:'.; :

J.

.•..'. No:rrcEQfPETlTIOSIlY CROWNIWE

,'.' .' 'Bofi:ji~figm ~:LfGil~~~t~Tltll:nD,' , ',;:CONtROL BOARD ,

"

.' CrQwnHne :~;Q~~l~. Inc., ·wh.~th, man~factur~s ·flb.~rglass

boa.~! at .itsJ~cmty: at 118841 Country Club, Ro~d.t·West

·'Frankfort, m)JJoi,:·62896,' ha' fileda petition with the

Illinois.. Pollution"Control,..B'oard~.for an.adjus'ted

standard ori December.5, 2003 (Board Docket Number

AS04·l) ,ee!dng an adjusted 'tandard from ·35: Ill.

Adm, tode§ 215.301 (Use of Organic Material.'

· otherwise known as the 8Iblhr'Rule). ·-Crownline 'proPoses. the following ad~usted standard applica~le" '10 its " fibergla.ss .boat' manufacturing · ope~~on.".:'purs\1ant :to, the authority "underJ Section .28;1 .of"'tne Env1ronin1mtal Protection Act;· the Board

herebY:l,ldopts' the fo'llowing ~djtisted standard. "This

adjusted 'standard shilll. apply' 'solely 10 'Crownline:

'Boots, mc:' ("Crow'ntile")." As: an {lltemative to'

compliance Wiol', 35 iIAC.§ 215.301, thi$,. pdjusted

., standar4.,.a1low~i',:~row.Ql~n~ to limil ,its·:;'~~~h.~8e of organic):m:At~rillr:inlo '-,t,he almosphere: from it~ boat

manuf~ciurlni~'operations by:,'co~plying ': with' the

National ,Emission Sfimdard' for' Hazardous '. ~ir

Pollutants for New and Existing, Boat, Manufacturing

Paciiitie', 'et forth at 40 CFR §63Subpar!·vv.VV,'a,

may bC amended in the futUJ¥,"'

Any .person m",y cause a:·public'..heari,:!g 10 -be h~ld in

the, above-described adjuslj:d standar.d proceeding by

filing "a hearing request .with :Ihe Illinois: Pollulion

Control Board within'; 2:( days after. ,the ,·dale" 'of

publication of this' notic~. The. hearing, request should

_:elearly: -indicate Ole,::dOcket .,·number Jor·~tht}':jl~.uP.t~d

'" standard'proceedinSi .... fquhd in thisnotice"'''''d;~»'t

'. hemailedtothe;.CI.••Ic1.~I•.t~e.BOai.d.lIiino\rFp.\ip~iln .Control Board;.I¢,W;.,Randolph""treekSu'te::H;~.OO. ,.~ 'Chicago"Illill0i~,',6<>60f. ," ,.'~ .. '~.,:' ;:;

>L~2~2,,12I!O; 1.#;17;12124 ';.

STATE OF ILLINOIS}C 'f" .. FRANKLIN COUNTY 55. ertl.lcate of PubhcatlOll : THIS CERTIFIES that the annexed is a true and exact printed .1

copy ofa Notice which was published 'once each week for

. --3 successive weeks in the DAILY AMERICANa Daily

Newspaper of general circulation published in the City of West

Frankfort, County of Franklin and State of Illinois. The Daily

American is

a newspaper as defined in Act--Chapter 100, Section.s

1 and5 Illinois Revised Statutes.

The first publication of the said n.otice appeared in the said

~Y AMERICAN in the issue b.earing the date of

/0 20~: and the last PublicatiC!n ofsaid

I n0:ti,e appeared in the issue of said paper bearing date of

,JR'I C<V'fuA• ofj 20 03

I hereby certify thatI am Ihe publisher of the Daily American.

and thatI make this certificate on behalfof saidl1e~spaper.

Dated at West Frankfort, Illinois

This /2

t 6Q- of ;/Oec./ 20 03'

DAlLY AMERICAN, Publisher ¥ n )

Pril1ter'sFee /o<';l, /0 By.J.()67U::::::....:..::::_

•

figzp

II'J
'EPA ATTACHMENT NO.

AS oLf-OV I . (Adjusted Standard - Ai~)

)

)

, )

, )

)

RECEIVED

CLERK'S OFFICE

BEFORE THE ILLINOIS POLLUTioN CONTROL BOA~ 22 2004

STATE OF ILUNOIS

pollution Control Board . IN THE MATTER OF:

PETITION OF CROWNLINEBOATS, INC.

FOR AN ADJUSTED FROM .

35 ILL. ADM. CODE 215.301

NOTICE

TO: Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11-500

.Chicago, lllinois 60601

Carol Sudman, Hearing Officer

Illinois Pollution Control Board

1021 N. Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

Dale Guariglia

Bryan Cave

One Metropolitan Square

211 North Broadway, Suite 3600

St. Louis, Missouri 63102-2750

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution

Control Board the RECOMMENDATION OF THE ILLINOIS EPA AND AN APPEARANCE

ofthe TIlinois Environmental Protection Agency, a copy ofwhich is herewith served upon you. . .

Date: January 20, 2004 ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

BY:~=","""S-::::-~--:-....p;.L:..--,'-7L--­ Charles E. Matoesi

Assistant Counsel

Division ofLegal Counsel

; .,

. 1021 North Grand Avenue East

P.O. Box 19276

Spring field, IL 62794-9276

217/782-5544

THIS FILING IS SUBMmED ON

RECYCLED PAPER
RECEIVED

CLERK'S OFFICE

JAN 222004

AS 04-{)01

(Adjusted Standard-Air)

BEFORE THE ILLINOIS POLLUTION CONTROL BOA.R5TATE OF ILLINOIS

Pollution Gontrol Board

W THE MATTER OF: )'

)

)

, )

, )

)

PETITION OF CROWNLlNE BOATS, INC.

