333.92 T579ex EFFECT OF RACT II ENVIRONMENTAL CONTROLS IN ILLINOIS R80-5 DOCUMENT NO. 81/28 DEPOSITORY MAR 1 8 1982 UNIVERSITY Oh ILLINOIS AI URBANA-CHAMPAIGN ENVIRONMENTAL MANAGEMENT DIVISION Illinois Institute of Printed by Authority of the State of Illinois UNIVERSITY OF ILLINOIS LIBRARY AT URBANA-CHAMPAIGN BOQKSTACKS DOC, NO- 81/28 August, 1981 EFFECT OF RA.CT II ENVIRONMENTAL CONTROLS IN ILLINOIS, R80-5 by George S. Tolley Stuart B. Townsend Timothy R. Guimond RCF , Inc . Suite 717 104 South Michigan Avenue Chicago, Illinois 60603 Project No. 80.207 Frank Beal, Director State of Illinois Institute of Natural Resources 309 West Washington Street Chicago, IL 60606 NOTE This report has been reviewed by the Institute of Natural Resources and approved for publica- tion. With the exception of the Opinion of the Institute's Economic Technical Advisory Committee, views expressed are those of the contractor and do not necessarily reflect the position of the IINR. Printed by Authority of the State of Illinois Date Printed: August, 1981 Quantity Printed: 500 Illinois Institute of Natural Resources 309 West Washington Street Chicago, IL 60606 (312) 793-3870 11 Opinion of the Economic Technical Advisory Committee of the Illinois Institute of Natural Resources The Economic Technical Advisory Committee has reviewed and approved an INR study entitled: Effect of Ract II Environmental Controls in Illinois . The document has also been subject to inten- sive review by the Institute's staff and has been approved for pub- lication. The ETAC and the Institute note that the costs of implementing the RACT II environmental controls exceed the benefits by a substan- tial margin. The total annual costs of implementation are estimated at $38.3 million, expressed in 1980 dollars. The most likely estimate of increased costs of unemployment and providing government services is estimated at $1.2 million. On the other hand, the most likely estimate of benefits (health, vegetation, materials and other ancil- lary effects) of RACT II was estimated at $4.9 million per year. This study estimates that reduced emissions that could be at- tributed to the implementation of RACT II would be 12.5 percent below the levels that would occur in the absence of the implementation of the regulation. In addition, reductions in second highest once-hour ozone level due to RACT II were projected to be 12.2 percent for Chicago and 14.7 percent for the St. Louis areas. However, these reductions would not be sufficient enough to bring the aforementioned areas into "attainment" status. The ETAC and the INR note that the cost of compliance with the proposed regulation would vary from industry to industry in the State. Some would experience higher costs than projected in the economic study, i i i while others may incur lower costs of compliance. The impact study includes a sensitivity analysis to delineate probable ranges. We note that there will be no benefit in applying RACT II as proposed to sources located in attainment areas within the State. Notwithstanding the above referenced caveats, we find the study to be in compliance with the applicable provisions of Public Act 80-1218. We recommend that the Illinois Pollution Control Board schedule technical merit hearings on this economic impact study. TV Preface The Illinois Environmental Protection Agency has proposed amendments and revisions to the Illinois Pollution Control Board's rules and reg- ulations concerning emission of volatile organic material. These measures, in further compliance with section 172 of the Clean Air Act, include new requirements for a group category referred to as RACT II (Reasonably Available Control Technnol- ogy) and refinements to the RACT I regulations. Under the provisions of Public Act 79-700, the Illinois Institute of Natural Resources must perform economic impact studies for all amendments and petitions to regulations submitted to the IPCB. The economic impact analysis submitted herewith is intended to satisfy that requirement. The study was carried out by RCF , Inc. under contract to the Institute and constitutes the final report to Project No. 80.207: Economic Impact of Amendments to Air Pollution Control Regulations — Emission of Volatile Organic Material, R80-5. V Digitized by the Internet Archive in 2013 http://archive.org/details^ffectofractiien8128toll CONTENTS Page LIST OF TABLES X EXECUTIVE SUMMARY xiv 1. INTRODUCTION 1 1.1 Background of Proposed RACT II Regulations 1 1.2 Difference Between RACT I and RACT II 2 1.3 Description of the RACT II Regulations 4 1.4 Need to Predict Effects on Ozone 5 1.5 Cost Considerations 7 1.6 Benefit Considerations 8 2. AIR QUALTIY IMPACTS OF RACT II 9 2.1 Recent Ozone Levels 10 2.2 VOM Emissions as a Precursor to Ozone 15 2.3 Effect of RACT II on Emissions 18 2.4 Air Quality Modeling 21 2.4.1 Available Air Quality Models 22 2.4.2 Results for Three Major Urban Areas 27 2.4.3 Results for Remaining Areas 31 2.5 Summary 34 3. COSTS OF RACT II 37 3.1 Direct Costs of RACT II 37 3.1.1 Rotogravure and Flexography 38 3.1.2 Petroleum Refining Leaks 47 3.1.3 Surface Coating of Metal Products 53 3.1.4 Storage Tanks with Floating Covers 67 vii CONTENTS (Continued) Page 3.1.5 Synthesized Pharmaceuticals 73 3.1.6 Perchloroethylene Dry Cleaners 80 3.1.7 Pneumatic Rubber Tire Making 87 3.1.8 Direct Cost Estimate Ranges 94 3.2 Indirect Effects of RACT II 100 3.2.1 Changes in the Illinois Economy 101 3.2.2 Monetary Values Associated with Indirect Effects of RACT II in Illinois 110 3.3 Summary 113 4. BENEFICIAL EFFECTS OF REDUCED OZONE CONCENTRATIONS 117 4.1 Human Health 118 4.1.1 Toxicological Evidence 118 4.1.2 Clinical Evidence 119 4.1.3 Epidemiological Evidence 120 4.1.4 Health Effects of RACT II in Illinois 121 4.2 Vegetation 134 4.2.1 Effects of Ozone on Vegetation 134 4.2.2 Vegetation Effects of RACT II in Illinois 139 4.3 Materials 145 4.3.1 Effects of Ozone on Materials 145 4.3.2 Materials Effects of RACT II in Illinois 147 4.4 Summary 152 5. CONCLUSIONS 155 5.1 Air Quality Impacts of RACT II 155 viii CONTENTS (Continued) 5.2 Costs of RACT II 5.2.1 Direct Costs of RACT II 5.2.2 Indirect Costs of RACT II 5.2.3 Total Costs of RACT II 5.3 Beneficial Effects of RACT II 5.3.1 Health Effects 5.3.2 Vegetation Benefits 5.3.3 Materials Benefits 5.3.4 Summary of Beneficial Effects of RACT II Page 157 158 161 162 164 164 166 166 167 REFERENCES 170 APPENDIX A: THE PROPOSED RACT II AMENDMENTS APPENDIX B: OZONE STANDARD ATTAINMENT STATUS FOR COUNTIES OF ILLINOIS APPENDIX C: ECONOMIC FACTORS C.l Price Deflators C.2 Capital Charges C.3 Price and Output Changes C.4 Use of the Illinois Input-Output Model 177 213 217 217 219 219 221 IX LIST OF TABLES Page TABLE I Total Annual Costs and Emission Reductions Expected from Implementation of RACT II in Illinois xii TABLE 1.1 Description of Proposed RACT II Regulations 6 TABLE 2.1 Second Highest One-hour Concentrations of Ozone 11 TABLE 2.2 Hydrocarbons Identified in Ambient Air 17 TABLE 2.3 Effect of RACT On Emissions of Volatile Organic Materials 19 TABLE 2.4 Second Highest One-hour Ozone Levels before and after Implementation of RACT II in Illinois 29 TABLE 3.1 Control Technology Percentage Emission Reductions for Rotogravure and Flexographic Printing 39 TABLE 3.2 Information on Firms Affected by Proposed RACT II Regulations for Rotogravure Printing 41 TABLE 3.3 Estimated Cost of RACT II Controls for Lustour Corporation 43 TABLE 3.4 Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Model Rotogravure Printing Plants 45 TABLE 3.5 Total Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Rotogravure Printers in Illinois 46 TABLE 3.6 Information on Petroleum Refineries in the State of Illinois 48 TABLE 3.7 Cost of RACT II Controls for Leaks in a Model Refinery 49 LIST OF TABLES (Continued) TABLE 3.8 TABLE 3.9 TABLE 3.10 TABLE 3.11 TABLE 3.12 TABLE 3.13 TABLE 3.14 TABLE 3.15 TABLE 3.16 TABLE 3.17 TABLE 3.18 Page Total Control Costs and Emission Reductions of RACT II for Refinery Leaks in Illinois 52 Information on Firms Affected by RACT II Regulations for Surface Coating of Miscellaneous Metal Parts and Products 56 Number of Emission Sources of Affected Miscellaneous Metal Parts and Products Surface Coaters in Illinois, by Type 61 Control Costs and Emission Reductions for Model Surface Coating Operations 63 Total Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Miscellaneous Metal Parts and Products Surface Coaters in Illinois 66 Number of External Floating Roof Tanks, by Type 68 Control Costs and Emission Reductions for Model External Floating Roof Tanks in Illinois 71 Total Control Costs and Emission Productions of RACT II for External Floating Roof Tanks in Illinois 72 Information on Synthesized Pharmaceutical Manufacturers 7o Number of Synthesized Pharmaceutical Manufacturing Emission Sources Affected by RACT II Regulations, by Type 76 Control Costs for Model Synthesized Pharmaceutical Emission Sources 78 XI LIST OF TABLES (Continued) TABLE 3.19 TABLE 3.20 TABLE 3.21 TABLE 3.22 TABLE 3.23 TABLE 3.24 TABLE 3.25 TABLE 3.26 TABLE 3.27 TABLE 3.28 TABLE 3.29 Page Total Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Synthesized Pharmaceutical Manufacturers in Illinois 81 Number of Dry Cleaners with Payrolls in Illinois, by Type 83 Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Model Perchloroethylene Dry Cleaning Plants 86 Total Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Perchloroethylene Dry Cleaners in Illinois 88 Information on Pneumatic Rubber Tire Plants in Illinois 90 Information on Pneumatic Rubber Tire Manufacturing Processes Affected by Proposed RACT II Regulations 91 Costs of RACT II Controls for Model Pneumatic Rubber Tire Manufacturing Processes 92 Total Control Costs, Emission Reductions and Cost Effectiveness of RACT II for Pneumatic Rubber Tire Manufacturers in Illinois 93 Estimated Price Changes from RACT II in Illinois 102 Impact of RACT 1 1 on Output and Employment in Illinois 105 Impact of RACT 1 1 on Unemployment and Emigration in Illinois 107 Xll LIST OF TABLES (Continued) TABLE 3.30 TABLE 4.1 TABLE 4.2 TABLE 4.3 TABLE 4.4 TABLE 4.5 TA3LE 4.6 TABLE 4.7 TABLE 4.8 TABLE 5.1 TABLE 5.2 TABLE 5.3 TABLE B.l TABLE C.l Page Capital Costs, Annual Costs, and Emission Reductions in Industries Required to Adopt RACT II Controls 114 Ozone Related Health Symptom Person-days in Illinois before RACT II and Changes Due to RACT II 124 Estimated Exposure Thresholds for Adverse Effects of Photochemical Oxidants 127 Monetary Value of Health Symptom Improvements from RACT II in Illinois 131 Determinants of Plant Response to Ozone 137 Effects of Long-term Ozone Exposure on Growth, Yield and Foliar Injury to Corn, Soybeans, Oats and Wheat 138 Plant Losses from Oxidant Air Pollutants 140 Economic Benefits of RACT II from Reduced Vegetation Damage in Illinois 143 Economic Benefits of RACT II from Reduced Materials Damage in Illinois 150 Direct and Indirect Costs of RACT II in Illinois 163 Ozone Related Health Symptom Person-days in Illinois before RACT II and Changes Due to RACT II 165 Monetary Values Associated with Benefits of of RACT II in Illinois 169 Illinois Counties: Ozone Standard Attainment Status 214 Gross National Product Implicit Price Deflator 218 Xlll EXECUTIVE SUMMARY Background of RACT II Like many other states, Illinois contains areas that do not meet the federal standard for ozone. One of the steps required by federal law to achieve compliance is that exist- ing stationary sources in nonattainment areas of the state adopt reasonably available control technology (RACT). An earlier set of guidelines known as RACT I which was adopted by the state in 1979 specifies reasonably available control technologies for several categories of emissions of volatile organic materials. Amendments concerning addi- tional sources, referred to as RACT II, have been proposed by the Illinois Environmental Protection Agency. The pre- sent document is the economic impact statement prepared in connection with the proposal to adopt RACT II in Illinois. The following categories of emissions of volatile organic materials are covered in the proposed RACT II Regu- lations: Rotogravure and Flexography Petroleum Refining Leaks XIV Surface Coating o: Metal Products Storage Tanks with Floating Covers Synthesized Pharmaceuticals Perchloroethylene Dry Cleaning Pneumatic Rubber Tire Making The emissions of volatile organic materials to be cont- rolled are found in fumes from materials used in the manu- facturing processes as well as in fumes from liquid pro- ducts. The control technologies available for the categories include carbon adsorption, incineration, the use of devices specific to the various industrial processes, changing to industrial materials with reduced organic com- pound content, and adoption of programs of inspection, moni- toring and maintenance of equipment. ^ffn Air Quality Impacts of RACT II It was estimated in this study that RACT II would / reduce emissions of volatile organic materials in the state in 1982 by 12.5 percent below levels that would otherwise occur. ' i '■"-■-/ Air quality effects of the emissions reductions were i estimated using air quality modeling to predict second highf' ly'h :-//^j XV est one-hour yearly readings. The federal standard stipu- lates that an hourly ozone concentration of .12 parts per million not be exceeded more than once per year, implying that the second highest one-hour reading in a year deter- mines whether an area is in attainment. The air quality modeling results indicate that the metropolitan areas of Chicago and the part of the St. Louis area which is in Illi- nois would remain out of attainment of the federal standard in the absence of RACT II, in spite of reductions in emis- sions due to the federal motor vehicle standards and RACT I. However, the Peoria area and a group of 10 other counties designated as being out of attainment in 1979 were projected to come into attainment by 1982 without RACT II. The reductions in second highest one-hour ozone level due to RACT II were projected to be 12.2 percent for Chicago area and 14.7 percent for the St. Louis area, but these reductions are still not sufficient to bring them into attainment. The reductions outside these areas, ranging from 1.9 to 5.8 percent, do not affect attainment status since all the other areas are projected to be in attainment in 1982 even without RACT II. XVI Costs of RACT II Direct and indirect effects of RACT II were estimated in this study. Direct costs are incurred by firms required to use pollution control technologies and include the pur- chase, operation and maintenance of control equipment and higher costs paid for compliance materials. Also included are possible savings from the reuse of captured organic materials or energy. For each of the categories covered by RACT II, informa- tion was obtained for affected plants, processes, employment and other variables. Effects on emissions and costs of applicable control technologies were estimated using infor- mation from U.S. EPA, Illinois EPA, industry associations, solvent and equipment suppliers, and individual firms. Table I gives a summary of annual control costs and emission reductions by industry for attainment and nonat- tainment areas of the state. Total annual costs are $38.3 million, and er^ission reductions are 91.8 thousand tons per year. All costs are expressed in 1980 dollars. A sensitiv- ity analysis of the cost estimates indicated a range of annual costs of $22.6 to $60.2 million. Indirect effects arise from induced impacts on the Illinois economy beyond the directly affected firms. Exam- ples of indirect effects include higher prices, increases in xvii TABLE I TOTAL ANNUAL COSTS AND EMISSION REDUCTIONS EXPECTED FROM IMPLEMENTATION OF RACT II IN ILLINOIS Annual Cost Emission Reduction (Million $) (Thousand tons/year Non- Non- RACT II Category Attainment Attainment Attainment Attainme Rotogravure and Flexography 1.3 1.0 4.5 14.9 Petroleum Refining 0.0 0.0 9.3 21.7 Leaks Surface Coating of Metal Products 9.0 23.9 8.7 Storage Tanks with Floating Covers 0.0 0.0 3.7 Synthesized Pharma- ceuticals ~ 2.4 Perchloroethylene Dry Cleaners 0.1 0.1 0.5 Pneumatic Rubber Tire Making 0.5 - 1«5 State of Illinois ■ 10.9 27.4 28.2 63. ( Sources; Tables 3.5, 3.8, 3.12, 3.15, 3.19, 3.22 and 3.26 XVlll unemployment and increases in the cost of government ser- vices to those remaining in Illinois. The Illinois input- output model was used in developing estimates of the indi- rect effects. The estimated price rises resulting from RACT II range from zero in the petroleum industry to .2 of 1 percent in rotogravure and flexography. The most likely estimate of increased costs of unemployment and providing government services is $1.2 million, with a low value of $42 thousand and a high value of $2.4 million. Benefits of RACT II The effects of ozone on health, vegetation and materi- als were evaluated, and estimates of the beneficial effects of reduced ozone resulting from RACT II were developed. In addition, monetary values associated with these beneficial effects were considered. Toxicological , clinical and epidemiological evidence of effects of ozone on human health was reviewed. Ozone induced changes in host defense mechanisms, pulmonary and extrapulmonary functions, and lungs and other organs were indicated for ozone levels ranging from .50 to .10 parts per million. Other effects include irritation of eye, nose, XIX throat and mucous membranes, coughing, chest discomfort and headache. No verifiable relationship has been found between ozone and mortality rates. A study of self -reported symptoms related to ozone con- centrations (Hammer et al., 1974) was used to estimate the number of symptom days of chest discomfort, cough, eye dis- comfort and headaches related to reductions of ozone from RACT II. The threshold levels for chest discomfort and cough, .30 and .27 parts per million, were higher than Illi- nois ozone levels. However, the analysis resulted in an estimated reduction in person-days of eye discomfort of 146.3 thousand and a reduction in person-days of headache of 116.2 thousand from RACT II in Illinois. Almost all of these effects occurred in nonattainment areas of the state. A dose response function developed by Gillette (1974), which has a threshold of .05 parts per million and which incorporates scientific opinions of the extent and severity of several health symptoms related to ozone exposure, was used to estimate a monetary value associated with health effects. The monetary value was estimated to be $.7 million per year. To allow for the possibility of a mortality effect, a less likely estimate of health effects was developed allow- ing for a saving of 4 lives per year. The monetary value associated with the health effects would then be increased to $5.5 million per year. XX Ozone has been observed to affect the metabolism and photosynthet ic rate of many types of vegetation, and sus- tained exposure can cause reductions in plant growth, yield and quality. In the absence of adequate data to develop dose response relationships between ozone and crop damage, estimates of total economic crop loss from ozone exposure in other parts of the country were used. Based on a propor- tional relationship between ambient ozone concentrations and total crop damages per farm resident, an estimate of reduc- tion in crop loss of $1.4 million from RACT II in Illinois was obtained. Ozone causes damage to many types of organic materials. The rigidity of elastomers is increased, causing brittleness and cracking and necessitating the use of antiozone addi- tives. Ozone causes fading and weakening of textiles, and advances the erosion of paint surfaces. Nonlinear dose res- ponse functions relating material damage to annual average ozone levels for each of these materials were used in esti- mating the reductions in materials damages from RACT II. The estimate of the reduction in damage to materials was $2.8 million per year. The sum of the most likely estimates of monetary values associated with the health, vegetation and materials effects of RACT II was found to be $4.9 million per year. A less likely high estimate, influenced primarily by the possibil- XXI ity of a mortality effect, was found to be $11.5 million per year . xxii 1. INTRODUCTION 1 . 1 Background of Proposed RACT II Regulations Like many other states, Illinois contains areas where concentrations of ozone are greater than permissible accord- ing to national standards. For these states, federal law requires that steps be taken to achieve compliance. One of the steps required is that existing stationary sources in nonatta inment areas of the state adopt reasonably available control technology (RACT). The U.S. Environmental Protection Agency has from time to time issued guidelines describing reasonably available control technologies. Because of findings indicating that organic compounds in the air contribute to formation of ozone, some of the guidelines have concerned volatile organic materic_''s (VOM) . An earlier set of guidelines was adopted by the State of Illinois in 1979 and remains in effect. These guide- lines, known as RACT I, specify reasonably available control technologies for several categories of VOM emission sources. Over and above the RACT I guidelines, additional federal guidelines for VOM emission sources have been issued. While not yet adopnec, the add:iicnal ouidelines neve oeer recon-- mended for adoption in Illinois by the Illinois Environmen- tal Protection Agency. The additional guidelines for VOM sources are known as RACT II. Illinois state law requires that an economic impact statement be prepared for consideration by the Illinois Pol- lution Control Board in its deliberations on proposed regu- lations. The present document is the economic impact state- ment prepared in connection with the proposal to adopt RACT II in I llinois . 1 .2 Difference Between RACT I and RACT II The RACT I cateqories of emission sources are: Petroleum Refineries - Vacuum Producing Systems - Oil/Water Separators - Process Unit Turnarounds Surface Coating - Large Appliances - Cans - Metal Coils - Paper - Fabric - Autos and Light Duty Trucks - Metal Furniture - Magnet Wire Insulation Fixed Roof Storage Tanks Solvent Metal Cleaning (Deareasing) Bulk Gasoline - Terminals - Plants Cutback Asphalt Services Stations, Stage I RACT II adds to the controls required under RACT I. First, RACT II would extend controls for three processes already included in RACT I. The processes already included in RACT I are in Petroleum Refining, Surface Coating of Metals, and Petroleum Storage. The RACT II controls for Petroleum Refining are aimed at reducing leaks, which are not a specific concern in RACT I. The RACT II controls for Surface Coating of Metal Products extend the processes cov- ered to metal products beyond those already covered in RACT I. The RACT II controls for Petroleum Storage pertain to tanks with floating roofs, whereas RACT I is concerned with tanks having fixed roofs. In adaici'^n, RACT II would add controls for processes in four industries not included in RACT I. The processes added by RACT II are in Graphic Arts, Pharmaceuticals, Dry Cleaning and Rubber Tire Making. 1 . 3 Descr ir.i lor. cf rhe RAC? II Reoulstior.s Altogether seven categories cf emission sources are identified in the proposed RACT II Regulations: Rotogravure and Flexography Petroleum Refining Leaks Surface Coating of Metal Products Storage Tanks with Floating Covers Synthesized Pharmaceuticals Perchloroethylene Dry Cleaning Pneumatic Rubber Tire Making The emissions to be controlled are found in fumes from materials used in the industrial processes as well as in fumes from liquid products. For Rotogravure and Flexogra- phy, Surface Coating of Metal Products, Pharmaceuticals and Rubber Tire Making, the emissions stem primarily from, indus- trial process materials. For Petroleum Refining, Storage Tanks and Dry Cleaning, the emissions stem from inadvertent leaks of vapors of contained fluids and, in the case of Dry Cleaning, disposal of waste materials. The control technologies for the seven categories are quite varied. They include carbon adsorption, incineration, the use of devices specific to the various industrial pro- cesses, changing to industrial materials with reduced organic compound content, and adoption of programs of inspection, monitoring and maintenance of equipment. 4 Tne sources of emissions to be controlled for each RACT II category, along with applicable control technologies, are presented in Table 1.1. Further details may be found in Appendix A, which reproduces in entirety the RACT II regula- tions proposed by the Illinois Environmental Protection Agency . A notable feature of the proposed RACT II regulations is that they are written to have statewide applicability. Federal law requires only that RACT be applied to nonattain- ment areas within a state. However, the Illinois EPA has stated that emissions of volatile organic materials outside of nonatta inment areas can "contribute to and often aggre- vate ozone-related problems in urban nonattainment areas" (Illinois EPA, 1980a). As a result of this concern about long range transport of ozone, the Illinois EPA has asked for controls, not only in nonattainment areas, but in all of Illinois including ozone attainment counties and counties which are unclassified due to lack of ozone monitoring data. 1 . 4 Need to Predict Effects on Ozone To find the environmental improvement that would be brought about by RACT II requires, first, estimation of the reductions that would be brought about in VOM emissions, and second, estimation of the effects of these reductions on TABLE i.l DESCRIPTION OF PROPOSED RACT II REGULATIONS Category Emission Source Control Technologies Rotogravure and Flexography Petroleum Refining Leaks Surface Coating of Metal Products Storage Tanks with Floating Covers Synthesized Pharma- ceuticals Perchloroethy- lene Dry Cleaning Pneumatic Rubber Tire Making Fumes from fluids used in printing Leaks from seals, vents, valves, drains and pipes Fumes from coatings during application and drying Leaks from floating roof s Fumes f rom, reactors , centrigues, crystal- lizers and dryers Leaks and disposal of wastes from dryers using perch- loroethylene solvent Materials used in cementing, spraying and bead preparation Carbon adsorption, fume incineration, use of inks with less VOM content Inspection, monitoring and maintenance Carbon adsorption, incineration, electro- deposition, use of coatings with less VOM content Secondary seal and inspection Carbon adsorption, condensers, scrubbers Carbon adsorption, proper operation, inspection and monitoring Carbon adsorption, incineration, use of water based sprays Source: Appendix A I ozone levels. These effects are estimated in Chapter 2 of the present report using air quality modeling. 1 . 5 Cost Considerations Costs of implementation of the proposed RACT II regula- tions in Illinois are estimated in Chapter 3. The costs of implementation include the direct costs to firms required to use the pollution control technologies. Examples of these costs are outlays for purchase, operation and maintenance of control technology, and payment for higher priced compliance materials. In some cases, the affected firms will experi- ence savings from the reuse of captured solvents and petro- leum. In addition to direct effects, the effects of implemen- tation include indirect effects such as changes in price, output, employment, population and energy usage. Changes in price and output in industries required to adopt controls are estimated uaking into account changes in cost and in supply and demand conditions in the industries. Additional changes in output and employment in the Illinois economy are estimated using the Illinois input-output model. Next, pro- jections of the changes in unemployment and population and and estimates of the monetary values associated with these changes are made. 1 . 6 Benefit Considerations Effects of ozone reductions determining the benefits of RACT II are estimated in Chapter 4. Three types of benefits are considered. The first is the reduction of ozone-induced symptoms and illness for people in Illinois. The second type of benefit, particularly important in agricultural regions of the state, is reduced damage to vegetation. The third type of benefit is the reduction in damage to materi- als sensitive to ozone, including elastomers, textiles and paints . In each case, the physical effects of ozone are consid- ered. To obtain monetary values associated with these effects, relationships specifying dollar amounts of damage reduction per person resulting from a one part per million reduction in ozone are used. For example, a reduction in ozone will cause less wear to fibers, rubber products and paints, thereby reducing replacement costs and ozone-preven- tive measures. The per person damage reductions are related to affected populations in Illinois to estimate total mone- tary values associated with the physical effects. Finally, in Chapter 5, the major conclusions on air quality impacts, costs and beneficial effects of RACT II in Illinois are brought together. 2. AIR QUALITY IMPACTS OF RACT II This chapter is concerned with how the reductions in volatile organic materials (VOM) emissions resulting from the proposed RACT II regulations would affect ozone levels. To provide background information, data on recent ozone levels are presented in Section 2.1, based on monitoring data for the 22 counties in Illinois which have operating ozone monitors. In Section 2.2, the precursor relationship between volatile organic materials (VOM) and ozone formation is described. Section 2.3 presents estimates of VOM emis- sions for major urban areas and the rest of Illinois. Sec- tion 2.3 also provides estimates, needed in the rest of the chapter, of emission reductions that would result from implementation of RACT II. In Section 2.4 the estimates of emission reductions are used as inputs into air quality models to predict effects of RACT II on ozone levels. Several types of air quality models available for predicting the effects of VOM emissions on ozone are evaluated. Then results are presented of applying the Empirical Kinetic Modeling Approach (EKMA) to the three major nonattainment urban areas in Illinois which are Chicago, St. Louis and Peoria. Finally, results are presented of applying a rollback model to remaining areas of the state. 