# C 1

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

TABLE OF CONTENTS IN THE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERlALEMISSIONS FROM GROUP 

### N CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE21l, 218, and 219

1. Notice ofFiling ) ) ) ) ) ) ) ) 

### Rl0- 

# ;,1) (Rulemaking-Air) 

### RECEIVED

CLERK'S OFFICE



## MAR 06 2010 STATE OF iLLINOIS 

### Pollution Control Board 2. Appearance ofDanaVetterhoffer, Assistant Counsel 

### for the D1inois Environmental Protection Agency 3. Proposal ofRegulations by DirectorDouglas P. Scott 4. Certificatlon ofRequired Rule 5. Certification ofOrigination 6. Agency Analysis ofEconomic and BudgetaryEffects 7. Motion for Waiver ofCopy Requirements 8. FastTrack Rulemaking CoverSheet 9. Statement ofReasons 10. Proposed Amendments to 35 IlL Adm. Code Parts 211, 218, and 219 11. Technical SupportDocumenlfor Control ofVolatUe OrganiCMaterial Emissions in Non-AttainmentAreas from MiscellaneousMetal andPlasticParts Coatings; Automobile andLight-Duly TruckAssembly Coatings; Miscellaneous Industrial Adhesives; andFiberglass BoatManufacturingMaterials, 

### AQPSTR 10-01, Illinois Environmental Protection Agency, January 2010 12. Documents Relied Upon: Control Techniques GuidelinesforMiscellaneous Metal andPlastic Parts Coatings, 

### United States Environmental Protection Agency, Office ofAir QualityPlaMing and Standards, Research Triangle Park, NC, September 2008.
1Control Techniques GuidelinesforAUlomobile andLight-Duty TruckAssembly Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2008. Control Techniques GuidelinesforMiscellaneous IndustrialAdhesives, United States Environmental Protection Agency, Office of

### Air Quality Planning and Standards, Research Triangle Park, NC, September2008. Control Techniques Guidelinesfor Fiberglass BoatManufacturingMaterials, United States Environmental Protection Agency. Office of

### Air Quality Planning and Standards, Research Triangle Park. NC, September2008, Consumer and CommercialProducts. Group IV: Control Techniques Guidelines in Lieu of Regulations forMiscellaneous MelalProducts Coatings. PlasticParis Coatings. Auto andLight-Duty TruckAssembly Coatings. Fiberglass Boat Manufacturing Materials. andMiscellaneous IndustrialAdhesives, 73 FR 58481- 58491 (October 7, 2008). NationalEmission Standardsfor HazardousAirPollutants: Surface Coating of Automobiles andLight-Duty Trucks; NationalEmission Standardsfor HazardousAir Pollutantsfor Surface Coaling of PlasticParIS andProducts, 72 FR 20227-20237 (April 24, 2007). Illinois Environmental ProtectionAct (415 ILCS 5tel seq.) Clean AirAct (42 U.S.C 7401 

### etseq.) Incorporations by reference: "Protocol for Determining the Daily Volatile Organic Compound Emission Rate ofAutomobile andLight-Duty TruckPrimer-Surfacer and Topcoat Operations," September 2008, United States Environmental Protection Agency, Washington, D.C., EPA-453/R-08-002 40 CFR 63, Subpart PPPP, Appendix A (2008). 46 CFR, Subchapter Q (2007). 46 

### CFR SubchapterT (2008). A.S.T.M.D-523-80. A.S.T.M.D-523-89. Federal Insecticide, Fungicide, andRodenticide Act, 7 U.S.C. Section 136 (2009). 2

### American Architectural Manufacturers Association Specification 2604-05 (Voluntary Specification, Perfonnance Requirements and TestProcedures for High Perfonnance Organic Coatings on Aluminum Extrusions and Panels) (2005). American Architectural Manufacturers Association Specification2605-05 (V

### oJuntary Specification, Perfonnance Requirements and Test Procedures for SuperiorPerforming Organic Coatings on Aluminum Extrusions and Panels) (2005). 13. Certificate ofService 14. First Notice Fonns 15. Disk in Microsoft WORD containing Agency's Proposed Amendments toParts 211, 218, and 219, and First Notice Fonns



### 3

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

NOTICE IN THE MAttER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANlC MATERJAL EMISSIONS FROM GROUP 

### IV CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219 ) ) ) ) ) ) ) ) 

### RIO.;;,O (RuJemak:ing-Air) 

## RECEIVED

ClERK'S OFFICe



## MAll 08 2010 STATE 

### OF IWNOIS 

### Pollution COl'llfoiBoard To: John Therriault, Assistant Clerk Illinois Pollution Control Board James

### R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Il1inois 60601-3218 Virginia Yang Deputy Legal Counsel Illinois Department ofNatural Resources One Natural Resources Way Springfield, IL 62702 Matthew Dunn, Chief
. Division ofEnvironmental Enforcement Office ofthe Attorney General 69 W, Washington, Suite 1800 Chicago, IL 60602

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control Board the REGULATORY PROPOSAL entitled "REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP 

### IV CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219," MOTIONFOR WAlVEROF COPY REQUIREMENTS, and APPEARANCE ofthe Illinois Environmental Protection Agency, a copy ofwhich is herewith served upon you. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:((<,yv;..,..

# Jrdi;;;j~ Dana Vetterhoffer. Assistant Counsel Division ofLegal CounselDATED: March 3, 2010 ]021 N. Grand 

### Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544 

### THIS fiLING IS SUBMITTED ON RECYCLED PAPER

### BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
IN THE MATTER OF REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP N 

### CONSUMER & 

### COMMERCIAL

.PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE211, 218, and 

### 219 ) ) ) ) ) ) 

### ) ) 

### RJO- (Rulemaking-Air)



### APPEARANCE The undersigned hereby enters her appearance as an attorney on behalfofthe illinois Environmental Protection Agency. Respectfully submitted, 

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By: 

## C'-o-ha-

# r!d/z..&~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel 

### DATED: March 3, 2010 1021 N. Grand Ave. East 

### P.O. Box 19276 Springfield, 11 

### 62794-9276 (217) 782-5544

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP 

### IV CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 351L1. ADM. CODE 211,218, and 219 

### ) ) ) ) ) 

### ) ) ) 

### RIO- 

# ;I? (Rulemaking-Air} 

### RlEC&!'VED

CLERK'S OFFICE



## MAR U

### IJ 

## 2010 STATE OF IlliNOIS 

### Pollution Conltol Board ILLINOIS ENVIRONMENTAL PROTECTION AGENCY PROPOSAL OF REGULATIONS The lIIinois Environmental Protection Agency moves that the lIlinois Pollution Control Board adopt the attached regulations.
Respectfully submitted, 

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# By:~P20A Director


### DATED: 

### JoouMj 12. 

### ,2010 1021 N. Grand Ave. East 

### P,O. Box 

### 19276 Springfield, 

### IL 62794-9276 (217) 782-5544BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

CERTIFICATION OF REOillRED RULE IN THE MAITER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACn FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP N CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219 ) ) ) ) ) ) ) )

# RI0-~ (Rulemaking-Air) 

### fU:!CEIV'ED

CLERK'S 

### OFFICE



## MAR 

## 08 

## 2010 STATE OF 

### fLUNOIS 

### Pollution Control

### Board
The Illinois Environmental Protection Agency certifies in accordance with 35 Ill. Adm. Code 102.202(h) and 102.500, and 415 ILCS 5128.2(b), that it believes that this proposal for amendments to 35 Ill. Adm. Code211, 218, and 219 is afederally required rule under Sections 172(c)(1) and 182(b)(2) ofthe Clean 

### Air Act ("CAA"). 42 U.S.C. 

### §§ 7502(c)(I) and 75l1a(b)(2). The proposal for amendments is needed to satisfy Illinois' obligation to submit a State Implementation Plan ("SIP") for sources ofvolatile organic materials ("VOM") emissions in
areas designated as nonattainment with respect to the ozoneNational AmbientAir Quality Standard. Section 172(c)(1) ofthe CAA provides that states must include in their SIPs for nonattainment areas ''reasonably available control measures," including "reasonably available control technology" ("RACT''), for sources ofemissions. 42 U.S.C. 

### § 7502(c)(I). Section 182(b)(2) ofthe CAA provides that, for ozone nonattainment areas, the Statemust revise its SIP to includeRACT for sources ofYOM emissions covered by a control techniques guideline ("CTG") issued between November 15, 1990, and the date ofattainment. 42 U.S.C. 

### § 75lla(b)(2).

1

### The proposed amendments are intended to establishRACT requirements for Group IV Consumer and Commercial Product categories in responseto CTGs issued by the United States Environmental Protection Agency on October 7, 2008, 

### and thereby satisfy the CAArequirements described above. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By Cl',c?Uy:l. 

### DanaVetterhoffe; Assistant Counsel Division ofLegal Counsel
DATED: March 

### 3, 2010 1021 

### N. Grand Ave. East P.O. Box 19276 Springfield, 

### IL 62794-9276 (217)'782-5544

2BEFORETHE ILLINOIS POLLUTION CONTROL BOARD
IN TIlE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FORVOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP 

### IV CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. 

### ADM. CODE 211,218, alld 219 ) ) ) ) ) ) ) ) RIO- 

# dO (Rulemaking-Air) 

### RECEIVED CLERK'S 

### OFFICE



## MAR

# a 820m STATE OF 

### lLUNOIS Pollution Control

## BoIiid

CERTIFICATION OF ORIGINATION The Illinois Environmental Protection Agency certifies in accordance with 35 111. Adm. Code 102.202(1) that this proposal for amendments to 35 

### TIL Adm. Code 211,218, and 219 amends the most recent version ofthe rules as published on the Illinois Pollution Control Board's website. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By: 

### Qy>.i>4

# \~ DanaVetterhoffer Assistant Counsel Division ofLegal Counsel
DATED: March3,20JO 1021 

### N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544Agency: Part!Title: Agency Analysis ofEconomic and Budgetary Effects ofProposed RuJemaking TIlinois Pollution Control Board Definitions and General Provisions (35 III. Adm. Code Part 21 J)
Illinois Register Citation:

_ Please attempt to provide as dollar-specific responses as possible and feel free to add any relevant explanation. J. Anticipated effecl on State expenditures andrevenues. (a) Current cost to the agency for this program/activity. (approximately) $ 0 per year (b) Ifthis rulemaking will result in an increase or decrease in cost, specify the fiscal year in which this change will first occur and the dollar amount ofthe effect. N/A (c) Indicate the funding source, including Fund and appropriation lines, for this program/activity. N/A (d) Ifan increase or decrease in the costs ofanother State agency is anticipated, specifY the fiscal year in which this change will first occur and the estimated dollar amount ofthe effect. N/A (e) Will this rulemaking have any effect on State revenues or expenditures not already indicated above? No 2. Economic effect on persons affected by the rulemaking: Cal Indicate the economic effect and specify the persons affected: Positive

_ Negative

__ No effect-X Persons affected: Owners and operators of affected automobilo and light duty truck assembly coating lines, miscellaneous metal parts and products coating lines, plastic parts and products coating lines. sources using miscellaneous industrial adhesives. and sources using fiberglass boat manufacturing materials. Dollar amountperpcrson: _0_ Total statewide cost:

__ 0 (b) Ifan economic effectis predicted, please briefly describe how the effect will occur. N/A

### (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? No Will there be any change in requirements such as filing, documentation, reporting or completion offonns? No The proposed changes to Part 211 should have no indirect effect that mav result in increased administrative costs.Agency: Agency Analysis ofEconomic and Budgetary Effects ofProposed Rulemaking Illinois Pollution Control Board ParlITitle: Organic Material Emission Standards andLimitations for the Chicago Area C35 Ill. Adm. Code Part218) Illinois Register Citation:**~_** Please attempt to provide as dollar-specific responses as possible and feel free to add any relevant explanation. 1. Anticipated effect on State expenditures and revenues. Ca) Current costto the agency for thisprogram/activity.
. -$50.300 per year (b) II this rulemaking will result in an increase or decrease in cost, specify the fiscal year in which this change will first occur and the dollar amount ofthe effe.:t. ' N/A (c) Indicate the funding source, including Fund and appropriation lines, for this program/activity. N/A (d) II an increase or decrease in the costs of another State agency is anticipated, specify the fiscal year in which this change will first occur and the estimated dollar amount ofthe effect. N/A (e) Will this rulemaking have any effect on State revenues or expenditures not already indicated above? No 2. Economic effect on persons affected by the rulemaking: (a) Indicate the economic effect and specify the persons affected: Positive

_ Negative No effect

__ Persons affected: See list ofpotentially affected sources in TSD. Dollar amount per person: Affected miscellaneous metal andplastic parts coating operations: $0-1760Iton Affected automobile and light-duty truck assembly coating operations: $0 Affected miscellaneous industrial adhesive sources: $0-270Iton Affected fiberglass boatmanufacturing facilities: :;;0 Total statewide cost Affected miscellaneous metal and plastic parts coating operations: $2820/day Affected automobile and Iight-duty truck assembly coating operations: $0 Affected miscellaneous industrial adhesive sources: $97/dayAffected fiberglass boat manufacturing facilities: $0 (no affected sources) (b) If an economic effect is predicted, please briefly describe how the effect will occur. Costs due to control measures and switching to low-VOM materials at affected sources, as described in TSD. (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? Will there be any change in requirements such as filing, documentation, reporting or completion offorms? The rulemaklng will require a small amount ofadditional reporting but should have no more than a negligible indirect effect that maY result in increased administrative 

### costs.Agency: 

### Agency Analysis ofEconomic and BudgetaryEffects ofProposedRulemaking Illinois Pollution Control Board Partffitle: Organic Matcrial Emission Standards and Limitations for the Metro East Area (35 

## m. Adm. Code Part 219) minois Rcgister Citation:

_ Please attempt to provide as dollar-specific responses as possible and feel 

### fre:: to add any relevant explanation. 1. Anticipated effect on State expenditures and revenues. (a) Currentcost to the agency for thisprogram/activity. -$5,500 

### per vear (b) If this rulemaking will result in an increasc or decrease in cost, specify the fiscal year in which this change will first OCcurand the dollar amountofthe effect. NIA (c) Indicate the funding source, including Fund and appropriation lines, for this program/activity. NIA (d) If an increase or decrease in the costs of another State agency is anticipated, specify the fiscal year in which this cbange will first occur and the estimated dollar amount ofthe effecl. NI A . (e) Will this ruteroaking have any effect on State revenues or expenditures not already indicated above? No 2. Economic effect on persons affected by the rutemaking: Ca) Indicate the economic effect and specify the persons affected: Positive

_ Negative

## --.K..- No effect

__ Persons affected: See Ust ofpotentiallv affected sources in TSD. Dollar amount perperson: Affccted miscellaneous metal and plastic parts coating operations: $0-1760/ton Affected automobile and light-duty truck assembly coating operations: $0 Affccted miscellaneous industrial adhesivc sources: $0-270/ton Affected fiberglass boat manufacturing facilities: $0 Total statewide cost AfIected miscellimeous metal and plastic parts coating operations: $374/day Affected automobile and lighHluty truck assembly coating operations: $0 (no affected sources)Affected miscellaneous industrial adhesive sources: $IO/day Affected fiberglass boat manufacturing facilities: $0 (no affected sources) (b) If an economic effect is predicted, please briefly describe how the effect will occur. Costs due to control measures or switching to low-VOM materials at sources, as described in TSD. (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? Will there be any change in requrrements such as filing, documentation, reporting or completion offorms? The rulemak.ing will require a small amount ofadditional reporting but should have no more than a negligible indirect effect that may result in increased admioist.-ativc costs.BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATIER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERJAL EMISSIONS FROM GROUP IV CONSUMER 

### & COMMERCIAL PRODUCTS PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219 ) ) ) ) ) ) ) ) 

### RIO- (Rulemaking-Air) 

### RECEiVED

CLERK'S OFFICE



## MAR U 820m STATE OF IWNOIS MOTION FOR WAIVER OF COPY REOillREMENf-gl1ution Control Board The Proponent, the lIlinois Environmental Protection Agency ("Illinois EPA"), by its attorney, and pursuant to 35 Ill. Adm. Code I01.500, 102.110, 102.200, and 102.402, respectfully moves that the TIlinois Pollution Control Board ("Board") waive the requirement that the Illinois EPA submit the original and nine copies ofthe regulatory proposal including all documents relied upon, and waive the requirement that the Illinois EPA provide copies ofcertain documents relied upon. In support ofits Motion, Illinois EPA states as follows: 

### 1. Section 102.200 ofthe Board's procedural rules requires that the original and nine copies ofeachregulatory proposal be filed with the Clerk. 35 

### TIl. Adm. Code Section 102.200. Section 27(a) ofthe Environmental Protection Act also requires that the Illinois EPA provide infonnation supporting aregulatoryproposal. 415 ILCS 5!27(a). 2. The Illinois EPA directly relied upon several documents when drafting theregulatory proposal, and incorporated byreference certain documents as welL The documents relied upon/incorporatedbyreference are as follows:


### a. Control Techniques Guidelinesfor Miscellaneous MetalandPlastic Paris Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September2008.

1b. Control Techniques GuidelinesforAutomobile andLight-Duty TruckAssembly Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2008.
c. Control Techniques Guidelinesfor Miscellaneous IndustrialAdhesives, United States Environmental Protection Agency, Office of

### Air Quality Planning and Standards, Research Triangle Park, NC, September 2008. d. Control Techniques GuidelinesforFiberglass BoatManufacturing Materials, United States Eovironmental Protection Agency, Office ofAir Quality Planning and Standards, Research TrianglePark, NC, September2008.
e. Consumerand Commercial Products, Group IV: Control Techniques Guidelines in Lieu of RegulationsforMiscellaneousMetal Products Cootings, PlasticPorts Coatings, Auto andLight-Duty TruckAssembly Coatings, FiberglassBoat ManufacturingMaterials, andMiscellaneous IndustrialAdhesives, 73 Fed. Reg. 58481-58491 (October 7, 2008). f. NationalEmission StandardsforHazardous AirPollutants: Surface Coating of Automobiles andLight-Duty Trucks; NationalEmission StandardsforHazardousAir Pollutantsfor Surface Coating of Plastic Pans andProducts, 72 Fed. Reg. 20227- 20237 (April 24, 2007). g. Dlinois Environmental Protection Act (415 ILCS 51etseq.). h. Clean A;r Act (42 U .S.c. 7401 et seq.).
1. IncOl])oratioos by reference: 1. "Protocol for Determining theDaily Volatile Organic CompoundEmission Rate ofAutomobile and Light-DUty Truck Primer-Surfacer and Topcoat Operations", September 2008, United Stales Environmental Protection Agency, Washington, D.C., EPA--4531R-08-002. 2. 40 CFR 63, SubpartPPPP. Appendix A (2008). 3. 46 CFR, Subchapter Q (2007). 4. 46 CFR, SubchapterT (2008). 5. A.ST.M. D-523-80. 6. A.S.T.M D-523-89. 7. Federal Insecticide. Fungicide, and Rodenticide Act, 7 U.S.C. Section 136 (2009). 28. American Architectural Manufacturers Association Specification 2604-05 (Voluntary Specification, Perfonnance Requirements and TestProcedures for High Performance Organic Coatings on AluminumExtrusions and Panels) (2005). 9. American Architectural Manufacturers Association Specification 2605-05 (Voluntary Specification, Perfonnance Requirements and TestProcedures for SuperiorPerforming Organic Coatings on Aluminum Extrusions and Panels) (2005). 3. Several ofthe documents described above--the Illinois Environmental Protection Act, Clean AirAct, several portions ofthe Code ofFederal Regulations, and the Federal Insecticide, Fungicide, and Rodenticide Act--are readily accessible to or arewithin the possession ofthe Board. Given the ease ofaccessibility ofthese documents, listed as items (g), (h), (i)(2), (i)(3), (i)(4), and (i)(7) above, the illinois EPA moves that theBoard waive therequirement thatthe nIinois EPA provide copies ofsuch documents. 4. Section 5-75(a) ofthe Illinois Administrative Procedure Act ("lAPA') provides that
an agency may incorporate byreference the regulations, standards, and guidelines ofan agency ofthe United States or anationally recognized organization or association withoutpublishing the incorporatedmaterial 

### in full. 5 ILCS 100/5-75(a). Section 5-75(c) ofthe lAPA provides, however, that such agency shall maintain a copy ofthe referenced material 

### in at least one ofits principal offices and shall make it available to the public upon request. 5 ILCS 100/5-75(c). 5. In developing this proposed rulemaking, the Illinois EPA incorporated byreference two documents published by the American Society for Testing and Materials ("ASTM") and two voluntary specifications published by the American Architectural Manufacturers Association ("AAMA"), listed above as items (i)(5), (i)(6), (i)(8), and (i)(9). The documents are cop)iTight protected and mustbe downloaded at a costto the Illinois EPA. The Illinois EPA is also subject to additional fees for each copy provided to the Board. 

### In orderto keep costs incurred by the

3Illinois EPA at aminimum, Illinois EPA requests thatthe Board waive the nonnal copy requirements and allow the Illinois EPA to file only the originals ofsuch documents. Attached with the ASTMs is a copy ofthe License Agreement utilized by the ownerofthe copyright, and attached with the AAMA specifications is a copy ofthe copyrightnotice. The Illinois EPA directs the Board's attention to such documents so thatthe Boardmay confono its handling of the standards consistentwith those agreements. 6. The remaining documents in theregulatory proposal consist ofover 700 pages. Given the length ofthe proposal and the resources required to provide nine copies, Illinois EPA requests thatthe Board waive thenormal copy requirements and allow Illinois EPAto file the original and four complete copies ofsuch documents. 

### WHEREFORE, the illinois EPA moves thatthe Board waive the requirement thatthe Illinois EPA provide copies ofthe documents listed 

### as items (g), 

### (Ii), (i)(2), (i)(3), (i)(4), and (i)(7); waive therequirementthat the Illinois EPA provide an original and nine copies ofthe copyrighted materials listed 

### as items (i)(5), (i)(6), (i)(8), and (i)(9), allowing the Dlinois EPA to provide only the originals ofsuch documents; and waive the requirementthatthe Illinois EPA provide an original and nine copies ofthe remaining documents in its proposal, allowing the Illinois EPA to provide the original and four copies. Respectfully submitted, 

### ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# !di~ By 

## CD:> J/\A... IW Dana Vetterhoffer Assistant Counsel Division oftegal Counsel

4

### DATED: March 3, 2010 1021 N. Grand Ave, 

### East P.O. Box 19276 Springfield. 11, 

### 62794-9276 (217) 782-5544

5

# THISISA 

# FASTTRACK RULEMAKING

FILED IN ACCORDANCE WITH SECTION 28.5 OF THE ENVIRONMENTAL PROTECTION ACT (415 ILCS 5/28.5)BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

STATEMENT OF REASONS IN THE MAITER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP IV CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219 

### ) ) ) ) ) ) ) ) 

### RIO·

# dP (Rulemaking-Air)



## RECEIVED

CLERK'S OFFICE



### MAI{ UII 2010 I. INTRODUCTION 

### STATE OF lLUNOIS 

### Pollution Control Board The TIlinois Environmental Protection Agency ("Illinois EPA'') submits this Statement ofReasons to the TIlinois Pollution Control Board ("Board") pursuantto Sections 10,27,28, and 28.5 ofthe Environmental Protection Act ("Act'') (415 ILCS 5/10,27,28, and 28.5) and 35 Ill. Adm. Code 102.202 in support ofthe attached proposal ofregulations. These regulations are proposed to control emissions ofVolatile Organic Material ("VOM"), which is effectively the same as volatile organic compounds ("VOC"), from the following Group IV Consumer and Conunercial Product Categories: Miscellaneous Metal and Plastic Parts Coatings, Auto and Light-Duty Truck Coatings, Miscellaneous Industrial Adhesives, and Fiberglass Boat ManufacturingMaterials, This proposed rulemaking is intended to meet certain obligations ofthe State of Illinois under the federal Clean Air Act 

### ("CAN'), 42U.S.C § 7401 et

### seq. Specifically, the rulemaking is intended to satisfy Illinois' obligation to submit a State Implementation Plan ("SIP") to address requirements under Sections 172 and 182 ofthe CAA for sources ofVOM emissions in areas designated as nonattainment with respect to the ozone National Ambient 

### Air Quality Standard ("NAAQS"). 

### See 42 U.S.c. §§ 7502 and 7511a

### Section 172(c)(I) ofthe CAAprovides that states mustinclude in their Sll's for nonattainment areas ("NMs") "reasonably available control measures" ("RACM"), including "reasonably available control technology" ("RACT"), for sources ofemissions. 42 U.S.C. § 

### 7502(c)(1). Section 182(b)(2) ofthe CAAprovides that, for ozoneNAAs, the Statemust revise its SIP to includeRACT for sources ofVOM emissions coveredby
acontrol techniques guideline ("CTG") issuedbetweenNovember 15, 1990, and the date ofattainment. 42 U.S.C. § 

### 7511a(b)(2). Illinois is proposingreasonable and cost effectiveYOM controls for Group IV Consumer and Commercial Product Categories inresponse to eTGs issuedfor such categories. Included in this proposal are amendments to 35 Ill. 