FORAN ADmSTED STANDARD FROM

35 ILL. ADM. CODE215.301

RECOMMENDATION OF THE ILLINOIS EPA

The TIlinois Environmental Protection Agency (''Illinois EPA'') hereby submits its

recommendation in the above captioned matter pursuant to the regulations ofthe Pollution Co~trol

. Board ("Board'') at 35 m. Adm. Code Section 104.416. The llIinois EPA recommends that the

Board GRANT the petition ofCrownline Boats,Inc:, subject to the terms and C?nditions contained

in this recommendation. In support ofthis recommendation, the illinois EPA states as follows:

BACKGROUND

1. Crownline; Inc. ("Crownline'') filed its Petition for Adjusted Standard ("Petition'') on

December 4, 2003~:pursllant to Section 28.1 ofthe illinois Environmental Protection Act ("Act"),

415 ILCS 5/28.1, and the regulations ofthe Board at 35 TIl. Adm. Code Section 104.402. The

Petition requests that the Board grant Crownline an adjusted standard from 35 TIL Adm.' Code

.Section 215.301, the Use ofOrganicMaterial Rille, better known asthe "81blhrRule" as it appliesto

the emissions ofvolatile organic material ("VOM") from Crownline's WestFrankfort, minois, boat

manufacturing facility. The 8 Ib/hr Rule states:

No person shall cause or allow the discharge ofmore than 3.6 kglbr (8 Ibslhr) of .

organic material into the atmosphere from anyemissionsource, except as provided in

Sections 215.302, 215.303, 215.304 and the following exception:Ifno odornuisance

exists the limitation of this Subpart shall apply only to photochemically reactive

material. l
2, The Petition for Adjusted Standard stems from Crownline's request to use averaging to

comply with the 8 Ib/hr Rule for VOM as set forth in its application for Clean Air Act Permit

Program ("CAAPP") permit (no. 96030137) received by the IlIinois EPA on March 7, 1996. The

request was followed by several meetings between' the parties during which Crownline presented

evidence that it could not reasonably complywith the 8 Ib/hrRule on a strict hourly basis, and that

emissions averaging would result in no measurable negative impact on ambient air quality. (pet.

App. at 1). After reviewing the evidence, the lllinois EPA encouraged Crownline to file a Petition

for an Adjusted Standard. This Petition covers the Crownline ge1coat and lamination areas, plus

other boat manufacturing activities at the source.

3. On January 5, 2004, Crownline filed aProofofPublication ofNotice with the Board for this

Petition. The notice appeared in the West Frankfort Daily American on December 10, 17, and 24,

2003.

4. Pursuant to 35 Ill. Adm. Code Section 104.416, the illinois EPA is requiredto file aresponse

to a Petition for Adjusted Standard within 45 days offiling.

DESCRIPTION OF THE FACILITY

5. The Crownline facility is located inWest Frankfort, Hancock County, Illinois. (pet. App. at

4). Crowuline employs approximately 500-600 people in itsfacility and produces approximately 15

to 20 fiberglass boats per day. Id. The Illinois EPA accepts Crowuline's description ofits facility

and process and incorporates by'reference Section II. D ofthe current P·etition.

6. A new MACT standard for boat manufacturers becomes effective on August 23, 2004. 40

CPR Part 63, Subpart VVVV. Crownline is already in compliance with this new MACT standard.'

(pet. App. at 6). To complywith the MACT standard, Crownline replaced its air atomized guns with .

2

(
flow-coat guns in its lamination operation, introduced a lower Hazardous Air Pollutant ("HAP")

content resin (35% as compared to 42%), and switched to a gelcoat with a HAP content of33.4%:

, COMPLIANCE ALTERNATIVES

7. Crownline asserts in its Petition that its operations were not contemplated by the 8lb/hrRule, ,

which was established in 1971. ld. at 11, 12. CrO\vnline states that the "factors relating to boat

building" are "significantly different from most manufacturing operations which emit organic

material," and "emission data from boat building was not even available to the Board until after

1991." ld. Moreover, fiberglass boat production is a batch-type process involving the appljcati~n of

layers of "skins" to 'a boat frame. ld. Because materials are not applied continuously, but rather in

steps, YOM emissions are not constant and even. Crowcline states that emission controls are more

economically feasible where processes are continuous. ld.

8. Finally, Crownline asserts the requirements ofOSHA's worker protection regulation at 29

CFR 1910 prevent compliance with the 8lb/hrRule. ld. at 13. OSHA rulesrequire workplaces that

emit styrene to "maintainan in-plant work area atmosphere...ofless than 100 ppm." ld. Crownline

has thus installed a ventilation system "that exhausts approximately 654,000 cubic feet ofplant air

every minute." ld. Because of the enonnous rate of air transfer, Crownline asserts that add-on

emission controls are fiscally impractical. ld.. Crownline further assertsthattheBoardin 1971 could

not have possibly anticipated the promulgation ofthe OSHA rules. ld.

9. Crownline obtained the services ofAdvance Environmental Associates, LLC ("ABA"), to

assess the technical and economic feasibility ofcompliance aitematives. ld. at 6. The alternatives

considered were "(1) reducing YOM content inproduction materials; (2) using alternative operating

procedures and methods; and (3) installing end-of-the-pipe emission control technologies." ld.

3
Crownline claims that other than end-of-the-pipe emission controls, "many of the alternatives

investigated would not allow it to complywith the 81blhrRule on a strict hourlybasis." Id. Further,

Crownline declares that it could not ideptify any compliance alternatives to reduce YOM emissions

from the use ofadhesives, laquer and caulks. IeL .

10. Crownline contends that end-of-the-pipe emission controls are not economically feasible.

Crownline estimates up-front capital costs at $7 to$14 million with annualized costs ranging from

$4.5 million to $6 million, and a cost per ton ofVOM removed of$35,000 to $58,000. Id. at 8.

Crownline explains these figures in Section 4.3 ofthe Technical Document in Support ofa Pet!tion

By Crownline Boats, Inc. for an Adjusted Standard ("Technical Document") appended to the

Petition. Id. In Crownline's estimation, the main reason for these high costsisthe ventilation system

required by the OSHA regulations. Id. Lastly, as Crownline notes, when developing the MACT

standard, one of the factors the United States Environmental Protection Agency ("USEPA")

considered was that with one partial exception, no boat manufacturer uses tailstack emission control

technologies to reduce HAP emissions. Id. at 7.

11. Crownline also investigated alternative production methods which could result in reduced

VOM emissions. These included "open moulding" methods such as using "rollers' for resin

application, pre-preg materials, in.house resin impregnation, and vacuum bagging." Id. at 6, 7.

"Closed moulding" methods included "resin transfer molding, resin infusion, and .the patented

Virtual Engineered Composites ("VEC") technology." Id. at 7. Crownline states that these

altematives were all found to be technologically or economically impractical and explains its

reasoning in Section 4.2 ofthe Technical Document. rd.

