Electronic Filing - Received, Clerk's Office, July 17, 2009 IEPA ATTACHMENT NO.5

BEFORE THE ILLINOIS POLLUTIO CONTROL BOARD

IN THE MAITER OF:

Petition of Royal Fiberglass Pools, Inc.

for an Adjusted Standard ITom

35 lAC § 215.301

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AS 2009-04

(Adjusted Standard)

FIRST AME DED PETITIO FOR AN 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 it applies 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 entirety Royal's original Petition For An 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 First Amended

Petition does not seek a substantive change to the relief sought 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 of the 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 a common exhaust ventilation system. The

production bays utilize an approximate 35,000-cfTn cross-flow ventilation system that exhausts

air from the work areas to the outside atmosphere through a 36 inch diameter, 36 foot tall vertical

discharge stack in order to control worker exposure 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 of 2004,

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 a modification 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 longer time period.

On January 10, 2006, the lllinois EPA issued Violation Notice A-2005-D0281 to Royal.

After receipt of this otice, representatives of Royal met with illinois EPA in person and also

corresponded with Illinois EPA regarding the notice. As part of these communications, Royal

provided a significant amount of information 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 of demonstrating compliance, the hourly VOM emissions from

certain of its operations (gelcoat and resin application) did not appear to comply with IEPA's

interpretation of the 8 lb/hr Rule.

After carefully examining its options for add-on controls and/or for changing

manufacturing methods/equipment to reduce Royal's levels of hourly VOM emissions, Royal

realized that the cost for compliance via either of these options will neither allow it to remain

competitive nor profitable, and will force closure of the 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 that applying the 8 Ib/hour Rule to Royal's operations on a strict hourly basis

would indeed impose an unreasonable burden. Royal and Illinois EPA agreed that Royal would

apply for an adjustment from the 8 Ib/hr Rule?

Accordingly, Royal offers the following summary of reasons as to why it should receive

an adjusted standard with respect to 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 cost for a facility 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 of operations 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 strict hourly 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 of the 8 Iblhr Rule to Royal's operations, and this

Petition shall not act as a waiver ofsuch rights or defenses, nor as an admission of positions Iaken by Illinois EPA.

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

ton of pollutant removed.

• Although some alternate methods for manufacturing fiberglass reinforced plastic ("FRP")

products exist, none of them 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 comply with the 8 Iblhr Rule on a strict hourly basis.

• The high cost of using either end-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 in one ofthe following scenarios:

• To remain competitive, Royal will be forced to move to another state which does

not have an 8 IbIhr Rule (or any 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 of its 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 of those

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 Relief is Sought - § 104.406(a}

Royal requests an adjusted standard from 35 Ill. Adm. Code § 215.301 (Use of Organic

Material, otherwise known as the "8 Iblhr Rule''). Illinois' organic material emission limitations

were originally promulgated as Rule 205 in 1971. Section 215.301 now provides:

"No person shall cause or allow the discharge of more 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 of 35 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 of a type capable of emitting specified air contaminants 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 of carbon 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 of tbe Regulation of General Applicability - Section l04.406(b)

This regulation was promulgated to implement the federal requirements under the Clean

Air Act, 42 USC § 740 I et seq.

C. Level of Justification - Section 104.406(c)

The regulation of general applicability from which Royal seeks an adjusted standard does

not specify a level ofjustification for 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 Plant began 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 of the attached Technical

Document.

The CAAPP permit application submitted to Illinois EPA in November 2004 requested a

maximum facility-wide annual production cap of 400 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.

Composite Pool Manufacturing Procedure. The composite pool manufacturing at the

Dix Plant consists ofthree basic process steps, all of which emit VOMs and would be subject to

the requested adjusted standard:

I. Gelcoat application. Either a thin layer of white gelcoat or two layers (one of

which is translucent gelcoat and the other is regular production 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.

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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 of three 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 of the VE resin. The VE resin contains up to

48% styrene content by 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-resistant resin 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 of the ISO resin.

The other manufacturing steps include: (I) parts finishing, including trimming, grinding

and sanding of finished 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 other steps do not have significant amounts ofVOM emissions.

VOM Emissions Estimates. The YOM emissions from the Dix Plant vary depending on

the type and size of each swimming pool part. The facility emissions consist predominately of

styrene, but also include small amounts of other YOM and volatile organic HAP species such as

methyl methacrylate ("MMA''). The average YOM emissions per pool for the gelcoating process

is 53.8 Ibs of YOM. The resin process averages 94.4 Ibs of YOM emitted per pool. The total

average YOM emitted per pool 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 of the 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 memorandum regarding 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 of acetone, which has no HAP or YOM emissions. By

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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 of 43%.

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 of Compliance 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 other than

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 further reduce YOM emissions from Royal's operations.

1. Lower YOM Content Materials

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 of its suppliers regarding lower YOM content production materials,

further reduction of styrene in the resins (below that needed to comply with MACT) is not

currently technically feasible while still maintaining product integrity.

2. Alternate Operating Procedure 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 of any effective

alternative:

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

male molds.

• Composite pools are too large to use any closed molding process. Even if closed molding

was feasible for the smallest pool model, the gelcoat layer must still be applied to the

"open" closed mold with a gelcoat applicator.

• A high-quality gelcoat finish is an essential component of a 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

smaller spa pools.

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• 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 360 pounds of gelcoat.

• 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 gel coat process cannot be appreciably reduced with any

additional workpractice improvements, pollution prevention techniques, or gelcoat

material substitutions.

• The application of gelcoat 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 air pollution control equipment. The cost

ofthe lowest-cost control equipment is detailed in the next section.

3. Add-On Air Pollution Controls

The cost and feasibility of add-on air pollution controls at reinforced plastic composite

manufacturing facilities has been thoroughly studied and documented as part of the 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 of HAP or new facility that produces large parts such as

swimming pools and emits more than 250 tpy of HAP. The Dix Plant emitted less than 12 tons

of HAPs in 2008, so add-on controls would not be cost effective by a very wide margin.

A comprehensive study entitled "Feasibility and Cost of the Capture and Control of

Hazardous Air Pollutant Emissions from the Open Molding of Reinforced Plastic Composites"

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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 MACT rule. This report has 377 pages ofinformation concerning the cost and

feasibility of add-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 of the air pollution control systems, which are detailed in the

aforementioned study and are available for use, is contained in the following table:

Commercially Available Air Pollution Controls

-'{"- • .h~jd~rns -; :<; ,:-- i~~-.; .l

.~. J.ech~?f.t~ -:.a, _. ~~. ~-.~ - _ (~_:"r.-~

-', ~~~s~'*~\ . xEaQf

Absorption Stvrene is nearly insoluble in water infeasible

Styrene polymerizes on sorbent media

Adsorption Desorbed styrene is not reusable infeasible

Desorbed styrene 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 airflow

Styrene concentration in air too low to be economic

Condensation Condensate is mostly water with trace styrene infeasible

Condensate must be 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 costly than RTO

I Regenerative thermal oxidation is currently employed technically

I at one truck cap plant and several large bathware plants feasible

that produce small parts on automated production lines,

Oxidation RTO operate continuously (24 br/day, 360 dayslyr) and have economically

uncontrolled styrene emissions >250 tpy. A RTO infeasible

system large enough to handle the 35,000 cfm exhaust

airflow at the Dix Plant would cost over $600,000 to

install and over $300,000 per year to operate.

