B 1
BEFORE THE ILLI1"lOIS I'OLLUTION CONTROL BOARD

TABLE OF CONTENTS

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERlAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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RECEIVED

CLERK'S OFFICE

OCT 23 2009

STATE OF IlliNOIS

Po!lution Control Board

1. Notice of Filing

2. Appearance ofDana Vetterhoffer, Assistant Counsel for the Il1inois Environmental

Protection Agency

3. Proposal ofRegulations by Director Douglas P. Scott

4. Certification ofRequired Rule

5. Certification ofOrigination

6. Agency Analysis ofEconomic and Budgetary Effects

7. Motion for Waiver ofCopy Requirements

8. Fast Track Rulemaking Cover Sheet

9. Statement ofReasons

10. Proposed Amendments to 35 Ill. Adm. Code Parts 218 and 219

II. Technical Support Documentfor Control ofVolatile Organic Material Emissions in

Non-Attainment Areasfrom Paper, Film, and Foil Coatings, Large Appliance

Coatings, and Metal Furniture Coatings, AQPSTR09-IO, Il1inois Environmental

Protection Agency, July 2009

12. Documents Relied Upon:

Control Techniques Guidelinesfor Paper, Film, and Foil Coatings, United States

Environmental Protection Agency, Office ofAir Quality Planning and Standards,

Research Triangle Park, NC, September 2007.

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Control Techniques Guidelinesfor Metal Furniture Coatings, United States

Environmental Protection Agency, Office ofAir Quality Planning and Standards,

Research Triangle Park, NC, September 2007.

Control Techniques Guidelinesfor Large Appliance Coatings, United States

Environmental Protection Agency, Office ofAir Quality Planning and Standards,

Research Triangle Park, NC, September 2007.

Illinois Environmental Protection Act (415 ILCS 5/et seq.)

Clean Air Act (42 U.S.C. 7401 et seq.)

13. Certificate ofService

14. First Notice Forms

15. Disk in Microsoft WORD containing Agency's Proposed Amendments to Parts 218

and 219, and First Notice Forms

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

IN THE MATTER OF:

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RECE8VlED

CLERK'S OFFICE

OCT 23 2009

STATE OF IlLINOIS

POllution Control Board

Matthew Dunn, Chief

Division ofEnvironmental Enforcement

Office ofthe Attorney General

69 W. Washington, Suite 1800

Chicago, IL 60602

NOTICE

John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Dlinois 60601-3218

To:

Virginia Yang

Deputy Legal Counsel

Illinois Department ofNatural Resources

One Natural Resources Way

Springfield, IL 62702

PLEASE TAKE NOTICE that I have today tiled with the Office of the Pollution Control

Board the REGULATORY PROPOSAL entitled "REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM

GROUP mCONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO

35 ILL. ADM. CODE 218 and 219," MOTION FOR WAJVER OF COPY REQUIREMENTS,

and APPEARANCE ofthe illinois Environmental Protection Agency, a copy ofwhich is

herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:~~~~Zi!tJ.¥A;L Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: )

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REASONABLY AVAlLABLE CONTROL )

TECHNOLOGY (RACT) FOR VOLATILE )

ORGANIC MATERIAL EMISSIONS FROM )

GROUP III CONSUMER & COMMERCIAL )

PRODUCTS: PROPOSED AMENDMENTS )

T035 ILL. ADM. CODE218 and 219 )

APPEARANCE

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STATE 0

"Ollution CF IL1..JNOIS antral Board

The undersigned hereby enters her appearance as an attorney on behalf ofthe Illinois

Environmental Protection Agency.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By~tkdak~_ Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel

DATED: October 15,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 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 III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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ILLINOIS ENVIRONMENTAL PROTECTION AGENCY PROPOSAL OF

REGULATIONS

The illinois Environmental Protection Agency moves that the Illinois Pollution Control

Board adopt the attached regulations.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

DATED: Oc_-h>her 8 ,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RI\CT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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!RECEIVEEi

CLERK'S OFFICE

OCT 232009

STATE OF lLUNOIS

Pollution Control Board

CERTIFICATION OF REQUIRED RULE

The Illinois Environmental Protection Agency certifies in accordance with 35 Ill. Adm.

Code 102.202(h) and 102.500, and 415 ILCS 5/28.2(b), that it believes that this proposal for

amendments to 35 Ill. Adm. Code 218 and 219 is a federally required rule under Sections

172(c)(1) and I82(b)(2) of the Clean Air Act ("CAA"). 42 US.c. §§ 7502(c)(I) and

7511 a(b)(2).

The proposal for amendments is needed to satisfY Illinois' obligation to submit a State

Implementation Plan ("SIP") for sources of volatile organic materials ("VOM") emissions in

areas designated as nonattainment with respect to the ozone National Ambient Air Quality

Standard. Section I72(c)(I) 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 of emissions. 42 U.S.c. § 7502(c)(I). Section

I 82(b)(2) ofthe CAA provides that, for ozone nonattainment areas, the State must revise its SIP

to include RACT for sources of YOM emissions covered by a control techniques guideline

("CTG") issued between November 15, 1990, and the date of attainment. 42 US.c. §

751Ia(b)(2).

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The proposed amendments are intended to establish RACT requirements for Group III

Consumer and Commercial Product categories in response to CTGs issued by the United States

Environmental Protection Agency on October 9, 2007, and thereby satisfy the CAA requirements

described above.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:~~~ Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel

DATED: October 15,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544

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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

CERTIFICATION OF ORIGINATION

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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The Illinois Environmental Protection Agency certifies in accordance with 35 Ill. Adm.

Code 102.202(i) that this proposal for amendments to 35 Ill. Adm. Code 218 and 219 amends the

most recent version of the rules as published on the Illinois Pollution Control Board's website.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:~~ Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel

DATED: October 15, 2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Agency:

Agency Analysis of Economic and

Budgetary Effects of Proposed Rulemaking

DJinois Pollution Control Board

lECERVI!

CLERK'S OFFlceffi;

aCT 23 2a09

.;;TATE OF ILLlNQ

'nilur':m ""ontroJ B IS 'v" Oard

Part/Title: Organic Material Emission Standards and Limitations for the Chicago Area (35

TIl Adm. Code Part 218)

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.

(a) Current cost to the agency for this program/activity, -$13,000 per year

(b) If 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 of the effect.

N/A

(c) Indicate the funding source, including Fund and appropriation lines, for this

program/activity. N/A

(d) If an increase or decrease in the costs of another State agency is anticipated,

specify the fiscal year in which this change will frrst occur and the estimated

dollar amount ofthe effect. N/A

(e) Will this mlemaking have any effect on State revenues or expenditures not

already indicated above? No

2. Economic effect on persons affected by the mlemaking:

(a) Indicate the economic effect and specify the persons affected:

Positive _ Negative No effect __

Persons affected: See list of potentially affected sources in TSD.

Dollar amount per ton ofVOM emissions reduced:

Affected paper, film and foil coaters: $0-1,200/ton

Affected large appliance coater: $0-500/ton'

Affected metal furniture coater: $0-200/ton

Total statewide cost:

Affected paper, film and foil coaters: $0-25,740/year

Affected large appliance coater: SO/year (No affected source)

Affected metal furniture coater: SO/year (No affected source is expected to need

additional control)
(b) If an economic effect is predicted, please briefly describe how the effect will

occur. Costs due to control measures for newly-affected sources, as descrihed

in TSD.

(c) Will the rulemaking have an indirect effect that may result in increased

administrative costs? WilJ there be any change in requirements such as

filing, documentation, reporting or completion offolTIls?

The rulemaking will require a small amount of additioual reporting but

should have no more than a negligible indirect effect that mav result in

increased administrative costs.
Agency:

Agency Analysis of Economic and

Budgetary Effects of Proposed Rulemaking

I1Jinois Pollution Control Board

PartlTitle: Organic Material Emission Standards and Limitations for the Metro East Area

(35 IlL Adm. Code Part 219)

I1Jinois Register Citation: _

Please attempt to provide as dollar-specific responses as possible and feel free to add any relevant

explanation.

I. Anticipated effect on State expenditures and revenues.

(a) Current cost to the agency for this program/activity. -$1,200 per year

(b) If 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 effect.

N/A

(c) Indicate the funding source, including Fund and appropriation lines, for this

program/activity. N/A

(d) If 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 -.-X- No effect __

Persons affected: See Jist of potentiallv affected sonrces in TSD.

Dollar amount per ton of YOM emissions reduccd:

Affected paper, film and foil coaters: $0-1,200/ton

Affected large appliance coater: SO-500/ton

Affected metal furniture coater: SO-200/ton

Total statewide cost:

Affected paper, film and foil coaters: SO/year year (No affected source is

expected to need additional control)

Affected large appliance coater: SO/year (No affected source)

Affected metal furniture coater: SO/year (No affected source)
(b) If an economic effect is predicted, please briefly describe how the effect will

occur. Costs due to control measures for newlv-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 offonlls?

The rllicmaking will require a small amount of additional reporting but

should have no more than a negligible indirect effect that mav result iu

increased administrative costs.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MOTION FOR WAIVER OF COPY REOUIREMENTS

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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The Proponent, the Illinois Environmental Protection Agency ("Illinois EPA"), by its

attomey, and pursuant to 35 Ill. Adm. Code 101.500, 102.1 10, 102.200, and 102.402,

respectfully moves that the Illinois 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 of each regulatory proposal be filed with the Clerk. This entire regulatory proposal

consists of approximately 400 pages. Given the length ofthe proposal and the resources required

to provide nine copies, Illinois EPA requests that the Board waive the normal copy requirements

and allow Illinois EPA to file the original and four complete copies ofthe documents.

2. Section 27(a) ofthe Environmental Protection Act requires that the Illinois EPA

provide information supporting the proposal. 415 ILCS 5/27(a). Two ofthe documents relied

upon by the Illinois EPA, the Illinois Environmental Protection Act and the Clean Air Act, are

readily accessible to or are within the possession of the Board. Given the ease of accessibility of

these documents, listed as items 'd' and 'e' below, the Illinois EPA moves that the Board waive

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the requirement that the Illinois EPA provide copies ofsuch documents. The Illinois EPA has

otherwise provided documents which were directly relied upon when drafting the regulatory

proposal. The documents relied upon are as follows:

a. Control Techniques Guidelinesfor Paper, Film, and Foil Coatings, United States

Environmental Protection Agency, Offiee ofAir Quality Planning and Standards,

Researeh Triangle Park, NC, September 2007.

b. Control Techniques Guidelinesfor Metal Furniture Coatings, United States

Environmental Protection Agency, Office ofAir Quality Planning and Standards,

Research Triangle Park, NC, September 2007.

c. Control Techniques Guidelinesfor Large Appliance Coatings, United States

Environmental Protection Agency, Office ofAir Quality Planning and Standards,

Research Triangle Park, NC, September 2007.

d. Illinois Environmental Protection Act (415 ILCS 51et seq.).

e. Clean Air Act (42 U .S.C. 7401 et seq.).

WHEREFORE, the Illinois EPA moves that the Board waive the requirement that the

Illinois EPA provide eopies ofthe documents listed as items 'd' and 'e' above, and waive the

requirement that the Illinois EPA provide an original and nine copies ofthe remaining

documents in its proposal.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By: L

Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel

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THIS/SA

FAST TRACK

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

I. INTRODUCTION

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED A.J.\1ENDMENTS

TO 35 ILL ADM. CODE 218 and 219

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RIO- /0

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STArE 0"

POI/ution C ILLINOiS

Ontrol BO

ara

The Illinois Environmental Protection Agency ("Illinois EPA") submits this

Statement ofReasons to the Illinois Pollution Control Board ("Board") pursuant to

Sections 10,27, and 28.5 ofthe Environmental Protection Act ("Act") (415 ILCS 5110,

27, and 28.5) and 35 TIl. Adm. Code 102.202 in support ofthe attached proposal of

regulations. 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 III Consumer and Commercial Product Categories:

Paper, Film, and Foil Coatings, Metal Furniture Coatings, and Large Appliance Coatings.

This proposed rulemaking is intended to meet certain obligations ofthe State of

Illinois under the federal Clean Air Act ("CAA"), 42 U.S.c. § 7401 et seq. Specifically,

the rulcmaking is intended to satisfy Illinois' obligation to submit a State Implementation

Plan ("SIP") to address requirements under Sections 172 and 182 ofthe CAAfor sources

ofVOM emissions in areas designated as nonattainment with respect to the ozone

National Ambient Air Quality Standard C'NAAQS"). See 42 U.S.C. §§ 7502 and 7511a.

Section 172(c)(1) ofthe CAA provides that states must include in their SIPs for

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nonattailll11ent areas ("NAAs") "reasonably available control measures" ("RACM"),

including "reasonably available control technology" ("RACT"), for sources of emissions.

42 U.S.c. § 7502(c)(l). Section 182(b)(2) ofthe CAA provides that, for ozone NAAs,

the State must revise its SIP to include RACT for sources ofVOM emissions covered by

a control techniques guideline ("CTG") issued between November 15, 1990, and the date

ofattailll11ent. 42 U.S.c. § 7511a(b)(2).

Illinois is proposing reasonable and cost effective YOM controls for Group III

Consumer and Commercial Product Categories in response to CTGs issued for such

categories. Included in this proposal are amendments to 35 Ill. Adm. Code Part 21 8,

Organic Material Emission Standards and Limitations for the Chicago Area, and 35 Ill.

Adm. Code Part 219, Organic Material Emission Standards and Limitations for the Metro

East Area.

II. STATEMENT OF FACTS

The CAA establishes a comprehensive program for controlling and improving the

nation's air quality via state and federal regulations. The United States Envirolll11ental

Protection Agency ("USEPA") is charged with identifying air pollutants that endanger

the public health and welfare and with formulating the NAAQS that specify the

maximum permissible concentrations ofthose pollutants in the ambient air pursuant to

Sections 108 and 109 ofthe CAA. 42 CS.C. §§ 7408-7409.

A. 8-Hour Ozone NAAQS

Ozone occurs both in the Earth's upper atmosphere and at ground level. YOM is

a primary precursor to the formation of ground-level ozone, which is formed when oxides

ofnitrogen and YOM react in the atmosphere in the presence ofsunlight. Ground-level

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ozone is a major component ofsmog. 72 Fed. Reg. 57217 (Oct. 9, 2007). Exposure to

sufficient concentrations of ground-level ozone is associated with agricultural crop loss,

damage to forests and ecosystems, and a variety of human health conditions, including

acute respiratory symptoms, increased susceptibility to respiratory infection, and

pulmonary inflammation. 72 Fed. Reg. 57217.

On July 18, 1997, USEPA revised the NAAQS for ozone by replacing the I-hour

standard with an 8-hour standard. 62 Fed. 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 Sable Townships), Kane, Kendall (partial-Oswego

Township), Lakc, McHenry, and Will Counties; and 2) the St. Louis, MO-IL designated

area, which includes Jersey, Madison, Monroe, and St. Clair Counties. 40 CFR § 81.314.

B. CAA Requirements

1. Consumer and Commercial Products, Group III

Section 183(e) ofthe CAA required that USEPA conduct a study of the emissions

ofVOM into the ambient air from consumer and commercial products in order to

determine their potential to contribute to ozone levels which violate the ozone NAAQS

and to establish criteria for regulating emissions ofVOMfrom such products. 72 Fed.

Reg. 57217. Section l83(e) provides, H[T]he Administrator shall Jist those categories of

consumer or commercial products that the Administrator determines, based on the study,

account for at least 80 percent ofthe VOC emissions ... from consumer or commercial

products in areas that violate the NAAQS for ozone" and shall divide the categories into

groups. 42 U.S.c. § 7511 b(e)(3)(A).

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The CAA requires that USEPA then either regulate YOM emissions from such

categories or issue a CTG in lieu of a national regulation ifthe Administrator determines

that such guidance will be substantially as effective as regulations in reducing emissions

ofVOM which cOntribute to ozone levels in ozone NAAs. 42 U.S.C. § 75 1lb(e)(3)(C).

CTGs provide states with recommendations regarding what types of controls could

constitute RACT for YOM for the applicable source categories. 72 Fed. Reg. 57217-

57218. States must either adopt regulations to implement the recommendations in the

CTG or adopt alternative approaches that constitute RACT, either of which must be

submitted to the USEPA for review and approval as part ofthe SIP process. 72 Fed. Reg.

57218.

On October 9, 2007, the USEPA issued final CTGs for three Group III Consumer

and Commercial Product Categories. The USEPA required that states submit SIP

revisions in response to the CTGs within one year. 72 Fed. Reg. 57215-57218.

2. RACT Requirements

USEPA designated the Chicago and Metro East areas in Dlinois as nonattainment

(moderate) for the 8-hour ozone NAAQS, which triggered requirements under the CAA

for adopting regulations that reduce emissions sufficiently to demonstrate attainment of

the standard. Section 172(c)(l) ofthe CAA provides, in pertinent part:

(c) Nonattainment plan provisions

The plan provisions (including plan items) required to be submitted under this

part shall comply with each ofthe following:

(1) In general

Such plan provisions shall provide for the implementation of all

reasonably available control measures as expeditiously as

practicable (including such reductions in emissions from existing

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sources in the area as may be obtained through the adoption, at a

minimum, ofreasonably available control technology) and shall

provide for attainment ofthe national primary ambient air quality

standards.

42 U.S.C. § 7502(c)(l). A subset ofRACM is RACT, which is defined as the lowest

emission limitation that a particular source can meet by applying a control technique that

is reasonably available considering teclmological and economic feasibility. See 44 Fed.

Reg. 53762 (September 17, 1979).

Additionally, Section 182(b) of the CAA provides, in peltinent part:

(b) Moderate Areas

Each State in which all or palt of a Moderate Area is located shall, with respect to

the Moderate Area, make the submissions described under subsection (a) ofthis

section (relating to Marginal Areas), and shall also submit the revisions to the

applicable implementation plan described under this subsection.

(2) Reasonably available control technology

The State shall submit a revision to the applicable implementation

plan to include provisions to require the implementation of

reasonably available control technology under section 7502(c)(l)

ofthis title with respect to each ofthe following:

(A) Each category ofVOC sources in the area covered by a

CTG document issued by the Administrator between

November 15, 1990, and the date of attainment.

42 U.S.C. § 7511a(b)(2).

Sections 172 and 182 ofthe CAA establish the requirement for Illinois to submit

YOM regulations constituting RACT for Group III Consumer and Commercial Product

Categories in ozone NAAs classified as moderate and above. Illinois was required to

submit its SIP revisions by October 9,2008.

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C. Fast Track

This regulatory proposal is properly submitted to the Board under Section 28.5 of

the Act as a fast-track rulemaking. Section 28.5 provides, "When the [CAA] requires

rules other than identical in substance rules to be adopted, upon request by the Agency,

the Board must adopt rules under fast-track rulemaking requirements" A rule is

"required to be adopted" when the USEPA "is empowered to impose sanctions against

the State for failure to adopt such rules." 415 ILCS 5/28.5.

This rulemaking proposal 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 which set forth recommendations that a state may utilize when

making YOM RACT detenninations for Group III product categories. See 72 Fed. Reg.

57218: Second, the proposed rule is required to be adopted. As previously discussed,

Sections 172 and 182 ofthe eM require that Illinois submit as a SIP revision YOM

RACT regulations for Group III categories in ozone NMs. Pursuant to Section 179 of

the CM, two sanctions are available to USEPA ifIllinois fails to do so: 1) the loss of

highway funds; and 2) an increase in the emissions offset ratio for New Source Review.

42 U.S.c. § 7509. Further, ifIllinois fails to make an adequate SIP submission, USEPA

has the authority to impose a Federal Implementation Plan pursuant to Section 110(c)(l)

ofthe CAA. 42 U.S.C. § 7410(c)(l). Illinois EPA's submittal ofits proposal as a fasttrack iulemaking is therefore appropriate.

III. PURPOSE AND EFFECT OF THE PROPOSAL

As described in detail above, this rulemaking proposal has been prepared to

satisfy Illinois' obligation to submit a SIP to address the requirements under Sections 172

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and 182 ofthe CAA for sources of YOM emissions in areas designated as nonattainment

with respect to the ozone NAAQS. See 42 U.S.c. §§ 7502 and 7511a.

Additionally, lllinois is required to submit these SIP revisions before the USEPA

can redesignate the Chicago and Metro East NAAs to attainment ofthe 1997 ozone

NAAQS, regardless of whether the YOM reductions obtained by the SIP revisions are

actually necessary to achieve attainment ofthe NAAQS. Section 107(d)(3)(E) ofthe

CAA provides that the Administrator may not redesignate a NAA to attainment unless

the State has a fully-approved SIP for the area seeking redesignation and the State has

met all applicable requirements of Section 110 and Part D (which includes the

requirement that states adopt YOM RACT rules for categories covered by a CTG). 42

U.S.c. § 7407(d)(3)(E). In a September 17, 1993, guidance document from Michael H.

Shapiro, Acting Assistant Administrator for Air and Radiation ("Shapiro

Memorandum"), the USEPA confirmed, "[B]efore EPA can act favorably upon any State

redesignation request, the statutorily-mandated control programs ofsection 110 and part

D (that were due prior to the time ofthe redesignation request) must have been adopted

by the State and approved by EPA into the SIP." (Shapiro Memorandum, p. 2).1

On July 2, 2007, the Illinois EPA submitted to the USEPA an attainment

demonstration for the Metro East NAA for the 1997 8-hour ozone NAAQS. On March

19,2009, the lllinois EPA submitted an attainment demonstration for the Chicago NAA

as well. These areas call1lot be redesignated to attainment of the ozone NAAQS,

1 See also Wall v. USEPA. In Wall, the United States Court ofAppeals for the Sixth Circuit vacated the

USEPA's redesignation of a state to attainment, in pal1 because the state failed to promulgate VOC RAeT

rules in response to CTGs. The USEPA argued that fully adopted VOC RACT rules were unnecessary

because the state did not need the reductions from such rules to achieve attainment. The court rejected

USEPA's argument, holding that the CAA unambiguously requires that a SIP submitted with respect to a

rcdesignation request contain fully adopted RACT rules required by Part D. Redesignation absent such

rules was therefore improper. Wall v. USEPA, 265 F.2d 426,433,440-42 (6th Cir. 2001).

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however, unless and until the Illinois EPA submits SIP revisions in response to the Group

III CTGs and the USEPA approves such revisions.

Finally, in March 2008, USEPA strengthened the eight-hour ozone standard. 73

Fed. Reg. 16436 (March 27, 2008). It is likely that the same areas in Illinois that are

currentiy designated as nonattainment for the present standards will be designated as

nonattainment for the revised standard. While attainment of the revised standard is not

the purpose ofthis rulemaking, it should be noted that any reduction in YOM emissions

in the NAAs resulting from these proposed amendments will improve ozone air quality

and will likely help Illinois achieve and maintain the newly revised NAAQS.

IV. GEOGRAPHIC REGIONS AND SOURCES AFFECTED

The geographic regions subject to the proposed regulations are the two areas

designated as nonattainmcnt for the 8-hour ozone standard: 1) the Chicago-Gary-Lake

County, IL-IN designated area, which includes Cook, DuPage, Gnmdy (partial-Goose

Lake and Aux Sable Townships), Kane, Kendall (partial-Oswego Township), Lake,

McHenry, and Will Counties; and 2) the St. Louis, MO-IL designated area, which

includes Jersey, Madison, Monroe, and St. Clair Counties. 40 CFR § 81.314.

The proposed regulations are generally expected to affect both new and existing

sources that are covered by a Group III CTG, are located in the Chicago or Metro East

NAAs, and meet the applicability criteria specified in the regulations. Table 11 in the

Technical Support Document lists the sources potentially affected by the proposed

regulations.

V. TECHNICAL FEASIBILITY AND ECONOMIC REASONABLENESS

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The technology for controlling YOM emissions from Group II! product categories

is both technically feasible and economically reasonable. Affected sources can meet the

requirements in the proposed anlendments through a number ofreadily available control

techniques.

Control approaches for reducing YOM emissions from paper, film, and foil

coatings include work practices, material reformulation or substitution (namely, the use

oflow-VOM coatings or no-YOM coatings), and capture systems and add-on control

devices such as oxidizers, carbon adsorption systems, and condensers. Similarly, YOM

control techniques for metal furniture coatings include work practices for coating waste

and cleaning materials, and material reformulation/substitution via low-YOM coatings

such as higher solids coatings and waterborne coatings. Metal furniture coating lines can

also control YOM emissions by utilizing capture systems and add-on control devices

such as oxidizers, adsorbents, and absorbents, and more efficient coating application

equipment, such as electrostatic or high volume/low pressure spray equipment. Control

approaches for large appliance coatings are similar to those available for metal furniture

coatings. See Technical Support Document.

In the Technical Support Document, 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. On July 20, 2009, the

Illinois EPA posted a draft ofthe proposed rule and copies ofthe pertinent CTGs on its

website for public comment. The Illinois EPA also contacted potentially affected sources

9
via email, soliciting feedback on the proposed mle. While the Illinois EPA did not

receive any comments regarding its proposal, interested parties have nonetheless had an

opportunity to review the rule and discuss any issues with the Illinois EPA.

VII. SYNOPSIS OF TESTIMONY

The Illinois EPA plans to call Yoginder Mahajan, Environmental Protection

Engineer, Air Quality Planning Section, Bureau of Air, Illinois EPA, as a witness at

hearing. Mr. Mahajan will testifY and answer questions regarding the proposed

amendments. Written testimony will be submitted prior to hearing in accordance with the

Board's procedural mles and with Board orders.

VIII. THE ILLINOIS EPA'S PROPOSAL

Generally, Illinois EPA's regulatory proposal aims to implement the

recommendations contained in the CTGs to the extent that such recommendations are

consistent with existing regulations. For all three coating categories, the Illinois EPA

proposes amending YOM content limitations, adding CTG-recommended exclusions, and

adding work practice requirements. For metal furniture and large appliance coating lines,

the Illinois EPA also proposes adding limitations regarding coating application methods.

The following is a Section-by-Section summary ofthe Illinois EPA's proposal.

35 Ill. Adm. Code 218/219

Subpart A: General Provisions

Section 218/219.106 Compliance Dates

The Illinois EPA proposes adding a new subsection (e) to Section 218.106 and a

new subsection (c) to Section 219.106, which establish May 1,2011, as the compliance

date for sources subject to the rulemaking proposal.

10
Subpart F: Coating Operations

Section 218/219.204 Emission Limitations

The Illinois EPA proposes amending the introductory paragraph to reference

revised subsections of Section 218/219.204.

The lllinois EPA proposes amending subsection (c) to restrict the VOM content of

paper coatings to the limitations setJortb in the CTG, and to provide that such limitations

shall not apply to coating performed on or in-line with digital printing presses, or to size

presses and on-machine coaters on papennaking machines applying sizing or water-based

clays.

The Illinois EPA proposes an1ending subsection (g) to restrict the VOM content

of metal furniture coatings to the limitations set forth in the CTG, and to provide that

such limitations shall not apply to stencil coatings, safety-indicating coatings, solid-film

lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair

coatings, or coating applications utilizing hand-held aerosol cans. The Illinois EPA also

proposes amending subsection (g) to provide that coating lines shall comply with the

application method requirements specified in the proposed rule revisions.

The Illinois EPA proposes amending subsection (h) to restrict the VOM content

oflarge appliance coatings to the limitations set forth in the CTG, and to provide that

such limitations shall not apply to stencil coatings, safety-indicating coatings, solid-film

lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair

coatings, or coating applications utilizing hand-held aerosol cans. The Illinois EPA also

proposes amending subsection (h) to provide that coating lines shall comply with the

application method requirements specified in the proposed rule revisions.

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Section 2181219.205 Daily-Weighted Average Limitations

The Illinois EPA proposes amending the introductory paragraph to reference

proposed subsection G).

The Illinois EPA proposes amending subsection (a) to provide that such

subsection only applies to paper coating lines until May I, 2011.

The Illinois EPA proposes adding subsection G), which sets forth the

requirements for paper coating lines utilizing the daily weighted averaging alternative on

and after May 1, 201l.

Section 218/219.207 Alternative Emission Limitations

The Illinois EPA proposes amending subsection (a) to reference proposed

subsection (I).

The Illinois EPA proposes amending subsections (c), G), and (k) to provide that

such subsections only apply to paper coating lines, metal furniture coating lines, and

large appliance coating lines, respectively, until May 1, 2011.

The illinois EPA proposes. adding subsection (1), which sets forth the

requirements for paper, metal furniture, and large appliance coating lines utilizing the

alternative emissions limitation on and after May 1, 2011.

Section 218/219.210 Compliance Schedule

The Illinois EPA proposes adding subsection (g), which provides that, on and

after a date consistent with Section 218/219.] 06, sources subject to the proposed paper,

metal furniture, or large appliance ccating limitations shall comply with such limitations,

as well as with all other applicable provisions in Subpart F. The Illinois EPA also

proposes amending the introductory paragraph to reference proposed subsection (g).

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Section 218/219.211 Recordkeeping and Reporting

The Illinois EPA proposes correcting two spacing elTOTS in subsection (b)(1) of

Section 218.211.

The Illinois EPA proposes amending subsection (c) to provide that, for paper

coating lines subject to the proposed YOM content limitations, YOM content information

shall be maintained and/or reported in terms of weight of YOM per weight ofsolids or

coatings, as applicable, as applied each day on each coating line. The Illinois EPA also

proposes amending subsection (c) to provide that metal furniture and large appliance

coating lines subject to the proposed YOM content limitations maintain and/or report

YOM content information in terms of weight of YOM per volume of each coating or

solids, as applicable, as applied each day on each coating line, and report the.application

methodes) used to apply coatings on each subjcct coating line. Paper, metal furniture,

and large appliance coating lines shall also maintain and report certified product data

sheets for each coating applied on each line.

The Illinois EPA proposes amending subsection (d) to provide that, for paper

coating lines utilizing the daily weighted averaging alternative, YOM content information

shall be maintained and/or reported in terms of weight of YOM per weight ofsolids or

coatings, as applicable, as applied each day on each coating line. The Illinois EPA also

proposes amending subsection (d) to provide that metal furniture and large appliance

coating lines utilizing the daily weighted averaging alternative maintain and/or report

YOM content information in terms ofweight ofYOM per volume of each coating or

solids, as applicable, as applied each day on each coating line.

The Illinois EPA proposes amending subsection (e) to provide that coating lines

13
complying pursuant to Section 218/219.207(1) shall comply with the recordkeeping and

reporting requirements set forth in subsection (e).

The Illinois EPA proposes adding subsection (g), which establishes recordkeeping

and reporting requirements for paper, metal furniture, and large appliance coating lines

subject to the work practice requirements set forth in Section 2181219.218.

Section 218/219.212 Cross-Line Averaging to Establish Compliance for Coating

Lines

The Illinois EPA proposes amending this Section to provide that the cross-line

averaging alternative is not available to coating lines subject to the revised YOM content

limitations.

Section 218/219.218 Work Practice Standards for Paper Coatings. Metall<'urniture

Coatings, and Large Appliance Coatings

The Illinois EPA proposes adding Section 218/219.218, which sets forth work

practice requirements for cleaning materials and/or cleaning-related activities associated

with paper, metal furniture, and large appliance coating lines. Generally, Illinois EPA

proposes that subject coating lines store all YOM-containing materials in closed

containers, ensure that mixing and storage containers used for YOM-containing materials

are kept closed at all times except when in use, minimize spills ofYOM-containing

materials, convey such materials from one location to another in closed containers or

pipes, and minimize YOM emissions from the cleaning ofstorage, mixing, and

conveying equipment.

14
DATED: October 15,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:-.D~"""'---=Y--"""""'~fbI'-"-4­ Dana Vetterhoffer

. Assistant Counsel

Division of Legal Counsel

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TECHNICAL SUPPORT DOCUMENT

CONTROL OF VOLATILE ORGANIC MATERIAL

EMISSIONS IN NON-ATTAINMENT AREAS

FROM

PAPER, FILM, AND FOIL COATINGS,

LARGE APPLIANCE COATINGS,

AND METAL FURNITURE COATINGS

AQPSTR 09-10

October 1, 2009

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST

P.O. BOX 19276

SPRINGFIELD, ILLINOIS 62794-9276
Table of Contents

List of Tables ---------------- ----------------- 4

List of Acronyms 5

Executive Summary 6

1.0 Introducti0 n 7

2.0 Process Description and Source of YOM Emissions 9

2.1 Paper, Film, and Foil Coatings 9

2_2 Large AppIiance Coatings I0

2_3 Metal Fumiture Coatings 11

3.0 TechnicaI Feasibility of Con trols .1 3

3.1 Paper, Film, and Foil Coatings .1 3

3.2 Large AppIiance Coatings IS

3.2_1 Emission Ljmits Based on Low-VOM Coatings J 7

3_2_2 Optional Add-On Controls for Coating Operations J 7

3_2.3 Work Practices for Coating Operations and Cleaning Materials 20

3_3 Metal Fumiturc Coatings 20

3.3.1 Emission Limits based on Low-YOM Coatings 22

3.3.2 Add-On Controls for Coating Operations 22

3.3.3 Work Practices for Coating Operations and Cleaning Materials 24

4.0 Economic Reasonableness 26

4_1 Paper, Film, and Foil Coatings 26

4_2 Large Appliance Coatings 26

4.3 Metal Fumiture Coatings 2 7

5.0 Existing and Proposed ReguIations 28

5_1 Existing Regulations 2 8

5_1_1 Paper, Film and Foil Coating 28

5.1.2 Large Appliance Coatings 29

5_1 .3 Metal Fumiture Coatings .30

5.2 Proposed Regul ations .30

5_2_1 Paper, Film, and Foil Coatings .30

2

6.0

7.0

5.2.2 Large Appliance Coatings 32

5.2.3 Metal Fumiture Coatings.. . 33

Affected Sources 34

References 36

3
Table 1.

Table 2.

Table 3.

Table 4.

Table 5.

Table 6.

Table 7.

Table 8.

Table 9.

Table 10.

Table 11.

Tables

RACT Limits for Paper, Film, and Foil Coatings .15

Mass of YOM per Volume of Coating for Large Appliance Coatings J 8

Mass of YOM per Volume of Solids for Large Appliance Coatings .19

Mass ofVOM per Volume ofCoating for Metal Fumiture Coatings 23

Mass ofVOM per Volume of Solids for Metal Fumiture Coatings 24

Existing YOM Content Limits for Paper Coatings 28

Existing YOM Content Limits for Large Appliance Coatings 29

Existing Metal Fumiture Coatings limits 30

Proposed Limits for Paper Coatings .31

YOM Emission Reductions in the Chicago and Metro East NAAs .34

List of Affected Sources in the Chicago and Metro East NAAs .35

4
CAA

CO

CTG

Illinois EPA

NAA

NAAQS

NOx

PTE

RACT

SIP

tpy

U.S. EPA

VOM

List of Acronyms

Clean Air Act

Carbon Monoxide

Control Techniques Guidelines

Illinois Environmental Protection Agency

Non-attainment Area

National Ambient Air Quality Standards

Nitrogen Oxides

Potential To Emit

Reasonably Available Control Technology

State Implementation Plan

Tons per year

United States Environmental Protection Agency

Volatile Organic Material

5
EXECUTIVE SUMMARY

The Clean Air Act (CAA)!, as amended in 1990, requires that state implementation plans (SIPs)

for ozone non-attainment areas (NAAs) be revised in accordance with the implementation of

reasonably available control technology (RACT). For control of volatile organic materials

(VOM), which are precursors to the fomlation of ozone, the United States Environmental

Protection Agency (U.S. EPA) has published control techniques guidelines (CTGs) to establish

RACT categories for certain source categories. The regulated list was first released on March 23,

1995, and includes the following categories: paper, film, and foil coatings, metal fumiture

coatings, and large appliance coatings. In September of2007, the U.S. EPA released an update

to the CTGs for paper, film, and foil coatings2

; large appliance coatings3; and metal fumiture

coatings4

• As a result, Illinois Environmental protection Agency ("Illinois EPA") is proposing

the regulations to control YOM emissions from these categories ofsources in the Chicago and

Metro-East nonattainment areas ("NAAs"). The ,Chicago NAA includes the counties ofCook,

DuPage, Kane, Lake, McHenry, Will, the townships of Aux Sable and Goose Lake in Grundy

County, and the Oswego township in Kendall County, while the Metro East NAA includes

Jersey, Madison, Monroe, and St. Clair counties.

The Illinois EPA reviewed and relied upon the recommendations contained in the CTGs to

develop its proposal to control YOM emissions from the affected sources. There are a total of24

sources'affected by this proposal in the Illinois NAAs. Though it is difficult to quantify actual

YOM emissions reductions from this proposal, the Illinois EPA estimates that there will be 21.45

ton per year ofreductions in the YOM emissions at a cost of $1200.00 per ton ofVOM removed.

The Illinois EPA believes that the proposed regulations are technically feasible and cost

effective.

G
].0 INTRODUCTION

Pursuant to Section 109 ofthe CAA1

, and to protect the public health, the U.S. EPA revised the

national ambient air quality standard ("NAAQS") for ozone, effective July 17, 1997. The U.S.

EPA lowered the NAAQS for ozone to 0.08 parts per million from the previous 0.12 parts per

million. In addition, the time period used for measuring compliance was increased from the

previous I hour to 8 hours. The U.S. EPA designated areas that did not meet the NAAQS for 8-

hour ozone in April 2004. In lllinois, the Chicago and the Metro EastlSt. Louis areas have been

designated as moderate ozone nonattainment areas under the new NAAQS. Included in the

Chicago NAA are Cook, DuPage, Kane, Lake, McHenry, and Will counties, as well as the Aux

Sable Township and Goose Lake Township in Grundy County, and Oswego Township in

Kendall County. The Metro EastlSt. Louis NAA is comprised ofJersey, Madison, Monroe, and

St. Clair counties. The CAA Section 172 requires that SIPs for these non-attainment areas must

include emission controls that are economically and technologically feasible. Emission control

technologies that meet these criteria are known as reasonably available control technology

("RACT").

Accordingly, the lllinois EPA is proposing to reduce YOM emissions from the following

categories: paper, film, and foil coatings; large appliance coatings; and metal furniture coatings.

These three emission categories have been designated as "Consumer and Commercial Products,

Group III" by the U.S. EPA. Pursuant to CAA Section I 83(e)(3)(C), U.S. EPA determined that

CTGs "will be substantially as effective as national regulations in reducing emissions of volatile

organic compounds in ozone national ambient air quality standard nonattainment areas." Based

on that deternlination, U.S. EPA issued final CTGs in lieu of national regulations for the affected

categories in September 2007.

The U.S. EPA's CTG for Paper, Film, and Foil Coatings2 suggests applying control methods to

reduce YOM emissions for cleaning operations to each source in which the total actual YOM

emissions from all paper, film, and foil coating operations are equal to 15 Ib/day or more. For

coatings, the CTG suggests applying control methods to paper, film, and foil surface coating

lines that have a potential to emit ("PTE") at least 25 tons per year (tpy) ofVOM, before the

7
consideration of controls. However, for sources that have actual emissions greater than IS Ib/day

and where no single coating line has the PTE of 25 tpy or more before controls, the CTG

recommends applying only the suggested work practices. The U.S. EPA's CTG for paper, film,

and foil coatings cautions that this category is not to be confused with the coating that is

perfomled on or in-line with any offset lithographic, screen, letterpress, flexographic,

rotogravure, or digital printing press, as it is part of a printing process and not a coating process.

The CTGs for large appliance coatings and metal fumiture coatings recommend applying control

methods to sources in which the total actual YOM emissions from all related operations

(including cleaning activities) equal 15 lb/day or more, or an equivalent level (such as 3 tons per

12-month rolling period), before consideration of controls. This threshold level is deemed to be

equal to the evaporation of about 2 gallons ofsolvent per day, which is considered an incidental

level that can be expected even in sources that utilize low-solvent coatings (i.e. powder or UV

cure coatings)3,4

8
2.0 PROCESS DESCRIPTION AND SOURCE OF EMISSIONS

The U.S. EPA's CTGs contain infOlTIlation on various coating processes and their sources of

YOM emissions. The following discussion is based on the U.S. EPA's CTG documents.

2.1 Paper, Film, and Foil Coatings

Paper, film, and foil coatings include adhesives used on tapes and labels, and are defined as "any

protective, decorative, or functional coating applied on paper, plastic film, or metallic foil to

make certain products, including but not limited to, adhesive tapes and labels, book covers, post

cards, office copier paper, drafting paper, or pressure sensitive tapes"; this includes coatings

applied through saturation or impregnation. Paper, film, and foil surface coatings can also be

categorized as a web coating process, which typically involves the application of a continuous

layer of coating across either a whole or part ofthe width of a web substrate to do the following:

I) provide a covering, finish, or functional or protective layer to a substrate; 2) saturate a

substrate for lamination; or 3) provide adhesion between two substrates for lamination.

An average coating line can include a series ofone or more unwind/feed stations; one or more

coating applicators; the flash off area (the portion between two or more consecutive coating

applicators or between the coating applicator and the drying oven); one or more drying ovens;

and one or more rewind/cutting stations. Many varying kinds of coating applicators can exist,

and they include: rotogravure, reverse roll, slot die, knife, flexography, Mayer rod, dip and

squeeze, and extrusion/calendering. Further details regarding these types of coating applicators

can be found in the paper, film, and foil coatings CTG2 In addition, the cleaning activities that

occur at associated facilities are carried out to eliminate coating residue or other unwanted

materials from equipment related to coating operations; this is done via spray gun cleaning and

other such related cleaning operations.

Sources of YOM emissions arise from the evaporation of volatile components ofthe coatings

and cleaning materials. These can mostly be from the process of coating application/flash-off,

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coating curing/drying, and cleaning, About 90% ofthe YOM in the coatings is evaporated in the

d . 2

rymg ovens,

2.2 Large Appliance Coatings

Large appliancc coatings include paints, topcoats, basecoats, primers, enamels, sealants, caulks,

inks, adhesives, and maskants that are used in the manufacture oflarge appliances (such as

washers and dryers), Coatings from large appliances are defined as any protective, decorative, or

functional coating applied onto the surface oflarge appliances or to the constituent metal parts,

'Some examples that are listed as large appliances include residential and commercial washers,

dryers, ranges, refrigerators, freezers, water heaters, dishwashers, trash compactors, air

conditioners, and other similar products, The employment of coatings is an important part in the

making of large appliances, as they protect the metal on the large appliances from rusting away

by allowing resistance to such factors as moisture, heat, detergent, and even outdoor elements.

They must be durable and have superb adhesion properties to prevent chipping or peeling as

well.

Typical coating methods include air atomized spraying, airless spraying, electrostatic spraying,

dip coating, clectrodeposition, and flow coating. In air atomized spraying, compressed air is

used to provide transfer efficiencies of up to 40%, while airless spraying employs an airless

pump system to force the coating through a nozzle that is made to atomize the coating for a

transfer efficiency of between 50 to 60 percent. For electrostatic spraying, an air or an airless

gun system can be created to magnetize the coating to the substrate and achieve approximately

85% transfer efficiency. A dip coating process involves dipping a part into a tank that contains

the coating to have a transfer efficiency of close to 85%. Electrodeposition is just a type of dip

coating method that uses an electric field to aid the placement of a waterborne coating to a

substrate. Finally, flow coating is a technique that applies a coating directly onto a substrate

without atomizing the coating and usually creates 85% transfer efficiency. Further details

concerning the process for large appliance coatings are in the U.S, EPA's CTG for large

appliance coatings3

.

10
Primary sources of YOM emissions evolve from the coating application (prime, single or topcoat

application)/flash-off and drying/curing ofthe coatings, and from mixing and/or thinning. In

addition, cleaning materials are another source ofVOM emissions. Cleaning can involve

different types of chemical washes, including solvent cleaning, acid washing, phosphate

washing, and de-ionized water washing-solvent cleaning and wetting oil treatments are the

highest source ofVOM emissions. Cleaning materials can also be used in cleaning coating

equipment and to touch up the final products, and are typically YOM solvents, such as methyl

ethyl ketone (MEK) and toluene, but there has been a greater trend towards using alcohol and

water-based cleaners3

2.3 Metal Furniture Coatings

Metal furniture coatings include paints used in the manufacture of furniture made in whole or

part by metal (such as chairs and tables). Metal furniture coating is defined as "any protective,

decorative or functional coating applied onto the surface of any metal furniture or any metal part

which will be assembled with other metal, wood, fabric, plastic or glass parts to form metal

furniture." Examples of metal furniture include tables, chairs, waste baskets, beds, desks,

lockers, benches, shelving, file cabinets, lamps, and room dividers that are made in whole or in

part by metal. Similar to large appliance coatings, the coatings on metal furniture protect them

from rusting away by allowing resistance to such elements as moisture, heat, detergent, and even

outdoor factors, and they must be durable and have superb adhesion properties to prevent

chipping or peeling as well.

Four main processes are involved in the creation of metal furniture manufacturing: l) raw

material preparation; 2) surface preparation; 3) coating and adhesive application operations; and

4) assembly. Surface preparation, coating application operations, and cleaning activities use

YOM-containing compounds (e.g. coatings, thinners, and/or cleaning materials). Prior to a metal

furniture part or product being coated, its surface must be cleaned; this consists ofthe following

processing steps: l) alkali.ne or acid cleaning, 2) water rinse, 3) iron phosphate treatment, 4)

water rinse, and 5) pre-treatment and/or another final water rinse. After this stage, the surface

coating application occurs, followed by curing or a drying ofthe coating; the coating could either

11
be a liquid or powder, and can be sprayed or dipped. Next, the final unit is assembled and

packaged for shipment.

Similar to the large appliance coatings, the primary source of YOM emissions can occur from the

evaporation ofthe volatile contents ofthe coatings and cleaning materials. Most notably, the

YOM emissions from coating applications arise when solvent vanishes from the coating as it is

being placed onto the part, or even when solvents are being used during the final cleaning

process. It is important to state that the more efficient that a coating application technique is in

enabling a transfer of coatings to the metal furniture part, the volume of coatings needed during

productions decreases, which thereby results in lower YOM emissions4.

12
3.0 TECHNICAL FEASIBILITY OF CONTROLS

After reviewing the original 1977 CTG, all other associated revisions thereafter, and current state

and local regulations, the U.S. EPA proposed emission limits and work practices to control YOM

emissions from the coating catcgories involved in Consumer and Commercial Products, Group

III: Paper, Film, and Foil Coatings, Large Appliance Coatings, and Metal Furniture Coatings.

3.1 Paper, Film, and Foil Coatings

Common control techniques for reducing YOM emissions from paper, film, and foil surface

coatings include pollution prevention measures and the operation of emission capture and add-on

systems. Product substitution/reformulation is commonly used as a pollution prevention measure

in the paper, film, and foil surface coating industry to decrease YOM emissions from coatings.

Lower YOM content coatings, such as waterborne and higher solids contents coatings, or

coatings with no solvents may be used to reduce YOM emissions by reducing or eliminating the

organic solvent present in the coatings. Coating manufacturers have developed and are

continuing to develop waterborne and other alternative coating fornlUlations that replace

conventional organic solvent-based coatings. These coating are available for a number of

applications. However, for some pro~ucts, the currently available low-VOM coatings or coatings

with no solvent do not meet the performance requirements ofsome paper, film, and foil surface

coating operations.

When low-YOM content coatings cannot be used due to performance requirements calling for

higher YOM content coatings, YOM emissions from paper, film, and foil surface coating

operations can be reduced by the use of capture systems in conjunction with add-on control

systems that either destroy or recover the YOM in the exhaust streams. Add-on control devices

reduce the amount ofVOM emissions by either destruction or recovery with or without recycling

ofVOM collected from the exhaust streams. Two categories of add-on control devices are

typically used by paper, film, and foil industry: combustion (thermal or catalytic oxidation) and

recovery (adsorption and condensation). In general, oxidation and adsorption systems can

achieve destruction efficiency of greater than 95 percent as applied to surface coating application

13
operations with high and constant concentration ofVOM. Detailed infonnation on these control

technologies are contained in the U.S. EPA's CTG for paper, film, and foil coatings2

Pollution prevention is the most common emission control technique for reducing YOM

emissions from cleaning materials. Reducing the composite vapor pressure or YOM content of

the cleaning material used, either by substitution or fonnulation, is one ofthe pollution

prevention measures that is used to reduce YOM emissions from cleaning operations. However,

little infonnation is available regarding the types of low-YOM or YOM-free cleaning materials

that could be used in the paper, film, and foil surface coating industry.

The CTG for paper, film, and foil surface coatings recommended an overall YOM control

efficiency of 90% for each coating line that has a potential to emit at least 25 tpy of YOM from

coatings before the consideration of add-on controls. However, as an alternative to the 90%

overall control efficiency, the U.S. EPA recommends a limit of 0.20 kg YOM/kg (0.20 lb

VOM/lb) solids applied or 0.067 kg VOM/kg (0.067Ib VOM/lb) coatings applied for pressure

sensitive tape and label surface coating lines, and a limit of 0.40 kg YOM/kg (0.40 lb VOM/lb)

solids applied or 0.08 kg VOM/kg (0.08 Ib VOM/lb) coating applied for all other paper, film, and

foil surface coating lines. Table 1 summarizes the U.S. EPA's recommended RACT limits for

paper, film, and foil coatings.

These limits can be met through daily within-line averaging (i.e. averaging the YOM content of

materials used on an individual surface coating line each day).

The U.S. EPA recommends work practices to decrease YOM emissions for cleaning materials,

but nol the application of add-on controls (add-on controls would be too costly because the area

to be controlled is very large, and would thereby require a large volume of air to be captured and

directed to a control device). Typically, YOM emissions for cleaning materials come from the

mixing, storage, and handling of cleaning materials and cleaning-related waste materials. In

order to minimize the emissions, the following work practices can be employed: (l) place all

YOM-containing cleaning materials in closed containers; (2) guarantee that mixing and storage

containers used for YOM-containing materials are kept closed at all times except when

14
Table 1: RACT Limits for Paper, Film, and Foil Coatings

RACT Limits

Paper, Film, and Foil Surface

Units Pressure Sensitive Tape Coating (does not include

and Label Surface Coating Pressure Sensitive Tape and

Label Surface Coating)

Emission Reduction

90 90

(%)

kg VOMlkg solids (lb

0.20 0.40

VOM/lb solids)

kg VOMlkg coatings

0.067 0.08

(lb VOM/lb coatings)

depositing or removing these materials; (3) curtail spills ofVOM-containing cleaning materials;

(4) transfer YOM-containing cleaning materials from one location to another in closed containers

or pipes; and (5) reduce YOM emissions from cleaning ofstorage, mixing, and conveying

equipment.

3.2 Large Appliance Coatings

Several kinds of controls are available to industry to control YOM emissions from coatings and

the cleaning materials associated with this category. These available controls for coatings

include pollution prevention measures, such as product substitution/reformulation and work

practices, and emission capture and add-on control systems. The same types of available

controls would also apply to cleaning materials associated with large appliance coatings

operations.

For product substitution/reformulation, affected sources can use waterborne coatings, higher

solids solvent-borne coatings, and powder coatings to reduce YOM emissions through

decreasing or even eliminating the amount of organic solvent in the coatings. Several coating

15
manufacturers provide such environmentally-friendly product substitution/refollliulation

methods, which are easily convertible from the original solvent-borne coatings, and are generally

available. In addition to this, work practices may be used to reduce YOM emissions from

coatings during paint mixing, paint storage, and paint transfer operations. These work practices

include keeping coating supply lines, holding tanks, coating storage containers, or any such fluid

handling equipment well maintained to prevent spills, leaks, or other such problems that would

aggravate the amount of YOM released into the air. During mixing operations, mixing vessels

should have a top that prevents YOM emissions from being released into the air during the

agitation process, and mixed coatings and solvents should be stored in closed containers when

they are not being combined.

Emission capture and add-on control systems can also be used to reduce YOM emissions from

large appliance coating operations. The most common method for the destruction of YOM from

coatings is thennal oxidation, and can include the following: (I) direct, gas-fired, thennal

recuperative oxidation; (2) direct, gas-fired thennal regenerative oxidation; (3) direct, electrically

heated, thernlal regenerative oxidation; (4) direct, electrically heated, catalytic oxidation; and (5)

direct, gas-fired, catalytic oxidation. These add-on control systems can achieve a YOM control

efficiency between 80% and 98%, with thennal oxidation being the more preferred method for

YOM destruction. More infonnation concerning these add-on control systems available for large

appliance coatings can be found in the U.S. EPA's eTG for large appliance coatings3

.

Available control options for YOM emissions from cleaning materials associated with large

appliance coating operations are similar to those for coating operations, including pollution

prevention measures (e.g. product substitutionlrefonnulation and work practices) and emission

capture/add-on control systems. For product substitutionlrefonnulation, alternative cleaners,

such as alcohols and citrus-based cleaners, can be employed to restrict YOM emissions from

cleaning operations. An example of a work practice procedure that can be utilized to further

reduce YOM emissions from cleaning operations associated with large appliance coatings

operations involves nozzle maintenance, which is an integral part of any metal pre-treatment

system-an improperly maintained nozzle can lower spray impact and can distort spray systems,

and thereby reduce the cleaning efficiency. In addition, storing cleaning materials in covered

16
containers, minimizing the use of necessary cleaning materials, and collecting and placing

solvent-filled cleaning materials in closed containers after they are used can further prevent the

vaporization ofVOM into the air.

Along with the pollution prevention measures listed above, affected sources can use emission

capture and add-on control systems to control YOM emissions from cleaning operations for large

appliance coatings. These include carbon adsorption units or oxidizers.

The U.S. EPA believes that such recommendations will reduce YOM emissions from this

category by approximately 30%, which is a potential reduction of about 1,000 tons ofVOM from

the NAA facilities. The U.S. EPA assumes that most facilities will use low-YOM coating

materials, due to economic and/or financial reasons.

3.2.1 Emission Limits Based on Low-YOM Coatings

Tables 2 and 3 list the suggested U.S. EPA emission limits based on low-YOM coatings for onecomponent and multi-component general purpose coatings, as well as specific emission limits for

certain specialty coatings (both are separated into baked and air-dried coatings). Table 2

specifies limits in terms ofmass ofVOM per volume of coating (excluding water and exempt

compounds, as applied) and Table 3 specifies the equivalent limits in terms ofmass ofVOM per

volume ofsolids, as applied.

3.2.2 Optional Add-On Controls for Coating Operations

If a product's performance requirements or other needs require thc use of higher-VOM materials

than those listed in Tables 2 or 3, an affected source could choose to use add-on control

equipment to meet a 90% overall control efficiency. Add-on devices include oxidizers and

solvent recovery systems that, when joined with their YOM capture systems, would allow for the

source to achieve the 90% overall control efficiency. An affected facility could also combine

17
Table 2: Mass of VOM per Volume of Coating for Large Appliance Coatings

Coating type Baked Air Dried

kg/I lb/gal kg/I Ib/gal

General, One Component 0.275 2.3 0.275 2.3

General, Multi-Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Performance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

18
Table 3: Mass ofVOM per Volume of Solids for Large Appliance Coatings

Coating type Baked Air Dried

kg/l Ib/gal kg/I Ib/gal

General, One Component 0.40 3.3 0.40 3.3

General, Multi-Component 0.40 3.3 0.55 4.5

Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Perfonnance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.80 6.7

Metallic 0.80 6.7 0.80 6.7

Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

coatings and add-on control equipment on a coating unit to meet the recommended mass of

YOM limits, as listed in Tables 2 or 3.

