NOTICE
TO :
Dorothy Gunn, Clerk
Matthew Dunn
Illinois Pollution Control Board
Illinois Attorney General's Office
James R. Thompson Center
Environmental Control Division
100 W. Randolph Street, Suite 11-500
188 W. Randolph Street, 20th Floor
Chicago, Illinois 60601
Chicago, Illinois 60601
General Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
PLEASE TAKE NOTICE that I have filed with the Office of the Pollution
Control Board the MOTION FOR ACCEPTANCE APPEARANCE OF ATTORNEYS,
CERTIFICATION OF ORIGINATION, STATEMENT OF REASONS AND THE
REGULATORY PROPOSAL on behalf of the Illinois Environmental Protection Agency, a copy
of which is herewith served upon you
.
Date: December 20, 2005
ILLINOIS ENVIRONMENTAL
PROTECTIO
AGENCY
By:
ORIGINAL
Annet C. Godiksen
Assistant Counsel
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Spring field, IL 62794-9276
THIS FILING IS SUBMITTED ON
217/782-5544
RECYCLED PAPER
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
DEC 2 2 2005
IN THE MATTER OF
:
ORGANIC MATERIAL EMISSION
)
)
STATE OF ILLINOIS
Pollution Control Board
R 06-
`y1
STANDARDS AND LIMITATIONS FOR
)
(Rulemaking Air)
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL. ADM. CODE 218 AND 219
)
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF :
)
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR
)
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL. ADM. CODE 218 AND 219
)
MOTION FOR ACCEPTANCE
.NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA")
and, pursuant to 35 111. Adm. Code 102 .106, 102 .200 and 102 .202, moves the Illinois
Pollution Control Board ("Board") accept for hearing the Illinois EPA's proposal for
amendment to 35 Ill. Adm. Code Parts 218 and 219 . This regulatory proposal includes :
1
.
Appearances for the Attorneys Representing the Illinois EPA ;
2 .
Certification of Origination
;
3
.
Statement of Reasons ; and
4 .
Proposed Amendments .
By :
Douglas .P
.
Director
R06-'
I
(Rulemaking Air)
ILLINOI ENVIRONMENTAL PROTECTION AGENCY
I'
Dated :
a
t) \tUO S
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-3397
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
DEC 2 2 2005
STATE OF ILLINOIS
Pollution Control Board
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF :
)
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR
)
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL.ADM. CODE 218 AND 219
)
APPEARANCE
The undersigned, as one of its attorneys, hereby enters her APPEARANCE on
behalf of the Illinois Environmental Protection Agency
.
ILLINOIS ENVIRONM
TAL P OTECTION AGENCY
By :
/L„
Annet C. Godiksen
Assistant Counsel
Division of Legal Counsel
Dated: December 20, 2005
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
ORIGINAL
R06- /)-
I
(Rulemaking Air)
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
DEC 2 2 2005
STATE OF ILLINOIS
Pollution Control Board
IN THE MATTER OF
:
)
ORGANIC MATERIAL EMISSION )
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL. CODE 218 AND 219
)
APPEARANCE
The undersigned, as one of its attorneys, hereby enters her APPEARANCE on
behalf of the Illinois Environmental Protection Agency
.
ILLINOIS ENVIRONME TA PROTECTION AGENCY
B
x.14141_....
I
41
JAL
It
imberly A Geving
Assistant C unsel
Division of Legal Counsel
Dated: December 20, 2005
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
(217) 782-5544
ORIGINAL
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R06-
7-'
(Rulemaking Air)
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
CLERIVS OFFICE
DEC 2 2 2005
STATE
Pollution
Bo
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF
:
)
ORGANIC MATERIAL EMISSION )
STANDARDS AND LIMITATIONS FOR )
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL. ADM. CODE 218 AND 219
)
Annet C. Godiksen
Assistant Counsel
Division of Legal Counsel
Dated: December 20, 2005
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, Illinois 62794-9276
R06-
2
k
(Rulemaking Air)
CERTIFICATION OF ORIGINATION
NOW COMES the Illinois Environmental Protection Agency ("Illinois EPA") to
certify in accordance with 35 111 . Adm. Code 102 .202(1) that this proposal for
amendments to 35 Ill. Adm. Code 218 and 219 amends the most recent version of that
rule as published on the Illinois Pollution Control Board's website
.
