# A 1

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

# ID

.. RWY- (Rulemaking-Air) IN THE MATTER OF: ) ) 

### AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STANDARDS FORTHE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) 

### TABLE OFCONTENTS 1. 

### Notice ofFiling 

### £l'IIEcenVEIOi CLERK'S OFFICE



## JUL U 

## 92009 STATE OF ILUNO ' Pollution Control

## 8o~~d

2. Appearances ofDanaVetterhoffer, Assistant Counsel for the Dlinois Environmental Protection Agency, and John Kim, ChiefLegal Counsel for the Dlinois Environmental Protection Agency 3. Proposal ofRegulations by Director Douglas P. Scott 4. Certification ofRequired Rule 5. Certification ofOrigination 6. AgencyAnalysis ofEconomic and Budgetary Effects 7. Motion forWaiver ofRequirements 8. StatementofReasons 9. Proposed Amendments to 35m. Adm. Code Parts 211,218, and 219 10. TechnicalSupportDocument for Controlling VOMEmissions from Lithographic Printing, Letterpress Printing, Flexible Package Printing, Flat WoodPaneling Coating. andIndustrial Cleaning Operations, 

### Illinois Environmental Protection Agency. June 2009 II. Documents Relied Upon: Control Techniques Guidelines for OffsetLithographicPrinting andLetterpress Printing, 

### United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research TrianglePark, NC, September2006.Control Techniques Guidelinesfor Flexible PackagePrinting, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2006. Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Rese,arch Triangle Park, NC, September 2006. Control Techniques Guidelinesfor Flat WoodPaneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September2006. Technical SupportDocumentfor Controlling VOMEmissionsfrom Lithographic Printing Operations, illinois Environmental Protection Agency, Air QualityPlanning Section, Springfield, 

### IL, October 1994. Control Techniques Guideline Series: Control ofVolatile Organic Compound Emissionsfrom OffsetLithographicPrinting (DRAFT), United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 1993. Control of volatile organic compoundemissionsfrom industrialsolventcleaning operations (Proposed), Ohio Administrative Code 3745-21-23 (February 2, 2009). 12. Motion for Expedited Review 13. Certificate ofService 14. Notices ofProposed Amendments 15. Diskin MicrosoftWORD containing Agency's Proposed Amendments to Parts 211, 218, and 219, andNotices ofProposed Amendments.

2BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: ) ) AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STANDARDS FOR THE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) NOTICE 

# ,o/'t (Rulemaking-Air)

### ~~c

# CLeRI<~**!~/~l~** JUL U 

### 9

## 2UU9 STATE 0 POllution

## c~~rLINOIS rO/Board To: John Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Illinois 60601-3218 Virginia Yang DeputyLegal Counsel Illinois DepartmentofNatural Resources OneNatural Resources Way Springfield, IL 62702 Matthew Dunn, Chief Division ofEnvironmental Enforcement Office ofthe Attorney General 188 West Randolph, 20th Floor Chicago, IL 60601

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control Board the REGULATORY PROPOSAL entitled "AMENDMENTS TO 35 ILL. ADM. CODE 218, ORGANIC MATERIAL EMISSION STAl\TDARDS FOR THE CHICAGO AREA, 35 ILL. ADM. CODE 219, ORGANIC MATERIAL EMISSION STANDARDS FORTHE METRO EAST AREA, AND 35 ILL. ADM. CODE 211," MOTION FOR WAIVER, MOTIONFOR EXPEDITED REVIEW, and APPEARANCES ofthe Illinois Environmental Protection Agency, a copy ofwhich is herewith served upon you. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:c?h 

# =-

# iIdb~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: ) 

### ) AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STANDARDS FOR THE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) 

### APPEARANCE 

# 1°**/~** R99<'" (Rulemaking-Air) 

### ReceOVElQi

Cl.ERK'S OFFICE



## JUL U

## 9

## 2009 STATE OF ILLINOIS 

### Pollution Control Board

The undersigned hereby enters her appearance as an attorney onbehalfofthe Illinois Environmental Protection Agency. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:

## c:z:-x::,,MO,.

# ~~ Dana Vetterhoffer Assistant Counsel Division ofLcgal Counsel DATED: July 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: ) ) AME1\1J)MENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STANDARDS FOR THE CmCAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) APPEARANCE

# o/~ 

# RGk (Rulemaking-Air)

The undersignedhereby enters his appearance as an attorney onbehalfofthe Illinois Environmental Protection Agency. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AG 

### Y**BY::~-J~~~::::::::===---_** Jo 

### J.

. ChiefLegal Counsel Division ofLegal Counsel DATED: July 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: ) ) AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STANDARDS FOR THE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) 

# [o/'t R.8g:' (Rulemaking-Air) 

### AeCE;iVED CLERK'S OFFICE



## JUl U 

## 2009 STATEOF 

### ILLINOIS 

### PollutIon Control Board 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 / By:.L/1 

### --"C:"--"-7F"'-::':"--'::"-"'-L"""'--'-""-

_

DATED: June 

## 29 ,2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

# ,0

# /'~ 

# Rd?' (Rulemaking-Air) IN THE MATTER OF: ) ) AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIALEMISSION ) STANDARDS FOR THE CmCAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STA..'NDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 ) CERTIFICATION OF REQUIRED RULE

### Arec~nVED CLERK'S OFFICE



## JUL U

## 920D9 STATE OF 

### ILLINOIS 

### Pollution Control Board

The Illinois Environmental Protection Agency certifies in accordance with 35 Ill. Adm. Code 102.202(h) and 102.500, and 415 ILCS 5128.2(b), thatitbelieves that this proposal for amendments to 35 Ill. Adm. Code 211, 218, and 219 is a federally required rule under Sections 172(c)(I) and 182(b)(2) ofthe Clean AirAct ("CAA"). 42 U.S.C. 

### §§ 7502(c)(1) and 7511 a(b)(2). The proposal for amendments is needed to satisfy Illinois' obligation to submit a State Implementation Plan ("SIP") for sources ofvolatile organic materials ("VOM") emissions in

areas designated as nonattainment with respect to the ozone National AmbientAir Quality Standard ("NAAQS"). Section 172(c)(1) ofthe CAA provides that states mustinclude in their SIPs for nonattainment areas "reasonably available control measures," including "reasonably available control technology" ("RACT"), for sources ofemissions. 42 U.S.C. 

### § 7502(c)(1). Section 182(b)(2) ofthe CAAprovides that, for ozone nonattainment areas, the Statemustrevise its SIP to include RACT for sources ofVOM emissions covered by a control techniques**guidelin~** ("CTG") issuedbetween November 15, 1990, and the date ofattainment. 42 U.S.c. 

### § 7511a(b)(2).Theproposed amendments are intended to establish RACT requirements for Group II Consumer and Commercial Product categories in response to CTGs issued by the United States Environmental Protection Agency for such categories, and thereby satisfy the CM requirements described above. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

DATED: July 8, 2009 1021 N. Grand Ave. East P.O. Box 19276

. Springfield, IL 62794-9276

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

CERTIFICATION OF ORIGINATION IN THE MATTER OF: AMENDMENTS TO 35 ILL. ADM. CODE 218, ORGANIC MATERIAL EMISSION STANDARDS FOR THE CHICAGO AREA, 35 ILL. ADM. CODE 219, ORGANIC MATERIAL EMISSION STANDARDS FOR THEMETROEASTAREA,AND 35 ILL. ADM. CODE 211 ) ) 

### ) ) ) ) ) ) )

# RJ~ ,,'& (Rulemaking-Air) 

## F'Qec

# Cl.cFlIi~**~'X:,a** 0 

## JUL 

# a 92009 STATED 

### POllution

## C~~fLL,'NOIS ro Board 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 211, 218, and 219 amends the mostrecent version oftherules as published on the Illinois Pollution Control Board's website. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By: O)-v·"g

# 1!dIu~ DanaVetterhoffer Assistant Counsel Division ofLegal Counsel

DATED: July 8,2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544Dlinois Register Citation:

_ Agency: PartfTitle: Agency Analysis ofEconomic and Budgetary Effects ofProposed Rulemaking Dlinois Pollution Control Board Definitions and General Provisions (35 Ill. Adm. Code Part 211)

### iPllE:C~n~n**CLEFlKf~o"** F" 

### IE[!J , FICE 

## JUL U!J 2009 STATE OF 

### POllution

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

_ Negative

__ No effect Persons affected: Owners and operators of affected lithographic printers, letternress printers, flcxible package printers, flat wood paneling coaters, and sources using industrial cleaning solvents. Dollar amount perperson: _0_ Total statewide cost:

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

### (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? No Will there be any change in requirements such as filing, documentation, reporting orcompletion offorms? No The proposed changes to Part 211 should have no indirect effectthat may result in increased administrative costs,Agency: Agency Analysis ofEconomic and Budgetary Effects ofProposed Rulemaking l11inois Pollution Control Board Part/Title: Organic Material Emission Standards and Limitations for the Chicago Area (35 111. Adm. CodePart 218) Illinois Register Citation:

_ Please attemptto 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 costto the agency for this program/activity. -$50,300 per year (b) Ifthis rulemaking will result in an increase or decrease in cost, specify the fiscal year in whichthis change will first occur and tlie dollar amount ofthe effect. N/A (c) Indicate the fimding source, including Fund and appropriation lines, for this program/activity. N/A (d) If an increase or decrease in the costs of another State agency is anticipated, specify the fiscal year in which this change will first occur and the estimated dollar amount ofthe effect. N/ A (e) Will this rulemaking have any effect on State revenues or expenditures not already indicated above? No 2. Economic effect on persons affected by the rulemaking: (a) Indicate the economic effect and**~pecify** the persons affected: Positive

_ Negative....1L- No effect

__ Persons affected: See list ofpotentiallv affected sources in TSD. Dollar amount per person: Affected lithographic printers: SO-855/ton Affected letterpress printers: SO-855/ton Affected flexible package printers: $O-2800/ton Affected flat wood paneling coaters: SO-2600/ton Affected industrial cleaning solventusers: Probable cost savings Total statewide cost: Affected lithographic printers: S308/day Affected letterpress printers: S4/dayAffected flexible packageprinters: $84/day Affected flat woodpaneling coaters: $130/day Affected industrial cleaning solvent users: Probable cost savings (bl If an economic effect is predicted, please briefly describe how the effect will occur. Costs due to control measures for newlv-affected sources, as described in TSD. (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? Will there be any ehange in requirements sueh as filing, documentation, reporting or completion offorms? The rulemaking will require a small amount ofadditional reporting but should have no more than a negligible indirect effect that may result in increased administrative costs.Agency: Agency Analysis ofEconomic and BudgetaryEffects ofProposed Rulemaking TIlinois Pollution Control Board PartlTitle: Organic Material Emission Standards and Limitations for the Metro East Area (35 ill. Adm. Code Part219) TIlinois Register Citation:

_ Please attempt to provide as dollar-specific responses as possible and feel free to add any relevant explanation. J. Anticipated effect on State expenditures andrevenues. (a) Current costto the agency for this program/activity. -$5,500 per year (b) Ifthis rulemaking will result in an increase or decrease in cost, specifY the fiscal year in which this change will first occur and the dollar amount ofthe effect. N/A (c) Indicate the funding source, including Fund and appropriation lines, for this program/activity. N/A (d) 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 dollaramount ofthe effect. N/ A (e) Will this rulemaking have any effect on State revenues or expenditures not already indicated above? No 2. Economic effect onpersons affected by the rulemaking: (a) Indicate the economic effect and specifY the persons affected: Positive

_ Negative No effect

__ Persons affected: See list ofpotentially affected sources in TSD. Dollaramount perperson: Affected lithographic printers: $0-855/ton Affected letterpress printers: $0 (no affected sources) Affected flexible package printers: $0 (no affected sources needing add-on control modification) Affected flat wood paneling coaters: $0 (no affected sources) Affected industrial cleaning solvent users: Probable cost savings Total statewide cost: Affected lithographic printers: $6/dayAffected letterpress printers: $0 (no affected sources) Affected flexible packageprinters: $0 (no affected sources needing add-on control modification) Affected flat wood paneling coaters: $0 (no affected sources) Affected industrial cleaning solvent users: Probable cost savings (b) If an economic effect is predicted, please briefly describe how the effect will occur. Costs due to control measures for newlv-affected sources, as described in TSD. (c) Will the rulemaking have an indirect effect that may result in increased administrative costs? Will there be any change in requirements such as filing, documentation, reporting or completion offorms? The rulemaking will require a small amount ofadditional reporting hut should have no more than a negligible indirect effect that may result in increased administrative costs.

### BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

# \0

# r'b M9- (Rulemaking-Air) ) 

### ) ) ) ) ) ) ) )

### RIECEHVE~ CLERK'S OFFICE



## JUL U

## 9

## 2009 STATE 

### OF ILLINOIS 

### POllution Control Board MOTION FORWAIVER OF REOUIREMENTS IN THE MATTER OF: AMENDMENTS TO 35 ILL. ADM. CODE 218, ORGANIC MATERIAL EMISSION STANDARDS FORTHE CHICAGO AREA, 35 ILL. ADM. CODE 219,**ORG.M~IC** 

### MATERIAL EMISSION STANDARDS FOR THEMETRO EAST AREA, AND

. 35 ILL. ADM. CODE 211

The**Proponent~** 

### the Illinois Environmental Protection Agency ("Illinois EPA"), by its attorney, and pursuant to 35 

### Ill. Adm. Code 101.500, 102.110,102.200, and 102.402, respectfullymoves that the Illinois Pollution Control Board ("Board") waive the requirementthat the Dlinois EPA submit the original and nine copies ofthe regulaioryproposal including all documents relied upon. In support ofits Motion, Illinois EPA states as follows: 1. Section 102.200 ofthe Board's procedural rules requires that the original and nine copies ofeach regulatory proposal be filed with the Clerk. 2. Section 27(a) ofthe Environmental ProtectionAct ("Act') requires that the Illinois EPA provide information supporting the proposal. 415 ILCS 5/27(a). In doing so, the Illinois EPA has provided documents which were directly relied upon when drafting the regulatory proposal. The documents relied upon are as follows:



### a. Control Techniques Guidelines for OffsetLithographicPrinting andLetterpress Printing, 

### United States Environmental Protection Agency, Office ofAir Quality Plarming and Standards, Research Triangle Park, NC, September 2006. b. Control Techniques GuidelinesforFlexible Package Printing, 

### United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September2006.

1c. Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research TrianglePark, NC, September 2006. d. Control Techniques Guidelinesfor Flat WoodPaneling Coatings, United States Environmcntal Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2006. 

## e

.. Technical SupportDocument for Controlling VOMEmissions from Lithographic Printing Operations, nlinois Environmental Protection Agency, Air Quality Planning Section, Springfield, IL, October 1994. f. Control Techniques Guideline Series: Control ofVolatile Organic Compound Emissions from OffsetLithographic Printing (DRAFT), United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 1993. g. Control of volatile organic compoundemissionsfrom industrialsolventcleaning operations (Proposed), Ohio Administrative Code 3745-21-23 (February 2,2009). 3. This entire regulatory proposal consists ofover 700 pages. Given the length ofthe proposal and the resources required to provide nine copies, Illinois EPA requests that the Board waive the normal copy requirements and allow lllinois EPA to file the original and four complete copies ofthe documents. WHEREFORE, the Illinois EPAmoves that the Board waive the copyrequirement and allow the lllinois EPA to provide the Board with an original and four copies ofthe proposal and the documents relied upon in the development ofthe proposal, as listed above. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY

# By:(2)~~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

2

### DATED: July 8, 2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

3BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: ) ) AMENDMENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERlAL EMISSION ) STANDARDS FOR THE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERlAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 

## /0

# ~~ Rd¢' (Rulemaking-Air) 

# Aeceg

CLERK'S

## O~lfaP JUl U!:J 

## 2009 STATE OF 

### POllution

## CO~b~,'NBOIS Oara STATEMENT OF REASONS I. INTRODUCTION The Illinois Environmental Protection Agency ("Illinois EPA") submits this Statement ofReasons to the lllinois Pollution Control Board ("Board") pursuantto Sections 27 and 28 ofthe EnvironmentalProtection Act ("Act") (415 ILCS 5/27 and 28) and 35 TIl. Adm. Code 102.202 in support ofthe attached proposal ofregulations. These regulations are proposed to control emissions ofVolatile Organic Material ("VOM"), which is effectively the same as volatile organic compounds ("VOC"), from the following Group II Consumer and Commercial Product Categories: Industrial Cleaning Solvents, FlatWood Paneling Coatings, Flexible Packaging Printing Materials, Lithographic Printing Materials, and Letterpress Printing Materials. This proposed rulemaking is intended to meet certain obligations ofthe State of lllinois under the federal Clean Air Act ("CAA"), 42 U.S.c. 

### § 7401 etseq. Specifically, the rulemaking is intended to satisfy TIlinois' obligation to submit a State Implementation Plan ("SIP") to address requirements under Sections 172 and 182 ofthe CAA for sources ofVOM emissions in areas designated as nonattainment with respect to the ozone National Ambient Air Quality Standard ("NAAQS"): See 42 U.S.C. 

### §§ 7502 and 75lla. 1Section l72(c)(l) ofthe CAA provides that states must include in their SIPs for nonattainment areas "reasonably available control measures" ("RACM"), including "reasonably available control technology" ("RACT"), for sources ofemissions. 42 U.S.C. § 7502(c)(1). Section 182(b)(2) ofthe CAA provides that, for ozone nonattainment

.: areas, the State must reviseits SIP to include RACT for sources ofVOC emissions

coveredby a control techniques guideline ("CTG") issued between November 15, 1990, and the dateofattainment. 42 U.S.C. 

### § 75 1la(b)(2). Illinois is proposingreasonable and cost effective VOM controls for Group II Consumer and Commercial Product Categories in response to CTGs issued for such categories. Included in this proposal are amendments to 35lll. Adm. Code Part 218, Organic Material Emission Standards and Limitations for the Chicago Area; 35 

# m. Adm. Code Part 219, Organic Material Emission Standards and Limitations for the Metro East Area; and 35 Ill. Adm. Code Part 211, Definitions and General Provisions. 

### II. 

### STATEMENT OFFACTS The CAA establishes a comprehensiveprogram for controlling and improving the nation's air quality via state and federal regulations. TheUnited States Environmental Protection Agency ("USEPA") is charged with identifying airpollutants that endanger the public health and welfare and with formulating the NAAQS that specifY the maximumpermissible concentrations ofthose pollutants in the ambient airpursuantto Sections 108 and 109 ofthe CAA. 42 U.S.C. §§ 7408-7409. 

### A. 8-Hour Ozone 

### NAAQS Ozone is a gas composed ofthree atoms ofoxygen. Ozone occurs both in the Earth's upper atmosphere and at ground level. VOC is aprimaryprecursorto the



### 2formation ofground-level ozone, which is formed when oxides ofnitrogen and VOC react in the atmosphere in the presence ofsunlight. 71 Fed. Reg. 58746 (Oct. 5,2006). Exposure to sufficientconcentrations ofground-level ozone is associated with agricultural crop loss, damage to forests and ecosystems, and a variety ofhumanhealth effects, including acute respiratory symptoms, increased susceptibilitytorespiratory infection, and pulmonary inflammation. 71 Fed. Reg. 58746. On July 18, 1997, USEPA revised the NAAQS for ozone byreplacing 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-hourozone standard: I) the Chicago-Gary-Lake County, IL-IN dc;signated area, which includes Cook, DuPage, Grundy (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. B. Consumer and Commercial Prodncts, Group II Section 183(e) ofthe CAA required that USEPA conduct a study ofthe emissions ofVOC into the ambient air from consumer and commercial products in orderto determine theirpotential to contribute to ozone levels which violate the ozone NAAQS andto establish criteria for regulating emissions ofVOC from those products. 71 Fed. Reg. 58746. Section I83(e) provides, "[T]he Administrator shall listthose 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 thatviolate the NAAQS for ozone" and shall divide the categories into groups. 42 U.SC. 

### § 751Ib(e)(3)(A).



### 3Thc CAA requires that USEPA then either regulate VOC emissions from such categories or issue a CTG in lieu ofa national regulation ifthe Administrator determines that such guidance will be substantially as effective as regulations 

### in reducing emissions ofVOC which contribute to ozonc levels in ozonenonattainment areas. 42 U.S.C. 

### § 7511b(e)(3)(C). CTGs provide states with recommendations regarding what types of controls could constitute RACT for VOCs for the applicable source categories. 71 Fed. Reg. 58745,58747. States must either adopt regulations to implement the recommendations in the CTG or adopt alternative approaches that constitute RACT, eitherofwhich mustbe submitted to the USEPA for review and approval as part ofthe SIP process. 71 Fed. Reg. 58745,58747. On October 

### 5, 2006, the USEPA issued final CTGs for Group 

### IT Consumer and Commercial Product Categories in lieu ofnational regulations for the control ofVOC emissions. The USEPA required that states submit SIP revisions 

### in response to the CTGs within one year. 71 Fed. Reg. 58745-58753. Co CAA's RACT Requirements USEPA designated the Chicago and Metro East areas in Illinois as nonattainment (moderate) for the 8-hour ozone NAAQS, which triggered requirements under the CAA for adopting regulations that reduce emissions sufficiently to demonstrate attainment of the standard. Section 172(c)(l) ofthe CAA provides, in pertinentpart: (c) Nonattainmentplan provisions Theplan provisions (including plan items) required to be submitted underthis part shall comply with each ofthe following: (1) In general

4Such plan provisions shall provide for the implementation ofall reasonably available control measures as expeditiously as practicable (including such reductions in emissions from existing sources in the area as may be obtained through the adoption, at a miillmum, ofreasonably available control technology) and shall provide for attainment ofthe national primary ambient air quality standards. 42 U.S.C. 

### § 7502(c)(I). A subset ofRACM is RACT, which is defined as the lowest emission limitation that aparticular source can meetby applying a control technique that is reasonably. available considering technological and economic feasibility. See 44 Fed. Reg. 53762 (September 17,1979). Additionally, Section 182(b) ofthe CAA provides, in pertinentpart: (b) Moderate Areas Each State in which all orpart ofaModerate Areais located shall, with respectto the Moderate Area, make the submissions described under subsection (a) ofthis section (relatingto 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 arevision to the applicable implementation plan to include provisions to require the implementation of reasonably available control technologyunder section 7502(c)(I) ofthis title with respect to each ofthe following: (A) Each category ofVOC sources in the area coveredby a CTG documentissuedbythe Administratorbetween November 15, 1990, and the date ofattainment. 42 U.S.C. 

### § 7511 a(b)(2). Sections 172 and 182 ofthe CAA establish the requirement for Illinois to submit VOC regulations constitutingRACT for Group II Consumer and Commercial Product Categories in ozone nonattainment areas classified as moderate and above. Illinois was required to submit its SIP revisions by October 5, 2007. 5

### III. PURPOSE AND EFFECT OF THE PROPOSAL This rulemaking proposal has been prepared to satisfy Illinois' obligation to submit a SIP to address the requirements under Sections 172 and 182 ofthe CAA, as described above, for sources ofVOC emissions in areas designated as nonattainment with respect to the ozone NAAQS. See 42 U.S.c. 

### §§ 7502 and 7511a. Also, Illinois is required to submit these SIP revisions before the USEPA can redesignate the Chicago and Metro Eastnonattainment areas as attaining the 1997 ozone NAAQS, regardless ofwhether the VOC reductions obtained by the SIP revisions are actuallynecessary to achieve attainment ofthe NAAQS. Section 107(d)(3)(E) ofthe CAA providcs that the Administratormaynotredesignate a nonattainment area to attainmentunless the State has a fully-approved SIP for the area seeking redesignation and the Statehas met all applicable requirements ofSection 110 and PartD (which includes the requirement that states adopt VOC RACT rules for categories coveredby a CTG). 42 U.S.c. 

### § 7407(d)(3)(E). In a September 17, 1993,guidancedocument from Michael H. Shapiro, Acting AssistantAdministrator for Air and Radiation ("Shapiro Memorandum"), the USEPA confinned, "[B]efore EPA can act favorably upon any State redesignation request, the statutorily-mandated control programs ofsection 110 and part D (thatwere due prior to the time ofthe redesignation request) musthavebeen adopted by the State and approvedbyEPA into the SIP." (Shapiro Memorandum, p. 2).1

) See also Wall v. USEPA. In Wall, the United States Court ofAppeals for the Sixth Circuit vacated the USEPA's redesignation ofa state to attainment, in partbecause the state failed to promulgate VOCRACT 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 attairunent. The court rejected USEPA's argument, holding that the CAA unambignouslyrequires that a SIP submitted with respect to a redesignation request contain fully adopted RACT rules required by Part D. Redesignation absent such rules was therefore improper. Wall v. USEPA. 265 F.2d426,433,440-42 (6th Cir. 2001). 

### 6On July 2, 2007, the Illinois EPA submitted to the USEPA an attainment demonstration for theMetro East nonattainment area for the 1997 8-hour ozone NAAQS. On March 19,2009, the Illinois EPA submitted an attainment dcmonstration for the Chicago nonattainment area as well. These areas cannotbe redesignated to attainmentof the ozone NAAQS, however, unless and until the Illinois EPA submits SIP revisions in response to the Group II 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 llIinois that are currently designated as nonattainment for the present standards will soon be designated as nonattainment for therevised standard. While attainment ofthe revised standard is not the purpose ofthis rulemaking, it should be noted that any reduction in YOM emissions

. in the nonattainment areas resulting from these proposed amendments will likelyhelp Illinois achieve the revised NAAQS. Generally, lllinois EPA's regulatoryproposal aims to implementthe recommendations contained in the CTGs to the extent that such recommendations are consistent with, and impose stricterrequirements than, existing regulations: Industrial Cleaning Solvents. Theproposedregulations apply to cleaning operations at sources that meet the applicability threshold set forth in the CTG, subjectto several partial and complete exclusions. Per the CTG, the proposedregulations require that subject sources complywith work practice requirementsand with one ofthree alternative control requirements. Flat Wood Paneling Coatings. The proposed regulations require that flat wood paneling coating lines comply with the YOM contentlimitation specified in the CTG. As



### 7an alternative to the YOM content limit, subject lines may comply with a daily weighted averaging limitation orutilize an add-on control device that meets a specified overall YOM reduction requirement. The proposed regulations also require that flat wood paneling coating lines comply with the existing cleaning and storage work practice requirements for wood furniture, as well as with the workpractices set forth in the CTG. Flexible Packaging Printing Materials. The proposed regulations require that flexographic and rotogravure printing lines that printflexible packaging, or that print flexible packaging and non-flexible packaging on the same line, comply with the CTGrecommended YOM content limit. Alternatively, such lines may comply with aweighted averaging limitation orinstall and operate a capture and control system that reduces YOM emissions by specified percentages. The proposed regulations also require that printing lines that meet the CTG's prescribed applicability threshold comply with work practice requirements for cleaning materials. Lithographic Printing Materials. Theproposed regulations provide that the existing requirements regarding fountain solutions and cleaning materials apply to

sources that meet the applicability threshold specified in the CTG, subjectto certain exclusions. Additionally, the proposed regulations require that afterburners or other approved control devices installed·on heatset web offset lithographic printing lines reduce YOM emissions by specified percentages or to a maximum afterburner exhaust outlet concentration. Letterpress Printing Materials. The proposed regulations require that heatsetweb letterpress printing lines that meet the CTG's prescribed applicability threshold install afterburners or other approved control devices that reduce YOM emissions by specified

8percentages orto a maximum afterburner exhaust outlet concentration. All letterpress printing lines that meet the CTG's lower applicability threshold must complywith work practices for cleaning materials. Such lines must also complywith either a YOM content limit or YOM composite partial vaporpressure limit for as-used cleaning solutions, subjectto a CTG-recommended exclusion for up to 110 gallons ofcleaning materials per year. IV. GEOGRAPHIC REGIONS AND SOURCES AFFECTED The geographic regions subject to the proposedregulations arethe two areas designated as nonattainment for the 8-hourozone standard: 1) the Chicago-Gary-Lake County, IL-lN designated area, which includes Cook, DuPage, Grundy (partial-Goose Lake and Aux Sable Townships), Kane, Kendall (partial-Oswego Township), Lake, McHenry, and Will Counties; and 2) the S1. Louis, MO-IL designated area, which includes Jersey, Madison, Monroe, and S1. Clair Counties. 40 CFR 

### § 81.314. The proposed regulations are generally expected to affectboth new and existing

sources that are covered by a Group II CTG, are located in the Chicago orMetro East nonattainment areas, and meet the applicability criteria specified in theregulations. Appendix B to the TSD lists the sources potentiallyaffected bytheproposed regulations. 

### V. TECHNICAL FEASIBILITY AND ECONOMIC REASONABLENESS

The technology for controlling YOM emissions from Group II product categories is both technically feasible and economicallyreasonable. Affected sources can meet the requirements in the proposed amendments through a number ofreadily available control techniques.

9Control techniques for reducing YOM emissions from industrial cleaning solvents include work practices, material reformulation or substitution (namely, the use oflowYOM cleaning solvents, no-YOM solvents, orlow vaporpressure solvents), and add-on controls ormodifying equipment. Similarly, material reformulation, add-on controls, and workpractices for coatings and cleaning materials are available YOM reduction techniques for flat wood paneling coating lines. See Technical SupportDocument. YOM control approaches for flexible packagingprinting lines include material reformulation, add-on controls such as thermal oxidizers, catalytic oxidizers, and carbon adsorbers, and workpractices for cleaning materials. Forlithographic printing lines, control options include add-on controls for heatset web offset lithographic printing lines, such as thermal afterburners, catalytic afterburners, and condenser filter systems, fountain solution reformulation (such as the use ofalcohol substitutes), process modifications for fountain solutions, and material reformulation or substitution for cleaning solutions. Control approaches for letterpresses are similar to those available for lithographic printing lines (although letterpresses do not utilize fountain solutions). Technical Support Document. In the Technical Support Document, the IllinoisEPA explains in detail thatthe above control approaches are economically feasible, particularly as many ofthe techniques are already widely used by the affected industries. 