19
3.2.3 Work Practices for Coating Operations and Cleaning Materials

Similar to the control options for cleaning materials operations from the paper, film, and foil

coatings subcategory, the U.S. EPA is recommending work practices to minimize YOM

emissions from large appliance coatings as well. These work practices are applicable to solvent

storage, mixing operations, and handling operations for coatings, thinners, cleaning materials,

and waste materials, and include the following: (1) store all YOM-containing coatings, thinners,

and cleaning materials in closed containers; (2) minimize spills ofVOM-containing coatings,

thinners, and cleaning materials; (3) clean up spills immediately; (4) convey any coatings,

thilmers, and cleaning materials in closed containers or pipes; (5) close mixing vessels that

contain YOM coatings and other materials except when specifically in use; and (5) minimize

usage ofsolvents during cleaning ofstorage, mixing, and conveying of equipment.

3.3 Metal Furniture Coatings

Similar to the available controls for the prior two subcategories, two basic emission control

techniques are available to reduce YOM emissions from metal furniture coatings: pollution

prevention measures, and emission capture and add-on control systems, pollution prevention

being the preferred technique used by most metal furniture coating sources.

A source may choose to substitute higher-solvent coatings with either powder coatings,

waterborne coatings, higher solids coatings, UV coatings, electrocoatings, and autophoretic

coatings, all of which have little or no solvents. Several manufacturers are slowly veering away

from using conventional organic solvent-borne coatings, and are replacing them with waterborne

and powder coating formulations. It is important to note that the currently available low-YOM

coatings or coatings with no solvents do not meet the performance requirements ofsome metal

furniture and cannot be viable options for the production ofthese products. Additionally,

utilizing more effective application equipment can reduce YOM emissions. Conventional air

atomized application systems have typical transfer efficiencies between 25-40% using high

atomizing air pressure. More modem technologies include electrostatic and high volume/low

pressure (HYLP) spray equipment, which can attain far greater transfer efficiencies, which

20
results in less dependence on YOM-containing materials. More information on these types of

spray applications can be found in the CTG for metal furniture coatings4

.

Along with pollution prevention measures, YOM emissions from metal furniture coating

operations can be reduced via the use of capture systems and add-on control devices, which

either destroy or recover the YOM in the exhaust stream. Examples of capture systems include

such simple components as hoods and enclosures, which collect solvent-filled air from process

vents (such as spray booths or bake oven vents) and/or fugitive emissions from the flash-off area,

and direct it to a control de,:iee. Control devices for the metal furniture coating industry include

combustion (thermal or catalytic oxidation) and recovery (adsorption and absorption). These

types of add-on control systems can reach a control efficiency of95% or greater. Recovered

solvents that cannot be reused can either be sold back to the solvent supplier or an independent

firnl that specializes in reclaiming contaminated solvents, or used as a fuel in coating boilers or

coating ovens; the latter option would require burner modifications to bum solvent, since many

coating ovens and boilers are gas-fired. Other control technologies, such as condensation,

biodegradation, and UV oxidation, are all applicable for YOM emissions control from metal

furniture coating operations, but are currently not widely used.

Pollution prevention is the most widely used emission control technique for decreasing YOM

emissions from cleaning materials related to metal furniture coating operations. An affected

source can reduce the composite YOM vapor pressure or YOM content ofthe cleaning material

being used by using low-YOM or YOM-free cleaning materials. In addition, work practice

procedures can be employed to reduce YOM emissions from cleaning material processes, and

they include the following:

• Cover mixing and storage vessels for YOM-containing cleaning materials, and

cleaning waste materials except when adding, removing, or mixing contents;

• Use closed containers or pipes to store and convey YOM-containing cleaning and

cleaning waste materials;

• Minimize spills ofYOM-containing cleaning and cleaning waste materials; and

• Minimize YOM emissions during cleaning operations.

21
3.3.1 Emission Limits Based on Low-VOM Coatings

The emission limits set forth in the U.S. EPA's CTG on metal furniture coatings are for onecomponent and multi-component general purpose coatings, as well as for certain specialty

coatings, all ofwhich are separated by baked and air-dried coatings. Tables 4 and 5 show YOM

limits for metal furniture coatings in mass per volume of coating and equivaleni limits in mass

per volume ofsolids, respectively.

These YOM content limits can be met through daily within-coating unit averaging (averaging the

YOM content ofmaterials used on a single surface coating unit each day). In addition, the U.S.

EPA is recommending that affected sources utilize one or more ofthe following application

methods: electrostatic application, high volume low pressure (HVLP) spray, flow coat, roller

coat, dip coat including electro-deposition, or other such coating application method that'is

capable of achieving a transfer efficiency equivalent or better than that which is achieved by

HVLP spraying. However, the U.S. EPA is recommending that the following kinds of coatings

and coating operations be exempt from the YOM content limits stated above: stencil coatings,

safety-induced coatings, solid-film lubricants, electric-insulating and thermal-conducting

coatings, touch-up and repair coatings, and coating application utilizing hand-held aerosol cans.

The limits set forth in Tables 4 and 5 are the same YOM content limits set forth for large

appliance coatings.

3.3.2 Add-On Controls for Coating Operations

The optional add-on controls for coating operations related to metal furniture production are the

same as those for large appliance coatings:

-a 90% overall control efficiency for add-on control equipment (including oxidizers and

solvent recovery systems; or

-a combination of coatings and add-on control equipment on a coating unit to meet the

recommended mass ofVOM per volume of coating solids limits.

22
Table 4: Mass of VOM per Volume of Coating (excluding water and exempt compounds)

for Metal Furniture Coatings

Coating type Baked Air Dried

kg/I Ib/gal kgll Ib/gal

General, One Component

0.275 2.3 0.275 2.3

General, Multi-Component 0.275 2.3 0.340 2.8

Extreme High Gloss 0.360 3.0 0.340 2.8

Extreme Perfonnance 0.360 3.0 0.420 3.5

Heat Resistant 0.360 3.0 0.420 3.5

Metallic 0.420 3.5 0.420 3.5

Pretreatment Coatings 0.420 3.5 0.420 3.5

Solar Absorbent 0.360 3.0 0.420 3.5

23
Table 5: Mass of YOM per Volume of Solids (as applied) for Metal Furniture Coatings

Coating type Baked Air Dried

kg/l Ib/gal kg/l Ib/gal

General, One Component 0.40 3.3 0.40 3.3

General, Multi-Component 0.40 3.3 0.55 4.5

Extreme High Gloss 0.61 5.1 0.55 4.5

Extreme Performance 0.61 5.1 0.80 6.7

Heat Resistant 0.61 5.1 0.80 6.7

Metallic 0.80 6.7 0.80 6.7

Pretreatment Coatings 0.80 6.7 0.80 6.7

Solar Absorbent 0.61 5.1 0.80 6.7

3.3.3 Work Practices for Coating Operations and Cleaning Materials

To further reduce YOM emissions from metal furniture surface coating-related activities, the

CrG recommends instilling the following work practices: (I) store all YOM-containing coatings,

thinners, and coating-related waste materials in closed containers; (2) ensure that mixing and

24
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 of YOM-containing coatings, thinners, and coating-related waste materials; and

(4) convey YOM-containing coatings, thinners, and coating-related waste materials from one

location to another in closed containers or pipes. While work practices are extremely favorable

to the goal ofreducing YOM emissions, it is important to note that YOM reductions may not be

quantifiable.

As for cleaning materials associated with metal furniture coating operations, the U.S. EPA's

eTG simply recommends work practices such as: (1) closed container storage of all YOMcontaining cleaning materials and used shop towels; (2) ensure that mixing and storage

containers used for YOM-containing cleaning materials remain closed at all times except when

depositing or removing such materials; (3) minimize spills of YOM-containing cleaning

materials; (4) convey YOM-containing cleaning materials from one area to another in closed

containers or pipes; and (5) minimize YOM emissions from cleaning ofstorage, mixing and

conveying equipment.

25
4.0 ECONOMIC REASONABLENESS

The Illinois EPA relied on the U.S. EPA's economic analysis included in the respective CTGs to

determine the economic costs and impacts associated with the control ofVOM emissions from

paper, film, and foil coatings; metal furniture coatings; and large appliance coatings operations in

Illinois' NAAs.

4.1 Paper, Film, and Foil Coatings

In order to calculate the approximate costs that are associated with the add-on control

recommendation set forth in the paper, film, and foil coatings CTG, the U.S. EPA assumed that

about 47% ofthe facilities in the 2002 National Emissions Inventory (NEI) database (119

facilities) were currently in compliance with the 2002 National Emission Standards for

Hazardous Air Pollutants (NESHAP). Based on the average number of coating lines per facility

classified in Table 2 ofthe CTG that had a potential to emit 25 tpy ofVOM or greater before

consideration of add-on controls, the total annual cost was about $24.5 million per year.

Furthermore, iffacilities that exceed. the emission thresholds and that are located in NAAs

utilized the 90% emission reduction, it would create an emission reduction 20,800 tpy. With this

in mind, the CTG states that the expected cost-effectiveness ofimplementing the CTG's

approaches to control YOM emissions would be about $1,200 per ton. For cleaning materials

associated with this category, the U.S. EPA believes that the application of add-on controls

would be a costly alternative for decreasing YOM emissions because the area that would be

controlled has a large volume of air that would be captured and directed to a control device.2

4.2 Large Appliance Coatings

When suggesting control options, the U.S. EPA assumed that all facilities would choose to use a

low-YOM coating materials alternative. This was made for two reasons: I) complying lowYOM coating materials are already available on the market at a cost that is not much greater than

the cost of coating materials with higher YOM contents; and 2) the use of add-on controls to

reduce YOM emissions from average spray coating operations would be a more costly

26
allernative. By applying the emission limits based on low-YOM coatings, the 90% overall

control efficiency, as well as utilizing thc work practices associated with cleaning materials from

such operations, the U.S. EPA believes that the cost-effectiveness for a medium sized facility

that uses waterborne prime and higher solids topcoat would be approximately $425 per ton in

2006 dollars. However, the 2002 NESHAP presented a control cost of$480,000 for

approximately 1,000 tons of HAP reduction from 74 facilities anticipated to be subject to the mle

($480 per ton ofHAP reduced in 2006 dollars). Therefore, for the purpose of establishing costeffectiveness for YOM emissions control from applicable NAA sources, the U.S. EPA

approximates a cost of about $500 per ton ofYOM reduced, and a total annual cost ofthe 1,000

tpy of emissions reduction to be $500,0003

4.3 Metal Furniture Coatings

Using the 2002 NEI database to estimate the number of metal furniture manufacturing sources,

the U.S. EPA approximated that there were a total of 456 metal furniture facilities nationally.

Out ofthese 456 facilities, it was estimated that there were about 289 facilities in ozone NAAs,

and that 143 ofthose 289 emitted at or beyond the 15 Ib/day YOM emissions threshold. Similar

to the eTG for large appliance coatings, the U.S. EPA assumed that all facilities would choose to

use a low-YOM coating materials alternative. This was made for two reasons: 1) complying

low-YOM coating materials are already available on the market at a cost that is not much greater

than the cost of coating materials with higher YOM contents; and 2) the use of add-on controls to

reduce YOM emissions from average spray coating operations would be a more costly

alternative. In accordance with studies that were carried out for the 2003 NESHAP, the cost to

implement the control alternatives from the U.S. EPA's eTG for this category averaged across

all sizes offacilities was as high as $1,670 per facility. For the 143 facilities mentioned

previously that exceeded the 15 Ib/day applicability threshold, total annual costs were estimated

to be approximately $240,500; such an implementation will result in a 35% (l ,200 tpy) reduction

in YOM emissions from metal furniture coatings. U.S. EPA calculated the cost effectiveness to

be about $200 per ton in YOM emissions reduction.

27
5.0 EXISTING AND PROPOSED REGULATIONS

The Il1inois EPA reviewed the control techniques recommended in the CTOs to control YOM

emissions from coating operations. These recommendations were then compared to current

Illinois EPA regulations and the corresponding Illinois EPA inventory to determine if proposed

changes needed to be made, such that they would be mirrored with U.S. EPA requirements.

5.1 EXISTING REGULATIONS

Currently, Il1inois EPA regulates YOM emissions from various surface coating operations

including paper, film, and foil; metal furniture; and large appliance coating operations in the

Illinois' NAAs (Chicago and Metro-East).

5.1.1 Paper, Film and Foil Coatings

Parts 218 and 219 of35 Ill. Adm. Code5 contain specific regulations for controlling YOM

emissions from paper, film, and foil coatings. YOM content limitations are prescribed for paper

coating operations that emit 15 Ib/day or more of YOM from all associated coating operations.

Table 6 shows the existing YOM content limits for paper coatings.

Table 6: Existing YOM Content Limits for Paper Coatings

Compliance Date Limitation

kg/l lblgal

Prior to March 15, 1996 0.35 2.9

On and After March 15, 1996 0.28 2.3

Alternatively, sources may install and operate YOM capture and control systems that provide

81 % reduction in overall YOM emissions, and the control device must achieve 90% efficiency

28
(control devices include afterburner, carbon adsorption, condensation, or absorption scrubber

system).

5.1.2 Large Appliance Coatings

Specific regulations for large appliance coatings are located in Subpart F of35 Ill.

Administrative Code Palts 218 and 219. The applicable threshold for the total actual

uncontrolled YOM emissions from all large appliance coating operations is 15 Ibs/day or more.

Furthermore, lllinois EPA does not distinguish between different coating types, and instead

divides between a baked and air-dried coating operation that has a compliance date before or

after March 15, 1996. Table 7 shows the existing YOM content limits for large appliance

coatings in Illinois' NAAs.

Table 7: Existing YOM Content Limits for Large Appliance Coatings

Compliance date Baked Air Dried

kg/I Ib/gal kg/I Ib/gal

Until March 15, 1996 0.34 2.8 0.34 2.8

On and After March 15, 1996 0.28 2.3 0.34 2.8

As an alternative to compliant coatings, the rule provides an add-on control option that requires a

coating line to be equipped with a capture system and control device that provides an 81 %

reduction in overall YOM emissions, and the control device (i.e. afterburner, carbon adsorption,

condensation, or absorption scrubber system) achieves a 90% efficiency.

29
5.1.3 Metal Furniture Coatings

Regulations for metal furniture coating operations are very similar to the regulations for large

appliance coatings, except with regard to the YOM emission limits for baked or air-dried metal

furnitme coatings until March 15, 1996:

Table 8: Existing Metal Furniture Coatings Limits

Compliance date Baked Air Dried

kg/l Ib/gal kg/l Ib/gal

Until March 15, 1996 0.36 3.0 0.36 3.0

On and After March 15, 1996 0.28 2.3 0.34 2.8

5.2 PROPOSED REGULATIONS

Illinois EPA is proposing amendments to Parts 218 and 219 of35 Ill. Adm. Code to control

YOM emissions from paper coating, metal furniture coating, and large appliance coating. The

control requirements are consistent with the recommendations contained in the 2007 CTGs. The

proposed compliance date to comply with the regulations is on and after May I, 2011.

5.2.1 Paper, Film and Foil Coatings

Illinois EPA is not proposing any change to the applicability threshold of 15 Ib/day or more for

control requirements for paper coating. However, Illinois EPA is proposing to specify the YOM

content limits of paper coating in lb (kg) ofVOM per Ib (kg) ofsolids and equivalent YOM

limits in kg (lb) ofVOM per kg (lb) of coating. Except for pressure sensitive tape and label

surface coating, the YOM limits are equivalent to the existing YOM limits for paper coating.

Table 9 shows the proposed YOM limits for paper coatings.

30
Table 9: Proposed Limits for Paper Coatings

Units Proposed Limits

Pressure Sensitive Paper, Film, and Foil Coatings (not

Tape and Label including Pressure Sensitive Tape and

Surface Coatings Label)

kg YOMlkg solids

0.20 0.40

(lb YOM/lb solids)

kg YOM/kg coatings

0.067 0.08

(Ib YOMllb coatings)

Affected sources may use add on capture and control systems to comply with the YOM content

limits ofthe coatings. Illinois EPA is proposing to increase the overall control efficiency

standards to 90 percent from the existing 81 percent overall control efficiency ofthe add-on

capture and control systems.

In addition, the Illinois EPA is proposing to add Section 218.218: Work Practice Standards for

Paper Coatings to include the following standards for cleaning materials from applicable sources

related to this category on and after May 1, 2011:

I) Store all YOM-containing cleaning materials in closed containers;

2) Ensure that mixing and storage containers used for YOM-containing

materials are kept closed at all times except when depositing or removing

such materials;

3) Minimize spills of YOM-containing cleaning materials;

4) Convey YOM-containing cleaning materials from one location to another

in closed containers or pipes; and

5) Minimize YOM emissions from the cleaning ofstorage, mixing, and

conveying equipment.

31
5.2.2 Large Appliance Coatings

The Illinois EPA is not proposing any change to the applicability requirement of IS Ib YOM/day

or more for the control requirements for large appliance coatings. The proposed regulations

specify separate YOM content limits for one-component and multi-component general purpose

coatings. Also, the proposed regulations provide specific emission limits for certain specialty

coatings. For each ofthese coating types, Illinois EPA is proposing separate emission limits for

baked and air-dried coatings. Depending on the type of coating, the YOM limits vary from 2.3

lb/gal (0.275 kg/I) to 3.5 Ib/gal (0.42 kg/I). Table 2 ofsection 3.2.1 contains the various

emission limits expressed in terms of mass of YOM per volume of coating for large appliance

coatings that JIlinois EPA is proposing and Table 3 ofsection 3.2.1 contains the equivalent

emission limits expressed in mass/volume ofsolids.

The proposed regulations require the use of one or more ofthe following application methods:

electrostatic application, HVLP spray, flow coat, roller coat, dip coat including electrodeposition,

or other coating application method, with approval ofthe Illinois EPA, capable of achieving a

transfer efficiency equivalent or better than achieved by HVLP spraying.

In addition, the proposed regulations provide that stencil coatings, safety-indicating coatings,

solid-film lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair

coatings, or coating applications utilizing hand-held aerosol cans are exempt from YOM content

limits.

Affected sources may use add-on capture and control systems to comply with the YOM content

limits ofthe coatings. Illinois EPA is proposing to increase the overall control efficiency

standard to 90 percent from the existing 81 percent overall control efficiency.

Also, the Illinois EPA is recommending the following work practice standards for large

appliance coatings:

1) Store all YOM-containing coatings, thinners, coating-related waste

materials, cleaning materials, and used shop towels in closed containers;

32
2) Ensure that mixing and storage containers used for YOM-containing

coatings, thinners, coating-related waste materials, and cleaning materials

are kept closed at all times except when depositing or removing such

materials;

3) Minimize spills of YOM-containing coatings, thinners, coating-related

waste materials, and cleaning materials, and clean up spills immediately;

4) Convey YOM-containing coatings, thinners, coating-related waste

materials, and cleaning materials from one location to another in closed

containers or pipes; and

5) Minimize YOM emissions from the cleaning ofstorage, mixing, and

conveying equipment.

5.2.3 Metal Furniture Coatings

The proposed applicability, YOM limits, add-on control device efficiency, and work practices

requirements for metal furniture coatings are identical to the proposed regulations for large

appliance coatings.

33
6.0 AFFECTED SOURCES and YOM EMISSIONS REDUCTIONS

l1linois EPA reviewed its emissions inventory database to identify any potentially affected

sources ofthe proposed regulations. There are a total of 22 sources in the Chicago NAA and two

in the Metro-East NAA potentially affected by the proposed regulations. Out of22 sources in

the Chicago NAA, 16 sources have paper coating operations and six have metal furniture coating

operations. Two sources in the Metro-East NAA have paper coating operations. There are no

large appliance coaters in either the Chicago or the Metro-East NAAs.

The Illinois EPA reviewed the 2005 YOM emissions inventory and determined that seven

sources in the Chicago NAA comply with the paper coating regulations by using add-on capture

and control systems. All other affected sources use compliant coatings to comply with the

regulations. The Illinois EPA believes that no new add-on capture and control systems will be

installed to meet the proposed regnlations. Rather, the Illinois EPA ex,pects that affected sources

will continue to use compliant coatings, or upgrade their existing add-on capture and control

systems to meet the proposed YOM emission limits. Table 10 shows the estimated YOM

emissions reductions and Table II lists the affected sources.

Table 10: YOM Emission Reductions in the Chicago and Metro-East NAAs

Number of Sources

2005 YOM Emissions

Category Non-attainment areas

Total Reduction

Chicago Metro-East

(TPY) (TPY)

Paper, Film and Foil Coatings 16 2 109.83 21.45

Large Appliance Coatings None None 0 0

Metal Furniture Coatings 6 None 89.4 0

TOTAL 22 2 199.23 21.45

34
Table 11: List of Affected Sources in the Chicago and Metro-East NAAs

1.0. Number Name of the Facility

031030ACM Replogle Globes Corp.

031186AHL Mecalux USA Inc

031600BPK Edsal Mfg Co Inc

031600EDF Marvel Group Inc

031600GCL Dentalez Alabama Corp

11101SABO Knaack LLC

03101SAAM Akan Packaging Food and Tobacco

Inc

031030ABQ Lithographic Industries

0310S1AFP Microcosm

031081ACU Tapecoat Company Inc

031198ABP Sun Process Converting Co

031198ABW Stimsonite Corp

031288ABA Federal-Mogul Corp

031600BGU Color Communication Inc

031600BUF Chicago Steel container Corp

04300SAJS Rollprint Packaging Product

04300SAMQ Pres-on Tape and Gasket Corp

08903SAAK Olon Industries Inc

089438ADW Printpack Inc

09700SABB Nu-way Speaker Products Inc

111010AAT Flcxicon Inc

163010AEZ Weyerhaeuser Co

163806AAA Hexacomb Corp

1970S0AAK Panduit Corp

35
7.0 REFERENCES

1. The Clean Air Act as amended in 1990 (42U.S.C. Section 7401 etseg.).

2. U.S. EPA. "Control Technique Guidelines for Paper, Film, and Foil Coatings". EPA

453/R07-003, September 2007.

3. U.S. EPA. "Control Technique Guidelines for Large Appliance Coatings". EPA-453/R07-004, September 2007.

4. U.S. EPA. "Control Technique Guidelines for Metal Furniture Coatings". EPA-453/R07-005, September 2007.

36
B 2
ILLINOIS POLLUTION CONTROL BOARD

November 5, 2009

IN THE MATTER OF: )

)

REASONABLY AVAlLABLE CONTROL )

TECHNOLOGY (RACT) FOR VOLATILE )

ORGAJ'lIC MATERIAL EMISSION FROM )

GROUP III CONSUMER & COMMERCIAL )

PRODUCTS: PROPOSED AMENDMENTS TO )

35 ILL. ADM. CODE 218 AND 219 )

Proposed Rule. First Notice.

RIO-IO

(Rulemaking - Air)

OPINION AND ORDER OF THE BOARD (by A.S. Moore)

On October 23, 2009, the Illinois Environmental Protection Agency (Agency or Illinois

EPA) filed a rulcmaking proposal (Prop.) pursuant to Sections 10,27, and 28.5 ofthe

Environmental Protection Act (Act). See 415 ILCS 5110,27 (2008); Public Act 96-0308, eff.

Aug. 11,2009 (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 proposed regulatory language.

. The Agency states that it seeks to satisfy Illinois' obligations under the federal Clean Air

Act (CAA). SR at I, citing 42 U.S.c. § 7401 et seq. The Agency further states that "the

rulemaking is intended to satisfy minois' 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 area designated as nonattainment with respect to the ozone

National Ambient Air Quality Standard (NAAQS)." SR at 1, citing 42 U.S.c. §§ 7502, 7511a.

The Agency states that in ozone nonattainment areas, "the State must revise its SIP to include

RACT [reasonably available control technology] for sources ofVOM emission 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. § 7511 a(b)(2). Specifically, the Agency proposes YOM

emission controls in response to CTGs issued on October 9, 2007, for the following Group III

Consumer and Commercial Product Categories: paper, film, and foil coatings; metal furniture

coatings; and large appliance coatings. SR at 1,4, citing 72 Fed. Reg. 57215-18.

The Agency filed this proposal pursuant to the "fast-track" rulemaking provisions of

Section 28.5 of the Act (P.A. 96-0308), and the Board accepts the proposal for hearing. Section

28.5 requires the Board to proceed toward adoption of the proposed regulations by meeting a

series ofstrict deadlines. The Act provides the Board no discretion to extend those deadlines.

See generally P.A. 96-0308.

The first of those strict deadlines provides that the Board must within 14 days of

receiving the proposal must file the proposed rule for first notice under the lllinois

Administrative Procedure Act (5 ILCS 10011-1 et seq. (2008». P.A. 96-0308 (subsection (e».

Section 28.5(m) provides that "[t]he Board shall not revise or otherwise change an Agency fast-
2

track rulemaking proposal without agreement of the Agency until after the end of the hearing and

comment period. Any revisions to the Agency proposal shall be based on the record ofthe

proceeding." Id. (subsection (t)). Therefore, the Board today accepts the proposal without

commenting on its substantive merits and directs the Clerk to cause publication of the proposed

rule for first notice in the Illinois Register.

In the same 14-day period, the Board must also schedule and provide notice ofthree

hearings, "each of which shall be scheduled to continue from day to day, excluding weekends

and State and federal holidays, until completed." P.A. 96-0308 (subsections (e), (I)). Within 55

days ofreceiving the proposed rule, the Board must hold a first hearing "confined to testimony

by and questions of the Agency's witnesses concerning the scope, applicability, and basis of the

rule." P.A. 96-0308 (subsection (g)(I)). Then, "[w]ithin 7 days after the first hearing, any

person may request that the second hearing be held." Id. 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 (g)(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 other parties."

P.A. 96-0308 (subsection (g)(3)). The Board will cancel the third hearing "ifthe Agency

indicates to the Board that it docs not intend to introduce any additional material." Id.

Accordingly, the Board directs the hearing officer expeditiously to schedule all hearings

in this proceeding according to the following statutory deadlines:

First Notice

First Hearing

Second Hearing

Third Hearing

Second Notice

Final Filing

on or before Friday, November 6, 2009 (P.A. 96-0308 (subsection

(I))

on or before Thursday, December 17, 2009 (P.A. 96-0308

(subsection (1)(1))

on or before Monday, January 18,2010 (P.A. 96-0308 (subsection

(1)(2); see 35 Ill. Adm. Code 101.300(a) (State holiday for Martin

Luther King Day))

on or before Monday, February 1,2010 (P.A. 96-0308 (subsection

(g)(3))

on or before Tuesday, March 2, 2010, "ifno third hearing is held,"

or Monday, March 22, 2010, "ifthe third hearing is held" (P.A. 96-

0308 (subsection (e))

within 21 days of "receipt of a statement of no objection to the rule

from the Joint Committee on Administrative Rules" (PA 96-0308

(subsection (0)).

As noted above, a "Motion for Waiver of Copy Requirements" accompanied the

Agency's rulemaking proposal. The Agency's motion first notes that the Board's procedural

rules require it to filc an original and nine copies of its proposal. Mot. at I, citing 35 Ill. Adm.

Code 102.200. Citing the length of its proposal, the Agency "requests that the Board waive the

normal copy requirements and allow Illinois EPA to file the original and four complete copies of
3

the documents." Mot. at I. The Agency further notes that the Act requires it to provide

materials supporting its proposal. Id., citing 415 ILCS 51271(a) (2008). The Agency argues that

it relied on two documents, the Act and the CAA, which "are readily accessible to or are within

the possession ofthe Board." Mot. at 1-2, citing 42 U.S.c. § 7401 et seq.; 415 ILCS 5/1 et seq.

(2008). Stressing that accessibility, the Agency "moves that the Board waive the requirement

that the Illinois EPA provide copies ofsuch documents." Mot. at 1-2. The Agency states that it

has provided the Board copies ofthree other documents on which it directly relied in drafting its

proposal. !d. at 2 (listing three CTGs).

Section 101.500(d) ofthe Board's procedural rules provides, in pertinent part, that,

[w]ithin 14 days after service of a motion, a party may file a response to the

motion. If no response is filed, the party will be deemed to have waived objection

to the granting of the motion, but the waiver of objection does not bind the Board

or the hearing officer in its disposition of the motion. Unless undue delay or

material prejudice would result, neither the Board nor the hearing officer will

grant any motion before expiration ofthe 14 day response period...." 35 Ill.

Adm. Code 101.500(d).

As noted above, Section 28.5 ofthe Act requires the Board's rulemaking activities to

follow a series ofstrict deadlines in scheduling and conducting hearings and issuing its opinions

and orders. Under these circumstances, undue delay would result from allowing the full 14-day

response period to run. See 35 Ill. Adm. Code 101.500(d).

Having reviewed the substance ofthe motion and in the absence to date of any objection,

the Board grants the Agency's motion. The Board allows the Agency to file the original and four

complete copies the documents comprising its rulemaking proposal. In addition, the Board

waives the requirement that the Agency provide copies ofthe CAA and the Act.

ORDER

The Board directs the Clerk to cause the publication ofthe following rule for first notice

in the Illinois Register.

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSIONS STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART2l8

ORGANIC MATERIAL EMISSION STANDARDS AND

LIMITATIONS FOR THE CHICAGO AREA
B 3
ILLINOIS POLLUTION CONTROL BOARD

November 5, 2009

IN THE MATTER OF: )

)

REASONABLY AVAILABLE CONTROL )

TECHNOLOGY (RACT) FOR VOLATILE )

ORGANIC MATERIAL EMISSION FROM )

GROUP ill CONSUMER & COMMERCIAL )

PRODUCTS: PROPOSED AMENDMENTS TO )

35 ILL. ADM. CODE 218 AND 219 )

RIO-IO

(Rulemaking - Air)

RECEIVED

CLERK'S OFFICE

NOV 052009

STATE OF ILUNOIS

Pollution Control Board

NOTICE OF HEARINGS

DATES, TIMES, AND LOCATIONS

FIRST HEARING: WEDNESDAY, DECEMBER 9, 2009, TO BE

CONTINUED DAY-TO-DAY UNTIL BUSINESS

IS COMPLETE

10:00 AM

James R. Thompson Center

100 W, Randolph St.

Pollution Control Board Conference Room 11-512

Chicago, lllinois

SECOND HEARING (IF NECESSARy): WEDNESDAY, JAJ'WARY 6, 2010, TO BE

CONTINUED DAyoTO-DAY UNTIL BUSINESS

IS COMPLETE

10:00 AM

Michael A. Bilandic Building

160 N, LaSalle Street

Room N-505

Chicago, Illinois

THIRD HEARING (IF NECESSARY):

10:00 AM

Michael A. Bilandic Building

160 N. LaSalle Street

RoomN-505

WEDNESDAY, JANUARY 20, 2010, TO BE

CONTINUED DAY-TO-DAY UNTIL BUSINESS

IS COMPLETE
2

Chicago, Illinois

PURPOSE OF HEARINGS:

ATTENDING BOARD MEMBER:

HEARING OFFICER:

Merit and Economic

Andrea S. Moore

Timothy J. Fox

HEARING OFFICER ORDER

Statutory Requirements

The Illinois Environmental Protection Agency (Agency) filed this rulemaking proposal

pursuant to authorities including the newly re-enacted Section 28.5 ofthe Environmental

Protection Act (Act). See Public Act 96-0308, eff. Aug. 11, 2009 (PA 96-0308) (reenacting

repealed Section 28.5). That provision requires the Board to proceed toward adoption ofthe

proposed regulation by meeting a series ofstrict deadlines. The Board has applied those

deadlines to this proceeding in its opinion and order ofNovember 5, 2009, and in this notice of

hearing and order.

Section 28.5 specifies the timing and purpose for each hearing and establishes other

procedural requirements. Section 28.5(f)(1) provides that "[t]he first hearing shaH be held 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 request that the sccond hearing be held." P.A. 96-0308.

Section 28.5(f)(1 )(A) provides in pertinent part that "[i]f, after the first hearing, the

Agency and affected entities are in agreement on the rule, the United States Environmental

Protection Agency has not informed the Board of any unresolved objection to the rule, and no

other interested party contests the rule or asks for the opportunity to present additional evidence,

the Board may cancel the additional hearings." P.A. 96-0308. Section 28.5(f)(l)(B) provides in

pertinent part that

[i]f, after the first hearing, the Agency and affected entities are in agreement upon

a portion ofthe rule, the United States Environmental Protection Agency has not

informed the Board of any unresolved objection to that agrced portion ofthe rule,

and no other interested party contests the agreed portion ofthe rule or asks for the

opportunity to present additional evidence, the Board must proceed to the second

hearing, ... but the hearing shall be limited in scope to the unresolved portion of

the proposal. ld.

Section 28.5(f)(2) provides that, ifit is 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 oftestimony, documents, and comments by affected entities and aH other interested

parties." PA 96-0308. Section 28.5(f)(3) provides that, ifit is necessary,
3

[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 response to

the material submitted at the second hearing and to any response by other parties.

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(f) provides that "[t]he Board must require the written submission of all

testimony at least 10 days before a hearing, with simultaneous service to all participants of

record in the proceeding as of 15 days prior to 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 after the availability ofthe transcript." P.A. 96-0308.

Section 28.5(n) provides that

[t]he Board must complete a fast-track rulemaking by adopting a second notice

order no later than 130 days after receipt ofthe proposal ifno third hearing is held

and no later than 150 days ifthe third hearing is held. Ifthe order includes a rule,

the Illinois [Pollution Control] Board must file the rule for second notice under

the Illinois Administrative Procedure Act within 5 days after adoption ofthe

order. P.A 96-0308; see 5 ILCS 100/5-40 (2008).

Also, Section 28.5(0) provides that, "[u]pon receipt of a statement ofno objection

to the rule from the Joint Committee on Administrative Rules, the Board must adopt the

final order and submit the rule to the Secretary of State for publication and certification

within 21 days." PA 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, December 9, 2009, and is not subject to continuation or cancellation by the Board.

The second and third hearings, ifneeessary, will begin on the dates listed above in the notice of

hearings. At the second hearing, participants may offer testimony or comment on the Board's

request to the Department ofCommerce and Economic Opportunity for an economic impact

study. See 415 ILCS 5/27(b) (2008).

Service and Notice Lists

The Board will establish a notice list and a service list for this proceeding. All persons on

the notice list will receive notice of all Board actions and hearing officer orders. 35 Ill. Adm.

Code 102.422(a).

Under Section 102.422(b) ofthe Board's procedural rules,
4

[t]he hearing officer may establish a service list for any regulatory proceeding, in

addition to the notice list. The hearing officer may direct participants to serve

copies of all documents upon the persons listed on the service list. ... For

purposes offast-track rulemakings under Section 28.5 ofthe Act, participants of

record will be the individuals on the service list. 35 m. Adm. Code I02.422(b).

In addition to receiving notice of all Board actions and hearing officer orders, persons on the

service list will receive pre-filed testimony and other filings in this proceeding. The service list

is intended for persons such as those who will be testifYing and participating actively in this

rulemaking.

The Board notes that the Agency's proposal included a Technical Support Document

(TSD), Table 11 ofwhich lists 24 potentially affected sources. TSD at 34-35. The Board begins

this rulemaking proceeding by including in the Notice List each ofthe 24 sources listed in Table

11 ofthe Agency's TSD. While the Board will mail a copy ofthe Board's November 5, 2009,

order and this hearing officer order to each ofthose 24 sources, the Board will provide copies of

any subsequent opinions and orders only to those who specifically indicate that they wish to

remain on either the Service List or Notice List for this proceeding. Any entity wishing to

remain on the Service List or Notice List must provide the information requested in the form

attached to this order as Attachment A to the Board by Friday, November 20, 2009.

In order to clarify the record in this proceeding, Attachment B to this order contains the

names, mailing addresses, and contact names for each ofthe 24 entities listed by the Agency iu

Table II ofits TSD and to each ofwhich the Board has mailed its November 5, 2009, order and

this hearing officer order.

Note that, through the Clerk's Office On-Line (COOL) on the Board's Web site

(www.ipcb.state.il.us).personscanrequesttoreceiveelectronicnotification.This "enotification" 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 of charge. Also through COOL, pre-filed testimony, public comments, and other filings are

available generally for viewing and downloading. One exception to this availability may be

voluminous filings, which will nonetheless be available upon request to the Clerk's office. With

the access to filings provided by COOL, persons who are not on the service list and wish to file

only a public comment need not serve their comments on the service list in this proceeding.

Pre-Filing Testimony

As noted above, Section 28.5(1) provides strict deadlines for pre-filing tcstimony. In a

"fast-track" rulemaking, "[t]he Board must require the written submission ofall testimony at

least 10 days before a hearing, with simultaneous service to all participants ofrecord in the

proceeding as of 15 days prior to hearing, unless a waiver is granted by the Board for good

cause." PA 96-0308 (emphasis added).

Service Lists
5

For purposes ofserving pre-filed testimony, the service list for the fIrst hearing will close

on Tuesday, November 24, 2009; the service list for the second hearing will close on Tuesday,

December 22, 2009; and the service list for the third hearing will close on Tuesday, January 5,

2010. Any person who submits a fax or e-mail request to be added to the service list to the

hearing officer by 4:30 PM on or before those three deadlines will be added to the service list for

the remaining hearing or hearings. The service list for any ofthe three hearings will be available

after 9:30 AM on the day following each offue three deadlines.

First Hearing

For the fIrst hearing, pre-filed testimony must be served on all persons on the service list

as of4:30 PM on Tuesday, November 24, 2009. Persons wishing to pre-file testimony for the

first hearing may obtain a copy ofthe service list by contacting the hearing officer after 9:30 AM

on Wednesday, November 25, 2009. Because ofthe State Thanksgiving holidays on Thursday,

November 26,2009, and Friday, November 27,2009, all pre-filed testimony for the first hearing

must be submitted nO later than Wednesday, November 25, 2009. 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 on the Board, the ''mailbox rule" at 35 m. Adm. Code 101.300(c) does not apply.

The Board's Clerk must receive this pre-filed testimony before the close ofbusiness on

Wednesday, November 25,2009. Although pre-fIled testimony maybe filed electronically

through COOL, all electronic or approved fax fIlings must be received by the Clerk's Office no

later than 4:30 PM on that date.

Second Hearing

For the second hearing, pre-filed testimony must be served on all persons on the service

list as of4:30 PM on Tuesday, December 22, 2009. Persons wishing to pre-fIle testimony for the

fIrst hearing may obtain a copy ofthe service list by contacting the hearing offIcer after 9:30 AM

on Wednesday, December 23,2009. Because ofthe State Christmas holiday on Friday,

December 25,2009, all pre-filed testimony for the second hearing must be submitted no later

than Thursday, December 24, 2009. See P.A. 96-0308 (requiring pre-filing at least 10 days

before hearing). For the purpose ofserving pre-filed testimony for the second hearing on the

Board, the "mailbox rule" at 35 TIl. Adm. Code 101.300(c) does not apply. The Board's Clerk

must receive this pre-fIled testimony before the close ofbusiness on Thursday, December 24,

2009. 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 later than 4:30 PM on that date.

Third Hearing

For the third hearing, pre-filed testimony must be served on all persons on the service list

as of 4:30 PM on Tuesday, January 5, 2010. Persons wishing to pre-file testimony for the fIrst

hearing may obtain a copy ofthe service list by contacting the hearing offIcer after 9:30 AM on

Wednesday, January 6,2010. All pre-filed testimony for the third hearing must be submitted no

later than Friday, January 8, 2010. See PA 96-0308 (requiring pre-filing at least 10 days before
6

hearing). For the purpose ofserving pre-filed testimony for the third hearing on the Board, the

"mailbox rule" at 35 Ill. Adm. Code 101.300(c) does not apply. The Board's Clerk must receive

this pre-filed before the close ofbusiness on Friday, January 8, 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 later than 4:30 PM on that date.

IT IS SO ORDERED.

Hearing Officer

Illinois Pollution Control Board

100 West Randolph Street, Suite 11-500

Chicago, Illinois 6060I

(312) 814-6085

(312) 814-3669 (fax)

foxt@ipcb.state.il.us
7

ATTACHMENT A

To Hearing Officer Order ofNovember 5, 2009

Reasonably Available Control Technology (RACY) for Volatile Organic Material Emissions from Group

ill Consumer & Commercial Products: Proposed Amendments to 35 TIl. Adm. Code 218 and 219

(RIO-IO)

I wish to added to the (please check one)

Service List

Notice List

in the minois Pollution Control Board rulemaking proceeding listed above:

Name

Organization or Company

Address

City, State, Zip

PLEASE SUPPLY TIDS INFORMATION BY FRIDAY, NOVEMBER 20, 2009 TO:

Lynn Patras

E-mail:

patl'asl@ipcb.state.il.us

Fax:

312-814-3669

Mail:

100 W. Randolph St., Suite 11-500

James R. Thompson Center

Chicago, lllinois 60601
8

ATTACHMENTB

To Hearing Officer Order ofNovember 5, 2009

Reasonably Available Control Technology CRACT) for Volatile Organic Material Emissions from Group

III Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 218 and 219

(RIO-IO)

Potentially Affected Sources in Illinois Non-Attainment Areas for

Consumer and Commercial Products. Group III

Company Name Street Address City Zip Company Contact

Code

Replogle Globes Inc 2801 S 25th Ave Broadview 60153 Edward

Dieschbourg

Mecalux USA Inc 1600 N 25th Ave Melrose 60160 Ada Whitaker

Park

Edsal Mfg Co Inc 4400 S Packers Ave Chicago 60609 Bruce Murray

Marvel Group Inc 3843 W 43rd St Chicago 60632 Dane Nakashima

Nevin Laboratories Inc 5000 S Halsted St Chicago 60609 John Denman

Clarin Div Of 927 N Shore Dr Lake Bluff 60044 Greg Beckwith

Greenwich Industries LP

Knaack Mfg Co 420 E Terra Cotta Ave Crystal 60014 Rich Geilfuss

Lake

Alcan Packaging Food 5303 St Charles Rd Bellwood 60104- Brian Fulrrer

& Tobacco Inc 1089

Lithographic Industries 2445 Gardncr Rd Broadvicw 60153 Louis A Ebert

Microcosm 1699 S 55th Ave Cicero 60804 John C Justice

Tapecoat Co Inc 1520 Lyons St Evanston 60201 Donald H Katlrrein

Moore Wallace- 4600 W Roosevelt Rd Hillside 60162- Unknown

Hillside Printing 2034

Sun Process Converting 1660 W Kenneth Dr Mt Prospect 60056- Tim Fitzgerald

Co 5515

Avery Dennison 902 Feehanville Dr Mount 60056 Lee Harris

Prospect

Fcderal-Mogul Corp 7450 N McCormick Skokie 60076- William VanHorne

Blvd 8103

Color Communications 4000 W Fillmore St Chicago 60624- Erendira Santillan

Inc 3916

Chicago Steel Container 1846 S Kilbourn Ave Chicago 60623- Anthony Pileggi

Corp 2306
9

Rollprint Packaging 320 Stewart Ave Addison 60101- Mark E Pederson

Products Inc 3310

Pres-on Tape & Gasket 1020 S Westgate Dr Addison 60101 Steven Atlas

Corp

Olon Industries Inc 411 Union St Geneva 60134 Greg Kozuch

Printpack Inc 1400 Abbott Dr Elgin 60123- Donna McCoy

1823

Nuway Speaker 945 Anita Ave Antioch 60002 George Wise

Products Inc

AMPAC Flexicon LLC 165 Chicago St Cary 60013 Jeff Uhrig

Panduit Corp 16530 163rd St Lockport 60441 William P Tonn
B 4
iJ=3ECfEBVE©

CLERK'S OFFICE

~jOV 0J2009

STATE OF ILLINOIS

Pollution Control Board

ILLINOIS POLLUTION CONTROL BOARD

Since 1998, Section 27(b) ofthe Environmental Protection Act has required

the Board to:

This rulemaking was filed with the Board on Octobcr 23,2009, by the Illinois

Environmental Protcction Agency under the "fast-track" rulemaking authority at

.' Scction 28.5 ofthe Act, which was recently rc-enactcd by Public Act 96-0308,

<iii effective August 11,2009. Section 28.5 rcquires the Board to proceed toward

:; adoption ofthe proposed regulations by meeting a series ofstrict deadlincs.

Specifically, the Board must hold at least two, and possibly three, hearings on the

, proposal. Additionally, thc Board must submit the propOSed amendments to the

Joint Committee on Administrative Rules on or before either March 2, 2010, or

'March 22, 2010 (130 or 150 days after the proposal's filing), depending on whether

theBoard holds two or three hearings. The BOflrd has scheduled hearings in this

~lemaJci!1J>tobegin on December 9, 2009, Jaiiuary 6,2010, and January 20, 2010,

The Board respcctfully requests that your Department expedite its determination

whether it will conduct an economic impact study on the proposal and respond no

later than Tuesday, December 15, 2009.

I:i~g,·. ., .,,;. i

!~1~II,i No,=b~ 5, 2009

1t-:'<"'" '·>"""··"':r:"~:k.?J. ~e~~~~n~l~~'~=~r~e and Economic Opportunity

0"" .,,, 620 East Adams Street S-6 ~Y·::,-:.. ·1"",,<;-;f~J·.'\:,·;~~·~· ..'

;:: G:ii1lili 'PhJ).r7 Spnngfield, IllmOls 62704 I;, '. r:~~:Z:-;;~~!.~~;:;:~:~~p~:~:%:?;;::::~~~~E~;1 '!Ji{ ,~~ Code 218 and 219 (R1?~10) .

;r"... =",'1 :1 Dear Director Ribley:

"J

:¥J On November 5, 2009, the Board accepted for hearing a proposal entitled

i:' Reasonably Available Control Technology (RACT) for Volatile Organic Material

Emissions from Group 1II Consumer & Commercial Products: Proposed

Amendments to 35 Ill. Adm. Code 218 and 219 (Board Dockct RI0-1O).· Gcncrally,

thc Agcncy proposes to adopt air pollution regulations to control cmissions of

volatilc organic material from Group 1II Consumer & Commercial Products in ozone

nonattainment areas classified as moderate and abovc. Group 1II includes the

following product categorics: papcr, film, and foil coatings; metal furniture coatings;

and large appliance coatings. I writc to requcst that your Departmcnt conduct an

economic impact study conccrning this proposal.
..'-'

..:.::-

~.;::,

..'

-. . ".-;

1) request that the Department ofCommerce and Economic Opportunity

(fonnerly the Department of Commerce and Community Affairs) conduct a

study ofthe economic impact ofthe proposed rules. The Department may

within 30 to 45 days ofsuch request produce a study ofthe economic impact "',

ofthe proposed rules. At a minimum, the economic impact study shall

address a) economic, environmental, and public health benefits that may be

achieved through compliance with the proposed rules, b) the effects ofthe

proposed niles on employment levels, commercial produbtivity, the economic

growth ofsmall businesses with 100 or less employees, and the State's

overall economy, and c) the cost per unit ofpollution rcduced and the

variability of company revenues expected to be used to implement the

proposed rules; and >'.'"

., ."

(2) conduct at least one public hearing on the economic impact ofthose

rules. At least 20 days before the hearing, the Board shall notifY the public of

the hearing and make the economic impact study, or the Department of

Commerce and Economic Opportunity's explanation for not proaucing an

economic impact study, available to the public. Such public hearing may be

held simultaneously or as a part of any Board hearing considering such new

rules. 415 ILCS 5/27(b) (2008).

The Board intends to proceed promptly with this rulemaking as required by

Section 28.5 ofthe Act, and asks that you detennine whether DCEO will conduct an

economic impact study on the proposal and respond no later than Tuesday,

December 15, 2009. IfI, or my staff, can provide you with any additional

infonnation, please let me know. .

Thank you in advance for your prompt response.

Sincerely,

, . G, T3nn!M'-Giiard

., ,J Acting ch~iin{an

Pollution Control Board

., cc: John T. Therriault, Assistant Clerk ofthe Board
B 5
i

Volume 33, Issue 47

November 20, 2009

Pages 15926-16539
ILLINOIS REGISTER 16399

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

1) Heading of the Part: Organic Material Emission Standard and Limitations for the 

Chicago Area

2) Code Citation: 35 Ill. Adm. Code 218

3) Section Numbers: Proposed Action:

218.106 Amended

218.204 Amended

218.205 Amended

218.207 Amended

218.210 Amended

218.211 Amended

218.212 Amended

218.218 New

4) Statutory Authority: Implementing Section 10 and authorized by Sections 27, 28 and 

28.5 of the Environmental Protection Act [415 ILCS 5/10, 27, 28 and 28.5]

5) A Complete Description of the Subjects and Issues Involved: The proposed rulemaking 

is intended to satisfy Illinois' obligation to submit a State Implementation Plan addressing 

requirements under Sections 172 and 182 of the federal Clean Air Act, 42 USC 7401 et 

seq., for sources of volatile organic material (VOM) emissions in areas designated as 

nonattainment with respect to the ozone National Ambient Air Quality Standard. The 

United States Environmental Protection Agency (USEPA) issued Control Techniques 

Guidelines (CTGs) for the following Group III Consumer and Commercial Product 

Categories: Paper, Film, and Foil Coatings, Metal Furniture Coatings, and Large 

Appliance Coatings. In the CTGs, the USEPA recommended control measures that it 

believes constitute reasonably available control technology for those product categories. 

The Illinois EPA proposes amending Parts 218 to implement such recommendations for 

the Chicago nonattainment area. Generally, the proposal amends VOM content 

limitations and exclusions, requires that metal furniture and large appliance coating lines 

comply with application method limitations, and requires that subject coating lines 

implement specified work practices for cleaning materials and/or cleaning-related 

activities.

6) Published studies or reports, and sources of underlying data, used to compose this 

rulemaking: The regulatory proposal included the Illinois EPA's Technical Support 

Document, which relied on several sources. Copies of the documents the Illinois EPA 
ILLINOIS REGISTER 16400

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

relied upon are available for review with the Pollution Control Board and are listed 

below:

Control Techniques Guidelines for Paper, Film, and Foil Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

Control Techniques Guidelines for Metal Furniture Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

Control Techniques Guidelines for Large Appliance Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

7) Will these proposed amendments replace any emergency rulemaking currently in effect? 

No

8) Does this rulemaking contain an automatic repeal date? No

9) Do these proposed amendments contain incorporations by reference? No

10) Are there any other proposed amendments pending on this Part? No

11) Statement of Statewide Policy Objectives: This proposed rule does not create or enlarge 

a State mandate, as defined in Section 3(b) of the State Mandates Act. [30 ILCS 805/3(b) 

(2006)].

12) Time, Place, and Manner in which interested persons may comment on this proposed 

rulemaking: Interested persons may request copies of the Board's opinion and order by 

calling the Clerk's office at 312-814-3620, or may download copies from the Board's 

Web site at www.ipcb.state.il.us. The Board will accept written public comment on this 

proposal for 45 days after the date of publication in the Illinois Register. Comments 

should reference Docket R10-10 and be addressed to:

Clerk's Office

Illinois Pollution Control Board

100 W. Randolph St., Suite 11-500

Chicago, IL 60601
ILLINOIS REGISTER 16401

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

312/814-3620

The Board has scheduled hearings according to the deadlines and for the purposes

established by Section 28.5. Each hearing will continue from day-to-day until business is 

completed:

First hearing: Wednesday, December 9, 2009

10:00 AM

James R. Thompson Center

100 W. Randolph St.

Pollution Control Board Conference Room 11-512

Chicago, Illinois

Second hearing: Wednesday, January 6, 2010

(if necessary) 10:00 AM

Michael A. Bilandic Building

160 N. LaSalle Street

Room N-505

Chicago, Illinois

Third hearing: Wednesday, January 20, 2010

(if necessary) 10:00 AM

Michael A. Bilandic Building

160 N. LaSalle Street

Room N-505

Chicago, Illinois

A November 5, 2009 hearing officer order contains additional details concerning 

participation in the rulemaking. For more information contact Hearing Officer Tim Fox 

at 312-814-6085 or email at foxt@ipcb.state.il.us.

13) Initial Regulatory Flexibility Analysis:

A) Types of small businesses, small municipalities and not for profit corporations 

affected: this rulemaking will impact any small business, small municipality, and 

not for profit corporation that falls within one of the Group III Product Categories 

and meets the applicability thresholds specified in the proposal.
ILLINOIS REGISTER 16402

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

B) Reporting, bookkeeping or other procedures required for compliance: the 

proposed rulemaking requires that the owner or operator of a subject source 

perform emissions monitoring, submit certifications, complete required tests, and 

maintain records and make reports as required.

C) Types of Professional skills necessary for compliance: no professional skills 

beyond those currently required by the existing state and federal air pollution 

control regulations applicable to affected sources will be required.

14) Regulatory Agenda on which this rulemaking was summarized: July 2009

The full text of the Proposed Amendments begins on the next page:
ILLINOIS REGISTER 16460

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

1) Heading of the Part: Organic Material Emission Standards and Limitations for the Metro 

East Area

2) Code Citation: 35 Ill. Adm. Code 219

3) Section Numbers: Proposed Action:

219.106 Amended

219.204 Amended

219.205 Amended

219.207 Amended

219.210 Amended

219.211 Amended

219.212 Amended

219.218 New

4) Statutory Authority: Implementing Section 10 and authorized by Sections 27, 28 and 

28.5 of the Environmental Protection Act [415 ILCS 5/10, 27, 28, and 28.5]

5) A Complete Description of the Subjects and Issues Involved: The proposed rulemaking 

intends to satisfy Illinois' obligation to submit a State Implementation Plan addressing 

requirements under Sections 172 and 182 of the federal Clean Air Act, 42 USC 7401 et 

seq., for sources of volatile organic material (VOM) emissions in areas designated as 

nonattainment with respect to the ozone National Ambient Air Quality Standard. The 

United States Environmental Protection Agency (USEPA) issued Control Techniques 

Guidelines (CTGs) for the following Group III Consumer and Commercial Product 

Categories: Paper, Film, and Foil Coatings, Metal Furniture Coatings, and Large 

Appliance Coatings. In the CTGs, the USEPA recommended control measures that it 

believes constitute reasonably available control technology for the product categories. 

The Illinois EPA proposes amending Part 219 to implement such recommendations for 

the Metro East nonattainment area. Generally, the proposal amends VOM content 

limitations and exclusions, requires that metal furniture and large appliance coating lines 

comply with application method limitations, and requires that subject coating lines 

implement specified work practices for cleaning materials and/or cleaning-related 

activities.

6) Published studies or reports, and sources of underlying data, used to compose this 

rulemaking: The regulatory proposal included the Illinois EPA's Technical Support

Document, which relied on several sources. Copies of the documents the Illinois EPA 
ILLINOIS REGISTER 16461

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

relied upon are available for review with the Pollution Control Board and are listed 

below:

Control Techniques Guidelines for Paper, Film, and Foil Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

Control Techniques Guidelines for Metal Furniture Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

Control Techniques Guidelines for Large Appliance Coatings, United States 

Environmental Protection Agency, Office of Air Quality Planning and Standards, 

Research Triangle Park, NC, September 2007.

