products coatings in subsection (j) above.

l) Wood Furniture Coating

Limitations before March 15,

F) Semi-transparent stain

(Note: Prior to March 15, 1998, an owner or operator of a wood

furniture coating operation subject to this Section shall apply all

coatings, with the exception of no more than 37.8 l (10 gal) of

coating per day used for touch-up and repair operations, using one

or more of the following application systems: airless spray

application system, air-assisted airless spray application system,

electrostatic spray application system, electrostatic bell or disc

spray application system, heated airless spray application system,

roller coating, brush or wipe coating application system, dip

coating application system or high volume low pressure (HVLP)

application system.)

2) On and after March 15, 1998, wood furniture sealers and topcoats must

comply with one of the limitations specified in subsections (l)(2)(A)

Sealers and topcoats with

the following limits:

iii) Acid-cured alkyd 2.3

C) Meet the provisions of Section 219.215 of this Subpart for use of

an averaging approach;

D) Achieve a reduction in emissions equivalent to the requirements of

Section 219.204(l)(2)(A) or (B) of this Subpart, as calculated using

Section 219.216 of this Subpart; or

E) Use a combination of the methods specified in Section

219.204(l)(2)(A) through (D) of this Subpart.

3) Other wood furniture coating limitations on and after March 15, 1998:

B) Non-topcoat pigmented

D) Semi-transparent stain

4) Other wood furniture coating requirements on and after March 15, 1998:

A) No source subject to the limitations of subsection (l)(2) or (3) of

this Section and utilizing one or more wood furniture coating spray

booths shall use strippable spray booth coatings containing more

than 0.8 kg VOM/kg solids (0.8 lb VOM/lb solids), as applied.

B) Any source subject to the limitations of subsection (l)(2) or (3) of

this Section shall comply with the requirements of Section 219.217

of this Subpart.

C) Any source subject to the limitations of subsection (l)(2)(A) or (B)

of this Section and utilizing one or more continuous coaters, shall

for each continuous coater, use an initial coating which complies

with the limitations of subsection (l)(2)(A) or (B) of this Section.

The viscosity of the coating in each reservoir shall always be

177

greater than or equal to the viscosity of the initial coating in the

reservoir. The owner or operator shall:

i) Monitor the viscosity of the coating in the reservoir with a

viscosity meter or by testing the viscosity of the initial

coating and retesting the coating in the reservoir each time

solvent is added;

ii) Collect and record the reservoir viscosity and the amount

and weight of VOM per weight of solids of coating and

solvent each time coating or solvent is added; and

iii) Maintain these records at the source for a period of three

years.

Plastic Parts Coating:

Automotive/Transportation

Exteriors (flexible and non-

ii) Primer non-flexible

iv) Color coat (others)

0.61*

(5.1)*

3) Specialty

A) Vacuum metallizing

basecoats, texture

basecoats

0.66* (5.5)*

Black coatings, reflective

argent coatings, air bag

cover coatings, and soft

coatings

0.71* (5.9)*

Gloss reducers, vacuum

metallizing topcoats, and

texture topcoats

0.77* (6.4)*

Stencil coatings, adhesion

primers, ink pad coatings,

electrostatic prep coatings,

and resist coatings

0.82* (6.8)*

Head lamp lens coatings

0.89*

(7.4)*

Plastic Parts Coating: Business Machine

Color coat (non-texture coat)

0.28*

(2.3)*

Color coat (texture coat)

0.28*

(2.3)*

4) Electromagnetic interference/radio

frequency interference (EMI/RFI)

shielding coatings

0.48* (4.0)*

5) Specialty Coatings

C) Plating sensitizer

0.85*

(7.1)*

(Source: Amended at _______________, effective ________________)

SUBPART H: PRINTING AND PUBLISHING

Section 219.405 Lithographic Printing: Applicability

a) Until March 15, 1996, the limitations of Section 219.406 of this Subpart apply to

all heatset web offset lithographic printing lines (including solvents used for

cleanup operations associated with the heatset web offset lithographic printing

line(s)) at a source subject to the requirements of this Subpart. All sources with

heatset web offset lithographic printing lines are sources subject to the

requirements of this Subpart unless:

1) Total maximum theoretical emissions of VOM from all heatset web offset

lithographic printing lines (including solvents used for cleanup operations

associated with the heatset web offset lithographic printing line(s)) at the

source never exceed 90.7 Mg (100 tons) per calendar year in the absence

of air pollution control equipment; or

2) A federally enforceable permit or SIP revision for all heatset web offset

lithographic printing line(s) at a source requires the owner or operator to

limit production or capacity of these printing line(s) to reduce total VOM

emissions from all heatset web offset lithographic printing line(s) to 90.7

Mg (100 tons) per calendar year or less in the absence of air pollution

control equipment.

b) Any owner or operator of any heatset web offset lithographic printing line that is

exempt from the limitations in Section 219.406 of this Subpart because of the

criteria in subsection (a) of this Section shall be subject to the recordkeeping and

reporting requirements in Section 219.406(b)(1) of this Subpart.

c) On and after March 15, 1996, every owner or operator of lithographic printing

line(s) is subject to the recordkeeping and reporting requirements in Section

219.411 of this Subpart.

d) On and after March 15, 1996, Sections 219.407 through 219.410 219.411 of this

Subpart shall apply to:

1) All owners or operators of heatset web offset lithographic printing line(s)

unless:

180

A) Total maximum theoretical emissions of VOM from all heatset

web offset lithographic printing lines (including solvents used for

cleanup operations associated with heatset web offset lithographic

printing lines) at the source never exceed 90.7 Mg (100 tons) per

calendar year before the application of capture systems and control

devices. To determine a source's total maximum theoretical

emissions of VOM for the purposes of this subsection, the owner

or operator shall use the calculations set forth in Section

219.406(b)(1)(A)(ii) of this Subpart; or

B) Federally enforceable permit conditions or SIP revision for all

heatset web offset lithographic printing line(s) at the source

requires the owner or operator to limit production or capacity of

these printing line(s) to total VOM emissions of 90.7 Mg/yr (100

TPY) or less, before the application of capture systems and control

devices;

e) If a lithographic printing line at a source is or becomes subject to one or more of

the limitations in Sections 219.406 or 219.407 of this Subpart, the lithographic

printing line(s) at the source are always subject to the applicable provisions of this

Subpart.

2) All owners or operators of heatset web offset, non-heatset web offset, or

sheet-fed offset lithographic printing line(s), unless the combined

emissions of VOM from all lithographic printing line(s) at the source

(including solvents used for cleanup operations associated with the

lithographic printing line(s)) never exceed 45.5 kg/day (100 lbs/day), as

determined in accordance with Section 219.411(a)(1)(B), before the

application of capture systems and control devices.

(Source: Amended at _______________, effective ________________)

Section 219.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to

March 15, 1996

A) Emission Standards and Limitations. No owner or operator of a heatset web

offset printing line at a source that meets or exceeds the applicability levels in

Section 219.405(a) of this Subpart may cause or allow the operation of such

heatset web offset printing line(s) unless the owner or operator meets the

requirements in subsections (a)(1) or (a)(2) of this Section and the requirements in

subsections (a)(3) and (a)(4) of this Section. The owner or operator shall

demonstrate compliance with this Section by using the applicable test methods

and procedures specified in Section 219.105(a), (d), and (f) of this Part and by

complying with the recordkeeping and reporting requirements specified in

subsection (b) of this Section.

181

1) An afterburner system is installed and operated that reduces 90 percent of

the VOM emissions (excluding methane and ethane) from the dryer

exhaust; or

2) The fountain solution contains no more than 8 percent, by weight, of

VOM and a condensation recovery system is installed and operated that

removes at least 75 percent of the non-isopropyl alcohol organic materials

from the dryer exhaust; and

3) The control device is equipped with the applicable monitoring equipment

specified in Section 219.105(d)(2) of this Part and the monitoring

equipment is installed, calibrated, operated and maintained according to

manufacturer's specifications at all times when the control device is in use;

and

4) The control device is operated at all times when the printing line is in

operation.

b) Recordkeeping and Reporting. The VOM content of each fountain solution and

ink and the efficiency of each control device shall be determined by the applicable

test methods and procedures specified in Section 219.105 of this Part to establish

the records required under this subsection.

1) Any owner or operator of a lithographic printing line which is exempted

from the limitations of subsection (a) of this Section because of the criteria

in 219.405(a) of this Subpart shall comply with the following:

A) By a date consistent with Section 219.106 of this Part, the owner or

operator of a heatset web offset lithographic printing line to which

subsection (b)(1) of this Section is applicable shall certify to the

Agency that the heatset web offset lithographic printing line is

exempt under the provisions of Section 219.405(a) of this Subpart.

Such certification shall include:

i) A declaration that the heatset web offset lithographic

printing line is exempt from the limitations of subsection

(a) of this Section because of the criteria in Section

219.405(a) of this Subpart; and

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 of

air pollution control equipment. Total maximum

theoretical emissions of VOM for a heatset web offset

lithographic printing source is the sum of maximum

182

theoretical emissions of VOM from each heatset web offset

lithographic printing line at the source. The following

equation shall be used to calculate total maximum

theoretical emissions of VOM per calendar year in the

absence of air pollution control equipment for each heatset

web offset lithographic printing line at the source:

Ep = (R x A x B) + (C x D) + 1095 (F x G x H)

100

where:

Ep = Total maximum theoretical emissions of VOM from

one heatset web offset printing line in units of kg/yr

(lb/yr);

A = Weight of VOM per volume of solids of ink with

the highest VOM content as applied each year on

the printing line in units of kg/l (lb/gal) of solids;

B = Total volume of solids 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 of each 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 of VOM per volume of fountain solution

with the highest VOM content as applied each year

on the printing line in units of kg/l (lb/gal) The

weight percent VOM of the fountain solution with

the highest VOM content;

D = The total volume of fountain solution that can

potentially be used each year on the printing line in

units of 1/yr (gal/yr). The instrument and/or

method by which the owner or operator accurately

measured or calculated the volume of each 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 of VOM per volume of material for the

cleanup material or solvent with the highest VOM

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content as used each year on the printing line in

units of kg/l (lb/gal) of such material;

G = The greatest volume of cleanup material or solvent

used in any 8-hour period; and

H = The highest fraction of cleanup 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

retained in the substrate being used. For paper, R =

0.8. For foil, plastic, or other impervious substrates,

R = 1.0.

B) On and after a date consistent with Section 219.106 of this Part, the

owner or operator of a heatset web offset lithographic printing line

to which subsection (b)(1) of this Section is applicable shall collect

and record all of the following information each year for each

printing line and maintain the information at the source for a

period of three years:

i) The name and identification of each fountain solution and

ink as applied on each printing line; and

ii) The VOM content and the volume of each fountain solution

and ink as applied each year on each printing line.

C) On and after a date consistent with Section 219.106 of this Part, the

owner or operator of a source exempted from the limitations of

subsection (a) of this Section because of the criteria in Section

219.405(a) of this Subpart shall notify the Agency of any record

showing that total maximum theoretical emissions of VOM from

all heatset web offset lithographic printing lines exceed 90.7 Mg

(100 tons) in any calendar year in the absence of air pollution

control equipment by sending a copy of such record to the Agency

within 30 days after the exceedence occurs.

