# 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 

### ) ) 

### ) ) ) ) ) ) R10- ) 

# 0 (Rulemlling-Air)



### RECEIVED

CLERK'S OFFICE



## OCT 23 2009

STATE OF IlliNOIS Po!lution Control Board

1. Notice of Filing

2. Appearance of Dana Vetterhoffer, Assistant Counsel for the Il1inois Environmental Protection Agency

3. Proposal of Regulations by Director Douglas P. Scott



### 4. Certification of Required Rule



### 5. Certification of Origination

6. Agency Analysis of Economic and Budgetary Effects

7. Motion for Waiver of Copy Requirements

8. Fast Track Rulemaking Cover Sheet

9. Statement of Reasons

10. Proposed Amendments to 

### 35 Ill. Adm. Code Parts 218 and 219

II. Technical Support Document for 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 of Air Quality Planning and Standards, Research Triangle Park, NC, September 2007.

1Control Techniques Guidelinesfor Metal Furniture Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2007.

Control Techniques Guidelinesfor Large Appliance Coatings, United States Environmental Protection Agency, Office of Air 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 of Service

14. First Notice Forms

15. Disk in Microsoft WORD containing Agency's Proposed Amendments to Parts 218 and 219, and First Notice Forms

2

### 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: 

### RIO- 

# 10 (Rulemaking-Air) ) ) ) ) ) ) ) ) 

### 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 

## m CONSUMER & 

### COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 218 and 219," MOTION FOR W AJVER OF COPY REQUIREMENTS, and APPEARANCE of the illinois Environmental Protection Agency, a copy of which is herewith served upon you. Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

## By:~~~~Zi!tJ.¥A;L Dana Vetterhoffer Assistant Counsel Division of Legal Counsel

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: ) ) REASONABLY AVAlLABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLA TILE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP III CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) T035 ILL. ADM. CODE218 and 219 )



### APPEARANCE R10- / 

# D (Rulemaking-Air) 

### <J:f&.;c

## CLER/(~O'''EtJ) F'FICI: 

# ocr 23 20U9 STATE 0 

### "Ollution CF 

### IL1..JNOIS 

### antral Board

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

Environmental Protection Agency.
Respectfully submi tted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# By~tkdak~_ Dana Vetterhoffer Assistant Counsel Division of Legal 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 ) 

### ) ) 

### ) ) ) 

### ) ) 

### RIO- 

# 10 (Rulemaking-Air)



### 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) 782-5544BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AV AILABLE CONTROL TECHNOLOGY (RI\CT) FOR VOLA TILE ORGANIC MATERIAL EMISSIONS FROM GROUP III CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 218 and 219 ) ) ) ) ) ) ) ) RIO- 

# /0 (Rulemaking-Air) 

### !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 I 82(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 ("V OM") emissions in

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

Standard. Section I 72(c)(I) of the 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) of the 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).

1The 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 of Legal Counsel

DATED: October 15,2009

1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

2BEFORE 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 ) ) ) ) ) ) ) ) R10- 

### J 

# 0 (Rulemaking-Air)

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 of Legal Counsel

DATED: October 15, 2009

1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544Agency: 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 of the 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 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 first occur and the estimated dollar amount of the 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 new lv-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 ) ) ) ) ) ) ) ) 

### RIO- / 

# b (Rulemaking-Air)

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 of the regulatory proposal including all

documents relied upon, and waive the requirement that the Illinois EPA provide copies of certain

documents relied upon. In support of its Motion, Illinois EPA states as follows:

1. Section 102.200 of the 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 of the 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 of the documents.

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

provide information supporting the proposal. 415 ILCS 5/27(a). Two of the 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

1the requirement that the Illinois EPA provide copies of such 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 of Air Quality Planning and Standards, Researeh Triangle Park, NC, September 2007.

b. Control Techniques Guidelinesfor Metal Furniture Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2007.

c. Control Techniques Guidelinesfor Large Appliance Coatings, United States Environmental Protection Agency, Office of Air 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 EP A moves that the Board waive the requirement that the

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

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

documents in its proposal.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By: L Dana Vetterhoffer Assistant Counsel Division of Legal Counsel

2

# 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 ) ) ) ) ) ) ) ) 

### RIO- 

# /0 (Rulemaking-Air)

### ~I£:c 

## OLI:Fik'*O'VI£O

. ,"Flce 

# ocr 23 2009 STArE 0" POI/ution 

### C 

### ILLINOiS Ontrol BOara

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

Statement of Reasons to the Illinois Pollution Control Board ("Board") pursuant to

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

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

regulations. These regulations are proposed to control emissions of Volatile Organic

Material ("V OM"), 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 of the 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 of the 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

1nonattailll11ent 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) of the 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 1 5, 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 of those 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 of sunlight. Ground-level

2ozone is a major component of smog. 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, USEP A 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) of the 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).

3The CAA requires that USEP A then either regulate YOM emissions from such

categories or issue a CTG in lieu of a national regulation if the 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 1 lb(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 US EPA issued final CTGs for three Group III Consumer

and Commercial Product Categories. The USEP A 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 non attainment

(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 1 72(c)(l) of the 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 of the 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

4sources in the area as may be obtained through the adoption, at a minimum, ofreasonably available control technology) and shall provide for attainment of the 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) of this title with respect to each of the 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 of the 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.