12. Crownline has already reduced YOM concentration in its production materials in order to .

4
comply with the forthcoming MACT standard. Id. Compliance with the MACT does not yield

compliancewith the 8 Iblhr Rule.· Crownline states that reduction ofstyrene in the resins, beyond

that required by the MACT, is not technically feasible while maintaining product integrity. Id.

PROPOSED ADJUSTED STANDARD

13. Crownline has requested an Adjusted Standard from the Board's air pollution control

requirements found at 35 Ill. Adm. Code Section 215.301, insofar as that regulation applies to the

YOM emissions from Crownline's production facility in West Frankfort, lllinois. The illinois EPA

recommends that the Board GRANT Crownline's petition, and requests that the Board a!low

Crownline to operate its boat production facility so long as it complies with the following conditions:

a Crownline shall operate in full compliance with theNationalEITI!ssion Standardsfor

Hazardous Air Pollutants for New and Existing Boat Manufacturing Facilities, set forth at 40 CFR

Section 63 Subpart VVVV, as may be amended in the future.

b. Operation in full compliance with the National Emission Standard for Hazardous Air

Pollutants for New.and Existing Boat Manufacturing Facilities, set forth at 40 CFR Section 63 - . . .

SubpartVVVV, asmay be amended in the future, shall be in lieu ofcompliance withthe 81blhrRule

found at 35 TIl. Adm. Code Section 215.301.

c. Crownline shall continue to investigate boat production methods with a reduced

YOM content and, where practicable, shall substitute current coatings with lower YOM content

coatings as long as such substitution does not result in a net increase inVOM emissions. Crownline

shall be required to do any test which the illinois EPA speci.6.caIly recommends that they do. An

armual report summarizing the activities and results ofthese investigatory efforts shall be prepared .

by Crownline and submitted to the lllinois EPA Bureau of Air, Compliance and Enforcement

5

it
·.

Section.

d.. The reliefgranted in this proceeding shall be limited to the emission activities at the

Crownline West Frankfort facility as ofthe date ofthis filing.

e. Crownline shall operate in full compliance with the Clean Air Act, its CAAPP, the

lllinois Environmental Protection Act and other applicable regulations not otherwise discussed

herein.

ENVIRON1l1ENTAL IMPACT

14. Crownline estimates that at its current production rate of 15 to 20 boats per day, its fac.ility

will emit approximately 200 tons/yr ofVOM ifit complies with the forthcoming MACT. Id.at 10.

Compliance with the 8 lb/hr Rule would yield an expected 144 tons ofVOM ba~ed upon estimated

2003 production data. Id. Compliance with neitherthe MACT nor the 8 1b/hrRule would yield an

estimated 245 tons/yr ofVOM emissions for similar production figures. Id.·

15. ABA prepared an Ambient Air QualityImpact Analysis which estimatedCrowuline;s impact

on ozone formatio)) in south central illinois. Id. at 9. Discussed iIi detail in Section 5 of the

Technical Document, the analysis showed that the potential impact from Cromwell's operations

would not cause an ozone concentration at the nearest monitor (Dale, lllinois-25 miles distant) in

excess ofthe NAAQS of0.12 ppm. Id. at 9,10. The illinois EPA does not dispute this analysis.

16. In addition, Crownline presents a valid pointwhen itstates that ifit could somehow capture

YOM emissions and release them uniformly, rather than in bursts, it could complywith the 8 Th/hr

Rule while not reducing emissions at all. Id. at 10.

17. Crownline asserts that no cross-media impact is expected from the granting ofthe adjusted

standard. Id. at 11.

6
18. .Considered together, the batch process nature of the business which produces YOM

emissions in spurts, the fact that the Section 215.301 rule did not anticipate an operation like

Crownline's, compliance with the forthcoming MACT standard a year early, and the high cost of

add-on control technology due in part to OSHA' requirements, favor an adjusted ~tandard for,

Crownline.

STANDARD OF REVIEW

19. Section 28.1 of the Act states that the Board may grant individual adjusted standards from

rules of general applicability whenever the Board determines that an applicant can justif'y an

adjustment. In adopting a rule of general applicability, the Board may specif'y the 'level of

justification required ofa petitioner for an adjusted standard. Ifa rule ofgeneraJ applicability does

not contain a level ofjustification that the petitioner must meet to obtain an adjusted standard, the

requirements ofSection 28.1 (c) ofthe Act apply. Section 28.1 (c) states that the Board may grant

individual adjusted standards whenever the Board determines that:

(l) -.

(2)

(3)

(4)

Factors relating to that petitioner are substantially and sufficiently different

from the factors relied upon by the Board in adopting the general regulations -

applicable to that petitioner;

The existence ofthose factors justifies an adjusted standard;

The requested standard will not result in enviromnental or health effects

substantially and sufficientlymore adverse than the effectsconsideredbytheBoard in adopting the nile ofgeneral applicability; and

The adjusted standard is consistent with any applicable federal law.

20. The ~egulationofgeneral applicability from which CrciWIiline seeks an adjusted standard, 35

llI. Adm. Code Section215.301, does not specif'ya level ofjustification that Crownlinemustsatisf'y

to obtain an adjusted standard. Therefore, Crownline must satisf'y the level ofjustification set forth

7
in Section 28.l(c) of the Act. As summarized below, the requested adjusted standard for

Crownline's boat production operations is justified.

21. The illinois EPA agrees with Crownline's.analysis of the justification for its proposed ,

Adjusted Standard as set forth in Sectionn.Bofthe Petition, and hereby incorporates tliatsection by,

reference. The 8 lblhr Rule at Section 215.301 simply did not anticipate the type of operation

Crownline maintains. Unlike many other manufacturers, Crownline emits YOM in spurts as it

applies a "skin" to the boat frame. What is more, reasonable alternative emission control'

technologies either do not result in compliance with the 8 lblhr Rule or are prohibitively expe~ive

due in no small part to the OSHA requirement for continual ventilation.

