### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009 IEPAATTACHMENTNO.

# 5

BEFORE THE ILLINOIS POLLUTIO CONTROL BOARD 

### IN THEMAITER OF: Petition ofRoyal Fiberglass Pools, Inc. for an Adjusted Standard ITom 35 lAC § 215.301 

### ) ) ) ) ) AS 2009-04 (Adjusted Standard)
FIRST AME DED PETITIO FORAN ADJUSTED STANDARD Royal Fiberglass Pools, Inc. ("Royal''), through its attorneys, Bryan Cave LLP, and pursuant to 35 

### UI. Adm. Code § 104.400 et seq., submits this First Amended Petition For An 

### Adjustcd Standard ("First Amended Petition") to the Illinois Pollution Control Board ("!PCB"), seeking an adjusted standard from 35 Ill. Adm. Code §215.301 (commonly known as the "8Ib/hr Rule") as itapplies to the emissions ofvolatile organic material ("VOM'') at Royal's Dix, Illinois swimming pool manufacturing facility. This First Amended Petition For An 

### Adjusted Standard shall replace in its entiretyRoyal's original PetitionForAn 

### Adjusted Standard filed on March 31, 2009. In addition, Royal is replacing in its entirety the Technical Document which supported the Royal's original Petition with the Technical Document Supporting This First Amended Petition which is attached hereto, incorporated herein, and filed contemporaneously. This FirstAmended Petition does not seek a substantive change to the reliefsought by Royal in its original Petition, therefore, pursuant to 35 Ill. Adm. Code § 104.418, Royal does not plan to re-notice this First Amended Petition. I. 

### BACKGROUND Royal operates a fiberglass pool manufacturing facility located at 312 Duncan Road, Dix, Illinois (the "Dix Plant''). The facility has one large production building in which composite pool manufacturing occurs inside three self-contained rooms, which are called "bays," that are located inside the plant building. Most ofthe pool production occurs in the two main bays (Bay I and Bay 2), but pool finishing, partrepair, and 

### someoccasional small pool production occurs in the third bay. All 

### three bays are connected to a common exhaust ventilation system. The production bays utilize an approximate 35,000-cfTn cross-flow ventilation system that exhausts 

### airfrom the work areas to the outside atmosphere through a36 inch diameter, 36 foot tall vertical discharge stackinorderto control workerexposure to styrene. Royal has always strived to comply with environmental and other regulations that apply to operations at the Dix Plant and, until recently, 

### has been able to demonstrate compliance with such rules. In keeping with its desire to comply with applicable rules, 

### in November of2004, Royal submitted an application for a Clean Air Act Permits Program ("CAAPP") operating permit from the Illinois Environmental Protection Agency ("lllinois EPA")." To date, a permit has not been issued. Royal is aware that Illinois EPA has rejected the use of averaging to demonstrate compliance with the 8 Ib/hr Rule. The Illinois EPA has stated that the 8 Ib/hr Rule

1/ On July 14,2009, Royal submitted to Illinois EPA amodification to its CAAPP permit application.

### Electronic Filing - Received, Clerk's Office, July 17, 2009
specifies a maximum hourly emission rate and, therefore, compliance with the rule would need to be demonstrated on a strict hourly basis, not on an average from any longertimeperiod. On January 10, 2006, the lllinois EPA issued Violation Notice A-2005-D0281 to Royal. After receipt ofthis otice, representatives ofRoyal met with illinois EPA in person and also corresponded with Illinois EPA regarding the notice. As part 

### ofthese communications, Royal provided a significant amount ofinformation to Illinois EPA regarding the Dix Plant and the relevant industry. With assistance from its environmental consultant, Engineering Environmental Consulting Services ("EECS"), Royal computed the VOM emitted during the manufacture of the various pools Royal constructs. Royal discovered that, based on Illinois EPA's strict hourly interpretation ofdemonstrating compliance, the hourly VOM emissions from certain ofits operations (gelcoat and resin application) did not appear to comply with IEPA's interpretation ofthe 8 lb/hrRule. After carefully examining its options for add-on controls and/or for changing manufacturing methods/equipment to reduce Royal's levels ofhourly VOM emissions, Royal realized that the cost for compliance via either ofthese options will neither allow it to remain competitive nor profitable, and will force closure ofthe Dix Plant. Royal met with illinois EPA and presented evidence demonstrating why requiring Royal's compliance with the 8 lb/hr Rule on a strict hourly basis is unreasonable. After considering the information presented by Royal, Illinois EPA agreed thatapplyingthe 8 Ib/hourRuleto Royal's operations on a stricthourly basis would indeed impose an unreasonable burden. Royal and Illinois EPA agreed that Royal would apply for an adjustment from the 8 Ib/hrRule? Accordingly, Royal offers the following summary ofreasons as to why it should receive an adjusted standard with respectto the 8 lb/hr Rule:

• Royal is already subject to National Emission Standard for Hazardous Air Pollutants for reinforced plastic composite manufacturing facilities, found at 40 CFR Part 63 Subpart WWWW (the "Composites MACT'). EPA estimates that the annual costfor afacility to 

### comply with the MACT is $2,800/ton of hazardous air pollutants removed and will reduce styrene emissions by an average of 43%. Royal has been in continuous compliance since the start ofoperations and is currently in compliance with the MACT emission limits and work practices.

• Technical and regulatory constraints (such as the high air flow needed to ventilate building air in order to comply with OSHA worker health & safety standards) make the cost for Royal to comply with the 8 Ib/hr Rule on a strict hourly basis using emission controls unreasonably high.



### • The capital costs associated with tail-stack (end-of-pipe) controls for Royal to comply with the 8 lb/hr Rule on a stricthourly basis would amount to approximately $709,500 to
'J To the extent the lPCB does not grant Royal an adjusted standard pursuant to this Petition, Royal reserves all rights and defenses it may have concerning the application ofthe 8 Iblhr Rule to Royal's operations, and this Petition shall not act as awaiver ofsuch rights ordefenses, noras an admission ofpositions Iaken by Illinois EPA.
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### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

install and over $470,000 peryear to operate. This equates to approximately $18,400 per ton ofpollutantremoved.

• Although some alternate methods for manufacturing fiberglass reinforced plastic ("FRP") products exist, none ofthem can be technically or economically applied to a swimming pool manufacturing operation such as Royal's and none ofthem will actually allow Royal to fully complywith the 8 IblhrRule on a stricthourly basis.

• The high cost ofusing eitherend-of-stack emission controls or very expensive alternative production methods (those requiring complete re-tooling and re-design of production methods and procedures), will put Royal at a significant competitive disadvantage. This will result inoneofthefollowing scenarios:

• To remain competitive, Royal will be forced to move to another state which does not have an 8 IbIhrRule (orany similar limitation); or • Royal will eventually be forced out of business because it will not be able to compete for customers due to the high cost ofits swimming pools and/or due to the diminished quality/durability ofits swimming pools.

• The 8 lblhr Rule puts Royal at a competitive disadvantage to other swimming pool manufacturers located in states without a similar 8 lbfhr Rule. Royal and its consultant, EECS, are familiar with swimming pool manufacturing facilities in at least seven other states (Tennessee, West Virginia, Florida, Arizona, South Carolina, New York and Louisiana, where Royal's only other manufacturing facility is located), and none ofthose states have an 8 lblhr Rule. Royal and its consultant are not familiar with any other swimming pool manufacturing operations within Illinois. 

## n. 3S ILL. ADM. CODE § 

### 104.406 REQUIREMENTS A. 

### Standard From Which Reliefis Sought

- § 

### 104.406(a} Royal requests an adjusted standard from 35 Ill. Adm. Code 

### § 215.301 (Use ofOrganic Material, otherwise known as the "8 Iblhr Rule''). Illinois' organic material emission limitations were originallypromulgated as Rule 205 in 1971. Section 215.301 nowprovides: "No person shall cause or allow the discharge ofmore than 3.6 kg/hr (8 Ibslhr) of organic material into the atmosphere from any emission source, except as provided in Sections 215.302, 215.303, 215.304 and 

### the following exception: If no odor nuisance exists the limitation of this Subpart shall apply only to photochemically reactive material." 35 

## m. Adm. Code 

### § 215.101 states that ''the definitions of35 Ill. Admin. Code 201 and 211 apply to this part." Pursuant to 35 Ill. Adm. Code 

### § 201.102, "emission source" means "any equipment or facility ofa type 

### capable ofemitting specified aircontaminants to the atmosphere." Additionally, 

### § 211.4250(b) defines "organic material" as:

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### Electronic Filing - Received, Clerk's Office, July 17, 2009

"Any chemical compound ofcarbon including diluents and thinners which are liquids at standard conditions and which are used as dissolvers, viscosity reducers, or cleaning agents, but excluding methane, acetone, carbon monoxide, carbon dioxide, carbonic acid, metallic carbonic acid, metallic carbide, metallic carbonates, and ammonium carbonate." B. Nature oftbe Regulation ofGeneral Applicability

- Section l04.406(b) This regulation was promulgated to implement the federal requirements under the Clean AirAct, 42 USC 

### § 740I et seq. 

### C. Level ofJustification

- Section 104.406(c) The regulation ofgeneral applicability from which Royal seeks an adjusted standard does not specify a level of justificationfor an adjusted standard. D. Facility and Process Description

- Section l04.406(d) Royal operates a fiberglass swimming pool manufacturing facility in Dix, Illinois. Royal manufactures twenty different models offiberglass pools, ranging from 12' wide x 16' long x 3' 10" deep to 17' wide x 40' 6" long x 8' deep. The Dix Plantbegan operations in the early 1990s and during peak season employs approximately twenty individuals plus another five to ten contract haulers. Additional information regarding Royal's history and operations (including photographs and maps showing its location) are set forth Section 1 ofthe attached Technical Document. The CAAPP permit application submitted to Illinois EPA 

### in November 2004 requested a maximum facility-wide annual production cap of400 pools per year, which corresponds to full production (two pools per day) in spring, summer and fall. This same facility-wide annual production cap of 400 pools per year is also included in Royal's modification to 

### its permit application filed on July 14,2009. CompositePoolManufacturing Procedure. Thecomposite pool manufacturing atthe Dix Plant consists ofthree basicprocess steps, all ofwhich emitVOMs and would be subjectto therequested adjusted standard: I. 

### Gelcoat application. Either a thin layer ofwhite gelcoat or two layers (one of which is translucent gelcoat and the other is regularproduction gelcoat) is applied to each bare waxed pool mold with a Magnum Venus Products ("MVP") high-volume lowpressure ("HVLPj fluid impingement technology ("FIT") applicator gun. The gelcoat applicator is operated as an atomizing gelcoat spray 

### gun. The white gelcoat used at Dix contains 27% styrene monomer by weight and 3% methyl methacrylate (MMA) by weight. The two layer gelcoats range from 27%

- 38% styrene and 3%

- 10% MMA.

4

### Electronic Filing - Received, Clerk's Office, July 

### 17,2009

This gelcoat IS 

### the state-of-the-art In 

### low-HAP fonnulations for swimming pool production. 2. Barrier coat resin application. A 100 to 120 mil (0.100 to 0.120") laminate layer ofthree ounce glass mat and vinyl ester ("VE") corrosion-resistant resin is applied to the cured gelcoat layer with the same MVP applicator that is used to apply gelcoat. However, the gelcoattip is replaced with a 5020 VE tip and the pump pressure is adjusted to allow for the non-atomized application ofthe VE resin. The VE resin contains up to 48% styrene contentby weight. 3. lsophthalic structural resin applicatioo. A series of consecutive laminate layers consisting of IY, 

### oz. chopped glass strand mat ("CSM''), woven glass roving ("WR"), and isophtha1ic ("ISO") corrosion-resistantresin is applied to the cured VE layer with the same MVP applicator that is used to apply the gelcoat and VE resin. However, the VE tip is replaced with a 7025 ISO resin tip and the pump pressure is adjusted to allow for the non-atomized application ofthe ISO resin. The other manufacturing steps include: (I) parts finishing, including trimming, grinding and sanding offinished pools parts; (2) gelcoat and resin cleanup, in which acetone, non-HAP and non-VOC cleaning solvent is used to clean gelcoat and resin residues from the application equipment and roller tools; and (3) mold repair and mold prep, in which very small amounts of tooling gelcoat and tooling resin are used to repair the molds and a small quantity of mold cleaner, mold sealer, and mold release (called mold wax), is used to prepare the bare mold for gelcoat application. These othersteps do nothave significant amounts ofVOM emissions. 

### VOMEmissions Estimates. The YOM emissions from the Dix Plant vary depending on the type and size ofeach swimming pool part. The facility emissions consist predominately of styrene, but also include small amounts ofother YOM and volatile organic HAP species such as methyl methacrylate ("MMA''). The average YOM emissions perpool for the gelcoating process is 53.8 Ibs ofYOM. The resin process averages 94.4 Ibs ofYOM emitted per pool. The total average YOM emitted perpool is 148.8 Ibs. The maximum facility-wide hourly YOM emission rate is 156.70 Ibs per hour. Annual YOM emissions at the Dix Plant for 2007 and 2008 were 14.8 tpyand 11.6 tpy, respectively. The current CAAPP application estimates the Oix Plant's maximum YOM emissions at about 29.76 tpy, approximately 27.54 tons of which relate to potential sryrene emissions. For more detailed infonnation regarding Royal's YOM emissions, see Section 2 ofthe attached Technical Document which contains three exhibits (Exhibits A, B, and C) 

### from Royal's modification to its CAAPP pennit application filed July 14,2009, as well as a memorandumregarding the Dix Plant's maximum hourly YOM emission rate. 

### Compliance with the Composites MACT. The Composites MACT, 40 C.F.R. 63 Subpart WWWW, requires that subject facilities similar to Royal's be in compliance with the work practice standards contained therein by April 21, 2006. Royal was in compliance with the Composites MACT by February 2006. To comply with the work practice standards in the Composites MACT, Royal adopted standards requiring that all resin containers are closed when not in use, and implementing the use ofacetone, which has no HAP or YOM emissions. By

5

### Electronic Filing - Received, Clerk's Office, July 17, 2009
complying with the Composites MACT, United States EPA estimates that industry-wide, reinforced plastic composite manufacturers will reduce HAP emissions by an average of43%. Royal meets the MACT emission standards by using the HAP emissions factor averaging option (see 40 CFR 63.581O(b)) and Royal has continually been in compliance with the emission limits set forth in the Composites MACT. 

### Eo Investigation ofCompliance Alternatives: Methods for Reducing YOM Emissions From Royal's Swimming Pool Manufacturing OperationsSection l04.406(e) Royal investigated compliance alternatives that would help enable it to comply with the 8 lblhr Rule on a strict hourly basis. As discussed below, Royal investigated: (l) 

### reducing YOM content in production materials; (2) using alternative operating procedures and methods; and (3) installing add-on emission control technologies. It is important to note, however, that otherthan add-on emission controls, many ofthe alternatives investigated would not allow Royal to comply with the 8 lblhr Rule on a strict hourly basis. In addition, Royal could not identify any feasible compliance alternatives to furtherreduce YOM emissions from Royal's operations. 1. LowerYOM ContentMaterials Royal has already reduced the YOM concentration in its production materials (gelcoat and resin materials) in compliance with the MACT. Complying with the MACT alone will not reduce Royal's emissions to a level satisfactory to meet the 8 lblhr Rule on a strict hourly basis. While Royal bas inquired ofits suppliers regarding lower YOM content production materials, further reduction of styrene in the resins (below that needed to comply with MACT) is not currentlytechnicallyfeasible while still maintainingproduct integrity. 2. Alternate OperatingProcedure and Methods Royal carefully studied the gelcoating process at the Dix Plant, and considered every recognized alternative procedure and method that might reduce the hourly YOM emissions rate. However, this study revealed inherent process limitations that precluded the use ofany effective alternative:

• Composite swimming pools are produced with open molding processes on very large malemolds.

• Compositepools are too large to use any closed moldingprocess. Even ifclosed molding was feasible for the smallest pool model, the gelcoat layer must still be applied to the "open" closed mold with a gelcoatapplicator. • A high-quality gelcoat finish is an essential component ofa commercially acceptable composite pool. The pool models are much too large to use a vacuum-formed thermoplastic shell finish, which is the only acceptable alternative finish that is used for smallerspapools.

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### Electronic Filing - Received, Clerk's Office, July 17, 2009

• Gelcoat must be applied to the pool mold in a single uniform layer. Gelcoat cannot 

### be applied in separate strips or sections, because the lapped gelcoat seams would be structurally unsound and WlSightiy.

• Gelcoat must be applied to the mold with an atomizing mechanical applicator. Nonatomizing gelcoat equipment is available that might reduce the gelcoat emission rate. However, the available non-atomizing equipment will not provide an acceptable surface finish and has failed to reduce gelcoat emissions as promised by the manufacturer.

• The gelcoat process takes about one hour for the largest pool model and the largest pool model requires at least 360pounds ofgelcoat.

• The white gelcoat used by Royal is state-of-the-art and contains the lowest feasible monomer contents of 27% styrene and 3% MMA. lbis gelcoat provides a flexible, durable, glossy fmish that must resist impact, weathering, temperarure extremes, UV radiation, and blistering.

• The emissions from the current gelcoat process cannot be appreciably reduced with any additional workpractice improvements, pollution prevention techniques, or gelcoat material substitutions.