CO Catalytic media bas a relatively short lifetime and is infeasible

unreliable

Preconcentration is currently employed at four large technically

bathware plants. The 10ng-teIm perfoImance ofthe questionable

Preconcentration adsorber in questionable due to an unexpected failure

wlRTO ofthe activated charcoal sorbent media at one ofthe economically

sites. A preconcentrator system large enough 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 of this study. Royal is not including a copy with tbis Petition. It is pan of EPA's docket

regarding the Composites MACT rule promUlgation aod adoption. Should the Board desire a copy of the study,

Royal would be pleased to provide it to 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 of its 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 of over $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 of the RTO control option is much

greater than what is widely regarded as affordable. The annual operating cost ofthe RTO control

options is several times greater than the annual profit for the Dix Plant Hence, add-on controls

are prohibitively expensive and not economically feasible for the Dix Plant.

F. Royal's Proposed Adjusted Standard - Section 104.406(0

As set forth above, the rule of general 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 of emissions 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 of the Composites

MACT Standard. According to the Composites MACT, EPA estimates that compliance with the

MACT will cost $2,800/ton annually and will reduce emissions by an average of 43%.

Royal proposes the following language for a Board order to 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 of new 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 of such tests, Royal

must prepare and submit a report summarizing the activities and results of these

investigatory efforts. The report must be submitted to the Agency, Bureau of Air,

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) of the Act, and any other applicable regulation.

G. Quantitative and Qualitative Description of Royal's Impact on the

Environment Before and After the Proposed Adjusted Standard - Section

l04.406(g)

Air Quality Impact Analysis of Royal'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 of the Technical

Document is an Air Quality Impact Analysis of the 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 the hourly 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/hr Rule.

Should Royal's First Amended Petition be granted, there will not be any increase on a per

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 Petition will not amount to an increase of per unit emissions.

Cross-Media Environmental Impacts Resulting from an Adjusted Standard. None.

The Dix Plant's waste and wastewater generation is independent of YOM emissions, thus no

change in the nature or volume of waste and wastewater generation is anticipated.

R. Justification -Section l04.406(h)

Under Section 28.1 of the Environmental Protection Act (the "Act"), the Board may grant

an adjusted standard for persons who can justifY 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 of justification required of a petitioner to qualil)< for an

adjusted standard, the Board may grant individual adjusted standards upon adequate proof that:

(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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existence ofthose factors justifies 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 boat manufacturing facility in West Frankfort, 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/hr Rule was to prevent ozone formation and odor nuisance.

However, the Board did not contemplate the methods Royal Fiberglass Pools would usc to

manufacture swimming pools at the Dix Plant when it promulgated the 8 lb/hr Rule 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 of add-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/hr Rule 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 of the rule, Royal believes that the factors

primarily relied upon by the Board involved concerns about preventing 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

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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 of these regulations is for control of

photochemical oxidants. In addition, odor causing organic emissions were included if a

local odor nuisance exits . . . these provisions are designed to require the use of

equipment that is already in use 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 of Royal's operations shows that the main purposes of this rule are not

furthered through its application to Royal: first, as discussed in Section Il.G of this First

Amended Petition, the daily amounts of YOM cmitted by Royal's operations have a negligible

impact on ambient ozone levels and would not cause a violation of the ozone NAAQS; and

second, Royal has a tall stack in 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 of a fiberglass swimming pool involves a batchtype process (of applying 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 of materials that emit YaMs)

are of a continuous nature or, are at least are distributed more evenly over a 24 hour period. For

continuous or near-continuous operations, the use of emission 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 of the gelcoat and resin application processes at the Dix Plant,

they are neither continuous nor evenly distributed over a longer period 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 (worker breathing air) ofless than 100 ppm. 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 of the 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 of one of the fundamental purposes of the 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/hr Rule on a strict hourly basis.

2. The Existence of Those 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 of Royal's efforts to obtain an adjusted standard

justifies the granting of an adjusted standard.

3. The Requested Standard Will Not Result 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 other states.

4. The Proposed Adjusted Standard is Consistent with Federal Law

The granting ofthis proposed adjusted standard is consistent with 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 of 8 lbslhr, on a strict hourly basis. Because Royal is proposing to comply

with the CompositeS MACT, the proposed adjusted standard is consistent with 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 Document is 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 of complying

with the requirements ofthe 8 Iblhr Rule on a strict hourly 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~ ( Dale A. ~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 undersigned certifies that a copy of the foregoing First Amended Petition was served

upon the following parties on thcfI!::aay ofJuly, 2009:

lIIinois Pollution Control Board, Attn: Clerk

100 West Randolph Street

James R. Thompson Center, Suite 11-500

Chicago, IL 60601-3218

Division ofLegal Counsel

lIIinois Environmental Protection Agency

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 few

,Ieps from your bockdoor,

yovr world can be

transformed into a calm,

peaceful oasis or

exciting waler

adventure for the

enlire family.
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Electronic Filing - Received, Clerk's Office, July 17, 2009

TAKE THE

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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. A luxurious

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

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The advantages 01 a Royal fiberglass Pool are mony.

Mode In Americo

And Proud 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. winler cover, salor blonket ond reel oulo

cover, ozone purification, ceramic tile. landscape

lighting. ~ber aplic lighting, handrails. and

ladders.

Sianciord Accessories: Skimmer. moin drain and re/urn

inlels.

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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 know you're

buying Ihe very best pool 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!
Electronic Filing - Received, eler I 1>1ffiO&hffif.i4r:2Qi~~~~m~bj
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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 per year

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 per year /2000 Ib/ton = 29.76 tpy YOM
Electronic Filing - Received, Clerk's Office, July 17, 2009

EXHIBIT C - Maximum Hourly VOM Emissions from Gelcoating at the 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 45.79 271

..il 3'/\ 44.51% 751", 24.29 4.55 28.84

BARON 334.69 Clear 174.25 24% 4% 44.51 '10 75% 35.75 10.04 45.79 381

/0 10% 52.28% 75°4 34.62 13.07 47.69

BARON 357.00 Ughl Blue 1742S 24 1

t. 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

DUKE SHALLUW 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

DUKE SHALLOW 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

DUKE SII,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 0.00 27% 3% 44.51 ~.4 75", 40.76 7.63 46.39 44.51% 75'''' 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, Engineering Environmental 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 occur during 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-hour period.

3. The greatest gelcoat-cmitting pool model is a Duchess Pool with a Royal Sapphire fInish,

which emits 78.55 Ibs YOM per hour (see Exhibit C to the CAAPP revision).

4. The second greatest gelcoat-emitting pool model is a King Shallow Pool 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.

The maximum resin application YOM emission rate for one pool is based on the following

assumptions:

I. Maximum resin usage rate of 1.5 gallons per hour which is equivalent to 812 Ibs per hour

or about 50010 ofthe total resin used per pool.

2. Resin styrcne content of 47.5% by weight.

3. UEF emission factor for non-atomized resin application equal to 12.23 % styrene content

weight

The maximum single-pool rein application hourly 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 per hour.
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 of Controls 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 behalf of

Royal Pool, Inc.

Breaux £3ridge, Louisiana

by

~a~---- Robert A. Haberlein. Ph.D., QEP

Engineering Environmental

Two Fisk Circle

Annapolis, Maryland 2 I40 J-3212

June 19,2009
Electronic Filing - Received, Clerk's Office, July 17, 2009

ENGINEERING ENVIRONMENTAL

co SULTING SERVICES

Cost of Controls for the Dix Plant

June 19,2009

Page 2 of23

Executive Summary

If Royal 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 vapor emissions from composite facilities.

