BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY A V AILABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLA TILE
ORGANIC MATERIAL EMISSIONS FROM
GROUP
III
CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35 ILL. ADM. CODE 218 and 219
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RI 0-1 0
(Rulemaking-Air)
NOTICE
To:
John Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R.
Thompson Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601-3218
SEE ATTACHED SERVICE LIST
PLEASE TAKE NOTICE that
I
have today filed with the Office of the Pollution Control
Board the TESTIMONY
OF YOGINDER MAHAJAN of the Illinois Environmental Protection
Agency, copies
of which are herewith served upon you.
DATED: November
25,2009
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-5544
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
C2'p~
Dan~tterhoffer
J~4
Assistant Counsel
Division
of Legal Counsel
Electronic Filing - Received, Clerk's Office, November 24, 2009
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY
A V AlLABLE CONTROL
TECHNOLOGY
(RACT) FOR VOLATILE
ORGANIC
MATERIAL EMISSIONS FROM
GROUP
III CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35 ILL. ADM. CODE 218 and 219
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)
)
)
)
)
)
)
RIO-IO
(Rulemaking - Air)
TESTIMONY
OF YOGINDER
MAHAJAN
My name is
Yoginder Mahajan. I am employed as an Environmental Protection Engineer
in the Air Quality Planning
Section in the Bureau of Air of the Illinois Environmental
Protection Agency
("Agency"). I have been employed in this capacity since March 1992.
Prior to my employment with the Agency I worked for various metal fabrication
industries for nine years.
My educational background includes a Bachelor of Engineering
Degree in Mechanical Engineering from Bhopal University at Bhopal, India.
As part
of my regular duties in the Air Quality Planning Section, I have been involved
with preparing emission estimates for various source categories used in the development
of the 1990 ozone season weekday emissions inventories; evaluating control technologies
applicable to volatile organic material
("VOM") emissions sources in preparation of the
Rate-of-Progress plans for the Chicago and
St. Louis ozone nonattainment areas; and
assisting in the development ofregulations for the control
ofVOM emissions from
source categories included in the Rate-of-Progress plans. I prepared the technical support
document
("TSD") for this proposal before you.
1
Electronic Filing - Received, Clerk's Office, November 24, 2009
The Agency's proposal addresses reductions in YOM emissions from the following
categories: paper, film and foil coatings; large appliance coatings; and metal furniture
coatings. The
United States Environmental Protection Agency ("U.S. EPA") identified
these three categories
of coatings as the Consumer and Commercial Products, Group III.
Section 172
of the Clean Air Act ("CAA") requires that state implementation plans
("SIPs") for nonattainment areas, such as the Chicago and Metro-East St. Louis
nonattainment areas
("NAAs") in Illinois, include requirements for reasonably available
control technology
("RACT") as it applies to emissions sources. Section 182(b )(2)(A) of
the CAA further requires that SIPs be revised to include RACT for YOM emissions
sources that are covered
by a CTG document issued by U.S. EPA after November 15,
1990, and before the area's date of attainment.
The
U.S. EPA defines RACT as "the lowest emission limitation that a particular source is
capable
of meeting by the application of control technology that is reasonably available
considering technological and economic
feasibility." In September 2007, the U.S. EPA
issued the final CTGs for Consumer and Commercial Products, Group III. These CTGs
contained information regarding sources
of YOM emissions from the applicable
industries, the recommended available control options to reduce
YOM emissions, and the
cost
of recommended control measures. The Agency relied on the information contained
in the CTGs to develop this proposal.
2
Electronic Filing - Received, Clerk's Office, November 24, 2009
The affected sources in the Chicago and Metro-East St. Louis NAAs are required to
comply with the proposed regulations on and after May 1,2011.
Paper, Film, and Foil Coatings
Currently, 35
Ill.
Adm. Code 218 and 219 specify YOM limits in terms of mass ofVOM
per volume of coating for paper coating. The Agency is proposing to amend subsection
(c)
of Section 218/219.204 to specify YOM limits in terms of mass ofVOM per mass of
solids applied, and equivalent limits in terms of mass of YOM per mass of coatings
applied. The Agency is proposing a lower
YOM limit of 0.20 kg per kg of solids (0.20
Ib/lb of solids) for pressure sensitive tape and label surface coating. Except for pressure
sensitive tape and label coatings, the YOM limits are equivalent to the existing YOM
limits for paper coating. The Agency is proposing to increase the overall control
efficiency standard for
add-on capture and control systems to 90 percent from the
existing
81 percent overall control efficiency requirement. The affected sources may
comply with the
YOM emission limits by installing and operating add-on capture and
control systems or by utilizing a combination
of both low YOM coatings and add-on
capture and control systems.
In
addition, the Agency is proposing to add Section
218/219.218, which contains work practice standards recommended by the U.S. EPA.