• The application ofgelcoat takes place in large work bay areas that require significant amounts of ventilation airflow to protcct thc workers against styrene exposure. This ventilation is required by OSHA regulations. The relatively large airflow rate and low styrene exposure limits established by OSHA result in a large dilute exhaust stream that cannot be economically controlled with add-on airpollution control equipment. The cost ofthe lowest-cost control equipment is detailed in the next section. 3. Add-On AirPollution Controls The cost and feasibility ofadd-on air pollution controls at reinforced plastic composite manufacturing facilities has been thoroughly studied and documented as part ofthe Composites MACT (40 C.F.R. 63 Subpart WWWW). The Dix Plant is fully compliant with the HAP emission limits listed in the Composites MACT standard, averaging 72% of the MACT emissions limit. According to the Composites MACT, a composites facility such as the Dix Plant is not required to install add-on air pollution controls. During the promulgation and development of the Composites MACT, the United States EPA discovered that add-on 

### air pollution controls are not cost effective at most existing composite facilities. The United States EPA also determined that add-on controls with 95% control efficiency would only 

### be cost effective for new composite facilities that emit more 

### than 100 tpy ofHAP or new facility that produces large parts such as swimming pools and 

### emits more than 250 tpy ofHAP. The Dix Plant emitted less than 12 tons ofHAPs in 2008, so add-on controls would not

### be cost effective by a very wide margin. A comprehensive study entitled 

### "Feasibility and Cost ofthe Capture and Control of Hazardous Air Pollutant Emissionsfrom the Open Molding of ReinforcedPlastic Composites"

7

## Electronic Filing- Received, Clerk's Office, July 17, 2009
prepared by EECS was submitted to United States EPA in April 2000 as part ofthe promulgation ofthe Composites MACTrule. This reporthas 377 pages ofinformation concerning the cost and feasibility ofadd-on controls at composites facilities. Very little has changed since the 2000 publication date, except that the cost of electricity and natural gas needed to operate add-on controls has risen drarnaticallyJI An 

### abbreviated summary ofthe air pollution control systems, which are detailed in the aforementioned study and are available for use, is contained in the following table: Commercially AvailableAir Pollution Controls 

# -'{"- •

# .h~jd~rns -; :<; ,:--

### i~~-.; 

# .l

# ~~~s~'*~\**J.ech~?f.t~** _.

### ~~. -',**.~.** -:.a,**~-.~** - _**(~_:"r.-~** 

### . xEaQf Absorption Stvrene is nearly insoluble in water infeasible Styrenepolymerizes on sorbentmedia Adsorption Desorbed styrene is not reusable infeasible Desorbed styrene must be disposed as hazardous waste Biodigestion Microbes are unreliable andmust stay warmand moist infeasible Digestion beds must behuge to handle exhaustairflow Styreneconcentration in air too low to be economic Condensation Condensate is mostly water with trace styrene infeasible Condensatemustbe disposed as hazardous waste Flare Styrene concentration in air is too low to be economic infeasible TO Conventional recuperative oxidation is always more RTO is better costlythan RTO 

# I Regenerativethermal oxidation is currently employed technically 

### I at onetruck cap plant and several large bathwareplants feasible that produce small parts on automated production lines, Oxidation RTO operatecontinuously (24 br/day, 360dayslyr) and have economically uncontrolled styrene emissions >250 tpy. A RTO infeasible system large enoughto handlethe 35,000 cfm exhaust airflow atthe Dix Plantwould cost over$600,000 to install and over $300,000 per yearto operate. CO Catalytic mediabas 

### arelatively short lifetime and is infeasible unreliable Preconcentration is currently employed at four large technically bathware plants. The 10ng-teImperfoImance ofthe questionable Preconcentration adsorberin questionable due to an unexpected failure 

### wlRTO ofthe activated charcoal sorbent mediaat one ofthe economically sites. A preconcentrator system largeenough to handle infeasible the 35,000 elin 

### exhaust airflow at the Dix Plant would cost almost one million dollars to install and operate.

)I Due to tbe size ofthis study. Royal is not including a copy with tbis Petition. It is pan ofEPA's docket regarding the Composites MACT rule promUlgation aod adoption. Should the Board desire a copy ofthe study, Royal would be pleased to provide itto the Board.
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### Electronic Filing - Received, Clerk's Office, July 17, 2009
Royal commissioned EECS 

### to prepare a detailed control cost analysis for a skid-mounted RTO system for the Dix Plant. EECS's report ofits analysis was submitted to Illinois EPA on June 19, 2009 and is attached in the accompanying Technical Document at Section 3. As detailed in this analysis, the skid-mounted RTO control option would have an installed capital cost approximately $709,500 and would have annual operating costs ofover $470,000 per year. The cost effectiveness for this add-on control would be about $18,400 per ton of styrene and MMA removed per year. As such, the cost effectiveness ofthe RTO control option is much greaterthan what is widelyregarded as affordable. The annual operating costofthe RTO control options is several times greater than the annual profit for the Dix Plant Hence, add-on controls are prohibitively expensive and noteconomicallyfeasible for the Dix Plant. F. Royal's Proposed Adjusted Standard

- Section 104.406(0 As set forth above, the rule ofgeneral applicability from which Royal seeks this adjusted Standard prohibits Royal from emitting "more than 8 lbslhr of organic material into the atmosphere from any emission source." 35 LA.C. §215.301. Because IEPA will not allow averaging ofemissions to meet this standard, Royal can not comply with the 8 lblhr Rule as interpreted by !EPA. Accordingly, Royal proposes that, in lieu of being subject to 35 lAC. §215.301, Royal shall comply with the MACT Standard finalized at 40 C.F.R. Part 63, Subpart WWWW (the "Composites MACT''). 

### As discussed in Section II.D of this First Amended Petition, Royal 

### has come into compliance with the work practice standards ofthe Composites MACT Standard. According to the Composites MACT, EPA estimates that compliance with the MACT will cost $2,800/tonannually and will reduceemissions by an average of43%. Royal proposes the following language for a Board orderto impose the adjusted standard: I. 

### Pursuant to Section 28.1 of the Environmental Protection Act ("Act") (415 ILCS 5/28/1), the Board 

### grants Royal Fiberglass Pools ("Royal) an adjusted standard from 35 Ill. Adm. Code. 215.201 ("8 IMlr Rule"), effective ,20_. Thc adjusted standard applies to the emissions of volatile organic material ("VOM") into the atmosphere from Royal's swimming pool manufacturing facility located in Dix, lllinois. 2. 35lll. Adm. Code 215.301 does not apply. Royal remains subject to the following:
a. Royal must continue to investigate: (a) swimming pool production methods that generate fewer YOM emissions, and (b) 

### materials that have a reduced YOM content and/or are compliant with the Composites MACT HAP content. Where practicable, Royal must substitute current materials with lower YOM content materials as long as such substitution does not result in a net increasc in YOM emISSIOns. b. Royal must perfonn any rcasonable test ofnew technologically or economically reasonable production methods or materials applicable to the open-mold swimming pool manufacturing industry, which may reduce YOM emissions at
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### Electronic Filing - Received, Clerk's Office, July 17, 2009
Royal's facility which the Illinois Environmental Protection Agency (Agency) specifically requests in writing they do. After perfonnance ofsuch tests, Royal must prepare and submit a report summarizing the activities and results ofthese investigatory efforts. The reportmust be submitted to the Agency, Bureau ofAir, Compliance and Enforcement Section.
c. Royal must operate in full compliance with the Clean Air Act, its Clean Air Act Pennit Program permit (once issued), the ational Emissions Standard for Hazardous Air Pollutants for Reinforced Plastic Composite Manufacturing Facilities, set forth in 40 C.F.R. 63, Subpart WWWW, as required by Section 9.1 (a) oftheAct, and any other applicableregulation. G. Quantitative and Qualitative Description ofRoyal's Impact on the Environment Before and After the Proposed Adjusted Standard

- Section l04.406(g) 

### Air Quality Impact Analysis ofRoyal's Operations. As 

### indicated, the Dix Plant is already in compliance with the Composites MACT, and the proposed adjusted standard will not impact future compliance with the MACT. AdditionallY, attached at Section 4 ofthe Technical Document is an Air Quality Impact Analysis ofthe Dix Plant. This analysis presents the worstcase scenario for ozone emissions using the proposed adjusted standard. Based on the results of the analysis, the worst-case one-hour average ozone impact is still only 74% of the one-hour ozone standard. Royal understands that in 2005, EPA replaced the one-hour average ozone standard with an eight-hour average standard, but believes thehourly calculation presented in the attached Air Quality Impact Analysis is useful given the obvious concerns about hourly emissions that are reflected in the 8 lb/hrRule. Should Royal's First Amended Petition be granted, there will not

### be any increase on aper unit basis over the current emissions from the Dix Plant. 

### This First Amended Petition merely seeks to 

### allow Royal to continue manufacturing in the saroe manner, and granting the First Amended Petitionwill not amount to an increase ofperunit emissions. 

### Cross-Media Environmental Impacts Resultingfrom an Adjusted Standard. None. The Dix Plant's waste and wastewater generation is independent ofYOM emissions, thus no change in the nature orvolume ofwaste and wastewatergeneration is anticipated. R. Justification -Section l04.406(h) 

### Under Section 28.1 oftheEnvironmental Protection Act (the "Act"), the Board may grant an adjusted standard for persons who canjustifY such an adjustment consistent with subsection (a) of Section 27 of the Act. 415 LL.C.S. 5/28.1. Moreover, if a regulation of general applicability does not specil)< a level ofjustification required of a petitioner to qualil)< for an adjusted standard, the Board may grant individual adjusted standards upon adequate proofthat: (I) 

### factors relating to that petitioner are substantially and significantly different from thc factors relied upon by the Board in adopting the general regulation applicable to that petitioner; (2) the

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### Electronic Filing - Received, Clerk's Office, 

## July 17,2009

existence ofthose factorsjustifies an adjusted standard; (3) the requested standard will not result in environmental or health effects substantially and significantly more adverse than the effects considered by the Board in adopting thc rulc of gcneral applicability; and (4) the adjusted standard is consistent with any applicable federal law. Significantly, the proposed adjusted standard is consistent with prior adjusted standards from the 8 IbIhr Rule issued by the !PCB for similar manufacturing processes. Specifically, on July 22, 2002, the !PCB granted Crownline Boats, Inc.'s ("Crownline') Petition for Adjusted Standard. Crownline operates a fiberglass boatmanufacturing facility in WestFrankfort, Illinois, using a gelcoat and resin application process very similar to that employed by Royal. Crownline was granted an exemption from compliance with the 8 IbIhr Rule because compliance with a MACT standard similar to the Composites MACT could be demonstrated. See Section 5 of

### the attached Technical Document for a copy of the !PCB's opinion and order regarding the Crownline petition. The adjusted standard proposed herein is based on the adjusted standard approved by the LPCB in response to Crownline's petition. 1. Factors Relating to Royal are Substantially and Significantly Different The primary intent ofthe 8 Ib/hrRule 

### was to prevent ozone formation and odor nuisance. However, the Board did not contemplate the methods Royal Fiberglass Pools would usc to manufacture swimmingpools at theDix Plant when itpromulgated the 8 lb/hrRule in 1971. The manufacture of large composite pacts such as swimming pool shells involves a batch-type process rather than a continuous application process typically used in manufacturing processes for other products. This fact, together with the ventilation system needed to comply with OSHA's worker protection regulation at 29 C.F.R. Part 1910, makes the use ofadd-on emission controls economically infeasible. Under OSHA health and safety standards for styrene, the Dix Plant must maintain large airflow to ventilate the work areas properly. The small emission rate and large airflow makes the cost of using add-on emissions controls unaffordable. In short, Royal Fiberglass Pools believes that the Board did not anticipate the requisite production methods for manufacturing large composite 

### parts and the OSHA standard when adopting the 8 Ib/hrRule in 1971. The factors relating to Royal's operations are substantially and significantly different than the general factors relied upon by the Board in promulgating the 8 IbIhr Rule. The 8 Ib/hr Rule was first promulgated in 1971 as Chapter 2: Air Pollution, Rule 205. 4 PCB 191, R71-23. Because it 

### was adopted over 30 years ago, it is difficult, ifnot impossible, to know exactly what factors the Board relied upon in adopting this rule. However, based upon lIlinois Pollution Control Board case law and a common sense reading ofthe rule, Royal believes that the factors primarily relied upon by the Board involved concerns aboutpreventing ozone formation. In fact, it appears that the main intent ofthe rule was to ensure that operations emitting organic material utilized control equipment already in place to ensure that their facilities do not cause a violation of the one-hour ozone standard nor create an odor nuisance. For example, in Illinois v. Processing and Books, Inc., the !PCB explained that: "Rule 205: Organic Material'Emission Standards serves both to achieve and maintain

I)

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009
compliance with the federal air quality standard for photochemical oxidants (0.08 ppm for one hour not to exceed more 

### than once per year, 36 Fed. Reg. 22385 ov. 25,1971) and to prevent local nuisances
.... the major pUlJlose ofthese regulations is for control of photochemical oxidants. 

### In addition, odor causing organic emissions were included ifa local odor nuisance exits
. . . these provisions are designed to require the use of equipmentthat is already inuse at numerous facilities
..." 1977 WL 9986, ·4 (Ill. Pol. Control. Bd.). From this explanation it is evident that the Board 

### was most concerned with: (I) protecting ambient air quality by prcvcnting any violation of the I-hour ozone NAAQS; and (2) controlling any odor nuisances from manufacturing operations. A review ofRoyal's operations shows that the main purposes ofthis rule are not furthered through its application to Royal: first, as discussed in Section Il.G of this First Amended Petition, the daily amounts ofYOM cmitted by Royal's operations have a negligible impact on ambient ozone levels and would not cause a violation ofthe ozone NAAQS; and second, Royal has atall stackin place to minimize odor nuisance from its opcrations. The above quote from the Illinois Pollution Control Board also shows that, when adopting the rule in 1971, the Board most likely relied upon the fact that facilities would have no problem complying with the rule by utilizing equipment already availablc and in use by most facilities subject to the rule. It 

### is clear that this rule was promulgated as a catch-all provision, intending to cast a wide net over all operations which emit organic materials. However, the Board could not possibly have contemplated all the circumstances in which organic material is emitted, and, in fact, there is no indication that the Board considered the factors peculiar to pool fabrication when adopting this rule. There are other substantial and significant factors which are inherent or otherwise necessary to Royal's operations that tbe Board did not consider (nor could it have) when it adopted the 8 Iblhr Rule in 1971. The building ofa fiberglass swimming pool involves a batchtype process (ofapplying layers or skins), rather than a continuous application process. This is an important distinction because compliance with the rule can be reasonably accomplished and demonstrated when manufacturing operations (that involve the use ofmaterials that emit YaMs) are ofa continuous nature or, are at least are distributed more evenly over a 24 hour period. For continuous or near-continuous operations, the use ofemission controls, as provided by 35 l.A.C. 215.302, is economically feasible. Due to the large size of the swimming pool molds and necessary batch-type sequence ofthe gelcoat and resin application processes at the Dix Plant, they are neither continuous nor evenly distributed over a longerperiod oftime. Additionally, the advent of OSHA's worker protection regulation at 29 CFR 1910, requires manufacturers who use materials that contain and emit styrene to maintain an in-plant work area atmosphere (workerbreathing air) ofless than 100ppm. To do so, Royal had to install a large ventilation system that exhausts approximately 35,000 cubic feet of plant air every minute. This makes the use of add-on emission controls for Royal's operations fiscally impractical. See Section 3 ofthe Technical Document. The Board could not have possibly anticipated this OSHA requirement and its affect when it made its decision to adopt the 8 lblhr Rule for

### all manufacturing facilities in the State.

12

### Electronic Filing - Received, Clerk's Office, July 17, 2009

Finally. on June 15,2005, EPA revoked the one-hour average ozone standard, which was replaced by an eight-hour average standard. See 69 Fed. Reg. 23951 (Apr. 30, 2005). As referenced by the Board in Illinois v. Processing and Books, Inc., the 8 Ib/hr Rule was designed in primary part to assist in achieving compliance with EPA's one-hour average standard. Although Royal is not requesting that the Board revoke the 8 lb/hr Rule, Royal asserts that the elimination ofone ofthe fundamental purposes ofthe 8 lblh Rule supports this request for an adjusted standard. Because the [PCB could not (and did not) consider these factors relating to Royal's operations, Royal contends that it is unreasonable to expect it to demonstrate compliance with the 8 lb/hrRule ona stricthourly basis. 2. The Existence ofThose Factors Justifies an Adjusted Standard As discussed fully in Section D.E. ofthis First Amended Petition, Royal has investigated numerous compliance alternatives that have proven to 

### be neither economically nor technically feasible due to the substantialIy different factors relating to Royal's operations. The existence of these factors, coupled with fEPA's endorsement ofRoyal's efforts to obtain an adjusted standard justifies the granting ofan adjusted standard. 3. The Requested Standard Will NotResult in Adverse Environmental or Health Effects. As discussed previously in Section II.G of this First Amended Petition, the requested adjusted standard wilI have little, if any, adverse impact on the environment or health. By complying with the Composites MACT, Royal has limited its YOM emissions and also decreased the amount of solid and hazardous waste Royal generates. Even without these changes, Royal's operations do not cause or contribute to any ozone exceedances. With respect to health effects, Royal notes that Illinois does not have a health standard for styrene emissions, and this manufacturing process is the same process used by swimming pool manufacturers in many otherstates. 4. The Proposed Adjusted Standard is Consistentwith Federal Law The granting ofthis proposed adjusted standard is consistentwith federal law and will not violate any provision of the federal Clean Air Act. Specifically, there is no Clean Air Act equivalent rule or regulation prohibiting swimming pool manufacturers' emissions of organic material in excess of8 lbslhr, on a strict hourly basis. Because Royal is proposing to comply with the CompositeS MACT, theproposed adjusted standard is consistentwith federal law. I. Consistency with Federal Law

- Section l04.406(j) There is no Clean Air Act equivalent rule or regulation prohibiting YOM emissions from reinforced plastic composite manufacturing in excess of 8 Ibslhr on a strictly hourly basis.