7) Will this rulemaking replace any emergency rulemaking currently in effect? No

8) Does this rulemaking contain an automatic repeal date? No

9) Does this rulemaking contain incorporations by reference? No

10) Are there any other proposed amendments pending on this Part? No

11) Statement of Statewide Policy Objectives: This proposed rulemaking does not create or 

enlarge a State mandate, as defined in Section 3(b) of the State Mandates Act. [30 ILCS 

805/3(b) (2006)]

12) Time, Place, and Manner in which interested persons may comment on this proposed 

rulemaking: Interested persons may request copies of the Board's opinion and order by 

calling the Clerks office at 312/814-3620, or may download copies from the Board's Web 

site at www.ipcb.state.il.us. The Board will accept written public comment on this 

proposal for 45 days after the date of publication in the Illinois Register. Comments 

should refer to Docket R10-10 and be addressed to:

Clerk's Office

Illinois Pollution Control Board

100 W. Randolph St., Suite 11-500

Chicago, IL 60601

312/814-3620
ILLINOIS REGISTER 16462

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

The Board has scheduled hearings according to the deadlines and for the purposes 

established by Section 28.5. Each hearing will continue from day-to-day until business is 

completed:

First hearing: Wednesday, December 9, 2009

10:00 AM

James R. Thompson Center

100 W. Randolph St.

Pollution Control Board Conference Room 11-512

Chicago, Illinois

Second hearing: Wednesday, January 6, 2010

(if necessary) 10:00 AM

Michael A. Bilandic Building

160 N. LaSalle Street

Room N-505

Chicago, Illinois

Third hearing: Wednesday, January 20, 2010

(if necessary) 10:00 AM

Michael A. Bilandic Building

160 N. LaSalle Street

Room N-505

Chicago, Illinois

A November 5, 2009 hearing officer order contains additional details concerning 

participation in the rulemaking. For more information contact Hearing Officer Tim Fox 

at 312/814-6085 or email at foxt@ipcb.state.il.us.

13) Initial Regulatory Flexibility Analysis:

A) Types of small businesses, small municipalities and not for profit corporations 

affected: This rulemaking will impact any small business, small municipality, 

and not-for-profit corporation that falls within one of the Group III Product 

Categories and meets the applicability thresholds specified in the proposal.

B) Reporting, bookkeeping or other procedures required for compliance: The 

proposed rulemaking requires that the owner or operator of a subject source 
ILLINOIS REGISTER 16463

09

POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

perform emissions monitoring, submit certifications, complete required tests, and 

maintain records and make reports as required.

C) Types of Professional skills necessary for compliance: No professional skills 

beyond those currently required by the existing State and federal air pollution 

control regulations applicable to affected sources will be required.

14) Regulatory Agenda on which this rulemaking was summarized: July 2009

The full text of the Proposed Amendments begins on the next page:
B 6
CO-CHAIR:

SEN. MAGGIE CROTTY

CO-GHAIR:

REP. ANGELO ·SKIP· SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ONADMINISTRATIVE RULES

ILUNOIS GENERAL ASSEMBLY

SEN. J. BRADLEY BURZYNSKI

SEN. RANDALL HULTGREN

SEN. MATIIE HUNTER

SEN. DAN RUTHERFORD

SEN. IRA SILVERSTEIN

REP. JOHN FRITCHEY

REP, LOU LANG

REP. DAVID MILLER

REP. DONALD MOFFITI

REP, ROSEMARY MULLIGAN

TO:

FROM:

DATE:

700 STAAlTON BUILDING

SPRINGFIELD, ILLINOIS 62705

2171785-2254

MEMORANDUM

Tanner Girard, Chainnan

Pollution Control Board

Vicki Thomas

Executive Director

November 17, 2009

ReceeVED

CLERK'S OFFICE

NOV f 92009

STATE OF 'LUNO

POllution COntrOl ~~

RE: Organic Material Emission Standards and Limitations for the Metro East Area (35

m. Adm. Code 219)

33 Ill. Reg. 16460 - 11/20/09

Pursuant to Section 5-40(b) of the Illinois Administrative Procedure Act, the Committee is

requesting from your agency an analysis of the effects of the above-referenced rulemaking on

units of local government, school districts, or community college districts, pursuant to the State

Mandates Act, as it appears that this rulemaking may create or expand a State mandate on these

entities.

The enclosed illustration entitled "State Mandates Act Questionnaire" indicates the infonnation

to be provided as a part ofthe Second Notice submitted to JCAR.

If you have any questions about this request, please contact us at (217)785-2254. Thank you for

your cooperation in this matter.

VT:DC:nn

Enc.

cc: John Therriault
STATE MANDATES ACT QUESTIONNAIRE

Agency: Pollution Control Board

Heading of the Part: Organic Material Emission Standards and Limitations for the Metro East

Area

Administrative Code Citation: 35 III Adm Codc 219

Signature of Agency Head:

I. Does this rulemaking affect any ofthe following:

Municipality

County

Township

Other Unit ofLocal Gov!.

School District

Community College District

2. Does this rule require any of the above entities to establish, expand or modify its

activities in such a way as to necessitate additional expenditures from local revenues?

Yes No Number of units affected

If yes, please estimate the amount of additional expenditures necessitated by this

rulemaking pcr unit of government: $ _

NOTE: Ifthe dollar amount, or total number of units affected is unknown, please outline

and attach to this form an explanation of the steps taken by the agency to determine the

approximate expense of the rulemaking, and the number of units affected.

Ifno, please explain why the rule does not necessitate such additional expenditures.

3. Were any alternatives that do not necessitate additional expenditures considered?

Yes No _

If yes, please list these alternatives and explain why they were rejected.

4. What are the policy objectives ofthe rulernaking? (please be specific)

5. Please explain why the policy objectives ofthis rule cannot be achieved in the absence of

the rule or through a rule that does not create a State Mandate.
CO-CHAIR:

SEN. MAGGIE CROTTY

CO-CHAIR:

REP. ANGELO ·SKIP" SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ONADMINISTRATIVE RULES

ILLINOIS GENERAL ASSEMBLY

SEN. J. BRADLEY BURZYNSKI

SEN. RANDALL HULTGREN

SEN. MAnlE HUNTER

SEN. DAN RUTHERFORD

SEN. IRA SILVERSTEIN

REP. JOHN FRITCHEY

REP. LOU LANG

REP. DAVID MILLER

REP. DONALD MOFFITI

REP. ROSEMARY MULLIGAN

TO:

FROM:

DATE:

700 STRATTON BUILDING

SPRINGFIELD, ILLINOIS 62706

217/785-2254

MEMORANDUM

Tanner Girard, Chainnan

Pollution Control Board

Vicki Thomas

Executive Director

November 17, 2009

REce8VED

CLERK'S OFFICE

NOV 192009

STATE OF IlliNOIS

Pollution Control Board

RE: Organic Material Emission Standards and Limitations for the Chicago Area (35

TIl. Adm. Code 218)

33 111. Reg. 16399 - 11/20/09

Pursuant to Section 5-40(b) of the Illinois Administrative Procedure Act, the Committee is

requesting from your agency an analysis of the effects of the above-referenced rulemaking on

units of local government, school districts, or community college districts, pursuant to the State

Mandates Act, as it appears that this rulemaking may create or expand a State mandate on these

entities.

The enclosed illustration entitled "State Mandates Aet Questionnaire" indicates the infonnation

to be provided as a part of the Second Notice submitted to JCAR.

If you have any questions about this request, please contact us at (217)785-2254. Thank you for

your cooperation in this matter.

VT:DC:nn

Ene.

ec: John Therriault
STATE MANDATES ACT QUESTIONNAIRE

Agency: Pollution Control Board

Heading of the Part: Organic Material Emission Standards and Limitations for the Chicago

Area

Administrative Code Citation: 35 III Adm Code 218

Signature of Agency Head:

1. Does this rulemaking affect any ofthe following:

Municipality

County

Township

Other Unit ofLocal Govt.

School District

Community College District _

2. Does this rule require any of the above entities to establish, expand or modify its

activities in such a way as to necessitate additional expenditures from local revenues?

Yes No Number of units affected

If yes, please estimate the amount of additional expenditures necessitated by this

rulemaking per unit of government: $ _

NOTE: Ifthe dollar amount, or total number ofunits affected is unknown, please outline

and attach to this form an explanation ofthe steps taken by the agency to determine the

approximate expense ofthe rulemaking, and the number of units affected.

If no, please explain why the rule does not necessitate such additional expenditures.

3. Were any alternatives that do not necessitate additional expenditures considered?

Yes No _

Ifyes, please list these alternatives and explain why they were rejected.

4. What are the policy obj ectives ofthe rulemaking? (please be specific)

5. Please explain why the policy objectives ofthis rule cannot be achieved in the absence of

the rule or through a rule that does not create a State Mandate.
B 7
Electronic Filing - Received, Clerk's Office, November 24, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP JIJ CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

)

)

)

)

)

)

)

)

RIO-IO

(Rulemaking-Air)

NOTICE

To: John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601-3218

SEE ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control

Board the TESTIMONY OF YOGINDER MAHAJAN ofthe Illinois Environmental Protection

Agency, copies ofwhich arc herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:C2'y,1"4o Dana Velterhoffer ~4

Assistant Counsel

Division ofLegal Counsel

DATED: November 25,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Electronic Filing - Received, Clerk's Office, November 24, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAlLABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

)

)

)

)

)

)

)

)

RIO-IO

(Rulemaking - Air)

TESTIMONY OFYOGINDER MAHAJAN

My name is Yoginder Mahajan. I am employed as an Environmental Protection Engineer

in the Air Quality Planning Section in the Bureau ofAir ofthe II1inois Environmental

Protection Agency ("Agency"). I have been employed in this capacity since March 1992.

Prior to my employment with the Agency I worked for various metal fabrication

industries for nine years. My educational background includes a Bachelor ofEngineering

Degree in Mechanical Engineering from Bhopal University at Bhopal, India.

As part ofmy regular duties .in the Air Quality Planning Section, I have been involved

with preparing emission estimates for various source categories used in the development

ofthe 1990 ozone season weekday emissions inventories; evaluating control technologies

applicable to volatile organic material ("VOM") emissions sources in preparation ofthe

Rate-of-Progress plans for the Chicago and St. Louis ozone nonattainment areas; and

assisting in the development ofregulations for the control ofVOM emissions from

source categories included in the Rate-of-Progress plans. I prepared the technical support

document ("TSD") for this proposal before you.

I
Electronic Filing - Received, Clerk's Office, November 24, 2009

The Agency's proposal addresses reductions in VOM emissions from the following

categories: paper, film and foil coatings; large appliance coatings; and metal furniture

coatings. The United States Environmental Protection Agency ("U.S. EPA") identified

these three categories of coatings as the Consumer and Commercial Products, Group m.

Section 172 ofthe Clean Air Act ("CAA'') requires that state implementation plans

("SIPs") for nonattainment areas, such as the Chicago and Metro-East St. Louis

nonattainment areas ("NAAs") in Illinois, include requirements for reasonably available

control technology ("RACT") as it applies to emissions sources. Section I82(b)(2)(A) of

the CAA further requires that SIPs be rcviscd to include RACT for VOM emissions

sources that are covered by a CTG document issued by U.S . EPA after November 15,

1990, and before the area's dale ofaUainment.

The U.S. EPA defines RACT as "the lowest emission limilationlhat a particular source is

capable ofmeeting by the application ofcontrol lechnology that is reasonably available

considering technological and economic feasibility." In September 2007, the U.S. EPA

issued the final CTGs for Consumer and Commercial Products, Group Ill. These CTGs

contained information regarding sources ofVOM emissions from the applicable

industries, the recommended available control options to reduce VOM emissions, and the

cost ofrecommended control measures. The Agency relied on the information contained

in the CTGs to develop this proposal.

2
Electronic Filing - Received, Clerk's Office, November 24, 2009

The affected sources in the Chicago and Metro-East St. Louis NAAs are required to

comply with the proposed regulations on and after May I, 2011.

Paper, Film, and Foil Coatings

Currently, 35 Ill. Adm. Code 218 and 219 specify YOM limits in telms ofmass ofVOM

per volume of coating for paper coating. The Agency is proposing to amend subsection

(c) of Section 218/219.204 to specify YOM limits in terms ofmass ofVOM per mass of

solids applied, and equivalent limits in terms ofmass ofVOM per mass of coatings

applied. The Agency is proposing a lower YOM limit of 0.20 kg per kg ofsolids (0.20

Ib/lb ofsolids) for pressure sensitive tape and label surface coating. Except for pressure

sensitive tape and label coatings, the YOM Jimits are equivalent to the existing YOM

limits for paper coating. The Agency is proposing to increase the overall control

efficiency standard for add-on capture and control systems to 90 percent from the

existing 81 percent overall control efficiency requirement. The affected sources may

comply with the YOM emission limits by installing and operating add-on capture and

control systems or by utilizing a combination of both low YOM coatings and add-on

capture and control systems. In addition, the Agency is proposing to add Section

21812 ]9.218, which contains work practice standards recommended by the U.S. EPA.

The Agency staff reviewed the 2005 YOM emissions inventory and determined that there

are 16 affected sources in the Chicago NAA and two in the Metro-East NAA. Seven out

of] 6 affected sources comply with the regulations by using add-on capture and control

systems. The Agency beJieves that no new add-on capture and control systems will be

3
Electronic Filing - Received, Clerk's Office, November 24, 2009

installed to comply with the proposed regulations. Rather, the Agency expects that

affected sources will continue to use compliant coatings, or upgrade their existing add-on

capture and control systems to meet the proposed VOM emission limits. The Agency

estimates that approximately 21.45 tons per year ofVOM emissions will be reduced in

the Chicago NAA at a cost of$1,200 per ton ofVOM reduced. The Agency does not

expect any reduction in YOM emissions in the Metro-East St. Louis NAA.

Metal Furniture Coatings and Large Appliance Coatings

Currently, 35 Ill. Adm. Code 218 and 219 specify YOM limits in terms ofmass ofVOM

per volume ofcoating for air dried and baked coatings for large appliance coatings and

metal furniture coatings. The Agency is proposing to amend subsections (g) and (h) to

provide VOM limits for one-component and multi-component general purpose coatings,

and provide specific YOM emission limits for certain specialty coatings. For several of

these coating types, separate emission limits in terms of mass of YOM per volume of

coating are proposed for baked and air-dried coatings. Also, equivalent YOM limits in

terms of mass ofVOM per volume ofsolids applied arc specified. The proposed

regulations exempt stencil coatings, safety-indicating coatings, touch-up repair coatings,

and coating applications utilizing handheld aerosol cans.

The proposed regulations require the use of one or more ofthe following application

methods: electrostatic application, high volume Jow pressure ("HVLP") spray, flow coat,

roller coat, dip coat including electrodeposition, brush coating for only large appliance

4
Electronic Filing - Received, Clerk's Office, November 24, 2009

coatings, or other coating application method capable of achieving a transfer efficiency

equivalent or better than achieved by HVLP spraying.

Affccted sources may use add-on capture and control systems to comply with the YOM

content limits ofthe coatings. The Agency is proposing to increase the overall control

efficiency standard to 90 percent from the existing 81 percent overall control efficiency.

The affected sources may comply with the YOM emission limits by installing and

operating add-on capture and control systems or by utilizing a combination ofboth low

YOM coatings and add-on capture and control systems. In addition, the Agency is

proposing to add Section 218/219.218, which contains work practice standards

recommended by the U.S. EPA.

The Agency staffreviewed the 2005 YOM emissions inventory and detennined that there

are six affected sources of metal furniture coating in the Chicago NAA and none in the

Metro-East NAA. There are no affected sources oflarge appliance coatings in the

Chicago and Metro-East St. Louis NAAs. The Agency expects that affected sources will

continue using compliant coatings to comply with the YOM limits. The Agency does not

expect any reduction in YOM emissions.

On July 20,2009, the Agency posted a draft ofthe proposed rule and copies ofthe

pertinent CTGs on its website for public comments. The Agency also contacted

potentially affected sources via email, soliciting feedback on the proposed regulations.

5
Electronic Filing - Received, Clerk's Office, November 24, 2009

The Agency did not receive any comments regarding this proposal. The Agency believes

these proposed changes are not controversial, as they are largely based on the U.S. EPA's

recommendations. The Agency believes that the proposed changes are technically

feasible and economically reasonable.

6
Electronic Filing - Received, Clerk's Office, November 24, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

)

)

)

)

)

)

)

)

RIO-IO

(Rulemaking-Air)

CERTIFICATE OF SERVICE

I, the undersigned, an attorney, state that I have served electronically the attached

TESTIMONY OF YOGINDER MAHAJAN upon the following person:

John Theniault, Assistant Clerk

lIlinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, lIlinois 60601-3218

and electronically to the following persons:

SEE ATTACHED SERVICE LIST.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By: (4vu.?lbi(J~ Dana Vetterhoffer

Assistant Counsel

Division ofLegal Counsel

DATED: November 25,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Electronic Filing - Received, Clerk's Office, November 24, 2009

Service List R1 0-1 0

Timothy J. Fox

Hearing Officer

Illinois Pollution Control Board

100 W. Randolph St., Suite 11-500

Chicago, IL 6060 I

foxt@ipcb.state.il.us

Virginia Yang

Deputy Legal Counsel

1l1inois Department of Natural Resources

One Natural Resources Way

Springfield, lL 62702-1271

virginia.yang@illinois.gov

Matthew Dunn, Chief

Division ofEnvironmental Enforcement

Office ofthe Attorney General

69 W. Washington St., Suite 1800

Chicago, IL 60602

mdunn@atg.state.iI.us
B 8
Page 1

ILLINOIS POLLUTION CONTROL

IN RE THE ~~TTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR

VOLATILE ORGANIC MATERIAL

EMISSIONS FROM GROUP III

CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED

AMENDMENTS TO 35 Ill. Adm.

Code 218 and 219

BO~eEBVIEfi) CLERK'SOF~

DEC 602009

STATE OF ILLINOIS

Pollution Control Board

No. R10-10

(Rulemaking- Air)

,

\

{

REPORT OF PROCEEDINGS held in the

above-entitled cause before Hearing Officer Timothy

Fox, called by the Illinois Pollution Control Board,

taken before Laura Mukahirn, CSR, a notary public

within and for the County of Cook and State of

Illinois, at the James R. Thompson Center, 100 West

Randolph Street, Chicago, Illinois, on the 9th day

of December 2009, commencing at the hour of 10:00

a.m.
1

2

A P PEA RAN C E S

Page 2

3 MR. TIMOTHY FOX, Hearing Officer

MR. THOMAS JOHNSON, Member

4 MR. ANAND RAO, Member

MS. ANDREA S. MOORE, Member

5 MS. CARRIE K. ZALEWSKI, Member

Appearing on behalf of the Illinois

6 Pollution Control Board;

7 ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

8 P.O. Box 19276

Springfield, Illinois 62794-9276

9 Appearing on behalf of the IEPA.

10 ALSO PRESENT:

11 MR. ROBERT J. KALEEL - IEPA

Manager, Air Quality Planning Section, Bureau of Air

12

(

13

14

15

16

17

18

19

20

21

22

23

24

MR. YOGINDER MAHAJAN - IEPA

Environment Protection Engineer, Bureau of Air
B 9
Electronic Filing - Received, Clerk's Office, December 28, 2009

BEFORT~ THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (KAeT) FOR VOLATILE

ORGANIC MATER[AL EMISSIONS FROM

GROUP !II CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. A.DM. CODE2I8 and 219

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R10-10

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NOTICE

To: John Therriault, Assistant Clerk

!lJinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601-3218

SEE ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that I have today filed with the Of1lee of tile Pollution Control

Board the MOTION TO AMEND RULEMAKING PROPOSAL ofthe Illinois Environmental

Protection Agency, copies of which are herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:..i.L~~l!#;tq:.~'f.r4.'-- Dana Vetterhoffer

AssistaJ1t Counsel

Division of Legal Counsel

DATED: December 28, 2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Electronic Filing - Received, Clerk's Office, December 28, 2009

BEFORE THE ILLINOlS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISSIONS FROM

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 219

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RIO-IO

(Rulemaking-Air)

MOTION TO AMEND RULEMAKING PROPOSAL

The Proponent, the Illinois Environmental Protection Agency ("Illinois EPA"), by its

attorney, and pllrsuant to 351l1. Adm. Code 101.500 and 102.402, moves that the Illinois

Pollution Control Board ("Board") amend Parts 218 and 219 of this rulemaking proposal. In

support ofits Motion, the Illinois EPA states as follows:

1. On October 23,2009, the Illinois EPA filed a proposal with the Board to amend 35 III.

Adm. Code Parts 218 and 219 to control the emissions of volatile organic materials ("VOM")

from Group III Consumer and Commercial Product categories. Thc proposal implements

reasonably available control technology for such categories in response to Control Techniques

Guidelines issued by the United States Envirol1llJemal Protection Agency.

2. On December 9, 2009, the Board held its first hearing regarding this rulemaking

proposal. Based upon questions asked and comments received at such hearing, the Illinois EPA

proposes the following amendments to its proposal.

3. In response to a Board recommendation that the proposed application method limitations

set forth in Section 2l8/219.204(g) and (h) be instead placed in a more appropriate section of

Subpart F, the Illinois EPA recommends moving such limitations to Section 218/219.218, as

follows:
Electronic Filing - Received, Clerk's Office, December 28, 2009

Section 218/219.204(g)(3) and (11)(3):

g) Metal Furniture Coating

3) 01HlJld after May 1,2011, aR-e·wner or operator ofa coaliJtg-J-ioo

subject to tHe limitations in sabsec-tton (g) ofthis Ssctien shall

apply all csatit:gs using-Bns or mars oftHsreliowing application

methods:

A) E1ectrostatio spray;

B) High volums low prsssure lEVU) SpffiJS

C) flow coeting. for tHe purposes sftHis subsection (g), .flow

eostiRg means a non atomiGed tee!lniEjue of applying

coating to..n..substrate with a .fluid ROGzle-with no air

sUj'lj'llied to the Houls;

D) Roll coatiHgr

E) Dij'l COaling, including electrod€j3osition. For PlirpeseS-ef'

this subsection (g), clectrodej'losition means s water llome

dij'l coating j'lrGcess in WhWH oj'lposi~e eJectTieal charges are

aj'lj'llied [0 ~tGand the coating. The coating is

atffiH4ed-te· the substrate due-tfl-lhe electrochemical

potcetial difference that is created; or

F) Anotker coatie; aj3j'llieation method capable ofachi<Wing..a

transfer effieiel*T-equal to or better than tflat..aehisved lly

HVLP sj'lraying, if stleiJ method is apj'lfO\ ed in writing-by

tfie Ageney.

(h) Large Appliance Coating

3) On and after May J, 20/1, an ownor or oj'lerator of a coating linG

subject to the limitaliuns in sabseetion (h) ofthis Section shall

ilj}j3ly all coatings using ene or-more ofths rellewing apj'lJieation

methods:

A) Elee\ros'catie spray;

2
Electronic Filing - Received, Clerk's Office, December 28, 2009

B) Hit;h "obme low pre5W~VLP) spray;

C) Flo..,.. eoatillg. For the purposes offlHS sUBseetion (h), flow

waling means a nOll atomized techni~ue of applying

coating to a sUBstmle with a fluid nozzle with no air

sHj3j3lieello :he nozzle;·

D) Roll Goating;

E) Brush Goating;

F) Dij)-€OOtieg, il:Glading-~lcGtrodeposition. For purposes of

this saBseGtion (h), clcetroelepssition lJ~eans a water Berne

<ltv coating process in WHich opposito eloctrical charges are

applied to the SUBstrate and lhe coalia;. The Goatia; is

attrac-ted to the SUBstrate due to tile electroGhemical

j7etent1al difference that is ereated; or

0) Anotllcr eOBliflg !ljJplicBtiofl method eBpH~el!ieviag-a

transfer effieiency CEJllBl 10 or better thBn Ihal'-aehieved-iJy

HVLP sprayffig,--ikt!elHuethod is Bj'lj'lroved in writing by

the-Ageney7

Section 218. 218(b):

b) On and after May 1,2011, every owner or operator of a source subject to

the requirements of Section 218.204(g) or 218.204(b) of tbis Subpart sball:

1) Store all YOM-containing coati.ngs, tbinners, coating-related waste

materials, cleaning materials, and used shop towels in closed

containers;

2) Ensure that mixing and storage containers used for VOMcontaining coatillgs, tbinners, coating-related waste materials, and

cleallillg materials are kept closed at all times except when

depositing or removing such materials;

3) Minimize spills ofVOM-containing coatings, thinners, coatingrelated waste materials, and cleaning materials, and clean up spills

immediately;

4) Convey YOM-containing coatings, thinners, coating-rclated waste

materials, and cleaning materials from one location to another in

closed containers or pipes; ana

3
Electronic Filing - Received, Clerk's Office, December 28,2009

5) Minimize YOM emissions from the cleaning ofstorage, mixing,

and conveying equipment; and,

6) Apply all coatings using one or more ofthe following application

methods:

A) Electrostatic spray;

B) High volume low presslU·e (HVLP) spray;

Cl Flow coating. For the purposes ofthis subsection (b), flow

coating means a non-atomized technique of applying

coating to a substrate with a fluid nozzle with no air

supplied to the nozzle;

D) Roll coating;

E) Dip coating, including electrodcposition. For purposes of

this subsection (b), eleclrodeposilion means a water-borne

dip coating process in which opposite electrical charges arc

applied to the substrate and the coating. The coating is

attracted to the substrate due to the electrochemical

potential difference that is created;

F) Brosh coating. ifsubject to the requircments ofSection

2J8.204(h); or

G) Another coating application method capable of achieving a

transfer efficiency equal to or better than that achicved bv

HVLP spraying, if such method is approved in writing by

the Agency.

Section 219.218(b):

b) On and after May I, 2011, every owner or operator of a source subject to

the requirements of Section 2I9.204(g) or 219.204(h) ofthis Subpart shall:

1) Store all YOM-containing coatings, thinners, coating-related waste

materials, cleaning materials, and used shop towels in closed

containers;

2) Ensure that mixing and storage containers used for VOMcontaining coatings, thinners, coating-related waste materials, and

cleaning materials are kept closed at all times except when

depositing or removing such materials;

4
Electronic Filing - Re~eived, Clerk's Office, December 28,2009

3) Minimize spills ofVOM-containing coatings, thinners, coatingrelated waste materials, and cleaning materials, and clean up spi lls

immediately;

4) Convey YOM-containing coatings, thinners, coating-related waste

materials, and cleaning materials from one location to another in

closed containers or pipes; aflti

5) Minimize YOM emissions from the cleaning ofstorage, mixing,

and conveying equipment; ando

6) Apply all coatings using one or more of the following application

methods:

A) Electrostatic spray;

B) High volume low pressure (HVLP) spray;

C) Flow coating. For the purposes of this subsection Ib),

flow coating means a non-atomized technique of applying

coating to a substrate with a fluid nozzle with no air

~pplied to the nozzle;

D) Roll coating;

E) Dip coating, including electrodeposition. For purposes of

this subsection Ib), electrodeposition means a water-borne

>!ill coating process in which opposite electrical charges

are applied to the substrate and the coating. The coating

is attracted to the substrate due to the electrochemical

potential difference that is created;

F) Brush coating, if su1?ject to the requirements of Section

219.204Ih); or

G) Another coating application method capable of achieving a

transfer efficiency equal to or better than that achieved by

HVLP spraying, if such method is approved in writing by

the Agency.

4. In response to a Board recommendation that any substantive requirements contained in

Board "Notes" be instead placed in the body ofthe proposed rule, the Illinois EPA recommends

amending the Note in Section 2l8/2l9.204(c) as follows:

5
Electronic Filing - Received, Clerk's Office, December 28,2009

Section 218.204(c):

c) Paper Coating

3) EN€>!€-;-The paper coating limitation set forth in this subsection Ie)

shall not apply to any owner or operator of any papcr coating line

on which tlcxographic or rotogravure printing is pcrformed if the

paper coating line complies \vith the emissions limitations in

Section 218.40 I ofthis Part. In addition, SCreen printing on paper

is not rcgulated as paper coating, but is regulatcd under Subpart TT

ofthis Part. On and after May 1,2011, the paper coating limitation

shall also not apply to coating pcrformed on or in-line with any

digital printing press, or to size presses and on-machinc coaters on

papclmaking machines applying sizing or water-bascd clays.,

Section 219.204(c):

c) Paper Coating

3) (Note: The paper coating limitation set forth in this subsection (c)

shall not apply to any owner or operator of any paper coating linc

on which tlexographic or rotogravure printing is perfonncd ifthe

paper coating line complies with the emissions limitations in

Section 219.401 ofthis Part. In addition, screen printing on paper

is not rcgulated as paper coating, but is regulated under Subpart TT

ofthis Part. On and after May 1,2011, the paper coating limitation

shall also not apply to coating performed on or in-line with any

digital printing press, or to size prcsses and on-machine coaters on

papelmaking machines applying sizing or water-based clays.,

5. For reasons similar to those set forth above, the lllinois EPA proposes amending the Note

in Section 218/219.204(h) as follows:

Section 218/219.204(h):

(h) Large Appliance Coating

3) tNetee-TheS€limitations set forth in this subsection (h) shall not

apply to the use of quick-drying lacquers for repair ofscratches

6
Electronic Filing - Received, Clerk's Office, December 28, 2009

and nicks that occur during assembly, provided that the volume of

coating does not exceed 0.95 I (1 quart) in anyone rolling eighthour period. On and after May 1,2011, these limitations shall also

not apply to stencil coatings, safety-indicating coatings, solid-film

lubricants, electric-insulating and thermal-conducting coatings,

touch-up and repair coatings, or coating applications utilizing

hand-held aerosol cans)

6. For reasons similar to those set forth abovc, the Illinois EPA proposes amending the

. proposed Note in Section 218/219.204(g) as follows:

Sec/ion 218/219.204(g):

g) Metal Furniture Coating

3) (Note: On and after May 1, 2011, these limitations set forth in this

subsection (g) shall not apply to stencil coatings, safety-indicating

coatings, solid-film lubricants, electric-insulating and thelmalconducting coatings, touch-up and repair coatings, or coating

applications utilizing hand-held aerosol cans.j

WHEREFORE, for the reasons set forth above, the 111inois EPA moves that the Board

amend Pmis 218 and 219 as set forth herein.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By: Ox.o<.//~ Ileiiaitftf& Dana Vetterhoffer .

Assistant Counsel

Division ofLegal Counsel

DATED: December 28,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, 110 62794-9276

(217) 782-5544

7
Electronic Filing - Received, Clerk's Office, December 28, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

ORGANIC MATERIAL EMISS]ONS FROM

GROUP 1II CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 and 2]9

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RI 0-1 0

(Rulemaking-Air)

CERTIFICATE OF SERVICE

1, the undersigned, an attomey, state that 1 have served electronically the attached

MOTION TO AMEND RULEMAKING PROPOSAL upon the following person:

John TheITiault, Assistant Clerk

llIinois Pollution Control Board

James R. Thompson Center

100 West RandoJph, Suite 11-500

Chicago, Illinois 60601-3218

and electronically to the following persons:

SEE ATTACHED SERVICE LIST.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By: C~ ';d:fair~ Dana Vetterhoffer 1)"

Assistant Connsel

Division ofLegal Counsel

DATED: December 28,2009

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Electronic Filing - Received, Clerk's Office, December 28, 2009

Service List RIO-IO

Timothy J. Fox

Hearing Officer

Jllinois Pollution Control Board

100 W. Randolph St., Suite 11-500

Chicago, IL 6060 I

fox tli;'ipcb.state.il.us

Virginia Yang

Deputy Legal Counsel

Illinois Department of Natural Resources

One Natural Resources Way

Springfield, IL 62702-1271

virginia.yang@il.linois.gov

Matthew Dunn, Chief

Division ofEnviromnental Enforcement

Office ofthe Attorney General

69 W. Washington St., Sui te 1800

Chicago, IL 60602

mdunn@atg.statc.il.us

Katherine D. Hodge

Monica T. Rios

Hodge Dwyer & Driver

3150 Roland Avc.

P.O. Box 5776

SpringfIeld, IL 62705-5776

khodge@hddattoJl1cys.com

mrios@hddattorneys.com

Alec M. Davis

General Counsel

Iilinois Environmental Regulatory Group

215 E. Adams St.

Springfield, IL 62701

adavis@ienr.org
B 10
Page 1

ILLINOIS POLLUTION CONTROL BOARD

JANUARY 6, 2010

REASONABLY AVAILABLE CONTROL

TECHNOLOGY FOR VOLATILE

ORGANIC MATERIAL EMISSIONS

FROM GROUP 3 CONSUMER AND

COMMERCIAL PRODUCTS PROPOSED

AMENDMENTS TO 35 ILLINOIS

ADMINISTRATIVE CODE 218 AND

219

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Ii"lJi:;CSlve"')

CI.,E;;fJli{'S OP~IC!l'"

JAN 03 2010

STATE. 0::: tLLINOJ

R1 0_18oIlU!I(Jf, Gontrol BOEd

(

REPORT OF PROCEEDINGS at the hearing of the

above-entitled cause before Timothy J. Fox, Hearing

Officer, taken before Rebecca A. Graziano, Certified

Shorthand Reporter within and for the County of Cook

and State of Illinois, at the Bilandic Building,

Room N-505, Chicago, Illinois, commencing at the

hour of 10:00 a.m. on the 6th day of January, A.D.,

2010.
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Page 2

A P PEA RAN C E S

ILLINOIS POLLUTION CONTROL BOARD

Timothy J. Fox

Andrea S. Moore

Carrie K. Zalewski

Anand Rao

THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794

(217) 782-5544

BY: MS. DANA VETTERHOFFER

MR. YOGINDER MAHAJAN

ALSO PRESENT:

MR. ANDREW ARMSTRONG
B 11
ILLINOIS POLLUTION CONTROL BOARD

January I I, 2010

IN THE MATTER OF: )

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REASONABLY AVAILABLE CONTROL )

TECHNOLOGY (RACT) FOR VOLATILE )

ORGANIC MATERIAL EMISSION FROM )

GROUP III CONSUMER & COMMERCIAL )

PRODUCTS: PROPOSED AMENDMENTS TO )

35 ILL ADM. CODE 218 AND 219 )

RIO-IO

(Rulemaking - Air)

RECEIVED

ClERK'SUFFICE

JAN 1 1 2010

.. , rE OF ILLINOIS

.""". ""~ Control Board

DOR'G'NAL

HEARING OFFICER ORDER

The second hearing in this docket took place as scheduled on Wednesday, January 6,

2010, in Chicago. The Board received the transcript ofthat hearing (Tr2) on Friday, January 8,

2010.

Section 2S.5(f)(3) ofthe Enviromnental Protection Act (Act), regarding hearings in "fasttrack" rulemaking proceedings, provides that

[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 the [Illinois

Enviromnental Protection] Agency response to the material submitted at the

second hearing and to any response by other parties. The third hearing shall be

cancelled if the Agency indicates to the Board that it does not intend to introduce

any additional material. Public Act 96-0308, eff Aug. 11,2009 (PA 96-030S)

(reenacting repealed Section 28.5).

During the second hearing, the Agency indicated that it did not seek to offer a response

and wished to have the Board cancel the third hearing. Tr.2 at 7-8. Accordingly, the third

hearing scheduled to take place on January 20,2010, is cancelled. See P.A. 96-0308 (Section

282(f)(3)).

Section 28.5(k) of the Act provides that, "[f]ollowing the hearings, the Board must close

the record 14 days after the availability ofthe transcripl." PA 96-0308 (Section 28.5(k)). With

the cancellation ofthe third hearing, the hearings in this proceeding concluded on Wednesday,

January 6, 2010. On Friday, January 8, 2010, the Board received the transcript ofthe second and

final hearing. Accordingly, the statutory 14-day comment period will close Friday, January 22,

2010.

The "mailbox rule" (35 IlL Adm. Code I 01.300(b)(2)) does not apply to the filing of

postOhearing comments, and the Board's Clerk must receive any post-hearing comments before

the close ofbusiness on Friday, January 22, 2010. Although documents may be filed

electronically through the Clerk's Office On-Line from the Board's Web site

(www.ipcb.state.iLus), all electronic or approved fax filings must be received by the Clerk's
2

Office no later than 4:30 PM on January 22, 2010. Questions about electronic filing should be

directed to the Clerk's Office at 312·814·3629.

IT IS SO ORDERED.

Timothy 1. Fox

Hearing Officer

Il1inois Pollution Control Board

100 West Randolph Street, Suite 11·500

Chicago, Illinois 60601

(312) 814-6085

(312) 814·3669 (fax)

foxt(@ipcb.state.il.us
B 12
ILLINOIS POLLUTION CONTROL BOARD

February 4, 20 I0

IN THE MATTER OF: )

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REASONABLYAYAILABLE CONTROL )

TECHNOLOGY (RACT) FOR VOLATILE )

ORGANIC MATERIAL EMISSIONS FROM)

GROUP 111 CONSUMER & COMMERCIAL )

PRODUCTS: PROPOSED AMENDMENTS )

TO 35 ILL. ADM. CODE218 AND219 )

Proposed Rule. Second Notice.

RIO-10

(Rulemaking - Air)

OPINION AND ORDER OF THE BOARD (by A.S. Moore)

Today the Board adopts for second notice a proposal amending its air pollution

regulations. On October 23, 2009, the Illinois Environmental Protection Agency (Agency or

Illinois EPA or IEPA) filed a proposal under provisions including the "fast-track" ruIcmaking

authority of Section 28.5 ofthe Environmental Protection Act (Act). See 415 ILCS 5110, 27,

(2008); Public Act 96-0308, eff. Aug. JJ, 2009 (P.A. 96-0308) (reenacting repealed Section

28.5). The Agency proposes volatile organic material (YOM) emission controls in response to

control techniques guidelines (CTG) issued by the United States Environmental Protection

Agency (USEPA) for the following Group 1II Consumer and Commercial Product Categories:

paper, film, and foil coatings; metal furniture coatings; and large appliance coatings. On

November 5, 2009, the Board adopted its first-notice opinion and order in this proceeding

without commenting on the substantive merits ofthe Agency's proposal. See 33 Ill. Reg. 16399,

16460 (Nov. 20, 2009); see also P.A. 96-0308 (subsection (e)).

In this opinion, the Board first provides the procedural history ofthis rulemaking before

addressing a preliminary matter and briefly summarizing the background offederal YOM

regulation in these categories. The Board then describes the processes addressed in this

rulemaking and the sources of YOM emissions from them. Next, the Board summarizes current

regulations governing those processes and the Agency's proposed amendments. The opinion then

discusses public comments before considering the matters ofthe economic reasonableness and

technical feasibility ofthe proposal. The Board then summarizes its second-notice proposal on a

section-by-section basis. Finally, the order following the opinion then sets forth the proposed

amendments for second notice review by the Joint Committee on Administrative Rules.

PROCEDURAL HISTORY

On October 23,2009, the Agency filed a rulemaking proposal to amend Parts 218 and

219 ofthe Board's air pollution regulations (Prop. 218 and Prop. 219, respectively). The Agency

filed its proposal under provisions including the "fast-track" rulemaking authority of Section

28.5 ofthe Act. See 415 ILCS 5/10,27 (2008); P.A. 96-0308. Among other documents, a

Statement of Reasons (SR) and a Technical Support Document (TSD) accompanied the proposal.
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The Agency also filed a motion for waiver of copy requirements. In an order dated November 5,

2009, the Board accepted the Agency's proposal for hearing and granted the Agency's motion

for waiver of copy requirements.

In a letter dated November 5, 2009, the Board requested that the Department of

Commerce and Economic Opportunity (DCEO) conduct an economic impact study ofthe

Agency's rulemaking proposal. See 415 ILCS 5/27(b) (2008). DCEO has not responded to the

Board's request.

In an order dated November 5, 2009, the hearing officer scheduled three hearings to take

place in Chicago: the first beginning on December 9, 2009, the second beginning on January 6,

20 I0, and the third beginning on January 20, 2009.

First notice of the proposed rules appeared in the Illinois Register on November 20, 2009.

33 III. Reg. 16399-16516 (Nov. 20, 2009); see 5 ILCS 100/5-40(b) (2008) (45-day comment

period).

On November 25,2009, the Agency pre-filed for the first hearing the testimony ofMr.

Yoginder Mahajan (Mahajan Test.). The first hearing took place as scheduled on December 9,

2009. The Board received the transcript ofthe first hearing (Tr.I) on December 10, 2009.

During the first hearing, the hearing officer admitted into the record a single exhibit, the pre-filed

testimony ofMr. Mahajan (Exh. 1). Tr.l at 8-9.

On December 28, 2009, the Agency filed a motion to amend its rulemaking proposal,

which the Board addresses in the following section ofthis opinion.

No participant pre-filed testimony for the second hearing, which took place as scheduled

on January 6, 2010. The Board received the transcript ofthe second hearing (Tr.2) on January 8,

20 IO. On the record at the second hearing, the Agency stated that it did not wish to introduce

any additional material and that it wished to cancel the third hearing scheduled to take place on

January 20,2010. Tr.2 at 7-8; see P.A. 96-0308 (subsection (1)(3)). In an order dated January

11,20 I0, the hearing officer cancelled the third hearing and set a deadline ofJanuary 22, 2010,

for filing post-hearing comments. See P.A. 96-0308 (subsection (k)).

PRELIMINARY MATTER

On December 28, 2009, the Agency filed a motion to amend its rulemaking proposal

(Mot. Amend). First, the Agency states that, "[i]n response to a Board recommendation that the

proposed application method limitations set forth in Section 218/219.204(g) and (h) be instead

placed in a more appropriate section of Subpart F, the Illinois EPA recommends moving such

limitations to Section 218/219 ...." Mot. Amend at I (~3). Second, the Agency proposes in

response to Board recommendations "that any substantive requirements contained in Board

"Notes" be instead placed in the body ofthe proposed rule." ld. at 5, 6, 7 (~~4, 5, 6).
3

Section 100.500(d) ofthe Board's procedural rules provides in pertinent part that,

"[w]ithin 14 days after service of a motion, a party may file a response to the motion. Ifno

response is filed, the party will be deemed to have waived objection to the granting ofthe

motion, but the waiver of objection does not bind the Board or the hearing officer in its

disposition ofthe motion" 35 III. Adm. Code 101.500(d). No participant has filed a response to

the Agency's motion to amend. Having reviewed the Agency's motion, the Board grants the

motion and amends the Agency's rulemaking proposal as requested. The Board below addresses

the substance ofthe amendments in providing a summary ofthe Board's second notice proposal.

BACKGROUND OF FEDERAL YOM REGULAnON

Thc Agency states that its rulemaking proposal intends to satisfY Illinois' obligation

under the Clean Air Act (CAA) to submit a State Implementation Plan (SIP) addressing

requirements for sources of YOM emissions in areas designated as nonattainment with respect to

the National Ambient Air Quality Standard (NAAQS) for ozone. SR at I, 6-7, citing 42 U.S.c.

§§ 7502, 7511a.

The Agency characterizes YOM] as "a primary precursor to the formation of groundlevel ozone, which is formed when oxides of nitrogen and YOM react in the atmosphere in the

presence ofsunlight." SR at 2. "Ground-level ozone is a major component ofsmog." SR at 2-3,

citing 72 Fed. Reg. 57217 (Oct. 9, 2007). The Agency states that, in 1997, USEPA revised the

NAAQS for ozone by replacing a I-hour standard with an 8-hour standard. Id. at 3, citing 62

Fed. Reg. 38856 (July J8, 1997), see TSD at 7. Two Illinois areas, Chicago and St. LouisfMetro

East, have been designated as moderate nonattainment areas (NAA) for the 8-hour ozone

standard2 SR at 3, TSD at 7.

These nonattainment designations trigger CAA requirements "for adopting regulations

that reduce emissions sufficiently to demonstrate attainment of the standard." SR at 4, citing 42

U.S.c. § 7502(c)(1). Specifically, the Agency claims that the CAA requires Illinois "to subm it

YOM regulations constituting RACT [reasonably available control technology] for Group ]]]

Consumer and Commercial Product Categories in ozone NAAs classified as moderate and

above." SR at 5, citing 42 U.S.c. §§ 7502(e)(1), 751Ia(b)(2). The Agency defines RACT "as

the lowest emissions limitation that a particular source can meet by applying a control technique

that is reasonably available considering technological and economic feasibility." SR at 5, citing

44 Fed. Reg. 53762 (Sept. 17, 1979); see TSD at 7. The Agency states that "Illinois was

required to submit its SIP revisions by October 9, 2008." SR at 5.

J The Agency states that YOM and volatile organic compounds (YOC) are "effectively the

same" as one another. SR at 1.

2 The Chicago nonattainment area includes the following jurisdictions: Cook, DuPage, Kane,

Lake, McHenry, and Will Counties, Goose Lake and Aux Sable Townships in Grundy County,

and Oswego Township in Kendall County. SR at 3, citing 40 C.F.R. 81.314; see TSD at 6,7.

The St. Louis/Metro East nonattainment includes the following Illinois counties: Jersey,

Madison, Monroe, and St. Clair. SR at 3, citing 40 C.F.R. 81.314; see TSD at 6, 7.
4

The Agency states that the CAA requires USEPA to "conduct a study ofthe emissions of

YOM into the ambient air from consumer and commercial products in order to determine their

potential to contribute to ozonc levels which violate thc ozone NAAQS and to establish criteria

for rcgulating emissions of YOM from such products." SR at 3, citing 72 Fed. Rcg. 57217 (Oct.

9,2007). The Agency further states that the CAA provides that "[t]he Administrator shall list

those categories of consumer or commercial products that the Administrator determines, based

on the study, account for at least 80 percent ofthe YOC emissions ... from consumer or

commercial products in areas that violate the NAAQS for ozone" and separate those categories

into groups. SR at 3, citing 42 U.S.c. 751Ib(e)(3)(A).

The Agency claims that "[t]he CAA requires that USEPA then either regulate YOM

emissions from such categories or issue a CTG in lieu of a national regulation ifthe

Administrator determines that such guidance will be substantially as effective as regulations in

reducing em issions of YOM which contribute to ozone levels in ozone NAAs." SR at 4, citing

42 U.S.C. § 751 Ib(e)(3)(C). The Agency states that "CTGs provide states with

recommendations regarding what types of controls could constitute RACT for YOM for the

applicable source categories." SR at 4, citing 72 Fed. Reg. 57217-18. The Agency claims that

"[s]tates must either adopt regulations to implement the recommendations in the CTG or adopt

alternative approaches that constitute RACT, either ofwhich must be submitted to the USEPA

for review and approval as part ofthe SIP process." SR at 4, citing 72 Fed. Reg. 57218; see TSD

at 6.

The Agency reports that, on October 9, 2007, USEPA issued final CTGs for three Group

III Consumer and Commercial Product categories. SR at 4; see TSD at 6,7. The Agency states

that "[t]hese CTGs contained information regarding sources ofVOM emissions from the

applicable industries, the recommended available control options to reduce YOM emissions, and

the cost of recommended control measures." Mahajan Test. at 2. USEPA required submission

of SIP revisions responding to the CTGs within one year. SR at 4, citing 72 Fed. Reg. 57215-18.

The Agency reports that "Illinois is required to submit these SIP revisions before the

USEPA can re-designate the Chicago and Metro East NAAs to attainment ofthe 1997 ozone

NAAQS, regardless of whether the YOM reductions obtained by the SIP revisions are actually

necessary to achieve attainment ofthe NAAQS." SR at 7, citing Wall v. USEPA, 265 F.2d 426,

433,440-42 (6th Cir. 2001); 42 U.S.c. § 7407(d)(3)(E). The Agency notes that, on July 2, 2007,

it "submitted to the USEPA an attainment demonstration for the Metro East nonattainment area

for the 1997 8-hour ozone NAAQS." SR at 7. The Agency further notes that, on March 19,

2009, it submitted an attainment demonstration for the Chicago nonattainment area. Id. The

Agency argues that "[t]hese areas cannot be redesignated to attainment ofthe ozone NAAQS,

however, unless and until the Illinois EPA submits SIP revisions in response to thc Group III

CTGs and thc USEPA approves such rcvisions." Id. at 7-8. The Agency states that its proposal

intends generally "to implement the recommendations contained in the CTGs to the extent that

such recommendations are consistent with existing regulations." SR at 10.

The Agency also notes that USEPA recently strengthened the ozone standard. SR at 8

citing 73 Fed. Reg. J6436 (Mar. 27, 2008). The Agency considers it "likely" that areas
5

designated as nonattainment for the current standards will be designated nonattainment for the

revised standard as well. SR at 8. The Agency argues that, "[w]hile attainment ofthe revised

standard is not the purpose ofthis rulemaking, it should be noted that any reduction in YOM

emissions in the NAAs resulting from these proposed amendments will improve ozone air

quality and will likely help Illinois achieve and maintain the newly revised NAAQS." ld.

DESCRIPTION OF PROCESSES AND SOURCES OF YOM EMISSIONS

Paper, Film, and Foil Coatings

The Agency states that "[pjaper, film, and foil coatings include adhesives used on tapes

and labels, and are defined as 'any protective, decorative, or functional coating applied on paper,

plastic film, or metallic foil to make certain products, including but not limited to adhesive tapes

and labels, book covers, post cards, office copier paper, drafting paper, or pressure sensitive

tapes.''' TSO at 9 (§2.1). The Agency states that this category also includes "coatings applied

through saturation or impregnation." ld. The Agency indicates that these coatings

can also be categorized as a web coating process, which typically involves the

application of a continuous layer ofcoating across either a whole or part ofthe

width of a web substrate to do the following: 1) provide a covering, finish, or

functional or protcctive layer to a substrate; 2) saturate a substrate for lamination;

or 3) provide adhesion between two substrates for lamination." ld.

The Agency lists various kinds ofcoating applicators including "rotogravure, reverse roll,

slot die, knife, flexography, Mayer rod, dip and squeeze, and extrusion/calendaring." TSO at 9,

citing Control Techniques Guideline for Paper, Foil, and Foil Coatings, Office of Air Quality

Planning and Standards, USEPA 453/R07-003 (Sept. 2007). The Agency states that "[a]n

average coating line can include a series of one or more unwind/feed stations; one or more

coating applicators; the flash off area (the portion between two or more consecutive coating

applicators or between the coating applicator and the drying oven); one or more drying ovens;

and one or more reWind/cutting stations." TSO at 9. The Agency notes that facilities also

conduct cleaning activities "to elim inate coating residue or other unwanted materials from

equipment related to coating operations." ld. Facilities conduct this cleaning with spray guns

and related operations. ld.

The Agency states that YOM emissions in this category result "from the evaporation of

volatile components ofthe coatings and cleaning materials." TSO at 9. The Agency further

states that these can result chiefly from "the process of coating application/flash-off, coating

curing/drying, and cleaning." ld. at 9-]0. The Agency indicates that "[a]bout 90% ofthe YOM

in the coatings is evaporated in the drying ovens" Id. at 10, citing Control Techniques Guideline

for Paper, Foil, and Foil Coatings, Office ofAir Quality Planning and Standards, USEPA

453/R07-003 (Sept. 2007).

Large Appliance Coatings
6

The Agency defines largc appliance coatings as "any protective, decorative, or functional

coating applied onto the surface oflarge appliances or to the constituent metal parts" TSD at 10

(§2.2). The Agency lists as examples of large appliances "residential and commercial washers,

dryers, ranges, refrigerators, freezers, water heaters, dishwashers, trash compactors, air

conditioners, and other similar products." [d. The Agency states that coatings are a significant

part of appliance manufacturing, "as they protect the metal on the large appliances from rusting

away by allowing resistance to such factors as moisture, heat, detergent, and even outdoor

elements." [d. The Agency also states that the coatings "must be durable and have superb

adhesion properties to prevent chipping or peeling." [d. The Agency indicates that specific

coatings "include paints, topcoats, basecoats, primers, enamels, sealants, caulks, inks, adhesives,

and maskants...." [d.

The Agency describes a number of processes for the application of large appliance

coatings. TSD at 10, citing Control Techniques Guidelines for Large Appliance Coatings, Office

ofAir Quality Planning and Standards, USEPA 453/R-07-004 (Sept. 2007). First, the Agency

states that, "[i]n air atomized spraying, compressed air is used to provide transfer efficiencies of

up to 40%." TSD at 10. The Agency distinguishes airless spraying, which "employs an airless

pump system to force the coating through a nozzle that is made to atomize the coating for a

transfer efficiency of between 50 to 60 percent." [d. The Agency also describes electrostatic

spraying, in which "an air or airless gun system can be created to magnetize the coating to the

substrate and achieve approximately 85% transfer efficiency." [d. The Agency states that dip

coating "involves dipping a part into a tank that contains the coating" and has a transfer

efficiency of nearly 85%. [d. The Agency describes electrodeposition as 'Just a type of dip

coating method that uses an electric field to aid the placement of a waterborne coating to a

substrate." [d. Finally, the Agency states that "flow coating is a technique that applies a coating

directly onto a substrate without atomizing the coating and usually creates 85% transfer

efficiency." [d.

The Agency states that, in large appliance coating, "[p]rimary sources ofVOM emissions

evolve from the coating application (prime, single or topcoat application)/flash-off and

drying/curing ofthe coatings and from mixing and/or thinning." TSD at 11. In addition, the

Agency cites eleaning materials as another source ofVOM emissions from this category. [d.

The Agency states that cleaning may involve different types of chemical washes, "ineluding

solvent cleaning, acid washing, phosphate washing, and de-ionized water washing," with solvent

eleaning and wetting oil treatments constituting the greatest source of emissions. [d. The

Agency also notes that "[c]leaning materials can also be used in eleaning coating equipment and

to touch up final products." [d. The Agency elaims that, although many ofthese cleaning

products are typically YOM solvents, there is greater use of alcohol and water-based eleaners.

[d., citing Control Techniques Guidelines for Large Appliance Coatings, Office of Air Quality

Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

Metal Furniture Coatings

The Agency provides examples of metal furniture: "tables, chairs, waste baskets, beds,

desks, lockers, benches, shelving, file cabinets, lamps, and room dividers that arc made in whole
7

or in part by metal." TSO at II (§2.3). The Agency defines metal furniture coatings as "any

protective, decorative or functional coating applied onto the surface of any metal furniture or any

metal part which will be assembled with other metal, wood, fabric, plastic or glass parts to form

metal furniture." /d. The Agency states that these coatings include paints and that they protect

metal furniture "from rusting away by allowing resistance to such elements as moisture, heat,

detergent, and even outdoor factors." /d. The Agency also states that the coatings "must be

durable and have superb adhesion properties to prevent chipping or peeling." /d.

The Agency states that metal furniture manufacturing involves four main processes, the

first of which is raw material preparation. TSO at 11. The second process, surface preparation,

consists ofthe following steps: 1) alkaline or acid cleaning, 2) water rinse, 3) iron phosphate

treatment, 4) water rinse, and 5) pre-treatment and/or another final water rinse. /d. Thc third

process, coating and adhesive application operations, includes curing or drying ofthe coating.

