ILLINOIS POLLUTION CONTROL BOARD
July
19, 2005
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
R05-20
EXEMPTIONS FROM
STATE
)
(Rulemaking
-
Air)
PERMITTING REQUIREMENTS FOR
)
PLASTIC INJECTION MOLDING
)
OPERATIONS
(35
ILL.
ADM. CODE 201.146))
CUMULATIVE EXHIBIT LIST
First Hearing:
July
1, 2005,
Chicago
Exhibit
1:
The Chemical Industry ofIllinois’
(CICI) first errata sheet including amendments to
proposed Section 201. 146(hhh) and a correction to the pre-filed testimony ofMr.
Lynne R.
Harris.
Exhibit 2:
Pre-filed testimony of Ms.
Lisa Frede on behalfof CICI.
Exhibit 3:
Pre-filed testimony ofMr. Lynne Harris on behalfofCICI,
including attached
Exhibits
1-11.
Exhibit 4:
Plastic Injection Molding Machine
—
Sequence of Operation Diagram.
ExhibitS:
Pre-filed testimony ofMs. Patricia F.
Sharkey on behalfof CICI.
Second Hearing:
July
15, 2005, Springfield
CICI Exhibit 6:
Second errata sheet and pre-filed testimony of Ms. Lisa Frede,
Mr.
Lynne
Harris, and Ms. Patricia Sharkey on behalfof CICI.
CICI Exhibit 7:
Sample ofspru and
associated plastic rurmer.
CICI Exhibit 8:
Sample ofplastic resin.
CICI Exhibit 9:
Sample ofend product.
CICI Exhibit
10:
Sample ofregrind.
CICI Exhibit
11:
Photograph of color mixer.
Agency Exhibit
1:
Prefiled testimony ofMr. Don Sutton on behalfofthe Environmental
Protection Agency (Agency).
I.
~
C C~5~-
Zo
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
2-.
\~
IN THE MATTER OF:
)
)
PROPOSED
AMENDMENTS
TO
)
EXEMPTIONS FROM STATE
)
R 05-20
PERMITTING REQUIREMENTS
)
FOR PLASTIC INJECTION MOLDING)
OPERATIONS
)
(35 III. Admin. Code 201.146)
)
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100
West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA ELECTRONIC FILING)
(PERSONS
ON
ATtACHED SERVICE LIST)
PLEASE TAKE NOTICE that on July
11, 2005, I filed with the Office of the Clerk of the
Illinois Pollution
Control Board by
eiectronic filing the SECOND
ERRATA SHEET and PRE-
FILED TESTIMONY ON BEHALF OF THE CHEMICAL INDUSTRY COUNCIL OF
ILLINOIS,
a
copy of which
is hereby served
upon you.
Dated:
July
11, 2005
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
By:
Is/ Patricia F. Sharkev
One of its Attorneys
Patricia F. Sharkey
Mayer, Brown, Rowe & Maw LLP
71
South
Wacker Drive
Chicago, Illinois
60606-4637
(312)782-0600
CERTIFICATE OF SERVICE
I, Patricia F. Sharkey,
an attorney, hereby certify
that I have served the Second Errata
Sheet and Prc-Filed Testimony on Behalf of the Chemical Industry Council of Illinois upon:
Ms. Dorothy M.
Gunn
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(Electronic Mail)
Matthew Dunn, Chief
Division ofEnvironmental
Enforcement
Office of the Attorney General
188 West Randolph Street, ~
floor
Chicago, Blinois 60601
(U.S. Mail)
Donald Sutton
Manager, Permit Section
Division of Air Pollution
Bureau of Air
Illinois Environmental Protection Agency
1021
North Grand Avenue East
Post Office Box
19276
Springfield, Illinois 62794-9276
(U.S. Mail)
Charles E. Matoesian
Division of Legal
Counsel
Illinois Environmental Protection
Agency
1021
North Grand Avenue East
Post Office Box
19276
Springfield,
Illinois 62794-9276
(U.S. Mail
and E-Mail)
Office ofLegal Services
Illinois Department ofNatural Resources
One Natural Resources Way
Springfield, Illinois
62702-127 1
(U.S. Mail)
as indicated above, by e-mail and/or by depositing
said document in
the United States Mail,
postage prepaid, in
Chicago, Illinois on
July 11,2005.
Patricia F.
Sharkey
Mayer, Brown, Rowe & Maw LLP
190 South LaSalle Street
Chicago, Illinois
60603-344 1
(312) 782-0600
Is!
Patricia F.
Sharkey
Patricia F.