13

### Electronic Filing - Received, Clerk's Office, July 17, 2009
Regardless, the facility must comply with the new federal NESHAP for reinforced plastic composite manufacturing. For these reasons, the proposed adjusted standard is consistent with federal law. 

### J. Hearing

- Section 104.4060) Royal requests a hearing in this matter. 

### K. Supporting Document

- ection 104.406(1<) The Technical Documentis filed contemporaneously with this First Amended Petition. 

### III. CONCLUSION The requested adjusted standard should be granted as an alternative to Royal's compliance with 35 lAC §215.301. Notwithstanding the technical impracticality ofcomplying with the requirements ofthe 

### 8 Iblhr Rule on a stricthourly basis. to require Royal to comply with the 

### 8 Iblhr Rule would result in substantial economic hardship to Royal, and perhaps even closure ofthe Dix Plant. WHEREFORE, Royal Fiberglass Pools, Inc. respectfully requests an adjusted standard from 35 lAC § 215.301 

### as set forth herein. Respectfully Submitted, BRYAN CAVE LLP

# By;;kg~ ( DaleA.

## ~Bl\(2988 Brandon W. Neuschafer, MO Bar#53232 One Metropolitan Square 211 North Broadway, Suite 3600 5t. Louis, Missouri 63102 Tel. (314) 259-2000 Fax. (314) 259-2020 Attorneys for Royal Fiberglass Pools, Inc.

14

### Electronic Filing - Received, Clerk's Office, July 17, 2009

CERTJFICATE OF SERVICE The undersignedcertifies that acopy ofthe foregoing FirstAmended Petition was served upon the following parties on thcfI!::aayofJuly, 2009: lIIinois Pollution Control Board, Attn: Clerk 100 West Randolph Street James 

### R. Thompson Center, Suite 11-500 Chicago, IL 

### 60601-3218 DivisionofLegal Counsel lIIinoisEnvironmental ProtectionAgency 1021 North Grand Avenue**Ea~t** 

### P.O. Box 19276 Springfield, IL 

### 62794-9276 Attn: Charles Matoesian

15

### Electronic 

## Filing - Received, Clerk's Office, 

## July 17, 2009



# EXHIBIT 1

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# DIVE**IN~**

M lhere's nothing quite like il...the feel of cool, in igorating waler rushing over you as you lake that first dive inlo your new Royol Fiberglass Pool. In on in,lanl, the world i, quiet, tranquil. 

### All your ten,ion, jusl

## Row away.

Welcome to the Royal Fiberglass Pool,

experien<e. Royal Fiberglass pools offers the

fine,t product, on the morket today. Pool,

and Spe' in a variety of ,hopes and ,ize"

cu,tomized 10 fit your life,tyle. Simple 10

elegant design' offer something for

everyone and every budgel.
Turn your backyard into a

Iropicol relreot. Just a 

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### 17, 2009 

# TAKE THE

I 

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# LUNGE!

How mony times hove you soid it? 'One doy, we'll have 0 

### pool.' Haven', you've waited long enough? 

### Go oheod
...**'o~e** the plunge. Toke thai dreom and make il real. Imogine
...everydoy you could escape to your own backyard porodise. You'll feel like royalty as you relox in your very own**spor~ling** pool. The oddition of a Royal Pool or Spo

odds a new dimension 10 your home.

II's the perfect seHing lor

entertaining. The ultimote spol for

quality family time. Aluxurious

way 10 spend some quiet time 10 focus and reiuvenate. A mini vacation in your own backyard yeor after yeor. When you invest in a Royal Pool or Spa, you can counl on quolity crohsmonship ,hal only comes with the Royal nome. The process used in ,he manufocture of these fine quality pools and spos is, by for, the best in the industry

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### 01 II! Royal fiberglass Pools has manufocluring focililies in Breaux Bridge lA and Dix IL. centrally located 10 serve our nationwide dealer network. When you move. 

### your pool can go wilh you.

Member**o~** Optional Accessories: Automotic pool deoner, water

healer, additional clecking. slide, diving boord. eXIra jets. winlercover, salor blonketond reel oulo cover, ozone purification, ceramic tile. landscape lighting.**~ber** aplic lighting, handrails. and ladders. Sianciord Accessories: Skimmer. moin drain and re/urn

inlels.



# - Stanclord Features: Your Royol Fiberglass Pool includes a built·

in coping. molded. non·slip surfoce sleps and benches. Movable: Maintenance Free: The gelcool finish is 

### smooth, hard and non' porous moking il resistant 10 algoe. This feolure reduces chemical

usage and mointenonce costs. Unlike other types of pools. there is

never a need to drain a one'piece fiberglass pool. When you invesl in a pool by Rayol fiberglass Pools, you knowyou're buying Ihe very bestpool thol money can buy. In addition to selling the finest quality pools and spos in the country, the Hebert family provides customers with the ulmasl respeel and**o~ention.** 

### - Received, Clerk's Office, July 17, 2009

Quick Ins10110lion: Usually 

### 3 10 

### 5 days. Durability: The pool's seamless construction withstands exlreme environmental changes and can flex up to twelve full inches without damoge. Royal fiberglass pools are engineered to be up to sevenleen times stronger per inch Ihon concrete pools. This remorkable flexing feature makes the**~bergloss** pool the mosl resilient 10 any weather condition. No other

### pool comes dose. 

# THE ROYAL 

# TREATMENT!

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### Electronic Filing - Received, Clerk's Office, July 17, 2009



# EXHIBIT 2

### Electronic Filing - Received, Clerk's Office, July 17, 2009

EXHIBIT A 

### Royal Fiberglass Pools - Dix Plant Material Usages and Emissions - 2005 through 2008 Year Pools built peryear Hours worked manhours Manhours per pool Hours per pool (9 workers) 2005 2006 2007 2008 158 188 200 161 27,657 28,714 30,002 21,340 175 153 150 133

19 17 17 15 Actual Annual Material Usaaes Resins Iblyr 161,800 267,140 324,500 233,820 Gelcoats Ib/yr 35,704 51,475 71,727 55,607 Catalysts Ib/yr 3,136 4,068 5,317 4,608

Putties Iblvr 0 0 0 0 Reported YOM Ib/yr 14,773 23,222 29,616 21,443 emissions tov 7,39 11.61 14,81 11.65 Actual "Per·Pool" Usaaes Resins Iblpool 1,024 1,421 1,623 1,452 Gelcoats Ib/pool 226 274 359 345 Catalysts Ib/oool 19.8 21,6 26.6 28.6 Catalyst Ratio %wl 1.59% 1.28% 1.34% 1.59%

Resins Gelcoats Catalys1s

Putties Maximum "Per·Pool" Emission Rate Max actual CY 2008 ave!age YOM VOM

## I~:(ge; YOM Content

### ~~Factor tmission

I 001 "Iowl O/OVOM Ibloool Resins 1,625 47.5% styrene 12.23% 94.4 Gelcoats 360 27.0% styrene 44.51% 43.3 3.9% MMA 75% 10.5 Catalysts 32 2%VOM 100% 0.6

Putties 0 N/A 0 Total YOM emissions per pool (Ib/hr) - 148.8

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

y 

### EXHIBIT B 

### Royal Fiberglass Pools

- Annual Polenlial-to-Emit YOM Calculation
Average Per-Pool YOM Emissions (based on worst-case from 2005 to 2008 data) Gelcoat

- Resin

- Catalyst

- 360 Ib x 27.0% styrene x 44.5\% stYrene wt = 360 Ib x 3.9% MMA x 75% M\1A wt = 1,625 Ib x 47.5% styrene x 12.23% styrene wI 

### = 321b x 2% MEK x 100% MEK 

### "t = 43.3 Ih styrene/pool 10.5 Ib MMA/ pool 94.4 Ib styrene/ pool

0.6 lb MEK/oool 148.8 Ib YOM/pool
Annual YOM Emissions for 400-Pools-per-Year 148.8 Ib VOM/hr per pool x 400 pools peryear/2000 Ib/ton = 29.76 tpy YOM

### Electronic Filing - Received, Clerk's Office, July 17, 2009

EXHIBIT C - Maximum Hourly VOM Emissions from Gelcoating atthe Royal Fiberglass Pools Dix Plant Pool Royal Ge]coat Backcoat Backcoat Gelcoat Gelcoal Gelcoat**Bac~coat** Backcoat Backcoat Model Color Usage Color Usage Contents Factors Em15.slon
.. .'**CDnt~nts** Factors Emissions Sty<ene MMA Styrer.e MMA Styrene MfAA VOM Styrene MMA Styrene MMA Styrene MfAA VOM Ibfpool IbJpool (".4Yo1:) (%W1.) ('fisty) (eA>MMA) (Lb/pool) lib/pool) IlbI""") (%wt) IY.wt) (%sty) (%MMAI Oblpool) (lb/pooll (lblpool) HARON 334.69 Wllle 202.13 24"10 4% 44.51% 75% 35.75 10.04 45.79 27 1..il 3'/\ 44.51% 75 1", 24.29 4.55 28.84 BARON 334.69 Clear 174.25 24% 4% 44.51 '10 75% 35.75 10.04 45.79 38 1/0 10% 52.28% 75°4 34.62 13.07 47.69 BARON 357.00 Ughl Blue 1742S 24 1t. 4% 44.51% 75% 38.1. 10.71 48.85 281>1. 4% 44.51% 75°,4 21.72 5.23 26.94 BARON 0428.40 Claar 223.04 24',4 4% 44.51 1
" 75% 45.76 12.85 58.61 38°,- lOll. 52.26% 75% 44.31 16.73 61.04 IJAIlON 223.69 0.00 27% 3% 44.51 e ,.. 75'''' 26.88 5.03 31.91
....51'" 75''''' 0.00 0.00 0.00 CLASSIC" 223.13 Gray 174.25 24% 4% "4.51''''' 75'Y, 23.84 8.69 30.53 2acy. 4'/\ 44.51 % 75% 21.72 5.23 26.94 ('J.ASSJC 142.35 0.00 27% 3% 44.51'" 75,., 17.11 3.20 20.31 4".51'" 75'''' 0.00 0.00 0.00 /lUCHESS 499.80 Clear 287.00 24t/a 4% 44.51% 75'1, 53.39 14.99 68.38 38'.4 10'/\ 52.28°.4 75% 57.02 21.53**'fa.~5** {)/K:IIESS 481.95 Ligtt Blue 136.00 24% 4% 44.51% 75% 51.48 14.46 65.94 28';' 4'/\ 4".51°", 75'''' 16.95 4.08 21.03 Dl'Cfl£SS 446.25 G,ay 174.25 24% 4% 4".51% 75% 47.67 13.39 61.08 26% 4'/\ 4".51'''' 75'/. 21.72 5.23 26.94 I>UCII/!S5 266.79 0.00 27'''' 3% 44.51 '.4 75% 32.06 6.00 36.06 44.51'''' 75'" 0.00 0.00 0.00 DUKESHALLUW 334.69 CIe

... 174.25 24% 4% 44.51% 75% 35.75 10.04 45.79 38% 10'''' 52.28% 75'" 34.62 13.07 47.69 DUKESHALLOW 211.40 Gray 90.00 24'" 4% 44.51'10 75'" 22.58 6.34 28.92 28'.4 ,'/\ 44.51% 75% 11.22 2.70 13.92 DUKESII,lLl.OW 228.64 0.00 27% 3% 44.51'" 75'4 27.24 5 10 32.34 ',f<' 44.51'", 75"'''' 0.00 0.00 0.00 JEWEL 334.69 light BlUe 174.25 24',4 4% 44.51',4 75% 35.75 10.04 45.79 28'10 4% 44.51''''' 75"''''' 21.72 5.23 26.94 EWE/. 260.31 GrAy 155.66 2'% 4% 44.51 'k 75% 27.81 7.81 35.62 28'''' 4% 4•.51% 75',4 19.40 4.67 24.07 IEHEL 188.99 0.00 27% 3% 44.51°"" 75% 22.71 4.25 28.96 44.51% 75'" 0.00 0.00 0.00 KINGDHEP 557.81 CIe

... 261.38 24'10 4% 44.51% 75% 59.59 16.73 76.32 38% 10% 52.28'''' 75% 51.93 19.60 71.53 KING DEEP 291.72 0.00 27'" 3% 44.51% 75% 35.06 6.56 41.62 44.51 ''''' 75% 0.00 0.00 0.00 KJNGSJIALWW 557.81 VvtIile 174.25 24% 4% 44.51% 75% 59.59 16.73 76.32 27% 3% 44.51% 75% 20.94 3.92 24.86 KING SI/ALI.OW 453.44 Clear 261.38 24% 4% 44.51 ',4 75'Y, 51.64 14.50 66.15 36% 10% 52.28'1, 75'/, 51.93 19.60 71.53 KiNG SIIAU.oW 557.81 LIght Blus 251.38 24''''' 4% 44.51',4 75% 59.59 16.73 76.32 26% 4'/\ 44.51% 75% 32.57 7.84 40.42 KING SIIAI../.J)W 553.53 C

..... 238.72 24'.4 4% 44.51% 75% 59.13 16.61 75.73 38% 10'" 52.28% 75'''' 47.43 17.90 65.33 KING SIIALWW 571.20 Whrt< 223.04 24'.4 4% 44.51'10 75',4 61.02 17.14**~5** 27% 3% 44.51% 75% 26.80 5.02 31.62 KING SHALLOW 481.95 light Bhle 267.80 24% 4% 44.51% 75'Y, 51.46 14.46 65.94 28% 4% 44.5111,4 75% 35.84 8.63 44.47 KING SIJALWW 33i.15 27% 3% 44.51**~.4** 75", 40.76 7.63 46.39 44.51% 75'''' 0.00 0.00 0.00 0.00 MONARCH 171.55 0.00 27'" 3% 44.51". 75% 20.82 3.66 24.48
. 44.51% 75% 0.00 0.00 0.00 NOIII.r: 113.67 0.00 27'''' 3% 44.51'.4 75°;' 20.87 3.91 24.78.:. 44.51% 75% 0.00 0.00 0.00 PRJNC'E.<t.,s IJE.l:.'P 223.13 Goay 87.13 24% 4% 44.51% 75'Y, 23.84 6.69 30.53 28''''' 4·/\ 44.51% 75% 10.86 2.61 13.47 PRiNCES:,. OI!El' 139.54 0.00 27'/0 3"/\ 44.51°.4 75% 16.77 3.14 19.91 44.51% 75'''' 0.00 0.00 0.00 QUEE.V 361.46 Gray 133.41 24% 4% 44.51"'''' 75'Y, 38.61 10.84 49.46 26% 4% 44.51 % 75'), 16.63 4.00 20.63 QUEEN '-84.64 Light Blue 176.90 24'''' 4'/\ 44.51',4 75'" 49.66 13.95 63.60 28'''' 4% 44.51 ',4 75% 22.30 5.37 27.66 QUEEN 481.95 IM'Ilte 188.19 24'''' 4% 44.51 '''' 75% 51.48 14.46 65.94 27% 3% 44.51',4**7M~** 22.62 4.23 26.85 QUEbW 322.66 0.00 27',4 3% 44.510/. 750/. 38.78 7.26 46.04 44.51'.4 75'''' 0.00 0.00 0.00 ROMA,\' 1044.67 0.00 27'''- 3% 44.51% 750/, 17.39 3.26 20.64 44.51% 75'" 0.00 0.00 0.00

### FROM: DATE: 

### RE: 

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

Robert Haberlein, Ph.D.• QEP, EngineeringEnvironmental Consulting ervices July 16. 2009 Maximum Hourly YOM Emissions, Royal Fiberglass Pools. Dix, Illinois
The maximum hourly YOM emission rate is based on the following assumptions: I. Maximum process emissions occurduring the gelcoating process (gelcoat application emits at about twice the resin application rate). 2. According to actual usage data for CY 2008, the maximum gelcoat emissions occur when the greatest-cmitting and second greatest-emitting colored pool models are gclcoated simultaneously in the same onc-hourperiod. 3. The greatest gelcoat-cmitting pool model is a Duchess Pool with aRoyal Sapphire fInish, which emits 78.55 Ibs YOM per hour (see Exhibit C to the CAAPP revision). 4. The second greatest gelcoat-emittingpool model is a King ShallowPool with a Sand finish, which emits 78.15 lbs YOM per hour (again see Exhibit C to the CAAPP revision). The corresponding maximum facility-wide hourly YOM emission rate is: 78.55 + 78.15 = 

### 156.70 Ibs YOM per hour.
Themaximum resin application YOM emission rate for one pool is based on the following assumptions: I. Maximum resin usage rate of1.5 gallons per hour which is equivalent to 812 Ibs per hour or about 

### 50010ofthe total resin used per pool. 2. Resin styrcne content of47.5% by weight. 3. UEF emission factor for non-atomized resin application equal to 12.23 % styrene content weight The maximum single-pool rein applicationhourly YOM emission rate is: 812 x 47.5% x 12.23% 

## = 47.171bs VO 1 per hour The corresponding maximum facility-wide hourly YOM emission rate for simultaneous resin application to two pool molds is twice the single-pool rate: 47.17 +47.17 = 

### 94.341bs YOM perhour.

### Electronic Filing - Received, Clerk's Office, July 17, 2009



# EXHIBIT 3" 

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009 ENGINEERlNG ENVIRONMENTAL CONSULTING SERVICES 

### Cost ofControls for the Dix Plant June 19.2009 Page I of23 

## A ALYSIS 

# Control Cost for a Regenerative Thermal Oxidation System at the Royal Pools Facility in Dix, Illinois prepared under the supervision of Mr. Dale A. 