Respectfully submitted,
ILLINOI
NV
ONMEN L PROTECTION AGENCY
By :
THIS FILING SUBMITTED ON RECYCLED PAPER
RECEIVED
CLERK'S
OFFICE
DEC 2 2 2005
Pollution Control
Bo rd
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD RECEIVED
CLERK'S OFFICE
DEC 2 2 2005
ORIGINAL
IN THE MATTER OF
:
)
STATE OF ILLINOIS
R06-
Board
(Rulemaking Air)
ORGANIC MATERIAL EMISSION
)
STANDARDS AND LIMITATIONS FOR
)
THE CHICAGO AND METRO-EAST
)
AREAS: PROPOSED AMENDMENTS
)
TO 35 ILL. ADM. CODE 218 AND 219
)
STATEMENT OF REASONS
The Illinois Environmental Protection Agency ("Illinois EPA") hereby submits its
Statement of Reasons for the above-captioned proceeding to the Illinois Pollution Control
Board ("Board") pursuant to Section 27 of the Illinois Environmental Protection Act
("Act"), 415 ILCS 5/27 (2002), and 35 Ill. Adm. Code Section 102.200 and 102.202 .
I .
STATUTORY BASIS AND OVERVIEW
A. Statutory Basis
This is a regulatory proposal submitted pursuant to Sections 27 and 28 of the
Illinois Environmental Protection Act
.
See 415 ILCS 5/27 and 28
.
It is not being
proposed as an identical in substance, fast track or federally required rule . In addition,
this proposal is being filed
as
a general (rather than emergency or peremptory)
rulemaking pursuant to Section 5-40 of the Illinois Administrative Procedure Act . See 5
ILCS 100/5-40. Section 27 of the Act confers general substantive rulemaking authority
on the Board
.
The contents of this regulatory proposal are within these general
rulemaking powers
.
B. Overview
Solvent cleaning, or degreasing
as it is commonly called, is a process using
aqueous liquids or non-aqueous organic solvents to clean and remove soils from surfaces
.
Solvent cleaning is divided into the following three major types : cold cleaning, open-top
vapor degreasing, and conveyorized degreasing . Evaporation of the solvent used during
degreasing results in emissions of volatile organic material ("VOM") .
Emissions are
produced while parts are being cleaned as well as when the degreasing unit sits idle
.
These VOM emissions react with other pollutants, such as nitrogen oxides ("NOx") and
carbon monoxide ("CO") to form ozone
.
In May 2003, Diversapack alerted Illinois EPA of their desire to obtain a variance
to Section 218.182(c) of the Illinois Administrative Code, citing the need to use solvents
compatible with their printing operations . These solvents do not meet the current vapor
pressure requirements. Diversapack recycles its solvent in a totally enclosed parts washer
and uses add-on controls for the abatement of process emissions . Three additional point
sources also using add-on controls and solvents that do not meet the lower vapor pressure
limits have been identified in the Chicago nonattainment area . The point sources' add-on
controls would have been allowed pursuant to the regulatory language in effect prior to
the revisions of 1997
.
In lieu of site-specific rulemakings for each of these facilities, the Illinois EPA is
proposing revisions to 35 I11. Adm. Code 218 and 219. Specifically, the Illinois EPA
2
proposes revisions to two Sections: 218.182 and 219.182. The proposed revisions will
allow for add-on controls or equivalent alternative control plans as compliance options
.
Additional revisions concerning solvent sale, solvent use, add-on control testing, and
recordkeeping requirements are also being proposed
.
Currently an 8-hour national ambient air quality standard ("NAAQS") is in effect
for the Chicago and the Metro-East areas, which designates both areas as "moderate"
ozone nonattainment areas. The 8-hour NAAQS replaced the previous 1-hour standard
on June 15, 2005 . Given that the USEPA has a policy against regression, the control
measures adopted to meet the 1-hour standard must still be maintained
.
In 1997, as part of the 9 percent rate of progress plan for the 1-hour ozone
standard, Illinois EPA submitted control measures that reduced VOM emissions for cold
cleaning degreaser operations in the Chicago and Metro-East nonattainment areas . The
revisions to the cold cleaning degreaser regulations, submitted September 8, 1997,
lowered the allowed solvent vapor pressure for operations located in the Chicago and
Metro-East ozone nonattainment areas in two steps. The first step lowered the allowed
vapor pressure of solvent used to 2.0 mmHg by 1999, and the second step lowered the
allowed vapor pressure to 1 .0 mmHg by 2001. The respective resultant VOM reductions
were 11 .35 and 11.68 tons per day towards the rate of progress requirements. Modeled
after an adopted Maryland rule, the 1997 rule revisions had no provisions for add-on
controls for cold cleaning degreasers and in fact overrode add-on control provisions that
had previously been in effect .
