### 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 FORAREA 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 orderto 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 ofLand

- 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 PaperAttachment 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 JackLavin, 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 RegisterNotice ofProposed Amendments, volume 32, issue 45, p. 17301, publishedNovember 7, 2008 Illinois EPA's Third Errata Sheet, filed July 10, 2008 Illinois Environmental Regulatory Group's Comments, filed July25,2008 Opinion Order ofthe IPCB byA.S. Moore sendingproposal to First Notice, dated October 16,2008 Opinion Orderofthe IPCB byA.S. Moore sending proposal to Second Notice, dated March 19,2009 JCAR Letter stating theproposedrulemaking 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 byA.S. Moore, dated May 7, 2009 Illinois RegisterNotice 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 enclosedto assist in yourreview. The rulemaking docket canbe found at: http://www.ipcb.state.i1.us/CoollExtemal/CaseView.aspx?referer=results&case=13386. Iffurther information is required, please contact Shannon Bilbruck ofmy staffat 217/557-4261.

### Laurel L. 

### Kroack, Chief Bureau ofAir Attachments

bcc: Laurel Kroack- letter, checklists VickyVon Lanken- letter, checklists Jim Ross- letter, checklists AQPS- letter, checklists, attachments Charles Matoesian- letter, checklists Shannon Bilbruck-Ietter, checklists, attachmentsSTATE IMPLEMENTION PLAN CHECKLISTS

In the Matterof:

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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### ij;ilii·ijijiiii.·i.iilil< Re: Attachment 1. 

### The Submittal is accompaniedby a fonnalletter of Yes, Cover submittal from the Governor ordesignee. Letter The date ofsubmittal is April 7, 2010 2. Evidence is providedthatthe revision has been adopted in Yes, Cover the State Code orbody ofregulations. Letter, 17


## • The date ofadoption is

. May 7, 2009


## • Test methods/rules are correctlyincorporatedby reference 3. Evidence is providedthatthe Statehas the necessarylegal Sections 4, authorityunder State law to adopt and implementthe 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 thatthe 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 thatpublic notice was given bythe 2,4, 10, 17 State, including the date ofpublication. 7. Certification is provided thatthe public hearing was held in 4,6,8 accordance with the infonnationprovided 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 athearing. 9. The submittal contains a compilation ofpublic comments 16,*See Boardwebsite**1~1~!;~~II~i~~ 11~I~i~l;i**  

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### iTAh'.**~liiiiii;iifliili~li!lii~iiiii:iiilliilliflii .lJ5'\1JrlNI(iiJAlli:H~;(** **~K** ·.'JQii Re: Attachment 1. The regulatedpollutants affectedbyrevision 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 ofaffected 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 visibilitywill be protected ifthe N/A revision is approved and implemented. 6. Modeling infonnation is provided (ifnecessary) 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 workpractice standards requirements are incorporated N/A (ifnecessary) to ensure emission levels. The recordkeeping/reporting requirements are incorporated 16, 17 (ifnecessary) 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.;llllil'l'\titlH**'''f7~Tl~I!!!!!!!11!!!iii!i** iiii·

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## /1!;.1: Re: Attachment 1. Applicability What sources are being regulated? 1,4,16,17 What are criteria for exemption? N/A Is calculationprocedure 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 ofcompliance (lbs VOC per gallon of Mass per solids applied less water, grains per standard cubic foot)? volume of VOMin products Is bubbling or averaging ofanytype allowed? Ifyes, state NO criteria. Could aUSEPA inspectorindependently determine ifthe criteriawere met? Does EPAhave to approve each case? Ifthere is aredesignation, will this change the emission N/A limitations? Ifyes, 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 evaluationrequired? (i.e., N/A dailyweighted average for VOC) Ifyes, listthe formula, period ofcompliance, and/or N/A evaluation period. 4. Incorporation byReference What is the state authority for rulemaking? Sections 4, 10,27, & 28 ofIll. Env. Prot. Act Are methods/rules incorporatedbyreference in the right Yes: 16, 17 manner? 5. Recordkeeping Whatrecords are required to determine compliance? 16, 17 In what form orunits (lbs/gal, gr/dscf, etc
...) mustthe 16, 17 records be kept? On what time basis (instantaneously,hourly, daily)? Does the rule affinnativelyrequire the records be kept? Yes 6. Exemption List any exemptions allowed. See IEPA's Statement of No Proposal-attachment 1 Is the criteria for application clear? N/A