/d. In the fourth process, "the final unit is assembled and packaged for shipmen!."!d. at 12. The

Agency further states that surface preparation, coating application, and cleaning activates use

YOM-containing compounds such as coatings, thinners, and cleaning materials. /d. at II.

The Agency states that, "[s]imilar to the large appliance coatings, the primary source of

YOM emissions can occur from the evaporation ofthe volatile contents ofthe coatings and

cleaning materials." TSO at 12. Specifically, emissions occur when solvents vanish "from the

coating as it is being placed onto the part, or even when solvents are being used during the final

cleaning process." /d. The Agency claims "that the more efficient that a coating application

technique is in enabling a transfer of coatings to the metal furniture part, the volume of coatings

needed during production decreases, which thereby results in lower YOM emissions." !d., citing

Control Techniques Guidelines for Metal Furniture Coatings, Office of Air Quality Planning and

Standards, USEPA 453/R-07-005 (Sept. 2007).

SUMMARY OF EXISTING REGULATIONS

The Agency states that it now regulates YOM emissions in the two Illinois NAAs Irom

coating operations including paper, film, and foil; metal furniture; and large appliances. TSO at

28 (§5.1). The Board briefly summarizes those existing regulations in the following subsections.

Paper, Film, and Foil Coatings

The Agency states that Parts 218 and 219 currently regulate YOM emission from paper,

film, and foil coating processes. TSO at 28 (§5.1.1); see Mahajan Test. at 3. Specifically, the

Agency states that "VOM content limitations are prescribed for paper coating operations that

emit 15 Ib/day or more ofVOM from all associated coating operations." TSO at 28; see 35 III.

Adm. Code 218.208, 219.208. On and after March 15, 1996, those limitations are 0.28 kg/lor

2.3 lb/gal. 35 Ill. Adm. Code 218.204(c), 219.204(c). The Agency further states that,

"[a]lternatively, sources may install and operate YOM capture and control systems that provide

81 % reduction in overall YOM emission, and the control device must achieve 90% efficiency

(control devices include afterburner, carbon adsorption, condensation, or absorber scrubber

system)." TSO at 28-29; see 35 Ill. Adm. Code 218.207(b), 2J9.207(b).
8

Large Appliance Coatings

The Agency states that "[s]pecific regulations for large appliance coatings are located in

Subpart F...." TSD at 29 (§5.1.2); see 35 III. Adm. Code 218.204-217, 219.204-217, Mahajan

Test. at 4. The Agency further states that "[t]he applicable threshold for the total actual

uncontrolled YOM emission from all large appliance coating operations is 15 Ibs/day or more."

TSD at 29; see 35 III. Adm. Code 218.208, 219.208. The Agency notes that existing regulations

do not distinguish between coating types and instead distinguish baked and air-dried operations.

TSD at 29; see 35 III. Adm. Code 218.204(h), 219.204(h). On and after March 15, 1996, those

limitations are 0.28 kg/l and 2.3 Ib/gal for baked coatings and 0.34 kg/l and 2.8 Ib/gal for airdried coatings. TSD at 29; see 35111. Adm. Code 218.204(h), 219.204(h). The Agency further

slates that the regulations provide an alternative requiring "a coating line to be equipped with a

capture system and control device that provides an 81 % reduction in overall YOM emissions,

and the control device ... achieves a 90% efficiency." TSD at 29; see 35 Ill. Adm. Code

218.207(b),219.207(b).

Metal Furniture Coatings

The Agency states that the "[r]egulations for metal furniture coating operations are very

similar to the regulations for large appliance coatings," except for limits applicable before March

15, 1996. TSD at 30 (§5.1.3); see 35 111. Adm. Code 218.204(g), 219.204(g), see also Mahajan

Test. at 4.

SUMMARY OF AGENCY'S PROPOSED REGULATIONS

The Agency claims that its proposed amendments are consistent with the 2007 USEPA

CTGs and that its proposal controls YOM emissions from paper coating, metal furniture coating,

and large appliance coating. TSD at 30 (§5.2); see id. at 7-8 (summarizing CTG

recommendations). The Agency proposes that compliance with its proposed new regulations

begin on May 2, 2011. TSD at 30. Below, the Board briefly summarizes the Agency's proposed

revisions to Parts 218 and 219.

Paper, Film, and Foil Coatings

The Agency states that it proposes no "change to the applicability threshold of 15 Ib/day

or more for control requirements for paper coating." TSD at 30 (§5.2.1). The Agency proposes,

however, "to specify the YOM content limits of paper coating in Ib (kg) ofYOM per Ib (kg) of

solids and equivalent YOM limits in kg (Ib) ofYOM per kg (Ib) of coating." ld., Mahajan Test.

at 3. The Agency also proposes "a lower YOM limit of 0.20 kg per kg ofsolids (0.20 Ib/lb of

solids) for pressure sensitive tape and label surface coating." Mahajan Test. at 3; see TSD at 14-

15. The Agency claims that, "[e]xcept for pressure sensitive tape and label surface coating, the

YOM limits are equivalent to the existing YOM limits for paper coating." TSD at 30; see Prop.

218 at 12, Prop. 219 at II.
9

The Agency states that "[a]ffected sources may use add on capture and control systems to

comply with the YOM content limits ofthe coatings." TSD at 31. However, the Agency

proposes "to increase the ovcrall control efficiency standards to 90 percent from the existing 81

percent overall control efficiency ofthe add-on capture and control systems." Id., Mahajan Test.

at 3; see TSD at 14-15. In addition, the Agency proposes that "[t]hese limits can be met through

daily within-line averaging (i.e., averaging the YOM content of materials used on an individual

surface coating line each day)." TSD at 14.

In addition, the Agency proposes a new Section 218/219.218 prescribing standards for

the use ofcleaning materials at applicable sources on and after May 1, 20 II. TSD at 31; see

Prop. 218 at 51-52, Prop. 219 at 48-49. For cleaning matcrials, the Agency states that "add-on

controls would be too costly because the area to be controlled is very large, and would thereby

require a large volume ofair to be captured and directed to a control device." TSD at 14. The

Agency lists the following as work practices that may be employed to reduce YOM emissions

from cleaning materials:

I) place all YOM-containing cleaning materials in closed containers; 2) guarantee

that mixing and storage containers used for YOM-containing materials are kept

closed at all times except when depositing or removing these materials; 3) curtail

spills ofYOM-containing cleaning materials; 4) transfer YOM-containing

clcaning materials from one location to another in closed containers or pipes; and

5) reduce YOM emissions from cleaning ofstorage, mixing, and conveying

equipment. ... TSD at 14-15

Large Appliance Coatings

The Agency states that it proposes no "change to the applicability requirement of 15 lb

YOM/day or more for the control requirements for large appliance coatings. TSD at 32 (§5.2.2).

The Agency proposes to "specifY separate YOM content limits for one-component and multicomponent general purpose coatings." !d.; see Prop. 218 at 15, Prop. 219 at 14, TSD at 18-19

(Tables 2,3), Mahajan Test. at 4. The Agency also proposes "specific emission limits for certain

specialty coatings." TSD at 32; see Prop. 218 at 15-16, Prop. 219 at 14-15, TSD at J8-19

(Tables 2, 3), Mahajan Test. at 4. In addition, the Agency proposes "separate emission limits for

baked and air-dried coatings." TSD at 32; see Prop. 218 at ] 5-16, Prop. 219 at 14-15, TSD at

18-19 (Tables 2, 3), Mahajan Test. at 4.

The Agency's proposal requires the use of one or more application methods: electrostatic

application, HVLP [high volume low pressure] spray, flow coat, roller coat, or dip coat including

electrodeposition. The proposal allows the use of other coating application methods capable of

achieving a transfer efficiency equivalent or better than that achieved by HVLP spraying with the

approval ofthe Agency. TSD at 32; see Prop. 218 at 16-17, Prop. 219 at 15-16, Mahajan Test. at

4-5. Also, the proposal provides "that stencil coatings, safety-indicating coatings, solid-film

lubricants, electric-insulating and thermal-conducting coatings, touch-up and repair coatings, or

coating applications utilizing hand-held aerosol cans are exempt from YOM content limits."

TSD at 32; see Prop. 218 at 16, Prop. 219 at 15-16, Mahajan Test. at 4.
10

The Agency states that "[a]ffected sources may use add-on capture and control systems to

comply with the YOM content limits ofthe coatings." TSD at 32. However, the Agency

proposes "to increase the overall control efficiency standard to 90 percent from the existing 81

percent overall control efficiency." Id., Mahajan Test. at 5; see TSD at 18-19 (Tables 2, 3). In

addition, the Agency proposes a"new Section 218/219.218 establishing work practice standards

for large appliance coatings. TSD at 3], ~'ee Prop. 218 at 51-52, Prop. 219 at 48-49, TSD at 20

(§ 3.2.3) (USEPA recommendations), Mahajan Test. at 5.

Metal Furniture Coatings

The Agency states that "[t]he proposed applicability, YOM limits, add-on control device

efficiency, and work practices requirements for metal furniture coatings are identical to the

proposed regulations for large appliance coatings." TSD at 33 (§5.2.3); see Mahajan Test. at 4-

5; see also TSD at 20-25 (Tables 4,5) (USEPA recommendations).

ECONOMIC REASONABLENESS AND TECHNICAL FEASIBILITY

In pre-filed testimony, Mr. Mahajan states that "[t]he Agency believes that the proposed

changes are technically feasible and economically reasonable." Mahajan Test. at 6. The Agency

further indicates that "[t]he technology for controlling YOM emissions from Group III product

categories is both technically feasible and economically reasonable." TSD at 9. The Agency

argues that "[a]ffected sources can meet the requirements in the proposed amendments through a

number ofreadily available control techniques." Id. In the following subsections, the Board

summarizes the record pertaining to the issues of economic reasonableness and technological

feasibility.

Affected Sources and Projected YOM Emissions Reductions

The Agency states that it reviewed its emission inventory data to identify emission

sources potentially affected by these proposed regulations. TSD at 34. The Agency reports that

it has identified 24 potentially affected sources, all but two of which are situated in the Chicago

NAA. ld. at 6, 34. In the following subsections, the Board summarizes the record regarding

these sources and the anticipated emissions reductions in each ofthe categories addressed in this

rulemaking.

Paper, Film, and Foil Coatings

The Agency determined that 16 sources in the Chicago NAA and two in the Metro-East

NAA are potentially affected by these proposed regulations. TSD at 34 (Table 10), Mahajan

Test. at 3-4. The Agency states that seven ofthe 16 sources in the Chicago NAA comply

through the use of add-on capture and control systems. TSD at 34, Mahajan Test. at 3. The

Agency claims that "[a]1I other affected sources use compliant coatings to comply with the

regulations." TSD at 34. The Agency further claims that "no new add-on capture and control

systems will be installed to meet the proposed regulations." Id., see Mahajan Test. at 3-4.
II

Instead, the Agency "expects that affected sources will continue to use compliant coatings, or

upgrade their existing add-on capture and control systems to meet the proposed YOM emissions

limits" Mahajan Test. at 4; see TSD at 34.

The Agency states that, in 2005, these 18 sources accounted for total YOM emissions of

109.83 tons. TSD at 34 (Table 10). The Agency states that its proposal will reduce YOM

emissions by 21.45 tons per year in the Chicago NAA at a cost of$1 ,200 per ton ofVOM

reduced. Mahajan Test. at 4, TSD at 34. The Agency states that it "does not expect any

reduction in YOM emissions" in the Metro-East NAA. Mahajan Test. at 4; see TSD at 34.

Large Appliance Coatings

The Agency determined that "[t]here are no affected sources of large appliance coatings"

in either the Chicago or Metro-East NAA. Mahajan Test. at 5; see TSD at 34 (Table 10).

Accordingly, the Agency expects its proposal to yield no YOM emissions reductions in this

category. See TSD at 34.

Metal Furniture Coatings

The Agency "determined that there are six affected sources ofmetal furniture coatings in

the Chicago NAA and none in the Metro-East NAA." Mahajan Test. at 5; see TSD at 34 (Table

10). The Agency states that, in 2005, these six sources accounted for total YOM emissions of

89.4 tons. TSD at 34. However, the Agency states that it "expects that affected sources will

continuc using compliant coatings to comply with the YOM limits." Mahajan Test. at 5.

Accordingly, the Agency expects its proposal to yield no YOM emissions reductions in this

category. Mahajan Test. at 5; see TSD at 34 (Table 10).

Technical Feasibility

Paper, Film, and Foil Coatings

The Agency states that paper, film, and foil coating operations commonly employ

pollution prevention measures such as product substitution/reformulation to reduce YOM

emissions. TSD at 13 (§3.1); see SR at 9. The Agency further states that "[I]ower YOM contcnt

coatings, such as waterborne and higher solids content coatings, or coatings with no solvents

may be used to reduce YOM emissions by reducing or eliminating the organic solvent present in

the coatings." TSD at 13. The Agency reports that "manufacturers have developed and are

continuing to develop waterborne and other alternative coating formulations that rcplace

conventional organic solvent-based coatings" Id. The Agency acknowledges, however, that

available low-YOM coatings and coatings with no solvent may not satisfy the performance

requirements of certain coating operations. [d.

The Agency claims that, if these low-YOM coatings do not meet the performance

requirements, emissions "can be reduced by the use of capture systems in conjunction with addon control systems that either destroy or recover the YOM in the exhaust streams." TSD at 13.
]2

The Agency reports that paper, film, and foil coating operations typically rely on two categories

of control devices: "combustion (thermal or catalytic oxidation) and recovery (adsorption and

condensation)." ld. The Agency claims that, "[i]n general, oxidation and adsorption systems can

achieve destruction efficiency of greater than 95 percent as applied to surface coating application

operations with high and constant concentration of YOM." Id. at 13-14, citing Control

Techniques Guideline for Paper, Foil, and Foil Coatings, Office ofAir Quality Planning and

Standards, USEPA 453/R07-003 (Sept. 2007).

The Agency states that "[p]ollution prevention is the most common emission control

technique for reducing YOM emissions from cleaning materials." TSD at 14. These measures

include "[r]educing the composite vapor pressure or YOM content ofthe clcaning material

used." Id. The Agency acknowledges, however, that "little information is available regarding

the types oflow-YOM or YOM-free cleaning materials that could be used in the paper, film, and

foil surface coating industry." Id.

Large Appliance Coatings

The Agency states that "[s]everal kinds of controls are available to industry to control

YOM emissions from coatings and the cleaning materials associated with this category." TSD at

15 (§3.2); see SR at 9. Pollution prevention measures include product

substitutionlreformulation, through which "affected sources can use waterborne coatings, higher

solids solvent-borne coatings, and powder coatings to reduce YOM emissions through

decreasing or cven eliminating the amount of organic solvent in the coatings." TSD at 15. The

Agency claims that "work practices may be used to reduce YOM emissions from coatings during

paint mixing, paint storage, and paint transfer operations." Id. at 16.

The Agency reports that "[e]mission capture and add-on control systems can also be used

to reduce YOM emissions from large appliance coating operations." TSD at 16. The Agency

states that

[t]he most common method for the destruction of YOM from coatings is thcrmal

oxidation, and can include the following: (I) direct, gas-fired, thermal

recuperative oxidation; (2) direct, gas-fired thermal regenerative oxidation; (3)

direct, electrically heated, thermal regenerative oxidation; (4) direct, electrically

heated, catalytic oxidation; and (5) direct, gas-fired, catalytic oxidation. ld.

The Agency claims that controls ofthese types "can achieve a YOM control efficiency between

80% and 98%, with thermal oxidation being the more preferred method for YOM destruction."

Id., citing Control Techniques Guidelines for Large Appliance Coatings, Office ofAir Quality

Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

The Agency states that options for controlling YOM emissions from cleaning materials

include pollution prevention measures. TSD at 16. The Agency reports that, "[f]or product

substitution/reformulation, alternative cleaners, such as alcohols and citrus-based cleaners, can

be employed to restrict YOM emissions from cleaning operations." Id. The Agency also repOlts
13

that "[a]n example of a work practice procedure that can be utilized to further reduce YOM

emissions from cleaning opcrations involves nozzle maintenance, which is an integral part of any

metal pre-treatment system - an improperly maintained nozzle can lower spray impact and can

distort spray systems, and thereby reduce the cleaning efficiency." ld. The Agency also

indicates that sources can use emission capture and add-on controls to reduce YOM emissions

from cleaning operations in this category. ld. at 17.

Metal Furniture Coatings

The Agency states that sources in this category have available two techniques for

reducing YOM emissions. TSD at 20 (§3.3); see SR at 9. First, as pollution prevention

measures, "[a] source may choose to substitute higher-solvent coatings with either powder

coatings, waterborne coatings, higher solids coatings, UY coatings, electrocoatings, and

autophoretic coatings, all ofwhich have little or no solvents." TSD at 20. Second, when lowYOM coatings or coatings with no solvent fail to meet the performance standards of an

operation, the use ofmore effective application equipment can reduce emissions. Id. The

Agency reports that "[c]onventional air atomized application systems have typical transfer

efficiencies between 25-40% using high atomizing air pressure. More modern technologies

include electrostatic and high volume/low flow pressure (HYLP) spray equipment, which can

attain far greater transfer efficiencies, which results in less dependence on YOM-containing

materials." ld. at 20-21, citing Control Techniques Guidelines for Metal Furniture Coatings,

Office of Air Quality Planning and Standards, USEPA 453/R-07-005 (Sept. 2007).

The Agency states that, in addition to pollution prevention measures, sources in this

category can reduce YOM emissions through "use of capture systems and add-on control

devices, which either destroy or recover the YOM in the exhaust stream." TSD at 21. The

Agency cites as an example of a capture system "such simple components as hoods and

enclosures, which collect solvent-filled air from process vents (such as spray booths or bake

oven vents) and/or fugitive emissions from the flash-off area, and direct it to a control device."

Id. The Agency states that control devices "include combustion (thermal or catalytic oxidation)

and recovery (adsorption and absorption)," which "can reach a control efficiency of 95% or

greater." ld. The Agency lists other control technologies that are not in wide use:

"condensation, biodegradation, and UY oxidation." Id.

Regarding control of emissions from cleaning materials in this category, the Agency

states that pollution prevention is "the most widely used" technique. TSD at 21. Sources may

use low-YOM or YOM-free cleaning materials and can also employ various work practice

procedures. !d.

Economic Reasonableness

The Agency states that it "relied on the U.S. EPA's economic analysis in the respective

CTGs to determine the economic costs and impacts associated with the control of YOM

emissions from paper, film, and foil coatings; metal furniture coatings; and large appliance
14

coatings opcrations in III inois' NAAs." TSO at 26 (§ 4.0). In the following subsections, the

Board reviews the record on these issues.

Paper, Film, and Foil Coatings

The Agency states that USEPA "assumed that about 47% ofthe facilities in the 2002

National Emissions Inventory (NEI) database (119 facilities) were currently in compliance with

the 2002 National Emissions Standards for Hazardous Air Pollutants (NESHAP)." TSO at 26

(§4.1). The Agency further states that, based on the average number of coating lines per facility

whose potential emissions exceeded applicability thresholds, "the total annual cost was about

$24.5 million per year." Id. The Agency claims that, "if facilities that exceed the emission

thresholds and that are located in NAAs utilized the 90% emissions reduction, it would create an

emission reduction [of] 20,800 tpy." Id. The Agency states that the CTG expects "costeffectiveness of implementing the CTG's approaches to control YOM emissions would be about

$1,200 per ton." Id.

The Agency states that USEPA expects the use of add-on controls to reduce emissions

from cleaning materials to be costly. TSO at 26. The Agency attributes this cost to the

likelihood that "the area that would be controlled has a large volume of air that would be

captured and directed to a control device." Id., citing Control Techniques Guideline for Paper,

Foil, and Foil Coatings, Office ofAir Quality Planning and Standards USEPA 453/R07-003

(Sept. 2007).

Large Appliance Coatings

The Agency states that USEPA expects affected sources to rely on the low-YOM

coatings materials alternative. TSO at 26 (§4.2). The Agency attributes this expectation to two

factors: "1) complying low-YOM coatings are already available on the market at a cost that is

not much greater than the cost of coating materials with higher YOM contents; and 2) the use of

add-on controls to reduce YOM emissions from average spray coating operations would be a

more costly alternative." Id. at 26-27.

The Agency states that, by taking into account ihe use of low-YOM coatings, the 90%

overall control efficiency, and cleaning materials work practices, USEPA expects "that the costeffectiveness for a medium sized facility that uses waterborne prime and higher solids topcoat

would be approximately $425 per ton in 2006 dollars" TSO at 27. The Agency notes, however,

that "the 2002 NESHAP presented a control cost of $480,000 for approximately 1,000 tons of

HAP reduction from 74 facilities anticipated to be subject to the rule ($480 per ton ofHAP

reduced in 2006 dollars)." Id. The Agency reports that USEPA consequently expects an

approximate cost-effectiveness "of about $500 per ton of YOM reduced, and a total annual cost

ofthe 1,000 tpy of emissions reduction to be $500,000." Id.. citing Control Techniques

Guidelines for Large Appliance Coatings, Office ofAir Quality Planning and Standards, USEPA

453/R-07-004 (Sept. 2007).

Metal Furniture Coatings
15

The Agency states that USEPA relied on the 2002 NE1 database to estimate that

nationally there are 143 metal furniture facilities located in an ozone NAA and whosc YOM

cmissions equal or exceed the applicability threshold. TSD at 27 (§4.3). The Agency states that

USEPA assumes affected sources will rely on the low-YOM coatings materials alternative. /d.

The Agency attributes this expectation to two factors: "I) complying low-YOM coating

materials are already available on the market at a cost that is not much greater than the cost of

coating materials with higher YOM contents; and 2) the use of add-on controls to reduce YOM

emissions from average spray coating operations would be a more costly alternative." /d.

The Agency states that studies carried out for the 2003 NESHAP showed that "the cost to

implement the control alternatives from the U.S. EPA's CTG for this category averaged across

all sizes offacilities was as high as $1,670 per facility." TSD at 27. Regarding the 143 facilities

cited in the preceding paragraph, "total annual costs were estimated to be approximately

$240,500" /d. The Agency claims that implementation ofthe proposed regulations "will result

in a 35% (1,200 tpy) reduction in YOM emissions from metal furniture coatings." /d. The

Agency states that "U.S. EPA calculated the cost effectiveness to be about $200 per ton in YOM

emissions reduction." /d.

Summary of Economic Reasonableness and Technical Feasibility

Although the Board in a letter dated November 5, 2009, requested that DCEO conduct an

economic impact study on the Agency's amended rulemaking proposal (see 415 1LCS 5/27(b)(l)

(2008)), the Board to date has received no response to that request. At the second hearing, the

Board received no testimony or comment regarding the absence of any response to the request.

See Tr.2 at 6-7.

In his pre-filed testimony on behalf ofthe Agency, Mr. Mahajan states that "[t]he Agency

believes that the proposed changes are technically feasible and economically reasonable."

Mahajan Test. at 6. The Agency further states that "[t]he technology for controlling YOM

emissions from Group III product categories is both technically feasible and economically

reasonable." TSD at 9. The Agency argues that "[a]ffected sources can meet the requirements in

the proposed amendments through a number ofreadily available control techniques." [d.

No participant has offered evidence or arguments rebutting the Agency's general position

on these issues. Having reviewed the record before it on thc issues offeasibility and

reasonableness, the Board finds that the Agency's proposal, as amended by the motion to amend,

is both technically feasible and economically reasonable.

PUBLIC COMMENT

As noted above, first notice ofthe proposed rules appeared in the Illinois Register on

November 20, 2009, and began a 45-day public comment period. 33 III. Reg. 16399-16516

(Nov. 20, 2009); see 5 1LCS 100/5-40(b) (2008). Pursuant to a hearing officer order dated

January 1I, 2010, post-hearing comments were due on or before January 22,2010. See P.A. 96-
16

0308 (subsection (k)). However, the Board has not received a public comment during this

proceeding. Accordingly, the Board turns in the next section ofthe opinion to a summary of its

second-notice proposal.

SUMMARY OF BOARD'S SECOND NOTICE PROPOSAL

Subpart A: General Provisions

Existing Subpart A provides general requirements regarding organic material emissions

in Illinois' two ozone NAAs. See 35 Ill. Adm. Code 218.100-114, 219.100-113. The Agency's

proposal seeks only to amend Section 218/219.106, which establishes compliance dates. See 35

III. Adm. Code 218.1 06, 219.106. Specifically, the Agency proposes to add a new Section

218.1 06(e) and a new Section 219.1 06(e), both of "which establish May I, 2011, as the

compliance date for sources subject to the rulemaking proposaL" SR at 10; see Prop. 218 at 9,

Prop. 219 at 8-9. In responding to questions at the first hearing, the Agency suggested that this

deadline should allow ample time for affected source to comply with the rule. Tr.1 at I I. Thc

Agency also indicated that this proposed compliance date would not interfere with its pending

demonstrations that the two NAAs have attained the ozone NAAQS. !d. at 12.

Subpart F: Coating Operations

Existing Subpart F addresses YOM emissions from coating operations. See 35 Ill. Adm.

Code 218.204-217, 219.204-217. The Agency proposes a number of amendments to the

provisions in that Subpart. See Prop. 218 at 10-52, Prop. 219 at 9-49. In this subsection ofthe

opinion, the Board separately addresses those proposed amendments on a section-by-seetion

basis.

Section 218/219.204: Emission Limitations. The Agency states that these sections

currently "speeify YOM limits in terms ofmass of YOM per volume of coating for paper

coating" and also "for air dried and baked coatings for large appliance coatings and metal

furniture coatings." Mahajan Test. at 3, 4; see 35 Ill. Adm. Code 218.204,219.204. In its

proposal, the Agency first seeks to amend these sections so that their introductory paragraphs

refer to revisions made in subsequent subsections. SR at 11; see Prop. 218 at 10, Prop. 219 at 9.

Subsection (cl. The Agency proposes to amend this subsection "to specify YOM limits

in terms of mass ofYOM per mass ofsolids applied, and equivalent limits in terms ofmass of

YOM per mass of coatings applied." Mahajan Test. at 3; see Prop. 218 at 12, Prop. 219 at 1I.

Regarding pressure sensitive tape and label surface coating, the Agency proposes "a lower YOM

limit of 0.20 kg per kg ofsolids (0.20 Ib/lb ofsolids)." Mahajan Test. at 3; see Prop. 218 at 12,

Prop. 219 at 11. The Agency argues that, except for these two categories of pressure sensitive

tape and label surface coating, "the YOM limits are equivalent to the existing YOM limits for

paper coating." Mahajan Test. at 3. The Agency further argues that these limitations reflect

those set forth in the CTG. See id.
17

The Note following this subsection addresses the application of its provisions. See 35 III.

Adm. Code 218.204(c), 219.204(c). The Agency also seeks to add to this Note language

providing that, "[o]n and after May 1,2011, the paper coating limitation shall also not apply to

coating performed on or in-line with any digital printing press, or to size presses and on-machine

coaters on papermaking machines applying sizing or water-based clays." Prop. 218 at 12, Prop.

219 at II; see SR at II. In its motion to amend, the Agency responds "to a Board

recommendation that any substantive requirements contained in Board "Notes" be instead placed

in the body ofthe proposed rule." Mot. Amend at 5 ('14); see 'I'Ll at 15. The Agency seeks to

amend its proposal by adding clarifying language to the Note and re-designating it as new

subsection (c)(3). Mot. Amend at 5.

Subsectioll (gl. This provision now establishes limits "in terms ofmass of YOM pcr

volume of coating for air dried and baked coatings" for metal furniture coatings. Mahajan Test.

at 4; see 35 III. Adm. Code 218.204(g), 219.204(g). The Agency proposes to amend this

subsection to restrict the YOM content ofthese coatings "to the limitations set forth in the CTG."

SR at II. More specifically, the Agency seeks to establish "YOM limits for one-component and

multi-component general purpose coatings, and provide specific YOM emission limits for certain

specialty coatings." Mahajan Test. at 4; see Prop. 218 at 13-14, Prop. 219 at 12-13. For a

number oftypes of coatings, the Agency proposes separate emission limits in terms ofmass of

YOM per volume of coatings for baked and air-dried coatings. Mahajan Test. at 4; see Prop. 218

at 13-14, Prop. 219 at 12-13. In addition, the Agency proposes "equivalent YOM limits in terms

ofmass ofYOM per volume ofsolids applied." Mahajan Test. 4; see Prop. 2 I8 at 13-I4, Prop.

219 at 12-13; see also Tr.1 at 12-14.

The Agency also proposes "that such limitations shall not apply to stencil coatings,

safety-indicating coatings, solid-film lubricants, electric-insulating and thermal-conducting

coatings, touch-up and repair coatings, or coating applications using hand-held aerosol cans."

SR at II; see Mahajan Test. at 4, Prop. 218 at 14, Prop. 219 at 13. Responding to a question at

the first hearing, the Agency explained its basis for these exclusions. The Agency states that

USEPA determined in the CTG that low-YOM coatings are not available in these categories,

requiring sources in those categories to use coatings with greater YOM content. Tr.1 at 14-15.

The Agency also suggested that these excluded categories employ coatings at relatively low rates

or volumes. See id. at IS.

Also during the first hearing, the Agency responded to a question by agreeing that it

proposed to add language exempting these categories in a note attached to subsection (g)(2).

Tr.1 at 15; see Prop. 218 at 14, Prop. 219 at 13. Although the Agency suggested that this

organization was consistent with other provisions in Subpart F, it agreed to incorporate the

proposed exemptions into the text ofthose regulations. See 'I'Ll at 15-16. In its motion to

amend, the Agency proposed to redesignate the language ofthe proposed note as a new

subsection (g)(3). Mot. Amend at 7 (116).

The Agency's proposal originally sought to require that metal furniture coating lines

employ specific application methods. SR at I I. Responding to a question at the first hearing,

the Agency indicated that it would consider whether these requirements should remain as
18

proposed in subsection (g)(3) or should be codified in another section. See Tr.1 at 19-20. In its

motion to amend, the Agency proposed to place these application method limitations in Section

218/219.218 addressing work practice standards. Mot. Amend at 1-5 (~3). The Board addresses

those requirements below in its summary of proposed Section 218/219.218. See infra at 20-21.

Subsection a,i. This provision now establishes limits "in terms of mass of YOM per

volume of coating for air dried and baked coatings" for large appliance coatings. Mahajan Test.

at 4; see 35 Ill. Adm. Code 218.204(h), 219.204(h). The Agency proposes to amend this

subsection to restrict the YOM content ofthcse coatings "to the limitations set forth in the CTG."

SR at 11. More specifically, the Agency seeks to establish "YOM limits for one-component and

multi-component general purpose coatings, and provide spccific YOM emission limits for certain

specialty coatings." Mahajan Test. at 4; see Prop. 218 at 15-16, Prop. 219 at 14-15. For a

number oftypes of coatings, the Agency proposes separate emission limits in terms ofmass of

YOM per volume of coatings for baked and air-dricd coatings. Mahajan Test. at 4; see Prop. 218

at 15-16, Prop. 219 at 12-13. In addition, the Agency proposes "equivalent YOM limits in terms

of mass of YOM per volumc ofsolids applied." Mahajan Test. 4; see Prop. 218 at 13-14, Prop.

219at 12-13;see also Tr.1 at 14-15.

The Agency also proposes "that such limitations shall not apply to stencil coatings,

safety-indicating coatings, solid-film lubricants, electric-insulating and thermal-conducting

coatings, touch-up and repair coatings, or coating applications using hand-held aerosol cans."

SR at II; see Mahajan Test. at 4, Prop. 218 at 16, Prop. 219 at 15-16. Responding to a question

at the first hearing, the Agency explained its basis for these exclusions. The Agency states that

USEPA determined in the CTG that low-YOM coatings are not available in these categories,

requiring sources in those categories to use coatings with greater YOM content. Tr.1 at 14-15.

The Agency also suggested that these excluded categories employ coatings at relatively low rates

or volumes. See id. at 15.

Also during the first hearing, the Agency responded to a question by agreeing that it

proposed to add language exempting these categories in a note attached to subsection (h)(2).

Tr.1 at 15; see Prop. 218 at 16, Prop. 219 at 15-16. Although the Agency suggested that this

organization was consistent with other provisions in Subpart F, it agreed to incorporate the

proposed exemptions into the text ofthose regulations. See Tr.l at 15-16. In its motion to

amend, the Agency proposed to redesignate the language ofthe proposed note as a new

subsection (h)(3). Mot. Amend at 6-7 (~5).

The Agency's proposal originally sought to require that metal furniture coating lines

employ specific application methods. SR at 11. Rcsponding to a question at the first hearing,

the Agency indicatcd that it would consider whether these requirements should remain as

proposed in subsection (h)(3) or should be codified in another section. See Tr.l at ]9-20. In its

motion to amend, the Agency proposed to place these application method limitations in Section

218/219.218 addrcssing work practice standards. Mot. Amend at 1-5 (~3). The Board addresses

those requirements below in its summary ofproposed Section 218/219.218. See infra at 20-21.
]9

Section 218/219.205: Daily-Weighted Average Limitations. Existing Section

218/219.205 allows compliance with the limitations in Section 218/219.204 through a daily

weighted averaging alternative. See 35 III. Adm. Code 218.205,219.205. The Agency first

proposes to amend this Section by adding a subsection (j) to Section 218.205 and a subsection (i)

to Section 219.205 to provide "requirements for paper coating lines utilizing the dai Iy weighted

averaging altcrnative on and after May I, 2011 " SR at 12; see Prop. 218 at 29-30, Prop. 219 at

27. The Agency proposes to amend the introductory paragraphs ofthese Sections to add a

reference to the proposed new subsections. SR at 12, see Prop. 218 at 24, Prop. 219 at 22.

Finally, the Agency also proposes to amend the existing subsection (a) to provide that its

requirements apply to paper coating lines only until May 1,2011. SR at 12; see Prop. 218 at 24,

Prop. 219 at 22.

Section 218/219.207: Alternative Emission Limitations. Existing Section 218/219.207

establishes alternative emission limitations based upon the operation of a capture system and

control device. See 35111. Adm. Code 218.207, 219.207. The Agency first proposes to amend

this Section by adding a subsection (I) to Section 218.207 and a subsection (k) to Section

219.207 to set "forth the requirements for paper, metal furniture, and large appliance coating

lines utilizing the alternative emissions limitation on and after May 1,2011." SR at 12; see Prop.

218 at 34, Prop. 219 at 31. The Agency also proposes to amend the existing subsection (a) to

refer to the proposed new subsections. SR at 12, see Prop. 218 at 30, Prop. 219 at 27. The

Agency also proposes to amend the existing subsection (c), (j), and (k) in Section 218.207 and

the existing subsections (c), (i), and (j) in Section 219.207 "to provide that such subsections only

apply to paper coating lines, metal furniture coating lines, and large appliance coating lines,

respectively, until May I, 201 L" SR at 12; see Prop. 218 at 31, 33, Prop. 219 at 28, 30-31.

Section 218/219.210: Compliance Schedule. Existing Section 218/219.210 establishes

compliance schedules for coating lines subject to various requirements under Subpart F. 35 III.

Adm. Code 218.2] 0, 219.210. The Agency proposes to add a new subsection (g) providing

"that, on and after a date consistent with Section 218/219.106, sources subject to the proposed

paper, metal furniture, or large appliance coating limitations shall comply with such limitations,

as well as with all other applicable provisions in Subpart F." SR at 12; see Prop. 218 at 35, Prop.

219 at 32. The Agency also proposes to amend the introductory paragraph ofthe section to refer

to the proposed new subsection. SR at 12; see Prop. 218 at 34, Prop. 219 at 31.

Section 218/219.211: Recordkeeping and Reporting. Existing Section 218/219.211

establishes recordkeeping and reporting requirements for affected coating operations. 35 III.

Adm. Code 218.211, 219.211. The Agcncy proposes to amend various subsection ofthat

provision, as described separately below. See Prop. 218 at 35-46, Prop. 219 at 32-44.

Subsection (c). The Agency proposes to amend subsection (c) "to provide that, for paper

coating lines subject to the proposed YOM content limitations, YOM content information shall

be maintained and/or reported in terms of weight ofYOM per weight ofsolids or coatings, as

applicable, as applied each day on each coating line" SR at 13; see Prop. 218 at 39, Prop. 219 at

36. The Agency also proposes to amend this subsection "to provide that metal furniture and

large appliance coating lines subject to the proposed YOM content limitations maintain and/or
20

report YOM content information in terms of weight of YOM per volume of each coating or

solids, as applicable, as applied each day on each coating line, and report the application

methodes) used to apply coatings on each subject coating line." SR atl3; see Prop. 218 at 39,

Prop. 219 at 36. The Agency also seeks to require that "[p]aper, metal furniture, and large

appliance coating lines shall also maintain and report certified product data sheets for each

coating applied on each line." SR at 13; see Prop. 218 at 39-40, Prop. 219 at 37.

Subsection (d). The Agency proposes to amend subsection (d) "to provide that, for

paper coating lines utilizing the daily weighted averaging alternative, YOM content information

shall be maintained and/or reported in terms of weight of YOM per weight ofsolids or coatings,

as applicable, as applied each day on each coating line." SR at 13; see Prop. 218 at 40-43, Prop.

219 at 37-40. The Agency also proposes to amend this subsection "to provide that metal

furniture and large appliance coating lines utilizing the daily weighted averaging alternative

maintain and/or report YOM content information in terms of weight of YOM per volume of each

coating or solids, as applicable, as applied each day on each coating line." SR at 13; see Prop.

218 at 40-43, Prop. 219 at 37-40.

Subsection (e). The Agency proposes to amend subsection (e) to provide that coating

lines complying through the alternative emission limitations must comply with the recordkeeping

and reporting requirements specified in the subsection. SR at 13-14; see Prop. 2] 8 at 43, Prop.

219at40.

Subsection (e). The Agency proposes to add a new subsection (g) establishing

"recordkeeping and reporting requirements for paper, metal furniture, and large appliance

coating lines subject to the work practice requirements set forth in Section 218/219.218." SR at

14; see Prop. 218 at 46, Prop. 219 at 43-44.

Section 218/219.212: Cross-Line Averaging to Establish Compliance for Coating

Lines. Existing Section 2 J8/219.212 allows specified coating lines to establish compliance with

YOM content limitations through cross-line averaging. See 35111. Adm. Code 218.212, 219.212.

The Agency "proposes amending this Section to provide that the cross-line averaging alternative

is not available to eoating lines subject to the revised YOM content limitations." See SR at 14;

see Prop. 218 at 47, Prop. 219 at 44.

Section 218/219.218: Work Practice Standards for Paper Coatings, Metal Furniture

Coatings, and Large Appliance Coatings:

The Agency proposes to add a new section setting "forth work practice requirements for

cleaning materials and/or cleaning-related activities associated with paper, metal furniture, and

large appliance coating lines." SR at 14. The Agency generally

proposes that subject coating lines store all YOM-containing materials in closed

containers, ensure that mixing and storage containers used for YOM-containing

materials are kept closed at all times except when in use, minimize spills of

YOM-containing materials, convey such materials from one location to another in
21

closed containers or pipes, and minimize YOM emissions from the cleaning of

storage, mixing, and conveying equipment. SR. at 14; see Prop. 218 at 48-49,

Prop. 219 at 48-49.

The Agency's proposal originally sought to require in Section 218/219.204 that mctal

furniture and large appliance coating lines employ spccific application methods. SR at 11; see

Prop. 2] 8 at ]4-15, 16-] 7, Prop. 219 at 13-14, 16. Responding to a question at the first hearing,

the Agency indicated that it would consider whether these requirements should remain in that

Section or should be codified in a different section. See TLl at 19-20. In its motion to amend,

the Agency proposed to place these application method limitations in Section 218/219.218,

which addresses work practice standards, instead of Section 218/219.204. Mot. Amend at 1-5

(~3).

Those application methods include electrostatic application, HVLP spray, flow coat,

roller coat, dip coat including electrodeposition, or other coating applications with a transfer

efficiency equivalent to or better than that achieved by HVLP spraying. Mahajan Test. at 4-5;

see Mot. Amend at 4-5. Responding to a question at the first hearing, the Agency explained its

basis for these requirements. The Agency stated that the listed methods are more efficient in

terms of applying solids to a substrate. TLl at 17. The Agency indicated that, while a spray gun

may provide 25% efficiency, the listed methods provide "more than 40, 60, even 70, 90 percent

efficiencies." Id. The Agency stated that these higher efficiencies reduce YOM emissions from

the coating operations and are recommended by the CTG. Id. at 17-18.

CONCLUSION

The Board proposes for second notice amendments to its regulations governing VOM

emissions in Parts 218 and 219 (35111. Adm. Code 2J8, 219). Substantively, the Board is

adopting the Agency's proposal including changes reflected in the Agency's motion to amend,

which the Board granted above. See Mot. Amend; see also supra at 2-3 ("Preliminary Matter").

The Board also makes non-substantive changes, which are not addressed in this opinion.

ORDER

The Board directs the Clerk to file the following proposed amendments with the Joint

Committee on Administrative Rules for second-notice review. Proposed additions are

underlined, and proposed deletions appear stricken.

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSIONS STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART218
B 13
JOINT COMMITTEE ONADMINISTRATIVE RULES

ILLINOIS GENERAL ASSEMBLY

CO-CHAIR:

SEN. MAGGIE CROnY

CO-CHAIR:

AEP. ANGELO 'SKIP' SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

SEN. J. BRADLEY BURZYNSKI

SEN. RANDALL HULTGREN

SEN. MAT11E HUNTER

SEN. DAN RUTHERFORD

SEN. IRA SILVERSTEIN

AEP. JOHN FRITCHEY

REP. LOU LANG

REF'. DAVID MillER

REP. DONALD MOFFITI

REP ROSEMARY MULLIGAN

700 STRAITON BUILDING

SPRINGF!ELD, ILLINOIS 62706

2171765·225<1

MEMORANDUM

TO:

FROM:

DATE:

Tanner Girard, Chainnan

Pollution Control Board

Vicki Thomas

Executive Director

2/8/10

RE: Organic Material Emission Standards and Limitations for the Chicago Area (35

Ill. Adm. Code 218)

33 Ill. Reg. 16399 - 11/20/09

The Office of the Joint Committee on Administrative Rules has accepted the Second Notice for

the above-referenced rulemaking. The Second Notice period began on 2/8/10 and ends no later

than 3/24/10, unless extended pursuant to Section 5-40 of the IAPA.

This rulemaking is scheduled to be considered by JCAR at its 3/9/10 meeting, currently

scheduled for I I:00 a.m., Room C-I, Stratton Office Building, Springfield, IL. Staff will be

contacting you if they have questions concerning this rulemaking and will advise you of any

change in time or location ofthe Committee meeting.

Please contact us if you have any questions regarding the JCAR review procedure.

VT:DC:nn

cc: Tim Fox

Adm. Code Div.
CO-CHAIR:

SEN. MAGGIE CROTTY

CO-GHA1R:

REP, ANGELO 'SKIP" SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ON ADMINISTRATIVE RULES

ILLINOIS GENERAL ASSEMBLY

700 STFlATTON BUILDING

SPRINGFiElD, ILLINOIS 62706

217085·2254

SEN, J. BRADLEY BURZYNSKI

SEN. RANDAll HULTGREN

SEN, MATIIE HUNTER

SEN. DAN RUTHERFORD

SEN. IRA SILVERSTEIN

REP. JOHN FAITCHE'(

REP: LOU LANG

REP. DAVIO MILLER

REP. DONALD MOFFITI

REP ROSEMARY MULLIGAN

TO:

FROM:

DATE:

MEMORANDUM

Tanner Girard, Chainnan

Pollution Control Board

Vicki Thomas

Executive Director

2/8/10

RECEIVED

CLEAWS OFFICE

FEB' 02010

STATE OF ILLINOIS

Pollu"o!"> Control Board

RE: Organic Material Emission Standards and Limitations for the Metro East Area (35

Ill. Adm. Code 219)

33 Ill. Reg. 16460 - 11120/09

The Office of the Joint Committee on Administrative Rules has accepted the Second Notice for

the above-referenced rulemaking. The Second Notice period began on 2/8/10 and ends no later

than 3/24/10, unless extended pursuant to Section 5-40 ofthe IAPA.

This rulemaking is scheduled to be considered by JCAR at its 3/8/10 meeting, currently

scheduled for 11:00 a.m., Room C-I, Stratton Office Building, Springfield, IL. Staff will be

contacting you if they have questions concerning this rulemaking and will advise you of any

change in time or location ofthe Committee meeting.

Please contact us if you have any questions regarding the JCAR review procedure.

VT:DC:nn

ee: Tim Fox

Adm. Code Div.
CO-CHAIR:

SEN. MAGGIE GROTTY

CO-CHAIR:

REP. ANGELO 'SKIP' SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ONADMINISTRATIVE RULES

ILLINOIS GENERAL ASSEMBLY

700 STRATION BUILDING

SPRINGFIELD, ILLINOIS 62706

217na5-2254

SEN. J. BRADLEY BURZYNSKI

SEN. RANDAll HULTGREN

StN. MATTIE HUNTER

SEN, DAN RUTHERFORD

SEN. IRA SILVERSTEIN

REP. JOHN FRlTCHEY

REP. LOU LANG

REP. DAVID MILLER

REP. DONALD MOFFITT

REP. ROSEMARY MULLIGAN

Tanner Girard, Chainnan

Pollution Control Board

James R. Thompson Center

100 W. Randolph, Suite 11-500

Chicago, lllinois 60601

Dear Chainnan Girard:

March 9, 2010

RECEiVED

CLERI<;'{; OFFICE

MAR 112010

STATE OF ILLINOIS

Pollution Control Board

This is to notify you that JCAR considered the following proposed rulemakings at its 3/9/10

meeting:

Organic Material Emission Standards and Limitations for the Chicago Area (35 Ill. Adm.

Code 218)

33 m. Reg. 16399 - 11/20/09

Organic Material Emission Standards and Limitations for the Metro East Area (35 lll.

Adm. Code 219)

33 TIl. Reg. 16460 - 11120/09

If your agency has agreed to any substantive modifications during its discussions with JCAR,

they are described in the "Agreements" attached to the certification. Based on these agreements,

as well as the other responses you have provided the Committee during the review of these

rulemakings, JCAR has detennined that No Objection will be issued. Enclosed you will fmd

fonnal certification ofthis action.

These rulemakings may now be adopted upon filing with the Office ofthe Secretary of State.

Please note that the fact that the Committee has not objected to these rulemakings does not

necessarily constitute approval, expressed or implied, ofthe substance ofthe rulemakings.
Thank you for the cooperation your agency has shown during our review ofthese issues.

Sincerely,

Senator Maggie Crotty

Co-Chairman

SMC:RBH:DC:rm

cc: Tim Fox

Ene.
Agency:

Rulemaking:

Changes:

SECOND NOTICE CHANGES

Pollution Control Board

Organic Material Emission Standards and Limitations for the Chicago

Area (35 TIl. Adm. Code 218; 33 III. Reg. 16399)

1. In lines 593, 604 and 846, after "i.e." add a comma.

2. In the table after line 601, in the "n" where statement, 2nd line, after "i.e." add a comma.

2/25/10
B 14
CO-CHAIR:

SEN. MAGGIE CROnY

CO-CHAIA:

REP. ANGELO 'SKIP' SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ONADMINISTRATlVE RULES

ILLINOIS GENERAL ASSEMBLY

700 STRAITON BUILDING

SPRINGFIELD, ILLINOiS 62706

2 i 71785·2254

JOINT COMMITTEE ON ADMINISTRATIVE RULES

SEN. J. BRADLEY BURZYNSKI

SEN. AANDAlL HULTGREN

SEN. MATTIE HUNTER

SEN. DAN RLITHERFOAQ

SEN. IRA SILVERSTEIN

REP. JOHN FRtTCHEY

REP. lOU LANG

REP. DAVID MILLER

REP. DONALD MOFFITT

REP, ROSEMARY MULLIGAN

CERTIFICATION OF NO OBJECTION

TO PROPOSED RULEMAKING RECEIVED

ClER~S OFFICE

MAR 1 I 2010

STATE: OF ILLINOIS

Pollutiop Control Board

This is to certify that the Joint Committee on Administrative Rules, at its 3/9/1 0 meeting,

considered Organic Material Emission Standards and Limitations for the Chicago Area (35 IlL

Adm. Code 218), proposed by the Pollution Control Board and published in the I1/20/09 issue of

the Illinois Register. After consideration, and based upon the agreements, if any, for

modification of the rulemaking made by the agency and attached to this document, the

Committee detennined that no Objection will be issued to the above-mentioned rulemaking,

March 9, 2010

Executive Director

Attachments: Agreements
Agency:

Rulemaking:

Changes:

SECOND NOTICE CHANGES

Pollution Control Board

Organic Material Emission Standards and Limitations for the Metro East

Area (35 Ill. Adm. Code 219; 33 Ill. Reg. 16460)

1. In lines 570, 582 and 795, after "i.e." add a comma.

2. In the table after line 579, in the "n" where statement, after "i.e." add a comma.

3. In line 1518, change "218.204fh)" to "219.204fh)".

2/25/10
CO-CHAIR:

SEN, MAGGIE CROnY

CO-CHAIR:

REP, ANGELO ·SKlp· SAVIANO

EXECUTIVE DIRECTOR:

VICKI THOMAS

JOINT COMMITTEE ONADMINISTRATIVE RULES

ILLINOIS GENERAL ASSEMBLY

700 STAATION BUILDING

SPRINGFIELD, ILLINOIS 62706

217/785-2254

JOINT COMMITTEE ON ADMINISTRATIVE RULES

CERTIFICATION OF NO OBJECTION

TO PROPOSED RULEMAKING

SEN. J. BRADLEY BURZYNSKI

SEN. RANDALL HULTGREN

SEN. MArnE HUNTER

SEN. DAN RUTHERFORD

SEN. IRA SILVERSTEIN

REP. JOHN FAITCHEY

REP. LOU LANG

REP DAVID MILLER

REP DONALD MOFFITT

REP. ROSEMARY MULUGAN

:flu/rD

RECEIVED

ClER~:S{)FFICE

MAR 112010

STATE OF ILUOOfS

Pollution Control Board

This is to certify that the Joint Committee on Administrative Rules, at its 3/9/10 meeting,

considered Organic Material Emission Standards and Limitations for the Metro East Area (35 Ill.

Adm. Code 219), proposed by the Pollution Control Board and published in the 11/20/09 issue of

the Illinois Register. After consideration, and based upon the agreements, if any, for

modification of the rulemaking made by the agency and attached to this document, the

Committee determined that no Objection will be issued to the above-mentioned rulemaking.

March 9, 2010

Attachments: Agreements

V i Thomas

Executive Director
B 15
ILLINOIS POLLUTION CONTROL BOARD

March 18,2010

IN THE MAITER OF:

REASONABLY AVAILABLE CONTROL

TECHNOLOGY (RACT) FOR VOLATILE

GROUP III CONSUMER & COMMERCIAL

PRODUCTS: PROPOSED AMENDMENTS

TO 35 ILL. ADM. CODE 218 AND 219

)

)

)

)

ORGANIC MATERIAL EMISSIONS FROM )

)

)

)

Adopted Rule. Final Order.

RlO-lO

(Rulemaking - Air)

OPINION AND ORDER OF THE BOARD (by A.S. Moore)

Today the Board adopts its final order in this rulemaking amending its air pollution

regulations. See 35 III. Adm. Code 218, 219.

On October 23, 2009, the lllinois Environmental Protection Agency (Agency or lllinois

EPA or TEPA) initiated this proceeding by filing a proposal under provisions including the "fasttrack" rulemaking authority of Section 28.5 ofthe Environmental Protection Act (Act). See 415

ILCS 5/1 0, 27 (2008); Public Act 96-0308, eff. Aug. II, 2009 (P.A. 96-0308) (reenacting

repealed Section 28.5). The Agency proposed volatile organic material (VOM) emission

controls in response to control techniques guidelines (CTG) issued by the United States

Environmental Protection Agency (USEPA) for the following Group III Consumer and

Commercial Product Categories: paper, film, and foil coatings; metal furniture coatings; and

large appliance coatings.

On November 5, 2009, the Board adopted its first-notice opinion and order in this

proceeding without commenting on the substantive merits ofthe Agency's proposal. See 33 Ill.

Reg. 16399, 16460 (Nov. 20, 2009); P.A. 96-0308 (subsection (e). On February 4, 2010, the

Board adopted its second-notice opinion and order. At its meeting on March 9, 2010, the Joint

Committee on Administrative Rules (lCAR) considered the Board's second-notice proposal and

issued its Certificate of No Objection.

In this opinion, the Board first provides the procedural history of this rulemaking and

briefly summarizes the background offederal YOM regulation in these product categories. The

Board then describes the processes addressed in this mlcmaking and the sources ofVOM

emissions from them. Next, the Board summarizes current regulations governing those

processes and provides an overview ofthe Agency's proposal. The opinion then addresses the

economic reasonableness and technical feasibility ofthe proposal. The Board then summarizes

the adopted rules on a section-by-section basis. Finally, the Board's order directs the Clerk to

file the adopted amendments with the Secretary of State for publication in the Illinois Register.

PROCEDURAL HISTORY
2

On October 23,2009, the Agency filed a mlemaking proposal to amend Parts 218 and

219 ofthe Board's air pollution regulations (Prop. 218 and Prop. 219, respectively). The Agency

. filed its proposal under provisions including the "fast-track" mlemaking authority of Section

28.5 of the Act. See 415 lLCS 5/1 0, 27 (2008); P.A. 96-0308. Among other documents, a

Statement ofReasons (SR) and a Technical Support Documcnt (TSD) accompanied the proposal.

The Agcncy also filcd a motion for waiver of copy rcquirements. In an order datcd November 5,

2009, the Board accepted thc Agency's proposal for hearing and granted thc Agency's motion

for waiver of copy requirements.

In a letter dated NovemberS, 2009, the Board requested that the Department of

Commerce and Economic Opportunity (DCEO) conduct an economic impact study ofthe

Agency's mlemaking proposal. See 415 ILCS 5/27(b) (2008). DCEO has not responded to the

Board's request.

In an order dated November 5, 2009, the hearing officer scheduled three hearings to take

place in Chicago: the first beginning on December 9, 2009, the second beginning on January 6,

2010, and the third beginning on January 20,2009.

First notice of the proposed mles appeared in the Illinois Register on November 20, 2009.

33 Ill. Reg. 16399-16516 (Nov. 20, 2009); see 5 ILCS 100/5-40(b) (2008) (45-day comment

period).

On November 25, 2009, the Agency pre-filed for the first hearing the testimony ofML

Yoginder Mahajan (Mahajan Test.). The first hearing took place as scheduled on December 9,

2009. The Board received the transcript ofthe first hearing (TLI) on December 10, 2009.

During the first hearing, the hearing officer admitted into the record a single exhibit, the pre-filed

testimony ofML Mahajan (Exh. I). TLI at 8-9.