2) Any owner or operator of a printing line subject to the limitations of

subsection (a) of this Section and complying by means of subsection (a)(1)

of this Section shall comply with the following:

A) By a date consistent with Section 219.106 of this Part, or upon

initial start-up of a new printing line, or upon changing the method

of compliance for an existing printing line from subsection (a)(2)

to (a)(1) of this Section, perform all tests and submit to the Agency

184

the results of all tests and calculations necessary to demonstrate

that the subject printing line will be in compliance with subsection

(a)(1) of this Section on and after a date consistent with Section

219.106 of this Part, or on and after the initial start-up date;

B) On and after a date consistent with Section 219.106 of this Part, or

on and after the initial start-up date, collect and record the

following information each day for each printing line and maintain

the information at the source for a period of three years:

i) Control device monitoring data;

ii) A log of operating time for the control device, monitoring

equipment and the associated printing line; and

iii) A maintenance log for the control device and monitoring

equipment detailing all routine and non-routine

maintenance performed including dates and duration of any

outages;

C) On and after a date consistent with Section 219.106 of this Part,

notify the Agency in the following instances:

i) Any violation of subsection (a)(1) of this Section shall be

reported to the Agency, in writing, within 30 days

following the occurrence of the violation;

ii) Any record showing a violation of subsection (a)(1) of this

Section shall be reported by sending a copy of such record

to the Agency within 30 days following the occurrence of

the violation; and

iii) At least 30 calendar days before changing the method of

compliance with subsection (a) of this Section from

subsection (a)(1) to (a)(2) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(3)(A) of this Section. Upon changing the method of

compliance with subsection (a) of this Section from

subsection (a)(1) to (a)(2) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(3) of this Section.

3) Any owner or operator of a printing line subject to the limitations of

subsection (a) of this Section and complying by means of subsection (a)(2)

of this Section shall:

185

A) By a date consistent with Section 219.106 of this Part, or upon

initial start-up of a new printing line, or upon changing the method

of compliance for an existing printing line from subsection (a)(1)

to (a)(2) of this Section, perform all tests and submit to the Agency

and the USEPA the results of all tests and calculations necessary to

demonstrate that the subject printing line will be in compliance

with subsection (a)(2) of this Section on and after a date consistent

with Section 219.106 of this Part, or on and after the initial start-up

date;

B) On and after a date consistent with Section 219.106 of this Part, or

on and after the initial start-up date, collect and record the

following information each day for each printing line and maintain

the information at the source for a period of three years:

i) The VOM content of the fountain solution used each day

on each printing line;

ii) A log of operating time for the control device and the

associated printing line; and

iii) A maintenance log for the control device detailing all

routine and non-routine maintenance performed including

dates and duration of any outages;

C) On and after a date consistent with Section 219.106 of this Part,

notify the Agency in the following instances:

i) Any violation of subsection (a)(2) shall be reported to the

Agency, in writing, within 30 days following the

occurrence of the violation;

ii) Any record showing a violation of subsection (a)(2) of this

Section shall be reported by sending a copy of such record

to the Agency within 30 days following the occurrence of

the violation; and

iii) At least 30 calendar days before changing the method of

compliance with subsection (a) of this Section from

subsection (a)(2) to (a)(1) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(2)(A) of this Section. Upon changing the method of

compliance with subsection (a) of this Section from

subsection (a)(2) to (a)(1) of this Section, the owner or

operator shall comply with all requirements of subsection

(b)(2) of this Section.

186

c) Compliance Schedule. Every owner or operator of a heatset web offset

lithographic printing line shall comply with the applicable requirements of

subsections (a) and (b) of this Section in accordance with the applicable

compliance schedule specified in subsections (c)(1), (c)(2), or (c)(3) of this

Section:

1) No owner or operator of a heatset web offset lithographic printing line

which is exempt from the limitations of subsection (a) of this Section

because of the criteria in Section 219.405(a) of this Subpart shall operate

said printing line on or after a date consistent with Section 219.106 of this

Part, unless the owner or operator has complied with, and continues to

comply with, Sections 219.405(a) and 219.406(b)(1) of this Subpart.

2) No owner or operator of a heatset web offset lithographic printing line

complying by means of subsection (a)(1) of this Section shall operate said

printing line on or after a date consistent with Section 219.106 of this Part,

unless the owner or operator has complied with, and continues to comply

with, subsections (a)(1), (a)(3), (a)(4) and (b)(2) of this Section.

3) No owner or operator of a heatset web offset lithographic printing line

complying by means of subsection (a)(2) of this Section shall operate said

printing line on or after a date consistent with Section 219.106 of this Part,

unless the owner or operator has complied with, and continues to comply

with subsections (a)(2), (a)(3), (a)(4) and (b)(3) of this Section.

(Source: Amended at _______________, effective ________________)

Section 219.407 Emission Limitations and Control Requirements for Lithographic Printing

Lines On and After March 15, 1996

a) On and after March 15, 1996, no owner or operator of lithographic printing line(s)

subject to the requirements of this Subpart shall:

1) Cause or allow the operation of any heatset web offset lithographic

printing line unless:

A) The total VOM content in the as-applied fountain solution meets

one of the following conditions:

i) 1.6 percent or less, by volume;

ii) 3 percent or less, by volume, and the temperature of the

fountain solution is maintained below 15.6

C (60

F),

measured at the reservoir or the fountain tray; or

187

iii) 5 percent or less, by volume, and the as-applied fountain

solution contains no alcohol;

B) The air pressure in the dryer is maintained lower than the air

pressure of the press room, such that air flow through all openings

in the dryer, other than the exhaust, is into the dryer at all times

when the printing line is operating;

C) An afterburner is installed and operated so that VOM emissions

(excluding methane and ethane) from the press dryer exhaust(s) are

reduced by 90 percent, by weight, or to a maximum afterburner

exhaust outlet concentration of 20 ppmv (as carbon);

D) The afterburner is equipped with the applicable monitoring

equipment specified in Section 219.105(d)(2) of this Part and the

monitoring equipment is installed, calibrated, operated, and

maintained according to manufacturer's specifications at all times

when the afterburner is in use; and

E) The afterburner is operated at all times when the printing line is in

operation, except the afterburner may be shut down between

November 1 and April 1 as provided in Section 219.107 of this

Part;

2) Cause or allow the operation of any non-heatset web offset lithographic

printing line unless the VOM content of the as-applied fountain solution is

5 percent or less, by volume, and the as-applied fountain solution contains

no alcohol;

3) Cause or allow the operation of any sheet-fed offset lithographic printing

line unless:

A) The VOM content of the as-applied fountain solution is 5 percent

or less, by volume; or

B) The VOM content of the as-applied fountain solution is 8.5 percent

or less, by volume, and the temperature of the fountain solution is

maintained below 15.6

C (60

F), measured at the reservoir or the

fountain tray;

4) Cause or allow the use of a cleaning solution on any lithographic printing

line unless:

A) The VOM content of the as-used cleaning solution is less than or

equal to 30 percent, by weight; or

188

B) The VOM composite partial vapor pressure of the as-used cleaning

solution is less than 10 mmHg at 20

C (68

F);

5) Cause or allow VOM containing cleaning materials, including used

cleaning towels, associated with any lithographic printing line to be kept,

stored or disposed of in any manner other than in closed containers.

b) An owner or operator of a heatset web offset lithographic printing line subject to

the requirements of Section 219.407(a)(1)(C) of this Subpart may use a control

device other than an afterburner, if:

1) The control device reduces VOM emissions from the press dryer

exhaust(s) by at least 90 percent, by weight, or to a maximum control

device exhaust outlet concentration of 20 ppmv (as carbon);

1) The owner or operator of any lithographic printing line(s) relying on the

temperature of the fountain solution to demonstrate compliance shall

install, maintain, and continuously operate a temperature monitor of the

fountain solution in the reservoir or fountain tray, as applicable.

2) The owner or operator submits a plan to the Agency detailing appropriate

monitoring devices, test methods, recordkeeping requirements, and

operating parameters for the control device; and

3) The use of the control device with testing, monitoring, and recordkeeping

in accordance with this plan is approved by the Agency and USEPA as

federally enforceable permit conditions.

(Source: Amended at _______________, effective ________________)

Section 219.410 Monitoring Requirements for Lithographic Printing

a) Fountain Solution Temperature.

2) The temperature monitor must be capable of reading with an accuracy of

C or 2

F 0.3

C or 0.5

F, and must be attached to an automatic,

continuous recording device such as a strip chart, recorder, or computer,

with at least the same accuracy, that is installed, calibrated and maintained

in accordance with the manufacturer's specifications. If the automatic,

continuous recording device malfunctions, the owner or operator shall

record the temperature of the fountain solution at least once every two

operating hours. The automatic, continuous recording device shall be

repaired or replaced as soon as practicable.

189

b) Fountain Solution VOM Content. The owner or operator of any lithographic

printing line(s) subject to Section 219.407(a)(1)(A) 218.407(a)(1)(A), (a)(2) or

(a)(3) of this Subpart shall:

1) For a fountain solution to which VOM is not added automatically:

A) Maintain records of the VOM content of the fountain solution in

accordance with Section 219.411(c)(2)(C) 218.411(c)(2)(C); or

B) Take a sample of the as-applied fountain solution from the fountain

tray or reservoir, as applicable, each time a fresh batch of fountain

solution is prepared or each time VOM is added to an existing

batch of fountain solution in the fountain tray or reservoir, and

shall determine compliance with the VOM content limitation of the

as-applied fountain solution by using one of the following options:

i) With a refractometer or hydrometer with a visual, analog,

or digital readout and with an accuracy of 0.5 percent. The

refractometer or hydrometer must be calibrated with a

standard solution for the type of VOM used in the fountain

solution, in accordance with manufacturer's specifications,

against measurements performed to determine compliance.

The refractometer or hydrometer must be corrected for

temperature at least once per 8-hour shift or once per batch

of fountain solution prepared or modified, whichever is

longer; or

ii) With a conductivity meter if it is demonstrated that a

refractometer and hydrometer cannot distinguish between

compliant and noncompliant fountain solution for the type

and amount of VOM in the fountain solution. A source

may use a conductivity meter if it demonstrates that both

hydrometers and refractometers fail to provide significantly

different measurements for standard solutions containing

95 percent, 100 percent and 105 percent of the applicable

VOM content limit. The conductivity meter reading for the

fountain solution must be referenced to the conductivity of

the incoming water. A standard solution shall be used to

calibrate the conductivity meter for the type of VOM used

in the fountain solution, in accordance with manufacturer's

specifications;

2) For fountain solutions to which VOM is added at the source with

automatic feed equipment, determine the VOM content of the as-applied

fountain solution based on the setting of the automatic feed equipment

which makes additions of VOM up to a pre-set level. Records must be

190

retained of the VOM content of the fountain solution in accordance with

Section 219.411(c)(2)(D) of this Subpart. The equipment used to make

automatic additions must be installed, calibrated, operated and maintained

in accordance with manufacturer's specifications.

c) Afterburners For Heatset Web Offset Lithographic Printing Line(s).

If an afterburner is used to demonstrate compliance, the owner or operator of a

heatset web offset lithographic printing line subject to Section 219.407(a)(1)(C)

of this Subpart shall:

1) Install, calibrate, maintain, and operate temperature monitoring device(s)

with an accuracy of 3

C or 5

F on the afterburner in accordance with

Section 219.105(d)(2) of this Part and in accordance with the

manufacturer's specifications. Monitoring shall be performed at all times

when the afterburner is operating; and

2) Install, calibrate, operate and maintain, in accordance with manufacturer's

specifications, a continuous recorder on the temperature monitoring

device(s), such as a strip chart, recorder or computer, with at least the

same accuracy as the temperature monitor.

d) Other Control Devices for Heatset Web Offset Lithographic Printing Line(s). If a

control device other than an afterburner is used to demonstrate compliance, the

owner or operator of a heatset web offset lithographic printing line subject to this

Subpart shall install, maintain, calibrate and operate such monitoring equipment

as set forth in the owner or operator's plan approved by the Agency and USEPA

pursuant to Section 219.407(b) of this Subpart.

e) Cleaning Solution.