Under the Clean Air Act and USEPA State
Implementation Plan ("SIP") guidance, failure to obtain equivalent emissions reductions
from the cold cleaning sources would require the Agency to makeup the deficiency
3
through the implementation of contingency control measures
.
Discussions with the
USEPA indicate that the proposed 95 percent control level is considered sufficient for
this emissions source category .
II.
REGULATORY PROPOSAL
A.
Purpose and Effect of Regulatory Proposal
The purpose of these amendments is to allow for the use of add-on controls as a
compliance option for the cold cleaning solvent degreasing operations in the Chicago and
Metro-East nonattainment areas . The use of an equivalent alternative control plan is also
a means of compliance .
Four cold cleaning degreaser operations located in the Chicago nonattainment
area have been identified as using add-on controls . Three are using thermal oxidizers to
control emissions from closed loop cold cleaning systems that are recycling spent
solvents. These systems capture 100 percent and remove or destroy at least 95 percent of
the VOM emissions from the cold cleaning process. The fourth source is using carbon
adsorption with an overall capture and control efficiency of 99 percent . There are less
emissions being emitted to the atmosphere from the impacted sources than if the
specified low vapor pressure solvent were being used without controls . Thus, potential
emissions from these highly controlled sources are minimal, which is consistent with the
overall intent of the Illinois EPA control measures in the rate of progress plan
.
4
B .
Facts in Support
As discussed above, all four Chicago nonattainment area point sources are
reporting 95 percent or greater overall capture and control of the emissions from their
cold cleaning operations .
At the facility reported control levels, the environment is
experiencing fewer VOM emissions than if the currently required low vapor pressure
solvent were being used without controls . The Metro-East nonattainment area does not
have cold cleaning degreaser operations large enough to be classified as point sources at
this time. As of this date, there are no proposed equivalent alternative control plans
.
C .
Summary of the Proposal
The Illinois EPA is proposing to revise its cold cleaning degreaser rules in the
Chicago and Metro-East nonattainment areas by making parallel changes to Section
218.182 (c) and (d), and Section 219 .182 (c) and (d) .
Section 218 .182(c)(2) and Section 219 .182(c)(2)
The Illinois EPA is proposing revisions to Section 218 .182(c)(2) and Section
219.182(c)(2) to allow for the sale or purchase of solvents with vapor pressure greater
than 1 .0 mmHg in units greater than five (5) gallons to or by sources that have valid
permits, are in compliance with the add-on control requirements, or are exempt
.
2 .
Section 218.182(c)(3) and Section 219.182(c)(3)
The Illinois EPA is proposing control requirements to allow for the option of add-
on controls .
New subsections are being created, Section 218 .182(c)(3) and Section
5
219.182 (c)(3), that will require sources using solvents with vapor pressures greater than
1 .0 mmHg to control their emissions to an overall capture and control efficiency of no
less than 95 percent .
There are also provisions in Section 218.182 (c)(3) and Section 219.182 (c)(3)
allowing for equivalent alternative emissions plans .
These subsections stipulate that
emissions from a solvent with a vapor pressure of 1 .0 mmHg shall be the basis for
assessment of equivalent emissions for any proposed control plan and that equivalent
alternative control plans must have at least 95 percent reduction in VOM emissions . The
equivalent alternative control plans are subject to approval by the USEPA and the Illinois
EPA in the form of either a federally enforceable permit or as a SIP revision .
Provisions have also been added mandating the testing of add-on controls .
Currently operating add-on controls shall be tested by March 1, 2006, and newly
constructed add-on controls shall be tested within 90 days after startup .
The testing
procedures, monitoring, and recordkeeping provisions for add-on controls and equivalent
alternative control plans will be consistent with the provisions in Section 218 .105 and
Section 219.105, which require that the control devices be operated and maintained at the
manufacturer's specifications and continuously monitored to assure that they are
operating at the required compliance levels . All records must be kept for a minimum of
three years .
3.
Section 218 .182(d) and Section 219.182(d)
Changes to Section 218.182(d) and Section 219.182(d) include recordkeeping
requirements for persons using add-on controls or an equivalent alternative control plan
.