On December 28, 2009, the Agency filed a motion to amend its mlemaking proposal.

No participant pre-filed testimony for the second hearing, which took place as scheduled

on January 6, 20 IO. The Board received the transcript of the second hearing (TL2) on January 8,

2010. On the record at the second hearing, the Agency stated that it did not wish to introduce

any additional material and that it wished to cancel the third hearing scheduled to take place on

January 20,2010. TL2 at 7-8; see P.A. 96-0308 (subsection (1)(3)). In an order dated January

II, 2010, the hearing officer cancellcd the third hearing and set a deadline ofJanuary 22, 20 I0,

for filing post-hearing comments. See P.A. 96-0308 (subsection (k)). The Board has received no

public comments during the course of this proceeding.

On Febmary 4,2010, the Board adopted its second-notice opinion and order, which

granted the Agency's December 28, 2009 motion to amend its mlemaking proposal. At its

meeting on March 9, 2010, JCAR considered the Board's second-notice proposal and issued its

Certificate of No Objection. JCAR proposed non-substantive changes, which the Board

incorporates in its order below.
3

BACKGROUND OF FEDERAL YOM REGULATION

The Agency stated that its rulemaking proposal intended to satisfy Illinois' obligation

under the Clean Air Act (CAA) to submit a State Implementation Plan (SIP) addressing sources

ofVOM emissions in areas designated as nonattainment with respect to the National Ambient

Air Quality Standard (NAAQS) for ozone. SR at 1,6-7, citing 42 U.S.c. §§ 7502, 7511a.

The Agency characterized YOM1 as "a primary precursor to the formation of groundlevel ozone, which is fomled when oxides of nitrogen and YOM react in the atmosphere in the

presence ofsunlight." SR at 2. "Ground-level ozone is a major component ofsmog." SR at 2-3,

citing 72 Fed. Reg. 57217 (Oct. 9, 2007). The Agency stated that, in 1997, USEPA revised the

NAAQS for ozone by replacing a I-hour standard with an 8-hour standard. Jd. at 3, citing 62

Fed. Reg. 38856 (July 18, 1997), see TSD at 7. Two Illinois areas, Chicago and St. LouislMetro

East, have been designated as moderate nonattainment areas (NAA) for the 8-hour ozone

standard. 2 SR at 3, TSD at 7.

111ese nonattainment designations trigger CAA requirements "for adopting regulations

that reduce emissions sufficiently to demonstrate attainment ofthe standard." SR at 4, citing 42

U.S.c. § 7502(c)(l). Specifically, the Agency claimed that the CAA requires Illinois "to submit

YOM regulations constituting RACT [reasonably available control technology] for Group III

Consumer and Commercial Product Categories in ozone NAAs classified as moderate and

above." SR at 5, citing 42 U.S.c. §§ 7502(c)(I), 7511a(b)(2). The Agency defined RACT "as

the lowest emissions limitation that a particular source can meet by applying a control technique

that is reasonably available considering technological and economic feasibility." SR at 5, citing

44 Fed. Reg. 53762 (Sept. 17, 1979); see TSD at 7. The Agency stated that "llIinois was

required to submit its SIP revisions by October 9,2008." SR at 5.

The Agency stated that the CAA requires USEPA to "conduct a study of the emissions of

YOM into the ambient air from consumer and commercial products in order to determine their

potential to contribute to ozone levels which violate the ozone NAAQS and to establish criteria

for regulating emissions ofVOM from such products." SR at 3, citing 72 Fed. Reg. 57217 (Oct.

9,2007). The Agency further stated that the CAA provides that "[t]he Administrator shall list

those categories of consumer or commercial products that the Administrator determines, based

on the study, account for at least 80 percent ofthe VOC emissions ... from consumer or

commercial products in areas that violate the NAAQS for ozone" and separate those categories

into groups. SR at 3, citing 42 U.S.c. 751Ib(e)(3)(A).

1 The Agency stated that YOM and volatile organic compounds (VOC) are "effectively the

same" as one another. SR at I.

2 The Chicago nonattainment area includes the following jurisdictions: Cook, DuPage, Kane,

Lake, McHenry, and Will Counties, Goose Lake and Aux Sable Townships in Grundy County,

and Oswego Township in Kendall County. SR at 3, citing 40 C.F.R. 81.314; see TSD at 6, 7.

The St. Louis/Metro East nonattainment includes the following l1linois counties: Jersey,

Madison, Monroe, and St. Clair. SR at 3, citing 40 C.F.R. 81.314; see TSD at 6,7.
4

The Agency claimed that "[t]he CAA requires that USEPA then either regulate YOM

emissions from such catcgories or issue a CTG in lieu of a national regulation ifthe

Administrator dctcmlines that such guidance will be substantially as effective as regulations in

reducing emissions of YOM which contribute to ozone levels in ozone NAAs." SR at 4, citing

42 U.S.c. § 751Ib(e)(3)(C). The Agency stated that "CTGs provide states with

recommendations regarding what types of controls could constitute RACT for YOM for the

applicable source categories." SR at 4, citing 72 Fed. Reg. 57217-18. The Agency claimed that

"[s]tates must either adopt regulations to implement the recommendations in the CTG or adopt

alternative approaches that constitute RACT, eithcr of which must be submitted to the USEPA

for review and approval as part ofthe SIP process." SR at 4, citing 72 Fed. Reg. 57218; see TSD

at 6.

The Agency reported that, on October 9, 2007, USEPA issued final CTGs for three

Group III Consumer and Commercial Product categories. SR at 4; see TSD at 6, 7. The Agency

stated that "[t]hese CTGs contained information regarding sources of YOM emissions from the

applicable industries, the recommended available control options to reduce YOM emissions, and

the cost ofrecommended control measures." Mahajan Test. at 2. USEPA required submission

of SIP revisions responding to the CTGs within one year. SR at 4, citing 72 Fed. Reg. 57215-18.

-TI,e Agency reported that "Illinois is required to submit these SIP revisions before the

USEPA can re-designate the Chicago and Metro East NAAs to attainment ofthe 1997 ozone

NAAQS, regardless of whether the YOM reductions obtained by the SIP revisions are actually

necessary to achieve attainment of the NAAQS." SR at 7, citing Wall v. USEPA, 265 F.2d 426,

433,440-42 (6th Cir. 2001); 42 U.S.C. § 7407(d)(3)(E). The Agency noted that, on July 2,2007,

it "submitted to the USEPA an attainment demonstration for the Metro East nonattainment area

for the 1997 8-hour ozone NAAQS." SR at 7. The Agency further noted that, on March 19,

2009, it submitted an attainment demonstration for the Chicago nonattainment area. Id. The

Agency argued that "[t]hese areas cannot be redesignated to attainment of the ozone NAAQS,

however, unless and until the Illinois EPA submits SIP revisions in response to the Group III

CTGs and the USEPA approves such revisions." Id. at 7-8. The Agency stated that its proposal

intended generally "to implement the recommendations contained in the CTGs to the extent that

such recommendations are consistent with existing regulations." SR at 10.

The Agency also noted that USEPA recently strengthened the ozone standard. SR at 8

citing 73 Fed. Reg. 16436 (Mar. 27, 2008). The Agency considered it "likcly" that areas

designated as nonattainment for the current standards will be designated nonattainment for the

revised standard as well. SR at 8. The Agency argued that, "[w]hile attainment of the revised

standard is not the purpose ofthis mlemaking, it should be noted that any reduction in YOM

emissions in the NAAs resulting from these proposed amendments will improve ozone air

quality and will likely help Illinois achieve and maintain the newly revised NAAQS." !d.

DESCRIPTION OF PROCESSES AND SOURCES OF YOM EMISSIONS

Paper, Film, and Foil Coatings
5

The Agency stated that "[p]aper, film, and foil coatings include adhesives used on tapes

and labels, and are defined as 'any protective, decorative, or functional coating applied on paper,

plastic film, or metallic foil to make certain products, including but not limited to adhesive tapes

and labels, book covers, post cards, office copier paper, drafting paper, or pressure sensitive

tapes.'" TSO at 9 (§2.1). The Agency stated that this category also includes "coatings applied

through saturation or impregnation." !d. The Agency indicated that these coatings

can also be categorized as a web coating process, which typically involves the

application of a continuous layer of coating across either a wholc or part of thc

width of a web substrate to do the following: 1) providc a covering, finish, or

functional or protective layer to a substrate; 2) saturate a substrate for lamination;

or 3) provide adhesion between two substrates for lamination" !d.

The Agency listed various kinds of coating applicators including "rotogravure, reverse

roll, slot die, knife, flexography, Mayer rod, dip and squeeze, and extrusion/calendaring." TSO

at 9, citing Control Techniques Guideline for Paper, Foil, and Foil Coatings, Office of Air

Quality Planning and Standards, USEPA 453/R07-003 (Sept. 2007). The Agency stated that

"[a]n average coating line can include a series of one or more unwind/feed stations; one or morc

coating applicators; the flash off area (the portion between two or more consecutive coating

applicators or between the coating applicator and the drying oven); one or more drying ovens;

and one or more rewind/cutting stations." TSO at 9. The Agency noted that facilities also

conduct cleaning activities "to eliminate coating residue or other unwanted materials from

equipment related to coating operations." !d. Facilities conduct this cleaning with spray guns

and related operations. Id.

The Agency stated that YOM emissions in this category result "from the evaporation of

volatile components of the coatings and cleaning materials." TSO at 9. The Agency further

stated that these can result chiefly from "the process of coating application/flash-off, coating

curing/drying, and cleaning." !d. at 9-10. The Agency indicated that "[a]bout 90% ofthe YOM

in the coatings is evaporated in the drying ovens." Id. at 10, citing Control Techniques Guideline

for Paper, Foil, and Foil Coatings, Office ofAir Quality Planning and Standards, USEPA

453/R07-003 (Sept. 2007).

Large Appliance Coatings

The Agency defined large appliance coatings as "any protective, decorative, or functional

coating applied onto the surface oflarge appliances or to the constituent metal parts." TSO at 10

(§2.2). The Agency listed as examples oflarge appliances "residential and commercial washers,

dryers, ranges, refrigerators, freezers, water heaters, dishwashers, trash compactors, air

conditioners, and other similar products." Id. The Agency stated that coatings are a significant

part of appliance manufacturing, "as they protect the metal on the large appliances from rusting

away by allowing resistance to such factors as moisture, heat, detergent, and even outdoor

elements." !d. The Agency also stated that the coatings "must be durable and have superb

adhesion properties to prevent chipping or peeling." Id. The Agency indicated that specific
6

coatings "include paints, topcoats, basecoats, primers, enamels, sealants, caulks, inks, adhesives,

and maskants...." !d.

The Agency described a number of processes for the application oflarge appliance

coatings. TSD at 10, citing Control Techniques Guidelines for Large Appliance Coatings, Office

of Air Quality Planning and Standards, USEPA 453/R-07-004 (Sept. 2007). First, the Agency

stated that, "[i]n air atomized spraying, compressed air is used to provide transfer efficiencies of

up to 40%" TSD at 10. The Agency distinguished airless spraying, which "employs an airless

pump system to force the coating through a nozzle that is made to atomize the coating for a

transfer efficiency of between 50 to 60 percent." !d. The Agency also described electrostatic

spraying, in which "an air or airless gun system can be created to magnetize the coating to the

substrate and achieve approximately 85% transfer efficiency." !d. The Agency stated that dip

coating "involves dipping a part into a tank that contains the coating" and has a transfer

efficiency of nearly 85%. !d. The Agency described electrodeposition as ''just a type of dip

coating method that uses an electric field to aid the placement of a waterborne coating to a

substrate." !d. Finally, the Agency stated that "flow coating is a technique that applies a coating

directly onto a substrate without atomizing the coating and usually creates 85% transfer

efficiency." Id.

The Agency stated that, in large appliance coating, "[p]rimary sources ofVOM emissions

evolve from the coating application (prime, single or topcoat application)/flash-off and

drying/curing ofthe coatings and from mixing and/or thinning." TSD at II. In addition, the

Agency cited cleaning materials as another source ofVOM emissions from this category. Id.

The Agency stated that cleaning may involve different types of chemical washes, "including

solvent cleaning, acid washing, phosphate washing, and de-ionized water washing," with solvent

cleaning and wetting oil treatments constituting the greatest source of emissions. Id. The

Agency further noted that "[c]Ieaning materials can also be used in cleaning coating equipment

and to touch up final products." Id. The Agency claimed that, although many ofthese cleaning

products are typically YOM solvents, there is greater use of alcohol and water-based cleaners.

!d., citing Control Techniques Guidelines for Large Appliance Coatings, Office ofAir Quality

Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

Metal Furniture Coatings

The Agency provided examples ofmetal furniture: "tables, chairs, waste baskets, beds,

desks, lockers, benches, shelving, file cabinets, lamps, and room dividers that are made in whole

or in part by meta1." TSD at II (§2.3). The Agency defined metal furniture coatings as "any

protective, decorative or functional coating applied onto the surface of any metal furniture or any

metal part which will be assembled with other metal, wood, fabric, plastic or glass parts to form

metal furniture." Id. The Agency stated that these coatings include paints and that they protect

metal furniture "from rusting away by allowing resistance to'such elements as moisture, heat,

detergent, and even outdoor factors." Id. The Agency also stated that the coatings "must be

durable and have superb adhesion properties to prevent chipping or peeling." Id.
7

The Agency stated that metal furniture manufacturing involves four main processes, the

first of which is raw material preparation. TSD at 11. The second process, surface preparation,

consists of the following steps: 1) alkaline or acid cleaning, 2) water rinse, 3) iron phosphate

treatment, 4) water rinse, and 5) pre-treatment and/or another final water rinse. ld. The third

process, coating and adhesive application operations, includes curing or drying ofthe coating.

ld. In the fourth process, "the final unit is assembled and packaged for shipment." !d. at 12. The

Agency further stated that surface preparation, coating application, and cleaning activities use

YOM-containing compounds such as coatings, thinners, and cleaning materials. ld. at 11.

The Agency stated that, "[s]imilar to the large appliance coatings, the primary source of

YOM emissions can occur from the evaporation of the volatile contents of the coatings and

cleaning materials." TSD at 12. Specifically, emissions occur when solvents vanish "from the

coating as it is being placed onto the part, or even when solvents are being used during the final

cleaning process." ld. The Agency claimed "that the more efficient that a coating application

technique is in enabling a transfer of coatings to the metal furniture part, the volume of coatings

needed during production decreases, which thereby results in lower YOM emissions." ld., citing

Control Techniques Guidelines for Metal Furniture Coatings, Office of Air Quality Planning and

Standards, USEPA 453/R-07-005 (Sept. 2007).

SUMMARY OF EXISTING REGULAnONS

The Agency stated that it now regulates YOM emissions in the two l1Iinois NAAs from

coating operations including paper, film, and foil; metal furniture; and large appliances. TSD at

28 (§5.1). The Board briefly summarizes those existing regulations in the following subsections.

Paper. Film. and Foil Coatings

The Agency stated that Parts 218 and 219 currently regulate YOM emission from paper,

film, and foil coating processes. TSD at 28 (§5.1.1); see Mahajan Test. at 3. Specifically, .the

Agency stated that "VOM content limitations are prescribed for paper coating operations that

emit 15 Ib/day or more ofVOM from all associated coating operations." TSD at 28; see 35111.

Adm. Code 218.208, 219.208. On and after March 15, 1996, those limitations are 0.28 kg/lor

2.3Ib/gal. 35 Ill. Adm. Code 218.204(c), 219.204(c). The Agency further stated that,

"[a]lternatively, sources may install and operate YOM capture and control systems that provide

81 % reduction in overall YOM emission, and the control device must achieve 90% efficiency

(control devices include afterburner, carbon adsorption, condensation, or absorber scrubber

system)." TSD at 28-29; see 35111. Adm. Code 218.207(b), 219.207(b).

Large Appliance Coatings

The Agency stated that "[s]pecific regulations for large appliance coatings are located in

Subpart F...." TSD at 29 (§5.1.2); see 35 111. Adm. Code 218.204-217, 219.204-217, Mahajan

Test. at 4. The Agency further stated that "[t]he applicable threshold for the total actual

uncontrolled YOM emission from all large appliance coating operations is 15lbs/day or more."

TSD at 29; see 35111. Adm. Code 218.208, 219.208. The Agency noted that existing regulations
S

do not distinguish between coating types and instead distinguish baked and air-dried operations.

TSD at 29; see 35111. Adm. Code 2] S.204(h), 2]9.204(h). On and after March] 5,1996, those

limitations are O.2S kg/I and 2.3 ]b/gal for baked coatings and 0.34 kg/1 and 2.S Ib/gal for airdried coatings. TSD at 29; see 35 Ill. Adm. Code 2IS.204(h), 219.204(h). The Agency further

stated that the regulations provide an altemative requiring "a coating line to be equipped with a

capture system and control device that provides an S] % reduction in overall YOM emissions,

and the control device ... achieves a 90% efficiency." TSD at 29; see 35 Jl1. Adm. Code

2IS.207(b),219.207(b).

Metal Furniture Coatings

The Agency stated that the "[r]egulations for metal fumiture coating operations are very

similar to the regulations for large appliance coatings," except for limits applicable before March

15, ] 996. TSD at 30 (§5.1.3); see 35 111. Adm. Code 2IS.204(g), 219.204(g), see also Mahajan

Test. at 4.

SUMMARY OF AGENCY'S PROPOSED REGULATIONS

The Agency claimed that its proposed amendments are consistent with the 2007 USEPA

CTGs and that its proposal controls YOM emissions from paper coating, meta] fumiture coating,

and large appliance coating. TSD at 30 (§5.2); see id. at 7-S (summarizing CTG

recommendations). The Agency proposed that compliance with its proposed new regulations

begin on May 2, 2011. TSD at 30. Below, the Board provides a brief overview ofthe Agency's

proposed revisions to Parts 2lS and 219.

Paper, Film, and Foil Coatings

The Agency stated that it proposes no "change to the applicability threshold of 15 Ib/day

or more for control requirements for paper coating." TSD at 30 (§5.2.l). The Agency proposed,

however, "to specify the YOM content limits of paper coating in Ib (kg) of YOM per Ib (kg) of

solids and equivalent YOM limits in kg (lb) ofYOM per kg (lb) of coating." Id., Mahajan Test.

at 3. The Agency also proposed "a lower YOM limit of 0.20 kg per kg ofsolids (0.20 Ib/lb of

solids) for pressure sensitive tape and label surface coating." Mahajan Test. at 3; see TSD at ]4-

] 5. The Agency claimed that, "[e]xcept for pressure sensitive tape and label surface coating, the

YOM limits are equivalent to the existing YOM limits for paper coating." TSD at 30; see Prop.

21S at 12, Prop. 219 at] 1.

The Agency stated that "[a]ffected sources may use add on capture and control systems to

comply with the YOM content limits ofthe coatings." TSD at 31. However, the Agency

proposed "to increase the ovcrall control efficiency standards to 90 percent from the existing S]

percent overall control efficiency ofthe add-on capture and control systems." Id., Mahajan Test.

at 3; see TSD at 14-] 5. In addition, the Agency proposed that "[t]hese limits can be met through

daily within-line averaging (i.e., averaging the YOM content ofmaterials used on an individual

surface coating line each day)." TSD at ]4.
9

In addition, the Agency proposed a new Section 218/219.218 prescribing standards for

the use of cleaning materials at applicable sources on and after May I, 2011. TSD at 31; see

Prop. 218 at 51-52, Prop. 2 I9 at 48-49. For cleaning materials, the Agency stated that "add-on

controls would be too costly because the area to be controlled is very large, and would thereby

require a large volume of air to be captured and directed to a control device." TSD at 14. The

Agency listed the following as work practices that may be employed to reduce YOM emissions

from cleaning materials:

I) place all YOM-containing cleaning materials in closed containers; 2) guarantee

that mixing and storage containers used for YOM-containing materials are kept

closed at all times except when depositing or removing these materials; 3) curtail

spills ofVOM-containing cleaning materials; 4) transfer YOM-containing

cleaning materials from one location to another in closed containers or pipes; and

5) reduce YOM emissions from cleaning ofstorage, mixing, and conveying

equipment. ... TSD at 14-15

Large Appliance Coatings

The Agency stated that it proposes no "change to the applicability requirement of 15 Ib

YOM/day or more for the control requirements for large appliance coatings. TSD at 32 (§5.2.2).

The Agency proposed to "specify separate YOM content limits for one-component and multicomponent general purpose coatings." Id.; see Prop. 218 at 15, Prop. 219 at 14, TSD at 18-19

(Tables 2, 3), Mahajan Test. at 4. The Agency also proposed "specific emission limits for certain

specialty coatings." TSD at 32; see Prop. 218 at 15-16, Prop. 219 at 14-15, TSD at 18-19

(Tables 2, 3), Mahajan Test. at 4. In addition, the Agency proposed "separate emission limits for

baked and air-dried coatings." TSD at 32; see Prop. 218 at 15-16, Prop. 219 at 14-15, TSD at

18-19 (Tables 2, 3), Mahajan Test. at 4.

The Agency's proposal required the use of one or more application methods:

electrostatic application, HVLP [high volume low pressure] spray, flow coat, roller coat, or dip

coat including electrodeposition. The proposal allowed the use of other coating application

methods capable of achieving a transfer efficiency equivalent to or better than that achieved by

HVLP spraying with the approval ofthe Agency. TSD at 32; see Prop. 218 at 16-17, Prop. 219

at 15-16, Mahajan Test. at 4-5. Also, the proposal provided "that stencil coatings, safetyindicating coatings, solid-film lubricants, electric-insulating and thermal-conducting coatings,

touch-up and repair coatings, or coating applications utilizing hand-held aerosol cans are exempt

from YOM content limits." TSD at 32; see Prop. 218 at 16, Prop. 219 at 15-16, Mahajan Test. at

4.

The Agency stated that "[a]ffected sources may use add-on capture and control systems

to comply with the YOM content limits ofthe coatings." TSD at 32. However, the Agency

proposed "to increase the overall control efficiency standard to 90 percent from the existing 8I

percent overall control efficiency." !d., Mahajan Test. at 5; see TSD at 18-19 (Tables 2, 3). In

addition, the Agency proposed a new Section 218/219.218 establishing work practice standards
10

for large appliance coatings. TSD at 31, see Prop. 218 at 51-52, Prop. 219 at 48-49, TSD at 20

(§ 3.2.3) (USEPA recommendations), Mahajan Test. at 5.

Metal Furniture Coatings

The Agency stated that "[t]he proposed applicability, YOM limits, add-on control device

efficiency, and work practices requirements for metal furniture coatings are identical to the

proposed regulations for large appliance coatings." TSD at 33 (§5.2.3); see Mahajan Test. at 4-

5; see also TSD at 20-25 (Tables 4, 5) (USEPA recommendations).

ECONOMIC REASONABLENESS AND TECHNICAL FEASIBILITY

In pre-filed testimony, Mr. Mahajan stated that "[t]he Agency believes that the proposed

changes are technically feasible and economically reasonable." Mahajan Test. at 6. The Agency

further indicated that "[t]he technology for controlling YOM emissions from Group 11I product

categories is both technically feasible and economically reasonable." TSD at 9. The Agency

argued that "[a]ffected sources can meet the requirements in the proposed amendments through a

number ofreadily available control techniques." Id. In the following subsections, the Board

summarizes thc record pertaining to the issues of economic reasonableness and technological

feasibility.

Affected Sources and Projected YOM Emissions Reductions

The Agency stated that it reviewed its emission inventory data to identify emission

sources potentially affected by these proposed regulations. TSD at 34. The Agency reported

that it had identified 24 potentially affected sources, all but two ofwhich are situated in the

Chicago NAA. Id. at 6, 34. In the following subsections, the Board summarizes the record

regarding these sources and the anticipated emissions reductions in each ofthe categories

addressed in this rulemaking.

Paper, Film, and Foil Coatings

The Agency determined that 16 sources in the Chicago NAA and two in the Metro-East

NAA are potentially affected by these proposed regulations. TSD at 34 (Table 10), Mahajan

Test. at 3-4. The Agency stated that seven of the 16 sources in the Chicago NAA comply

through the use of add-on capture and control systems. TSD at 34, Mahajan Test. at 3. The

Agency claimed that "[a]lI other affected sources use compliant coatings to comply with the

rcgulations." TSD at 34. The Agency further claimed that "no new add-on capture and control

systems will be installed to meet the proposed regulations." Id., see Mahajan Test. at 3-4.

Instead, the Agency "expects that affected sources will continue to use compliant coatings, or

upgrade their existing add-on capture and control systems to meet the proposed YOM emissions

limits." Mahajan Test. at 4; see TSD at 34.

The Agency stated that, in 2005, these 18 sources accounted for total YOM emissions of

109.83 tons. TSD at 34 (Table 10). The Agency stated that its proposal will reduce YOM
I I

emissions by 21.45 tons per year in the Chicago NAA at a cost of$I,200 per ton of YOM

reduced. Mahajan Test. at 4, TSD at 34. The Agency stated that it "docs not expect any

reduction in YOM emissions" in the Metro-East NAA. Mahajan Test. at 4; see TSD at 34.

Large Appliance Coatings

The Agency determined that "[t]here arc no affected sources oflarge appliance coatings"

in either the Chicago or Metro-East NAA. Mahajan Test. at 5; see TSD at 34 (Table 10).

Accordingly, the Agency expects its proposal to yield no YOM emissions reductions from this

category. See TSD at 34.

Metal Furniture Coatings

Thc Agency "determined that there are six affected sources of metal furniture coatings in

the Chicago NAA and none in the Metro-East NAA." Mahajan Test. at 5; see TSD at 34 (Table

10). The Agency stated that, in 2005, these six sources accounted for total YOM emissions of

89.4 tons. TSD at 34. However, the Agency stated that it "expects that affected sources will

continue using compliant coatings to comply with the YOM limits." Mahajan Test. at 5.

Accordingly, the Agency expected its proposal to yield no YOM emissions reductions from this

category. Mahajan Test. at 5; see TSD at 34 (Table 10).

Technical Feasibilitv

Paper, Film, and Foil Coatings

The Agency stated that paper, film, and foil coating operations commonly employ

pollution prevention measures such as product substitution/reformulation to reduce YOM

emissions. TSD at 13 (§3.1); see SR at 9. The Agency further stated that "[I]ower YOM content

coatings, such as waterborne and higher solids content coatings, or coatings with no solvents

may be used to reduce YOM emissions by reducing or eliminating the organic solvent present in

the coatings." TSD at 13. The Agency reported that "manufacturers have developed and are

continuing to develop waterborne and other alternative coating formulations that replace

conventional organic solvent-based coatings." !d. The Agency acknowledged, however, that

available low-YOM coatings and coatings with no solvent may not satisfy the performance

requirements of ccrtain coating operations. !d.

The Agency claimed that, ifthese low-YOM coatings do not meet the performance

requirements, emissions "can be reduced by the use of capture systems in conjunction with addon control systems that either destroy or recover the YOM in the exhaust streams." TSD at 13.

The Agency reported that paper, film, and foil coating operations typically rely on two categories

of control devices: "combustion (thermal or catalytic oxidation) and recovery (adsorption and

condensation)." lei. The Agency claimed that, "[i]n general, oxidation and adsorption systems

can achieve destruction efficiency of greater than 95 percent as applied to surface coating

application operations with high and constant concentration ofYOM." lei. at 13-14, citing
12

Control Techniques Guideline for Paper, Foil, and Foil Coatings, Office of Air Quality Planning

and Standards, USEPA 453/R07-003 (Sept. 2007).

The Agency stated that "[p]ollution prcvention is the most common emission control

technique for reducing YOM emissions from cleaning materials." TSD at 14. These measures

include "[r]educing the composite vapor pressure or YOM content ofthe cleaning material

used." !d. The Agency acknowledged, however, that "littlc information is available regarding

the types oflow-YOM or YOM-free cleaning materials that could be used in the paper, film, and

foil surface coating industry." !d.

Large Appliance Coatings

The Agency stated that "[s]everal kinds of controls are available to industry to control

YOM emissions from coatings and the cleaning materials associated with this category" TSD at

15 (§3.2); see SR at 9. Pollution prcvention measures include product

substitution/reformulation, through which "affected sources can use waterborne coatings, higher

solids solvent-borne coatings, and powder coatings to reduce YOM emissions through

decreasing or even eliminating the amount of organic solvent in the coatings." TSD at 15. The

Agency claimed that "work practices may be used to reduce YOM emissions from coatings

during paint mixing, paint storagc, and paint transfer operations." Id. at 16.

The Agency reported that "[e]mission capture and add-on control systems can also be

used to reduce YOM emissions from large appliance coating operations." TSD at 16. The

Agency stated that

[t]he most common method for the destruction of YOM from coatings is thermal

oxidation, and can include the following: (I) direct, gas-fired, thermal

recuperative oxidation; (2) direct, gas-fired thermal regenerative oxidation; (3)

direct, electrically heated, thernlal regenerative oxidation; (4) direct, electrically

heated, catalytic oxidation; and (5) direct, gas-fired, catalytic oxidation. Id.

The Agency claimed that controls ofthese types "can achieve a YOM control efficiency between

80% and 98%, with thermal oxidation being the marc preferred method for YOM destruction."

Id., citing Control Techniques Guidelines for Large Appliance Coatings, Office of Air Quality

Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

The Agency stated that options for controlling YOM emissions from cleaning materials

include pollution prevention measures. TSD at 16. The' Agency reported that, "[f]or product

substitution/reformulation, alternative cleaners, such as alcohols and citrus-based cleaners, can

be employed to restrict YOM emissions from cleaning operations." Id. The Agency also

reported that "[a]n example of a work practice procedure that can be utilized to further reduce

YOM emissions from cleaning operations involves nozzle maintenance, which is an integral part

of any metal pre-treatment system - an improperly maintained nozzle can lower spray impact

and can distort spray systems, and thereby reduce the cleaning efficiency." Id. The Agency also
13

indicated that sources can use emission capture and add-on controls to reduce YOM emissions

from cleaning operations in this category. Id. at J7.

Metal Furniture Coatings

. The Agency stated that sources in this category have available two techniques for

reducing YOM emissions. TSD at 20 (§3.3); see SR at 9. First, as pollution prevention

measures, "[a] source may choose to substitute higher-solvent coatings with either powder

coatings, waterborne coatings, higher solids coatings, UY coatings, electrocoatings, and

autophoretic coatings, all of which have little or no solvents." TSD at 20. Second, when lowYOM coatings or coatings with no solvent fail to meet the performance standards of an

operation, the use ofmore effective application equipment can reducc cmissions. Id. The

Agency rcported that "[c]onventional air atomized application systems have typical transfer

efficiencies between 25-40% using high atomizing air pressure. More modem technologies

include electrostatic and high volume/low flow pressure (HYLP) spray equipmcnt, which can

attain far greater transfer efficiencies, which results in less dependence on YOM-containing

materials." Id. at 20-21, citing Control Techniques Guidelines for Metal Furniture Coatings,

Office ofAir Quality Planning and Standards, USEPA 453/R-07-005 (Sept. 2007).

The Agency stated that, in addition to pollution prevention measures, sources in this

category can reduce YOM emissions through "use of capture systems and add-on control

devices, which either destroy or recover the YOM in the exhaust stream." TSDat 21. The

Agency cited as an example of a capture system "such simple components as hoods and

enclosures, which collect solvent-filled air from process vents (such as spray booths or bake

oven vents) and/or fugitive emissions from the flash-off area, and direct it to a control device."

Id. TIle Agency stated that control devices "include combustion (thermal or catalytic oxidation)

and recovery (adsorption and absorption)," which "can reach a control efficiency of95% or

greater." Id. The Agency listed other control technologies that are not in wide use:

"condensation, biodegradation, and UY oxidation" Id.

Regarding control of emissions from cleaning materials in this category, the Agency

stated that pollution prevention is "the most widely used" technique. TSD at 21. Sources may

use low-YOM or YOM-free cleaning materials and can also employ various work practice

procedures. Id.

Economic Reasonableness

TIle Agency stated that it "relied on the U.S. EPA's economic analysis in the respcctive

CTGs to determine the economic costs and impacts associated with the control ofYOM

emissions from paper, film, and foil coatings; metal furniture coatings; and large appliance

coatings operations in Illinois' NAAs." TSD at 26 (§ 4.0). In the following subsections, the

Board reviews the record on these issues.

Paper, Film, and Foil Coatings
(

14

The Agency stated that USEPA "assumed that about 47% ofthe facilities in the 2002

National Emissions Inventory (NEI) database (1 19 facilities) were currently in compliance with

the 2002 National Emissions Standards for Hazardous Air Pollutants (NESHAP)." TSD at 26

(§4.l). The Agency further stated that, based on the average number of coating lines perfaeility

whose potential emissions exceeded applicability thresholds, "the total annual cost was about

$24.5 million per year." !d. The Agency claimed that, "iffacilities that exceed the emission

thresholds and that arc located in NAAs utilized the 90% emissions reduction, it would create an

emission reduction [of] 20,800 tpy." !d. The Agency stated that the CTG expects "eosteffectiveness ofimplementing the CTG's approaches to control YOM emissions would be about

$1,200 per ton" Jd.

The Agency stated that USEPA expects the use of add-on controls to reduce emissions

from cleaning materials to be costly. TSD at 26. The Agency attributed this cost to the

likelihood that "the area that would be controlled has a large volume of air that would be

captured and directed to a control device." Jd., citing Control Techniques Guideline for Paper,

Foil, and Foil Coatings, Office of Air Quality Planning and Standards USEPA 453/R07-003

(Sept. 2007).

Large Appliance Coatings

The Agency stated that USEPA expects affected sources to rely on the low-YOM

coatings materials alternative. TSD at 26 (§4.2). The Agency attributed this expectation to two

factors: "I) complying low-YOM coatings are already available on the market at a cost that is

not much greater than the cost of coating materials with higher YOM contents; and 2) the use of

add-on controls to reduce YOM emissions from average spray coating operations would be a

more costly alternative." !d. at 26-27.

The Agency stated that, by taking into account the use oflow-YOM coatings, the 90%

overall control efficiency, and cleaning materials work practices, USEPA expects "that the costeffectiveness for a medium sized facility that uses waterborne prime and higher solids topcoat

would be approximately $425 per ton in 2006 dollars." TSD at 27. The Agency noted, however,

that "the 2002 NESHAP presented a control cost of $480,000 for approximately 1,000 tons of

HAP reduction from 74 facilities anticipated to be subject to the rule ($480 per ton ofHAP

reduced in 2006 dollars)." Jd. The Agency reported that USEPA consequently expects an

approximate cost-effectiveness "of about $500 per ton ofYOM reduced, and a total annual cost

ofthe 1,000 tpy of emissions reduction to be $500,000." Jd., citing Control Techniques

Guidelines for Large Appliance Coatings, Office of Air Quality Planning and Standards, USEPA

453/R-07-004 (Sept. 2007).

Metal Furniture Coatings

The Agency stated that USEPA relied on the 2002 NEI database to estimate that

nationally there arc 143 metal furniture facilities located in an ozone NAA and whose YOM

emissions equal or exceed the applicability threshold. TSD at 27 (§4.3). The Agency stated that

USEPA assumes affected sources will rely on the low-YOM coatings materials alternative. !d.
15

The Agency attributed this expectation to two factors: "1) complying low-YOM coating

materials are already available on the market at a cost that is not much greater than the cost of

coating materials with higher YOM contents; and 2) the use of add-on controls to reducc YOM

emissions from average spray coating operations would be a more costly alternative." lei.

The Agency stated that studies carried out for the 2003 NESHAP showed that "the cost to

implement the control alternatives from the U.S. EPA's CTG for this category averaged across

all sizcs offacilities was as high as $1,670 per facility." TSD at 27. Regarding the 143 facilities

cited in the preceding paragraph, "total annual costs were estimated to be approximately

$240,500." lei. The Agency claimed that implementation ofthe proposed regulations "will

result in a 35% (1,200 tpy) reduction in YOM emissions from metal furniture coatings." lei. The

Agency stated that "U.S. EPA calculated the cost effectiveness to be about $200 per ton in YOM

emissions reduction." ld.

Summary of Economic Reasonableness and Technical Feasibility

Although the Board in a letter dated November 5, 2009, requested that DCEO conduct an

economic impact study on the Agency's amended rulemaking proposal (see 415 ILCS 5/27(b)(I)

(2008», the Board to date has received no response to that request. At the second hearing, the

Board received no testimony or comment regarding the absence of any response to the request.

See Tr.2 at 6-7.

In his pre-filed testimony on behalf ofthe Agency, Mr. Mahajan stated that "[t]he

Agency believcs that the proposed changes are technically feasible and economically

reasonable." Mahajan Test. at 6. The Agency further states that "[t]he technology for

controlling YOM emissions from Group III product categories is both technically feasible and

economically reasonable." TSD at 9. The Agency argues that "[a]ffected sources can meet the

requirements in the proposed amendments through a number ofreadily available control

techniques." ld.

No participant has offered evidence or arguments rebutting the Agency's position on

these issues. Having reviewed the record before it on the issues offeasibility and

reasonableness, the Board finds, as it did in adopting its proposal for second notice, that the

adoptcd rules below are both technically feasible'and economically reasonable.

SUMMARY OFADOPTED RULES

Subpart A: General Provisions

Existing Subpart A provides general requirements regarding organic material emissions

in Il1inois' two ozone NAAs. See 35111. Adm. Code 218.100-114, 219.100-113. The Agency's

proposal sought only to amend Section 218/219.106, which establishes compliance dates. See 35

111. Adm. Code 218.106, 219.106. Specifically, the Agency proposed to add a new Section

218.106(e) and a new Section 219.106(c), both of "which establish May I, 2011, as the

compliance date for sources subject to the rulemaking proposaL" SR at 10; see Prop. 218 at 9,
16

Prop. 219 at 8-9. In responding to questions at the first hearing, the Agency suggested that this

deadline should allow ample time for affected source to comply with the rule. Tr.l at 11. The

Agency also indicated that this proposed compliance date would not interfere with its pending

demonstrations that the two NAAs have attained the ozone NAAQS. Jd. at 12.

Subpart F: Coating Operations

Existing Subpart F addresses YOM emissions from coating operations. See 35 lI1. Adm.

Code 218.204-217, 219.204-217. The Agency proposed a number of amendments to the

provisions in that Subpart. See Prop. 218 at 10-52, Prop. 219 at 9-49. In this subsection of the

opinion, the Board separately addresses its adopted rules on a section-by-section basis.

Section 218/219.204: Emission .Limitations. The Agency stated that these sections

currently "specify YOM limits in terms ofmass ofYOM per volume of coating for paper

coating" and also "for air dried and baked coatings for large appliance coatings and metal

furniture coatings." Mahajan Test. at 3, 4; see 35 lI1. Adm. Code 218.204, 219.204. In its

proposal, the Agency first sought to amend these sections so that their introductory paragraphs

·refer to revisions made in subsequent subsections. SR at 11; see Prop. 218 at 10, Prop. 219 at 9.

Subsection (cl. The Agency proposed to amend this subsection "to specify YOM limits

in terms of mass ofYOM per mass ofsolids applied, and equivalent limits in terms ofmass of

YOM per mass of coatings applied." Mahajan Test. at 3; see Prop. 218 at 12, Prop. 219 at 11.

Regarding pressure sensitive tape and label surface coating, the Agency proposed "a lower YOM

limit of 0.20 kg per kg ofsolids (0.20 IbIlb ofsolids)." Mahajan Test. at 3; see Prop. 218 at 12,

Prop. 219 at 11. The Agency argued that, except for these two categories ofpressure sensitive

tape and label surface coating, "the YOM limits are equivalent to the existing YOM limits for

paper coating." Mahajan Test. at 3. The Agency further argued that these limitations reflect

those set forth in the CTG. See id..

The Note following this subsection addresses the application ofits provisions. See 35 lI1.

Adm. Code 218.204(c), 219.204(c). The Agency also sought to add to this Note language

providing that, "[o]n and after May 1,20]'], the paper coating limitation shall also not apply to

coating performed on or in-line with any digital printing press, or to size presses and on-machine

coaters on paperrnaking machines applying sizing or water-based clays." Prop. 218 at 12, Prop.

219 at 11; see SR at II. In its motion to amend, the Agency responded "to a Board

recommendation that any substantive requirements contained in Board "Notes" be instead placed

in the body of the proposed rule." Mot. Amend at 5 ('14); see Tr.1 at 15. The Agency sought to

amend its proposal by adding clarifying language to the Note and re-designating it as new

subsection (c)(3). Mot. Amend at 5. As noted above, the Board has granted the Agency's

motion and reflected those amendments in its order below.

Subsection (gl. This provision now establishes limits "in terms ofmass of YOM per

volume of coating for air dried and baked coatings" for metal furniture coatings. Mahajan Test.

at 4; see 35111. Adm. Code 218.204(g), 219.204(g). The Agency proposed to amend this

subsection to restrict the YOM content of these coatings "to the limitations set forth in the CTG."
17

SR at I I. More specifically, the Agency sought to establish "VOM limits for one-component

and multi-component general purpose coatings, and provide specific YOM emission limits for

certain specialty coatings." Mahajan Test. at 4; see Prop. 218 at 13-14, Prop. 219 at 12-13. For

a number oftypes of coatings, the Agency proposed separate emission limits in terms ofmass of

YOM per volume of coatings for baked and air-dried coatings. Mahajan Test. at 4; see Prop. 218

at 13-14, Prop. 219 at 12-13. In addition, the Agency proposed "equivalent YOM limits in terms

ofmass ofVOM per volume ofsolids applied." Mahajan Test. 4; see Prop. 218 at 13-14, Prop.

219 at 12-13; see also Tr.l at 12-14.

The Agency also proposed "that such limitations shall not apply to stencil coatings,

safety-indicating coatings, solid-film lubricants, electric-insulating and thermal-conducting

coatings, touch-up and repair coatings, or coating applications using hand-held aerosol cans."

SR at 11; see Mahajan Test. at 4, Prop. 218 at 14, Prop. 219 at 13. Responding to a question at

the first hearing, the Agency explained its basis for these exclusions. The Agency stated that

USEPA determined in the CTG that low-YOM coatings are not available in these categories,

requiring sources in those categories to use coatings with greater YOM content. Tr.1 at 14-15.

The Agency also suggested that these excluded categories employ coatings at relatively low rates

or volumes. See id. at 15.

Also during the first hearing, the Agency responded to a question by agreeing that it

proposed to add language exempting these categories in a note attached to subsection (g)(2).

Tr.1 at 15; see Prop. 218 at 14, Prop. 219 at 13. Although the Agency suggested that this

organization was consistent with other provisions in Subpart F, it agreed to incorporate the

proposed exemptions into the text of those regulations. See Tr.1 at 15-16. In its motion to

amend, the Agency proposed to redesignate the language ofthe proposed note as a new

subsection (g)(3). Mot. Amend at 7 (~6). As noted above, the Board has granted the Agency's

motion and reflected those amendments in its order below.

The Agency's proposal originally sought to require that metal furniture coating lines

employ specific application methods.. SR at II. Responding to a question at the first hearing,

the Agency indicated that it would consider whether these requirements should remain as

proposed in subsection (g)(3) or should be codified in another section. See Tr.1 at 19-20. In its

motion to amend, the Agency proposed to place these application method limitations in Section

218/219.218 addressing work practice standards. Mot. Amend at 1-5 (~3). As noted above, the

Board has granted the Agency's motion and reflected those amendments in its order below.

Subsection 0,). This provision now establishes limits "in terms of mass ofVOM per

volume of coating for air dried and baked coatings" for large appliance coatings. Mahajan Test.

at 4; see 35 Ill. Adm. Code 218.204(h), 219.204(h). The Agency proposed to amend this

subsection to restrict the YOM content ofthese coatings "to the limitations set forth in the CTG."

SR at II. More specifically, the Agency sought to establish "VOM .limits for one-component

and multi-component general purpose coatings, and provide specific YOM emission limits for

certain specialty coatings." Mahajan Test. at 4; see Prop. 218 at 15-16, Prop. 219 at 14-15. For

a number oftypes of coatings, the Agency proposed separate emission limits in terms of mass of

YOM per volume of coatings for baked and air-dried coatings. Mahajan Test. at 4; see Prop. 218
18

at 15-16, Prop. 219 at 12-13. In addition, the Agency proposed "equivalent YOM limits in tenns

ofmass of YOM per volume ofsolids applied." Mahajan Test. 4; see Prop. 218 at 13-14, Prop.

219 at 12-13; see also Tr.1 at 14-15.

Thc Agency also proposed "that such limitations shall not apply to stencil coatings,

safety-indicating coatings, solid-film lubricants, electric-insulating and thennal-conducting

coatings, touch-up and repair coatings, or coating applications using hand-held aerosol cans."

SR at 11; see Mahajan Test. at 4, Prop. 218 at 16, Prop. 219 at 15-16. Responding to a question

at thc first hearing, the Agency explaincd its basis for these exclusions. The Agency stated that

USEPA detennined in the CTG that low-YOM coatings are not available in these categories,

requiring sources in those catcgories to use coatings with greater YOM content. Tr.1 at 14-15.

The Agency also suggested that these excluded categories employ coatings at relatively low rates

or volumes. See id. at 15.

Also during the first hearing, the Agency responded to a question by agreeing that it

proposed to add language exempting these categories in a note attached to subsection (h)(2).

Tr.1 at 15; see Prop. 218 at 16, Prop. 219 at 15-16. Although the Agency suggested that this

organization was consistent with other provisions in Subpart F, it agreed to incorporate the

proposed exemptions into the text of those regulations. See Tr.1 at 15-16. In its motion to

amend, the Agency proposed to redesignate the language ofthe proposed note as a new

subsection (h)(3). Mot. Amend at 6-7 ("5). As noted above, the Board has granted thc Agency's

motion to amend.

The Agency's proposal originally sought to require that metal furniture coating lines

employ specific application methods. SR at II. Responding to a question at the first hearing,

the Agency indicated that it would consider whether these requirements should remain as

proposed in subsection (h)(3) or should be codified in another section. See Tr.1 at 19-20. In its

motion to amend, the Agency proposed to place these application method limitations in Section

218/219.218 addressing work practice standards. Mot. Amend at 1-5 (~3). The Board has

granted the Agency's motion to amend and addresses those application requirements below in its

summary of proposed Section 218/219.218.

Section 218/219.205: Daily-Weighted Average Limitations. Existing Section

218/219.205 allows compliance with the limitations in Section 218/219.204 through a daily

weighted averaging alternative. See 35 Ill. Adm. Code 218.205, 219.205. The Agency first

proposed to amend this Section by adding a subsection (j) to Section 218.205 and a subsection (i)

to Section 219.205 to provide "requirements for paper coating lines utilizing the daily weighted

averaging alternative on and after May 1,2011." SR at 12; see Prop. 218 at 29-30, Prop. 219 at

27. The Agency proposed to amend the introductory paragraphs ofthese Sections to add a

reference to the proposed new subsections. SR at 12, see Prop. 218 at 24, Prop. 219 at 22.

Finally, the Agency also proppsed to amend the existing subsection (a) to provide that its

requirements apply to paper coating lines only until May 1,2011. SR at 12; see Prop. 218 at 24,

Prop. 219 at 22.
19

Section 2181219.207: Alternative Emission Limitations. Existing Section 218/219.207

establishes alternative emission limitations based upon the operation of a capture system and

control device. See 35 Ill. Adm. Codc 218.207, 219.207. The Agency first proposed to amend

this Section by adding a subsection (1) to Section 218.207 and a subsection (k) to Section

219.207 to set "forth the requirements for paper, metal furniture, and large appliance coating

lines utilizing the alternative emissions limitation on and aftcr May 1, 20 II." SR at 12; see Prop.

218 at 34, Prop. 219 at 31. The Agcncy also proposed to amend the existing subsection (a) to

refer to the proposed new subsections. SR at 12, see Prop. 218 at 30, Prop. 219 at 27. The

Agency also proposed to amend the existing subsection (c), (j), and (k) in Section 218.207 and

the existing subsections (c), (i), and (j) in Section 219.207 "to provide that such subsections only

apply to paper coating lines, metal furniture coating lines, and largc appliance coating lines,

respectively, until May 1, 2011." SR at 12; see Prop. 218 at 31, 33, Prop. 2 I9 at 28, 30-31.

Section 218/219.210: Compliance Schedule. Existing Scction 218/219.2 I0 establishes

compliance schedules for coating lines subject to various requirements under Subpart F. 35 Ill.

Adm. Code 218,210, 219.210, The Agency proposed to add a new subscction (g) providing

"that, on and after a date consistent with Section 218/219.106, sources subject to the proposed

paper, metal furniture, or large appliance coating limitations shall comply with such limitations,

as well as with all other applicable provisions in Subpart F." SR at 12; see Prop, 218 at 35, Prop,

219 at 32. The Agency also proposed to amend the introductory paragraph of the section to refcr

to the proposed ncw subsection, SR at 12; see Prop. 218 at 34, Prop. 2 I9 at 3 I.

Section 218/219.211: Recordkeeping and Reporting. Existing Section 218/2 I9.211

establishes recordkeeping and reporting requirements for affected coating operations, 35 Ill.

Adm, Code 218,211, 219.211. The Agency proposed to amend various subsections ofthat

provision, as describcd separately below. See Prop. 218 at 35-46, Prop. 219 at 32-44.

Subsection (c). The Agency proposed to amend subsection (c) "to provide that, for paper

coating lines subject to the proposed YOM content limitations, YOM content information shall

be maintained and/or reported in terms ofweight ofYOM per weight ofsolids or coatings, as

applicable, as applied each day on each coating line." SR at 13; see Prop. 218 at 39, Prop. 219 at

36. The Agency also proposed to amend this subsection "to provide that metal furniture and

large appliance coating lines subject to the proposed YOM content limitations maintain and/or

report YOM content infornlation in terms of weight ofYOM per volume of each coating or

solids, as applicable, as applied each day on each coating line, and report the application

methodes) used to apply coatings on each subject coating line." SR at 13; see Prop. 218 at 39,

Prop. 219 at 36. The Agency also sought to require that "[pJaper, metal furniture, and large

appliance coating lines shall also maintain and report certified product data sheets for each

coating applied on each line," SR at 13; see Prop. 218 at 39-40, Prop, 219 at 37,

Snbsection (d), The Agency propo'sed to amend subsection (d) "to provide that, for

paper coating lines utilizing the daily weighted averaging alternative, YOM content information

shall be maintained and/or reported in terms ofweight ofYOM per weight ofsolids or coatings,

as applicable, as applied each day on each coating line," SR at 13; see Prop, 218 at 40-43, Prop.

219 at 37-40. The Agency also proposed to amend this subsection "to provide that metal
20

furniture and large appliance coating lines utilizing the daily weighted averaging altemative

maintain and/or report YOM content infonnation in tenns ofweight ofVOM per volume of each

coating or solids, as applicable, as applied each day on each coating line." SR at 13; see Prop.

218 at 40-43, Prop. 219 at 37-40.

Subsection (el. The Agency proposed to amend subsection (e) to provide that coating

lines complying through the alternative emission limitations must comply with the recordkeeping

and rcporting requirements specified in the subsection. SR at 13-14; see Prop. 218 at 43, Prop.

219at40.

Subsection (el. The Agency proposed to add a new subsection (g) establishing

"recordkeeping and reporting requirements for paper, metal furniture, and large appliance

coating lines subject to the work practice requirements set forth in Section 218/219.218." SR at

14; see Prop. 218 at 46, Prop. 219 at 43-44.

Section 218/219.212: Cross-Line Averaging to Establish Compliance for Coating

Lines. Existing Section 218/219.212 allows specified coating lines to establish compliance with

YOM content limitations through cross-line averaging. See 35 Ill. Adm. Code 218.212, 219.212.

The Agency proposed "amending this Section to provide that the cross-line averaging alternative

is not available to coating lines subject to the revised YOM content limitations." See SR at 14;

see Prop.l18 at 47, Prop. 219 at 44.

Section 218/219.218: Work Practice Standards for Paper Coatings, Metal Furniture

Coatings, and Large Appliance Coatings: The Agency proposed to add a new section setting

"forth work practice requirements for cleaning materials and/or cleaning-related activities

associated with paper, metal furniture, and large appliance coating lines." SR at 14. The Agency

generally proposed

that subject coating lines store all YOM-containing materials in closed containers,

ensure that mixing and storage containers used for VOM-eontaining materials are

kept closed at all times cxcept when in use, minimize spills ofVOM-containing

materials, convey such materials from one location to another in closed containers

or pipes, and minimize YOM emissions from the cleaning ofstorage, mixing, and

conveying equipment. SR. at 14; see Prop. 218 at 48-49, Prop. 219 at 48-49.

The Agency's' proposal originally sought to require in Section 218/219.204 that metal

furniture and large appliance coating lines employ specific application methods. SR at 11; see

Prop. 218 at 14-15, 16-17, Prop. 219 at 13-14, 16. Responding to a question atthe first hearing,

the Agency indicated that it would consider whether these requirements should remain in that

Section or should be codified in a different section. See Tr.1 at 19-20. In its motion to amend,

the Agency proposed to place these application method limitations in Section 218/219.218,

which addresses work practice standards, instead of Section 218/219.204. Mot. Amend at 1-5

('13). As noted above, the Board has granted the Agency's motion to amend.
21

Those application methods include elcctrostatic application, HVLP spray, flow coat,

roller coat, dip coat including electrodeposition, or other coating applications with a transfer

efficiency equivalent to or better than that achieved by HVLP spraying. Mahajan Test. at 4-5;

see Mot. Amend at 4-5. Responding to a question at the first hearing, the Agency explained its

basis for these requirements. The Agency stated that the listed methods are more efficient in

terms of applying solids to a substrate. Tr.1 at 17. The Agenqr indicated that, while a spray gun

may provide 25% efficiency, the listed methods provide "more than 40, 60, even 70, 90 percent

efficiencies." !d. The Agency stated that these higher efficicncies reduce YOM emissions from

the coating operations and are recommendcd by the CTG. Id. at 17-18.

CONCLUSION

The Board proposes for final adoption amendments to its regulations govcrning YOM

emissions in Parts 218 and 219 (35 Ill. Adm. Code 218,219). Substantively, the Board is

adopting the Agency's proposal including changes reflected in the Agency's motion to amend,

which the Board has granted above. See Mot. Amend. The Board also makes non-substantive

changes, including those offered by ICAR, which are not addressed in this opinion.

ORDER

The Board directs the Clerk to file the following adopted rule with the Secretary of State

for publication in the Illinois Register. Proposed additions are underlined, and proposed deletions

appear stricken.