1) The owner or operator of any lithographic printing line relying on the

VOM content of the cleaning solution to comply with Section

219.407(a)(4)(A) of this Subpart must:

A) For cleaning solutions that are prepared at the source with

equipment that automatically mixes cleaning solvent and water (or

other non-VOM):

i) Install, operate, maintain, and calibrate the automatic feed

equipment in accordance with manufacturer's specifications

to regulate the volume of each of the cleaning solvent and

water (or other non-VOM), as mixed; and

ii) Pre-set the automatic feed equipment so that the

consumption rates of the cleaning solvent and water (or

191

other non-VOM), as applied, comply with Section

219.407(a)(4)(A) of this Subpart;

B) For cleaning solutions that are not prepared at the source with

automatic feed equipment, keep records of the usage of cleaning

solvent and water (or other non-VOM) as set forth in Section

219.411(d)(2) of this Subpart.

2) The owner or operator of any lithographic printing line relying on the

vapor pressure of the cleaning solution to comply with Section

219.407(a)(4)(B) of this Subpart must keep records for such cleaning

solutions used on any such line(s) as set forth in Section 219.411(d)(2)(C)

of this Subpart.

(Source: Amended at _______________, effective ________________)

Section 219.411 Recordkeeping and Reporting for Lithographic Printing

a) An owner or operator of lithographic printing line(s) exempt from the limitations

of Section 219.407 of this Subpart because of the criteria in Section 219.405(d) of

this Subpart shall comply with the following:

1) By March 15, 1996, upon initial start-up of a new lithographic printing

line, and upon modification of a lithographic printing line, submit a

certification to the Agency that includes:

A) A declaration that the source is exempt from the control

requirements in Section 219.407 of this Part because of the criteria

in Section 219.405(d) of this Subpart;

B) Calculations which demonstrate that combined emissions of VOM

from all lithographic printing lines (including inks, fountain

solutions, and solvents used for cleanup operations associated with

the lithographic printing lines) at the source never exceed 45.5

kg/day (100 lbs/day) before the use of capture systems and control

devices, as follows:

i) To calculate daily emissions of VOM, the owner or

operator shall determine the monthly emissions of VOM

from all lithographic printing lines at the source (including

solvents used for cleanup operations associated with the

lithographic printing lines) and divide this amount by the

number of days during that calendar month that

lithographic printing lines at the source were in operation;

192

ii) To determine the VOM content of the inks, fountain

solution additives and cleaning solvents, the tests methods

and procedures set forth in Section 219.409(c) of this

Subpart shall be used;

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 of 0.80 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 emission adjustment factor is used. The

VOM content of the 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

iv) To determine VOM emissions from fountain solutions and

cleaning solvents used on lithographic printing line(s) at the

source, no retention factor is used;

C) Either a declaration that the source, through federally enforceable

permit conditions, has limited its maximum theoretical emissions

of VOM from all heatset web offset lithographic printing lines

(including solvents used for cleanup operations associated with

heatset web offset printing lines) at the source to no more than 90.7

Mg (100 tons) per calendar year before the application of capture

systems and control devices or calculations which demonstrate that

the source's total maximum theoretical emissions of VOM do not

exceed 90.7 Mg/yr (100 TPY). To determine the source's total

maximum theoretical emissions for the purposes of this subsection,

the owner or operator shall use the calculations set forth in Section

219.406(b)(1)(A)(ii) of this Subpart; and

D) A description and the results of all tests used to determine the

VOM content of inks, fountain solution additives, and cleaning

solvents, and a declaration that all such tests have been properly

conducted in accordance with Section 219.409(c)(1) of this

Subpart;

2) On and after March 15, 1996, collect and record either the information

specified in subsection (a)(2)(A) or (a)(2)(B) of this Section for all

lithographic printing lines at the source:

A) Standard recordkeeping, including the following:

193

i) The name and identification of each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line, recorded each month;

ii) A daily record which shows whether a lithographic printing

line at the source was in operation on that day;

iii) The VOM content and the volume of each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line, recorded each month;

iv) The total VOM emissions at the source each month,

determined as the sum of the product of usage and VOM

content for each fountain solution additive, cleaning

solvent, and lithographic ink (with the applicable ink VOM

emission adjustment) used at the source, calculated each

month; and

v) The VOM emissions in lbs/day for the month, calculated in

accordance with Section 219.411(a)(1)(B) of this Subpart;

B) Purchase and inventory recordkeeping, including the following:

i) The name, identification, and VOM content of each

fountain solution additive, lithographic ink, and cleaning

solvent used on any lithographic printing line, recorded

each month;

ii) Inventory records from the beginning and end of each

month indicating the total volume of each fountain solution

additive, lithographic ink, and cleaning solvent to be used

on any lithographic printing line at the source;

iii) Monthly purchase records for each fountain solution

additive, lithographic ink, and cleaning solvent used on any

lithographic printing line at the source;

iv) A daily record which shows whether a lithographic printing

line at the source was in operation on that day;

v) The total VOM emissions at the source each month,

determined as the sum of the product of usage and VOM

content for each fountain solution additive, cleaning

solvent, and lithographic ink (with the applicable ink VOM

emission adjustment) used at the source, calculated each

194

month based on the monthly inventory and purchase

records required to be maintained pursuant to subsections

(a)(2)(B)(i), (a)(2)(B)(ii) and (a)(2)(B)(iii) of this Section;

and

vi) The VOM emissions in lbs/day for the month, calculated in

accordance with Section 219.411(a)(1)(B)218.411(a)(1)(B)

of this Subpart;

3) On and after March 15, 1996, notify the Agency in writing if the

combined emissions of VOM from all lithographic printing lines

(including inks, fountain solutions, and solvents used for cleanup

operations associated with the lithographic printing lines) at the source

ever exceed 45.5 kg/day (100 lbs/day), before the use of capture systems

and control devices, within 30 days after the event occurs. Such

notification shall include a copy of all records of such event.

b) An owner or operator of a heatset web offset lithographic printing line(s) subject

to the control requirements of Section 219.407(a)(1)(C) or (b)(1) of this Subpart

shall comply with the following:

1) By March 15, 1996, upon initial start-up of a new printing line, and upon

initial start-up of a new control device for a heatset web offset printing

line, submit a certification to the Agency that includes the following:

A) An identification of each heatset web offset lithographic printing

line at the source;

B) A declaration that each heatset web offset lithographic printing line

is in compliance with the requirements of Section 219.407

(a)(1)(B), (a)(1)(C), (a)(1)(D) and (a)(1)(E) or (b) of this Subpart,

as appropriate;

C) The type of afterburner or other approved control device used to

comply with the requirements of Section 219.407(a)(1)(C) or

(b)(1) of this Subpart;

D) The control requirements in Section 219.407(a)(1)(C) or (b)(1) of

this Subpart with which the lithographic printing line is complying;

E) The results of all tests and calculations necessary to demonstrate

compliance with the control requirements of Section

219.407(a)(1)(C) or (b)(1) of this Subpart, as applicable; and

F) A declaration that the monitoring equipment required under

Section 219.407(a)(1)(D) or (b) of this Subpart, as applicable, has

195

been properly installed and calibrated according to manufacturer's

specifications;

2) If testing of the afterburner or other approved control device is conducted

pursuant to Section 219.409(b) of this Subpart, the owner or operator

shall, within 90 days after conducting such testing, submit a copy of all

test results to the Agency and shall submit a certification to the Agency

that includes the following:

A) A declaration that all tests and calculations necessary to

demonstrate whether the lithographic printing line(s) is in

compliance with Section 219.407(a)(1)(C) or (b)(1) of this

Subpart, as applicable, have been properly performed;

B) A statement whether the lithographic printing line(s) is or is not in

compliance with Section 219.407(a)(1)(C) or (b)(1) of this

Subpart, as applicable; and

C) A maintenance log for the afterburner or other approved control

device and monitoring equipment detailing all routine and non-

routine maintenance performed, including dates and duration of

any outages; and

D) A log detailing checks on the air flow direction or air pressure of

the dryer and press room to insure compliance with the

requirements of Section 219.407(a)(1)(B) of this Subpart at least

once per 24-hour period while the line is operating;

4) On and after March 15, 1996, notify the Agency in writing of any

violation of Section 219.407(a)(1)(C) or (b)(1) of this Subpart within 30

C) The operating parameters of the afterburner or other approved

control device during testing, as monitored in accordance with

Section 219.410(c) or (d) of this Subpart, as applicable;

3) On and after March 15, 1996, collect and record daily the following

information for each heatset web offset lithographic printing line subject

to the requirements of Section 219.407(a)(1)(C) or (b)(1) of this Subpart:

A) Afterburner or other approved control device monitoring data in

accordance with Section 219.410(c) or (d) of this Subpart, as

applicable;

B) A log of operating time for the afterburner or other approved

control device, monitoring equipment, and the associated printing

line;

196

days after the occurrence of such violation. Such notification shall include

a copy of all records of such violation;

5) If changing its method of compliance between subsections (a)(1)(C) and

(b) of Section 219.407 of this Subpart, certify compliance for the new

method of compliance in accordance with subsection (b)(1) of this Section

at least 30 days before making such change, and perform all tests and

calculations necessary to demonstrate that such printing line(s) will be in

compliance with the requirements of Section 219.407(a)(1)(B), (a)(1)(C),

(a)(1)(D) and (a)(1)(E) of this Subpart, or Section 219.407(b) of this

Subpart, as applicable.

c) An owner or operator of a lithographic printing line subject to Section

219.407(a)(1)(A), (a)(2), or (a)(3) of this Subpart, shall:

1) By March 15, 1996, and upon initial start-up of a new lithographic

printing line, certify to the Agency that fountain solutions used on each

lithographic printing line will be in compliance with the applicable VOM

content limitation. Such certification shall include:

A) Identification of each lithographic printing line at the source, by

type, e.g., heatset web offset, non-heatset web offset, or sheet-fed

offset;

B) Identification of each centralized fountain solution reservoir and

each lithographic printing line that it serves;

C) The VOM content limitation with which each fountain solution

will comply;

D) Initial documentation that each type of fountain solution will

comply with the applicable VOM content limitation, including

copies of manufacturer's specifications, test results, if any,

formulation data and calculations;

E) Identification of the method that will be used to demonstrate

continuing compliance with the applicable limitation, e.g., a

refractometer, hydrometer, conductivity meter, or recordkeeping

procedures with detailed description of the compliance

methodology; and

F) A sample of the records that will be kept pursuant to Section

219.411(c)(2) of this Subpart.

2) On and after March 15, 1996, collect and record the following information

for each fountain solution:

197

A) The name and identification of each batch of fountain solution

prepared for use on one or more lithographic printing lines, the

lithographic printing line(s) or centralized reservoir using such

batch of fountain solution, and the applicable VOM content

limitation for the batch;

B) If an owner or operator uses a hydrometer, refractometer, or

conductivity meter, pursuant to Section 219.410(b)(1)(B), to

demonstrate compliance with the applicable VOM content limit in

Section 219.407(a)(1)(A), (a)(2), or (a)(3) of this Subpart:

i) The date and time of preparation, and each subsequent

modification, of the batch;

ii) The results of each measurement taken in accordance with

Section 219.410(b) of this Subpart;

iii) Documentation of the periodic calibration of the meter in

accordance with the manufacturer's specifications,

including date and time of calibration, personnel

conducting, identity of standard solution, and resultant

reading; and

iv) Documentation of the periodic temperature adjustment of

the meter, including date and time of adjustment, personnel

conducting and results;

C) If the VOM content of the fountain solution is determined pursuant

to Section 219.410(b)(1)(A) of this Subpart, for each batch of as-

applied fountain solution:

i) Date and time of preparation and each subsequent

modification of the batch;

ii) Volume and VOM content of each component used in, or

subsequently added to, the fountain solution batch;

iii) Calculated VOM content of the as-applied fountain

solution; and

iv) Any other information necessary to demonstrate

compliance with the applicable VOM content limits in

Section 219.407(a)(1)(A), (a)(2) and (a)(3) of this Subpart,

as specified in the source's operating permit;

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D) If the VOM content of the fountain solution is determined pursuant

to Section 219.410(b)(2) of this Subpart, for each setting:

i) VOM content limit corresponding to each setting;

ii) Date and time of initial setting and each subsequent setting;

iii) Documentation of the periodic calibration of the automatic

feed equipment in accordance with the manufacturer’s

specifications; and

iv)

Any other information necessary to demonstrate

compliance with the applicable VOM content limits in

Sections 219.407(a)(1)(A), (a)(2) and (a)(3) of this Subpart,

as specified in the source’s operating permit.