### Adm. CodePart 218, OrganicMaterial Emission Standards and Limitations for the Chicago Area; 35 

### Ill. Adm. Code 

### Part219, OrganicMaterial Emission Standards and Limitations for the Metro EastArea; and 35 Ill. Adm. CodePart 211, Definitions and General Provisions. II. STATEMENT OFFACTS 

### The eM establishes acomprehensive program for controlling and improving the nation's airquality via state and federal regulations. TheUnited Slates Environmental Protection Agency ("USEPA") is charged withidentifying airpollutants that endanger thepublic health and welfare and with formulating the NMQS that specifythe maximumpermissible concentrations ofthose pollutants in the ambient 

### air pursuant to Sections 108 and 109 ofthe CM. 42 U.S.C. §§ 

### 7408-7409. A. 

### 8-Hour Ozone NAAOS

2

### Ozone occurs both in the Earth's upper atmosphere and at ground level. YOM is
aprimaryprecursor to the fonnation ofground-level ozone, which is fonned when oxides ofnitrogen and YOM react in the atmosphere in the presence ofsunlight. Ground-level
ozone is amajorcomponent ofsmog. 73 Fed. Reg. 

### 58482 (Oct. 7,2008). Exposure to 

### sufficient concentrations ofground-level ozone is associated with agricultural crop loss, damage to forests and ecosystems, and a variety ofhuman health conditions, including acute respiratory symptoms, increased susceptibility to respiratory infection, and pulmonary inflammation. 73 Fed. Reg. 58482. 

### On July 18,1997, USEPA revised the NAAQS for ozone by replacing the I-hour standard with an 8-hour standard. 62Fed. Reg. 

### 38856 (July 18, 1997). 

### In Illinois, there
are two areas designated as nonattainment (moderate) for the 8-hour ozone standard: 1) the Chicago-Gary-Lake County, IL-IN designated area, which includes Cook, DuPage, Grundy (partial-Goose Lake and Aux SableTownships), Kane, Kendall (partial-Oswego Township), Lake, McHenry, andWill Counties; and 2) the S1. Louis, MO-IL designated area, whichincludes Jersey, Madison, Monroe, and St. ClairCounties. 40 CFR 

### § 81.314, B. 

### CAAReguirements 1. Consumer and Commercial Products, Groun IV Section I83(e) ofthe CAA required thatUSEPA conduct a study ofthe emissions ofVOM into the ambient airfrom consumer and commercial products inorder to determine theirpotential to contribute to ozone levels which violate the ozoneNAAQS and to establish criteria forregulating emissions ofVOM from such products, 73Fed. Reg. 

### 58482. Section 183(e) provides, "[T]heAdministrator shall listthose categories of
consumerorcommercial products that the Administrator determines, based on the study,

3account for at least 80 percent ofthe VOC emissions
... from consumer or commercial products in areas that violate the NAAQS for ozone" and shall dividethe categories into groups. 42 U.S.C. 

### § 7511b(e)(3)(A). The CAA requires that USEPA then eitherregulate YOM emissions from such categories orissue a CTG in lieu ofanatiDnal regulation iftbe Administrator determines that sucb guidance will be substantially as effective as regulations 

### in reducing emissions ofVOM which contribute to ozone levels in ozoneNAAs. 42 U.S.C. 

### § 7511b(e)(3)(C). CTGs provide states withrecommendations regarding whattypes ofcontrDls could constitute RACT for YOM for the applicable sourcecategories. 73 Fed. Reg. 58483. States must either adopt regulations to implementthe recommendatiDns in the CTG Dr adopt alternative approaches that constituteRACT. either ofwhich must be submittedto the USEPA for review and approval as part ofthe SIPprocess. 73 Fed. Reg. 58483. On October 7.2008. the USEPA issued final CTGs for Group 

### IV Consumer and Commercial Product Categories. The USEPA required that states submit SIP revisions in response to the CTGs within one year. 73 Fed. Reg. 58484. 2. RACT Requirements USEPA designated the Chicago and Metro East areas in Illinois as nonattainment (moderate) for the 8-hour ozone NAAQS. which triggered requirements underthe CAA fDr adDptingregulations thatreduce emissions sufficiently to demDnstrate attainment of the standard. Section 172(c)(l) ofthe CAA provides. in pertinentpart: (c) Nonattainrnentplan provisions Theplan provisions (including plan items) required to be submitted under this part shall comply with each ofthe following: (l) In general
4Such plan provisions shall provide for the implementation ofall reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a minimum, oheasonably available control technology) and shall provide for attainment ofthe national primary ambient air quality standards. 42 U.S.C. 

### § 7502(c)(1). A subset ofRACM is RACT, which is defined as the lowest emission limitation that aparticular source can meet by applying acontrol technique that is reasonably available considering technological and economic feasibility. 

### See 44

### Fed. Reg. 53762 (September 17, 1979). Additionally, Section 182(b) ofthe CAA provides, in pertinentpart: (b) Moderate Areas Each Statein which all orpart ofaModerateArea is located shall, with respectto the Moderate Area, make the submissions described under subsection (a) of

### this section (relating to Marginal Areas), and shaH also 'submit the revisions to the applicable implementationplan described underthis subsection.
(2) Reasonably available control technology The State shall submit arevision to the applicable implementation plan to include provisions to require the implementation of reasonably available control technology under section 7502(c)(1) ofthis title with respect to each ofthe following: (A) Each category ofVOC sources in the area covered by a CTG document issuedby the Administratorbetween November 15, 1990, and the date ofattainment. 42 US.C. 

### § 75Ila(b)(2). Sections 172 and 182 ofthe CAA establish therequirement for Illinois to submit VOM regulations constituting RACT for Group IV Consumer and Commercial Product



### 5Categories in ozone NAAs classified as moderate and above. lllinois is required to submit its SlP revisions by October 7, 2009. 

### C. Fast Track This regulatory proposal is properly submitted to the Boardunder Section 28.5 of the Act as a fast-track rulemaking. Section 28.5 provides, "Whenthe [CAA] requires rules other than identical in substance rules to be adopted, upon request by the Agency, the Board must adopt rules underfast-track rulemaking requirements." A rule is "required to be adopted" whentheUSEPA "is empowered to impose sanctions against the State for failure to adopt such rules." 415 ILCS 5/28.5. This rulemakingproposal satisfies such criteria. First, the proposed rule is not identical in substance to any federal regulation. The CTGs at issue here are merely guidance documents a state may utilizewhen making YOM RACT detenninations for· Group IV product categories. Second, theproposed rule is required to be adopted. As previously discussed, Sections 172 and 182 ofthe CAA require that Illinois submit as a SIP revision YOM RACTregulations for Group IY categories in ozone NAAs. Pursuant to Section 179 ofthe CAA, two sanctions are available to USEPA ifTIlinois fails to do
so: I) the loss ofhighway funds; and 2) an increase in the emissions offsetratio for New Source Review. 42 U.S.C. 

### § 7509. Further, ifIllinois fails to make an adequate SlP submission, USEPA has the authority to impose aFederal ImplementationPlan pursuant to Section 11 O(c)(l) ofthe CAA. 42 U.S.C. 

### § 7410(c)(I). TIlinois EPA's submittal ofits proposal as a fast-trackrulernaking is therefore appropriate. 

### III. PURPOSE AND EFFECT 

### OF THE PROPOSAL

6As described in detail above, this rulemaking proposal has beenprepared to satisfy Illinois' obligation to submit a SIP revision to address the requirements under Sections 172 and 182 ofthe CAA for sources ofVOM emissions in areas designated as nonattairunent with respect to the ozone NAAQS, 

### See 42 U.S.C. 

### §§ 7502 and 7511a. Additionally, Illinois is required to submitthese SIPrevisions before theUSEPA
can redesignate the Chicago and Metro EastNAAs to attainment ofthe 1997 ozone NAAQS, regardless ofwhether the YOM reductions obtainedby the SIP revisions are actually necessary to achieve attainment ofthe NAAQS
.. Section 107(d)(3)(E) ofthe CAA provides thattheAdministratormaynotredesignate aNAA to attainmentunless the State has a fully-approved SIP for the area seekingredesignation and the Statehas met all applicable requirements ofSection 110 and Part D (which includes the requirement that states adoptYOM RACT rules for categories coveredby a CTG). 42 U.S.C. 

### § 7407(d)(3)(E). 

### In a September 17, 1993, guidance document from Michael H. Shapiro, ActingAssistantAdministrator for Air andRadiation ("Shapiro Memorandum"), the USEPA confinned, U[B]efore EPA can actfavorably upon any State redesignation request, the statutorily-mandated control programs ofsection 110 and part D (thatwere duepriorto the time ofthe redesignation request) musthave been adopted by the State and approved byEPA into the SIP." (Shapiro Memorandum, p. 2).' On July 2,2007, the Illinois EPA submittedto theUSEPA an attainment demonstration for the Metro East NAA for the 1997 8-hour ozone NAAQS. On March

I See also Wall v. USEPA. In Wall, the United States Court ofAppeals for the Sixth Circuit vacated Ibe USEPA's redesignation ofastate 10 attainment, in partbecause the stale failed to promulgale

### vecRACT rules in response to CTGs. TheUSEPA argued that fully adopted 

### vecRACT rules were unnecessary because the state did notneed the reductions from such rules to achieve attainment. The court rejected USEPA's**argumen~** hnlding that the CAA unambiguouslyrequires thata SIP submitted with respect to • redesignalion request contain fully adopted RAeT rules requiredbyPartD. RedesignatloD absentsuch rules was therefore improper, Wall v. USEPA. 265 F.2d 426, 433, 440-42 (6th Cir. 2001). 

### 719,2009, the Illinois EPA submitted an attainment demonstration forthe Chicago NAA
as well. Monitoring data indicates that these areas have, in fact, attained the 1997 8-hour
ozone NAAQS, which qualifies them for redesignation to attainment. These areas cannot be redesignated to attaimnent, however, unless and until the lIIinois EPA submits SIP revisions in responseto the Group IV CTGs and theUSEPA approves suchrevisions. 

### IV. GEOGRAPHIC REGIONS AND SOURCES AFFECTED The geographic'regions subjectto theproposedregulations are the two areas designated as nonattainment for the 8-hour ozone standard: 1) the Chicago-Gary-Lake County, IL-IN designated area, which includes Cook, DuPage, Grundy (partial-Goose Lake and Aux Sable Townships), Kane, Kendall (partial-Oswego Township), Lake, McHemy, and Will COWlties; and 2) the St. Louis, MO-IL designated area, which includes Jersey, Madison, Monroe, and St. ClairCounties. 40 CFR 

### § 81.314. The proposedregulations are generally expectedto affectboth new and existing
sources that are coveredby a Group IV CTG, are located in the Chicago orMetro East NAAs, and meetthe applicability criteria specified in the proposed regulations. Table 23, Section 3.6, and Table 4.2 in the Technical SupportDocument lists the sources potentially affected bythe proposed regulations. 

### V. TECHNICAL FEASIBILITY AND ECONOMIC REASONABLENESS

The technology for controlling YOM emissions from Group IV product categories is both technically feasible and economically reasonable. Affected sources can meetthe requirements in the proposed amendments through anumber ofreadily available control

. techniques.

8Control approaches for reducing YOM emissions from automobile and light-duty truck assembly coatings and miscellaneous metal and plastic parts coatings include work practices, product substitution Or refonnulation (namely, the use oflow-YOM or noYOM coatings orcleaning materials), utilization ofhigherefficiency coating application equipment, and capture and control systems. Control devices available to automobile and light-duty truck assembly coatings include oxidizers and hybrid systems. Those available to miscellaneous metal and plastic parts coatings include oxidizers, absorbers, and adsmbens. Similarly, YOM emissions from miscellaneous industrial adhesives can be controlledby product reformulation or substitution via low-YOM adhesives, work practice procedures, utilization ofmore efficient application equipment, such as electrostatic orhighvolume low pressure spray equipment, and capture systems and control devices, including oxidizers, adsorbers, and absorbers. Finally, YOM control techniques for fiberglass boatmanufacturing operations include use ofone or more ofthe following: low monomerYOM resins and gel coats, vapor suppressedresins and gel coats, non-atomizing resin application methods, and closed moldingprocesses, such as vacuumbagging. In the 

### Technical SupporlDocument, the Illinois EPA explains in more detail that the above control approaches are both technically feasible and economically reasonable. 

### See also, eTGs. 

### VI. COMMUNICATION WITH INTERESTED PARTIES The Illinois EPA engaged in outreach on this proposal. OnNovember 5, the Illinois EPA posted a draft ofthe proposed rule and copies ofthe pertinent CTGs on its


### 9website for public comment. The TIlinois EPA also contacted potentially affected sources via email, soliciting feedback on the proposed rule. The lIlinois EPA received several comments regarding theproposed rule. GenerallY"the comments can be categorized into the following areas: revisions to proposed definitions, requests that certain tenus be defined., requests for clarification of specific provisions in the proposal, appropriate VOM content limitations, appropriate applicability language and exclusions, and the location offuture hearings regarding the proposed rulemaking. This proposal incorporates many ofthe concerns and suggestions setforth in those comments, and discussions continuebetween the Illinois EPA and interested parties regarding certain otherissues raised in comments. These regulations arebeing proposed afterthe interested parties have had an opportunity to review the proposal and discuss any issues with the lilinois EPA. 

### VII. SYNOPSIS OF TESTIMONY The Illinois EPAplans to callRory Davis, Environmental Protection Engineer, Air Quality Planning Section, Bureau ofAir, lIlinois EPA, as awitness athearing. 

### Mr. Davis will testify and answer questions regarding theproposed amendments. The Illinois EPA may also call Rob Kaleel, Manager ofthe 

### Air QualityPlanning Section, Bureau of Air, D1inois EPA, to testify and answer questions regarding the proposed amendments as well. Written testimony will be submittedpriorto hearing in accordance with the Board's procedural rules and with Board orders. 

### VIII. THE ILLINOIS EPA'S PROPOSAL Generally, Illinois EPA's regulatoryproposal aims to implement the recommendations contained in the eTGs to the extentthat suchrecommendations are


### 10

### consistent with existingregulations. The following is a Section-by-Section summary of the Dlinois EPA's proposal. 35 Ill. 

### Adm. Code 211 SubpartA: General Provisions Section 211.101 Incorporations by

### Reference The TIlinois EPA proposes addingincorporations by reference for five documents referencedin theproposed amendments to SubpartB ofPart 211. Section 211.102 Abbreviations and Conversion Factors The IllinoisEPA proposes adding abbreviations for five terms referenced in the proposed amendments to Subpart B ofPart 211. Subpart '8: Definitions The Illinois EPA proposes amending currentdefinitions in, and addingnew definitions to, Part 211. Section 211.200 Acrylonitrile-Butadiene-Styrene (ABS) Welding The TIlinois EPAproposes adding a definition for acrylonitrile-butadiene-styrene (ABS) welding. This definition is necessary forproposed Subpart

### JJ ofParts 218 and 219. Section 211.233 Adbesion Primer The IllinoisEPA proposes adding a definition for adhesion primer. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.235 Adhesive Primer The Illinois EPA proposes adding a definition for adhesive primer. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219.

11Section 211.260 Aerosol Adhesive and Adhesive Primer The lllinois EPAproposes adding a definition for aerosol adhesive and adhesive primer. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 2J9. Section 211.492 Antifoulant Coating The Illinois EPA proposes adding a definition for antifoulantcoating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.540 Architectural Structure The Illinois EPA proposes adding a definition for architectural structure. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.715 Bedliner The Illinois EPA proposes adding a definition forbedliner. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.735 Black Coating The Illinois EPAproposes adding a definition for black coating
..This definition is necessary for SubpartF ofParts 218 and 219. Section 211.829 Business Machine Plastic Parts The Illinois EPAproposes amending the defmition ofbusiness machineplastic parts to implement the definition recommended in the CTG. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.825 Camouflage Coating The illinois EPA proposes adding a definition for camouflage coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.954
.Cavity Wax

12The D1inois EPA proposes adding a definition for cavity wax. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.965 Ceramic Tile Installation Adhesive The Illinois EPA proposes adding a definition for ceramic tile installation adhesive. This definition is necessary forproposed Subpart

### JJ ofParts 218 and 219. Section 211.1128 Closed Molding The Illinois EPA proposes adding a definition for closed molding. 'This definition is necessary for proposed SubpartII ofParts 218 and 219. Section 211.1455 ContactAdhesive The D1inois EPA proposes adding a definition for contact adhesive. This defmition is necessaryfor proposed Subpart

### JJ ofParts 218 and 219. Section 211.1 560 Cove Base The Dlinois EPA proposes adding a definition for cove base. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.1565 Cove Base Installation Adhesive The Illinois EPAproposes adding a definition for covebase installation adhesive. This defmition is necessary forproposed Subpart

### JJ ofParts 218 and 219. Section 211.1655 Cyanoacrylate Adhesive The Dlinois EPAproposes adding a definition for cyanoacrylate adhesive. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.1700 Deadener The Illinois EPA proposes adding a definition for deadener. This definition is necessary for SubpartF ofParts 218 and 219.

13

### Section 211.1876 Electric Dissipating Coating The illinois EPA proposes adding a definition for electric dissipating coating. This definition is necessary for Subpart FofParts 218 and 219. Section 211.1877 Electric-InsulatingVarnish The lllinois EPA proposes adding a defmition for electric-insulating varnish. This**defini~on** 

### is necessary for SubpartF ofParts 218 and 219 Section 211.1878 ElectrodeDoSition Primer The TIlinois EPA proposes adding adefinition for electrodepositionprimer. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2040 Etching Filler The Illinois EPA proposes adding adefinition for etching filler. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2055 Ethylene Propvlenediene Monomer (EPDM) RoofMembrane The lllinois EPAproposes adding adefinition for ethylenepropyJenediene
monomer (EPDM) roofmembrane. This definition is necessary forproposed Subpart 11 ofParts 218 and 219. Section 211.2200 Extreme High-Gloss Coating The Illinois EPAproposes adding adefinition for extreme high-gloss coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2210 Extreme Performance Coating The Illinois EPA proposes amending the definition for extreme performance coating to implement the definition recommended in the CTG. This definition is necessary for SubpartF ofParts 218 and 219.


### 14

### Section 211.2310 Final Repair Coat The Illinois EPA proposes amending the definition for final repaircoat to implement tbe definition recommended in the CTG. This definition is necessary for Subpart FofParts 218 and 219. Section 211.2320 Finish Primer/Surfacer The Jllinois EPA proposes adding a definition for finisb primer/surfacer. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.2367 Flexible Vinyl The Illinois EPA proposes adding a definition for flexible vinyL This definition is necessary forproposed Subpart

### JJ ofParts 218 and 219. Section 211.2415 Fog Coat The Illinois EPA proposes adding a definition for fog coat. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2525 Gasket/GasketSealing Material The Illinois EPA proposes adding a definition for gasket/gasket sealing material. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2625 Glass Bonding Primer The Illinois EPAproposes adding a definition for glass bonding primer. This definitionis necessary for SubpartF ofParts 218 and 219. Section 211.2825**Heat-Resi~tant** 

### Coating The Illinois EPAproposes adding a definition for heat-resistant coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2955 High Bake Coating

15The llIinois EPA proposes adding a definition forhigh bake coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.2956 High Build Primer/Surfacer The Dlinois EPA proposes adding a definition for high build primer/surfacer. This definition is necessary for Subpart

### F ofParts 218 and 219. Section 211,2958 High Gloss Coating The Illinois EPA proposes adding a definition for high gloss coating. This definition is necessary for Subpart 

### FofParts 218 and 219. Section 211.2960 High-Performance Architectural Coating The Dlinois EPA proposes adding a definition for high-performance architectural coating. This definition is necessary for Subpart

### F ofParts 218 and 219. Section 211.2980 High Temperature Coating The llIinois EPAproposes adding a definition for high temperature coating. This definition is necessary for Subpart

### F ofParts 218 and 219. Section 211.3100 Indoor Floor Covering Installation Adhesive The Illinois EPA proposes adding a definition for indoor floor covering installation adhesive. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.3120 In-Line Repair The Illinois EPA proposes adding a defmition for in-linerepair. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.3240 Laminate

16

### The Illinois EPA proposes adding adefinition foi: laminate. This definition is necessary forproposed Subpart JJ 

### ofParts 218 and 219. Section 211.3505 Lubricating Wax/Compound The Illinois EPAproposes adding a defmition for lubricating wax/compound. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.3640 Marine Coating The Illinois EPAproposes adding adefinition for marine coating. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.3665 Mask Coating The Illinois EPAproposes adding adefinition for mask coating. This definition is necessary for Subpart F ofParts 218 and 219, Section 211.3760 Metallic Coating The Illinois EPA proposes adding adefinition for metallic coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.3775
. Metal to UrethanelRubber Molding or Casting Adhesive The lllinois EPAproposes adding adefinition for metal to urethane/rubber molding orcasting adhesive. This definition is necessary for proposed Subpart JJ 

### of Parts 218 and 219, Section 211.3785 Military Specification Coating The Illinois EPA proposes adding a definition formilitary specification coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.3820 Miscellaneous Industrial Adhesive Application Operation



### 17The lJJinois EPA proposes adding a definition for miscellaneous industrial adhesive application operation. This definition is necessary for proposed Subpart

### JJ of Parts 218 and 219. 

### Section 211.3925 Mold Seal Coating The Illinois EPA proposes adding a definition for mold seal coating. This definition is necessary for SubpartF ofParts 218 and 219. 

### Section 211.3961 Motor Vehicle Adhesive The lllinois EPA proposes adding a definition for motorvehicle adhesive. This definition is necessary for proposed Subpart

### J1 ofParts 218 and 219. 

### Section 211.3967 Motor VehicleWeatherstrip Adhesive The Illinois EPA proposes adding a definition for motor vehicle weatherstrip adhesive. This definition is necessary forproposed Subpart 

### JJ ofParts 218 and 219. 

### Section 211.3968 Multi-Colored Coating The Illinois EPA proposes adding a definition for multi-colored coating. This definition is necessary for SubpartF ofParts 218 and 219 

### Section 211.3969 Multi-Component Coating The lllinois EPA proposes adding a definition for multi-component coating. This definition is necessary for SubpartF ofParts 218 and 219. 

### Section 211.3975 Multipurpose Construction Adbesive The D1inois EPA proposes adding a definition for multipurpose construction adhesive. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. 