### 5C. 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 USEP A "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 of the 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 if Illinois 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, if Illinois fails to make an adequate SIP submission, USEPA

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

of the CAA. 42 U.S.C. 

### § 7410(c)(l). Illinois EPA's submittal of its 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



### 6and 182 of the 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 of the 1997 ozone
NAAQS, regardless of whether the YOM reductions obtained by the SIP revisions are
actually necessary to achieve attainment of the 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 US EPA confirmed, "[B]efore EPA can act favorably upon any State

redesignation request, the statutorily-mandated control programs of section 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 of Appeals 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).



### 7however, 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 of this 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



### 8The 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 of readily 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 of the proposed rule and copies of the pertinent CTGs on its

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

9via 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 EP A also proposes adding limitations regarding coating application methods.

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

35 Ill. Adm. Code 218/219
Subpart A: General Provisions

Section 218/219.106 Compliance Dates

The Illinois EP A 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.

10Subpart 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.

11Section 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).

12Section 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 of solids 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 of solids 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 of YOM 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

13complying 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 of YOM-containing

materials, convey such materials from one location to another in closed containers or
pipes, and minimize YOM emissions from the cleaning of storage, mixing, and
conveying equipment.

14DATED: 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

15

# I I I 

# I I I I I I I 

# I I I I I I I 

# I I I I I I I 

# I I I I I I I 

# I I

# 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 In trod u cti 0 

### n 7
2.0 Process Description and Source of YOM Emissions 9

2 

### .1 Paper, Film, and Foil Coatings 9 2_2 Large App 

### Ii ance Coatings I0
2_3 Metal F umi ture Coatings 11

3.0 Tech n ica I F eas ib ility of Con trols 

## .1 3

3.1 Paper, Film, and Foil Coatings 

## .1 3

3.2 Large App I iance Coati n gs 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 Fumi turc 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 App liance Coatings 26

4.3 Metal Fumi ture Coatings 2 7
5.0 Exis ti ng and Proposed Regu Iations 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 F umi ture Coatings .3 0
5.2 Proposed Regul ati ons .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 of Coating 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 EP A NAA NAAQS NO x 

### 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 coatings 2 ; 

### large appliance coatings 3 ; 

### and metal fumiture coatings 4

• 

### As a result, Illinois Environmental protection Agency ("Illinois EPA") is proposing
the regulations to control YOM emissions from these categories of sources in the Chicago and

Metro-East nonattainment areas ("NAAs"). The ,Chicago NAA includes the counties of Cook, 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 of reductions 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 of the CAA 1

, 

### 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 of Jersey, 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 Coatings 2 

### 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 of solvent 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 of the 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 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. 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 CTG 2 

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

9

### coating curing/drying, and cleaning, About 90% of the 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 coatings 3

.



### 10

### Primary sources of YOM emissions evolve from the coating application (prime, single or topcoat application)/flash-off and drying/curing of the 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 cleaners 3



### 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 of the 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 of the volatile contents of the 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 emissions 4

.



### 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-V OM coatings or coatings

with no solvent do not meet the performance requirements of some 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 coatings 2



### 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 of the 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 of storage, 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 coatings 3

.



### 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 of mass ofVOM per volume of coating (excluding water and exempt compounds, as applied) and Table 3 specifies the equivalent limits in terms of mass ofVOM per
volume of solids, 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-V OM 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 of solvents during cleaning of storage, 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 of some 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 coatings 4

.



### 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 of the 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 of YOM-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 of which 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 of solids, respectively.

These YOM content limits can be met through daily within-coating unit averaging (averaging the
YOM content of materials used on a single surface coating unit each day). In addition, the U.S.

EPA is recommending that affected sources utilize one or more of the 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 of reducing 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 of storage, 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% of the 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 of the 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 of implementing 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 of HAP 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 of YOM reduced, and a total annual cost of the 1,000
tpy of emissions reduction to be $500,000 3



### 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 of these 456 facilities, it was estimated that there were about 289 facilities in ozone NAAs,
and that 143 of those 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 of facilities 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. Code 5 

### 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) of solids 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 Y OMllb coatings)

Affected sources may use add on capture and control systems to comply with the YOM content
limits of the coatings. Illinois EPA is proposing to increase the overall control efficiency
standards to 90 percent from the existing 81 percent overall control efficiency of the 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 of storage, 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 of these 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 of section 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 of section 3.2.1 contains the equivalent
emission limits expressed in mass/volume of solids.

The proposed regulations require the use of one or more of the following application methods:
electrostatic application, HVLP spray, flow coat, roller coat, dip coat including electrodeposition,

or other coating application method, with approval of the 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 of the 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 of storage, 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 of the 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 2ILLINOIS POLLUTION CONTROL BOARD November 5, 2009

IN THE MATTER OF: ) ) REASONABLY AV AlLABLE 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 of the 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 of Copy 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 of the 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 of strict 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 of the 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 of three 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 of receiving 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 of the first day of the first hearing and shall be devoted to presentation of testimony, 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 of the 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 "if the 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, "if the 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 of3

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 of the 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 of such documents." Mot. at 1-2. The Agency states that it has provided the Board copies of three other documents on which it directly relied in drafting its proposal. !d. at 2 (listing three CTGs).