ED) If the owner or operator relies on the temperature of the fountain

solution to comply with the requirements in Section

219.407(a)(1)(A)(ii) or (a)(3)(B) of this Subpart:

i) The temperature of the fountain solution at each printing

line, as monitored in accordance with Section 219.410(a);

and

ii) A maintenance log for the temperature monitoring devices

and automatic, continuous temperature recorders detailing

all routine and non-routine maintenance performed,

including dates and duration of any outages;

3) Notify the Agency in writing of any violation of Section 219.407 of this

Subpart within 30 days after the occurrence of such violation. Such

notification shall include a copy of all records of such violation; and

4) If changing its method of demonstrating compliance with the applicable

VOM content limitations in Section 219.407 of this Subpart, or changing

the method of demonstrating compliance with the VOM content

limitations for fountain solutions pursuant to Section 219.409 of this

Subpart, certify compliance for such new method(s) in accordance with

subsection (c)(1) of this Section within 30 days after making such change,

and perform all tests and calculations necessary to demonstrate that such

printing line(s) will be in compliance with the applicable requirements of

Section 219.407 of this Subpart.

d) For lithographic printing line cleaning operations, an owner or operator of a

lithographic printing line subject to the requirements of Section 219.407 of this

Subpart shall:

199

1) By March 15, 1996, and or upon initial start-up of a new lithographic

printing line, certify to the Agency that all cleaning solutions, and the

handling of cleaning materials, will be in compliance with the

requirements of Section 219.407(a)(4)(A) or (a)(4)(B) and (a)(5) of this

Subpart, and such certification shall also include:

A) Identification of each VOM-containing cleaning solution used on

each lithographic printing line;

B) The limitation with which each VOM-containing cleaning solution

will comply, i.e., the VOM content or vapor pressure;

C) Initial documentation that each VOM-containing cleaning solution

will comply with the applicable limitation, including copies of

manufacturer's specifications, test results, if any, formulation data

and calculations;

D) Identification of the method that will be used to demonstrate

continuing compliance with the applicable limitations;

E) A sample of the records that will be kept pursuant to Section

219.411(d)(2) of this Subpart; and

F) A description of the practices that assure that VOM-containing

cleaning materials are kept in closed containers;

2) On and after March 15, 1996, collect and record the following information

for each cleaning solution used on each lithographic printing line:

A) For each cleaning solution for which the owner or operator relies

on the VOM content to demonstrate compliance with Section

219.407(a)(4)(A) of this Subpart and which is prepared at the

source with automatic equipment:

i) The name and identification of each cleaning solution;

ii) The VOM content of each cleaning solvent in the cleaning

solution, as determined in accordance with Section

219.409(c) of this Subpart;

iii) Each change to the setting of the automatic equipment, with

date, time, description of changes in the cleaning solution

constituents (e.g., cleaning solvents), and a description of

changes to the proportion of cleaning solvent and water (or

other non-VOM);

200

iv) The proportion of each cleaning solvent and water (or other

non-VOM) used to prepare the as-used cleaning solution;

v) The VOM content of the as-used cleaning solution, with

supporting calculations; and

vi) A calibration log for the automatic equipment, detailing

periodic checks;

B) For each batch of cleaning solution for which the owner or

operator relies on the VOM content to demonstrate compliance

with Section 219.407(a)(4)(A) of this Subpart, and which is not

prepared at the source with automatic equipment:

i) The name and identification of each cleaning solution;

ii) Date and time of preparation, and each subsequent

modification, of the batch;

iii) The VOM content of each cleaning solvent in the cleaning

solution, as determined in accordance with Section

219.409(c) of this Subpart;

iv) The total amount of each cleaning solvent and water (or

other non-VOM) used to prepare the as-used cleaning

solution; and

v) The VOM content of the as-used cleaning solution, with

supporting calculations;

C) For each batch of cleaning solution for which the owner or

operator relies on the vapor pressure of the cleaning solution to

demonstrate compliance with Section 219.407(a)(4)(B) of this

Subpart:

i) The name and identification of each cleaning solution;

ii) Date and time of preparation, and each subsequent

modification, of the batch;

iii) The molecular weight, density, and VOM composite partial

vapor pressure of each cleaning solvent, as determined in

accordance with Section 219.409(e) of this Subpart;

201

iv) The total amount of each cleaning solvent used to prepare

the as-used cleaning solution; and

v) The VOM composite partial vapor pressure of each as-used

cleaning solution, as determined in accordance with Section

219.409(e) of this Subpart;

D) The date, time and duration of scheduled inspections performed to

confirm the proper use of closed containers to control VOM

emissions, and any instances of improper use of closed containers,

with descriptions of actual practice and corrective action taken, if

any;

3) On and after March 15, 1996, notify the Agency in writing of any

violation of Section 219.407 of this Subpart within 30 days after the

occurrence of such violation. Such notification shall include a copy of all

records of such violation; and

4) If changing its method of demonstrating compliance with the requirements

of Section 219.407(a)(4) of this Subpart, or changing between automatic

and manual methods of preparing cleaning solutions, certify compliance

for such new method in accordance with subsection (d)(1) of this Section,

within 30 days after making such change, and perform all tests and

calculations necessary to demonstrate that such printing line(s) will be in

compliance with the applicable requirements of Section 219.407(a)(4) of

this Subpart.

e) The owner or operator shall maintain all records required by this Section at the

source for a minimum period of three years and shall make all records available to

the Agency upon request.

(Source: Amended at _______________, effective ________________)

SUBPART Z: DRY CLEANERS

Section 219.601 Perchloroethylene Dry Cleaners (Repealed)

The owner or operator of a dry cleaning operation which uses perchloroethylene shall:

Vent the entire dryer exhaust through a properly designed and functioning carbon

adsorption system or equally effective control device; and

Emit no more than 100 ppmv of VOM from the dryer control device before

dilution, or achieve a 90 percent average reduction before dilution; and

Immediately repair all components found to be leaking liquid VOM; and

202

Cook or treat all diatomaceous earth filters so that the residue contains 25 kg (55

lb) or less of volatile organic material per 100 kg (220 lb) of wet waste material;

and

Reduce the VOM from all solvent stills to 60 kg (132 lb) or less per 100 kg (220

lb) of wet waste material; and

Drain all filtration cartridges in the filter housing or other sealed container for at

least 24 hours before discarding the cartridges; and

Dry all drained filtration cartridges in equipment connected to an emission

reduction system or in a manner that will eliminate emission of volatile organic

material to the atmosphere.

(Source: Repealed at _______________, effective ________________)

Section 219.602 Exemptions (Repealed)

The provisions of Section 219.601 are not applicable to perchloroethylene dry cleaning

operations which are coin-operated or to dry cleaning operations consuming less than 30 gal per

month (360 gal per year) of perchloroethylene.

(Source: Repealed at _______________, effective ________________)

Section 219.603 Leaks (Repealed)

The presence of leaks shall be determined for purposes of Section 219.601(c) of this Part by a

visual inspection of the following: hose connections, unions, couplings and valves; machine door

gaskets and seatings; filter head gasket and seating; pumps; base tanks and storage containers;

water separators; filter sludge recovery; distillation unit; diverter valves; saturated lint from lint

baskets; and cartridge filters.

(Source: Repealed at _______________, effective ________________)

SUBPART HH: MOTOR VEHICLE REFINISHING

Section 219.790 General Recordkeeping and Reporting (Repealed)

On and after the compliance date specified in Section 219.791 of this Subpart, every owner or

operator of a motor vehicle refinishing operation shall maintain the following records for the

most recent consecutive 3 years. Such records shall be made available to the Agency

immediately upon request:

The name and manufacturer of each coating and surface preparation product used

at the source each month;

203

The volume of each category of coating, as set forth in Section 219.780 of this

Subpart, purchased by the source each month;

The coating mixing instructions, as stated on the container, in literature supplied

with the coating, or otherwise specified by the manufacturer, for each coating

purchased by the source each month;

The VOM content, expressed as weight of VOM per volume of coating, minus

water and any compounds that are specifically exempted from the definition of

VOM, recorded on a monthly basis for:

Each coating as purchased, if the coating is not mixed with any additives

prior to application on the substrate; or

Each coating after mixing according to manufacturer's instructions as

collected pursuant to subsection (c) of this Section;

The weighted average VOM content of the coating, as specified in Section

219.780(d)(1), (d)(2) or (d)(3) of this Subpart, for each basecoat/clearcoat, and

three or four stage coating system purchased by the source, recorded on a monthly

basis;

The total monthly volume of all specialty coatings purchased and the percentage

specialty coatings comprise in the aggregate of all coatings purchased by the

source each month;

The volume of each category of surface preparation material, as set forth in

Section 219.786 of this Subpart, purchased by the source each month; and

The VOM content, expressed as weight of VOM per volume of material,

including water, of each surface preparation material purchased by the source,

recorded on a monthly basis.

Section 219.792 Registration

(Source: Repealed at _______________, effective ________________)

a) Every owner or operator of a motor vehicle refinishing operation shall register

with the Agency on or before the date specified in Section 219.791 of this Subpart

and re-register no later than 45 days following the end of each subsequent

calendar year. The following information shall be included in this registration:

1) The name and address of the source, and the name and telephone number

of the person responsible for submitting the registration information;

204

2) A description of all coating operations of motor vehicles, mobile

equipment, or their parts or components, and all associated surface

preparation operations at the source;

3) A description of all coating applicators used at the source to comply with

Section 219.784(a) of this Subpart, if applicable;

4) A description of all cleanup operations at the source, including equipment

used to comply with Section 219.784(b) of this Subpart, if applicable;

5) A description of all work practices at the source used to comply with

Section 219.787 of this Subpart;

6) If a source claims to be exempt from the equipment requirements in

Section 219.784 of this Subpart because it uses less than 20 gallons of

coating per year, the owner's or operator's certification that the annual

usage is below this level;

7) A written declaration stating whether the source is complying with this

Subpart by using coatings that comply with the applicable VOM content

limits in Section 219.780 of this Subpart or by control equipment as

specified in Section 219.782; and

8) A description of any control devices used to comply with Section 219.782

of this Subpart and the date(s) the device was installed and became

operational.

b) At least 30 calendar days before changing the method of compliance to or from

Sections 219.780 and 219.782, the owner or operator of a motor vehicle

refinishing operation shall notify the Agency and certify that the source is in

compliance with the applicable requirements for the new method of compliance.

(Source: Amended at _______________, effective ________________)

Section 219.Appendix B VOM Measurement Techniques for Capture Efficiency (Repealed)

Procedure G.1 - Captured VOM Emissions

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the volatile organic materials

(VOM) content of captured gas streams. It is intended to be used as a segment in the

development of liquid/gas or gas/gas protocols for determining VOM capture efficiency (CE) for

surface coating and printing operations. The procedure may not be acceptable in certain site-

specific situations, e.g., when: (1) direct fired heaters or other circumstances affect the quantity

205

of VOM at the control device inlet; and (2) particulate organic aerosols are formed in the process

and are present in the captured emissions.

1.2 Principle. The amount of VOM captured (G) is calculated as the sum of the products of the

VOM content (CGj), the flow rate (QGj), and the sample time (TC) from each captured emissions

point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

captured or fugitive emissions point as follows: QGj = 5.5 percent and CGj = +5.0 percent. Based

on these numbers, the probable uncertainty for G is estimated at about + 7.4 percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

2. APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to mininize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow rate control valve and

rotameter must be heated to prevent condensation. A control valve may also be located on the

sample pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the flame

ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

206

components shall be constructed of stainless steel or Teflon. If captured or fugitive emissions

are to be measured at multiple locations, the measurement system shall be designed to use

separate sampling probes, lines, and pumps for each measurement location and a common

sample gas manifold and FIA. The sample gas manifold and connecting lines to the FIA must be

heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than + 3.0 percent of the span value.