CONSISTENCY WITH FEDERAL LAW

22. The Board may grant the proposed adjusted standard consistent with federal law under

Section '1 10 ofthe Clean Air Act, 42 U.S.C. Section 7410, which grants the individual states the

authority to promulgate aplan for the implementation, maintenance, and enforcement ofair quality

standards, subject to approval by USEPA. Pursuant to federal law, st~tes also have the authority to

revise such a plan, subject to USEPA approval. By following its adjusted standard procedure with

respect to the Board's federally authorized and approved air emission regulations, the Board is

exercising the authority granted to the states through Section 110 of the Clean Air Act. Ifthe

requested adjusted standard is adopted by the Board, illinois EPA has the authority and will submit

the adjusted standard to USEPA as a SIP revision, thus complying with federal law.

HEARING

23. Crownline has requested a hearing before the Pollution Control Board.

8
WHEREFORE, the Illinois EPA recommends that Crownline's Petition for Adjusted

Standard be GRANTED, and an order be entered adopting the adjusted standard with the specific

langJIage presented in this Recommendation.

Respectfully submitted,

Dated:

1020 North Grand Avenue East

P.O. Box 19276

Springfield, lllinois 627949276

(217)782-5544

(217)782-9807 Facsimile

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By'.:::;·~==----"'=''''7-''<:­ Charles E. Mato

Assistant Counsel

Division ofLegal Counsel

9

iI

:I

,I

I
RECEIVED

CLERK'S OFFICE

JAN 222004

AS O+--oo[

(Adjusted Standard - Air)

BEFORE THE ILLINOIS POLLUTION CONTRrS1iI~~ILLINOIS . ''P6! ution Control Board

INTHEMAITEROF: )

)

)

, )

, )

PETITION OF CROWNLINE BOATS, INC.

FOR AN ADJUSTED STANDARD FROM

35 ILL. ADM. CODE 215.301

APPEARANCE

I hereby file my Appearance in this proceeding, on behalf of the Illinois Environmental

Protection Agency.

Charles E. Matoesian

Assistant Counsel

Division ofLegal Counsel

DATED: January 20, 2004

ILLINOIS ENVIRONMENTAL PROTECTION

AGENCY

1021 North Grand Avenue East

P.O. Box 19276

Springfield, illinois 62794-9276

217/782-5544

THIS FILING IS SUBMITTED

ON RECYCLED PAPER
STATE OF ILLINOIS )

) SS.

COUNTY OF SANGAMON )

PROOF OF SERVICE ,

I, the undersigned, on oath state that I have seIVed the attached Recommendation ofthe

Illinois EPA lind an ApjJearance upon the person to whom.it is directed, by placing it in an

envelope addressed to:

TO: Dorothy dunn, Clerk

llIinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11·500

Chicago, llIinois 60601

Dale Guariglia

One Metropolitan Square

211 North Broadway, Suite 3600

St. Louis Missouri 63102-2750

Carol Sudman, Hearing Officer

illinois Pollution Control Board

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, llIinois 62794~9276

and mailing it by First Class Mail from Springfield, illinois on January 20,2004, with sufficient

postage affixed.

SUBSCRIBED AND SWORN TO BEFORE ME

this 20th day ofJanuary, 2004

t--:·o:··:··:··:··:··:··:··:·,y·;··;··:··:· ~:..:..:..:..:..:..:..:..:..:..:-:.

S· OFFICIAL SEAL . :i: ~: BRENDA BOEHNEr. :;.

:,: NOTARY PUBUC. STATE OF ILLINOIS .;-

~:MY COMMISSION EXPIRE. 1)-14-2005:; ':":":":":":":":":":":":":":"~""""'" ..:..:..:..:~'
L

IEPA ATTACHMENT NO.J

ILLINOIS POLLUTION CONTROL BOARD

February 5, 2004

IN THE MATTER OF: )

)

PETITION OF CROWNLINE BOATS, INC. )

FOR AN ADJUSTED STANDARD FROM ),

35 ILL. ADM. CODE 215.301 )

ORDER OF THE BOARD (by N.J. Melas):

AS 04-01

(Adjusted Standard)

On December 5, 2003, Crownline Boats, Inc. (Crownline) filed a petition for an adjusted

standard from 35 Ill. Adm. Code 215.301, commonly known as the "8Ib/hr Rule," as that Board

regulation pertains to the emissions of volatile organic material (VOM) at CrownIine's West

Frankfort, Illinois boat manufacturing facility. Crownline's facility is located at 11884 Country

Club Road, West Frankfort, Franklin County. In the petition, CrownIine requests a hearing in

this matter. The Illinois Environmental Protection Agency (Agency) filed a recommendation

that the Board grant CrownIine's petition on January 22, 2004. As discussed below, the Board

accepts CrownIine's petition for hearing.

Accompanying the petition, CrownIine filed a motion for expedited review in this matter.

Crownline asserts that the Agency recently issued CrownIine a Title V CAAPP Permit and Title

I Permit, requiring CrownIine either to obtain an adjusted standard from 35 Ill. Adm. Code

215.301 or demonstrate compliance with that section by December 31, 2004. The Board grants

CrownIine's motion for expedited review.

Also on December 5, 2003, Dale A. Guariglia filed a motion requesting permission to

appear pro hac vice on behalf of petitioner in this proceeding in accordance with Section

101.400(a)(3). 35·m. Adm. Code 101.400(a)(3). Mr. Guariglia is a member in good standing.

and admitted to practice in the State ofMissouri. The Board grants Mr. Guariglia's motion to

appear pro hac vice.

Section 28.1 ofthe Environmental Protection Act (Act) (415 ILCS 5/28.1 (2002» imd 35

Ill. Adm. Code 104.408 require publication of a notice of an adjusted standard proceeding in a

newspaper of general circulation in the area affected by the petitioner's activity. The notice must

be published within 14 days offiling a petition for an adjusted standard with the Board. See 35

Ill. Adm. Code 104.408(a). As required by 35 Ill. Adm. Code 104.410, CrownIine timely filed a

certificate ofpublication with the Board, postmarked December 30,2003, indicating that notice

ofthe petition was published in the West Frankfort Daily American on December 10, 17, and 24,

2003.

The Board finds that the notice meets the requirements of Section 28.1 ofthe Act and

Section 104.408 ofthe Board's procedural rules. The Board also finds the petition meets the

petition content requirements ofthe Board's procedural rules, and accepts this matter for hearing.

See 35 Ill. Adm. Code 104.406. A hearing is to be scheduled and completed in a timely manner.

The assigned hearing officer must inform the Clerk ofthe Board ofthe time and location ofthe
2

hearing at least 40 days in advance ofhearing so that a 30-day public notice of hearing may be

published.