TITLE 35: ENVIRONMENTAL PROTECTION

SUBTITLE B: AIR POLLUTION

CHAPTER I: POLLUTION CONTROL BOARD

SUBCHAPTER c: EMISSIONS STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART 218

ORGANIC MATERIAL EMISSION STANDARDS AND

LIMITATIONS FOR THE CHICAGO AREA

SUBPART A: GENERAL PROVISIONS

Section

218.100

218.101

218.102

218.103

218.104

218.105

218.106

Introduction

Savings Clause

Abbreviations and Conversion Factors

Applicability

Definitions

Test Methods and Procedures

Compliance Dates
B 16
OFFICE OF THE SECRETARY OF STATE

JESSE WHITE' Secretary of State

April I, 2010

POLLUTION CONTROL BOARD

JOHN THERRIAULT ASSISTANT CLERK

100 W RANDOLPH ST, STE JI-500

CHICAGO,IL 60601

Dear JOHN THERRIAULT ASSISTANT CLERK

RECEiVED

CLERK'S OFFICE

APR 08 2010

STATE OF ILLINOIS

Pollution Control Board

Your rules Listed below met our codification standards and have been published in Volume 34,

Issue 15 ofthe Illinois Register, dated 4/9/2010.

ADOPTED RULES

Organic Material Emission Standards and Limitations for the Chicago Area

35 I]!. Adm. Code 218 5330

Point ofContact: Nancy Miller

Organic Material Emission Standards and Limitations for the Metro East Area

35111. Adm. Code 219 5392

Point of Contact: Nancy Miller

If you have any questions, you may contact the Administrative Code Division at

(217) 782 - 7017

Index Department - Administrative Code Division - I I I East Momoe Springfield, IL 62756
B 17
i 

Volume 34,Issue 15

April 9, 2010 

Pages 4947-5491 
 ILLINOIS REGISTER 5330

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

1) Heading of the Part: Organic Material Emission Standards and Limitations for the 

Chicago Area 

2) Code Citation: 35 Ill. Adm. Code 218 

3) Section Numbers: Adopted Action: 

218.106 Amended 

218.204 Amended 

218.205 Amended 

218.207 Amended 

218.210 Amended 

218.211 Amended 

218.212 Amended 

218.218 New 

4) Statutory Authority: Implementing Section 10 and authorized by Sections 27, 28, and 

28.5 of the Environmental Protection Act [415 ILCS 5/10, 27, 28, and 28.5] 

5) Effective Date of Amendments: March 23, 2010 

6) Does this rulemaking contain an automatic repeal date? No 

 

7) Does this rulemaking contain incorporations by reference? No 

8) A copy of the adopted amendments, including any material incorporated by reference, is 

on file in the Board's Chicago office at the James R. Thompson Center, 100 W. 

Randolph, Suite 11-500, and is available there for public inspection. 

9) Notice of Proposal Published in Illinois Register: 33 Ill. Reg. 16399; November 20, 2009 

10) Has JCAR issued a Statement of Objection to these amendments? No 

11) Differences between proposal and final version: In proceeding from its first-notice 

proposal to final adoption in this docket, the Board made changes proposed by the Illinois 

Environmental Protection Agency in a motion to amend its rulemaking proposal. 

In Section 218.204(c), which addresses emission limitations for paper coating operations, 

the Board placed the language of an amended Note regarding applicability of limitations 

in the body of the rule as subsection (c)(3). 
 ILLINOIS REGISTER 5331

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

The Board deleted limitations on application methods from Section 218.204(g)(3), which 

addresses emission limitations for metal furniture coating operations, and placed those 

requirements instead in Section 218.218(b)(6) which establishes work practice standards 

for various operations. 

In Section 218.204(g), which addresses emission limitations for metal furniture coating 

operations, the Board placed the language of a proposed Note following subsection 

(g)(2)(H) regarding applicability of limitations in the body of the rules as subsection 

(g)(3). 

The Board deleted limitations on application methods from Section 218.204(h)(3), which 

addresses emission limitations for large appliance coating operations, and placed those 

requirements instead in Section 218.218(b)(6), which establishes work practice standards 

for various operations. 

In Section 218.204(h), which addresses emission limitations for large appliance coating 

operations, the Board placed the language of an amended Note following subsection 

(h)(2)(H) regarding applicability of limitations in the body of the rule as subsection 

(h)(3). 

The Board's opinion and order adopting these rules addresses changes made by the Board 

in proceeding from first notice to final adoption. See Reasonably Available Control 

Technology (RACT) for Volatile Organic Material Emissions from Group III Consumer 

& Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 218 and 219, 

R10-10 (March 18, 2010). Copies of the Board's opinions and orders may be requested 

from the Clerk of the Board at the address listed in #8 above or by calling 312/814-3620. 

Please refer to the Board docket number R10-10 in your request. The Board order is also 

available through the Board's Web site (www.ipcb.state.il.us). 

12) Have all the changes agreed upon by the agency and JCAR been made as indicated in the 

agreements letter issued by JCAR? Yes 

13) Will this rulemaking replace any emergency rulemaking currently in effect? No 

14) Are there any amendments pending on this Part? Yes 

Section Numbers: Proposed Action: Illinois Register Citation: 
 ILLINOIS REGISTER 5332

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.106 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.181 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.187 New 34 Ill. Reg. 1791; February 5, 2010 

218.204 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.205 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.207 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.210 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.211 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.212 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.217 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.401 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.402 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.403 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.404 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.405 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.406 Repeal 34 Ill. Reg. 1791; February 5, 2010 

218.407 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.408 Repeal 34 Ill. Reg. 1791; February 5, 2010 

218.409 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.410 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.411 Amend 34 Ill. Reg. 1791; February 5, 2010 

218.412 New 34 Ill. Reg. 1791; February 5, 2010 

218.413 New 34 Ill. Reg. 1791; February 5, 2010 

218.415 New 34 Ill. Reg. 1791; February 5, 2010 

218.416 New 34 Ill. Reg. 1791; February 5, 2010 

218.417 New 34 Ill. Reg. 1791; February 5, 2010 

218.105 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.106 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.112 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.204 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.205 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.207 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.208 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.210 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.211 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.212 Amended 34 Ill. Reg. 4335; April 2, 2010 

218.219 New 34 Ill. Reg. 4335; April 2, 2010 

218.890 New 34 Ill. Reg. 4335; April 2, 2010 

218.891 New 34 Ill. Reg. 4335; April 2, 2010 
 ILLINOIS REGISTER 5333

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.892 New 34 Ill. Reg. 4335; April 2, 2010 

218.894 New 34 Ill. Reg. 4335; April 2, 2010 

218.900 New 34 Ill. Reg. 4335; April 2, 2010 

218.901 New 34 Ill. Reg. 4335; April 2, 2010 

218.902 New 34 Ill. Reg. 4335; April 2, 2010 

218.903 New 34 Ill. Reg. 4335; April 2, 2010 

218.904 New 34 Ill. Reg. 4335; April 2, 2010 

15) Summary and Purpose of Amendments: For a more detailed description of this 

rulemaking, please see the Board's March 18, 2010, opinion and order. Reasonably 

Available Control Technology (RACT) for Volatile Organic Material Emissions from 

Group III Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. 

Code 218 and 219, R10-10 (March 18, 2010). The Illinois Environmental Protection 

Agency (Agency) filed this adopted rulemaking as a proposal to meet Illinois' obligation 

to submit a State Implementation Plan addressing requirements under Sections 172 and 

182 of the federal Clean Air Act, 42 U.S.C. § 7401 et seq., for sources of volatile organic 

material (VOM) emissions in areas designated as nonattainment with respect to the ozone 

National Ambient Air Quality Standard. The United States Environmental Protection 

Agency (USEPA) issued Control Techniques Guidelines (CTGs) for the following Group 

III Consumer and Commercial Product Categories: Paper, Film, and Foil Coatings; 

Metal Furniture Coatings; and Large Appliance Coatings. In the CTGs, the USEPA 

recommended control measures that it believes constitute reasonably available control 

technology for those product categories. The Agency proposed to amend Part 218 to 

implement such recommendations for the Chicago nonattainment area, and PCB now 

adopts such regulations. 

16) Information and questions regarding these adopted amendments shall be directed to: 

 Timothy Fox 

Illinois Pollution Control Board 

100 W. Randolph 11-500 

Chicago, IL 60601 

312/814-6085 

Copies of the Board's opinions and orders may be requested from the Clerk of the Board 

at the address listed in #8 above or by calling 312/814-3620. Please refer to the Docket 

number R10-10 in your request. The Board order is also available from the Board's Web 

site (www.ipcb.state.il.us). 
 ILLINOIS REGISTER 5334

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

The full text of the Adopted Amendments begins on the next page: 
 ILLINOIS REGISTER 5335

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

TITLE 35: ENVIRONMENTAL PROTECTION 

SUBTITLE B: AIR POLLUTION 

CHAPTER I: POLLUTION CONTROL BOARD 

SUBCHAPTER c: EMISSIONS STANDARDS AND 

LIMITATIONS FOR STATIONARY SOURCES 

PART 218 

ORGANIC MATERIAL EMISSION STANDARDS AND 

LIMITATIONS FOR THE CHICAGO AREA 

SUBPART A: GENERAL PROVISIONS 

Section 

218.100 Introduction 

218.101 Savings Clause 

218.102 Abbreviations and Conversion Factors 

218.103 Applicability 

218.104 Definitions 

218.105 Test Methods and Procedures 

218.106 Compliance Dates 

218.107 Operation of Afterburners 

218.108 Exemptions, Variations, and Alternative Means of Control or Compliance 

Determinations 

218.109 Vapor Pressure of Volatile Organic Liquids 

218.110 Vapor Pressure of Organic Material or Solvent 

218.111 Vapor Pressure of Volatile Organic Material 

218.112 Incorporations by Reference 

218.113 Monitoring for Negligibly-Reactive Compounds 

218.114 Compliance with Permit Conditions 

SUBPART B: ORGANIC EMISSIONS FROM STORAGE 

AND LOADING OPERATIONS 

Section 

218.119 Applicability for VOL 

218.120 Control Requirements for Storage Containers of VOL 

218.121 Storage Containers of VPL 

218.122 Loading Operations 

218.123 Petroleum Liquid Storage Tanks 
 ILLINOIS REGISTER 5336

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.124 External Floating Roofs 

218.125 Compliance Dates 

218.126 Compliance Plan (Repealed) 

218.127 Testing VOL Operations 

218.128 Monitoring VOL Operations 

218.129 Recordkeeping and Reporting for VOL Operations 

SUBPART C: ORGANIC EMISSIONS FROM MISCELLANEOUS EQUIPMENT 

Section 

218.141 Separation Operations 

218.142 Pumps and Compressors 

218.143 Vapor Blowdown 

218.144 Safety Relief Valves 

SUBPART E: SOLVENT CLEANING 

Section 

218.181 Solvent Cleaning in General 

218.182 Cold Cleaning 

218.183 Open Top Vapor Degreasing 

218.184 Conveyorized Degreasing 

218.185 Compliance Schedule (Repealed) 

218.186 Test Methods 

SUBPART F: COATING OPERATIONS 

Section 

218.204 Emission Limitations 

218.205 Daily-Weighted Average Limitations 

218.206 Solids Basis Calculation 

218.207 Alternative Emission Limitations 

218.208 Exemptions from Emission Limitations 

218.209 Exemption from General Rule on Use of Organic Material 

218.210 Compliance Schedule 

218.211 Recordkeeping and Reporting 

218.212 Cross-Line Averaging to Establish Compliance for Coating Lines 

218.213 Recordkeeping and Reporting for Cross-Line Averaging Participating Coating 

Lines 
 ILLINOIS REGISTER 5337

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.214 Changing Compliance Methods 

218.215 Wood Furniture Coating Averaging Approach 

218.216 Wood Furniture Coating Add-On Control Use 

218.217 Wood Furniture Coating Work Practice Standards 

218.218 Work Practice Standards for Paper Coatings, Metal Furniture Coatings, and Large 

Appliance Coatings

SUBPART G: USE OF ORGANIC MATERIAL 

Section 

218.301 Use of Organic Material 

218.302 Alternative Standard 

218.303 Fuel Combustion Emission Units 

218.304 Operations with Compliance Program 

SUBPART H: PRINTING AND PUBLISHING 

Section 

218.401 Flexographic and Rotogravure Printing 

218.402 Applicability 

218.403 Compliance Schedule 

218.404 Recordkeeping and Reporting 

218.405 Lithographic Printing: Applicability 

218.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to March 

15, 1996 

218.407 Emission Limitations and Control Requirements for Lithographic Printing Lines 

On and After March 15, 1996 

218.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996 

218.409 Testing for Lithographic Printing On and After March 15, 1996 

218.410 Monitoring Requirements for Lithographic Printing 

218.411 Recordkeeping and Reporting for Lithographic Printing 

SUBPART Q: SYNTHETIC ORGANIC CHEMICAL 

AND POLYMER MANUFACTURING PLANT 

Section 

218.421 General Requirements 

218.422 Inspection Program Plan for Leaks 

218.423 Inspection Program for Leaks 
 ILLINOIS REGISTER 5338

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.424 Repairing Leaks 

218.425 Recordkeeping for Leaks 

218.426 Report for Leaks 

218.427 Alternative Program for Leaks 

218.428 Open-Ended Valves 

218.429 Standards for Control Devices 

218.430 Compliance Date (Repealed) 

218.431 Applicability 

218.432 Control Requirements 

218.433 Performance and Testing Requirements 

218.434 Monitoring Requirements 

218.435 Recordkeeping and Reporting Requirements 

218.436 Compliance Date 

SUBPART R: PETROLEUM REFINING AND 

RELATED INDUSTRIES; ASPHALT MATERIALS 

Section 

218.441 Petroleum Refinery Waste Gas Disposal 

218.442 Vacuum Producing Systems 

218.443 Wastewater (Oil/Water) Separator 

218.444 Process Unit Turnarounds 

218.445 Leaks: General Requirements 

218.446 Monitoring Program Plan for Leaks 

218.447 Monitoring Program for Leaks 

218.448 Recordkeeping for Leaks 

218.449 Reporting for Leaks 

218.450 Alternative Program for Leaks 

218.451 Sealing Device Requirements 

218.452 Compliance Schedule for Leaks 

218.453 Compliance Dates (Repealed) 

SUBPART S: RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS 

Section 

218.461 Manufacture of Pneumatic Rubber Tires 

218.462 Green Tire Spraying Operations 

218.463 Alternative Emission Reduction Systems 

218.464 Emission Testing 
 ILLINOIS REGISTER 5339

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.465 Compliance Dates (Repealed) 

218.466 Compliance Plan (Repealed) 

SUBPART T: PHARMACEUTICAL MANUFACTURING 

Section 

218.480 Applicability 

218.481 Control of Reactors, Distillation Units, Crystallizers, Centrifuges and Vacuum 

Dryers 

218.482 Control of Air Dryers, Production Equipment Exhaust Systems and Filters 

218.483 Material Storage and Transfer 

218.484 In-Process Tanks 

218.485 Leaks 

218.486 Other Emission Units 

218.487 Testing 

218.488 Monitoring for Air Pollution Control Equipment 

218.489 Recordkeeping for Air Pollution Control Equipment 

SUBPART V: BATCH OPERATIONS AND AIR OXIDATION PROCESSES 

Section 

218.500 Applicability for Batch Operations 

218.501 Control Requirements for Batch Operations 

218.502 Determination of Uncontrolled Total Annual Mass Emissions and Average Flow 

Rate Values for Batch Operations 

218.503 Performance and Testing Requirements for Batch Operations 

218.504 Monitoring Requirements for Batch Operations 

218.505 Reporting and Recordkeeping for Batch Operations 

218.506 Compliance Date 

218.520 Emission Limitations for Air Oxidation Processes 

218.521 Definitions (Repealed) 

218.522 Savings Clause 

218.523 Compliance 

218.524 Determination of Applicability 

218.525 Emission Limitations for Air Oxidation Processes 

218.526 Testing and Monitoring 

218.527 Compliance Date (Repealed) 

SUBPART W: AGRICULTURE 
 ILLINOIS REGISTER 5340

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

Section 

218.541 Pesticide Exception 

SUBPART X: CONSTRUCTION 

Section 

218.561 Architectural Coatings 

218.562 Paving Operations 

218.563 Cutback Asphalt 

SUBPART Y: GASOLINE DISTRIBUTION 

Section 

218.581 Bulk Gasoline Plants 

218.582 Bulk Gasoline Terminals 

218.583 Gasoline Dispensing Operations – Storage Tank Filling Operations 

218.584 Gasoline Delivery Vessels 

218.585 Gasoline Volatility Standards 

218.586 Gasoline Dispensing Operations – Motor Vehicle Fueling Operations 

SUBPART Z: DRY CLEANERS 

Section 

218.601 Perchloroethylene Dry Cleaners (Repealed) 

218.602 Applicability (Repealed) 

218.603 Leaks (Repealed) 

218.604 Compliance Dates (Repealed) 

218.605 Compliance Plan (Repealed) 

218.606 Exception to Compliance Plan (Repealed) 

218.607 Standards for Petroleum Solvent Dry Cleaners 

218.608 Operating Practices for Petroleum Solvent Dry Cleaners 

218.609 Program for Inspection and Repair of Leaks 

218.610 Testing and Monitoring 

218.611 Applicability for Petroleum Solvent Dry Cleaners 

218.612 Compliance Dates (Repealed) 

218.613 Compliance Plan (Repealed) 

SUBPART AA: PAINT AND INK MANUFACTURING 
 ILLINOIS REGISTER 5341

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

Section 

218.620 Applicability 

218.621 Exemption for Waterbase Material and Heatset-Offset Ink 

218.623 Permit Conditions (Repealed) 

218.624 Open-Top Mills, Tanks, Vats or Vessels 

218.625 Grinding Mills 

218.626 Storage Tanks 

218.628 Leaks 

218.630 Clean Up 

218.636 Compliance Schedule 

218.637 Recordkeeping and Reporting 

SUBPART BB: POLYSTYRENE PLANTS 

Section 

218.640 Applicability 

218.642 Emissions Limitation at Polystyrene Plants 

218.644 Emissions Testing 

SUBPART CC: POLYESTER RESIN PRODUCT MANUFACTURING PROCESS 

Section 

218.660 Applicability 

218.666 Control Requirements 

218.667 Compliance Schedule 

218.668 Testing 

218.670 Recordkeeping and Reporting for Exempt Emission Units 

218.672 Recordkeeping and Reporting for Subject Emission Units 

SUBPART DD: AEROSOL CAN FILLING 

Section 

218.680 Applicability 

218.686 Control Requirements 

218.688 Testing 

218.690 Recordkeeping and Reporting for Exempt Emission Units 

218.692 Recordkeeping and Reporting for Subject Emission Units 
 ILLINOIS REGISTER 5342

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SUBPART FF: BAKERY OVENS (REPEALED) 

Section 

218.720 Applicability (Repealed) 

218.722 Control Requirements (Repealed) 

218.726 Testing (Repealed) 

218.727 Monitoring (Repealed) 

218.728 Recordkeeping and Reporting (Repealed) 

218.729 Compliance Date (Repealed) 

218.730 Certification (Repealed) 

SUBPART GG: MARINE TERMINALS 

Section 

218.760 Applicability 

218.762 Control Requirements 

218.764 Compliance Certification 

218.766 Leaks 

218.768 Testing and Monitoring 

218.770 Recordkeeping and Reporting 

SUBPART HH: MOTOR VEHICLE REFINISHING 

Section 

218.780 Emission Limitations 

218.782 Alternative Control Requirements 

218.784 Equipment Specifications 

218.786 Surface Preparation Materials 

218.787 Work Practices 

218.788 Testing 

218.789 Monitoring and Recordkeeping for Control Devices 

218.790 General Recordkeeping and Reporting (Repealed) 

218.791 Compliance Date 

218.792 Registration 

218.875 Applicability of Subpart BB (Renumbered) 

218.877 Emissions Limitation at Polystyrene Plants (Renumbered) 

218.879 Compliance Date (Repealed) 

218.881 Compliance Plan (Repealed) 

218.883 Special Requirements for Compliance Plan (Repealed) 
 ILLINOIS REGISTER 5343

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.886 Emissions Testing (Renumbered) 

SUBPART PP: MISCELLANEOUS FABRICATED PRODUCT 

MANUFACTURING PROCESSES 

Section 

218.920 Applicability 

218.923 Permit Conditions (Repealed) 

218.926 Control Requirements 

218.927 Compliance Schedule 

218.928 Testing 

218.929 Cementable and Dress or Performance Shoe Leather 

SUBPART QQ: MISCELLANEOUS FORMULATION 

MANUFACTURING PROCESSES 

Section 

218.940 Applicability 

218.943 Permit Conditions (Repealed) 

218.946 Control Requirements 

218.947 Compliance Schedule 

218.948 Testing 

SUBPART RR: MISCELLANEOUS ORGANIC CHEMICAL 

MANUFACTURING PROCESSES 

Section 

218.960 Applicability 

218.963 Permit Conditions (Repealed) 

218.966 Control Requirements 

218.967 Compliance Schedule 

218.968 Testing 

SUBPART TT: OTHER EMISSION UNITS 

Section 

218.980 Applicability 

218.983 Permit Conditions (Repealed) 

218.986 Control Requirements 
 ILLINOIS REGISTER 5344

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

218.987 Compliance Schedule 

218.988 Testing 

SUBPART UU: RECORDKEEPING AND REPORTING 

Section 

218.990 Exempt Emission Units 

218.991 Subject Emission Units 

218.APPENDIX A List of Chemicals Defining Synthetic Organic Chemical and Polymer 

Manufacturing 

218.APPENDIX B VOM Measurement Techniques for Capture Efficiency (Repealed) 

218.APPENDIX C Reference Methods and Procedures 

218.APPENDIX D Coefficients for the Total Resource Effectiveness Index (TRE) Equation 

218.APPENDIX E List of Affected Marine Terminals 

218.APPENDIX G TRE Index Measurements for SOCMI Reactors and Distillation Units 

218.APPENDIX H Baseline VOM Content Limitations for Subpart F, Section 218.212 

Cross-Line Averaging 

AUTHORITY: Implementing Section 10 and authorized by Sections 27, 28, and 28.5 of the 

Environmental Protection Act [415 ILCS 5/10, 27, 28, and 28.5]. 

SOURCE: Adopted at R91-7 at 15 Ill. Reg. 12231, effective August 16, 1991; amended in R91-

24 at 16 Ill. Reg. 13564, effective August 24, 1992; amended in R91-28 and R91-30 at 16 Ill. 

Reg. 13864, effective August 24, 1992; amended in R93-9 at 17 Ill. Reg. 16636, effective 

September 27, 1993; amended in R93-14 at 18 Ill. Reg. 1945, effective January 24, 1994; 

amended in R94-12 at 18 Ill. Reg. 14973, effective September 21, 1994; amended in R94-15 at 

18 Ill. Reg. 16392, effective October 25, 1994; amended in R94-16 at 18 Ill. Reg. 16950, 

effective November 15, 1994; amended in R94-21, R94-31 and R94-32 at 19 Ill. Reg. 6848, 

effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7359, effective May 22, 1995; 

amended in R96-13 at 20 Ill. Reg. 14428, effective October 17, 1996; amended in R97-24 at 21 

Ill. Reg. 7708, effective June 9, 1997; amended in R97-31 at 22 Ill. Reg. 3556, effective 

February 2, 1998; amended in R98-16 at 22 Ill. Reg. 14282, effective July 16, 1998; amended in 

R02-20 at 27 Ill. Reg. 7283, effective April 8, 2003; amended in R04-12/20 at 30 Ill. Reg. 9684, 

effective May 15, 2006; amended in R06-21 at 31 Ill. Reg. 7086, effective April 30, 2007; 

amended in R08-8 at 32 Ill. Reg. 14874, effective August 26, 2008; amended in R10-10 at 34 Ill. 

Reg. 5330, effective March 23, 2010. 

SUBPART A: GENERAL PROVISIONS 
 ILLINOIS REGISTER 5345

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NOTICE OF ADOPTED AMENDMENTS 

Section 218.106 Compliance Dates 

a) Except as otherwise provided in this Section or as otherwise provided in a specific 

Subpart of this Part, compliance with the requirements of all rules is required by 

July 1, 1991, or September 1, 1991, for all sources located in Cook, DuPage, 

Kane, Lake, McHenry, or Will Counties, consistent with the appropriate 

provisions of Section 218.103 of this Subpart. 

b) Except as otherwise provided in this Section or as otherwise provided in a specific 

Subpart of this Part, compliance with the requirements of this Part is required by 

November 15, 1993, for all sources located in Aux Sable Township or Goose 

Lake Township in Grundy County, or in Oswego Township in Kendall County. 

c) All emission units which meet the applicability requirements of Sections 

218.402(a)(2), 218.611(b), 218.620(b), 218.660(a), 218.680(a), 218.920(b), 

218.940(b), 218.960(b) or 218.980(b) of this Part, including emission units at 

sources which are excluded from the applicability criteria of Sections 

218.402(a)(1), 218.611(a), 218.620(a), 218.920(a), 218.940(a), 218.960(a), or 

218.980(a) of this Part by virtue of permit conditions or other enforceable means, 

must comply with the requirements of Subparts H, Z, AA, CC, DD, PP, QQ, RR 

or TT of this Part, respectively, by March 15, 1995. Any owner or operator of an 

emission unit which has already met the applicability requirements of Sections 

218.402(a)(1), 218.611(a), 218.620(a), 218.920(a), 218.940(a), 218.960(a) 

218.980(a) of this Part on or by the effective date of this subsection is required to 

comply with all compliance dates or schedules found in Sections 218.106(a) or 

218.106(b), as applicable. 

d) Any owner or operator of a source with an emission unit subject to the 

requirements of Section 218.204(m)(2) or (m)(3) of this Part shall comply with 

those requirements by March 25, 1995. 

e) Any owner or operator of a source subject to the requirements of Section 

218.204(c)(2), 218.204(g)(2), or 218.204(h)(2) of this Part shall comply with the 

applicable requirements in the applicable subsections, as well as all applicable 

requirements in Sections 218.205 through 218.214 and 218.218, by May 1, 2011.

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 
 ILLINOIS REGISTER 5346

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SUBPART F: COATING OPERATIONS 

Section 218.204 Emission Limitations 

Except as provided in Sections 218.205, 218.207, 218.208, 218.212, 218.215 and 218.216 of 

this Subpart, no owner or operator of a coating line shall apply at any time any coating in which 

the VOM content exceeds the following emission limitations for the specified coating. Except as 

otherwise provided in Section 218.204(c), 218.204(g), 218.204(h), and Section 218.204(l), 

compliance with the emission limitations marked with an asterisk in this Section is required on 

and after March 15, 1996, and compliance with emission limitations not marked with an asterisk 

is required until March 15, 1996. The following emission limitations are expressed in units of 

VOM per volume of coating (minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied at each coating applicator, except where noted. 

Compounds which are specifically exempted from the definition of VOM should be treated as 

water for the purpose of calculating the "less water" part of the coating composition. 

Compliance with this Subpart must be demonstrated through the applicable coating analysis test 

methods and procedures specified in Section 218.105(a) of this Part and the recordkeeping and 

reporting requirements specified in Section 218.211(c) of this Subpart except where noted. 

(Note: The equation presented in Section 218.206 of this Part shall be used to calculate emission 

limitations for determining compliance by add-on controls, credits for transfer efficiency, 

emissions trades and cross-line averaging.) The emission limitations are as follows: 

a) Automobile or Light-Duty Truck Coating kg/l lb/gal 

 1) Prime coat 0.14 (1.2) 

 0.14* (1.2)* 

 2) Primer surface coat 1.81 (15.1) 

 1.81* (15.1)* 

 (Note: The primer surface coat limitation is in units of kg (lbs) of VOM 

per l (gal) of coating solids deposited. Compliance with the limitation 

shall be based on the daily-weighted average from an entire primer 

surfacer operation. Compliance shall be demonstrated in accordance with 

the topcoat protocol referenced in Section 218.105(b) and the 

recordkeeping and reporting requirements specified in Section 218.211(f). 

Testing to demonstrate compliance shall be performed in accordance with 

the topcoat protocol and a detailed testing proposal approved by the 

Agency and USEPA specifying the method of demonstrating compliance 
 ILLINOIS REGISTER 5347

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

with the protocol. Section 218.205 does not apply to the primer surfacer 

limitation.) 

 3) Topcoat kg/l lb/gal 

 1.81 (15.1) 

 1.81* (15.1)* 

 (Note: The topcoat limitation is in units of kg (lbs) of VOM per l (gal) of 

coating solids deposited. Compliance with the limitation shall be based on 

the daily-weighted average from an entire topcoat operation. Compliance 

shall be demonstrated in accordance with the topcoat protocol referenced 

in Section 218.105(b) of this Part and the recordkeeping and reporting 

requirements specified in Section 218.211(f). Testing to demonstrate 

compliance shall be performed in accordance with the topcoat protocol 

and a detailed testing proposal approved by the Agency and USEPA 

specifying the method of demonstrating compliance with the protocol. 

Section 218.205 of this Part does not apply to the topcoat limitation.) 

 4) Final repair coat kg/l lb/gal 

 0.58 (4.8) 

 0.58* (4.8)* 

b) Can Coating kg/l lb/gal 

 1) Sheet basecoat and overvarnish 

 A) Sheet basecoat 0.34 (2.8) 

 0.26* (2.2)* 

 B) Overvarnish 0.34 (2.8) 

 0.34 (2.8)* 

 2) Exterior basecoat and overvarnish 0.34 (2.8) 

 0.25* (2.1)* 

 3) Interior body spray coat 

 A) Two piece 0.51 (4.2) 

 0.44* (3.7)* 
 ILLINOIS REGISTER 5348

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NOTICE OF ADOPTED AMENDMENTS 

 B) Three piece 0.51 (4.2) 

 0.51* (4.2)* 

 4) Exterior end coat 0.51 (4.2) 

 0.51* (4.2)* 

 5) Side seam spray coat 0.66 (5.5) 

 0.66* (5.5)* 

 

 6) End sealing compound coat 0.44 (3.7) 

 0.44* (3.7)* 

c) Paper Coating kg/l lb/gal

0.35 (2.9)

0.28* (2.3)*

1) Prior to May 1, 2011:

kg/l lb/gal

0.28 (2.3)

2) On and after May 1, 2011:

kg VOM/kg kg VOM/kg

(lb VOM/lb) (lb VOM/lb)

solids 

applied

coatings 

applied

A) Pressure sensitive tape and 

label surface coatings 0.20 (0.067)

B) All other paper coatings 0.40 (0.08)

3) (Note: The paper coating limitation set forth in this subsection (c) shall 

not apply to any owner or operator of any paper coating line on which 

flexographic or rotogravure printing is performed if the paper coating line 

complies with the emissions limitations in Section 218.401 of this Part. 

In addition, screen printing on paper is not regulated as paper coating, but 

is regulated under Subpart TT of this Part. On and after May 1, 2011, the 

paper coating limitation shall also not apply to coating performed on or 

in-line with any digital printing press, or to size presses and on-machine 

coaters on papermaking machines applying sizing or water-based clays.)
 ILLINOIS REGISTER 5349

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NOTICE OF ADOPTED AMENDMENTS 

d) Coil Coating kg/l lb/gal 

 0.31 (2.6) 

 0.20* (1.7)* 

e) Fabric Coating 0.35 (2.9) 

 0.28* (2.3)* 

f) Vinyl Coating 0.45 (3.8) 

 0.28* (2.3)* 

g) Metal Furniture Coating 

1) Prior to May 1, 2011:

kg/l lb/gal

A) Air dried 0.34 (2.8)

B) Baked 0.28 (2.3)

2) On and after May 1, 2011: 

kg/l kg/l (lb/gal)

(lb/gal) solids applied

A) General, One-Component 0.275 0.40

(2.3) (3.3)

B) General, Multi-Component

i) Air Dried 0.340 0.55

(2.8) (4.5)

ii) Baked 0.275 0.40

(2.3) (3.3)

 C) Extreme High Gloss 

 i) Air Dried 0.340 0.55

 (2.8) (4.5)

 ii) Baked 0.360 0.61
 ILLINOIS REGISTER 5350

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 (3.0) (5.1)

 D) Extreme Performance 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

 E) Heat Resistant 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

 F) Metallic 0.420 0.80

 (3.5) (6.7)

 G) Pretreatment Coatings 0.420 0.80

 (3.5) (6.7)

 H) Solar Absorbent 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

1) Air dried 0.36 (3.0)

 0.34* (2.8)*

2) Baked 0.36 (3.0)

 0.28* (2.3)*

3) On and after May 1, 2011, the limitations set forth in this subsection (g) 
 ILLINOIS REGISTER 5351

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

shall not apply to stencil coatings, safety-indicating coatings, solid-film 

lubricants, electric-insulating and thermal-conducting coatings, touch-up 

and repair coatings, or coating applications utilizing hand-held aerosol 

cans.

h) Large Appliance Coating 

1) Prior to May 1, 2011:

kg/l lb/gal

A) Air Dried 0.34 (2.8)

B) Baked 0.28 (2.3)

2) On and after May 1, 2011: kg/l kg/l (lb/gal)

(lb/gal) solids 

applied

A) General, One Component 0.275 0.40

(2.3) (3.3)

B) General, Multi-Component

i) Air Dried 0.340 0.55

(2.8) (4.5)

ii) Baked 0.275 0.40

(2.3) (3.3)

C) Extreme High Gloss

i) Air Dried 0.340 0.55

(2.8) (4.5)

ii) Baked 0.360 0.61

(3.0) (5.1)

D) Extreme Performance

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

(3.0) (5.1)
 ILLINOIS REGISTER 5352

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

E) Heat Resistant

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

(3.0) (5.1)

F) Metallic 0.420 0.80

(3.5) (6.7)

G) Pretreatment Coatings 0.420 0.80

(3.5) (6.7)

H) Solar Absorbent

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

(3.0) (5.1)

3) BOARD NOTE: The limitations set forth in this subsection (h)The 

limitation shall not apply to the use of quick-drying lacquers for repair of 

scratches and nicks that occur during assembly, provided that the volume 

of coating does not exceed 0.95 1 (1 quart) in any one rolling eight-hour 

period. On and after May 1, 2011, these limitations shall also not apply to 

stencil coatings, safety-indicating coatings, solid-film lubricants, electricinsulating and thermal-conducting coatings, touch-up and repair coatings, 

or coating applications utilizing hand-held aerosol cans.

i) Magnet Wire Coating kg/1 lb/gal 

0.20 (1.7) 

0.20* (1.7)* 

j) Miscellaneous Metal Parts and Products Coating 

1) Clear coating 0.52 (4.3) 

0.52* (4.3)* 
 ILLINOIS REGISTER 5353

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 2) Extreme performance coating 

A) Air dried 0.42 (3.5) 

0.42* (3.5)* 

B) Baked 0.42 (3.5) 

0.40* (3.3)* 

3) Steel pail and drum interior coating 0.52 (4.3) 

0.52* (4.3)* 

 4) All other coatings 

A) Air Dried 0.42 (3.5) 

0.40* (3.3)* 

B) Baked 0.36 (3.0) 

0.34* (2.8)* 

 5) Marine engine coating 

A) Air Dried 0.42 (3.5) 

0.42* (3.5)* 

B) Baked 

i) Primer/Topcoat 0.42 (3.5) 

0.42* (3.5)* 

ii) Corrosion resistant basecoat 0.42 (3.5) 

0.28* (2.3)* 

C) Clear Coating 0.52 (4.3) 

0.52* (4.3)* 

 6) Metallic Coating 

A) Air Dried 0.42 (3.5) 

0.42* (3.5)* 
 ILLINOIS REGISTER 5354

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

B) Baked 0.36 (3.0) 

0.36 (3.0)* 

7) Definitions 

A) For purposes of subsection 218.204(j)(5) of this Section, the 

following terms are defined: 

i) "Corrosion resistant basecoat" means, for purposes of 

subsection 218.204(j)(5)(B)(ii) of this Section, a waterborne epoxy coating applied via an electrodeposition 

process to a metal surface prior to spray coating, for the 

purpose of enhancing corrosion resistance. 

ii) "Electrodeposition process" means, for purposes of 

subsection 218.204(j)(5) of this Section, a water-borne dip 

coating process in which opposite electrical charges are 

applied to the substrate and the coating. The coating is 

attracted to the substrate due to the electrochemical 

potential difference that is created. 

iii) "Marine engine coating" means, for purposes of subsection 

218.204(j)(5) of this Section, any extreme performance 

protective, decorative or functional coating applied to an 

engine that is used to propel watercraft. 

B) For purposes of subsection 218.204(j)(6) of this Section, "metallic 

coating" means a coating which contains more than 1⁄4 lb/gal of 

metal particles, as applied. 

k) Heavy Off-Highway Vehicle Products Coating kg/l lb/gal 

 1) Extreme performance prime coat 0.42 (3.5) 

 0.42* (3.5)* 

 2) Extreme performance topcoat (air dried) 0.42 (3.5) 

 0.42* (3.5)* 

 3) Final repair coat (air dried) 0.42 (3.5) 
 ILLINOIS REGISTER 5355

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 0.42* (3.5)* 

 4) All other coatings are subject to the emission limitations for 

miscellaneous metal parts and products coatings in subsection (j) above. 

l) Wood Furniture Coating 

 1) Limitations before March 15, 1998: kg/l lb/gal 

 

 A) Clear topcoat 0.67 (5.6) 

 B) Opaque stain 0.56 (4.7) 

 C) Pigmented coat 0.60 (5.0) 

 D) Repair coat 0.67 (5.6) 

 E) Sealer 0.67 (5.6) 

 F) Semi-transparent stain 0.79 (6.6) 

 G) Wash coat 0.73 (6.1) 

 (Note: Prior to March 15, 1998, an owner or operator of a wood furniture 

coating operation subject to this Section shall apply all coatings, with the 

exception of no more than 37.8 l (10 gal) of coating per day used for 

touch-up and repair operations, using one or more of the following 

application systems: airless spray application system, air-assisted airless 

spray application system, electrostatic spray application system, 

electrostatic bell or disc spray application system, heated airless spray 

application system, roller coating, brush or wipe coating application 

system, dip coating application system or high volume low pressure 

(HVLP) application system.) 

2) On and after March 15, 1998, wood furniture sealers and topcoats must 

comply with one of the limitations specified in subsections (l)(2)(A) 

through (E), below: 

 kg VOM/ lb VOM/ 
 ILLINOIS REGISTER 5356

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 kg solids lb solids 

 A) Topcoat 0.8 (0.8) 

 B) Sealers and topcoats with the 

following limits: 

 

 i) Sealer other than acid-cured 

alkyd amino vinyl sealer 

1.9 (1.9) 

 ii) Topcoat other than acidcured alkyd amino 

conversion varnish topcoat 

1.8 (1.8) 

 iii) Acid-cured alkyd amino 

vinyl sealer 

2.3 (2.3) 

 iv) Acid-cured alkyd amino 

conversion varnish topcoat 

2.0 (2.0) 

C) Meet the provisions of Section 218.215 of this Subpart for use of 

an averaging approach; 

D) Achieve a reduction in emissions equivalent to the requirements of 

subsection (l)(2)(A) or (B) of this Section, as calculated using 

Section 218.216 of this Subpart; or 

E) Use a combination of the methods specified in subsections 

(l)(2)(A) through (D) of this Section. 

3) Other wood furniture coating limitations on and after March 15, 1998: 

 kg/l lb/gal 

 A) Opaque stain 0.56 (4.7) 

 B) Non-topcoat pigmented coat 0.60 (5.0) 

 C) Repair coat 0.67 (5.6) 
 ILLINOIS REGISTER 5357

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 D) Semi-transparent stain 0.79 (6.6) 

 E) Wash coat 0.73 (6.1) 

4) Other wood furniture coating requirements on and after March 15, 1998: 

A) No source subject to the limitations of subsection (l)(2) or (3) of 

this Section and utilizing one or more wood furniture coating spray 

booths shall use strippable spray booth coatings containing more 

than 0.8 kg VOM/kg solids (0.8 lb VOM/lb solids), as applied. 

B) Any source subject to the limitations of subsection (l)(2) or (3) of 

this Section shall comply with the requirements of Section 218.217 

of this Subpart. 

C) Any source subject to the limitations of subsection (l)(2)(A) or (B) 

of this Section and utilizing one or more continuous coaters shall, 

for each continuous coater, use an initial coating which complies 

with the limitations of subsection (l)(2)(A) or (B) of this Section. 

The viscosity of the coating in each reservoir shall always be 

greater than or equal to the viscosity of the initial coating in the 

reservoir. The owner or operator shall: 

i) Monitor the viscosity of the coating in the reservoir with a 

viscosity meter or by testing the viscosity of the initial 

coating and retesting the coating in the reservoir each time 

solvent is added; 

ii) Collect and record the reservoir viscosity and the amount 

and weight of VOM per weight of solids of coating and 

solvent each time coating or solvent is added; and 

iii) Maintain these records at the source for a period of three 

years. 

m) Existing Diesel-Electric Locomotive Coating 

Lines in Cook County 

kg/l lb/gal 
 ILLINOIS REGISTER 5358

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 1) Extreme performance prime coat 0.42 (3.5) 

 0.42* (3.5)* 

 2) Extreme performance top-coat (air dried) 0.42 (3.5) 

 0.42* (3.5)* 

 3) Final repair coat (air dried) 0.42 (3.5) 

 0.42* (3.5)* 

 4) High-temperature aluminum coating 0.72 (6.0) 

 0.72* (6.0)* 

 5) All other coatings 0.36 (3.0) 

 0.36* (3.0)* 

n) Plastic Parts Coating: Automotive/Transportation kg/l lb/gal 

 1) Interiors 

 A) Baked 

 i) Color coat 0.49* (4.1)* 

 ii) Primer 0.46* (3.8)* 

 B) Air Dried 

 i) Color coat 0.38* (3.2)* 

 ii) Primer 0.42* (3.5)* 

 2) Exteriors (flexible and non-flexible) 

 A) Baked 

 i) Primer 0.60* (5.0)* 

 ii) Primer non-flexible 0.54* (4.5)* 
 ILLINOIS REGISTER 5359

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 iii) Clear coat 0.52* (4.3)* 

 iv) Color coat 0.55* (4.6)* 

 B) Air Dried 

 i) Primer 0.66* (5.5)* 

 ii) Clear coat 0.54* (4.5)* 

 iii) Color coat (red & black) 0.67* (5.6)* 

 iv) Color coat (others) 0.61* (5.1)* 

 3) Specialty 

 A) Vacuum metallizing basecoats, 

texture base coats 

0.66* (5.5)* 

 B) Black coatings, reflective argent 

coatings, air bag cover coatings, 

and soft coatings 

0.71* (5.9)* 

 C) Gloss reducers, vacuum metallizing 

topcoats, and texture topcoats 

0.77* (6.4)* 

 D) Stencil coatings, adhesion primers, 

ink pad coatings, electrostatic prep 

coatings, and resist coatings 

0.82* (6.8)* 

 E) Headlamp lens coatings 0.89* (7.4)* 

o) Plastic Parts Coating: Business Machine kg/l lb/gal 

 1) Primer 0.14* (1.2)* 

 2) Color coat (non-texture coat) 0.28* (2.3)* 

 3) Color coat (texture coat) 0.28* (2.3)* 
 ILLINOIS REGISTER 5360

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 4) Electromagnetic interference/radio 

frequency interference (EMI/RFI) 

shielding coatings 

0.48* (4.0)* 

 5) Specialty Coatings 

 A) Soft coat 0.52* (4.3)* 

 B) Plating resist 0.71* (5.9)* 

 C) Plating sensitizer 0.85* (7.1)* 

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.205 Daily-Weighted Average Limitations 

No owner or operator of a coating line subject to the limitations of Section 218.204 of this 

Subpart and complying by means of this Section shall operate the subject coating line unless the 

owner or operator has demonstrated compliance with subsection (a), (b), (c), (d), (e), (f), (g), (h),

or (i), or (j) of this Section (depending upon the category of coating) through the applicable 

coating analysis test methods and procedures specified in Section 218.105(a) of this Part and the 

recordkeeping and reporting requirements specified in Section 218.211(d) of this Subpart: 

a) No owner or operator of a coating line subject to only one of the limitations from 

among Section 218.204(a)(1), (a)(4), (c), (d), (e), (f), or (i), or, prior to May 1, 

2011, (c) of this Subpart shall apply coatings on any such coating line, during any 

day, whose daily-weighted average VOM content exceeds the emission limitation 

to which the coatings are subject. 

b) No owner or operator of a miscellaneous metal parts and products coating line 

subject to the limitations of Section 218.204(j) of this Subpart shall apply coatings 

to miscellaneous metal parts or products on the subject coating line unless the 

requirements in subsection (b)(1) or (b)(2) of this Section are met. 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(j) during the same day (e.g., all coatings used on the line are 

subject to 0.42 kg/l ([3.5 lbs/gal))]), the daily-weighted average VOM 
 ILLINOIS REGISTER 5361

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content shall not exceed the coating VOM content limit corresponding to 

the category of coating used, or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(j) of this Subpart, during 

the same day, the owner or operator shall have a site-specific proposal 

approved by the Agency and approved by the USEPA as a SIP revision. 

To receive approval, the requirements of USEPA's Emissions Trading 

Policy Statement (and related policy) 51 Fed. Reg. 43814 (December 4, 

1986), must be satisfied. 

c) No owner or operator of a can coating line subject to the limitations of Section 

218.204(b) of this Subpart shall operate the subject coating line using a coating 

with a VOM content in excess of the limitations specified in Section 218.204(b) 

of this Subpart unless all of the following requirements are met: 

1) An alternative daily emission limitation shall be determined for the can 

coating operation, i.e., for all of the can coating lines at the source, 

according to subsection (c)(2) of this Section. Actual daily emissions shall 

never exceed the alternative daily emission limitation and shall be 

calculated by use of the following equation. 

i

n

i

Ed ViC  1

where: 

Ed = Actual VOM emissions for the day in units of kg/day 

(lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied in the can coating 

operation, i.e., all can coating lines at the source; 

Vi = Volume of each coating applied for the day in units of 

l/day (gal/day) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 
 ILLINOIS REGISTER 5362

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POLLUTION CONTROL BOARD 

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Ci = The VOM content of each coating as applied in units of 

kg VOM/l (lbs VOM/gal) of coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM). 

2) The alternative daily emission limitation (Ad) shall be determined for the 

can coating operation, i.e., for all of the can coating lines at the source, on 

a daily basis as follows: 



















   i i

i i

i

n

i

d i D L

D C A V L

1

where: 

Ad = The VOM emissions allowed for the day in units of 

kg/day (lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of surface coatings applied in the can 

coating operation; 

Ci = The VOM content of each surface coating as applied in 

units of kg VOM/l (lbs VOM/gal) of coating (minus 

water and any compounds which are specifically 

exempted from the definition of VOM); 

Di = The density of VOM in each coating applied. For the 

purposes of calculating Ad, the density is 0.882 kg 

VOM/l VOM (7.36 lbs VOM/gal VOM); 

Vi = Volume of each surface coating applied for the day in 

units of l (gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 

Li = The VOM emission limitation for each surface coating 

applied as specified in Section 218.204(b) of this Subpart 

in units of kg VOM/l (lbs VOM/gal) of coating (minus 

water and any compounds which are specifically 

exempted from the definition of VOM). 
 ILLINOIS REGISTER 5363

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d) No owner or operator of a heavy off-highway vehicle products coating line 

subject to the limitations of Section 218.204(k) of this Subpart shall apply 

coatings to heavy off-highway vehicle products on the subject coating line unless 

the requirements of subsection (d)(1) or (d)(2) of this Section are met. 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(k) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.42 kg/l (3.5 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(k) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) 51 Fed. Reg. 43814 

(December 4, 1986), must be satisfied. 

e) No owner or operator of a wood furniture coating line subject to the limitations of 

Section 218.204(l)(1) or (l)(3) of this Subpart shall apply coatings to wood 

furniture on the subject coating line unless the requirements of subsection (e)(1) 

or subsection (e)(2) of this Section, in addition to the requirements specified in the 

note to Section 218.204(l)(1) of this Subpart, are met. 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(l)(1) or (l)(3) of this Subpart, during the same day (e.g., all 

coatings used on the line are subject to 0.67 kg/l (5.6 lbs/gal)), the dailyweighted average VOM content shall not exceed the coating VOM content 

limit corresponding to the category of coating used, or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(l)(1) or (l)(3) of this 

Subpart, during the same day, the owner or operator shall have a site 

specific proposal approved by the Agency and approved by the USEPA as 

a SIP revision. To receive approval, the requirements of USEPA's 

Emissions Trading Policy Statement (and related policy) 51 Fed. Reg. 
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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

43814 (December 4, 1986), must be satisfied. 

f) No owner or operator of an existing diesel-electric locomotive coating line in 

Cook County, subject to the limitations of Section 218.204(m) of this Subpart 

shall apply coatings to diesel-electric locomotives on the subject coating line 

unless the requirements of subsection (f)(1) or (f)(2) of this Section are met. 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(m) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.42 kg/l (3.5 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(m) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) must be satisfied. 

g) No owner or operator of a plastic parts coating line, subject to the limitations of 

Section 218.204(n) or (o) of this Subpart shall apply coatings to business machine 

or automotive/transportation plastic parts on the subject coating line unless the 

requirements of subsection (g)(1) or (g)(2) of this Section are met: 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(n) or (o) of this Subpart, during the same day (e.g., all coatings 

used on the line are subject to 0.42 kg/l (3.5 lbs/gal)), the daily-weighted 

average VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used; or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(n) or (o) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) must be satisfied. 
 ILLINOIS REGISTER 5365

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

h) No owner or operator of a metal furniture coating line, subject to the limitations 

of Section 218.204(g) of this Subpart shall apply coatings on the subject coating 

line unless the requirements of subsection (h)(1) or (h)(2) of this Section are met: 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(g) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.34 kg/l (2.8 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used; or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(g) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) must be satisfied. 

i) No owner or operator of a large appliance coating line, subject to the limitations 

of Section 218.204(h) of this Subpart shall apply coatings on the subject coating 

line unless the requirements of subsection (i)(1) or (i)(2) of this Section are met: 

1) For each coating line which applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(h) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.34 kg/l (2.8 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line which applies coatings subject to more than one 

numerical emission limitation in Section 218.204(h) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) must be satisfied. 

j) On and after May 1, 2011, no owner or operator of a paper coating line subject to 

the limitations of Section 218.204(c) of this Subpart shall apply coatings on the 
 ILLINOIS REGISTER 5366

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NOTICE OF ADOPTED AMENDMENTS 

subject coating line unless the requirements in subsection (j)(1) or (j)(2) of this 

Section are met:

1) For each coating line that applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

218.204(c) during the same day (e.g., all coatings used on the line are 

subject to 0.40 kg/kg solids (0.08 kg/kg coatings)), the daily-weighted 

average VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used; or

2) For each coating line that applies coatings subject to more than one 

numerical emission limitation in Section 218.204(c) during the same day, 

the owner or operator shall have a site-specific proposal approved by the 

Agency and approved by USEPA as a SIP revision. To receive approval, 

the requirements of USEPA's Emissions Trading Policy Statement (and 

related policy), 51 Fed. Reg. 43814 (December 4, 1986), must be satisfied.

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.207 Alternative Emission Limitations 

a) Any owner or operator of a coating line subject to Section 218.204 of this Subpart 

may comply with this Section, rather than with Section 218.204 of this Subpart, if 

a capture system and control device are operated at all times the coating line is in 

operation and the owner or operator demonstrates compliance with subsections 

(c), (d), (e), (f), (g), (h), (i), (j), or (k), or (l) of this Section (depending upon the 

source category) through the applicable coating analysis and capture system and 

control device efficiency test methods and procedures specified in Section 

218.105 of this Part and the recordkeeping and reporting requirements specified in 

Section 218.211(e) of this Subpart; and the control device is equipped with the 

applicable monitoring equipment specified in Section 218.105(d) of this Part and 

the monitoring equipment is installed, calibrated, operated and maintained 

according to vendor specifications at all times the control device is in use. A 

capture system and control device, which does not demonstrate compliance with 

subsection (c), (d), (e), (f), (g), (h), (i), (j), or (k), or (l) of this Section may be 

used as an alternative to compliance with Section 218.204 of this Subpart only if 

the alternative is approved by the Agency and approved by the USEPA as a SIP 

revision. 
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b) Alternative Add-On Control Methodologies 

1) The coating line is equipped with a capture system and control device that 

provides 81 percent reduction in the overall emissions of VOM from the 

coating line and the control device has a 90 percent efficiency, or 

2) The system used to control VOM from the coating line is demonstrated to 

have an overall efficiency sufficient to limit VOM emissions to no more 

than what is allowed under Section 218.204 of this Subpart. Use of any 

control system other than an afterburner, carbon adsorption, condensation, 

or absorption scrubber system can be allowed only if approved by the 

Agency and approved by the USEPA as a SIP revision. The use of transfer 

efficiency credits can be allowed only if approved by the Agency and 

approved by the USEPA as a SIP revision. Baseline transfer efficiencies 

and transfer efficiency test methods must be approved by the Agency and 

the USEPA. Such overall efficiency is to be determined as follows: 

A) Obtain the emission limitation from the appropriate subsection in 

Section 218.204 of this Subpart; 

B) Calculate "S" according to the equation in Section 218.206 of this 

Subpart; 

C) Calculate the overall efficiency required according to Section 

218.105(e) of this Part. For the purposes of calculating this value, 

according to the equation in Section 218.105(e)(2) of this Part, 

VOMl is equal to the value of "S" as determined above in 

subsection (b)(2)(B) of this Section. 

c) No owner or operator of a coating line subject to only one of the emission 

limitations from among Section 218.204(a)(1), (a)(4), (c), (d), (e), (f), or (i), or, 

prior to May 1, 2011, (c) of this Subpart and equipped with a capture system and 

control device shall operate the subject coating line unless the requirements in 

subsection (b)(1) or (b)(2) of this Section are met. No owner or operator of a 

coating line subject to Section 218.204(a)(2) or 218.204(a)(3) and equipped with 

a capture system and control device shall operate the coating line unless the 

owner or operator demonstrates compliance with such limitation in accordance 

with the topcoat protocol referenced in Section 218.105(b). 
 ILLINOIS REGISTER 5368

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NOTICE OF ADOPTED AMENDMENTS 

d) No owner or operator of a miscellaneous metal parts and products coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 218.204(j) of 

this Subpart (e.g., all coatings used on the line are subject to 0.42 kg/l [3.5 

lbs/gal], and thatwhich is equipped with a capture system and control device shall 

operate the subject coating line unless the requirements in subsection (b)(1) or 

(b)(2) of this Section are met. 

e) No owner or operator of a heavy off-highway vehicle products coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 218.204(k) of 

this Subpart (e.g., all coatings used on the line are subject to 0.42 kg/1 [3.5 

lbs/gal]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

f) No owner or operator of an existing diesel-electric locomotive coating line in 

Cook County thatwhich applies one or more coatings during the same day, all of 

which are subject to the same numerical emission limitation within Section 

218.204(m) of this Subpart (e.g., all coatings used on the line are subject to 0.42 

kg/1 [3.5 lbs/gal]), and thatwhich is equipped with a capture system and control 

device shall operate the subject coating line unless the requirements in subsection 

(b)(1) or (b)(2) of this Section are met. 

g) No owner or operator of a wood furniture coating line thatwhich applies one or 

more coatings during the same day, all of which are subject to the same numerical 

emission limitation within Section 218.204(l) of this Subpart (e.g., all coatings 

used on the line are subject to 0.67 kg/l [5.6 lbs/gal]), and thatwhich is equipped 

with a capture system and control device shall operate the subject coating line 

unless the requirements in subsection (b)(1) or (b)(2) of this Section are met. If 

compliance is achieved by meeting the requirements in subsection (b)(2) of this 

Section, then the provisions in the note to Section 218.204(l) of this Subpart must 

also be met. 

h) No owner or operator of a can coating line thatwhich is equipped with a capture 

system and control device shall operate the subject coating line unless the 

requirements in subsection (h)(1) or (h)(2) of this Section are met. 