### VI. COMMUNICATION WITH INTERESTED PARTIES The Illinois EPA engaged in extensive outreach onthis proposal. On November 5,2008, the Illinois EPA posted a draft oftheproposedrule and copies ofthepertinent CTGs on its website for public comment. The Illinois EPA subsequently engaged in

10numerous conference calls and exchanged correspondence with representatives of affected sources regarding the proposal. Illinois EPA received several comments on the draftrule, and this proposal incorporates many ofthe concerns and suggestions set forth in those comments. Such comments can generally be categorized into the following areas: appropriate applicability thresholds and exclusions, methods ofcalculating applicability thresholds, appropriate control requirements, simplification ofrecordkeeping and reportingrequirements, and revisions to proposed definitions. These regulations are being proposed after the interested parties have had an opportunity to review the proposal and discuss any issues with the Illinois EPA. 

### VII. SYNOPSIS OF TESTIMONY The Illinois EPA plans to call David Bloomberg, Compliance UnitManager, Compliance Section, Bureau ofAir, 11linoisEPA, as awitness at hearing, Mr. Bloombergwill testifyregarding theproposed amendments and will answer questions, Written testimony will be submittedpriorto hearing in accordance with the Board's procedural rules'. 

### VIII. THE ILLINOIS EPA'S PROPOSAL The following is a Section-by-Section summary ofthe Illinois EPA's proposal. 

### 35 Ill. 

### Adm. Code 211 Subpart B: Definitions The Illinois EPAproposes amending current definitions in, and adding new definitions to, Part 211. 

### Section 211.1000 Class II Finish

11

### The Illinois EPAproposes adding a definition for Class IT finish. This definition is necessary for SubpartF. Section 211.1745 Digital Printing The Illinois EPA proposes adding a definition for digital printing. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.1878 Electrical Apparatus Component The Illinois EPAproposes adding a definition for electrical apparatus component. This definition is necessaryfor Section 2181219.187 ofSubpartE. Section 211.1885 Electronic Component The Illinois EPAproposes amending the definition ofelectronic component by extending the application ofthe definition to Section 218/219.187 andby adding an exception to the definition. These revisions are necessary for Section 218/219.187 of Subpart E. Section 211.2355 FlatWood Paneling The Illinois EPAproposes adding adefinition for flat wood paneling. This definition is necessary for SubpartF. Section 211.2356 FlatWood Paneling Coating Line The Illinois EPA proposes adding adefinition for flat wood paneling coating line. This definition is necessary for SubpartF. Section 211.2368 Flexible Packaging The Illinois EPAproposes adding adefinition for flexible packaging. This definition is necessary for Subpart H. Section 211.2615 General Work Surface

12

### The Illinois EPAproposes adding a definition for general work surface. This definition is necessary for Section 2181219.187 

### ofSubpart E. Section 211.2830 Heatsct The Illinois EPA proposes amending the definition of"heatset" to include letterpress printing lines. This revision is necessary for SubpartH. Section 211.2855 Heatset Web Letterpress Printing Line The Illinois EPA proposes adding a definition forheatset web letterpress printing line. This definition is necessary for SubpartH. Section 211.2965 High Precision Optic The illinois EPA proposes adding a definition for highprecision optic. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.3215 Janitorial Cleaning The illinois EPA proposes adding a definition forjanitorial cleaning. This defmition is necessary for Section 218/219.187 ofSubpartE. Section 211.3305 Letterpress Printing Line The Illinois EPA proposes adding a definition for letterpress printing line. This definition is necessary for Subpart H. Section 211.3555 Maintenance Cleaning The Illinois EPA proposes adding a definition for maintenance cleaning. This defmition is necessary for Section 218/219.187 ofSubpartE.

Section 211.3705 Medical Device

.The Illinois EPAproposes adding adefinition for medical device. This definition is necessary for Section 2181219.187 

### ofSubpart E.

13

### Section 211.3707 Medical Device and Pharmaceutical Manufacturing The Illinois EPA proposes adding a definitiou for medical device and pharmaceutical manufacturing

.. This definition is necessary for Section 2I8/219.187 of SubpartE. Section 211.4065 Non-Heatset The Illinois EPA proposes amending the definition of"non-heatset" to include letterpress printing lines. This revision is necessary for SubpartH. Section 211.5335 Radiation Effect Coating TheIllinois EPA proposes adding a definition for radiation effect coating. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.5535 Repair Cleaning The Illinois EPA proposes adding a definition for repair cleaning. This definition is necessary for Section 218/219.187 ofSubpartE. Section 211.5585 Research and Development Operation The illinois EPA proposes adding a definition for research and development operation. This definition is necessary for Section 218/219.187 ofSubpartE. Section 211.5860 Scientific Instrument The Illinois EPA proposes adding a defmition for scientific instrument. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.5875 Screen Printing The Illinois EPA proposes adding a definition for screen printing. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.5885 Screen Reclamation The Illinois EPA proposes adding a definition for screen reclamation. This 14definition is necessary for Section 218/219.187 ofSubpartE. Section 211.6405 Sterilization Indicating Ink Thc Illinois EPA proposes adding a definition for sterilization indicating ink. This definition is necessary for Section 218/219.187 ofSubpartE. Section 211.6425 Stripping The Illinois EPA proposes adding a definition for stripping. This definition is necessary for Section 218/219.187 ofSubpartE. Section 211.6535 Surface Preparation Theillinois EPA proposes adding a definition for surface preparation. This definition is necessary for Section 218/219.187 ofSubpart E. Section 211.7290 Wood Furniture The Illinois EPA proposes amending the definition of"wood furniture" by excluding flat woodpaneling from such definition. This revision is necessary for Subpart F. 35 III. Adm. Code 2181219 SubpartA: General Provisions Section 218/219.106 Compliance Dates The Illinois EPAproposes adding a new subsection (e) to Section 218.106 and a

new subsection (c) to Section 219.106, which establish May 1, 2010, as the compliance date for sources subjectto the flat woodpaneling emission limits. Subpart E: Solvent Cleaning Section 

### 2181219.181 Solvent Cleaning in General

15The Illinois EPA proposes changing the title ofthis Section to "Solvent Cleaning Degreasing Operations." The Illinois EPA also proposes amending this Section to specifYthat Sections 2181219.182 through 218/219.184 and Section 218/219.186 are applicable to cold cleaning, open top vapor, and conveyorized degreasing operations. Section 218/219.187 Other Industrial Solvent Cleaning Operations The Illinois EPA proposes adding Section 218/219.187. Subsection (a) provides thatthe requirements in Section 218/219.187 apply to all cleaning operations which use organic materials at sourccs that emit 6.8 kg/day (IS Ibs/day) Ormore ofVOM from cleaning operations at the source, in the absence ofair pollution control equipment. Subsection (a)(2), however, exempts numerous types ofcleaning operations from some

or all ofthe limitations in Section 218/219.187. Subsection (a) also defines "cleaning operations." Subsection (b) provides that no source subject to Section 218/219.187 shall perform subject cleaning operations unless the source complies with the applicable YOM content limitation, uses cleaning materials with a composite vapor pressure ofno more than 8.0 mmHg measured at 20 degrees Celsius, or installs and operates an emissions control system that reduces YOM emissions from the subject cleaning operation by at least 85 percent overall. Subsection (c) provides that sources shall demonstrate compliancewith this Section by using the applicable testmethods and proc·edures in Section 218/219.187(g) and by complying with all applicable recordkeeping and reporting requirements in Section 218/219.187(e).

16Subsection (d) provides that, for each subject cleaning operation, subject sources shall cover open containers, minimize air circulation around the cleaning operation, properly dispose ofused solvent and shop towels, and utilize equipmentpractices that milllmlZe emISsIOns. Subsection (e) establishes recordkeeping and reporting requirements for sources subject to or exempt from the limitations ofthis Section. Subsection (e)(l) provides that, by May 1, 2010, sources exempt from the limitations ofSection 218/219.187 because of the criteria in Section 218/219.187(a)(I) shall submit a certification to the Illinois EPA that includes a <)eclaration that the source is exempt, as well as calculations which demonstrate that combined emissions ofVOM from cleaning operations at the source

never equal or exceed 6.8 kg/day (15 lbs/day). Such sources shall notify the minois 

### EPA ofanyrecords that show that the combined emissions ofVOM from cleaning operations at the source ever equal or exceed 6.8 kg/day (15 lbs/day). Subsection (e)(2) provides that, byMay 1,2010, all sources subject to Section 2181219.187 shall submit a certification to the Illinois EPA that includes I) a declaration that all subject cleaning operations are in compliance with the requirements ofthis Section; 2) identification ofeach subject cleaning operation and each YOM-containing cleaning solution used in such operation; 3) the limitation with which each subject cleaning operation will comply, and ifcomplying with the emissions control system requirement, what type ofemissions control system will beused; 4) initial documentation that each subject cleaning operation will comply with the applicable limitation; 5) identification ofthe method that will be usedto demonstrate continuing compliance with the applicable limitations; 

### 6) a description ofthe practices and procedures that the source

17will follow to ensure compliance with the limitations ofSection 218/219.187(d); and 7) a description ofeach cleaning operation exemptpursuant to Section 218/219.187(a)(2), if any, and a listing ofthe emission unites) on which the exempt cleaning operation is performed. Subsection (e)(3) provides additional recordkeeping and reporting provisions for

sources complying with the YOM content limitations in subsection (b)(l) ofSection 2181219.187. Subsection (e)(

### 4) provides additional recordkeeping and reporting provisions for

sources complying with the YOM composite partial vaporpressure limitations in subsection (b)(2) ofSection 218/219.187 Subsection (c)(5) provides additional recordkeeping and reporting provisions for

sources complying with the emissions control system requirements in subsection (b)(3) of Section 218/219.187. Subsection (e)(6) provides that all sources subject to the requirements of subsections (b) and (d) ofthis Section shall notify the Illinois EPA ofanyviolation of such subsections byproviding adescription ofthe violation and copies ofrecords documenting the violation to the illinois EPA within 30 days following the occurrence of the violation. Subsection (e)(7) provides that all records required by subsection (e) shall be retainedbythe source for three years and shall be made available to the Illinois EPA upon request. Subsection (f) establishes monitoring requirements for emissions control systems ifsuch systems are used to demonstrate compliance.

18Subsection (g) establishes requirements regarding testing to demonstrate compliance with Section 218/219.187. Subpart F: Coating Operations Section 218/219.204 Emission Limitations The Illinois EPA proposes amending subsection (c) to provide that the paper coating limitation shall not apply to any owner or operator ofapapercoating line on which lithographic or letterpress printing is performed ifthe papercoating line complies with the applicable emissions limitations in SubpartH ofthis Part. The Illinois EPA proposes adding subsection (p) to Section 218.204 and subsection (0) to Section 219.204, which restrict the VOM content offlat wood paneling coatings to 0.25 kg VOMII coatings or 0.35 kg VOMII solids or less. Section 218/219.205 Daily-Weighted Average Limitations The Illinois EPA proposes amending subsection (a) ofthis Section to include flat wood paneling coating lines in the daily-weighted averaging alternative. Section 218/219.207 Alternative Emission Limitations The Illinois EPA proposes amending subsection (a) ofthis Section, adding subsection (I) to Section 218.207, and adding subsection (k) to Section 219.207 to include flat wood paneling coating lines in the alternative emissions limitations option. The proposed subsections provide that a flat wood paneling coating line may utilize a capture system and control device ifsuch systemprovides at least 90 percentreduction in the overall emissions ofVOM from the coating line or tlle owneroroperator ofthe flat wood paneling coating line complies with all requirements set forth in subsection (b)(2) ofthis Section.

19The lllinois EPA also proposes amending Section 218.207(h)(1) to correctthe formatting ofan equation. Section 218/219.210 Compliance Schedule The Illinois EPA proposes adding subsection (g), which provides that, on and after a date consistentwith Section 218/219.106, sources subjectto the flat wood paneling coating emission limitations shall comply with the applicable provisions in SubpartF. Section 218/219.211 Recordkeeping and Reporting The Illinois EPA proposes amending subsections (c) and (d) to provide that, for flat wood paneling coating lines, YOM content infoffilation shall be maintained and/or reported in terms ofweight ofVOM pervolume ofcoatings or solids, as applicable, as applied each day on each coating line. The illinois EPA also proposes correcting a spelling errorin Section 2l8.2II(c)(3)(A). The Illinois EPAproposes amending subsection (e) to provide that flat wood paneling coating lines complying pursuantto Section 218/219.207 shall complywith the recordkeeping and reportingrequirements set forth in subsection (e). The Illinois EPAproposes adding subsection (g), which establishes recordkeeping andreporting requirements for flat wood paneling coating lines subject to the work practice requirements set forth in Section 218/219.217. Finally, the Illinois EPA proposes adding a space and deleting a space in Section 218.211(b)(I). Section 218/219.212 Cross-Line Averaging to Establish Compliance for Coating 

### Lines

20The Illinois EPA proposes amending this Section to provide that the cross-line averaging alternative is not available to flat wood paneling coating lines. Section 218/219.217 Wood Furniture Coating Work Practice Standards The Illinois EPAproposes changing the title ofthis Section to "WoodFurniture Coating and Flat Wood Paneling Coating Work Practice Standards." The Illinois EPA also proposes amending this Section to provide that flat wood paneling coating lines are subjectto the existing cleaning and storage workpractice requirements in this Section. The Illinois EPA proposes adding additional cleaning and storagerequirements for flat wood paneling coating lines as well; specifically, the Illinois EPAproposes requiring that such coating lines minimize spills ofVOM containing coatings, thinners, and cleaning materials, minimize emissions ofVOM during cleaning activities, and keep mixing vessels which contain YOM coatings and other materials closed exceptwhen specifically in use. SubpartH: Printing and Publishing Section 218/219.401 Flexographic and Rotogravure Printing The Illinois EPA proposes amending this Section to separate requirements that are applicable priorto thenew compliance date from those applicable after the new compliance date. The Illinois EPA proposes amending subsection (a) to provide that, on and after May 1, 2010, owners and operators offlexographic orrotogravureprinting lines that do notprint flexible packaging and that are complyingwith subsection (a) shall comply with the existing YOM content limitations. Owners and operators offlexographic or rotogravure printing lines thatprint flexible packaging orthatprint flexible packaging

21and non-flexiblepackaging on the same line shall restrict the YOM content ofcoatings and inks to .8 kg VOM/kg solids applied or.l6 kg VOM/kg materials applied Orless. The Illinois EPAproposes amending Scction 21 81219.401 (b) to provide that, on and after May I, 2010, owners and operators offlexographic orrotogravure printing lines that do notprint flexible packaging and that are complying with subsection (b) shall complywith the existing weighted averaging requirements. Owners and operators of flexographic orrotogravure printing lines that print flexible packaging, or thatprint flexible packaging and non-flexiblepackaging on the same line, and that are complying with subsection (b) shall not apply coatings orinks on the subjectprinting line unless the weighted average, byweight, YOM content ofall coatings and inks as applied each day

on the subjectprinting line does not exceed the YOM limitations specified in amendments to subsection (a) ofthis Section. The Illinois EPA proposes inserting equations for calculating the weighted average YOM content for such lines. 2 The lllinois EPA also proposes amending Section 218.401(b)(l)(A) to correct a typographical error in the existing equation, and Section 219.401(b) to correct spacing

errors in the existing equations. The Illinois EPA proposes amending subsection (c) to provide that, on and after May 1, 201 0, the owner oroperator ofa flexographic orrotogravure printing line that does not printflexible packaging and that is complying with subsection (c) shall equip the printing line with a capture system and control device thatcomplies with the existing control efficiency requirements. The owner or operator ofa flexographic orrotogravure printing line that prints flexible packaging shall equip theprinting line with a capture system and control device that provides an overall rcduction in YOM emissions of65·80

2 For ease ofreading, however, the equations are not underlined in the text ofthe proposed rule. 22percent, depending On the dates that theprinting line and control system were first constructed at the subject source. The owner or operator ofaflexographic orrotogravure printing line that prints flexible packaging and non-flexible packaging on the same line shall complywith the overall control efficiency requirements set forth in either subsection (c)(I)(D) or subsection (c)(3) ofthis Section, whicheveris more stringent. The Illinois EPA proposes amending subsection (c)(6) to specify the printing lines that arerequired to perform testing pursuantto this subsection. The Illinois EPA proposes adding subsection (d), which provides that VOMcontaining cleaning materials associated with flexographic orrotogravure printing lines thatprint flexible packaging orprint flexible packaging and non-flexible packaging on the same line shall be kept, stored, and disposed ofin closed containers, and conveyed from one location to anotherin closed containers orpipes. Section 218/219.402 Applicability The Illinois EPA proposes adding subsection (b), whichprovides that the limitations ofSection 218/219.401(d) apply to all flexographic and rotogravureprinting lines that print flexible packaging orprint flexible packaging and non-flexiblepackaging

on the same line at sources where the combined emissions ofVOM from all flexographic and rotogravure printing lines total 6.8 kg/day (15 Ibs/day) ormore, in the absence ofair pollution control equipment. Section 218/219.403 Compliance Schedule The Illinois EPAproposes adding subsections (e), (f), and (g), which establish May I, 2010, as the compliance date for the requirements setforth in the proposed amendments.

23

### Section 218/219.404 Recordkeeping and Reporting The Illinois EPA proposes amending this Section to reference recordkeeping and reporting compliance dates for printing lines subject to the limitations in the proposed amendments to Section 218/219.401. The Illinois EPA also proposes amending subsections (c) and (d) to clarify that the owner or operator ofaprinting line subject to the requirements in Section 218/219.401 (a)(2)(B) or (b)(3) shall certify in accordance with subsection (c)(l) Or (d)(1), as applicable, even ifthe owner or operator ofsuch line submitted a certification priorto January 1,2010. The Illinois EPA proposes amending subsection (e) to provide that.ifthe owneror operator ofaprinting line is notrequired to perform testing ofa capture system and control device pursuantto Section 218/219.401(c)(6), the owner or operator shall subm.it

a certification to the Agency that includes specified information. The Illinois EPA also proposes amending this subsection to provide that, by May 1, 2010, owners or operators ofprinting lines subject to Section 218/219.401(c)(3) or (c)(4) shall submit to the Illinois EPA records documenting the dates each subjectprinting line and control device were constructed at the subject source. The Illinois EPAproposes adding subsections (f), (g), and (h). Subsection (f) establishes recordkeeping and reporting requirements for any owner or operator ofa flexographic orrotogravure printing line that prints flexible packaging orprints flexible packaging and non-flexible packaging on the same line and which is exempt from the limitations ofSection 218/219.401(d)because ofthe criteria in Section 218/219.402(b). Subsection (g) establishes recordkeeping and reporting requirements for any owner or

24operator ofaprinting line subjectto the limitations ofSection 218/219.401 (d). Subsection (h) provides that all records required by subsections 

### (f) and (g) shall be retained for three years and shall bemade available to the Agency upon request. Section 2181219.405 Lithographic Printing: Applicabilitv The Illinois EPA proposes amending this Section to separate requirements that are applicable priorto the new compliance date from those applicable after the new compliance date. The Illinois EPA also proposes deleting requirements that were only applicable until March 15, 1996, and reformatting/renumbering the remaining subsections accordingly. The Illinois EPA proposes adding anew subsection (c) to provide that, on and afterMay 1, 2010, the requirements in Sections 218/219.407(a)(I)(B) through (a)(I)(E) and 218/219.407(b) and an applicable provisions in Sections 218/219.408 through 218/219.411 ofthis Subpart shan apply to an owners oroperators ofheatsetweb offset lithographic printing tine(s) ifthe combined emissions ofVOM from all lithographic printing Ene(s) at the source (including solvents used for cleanup operations associated with the lithographic printing line(s)) ever exceed 45.5 kg/day (100 lbs/day), before the application ofcapture systems and control devices. On and afterMay 1,2010, Sections 218/219.407(a)(l)(A), 218/219.407(a)(2) through (a)(5), and all applicable provisions in Sections 218/219.408 through 218/219.411, shall apply to all owners or operators of lithographic printing lines at sources where the combined emissions ofVOM from an lithographic printing lines at the source (including solvents used for cleanup operations associated with the lithographic printing lines) ever total 6.8 kg/day (15 lbs/day) ormore. Finany, subsection (c) provides that, at sources where the combined emissions ofVOM

25from all lithographic printing line(s) at the source equal or exceed 6.8 kg/day (15 lbs/day) but do not exceed 45.5 kg/day (100 lbs/day), before the application ofcapture systems and control devices, certain specified exclusions apply unless the owner or operator ofthe

source certifies that the source will not make use ofany such exclusions. Section 218/219.406 Provisions Applving to ReatsetWeb Offset Lithographic Printing Prior to March 15,1996 The TIlinois EPAproposes repealing this Section, as it contains requirements that

.were applicable prior to March IS, 1996. Section 2181219.407 Emission Limitations and Control Requirements for Lithographic Printing Lines On and 

### Mter March 15, 1996 The TIlinois EPAproposes amending this Section by deleting references to the previous compliance date ofMarch IS, 1996, and separating requirements that are applicable priorto the new compliance date from those applicable after the new compliance date. The Illinois EPA also proposes changing the YOM content limitations for fountain solutions from "by volume" to "by weight," as USEPAhas informed the lllinois EPA that this is the appropriate way to measure the limit. The lllinois EPA proposes amending subsections (a)(I)(C) and (b) to provide that,

on and afterMay 1,20I0, owners or operators ofsubject heatset web offset lithographic printing lines shall install and operate an afterburner or other approved control device so that YOM emissions from the press dryer exhaust are reduced by 90-95 percent, by weight, depending on the date that the afterburner or othercontrol device was first constructed at the subject source, or to a maximum afterburner exhaust outlet concentration of20 ppmv (as carbon).

26The Illinois EPA proposes amending subsection (a)(1 )(D) to delete references to monitoring requirements already set forth 

### in Section 218/219.410. The Illinois EPA proposes amending subsection (a)(4) to provide that, on and afterMay I, 2010, owners or operators ofsources that meet the applicability criteriain Section 218/219.405(c)(3) and do not certifypursuantto Section 218!219.411(g)(I)(B) that the sourcewill not make use ofany ofthe exclusions 

### in Section 218/219.405(c)(3) shall not cause or allow theuse ofa cleaning solution on any lithographic printing line unless the YOM content ofthe as-used cleaning solution is less than or equal to 70 percent, by weight, or shall satisfy the alternative YOM composite partial vaporpressure limitation. The Illinois EPA proposes amending subsection (a)(5) to specify that the storage and disposal requirements for cleaning materials apply except when such materials are specifically 

### in use. Section 218/219.408 Compliance Schedule for Lithographic Printing On and After March 15, 1996 The Illinois EPAproposes repealing this Section, as thepertinentcompliance dates are set forth in Section 218/219.405. Section 218/219.409 Testing for Lithographic Printing 

### On and After March 15, 1996 The Illinois EPA proposes deleting a reference to the previous compliance date of March IS, 1996, in the title to this Section. Section 218/219.411 Recordkeeping and Reporting for Lithographic Printing The Illinois EPAproposes amending this Sectionby deleting references to the previous compliance date ofMareh IS, 1996, and clarifying therequirements that apply

27to sources priorto the new compliance date and those that apply on and afterthe new compliance date. The Illinois EPA also proposes inserting into this Section the equation fOT calculating maximum theoretic emissions ofVOM, which was previously contained in Section 2181219.406. The Illinois EPA proposes adding a new subsection (b), which contains recordkeeping and reporting provisions forprinting lines that are exempt on and after

.May I, 2010, andrelettering theremaining subsections accordingly. Subsection (b)(l)

governs lithographic printing lines exemptpursuantto Section 2l8/2l9.405(c)(2). Along with standardrecordkeeping andreporting requirements, the Illinois EPAproposes an emission a<ljustrnentfactor to be usedwhen determining VOM emissions from inks used On lithographic printing line(s) at the source, as well as an emission adjustment factor to be used when calculating emissions from used shop towels ifthe YOM composite vapor pressure ofeach associated cleaning solution is less than 10 mmHg measured at 20"C (68°F) and the shop towels are kept iil closed containers. The Illinois EPA proposes that, as an alternative to the YOM emission calculations set forth in subsection (b)(l)(B), a source may determinethat it emits below 6.8 kg/day (15lbs/day) ofVOM ifit complies with material use limitations during each calendarmonth. The Illinois EPA proposes that the material use alternative onlybe available to sources with only one type oflithographic printing operation (e.g., a source with only heatset web offset lithographic printing operations). Ifa source exceeds the material use limitation in any given month, the source shall complete emissions calculations pursuantto subsection (b)(I)(B) within 15 days ofthe end ofthatmonth. If

28a source exceeds thematerial use limitations for six consecutive months, the source is no longer eligible for the material use alternative. Subsection (b)(2) governs heatset web offset lithographic printing lines exempt pursuant to Section 2IS/2l9.405(c)(l) butnot exemptpursuantto Section 2IS/219.405(c)(2). Along with standardrecordkeeping and reportingrequirements, the Illinois EPA proposes an emission adjustmentfactor to be used when determining YOM emissions from inks used on lithographicprinting line(s) at the source, and an emission adjustment factor to be used when calculating emissions from used shop towels ifthe YOM composite vaporpressure ofeach associated cleaning solution is less than 10 mmHg measured at 20°C (6SoF) and the shop towels are kept in closed containers. The Illinois EPAproposes amending subsection (c) to providethat the recordkeeping requirements in subsections (c)(l) or (c)(2) do not applyto sources utilizing the material use limitation alternative. The lllinois EPA also proposes deleting subsection (c)(3). The Illinois EPAproposes amending subsection (d) to provide that sources complying with the add-on control device requirement shall include in their initial certification to the Illinois EPA the date that the device was first constructed atthe subject source. TheIllinois EPA also proposes amending subsection (d) to change the frequency that owners or operators ofheatset web offset lithographic printing lines complying with the add-on control device requirements are required to checkthe air flow direction or airpressure ofthe dryer and press room from once a day to once per calendar month.

29The Illinois EPA proposes amending subsection (e)(l)(C) to provide that a source subject to fountain solution YOM contentlimitations shall include in its initial certification a statement that the fountain solution will comply with the YOM content limitations in Section 218/219.407(a)(l)(A), (a)(2), or (a)(3), as applicable. The Illinois EPA proposes amending subsection (e)(2)(C) to provide that the weight ofeach componentused in a fountain solution batch shall be recorded by sources, ifapplicable. The Illinois EPA also proposes deleting subsection (e)(4). The Illinois EPA proposes amending subsection (£)(1) to specify that lithographic printing line cleaning operations that are excluded pursuant to Section 218/219.405(c)(3)(C) are notrequired to submit a certification pursuantto subsection (£). The Illinois EPA also proposes deleting subsections (£)(1 )(A), (£)(l)(C), and (£)(4), and amending the relettered subsection (£)(l)(A) to provide that a source subject to the cleaning requirements in Section 2181219.407shall include in its initial certification a statement that the cleaning solution will comply with the limitations in Section 218/219.407(a)(4). The Illinois EPA proposes adding subsection (g), which sets forth the recordkeeping and reporting requirements for owners or operators oflithographic printing line(s) subject to one ormore ofthe exclusions set forth in Section 218/219.405(c)(3). Such owners oroperators shall submit an initial certification to the Illinois EPA, collect and record specifiedinformation for each subject printing line, notify the Agency ifthe printing line everbecomes ineligible for the exclusions set forth in Section 218/219.405(c)(3), and, ifchanging between opting out ofsuch exclusions and utilization

30ofthe exclusions, submit an additional certification, infonningthe Illinois EPA ofthe change.The Illinois EPAproposes adding subsection (i), which sets forth emission adjustmentfactors that may be used when calculating YOM emissions from heatset web offset lithographic printing operations for purposes otherthan the applicabilitythresholds in Section 218/219.405. Section 2J 8/2J9.412 Letterpress Printing Lines: Applicability The Illinois EPAproposes adding this Section, which addresses the applicability oftheproposed letterpress printing regulations. Subsection (a) ofthis Sectionprovides that the limitations in Sections 218/219.413 through 218/219.416 applyto all owners or operators ofheatset web letterpressprinting lines ifsuch lines (including solvents used for cleanup operations associated with such lines) at the source have apotential to emit 22.7 Mg (25 tons) ormore ofVOMper year. Subsection (a) also provides that Sections 218/219.413 through 218/219.416 apply to all owners or operators ofletterpress printing lines at sources where the combined emissions ofVOM from all letterpress printing lines at the source (including solvents used for cleanup operations associated with the letterpress printing lines) everequal or exceed 6.8 kg/day (15 Ibs/day), inthe absence of airpollution control equipment. Subsection (b) provides that the requirements ofSection 218/219.413(a)(2) shall not applyto up to 416.3 liters (110 gallons) peryearofcleaningmaterials used on letterpress printing lines at a subject source.