### Section 211.4052 Non-Convertible Coating

18The I1Iinois EPA proposes adding a definition for non-convertible coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.4080 One-Component Coating The Illinois EPA proposes adding a definition for one-componentcoating. This definitionis necessary for SUbpartF ofParts 218 and 219. Section 211.4220 Optical Coating The Illinois EPAproposes adding a definition for optical coating. This definition is necessary for SUbpartF ofParts 218 and 219. Section 211 .4280 Outdoor Floor Covering Installation Adhesive The Illinois EPAproposes adding a definition for outdoor f100I coveTing installation adhesive. This definition is necessary forproposed Subpart 11 ofParts 218 I and 219. Section 211.4455 Pan Backing Coating The Illinois EPA proposes adding a definition forpan backing coating. This defmition is necessary for SubpartF ofParts 218 and 219. Section 211.4540 PerimeterBonded SheetFlooring The Illinois EPA proposes adding a definition for perimeterbonded sheet flooring. This definition is necessary forproposed SubpartJ1 ofParts 218 and 219. Section 211.4735 Plastic The Illinois EPA proposes adding a definition for plastic. This definition is necessary forproposed Subpart JJ ofParts 218 and 219. Section 211.4760 Plastic Solvent Welding Adhesive

19The Illinois EPAproposes adding adefinition for plastic solvent welding adhesive. This definition is necessary forproposed Subpart 

### JJ ofParts 218 and 219. Section 211.4765 Plastic Solvent Welding Adhesive Primer The Illinois EPA proposes adding a definition for plastic solvent welding adhesiveprimer This definition is necessary for proposed Subpart 

### JJ ofParts 218 and 219. Section 211.4768 Pleasure Craft The Illinois EPA proposes adding a definition forpleasure craft. This definition is necessary for Subpart F ofParts 218 and 219. Section 2J 1.4769 Pleasure Craft Surface Coating The Illinois EPA proposes adding a definition for pleasure craft surface coating. This definition is necessary for Subpart F ofParts 218 and 219. Section 2J1.4895 Polyvinyl Chloride Plastic (PVC Plastic) The Illinois EPA proposes adding a definition for polyvinyl chlorideplastic (pVC plastic). This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.4900 Porous Material The Illinois EPAproposes adding a definition forporous material. This definition is necessary forproposed Subpart

### JJ ofParts 218 and 219. Section 211.5012 Prefabricated Architectural Coating The llIinois EPA proposes adding adefinition for prefabricated architectural coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.5061 Pretreatment Coating

20

### The lllinois EPA proposes adding a definitionfor pretreatment coating. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.5061 Pretreatment Wash Primer The Illinois EPA proposes amending the definition forpretreatment wash 

### primer to implement the definition recommended in the eTG. The minois EPA also proposes changing the Section number ofthis definition to Section 211.5062 to make room for the proposed definition forpretreatment coating. This definition is necessary for Subpart

### F ofParts 218 and219. Section 211.5090 Primer Surfacer Coat The Illinois EPA proposes amending the definition forprimer surfacer coal 10 

### implement the defulition recommended in the CTG. nus definition is necessary for Subpart

### F ofParts 218 and 219. Section 211.5400 Red Coating The Illinois EPA proposes adding a definition forred coating. This defmition is necessary for Subpart 

### F ofParts 218 apd 219. Section 211.5520 Reinforced Plastic Composite The Illinois EPA proposes adding a definition forreinforced plastic composite. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 2J 1.5550 Repair Coat The lllinois EPA proposes amending the defulition forrepair coat to implement the definition recommended in the CTG. This definition is necessary for Subpart 

### Fof Parts 218 and 219. Section 211.5800 Rubber

21The n1inois EPA proposes adding a definition forrubber. This definition is necessary for proposed Subpart 

### JJ ofParts 218 and 219. Section 211.5890 Sealer The Illinois EPA proposes amending the defmition for sealer to implement the definition recommended in the 

### eTG. This definition is necessary for Subpart 

### F ofParts 218 and 219. Section 211.5985 Sheet Rubber Lining Installation The Illinois EPA proposes adding a definition for sheet rubberlining installation. This definition is necessary forproposed Snbpart

### JJ ofParts 218 and 219. Section 211.5987 Shock-Free Coating The n1inois EPA proposes adding a definition for shock-free coating. This definition is necessary for SubpartF ofParts·ll8 and 219. Section 211.6012 Silicone-Release Coating The Illinois EPA proposes adding a definition for silicone-release coating. This defInition is necessary for SUbpart

### F ofParts 218 ana 219. Section 211.6015 Single-Ply RoofMembrane TheIllinois EPAproposes adding a definition for single-ply roofmembrane. This definition is necessary for proposed SUbpart

### JJ ofParts 218 and 219. Section 211.6017 Single-Ply RoofMembrane Adhesive Primer The Illinois EPA proposes adding a definition for single-ply roofmembrane adhesive primer. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.6020 Single-PIV RoofMembrane Installation and Repair Adhesive


### 22

### The Illinois EPAproposes adding a definition for single-ply roofmembrane installation and repair adhesive. This definition is necessary for proposed Subpart 

### JJ of Parts 218 and 219. Section 211.6063 Solar-Absorbent Coating The Illinois EPA proposes adding adefinition for solar-absorbent coating. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.6065 Solids Turnover Ratio CRT} The Illinois EPA proposes adding a definition for solids turnoverratio (RT). This definition is necessary for SubpartF ofParts 218 and 219. Section 211.6400 Stencil Coat The lllinois EPAproposes amending the definition for stencil coat to implement the defmition recommended. in the CTG. This definition is necessary for Subpart F of Parts 218 and 219. Section 211.6425 Structural GlaZing The Illinois EPAproposes adding a definition for structural glazing. This definition is necessaryforproposed Subpart JJ 

### ofParts 218 and 219. Section 211.6460 Subfloor The Jllinois EPA proposes adding adefmition for subfloor. This definition is necessaryforproposed SubpartJJ 

### ofParts 218 and 219. Section 211.6585 Thin Metal Laminating Adhesive The Illinois EPA proposes adding a defmition for !hili 

### metal laminating adhesive. This defmition is necessary forproposed Subpart 

### JJ ofParts 218 and 219. Section 211.6640 Tire Repair


### 23The Illinois EPA proposes adding a definition for tire repair. This definition is necessary for proposed Subpart

### JJ ofParts 218 and 219. Section 211.6670 Topcoat The lIlinois EPA proposes amending the definition for topcoatto implement the definition recommended in the CTG. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.6690 Topcoat Operation The Illinois EPA proposes amending the definition fortopcoat operation to implementpart ofthe definition recommended in the CTG. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.6720 Touch-Up Coating The Illinois EPAproposes amending the definition for touch-up coating to implement the definition recommended in the eTG. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.6740 Translucent Coating The Illinois EPAproposes adding a definition for translucent coating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.6780 TrunkInterior Coating The illinois EPA proposes adding a definition for trunkinteriorcoating. This definition is necessary for SubpartF ofParts 218 and 219. Section 211.6825 Underbodv Coating The Illinois EPA proposes adding a definition for underbody coating. This definition is necessary for SubpartF ofParts 218 and 219.


### 24Section 211.6885 Vacuum Metalizing Coating The Illinois EPAproposes adding a definition for vacuum metalizing coating. This definition is necessary for Subpart F ofParts 218 and 219. Section 211.7220 WaterproofResorcinol Glue The Illinois EPAproposes adding a definition for waterproofresorcinol glue. This definition is necessary for proposed Subpart 

### JJ ofParts 218 and 219. Section 211.7240 Weatherstrip Adhesive The Dlinois EPA proposes adding a definition for weatherstrip adhesive.' This definition is necessary for Subpart 

### F ofParts 218 and 219. 35 III. Adm. Code 218/219 SubpartA: General Provisions Section 218/219.105 TestMethods and Procedures The Illinois EPA proposes amending subsection (b) by updating the testing protocol for automobile and light-duty truckprimer-surfacer and topcoat operations. Section 218/219.106 Compliance Dates The Ulinois EPA proposes adding subsection (e) to Section 218.106 and subsection (c) to Section 219.106, which establish May 1,2011, as the compliance date for sources subjectto the rulemakingproposal. The Illinois EPA also proposes amending subsection (a) ofSection 219.106 to reference proposed subsection (c). Section.218/219.1l2 Incorporations by Reference The Illinois EPA proposes adding subsections (cc), (dd), (ee), and (ft) to Section 218.112, and subsections (aa), (bb), (cc), and (dd) to Section 219.112, which incorporate

25byreference several documents mentioned in the Illinois EPA's proposed amendments to Parts 218 and 219. SubpartF: Coating Operations Section 2181219.204 Emission Limitations The lllinois EPA proposes amending the introductory paragraph to reference revised and new subsections ofSection 2181219.204. The Illinois EPA proposes amending subsection (a) to restrict the YOM content of automobile and light-duty truck coatings to the limitations set forth in the 

### eTG, and to separate the limits that are applicable to such coatings priorto the new compliance date from those applicable on and after the new compliance date. The illinois EPAalso proposes amending subsection (a) to include a definition for electrodeposition; to specify how compliance with the amended YOM content limitations forprimer-surfacer, topcoat, and combined primer-surfacer and topcoat operations shall be demonstrated; to specify what testing is required for such operations; and to provide an equation for determining
occurrence weighted average for fmal repair coat operations. Finally, the illinois EPA's proposed amendments provide that the amended YOM content limitations shan not apply to materials supplied in containers with a net volume of 16 ounces or less, or a net weight ofone pound or less. Thelllinois EPAproposes amending subsection 

### (j) to specify that the limitations in (j) are only applicable to miscellaneous metal parts andproducts coatings prior to May 1,2011, and that on and after such date, the limitations in subsection (q) shall apply.



### 26The Illinois EPA proposes amending subsection (n) to specifythat the limitations in (n) are only applicable to plastic parts coatings (automotive/transportation) prior to May I, 2011, and that on and after such date, the limitations in subsection (q) shall apply. The Illinois EPA proposes amending subse<:tion (0) to spe<:ify that the limitations 

### in (0) are only applicable to plastic parts coatings (business machines) prior to May I, 2011, and that on and after such date, the limitations in subsection (q) shall apply. The Illinois EPAproposes adding subsection (q), which sets forth YOM content limitations, definitions, and exclusions for metal parts and products coatings; plastic parts and products-miscellaneous coatings; plasticparts and productsautomotive/transportation coatings; plastic parts and products-business machine coatings; pleasure craft surface coatings; and motor vehicle materials coatings. Section 218/219.205 Daily-Weighted Average Limitations The Illinois EPAproposes amending the introductoryparagraph to reference proposed subsection 

### U) in Section 218.205, and proposed subsection (i) in Section 219.205. The Illinois EPA proposes amending subsection (a) to provide that such subsection applies to Section 218J219.204(a)(I)(A), (a)(I)(D), (a)(2)(A), (a)(2)(E), and (a)(2)(F), among other listed subsections. The Illinois EPA proposes amending subsection (b) to specifythat the limitations in such subsection only applyto miscellaneous parts and products coatings priorto May 1,2011. The nIinois EPA proposes amending subsection (g) to specifytbatthe limitations in such subsection only apply to plastic parts coatings prior to May I, 2011.


### 27The Illinois EPAproposes adding subsection 

### CD to Section 218.205 and subsection (i) to Section 219.205, which set forth therequirements for miscellaneous metal parts and products coating lines, plasticparts and products coating lines, pleasure craft surface coating lines, and motor vehicle materials coating lines utilizing the daily weighted averaging alternative on and afterMay 1,2011. Section 218/219.207 Alternative Emission Limitations The Illinois EPAproposes amending subsection (a) to referenceproposed subsection (1) in Section 218.207, and proposed subsection (k) in Section 219.207, and to exclude coating lines subject to Section 218/219.204(q)(6) from the alternative emission limitations option. The Illinois EPA proposes amending subsection (b) to provide for sources complying with aproposed emission limitation in Section 218/219.204 that is alreadyin terms ofweight ofVOM pervolume ofsolids. The Dlinois EPA proposes amending subsection (c) to include references to certain amended YOM contentlimitations. The Illinois EPA proposes adding subsection 

### (1) to Section 218.207 and subsection (1<) to Section 219.207, which set forth the requirements for miscellaneous metal parts and products coating lines, plastic parts andproducts coatings lines, and pleasure craft surface coaling lines utilizing the alternative emissions limitation on and afterMay 1,2011. Section 218/219.208 Exemptions 

### from Emissinn Limitations The Illinois EPA proposes amending subsection (a) to provide that on and after May 1, 2011, for applicability purposes YOM emissions from heavy off-highwayvehicle


### 28products coatings lines shall be combined with YOM emissions from miscellaneous metal parts and products coating lines and plastic parts and products coating lines. The Illinois 

### EPA proposes amending subsection (c) and adding subsection (d) to provide that the exclusions contained in such subsections shall only apply to miscellaneous metal parts and products, plastic parts coatings for automotivel transportation, and plastic parts coatings for business machines Wltil May I, 201 J. The Illinois 

### EPA proposes relettering the existing subsection (d) to subsection (e) and correcting internal cross-references. Section 218/219.210 Compliance Schedule The lJIinois 

### EPAproposes amending the introductoryparagraph to reference the proposed subsection (g). The Illinois 

### EPA proposes adding subsection (g), which provides that, on and after a date consistent with Section 218/219.106, sources subjectto the proposed limitations in Section 218/219.204(a) or (q), or SUbject to the limitations 

### in Section 2181219.219, shall comply with such limitations, 

### as well as 

### with all other applicable provisions in Subpart

### F. Section 218/219.211 Recordkeeping and Reporting The TIlinois 

### EPAproposes amending subsection (c) to includereferences to the amended YOM contentlimitations for automobile and light-duty truck coatings, and to provide that, for certain automobile and.light-dutytruck coating lines, YOM content information shall be maintained and/or reported in terrns ofweight ofVOM per volume ofsolids or coatings, as applicable, as applied each day on each coating line. The Illinois 

### EPA also proposes amending subsection (c) to provide that coating lines subject to

29Section 218/219.204(a)(2)(A) shall maintain and/orreport the solids turnoverratio of each electrodeposition primeroperation. Subjectprinting lines shall also maintain certified product data sheets for each coating applied on each line. The Illinois EPA proposes amending subsection (d) to provide that, for coating lines that are subjectto Section 218/2l9.204(a)(2)(A) or (q) and that are utilizing the daily weighted averaging alternative, YOM content information shall bemaintained and/orreported in terms ofweight ofVOM per volume ofsolids orcoatings, as applicable, as applied each day on each coating line. The Illinois EPA proposes amending subsection (e) to provide that coating lines complying pursuant to Section 218.207(1) or 219.207(1<) shall comply with the recordkeeping and reporting requirements set forth in subsection (e). The Illinois EPA also proposes amendinginternal cross references. The Illinois EPA proposes adding subsection (g), which establishes recordkeeping and reporting requirements for coaling lines subject to the work practices setforth in Section 2181219.219. Section 218/219.212 Cross-Line Averaging to Establish Compliance for Coating Lines The illinois EPA proposes amending this Section to provide thatthe cross-line averaging alternative is not available to coating lines subjectto the revised YOM content limitalions. Section 218/219.219 Work Practice Standards for Automobile and Light-Dutv TruckAssembly Coatings and Miscellaneous Metal and Plastic Parts Coatin£s The Illinois EPA proposes adding Section 218/219.219, which sets forth work practice requirements for YOM-containing coatings, thinner, coating-related waste 30materials, cleaningmaterials. and cleaning-related activities associated with automobile and light-duty truck assembly coating lines or miscellaneous metal orplastic parts coatings lines. This Section also establishes application method requirements for certain coating lines described in Section 218/219.204(q). SubpartII: Fiberglass Boat Manufacturing Materials The Illinois EPA proposes adding Subpart II to Parts 218 and 219 regarding fiberglass boat manufacturing materials. Section 218/219.890 Applicability Subsection (a) provides that, on and afterMay I, 2011, therequirements of SubpartII shall apply to the owners and operators ofsourcesthat manufacturehulls or decks ofboats from 'fiberglass, orthatbuild molds to make hulls ordecks ofboats from fiberglass, and that emit 15 lbs/day ormore ofVOM from specified operations. Ifa
source meets such criteria, the limitations in Subpart IT apply to themanufactureofall fiberglass boatparts at the source. Subsection (b) establishes exemptions for certain coatings and operations. Subsection (c) provides that ifa source is or becomes subjectto this Subpart, the
source is always subject to the Subpart. Subsection (d) provides that sources exemptpursuantto this Section are still subject to recordkeeping and reporting requirements. Section 218/219.891 Emission Limitations and Control**Reguire~ents** Subsection (a) provides that resins and gel coats at subject sources shall comply with the limitations setforth in subsection (b)(I) or (b)(2), (c), or (d) ofthis Section, as well as with subsections (e), (g), and (li) ofthis Section. This subsection also provides



### 31that ifa source complies pursuantto subsection (b) or (c), and the non-monomer YOM content ofa resin or gel coat exceeds five percent, by weight, the excess non-monomer YOM shall be added to the monomer YOM content ofsuch resin or gel coat in accordance with a specified equation. Subsection (b) establishes YOM content limitations for subjectresins and gel coats, and a 12-month roUing weighted averaging alternative to such limitations.' Subsection (c) establishes an emission averaging alternativeinwhich resin and gel coat operations utilizing the alternative comply with a source-specific monomer YOM mass emission limit on a 12-month rolling average basis. Subsection (c) sets forth several equations that sources shall utilize ifcomplying bymeans ofthis alternative_ Sources shall utilize Equation 2 to determine the source-specific monomer YOM mass emission Jimit; Equation 3 to calculatemonomer YOM emissions from the resin and gel coat operations included in the emissions average; and Equation 

### 4to calculatethe weighted-average monomer YOM emission rate for the previous 12 months for each resin and gel coat operation. Subsection (c) also sets forth monomer YOM emission rate formulas for use in Equation 4 and subsection (e)(3) ofthis Section. Subsection (d) establishes an emissions control alternative for subjectresin and gel coat operations. Subsection (d) provides that an afterburner, carbon adsorber, or other approved control device shall be installed and operated such that the YOM emissions at the outlet ofthe control device meet an emission limitation determinedusing a slightly altered version ofEquation 2, as set forth in subsection (c)(1). Subsection (e) sets forth Equation 5 and provides that, for all filled production and tooling resins, the owner or operator ofa subject source shall use such equation to adjust

32the monomerYOM emission rates detennined pursuant to subsection (b). Subsection (e) also sets forth limitations to the emission rate determined using Equation 5 for sources complying pun;uant to subsection (b). Subsection 

### (f) provides tbat certain types ofmaterials are exempt from tbe limitations setforth in subsections (a) through (e). Such materials shall instead comply with therequirements set forth in subsection 

### (t). Subsection (g) provides that no owner Or operator ofa source subjectto this Subpart shall use YOM-containing cleaning solutionsto remove cured resin and gel coats from fiberglass boat manufacturing application equipment. Additionally, no owner or operator shall useYOM-containing cleaning solutions for routine cleaning ofapplication equipment unless specified YOM content or composite vaporpressurerequirements are met. Subsection (h) provides thatno owner or operator ofa source subject to this Subpart shall use resin or gel coatmixing containers with a capacityequal to or greater than 55 gallons unless such containers have covers with no visible gaps in place at all times, exceptwhen material is being manually added to orremoved from a containeror when mixing orpumping equipment is being placedin orremoved from a container. Section 218/219.892 Testing and Monitoring Requirements Subsection (a) provides that testingto demonstrate compliance with Section 218/219.891 shall beconducted within 90 days after a requestbytheIllinois EPA, or as otherwise specified in Subpart II. The Illinois EPA shall benotified in writing 30 days in advance ofsuch testing.

33

### 34solvents, testing may instead be conducted in accordance with the manufacturer's specifications ifcertain conditions are met. Subsection (e) sets fonh monitoring requirements for owners or operators relying
on the YOM content ofcleaning solutions to comply with Section 2181219.891(g)(l). Subsection (f) provides that testing to demonstrate compliance with the YOM composite pania] vapor pressure limitation for cleaning solvents shall be conducted in accordance with themethods and procedures set forth in Section 218/219.11 

### O. Section 218/219.894 Recordkeepinl! and Reporting Requirements Subsection (a) provides that the owners and operators ofsources exemptfrom the limitations ofSubpart IT because ofthe criteria in Section 218/219.890(a) shall submit a certification to the illinois EPA that includes a declaration that the source is exempt and calculations that demonstrate thatthe source is exempt. The owneror operator shall also notifythe Dlinois EPA 

### jfthe combined emissions ofVOM from subject fiberglass boat manufacturing operations at the source ever equal or exceed 

### J5 lbs/day, within 30 days after the event occurs. Subsection (b) sets forth recordkeeping and reporting requirements for all sources subjectto the requirements ofSubpan IL Such sources shall submit a certification to the Illinois EPA thatincludes specified information, notify the Illinois EPA at least 30 calendar days before changing the method ofcompliancebetween Sections 218/219.891(b), (c), and (d), notify the Illinois EPA ofanyviolation ofthe requirements ofSubpart II within 30 days following the violation, retain all records required by this Section for at least three years, and make such records available to the TIlinois EPA upon request.


### 35Subsection (c) provides that the owner or operator ofa subject fiberglass boat manufacturing operation that is complying by means ofSection 218/219.891 (b) shall submit a certification to the Illinois EPA that includes thename, identification number, and YOM content ofeach subject resin and gel coat as applied each day. The owner or operator shall collect and record such information, as wel1 as the daily weighted average YOM content ofall subject resins and gel coats complying pursuant to Section 218/219.891 (b)(2). Subsection (d) provides that the owner or operator ofa subjectfiberglass boat manufacturing operation thatis complying by means ofSection 218/219.891(c) shall collect and record each month the amount and YOM content ofeach subject resin and gel coat used in each subjectmanufacturing operation. At the end ofthe 12-month averaging period, and at the end 0feach subsequentmonth, tbe owner or operator shall also collect and record the monomer YOM mass emission limit for the subjectmanufacturing operations for the applicable 12-month averaging period, and the total actual emissions of YOM from such operations. Subsection (e) provides that the owner or operator ofa subject fiberglass boat manufacturing operation that is complyingby means ofSection 218/219.89I(d) shall submit a certification to the Illinois EPA that includes infonnation regarding the type of conlrol device used to demonstrate compliance, the results ofall tests and calculations necessary to demonstrate compliance, and a declaration thatthe owner or operatoris in compliance with monitoring requirements. The owner or operator shall also submit

### to the Illinois EPA a copy ofall test results within 90 days after conducting testing, and a certificationproviding specified details regarding such testing. Finally, the owner or


### 36operator sball collect and record daily control device monitoring data, a log ofoperating time for the control device and monitoring equipment, a maintenance log for the control device and monitoring equipment, and information substantiating that the fiberglass boat manufacturing operation is operating in compliance with theparameters detennined pursuantto Section 218/219.892. Subsection 

### (f) provides that the owner or operator ofa source subject to Section 218/219,891 (f) shall collect and record specified information regarding materials exempt pursuant to such Section. Subsection (g) provides that the owner or operator ofa subject source shall collect and record specified information for each cleaning solution used in each fiberglass boat manufacturing operation. Subpart JJ: Miscellaneous Industrial Adhesives Section 218/219.900 Applicability Subsection (a) provides that, on and afterMay 1,2011, therequirements in Subpart

### JJ apply to miscellaneous industrial adhesive application operations at sources where the total actual YOM emissions from sucb operations, including related cleaning activities, equal or exceed 15 Ibs/day, in the absence ofairpollution control equipment. Subsection (b) establishes exemptions for certain coatings, adhesives, and operations. Subsection (c) provides that ifa source is OTbecomes subject to this Subpart, the
source is always subject to the Subpart. Subsection (d) provides that sources exemptpursuant to this Section are still subject to recordkeeping and reporting requirements.

37Section 218/219.901 Emission Limitations and Control Requirements Subsection (a) provides thatthe owner or operator ofasource subject to the requirements ofSubpart 

### JJ shall complywith subsection (b), (c), or (d) ofthis Section, as well as with the limitations in subsections (e) and (f) ofthis Section. Sources subjectto Section 218.900(b)(2), however, shall only comply with the limitations in subsection (f). Subsection (b) establishes YOM content limitations for subject adhesives. Subsection (c) establishes a daily-weighted averaging alternative to the YOM content limitations in subsection (b). Subsection (d) establishes an emissions control alternative for subject adhesives. Subsection (d)provides that an afterburner, carbon adsorber, or other approved control device shaH be utilized thatprovides at least 85% reduction in the overall emissions of YOM from the adhesive application operation. Alternatively, the owneror operatormay comply with the applicable limitation set forth in Section 218.901(b) byutilizing a combination oflow-YOM adhesives and an afterburner, carbon adsorber, or other approved control device. Subsection (e) provides that the owner or operatorofa subject source shall comply with specified application method requirements. Subsection (f) provides that the oWneroroperatorofasubject source shall comply with specified work practices for each subject adhesive application operation. Section 2181219.902 Testing Requirements Subsection (a) provides that testing to demonstrate compliance with Subpart

### JJ shall be conducted within 90 days after arequest by the 11linois EPA, or as otherwise



### 38specified. The Illinois EPA shall be notifiedin writing 30 days in advance ofsuch testing. Subsection 

### (b) provides that testing to demonstrate compliance with theYOM content limitations setforth in Section 218/2I 9.901 

### (b) shaH be conducted in accordance with specified test methods, or, under certain circumstances, in accordance with the manufacturer's specifications. Subsection (c) provides that the owneror operator of

### a source complying with Section 218/219.901(d) by utilizing an afterburner or carbon adsorber shall perform testingpursuant to 'specified test methods andprocedures. Subsection (d) provides that the owneroroperator'ofasource complying with Section 218/2·19.901(d) by utilizing an emissions control system other than afterburner or carbon adsorber shall conducttesting as set forth in the owner oroperator'splan approved by the Dlinois EPA and USEPA. Section 218/219.903 Monitoring Requirements Subsection (a) sets forth monitoring requirements for owners or operators utilizing an afterburner orcarbon adsorberto demonstrate compliance with Section 218/219.901 (d). Subsection (b) sets forth monitoring requirements for owners or operators utilizing 

### an emissions control system other than an afterburner or carbon adsorberto demonstrate compliance with Section 218/2 19.901 (d). Section 218/219.904 Recordkeeping and Reporting Requirements Subsection (a) provides thatthe owners and operators ofsources exempt from Ihe limitations ofSubpart JJ because ofthe criteria in Section 2I 81219.900(a) shall submit a
39certification to the Illinois EPA that includes a declaration that the source is exempt and calculations that demonstrate thatthe source is exempt. The owneror operator shall also notify the Illinois EPA ifthecombined emissions ofVOM from subject miscellaneous industrial adhesive application operations at the source ever equal or exceed 15 lbs/day, within 30 days afterthe event OCCUTS. Subsection (b) sets forth recordkeeping and reporting requirements for all sources subject to the requirements ofSubpartJJ. Such sources shall submit a certification to the illinois EPA that includes specified information, notify theIllinois EPA at least30 calendar days before changing the method ofcompliancebetween Sections 218/219.901(b), (c), and (d), notify the illinois EPA ofany violation ofthe requirements ofSubpart JJ within 30 days following theviolation, retain all records required by this Section for at leastthree years, andmake such records availableto the Illinois EPA upon request.Subsection (c) provides that the owner or operator ofa subject adhesive application operation that is complyingbymeans ofSection 218/219.901(b) shall submit
a certifieation to the Illinois EPA that includes thename, identification number, and YOM content ofeach SUbject adhesive as applied each day. The owner or operator shall also collect and record such information. Subsection (d) provides that the owner Or operator ofa subject adhesive application operation thatis complying by means ofSection 218/219.901 (c) shall submit
a certification to the Illinois EPA that includes thename, identification number, and YOM content ofeach subject adhesive as applied each day. The owneror operator shall



### 40also collect and record such infonnation, along with the daily weighted average YOM content ofall subject adhesives as applied. Subsection (e) provides thatthe owner or operator ofa subject adhesive application operation that is complying by means ofSection 218/2l9.90l(d) shall submit
a certification to the Illinois EPA that includes information regarding the type ofcontrol device used to demonstrate compliance, the results ofall tests and calculations necessary to demonstrate compliance, and a declaration that the owner or operator is in compliance with monitoring requirements. The owner or operator shall also submit to the Illinois EPA acopy ofall test results within 90 days after conducting testing, and a certification providing specified details regarding such testing. Finally, the owner or operatorshall collect and record daily control device monitoring data, a Jog ofoperating time for the control device, monitoring equipment, and the associated adhesive application unit, and a maintenance log for the control device and monitoring equipment.