1) An alternative daily emission limitation shall be determined for the can 
 ILLINOIS REGISTER 5369

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

coating operation, i.e., for all of the can coating lines at the source, 

according to Section 218.205(c)(2) of this Subpart. Actual daily emissions 

shall never exceed the alternative daily emission limitation and shall be 

calculated by use of the following equation: 

  i i

n

i

Ed  ViC  F 1

1

where: 

Ed = Actual VOM emissions for the day in units of kg/day 

(lbs/day); 

i = Subscript denoting the specific coating applied; 

n = Total number of surface coatings as applied in the can 

coating operation; 

Vi = Volume of each coating as applied for the day in units of 

l/day (gal/day) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 

Ci = The VOM content of each coating as applied in units of 

kg VOM/l (lbs VOM/gal) of coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) and 

Fi = Fraction, by weight, of VOM emissions from the surface 

coating, reduced or prevented from being emitted to the 

ambient air. This is the overall efficiency of the capture 

system and control device. 

2) The coating line is equipped with a capture system and control device that 

provide 75 percent reduction in the overall emissions of VOM from the 

coating line and the control device has a 90 percent efficiency. 

i) No owner or operator of a plastic parts coating line, thatwhich applies one or 

more coatings during the same day, all of which are subject to the same numerical 

emission limitation within Section 218.204(n) or (o) of this Subpart (e.g., all 
 ILLINOIS REGISTER 5370

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NOTICE OF ADOPTED AMENDMENTS 

coatings used on the line are subject to 0.42 kg/l ([3.5 lbs/gal)]), and thatwhich is 

equipped with a capture system and control device shall operate the subject 

coating line unless the requirements in subsection (b)(1) or (b)(2) of this Section 

are met. 

j) Prior to May 1, 2011, noNo owner or operator of a metal furniture coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 218.204(g) of 

this Subpart (e.g., all coatings used on the line are subject to 0.34 kg/l ([2.8 

lbs/gal)]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

k) Prior to May 1, 2011, noNo owner or operator of a large appliance coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 218.204(h) of 

this Subpart (e.g., all coatings used on the line are subject to 0.34 kg/l ([2.8 

lbs/gal)]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

l) On and after May 1, 2011, no owner or operator of a paper coating line, metal 

furniture coating line, or large appliance coating line that is equipped with a 

capture system and control device shall operate the subject coating line unless 

either:

1) The capture system and control device provide at least 90 percent 

reduction in the overall emissions of VOM from the coating line; or

2) The owner or operator complies with the applicable limitation set forth in 

Section 218.204 of this Subpart by utilizing a combination of low-VOM 

coatings and a capture system and control device.

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.210 Compliance Schedule 

Every owner or operator of a coating line (of a type included within Section 218.204 of this 

Subpart) shall comply with the requirements of Section 218.204, 218.205, 218.207 or 218.208 
 ILLINOIS REGISTER 5371

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NOTICE OF ADOPTED AMENDMENTS 

and Section 218.211 or Sections 218.212 and 218.213 of this Subpart in accordance with the 

appropriate compliance schedule as specified in subsection (a), (b), (c), (d), (e), or (f), or (g) of 

this Sectionbelow: 

a) No owner or operator of a coating line thatwhich is exempt from the limitations of 

Section 218.204 of this Subpart because of the criteria in Section 218.208(a) or 

(b) of this Subpart shall operate said coating line on or after a date consistent with 

Section 218.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Section 218.211(b) of this Subpart. 

b) No owner or operator of a coating line complying by means of Section 218.204 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 218.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 218.204 and 218.211(c) of this Subpart. 

c) No owner or operator of a coating line complying by means of Section 218.205 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 218.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 218.205 and 218.211(d) of this Subpart. 

d) No owner or operator of a coating line complying by means of Section 218.207 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 218.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 218.207 and 218.211(e) of this Subpart. 

e) No owner or operator of a coating line subject to one or more of the emission 

limitations contained in Section 218.204 of this Subpart on or after March 15, 

1996, choosing to comply by means of Section 218.204, 218.205 or 218.207 of 

this Subpart, shall operate said coating line on or after March 15, 1996, unless the 

owner or operator complies with and continues to comply with, respectively, the 

applicable requirements in Section 218.204, or the alternative control options in 

Section 218.205 or 218.207 and the requirements of Section 218.211. 

f) No owner or operator of a coating line subject to one or more of the emission 

limitations contained in Section 218.204 of this Subpart on or after March 15, 

1996, choosing to comply by means of Section 218.212 of this Subpart, shall 

operate said coating line on or after March 15, 1996, unless the owner or operator 

complies with and continues to comply with the requirements of Sections 218.212 

and 218.213 of this Subpart. 
 ILLINOIS REGISTER 5372

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NOTICE OF ADOPTED AMENDMENTS 

g) No owner or operator of a coating line subject to the emission limitations in 

Section 218.204(c)(2), 218.204(g)(2), or 218.204(h)(2) of this Subpart shall 

operate that coating line on or after a date consistent with Section 218.106(e) of 

this Part, unless the owner or operator has complied with, and continues to 

comply with, Section 218.204(c)(2), 218.204(g)(2), or 218.204(h)(2), as 

applicable, or the alternative control options in Section 218.205 or 218.207, and 

all applicable requirements in Sections 218.211 and 218.218 of this Subpart.

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.211 Recordkeeping and Reporting 

a) The VOM content of each coating and the efficiency of each capture system and 

control device shall be determined by the applicable test methods and procedures 

specified in Section 218.105 of this Part to establish the records required under 

this Section. 

b) Any owner or operator of a coating line thatwhich is exempted from the 

limitations of Section 218.204 of this Subpart because of Section 218.208(a) or 

(b) of this Subpart shall comply with the following: 

1) For sources exempt under Section 218.208(a) of this Subpart, by a date 

consistent with Section 218.106 of this Part, the owner or operator of a 

coating line or a group of coating lines referenced in subsection (b) of this 

Section shall certify to the Agency that the coating line or group of coating 

lines is exempt under the provisions of Section 218.208(a) of this Subpart. 

Such certification shall include: 

A) A declaration that the coating line or group of coating lines is 

exempt from the limitations of Section 218.204 of this Subpart 

because of Section 218.208(a) of this Subpart; and 

B) Calculations thatwhich demonstrate that the combined VOM 

emissions from the coating lines or group of coating lines never 

exceed 6.8 kg (15 lbs) per day before the application of capture 

systems and control devices. The following equation shall be used 

to calculate total VOM emissions: 
 ILLINOIS REGISTER 5373

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NOTICE OF ADOPTED AMENDMENTS 

   



m

j

n

i

e AiBi j T

1 1

where: 

Te = Total VOM emissions from coating lines each day before 

the application of capture systems and control devices in 

units of kg/day (lbs/day); 

m = Number of coating lines at the source that otherwise 

would be subject to the same subsection of Section 

218.104 of this Part (because they belong to the same 

category, e.g., can coating); 

j = Subscript denoting an individual coating line; 

n = Number of different coatings as applied each day on each 

coating line; 

i = Subscript denoting an individual coating; 

Ai = Weight of VOM per volume of each coating (minus water 

and any compounds thatwhich are specifically exempted 

from the definition of VOM) as applied each day on each 

coating line in units of kg VOM/l (lbs VOM/gal); and 

Bi = Volume of each coating (minus water and any 

compounds thatwhich are specifically exempted from the 

definition of VOM) as applied each day on each coating 

line in units of l/day (gal/day). The instrument or method 

by which the owner or operator accurately measured or 

calculated the volume of each coating as applied on each 

coating line each day shall be described in the 

certification to the Agency. 

2) For sources exempt under Section 218.208(b) of this Subpart, by March 

15, 1998, or upon initial start-up, the owner or operator of a coating line or 

a group of coating lines referenced in subsection (b) of this Section shall 

certify to the Agency that the source is exempt under the provisions of 

Section 218.208(b) of this Subpart. Such certification shall include: 
 ILLINOIS REGISTER 5374

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

A) A declaration that the source is exempt from the limitations of 

Section 218.204(l) of this Subpart because of Section 218.208(b) 

of this Subpart; and 

B) Calculations which demonstrate that the source meets the criteria 

for exemption because of Section 218.208(b) of this Subpart. 

3) For sources exempt under Section 218.208(a) of this Subpart, on and after 

a date consistent with Section 218.106 of this Part, the owner or operator 

of a coating line or group of coating lines referenced in this subsection 

shall collect and record all of the following information each day for each 

coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line; and 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

4) For sources exempt under Section 218.208(b) of this Subpart, on and after 

March 15, 1998, the owner or operator of a coating line or group of 

coating lines referenced in this subsection (b) shall collect and record all 

of the following information for each coating line and maintain the 

information at the source for a period of three years: 

A) The name and identification number of each coating as applied on 

each coating line; and 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied on each coating line on a 

monthly basis. 

5) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a coating line or group of coating lines exempted from the 

limitations of Section 218.204 of this Subpart because of Section 
 ILLINOIS REGISTER 5375

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NOTICE OF ADOPTED AMENDMENTS 

218.208(a) of this Subpart shall notify the Agency of any record showing 

that total VOM emissions from the coating line or group of coating lines 

exceed 6.8 kg (15 lbs) in any day before the application of capture systems 

and control devices by sending a copy of such record to the Agency within 

30 days after the exceedance occurs. 

6) On and after March 15, 1998, any owner or operator of a source exempt 

from the limitations of Section 218.204(l) of this Subpart because of 

Section 218.208(b) of this Subpart shall notify the Agency if the source's 

VOM emissions exceed the limitations of Section 218.208(b) of this 

Subpart by sending a copy of calculations showing such an exceedance 

within 30 days after the change occurs. 

c) Any owner or operator of a coating line subject to the limitations of Section 

218.204 of this Subpart other than Section 218.204(a)(2) or (a)(3) of this Subpart 

and complying by means of Section 218.204 of this Subpart shall comply with the 

following: 

1) By a date consistent with Section 218.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance from 

an existing subject coating line from Section 218.205, Section 218.207, 

Section 218.215, or Section 218.216 of this Subpart to Section 218.204 of 

this Subpart; the owner or operator of a subject coating line shall certify to 

the Agency that the coating line will be in compliance with Section 

218.204 of this Subpart on and after a date consistent with Section 

218.106 of this Part, or on and after the initial start-up date. TheSuch

certification shall include: 

A) The name and identification number of each coating as applied on 

each coating line; 

B) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line; and 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 218.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line;. 
 ILLINOIS REGISTER 5376

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NOTICE OF ADOPTED AMENDMENTS 

D) For coating lines subject to the limitations of Section 218.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line; and

E) For coating lines subject to the limitations of Section 218.204(g)(2) 

or 218.204(h)(2) of this Subpart, the application methods used to 

apply coatings on the subject coating line and the weight of VOM 

per volume of each coating (or the weight of VOM per volume of 

solids in each coating, as applicable) as applied each day on each 

coating line. 

2) On and after a date consistent with Section 218.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 

each coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line; 

B) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line; 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 218.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line and certified product data sheets for 

each coating; and 

D) On and after March 15, 1998, for wood furniture coating spray 

booths subject to the limitations of Section 218.204(l)(4)(A) of this 

Subpart, the weight of VOM per weight of solids in each strippable 

spray booth coating as applied each day on each spray booth and 

certified product data sheets for each coating;. 
 ILLINOIS REGISTER 5377

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E) For coating lines subject to the limitations of Section 218.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line, and certified 

product data sheets for each coating; and

F) For coating lines subject to the limitations of Section 218.204(g)(2) 

or 218.204(h)(2) of this Subpart, the weight of VOM per volume 

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line, and certified product data sheets for each coating.

3) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 218.204 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance from Section 218.204 of this Subpart to Section 

218.205 or Section 218.207 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (d)(1) or (e)(1) of 

this Section below, respectively. Upon changing the method of 

compliance from Section 218.204 of this Subpart to Section 

218.205 of this Subpart or Section 218.207 of this Subpart, the 

owner or operator shall comply with all requirements of subsection 

(d) or (e) of this Section, respectively. 

d) Any owner or operator of a coating line subject to the limitations of Section 

218.204 of this Subpart and complying by means of Section 218.205 of this 

Subpart shall comply with the following: 

1) By a date consistent with Section 218.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance for 

an existing subject coating line from Section 218.204 or Section 218.207 

of this Subpart to Section 218.205 of this Subpart; the owner or operator 

of the subject coating line shall certify to the Agency that the coating line 
 ILLINOIS REGISTER 5378

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NOTICE OF ADOPTED AMENDMENTS 

will be in compliance with Section 218.205 of this Subpart on and after a 

date consistent with Section 218.106 of this Part, or on and after the initial 

start-up date. TheSuch certification shall include: 

A) The name and identification number of each coating line which 

will comply by means of Section 218.205 of this Subpart. 

B) The name and identification number of each coating as applied on 

each coating line. 

C) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

D) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 218.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line. 

E) For coating lines subject to the limitations of Section 218.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line.

F) For coating lines subject to the limitations of Section 218.204(g)(2) 

or 218.204(h)(2) of this Subpart, the weight of VOM per volume 

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line.

GE) The instrument or method by which the owner or operator will 

accurately measure or calculate the volume of each coating as 

applied each day on each coating line. 

HF) The method by which the owner or operator will create and 

maintain records each day as required in subsection (d)(2) of this 

Section. 
 ILLINOIS REGISTER 5379

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IG) An example of the format in which the records required in 

subsection (d)(2) of this Section will be kept. 

2) On and after a date consistent with Section 218.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 

each coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line. 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 218.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line. 

D) For coating lines subject to the limitations of Section 218.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line.

E) For coating lines subject to the limitations of Section 218.204(g)(2) 

or 218.204(h)(2) of this Subpart, the weight of VOM per volume 

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line.

FD) The daily-weighted average VOM content of all coatings as 

applied on each coating line as defined in Section 218.104 of this 

Part. 

3) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 
 ILLINOIS REGISTER 5380

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NOTICE OF ADOPTED AMENDMENTS 

following instances: 

A) Any record showing violation of Section 218.205 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 218.205 of this Subpart 

to Section 218.204 or Section 218.207 of this Subpart, the owner 

or operator shall comply with all requirements of subsection (c)(1) 

or (e)(1) of this Section, respectively. Upon changing the method 

of compliance with this subpart from Section 218.205 to Section 

218.204 or Section 218.207 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c) or (e) of this 

Section, respectively. 

e) Any owner or operator of a coating line subject to the limitations of Section 

218.207 of this Subpart and complying by means of Section 218.207(c), (d), (e), 

(f), (g), or (h), or (l) of this Subpart shall comply with the following: 

1) By a date consistent with Section 218.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance for 

an existing coating line from Section 218.204 or Section 218.205 of this 

Subpart to Section 218.207 of this Subpart, the owner or operator of the 

subject coating line shall perform all tests and submit to the Agency the 

results of all tests and calculations necessary to demonstrate that the 

subject coating line will be in compliance with Section 218.207 of this 

Subpart on and after a date consistent with Section 218.106 of this Part, or 

on and after the initial start-up date. 

2) On and after a date consistent with Section 218.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 

each coating line and maintain the information at the source for a period of 

three years: 

A) The weight of VOM per volume of coating solids as applied each 

day on each coating line, if complying pursuant to Section 

218.207(b)(2) of this Subpart. 
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B) Control device monitoring data. 

C) A log of operating time for the capture system, control device, 

monitoring equipment and the associated coating line. 

D) A maintenance log for the capture system, control device and 

monitoring equipment detailing all routine and non-routine 

maintenance performed including dates and duration of any 

outages. 

3) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 218.207 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 218.207 of this Subpart 

to Section 218.204 or Section 218.205 of this Subpart, the owner 

or operator shall comply with all requirements of subsection (c)(1) 

or (d)(1) of this Section, respectively. Upon changing the method 

of compliance with this subpart from Section 218.207 of this 

Subpart to Section 218.204 or Section 218.205 of this Subpart, the 

owner or operator shall comply with all requirements of subsection 

(c) or (d) of this Section, respectively. 

f) Any owner or operator of a primer surfacer operation or topcoat operation subject 

to the limitations of Section 218.204(a)(2) or (a)(3) of this Subpart shall comply 

with the following: 

1) By a date consistent with Section 218.106 of this Part, or upon initial startup of a new coating operation, the owner or operator of a subject coating 

operation shall certify to the Agency that the operation will be in 

compliance with Section 218.204 of this Subpart on and after a date 

consistent with Section 218.106 of this Part, or on and after the initial 

start-up date. TheSuch certification shall include: 
 ILLINOIS REGISTER 5382

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NOTICE OF ADOPTED AMENDMENTS 

A) The name and identification number of each coating operation 

which will comply by means of Section 218.204(a)(2) and (a)(3) of 

this Subpart and the name and identification number of each 

coating line in each coating operation. 

B) The name and identification number of each coating as applied on 

each coating line in the coating operation. 

C) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line. 

D) The transfer efficiency and control efficiency measured for each 

coating line. 

E) Test reports, including raw data and calculations documenting the 

testing performed to measure transfer efficiency and control 

efficiency. 

F) The instrument or method by which the owner or operator will 

accurately measure or calculate the volume of each coating as 

applied each day on each coating line. 

G) The method by which the owner or operator will create and 

maintain records each day as required in subsection (f)(2) of this 

Sectionbelow. 

H) An example format for presenting the records required in 

subsection (f)(2) of this Sectionbelow. 

2) On and after a date consistent with Section 218.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

operation shall collect and record all of the following information each 

day for each operation and maintain the information at the source for a 

period of three years: 

A) All information necessary to calculate the daily-weighted average 

VOM emissions from the coating operations in kg (lbs) per 1 (gal) 
 ILLINOIS REGISTER 5383

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NOTICE OF ADOPTED AMENDMENTS 

of coating solids deposited in accordance with the proposal 

submitted, and approved pursuant to Section 218.204(a)(2) or 

(a)(3) of this Subpart including: 

i) The name and identification number of each coating as 

applied on each coating operation. 

ii) The weight of VOM per volume of each coating (minus 

water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each 

coating operation. 

B) If a control device or devices aredevice(s) is used to control VOM 

emissions, control device monitoring data; a log of operating time 

for the capture system, control device, monitoring equipment and 

the associated coating operation; and a maintenance log for the 

capture system, control device and monitoring equipment, 

detailing all routine and non-routine maintenance performed 

including dates and duration of any outages. 

3) On and after a date consistent with Section 218.106 of this Part or on and 

after the initial start-up date, the owner or operator of a subject coating 

operation shall determine and record the daily VOM emissions in kg (lbs) 

per 1 (gal) of coating solids deposited in accordance with the proposal 

submitted and approved pursuant to Section 218.204(a)(2) or (a)(3) of this 

Subpart within 10 days from the end of the month and maintain this 

information at the source for a period of three years. 

4) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a subject coating operation shall notify the Agency in the 

following instances: 

A) Any record showing a violation of Section 218.204(a)(2) or (a)(3) 

of this Subpart shall be reported by sending a copy of such record 

to the Agency within 15 days from the end of the month in which 

the violation occurred. 

B) The owner or operator shall notify the Agency of any change to the 

operation at least 30 days before the change is effected. The 
 ILLINOIS REGISTER 5384

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

Agency shall determine whether or not compliance testing is 

required. If the Agency determines that compliance testing is 

required, then the owner or operator shall submit a testing proposal 

to the Agency within 30 days and test within 30 days of the 

approval of the proposal by the Agency and USEPA. 

g) On and after a date consistent with Section 218.106(e) of this Part, or on and after 

the initial startup date, whichever is later, the owner or operator of a coating line 

subject to the requirements of Section 218.218 of this Subpart shall comply with 

the following:

1) By May 1, 2011, or upon initial startup, whichever is later, submit a 

certification to the Agency that includes a description of the practices and 

procedures that the source will follow to ensure compliance with the 

applicable requirements in Section 218.218 of this Subpart;

2) Notify the Agency of any violation of Section 218.218 of this Subpart by 

providing a description of the violation and copies of records documenting 

the violation to the Agency within 30 days following the occurrence of the 

violation; and

3) Maintain at the source all records required by this subsection (g) for a 

minimum of three years from the date the document was created and make 

those records available to the Agency upon request.

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.212 Cross-Line Averaging to Establish Compliance for Coating Lines 

a) On and after March 15, 1996, any owner or operator of a coating line subject to 

the limitations set forth in Section 218.204 of this Subpart, except coating lines 

subject to the limitations in Section 218.204(c)(2), (g)(2), or (h)(2) of this 

Subpart, and with coating lines in operation prior to January 1, 1991 ("preexisting coating lines"), may, for pre-existing coating lines only, elect to comply 

with the requirements of this Section, rather than complying with the applicable 

emission limitations set forth in Section 218.204, if an operational change of the 

type described below has been made after January 1, 1991, to one or more preexisting coating lines at the source. An operational change occurs when a preexisting coating line is replaced with a line using lower VOM coating for the 
 ILLINOIS REGISTER 5385

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same purpose as the replaced line ("replacement line"). A source electing to rely 

on this Section to demonstrate compliance with the requirements of this Subpart 

shall operate pursuant to federally enforceable permit conditions approved by the 

Agency and USEPA. 

b) An owner or operator of pre-existing coating lines subject to a VOM content 

limitation in Section 218.204 of this Subpart and electing to rely on this Section to 

demonstrate compliance with this Subpart must establish, by use of the equations 

in subsection (d) of this Section, that the calculated actual daily VOM emissions 

from all participating coating lines, as defined below, are less than the calculated 

daily allowable VOM emissions from the same group of coating lines. For any 

pre-existing coating line to be aggregated for the purposes of Section 218.212, 

218.213, or 218.214 of this Subpart ("participating coating lines"), the source 

must establish that: 

1) All coatings applied on the participating coating line shall, at all times, 

have a VOM content less than or equal to the applicable VOM content 

limitation for such coating listed in Appendix H of this Part; and 

2) On the date the source elects to rely on this Section to demonstrate 

compliance with this Subpart, all coatings applied on the participating 

coating line are not already in compliance with the VOM content 

limitation for such coating effective on or after March 15, 1996; or the 

participating coating line is a replacement line, as defined in subsection (a) 

of this Section with an operational change occurring on or after January 1, 

1991. 

c) Notwithstanding subsection (a) of this Section, any owner or operator of a coating 

line subject to the limitations set forth in Section 218.204 of this Subpart and 

electing to rely on this Section to demonstrate compliance with this Subpart, may 

also include as a participating coating line, until December 31, 1999, only, any 

replacement line that satisfies all of the following conditions: 

1) The replacement line is operated as a powder coating line; 

2) The replacement line was added after July 1, 1988; and 

3) The owner or operator also includes as a participating coating line one or 

more coating lines that satisfy the criteria of a replacement line, as 
 ILLINOIS REGISTER 5386

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described in subsection (a) of this Section. 

d) To demonstrate compliance with this Section, a source shall establish the 

following: 

1) An alternative daily emission limitation shall be determined for all 

participating coating lines at the source according to subsection (d)(2) of 

this Section. All participating coating lines shall be factored in each day 

to demonstrate compliance. Provided compliance is established pursuant 

to the requirements in this subsection, nothing in this Section requires 

daily operation of each participating line. Actual daily emissions from all 

participating coating lines (Ed) shall never exceed the alternative daily 

emission limitation (Ad) and shall be calculated by use of the following 

equation: 

i

n

i

Ed ViC  1

where: 

Ed = Actual daily VOM emissions from participating coating 

lines in units of kg/day (lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied by all participating 

coating lines at the source; 

Vi = Volume of each coating applied for the day in units of 

l/day (gal/day) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); and 

Ci = The VOM content of each coating as applied in units of 

kg VOM/l (lbs VOM/gal) of coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM). 

2) The alternative daily emission limitation (Ad) shall be determined for all 

participating coating lines at the source on a daily basis as follows: 
 ILLINOIS REGISTER 5387

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NOTICE OF ADOPTED AMENDMENTS 

Ad  Ai  Ap

where Ai and Ap are defined in subsections (d)(2)(A) and (d)(2)(B) of this 

Section. 

A) The portion of the alternative daily emissions limitation for coating 

operations at a source using non-powder coating (Al) shall be 

determined for all such participating non-powder coating lines on a 

daily basis as follows: 



















   i i

i i

i

n

i

i i D L

D C A V L

1

where: 

Ai = The VOM emissions allowed for the day in units of kg/day 

(lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied in the participating 

coating lines; 

Ci = The VOM content of each coating as applied in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 

Di = The density of VOM in each coating applied. For the 

purposes of calculating Al, the density is 0.882 kg VOM/l 

VOM (7.36 lbs VOM/gal VOM); 

Vi = Volume of each coating applied for the day in units of l 

(gal) of coating (minus water and any compounds which 

are specifically exempted from the definition of VOM); 

and 
 ILLINOIS REGISTER 5388

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Li = The VOM emission limitation for each coating applied, as 

specified in Section 218.204 of this Subpart, in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM). 

B) The portion of the alternative daily emission limitation for coating 

operations at a source using powdered coating (Ap) shall be 

determined for all such participating powder coating lines at the 

source on a daily basis as follows: 

     

m

h

n

j j j

j j j h

p D L

V L D K

A

1 1

where: 

Ap = The VOM emissions allowed for the day in units of 

kg/day (lbs/day); 

h = Subscript denoting a specific powder coating line; 

j = Subscript denoting a specific powder coating applied; 

m = Total number of participating powder coating lines; 

n = Total number of powder coatings applied in the 

participating coating lines; 

Dj = The assumed density of VOM in liquid coating, 0.882 kg 

VOM/l VOM (7.36 lbs VOM/gal VOM); 

Vj = Volume of each powder coating consumed for the day in 

units of l (gal) of coating; and 

Lj = The VOM emission limitation for each coating applied, 

as specified in Section 218.204 of this Subpart, in units of 

kg VOM/l (lbs VOM/gal) of coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM); and 

K = A constant for each individual coating line representing 
 ILLINOIS REGISTER 5389

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NOTICE OF ADOPTED AMENDMENTS 

the ratio of the volume of coating solids consumed on the 

liquid coating system which has been replaced to the 

volume of powder coating consumed on the replacement 

line to accomplish the same coating job. This value shall 

be determined by the source based on tests conducted and 

records maintained pursuant to the requirements of 

Section 218.213 of this Subpart demonstrating the 

amount of coating solids consumed as both liquid 

powder. Test methods and recordkeeping requirements 

shall be approved by the Agency and USEPA and shall 

be contained in the source's operating permit as federally 

enforceable permit conditions, subject to the following 

restrictions: 

i) K cannot exceed 0.9 for non-recycled powder 

coating systems; or 

ii) K cannot exceed 2.0 for recycled powder coating 

systems. 

(Source: Amended at 34 Ill. Reg. 5330, effective March 23, 2010) 

Section 218.218 Work Practice Standards for Paper Coatings, Metal Furniture Coatings, 

and Large Appliance Coatings

a) On and after May 1, 2011, every owner or operator of a source subject to the 

requirements of Section 218.204(c) of this Subpart shall:

1) Store all VOM-containing cleaning materials in closed containers;

2) Ensure that mixing and storage containers used for VOM-containing 

materials are kept closed at all times except when depositing or removing 

those materials;

3) Minimize spills of VOM-containing cleaning materials;

4) Convey VOM-containing cleaning materials from one location to another 

in closed containers or pipes; and
 ILLINOIS REGISTER 5390

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5) Minimize VOM emissions from the cleaning of storage, mixing, and 

conveying equipment.

b) On and after May 1, 2011, every owner or operator of a source subject to the 

requirements of Section 218.204(g) or 218.204(h) of this Subpart shall:

1) Store all VOM-containing coatings, thinners, coating-related waste 

materials, cleaning materials, and used shop towels in closed containers; 

2) Ensure that mixing and storage containers used for VOM-containing 

coatings, thinners, coating-related waste materials, and cleaning materials 

are kept closed at all times except when depositing or removing those

materials; 

3) Minimize spills of VOM-containing coatings, thinners, coating-related 

waste materials, and cleaning materials, and clean up spills immediately; 

4) Convey VOM-containing coatings, thinners, coating-related waste 

materials, and cleaning materials from one location to another in closed 

containers or pipes;

5) Minimize VOM emissions from the cleaning of storage, mixing, and 

conveying equipment; and

6) Apply all coatings using one or more of the following application 

methods:

A) Electrostatic spray;

B) High volume low pressure (HVLP) spray;

C) Flow coating. For the purposes of this subsection (b), flow coating 

means a non-atomized technique of applying coating to a substrate 

with a fluid nozzle with no air supplied to the nozzle;

D) Roll coating;

E) Dip coating, including electrodeposition. For purposes of this 

subsection (b), electrodeposition means a water-borne dip coating 
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process in which opposite electrical charges are applied to the 

substrate and the coating. The coating is attracted to the substrate 

due to the electrochemical potential difference that is created;

F) Brush coating, if subject to the requirements of Section 

218.204(h); or

G) Another coating application method capable of achieving a transfer 

efficiency equal to or better than that achieved by HVLP spraying, 

if such method is approved in writing by the Agency.

(Source: Added at 34 Ill. Reg. 5330, effective March 23, 2010) 
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1) Heading of the Part: Organic Material Emission Standards and Limitations for the Metro 

East Area 

2) Code Citation: 35 Ill. Adm. Code 219 

3) Section Numbers: Adopted Action: 

219.106 Amended 

219.204 Amended 

219.205 Amended 

219.207 Amended 

219.210 Amended 

219.211 Amended 

219.212 Amended 

219.218 New 

4) Statutory Authority: Implementing Section 10 and authorized by Sections 27, 28, and 

28.5 of the Environmental Protection Act [415 ILCS 5/10, 27, 28, and 28.5] 

5) Effective Date of Amendments: March 23, 2010 

6) Does this rulemaking contain an automatic repeal date? No 

 

7) Does this rulemaking contain incorporations by reference? No 

8) A copy of the adopted amendments, including any material incorporated by reference, is 

on file in the Board's Chicago office at the James R. Thompson Center, 100 W. 

Randolph, Suite 11-500, and is available there for public inspection. 

9) Notice of Proposal Published in Illinois Register: 33 Ill. Reg. 16460; November 20, 2009 

10) Has JCAR issued a Statement of Objection to these amendments? No 

11) Differences between proposal and final version: In proceeding from its first-notice 

proposal to final adoption in this docket, the Board made changes proposed by the Illinois 

Environmental Protection Agency in a motion to amend its rulemaking proposal. 

In Section 219.204(c), which addresses emission limitations for paper coating operations, 

the Board placed the language of an amended Note regarding applicability of limitations 

in the body of the rule as subsection (c)(3). 
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NOTICE OF ADOPTED AMENDMENTS 

The Board deleted limitations on application methods from Section 219.204(g)(3), which 

addresses emission limitations for metal furniture coating operations, and placed those 

requirements instead in Section 219.218(b)(6), which establishes work practice standards 

for various operations. 

In Section 219.204(g), which addresses emission limitations for metal furniture coating 

operations, the Board placed the language of a proposed Note following subsection 

(g)(2)(H) regarding applicability of limitations in the body of the rules as subsection 

(g)(3). 

The Board struck limitations on application methods from Section 219.204(h)(3), which 

addresses emission limitations for large appliance coating operations, and placed those 

requirements instead in Section 219.218(b)(6), which establishes work practice standards 

for various operations. 

In Section 219.204(h), which addresses emission limitations for large appliance coating 

operations, the Board placed the language of an amended Note following subsection 

(h)(2)(H) regarding applicability of limitations in the body of the rule as subsection 

(h)(3). 

The Board's opinion and order adopting these rules addresses changes made by the Board 

in proceeding from first notice to final adoption. See Reasonably Available Control 

Technology (RACT) for Volatile Organic Material Emissions from Group III Consumer 

& Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 218 and 219, 

R10-10 (March 18, 2010). Copies of the Board's opinions and orders may be requested 

from the Clerk of the Board at the address listed in #8 above or by calling 312/814-3620. 

Please refer to the Board docket number R10-10 in your request. The Board order is also 

available through the Board's Web site (www.ipcb.state.il.us). 

12) Have all the changes agreed upon by the agency and JCAR been made as indicated in the 

agreements letter issued by JCAR? Yes. 

13) Will this rulemaking replace any emergency rulemaking currently in effect? No 

14) Are there any amendments pending on this Part? Yes 

Section Numbers: Proposed Action: Illinois Register Citation: 

219.106 Amend 34 Ill. Reg. 1941; February 5, 2010 
 ILLINOIS REGISTER 5394

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.181 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.187 New 34 Ill. Reg. 1941; February 5, 2010 

219.204 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.205 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.207 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.210 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.211 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.212 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.217 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.401 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.402 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.403 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.404 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.405 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.406 Repeal 34 Ill. Reg. 1941; February 5, 2010 

219.407 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.408 Repeal 34 Ill. Reg. 1941; February 5, 2010 

219.409 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.410 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.411 Amend 34 Ill. Reg. 1941; February 5, 2010 

219.412 New 34 Ill. Reg. 1941; February 5, 2010 

219.413 New 34 Ill. Reg. 1941; February 5, 2010 

219.415 New 34 Ill. Reg. 1941; February 5, 2010 

219.416 New 34 Ill. Reg. 1941; February 5, 2010 

219.417 New 34 Ill. Reg. 1941; February 5, 2010 

 219.105 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.106 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.112 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.204 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.205 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.207 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.208 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.210 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.211 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.212 Amended 34 Ill. Reg. 4475; April 2, 2010 

219.219 New 34 Ill. Reg. 4475; April 2, 2010 

219.890 New 34 Ill. Reg. 4475; April 2, 2010 

219.891 New 34 Ill. Reg. 4475; April 2, 2010 

219.892 New 34 Ill. Reg. 4475; April 2, 2010 
 ILLINOIS REGISTER 5395

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.894 New 34 Ill. Reg. 4475; April 2, 2010 

219.900 New 34 Ill. Reg. 4475; April 2, 2010 

219.901 New 34 Ill. Reg. 4475; April 2, 2010 

219.902 New 34 Ill. Reg. 4475; April 2, 2010 

219.903 New 34 Ill. Reg. 4475; April 2, 2010 

219.904 New 34 Ill. Reg. 4475; April 2, 2010 

15) Summary and Purpose of Amendments: For a more detailed description of this 

rulemaking, please see the Board's March 18, 2010, opinion and order. Reasonably 

Available Control Technology (RACT) for Volatile Organic Material Emissions from 

Group III Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. 

Code 218 and 219, R10-10 (March 18, 2010). The Illinois Environmental Protection 

Agency (Agency) filed this adopted rulemaking as a proposal to meet Illinois' obligation 

to submit a State Implementation Plan addressing requirements under Sections 172 and 

182 of the federal Clean Air Act, 42 U.S.C. § 7401 et seq., for sources of volatile organic 

material (VOM) emissions in areas designated as nonattainment with respect to the ozone 

National Ambient Air Quality Standard. The United States Environmental Protection 

Agency (USEPA) issued Control Techniques Guidelines (CTGs) for the following Group 

III Consumer and Commercial Product Categories: Paper, Film, and Foil Coatings; 

Metal Furniture Coatings; and Large Appliance Coatings. In the CTGs, the USEPA 

recommended control measures that it believes constitute reasonably available control 

technology for those product categories. The Agency proposed to amend Part 219 to 

implement such recommendations for the Metro East nonattainment area, and PCB now 

adopts such regulations. 

16) Information and questions regarding these adopted amendments shall be directed to: 

 Timothy Fox 

Illinois Pollution Control Board 

100 W. Randolph, Ste. 11-500 

Chicago, IL 60601 

312/814-6085 

Copies of the Board's opinions and orders may be requested from the Clerk of the Board 

at the address listed in #8 above or by calling 312/814-3620. Please refer to the Docket 

number R10-10 in your request. The Board order is also available from the Board's Web 

site (www.ipcb.state.il.us). 

 
 ILLINOIS REGISTER 5396

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

The full text of the Adopted Amendments begins on the next page: 
 ILLINOIS REGISTER 5397

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

TITLE 35: ENVIRONMENTAL PROTECTION 

SUBTITLE B: AIR POLLUTION 

CHAPTER I: POLLUTION CONTROL BOARD 

SUBCHAPTER c: EMISSIONS STANDARDS AND LIMITATIONS 

FOR STATIONARY SOURCES 

PART 219 

ORGANIC MATERIAL EMISSION STANDARDS AND LIMITATIONS 

FOR THE METRO EAST AREA 

SUBPART A: GENERAL PROVISIONS 

Section 

219.100 Introduction 

219.101 Savings Clause 

219.102 Abbreviations and Conversion Factors 

219.103 Applicability 

219.104 Definitions 

219.105 Test Methods and Procedures 

219.106 Compliance Dates 

219.107 Operation of Afterburners 

219.108 Exemptions, Variations, and Alternative Means of Control or Compliance 

Determinations 

219.109 Vapor Pressure of Volatile Organic Liquids 

219.110 Vapor Pressure of Organic Material or Solvent 

219.111 Vapor Pressure of Volatile Organic Material 

219.112 Incorporations by Reference 

219.113 Monitoring for Negligibly-Reactive Compounds 

SUBPART B: ORGANIC EMISSIONS FROM STORAGE AND LOADING OPERATIONS 

Section 

219.119 Applicability for VOL 

219.120 Control Requirements for Storage Containers of VOL 

219.121 Storage Containers of VPL 

219.122 Loading Operations 

219.123 Petroleum Liquid Storage Tanks 

219.124 External Floating Roofs 

219.125 Compliance Dates 
 ILLINOIS REGISTER 5398

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.126 Compliance Plan (Repealed) 

219.127 Testing VOL Operations 

219.128 Monitoring VOL Operations 

219.129 Recordkeeping and Reporting for VOL Operations 

SUBPART C: ORGANIC EMISSIONS FROM MISCELLANEOUS EQUIPMENT 

Section 

219.141 Separation Operations 

219.142 Pumps and Compressors 

219.143 Vapor Blowdown 

219.144 Safety Relief Valves 

SUBPART E: SOLVENT CLEANING 

Section 

219.181 Solvent Cleaning in General 

219.182 Cold Cleaning 

219.183 Open Top Vapor Degreasing 

219.184 Conveyorized Degreasing 

219.185 Compliance Schedule (Repealed) 

219.186 Test Methods 

SUBPART F: COATING OPERATIONS 

Section 

219.204 Emission Limitations 

219.205 Daily-Weighted Average Limitations 

219.206 Solids Basis Calculation 

219.207 Alternative Emission Limitations 

219.208 Exemptions From Emission Limitations 

219.209 Exemption From General Rule on Use of Organic Material 

219.210 Compliance Schedule 

219.211 Recordkeeping and Reporting 

219.212 Cross-Line Averaging to Establish Compliance for Coating Lines 

219.213 Recordkeeping and Reporting for Cross-Line Averaging Participating Coating 

Lines 

219.214 Changing Compliance Methods 

219.215 Wood Furniture Coating Averaging Approach 
 ILLINOIS REGISTER 5399

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.216 Wood Furniture Coating Add-On Control Use 

219.217 Wood Furniture Coating Work Practice Standards 

219.218 Work Practice Standards for Paper Coatings, Metal Furniture Coatings, and Large 

Appliance Coatings

SUBPART G: USE OF ORGANIC MATERIAL 

Section 

219.301 Use of Organic Material 

219.302 Alternative Standard 

219.303 Fuel Combustion Emission Units 

219.304 Operations with Compliance Program 

SUBPART H: PRINTING AND PUBLISHING 

Section 

219.401 Flexographic and Rotogravure Printing 

219.402 Applicability 

219.403 Compliance Schedule 

219.404 Recordkeeping and Reporting 

219.405 Lithographic Printing: Applicability 

219.406 Provisions Applying to Heatset Web Offset Lithographic Printing Prior to March 

15, 1996 

219.407 Emission Limitations and Control Requirements for Lithographic Printing Lines 

On and After March 15, 1996 

219.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996 

219.409 Testing for Lithographic Printing On and After March 15, 1996 

219.410 Monitoring Requirements for Lithographic Printing 

219.411 Recordkeeping and Reporting for Lithographic Printing 

SUBPART Q: SYNTHETIC ORGANIC CHEMICAL AND 

POLYMER MANUFACTURING PLANT 

Section 

219.421 General Requirements 

219.422 Inspection Program Plan for Leaks 

219.423 Inspection Program for Leaks 

219.424 Repairing Leaks 

219.425 Recordkeeping for Leaks 
 ILLINOIS REGISTER 5400

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.426 Report for Leaks 

219.427 Alternative Program for Leaks 

219.428 Open-Ended Valves 

219.429 Standards for Control Devices 

219.430 Compliance Date (Repealed) 

219.431 Applicability 

219.432 Control Requirements 

219.433 Performance and Testing Requirements 

219.434 Monitoring Requirements 

219.435 Recordkeeping and Reporting Requirements 

219.436 Compliance Date 

SUBPART R: PETROLEUM REFINING AND 

RELATED INDUSTRIES; ASPHALT MATERIALS 

Section 

219.441 Petroleum Refinery Waste Gas Disposal 

219.442 Vacuum Producing Systems 

219.443 Wastewater (Oil/Water) Separator 

219.444 Process Unit Turnarounds 

219.445 Leaks: General Requirements 

219.446 Monitoring Program Plan for Leaks 

219.447 Monitoring Program for Leaks 

219.448 Recordkeeping for Leaks 

219.449 Reporting for Leaks 

219.450 Alternative Program for Leaks 

219.451 Sealing Device Requirements 

219.452 Compliance Schedule for Leaks 

219.453 Compliance Dates (Repealed) 

SUBPART S: RUBBER AND MISCELLANEOUS PLASTIC PRODUCTS 

Section 

219.461 Manufacture of Pneumatic Rubber Tires 

219.462 Green Tire Spraying Operations 

219.463 Alternative Emission Reduction Systems 

219.464 Emission Testing 

219.465 Compliance Dates (Repealed) 

219.466 Compliance Plan (Repealed) 
 ILLINOIS REGISTER 5401

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SUBPART T: PHARMACEUTICAL MANUFACTURING 

Section 

219.480 Applicability 

219.481 Control of Reactors, Distillation Units, Crystallizers, Centrifuges and Vacuum 

Dryers 

219.482 Control of Air Dryers, Production Equipment Exhaust Systems and Filters 

219.483 Material Storage and Transfer 

219.484 In-Process Tanks 

219.485 Leaks 

219.486 Other Emission Units 

219.487 Testing 

219.488 Monitoring for Air Pollution Control Equipment 

219.489 Recordkeeping for Air Pollution Control Equipment 

SUBPART V: BATCH OPERATIONS AND AIR OXIDATION PROCESSES 

Section 

219.500 Applicability for Batch Operations 

219.501 Control Requirements for Batch Operations 

219.502 Determination of Uncontrolled Total Annual Mass Emissions and Actual 

Weighted Average Flow Rate Values for Batch Operations 

219.503 Performance and Testing Requirements for Batch Operations 

219.504 Monitoring Requirements for Batch Operations 

219.505 Reporting and Recordkeeping for Batch Operations 

219.506 Compliance Date 

219.520 Emission Limitations for Air Oxidation Processes 

219.521 Definitions (Repealed) 

219.522 Savings Clause 

219.523 Compliance 

219.524 Determination of Applicability 

219.525 Emission Limitations for Air Oxidation Processes (Renumbered) 

219.526 Testing and Monitoring 

219.527 Compliance Date (Repealed) 

SUBPART W: AGRICULTURE 

Section 
 ILLINOIS REGISTER 5402

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.541 Pesticide Exception 

SUBPART X: CONSTRUCTION 

Section 

219.561 Architectural Coatings 

219.562 Paving Operations 

219.563 Cutback Asphalt 

SUBPART Y: GASOLINE DISTRIBUTION 

Section 

219.581 Bulk Gasoline Plants 

219.582 Bulk Gasoline Terminals 

219.583 Gasoline Dispensing Operations – Storage Tank Filling Operations 

219.584 Gasoline Delivery Vessels 

219.585 Gasoline Volatility Standards 

219.586 Gasoline Dispensing Operations – Motor Vehicle Fueling Operations (Repealed) 

SUBPART Z: DRY CLEANERS 

Section 

219.601 Perchloroethylene Dry Cleaners (Repealed) 

219.602 Exemptions (Repealed) 

219.603 Leaks (Repealed) 

219.604 Compliance Dates (Repealed) 

219.605 Compliance Plan (Repealed) 

219.606 Exception to Compliance Plan (Repealed) 

219.607 Standards for Petroleum Solvent Dry Cleaners 

219.608 Operating Practices for Petroleum Solvent Dry Cleaners 

219.609 Program for Inspection and Repair of Leaks 

219.610 Testing and Monitoring 

219.611 Exemption for Petroleum Solvent Dry Cleaners 

219.612 Compliance Dates (Repealed) 

219.613 Compliance Plan (Repealed) 

SUBPART AA: PAINT AND INK MANUFACTURING 

Section 
 ILLINOIS REGISTER 5403

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

219.620 Applicability 

219.621 Exemption for Waterbase Material and Heatset-Offset Ink 

219.623 Permit Conditions 

219.624 Open-Top Mills, Tanks, Vats or Vessels 

219.625 Grinding Mills 

219.626 Storage Tanks 

219.628 Leaks 

219.630 Clean Up 

219.636 Compliance Schedule 

219.637 Recordkeeping and Reporting 

SUBPART BB: POLYSTYRENE PLANTS 

Section 

219.640 Applicability 

219.642 Emissions Limitation at Polystyrene Plants 

219.644 Emissions Testing 

SUBPART FF: BAKERY OVENS 

Section 

219.720 Applicability (Repealed) 

219.722 Control Requirements (Repealed) 

219.726 Testing (Repealed) 

219.727 Monitoring (Repealed) 

219.728 Recordkeeping and Reporting (Repealed) 

219.729 Compliance Date (Repealed) 

219.730 Certification (Repealed) 

SUBPART GG: MARINE TERMINALS 

Section 

219.760 Applicability 

219.762 Control Requirements 

219.764 Compliance Certification 

219.766 Leaks 

219.768 Testing and Monitoring 

219.770 Recordkeeping and Reporting 
 ILLINOIS REGISTER 5404

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SUBPART HH: MOTOR VEHICLE REFINISHING 

Section 

219.780 Emission Limitations 

219.782 Alternative Control Requirements 

219.784 Equipment Specifications 

219.786 Surface Preparation Materials 

219.787 Work Practices 

219.788 Testing 

219.789 Monitoring and Recordkeeping for Control Devices 

219.790 General Recordkeeping and Reporting (Repealed) 

219.791 Compliance Date 

219.792 Registration 

219.875 Applicability of Subpart BB (Renumbered) 

219.877 Emissions Limitation at Polystyrene Plants (Renumbered) 

219.879 Compliance Date (Repealed) 

219.881 Compliance Plan (Repealed) 

219.883 Special Requirements for Compliance Plan (Repealed) 

219.886 Emissions Testing (Renumbered) 

SUBPART PP: MISCELLANEOUS FABRICATED PRODUCT 

MANUFACTURING PROCESSES 

Section 

219.920 Applicability 

219.923 Permit Conditions 

219.926 Control Requirements 

219.927 Compliance Schedule 

219.928 Testing 

SUBPART QQ: MISCELLANEOUS FORMULATION 

MANUFACTURING PROCESSES 

Section 

219.940 Applicability 

219.943 Permit Conditions 

219.946 Control Requirements 

219.947 Compliance Schedule 

219.948 Testing 
 ILLINOIS REGISTER 5405

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SUBPART RR: MISCELLANEOUS ORGANIC CHEMICAL 

MANUFACTURING PROCESSES 

Section 

219.960 Applicability 

219.963 Permit Conditions 

219.966 Control Requirements 

219.967 Compliance Schedule 

219.968 Testing 

SUBPART TT: OTHER EMISSION UNITS 

Section 

219.980 Applicability 

219.983 Permit Conditions 

219.986 Control Requirements 

219.987 Compliance Schedule 

219.988 Testing 

SUBPART UU: RECORDKEEPING AND REPORTING 

Section 

219.990 Exempt Emission Units 

219.991 Subject Emission Units 

219.APPENDIX A List of Chemicals Defining Synthetic Organic Chemical and Polymer 

Manufacturing 

219.APPENDIX B VOM Measurement Techniques for Capture Efficiency (Repealed) 

219.APPENDIX C Reference Methods and Procedures 

219.APPENDIX D Coefficients for the Total Resource Effectiveness Index (TRE) Equation 

219.APPENDIX E List of Affected Marine Terminals 

219.APPENDIX G TRE Index Measurements for SOCMI Reactors and Distillation Units 

219.APPENDIX H Baseline VOM Content Limitations for Subpart F, Section 219.212 CrossLine Averaging 

AUTHORITY: Implementing Section 10 and authorized by Sections 27, 28 and 28.5 of the 

Environmental Protection Act [415 ILCS 5/10, 27, 28 and 28.5]. 
 ILLINOIS REGISTER 5406

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

SOURCE: Adopted in R91-8 at 15 Ill. Reg. 12491, effective August 16, 1991; amended in R91-

24 at 16 Ill. Reg. 13597, effective August 24, 1992; amended in R91-30 at 16 Ill. Reg. 13883, 

effective August 24, 1992; emergency amendment in R93-12 at 17 Ill. Reg. 8295, effective May 

24, 1993, for a maximum of 150 days; amended in R93-9 at 17 Ill. Reg. 16918, effective 

September 27, 1993 and October 21, 1993; amended in R93-28 at 18 Ill. Reg. 4242, effective 

March 3, 1994; amended in R94-12 at 18 Ill. Reg. 14987, effective September 21, 1994; 

amended in R94-15 at 18 Ill. Reg. 16415, effective October 25, 1994; amended in R94-16 at 18 

Ill. Reg. 16980, effective November 15, 1994; emergency amendment in R95-10 at 19 Ill. Reg. 

3059, effective February 28, 1995, for a maximum of 150 days; amended in R94-21, R94-31 and 

R94-32 at 19 Ill. Reg. 6958, effective May 9, 1995; amended in R94-33 at 19 Ill. Reg. 7385, 

effective May 22, 1995; amended in R96-2 at 20 Ill. Reg. 3848, effective February 15, 1996; 

amended in R96-13 at 20 Ill. Reg. 14462, effective October 28, 1996; amended in R97-24 at 21 

Ill. Reg. 7721, effective June 9, 1997; amended in R97-31 at 22 Ill. Reg. 3517, effective 

February 2, 1998; amended in R04-12/20 at 30 Ill. Reg. 9799, effective May 15, 2006; amended 

in R06-21 at 31 Ill. Reg. 7110, effective April 30, 2007; amended in R10-10 at 34 Ill. Reg. 5392, 

effective March 23, 2010. 

SUBPART A: GENERAL PROVISIONS 

Section 219.106 Compliance Dates 

a) Except as provided in subsection (b) below, compliance with the requirements of 

this Part is required by May 15, 1992, consistent with the provisions of Section 

219.103 of this Part. 

b) As this Part is amended from time to time, compliance dates included in the 

specific Subparts supersede the requirements of this Section except as limited by 

Section 219.101(b) of this Subpart. 

c) Any owner or operator of a source subject to the requirements of Section 

219.204(c)(2), 219.204(g)(2), or 219.204(h)(2) of this Part shall comply with the 

applicable requirements in the applicable subsections, as well as all applicable 

requirements in Sections 219.205 through 219.214 and 219.218, by May 1, 2011. 

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

SUBPART F: COATING OPERATIONS 

Section 219.204 Emission Limitations 
 ILLINOIS REGISTER 5407

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

Except as provided in Sections 219.205, 219.207, 219.208, 219.212, 219.215 and 219.216 of this 

Subpart, no owner or operator of a coating line shall apply at any time any coating in which the 

VOM content exceeds the following emission limitations for the specified coating. Except as 

otherwise provided in Section 219.204(c), 219.204(g), 219.204(h), andSection 219.204(l), 

compliance with the emission limitations marked with an asterisk in this Section is required on 

and after March 15, 1996, and compliance with emission limitations not marked with an asterisk 

is required until March 15, 1996. The following emission limitations are expressed in units of 

VOM per volume of coating (minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied at each coating applicator, except where noted. 

Compounds which are specifically exempted from the definition of VOM should be treated as 

water for the purpose of calculating the "less water" part of the coating composition. Compliance 

with this Subpart must be demonstrated through the applicable coating analysis test methods and 

procedures specified in Section 219.105(a) of this Part and the recordkeeping and reporting 

requirements specified in Section 219.211(c) of this Subpart except where noted. (Note: The 

equation presented in Section 219.206 of this Part shall be used to calculate emission limitations 

for determining compliance by add-on controls, credits for transfer efficiency, emissions trades 

and cross-line averaging.) The emission limitations are as follows: 

a) Automobile or Light-Duty Truck Coating kg/l lb/gal 

 1) Prime coat 0.14 (1.2) 

 0.14* (1.2)* 

 2) Primer surface coat 1.81 (15.1) 

 1.81* (15.1)* 

(Note: The primer surface coat limitation is in units of kg (lbs) of VOM per l (gal) 

of coating solids deposited. Compliance with the limitation shall be based on the 

daily-weighted average from an entire primer surface operation. Compliance shall 

be demonstrated in accordance with the topcoat protocol referenced in Section 

219.105(b) and the recordkeeping and reporting requirements specified in Section 

219.211(f). Testing to demonstrate compliance shall be performed in accordance 

with the topcoat protocol and a detailed testing proposal approved by the Agency 

and USEPA specifying the method of demonstrating compliance with the protocol. 

Section 219.205 does not apply to the primer surface limitation.) 

 3) Topcoat kg/l lb/gal 

 1.81 (15.1) 

 1.81* (15.1)* 
 ILLINOIS REGISTER 5408

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

(Note: The topcoat limitation is in units of kg (lbs) of VOM per l (gal) of coating 

solids deposited. Compliance with the limitation shall be based on the dailyweighted average from an entire topcoat operation. Compliance shall be 

demonstrated in accordance with the topcoat protocol referenced in Section 

219.105(b) of this Part and the recordkeeping and reporting requirements specified 

in Section 219.211(f). Testing to demonstrate compliance shall be performed in 

accordance with the topcoat protocol and a detailed testing proposal approved by 

the Agency and USEPA specifying the method of demonstrating compliance with 

the protocol. Section 219.205 of this Part does not apply to the topcoat limitation.) 