CONCLUSION

The Board grants Crownline's motion for expedited review, grants Mr. Guariglia's

motion to appear pro hac vice, and accepts Crownli,ne's petition for hearing.

IT IS SO ORDERED.

I, Dorothy M. Gunn, Clerk ofthe Illinois Pollution Control Board, certifY that the Board

adopted the above order on February 5, 2004, by a vote of 4-0.

d1"7AL

Dorothy M. Gunn, Clerk

Illinois Pollution Control Board
IEPA ATTACHMENT ~o, 5 '

17'···...,. "." -::. :~

Ci_;2:-;'i{;I.:t, Vj~r';IC:'::

ILLINOIS POLLUTION CO!\TROL BOARD

February 6, 2004

IN THE MATTER OF: . )

)

PETITION OF CROWLINE BOATS, INC, )

FOR AN ADJUSTED STMillARD FROM 35) ,

ILL. ADM. CODE 215.301 ) ,

AS 04-01

(Adjusted Standard)

FEB 6 2004

STATE OF ILLINOIS

Pollution Control Board

HEARING OFFICER ORDER

The parties are advised that this matter has been assigned to the hearing officer identified

below, From this date forward, any pleading filed with the Clerk ofthe Board in this matter

must also be served individually on the hearing officer.

The parties are directed to participate in a telephone status conference with the hearing

officer at 9:30 a.m, on February 17, 2004, The telephone status conference will be initiated

by the complainant. The parties shall be prepared to discuss the status of this matter.

IT IS SO ORDERED,

Carol Sudman

Hearing Officer .

Illinois Pollution Control Board

1021 North Grand Ayenue East

P.O. Box 19274 .

Springfield, Illinois 62794-9274

217/524-8509

sudmanc@ipcb.state.il.us
2

CERTfFfCATE OF SERVICE

It is hereby certified that tme copies ofthe foregoing order were mailed, first class, to

each ofthe following on February 6,2004:

Dale A. Guariglia

Bryan Cave, LLP

One Metropolitan Square

211 North Broadway, Suite 3600

St. Louis, MO 63102-2750

Charles E. Matoesian, Assistant Counsel

IEPA, Division of Legal Counsel , .

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

It is her:eby certified that a true copy ofthe foregoing order was hand delivered to the

following on Febmary 6, 2004:

Dorothy M. Gunn

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph St., Ste. 11-500

Chicago, Illinois 60601

Carol Sudman

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509 .

sudmanc@ipcb.state.il.us
.' IEPA ATTACHMENT NO.Jz..-

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

PETITION OF CROWNLINE BOATS, INC.

FOR AN ADJUSTED FROM

35 ILL. ADM. CODE 215301

)

)

, )

, )

)

AS-2004-001

(Adjusted Standard - Air)

CROWNLINE BOATS, INC.'S RESPONSE TO RECOMMENDATION OF THE

ILLINOIS EPA

Crownline Boats, Inc. ("Crownline"), hereby submits.its Response to the Recommendation

of the Illinois Environmental Protection Agency ("IEPA") filed in this case on or aboutJanuary' 20,

2004. This Response is filed pursuant to the regulations ofthe Pollution Control Board ("Board'') ,

at 35 Ill. Adm, Code § 104-416.

The Recommendation filed by the IEPA reco=ended that the Board gtant Crownline's

Petition for an Adjusted Standard subject to certain tenns and conditions set forth in IEPA's

Recommendation, Although Crownline welcomes IEPA's recommendation that the Adjusted

Standard Petition be gtanted, Crownline objects to one of the tenns and conditions contained within

IEPA's Recommendation. In Paragtaph 13c ofIEPA's Recommendation, IEPA recommends that

the Board gtant Crownline's Petition with the condition that "Crownline shall be required to do any

test which the Illinois EPA specifically recommends that they do." This recommended condition is

vague and overly broad. The condition does not specify what type oftests IEPA may request

Crownline to conduct, the scope ofsuch tests, nor how often such tests can be requested.

Crownline opposes this broad authority \vithout limits, In an attempt to reach a resolution on this,

Crownline and IEPA have begun discussions regarding this recommendAMe tVeD

I ni\tlsion of ~enal Counsel working together in an effort to agtee upon compromise language. t Ts CroWiiline s hope that 'pnor

FEB 062004

Environmental Protection

Agency
to the expected hearing on its Adjusted Standard Petition, Crownline and IEPA will reach an

agreement as to the conditions which would be acceptable to both IEPA and Crownline.

WHEREFORE, Crownline requests that the Board grant Crownline's Petition for an

Adjusted Standard but without the condition allowu;g IEPA to require Crownline to perform tests.

Respectfully Submitted,

BRYAN CAVELLP

BY:~vZ~Y~~ D kAGuariglia, MO Bt:f3F . One Metropolitan Square .

211 North Broadway, Suite 3600

St. Louis, Missouri 63102

Tel. (314) 259-2000

Fax. (314) 259-2020

Attorneys for Crownline Boats, Inc.

1767309.1 2
STATE OF ILLINOIS )

) SS.

COUNTY OF SANGAMON )

PROOF OF SERVICE

,

I, the undersigned, on oath state that I have served the attached Response of C;rownline

Boats, Inc. upon the person to whom it is directed, by placing it in an envelope addressed to:

TO: .Dorothy Gunn, Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph Street, Suite 11-500

Chicago, Illi.llOis 60601

Charles E. Matoesian

Assistant Counsel

Division oftegal Counsel

Illinois Environmental Protection Agency

102 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Carol Sudman, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, Illinois 6279+-9276

and mailing it by First Cla~s Mail from St. Louis, Missouri on Februartf!-, 2004, with sufficient·

postage affixed.

Y1~f9% Dale A. Guariglia, Esq.

1767309.1 3
ILU;-';OIS POLLUTION CONTROL BOARD

February 17, 2004

IEPA ATTACHMENT:NO.l

RECEJVE!I:I

CLERK'S OFFICE

FEB 17 2004

STATE OF ILLINOIS

Pollution Control Board

IN THE MATTER OF: )

)

PETITION OF CRO\VLlNE BOATS. INC. )

FOR AN ADJUS"(ED STANDARD FROM 35 )

ILL. ADM. CODE 215.301 1

AS 04-01

(AdjLlsted Standard)

HEARING OFFICER ORDER

After several discussions this week, the hearing date was changed to April 23, 2004.