2.1 Recent Ozone Levels Illinois EPA currently monitors ozone levels in 22 Illinois counties. Two types of continuous sampling ozone monitors are operated by Illinois EPA. An ultra-violet absorption monitor draws in ambient air and measures the decrease in transmi ttance resulting from the absorption of ultra-violet light by ozone molecules. A chemi luminescent monitor mixes ethylene gas with ambient air and measures the intensity of light given off in the chemical reaction. The majority of ozone monitors (36 of 43 in 1979) had over 75 percent data collection during the peak ozone season of May through September (Illinois EPA, 1980b). Table 2.1 gives ozone monitoring data from all the available monitors for 1977, 1978 and 1979. These values along with other data were used by Illinois EPA as part of the requirements of Section 107(d)(1) of the Clean Air Act (Illinois EPA, 1980c) in designating counties as attainment, nonattainment or unclassified with respect to the National Ambient Air Quality Standard for ozone. To make the designations, the number of days with one- hour average ozone levels above the federal standard (.12 10 TABLE 2.1 SECOND HIGHEST ONE-HOUR CONCENTRATIONS OF OZONE (parts per million) (a) (b) (c) Station 1977 1978 1979 ADAMS COUNTY Quincy .129 .105 .089 CHAMPAIGN COUNTY Champaign .103 .092 .081 COOK COUNTY Arlington Heights Bedford Park Calumet City Chicago Heights Evanston Hillside North Riverside Skokie Chicago: Austin West K.S. Cermak Pump Sta. Edgewater Kenwood H.S. La Salle St. Limblom h.C. Medical Center Northwestern Univ. Roseland Pump Sta. Stevenson Taft H.S. CRAWFORD COUNTY Robinson NA .112 .094 (Table continued on following page) 11 159 .123 .088 120 .120 .090 148 .133 .125 129 .098 .120 079 .208 .143 138 .145 NA NA NA .105 185 .205 .141 088 .107 .082 072 .088 .093 141 .133 .072 207 .148 .115 128 .049 NA 122 .090 .093 147 .119 NA NA .132 .110 NA .147 .102 105 NA NA NA .144 .108 TABLE 2.1 (Continued) SECOND HIGHEST ONE-HOUR CONCENTRATIONS OF OZONE (parts per million) (a) (b) (c) Station 1977 1978 1979 DE KALB COUNTY DeKalb DU PAGE COUNTY Wheaton KANE COUNTY Elgin KANKAKEE COUNTY Kankakee LAKE COUNTY Deerf ield Libertyville Waukegan LA SALLE COUNTY La Salle MACON COUNTY Decatur MACOUPIN COUNTY Ni Iwood MADISON COUNTY Alton Edwardsville Wood River Maryville (Table continued on following page) 12 159 .099 NA 130 .101 .085 NA NA .130 145 .095 .083 NA NA .143 NA .231 .122 261 .166 .158 129 .113 .107 119 .112 .087 NA NA .116 159 .173 .134 NA .164 .121 186 .180 .121 NA NA .119 TABLE 2.1 (Continued) SECOND HIGHEST ONE-HOUR CONCENTRATIONS OF OZONE (parts per million) Station (a) 1977 (b) 1978 (c) 1979 Mchenry county McHenry MONROE COUNTY Waterloo PEORIA COUNTY Peoria Peoria Heights ROCK ISLAND COUNTY Moline PEORIA COUNTY Peoria Peoria Heights ROCK ISLAND COUNTY Moline SANGAMON COUNTY Springfield (224 W. Adams) Spr ingf ieid (Fairgrounds ) ST. CLAIR COUNTY Cahokia Mounds Cahokia East St. Louis NA NA .079 NA NA .088 126 .116 .091 NA NA .107 116 126 NA 116 113 116 NA 113 .077 .091 .107 .077 134 .112 NA NA .129 .087 136 .131 NA NA .084 NA 130 .157 .099 (Table continued on following page) 13 TABLE 2.1 (Continued) SECOND HIGHEST ONE-HOUR CONCENTRATIONS OF OZONE (parts per million) Station (a) 1977 (b) 1978 (c) 1979 WILL COUNTY Braidwood Joliet South Lockport WILLIAMSON COUNTY Marion WINNEBAGO COUNTY Rockf ord (1528 18th Ave. ) Rockf ord (1405 Maple) NA NA .105 143 .116 NA NA NA .103 .150 .113 NA 120 117 NA .117 .084 .083 Sources: (a) Illinois EPA, State Implementation Plan for Air Pollution Control, Volume 5; Oxidants, Springfield, Illinois, April 1979b. (b) Illinois EPA, Annual Air Quality Report; 1978, Division of Air Pollution Control, Ambient Air Monitoring Sec- tion, Springfield, Illinois, June 1979a. (c) Illinois EPA, Annual Air Quality Report; 1979, Division of Air Pollution Control, Ambient Air Monitoring Sec- tion, Springfield, Illinois, June 1980b. 14 parts per million) was observed for each available site for the three year period 1977 to 1979. If two such violations occurred in one year, the county was designated nonattain- ment. If none of the three years experienced two or more violations of the federal standard, the county was classi- fied as being in attainment. Counties without sufficient monitor data have been designated as unclassified. There are currently 78 unclassified counties, 20 nonattainment counties and 4 attainment counties. Illinois EPA considers unclassified counties to be in attainment of ozone stan- dards, except for special cases such as Grundy, Kane and Kendall counties which were designated as nonattainment since they are located between nonattainment counties in and near the Chicago Metropolitan area (Illinois EPA, 1979b). The designation of each of the counties of Illinois as being either attainment or nonattainment is given in Appendix Table B.l. 2 . 2 VOM Emissions as a Precursor to Ozone Ambient air concentrations of ozone and other photo- chemical oxidants are directly related to the presence of organic precursors in the atmosphere. These compounds, referred to as volatile organic materials (VOM), consist of hydrocarbons from automobile exhaust and fuel evaporation, 15 oxygenated hydrocarbons and halocaroons emitted frorr. manu- facturing processes, other organic miaterials emitted from commercial and industrial processes, and natural organic emissions from vegetation (U.S. EPA, 1978a). Natural meth- ane emissions from vegetation are significant in rural areas, though methane has low reactivity in the atmosphere. Automobile emissions, on the other hand, play an important role in the formation of ozone in and around urban areas. Automobile emissions and natural methane would not be affected by RACT II but are determinants of the levels of ozone to which the RACT II reductions would be applied. Table 2.2 provides a list of hydrocarbon compounds which have been identified in the atmosphere by the U.S. EPA. The list is considered "far from complete because of the analytical problems created by the enormous complexity of the ambient organic mixtures and the trace concentrations of the various components" (U.S. EPA, 1978a). These com- pounds range from low to high oxidant-related reactivity in the atmosphere. The compounds methane and ethane, which exhibit low reactivity in the atmostphere, are specifically exempted from the proposed RACT II regulations. In addition to hydrocarbon compounds the ambient con- centrations of inorganic pollutants such as nitrogen oxides (NOx), the amount of ultra-violet light and meteorological conditions play a role in the formation of atmospheric 16 TABLE 2.2 HYDROCARBONS IDENTIFIED IN AMBIENT AIR Carbon Number Compound Carbon Number Compound Methane Ethane Ethylene Acetylene Propane Propylene Propadiene Methylacetylene Butane I sobutane 1-Butene c i s-2-Butene trans-2-Butene I sobutene Pentane I sopentane 1-Pentene c is-2-Pentene trans-2-Pentene 2-methyl-l-Butene 2-methyl-2-Butene 3-Tnethyl-l-Butene 2 -me thy 1-1 , 3 -Buta- diene Cyclopentane Cyclopentene 10 Hexane 2-Methylpentane 3-Methylpentane 2 , 2-Dimethylbutane 2 , 3-Dimethylbutane ci s-2-Hexane trans-2-Hexane cis-3-Hexane trans-3-Hexane 2-methyl-l-Pentene 4-methyl-l-Pentene 4-methyl-2-Pentene Benzene Cyclohexane Methylcyclopentane 2-Methylhexane 2, 4-Di methyl pentane Toluene 2, 2, 4-Tri methyl pentane o-Xylene m-Xylene p-Xylene m-Ethyltoluene p-Ethyltoluene 1,2, 4-Tri methyl benzene 1, 3, 5-Tri methyl benzene sec-Butylbenzene Source: U.S. EPA, Air Quality Criteria for Ozone and Other Photochemical Oxidants, EPA-600/8-78-004 , Research Trian- gle Park, N.C., April 197Ra. 17 ozone. In a series of chemical reactions, nitrogen dioxide (N02) and ultra-violet sunlight react to form nitric oxide (NO) and an oxygen atom (0), which reacts with 02 to form ozone (03). Hydrocarbon molecules interfere with the subse- quent combination of 03 and NO to form N02 and 02, and a surplus of ozone results. Atmospheric mixing, wind speed, intensity and spectral distribution of sunlight, temperature and relative humidity affect both the physical accumulation and dispersion of ozone precursors and the chemical process of pollutant reactions. 2 . 3 Effect of RACT II on Emissions As indicated in Section 2.2, VOM emissions contribute to the formation of ozone and other photochemical oxidants in the atmosphere. The first column of Table 2.3 gives pro- jections of what VOM emissions would be without controls, as reported in the Illinois State Implementation Plan (Illinois EPA, 1979b) . Figures are given for the three major urban nonattainment areas of Chicago, St. Louis and Peoria, as well as for the urban areas of Rockford and Rock Island which are in attainment. Figures are given also for the rest- of the state, which contains both attainment and nonat- tainment counties. 18 TABLE 2.3 EFFECT OF RACT ON EMISSIONS OF VOLATILE ORGANIC MATERIALS (a) (d) 1982 Emissions (b) (c) RACT II Without RACT I RACT II Additional RACT Reductions Reductions Reductions (Tons/year) (Tons/year) (Tons/year) (Percent) Chicago (e) 453,658 St. Louis (f) 79,031 Peoria (g) Rockford (h) 27,595 11,574 Rock Island (i) 13,967 62,802 15,653 7,916 885 1,902 43,697 17,222 1,035 970 551 11.2 27.2 5.3 9.1 4.6 Rest of State 290,323 52,230 28,343 11.9 I llinois 876,148 141,388 91,818 12.5 (Table continued on following page) 19 TABLE 2.3 (Continued) EFFECT OF RACT ON EMISSIONS OF VOLATILE ORGANIC MATERIALS Footnotes Sources: (a) Illinois EPA, State Implementation Plan for Air Pollution Control, Volume 5; Oxidants, Springfield, Illinois, April 1979b. (b) Yates, et al., "Economic Impact of Incorporating RACT I Guidelines for VOC Emissions into Illinois Air Pollution Control Regulations," Illinois Institute of Natural Resources, 1978 (R78-3 and R78-4). (c (d (e (f (g (h (i RCF estimates developed in Chapter 3. Column (c) as a percent of columns (a) minus (b) . Cook, Du Page, Kane, Lake, McHenry and Will counties. Madison and St. Clair counties. Peoria and Tazewell counties. Winnebago county. Rock Island county. 20 The estimated 1982 emissions include emissions from industrial and mobile sources. The primary data base for industrial sources is Illinois EPA's Total Air System (TAS) computer file which is derived from source permits. Indus- trial emission estimates were supplemented with trade asso- ciation data, plant visits, personal communications and other information (Illinois EPA, 1979b). Mobile and small commercial and industrial source emissions were estimated in area source emission studies contracted by Illinois EPA. The VOM emission estimates in some cases depend on sampling and questionnaire data going back as far as 1975. The second and third columns of Table 2.3 show expected emission reductions from RACT I and RACT II. The RACT II emission reductions are summarized from the RCF estimates presented in Chapter 3. The fourth column, the percent emission reduction expected from RACT II controls, is based on the ratio of RACT II reductions to the 1982 VOM emissions after RACT I reductions. 2 . 4 Air Quality Modeling The objective of this section is to relate the reduc- tions in VOM emissions from implementation of RACT II in Illinois to reduced levels of ambient ozone concentration. Section 2.4.1 evaluates several types of air quality models 21 currently available for aeterminina rhe ozone reauctior froir. RACT II. Sections 2.4.2 and 2.4.3 present results for two of these models, EKMA as applied to major urban areas and rollback as applied to the rest of the state. 2.4.1 Available Air Quality Models Several types of air quality models exist that relate hydrocarbon emissions to photochemical oxidant pollution levels. The four types of models considered acceptable by the U.S. EPA for developing VOM emissions control require- ments in State Implementation Plans are: photochemical dis- persion models, the empirical kinetic modeling approach (EKMA), proportional or rollback models, and statistical models (Illinois EPA, 1979b). The descriptions of these models used here rely heavily on U.S. EPA's Uses, Limita - tions and Technical Basis of Procedures for Quantifying Relationships Between Photochemical Oxidants and Precursors (U.S. EPA, 1977). 2.4.1.1 Photochemical Dispersion Models The two major types of photochemical dispersion models are Eulerian and Lagrangian. Lagrangian models estimate the concentration of ozone and other chemical compounds within a specified parcel of air as it moves through the atmosphere and is impacted by subsequent emissions and meteorological conditions. Eulerian models calculate concentrations at 22 fixed locations in space for specified time periods. Both types of dispersion models simulate a wide range of chemical and physical conditions including the transformation of pri- mary species such as nonmethane hydrocarbons into secondary species such as ozone, allowing for the effects of meteoro- logical, atmospheric and transport conditions. Eulerian and to some extent Lagrangian photochemical dispersion models have several advantages when compared with less sophisticated models. Questions involving spatial resolution, for example whether control of equal amounts of pollutants from different sources will be equally benefi- cial, can be addressed. The models allow flexibility in estimating the benefits of precursor controls and permit the evaluation of control strategies involving a variety of source categories which exhibit various emissions patterns. There are, however, several major disadvantages in the application of photochemical dispersion models. Extensive meteorological, source emission and ambient monitoring data must be obtaip*='d, and the computational costs can be prohi- bitive. The more complex models often result in only slight improvements over less data-intensive approaches, particu- larly with regard to transport simulation. Furthermore, the photochemical dispersion models currently available have not yet been adequately verified. Examples of photochemical dispersion models include the SAI grid model (Systems Appli- 23 cations Incorporated), the LIRAQ mode]. (Lawrence Livermore Laboratory) and the DIFKIN model (General Research Corpora- tion) . 2.4.1.2 Empirical Kinetic Modeling Approach The empirical kinetic modeling approach (EKMA) is less data intensive than the photochemical dispersion models. EKMA is recommended by U.S. EPA for use by the states in modeling ozone in metropolitan areas (Gipson, 1980). It utilizes a set of computer generated ozone isopleths, which depict concentrations of ozone downwind from a city as a function of nonmethane hydrocarbon and nitrogen oxide (NOx) ambient concentrations, source emissions, meteorological conditions, reactivity of the precursor mix and concentra- tions of ozone and precursors transported from upwind areas . The physical model underlying EKMA is similar to the Lagrangian photochemical dispersion model. The relation- ships among ozone and its precursors are based upon the application of a chemical kinetics model. The modeling approach is capable of estimating the sensitivity of maximum hourly concentrations to changes in emissions from a variety of sources. The ozone isopleths can be generated from standard assumptions of sunlight intensity and duration, atmospheric dilution rates, precursor emission reactivity and daily 24 emission patterns or, with specific meteorological, trans- port and emissions data for selected high-ozone days, on a city-specific basis. For diverse study areas, city-specific ozone isopleths can be used for urban areas and a standard set of ozone isopleths (incorporating fixed assumptions of atmospheric reactivity and emissions patterns) can be used for nonurban areas where less data are available. The application of both standard and city-specific isopleths is described in Uses, Limitations and Technical Basis of Proce - dures for Quantifying Relationships Between Photochemical Oxidants and Precursors and supporting documentation (U.S. EPA, 1977 and U.S. EPA, 1978J). The results of city-spe- cific EKMA analysis for urban areas in Illinois are described in Section 2.4.2 below. 2.4.1.3 Rollback Model In rollback models, ambient pollutant concentrations are predicted to vary proportionally with changes in emis- sions. With regard to RACT II regulations, this model implies that ozone concentrations are proportional to organic compound emissions. Rollback models require less emissions and meteorological data than EKMA, photochemical dispersion models or statistical models and are therefore better suited for modeling ozone changes in rural areas. Several features of the rollback model warrant discus- sion. First, the model is difficult to validate experimen- 25 tally unless an adequate sample of source emission reduc- tions can be related to changes in ozone levels. Second, proportionality between ozone and rates of organic emissions is not supported strictly by scientific evidence (U.S. EPA, 1978a). Last, the effects of NOx emissions are not allowed for explicitly. Despite these limitations, rollback models have computational advantages and can be used over wide geo- graphical areas for which data are lacking to implement the more refined models. The results of applying a rollback model to the nonurban areas in Illinois are presented in Section 2.4.3. 2.4.1.4 Statistical Models The last type of model considered is based on statisti- cal analysis. Among the models within this type are rela- tively simple regression equations, empirically derived envelope curves for individual cities, stochastic models, and more complex multiple regression systems, which define associations among ambient ozone, meteorological conditions and emission rates. Statistical models often produce usable results where other modeling efforts have failed, and they also allow sensitivity testing of the predicted relations based on estimates of the standard errors. Several drawbacks, however, preclude the use of statis- tical models in this study. As with rollback, these models do not take account of specific pollutant reactions in the 26 atmosphere. In addition, they are developed for specific sites and have only limited applicability to other sites (U.S. EPA, 1978a). 2.4.2 Results for Three Major Urban Areas The EKMA model described in Section 2.4.1.2 was used to predict changes in ambient ozone concentrations from RACT II in the three major urban areas in Illinois which are in non- attainment. The results of the EKMA analysis are presented in this section for the urban areas of Chicago (Cook, Du Page, Kane, Lake, McHenry and Will counties), Peoria (Peoria and Tazewell counties), and St. Louis (Madison and St. Clair counties ) . The EKMA results are based on computer generated ozone isopleths developed by Illinois EPA for these urban areas. As noted in Section 2.4.1.2, ozone isopleths refer to curves which depict ozone levels as a function of two pollutants related to ozone, nonmethane hydrocarbons and nitrogen oxides. The city-specific ozone isopleth diagrams, devel- oped by Illinois EPA as part of the determination of control requirements for the National Ambient Air Quality Standard for ozone (Illinois EPA, 1979b), are based on meteorological and emissions data for selected modeling days. Several days with high ozone concentrations were modeled. An ozone design value was estimated by Illinois EPA for each modeling day. The ozone design value is defined as the 27 current maximurr (2nd highest) one-hour ozone concentration indicated at given monitoring sites. Illinois EPA used a tabular procedure, recommended by U.S. EPA, to select design values from monitor data for the period 1976 to 1978. The ozone isopleth curves were estimated by Illinois EPA after selecting the specific modeling days and ozone design values, and using information on light intensity, rate of atmospheric dilution, relative rate of emissions, and background and transport (upwind) concentrations. These data were used as inputs to the Ozone Plotting Package Com- puter Program, which is described in the U.S. EPA user's manual (Whitten, 1978) to obtain the isopleth. These iso- pleths were used by RCF to ascertain the change in ozone level implied by the reductions in VOM emissions in each of the three areas. The resulting p'-edictions of reductions in ozone levels are 12.2 percent for the Chicago area, 14.7 percent for the St. Louis area and 2.9 percent for the Peoria area. These percentage reductions are entered in the second column of Table 2.4 for the three areas. The reductions are applied to the projected ozone concentrations shown in the first column of the table to arrive at the reductions in ozone concentrations due to RACT II shown in the final column. The projected ozone concentrations in the first column are concentrations after allowing for RACT I and the federal 28 TABLE 2.4 SECOND HIGHEST ONE-HOUR OZONE LEVELS BEFORE AND AFTER IMPLEMENTATION OF RACT II IN ILLINOIS (a) (c) Projected Reduction 1982 Ozone (b) in Ozone Concentrations Ozone Concentration Area Without RACT II Reduction From RACT II (Parts per From RACT II (Parts per million) (Percent) million) Nonattainment Chicago (d) .180 12.2 .023 St. Louis (e) .150 14.7 .022 Peoria (f) .104 2.9 .003 Rest of State in Nonattainment (g) .117 5.8 .007 Attainment Areas Rockford (h) .100 3.6 .004 Rock Island (i) .101 1.9 .002 Rest of State in Attainment .096 4.5 .004 (Table continued on following page) 29 TABLE 2.4 (Continued) SECOND HIGHEST ONE-HOUR OZONE LEVELS BEFORE AND AFTER IMPLEMENTATION OF RACT II IN ILLINOIS Footnotes (a) The derivation of this column, using ozone concentra- tions from the State Implementation Plan and air quality modeling, is described in the text. (b) The entries in this column are the calculated percentage reductions in ozone for each area given in the text. (c) This column is column (a) times column (b) divided by 100. (d) Cook, Du Page, Kane, Lake, McHenry and Will counties. (e) Madison and St. Clair counties. (f) Peoria and Tazewell counties. (g) Adams, Boone, De Kalb, Grundy, Kankakee, Kendall, La Salle, Monroe, Sangamon, Williamson counties. (h) Winnebago county. (i) Rock Island county. 30 motor vehicle control program. To calculate the concentra- tions given in the first column, estimated 1977 VOM emis- sions and projected 1982 VOM emissions allowing for growth and for imposition of federal motor vehicle controls were first obtained for each area from the Illinois State Imple- mentation Plan (Illinois EPA, 1979b). Using these figures, a projected percentage change in emissions from 1977 to 1982 was calculated for each area, which was in turn used to estimate the percentage change in ozone by applying EKMA for the Chicago, St. Louis and Peoria areas and rollback for the remaining areas of the state. The ozone concentrations given in the first column of Table 2.4 were calculated by applying these percentage changes to 1977 second highest hourly ozone readings given in the Illinois State Implemen- tation Plan. 2.4.3 Results for Remaining Areas The reductions in ozone for the rest of the state, out- side of the Chicago, Peoria and St. Louis urban areas, were estimated using a rollback model. The specific form of rollback model used was based on the U.S. EPA's criteria document for ozone (See p. 92, U.S. EPA, 1978a). According to the model, the concentration of ozone equals the amount of background ozone plus the VOM emissions rate times a pro- portionality factor: L = B + kE (2.1) 31 where L = ozone concentration in parts per million B = background ozone concentration in parts per million k = proportionality factor E = VOM emission rate in tons per year By subtracting B from both sides, another way of stating the model is obtained, namely, that the excess of ozone over the background level, L-B, is proportional to VOM emissions. Letting the superscript 1 refer to the situation after imposing RACT II controls and refer to the situation before imposing the controls, the percentage reduction in ozone level is: * (L^-LM/L» = [(E^-E°)/E°] [(L»-B)/L"] (2.2) which indicates that the percentage reduction in ozone level is equal to the percentage reduction in VOM emissions (E^-EM/E" times the ratio of the excess of ozone level over the background level to the ozone level before imposition of controls (L''-B)/L''. The formula for the percentage reduc- tion in ozone given by equation (2.2) is obtained by sub- tracting the values for the rollback relation (2.1) for the before situation from values for the after situation, divid- 32 ing both sides of the result by L", multiplying the right side by {L''-B)/kE'' which equals one from equation (2.1), and then cancelling k's. The percent reductions in VOM emissions (E^-EM/E" needed to apply the formula are obtained from Table 2.3 in Section 2.3 and are 9.1 percent for Rockford, 4.6 percent for Rock Island and 11.9 percent for the rest of the state. For this analysis, the 11.9 percent is taken to be applica- ble to the rest of the state in attainment, as well as the rest of the state in nonattainment . The ozone levels before imposition of RACT II controls, L' , needed in equation (2.2) are the projected second high- est readings for Rockford, Rock Island and the rest of the state in attainment and nonattainment as reported in the first column of Table 2.4. The background level of ozone B needed in equation (2.2) was estimated to be .07 in each case. While direct measurements of background level B are not available, all the background levels for those areas modeled by EKMA are approximately .07 parts per million (Illinois EPA, 1979b), suggesting that this value of B is reasonable for Illinois. Possible long range transport effects due to RACT II ozone reductions in other counties did not appear great enough, in view of the results in the final column of Table 2.4, to warrant adjustment of the background level for long range 33 transport effects of RACT II. The ozone reductions shown in the final column of Table 2.4 would have to be reduced for dispersion if used as a basis for transport effects to other counties, with the result that the estimate of the back- ground level of .07 parts per million in any receiving county apparently would not be affected importantly. The results from inserting the values just described into equation (2.2) are predicted reductions in ozone due to RACT II of 3.6 percent for the Rockford area, 1.9 percent for the Rock Island area and 5.8 percent for the rest of the state in nonattainment and 4.5 percent for the rest of the state in attainment. These are shown as the percentage reductions for these areas in the second column of Table 2.4. The reductions are applied to projected ozone concen- trations before RACT II shown in the first column, in order to arrive at the reduction in concentrations due to RACT II shown in the final column. 2 . 5 Summary Based on readings from 43 ozone monitors in 22 of the counties of Illinois, counties have been designated by the Illinois EPA as being in nonattainment, attainment or unclassified with respect to the federal ozone standard. The standard specifies that an average hourly concentration of .12 parts per million not be exceeded more than once per year. The Chicago, St. Louis and Peoria areas have been 34 designated as oeinq m nona t ta inmen:: . Ten counr. les outside these major areas have been designated as being in nonat- tainment. The Rockford and Rock Island areas and the remaining counties of the state are considered to be in attainment by Illinois EPA, since most unclassified counties are allowed to be considered in attainment. Without RACT II, emissions of volatile organic materi- als (VOM) in 1982 will be affected by growth, federal motor vehicle controls and RACT I. Estimates were presented in uhis chapter indicating that RACT II would reduce VOM emis- sions in the state by 91.8 thousand tons per year. Emis- sions would be reduced 12.5 percent below those projected to occur in 1982 in the absence of RACT II. The projected changes in ozone concentrations from RACT II in Illinois were presented in the third column of Table 2.4. These changes were estimated after accounting for reductions in ozone from the federal motor vehicle control program and from RACT I . As can be seen from Table 2.4, the attainment designa- tion with regard to the federal ozone standard of .12 parts per million is not affected by the RACT II ozone reductions in any of the areas listed in Table 2.4. The Peoria area and the rest of state area in nonatta inment , designated as being in nonatta inment according to 1977-1979 data, are pro- jected to come into attainment by 1982 due to ozone reduc- 35 tions from the federal motor vehicle control proqrarr and from RACT I, as shown in column one of Table 2.4. The Chi- cago and St. Louis areas are projected to remain in nonat- tainment without RACT II, and the ozone reductions due to RACT II are not great enough to bring these two areas into attainment . The projected ozone reductions due to RACT II shown in Table 2.4 are used in Chapter 4 to determ.ine the potential benefits from reduced damage to human health, vegetation and materials in Illinois. 36 3. COSTS OF RACT II The estimated costs of implementing RACT II controls in Illinois consist of the direct costs of controls, considered in Section 3.1, and the indirect costs, considered in Sec- tion 3.2. 3.1 Direct Costs of RACT II The estimated direct costs of compliance with the RACT II requirements are presented in this section. The esti- mates are based on U.S. and Illinois EPA studies, and are supplemented by information from individual firms, indus- trial associations, solvent suppliers and control equipment manufacturers . Costs are expressed in 1980 dollars. The capital cost estimates include the cost of installed equipment, engineer- ing design, materials and construction. Annual costs include capital charges, operation, maintenance and solvent and energy credits. An annual capital charge rate of 17.5 percent is used to obtain the annual capital cost of pollu- tion control equipment. The derivation of the annual capi- tal cost, which incorporates interest, depreciation, invest- 37 ment tax credits, corporate and property taxes and other factors, is discussed in Appendix C.2, Capital Charges. 3.1.1 Rotogravure and Flexoqraphy Rotogravure and flexographic printing are the two graphic arts processes affected by the RACT II regulations. Flexography requires very fluid inks which dry by solvent absorption and evaporation. Rotogravure also uses fluid inks, and the solvent content is evaporated in low tempera- ture dryers. The rotogravure printing process is used for packaging, specialties and publications. The publication printing is generally done in larger plants (U.S. EPA, 1978e). The major sources of VOM emissions from rotogravure and flexographic printing are the printing units and the dryers. Emissions can be reduced by add-on control devices and by the use of water-borne or low solvent inks. However, these ■ compliance inks have limitations depending on the stock of paper used. Fume incinerators and carbon adsorbers are effective in controlling vapors from rotogravure and flexo- graphic printing (U.S. EPA, 1978e). Table 3.1 summarizes the applicable control technologies and their estimated ef f ic ienc ies . The Illinois EPA used several sources in compiling a list of firms affected by the RACT II rules for Rotogravure and Flexographic publications and package printing, includ- 38 TABLE 3.1 CONTROL TECHNOLOGY PERCENTAGE EMISSION REDUCTIONS FOR ROTOGRAVURE AND FLEXOGRAPHIC PRINTING Percentage Emission Reduction Control Rotogravure Rotogravure Technology Package Publication Flexography Carbon Adsorption - 75 Incineration 65 - Water-Borne Inks 65 - 60 Source: U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Existing Stationary Sources - . Volume VIII: Graphic Arts - Rotogravure and Flexography, Research Triangle Park, N.C., December 1978e. ing the Total Air System (TAS) Computer File, the 1979 Thomas Register of American Manufacturers, the 1979 Illinois Manufacturers Directory and the Yellow Pages (Illinois EPA, 1980e). The proposed regulations would exempt printing plants with VOM emissions of 1,C00 tons or less per year. Nine firms have been identified by Illinois EPA as being affected by the proposed rules, and five of these were 39 scheduled to achieve the required reduction ir emissions after applying controls in 1980. Table 3.2 gives information on the four printing plants identified as being subject to additional controls. The table shows the company name, printing process used, Stan- dard Industrial Classification (SIC) code, location by county and estimated employment. Lustour Corporation is the only affected plant located in an attainment county. The cost of implementing RACT II depends on ink throughput, VOM concentration in the emissions, the type of control technology used, and other factors. Two model plants are used here, one for package rotogravure printing and one for publications rotogravure printing. The model package rotogravure plant considered by U.S. EPA has one printing operation using 2,750 tons of ink per year with 1,500 parts per million VOM concentration by volume in emissions. The applicable control technology for this plant is a thermal incinerator with 40 percent heat recovery. Carbon adsorption is not an appropriate control technology in this printing application since package roto- gravure presses often use many different inks or solvents and the recovered solvents are not easily reusable. The model plant is similar in size to the Nabisco printing oper- ation but several times smaller than Lustour 's operation. 40 TABLE 3.2 INFORMATION ON FIRMS AFFECTED BY PROPOSED RACT II REGULATIONS FOR ROTOGRAVURE PRINTING Rotogravure Firm Process SIC County Employment Package 2641 Jackson 250 Package 2652 LaSalle 280 Publ icat ion 2751 Cook 500 Publication 2751 . Cook 1,000 Lustour Corp. Nabisco , I nc . Alco-Gravure , Inc Chicago Rotoprint Sources: Illinois EPA, "Technical Support for RACT II: Graphic Arts - Rotogravure, Flexography , " Air Quality Planning Section, Springfield, Illinois, May 1980e. Manufacturers' News, Inc., Illinois Manufacturers Direc tory , Chicago, 1980. The model publications rotogravure plant has one print- ing unit using 7,720 tons of ink per year with 1,200 parts per million VOM concentration in emissions. The applicable control technology for this model plant is a carbon adsorp- tion unit. This model plant is similar in size to the Alco-Gravure printing operations but at least four times smaller than Chicago Rotoprint operations. 