31Subsection (c) provides that, on and afterMay 1, 2010, the recordkeeping and reporting requirements in Section 218/219.417 shall apply to all owners or operators of letterpress printing line(s). Subsection (d) provides that, ifaletterpress printing line at a source is orbecomes subject to one ormore ofthe limitations in Section 218/219.413, the letterpress printing lines at the source are always subject to the applicableprovisions ofSubpartH. Section 218/219.413 Emission Limitations and Control Requirements for Letterpress Printing Lines The Illinois EPA proposes adding this Section. Subsection (a) provides that heatset web letterpress printing lines that meet the applicability requirements ofSection 218/219.412(a)(l) shall maintain the air pressure in the dryer lower than the airpressure ofthe press rpom and install and operate an afterburner that reduces YOM emissions by 90-95 percent, by weight, depending on the date that the afterburner was first constructed at the subject source, or to amaximum afterburner exhaust outlet concentration of20 ppmv (as carbon). Such printing lines shall also equip the afterburnerwith applicable monitoring equipment and operate the afterburner at all times when the printing line is in operation, except as provided in Section 218/219.107. subseciion (a) furtherprovides that no owneror operatorofsubject letterpress printing lines shall use cleaning solutions on such lines unless the YOM content ofthe asused cleaning solution is less than or equal to 70 percent, by weight, or the YOM composite partial vaporpressure ofthe as-used cleaning solution is less than 10 mmHg at 20 degrees Celsius. Cleaning materials mustbe kept, stored, and disposed ofin closed containers, except when specifically in use.

32Subsection (b) provides that heatsel web letterpress printing lines mayuse a control device otherthan an afterburner ifthe control device meets the YOM emission reduction requirements in subsection (a) and is approved bythe Illinois EPA and USEPA

as federally enforceable permitconditions. Section 218/219.415 Testing for Letterpress Printing Lines The Illinois EPAproposes adding this Section, which sets forth the testing requirements that apply to owners or operators ofletterpress printing lines subject to Section 218/219.413. Subsection (a) provides that testing to demonstrate compliance with 218/219.413 shall be conducted at the expense ofthe owner or operator within 90 days ofa request bythe Illinois EPA, and the owner or operator shall notify the Illinois EPA 30 days in advance ofconducting such testing. Subsection (b) describes the methods and procedures in Section 218f219.105(d) and (f) that shall be used for testing to demonstrate compliance with the add-on control device requirements ofSection 218/219.413(a)(I)(B) and (b)(I). Subsection (c) provides that testing to demonstrate compliance with the YOM contentlimitations in Section 21 8/219.413(a)(2)(A) and to determine the YOM content of cleaning solvents, cleaning solutions, and inks shall be conductedusing the applicable test methods and procedures in Section 218/219.105(a). The manufacturer's specifications for YOM content for cleaning solvents and inks maybe used ifsuch specifications are based on results oftests conducted in accordance with Section 218/219.105(a).

33Subsection (d) provides that testing to demonstrate compliance with Section 21 8/2I9.413(b) shall be conducted as set forth in the owner or opcrator's plan approved bythe Illinois EPA and USEPA as federally enforceable permit conditions. Subsection (e) provides that testing to determine the YOM composite partial vaporpressure ofcleaning solvents, cleaning solvent cOncentrates, and as-used cleaning solutions shall be conducted in accordance with the applicable methods and procedures specified in Section 218/219.110, Section 218/219.416 Monitoring Requirements for Letterpress Printing Lines TheIllinois EPA proposes adding this Section. Subscction (a) provides that, ifan afterburner is used to demonstrate compliance, the owner or operator ofa heatset web letterpress printing line shall install, calibrate, maintain, and operate temperature monitoring devices with an accuracy of3° C or 5° F on the afterburner in accordance with Section 218/219.1 05(d)(2) and in accordance with the manufacturer's specifications. Monitoring shall beperformed at all times when the afterburner is operating. Such

owners or operators shall also install, calibrate, operate, and maintain in accordance with manufacturer's specifications a continuous recorder on the temperature monitoring devices with at least the same accuracy as the temperature monitor. Subsection (b) provides thatifa control device other than an afterburner is used to demonstrate compliance, the owner or operator ofa heatset web letterpress printing line shall install, maintain, calibrate, and operate such monitoring equipment as set forth in the owner or operator's plan approved by the Illinois EPA and USEPA pursuant to Section 218/219.413(b).

34Subsection (c) sets forth the monitoring requirements for owners or operators of letterpress printing lines relying on the YOM content ofthe cleaning solution to comply with Section 218/219.4I3(a)(2)(A), orrelying on the vaporpressure ofthe cleaning solution to comply with Section 218/219.413(a)(2)(B). Section 218/219.417 Rccordkeeping and Reporting for Letterpress Printing Lines The Illinois EPA proposes adding this Section. Subsection (a) provides that the

owner or operatorofaheatset web letterpress printing line exempt from any ofthe limitations ofSection 218/219.413 because ofthe criteria in Section 218/219.412(a)(1) shall submit a certification to the Illinois EPA that includes adeclaration that the source is exempt and calculations that demonstrate that the source's total potential to 

### emitVOM does not equal orexceed 25 tons peryear. Subsection (b) provides that the owner or operator ofaletterpress printing line exempt from any ofthe limitations ofSection 218/219.413 because ofthe criteriain Section 218/219.412(a)(2) shall submit a certification to the Illinois EPA that includes a declaration that the source is exempt, calculations that demonstrate that combined emissions ofYOM from all letterpress printing lines at the source never equal orexceed 6.8 kg/day (15 lbs/day), and a description and the results ofall tests used to determine the YOM content ofinks and cleaning solvents. Such sources shall also notify the Agency 

### if the combined emissions ofVOM from all letterpress printing lines at the source ever equal orexceed 6.8 kg/day (15 lbs/day). Subsection (b) furtherprovides that, as an alternative to the YOM emission calculations set forth in subsection (b)(l)(B), a source may determine thatitemits below 6.8 kg/day (151bs/day) ofVOM ifitcomplies with material usc limitations during each

35calendar month. The material use alternative shall onlybe available to sources with only

one type ofletterpress printing operation (e.g., a source with onlyheatsetweb letterpress printing operations). Ifa source exceeds the material use limitation in any givcn month, the source shall complete emissions calculations pursuant to subsection (b)(I)(B) within 15 days ofthe end ofthat month. Ifa source exceeds the material use limitations for six consccutive months, the source is no longer eligible for the material use alternative. Subsection (c) provides that, unless utilizing the material use altcrnative, the

owner or operator ofa lettcrpress printing line subject to the requirements 

### in subsection (a) or (b) ofthis Section shall collect and record either thc specified standard recordkeeping information or the specified purchase and inventoryrecordkeeping inforrnation. Subsection (d) provides that the owner or operator ofaheatsetweb letterpress printing line subject to Section 218f219.413(a)(I)(B) or (b)(1) ofthis Subpart shall submit a certification to the illinois EPA that includes identification ofeach heatsetweb letterpress printing line at the source, a declaration that each such line is in compliance with Section 218/219.413(a)(I) or (b), the type ofafterburner or other approved control device being**~sed** and the date that such device was first constructed at the subject source, the control requirements with which the printing line is complying, the results of all tests and calculations necessary to demonstrate compliance, and a declaration that the required monitoring equipmenthas been properly installed and calibrated. The owner or operator shall also collect and record specified information for each heatsetweb letterpress printing line and notify the Illinois EPA ofany violation ofSection 218/219.413(a)(I)(B) or (b)(l).

36operator shall also collect and record specified infonnation for each heatset web letterpress printing line and notify the Illinois EPA ofany violation ofSection 218/219.413(a)(1)(B) or (b)(1). Subsection (d) further provides that iftesting ofan afterburner or other approved control device is conducted pursuant to Section 218/219.415(b), the owner or operator shall submit a copy ofall test results to the Illinois EPA, as well as a certification that includes a declaration that all necessary tests and calculations have been perfonned, a statement whether theprinting line is in compliance with Section 218/2l9.413(a)(1 )(B) or (b)(I), and the operating parameters ofthe afterburner or other approved control device during testing. 

### Ifchanging its method ofcompliance between subsections (a)(1)(B) and (b) ofSection 218/219.413, the owner or operatormust certify compliance for the new method ofcompliance and perfonn all tests and calculations necessary to demonstrate compliance with suchmethod. Subsection (e) establishes recordkeeping and reporting requirements for letterpress printing line cleaning operations. Subsection (e) provides that the owner or operator ofa letterpress printing line shall certify to the Illinois EPA that an cleaning solutions, other than those excluded pursuant to Section 2l8.4l2(b), and the handling of all cleaning materials will be in compliance with Section 2l8/2l9.413(a)(2)(A) or (a)(2)(B) and (a)(3). The certification shall also include specified infonnation regarding the cleaning operations ofthe subjectprinting line. The owner or operator shall collect and record specified infonnation for each solution used on each letterpress printing line and notify the lllinois EPA ofany violation ofSection 218/219.413.

3716. Redesignation is therefore necessary to foreclose the risk that a future violation of the 1997 standard will implicate reclassification and, in turn, heightened control measures. 17. Further, the USEPA's future transition policy between the 1997 standard and the revised standard will most likelyimpose additional obligations upon areas that are still designated as nonattainment for the 1997 standard at the time final designations for the revised standard are made. (See, e.g., 40 C.F.R. 

### § 51.905(a)(l), which sets forth added requirements for

areas that were nonattainment for the I-hour ozone NAAQS atthe time nonattainment designations for the 1997 standard were finalized). 18. Any complications that arise in connection with the future transition policy, such as legal challenges,-couldpotentially affect such NAAs as well. Illinois, for example, was attaining the I-hour ozone standardbuthad not yet been formallyredesignated at the time the USEPA finalized nonattainment designations for the 1997 standard. Consequently, Illinois was subject to the USEPA's I-hour/8-hourtransition policies, and is still dealing withthe ramifications of several lawsuits that arose challenging, among otherthings, the transition portions ofUSEPA's 8-hourimplementation rules. (See, e.g., South CoastAir QualityMgt. Dist. v. Environmental ProtectionAgency, 472 F.3d 882 (D.C. Cir. 2006)). (One such ramification, for instance, is the continuedpossibility thatthe major source threshold for the Chicago NAA will be lowered from 100tons peryear (the threshold for moderate areas under the 8-hour standard) to 25 tons per year (the threshold for severe areas underthe I-hour standard)). 19. While the details ofUSEPA's transition policy, and whether such policy will likely result in litigation, is uncertain, atimelyredesignation to attainment (i.e., redesignation priorto the date the USEPA finalizes nonattainment designations for therevised standard) would render the above contingencies moot.

420. Redesignation is needed to ensure that Illinois avoids needless additional hurdles and reaps the benefits ofthe air quality planning efforts that led to attainment ofthe 1997 standard. 21. In light ofthe foregoing, it is necessary to expedite review in this matter. 22. As required by 35 Ill. Adm. Code Section 101.512, this Motion is accompanied by an Affirmation attesting that the facts cited herein are true. WHEREFORE, for the reasons set forth above, the Illinois EPA respectfullyrequests that the Board grant this Motion and expedite review in this matter. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~I/~~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

DATED: July 8, 2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

5BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: ) ) AME:t\TJ)MENTS TO 35 ILL. ADM. CODE 218, ) ORGANIC MATERIAL EMISSION ) STAi'IDARDS FOR THE CHICAGO AREA, ) 35 ILL. ADM. CODE 219, ORGANIC ) MATERIAL EMISSION STANDARDS FOR ) THE METRO EAST AREA, AND ) 35 ILL. ADM. CODE 211 AFFIRMATION R09- (Rulemaking-Air)

I, Dana Vetterhoffer, under oath, hereby state and affirm that I 

### am an Assistant Counsel for the Illinois EPA and that the facts cited in the foregoing Motion for Expedited Review are true and correct to the best ofmy information and belief.

# ~WIJn~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel**S~§glBED ~D**  SWORN TO BEFORE ME this

### ~'day**of~,** 2009

# 3~~~ NotaryPublic**~~~0~~~~~~~>'~~V~<~~~~~Y~_** 

### i: OFFICIAL SEAL :( ;: BRENDA BOEHNER 

## ± ::: NOTARY PUBUC, STATE OF ILUNOIS :i: 

### i: MYCOMMISSION gxPIRES 11 ,a-2009

...**~·:.·:·** ......**~:··"'i'.p4'.:.+** ...*<lo

...**~9~OOOo!o.,.q,,.;** ..



### 6BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

CERTIFICATE OF SERVICE IN THE MATTER OF: AMENDMENTS TO 35 ILL. ADM. CODE 218, ORGANIC MATERIAL EMISSION STANDARDS FOR THE CHICAGO AREA, 35 ILL. ADM. CODE 219, ORGANIC MATERIAL EMISSION STANDARDS FOR THE METRO EAST AREA, AND 35 ILL. ADM. CODE 211 ) ) ) ) ) ) ) ) 

### ) 

# 10

# Jb (Rulemaking-Air) 

### RE'cegVEO

CLERK'S OFFICE



## JUl U 92009 STATe OF ILLINOIS 

### Pollution Control Soard I, the undersigned, an attorney, state that I have served the attached REGULATORY PROPOSAL entitled "AMENDMENTS TO 35 ILL. ADM. CODE 218, ORGANIC MATERIAL EMISSION STANDARDS FORTHE CHICAGO AREA, 35 ILL. ADM. CODE 219, ORGANIC MATERIAL EMISSION STANDARDS FORTHE METRO EAST AREA, AND 35 ILL. ADM. CODE 211," MOTION FORWAIVER, MOTION FOREXPEDITED REVIEW, and APPEARANCES ofthe Illinois Environmental Protection Agency upon the person to whom itis directed, by mailing it by first-class mail from Springfield, llIinois, with sufficientpostage affixed, to the following persons: John Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 WestRandolph, Suite 11-500 Chicago, Illinois 60601-3218 Virginia Yang Deputy Legal Counsel Illinois Department ofNatural Resources One Natural Resources Way Springfield, IL 62702 Matthew Dunn, Chief Division ofEnvironmental Enforcement Office ofthe Attorney General 188 West Randolph, 20th Floor Chicago, IL 60601

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~o,~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

### TECHNICAL SUPPORT DOCUMENT FOR CONTROLLING YOM EMISSIONS FROM LITHOGRAPIDC PRINTING, LETTERPRESS PRINTING, FLEXIBLE

PACKAGE PRINTING, FLAT WOOD PANELING COATING, AND INDUSTRIAL CLEANING OPERATIONS

DIVISION OF AIR

### POLLUTION CONTROL BUREAU OF AIR 

### ILLINOIS ENVIRONMENTAL PROTECTIONAGENCY SPRINGFIELD, IL 62702 APRIL 20091.0 INTRODUCTION Section 172 ofthe CleanAir Act (CAA) requires that state implementation plans (SJPs) for nonattainment areas, such as the Chicago and Metro-East St. Louis nonattainment areas (NAAs) in Illinois, must include requirements for "reasonably available control technology" (RACT) as it applies to emissions sources. I The Chicago NAA currently includes the entire counties ofCook, DuPage, Kane, Lake, McHenry, and Will, as well as Aux Sable and Goose Lake Townships in Grundy County, and Oswego Township in Kendall county. Madison, Monroe, St. Clair, and Jersey counties are part ofthe ozoneNAA in the St. LouislMetro-East geographic location. In March 2008, the United States Environmental Protection Agency (USEPA) strengthened the eight-hour ozone standard. It is likely that the same areas in Illinois that are currentlydesignated as nonattainment for the present standards will soon be designated as nonattainment for this revised standard. Reducing YOM emissions in these areas will likelyhelp Illinois achieve the newlyrevised NAAQS as well as satisfy CAA obligations. USEPA is expected to finalize the nonattainment designations in 2010, initiating a new cyele ofplanning and regulatory development. Obviously, suchplanninghas not occurred yet, so itis not possible to identify specific emission reduction measures needed to attain these standards. However, YOM emission reductions will improve ozone airquality, which will help to meet the new standards and should help to address any future requirements to implementRACT for the new standards. Section 182(b)(2)(A) ofthe CAA further requires that SIPs be revised to include RACT for volatile organic material (VOM) emissions sources that are coveredby a control techniques guideline (CTG) document issued byUSEPA after November 15, 1990, and before the area's date ofattainment. The USEPA defines RACT as "the lowest emission limitation that aparticular source is capable ofmeetingby the application ofcontrol technologythat is reasonably available considering technological and economic feasibility." (44 FR 53761, September 17, 1979.) In developing the CTGs for the categories covered bythis Technical SupportDocument (TSD), USEPA evaluated the sources of YOM emissions from the applicable industries, the available control possibilities to address the associated emissions, and the cost ofsuch control measures. Emissions ofVOM result from various points in theprocesses coveredbythis TSD. These YOM emissions react with otherpollutants inthe atmosphere, such as oxides ofnitrogen (NOx) and carbon monoxide (CO), to form ozone. Ozone formation is most active during the summermonths because the chemical reactions involved relyon direct sunlight and high ambient temperatuf(:'s. Ozone

1is apowerful oxidant, and as such reacts readily with awide range ofsubstances. 

### In hwnans, ozone irritates the respiratory system and reduces lung function. Laboratory studies suggest that itmay damage lung and othertissue. There is concern that this damage can impair breathing and reduce immunityto disease for people in good health, and the effectmay be more severe for people with preexisting respiratory diseases. Ozone oxidation can also impairplant tissue and reduce the yield ofsome crops, as well as damage materials such as rubber products. This TSD presents the rationale, docwnentation, and methodologyrelied uponto technicallyjustifythe Illinois EPA's proposedregulatory changes to control YOM emissions from the categories known collectively as the Consumer and Commercial Products, Group II, which includes lithographic printing, letterpress printing, flexible packaging printing, flat wood paneling coating, and industrial cleaning solvents. To assist in evaluating the potential for implementing new emission standards for Illinois sources, theIllinois Environmental Protection Agency (Illinois EPA) reviewed and evaluated the USEPA CTGs, as well as other available information, including regulations in other states and those already existing within Illinois. 

### In addition, Illinois EPA staffheJd conversations with stafffrom USEPA and other states, as well as with representatives from various industry groups. Based on this information, theillinois EPA determined the applicabilitythresholds for applieation ofcontrols and is recommending appropriate control measures. This TSD is based on the aforementioned documents and addresses the technological feasibility and economic reasonableness ofimplementing new standards for lithographic printing, letterpress printing, flexible package printing, flat wood paneling coating, and industrial cleaning processes. 

### 2.0 PROCESS DESCRIPTION AND SOURCES OF EMISSIONS 2.1 Lithographic Printing Offset lithographic printinghas abroadrange ofapplications, including books, magazines, periodicals, labels and wrappers, catalogs and direetories, financial and legal docwnents, business forms, advertising materials, newspapers, newspaperinserts, eharts and maps, calendars, tiekets and eoupons, greeting cards, and stamps. None ofthe above applications are exclusive to offsetprinting; othermodes of printing in the graphic arts industry can produce items such as thosementioned above. However, the newspaperindustry uses offset lithography predominantly, with over70 percent ofall newspapers in theUnited States printed by this method.

2Lithography is aplanographic method ofprinting; that is, theprinting and nonprinting areas are essentially in the same plane on the surface ofa thin metal "lithographic" plate. The distinction between the areas is maintained chemically; when the lithographic plate is made, the image area is rendered waterrepellent, and the nonimage area is rendered waterreceptive. 

### In offset lithographic printing, ink is transferred from the lithographic plateto a rubber-covered "intennediate," or "blanket," cylinder and then to the substrate. Transfer oftheink from the lithographic plate to the blanketcylinder, ratherthan directlyto the substrate, is the offset characteristic ofthis type ofprinting. A printing press is made up ofa number ofprinting units. Printing units are available thatprintboth sides ofthe substrate at the same time (aprocessknown as perfecting), as well as onlyone side (known as nonperfecting). Offset lithographic printing is also characterized bythe form inwhich the material to beprinted on - the substrate

- is fed to the press. 

### In sheet-fedprinting, individual sheets ofpaper or other substrate are fed to thepress. In web printing, continuous rolls ofpaper are fed to the press and the paper is cutto size afteritis printed. Lithographic inks are composed ofpigments, vehicles, binders, and other additives. The pigments provide the desired eolor and are composed oforganic and inorganic materials. Lithographic inks maybe heatset, where heatis required to setthe ink, ornon-heatset, where the inks are setby absorption into the substrate by oxidation or othermethods notrequiring added heat. Heatsetinks may contain up to 45 percent VOMs. Non-heatset inks havehigherboilingpoints than heatset inks and are less pasty. Theyusual1y contain less than 35 perecnt VOMs. Mostnon-heatsetinks used in sheet-fed printing .arebelow 25 percent YOM. A fountain solution is applied to the lithographic plate to renderthenonimage areas unreceptiveto ink. Since printing inks are oil-based and oil is repelled by water, the fountain solution is water-based. The fountain solution contains small quantities ofgum arabic or synthetic resins, acids, and buffer salts to maintain the pH ofthe solution, and a wetting agent or "dampening aid" to enhancethe spreadabilityofthe fountain solution across the printplate. The role ofthe dampening aid is to reduce the surface tension ofwater as well as increase viscosity. Isopropyl alcohol (IFA), a YOM, had been used as the primary dampening aid since the 1950s. Ethanol and normal propyl alcohol have also been used in this capacity. Before the 1980s, concentration ofalcohol in the fountain solution could range from 0 to 35 percent orhigher, with mostpresses usingbetween 15 and 20 percent. However, in more recent years, printers have significantly reduced

3fountain solution alcohol contents and often replaced alcohol completelywith otherdampening aids. Indeed, current I11inois rules forheatset web presses inthe NAAs require that subject sources use no more than 1.6percent alcohol, or 3 percent ifthe fountain solution is refrigerated; fountain solutions using only alcohol substitutes may use up to 5 percentYOM. Non-heatset web presses cannot use any alcohol and are subjectto the same 5 percent YOM limit. Sheet-fed presses are limited to 5 percent YOM content or 8.5 percent ifthe fountain solution is refrigerated. Cleaning solutions are used to remove excessprinting inks, oils, and paper components from press equipment. The solutions are petroleum-based solvents, often mixed with detergent and/or water. The cleaning compound maybe a single solvent, such as kerosene, or a combination ofsolvents. Cleaning solutions are used to wash the blankets, the rollers, the outside ofthe presses, and to remove excess inkresidue between colorchanges. Some cleaning is done automatically, while other cleaning is done manually. 2.2 Letterpress Printing Letterpress printing involves the use ofareverse-imaged raised surface that is inked and then pressed against a substrate to transfer the image. Letterpress operations make up a very small percentage oftheprinting industry compared to othertypes ofprinting (lithographic, flexographic, rotogravure). Indeed, according to information from the I11inois EPA's source inventory, no letterpress printing facility could be found in the Metro-EastNAA, with very few ofthese facilities found even in the Chicago NAA. Letterpress inks and lithographic inks are very similar, and letterpress operations also maybe accomplished through sheet-fed and web presses. Thus, ink emission sources are similarto those described above for lithographic printing. Letterpress operations do not use fountain solutions, but the cleaning solutions are once again similarto those used in lithographic printing operations. 2.3 Flexible Package Printing The existingregulations found in Sections 218/219.401-404 currently cover all rotogravure and flexographic printing. The modifications being proposed in this rulemaking coverboth types ofprinting, but only as they applyto flexible packaging. Flexiblepackaging means any package orpart ofapackage, the shape ofwhich canbe readily changed. Flexible packaging includes, butis not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coatedpaper orfilm, or any combination ofthese materials. Shrinkwrap labels or wrappers (butnot self-adhesive labels) printed on orin-line with a flexible packaging printingpress are also considered to be flexible packaging.

4Flexible packaging does not include folding cartons, gift wraps, hot stamp foils, wall coverings, vinyl products, decorative laminates, floor coverings, or tissue products. Rotogravure printing uses an image etched or engraved into a plate or cylinder. Inks, coatings, and adhesives maybe applied to a substrate through the rotogravure process. Flexographic printing has an image raised above the level oftheprinting plate, with the image carriermade ofrubber or other flexible material. Flexographie printing is better suited to shortproduction runs, in contrastto rotogravure printing, which is more useful for long runs. YOM emissions for both types ofprinting originate from the drying ofinks as well as solvents used to clean presses and othercomponents. According to the CTG for Flexible Package Printing, the use ofwater based inks is increasing. However, USEPA also noted, "Many facilities use hundreds of different inks to print various custom colors required by their packaging customers. Low [YOM] inks, coatings, and adhesives may not be available to meet all ofthe performance requirements.") As such, most YOM control for flexible packageprinting is achieved through the use ofadd-on control devices. Inthese processes, most ofthe solvent is captured through evaporation in a dryer, along with hoods and other collection devices for solventthat evaporates elsewhere in the printing process. Olderpresses frequently do not allow for the same level ofcapture as newer installations do, butthe CTG notes, "There have been significant improvements in capture efficiency of flexographic presses androtogravurepresses" since the lasttime USEPA reviewed those types ofoperations. It continues, "Since 1990, many vendors have guaranteed capture efficiencyof85 to 90 percent without use ofapermanenttotal enclosure." Control devices, which destroy orrecover the captured solvents, "can achieve at least 95 percent control," according to USEPA,) USEPA's recommended approach to reducing YOM emissions from flexible package printing cleaning materials focuses on workpractices, "such as keeping solvent containers closed except when filling, draining or conducting cleaning operations, keeping used shop towels in closed containers, and conveying cleaning materials from one location to another in closed containers orpipes.") 2.4 Industrial Cleaning Solvents The industrial cleaning solvents category encompasses many products and cleaning styles that are used to clean dirt, soil, oil, and grease as well as remove .adhesives, paints, and inks. Studies done byUSEPA on six focus industries

5(automotive, electrical equipment, magnetic tape, furniture, packaging, and photographic supplies) identified nine main areas where emissions ofVOM occurred during cleaning processes. These nine cleaning categories are spray gun cleaning, spray booth cleaning, large manufactured components cleaning, parts cleaning, equipment cleaning, line cleaning, floor cleaning, tank cleaning, and small manufactured components cleaning. The majority ofVOM emissions were released during the first four types ofoperations, especially the spray gun cleaning, which made up 50 percent ofemissions by itself. However, 

### it should be noted that while the CTG focused on these specific areas, it recommends coverage ofa wide range ofcleaning activities and the proposed industrial cleaning regulation follows that recommendation. YOM emissions occur during the cleaningprocess while wiping, flushing, brushing, and from the storage and disposal ofused solvents and rags. General cleaning ofoffices, bathrooms, and otherjanitorial type services are not covered by this proposed regulation. 2.5 Flat Wood Paneling Coating According to the CTG for FlatWood Paneling Coatings, "Flat wood paneling products are used in construction and can be classified as three main product types: decorative interior panels, exterior siding, and tileboard." 5 Decorative interiorpanels are often embossed and usually grooved, having more decorative coating requirements than many otherproducts. Substrates include hardwood, plywood,. medium density fiberboard, and particle board. Exterior siding may be coated at the production facility or on-site (the latter is not subject to this proposed regulation). Exteriortrim is also generally manufactured at the same production facility and coated with the same coatings. Substrates include solid wood, hardboard, and waferboard. Tileboard is used in high-moisture areas such as kitchens andbathrooms, and is considered a premium interiorwall paneling. Tileboard meets the specifications for Class Ihardboard according to the American National Standards Institute. Flat wood paneling products are coated to provideprotection from the environment, modify the surface, and present a desired appearance. According to the CTG for Flat Wood Paneling Coatings, "A typical flat wood coating facility applies stains and varnishes to natural plywoodpanels used for wall coverings. Otherplants print wood grainpatterns onparticle board panels that were first undercoated with an opaque coating to mask the original surface. Coatings applied to flat wood paneling include fillers, sealers, 'groove' coats, primers, stains, basecoats, inks and topcoats. Most coatings are applied by direct

6roll coating. Filleris usually applied by reverse roll coating. The offset rotogravure process is used where the coating and printing operationrequires precision printing techniques. Other coatingmethods include spray techniques, brush coating and curtain coating. A typical flat wood paneling coating line includes a succession ofcoating operations. Each individual operation consists of the application ofone ormore coatings followed by a heated oven to cure the coatings. A typical production line begins with mechanical alterations ofthe substrate (filling ofholes, cutting ofgrooves, sanding, etc.), followed by the coating operations, and packaging/stacking for shipment.,,5 YOM emissions occurprimarily during the coatingprocess as the coatings dry and cure, but also as coatings are applied, and during mixingbefore application. 

### 3.0 TECHNICAL FEASIBILITY OF CONTROLS CTGs for each ofthese categories were published by the USEPA in September 2006. Each ofthe CTGs contain information about add-on controls, process modifications, workpractices, and material reformulation and substitution that can beused to accomplish thenecessary emission reductions. The Illinois EPA depended on the CTGs, as well as discussions with other states and industry, in developing and implementing thc proposed regulations. 3.1 Lithographic Printing Add-On Controls Add-on control devices are applicable only to heatset web offset lithographic printing, not non-heatset or sheet-fed lithographic printing, and can be grouped into two broad categories: combustion control devices (destructive) and recovery devices (nondestructive). Combustion control devices are designed to destroy VOMs in the vent strcampriorto atmospheric discharge; recovery devices limit YOM emissions byrecovering material forreusc. The heatset web offset lithographicprinting industry employs threebasic add-on control devices: (1) thermal afterburners, (2) catalytic afterburners, and (3) condenserfilter systems. The experience ofthe Illinois EPA indicates that the field is dominatedby thermal and catalytic afterburners, which can often achieve 98 percent or greaterYOM removal. The condenser filter systems currentlyinuse have been designed specifically for the heatset web offsetprinting industry. Condenserfilter systems can achieve as high as 97 percent YOM removal efficiency, with 90 percentbeing easily achievable for older systems.