The parties are reminded to participate in a telephone status conference with the hearing

officer at 10:00 a.m. on April I, 2004. The telephone status conference will be initiated by the

complainant. The parties shall be prepared to discuss the status of this matter.

IT IS 50 ORDERED.

Carol 5udman

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois '62794-9274

217/524-8509

sudmanc@ipcb.state.il.us

~'"""'=';\!7= . .. .b~tb,~I)J~D DIvision of LpG'>' r"nl ...,..... 'V:...unsei

FEB 18 200~

Environmentai Protection'

Agency
CERTIFICATE OF SERVICE

It is hereby certified that true copies of the foregoing order were mailed, first class, to

each of the following on "February 17,2004:

Dale A. Guariglia

Bryan Cave, LLP

One Metropolitan Square

211 North Broadway, Suite 3600

St. Louis, MO 63102-2750

Charles E. Matoesian, Assistant Counsel

IEPA, Division of Legal Counsel

10:'21 North GrandAvenue East

P.O. Box 19276

Springfield, IL 62794-9276

It is hereby certified that a true copy of the foregoing order was hand delivered to the

following on February 17, 2004:

Dorothy lvl. Gunn

Illinois Pollution Control Board

James R. Thompson,Center

100 W. Randolph St., Ste. 11-500

Chicago, Illinois 60601

Carol Sudman

Hearing 0 fficer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

sudmanc@ipcb.state.il.lls
ILLINOIS POLLUTION COT\TROL BOARD

February 17,2004

IEPA ATTACHMENT NO:~

IAECEJVED

CLERK'S OF;=ICS

FEB j 7 200~

STATE OF ILLINOIS

Pollution Control Boarj

IN THE MATTER OF: )

)

PETITION OF CROWUNE BOATS, INC. )

FOR AN ADJUSTED STAi-mARD FROM 35 ), ILL. ADM. CODE 215.301 ),

AS 04-01

.(Adjusted Standard)

NOTICE OF HEARING

A hearing in the above-captioned matter is scheduled and will be held in accordance \\'itll .

the following schedule:

DATE:

TIME:

PLACE:

Friday, April 23, 2004

12:00 p.m.

City Hall Council Room

20 I E. Nolen Street

West Frankfort, Illinois

\

\

The hearing is open to the public.

IT IS SO ORDERED.

Carol Sudman

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

sudmanc@ipcb.state.iI.us

RlECE~Vf2:D Division of L0021Counsel

FEB 18 20C~

III ~·,~T'i"·!j':llL-: W,!J; til;: :\:,l\:ri;':<lI\' \'.jt!1 DISliliiiu,_, :\." .1', ';J: :I~~r:li~·~~::~~.~e~~,::~,il.r.~.l.~~~'t-:jtrnvi'tdnthe)ltat :P"(9t~9.~~9.n~':,,·,;· ·.,'il~\ d,~,.pi:!::~·\. p:,\(ln.' 1\:{ju:r:I:J; :lu:;ili:lf)" :,Id, ;1"/ .. ' ',' ·(t.,.....) .. ,,,_, C-,r,-..l/ ',).1,.11, t'L, .. " ,,,',_ ;., ·,-10. '. 11.'11 \)1,;, {'b ...... ,. - '\,

Sllit~: . ' )IJlJ. {:liic';I':", 1l!lIil~l,. {)~!(I( (l. ;\{ <.ch':i~i!, .r:-.: lr : : 2·... ·1 UH l. t;\\ Ilt;m:~f 3 i 2iS: -\.-J(,("I; ,'f ;! oJAgenay:Si -H(I)_~:. (i· -~ ;'.!. '

p.-illf t,- J.l:~' Il~',(ril(g.
2

CERTIFICATE OF SERVICE

It is hcrcby certified that true copies of the foregoing order wcrc mailed, first class, to

each of the folkm'ing on February 17,2004:

Dale A. Guariglia

Bryan Cave, LLP

One Metropolitan Square

211 North Broadway, Suite 3600

St. Louis, MO 63102-2750

Charles E. Matoesian. Assistant Counsel

lEPA, Division of Legal Counsel

1021 North Grand Avenue East·

P.O. Box 19276

Springfield, IL 62794-9276

It is hereby certified that a true copy ofthe foregoing order was hand delivered to the

following on Febnrary 17, 2004:

Dorothy [\1. Gunn

1I1inois Pollution Control Board

James R. ThompsonCenter

100 W. Randolph St., Ste. 11-500

Chicago, lIIinois 60601

Carol Sudman

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

sUdmanc@ipcb.state.il.us
IEPA ATTACHMENT NO.

RECEIVED

CLERK'S OFFICE

HEARING OFFICER ORDER

ILLINOIS POLLUTION CONTROL BOARD

April 6, 2004

IN THE MATTER OF: . )

)

PETITION OF CROWNLlNE BOATS, INC. )

FOR AN ADJUSTED STANDARD FROM 35)

ILL. ADM. CODE 215.301 . ) ,

AS 04-0 I

(Adjusted Standard)

APR - 62004

STATE OF ILLINOIS

Pollution Control Board

RECEIVED

Division of Legal Coun

APR U7 2004

Environmental Protec

On April 1, 2004, the parties participated in a telephone status conference with the Agency

hearing officer. To facilitate the Board's decision on this adjusted standard, petitioner should be

prepared to allswer the following questions at the hearing set for April 23, 2004.

AS 2004-1 Crownline Boat. Inc.

35 lAC 104.406 (e)

I. In the Fedenil Register, the United States Environrnental Protection Agency (USEPA)

estimates there are approximately I 19 existing facilities that \vill be subject to the Federal

mle 40 C.F.R. 63 Subpart VVVV. Annual compliance costs for all existing facilities

were estimated at $ 14 million. This included capital, materials, monitoring,

recordkeeping, and reporting costs (66 FR 44222). Petition at S notes that USEPA

estimates that complying with 40 C.F.R. Subpart VVVV will cost 54,060/ton of

Hazardous Air Pollutant (HAP) reduced/year.

USEPA also ~stimated the capital costs for new equipment:

• Resin Application Equipment (flowcoaters): $6000/unit

• Adhesive application Equipment: $6000/unit

• Resin and Gel Coat Mixer Covers: $ ISO/container

(66 FR 44222)

(a) Would you please quantify the costs Crownline has spent on replacing the

atomized spray guns with flow-coat guns and switching to a lower styrene resin~

Crownline has already made the change in:the lamination process. Does

Crownline consider switching to flow-coat guns in the gel coat process an

alternative as well?