41 The four printing firms affected oy RACT II regulations were contacted in order to validate the cost estimates. Lustour Corporation, which operates 9 rotogravure package printing units and one flexographic unit, has provided an independent estimate of cost impacts of RACT II for their firm. Since the majority of their plant buildings have min- imal heat loss, heat recovery was not considered efficient. The two add-on technologies considered were incineration without heat recovery and carbon adsorption. The Lustour cost estimates are given in Table 3.3. The capital costs for incineration are similar to the RCF estimates based on EPA model plant costs, but annual costs are much higher due to the cost of propane to run the control system,. Lustour Corporation regards the substitution of low solvent or water-based inks as the most attractive control alternative, though the conversion of printing operations could not be achieved by 1982. Nabisco, Inc. has stated that water-based inks are not feasible for their rotogravure package printing operations. In addition, the hydrocarbon loading, the periodic stripping of the carbon bed and the use of a water-emissable solvent blend make the carbon adsorption alternative prohibitively expensive. Nabisco estimates a capital cost of $1-1.5 mil- lion for controlling emissions by incineration and using a revised ink mixture (Freeman, 1980), which agrees with the RCF cost estimate. 42 TABLE 3.3 ESTIMATED COST OF RACT II CONTROLS FOR LUSTOUR CORPORATION (Dollars) Cost Item Incinerator Without Heat Recovery Carbon Adsorber Installed Capital Cost Annual Cost Electrical Fuel (Gas or Steam) Carbon Water Solvent Disposal Capital Charge 1,035,000 105,500 2,359,700 310,500 3,290,500 151,800 55,900 23,200 316,200 3,855,200 987,100 Total Annual Cost 2,775,700 5,389,400 Source: James Dawson, Lustour Corporation. The Chicago Rotoprint Company currently operates 13 publication rotogravure printing presses, in addition to 4 proof presses which are operated on an infrequent basis and are not expected to be subject to RACT II rules (Epstein, 1981). Of the 13 presses, 5 will be removed or retired by January 1983 and 3 others will be removed during the remain- 43 der of 1983. Emissions from another press are currently controlled with a carbon adsorber. Chicago Rctoprint esti- mates that the capital cost of ducting and retrofitting 2 carbon adsorbers on the remaining 4 presses is $3 million and that the recycling of recovered solvents will provide payback in 3 years (Epstein, 1981). The capital costs are identical with those estimated by RCF below, which are based on U.S. EPA studies. Alco-Gravure , a subsidiary of MacMillan Publishing Com- pany, currently operates 7 publication rotogravure printing presses. MacMillan, which owns 3 other printing plants, is considering curtailment of operations at Alco-Gravure since the plant is old and many of the printing units are consid- ered obsolete (Ehrsam, 1981). A shut-down of the plant would affect 300 to 400 workers. The economic impact of this plant closing will be discussed in Section 3.3.3. If the plant installs carbon adsorption control technology, capital costs are estimated by Alco-Gravure to be $1 million per press using a rule-of -thumb convention. The cost estimates from the individual firms are in basic agreement with the RCF estimates based on the U.S. EPA model plant studies. Table 3.4 shows the estimated cost of compliance using the model plant specifications, and Table 3.5 gives the total costs for Illinois by attainment and nonattainment areas. For the four affected firms the esti- 44 3.1.2 Petroleum Refining Leaks Nine petroleum refineries in Illinois have been identi- fied as being affected by the proposed RACT II controls (Illinois EPA, 1980f). Table 3.6 gives the names, loca- tions, capacities and estimated employment for these refi- neries. Seven of the plants are located in nonattainment counties. The two plants in unclassified counties, Marathon and Texaco (Lawrence), account for 30 percent of the refi- nery capacity enumerated in Table 3.6. VOM emissions originate from leaks in a variety of refinery equipment including pump seals, compressor seals, valves, flanges and other connections. A small percentage of these sources accounts for the majority of emissions (U.S. EPA, 1978c). The methods used to control refinery leaks are a pro- gram of periodic monitoring and maintenance, and add-on technology where needed. The two major components of costs are the purchase of monitoring instruments and the labor required for detection and maintenance of leaks. Table 3.7 shows the control costs for a medium size petroleum refining plant with throughput of 100,000 barrels per day (U.S. EPA, 1978c). All costs other than costs related to capital have been increased by a factor of 1.33 since Illinois refineries are 33 percent larger than the EPA model plant. The capital cost of $11,200 includes thepur- 47 TABLE 3 . 6 INFORMATION ON PETROLEUM REFINERIES IN THE STATE OF ILLINOIS Crude Capac i ty Firm City County Employment (Bbls/day) Amoco Wood River Madison 520 110, ,000 Clark Oil Blue Island Cook 328 56, ,500 Clark Oil Hartford Madison 300 57, ,000 Marathon Robinson Crawford 658 195, ,000 Mobile Oil Joliet Will 600 180, ,000 Shell Oil Wood River/ Roxana Madison 1,750 283, ,000 Texaco Lawrencevi lie Lawrence 600 84, ,000 Texaco Lockport Will 700 72, ,000 Union Oil Lemont Cook 600 151, ,000 Sources: Manufacturers' News, Inc., Illinois Manufacturers Directory , Chicago, 1980. Illinois EPA, "Technical Support Document for RACT II: Direct Costs of Implementing RACT II Regulations in Illi- nois," Air Quality Planning Section, Springfield, Illi- nois, January 1981. 48 TABLE 3.7 COST OF RACT II CONTROLS FOR LEAKS IN A MODEL REFINERY (Thousands of Dollars) Cost Item Cost Capital Cost 11.2 Annual Cost Capital Charge 2.0 Instrument Materials, Maintenance & Calibration 3.4 Monitoring Labor 89.8 Maintenance Labor • 94.6 Administrative and Support 56.5 Total Annual Cost 246.3 Source: U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment , Research Triangle Park, N.C., June 1978c. 49 chase of two monitoring instruments. The annual cost, $246,300, includes capital charges, instrument maintenance and calibration, monitoring and maintenance of leaks, labor costs and administrative and support costs. Monitoring labor costs have been doubled from. EPA estimates since the latter do not include directed maintenance (defined below) and they do not include adequate travel time to leaking com- ponents (Bruckert, 1980). Several points can be made regarding these estimates. One source of higher annual maintenance costs is the dis- tinction between directed and undirected m.aintenance . Directed maintenance involves simultaneous maintenance and screening of a valve which leaks hydrocarbons. With undi- rected maintenance the valve is not monitored during perfor- mance of the maintenance. Directed maintenance, which is generally more effective in reducing leaks (Radian, 1980), requires more manpower and thus adds to labor costs. Second, Darrell Bruckert, speaking on behalf of the Illinois Petroleum Council, has stated a belief that the labor costs are underestimated since certain components are located in remote or difficult to access areas. For these reasons, the monitoring labor costs estimated by U.S. EPA have been doubled in this analysis. 50 Capital costs may also be understated. If the large refineries in Illinois require additional monitoring instru- ments for use in directed maintenance or for backups, higher capital costs will be incurred. An influence that will tend to offset these potential additional costs is the reduction in the number and degree of leaks after controls are implemented. The amount of maintenance required should decline as leaks are repaired or controlled. Monitoring costs would still be incurred. After exempting valves in heavy liquid service, total VOM emissions from petroleum leaks in Illinois have been estim.ated to be 34,430 tons per year (Ting, 1980). Poten- tial emission reductions from RACT II controls were obtained using data on emissions from petroleum refining (Radian, 1980). The overall reduction in the leak rate following directed maintenance of valves is estimated to be 90.2 per- cent (Wetherold, 1980). Applying this percentage to current emissions in Illinois refineries gives a reduction in VOM emissions of 31,056 tons per year. Total estimated costs of RACT II refinery controls are shown in Table 3.8. For the nine refineries, the capital costs are $.1 million and the annual costs are $2.2 million. The reduction in leakage will result in savings of crude oil and gasoline for the nine refineries implementing RACT II. These savings will offset the costs of the con- 51 TABLE 3.8 TOTAL CONTROL COSTS AND EMISSION REDUCTIONS OF RACT I! FOR REFINERY LEAKS IN ILLINOIS Attainment Nonatta inment Item Counties* Counties Capital Cost (Thousand $) Annual Cost (Thousand $) Annual Petroleum Saving (Thousand $) VOM Emission Reduction (Tons/Year) 30.2 70.6 665.0 1,551.7 3,090.0 7,210.0 9,316.8 21,739.2 * Attainment counties have 30 percent of refinery capacity in Illinois from Table 3.6 and the costs and emission reduction figures represent this portion of total Illinois f igures . Sources: Tables 3.6 and 3.7. 52 trols. The reduction in VOM emissions of 31,056 tons is estimated to represent a savings of 320,000 barrels of crude oil (Ting, 1980) which, evaluated at the January 1981 national average price for crude oil of $32.34 per barrel (Wall Street Journal, 1981), results in a savings for Illi- nois refineries of $10.3 million. These estimated savings are greater than the total annual costs of control, and they suggest that refineries will control emissions in order to achieve the petroleum savings. The net annual costs due to RACT II are estimated to be zero since no additional con- trols will be implemented as a result of the regulations. 3.1.3 Surface Coating of Metal Products The RACT II category for surface coating of metal parts and products consists of manufacturing firms classified under SIC Codes 33 through 39, which are Primary and Fabri- cated Metals, Machinery, Equipment, Instruments and Miscel- laneous Manufacturing. This category excludes the surface coating of cans, coils, magnet wire, automobiles and light duty trucks, metal furniture, large appliances, airplanes and marine vessels. All but the latter two metal products were covered by RACT I regulations. Surface coating applications can vary widely in size and type of process. The U.S. EPA Control Technique Guide- line document for this category (U.S. EPA, 1978d) describes selected typical processes, emission points and control 53 technologies. The surface coating operations effected by the proposed regulations are of three general types: con- veyorized or batch single-coat, conveyorized two-coat, and manual two-coat. All three operations commonly require the cleaning and pretreatment of the metal product. The next step is a flow, dip or spray application of the coating. The conveyorized operation often uses an oven for drying while the manual process is usually air dryed. The actual procedure used on metal coating lines can vary from these basic types depending on the age of the equipment, the spe- cific metal products coated, and other unique design, safety or application considerations. VOM emissions occur during application, evaporation of solvent (flash-off) and drying of surface coatings. A var- iety of control methods can be used to reduce these emis- sions. One method is to improve the transfer of solvent coatings to the product surface. The most common surface coating technique, spraying, has a transfer efficiency of 40 to 70 percent. The efficiency can be increased to 70 to 90 percent with electrostatic spraying, which may be used under the proposed regulations as a means of reducing VOM emis- sions. Other forms of control are conversion to water-borne and high solids coatings and the installation of carbon adsorption or incineration units. 54 One hundred forty-five plants involved in the surface coating of miscellaneous metal parts and products have been identified as subject to the proposed rules. Plants with VOM emissions of 25 tons or less per year are considered exempt (Illinois EPA, 1980j). Table 3.9 shows the affected firm name, the county the plant is located in, the attain- ment status of that county, the Standard Industrial Classi- fication Code, and the estimated employment given in the Illinois Manufacturers Directory (Manufacturers' News, 1980). Information for eight of the affected firms was not available in the Manufacturers Directory. The table shows that 110 firms or 76 percent of the firms affected by the RACT II regulations are in nonattainment counties. The Illinois EPA Total Air System (TAS) computer file, which was used to identify the number of affected firms, also has data on specific emission sources at these firms. It lists 380 ovens, flow coaters, dip coaters and spraying operations in attainment and unclassified counties. These 'sources account for a maximum of 13,837 tons of VOM emis- sions per year if each source were operated at the maximum rate indicated in the permit. Illinois EPA also identified 1,134 sources in nonattainment counties with maximum VOM emissions of 36,184 tons per year (Illinois EPA, 1981). The breakdown of these sources is provided in Table 3.10. The majority of surface coating emissions sources are spraying 55 TABLE 2.9 INFORMATION ON FIRMS AFFECTED BY RACT II REGULATIONS FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS Firm Name Attainment County Status SIC Employn: Container Co. (Gale Products) J&S Tin Mill Products Co., Inc Evans Supply Co. Abex Corporation Naylor Pipe Co American Steel Vernois, Inc. OMC--Galesburg Alcan Metallic Laidlaw Corp. Caterpillar Tractor--Mapleton Northwestern Steel & Wire Co. Litteral Mfg. Co. Trinity Industries Inland Steel Container Co. Lamson and Sessions Co. Young Ottawa, Inc. Nat ico , Inc . Chicago Finished Metals, Signode Corp. Keystone Steel & Wire Suburban Finishing Ltd. Eagle Sheet Metal Mfg. Co Acme Finishing Company Enamelers & Japanners, In Imperial Japanning Co. Jokes and Shafer, Inc. Meyer Steel Drum Inc. Skolnick Drum Corporation Rheem Manufacturing Co. Abbey Finishing Co. Intercraft Industries Corp. Drackett Co. Ready Metal Manufacturing Co. Manta Vin-Cor Steel Corp. ILG Industries Inc. Trilla Steel Drum Corp. Cook N 3316 Cook N NA Cook N 3321 Cook N 3317 Cook N 3412 Jefferson U NA Knox U 3524 2 Lake N NA Massac U 3312 Peoria N 3321 3 Whiteside U 3312 3 Adams N 3499 Cass U 3443 Cook N 3412 Cook N 3452 Cook N NA Cook N 3412 Cook N 3412 Cook N 3499 Cook N 3315 Cook N NA Cook N 3444 Cook N NA Cook N 3479 Cook N 3479 Cook N 3479 Cook N 3412 Cook N 3412 Cook N 3443 1 Cook N 3479 Cook N 2499 Cook N 2843 Cook N 3562 Cook N 3316 Cook N 3433 Cook N 3412 (Table continued on following page) 56 TABLE 3.9 (Continued) INFORMATION ON FIRMS AFFECTED BY RACT II REGULATIONS FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS Firm Name Attainment County Status SIC Employment Ess-Kay Enameling Co. Cook *Phoenix Closures DuPage Dresser Industries Inc. Cook Progress Industries, Inc. Douglas Equipto Kane Lawndale Industries Inc. Kane Miss. Valley Structural Steel Kane Model Industries Inc. Kendall Butler Manufacturing Co. Knox Morton Manufacturing Co. Lake Motor Wheel Corp. LaSalle Interlake I nc . --Pont iac Livingsto King-Seely Thermas Div.-- Macomb McDonough Modine Manufacturing Co. McLean Miss. Valley Structural Steel Macon Nesco Steel Barrel Company Madison Rockwell Industries Marion Wiegmann & Company, Inc. St. Clair Locke Stove Company St. Clair King-Seely Thermos Di v . -Freeport Stephenso Bennett Industries Div. Will *Ceco Corporation Will Amerock Corporation Winnebago Amerock Corporation Winnebago Atwood Vacuum Machine Co. Winnebago Continental Scale Corporation Cook Advertising Metal Display Co. Cook Symons Manufacturing Co. Cook Allis Chalmers--Ind. Truck Div. Cook International Harvester--Mel .Pk . Cook Bell & Gossett Fluid Handling Cook Addressograph Multigraph Cook A.B. Dick Company Cook Spotnails Inc. . Cook Skil Corporation Cook Skil Corporation Cook n N N N U N N N N U N N U U A A N U N N U N N U U U N N N N N N N N. N N N 3479 3469 3423 3443 2542 3431 3441 3462 3499 3446 3312 3537 3429 3713 3441 3412 3412 3462 3433 3631 3412 3441 2514 3429 3714 3567 3993 3561 3537 3523 NA 3579 3579 3552 3553 3553 19 300 300 350 480 150 85 155 875 150 275 525 600 190 280 100 100 180 135 400 500 300 100 800 000 205 325 100 200 000 NA 400 983 500 200 350 (Table continued on following page) 57 TABLE 3.9 (Continued) INFORMATION ON FIRMS AFFECTED BY RACT II REGULATIONS FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS Firm Name County Attainment Status SIC International Harv.--West Pulman Cook Lakewood Engineering & Mfg. Co. Cook Turner Co. DeKalb International Harvester-- Canton Fulton Hyster Company Henry Barber-Greene Co.-- Aurora Kane *Caterpillar Tractor-- Aurora Kane Internat. Harvester-Libertyvi lie Lake Outboard Marine Corporation Lake Caterpillar Tractor-- Decatur Macon Wabco Construction and Mining Peoria Caterpillar Tractor-- Massville Peoria Internat. Harvester--East Moline Rock Isl John Deere Harvester Works Rock Isl John Deere Plow & Planter Works Rock Isl American Air Filter Co., Inc. Rock Isl Internat. Harvester--Rock Island Rock Isl Fiat Allis Sangamon Caterpillar Tractor-- East Peoria Tazewell *Caterpillar Tractor-- Morton Peoria Hyster Co. Vermilli *Desa Industries Cook Caterpillar Tractor-- Joliet Will Container Stapling Corporation Williams The Brearley Company Winnebag Jefferson Electric Co. Cook Sun Electric Cook Western Electric Hawthorne Works Cook General Bathroom Products Cook Sunbeam Appliance Co. Cook Rock Ola Manufacturing Corp. Cook Seeburg Corporation Cook S&C Electric Co. Cook Westinghouse Electric Cook ♦General Electric-- DeKalb DeKalb Fox Valley Manufacturing Div. Kane N N N U U N N N N A N N and U and U and U and U and U N N N U N N N U N N N N N N N N N N N on on o 3523 3564 3599 3523 3536 3531 3537 3531 3519 3531 3531 3519 3523 3523 3523 3561 3523 3523 3531 3321 3536 3724 3531 3579 3576 3612 3499 3661 2514 3634 3651 3613 3613 3661 3621 3645 1 6 2 4 5 1 8 4 5 3 3 2 16, D( 3 2 (Table continued on following page) 58 TABLE 3.9 (Continued) INFORMATION ON FIRMS AFFECTED BY RACT II REGULATIONS FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS Firm Name Attainment :ounty Status SIC Employmen Lake N 3645 150 McHenry N 3621 850 McLean A 3622 1,000 Adams N 3523 1,500 Cook N 3599 200 Cook N 3462 1,450 Cook N 3743 306 Cook N 3743 1,000 Cook N 3743 180 Cook N NA NA Kane N 3711 250 Cook N 3713 14,500 Cook N 3523 680 Cook N 3751 2,000 Cook N 3711 4,500 Cook N 3714 3,400 Edgar U 3713 306 Edwards U 3714 1,086 Jefferson U 3714 425 LaSalle N 3523 220 Macon A 3585 1,400 Madison N 3714 2,100 Union U 3715 145 Will N 3599 120 Winnebago U 3714 900 Cook N 3861 2,190 DuPage N 3842 300 McHenry N 3622 750 McHenry N 3824 800 Cook N 3999 350 Cook N 3944 350 Cook N 3949 270 Cook N 3999 240 Cook N 3944 1,000 Kane N 3995 350 Percy U 3949 400 Richland U 3949 2,085 Lighting Products, Inc. Woodstock Die Casting General Electric-- Bloomington Electric Wheel Co. *Cummins Engine Company Inc. Borg-Warner-- Spring Division U.S. Railroad Manufacturing Co. Thrall Car Manufacturing Co. North American Car Corp. General Motors-- McCook *Elgin Sweeper Co. General Motors-- Chicago Ingersoll Products Schwinn Bicycle Co. Ford Motor Co.-- Chicago Stamping General Motors-- Fisher Body Mid West Body & Manufacturing Champion Laboratories, Inc. General Radiator Hart Carter Co. Borg-Warner Corp.-- York Division A.O. Smith Transcraft Corp. Nash Bros. Inc. Warner Elec. Brake and Clutch Co. Bell & Howeli-- Lincolnwood Protectoseal Company Intermat ic I nc . Sun Electric Aero Space Division General Fire Extinguisher Corp. Strombecker Corporation Radio Steel S< Manufacturing Co. Candle Corporation of America Playskool, Inc. Elgin Metal Casket Company Turco Manufacturing Co. AMF Incorporated (Table continued on following page) 59 TABLE 3.9 (Continued) INFORMATION ON FIRMS AFFECTED BY RACT II REGULATIONS FOR SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS Footnotes * The permit for this company is filed in a county other than that listed in the Manufacturers Directory shown here. Sources: Illinois EPA, "Technical Support Document for RACT II: Surface Coating of Miscellaneous Metal Parts and Pro- ducts," Air Quality Planning Section, Springfield, Illi- nois, May 1980J. Manufacturers' News, Inc., Illinois Manufacturers Direc - tory, Chicago, 1980. Key: N - Nonattainment U - Unclassified A - Attainment NA - Not Available SIC - Standard Industrial Classification code 60 TABLE 3.10 NUMBER OF EMISSION SOURCES OF AFFECTED MISCELLANEOUS METAL PARTS AND PRODUCTS SURFACE COATERS IN ILLINOIS, BY TYPE Source Size Emission Attainment Small Medium Large Source Status (a) (b) (c) Spray A N Dip A N Flow A N Ovens A N (a) Small: <25 tons per year. 188 56 16 559 150 49 13 12 4 36 19 1 1 3 9 2 1 3 53 20 5 175 126 13 (b) Medium: ^-25 and <100 tons per year. This category includes sources with missing data. (c) Large: >100 tons per year. Source: Illinois EPA, "Technical Support Document for RACT II: Direct Costs of Implementing RACT II Regulations in Illinois," January 1, 1981. Key: A - Attainment and Unclassified Counties N - Nonattainment Counties 61 operations. No data exist on the number of manual opera- tions . The capital costs, annual costs and percentage emission reductions for alternative control technologies and diffe- rent surface coating operations in a model plant were esti- mated by the U.S. EPA (U.S. EPA, 1978h). Selected estimates are presented in Table 3.11. High solids coatings were selected for spray operations and water-borne coatings were selected for dip and flow operations since these were the most cost effective control technologies reported for each operation. The cost of incineration is also included for each type of operation since this cost is used to estimate the cost impact of the nonexemption in Illinois of two alternative solvents. These cost estimates are based on typical surface coat- ing operations. However, some firms may have unique pro- cesses which would require alternate, more costly technolo- gies. Also, the U.S. EPA cost estimates do not incorporate all of the costs of changes in paint systems, nor do they include the extra capital cost to provide washers since com- pliance coatings often require less soiling on the product surface (Grotelueschen , 1980). The model plant costs of the most cost effective con- trol technique were adjusted to reflect added costs that may be incurred because of Illinois EPA's proposed nonexemption 62 TABLE 3.11 CONTROL COSTS AND EMISSION REDUCTIONS FOR MODEL SURFACE COATING OPERATIONS Surface (a) (b) (c) (d) Coating Source Control Capital Annual Emission Operation Size Technology Cost Cost Reduction (Thousand $) (Thousand $) (Tons/ year) Spray Small High Solids 38.3 12.8 4.5 Medium II 54.9 31.9 31.0 Large II 75.3 52.4 139.5 Small Incineration ( o "l 280.9 90.7 5.4 Medium \ e ) II 1,172.3 384.4 37.7 Large •1 2,187.5 717.7 169.4 Dip Small Water-borne 15.3 6.4 10.6 Medium 11 25.5 17.9 54.9 Large II 35.8 33.2 207.8 Small I nc inerat ion 81.7 26.8 11.9 Medium II 160.9 53.6 61.7 Large II 256.7 84.3 233.8 Flow Small Water-borne 15.3 6.4 6.4 Medium II 25.5 17.9 29.6 Large II 35.8 33.2 230.6 Small Inc inerat ion 75.3 24.3 7.2 Medium II 132.8 44.7 33.3 Large II 199.2 65.1 259.4 (Table continued on following page) 63 TABLE 3.11 (Continued) CONTROL COSTS AND EMISSION REDUCTIONS FOR MODEL SURFACE COATING OPERATIONS Footnotes (a) The sizes of the model plants vary with each operation and are given in the EPA document cited below. The sizes correspond with the ranges used in Table 3-3. (b) The capital costs are obtained from U.S. EPA, 1978d, Tables 3-3, 3-4, and 3-5 and are converted to 1980 dol- lars . (c) The annual costs are the sum of the operating cost from U.S. EPA, 1978d, Tables 3-3, 3-4 and 3-5, converted to 1980 dollars and the annual capital charge rate times the capital cost. (d) Emission reductions are computed using the averages for the sources in U.S. EPA, 1978d, Table 3-3. The esti- mated percentage emission reductions are: 70 percent for high solids-spray, 85 percent for incineration- spray, 80 percent for water-borne-dip and -flow, and 90 percent for inc incerat ion-dip and -flow (Illinois EPA, 1981). (e) The thermal inc incerat ion unit has 90 percent heat recovery . Source: U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VI: Surface Coating of Miscellaneous Metal Parts and Products, Research Triangle Park, N.C., June 1978d. 64 of two chemicals used in some coatings, 1 , 1 , 1-tr ichloro- ethane and methylene chloride. In testimony given on Novem- ber 5, 1980 Frank Graziano of the National Coil Coaters Association stated that 7 percent of the affected firms would be unable to use the most cost effective technology and that solvents using either of the two chemicals would be the next best alternative. If the chemicals were not exempt they may be required to use incineration as a control tech- nique. His testimony emphasized that the choice of control technique depends not just on the cost of coatings and con- trol devices but also on physical properties such as evapo- ration rate, solubility, hydrogen bonding and surface ten- sion . The total cost estimates shown in Table 3.12 are com- puted using the number of emission sources in Table 3.10 and the cost figures in Table 3.11. The costs are based on 93 percent of these sources switching to the use of high solids or water-borne compliance coatings and 7 percent adding on thermal incineration. This is considered to be the case if the two chemicals remain nonexempt . If the two chemicals were exempt, the cost of control for the 7 percent of firms which are estimated to use them would be lower, but not as low as the cost of switching to high solids or water-borne compliance coatings. The sources controlled with incinera- tion units account for nearly half (41.4 percent) of total annual costs. 65 TABLE 3.12 TOTAL CONTROL COSTS, EMISSION REDUCTIONS AND COST EFFECTIVENESS OF RACT II FOR MISCELLANEOUS METAL PARTS AND PRODUCTS SURFACE COATERS IN ILLINOIS Attainment Nonattainment Item Counties Counties Capital Cost (Thousand $) 22,642.5 61,875.5 Annual Cost (Thousand $) 8,996.9 23,897.7 VOM Emission Reduction (Tons/Year) 8,717.7 16,656.6 Cost Effectiveness (Annual $ Cost/Ton) 1,032.0 1,434.7 Sources: Tables 3.10 and 3.11. Estimated annual costs in nonattainment counties are 73 percent of the total for Illinois. Cost effectiveness is higher for nonattainment counties, $1,434.7 versus $1,032.0 for attainment counties, since a higher proportion of spray operations, which are generally more difficult to control, are in nonattainment counties. 66 3.1.4 Storage Tanks With Floating Covers The floating cover on a storage tank is ordinarily a double deck or pontoon single deck cover, which rests upon the crude oil or gasoline, and is equipped with a primary closure seal between the roof edge and tank shell. The rate of VOM emissions depends upon the tank shell construction (riveted or welded), the type of seal or seals, the type of petroleum liquid stored, atmospheric conditions and other factors . Illinois EPA has identified 414 storage tanks^ subject to controls in Illinois (Illinois EPA, 1981). This figure appears consistent with a survey conducted by the Illinois Petroleum. Council in which 90 percent of the firms respond- ing identified 362 tanks (Bruckert, 1980). Table 3.13 shows the location of the tanks by county, the attainment status of the county, the type of liquid stored and the tank shell construction. Only 400 tanks are listed, since tanks with vapor pressure less than 1.5 pounds per square incL, or capacity for gasoline storage of less than 900 barrels, are exempted (Levis, 1980). The table shows there are 339 welded tanks, and 222 tanks used to store gasoline. The majority of tanks, 66 percent, are located in nonat tainment counties. ' The Illinois EPA Total Air System (TAS) computer file, containing 416 tanks when the Technical Support Document (Illinois EPA, 1980h) was prepared in early 1980, has since been revised. 67 TABLE 3.13 NUMBER OF EXTERNAL FLOATING ROOF TANKS, BY TYPE Attainment Crude Oi 1 Storage Gasol ine Storage County Status Welded Riveted Welded Riveted Clark ■ U 13 1 Cook N 4 15 Crawford A 7 1 26 De Witt U 3 Edwards U 1 Ef f ingham U 2 Fayette U 2 Iroquois U 1 Kankakee N 4 Livingston U 11 2 Macon A 4 Madison N 44 2 55 3 Marion U 53 Mason U 2 McLean A 1 Ogle U 1 Peoria N 1 St. Clair N 5 18 15 Tazewell N 8 Will N 23 7 34 27 Winnebago U 4 162 16 177 45 Source: Illinois EPA Total Air System (TAS) Computer File Key: U - Unclassified County N - Nonattainment County A - Attainment County 68 The applicable control technology for external floating roof tanks is a rim-mounted secondary seal (U.S. EPA, 1978i). Ninety-three percent of the 400 tanks identified are currently fitted with a single primary seal, while the rest have a double seal. Weather guards are not considered sufficient since the amount of emissions controlled is uncertain in different applications (U.S. EPA, 1978i). The cost estimates developed by the U.S. EPA are based on a model storage tank with a capacity of 55,000 barrels or 2.3 million gallons (U.S. EPA, 1980i), which is one-half the average capacity for the affected tanks in Illinois. The maximum tank height is generally considered to be forty- eight feet for capacities greater than 3.1 million gallons (Moody, 1981). The diameter for the model storage tank in Illinois, computed using the equation^ for the volume of a solid cylinder, is 127.7 feet. ^ The formula for the diameter is: D = 2 X [V/(F X P X H) ] ** (1/2) where: D = diameter in feet V = volume in gallons = 4.6 million F = gallons per cubic foot = 7.481 P = pi = 3.1415927 H = height in feet = 48 The symbol ** indicates exponentiation. 69 The capital cost of implementing RACT II for a model Illinois storage tank is $25,800 (using a cost of $54.40 per linear foot of circumference taken from U.S. EPA, 1978i, p. 4-7) and includes equipment and the cost of cleaning and degassing the tank. It does not include research and devel- opment, lost time during installation and start-up and other variable costs which depend on the specific installation. Annual control costs of $5,900 include annualized capital charges of $4,500 and operation and maintenance costs of $1,400 (U.S. EPA, 1978i, p 4-9). In addition to these costs, there are savings from controlling emissions. The annual savings of petroleum liquid stored in external floating roof tanks with installa- tion of rim-mounted secondary seals depend on wind speed, vapor pressure, type of primary seal and the density, mole- cular weight and value of the liquid stored. Table 3.14 shows the estimated VOM emissions, annual control costs, petroleum savings and VOM emissions cont- rolled for model gasoline and crude oil storage tanks. The implementation of the RACT II regulations in Illinois is estimated to result in no additional costs for floating roof tanks because of the petroleum credits. Table 3.15 gives the direct capital cost, annual cost, annual petroleum credit, and emission reductions for attainment and nonat- tainment counties in Illinois. 70 TABLE 3.14 CONTROL COSTS AND EMISSION REDUCTIONS FOR MODEL EXTERNAL FLOATING ROOF TANKS IN ILLINOIS Gasoline Storage Crude Storage Item Welded Riveted Welded Riveted Capital Costs (Thousand $) 25.8 25.8 25.8 25.8 Annual Control Costs (Thousand $) 5.9 5.9 5.9 5.9 Annual Petroleum Credit (Thousand $) (13.3) (12.4) (8.1) (7.5) VOM Emissions Controlled (Tons/year) 36.2 33.6 23.6 21.8 VOM Emissions (Tons/year) 44.9 74.7 29.3 48.5 Sources: Annual Control Costs - see text. Annual Petroleum Credit - VOM emissions controlled times value of conserved petroleum. Gasoline is valued at $43.26 per barrel (Wall Street Journal, 1981) and crude oil is valued at $32.34 per barrel (Ibid). VOM Emissions Controlled - Emissions before control times control efficiency (U.S. EPA, 1978i, Table 4-1). 71 TABLE 3.15 TOTAL CONTROL COSTS AND EMISSION REDUCTIONS OF RACT II FOR EXTERNAL FLOATING ROOF TANKS IN ILLINOIS Attainment Nonattainment Item Counties Counties Capital Cost (Thousand $) 3,483.0 6,837.0 Annual Control Cost (Thousand $) 796.5 1,563.5 Annual Petroleum Savings (Thousand $) 1,306.5 3,029.5 VOM Emission Reduction • (Tons/Year) 3,708.1 8,376.6 Sources: Tables 3.13 and 3.14. These cost estimates include tanks which store waxy, heavy crude oil. Illinois EPA is considering exempting these tanks, but a definition of waxy, heavy crude has not yet been determined. If the definition proposed by Marathon Oil Company in its testimony were accepted, 24 Marathon Oil tanks would be exempted from the proposed rule (Fisher, 1980). The number of exempted tanks at other refineries is not known. The exemption of Marathon tanks would reduce 72 capital costs in Illinois by $.6 million and annual costs by $.1 million. The effect on annual costs would depend on whether the exempted tanks are of the welded or riveted type. There is some question whether tanks with existing dou- ble seals will be exempted (Illinois EPA, 1981). There are currently 5 tanks in nonattainment counties and 22 in attainment areas fitted with double seals. If these tanks are exempted, the capital costs would be reduced by $.6 mil- lion in attainment areas, and $.1 million in nonattainment areas . 