2.1.7.2 Calibration Drift. Less than + 3.0 percent of the span value.

2.1.7.3 Calibration Error. Less than + 5.0 percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized date

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to +1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than +2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane or

carbon equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

207

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Captured Emissions Volumetric Flow Rate.

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

3. DETERMINATION OF VOLUMETRIC FLOW RATE OF CAPTURED EMISSIONS

3.1 Locate all points where emissions are captured from the affected emission unit. Using

Method 1, determine the sampling points. Be sure to check each site for cyclonic or swirling

flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

4. DETERMINATION OF VOM CONTENT OF CAPTURED EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each captured emissions point during the

entire test run or, if applicable, while the process is operating. If there are multiple captured

emission locations, design a sampling system to allow a single FIA to be used to determine the

VOM responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA according to the

procedure in Section 5.1.

4.2.2 Conduct a system check according to the procedure in Section 5.3.

4.2.3 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct, and

is sealed tightly at the stack port connection.

4.2.4 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position.

4.2.5 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

208

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.6 Verify that the sample lines, filter, and pump temperatures are 120 +5

4.2.7 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple captured emission locations are sampled using a single FIA, sample at each location for

the same amount of time (e.g., 2 minutes) and continue to switch from one location to another for

the entire test run. Be sure that total sampling time at each location is the same at the end of the

test run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the measurements at each sampling location until two times the response time

of the measurement system has elapsed. Continue sampling for at least 1 minute and record the

concentration measurements.

4.3 Background Concentration.

4.3.1 Locate all NDO’s of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO’s,

choose 6 sampling points evenly spaced among the NDO’s.

4.3.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3. NOTE: This sample train shall be a

separate sampling train from the one to measure the captured emissions.

4.3.3 Position the probe at the sampling location.

4.3.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.4 to 4.2.7.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

5. CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

209

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the captured emissions for conducting the drift checks. Introduce the zero and

calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate and

pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct the system drift checks at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before and after each test run.

5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

total area of all NDO's in the enclosure, ft

;

Cbi

corrected average VOM concentration of background emissions at point i,

ppm propane;

average background concentration, ppm propane;

CGj

corrected average VOM concentration of captured emissions at point j,

ppm propane;

CDH

average measured concentration for the drift check calibration gas, ppm

propane;

CDO

average system drift check concentration for zero concentration gas, ppm

propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average background VOM concentration measured at point i,

ppm propane;

210

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of captured emissions, kg;

1.830 X 10

kg/(m

)-ppm);

number of measurement points;

QGj

average effluent volumetric flow rate corrected to standard conditions at

captured emissions point j, m

/min;

total duration of captured emissions sampling run, min.

CALCULATIONS

7.1 Total VOM Captured Emissions.

G =

(CGj - CB) QGj TC K1 Eq. 1

j=1

7.2 VOM Concentration of the Captured Emissions at point j.

CGj =

(Cj - CDO) CH Eq. 2

CDH - CDO

7.3 Background VOM Concentration at point i.

CBi =

(Ci - CDO) CH Eq.3

CDH - CDO

7.4 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure G.2 - Captured VOM Emissions (Dilution Technique)

1. INTRODUCTION

211

1.1 Applicability. This procedure is applicable for determining the volatile organic materials

(VOM) content of captured gas streams. It is intended to be used as a segment in the

development of a gas/gas protocol in which fugitive emissions are measured for determining

VOM capture efficiency (CE) for surface coating and printing operations. A dilution system is

used to reduce the VOM concentration of the captured emission to about the same concentration

as the fugitive emissions. The procedure may not be acceptable in certain site-specific situations,

e.g., when: (1) direct fired heaters or other circumstances affect the quantity of VOM at the

control device inlet; and (2) particulate organic aerosols are formed in the process and are

present in the captured emissions.

1.2 Principle. The amount of VOM captured (G) is calculated as the sum of the products of the

VOM content (CGj), the flow rate (QGj), and the sampling time (TC) from each captured

emissions point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

captured or fugitive emissions point as follows: QGj = +5 percent and CGj= +5 percent. Based on

these numbers, the probable uncertainty for G is estimated at about +7.4 percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

2. APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Dilution System. A Kipp in-stack dilution probe and controller or similar device may be

used. The dilution rate may be changed by substituting different critical orifices or adjustments

of the aspirator supply pressure. The dilution system shall be heated to prevent VOM

condensation. Note: An out-of-stack dilution device may be used.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

212

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow control valve and rotameter

must be heated to prevent condensation. A control valve may also be located on the sample

pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the flame

ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If captured or fugitive emissions

are to be measured at multiple locations, the measurement system shall be designed to use

separate sampling probes, lines, and pumps for each measurement location and a common

sample gas manifold and FIA. The sample gas manifold and connecting lines to the FIA must be

heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than +3.0 percent of the span value.

2.1.7.2 Calibration Drift. Less than +3.0 percent of the span value.

2.1.7.3 Calibration Error. Less than +5.0 percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to +1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than +2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

213

2.1.9.2 Carrier Gas and Dilution Air Supply. High purity air with less than 1 ppm of organic

material (as propane or carbon equivalent) or less than 0.1 percent of the span value, whichever

is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.9.4 Dilution Check Gas. Gas mixture standard containing propane in air, approximately half

the span value after dilution.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Captured Emissions Volumetric Flow Rate.

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

3. DETERMINATION OF VOLUMETRIC FLOW RATE OF CAPTURED EMISSIONS

3.1 Locate all points where emissions are captured from the affected facility. Using Method 1,

determine the sampling points. Be sure to check each site for cyclonic or swirling flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

4. DETERMINATION OF VOM CONTENT OF CAPTURED EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each captured emissions point during the

entire test run or, if applicable, while the process is operating. If there are a multiple captured

emissions locations, design a sampling system to allow a single FIA to be used to determine the

VOM responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA according to the

procedure in Section 5.1.

214

4.2.2 Set the dilution ratio and determine the dilution factor according to the procedure in

Section 5.3.

4.2.3 Conduct a system check according to the procedure in Section 5.4.

4.2.4 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct, and

is sealed tightly at the stack port connection.

4.2.5 Inject zero gas at the calibration valve assembly. Measure the system response time as the

time required for the system to reach the effluent concentration after the calibration valve has

been returned to the effluent sampling position.

4.2.6 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.4. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.7 Verify that the sample lines, filter, and pump temperatures are 120 +5

4.2.8 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple captured emission locations are sampled using a single FIA, sample at each location for

the same amount of time (e.g., 2 minutes) and continue to switch from one location to another for

the entire test run. Be sure that total sampling time at each location is the same at the end of the

test run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the measurements at each sampling location until two times the response time

of the measurement system has elapsed. Continue sampling for at least 1 minute and record the

concentration measurements.

4.3 Background Concentration.

4.3.1 Locate all NDO’s of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO’s,

choose 6 sampling points evenly spaced among the NDO’s.

4.3.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.4.

4.3.3 Position the probe at the sampling location.

4.3.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.4 to 4.2.8.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

215

5. CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

the dilution system and adjust the back-pressure regulator to the value required to achieve the

flow rates specified by the manufacturer. Inject the zero- and the high-range calibration gases

and adjust the analyzer calibration to provide the proper responses. Inject the low- and mid-

range gases and record the responses of the measurement system. The calibration and linearity

of the system are acceptable if the responses for all four gases are within 5 percent of the

respective gas values. If the performance of the system is not acceptable, repair or adjust the

system and repeat the linearity check. Conduct a calibration and linearity check after assembling

the analysis system and after a major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the diluted captured emissions for conducting the drift checks. Introduce the

zero and calibration gas at the calibration valve assembly and verify that the appropriate gas flow

rate and pressure are present at the FIA. Record the measurement system responses to the zero

and calibration gases. The performance of the system is acceptable if the difference between the

drift check measurement and the value obtained in Section 5.1 is less than 3 percent of the span

value. Conduct the system drift check at the end of each run.

5.3 Determination of Dilution Factor. Inject the dilution check gas into the measurement system

before the dilution system and record the response. Calculate the dilution factor using Equation

5.4 System Check. Inject the high range calibration gas at the inlet to the sampling probe while

the dilution air is turned off. Record the response. The performance of the system is acceptable

if the measurement system response is within 5 percent of the value obtained in Section 5.1 for

the high range calibration gas. Conduct a system check before and after each test run.

5.5 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

total area of all NDO’s in the enclosure, ft

;

actual concentration of the dilution check gas, ppm propane;

Cbi

corrected average VOM concentration of background emissions at point i,

ppm propane;

216

average background concentration, ppm propane;

CDH

average measured concentration for the drift check calibration gas, ppm

propane;

CDO

average system drift check concentration for zero concentration gas, ppm

propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average background VOCM concentration measured at point

i, ppm propane;

uncorrected average VOCM concentration measured at point j, ppm

propane;

measured concentration of the dilution check gas, ppm propane;

dilution factor;

total VOCM content of captured emissions, kg;

number of measurement points;

QGj

average effluent volumetric flow rate corrected to standard conditions at

captured emissions point j, m

/min;

total duration of capture efficiency sampling run, min.

7. CALCULATIONS

7.1 Total VOM Captured Emissions.

G =

CGj QGj TC Kl Eq. 1

j=1

7.2 VOM Concentration of the Captured Emissions at Point j.

CGj =

DF (Cj - CDO) CH Eq.2

7.4 Background VOM Concentration at Point i.

CBi =

(Ci - CDO) CH Eq. 4

CDH - CDO

7.5 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure F.2 - Fugitive VOM Emissions from Building Enclosures

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the fugitive volatile organic

materials (VOM) emissions from a building enclosure (BE). It is intended to be used as a

segment in the development of liquid/gas or gas/gas protocols for determining VOM capture

efficiency (CE) for surface coating and printing operations.

1.2 Principle. The total amount of fugitive VOM emissions (FB) from the BE is calculated as the

sum of the products of the VOM content (CFj) of each fugitive emissions point, its flow rate

(QFj), and time (TF).

1.3 Measurement Uncertainty. The measurement uncertainties are estimated for each fugitive

emissions point as follows: QFj = +5.0 percent and CFj = +5.0 percent. Based on these numbers,

the probable uncertainty for FB is estimated at about +11.2 percent.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

2. APPARATUS AND REAGENTS

218

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow rate control valve and

rotameter must be heated to prevent condensation. A control valve may also be located on the

sample pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the flame

ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If emissions are to be measured at

multiple locations, the measurement system shall be designed to use separate sampling probes,

lines, and pumps for each measurement location and a common sample gas manifold and FIA.

The sample gas manifold must be heated to prevent condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.1.7.1 Zero Drift. Less than +3.0 percent of the span value.

2.1.7.2 Calibration Drift. Less than +3.0 percent of the span value.

2.1.7.3 Calibration Error. Less than +5.0 percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

219

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to +1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than +2 percent from

the certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (propane or carbon

equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Fugitive Emissions Volumetric Flow Rate.

2.2.1 Flow Direction Indicators. Any means of indicating inward or outward flow, such as light

plastic film or paper streamers, smoke tubes, filaments, and sensory perception.

2.2.2 Method 2 or 2A Apparatus. For determining volumetric flow rate. Anemometers or

velocities are present. Vane anemometers (Young-maximum response propeller), specialized

pitots with electronic manometers (e.g., Shortridge Instruments Inc., Airdata Multimeter 860) are

commercially available with measurement thresholds of 15 and 8 mpm (50 and 25 fpm),

respectively.