(b) What other costs have Crownline incurred to meet the Federal mle?

(c) Has Crownline estimated the additional compliance costs associated with

monitoring, recordkeeping and reporting?
2

2. Petition at 2 (Pet. at 2) states, "Crownline took steps early to comply with the [Federal]

Maximum Achievable Control Technology (MACT) and came into compliance with the

MACT emission limits more that a year prior to the deadline." Pet. at 2. Furthur down

on that same page; the petition states that the costs to install tail-stack controls to comply

with the Slb/hr Rule would range from approximately 57 million to 514 million and that

"this equates to approximately 53),000 to 558,000 per ton of pollutant removed on top of

the costs Crownline \viI! have to incur to comply with the newly promulgated MACT

standard" (emphasis added). Pet. at 2. '

(a) Would you please clarify whether Crownline has already incurred costs to come

into compliance with the Federal standardry Ifso, what was the cost incurred to

comply with the Federal standard? Does Crownline expect to incur additional

costsry

(b) . Could you please calculate a total cost/ton HAP reduced/year that Crownline will

incur as a result of complying with 40 C.F.R. Subpart VVVV.

35 lAC 104.406 (f)

3. Petition at 2 states, "Crownline took steps early to comply with the MACT and came into

compliance with the MACT emission limits more than a year prior to the deadline." Pet.

at 2.

(a) Could you please indicate if Crownline has made a demonstration of compliance

with the new NESHAP regulations under 40 C.F.R. Part 64 Subpart VVVV to

USEPA yetry Did USEPA respond to the compliance'demonstration, and ifso,

howry

(b) Since Crownline is proposing replacing the I-hour a.veraging time under the 8

lb/hr rule, would you please describe over what time period emissions will be

averaged under 40 C.F.R. Subpart VVVV? Since the boat-building process takes

an av;rage of22 days, would it be technically feasible and economically:

reasonable to average emissions on a I-day, 7-day or 30-day rolling average

instead of a 12-month rolling average? Would this help to more closely monitor

the daily and seasonal impact ofthe emissions that the I-hour averaging required

under the S lb/hr rule?

4. Petition at 3 quotes the definition of "emission source" from 35 lAC 201.102 as "any

equipment or facility of a type capable of emitting spe.cified air contaminants to the

atmosphere." The Petition's Technical Document in Appendix 5 is a letter from·

Crownline's environmental consultant to lEPA seeking to resolve the issue of properly

defining the term "emission source" for purposes of applying the S lb/hr rule.

(a) Could you please explain how Crownline is regulated under 35 lAC 215.301 in

the context ofthe definition of "emission source." Is the whole facility regulated

as one source or do individual sources exist within the facility that are regulated
3

as separate sources? Could you please identify the indi vidual emission source(s)

at Crownline regulated under 35 lAC 215.301? Is each boat line or model line

considered an emission source~ Is the process of building each boat considered

an emission source? Is each spray gun considered an emission source~

(b) The lIlinois Environmental Protection Agency's (Agency) recommendation (1-

22-04) included one condition relating to testing which Crownline found vague

and overly broad. In Crown line's Response to the Recommendation ofthe

Agency, Crownline suggests the t,,:o parties might reach a compromise on this

language in time for hearing. Could you please provide an update on this?

35 lAC 104.406 (g)

5. The Technical Document prepared by Advance Environmental Associates (AEA) on

page 7 states, "Estimates of hourly Volative Organic Materials (VOM) emissions from

Crownline's gelcoat and lamination operations in compliance with the MACT are set

forth in Exhibit 4 ofAppendix 6." However, Exhibit 40f Appendix 6 seems to sho\y the

annual total emissions in tons per year (tpy) rather than estimates of the total emissions

onan hoqrly basis in pounds per hour (Ib/hr). Appendix 7 shows estimates of hourly

YOM emissions (lb/hr), but only from the caulking, adhesive and lacquer operations.

(a) Could you please provide data in a fomlat similar to Appendix 7 in Iblhr for the

gelcoat and lamination operations for the sake of comparison to the 8 Iblhr nIle~

(b) Appendix 8 ofthe Technical Document contains a table entitled "Crownline

Small Part Usage in Pounds of Material; MACT Compliance Scenario." Could

you please specify the units of measurement for each column in the table?

6. The Federal NESHAP regulations at 40 C.F.R. 63.5698 pro,YiCle a fom1Ula to calculate the

HAP emission limit based on a 12-month rolling average.

(a) Would you please identify Crownline's HAP Emission Limit per40 C.F.R.

63.5698 and show how Crownline calculated it.

7. Pet. at 2 references USEPA's discussion ofthe National Emissions Standards for

Hazardous Air Pollutants (NESHAP) for Boat Manufacturing in the Federal Register (66

FR 44222). Referring to the Federal Register discussion, USEPA provides the following

figures: :

• Existing facilities: 119

• -Rate of growth: 5 facilities/year for next 5 years

• 1997 baseline emissions: 9920 tpy

• NESHAP reductions: 3450 tpy

• % total reduction in HAP: 35%

• Total Annual Compliance Costs: $14 million

• Annual Costs: $4060 / ton HAP reduced
4

• Capital costs:

o Resin application equipment: $6000/unit

o Adhesive application equipment: $6000/unit

o Resin and gel coat mixer covers: $180/year/container

(66 FR 44222)

Based on these figures, the following aver~ges can be calculated:

• 1997 baseline emissions: 9920 tpy/l19 facilities = 83.4 tpy/tacility

• NESHAP emissions reductions: (9920-3450 tpy)/l19 facilities = 54.4 tpy/facility

• Annual Compliance Costs: $14 million I 119 facilities = $117,647 'facility

• % total reduction in HAP: 35%

(a) Could you please make a relative comparison ofCrownline's figures to the

averages calculated above:

1. How do Crownline's 2003 Pre-MACT emissions compare to the average

ofthe facilities as depicted above?

II. How do Crownline's proposed NESHAP emissions reductions compare to

the average of the facilities above?

111. How do Crownline's annual compliance costs compare with the average

ofthe facilities above?