Section 101.500(d) of the 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 of the 14 day response period

.... " 35 Ill. Adm. Code 1 01.500(d).

As noted above, Section 28.5 of the Act requires the Board's rulemaking activities to follow a series of strict 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 of the 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 of the CAA and the Act.

ORDER

The Board directs the Clerk to cause the publication of the 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 3ILLINOIS 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 DAyo TO-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 COMPLETE2

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 of the Environmental Protection Act (Act). See Public Act 96-0308, eff. Aug. 11, 2009 (P A 96-0308) (reenacting repealed Section 28.5). That provision requires the Board to proceed toward adoption ofthe proposed regulation by meeting a series of strict 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 of the rule and shall be confined to testimony by and questions of the 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 of the rule, the United States Environmental Protection Agency has not informed the Board of any unresolved objection to that agrced portion of the rule, and no other interested party contests the agreed portion of the 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 of the first day of the 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 of the 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 if the 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 of the 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 of the proposal if no third hearing is held and no later than 150 days if the third hearing is held. If the 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 of no 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 of Commerce 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) of the 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 of the Act, participants of record will be the individuals on the service list. 35 

## m. Adm. Code I 02.422(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 of which lists 24 potentially affected sources. TSD at 34-35. The Board begins this rulemaking proceeding by including in the Notice List each of the 24 sources listed in Table 11 of the Agency's TSD. While the Board will mail a copy of the Board's November 5, 2009, order and this hearing officer order to each of those 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 of the 24 entities listed by the Agency iu Table II of its TSD and to each of which 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 of all 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 of serving 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 of the 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 of 4:30 PM on Tuesday, November 24, 2009. Persons wishing to pre-file testimony for the first hearing may obtain a copy of the service list by contacting the hearing officer after 9:30 AM

on Wednesday, November 25, 2009. Because of the 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 of serving 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 of business 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 of the service list by contacting the hearing offIcer after 9:30 AM

on Wednesday, December 23,2009. Because of the 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 of serving 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 of the 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 of serving 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 6060 I (312) 814-6085 (312) 814-3669 (fax) foxt@ipcb.state.il.us7

ATTACHMENT A

To Hearing Officer Order of November 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 606018

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 Laboratori es 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 A very Dennison 902 F eehanville 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 

## 0 J2009

STATE OF ILLINOIS 

### Pollution Control Board 

# ILLINOIS POLLUTION CONTROL BOARD

Since 1998, Section 27(b) of the 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 of the 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 of the proposed regulations by meeting a series of strict 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 of Commerce and Economic Opportunity (fonnerly the Department of Commerce and Community Affairs) conduct a study of the economic impact of the proposed rules. The Department may within 30 to 45 days of such request produce a study of the 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 of the proposed niles on employment levels, commercial produbtivity, the economic growth of small businesses with 100 or less employees, and the State's overall economy, and c) the cost per unit of pollution 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 of those 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 of the Board

# B 5

### i 

# V olume 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 sati sfy 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) 1 0:00 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 C ontrol 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 af fected : 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 S tate 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 6CO-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 

## 9 2009
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 of the following:

Municipality County Township Other Unit of Local 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: If the 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 of the rulernaking? (please be specific)

5. Please explain why the policy objectives of this 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 1 9 2009

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 TherriaultSTATE 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 of the following:
Municipality County Township Other Unit of Local 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: If the 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.

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

_
If yes, please list these alternatives and explain why they were rejected.

4. What are the policy obj ectives of the 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 AV AILABLE 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 of the Pollution Control Board the TESTIMONY OF YOGINDER MAHAJAN of the Illinois Environmental Protection Agency, copies of which arc herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By:C2'y,1"4o

# ~4 Dana Velterhoffer Assistant Counsel Division of Legal 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 of Air of the 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 of Engineering

Degree in Mechanical Engineering from Bhopal University at Bhopal, India.

As part of my regular duties .in the Air Quality Planning Section, I have been involved

with preparing emission estimates for various source categories used in the development

of the 1990 ozone season weekday emissions inventories; evaluating control technologies

applicable to volatile organic material ("VOM") emissions sources in preparation of the

Rate-of-Progress plans for the Chicago and St. Louis ozone nonattainment areas; and

assisting in the development of regulations 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 of the Clean Air Act ("CAA'') requires that state implementation plans

("SIPs") for non attainment 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 I 82(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 of meeting by the application of control 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 of recommended 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 of mass 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 of mass 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 of solids (0.20

Ib/lb of solids) 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 of mass ofVOM

per volume of coating 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 of solids 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 of the 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 of the 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 staff reviewed 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 of the proposed rule and copies of the

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 YO GINDER 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 of Legal 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 of Environmental Enforcement Office of the 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 MA TTER OF:

REASONABL Y 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 ) ) ) ) ) ) ) ) R10-10 (Rulemaking-Air)