2.2.3 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.4 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

3. DETERMINATION OF VOLUMETRIC FLOW RATE OF FUGITIVE EMISSIONS

220

3.1 Preliminary Determinations. The purpose of this exercise is to determine which exhaust

points should be measured for volumetric flow rates and VOM concentrations.

3.1.1 Forced Draft Openings. Identify all forced draft openings. Determine the volumetric flow

rate according to Method 2.

3.1.2 NDO’s Exhaust points. The NDO’s in the roof of the building or room in which the

emission unit is located are considered to be exhaust points. Determine volumetric flow rate

from these NDO’s. Divide the cross-sectional area according to Method 1 using 12 equal areas.

Use the appropriate velocity measurement devices, e.g., propeller anemometers.

3.1.3 Other NDO’s.

3.1.3.1 This step is optional. Determine the exhaust flow rate, including that of the control

device, from the enclosure and the intake air flow rate. If the exhaust flow rate divided by the

intake air flow rate is greater than 1.1, then all other NDO’s are not considered to be significant

exhaust points.

3.1.3.2 If the option above is not taken, identify all other NDO's and other potential points

through which fugitive emissions may escape the enclosure.

Then use the following criteria to determine whether flow rates and VOM concentrations need to

be measured:

3.1.3.2.1 Using the appropriate flow direction indicator, determine the flow direction. An NDO

with zero or inward flow is not an exhaust point.

3.1.3.2.2 Measure the outward volumetric flow rate from the remainder of the NDO’s. If the

collective flow rate is 2 percent, or less, of the flow rate from Sections 3.1.1 and 3.1.2, then these

NDO’s, except those within two equivalent diameters (based on NDO opening) from a VOM

emitting point, may be considered to be non-exhaust points.

3.1.3.2.3 If the percentage calculated in Section 3.1.3.2.2 is greater than 2 percent, those NDO’s

(except those within two equivalent diameters from a VOM emitting point) whose volumetric

flow rate total 2 percent of the flow rate from Sections 3.1.1 and 3.1.2 may be considered as non-

exhaust points. All remaining NDO’s shall be measured for volumetric flow rate and VOM

concentrations during the CE test.

3.1.3.2.4 The tester may choose to measure VOM concentrations at the forced exhaust points and

the NDO’s. If the total VOM emissions from the NDO’s are less than 2 percent of the emissions

from the forced draft and roof NDO’s, then these NDO’s may be eliminated from further

consideration.

3.2 Determination of Flow Rates.

221

3.2.1 Measure the volumetric flow rate at all locations identified as exhaust points in Section 3.1.

Divide each exhaust opening into 9 equal areas for rectangular openings and 8 for circular

openings.

3.2.2 Measure the velocity at each site at least once every hour during each sampling run using

Method 2 or 2A, if applicable, or using the low velocity instruments in Section 2.2.2.

4. DETERMINATION OF VOM CONTENT OF FUGITIVE EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each fugitive emission point during the

entire test run or, if applicable, while the process is operating. If there are multiple emissions

locations, design a sampling system to allow a single FIA to be used to determine the VOM

responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3, respectively.

4.2.2 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct, and

is sealed tightly at the stack port connection.

4.2.3 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position.

4.2.4 Conduct a system check before and a system drift check after each sampling run according

to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform drift checks

during the run not to exceed one drift check per hour.

4.2.5 Verify that the sample lines, filter, and pump temperatures are 120 +5

4.2.6 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple emission locations are sampled using a single FIA, sample at each location for the same

amount of time (e.g., 2 minutes) and continue to switch from one location to another for the

entire test run. Be sure that total sampling time at each location is the same at the end of the test

run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the response measurements at each sampling location until two times the

response time of the measurement system has elapsed. Continue sampling for at least 1 minute

and record the concentration measurements.

222

4.3 Alternative Procedure The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

5. CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas that most closely approximates the

concentration of the captured emissions for conducting the drift checks. Introduce the zero and

calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate and

pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct a system drift check at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before each test run.

5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

percent.

NOMENCLATURE

CDH

average measured concentration for the drift check calibration gas, ppm

propane;

CDO

average system drift check concentration for zero concentration gas, ppm

propane;

CFj

corrected average VOM concentration of fugitive emissions at point j,

ppm propane;

223

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of fugitive emissions from the building, kg;

number of measurement points;

QFj

average effluent volumetric flow rate corrected to standard conditions at

fugitive emissions point j, m

/min;

total duration of capture efficiency sampling run, min.

7. CALCULATIONS

7.1 Total VOM Fugitive Emissions From the Building.

FB =

CFj QFj TF K1 Eq. 1

j=1

7.2 VOM Concentration of the Fugitive Emissions at Point j.

CFj =

Cj - CDO) CH Eq. 2

CDH - CDO

Procedure F.1 - Fugitive VOM Emissions from Temporary Enclosures

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the fugitive volatile organic

materials (VOM) emissions from a temporary total enclosure (TTE). It is intended to be used as

a segment in the development of liquid/gas or gas/gas protocols for determining VOM capture

efficiency (CE) for surface coating and printing operations.

1.2 Principle. The amount of fugitive VOM emissions (F) from the TTE is calculated as the sum

of the products of the VOM content (CFj), the flow rate (QFj), and the sampling time (TF) from

each fugitive emissions point.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

fugitive emission point as follows: QFj) = +5.5 percent and CFj = +5.0 percent. Based on these

numbers, the probable uncertainty for F is estimated at about +7.4 percent.

224

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

2. APPARATUS AND REAGENTS

2.1 Gas VOM Concentration. A schematic of the measurement system is shown in Figure 1.

The main components are described below:

2.1.1 Sample Probe. Stainless steel, or equivalent. The probe shall be heated to prevent VOM

condensation.

2.1.2 Calibration Valve Assembly. Three-way valve assembly at the outlet of sample probe to

direct the zero and calibration gases to the analyzer. Other methods, such as quick-connect lines,

to route calibration gases to the outlet of the sample probe are acceptable.

2.1.3 Sample Line. Stainless steel or Teflon tubing to transport the sample gas to the analyzer.

The sample line must be heated to prevent condensation.

2.1.4 Sample Pump. A leak-free pump, to pull the sample gas through the system at a flow rate

sufficient to minimize the response time of the measurement system. The components of the

pump that contact the gas stream shall be constructed of stainless steel or Teflon. The sample

pump must be heated to prevent condensation.

2.1.5 Sample Flow Rate Control. A sample flow rate control valve and rotameter, or equivalent,

to maintain a constant sampling rate within 10 percent. The flow control valve and rotameter

must be heated to prevent condensation. A control valve may also be located on the sample

pump bypass loop to assist in controlling the sample pressure and flow rate.

2.1.6 Sample Gas Manifold. Capable of diverting a portion of the sample gas stream to the flame

ionization analyzer (FIA), and the remainder to the bypass discharge vent. The manifold

components shall be constructed of stainless steel or Teflon. If emissions are to be measured at

multiple locations, the measurement system shall be designed to use separate sampling probes,

lines, and pumps for each measurement location and a common sample gas manifold and FIA.

The sample gas manifold and connecting lines to the FIA must be heated to prevent

condensation.

2.1.7 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however, other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

225

2.1.7.1 Zero Drift. Less than

3.0 percent of the span value.

2.1.7.2 Calibration Drift. Less than

3.0 percent of the span value.

2.1.7.3 Calibration Error. Less than

5.0 percent of the calibration gas value.

2.1.7.4 Response Time. Less than 30 seconds.

2.1.8 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.1.9 Calibration and Other Gases. Gases used for calibration, fuel, and combustion air (if

required) are contained in compressed gas cylinders. All calibration gases shall be traceable to

NIST standards and shall be certified by the manufacturer to

1 percent of the tag value.

Additionally, the manufacturer of the cylinder should provide a recommended shelf life for each

calibration gas cylinder over which the concentration does not change more than

2 percent from

thecertified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.1.9.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.1.9.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane or

carbon equivalent) or less than 0.1 percent of the span value, whichever is greater.

2.1.9.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards with

nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.1.10 Particulate Filter. An in-stack or an out-of-stack glass fiber filter is recommended if

exhaust gas particulate loading is significant. An out-of-stack filter must be heated to prevent

any condensation unless it can be demonstrated that no condensation occurs.

2.2 Fugitive Emissions Volumetric Flow Rate.

2.2.1 Method 2 or 2A Apparatus. For determining volumetric flow rate.

2.2.2 Method 3 Apparatus and Reagents. For determining molecular weight of the gas stream.

An estimate of the molecular weight of the gas stream may be used if it can be justified.

2.2.3 Method 4 Apparatus and Reagents. For determining moisture content, if necessary.

226

2.3 Temporary Total Enclosure. The criteria for designing a TTE are discussed in Procedure T.

3. DETERMINATION OF VOLUMETRIC FLOW RATE OF FUGITIVE EMISSIONS

3.1 Locate all points where emissions are exhausted from the TTE. Using Method 1, determine

the sampling points. Be sure to check each site for cyclonic or swirling flow.

3.2 Measure the velocity at each sampling site at least once every hour during each sampling run

using Method 2 or 2A.

4. DETERMINATION OF VOM CONTENT OF FUGITIVE EMISSIONS

4.1 Analysis Duration. Measure the VOM responses at each fugitive emission point during the

entire test run or, if applicable, while the process is operating. If there are multiple emission

locations, design a sampling system to allow a single FIA to be used to determine the VOCM

responses at all sampling locations.

4.2 Gas VOM Concentration.

4.2.1 Assemble the sample train as shown in Figure 1. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3, respectively.

4.2.2 Install the sample probe so that the probe is centrally located in the stack, pipe, or duct, and

is sealed tightly at the stack port connection.

4.2.3 Inject zero gas at the calibration valve assembly. Allow the measurement system response

to reach zero. Measure the system response time as the time required for the system to reach the

effluent concentration after the calibration valve has been returned to the effluent sampling

position. 4.2.4 Conduct a system check before and a system drift check after each sampling run

according to the procedures in Sections 5.2 and 5.3. If the drift check following a run indicates

unacceptable performance, the run is not valid. The tester may elect to perform system drift

checks during the run not to exceed one drift check per hour.

4.2.5 Verify that the sample lines, filter, and pump temperatures are 120

4.2.6 Begin sampling at the start of the test period and continue to sample during the entire run.

Record the starting and ending times and any required process information as appropriate. If

multiple emission locations are sampled using a single FIA, sample at each location for the same

amount of time (e.g., 2 minutes) and continue to switch from one location to another for the

entire test run. Be sure that total sampling time at each location is the same at the end of the test

run. Collect at least 4 separate measurements from each sample point during each hour of

testing. Disregard the response measurements at each sampling location until two times the

response time of the measurement system has elapsed. Continue sampling for at least 1 minute

and record the concentration measurements

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4.3 Background Concentration.

4.3.1 Determination of VOM Background Concentration.

4.3.1.1 Locate all NDO’s of the TTE. A sampling point shall be centrally located outside of the

TTE at 4 equivalent diameters from each NDO, if possible. If there are more than 6 NDO’s,

choose 6 sampling points evenly spaced among the NDO’s.

4.3.1.2 Assemble the sample train as shown in Figure 2. Calibrate the FIA and conduct a system

check according to the procedures in Sections 5.1 and 5.3.

4.3.1.3 Position the probe at the sampling location.

4.3.1.4 Determine the response time, conduct the system check and sample according to the

procedures described in Sections 4.2.3 to 4.2.6.

4.4 Alternative Procedure. The direct interface sampling and analysis procedure described in

Section 7.2 of Method 18 may be used to determine the gas VOM concentration. The system

must be designed to collect and analyze at least one sample every 10 minutes.

5. CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. Select the calibration gas concentration that most closely

approximates that of the fugitive gas emissions to conduct the drift checks. Introduce the zero

and calibration gas at the calibration valve assembly and verify that the appropriate gas flow rate

and pressure are present at the FIA. Record the measurement system responses to the zero and

calibration gases. The performance of the system is acceptable if the difference between the drift

check measurement and the value obtained in Section 5.1 is less than 3 percent of the span value.