7Fountain Solution Reformulation andProcessModifications A significantportion ofYOM emissions from lithographic printing can be ascribed to evaporation from fountain solutions. Alcohol substitutes havebeen in use for over 20 years to replace orminimize the amount ofalcohol used in a fountain solution. These substitutes have lower volatilitythan alcohol and thus reduce emissions. Process modifications are changes in operational methods orequipment resulting in improved YOM control. Such modifications mayinvolveretrofitting existing equipment orreplacing older equipment with new technologyto accommodate the process change. However, the Illinois EPA does not expectretrofitting or replacementtobe an issue with this rulemaking. Cooling afountain solution is one process modification thatreduces YOM emissions from the fountain solution by minimizing evaporation. Refrigerated circulators can cool the fountain solutionto a temperature that usually ranges between 55 and 60°F. Refrigeration has been shown to reduce consumption of alcohol in the solution by as much as 44 percent. Material Reformulation orSubstitutionfor CleaningSolutions As with fountain solutions, cleaning solutions can also be a significant source of YOM emissions from the overall lithographicprintingprocess. To reduce these emissions, cleaning solutions maybe reformulated in one oftwo ways. Solutions containing a smaller amount ofYOM maybe used. The currentlllinois rule limits such solutions to no more than 30 percent YOM. While no problems with this limithave been reported to Agencypersonnel in Illinois, there have apparently been complaints on a national level. As such, the CTG now recommends limiting such solutions to 70 percent YOM2 The Illinois EPA's proposed regulation contains this higher limit for sources between 15 and JOO pounds per day (PPD), with the previous limitremaining in effect for larger sources. In addition, an alternative to low-YOM cleaning materials are solutions with a low vaporpressure. The CTGnotes, "Cleaning materials with [YOM] composite vaporpressure less than 10millimeters ofmercury (mm Hg) at20°C havebeen used successfullybymanyprinters forblanketwashing and othercleaning activities.,,2 It was determined byUSEPA priorto Illinois' promulgation ofthe previous lithographicprinting rule that the use ofcleaningmaterials with a YOM composite vaporpressure less than 10mm Hg at 20°C would result in a comparable emission reduction to using cleaning materials that contain less than 30 weightpercent YOM. Once again, the Agencybelieves that currently-subject sources are using materials that meet this limit withoutproblems. As such, this limitis notbeing changed; it willjust apply to smaller sources as well.

83.2 Letterpress Printing Letterpress emission sources are similarto those for lithographic printing, with the exception that letterpress operations do not use a fountain solution. 

### In addition, letterpress printing presses are often operated at the same source as lithographic printing and many ofthe control options for letterpress printing are the same as the control options for lithographic printing as well. This is especially true in tenns ofcleaning solutions, though. Because letterpress operations have never been specifically regulated in Illinois before, the Agency is proposing to use the 70 percent YOM content limit for all subject letterpress units. It is the Agency's belief, supportedby conversations with industryrepresentatives, that I1Iinois does not currently contain anyheatset web letterpress operations in eitherthe Chicago orMetro-East NAA, buttheregulation is necessary and technically feasible should a new such operation locate into one oftheNAAs. 3.3 Flexible Packaging Printing Similarto the types ofprinting discussed above, thetwo main sources ofVOM emissions from flexible package printing are the evaporation ofinks, coatings, and adhesives, as well as the use ofcleaning materials. TheseYOM emissions maybe controlled by material reformulation or, especially in the case ofink emissions, through theuse ofadd-on controls. MaterialReformulation This approach, similarto that described above, focuses on the substitution oflowYOM inks, coatings, and adhesives. According to the eTG, such refonnulation "has been achievedbymany facilities in thepackagingrotogravure and flexographic printing industries.,,3 Whether aparticularfacility is able to use such reformulated materials depends upon their specific activities, including the substrate(s) being used. Add-On Controls Add-on controls, however, may be used by all such printers. The most common control devices used by these sources are thennal oxidizers, catalytic oxidizers, and carbon adsorbers, with adsorbers probablybeing the least-used ofthe three. As the CTG notes, "Today, these control devices can achieve at least 95 percent control device efficiency.,,3 Capture systems have evolved overthe years. These systems collectthe VOMcontaining air so itmaybe destroyed orreclaimed bythe control device described above. While new presses maybe able to obtain as high as 100percentcapture if designed properly, olderpresses were not necessarily constructed with emissions

9capture in mind. As such, the Agency is proposing a tiered approach to capture and control in this rulemaking. WorkPracticesfor CleaningMaterials The CTG recommends workpractice requirements as the bestmeans to control emissions from cleaning operations at flexible package printing sources. In particular, the document says thesepractices should include "keeping solvent containers closed except when filling, draining or conducting cleaning operations, keeping used shop towels in closed containers, and conveying cleaningmaterials from one location to another in closed containers orpipes." 3

3.4 Industrial Cleaning Solvents The industrial cleaning solvents proposed regulation covers a wide range of products thatremove contaminants from parts, products, tools, machinery, and other workproduction areas. The nine main cleaning categories mentioned in Section 2.4, above, use a multitude ofdifferent solvents with different styles of applications. YOM emission reductions can be attained by workpractices, solvent substitution, and controls. The CTG recommends that sources exceeding 15 lbsfday ofVOM emissions from the cleaning category must complywith the following requirements.4 The proposedregulation follows this suggestion. WorkPractices Reductions can be obtained through solventmanagementpractices. General work practices include keeping solvent containers and used applicators covered; properly storing and disposing ofspent solvents and used cleaning rags; minimizing air circulation around all cleaning operations; and implementing equipmentpractices thatreduce emissions, e.g., leak detection and repair practices. VOMContentLimits Solvent substitution to a low-YOM orno-YOM solventcan also reduce emissions. The CTG recommends a contentlimit of50 grams YOM per liter (0.42 lbfgal) ofcleaningmaterial for those industries that are not already covered, orto be covered, by a CTG, as listed in Section 218.187(a)(2)(B).4 However, discussions with industry, other states, and USEPA led to the addition ofa numberofexemptions and higher YOM content limits for certain specific cleaning activities.

10Higher limits have been considered for categories thatmay notbe able to easily meet this limit, based on recommendations from industry as well as from other states. These higher limits are outlined within the rule. Alternate VaporPressure Limit Low vaporpressure solvents are also recommended since the slower evaporation reduces the amount ofVOM released into the atmosphere. The CTG recommends that a limit of8 mm Hg at 20 degrees Celsius be allowed in place ofthe 50 gram YOM perliter ofcleaning material, and the proposed regulation follows this recommendation. Alternate Control Emissions can also be reduced by add-on controls, modifying equipment, or changing the method ofcleaning. The CTG recommends an overall control efficiency of85 percent reduction in emissions ofYOM, which is reflected in the proposed rule. Exclusions As noted above, the CTG suggests excluding certain categories from the cleaning regulations, as these categories alreadyhave or will have their own recommended workpractices and limitations. These categories include coating operations for aerospace, wood furniture, flat wood paneling, large appliance, metal furniture, plastic parts, paper film and foil, miscellaneous metal parts, auto and light-duty truck assembly, and shipbuilding and repair; flexible packagingprinting materials; lithographic printing materials; letterpress printingmaterials; fiberglass boat manufacturing materials; and miscellaneous industrial adhesives. Other categories with specific exemptions have also been suggestedby the CTG as well as by discussions with industry groups. These include electrical and electronic components; precision optics; numismatic dies; stripping ofcured inks, coatings, and adhesives; cleaning ofresin, coating, ink, and adhesive mixing, molding, and application equipment; research and development laboratories; medical device orpharmaceutical manufacturing; andperformance orquality assurance testing ofcoatings, inks, or adhesives. Further exclusion recommendations include cleaning ofpaper-based gaskets and clutch assemblies; cleaning ofadhesive application cquipmentused for thin metal laminating; touch-up cleaning on circuit boards; cleaning ofcoating and adhesive application processes utilized to manufacture transdermal drug deliveryproduct using less than three gallons per day ofethyl acetate; cleaning ofapplication equipmentused to apply coatings on satellites and radiation effect coatings; cleaning ofapplication equipment used to apply solvent-borne fluoropolymer

11coatings; cleaning ofultraviolet or electron beam adhesive application; and cleaning ofelectrical cables. 3.5 Flat Wood Paneling Coatings Flat wood paneling coating, like other forms ofindustrial coating, provides two options for controlling YOM emissions: reformulation or add-on controls. MaterialReformulation Reformulation would entail sources changing from high-YOM coatings to lowYOM materials. According to the CTG, low-YOM, water-based coatings "are generally available" and "can lower [YOM] emissions greatly, and most coatings operations are capable ofconverting to waterborne coatings."s Another option forreformulation is the use ofcoatings that emit almost zero YOM and are cured through the use ofultraviolet light or an electronbeam. The use ofsuch systems are more limited than those for waterbased coatings, but they are available. Add-On Controls Add-on controls for flat wood paneling coating can be used when the source needs, orchooses, to use high-YOM coatings. The CTG notes, "Currently, an overall control and capture efficiency of90 percent is awidely-accepted and readily available technique."s llIinois EPA agrees, based on its experience with a variety ofcoating operations. WorkPractices for Coatings and CleaningMaterials The CTG recommends specific work practice requirements for flat woodpaneling coating operations: "storing all [YOM] coatings, thinners, and cleaning materials in close containers, minimizing spills of[YOM] containing coatings, thinners, cleaning up spills immediately, conveying any coatings, thinners, and cleaning materials in closed containers orpipes, closing mixing vessels whichcontain [YOM] coatings and othermaterials except when specifically in usc, and minimizing emissions of[YOM] during cleaning ofstorage, mixing, and conveying equipment."s Some ofthese requirements are already in place within Illinois regulations for wood furniture coaters. Under the Agency's proposal, these will applyto flat wood paneling coaters as well, and other specific requirements listed above will apply as well. These will minimize unnecessary YOM emissions from such operations.

124.0 ECONOMIC REASONABLENESS 4.1 Lithographic Printing The largest cost factor for lithographic printing

- add-on control devices

- is applicable to heatset web lithographic operations only. Since the Agency's proposal does not increase the number ofsources for which this requirement is applicable, there is no foreseen additional cost due to add-on controls for existing sources. New sources will need to achieve ahigher control efficiency, but since new add-on control devices would alreadybe expected to achieve that efficiency, no additional cost is expected for this reason either. Fountain solution and cleaning solution reformulation costs could occur for newly-regulated sources between 15 and 100 PPD ofemissions under this proposal. USEPA estimated the cost for cleaning material reformulation at $855 perton ofYOM removed (in 2005 dollars)? Forfountain solutions, USEPA actually estimated a cost savings due to a reduction in the use ofalcohol. While they did not provide a specific value for the savings, the TSD for the Illinois lithographic printingrule in 1994 put this savings at $920 perton (while alcohol substitutes are more expensive, the costis reduced because they are used in lower quantities)6 4.2 Letterpress Printing As previouslynoted, letterpress printing shares a great deal in commonwith lithographic printing when it comes to emissions and the applicable controls. As the CTG notes, "Because ofthe similarities between offset lithographic printing and letterpress printing in terms ofthe nature ofthe processes at issue, the sources of[YOM] emissions and available control approaches, itis reasonable to assume that the cost-effectiveness estimates

... for control of[YOM] from hcatset inks and control of[YOM] from cleaning materials apply equally to the letterpress printing industry.,,2 The difference is that there is not currently a regulation for heatset web letterpress printing operations in Illinois. As such, the reasoning behind the zero cost estimate for heatset web lithographic printing cannotbe used for letterpress operations. Thus, referring to the eTG, USEPA's cost estimate is $2,010 per ton ofVOM removed (in 2005 dollars). However, as noted earlier, the Agency believes thatthe Illinois NAAs do not currently contain anyheatsetweb letterpress operations.

134.3 Flexible Packaging Printing According to thc CTG, "Many facilities located in ozone nonattainrnent areas are already meeting the control levels being recommended in this CTG.,,3 Indeed, this proposal does not expand the number ofsources that will be subjectto the ink or control device portions ofthe flexible packaging rotogravure and flexographic printing regulations. Itis expected that those sources currently able to use compliant inks and coatings will similarly be able to make use ofinks and coatings meeting the new compliance limit, while those using add-on control devices will continue to do so as well. As such, the Illinois EPA expects that there will notbe any additional add-on control costs for subject facilities. In the case ofany sources not already meeting the proposed standards and needing to put on an add-on control device, the CTG says, "The costs ... will vary depending on the flow rate, hourly solvent use rate, and operating hours." USEPA made reasonable estimates to determine the cost effectiveness, and determined that "apress exhausting approximately 5,800 cubic feet perminute, operating 2000 hours peryear, and achieving 70 percent capture efficiency" would have a cost ofbetween $1,300 and $2,800 perton ofVOM removed.3A source with a largerpress, 1llgher solvent use rate, more operating hours, orbetter capture efficiency would have an even lower cost per ton ofVOM removed. Costs associated with additional sources becoming subjectto the clcaning provisions ofthis proposedregulation are expected to be minimal. Indeed, some sources may see an overall cost savings as less cleaning solution is necessary. 4.4 Industrial Cleaning Solvents USEPA estimated that there would be 130 sources in Illinois NAAs that would be impacted bythis regulation, with a total of2293 Mglyr (2528 tons/yr) ofbaseline YOM emissions peryearby using the 2002 Nation Emissions Inventory database. USEPA then determined the cost effectiveness ofmeeting the 50 grams ofYOM perliter ofcleaning material limit fon parts cleaner at $1664/ton based on a studyprovided bythe CaliforniaBay Area 

### Air QualityManagementDistrict. Costs associated with switching from 1llgh-YOM content solvents to low-YOM content or aqueous solvents may show an actual cost savings of$ I460IMg ($1325/ton) when taking in consideration the reduction ofdisposal costs, according to the CTG. 4.5 Flat Wood Paneling Coatings USEPA based their cost estimate on information obtained from the South Coast Air Quality Management District in California, arriving at a cost ofbetween $1,900 and $2,600 perton ofVOM reduced (in 2005 dollars). According to the

14CTG, for any sources subject to this rule in Illinois, costs "couldbe incurred to make changes to their coatings in order to meet" the new regulation.5 Thus, the only significant cost is expected to be reformulation ofcoatings. 5.0 EXISTING AND PROPOSED STANDARDS 5.1 Lithographic Printing Currently, Illinois has regulations covering all types oflithographic printing in the NAAs, with an applicability level of100 PPD (calculated monthly). 

### In addition, there is a secondary applicability level of 100 tons per year ofmaximum theoretical emissions for heatset web lithographic printing, which was carried over from the previous rule. The Agency is proposing removing the 1DO-ton limit, as it is no longer necessary and USEPA has agreed that removing itwill not cause a backsliding concern. This new proposal does not reduce the applicability threshold for add-on control devices used byheatsetpresses. Thus, no new lithographic printing units will need to add controls. However, new control devices on heatset web lithographic presses will need to meet a 95 percent control efficiency instead ofthe current 90 percent limit. TheAgencybelieves that control devices in existence today can meet the 95 percent limit, but at the request ofprinting industryrepresentatives, the Agency has agreed to not ask existing sources to meet the higher control efficiency. Theproposal does provide a new applicability threshold of15 PPD for fountain solution and cleaning solution requirements for all lithographicprinting operations. The requirements are the same as are already presentin the lllinois regulations, other than a correction to the fountain solution limits that changes their measurement from "by volume" to "by weight." USEPA has informed Illinois EPA that the limit should be weight-based, and the change will slightly loosen the standard for sources, ifanything. The Illinois EPA has not encountered any sources with problems complying with the fountain solution, cleaning solution, recordkeeping, reporting, or material handling portions ofthe existing rule, and no such issues are expected when lowering the applicability threshold. Sources between 15 and 100 PPD will be able to take advantage ofseveral new exclusions pertaining to fountain and cleaning solutions. Sheet-fed presses that print substrates no largerthan 11 inches by 17 inches and any lithographicpress with a fountain solution reservoirofno larger than one gallon are not required to comply with the fountain solution requirements. As described above, all sources in this group will also need to meet only a 70 percent YOM content limit in cleaning solutions rather than the 30 percent limit that is applicable to sources over 100 PPD. All such sources will also be able to use up to 110 gallons of cleaning solution per year that do not meet eitherthe YOM content or vapor



### ISpressure requirements. These exclusions will ease any potential burden on the smallest sources affected by this rule. Sources which fall below one ofthe applicability limits, and are thus exempt from one ormore control requirements, must certifY this exemption to Dlinois EPA through calculations showing that their emissions will not exceed the applicable YOM threshold. These calculations must include all YOM emissions, including inks, fountain solution, and cleaning solvents, and are determined on amonthly basis. It should be noted that the currentregulation recognizes that the substrate retains some ofthe YOM present in the ink, and thus a retention factor of0.95 is used when calculating emissions from non-heatset inks, and a factor of0.20 is used when calculating emissions from heatset inks. 

### In addition, it contains a factor recognizing that YOM remains on solvent-ladenrags that are stored and disposed ofproperly. These factors continue to be allowed for determination of applicability. 

### In addition, this proposal adds emission adjustment factors to be used in other situations when not determining applicability (such as Annual Emissions Reports and permitlimits). These factors take into account carryover of YOM from automatic blanket wash and fountain solutions into thc dryer and control device. All ofthese factors may be found in the CTG2 Because ofthe new exclusions that apply onlybetween 15 and 100 PPD, even

.subject sources in this group must continue to calculate emissions to ensure they do not exceed the 100PPD threshold and lose the exclusions. Sources may opt out ofthe exclusions ifthey do not wish to make use ofthem, and thus would not need to calculate emissions in this fashion. 5.2 Letterpress Printing There are currently no specific Dlinois regulations covering letterpress printing operations; any such operations would therefore be coveredby Subpart TT, Section 218/219.30I, orpaper coating regulations. The new proposal addresses both heatset and non-heatset letterpress operations. This proposal would require that heatset letterpress printers use an add-on control device ifthey meet the applicabilityrequirement of25 TPY PTE plantwide. However, as noted earlier, the Agency believes there are no such operations in Dlinois NAAs. All letterpress printing operations of 15 PPD ormore will be also required to abide by cleaning material limitations equivalentto those described above for lithographic sources between 15 and 100 PPD. That is, cleaning solutions will be required to contain no more than 70 percent YOM orhave a maximum composite partial vaporpressure ofJess than 10 mm Hg.

165.3 Flexible Packaging Printing Currently, Illinois rules cover all f1exographic, packagingrotogravure, and publicationrotogravureprinting. All ink limits for these different types ofprinting are identical, with the only difference found inthe add-on control requirementsf1exographic printers are required to get 60 percent overall YOM reduction, packaging rotogravure are required to get 65 percent overall reduction, and publication rotogravure must achieve 75 percent overall reduction. The new proposal separates out flexible package printing from the existing f1exographic and rotogravure regulations. Thus, any f1exographic orrotogravure operation that is not printing on flexible packaging will not see achange to the applicable regulations. Sources that print on flexible packaging will need to meet either a tightened ink YOM content or add-on control requirement. The required control efficiencywill depend onboth the date ofconstruction, at the source, ofthepress and the control device. This recognizes that presses and control devices already installed at the source might nothave been designed to obtain capture and control efficiencies as high as are currently obtainable. 5.4 Industrial Cleaning Solvents lllinois has currentregulations for cold cleaning degreasing, open top vapor degreasing, and conveyorized degreasing operations as well as some limitations and workpracticcs on cleaning solventuses in existingrules, e.g., regulations

. regarding autobodyrefinishing, wood furniture coating, and lithographicprinting.

This newrule sets limitations based on an applicability of 15 Ibs/day ofactual YOM emissions from cleaning operations. Once applicable, the source will need to follow the workpractice standards discussed in Section 3.4, above, and either complywith a YOM content limitation ofthe cleaning solutions, use a low vapor pressure cleaning solution, orutilize an emissions control systemthat provides 85 percent overall control ofYOM emissions from cleaning activities. 5.5

. FlatWood Paneling Coatings There are currentlyno specific Illinois regulations covering flat wood paneling coating operations; any such operations would therefore be coveredby Subpart TT, Section 218/219.301, or potentially wood furniture coating, depending on whether the operations fell into the defmition related to thatprocess. The new proposal will add coating YOM requirements and workpractice requirements forboth coatings and associated cleaning operations. As with other coating categories, there is also an option available to use add-on control instead

17ofcompliant coatings; however, the flat wood paneling coating category will require an overall control of90 percent rather than the 81 percent overall control required for existing coating categories. The workpractice requirements include several that are already required for wood furniture coaters, which have been accomplished without anyproblems known to the Agency. In addition, othercommon sense requirements are being added, including minimizing spills ofVOM-containing materials, minimizing YOM emissions during cleaning, and closing mixing vessels except when they are in use. 

### 6.0 AFFECTED SOURCES AND EMISSION REDUCTIONS 6.1 Lithographic Printing The Agency does not expect any additional reductions from increasing the required control efficiency for heatset web lithographic printers from 90 to 95 percent, becausethat change will not affect existingcontrol devices. However, there will be some small YOM reductions related to the addition of fountain and cleaning solutionrequirements for sources with 15 PPD ormore of emissions. Itis difficult to estimate such reductions because the TIlinois source inventory does not trackinformation such as the number ofgallons ofcleaning solution used, the size ofsheet-fedpresses, orthe fountain solution reservoir volume

- as such, sources that maybe excluded from requirements are not identifiable. The Agencyfound a total of98 lithographic printing sources inthe Chicago NAA and three in the Metro-East NAA thathave lithographic printing emissions over 15 PPD, according to the Bureau ofAir's 2005 source inventory (modified for sources that have shut down since that timel. In the Chicago NAA, 66 ofthe sources are below 100PPD, and thus are potentially impacted bythismlemaking (two more are over 99 PPD and are assumed to be alreadycomplying with the existing lithographic printing regulations). In theMetro-EastNAA, all three sources are below 100 PPD. The Agency is conservativelyjudging that all ofthe sources listed may be impacted, but it is likely that some ofthem are already considered subject, as the daily emission rate in the inventory is an average estimate, while sources may have exceeded 100 PPD at someprevious point. The Agencyhas tried to account for sources that are alreadycontrolled, as the 100PPD applicability limit applies to uncontrolled emissions. (See Appendix B forthe list ofthesepotentially affected sources.)

18For the sources that apparently would be affected bythis proposed regulation, the Illinois EPA reviewed its inventory in an attempt to estimatcpotential emission reductions from fountain solution reformulation. The .recent lithographic printing CTG does not contain enough specific information to usefully estimate such reductions, but refers back to the 1993 draft CTG on this source category.' Using the information andmodel plants therein, Illinois EPA determined that fountain solution emission reductions would be estimated at between 25% and 90% for smaller sources. As this draft CTG is 16 years old and the new CTG indicates that steps havebcen taken to reduce YOM content in fountain solutions, the Dlinois EPA nsed the 25% figure in calculating reductions. Cleaning solutions canbe calculated as a straight 30% reduction, since the regulation requires reformulation such that they cannot contain more than 70% YOM. As notcd above, the lllinois EPA inventory does not necessarily specifY, for each source, which emissions result from cleaning and which are from fountain solutions. However, using the model plants from the 1993 draft CTG as a guidc, it appears that cleaning solntion emissions at smallerplants make up a lower percentage ofemissions compared to fountmn solutions, ranging up to approximately 50% at certain facilities. Assuming that almost 50% ofnon-ink emissions come from clcaning solutions, which have 30% reduction, it is safe to use a 25% overall emission reduction to cover all YOM originating from the source. Thetotal YOM emissions from the 66 Chicago NAA sources are 1.455 tons per day. Thus, a 25% overall reduction equates to 0.36 tons per day ofVOM. The total YOM emissions from the thTee Metro-East NAA sources is 0.0295 tons pcr day. A 25% overall reduction would provide 0.007 tons per day. 6.2 Letterpress Printing As noted earlier, the Agency does not believe there are currently any heatsetweb letterpress printing operations in the NAAs. As such, no emissions reductions are expected from add-on controls for this category. According to a search ofthe Bureau ofAir's 2005 source inventory, there are two sources in the Chicago NAA, and none in the Metro-EastNAA, making use of letterpress printing (see Appendix B). Only one ofthese sources appears to emit more than 15 PPD from such operations, with less than 0.02 TPD ofVOM, including emissions from the letterpress as well as other printing operations. Even ifall ofthe emissions originated from letterpress cleaning solutions, which are to be reduced by 30 percent, the resulting reduction would be 0.005 TPD. As such, the Illinois EPA expects negligible emissionreductions overall from the implementation ofthis regulation.

196.3 Flexible Packaging Printing It is difficultto estimate emission reductions for the flexible packagingprinting category, as the Illinois source database does not generally specifythe type of substrate being used by aflexographic or rotogravure printing operation, nor does it specify the date oforiginal installation ofthe printing press orthe associated control device. As such, all existing flexographic and rotogravure printing facilities identified as such in the Illinois inventory and exceeding the proposed applicability threshold are listed in Appendix B as potentially affected sources. However, the lllinois inventoryindicates that all sources but one using flexographic orrotogravure printing ofany type are already achieving greater control efficiencythan required by the proposed regulation. The remaining source (identified with an asteriskin Appendix B) is required byits permitto achieve 60 percent control efficiency, but will now need to achieve 65 percent. This change would equate to a 0.03 TPD reduction according to its permitted emissions, but a 0.01 TPD reduction according to emissions information inthe inventory. While the inventory does notprovide information regarding the use ofcompliant inks, ithas been theAgency's experience that sources printing on flexible packaging have had difficulty withthe use ofcompliant YOM inks on such substrates. Sources eitherrelied on add-on controls or switched to waterbased inks that should meetthenewlyproposed requirements as well as the existing ones. As such, negligible emission reductions are expected from the new inklimits. The cleaning materials workpractice standards being proposed do not lend themselves to a calculation ofemission reductions. The Agencybelieves that the environmentwill see actual YOM emission reductions due to the storing of cleaning materials andused shop towels in closed containers, as well as conveying cleaning materials in closed containers orpipes, but calculation ofsuch emission reductions cannotbe accomplished without detailed information from every affected source - both before and after such changes are made. 6.4 Industrial Cleaning Solvents USEPA estimatedthat there are 130 sources in the impacted areas thathave emissions over 15 PPD in Illinois. These sources are estimatedto havebaseline emissions of2293 Mg/yr (2528 TPY) ofVOM as mentioned previously and

.include degreasing operations that are already impactedby existing state regulations thatwill not gain any further reductions. It is notreasonablypracticable to estimate emissionreductions for the other impacted sources under the industrial clean-up solventrule, as any source in either

20NAAs that uses cleaning solvents is potentially affected, depending upon the source's usage level. Further, many different types ofsources throughout the NAAs may use different types ofcleaning solutions and may already be using compliant solutions. For these reasons, Appendix B docs not list specific sources that are potentially impactedby this rulemaking. As discussed above, the Agencybelieves that the environmentwill see actual YOM emission reductions due to these proposedregulations, but calculation of such emission reductions cannotbe accomplished without detailed information from every affected source. • 6.5 Flat Wood Paneling Coatings A search ofthe Bureau ofAir's 2005 source inventory indicated fOUT sources that will likelybe subjectto the proposed flat wood paneling coating regulation inthe Chicago NAA, and none in the Metro-EastNAA. One ofthese four sources would appear to fall below the proposed applicability threshold. The otherthree total 0.09 TPD ofVOM emissions. According to the CTG, YOM emissions were reduced an average of60 percentfor interiorpaneling and tileboard manufacturing. This description seems to fit the Illinois NAA sources best. As such, Illinois EPA estimates aYOM reduction of0.05 TPD in the Chicago NAA and no reductions 

### in theMetro-EastNAA. 7.0 

### OTHER STATES' STANDARDS 7.1 Lithographic Printing Appendix B ofthe CTG for Lithographic and Letterpress Printing contains a list ofstate standards for lithographic printing across the country. Ratherthan reproduce the entire listhere, the reader is referred to that list.2 A keypoint to note is that all states with ozone NAAs will need to implement the same Group IT CTGs as illinois is implementing with this rulemaking. 7.2 Letterpress Printing Appendix C ofthe CTG for Lithographic and Letterpress Printing contains alist ofstate standards for letterpress printing across the country. Rather than reproduce the entire list here, the reader is referred to that list.2 A keypointto note is that all states with ozone NAAs will need to implement the same Group IT CTGs as Illinois is implementing with this rulemaking. 7.3 Flexible Packaging Printing Section V ofthe CTG for Flexible Package Printing contains a list ofstate standards for flexible package printing across the country. Ratherthan reproduce

21the entire list here, the reader is referred to that list.3 A keypoint to note is that all states with ozone NAAs will need to implement the same Group II CTGs as lllinois is implementing with this rulemaking. 7.4 Industrial Cleaning Solvents The CTG for Industrial Cleaning Solvents contains some information on other state standards throughout the document.4 Besides thoserules, ofparticularnote are regulations in California

- South Coast, Bay Area, and San Joaquin Valleyas well as Wisconsin and a proposed regulation in Ohio, from which TIlinois obtained most ofits proposed limits for activities that have a limit different from the basic one suggested in the CTG.

. Appendix A contains a table (originally provided by Ohio and modified to include proposed Illinois limits) that is a comparison ofIllinois' proposed limits with the above areas' limits. 7.5 Flat Wood Paneling Coatings Section V and Appendix B ofthe CTG for Flat Wood Paneling Coating contains information on state standards for these operations across the country. Rather than reproduce the entire list here, the reader is referred to that list.sA keypoint to note is that all states with ozone NAAs will need to implement the same Group II CTGs as Illinois is implementing with this rulemaking. 8.0 SUMMARY The regulations proposed in this rulemaking, covering the CTGs from Group II of USEPA's Consumer and Commercial Products category, addnew requirements or tighten existing requirements for lithographic printing, letterpress printing, flexible packaging printing, flat woodpaneling coating, and industrial cleaning solvents. The Agencybelieves that all theproposed changes are technically feasible and economically reasonable. Incorporating these additions and modifications to existing Illinois regulations is requiredby the CAA and USEPA; specifically, Section 182(b)(2)(A) ofthe CAA requires that SIPs must berevised to include RACT for VOM emissions sources that are covered by a CTG issued byUSEPA after November 15, 1990, and before the area's date ofattainment. The illinois EPA made mUltiple rounds ofoutreach efforts in relation to this proposed rulemaking. The first was accomplished electronically, with the second involving follow-up calls from the Agencyto sources that had submitted comments as well as detailed discussions between the Agency and industry group representatives. In addition, the Agencyhas had frequent discussions with USEPA personnel in both the regioI!al office and headquarters, and has gathered information from other states. After this extensive effort, the Agency has proposed

22this rulemaking, which incorporates therequirements ofthe CTGs and USEPA plus comments from industry. While the Agency recognizes that it is difficult to quantify specific emission reductions that will be achieved through theserule modifications, the environment will see a real**reductio~** ofVOM emissions. As previously noted, USEPA strengthened the eight-hour ozone standard last year. It is likelythatthe same areas in Illinois that are currentlydesignated as nonattainmentfor the present standards will soon be designated as nonattainmentfor this revised standard. Any reduction in YOM emissions in the NAAs will help Illinois to achieve the newly revised NAAQS as well as satisfy CAA obligations.

