ILLINOIS ENVIRONMENTAl PROTECTION AGENCY 

1021 NORTH GRAND A VENU E EAST, P.O. BOX 19276, SPRINGFIELD, ILLINOIS 62794-9276 • (217) 782-3397 

PAT QUINN, GOVERNOR JOHN J. KIM, INTERIM D l RECTOR 

2171782-5544 

2171782-9143 (TDD) 

September 11, 2012 

George Czerniak, Acting Director 

Air and Radiation Division 

United States Environmental 

Protection Agency Region V 

77 West Jackson Boulevard, AR-18J 

Chicago, Illinois 60604-3598 

SEP I 

CERTIFIED MAIL 

RETURN RECEIPT REQUESTED 

7009 2820 0001 7496 1749 

Re: R12-8: IN THE MATTER OF: AMENDMENTS TO 35 ILL. ADM. CODE 

PART 223, STANDARDS AND LIMITATIONS FOR ORGANIC MATERIAL 

EMISSIONS FOR AREA SOURCES 

Dear Ntf. Cz ak: 2::0 / 

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

Section 28 of the 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 of 

the October 20, 2009, e-mail from Mr. Jolm Smmnerhays to Charles Matoesian of the 

Illinois EPA. See Attachment 17. 

On July 13, 2011, the Illinois EPA filed a proposal to amend Part to 3 5 Ill. Adm. Code 

223 with the Illinois Pollution Control Board (!PCB). Notice of Hearing was filed on 

August 4, 2011. Public hearings were held on October 6, 2011, in Springfield, Illinois and 

November 17, 2011 , in Chicago, Illinois. The Illinois EPA filed post-hearing comments in 

support of the proposed amendments. On May 14, 2012, the IPCB adopted a Final 

Opinion and Order adopting the amendments to 3 5 Ill. Adm. Code 223. 

4302 N. M ain St., Rockford, ll 6 1 I 03 (81 5 )987 -77 60 

595 S. Stol e, Elgin, ll 60 123 (847)608-3 131 

2 125 S. First St., Champaign, IL 6 1820 (217)278-5800 

2009 Mall St., Collinsville, IL 62234 (6 18)346-5 120 

PLEASE PRINT ON RECYCLED PAPER 

95 11 Harrison St., Des Plaines, IL 600 16 (847)294-4000 

5407 N. University St., Arbor 1 13, Peoria, ll61614 (309)693 -5462 

2309 W. Main St., Suite 116, Marian, ll 62959 (6 18)993-7200 

100 W. Randolph, Suite 11 -300, Chicago, IL 60601 (3 12)814-6026 
In order to assist with your review of this SIP submittal, the following docwnents are 

enclosed and an electronic disc is included which contains identical copies of these 

documents: 

Attachment I) 

Attachment 2) 

Attachment 3) 

Attaclunent 4) 

Attaclunent 5) 

Attaclunent 6) 

Attaclunent 7) 

Attaclunent 8) 

Attaclunent 9) 

Attaclunent 1 0) 

Attaclunent 11) 

Attaclunent 12) 

Attaclunent 13) 

Attaclunent 14) 

Attaclunent 15) 

Illinois EPA's Regulatory Proposal, filed July 13,2011 

Letter from Acting Chairman Girard, IPCB to Warren Rib ley, 

Director, Department of Commerce and Economic Opportunity, 

request for economic impact study, dated August 4, 2011 

IPCB Order accepting Proposal for Hearing, August 4, 2011 

IPCB Hearing Officer Order, Notice of Hearings, dated August 4, 

2011 

Prefiled Testimony ofRory Davis 

Prefiled Testimony of the Consumer Specialty Products Association 

DCEO Rejection of carrying out an economic impact study, 

September 28, 2011 

Transcript of Hearing on October 6, 2011 

Hearing Officer Order, November 17, 2011 

Transcript of Hearing on November 18, 2011 

Order of the Board sending rulemaking to First Notice, dated 

January 5, 2012 

Illinois Register Notice of Proposed Amendments, volume 36, 

issue 3, p. 727, published January 20, 2012 

J CAR Request for Economic and Budgetary Effects, January 19, 

2012 

Opinion Order ofthe IPCB by T.A. Holbrook sending proposal to 

Second Notice, dated March 15, 2012 

JCAR Letter accepting the Standards and Limitations for Organic 

Material Emissions for Area Sources for Second Notice. Dated 

March 19, 2012 
Attachment 16) 

Attaclunent 17) 

Attachment 18) 

Adopted Rule, Final Order, Opinion and Order of the IPCB by T.A. 

Holbrook, dated May 3, 2012 

Illinois Register Notice of Adopted Rule, volume 36, issue 20, p. 