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 of the 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 ) ) ) ) ) ) ) ) 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 of its 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 ("V OM")

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) of this 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 sf tHis 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**~tG** and 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 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 presslU·e (HVLP) spray;


## Cl 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 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. if subject to the requircments of Section 2 

### J 8.204(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 2I 9.204(g) or 219.204(h) of this 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 of storage, 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 of the 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 of this Part. In addition, SCreen printing on paper is not rcgulated as paper coating, but is regulatcd under Subpart TT of this 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 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 rcgulated 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 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 of scratches

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 of Legal 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 ) ) ) ) ) ) ) ) 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 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

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 of Enviromnental Enforcement Office of the 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 10Page 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 ) ) ) ) ) ) ) ) ) 

### Ii"lJi:;CSlve"') CI.,E;;fJli{'S**OP~IC!l'"**



## JAN 0 3 

## 2010

STATE. 0::: 

### tLLINOJ 

### R1 0_18 oIlU !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.,

2010.1

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# ( 12

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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 11ILLINOIS POLLUTION CONTROL BOARD January I I, 2010

IN THE MATTER OF: ) ) 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 of that 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 of the 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 of the third hearing, the hearings in this proceeding concluded on Wednesday, January 6, 2010. On Friday, January 8, 2010, the Board received the transcript of the 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's2

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 12ILLINOIS POLLUTION CONTROL BOARD February 4, 20 I0

IN THE MATTER OF: ) ) REASONABL YAY AILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLA TILE ) 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. 

### J J, 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 of the 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 of this 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 of the 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 of the Board's air pollution regulations (Prop. 2 18 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.

### 2

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 of the 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 I 0, 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 of Mr. Yoginder Mahajan (Mahajan Test.). The first hearing took place as scheduled on December 9, 2009. The Board received the transcript of the 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 of this opinion.

No participant pre-filed testimony for the second hearing, which took place as scheduled

on January 6, 2010. The Board received the transcript of the second hearing (Tr.2) on January 8, 20 I 

### O. 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 I 0, the hearing officer cancelled the third hearing and set a deadline of January 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 of the proposed rule." 

### ld. at 5, 6, 7**(~~4,** 5, 6).

### 3

Section 100.500(d) of the 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 of the motion, but the waiver of objection does not bind the Board or the hearing officer in its disposition of the 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 of the amendments in providing a summary of the Board's second notice proposal.

BACKGROUND OF FEDERAL YOM REGULA nON

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 of sunlight." SR at 2. "Ground-level ozone is a major component of smog." 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 J 8, 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 standard 2 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 of the 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 of the 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 if the 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 of which must be submitted to the USEPA for review and approval as part of the 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 of the 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. 

### J 6436 (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 of the revised standard is not the purpose of this 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 of coating across either a whole or part of the 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 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 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% of the YOM in the coatings is evaporated in the drying ovens" Id. at 10, 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

### 6

The Agency defines largc appliance coatings as "any protective, decorative, or functional coating applied onto the surface of large 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 of Air 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 of the 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 of these 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 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. /d. Thc third process, coating and adhesive application operations, includes curing or drying of the 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 of the volatile contents of the 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) of YOM per Ib (kg) of solids and equivalent YOM limits in kg (Ib) of YOM per kg (Ib) of coating." 

### ld., Mahajan Test. at 3. The Agency also proposes "a lower YOM limit of 0.20 kg per kg of solids (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 of the 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 of the 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 of cleaning 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 of air 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 of YOM -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 of storage, 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 

### J 8-19 (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 of the Agency. TSD at 32; see Prop. 2 18 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 of the 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 of readily 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 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 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 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 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 of Air 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 of these 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 of Air 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 repOlts13

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 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 of more 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 appliance14

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% of the 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 of Air 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 of HAP 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 of the 1,000 tpy of emissions reduction to be $500,000." Id

.. citing Control Techniques Guidelines for Large Appliance Coatings, Office of Air Quality Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

Metal Furniture Coatings15

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 of the 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 DC EO 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 of the 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 of readily 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 of feasibility 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 of the 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 1 I, 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 of the 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 of the 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 of mass 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 of YOM per mass of solids applied, and equivalent limits in terms of mass of YOM per mass of coatings applied." Mahajan Test. at 3; see Prop. 218 at 12, Prop. 219 at 1 I. Regarding pressure sensitive tape and label surface coating, the Agency proposes "a lower YOM limit of 0.20 kg per kg of solids (0.20 Ib/lb of solids)." 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 of the 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 of mass 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 of these 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 of types of coatings, the Agency proposes 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 at 13-14, Prop. 219 at 12-13. In addition, the Agency proposes "equivalent YOM limits in terms of mass of YOM per volume of solids applied." Mahajan Test. 4; see Prop. 2 I8 at 13- I 4, 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 of those regulations. See 'I'Ll at 15-16. In its motion to amend, the Agency proposed to redesignate the language of the 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 as18

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 of types of coatings, the Agency proposes separate emission limits in terms of mass 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 of solids 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 of those regulations. See Tr.l at 15-16. In its motion to amend, the Agency proposed to redesignate the language of the 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 of proposed 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 of these 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 of the 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 of that 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 of YOM per weight of solids 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/or20

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 of solids 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 J 8/219.212 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 in21

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 of the 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' 0 2010
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 of the IAPA.