23

### Appendix A: Comparison o[ProposedIllinois Industrial Cleaning Solvent Limits to Those in Other States**~,~,** :(a)". ":p;ro"ducf**¢1eanj.ngdui"irig·~**



### . manufa6iUrlngl:proceSs;Qf

"**"siJrf'.l-ccpf~ii~tirin1'or:** :.',"

·coating. adhesive,'.:or,.irik'",· .a'·**]i~ti~n:':..** .'**~":** .

.'(c) 'Cleanirig:ofink'applkation ui "men!:

..' " . '

.. {i)**·G~neral** . (ii) Flexographic and .'Rotogravure,'printing'**.:th~i** does not-ptint; Jlexibie, atka "Ii .

.(iii) Screen**pri~tirig**

._

(iv) Ultraviolet ink and

. electron beam ink application e<iuipment.'· 

### exce tscreen rintin _.:t•. 

## .-to

"..';.

24Appendix B: Potentially Affected Sources Lithographic Printing Sources Chicago NonattainmentArea: BOA ID Number 0310l2AGH 031015AAR 0310l5ACC 03 10I8AAK 031030ACU 031030ACW 031030ADM 031051ABM 03105lADK 031063AHP 031063AHU 031096AAD 031096ANR 031120AAF 031123ABZ 031123ACD 031126AAZ 031186AGD 031201ADU 031201AEG 03120lAEQ 031288AJJ 03 1297ABT 031440AFJ 031440ALJ 031440ALO 03 1440ALR 031440AMW 03 1600AWL ·031600BGU

03l600BKC 031600CAG 031600CHZ 031600FAN 031600FOV 031600GBC 031600GFC 031600GHF 03l600GHI 03l600GJN 03l600GQV 03l82lABB Source Name Nuart SleepeckPrinting Co Douglas Press Inc The Buhl Press Inc Kelvyn Press Inc H&W Graphics Inc Rapid Impressions Inc Unique Printers & Lithographers Royal Continental Box Co ChromatechPrinting Inc Des Plaines Printing LLC TIN Inc DBA Temple-Inland TukaizLLC Cadore-MillerPrinting Inc Darwill Creative Automation Liberty Suburban Chicago Newspaper MeadWestvaco ConsumerPackaging Group LLC Iohnson & QUlllInC Ed Garvey & Co SKi\![ Ventures LLC Great Lakes Graphics Calumet Carton Co Bruce Offset Co I PearsonI Inc Elk Grove Graphics Quality Color Graphics Inc Premier Card Solutions LLC Impact Printers & Lithographers Lakeside Lithography LLC Color Communications Inc Goes Lithographing Co Inc Chicago Press Corp Cardinal ColorprintPrinting Chicago Tribune Co Seven Worldwide Inc Newsweb Corp Melar Litho Inc American Thiessen LLC Palmer Printing Inc Enteron Group LLC Diemand Printing Co Ideal Box Co

25BOA JD Number 043005ALJ 043005AMK 043005AMS 043020ABI 043020ACM 043030ADL 043030AEG 043030AEL 043065ACG 043120AAR 043452AAW 089010ACG 089020ABH 089407AAO 089438AFT 089483ACC 089483ACM 089800ABV 097l90ACR 097I90AFK 1110l5ACP 197025AAM 197080AAN 19749IAAD Source Name Advantage Printing Inc Lakewood Printing Inc ABS Graphics Inc Tempo Graphics Inc Flint lnkNorthAmerica Corp Johnson Printers Diamond Web Printing Inc Jet LithocolorInc Dow Jones & Co Inc Madden Communication Vis-a-Graphics Tegrant Alloyd Brands Inc Carlith Printing Co Voris Communications Co Inc d/b/a KclmscottPress Hagg Press Inc InterCo Print LLC Perfect Plastic Printing Corp Freedom Imaging Systems Ine Nosca Inc Lake County Press Inc Corporate Express JolietPattern Works Inc Fox ValleyPublications Vision Integrated Graphics LLC Metro-East Nonattainment Area: BOA JD Number ll9055AAZ 119819AAA 133025AAK Source Name Dow Jones and Co Inc Highland SupplyCorp Mar Graphics Letterpress Printing Sources Chicago Nonattainment Area: BOA ID Number 03l288ABA lllOl5ADP Source Name Federal-Mogul Corp Stephen Fossler Company

26Flexible Packaging Printing Sources Chicago Nonattainment Area: BOA ID Numbcr 031003ACU 031009AAS 031012ACA 031012AFM 031012AGJ 031015AAM 031027AAS 031045AGl 031063ADM 031063AFT 031063AHT 031096AMM 031096AOB 031 186AFK 031440AHX 031489AAU 031497AAM 031600ACL 031600AIL 031600BGU 031600BTT 031600CKM 031600DNZ' 031600GEl 031600GFH 031600GlB 031600GLJ 031820AAl 043005AJS 043005ALB 043020AAC 043020ACH 043020ACJ 043035ACX 043462AAA 043806AAN 089010ACC 089055AAK 089407AAZ 089438ADW 089438AFL 089438AGQ 089483ABV 089483ACY Source Name Duro Bag Mfg Co Webcr Marking Systems Inc Packaging Corp ofiL d/b/a Acorn Corrugated Box Co International Paper Co International Paper Co Alcan Packaging Food & Tobacco Inc Smurfit-Stone Container Corp CFC Intemational Inc International Paper Co Deluxe Manufacturing Operations Inc Pamco Printed Tape & Label Co Formel Industries Inc Prairie State Group Wagner Zip Change Clear-Lam Packaging Inc Paddock Printing Center Bio-Industries BagcraftPackaging LLC Solo Cup Operating Corporation Color Communications Inc GeneralPackaging Products MeadWestvaco Packaging Systems LLC Bio StarFilms LLC Cenveo TIN Inc d/b/a Temple

- Inland American Labelmark Co General Packaging Products Inc Bluegrass Flexihle Packaging Co LLC RoUprint Packaging Produc1s Inc QualityBags Inc Graphic Packaging International Inc Meyercord Revenue Co Packaging Personified Inc Bema Poly Tech d/b/a BemaFilm Sys Inc Genesis Packaging & Design Pro-pak Industries Inc Pechiney Plastic Packaging Inc International Paper Covalence SpecialtyMaterials Corp Printpack Inc Multifilm Packaging Corp.' TIN Inc DBA Elgin Corrugated Box Dopaco Inc Moore Wallace North America Inc

27BOA ill Number 097035ABE 097080AAY 097084AAI 097115ABC 097Il5ACJ 0971 25AAY 097190ACR 097418AAL 097803AAB 097809ABG lllOlOAAT 111035AAP 111065AAR 1 11803AAF Source Name

NOSCD Inc

. Colbert Packaging Corp VoneD Products Inc ArncorFlexibles Healthcare Inc Parade Packaging Stone Container Corp NoscD Inc Fisher Container Corp 

### cn Industries Corp Kraftseal Corp AMPAC Flexicon LLC HS Crocker Co Inc Divers.packLLC Catty Corp Metro-East Nonattainment Area:

BOA ill Number 119040ATD 119055AAL 11 98 19AAA Source Name GatewayPackaging Inc Highland SupplyCorp HigWand SupplyCorp

Flat Wood Paneling Coating Sources Chicago NonattainmentArea: BOA ill Number 031600AFA 03 I600FZW 031600GGJ 197815AAH Source Name WilliamYuenger Manufacturing Co Interior Crafts Inc FCI Inc Illinois FlushDoor Ine

28REFERENCES 

### 1. The Clean Air Act as amended in 1990 (42 U.S.C. Section 7401 et seq.). 2. Control Techniques Guidelines for OffsetLithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September2006. 3. Control Techniques Guidelines for Flexible Package Printing. United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2006. 4. Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September2006. 5. Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 2006. 6. Technical SupportDocument for Controlling YOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency; AirQualityPlanning Section, Springfield, IL, October 1994. 7. Control Techniques Guideline Series: Control ofVolatile Organic Compound Emissions from Offset Lithographic Printing (DRAFT), United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, Research Triangle Park, NC, September 1993.

29

# A 2. /.**fl"irc:CICOVE~** CLERK'S OFFICE



## AUG 062009 STATE OF ILLINOIS Pollution Control 

### Board August 6, 2009 Warren Ribley, Director

.. Department ofCommerce and Economic Opportunity

620 East Adams Street, S-6 Springfield, Illinois 62704 Cr.:-"'.'EFG,()!(**~,'.~')d** K**g1ag':)j(~"iC:;-1**

Re: Request for Economic Impact Study for: Reasonably Available Control Technology IRACT) for Volatilc Organic Material Emissions from Group 

## n Consumer & Commercial Products: Proposed Amendments to 35 Ill. Adm. Code 211, 218, and 219, (RI0-08) DearDirectorRibley:

Since 1998, Section 27(b) ofthe Enviromnental Protection Acthas required

· theBoardto: 1) request that the Department ofCormnerce and Economic Opportunity (formerlythe Department ofCormnerce and Community Affairs) conduct a study ofthe economic impact ofthe proposedrules. The Departmentmay within 30 to 45 days ofsuch requestproduce a study ofthe economic impact oftheproposedrules. At aminimum, the economic impact study shall address a) economic, environmental, and public health benefits that maybe achieved through compliance with the proposed rules, b) the effects ofthe proposedrules on employment levels, commercial productivity, the economic growth ofsmall businesses with 100 or less employees, and the State's overall economy, and c) the cost perunit ofpollution reduced and the variability ofcompanyrevenues expected to be used to implementthe proposed rules; and

On August 6, 2009, the Board accepted forhearing aproposal in Reasonably

· Available Control Technology IRACT) for Volatile Organic Material Emissions

· from Group II Consumer & Commercial Products: Proposed Amendments to 35 Ill. ; Adm. Code 211, 218, and 219, (R09-2l). This rulemaking was filed with the Board

, on July 9, 2009, bythe Illinois Enviromnental Protection Agency. Generally, the Wfn!'TGHELlJ OFFiCE' Agency proposes to adopt airpollutionregulations to control emissions ofvolatile 02 j

## x,;n;,**(;r~;,,;** P.v". c'" : organic material for Group II Consumer & Commercial Products in ozone : FO. Bo;; 1'12;·'1· : nonattaimnent areas classified as moderate and above. Group II products include

### Si~;;;'~1~~:iiiL 

# .industrial cleaning solvents, flat wood paneling coatings, flexible packagingprinting 2i7·524:xifYJ : materials, lithographic printing materials, and letterpress printing materials. Iwrite FAX 217·52"·.ii5(" : to request that your Department conduct an economic impact study concerning this

, proposal.

## 1,,~~ri[~AS9:?~FrC£ 

# .**~aIP~'tI<.· Tho·~1j;·~on** **Ccm~r** 

### I·

.. '. Wil We,LRiildclph·

.

## > I'

.**·Sl.lit~i,l~:;oo** .. ·· . 1**Chica~'Q!)i** '60f,o'J";' ,:,'1

. ;"'j'2"Xg:j'**i.36~}() ':-~:,,;',<:,~,,:**  "', .A::...·;'f· ,-**.~",** . ,',',- : ; FAX J1R,814'3669

# 1\~~~i;;'~j'M t**")"~'** 01

- ..**~_ ',':~** (2) conduct at least one public hearing onthe economic impact ofthose rules. At least 20 days before the hearing, the Board shall notifYthe public of the hearing andmake the economic impact study, orthe Dej:Jlutment of Commerce and Economic Opportunity's explanation for not producing an economic impact study, available to the public. Such public hearing maybe held simultaneously or as apart ofanyBoardhearing considering such new rules. 415 ILCS 5/27(b) (2008). The Board is in theprocess ofscheduling ahearing in this rulemaking. Although there is no decision deadline in this rulemaking, the Board intends to proceed promptlywith this rulemaking, and asks that you respond to this request as soon as you conveniently can. IfI, ormy staff, can provide you with any additional information, please let me know. Thankyou in advance for yourpromptresponse. Sincerely,

G. TannerGirard Acting Chairman Pollution Control Board

ee: John T. Therriault, Assistant Clerk ofthe Board

# A 3ILLINOIS POLLUTION CONTROL BOARD August 6, 2009 IN THE MATTER OF: ) ) REASONABLY AVAlLABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATLE ) ORGANIC MATERIAL EMISSIONS FROM) GROUP II CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE 21 I, 218, and 219 ) ORDER OF THE BOARD (by A.S. Moore): RIO-08 (Rulemaking

- Air)

On July 9,2009, the Illinois Environmental Protection Agency (Agency or Illinois EPA) filed aproposal under the general rulemaking provisions ofSections 27, 28, and 28.2 ofthe Environmental Protection Act (Act). See415 ILCS 5/27, 28, 28.2 (2008). Generally, the Agencyproposes to adopt airpollution regulations to control emissions ofvolatile organic material (VOM) I for Group II Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above. Group II products include industrial cleaning solvents, flat wood paneling coatings, flexible packaging printing materials, lithographic printing materials, and letterpress printing materials. Accompanying the Agency's proposal were a motion for waiver ofcopy requirements (Mot. Waive) and a motion for expedited review (Mot. Expedite). The Board today accepts the Agency's proposal for hearing and grants the Agency's request for waiver ofcopy requirements but denies the Agency's motion for expedited review. The Board also directs the hearing officerto expeditiously schedule and proceed to hearing in this matter. SUMMARY OF PROPOSAL The Agency characterizes YOM as "a primary precursor to the formation ofground-level ozone." Statement at 2-3. In 1997, USEPA revised the National Ambient Air Quality Standard (NAAQS) for ozone by instituting an 8-hour standard. ld. at 3, citing 62 Fed. Reg. 38856 (July 18, 1997). Two Illinois areas, Chicago and St. LouislMetro East, have been designated as moderate nonattaimnent areas for the 8-hour ozone standard. 2 Statement at 3.

l The Agency states that YOM and volatile organic compounds (VOC) are "effectively the same" as one another. Statement at I. 2 The Chicago nonat1ainment area includes the followingjurisdictions: Cook, DuPage, Kane, Lake, McHenry, and Will Counties, Goose Lake and Aux Sable Townships in Grundy County, and Oswego Township in Kendall County. Statement at 3, citing 40 C.F.R. 81.314. The St. LouislMctro East nonattaimnent includes the following llIinois counties: Jersey, Madison, Monroe, and St. Clair. Statement at 3, citing 40 C.F.R. 81.314.2

The Agency states that its proposal intends to satisfy Il1inois' obligation under the Clean Air Act (CAA) to submit a State Implementation Plan addressing YOM emissions in areas designated as nonattainment for the NAAQS for ozone. Statement at I, 6, citing 42 U.S.c. §§ 7502, 7511a. Specifically, the Agency states that Illinois must revise its SIP to include reasonably available control tcchnology (RACT) for sources ofYOM emissions covered by a USEPA control technology guideline (CTG). Statement at 2, citing 42 U.S.c. § 751Ia(b)(2). The Agency reports that, on October 5, 2006, USEPA issued final CTGs for Group II Consumer and Commercial Products. Statement at 4. USEPA required submission ofSIP revisions responding to the CTGs within one year. !d. at 4, 5, citing 71 Fed. Reg. 58745-53. In addition, the Agency states that "Il1inois is required to submit these SIP revisions before the USEPA can redesignate the Chicago and Metro East nonattainment area as attaining the 1997 ozone NAAQS, regardless ofwhether the VOC reductions obtained by the SIP revisions are actually necessary to achieve attainment ofthe NAAQS." Statement at 6. 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." ld. at 7. The Agency further notes that, on March 19, 2009, it submitted an attainment demonstration for the Chicago nonattainment area. ld. The Agency argues that "[t]hese areas cannot be redesignated to attainment ofthe ozone NAAQS, however, unless and until the Il1inois EPA submits SIP revisions in response to the Group II CTGs and the USEPA approves such revisions." !d. The Agency claims that its proposal seeks "to implementthe recommendations contained in the CTGs to the extent that such recommendations are consistent with, and impose stricter requirements than, existing regulations." ld. TheAgency also notes that USEPA recently strengthened the ozone standard. Statement at 7, citing 73 Fed. Reg. 16436 (Mar. 27,2008). The Agency considers it "likely" that areas designated as nonattainment for the current standards will be designated nonattainment for the revised standards as well, with the exception ofJersey County. Statement at 7; Mot. Expedite at 3. The Agency argues that "[w]hile attainment ofthe revised standard is not the purpose ofthis rulemaking, it should be noted that any reduction in YOM emissions in the nonattainment areas resulting from theseproposed amendments wil1likely help Il1inois achieve the revised NAAQS." ld. MOTION FOR WAIVER OF REOUIREMENTS The Agency notes that the Board's procedural rules require filing the original and nine copies ofits regulatory proposal with the Board's Clerk. Mot. Waive at I, citing 35 Ill. Adm. Code 102.200. The Agency further notes that that Act requires it also to file information supporting its proposal. Mot. Waive at I, citing 415 ILCS 5/27(a) (2008). The Agency states that it has supplied with Board with seven documents on which it directly relied in drafting the proposed regulations. Mot. Waive at 1-2. Because its entire proposal consists ofmore than 700 pages, the Agency "requests that the Board waive the normal copy requirements and allow Il1inois EPA to file the original and four copies" ofits proposal and the documents relied upon in the development ofthe proposal. !d. at 2. MOTION FOR EXPEDITED REVIEW3

The Agency states that ithas submitted demonstrations that the Chicago and St. Louis/Metro East nonattainment areas now attain the 1997 8-hour ozone standard. Mot. Expedite at 2. The Agency argues that USEPA cannot redesignate those areas as attaining that standard "unless and until the Illinois EPA submits SIP revisions in response to Group II CTGs and the USEPA approves such revisions." !d. Also as noted above, USEPA has strengthened the 8-hour ozone NAAQS. Mot. Expedite at 3, citing 73 Fed. Reg. 16436 (Mar. 27, 2008). The Agency states that, in March of2009, it "recommended to the USEPA that the same areas in Illinois that are currently designated as nonattainment for the 1997 standard be designated as nonattainment for the revised standards as well, with the exception ofJersey County." Mot. Expedite at 3. The Agency further states that USEPA is expected make nonattainment designations by March of201O, at which time "USEPA will issue guidance for states transitioning fTOm the 1997 standard to the revised standard." !d. The Agency argues that, ifeither ofthe two ofthe two nonattainment areas violate the 1997 ozone standard before it is fo'rmally redesignated as attaining that standard, then "it is possible that such area would be 'bumped up' from its current 'moderate' nonattainment classification to a 'serious' orhigher classification." Mot. Expedite at 3, citing 42 U.S.C. § 751Ia(c). The Agency states that "[a]reas designated as 'serious' are subject to more stringent requirements, including a lower major source threshold, enhanced monitoring requirements, and a stricteremission offsetratio." Mot. Expedite at 3, citing 42 U.S.c. 

### § 7511a. The Agency further states that a violation ofthe 1997 standard occurring afterredesignation would notresult in reclassification. Mot. Expedite at 3. Instead, "[t]he area in which the violation occurred would merely be required to implement targeted control measures pursuantto contingency provisions contained in the area's maintenance plan." 

### lei., citing 42 U.S.c. 

### § 7505a. The Agency claims that "[r]edesignation is therefore necessary to foreclose the risk that a future violation ofthe 1997 standard will implicate reclassification and, in turn, heightened control measures." Mot. Expedite at 4. The Agency further argues that transition from the 1997 ozone standard to the revised standard "will most likely impose additional obligations upon areas that are still designated as nonattainment for the 1997 standard at the time final designations for the revised standard are made." Mot. Expedite at 4, citing 40 C.F.R. 51.905(a)(I). The Agency claims that, although the USEPA's transition policy and the risk ofcomplications such as legal challenges resulting from that policy are uncertain, an expeditious redesignation would relieve Illinois ofhaving to comply with such a policy and contend with its consequences. 

### See Mot. Expedite at 4-5. Consequently, the Agency requests that the Board grant its motion for expedited review. !d. at 5. DISCUSSION AND CONCLUSIONS First, the Board finds that the rulemaking proposal meets the contentrequirements of35 Ill. Adm. Code 102. The Board accepts this proposal for hearing and directs the assigned hearing officerto proceed to hearing under the rulemaking provisions ofthe Act and the Board's procedural rules. 415 ILCS 5/27, 28, 28.2 (2008); 35 

### Ill. Adm. Code 102.4 Next, the Board grants the Agency's motion for waiver ofrequirements and allows the Agency to file an original and four complete copies ofits proposal and the documents upon which it directly relied in drafting the proposal. Finally, turning to the Agency's motion for expedited review, the Board notes that Section 101.512 ofits procedural rules addresses requests ofthis nature See 35 Ill. Adm. Code 101.512. Such requests must include, among other elements, "a complete statement ofthe facts and reasons for the request." 35 Ill. Adm. Code 10 1.512(a). In acting on a motion for expedited review, the Board considers, at a minimum, "all statutory requirements and whether or not material prejudice will result from the motion being granted or denied." 35111. Adm. Code I01.512(b). In addition, the Board will only grant a motion for expedited review consistent with available resources. See 35 Ill. Adm. Code 101.512(e). As a matter ofits various resources and decision deadlines, the Board cannot expedite consideration ofevery case orrulemaking proposal. In denying a recent motion for expedited review filed by the City ofGalva, the Board stated that its "limited resources in light ofits current and future decision deadlines render the granting ofa motion for expedited review unlikely in all but the most dire circumstances." In the Matter of: City ofGalva Site-Specific Water Ouality Standard for Boron Discharges to Edwards River and Mud Creek: 35 Ill. Adm. Code 303.447 and 303.448, R9-ll, slip op. at 3 (Feb. 5,2009) (denying motion for expedited review); see also In the Matter of: Ameren Ash Pond Closure Rules (Hutsonville Power Station): Proposed 35 Ill. Adm. Code Part 840.101 through 840.144, R09-21, slip op. at 9-10 (June 18,2009) (same); In the Matter of: Petition ofWestwood Lands, Inc. for an Adjusted Standard from Portion 005 Ill. Adm. Code 807.104 and 810.103 or, in the Alternative, a Finding ofInapplicability, AS 09-3, slip op. at 10 (May 21,2009) (same). As noted above, expedited review is granted consistent with the Board's decision deadlines and available resources. See 35 Ill. Adm. Code 101.512(c). The Board currently has a number rulemaking dockets requiring immediate attention, as well as pressing cases ofother types. As aresult ofattrition, the Board has fewer staffthan it has had in many years. These circumstances have not meaningfully changed since the Board denied the City ofGalva's motion for expedited review. These limited resources, particularly in light ofcurrent and future decision deadlines, continue to make it unlikely that the Board will grant a motion for expedited review in all but the most dire circumstances. The Board did recently grant two Agency motions to expedite consideration ofproposed rules in which the Agency described the risk ofUSEPA sanctions in the event that the State failed to remedy deficiencies in the SIP for ozone attainment. In each ofthese two rulemaking proceedings, the Board found that the USEPA implementation deadline ofSeptember 24, 2009, and the risk offederal sanctions, including those related to new source offsets and highway funding, constituted "dire circumstances." Section 27 Proposed Rules for Nitrogen Oxide (NO,) Emissions From Stationary Reciprocating Internal Combustion Engines and Turbines: Amendments to 35 Ill. Adm. Code Parts 211 and 217, R07-19, slip op. at 4 (Apr. 2, 2009); In the Matter of: Nitrogen Oxides Emissions from Various Source Categories, Amendments to 35 III. Adm. Code Parts 211 and 217, R08-19, slip op. at 4 (Apr. 2, 2009).5 The Board does not discount the Agency's arguments regarding rcdesignation ofthe nonattainment areas. However, these arguments do not necessarily constitute "material prejudice" sufficientto allow the Board to grant the Agency's motion. Accordingly, the motion to expedite is denied. However, the Board commits to reaching a prompt decision in this matter as soon as the record is complete and directs its hearing officerto take any necessary steps to avoid delay 

### in scheduling the required hearings and completing the record. IT IS SO ORDERED

.

. I, John 1'. Therriault, Assistant Clerk ofthe Illinois Pollution Control Board, certify that the Board adopted the above opinion and order on August 6,2009, by a vote of5-0.

John T. Therriault, Assistant Clerk Illinois Pollution Control Board

# A 4ILLINOIS POLLUTION CONTROL BOARD August 12, 2009 INTHEMAITEROF: ) ) REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATLE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP II CONSUMER 

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

### RIO-8 (Rulemaking

- Air) 

## REceiVED CLERK'S OFFICE



## AUG 122009 STATE OFfWNOIS 

### Pollution Control 

## Board

NOTICE OF HEARINGS DATES, TIMES, AND LOCATIONS: FIRST HEARING: TUESDAY, OCTOBER 27, 2009 9:00AM Madison County Administration Building CountyBoardRoom #203 157 N. Main St. Edwardsville, illinois AND, IF BUSINESS REMAINS AT THE END OF THE HEARING ON THAT DAY, CONTINUING ON WEDNESDAY, OCTOBER 28, 2009, BEGINNINGAT 9:00 AM ATTHE SAME LOCATION. SECOND HEARING: TUESDAY, DECEMBER 8, 2009 9:00AM James R. Thompson Center Room 9-039 100 W. Randolph St. Chicago, illinois AND, IF BUSINESS REMAINS AT THE END OF THE HEARING ON THAT DAY, CONTINUING ONWEDNESDAY, DECEMBER 9, 2009, BEGINNING AT 9:00 AM AT THE SAME LOCATION. PURPOSE OF HEARINGS: AITENDINGBOARD MEMBER: HEARING OFFICER: Merit and Economic Andrea S. Moore Timothy 

### J. Fox

In eompliam:e with tilt: AIn::ricum widl DisubiJilie-s Acl and nU,cr applic::lolc- f;;:drml and State laws, tllt: hC<lnng**\\~lJ** be acct'Ssiblt' to**ilHJi\"k"hrJl~ ,~ilh**  dis,,'binl-i['S. PCI'S(1I1S requiring auxiliary :lids 311d services should ,;'u1H:I" John Thttriall!l, A:>siz:t:lntCk-rk ()t'the Board. at 100 West R"nd",!ph Sf., Suite 11-:.'01), Chicago. Illinois 60601. attclqlhonc lIumber 312!81-t..:()931. fa.

... nUlllb?r 312i814<H169. orTOD number 312·'814

...60.\2,**ri~'('** days prior to**th~** hC3ring.,2



### HEARING OFFICER ORDER 

### On July 9, 2009, the Board received a rulemaking proposal from the Illinois Environmental Protection Agency (Agency). Generally, the Agencyproposes to adopt air pollutionregulations to control emissions ofvolatile organic material (VOM)l for Group II Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above. Group IIproducts include industiial cleaning solvents, flat woodpaneling coatings, flexible packagingprintingmaterials, lithographic printing materials, and letterpress printing materials. 

### In an orderdated August 6, 2009, the Board accepted theproposal for hearing and directed the hearing officerto take anynecessary steps to avoid delay in scheduling the required hearings and completing the record. The Board will conducttwo hearings in order to allow the proponent and any other interested participants the opportunity to present testimony on the merits and economic impact of therulemaking proposal. At hearing, all persons who testify will be sWorn in and subjectto questioning. The Board will also receive any testimony on any economic impact study (EclS) conducted by the Department ofCommerce and Economic Opportunity (DCEO) on theproposed rules or on DCEO's decisionnot to perform an EelS. 

### In setting hearing dates, the Board has considered and accommodated its general workload andhearings now scheduled. 

### As indicatedabove in the notice ofhearings, the first hearing will begin on Tuesday, October 27, 2009, and, ifbusiness remains at the end ofthe hearing on that day, will continue on Wednesday, October 28, 2009. The second hearing will begin Tuesday, December 8, 

### 2009, and, ifbusiness remains at the end ofthehearing on that day, will continue on Wednesday, December 9, 2009. 

### Pre-Filing Deadlines Participants who intend to testify athearing are urged to pre-file theirtestimony and directed to servepre-filed testimony on the hearing officer and all persons on the Service List. Before filing pre-filed testimony or any other document with the Clerk, please check withthe hearing officer orthe Board's Clerkto obtain the most recentversion ofthe Service List. Participants who wish to testify at the first hearing are directed to pre-file all oftheir testimony and anyrelated exhibits no later than Tuesday, September 15,2009. To expedite the first hearing, participants are directed to pre-file questions based upon pre-filed testimony no laterthan Tuesday, September29,2009. Participants whosepre-filed testimony elicits pre-filed questions are directed to pre-file written answers to those questions no laterthanTuesday, October 13, 

### 2009. Although Section 27 ofthe Environmental Protection Act (415 ILCS 5/27 (2008» does not limit the first hearing to the testimony oftheproponent, thehearing officerpresentlyintends

J The Agency states that YOM and volatile organic compounds (VOe) are "effectivelythe same" as one another. Statement at I.