Conduct a system drift check at the end of each run.

5.3 System Check. Inject the high range calibration gas at the inlet of the sampling probe and

record the response. The performance of the system is acceptable if the measurement system

response is within 5 percent of the value obtained in Section 5.1 for the high range calibration

gas. Conduct a system check before each test run.

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5.4 Analysis Audit. Immediately before each test analyze an audit cylinder as described in

Section 5.2. The analysis audit must agree with the audit cylinder concentration within 10

total area of all NDO's in the enclosure, ft

;

Cbi

corrected average VOM concentration of background emissions at point i,

ppm propane;

average background concentration, ppm propane;

CDH

average measured concentration for the drift check calibration gas, ppm

propane;

CDO

average system drift check concentration for zero concentration gas, ppm

propane;

CFj

corrected average VOM concentration of fugitive emissions at point j,

ppm propane;

actual concentration of the drift check calibration gas, ppm propane;

uncorrected average background VOM concentration at point i, ppm

propane;

uncorrected average VOM concentration measured at point j, ppm

propane;

total VOM content of captured emissions, kg;

number of measurement points;

QFj

average effluent volumetric flow rate corrected to standard conditions at

fugitive emissions point j, m

/min;

total duration of fugitive emissions sampling run, min.

7. CALCULATIONS

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7.1 Total VOM Fugitive Emissions.

F =

(CFj - CB) QFj TF Kl Eq. 1

j=l

7.2 VOM Concentration of the Fugitive Emissions at Point j.

CFj =

(Cj - CDO) CH Eq. 2

CDH - CDO

7.3 Background VOM Concentration at Point i.

CBi =

(Ci - CDO) CH Eq. 3

CDH - CDO

7.4 Average Background Concentration.

NOTE: If the concentration at each point is within 20 percent of the average concentration of all

points, the terms "Ai" and "AN" may be deleted from Equation 4.

Procedure L - VOM Input

1. INTRODUCTION

1.1 Applicability. This procedure is applicable for determining the input of volatile organic

materials (VOM). It is intended to be used as a segment in the development of liquid/gas

protocols for determining VOM capture efficiency (CE) for surface coating and printing

operations.

1.2 Principle. The amount of VOM introduced to the process (L) is the sum of the products of

the weight (W) of each VOM containing liquid (ink, paint, solvent, etc.) used and its VOM

content (V). A sample of each VOM containing liquid is analyzed with a flame ionization

analyzer (FIA) to determine V.

1.3 Estimated Measurement Uncertainty. The measurement uncertainties are estimated for each

VOM containing liquid as follows: W =

2.0 percent and V =

-12.0 percent. Based on these

230

numbers, the probable uncertainty for L is estimated at about

12.2 percent for each VOM

containing liquid.

1.4 Sampling Requirements. A capture efficiency test shall consist of at least three sampling

runs. The sampling time for each run should be at least 8 hours, unless otherwise approved.

1.5 Notes. Because this procedure is often applied in highly explosive areas, caution and care

should be exercised in choosing appropriate equipment and installing and using the equipment.

Mention of trade names or company products does not constitute endorsement. All gas

concentrations (percent, ppm) are by volume, unless otherwise noted.

2. APPARATUS AND REAGENTS

2.1 Liquid Weight.

2.1.1 Balances/Digital Scales. To weigh drums of VOM containing liquids to within 0.2 lb.

2.1.2 Volume Measurement Apparatus (Alternative). Volume meters, flow meters, density

measurement equipment, etc., as needed to achieve same accuracy as direct weight

measurements.

2.2 VOM Content (Flame Ionization Analyzer Technique). The liquid sample analysis system is

shown in Figures 1 and 2. The following equipment is required:

2.2.1 Sample Collection Can. An appropriately sized metal can to be used to collect VOM

containing materials. The can must be constructed in such a way that it can be grounded to the

coating container.

2.2.2 Needle Valves. To control gas flow.

2.2.3 Regulators. For carrier gas and calibration gas cylinders.

2.2.4 Tubing. Teflon or stainless steel tubing with diameters and lengths determined by

connection requirements of equipment. The tubing between the sample oven outlet and the FIA

shall be heated to maintain a temperature of 120

2.2.5 Atmospheric Vent. A tee and 0- to 0.5-liter/min rotameter placed in the sampling line

between the carrier gas cylinder and the VOM sample vessel to release the excess carrier gas. A

toggle valve placed between the tee and the rotameter facilitates leak tests of the analysis system.

2.2.6 Thermometer. Capable of measuring the temperature of the hot water bath to within 1

2.2.7 Sample Oven. Heated enclosure, containing calibration gas coil heaters, critical orifice,

aspirator, and other liquid sample analysis components, capable of maintaining a temperature of

120

231

2.2.8 Gas Coil Heaters. Sufficient lengths of stainless steel or Teflon tubing to allow zero and

calibration gases to be heated to the sample oven temperature before entering the critical orifice

or aspirator.

2.2.9 Water Bath. Capable of heating and maintaining a sample vessel temperature of 100

2.2.10 Analytical Balance. To measure

0.001 g.

2.2.11 Disposable Syringes. 2-cc or 5-cc.

2.2.12 Sample Vessel. Glass, 40-ml septum vial. A separate vessel is needed for each sample.

2.2.13 Rubber Stopper. Two-hole stopper to accommodate 3.2-mm (1/8-in) Teflon tubing,

appropriately sized to fit the opening of the sample vessel. The rubber stopper should be

wrapped in Teflon tape to provide a tighter seal and to prevent any reaction of the sample with

the rubber stopper. Alternatively, any leak-free closure fabricated of non-reactive materials and

accommodating the necessary tubing fittings may be used.

2.2.14 Critical Orifices. Calibrated critical orifices capable of providing constant flow rates from

50 to 250 ml/min at known pressure drops. Sapphire orifice assemblies (available from O'Keefe

Controls Company) and glass capillary tubing have been found to be adequate for this

application.

2.2.15 Vacuum Gauge. 0- to 760-mm (0- to 30-in) Hg U-Tube manometer or vacuum gauge.

2.2.16 Pressure Gauge. Bourdon gauge capable of measuring the maximum air pressure at the

aspirator inlet (e.g., 100 psig).

2.2.17 Aspirator. A device capable of generating sufficient vacuum at the sample vessel to

create critical flow through the calibrated orifice when sufficient air pressure is present at the

aspirator inlet. The aspirator must also provide sufficient sample pressure to operate the FIA.

The sample is also mixed with the dilution gas within the aspirator.

2.2.18 Soap Bubble Meter. Of an appropriate size to calibrate the critical orifices in the system.

2.2.19 Organic Concentration Analyzer. An FIA with a span value of 1.5 times the expected

concentration as propane; however other span values may be used if it can be demonstrated that

they would provide more accurate measurements. The system shall be capable of meeting or

exceeding the following specifications:

2.2.19.1 Zero Drift. Less than

3.0 percent of the span value.

2.2.19.2 Calibration Drift. Less than

3.0 percent of span value.

2.2.19.3 Calibration Error. Less than

5.0 percent of the calibration gas value.

232

2.2.20 Integrator/Data Acquisition System. An analog or digital device or computerized data

acquisition system used to integrate the FIA response or compute the average response and

record measurement data. The minimum data sampling frequency for computing average or

integrated values is one measurement value every 5 seconds. The device shall be capable of

recording average values at least once per minute.

2.2.21 Chart Recorder (Optional). A chart recorder or similar device is recommended to provide

a continuous analog display of the measurement results during the liquid sample analysis.

2.2.22 Calibration and Other Gases. For calibration, fuel, and combustion air (if required)

contained in compressed gas cylinders. All calibration gases shall be traceable to NIST

standards and shall be certified by the manufacturer to

1 percent of the tag value. Additionally,

the manufacturer of the cylinder should provide a recommended shelf-life for each calibration

gas cylinder over which the concentration does nor change more than

2 percent from the

certified value. For calibration gas values not generally available, alternative methods for

preparing calibration gas mixtures, such as dilution systems, may be used with prior approval.

2.2.22.1 Fuel. A 40 percent H2/60 percent He or 40 percent H2/60 percent N2 gas mixture is

concentration varies significantly from a mean value.

2.2.22.2 Carrier Gas. High purity air with less than 1 ppm of organic material (as propane) or

less than 0.1 percent of the span value, whichever is greater.

2.2.22.3 FIA Linearity Calibration Gases. Low-, mid-, and high-range gas mixture standards

with nominal propane concentrations of 20-30, 45-55, and 70-80 percent of the span value in air,

respectively. Other calibration values and other span values may be used if it can be shown that

more accurate measurements would be achieved.

2.2.22.4 System Calibration Gas. Gas mixture standard containing propane in air, approximating

the undiluted VOM concentration expected for the liquid samples.

3. DETERMINATION OF LIQUID INPUT WEIGHT

3.1 Weight Difference. Determine the amount of material introduced to the process as the

weight difference of the feed material before and after each sampling run. In determining the

total VOM containing liquid usage, account for: (a) the initial (beginning) VOM containing

liquid mixture; (b) any solvent added during the test run; (c) any coating added during the test

run; and (d) any residual VOM containing liquid mixture remaining at the end of the sample run.

3.1.1 Identify all points where VOM containing liquids are introduced to the process. To obtain

an accurate measurement of VOM containing liquids, start with an empty fountain (if

applicable). After completing the run, drain the liquid in the fountain back into the liquid drum

(if possible), and weigh the drum again. Weigh the VOM containing liquids to

0.5 percent of

the total weight (full) or

-0.1 percent of the total weight of VOM containing liquid used during

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the sample run, whichever is less. If the residual liquid cannot be returned to the drum, drain the

fountain into a preweighed empty drum to determine the final weight of the liquid.

3.1.2 If it is not possible to measure a single representative mixture, then weigh the various

components separately (e.g., if solvent is added during the sampling run, weigh the solvent

before it is added to the mixture). If a fresh drum of VOM containing liquid is needed during the

run, then weigh both the empty drum and fresh drum.

3.2 Volume Measurement (Alternative). If direct weight measurements are not feasible, the

tester may use volume meters and flow rate meters (and density measurements) to determine the

weight of liquids used if it can be demonstrated that the technique produces results equivalent to

the direct weight measurements. If a single representative mixture cannot be measured, measure

the components separately.

4. DETERMINATION OF VOM CONTENT IN INPUT LIQUIDS

4.1 Collection of Liquid Samples.

4.1.1 Collect a 100-ml or larger sample of the VOM containing liquid mixture at each

application location at the beginning and end of each test run. A separate sample should be taken

of each VOM containing liquid added to the application mixture during the test run. If a fresh

drum is needed during the sampling run, then obtain a sample from the fresh drum.

4.1.2 When collecting the sample, ground the sample container to the coating drum. Fill the

sample container as close to the rim as possible to minimize the amount of headspace.

4.1.3 After the sample is collected, seal the container so the sample cannot leak out or evaporate.

4.1.4 Label the container to identify clearly the contents.

4.2 Liquid Sample VOM Content.

4.2.1 Assemble the liquid VOM content analysis system as shown in Figure 1.

4.2.2 Permanently identify all of the critical orifices that may be used. Calibrate each critical

orifice under the expected operating conditions (i.e., sample vacuum and temperature) against a

volume meter as described in Section 5.3.

4.2.3 Label and tare the sample vessels (including the stoppers and caps) and the syringes.

4.2.4 Install an empty sample vessel and perform a leak test of the system. Close the carrier gas

valve and atmospheric vent and evacuate the sample vessel to 250 mm (10 in.) Hg absolute or

less using the aspirator. Close the toggle valve at the inlet to the aspirator and observe the

vacuum for at least one minute. If there is any change in the sample pressure, release the

vacuum, adjust or repair the apparatus as necessary and repeat the leak test.