This rulemaking is scheduled to be considered by JCAR at its 3/8/1 0 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 of the 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 11 2010
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 of the 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, of the substance of the rulemakings.Thank you for the cooperation your agency has shown during our review of these 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, 2 nd line, after "i.e." add a comma.

2/25/10

# B 14CO-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 I 1/20/09 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)".

2/25/10CO-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 11 2010

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 15ILLINOIS POLLUTION CONTROL BOARD March 18,2010

IN THE MA ITER OF:

REASONABLY AV AILABLE CONTROL TECHNOLOGY (RACT) FOR VOLA TILE

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 of the 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 of the 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 of federal 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 of the Agency's proposal. The opinion then addresses the economic reasonableness and technical feasibility of the 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 HISTORY2

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 of Reasons (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 (DC EO) 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 of the 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 I O. 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 of January 22, 20 I 0, 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 YOM 1 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 of sunlight." SR at 2. "Ground-level ozone is a major component of smog." 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 of the 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 of the 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 of the 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 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.

-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 of the 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 of this 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 Coatings5

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% of the YOM in the coatings is evaporated in the drying ovens." 

### Id. at 10, 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 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 air less 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 of the 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 of these 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 of Air Quality Planning and Standards, USEPA 453/R-07-004 (Sept. 2007).

Metal Furniture Coatings

The Agency provided examples of metal 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 of the 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 REGULA nONS

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) of YOM per kg (lb) of coating." 

### Id., Mahajan Test. at 3. The Agency also proposed "a lower YOM limit of 0.20 kg per kg of solids (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 of the 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 of the 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 of materials 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 of storage, 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 of the 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 of the 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 standards10

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 of readily 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 of which 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 of the 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 YOMI 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, 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. 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 of YOM." 

### lei. at 13-14, citing12

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 of the cleaning material used." !d. The Agency acknowledged, however, that "littlc information 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." !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 also13

indicated that sources can use emission capture and add-on controls to reduce YOM emissions from cleaning operations in this category. 

### Id. at J 7.

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 of more 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 of Air 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 of YOM 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% of the 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 of implementing 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 of HAP reduced in 2006 dollars)." Jd. The Agency reported that USEPA consequently expects an approximate cost-effectiveness "of about $500 per ton of YOM reduced, and a total annual cost of the 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 of the 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 of the 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 of readily 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 of feasibility 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 OF ADOPTED 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 of mass 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 

### 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 of YOM per mass of solids applied, and equivalent limits in terms of mass 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 of solids (0.20 IbIlb of solids)." Mahajan Test. at 3; see Prop. 218 at 12, Prop. 219 at 11. The Agency argued 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 argued that these limitations reflect those set forth in the CTG. See id

..

The Note following this subsection addresses the application of its 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 of mass 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 of types 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
at 13-14, Prop. 219 at 12-13. In addition, the Agency proposed "equivalent YOM limits in terms of mass ofVOM per volume of solids 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 of the 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 of these 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 of types 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. 21818

at 15-16, Prop. 219 at 12-13. In addition, the Agency proposed "equivalent YOM limits in tenns of mass of YOM per volume of solids 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 of these 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 I 9.211 establishes recordkeeping and reporting requirements for affected coating operations, 35 Ill. Adm, Code 218,211, 219.211. The Agency proposed to amend various subsections of that 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 of weight of YOM per weight of solids 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 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 at 13; see Prop. 218 at 39, Prop. 219 at 36. The Agency also sought to require that "[p Japer, 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 of weight of YOM per weight of solids 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 metal20

furniture and large appliance coating lines utilizing the daily weighted averaging altemative maintain and/or report YOM content infonnation in tenns of weight 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 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 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 recommend cd 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 of the 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 of Contact: 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 languageof 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 languageof 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. SeeReasonably 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 Bo ard'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 agencyand 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 thes e 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

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The full text of the Adopted Amendments begins on the next page :

### ILLINOIS REGISTER 5335 10 POLLUTION CONTROL BOARD

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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

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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 EMISSIONSFROM 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

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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 Offs et 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

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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 MI SCELLANEOUS 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

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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 Eq uipment 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

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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

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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: POLYES TER 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

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SUBPART FF: BAKERYOVENS (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

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218.886 Emissions Testing (Renumbered)

SUBPART PP: MISCELLANEOU S 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: MISCELLA NEOUS 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

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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 Technique s for Capture Efficiency (Repealed) 218.APPENDIX C Reference Methods and Procedures 218.APPENDIX D Coefficients for the Total Re source 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, eff ective 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, eff ective 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

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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 21 8.103 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 thisPart, 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 10 POLLUTION CONTROL BOARD

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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 otherwiseprovided in Section 218.204(c), 218.204(g), 218.204(h), and Section 218.204(l), compliance with the emission limitations marked withan asterisk in this Section is required on and after March 15, 1996, and compliance with emi ssion 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 co ating 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 218.2 11(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 10 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 Partand 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 a pproved 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 10 POLLUTION CONTROL BOARD