### 3

to allow the Agency as proponent to presentthe testimony ofall ofits witnesses before hearing the testimony ofotherparticipants who have pre-filed testimony. Nonetheless, anyperson wishing to testifY at the first hearing shouldpre-file testimonyby Tuesday, September 15,2008. Pre-filing deadlines for the secondhearing will be determined at a later date. The "mailbox rule" at 35 Ill. Adm. Code 101.300(b)(2) does not apply to the filing ofany ofthis pre-filedtestimony, pre-filed questions, orpre-filed answers, and the Board's Clerkmust rec.eive these documents before the close ofbusiness on the specified dates. Although pre-filed testimony, pre-filed questions, and pre-filed answers maybe filed electronicallythrough the Clerk's Office On-Line (COOL) from the Board's Web site at www.ipcb.state.il.us. all electronic or approved fax filings mustbe received bythe Clerk's Office no laterthan 4:30 PM on the day ofthe applicable deadline. Anyquestions about electronic filing through COOL should be directed to the Clerk's Office at (312) 814-3629. OrderofHearings As indicated above, the hearing scheduled to begin on October27,2009, will beginwith the Agency's presentation ofits case as the proponent. All pre-filed testimony will be entered into the record as ifread. 

### See 35 Ill. Adm. Code 102.424(f). Forthe first hearing, abrief summary oftestimony will be allowed ifa witness wishes to provide onebefore responding to questions. Witnesses will then address pre-filed questions. The hearing officerintends to allow anyparticipant to askfollow-up questions and, after addressingpre-filed questions, to allow participants who have notpre-filed questions to askthem. Afterthe Agencyhas addressed all questions from otherparticipants, and iftime permits beforethe conclusion ofthe first hearing, otherparticipants who have pre-filed testimonymay testifY and address pre-filed questions. Participants who do notpre-filetestimony will be allowed to testifY as timepermits afterthe conclusion ofpre-filed testimony and questionsbased upon it. Consequently, anyperson wishing to testifY at either ofthe two hearings is urged to prefile testimonyin orderto ensure thattheyhave an opportunity to testifY. The hearing scheduled to begin December 8, 2009, will begin withparticipants who prefiled testimony for the first hearing andwere not able to testifY at that time. Participants who pre-filed testimony for the secondhearing will then presentthat testimony. Anyparticipant who wishes to offer apublic coIilment at eitherhearing willbe allowed to do so iftime permits atthe close ofpre-filedtestimony and questions based upon it. The Board's procedural rules also include an opportunityto file post-hearing comments. 

### See 35 ill. Adm. Code 102.108(b). The rules also provide that "[t]he Board will acceptwritten comments from anyperson concerningthe proposedregulations during the first notice period." 35 Ill. Adm. Code 102.604. Service and Notice Lists4 The Service List for this rulemaking is the list ofpersons who wish to participate actively in this proceeding and receive not only the Board's opinions and orders but also other filings such as pre-filed testimony. The Notice List includes participants who wish to receive only the Board's opinions and orders and hearing officer orders. The Boardbegins this rulemaking proceeding by including in the Notice List each ofthe 136potentially affected manufacturers listed in Appendix B to the Agency's Technical SupportDocument. While the Boardwill mail a copy ofthe Board's August 6, 2009, order and this hearing officer order to each ofthose entities, the Board will mail copies ofany subsequent opinions and orders only to those who specifically indicate that they wish to remain on the Notice List for this proceeding. Any entity wishing to remain on the Notice List mustprovide the information requested in the form attached to this order as Attachment A to the BoardbyFriday, September 4, 2009. 

### In order to clarifYthe record in this proceeding, Attachment B to this order contains the names and addresses ofall ofthe entities listedbythe Agencyin its Appendix B and to which the Board has mailed this first hearing officer order. Note that interestedpersons may now request electronic notice offilings byproviding an e-mail address through COOL under this docket number RI0-8. This electronic notice generates an electronic mail notificationthat a document has been filed with the Board in this docket, including document that are nottypicallyprovided to persons ontheNotice List. In addition, COOLprovides links to documents filed with the Board. Those documents can be viewed, downloaded, and printed free ofcharge as soon as they areposted to the Board's Web site. For more information about the option ofelectronic notice or COOL, please consult eitherthe Board's Web site at www.ipcb.state.il.usorJohnTherriault.theBoard·sAssistantClerk.at (312) 814-3629. 

### IT IS SO ORDERED.

TimothyJ. Fox Hearing Officer Illinois Pollution Control Board 100W. Randolph St., Suite 11-500 Chicago, Illinois 60601 312-814-6085 foxt@ipcb.state.il.us5

ATTACHMENT A To Hearing Officer Order ofAugust 

### 12,2009 Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions from Group 

### II Consumer & Commercial Products: Proposed Amendments to 

### 35 TIl. Adm. Code 

### 211, 218, and 

### 219: (RI0-8) I wish to remain on the Notice List in the Pollution Control Boardrulemaking proceeding listed above:

Name

Organization or Company

Address

City, State, Zip PLEASE SUPPLY THIS INFORMATION BY FRIDAY, SEPTEMBER

### 4,2009 TO: LynnPatras E-mail: patrasl@ipcb.state.il.us 

### Fax: 

### 312-814-3669 Mail: 

### 100 W. Randolph St., Suite 

### 11-500 James R. Thompson Center Chicago, illinois 

### 60601

### 6 ATTACHMENTB To Hearing Officer Order ofAugust 12, 2009 Reasonably Available Control Technology fRACT) for Volatile Organic Material Emissions from Group II Consumer 

### & Commercial Products: Proposed Amendments to 35 TIl. Adm. Code 211, 218, and 219: (RIO-8) Nuart SleepeckPrinting Co Douglas Press Inc The Buh! Press Inc Kelvyn Press Inc H&W Graphics Inc Rapid Impressions Inc Unique Printers & Lithographers Royal ContinentalBox Co Cbromatech Printing Inc Des Plaines Printing LLC TIN Inc DBA Temple-Inland Tukaiz LLC Cadore-Miller Printing Inc Darwill CreativeAutomation Liberty Suburban Chicago Newspaper MeadWestvaco ConsumerPackaging Group LLC Johnson & QuinInc Ed Garvey & Co SKM Ventures LLC Great Lakes Graphics Calumet Carton Co Bruce Offset Co IPearson I Inc Elk Grove Graphics Quality ColorGraphics Inc Premier Card Solutions LLC ImpactPrinters & Lithographers Lakeside Lithography LLC ColorCommunications Inc Goes Lithographing Co Inc Chicago Press COlp Cardinal ColorprintPrinting ChicagoTnbune Co SevenWorldwide Inc Newsweb Corp Melar Litho Inc American Thiessen LLC Palmer Printing Inc Enteron Group LLC Diemand Printing Co Ideal Box Co 6247 W 74th St 815 25th Ave 2810 Madison St 5656 McDennott 2910 S 18thAve 2649 GardnerRd 2206 Parkes Drive 5500 W 31st St 1301 S47thAve 16 Mary St 1000 ExecutiveDr 11600 W GrandAve 2917 Latoria Ln 9901 S 78thAve 11900 W RooseveltRd 220 Fencl Ln 7545 Santa Fe Dr 1950N Ruby St 7460 N LehighAve 5990 W Toughy 5990 W Touhy Ave 5555 W Howard St 16920 Statc St 1099 GrcenleafAve 1200 Chase Ave 1855 GreenleafAve 1800 GreenleafAve 1401 BnunmelAve 1600 S Laflin St 4000 W Fillmore St 42 W 61st St 1112 N HornanAve 2532 W Irving Park Rd 777 W Chicago Ave 225 W Superior 1645 W FullertonAve 2544 W Diversey 2357 N Milwaukee 739 S Clark St 5565 N Lynch St 4237 W 42ndPI 4800 S Austin BedfordPark IL Bellwood IL Bellwood IL Berkeley IL Broadview IL Broadview IL Broadview IL Cicero IL Cicero UL Des Plaines IL Des Plaines IL Northlake IL Franklin Park .IL Hickory Hills IL Hillside IL Hillside IL Hodgkins IL Melrose Park IL Niles IL Niles IL Niles IL Skokie IL South Holland IL Elk Grove Village IL Elk Grove Village IL Elk Grove Village IL Elk Grove Village IL Elk Grove Village IL Chicago IL Chicago IL Chicago IL Chicago IL Chic.ago IL Chicago IL Chicago IL Chicago IL Chicago IL Chicago IL Chicago IL Chicago IL Chicago IL Forest View IL 60499 60104 60104 60163 60153 60155 60155 60804 60804-1598 60016-3407 60018 60164 60131 60457 60162-2070 60162 60525 60160-1110 60714 60714-4610 60712 60077 60473 60007 60007 60007 60007 60007 60608-2123 60624-3916 60621-3941 60651 60618-3716 60610 60610 60614 60647 60647 60605 60630 60632 604027 Advantage Printing Inc 1385 Jeffrey Dr Addison 

### IL 60101 Lakewood PrintingInc 85 S Fairbank Addison 

### IL 60101 ABS Graphics Inc 901 S Rohling Rd Addison IL 60101 Tempo Graphics Inc 455 E North Ave Carol Stream 

### IL 60188 FlintInkNorth America Corp 530 TowerBlvd Carol Stream 

### IL 60188 JohnsonPrinters 2659 Wisconsin Ave Downers Grove 

### IL 60515 Diamond Web Printing Inc 2820 Hitchcock Downers Grove 

### IL 60515 Jet Lithocolor Inc 1500 Centre Circle Downers Grove IL 60515-1081 DowJones & Co Inc 340 Shwnan Blvd Naperville IL 60566 Madden Communication 90I Mittel Dr Wood Dale IL 60191 Vis-o-Graphics 9 S 050 Joliet Rd Willowbrook IL 60527-5637 TegrantAlloyd Brands Inc 1500 Paramount Pkwy Batavia IL 60510 Carlith Printing Co 250 CarpenterBlvd Carpentersville IL 60110 Voris Communications Co Inc d/b/a Kehnscott Press 1665 Mallette Rd Aurora IL 60505 Hagg Press Inc 1165 Jansen Farm Ct Elgin IL 60123 InterCo PrintLLC 2531 DuKane Dr St Charles IL 60174 PerfectPlastic Printing Corp 345 KautzRd St Charles IL 60174 FreedomImaging Systems Inc 780 McClureRd Aurora 

### IL 60504 651 S Martin Luther Nosco Inc King JrAve Wankegan IL 60085 Lake County Press Inc 98 Noll St Waukegan IL 60085 Corporate Express 176 WTerra Cotta Ave Crystal Lake IL 60014 JolietPattern Works Inc 508 Pasadena Ave CrestHill IL 60435 Fox Valley Publications 3101 Route 30 Plainfield IL 60544 Vision Integrated Graphics LLC 8301 W 183 Rd St TinleyPark IL 60487-6225 DowJones & Co Inc 915 Hemlock Highland IL 62249 Highland SupplyCorp 12344 State Route 143 Highland IL 62249 Mar Graphics 523 SMeyer Valmeyer IL 62295 7450 N McCormick Federal-Mogul Corp Blvd Skokie IL 60076-8103 Stephen Foss1er Company 439 S Dartmoor Dr Crystal Lake IL 60014 Duro BagMfg Co 12245 S Central Ave Alsip IL 60803 WeberMarking Systems Inc 711 W AlgonquinRd ArlingtonHeights IL 60005-4520 Packaging Corp oflL d/b/aAcorn CorrugatedBox Co 5133 W 65th St BedfordPark IL 60638 International Paper Co 7333 S Lockwood Ave BedfordPark IL 60638 International Paper Co 5300 W 73rd Sl BedfordPark 

### IL 60638 A1can Packaging Food & Tobacco Inc 5303 StCharles Rd Bellwood IL 60104-1089 Srnurfit-Slone Container Corp 7601 S 78th Ave Bridgeview IL 60455-1200 CFC International Inc 500 State St Chicago Heights IL 60411 International Paper Co 100 E Oakton St Des Plaines IL 60018-1966 Deluxe Manufacturing Operations Inc 1600 E Touby Ave Des Plaines IL 60018 PamcoPrinted Tape & Label Co 2200 S WolfRd Des Plaines 

### IL 60018 Formel Industries Inc 2355 N 25thAve Franklin Park IL 60131 Prairie StateGroup 11100W AddisonAve Franklin Park IL 60131 Wagner Zip Change 3100 Hirsch Melrose Park IL 60160 Dear-LamPackaging Inc 1950 PrattBlvd Elk Grove Village IL 60007-5993 Paddock Printing Center 1000W Albion Ave Schaumburg IL 60193 Bio-Industries 540 Allendale Dr Wheeling IL 60090-2639 BagcraftPackaging LLC 3900 W 43rd Sl Chicago IL 60632 Solo Cup Operating Corporation 7575 S Kostner Ave Chicago IL 60652 Color Communications Inc 4000 W Fillmore St Chicago IL 60624-3916

### 8

General Packaging Products 1700 S Canal St Chicago IL 60616 MeadWestvaco Packaging Systems LLC 9540 S DorchesterAve Chicago IL 60628 Bio Star Films LLC 4848 S Hoyne Ave Chicago IL 60609-4097 Cenveo 3001 N RockweIl St Chicago IL 60618 TIN Inc d/b/aTemple

- Inland 2555 S Leavitt St Chicago IL 60608 American Labelmark Co 5724 N Pulaski Rd Chicago IL 60646-6797 General Packaging Products Inc 730I HamlinAve Chicago IL 60629 Bluegrass Flexible Packaging Co LLC 1228 E Tower Rd Schaumburg IL 60173-4386 ROIlprint Packaging Products Inc 320 StewartAve Addison IL 60101·3310 Quality Bags Inc 575 S Vista Ave Addison IL 60101 Graphic Packaging International Inc 400ENAve Carol Stream IL 60188 MeyercordRevenue Co 475 Village Dr Carol Stream IL 60188 Packaging Personified Inc 246 Kehoe Blvd Carol Stream IL 60188 Bema PolyTech d/b/a Bema FilmSys Inc 744 N Oaklawn Ave Elmhurst IL 60126 Genesis Packaging & Design 20W345 IOlst St Lemont IL 60439 Pro-pak Industries Inc 1099 Atlantic DrUnit I WestChicago IL 60185 PechineyPlastic Packaging Inc 475 N KirkRd Batavia IL 60510 International Paper 100I KneIl St Montgomery IL 60538 Covalence Specialty Materials Corp 921 Industrial Dr Aurora IL 60506 PrintpackInc 1400 AbbottDr Elgin IL 60123-1823 Multifilm Packaging Corp_' 1040N McLeanBlvd Elgin IL 60123 TIN Inc DBA Elgin Corrugated Box 824 Raymond St Elgin IL 60120 Dopaco Inc 315 KirkRd St Charles IL 60174-3429 Moore WaIlace North America Inc 3626 StemAve St Charles IL 60174 Nosco Inc 2199 DelanyRd Gurnee IL 60031 ColbertPackaging Corp 28355 N BradleyRd Lake Forest IL 60045 Vonco ProductsInc 201 Park Ave Lake Villa IL 60046 AmcorFlexibles Healthcare Inc 1919 S Butterfield Rd Mundelein IL 60060-9735 Parade Packaging 262 S Shadle Ave Mundelein IL 60060 Stone ContainerCorp 1900Foss ParkAve NorthChicago IL 60064 651 S MartinLuther Nosco Inc KingJrAve Waukegan IL 60085 Fisher Container Corp 1111 BuschPkwy Buffalo Grove IL 60089 

## en Industries Corp 22160 N PepperRd Barrington IL 60010 Kraftseal Corp 13970 W Polo Trail Dr LakeForest IL 60045 AMPAC Flexicon LLC 165 Chicago St Cary IL 60013 HS Crocker Co Inc 12100 SrnithDr Huntley IL 60142-9618 Diversapack LLC 201 N Prospect St Marengo IL 60152 Catty Corp 6111 White Oaks Rd Harvard IL 60033 Gateway Packaging Inc 20 Central IndustrialDr Grartite City IL 62040 Highland Supply Corp 1111 6th St Highland IL 62249 Highland Supply Corp 12344 State Route 143 Highland IL 62249 WilliamYuenger Manufacturing Co 5215 S Keeler Chicago IL 60632 InteriorCrafts Inc 2513 W Cullerton Chicago IL 60608 FCI Inc 1750NLawndale Ave Chicago IL 60647 Illinois FlushDoorInc 14325 S Vandyke Rd Plainfield IL 60544

# A 5

## Electronic Filing - Received, Clerk's Office, September 14, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD



### INTHE MATTEROF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FORVOLATILE ORGANlC MATERIAL EMISSIONS FROM GROUP II 

### CONSUMER & 

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

### ) ) ) 

### ) ) ) 

### RIO-8 (Rulemaking-Air)

NOTICE 

### To: John Therriault, Assistant Clerk

. Illino.is Pollution ControlBoard James R. 

### Thompson Center 100West Randolph, Suite 11-500 Chicago, Illinois 60601-3218 SEE ATTACHED SERVICE LIST 

### PLEASE TAKENOTICEthat Ihave todayfiled withthe Office ofthe Pollution Control Board the TESTIMONY OF DAVID BLOOMBERG and MOTION TO AMEND RULEMAKJNG PROPOSAL ofthe lIIinois EnvironmentalProtection Agency, copies ofwhich are herewith served upon you.

Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:Cz):;u,o DanaVetterhoffer Assistant Counsel Division ofLegal Counsel DATED: September 14, 2009 1021 N. GrandAve. East 

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

## Electronic Filing - Received, Clerk's Office, September 14, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD



### IN THEMATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FORVOLATILE ORGA.1"llCMATERIALEMISSIONS FROM GROUP IT CONSUMER & 

### COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE211,218, and 219 ) ) 

### ) ) 

### ) ) ) ) 

### RIO-8 (Rulemaking-Air)

TESTIMONY OFDAVID BLOOMBERG 

### My name is David E. Bloomberg. I am employedby the JIlinois Environmental Protection Agency ("Illinois EPA" or "Agency") as the ComplianceUnitManagerin the Compliance Section within the Division ofAirPoIlutionControl. Ihavebeen at the Agency in this capacity for overfive years, and was previouslyanEnvironmental ProtectionEngineerin theAir Quality Planning Section fortwelve and ahalfyears.

My academic credentials include aBachelorofScience degreein ceramic engineering from the UniversityofIllinois at Champaign-Urbana, as weIl as completion ofall graduatecoursework required for aMaster's degree in the same areaofstudy. Ihave also completednumerous environmental courses overthe years andprovided training on airpollution complianceissues to industrypersonnel and environmental consultants.

Among my duties, Iwrotethe technical support document ("TSD") and co-wrotethe regulatory language forthis rulemaking proposal, and did likewise forprevious rulemakings involving lithographicprinting and several coating categories. Ihave alsobeen the Agency's main contact forinterpretations and questions involving these rules and otherregulations coveringprinting I

## Electronic Filing - Received, Clerk's Office, September 14, 2009

and coating for over 14 years. 

### In thatrole and as part ofmy Compliance UnitManager responsibilities, {have also participated in both adjusted standard and enforcementhearings involving sources engaged in the printing offlexible packaging. 

### In addition, Ihave been involved in designing, writing, implementing, and enforcing a widevariety ofairpollution regulations, including those for mercury, NOx trading, the CleanAir Interstate Rule, and the Emissions Reduction Market System.

My duties as the ComplianceUnitManagerinvolve supervision ofthe Bureau ofAir staffwho review documents submittedby sources, such as exceedance, semi-annual, and annual compliance reports, as well as those who review emissions tests, and I sign offon all such reviews before they are finalized. 

### In addition, I participate in decisions regarding enforcement of the Board's airpollution regulations and oversee theprocess ofsending out Violation Notices and related activities.

I am here todayto provide testimony and to answer questions pertaining to the Group II Yolatile Organic Materials ("YOM") Control Techniques Guidelines ("CIGs") regulations that the Agency has proposed. A more extensive discussion oftheseproposed modifications can be found in the ISD and StatementofReasons, but Iwill summarize them briefly again here.

These proposals address the same categories as those covered by the United States Environmental Protection Agency ("USEPA") in what is known collectively as the Consumer and Commercial Products, Group II, which includes lithographic printing, letterpress printing, flexible packagingprinting, flat wood paneling coating, and industrial cleaning solvents.



### 2

## Electronic Filing - Received, Clerk's Office, September 14, 

## 2009

Section 172 ofthe Clean Air Act ("CAA") requires that state implementation plans ("SIPs") for

nonattainment areas, such as the Chicago and Metro-East St. Louis nonattainment areas (''NAAs'') in Illinois, must include requirements for "reasonably available control technology" (''RACT'') as it applies to emissions sources. Section I82(b)(2)(A) ofthe CAA further requires that SIPs be revised to include RACT for yOM emissions sources that are covered by a CTG document issued by USEPA afterNovember 15, 1990, and before the area's date ofattainment.

TheUSEPA defines RACT as "the lowest emission limitation that aparticular source is capable ofmeetingbythe application ofcontrol technology that is reasonably available considering technological and economic feasibility." 

### In developing the CTGs for the categories covered by this rulemaking, USEPA evaluated the sources ofVOM emissions from the applicable industries, the available control possibilities to address the associated emissions, and the cost ofsuch control measures. lllinois EPA based much ofits proposal on these CTGs and on USEPA research.



### Lithographic Printing

Proposed changes to the lithographic printing regulations involve modifications to control requirements for heatset web offsetlithographicprinters as well as changes to fountain solution and cleaning solution limitations for all subjectunits. 

### In addition, the requirements for cleaning solutions and fountain solutions are being extended to sources with lower emissions. All ofthese

3

## Electronic Filing - Received, Clerk's Office, September 14, 2009

changes have been determined to be 

### RAeT by USEPA, and Illinois EPA's experience with control devices on lithographic printing sources correlates with that determination.

In orderto reduce the burden on smaller sources, and as aresult ofdiscussions with industry representatives, exclusions to the cleaning solution and fountain solution requirements have been included in this proposal. Sources may make use ofsuch exclusions ifthey fall into the listed categories. Specifically, the exclusions apply to sources that emit between 15 and 100pounds per day ofVOM and include sheet-fed presses that print substratesno larger than II inches by 17 inches and any lithographic presswith afountain solution reservoirofno largerthan one gallon. In addition, all sources in this emission range will be able to use up to 110 gallons ofcleaning solution per year that do not meet eitherthe YOM content or vaporpressure requirements. Sources may choose to opt out ofthese exclusions ifthey do not wish to make use ofthem, and thus would not need to keep the records required ofthose utilizing the exclusions. 

### In addition, discussions with industry led the Agency to propose anew method ofcalculating applicability based on material use, which maybe easierfor some sources.

Another change to the lithographic printingregulation that aids sources is the specification of YOM retention factors. The existingregulation recognizes that the substrate retains some ofthe YOM present in the ink, and thus aretention factor of0.95 is used when calculating emissions from non-heatsetinks, while a factor of0.20 is used when calculating emissions from heatset inks. Theproposed modification contains a factor recognizing that YOM also remains on solvent-ladenrags that are stored and disposed ofproperly. These factors continue to be allowed for determination ofapplicability. In addition, this proposal adds emission adjustmentfactors to



### 4

## Electronic Filing - Received, Clerk's Office, September 14, 2009

be used in other situations when not determining applicability (such as for Annual Emissions Reports and permit limits). These factors take into account carryover ofVOM from automatic blanket wash and fountain solutions into the dryer and control device.

Letterpress Printing

. While there are veryfew letterpress operations in Illinois NAAs, and apparently no heatset

letterpress units, the State is still required to promulgate the CTG regulations for this category. Letterpress emission sources are similarto those for lithographic printing, with the exception that letterpress operations do not use a fountain solution. 

### In addition, letterpress printingpresses are often operated at the same source as lithographic printing and many ofthe control options for letterpress printing are the same as the control options for lithographic printing as well. This is especially true in terms ofcleaning solutions. As such, the proposed rule would adoptmost ofthe RACT recommendations ofthe CTG. It should be noted that, unlike for largerlithographic printing sources, the Agency is proposing to usethe cleaning solution 70 percentYOM content limit for all subject letterpress units, as letterpress operationshave neverbeen specifically regulated in Illinois before and thus there are no concerns about loosening existing standards.

Flexible Packaging Printing

The modifications being proposed for flexible packageprinting appear inthe sections that currentlycover all rotogravure and flexographic printing; however, these modifications only apply to this specific subcategory ofprinting operations.



### 5

## Electronic Filing - Received, Clerk's Office, September 14, 2009

The proposedchanges focus on reducing YOM emissions from inks and cleaning operations, Ink emissions must be reduced either through a lower YOM content orby a control device, where the percentage reduction required ofan add-on control varies depending on when the press and control were constructed at the site, The approach to reducing YOM emissions from cleaning materials focuses on workpractices, and thus there is no specific numeric limitthat applies; however, the applicability level for suchworkpractices is much lower, at 15 pounds per day, as compared to the applicability thresholds of25 tons peryearpotential to emit or 100 tons peryear maximum theoretical emissions for the remainder ofthe rule.

Industrial Cleaning Solvents

Thc industrial cleaning solvents category encompasses many products and cleaning styles that

are used to clean dirt, soil, oil, and grease, as well as remove adhesives, paints, and inks. The proposed rule thus covers awide range ofcleaning activities. Theproposal follows USEPA's CTG in the applicability threshold of 15 pounds per day ofYOM emissions and inmost ofthe required YOM limits. The CTGrecommends a contentlimit of50 grams YOM perliter (0.42 lb/gal) ofcleaning material for those industries that are not already covered, and are not to be covered, by a CTG. However, there are some cases where the Illinois EPA has received USEPA permission to use higher limits

- orindeed to exempt the type ofoperation entirely

- in response to industryrepresentatives' comments regarding issues specific to certain categories ofcleaning. 

### In addition, there is an alternate vaporpressure limit of8 nun Hg at 20 degrees Celsius that may be used in place ofthe 50 gram limit. Furthermore, cleaning solvent emissions can alsobe



### 6

## Electronic Filing - Received, Clerk's Office, September 14, 2009

reduced by add-on controls, modifying equipment, or changing the method ofcleaning such that

an overall control efficiency of85 percent reduction in emissions ofcleaning solvent YOM is achieved

.

. In addition to the limits discussed above, all subject sources must make use ofcertain work

practices to reduce emissions. General workpractices include keeping solventcontainers and

. . used applicators covered; properly storing and disposing ofspent solvents and used cleaning rags; minimizing air circulation around all cleaning operations; and implementing equipment practices that reduce emissions, e.g., leak detection and repairpractices.

Flat Wood Paneling Coating

The category offlat wood panelingcoating has not beenpreviously covered in Illinois' regulations (though some products that will now be defined as flat wood paneling may havebeen previously covered under the wood furniture coatingregulations). 

### As with most coating categories, the two main options for compliance are the use oflower-

### yOM coatings or add-on controls. Illinois EPA is using the YOM content limits and control efficiencies that USEPA determined in the CTG to be RACT.

In addition, workpractices related to cleaning operations will applyto this category. Some of these requirements are already in place within the existing regulations for wood furniture coaters. UndertheAgency's proposal, these will apply to flat wood paneling coaters as well, as will several other specific requirements.



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## Electronic Filing - Received, Clerk's Office, September 14, 2009

Conclusions

The Agencybelieves these proposed changes to be largely non-controversial, as they stem from USEPA's determination ofRACT that applies to these categories ofsources nationwide. The Agency agrees with USEPA that all the proposed changes are technically feasible and economicallyreasonable. Furthermore, as noted earlier, incorporating these additions and modifications to existing Illinois regulations is required by the CAA and USEPA; specifically, Section 182(b)(2)(A) ofthe CAA requires that Illinois revise its SIP to include RACT for YOM emissions sources that are coveredby a Group II CTG.

The Illinois EPA engaged in multiple rounds ofoutreach efforts in relation to this proposed rulemaking. The first was accomplished electronically, with the second involving follow-up calls from the Agency to sources that had submitted comments as well as extensive, detailed discussions between the Agency and industry group representatives. Such communication resulted in the Agency making numerous changes to the proposed rule between the original draft sent out for comments and the [mal proposal submitted to the Board, with almost all such changes being inresponse to industry concerns. 

### In addition, thc Agencyhas had frequent discussions with USEPA personnel in both theregional office and headquarters, and has gathered information from other states. Even aftertheAgency submittedits proposal to the Board, communication with theseparties continued, resulting in the Motion to Amend Rulemaking Proposal that is being submitted along with this prefiJed testimony. 

### In responding to



### 8

## Electronic Filing - Received, Clerk's Office, September 14, 2009 industry, the Agencyhas been as agreeable as possible to recommendations while still adhering to USEPA requirements andmaintaining theintegrity ofthe rules.

9

## Electronic Filing - Received, Clerk's Office, September 14, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD



### IN THEMATTER OF:**REASONABLYAVA~ABLECONTROL** 

### TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUPII CONSUMER & 

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

### ) ) 

### ) ) ) ) 

### RIO-8 (Rulemaking-Air)

MOTION TO AMEND RULEMAKING PROPOSAL 

### The Proponent, the Illinois Environmental ProtectionAgency ("Illinois EPA"), byits attorney, andpursuant to 35 Ill. Adm. Code 101.500 and 102.402, moves that the D1inois Pollution ControlBoard ("Board") amend Parts 218 and 219 oftms rulemaking proposal. In supportofits Motion, the l1Iinois EPA states as follows: I. OnJuly 9, 2009, the Illinois EPA filed aproposal with the Boardto amend 35 Ill. 