Sharkey
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
EXEMPTIONS FROM STATE
)
PERMITTING
REQUIREMENTS
)
FOR PLASTIC INJECTION MOLDING)
R 05-20
OPERATIONS
)
(35 III. Admin. Code 201.146)
)
CHEMICAL INDUSTRY COUNCIL
OF ILLINOIS’
SECOND ERRATA
SHEET
The Chemical Industry Council of Illinois (“CICI”), by its
attorneys Mayer,
Brown, Rowe & Maw LLP,
hereby submits the following corrections and
amendments to
documents previously filed
in this proceeding:
AMENDMENT TO PROPOSED REGULATORY LANGUAGE
CICI proposes to
amend the text
ofits
regulatory
language, as proposed in its
original
filing on April
19, 2005, as follows:
TITLE 35:
ENVIRONMENTAL PROTECTION
SUBTITLE B:
AIR POLLUTION
CHAPTER
1:
POLLUTION CONTROL BOARD
PART 201
PERMITS AND GENERAL PROVISIONS
Section
201.146
Exemptions from State Permit Requirements
Construction or operating permits, pursuant to Sections 201.142,
201.143, and 201.144 of
this Part, are not required for the classes of equipment
and activities listed below in
this
Section.
The permitting exemptions
in
this
Section do not
relieve the owner or operator
of any source
from any obligation to comply with any other applicable requirements,
including the obligation to obtain
a
permit pursuant to Sections 9.1(d) and 39.5 of the
Act, Sections
165,
173, and 502 of the Clean Air Act
or any other applicable permit or
registration requirements.
hhh)
Plastic injection, compression,
and transfer molding equipment with an annual
through-put not exceeding 5,000 Ions of plastic resin and associated plastic
resin heedjing
loading,
unloading~conveying, mixing, storage, grinding.
~anuiatin2,
and drying equipment and associated
mold release and mold
cleaning a2ents.
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL
OF ILLINOIS
By:
!s/ Patricia F.
Sharkey
One of Its Attorneys
Dated:
July 11,2005
Patricia F.
Sharkey
Mayer, Brown, Rowe &
Maw
~
71
South Wacker Drive
Chicago, Illinois
60606-4637
(312) 782-0600
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
IN
THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
EXEMPTIONS FROM STATE
)
PERMITTING REQUIREMENTS
)
FOR PLASTIC INJECTION MOLDING)
R 05-20
OPERATIONS
(35 III. Admin. Code 2011146)
)
PRE-FILED
TESTIMONY
ON
BEHALF OF
THE
CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
In response to questions posed at the first hearing in this matter on July 1,2005,
CICI
is herewith providing certain requested information. CICI witnesses, Lynne Harris,
Lisa Frede,
and Patricia Sharkey, will be present
to answer questions regarding these
responses at the
July
15,
2005 hearing in Springfield.
1.
Size of Facilities Exempted Under This Proposal
At
the July
1,2005 hearing, the Board
asked how
many
PIM machines may be
located at
a given
PIM facility. CICI has not
found any
studies or data directly addressing
this
question.
However, CICI can state that its
member facilities have between 4 and 70
machines.
Because the size ofPIIM machines varies, resin throughput is
a better indicator of
the volume of emissions associated with
a given facility.
CICI
member facilities have
annual PIN resin throughput ranging
from
100 tons/yr to
3,250 tons/yr.
Average facility
annual PIN resin
throughput is approximately
500 tons/yr.
CIDBOI
1285013.1
I
1-Jul-05
15:28
2.
Estimated Volume of PIM Emissions Statewide in Illinois.
The
Board asked what volume of emissions would be exempt from permitting
under this
exemption.
A
broad estimate ofthe
total volume of emissions generated by
PIN processes statewide can be
derived by first multiplying the number of facilities in
Illinois by the
average volume
of resin processed per facility, and then multiplying that
number by
an appropriate emission factor.
As indicated in Mr.
Harris’ testimony, a worst
case VOM emission factor is 0.4 lb/ton of resin processed.
If we add to that a worst case
emission factor of 0.4 lb/ton of resin processed for the use ofrelease or cleaning agent, as
discussed in Section
5
below, we arrive at a conservative
overall VOM emission factor of
0.8
lb/ton of resin used.
Using the
above information
and the previous
testimony that approximately 500
PIN facilities
are located in Illinois, the formula for calculating statewide VOM
emissions associated with PIN is
as follows:
500 facilities
X
500 tons resin
Iyr
=
250,000 tons resin/yr
250,000 tons/yr
X
0.8
lb VOM /ton resin
=
100 tons VOM /yr
CICI believes
100
tons per year
is
a reasonable worst case estimate of the total
volume of VOM emissions
generated statewide by PIN facilities in Illinois.
We note that
this equates to
0.2
tons of
VOM
emissions per facility per year.
We further note that not
all of the approximately 500 PIN facilities in Illinois will be exempted from
state
permitting under the proposal
in this rulemaking.