6
Those requirements pertain to purchase information, records for periodic inspection of
the cold cleaning degreasers and add-on control equipment, records for repair of
malfunctions and breakdowns, and other records pertaining to the use of good operating
practices .
Additionally, all persons subject to the material or control requirements will be
obligated to notify the Agency of changes in compliance methods at least 30 days prior to
any such change
.
Also, all persons subject to the equipment, material or control
requirements will be obligated to notify the Agency of violations of the same
requirements within 30 days
.
D .
Technical Feasibility and Economic Justification
1 .
Technical Feasibility
In the cases of both add-on controls and alternative plans, the Agency is
proposing additional options to supplement the technically feasible low-solvent
requirement already in place. The technical feasibility of add-on controls for point source
cold cleaning degreasers is already being demonstrated
.
Of the three sources using
thermal oxidizers, two reported 98 percent and one reported 95 percent overall control
efficiencies in their 2003 Annual Emissions Reports ("AERs")
.
The source using the
carbon adsorber reported 99 percent overall control efficiency of the VOM emissions
from its cold cleaning operation in 2003 . At this time there are no proposed equivalent
alternative control plans ; as such, the technical feasibility of such plans cannot be
assessed.
7
2 .
Economic Justification
The economic reasonableness analysis indicates that add-on controls coupled with
closed loop automatic parts washers offer cost benefits comparable to converting to low
vapor pressure solvents for some cold cleaning operations . Using data supplied by the
four impacted sources, the estimated cost effectiveness of using thermal oxidizers as an
add-on control is $115
- $562 per ton of VOM reduced. Emissions from the operation
using the carbon adsorber were considered insignificant, thus an analysis of cost
effectiveness was not undertaken for that plant
.
Requ'ring the impacted printing sources to use low vapor pressure solvents
presents economic problems in the form of additional waste, quality issues, and
inefficiencies .
By allowing the use of add-on controls, waste can be minimized as
solvent may be reused. In the printing operations the clean-up solvents from the closed
loop parts cleaners are recycled for use in the printing process or for additional clean-up,
thereby reducing solvent waste, solvent purchases, and operating costs . Using low vapor
pressure solvent that could not be reused in other plant operations would result in
additional waste disposal costs of an estimated $161,000 per year in the case of
Diversapack .
In addition, Diversapack estimates that using a lower vapor pressure
solvent would result in further solvent costs of $1,100,000 per year
.
The thermal
oxidizers would suffer and supplemental fuel would be necessary to maintain destruction
efficiency levels
.
At this time there are no proposed equivalent alternative control plans ; as such,
the economic justification of such plans cannot be assessed
.
8
E .
Affected Facilities and Outreach
Diversapack, Printpack, MPC Products, and Pechiney Plastic Packaging are cold
cleaning degreaser point sources that are using add-on controls .
These sources were
identified from information provided in AERs for the year 2003 . In 2003, the controlled
VOM emissions from these sources totaled 0.033 tons per day in the Chicago
nonattainment area. There are no cold cleaning degreaser operations large enough in the
Metro-East nonattainment area to be classified as point sources .
On June 30, 2005, the Illinois EPA sent copies of the draft regulatory proposal to
:
Chemical Industry Council of Illinois
Diversapack
Illinois Environmental Regulatory Group
Illinois Manufacturers' Association
Metal Impact Corporation
MPC Products Corporation
Pechiney Plastic Packaging, Inc .
Printpack, Inc
.
On July 25, 2005, the Illinois EPA sent a copy of the draft regulatory proposal via email
to :
USEPA, Region V, Air and Radiation Regulatory Unit
The USEPA has reviewed this proposal and is in agreement with Illinois EPA's
control level recommendation.
Outreach efforts to the impacted sources and USEPA
found the proposed revisions to be acceptable
.
9
III .
SYNOPSIS OF TESTIMONY
The Agency will provide one witness in this proceeding : Gary Beckstead. Mr.
Beckstead will address the basis for proposing these changes
.
The Agency will submit pre-filed written testimony in advance of the hearings
pursuant to any hearing officer order that follows this proposal . The Agency respectfully
requests that the Board accept Mr. Beckstead's testimony into the record as if read at
hearing and allow him to briefly summarize his testimony during the hearing
.
The
suggestion has streamlined several regulatory hearings in the past and offers the Agency
the opportunity to more fully respond to questions (pre-filed or otherwise) during the
information gathering process .
IV .