### Adm. CodeParts 211, 218, and 219 to control the emissions ofvolatile organic materials ("VOM") from Group II Consumerand Commercial Product categories. The proposal implements reasonably available control technology for such categories in responseto controltechniques guidelines issuedby the United States Environmental ProtectionAgency (''USEPA''). The Illinois EPAproposes the following amendments to its proposal. Industrial Cleaning Solvents 2. The USEPArecentlyinformedthe Illinois EPA that the Illinois EPA may exempt digital printing from the control requirements set forth in Section 218/219.187 ofits proposal. The Illinois EPAtherefore recommends amending Section 218/219.1 87(a)by addingdigital printing to the listofexclusions, and Section 218/219.1 87(b) byremoving digital printing from the YOM content limitations.

I

## Electronic Filing - Received, Clerk's Office, September 14, 

## 2009

Section 

### 218/219,187(a)(2)(C)(xv) and (xvi): 

### C) The following cleaning operations shall be exempt from the requirements ofsubsections (b), (c), 

### (f), and (g) ofthis Section:

xv) Cleaning ofnumismatic**dies~,** (xvi) Cleaning operations associated with digital printing, Section 

### 218/219, 187(b)(1)(C)(ii) and (iii): C) Cleaning ofink application equipment:

ii) Screen printing aHa a:gital jlriHtiHg iii) Ultravioletink and electron beam

.ink application equipment, except screenprinting aBE! E!igital printing 

### 0,50 4,2

0,65 5.4 3, 

### In response to a commentby industry representatives, the Illinois EPA proposes amending Section 218/219.I87(e)(1 

### )(B) by removing the requirement that a source include in its notification to the Illinois EPA calculations showing an exceedance ofthe applicability threshold

.. Section 218/219.187(e)(1)(B): 

### B) Notifythe Agency ofany record that shows that the combined emissions ofVOM from cleaning operations at the source everequal or exceed 6,8 kg/day 

### (15 Ibslday), in the absence ofair pollution control equipment, within 30 days afterthe event**occurs~.** 811M Betifieatiell sIlail illslll!le sale"latieHs sbewing tbe eail)' emi5sisBS efVOM frelll eleallillg ejleffltieBs at tbe semee fer tba 1'16)'(5) 

### ill "Alieb ellliss;sllS aEl"aled er exeeeaed 8.8 k/iday (15**IlJslaa)~;** 4. In response to a requestby industry representatives, the lllinois EPA proposes amending Section 218/2I9.187(e)(2) by deleting the requirement that a subject source certifythe limitation with which each subject cleaning operation will comply, The Illinois EPA also proposes 

### 2

## Electronic Filing - Received, Clerk's Office, September 14, 2009

deleting the requirement that a source notify the Illinois EPA at least 30 days in advance of changing its method ofcompliance between the YOM content limitation andvaporpressure limitation. 

### Section 

### 218/219. 187(eJ(2J(AJ(iii): A) ByAprill, 2011, orupon initial start-up ofthe source, whicheveris later, submit a certification to theAgencythatincludes:

iii) The limilatiea

### wilfi wilich eBel! sl>bjeet cleaning operBlioa

### will 60Hljlly (i.e., t!lo emissions eontrel systemreEJ:uireffieHt, VOM soslest limitatios, orya!"orjlressure limitatios), 

### ana illfcomplying with the emissions control system requirement, what type of emissions control system will be used; 

### Section 

### 218/219. 187(eJ(2J(B): B) At least 30calendar days before changing the method ofcompliance between subsections (b)(l) or, (b)(2), and subsection (b)(3) ofthis Section, notify the Agency in writing ofsuch change. Such notification shall include a demonstration ofcompliance with thenewly applicable subsection; 5. The Illinois EPA proposes amending Section 21 

### 8/219.1 87(g) by clarifying when testing pursuant to sueh Section shall be perfonned. 

### Section 218.187(g)(1) and(2): g) TestingRequirements. I) Testingto demonstrate compliance with the requirements ofthis Section shall be conducted bythe owner or operatorwithin 90 days after a requestby the Agency, oras otherwise specified in this Section. Such testing shall be conducted at the expense ofthe owner or operator and the owneroroperator shall notify the Agencyinwriting 30 days 

### in advance ofconducting such testingto

.allow the Agencytobepresent during such testing; 2) Testing to demonstrate compliancewith the YOM content limitations in Section 2I8.1 87(b)(l) ofthis Subpart, and to determine the YOM content ofcleaning solvents and cleaning 3

## Electronic Filing - Received, Clerk's Office, September 14, 2009

solutions, shall be conducted Hj38fl T8EjHest eftlle AgeRey, as follows: Section 

### 219. 187(g)(J) and (2): g) TestingRequirements. I) Testing to demonstrate compliance with therequirements ofthis Section shall be conductedby the owner or operator within 90 days after arequest by the Agency, or as otherwise specified in this Section. Such testing shall be conducted at the expense ofthe owner or operator and the owner oroperator shall notify the Agency in writing 30 days in advance ofconducting such testing to allow the Agencyto bepresent during such testing; 2) Testing to demonstrate compliance with the YOM content limitations in Section 219.187(b)(1) ofthis Subpart, and to determine the YOM content ofcleaning solvents and cleaning solutions, shall be conducted ulleil reEjllest eftlle Ageiley, as follows: Flexible Packaging Printing 6. 

### In response to a requestby industryrepresentatives, the Ulinois EPA proposes amending Section 2181219.404(b)(I

### )(B) and (d)(1 

### )(0) by deletingreferences to instruments bywhich

. owner or operators may calculate the volume or weight ofcoatings and inks as applied each day

on subjectcoating lines, as such instrumentation is not currently available to sources. Section 

### 218/219.404(b)(1)(B): B) Calculations which demonstratethat total maximum theoretical emissions ofVOM from all flexographic and rotogravure printing lines at the source never exceed 90.7 Mg (100 tons) percalendaryearbefore the application ofcapture systems and control devices. Total maximum theoretical emissions ofYOM for a flexographic orrotogravure printing source is the sum ofmaximum theoretical emissions ofYOM from each flexographic and rotogravureprinting line at the source. The following equation shall be used to calculate total maximum theoretical emissions ofYOM per calendar yearbefore the application ofcapture systems and control devices for each flexographic androtogravureprinting line at the source: 

### Ep 

## =A x B 

### + 1095 (Cx D x F)



### 4

## Electronic Filing - Received, Clerk's Office, September 14, 2009

where: 

### Ep = 

### Total maximwn theoretical emissions ofVOM from one flexographic orrotogravure printing line in units ofkg/year (lbs/year); A = 

### Weight ofVOM per volume ofsolids ofthe coating or ink with the highest YOM content as applied each year on the printing line .in units ofkg VOM/I (lbs VOM/gal) ofcoating orink solids; 

### B

## = Total volwne ofsolids for all coatings and inks that canpotentially be applied each year on theprinting line in units ofl/year (gaVyear). The instrument andlElF 

### method by which the owneror operator accurately mea5IHB8 ElF 

### calculated the volume ofeach coating and ink as applied and the amount that can potentiallybe applied each year on the printing line shall be described in the certification to the Agency; C

## = Weight ofVOM pervolume ofmaterial forthe cleanup material or solvent with thehighest YOM content as used each year on the printing line in units ofkg/1 (lbs YOM/gal) ofsuch material; D = 

### The greatestvolume ofcleanup material or solventused in any 8- hourperiod and F

## = The highest fraction ofcleanup material or solventwhich·is not recycled orrecovered for offsite disposal during any 8-hourperiod. Section 218/219.404(d)(l)(D): D) The inslmlfleHt ElF

### method by which the owneroroperatorwill accurately mBa5lHe OF 

### calculate the volume, orweight ofsolids, as applicable, of each coating and ink as applied each day on eachprinting line. 7. 

### In response to a comment by industryrepresentatives, the Illinois EPA recommends amending Section 218!2l9.404(t)(2} by removing the requirementthat a source include in its notification to the Illinois EPA calculations showing an exceedance ofthe applicability threshold. Section 218/219.404(f)(2): 2) Notify the Agencyin writing ifthe combined emissions ofVOM from all flexographic and rotogravureprinting lines (including inks and solvents 

### 5

## Electronic Filing - Received, Clerk's Office, September 14, 2009

used for cleanup operations associated with the flexographic and rotogravure lines) at the source everequal or exceed 6.8 kg/day (15 Ibs/day), in the absence ofairpollution control equipment, within 30 days afterthe event occurs. Sush nelifisatieR shall iHehl!le salsulatieRs shewiBg Ihe eaily emissieAs efVOM [rem all flexographie aHe retegra'AlFe priRtiAg liBes atthe seUfse fer the sayEs) iR '""hish emissieHs e!l1Jalee ef el(SeeSee 

### e.8 I[l¥eay (15 las/eay). Lithographic Printing 8. The Illinois EPA proposes amending Section 218/219.405(c) by deleting references to Section 218/219.408 that were inadvertently left in the rule, as the Illinois EPA is proposing to repeal Section 218/219.408. Section 218.405(c): c) On and afterMay I, 2010: I) The requirements in Sections 218.407(a)(I)(B) through (a)(I)(E) and 218.407(b) and all applicable provisions in Sections 218.40528 through 218.411 ofthis Subpart shall apply to all owners or operators ofheatset web offset lithographicprinting line(s), iftbe combined emissions ofVOM from all lithographic printing line(s) at the source (including solvents used for cleanup operations associated with the lithographic printing line(s» ever exceed 45.5 kg/day (100 Ibs/day), calculated in accordance with Section 218.411(b)(2)(B), before the'application ofcapture systems and control dcvices; 2) The requirements in Sections 218.407(a)(I)(A) and 218.407(a)(2) through (a)(5) and all applicableprovisions in Sections 218.4028 through 218.411 ofthis Subpart shall apply to all owners or operators oflithographic printing line(s) ifthe combined emissions ofVOM from all lithographic printing \ine(s) at the source (including solvents used for cleanup operations associated with the lithographic printing line(s» everequal orexceed 6.8 kg/day (IS Ibs/day), calculated in accordance with Section 218.411 (b)(I)(B), before the application ofcapture systems and control devices; Section 219.405(c): c) On and afterMay 1,2010:



### 6

## Electronic Filing - Received, Clerk's Office, September 14, 2009

1) The requirements in Sections 219.407(a)(1 )(B) through (a)(I)(E) and 219.407(b) and all applicable provisions in Sections 219.4028 through 219.411 ofthis Subpart shall applyto all owners or operators ofheatset web offset lithographic printing line(s), ifthe combined emissions ofVOM from all lithographic printing line(s) at the source (including solvents used for cleanup operations associated with the lithographic printing line(s) everexceed 45.5 kg/day (100 Ibs/day), calculated in accordance with Section 219.411 (b)(2)(B), before the application ofcapture systems and control devices; 2) The requirements in Sections 219.407(a)(I)(A) and 219.407(a)(2) through (a)(5) and all applicable provisions in Sections 219.4028 through 219.411 ofthis Subpart shall apply to all owners or operators oflithographic printing line(s) ifthe combined emissions ofVOM from all lithographicprinting Jine(s) atthe source (including solvents used for cleanup operations associated with the lithographic printing line(s» everequal orexceed 6.8 kg/day (15 Ibs/day), calculated in accordance with Section 219.41 I(b)(I)(B), before the application ofcapture systems and control devices; 9. The Illinois EPAproposes amending Section 218/219.409(a) and (c) by clarifying when testing pursuant to such Section shall be performed. The Illinois EPA also proposes amending subsection (c) bycorrecting an internal cross-reference. Section 218.409(a) and (c): 

### a) Testing to demonstrate compliance with the requirements ofSection 218.407 ofthis SUbpart shall be conductedby the owneroroperator within 90 days after arequest by the Agency. or as otherwise specified in this Subpart. Such testing shall be conducted at the expense ofthe owner oroperator and the owneroroperator shall notifythe Agency in writing 30 days in advance ofconducting such testing to allow theAgencyto be presentduring such testing.

c) Testing to demonstratecompliance with the YOM contentlimitations in Section 218.407(a)(I)(A), (a)(2), (a)(3) and (a)(4)(A) oftlris Subpart, and to determine theYOM contentoffountain solutions, fountain solution additives, cleaning solvents, cleaning solutions, and inks (pursuantto the requirements ofSection 218.411 (a)(1 )(B), (b)(l)(B). 

### or (b)(2)(B) ofthis Subpart, as applicable), shall be conducted upon request oflbe Agency,..N as otherwise specified in this Subpart, as follows: 

### 7

## Electronic Filing - Received, Clerk's Office, September 14, 2009

Section 219.409(a) and (c): 

### a) Testing to demonstrate compliance with the requirements ofSection 219.407 ofthis Subpart shall be conductedby the owner or operator within 90 days after a requestby the Agency, or as otherwise specified in this Subpart. Such testing shall be conducted at the expense ofthe owner oroperator and the owner or operator shall notify the Agency in writing 30 days in advance ofconducting such testing to allow the Agency to be presentduring such testing.

c) Testing to demonstrate compliance with the YOM content limitations in Section 219.407(a)(I)(A), (a)(2), (a)(3) and (a)(4)(A) ofthis Subpart,and to determine the YOM content offountain solutions, fountain solution additives, cleaning solvents, cleaning solutions, and inks (pursuantto the requirements ofSection 219.41 I(a)(1 )(B), (b)(l)(B), or (b)(2)(B) ofthis Subpart, as applicable), shall be conductedupon request ofthe Agency, ill 

### as otherwise specified in this Subpart, as follows: 10. The Illinois EPA proposes adding, and amending, Section 218/219.410 to the rulemaking proposal. 

### In response to acomment from industry representatives, the Illinois EPAhas discovered several incorrect internal cross-references within the current Section 218/219.410. The Illinois EPA therefore proposes amending subsections 

### (b)(l), (b)(2), (e)(I)(B), and (e)(2) to correct the cross-references. As 218/219.410 is an existing section, only the IIlinois EPA's proposed amendments are underlined below. Section 218.410 Monitoring Requirements for Lithographic Printing a) Fountain SolutionTemperature. I)'

. The owneror operator ofany lithographic printing line(s) relying on the temperature ofthe fountain solution to demonstrate compliance shall install, maintain, and continuously operate a temperature monitor ofthe fountain solution in the reservoir orfountain tray, as applicable. 2) The temperaturemonitor mustbe capable ofreading with an accuracy of 1°C or 2°C, and mustbe attached to an automatic, continuous recording device such as a strip chart, recorder, orcomputer, with at leastthe same accuracy, that is installed, calibrated and maintained in accordancewith 

### 8

## Electronic Filing - Received, Clerk's Office, September 14, 2009

the manufacturer's specifications. Ifthe automatic, continuous recording device malfunctions, the owneroroperator shall record the temperature of the fountain solution atleast once every two operating hours. The automatic, continuous recording device shall be repaired orreplaced as soon as practicable. b) Fountain Solution YOM Content. The owneroroperatorofany lithographic

. printing line(s) subjectto Section 218.407(a)(I)(A), (a)(2) or (a)(3) ofthis

Subpart shall: 1) For a fountain solution to which YOM is not added automatically: A) Maintainrecords ofthe YOM contentofthe fountain solution in accordancewith Section**2l8.411~)(2)(C);** 

### or B) Take a sample ofthe as-applied fountain solution from the fountain tray orreservoir, as applicable, each time a fresh batch offountain solution is prepared oreach time YOM is added to an existing batch offountain solution in the fountain tray orreservoir, and shall determine compliance with the YOM content limitation ofthe as-applied fountain solution by using one ofthe following options: i) With a refractometer orhydrometer with a visual, analog, or digital readout and with an accuracy of0.5 percent. The refractometer orhydrometermustbe calibrated with a standard solution for the type ofVOM used in the fountain solution, in accordancewith manufacturer's specifications, againstmeasurements performed to determine compliance. Therefractometerorhydrometer mustbe corrected for temperature at least once per 8-hour shift oronceperbatch offountain solution prepared ormodified, whicheveris longer; or ii) With a conductivitymeterifit is demonstrated that a refractometerand hydrometercannot distinguish between compliant and noncompliant fountain solution forthe type and amount ofVOM in the fountain solution. A source may use aconductivitymeterifit demonstrates thatboth hydrometers and refractometers fail to provide significantly different measurements for standard solutions containing 95 percent, 100percent and 105 percent ofthe applicable YOM content limit. The conductivity meterreading for the fountain solution mustbereferenced to the conductivityof the incomingwater. A standard solution shall be used to calibrate the conductivity meterforthe type ofYOM uscd



### 9

## Electronic Filing - Received, Clerk's Office, September 14, 2009

in the fountain solution, in accordance with manufacturer's specificalions; 2) For fountain solutions to which YOM is added at the source with automatic feed equipment, determine the YOM contcnt ofthe as-applied fountain solutionbased on the setting ofthe automatic feed equipment whichmakes additions ofVOM up to apre-set level. Records must be retained ofthe YOM content ofthe fountain solution in accordance with Section**218.411~)(2)(D)** 

### ofthis Subpart. The equipment used to make automatic additions mustbe installed, calibrated, operated and maintained in accordance with manufacturer's specifications. c) Afterburners ForHeatset Web Offset Lithographic Printing Line(s). Ifan afterburneris used to demonstrate compliance, the owneroroperator ofa heatset web offset lithographic printing line subject to Section 218.407(a)(1)(C) ofthis Subpart shall: 1) Install, calibrate, maintain, and oPerate temperature monitoring device(s) with an accuracy of3° C or 5° F on the afterburner in accordance with Section 218.105(d)(2) ofthis Part and in accordance with the manufacturer's specifications. Monitoring shall be performed at all times when the afterburner is operating; and 2) Install, calibrate, operate and maintain, in accordance with manufacturer's specifications, a continuous recorder on the temperature monitoring device(s), such as a strip chart, recorder orcomputer, with atleastthe same accuracy as the temperature monitor. d) Other Control Devices for Heatset Web Offset Lithographic Printing Line(s). Ifa control device otherthan an afterburner is used to demonstrate compliance, the owneroroperatorofaheatset web offsetlithographic printing line subject to this Subpart shall install, maintain, calibrate and operate such monitoring equipment as set forth in the owneror operator's plan approved bythe Agency and USEPA pursuant to Section 218.407(b) ofthis Subpart. e) Cleaning Solution. I) The owner or operatorofany lithographic printing line relying on the YOM content ofthe cleaning solution to complywith Section 218.407(a)(4)(A) ofthis Subpartmust: A) Forcleaning solutions that areprepared atthe source with equipment that automatically mixes cleaning solvent and water (or othernon-VOM):

10

## Electronic Filing - Received, Clerk's Office, September 14, 2009

i) Install, operate, maintain, and calibrate the automatic feed equipment in accordance with manufacturer's specifications to regulate the volume ofeach ofthe cleaning solvent and water (or othernon-YOM), as mixed; and ii) Pre-set the automatic feed equipment so that the consumption rates ofthe cleaning solvent and water (or othernon-YOM), as applied, comply with Section 218.407(a)(4)(A) ofthis Subpart; 

### B) For cleaning solutions that are not prepared at the source with automatic feed equipment, keep records ofthe usage ofcleaning solvent and water (orothernon-YOM) as set forth in Scction 218.411 (fd)(2) ofthis Subpart. 2) The owner or operatorofany lithographic printing line relying on the vaporpressure ofthe cleaning solution to comply with Section 218.407(a)(4)(B) ofthis Subpart must keep records for such cleaning solutions used on any such line(s) as set forth in Section 218.41 

### J(fd)(2)(C) ofthis Subpart. (Source: Amended at

_ Ill. Reg.

__,**effective~** Section 219.410 Monitoring Requirements for Lithographic Printing a) Fountain Solution Temperature. 

### I) The owner oroperatorofany lithographic printing line(s) relying on thc temperature ofthe fountain solution to demonstrate compliance shall install, maintain, and continuously operate atemperature monitor ofthe fountain solution in the reservoiror fountain tray, as applicable. 2) The temperature monitor must be capable ofreadingwith an accuracy of 1°C or2°F and mustbe attached to an automatic, continuous rccording dcvice such as 

### a strip chart, recorder, or computer, with at least the same accuracy, thatis installed, calibrated andmaintained in accordance with the manufacturer's specifications. Ifthe automatic, continuous recording device malfunctions, the owner oroperator shall record the temperature of the fountain solution at least once every two operating hours. The automatic, continuous recording device shall be repaired orreplaced as soon as practicable. b) Fountain Solution YOM Content. The owner oroperator ofany lithographic printing line(s) subjectto Section 219.407(a)(I)(A), (a)(2) or (a)(3) ofthis Subpart shall:

11

## Electronic Filing - Received, Clerk's Office, September 14, 2009

I) For a fountain solution to which YOM is not added automatically: A) Maintain records ofthe YOM content ofthe fountain solution in accordance with Section 219.41 1(§6)(2)(C); or B) Take a sample ofthe as-applied fountain solution from the fountain tray orreservoir, as applicable, each time a fresh batch offountain solution is prepared oreach time YOM is added to an existing batch offountain solution in the fountain tray or reservoir, and shall determine compliance with the YOM content limitation ofthe as-applied fountain solution byusing one ofthe following options: i) With arefractometer orhydrometer with a visual, analog, or digital readout and with an accuracy of0.5 percent. The refractometer orhydrometer must be calibrated with a . standard solution for the type ofYOM uscd in the fountain solution, in accordance with manufacturer's specifications, against measurements performed to determine compliance. The refractometer orhydrometer mustbe corrected for temperature at least once per 8-hour shift or onceperbatch offountain solution prepared ormodified, whicheveris longer; or ii) With aconductivitymeterifit is demonstrated that a refractometer and hydrometer cannotdistinguish between compliant and noncompliant fountain solution forthe type and amount ofVOM in the fountain solution. A source mayuse a conductivitymeter ifit demonstrates thatboth hydrometers and refractometers fail to provide significantly different measurements for standard solutions containing 95 percent, 100percent and 105 percent ofthe applicable YOM contentlimit. The conductivity meterreading for the fountain solution mustbereferenced to the conductivityof the incoming water. A standard solution shall be used to calibrate the conductivity meterfor the type ofVOM used in the fountain solution, in accordance with manufacturer's specifications; 2) For fountain solutions to which YOM is added at the source with automatic feed equipment, determine the YOM content ofthe as-applied fountain solution based on the setting ofthe automatic feed equipment which makes additions ofYOM up to a pre-set level. Records mustbe retained ofthe YOM content ofthe fountain solution in accordance with Section 219.41 I(§6)(2)(D) ofthis Subpart. The equipmentused to make automatic additions mustbe installed, calibrated, operated and maintained in accordance with manufacturer's specifications.

12

## Electronic Filing - Received, Clerk's Office, September 14, 2009

c) Afterburners ForHeatset Web Offset Lithographic Printing Line(s). Ifan afterburner is used to demonstrate compliance, the owneroroperator ofa heatsetweb offset lithographic printing line subject to Section 219.407(a)(1 )(C) ofthis Subpart shall: I) Install, calibrate, maintain, and operate temperature monitoring device(s) with an accuracy of3°C or 5°F on the afterburner 

### in accordance with Section 219. 105(d)(2) ofthis Part and in accordance with the manufacturer's specifications. Monitoring shall be performed at all times when the afterburneris operating; and 2) Install, calibrate, operate and maintain, in accordancewith manufacturer's specifications, a continuous recorder on the temperature monitoring device(s), such as a strip chart, recorder or computer, with at least the same accuracy as the temperature monitor. d) OtherControl Devices for Heatset Web Offset LithographicPrinting Line(s). Ifa control device otherthan an afterburner is used to demonstrate compliance, the owner or operator ofa heatsetweb offset lithographic printing linc subjectto this Subpart shall install, maintain, calibrate and operate such monitoring equipment as set forth in the owner or operator's plan approved bythe Agency and USEPA pursuantto Section 2l9.407(b) oftbis Subpart.

. e) Cleaning Solution. I) The owner or operator ofany lithographic printing line relying on the YOM content ofthe cleaning solution to complywith Section 219.407(a)(4)(A) ofthis Subpartmust: A) Forcleaning solutions that are prepared at the source with equipmentthat automatically mixes cleaning solvent and water (or othernon-YOM): i) Install, operate, maintain, and calibrate the automatic feed equipment in accordance with manufacturer's specifications to regulate the volume ofeach ofthe cleaning solvent and water (or othernon-YOM), as mixed; and ii) Pre-set the automatic feed equipment so that the consumption rates ofthe cleaning solvent aridwater (or othernon-YOM), as applied, comply with Section 219.407(a)(4)(A) ofthis Subpart;

13

## Electronic 

## Filing - Received, Clerk's Office, September 14, 2009

B) For cleaning solutions that are not prepared at the source with automatic feed equipment, keep records ofthe usage ofcleaning solvent and water (or other non-VOM) as set forth in Section 219.411 ([tI)(2) ofthis Subpart. 2) The owneror operator ofany lithographic printing line relying on the vapor pressure ofthe cleaning solution to comply with Section 219.407(a)(4)(B) ofthis Subpartmust keep records for such cleaning solutions used on any such line(s) as set forth in Secdon 219.41 1([tI)(2)(C) ofthis Subpart. (Source: Amended at

_ Ill. Reg.

__' effective----.J 

### II. The Illinois EPA recommends amending Section 218/219.4II(a)(l)(C) by deleting references to instruments by which owners or operators may calculate the volume ofinks as applied each day on subjectprinting lines, as such instrumentation is not currently available to

sources. Section 218/2]9.411(a)(1)(C): C) Either a declaration that the source, through federally enforceable permit conditions, has limited its maximum theoretical emissions ofVOM from ali heatset web offset lithographic printing lines (including solvents used for cleanup operations associated with heatset web offsetprinting lines) at the source to no more than 90.7 Mg (100 tons) per calendaryear before the application ofcapture systems and control devices or calculations which demonstrate thatthe source's total maximum theoretical emissions ofVOM do not exceed 90.7 Mg/yr (100 

### TPY). Total maximum theoretical emissions ofVOM for aheatset web offset lithographic printing source is the sum ofmaximum theoretical emissions ofVOM from each heatset web offsellithographic printing line at the source. The following equation shall be used to calculate total maximum theoretical emissions ofVOM percalendaryear in the absence ofairpollution control equipmentfor each heatsel web offset lithographic printing line at the source: 

### Ep = (R x A 

### x B) 

### +(C x 

### D) 

### + 1095 (F x 

### G 

### x H) Where: 

### Ep = Total maximum theoretical emissions ofVOM from one heatset web offset printing line inunits ofkg/yr (Ib/yr);

14

## Electronic 

## Filing - Received, Clerk's Office, September 14, 2009

A 

## = Weight ofVOM pervolume ofsolids ofinkwith thehighest YOM content as applied each year on theprinting line in units ofkg/I (lb/gal) ofsolids; B 

## = Total volume ofsolids for all inks that can potentially be applied each year on the printing line in units oflIyr (gal/yr). The instrument ar method by which the owner or operator accurately measlifes ar calculated the volume ofeach ink as applied and the amount that can potentially be applied each year on the printing line shall be described in tbe certification to the Agcncy; C = 

### Weight ofVOMpervolume offountain solution with the highest YOM content as applied each year on theprinting line in units of kg/I (lb/gal); D = 

### The total volume offountain solution that can potentiallybe used each year on the printing line in units ofJlyr (gallyr). The instrument andlermethod bywhich the owneror operator accuratelymeasurea af

### calculated the volume ofeach fountain solution used and the amount that can potentially be used each year on the printing line shall be described in the certification to the Agency; 12. The Illinois EPA proposes amending Section 21 8/2I9.411(b) bychanging the material

use thresholds for lithographic printing lines. USEPA previously recommended that material use thresholds for such lines be conservativelybased on 50 percent ofthe poundperday applicability threshold. USEPA has now determined that a 90 percent emission equivalency level is acceptable forboth lithographic and letterpress printingoperations. The following amendments reflect the 90 percent equivalency level for lithographic printing lines. Section 218/219.41l(b)(1)(C)(i) and (b)(l)(C)(ii): 

### C) As an alternative to the calculations in subsection (b)(I)(B), above, a statement that the source uses less than the amount ofmaterial specified in subsections (b)(1)(C)(i) or (ii), below, as applicable, during each calendar month. A source may determine that it emits below 6.8 kg/day (15 lbs/day) ofVOM based upon compliance with such material use limitations. Ifthe source exceeds this amount ofmaterial use in a given calendarmonth, the ov"neroroperatormust, within 15 days ofthe end of that month, complete the emissions calculations ofsubsection (b)(I)(B) to determine daily emissions for applicability purposes. lfthe source ever 15

## Electronic Filing - Received, Clerk's 

## Office, September 14, 2009

exceeds this amount ofmaterial use for six consecutive calendar months, it is no longer eligible to use this subsection as an alternative to the calculations in subsection (b)(1 )(B). Ifa source has both heatset web offset and eithernonheatset web offset orsheetfed lithographicprinting operations, or has all three types ofprinting operations, the owneror operatormay not make use ofthis alternative and must use the calculations in subsection (b)(I)(B). i) The sum ofall sheetfed and nonheatset web offset lithographic printing operations at the source:**242,3~** liters ({L4M gallons) ofcleaning solvent and fountain solution additives, combined; or 

### ii) The sum ofall heatset web offset lithographic printing operations at the source: 204.1+H4kg (4500.w lbs) ofink, cleaning solvent, and fountain solution additives, combined. 13, In response to a commentby industryrepresentatives, the Illinois EPA proposes amending Section 218/219.41 I(b)(I)(E) by removing the requirement that a source include in its notification to the lilinois EPA calculations showing an exceedance ofthe applicability threshold. Section 218.411(b)(l)(E): E) For sources complying with subsection (b)(l)(B) ofthis Section, notify the Agency in writing ifthe combined emissions ofVOM from all lithographicprinting lines (including 