7569, published May 18,2012 

E-mail from John Summerhays to Charles Matoesian 

The SIP Checklists are also enclosed to assist in your review. If further infonnation is 

required, please contact Shannon Bilbruck of my staff at 217/782-5544. 

Cordially, 

·j~{~J[_~ Laurel L. Kroack, Chief 

Bureau of Air 

Attachments 
STATE IMPLEMENTION PLAN CHECKLISTS 

In the Matter of: 

R12-08: IN THE MATTER OF: AMENDMENTS TO 35 ILL. ADM. CODE PART 223, 

STANDARDS AND LIMITATIONS FOR ORGANIC MATERIAL EMISSIONS FOR 

AREA SOURCES 

Illinois Environmental Protection Agency 

Bureau of Air 

Division of Legal Counsel 

1021 North Grand Ave. East 

P.O. Box 19276 

Springfield, Illinois 62794-9276 
.. ADMIN'ISTRATIVE · CIIEC:k.tlST ::> : 

Re: Rl2-08 Attachment 

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

submittal from the Governor or designee. Letter 

The date of submittal is 5e pl. 111 "l-0 I '2-- August X*;' 

~ 

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

the State Code or body of regulations. Letter, 17 

• The date of adoption is . May 18, 2012 

• Test methods/rules are correctly incorporated by N/A 

reference 

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

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

revlSlon the Ill Env. 

Prot Act 

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

the submittal 

5. Evidence is provided that the State followed all the 1,2,3,4,8,9,1 0, 

requirements of its Administrative procedures Act (or 11,12,14,15, 

equivalent) in conducting and completing adoption/issuance 16,17 

of the revision. 

6. Evidence is provided that public notice was given by the 3, 4, 11, 12, 

State, including the date of publication. 14, 16, 17 

7. Certification is provided that the public hearing was held in 4,8,10,11 

accordance with the information provided in the public 

notice. 

The dates of the public hearings were October 6, 2011, & 

November 17, 2011 

8. The submittal contains a compilation of the exhibits entered 8,10,11 

into the record at hearing. 

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

Board website 
<;.;< .. :::::<· .::······<···· !'·}· .r.,:r ~> ·: ~ i 

Re: R12-08 A 

1. The regulated pollutants affected by revision are: sulfur 

dioxide __ ; ozone __x_; particulate matter __ ; 1 

mu;;cu dioxide ; carbon monoxide ; lead 

2. Attainment status designation for the affected area is I 

included in the submittal.· 

Status of the 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 lncMinns and types of: sources are •~ · I ,16 

4. Changes in SIP-allowable emissions for affected sources are N/A 

.~ or estimated. 

Changes in actual emissions from affected sources are I 

or estimated. 

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

the revision is "JJJJlU vcd and ;, ,,, " 

Evidence is provided that the PSD increment will be 1 

~ if the revision is and· 

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

"if the revision is "~JJ!uved and'· ·' ted 

Evidence is provided that visibility will be protected if the N/A 

reVISIOn lS ~and imnl. -~ 

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

of the revision. 

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

emissions reduction -'- >10gy, 

8. The emissions limitations requirements are incorporated (if N/A 

y) to ensure emission levels. 

The work practice standards requirements are incorporated N/A 

(if nP~ to ensure emission levels. 

The recordkeeping/reporting requirements are incorporated N/A 

(if to ensure emission levels. 

9. The submittal contains enforcement/compliance strategies, N/A 

including how compliance will be detennined in practice 

and at what "-
'•••·ENFORCEABILITY CIIECK:Lisr·· ................ ················' ; • ; .. •. 

Re: Rl2-08 Attachment 

L AQQlicability 

What sources are being regulated? I 

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 I 

the attainment demonstration? 

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

those of the ambient standard? 

What are the units of compliance ? Percent VOM 

by Weight 

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

criteria. Could a USEP A inspector independently 

determine if the criteria were met? Does EPA have to 

approve each case? 

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

limitations? If yes, which ones and how? 

2. ComQliance Dates 

What is the compliance date? July I, 2012 

What is the attainment date? N/A 

3. SQecificity of Conduct 

What test method is required? N/A 

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. Incomoration by Reference 

What is the state authority for rulemaking? Sections 4, 27, & 

28 oflll. Env. 

Prot. Act 

Are methods/rules incorporated by reference in the right N/A 

manner? 

5. RecordkeeQing 

What records are required to determine compliance? N/A 

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

records be kept? On what time basis (instantaneously, by Weight 

hourly, daily)? 

Does the rule affirmatively require the records be kept? N/A 

6. ExemQtion 

List any exemptions allowed. See !EPA's Statement of N/A 

Proposal-attachment I 

Is the criteria for application clear? N/A