A small skid-mounted regenerative thermal oxidizer unit is the most practical 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 per year.

• The amount of reduced annual styrene emissions would be about 25.71 tpy (assuming 29.76

tpy at 86% overall capture & conlrol efficiency - 90% 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 feasiblc at the Royal

Pools' Dix, Illinois facility.
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Cost of Controls for the Dix Plant

June 19.2009

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Section 1 - Introduction

Purpose

This report provides an updated and detailed !Jest Available Control Technology (!JACT) cost

analysis ofthe economic feasibility of a 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 Plant to emit more than eight pounds of VOC per hour when fabricating a large

composite pool part.

Background

As detailed in Table I of the 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 of this 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. For these 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 Handbook a/Control Technologies/or Hazardou.\ Air Pollutants

• EPA's Assessment ofSryrene Emission Controls/or FRPIC and Boat Building Industries

• Air pollution control cost guidelines in the EPA OAQPS Contml Cost Manual- Sitth

Edition

• ACMA's Feasibility and Cost a/the Captw'e and Control ofHazardous Air Pollutant

Emissions/rom the Open Molding ofRein/arced PlastiC Composites

• Recent control system quotes and communications from Adwest
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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 Dix Plint

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 per year to 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 of the 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 of the referenced preconcentrator systems have been decommissioned and

demolished and the original preconcentrator system has failed twice, leading to enforcement

actions against the facility. The preconcentrator process is a still a technically questionable

control technology for reinforced plastic composite fucilities.
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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 ester and isophthalic resins. The gelcoals and

resins are mixed with a small amount of organic peroxide initiator to start the curing reaction.

Normally, about 50-75% of the gel coat process 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 of the 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 a common 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 at 40,000 cfm maximum airflow. The

proposed control system would be directly connected to the existing ventilation outlet using a

new section of 48-inch diameter duct and fittings. and the existing stack would be demolished.

According to the ventilation designer, Mr. Jimmie Talbot of Reed 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 of the supply air is delivered by a mechanical air supply unit. An important portion

of the supply air enters through gaps under the 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 of the bays (opposite the doors), where a significant portion of the process emissions are

collected and discharged through the exhaust stack. However, a portion of the process emissions

is recirculated back to the bay spaces, because the volumes of induced airflow moving towards

the inlets are normally greater than the exhaust airflow. In this circumstance, it is physically

impossible for all of the air flowing towards the exhaust inlets to be captured althe inlets and

some oflhis air must be recirculated back.
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The original control cost estimate in 2005 assumed the exhaust airflow was 50,000 acfm. At the

request of IEPA, 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 of 35,000 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 of three feet from the floor. The ventilation airflow was recently

measured with the doors opened about 1.5 feet (18 inches), which was about one-half ofthe

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 or greater.

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 per door or 180 tt2 in total for the

three doors.

According to Mr. Talbot, approximately 80% of the 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% of the design value

of 3 feet) and 20"10 of the 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.
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The capture efficicncy ofthe bays is also impacted by another physical 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 of wind, 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 of the Docket for the

Composite MACT rule (see the repon entitled Feasibility and Cost ofthe Capture and Conlral

ofHazardous Air Pol/ulam Emissionsfrom Ihe Open Molding ofReinforced Plaslic

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 of the possible wind directions. The degree of loss 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 of 90% capture

efficiency is assumed to reflect the very low average air velocity through the NDO door-gap

openings and the influence of wind pressure on the exterior enclosure 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 or materials used at the Dix Plant.

The original control cost estimate submitted to IEPA in 2005 included a detailed annual emission

estimate for production of all-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 per year.

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 of different gelcoats) in addition to

the all-white pools that were made in 2005. Further. the company now has four years of material

usage data at the Dix Plant instead ofjust one year. A summary of this new data is listed in

Table 2 on the next page.
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Table 2 - Material Usages at the Dix Plant for 2005 through 2008

Year

Pools bUill per year

Hours worked manhours

Manhours per pool

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

Actua, 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 per actual 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 of actual 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 of 400 pools per year is now:

400 pools/yr x 148.80 Iblhr /2,000 Iblton = 29.76 tpy

For this reason, a maximum annual emission rate of 29. 76 tpy is used in this cost analysis.
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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 per year. However. a presumption of continuous operation is not

reasonable for a production level of 400 pools per year 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 part of the winter season. However, Royal Pools plans to build

pools during the winter seasons in the future, after the pool market improves and stockpiling an

inventory of pools 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 per year. However, the

plant has never produced 250 pools per year, so the additional labor requirements for 400-poolsper-year are not well documented. Aecording to best estimates by Royal Pools, the production

of 400 pools per year 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 per year

In reality, the control system must be operated longer than the 4,000-hour work period assumed

above for two important reaSOns. First, the oxidizer unit must be pre-heated to the prescribed

1,600 F oxidation temperature before the star! of production. 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 of preheating on the other

\\ eekday mornings duc to the shorter overnight unit shutdown period. Second, the oxidizer unit

must be operated for about 15 minutes after the end of operations 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 per year x I hrslday = 50 hrslyr

Other weekday mornings 200 per year x 0.5 hrslday = 104 hrslyr

After-work periods 250 per year x 0.25 hrs/day = 63 hrslyr

Total annual control period 4,213 hrs/yr

Accordingly, a control period of 4,213 hours per year is assumed for this cost analysis.
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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 a capture efficiency of90% over a control period of 4,123 hr/yr

result is 12.99Ib1hr. The styrene exhaust concentration calculation is shown in Table 3 below.

Table 3 - Styrene Exhaust Concentration Calculations

e 2005 Enginser1ng Environmental

Molecular Wt (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-per hour VOM emissions standard. The annual average control period

concentration is surprising low. The low concentration is an unavoidable consequence of long

periods of low emissions punctuated by short periods of very 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 of low emissions. This unique fealurc of composites

manufacturing is the main reason that federal EPA did not require add-on controls for small

sources in the Composite MACT rule.
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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) H20

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

CH, + (I + 0.25 x4) --> CO2 + 2 H20

CsHs + (8 + 0.25 x8) O2 --> 8 CO2 + 4 H20

The performance of an oxidizer is commonly characterized by three imponant parameters known

as the "Three Ts:"

I. Temperature - the oxidation reaction rate is accelerated at elevated temperatures. 11 igher

temperatures cause faster oxidation rates and higher destruction efficiencies. In order to

ensure a destruction efficiency of99%. styrene vapor requires thennal oxidation

temperature between 1,800 and 2.000°F with an associated retention time of I 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 of a 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 of I,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.

lligher oxidation temperatures apparently resulted in lower secondary CO emissions.

• 1.600°F - several existing RTO units at composite facilities have an oxidation

temperature setting of about 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.
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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. Greater destruction efficiencies result from longer residence 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 of the exhaust could pass through the

chamber without adequate oxidation. Note that turbulence is not directly related to either

temperature or time, but is a necessary condition for high destruction efficiency.