### Guariglia Bryan Cave LLP One Metropolitan Square 211 N. 

### Broadway Suite 3600 Sl. Louis, Missouri 63102-2750

on the behalfof Royal Pool, Inc. Breaux £3ridge, Louisiana
by

# ~a~---- RobertA. Haberlein. Ph.D., QEP Engineering Environmental Two FiskCircle Annapolis, Maryland 2 I40J

### -3212
June 19,2009

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL 

## co SULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 2 of23 

## Executive Summary IfRoyal Pools' Dix, Illinois facility were to install add-on emission controls, thermal oxidation is the only commercially available technology that is generally free ofteehnical problems for controlling styrene vaporemissions from composite facilities. A small skid-mounted regenerative thermal oxidizer unit is the mostpractical thermal oxidation option for the facility. As detailed in this report, a skid-mounted RTO control system would have the following characteristics and costs:

• The installed capital cost would 

### be $709,500.

• The operating cost would 

### be $473,000 peryear.

• The amount ofreduced annual styrene emissions would be about25.71 tpy (assuming 29.76 tpy at 86% overall capture & conlrol efficiency

- 90% capture and 96% control).

• The costeffectiveness would 

### be about $18,400 per ton reduced styrene emissions peryear. Therefore, the RTO system is too expensive and would not 

### be economically feasiblc at the Royal Pools' Dix, Illinois facility.

## Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CO SULTI C SERVICES Cost ofControls for the Dix Plant June 19.2009 Page 3 of23 

## Section 1

- Introduction Purpose This report provides an updated and detailed !Jest Available Control Technology (!JACT) cost analysis ofthe economic feasibility ofa skid-mounted regenerative thermal oxidation system for a small, reinforced plastic composite pool manufacturing facility located in Dix. Illinois, which is henceforth called the "Dix Plant." This facility is owned and operated by Royal Pools, Inc. This updated and detailed control cost analysis was requested by the lIIinois Environmcntal Protection Agency (lEPA) to support a petition request by Royal Pools for an adjusted standard that would allow the Dix Plantto emit more than eightpounds ofVOC per hour when fabricating a large composite pool part. Background As detailed in Table I ofthe compliance pl"n submitted to JEPA in 2005 (please see the next page). thermal oxidation is the only proven, commercially available control technology for controlling exhaust streams from a small. reinforced plastic composite facilities such as the Dix Plant. As shown in this table and discussed in Section III ofthis report, a pre-packaged skidmounted RTO system is the least expensive oxidation technology for exhaust streams less than 50.000 cfm. Adwest is a leading manufacturer ofskid-mounted RTO systems with competitive RTO equipment prices. Forthese reasons. this control cost analysis is based on a skid-mounted RTO unit manufactured by Adwest. The cost analysis procedure in this analysis follows the guidelines for small RTO systems that are set forth in the 

### OAQPS Control Cost Manual- Sixth Edition. References This report utilizes information on air pollution control systems from the following reference sources:

• EPA's 

### "Top-Down" Best/lvailable Control Technology Guidance Document

• EPA's 

### Handbooka/Control Technologies/or Hazardou.\ AirPollutants

• EPA's

### Assessment ofSryrene Emission Controls/orFRPICandBoat BuildingIndustries

• Air pollution control cost guidelines in the EPA 

### OAQPS Contml Cost Manual- Sitth Edition

• ACMA's 

### Feasibility andCosta/the Captw'e andControl 

## of HazardousAirPollutant Emissions/rom the Open Molding of Rein/arcedPlastiC Composites

• Recent control system quotes and communications from Adwest

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGrNEERI G ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 4 of23


### Table I Commercially Available Air Pollution Controls (Reprinted from the Feb 28.2005 compliance plan submitted to JEPA)
I 'Status at the Technology Applicability Concerns DixPlint 

## I Absorption Styrene in nearlv insoluble in water infeasible 

# I Adsorption Styrene polymeri,es on sorbent media Desorbed styrene is not reusable infeasible Desorbed stvrene must be disposed as hazardous waste. Biodigestion Microbes are unreliable and must stay warm and moist infeasible Digestion beds must be huge to handle exhaust airOow Styrene concentration in air too low to be economic Condensation Condensate is mostly water with trace styrene infeasible Condensate must be disposed as haLardous waste. Flare Stvrene concentration in air is too low to 

### be economic infeasible TO Conventional recuperative oxidation is always more RTO is better costlv than RTO

- SEE below Regenerative thermal oxidation is currently employed technically at one truck cap plant and several large bathware plants feasible that produce small parts on automated production lines, Oxidation RTO operate continuously (24 hr/day, 360 dayslyr) and have economically uocontrolled styrene emissions >250 tpy. A RTO infeasible system large enough to handle the 50,000 cfm exhaust airOow at the Dix Plant would cost over $600,000 to install and over $300,000 peryearto ooerate. CO Catalytic media has a relatively short lifetime and is infeasible unreliable Preconcentrators are currently employed at four large technically bathware plants. The long-term performance ofthe questionable adsorber is questionable due to an unexpected failure of Preconcentrator the activated charcoal sorbent media at one ofthe sites. economically wlRTO A preconcentrator system large enough to handle the proposed 50,000 cfm exhaust airflow at the Dix Plant would cost almost one million dollars to install and orate. infeasible

Since 2005, some ofthe referenced preconcentrator systems have been decommissioned and demolished and the original preconcentrator system has failed twice, leading to enforcement actions against the facility. The preconcentratorprocess is a still a technically questionable control technology for reinforced plastic composite fucilities.

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009 ENGINEERlNG ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 5 of23 

## Section II

- 

## Description ofFacility and Operations Facility Operations The Dix Plant produces large reinforced plastic composites pools using the mechanical atomized gelcoat application and the mechanical non-atomized resin application processes. The raw production materials include fiberglass reinforcements, metal and wood reinforcements, highperformance gelcoats, and high-performance vinyl esterand isophthalic resins. The gelcoals and resins are mixed with a small amount oforganic peroxide initiatorto start the curing reaction. Normally, about 50-75% ofthe gelcoatprocess emissions occur during the application phase, and the 25-50% occurs during the curing phase. About 33-50% ofthe resin emissions occur during application, and 50-67% occurs during rollout and curing. All gelcoat and resin application at the plant takcs place inside three self-contained rooms, which are called "Bays," that are located inside the plant building. Most ofthe pool production occurs in the two main bays (Bay I and Bay 2), but pool finishing, part repair, and some occasional small pool production occurs in the third bay. All three bays are connected to acommon exhaust ventilation system. Existing Ventilation The exhaust ventilation for the three bays is currently provided by a single centrifugal fan connected to a single tall exhaust stack. The fan is rated at40,000 cfm maximum airflow. The proposed control system would be directly connected to the existing ventilation outlet using a new section of48-inch diameter duct and fittings. and the existing stack would be demolished. According to the ventilation designer, Mr. Jimmie TalbotofReed lndustrial Systems, Inc
.. Shreveport, Louisiana, the Dix system is a typical push-pull ventilation system. The push-pull design directs fresh supply air around a reduced work zone area around the pool molds inside the bays. 10st ofthe supply air is delivered by a mechanical airsupply unit. An important portion ofthe supply air enters through gaps underthe partially opened exterior bay doors. According to Tal""t, the doors should be opened about three to four feet above the floor for proper airflow and air motion in the work zones. The airflow induced by the supply air envelopes the pool mold and conducts most ofthe process vapors to the exhaust inlets locatcd at the back ofthe bays (opposite the doors), where a significant portion ofthe process emissions are collected and discharged through the exhaust stack. However, a portion ofthe process emissions is recirculated back to the bay spaces, because the volumes ofinduced airflow moving towards the inlets are normally greaterthan the exhaust airflow. In this circumstance, it is physically impossible for all ofthe air flowing towards the exhaust inlets to be captured althe inlets and some oflhis air must be recirculated back.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTINO SERVICES COSI ofControls for the Oix Plant June 19,2009 Page 6 of23
The original control costestimate in 2005 assumed the exhaust airflow was 50,000 acfm. At the request ofIEPA, the actual exhaust airflow was measured by a third-pany testing company. and Royal Pools has updated the original analysis using the actual measured airflow rate. The exhaust airflow rate in the exhaust slack was measured by CEC on May 19,2009. The rate was measured three times for two conditions, thc bay doors opened 1.5 feel and the doors wide open. The average exhaust airflows were 34.240 acfm and 34,810 acfm, respectively. The difference between the two conditions was negligible (less than 2%). This is explained by the fact that most ofthe supply air is furnished by a mechanical supply air system inside the bays, so the flow restriction caused by paniaJly closed doors has no appreciable effect on the exhaust airflow rate. Accordingly, an exhaust airflow rate of35,000 cfm. the nearest whole value derived from the recent third-pany stack measurementS by CEC, is assumed for this cost analysis. Capture Efficiency As discussed above, the ventilation system was designed to operate properly with the outside doors opened a minimum ofthree feet from the floor. The ventilation airflow was recently measured with the doors opened about 1.5 feet (18 inches), which was about one-halfofthe design gap distance specified by the system designer. The door gaps remain open during routine operation, so these gaps at the floor are natural drafl openings (NOO) as defined in EPA Reference Method 204. In order to meet the presumption of 100% capture as dctailcd in Method 204, the inward air velocity through these openings must average 200 fpm orgreater. The three outside doors are the same size, measuring 20 feet wide and 16 feet high each. The design open gap is 3 feel, so the open area is 3 x 20

## =60 

### ft2 perdoor or 180

## tt2 in total for the three doors. According to Mr. Talbot, approximately 80% ofthe supply air is delivered to the three bays from the mechanical supply air heater/handler unit. Hence. 20% ofthe supply air flows into the bays through the three open door gaps. The average inward air velocity through the door gaps can be estimated using a simple volumetric calculation. Assuming a 1.5-foot gap under each door (only 50% ofthe design value of3 feet) and 

### 20"10 ofthe lotal 35.000 acfm controlled airflow rale derived from the CEC measurements, the average air velocity through the NOOs is 20% x 35.000 cfm 

### I (3 x 1.5 x 20) 

### = 78 fpm. Hence, the actual average air velocity is only 39% ofthe minimum 200-fpm air velocity criterion required under EPA Reference Method 204 for 100% capture efficiency. The bays do not meet this criterion by a wide margin. so 100% capture ofthe process emissions inside the bays cannot be assumed.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 7 of23
The capture efficicncy ofthe bays is also impacted by anotherphysical phenomenon. Some of the bay walls and the bay ceilings are exterior building enclosure surfaces that are influenced by wind pressurc. The negative pressures caused by the flow ofwind, even light winds, will overwhelm the mechanically induced suction pressure created by the exhaust fan. This phenomenon is widely recognized and well documented, and is pan ofthe Docket for the Composite MACT rule (see the repon entitled 

### Feasibility and Costof the Capture and Conlral of HazardousAirPol/ulam Emissionsfrom Ihe Open Molding of ReinforcedPlaslic Composiles). Negative wind pressures could draw process emissions out ofthe building through numerous cracks and cervices for all wind directions, and through the open door gaps for about three-fourths ofthe possible wind directions. The degree ofloss depends on the wind direction and speed. The actual average capture efficiency is unknown and may be truly unknowable. Method 204 offers several field-test methods to measure the actual capture efficiency for short periods, but these complex methods are difficult, time-consuming, and prohibitively expensive to perfonn. Regardless, the outcome ofsuch testing would be so dependent on the wind speed and direction during the test runs that the results would not be accurate or representative. As explained above, the value cannot be either 0% or 100"10, so some intermediate value must be assumed in order to perfonn this cost analysis. Therefore, an interim value of90% capture efficiency is assumed to reflect the very low average air velocity through the NDO door-gap openings and the influence ofwind pressure on the exteriorenclosure walls and ceiling.
Maximum Emission Rates Prior to 2004, Royal Pools submitted an application to JEPA to pennitthe composite operations at the Dix Plant at a production level of250 pools per year. In 2004, Royal Pools requested two revisions to this pending application. The company raised the maximum pool production level to 400 pools per year and increased the corresponding annual emission estimate to 16.3 lpy. The revised emissions estimate was based on conditions, materials, and processes used at the Louisiana Plant in 2004, not the conditions ormaterials used at the Dix Plant. The original control cost estimate submitted to IEPA in 2005 included a detailed annual emission estimate for production ofall-white pools at the Dix Plant. Based on this original estimate, the maximum annual emission rate was about I 1.3 tpy for a production level of250 pools peryear. There have been several important changes in material types and usages per pool since 2005. The Dix Plant now produces colored pools (using two layers ofdifferent gelcoats) in addition to the all-white pools that were made in 2005. Further. the company now has four years ofmaterial usage data at the Dix Plant instead of just one year. A summary ofthis new data is listed in Table 2 on the next page.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Oix Plant June 19. 2009 Page 8 of23 

### Table 2 - Material Usages 

### at the Dix Plant for 2005 through 2008 Year Pools bUill peryear Hours worked manhours Manhours perpool Hours per pool (91'1O"'.'s) 2005 2006 2007 2008 158 188 200 161 27,657 28,714 30,002 21,340 175 lS3 150 133

19 17 17 15 A

ctua, Annual Malerial UsaQes Resins Iblyr 161,800 267,140 324,500

### 233,82~1 Geleoals Iblyr 35,704 51,475 71,727 55,607 Catalysts Iblyr 3,136 4,068 5,317 4,608

PUllies Ib/yr 0 0 0 0 Reported VOM Ib/yr 14,773 23,222 29,616 21,443

emissions tpv 7.39 11.61 14.81 11,65 Actual "Per-Pool" Usages Resins Iblpool 1,024 1,421 1,623 1,452 Gelcoats Ib/pool 226 274 359 345 Catalvsts tb/oool 19,8 21.6 26.6 28.6 Catalyst Ratio %wt 1.59% 1.28% 1.34% 1.59% Maximum "Per-Pool" Usages pe' original peractual usage data Sep 06 NOV plan 2005 through 2009 Ib/POol Ib/pool Resins 990 1,625 Gelcoats 220 360 Catalysts 19,2 32

PUllies 0 0 

### A detailed estimate ofthe maximum emission rate per pool at the Oix Plant, which is based on the worst-case malerial usage data for four years ofactual operations at Oix. is listed below: Geleoat

- Resin

-C'atalyst360 Ib geleoats x 27.0% styrene x 44.51 % styrene "1 = 360 Ib gelcoats x 

### 3.9"10 MMA content x 75% 

### MMA WI = 1,625 Ib resins x 47.5% styrene x 12.23% styrene WI = 321b x 2% 

### MEK x 100% 

### MEK WI = Total emissions per pool = 43.261b 10.531b 94.37 Ib

0.64 Ib 148.801b Royal Pools has reviewed the above estimate and believes that it more accurately reflects the current conditions at the Oix Plant. The corresponding maximum annual emission rate at a production level of400 pools per year is now: 400 pools/yr x 148.80 Iblhr/2,000 Iblton = 29.76 tpy Forthis reason, a maximum annual emission rate of29.76 tpy is used in this cost analysis.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTINa SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 9 of23
Maximum Production Hours-or-Operation and Annual Control Period IEPA suggested that Royal Pools usc the conditions specified in the 2004 pennit application revision request for this control cost analysis. However, the 2004 request did not include any hours-of-operation limitation. Without such limitation, the facility could hypothetically operate continuously for 8,760 hours per year (non-leap years), so strictly speaking, this analysis should be made at 8,760 hours peryear. However. a presumption ofcontinuous operation is not reasonable for a production level of400 pools peryear at the Dix Planl. Obviously, a more reasonable assumption should be made for this analysis. Historically, the Dix Plant has produced pools during three seasons and then shutdown production during the coldest partofthe winter season. However, Royal Pools plans to build pools during the winter seasons in the future, afterthe pool market improves and stockpiling an inventory ofpools becomes feasible. Thus, full four-season operation must be assumed for this analysis. The Dix Plant needs a full 8-hour workshift to build 250 large pools peryear. However, the plant has never produced 250 pools peryear, so the additional labor requirements for 400-poolsper-year are not well documented. Aecording to best estimates by Royal Pools, the production of400 pools peryear would require a full second-shift at the Dix Plant. Less than two shifts would result in significant overtime costs and scheduling problems. Hence, a full four-season two-shift production period is assumed for this cost analysis, which is equivalent to: 250 days/yr x 16 hrslday = 4,000 work hours peryear In reality, the control system must be operated longerthan the 4,000-hour work period assumed above for two important reaSOns. First, the oxidizerunit must be pre-heated to the prescribed 1,600 F oxidation temperature before the star! ofproduction. The unit preheating will require about one hour offiring with supplemental natural gas fuel on Monday mornings due to the prolonged two-day weekend unit shutdown and about 30 minutes ofpreheating on the other \\eekday mornings duc to the shorterovernight unit shutdown period. Second, the oxidizer unit must be operated for about 15 minutes after the end ofoperations each workday to collcct and destroy the process emissions that have accumulated inside the bay spaces. The total maximum control period. which includes the maximum production period and the additional preheat and after-work control periods, is computed as follows: Two-shift production period 4,000 hrslyr Monday mornings 50 peryear x I hrslday = 50 hrslyr Otherweekday mornings 200 peryear x 0.5 hrslday = 104 hrslyr After-work periods 250 peryear x 0.25 hrs/day = 63 hrslyr Total annual control period 4,213 hrs/yr Accordingly, a control period of4,213 hours peryear is assumed for this cost analysis.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRO MENTAL CONSULTl'iG SERVICES Cost ofControls for the Oix Plant June 19, 2009 Page 10 of23
Exhaust Styrene CODcentration The Ideal Gas 