### inks, fountain solutions, and solvents used for cleanup operations associated with the lithographicprinting lines) at the source everequal or exceed 6.8 kg/day (15 lbs/day), before the use ofcapture systems and control devices, within 30 days afterthe event occurs. Slleh Hetificatien shall ineiliae ealclllatiens )lllTSliaHl Ie Sestien 218.411 (ll)(1)(B) shewiBg !he aaily emissieBs eP/OM /Fern all litRegFaphic l'lRl1lil1g lines at the sellfGe 

### fer IRe mel1!h 

### in 

### ",,'!lich ernissieHs equaled eT el!eeedeEl 

### e.8 kWEla,' 

### (I j lllsfday). Ifsuch emissions ofVOM at the source equal or exceed 6.8 kg/day (15 Ibs/day) but do not exceed 45.5 kg/day (100 Ibs/day), the source shall comply with the requirements in subsection (b)(2) ofthis Section. Section 219.411(b)(1)(E): E) For sources complying with subsection (b)(I)(B) ofthis Section, notify the Agency in writing ifthe combined emissions ofVOM from all lithographic printing lines (including inks, fountain solutions, and solvents used for cleanup operations associated with the lithographic printing lines)

16

## Electronic Filing - Received, Clerk's Office, September 14, 2009

at the source ever equal or exceed 6.8 kg/day (15Ibs/day), before the use ofcapture systems and control devices, within 30 days after the event occurs. SUSfl notiHsatiofi sRaH insluEle ealsulatiofls Ilursuant to SestioR 219.411(1J)(I)(B) sRowifig tlJe Elaily emissions ofVOM ffom all litRogfapRie IlAfilifig hifles al 

### tlJe sOllrse for!fle mOHtlJ 

### iH wRieR emissiolls equaleEi or el(SeeEleEi e.8 k!Vday (15 Ills,lElay). Ifsuch emissions ofVOM at the source equal or exceed 6.8 kg/day (15Ibs/day) but do not exceed 45.5 kg/day (100 lbs/day), the source shall comply with the requirements in subsection (b)(2) ofthis Section. 14. In response to a comment by industryrepresentatives, the Illinois EPAproposes amending Section 21 8/219.411 (b)(2)(D) byremoving the requirement that a source include in its notification to the Illinois EPA calculations showing an exceedance ofthe applicability threshold. Section 218.411(b)(2)(D): D) Notify the Agency inwriting ifthe combined emissions ofVOM from all lithographic printing lines (including inks, fountain solutions, and solvents used for cleanup operations associated with the lithographic printing lines) at the source ever exceed 45.5 kg/day (100 lbs/day), before the use of capture systems and control devices, within 30 days after the event occurs. SllshHotifieatioll s1tall illslllEis salsldalioHs llursuaRllo Seslioo 218.411(1J)(2)(B) sflswiflg!fle Elaily efflissiollS ofVOM ffoffl all litlJograllRis printillg lines 

### attRe SOllree fer!fle mOlltlJ 

### in wRieR emissioHs sl(eeeEled 4551(WEl8J' (199 Ills,4iay). Section 219.411(b)(2)(D): D) Notify the Agencyin writing ifthe combined emissions ofVOMfrom all lithographic printing lines (including inks, fountain solutions, and solvents used for cleanup operations associated with the lithographic printing lines) at the source ever exceed 45.5 kg/day (100 Ibslday), before the use of capture systems and control devices, within 30 days after the event occurs. Sllsh Hotifisation shall illehlEle salsulatioHs Ilursuantto Sestion 219.411 (1l)(2)(B) sItowing the Elaily emissions ofVOM from all lithogrollrusllrinting lifles at the souree fer tile montl! in whieR emissiofls eJ[eeeEleEi 45.5 kWEloy (I 99 Ills/Elay). 15. In response to a request by industryrepresentatives, the Illinois EPAproposes amending Section 2181219.411 (t)(2)(B) and (t)(2)(C) by specifying that, for cleaning solutions used as17

## Electronic Filing - Received, Clerk's Office, September 14, 2009

purchased, sources may use manufacturer's specifications to determine VOM content and YOM composite partial vapor pressure. Section 

### 218.411 (j)(2)(B)(v), (j)(2)(C)(iii), and(j)(2)(C)(v): B) Foreach batch ofcleaning solution for which the owneror operatorrelies on the YOM contentto demonstrate compliancewith Section 2l8.407(a)(4)(A) ofthis Subpart, and which is not prepared at the source with automatic equipment:

v) The YOM content ofthe as-used cleaning solution, with supporting calculations. Forcleaning solutions that are used as purchased, the manufacturer's specifications for YOM contentmay be used ifsuch manufacturer's specifications are based on results

. oftests ofthe YOM content conducted in accordance with methods specified in Section 218.IOS(a) ofthis Part; 

### C) Foreach batch ofcleaning solution for which the owner or operator relies on the vaporpressure ofthe cleaning solution to demonstrate compliance with Section 218.407(a)(4)(B) ofthis Subpart:

iii) The molecularweight, density, and YOM composite partial vapor pressure ofeach cleaning solvent, as determined in accordance with Section 218.409(e) ofthis Subpart. Forcleaning solutions that areused as purchased, thc manufacturer's specifications for YOM composite partial vaporpressuremaybe used ifsuch manufacturer's specifications are based on results oftests conducted in accordance with methods specified in Sections 218.10S(a) and 218.110 ofthis Part; iv) The total amount ofeach cleaning solventused to prepare the asused cleaning solution; and v) The YOM composite partial vaporpressure ofeach as-used cleaning solution, as determined in accordance with Section 218.409(e) ofthis Subpart. For cleaning solutions that are used as purchased, the manufacturer's specifications for YOM composite partial vapor pressure maybeusedjfsuch manufacturer's specifications arebased on results oftests conducted in accordance with methods specified 

### in Sections 218.10S(a) and 218.1 JO ofthis Part; 18

## Electronic Filing - Received, Clerk's Office, September 14, 2009

Section 219.411(j)(2)(B)(v), (j)(2)(C)(iii), and (j)(2)(C)(v): B) Foreach batch ofcleaning solution for which the owner or operatorrelies on the 

### VOM content to demonstrate compliance with Section 219.407(a)(4)(A) ofthis Subpart, and which is not prepared at the source with automatic equipment:

v) The 

### YOM content ofthe as-used cleaning solution, with supporting calculations. Forcleaning solutions that are used as purchased, the manufacturer's specifications for 

### YOM contentmay be used ifsuch manufacturer's specifications are based on results oftests ofthe 

### YOM contentconducted in accordance with methods specified in Section 219.105(a) ofthis Part; C) Foreachbatch ofcleaning solution for which the owner oroperatorrelies on the vaporpressure ofthe cleaning solution to demonstrate compliance with Section 219.407(a)(4)(B) ofthis Subpart:

iii) The molecular weight, density, and 

### YOM composite partial vapor pressure ofeach cleaning solvent, as determined in accordance with Section 219.409(e) ofthis Subpart. Forcleaning solutions that are used as purchased, the manufacturer's specifications for 

### YOM compositepartial vaporpressure maybe used ifsuch manufacturer's specifications are based on results oftests conducted in accordance with methods specified in Sections 219.1 051a) and 219.110 ofthis Part; iv) The total amount ofeach cleaning solventused to prepare the 

### asused cleaning solution; and v) The

### YOM compositepartial vaporpressure ofeach as-used cleaning solution, 

### as determined in accordancewith Section 219.409(e) ofthis Subpart. Forcleaning solutions that are used as purchased, the manufacturer's specifications for 

### YOM composite partial vaporpressure may be used ifsuch manufacturer's specifications are based on results oftests conducted in accordance with methods specified in Sections 219.105Ia) and 219.110 ofthis Part;

19

## Electronic Filing - Received, Clerk'.s Office, September 14, 2009

16. 

### In response to arequestby industryrepresentatives, the Illinois EPA proposes amending

. Section 21 8/2I9.411 (g)(2)(A) to correctagrammarmistake. Section 

### 218/219411 (g)(2)(A)(ii): 

### ii) The amount ofcleaning materials used on lithographic printing lines atthe sourcethat does not comply with the cleaning material limitations in Section 218.407(a)(4) ofthis Subpart. 17. 

### Inresponse to a commentby industryrepresentatives, the Illinois EPAproposes amending Section 218/219.411 (g)(2)(B) byremoving therequirement that a sourceinclude in its notification to the Illinois EPA calculations showing an cxceedance ofthe applicability threshold. Section 218,41l(g)(2)(B): 

### B) Notify the Agency in writing ifthe combined emissions ofVOM from all lithographic printing lines (including inks, fountain solutions, and solvents used for cleanup operations associated with the lithographic printing lines)

. at the source everexceed 45.5 kg/day (100 lbs/day), beforethe use of capture systems and control devices, within 30days afterthe event occurs. SlIellnetifieatieR shall ineluee ealsulatiensPllfsuaRtte Seetien 218.411 EB)(2)(B) s!lewiRg the eaily emissions ef\laM ffem all litllegraphie pARting lines at tile SOIff6e for tile mentl! in ",lIliell emissieRs lllteeeeee 45.5**lE~ay** 

### (lGG Iss/eay). Section 219.411 (g)(2)(B): 

### B) Notifythe Agency in writing ifthe combined emissions ofVOM from all lithographic printing lines (including inks, fountain solutions, and solvents used for cleanup operations associated with the lithographicprinting lines) at the source everexceed 45.5 kg/day (100 lbs/day), before the use of capture systems and control devices, within 30days afterthe eventoccurs. S\loll Retifieation shall inel\lee ealsuletiens pUFSuaRtte Seetien 219.4IIEB)(2)(B) showing 1110 eaily emissioRS ef\lOM ffem all litllegrapmspriHting lines at tho sellfee for tile meRth iRwmell emissioRS eJweeeee 45.5 kg/eay (I 

### GG Issl6ay).

20

\

## ,

## Electronic Filing - Received, Clerk's Office, September 14, 2009

Letterpress Printing: 18. In response to arequestby industry representatives, the Illinois EPA proposes amending Section 2181219.415(a) and (c) by clarifyingwhen testingpursuant to such Section shall be performed. Section 218.415(a) and

### (c): a) Testing to demonstrate compliance with the requirements ofSection 218.413 ofthis Subpart shall be conducted by the owner oroperator within 90 days after a request by the Agcncy, or as otherwise specified in this Subpart. Suchtesting shall be conducted at the expense ofthe owner or operator, and the owner or operator shall notifY the Agency in writing 30 days in advance ofconducting such testing to allow the Agency to be presentduring such testing.

c) Testing to demonstrate compliance with the 

### VOM content limitations in Section 218.413(a)(2)(A) ofthis Subpart, and to determine the 

### VOM contentofcleaning solvents, cleaning SOlutions, and inks (pursuantto the requirements ofSection 218.417(b)(1)(B) ofthis Subpart), shall be conducted upon request ofthe Agency, or

### as otherwise specified in this Subpart. 

### as follows: Section 219.415(a) and 

### (c): a) Testing to demonstrate compliance with the requirements ofSection 219.413 ofthis Subpart shall be conductedby the owneroroperator within 90 days after a requestby the Agency, or 

### as otherwise specified in this Subpart. Such testing shall be conducted at the expense ofthe owner or operator, and the owneroroperator shall notify the Agency in writing 30 days in advance ofconducting such testing to allow the Agency to be present during such testing

.



### ........................................................... c) Testingto demonstrate compliance with the 

### YOM contenllimitations in Section 219.413(a)(2)(A) ofthis Subpart, and to determine the 

### YOM content ofcleaning solvents, cleaning solutions, and inks (pursuantto the requirements ofSection 219.417(b)(I)(B) ofthis Subpart), shall be conducted upon request ofthe Agency, oras otherwise specified in this Subpart. 

### as follows:

21

## Electronic Filing - Received, Clerk's Office, September 14, 2009

. 19. The Illinois EPA proposes amending Section 2181219.417(b)(1) by changing the material

use thresholds for letterpress printing lines. USEPApreviously recommended that material use thresholds for lithographic printing lines be conservativelybased on 50 percent ofthe pound per day applicability threshold. USEPA has now determined that a 90percent emission equivalency level is acceptable for both lithographic and letterpress printing operations. The following amendments reflect the 90 percent equivalency level for letterpress printing lines. Section 218/219.417(b)(l)(D)(l) and(b)(J)(D)(il): D) As an alternative to the calculations in subsection (b)(l)(B), above, a statementthat the source uses less than the amount ofmaterial specified in subsections (b)(I)(D)(i) or (b)(l)(D)(ii), below, as applicable, during each calendarmonth. A source may determine thatit emits below 6.8 kg/day (15 Ibs/day) of

### YOM based upon compliance with such material use limitations. lfthe source exceeds this amount ofmaterial use in a given calendarmonth, the owner or operatormust, within IS days ofthe end of that month, complete the emissions calculations ofsubsection (b)(l)(B) to determine daily emissions for applicabilitypurposes. Ifthe source ever exceeds this amount ofmaterial use for six consecutive calendarmonths, it is no longer eligible to use this subsection as an alternative to the calculations in subsection (b)(1)(B). 

### Ifa source has bothhcatset web and eithernonheatsetweb or sheetfed letterpressprinting operations, orhas all three types ofprinting operations, the owner or operatormay not make use ofthis alternative and must use the calculations in subsection (b)(l)(B). i) The sum ofall sheetfed and nonheatset web letterpress printing operations at the source: 242.3HH liters**(~** gallons) of cleaning solvent; or ii) The sum ofall heatset web letterpress printing operations at the source: 204.1 ++;l.,4kg**(45~** Ibs) ofink and cleaning solvent. 20. In response to a commentbyindustryrepresentatives, the J1Iinois EPAproposes amending Section 218/2 

### I 9.4 17(b)(2)by removing therequirementthat a source include in its notification to the JIlinois EPA calculations showingan exceedance ofthe applicability threshold. Section 218.417(b)(2): 22

## Electronic Filing - Received, Clerk's Office, September 14, 2009

2) For sources complying with subsection (b)(I)(B) ofthis Section, notify the Agency in writing ifthe combined emissions ofVOM from all letterpress printing lines (including inks and solvents used for cleanup operations associated with the letterpress printing lines) at the source ever equal or exceed 6.8 kg/day (I5Ibs/day), in the absence ofairpollution control equipment, within 

### 30 days after the event occurs. 8uea Iletifieatiell saall illeluee ealeulaRslls pursuant ts 8eetisIl21 g.417(bj(1 

### )(E) slls

.....illg tile eaiJy emissislls sf',10M Hsm allletteFJlressjlHlltillglilles at the sSlIree fur tlls mSlltll ill whieh emissislls eEjualee sr eJ£eeeeee e.g kglea,' (I § IbsltJayj. Section 219.417(b)(2): 2)

. For sources complying with subsection (b)(l)(B) ofthis Section, notify the Agencyin writing ifthe combined emissions ofYOM from all letterpress printing.Jines (including inks and solvents used for cleanup operations associated withthe letterpress printing lines) at the source ever equal or exceed 6.8 kg/day (I5 Ibslday), in the absence ofair pollution control equipment, within 

### 30 days after the event occnrs. 811eaHetifieatisll shall illeluee ealeulatiells pUFSllant te 8eetieIl219.417(b)(I)(Ej saewillg tile dail,' emissi8lls sfVOM lfsFIl allletteFJlressjlRlltillg lilles 

### at tile sellree fer the mSlltfl ill wl1ieh emissisHS eqllalee sr eJ£ceeeee e.g kl:1E1ay (15 lbs/Elay). 21. 

### In response to a comment by industry representatives, the illinois EPA proposes amending Section 2l8/2l9.4l7(e)(2)(B) and (e)(2)(C) by specifyingthat, for cleaning solutions used as-purchased, sources mayuse manufacturer's specifications to determine YOM content and YOM compositepartial vaporpressure. Section 218.417(e)(2)(B)(v), (e)(2)(C)(iii), and(e)(2)(C)(v): B) For each batch ofcleaning solution for which the owner or operator relies on the YOM contentto demonstrate compliancewith Section 2l8.413(a)(2)(A) ofthis Subpart, and which is not prepared at the source with automatic equipment:

v) The YOM content ofthe as-used cleaning solution, with supporting calculations. For cleaning solutions that are used as purchased, the manufacturer's specifications for YOM content 

### may be used ifsuch manufacturer's specifications are based on results

### 23

## Electronic Filing - Received, Clerk's Office, September 14, 2009

oftests ofthe 

### YOM content conducted in accordance with methods specified in Section 218.1 OSla) ofthis Part; C) Foreach batch ofcleaning solution for which the owner or operator relies on the vaporpressure ofthe cleaning solution to demonstrate compliance with Section 218.413(a)(2)(B) ofthis Subpart:

iii) The molecular weight, density, and 

### YOM compositepartial vapor pressure ofeach cleaning solvent, as determined in accordance with Section 218.41S(e) ofthis Subpart. Forcleaning solutions that are used as purchased, the manufacturer's specifications for 

### YOM compositepartial vaporpressure may be used ifsuch manufacturer's specifications are based on results oftests conducted in accordance with methods specified in Sections 218.10Sla) and 218.110 ofthis Part; iv) The total amount ofeach cleaning solvent used to prepare the asused cleaning solution; and v) The 

### YOM compositepartial vaporpressure ofeach as-used cleaning solution, as determined in accordance with Section 218.41S(e) ofthis Subpart. Forcleaning solutions that are used as purchased, the manufacturer's specifications for

### YOM composite partial vaporpressure may be used ifsuch manufacturer's specifications arebased on results oftests conducted in accordance with methods specified in Sections 218.1 OSla) and 218.110 ofthis Part; Section 2J9.4J7(e)(2)(B)(v). (e)(2)(C)(iii). and(e)(2)(C)(v): 

### B) Foreach batch ofcleaning solution for which the owner oroperatorrelies on the 

### YOM content to demonstrate compliance with Section 219.413(a)(2)(A) ofthis Subpart, andwhich is notprepared at the source with automatic equipment:

v) The 

### YOM content ofthe as-used cleaning solution, with supporting calculations. Forcleaning solutions that are used as purchased. the manufacturer's specifications for 

### YOM contentmay beused ifsuch manufacturer's specifications arebased on rcsults oftests ofthe 

### YOM contentconducted in accordance with methods specified in Section 219.1 OSla) ofthis Part;

24

## Electronic Filing - Received, Clerk's Office, September 14, 2009

C) For each batch ofcleaning solution for which the owneror operator relies on the vaporpressure ofthe cleaning solution to demonstrate compliance with Section 219.4I3(a)(2)(B) ofthis Subpart:

iii) The molecular weight, density, and YOM composite partial vapor pressure ofeach cleaning solvent, as determined in accordance with Section 219.4l5(e) ofthis Subpart. Forcleaning solutions that are used as purchased, the manufacturer's specifications for YOM composite partial vaporpressure maybeused ifsuch manufacturer's specifications are based on results oftests conducted in accordance with methods specified in Sections 219.105(a) and 219.110 ofthis Part; iv) The total amount ofeach cleaning solvent used to prepare the asused cleaning solution; and v) The YOM composite partial vaporpressure ofeach as-used cleaning solution, as determined in accordance with Section 219.415(e) ofthis Subpart. Forcleaning solutions that are used as purchased. the manufacturer's specifications for YOM composite partial vaporpressure may be used ifsuch manufacturer's specifications'are based on results oftests conducted in accordance with methods specified in Sections 219.105(a) and 219.110 ofthis Part; WHEREFORE, for thereasons set forth above, the lllinois EPA moves that the Board amend Parts 218 and 219 as set forth herein. Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By: 

## On 04

# "{d;/dJ~ DanaVetterhoffer Assistant Counsel Division ofLegal Counsel DATED: September 14,2009 1021 N, Grand Ave, East P.O. Box 19276 Springfield, 

### 1L 62794-9276 (217) 782-5544 25

## Electronic Filing - Received, Clerk's Office, September 14, 2009

BEFORETHE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP 

### II CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 21S, and 219 

### ) ) ) 

### ) ) ) ) 

### ) RIO-S (Rulemaking-Air)



### CERTIFICATE OF SERVICE I, the undersigned, an attorney, state that Ihave served electronically the attached TESTIMONTY OF DAVID BLOOMBERG and MOTION TO AMEND RULEMAKlNG PROPOSAL upon the following person: John Therriault, Assistant Clerk 1llinois Pollution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Illinois 60601-3218 and electronically to the following persons: 

### SEE 

### AUACHED SERVICE LIST.

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY By:

# c:zn M?-

# ikJJrr~~

. Dana VetterhoffuT Assistant Counsel Division ofLegal Counsel

DATED: September 14, 2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

### Electronic Filing - Received, Clerk's Office, September 14, 2009

Service List RI0-8

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 Illinois Department ofNatural Resources OneNatural Resources Way Springfield, 

### IL 62702-1271 virginia.yang@illinois.gov MatthewDwm, Chief Division ofEnvironmental Enforcement Office ofthe Attorney General 69 W. Washington St., Suite 1800 Chicago, 1L 60602 mdunn@atg.state.il.us

# A 6ILLINOIS POLLUTION CONTROL BOARD October 15, 2009 IN THE MATTER OF: ) ) REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATLE ) ORGANIC MATERIAL EMISIONS FROM ) GROUP II CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE 211,218, and 219 ) ORDER OF THE BOARD (by A.S. Moore): RIO-08 (Rulemaking

- Air)

On July 9, 2009, the Illinois Environmental Protection Agency (Agency) filed aproposal under the general rulemaking provisions ofSections 27, 28, and 28.2 ofthe Environmental Protection Act. See 415 ILCS 5/27, 28, 28.2 (2008). Among othermaterials, a Statement of Reasons (SR) accompanied the proposal. Generally, the Agency proposes to adopt airpollution regulations to control emissions of volatile organic material (VOM) for Group II Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above. Two Illinois areas, Chicago and St. Louis/Metro East, have been designated as moderate nonattainment areas for the 8-hour ozone standard. The Chicago nonattainment area includes the followingjurisdictions: 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. 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. Group II products include industrial cleaning solvents, flat wood panelin'g coatings, flexible packaging printing materials, lithographic printing materials, and letterpress printing materials. SR at 1,7-9. On September 14,2009, the Agency filed amotion to amend its rulemaking proposal (Mot.). The Agency proposes 20 amendments to the proposal, many ofthem stemming from a request or commentby industry representatives. E.g., Mot. at 4-5 (proposing to amend existing Sections 218.404 and 219.404). The Agency requests that the Board amend Parts 218 and 219 as set forth in its motion. Mot. at 1,25; see 35 

### Ill. Adm. Code 218,219. Section 101.500(d) ofthe Board's procedural rules provides in pertinentpart that, "[w]ithin 14 days after service ofa motion, aparty may file a response to the motion. Ifno response is filed, the party will be deemed to have waived objection to the granting ofthe motion, butthe waiver ofobjection does notbind the Board or the hearing officer in its disposition ofthe motion." 35111. Adm. Code 101.500(d). The Board has received no response to the Agency's motion to amend. Based on its review ofthe substance ofthe Agency's motion, and in the absence ofany response it, the Board grants the motion to amend the proposal.

### 2 The first hearing in this proceeding will take place as scheduled beginning on Tuesday, Octobcr 27, 2009, in Edwardsville. IT IS SO ORDERED. I, John T. Therriault, Assistant Clerk ofthc lllinois Pollution Control Board, certify that the Board adopted the above opinion and order on October 15, 2009, by a vote of5-0.

John T. Therriault, Assistant Clerk lllinois Pollution Control Board

# A 7( 1 2 

### ILLINOIS POLLUTION CONTROL BOARD

Keefe Reporting Company 1 

### RECORD OF HEARING October 27, 2009

Reported by Holly A. McCullough, C.S.R., C.C.R., R.P.R.

## "'~CIE: CLERK'S

# l~/~l~**a~T2** 92009 STArE 

### RIO- 8 POI/ution

# gF ILLINOIS 

### (Rulemaking

-

### ~P~Board IN THE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP II CONSUMER & 

### COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218 and 219. 3 4 5

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### 2 3 ILLINOIS POLLUTION CONTROL BOARD IN THE MATTER OF:

APPEARANCES: BOARD MEMBERS: Timothy 

### J. Fox, Hearing Officer Andrea S. Moore Anand Rao Shundar Lin For Illinois Environmental Protection Agency: Dana Vetterhoffer 1021 North Grand Avenue East 

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### 12 13 14 15 REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP II CONSUMER 

### & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 211, 218 and 219. R10-8 (Rulemaking

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### ( P. O. Box 19276 16 Springfield, IL 62794-9276 17 

### And David Bloomberg 18 INDEX OF EXHIBITS: 19 Exhibit No. 1

-- Page 7 20 (Exhibit No. 7 was marked for identification and retained by Mr. Fox.) 21 

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Keefe Reporting Company 2

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### 23 24 BE IT KNOWN that a record was made on October 27, 2009, at the Madison County Administration Building, before Holly A. McCullough, an Illinois Certified Shorthand Reporter, a Missouri Certified Court Reporter, a Registered Professional Reporter and a Notary Public. Also, it is stipulated and agreed that this record may be taken in stenotype by Holly A. McCullough and thereafter transcribed into typewriting.



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MR. FOX: Good morning and welcome to this Illinois Pollution Control Board hearing. My name is Tim Fox, and I'm the hearing officer for this ru1emaking proceeding, which is entitled "In the Matter of Reasonably Available Control Technology (RACT) For Volatile Organic Material Emissions From Group II Consumer and Commercial Products: Proposed Amendments to 35 Illinois Administrative Code Parts 211, 218 and 219." Also present from the Board are on my immediate left Board Member Andrea S. Moore, M-O-O-R-E, the lead Board Member for this rulemaking, and also present on my right is Anand Rao of the Board's technical staff.

Keefe Reporting Company 3

# A 8REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ILLINOIS POLLUTION CONTROL BOARD October 28, 2009 IN THE MATTER OF:

GROUP IT CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 21 1,218, AND 219 

### RlECE6VED CLERK'S OFFiCe



## OCT 2B2009 STATE OF ILLINOIS Pollution Control 

### Board 

# ORIGINAL RIO-8 (Rulemaking

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### Air) ) ) ) ) ORGANIC MATERIAL EMISSIONS FROM ) ) ) ) 

### HEARING OFFICER ORDER On July 9, 2009, the Illinois Environmental Protection Agency (Agency) filed aproposal to adopt airpollutionregulations controlling emission ofvolatile organic material from Group IT Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above. Group IT products include industrial cleaning solvents, flat woodpaneling coatings, flexible packaging printing materials, lithographic printing materials, and letterpress printing materials. In an orderdatedAugust 6, 2009, the Board among other actions accepted the proposal for hearing. In an orderdated August 12,2009, the hearing officer scheduled two hearings, the first beginning October 27,2009, in Edwardsville, and the secondbeginningDecember 8, 2009, in Chicago. The order also setdeadlines to pre-file testimony, questions, and answers for the first hearing. The order also specificallyprovided that "[p]re-filing deadlines for the secondhearing will be determined at a later date." The frrst hearing tookplace as scheduled on October27,2009, and the Boardexpects to receive the transcript ofthathearing by Friday, November 6, 2009. During the firsthearing, the hearing officer set deadlines to pre-file testimony and questions for the secondhearing. Pre-Filing Deadlines Participants who intend to testify at the secondhearing are urged to pre-file their testimony. Participants pre-filing testimony and any related exhibits are directed to do so no laterthan Tuesday, November 17; 2009. To expedite the secondhearing, participants are directed to pre-file questions based uponpre-filed testimonyno laterthan Thursday, December 3,2009. The "mailboxrule" at 35 

### III. Adm. Code 101.300(b)(2) does not apply to the filing ofany ofpre-filed testimony orpre-filed questions, and the Board's Clerkmustreceive these documents before the close ofbusiness on the specified dates. Although pre-filed testimony and pre-filed questions maybe filed electronicallythrough the Clerk's Office On-Line (COOL) from the Board's Web site at www.ipcb.state.il.us, all electronic or approved fax filings mustbe receivedby the Clerk's Office no laterthan 4:30 PM on the day ofthe applicable deadline. Any2 questions about electronic filing through COOL should be directed to the Clerk's Office at (312) 814-3629. Participants are directed to serve pre-filed testimony and pre-filed questions on the hearing officer and all persons on the Service List. Before filing pre-filed testimony orpre-filed questions or any other document with the Clerk, please check withthe hearing officerorthe Clerkto obtain themostrecent version ofthe Service List. Order ofSecond Hearing The hearing officerintends to begin the second hearing with pre-filedtestimony. All prefiled testimony will be entered into the record as ifread. See 35 

### III. Adm. Code 102.424(f). A briefsummary oftestimony will be allowed ifa witness wishes to provide one before responding to questions. Witnesses will then address anypre-filed questions. The hearing officerintends to allow any participantto ask follow-up questions and, after addressing pre-filed questions, to allowparticipants who have notpre-filed questions to ask them. Participants who do not pre-file testimony will be allowed to testifY as timepermits after the conclusion ofpre-filed testimony and questions based upon it. Consequently, anypersons wishing to testifY are urged to pre-file testimony in orderto ensure that theyhave an opportunity to testify. Any participantwho wishes to offer apublic comment at the secondhearing will be allowedto do so iftime permits atthe close oftestimony and questions based upon it. The Board's procedural rules also include an opportunityto file post-hearing comments. See 35 

### III. Adm. Code 102.108(b). The rules also provide that "[t]he Boardwill accept written comments from anyperson concerning theproposed regulations during the first notice period." 35 Ill. Adm. Code 102.604. IT IS SO ORDERED.

# ~~g~- Timothy

### J. Fox Hearing Officer Illinois Pollution Control Board 100 W. Randolph St., Suite 11-500 Chicago, Illinois 6060I 312-814-6085 foxt@ipcb.state.il.us