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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 isperformed if the paper coating line complies with the emissions limitationsin Section 218.401 of this Part. In addition, screen printing on paper isnot regulated as paper coating, but is regulated under Subpart TT of this Part. On and after May 1, 2011, the p aper coating limitation shall also not apply to coating performed on or in-line with any digital printing pres s, or to size presses and on-machine coaters on papermaking machines applying sizing or water-based clays. )

### ILLINOIS REGISTER 5349 10 POLLUTION CONTROL BOARD

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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 10 POLLUTION CONTROL BOARD

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(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)

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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)

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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 limitationsset forth in this subsection (h) The limitationshall 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 al so 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 10 POLLUTION CONTROL BOARD

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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 10 POLLUTION CONTROL BOARD

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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 baseco at" 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 thisSection, a water-borne dip coating process in which oppos ite 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 10 POLLUTION CONTROL BOARD

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0.42* (3.5)*
4) All other coatings are subject to the emission limitations for miscellaneous metal parts and products coatings in subs ection (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

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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 10 POLLUTION CONTROL BOARD

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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 limitationsof 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 limitationsof 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 aninitial 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 weightof 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

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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 10 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 10 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 coatingson 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 10 POLLUTION CONTROL BOARD

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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 S ection. Actual daily emissions shall never exceed the alternative daily emission limitation and shall be calculated by use of the following equation.

i n

i i d 

### C V E 

# 

 

### 
1



### where:

E d 

### = 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

C i 

### = 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 i d 

### L D C D L V A

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;

C i 

### = 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); D i 

### = 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
d) No owner or operator of a heavy o ff-highway vehicle products coating line subject to the limitations of Section 2 18.204(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 (3.5lbs/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 op erator 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 tothe limitations of Section 218.204(l)(1) or (l)(3) of this Subpart shall apply coatings to wood furniture on the subject coating line unle ss the requirements of subsection (e)(1) or subsection (e)(2) of this S ection, 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.

### ILLINOIS REGISTER 5364 10 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 (3.5lbs/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 categor y 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 10 POLLUTION CONTROL BOARD

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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 (2.8lbs/gal)), the daily-weighted average VOM content shall not exceed the coating VOM content limit corresponding to the categor y 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 op erator 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 (2.8lbs/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 op erator 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 10 POLLUTION CONTROL BOARD

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subject coating line unless the requirementsin 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 thanwith 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.

### ILLINOIS REGISTER 5367 10 POLLUTION CONTROL BOARD

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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 fromthe 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 beallowed 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 methodsmust be approved by the Agency and the USEPA. Such overall efficiency isto 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 pur poses 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 10 POLLUTION CONTROL BOARD

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d) No owner or operator of a miscellaneous metal parts and products coating line thatwhichapplies 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 onthe line are subject to 0.42 kg/l [3.5 lbs/gal], and thatwhichis 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 o ff-highway vehicle products coating line thatwhichapplies 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 onthe line are subject to 0.42 kg/1 [3.5 lbs/gal]), and thatwhichis equipped with a capturesystem 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 thatwhichapplies one or more coatingsduring the same day, all of which are subject to the same numeri cal 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 thatwhichis equipped with a capture system and control device shall operate the subj ect 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 thatwhichapplies 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 to0.67 kg/l [5.6 lbs/gal]), and thatwhichis 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 thatwhichis equipped with a capture system and control device shall operatethe 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 10 POLLUTION CONTROL BOARD

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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 i d 

### F C V E

  

# 

 

### 1

1



### where:

E d 

### = 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);

C i 

### = 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

F i 

### = 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 , thatwhichapplies 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 10 POLLUTION CONTROL BOARD

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coatings used on the line are subject to 0.42 kg/l ( [ 3.5 lbs/gal) ] ), and thatwhichis equipped with a capture system and control device shall operate the subject coating line unless the requirements in subs ection (b)(1) or (b)(2) of this Section are met.
j) Prior to May 1, 2011, noNoowner or operator of a metal furniture coating line thatwhichapplies 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 thatwhichis equipped with a capturesystem 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, noNoowner or operator of a large appliance coating line thatwhichapplies 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 thatwhichis equipped with a capturesystem 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 thatis 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 10 POLLUTION CONTROL BOARD

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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 Section below :
a) No owner or operator of a coating line thatwhichis exempt from the limitations of Section 218.204 of this Subpart because of the criteria in S ection 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 S ection 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 10 POLLUTION CONTROL BOARD

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 operatethatcoating line on or after a date c onsistent 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 Partto establish the records required under this Section.
b) Any owner or operator of a coating line thatwhichis 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 2 18.208(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 thatwhichdemonstrate 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 fo llowing equation shall be used to calculate total VOM emissions:

### ILLINOIS REGISTER 5373 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS


##   

# 

  

###  m

j n

i j i i e 

### B A T

1 1



### where:

T e 

### = 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 atthe source that otherwise would be subject to the same subsection of Section 218.104 of this Part (becausethey 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 anindividual coating;