### Law and molecular weight ofstyrene can be used to convert the maximum annual emission rate into the corresponding average styrene concentration in the exhaust airflow. MMA and slyrene have nearly the same molecular weight (104 for SlYrene and 100 for MMA) so styrene values can be uscd for both pollutants. The average hourly emission rate for an annual emission rate of29.76 tpy with acapture efficiency of90% over a control period of4,123 hr/yr result is 12.99Ib1hr. The styrene exhaustconcentration calculation is shown in Table 

### 3 below. 

### Table 3 - Styrene Exhaust Concentration Calculations 

## e 2005 Enginser1ng Environmental MolecularWt (MW) Standard Volume SV) Knowns 104.1 24.45 Styrene @77"F& 1 aIm Unknown 24.04@68'F Average Styrene Styrene Flow Rate Emission Cone Q E C (d.cfm) (Iblhr) (ppmv) 35,000 150 268.7 35,000 14.88 26.7 35,000 12.99 23.3 

## c = 35,53 x 453 600 x SV x E 60xMWxQ peak hourly (gelcoating) annual average production period annual average control period 90% caplure

Based on the foregoing, the plant-wide annual average hourly emission rate for all operations is greater than the 8-Ib-perhour VOM emissions standard. The annual average control period concentration is surprising low. The low concentration is an unavoidable consequence oflong periods oflow emissions punctuated by short periods ofvery high emissions. The process ventilation system and companion control system must be sized large enough to protect the workers against chemical exposure at peak emissions, but then the system must continue to operate during the subsequent period oflow emissions. This unique fealurc ofcomposites manufacturing is the main reason that federal EPA did not require add-on controls for small sources in the Composite MACT rule.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 E GiNEERING ENVIRONMENTAL CONSULTING SERVICES CostofControls for the Dix Plant June 19,2009 Page II 01'23 

## Section JJI - Thennal 

## Oxidation Background A thermal oxidation system uses thermal energy to oxidize the organic vapors in the plant exhaust. The oxidation process involves the high temperature destruction ofthe organic compounds into the combustion byproducts carbon dioxidc (C02) and water vapor (H20). Theoretically, any hydrocarbon compound is complctely oxidized according 10 the following equation: C,llb 

### + (a 

### + 0.25b) O2 

### --> (a) CO2 

### + (0.5b) H 2

0 For a natural gas-fired incinerator burning styrene vapor, the oxidation equations are: CH, 

### + (I 

### + 0.25 x4) --> CO2 

### + 2 H20 CsHs 

### + (8 

### +0.25x8) O2 --> 8 CO2 

### + 4 H20 The performance ofan oxidizer is commonly characterized by three imponant parameters known as the "Three Ts:" 

### I. Temperature

- the oxidation reaction rate is accelerated at elevated temperatures. 11igher temperatures cause faster oxidation rates and higherdestruction efficiencies. In orderto ensure a destruction efficiency of99%. styrene vaporrequires thennal oxidation temperature between 1,800 and 2.000°F with an associated retention time ofI to 2 seconds. Acetone vapor requires an oxidation temperature of 1.800°F with a retention time of V, to I second. Lower oxidation temperatures generally result in lower destruction efficiencies. as follows: • I,525°F

- the performance test ofa RTO unit with an average oxidation temperature of I,525°F revealed an excessive level ofsecondary carbon monoxide (CO) emissions in the exhaust that was unacceptable to the local EPA authorities.

• 1.575°F -the average oxidation temperature for the aforementioned RTO unit was increased from ofI,525°F to I,575°F. and the unit was retested. The concentration of secondary CO emissions in the exhaust dropped significantly to an acceptable level. lligheroxidation temperatures apparently resulted in lower secondary CO emissions.

• 1.600°F

- several existing RTO units at composite facilities have an oxidation temperature setting ofabout 1.600°F for styrene applications. This temperature corresponds to measured styrene destruction efficiencies 01'98% or higher. and appears to result in the best balance ofsecondary CO and nitrogen oxide (NOx) emiSSions.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 12 of23


### 2. Time

- in order for the oxidation reaction to occur. the exhaust must remain at the reaction temperature for a minimum amount oftime, called the "residence" or "retention" time. Greaterdestruction efficiencies result from longerresidence times. Note that the temperature and time are inversely proportional (although nonlinear) to each other in determining destruction efficiency. 

### 3. Turbulence

- is required to enSUre that the exhaust is well mixed throughout the incineration chamber. Otherwise, a portion ofthe exhaust could pass through the chamber without adequate oxidation. Note that turbulence is not directly related to either temperature ortime, but is a necessary condition for high destruction efficiency. 

### Oxidation Technologies An oxidation system may be characterized according to two differenttechnology classification schemes:

• Oxidation method

- "thermal" or "catalytic." Thermal oxidation is a mature control option that has been installed at several composites manufacturing facilities. No special technical problems are expected. Catalytic oxidization utilizes special catalytic cells, honeycombs, orcoated beds thatcontain special catalyst materials. These catalyst materials consist ofprecious metals. such as platinum-coated orpalladium-coated ceramic beads, orbase metals, such as magnesium oxide particles. The catalyst haslens the oxidation oforganic pollutant vapors at much lower temperatwes than for straight thermal oxidation. The lower oxidation temperatures result in reduced supplemental fuel requirements and smaller amounts ofsecondary emissions from the oxidizer, such as carbon monoxides and nitrogen oxides.

• Heat energy recovery method

- "recuperative" or "regenerative:' Recuperative systems use heat exchangers and regenerative system use large thermal masses to recover oxidation heat. The aforementioned oxidation technology classification schemes result in four possible system technology types: I. Recuperative Thermal Oxidatioo

- uses a heat exchanger to transfer the thermal energy from the oxidizer exhaust airstream to the inlet airstream. In this application, the heat exchanger normally consists ofrelatively thin metallic surfaces that serve to physically separate the two flow streams, yet still efficiently transferthe heat energy. These thin metallic surfaces are prone to mechanical and thermal damage at elevated temperatures, so a recuperative oxidizer is usually limited to chamber temperatures less than 1.600°F. 2. Regenerative Thermal Oxidation (RTO)

- cycles the heat energy back and forth between the inletand outlet airstreams using an arrangement ofthermal masses. The

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTINC SERVICES CostofControls for the Dix Plant June 19, 2009 Page 

### 1301'23 equipment is designed so that the hot exhaust gas heats a storage mass, usually a heatresistant ceramic material, as the gas exits the very hot oxidation chamber. Once this storage mass has reached a preset temperature, the exhaust now is redirected and the relatively cool styrene-laden plant exhaust nows through the heated mass. The energy stored in the thermal mass then heats the plant exhaust before it enters the oxidation chamber. As much as 95% ofthe thermal energy can be recovered and reused in this manner 

### 3. Recuperative Catalytic Oxidation

- combines the features ofcatalytic oxidation with recuperative heat recovery by incorporating a heat exchanger to transfer thermal energy from the oxidizer outlet stream to tbe inlet stream. 4. Regenerative Catalytic Oxidation (RCO)

- combines the features ofcatalytic oxidation with the benefits ofregenerative heat recovery. A RCO is very similar to a typical RTO unit, exccpt that small layeror a fine coating ofcatalyst is added to the thermal regeneration masses. Problems with Catalytic Oxidation Systems Catalytic oxidation is more complicated than thermal oxidation and has four unique problems: 

### I. CatalystDeactivation

- refers to the steady deterioration in destruction efficiency caused by the deactivation ofthe catalyst. The transient nature ofthe catalytic effect requires careful system design and periodic replacement ofthe catalyst media. The catalyst in most systems is usually replaced every three to five years, but it may require annual replacement in some applications. Due to the unpredictable nature ofthe catalyst performance, continuous emissions monitoring may also be required by some regulatory agencies to verify the effectiveness ofthe catalyst. Such long-term monitoring is quite difficult for styrene vapor. 

### 2.**Cata~vst** 

### Poisoning

- is caused by various airborne contaminants, such as heavy metals, silicates, and sulfur, which poison the catalyst. This poisoning reduces the beneficial effect ofthe catalyst and requires the catalytic media to be replaced soonerthan the expected service life. The problem ofpoisoning can be so sudden, severe, and unpredictable in some cases that catalytic oxidation is prohibited as a control option by the local reviewing agency. [Palkar. A. el al.: "Ilazardous AirPollution Control**Technolog~s:** An O\C:rvicw," New HazNdou$ AirPollutant

### La",and Regulations, SP·S2: A&WMA, Pittsburgh, PA; 1992]. 

### The problem ofpremature catalyst failure in a catalytic oxidizerwas discussed with U.S.EPA during MACTpromulgation, because the composites industry is likely to generate airborne catalytic poisons. Direct, firsthand evidence ofthis problem is available for the Polyad system at the American Standard fiberglass bathware facility in Ohio. The Polyad system used a catalytic oxidizer to destroy concentrated styrene vapor. However, catalyst poisoning caused the failure ofthe catalytic oxidizer. A core sample ofthe catalyst honeycomb was removed and analyzed for contamination. The analysis confirmed the

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES CostofControls for the Dix Plant June 19,2009 Page 14 of23 catalyst failure. An extremely large amount ofsilicon, and trace amounts ofphosphorus, chlorine, and sulfurcompounds were detected in the catalyst. Silicon is a common airborne contaminant at many composite plants (airborne glass dust and fiber) and was the suspected agent in this catalyst failure [A", 29 '97 phon< ,oo",,.toon w,th Magnus O,nod"'n. Woa't>edy]. This experience offers a clear warning that catalytic oxidation is not suitable for composite facilities. 

### 3. CaialyslPluggillg

- involves the small openings in the catalyst bed that can become plugged with foreign matterentrained into the exhauS! stream. Significant quantities of dust and aerosol in the exhaust airstream are common to composites industry. Large resin aerosols can be easily removed by normal air filters, but fine dust and tiny aerosols are more difficult to remove. A thicker filter pad ofthe same filter media generally does not significantly increase the collection efficiency for tiny aerosols. A different media (much finer and more expensive) is needed instead. Indeed, any common filter media, no maller how thickcannot effectively collect the very tiny aerosol droplets. These tiny aerosols require a more sophisticated collection device. The filter pad installation at many plants is often "casual," resulting in gaps and holes, but this is aCOmmon problem and would be very difficult to avoid in practice. A completely different filter system and/ormedia would be needed to ensure a more "formal" installation. 

### 4. Prejil/ralioll Cos/- is the most frequent solution proposed to prevent catalytic poisoning is a high-efficiency prefiltration system. Ifproperly designed and maintained such a prefiltration system could greatly reduce, but not eliminate, the plugging problem. However, the costofa high-efficiency filtration system can be great for large and dirty air streams, which are Common at many open molding plants. Forexample, Aker Plastics composites manufacturing plant in West Virginia installed a high-efficiency prefiltration system to remove dust and aerosol from the exhaust airstream in the plant's exhaust streams. 

### Control System Design The proposed RTO control system will include the following design features:



### • Duc/work

- will connect the existing exhaust outlets to the RTO unit inlet. This connection will consist ofapproximately 100 feet of48-inch diameter galvanized steel spiral duct and four48-inch galvanized steel elbow fittings. The cost ofthe ductwork material is given by the cost equations listed in Table 1.9 and Table 1.10 in Section 2 ofthe OAQPS Control Cost Manual. These OAQPS ductwork costs, which were developed in 1995, are adjusted to 2009 dollars using the Producer Price Index ratio of 1.394 for sheet metal manufacturing from the U.S. Bureau ofLabor statistical database for the period from 1995 to 2009. The ductwork material costs are computed in Table 4 on the next page. The ductwork installation cost is included in the overall control system costestimate.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERlNG ENVIRONME TAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 1501'23 

### Table 4 - Ductwork Material Costs according to 

### OAQPS Duct diameter 

### =

Inflation Factor 

### $20W $,••

### s

# =187.5/134.5 Galvanizedspiralsteel duct Cost per

### ft $,09S

# =1.55 

### D·J6 Cost $,••s Cost $200. Galvanizedsteel elbows Costeach 

### $,
..s = 30.4 eO.os••(O) Cost $,••s Cost$2009 Total ductwork material cost 48 in 1.394

100 

### ft $58 

### 1ft $5,807 $8,096 

### 4 ea $258 ea $1,032 $1,438 $9,534 OAOPS Cost Manual Section 2 - Table 1.9

OAOPS Cost Manual Section 2 - Table 1.10

• COllcre/ePad

- the skid-mounted RTO uoit will 

### be mounted on a large steel-reinforced concrete pad that will 

### be placed at an open area next the plant building. This pad must be designed to support the weight ofthe heavy IUO unit, and will require soil testing and special engineering approval. The cost ofthe design and installation ofthis pad is included as part ofthe overall OAQPS control cost estimate.

• Ills/allation

- a skid-mounted RTO system is a packaged unit that would require a mioimal effort to install and start-up at the site. Forthis reason, the construction and startup line items in the OAQPS cost procedure are setto zero.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 16 of23 

## Control System CostAssumptions and Parameters

• AllllualcOlltrolperiod- is 4,213 hours per years as previously discussed in Section II. This period covers a two-shift schedule and includes the startup. operating, and shutdown periods.



### • RTO equipmentcost- is $408,833 FOB Anaheim using Adwest costs and cost multipliers as shown in Figure 1 below: 

### Figure 1

" 

### , EquipmentCostofSkid-Mounted RTO Units· 2006 2009 data $500,000 

### r---------------------.

### .:::~-';c:::.-.T_---- ..
$400,000

### I----T----i---::::~p-==---t:::::::::::;:;;;:i

o $300,000**+-----+--?"'~-+-_=_==__j------t-----__j** 

### u 

### C 

# .. E 

### .9- $200,000 t---7""-",-1i----- 

### 1------1------;------1 

# " ,[ $100,000 

### +-''"----.L-----!-----l-----ii------f

Airflow Capacity (efOl)

... 2009 data --2009 est • 2006 data

__PaNer (2006dala) 

### y =491 0.3x'·"""

R' =0,9842 $0**+----~---_+---_b---+._-------l** 

### o 10,000 20,000 30,000 40,000

The dark red line is the purchase C051 equation (expressed as a power function) for skid-mounted RTO units made by Adwe51. The data regression has a R2 correlation ofover0.98, which indicates a very accurate regression fit This power function equation was used to estimate the RTO cost in the original cost analysis submitted to [EPA. However, according to Adwest, the purchase cost in 2009 will 

### be at lea51 20% greater than the purchase cost in 2006 due chiefly to substantial increases in steel and ceramic media. which are energy sensitive raw materials. Thus, the original curve is modified by a factor of 120% to account for these cost increase (see the blue line). Five recent 2009 RTO unit quotes (shown as blue triangles) are plotted on the 2009 cost curve to verify the accuracy ofthe new 2009 cost curve. Ironically, the 2009 purchase cost for the smaller 35,000 cfm RTO unit is slightly greater than the original 2006 purchase cost for the larger 50.000 cfm RTO unit.

## Electronic Filing - Received, Clerk's Office, July 17,2009 ENGINEERING ENVIRONMENTAL COI\SULTlNG SERVICES 

### Cost of ontrols for the Dix Plant June 19,2009 

### Page 1701'23



### • Siale ant/localsalestax- is 7.75% 

### ofthe purchased equipment cost (PEC) for Jefferson County. Illinois.



### • Freight

- 6% 

### ofPEC, which is greater than the OAQPS default value in 2000 

### due to the significant increases in freight costs since 2000.



### • Ductwork materialcost- i $9,534 

### as computed earlier in Table 4.



### • System**pre~'~'ure** 

### t/rop

- is the sum ofthe pressure drops in the ductwork and RTO unit. According to Adwest, the combined pressure drop ofthe ductwork and unit will be 19 

### + 2 = 

### 21 

### inches water gauge (w.g.).



### • Fan efficiency

- assumed 70%, 

### which is the high bound ofthe OAQPS range of40 

### to 70%.



### • Malarefficiency

- assumed 90%. 

### which is the high bound ofthe OAQPS range for motors.



### • Overt/IIelectricalefficiency

- 70% x 

### 90% = 

### 63%.



### • Electricity role

- $0.15 

### per kWhr is assumed for this cost analysis based on the comparable rates for the past few years and the likelihood ofproportionally higherelectricity rates for the next ten-yearperiod,. This is an educated guess, because even the experts on electricity costs disagree on future rates for the next ten years, except thatthe rates will probably be much higher than today.



### • Annualelectricity cost- would be $90,563 

### peryearas computed in Tahle 5 

### below using the OAQPS equation. The total cost includes an additional 5% 

### to operate the other equipment associated with control system. Tahle 

### 5 - Annual Electricity Utility Cost
Vari:llble Description Value 

### Unlb Source Qexh 

### ExhaustAirflow 35,000 clm dP 

### Total pressuredrop 21 inw.g. 

### Adwest3109 E

motcw 

### Motorefficiency 90';' OAOPS Ebn 

### Fanefficiency 70% OAOPS4Cl-70% E

tobl 

### Combinedefficiency 63% Elf'OIarxEr.. 

### OAOPS 6Cl-70%

Electrical power rate 

### 137 kW H", Annual operating hours 

### 4,212.5Ihrlyr see hours sheet 

### E.,. Annual electricity usage 575,006 IkW1r 

### R,,"'ct Electricity utility 

### rate $0.15 lperkW1r est201Cl-2019 S. 

### = 

# I $86,251 Iyr 

# I Add 5% 

### for unitcontrols and otherpowered control-related equipment 

# I $90,563 Iyr 

# I

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 18 of23

o 

### Interest rate- is assumed at 7% peryear, which is the OAQPS dcfault value. IEPA specifically directed this interest rate value in spite ofthe fact that IEPA also understands that a small facility such as the Dix Plantcould not secure financing for a large airpollution control system at any interest rate under currenteconomic conditions. IfRoyal Pools were forced to secure funding, the real interest rate might be 20 or 30%.

o 

### Equipmentlifetime

- is assumed at 10 years, which is the OAQPS default value.

o 

### Naturalgas rate - is assumed at $15 perthousand cubic feet (MCF) which includes delivery charges and taxes.

o 

### Thermal efficiency of RTO linit

- would be at least 95% according to Adwest.

o 

### Annllalnatllralgass"pplementalf"elcost- would 

### be $2J5,950 peryear according to the OAQPS supplemental fuel equation for thermal oxidation, which is shown in Table 6 on the next page. The OAQPS equation requires an estimate ofthe specific heat value for air at 1,600 OF, which is provided in Table 7.

o 

### Direct annllalcost otherthan IItilities

- includes overhead, administrative charges, property taxes and insurance. The standard OAPQS values for these items are assumed

o 

### Performance test -the OAQPS default value signiftcantly underestimates the current cost of a Method 25A test. The typical cost for such atest, including the protocol, site prep, actual testing and test reporting, is $10,000. The analysis presumes that a performance test will be required by IL EPA every five years, which is equivalentto $2,000 peryear.

o 

### Filter replacement-would be $7,000 peryear based on $0.20-per-cfm-per-year for similar high efficiency filters.

o 

### Indirect annualcosts- includes overhead, administrative charges, property taxes and insurance. The standard OAPQS values for these items are assumed.

o 

### Capture effiCiency

- is assumed at 90%, as discussed in Section 11.