Oxidation Technologies

An oxidation system may be characterized according to two different technology 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, or coated beds that contain special catalyst materials. These catalyst

materials consist of precious metals. such as platinum-coated or palladium-coated

ceramic beads, or base 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

ox idation 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 transfer the 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 inlet and outlet airstreams using an arrangement of thermal masses. The
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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% of the thermal energy can be recovered and reused in this

manner

3. Recuperative Catalytic Oxidation - combines the features of catalytic 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 of catalytic oxidation

with the benefits ofregenerative heat recovery. A RCO is very similar to a typical RTO

unit, exccpt that small layer or a fine coating of catalyst 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. Catalyst Deactivation - refers to the steady deterioration in destruction efficiency caused

by the deactivation ofthe catalyst. The transient nature of the 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 of the catalyst

performance, continuous emissions monitoring may also be required by some regulatory

agencies to verify the effectiveness of the 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 sooner than the

expected service life. The problem of poisoning 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 Air Pollution Control Technolog~s: An

O\C:rvicw," New HazNdou$ Air Pollutant La", and Regulations, SP·S2: A&WMA, Pittsburgh, PA; 1992]. The

problem of premature catalyst failure in a catalytic oxidizer was discussed with U.S.EPA

during MACT promulgation, 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 of the catalytic oxidizer. A core sample of the catalyst

honeycomb was removed and analyzed for contamination. The analysis confirmed the
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catalyst failure. An extremely large amount ofsilicon, and trace amounts of phosphorus,

chlorine, and sulfur compounds 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 fai lure [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. Caialysl Pluggillg - involves the small openings in the catalyst bed that can become

plugged with foreign matter entrained 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 thick cannot 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 a COmmon problem

and would be very difficult to avoid in practice. A completely different filter system

and/or media 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. If properly designed and maintained such a

prefiltration system could greatly reduce, but not eliminate, the plugging problem.

However, the cost ofa high-efficiency filtration system can be great for large and dirty

air streams, which are Common at many open molding plants. For example, 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 of approximately 100 feet of48-inch diameter galvanized steel spiral duct and

four 48-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 of Labor 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 cost estimate.
Electronic Filing - Received, Clerk's Office, July 17, 2009

ENGINEERlNG ENVIRONME TAL

CONSULTING SERVICES

Cost of Controls 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

Galvanized spiral steel duct

Cost per ft $,09S =1.55 D·J6

Cost $,••s

Cost $200.

Galvanized steel elbows

Cost each $,..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/e Pad - 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 of the heavy IUO unit, and will require soil testing and

special engineering approval. The cost ofthe design and installation ofthis pad is included

as part of the 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. For this reason, the construction and startup line items

in the OAQPS cost procedure are set to zero.
Electronic Filing - Received, Clerk's Office, July 17, 2009

ENGINEERING ENVIRONMENTAL

CONSULTING SERVICES

Cost of Controls for the Dix Plant

June 19,2009

Page 16 of23

Control System Cost Assumptions and Parameters

• Allllual cOlltrol period - 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 equipment cost- is $408,833 FOB Anaheim using Adwest costs and cost multipliers as

shown in Figure 1 below:

Figure 1

"

, Equipment Cost of Skid-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 (2006 dala)

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 of over 0.98, 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 of the 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/local sales tax - 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 material cost- 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 of the ductwork and unit will be 19 + 2 =

21 inches water gauge (w.g.).

• Fan efficiency - assumed 70%, which is the high bound of the OAQPS range of 40 to 70%.

• Malar efficiency - assumed 90%. which is the high bound ofthe OAQPS range for motors.

• Overt/II electrical efficiency - 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 of proportionally higher electricity rates for the

next ten-year period,. This is an educated guess, because even the experts on electricity costs

disagree on future rates for the next ten years, except that the rates will probably be much

higher than today.

• Annual electricity cost- would be $90,563 per year as 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 Exhaust Airflow 35,000 clm

dP Total pressure drop 21 inw.g. Adwest 3109

Emotcw Motor efficiency 90';' OAOPS

Ebn Fan efficiency 70% OAOPS 4Cl-70%

Etobl Combined efficiency 63% Elf'OIar xEr.. 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 lper kW1r est 201Cl-2019

S. =

I $86,251 I yr I

Add 5% for unit controls and other powered control-related equipment

I $90,563 I yr I
Electronic Filing - Received, Clerk's Office, July 17, 2009

ENGINEERING ENVIRONMENTAL

CONSULTING SERVICES

Cost of Controls for the Dix Plant

June 19,2009

Page 18 of23

o Interest rate- is assumed at 7% per year, which is the OAQPS dcfault value. IEPA

specifically directed this interest rate value in spite of the fact that IEPA also understands that

a small facility such as the Dix Plant could not secure financing for a large air pollution

control system at any interest rate under current economic conditions. If Royal Pools were

forced to secure funding, the real interest rate might be 20 or 30%.

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

o Natural gas rate - is assumed at $15 per thousand cubic feet (MCF) which includes delivery

charges and taxes.

o Thermal efficiency ofRTO lin it - would be at least 95% according to Adwest.

o Annllalnatllral gas s"pplementalf"el cost - would be $2J 5,950 per year 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 of the specific heat value for air at

1,600 OF, which is provided in Table 7.

o Direct annllal cost other than 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 a test, 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 equivalent to $2,000 per year.

o Filter replacement -would be $7,000 per year based on $0.20-per-cfm-per-year for similar

high efficiency filters.

o Indirect annual costs - 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 oxidizer destrllctian efficiency - assumed to be 96% based on 1,600 OF oxidation

temperature and actual performance test results for other units operated at this temperature.

The detailed control cost calculation for the RTO control system, which follows the procedures

described in the OAQPS Control Cost Manual 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 of Controls 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 dry gas at 77 F

1001 Btu/ft J

OAQPS Appendix 3B, 3-72

OAQPS Appendix 38, 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

Twi 7-7 of waste gas inlet temperature

Two 1.524 'F waste gas r"gen outlet temeprature

T 1,600 'F combustion temperature

T tD 153 'F exhaust (nue) temperature

T,et.at 77 'F reference temperature (auxiliary fuet inlet) OAQPS Appendix 3B, 3-71

Cpm '.;;;-;; 0 Btunb-'F average specific h~at of air

lIh,tyrene 4,805 Blulft3 heat value of pure styrene vapor

m5t)'rene 23.3 ppmv organic volumetric conlent

lIhcwi 0.112 Btu/lt3 heat value of organic volumetric content

lIHcWi 1.5 Btullb heat value of organic 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 of RTO

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 of Controls 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 x T + 0.04697'10" T' /2 + 0.1147'10" T' /3·0.4696 '10" r 14

Cair = ID.!:!I

T2 - 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 of Controls 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 per Adwest Costs

@2007 Engineering Environmental

CAPITAL COSTS NOTES

Direct Costs

Purchased Equipment 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 Adwest quote

Sales Tax 7.75% of A $32,158 Jefferson Co sales tax

Freight 6% of A $25,726 Anaheim CA 10 Dix IL

Purchased Equipment 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 for skid-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

Total Direct 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 by Ad.....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 of Controls for the Oix Plant

June 19,2009

Page 22 of23

Table 8, continued - Control Cost Calculation for the RTO System, Continued

ANNUAL COSTS

Direct Annual Costs (DAC)

Operating Labor

Operator

Supervisor

Operating Materials

Maintenance

Labor

Materials

Replacement Costs

High-efficiency air finers

Utilities

EIec1ricity

Supplemental Fuel

Total Direct Annual Cost (DAC)

Indirect Annual 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 Indirect Annual 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 per yr

E $90,563 see electricity cost

F $215,950 see natural gas 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 IEPA dirBCbon

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 $18,3971par ton
Electronic Filing - Received, Clerk's Office, July 17, 2009

ENGINEERING ENVIRONMENTAL

CONSULTING SERVICES

Cost of Controls for the Dix Plant

June 19,2009

Page 23 of 23

Section IV - Conclusions

If the Dix Plant were to install add-on emission controls, thermal oxidation is the only

commercially available technology that is generally free of technical 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 of reduced 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

2 II onh Broadway

Sl. Louis, Missouri 63102·2750

Mr. Guariglia:

As you requested, a revised worst-case air quality ozone impact analysis of the 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 pcr year to 29.7 tpy for 400 pools per year.