In response to the Board’s question
regarding the number of PIM facilities that have no other processes, such as coating,
SPI
did
a rough survey of its
members and
determined that approximately 80
of its
members in the PIN industry do not perform
other processes at the their facilities.
This
2
CIDBOI
1285013.1
11-Jul-05
~5:28
indicates that around 20
of the approximately 500 Illinois PIN facilities will
not be
covered by this exemption. Thus total statewide
emissions ofVOM covered by this
exemption are actually likely to
be on the order of 80 tons per year.
To answer any concern the Board may have that there may be larger volumes of
emissions involved,
CICI has proposed in its Second Errata Sheet to limit the proposed
exemption
to PIN facilities with no more than 5,000 tons/yr ofresin
processed.
Ifevery
facility in Illinois processed 5,000 tons of resin per year
(an extraordinary assumption),
the total
VOM emissions
subject to this exemption would
be
1,000 tonsfyr.
That equates
to approximately 2 tons of VOM per year per facility.
3.
Location of NM facilities
in
Illinois (Attainment
Areas/
Non-
Attainment Areas)
The Board asked about the location of PIM facilities in
the State
and whether they
were primarily located in Attainment or Non-Attainment Areas.
To answer this question,
CICI reviewed the locations ofthe Illinois facilities
listed in
the Plastic News “2005
Survey of North American Injection Molders”
and the locations of CICI member
facilities, and determined that
14
ofthose PIN facilities are located in
Attainment
Areas and
the remaining 86
are
located in Non-Attainment Areas.
Of those located in
Non-Attainment Areas, all are located in
areas which have been designated
as Moderate
NAA under the new 8-hour ozone standard.
4.
Estimated Emission from Resin Handling Operations:
Loading,
Unloading,
Conveying,
Storage,
Mixing, Grinding, Drying
As indicated at the July
1st hearing, CICI has attempted to find
studies and
other
sources of information on the volume and type of emissions
generated by the various
activities
associated with resin
handling operations. We have found no studies directly
3
CHOBOI
1285013.1
11-Jul-05 15:28
addressing or quantifying emissions from
these activities. This is actually not
surprising.
As
indicated in Mr.
Harris’ June
16, 2005 Pre-Filed Testimony, emissions from the
injection molding process as a whole had not been quantified prior to 1996.
This lack of
quantitative information
on emissions may also be explained by the nature of the
materials involved and the process. The resin
and scrap are hardened plastic material at
ambient and low temperatures. Furthermore, these ancillary activities
operate under
negative pressure, thus emissions from the movement ofresin, the drying ofthe resin and
the grinding of scrap plastic are
largely, if not entirely, drawn back into the process.
The following information on
how and where emissions
are formed in this
process may assist the Board
in understanding that emissions from these ancillary
activities are minimal.
a.
VOM
and
HAP
Emissions
VOM and HAP emissions from plastic resin
are directly related to
temperature.
As found in the SPI studies
accompanying Mr. Harris’ Pre-Filed Testimony (Group
Exhibit 3), “emission
rates are
directly correlatable with the melt temperature of the resin
involved.”
(Group Exhibit
3, Harris Exhibit 3, p. 56.)
Thermoplastic resins have melt
temperatures
in the range of 300 F
—
600
F.
(Group Exhibit
3, Harris Exhibits
3
—
6.) The
SPI studies demonstrate that even
at the melt temperatures reached in the extruder screw
VOM and HAP emissions are low. Thus,
the brief drying of the resin at far lower
temperatures to remove moisture from
the pellets can be
presumed to
generate only a
fraction of those emissions. The ancillary resin loading, conveyance and
mixing at
ambient temperatures can be presumed to be
even lower.
4
CHDBOI
1285013.1
11-Jul-05
15:28
To
a varying degree,
all plastic resins take on
moisture when exposed to relative
humidity.
Even
a minimal amount of moisture
in
many plastics can negatively affect
molding characteristics.
Dryers operated at low
temperatures are often utilized to remove
such moisture
from plastic resin prior to the plastic injection molding process. The dryers
blow heated ambient air over the plastic resins.
The temperatures used for drying plastic
resins are generally less
than
one half of the melting temperature of the plastic resin
involved. (See attached Table
5.1
from the
Modern Plastics Handbook.)
Although CICI
has not
been able to
find any data on emissions from
dryers, emissions ofVOM from
plastic resin at the relatively low temperatures used in the drying process can be
presumed to result in
a small percentage ofVOM or particulate emissions generated by
the overall process.
The conclusion that VOM emissions from resin pellets handled at ambient
temperatures are minimal is confirmed by the polyethylene study (Group Exhibit 3,
Harris Exhibit 5) which measured emissions of VOC from the hopper
area and found that
emissions from this
area accounted for less
than 2
ofthe total VOCs measured. (Ii,
p. 577.)
b.