### • RTO oxidizerdestrllctian efficiency

- assumed to 

### be 96% based on 1,600 OF oxidation temperature and actual performance test results for other units operated atthis temperature. The detailed control cost calculation for the RTO control system, which follows the procedures described in the OAQPS Control CostManual using the abovementioned assumptions and values, is shown in Table 8 on the following two pages. This calculation includes the total capital investment and total annual operating cost and the control cost efTectiveness.

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERlNG ENVIRONMENTAL CONSIJLTING SERVICES Cost ofControls fOI' the Dix Plant June 19,2009 Page 190f23 

### Table 6 - Annual Natural Gas Utility Cost Calculation of RTO Auxiliary Fuel Usage and Fuel Cost Reference - EPA-OAQPS Control Cost Manual EPA 450/3-90-006 (revised Appendix 38) 2007 Engineering Environmental

Boundy& Boyer, 1952 ideal drygasat77 F

1001 Btu/ftJ OAQPSAppendix3B, 3-72

OAQPSAppendix38, 3·71 natural gas density natural gas volumetric flow rate annual operating hours annual auxiliary fuel consumption natural gas utility rate Pwl 0.0737 Ibltt' waste gas inlet density Qwi 35,000 ft?/min waste gas inlet volumetric flow rate Qto 35,057 It'/min nue outlet volumetric now rate T

wi 7-7 of waste gas inlet temperature Two 1.524 'F waste gas r"gen outlet temeprature T 1,600 'F combustion temperature TtD 153 'F exhaust (nue) temperature T,et.at 77 'F reference temperature (auxiliary fuet inlet) OAQPSAppendix3B, 3-71 

## C

pm '.;;;-;; 

## 0 Btunb-'F average specific**h~at** ofair lIh,tyrene 4,805 Blulft3 heat value of pure styrene vapor m 5t)'rene 23.3 ppmv organic volumetric conlent lIhcwi 0.112 Btu/lt3 heat value oforganic volumetric content lIHcWi 1.5 Btullb heat value oforganic mass content lIHcat 22,750 Blullb heat value of natural gas auxiliary fuel r,loss 1% heat loss from equipment surfaces 'llhcnn 95% overall thermal efficiency ofRTO P.t Q.t 

### =Pw' Qw' {[Cpm [n,o
.. (T.-T**~,I** + (T,,-Tw,l]- Llh,w') / (Llh"r' C.m[n",
.. (Tn-T
..,) + (T'o-T**~r)J)** 2.506 Ib/min

. auxiliary fuel usage mass rate 3.42 MMBtu/hr Pat 0.0440 Iblft' Qat 57.0 It'/min HrYR 4,213 hr/yr Qgasy, 143,967 CCF/yr Rga, $15 / MCF $gasyr = Rgas Qguyr/1 0 

# I $215,950 / yr

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES 

### Cost ofControls for the Dix Plant June 19, 2009 Page 20 of23 

### Table 7 - Specific Heat Value for Air at 1,600°F Calculation of Specific Heat for Air Reference· EPA·OAQPS Control Cost Manual EPA 45013·90-006 Table 3.13 © 2007 Engineering Environmental

cp =6.713 + 0.04697'10" T+ 0.1147'10" T'· 0.4696'10" 

### T' For OAQPS Method 

# I T,= 1,600 'F 1144 oK T, = 77'F 298 'K 1 Ib-mole= 453.6 g-mol 24.45 Vgmol @ 77 'F 11090.533 I 1/b-mole= 391.7532 ft3 Cp = 6.046513612 Btunb.mole-F air density 0.0739 Ibm' @ 77 'F 0.020544657 Btu/ft3-F 0.277699623 Btunb·F 

## rCp dT = 6.713 xT+ 0.04697'10" T' /2 + 0.1147'10" T' /3·0.4696 '10" 

# r 14

Cair = 

### ID.!:!I T

2 - T, T, 6359.3 1144.1 T, 2030.5

298 = 7.480 Btulib·mole·'F 0.0191 Btu/ft'·'F 0.2583 Blunb·'F

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CO SULTI G SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 2 I of23 

### Table 8 - Control Cost Calculation for the RTO System Calculation of Control Costs for Regenerative Thermal Oxidation Reference - EPA-OAQPS Control Cost Manual**EPAl4521B·02~01** (revised Sep 2000) adjusted for small skid-rnounted RTO unit perAdwest Costs @2007 Engineering Environmental CAPITAL COSTS NOTES DirectCosts PurchasedEquipment Costs Control Equipment Cost (EC) EC Skid·mounted RTO unit 35,000 cfm $408,833 Adwest cost data Auxiliary Equipment AUX Ductwork Materials $9,534 see ductwork cosl Pressure Controller $10,400 Adwestquote A= EC +AUX $428,767 Instrumentation - controller upgrade $4,600 Adwestquote Sales Tax 7.75% ofA $32,158 Jefferson Co sales tax Freight 6% of A $25,726 Anaheim CA 10 Dix IL PurchasedEquipment Cost (PEC) B = PEC $491,251 Direct Installation Costs Foundations and Supports 8% of8 $39,300 Handling and Erection 6% of B $29,475 reduced for skid-mount Electrical 2% of 8 $9,825 reduced forskid-mount Piping 2% 018 $9,825 Insulation lor Ductwork 1% alB $4,913 Painting 1%018 $4,913 Direct Installation Costs (OIC) DIC =20% 01 PEC $98,250 OAQPS minimum Site Preparation SP $5,000 seaJnty fence $5,000 demo existing slack 8uildings 81dg $0 TotalDirect Cost (DC) DC $594,501 Indirect Costs (Installation) Engineering 10% 01 8 $49,125 Construction and Field Expense by Adwest $0 included by Adwe51 Contractor Fees 10"kol8 $49,125 Start-up by Adwe.l $0 inetuded byAd.....esl Performance Test EPA Method source test $2,000 S-yr test estimate Contingencies 3%018 $14?38 Total IndIrect Costs (IC) IC $114,988 Total Capitallnvestrrlent (TCI) TCI 

### =DC +IC $709,488

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Oix Plant June 19,2009 Page 22 of23



### Table 8, continued

- Control Cost Calculation for the RTO System, Continued ANNUAL COSTS DirectAnnual Costs (DAC) Operating Labor Operator Supervisor Operating Materials Maintenance Labor Materials Replacement Costs High-efficiency air finers Utilities EIec1ricity Supplemental Fuel Total DirectAnnual Cost(DAC) IndirectAnnual Costs (lAC) Overhead Administrative Charges Property Taxes Insurance**Cap~al** Recovery (Amcrtized TCI) Return on Investment (%) Economic L'fe (yr) Capital Recovery Factor (CRF) Total IndirectAnnual Cost(lAC) Total Annual Cost (TAC) EMISSIONS REDUCTION Uncontrolled Plant Emissions Fraction of PTE to be controlled Capture Effidency C% Oxidizer Effiaency 0% Capture & Control Effidency Annual Emissions Reduction (tpy) Control Cost EffectivenGss DOC 0.5 hrlshift @ $12.95/hr $6,480 OAOPS

15% of ooerator labor $972 OAOPS OM $0 MAIN 0.5 hrlshift@ $12.g5/hr $7,130 OAOPS

100% of Mainl. Labor $7,130 OAOPS R $7,000 $0.2 pel' elm peryr E $90,563 see electricity cost F $215,950 see naturalgas cost DAC ; DOC+OM+MAIN+R+E+F $335,225 OV; 60% (DOC + MAIN) $13,027 O/IOPS 2% ofTCI $11,890 1% ofTCI $5,945 1% oITCI $5,945 7'" at IEPAdirBCbon 10 0.1424 CRF x TCI $101,015

lAC

## = OV + (0.04 + CRF) TCI $137,822 TAC "DAC 

### + lAC $47;Q47
PTE 29.76 'loP 100% 90% 96'/0 0%

## ='loP X C',," X 0% 86% tpy

## =PTE X Do/. 25.71 TAC Ilpy $18,3971parton

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Cost ofControls for the Dix Plant June 19,2009 Page 23 of23 

## Section IV

- Conclusions
Ifthe Dix Plant were to install add-on emission controls, thermal oxidation is the only commercially available technology that is generally free oftechnical problems for controlling styrene vapor emissions from composite facilities. A small skid-mounted regenerative thermal oxidizer unit is the most practical thermal oxidation option for the Dix Plant. As detailed in the previous section, a skid-mounted RTO control system would have the following characteristics and costs:

• The installed capital cost would 

### be $709,500.

• The operating cost would be $473,000 per)'ear,

• The amount ofreduced annual styrene emissions would be about 25.71 tpy (assuming 29,76 tpy at 86% overall capture & control efticiency

- 90"10 capture and 96% control).

• The cost effectiveness would be about $18,400 per ton reduced styrene emissions per year. Therefore, the RTO system is too expensive and would not be economically feasible at the Dix Plant.

### Electronic Filing - Received, Clerk's Office, July 17, 2009



# EXHIBIT 4

### Electronic Filing - Received, Clerk's Office, July 17,2009 

# ENGINEERING ENVIRONMENTAL CONSULTING SERVICES Robert 

### A. Haberlein, 

### Ph.D., QEP robhab@;erols.com 

### TWO FISK CIRCLE ANNAPOLIS, MD 21401 (410) 268-7367 (410) 267-8174 fax (4101 693-0992 cell July 10,2009 Page I of2 Dale Guariglia, Esq. Bryan Cave LLI' One Metropolitan Square Suite 3600 2II onh Broadway Sl. Louis, Missouri 63102·2750 Mr. Guariglia: As you requested, a revised worst-case airquality ozone impact analysis ofthe maximum YOM emission rate from the Royal Pools facility in Dix, Jllinois is auached hereto. This revision incorporates the recent increase in the maximum annual YOM emission rate from JJ.3 tpy for 250 pools pcryearto 29.7 tpy for 400 pools peryear. As before in the original analysis, this revised analysis employs the Scheffe ozone screening tables, the latest ambient one-hour average ozone data from the ozone monitoring station nearest to the Dix facility, and the one-hour average ozone standard established by U.S. EPA. As shown in this revised analysis, the worst-case one-hour average ozone impact has not changed. The new increased emission rale of29.7tpy is still less than 50 tpy. which is the lowest YOC emission rOW the SchefTe table. The greatestozone impact is still only 89 ppb. which is only 74% ofthe one-hour average \20 ppb ozone standard. This analysis is conservative, because the actual YOM emissions from the Dix facility will be less than the smallest annual MOC emission rate listed in the SchefTe screening tables.
Best regards

Roben A. Haberlein, Ph.D., QEP

### Electronic Filing - Received, Clerk's Office, July 17, 2009 ENGINEERI G ENVIRONMENTAL CO)lSULTING SERVlCES 

### July 10,2009 Page 2of2 

### Revised Air Quality Impact Analysis ofthe VOC Emissions from the Royal Pools Facility in Dix, Illinois using the Scheffe ScreeningTables The most recent available five years ofone-houraverage ambientozone data from the nearest ozone monitoring station located in Hamilton County is listed in the following table: Year**I~** 

### 2nd 

### 3'· 4th 

### (highest samples in ppb) 2007 2006 2005 2004 2003 89 85 79 79 87 86 85 81 102 89 84 74 86 80 88 83 73 

### 85 76 

### 85 The fourth greatest Ozone measurement value is 85 ppb in calendaryears 2003 and 2005. Therefore, the one-houraverage ozone baseline concentration for the Oix facility is 85 ppb. The maximum proposed annual styrene and MMA emission rales from the Oix facilily that results from thc production of400 pools peryear is now 29.7tpy. Styrcnc and MMA are the only significant VOM emission species from theplant. The only other significant emission specie is acelone, which is non-photochemicaUy reactive and does not contribute to the formation ofozone. The total VOM emissions from the facilily will be less than 30tpy. lhe maximum natural gas usage at the Oix plant should be less than 10 million cubic feet per year. According to the AP-42 NOxfactors for gas-fired heaters, this maximum usage is equivalent to: 10 million cu. ft. x 100 Iblmillion cu. ft. 

### 12000 Iblton = 

### 0.50tpy of Ox emissions. The annual VOC-to-NOx ratio is 30 1

### 0.50 = 

### 60. According 10 

### Scheffe Table I "Rural basedozone incrementas ajuncfion ofNMOCemissions andNMOCINOx ratios" 

### in the September 1988 report entitled VOC Ox Point Source Screening Tables by Richard O. Scheffe ofthe U.S. EPA OAQPS office, the worst-case ozone increment for the Oix facility will only be 4 ppb (0.4 pphm x 10 ppblpphm). This table value appears in the row labeled 50 tpy NMOC under the column labeled >20.7 MOCINOx

### ratio. Adding the one-hour average ozone increment for the Oix facility to the one-hour average ozone baseline for the local area yields a worst-case ozone impactconcentration of85 

### +4

## =89 ppb. This worst-case impact is much less Ihan the one-houraverage ozone standard of 120ppb established by U.S. EPA. Although EPA replaced the one-houraverage ozone standard wilh an eight-houraverage standard for most areas in the USA on June IS, 2005, lhe one-hour ozone standard is still the only standard that would apply to 

### the IL EPA 8pound-per-hour VOC limit, which is also an hourly emission limitation.

### Electronic Filing - Received, Clerk's Office, July 17, 2009



# EXHIBITSAS 04-01 (Adjusted Standard) " 

## Electronic Filing - Received, Clerk's Office, July 17,2009

ILLINOIS POLLlJrlON CONTROL BOARD July22,2002 IN THE MAlTER OF: ) ) PETITION OF CROWNLINE BOATS, INC. ) FORAN ADJUSTED STANDARD FROM ) 35 ILL. ADM. CODE 215.301 ) DALE A. GUARIGLIA, BRYAN CAYE, LLP, and ANDREW POLCYN, M.E., AnVANCE ENVIRONMENTAL ASSOCIATES, L.L.G,**APPP~D** ON BEHALF OFPETITIONER; and CHARLES E. MATOESlANAPPEARED ON BEHALF OFTHE ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY. OPINlON AND ORDER OFTHEBOARD (byN.J. Melas): Crownline Boats, 

### Inc, (Crownline) is a fiberglass boat manufacturerlocated in West Frankfort, Franklin County. 'In this opinion and order, -the Board exempls Crownline from compliance with the volatile organic material (YOM) control requirements at 35 TIl. Adm. COde 215:301. Crownline remains subject, under state and federal laws, 10 YOM controls set forth in the National Emission Standard for Hazardous'AirPollutants (NESHAP) along with additional'conditions cOl;tamed in this order:' .'
. 

### OnDecember5, 2003, CrownlineBoats, lnc. (Crownline) filed apetition for an adjusted standard from 35 Ill. Adm. Code215.301 oftheBoard's airpollutionregulations, commonly known as the "8 lbIhrRuJe," as thatBoardregulation pertains to the emissions ofVOM Crownline's facility is located at 11884 CountryClub Road, West Frankfort, Franklin County. In the petition, Crownlinerequested aheming, whichwas held April 23, 2004. TheIllinois Environmental ProtectionAgency (Agency) filed arecommendation thattheBoard grant CrownIine'spetition on January 22, 2004. Accompanyingthepetition, Crownline

### filed amotion forexpedited review. Crownline asserts that the Agencyrecentlyissued Crownline aTitleV Clean

### AirActPennitProgram (CAAPP) permit and TitleI permit, requiring Crownline eitherto obtain an adjusted standard from 35 TIL Adm. Code

### 215.301 ordemonstrate compliancewith that sectionby December 31, 2004. 

### On the same day, Dale A. Guariglia filed amotion requesting permission to appearpro hacvice on behalfofpetitionerin this proceedingin accordance 

### with Section 101.400(a)(3). 35 Ill. Adm. Code 101.400(a)(3). The Board grantedboth Crownline'smotion forexpeditedreview and Mr. Guariglia's motion to'appearpro 

### hOI:vice.

. Basedon therecord before it, the Board 

### finds that Crownline hasprovided sufficient justification for eachofthe Section 28.1 factors.· TheBOard giants Crowniinean adjusted Standard from the 81blhrRule subjectto conditions outlined in this order.

