ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East, P.O. Box 19276, Springfield, Illinois 62794-9276. (217) 782-2829

James R. Thompson Center, 100 West Randolph, Suite 11-300, Chicago, IL 60601 • (312) 814-6026

PAT QUINN, GOVERNOR

April 7, 2010

217/782-5544

217/782-9143 (TDD)

Cheryl Newton, Director

Air and Radiation Division

United States Environmental

Protection Agency Region V

77 West Jackson Boulevard, AR-18J

Chicago, Illinois 60604-3598

Attn: Jay Bortzer

DOUGLAS P. SCOTT, DIRECTOR

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Re: R08-17: IN THE MATTER OF: PROPOSED NEW 35 ILL. ADM. CODE PART

223 STANDARDS AND LIMITATIONS FOR ORGANIC MATERIAL

EMISSIONS FOR AREA SOURCES

Dear~n\

Pursuant to Section 110(a)(2) ofthe Clean Air Act (CAA) (42 U.S.C. §7410 (a)(2)), and Section

28 ofthe Illinois Environmental Protection Act (415 ILCS 5/28), the Illinois Environmental

Protection Agency (Illinois EPA) submits the following amendments to the Illinois State

Implementation Plan (SIP). This submittal complies with the substance ofthe October 20,2009,

e-mail from Mr. John Summerhays to Charles Matoesian ofthe Illinois EPA. See Attachment

18.

On January 2,2008, the Illinois EPA filed a proposal to add a new Part to 35 Ill. Adm. Code with

the Illinois Pollution Control Board (IPCB). Notice ofHearing was filed on February 13,2008.

Public hearings were held on April 30, 2008, in Springfield, Illinois and June 4, 2008, in

Chicago, Illinois. The Illinois EPA filed post-hearing comments in support ofthe proposed

amendments. On May 7,2009, the IPCB adopted a Final Opinion and Order adopting the

proposed rule as 35 Ill. Adm. Code 223.

In order to assist with your review ofthis SIP submittal, the following documents are enclosed:

Rockford. 4302 N. Main St., Rockford, IL 61103 • (815) 987-7760

Elgin. 595 S. State, Elgin, IL 60123. (847) 608-3131

Bureau of Land - Peoria. 7620 N. University St., Peoria, IL 61614. (309) 693-5462

Collinsville. 2009 Mall Street, Collinsville, IL 62234. (618) 346-5120

Des Plaines. 9511 W. Harrison St., Des Plaines,lL 60016. (847) 294-4000

Peoria. 5415 N. University St., Peoria, IL 61614. (309) 693-5463

Champaign. 2125 S. First St., Champaign, IL 61820. (217) 278-5800

Marion. 2309 W. Main St., Suite 116, Marion, IL 62959. (618) 993-7200

Printed on Recycled Paper
Attachment 1)

Attachment 2)

Attachment 3)

Attachment 4)

Attachment 5)

Attachment 6)

Attachment 7)

Attachment 8)

Attachment 9)

Attachment 10)

Attachment 11)

Attachment 12)

Attachment 13)

Attachment 14)

Attachment 15)

Attachment 16)

Attachment 17)

Attachment 18)

Illinois EPA's Proposal Rule, filed January 2,2008

IPCB Order accepting Proposal for Hearing, January24, 2008

Letter from Acting Chairman Girard, IPCB to Jack Lavin, Director,

Department ofCommerce and Economic Opportunity, request for

economic impact study, dated January 31, 2008

IPCB Hearing Officer Order, Notice ofHearings, dated February 13,2008

Illinois EPA's First Errata Sheet, filed April 16, 2008

Transcript ofHearing on April 30, 2008, filed May 7,2008

Illinois EPA's Second Errata Sheet, filed June 4, 2008

Transcript ofHearing on June 4,2008, filed June 11,2008

IPCB Hearing Officer Order, dated June 11,2008

Illinois Register Notice ofProposed Amendments, volume 32, issue 45, p.

17301, published November 7, 2008

Illinois EPA's Third Errata Sheet, filed July 10, 2008

Illinois Environmental Regulatory Group's Comments, filed July 25,2008

Opinion Order ofthe IPCB by A.S. Moore sending proposal to First

Notice, dated October 16,2008

Opinion Order ofthe IPCB by A.S. Moore sending proposal to Second

Notice, dated March 19,2009

JCAR Letter stating the proposed rulemaking was considered at JCAR's

April 21, 2009 meeting with the attached Certification ofNo Objections,

dated April 21, 2009

Adopted Rule, Final Order, Opinion and Order ofthe IPCB by A.S.

Moore, dated May 7, 2009

Illinois Register Notice ofAdopted Rule, volume 33, issue 25, p. 8224,

published June 19,2009.

E-mail from John Summerhays to Charles Matoesian

The SIP Checklists are also enclosed to assist in your review. The rulemaking docket can be

found at: http://www.ipcb.state.i1.us/CoollExtemal/CaseView.aspx?referer=results&case=13386.