CONCLUSION
The Illinois EPA is modifying the current rule to provide additional compliance
options and allow cold cleaning solvent degreasing sources in the Chicago and Metro-
East nonattainment areas to continue using add-on controls . The recommended overall
capture and control efficiency for add-on controls is set at 95 percent to limit potential
deficiencies in anticipated control strategy emission reductions used to meet the rate of
progress plan requirements
.
As noted above, failure to obtain equivalent emissions
reductions from the cold cleaning point sources would require the Agency to make-up the
deficiency through the implementation of contingency control measures . The emissions
from the existing cold cleaning sources currently using add-on controls are equal to or
10
less than emissions generated by cold cleaning operations using solvents having a 1 .0
mmHg vapor pressure without controls
.
Respectfully submitted,
ILLINOIS
ENVIRONMENTAL
PROTECTION AGENCY
By :
Annet C. Godiksen
Assistant Counsel
Division ofLegal Counsel
Date: October 21, 2005
1021 N . Grand Avenue East
P.O .Box 19276
Springfield, Illinois 62794-9276
217-782-5544
1 1
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 E: SOLVENT CLEANING
Section 218.182 Cold Cleaning
a)
'Operating Procedures : No person shall operate a cold cleaning degreaser unless
:
1)
Waste solvent is stored in covered containers only and not disposed of in
such manner that more than 20% of the waste solvent (by weight) is
allowed to evaporate into the atmosphere
;
2)
The cover of the degreaser is closed when parts are not being handled ; and
3)
Parts are drained until dripping ceases .
b)
Equipment Requirements : No person shall operate a cold cleaning degreaser
unless :
1)
The degreaser is equipped with a cover which is closed whenever parts are
not being handled in the cleaner. The cover shall be designed to be easily
operated with one hand or with the mechanical assistance of springs,
counter-weights or a powered system if:
A)
The solvent vapor pressure is greater than 2 kPa (15 mmHg or 0 .3
psi) measured at 38° C (100° F) ;
B)
The solvent is agitated; or
C)
The solvent is heated above ambient room temperature
.
2)
The degreaser is equipped with a device for draining cleaned parts . The
drainage device shall be constructed so that parts are enclosed under the
cover while draining unless
:
A)
The solvent vapor pressure is less than 4 .3 kPa (32 mmHg or 0 .6
psi) measured at 38° C (100° F) ; or
B)
An internal drainage device cannot be fitted into the cleaning
system, in which case the drainage device may be external
.
3) The degreaser is equipped with one of the following control devices if the
vapor pressure of the solvent is greater than 4 .3 kPa (32 mmHg or 0 .6 psi)
measured at 38° C (100° F) or if the solvent is heated above 50° C (120°
F) or its boiling point:
A)
A freeboard height of 7
/10
of the inside width of the tank or 91 cm
(36 in), whichever is less ; or
B)
Any other equipment or system of equivalent emission control as
approved by the Agency and further processed consistent with
Section 218.108 of this Part. Such a system may include a water
cover, refrigerated chiller or carbon adsorber .
4)
A permanent conspicuous label summarizing the operating procedure is
affixed to the degreaser; and
5)
If a solvent spray is used, the degreaser is equipped with a solid fluid
stream spray, rather than a fine, atomized or shower spray
.
c)
Material and Control Requirements :
1)
On and after March 15, 1999, no person shall
:
A)
Cause or allow the sale of solvent with a vapor pressure which
exceeds 2.0 mmHg (0.038 psi) measured at 20° C (68° F) in units
greater than five (5) gallons, for use in cold cleaning degreasing
operations located in the area covered by Section 218.103 of this
Part .
B)
Operate a cold cleaning degreaser with a solvent vapor pressure
which exceeds 2.0 mmHg (0.038 psi) measured at 20° C (68° F)
.
2)
On and after March 15, 2001, no person shall
:
A)
Cause or allow the sale of solvent with a vapor pressure which
exceeds 1.0 mmHg (0.019 psi) measured at 20° C (68° F) in units
greater than five
(D
gallons, for use in cold cleaning degreasing
operations located in the area covered by Section 218 .103 of this
Part, unless the purchaser provides a copy of a valid state or
federal construction or operating permit or a copy of the Federal
Register demonstrating that they are in compliance with the control
requirements of subsection(c)(3)of this Section or are exempt
under subsection (f) or (g) of this Section
.