3.1.5 Synthesized Pharmaceuticals The manufacture of synthesized pharmaceutical products, which is classified under Standard Industrial Classification (SIC) Code 28, Chemicals and Allied Products, entails pro- ducing a wide range of intermediate and final products. The products are generally manufactured in batch processes at infrequent intervals. The four most important VOM emission sources are dryers, reactors, distillation systems, and storage tanks and transfer operations. Other sources contributing VOM emissions are filters, extractors, centrifuges and crystal- lizers. The applicable controls are carbon adsorbers, con- densers, scrubbers, floating roofs and vent controls. Some of this technology may be used to control emissions from several sources ducted together (U.S. EPA, 1978g). 73 :m There are reported to be five manufacturers of synthesized pharmaceutical products in Illinois (U.S. EPA, 1978g and Illinois EPA, 1980g). Table 3.16 shows the fir names, locations, SIC Codes, and estimated employment. All five firms are located in nonattainment counties. The identification of affected emission sources at these five firms is complicated for several reasons. The proposed rules for this category exempt sources which do not have the potential to emit more than fifteen pounds per day of VOM. Furthermore, many of the affected firms manufacture pharmaceuticals which are not considered synthesized, and many of the operations that produce synthesized pharmaceuti- cal products are already controlled. Illinois EPA searched its permit file to determine the number of uncontrolled, synthesized pharmaceutical emission sources with potential ^or emitting 15 pounds or more of VOM. Table 3.17 lists the number of sources found which meet these criteria. The applicable control technology for reactors, centri- fuges and crystall izers is generally considered to be con- densers. Air dryers can be controlled with water scrubbers, except for one unit at Abbott Laboratories which requires carbon adsorption (Reed, 1980). Typical source sizes were used to estimate control costs. In each case the midpoint of a range of source sizes was used. The annual costs do not include the solvent recovery credits from condenser con- 74 TABLE 3.16 INFORMATION ON SYNTHESIZED PHARMACEUTICAL MANUFACTURERS Chicago Hts Cook 2833 NA Chicago Hts Cook 2833 145 Frankfort Will 2899 36 Skokie Cook 2869 1600 North Chicago Lake 2834 4500 Firm City County SIC Employment A. L. Laboratories Dawes Products Diamond Shamrock Searle Laboratories Abbott Laboratories Sources: Illinois EPA, "Technical Support Document for RACT II: Manufacture of Synthesized Pharmaceutical Products," Air Quality Planning Section, Springfield, Illinois, May 1980g. Manufacturers' News, Inc., Illinois Manufacturers Direc - tory, Chicago, 1980. Key: SIC - Standard Industrial Classification code NA - Not available 75 TABLE 3.17 NUMBER OF SYNTHESIZED PHARMACEUTICAL MANUFACTURING EMISSION SOURCES AFFECTED BY RACT II REGULATIONS, BY TYPE VOM Emission Source Firm Reactors Centrifuges Crystallizers Dryers A. L. Laboratories 1 - 11 Dawes Products - 1 - 1 Diamond Shamrock - - - 2 Searle Laboratories 7 4 - 3 Abbott Laboratories 8 10 3 12 Totals 16 15 4 19 Source: John Reed, Illinois EPA, Testimony Before the Illi- nois Pollution Control Board, R80-5, November 6, 1980. 76 trols, since "they are not presently definable" (U.S. EPA, 1978g). However, solvent recovery credits are included in the annual cost for, the carbon adsorber. Table 3.18 pre- sents the capital and annual costs for these model sources based on U.S. EPA estimates. It should be noted that characterizing typical control applications in this industry is made particularly difficult by variations in types and amounts of emissions. Officials at companies operating the two largest plants, Abbott and Searle, were contacted in order to corroborate the estimates of control costs and emission reductions. Abbott Laboratories has identified 193 VOM emission sources that involve synthesized pharmaceutical manufacture at the North Chicago plant (Schwarz, 1980). After excluding sources with less than 15 pounds of VOM emissions per day, which are exempt under the proposed rule, 110 emission points require controls. Abbott has estimated the capital cost of retrofitting scrubbers and condensers for these sources at $3 rrillion and the annual cost at $.6 million (Schwarz, 1980). These estimates include the use of a sin- gle control device for clusters of emission sources where appropriate, the disposal of organic materials and the increased energy costs. The estimates are based on a longer time period than the proposed rule specifies. Abbott has stated that full compliance by 1982 would require additional 77 TABLE 3.18 CONTROL COSTS FOR MODEL SYNTHESIZED PHARMACEUTICAL EMISSION SOURCES (a) (b) Capital Annual Emission Control Cost Cost Source Technology (Thousand $) (Thousand $) Reactor, Centrifuge, Crystallizer Condenser (c) 60 20 Air Dryer Scrubber (d) 67 130 Air Dryer Carbon Adsorber (e) 458 18 (a) Capital costs are obtained from Figures 5-7, 5-15 and 5-23 (U.S. EPA, 1978gi and are converted to 1980 dol- lars . (b) Annual costs are obtained from Figures 5-8, 5-16 and 5-24 (U.S. EPA, 1978g) and are converted to 1980 dol- lars . (c) Based on chilled water-cooled condenser and water chiller operating 2,000 hours per year (8 hours, 250 days) with 20 tons cooling capacity. (d) Based on venturi scrubber operating 2,000 hours per year with 10,000 cubic meters per hour capacity. (e) Based on carbon adsorption unit operating 2,000 hours per year with 550 pounds per hour emissions controlled. Source: U.S. EPA OAQPS Guideline Series, Control of Vola - t ile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products, Research Triangle Park, N.C., December 1978g. 78 engineering capacity, possible production losses and other inefficiencies, potentially adding 50-100 percent to the estimated costs. Abbott has estimated these control mea- sures will reduce VOM emissions by 90 percent, from 280 to 30 tons per year. As shown in Table 3.17, Illinois EPA, using the source classification code for synthesized pharmaceutical manufac- ture, identified only 33 uncontrolled sources at Abbott Laboratories. This is less than one-third of those cited by Abbott Laboratories. One reason for the discrepancy is that some permits apply to complete systems or processes involv- ing many intermediate sources, although only one source in the system has a permit. In other words, the Illinois EPA source count refers to systems rather than individual sources. The cost estimates, however, are similar since both RCF and Abbott in effect base their estimates on sys- tems or clusters of sources. Searle Laboratories is not expected to incur costs in implementing R.^CT II. Searle plans to suspend manufacturing operations at their Skokie plant and move out of state by 1982, for efficiency reasons unrelated to pollution regula- tions. The firm had previously estimated incremental capi- tal expenditures of $.5 million for RACT II (Nisselson, 1980). 79 The total RACT II costs for the five affected pharma- ceutical firms were estimated using the information in Tables 3.17 and 3.18. Total capital costs are $2.9 million and annual costs are $2.4 million. The costs are summarized in Table 3.19. 3.1.6 Perchloroethylene Dry Cleaners Commercial and Industrial Dry Cleaners using a perchlo- roethylene cleaning solvent are potentially affected by the RACT II controls in Illinois, although smaller firms may be exempted as will be discussed below. The major source of VOM emissions in dry cleaning systems is the dryer. Signi- ficant emissions also occur during disposal of waste materi- als and from liquid and vapor leaks. Control techniques include carbon adsorption, incinera- tion, good housekeeping practices and visual inspection or monitoring of leaks. Carbon adsorption systems are cur- rently in wide use in the industry (U.S. EPA, 1978h) since the captured solvent is generally reusable. Dry cleaning firms are more numerous and generally smaller than firms in other RACT II categories, and poten- tially affected firms are more difficult to identify. The 1977 Census of Service Industries was used to identify 1,012 commercial dry cleaning firms in Illinois with SIC 7216, Dry Cleaning Plants, excluding Rug Cleaning. (This figure only includes firms with payrolls, presumably excluding the very 80 TABLE 3.19 TOTAL CONTROL COSTS, EMISSION REDUCTIONS AND COST EFFECTIVENESS OF RACT II FOR SYNTHESIZED PHARMACEUTICAL MANUFACTURERS IN ILLINOIS Nonattainment Item Counties Capital Cost (Thousand $) 2,903.0 Annual Cost (Thousand $) 2,448.0 VOM Emission Reduction * (Tons/Year) 302.5 Cost Effectiveness (Annual $ Cost/Ton) 8,092.6 * Based on Illinois EPA estimates given in Table 3 of (Reed, 1980) using 90 percent control efficiencies. Sources: Tables 3.17 and 3.18. 81 small dry cleaning plants.) Furthermore, the Census of Ser- vice Industries only gives detailed statistics for counties and Standard Metropolitan Statistical Areas (SMSAs) with 500 or more service establishments. These counties contain 872 of the 1,012 commercial dry cleaning plants identified. The remaining 140 commercial plants were allocated to counties with fewer than 500 service establishments in proportion to population . There are 43 firms with payrolls in SIC Code 7218, Industrial Launderers. Half or 22 of these firms are esti- mated to operate industrial dry cleaning systems. Illinois has 793 establishments with payrolls in SIC Code 7215, Coin-operated Laundries and Dry Cleaners. The 112 establishments listed with SIC 7211, Family and Commer- cial Power Laundries, are not included in the analysis since no information is available on the number of perchloroethy- lene dry cleaning units operated by these laundries. Table 3.20 summarizes the information on the number of commercial, coin-operated and industrial dry cleaners in Illinois. Of the dry cleaners identified 1,371, or 75 per- cent, are located in nonattainment counties. The U.S. EPA estimates that 74 percent of commercial dry cleaning systems and 50 percent of industrial dry cleaning systems use per- chloroethylene cleaning solvent (U.S. EPA, 1978h). Further- more, U.S. EPA estimates that 35 percent of these systems 82 TABLE 3.2 NUMBER OF DRY CLEANERS WITH PAYROLLS IN ILLINOIS, BY TYPE Type of Dry Cleaner Attainment Commercial Industrial Coin-Operated Status (SIC 7216) (SIC 7218) (SIC 7215) Nonattainment 795 12 564 Attainment 217 10 229 Illinois 1,012 22 793 Source: U.S. Department of Commerce, 1977 Census of Service Indust r ies , Summary Statistics for Counties or SMSAs with 500 or More Establishments, 1978c. Key: SIC - Standard Industrial Classification code 83 already use carbon adsorption to control emissions, since firms find it economical to capture and reuse the increas- ingly expensive solvents (U.S. EPA, 1978h and Illinois EPA, 1981). All of the coin operated dry cleaners are estimated to use perchloroethylene . Applying these percentages to the number of plants listed in Table 3.20 gives 382 commercial dry cleaners affected by RACT II in nonattainment counties and 104 in attainment counties. The corresponding numbers for industrial dry cleaners are 4 and 3, respectively. The U.S. EPA Control Technique Guideline Document (U.S. EPA, 1978h) for this RACT II category provides cost esti- mates for several control technologies and plant sizes for commercial, industrial and coin-operated dry cleaning plants. Carbon adsorption control systems appear to be more cost effective, particularly for larger plants where emis- sions from many dry cleaning units can be ducted together. The cost estimates presented are based on a carbon adsorp- tion control system for a model commercial dry cleaning plant operating 23 units of 7.9 pounds capacity per unit and a model industrial dry cleaning plant operating 91 units of 7.9 pounds capacity per unit. The applicable control strategy for coin-operated dry cleaners is improved maintenance of existing control equip- ment, and detection and repair of leaking components. No additional equipment is required. The annual costs are 84 estimated using the EPA model plant size (2 units of 7.9 pounds capacity per unit) and include a solvent credit. Table 3.21 shows the control costs for the model per- chloroethylene dry cleaning plants. The capital costs reflect the labor and material cost of design, purchase and installation of a carbon adsorption system and include site preparation and removal of existing equipment. Annual costs include operating labor, maintenance, utilities, credits for solvent recovery, waste disposal and capital charges. The price of perchloroethylene solvent, $.68/kg or $.31/lb, has increased 38.8 percent since 1978 (Virginia, 1980). This increase is double the rate of inflation, and the increased credits for solvent recovery make carbon adsorption more economical than in 1978. The capital cost for the model commercial plant is $5.5 thousand. On an annual basis, comparing the annual cost of $1.4 thousand with the reduction in solvent cost of $2.1 thousand, shown as solvent credit in Table 3.21, gives a net annual gain rather than cost to adopting the technology. The annual gain is $700. The capital cost for the model industrial plant is larger, $10.1 thousand, and the solvent credit is also greater. Comparing annual cost and solvent credit again reveals that there is a net gain to adopting the control. In this case the gain is $13.9 thousand annu- ally. The estimated annual costs for coin operated dry 85 TABLE 3.21 CONTROL COSTS, EMISSION REDUCTIONS AND COST EFFECTIVENESS OF RACT II FOR MODEL PERCHLOROETHYLENE DRY CLEANING PLANTS Coin Item Commercial Industrial Operated Capital Cost (Thousand $) 5.5 10.1 Annual Cost (Thousand $) Operation and Maintenance .4 Capital Charges 1.0 1.0 .8 1.8 - 2.8 .8 (16.7) (.1) Total Annual Cost 1.4 Solvent Credit (Thousand $) (2.1) VOM Emission Reductions (Tons/year) 3.5 27.2 .3 Cost Effectiveness (Net Annual $ Cost/ton) (a) (a) 2,333.0 (a) Not applicable since credits exceed control costs. Source: U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Sys - tems , Research Triangle Park, N.C., December 1978h. 86 cleaners are $800, and solvent credits are $100 per year. Net annual cost is the difference, $700, and when divided by the estimated emission reduction of .3 tons gives an esti- mated cost effectiveness of $2,333 per ton. Table 3.22 summarizes the estimated capital and annual costs and emission reductions for the three types of dry cleaners in attainment and nonattainment areas in Illinois. The total capital cost is $2.7 million and the total annual cost is $.1 million. 3.1.7 Pneumatic Rubber Tire Making Certain operations in the manufacture of pneumatic rub- ber tires are subject to the proposed RACT II rules. Pneu- matic rubber tires are molded from strong fibers impregnated with polymers and overlayed with a tread of wear-resistant polymer (U.S. EPA, 1978f). The majority of these tires are constructed for passenger cars but include tires for trucks, tractors, bicycles and many other types of vehicles and equipment. The SIC code for this industry is 3011, Tires and Inner Tubes. The sources of VOM emissions from pneumatic rubber tire manufacture, in decreasing order of emissions, are under- tread cementing, green tire spraying, tread end cementing, bead dipping and tire building. The first four manufactur- ing processes contribute 75 to 85 percent of VOM emissions (Illinois EPA, 1980i). Incineration or carbon adsorption 87 TABLE 3.22 TOTAL CONTROL COSTS, EMISSION REDUCTIONS AND COST EFFECTIVENESS OF RACT II FOR PERCHLOROETHYLENE DRY CLEANERS IN ILLINOIS Attainment Nonattainment Counties Counties Capital Cost (Thousand $) 602.3 2,141.4 Annual Cost (Thousand $) 45.8 71.8 VOM Emission Reduction (Tons/year) 514.3 1,615.0 Cost Effectiveness (Annual $ Cost/ton) 89.1 44.5 Sources: Tables 3.20 and 3.21. can be used to control emissions from these processes, and water-based spray can be used to control green tire spray emissions . Three manufacturers of pneumatic rubber tires in Illi- nois have been identified as being affected by RACT II (U.S EPA, 1978f and Illinois EPA, 1980i) and all are located in attainment counties. Table 3.2? lists the affected plants. 88 their location by city and county, and estimates of employ- ment . The applicable RACT II controls, shown in Table 3.24, are unique for the three firms. Firestone Company must con- trol emissions from their manual undertread cementing pro- cess, and Kelly-Springfield has agreed to control emissions from manual undertread cementing and green tire painting (Herringshaw, 1980). Table 3.25 presents the control costs for the affected processes at a model plant manufacturing 16,000 tires per day. The actual average for the plants in Illinois is 15,333 passenger tires per day (Illinois EPA, 1980i). Annual costs include capital charges, operation, mainte- nance, and solvent recovery credits. Table 3.26 presents the estimated costs of proposed RACT II regulations for the two affected pneumatic rubber tire manufacturers in Illinois. Total capital costs are $.9 million and annual costs are $.5 million. RACT II emission reductions for Lhe two firms in Illinois are estimated by Illinois EPA to be 1,490 tons per year for the three affected operations shown in Table 3.24 (Illinois EPA, 1980i). This gives an overall cost effectiveness of $357.5 per ton VOM emissions controlled. This figure is higher than U.S. EPA estimates of cost effectiveness shown in Table 3.25 since Illinois plants use less solvent per tire than 89 TABLE 3.2 3 INFORMATION ON PNEUMATIC RUBBER TIRE PLANTS IN ILLINOIS Firm City County Employment Firestone Tire & Rubber Decatur Macon 2500 General Tire & Rubber Mt . Vernon Jefferson (a) Kelly-Springfield Tire Freeport Stephenson 1500 (a) Not available. Sources: Illinois EPA, "Technical Support Document for RACT II: Pneumatic Rubber Tire Manufacture," Air Quality Plan- ning Section, Springfield, Illinois, May 1980i. Manufacturers' News, Inc.' Illinois Manufacturers Direc - tory, Chicago, 1980. 90 TABLE 3.24 INFORMATION ON PNEUMATIC RUBBER TIRE MANUFACTURING PROCESSES AFFECTED BY PROPOSED RACT II REGULATIONS Process Tread End Bead Under Tread Green Tire Firm Cementing Dipping Cementing Spraying General Tire Exempt Exempt Currently Currently no emissions water-based Firestone Exempt Currently Affected Currently no emissions water-based Kelly- Springfield Exempt Exempt Affected Affected Sources: Illinois EPA, "Technical Support Document for RACT II: Pneumatic Rubber Tire Manufacture," Air Quality Plan- ning Section, Springfield, Illinois, May 1980i. John Reed, Illinois EPA, Testimony Before Illinois Pollu- tion Control Board, R80-5, November 6, 1980. 91 TABLE 3.2 5 COSTS OF RACT II CONTROLS FOR MODEL PNEUMATIC RUBBER TIRE MANUFACTURING PROCESSES Carbon Adsorption Water-based for Undertread Green Tire Item Cementing Spray Capital Cost (Thousand $) 418.2 18.5 Annual Cost * (Thousand $) 190.7 151.3 Cost Effectivness (Annual $ Cost/ton) 312.4 236.2 Based on solvent recovery at fuel value. Source: U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires, Research Triangle Park, N.C., December 1978f. 92 TABLE 3.2 6 TOTAL CONTROL COSTS, EMISSION REDUCTIONS AND COST EFFECTIVENESS OF RACT II FOR PNEUMATIC RUBBER TIRE MANUFACTURERS IN ILLINOIS Attainment Item Counties Capital Cost (Thousand $) 854.9 Annual Cost (Thousand $) 532.7 VOM Emission Reduction (Tons/year) 1,490.0 Cost Effectiveness (Annual $ Cost/ton) 357.5 Sources: Tables 3.24 and 3.25. 93 reported in the U.S. EPA document for manual tread end cementing and green tire spraying (Lawrence, 1980; Reed, 1980; Burkett, 1980). 3.1.8 Direct Cost Estimate Ranges The estimated direct costs of RACT II above are pre- sented as the best estimates available. In view of uncer- tainties alternate estimates were developed also and are considered in this section. One consideration affecting the costs is the number of firms that will be subject to RACT II controls. This con- sideration is of importance in surface coating because of the large number of firms involved. In addition to the problem of identification, there is uncertainty in the num- ber of plants exempted from the proposals. Plants may be exempted because they do not exceed emission thresholds and, possibly, because of granting of petitions for individual exemptions. 3.1.8.1 Rotogravure and Flexography The cost estimates for rotogravure and flexographic printers are sensitive to the size of printing unit and to the VOM concentration in the emission stream. If a small size model plant is used an estimated annual cost of $.8 million is obtained, compared to the estimate of $2.3 mil- lion given in Section 3.1.1. On the other hand, according ■94 to U.S. EPA, if the VOM concentration is increased to 500 parts per million in the emission stream, the annual cost is $8.0 million for the 4 plants in Illinois. If RACT II is required only in nonattainment areas rather than statewide, costs may be higher in the printing industry. Illinois EPA has testified (Reed, 1980) that three additional firms, all located in nonattainment coun- ties, (Bee Coated Film, Bagcraft Corp. of America, and International Paper Co.) would be affected since the U.S. EPA requires that States achieve at least 95 percent of potential RACT II emission reductions in an affected indus- try (Federal Register, 1979, p. 38597). Lustour Corporation is the only affected printing firm located in an attainment county and would not be required to implement RACT II if the rule were changed. However, uncontrolled emissions at Bee Coated, Bagcraft and International Paper are currently 38 percent greater than those at Lustour Corporation (Illinois EPA, 1980e). Estimated total costs for the state would thus increase by 33 percent of Lustour 's estimated costs of implementing RACT II. The additional capital cost would be $.8 million and the increase in annual cost would be $.5 million . 95 3.1.8.2 Petroleum Refining Leaks The annual cost of controlling leaking components esti- mated in Section 3.1.2 includes the purchase of two monitor- ing instruments and directed maintenance, which is estimated to double monitoring costs. If 4 monitoring instruments are required and if monitoring labor costs are higher than esti- mated, the annual costs could be as much as $3.1 million. A low estimate, based on the purchase of one monitor instru- ment and without directed maintenance, is $1.8 million. Even for the high estimate, the annual control costs are not sufficient to offset the petroleum saving, so that the esti- mated net cost of RACT II for this category remains zero. 3.1.8.3 Surface Coating of Metal Products The estimated control costs for surface coating of metal products given in Section 3.1.3 are based on 7 percent of the sources adding incineration units and 93 percent con- verting to high solids or water-borne coatings. This proce- dure was chosen as reasonable in light of testimony given by Mr. Frank Graziano of the Chemical Coaters Association (see Section 3.1.3). The annual cost, if all firms instead of 93 percent switch to compliance coatings, is $21.1 million. A high estimate is based on another issue developed in testimony, namely, the possible lack of availability of com- pliance high solids coatings for heavy equipment manufactur- ers (3.5 pounds of VOM per gallon of coating). Mr. Steven 96 Look of Caterpillar Tractor stated in testimony in June 1980 that no air dry topcoats with 3.5 pounds of VOM per gallon of coating have been found which display satisfactory dry time, film thickness and other properties (Look, 1980). Caterpillar Company suggested 4.3 pounds per gallon coatings as the minimum reasonably available control by 1986. Mr. William McGehee of Fiat-Allis also expressed reservations concerning the availability of high solids coatings for large construction equipment by 1982 (McGehee, 1981). However, on December 17, 1980 Messrs. John Lowe and Michael Paparone of DuPont Inc., which supplies chemical coatings, testified that a 3.5 pounds per gallon high solids coating for farm implements has been production tested and is commercially available starting in January 1981. This product is not suitable for all coaters because of tempera- ture restrictions and plant-specific restrictions. Control costs would be higher in the case where particular plants were unable to convert to high solids compliance coatings and required ddd-on technology or incurred noncompliance penalties. If the nonavailability of compliance coatings caused an additional 3 percent of the affected firms to install thermal incineration units or other equally expen- sive control devices, the annual cost for surface coaters in Illinois would be $39.2 million. 97 Mr. Ralph Groteleuschen of the Environmental Control Department of Deere & Company has provided estimates of the cost of implementing RACT II at the John Deere Harvester Works. The costs are based on a least cost approach to meeting RACT II requirements (Groteleuschen, 1981). The capital costs include equipment, conveyor, and building costs of adding on incineration and washer systems for 12 coating systems. The annual costs include energy costs for added washer stages and incineration, additional chemical costs for washers, additional paint material costs and maintenance. Transfer efficiency was expected to remain the same. Average emission rates were 5.00 and 6.77 pounds of VOM per gallon of solids for water-borne and medium solids paints, respectively. Total estimated capital costs are $3.8 million, and annual costs are $2.4 million, both in 1981 dollars. The cost estimates are based on a compliance date of December 1986, and are expected to be higher to meet the Illinois EPA proposed compliance date of December 31, 1982. Total VOM reductions were estimated to be 1,000 tons (Groteleuschen, 1981). RCF estimates of capital costs for this plant are $.9 million using the procedure given in Sec- tion 3.1.3. However, this cost does not include the cost of washer systems, which would be $3.1 million according to Deere & Company estimates. The annual cost calculation would be raised using the Section 3.1.3 procedure from $.5 98 to $1 million for Deere & Co. if this modification is included. The calculation gives some idea of the effect on costs of considerations not included in the estimates of Section 3.1.3. On the other hand, the modification may not be applicable to smaller operations. 3.1.8.4 Storage Tanks with Floating Covers The costs of controlling emissions from external float- ing roof tanks can vary with the cost of secondary seals. The cost used in this analysis, $64.4 per linear foot of circumference, is taken from the Control Technique Guideline document (U.S. EPA, 1978i). An alternate cost estimate of $39.6 per linear foot is given in the preliminary U.S. EPA new source performance standards (U.S. EPA, 1980), which would reduce annual costs from $2.4 million to $1.7 million. As a high estimate, if individual retrofit circumstances raised the costs to $100 per linear foot, the annual cost would be $3.4 million, which is still not high enough to offset the petroleum savings from adopting the controls. 3.1.8.5 Synthesized Pharmaceuticals The annual cost estimate for manufacturers of synthe- sized pharmaceuticals, $2.4 million, is based on the mid- point of control costs in the U.S. EPA guideline document (U.S. EPA, 1978g). The range of EPA control costs is from $.6 to $12.2 million. 99 3.1.8.6 Perchloroethylene Dry Cleaning The annual cost estimate for dry cleaners varies with the amount and market price of captured reusable solvents. If the solvent credit is doubled the estimated annual cost falls to -$.3 million. The annual cost is $.2 million if the solvent credit is halved. 3.1.8.7 Pneumatic Rubber Tire Making For the undertread cementing process, the EPA cost estimates are given for three cases: no recovery credit, recovery credit at fuel value, and recovery credit at market value. The corresponding annual cost estimates are $.4 mil- lion, $.5 million and $.6 million, respectively. 3.2 Indirect Effects of RACT II Principal indirect effects of RACT II include increases in prices, increased unemployment and loss of population affecting costs of government in Illinois. The present sec- tion presents estimates of indirect effects and the monetary costs associated with them. 100 3.2.1 Changes in the Illinois Economy 3.2.1.1 Prices in Industries Required to Adopt Controls The extent to which prices would rise in industries required to adopt RACT II controls depends on how great the increase in costs relative to value of output is in the affected industries, and it also depends on supply and demand conditions. The third column of Table 3.27 gives control costs as a percent of the value of shipments in each of the industries that would be required to adopt controls, obtained by expressing the first column as a percent of the second column in the table. As can be seen, control costs as a percent of value of shipments range from zero in the petroleum industry, where petroleum savings exceed control costs, to almost .2 of one percent in rotogravure and flex- ography . The fourth column of Table 3.27 gives the estimated percentage change in price of outputs for each industry, obtained using the formula for percentage rise in price given in Appendix Section C.3. The percentage rise in price gives the portion of the column three rise in costs which is borne by customers. The percentage rise in price ranges from zero in petroleum to nearly .1 of one percent in roto- gravure and flexography. 101 TABLE 3.2 7 ESTIMATED PRICE CHANGES FROM RACT II IN ILLINOIS RACT II Category (a) Annual Cost of Controls (Million $) (b) I llinois Value of Shipments (Million $) (c) Cost as Percent of Shipments Rotogravure and Flexography 2.3 1,227.5 .18 Petroleum Refining Leaks and Storage Tanks with Floating Covers 0.0 8,727.4 (e) .00 Surface Coating of Metal Products 32.9 62,133.6 .05 Synethesized Pharmaceuticals 2.4 1,435.5 .17 Perchloroethylene Dry Cleaners 0.1 301.4 (f) .04 Pneumatic Rubber Tire Making 0.5 626.1 .09 (Table continued on following page) 102 TABLE 3.27 (Continued) ESTIMATED PRICE CHANGES FROM RACT II IN ILLINOIS Footnotes (a) These figures are from Tables 3.5, 3.8, 3.12, 3.15, 3.19, 3.22, and 3.26. (b) Sources: U.S. Department of Commerce, Bureau of the Census, Census of Manufactures: 1977, Preliminary Reports, Washington, D.C., 1978b. U.S. Department of Commerce, Bureau of the Census, Cen - sus of Service Industries, Washington, D.C., 1978c. (c) Column one as a percent of column two. (d) Explained in Appendix Section C.3. (e) The value of shipments from SIC 2911 is used for these categories . (f) Total receipts are used in place of value of shipments 103 3.2.1.2 Employment Estimates of effects of RACT II on employment in Illi- nois are needed as a basis for obtaining unemployment and population loss effects. The effects on employment were calculated starting with (a) estimates of effects on output in industries required to adopt RACT II controls, following the method in Appendix Section C.3, and (b) estimates of increases in pollution control related investment in Illi- nois that would take place as a result of RACT II. These estimates were used as inputs to the Illinois input-output model as explained in Appendix Section C.4 to arrive at changes in total output and employment in Illinois. Different estimates are obtained for the years 1982 and 1983 than for 1984 and beyond because the increase in pollu- tion control related investment would last only until all the pollution control equipment was installed. Different estimates are also obtained depending on ranges in supply and demand conditions in industries adopting controls, as explained in Appendix Section C.3. As shown in Table 3.28, the low estimate gives an increase in both output and employment in 1982 and 1983. This result is due to the increase in investment in pollu- tion control equipment occuring in the first two years of controls. In the high estimate case the declines in output and employment from higher industry costs are larger than 104 TABLE 3.28 IMPACT OF RACT II ON OUTPUT AND EMPLOYMENT IN ILLINOIS High Estimate Low Estimate 1982- 1984 1982- 1984 Item 1983 and 1983 and Beyond Beyond Output (Million $) -36.6 -78.4 22.8 -13.0 Employment -630.0 -884.0 521.0 -253.0 Source: Illinois Bureau of the Budget, "The Illinois Out- put, Employment and Wage Impacts of RACT II in Illinois," Office of Planning, Springfield, Illinois, March 1981. the increases due to added investment in pollution control equipment. After the investment period has ended employment and output fall below the initial levels for both cases. Averaging the high and low estimates, a medium estimate is that employment will be reduced by 54 persons in 1982 and 1983 and by 569 persons in 1984 and beyond. 