Particulate Matter Emissions
There is an
assumption that the movement of resin, even at ambient temperatures,
generates some level of particulate matter (“PM”).
However, CICI has been unable to
find any EPA or industry studies of this subject.
To provide the Board with
some perspective on the level ofPM present at a PIM
facility, CICI Regulatory Affairs Director Lisa Frede visited one of its member facilities
on
July 7,
2005.
Ms.
Frede will provide testimony
at the July
15, 2005
hearing that she
5
CHDBOI
1285013.1
I 1-Jul-05
15:28
found it to be exceedingly clean, with no dust or film on the floor or the equipment,
including the grinder or granulator, which
is presumed to be the piece ofequipment most
likely to produce PM.
She
will
also testify
that none of the employees in this workplace
wear respiratory protection, indicating the indoor particle levels meet OSHA standards
without such protection.
One of the primary reasons that PM is so low in
these facilities
is that product specifications require that foreign
material not enter the process. Another
reason is that injection
molding and the associated resin and scrap handling are almost
entirely enclosed operations which take place under negative pressure.
Ms.
Frede will provide photographs and her observations on the injection molding
process.
(
See
attached Photos Nos.
1
—
9.)
As
can be
seen from the attached photographs,
the resin is brought to the machine in
a cardboard “gaylord” box
and fed via vacuum hose
into the dryer and the hopper. The screw extruder and the mold are entirely enclosed
processes. When the mold opens, the product drops on to
an open conveyor belt, which
can be seen to have little or no dust on it. Ms.
Frede will testify that the plastic product
and plastic
scrap leaving
the mold are extremely clean.
The scrap plastic
“runners” and
“sprus” are removed from the mold by
way of a robotic arm which drops the scrap into
the grinder or granulator.
As can be
seen from
the attached photos, the grinder area has
little or no dust.
Again, this is because the grinder operates under negative pressure and
both
the scrap plastic and
any associated
dust are drawn into the grinder.
Closing the
loop, the granulated plastic, while somewhat dusty, is fed
directly from the grinder back
to the hopper to be reused in the process.
This takes place by
way of a vacuum hose.
Thus, the granulated plastic is never exposed to ambient air.
6
CHDBOI
1285013.1
I 1-Jul-05
15:28
Given the fact that these processes are so
clean, there is
little likelihood that
VIM
machines would be
vented outside the workplace. CICI’s survey of its member facilities
indicates that none ofthose facilities vent PIM machines outside the workplace. Thus
there is little likelihood of PIM emissions entering the outside environment. To the extent
that
a PM
facility has emissions of concern within the workplace, they are subject to
OSHA standards and are not regulated under the Environmental Protection Act or air
pollution control permits issued under the Board’s rules.
At the July
15,
2005 hearing, Ms. Frede will be happy to
answer any questions
regarding her observations at this facility. CICI will
also provide samples of a typical
resin, typical “runner” and
granulated scrap, and
a typical PIM plastic productwhich Ms.
Frede
observed being handled and processed at this facility.
5.
Mold Release Agents and Cleaning Agents
Mold release agent and/or mold cleaner are sometimes used in the plastic
injection molding
(PIM) process.
Mold release agent leaves a very thin layerof a “non-
stick” substance
on the surface ofthe mold to help parts fall from
the mold as it opens at
the end of the cycle.
Mold
cleaner is used to remove built-up residue from the mold
surface.
Some CICI member facilities have designed their molds to avoid use ofmold
release altogether, but
still use mold cleaner.
Historically, the volatile organic matter content of aerosol mold release agents and
mold cleaning products was in excess of90.
However, mold release agents
and mold
cleaning products
are now available in water-based formulations and in formulations that
utilize non-photochemically reactive chemicals as carrier solvents.
7
CHDBOI
1285013.1
11-Jul-05
15:28
Both mold release agent and mold cleaner are generally used in
12-
16 ounce
aerosol cans.
Based
on data collected from CICI
member facilities, VOM emissions
from mold release agent and/or mold cleaner range from less than 0.1
lbs/ton of resin
processed up to 0.4 lb/ton ofresin
processed.
The combined usage of mold release
agents
and mold cleaner at a PIM facilitycan be conservatively estimated to
generate 0.4
lbs of VOM per ton of resin processed.
In general, facilities try to design
molds to minimize the use of mold release
agents and mold cleaner because it is very inefficient to stop the PIM machine
periodically to apply either release
agent or cleaner to the mold.
Well-designed molds
require only a minimal amount of either substance.
When possible, facilities
try to apply
mold release agent or mold cleaner only
at the beginning of a production shift.
6.
Definitions of
“Compression Molding” and “Transfer Molding”
In response to
a question from
the Board, CICI
is providing the following
definitions which
appear on The Society of the Plastics Industry, Inc. (“SPI”) website at
http://www.plasticsindustry.org.:
“Compression molding
is the most common method of forming thermosetting
materials. It is not generally used for thermoplastics.