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 greatest ozone 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 2 of2

Revised Air Quality Impact Analysis of the

VOC Emissions from the Royal Pools Facility in Dix, Illinois

using the Scheffe Screening Tables

The most recent available five years ofone-hour average ambient ozone 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 calendar years 2003 and 2005.

Therefore, the one-hour average 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 of 400 pools per year is now 29.7tpy. Styrcnc and MMA are the

only significant VOM emission species from the plant. The only other significant emission

specie is acelone, which is non-photochemicaUy reactive and does not contribute to the

formation of ozone. 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 NOx factors for gas-fired heaters, this maximum usage is

equivalent to:

10 million cu. ft. x 100 Iblmillion cu. ft. 12000 Iblton = 0.50 tpy of Ox emissions.

The annual VOC-to-NOx ratio is 30 10.50 = 60.

According 10 Scheffe Table I "Rural based ozone increment as ajuncfion ofNMOC emissions

and NMOCINOx 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 impact concentration of 85 + 4 =89 ppb.

This worst-case impact is much less Ihan the one-hour average ozone standard of 120 ppb

established by U.S. EPA. Although EPA replaced the one-hour average ozone standard wilh an

eight-hour average 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 8 pound-per-hour VOC limit,

which is also an hourly emission limitation.
Electronic Filing - Received, Clerk's Office, July 17, 2009

EXHIBITS
AS 04-01

(Adjusted Standard)

"

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

ILLINOIS POLLlJrlON CONTROL BOARD

July 22,2002

IN THE MAlTER OF: )

)

PETITION OF CROWNLINE BOATS, INC. )

FOR AN 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 OF PETITIONER;

and

CHARLES E. MATOESlAN APPEARED ON BEHALF OF THE ILLINOIS

ENVIRONMENTAL PROTECTION AGENCY.

OPINlON AND ORDER OF THE BOARD (by N.J. Melas):

Crownline Boats, Inc, (Crownline) is a fiberglass boat manufacturer located 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'Air Pollutants (NESHAP) along with

additional' conditions cOl;tamed in this order:' .' .

On December 5, 2003, Crownline Boats, lnc. (Crownline) filed a petition for an adjusted

standard from 35 Ill. Adm. Code 215.301 ofthe Board's air pollution regulations, commonly

known as the "8 lbIhr RuJe," as that Board regulation pertains to the emissions ofVOM

Crownline's facility is located at 11884 Country Club Road, West Frankfort, Franklin County.

In the petition, Crownline requested a heming, which was held April 23, 2004. The Illinois

Environmental Protection Agency (Agency) filed a recommendation that the Board grant

CrownIine's petition on January 22, 2004.

Accompanying the petition, Crownline filed a motion for expedited review. Crownline

asserts that the Agency recently issued Crownline a Title V Clean Air Act Pennit Program

(CAAPP) permit and Title I permit, requiring Crownline either to obtain an adjusted standard

from 35 TIL Adm. Code 215.301 or demonstrate compliance with that section by December 31,

2004. On the same day, Dale A. Guariglia filed a motion requesting permission to appear pro

hac vice on behalf ofpetitioner in this proceeding in accordance with Section 101.400(a)(3). 35

Ill. Adm. Code 101.400(a)(3). The Board granted both Crownline's motion for expedited review

and Mr. Guariglia's motion to'appear pro hOI: vice.

. Based on the record before it, the Board finds that Crownline has provided sufficient

justification for each ofthe Section 28.1 factors.· The BOard giants Crowniine an adjusted

Standard from the 81blhr Rule subject to 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 et seq. (2002)) and Board rules

provide that a petitioner may request, and the Board may grant, an environmental standard that is

different from the generally applicable standard that would otherwise apply to the petitioner.

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 104.400 et al.

The Board rules for the content requirements of the petition and Agency recommendation

are found at Section 104.406 and Section 104.416, respectively. 35 III. Adm. Code 104.406,

104.416.

PROCEDURAL BACKGROUND

On December 5, 2003, Crownline filed this petition (pet.), accompanied by a motion for

expedited review, with the Board for an adjusted standard from the paper coating rule. From

December 10,2003 through December 24, 2003, Crownline published notice ofthe petition in

the West Frankfort Daily American, and filed the· certificate ofpublication with the Board on

January 5, 2004. The Agency filed its recommendation (Ree.) that the Board grant Crownline's

. requested relief On January 22,2004, subject to certain terms and conditions contained in the

Agency's recoriunendation.

On April 23,2003, Hearing Officer Carol Sudman conducted a hearing in this matter at

the offices ofthe West Frankfort City Administration Office, 110 North Jefferson Street, West

Frankfort. Three witnesses testified at hearing: Mr. James T. Claxton, president ofCrownline

Boats; Mr. Dale Guariglia, attOrney for Crownline; and Mr. Andrew Polcyn, consultant for

Crownline. Hearing officer Sudman found all three witnesses credible. Mr. David BloOl~berg

was also present on behalf o.fthe Agency's Bureau ofA.ir. At hearing,.Crownline offered eight

exhibits (pel. Exh.). Crownline filed a post-hearing briefon May 14, 2004 (pel Br.), and the

Agency filed a post-hearing brief on May 17,2004 (Ag. Br.).

FACTUAL BACKGROUND , '

Tbe Facility

Crownline owns and operates a fiberglass boat manufacturing facility where it

. manufactures approximately 30 different mndels ofpersonal recreation fiberglass boats ranging

from 17'6" oPen bow boat, to a 29' cabin cruiser: Pet. at 4. SinCe it began operations in 1991,

Crownline has manufactured approximately 40,000 boats, currently producing between 15-20

boats each day. The FrankfOrt facility began operation in 1994 and employs approximately 500-

600 individuals. !d. .

Crownline's boat manufacturing process 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 petition focuses mainly on the gel coat and
Electronic Filing - Received, Clerk's Office, July 17, 2009

3

lamination production areas, since they generate most ofCrownline's YOM emissions and are,

therefore, most impacted by the 8 lblhr Rule. In addition, Crownline notes that the use of

adhesives, lacquers, and Caulks in other production areas also .do not meet the 8 Iblhr Rule on a

strict hourly bases. Pet. at 4. Crownline's YOM emissions that do not meet the g·jblhr Rule

consist primarily·ofstyrene..Id.

GeJcoat Application

The purpose ofthe gelcoat application is to provide color and a smooth surface to the

fiberglass boats. Pet. at 5. Molds are prepared for the gelcoat application by cleaning with

stripping solvent and a wax-releasing agent applied. Pet. at 4. In one offour gelcoat booths,

gelcoat ·is applied tei the hull or deck mold in a single application using air atomized spray guns.

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

Lamination

After the gel coat has dried, the molds are moved to one oftwenty-four laminating

stations. Pet. at 5. During lamination, glass fibers, polyester resin and a resin catalyst are

applied to the mold using non-atomized flow-coat chopper guns (f1ow-coat guns). The layer of

. fiberglass and resin is then rolled flat using hand rollers to remove any air bubbles that were

.created in the application. Laminate is applied in layers called "skins" and requires curing

periods between each skin application. Pet. At 5. Three resin skins are typically applied to

decks and two to three skins for hulls, followed by a separate application to build the boat floor.