105 3.2.1.3 Unemployment and Population The employment impacts in Section 3.2.1.2 are expected to affect unemployment and migration patterns as follows. In the low estimate case the short term increase in employment in the 1982-83 time period is not estimated to affect migration patterns nor to affect population. Unem- ployment is actually estimated to decline as a result of the increase in employment, with some of the additional employ- ees being drawn from the unemployed and others being drawn into the labor force who would not otherwise be looking for a job. The estimate used in this study is that every two new short term employment positions cause unemployment to fall by one person. The effect on unemployment and population is more com- plicated in the case of employment declines, which take place in the high estimate for 1982 and 1983 and in both the high and the low estimates for 1984 and beyond. The initial impact of a decline in employment is to increase the number of unemployed workers. The number of these unemployed work- ers who remain unemployed is projected to decline by one half each year. Unemployment declines each year after the initial increase because people find jobs, emigrate or leave the labor force. Table 3.29 shows the changes in unemployment and popu- lation for 14 years after controls are implemented. The 106 TABLE 3.2 9 IMPACT OF RACT II ON UNEMPLOYMENT AND EMIGRATION IN ILLINOIS High Estimates Low Estimates Year Unemployment Emigration Unemployment Emigration 1982 630 1983 315 315 1984 1,042 158 1985 521 521 1986 260 260 1987 130 130 1988 65 65 1989 33 33 1990 17 17 1991 8 8 1992 4 4 1993 2 2 1994 1 1 1995 260 260 253 126 126 63 63 32 32 16 16 8 8 4 4 2 2 1 1 Source: See the discussion in the text. 107 change in population is based on an average of three persons in each emigrating family. Summing the migration over all years, the total change in population is 1,514 persons for the high estimate and 252 persons for the low estimate. For both the high and low estimates, the unemployment effect reaches a high in 1984, in which year the range is 253 to 1,042 persons unemployed. 3.2.1.4 Energy Impact of RACT II Many of the control techniques required by the proposed RACT II rules will alter a firm's energy consumption. The cumulative effect of higher or lower energy consumption in affected industries may have an impact on total Illinois energy needs. The following paragraphs summarize the dis- cussion of energy effects given in the U.S EPA Control Tech- nique Guideline documents for each affected industry. The incineration and carbon adsorption units used to control emissions from printing units require additional fuel to operate. In addition, steam is required to strip the carbon bed of solvent. The energy impact can be reduced by effective heat recovery systems on pebble bed incinera- tors (U.S. EPA, 1978e). The energy requirement for monitoring instruments and repair of leaking refinery components "will be more than offset by energy savings realized through product recovery" (U.S. EPA, 1978c). 108 Conversion to high solids and water-borne coatings will generally reduce the energy requirements of oven drying for surface coaters. Despite efficiency advantages, energy use for electrodeposition systems may be 3 times more than for water-borne flow or dip coating operations, and the "energy required to operate a carbon adsorption system is a poten- tial disadvantage" (U.S. EPA, 1978d). The energy impact of incineration depends on the amount of primary heat recovery and the reuse of secondary heat recovery. Some plants may actually reduce overall fuel consumption (U.S. EPA, 1978d). The energy impact of controlling VOM emissions from external floating roof tanks is not discussed in the Control Technique Guideline document for this industry. The petro- leum savings from reduced emissions discussed in Section 3.1.4 will have a positive impact on energy supplies in I llinois. The energy impact of RACT II for synthesized pharmaceu- tical manufacturers is primarily due to the operation of condensers anu scrubbers. Energy is used to power the pumps, cooling system and blower (U.S. EPA, 1978g). Carbon adsorption also requires increased fuel consumption to oper- ate. According to Abbott Laboratories, the increased elec- trical costs of refrigeration account for 20 percent ($120,000/$600,000) of annual operating costs (Schwarz, 1980). 109 Carbon adsorbers are also an applicable control tech- nology for dry cleaners. The dry cleaning plant will have increased energy consumption. However, the recovery and reuse of solvents will reduce the demand for solvents and cause an energy savings to solvent producers. The U.S. EPA estimates a net energy savings from this process (U.S. EPA, 1978h) . The control of VOM emissions from rubber tire manufac- ture by carbon adsorption and incineration requires increased energy use. However, in the case of incineration heat recovery can offset the increased energy use. Further- more, carbon adsorption allows reuse of water immiscible solvents which represents a savings (U.S. EPA, 1978f). 3.2.2 Monetary Values Associated with Indirect Effects of RACT II m Illinois In this section, estimates are presented of the mone- tary values associated with the unemployment and population changes that were developed in Sections 3.2.1.2 and 3.2.1.3, Estimates of the monetary value of the energy impacts dis- cussed in Section 3.2.1.4 are not made since they are already included as part of the direct costs of control. Similarly, the price increases estimated in Section 3.2.1.1 do not enter the indirect costs. The price increases serve to show how the direct costs are distributed between custom- ers and producers but do not add any additional costs above the direct costs. 110 The costs of unemployment include the output lost per unemployed worker as well as retraining and relocation costs associated with the change in employment. Unemployment com- pensation payments provide a measure of the monetary value associated with unemployment. While unemployment compensa- tion understates the output that workers would produce if employed, to provide an accurate estimate the unemployment compensation needs only to be equal to what workers would earn if employed less the value they place on the increase in time spent outside of formal labor force activities. Average weekly unemployment compensation in Illinois is $132.74. An individual worker is eligible for 39 weeks of benefits. With workers constantly entering and leaving unemployed status, the monetary value is estimated to be applicable to all members of the unemployed group at any time. The monetary value each year for a member of the unemployed group is $6,902.48. Outmigration is estimated to reduce government revenues by more than government costs, with the result that the costs of government are raised for the residents remaining in Illinois. State and local government revenue receipts in Illinois are $662 per capita, which is an estimate of the amount by which government revenues would be reduced for every person who emigrates. Some government service costs which are person related would be reduced in proportion to 111 the population, but other costs connected with provision of basic physical facilities such as roads would decline little if at all. Each emigrant is estimated to reduce the cost of government by only half of state disbursements per capita or $333.50, leaving $328.50 in increased annual costs for the remaining residents. In contrast to the unemployment costs which gradually decline as unemployed workers find other pursuits in or out of the state, the increase in cost of government is permanent and reoccurs each year after emigra- tion. The present value of the increased costs per emi- grant, using a 10 percent discount rate, is $3,285. The unemployment and emigration estimates shown in Table 3.29 are multiplied by the costs developed above, dis- counted, and summed to obtain the present value of the indi- rect costs. The present value is then annualized to give a value comparable to the direct costs and benefits. The high estimate of the unemployment costs on an annual basis is $1.57 million, and the low estimate is $.23 million. The high estimate of costs due to emigration is $.39 million, and the low estimate is $.2 million. The total of the high estimates of the two types of indirect costs is $1.9 million, and the low estimate is $.4 million. The best estimate of total indirect costs is con- sidered to be the average of the high and low estimates, or $1.1 million . 112 3 . 3 Summary Estimates of direct costs and indirect effects in the Illinois economy of implementing the proposed RACT II regu- lations have been presented in this chapter. Estimates of VOM emission reductions were also obtained and were used in Chapter 2. Table 3.30 summarizes the direct costs and emissions reductions expected for each of the seven RACT II catego- ries. Cost ranges for the RACT II categories in Section 3.1.8 suggested amounts by which costs could be different for the estimates considered most likely.. In distinction to the most likely direct annual cost for the state of $38.3 million, if the high estimates for each category are added, the annual direct costs are $60.2 million, and they are $22.6 million if the low estimates are added. It is unlikely that all of the high or low conditions would occur together . The range in direct cost is importantly affected by conditions in surface coating, which constitutes the largest element in direct cost. The low estimate is low primarily because the 7 percent of sources estimated under the most likely conditions to adopt incineration instead are assumed to switch to low VOM coatings. The high estimate is made high, importantly, because 3 percent additional surface coating sources are equipped with incinerators and because the high estimate of synthesized pharmaceutical controls, 113 'I TABLE 3.30 CAPITAL COSTS, ANNUAL COSTS, AND EMISSION REDUCTIONS IN INDUSTRIES REQUIRED TO ADOPT RACT II CONTROLS RACT II Category Capital Annual Emission Cost Cost Reduction (Thousand $) (Thousand $) (Tons/yr) Rotogravure and Flexography 10,062.6 2,258.0 19,350.0 Petroleum Refining Leaks Surface Coating of Metal Products 100.8 0.0 31,056.0 I 84,518.1 32,894.6 25,374.3 Storage Tanks With Floating Covers 10,320.0 0.0 12,084.7 Synthesized Pharmaceut icals 2,903.0 2,448.0 302.5 Perchloroethylene Dry Cleaners 2,743.7 117.6 2,129.3 Pneumatic Rubber Tire Making State of Illinois 854.9 532.7 1,490.0 111,503.1 38,250.9 91,786.8 Sources: Tables 3.5, 3.8, 3.12, 3.15, 3.19, 3.22, and 3.26. 114 taken from the U.S. EPA Guideline document, reflects the existence of a wide range of costs for this category. The most likely estimates of direct costs shown in Table 3.30 are in the middle of the ranges. The most likely estimate of direct cost for the state is $38.3 million annu- ally. While not shown in the table, costs were calculated separately for nonattainment and attainment areas. The annual costs are $27.4 million for nonattainment areas and $10.9 million for attainment areas. The indirect effects considered included price rises, unemployment and population losses. The most likely esti- mate is that producers and consumers would share equally in bearing the direct costs of RACT II and that price rises would vary from zero in the petroleum industry to .2 of one percent in flexography and rotogravure. In the most likely estimates unemployment due to RACT II would rise to 648 per- sons in 1984 and then be gradually reduced. Some of the unemployed people and their families would migrate resulting in an eventual loss of population from Illinois of 883 per- sons in the most likely estimate. The monetary value associated with the unemployment was estimated to be $.9 million on an annual basis. The popula- tion losses would reduce government revenues more than costs and increase the burden of government on those remaining in the state by an estimated $.2 million per year, giving a 115 total of indirect costs of RACT II for the state of $1.1 million annually. If the indirect costs are allocated on the basis of population, the indirect costs would be $.9 million in non- attainment areas and $.2 million in attainment areas. 116 4. BENEFICIAL EFFECTS OF REDUCED OZONE CONCENTRATIONS This chapter is concerned with the effects of ozone on health, vegetation and materials. Estimates are developed of the beneficial effects of reduced ozone that would result from adopting the proposed RACT II regulations in Illinois. Where possible, monetary values associated with the benefi- cial effects are considered. Section 4.1 evaluates the various kinds of available evidence on health effects of ozone and presents estimates of the improvements that would result from RACT II. Section 4.2 concerns vegetation. It deals with the major affected crops in Illinois, which are corn, soybeans, wheat and oats. Studies of ozone damage to crops are reviewed, and estimates of reduced crop damage following adoption of RACT II are obtained. Section 4.3 concerns damages to materials. Estimates of damage reductions are derived for classes of materials particularly sensitive to ozone, including elastomers, tex- tiles and paints. The results of the chapter are summarized in Section 4.4. 117 4 . 1 Human Health Toxological, clinical and epidemiological studies throwing light on the effects of ozone on human health are considered in Sections 4.1.1 to 4.1.3. In Section 4.1.4, a quantitative approach adapted from previous studies is used to estimate health symptom benefits from RACT II in Illi- nois, in view of the ozone reductions and numbers of people who would be affected in different parts of the state. 4.1.1 Toxicological Evidence There is a consensus that ozone concentrations above one part per million have deleterious effects on health. The issue of relevance in the present study is whether there are significant effects in the lower ambient ozone ranges which are observed in practice. For instance, the highest concentration reported in Illinois for the years 1977, 1978 and 1979, as reported in Table 2.1, is .26 parts per mil- lion. Chapter 8 of the U.S. EPA's criteria document on ozone (U.S. EPA, 1978a, pp. 137-183) lists 218 studies which have directly or indirectly been concerned with toxological effects of ozone concentrations as studied in animal experi- ments. Of 146 results of animal experiments tabulated, 58 results - 40 percent of the total - pertained to ozone con- centrations of less than .50 parts per million, and 38 118 results - 26 percent of the total - pertained to concentra- tions of .25 parts per million or less, which would be in the range observed in Illinois. Among the effects indicated by the animal experiments are alterations in host defense mechanisms, changes in pul- monary and extrapulmonary functions, and morphological and biochemical changes in the lungs and other organs. Ozone is suspected as a mutagenic agent, causing breaks in chromo- somes and delaying cell mitosis. There is some evidence that ozone may act synergist ically with other environmental factors such as dietary levels of Vitamin E or the presence of other pollutants. 4.1.2 Clinical Evidence The U.S. EPA's criteria document on ozone lists 67 stu- dies related to occupational exposure and human experiments (U.S. EPA, 1978a, pp. 184-199). Of results tabulated from 21 studies, 8 results were for ozone concentrations of .5 parts per million or less, and 5 were for concentrations of less than .25 parts per million. There were 10 experimental studies reported, in which the average number of subjects was 6 persons. A number of other studies are reported in the text of the document. The most reliably established effects of ozone are sub- jective complaints pertaining particularly to irritation of eyes. Beyond eye irritation, subjective complaints pertain 119 to nose, throat and mucous membranes, coughing, chest con- striction, headache, detection of odor, substernal soreness and drowsiness. These symptoms are reported in some cases for concentrations of ozone as low as .10 and .15 parts per million (U.S. EPA, 1978a, p. 8) In distinction to the subjective complaints, objective measurements of effects of ozone in human subjects, such as on pulmonary function, have been difficult to detect. While blood changes have been detected, they have not been related to disease (U.S. EPA, 1978a, p. 9). 4.1.3 Epidemiological Evidence The assessment of 67 studies related to epidemiology in the U.S. EPA's criteria document on ozone (U.S. EPA, 1978a, pp. 200-252) verifies the temporary symptoms associated with ozone found in the clinical studies. No mortality effects or permanent health effects have been established in the epidemiological studies, although the data are difficult to interpret. As stated in the summary (p. 9), a review "of existing studies shows no consistent association between daily oxi- dant concentrations and daily mortality rates." Regarding effects of long-term exposure, the criteria document states (pp. 9-10): 120 Mahoney has observed an association between broad patterns of oxidant distribution and annual respiratory disease mortality in the Los Angeles area. However, no convincing association between lung cancer mortality and oxidant exposure has been shown. In some studies, a limited association between the frequency of chronic obstructive lung disease and oxidant exposure has been observed. In other studies, however, no such associa- tion has been apparent. No relationship between long- term oxidant exposure and acute respiratory disease incidence or change in lung function has been observed, though neither of these areas has been extensively investigated. Most available epidemiologic studies of long-term oxidant exposure are difficult to interpret . . . Thus human studies cannot yet provide the environmental decision-maker with concrete information as to the effects of long-term oxidant exposures on public health. 4.1.4 Health Effects of RACT II in Illinois Two quantitative studies which are broadly consistent with the foregoing toxicological , clinical and epidemiologi- cal evidence on ozone contain results that can be used to estimate health effects of ozone in Illinois. The first is an epidemiological study conducted by Hammer et al. (1974). The Hammer study developed dose response threshold functions for 4 types o£ health symptoms related to ozone: chest dis- comfort, cough, eye discomfort and headache. The functions were estimated by relating self-reported symptoms of student nurses to reported ozone levels in Los Angeles. To apply these results in the investigation of health effects in Illinois, ozone data from U.S. EPA's Air Quality Data - 1977 Annual Statistics were first used to determine 121 the number of person-days of ozone concentrations above the estimated threshold values in Illinois in 1977. The U.S. EPA air quality data are given in percentiles, that is the percentage of observations (hourly average ozone concentra- tions) above specified ozone levels. These data were used to estimate the percentage of hours above the threshold value for each type of health symptom, and subsequently con- verted to days in order to be compatible with the Hammer et al. dose response functions. The threshold values for chest discomfort and cough without fever, .30 and .27 parts per million, respectively, indicate that no ozone related person-days for these symp- toms occurred in Illinois in 1977. However, a significant number of hours were above the threshold for eye discomfort (.15 parts per million) and for headaches without fever (.05 parts per million). The percentage change in ozone concentration for each of the areas in Illinois from 1977 to 1982 after allowing for federal motor vehicle controls and RACT I, as developed in Chapter 2, were applied to the 1977 percentiles to esti- mate hours above the threshold in 1982 before RACT II. The ozone changes due to RACT II developed in Chapter 2 were similarly used to estimate hours above the threshold in 1982 after RACT II. The coefficients from the Hammer et al. study were then applied to estimate symptoms before and after RACT II . 122 The analysis was performed for 5 urban areas in Illinois and for the rest of the state in both attainment and nonattainment . The results for eye discomfort and head- aches are shown in Table 4.1. The first column is the num- ber of person-days of ozone related eye discomfort before implementation of RACT II. The second column is the change in person-days of eye discomfort after RACT II ozone reduc- tions. The third and fourth columns give the data for head- aches (without fever). The reductions in person-days of headaches is smaller than the reductions in eye discomfort because the dose response function is steeper in the range of ozone concentrations reported in Illinois. Consequently, most of the benefits are due to less eye discomfort even though fewer persons experience this discomfort than head- aches. The second quantitative study which can be used to estimate health effects in Illinois is Gillette's national health cost study on ozone (1974). Gillette obtained opin- ions of medical and air pollution experts on the severity of symptoms and on the proportion of population that would be affected at various ozone levels. The resulting response functions were used in conjunction with population figures and frequencies of ozone concentrations to estimate national damages from ozone and the benefits at the national level from a 20 percent reduction in ozone. Gillette estimated 123 TABLE 4.1 OZONE RELATED HEALTH SYMPTOM PERSON-DAYS IN ILLINOIS BEFORE RACT II AND CHANGES DUE TO RACT II (Thousands of Person-Days) 1982 Change in Ozone Ozone 1982 Change in Related Related Ozone Ozone Eye Eye Related Related Discomfort Discomfort Headaches Headaches Before Due to Before Due to RACT II RACT II RACT II RACT II Nonattainment Chicago (a) 786.5 140.4 13,946.1 80.9 St. Louis (b) 35.9 5.2 1,673.8 8.1 Peoria (c) - - 401.6 0.4 Rest of Non- attainment (d) 63.6 0.7 2,471.1 13.6 Attainment Rockford (e) Rock Island (f) Rest of Attain- ment (g) I llinois 886.0 146.3 416.9 191.3 3,901.8 23,002.6 0.8 0.2 12.2 116.2 (Table continued on following page) 124 TABLE 4.1 (Continued) OZONE RELATED HEALTH SYMPTOM PERSON-DAYS IN ILLINOIS BEFORE RACT II AND CHANGES DUE TO RACT II (Thousands of Person-Days) Footnotes (a) Cook, Du Page, Kane, Lake, McHenry and Will counties. The monitor data used for this area are from the Calumet City and Chicago Heights monitors. (b) Madison and St. Clair counties. The monitor data are for Wood River. (c) Peoria and Tazewell counties. The monitor data are for Peoria . (d) Adams, Boone, De Kalb, Grundy, Kankakee, Kendall, La Salle, Monroe, Sangamon, Williamson counties. The moni- tor data are for Kankakee. (e) Winnebago county. The monitor data are for Rockford. (f) Rock Island county. The monitor data are for Rock Island. (g) Rest of the counties in Illinois. The monitor data are for Champaign. Sources: Adapted from Hammer, D.I. et al., "Los Angeles Student Nurse Study," Arch. Environ. Health, Volume 28, May 1974. Also see the discussion in the text. 125 that the health damages from ozone in the United States in 1973 were $183 million and that the benefits of a nation- wide 20 percent reduction in ozone would be $131 million (1973 dollars). Threshold levels for the adverse effects of photochemical oxidants on human health as reported by Gil- lette are given in Table 4.2. The overall threshold level of ozone in his dose response function is .05 parts per mil- lion . Gillette's dose response function is (p. 330): In Y = A + B ln(X - .05) (4.1) where Y = Health costs in dollars per person-hour of exposure to ozone A = Health costs at the threshold level not attributable to oxidants B = Elasticity of the health costs with respect to the excess of ozone over the threshold level, where ozone is measured in parts per million Health costs at the threshold level A in this study were taken to be $43.84, which is obtained by inflating the 1973 value used by Gillette to the 1980 level, using the price index given in Appendix Table C.l. The elasticity of health costs with respect to ozone above the threshold is estimated by Gillette to be 3.9675. Using Gillette's method, the 126 TABLE 4.2 ESTIMATED EXPOSURE THRESHOLDS FOR ADVERSE EFFECTS OF PHOTOCHEMICAL OXIDANTS Threshold Effect (Parts per Reference million ) Headaches without fever 0.05 Hammer, 1974 Irritation of eyes 0.10 to 0.15 Hammer, 1974 Decreased cardio- pulmonary reserve (Healthy adult) 0.12 to 0.51 Wayne, 1957 Aggravation of Brinkman et certain anemias 0.20 to 0.25 al., 1964 Aggravation of Schoettlin et asthma 0.25 al., 1961 Aggravation of chronic lung Remmers and disease 0.25 Balchum, 1965 Irritation of res- piratory tract Klemfield et (Healthy adult) 0.25 to 0.30 (a) al., 1957 Increased suscepti- bility to acute respiratory dis- Coffin et al., ease 0.08 (b) 1968 (Table continued on following page) 127 TABLE 4.2 (Continued) ESTIMATED EXPOSURE THRESHOLDS FOR ADVERSE EFFECTS OF PHOTOCHEMICAL OXIDANTS Effect Threshold (Parts per million ) Reference Impaired fetal survival Risk of mutations Decreased visual acuity 0.10 to 0.20 0.20 to 0.30 0.20 to 0.50 Br inkman et al . , 1964 Zelac et al . , 1971 Lagerwerf f , 1973 (a) Involves exposures of three to seven hours daily for several weeks. (b) Based solely on animal experiments involving exposures of three to seven hours daily for several weeks. Source: Gillette, D.G., "Ambient Oxidant Exposure and Health Costs in the United States - 1973," Journal of the Air Pollution Control Association, Vol. 27, No. T~, April 1977, p. 330. 128 health cost indicated by the dose response function is mul- tiplied by the number of hours at each ozone level, and the results are added to obtain annual per capita health costs. This result in turn is multiplied by population in each area to arrive at total health costs. Gillette's work permits estimates of the monetary value of the health benefits of ozone reduction. In order to use Gillette's method, the number of hours at various ozone lev- els above the estimated threshold of .05 parts per million are needed. These data are given for each monitor in Illi- nois in the U.S. EPA's Air Quality Data - 1977 Annual Sta - tistics which was used in Section 4.1.3 above. The number of hours at various ozone levels above the threshold were estimated using the data from the monitor in each area hav- ing the maximum number of hours above the threshold of .05 parts per million. To convert from 1977 to 1982 values before RACT II, each 1977 ozone level was reduced by the projected percen- tage reduction in ozone due to the federal motor vehicle control program and RACT I after allowing for 1977 to 1982 growth, using EKMA for the three major urban areas and roll- back for the remaining areas of the state, as described in Section 2.4.2 above. The various ozone levels after RACT II were estimated by reducing the 1982 before RACT II ozone levels by the percentage reductions in ozone due to RACT II as given in column 2 of Table 2.4. 129 Using Gillette's method, the total health costs were then computed for each area in Illinois, before and after RACT II. Health benefits were computed as the difference between health costs before and after RACT II. The per per- son and total health damage reductions that would result from RACT II for areas of Illinois as well as for the entire state are given in Table 4.3. For the state as a whole, the annual amount of benefits is 6.5 cents per person, giving a total of $725.8 thousand in annual reductions in health costs. The health effects estimated to this point do not include any effects from reduced risk of mortality, since as mentioned earlier no relation between ozone and mortality in the observed range of exposure has been established. How- ever, in order to determine an upper bound of the benefits to human health in Illinois from RACT II ozone reductions, an estimate was made, allowing for the possible existence of a mortality effect. The possible mortality effect, expressed as the number of lives saved, was computed by mul- tiplying the elasticity of mortality with respect to'air pollution times the percent of ozone in air pollution, times the reduction in ozone from RACT II, times the total number of deaths in Illinois. This procedure should give a high estimate since other pollutants than ozone have better established relationships to mortality (Freeman, 1979). 130 TABLE 4.3 MONETARY VALUE OF HEALTH SYMPTOM IMPROVEMENTS FROM RACT II IN ILLINOIS Total Health Health Benefits Benefits for Area per Person Area (Dollars) (Thousands of dollars) Nonattainment Areas Chicago (a) .024 170.6 St. Louis (b) .315 164.1 Peoria (c) .004 1.4 Rest of Nonattainment Counties (d) .545 372.4 Attainment Areas Rockford (e) .008 2.0 Rock Island (f) .014 2.3 Rest of Attainment Counties (g) .006 13.0 State of Illinois .065 725.8 (Table continued on following page 131 (a (b (d (e (f (g TABLE 4.3 (Continued) MONETARY VALUE OF HEALTH SYMPTOM IMPROVEMENTS FROM RACT II IN ILLINOIS Footnotes Cook, Du Page, Kane, Lake, McHenry and Will counties. The monitor data used for this area are from the Calumet City monitor. Madison and St. Clair counties. The monitor data are for Wood River. Peoria and Tazewell counties. The monitor data are for Peoria . Adams, Boone, De Kalb, Grundy, Kankakee, Kendall, La Salle, Monroe, Sangamon, Williamson counties. The moni- tor data are for Kankakee. Winnebago county. The monitor data are for Rockford. Rock Island county. The monitor data are for Rock I sland. Rest of the counties in Illinois. The monitor data are for Champaign. Source: See discussion in text. 132 Freeman (1979) estimates an elasticity of mortality with respect to total pollution of .05. Data from the Calu- met City monitoring station for 1977 indicate that ozone constitutes 1 percent of 5 criteria pollutants (carbon monoxide, sulfur dioxide, nitrogen oxide, particulate and ozone) expressed in annual average micrograms per cubic meter. The overall reduction in ozone from RACT II is 7.5 percent (see Table 2.4). Finally, the total number of deaths in Illinois in 1977 was 103,000 (U.S. Department of Commerce, 1979b). Multiplying these values gives an expected reduction in lives lost due to RACT II of 4 lives. A possible value of reduced mortality is $1.2 million per life expected to be saved (Smith, 1974), which is the upper bound used by Crocker et al. (1978), and which is also used by Freeman (1979). This value is "representative of those individuals' willingness to pay for reduced mortality based upon observations of individual behavior with respect to risk of death. This value of statistical life is sub- stantially Higher than . . . values based on productivity . . ." (Freeman, 1979, p. 66). It should be noted that the measure is applicable to small changes in risk and not to certainty of death. For instance, the value of reducing the risk of death by 1 percent would be estimated as 1 percent of $1.2 million or $120,000 per person. In the present case, the possible change in the death rate in Illinois is 133 much smaller, going from 9.1649 per 1,000 persons to 9.1546 per 1,000 persons due to RACT II. A monetary value of the possible RACT II mortality effect is thus estimated to be $4.8 million. Adding this result to the medium estimate obtained above of $725.8 thou- sand associated with health symptoms, gives a high estimate of annual monetary value of health effects of $5.5 million from RACT II in Illinois. 4 . 2 Vegetation Illinois is a major producer of agricultural products, some of which are sensitive to ozone. Section 4.2.1 dis- cusses the important ozone-sensitive crops in Illinois and their responses to ozone. Section 4.2.2 develops an esti- mate of the reduced vegetation damage from RACT II in Illi- nois . 