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
By: 

### C)jp e\'" 

# 1!TJii{, DanaVetterhoffer Assistant Counsel Division ofLegal Counsel
DATED: March 3, 2010 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

41

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF: REASONABLY AVAlLABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANlC MATERlAL EM1SSIONS FROM GROUP JV CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219 ) 

### ) ) ) ) ) ) 

### ) 

### RIO- 

# ;;IJ (RuJemaking-Air) 

### ReCEIVED

CLERK'S 

### OFFICE



## MAR 08 2010 STATE OF 

### ILUNOlS POllution Control 

### Board CERTIFICATE OFSERVICE I, the undersigned, an attorney, state that 1have served the attached REGULATORY PROPOSAL entitled "REASONABLY AVAILABLE CONTROLTECHNOLOGY (RACT) FOR VOLATILE ORGANlC MATERIAL EMISSIONS FROM GROUP JV CONSUMER & COJ\.1MERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218, and 219," MOYlON FOR WAJVER OF COpy REQUIREMENTS, and APPEARANCE of the Illinois Environmental Protection Agency upon the person to whom it is directed, by mailing it by first-class mail from Sprillgfield, llIinois, with sufficientpostage affixed, to the following persons: John Therriault, Assistant Clerk TIlinois Pol1ution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Dlinois 60601-32

### J8 Virginia Yang Deputy Legal Counsel Illinois Department ofNatural Resources One Natural Resources Way Springfield, IL 62702

DATED: March 3, 2010 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544 Matthew Dunn, Chief Division ofEnvironmental Enforcement Office ofthe Attorney General 69 W. Washington, Suite 1800 Chicago, IL 60602

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~~1fJb Dana Vetterhoffe;: Assistant Counsel Division ofLegal Counsel

# TECHNICAL SUPPORT DOCUMENT for 

# CONTROL OF VOLATILE ORGANIC MATERIAL EMISSIONS IN NON-ATTAINMENT AREAS from 

# MISCELLANEOUS METAL AND PLASTIC PARTS COATINGS; AUTOMOBILE AND LIGHT-DUTY TRUCK ASSEMBLY COATINGS; MISCELLANEOUS INDUSTRIAL ADHESIVES; AND FIBERGLASS BOAT MANUFACTURING MATERIALS
AQPSTR 10-01



# January 2010

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 1021 NORTH GRAND AVENUE EAST P.O. BOX 19276
. SPRINGFIELD, ILLINOIS 62794-9276Table ofContents List ofAcronyms
. Tables....................
. . Executive Summary , ,.. ', . 2 3 4 1.0 2.0

3.0

4.0

5.0 Introduction
. Miscellaneous Metal and Plastic Parts Coatings
. 2.1 Description ofSources and Emissions
. 2.2 Emissions in Illinois from Miscellaneous Metal and Plastic Parts Coatings : . 2.3 Teclmical Feasibility"ofControls
. 2.3.1 Option I: Use ofLow YOM Coatings
. 2.3.2 Option 2: Use ofLow YOM Coatings and Add-on Controls
. 2.3.3 Option 3: 90% Capture and Control Efficiency
. 2.4 Economic Reasonableness and Cost Effectiveness ofControls
. 2.5 Additional Recommendations: Work Practices
. 2.6 Potentially Affected Sources in Illinois
. 2.7 Existing Regulations
. Automobile and Light-Duty TruckAssembly Coatings
. 3.1 Description ofSources and Emissions , .. 3.2 Emissions in Illinois fromAuto and Light-Duty Truck Coatings
.. 3.3 Technical Feasibility ofControls
. 3.4 Economic Reasonableness and Cost Effectiveness ofControls
.. 3.5 Additional Recommendations: WorkPractices
. 3.6 Potentially Affected Sources in TIlinois
.. 3.7 Existing Regulations
. Miscellaneous Industrial Adhesives
.. 4.1 Description ofSources and Emissions . 4.2 Emissions in Illinois fromMiscellaneous Industrial Adhesives
. 4.3 Technical Feasibility ofControls
.. 4.4 Economic Reasonableness and Cost Effectiveness ofControls
. 4.5 Additional Recommendations: WorkPractices
.. 4.6 Potentially Affected Sources in Ulinois
.. Fiberglass BoatManufacturing Materials
. 5.1 Description ofSources and Emissions
. 5.2 Recommended Control Techniques forFiberglass Boat Manufacturing Materials
.. 5.2.1 Option I: Use ofLow Monomer YOM Manufacturing Materials
. 5.2.2 Option 2: Emissions Averaging Option
.. 5.2.3 Option 3: Add-on Controls
. 5.3 Technical Feasibility ofControls , . 5.4 Economic Reasonableness ofControls
.. 5.5 Additional Recommendations: Work Practices
. 6 8 8 9 9 10 14 17 17 19 20 23 24 24 24 25 27 28 29 29 30 30 31 31 34 34 35 37 37 37 38 39 42 43 43 43 References.... . 45CAA CO CTG EDP Illinois EPA MMA NAA NAICS 

### NESHAP NOx OTC ppm RACT 

### SIP USEPA VOM 

### List ofAcronyms Clean AirAct Carbon Monoxide Control Techniques Guidelines Electrodeposition Primer Illinois Environmental Protection Agency Methyl Methacrylate Non-attainment Area North American Industry Classification System National Emissions Standards for Hazardous AirPollutants Nitrogen Oxides Ozone Transport Commission Parts permillion Reasonably Available Control Technology State Implementation Plan United States Environmental ProtectionAgency Volatile Organic Material

2Table 2.1

Table 2.2
Table 2.3 Table 3.I
Table 3.2

Table 4.1
Table 4.2 Table 5.1
Table 5.2 Tables YOM Limits for Metal and Plastic Parts Coatings in Terms ofMass per Volume ofCoating 12
YOM Limits for Metal and Plastic Parts Coatings in Terms ofMass per Volume ofSolids 15 Potentially Affected Sources in lllinois 20 Recommended YOM Emission Limits for Automobile and Light-Duty Truck Assembly Coatings 26 Recommended YOM Emission Limits for Miscellaneous Materials Used at Automobile and Light-DutyTruckAssembly Coating Facilities (grams ofVOM per liter ofcoating excluding water and exempt compounds as applied)..... 27 YOM Emission Limits for General and Specialty Adhesive Applicatiou Processes 33 Potentially Affected Sources in lllinois 36 Compliant Materials Monomer YOM Content Recommendations for Open Molding Resin and Gel Coat.. 39 Monomer YOM Emission Rate Formulas for Open Molding Operations 42

3Executive Summary
On September 30, 2008, theUnited States Envirorunental Protection Agency ("USEPA") issued final Control Techniques Guidelines ("CTGs") in lieu ofnational rules to regulate five categories ofconsumer and commercial products that have been designated as Group IV Consumer and Commercial Products. The intent ofthese CTGs was to reduce emissions ofvolatile organic material ("VOM") from miscellaneous metal and plastic parts coatings, auto and light-duty truck coatings, miscellaneous industrial adhesives, and fiberglass boatmanufacturing materials.
The purpose ofthis document is to provide technical support for arulemaking to incorporate the recommended control techniques for the Group IV categories into Illinois regulations, limiting emissions ofVOM in ozone non-attairunent areas (''NAAs''). This technical support document

, . addresses: the technical feasibility ofthe proposed control techniques; their economic reasonableness and cost effectiveness; the sources in Illinois thatwill be impacted by the proposed regulation; the reasoning behind adopting these rules in Illinois; and the process by which the control techniques have been developed by the USEPA in orderto meet areasonably available control technology ("RACT") standard,
The Illinois Environmental Protection Agency ("Illinois EP

### A") has detennined that the proposed regulations to implementthe recommendations ofthe USEPA CTGs addressing the Group IV categories are both technically feasible and economically reasonable. The Dlinois EPA has relied primarily upon the analysis conductedby the USEPA in developing the CTGs for these categories. Illinois is required by the Clean Air Act ("CAA") to revise its State Implementation Plan ("SIP") to include RACTcontrol for sources addressed by a CTG. CAA Section 182(b)(2) requires that states submit SIP revisions in response to any CTG issued between November 15, 1990, and the attainment date for any NAA, The Illinois EPA is proposing regulations consistent with the recommendations contained in the CTGs to control VOM emission from Consumer and Commercial Products, Group IV,
Three ofthe Group IV categories, miscellaneous metal coatings, plastic parts coatings, and auto and light-duty truck assembly coatings, are currently addressed by Illinois regulations for the 4Chicago and Metro-East St. Louis NAAs in 35 

### Ill. Adm. Code Parts2l8 and 219, respectively. The RACT recommendations ofthe current CTGs provide more stringent limits for sources as well as more specific subcategories for coatings and applications. 'Parts 218 and 219 have been amended to reflect the CTGs' RACT recommendations.
The other two Group IV categories addressed by CTGs are currently not specifically addressed by Illinois regulations. These categories are miscellaneous industrial adhesives and fiberglass boatmanufacturing materials. The Illinois EPA is proposing two new Subparts, Subparts II and JJ, forParts 218 and 219 that will address these categories:

5

### 1.0 Introduction Pursuant to Section 109 ofthe CAA, as amended in 1990, and to protect the public health, the USEPA revised the National AmbientAir Quality Standard ("NAAQS") for ozone effective July 17, 1997. The USEPA lowered the NAAQS for ozone to 0.08 parts permillion ("ppm") from the previous 0.120 parts permillion. In addition, the time period used for measuring compliance was increased from the previous 1 hourto 8 hours. In Illinois, Chicago and the Metro-East St. Louis area have becn designated as moderate ozone NAAs for the 1997 NAAQS. Included in the Chicago NAA are Cook, DuPage, Kane, Lake, McHenry, and Will counties, as well as the Aux Sable Township and GooseLake Township in Gnmdy County, and Oswego Township in Kendall County. The Metro-East St. Louis NAA is comprised ofJersey, Madison, Monroe, and St. Clair counties. CAA Section 172 requires that SIPs for theseNAAs include requirements for RACT as it applies to emissions sources.
To comply with the requirements forRACT, the Illinois EPA is proposing to reduce YOM emissions from miscellaneous metal and plastic parts coatings, automobile and light-dutytruck assembly coatings, miscellaneous industrial adhesives, and fiberglass boatmanufacturing materials. These five YOM emission sources have been designated as "Consumer and Commercial Products, Group 

### N" categories by the USEPA. Pursuantto CAA Section 183(e)(3)(C), USEPA determined that CTGs "will be substantially as effective as national regulations in reducing emissions ofvolatile organic compounds in ozone national ambient air quality standard nonattainrnent areas5.', Based on that determination, USEPA issued final CTGs in lieu ofnational regulations forthe affected categories on September30, 2008. Illinois EPA has addressed the CTGrecommendations in the proposed rule forthis group ofSOurce

. 1-4 categones . Miscellaneous metal parts coatings, plastic parts coatings, and auto and light-duty truck assembly coatings are currently regulated by the TIlinois EPA in SubpartF of35 

### Ill. Adm. Code Parts 218.204 and 219.204 forthe Chicago and Metro-East St. Louis NAAs respectively. However, the Illinois EPA's proposed amendments are more stringent, and prescribe YOM content limits for more specific product subcategories, than current TIlinois regulations.



### 6Fiberglass boat manufacturing materials are currently regulated by a 200I National Emission Standard for Hazardous 

### AirPollutants ("NESHAY') (40 CFRPart 63 SubpartVVVV). The current Illinois regulation forpolyesterresin product manufacturing in Subpart CC of35 Ill. Adm. Code Part 218, requiring high efficiency spray techniques and YOM content limits in resin and gel coat materials, was determined by the USEPA to be less stringent than the 2001 NESHAP4

. The recommendations in the CTG are based on the emission levels from sources complying with the aforementioned NESHAP.
There are currently no federal or state regulations specifically addressing miscellaneous industrial adhesives>'
Furtherreductions ofVOM emissions from the aforementioned categories will be beneficial to the environment and are consideredto be both economicallyreasonable and technologically feasible. Forthese reasons the Illinois EPA has proposed this rule for controlling YOM emissions from Group IV consumer and commercial products.
In evaluating the potential reductions ofVOM emissions from Group IV consumer and commercial products and their cost effectiveness, the illinois EPA has relied upon the four USEPA CTG documentsl -4. This technical support document is based on areview ofthose CTGs and is in support ofthe amendments proposed to implement RACT control techniques in Illinois. Further regulation ofthese source categories will be integrated into Illinois' state implementation plan ("SIP") for achieving and maintaining attainment oftheNAAQS in Illinois NAAs.

72.0 Miscellaneous Metal and Plastic Parts Coatings 2.1 Description ofSources and Emissions Miscellaneous metal and plastic parts coatings are coatings applied to awide range ofmetal and plastic parts for decorative, protective, and functional purposes. The coatings are applied to components ofproducts that include, but are not limited to: fabricated metal products, molded plastic parts, small and large farm machinery, commercial and industrial machinery and equipment, automotive ortransportation equipment, interiororexterior automotive parts, construction equipment, motor vehicle accessories, bicycles and sporting goods, toys, recreational vehicles, pleasure craft (recreational boats), extruded aluminum structural components, railroad cars, heavier vehicles, lawn and garden equipment, business machines, laboratory and medical equipment, electronic equipment, steel drums, metal pipes, and numerous otherindustrial and household products. Forthe purposes ofthis technical support document, and for consistency with the corresponding CTG, these varied subcategories ofparts will be referred to collectively as "miscellaneous metal and plastic parts coatings:"]
Emissions ofVOM from this source category occur when the solventcarrying the coating material evaporates and leaves the coating material on the surface during application and drying, and to a lesserextent during the mixing and thinning ofthe coating, and during cleaning . I operatIOns
. The coatings affected by the proposed amendments are coatings that are applied bythe manufacturers to the parts they produce, and not for coatings that are applied to testpanels or coupons forresearch and development, quality control, orperformance testing. Additionally, miscellaneous metal and plastic parts coatings do not include any coatings that are otherwise defined in CAA Section 183(e) which have been previously addressed by othererGs. These previously addressed coatings include: shipbuilding and repair coatings; aerospace coatings; wood furniture coatings; metal furniture coatings; large appliance coatings; automobile and lightduty truck assembly coatings; flatwood paneling coatings; miscellaneous industrial adhesives; fiberglass boatmanufacturing materials; and paper, film, and foil coatings.

8The USEPA CTG addressing miscellaneous metal and plastic parts coatings provides a more detailed description ofthe affected categories and the processes in which they are used and emit VOM 1
2.2 Emissions 

### in Illinois from Miscellaneons Metal and Plastic Parts Coatings The Illinois EPA has determincd that there are approximately III sources in l11inois NAAs that fall into the miscellaneous metal and plastic parts coating category, and that meet or exceed the 15 pound per day criteria for YOM emissions for sources inthe proposed regulation. Because existing emission sources in Illinois arc riotrequired to report whatportion oftheir YOM emissions are due to metal and plastic parts coatings, it is difficultto determine the total YOM emissions directlyrelated to the category. The Illinois EPA used dataprovided by USEPA to determine which Illinois sources would potentially be affected. Based on this information the Illinois EPA estimates thatpotentially affected sources in Illinois emitted a total of 1730 tons of YOM in 2007. The USEPA's CTG on miscellaneous metal and plastic parts coatings does not detail the level ofcontrol anticipated from proposedregulations meeting the CTG's recommendations, so the Illinois EPA has not estimated the YOM reductions that may result from implementation ofthis proposal.
While the dataregarding total emissions ofVOM and emission reductions from the proposed regulation ofmiscellaneous metal plastic parts coatings is uncertain, CAA Section 182(b)(2)(A) requires that SIPs be revised to include RACT for YOM sources coveredby a CTG issuedby USEPA afterNovember 15, 1990, and before the area's date ofattainmentl

. The USEPA CTG regarding this categorywas intended to provide recommendations for RACT control ofthe various affected coatings. The Illinois EPA concurs with the recommendations ofthe CTG and has included them, with few exceptions, in the proposed regulation for Group IV ofconsumer and commercial products
.. 2.3 Technical Feasibility ofControls The CTG issued byUSEPA for the control ofemissions from miscellaneous metal and plastic parts coatings proposes three options for the control ofemissions from affected sources, as well as additional recommendations for workpracticesrelated to coating activities and cleaning 

### 9activities. The three options for control detailed in the eTG are intended to provide a measure of flexibility in compliance. The Illinois EPA has included all three options in the proposed regulation.
Reduction ofVOM emissions from this category can typically be achieved by: pollution prevention methods such as product substitution orreformulation to use lower YOM materials; use ofhigher efficiency coating application equipment such as electrostatic sprayers orhigh volume low pressure ("HVLP") sprayers; the use ofcapture and control equipmentto capture emissions and combust them, orto recover them using adsorption or absorption processes; and the use ofrecommended work practices. The eTG for miscellaneous metal and plastic parts coatings provides a more complete description ofthese control methods'.'
The Illinois EPA has relied upon the eTG to determine the technical feasibility oftheproposed YOM limits. The USEPA based the limits and practices in the eTG on regulations achievingthe same level ofemissionreduction in ealifomia, and specifically in the South CoastAir Quality ManagementDistrict. Based upon compliance with these limits in otherregions ofthe U.S., along with the flexibility in compliance measures in the proposedregulation, the limits in the proposedregulation are technically feasible.
2.3.1 Use ofLow YOM Coatings To reduce YOM emissions from miscellaneous metal and plastic parts coatings, an affected source mayuse low-YOM coatings. Option I from the eTG involves recommended application methods and specific limits on YOM content in coatings in terms ofmass ofYOM pervolume of coating. TheseYOM limits do not include water and exempt compounds in the calculation of mass pervolumeYOM content. Table 2.1 lists the YOM limits in terms ofmass ofVOM per volume ofcoating for each coating categoryincludedjn the proposedregulation. Table 2.2 specifies the equivalent YOM limits in tenns ofmass ofYOM pervolume ofsolids. Included in the eTG there are a number ofexceptions for specified coatings oruses ofthose coatings that exemptthem from eitherthe YOM limits, the application methods, orboth. This is due to these coatings requiring a higherYOM content in orderto meetperformance specifications. These

10

### Table 2.1 VOM Limits for Metal and Plastic Parts Coatings in Terms ofMass per Volume ofCoating Metal Parts and Products Air Dried Baked kg VOM/L Ib VOM/gal kg Ib Coating Category Coating Coating VOM/L VOM/gal Coating Coating General One Component 0.34 2.8 0.28 2.3 GeneraI Multi Component 0.34 2.8 0.28 2.3 Camouflage 0.42 3.5 0.42 3.5 Electric-Insulating Varnish 0.42 3.5 0.42 3.5 Etching Filler 0.42 3.5 0.42 3.5 Extreme High-Gloss 0.42 3.5 0.36 3.0 Extreme Performance 0.42 3.5 0.36 3.0 Heat-Resistant 0.42 3.5 0.36 3.0 High Performance Architectural 0.74 6.2 0.74 6.2 High Temperature 0.42 3.5 0.42 3.5 Metaiiic 0.42 3.5 0.42 3.5 Military Specification 0.34 2.8 0.28 2.3 Mold-Seal 0.42 3.5 0.42 3.5 Pan Backing 0.42 3.5 0.42 3.5 Prefabricated Architectural Multi-Component 0.42 3.5 0.28 2.3 Prefabricated Architectural One-Component 0.42 3.5 0.28 2.3 Pretreatment Coatings**0.4~** 3.5 0.42 3.5 Repair and Touch Up 0.42 3.5 0.36 3.0 Silicone Reiease 0.42 3.5 0.42 3.5 Solar-Absorbent 0.42 2.5 0.36 3.0 Vacuum-Metal/zing 0.42 3.5 0.42 3.5 Drum Coating, New, Exterior 0.34 2.8 0.34 2.8 Drum Coating, New, Interior 0.42 3.5 0.42 3.5 Drum Coating, Reconditioned, Exterior 0.42 3.5 0.42 3.5 Drum Coating, Reconditioned, Interior 0.50 4.2 0.50 4.2 Plastic Parts and Products kg VOM/L Ib VOM/gal

Coating Coating Generai One Component 0.28 2.3 General Multi Component 0.42 3.5 Electric Dissipating Coatings and Shock-Free 0.80 6.7 Coatings Extreme Performance (2-pack coatings) 0.42 3.5 12Metallic Military Specification (1 pack) Military Specification (2 pack) Mold-Seal Multi-colored Coatings Optical Coatings Vacuum-Metalizing 0.42 0.34 0.42 0.76 0.68. 0.80 0.80 AutomotivelTransportation Coatings' 3.5 2.8 3.5 6.3 5.7 6.7 6.7

High Bake Coatings - Interior and Exterior Parts Flexible Primer Non-flexible Primer Base Coats Clear Coat Non-basecoaUciear coat kg VOM/L Coating

0.54 0.42 0.52 0.48 0.52 Ib VOM/gal Coating
4.5 3.5 4.3 4.0 4.3 Low Bake/Air Dried Coatings - Exterior Parts Primers Basecoat Clearcoats Non-basecoatiClearcoat Low Bake/Air Dried Coatings - Interior Parts Touchup and Repair Coatings 0.58 4.8 0.60 5.0 0.54 4.5 0.60 5.0 0.60 5.0 0.62 5.2

Primers Topcoat Texture Coat Fog Coat Touchup and repair Business Machine Coatings kg VOM/L

Coating

0.35 0.35 0.35 0.26 0.35 Ib VOM/gal Coating 2.9 2.9 2.9 2.2 2.9

• For red, yellow. and black automotive coatings, except touch up and repair coatings, the recommended limit is determined by multiplying the appropriate limit in this table by 1.15.