“Compression molding is simply the squeezing of a material into a
desired shape by application of heat and pressure to the material in
a mold.
“Plastic molding
powder, mixed with
such materials or fillers as
woodflour and cellulose
to strengthen or give other added qualities
to the finished product, is put
directly into the open
mold cavity.
The mold is then closed, pressing down
on the plastic
and causing
it to flow throughout the mold. It is
while the heated mold is closed
that the thermosetting material
undergoes
a chemical
change which
permanently hardens
it into the shape of the mold. The three
compression
molding factors
--
pressure, temperature
and time
the
8
CHDBOI
1285013.1
11-Jul-05
25:28
mold is closed
--
vary with the design ofthe finished article and
the material being molded.”
“Transfer molding
is most generally
used for thermosetting
plastics. This method
is like
compression molding in that the
plastic is cured into an
infusible state in
a mold under heat and
pressure. It differs from compression molding in that the plastic is
heated to
a point of plasticity before it reaches the mold and is
forced into a closed mold by means of a hydraulically
operated
plunger.
“Transfer molding was developed to
facilitate the molding of
intricate products with small
deep holes or numerous metal
inserts.
The dry mold compound used in compression molding sometimes
disturbs the position of the metal inserts
and the pins which form
the holes. The liquefied plastic material in transfer molding flows
around these metal parts without causing them to
shift position.”
As stated in the first hearing,
CICI
is no longer proposing that these processes be
included in the proposed exemption and
does not plan to provide additional testimony
regarding these processes.
Dated:
July
11, 2005
Respectfully submitted,
CHEMICAL INDUSTRY COUNCIL OF ILLINOIS
By:
/s/ Patricia F. Sharkey
One of its Attorneys
Patricia F. Sharkey
Mayer,
Brown, Rowe & Maw LLP
71
South Wacker Drive
Chicago, Illinois
60606-4637
(312) 782-0600
9
CHDBOI
1285023.1
11-Jul-05
15:28
Modern
Plastics
Handbook
Modern Plastics
and
Charles A. Harper
Editor In ChI.f
Technology Seminars,
Inc.
Lutherville,
Maryland
McGraw-Hill
New York
San Francisco
Washlnglon,
D.C.
Auckland
Bogoil
Caracas
Lisbon
London
Madrid
Mexico
City
Milan
Montreal
NOW
Delhi
San Juan
Singapora
Sydney
Tokyo
Toronto
Library of Congress Cataloging4n-Pubflcation
Data
Modem plastics handbook
I
Modem
Plastics,
Charles A. Harper (editor in chief).
p.
cm.
ISBN 0-07-026714.6
1.
Plastics.
I.
Modem Plasties.
H.
Harper,
Charles A.
TA455.P5
M62
1999
668.4—dc2l
99-056522
CIP
McGraw-HiU
A Division
of
The McGraw-HillCompanies
Copyright © 2000 by The McGraw-Hill Companies,
Inc.
Printed
In the
United
States
ofAmerica. Except as permitted under the
United States
Copyright
Act
of 1976,
no
part
of this
publication
may
be
reproduced
or distributed in
any form
or by
any
means, or
stored
in a
data
base
or
retrieval system, without
the
prior
written
permission of
the
publisher.
1
2
3
4
5
6
7
8
9
0
DOC/DOC
0
6
5
4
3
2
1
0
ISBN 0-07-026714.6
The
sponsoring editor of this
book
was Robert Esposito.
The editing
supervisor was DavidE. Fogarty,
and
th. production supervisor was
Sherri Souffrance. It was setin New Centwy Schoolbookper
the
MET
design by Paul
Sconari and
Deirdre Sheean ofMcGraw-Hill’s
Professional Book Group, in Rightstown, NJ.
Printed and
bound by B. R. Donnelley & Sons Company..
®
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5.6
Chapter
FIve
TABLE
8.1
Suggested Otying Conditions for Generic RsslneM
Water
Maximum
Tnt..,s.~,
Material
absorption,
wster,*
G0
Tt,~.
m,Wths.
°C
Pew.