4.2.1 Effects of Ozone on Vegetation Ozone primarily affects the foliage of plants by modi- fying amino acids, proteins, unsaturated fatty acids and sulfhydryl residues. These effects can inhibit photosynthe- sis and cause reduced plant growth, yield and quality. The following hierarchy of plant responses are induced by ozone (U.S. EPA, 1978a): 134 biochemical and cellular changes reduced photosynthesis; increased membrane permeability; production of stress ethylene altered enzyme activities, metabolic pools and translocation. reduced plant growth and yield; altered product quality; loss of plant vigor-. changes in plant communities and ecosystems. The rate of photosynthesis is an indicator of plant vigor, and decreases in this rate occur at low doses of ozone (.6 parts per million and lower, U.S. EPA, 1978a, p. 255). Furthermore, the distribution of products of photo- synthesis in plants can also be altered by ozone. For exam- ple, ozone apparently causes sugar retention in foliage, preventing translocation of carbohydrates to the roots. This effect in turn causes reduced nitrogen fixation and plant growth. The process of nitrogen fixation is a factor in the impact of oxidants on the plant community/ecosystem complex (U.S. EPA, 1978a). Ozone may prevent nodulation in the roots of soybeans, and the total biomass and agricul- tural yield may be affected, especially in areas with low nitrogen content in the soil. Ozone can also act to disrupt normal cell processes and cell structure. An initial plant response to ozone is the 135 loss of salt and water from the cell interior, a phenomenon which causes plasmolysis or shrinking of the cytoplasm away from the, cell membrane. For most plants, ozone has been observed to have the greatest effect on the more mature tissues. The maximum sensitivity of soybeans, for example, has been found when the leaves are from 60 to 80 percent expanded. Also, plants appear generally more sensitive to ozone damage during the periods of rapid growth. Many other factors affect the res- ponse of plants to ozone. Table 4.4 gives a partial list of these interacting determinants of plant response to ozone. Not all plants affected by ozone contribute to economic loss. Plant injury is defined as any identifiable and mea- surable response to air pollution, while plant damage is any measurable adverse effect on the desired or intended use of the plant (NRC, 1977). Some visible or physiologic res- ponses to ozone do not necessarily alter the plant's eco- nomic value. Illinois accounted for 14.5 percent ($6.8 billion/$46 . 7 billion) of the value of production in the United States in 1980 of corn, soybeans, wheat and oats (U.S. Department of Agriculture, 1981). The major agricultural benefits of reduced ozone are reductions in damage and adverse physical effects in these crops. Table 4.5 summarizes results of several studies of the effects of controlled ozone exposure 136 TABLE 4.4 DETERMINANTS OF PLANT RESPONSE TO OZONE Category Contributing Factors POLLUTANT CONCENTRATION Ozone, SOx, NOx Number of Exposures Duration of Exposures CLIMATIC CONDITIONS Light Quality and Intensity Relative Humidity Carbon Dioxide Barometric Pressure; Precipitation SOIL CONDITIONS Moisture Salinity Soil Minerals BIOTIC GENETIC - Infection by Pathogens Resistance Mutagenic STAGE OF DEVEi^CPMENT - Physiological Maturity Source: U.S. EPA, Air Quality Criteria for Ozone and Other Photochemical Oxidants, EPA-600/8-78-004 , Research Trian- gle Park, N.C., April 1978a. 137 TABLE 4.5 EFFECTS OF LONG-TERM OZONE EXPOSURE ON GROWTH, YIELD AND FOLIAR INJURY TO CORN, SOYBEANS, OATS AND WHEAT • Ozone Plant Concentration Exposure Plant Response Souri Species (Parts per Time (% Reduction Ket Million) From Control) Sweet Corn, Cultivar Jubilee .20 3 hr/da,3 da/wk 13, kernel dry wt (a Cultivar Midget .05 6 hr/da,64 da 9, kernel dry wt (b Wheat, ; Cultivar .20 4 hr/da,7 da 30, yield (el Arthur 71 Soybean .05 8 hr/da,15 da 13, yield (d Soybean .10 8 hr/da,15 da 9, root dry wt (d Soybean , Cultivar Dare .05 6 hr/da,133 da 19, 0, in;]ury yield (e Cultivar Dare .10 6 hr/da,133 da 37, 0, in3ury yield (e Source: Taken from U.S. EPA, Air Quality Criteria for Ozone and Other Photochemical Oxidants, EPA-600/8-78-004 , Research Trian(t Park, N.C., April 1978a, pp. 262-3. (a) Oshima, R.J., "Effect of Ozone on a Commercial Sweet Corn Variety," Plant Dis. Rep. 57:719-723, 1973. (b) Heagle, A.S. et al., "Effect of Ozone on Yield of Sweet Corn," Phytopathology 52:683-687, 1972. (c) Kochhar, M. , "Phytotoxic and Competitive Effects of Tall Fc cue on Ladino Clover as Modified by Ozone and/or Rhizoctonia Solani", Ph.D. Thesis, North Carolina State University, Raleigl N.C., 1974. (d) Tingley, D.T. et al., "Stress Ethylene Envolution: A Measui of Ozone Effects on Plants", Atmos. Environ. 10:969-974, 1976. (e) Heagle, A.S. et al., "Injury and Yield Responses of Soybear to Chronic Doses of Ozone and Sulfur Dioxide in the Field," Phj topathology 64:132-136, 1974. 138 on growth, yield and foliar injury to several types of corn, wheat and soybeans. Among the results shown in the table, the response of corn, expressed as the change in kernel dry weight, ranges from 9 percent for an ozone exposure of .05 parts per million to 13 percent for an ozone exposure of .20 parts per million. A .20 parts per million ozone. exposure results in a 30 percent reduction of wheat yield (cultivar Arthur 71). The response of soybeans to ozone ranges from 3 to 55 percent of seed yield. 4.2.2 Vegetation Effects of RACT II in Illinois More complete data on ozone concentrations, exposure , times and plant responses would be needed to construct threshold dose response or damage functions relating crop yields to ozone concentrations. In the absence of these functions, it is possible to use estimates that have been made of total economic crop loss caused by oxidant pollu- tion. Available estimates are summarized in Table 4.6 which gives dollar losses of crops due to oxidants for various geographic areas. The table also gives dollars per farm resident of each area. The average for all the areas in Table 4.6 is a crop loss due to oxidants of $66.36 per farm resident. If the average loss per farm resident applies to Illinois, then multiplying by the Illinois farm population of 473,000 (Census, 1979) gives a total crop loss in Illi- nois from oxidant pollution of $31.4 million per year. 139 TABLE 4.6 PLANT LOSSES FROM OXIDANT AIR POLLUTANTS Area Per 1970 Farm (Millions Resident Source ear 1980 $) (1980 $) Comments Key United States 1963 306.9 164.0 California 1963 85.2 1970 34.7 Pennsylvania 1963 15.9 1969 20.0 1970 0.1 New Jersey 1971 1.8 1972 0.1 New England 1971 2.1 31. .60 Commercial Crops & Ornamental (a) 16, .90 Commercial Crops (a) 342, .17 Commercial Crops & Ornamental (a) 139, .36 Commercial Crops (b) 55. .99 Commercial Crops & Ornamental (a) 20. .42 Includes Indirect Costs (c) 0. .35 Includes Indirect Costs (d) 38. ,30 Commercial Crops (e) 2. .13 Commercial Crops (f) 16. .41 Commercial Crops & Ornamental (g) Sources: Taken from National Research Council, Ozone and Other Photochemical Oxidants, National Academy of Sci- ences, Washington, B.C., 1977, U.S. Department of Commerce, Bureau of the Census, Statis - tical Abstract of the United States; 1979, 10th Edition, Washington, D.C., 1979b. (Table continued on following page) 140 TABLE 4.6 (Continued) PLANT LOSSES FROM OXIDANT AIR POLLUTANTS Footnotes (a) Benedict, H. M, et al., Economic Impact of Air Pollu - tants on Plants in the United States, APTD-0953, U.S. EPA, Research Triangle Park, N.C., November 1971. (b) Millecan, A. A., A Survey and Assessment of Air Pollu - tion Damage to California Vegetation in 1970, APTD-0694, U.S. EPA, Air Pollution Control Office, Research Trian- gle Park, N.C., June 1971. (c) Lacasse, N. L. and Weidensaul, J. A., "A Cooperative Extension-Based System of Assessing Air Pollution Damage to Vegetation" in Proceedings of the Second Interna - tional Clean Air Congress, H. M. Englund and W. T. Beery, eds.. Academic Press, Inc., New York, 1971. (d) Lacasse, N. L. , "Assessment of Air Pollution Damage to Vegetation in Pennsylvania, CAES Publication No. 209-71, Pennsylvania State University, Center for Air Environ- ment Studies, University Park, Pa., 1971. (e) Feliciano, A tion Damage U. S. EPA, Resea . , 1971 Survey and Assessment of Air Pollu - te Vegetation in New Jersey, EPA-R5-72-010 , esearch Triangle Park, N.C., October 1972. (f) Pell, E. J., 1972 Survey and Assessment of Air Pollution Damage to Vegetation in New Jersey, EPA-R5-73-022 , U.S. EPA, Research Triangle Park, N.C., June 1973. (g) Naegele, J. A., et al.. Assessment of Air Pollut io n Dam - age to Vegetation in New England: July 1971 - July 1972, EPA-R5-72-009, U.S. EPA, Research Triangle Park, N.C., August 1972. 141 An estimate of the reduction in losses due to the implementation of RACT II may be obtained using a propor- tional relationship between ambient ozone concentrations and crop damages. The reductions in losses are estimated by multiplying the damages from oxidant air pollution derived above by the percentage reduction in ambient ozone concen- trations given in Table 2.4. The results of these calcula- tions are shown in Table 4.7. The total benefits to vegeta- tion are $1.4 million. This is .02 percent of the 1977 value of production in Illinois of soybeans, corn, wheat and oats. Attainment counties receive 67 percent of the bene- fits, and nonattainment counties receive 33 percent.^ An analysis was performed to determine the sensitivity of the benefit estimates. The average vegetation damage of $66.36 per farm resident from Table 4.6 was reconstructed by eliminating the two lowest estimates ($0.35 and $2.13) and by eliminating the two highest ($139.36 and $342.17). The result is a low average of $22.76 and a high average of $82.64 per farm resident, giving a low estimate of reduced vegetation damage from RACT II of $.5 million in Illinois and a high estimate of $1.7 million. ' The total vegetation benefits of $1.4 million were allo- cated on the basis of the number of farms reported in the 1978 Census of Agriculture since the farm population was not available by county. 142 TABLE 4.7 ECONOMIC BENEFITS OF RACT II FROM REDUCED VEGETATION DAMAGE IN ILLINOIS (Thousands of Dollars) Economic Benefits From Reduced Area Vegetation Damage Nonattainment Counties Chicago (a) 135.3 St. Louis (b) 110.3 Peoria (c) 17.2 Rest of Nonattainment counties (d) 193.0 Attainment Counties Rockford (e) 9.0 Rock Island (f) 4.1 Rest of Attainment Counties 917.0 State of Illinois 1,386.0 (Table continued on following page) 143 TABLE 4.7 (Continued) ECONOMIC BENEFITS OF RACT II FROM REDUCED VEGETATION DAMAGE IN ILLINOIS (Thousands of Dollars) Footnotes (a) Cook, Du Page, Kane, Lake, McHenry and Will counties. (b) Madison and St. Clair counties. (c) Peoria and Tazewell counties. (d) Adams, Boone, De Kalb, Grundy, Kankakee, Kendall, La Salle, Monroe, Sangamon, Williamson counties. (e) Winnebago county. (f) Rock Island county. Sources: U.S. Department of Commerce, Bureau of the Census, 1978 Census of Agriculture, Preliminary Reports, Washing- ton D.C. , 1979a. Also see the discussion in the text. The economic bene- fits are calculated after accounting for possible ozone reductions from RACT I and the federal motor vehicle con- trol programs. 144 4.3 Materials 4.3.1 Effects of Ozone on Materials Ozone causes damage to many types of organic materials, including elastomers, paint, textile dyes and fibers. Ozone increases the rigidity of some elastomers, and causes brit- tleness, cracking and reduced elasticity. According to the U.S. EPA, "the most vulnerable compounds are natural rubber and synthetic polymers ... [which] account for about 75 per- cent of the annual production value in the United States" (U.S. EPA, 1978a). Except for natural rubber the major use for these elastomers is in tires. They have some resistance to ozone, but special formulations which increase production costs are usually required to achieve satisfactory service lives. In sensitive elastomers, tension and/or stress is necessary for the occurrence of ozone cracking. The cracks develop at right angles to the direction of stress. Experi- ments have shown that sensitive elastomers, under strain as little as 2 to 3 percent and exposed to only .01 parts per million ozone, will develop cracks. This cracking necessi- tates replacing rubber products earlier than the normal wear life. As a consequence of ozone damage, some elastomers are coated with antiozone additives which provide a protective film that inhibits cracking. However, antiozone additives increase the cost of the finished nroduct, and their useful- 145 ness is temporary since reaction with atmospheric ozone eventually causes the protection to become inactive. Ozone has an effect on several types of textiles. Laboratory and field tests indicate that ozone causes color fading of dyes and, to a lesser extent, the weakening of cotton and synthetic fibers. The fading phenomenon associ- ated with ozone was first noticed on fabrics using disperse dyes (which are used to prevent streaks). Fading is primar- ily observed on two types of textile materials: polyester and cotton permanent press fabrics, and nylon carpets. Dur- ing the curing operation for polyester fibers, some disperse dyes migrate to the permanent press finish where fading by air contaminants can easily occur. For example, the folds and edges on trousers may fade after 10 days of storage in warehouses and retail outlets. Ozone fading in nylon car- pets occurs chiefly in warm, humid areas, in many cases after only 30 days of exposure. The problem of fading can be avoided by using ozone resistant dyes and by using nylon fibers modified by dry-heat texturing. Laboratory and field test results indicate that ozone also causes damage to paint by increasing the erosion of the surface of the paint film. Laboratory tests have been per- formed on at least four types of coatings: house paints, coil coating finishes, automotive refinishes, and industrial maintenance coatings. Coated panels, exposed to increasing 146 doses of ozone (up to 1 parts per million), demonstrate sta- tistically significant increases in erosion rates (U.S. EPA, 1978a). Oil based house paints experience the greatest increase in erosion rates followed by industrial maintenance coatings, latex and coil coatings, and automotive refin- ishes. 4.3.2 Materials Effects of RACT II in Illinois The benefits of RACT II from reduced materials damages were estimated in this study for elastomers, textiles and industrial paints. As noted above, these materials have been identified by the U.S. EPA as being sensitive to ozone (U.S. EPA, 1978a, pp. 329-340). Dose response functions developed by U.S. EPA (Ibid) that relate annual average ozone concentration to economic loss were used to evaluate the benefits of RACT II. The annual average ozone concen- trations required in the dose response functions were com- puted from the 1977 annual averages of monitor data reported by the U.S, EPA (U.S. EPA, 1978a, pp. 190, 198). The geome- tric mean of the reported averages is 20.95 micrograms per cubic meter. The estimated percentage reduction in the sec- ond highest one-hour ozone level (see Table 2.1) was multi- plied by the annual average, giving a reduction of 2.25 micrograms per cubic meter. The per capita reduction in elastomer costs due to a change in annual average ozone levels is 147 $1.31 / 03 where 03 is the annual average ozone concentration expressed in micrograms per cubic meter. This dose response is der- ived by taking the derivative of equation 13-5 (U.S. EPA, 1978a, p. 333) and converting to 1980 dollars. Note that a minus sign should proceed the 1 in equation 13-5. The per capita benefit is $0.14 for a 2.25 microgram per cubic meter reduction . The per capita reduction in textile costs is given by $0.38 / 03 where 03 is again the annual average ozone concentration before RACT II. This dose response function is obtained by differentiating equation 13-15 (U.S. EPA, 1978a, p. 337) with respect to 03 and converting to 1980 dollars. The per capita benefit is $0,041 for a 2.25 microgram per cubic meter reduction. Letting ** refer to the exponentiation operation, per capita industrial maintenance and vinyl paint costs due to ozone are given by [.0000001(O3)**2 + .0001(03) + .04] / {[1 + .01(03)] [1 + .001(O3)]}**2 where 03 is the annual average average ozone concentration in micrograms oer cubic meter. This loss function is 148 obtained by adding equations 13-20 and 13-21 (U.S. EPA, 1978a, p. 340) and taking the derivative with respect to 03. The loss function, evaluated using the before and after RACT II annual average ozone concentrations, gives a per capita benefit estimate of $0,098 per unit of ozone. The per capita economic loss functions developed above for elastomers, textiles and paints were used to estimate the benefits of less damage to materials from RACT II ozone reductions. Using the reductions in ozone estimated in Sec- tion 2.4, the per capita reductions in losses due to RACT II were estimated for each of the materials. The per capita benefits were then multiplied by the population in each area. Table 4.8 summarizes the results and gives the esti- mated benefits for the five urban areas and for the rest of the nonattainment and attainment areas in Illinois. The total economic benefits to materials from RACT II are $2.8 million for the State of Illinois. An alternative estimate of materials damage reductions was obtained by drawing on a national study carried out by the Midwest Research Institute in 1970 (U.S. EPA, 1978a). The value of production, economic life of materials, instal- lation cost and sensitivity to ozone were used to estimate ozone induced damages to paint, wood, cotton, synthetic fibers and elastomers. These national estimates, which reflect the total damage to these materials from ozone, were 149 TABLE 4.8 ECONOMIC BENEFITS OF RACT II FROM REDUCED MATERIALS DAMAGE IN ILLINOIS Total Materials Materials Benefits Benefits Area per Person for Area ($) (Thousands $) Nonattainment Areas Chicago (a) .31 2,191.0 St. Louis (b) .38 198.5 Peoria (c) .08 25.0 Rest of Nonattainment Counties (d) .17 112.8 Attainment Areas Rockford (e) . .10 23.0 Rock Island (f) .05 7.8 Rest of Attainment Counties .12 262.1 State of Illinois .25 2,820.2 Source: See the discussion in the text (Table continued on following page) 150 TABLE 4.8 (Continued) ECONOMIC BENEFITS OF RACT II FROM REDUCED MATERIALS DAMAGE IN ILLINOIS Footnotes (a) Cook, Du Page, Kane, Lake, McHenry and Will counties. The annual average concentration used for this area is from the Chicago Heights monitor. • (b) Madison and St. Clair counties. The annual average con- centration is for East St. Louis. (c) Peoria and Tazewell counties. The annual average con- centration is the same as for St. Louis. (d) Adams, Boone, De Kalb, Grundy, Kankakee, Kendall, La Salle, Monroe, Sangamon, Williamson counties. The annual average concentration is for Quincy. (e) Winnebago county. The annual average concentration is for Rockford. (f) Rock Island county. The annual average concentration is the same as for Rockford. (g) Rest of the counties in Illinois. The annual average concentration is the same as for Rockford. 151 adapted to Illinois based on the Illinois share of the value of production of these materials. The resulting estimate of ozone damages in Illinois was multiplied by the weighted average ozone reduction in the state from RACT II of 7.5 percent as calculated from Table 2.4, to arrive at estimated materials benefits from RACT II of $4.5 million for the state, which is higher than the benefits reported in Table 4.8 but still of the same general order of magnitude. 4 . 4 Summary of Physical and Monetary Effects and Benef its The effects of ozone reductions due to RACT II on health, vegetation and materials were analyzed in this chap- ter . The toxicological , clinical and epidemiological evi- dence of the effects of ozone on human health were reviewed, Ozone has been found to cause irritation of the eyes, nose, throat and mucous membranes. The evidence is ambiguous as to whether there are permanent effects or whether mortality is caused at levels of exposure observed in Illinois. Drawing on results of a study by Hammer et al. (1974), it was estimated that the number of ozone related person- days of eye discomfort in Illinois would be reduced by 146 thousand per year due to RACT II. It was estimated that 152 person-days of ozone related headaches would be reduced by 116 thousand per year. A dose response function developed by Gillette (1974) was used to estimate the monetary value of the health bene- fits in Illinois. The annual monetary value associated with reduced health symptoms was estimated to be $725.8 thousand for the State of Illinois, with $17.3 thousand of the total being in attainment counties and $708.5 thousand in nonat- tainment counties of Illinois. While mortality effects of ozone have not been estab- lished, a high estimate of possible mortality reductions was developed indicating a maximum reduction of deaths in Illi- nois of 4 per year. The high estimate of the monetary value associated with health effects is $5.5 million. The effects of ozone on vegetation were investigated. Ozone has been observed to reduce the rate of photosynthe- sis, cause sugar retention in foliage, reduce nitrogen fixa- tion, and prevent root nodulation. In order to estimate the benefits of reuuced ozone to vegetation, several national and regional studies were assessed. The annual benefit of reduced vegetation damage from RACT II was estimated to be $1.4 million in Illinois, with $.9 million of the benefits occuring in attainment counties and $.5 million in nonat- tainment counties. A range was developed, leading to a high estimate of total Illinois vegetation benefits of $1.7 mil- lion. 153 The effects of ozone on three particularly sensitive materials, elastomers, textiles and paint, were analyzed. Ozone can cause increased rigidity in some elastomers, which in turn causes brittleness, cracking and reduced elasticity. Antiozonants are used to coat elastomers, thus adding to costs. Ozone also can cause fading of dyes and the weaken- ing of synthetic and cottcTi fibers. A further effect is to erode paints. Dose response functions for the materials from a U.S. EPA study were used to estimate benefits from ozone reduc- tion. The total reduction in damage due to RACT II in Illi- nois for these three types of materials was estimated to be $2.8 million annually, of which $.3 million would be in attainment counties and $2.5 million would be in nonattain- ment counties. Based on another study, a high estimate of materials damages in Illinois of $4.3 million was obtained. Low estimates of the monetary values associated with the materials benefits, or other types of benefits, were not developed, as they would be similar to the medium estimates. 154 5. CONCLUSIONS This chapter summarizes and draws conclusions from the previous chapters on air quality impacts, costs and benefi- cial effects of the proposed RACT II regulations. 5.1 Air Quality Impacts of RACT II Estimates of the air quality impacts of RACT II were developed in Chapter 2. The state was divided into seven areas for purposes of this analysis. Three of the areas are the Chicago, St. Louis and Peoria areas, which have been designated by Illinois EPA to be in nonattainment of the federal ozone standard specifying that an hourly average ozone concentration of .12 parts per million not be exceeded more than once per year. The remaining counties of the state designated as being in nonattainment were considered together as a fourth area. The three additional areaG into which the state was divided consist of groups of attainment counties. These areas are the Rockford area, the Rock Island area and the rest of the counties of the state as a group, which are designated as either being in attainment or are unclassified and are all considered by Illinois EPA to be in attainment. 155 The effects of RACT II on the second highest ozone readings in these seven areas, based on 1977 to 1979 monitor data, were estimated by applying projected emission reduc- tions to two types of air quality models. The Empirical Kinetic Modeling Approach (EKMA) was applied to the Chicago, St. louis and Peoria areas, and rollback was applied to the other areas of the state. The air quality models were first used to project 1982 ambient ozone after allowing for reduc- tions due to the federal motor vehicle control program and RACT I, but not RACT II. Then 1982 ozone concentrations after introducing RACT II were projected. The results of the air quality analysis were summarized in Table 2.4 of Chapter 2. The results indicate that, with federal motor vehicle controls and RACT I, but without RACT II, the Chicago and St. Louis areas will remain in nonattainment in 1982 with projected second highest one-hour ozone levels of .18 and .15 parts per million, respectively. The Peoria area and the rest of the state in nonattainment in 1977 are projected to be brought into attainment without RACT II, although the projected .117 parts per million for the rest of the state in nonattainment in 1977, being close to the standard, sug- gests that some of the 10 counties in this group might pos- sibly remain in nonattainment. 156 The reductions in second highest one-hour ozone level due to RACT II were projected to be 12.2 percent for the Chicago area and 14.7 percent for the St. Louis area. The projected reductions due to RACT II in these two areas are not sufficient to bring them into attainment. The reductions in ozone level projected for the areas of the state other than the Chicago and St. Louis areas were smaller and ranged from 1.9 to 5.8 percent. None of the reductions outside the Chicago and St. Louis areas affect projected attainment status since all the other areas are projected to be in attainment in 1982 without RACT II. 5.2 Costs of RACT II Direct and indirect effects of implementing RACT II in Illinois were estimated in Chapter 3. Direct effects include costs borne by firms directly affected by RACT II and consist of the estimated costs of control technology, periodic monitoring and maintenance programs, and altered production techniques and material inputs. Indirect effects include changes in prices, increases in unemployment and loss of population. 157 5.2.1 Direct Costs of RACT II The direct costs of RACT II were estimated using infor- mation from U.S. EPA, Illinois EPA, individual firms, indus- try associations, solvent suppliers and control equipment manufacturers. All costs are given in 1980 dollars. The control technologies applicable to rotogravure and flexographic printing are carbon adsorption, incineration, and conversion to water-borne inks. The estimated annual costs for this industry are $2.3 million. If a smaller model plant is used, a low estimate of annual cost is $.8 million. A high estimate, based on a higher concentration of volatile organic materials in the emission stream, is $8.0 million . For petroleum refinery leaks, the applicable control method is a program of periodic monitoring and maintenance of leaking components. The annual cost of monitor instru- ments and labor is estimated to be $2.2 million for the nine affected refineries in Illinois. If the amounts of required monitor instruments and labor are varied, the low estimate is $1.8 million and the high estimate is $3.1 million. A wide variety of control techniques are applicable to surface coating of metal parts and products including carbon adsorption, incineration, electrodeposit ion and conversion to compliance coatings. The annual costs for this category are estimated to be $32.9 million and are based on seven 158 percent of the affected sources being retrofitted with ther- mal incineration units and the rest converting to high sol- ids or water-borne coatings depending on the type of paint system. If all sources were converted to the use of compli- ance coatings, the annual costs would be $21.1 million. The low estimate would result if two chemicals, currently nonex- empt from RACT II, were exempted. If compliance coatings are not readily available by 1982, a high estimate of annual costs is $39.2 million, based on an additional three percent of affected sources being retrofitted with incinerators. The control technology for external floating roof tanks is a rim-mounted secondary seal. Annual costs are estimated to be $2.4 million, but this is offset by the petroleum sav- ings with the secondary seal. Low and high estimates were calculated using alternative estimates of the cost of insta''ling the secondary seal and are $1.7 million and $17.1 million, respectively. The latter estimate of costs would not be entirely offset by the petroleum savings. The applicable control technologies for synthesized pharmaceutical manufacturing sources are carbon adsorbers, condensers and scrubbers. Annual costs in Illinois are estimated to be $2.4 million, based on medium size emission sources. By varying the size of emission sources a low estimate is $.6 million and a high estimate is $12.2 mil- lion. 159 Control techniques for perchloroethylene dry cleaners include carbon adsorption, incineration, good housekeeping practices and visual inspection of leaks. The estimated annual cost of these controls in affected firms in Illinois is $.1 million and includes credits for the reuse of solvent recovered by carbon adsorption. Based on possible variation in the amount and market price of reusable solvent, the low estimate of annual cost is -$.3 million and the high esti- mate is $.2 million. Incineration, carbon adsorption and water-based sprays can be used to control emissions from pneumatic rubber tire manufacturing processes. The estimated annual costs to this industry, based on solvent recovery at fuel value, are $.5 million. A low estimate based on no solvent recovery is $.4 million, and a high estimate based on recovery at market value is $.6 million. The medium estimate of direct costs that have been given totalling over all industries is $38.3 million per year. These figures refer to annual costs, which consist of yearly operations costs, with capital costs spread over the useful life of the control equipment. The adoption of RACT II controls will in some cases require initial capital out- lays, which may be deemed important if firms would have to finance them or forego other capital expenditures. The total estimated capital costs are $111.5 million in Illi- 160 nois. The capital costs range from $.1 million for refiner- ies with leaking components to $84.5 million for surface coaters of metal products. 5.2.2 Indirect Costs of RACT II To estimate indirect effects, price and output changes in the directly affected industries induced by higher annual costs were first estimated using an economic supply-demand model which is described in Appendix C.3. The effects of RACT II on employment were estimated by tracing the employ- ment impact of these changes throughout the Illinois economy using the Illinois input-output model. The employment impacts will in turn affect unemploy- ment, migration patterns and the cost of government. The low estimate is that the number of unemployed persons actu- ally decreases somewhat during the first two years (1982 and 1983) since the investment in pollution control equipment outweighs higher costs in the directly affected industries. Beyond the first two years, after the investment in pollution control equipment has taken place, some workers and their families will migrate out of Illinois, and others will remain unemployed for various periods of time. Eventu- ally, a point will be reached where all of the displaced workers have either migrated or found other employment in Illinois. The average of the high and low estimates of the eventual decrease in ponulation is 883 persons. The maximum 161 unemployment effect is reached in 1984, in which year the average estimate is that 648 persons would be unemployed as a result of RACT II. The number of unemployed persons is projected to gradually decline after 1984. The annualized cost of the increased unemployment com- pensation payments, which are spread over several years, is estimated to be $.9 million. The annualized value of the increases in costs of government to persons remaining in Illinois as a result of the loss in population is $.2 mil- lion per year. 5.2.3 Total Costs of RACT II A summary of costs is shown in Table 5.1, which gives direct costs by industry and also gives the breakdown of indirect costs between unemployment costs and increased costs of providing government services. Costs by nonattainment and attainment areas are not shown in the table, but were estimated. The direct costs for the state of $38.3 million per year consist of $27.4 million in nonattainment areas and $10.8 million in attain- ment areas. The indirect costs for the state of $1.2 mil- lion per year consist of $.9 million in nonattainment areas and $.2 million in attainment areas. 162 TABLE 5.1 DIRECT AND INDIRECT COSTS OF RACT II IN ILLINOIS (Thousands of Dollars) Item Annual Cost Direct Costs Rotogravure and Flexography 2,258.0 Petroleum Refining Leaks 0.0 Surface Coating of Metal Products 32,894.6 Storage Tanks with Floating Covers 0.0 Synthesized Pharmaceuticals 2,448.0 Perchloroethylene Dry Cleaners 117.6 Pneumatic Rubber Tire Making 532.7 Total Direct Costs for the State 38,250.9 Indirect Costs Unemployment 900.1 Cost of Government 202.9 Total Indirect Costs for the State 1,103.0 Sources: Direct costs are from Table 3.30. Indirect costs are from Section 3.2. 