Ai 

### = Weight of VOM per volume of each coating (minus water and any compounds thatwhichare 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

B i 

### = Volume of each coating (minus water and any compounds thatwhichare 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 10 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 Subpartbecause 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 2 18.208(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 2 18.208(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 subs ection (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 withSection 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 10 POLLUTION CONTROL BOARD

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 218.2 04(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. The Such 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 10 POLLUTION CONTROL BOARD

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 co atings, 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 withSection 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
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 co atings, 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 withSection 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 o ccurrence 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 fromSection 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 certif y to the Agency that the coating line

### ILLINOIS REGISTER 5378 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
will be in compliance with Section 2 18.205 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. The Suchcertification 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 co atings, as applicable) in each coating as applied eachday 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

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 withSection 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 co atings, as applicable) in each coating as applied eachday 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 withSection 218.106 of this Part, the owner or operator of a subject coating line shall notify the Agency in the

### ILLINOIS REGISTER 5380 10 POLLUTION CONTROL BOARD

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 o ccurrence 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 calculationsnecessary 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 withSection 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.

### ILLINOIS REGISTER 5381 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

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 withSection 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 o ccurrence 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 S ection 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 Su bpart 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 thisPart, or on and after the initial start-up date. The Suchcertification shall include:

### ILLINOIS REGISTER 5382 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

A) The name and identification number of each coating operation which will comply by means of S ection 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 withSection 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
of coating solids deposited inaccordance 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) isused 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 withSection 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 10 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 startu p, 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 S ection 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 theviolation 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 thoserecords 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 S ection 218.204 of this Subpart, except coating lines subject to the limitations in Section 2 18.204(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 thetype described below has been made after January 1, 1991, to one or more preexisting coating lines at the source. Anoperational change occurs when a preexisting coating line is replaced with a line using lower VOM coating for the

### ILLINOIS REGISTER 5385 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
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 torely 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 de fined below, are less than the calculated daily allowable VOM emissions from the same group of coating lines. For any pre-existing coating line tobe 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 onor 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 includesas a participating coating line one or more coating lines that satisfy the criteria of a replacement line, as

### ILLINOIS REGISTER 5386 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
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 i d 

### C V E 

# 

 

### 
1



### where:

E d 

### = 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

C i 

### = 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

p i d 

### A A A  

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 

### L D C D L V A

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;

C i 

### = 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);

D i 

### = 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

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 h j j j
p 

### L D K D L V 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;

D

j 

### = The assumed density of VOM in liquid coating, 0.882 kg VOM/l VOM (7.36 lbs VOM/gal VOM);

V

j 

### = Volume of each powder coating consumed for the day in units of l (gal) of coating; and

L

j 

### = 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 10 POLLUTION CONTROL BOARD

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 oroperator 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 thosematerials;
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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
5) Minimize VOM emissions from the cleaning of storage, mixing, and conveying equipment.
b) On and after May 1, 2011, every owner oroperator 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 material s, and clean up spills immediately;
4) Convey VOM-containing coatings, thinners, coating-related waste materials, and cleaning materials fromone 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

### ILLINOIS REGISTER 5391 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
process in which opposite electric al 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 tothe 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)

### ILLINOIS REGISTER 5392 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED 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 : 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).

### ILLINOIS REGISTER 5393 10 POLLUTION CONTROL BOARD

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 languageof 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 languageof 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 Bo ard'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 agencyand 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 thes e 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
The full text of the Adopted Amendments begins on the next page :

### ILLINOIS REGISTER 5397 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 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 FROMSTORAGE 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 10 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 Ruleon 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 10 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 Offs et 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 10 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 MI SCELLANEOUS 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 Eq uipment 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 10 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 10 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: MISCELLANEOU S 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: MISCELLA NEOUS 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: MISCELLANEOU S 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 Technique s for Capture Efficiency (Repealed) 219.APPENDIX C Reference Methods and Procedures 219.APPENDIX D Coefficients for the Total Re source 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, eff ective 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, eff ective 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 subs ection (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), andSection219.204(l), compliance with the emission limitations marked withan asterisk in this Section is required on and after March 15, 1996, and compliance with emi ssion 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 co at 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 coatingsolids 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 Partdoes 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 10 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 isperformed if the paper coating line complies with the emissions limitations in Section 219.401 of this Part. In addition, screen printing on paper is notregulated 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

0.28* (2.3)*
3) (Note: The limitationsset forth in this subsection (h) The limitationshall 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) inany one rolling eight-hour period. On and after May 1, 2011, these limitationsshall also not apply to stencilcoatings, 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 10 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 p articles, 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 10 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 10 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 limitationsof 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 limitationsof 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 aninitial 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 10 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 weightof 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) C olor coat 0.49* (4.1)*
ii) Primer 0.46* (3.8)* B) Air Dried i) C olor 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 10 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 coatingson 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 thatwhichapplies 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 (3.5lbs/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 thatwhichapplies 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 i i b 

### C V E

1



### where:

E d 

### = 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);

C i 

### = 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 i d 

### L D C D L V A

 
 

# 

 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;