### Electronic Filing - Received, Clerk's Office, July 17, 2009

2
ADJUSTED STANDARD PROCEDURE The Environmental Protection Act (Act) (415lLCS 5/1 etseq. (2002)) and Board rules provide that apetitionermayrequest, 

### and the Board maygrant, an environmental standard that is different from the generally applicable standard that would otherwise apply to thepetitioner. lbis is called an adjusted standard. The general procedures that govern an adjusted standa,rd proceeding are found at Section 28.1 ofthe Act and Part 104, Subpart 0 ofthe Board's procedural rules. 415 fLCS 5/28.1; 35IJI. Adm. Code 104.400etal. TheBoard rules for the content requirements ofthepetition and Agency recommendation are found at Section 104.406 and Section 104.416, respectively. 35 

### III. Adm. Code 104.406, 104.416. 

### PROCEDURALBACKGROUND OnDecember5, 2003, Crownline filed this petition (pet.), accompanied by amotion for expedited review, with the Board for an adjusted standard from the papercoatingrule. From December 10,2003 through December24, 2003, Crownlinepublished noticeofthepetition in the WestFrankfortDailyAmerican, and filed the·certificateofpublication with the Board on January 5, 2004. The Agency filed its recommendation (Ree.) thatthe Board grant Crownline's

. requested reliefOn January 22,2004, subjectto certain terms and conditions contained in the

Agency's recoriunendation. 

### On April 23,2003, Hearing OfficerCarol Sudman conducted ahearingin this matter at the offices ofthe WestFrankfort City Administration Office, 110North Jefferson Street, West Frankfort. Three witnesses testified athearing: Mr. James T. Claxton, presidentofCrownline Boats; 

### Mr. Dale Guariglia, attOrney for Crownline; and

### Mr. Andrew Polcyn, consultant for Crownline. Hearingofficer Sudman found all three witnesses credible. 

### Mr. David

### BloOl~berg was alsopresent on behalfo.fthe Agency's Bureau ofA.ir. Athearing,.Crownline offered eight exhibits (pel. Exh.). Crownline filed apost-hearing briefon May 14, 2004 (pel Br.), 

### and the Agencyfiled apost-hearingbriefonMay 17,2004 (Ag. Br.). 

### FACTUALBACKGROUND 

# , ' Tbe 

### Facility Crownline owns and operates afiberglass boat manufacturing facility where it

. manufactures approximately 30 different mndels ofpersonalrecreation fiberglass boats ranging

from 17'6" oPen bow boat, 

### to a 29' cabin cruiser: Pet. at4. SinCe itbegan operations in 1991, Crownlinehas manufactured approximately40,000boats, currentlyproducing between 15-20 boats each day. The FrankfOrt facility began operation in 1994 

### and employs approximately 500- 600 individuals. !d.
. Crownline's boatmanufacturingprocess involves the following production areas: (1) mold fabrication; (2) gelcoat applica:tiori; (3)lamination; (4) grind & trim; (5) woodworking; (6) upholstery; (7) final assembly; and (8) shippiilg.·.This petitionfocuses mainlyon thegelcoat and

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

3 lamination production areas, sincetheygenerate mostofCrownline's YOM emissions and are, therefore, most impacted by the 8lblhrRule. In 

### addition, Crownline notes that the use of adhesives, lacquers, and Caulks in otherproduction areas also.do notmeetthe 8 IblhrRule on a strict hourly bases. Pet. at 4. Crownline's YOM emissions that do notmeet the g·jblhrRule consist primarily·ofstyrene..

### Id. GeJcoat Application Thepurpose ofthe gelcoatapplicationis to providecolorand asmooth surface to the fiberglass boats. Pet. at 5. Molds are prepared for thegelcoat applicationbycleaning with stripping solvent and awax-releasing agent applied. Pet. at4. In

### one offourgelcoatbooths, gelcoat·is applied tei thehull ordeckmold in asingleapplication using air 

### atomized spray guns. There are thirty-one atomized spray gunsin the gelcoat arCll. Jd. 

### Lamination After the gelcoathas dried, themolds aremoved to one of

### twenty-fourlaminating stations. Pet. at 5. During lamination, glass fibers, polyesterresin and aresin catalyst are applied to themoldusing non-atomized flow-coat chopperguns (f1ow-coatguns). The layerof

. fiberglass and resin is then rolled flatusing hand rollers to remove any air

### bubbles that were

.createdin the application. Laminateis applied in layers called "skins" and requires curing periodsbetween eachskin 

### application. Pet. At 5. Threeresinskins are typically appliedto decks and two to three 

### skins forhulls, followed bya separate application to build theboat floor. 

### Id. .'

, :':

. 

### Pollution ControlEquipmentIn 

### Use. In 

### the gclcoatapplication and laminationprooesses, Crownlirieuses the following: (I) a

. high-volume ventilation system to keep styrenelevels belowthe workerexposurelimitrequired

by OSHA; (2) enclosed spraybooths in the gelcoatapplicationprocess to reduceYOM emissions info theplantairwhen using spray guns; (3) use oflowerstyt:ene-content gelcoat (33.4%) and resin withlowerhazardous airpollutant

## (HAP) content (35% HAP); (4) f1oy,>-coat guns inplace ofairatomized spray guns in the lamination area, (5) panel filters insidethe spray booths and lamination areas to control particulate emissions fiom thesprayguns; and 

### (6) submerged-fillresin tanks inthe lamination process to reducesplashiogand the creationofYOM emissions. Pet. at 5. YOM Emissions Crownline states that the YOM emissions from the facility varydepending onthetype and size ofeach customboat it

### manufactures. Pet. at 5. Crownline's emissions consistprimarily ofstyrene;but also include other YaMs and volatileorganicHAPs such asmethyl methaCrylate (MMA). Technical Doc. at 6, 7, App. 7. Forpurposes ofcomplyingwiththe 8Jblhr·Rule, theAgencydirected.Crownlineto considereachboatpart (e.g., 

### hull, deck, etc.)'as the "emission source." Pet. Exh. I at4. From

### Electronic Filing - Received, Clerk's Office, July 17, 2009

4
theindividual emission sources, Crownline estimated hourly YOM emissions. Among the highestwere 34.08 Ibihrfor gray lacquer, 15.891bihr for carpet adhesive, 21.8 lblhrfor gelcoal, and 19.8 IbIhr forresin. Technical Doc. App. 7, Pet. 

### Exh. I, 

### Exh. 5 and 6. Crownline notes that some values wereoverestimated, but several boat models still have parts with emissions greater than 8 Iblhrwhen YOM emissions are determined on a strictlyhourly basis. Pel. Exh. I at5. According to its 2002 Annual**Emissio.n~** Report, Crownline estimated YOM emissrons totaled 187 tons per. 

### year. To quantify and compare potential YOM reductions, Crownline calculated its annual YOM emissions based on 2003 production data under 

### three scenarios: proMAcr, MACT, and the 8 Ibihr Rule in place. The.pro-MACT scenario resulted in 244.82tpy YOM, while the MACT scenario resulted in 199.79tpyYOM, and the 8 Iblhrscenario yielded 144.36tpy YOM. Technical Doc. App. 6, Exh. 3, 4 and 5. In terms ofHAP, CrownJine's preMAcr emissions were approximately 204 tpy HAP, while theMAcrscenario would result in a 50 tpyreduction in HAP. Pel. Exh. I at 7. 

### CAAPPPermit In discussions between theAgency and Crownline regarding CroWnJine's draft CAAPP operatingpermit, the Agency stated that Crownline could not average emissions to demonstrate compliance with the81blhrRule. TheAgency stated thatthe 8 IblhrRule specifies amaximum hourly emission rate and, therefore, compliance would need to be demonstrated on a stricthourly

.basis, not on an averagefrom any longerperiod oftime. Crownline determined that based on the Agency's interpretation, it couldnot coml?ly .with the-8lblhrRule
.. Pel. at I
.. 

### OnNovember 13, 2003, the Agency issued Crownline aTitle V CAAPP permit and Title I permit (No. 055070AAU). The Title V permit states that CrownJine is to obtain an adjusted standard from 35 1lI. Adm. Code215.301 ordemonstrate cOmpliance with Section 215.301 by December31,2004. Pet at2. Crownline's CAAPP pennitlimits annunl emissions to 249 tons ofVOM peryear. Pet. Exh. I at 8. STANDARD OFREVIEW The Board agrees'with Crownline and theAgency

### thatthe regulation ofgeneral applicability at 35 ID:'Adrn. Code2J 5.301 does notspecify alevel of justification for an adjusted standard. Pet at II; Ret:. at7. Therefore,**p~ant** to Section 28.I(c) oftheAct, the burden of proofis on thepetitionerto demonstrate that: I.
. Factors relating to that petitioner are substantially and significantly differentfrom the factors relied uponby theBoard in adopting the general regulation applicable to that petitioner; .2. The. existenceofthose factorsjustifies an adjusted standard; 3.' The requested standard will not result in environmental orheilth effects substantiallyand significantly.more adverse

### than the effects considered by the Board in adopting the rule ofgeneral applicability; and

### Electronic Filing - Received, Clerk's Office, July 17, 2009

5

4. The adjusted standard is consistent with any applicable federal law. 415 ILCS 5/28.I(c) (2002); 35 

### III. Adm. Code 104.426(a). CURRENTAPPLICABLE STANDARDS One standard applicable to Crownline's boatmanufacturing operations is set forth in 35 III. Adm. Code 215.301. Section 215.301 provides: No person shall cause orallow the dischargeofmore than 3.6 kg/hr'(8 Ibslhr) of organic material into the atmosphere from any emission source, exCept 

### as provided in Sections 215.302,215.303,215.304 and the following exception: 

### If no odornuisance exists the limitationofthis Subpart shall apply only to photochemically reactivematerial. 35 

## m. Adm. Code 215.30I.

.Forpurposes ofcomplyingwith the 

### 8 Ib/hrRule;the Agency 

### has directed Crownline to considereach boat part (e.g., hull, deck, etc.) an emission source. Pet. Exh. 1 at4. Under separate federal regulation effective August23,2004, Crownline must also meet "'newlypromulgated NESHAPs forNew and ExistingBoatManufacturing Facilities applicable to

, boaimanufacturers that aremajor sources of

### HAP. Pet. at 6;,citing 40 C.F.R. Part 63 Subpart "VVVV, 40 C.F.R. 63.5683. Under Section 9.I(a) ofthe Act, NESHAP rules ornpplicable in

illinois and enforceableunder.the Act without additionall1llemaking'activity bythe·Board. 415 ..'LCS 5/9.I(a) (2002).
. The rnlerequires thatboatmanufacturers use maxirnuin available control technology (MAC1) to meetthe "MACffloor," which is the emission limitations achieved by the top performing 12% ofboatmanufacturers inthenation. Pel at 6. To comply with aHAP limit calculated for a facility, manufacturers 

### can useone ofthe following options: emissions averaging using a J2-month rolling average, compliant materials, and/oradd-on controls. 40 C.F.R. 63.5701, 63.5710. Otherrequirements include; using lower

### HAP contentgel-coat and resins; covering resin, gelcoat and solventcontainers; and using cleaningsolvents and adhesives containingno more than5% 

### HAP. TheMACT standard does notrequire airpollution
. eqtitplli'enL To'c(iiilply'WithMACT, Crownline**opin~** that most-boalm!inilf;lclurers with open molding operations will haveto useflow-coat guns and low-HAPproduction materialsin their resins, gelcoats, and adbesives. A flow coat 

### gun generates fewer emissionsbecause it operates at . a lowerpressure 

### and has a non-atomizeddelivery system. TheUnited States Environmental

ProtectionAgency (USEPA) estimates thatby complyingwith thenew MACT standard, boat manufacturers will reduce 

### HAP emissions by 

### an average of35%. Pet. at 2, 6; citing 66 F.R. 44222. Crownline states it is currently in compliance

### with the newMACT standard. CrownIine uses flow-coat guns ill its lamination operating and resin and gelcoat with lowerpercentages of HAP content. Pet. at 6. Crownlinehas notyet made ademonstrationofcompliance to the USEPA, and 

### will not

### be required to do so until August2005.' Pet. 

### Elch. rat 3.

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

6 CROWNLINE'S PROPOSED ADJUSTED STANDARD 

### In thepetition, Crownline proposed the following adjusted standard language for adoption by.theBoard:

OW, •• Pursuant to the authorityunder Seetion 28.1 ofthe Environmental Protection Act, the Boardhereby;adopts the following'adjusted standard: 

### This. adjuste4 standard shall apply solelyto CrownlineBoats, Inc. (UCrownline"). 

### As an alternative to compliancewith 35 lAC 

### § 215.301, this adjusted standard allows Crownline to limitits dischargeoforganicmaterial into the atmospbere from its boat manufacturingoperationsby complyingwith theNational Emission Standard for Hazardous 

### AirPollutants forNew and Existing Bo.at ManufacturingFacilities, set forth at 

### 40 CFR 

### §63 Subpart

### VVW, as maybe amended in the future. The Agency recommended that theBoard grant Crownline therequested adjusted standard so long

### as Crownline complied with the following addition31 conditions:
a. Crownline shal! operate in full compliance with the National Emission Standards for Hazardous Air Pollutants forNew and .l;'xisting Board ManufacturingFacilities, set forth at 

### 40 C.F.R. Section 

### 63 Subpart 

### VVW,.as may be amended in the future. b. Operation in full compliancewith theNational.EmissionStandard for Hazardous AirPollutants forNew andExistingBoatManufacturing Facilities,'set forthlit

### 40 CFR Section 

### §63 Subpart

### VVVV, as maybe

· amended in the future, shall be.in lieu'ofcompliance with the 8.IblhrRule

found at35 

## m. Adm. Code 215.301.


### c. Crownline sball continue to investigateboatproductionmethods with a 'reduced YOM content and, wherepracticable, shall substitute current coatings with lowerYOM content coatings as long as such substitution does notresult in anew increasein YOM emissions. Crownline $aJl be required to do any test which'thelIlinois EPA specificallyrecommends

· 1haflbeydo. ':AnIiiJ)lUal report'SUllUllMlilnJrthe liCti
...ties·lin'cfresnlts'of' ,

theseinvestigatoryefforts shall be preparedbyCrownline and submitted to the illinois EPABureau ofAir, Complianceand Enforcement. d. Thereliefgranted in this proceed.ing shall be limited to the emission activities at the CrownlineWestFrankfort facility as ofthe date ofthis filing.
e. Crownline shall operate in full compliancewith the Clean AirAct, its

·CAAPP, the OlinoisEnvironmentalProtection Act and other applicable. regulations not otherwise discussed herein. Rec. at 5-6.

### Electronic Filing - Received, Clerk's Office, July 17, 2009

7 

### At hearing, Crownline submitted the following revised adjusted standard language, agreed to by the Agency (Tr, at 41, Pet. Br., Exh. B), for adoption: As an alternativeto compliancewith the 8 lQlhrRule found at 35111. Adm. Code 215.301, this adjusted standard allows Crownline tolimitits dischargeoforganic material intothe 

### atmosphere from its boatmanufacturingoperations byoperating in full compliancewiththeNational EmissionStandard fOfHazardous Air 

### Pollutants forNew andExistingBoatManufacturing Facilities, set forth at40 C,F.R. §63, Subpart VVVV, as may be amended in the future, and with the following conditions:


### a. Crownlineshall continue to investigateboatproductionmethods with a reduced YOM content and, wherepracticable, shall substitutecurrent coatings withlower YOM con'tentcoatings aslong as such substitution

,does notresultin anetincreasein YOMemissions. Crownline shallbe required to do anyreasonable testofnew technologicallyoreconomically reasonableproduction methods ormaterials applicableto the open-mold fiberglass boatmanufacturing industrywhichmayreduceYOM emissions at Crownline's facility which the llIinois EPABureauofAirspecifically requestsin writing thatthey do. An annual 

### report summarizingthe ' activities and results ofthese investigatory**effo~** 

### shallbeprepared by Crownline and submitted to the DlinoisEPABureau ofAir, Compliance

, andEnforcementSection. , ':', , . :;'. '. "

.. ' '. ". 

### b: Thereliefgranted in this proceedingshall'be·limited,to.lbe,emission activities'atIbe CroWn.line West Frankfort,facility as ofthe

## dateofthis filing. c, Nothing in this adjusted standard shall relieveCrownlineofitsduty to operatein full compliance with the CleanAirAct. itsCAAPP, the illinois EnvironmentalProtection Actand otherapplicableregulations not otherwisediscussed herein.

- GR6WNLINE'S 

### COMPLIANCEWITHTHE MAGT STANDMU>



### UnderseparateNESHAPrequirements applicable to CrownlineunderSection 9.l(a) of the Act, Crownline statesittook steps earlyto comply with theMACT

### andcameinto compliancewith MACT

### emission limitsmore than a

## yearpriorto thedeadline. Pet. at

### 2, However, CrowoJinehas 

### notyetdemonstrated compliance, and will nothave to until August '2005. Pet. Exh. I at 3, Crowolineslates thatitwill demonstrate compliancetoUSEPA with the new MACT standardbyusing the "model pointvalueaveraging option"basedon a 12-month rolling average andbyusingcompliantmaterials. [d. 

### CrownJinenotes thatits HAP emission limits will vary from monthto monthbased on an'equation setforth in40 C.F,K63,5698. Pet. 