13Pleasure Craft Surface Coatings

Extreme High Gloss Topcoat High Gloss Topcoat Pretreatment Wash Primers Finish Primer/Surfacer High Build Primer Surfacer Aluminum Substrate Antifoulant Coating Other Substrate Antifoulant Coating All other pleasure craft surface coatings for metal or plastic kg VOM/L Coating

0.49 0.42 0.78 0.42 0.34 0.56 0.33 0.42 Ib VOM/gal Coating 4.1 

### 3.5 6.5 

### 3.5 2.8 4.7 2.8 

### 3.5

Vehicle Cavity Wax Vehicle Sealer Vehicle Deadener Vehicle GasketfGasket Sealing Material Vehicle Underbody Coating Vehicle Trunk Interior Coating Vehicle Bedliner Vehicle Lubricating Wax/Compound Motor Vehicle Materials kg VOM/L Coating

0.65 0.65 0.65 0.20 0.65 0.65 0.20 0.70 Ib VOM/gal Coating 

### 5.4 5.4 5.4 1.7 5.4 5.4 1.7 5.8


### 2.3.2 Use ofLow YOM Coatings and Add-on Controls An affected sourcemay also choose to combine theuse oflow-YOM coatings with add-on controls. This compliance option from the CTG involves achieving equivalentYOM emissions from affected coatings by limiting YOM emission rates in terms ofmass ofVOM emitted per volume ofcoating solids applied. Table 2.2 lists the YOM limits for each coating category included in theproposed regulation. This option is intended for use by facilities employing a combination oflow-VOM coatings, specific application methods, and add-on controls to achieve the mass ofVOM emitted relative to applied coating solids. These limits have been converted from those set forth in section 2.3.1, assuming a YOM density of

### 883g1L.

14

### Table 2.2 VOM Limits Metal and Plastic Parts Coatings in Terms ofMass perVolume ofSolids Metal Parts and Products Air Dried Baked Coating Category kg VOM/L Ib VOM/gal kg VOM/L lbVOM/gal Solids Solids Solids Solids General One Component 0.54 4.52 

### 0040 3.35 General Multi Component 0.54 4.52 

### 0040 3.35 Camouflage. 0.80 6.67 0.80 6.67 Electric-I nsulating Varnish 0.80 6.67. 0.80 6.67 Etching Filler 0.80 6.67 0.80 6.67 Extreme High-Gloss 0.80 6.67 0.61 5.06 Extreme Performance 0.80 6.67 0.80 6.67 Heat-Resistant 0.80 6.67 0.61 5.06 High Performance Architectural 4.56 38.00 4.56 38.00 High Temperature 0.80 6.67 0.80 6.67 Metallic 0.80 6.67 0.80 6.67 Military Speciiication 0.54 4.52 

### 0040 3.35 Mold-Seal 0.80 6.67 0.80 6.67 Pan Backing 0.80 6.67 0.80 6.67 Prefabricated Architectural Multi-Component 0.80 6.67 0.40 3.35 Prefabricated Architectural One-Component 0.80 6.67 

### 0040 3.35 Pretreatment Coatings 0.80 6.67 0.80 6.67 Silicone Release 0.80 6.67 0.80 6.67 Solar-Absorbent 0.80 6.67 0.61 5.06 Vacuum-Metalizing 0.80 6.67 0.80 6.67 Drum Coating, New, Exterior 0.54 4.52 0.54 4.52 Drum Coating, New, Interior 0.80 6.67 0.80 6.67 Drum Coating, Reconditioned, Exterior 0.80 6.67 0.80 6.67 Drum Coating, Reconditioned, Interior 1.17 9.78 1.17 9.78 Plastic Parts and Products Coating Category General One Component General Multi Component Electric Dissipating Coatings and Shock-Free Coatings Extreme Performance (2-pack coatings) kg VOM/L Ib VOM/gal Solids Solids



### 0040 3.35 0.80 6.67 8.96 74.70 0.80 6.67 15Metallic Military Specification (1 pack) Military Specification (2 pack) Mold-Seal Multi-colored Coatings Optical Coatings Vacuum-Metalizing 0.80 0.54 0.80 5.24 3.04 8.96 8.96 6.67 4.52 6.67 43.70 25.30 74.70 74.70 AutomotivelTransportation Coatings· Coating Category kg VOM/L Ib VOM/gal Solids Solids AutomotivelTransportation Coatings High Bake Coatings - Interior and Exterior Parts Flexible Primer 1.39 11.58 Non-flexible Primer 0.80 6.67 Base Coats 1.24 10.34 Clear Coat 1.05 8)6 Non-basecoaUclear coat 1.24 10.34 Low Bake/Air Dried Coatings - Exterior Parts Primers 1.60 13.80 Basecoat 1.87 15.59 Clearcoats 1.39 11.58 Non-basecoaUClearcoat 1.87 15.59 Low Bake/Air Dried Coatings - Interior Parts 1.87 15.59 Touchup and Repair Coatings 2.13 17.72 Business Machine Coatings Primers 0.57 4.80 Topcoat 0.57 4.80 Texture Coat 0.57 4.80 Fog Coat 0.38 3.14 Touchup and repair 0.57 4.80

• For red. yellow. and black automotive coatings. except touch up and repair coatings. the recommended limit is determined by multiplying the appropriate limit in this table by 1.15
..

16Pleasure Craft Surface Coatings Coating Category Extreme High Gloss Topcoat High Gloss Topcoat PretreatmentWash Primers Finish Primer/Surfacer High Build Primer Surfacer Aluminum Substrate Antifoulant Coating Other Substrate Antifoulant Coating All other pleasure craft surface coatings for metal or plastic kg VOM/L Solids

1.10 080 6.67 0.80 0.34 0.56 0.33 0.42 Ib VOM/gal Solids

9.20 6.67 55.60 6.67 280 4.70 2.80 3.50

Forthe limits set forth in Sections 2.3.1 and 2.3.2 ofthis document, the USEPA recommends One or more ofthe following application methods: electrostatic application, HVLP spray, flow coat, roller coat, dip coat (including electrodeposition), airless spray, air-assisted airless spray, or other coating application methods capable ofachieving a transfer efficiency equivalentto orbetter than that achievedby HVLP spraying.
2.3.3 90% Captnre and Control Efficiency In lieu ofusing low YOM coatings as described in Sections 2.3.1 and 2.3.2, a source may optto install and operate an add-on captnre and control system thatprovides an overall control efficiency ofat least 90%. Sources complying with this compliance option would notbe required to meetthe aforementioned YOM limits, orto employ recommended application methods. This compliance option is expectedto achieve emission reductions ofVOM that are equal to or greaterthanthe limits in Sections 2.3.1 and 2.3.2.

2.4 Economic Reasonableness and Cost Effectiveness ofControls The Illinois EPA has relied upon the cost analysis conductedby theUSEPA forthe eTGs for miscellaneous metal and plastic parts coatings to determine that the proposed regulations are cost effective.
17The USEPA used the National Emissions Inventory database to estimate the number of miscellaneous metal and plastic parts coatings operations in non-attainment areas in the United States that meet the IS lb per day threshold. They estimated that there are 1296 such sources in the United States emitting an estimated 22,108 tons ofVOM peryear. The USEPA also estimated the average cost ofcompliance with the CTGs for this emission category to be $10,500 per source, and a co'st effectiveness of$1,758 perton ofVOM reduced'. Using these estimates, an affected source, on average, could be expected to achieve areduction in YOM emissions of 5.97 tons annually. This would amount to an estimatedreduction of662 tons ofYOM in lIlinois NAAs. However, it shouldbe noted that these estimated reductions would include reductions thathave already occurred at sources since the currentregulations were implemented, and not necessarily reductions from current emission levels.
The USEPA supplied the data that was used to detemiine that there were 1269 potentially affected sources nationwide. Ofthese 1269 sources, ISS were found to be in Illinois NAAs and potentially subject to the CTGs. One hundred eleven ofthese 155 lIlinois sources remained in operation in 2007. Because the source emission datais generallynot specific enough to determine whether a source is emitting 15 pounds ofVOM perday specifically from miscellaneous metal and plastic parts coatings, a conservative approach for costestimates was used. Forthepurposes ofcost estimation, the Illinois EPA selected all sources in NAAs that were selectedby the aforementioned process. Because there were III potentially affected sources, the Illinois EPA estimated, assuming a $10,500 per source average cost ofcompliance, a maximum total compliance cost for Illinois state-wide to be approximately $1,165,500. While this figure is almost certainly an over-estimate ofpotential costs, the Illinois EPA considers the USEPA's estimate for cost effectiveness of$1758 perton to be reasonable for control ofVOM.
A more detailed description ofthe USEPA's co,st analyses canbe found in the CTG for miscellaneous metal and plastic parts coatings I.

182.5 Additional Recommendations: \Vork Practices In addition to the limits recommended in the CTG and included in the proposedregulation, the CTG also recommends work practices for miscellaneous metal and plastic parts coating operations. The workpractices address coating activities and cleaning activities, and are intended to furtherreduce YOM emissions from the source category. The CTG states that the emission reductions are unquantifiable, but states that the work practices will result in anet cost savings to sources in this category.
The CTG recommends that workpractices for coating related activities include the following: (1) store all YOM-containing coatings, thilmers, and coating-related waste materials in closed containers; (2) enSUre that mixing and storage containers used for YOM-containing coatings, thinners, and coating-related waste materials are kept closed at all times except when depositing orremoving these materials; (3) minimize spills ofVOM-containing coatings, thirmers, and coating-related waste materials; and (4) convey YOM-containing coatings, thinners, and coatingrelated waste materials from one location to anotherin closed contaIners orpipcs.
The CTG further recommends that work practices for cleaning materials include the following: (1) store all YOM-containing cleaning materials and used shop towels in closed containers; (2) ensure that storage containers used for YOM-containing cleaningmaterials are kept closed at all times except when depositing orremoving these materials; (3) minimize spills ofYOM containing cleaning materials; (4) convey YOM-containing cleaningmaterials from one location to anotherin closed containers orpipes; and (5) minimize YOM emission from cleaning of application, storage, mixing, and conveying equipmentby ensuring that equipmentcleaningis performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers.
The proposed regulation includes the recommended workpractices from the CTG in their entirety.

192.6 Potentially Affected Sources in Illinois In detennining the number ofsources potentially affected by the proposed regulation regarding miscellaneous metal and plastic parts coatings, the Illinois EPA relied upon infonnation provided by the USEPA. This source specific infonnation was the datathat the USEPA relied upon to estimate the number ofsources that would be impacted nationwide. The CTG for miscellaneous metal and plastic parts coatings states that 1269 sources nationwide in non-attaimnent areas would be affected by rules to implement the CTG. Ofthe 1269 sources in theU.S., 155 sources were found to be in Illinois non-altaimnent areas, and 111 ofthese sources remained in operation in 2007. Table 2.3 lists these impacted sources and their location.
Table 2.3 Potentially Affected Sources in Illinois

. Cook County

. l._
.._,. ••_. '_",

__,.....•..

_ .•

Elk Grove Village

• Elgin

. . • Elgin Name

NORTHROP GRUMMAN SYSTEMS CORP

HIGHLAND MACHINE AND SCREW PRODUCT CO
. Highland ADVANCED ELECTRONICS INC ,-.- . DEHLER MANUFACTURING CO EAGLE ELECTRONICS INC

JOHN STERLING CORP CHEM-PLATE INDUSTRIES INC i ILLINOIS To6L WORKS - SHAKEPROOF Div

_" ••••• .• , __ .".

__ •••

_ .n•• ••• '. ._.' ••

__

· MACHINERY COMPONENTS INC

· UNION PACIFIC RAILROAD CO

.............. _ ... --.-_. - . BORG WARNER TRANSMISSION SYSTEMS

... --., .

· PEERLESS INDUSTRIES

CALUMET ARMATURE & ELECTRIC CO Illinois Source 

### ID 031045AAE
. UGN INC

119055AAK

111075AAD 031440AHD 089807AAD

· .-..,-.__.-. _.- .... ----_. • 089483ACD

0316DDFXO

, .

031015AAC 031186AGO 031258AAZ 

### _. Glty

· Chicago

Ijeights

•

### Elg~~ . . .....

### K.~n~.c;o~~ly .

West Chicago : Kane Counly
.. • Chica!;j()..
.... Co."k Counly. Elk Grove DuPage .043440AHH
. COATING TECHNOLOGIES INC •

. "
.. __**.;'{ill~g~.... ...~County**  . ·.

### 03~~03~E ...

### A~~c;O**I.~C.** ....

### ~. A}.sip.
...

### Co()k.C()u~ly.

031096ABM CLAD REX INC Franklin Park •. Cook Counly
• 031600EIM**GE~.ERJ',~E~EC:rRICIN!ERNATIONAL** INC
..**c;~i~~~."..** •**Coo~Counly** . •**031~OOFSE** ,ACTION**F<Ac;~~.MA~UFACTURING** CO "'
..**:C;hica&JoC,,()~Counly**

·031600FME .• INGLOT**~L~c;:r.R()N.IC~GORP** c;h.icag"
.. c;ookC;oUnly Rolling

· Meadows
. Cook County

" --'

....

### -_...,,-- .. - ... _ .. , .,....- -'".. .'
..- Chicago Cook County Schaurnburg •...Cook**(~o~~ly** West Chicago
.

### ~~~~tge
... ... y ..**B~~lNood.** Cook c;ounty Melrose Park
. Cook County Riverdale ; Cook County Madison

.. gounly
..

, Cook County Richmond • McHenry

..... C;ounJL
. , Kane County ." "Cook**co~n;y** .

# 'I · 043090ADE · 031273ACK

. ,.,.. _..

· 0316DDFTR

D31282ACH

. .... . ,. '-,.. - ... _.. ... - . · 089438ADU . KINNEY ELECTRICAL MFG CO

......... ,._. - - . 031438AAW ELGIN SWEEPER CO 20; Chicago

: Lisle ; Aurora

.. Lombard

· University

Park

• +-. •••.••.

_ •.

Waukegan Bridgeview · Chicago

. ----,."

.-.-.

· Chicago



# ..**~Dowr;ers""** Grove REXNORD CORP· REX BEARING DIV

, ElM CORP 119115ABC 'MILLENNIUM RAIL INC 163060AAC ,WIEGMANN AND CO INC 043055AAC 

### ! LOCKFORMER CO 031600CUP 'KREL LABORATORIES INC 043407AAH
. FLUID AIR INC

;.-

.__.._---- ----_., ----,.

### _._---

'031600EZF
. YALE POLISHING & PLATING

..**--._~** _ ..--+.- .- ..- .,...,..... ""-"'
.._--", _.- ...'
..... - ..-

..,... 031600CFW
. WELDED TUBE CO OF AMERICA

'197072AAC ,FEDERAL SIGNAL CORP SIGNAL DIVISION

.. : 031024ABC • G &W ELECTRIC CO

. 043030AAU , DuPage**._,:.Q,?-u.n~y.**

... Cook County SI. Clair

· Freeburg

....'
... .._ County 

## -'Ou-Page

, County

. Madison Wood River County

... __**;.B~u~.I~.la~~ ,.:(~()QkCounl)'**  Harwood

## _03~~~~~~**:.~E.~:J.A~.IND.U.~~.RI.~~~~~.** ... . ..

## :.t!eig~l~ ..... ",.

## ~~o~**Cou~ty** ... '043030AAG
.. MAGNETROL INTERNATIONAL
. Downers
. DUPage .t.... ..**_.......:§r9"~** 

### .. _. . .C.ounty .•

_..

## :O=~4~~~~1**COMMERCIALFI~I.SHE:S.~O** L

## TDe:I~~~~ove.**~ook Coun~** **,.0328o..5~(3** ..**[)~RAC:;()PR()D~.c;:r?_It'JC:;...** . ., ..**~tr~",:"w..ood Coo.kCo~~ty**  .
, 031600FSL S & B FINISHING CO
.. Chicago , Cook County**'031~OO~~E.** RS OWENS AND CO
. Chicago
.. (,;ook,**Cou~ty.** . ,031600EYE
. SORINI RING MANUFACTURING CO INC
... .... ,**Chi~"Q?..** ,C.??k.C.".lJ.n.tl'.
.. ,

097200AAZ'TACTION ATHLETIC EQu'ipMENTiNC
. .. Zion Lake County
.. ,,,._.. _ ,.__._._.•

_**_~_** ._•• _, ._ "._, "

__ _._ ..__. __ ......••.. •.........

__ __ _ _ .• .•..

__•.•_.,, _. __l. "_,., ".• ".

__'._"

__..•....._. 

## i 031096ANA : QC FINISHERS
. Franklin Park 'Cook County**L.1.§I!'O?~~ .CLEVEL~NPS:rEELC:;()NTAINER**  CORP
.. __**P~c:t~nE!** .. _. .. Will C0lJ..n1l'..

__, ,097418AAQ
. VAPOR BUS INTERNATIONAL ' Buffalo Grove ,Lake County , .....----.--•.--..-..- _ --..- - ---... .._ - .-.--.-. ";"M'''fj -.. ; 111065AAQ ,NISSAN FORKLIFT CORPORATION NA • Marengo
. c enry

___..__ __. _ ". ..._ "

__ ._ :..**C;0ll.~ty**

. 043090ACH 'NATIONAL CONTROLS

## CORP:.:"'':~~_hi~~~~:.~~~;t~~ _**~031414APT":'VAPoR'POW'ER** .... , Bensenville ' Cook County : 031600CSZ : READY METAL MANUFACTURING

### CO:.s:.~~~\l.?..... __.":"

### C:;O?~C~~nty_

## '~7i15~~x. 

# ..**'~~~sc:~§rr~~RMF~.~~I~C' ~.~_u.n'!.~ein** **~~ake** c:;ounty ,

# rO=~.O~~~ ... AL_C?

# S~.~~N.~ ..

# IND~S~~~=-s.._____.;~;:~~~..._ . __

# C~Ok**~ount~.,** ; 031096ABK
. BRUNNER AND LAY INC Franklin Park
.. Cook County
..

# --1-~9~~~~~~**"~~Di~;~~~~~~'CO~~~~~~:LC** .. _ .... '._

# ~_ -

# _~~~~~~.~i;y~·**T~~~~~~n."** _-I

, 031174AAA. " GENERAL MOTORS
.. ELECTRO·MOTIVE DIV McCook , Cook County i 163010AAH 'EMPIRE COMFORT SYSTEMS Belleville; SI. Clair ; County

Cook County Cook County'.

.. :...•. ".'"
... , •..•..-._- 1 DuPage

, County

DuPage

. ,County

: Will County

Lake County
• Cook County' 097190AD'F';CH'ERRy'ELECTRicAL PRODUCTS : 031027AAG
. SIGNODE CORP
21Cook County

Cook County

... _.. .. DuPage Co."nly

_ SI. Clair

· County _.

Cook County DuPage 

### _g"u_':l..tL .'

..**c::()()~<:;?_u_nty**

.... '. Will**C_o~~!L**

.. Cook County

. _ ,--- _._--

·**C()()~c:;()_u~l~** .

Cook County
. : Cook County

Itasca Highland

Chicago Alorton · Aurora

Barrin[iton Chicago

. -- _. --

_ ...

### __.- -_ ..

· Morton Grove

Wheeling. Chicago Palatine

. .. -...-.. - Alsip

·**C~icago**

Chicago

.... - -_..._.

· Chicago

Heights. BRITT INDUSTRIES ICON IDENTITY SOLUTIONS AMERICAN FLANGE & MANUFACTURING CO INC ; Carol Stream

BASLER ELECTRIC CO API INDUSTRIES

ITW BUILDEX GOODER HENRICHSEN CO INC 031403AAC

043450AAA 031045AMS · 031297AAN 'SHELCO STEEL WORKS INC

---- ..

# _-_
..- . _ ... _.. ..._- - .-

· 031030AAI ELKAY MANUFACTURING

.. 119055AAB · 031440AHP · Bellwood

....... ,... _.-'

Elk Grove Cook County

.**_\J~lage_.** .. _ Crest Hill**".--.-.~ ,._~**  .._."
. C_

h 

### 2 ca

_[io Broadview

. .. ....•.. ._-,.

· Broadview

Arlington Heights

__. ?o.."th**_H~II~nd** '
..**c.O?~ ~o_u~y**  __**_~r()a_d~i~w** .. ..**C_o~~** _c;?ul1.tL
• 111813AAE TC tNDUSTRIES INC Crystal Lake' McHenry 

### _. .... ' .

__.._.. ... __. _._ . ,.__.__. . _... c;.()!!.':l..tX"
.. ..

.. 089802AAE
. RAYVAC PLASTIC DECORATORS INC
. Big Rock Kane County :**O~-3-0-4~~** ..**~~I~~~~-B~~~~R** CORP " Glen,i"'-!,, --. . DuPage --.. - - .

· Heights • County
. '197085AAS RUSSELL T BUNDY ASSOCIATES INC D/B/A PAN-
. Rockdale Will County : GLO**._o.3..1_~~OC;_S'~** .**S~ c:_~_~Ec:TRIc:_C()**  ... _ __ ... C;hicago**.,C:oo~C:()u~!y**

### 03!_~§s..~ElH_Y(L()_~_FA_~~~f\J~~ CORP ._. _ __. _ ... __

### Lin~o~n",oo~**._c.09~~()u!.'ty ,03.1_~~§~~_K**  •**IN~~~!'J!,~I<:J..f\J!,LTRUCK** AND ENC;INE C()RP... ._ Melrose**ParkC()()~_C;()~n!y** Elk Grove

..._**\I~I§ge** Chicago Cook County**.~a!,,~,,-e__** ....**C:()()~-'~**.. ()t:nty Madison

·**<::o~nty** _

... '.

_**£r~nkf9~** ... . _\IIIiIIFCl..unty'_ Melrose Park
. Cook County K-,,_neC;()unty

_ !-ake**C:()u.~ly** c:ookc:()unty Cook County C()()k**.Co~,,-ty_** Cook County

....... , ,., Cook County

....... - .....**_.~** .. Cook County Co'okCounty

.. Cook C0..unty ; 031440AKK ; 031015ABZ
. HA FRAMBURG AND CO

; 031600FWW USPS - CENTRAL VMF

· 031234AAM WEBER-STEPHEN INC

. ..- . _. . _.. - .

· 031600FLE ,EAGLEBROOK PLASTICS INC , 043020ABE

· 163005AAE
. METRO EAST INDUSTRIES INC - ....._ ..... '" - --,-_ ...- -----_._--- --_.",.
. -"

.. -

· 197040AAN
. NORWOOD MARKING SYSTEMS INC 

### -_..

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### -_ --_..__._-

## -_ .. _.. , - - ..

· 031186AFK WAGNER ZIP CHANGE _!J8?Oo.5Af-lf'A

__**~<:lLJII"~() ~LE_C:T'3..0NIC::S**  CORf'. 097803AAC CROWN GYM MAT INC

... _

...... -_._-_. - . _ .. , 

### .- 

### - ---_....._...._-..... .....,- 031600GGA MORSE AUTOMOTIVE CORP 

## ·031195Asi·' :'iIT-SELL-AN6'GOSSETI' .-- 031324ACC 'ACCO INTERNATIONAL INC
• 0316-01lGAF R &

## BPOWDER COATiNG

.... _ .. __._ ..._. _. '- 031234MP
. ARLINGTON PLATING CO

._. " .._._- . ._. 031003ABA GREIF BROS CORP 031600CEK ABBEY FINISHING CORP ,-- ....._... _..,. .. .... ----_.. _.- ....

· 031600FXN
. NINA ENTERPRISES INC ,"'" ,'.,.,.--**--._.~-** _ _ ..

### _-_


# __..,- .._ -

· 197025AAF HENDRICKSON STAMPING

• , •••••**~,** ••• ,.' ••

_••• _. "0'_'- "_••' •••_" •• ,,", ••

_ ••• · 031600FGY ACE PLATING CO 

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031030ACP BL DOWNEY CO INC

- ....-..-.....**~._** .._ ....,_.__

### ._-_.. : 031030ACM
. REPLOGLE GLOBES INC



### 22Aurora · Highland : East Alton

: Chicago

· Heights**_S:_h_i9~_Q~____** .__**S:~~k_,?_oun~** : Madison

· Granite City

. __ .**_~.ounty**

: Chicago : Cook County 

### ,

· Joliel._:
..will**C0u.~ty**


## .'-Eik-Grove-- : Cook County

__**-"'iI19g~_** __ ..**:~IQIJ:** . __**L~a~e: S::0un~~**  __

- Homewood ' Cook County

_Madison

, County Skokie ' Cook Coynty

·**~hi9a~_o.__,?o()k** ,?oLJnty 'Chicago
.**c::()~k_** C"unty

Lake Bluff

_Lake Counly

__**--'--~h.iG~.2() ~o()~_C::()unty_**  ..

· Romeoville Will County**-B~~;en~iil~ :C~~k** **C~-;;~iy**
, Madison

. County : Kendall

- County

. Cook County 031440AFY - ACME FINISHING CO



### ,

. 093807AAB ; CATERPILLAR TRACTOR f 031045ABS ; CHICAGO HEIGHTS STEEL •

__.__•.•

_ 1.....
.. ._.._. _.**~_.** . •.. ._.

- 089438AGC ! PLASTIC DECORATOR

".. -_.------ -_._- ,_.__._--_._ .•..•._--._-- ---- 

### ._-- .. : 031075AAB
. ILLINOIS CENTRAL RAILROAD '119020AAG ; OLIN CORP ·031288AHN
. AMERICAN LOUVER CO

......_ •.

__...._.__.... ".... .., ,.,...... - .... "., ... ' ....._- ...__. .031600APY MEYER STEEL DRUM INC ;,.
-..:..


## __._-_.,_._..... ,..,.,,- ... 

### _ .._

..

### __..._---_._. -

## -_._-_ ...---_..._. -_.

### ?3.1600BR~_**;~AK~~'?~D_~J;JG1~~~£<!!'J_~~~~_G** CO ; 097809AAG JESSUP MANUFACTURING CO '031600AXT - PALEX CONTAINTER SYSTEMS ,'--' ---_._---_.**-'_.'--'-'~---'-----** -- --_.- ; 197090AAZ ,AMERICAN STAIR CORP L
.. l

__ . . __.... ._,__. .__.__. : 031414AAM

_ASTROBLAST INC 

## i 119055ABE ; COOPER B-L1NE INC i 031600FAY
. MEYER STEEL DRUM INC ; 119040AAC 'ASF-KEYSTONE INC 1-··'·--·---···,,·-···---····**,~** . ,031600FDI • WHEATLAND TUBE CO ; 197809AAC
. CATERPILLAR INC t - .._- -_.. _ •._._--**~._** .... _. - ,,-- -- ----'•........•- ._-- - ._.. ".•.. '.•. -,. - _.