234

4.2.5 Perform the analyzer calibration and linearity checks according to the procedure in Section

5.1. Record the responses to each of the calibration gases and the back-pressure setting of the

FIA.

4.2.6 Establish the appropriate dilution ratio by adjusting the aspirator air

supply or substituting critical orifices. Operate the aspirator at a vacuum of at least 25 mm (1

in.) Hg greater than the vacuum necessary to achieve critical flow. Select the dilution ratio so

that the maximum response of the FIA to the sample does not exceed the high-range calibration

gas.

4.2.7 Perform system calibration checks at two levels by introducing compressed gases at the

inlet to the sample vessel while the aspirator and dilution devices are operating. Perform these

checks using the carrier gas (zero concentration) and the system calibration gas. If the response

to the carrier gas exceeds

0.5 percent of span, clean or repair the apparatus and repeat the

check. Adjust the dilution ratio as necessary to achieve the correct response to the upscale

check, but do not adjust the analyzer calibration. Record the identification of the orifice,

aspirator air supply pressure, FIA back-pressure, and the responses of the FIA to the carrier and

system calibration gases.

4.2.8 After completing the above checks, inject the system calibration gas for approximately 10

minutes. Time the exact duration of the gas injection using a stopwatch. Determine the area

under the FIA response curve and calculate the system response factor based on the sample gas

flow rate, gas concentration, and the duration of the injection as compared to the integrated

response using Equations 2 and 3.

4.2.9 Verify that the sample oven and sample line temperatures are 120

C and that the water

bath temperature is 100

4.2.10 Fill a tared syringe with approximately 1 g of the VOM containing liquid and weigh it.

Transfer the liquid to a tared sample vessel. Plug the sample vessel to minimize sample loss.

Weigh the sample vessel containing the liquid to determine the amount of sample actually

received. Also, as a quality control check, weigh the empty syringe to determine the amount of

material delivered. The two coating sample weights should agree within

0.02 g. If not, repeat

the procedure until an acceptable sample is obtained.

4.2.11 Connect the vessel to the analysis system. Adjust the aspirator supply pressure to the

correct value. Open the valve on the carrier gas supply to the sample vessel and adjust it to

provide a slight excess flow to the atmospheric vent. As soon as the initial response of the FIA

begins to decrease, immerse the sample vessel in the water bath. (Applying heat to the sample

vessel too soon may cause the FID response to exceed the calibrated range of the instrument, and

thus invalidate the analysis.)

4.2.12 Continuously measure and record the response of the FIA until all of the volatile material

has been evaporated from the sample and the instrument response has returned to the baseline

(i.e., response less than 0.5 percent of the span value). Observe the aspirator supply pressure,

FIA back-pressure, atmospheric vent, and other system operating parameters during the run;

235

repeat the analysis procedure if any of these parameters deviate from the values established

during the system calibration checks in Section 4.2.7. After each sample perform the drift check

described in Section 5.2. If the drift check results are acceptable, calculate the VOM content of

the sample using the equations in Section 7. Integrate the area under the FIA response curve, or

determine the average concentration response and the duration of sample analysis.

5. CALIBRATION AND QUALITY ASSURANCE

5.1 FIA Calibration and Linearity Check. Make necessary adjustments to the air and fuel

supplies for the FIA and ignite the burner. Allow the FIA to warm up for the period

adjust the back-pressure regulator to the value required to achieve the flow rates specified by the

manufacturer. Inject the zero- and the high-range calibration gases and adjust the analyzer

calibration to provide the proper responses. Inject the low- and mid-range gases and record the

responses of the measurement system. The calibration and linearity of the system are acceptable

if the responses for all four gases are within 5 percent of the respective gas values. If the

performance of the system is not acceptable, repair or adjust the system and repeat the linearity

check. Conduct a calibration and linearity check after assembling the analysis system and after a

major change is made to the system.

5.2 Systems Drift Checks. After each sample, repeat the system calibration checks in Section

4.2.7 before any adjustments to the FIA or measurement system are made. If the zero or

calibration drift exceeds

3 percent of the span value, discard the result and repeat the analysis.

5.3 Critical Orifice Calibration.

5.3.1 Each critical orifice must be calibrated at the specific operating conditions that it will be

used. Therefore, assemble all components of the liquid sample analysis system as shown in

Figure 3. A stopwatch is also required.

5.3.2 Turn on the sample oven, sample line, and water bath heaters and allow the system to reach

the proper operating temperature. Adjust the aspirator to a vacuum of 380 mm (15 in.) Hg

vacuum. Measure the time required for one soap bubble to move a known distance and record

barometric pressure.

5.3.3 Repeat the calibration procedure at a vacuum of 406 mm (16 in.) Hg and at 25 mm (1-in.)

Hg intervals until three consecutive determinations provide the same flow rate. Calculate the

critical flow rate for the orifice in ml/min at standard conditions. Record the vacuum necessary

to achieve critical flow.

NOMENCLATURE

area under the response curve of the liquid sample, area count;

area under the response curve of the calibration gas, area count;

236

actual concentration of system calibration gas, ppm propane;

1.830 X 10

-9

g/(ml-ppm);

total VOM content of liquid input, kg;

mass of liquid sample delivered to the sample vessel, g;

flow rate through critical orifice, ml/min;

liquid analysis system response factor, g/area count;

total gas injection time for system calibration gas during integrator

calibration, min;

VFj

final VOM fraction of VOM containing liquid j;

Vij

initial VOM fraction of VOM containing liquid j;

Vaj

VOM fraction of VOM containing liquid j added during the run;

VOM fraction of liquid sample;

WFj

weight of VOM containing liquid j remaining at end of the run, kg;

Wij

weight of VOM containing liquid j at beginning of the run, kg;

Waj

weight of VOM containing liquid j added during the run, kg.

7. CALCULATIONS

7.1 Total VOM Content of the Input VOM Containing Liquid.

7.2 Liquid Sample Analysis System Response Factor for Systems Using Integrators, Grams/Area

Counts.

RF =

CS q TS K Eq. 2

7.3 VOM Content of the Liquid Sample.

V =

AL RF Eq. 3

237

Procedure T - Criteria for and Verification of a Permanent or Temporary Total Enclosure

1. INTRODUCTION

1.1 Applicability. This procedure is used to determine whether a permanent or temporary

enclosure meets the criteria of a total enclosure.

1.2 Principle. An enclosure is evaluated against a set of criteria. If the criteria are met and if all

the exhaust gases are ducted to a control device, then the volatile organic materials (VOM)

capture efficiency (CE) is assumed to be 100 percent and CE need not be measured. However, if

part of the exhaust gas stream is not ducted to a control device, CE must be determined.

2. DEFINITIONS

2.1 Natural Draft Opening (NDO) -- Any permanent opening in the enclosure that remains open

during operation of the emission unit and is not connected to a duct in which a fan is installed.

2.2 Permanent Total Enclosure (PTE) -- A permanently installed enclosure that completely

surrounds an emission unit such that all VOM emissions are captured and contained for

discharge through a control device.

2.3 Temporary Total Enclosure (TTE) -- A temporarily installed enclosure that completely

surrounds an emission unit such that all VOM emissions are captured and contained for

discharge through ducts that allow for the accurate measurement of VOM rates.

3. CRITERIA OF A TEMPORARY TOTAL ENCLOSURE

3.1 Any NDO shall be at least 4 equivalent opening diameters from each VOM emitting point.

3.2 Any exhaust point from the enclosure shall be at least 4 equivalent duct or hood diameters

from each NDO.

3.3 The total area of all NDO’s shall not exceed 5 percent of the surface area of the enclosure's

four walls, floor, and ceiling.

3.4 The average facial velocity (FV) of air through all NDO’s shall be at least 3,600 m/hr (200

fpm). The direction of air through all NDO’s shall be into the enclosure.

3.5 All access doors and windows whose areas are not included in Section 3.3 and are not

included in the calculation in Section 3.4 shall be closed during routine operation of the emission

unit.

4. CRITERIA OF A PERMANENT TOTAL ENCLOSURE

238

4.1 Same as Sections 3.1 and 3.3 - 3.5.

4.2 All VOM emissions must be captured and contained for discharge through a control device.

5. PROCEDURE

5.1 Determine the equivalent diameters of the NDO’s and determine the distances from each

VOM emitting point to all NDO’s. Determine the equivalent diameter of each exhaust duct or

hood and its distance to all NDO’s. Calculate the distances in terms of equivalent diameters.

The number of equivalent diameters shall be at least 4.

5.2 Measure the total area (At) of the enclosure and the total area (AN) of all NDO's of the

enclosure. Calculate the NDO to enclosure area ratio (NEAR) as follows:

NEAR = AN/At

The NEAR must be

0.05.

5.3 Measure the volumetric flow rate, corrected to standard conditions, of each gas stream

exiting the enclosure through an exhaust duct or hood using EPA Method 2. In some cases (e.g.,

when the building is the enclosure), it may be necessary to measure the volumetric flow rate,

corrected to standard conditions, of each gas stream entering the enclosure through a forced

makeup air duct using Method 2. Calculate FV using the following equation:

FV = [QO - QI]/AN

where:

QO =

the sum of the volumetric flow from all gas streams exiting the enclosure

through an exhaust duct or hood

QI =

the sum of the volumetric flow from all gas streams into the enclosure

through a forced makeup air duct; zero, if there is no forced makeup air

into the enclosure.

AN =

total area of all NDO’s in enclosure.

The FV shall be at least 3,600 m/hr (200 fpm).

5.4 Verify that the direction of air flow through all NDO’s is inward. Use streamers, smoke

tubes, tracer gases, etc. Strips of plastic wrapping film have been found to be effective. Monitor

the direction of air flow at intervals of at least 10 minutes for at least 1 hour.

6. QUALITY ASSURANCE

239

6.1 The success of this protocol lies in designing the TTE to simulate the conditions that exist

without the TTE, i.e., the effect of the TTE on the normal flow patterns around the affected

emission unit or the amount of fugitive VOM emissions should be minimal. The TTE must

enclose the application stations, coating reservoirs, and all areas from the application station to

the oven. The oven does not have to be enclosed if it is under negative pressure. The NDO’s of

the temporary enclosure and a fugitive exhaust fan must be properly sized and placed.

6.2. Estimate the ventilation rate of the TTE that best simulates the conditions that exist without

the TTE, i.e., the effect of the TTE on the normal flow patterns around the affected emission unit

or the amount of fugitive VOM emissions should be minimal. Figure 1 may be used as an aid.

Measure the concentration (CG) and flow rate (QG) of the captured gas stream, specify a safe

concentration (CF) for the fugitive gas stream, estimate the CE, and then use the plot in Figure 1

to determine the volumetric flowrate of the fugitive gas stream (QF). A fugitive VOM emission

exhaust fan that has a variable flow control is desirable.

6.2.1 Monitor the concentration of VOM into the capture device without the TTE. To minimize

the effect of temporal variation on the captured emissions, the baseline measurement should be

made over as long a time period as practical. However, the process conditions must be the same

for the measurement in Section 6.2.3 as they are for this baseline measurement. This may

require short measuring times for this quality control check before and after the construction of

the TTE.

6.2.2 After the TTE is constructed, monitor the VOM concentration inside the TTE. This

concentration shall not continue to increase and must not exceed the safe level according to

OSHA requirements for permissible exposure limits. An increase in VOM concentration

indicates poor TTE design or poor capture efficiency.

6.2.3 Monitor the concentration of VOM into the capture device with the TTE. To limit the

effect of the TTE on the process, the VOM concentration with and without the TTE must be

within

10 percent. If the measurements do not agree, adjust the ventilation rate from the TTE

until they agree within 10 percent.

(Source: Repealed at _______________, effective ________________)

IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control Board, certify that the Board

adopted the above opinion and order on April 21, 2005, by a vote of 5-0.

Dorothy M. Gunn, Clerk

Illinois Pollution Control Board