C i

### = 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);

D i

### = 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 o ff-highway vehicle products coating line subject to the limitations of Section 2 19.204(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 thatwhichapplies 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 (3.5lbs/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 thatwhichapplies 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 op erator 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 tothe limitations of Section 219.204(l)(1) or (l)(3) of this Subpart shall apply coatings to wood furniture on the subject coating line unle ss 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 thatwhichapplies 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 thatwhichapplies 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 Subp art 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 thatwhichapplies 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

2) For each coating line thatwhichapplies 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 thatwhichapplies 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 (2.8lbs/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 thatwhichapplies coatings subject to more than one numerical emission limitation in Section 219.204(g) of this Subpart, during the same day, the owner or op erator 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 thatwhichapplies 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 (2.8lbs/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 thatwhichapplies coatings subject to more than one numerical emission limitation in Section 219.204(h) of this Subpart,

### ILLINOIS REGISTER 5424 10 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 requirementsin 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 co atings 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 thanwith 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 10 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 fromthe 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 beallowed 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 methodsmust be approved by the Agency and the USEPA. Such overall efficiency isto 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 pur poses of calculating this value, according to the equation in Section 219.105(e)(2) of this Part, VOM 1 

### 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 10 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 thatwhichapplies 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 thatwhichis equipped with a capturesystem 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 o ff-highway vehicle products coating line thatwhichapplies 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 thatwhichis equipped with a capturesystem 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 thatwhichapplies 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 thatwhichis 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 operatethe 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 10 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 i i d 

### F C V E

  

# 

 

### 1

1



### where:

E d

### = 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);

C i

### = 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

F i

### = 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 thatwhichapplies 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 thatwhichis

### ILLINOIS REGISTER 5428 10 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 subs ection (b)(1) or (b)(2) of this Section are met.
i) Prior to May 1, 2011, noNoowner or operator of a metal furniture coating line thatwhichapplies 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 thatwhichis equipped with a capturesystem 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, noNoowner or operator of a large appliance coating line thatwhichapplies 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 thatwhichis equipped with a capturesystem 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
appropriate compliance schedule as specified in subsection (a), (b), (c), (d), (e)
, or (f) , or (g) of this Section below :
a) No owner or operator of a coating line thatwhichis exempt from the limitations of Section 219.204 of this Subpart because of the criteria in S ection 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 S ection 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 10 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 Partto establish the records required under this Section.
b) Any owner or operator of a coating line thatwhichis 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 re ferenced 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 thatwhichdemonstrate 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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS


##   

# 

  

###  m

j n

i j i i e 

### B A T

1 1



### where:

T e

### = 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 anindividual 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);

B i 

### = 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 10 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 Subpartbecause 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 2 19.208(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 2 19.208(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 subs ection (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 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS
5) On and after a date consistent withSection 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 219.2 04(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. The Such 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 10 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 co atings, 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 withSection 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 co atings, 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 withSection 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 o ccurrence 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 fromSection 219.204 or Section 219.207

### ILLINOIS REGISTER 5436 10 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 Agencythat 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 initialstart-up date. The Suchcertification 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 co atings, as applicable) in each coating as applied eachday 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 10 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 withSection 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 co atings, as applicable) in each coating as applied eachday 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 10 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 withSection 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 o ccurrence 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 S ection 219.207 of this Subpart on and after a date consistent with Section 2 19.106 of this Part, or on and after the initial start-up date.
2) On and after a date consistent withSection 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 10 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 withSection 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 o ccurrence 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 Su bpart 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 thisPart, or on and after the initial start-up date. The Suchcertification shall include:
A) The name and identification number of each coating operation which will comply by means of S ection 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 withSection 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 10 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 inaccordance 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) isused 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 withSection 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 10 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 beforethe 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 S ection 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 tothe 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 S ection 219.204 of this Subpart, except coating lines subject to the limitations in Section 2 19.204(c)(2), (g)(2), or (h)(2) of this

### ILLINOIS REGISTER 5443 10 POLLUTION CONTROL BOARD

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 thetype described below has been made after January 1, 1991, to one or more preexisting coating lines at the source. Anoperational 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 torely 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 de fined below, are less than the calculated daily allowable VOM emissions from the same group of coating lines. For any pre-existing coating line tobe 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 onor 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:

### ILLINOIS REGISTER 5444 10 POLLUTION CONTROL BOARD

NOTICE OF ADOPTED AMENDMENTS

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 includesas 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 i i d 

### C V E

1



### where:

E d

### = 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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C i

### = 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:

p i d 

### A A A  

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 s ource 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 

### L D C D L V A

 
 

# 

 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;

C i 

### = 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);

D i

### = 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 h j j j
p 

### L D K D L V 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;

D

j

### = The assumed density of VOMin liquid coating, 0.882 kg VOM/l VOM (7.36 lbs VOM/gal VOM);

V

j

### = Volume of each powder coating consumed for the day in units of l (gal) of coating;

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L

j

### = 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 oroperator 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 oroperator 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 material s, and clean up spills immediately;
4) Convey VOM-containing coatings, thinners, coating-related waste materials, and cleaning materials fromone 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 coatingsusing 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 electric al 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 tothe requirements of Section 21 9 .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)