### 2.7 Existing Regulations The current Illinois regulations regarding miscellaneous metal and plastic parts coatings can be found in 35 IlL Adm_ Code Parts 218 and 219_ A summary ofthe Illinois rules for metal parts coatings and for plastic parts coatings can be found in Appendices C and D, respectively, ofthe CTG for these categories 1_

233.0 Auto and Light-Duty Truck Assembly Coatings 3.1 Description ofSources and Emissions Auto and light-duty truck assembly coatings are coatings applied to new automobile or light-duty truck bodies orbody parts for those vehicles. These coatings are categorized under Section 183(e) ofthe CAA, and are most often formulated and marketed for this purpose. These coatings are applied to vehicles to enhance durability and appearance. This coating category includcs coatings applicd on a contractual basis outsidevehicle manufacturing facilities, butdoes not include coatings used atplastic or composites molding facilities described in the Auto and LightDutyTrucks NESHAP (40 CFRPart 63, Subpart

# rrr/. Likewise, aerosol coatings are not included in this coating category, as they are addressed by the national YOM rule for aerosol coatings and are a separate category under CAA Section 183.
Emissions ofVOM from auto and light-duty truck coatings occur when the solvent carrying the coating material evaporates and leaves the coating material on the surface during application and drying, and to aJesser extent during the mixing and thinning ofthe coating. The majority of emissions from this category occur during coating application, flash off, and the drying and curing ofthe coatings. Emissions from this product category can be reduced through the use of lower YOM coatings, specific applicationmethods and workpractices, and by add-on control equipment forthe capture and control ofemissions.
The coating process for automobiles and light-duty trucks generally consists ofsurface preparation, priming operations, topcoat operations, and final repair operations. The proposed regulation includes control measures for each ofthese phases ofthe coating process to meetthe recommendations ofthe CTG regarding this category. The CTG provides amore detailed description ofthese processes"
3.2 Emissions in Illinois from Auto and Light-Duty Truck Coatin)::s The lllinois EPA has identified only one source in an Illinois non-attainment areathat will be affected by the proposed regulation regarding auto and light-duty truck coatings. FordMotor Co., located·in Cook County, is currently the only source in the Illinois EPA inventorythatis classifiedby the North American Industry Classification System (''NAICS'') codes specifiedby 

### 24USEPA's notice offinal determination and availability ofcontrol technique guidelines' to be affected bythe auto and light-duty tmck coatings category. This single source reported emissions ofapproximately 466 tons ofVOM from the affected coating lincs jn 2007. These coating operations consist oftopcoat operations, prime coat opcrations, sealer application, dip coating application, and a final repair coating line. All ofthese operations excecd the 15 pounds YOM per day criteriataken from the CTG2 and included in the proposed regulation:
3.3 Technical Feasibility ofControls The Illinois EPA has relied upon fhe CTG regarding auto and light-duty truck coatings to determine the appropriate level ofcontrol and the feasibility ofthose measures. The CTG regarding this category was intended to provide recommendations for RACT control ofthe affected coating operations for automobiles and light-duty tmcks. The Illinois EPA's proposed regulations for Group IV consumer and commercial products are consistentwith the CTG's recommendations.
Reduction ofVOM emissions from this category can typically be achieved by: pollution prevention methods, such as product substitution orreformulation to use lower YOM coatings and cleaning materials; use ofhigher efficiency coating application equipment such as electrostatic sprayers orhigh volume low pressure ("HVLP") sprayers; the use ofcapture and control equipmentto capture emissions and combust them, or use ofahybrid system employing a concentrator and an oxidizer; and the use ofrecommended work practices. For amore complete description ofthese control methods the reader is directed to the CTG for auto and light-duty truck assembly coatings2
The CTG issued by the USEPA for control ofemissions from auto and light-duty truck coatings recommends YOM emission limits for coating operations; work practices for storage and handling ofcoatings, thinners, and waste materials; and workpractices for handling and use of cleaning materials. The limits 'and workpractices included in the CTGreflect currentpractices that the USEPA considers to be RACT, and were supplied to the USEPAby member and nonmember companies ofthe Alliance ofAutomobileManufacturers in 2008. For a more detailed

25account oflocal, state, and federal actions leading to the USEPA determination ofthese limits please referto USEPA's eTG for auto and light-duty truck coatings2

. The recommended YOM limits for auto and light-duty truck coatings listed in Table 3.1 are specified by assembly coatingprocess, and in the case ofelectrodeposition primer ("EDP") operations, the YOM content is dependent on the solids turnoverratio, 

### RT. The solid turnover ratio is defined as the ratio oftotal volume ofcoating solids that is added to the EDP system in a calendarmonth divided by the total volume design capacity ofthe EDP system.

Table 3.1 Recommended YOM Emission Limits for Automobile and Light-Duty Truck Assembly Coatings Assemblv Coatinq Process Recommended VOM Emission Limit Electrodeposition primer When solids When 0.040s;R,.<0.160 When (EDP) operations (including turnover ratio application area, spray/rinse (RT )"",O.16 RT s;0.040 stations, and curing oven) .0.084 kg VOM/liter 0.84 x 350o.160-Rrkg NoVOM (0.7Ib/gal coating VOM/liter coating solids. emission limit. solids applied Primer-surfacer operations 1.44 kg ofVOM/liter of deposited solids (12.0 Ibs VOM/gaJ (including application area, deposited solids) on a daily weighted average basis as flash-off area, and oven) determined by following the procedures in the revised Automobile Topcoat Protocol. Topcoat operations 1.44 kg VOM/liter of deposited solids (12.0 Ib VOM/gal deposited (including application area, solids) on a daily weighted average basis as determined by flash-off area, and oven) following the procedures in the revised Automobile Topcoat Protocol. Final repair operations 0.58 kg VOM/liter (4.8 Ib VOMl.gallon of coating) less water and less exempt solvents on a daily weighted average basis or as an occurrence weiqhted averaqe. Combined primer-surfacer 1.44 kg VOMlliter of deposited solids (12.0 Ib VOM/gal deposited and topcoat operations solids) on a daily weighted average basis as determined by following the procedures in the revised Automobile Topcoat Protocol.
. In addition to the emission limits for assembly coating operations for automobiles and light-duty trucks, the eTG recommends YOM emission limits for anumber ofmiscellaneous materials used in auto and light-duty truck assembly coating. These limits are listed in Table 3.2, and have been included in their entirety in the proposedregulation. 

### 26Table 3.2 Recommended YOM Emission Limits for Miscellaneous Materials Used at Automobile and Light-Duty Truck Assembly Coating Facilities (grams of YOM per liter ofcoating excluding water and exempt compounds as applied)
Material Recommended YOM Emission Limit Automobile and light-duty truck glass bonding primer 900 g VOM/liter Automobile and light-duty truck adhesive 250 g VOMJliter Automobile and light-dutytruck cavity wax 650 g VOM/liter Automobile and light-duty truck sealer 650 g VOM/liter Automobile and light-duty truck deadener 650 g VOM/liter Automobile and light-duty truck gasket/gasket sealing material 200 g VOM/liter Automobile and light-duty truck underbody coating 650 g VOM/liter Automobile and light-duty truck trunk interior coating 650 g VOM/liter Automobile and light-duty truck bed liner 200 g VOM/liter Automobile and light-duty truck weatherstrip adhesive 750 g VOM/liter Automobile and light-duty truck lubricating wax/compound 700 9 VOMlliter
3.4 Economic Reasonableness and CostEffectiveness ofControls The USEPA estimates thatthere will be no additional cost for the implementation ofthe control techniques guidelines for auto and light-duty truck assembly coating. Affected sources have reduced YOM emissions from coating operations in response to the New Source Performance Standards ("NSPS''), the 2004 NESHAP6 for this category, and various State rules. The recommendations from the CTG for this category were derived from information supplied to the USEPA by the Alliance ofAutomobile Manufacturers, and reflectmeasures currently being implemented at affected sources. Further, the USEPA estimates that the additional work practices recommended in the CTG will result in anet cost savings to sources, as implementing tllese work practices reduces the amount ofcoating and cleaning materials used.

273.5 Additional Recommendations: Work Practices 

### In addition to the limits recommended in the USEPA CTG and included in the proposed regulation, the CTG also recommends work practices for auto and light-duty tmck assembly coating operations. The work practices included in the CTG address coating activities and cleaning activities, and are intended to further reduce YOM emissions from the source category. The CTG states thatthe emission reductions are unquantifiable, but states that the workpractices will resultin anet cost savings to sources in this category.
The CTG recommends that work practices for coating related activities and cleaning activities include the following: (I) store all YOM-containing coatings, thinners, and coating- related waste materials in closed containers; (2) ensure that mixing and storage containers used for YOM-containing coatings, thinners, and coating-related waste materials are kept closed at all times, except when depositing or removing these materials; (3) minimize spills ofYOMcontaining coatings, thinners, and coating-related waste materials; (4) convey YOM-containing coatings, thinners, and coating-related waste materials from one location to anotherin closed containers orpipes; and (5) minimize YOM emissions from cleaning ofstorage, mixing, and conveying equipment.
The CTG further recommends that sources in this category develop and implement awork practice plan to ensurethat YOM emissions are minimized from the following operations: vehicle body wiping; coating line purging; flushing ofcoating systems; cleaning ofspray booth grates; cleaning ofspray booth Walls; cleaning ofspray booth equipment; cleaning external spray booth areas; and other housekeeping measures (e.g., keeping solvent-laden rags in closed containers). Ifan affected source already has a work practices plan in place from the aforementioned 2004 NESHAP6, the proposed regulation does not require a new plan.
The proposed regulation includes the recommended workpractices from the USEPA CTGin their entirety.



### 283.6 Potentially Affected Sources in Illinois As previously stated, Illinois EPA has only identified One source from its emissions inventory that will be affected by the regulation regarding auto and light-duty truck assembly coatings. This source is Ford Motor Co. in Cook County (source ill 031600AAR).

3.7 Existing Regulations The current Illinois regulations regarding automobile and light duty truck assembly coatings in NAAs can be found in 35 Ill. Adm. Codc Parts 218 and 219. These rules currently are based upon the 2004 NESHAP6 as stated above, and a summary ofthese regulations can be found in the CTG for this category'.

29·4.0 Miscellaneous Industrial Adhesives 4.1 Description ofSources and Emissions The miscellaneous industrial adhesives category includes adhesives and adhesive primers at manufacturing and repair facilities with adhesive application operations. The category does not include adhesives that have been,addressed by earlierCTGs. Miscellaneous industrial adhesives are used forjoining surfaces

### in assembly and construction ofa large variety ofproducts. Adhesives allow for faster assemhly speeds, less laborinput, and more ability forjoining dissimilarmaterials than other fastening methods. Although there are a wide variety ofadhesives fonnulated from amultitude ofsynthetic and natural raw materials, all adhesives canbe generally classified as solution/waterborne, solvent-borne, solventless or solid (e.g., hot melt adhesives), pressure sensitive, hot-melt, orreactive (e.g., epoxy adhesives and ultraviolet-curable adhesives). Adhesives can also be generally classified according to whetherthey are structural or nonstructural. Structural adhesives are commonly used in industrial assembly processes and are designed to maintain aproduct's structural integrity3
The YOM emissions from miscellaneous industrial adhesives are generally dueto evaporation of solvents during application ofthe adhesive, drying and curing ofthe adhesive, and in cleaning operations. The majority ofemissions occur during the application and drying/curing ofthe adhesives. Industrial adhesives are applied in anumber ofways that include: air atomized spray, electrostatic spray, high volume/low pressure (HVLP) spray, dip coating, flow coating, brush or roll coating, electrocoating, and hand application. For amore detailed description ofoperations involved in the use ofmiscellaneous industrial adhesives please referto the USEPA CTG3 for the category.
There are currently no Federal or Illinois regulations specifically addressing miscellaneous industrial adhesives. The intent ofthe CTG regarding the category is to ,ecommend control measures that are considered RACT. The USEPA detennination ofRACT and the issuing of CTGs were based upon anumber ofcurrent regulations forindustrial adhesives in place in a number ofCalifornia air qualitymanagement districts. For amore detailed description ofthe regulatory history that was evaluated by the USEPA, the readeris directed to the CTG3 for miscellaneous industrial adhesives. 

### 304.2 Emissions 

### in Illinois from Miscellaneous Industrial Adhesives The Illinois EPA has detennined that there are approximately 12 sources in Illinqis nonattainment areas that couldbe potentially affected bythe proposed regulation for miscellaneous industrial adhesives. The Illinois EPA identified these sources from data provided by the USEPA while that agency was researching the CTG addressing this category. This group of sources was screened to detennine whether a source was in an Illinois NAA, and finally to detennine whether the source could potentially exceed the 15 pound per day YOM emission criteria from the CTG. Because the Illinois emission inventory data is not adequately specific to detennine whatportion ofa source's emissions are due to industrial adhesives, it is difficult to detennine the total YOM emissions directly related to the category at any given source. The potentially affected sources in Illinois NAAs emitted an estimated total of 120 tons ofVOM in 2007.
While the data regarding total emissions ofYOM and emission reductions from theproposed regulation ofmiscellaneous industrial adhesives is uncertain, CAA Section 182(b)(2)(A) requires that SIPs be revised to include RACT for YOM sources covered by a CTG issued byUSEPA after November 15, 19903• TheUSEPA CTG regarding this categorywas intended to provide recommendations for RACT control ofthe various affected coatings. The Illinois EPA's proposedregulations for Group IV consumer and commercial products are consistent with the CTG's recommendations.
4.3 Technical Feasibility ofControls The Illinois EPA has relied upon the USEPA CfG regarding miscellaneous industrial adhesives to detennine the appropriate level ofcontrol and the feasibility ofthose measures. The two most common emission control techniques forreducing YOM emissions from miscellaneous industrial adhesives are pollution prevention and add-on control equipment. The pollution prevention measures involve the use oflower YOM adhesives, higher solids content adhesives, higher efficiency application methods, and work practices to reduce waste and minimize emissions during cleaning operations. Add-on controls for capture and control ofYOM emissions are systems similarto those used for a variety ofprocesses that generate YOM emissions, and 31involve capture and oxidation orrecovery. The recommendations for control ofVOM from this category in the CTG were based upon rules currently in effect in Califomia and the Ozone Transport Commission ("OTC"). The USEPA believes these measures to be RACT, and the Illinois EPA concurs. The CTG for miscellaneous industrial adhesives3contains a complete description ofUSEPA's detemlination ofRACT for this category.
In orderto provide sources some flexibility in compliance measures, the USEPA has recommended three control options forreduction ofYOM emissions from this category. The first option for control involves the use oflow YOM adhesives and adhesive primers. The second control option is the use ofa combination oflow YOM adhesives and primers and add-on controls to achieve emissions equivalent to the YOM content limits ofthe first option. In the third compliance option a source may employ add-on.controls to achieve a control efficiency of 85% as an alternative to the prescribed emission limits ofthe first control option. This 85% control efficiency criteria is expected to achieve emissionreductions ofVOM that are equal to or greaterthan the prescribed emission limits for the industrial adhesives. The Illinois EPA has included all three options in the proposed regulation.
The emission limits for various adhesives and primers recommended in the CTG and includedin the proposed regulation are given in grams ofYOM perliter ofadhesive. These limits are listed in Table 4.1.



### 32Table 4.1 YOM Emission Limits for General and Specialty Adhesive Application Processes Recommended VOM General Adhesive Application Processes Emission Limit (g/l) (Ib/gal) Reinforced Plastic Composite 

### 200 1.7 Flexible Vinyl 

### 250 

## I 2.1 Metal 

### 30 03 Porous Material (Except Wood) 

### 120 1.0 

## ! Rubber 

### 250 2.1

Wood 

### 30 0.3

- Other Substrates 

### 250 2.1 Specialty Adhesive Application Processes Ceramic Tile Installation 

### 130 1.1 , Contact Adhesive 

### 250 2.1 Cove Base Installation 

### 150 1.3 Floor Covering Installation (Indoor) 

### 150 1.3 Floor Covering Installation (Outdoor) 

### 250 2.1 Floor Covering Installation (Perimeter Bonded Sheet Vinyl) 

### 660 5.5 

## _.

Metal to Urethane/Rubber Molding or Casting 

### 850 7.1 Motor Vehicle Adhesive 

### 250 2.1 Motor Vehicle Weatherstrip Adhesive 

### 750 6.3 Multipurpose Construction 

### 200 1.7 Plastic Solvent Welding (ABS) 

### 400 3.3 Plastic Solvent Welding (Except ABS) 

### 500 4.2 Sheet Rubber Lining Installation 

### 850 7.1 Single-Ply Roof Membrane Installation/Repair (Except EPDM) 

### 250 2.1 Structural Glazing 

### 100 0.8 Thin Metal Laminating 

### 780 100 Tire Repair 

### 100 0.8 Waterproof Resorcinol Glue 

### 170 1.4 Adhesive Primer Application Processes 

# I Motor Vehicle Glass Bonding Primer 

### 900 7.5 Plastic Solvent Welding Adhesive Primer 

### 650 5.4 S;;:;-gle-Ply Roof Membrane Adhesive Primer 

### 250 

## I 2.1

Other Adhesive Primer 

### 250 2.1

33·4.4 Economic Reasonableness and CostEffectiveness ofControls The Illinois EPA has relied upon the cost analysis conducted by theUSEPA for the CTGs for miscellaneous industrial adhesives and determined that the proposedregulations are cost effective.
The USEPA used theNational Emissions lnventory database to estimate the number ofsources operating miscellaneous industrial adhesives application processes in non-attainment areas in the United States that meet the 15 lb perday YOM emission criteria contained in the CTGs. The USEPA estimated thatthere are 180 such sources in the United States, emitting an estimated 4,881 tons ofVOM per year. The USEPA relied upon cost estimates from California's Ventura County AirPollution Control District's 1993 study. This study estimated that the annualized cost for a source to convertto using low YOM adhesives was approximately $2300 per source. The USEPA then scaled that costestimate to 1997 dollars and estimated the cost ofcontrol to be $3,356 per source. This estimate was based upon the assumption that sources would use the YOM limits in the proposedregulation ratherthan the alternative add-on control option. This assumption was made because sources in currently regulated areas have already implementedthe use ofthese low YOM adhesives. and the reformulated products should be readily available today. Using these assumptions the USEPA estimated the cost effectiveness on aperton basis of $265 perton ofVOM reduced. The Illinois EPA estimates.that, with 12 ofthe 180 affected sources nationwide, the total cost statewide for the proposedregulation will be approximately' $40,272 annually. The Illinois EPA considers these figures for cost effectiveness and total statewide cost to be reasonable for control ofVOM.
A more detailed description ofthe USEPA's cost analyses can be found in the CTG for miscellaneous industrial adhesives3
4.5 Additional Recommendations: Work Practices In addition to the limits recommended in the USEPA CTG and included in the proposed regulation, the CTG also recommends workpractices for miscellaneous industrial adhesives. The work practices included in the CTG address adhesive related activities and cleaning activities, and are intended to furtherreduce YOM emissions fTom the source category. The 34CTG states that the emission reductions are unquantifiable, but states that the workpractices will result in a net cost savings to sources in this category.
The CTG recommends that workpractices for adhesive related activities include the following: (I) store all YOM-containing adhesives, adhesive primers, and process-related waste materials in closed containers; (2) ensure that mixing and storage containers used for YOM-containing adhesives, adhesive primers, and process-related waste materials are kept closed at all times, except when depositing orremoving these materials; (3) minimize spills ofVOM-containing adhesives, adhesive primers, and process-related waste materials; and (4) convey VOMcontaining adhesives, adhesive primers, and process-related waste materials from one location to anotherin closed containers Orpipes.
The CTG further recommends that work practices for cleaningmaterials should include the following: (1) store all YOM-containing cleaning materials and used shop towels in closed containers; (2) ensure that storage containers used for YOM-containing cleaning materials are kept closed at all times except when depositing orremoving these materials; (3) minimize spills ofVOM-containing cleaningmaterials; (4) convey YOM-containing cleaningmaterials from one location to anotherin closed containers orpipes; and (5) minimize YOM emission from cleaning ofapplication, storage, mixing, and conveying equipmentby ensuring that equipmentcleaningis
. performed without atomizing the cleaning solvent and all spent solvent is captured in closed containers.
Theproposed regulation includes the recommended work practices from the USEPA CTG in their entirety.
4.6 Potcntially Affected Sources in Illinois In determining the number ofsources potentially affected by the proposedregulation regarding miscellaneous industrial adhesives the illinois EPA relied upon information provided bythe USEPA. This source specific information was the data that the USEPA relied upon to estimate the number ofsources that would be impacted nationwide. The CTG formiscellaneous industrial adhesives states that] 80 sources nationwide in non-attainment areas would be affected 35by rules to implement the CTG. Ofthe 180 sources in the U.S., 17 sources were found to be in Illinois non-attainment areas. Ofthose 17 sources, 5 sources ceased operation and 12 sources were in operation in 2007. Table 4.2 lists these impacted sources and theirlocation.
Table 4.2 Potentially Affected Sources in Illinois

Source 10 Name City County 031471ABS DELTA-UNIBUS CORPORATION Northlake Cook 031015AAC BORG WARNER TRANSMISSION SYSTEMS Bellwood Cook 031081ACU TAPECOATCO INC Evanston Cook 031324ACZ TECHNICAL LAMINATIONS &COATINGS INC WheelinQ Cook Elk Grove 031440AFH UNIVERSAL CHEMICALS &COATINGS INC VillaQe Cook Elk Grove 031440AFY ACME FINISHING CO VillaQe Cook 031096ABM CLAD REX INC Franklin Park Cook Elk Grove 031440AKY D & K INTERNATIONAL INC VillaQe Cook 031600FXL , ARCHITECTURAL SPECIALTY PRODUCTS INC ChicaQO Cook 031600FPE RS OWENS AND CO Chicaao Cook 063060ACR RITCHIE BROS AUCTIONEERS (AMERICA) INC Morris Gnundv 007005AAB PACTIV CORPORATION Trenton S\. Claire



### 365.0 Fiberglass Boat Manufacturing Materials 5.1 Description ofSources and Emissions The eTG addressing fiberglass boat manufacturing materials applies to sources manufacturing fiberglass hulls or decks for boats, or sources tharconstnlct molds forthe manufacture of fiberglass boat hulls ordecks. The eTG does not apply to sources solely manufacturing boat parts, however ifa source manufactures fiberglass boathulls arid decks, the manufacture ofalf fiberglass boatparts at the source is covered by the eTG.
Emissions ofVOM from fiberglass boat manufacture occur from the use ofgel coats and resins applied to fiberglass in the manufacturing process, and from material used to clean application equipmentused in the process. For amore complete description ofmanufacturing processes for this subcategory the readeris directed to the USEPA eTG addressing fiberglass boat manufacturing materials'.
5.2 Recommended Control Techniques for Fiberglass BoatManufacturing Materials The USEPA in its CTG for fiberglass boat manufacturing materials has made recommendations for what it considers RAeT control for the subcategory. In orderto provide affected sources with a degree offlexibility in compliance measures the eTGprovides three options for control. Much like the proposedregulation for miscellaneous metal and plastic parts coatings, these options include use ofcompliant low YOM coatings, an emission averaging option, and an overall control efficiency option. The USEPA recommends that States include all three options in their determination ofRACT for the subcategory. Illinois EPA has included all three options in theproposed regulation.
It should be noted that for the fiberglass boat manufacturing.materials subcategory that the control measures are intendedto reduce emissions ofmonomer YOM. The CTG describes monomerYOM as such:


### A monomer is 

### a volatile organic compound thatpartially combines with itself, or other similar compounds, by a cross-linking reaction to become apart ofthe cured resin. Aji-action of each monomer compound evaporates during resin Clnd gel COCIt application and curing. Not all ofthe styrene and MMA evaporate, 

### 37because a majority ojthese compounds are bound in the cross-linking reaction betweenpolymer molecules in the hardenedresin orgel coat and becomepart oj thefinishedproduct. 4 Styrene and methyl methacrylate ("MMA") are the primarymonomerVOMs used in gel coats and resins for the manufacture offiberglass boats. Non-monomeryOM is generally less than 5% ofaresin or gel coat formulation. The proposedregulation does not limit non-monomer YOM directly, however, ifaproduct is found to contain greaterthan 5% non-monomer YOM, the percentage exceeding 5% will be added to the monomerYOM content ofaproduct for the purposes ofcompliance.
There are anumber ofmethods to reduce monomer YOM emissions from fiberglass boat manufacturing material. Many ofthese methods are similarto theemissionreduction measures for the othercategories in the proposed regulation such as lower monomer YOM materials, addon capture and control equipment, and recommended workpractices. Other control options are specific to this category and include the use ofvapor suppressed**re~ins** and gel coats, the use of non-atomizing resin application, and various closed moldingtechniques. These control methods are discussed atlength in the USEPA CTG for fiberglass boat manufacturing materials4

5.2.1 Use ofLow Monomer YOM Manufacturing Materials The USEPA CTGrecommends a compliance option for sources using low monomerYOM resins and gel coats. A source may meetthe requirements by'using low monomerYOM products that meetthe emission limits given for each material used in a given operation, orthe YOM content for all materials used in a covered operation can be averaged on aweight-adjusted basis4 Table 5.1 lists the monomer YOM content limits based upon the material type and the application method used.
The applicable recommended limits in Table 5.1 above would be consideredmet ifall materials ofa certain type meet the applicable monomer YOM content limit for a specific application method on aweighted-average basis. The weighted-average monomer YOM contentwould be determined based on a 12-month rolling average. 