### Exh. 1 at 6. ' "

### Electronic Filing - Received, Clerk's Office, July 17, 2009

8
The USEPA estimates that compliance with the MACT standard by the boat manufacturing industry will result in an annual cost ofcompliance of$4,060 per ton ofHAP reduced and will reduce HAP emissions by an average of35%. 66 F.R. 44222. Crownline estimates its annual compliance costs at approximately $215.600 

### per year and that it will reduce annual HAP emissions (noftotal YOM) by approximately 50 tons. or 25%. Pet. Exh. I at2. Crownline's annua).compliance cost'is approximately $4,312

### perton ofHAP reduced, which is similar to USEPA's estimate of$4.060 

### per ton HAP reduced. Pet. Exh. I at 3. 8. 

### In terms of YOM, Crownline estimated a reduction from 244.82tpyYOM to 199.79tpy YOM underthe MACfscenario. Tecbnical Doc., App. 6, Exh. 3 and 4. EFFORTS·TO ACIDEVE COMPLIANCE AND ALTERNATIVES Crownline states it has investigated the following alternatives that would help CrownJine complywith the 81b/hrRule: (I) reducing YOM contentinproductionmaterials; (2) using alternative operatingprocedures and methods; and (3) installing end-{)f-the'pipe emission control. Crownline states that investigationsproved that, otherthan end-{)f-the-pipe emissiQn controls, many ofthe alternatives would not bring Crownline into compliance with the 8 IbIhr Rule ona strict hourlybasis. Pet. at 6. Reducing YOM in Production Materials Crownlinehas reduced YOM

### in its resin and gelcoatproductionmaterials to meet the federal MACT standard. ·How.ever, meeting the MACT.standard.a1one,wiIlnot bring CrownJine into complianee with the State 8 Ib/hrRule: CrownJine:states that

### it is notpossible to further reduce styrene in thcnesins.and·still maintainproductintegrity. ·Pel. at 6. Crownline and its consultant, Advanced Environmental Associates (AEA),.could not identify.any compliance' alternatives to reduce YOM emissions from CrownJine's use ofadhesives, lacquer.·and caulks. Vsmg Alternative Operatmg Procedures and Methods Crownline states that it investigated both open moldingand closed molding alternative productionmethods. However, Crow.nJine found that even though the alternatives investigated would reduce YOM emissions. they would not bring Crow.nJineinto compliancewith the 8 Iblhr Rule on a strictlYhourlybasis. Crownline explained that theopen and closed molding alternativeproduction methods investigated areonly available to the lamination process and ·there are no alternative**technol~l?;ie'" =c:ntlY'availllblef6~**  thegelceat, lacquering. caulking. and adhesive operations. Pet. at 7. Crownline replaced its atomized spray chopper guns used for resin applicationwith flow-coat guns in its laminationarea. Technical Doc. 8t4. Theflow-coat guns have lowerpressure and internal mixing as compared to the atomized guns. Pet. at 5. Crownline states itexperimented with using Dow-coat guns in the gelcoatprocess, but theyhad' too much ofanegative impact on product quality. Pet. Exh. I at2. End-or-Pipe Controls In developing·theMACT, theUSEPA did not include any emission control technologies as theMACT floor for. the follo'wing reasol)S: (I) only oneboat manufacturerused tliilstack emission controlteclIDologies to reduce HAP'emissions; (2) the cost ofemission control systems 

# was veryhigh beCause veryhigh air flows needed by facilities to comply with OSHA's styrene'.4.. 

# ,-
• 

# -. Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

9 regulations; and (3) theboatmanufacturing industry can reduce HAP content ofresins, gelcoat, and othermaterials to significantly reduce total HAP emissions without undue financial burden. Pet. at 7. CrownJine's consultantinvestigated thevarious end-of-pipe control technologies. As a resultofthe analysis, Crovmline detennined that emission controls arecostprohibitive and, therefore, not an economically reasonable option. For example, up-front capital costs to install tail-staclc controls range from S7 million to SI4 million with annual costs ranging from $4.5 million to nearly $6 million. Crownline estimates that such control would range from approximately $35,000 to $58,000 perton ofVOM removed. Pet. at 8; Technical Doc. at 16, 18. CrownJine explains that thereason end-of-pipe controls are so costly is because ofthe large volume ofairthatmustbetreated in order to reducethe relatively small amount ofVOM. As discussed above, Crownline must move alarge volume of

### airthrough the gelcoat and , lamination areas to maintain compliancewith OSHA's 8:hourworlcerexpoSure limit for styrene. Technical Doc. at 16, 18.·
. 

### SUBSTANTIALLY DIFFERENT FACTORS Crownline slates that the primary intent ofthe 8 IblhrRule was to prevent ozone formation and odornuisance. Crownline

### asserts that theBoard did not contemplate the methods Crownlineuses to manufacture boats at the Frankfort facility.when itpromulga,ted the 8 lb/hr Rule inI9?!. Pet. at 11. Crownline.states that manufacturing-fiberglass boatdecks.orhulls involves apatch-type processrather than'. continuous'application**p~ocess** 'typicallyused·in manufacturingprocesses for other**products~** CrownliIie argues·this-facttogether with·the ventilation'system ituses to'complywith OSHA's Workerprotection regulation 3129 C.F.R. 1910 makesthe use ofadd-on emission controls economicallyunreasonable. UnderOSHA workerbealth and safety Standards forstyrene,

### Cro~e must maintain high air flow to ventilate building air. Thehigh airflo\v makes the cost ofusing tail-end slackemissions controls

. unreasonably

## high. Crownline states that the Board did not anticipatethe current fiberglass boat

production methods and the OSHA standard when it adopted the 81b/hrRule in 1971. Pet. at 12- 

### 13.

__**~"-** 

### -. "
.. , IMPACT ON'THE'ENVIRONMENT' CrownJine contends that its requested adjusted standard will not ad'versely impact the environment or human health. Pet. at 13. Through AEA, CrownJineperformed an ambient

.air quality analysis to estimate CrownJine's impact on ozone formation in south-central illinois. Pet. at 9. ABA used an ozone screening method developed by the USEPA to detennine the impacts ofozone formation. 

### Id. Crownline contends that even without the changes it implemented to meet the MACf standard, the Crownline facility would not cause orcontnbute to any ozone exceedences in south-central Illinois. Based on its Ozone Impact Analysis, Crownline'could'lnore than triple

### its current aruiual VOM emissions wIthout causing an' exceedance ofthe I-hour ozone'

## NMQS: ·Pet. 

## EXh'-l at 8,

### Pet.EXh~2.·: CurrentJY:'the Crownline facility 

### emits approximately. 195 iori.iyr of\'OM peryear, 

## aD:! is permitted to . produce249 tpy YOM. Tr. at 22; Pet. 

### Exh. 1 at 8. Compliance with 8 Ib/hr Rule would

### Electronic Filing - Received, Clerk's Office, July 17, 2009

10 yield approximately 144 tons ofVOM per year. Rec. at 6. Before making any changes, the facility would emit approximately 245 tonslyr ofVOM for similar production figures. Jd
.. The Agency agrees with Crown/ine that ifCrownline could capture the VOM emissions 

### and release them uniformly, rather than in spurts, it could comply with the g lblhr Rule while Dot reducing emissions at all. Rec.' at 6. Crownline asserts that the Agency estimates a decrease

### in the amount ofsolid waste generated and no adverse impacts on water quality and energy consumption from the adjusted standard. Pet. at I L CONSISTENCY WlTH FEDERALLAW Crownline Slates there is no Oean Air Act equivalent rule or regulation prohibiting boat manufacturers' emissions ofVOM in excess of8 lbslhr, .on a strictly hourly basis. Ctownline points out that regardless, the facility must comply wiib the new federal NESHAP for boat manufacturers. Moreover, Crownline contends that ifthe .Board grants'Crownline's requested relief, Crownline will submit the adjusted srandard to the USEPA to be included in Illinois' State Implementation Plan (SIP). For these reasons, Crownline states the proposed adjusted stand'ard is consistent with federal law. Pet. at 13. DISCUSSION Crownline seeks reiief

### fro~.ihe.Slate'~**~.lblhr!iule** in the{oxm of

### II!' adjusted stand.ani.
. Under separate federal:regulation
..applicable to itunder Section 9.-1(a) oftheAct,.Crownline is
. already requiredio 'complywiththe NESHAP 'forNew and

### EXi~g Bc;>atMBnutacturing
. Facilities, which limits

### HAP emissions from ,facilities such as the CrownlineWestFrnmfort
. plant. Crownlinemustcomplywith the MACT emissions limits underthis standard by August 23, 2004. AcCordingly, Crownline requests that Section 215.301 not apply to their operations. The Agency recommends that the Board grant Crownline the requested reliefsubject to certain conditionS. 

### Ifgranted, the adjusted standard would apply only to the**m8terial~** and methods Crownline uses to manufacture fiberglass boats at its WestFrankfortfacility.

. The,Board fu.>,dsthat.Crownliqe's**reque~\Jor r~f**  irp)ll.the)\**IbIhrRuI~~~** the, .",. statutory "fundamentally different" factors ofsection28.I(c) oftheAct. Crown/inehas

. demonstrated that (Ijfaetors relatingto it are substantially and significantlydifferent from the

factors relied upon by the Board in adoptingthe general regulation; (2) the existenceofthese factorsjustifies an adjusted standard; (3) the requesied standard will not cause substantially or significantly more adverse environmental orhealth effects 

### than the effects consideredbythe Board in adoptingthe rule ofgeneral applicability; and (4) the adjusted standard is consistent with applicable federal laws. 415 ILCS 5128.I(c) (2002). Crc;>w.n1inebases itsjustificationfOl: the requested reliefon the Jack ofan ecooomic3JJy**reasonabl~** 9rtechpica)ly**feasibl~ .a1~erpative.**  The BOl'l'd finds that.**t!)~** effor!$beyond those Crownlinebas alreadyimplemented inthe three categories**of.alt~rnatives** that Crowniine investigated (reducing VOM contentin production materials, employing alternativeoperating procedures and Productionmethods, and applying end-of-pipe controls) are not currently

### Electronic Filing - Received, Clerk's Office, July 17, 2009

II technically feasible orecolIornically reasonable. Additionally, the Ozone Impact Analysis shows that CrownJine's emissions will not cause negative health orenvironmental effects. The Board finds no inconsistencybetween granting Crownlinc'srequested reliefand federal law. Finally, the Board finds that theBoard did not anticipate.thebatcb-type.proce.sses of coating and laminating fiberglass boatparts that Crownline employs at the West Frankfort facility when it promulgated the 8 

### IbIhrRule at"Section 215.301. As a matteroflaw, Crownline must comply with the MACfemissions limits byAugust 23, 2004, whichCrownline states ithas achieved over a year early. The Agency'srecommended adjusted standard language contains some**condition~** that Crownline's proposed language does not include. Rec. at 5. Specifically, the Agency proposed language limiting Crownline's reliefto apply specificallyto the emission activities at the CrownlineWestFrankfort,facility, the effective datebeing t1)e Board's final decision in this matter: 

### The Agency's adjusted standard l8hgliage rei'tetafcd that CrownliiJe'niUst operate in full compliancewith the federal standard. 

### !d. The Agencyproposed languagerequiring Crownline to continue to investigate boatproduction methOds and, wherepracticable, substitute current coatings with lowerYOM contentcoatings as long as the suhstitution does not result in increased YOM emissions, TheAgency further proposed that Crownline'must do testing as the Agency recommends and submit annual reports summarizing the activities and results ofits

.investigations to the Agency, Bureau ofAir. 

### Id. At hearing, Crownline submitted revised language, including threeconditions, with no objection bythe Agency. The reVised'wording incoiporated·the·Agency'sproposals to: .(1) contlIlUe1ci investigateboatproduction methOds with a'rtduced .yOM-content'aod, where· practicable, substitute current coatings with lower 

### VOM content coatings SO long as the substitution does notresult in higher YOM emissions; (2) perform anyreasonable test ofnew productionmethods ormaterials that theAgency, Bureau of

### Air, request in writing that they do; and (3) submit an annual report summarizingthe activities and results oftheirinvestigatiollS. The revised wording also reiterates that Crownlinemust operatein Compliance with the federal standard. 

### In grantin'g this adjusted standard, theBoardis adopting conilltions similar, but not identical·in wording, to those'suggested bytheparties. "TheBoardusedCrownline's revised language and, as theAgencyrecommended, the Boardhas tightened up the description ofthe facility and clarifiedreporting requirements. 

### The. balanceofthe changes are non-sub'stantive, and are intended to bring this order into conformity with theBoard's usual drafting style in adjusted standards. CONCLUSION The Board grants Crownlme's requested reliefand exempts it from the 81blhrRule at Section 215.301 oftheBoard's regulations at its facility in West Frankfort; FmrikJin CoiJnty, Crownline reinains-subject to the NESHAP ajlplicable" to'its facility and suggested-conditions. The reliefis effective

## as ofthe date ofthis order.

### Electronic Filing - Received, Clerk's Office, July 17, 2009

12
This opinion constitutes the Board's findings offact and conclusions ofIaw. 

### ORDER I. Pursuant to Section 28.1 ofthe Environmental'Protection 

### A-et (Act) (415 ILCS
. 5/28.1), theBoard grants Crownline Boats, Inc. an adjusted standard from 35 III. Adm. Code215.30I (8 ·IbihrRule), effectiveJuly 24, 2004. The adjusted standard applies to the emissions ofvolatile organicmaterial (YOM) into the atmosphere from Crownline'sboat manufacturing facility located at 11884 Country Club Road, West Frankfort, Franklin County. 2. 35 TIL Adm. Code 215.301 does not apply. Crownline remains subjectto the following:

a. Crownlinemust continue to investigateboat production methods that generate fewerYOM emissions and materials that have areduceil YOM content Wherepracticable, Crownlinemust substitutecurrent materials with lowerYOM content materials as long as such substitution does not result in a net increase in YOM emissions. b. Crownline mustperfonn any reasonable test ofnew technologicallyor economicallyreasonableproductionmethods or materials applicable to the open-mold fiberglass boat manufacturingindustry, which mayreduce YOM emissions at Crownline's facility whichthe U1inois Environmental Protection Agency (Agency) specificallyrequests in writinglhat theydo.
C. Crownlinemusfprepare and submit each year an annual report summarizing the activities and results ofthese investigatory efforts. The annual reportmustbewbmil\ed to theAgency, Bureau ofAir, Compliance and Enforcement Section; d. Crownline must operate in full compliancewith the Clean Air Act, its CleanAir ActPennit Programpermit, theNational Emissions Standard for Hazardous Air Pollutants forNew and Existing BoatManufacturing Facilities, set forth at40 C.F.R. 63, SubpartVVVV, as requiredby Section 9.1 (a) ofthe Act, and any other applicableregulation. IT IS SO ORDERED. Section 41(a) ofthe Environmental Protection Act provides that final Board orders may be appealed directly to the Illinois Appellate Court within 35 

### days after the Board serves the order. 415 ILCS 5/41(a)(2ooo); 

### seeaLto 35 

### DJ. Adm. Code I01 JOO(d)(2), 101.906, 102.706. llIinois Supreme CourtRule 335 establishes filing requirements that apply when thellIinois Appellate Court, by statute, directly reviews administrative orders. 172 

### nJ. 2d R. 335. The Board's procedural rules provide that motions for theBoard to reconsideror modify its final

### Electronic Filing - Received, Clerk's Office, July 17, 2009

13 orders maybe filed with the Board within 35 days afterthe orderis received. 35 

### ill. Adm. Code 101.520; see also 35 D1. Adm. Code 101.902, 102.700, 102.702. I, Dorothy M. Gunn, Clerk ofthe illinois Pollution Control Board, certifythat the Board adopted the above opinion and orderon July22,2004, by a.vote of5-.0.

# ~I>t-~ Dorothy M. Gunn, Clerk lllinois Pollution Control Board

. ,

### Electronic Filing - Received, Clerk's Office, July 

### 17, 2009

BEFORE THE ILLINOIS POLLUTION CONTROLBOARD 

### IN THE MAITER OF: Petition ofRoyal Fiberglass Pools, Inc. for an Adjusted Standard from 351AC 

### § 215.301 

### ) ) ) 

### ) ) AS 2009-04 (Adjusted Standard)



### TECHNICAL DOCUMENT SUPPORTING ROYALFllJERGLASS POOLS, INC.'S FIRST AMENDED PETITION FOR AN ADJUSTED STANDARD Section



### 2

3
4


### 5 Description General InformationRegarding Royal Fiberglass Pools and Photographs ofthe Composite Fiberglass Swimming Pool Manufacturing Process. Exhibits A, B, and C attached to Royal's modification to its CAAPP permit application ftled July 14,2009, detailing Royal's: material usages and emissions, annual potential to emit, and maximum hourly YOM emissions. July 16, 2009 memorandum regarding Royal Fiberglass Pools' Maximum Hourly YOM Emissions, prepared by Engineering Environmental Consulting Services. June 19, 2009 Control Cost Analysis for aRegenerative Thermal Oxidation System prepared by Engineering Environmental Consulting Services. July 10,2009 Air Quality Impact Analysis ofRoyal Fiberglass Pools' Dix Plant Operations prepared by Engineering Environmental Consulting Services. July 22, 2006 Illinois Pollution Control Board Decision Regarding Crownline Boats, Inc.'s Petition for an Adjusted Standard. Respectfully submitted, BRYANCAVELLP By:

# ~elo~~2998 Brandon W. Neuschafer, Missouri Bar#53232 OneMetropolitan Square 211 N. Broadway, Suite 3600 Sl. Louis, Missouri 63102 Telephone: (314) 259-2000 Facsimile: (314) 259-2020 Attorneys for Royal Fiberglass Pools, Inc.

## Electronic Filing - Received, Clerk's Office, July 17,2009

CERTIFICATE OF SERVICE 

### The undersigned certifies that..l.coPY ofthe foregoing Technical Documentwas served upon the following panies on the ('t""Oay ofJuly, 2009:
Illinois Pollution Control Board, Attn: Clerk 100 WestRandolph Street James R. Thompson Center, Suite 11-500 Chicago,IL 6060

### 1-3218
Division ofLegal Counsel Illinois Environmental Protection Agency 1021 North Grand Avenue East P.O. Box J

### 9276 Springfield, IL 62794-9276 Attn: Charles Matoesian