Id. .'

, :': .

Pollution Control Equipment In Use.

In the gclcoat application and lamination prooesses, Crownlirie uses the following: (I) a

. high-volume ventilation system to keep styrene levels below the worker exposure limit required

by OSHA; (2) enclosed spray booths in the gelcoat application process to reduce YOM

emissions info the plant air when using spray guns; (3) use oflower styt:ene-content gelcoat

(33.4%) and resin with lower hazardous air pollutant (HAP) content (35% HAP); (4) f1oy,>-coat

guns in place of air atomized spray guns in the lamination area, (5) panel filters inside the spray

booths and lamination areas to control particulate emissions fiom the spray guns; and (6)

submerged-fill resin tanks in the lamination process to reducesplashiog and the creation of YOM

emissions. Pet. at 5.

YOM Emissions

Crownline states that the YOM emissions from the facility vary depending on the type

and size of each custom boat it manufactures. Pet. at 5. Crownline's emissions consist primarily

ofstyrene; but also include other YaMs and volatile organic HAPs such as methyl methaCrylate

(MMA). Technical Doc. at 6, 7, App. 7.

For purposes of complying with the 8Jblhr·Rule, the Agency directed.Crownline to

consider each boat part (e.g., hull, deck, etc.)'as the "emission source." Pet. Exh. I at 4. From
Electronic Filing - Received, Clerk's Office, July 17, 2009

4

the individual emission sources, Crownline estimated hourly YOM emissions. Among the

highest were 34.08 Ibihr for gray lacquer, 15.891bihr for carpet adhesive, 21.8 lblhr for gelcoal,

and 19.8 IbIhr for resin. Technical Doc. App. 7, Pet. Exh. I, Exh. 5 and 6. Crownline notes that

some values were overestimated, but several boat models still have parts with emissions greater

than 8 Iblhr when YOM emissions are determined on a strictly hourly 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 199.79tpy YOM, and the 8 Iblhr scenario 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 the MAcr scenario would result in a

50 tpy reduction in HAP. Pel. Exh. I at 7.

CAAPP Permit

In discussions between the Agency and Crownline regarding CroWnJine's draft CAAPP

operating permit, the Agency stated that Crownline could not average emissions to demonstrate

compliance with the81blhr Rule. The Agency stated that the 8 Iblhr Rule specifies a maximum

hourly emission rate and, therefore, compliance would need to be demonstrated on a strict hourly

.basis, not on an average from any longer period oftime. Crownline determined that based on the

Agency's interpretation, it could not coml?ly .with the-8lblhr Rule.. Pel. at I ..

On November 13, 2003, the Agency issued Crownline a Title 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. Code 215.301 or demonstrate cOmpliance with Section 215.301 by

December 31,2004. Pet at 2. Crownline's CAAPP pennit limits annunl emissions to 249 tons

ofVOM per year. Pet. Exh. I at 8.

STANDARD OF REVIEW

The Board agrees'with Crownline and the Agency that the regulation ofgeneral

applicability at 35 ID:'Adrn. Code 2J 5.301 does not specify a level ofjustification for an adjusted

standard. Pet at II; Ret:. at7. Therefore, p~ant to Section 28.I(c) ofthe Act, the burden of

proofis on the petitioner to demonstrate that:

I. . Factors relating to that petitioner are substantially and significantly

different from the factors relied upon by the Board in adopting the general

regulation applicable to that petitioner;

.2. The. existence ofthose factors justifies an adjusted standard;

3.' The requested standard will not result in environmental or heilth effects

substantially and significantly. more adverse than the effects considered by

the Board in adopting the rule of general 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).

CURRENT APPLICABLE STANDARDS

One standard applicable to Crownline's boat manufacturing operations is set forth in 35

III. Adm. Code 215.301. Section 215.301 provides:

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 215.30 I.

.For purposes of complying with the 8 Ib/hr Rule;the Agency has directed Crownline to

consider each boat part (e.g., hull, deck, etc.) an emission source. Pet. Exh. 1 at 4.

Under separate federal regulation effective August 23,2004, Crownline must also meet

" 'newly promulgated NESHAPs for New and Existing Boat Manufacturing Facilities applicable to

, boaimanufacturers that are major sources ofHAP. 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 enforceable under.the Act without additionall1llemaking'activity by the ·Board. 415

..'LCS 5/9.I(a) (2002). .

The rnl e requires that boat manufacturers use maxirnuin available control technology

(MAC1) to meet the "MACf floor," which is the emission limitations achieved by the top

performing 12% ofboat manufacturers in the nation. Pel at 6. To comply with a HAP limit

calculated for a facility, manufacturers can use one ofthe following options: emissions

averaging using a J2-month rolling average, compliant materials, and/or add-on controls. 40

C.F.R. 63.5701, 63.5710. Other requirements include; using lower HAP content gel-coat and

resins; covering resin, gelcoat and solvent containers; and using cleaningsolvents and adhesives

containing no more than 5% HAP. The MACT standard does not require air pollution .

eqtitplli'enL To' c(iiilply'With MACT, Crownline opin~ that most-boal m!inilf;lclurers with open

molding operations will have to use flow-coat guns and low-HAP production materials in their

resins, gelcoats, and adbesi ves. A flow coat gun generates fewer emissions because it operates at

. a lower pressure and has a non-atomized delivery system. The United States Environmental

Protection Agency (USEPA) estimates that by complying with the new 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 new MACT standard. CrownIine

uses flow-coat guns ill its lamination operating and resin and gelcoat with lower percentages of

HAP content. Pet. at 6. Crownline has not yet made a demonstration of compliance to the

USEPA, and will not be required to do so until August 2005.' Pet. Elch. rat 3.
Electronic Filing - Received, Clerk's Office, July 17, 2009

6

CROWNLINE'S PROPOSED ADJUSTED STANDARD

In the petition, Crownline proposed the following adjusted standard language for

adoption by. the Board:

OW,••

Pursuant to the authority under Seetion 28.1 of the Environmental Protection Act,

the Board hereby; adopts the following' adjusted standard: This. adjuste4 standard

shall apply solely to Crownline Boats, Inc. (UCrownline"). As an alternative to

compliance with 35 lAC § 215.301, this adjusted standard allows Crownline to

limit its discharge oforganic material into the atmospbere from its boat

manufacturing operations by complying with the National Emission Standard for

Hazardous Air Pollutants for New and Existing Bo.at Manufacturing Facilities, set

forth at 40 CFR §63 Subpart VVW, as may be amended in the future.