### 38Table 5.1 Compliant Materials Monomer YOM Content Recommendations for Open Molding Resin and Gel Coat


## , Weighted Average Material Application Method MonomerVOM Content (weight percent) Production Resin Atomized (spray) 

### 28 : Production Resin Non-atomized 

### 35

Piqmenled Gel Coat Any method 

### 33 Clear Gel Coat Any method 

### 48 Toolino Resin Atomized 

### 30 Toolino Resin Non-atomized 

### 39 Toolinq Gel Coat Any method 

### 40

A sourcewould use Equation 1 to detennine weighted-averagemonomer YOM content for a particular open molding resin or gel coat material4 Equation 1:

.Where: 

### WeightedAverage Monomer VOM Content = 

### L:i;l(Mi

### VOMa Ii';l(Ma
Mi = Mass of open molding resin orgel coat, i. usedin thepast 12 month in an operation, in megagrams. VOM i =

n= Monomer VOMcontent, byweightpercent, of open molding resin orgel coat, i, used in thepast 12 months in an operation. Number of different open molding resins orgel coats used in thepast 12 months in an operation.
5.2.2 Emissions Averaging Option The second compliance option from the USEPA CTGinvolves averaging the monomer YOM emissions for all operations that a source chooses to include in an averaging group. Emission limits from other operations at a source couldbe met bythe compliance options detailed in Sections 5.2.1 or 5.2.3. The monomer YOM emission limit for operations for which a source chooses to use the averaging option is a source-specific monomer YOM limit determinedby
39Equation 2. The numerical coefficients on the light side ofEquation 2 are the allowable monomer YOM emission rates for each material in units ofkilograms permegagram.

Total allowable monomer VOMthat can be emittedJrom the open molding operations included in the average, kilogramsper J 2- monthperiod. Mass oj production resin usedin thepast 

### J 2 months, excluding any materials thatare exempt, megagrams. Mass oj pigmentedgel coat usedin thepast 

### J 2 months, excluding any materials thatare exempt, megagrams. Mass ojcleargel coat uSedin thepast 12 months, excluding any materials that are exempt, megagrams. Mass oJtooling resin used in thepast

### J 2 months, excluding any materials that are exempt, megagrams. Mass ojtoolinggel coat used in thepast J 2 months, excluding any materials thatare exempt, megagrams. Equation 

### 2: Monomer VOM Limit = 46(MR ) 

## + 159(M p

### c) 

## + 291(M c



### c) 

## + 54(MrR) 

## + 214(Mrc) Where: Monomer VOMContent

## =

Mco = Mpo =

Mro 

## = MTR 

## =

After a monomer YOM limit for a source's averaged operations has been determined using Equation 2, an emission average is determined on a 12 month rolling-average basis and calculated at the end ofeach month. At the end ofthe first 12month period, and at the end of each subsequentmonth, the monomer YOM emissions from the source's averaged operations are calculated, using Equation 3, to determine whetherthese emissions exceed the source's limit.



### 40Equation 

### 3: Monomer YOM Emissions 

## =(PVR)(MR ) 

## +(PVPG)(M pG)

## +(PVcG)(McG)

## + (PVTR)(MrR)

## +(PVrG)(Mrd
W1Jere: Monomer VOMemissions = Monomer VOMemissions calculatedusing the monomer VOM emission equationsfor each operation includedin the average, kilograms.

MpG= 

### PV CG =
MCG= 

### PVT7/ = 

### M

### m 

## = PVTG 

## =
MTG 

## = Weighted-average monomer VOMemission rateforproduction resin usedin the past 

### 12 months, kilogramsper megagram. Mass of production resin used in thepast 

### 12 months, megagrams. Weighted-average monomer VOMemission rateforpigmentedgel coat used in thepast 

### 12 months, kilogramspermegagram. Mass of pigmentedgel coatused in thepast 

### 12 months, megagrams. Weighted-average monomer VOMemission ratefor cleargel coat usedin the past 

### 12 months, kilogramspermegagram. Mass of cleargel coat usedin thepast 

### 12 months, megagrams. Weighted-average monomer VOMemission ratefor tooling resin usedin thepast 12 months. kilogramspermegagram. Mass of tooling resin usedin thepast 

### 12 months, megagrams. Weighted-average monomer VOMemission ratefor toolinggel coat usedin the past 

### 12 months, kilogramspermegagram. Mass of tooling gel coat usedin thepast 

### 12months, megagrams. Equation 4 is used to calculate**t~e** weighted average monomer YOM emission rate overthe previous 12 month period (PVop) for eaeh operationbeing averaged in Equation 3. Equation 4: l:f=,(MiPVi) l:f=,(Mi) W1Jere:

41PVop=

M

j =

n=
PV i = Weighted-average monomer YOM emission rateJor each open molding operation (PVR, PVPG, PVCG, PVTR, andPVTG) included in the average. kilograms oj monomer YOMpermegagram ojmaterial applied. Mass ojresin orgel coat, i, usedwithin an operation in thepast 

### 12 months, megagrams. Number ojdifferent open molding resins andgel coats used within an operation in thepast 

### 12months. The monomer YOMemission rateJor resin orgel coat, i, usedwithin an operation in thepast 

### 12 months, kilograms ojmonomer YOMpermegagram oj material applied. Use the equations in Table 4 to computePVi.
The monomer YOM emission rates for the specific materials and applicationmethods are given in Table 5.2.
Table 5.2 

### Monomer YOM Emission Rate Formulas for Open Molding Operations Material Application Method Formula to Calculate Monomer VOM Emission Rate Production Resin, Tooling Atomized 0.014 x (Resin 

### VOM%)".4"O Resin Atomized, plus vacuum 0.01185 x (Resin 

### VOM%)2.425 baaaina with roll-out Atomized, plus vacuum 0.00945 x (Resin 

### VOM%)2.425 baaaina without roll-out Nonatomized 0.014 x (Resin 

### VOM%)2.m Nonatomized, plus vacuum 0.0110 x (Resin 

### VOM%)2.275 baaaina with roll-aut Nonatomized, pius vacuum 0.0076 x (Resin 

### VOM%)2.275 baaaina without roll-out Pigmented Gel Coat, Clear All methods 0.445 x (Gel coat 

### VOM%)1.675 Gel Coat, Toolina Gel Coat
5.2.3 

### Add-on Controls In the case that perfonnance requirements or other aspects ofan operationrequire the use of materials that do not meet the monomer YOM emission limits, a source may opt to use add-on control equipmentto reduce YOM emissions to below the limit detennined by Equation 2. A


### 42source would be considered to be compliant ifmeasured emissions at the outlet ofa control device were less than the applicable emission limit for that operation. 5.3 Technical Feasibility ofControls The Illinois EPA concurs with USEPA's RAeT determination in the eTG addressing fiberglass boat manufacturing materials. Illinois EPA also concurs with the determination that the recommendations ofthe eTG are technicaJly feasible because these recommended control measures are merelybased on controls currentlyin place at affected sources due to the aforementioned 2001 NESHAP. It is also assumed that any source that intended to commence operation ofa source in this category in an Illinois non-attainment area would necessarily considertheproposed regulation in the planning ofsource operations, and that the proposed controls would be technically feasible for any new source.
5.4 Economic Reasonableness and CostEffectiveness ofControls Because there are currently no sources in Illinois that will be affected by the proposed regulation ofthis source category, there will be no associated economic impact for sources in Illinois. The eTG states thatthe USEPA expects sources in this category will incur little ifany increased costs due to the control recommendations. The Illinois EPA considers the controls to be technically feasible and concurs with the USEPA determination ofthe economic reasonableness ofthe measures.
5.5 Additional Recommendations: Work Practices In addition to the monomer YOM limits recommended in the USEPA eTG and includedin the proposed regulation, the eTa also recommends work practices for fiberglass boatmanufacturing materials. The workpractices included in the eTa address work practices forresin and gel coat mixing containers and for cleaning activities, and are intendedto further reduce YOM emissions from the source category. The eTa states that the emission reductions are unquantifiable, but are beneficial in reducing overall emissions at a source in this category.
Forresin and gel coat mixing containers, the eTG recommends that aJl containers with a capacity of55 gaJlons or greater should have a coverwith no visible gaps in place at aJl times.

43This does not apply to containers smaller than 55 gallons, or when material is being manually added orremoved from a container.
The USEPA CTG further recommends the use oflow-YOM and low vaporpressure cleaning materials. 

### It is recommended that YOM cleaning solvents should contain no more than 5% YOM by weight, orhave a composite vaporpressure ofno more than 0.50 mID Hg at 68 of.
The proposedregulation includes the recommended workpractices from the USEPA CTG in their entirety.



### 44References

I. Control Techniques Guidelines for Miscellaneous Metal and Plastic Parts Coatings, U.S. Environmental Protection Agency Office ofAir QualityPlanning and Standards Sector Policies and Programs Division Research Triangle Park, NC, Septcmber2008. 2. Control Teclmiques Guidelines for Automobile and Light-Duty TruckAssembly Coatings, U.S. Environmental Protection Agency Office ofAir Quality Planning and Standards SectorPolicies and Programs Division Research TrianglePark, NC, September 2008. 3. Control Techniques Guidelines for Miscellaneous Industrial Adhesives, U.S. Environmental Protection Agency Office ofAir QualityPlanning and Standards Sector Policies and Programs Division Research Triangle Park, NC, September2008. 4. Control Techniques Guidelines for Fiberglass Boat Manufacturing Materials, U.S. Environmental Protection Agency Office ofAir QualityPlanning and Standards Sector Policies and Programs Division Rescarch Trianglc Park, NC, September2008. 5. Consumer and Commercial Products. Group IV: Control Techniques Guidelines in Lieu ofRewlations for Miscellaneous Metal Products Coatings, Plastic Parts'Coatings, Auto and Light-Duty Truck Assembly Coatings, Fiberglass Boat Manufacturing Materials. and Miscellaneous Industrial Adhesives, 73 FR 58481-58491, October7,2008.
6. National Emission Standards for Hazardous AirPollutants: Surface Coating of Automobiles and Light-Duty Trucks; National Emission Standards for Hazardous Air Pollutants for Surface Coating ofPlastic Parts and Products, 72 FR 20227-20237, April 24,2007.

45

# C 2O()VERN9R. 

### March 18,2010 

# ILLINOIS POLLUTION CONTROL BOARD



# I • 

# I O'UR.'>IA,'

G. TonnerGiJarrl; Ph.D, 

### Warren Ribley, Director DepartmentofCommerce and Economic Opportunity 620 EastAdams Street, S·6 Springfield, llIinois 62704 

### RECEIVED**CLER~S** OFFICE 

## MAR 182010 STATE OF ILUNOIS Pollution Controt Board

Re: Request for Economic Impact Study for: Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions from Group IV Consumer & 

### Commercial Products: Proposed Amendments to 35 III. Adm
.

.Code 211. 218, and 219 (RI0-20) ":r '\ 

### DearDirectorRibley:**',':~** 

# ."

,**'.~'** '." ",/ ,•. ..**~'\** ,:{:!<:;'**I:1J''IltNGI'IIlLll;()Fi'll:'~:;i** 

### On March 18,2010, the Board accepted forhearing aproposal entitled

, ReasonablyAvailable Control Technology (RACT) forVolatile Organic Material Emissions from Group IV Consumer & 

### Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 211, 218. and 219 (BoardDocketRl0-20). Generally, the Illinois Environmental Protection Agency proposes that the Board adopt airpollutionregulations to control emissions ofvolatile organic material from Group IV Consumer & 

### Commercial Products in ozone nonattainment areas classified as moderate and above. Group IV includes the following productcategories:
. miscellaneous metal and plasticparts coatings; automobile and light-duty truck assembly coatings; miscellaneous industrial adhesives; and fiberglass boat manufacturingmaterials. Iwrite to request thatyourDepartment conduct an economic impact study concerning this proposal. -'.' ....

. 02}"**North-GrandA''t''Ei~'f~** 1\0. Box' 19214 ," Springfield, II

62794A?:/4 217-5244>511<. fAX**217-524-~~08** 

### This rulemaking was filed with the Boardon March 8, 2010, underthe "fasttrack" rulemaking authority at Section 28.5 ofth'e Act, which the General Assembly 

## 'c"'" recentlyre-enacted in Public Act 96-0308, effective August 11,2009. Section 28.5 '. requires the Boardto proceedtoward adoption ofthe proposed regulations by 'CHICA,ol:IOl'tq:;E'\ 

### meeting a series ofstrict deadlines. Specifically, the Board musthold at leasttwo, and possibly three, hearings on the proposal. Additionally, the Board must submit theproposed amendments to the Joint Committee on Administrative Rules on or before either July 16,2010, orAugust 5, 2010 (130 or 150 days afterthe proposal's filing), depending on whetherthe Boardholds two orthree hearings. The Board has scheduledhearings in this rulemakingto begin on April 28,2010; May 19, 2010; and June 2, 2010. The Board respectfullyrequests that yourDepartment expedite its determination whetherit will conduct an economic impact studyon the proposal and respond no laterthan Thursday, April I, 2010. ..**ri~** 

### It**Tho.p~ Gc.~r**  

### .**.1(Xl~Ww .~';"1i~bj'ph/**  SUItt 

### n.500 H Clli""W IL 6060I

.**312.814,3~10.** .

FAX**311'8J4".U6~** ,c 

### 'fY'Y.'1 (1-$If'603J ;', :J\."<:" "- - '._.

«"'t"

WEBSn;E WWW.i.i.Jcb=-:il3..·4.il.-us.".",i",**t"."~** Since 1998, Section 27(b) ofthe Environmental Protection Act has required the Board to:



### , . 1) request thatthe Department ofCommerce and Economic Opportunity (formerly the DepartmentofCommerce and Community Affairs) conduct a study ofthe economic impact ofthe proposedrules. The Departmentmay within 30 to 45 days ofsuchrequestproduce a study ofthe economic impact ofthe proposed rules. At aminimum, the economic impact study shall address a) economic, environmental, and public healthbenefits that maybe achieved through compliance with the proposed rules, b) the effects ofthe proposedrules on employmentlevels, commercialproductivity, the economic growth ofsmall businesses with 100 orless employees, and the State's overall economy, and c) the costperunit ofpollutionreduced and the variability ofcompanyrevenues expectedto be used to implement the proposedrules; and (2) conduct at least onepublic hearing on the economic impact ofthose rules. At least 20 days before thehearing, the Board shall notify the public of the hearing and make the economic impact study, orthe Department of Commerce and Economic Opportunity's explanation for not producing an economic impact study, available to thepublic. Suchpublic hearing maybe held simultaneously or as apart ofanyBoardhearingconsidering such new rules. 415 ILCS 5/27(b) (2008). The Boardintends to proceed promptlywith this rulemaking as required by Section 28.5 oftheAct, and asks thatyou determine whetherDCEO will conduct an economic impact studyon theproposal and respond no laterthan Thursday, April 1, 2010. 

### If!, ormy staff, canprovide you with any additional information, please let me know. Thank you in advance for yourpromptresponse. Sincerely,

G. Tanner Girard Acting Chairman Pollution Control Board
cc: John T. Therriault, Assistant Clerk ofthe Board

# C 3ILLINOIS POLLUTION CONTROL BOARD March 18,2010 IN THE MATTER OF: ) ) REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERIAL EMISSIONS FROM) GROUP IV CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE 211,218, AND 219 ) RI0-20 (Rulemaking

- Air)

### ~re1!CEIVE~ CLERK'S 

### OFFICE



## MAR 182010 STATE OF 

### IlliNOIS ;:lollution 

### Control Board



### NOTICE OF HEARINGS DATES, TIMES, AND LOCATIONS: FIRST HEARING: WEDNESDAY, APRIL 28, 2010, TO BE CONTINUED DAY-TO-DAY UNTIL BUSINESS IS COMPLETE 9:00AM Illinois Pollution Control Board Conference Room, First Floor 1021 N. Grand Ave. East (North Entrance) Springfield, Illinois SECOND HEARING (IF NECESSARY): WEDNESDAY, MAY 19,2010, TO BE CONTINUED DAY-TO-DAY UNTIL BUSINESS IS COMPLETE 10:00 AM Pollution Control Board Conference Room 11-512 James R. Thompson Center 100 W. Randolph St. Chicago, Illinois THIRD HEARING (IF NECESSARY): WEDNESDAY, JUNE 2,2010, TO BE CONTINUED DAY-TO-DAY UNTIL BUSINESS IS COMPLETE



### I ! 10:00 AM Pollution Control Board Conference Room 11-512 James R. Thompson Center 100 W. Randolph St. Chicago, IllinoisPURPOSE OF HEARINGS: ATTENDING BOARD MEMBER: HEARING OFFICER: 2

Merit and Economic Andrea S. Moore Timothy

### J. Fox 

### HEARING OFFICER ORDER Statutory Requirements On March 8, 2010, the Illinois Environmental Protection Agency (Agency) filed this rulemaking proposal pursuant toauthorities including the recently re-enacted Section 28.5 ofthe Environmental Protection Act (Act). See Public Act 96-0308, elf. Aug. 11,2009 (PA 96-0308) (reenacting repealed Section 28.5). Section 28.5 requires the Board to proceed to adoption ofthe proposed regulations by meeting a series ofstrictdeadlines. The Board has applied those deadlines to this proceeding in its opinion and order ofMarch 18, 2010, and in this notice of hearing and hearing officerorder. Section 28.5 specifies the timing and purpose ofeach ofthree hearings and establishes other procedural requirements. Section 28.5(1)(1) provides that "[t]he firsthearing shall beheld within 55 days ofreceipt ofthe rule and shall be confined to testimony by and questions ofthe Agency's witnesses concerning the scope, applicability, and basis ofthe rule. Within 7 days after the first hearing, any person may requestthat the secondhearing beheld." P.A. 96-0308. Section 28.5(1)(2) provides that, ifitis necessary, "[t]he second hearing shall be scheduled to commence within 30 days ofthe first day ofthe first hearing and shall be devoted to presentation oftcstimony, documents, and comments by affected entities and all other interested parties." P.A. 96-0308. Section 28.5(1)(3) provides that, ifit is necessary, [t]he third hearing shall be scheduled to commence within 14 days after the first day ofthe second hearing and shall be devoted solely to any Agency responseto the material submitted at the secondhearing and to any response by otherparties. The third hearing shall be cancelled ifthe Agency indicates to the Board that it does not intend to introduce any additional material. 

### Id. Section 28.5(1) provides that "[t]he Board must require the written submission ofall testimony at least 10 days before a hearing, with simultaneous service to all pmticipants of record in the proceeding as of 15 days priorto hearing, unless a waiver is granted by the Board for good cause." P.A. 96-0308. Section 28.5(k) provides that, "[f]ollowing the hearings, the Board must close the record 14 days aftcrthe availability ofthe transcript." P.A.96-0308. Section 28.5(n) provides that3
[t]he Board must complete afast-track rulemaking by adopting a second notice orderno laterthan 130 days after receipt ofthe proposal ifno third hearing is held and no laterthan 150 days ifthe third hearing is held. Ifthe orderincludes arule, the JIlinois [Pollution Control] Board mustfile the rule for second notice under the JIlinois Administrative Procedure Act within 5 days after adoption ofthe order. P.A 96-0308; see 5 JLCS 100/5-40 (2008). Also, Section 28.5(0) provides that, "[u]pon receipt ofa statement ofno objection to the rule from the Joint Committee on Administrative Rules, the Board must adopt the final order and submitthe rule to the Secretary ofStatefor publication and certification within 21 days." P.A. 96-0308. The Board has no discretion to adjust the strict deadlines established in Section 28.5 of the Act. See P.A. 96-0308. Therefore, the first hearing will begin as indicated above on Wednesday, April 28, 2010, and is not subject to continuation orcancellation by the Board. The second and third hearings, ifnecessary, will begin on the dates listed above in the notice of hearings. Service and Notice Lists The Board will establish anotice list and a service listfor this proceeding. All persons on the notice listwill receive notice ofBoard opinions and orders and hearing officerorders. 35 

### Jll. Adm. Code 102.422(a). Under Section 102.422(b) ofthe Board's procedural rules, [t]he hearing officermay establish a service list for any regulatory proceeding, in addition to the notice list. Thehearing officermay directparticipants to serve copies ofall documents upon the persons listed on the service list.
... For purposes offast-track rulemakings llIlder Section 28.5 ofthe Act, participants of record will be the individuals on the service list. 35 HI. Adm. Code 102.422(b). 

### In addition to receiving notice ofall Board actions and hearing officer orders, persons on the service listwill receivepre-filed testimony and other filings in this proceeding. The service list is intendedfor persons such as those who will testify and participate actively in this rulemaking. The Board notes thatthe Agency's proposal included aTechnical SupportDocument (TSD), which lists potentially affected sources. TSD at 20-23 (Table 2.3),29 (§ 3.6), 36 (Table 4.2),43 

### (§ 5.4). The Board begins this rulemaking proceeding by including in the Notice List each ofthe potentially affected sources listed by the Agency in its TSD. Whilethe Boardwill mail a copy ofthe BOard's March 18,2010, order and this hearing officerorderto each ofthose potentially affected sources, the Board will provide copies ofany subsequent opinions and orders only to those who specifically indicate to the Board that they wish to remain on eitherthe Service Listor Notice Listfor this proceeding. The Board requests that any entity wishing to4

remain on the Service List or Notice List provide the information requested in the form attached to this order as Attachment A to the Board by Friday, April 2, 2010. In order to clarify the record in this proceeding, Attachment B to this order contains the names, mailing addresses, and contactnames for each ofthe potentially affected entities listed by the Agency in its TSD and to each ofwhich the Boardhas mailed its March 18, 2010, opinion and order and this hearing officerorder. Note that, through the Clerk's Office On-Line (COOL) on the Board's Web site (www.ipcb.state.il.us).personseanrequesttoreceiveelectronicnotification.This "e-
. notification" generates an e-mail message when the Board receives and dockets a filing in this proceeding. These newly-filed documents will then be available to view, download, and print free ofcharge from COOL. Also through COOL, pre-filed testimony, public comments, and otherfilings are available generallyfor viewing and downloading. One exception to this availability may be voluminous filings, which will nonetheless he made available upon request to the Clerk's office. With the access to filings provided by COOL, persons who are not on the servicelist and wish to file only apublic comment need not servetheir comments on the service list in this proceeding. Pre-Filing Testimony As noted above under "Statutory Requirements," Section 28.5(f) provides strict deadlines forpre-filing testimony. In a "fast-track" rulemaking, "[t]he Board must requirethe written submission ofall testimony at least 10 days before ahearing, with simultaneous service to all participants ofrecord in the proeeeding as of 15 days priorto hearing, unless awaiver is granted by the Boardfor good cause." P.A. 96-0308. Service Lists Forpurposes ofserving pre-filed testimony, the service listfor the first hearing will close onTuesday, April 13,2010; the service listfor the second hearing will close on Tuesday, May 4, 2010; and the service list for the third hearing will close on Tuesday, May 18,2010. Any person who submits a fax or e-mail request to be added to the service listto thehearing officerby4:30 PM on or before those three deadlines will be added to the service listfor the remainder ofthis proceeding. The service list for any ofthe threehearings will be available after 9:30 AM onthe day following each ofthe three deadlines. FirstHearing Forthe first hearing, pre-filed testimony mustbe served on all persons on the servicelist as of4:30 PM on Tuesday, April 13, 2010. Persons wishing to pre-file testimony for the first hearing may obtain a copy ofthe service listby contacting the hearing officer after 9:30 AM on Wednesday, April 14, 2010. All pre-filed testimony for the first hearing mustbe submitted to the Board no laterthan Friday, April 16,2010. 

### See P.A. 96-0308 (requiring pre-filing at least 10 days before hearing). For the purpose ofserving pre-filed testimony for the first hearing onthe

### 5
Board, the "mailbox rule" at 35 Ill. Adm. Code 101.300(e) does not apply. The Board's Clerk mustreceive this pre-filed testimony before the close ofbusiness on Friday, April 16,2010. Although pre-filed testimony may be filed electronically through COOL, all electronic or approved fax filings mustbe received by the Clerk's Office no laterthan 4:30 PM on that date. Second Hearing Forthe second hearing, pre-filed testimony must be served on all persons on the service list as of4:30 PM on Tuesday, May 4, 2010. Persons wishing to pre-file testimony for the secondhearing may obtain a copy ofthe service list by contacting the hearing officer after 9:30 AM on Wednesday, May 5,2010. All pre-filed testimony for the secondhearing mustbe submitted no laterthan Friday, May 7, 2010. See P.A. 96-0308 (requiring pre-filing at least 10 days before hearing). Forthe purpose ofserving pre-filed testimony for the secondhearing on the Board, the "mailboxrule" at 35 Ill. Adm. Code 101.300(c) does not apply. The Board's Clerk mustreceive this pre-filed testimony before the close ofbusiness on Friday, May 7,2010. Although pre-filed testimony may be filed electronically through COOL, all electronic or approved fax filings must be received by the Clerk's Office no laterthan 4:30 PM on that date. Third Hearing Forthe third hearing, pre-filed testimony mustbe served on all persons on the service list. as of4:30 PM on Tuesday, May 18, 2010. Persons wishing to pre-file testimony for the third bearing may obtain a copy ofthe service list by contacting thehearing officer after 9:30 AM on Wednesday, May 19,2010. All pre-filed testimony for the third hearing must be submitted no laterthan Friday, May 21, 2010. See P.A. 96-0308 (requiring pre-filing at least 10days before hearing). Forthe purpose ofserving pre-filed testimonyfor the third hearing on the Board, the "mailbox rule" at 35 

### Ill. Adm. Code 101 JOO(c) does not apply. The Board's Clerkmust receive this pre-filedbefore the close ofbusiness on Friday, May 21, 2010. Although pre-filed testimony may be filed electronically through COOL, all electronic or approved fax filings must be received by the Clerk's Office no laterthan 4:30 PM on that date. 