4) Final repair coat kg/l lb/gal 

0.58 (4.8) 

0.58* (4.8)* 

b) Can Coating kg/l lb/gal 

 1) Sheet basecoat and overvarnish 

A) Sheet basecoat 0.34 (2.8) 

0.26* (2.2)* 

B) Overvarnish 0.34 (2.8) 

0.34 (2.8)* 

2) Exterior basecoat and overvarnish 0.34 (2.8) 

0.25* (2.1)* 

3) Interior body spray coat 

A) Two piece 0.51 (4.2) 

0.44* (3.7)* 

B) Three piece 0.51 (4.2) 

0.51* (4.2)* 

4) Exterior end coat 0.51 (4.2) 

0.51* (4.2)* 

5) Side seam spray coat 0.66 (5.5) 
 ILLINOIS REGISTER 5409

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

0.66* (5.5)* 

6) End sealing compound coat 0.44 (3.7) 

0.44* (3.7)* 

c) Paper Coating kg/l lb/gal

0.35 (2.9)

0.28* (2.3)*

1) Prior to May 1, 2011: kg/l lb/gal

0.28 (2.3)

2) On and after May 1, 2011: kg VOM/kg kg VOM/kg

(lb VOM/lb) (lb VOM/lb)

solids 

applied

coatings 

applied

A) Pressure sensitive tape and 

label surface coatings

0.20 (0.067)

B) All other paper coatings 0.40 (0.08)

3) (Note: The paper coating limitation set forth in this subsection (c) shall 

not apply to any owner or operator of any paper coating line on which 

flexographic or rotogravure printing is performed if the paper coating line 

complies with the emissions limitations in Section 219.401 of this Part. In 

addition, screen printing on paper is not regulated as paper coating, but is 

regulated under Subpart TT of this Part. On and after May 1, 2011, the 

paper coating limitation shall also not apply to coating performed on or inline with any digital printing press, or to size presses and on-machine 

coaters on papermaking machines applying sizing or water-based clays.)

d) Coil Coating kg/l lb/gal 

 0.31 (2.6) 

 0.20* (1.7)* 

e) Fabric Coating 0.35 (2.9) 

 0.28* (2.3)* 

f) Vinyl Coating 0.45 (3.8) 

 0.28* (2.3)* 
 ILLINOIS REGISTER 5410

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

g) Metal Furniture Coating 

1) Prior to May 1, 2011: kg/l lb/gal

A) Air Dried 0.34 (2.8)

B) Baked 0.28 (2.3)

2) On and after May 1, 2011: kg/l kg/l (lb/gal)

 (lb/gal) solids applied

A) General, One Component 0.275 0.40

 (2.3) (3.3)

B) General, Multi-Component 

 i) Air Dried 0.340 0.55

 (2.8) (4.5)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

C) Extreme High Gloss 

 i) Air Dried 0.340 0.55

 (2.8) (4.5)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

D) Extreme Performance 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

E) Heat Resistant 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61
 ILLINOIS REGISTER 5411

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 (3.0) (5.1)

F) Metallic 0.420 0.80

 (3.5) (6.7)

G) Pretreatment Coatings 0.420 0.80

 (3.5) (6.7)

H) Solar Absorbent 

 i) Air Dried 0.420 0.80

 (3.5) (6.7)

 ii) Baked 0.360 0.61

 (3.0) (5.1)

3) On and after May 1, 2011, the limitations set forth in this subsection (g) shall 

not apply to stencil coatings, safety-indicating coatings, solid-film lubricants, 

electric-insulating and thermal-conducting coatings, touch-up and repair 

coatings, or coating applications utilizing hand-held aerosol cans.

h) Large Appliance Coating 

1) Prior to May 1, 2011: kg/l lb/gal

A) Air Dried 0.34 (2.8)

B) Baked 0.28 (2.3)

2) On and after May 1, 2011: kg/l kg/l (lb/gal)

(lb/gal) solids applied

A) General, One Component 0.275 0.40

(2.3) (3.3)

B) General, Multi-Component

i) Air Dried 0.340 0.55

(2.8) (4.5)

ii) Baked 0.275 0.40

(2.3) (3.3)
 ILLINOIS REGISTER 5412

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

C) Extreme High Gloss

i) Air Dried 0.340 0.55

(2.8) (4.5)

ii) Baked 0.360 0.61

(3.0) (5.1)

D) Extreme Performance

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

(3.0) (5.1)

 

E) Heat Resistant

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

 (3.0) (5.1)

F) Metallic 0.420 0.80

(3.5) (6.7)

G) Pretreatment Coatings 0.420 0.80

(3.5) (6.7)

H) Solar Absorbent

i) Air Dried 0.420 0.80

(3.5) (6.7)

ii) Baked 0.360 0.61

(3.0) (5.1)

1) Air dried 0.34 (2.8)

 0.34* (2.8)*

2) Baked 0.34 (2.8)
 ILLINOIS REGISTER 5413

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 0.28* (2.3)*

3) (Note: The limitations set forth in this subsection (h)The limitation shall 

not apply to the use of quick-drying lacquers for repair of scratches and 

nicks that occur during assembly, provided that the volume of coating 

does not exceed 0.95 1 (1 quart) in any one rolling eight-hour period. On 

and after May 1, 2011, these limitations shall also not apply to stencil 

coatings, safety-indicating coatings, solid-film lubricants, electricinsulating and thermal-conducting coatings, touch-up and repair coatings, 

or coating applications utilizing hand-held aerosol cans.)

i) Magnet Wire Coating kg/l lb/gal 

 0.20 (1.7) 

 0.20* (1.7)* 

j) Miscellaneous Metal Parts and Products Coating 

1) Clear coating 0.52 (4.3) 

0.52* (4.3)* 

2) Extreme performance coating 

A) Air dried 0.42 (3.5) 

0.42* (3.5)* 

B) Baked 0.42 (3.5) 

0.40* (3.3)* 

3) Steel pail and drum interior coating 0.52 (4.3) 

0.52* (4.3)* 

4) All other coatings 

A) Air Dried 0.42 (3.5) 

0.40* (3.3)* 

B) Baked 0.36 (3.0) 

0.34* (2.8)* 

5) Metallic Coating 

A) Air Dried 0.42 (3.5) 
 ILLINOIS REGISTER 5414

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

0.42* (3.5)* 

B) Baked 0.36 (3.0) 

0.36 (3.0)* 

6) For purposes of subsection 219.204(j)(5) of this Section, "metallic 

coating" means a coating which contains more than 1⁄4 lb/gal of metal 

particles, as applied. 

k) Heavy Off-Highway Vehicle Products Coating kg/l lb/gal 

1) Extreme performance prime coat 0.42 (3.5) 

0.42* (3.5)* 

2) Extreme performance topcoat (air dried) 0.42 (3.5) 

0.42* (3.5)* 

3) Final repair coat (air dried) 0.42 (3.5) 

0.42* (3.5)* 

 4) All other coatings are subject to the emission limitations for 

miscellaneous metal parts and products coatings in subsection (j) above.

l) Wood Furniture Coating 

 1) Limitations before March 15, 1998: kg/l lb/gal 

 A) Clear topcoat 0.67 (5.6) 

 B) Opaque stain 0.56 (4.7) 

 C) Pigmented coat 0.60 (5.0) 

 D) Repair coat 0.67 (5.6) 

 E) Sealer 0.67 (5.6) 

 F) Semi-transparent stain 0.79 (6.6) 

 G) Wash coat 0.73 (6.1) 
 ILLINOIS REGISTER 5415

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

(Note: Prior to March 15, 1998, an owner or operator of a wood furniture 

coating operation subject to this Section shall apply all coatings, with the 

exception of no more than 37.8 l (10 gal) of coating per day used for 

touch-up and repair operations, using one or more of the following 

application systems: airless spray application system, air-assisted airless 

spray application system, electrostatic spray application system, 

electrostatic bell or disc spray application system, heated airless spray 

application system, roller coating, brush or wipe coating application 

system, dip coating application system or high volume low pressure 

(HVLP) application system.) 

2) On and after March 15, 1998, wood furniture sealers and topcoats must 

comply with one of the limitations specified in subsections (l)(2)(A) 

through (E), below: 

 kg VOM/kg 

solids 

lb VOM/lb 

solids 

 A) Topcoat 0.8 (0.8) 

 B) Sealers and topcoats with the 

following limits: 

 

 i) Sealer other than acid-cured 

alkyd amino vinyl sealer 

1.9 (1.9) 

 ii) Topcoat other than acid-cured 

alkyd amino conversion varnish 

topcoat 

1.8 (1.8) 

 iii) Acid-cured alkyd amino vinyl 

sealer 

2.3 (2.3) 

 iv) Acid-cured alkyd amino 

conversion varnish topcoat 

2.0 (2.0) 

 

C) Meet the provisions of Section 219.215 of this Subpart for use of 

an averaging approach; 
 ILLINOIS REGISTER 5416

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

D) Achieve a reduction in emissions equivalent to the requirements of 

Section 219.204(l)(2)(A) or (B) of this Subpart, as calculated using 

Section 219.216 of this Subpart; or 

E) Use a combination of the methods specified in Section 

219.204(l)(2)(A) through (D) of this Subpart. 

 3) Other wood furniture coating limitations on and after March 15, 1998: 

 kg/l lb/gal 

 A) Opaque stain 0.56 (4.7) 

 B) Non-topcoat pigmented coat 0.60 (5.0) 

 C) Repair coat 0.67 (5.6) 

 D) Semi-transparent stain 0.79 (6.6) 

 E) Wash coat 0.73 (6.1) 

4) Other wood furniture coating requirements on and after March 15, 1998: 

A) No source subject to the limitations of subsection (l)(2) or (3) of 

this Section and utilizing one or more wood furniture coating spray 

booths shall use strippable spray booth coatings containing more 

than 0.8 kg VOM/kg solids (0.8 lb VOM/lb solids), as applied. 

B) Any source subject to the limitations of subsection (l)(2) or (3) of 

this Section shall comply with the requirements of Section 219.217 

of this Subpart. 

C) Any source subject to the limitations of subsection (l)(2)(A) or (B) 

of this Section and utilizing one or more continuous coaters, shall 

for each continuous coater, use an initial coating which complies 

with the limitations of subsection (l)(2)(A) or (B) of this Section. 

The viscosity of the coating in each reservoir shall always be 

greater than or equal to the viscosity of the initial coating in the 

reservoir. The owner or operator shall: 
 ILLINOIS REGISTER 5417

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

i) Monitor the viscosity of the coating in the reservoir with a 

viscosity meter or by testing the viscosity of the initial 

coating and retesting the coating in the reservoir each time 

solvent is added; 

ii) Collect and record the reservoir viscosity and the amount 

and weight of VOM per weight of solids of coating and 

solvent each time coating or solvent is added; and 

iii) Maintain these records at the source for a period of three 

years. 

m) Plastic Parts Coating: Automotive/Transportation kg/l lb/gal 

 1) Interiors 

 A) Baked 

 i) Color coat 0.49* (4.1)* 

 ii) Primer 0.46* (3.8)* 

 B) Air Dried 

 i) Color coat 0.38* (3.2)* 

 ii) Primer 0.42* (3.5)* 

 2) Exteriors (flexible and non-flexible) 

 A) Baked 

 i) Primer 0.60* (5.0)* 

 ii) Primer non-flexible 0.54* (4.5)* 

 iii) Clear coat 0.52* (4.3)* 

 iv) Color coat 0.55* (4.6)* 

 B) Air Dried 

 i) Primer 0.66* (5.5)* 
 ILLINOIS REGISTER 5418

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

 ii) Clear coat 0.54* (4.5)* 

 iii) Color coat (red & black) 0.67* (5.6)* 

 iv) Color coat (others) 0.61* (5.1)* 

 3) Specialty 

 A) Vacuum metallizing basecoats, 

texture basecoats 

0.66* (5.5)* 

 B) Black coatings, reflective argent 

coatings, air bag cover coatings, and 

soft coatings 

0.71* (5.9)* 

 C) Gloss reducers, vacuum metallizing 

topcoats, and texture topcoats 

0.77* (6.4)* 

 D) Stencil coatings, adhesion primers, 

ink pad coatings, electrostatic prep 

coatings, and resist coatings 

0.82* (6.8)* 

 E) Head lamp lens coatings 0.89* (7.4)* 

n) Plastic Parts Coating: Business Machine kg/l lb/gal 

 1) Primer 0.14* (1.2)* 

 2) Color coat (non-texture coat) 0.28* (2.3)* 

 3) Color coat (texture coat) 0.28* (2.3)* 

 4) Electromagnetic interference/radio frequency 

interference (EMI/RFI) shielding coatings 

0.48* (4.0)* 

 5) Specialty Coatings 

 A) Soft coat 0.52* (4.3)* 

 B) Plating resist 0.71* (5.9)* 

 C) Plating sensitizer 0.85* (7.1)* 
 ILLINOIS REGISTER 5419

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.205 Daily-Weighted Average Limitations 

No owner or operator of a coating line subject to the limitations of Section 219.204 of this 

Subpart and complying by means of this Section shall operate the subject coating line unless the 

owner or operator has demonstrated compliance with subsection (a), (b), (c), (d), (e), (f), (g), or 

(h), or (i) of this Section (depending upon the category of coating) through the applicable coating 

analysis test methods and procedures specified in Section 219.105(a) of this Part and the 

recordkeeping and reporting requirements specified in Section 219.211(d) of this Subpart: 

a) No owner or operator of a coating line subject to only one of the limitations from 

among Section 219.204(a)(1), (a)(4), (c), (d), (e), (f), or (i), or , prior to May 1, 

2011, (c) of this Subpart shall apply coatings on any such coating line, during any 

day, whose daily-weighted average VOM content exceeds the emission limitation 

to which the coatings are subject. 

b) No owner or operator of a miscellaneous metal parts and products coating line 

subject to the limitations of Section 219.204(j) of this Subpart shall apply coatings 

to miscellaneous metal parts or products on the subject coating line unless the 

requirements in subsection (b)(1) or (b)(2) of this Section are met. 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(j) of this Subpart during the same day (e.g., all coatings used on 

the line are subject to 0.42 kg/l (3.5 lbs/gal), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line thatwhich applies coatings subject to more than one 

numerical emission limitation in Section 219.204(j) of this Subpart, during 

the same day, the owner or operator shall have a site-specific proposal 

approved by the Agency and approved by the USEPA as a SIP revision. 

To receive approval, the requirements of USEPA's Emissions Trading 

Policy Statement (and related policy) 51 Fed. Reg. 43814 (December 4, 

1986), must be satisfied. 

c) No owner or operator of a can coating line subject to the limitations of Section 

219.204(b) of this Subpart shall operate the subject coating line using a coating 
 ILLINOIS REGISTER 5420

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

with a VOM content in excess of the limitations specified in Section 219.204(b) 

of this Subpart unless all of the following requirements are met: 

1) An alternative daily emission limitation for the can coating operation, i.e.,

for all of the can coating lines at the source, shall be determined according 

to subsection (c)(2) of this Section. Actual daily emissions shall never 

exceed the alternative daily emission limitation and shall be calculated by 

use of the following equation. 





n

i

Eb ViCi

1

where: 

Ed = Actual VOM emissions for the day in units of kg/day (lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied in the can coating operation, 

i.e., all can coating lines at the source; 

Vi = Volume of each coating applied for the day in units of l/day 

(gal/day) of coating (minus water and any compounds which are 

specifically exempted from the definition of VOM); 

Ci = The VOM content of each coating as applied in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the definition 

of VOM). 

2) The alternative daily emission limitation (Ad) shall be determined for the 

can coating operation, i.e., for all of the can coating lines at the source, on 

a daily basis as follows: 

 

  i i

i i

i

n

i

d i D L

D C A V L 

  1

where: 
 ILLINOIS REGISTER 5421

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

Ad = The VOM emissions allowed for the day in units of kg/day 

(lbs/day); 

 

i = Subscript denoting a specific coating applied; 

 

n = Total number of surface coatings applied in the can coating 

operation; 

 

Ci = The VOM content of each surface coating as applied in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any compounds 

which are specifically exempted from the definition of VOM); 

 

Di = The density of VOM in each coating applied. For the purposes of 

calculating Ad, the density is 0.882kg VOM/l VOM (7.36 lbs 

VOM/gal VOM); 

 

Vi = Volume of each surface coating applied for the day in units of l 

(gal) of coating (minus water and any compounds which are 

specifically exempted from the definition of VOM); 

 

Li = The VOM emission limitation for each surface coating applied as 

specified in Section 219.204(b) of this Subpart in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any compounds 

which are specifically exempted from the definition of VOM). 

d) No owner or operator of a heavy off-highway vehicle products coating line 

subject to the limitations of Section 219.204(k) of this Subpart shall apply 

coatings to heavy off-highway vehicle products on the subject coating line unless 

the requirements of subsection (d)(1) or (d)(2) of this Section are met. 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(k) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.42 kg/l (3.5 lbs/gal), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line thatwhich applies coatings subject to more than one 
 ILLINOIS REGISTER 5422

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

numerical emission limitation in Section 219.204(k) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and approved by the USEPA as a SIP 

revision. To receive approval, the requirements of USEPA's Emissions 

Trading Policy Statement (and related policy) 51 Fed. Reg. 43814 

(December 4, 1986), must be satisfied. 

e) No owner or operator of a wood furniture coating line subject to the limitations of 

Section 219.204(l)(1) or (l)(3) of this Subpart shall apply coatings to wood 

furniture on the subject coating line unless the requirements of subsection (e)(1) 

or (e)(2) of this Section, in addition to the requirements specified in the note to 

Section 219.204(l)(1) of this Subpart, are met. 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(l)(1) or (l)(3) of this Subpart, during the same day (e.g., all 

coatings used on the line are subject to 0.67 kg/l (5.6 lbs/gal), the dailyweighted average VOM content shall not exceed the coating VOM content 

limit corresponding to the category of coating used, or 

2) For each coating line thatwhich applies coatings subject to more than one 

numerical emission limitation in Section 219.204(l)(1) or (l)(3) of this 

Subpart, during the same day, the owner or operator shall have a site 

specific proposal approved by the Agency and approved by the USEPA as 

a SIP revision. To receive approval, the requirements of USEPA's 

Emissions Trading Policy Statement (and related policy) 51 Fed. Reg. 

43814 (December 4, 1986), must be satisfied. 

f) No owner or operator of a plastic parts coating line subject to the limitations of 

Section 219.204(m) or (n) of this Subpart shall apply coatings to business 

machine or automotive/transportation plastic parts on the subject coating line 

unless the requirements of subsection (f)(1) or (f)(2) of this Section are met. 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(m) or (n) of this Subpart, during the same day (e.g., all coatings 

used on the line are subject to 0.42 kg/l (3.5 lbs/gal), the daily-weighted 

average VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 
 ILLINOIS REGISTER 5423

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

2) For each coating line thatwhich applies coatings subject to more than one 

numerical emission limitation in Section 219.204(m) or (n) of this 

Subpart, during the same day, the owner or operator shall have a site 

specific proposal approved by the Agency and USEPA as a SIP revision. 

To receive approval, the requirements of USEPA's Emissions Trading 

Policy Statement (and related policy) must be satisfied. 

g) No owner or operator of a metal furniture coating line subject to the limitations of 

Section 219.204(g) of this Subpart shall apply coatings on the subject coating line 

unless the requirements of subsection (g)(1) or (g)(2) of this Section are met: 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(g) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.34 kg/l (2.8 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line thatwhich applies coatings subject to more than one 

numerical emission limitation in Section 219.204(g) of this Subpart, 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and USEPA as a SIP revision. To 

receive approval, the requirements of USEPA's Emissions Trading Policy 

Statement (and related policy) must be satisfied. 

h) No owner or operator of a large appliance coating line subject to the limitations of 

Section 219.204(h) of this Subpart shall apply coatings on the subject coating line 

unless the requirements of subsection (h)(1) or (h)(2) of this Section are met. 

1) For each coating line thatwhich applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(h) of this Subpart, during the same day (e.g., all coatings used on 

the line are subject to 0.34 kg/l (2.8 lbs/gal)), the daily-weighted average 

VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used, or 

2) For each coating line thatwhich applies coatings subject to more than one 

numerical emission limitation in Section 219.204(h) of this Subpart, 
 ILLINOIS REGISTER 5424

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

during the same day, the owner or operator shall have a site specific 

proposal approved by the Agency and USEPA as a SIP revision. To 

receive approval, the requirements of USEPA's Emissions Trading Policy 

Statement (and related policy) must be satisfied. 

i) On and after May 1, 2011, no owner or operator of a paper coating line subject to 

the limitations of Section 219.204(c) of this Subpart shall apply coatings on the 

subject coating line unless the requirements in subsection (i)(1) or (i)(2) of this 

Section are met:

1) For each coating line that applies multiple coatings, all of which are 

subject to the same numerical emission limitation within Section 

219.204(c) during the same day (e.g., all coatings used on the line are 

subject to 0.40 kg/kg solids (0.08 kg/kg coatings)), the daily-weighted 

average VOM content shall not exceed the coating VOM content limit 

corresponding to the category of coating used; or

2) For each coating line that applies coatings subject to more than one 

numerical emission limitation in Section 219.204(c) during the same day, 

the owner or operator shall have a site-specific proposal approved by the 

Agency and approved by USEPA as a SIP revision. To receive approval, 

the requirements of USEPA's Emissions Trading Policy Statement (and 

related policy), 51 Fed. Reg. 43814 (December 4, 1986), must be satisfied.

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.207 Alternative Emission Limitations 

a) Any owner or operator of a coating line subject to Section 219.204 of this Subpart 

may comply with this Section, rather than with Section 219.204 of this Subpart, if 

a capture system and control device are operated at all times the coating line is in 

operation and the owner or operator demonstrates compliance with subsection (c), 

(d), (e), (f), (g), (h), (i), or (j), or (k) of this Section (depending upon the source 

category) through the applicable coating analysis and capture system and control 

device efficiency test methods and procedures specified in Section 219.105 of this 

Part and the recordkeeping and reporting requirements specified in Section 

219.211(e) of this Subpart; and the control device is equipped with the applicable 

monitoring equipment specified in Section 219.105(d) of this Part and the 

monitoring equipment is installed, calibrated, operated and maintained according 
 ILLINOIS REGISTER 5425

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

to vendor specifications at all times the control device is in use. A capture system 

and control device, which does not demonstrate compliance with subsection (c), 

(d), (e), (f), (g), (h), (i), (j), or (k) of this Section may be used as an alternative to 

compliance with Section 219.204 of this Subpart only if the alternative is 

approved by the Agency and approved by the USEPA as a SIP revision. 

b) Alternative Add-On Control Methodologies 

1) The coating line is equipped with a capture system and control device that 

provides 81 percent reduction in the overall emissions of VOM from the 

coating line and the control device has a 90 percent efficiency, or 

2) The system used to control VOM from the coating line is demonstrated to 

have an overall efficiency sufficient to limit VOM emissions to no more 

than what is allowed under Section 219.204 of this Subpart. Use of any 

control system other than an afterburner, carbon adsorption, condensation, 

or absorption scrubber system can be allowed only if approved by the 

Agency and approved by the USEPA as a SIP revision. The use of transfer 

efficiency credits can be allowed only if approved by the Agency and 

approved by the USEPA as a SIP revision. Baseline transfer efficiencies 

and transfer efficiency test methods must be approved by the Agency and 

the USEPA. Such overall efficiency is to be determined as follows: 

A) Obtain the emission limitation from the appropriate subsection in 

Section 219.204 of this Subpart; 

B) Calculate "S" according to the equation in Section 219.206 of this 

Subpart; 

C) Calculate the overall efficiency required according to Section 

219.105(e) of this Part. For the purposes of calculating this value, 

according to the equation in Section 219.105(e)(2) of this Part, 

VOM1 is equal to the value of "S" as determined above in 

subsection (b)(2)(B) of this Section. 

c) No owner or operator of a coating line subject to only one of the emission 

limitations from among Section 219.204(a)(1), (a)(4), (c), (d), (e), (f), or (i), or, 

prior to May 1, 2011, (c) of this Subpart and equipped with a capture system and 

control device shall operate the subject coating line unless the requirements in 
 ILLINOIS REGISTER 5426

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

subsection (b)(1) or (b)(2) of this Section are met. No owner or operator of a 

coating line subject to Section 219.204(a)(2) or (a)(3) of this Part and equipped 

with a capture system and control device shall operate the coating line unless the 

owner or operator demonstrates compliance with such limitation in accordance 

with the topcoat protocol referenced in Section 219.105(b) of this Part. 

d) No owner or operator of a miscellaneous metal parts and products coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 219.204(j) of 

this Subpart (e.g., all coatings used on the line are subject to 0.42 kg/l ([3.5 

lbs/gal)], and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

e) No owner or operator of a heavy off-highway vehicle products coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 219.204(k) of 

this Subpart (e.g., all coatings used on the line are subject to 0.42 kg/l ([3.5 

lbs/gal)]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

f) No owner or operator of a wood furniture coating line thatwhich applies one or 

more coatings during the same day, all of which are subject to the same numerical 

emission limitation within Section 219.204(l) of this Subpart (e.g., all coatings 

used on the line are subject to 0.67 kg/l ([5.6 lbs/gal)]), and thatwhich is equipped 

with a capture system and control device shall operate the subject coating line 

unless the requirements in subsection (b)(1) or (b)(2) of this Section are met. If 

compliance is achieved by meeting the requirements in subsection (b)(2) of this 

Section, then the provisions in the note to Section 219.204(l) of this Subpart must 

also be met. 

g) No owner or operator of a can coating line and equipped with a capture system 

and control device shall operate the subject coating line unless the requirements in 

subsection (g)(1) or (g)(2) of this Section are met. 

1) An alternative daily emission limitation for the can coating operation, i.e.,

for all of the can coating lines at the source, shall be determined according 

to Section 219.205(c)(2) of this Subpart. Actual daily emissions shall 
 ILLINOIS REGISTER 5427

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

never exceed the alternative daily emission limitation and shall be 

calculated by use of the following equation: 

 i

n

i

Ed  ViCi  F 1

1

where: 

Ed = Actual VOM emissions for the day in units of kg/day 

(lbs/day); 

i = Subscript denoting the specific coating applied; 

n = Total number of surface coatings as applied in the can 

coating operation; 

Vi = Volume of each coating as applied for the day in units of 

l/day (gal/day) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 

 

Ci = The VOM content of each coating as applied in units of 

kg VOM/l (lbs VOM/gal) of coating (minus water and 

any compounds which are specifically exempted from 

the definition of VOM) and 

Fi = Fraction, by weight, of VOM emissions from the surface 

coating, reduced or prevented from being emitted to the 

ambient air. This is the overall efficiency of the capture 

system and control device. 

2) The coating line is equipped with a capture system and control device that 

provide 75 percent reduction in the overall emissions of VOM from the 

coating line and the control device has a 90 percent efficiency. 

h) No owner or operator of a plastic parts coating line thatwhich applies one or more 

coatings during the same day, all of which are subject to the same numerical 

emission limitation within Section 219.204(m) or (n) of this Subpart (e.g., all 

coatings used on the line are subject to 0.42 kg/l ([3.5 lbs/gal)]), and thatwhich is 
 ILLINOIS REGISTER 5428

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

equipped with a capture system and control device shall operate the subject 

coating line unless the requirements in subsection (b)(1) or (b)(2) of this Section 

are met. 

i) Prior to May 1, 2011, noNo owner or operator of a metal furniture coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 219.204(g) of 

this Subpart (e.g., all coatings used on the line are subject to 0.34 kg/l ([2.8 

lbs/gal)]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

j) Prior to May 1, 2011, noNo owner or operator of a large appliance coating line 

thatwhich applies one or more coatings during the same day, all of which are 

subject to the same numerical emission limitation within Section 219.204(h) of 

this Subpart (e.g., all coatings used on the line are subject to 0.34 kg/l ([2.8 

lbs/gal)]), and thatwhich is equipped with a capture system and control device 

shall operate the subject coating line unless the requirements in subsection (b)(1) 

or (b)(2) of this Section are met. 

k) On and after May 1, 2011, no owner or operator of a paper coating line, metal 

furniture coating line, or large appliance coating line that is equipped with a 

capture system and control device shall operate the subject coating line unless 

either:

1) The capture system and control device provide at least 90 percent 

reduction in the overall emissions of VOM from the coating line; or

2) The owner or operator complies with the applicable limitation set forth in 

Section 219.204 of this Subpart by utilizing a combination of low-VOM 

coatings and a capture system and control device.

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.210 Compliance Schedule 

Every owner or operator of a coating line (of a type included within Section 219.204 of this 

Subpart) shall comply with the requirements of Section 219.204, 219.205, 219.207 or 219.208 

and Section 219.211 or Sections 219.212 and 219.213 of this Subpart in accordance with the 
 ILLINOIS REGISTER 5429

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appropriate compliance schedule as specified in subsection (a), (b), (c), (d), (e), or (f), or (g) of 

this Sectionbelow: 

a) No owner or operator of a coating line thatwhich is exempt from the limitations of 

Section 219.204 of this Subpart because of the criteria in Section 219.208(a) or 

(b) of this Subpart shall operate said coating line on or after a date consistent with 

Section 219.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Section 219.211(b) of this Subpart. 

b) No owner or operator of a coating line complying by means of Section 219.204 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 219.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 219.204 and 219.211(c) of this Subpart. 

c) No owner or operator of a coating line complying by means of Section 219.205 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 219.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 219.205 and 219.211(d) of this Subpart. 

d) No owner or operator of a coating line complying by means of Section 219.207 of 

this Subpart shall operate said coating line on or after a date consistent with 

Section 219.106 of this Part, unless the owner or operator has complied with, and 

continues to comply with, Sections 219.207 and 219.211(e) of this Subpart. 

e) No owner or operator of a coating line subject to one or more of the emission 

limitations contained in Section 219.204 of this Subpart on or after March 15, 

1996, choosing to comply by means of Section 219.204, 219.205 or 219.207 of 

this Subpart, shall operate said coating line on or after March 15, 1996, unless the 

owner or operator complies with and continues to comply with, respectively, the 

applicable requirements in Section 219.204, or the alternative control options in 

Sections 219.205 or 219.207 and the requirements of Section 219.211. 

f) No owner or operator of a coating line subject to one or more of the emission 

limitations contained in Section 219.204 of this Subpart on or after March 15, 

1996, choosing to comply by means of Section 219.212 of this Subpart, shall 

operate said coating line on or after March 15, 1996, unless the owner or operator 

complies with and continues to comply with the requirements of Sections 219.212 

and 219.213 of this Subpart. 
 ILLINOIS REGISTER 5430

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

g) No owner or operator of a coating line subject to the emission limitations in 

Section 219.204(c)(2), 219.204(g)(2), or 219.204(h)(2) of this Subpart shall 

operate that coating line on or after a date consistent with Section 219.106(c) of 

this Part, unless the owner or operator has complied with, and continues to 

comply with, Section 219.204(c)(2), 219.204(g)(2), or 219.204(h)(2), as 

applicable, or the alternative control options in Section 219.205 or 219.207, and 

all applicable requirements in Sections 219.211 and 219.218 of this Subpart.

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.211 Recordkeeping and Reporting 

a) The VOM content of each coating and the efficiency of each capture system and 

control device shall be determined by the applicable test methods and procedures 

specified in Section 219.105 of this Part to establish the records required under 

this Section. 

b) Any owner or operator of a coating line thatwhich is exempted from the 

limitations of Section 219.204 of this Subpart because of Section 219.208(a) or 

(b) of this Subpart shall comply with the following: 

1) For sources exempt from Section 219.208(a) of this Subpart, by a date 

consistent with Section 219.106 of this Part, the owner or operator of a 

coating line or group of coating lines referenced in subsection (b) of this 

Section shall certify to the Agency that the coating line or group of coating 

lines is exempt under the provisions of Section 219.208(a) of this Subpart. 

Such certification shall include: 

A) A declaration that the coating line is exempt from the limitations of 

Section 219.204 of this Subpart because of Section 219.208(a) of 

this Subpart; and 

B) Calculations thatwhich demonstrate that the combined VOM 

emissions from the coating line and all other coating lines in the 

same category never exceed 6.8 kg (15 lbs) per day before the 

application of capture systems and control devices. The following 

equation shall be used to calculate total VOM emissions: 
 ILLINOIS REGISTER 5431

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

   



m

j

n

i

e AiBi j T

1 1

where: 

Te = Total VOM emissions from coating lines each day before 

the application of capture systems and control devices in 

units of kg/day (lbs/day); 

 

m = Number of coating lines at the source that otherwise would 

be subject to the same subsection of Section 219.104 of 

this Part (because they belong to the same category, e.g., 

can coating); 

 

j = Subscript denoting an individual coating line; 

 

n = Number of different coatings as applied each day on each 

coating line; 

 

i = Subscript denoting an individual coating; 

 

Ai = Weight of VOM per volume of each coating (minus water 

and any compounds which are specifically exempted from 

the definition of VOM) as applied each day on each 

coating line in units of kg VOM/l (lbs VOM/gal); 

 

Bi = Volume of each coating (minus water and any compounds 

which are specifically exempted from the definition of 

VOM) as applied each day on each coating line in units of 

l/day (gal/day). The instrument or method by which the 

owner or operator accurately measured or calculated the 

volume of each coating as applied on each coating line 

each day shall be described in the certification to the 

Agency. 

2) For sources exempt under Section 219.208(b) of this Subpart, by March 

15, 1998, or upon initial start-up, the owner or operator of a coating line or 

a group of coating lines referenced in subsection (b) of this Section shall 
 ILLINOIS REGISTER 5432

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

certify to the Agency that the source is exempt under the provisions of 

Section 219.208(b) of this Subpart. Such certification shall include: 

A) A declaration that the source is exempt from the limitations of 

Section 219.204(l) of this Subpart because of Section 219.208(b) 

of this Subpart; and 

B) Calculations which demonstrate that the source meets the criteria 

of exemption because of Section 219.208(b) of this Subpart. 

3) For sources exempt under Section 219.208(a) of this Subpart, on and after 

a date consistent with Section 219.106 of this Part, the owner or operator 

of a coating line or group of lines referenced in this subsection shall 

collect and record all of the following information each day for each 

coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line; and 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

4) For sources exempt under Section 219.208(b) of this Subpart, on and after 

March 15, 1998, the owner or operator of a coating line or group of 

coating lines referenced in this subsection (b) shall collect and record all 

of the following information for each coating line and maintain the 

information at the source for a period of three years: 

A) The name and identification number of each coating as applied on 

each coating line; and 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied on each coating line on a 

monthly basis. 
 ILLINOIS REGISTER 5433

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

5) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a coating line or group of coating lines exempted from the 

limitations of Section 219.204 of this Subpart because of Section 

219.208(a) of this Subpart shall notify the Agency of any record showing 

that total VOM emissions from the coating line or group of coating lines 

exceed 6.8 kg (15 lbs) in any day before the application of capture systems 

and control devices by sending a copy of such record to the Agency 

within 30 days after the exceedance occurs. 

6) On and after March 15, 1998, any owner or operator of a source exempt 

from the limitations of Section 219.204(l) of this Subpart because of 

Section 219.208(b) of this Subpart shall notify the Agency if the source's 

VOM emissions exceed the limitations of Section 219.208(b) of this 

Subpart by sending a copy of calculations showing such an exceedance 

within 30 days after the change occurs. 

c) Any owner or operator of a coating line subject to the limitations of Section 

219.204 of this Subpart other than Section 219.204(a)(2) and (a)(3) of this 

Subpart and complying by means of Section 219.204 of this Subpart shall comply 

with the following: 

1) By a date consistent with Section 219.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance from 

an existing subject coating line from Section 219.205, Section 219.207, 

Section 219.215, or Section 219.216 of this Subpart to Section 219.204 of 

this Subpart; the owner or operator of a subject coating line shall certify to 

the Agency that the coating line will be in compliance with Section 

219.204 of this Subpart on and after a date consistent with Section 

219.106 of this Part, or on and after the initial start-up date. TheSuch

certification shall include: 

A) The name and identification number of each coating as applied on 

each coating line; 

B) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line; and
 ILLINOIS REGISTER 5434

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 219.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line;.

D) For coating lines subject to the limitations of Section 219.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line; and

E) For coating lines subject to the limitations of Section 219.204(g)(2) 

or 219.204(h)(2) of this Subpart, the application methods used to 

apply coatings on the subject coating line and the weight of VOM 

per volume of each coating (or the weight of VOM per volume of 

solids in each coating, as applicable) as applied each day on each 

coating line.

2) On and after a date consistent with Section 219.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 

each coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line; 

B) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line; 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 219.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line and certified product data sheets for 

each coating; and

D) On and after March 15, 1998, for wood furniture coating spray 

booths subject to the limitation of Section 219.204(l)(4)(A) of this 

Subpart, the weight of VOM per weight of solids in each strippable 
 ILLINOIS REGISTER 5435

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

spray booth coating as applied each day on each spray booth and 

certified product data sheets for each coating;.

E) For coating lines subject to the limitations of Section 219.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line, and certified 

product data sheets for each coating; and

F) For coating lines subject to the limitations of Section 219.204(g)(2) 

or 219.204(h)(2) of this Subpart, the weight of VOM per volume 

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line, and certified product data sheets for each coating.

3) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 219.204 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance from Section 219.204 to Section 219.205 or Section 

219.207 of this Subpart, the owner or operator shall comply with 

all requirements of subsection (d)(1) or (e)(1) below, respectively. 

Upon changing the method of compliance from Section 219.204 to 

Section 219.205 or Section 219.207 of this Subpart, the owner or 

operator shall comply with all requirements of subsection (d) or (e) 

of this Section, respectively. 

d) Any owner or operator of a coating line subject to the limitations of Section 

219.204 of this Subpart and complying by means of Section 219.205 of this 

Subpart shall comply with the following: 

1) By a date consistent with Section 219.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance for 

an existing subject coating line from Section 219.204 or Section 219.207 
 ILLINOIS REGISTER 5436

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

to Section 219.205 of this Subpart; the owner or operator of the subject 

coating line shall certify to the Agency that the coating line will be in 

compliance with Section 219.205 on and after a date consistent with 

Section 219.106 of this Part, or on and after the initial start-up date. 

TheSuch certification shall include: 

A) The name and identification number of each coating line which 

will comply by means of Section 219.205 of this Subpart. 

B) The name and identification number of each coating as applied on 

each coating line. 

C) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

D) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 219.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line. 

E) For coating lines subject to the limitations of Section 219.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line.

F) For coating lines subject to the limitations of Section 219.204(g)(2) 

or 219.204(h)(2) of this Subpart, the weight of VOM per volume 

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line.

GE) The instrument or method by which the owner or operator will 

accurately measure or calculate the volume of each coating as 

applied each day on each coating line. 
 ILLINOIS REGISTER 5437

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

HF) The method by which the owner or operator will create and 

maintain records each day as required in subsection (d)(2) of this 

Section. 

IG) An example of the format in which the records required in 

subsection (d)(2) of this Section will be kept. 

2) On and after a date consistent with Section 219.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 

each coating line and maintain the information at the source for a period of 

three years: 

A) The name and identification number of each coating as applied on 

each coating line. 

B) The weight of VOM per volume and the volume of each coating 

(minus water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each coating 

line. 

C) On and after March 15, 1998, for coating lines subject to the 

limitations of Section 219.204(l)(2)(A) or (B) of this Subpart, the 

weight of VOM per weight of solids in each coating as applied 

each day on each coating line. 

D) For coating lines subject to the limitations of Section 219.204(c)(2) 

of this Subpart, the weight of VOM per weight of solids (or the 

weight of VOM per weight of coatings, as applicable) in each 

coating as applied each day on each coating line.

E) For coating lines subject to the limitations of Section 219.204(g)(2) 

or 219.204(h)(2) of this Subpart, the weight of VOM per volume

of each coating (or the weight of VOM per volume of solids in 

each coating, as applicable) as applied each day on each coating 

line.
 ILLINOIS REGISTER 5438

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

FD) The daily-weighted average VOM content of all coatings as 

applied on each coating line as defined in Section 219.104 of this 

Part. 

3) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 219.205 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 219.205 to Section 

219.204 or Section 219.207 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c)(1) or (e)(1) of 

this Section, respectively. Upon changing the method of 

compliance with this Subpart from Section 219.205 to Section 

219.204 or Section 219.207 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c) or (e) of this 

Section, respectively. 

e) Any owner or operator of a coating line subject to the limitations of Section 

219.207 and complying by means of Section 219.207(c), (d), (e), (f), (g), or (h), or 

(k) of this Subpart shall comply with the following: 

1) By a date consistent with Section 219.106 of this Part, or upon initial startup of a new coating line, or upon changing the method of compliance for 

an existing coating line from Section 219.204 or Section 219.205 to 

Section 219.207 of this Subpart, the owner or operator of the subject 

coating line shall perform all tests and submit to the Agency the results of 

all tests and calculations necessary to demonstrate that the subject coating 

line will be in compliance with Section 219.207 of this Subpart on and 

after a date consistent with Section 219.106 of this Part, or on and after the 

initial start-up date. 

2) On and after a date consistent with Section 219.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 

line shall collect and record all of the following information each day for 
 ILLINOIS REGISTER 5439

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

each coating line and maintain the information at the source for a period of 

three years: 

A) The weight of VOM per volume of coating solids as applied each 

day on each coating line, if complying pursuant to Section 

219.207(b)(2) of this Subpart. 

B) Control device monitoring data. 

C) A log of operating time for the capture system, control device, 

monitoring equipment and the associated coating line. 

D) A maintenance log for the capture system, control device and 

monitoring equipment detailing all routine and non-routine 

maintenance performed including dates and duration of any 

outages. 

3) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 219.207 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 219.207 to Section 

219.204 or Section 219.205 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c)(1) or (d)(1) of 

this Section, respectively. Upon changing the method of 

compliance with this Subpart Part from Section 219.207 to Section 

219.204 or Section 219.205 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c) or (d) of this 

Section, respectively. 

f) Any owner or operator of a primer surfacer operation or topcoat operation subject 

to the limitations of Section 219.204(a)(2) or (a)(3) of this Subpart shall comply 

with the following: 
 ILLINOIS REGISTER 5440

 10 

POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

1) By a date consistent with Section 219.106 of this Part, or upon initial startup of a new coating operation, the owner or operator of a subject coating 

operation shall certify to the Agency that the operation will be in 

compliance with Section 219.204 of this Subpart on and after a date 

consistent with Section 219.106 of this Part, or on and after the initial 

start-up date. TheSuch certification shall include: 

A) The name and identification number of each coating operation 

which will comply by means of Section 219.204(a)(2) and (a)(3) of 

this Subpart and the name and identification number of each 

coating line in each coating operation. 

B) The name and identification number of each coating as applied on 

each coating line in the coating operation. 

C) The weight of VOM per volume of each coating (minus water and 

any compounds which are specifically exempted from the 

definition of VOM) as applied each day on each coating line. 

D) The transfer efficiency and control efficiency measured for each 

coating line. 

E) Test reports, including raw data and calculations documenting the 

testing performed to measure transfer efficiency and control 

efficiency. 

F) The instrument or method by which the owner or operator will 

accurately measure or calculate the volume of each coating as 

applied each day on each coating line. 

G) The method by which the owner or operator will create and 

maintain records each day as required in subsection (f)(2) of this 

Sectionbelow. 

H) An example format for presenting the records required in 

subsection (f)(2) of this Sectionbelow. 

2) On and after a date consistent with Section 219.106 of this Part, or on and 

after the initial start-up date, the owner or operator of a subject coating 
 ILLINOIS REGISTER 5441

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

operation shall collect and record all of the following information each 

day for each topcoat or primer surfacer coating operation and maintain the 

information at the source for a period of three years: 

A) All information necessary to calculate the daily-weighted average 

VOM emissions from the coating operations in kg (lbs) per 1 (gal) 

of coating solids deposited in accordance with the proposal 

submitted, and approved pursuant to Section 219.204(a)(2) or 

(a)(3) of this Subpart including: 

i) The name and identification number of each coating as 

applied on each coating operation. 

ii) The weight of VOM per volume of each coating (minus 

water and any compounds which are specifically exempted 

from the definition of VOM) as applied each day on each 

coating operation. 

B) If a control device or devices aredevice(s) is used to control VOM 

emissions, control device monitoring data; a log of operating time 

for the capture system, control device, monitoring equipment and 

the associated coating operation; and a maintenance log for the 

capture system, control device and monitoring equipment, 

detailing all routine and non-routine maintenance performed 

including dates and duration of any outages. 

3) On and after a date consistent with Section 219.106 of this Part or on and 

after the initial start-up date, the owner or operator of a subject coating 

operation shall determine and record the daily VOM emissions in kg (lbs) 

per 1 (gal) of coating solids deposited in accordance with the proposal 

submitted and approved pursuant to Section 219.204(a)(2) or (a)(3) of this 

Subpart within 10 days from the end of the month and maintain this 

information at the source for a period of three years. 

4) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a subject coating operation shall notify the Agency in the 

following instances: 
 ILLINOIS REGISTER 5442

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POLLUTION CONTROL BOARD 

NOTICE OF ADOPTED AMENDMENTS 

A) Any record showing a violation of Section 219.204(a)(2) or (a)(3) 

of this Subpart shall be reported by sending a copy of such record 

to the Agency within 15 days from the end of the month in which 

the violation occurred. 

B) The owner or operator shall notify the Agency of any change to the 

operation at least 30 days before the change is effected. The 

Agency shall determine whether or not compliance testing is 

required. If the Agency determines that compliance testing is 

required, then the owner or operator shall submit a testing proposal 

to the Agency within 30 days and test within 30 days of the 

approval of the proposal by the Agency and USEPA. 

g) On and after a date consistent with Section 219.106(c) of this Part, or on and after 

the initial start-up date, whichever is later, the owner or operator of a coating line 

subject to the requirements of Section 219.218 of this Subpart shall comply with 

the following:

1) By May 1, 2011, or upon initial start-up, whichever is later, submit a 

certification to the Agency that includes a description of the practices and 

procedures that the source will follow to ensure compliance with the 

applicable requirements in Section 219.218 of this Subpart;

2) Notify the Agency of any violation of Section 219.218 of this Subpart by 

providing a description of the violation and copies of records documenting 

the violation to the Agency within 30 days following the occurrence of the 

violation; and

3) Maintain at the source all records required by this subsection (g) for a 

minimum of three years from the date the document was created and make 

those records available to the Agency upon request.

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.212 Cross-Line Averaging to Establish Compliance for Coating Lines 

a) On and after March 15, 1996, any owner or operator of a coating line subject to 

the limitations set forth in Section 219.204 of this Subpart, except coating lines 

subject to the limitations in Section 219.204(c)(2), (g)(2), or (h)(2) of this 
 ILLINOIS REGISTER 5443

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NOTICE OF ADOPTED AMENDMENTS 

Subpart, and with coating lines in operation prior to January 1, 1991 ("preexisting coating lines"), may, for pre-existing coating lines only, elect to comply 

with the requirements of this Section, rather than complying with the applicable 

emission limitations set forth in Section 219.204, if an operational change of the 

type described below has been made after January 1, 1991, to one or more preexisting coating lines at the source. An operational change occurs when a preexisting coating line is replaced with a line using lower VOM coating for the 

same purpose as the replaced line ("replacement line"). A source electing to rely 

on this Section to demonstrate compliance with the requirements of this Subpart 

shall operate pursuant to federally enforceable permit conditions approved by the 

Agency and USEPA. 

b) An owner or operator of pre-existing coating lines subject to a VOM content 

limitation in Section 219.204 of this Subpart and electing to rely on this Section to 

demonstrate compliance with this Subpart must establish, by use of the equations 

in subsection (d) of this Section, that the calculated actual daily VOM emissions 

from all participating coating lines, as defined below, are less than the calculated 

daily allowable VOM emissions from the same group of coating lines. For any 

pre-existing coating line to be aggregated for the purposes of Section 219.212, 

219.213, or 219.214 of this Subpart ("participating coating lines"), the source 

must establish that: 

1) All coatings applied on the participating coating line shall, at all times, 

have a VOM content less than or equal to the applicable VOM content 

limitation for such coating listed in Appendix H of this Part; and 

2) On the date the source elects to rely on this Section to demonstrate 

compliance with this Subpart, all coatings applied on the participating 

coating line are not already in compliance with the VOM content 

limitation for such coating effective on or after March 15, 1996; or the 

participating coating line is a replacement line, as defined in subsection (a) 

of this Section with an operational change occurring on or after January 1, 

1991. 

c) Notwithstanding subsection (a) of this Section, any owner or operator of a coating 

line subject to the limitations set forth in Section 219.204 of this Subpart and 

electing to rely on this Section to demonstrate compliance with this Subpart, may 

also include as a participating coating line, until December 31, 1999, only, any 

replacement line that satisfies all of the following conditions: 
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1) The replacement line is operated as a powder coating line; 

2) The replacement line was added after July 1, 1988; and 

3) The owner or operator also includes as a participating coating line one or 

more coating lines that satisfy the criteria of a replacement line, as 

described in subsection (a) of this Section. 

d) To demonstrate compliance with this Section, a source shall establish the 

following: 

1) An alternative daily emission limitation shall be determined for all 

participating coating lines at the source according to subsection (d)(2) of 

this Section. All participating coating lines shall be factored in each day 

to demonstrate compliance. Provided compliance is established pursuant 

to the requirements in this subsection, nothing in this Section requires 

daily operation of each participating line. Actual daily emissions from all 

participating coating lines (Ed) shall never exceed the alternative daily 

emission limitation (Ad) and shall be calculated by use of the following 

equation: 





n

i

Ed ViCi

1

where: 

Ed = Actual daily VOM emissions from participating coating lines in 

units of kg/day (lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied by all participating coating 

lines at the source; 

Vi = Volume of each coating applied for the day in units of l/day 

(gal/day) of coating (minus water and any compounds which are 

specifically exempted from the definition of VOM); and 
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Ci = The VOM content of each coating as applied in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the definition 

of VOM). 

2) The alternative daily emission limitation (Ad) shall be determined for all 

participating coating lines at the source on a daily basis as follows: 

Ad  Ai  Ap

where Ai and Ap are defined in subsections (d)(2)(A) and (d)(2)(B) of this 

subsection. 

A) The portion of the alternative daily emissions limitation for 

coating operations at a source using non-powder coating (Ai) shall 

be determined for all such participating non-powder coating lines 

on a daily basis as follows: 

 

  i i

i i

i

n

i

i i D L

D C A V L 

  1

where: 

Ai = The VOM emissions allowed for the day in units of 

kg/day (lbs/day); 

i = Subscript denoting a specific coating applied; 

n = Total number of coatings applied by all participating 

coating lines at the source; 

Ci = The VOM content of each coating as applied in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); 

Di = The density of VOM in each coating applied. For the 

purposes of calculating Ai, the density is 0.882 kg VOM/l 

VOM (7.36 lbs VOM/gal VOM); 
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Vi = Volume of each coating applied for the day in units of l 

(gal) of coating (minus water and any compounds which 

are specifically exempted from the definition of VOM); 

and 

Li = The VOM emission limitation for each coating applied, as 

specified in Section 219.204 of this Subpart, in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM). 

B) The portion of the alternative daily emission limitation for coating 

operations at a source using powdered coating (Ap) shall be 

determined for all such participating powder coating lines at the 

source on a daily basis as follows: 

     

m

h

n

j j j

j j j h

p D L

V L D K

A

1 1

where: 

Ap = The VOM emissions allowed for the day in units of kg/day 

(lbs/day); 

h = Subscript denoting a specific powder coating line; 

j = Subscript denoting a specific powder coating applied; 

m = Total number of participating powder coating lines; 

n = Total number of powder coatings applied in the participating 

coating lines; 

Dj = The assumed density of VOM in liquid coating, 0.882 kg 

VOM/l VOM (7.36 lbs VOM/gal VOM); 

Vj = Volume of each powder coating consumed for the day in 

units of l (gal) of coating; 
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Lj = The VOM emission limitation for each coating applied, as 

specified in Section 219.204 of this Subpart, in units of kg 

VOM/l (lbs VOM/gal) of coating (minus water and any 

compounds which are specifically exempted from the 

definition of VOM); and 

K = A constant for each individual coating line representing the 

ratio of the volume of coating solids consumed on the liquid 

coating system which has been replaced to the volume of 

powder coating consumed on the replacement line to 

accomplish the same coating job. This value shall be 

determined by the source based on tests conducted and 

records maintained pursuant to the requirements of Section 

219.213 of this Subpart demonstrating the amount of coating 

solids consumed as both liquid and powder. Tests methods 

and recordkeeping requirements shall be approved by the 

Agency and USEPA and contained in the source's operating 

permit as federally enforceable permit conditions, subject to 

the following restrictions: 

 i) K cannot exceed 0.9 for non-recycled powder 

coating systems; or 

 ii) K cannot exceed 2.0 for recycled powder coating 

systems. 

(Source: Amended at 34 Ill. Reg. 5392, effective March 23, 2010) 

Section 219.218 Work Practice Standards for Paper Coatings, Metal Furniture Coatings, 

and Large Appliance Coatings

a) On and after May 1, 2011, every owner or operator of a source subject to the 

requirements of Section 219.204(c) of this Subpart shall:

1) Store all VOM-containing cleaning materials in closed containers;

2) Ensure that mixing and storage containers used for VOM-containing 

materials are kept closed at all times except when depositing or removing 

those materials;
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3) Minimize spills of VOM-containing cleaning materials;

4) Convey VOM-containing cleaning materials from one location to another 

in closed containers or pipes; and

5) Minimize VOM emissions from the cleaning of storage, mixing, and 

conveying equipment.

b) On and after May 1, 2011, every owner or operator of a source subject to the 

requirements of Section 219.204(g) or 219.204(h) of this Subpart shall:

1) Store all VOM-containing coatings, thinners, coating-related waste 

materials, cleaning materials, and used shop towels in closed containers; 

2) Ensure that mixing and storage containers used for VOM-containing 

coatings, thinners, coating-related waste materials, and cleaning materials 

are kept closed at all times except when depositing or removing those

materials; 

3) Minimize spills of VOM-containing coatings, thinners, coating-related 

waste materials, and cleaning materials, and clean up spills immediately; 

4) Convey VOM-containing coatings, thinners, coating-related waste 

materials, and cleaning materials from one location to another in closed 

containers or pipes;

5) Minimize VOM emissions from the cleaning of storage, mixing, and 

conveying equipment; and

6) Apply all coatings using one or more of the following application 

methods:

A) Electrostatic spray;

B) High volume low pressure (HVLP) spray;
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C) Flow coating. For the purposes of this subsection (b), flow coating 

means a non-atomized technique of applying coating to a substrate 

with a fluid nozzle with no air supplied to the nozzle;

D) Roll coating;

E) Dip coating, including electrodeposition. For purposes of this 

subsection (b), electrodeposition means a water-borne dip coating 

process in which opposite electrical charges are applied to the 

substrate and the coating. The coating is attracted to the substrate 

due to the electrochemical potential difference that is created;

F) Brush coating, if subject to the requirements of Section 

219.204(h); or

G) Another coating application method capable of achieving a transfer 

efficiency equal to or better than that achieved by HVLP spraying, 

if such method is approved in writing by the Agency.

(Source: Added at 34 Ill. Reg. 5392, effective March 23, 2010)