The Agency recommended that the Board grant Crownline the requested 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 for New 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 compliance with the National.Emission Standard for

Hazardous Air Pollutants for New and Existing Boat Manufacturing

Facilities, 'set forth lit 40 CFR Section §63 Subpart VVVV, as may be

· amended in the future, shall be.in lieu'of compliance with the 8 .Iblhr Rule

found at35 m. Adm. Code 215.301.

c. Crownline sball continue to investigate boat production methods with a

'reduced YOM content and, where practicable, shall substitute current

coatings with lower YOM content coatings as long as such substitution

does not result in a new increase in YOM emissions. Crownline $aJl be

required to do any test which'the lIlinois EPA specifically recommends

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

these investigatory efforts shall be prepared by Crownline and submitted

to the illinois EPA Bureau ofAir, Compliance and Enforcement.

d. The relief granted in this proceed.ing shall be limited to the emission

activities at the Crownline West Frankfort facility as ofthe date ofthis

filing.

e. Crownline shall operate in full compliance with the Clean Air Act, its

·CAAPP, the Olinois Environmental Protection 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 alternative to compliance with the 8 lQlhr Rule found at 35111. Adm. Code

215.301, this adjusted standard allows Crownline to limit its discharge of organic

material into the atmosphere from its boat manufacturing operations by operating

in full compliance with the National Emission Standard fOf Hazardous Air

Pollutants for New and Existing Boat Manufacturing Facilities, set forth at 40

C,F.R. §63, Subpart VVVV, as may be amended in the future, and with the

following conditions:

a. Crownline shall continue to investigate boat production methods with a

reduced YOM content and, where practicable, shall substitute current

coatings with lower YOM con'tent coatings as long as such substitution

,does not result in a net increase in YOM emissions. Crownline shall be

required to do any reasonable test of new technologically or economically

reasonable production methods or materials applicable to the open-mold

fiberglass boat manufacturing industry which may reduce YOM emissions

at Crownline's facility which the llIinois EPA Bureau ofAir specifically

requests in writing that they do. An annual report summarizing the '

activities and results ofthese investigatory effo~ shall be prepared by

Crownline and submitted to the Dlinois EPA Bureau ofAir, Compliance

, and Enforcement Section. , ':', , . :;'. '. "

..' '. ".

b: The reliefgranted in this proceeding shall'be·limited,to.lbe,emission

activities'at Ibe CroWn.line West Frankfort,facility as ofthe date ofthis

filing.

c, Nothing in this adjusted standard shall relieve Crownline of its duty to

operate in full compliance with the Clean Air Act. its CAAPP, the illinois

Environmental Protection Act and other applicable regulations not

otherwise discussed herein.

- GR6WNLINE'S COMPLIANCE WITH THE MAGT STANDMU>

Under separate NESHAP requirements applicable to Crownline under Section 9.l(a) of

the Act, Crownline states it took steps early to comply with the MACT and came into

compliance with MACT emission limits more than a year prior to the deadline. Pet. at 2,

However, CrowoJine has not yet demonstrated compliance, and will not have to until August

'2005. Pet. Exh. I at 3, Crowoline slates that it will demonstrate compliance to USEPA with the

new MACT standard by using the "model point value averaging option" based on a 12-month

rolling average and by using compliant materials. [d. CrownJine notes that its HAP emission

limits will vary from month to month based on an'equation set forth in 40 C.F,K 63,5698. 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 of compliance of$4,060 per ton of HAP

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 (nof total YOM) by approximately 50 tons. or 25%. Pet. Exh. I at2.

Crownline's annua).compliance cost'is approximately $4,312 per ton 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 244.82tpy YOM to 199.79tpy YOM under the

MACf scenario. 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

comply with the 81b/hr Rule: (I) reducing YOM content in production materials; (2) using

alternative operating procedures and methods; and (3) installing end-{)f-the'pipe emission

control. Crownline states that investigations proved that, other than end-{)f-the-pipe emissiQn

controls, many ofthe alternatives would not bring Crownline into compliance with the 8 IbIhr

Rule on a strict hourly basis. Pet. at 6.

Reducing YOM in Production Materials

Crownline has reduced YOM in its resin and gelcoat production materials to meet the

federal MACT standard. ·How.ever, meeting the MACT.standard .a1one,wiIl not bring CrownJine

into complianee with the State 8 Ib/hr Rule: CrownJine:states that it is not possible to further

reduce styrene in thcnesins.and·still maintain product integrity. ·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 of adhesives, lacquer.·and caulks.

Vsmg Alternative Operatmg Procedures and Methods

Crownline states that it investigated both open molding and closed molding alternative

production methods. However, Crow.nJine found that even though the alternatives investigated

would reduce YOM emissions. they would not bring Crow.nJine into compliance with the 8 Iblhr

Rule on a strictlY hourly basis. Crownline explained that the open and closed molding

alternative production methods investigated are only available to the lamination process and

·there are no alternative technol~l?;ie'"=c:ntlY'availllblef6~the gelceat, lacquering. caulking. and

adhesive operations. Pet. at 7. Crownline replaced its atomized spray chopper guns used for

resin application with flow-coat guns in its lamination area. Technical Doc. 8t4. The flow-coat

guns have lower pressure and internal mixing as compared to the atomized guns. Pet. at 5.

Crownline states it experimented with using Dow-coat guns in the gelcoat process, but they had'

too much of a negative impact on product quality. Pet. Exh. I at2.

End-or-Pipe Controls

In developing· the MACT, the USEPA did not include any emission control technologies

as the MACT floor for. the follo'wing reasol)S: (I) only one boat manufacturer used tliilstack

emission controlteclIDologies to reduce HAP 'emissions; (2) the cost of emission control systems

was very high beCause very high 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) the boat manufacturing industry can reduce HAP content of resins, gelcoat,

and other materials to significantly reduce total HAP emissions without undue financial burden.

Pet. at 7.

CrownJine's consultant investigated the various end-of-pipe control technologies. As a

result of the analysis, Crovmline detennined that emission controls are cost prohibitive 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 per ton ofVOM removed. Pet. at 8; Technical Doc. at 16, 18.

CrownJine explains that the reason end-of-pipe controls are so costly is because of the

large volume of air that must be treated in order to reduce the relatively small amount ofVOM.

As discussed above, Crownline must move a large volume of air through the gelcoat and ,

lamination areas to maintain compliance with OSHA's 8:hour worlcer expoSure limit for styrene.

Technical Doc. at 16, 18.· .

SUBSTANTIALLY DIFFERENT FACTORS

Crownline slates that the primary intent of the 8 Iblhr Rule was to prevent ozone

formation and odor nuisance. Crownline asserts that the Board did not contemplate the methods

Crownline uses to manufacture boats at the Frankfort facility.when it promulga,ted the 8 lb/hr

Rule inI9?!. Pet. at 11. Crownline.states that manufacturing-fiberglass boat decks.or hulls

involves a patch-type process rather than'. continuous'application p~ocess 'typically used·in

manufacturing processes for other products~ CrownliIie argues·this- facttogether with·the

ventilation'system it uses to 'comply with OSHA's Worker protection regulation 3129 C.F.R.

1910 makes the use of add-on emission controls economically unreasonable. Under OSHA

worker bealth and safety Standards for styrene, Cro~e must maintain high air flow to

ventilate building air. The high air flo\v makes the cost ofusing tail-end slack emissions controls

. unreasonably high. Crownline states that the Board did not anticipate the current fiberglass boat

production methods and the OSHA standard when it adopted the 81b/hr Rule 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, CrownJine performed 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 of ozone formation. Id. Crownline contends that even without the changes it

implemented to meet the MACf standard, the Crownline facility would not cause or contnbute

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 of the I-hour ozone' NMQS: ·Pet. EXh'-l at 8, Pet.EXh~2.·:CurrentJY:'the

Crownline facility emits approximately. 195 iori.iyr of\'OM per year, aD:! is permitted to .

produce 249 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 of VOM per year. Rec. at 6. Before making any changes, the

facility would emit approximately 245 tonslyr of VOM for similar production figures. Jd..

The Agency agrees with Crown/ine that if Crownline 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 of solid waste

generated and no adverse impacts on water quality and energy consumption from the adjusted

standard. Pet. at I L

CONSISTENCY WlTH FEDERAL LAW

Crownline Slates there is no Oean Air Act equivalent rule or regulation prohibiting boat

manufacturers' emissions of VOM in excess of 8 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 if the .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 reiieffro~.ihe.Slate'~~.lblhr!iulein the{oxm ofII!' adjusted stand.ani. .