### IT IS SO ORDERED.

# ~~ Timothy J. Fox Hearing Officer Illinois Pollution Control Board 100West Randolph Street, Suite 11-500 Chicago, Illinois 60601 (312) 814-6085 (312) 814-3669 (fax) foxt@ipcb.state.il.us

### 6

ATTACHMENT A To Hearing Officer Order ofMarch 18,2010 Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions from Group 

## rv Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 211, 218. and 2 I9 (R 10-20) 1wish to added to the (please check one) Service List Notice List in the Illinois Pollution Control Board rulemaking proceeding identified above:
Name Organization or Company
Address City, State, Zip PLEASE SUPPLY THJS INFORMATION BY FRIDAY, APRIL 2,2010, TO: Lynn Patras, Illinois Pollution Control Board E-mail: patrasl@ipcb.state.il.us Fax: 312-814-3669 Mail: 100W. Randolph St., Suite 11-500 James R. Thompson Center Chicago, lllinois 60601

### 7

ATTACHMENT B To Hearing Officer Order ofMarch 18, 2010 In the Matter of: Reasonably Available Control Technology CRACT) for Volatile Organic Material Emissions from Group IV Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 211, 218, and 219 (RI0-20) Potentially Affected Sources in IL NAAs: Miscellaneous Metal and Plastic Parts Coatings Company Name Street Address City State Zip Co. Contact Code S & B Finishing 3005W Chicago IL 60612 Kenneth S Co Inc Franklin Blvd Spielman RS Owens and Co 5521 N Lynch Chicago IL 60630 Ed Murawski Ave Sorini Ring 2524 S Blue Chicago IL 60608 Peter May Sr Manufacturing Co Island Ave Inc Action Athletic 3144 21st St Zion IL 60099 Joseph R Equipment Inc Higgins QC Finishers 10244 Franklin Franklin IL 60131 Paul Gratzke Ave Park Cleveland Steel 117 E Lincoln Peotone IL 60468 Bob Harding ContainerCorp VaporBus 1010 Johnson Buffalo IL 60089 Lynn International Dr Grove Mazurowski Nissan Forklift 240 N Prospect Marengo IL 60152 Tom Carlson CorpNA St National Controls 1725 Western West IL 60185 Jim Carter Corp Dr Chicago VaporPower 551 S County Bensenville IL 60131 Rob Pawlak Line Rd Chicago American 4500 W 47th St Chicago IL 60632 William MfgLLC Mundcll EO Schweitzer 1520 Mundelein IL 60060 James Loris Mfg Co Inc McCormick Ave Aleo Spring 2300 Euclid Chicago IL 60411- Gordon Industries Ave Heights 0188 Sharkey BrunnerAnd Lay 9300 King St Franklin IL 60131 David Inc Park Bullifent MidwestMetal 9 Konzen Ct Granite City IL 62040 MikeDake Coatings LLC ElectroMotive 9301 W 55th St McCook IL 60525- Jack Kaps8

Diesel Inc 3214 Empire Comfort 918 Freeburg Belleville IL 62222 Shane Hill Systems Ave Yale Polishing & 5247 S Keeler Chicago IL 60632 Margaret Plating Ave Fanning Atlas Tube Inc 1855 E 122nd St Chicago lL 60633 Allan Lambert Rexnord 2400 Curtiss St Downers IL 60515- Roman Industries Inc Grove 4056 Shcgelman Bearing Div ElM Coating 129 Eisenhower Lombard IL 60148 Greg Flora Services LnS Federal Signal 2645 Federal University 

### IL 60466- Thomas L Corp Signal Signal Dr Park 3195 Longtin Division Reum Corp 3600 Sunset Waukegan IL 60087 Debbie Ave O'Conell Signode Corp 7701 W 71st St Bridgeview 

### IL 60455 MarkE Hollo Amcrican Flange 290 E Fullerton Carol Stream IL 60188- Mark & Manufacturing Ave 1826 Comella Co Inc HA Framburg and 941 Cernan Dr Bellwood IL 60104- JeffSokol Co 2254 Icon Identity 2480 Greenleaf Elk Grove IL 60007 Shawn Solutions Ave Village Hyken Hendrickson 501 Caton Farm Crest Hill IL 60435 Nadya Bumper & Trim Rd FIgueroa Ace Plating Co 3433 W 48th PI Chicago IL 60632 Michael Holewinski BLDowneyCo 2125 Gardner Broadview IL 60153 Anna LLC Rd Skuratovsky Replogle Globes 2801 S 25th Broadview IL 60155 Edward Inc Ave Dieschbourg Britt Industries 3010 Malmo Dr Arlington IL 60005 Bill Schroll Heights Shelco Steel 15801 Van South 

### IL 60473 B. Zeller Works Inc Drunen Rd Holland Elkay Mfg 2700 S 17th Broadview IL 60155- RDvorak Ave 4722 TC Industries Inc 3703 S Route 31 Crystal Lake IL 60012- Gerardo 1412 Sarinana Rayvac Plastic 47 W 171 Rte Big Rock IL 60511 Robert D Decorators Inc 30 Raymond

### 9
Chicago Blower 1675 Glen Ellyn Glendale IL 60139- Diane Cronin Corp Rd Heights 2503 Russell T Bundy 800 Moen Ave Rockdale IL 60436 Scott Mouton Associates Inc dba Unit 3 Pan Glo Chicago S & C Electric Co 6601 N Ridge Chicago 

### IL 60626- Robert Blvd 3904 Sullivan NylokFastener 6465 Prosel Ave Lincolnwood IL 60712 PeterHenley Corp Navistar Inc 10400 W North Melrose 

### IL 60160 Adriana Ave Park Tremarin Chern-Plate 1250 Morse Ave Elk Grove 

### IL 60007 Jim See Industries Village USPS Chicago 740 S Canal St Chicago IL 60607- Curtis A Central VMF 9361 Anderson Weber-Stephen 200 E Daniels Palatine 

### IL 60067- Chris Inc Rd 6237 Childers BaslerElectric Co 12570Rte 143 Highland IL 62249- Jason T 0269 Snow Norwood Marking 250 Industry Frankfort IL 60423 Jack Systems Ave Schreiber Wagner Zip 3100 Hirsch Melrose IL 60160 Paul Change Park Mauersberger Equipto 435 Woodlawn Aurora 

### IL 60507 Steve Golz Electronics Corp Ave Crown Gym Mat 27W929 Barrington 

### IL 60010 Judy Eckert Inc Industrial Ave Morse 850W Chicago 

### IL 60609 Brian Kirts Automotive Corp Exchange ITT Corp 8200 N Austin Morton IL 60053 JeffMann Residential & Ave Grove Commercial WaterDiv AccoUSA Inc 770 S WolfRd Wheeling 

### IL 60090 Matthew Kaiser R &B Powder 4000 S Bell Chicago 

### IL 60609 Tony Cash Coating Arlington Plating 600 S Vermont Palatine IL 60078 Richard Co St Macary GreifIndustrial 4300 W BOth Alsip IL 60803 Nick Sheets Packaging & St Services LLC Abbey Finishing 1108 S Kilbourn Chicago IL 60624- Michael Corp Ave 3821 Carroll Nina Enterprises 1350 S Leavitt Chicago IL 60608 K S Desai

### 10

Inc St Gooder- 2900 State St Chicago 

### IL 60411 Paul henrichsen Co Inc Heights O'Connor ITW Buildex 1349 W Bryn Itasca 

### IL 60143 Steven Bel1 Mawr Ave Metro East 3200 Missouri Alorton 

### IL 62205 GayleL Industries Inc Ave Ortyl Eaglebrook 2600W Chicago IL 60608 John Kemper Plastics Inc Roosevelt Rd Meyer Steel Drum 2000 S Kilbourn Chicago 

### IL 60623 Brian Meyer Inc Ave Amsted Rail Co 1700 Walnut St Granite City 

### IL 62040- JeffKel1y Inc 3100 Wheatland Tube 4435 S Western Chicago 

### IL 60609 Ron Aranda Co: Chicago Blvd Division Caterpillar Inc 2200 Joliet IL 60436 Bruce H Channahon Rd Gilruth Acme Finishing 1595 E Oakton Elk Grove 

### IL 60007 Dennis W Co St Village Walters Plastic Decorators 1330 Holmes Elgin 

### IL 60123 Cathy Burger Inc Rd Illinois Central 17550 S Homewood 

### IL 60430 Michael Railroad Ashland Ave Avans Olin Corp 427N East Alton IL 62024- Michael ShamrockSt 1197 Redington American Louver 7700 N Austin Skokie 

### IL 60076 Carol Salas Co Ave Meyer Steel Drum 3201 S Mil1ard Chicago IL 60623 Edward Inc MeyerSr Lakewood 501 N Chicago 

### IL 60612 Dan Gabor Engineering & Sacramento MfgCo Blvd Jessup 1701 Rockland Lake Bluff 

### IL 60010- Dave Reese Manufacturing Co Rd 1450 MeyerIndustrial 610 W 81st St Chicago 

### IL 60620- Edward Container 2511 MeyerSr American Stair 642 Forestwood Romeoville IL 60446 Max Easton Corp Dr AstroblastInc 1141 EGreen St Bensenvil1e 

### IL 60106 Robert A Gill Cooper B-Line Inc 509 W Monroe Highland 

### IL 62249- Chris St 0326 Dietrich CaterpillarInc Route 31 Aurora IL 60507 Ann Hastert Chicago Heights 211 E Main Chicago 

### IL 60412 Rich Gollner Steel Heights11

UGN Inc 1001 State St Chicago IL 60411 Ken DeRolf Heights Illinois Tool 1201 StCharles Elgin IL 60120 Chuck Works Rd Fairbanks Machinery 1833 Downs Dr West IL 60185- Prashant Components Inc Chicago 1805 Kumar Union Pacific 423N Chicago IL 60635 Greg Gehrig Railroad Co Sacramento· Coatings 2671 United Ln Elk Grove IL 60007 Don Applications Inc Village Clemente Temperbent Glass 12400 S Alsip IL 60803 William LP Laramie Ave Wilczynski Clad Rex Inc 11500 King St Franklin IL 60131- Michael G Park 1310 Harker General Electric 6045 S Chicago IL 60638 Dan Frey International Inc Nottingham Ave Action Rack & 4810W Chicago IL 60639 John MfgCo Wrightwood Hamilton InglotElectronics 4878N Elston Chicago IL 60630 Andrew Corp Ave Platowski Northrop 1601-1605 Rolling IL 60008 William Grumman Rohlwing Rd Meadows Cameron Systems Corp Dehler 5801 W Dickens Chicago IL 60639 Barry Manufacturing Co Ave Pinchcofsky Inc Eagle Electronics 1735 Mitchell Schaumburg IL 60193 Mike Kalaria Inc Blvd Advanced 721**Win~ton** Dr West IL 60185 Nipul Patel Electronics Inc Chicago Borg-Warner 700 S 25th Ave Bellwood IL 60104 Jennifer Transmission Berbour Systems Peerless Industries 3215WNorth Melrose lL 60160 Amir Ave Park Yaghoobi CalumetArmature 1050 W 134th Riverdale IL 60627- Joseph & Electric LLC St 1003 Delaurentis Highland Machine 700 Fifth St Highland IL 62249 Kevin and Screw Product Hemann Co Chern-Plate 1990E Devon Elk Grove IL 60007 Jim See lndustries Inc Ave Village John Sterling Corp 11600 Sterling Richmond IL 60071 JohnR Pkwy Sterling Kinney Electrical 678 Buckeye St Elgin IL 60123 Lowell D12
MfgCo Naber Elgin SweeperCo 1300 W Bartlett Elgin IL 60121 David Strebel Rd Fluid Air Inc 2550 White Oak Aurora IL 60502- 

### K.c. Tilton Circle 9678 Krel Laboratories 388 and 383 and Chicago IL 60624 Robert Inc 382 N Avers Oleksyn Ave Hubbell

- 501 W Apple St Freeburg IL 62243 Ron Heflen Wiegmann Met-Coil Systems 711 Ogden Ave Lisle IL 60532 Gordon LLC Manning Watco Mechanical 435 Old St Wood River IL 62095 Steve Services Louis Rd Prokopich G & W Electric 3500W 127th Blue Island IL 60406 Pete Gerike Co St Bee-jay Industries 4650 N Ronald Harwood IL 60656 Ken Inc Ave Heights Fefferman Magnetrol 5300 Belmont Downers IL 60515 James Jani International Inc Rd Grove Commercial 540 Lively Blvd Elk Grove IL 60007 Samuel J Finishes Co Ltd Village Legittino Duraco Products 1109 E Lake St Streamwood IL 60107 Donald G Inc Grimaldi Potentially Affected Sources in IL NAAs: Miscellaneous Industrial Adhesives Company Name StreetAddress City State Zip Co. Code Contact Delta-Unibus Corp 515 North Northlake IL 60164- Perry A Railroad 1652 Weyant Borg-Warner 700 S 25th Ave Bellwood IL 60104 Jennifer Transmission Berbour Systems Tapecoat Co Inc 1520 Lyons St Evanston IL 60201 Donald Kathrein Technical 420 Northgate Wheeling IL 60090 Roger Laminations & Pkwy Haase Coatings Inc Universal Chemicals 1124 Elmhurst Elk Grove IL 60007 Bette & Coatings Inc Rd Village Dierwechter Acme Finishing Co 1595 E Oakton Elk Grove IL 60007 Dennis W St Village Walters Clad Rex Inc 11500 King St Franklin IL 60131- Michael G Park 1310 Harker13

D & K International 525 Crossen Elk Grove IL 60007 James Broz Inc Village Architectural 6312 W 74th St Chicago IL 60638 LorenD Specialty Products Jahn Inc RS Owens and Co 5521 N Lynch Chicago IL 60630 Ed Ave Murawski Richie Bros 2400 Ritchie Rd Morris 

### IL 60450 Lily Cheng Auctioneers (America) Inc Hexacomb Corp 11620 Old Hwy Trenton IL 62293 Jim Siegel 50W Potentially Affected Sources in IL NAAs: Automobile and Light-Duty Truck Coatings Company Name Street Address City State Zip Code Ford Motor Co. 12600 S. Torrence Chicago IL 60633 Ave.

# C 4ILLINOIS POLLUTION CONTROL BOARD March 18,2010 IN THE MATTER OF: ) 

## 1 REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERIAL EMISSIONS FROM) GROUP IV CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE 211, 218, AND 219 ) Proposed Rule. FirstNotice. RIO-20 (Rulemaking

- Air)

OPINION AND ORDER OF THE BOARD (byA.S. Moore): On March 8, 2010, the Illinois Environmental Protection Agency (Agency or Illinois EPA) filed a rulemaking proposal pursuantto Sections 10,27,28, and 28.5 ofthe Environmental Protection Act (Act). See 415 ILCS 5/1 0, 27,28 (2008); Public Act 96-0308, eff. Aug. II, 2009 (P.A. 96-0308) (reenacting repealed Section 28.5). Among other documents, a Statement of Reasons (SR) and a motion for waiver ofcopy requirements (Mot.) accompanied the proposal. The Agency states that its proposal seeks to meet Illinois' obligations under the Clean Air Act (CAA). SR at I, citing 42 U.S.c. § 7401 etseq. Specifically, the Agency indicates that "the rulemaking is intended to satisfy Illinois' obligation to submit a State Implementation Plan ("SIP") to address requirements under Sections 172 and 182 ofthe CAA for sources ofVOM [volatile organic material] emissions in areas designated as nonattainment with.respect to the ozone National Ambient Air Quality Standard ("NAAQS")." SR at I, citing 42 U.S.c. §§ 7502, 7511 a. The Agencyreports that, for ozone nonattainment areas, "the State mustrevise its SIP to include RACT [reasonably available control technology] for sources ofYOM emissions covered by a control techniques guideline ("CTG") issued between November 15, 1990, and the date of attainment." SR at 2, citing 42 U.S.C. § 7511a(b)(2). Specifically, the Agencyproposes YOM emission controls in response to CTGs issued on October7,2008, for the following Group IV Consumer and Commercial Product Categories: misc·ellaneous metal and plastic parts coatings; auto and light-duty truck coatings; miscellaneous industrial adhesives; and fiberglass boat manufacturing materials. SR at 1,4. The Agency filed the proposal pursuantto the "fast-track" rulemaking provisions of Section 28.5 ofthe Act, and the Board accepts the proposal for hearing. Section 28.5 requires the Board to proceed toward adoption ofthe proposed regulations by meeting a series ofstrict deadlines. The Actprovides the Board no discretion to extend those deadlines. Seegenerally P.A. 96-0308. The first ofthose deadlines provides that the Board within 14 days ofreceiving the proposal must file the proposed rule for first notice under the Illinois Administrative Procedure Act (5 ILCS 100/1-1 etseq. (2008)). P.A. 96-0308 (subsection (e)). Section 28.5(1) provides2

that "[t]he Board must notrevise or otherwise change an Agency fast-track rulemaking proposal without agreement ofthe Agency until after the end ofthe hearing and commentperiod. Any revisions to the Agency proposal shall be based on the record ofthe proceeding" Jd. (subsection (I)). Thereforc, the Board today accepts the Agency's proposal without commenting on its substantive merits and directs the Clerk to cause publication ofthe proposed rule for first notice in thefIIinois Register. In the same 14-day period, the Board must also schedule and provide notice ofthree hearings, "each ofwhich shall be scheduled to continue from day to day, excluding weekends and State and federal holidays, until completed." P.A. 96-0308 (subsections (e), (f)). Within 55 days ofreceiving the proposed rule, the Board must hold a first hearing "confined to testimony by and questions ofthe Agency's witnesses concerning the scope, applicability, and basis ofthe rule." P.A. 96-0308 (subsection (f)(I)). Thcn, "[w]ithin 7 days after the firsthearing, anyperson may request that the second hearing be held." Jd. A second hearing "shall be scheduled to commence within 30 days ofthe first day ofthe first hearing and shall be devoted to presentation oftestimony, documents, and comments by affected entities and all other interested parties" P.A. 96-0308 (subsection (f)(2)). A third hearing "shall be scheduled to commence within 14 days after the first day ofthe second hearing and shall be devoted solely to any Agency response to the material submitted at the second hearing and to any response by otherparties." P.A. 96-0308 (subsection (f)(3)). The Board will cancel the third hearing "ifthe Agency indicates to the Board that it does not intend to introduce any additional material." Jd. Accordingly, the Board directs the hearing officer expeditiously to schedule all hearings in this proceeding according to the following statutory deadlines: FirstNotice Filing on orbefore Monday, March 22, 2010 (P.A. 96-0308 (subsection (e)); FirstHearing within 55 days ofreceiving the proposal, on orbefore Monday, May 3, 2010 (P.A. 96-0308 (subsection (f)(I)) (see 5 ILCS 70/1 .11 (2008) (Statute on Statutes); 35 Ill. Adm. Code 101.300(a) (Computation ofTime)); Second Hearing within 30 days ofthe first day ofthe first hearing, on orbefore Wednesday, June 2, 2010 (P.A. 96-0308 (subsection (f)(2)); Third Hearing within 14 days after the first day ofthe second hearing, on or before Wednesday, June 16,2010 (P.A. 96-0308 (subsection (f)(3)); Second Notice on orbefore Friday, July 16,2010, "ifno third hearing is held," or Thursday, August 5, 2010, "ifthe third hearing is held" (P.A. 96- 0308 (subsection (n)); Final Order within 21 days of"receipt ofa statement ofno objection to the rule from the Joint Committee on Administrative Rules" (P.A. 96-0308 (subsection (0)).3

As noted above, a "Motion for Waiver ofCopy Requirements" accompanied the Agency's rulemaking proposal. The Agency's motion first notes that the Board's procedural rules require it to file an original and nine copies ofits proposal with the Clerk. Mot. at I, citing 35111. Adm. Code 102.200. The Agency also notes that the Act requires it to provide information supporting its proposal. Mot. at 1-2 (listing eight sources), citing 415 ILCS 5/27(a) (2008). In addition, the Agency lists nine documents itproposes to incorporate by reference. Mot. at 2-3. The Agency first argues that a number ofthe documents itrelied upon in drafting its proposal or that it seeks to incorporate by reference "are readily accessible to or are within the possession ofthe Board." Mot. at 3. Specifically, the Agency lists the Illinois Environmcntal Protection Act, the CAA, three portions ofthe Code ofFederal Regulations (CFR), and the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). Mot. at 3 (listing items (g), (h), (i)(2), (i)(3), (i)(4), and (i)(7)). The Agency "moves that the Board waive the requirement that the Illinois EPA provide copies ofsuch documents." Mot. at 3. Second, the Agency states that Illinois Administrative Procedure Act (lAPA) authorizes an agency to incorporationby reference specified materials withoutpublishing the incorporated material in full. Mot. at 3, citing 5 ILCS 100/5-75(a) (2008). The Agency further states that "the IAPA provides, however, "that such agency shall maintain a copy ofthe referenced material in at least one ofits principal offices and shall make it available to the public upon request." Mot. at 3; citing 5 ILCS I00/5-75(c) (2008). The Agency indicates that itproposes to incorporate by reference four copyright-protected documents, two published by the American Society for Testing and Materials (ASTM) and two published by the American Architectural Manufacturers Association (AAMA). Mot. at 2-3 (listing items (i)(5), (i)(6), (i)(8), and (i)(9)). The Agency requests that the Board allow itto file only the originals ofsuch documents in order to keep its costs "ata minimum." 

### Ie!. at 3-4. Finally, the Agency states that "[t]he remaining documents in the regulatory proposal consist ofover 700 pages." Mot. at4. The Agency "requests that the Board waive the normal copy requirements and allow Illinois EPA to file the original and four complete copies ofthe documents." 

### Ie!. Section 101.500(d) ofthe Board's procedural rules provides, in pertinentpart, that, [w]ithin 14 days after service ofa motion, aparty may file aresponse to the motion. Ifno response is filed, the party will be deemed to have waived objection to the granting ofthe motion, butthe waiver ofobjection does notbind the Board or the hearing officerin its disposition ofthe motion. Unless undue delay or material prejudice would result, neither the Board northe hearing officerwill grant any motion before expiration ofthe 14 day response period
...." 35 Ill. Adm. Code 101.500(d). As noted above, Section 28.5 ofthe Actrequires the Board's rulemaking activities to follow a series ofstrict deadlines in scheduling and conducting hearings and issuing its opinions4

and orders. Under these circumstances, the Board concludes that undue delay would result from allowing the full 14-day rcsponse pcriod to run to Monday, March 22, 20

### IO. See 35 

### Ill. Adm. Code 101.500(d). Having reviewed the substance ofthe motion and in the absence to date ofany objcction, the Board grants the Agcncy's motion for waiver ofcopy requirements. First, the Board waives the requirement that the Agency provide copies ofthe Act, the CAA, three specified portions of the CFR, and the FIFRA, the sources listed in the Agency's motion as items (g), (h), (i)(2), (i)(3), (i)(4), and (i)(7). Second, the Board allows the Agency to file only an original ofthe two documents published by the ASTM and the two documents published by the AAMA listed in the Agcncy's motion as items (i)(5), (i)(6), (i)(8), and (i)(9) that the Agencyproposes to incorporatc by refcrence. Finally, the Board allows the Agency to file the original and four complete copies the remaining documents comprising its rulemaking proposal. CONCLUSION The Board accepts the Agency's rulemaking proposal for hearing and directs thc hearing officer to schedulc hearings as required by Section 28.5 ofthe Act. See P.A. 96-0308. The Board also grants the Agency's motion for waiver ofcopy rcquirements. Finally, in its order below, the Board directs the Clerk to filc the Agency's proposal for first-notice publication in the l/lil1ois Register. ORDER The Board directs the Clerk to cause the publication ofthe following rule for first notice in the l/linots Register.
TITLE 35: ENVIRONMENTAL PROTECTION SUBTITLE B: AIR POLLUTION CHAPTER I: POLLUTION CONTROL BOARD SUBCHAPTER c: EMISSION STANDARDS AND LIMITATIONS FOR STATIONARY SOURCES PART211 DEFINITIONS AND GENERAL PROVISIONS SUBPART A: GENERAL PROVISIONS Section 2] 1.101 211.102
Section 211.121 Incorporations by Refcrence Abbreviations and Conversion Factors SUBPART B: DEFINITIONS OtherDefinitions