B)
Operate a cold cleaning degreaser with a solvent vapor pressure
which exceeds 1.0 mmHg (0.019 psi) measured at 20° C (68° F),
unless they are in compliance with the control requirements of
subsection(c)(3)of this Section or are exempt under subsection (fl
or (g) of this Section
.
3)
Control Requirements :
•
A person may operate a cold cleaning degreaser using solvent with
a vapor pressure greater than 1 .0 mmHg (0.019 psi) but less than
56 mmHg (1 .064 psi) measured at 20° C (68° F) provided add-on
control devices demonstrating at least 95 percent overall capture
and control of emissions are used. The add-on controls may
include, but are not limited to, carbon adsorbers or afterburners
.
•
An equivalent alternative control plan achieving at least 95 percent
reduction of VOM may be used to meet the control requirements
of this Section pursuant to Section 218 .108 of this Part. Pursuant
to the material requirements of subsection(c)(2)(B)of this Section,
a solvent with a vapor pressure of 1 .0 mmHg (0.019 psi) measured
at 20° C (68° F) shall be the basis for assessment of equivalent
emissions from any equivalent alternative control plan. A control
plan approved by the Agency shall be effective only when included
in a federally enforceable permit or approved by the U .S. EPA as a
SIP revision pursuant to Section 218 .108 of this Part .
•
Add-on controls operating at a source prior to the effective date of
this rule shall be tested by March 1, 2006. Add-on controls
constructed after the effective date of this rule shall be tested
within 90 days of initial startup. Testing procedures and
recordkeeping for add-on controls and equivalent alternative
controls subject to subsections (c)(3)(A)and (B) of this Section are
to be performed pursuant to Section 218 .105(c), (d),(e) and 1f) of
this Part .
d)
Recordkeeping Requirements : On and after March 15, 1999 :
1)
All persons subject to the requirements of subsections (c)(1)(A) and
(c)(2)(A) of this Section must maintain records which include for each
sale :
A)
The name and address of the solvent purchaser ;
B)
The date of sale ;
C)
The type of solvent ;
D)
The unit volume of solvent ;
E)
The total volume of solvent; and
F)
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F)
.
2)
All persons subject to the requirements of subsections (c)(1)(B) and
(c)(2)(B) of this Section must maintain records which include for each
purchase
:
A)
The name and address of the solvent supplier ;
B)
The date of purchase ;
C)
The type of solvent; and
D)
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F)
.
3)
All persons subject to the requirements of subsection (c)(3) of this Section
must maintain records, which include for each purchase
:
A)
The name and address of the solvent supplier ;
•
The date of purchase ;
•
The type of solvent;
D)
The unit volume of solvent ;
•
The total volume of solvent ; and
•
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F) .
4)
All persons subject to the requirements of subsection(c)(3)of this Section
shall maintain records documenting the use of good operating practices
consistent with the equipment manufacturer's specifications for the cold
cleaning degreasers and add-on control equipment . At a minimum these
records shall include :
•
Records for periodic inspection of the cold cleaning degreasers and
add-on control equipment with date, individual performing the
inspection, and nature of inspection
;
•
Records for repair of malfunctions and breakdowns with
identification and description of incident, date identified, date
repaired, nature of repair, and the amount of VOM that escaped
into the atmosphere as a result of the incident ;
•
Control device monitoring and recording data ; and
D~
A log of operating time for the control device, monitoring
equipment, and all associated degreasers .
5)
All persons subject to the requirements
of
subsection (c) of this Section
shall notify the Agency at least 30 days before changing the method of
compliance between subsection(c)(2)and(c)(3)
of
this Section. Such
notification shall include a demonstration
of
compliance with the newly
applicable subsection
.
6)
All persons subject to the requirements of subsection (b) or (c) of this
Section shall notify the Agency of any violation of subsection (b) or (c)
of
this Section by sending a description of the violation and copies of records
documenting such violations to the Agency within 30 days following the
occurrence of the violation
.
e)
All records required by subsection (d) of this Section shall be retained for three
years and shall be made available to the Agency upon request
.
The cleaning of electronic components as defined in 35 Ill . Adm. Code Section
211.1885 is exempt from the requirements of subsection (c)
of
this Section .
0
g)
Any cold cleaning taking place in a Detrex cold batch degreaser Model #2D-CC-
SPL Size 24-4-10, or substantial equivalent, including automated loading of parts,
totally enclosed operation (excluding loading or unloading) and permitted by the
Agency, is exempt from the requirements of subsection (c)
of
this Section .
