ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 NORTH GRAND AVENUE EAST, P.O. BOX 19276, SPRINGFIELD, ILLINOIS 62794-9276 • (217) 782-2829 

PAT QUINN, GOVERNOR LISA BONNETT, DIRECTO!r~;:;-:;:;::--;:::::;-;:--:::-:----

,{D)~ © lli: a w ~~m 217/785-4140 

217/782-9143 (TDD) 

August 18, 2014 

RECEIVED 

AUG 2 0 2014 

Certified Mail 

/JJ] AUG 2 6 1014 iJlJ 

AIR ENFORCEM2NT CR/~NCH U.S. EP/\ REGION 5 

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OFFICE OF REGIONAL ADMINISTRATOR Return Receipt Requested 

7012 0470 0001 3000 9378 

Dr. Susan Hedman 

Regional Administrator 

U.S. Environmental Protection Agency, Region 5 

77 West Jackson Boulevard (R-19J) 

Chicago, IL 60604-3507 

Re: State Implementation Plan Revision 

Dear Dr. Hedman: 

Pursuant to Section 169A of the Clean Air Act ("CAA'') (42 U.S.C. § 7491) and Section 4 ofthe Illinois 

Environmental Protection Act ( 415 ILCS 5/4 ), the Illinois Environmental Protection Agency ("Agency") 

submits the enclosed revision to the Illinois State Implementation Plan ("SIP"). This revision has been 

prepared as a result of the Illinois Pollution Control Board ("Board") granting a variance to Midwest 

Generation, LLC ("Midwest Generation"). The Agency requests that the variance be approved as a 

revision to the Illinois SIP. 

On April4, 2013, the Board granted Midwest Generation, with power plants in Cook, Will, Tazewell, 

and Lake Counties, a variance from portions of the Illinois Combined Pollutant Standard ("CPS"). 

Midwest Generation, LLC v. Illinois Environmental Protection Agency, PCB 13-024. Specifically, the 

Board granted Midwest Generation relief from the system-wide sulfur dioxide ("S02") emission rates 

set forth in 35 Ill. Adm. Code 225.295(b) from January 1, 2015, to December 31, 2016, and with respect 

to its Waukegan Generating Station, relief from the requirement set forth in 35 Ill. Adm. Code 

225.296(a)(2) regarding installation of certain S02 control equipment on Waukegan Unit 8 by December 

31, 2014; the Board granted Midwest Generation a five-month delay in such requirement, to May 31, 

2015. 

The portions of the CPS referenced above are approved rules in the Illinois SIP and were submitted to 

address the visibility protection requirements of Section 169A of the CAA, 42 U.S.C. § 7491 , and the 

Regional Haze Rule, as codified in 40 CFR § 51.308. See, 77 Fed. Reg. 39943 (July 6, 2012). As 

Midwest Generation sought relief from these provisions of the CPS and such relief was granted by the 

Board, the variance must be submitted for approval as a SIP revision addressing the visibility 

requirements under the CAA and the Regional Haze Rule. 

4302 N. Main St., Rockford,ll6 11 03 (815)987-7760 

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

2125 S. First St., Chompaign,ll 61820 (217)278-5800 

2009 Mall St., Collinsville, ll 62234 (6 18)346-5120 

9511 Harrison St., De s Plaines,ll60016 (847)294·4000 

5 407 N. University St., Arbor 11 3, Pe oria, ll616 14 (309)693-5462 

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

100 W. Randolph, Suite 11-300, Chicago, ll 60601 (312)814-6026 

PlEASE P RINT ON RECYCUD PAPER 
As evident from the approval of Illinois' Regional Haze plan, the CPS provides emission reductions well 

in excess of simply implementing Best Available Retrofit Technology ("BART") on subject units. 

Taking into account the variance granted to Midwest Generation, the reductions from Illinois' plan 

continue to provide significantly greater emission reductions for S02 than conservative defmitions of 

BART for the BART-subject units. (See Agency's Technical Support Document for SIP Submittal, 

enclosed). 

The Agency provided public notice of the SIP revision, offering the public an opportunity to comment 

and to request a public hearing. The Agency did not receive a request for a public hearing, and therefore 

no hearing was held. Likewise, the Agency did not receive any public comments. 

In order to assist with your review of this plan revision submittal, the following documents are enclosed 

(one hard copy and one exact duplicate electronic copy on discs): 

I) Midwest Generation's Petition for Variance (November 30, 2012) 

2) Agency's Appearance and Certification of Publication (December 13, 2012) 

3) Board Order Accepting Petition for Hearing (December 20, 2012) 

4) Notice of Board Hearing (December 21, 2012) 

5) Board Certificate of Publication I 

6) Board Certificate of Publication II 

7) Board Certificate of Publication III 

8) Board Certificate of Publication IV 

9) Board Certificate of Publication V 

10) Board Certificate of Publication VI 

11) Agency's Recommendation (January 10, 2013) 

12) Transcript of Hearing (January 29, 2013) (partial--full transcript omitted) 

13) Hearing Officer Order Verifying Hearing Held (January 31, 2013) 

14) Final Board Order Granting Variance (April4, 2013) 

15) Concurring Opinion by Board Member Glosser (April4, 2013) 

16) Midwest Generation's Certificate of Acceptance (May 17, 2013) 

17) Notice of Public Infonnation, 37 Ill. Reg. 15552 (September 27, 2013) 

18) Verification ofNo Public Hearing (November 4, 2013) 

19) Agency's Technical Support Document for SIP Submittal 

The complete docket for the rulemaking is available on the Board's website at 

http://www .ipcb.state.il. us/COO Llexternal/Case View .aspx?referer=results&case= 1453 6. 

If further information is required, please contact Dana Vetterhoffer at 217/782-5544 . 

. S7ly, 

~~~ Director 

En c. 

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