IV. How does Crown1ine's annual cost ofreduced HAP compare to the

U,sEPA figure of $4060/ton?

v. Comparing the Pre-MACT Scenario to the MACT Siandard Compliance

Scenario presented as Exhibits 3 and 4 in Appendix 6 ofthe Technical

Document, would you please estimate the % reduction in total HAP

emissions. Comparing the Pre-MACT Scenario to the 8 lblhr Compliance

Scenario presented in Exhibits 3 and 5, would you please estimate the %

reduction in total HAP emissions. Would you please compare these

percentage reduction figures to the 35% overall figure that USEPA

estimated? Ifthe percentage reduction proposed by Crownline for this

adjusted standard is less than 35%, are there additional measures

Crownline could take to improve its reduction to more closely approach

the 35%? If you are familiar with other affected facilities in the boat

'manufacturing industry, could you please comment on how closely their

reductions approach USEPA's anticipated overall percent reduction of

35%?

(b) IfCrownline were to experience a growth in production, could you please

comment on how such growth would affect the YOM emissions:
5

I. Could you please estimate on an hourly and annual basis how potential

growth would affect YOM emissions in comparison to the data provided

for-the 2003 production year? For example, would Crownline add new

production lines? Increase hours/day of production" Build a new facility?

II. By estimating a larger figure to represent potential increased YOM

emissions 5 to 10 years in t'he future, how would the Ozone Impact

Analysis conducted by AEA change in showing an exceedence at the loc,al

air monitor? .

Ill. Would such potential increased YOM emissions from Crownline's

operations require the Agency to return to USEPA for another State

Implementation Plan revision?

IT IS SO ORDERED.

Carol Sudman

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, IIIinois 62794-9274

217/524-8509

sUdmanc@ipcb.state.il.us
6

CERTIFICATE OF SERVICE

It is hereby certified that true copies of the foregoing order were mailed, first class, on

April 6, 2004, to each ofthe persons on the attached service list.

It is hereby certified that a true copy of the foregoing order was hand d,elivered to the

following on April 6, 2004: ' '

Dorothy M, GUM

Illinois Pollution Control Board

James K Thompson Center

100 W. Randolph St., Ste. II-SOD

Chicago, Illinois 6060 I

Carol Sudman

Hearing Officer

Illinois Pollution Control Board

1021.:North Grand Avenue East

P.O, Box 19274

Springfield, Illi110is 62794-9274

217/524-8509

sudmanc@ipcb,state,il.us
. [PCB servicelabels.asp

AS 2004-001

•

IEPA

1021 North Grand Avenue East, P.O. Box

19276

Springfield, IL 62794-9276

AS 2004-001

Dale A. Guariglia

Bryan Cave, LLP

One Metropolitan Square, 211 North

Broadway, Suite 3600

St. Louis, MO 63102-2750

AS 2004-001

Charles E. Matoesian

IEPA

1021 North Grand Avenue East, P.O. Box

19276

Springfield, IL 62794-9276

Page rof 1
"

IEPA ATTACHMENT NO..JQ.

RECEIVED

CLECiK'S OFFICE.

ILLINOIS POLLUTION CONTROL BOARD

April 26, 2004

IN THE MATTER OF: )

)

PETITION OF CROWNLINE BOATS, INC. )

FOR AN ADJUSTED STANDARD FROM 35 ) , ILL. ADM. CODE 215.301 ) ,

AS 04-01.

(Adjusted Standard)

• ;""\1 ,lORIt.0,... 2004

STATE OF ILLINOIS

Pollution Control Board

HEARING REPORT

On April 23, 2004, a hearing in this matter was held at City Hall in West Frankfort,

Franklin, County. Attorney Dale Guariglia appeared on behalfofthe petitioner. Attorney

Charles Matosian appeared on behalf ofthe Illinois Environmental Protection Agency.

Witness Credibilitv

Three witnesses testified during the hearing:

Mr. James Claxton

Mr. Dale Guariglia

Mr. Andrew Polcyn

Based upon my legal judgment, experience, and observations at hearing, I find that the

. credibility ofwitness is not an issue in this'matter.

Exhibits

• >

The petitioner offered 8 exhibits as evidence at hearing. An exhibit list itemizing the

offered exhibits and summarizing their status is attached to this order.

Briefing Schedule

The complete transcript is due May 5,2004, and the public comment deadline is

May 20, 2004. The parties briefs are due May 14, 2004. The mailbox rule will apply.

IT IS SO ORDERED.

RECEIVED

DiVisIon of Legal Counsel

APR 27 200li

environmental Protection

Agency
2

Carol Sudman

Hearing Officer

Illil10is Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

sudmanc(@'ipcb.state.il.us
.'

AS 04-1

3

Exhibit List

Exhibit Description Status

Petitioner's Exhibit #1 Responses to Board questions in hearing Admitted

officer order dated April 6, 2004

Petitioner's Exhibit #2 Comparison ofVOM emissions vs. Ozone Admitted'

impact

Petitioner's Exhibit #3 Outline of petitioner's presentation Admitted

Petitioner's Exhibits #4-8 Demonstrative photographs of petitioner's Admitted

operations
4

CERTIFICATE OF SERVICE

It is hereby certified that true copies ofthe foregoing order were mailed, first class, on

April 26, 2004, to each ofthe persons on the attached service list.

. It is hereby certified that a true copy ofthe foregoing order was hand delivered to the

following on April 26, 2004:'

Dorothy M. Guim

Illinois Pollution Control Board

James R. Thompson Center

100 W. Randolph St., Ste. 11-500

Chicago, Illinois 6060 I

Carol Sudrnan

Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

217/524-8509

sudmanc@ipcb.state.iLus
Page I of 1

~'inrnr~-ir£~

Stat Declsloo Due:

Charles' E;'Ma(oesl,,-n;AsslstantCounsel,'

314/259-2000

314/259-2020

Case Name: In the Hati:er of: P~titlon of Crownlln..:: BO:its, Inc. rOr an

AdJust<ed "Standud from 35 lAC Section 215.301

Board Members: t-1e!,3s, N.J.;

Hearing Officers: Sudman, C.;

Status Report Track

•

l

One Metropolitan Square St. Louis

211 North Broadway, Suite MO 63102-2750

13600

case No: AS ~004-001

Case Tyoe: AajUSt.e-d Standard

MedIa Type: Air

Fr<!nklln

Date FlIgd: 1215/2003

Bryan Cave, LlP

Petitioner

Dale A. Guariglia