Iffurther information is required, please contact Shannon Bilbruck ofmy staff at 217/557-4261.
Laurel L. Kroack, Chief

Bureau of Air

Attachments

bcc: Laurel Kroack- letter, checklists

Vicky Von Lanken- letter, checklists

Jim Ross- letter, checklists

AQPS- letter, checklists, attachments

Charles Matoesian- letter, checklists

Shannon Bilbruck-Ietter, checklists, attachments
STATE IMPLEMENTION PLAN CHECKLISTS

In the Matter of:

Illinois Environmental Protection Agency

Bureau ofAir

Division ofLegal Counsel

1021 North Grand Ave. East

P.O. Box 19276

Springfield, Illinois 62794-9276
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Re: Attachment

1. The Submittal is accompanied by a fonnalletter of Yes, Cover

submittal from the Governor or designee. Letter

The date ofsubmittal is April 7, 2010

2. Evidence is provided that the revision has been adopted in Yes, Cover

the State Code or body ofregulations. Letter, 17

• The date of adoption is. May 7, 2009

• Test methods/rules are correctly incorporated by

reference

3. Evidence is provided that the State has the necessary legal Sections 4,

authority under State law to adopt and implement the 10,27, & 28

reVISIOn ofthe Ill. Env.

Prot. Act

4. A copy ofthe actual regulation or document is included in 16, 17

the submittal

5. Evidence is provided that the State followed all the 1,2,3,4,6,8,10,

requirements ofits Administrative procedures Act (or 13,14,15,16,

equivalent) in conducting and completing 17

adoption/issuance ofthe revision.

6. Evidence is provided that public notice was given by the 2,4, 10, 17

State, including the date of publication.

7. Certification is provided that the public hearing was held in 4,6,8

accordance with the infonnation provided in the public

notice.

The dates ofthe public hearings were April 30, 2008, &

June 4, 2008

8. The submittal contains a compilation ofthe exhibits 6,8,9,16

entered into the record at hearing.

9. The submittal contains a compilation ofpublic comments 16,*See

Board website
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Re: Attachment

1. The regulated pollutants affected by revision are: sulfur

dioxide__; ozone ~; particulate matter__; I

nitrogen dioxide ; carbon monoxide

2. Attainment status designation for the affected area is 1

included in the submittal.

Status ofthe attainment plan for the affected area is 1

included in the submittal.

The attainment date for the affected area is included in the 1

submittal.

3. The locations and types of affected sources are identified. 1,4,16,17

4. Changes in SIP-allowable emissions for affected sources 1, 13, 16

are quantified or estimated.

Changes in actual emissions from affected sources are 1, 13, 16

quantified or estimated.

5. Evidence is provided that the NAAQS will be protected if 1

the revision is approved and implemented.

Evidence is provided that the PSD increment will be 1

protected ifthe revision is approved and implemented.

Evidence is provided that the RFP demonstration will be N/A

protected ifthe revision is approved and implemented.

Evidence is provided that visibility will be protected ifthe N/A

revision is approved and implemented.

6. Modeling infonnation is provided (if necessary) in support 1

ofthe revision.

7. The proposed emission limitations are based on continuous N/A

emissions reduction technology.

8. The emissions limitations requirements are incorporated (if 16, 17

necessary) to ensure emission levels.

The work practice standards requirements are incorporated N/A

(if necessary) to ensure emission levels.

The recordkeeping/reporting requirements are incorporated 16, 17

(if necessary) to ensure emission levels.

9. The submittal contains enforcement/compliance strategies, 16, 17

including how compliance will be detennined in practice

and at what frequency.
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Re: Attachment

1. Applicability

What sources are being regulated? 1,4,16,17

What are criteria for exemption? N/A

Is calculation procedure for exemption clearly specified? N/A

Is emission inventory listed in the background document of 1, 6, 16

the attainment demonstration?

Are the averaging times used in the rule different from N/A

those ofthe ambient standard?

What are the units of compliance (lbs VOC per gallon of Mass per

solids applied less water, grains per standard cubic foot)? volume of

VOMin

products

Is bubbling or averaging of any type allowed? If yes, state NO

criteria. Could a USEPA inspector independently

determine ifthe criteria were met? Does EPA have to

approve each case?

Ifthere is a redesignation, will this change the emission N/A

limitations? If yes, which ones and how?

2. Compliance Dates

What is the compliance date? 16, 17

What is the attainment date? 2010

3. Specificity ofConduct

What test method is required? 16, 17

What is the averaging time in compliance test method? N/A

Is a compliance calculation or evaluation required? (i.e., N/A

daily weighted average for VOC)

If yes, list the formula, period of compliance, and/or N/A

evaluation period.

4. Incorporation by Reference

What is the state authority for rulemaking? Sections 4,

10,27, & 28

ofIll. Env.

Prot. Act

Are methods/rules incorporated by reference in the right Yes: 16, 17

manner?

5. Recordkeeping

What records are required to determine compliance? 16, 17

In what form or units (lbs/gal, gr/dscf, etc...) must the 16, 17

records be kept? On what time basis (instantaneously,
hourly, daily)?

Does the rule affinnatively require the records be kept? Yes

6. Exemption

List any exemptions allowed. See IEPA's Statement of No

Proposal-attachment1

Is the criteria for application clear? N/A