Under separate federal:regulation..applicable to it under Section 9.-1(a) ofthe Act,.Crownline is .

already required io 'comply with the NESHAP 'for New and EXi~g Bc;>at MBnutacturing .

Facilities, which limits HAP emissions from ,facilities such as the Crownline West Frnmfort .

plant. Crownline must comply with the MACT emissions limits under this 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 reliefsubj ect

to certain conditionS. Ifgranted, the adjusted standard would apply only to the m8terial~ and

methods Crownline uses to manufacture fiberglass boats at its West Frankfort facility.

. The,Board fu.>,dsthat.Crownliqe's reque~\Jor r~firp)ll. the)\ IbIhrRuI~~~the, .",.

statutory "fundamentally different" factors ofsection 28.I(c) ofthe Act. Crown/ine has

. demonstrated that (Ijfaetors relating to it are substantially and significantly different from the

factors relied upon by the Board in adopting the general regulation; (2) the existence ofthese

factors justifies an adjusted standard; (3) the requesied standard will not cause substantially or

significantly more adverse environmental or health effects than the effects considered by the

Board in adopting the rule ofgeneral applicability; and (4) the adjusted standard is consistent

with applicable federal laws. 415 ILCS 5128.I(c) (2002).

Crc;>w.n1ine bases itsjustification fOl: the requested relief on the Jack ofan ecooomic3JJy

reasonabl~ 9r techpica)ly feasibl~ .a1~erpative. The BOl'l'd finds that.t!)~ effor!$ beyond those

Crownline bas already implemented in the three categories of.alt~rnatives that Crowniine

investigated (reducing VOM content in production materials, employing alternative operating

procedures and Production methods, and applying end-of-pipe controls) are not currently
Electronic Filing - Received, Clerk's Office, July 17, 2009

II

technically feasible or ecolIornically reasonable. Additionally, the Ozone Impact Analysis shows

that CrownJine's emissions will not cause negative health or environmental effects.

The Board finds no inconsistency between granting Crownlinc's requested relief and

federal law. Finally, the Board finds that the Board did not anticipate. the batcb-type.proce.sses of

coating and laminating fiberglass boat parts that Crownline employs at the West Frankfort

facility when it promulgated the 8 IbIhr Rule at" Section 215.301. As a matter oflaw, Crownline

must comply with the MACf emissions limits by August 23, 2004, which Crownline states it has

achieved over a year early.

The Agency's recommended 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 specifically to the emission activities at the

Crownline West Frankfort,facility, the effective date being t1)e Board's final decision in this

matter: The Agency's adjusted standard l8hgliage rei'tetafcd that CrownliiJe' niUst operate in full

compliance with the federal standard. !d. The Agency proposed language requiring Crownline

to continue to investigate boat production methOds and, where practicable, substitute current

coatings with lower YOM content coatings as long as the suhstitution does not result in increased

YOM emissions, The Agency 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 three conditions, with no

objection by the Agency. The reVised' wording incoiporated·the·Agency's proposals to: .(1)

contlIlUe1ci investigate boat production methOds with a'rtduced .yOM-content'aod, where·

practicable, substitute current coatings with lower VOM content coatings SO long as the

substitution does not result in higher YOM emissions; (2) perform any reasonable test ofnew

production methods or materials that the Agency, Bureau ofAir, request in writing that they do;

and (3) submit an annual report summarizing the activities and results oftheirinvestigatiollS.

The revised wording also reiterates that Crownline must operate in Compliance with the federal

standard.

In grantin'g this adjusted standard, the Board is adopting conilltions similar, but not

identical·in wording, to those'suggested by the parties. "TheBoard used Crownline's revised

language and, as the Agency recommended, the Board has tightened up the description of the

facility and clarified reporting requirements. The. balance ofthe changes are non-sub'stantive,

and are intended to bring this order into conformity with the Board's usual drafting style in

adjusted standards.

CONCLUSION

The Board grants Crownlme's requested relief and exempts it from the 81blhr Rule at

Section 215.301 ofthe Board's regulations at its facility in West Frankfort; FmrikJin CoiJnty,

Crownline reinains-subject to the NESHAP ajlplicable" to'its facility and suggested-conditions.

The relief is 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 of the Environmental'Protection A-et (Act) (415 ILCS .

5/28.1), the Board grants Crownline Boats, Inc. an adjusted standard from 35 III.

Adm. Code 215.30 I (8 ·Ibihr Rule), effective July 24, 2004. The adjusted standard

applies to the emissions of volatile organic material (YOM) into the atmosphere

from Crownline's boat manufacturing facility located at 11884 Country Club

Road, West Frankfort, Franklin County.

2. 35 TIL Adm. Code 215.301 does not apply. Crownline remains subject to the

following:

a. Crownline must continue to investigate boat production methods that

generate fewer YOM emissions and materials that have a reduceil YOM

content Where practicable, Crownline must substitute current materials

with lower YOM content materials as long as such substitution does not

result in a net increase in YOM emissions.

b. Crownline must perfonn any reasonable test ofnew technologically or

economically reasonable production methods or materials applicable to the

open-mold fiberglass boat manufacturing industry, which may reduce

YOM emissions at Crownline's facility which the U1inois Environmental

Protection Agency (Agency) specifically requests in writing lhat they do.

C. Crownline musf prepare and submit each year an annual report

summarizing the activities and results ofthese investigatory efforts. The

annual report must be wbmil\ed to the Agency, Bureau ofAir,

Compliance and Enforcement Section;

d. Crownline must operate in full compliance with the Clean Air Act, its

Clean Air Act Pennit Program permit, theNational Emissions Standard

for Hazardous Air Pollutants for New and Existing Boat Manufacturing

Facilities, set forth at 40 C.F.R. 63, Subpart VVVV, as required by Section

9.1 (a) ofthe Act, and any other applicable regulation.

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); see aLto 35 DJ. Adm. Code I01 JOO(d)(2), 101.906, 102.706.

llIinois Supreme Court Rule 335 establishes filing requirements that apply when the llIinois

Appellate Court, by statute, directly reviews administrative orders. 172 nJ. 2d R. 335. The

Board's procedural rules provide that motions for the Board to reconsider or modify its final
Electronic Filing - Received, Clerk's Office, July 17, 2009

13

orders may be filed with the Board within 35 days after the order is 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, certify that the Board

adopted the above opinion and order on July 22,2004, by a.vote of 5-.0.

~I>t-~

Dorothy M. Gunn, Clerk

lllinois Pollution Control Board

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

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MAITER OF:

Petition of Royal Fiberglass Pools, Inc.

for an Adjusted Standard from

351AC § 215.301

)

)

)

)

)

AS 2009-04

(Adjusted Standard)

TECHNICAL DOCUMENT SUPPORTING ROYAL FllJERGLASS POOLS, INC.'S

FIRST AMENDED PETITION FOR AN ADJUSTED STANDARD

Section

2

3

4

5

Description

General Information Regarding Royal Fiberglass Pools and Photographs of the

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 a Regenerative 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

One Metropolitan 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 Document was served

upon the following panies on the ('t""Oay ofJuly, 2009:

Illinois Pollution Control Board, Attn: Clerk

100 West Randolph Street

James R. Thompson Center, Suite 11-500

Chicago,IL 60601-3218

Division ofLegal Counsel

Illinois Environmental Protection Agency

1021 North Grand Avenue East

P.O. Box J9276

Springfield, IL 62794-9276

Attn: Charles Matoesian