163 5.3 Beneficial Effects of RACT II Estimates pertaining to the beneficial effects of RACT II were developed in Chapter 4. 5.3.1 Health Effects Studies were evaluated that relate ozone exposure to various health effects. Based on an analysis by Hammer et al. (1974), the number of ozone related person-days of eye discomfort and headaches before and after RACT II were esti- mated. The results for nonattainment and attainment areas are given in Table 5.2. The results indicate a reduction in the state of 146.3 thousand person-days per year of ozone related eye discomfort and 116.2 thousand person-days of ozone related headaches. All of the effects except 13.2 thousand person-days of ozone related headaches are in non- attainment areas of the state. Because an association has not definitely been estab- lished between human mortality and ambient ozone levels, a mortality effect from RACT II cannot be reliably estimated. An upper bound estimate of the possible mortality effect if it existed can be obtained by assuming that ozone contri- butes to mortality in proportion to the amount of ozone in total air pollution. This assumption will provide an upper bound since more definite evidence exists that there are relationships between other pollutants and mortality than it 164 TABLE 5.2 OZONE RELATED HEALTH SYMPTOM PERSON-DAYS IN ILLINOIS BEFORE RACT II AND CHANGES DUE TO RACT II (Thousands of Person-Days) 1982 Change in Ozone Ozone 1982 Change in Related Related Ozone Ozone Eye Eye Related Related Discomfort Discomfort Headaches Headaches Before Due to Before Due to Area RACT II RACT II RACT II RACT II Nonattainment 886.0 146.3 18,492.6 103.0 Attainment - - 4,510.0 13.2 Illinois 886.0 146.3 23,002.6 116.2 Source: Table 4.1. does for ozone (Freeman, 1979). Under the assumption given, the death rate in Illinois would be reduced by RACT II frorr. 9.1649 per 1,000 population to 9.1646 per 1,000, leading to a possible expectation of 4 fewer deaths per year in the State of Illinois. A dose response function developed by Gillette was used to estimate the possible monetary values associated with the 165 morbidity or health symptom effects from RACT II. The esti- mates are $.7 million in nonattainment areas and $.02 mil- lion in attainment areas, or a total of $.72 million for the state. If the assumption were used that RACT II would have mortality benefits and if each life saved were valued at $1.2 million the annual monetary value of the health bene- fits could be raised from $.7 million to $5.5 million. 5.3.2 Vegetation Benefits Illinois is a major producer of four crops, soybeans, corn, wheat and oats, which may be sensitive to ozone. The average value of crop damages per farm resident for ten stu- dies estimating ozone damages on farms was used to estimate the monetary value of vegetation benefits from RACT II in Illinois. The estimated total benefit is $1.4 million, $.5 million in nonattainment areas and $.9 million in attainment areas. A high estimate, calculated by using just the eight studies with the highest monetary values per farm resident, is $1.7 million . 5.3.3 Materials Benefits Three organic materials which are sensitive to ozone, elastomers, textiles and paints, were considered in estimat- ing reductions in damages to materials that would result from RACT II. Dose response functions from the U.S. EPA's criteria document (U.S. EPA, 1978a) for ozone were used to 166 estimate damage reductions from RACT II connected with these materials. For nonattainment areas the estimated damage reduction is $2.5 million and for attainment areas the esti- mate is $.3 million, giving a total for Illinois of $2.8 million. A high estimate, based on an earlier study by the Midwest Research Institute (1970), is $4.5 million for the state. 5.3.4 Summary of Beneficial Effects of RACT II In summary, the morbidity effects of RACT II are esti- mated to result in 146.3 thousand fewer person-days per year of ozone related eye discomfort and 116.2 thousand person- days of ozone related headaches in Illinois. While it is not clear that a mortality effect exists, an upper bound estimate of a possible effect is that RACT II would result in 4 fewer expected deaths in Illinois per year. The monetary value associated with the morbidity effects is estimated to be $.72 million per year for the state. If the mortality effect were assumed to exist, the monetary value associated with health effects would be raised to $5.5 million. The medium estimate of the reduction in crop damages that would result from RACT II is $1.4 million annually for the state, and for materials damage reduction it is $2.8 million. Adding the monetary value associated with the mor- ibidty affects to the vegetation and materials damage reduc- 167 tions gives a most likely estimate of the monetary value associated with the beneficial effects of RACT II of $4.9 million annually for the state, with $3.7 million in nonat- tainment areas and $1.2 in attainment areas. Low estimates would be similar to the most likely esti- mates and were not explicitly developed. Using the high estimates for health, vegetation and materials leads to a high estimate of the monetary value associated with the benefits of $11.7 million per year for the state, of which $10.0 million occurs in nonattainment areas and $1.7 million occurs in attainment areas. The high estimates of total monetary value are more than double the most likely esti- mates primarily because of the range estimated for health effects . The most likely monetary values are summarized in Table 5.3. 168 TABLE 5.3 MONETARY VALUES ASSOCIATED WITH BENEFITS OF RACT II IN ILLINOIS (Thousands of Dollars) Benefit Attainment Nonattainment Category Counties Counties Human Health 17.3 708.5 Vegetation 930.2 455.8 Materials 292.9 2,527.3 State of Illinois 1,240.4 3,691.6 Sources: See the discussion in Sections 4.1.4, 4.2.2 and 4.3.2. 169 REFERENCES Berhma, T. , Illinois EPA, Testimony Before Illinois Pollu- tion Control Board, R80-5, December 18, 1980. Brinkman, R. et al., "Radiomimet ic Toxicity of Ozonized Air," Lancet 1:133, 1964. Brookshire, D.S., et al.. Methods Development for Assessing Air Pollution Control Benefits, Vol. 1 1 , EPA-600/5-79-001b, Washington, D.C., February 1979. Bruckert, D. 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B., "A Quantitative Ozone Test for Small Specimens," Chem. Can. 11:34-38, 1959. Ehrsam, F., Alco-Gravure , Inc., Plant Visit, January 16, 1981. Epstein, R., Chicago Rotoprint Co., Chicago, Illinois, Per- sonal Communications, January 13-14, 1981. 170 Federal Register, Vol. 44, No. 128, "Proposed Rules," p. 38597, July 2, 1979. Fisher, J., Marathon Oil Company, Testimony Before the Illi- nois Pollution Control Board, R80-5, November 5, 1980. Folinsbee, L. J. et al., "Exercise Responses Following Ozone Exposure," Journal of Applied Physiology 38:996-1001, 1975. Freeman, M. , Nabisco, Inc., East Hanover, N.J., Personal Communication, December 5, 1980. Freeman, M. A., "The Benefits of Air and Water Pollution Control: A Review and Synthesis of Recent Estimates," pre- pared for the Council on Environmental Quality, December, 1979. Gillette, D. G., "Ambient Oxidant Exposure and Health Costs in the United States - 1973", U.S. EPA, Research Triangle Park, N.C. , 1974. Graziano, F., National Coil Coaters Association, Testimony Before Illinois Pollution Control Board, R80-5, November 5, 1980. Graziano, F., National Coil Coaters Association, Personal Communication, Febuary, 1981. Groteleuschen , R. D., Environmental Control Manager, Deere & Company, Moline, Illinois, Personal Communication, December 5, 1980. Groteleuschen, R. D. , Environmental Control Manager, Deere & Company, Moline, Illinois, Personal Communication, February 2, 1981. Hammer, D. I. et al., "Los Angeles Student Nurse Study", Arch. Environ. Health, Volume 28, May 1974. Herringshaw, T. , Testimony Before the Illinois Pollution Control Board, R80-5, December 18, 1980. Illinois Bureau of the Budget, "An Introduction to Input/ Output Models, the Illinois Input/Output Model and Impact Multiplier Analysis," Springfield, Illinois, 1980. Illinois EPA, "Amendments to Air Pollution Control Regula- tions - Emissions of Volatile Organic Material: Statement of Reasons," Springfield, Illinois, March 1980a. 171 Illinois EPA, Annual Air Quality Report; 1977, Springfield, Illinois, June 1978. Illinois EPA, Annual Air Quality Report; 1978, Springfield, Illinois, June 1979a. Illinois EPA, Annual Air Quality Report; 1979, Springfield, Illinois, June 1980b. Illinois EPA, "Geographic Designations of Attainment Status of Criteria Pollutants," Springfield, Illinois, October 1980c. Illinois EPA, State Implementation Plan for Air Pollution Control, Volume 5; Oxidants, Springfield, Illinois, April 1979b. Illinois EPA, "Technical Support Document for RACT II; Dry Cleaners Section, Springfield, Illinois," Air Quality Plan- ning Section, Springfield, Illinois, May 1980d. Illinois EPA, "Technical Support Document for RACT II; Graphic Arts - Rotogravure, Flexography , " Air Quality Plan- ning Section, Springfield, Illinois, May 1980e. Illinois EPA, "Technical Support Document for RACT II; Leaks from Petroleum Refinery Equipment," Air Quality Plan- ning Section, Springfield, Illinois, May 1980f. Illinois EPA, "Technical Support Document for RACT II; Manufacture of Synthesized Pharmaceutical Products," Air Quality Planning Section, Springfield, Illinois, May 1980g. Illinois EPA, "Technical Support Document for RACT II; Petroleum Liquid Storage in External Floating Roof Tanks," Air Quality Planning Section, Springfield, Illinois, May 1980h. Illinois EPA, "Technical Support Document for RACT II; Pneumatic Rubber Tire Manufacture Section, Springfield, Illinois, Air Quality Planning Section, Springfield, Illi- nois, May 1980i. Illinois EPA, "Technical Support Document for RACT II: Sur- face Coating of Miscellaneous Metal Parts and Products," Air Quality Planning Section, Springfield, Illinois, May 1980j. Illinois EPA, "Technical Support Document for RACT II; Direct Costs of Implementing RACT II Regulations in Illi- nois," Air Quality Planning Section, Springfield, Illinois, January 1981. 172 Kim, J. H. , Demographer, Illinois Department of Public Health, Springfield, Illinois, January 1981. Klemfield, M. C. et al., "Health Hazards Associated with Inert Gas Shield Arc Welding," Arch. Ind. Health, 15;27, 1957. Lagerwerff, J. J., "Prolonged Ozone Inhalation and its Effects on Visual Parameters," Aerospace Medicine, 34:479, 1973. Lawrence, M. , General Tire Company, Testimony Before the Illinois Pollution Control Board, R80-5, November 5, 1980. Levis, J., Illinois EPA, Springfield, Illinois, Personal Communication, December 18, 1980. Look, S., Caterpillar Tractor, Testimony Before Illinois Pollution Control Board, R80-5, June, 1980. Lowe, R. , State of Illinois Department of Labor, Research and Analysis, Personal Communication, April 8, 1981. Manufacturers' News, Inc., Illinois Manufacturers Directory, Chicago, 1980. McGehee, W. , Fiat-Allis, Springfield, Illinois, Personal Communication, January 12, 1981. Moody, William, U.S. EPA, Research Triangle Park, North Carolina, Personal Communication, January 8, 1981. National Air Pollution Control Administration Air Quality for Photochemical Oxidants, Publication No. AP-63, U.S. H.E.W., Washington, D.C., 1970. National Research Council (NRC), Ozone and Other Photochemi - cal Oxidants, National Academy of Sciences, Washington D.C., 1977. Nesselson, Searle Laboratories, Skokie, Illinois, Personal Communication, December 2, 1980. Radian Corporation, Assessment of Atmospheric Emissions from Petroleum Refining; Volume 1, Prepared for U.S. EPA (Con- tract No. 68-02-2147), Washington, D.C., July 1980. Reed, J., Illinois EPA, Testimony Before the Illinois Pollu- tion Control Board, R80-5, November 6, 1980. 173 Remmers, J. E. and Balchum, 0. J., "Effects of Los Angeles Urban Air Pollution Upon Respiratory Function of Emphysema- tous Patients: The Effect of Micro Environment on Patients with Chronic Respiratory Disease," presented at the 58th Annual Meeting of APCA, Toronto, Ontario, 1965. Schwarz, D. , Abbott Laboratories, Plant Visit, December 1, 1980. Smith, R. , "The Feasibility of an 'Injury Tax' Approach to Occupational Health," Law and Contemporary Problems, Summer- Autumn, 1974. Schoettlin, C. E. and Landau, E., "Air Pollution and Asth- matic Attacks in the Los Angeles Area," Public Health Reports, 6:545, 1961. Sterling, T.D. et al., "Urban Hospital Morbidity and Air Pollution," Archives of Environmental Health 15:362-374, 1967. Thaler, R. and Rosen, S., "The Value of Saving a Life: Evi- dence from the Labor Market," in N.E. Terleckyj, ed.. House - hold Production and Consumption, Columbia University Press, New York, 1975. Ting, J.C., Illinois EPA, Testimony Before the Illinois Pol- lution Control Board, R80-5, December 17, 1980. U.S. Department of Agriculture, Crop Values: 1978, 1979, 1980 , Crop Reporting Board, Washington, D.C., January 22, 1981. U.S. Department of Commerce, Bureau of the Census, 1978 Cen - sus of Agriculture, Preliminary Reports, Washington D.C., 1979a. U.S. Department of Commerce, Bureau of the Census, 1977 Cen - sus of Governments, Taxable and Other Property Values, Wash- ington, D.C., 1978a. U.S. Department of Commerce, Bureau of the Census, Census of Manufactures: 1977, Preliminary Reports, Washington, D.C., 1978b. U.S. Department of Commerce, Bureau of the Census, 1977 Cen - sus of Service Industries, Washington, D.C., 1978c. U.S. Department of Commerce, Bureau of the Census, Statisti - cal Abstract of the United States: 1979, 10th edition, Washington, D.C., 1979b. 174 U.S. EPA, Air Quality Criteria for Ozone and Other Photochemical Oxidants, EPA-600/8-78-004 , Research Triangle Park, N.C. , April 1978a. U.S. EPA, Air Quality Data - 1977 Annual Statistics, EPA-450/2-78-040, Research Triangle Park, N.C, September 1978b. U.S. EPA, Compilation of Air Pollutant Emission Factors, AP-42, Research Triangle Park, N.C, 1976. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Compound Leaks from Petroleum Refinery Equipment, Research Triangle Park, N.C, June 1978c. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VI; Sur - face Coating of Miscellaneous Metal Parts and Products, Research Triangle Park, N.C, June 1978d. U.S EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Existing Stationary Sources - Volume VIII; Graphic Arts - Rotogravure and Flexography, Research Trian- gle Park, N.C, December 1978e. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Manufacture of Pneumatic Rubber Tires, Research Triangle Park, N.C, December 1978f. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Manufacture of Synthesized Pharmaceutical Products , Research Triangle Park, N.C, December 1978g. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Perchloroethylene Dry Cleaning Systems, Research Triangle Park, N.C, December 1978h. U.S. EPA OAQPS Guideline Series, Control of Volatile Organic Emissions from Petroleum Liquid Storage in External Floating Roof Tanks, Research Triangle Park, N.C, December 1978i. U.S. EPA, Procedures for Quantifying Relationships Between Photochemical Oxidants and Precursors; Supporting Documenta - tion, EPA-450/2-77-021b, Office of Air Quality Planning and Standards, Research Triangle Park, N.C, February 1978j. U.S. EPA, Uses, Limitations and Technical Basis of Proce - dures for Quantifying Relationships Between Photochemical Oxidants and Precursors, EPA-45Q/i2-77-021a , Office of Air Quality Planning and Standards, Research Triangle Park, N.C. , November 1977. 175 U.S. EPA, Emissions From Volatile Organic Liquid Storage Tanks - Background Information for Proposed Standards; Preliminary Draft, Research Triangle Park, N.C., November 1980. Virginia-Carolina Laundry Supply Company, Durham, N.C., Per- sonal Communication, December 1980. Wayne, W. S. et al., "Oxidant Air Pollution and Athletic Performance," Journal of the American Medical Association, 199:90, 1967. Wetherold, R. G. et al.. Radian Corporation, Assessment of Atmospheric Emissions from Petroleum Refining; Volume 3, Appendix B, Interim Report, prepared for U.S. EPA (Contract No. 68-02-2147), EPA-600/2-80-075c , Washington, D.C., April 1980. Whitten, G. Z. & Hugo, H. , User's Manual for Kinetics Model and Ozone Isopleth Plotting Package, prepared under U.S. EPA Contract 68-02-2428, EPA-600/8-78-014a , U.S. EPA, Research Triangle Park, N.C., July 1978. Yates, J.J. et al.. Economic Impact of Incorporating RACT I Guidelines for VOC Emissions into the Illinois Air Pollution Control Regulations, R78-3 and R78-4, Illinois Institute of Natural Resources, Chicago, Illinois, April 1979. Zelac, R. E. et al., "Inhaled Ozone as a Mutagen, I. Chromo- some Aberrations in Chinese Hamster Lymphocytes," Environ . Res. , 4:262, 1971. 176 APPENDIX A: THE PROPOSED RACT II AMENDMENTS The proposed amendments to air pollution control regu- lations with regard to emissions of volatile organic mater- ial, referred to as RACT II, are given in this appendix. The proposed amendments were prepared by Illinois EPA and submitted to the Illinois Pollution Control Board in March 1980. The proceedings of the Illinois Pollution Control Board in hearing testimony on these amendments are referred to as R80-5. 177 STATE OF ILLINOIS ) ) SS COUNTY OF SANGATCN ) BEFORE THE ILLINOIS POLLUTION CONTROL BOARD AMENDMENTS TO ) AIR POLLUTION CONTROL ) REGULATIONS - ) R80-5 EMISSIONS OF VOLATILE ) ORGANIC MATERIAL ) PROPOSAL TO AMEND AIR POLLUTION CONTROL REGULATIONS Pursuant to Section 28 of the Illinois Environmental Protection Act (111. Rev. Stat., Ch. Ill 1/2, Section 1028, 1977) and the Illinois Pollution Control Board Rules and Regulations, Procedural Rules, Rule 203 and 204, the Environmental Protection Agency (Agency) proposes the following amendments and revisions to Illinois Pollution Control Board Rules and Regulations, Ch. 2, Rules 103, 104, 201 and 205: I. VOLATILE ORGANIC MATERIAL 1. The Agency proposes that the definition of Volatile Organic Material in Rule 201 be amended to read as follows: Volatile Organic Material : Any organic material which has a vapor pressure of 2 rS-peynds -pep-square -4Heh-abse^dte- (p54a}-(139-m4^4i-meteF5- of.ffleFcypy) 17.24kPa (2.5 psi) or greater at 7QQF 294. 30K (70OF). 178 For purposes of Rule 205(1), except 205(1) (4) , volatile organic material means any organic material which has a vapor pressure of Ir^-peHRds-peF sqdaFe-4R6h-ab5e^dte-(ps4a)-(?8-ffl441-4ffle%eFS-ef-ffleFedFy) 10.34kPa (1.5 psi) or greater at 70OF 294. 30K (70OF). For purposes of Rule 205(k), aRd-(R) 205(1)(4), 205(n), 205(s), 205(t), 205(u), and 205(v), volatile organic material means any organic material which has a vapor pressure greater than T0919-peaRds-peF-sqdare-4R6h-abse4Hte-fps4a)--(9Tl- ffl41-44meteFS-ef-meFedFy) 0.13kPA (.0019 psi) at 7GQF- 294.3 0K (70OF). For purposes of this definition, the following are not volatile organic material: 1. Methane, 2. Ethane. II. Rotogravure and Flexography 1. The Agency proposes that Rule 201 be amended to include the following new definitions concerning printing: Flexographic Printin g: The application of words, designs and pictures to a substrate by means of a roll printing technique in which the pattern to be applied is raised above the printing roll and the image carrier is made of elastomeric materials. Packaging Rotogravure Printing: Rotogravure printing upon pape*^, paper board, metal foil, plastic film and other substrates, which are, in subsequent operations, formed into packaging products or labels for articles to be sold. 179 Publication Rotogravure Printing: Rotogravure printing upon paper which is subsequently formed into books, magazines, catalogues, brochures, directories, newspaper supplements or other types of non-packaging printed materials. Roll Printing: The application of words, designs and pictures to a substrate usually by means of a series of hard rubber or metal rolls each with only partial coverage. Rotogravure Printing: The application of words, designs and pictures to a substrate by means of a roll printing technique in which the pattern to be applied is recessed relative to the non-image area. 2. The Agency proposes that Rule 205 be amended by adding a new section (s) as follows: (s) Flexographic and Rotogravure Printing (1) No owner or operator of a packaging rotogravure, publication rotogravure or flexographic printing press subject to this rule and employing solvent-containing ink may cause or allow the operation of the f acil i ty unless: (A) The volatile fraction of ink as it is applied to the substrate contains 25 or less percent by volume of organic solvent and 75 percent or more by volume of water; or (B) The volatile fraction of a waterless ink as it is applied to the substrate is 40 percent or less by volume; or 180 (C) The owner or operator installs and operates: (i) A carbon adsorption system which reduces the volatile organic emissions from the capture system by at least 90 percent by weight; or ( i i ) An afterburning system which oxidizes at least 90 percent of the captured nonmethane volatile organic materials (measured as total combustible carbon) to carbon dioxide and water; or ( i i i ) An alternative volatile organic material emission control system demonstrated to have at least a 90 percent overall reduction efficiency and approved by the Agency; and (iv) A capture system must be used in conjunction with the emission control systems in Rule 205(s)(l)(C)(i )-(iii) . The design and operation of the capture system must be consistent with good engineering practice and shall provide, in combination with the control equipment, an overall reduction in volatile organic material emissions of at least: (aa) 75 percent where a publication rotogravure process is employed; or (bb) 65 percent where a packaging rotogravure process is employed; or (cc) 60 percent where a flexographic printing process is employed. 181 (2) Exemptions The limitations of Rule 205(s) shall not apply to printing facilities whose total uncontrolled emissions of volatile organic material from printing presses of the type specified in Rule 205(s)(l) are limited by operating permit conditions to 907 Mg (1000 tons) per year or less in the absence of air pollution control equipment or from printing presses subject to Rule 205(s)(l) whose actual emissions in the absence of air pollution control equipment would be less than or equal to 907 Mg (1,000 tons) per year when averaged over the preceding three calendar years. (3) Applicability of Rule 205(f) Upon achieving compliance with Rule 205(s), the emission source is not required to meet Rule 205(f). Emission sources exempted from Rule 205(s) are subject to Rule 205(f). Rotogravure or flexographic equipment used for both roll printing and paper coating are subject to Rule 205(s). (4) Testing and Monitoring (A) Upon request of the Agency, the owner or operator of a volatile organic material source subject to Rule 205(s) shall at his own expense demonstrate compliance by methods or procedures approved by the Agency. 182 (B) A person planning to conduct a volatile organic material emissions test to demonstrate compliance with Rule 205(s) shall notify the Agency of that intent not less than 30 days before the planned initiation of the test so the Agency may observe. III. LEAKS FROM PETROLEUM REFINERY EQUIPMENT 1. The Agency proposes that Rule 201 be amended to include the following new definitions concerning leaks from petroleum refinery equipment: Component: Any piece of petroleum refinery equipment which has the potential to leak volatile organic material including but not limited to, pumping seals, compressor seals, seal oil degassing vents, pipeline valves, pressure relief devices, process drains, and open ended pipes. This definition excludes valves which are not externally regulated, flanges, and valves in heavy liquid service. Valves not Externally Regulated: Valves having no external controls, such as in-line check valves. Liquid Service: Equipment which processes, transfers or contains a volatile organic material or mixture of volatile organic materials in a liquid phase. Heavy Liquid: Liquid with a true vapor pressure of less than 0.7& 9. kPa (0.11 psi) at 294. s2k (70^) such as kerosene, diesel fuel, and heating oil . 183 Gas Service: Equipment which processes, transfers or contains a volatile organic material or mixture of volatile organic materials in a gaseous phase. Refinery Unit, Process Unit or Unit: A set of components which are a part of a basic process operation such as distillation, hydrotreating, cracking or reforming of hydrocarbons. 2. The Agency proposes that Rule 205(1) be amended by adding new subsections {4)-(7) as follows: (4) Leaks from Petroleum Refinery Equipment: (A) The owner or operator of a petroleum refinery shall: (i ) Develop a monitoring program consistent with the provisions of Rule 205(m)(4); (ii ) Conduct a monitoring program consistent with the provisions of Rule 205(1 )(5); ( i i i ) Record all leaking components which have a volatile organic material concentration exceeding 10,000 ppm when tested by methods or procedures approved by the Agency and signify each leaking component by a method approved by the Agency; (iv) Repair and retest the leaking components, as defined in Rule 205(1)(4)(A) (iii), as soon as possible but no later than 22 days after the leak is found unless the leaking components cannot be repaired until the unit is shutdown for turnaround; and 184 (v) Identify a11 leaking components, as defined 1n Rule 205(1 )(4)(A)(ii1) , which cannot be repaired until the unit is shutdown for turnaround. (B) The Agency may require early unit turnaround based on the number and severity of tagged leaks awaiting turnaround. (C) Except for safety pressure relief valves, no owner or operator of a petroleum refinery shall install or operate a valve at the end of a pipe or line containing volatile organic materials unless the pipe or line is sealed with a second valve, blind flange, plug, cap or other sealing device. The sealing device may be removed only when a sample is being taken or during maintenance operations. (D) Pipeline valves and pressure relief valves in gaseous volatile organic material service shall be marked in a manner obvious to both refinery personnel performing monitoring and Agency personnel performing inspections. (5) Monitoring for Refinery Leaks (A) The owner or operator of a petroleum refinery shall, for the purpose of detecting leaks, conduct a monitoring program consistent with the following provisions: (i ) Test yearly, by methods or procedures approved by the Agency, all pump seals, pipeline valves in liquid service, and process drains. 185 ( i i ) Test quarterly, by methods or procedures approved by the Agency, all compressor seals, pipeline valves in gaseous service, and pressure relief valves in gaseous service. ( i i i ) Observe visually all pump seals weekly; (iv) Test immediately any pump seal from which liquids are observed dripping; (v) Test any relief valve within 24 hours after it has vented to the atmosphere; and (vi) Test immediately after repair any component that was found leaking. (B) Inacccessible valves, storage tank valves, and pressure relief devices connected to an operating flare header or vapor recovery device are exempt from the monitoring requirements in Rule 205(1)(5)(A). (6) Recordkeeping (A) The owner or operator of a petroleum refinery shall maintain a leaking components monitoring log as required in Rule 205(1 )(4)(A)(iii) which shall contain, at a minimum, the following information: (i) The name of the process unit where the component is located; ( i i ) The type of component; (iii) The tag number of the component; (iv) The date on which a leaking component is discovered; 186 (v) The date on which a leaking component is repaired; (vi) The date and instrument reading of the recheck procedure after a leaking component is repaired; (vii ) A record of the calibration of the monitoring instrument; (viii) Those leaks that cannot be repaired until turnaround; and (ix) The total number of components inspected and the total number of components found leaking during that quarter. (B) Copies of the monitoring log shall be retained by the owner or operator for a minimum of two years after the date on which the record was made or the report prepared. (C) Copies of the monitoring log shall be made available to the Agency, upon verbal or written request, at any reasonable time. (7) Reporting (A) The owner or operator of a petroleum refinery, upon the completion of each yearly or quarterly monitoring procedure, shall: (1) Submit a report to the Agency by the 15th day of January, April, July, and October listing a11 leaking components located during the previous three calendar months but not repaired within 22 days, all leaking components awaiting unit turnaround, the total number of components inspected, and the total number of components found leaking; 187 (ii ) Submit a signed statement with the report attesting that a11 monitoring and repairs were performed as required under Rules 205(1)(4) - (5). (B) The Agency, upon written notice to the owner or operator of a petroleum refinery, may modify the monitoring, recordkeeping and reporting requirements consistent with the purpose of Rule 205(1)(4)-(7). 2. The Agency proposes that Rule 205(m) be amended by adding a new subsection (4) as follows: (4) Petroleum Refinery Leaks The owner or operator of a petroleum refinery, in order to comply with 205(1 )(4)-(7) , shall adhere to the increments of progress contained in the following schedule: (A) Submit to the Agency a monitoring program by January 15, 1981. This program shall contain, at a minimum, a list of the refinery units and the quarter in which they will be monitored, a copy of the log book format, and the make and model of the monitoring equipment to be used. In no case shall a monitoring program relieve the owner or operator of a petroleum refinery of the responsibility for compliance with this Rules 205(1 )(4) - (7). (B) Submit the first quarterly monitoring report to the Agency by July 15, 1981. 188 IV. SURFACE COATING OF MISCELLANEOUS METAL PARTS AND PRODUCTS 1. The Agency proposes that Rule 201 be amended to include the following new or revised definitions concerning surface coating: Air Dried Coating: Coatings that dry by the use of air or forced air at temperatures up to 363.15°K (194 ° F). Clear Coating: Coatings that lack color and opacity or are transparent using the undercoat as a reflectant base or undertone color. Extreme Performance Coating: Coatings designed for exposure to any of the following: the ambient weather conditions temperatures above 368.15^ (203^), detergents, abrasive and scouring agents, solvents, corrosive atmospheres, or other similar extreme environmental conditions. Low Solvent Coating: A coating which contains less organic solvent than the conventional coatings used by the industry. Low solvent coatings include water-borne, higher solids, electrodeposition and powder coatings. Miscellaneous Metal Parts and Products: For the purposes of Rule 205(n)(l)(J), miscellaneous metal parts and products shall include farm machinery, garden machinery, small appliances, commercial machinery, industrial machinery, fabricated metal products, and any other industrial category which coats metal parts or products under the Standard Industrial Classification Code for Major Groups 33, 34, 35, 36, 37, 38, or 39 with the exception of the following: coating lines subject to Rules 205(n)(l)(A)-(I), exterior of airplanes, automobile or light duty 189 truck ref1n1shing, the exterior of marine vessels, and the customized top coating of automobiles and trucks if production is less than thirty-five vehicles per day. Transfer Efficiency : The weight or volume of coating adhering to the material being coated divided by the weight or volume of coating delivered to the coating applicator and multiplied by 100 to equal a percentage. 2. The Agency proposes that Rule 205(n)(l) be amended t)y adding a new subsection (J) to provide as follows: (n)(l)(J) Miscellaneous Metal Parts and Products CoatingZ . (i) clear coating 0.52 (4.3) ( i i ) air dried coating 0.42 (3.5) ( i i i ) extreme performance 0.42 (3.5) coating (iv) all other coatings 0.36 (3.0) 3. The Agency proposes that Rule 205(n)(2) be amended by adding a new subsection (C) to provide as follows: (C) Methods or procedures used to determine emissions of organic material shall be approved by the Agency. Z The least restrictive limitation shall apply if more than one limitation pertains to a specific coating. 