°c
‘ewe
h
Acrylonitrile
butsdiene
a tyrene
(AESI
0.26-0.40
0.20
226
280
88
3-4
Acetal
0.25
—
—
200
98
1-2
AcrylIc
0.20—0.30
0.08
190
235
82
1—2
Polyamid.-6
(nylon)
(rAG)
1.60
0.16
270
290
82
4—S
Polysmlde.6, 6 (nylon)
(PA4,6)
1.60
015
285
265
82
4-6
Polycarbonate
(PC)
0.20
0.02
290
300
120
8-4
Polybutylene
tsrephthalate PBT)
0.08
0.04
—
240
126
2-2
Polyethylene
terephthalste
(PE’l’)
0.10
0.005
260
255
160
4-4
Poiyetherimide
(PEI)
0.26
—
—
870
165
4—6
High.dsnaity
polyethylene (IIDPE)
0.01
—
210
250
Low.d
entity
polyethylene
(LDPE)
0.01
—
ISO
205
Linear low-density
polyethylene
(LLDPE)
0.01
—
260
220
—
—
Polyphenylene
oxide IWO)
0.07
—
250
275
100
2—3
Polypropylene
PP)
0.01
—
288
255
—
—
Polystyrene (PS)
0.08
—
210
220
—
—
High-impact
polystyrene
(HIPS)
0.10
—
235
280
—
—
Polyphenylsne
sulfide
(PPS)
—
330
140
2—8
Polysulrone (PSU)
0.30
0.06
345
860
185
3—4
Polyurethane
(PU)
0.10
0.03
206
205
82
2.-S
PU (slsstomers)
0.07
0.08
200
205
100
2—8
r-PVC (polyvinyl
chloride)
0.10
0.07
185
196
—
—
p-PVC
(polyvinyl chloride)
0.02
—
175
150
—
—
Styrene acrylonitrile (SAN)
0.08
0.02
215
245
82
8—4
While
thermoplastic
polymers
soften
at
7’,,
and if semicrystalline,
melt
at
T,,~
cross-linked
polymers
do
not
melt
and
flow
(Fig.
5.2c5).
Lightly
cross-linked
polymers
soften
as
the
temperature
exceeds
7’,,
but they remain
rubbery
solids until
the polymer decomposes. Highly
cross-linked polymers
often
do not even
soften and retain a high mod-
ulus until
reaching the decomposition temperature. Thermoset resins,
like unsaturated
polyester,
epoxy, and polyurethanes, have varied lev-
els
of cross-linking.
However,
thermoplastic resins can be modified to
contain few cross-links; lightly cross-linked polyethylene (XLPE) often
improves the
mechanical properties
of rotomolded parts.
Some
therrnoplastics
will
decompose
before
they
melt
and
flow.
Extremely long polymer chains combined with intermolecular attrac-
tions
prevent
conventional
melt
processing
of
ultrahigh-molecular-
&taterial
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into pellets
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be
used
to mold
parts.
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S
EXHIBIT
I
o.tl
I
ll
3’
QcX’2071P
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
EXEMPTIONS FROM STATE
)
PERMITTING REQUIREMENTS
)
FOR PLASTIC INJECTION MOLDING)
R 05-20
OPERATIONS
)
(35 III. Admin. Code 201.146)
)
PRE-FILED TESTIMONY OF DONALD E. SUTTON ON BEHALF OF THE
ILLINOIS
ENVIRONMENTAL PROTECTION AGENCY
I am Donald E.
Sutton, P.E.
I have been manager
of
the manager~f
the Division ofAir
Pollution Control Permit Section since July 1991,
The following is my testimony that
provides the Agency’s view ofthis proposed rulemaking.
PROPOSAL DEVELOPMENT
In 1996,
the Board adopted revised rules providing
to expand, clarify and modifythe list
ofemission units
and activities that
are exempt from state air permitting requirements
specified at 35
Ill.
Adm.
Code 201.142, 201.143, and 20L 144.
Amendments to
Exemptions From
State Permit Requirements:
35
Ill. Adm.
Code 201
and 211, R96-17
(effective July 31,
1998).
These amendments
updated terminology and certain
amendments
are intended to clarify the types ofactivities or emission units thatare
covered by aparticular exemption such as the exemption forfuel combustion equipment.
In 1997, Section 39 of the Act (415
ILCS
5Iet.
seq.) was amended to establish a
4fetime
permit program. Pursuant to P.A.
90-367, effective June
17, 1998, the Board adopted
revised rules providing that emission sources not
subject to
Section
39.5
of
the Actor
required to have a federally enforceable state operating permit (“FESOP”)
shall have
operating permits that are required to be renewed
only upon request by the Agency or if
circumstances
warrant a
revised permit.
Amendments to General Permitting Provisions
to Require Perpetual Permits for Certain Sources:
Amendment to
35 Ill.
Adm. Code 201,
R98-13
(June
17,
1998).
Circumstances requiring a revised operating permit or
construction permit include change in ownership, construction or modification of an
emission unit
at a source pursuant to
Section 201.169(c).
“Construction” is defined as
“commencement ofon-site fabrication, erection or installation ofan emission source
or
of air
pollution control equipment.”
35
Ill.
Adm.
Code 201.102.
In 2003, the Board adopted rules to
amend its
permitting rules for the control ntair
pollution
section 201.142
and add section 201.170 (35 ill. Adm.
Code 201.142).