(Source: Amended 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 E: SOLVENT CLEANING
Section 219.182 Cold Cleaning
a)
Operating Procedures : No person shall operate a cold cleaning degreaser unless
:
1)
Waste solvent is stored in covered containers only and not disposed of in
such manner that more than 20% of the waste solvent (by weight) is
allowed to evaporate into the atmosphere
;
2)
The cover of the degreaser is closed when parts are not being handled ; and
3)
Parts are drained until dripping ceases
.
b)
Equipment Requirements: No person shall operate a cold cleaning degreaser
unless :
1)
The degreaser is equipped with a cover which is closed whenever parts are
not being handled in the cleaner . The cover shall be designed to be easily
operated with one hand or with the mechanical assistance of springs,
counter-weights or a powered system if
:
A)
The solvent vapor pressure is greater than 2 kPa (15 mmHg or 0.3
psi) measured at 38° C (100° F) ;
B)
The solvent is agitated ; or
C)
The solvent is heated above ambient room temperature
.
2)
The degreaser is equipped with a device for draining cleaned parts. The
drainage device shall be constructed so that parts are enclosed under the
cover while draining unless
:
A)
The solvent vapor pressure is less than 4.3 kPa (32 mmHg or 0.6
psi) measured at 38° C (100° F); or
B)
An internal drainage device cannot be fitted into the cleaning
system, in which case the drainage device may be external
.
3)
The degreaser is equipped with one of the following control devices if the
vapor pressure of the solvent is greater than 4.3 kPa (32 mmHg or 0 .6 psi)
measured at 38° C (100° F) or if the solvent is heated above 50° C (120°
F) or its boiling point
:
A)
A freeboard height of
7/1()
of the inside width of the tank or 91 cm
(36 in), whichever is less ; or
B)
Any other equipment or system of equivalent emission control as
approved by the Agency and further processed consistent with
Section 219.108 of this Part. Such a system may include a water
cover, refrigerated chiller or carbon adsorber
.
4)
A permanent conspicuous label summarizing the operating procedure is
affixed to the degreaser; and
5)
If a solvent spray is used, the degreaser is equipped with a solid fluid
stream spray, rather than a fine, atomized or shower spray
.
c)
Material and Control Requirements
:
1)
On and after March 15, 1999, no person shall
:
A)
Cause or allow the sale of solvent with a vapor pressure which
exceeds 2.0 mmHg (0.038 psi) measured at 20° C (68° F) in units
greater than five (5) gallons, for use in cold cleaning degreasing
operations located in the area covered by Section 219.103 of this
Part.
B)
Operate a cold cleaning degreaser with a solvent vapor pressure
which exceeds 2.0 mmHg (0.038 psi) measured at 20° C (68° F)
.
2)
On and after March 15, 2001, no person shall
:
A)
Cause or allow the sale of solvent with a vapor pressure which
exceeds 1 .0 mmHg (0.019 psi) measured at 20° C (68° F) in units
greater than five (5) gallons, for use in cold cleaning degreasing
operations located in the area covered by Section 219.103 of this
Part, unless the purchaser provides a copy of a valid state or
federal construction or operating permit or a copy of the Federal
31
Control Requirements
:
Register demonstrating that they are in compliance with the control
requirements of subsection(c)(3)of this Section or are exempt
under subsection (f) or (g) of this Section
.
B)
Operate a cold cleaning degreaser with a solvent vapor pressure
which exceeds 1 .0 mmHg (0.019 psi) measured at 20° C (68° F),
unless they are in compliance with the control requirements of
subsection(c)(3)of this Section or are exempt under subsection (f)
or (g) of this Section
.
•
A person may operate a cold cleaning degreaser using solvent with
a vapor pressure greater than 1 .0 mmHg (0.019 psi) but less than
56 mmHg (1 .064 psi) measured at 20° C (68° F) provided add-on
control devices demonstrating at least 95 percent overall capture
and control of emissions are used . The add-on controls may
include, but are not limited to, carbon adsorbers or afterburners .
•
An equivalent alternative control plan achieving at least 95 percent
reduction of VOM may be used to meet the control requirements
of this Section pursuant to Section 219 .108 of this Part. Pursuant
to the material requirements of subsection(c)(2)(B)of this Section,
a solvent with a vapor pressure of 1 .0 mmHg (0 .019 psi) measured
at 20° C (68° F) shall be the basis for assessment of equivalent
emissions from any equivalent alternative control plan. A control
plan approved by the Agency shall be effective only when included
in a federally enforceable permit or approved by the U .S. EPA as a
SIP revision pursuant to Section 219 .108 of this Part
.