190 V. EXTERNAL FLOATING ROOF TANKS 1. The Agency proposes that Rule 201 be amended to include the following new definitions concerning petroleum liquid storage tanks: External Floating Roof: A storage vessel cover in an open top tank consisting of a double deck or pontoon single deck which is supported by the petroleum liquid being contained and is equipped with a closure seal between the deck edge and tank wall. Liquid-Mounted Seal: A primary seal mounted in continuous contact with the liquid between the tank wall and the floating roof edge around the circumference of the roof. Vapor-Mounted Primary Seal: A primary seal mounted with an air space bounded by the bottom of the primary seal, the tank wall, the liquid surface, and the floating roof. Waxy, Heavy Pour Crude Oil: A crude oil with a pour point of 283. 15K (50^) or higher as determined by the American Society for Testing and Materials Standard 097-66, "Test for Pour Point of Petroleum Oils." as revised. EFR Rule Revision (4/11/80) 2. The Agency proposes that Rule 205(a)(2)(A) be revised to read as follows: 191 (A) A floating roof which rests on the surface of the volatile organic material and is equipped with a closure seal or seals %e-6^ese-the-spaee between the roof edge and the tank wall. Such _a floating roof shall not be permitted if the volatile organic material has a vapor pressure of i2T5-pedRds-peF-sqHaFe ioch-absoJute 86.19 kPa (12.5 psia) or greater at JQQf 294. 3K (70^). No person shall cause or allow the emission of air contaminants into the atmosphere from any gauging or sampling devices attached to such tanks-; except during sampling or maintenance operations. 3. The Agency proposes that Rule 205(a)(2)(C) be revised to read as follows: (C) Other equipment or means of equal efficiency approved by the Agency according to the provisions of Part 1 of this Chapter 2-; 4. The Agency proposes that Rule 205(a)(3) be deleted. 5. The Agency proposes that Rule 205(o)(3)(A) be revised to read as follows: (A) The requirements of Rule 205(o)(3)(B) shall not apply to any stationary storage tank: {1) (1 ) eqH4pped Equipped before January 1, 1979 with one of the vapor loss control devices specified in Rule 205(a)(2) except Rule 205(a)(2)(A) ; {2) (ii) w4th With a capacity of less than 151.42 mj . 192 _(_40,000 gallons^ ■(3) ( i i i ) w4th With a capacity of less than 1,600 m ^ {442^675) (422,400 gallons ) and used to store produced crude oil and condensate prior to custody transfer; (4) (iv) w4th With a capacity of less than Q^OOO-ban^e^s 1,430 ml (378,000 gallons) +f and used to store BFude-e+l- produced oil or condensate in crude oil gathering; (5) (v) subject Subject to new source performance standards for storage vessels of petroleum liquid (49-6FR PaFt-60T-SufepaFt-K) (Rule 909 of Chapter 2) ; er (6) (vi) 4n _Iji which volatile petroleum liquid is not storedj_ or (vii ) Which is a pressure tank as described in Rule 205(a)(1). 6. The Agency proposes that Rule 205(o)(3) be amended by adding new subsections (C) and (D) as follows: (C) Subject to Rule 205(o) (3)(A), no owner or operator of a stationary storage tank equipped with an external floating roof shall, in addition to the requirements of Rule 205(o)(3)(B), cause or allow the storage of any volatile petroleum liquid in the tank unless: 193 (i ) The tank has been fitted with a continuous secondary seal extending from the floating roof to the tank wall (rim-mounted secondary seal) or any other device which controls volatile organic material emissions with an effectiveness equal to or greater than a rim-mounted secondary seal ; (ii) Each seal closure device meets the following requirements: (aa) The seal is intact and uniformly in place around the circumference of the floating roof between the floating roof and tank wall; and, (bb) The accumulated area of gaps exceeding 0.32 cm (1/8 inch) in width between the secondary seal and the tank wall shall not exceed 21.2 cm £ per meter of tank diameter (1.0 in^ per foot of tank diameter), as determined by methods or procedures approved by the Agency; (Hi) Emergency roof drains are provided with slotted membrane fabric covers or equivalent covers across at least 90 percent of the area of the opening; (iv) Openings are equipped with projections into the tank which remain below the liquid surface at all times; (v) Routine inspections are conducted semi-annually in order to insure compliance with Rule 205(o)(3)(C) including a visual inspection of the secondary gap; 194 (vi) The secondary seal gap is measured annually in accordance with methods or procedures approved by the Agency; (vii) Records of the types of volatile petroleum liquid stored, the maximum true vapor pressure of the liquid as stored, the results of the i nspections and the results of the secondary seal gap meaurements are maintained and available to the Agency, upon verbal or written request, at any reasonable time for a minimum of two years after the date on which the record was made; (viii ) Upon the request of the Agency, the owner or operator of a volatile organic material source required to comply with Rule 205(o)(3)(C), at his own expense, demonstrates compliance by methods or procedures approved by the Agency; and (ix) A person planning to conduct a volatile organic material emission test to demonstrate compliance with Rule 205(o)(3) notifies the Agency of that intent not less than 30 days before the planned initiation of the tests so the Agency may observe the test. (D) The requirements of Rule 205(o)(3)(C) shall not apply to any stationary storage tank equipped with an external floating roof: ( i ) Exempted under Rule 205(o)(3)(A) ( i i)-(vi ) ; 195 ( ii) Of welded construction equipped with a metallic-type shoe seal having a secondary seal from the top of the shoe seal to the tank wall (shoe-mounted secondary seal); ( i i i ) Of welded construction equipped with a metallic-type shoe seal, a liquid-mounted foam seal, a liquid mounted liquid filled type seal, or other closure device of equivalent control efficiency approved by the Agency in which a petroleum liquid with a true vapor pressure less than 27.6 kPa (4.0 psia) is stored; or (iv) Used to store waxy, heavy pour crude oil. VI. SYNTHESIZED PHARMACEUTICALS 1. The Agency proposes that Rule 201 be amended to include the following new definitions concerning synthesized pharmaceutical manufacturing: Production Equipment Exhaust System: A device for collecting and directing out of the work area volatile organic material fugitive emissions from reactor openings, centrifuge openings and other vessel openings for the purpose of preventing dangerous or undesirable concentrations of such material from occurring. Reactor: A vat or vessel designed to contain chemical reactions. Surface Condenser: A device which removes condensable vapors in captured gases by a reduction in the temperature of the captured gas through indirect contact between the coolant and the process gas stream. 196 2. The Agency proposes that Rule 205 be amended by adding a new section (t) as follows: (t) Synthesized Pharmaceutical Manufacturing (1) This rule applies to all sources of volatile organic material including reactors, distillation units, dryers, storage tanks for volatile organic materials, equipment for the transfer of volatile organic materials, filters, crystallizers and centrifuges used in manufacturing of pharmaceutical products by chemical synthesis. (2) The owner or operator of a synthesized pharmaceutical manufacturing facility shall control all reactors, distillation operations, crystallizers, centrifuges and vacuum dryers that have the potential to emit 6.8 kg/day (15 lb/day) or more of volatile organic material. Surface condensers shall be used provided that the condenser outlet gas temperature must not exceed: (A) 248.2^ (-13^) when condensing volatile organic material of vapor pressure greater than 40.0 kPa (5.8 psi);* (B) 258.2-^ (5^) when condensing volatile organic material of vapor pr^essure greater than 20.0 kPa (2.9 psi);* (C) 273. 23< (32^) when condensing volatile organic material of vapor pressure greter than 10.0 kPa (1.5 psi);* (D) 283.2^ (50. 2 F) when condensing volatile organic material of vapor pressure greater than 7.0 kPa (1.0 psi);* (E) 298.2^ (77^) when condensing volatile organic material of vapor pressure greater than 3.50 kPa (0.5 psi);* or 197 (F) Unless volatile organic material emissions are reduced by equivalent controls which limit emissions by at least as much as a surface condenser would under the requirements of 205(t)(2)(A)-(E). (3) The owner or operator of a synthesized pharmaceutical manufacturing facility shall reduce the volatile organic material emissions from all air dryers and production equipment exhaust systems: (A) By at least 90 percent if uncontrolled emissions of volatile organic material are 150 kg/day (330 lb/day) or more; or, (B) To 15 kg/day (33 1b/day) or less if uncontrolled emissions of volatile organic material are less than 150 kg/day (330 lb/day). (4) The owner or operator of a synthesized pharmaceutical manufacturing facility shall : (A) Provide a vapor balance system or equivalent control that is at least 90 percent effective in reducing emissions from truck or railcar deliveries to storage tanks with capacities greater than 7.57 m^ (2,000 gallons) that store volatile organic material with vapor pressures greater than 28.3 kPa (4.1 psi) at 294. 3° K (ypOf); and, (B) Install pressure/vacuum conservation vents set at +0.21kPa (0.03 psi) on all storage tanks that store volatile organic material *Vapor pressures as measured at 294. 3£ K (7Q2f) 198 with vapor pressures greater than 10.3 kPa (1.5 psi) at 294.3 K (70^), unless a more effective control system is used. (5) The owner or operator of a synthesized pharmaceutical facility shall enclose all centrifuges, rotary vacuum filters and other filters having an exposed liquid surface where the liquid contains volatile organic material and exerts a total volatile organic material vapor pressure of 3.45 kpa (0.5 psi) or more at 294. 3°K (70 ° F). (6) The owner or operator of a synthesized pharmaceutical facility shall install covers on a11 in-process tanks containing a volatile organic material at any time. These covers must remain closed except when production, sampling, maintenance or inspection procedures require operator access. (7) The owner or operator of a synthesized pharmaceutical manufacturing facility shall repair all leaks from which a liquid containing volatile organic material is observed. The repair shall be completed the first time the equipment is off-line for a period of time long enough to complete the repair. (8) Upon achieving compliance with Rule 205(t), the emission source is not required to meet Rule 205(f). Emission sources exempted from Rule 205(t) are subject to Rule 205(f). (9) Testing and Monitoring (A) Upon the request of the Agency, the owner or operator of any volatile organic material source required to comply with Rule 199 205(t) shall at his own expense demonstrate compliance by the methods or procedures approved by the Agency. (B) A person planning to conduct a volatile organic material emissions test shall notify the Agencys of that intent not less than 30 days before the planned initiation of the tests so the Agency may observe. VII. PERCHLOROETHYLENE DRY CLEANING 1. The Agency proposes that Rule 201 be amended to include the following new definition concerning perchloroethylene dry cleaning: Dry Cleaning Facility: A facility engaged in the cleaning of fabrics using an essentially nonaqueous solvent by means of one or more solvent washes, extraction of excess solvent by spinning, and drying by tumbling in an airstream. The facility includes, but is not limited to, washers, dryers, filter and purification systems, waste disposal systems, holding tanks, pumps, and attendant piping and valves. 2. The Agency proposes that Rule 103(i) be amended by adding a new subsection (23) as follows: (23) coin-operated dry cleaning operations. 3. The Agency proposes that Rule 205 be amended by adding a new section (u) as follows: 200 (u) Dry Cleaning (1) The owner or operator of a perchloroethylene dry cleaning facility shall : (A) Vent the entire dryer exhaust through a properly designed and functioning carbon adsorption system or equally effective control device; (B) Emit no more than 100 ppmv of volatile organic material from the dryer control device before dilution; (C) Dry all drained filtration cartridges in equipment connected to an emission reduction system; (D) Imnediately repair a11 components found to be leaking liquid volatile organic material; (E) Cook or treat all diatomaceous earth filters so that the residue contains 25 kg (55 lb) or less of volatile organic material per 100 kg (220 lb) of wet waste material; (F) Reduce the volatile organic material from all solvent stills to 60 kg (132 lb) or less per 100 kg (220 lb) of wet waste material; and (G) Drain a11 filtration cartridges in the filter housing for at least 24 hours before discarding the cartridges. (2) The provisions of Rules 205(u)(l)(A), (B) and (C) are not applicable to perchloroethylene dry cleaning operations which are coin operated. (3) Testing and Monitoring 201 (A) Compliance with Rule 2Q5(u) (1 ) (A) , (C) and (G) shall be determined by a visual inspection; (B) Test procedures used to determine compliance with Rule 205(u)(l)(B) shall be approved by the Agency; (C) Compliance with Rule 205(u)(l)(D) shall be determined by a visual inspection of the following: hose connections, unions, couplings, and valves; machine door gaskets and seatings; filter head gasket and seating; pumps; base tanks and storage ' containers; water separators; filter sludge recovery; distillation unit; diverter valves; saturated lint from lint baskets; and cartridge filters; and (D) Compliance with Rule 205(u)(l)(E) and (F) shall be determined by methods or procedures approved by the Agency. VIII. MANUFACTURE OF PNEUMATIC RUBBER TIRES 1. The Agency proposes that Rule 201 be amended to include the following new definitions concerning pneumatic rubber tire manufacturing: Pneumatic Rubber Tire Manufacture: The production of pneumatic rubber tires with a bead diameter up to 20.0 inches and cross section dimension up to 12.8 inches not including specialty tires for antique or other vehicles when produced on equipment separate from normal production lines for passenger or truck type tires. Unde rtread Cementing: The application of a solvent-based cement to the underside of a tire tread. 202 Bead Dipping: The dipping or Immersion of an assembled t1re bead into a solvent-based cement. Tread End Cementing: The application of a solvent-based cement to the tire tread ends. Green Tires: Assembled tires before molding and curing have occurred Green Tire Spraying: The spraying of green tires, both inside and outside, with release compounds which help remove air from the tire during molding and prevent the tire from sticking to the mold after curing. Water-Based Sprays: Release compounds, sprayed on the inside and outside of green tires, in which solids, water, and emulsifiers have been substituted for organic solvents. 2. The Agency proposes that Rule 205 be amended by adding a new section (v) as follows: (v) Pneumatic Rubber Tire Manufacture (1) The owner or operator of a pneumatic rubber tire manufacturing facility shall : (A) Install and operate a capture system, with a minimum capture efficiency of 65 percent by weight of volatile organic material from all undertread cementing, tread end cementing and bead dipping operations. 203 (B) Install and operate a control device that meets the requirements of one of the following: (i) A carbon adsorption system designed and operated in a manner such that there is at least a 90 percent removal of volatile organic material by weight from the gases ducted to the control device; ( 1 i ) An afterburning system that oxidizes at least 90 percent of the captured nonmethane volatile organic materials measured as total combustible carbon) to carbon dioxide and water; or ( i i i ) An alternative volatile organic material emission reduction system demonstrated to have at least a 90 percent overall reduction efficiency and approved by the Agency. (2) The owner or operator of a green tire spraying operation at a pneumatic rubber tire manufacturing facility must implement one of the following means of reducing volatile organic material emissions: (A) Substitute water-based sprays containing no more than five percent by volume of volatile organic material as applied for the normal solvent-based mold release compound; or, (B) Install a capture system designed and operated in a manner that will capture and transfer at least 90 percent of the volatile organic material emitted by the green tire spraying operation to a control de vice provid e d the owner or operator installs and 204 operates a control device that meets the requirements of one of the following: (i) A carbon adsorption system designed and operated in a manner such that there is at least 90 percent removal of volatile organic material by weight from the gases ducted to the control device; (ii ) An afterburning system that oxidizes at least 90 percent of the captured nonmethane volatile organic material (measured as total combustible carbon) to carbon dioxide and water; or, ( i i i ) An alternative volatile organic material emission reduction system demonstrated to have at least a 90 percent overall reduction efficiency and approved by the Agency. (3) Testing and Monitoring (A) Upon request of the Agency, the owner or operator of a volatile organic material source required to comply with Rule 205(v) shall, at h is own expense, demonstrate compliance by methods or procedures approved by the Agency. (B) A person planning to conduct a volatile organic material emission test shall notify the Agency of that intent less than 30 days before the planned initiation of the test so the Agency may observe. 205 IX. RACT II SUBMISSION OF COMPLIANCE PLANS 1. The Agency proposes that Rule 104 be amended by adding a new Section (h) as follows: (h) RACT II Compliance Plan Submission and Approval (1) The owner or operator of a facility or emission source subject to Rules 205(n)(l)(J), 205(o)(3), 205(s), 205(t), 205(u)(l)(A) and (B), or 205(v) shall submit to the Agency compliance program and project completion "schedule, where applicable, no later than: Rule Days After Promulgation (A) Rules 205(o)(3)(C), 205(s), 90 205(t) and 205(v); (B) Rules 205(u)(l)(A) and (B) for 150 facilities located in Cook County; (C) Rule 205(n)(l)(J); 210 (D) Rule 205(u)(l)(A) and (B) for 240 counties not included in Rule 104(h)(1)(B) or (E); and (E) Rule 205(u)(l)(A) and (B) for facilities located in Boone, DuPage, Kane, Lake, Madison, McHenry, Peoria, Rock Island, St. Clair, Tazewell and Winnebago Counties. 300 206 (2) Unless the submitted compliance program or project completion schedule is disapproved by Agency, the owner or operator of a facility or emission source subject to Rules 205(n)(l)( J) , 205(o)(3), 205(s), 205(t), 205(u)(l)(A) and (B), or 205(v) may operate the emission source according to the program and schedule as submitted. (3) The program and schedule shall meet the requirements of Rule 104(b) including specific interim dates as required in Rule 104(b)(2). 2. The Agency proposes that Rule 104(a) be revised to read as follows: (a) PF9h4b4fe4-9R T — Ne-peFseR-sha^^-eadse-ep-a^^ew-the-eperat+GR-ef aR-em45s4eR-seaFee-wh4eh-4-s-flet-4R-eemp44aR6e-w4%h-the-5taRdaFds Gy=-44m4tat4eHS-set-feFth-4R-PaF%-2-ef-%l=i4s-6haptei=7-exeept-fe)« Rd4e-29§(k)-(q}-;-(afteF-fehe-date-by-wh4eh-su6h-effl4ss4eR-seyF6e 45-Feq«4Fed-te-have-aH-0peFat4R§-PeFm4%-pyFSHaHt-te-Ra4e-193- w4the«%-a-9efflp44aRee-PFegFaffl-aRd-a-PFe3e6t-6emp4et4eR-S6hedy4e appFeved-by-the-A§GR6yT (!■) Ne-peFseR-sha44-6ua5G-eF-a44ew-thG-epeFat4eH-ef-aH- em4ss4en-seuF6G-wh4eh-4s-Ret-4R-6emp44aReG-w4th-the thG-FeqH4FefflGHts-ef-Rul-e-20i(k)-(p)-afteF-the-date-by wh46h-a-5ebFeG-4s-FeqH4Fed-te-have-a-Gefflp44aReG-PFe§Faffl- uRdeF -Rd4e- 194(g) -w4th9dt-a-GGmp 4 4aR6G-PFGgFam-appF9ved- by-the-AgeR6yT 207 (2} yfl^ess-the-5eyF6e-w44^-eeh4eve-^4fia^-eefflp44aR6e-by- jH4y-i^-i989-eF-ofldeF-a-sehedd4e-set-#G>=th-4R-Rd;e-20§(m) H8-peFseH-5ha4^-6a«5e-eF-a4+ew-the-epeFat4eH-ef-aH- effl4ss4eH-seHF6e-wh46h-4s-Hefe-4H-€emp44aR6e-w4th-the- Feqd4Femefifes-ef-Ru4e-205fk)-(p)-afteF-the-date-by-wh46h- a-5eHFee-4s-FeqH4Fed-te-have-a-PFe5eet-6emp4et4eR- Sehed«4e-appFeved-by-tl=ie-A§efl6yT--Ge4d-64eaH4R§- de§Fea5eF5-aRd-5eHF6es-Sdb5e6*-%e-RH4e-29i(q)--aFe-Ret FeqH4Fed-te-5Hbffl4*-eF-Gb%a4R-aR-A§eR6y-appFeved' 6emp44aR6e-P4aR-GF-PFe5eet-6emp4el4eR-S6hedu4eT--ARy 6efflp44aRee-P4aR-eF-PFe5e6t-Gefflp4et4eR-Sel=iedH4G-j-wheFe app446ab4eT-slRa44-be-a-b4Rd4R§-eeHd4%4eR-ef-the- epeFat4R§-peFm4t-feF-%he-sedFeeT (a) Applicabil ity. (1) No person shall cause or allow the operation of an emission source not in compliance with the requirements of Rule 205(k)-(v) without a compliance program as provided for in Rule 104(g) or (h). (2) Unless the source w i ll achieve final compliance by July 1, 1980 or under a schedule set forth in Rule 205(m), no person shall cause or allow the operation of an emission source not in compliance with the requirements of Rule 205(l<)-(v) without a project completion schedule as provided for in Rule 104(g) or (h). 208 (3) Cold cleaning degreasers, coin operated perchloroethylene dry cleaning operations, and sources subject to Rule 205(q) are not required to submit or obtain an Agency approved compliance plan or project completion schedule. (4) Any compliance plan or project completion schedule, where applicable, shall be a binding condition of the operating permit for the source. 3. The Agency proposes that Rule 104(g) be revised to read as follows: (g) Submission and Approval Dates A source subject to the requirements of Rule 205(k)-(p) , except Rule 205(l)(4)-(8), 205(n)(l)(J) and 205(o)(3) , shall have a 6emp^-4aR6e compliance P4aR plan and a Pfejeet project Gefflpl-et4eR Sehedfai^e- schedule , where applicable, approved by the Agency by the following dates. A Gefflp4i-afi6e compliance P+an plan and a PFejeet project Gemp4et4eH completion Sehedyl-e schedule , where applicable, shall be submitted at least 90 days before the following datesj_ (1) By February 1, 1980. Gasoline dispensing facilities subject to Rule 205(p) and degreasers subject to Rule 205(k) located in Cook, DuPage, Lake, Kane, McHenry and Will Counties. (2) By March 1, 1980. Petroleum refineries subject to Rule 205(1), except (l)(4)-(7) . Gasoline dispensing 209 facilities subject to Rule 205(p) in Boone, Madison, St. Clair, Peoria, Tazewell, Rock Island and Winnebago eedRt4es Counties. (3) By April 1, 1980. Degreasers subject to Rule 205(l<) located in counties other than Cook, DuPage, Lake, Kane, McHenry or Will. Bulk gasoline plants, bulk gasoline terminals and petroleum liquid storage tanks subject to Rule 205(o), except (o)(3)(C), located in Cook, DuPage, Lake, Kane, McHenry and Will Counties. (4) By May April 1, 1980. Coating lines subject to Rule 205(n), except (n)(l)(J). Bulk gasoline plants, bulk gasoline terminals and petroleum liquid storage tanks subject to Rule 205(o) , except (o)(3), which are located in counties other than Cook, Lake, DuPage, Kane, McHenry or Will. 4. The Agency proposes that Rule 205{j) be revised to read as follows: (j) Compl iance Dates Every owner or operator of an emission source shall comply with the standards and limitations of Rule 205 in accordance with the dates shown in the following table: 210 Rule Rule 205(a through (i Rule 205(a through (i Rule 205(k Rule 205(1 205(1)(4)- Rule 205(n Rule 205(o (3)(B)(o) Rule 205(p Rule 205(q Rule 205(s and (t) Rule 205(u except 81 (1), (2), 3)(C) Type of Source New Emission Sources Existing Emission Sources All Emission Sources All Emission Sources All Emission Sources All Emission Sources All Emission Sources All Emission Sources All Emission Sources (1)(A)-(C) All Emission (u)(l)(D)-(G) Rule 205(v) Sources All Emission Sources Final Compliance Date April 14, 1972 December 31, 1973 July 1, 1980 July 1, 1980 December 31, 1982* July 1, 1981 August 15, 1981 See Rule 205(m) December 31, 1980 December 31, 1982 December 31, 1982 January 1, 1981 December 31, 1982 5. The Agency proposes that Rule 205(m)(l)(A) and (B) be revised to read as follows: (1) Coating Lines The owner or operator of coating lines subject to the requirements of Rule 205(n) , except (n)(l)J), shall take the following actions: 211 (A) Submit to the Agency a Compliance Program that meets the requirements of Rule 104(b)(1) by January 1, 1980. (B) For sources that, under the approved Compliance Plan, will comply with Rule 205(n) , except (n)(l)J), by use of low solvent coating technology the following increments of progress shall be met: 6. The Agency proposes that Rule 205(m)(l)(C) be revised to read as f 1 1 ows : (C) For sources that, under the approved Compliance Plan, will comply with Rule 205(n) , except (n)(l)(J), by installing emission control equipment the following increments of progress shall be met: 7. The Agency proposes that Rule 205(m)(2) be revised to read as follows; Bulk Gasoline Plants, Bulk Gasoline Terminals, Petroleum Liquid Storage Tanks The owner of an emission source subject to the requirements of Rule 205(o) , except (o)(3) , shall take the following actions: (A) Submit to the Agency a Compliance Program that meets the requirements of Rule 104(b)(1) by the date specified in Rule 104(g). SC:sp/2240B/l-35 212 APPENDIX B: OZONE STANDARD ATTAINMENT STATUS FOR COUNTIES OF ILLINOIS The accompanying Table B.l lists Illinois counties and gives their ozone attainment status designation. The attainment status was obtained from Illinois EPA, "Geo- graphic Designations of Attainment Status of Criteria Pollu- tants," revised in October 1980. The method Illinois EPA used in designating the status of each county with regard to the ozone standard was described in Section 2.1 above. 213 TABLE B.l ILLINOIS COUNTIES: OZONE STANDARD ATTAINMENT STATUS Attainment County Status Adams N Alexander U Bond U Boone N Brown U Bureau U Calhoun U Carroll U Cass U Champaign A Christian U Clark U Clay U Clinton U Coles U Cook N Crawford A Cumberland U De Kalb N De Witt U Douglas U Du Page N Edgar U Edwards U Effingham U Fayette U Ford U Franklin U Fulton U Gallatin U Greene U Grundy N Hamilton U Hancock U Hardin U Henderson U (Table continued on following page) 214 • TABLE B.l (Continued) ILLINOIS COUNTIES: OZONE STANDARD ATTAINMENT STATUS County Attainment Status Henry I roquois Jackson Jasper Jefferson Jersey Jo Daviess Johnson Kane Kankakee Kendall Knox Lake La Salle Lawrence Lee Livingston Logan Macon Macoupin Madison Marion Marshall Mason Massac McDonough McHenry McLean Menard Mercer Monroe Montgomery Morgan Moultrie Ogle Peoria U U U U U U U U N N N U N N U U U U A U N U U U U U N A U U N U U U U N (Table continued on following page) 215 TABLE B.l (Continued) ILLINOIS COUNTIES: OZONE STANDARD ATTAINMENT STATUS County Attainment Status Perry Piatt Pike Pope Pulaski Putnam Randolph Richland Rock Island St. Clair Saline Sangamon Schuyler Scott Shelby Stark Stephenson Tazewell Union Vermillion Wabash Wa r r e n Washington Wayne White Whiteside Will Williamson Winnebago Woodford U U u u u u u u u N U N u u u u u N U U U U U u u u N N U u Key: A - Attainment County N - Nonattainment County U - Unclassified County Sources: Illinois EPA, "Geographic Designations of Attainment Status of Criteria Pollutants," Springfield, Illinois, October 1980. 216 APPENDIX C: ECONOMIC FACTORS This appendix presents factors which were used in Chapter 3 in estimating the costs of RACT II in Illi- nois. est imating the costs of RACT II in Illinois. C.l Price Deflators The measure of the general level of prices used in this study is the GNP implicit price deflator. Table C.l shows the annual GNP deflator from 1970 to 1980 and the quarterly deflator for the last three years. The price deflator is compiled by the Bureau of Economic Analysis in the U.S. Commerce Department. In order to convert to 1980 dollars, the original dollar amount for any year is multi- plied by the ratio of the 1980 deflator to the original year deflator. This calculation was performed for all the dollar figures in this report, including both the costs in Chapter 3 and the monetary values associated with the benefits that were presented in Chapter 4. 217 TABLE C.l GROSS NATIONAL PRODUCT IMPLICIT PRICE DEFLATOR (1972=100) Impl ic i t Year/Quarter Price Deflator 1970 91.36 1971 96.02 1972 100.00 1973 105.80 1974 116.02 1975 127.15 1976 133.71 1977 141.70 1978 152.05 1979 165.50 1980 180.96 1977: I 138.34 II 140.93 III 142.59 IV 144.82 1978: I 147.05 II 150.82 III 153.45 IV 156.68 1979: I 160.22 II 163.81 III 167.20 IV 170.74 Sources: Figures through 1979 are from Economic Report of the President 1980, Transmitted to the Congress January 1980, Washington, D.C. Figures for 1980 are from U.S Department of Commerce Library, Chicago, Illinois, Personal Communication. 218 C. 2 Capital Charges In calculating the annual costs in Chapter 3, the capital cost for a control technology was converted to an annual capital charge in order to be made comparable to operation, maintenance and other yearly costs. The annual capital charge must be sufficient to recoup the costs of the equipment over its useful life, plus interest on the cost, less the present value of any salvage revenue. The annual capital charge used in this study is 17.5 percent of the cost of capital equipment. C. 3 Price and Output Changes Whether there is a change in output in industries being controlled depends on responsiveness of producers to the change in costs resulting from requiring controls, as well as on the extent to which the costs are borne by pro- ducers or are passed through to customers in the form of higher prices. To obtain estimates of output and price changes, con- trol costs as a percent of the value of production can be calculated as the ratio of column one to column two in Table 3.27, giving in the third column an estimate of c, the percentage increase in cost of supplying a given out- put as a result of requiring controls. The estimate of c 219 is used in conjunction with E, the elasticity of supply or percentage increase in output in response to a 1 percent increase in price, and N, the absolute value of the elas- ticity of demand or percentage decrease in quantity demanded in response to a 1 percent increase in price. Using c, E and N, the percentage cut-back in output in response to requirements to adopt emission controls is cN/(l+N/E). (C.l) The percentage rise in price in the industry being cont- rolled is c/(l+N/E). (C.2) The derivation of these formulas is available upon request . In the absence '^f previous estimates of the supply and demand elasticities E and N, lower and upper bounds of .5 and 3 are used in both cases in this study. Applying (C.2), the medium estimate of the percentage rise in price in this study is obtained when E and N are equal, in which case the percentage rise in price is .5c. An implication of the medium estimate is that 50 percent of the costs of control are passed on to customers with the remaining 50 percent borne by producers. A high estimate of the price rise is obtained if E is 3 and N is .5, in which case the 220 percentage rise in price is .85c, implying that 85 percent of the costs are passed on. A low estimate is obtained if E is .5 and N is 3, in which case the percentage rise in price is .16c. With regard to the output effect found by applying the values of N and E in (C.l), the largest output effect is found when N and E are both 3, in which case the per- centage decline in output is 1.5c. The smallest output effect is found when N and E are both .5, in which case the percentage decline in output is .5c. These two esti- mates are used as the high and low estimates of output change in industries required to control emissions in this study, and the medium estimate is taken as the average of these two estimates. C. 4 Use of the Illinois Input-Output Model An Illinois input-output model is currently main- tained by Lhc Illinois Bureau of the Budget. The model incorporates 472 agricultural, mining, construction, manu- facturing, service and governmental sectors of the Illi- nois economy. The technical coefficients are based on a Leontief input-output model of the U.S. economy. A detailed description of the Illinois model is available in the Bureau of the Budget's "An Introduction to Input/Out- 221 put Models, the Illinois Input/Output Model and Impact Multiplier Analysis" (1980). In this study, the estimated changes in output in the seven directly impacted industries, along with the invest- ment in the pollution control equipment industry, were used as inputs to the Illinois model. The output of the model was expressed as total annual output and employment impacts in the Illinois economy from RACT II. These impacts are reported in Section 3.2 above. 222 Si*