The
~
I
adopted rules exempted certain smaller emissions
sources from the requirement for
owners and operators to
obtain new construction permits
that were required by Section 39
ofthe Act (415 ILCS
5/39
(2000)) each time the site ofsmall
emission units are changed.
Amendments to
General Permitting Provisions for Portable EmissionUnits:
Amendments to 35 Ill.
Adm.
Code 201, R02-10
(February 6,2003).
Earlier this year, the Agency and the Illinois Environmental Regulatory Group (IERG)
jointly proposed to the Board additional categories to the permit exemptions in Section
201.146.
This prior rulemaking, which the Board has docketed R0S-l9, includes four
additional categories ofpermit exemptions will allow more efficient allocation ofIllinois
EPA resources during
a time of budget concerns.
The proposed additions
to
Section
201.146
are below:
a.
Replacement or Addition ofAir Pollution Control Equipment for Existing
Emission Units
—
Proposed Section 201. 146(hbh).
b.
New Emission Units and Modifications to Existing Emission Units at
Facilities with Federally Enforceable State Operating Permits
-
Proposed
Section 201.146(iii).
c.
New Emission Units or Modifications to Existing Emission Units
at
Permitted Sources That Are Not Major Sources or FESOPs
-
Proposed
Section 201. l46(jjj).
d.
Insignificant Activities at Clean Air Act Permit Program Sources
-
Proposed Section
201.146(kldc).
PROPOSAL
This
proposed rulemaking
(RO5-20)
would seek to add one more category to
the permit
exemptions
in Section 201.146 for plastic injection molding operations using 5,000 tons
of plastic resin per year orless.
This exemption does not threaten the public health tr
welfare.
The Agency understands that the primary effect ofthe proposed amendment is to
expand
the list ofactivities and
emission units that would qualify for exemption from state air
permitting requirements by adding a new category ofactivities
or emission units forthe
exemptions.
The activities and emission units, which are proposed for exemption, are
based on the historical experience ofthe Agency that such emissions units should not
merit permitting going forward as the emissions from the units or activities are minimal.
Further,
individual information on these activities will not be needed for purposes ofair
quality planning.
The amendment to Section 201.146 exempts from state construction and operating
permitting the plastic injection molding equipment with an annual through-put not
exceeding
10,000,000 pounds of plastic resin and associated plastic resin loading,
unloading, conveying, mixing, storage, grinding, and drying equipment and associated
mold release and mold cleaning agents.
The Agency has reviewed the proposed language
and has determined that these emission units are not subject to any federal New Source
Performance Standards (NSPS) under 40 CFR 60 or to
subject to any federal National
Emission Standards for Hazardous Air Pollutants (NESHAP) under 40 CFR 61
or 63.
The Agency also believes that the proposed amendments
do not alter or affect the liability
of an owner or operator of such plastic injection molding machines for compliance with
emission standards and other requirements that apply to such emission units or activities,
either individually orin conjunction with other emission units or activities constructed,
modified or located at the source.
ECONOMIC REASONABLENESS AND TECHNICAL FEASIBILITY
It is the Agency’s opinion that the proposed amendments expand the list ofexemptions
from state air permit requirements.
Thus, this proposal does not pose any issues with
respect to technical feasibility.
The additional exemptions will not significantly impact
the effectiveness ofthe permit program and may help focus attention on the more
“important emission units”.
I have been asked in previous hearings before the Board, specifically during Rulemaking
R05-19, about the cumulative effect ofexempting a large number ofsources ofair
pollution based on low or “de mjnus” emission levels.
This
question was also brought
during the previous hearing for this Rulemaking (R05-20).
To address this question,
there are a number ofregulatory schemes that would remain applicable in which this new
exemption
from permitting will have no effect.
For example, a determination whether a
source is considered to be major under USEPA regulations is dependent on the potential
emissions of a source
from all emission units regardless ofthe state permitting
requirements
upon that source or those units.
The state of Illinois does not have a right to
override
a federal requirement, such as New Source Review or Title V permitting.
There
could be a point in time that if you have enough emission units that are exempt from the
requirements to obtain
a state permit, that you
could actually trigger a higher level
requirement.
The Chemical Industry Council ofIllinois
(CICI) will provide testimony
that the emissions from these sources are approximately between a halfa ton per year to
two tons per year and most regulatory triggers, besides hazardous air pollutants
(HAP),
will be in
the 100 ton per year level.
Most ofthe sources in Illinois with Lifetime State
Operating permits have permitted emissions less than 25
tons per year of all pollutants
and actual emissions range from two
to
five tons per year.
We currently have 6,800
permitted sources in Illinois.
Ofthat total, we have roughly 4,900 sources that have
permits that keeps their emissions to
less than 25 tons per year.
As an economic matter the proposal will reduce costs as the amendments
expand the list
ofexemptions and many affected sources will be relieved of the requirement to obtain
a
state permit.