•
Add-on controls operating at a source prior to the effective date of
this rule shall be tested by March 1, 2006. Add-on controls
constructed after the effective date of this rule shall be tested
within 90 days of initial startup . Testing procedures and
recordkeeping for add-on controls and equivalent alternative
controls subject to subsections(c)(3)(A)and (B) of this Section are
to be performed pursuant to Section 219.105(c), (d),(e) and (f) of
this Part
.
d)
Recordkeeping Requirements : On and after March 15, 1999
:
1)
All persons subject to the requirements of subsections (c)(1)(A) and
(c)(2)(A) of this Section must maintain records which include for each
sale :
A)
The name and address of the solvent purchaser ;
B)
The date of sale ;
C)
The type of solvent
;
D)
The unit volume of solvent ;
E)
The total volume of solvent; and
F)
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F) .
2)
All persons subject to the requirements of subsections
(c)(1)(B) and
(c)(2)(B) of this Section must maintain records which include for each
purchase :
A)
The name and address of the solvent supplier
;
B)
The date of purchase
;
C)
The type of solvent; and
D)
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F) .
)
All persons subject to the requirements of subsection (c)(3) of this Section
must maintain records, which include for each purchase
:
A)
The name and address of the solvent supplier ;
•
The date of purchase ;
•
The type of solvent ;
The unit volume of solvent ;
•
The total volume of solvent; and
•
The vapor pressure of the solvent measured in mmHg at 20° C
(68° F) .
4)
All persons subject to the requirements of subsection (c)(3)of this Section
shall maintain records documenting the use of good operating practices
consistent with the equipment manufacturer's specifications for the cold
cleaning degreasers and add-on control equipment . At a minimum these
records shall include :
f)
g)
A)
Records for periodic inspection of the cold cleaning degreasers and
add-on control equipment with date, individual performing the
inspection, and nature of inspection ;
;3
Records for repair of malfunctions and breakdowns with
identification and description of incident, date identified, date
repaired, nature of repair, and the amount of VOM that escaped
into the atmosphere as a result of the incident
;
Q
Control device monitoring and recording data ; and
D)
A log of operating time for the control device monitoring
equipment and all associated degreasers
.
)
All persons subject to the requirements of subsection (c) of this Section
shall notify the Agency at least 30 days before changing the method of
compliance between subsection(c)(2)and(c)(3)of this Section. Such
notification shall include a demonstration of compliance with the newly
applicable subsection
.
6)
All persons subject to the requirements of subsection (b) or (c) of this
Section shall notify the Agency of any violation of subsection (b) or (c) of
this Section by sending a description of the violation and copies of records
documenting such violations to the Agency within 30 days following the
occurrence of the violation
.
e)
All records required by subsection (d) of this Section shall be retained for three
years and shall be made available to the Agency upon request
.
The cleaning of electronic components as defined in 35 Ill. Adm. Code Section
211.1885 is exempt from the requirements of subsection (c) of this Section
.
Any cold cleaning taking place in a Detrex cold batch degreaser Model #2D-CC-
SPL Size 24-4-10, or substantial equivalent, including automated loading of parts,
totally enclosed operation (excluding loading or unloading) and permitted by the
Agency, is exempt from the requirements of subsection (c) of this Section
.
(Source: Amended at 29 Ill . Reg . , effective
STATE OF ILLINOIS
)
)SS .
COUNTY OF SANGAMON
)
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Motion for Acceptance,
Appearance of Attorneys, Certification of Origination, Statement of Reasons and the Regulatory
Proposal 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
General Counsel
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, Illinois 62702-1271
and mailing it by First Class Mail from Springfield, Illinois on December 20, 2005, with
sufficient postage affixed
.
SUBSCRIBED AND SWORN TO BEFORE ME
this 20`h day of December, 2005,
Matthew Dunn
Illinois Attorney General
Environmental Control Division
188 W. Randolph Street, 20`h Floor
Chicago, Illinois 60601
OFFICIAL SEAL
CYNTHIA L. WOLFE
,<{;
NOTARY PUBLIC, STATE OF ILLINOIS ?;
MY COMMISSION EXPIRES 3.20
•p
()7
X
THIS FILING IS SUBMITTED ON RECYCLED PAPER