The Agency staff reviewed the 2005 YOM emissions inventory and determined that there
are 16 affected sources in the Chicago NAA and two in the Metro-East NAA. Seven out
of 16 affected sources comply with the regulations by using add-on capture and control
systems. The Agency believes that no new
add-on capture and control systems will be
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Electronic Filing - Received, Clerk's Office, November 24, 2009
installed to comply with the proposed regulations. Rather, the Agency expects that
affected sources will continue to use compliant coatings,
or upgrade their existing add-on
caphlre and control systems to meet the proposed
YOM emission limits. The Agency
estimates that approximately 21.45 tons per year
ofVOM emissions will be reduced in
the Chicago NAA at a cost of$I,200 per ton ofVOM reduced. The Agency does not
expect any reduction in
YOM emissions in the Metro-East St. Louis NAA.
Metal
Furniture
Coatings and Large Appliance Coatings
Currently, 35
Ill.
Adm. Code 218 and 219 specify YOM limits in terms of mass ofVOM
per volume of coating for air dried and baked coatings for large appliance coatings and
metal furniture coatings. The Agency is proposing to amend subsections (g) and (h) to
provide
YOM limits for one-component and multi-component general purpose coatings,
and provide specific
YOM emission limits for certain specialty coatings. For several of
these coating types, separate emission limits in terms of mass of YOM per volume of
coating are proposed for baked and air-dried coatings. Also, equivalent YOM limits in
terms
of mass ofVOM per volume of solids applied are specified. The proposed
regulations exempt stencil coatings, safety-indicating coatings, touch-up repair coatings,
and coating applications utilizing handheld aerosol cans.
The proposed regulations require the use
of one or more of the following application
methods: electrostatic application, high volume low pressure
("HVLP") spray, flow coat,
roller coat, dip coat including electrodeposition, brush coating for only large appliance
4
Electronic Filing - Received, Clerk's Office, November 24, 2009
coatings, or other coating application method capable of achieving a transfer efficiency
equivalent or better than achieved
by HVLP spraying.
Affected sources
may use add-on capture and control systems to comply with the YOM
content limits of the coatings. The Agency is proposing to increase the overall control
efficiency standard to
90 percent from the existing 8 I percent overall control efficiency.
The affected sources
may comply with the YOM emission limits by installing and
operating add-on capture and control systems or
by utilizing a combination of both low
YOM coatings and add-on capture and control systems.
In
addition, the Agency is
proposing to add Section
2181219.218,
which contains work practice standards
recommended
by the U.S. EPA.
The Agency staff reviewed the 2005 YOM emissions inventory and determined that there
are six affected sources
of metal furniture coating in the Chicago NAA and none in the
Metro-East NAA. There are no affected sources
oflarge appliance coatings in the
Chicago and Metro-East St. Louis NAAs. The Agency expects that affected sources will
continue using compliant coatings to comply with the
YOM limits. The Agency does not
expect any reduction in
YOM emissions.
On July 20,2009, the Agency posted a draft of the proposed rule and copies of the
pertinent
CTGs on its website for public comments. The Agency also contacted
potentially affected sources via email, soliciting feedback on the proposed regulations.
5
Electronic Filing - Received, Clerk's Office, November 24, 2009
The Agency did not receive any comments regarding this proposal. The Agency believes
these proposed changes are not controversial,
as they are largely based on the U.S. EPA's
recommendations. The Agency believes that the proposed changes are technically
feasible and economically reasonable.
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Electronic Filing - Received, Clerk's Office, November 24, 2009
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
REASONABLY
A V AILA8LE CONTROL
TECHNOLOGY
(RACT) FOR VOLA TILE
ORGANIC MATERIAL EMISSIONS FROM
GROUP
III CONSUMER
&
COMMERCIAL
PRODUCTS: PROPOSED AMENDMENTS
TO 35 ILL. ADM. CODE 218 and 219
)
)
)
)
)
)
)
)
RIO-IO
(Rulemaking-Air)
CERTIFICATE OF SERVICE
I, the undersigned, an attorney, state that I have served electronically the attached
TESTIMONY OF YOGJNDER MAHAJAN upon the following person:
John Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601-3218
and electronically to the following persons:
SEE ATTACHED SERVICE LIST.
DATED: November 25,2009
1021 N. Grand Ave. East
P.O. Box 19276
Springfield,
lL 62794-9276
(217) 782-5544
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
(hnAtl.
Dana Vetterhoffer
/tJiu-kyj14
Assistant Counsel
Division
of Legal Counsel
Electronic Filing - Received, Clerk's Office, November 24, 2009
Timothy J. Fox
Hearing
Officer
Illinois Pollution Control Board
100 W. Randolph St., Suite 11-500
Chicago, IL 6060 I
foxt@ipcb.state.il.us
Virginia
Yang
Deputy Legal Counsel
Service List RIO-IO
Illinois Department of Natural Resources
One Natural Resources Way
Springfield, lL 62702-1271
virginia.yang@illinois.gov
Matthew Dunn, Chief
Division
of Environmental Enforcement
Office of the Attorney General
69
W. Washington St., Suite 1800
Chicago, IL 60602
mdunn@atg.state.il.us
Electronic Filing - Received, Clerk's Office, November 24, 2009