A cost
savings will result as those sources which no longer require permits
will be relieved of the need to collect data, prepare permit applications and
submit permit
fees.
The loss ofpermit fees should not affect the Agency, as the loss ofrevenue from
eliminating permitting of these sources will be matched by the savings by eliminating the
cost ofreviewing suchpermit applications.
The sources most affected by this proposed
rulemaking currently pay the minimum amount ofair pollution
operating permit fees or
the minimum construction permit application
fees yet the processing ofapplications for
suchproposed activities or emission units covered by this proposed amendment may take
almost as long to process as the projects for activities or emission units that will remain
subject to the construction and operating
permit requirements.
Another question raised in the previous hearing before the Board for this
rulemaking was
whether this proposal would
cause more plastic injection molding businesses to come to
Illinois
and whether this would have an
impact on increasing emissions
from this
industry.
The regulatory burden on this industry to obtain air pollution control permits
is
currently not that
great and should not have been a deterrent to the plastics industry.
These types of sources generally would have a Lifetime State operating permit and would
pay the minimum construction permit application
and operating site fees.
Other states
within USEPA’s Region
5
already have similar permitting exemptions for this industry as
the one proposed in this amendment.
We agree with Ms.
Sharkey’s response to this same
question during the previous hearing.
At the July
1, 2005
hearing for this rulemaking, Anand Rao from the Board’s technical
unit asked the Agency whether we view plastic injection molding as an
extrusion
operation.
It is the Agency’s view that injection molding is a different type ofoperation
from
extrusion, and thus the Agency does not view injection molding machines as being
exempt from permitting under the extruder exemption found in
201.146(cc).
The Agency is willing to
answer any questions about theseproposed amendments or
address any comments
you may have.
STATE OF ILLINOIS
)
)SS.
COUNTY OF SANGAMON
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Illinois Environmental
Protection Agency’s First Correction to
the Transcript ofthe Hearing held July 1,
2005
conceming the Amendments to 35
Ill. Adm.
Code 201.146
and Pre-filed Testimony ofDonald E.
Sutton on behalf ofthe Illinois Environmental Protection Agency upon the person to whom it is
directed, by placing it in
an envelope addressed
to:
TO:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
SEE ATTACHED SERVICE LIST
OFFICIAL
SEAL
~
CYNThIAL WOLFE
~
NOTARY
PUBLIC,
STATE OF IWNOIS
~MY
COMMIS8ION EXPIRES
3-20.2007
2
Amy Antoniolli, Hearing Officer
Illinois Pollution Control
Board
James R. Thompson Center
100 W.
Randolph Street, Suite 11-500
Chicago, Illinois 60601
TO BEFORE ME
and mailing it by First
Class Mail from
Springfield,
Illinois on July
11, 2005, with sufficient
postage affixed.
SUBSCifiBED AND SWORN
this
11th
dayofJuly, 2005
Notary Public
THIS
FILING IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST R 05-20
Office ofLegal Services
Illinois Department ofNatural Resources
One Natural Resources
Way
Springfield, Illinois 62702-1271
Matthew Dunn, Chief
Division of Environmental
Enforcement
Office ofthe Attorney General
188 West Randolph Street, ~
Floor
Chicago, Illinois 60601
Patricia F.
Sharkey
Mayer, Brown, Rowe & Maw LLP
71
South Wacker Drive
Chicago, Illinois 60606-4637
Heidi E.
Hanson
H. E.
Hanson, Esq. P.C.
4721
Franklin Avenue Suite
1500
Western Springs, Illinois 60558-1720
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PROPOSED AMENDMENTS TO
)
EXEMPTIONS FROM STATE
)
PERMITTING REQUIREMENTS
)
FOR PLASTIC
INJECTION MOLDING)
R 05-20
OPERATIONS
)
(35 III.
Admin. Code 201.146)
)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY’S
FIRST
CORRECTION
TO THE TRANSCRIPT OF THE HEARING
HELD JULY 1,
2005
CONCERNING THE AMENDMENTS TO 35 ILL. ADM. CODE 201.146
NOW COMES the Illinois Environmental Protection Agency (“Illinois EPA”), by
and through its attorney Charles Matoesian, and submits this first correction to the
transcript for the hearing held July
1, 2005 in the Matter of:
Amendments to 35
Ill. Adm.
Code 201.146.
The Illinois EPA proposes the following amendment to the transcript.
On page 47 ofthe transcript, line 23,
the record states “the ABT technical
staff...” when it
should state “the Agency technical staff...”.
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
Charles E. Matoesian
DATED:
July 11,2005
1021 North Grand Avenue East
P.O. Box
19276
Springfield,
Illinois 62794-9276
(217) 782-5544
45~7~ht
~
