ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

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

JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601•(312)814-6026 

217/785-4140 

2171782-9143 (TDD) 

May 16, 2013 

Susan Hedman 

Regional Administrator 

PAT QUINN, GOVERNOR 

U. S. Environmental Protection Agency, Region 5 

77 West Jackson Boulevard (R-19J) 

Chicago, IL 60604-3507 

Re: State Implementation Plan Revision 

Dear Ms. Hedman: 

LiSA BONNETT, DIRECTOR 

Certified Mail 

Return Receipt Requested 

7010 2780 0002 1167 5942 

RECEIVED 

MAY 2 2 2013 

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

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

Agency ("Agency") submits the enclosed revision to the Illinois State Implementation Plan 

("SIP"). This revision has been prepared as a result of the Illinois Pollution Control Board 

("Board") granting variances to Midwest Generation, LLC- Waukegan Generating Station 

("Midwest Generation") and Ameren Energy Resources ("Ameren"), and the Agency is 

requesting that these variances be considered for approval individually and as a revision to the 

Illinois SIP. 

Specifically, on August 23, 2012, Midwest Generation was granted a variance from the 

provisions of the Illinois Combined Pollutant Standard ("CPS"), 35 Ill. Adm. Code 225.296(a)(l) 

and (c)(l), for the 12-month period beginning December 31, 2013, and ending December 31, 

2014, thereby allowing Midwest Generation an extra year to install pollution controls on Unit 7 

at its Waukegan Generating Station. Midwest Generation, LLC- Waukegan Generating Station 

v. Illinois Environmental Protection Agency, PCB 12-121. In addition, on September 20, 2012, 

Ameren was granted a variance from both the 2015 and 201 7 sulfur dioxide ("S02") emission 

rate provisions of the Illinois Multi-Pollutant Standard ("MPS"), 35 Ill. Adm. Code 225.233, for 

the electrical generating units in Ameren's MPS Group from the applicable requirements of35 

Ill. Adm. Code 225.233(e)(3)(C)(iii) for a period beginning January 1, 2015, through December 

31, 2019, and 35 Ill. Adm. Code 255.233(e)(3)(C)(iv) for a period beginning January 1, 2017, 

through December 31, 2019, subject to certain conditions. Ameren Energy Resources v.lllinois 

Environmental Protection Agency, PCB 12-126. 

As you know, the CPS, which includes Section 225.296(a) and (c), and the MPS, which includes 

Section 225.233(e), are approved rules of the Illinois SIP and were submitted to address the 

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

Rockford • 4302 N. Main St., Rockford, IL 61103 • (815) 987-7760 

Elgin • 595 S. State, Elgm, IL 60123 • (847) 608-3131 

Bureau Of Land- Peoria • 7620 N. University St., Peoria. IL 61614 • {309} 693-5464 

Collinsville • ,2009 Mall Street, Collinsville, IL 62234 • (618) 346-5120 

Des Plaines • 9511 Harrison St., Des Plaines, IL 60016 • (847) 294-4000 

Peoria • 5415 N University St., Peoria, IL 61614 • (309} 693-5463 

Champaign • 2125 S. First St., Champaign, \L 61820 • (217) 278-5800 

Marion • 2309 W. Main St., Suite 116, Marion, IL 62959 • (618) 993-7200 
Regional Haze Rule, as codified in 40 CFR § 51.308. See, 77 Fed. Reg. 39943 (July 6, 2012). 

Accordingly, since Midwest Generation and Ameren sought relief from provisions of the CPS 

and MPS and such relief was granted by the Board, the variances must be submitted for approval 

as a SIP revision addressing the visibility requirements under the CAA and the Regional Haze 

Rule. 

As evident from the approval of Illinois' Regional Haze plan, the CPS and MPS provide 

emission reductions well in excess of simply implementing Best Available Retrofit Technology 

("BART") on subject units. Taking into account the variances granted to Midwest Generation 

and Ameren, the reductions from Illinois' plan continue to provide significantly greater emission 

reductions for S02 than even very conservative defmitions of BART for the BART -subject units. 

See, Attachment 39, Agency Response, Tables 1 and 2, at pages 4 and 5. 

The Agency provided public notice of the SIP revision; however, no public hearing was held, 

because no request for a public hearing pursuant to the public notice was received by the 

Agency. Public connnents were submitted to the Agency pursuant to the public notice and such 

connnents are included herein with the Agency's response. 

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

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

Midwest Generation, LLC ~ Waukegan Generating Station v. Illinois Environmental Protection Agency 

Attachment 1) 

Attachment 2) 

Attachment 3) 

Attachment 4) 

Attachment 5) 

Attachment 6) 

Attachment 7) 

Attachment 8) 

Attachment 9) 

Attachment 1 0) 

Attachment II) 

Petition for Variance filed by Midwest Generation (April10, 2012) 

Hearing Officer Order (April30, 2012) 

Board Order (May 3, 2012) 

Filing of Additional Exhibit to Petition for Variance (May 4, 2012) 

Certification of Publication by the Agency (May 9, 2012) 

Hearing Officer Order (May 23, 2012) 

Reconnnendation of the Agency (May 25, 2012) 

Hearing Officer Order (May 30, 2012) 

Hearing Officer Order (August 9, 2012) 

Board Order Granting Variance (August 23, 2012) 

Certificate of Acceptance filed by Midwest Generation (August 27, 2012) 

Ameren Energy Resources v. Illinois Environmental Protection Agency 

Attachment 12) 

Attachment 13) 

Attachment 14) 

Attachment 15) 

Attachment 16) 

Attachment 1 7) 

Attachment 18) 

Attachment 19) 

Attachment 20) 

Attachment 21) 

Petition for Variance filed by Ameren (May 3, 2012) 

Certification of Publication by the Agency (May 22, 2012) 

Objection filed by Environmental [sic] Illinois, eta!. (May 31, 2012) 

Objection filed by Environment Illinois, eta!. (May 31, 2012) 

Board Order (June 7, 2012) 

Notice of Hearing (June 13, 2012) 

Hearing Officer Order (June 13, 2012) 

Waiver of Statutory Decision Deadline (June 18, 2012) 

Hearing Officer Order (Questions) (July 5, 2012) 

Hearing Officer Order (July 11, 2012) 
Attachment 22) 

Attachment 23) 

Attachment 24) 

Attachment 25) 

Attachment 26) 

Attachment 27) 

Attachment 28) 

Attachment 29) 

Attachment 30) 

Attachment 31) 

Attachment 32) 

Attachment 33) 

Attachment 34) 

Attachment 35) 

Attachment 3 6) 

Attachment 3 7) 

Attachment 38) 

Attachment 39) 

Recommendation of the Agency (July 23, 2012) 

Initial Comments ofthe Illinois Attorney General's Office (July 23, 2012) 

Appearance (July 24, 2012) 

Hearing Officer Order (Questions) (July 25, 2012) 

Responses to Board Questions filed by Ameren (July 30, 2012) 

Responses to Board Questions filed by Ameren (July 30, 2012) 

Hearing Transcript (August 1, 2012) 

Hearing Report (August 2, 2012) 

Comments ofEnviromnent Illinois, eta!. (August 10, 2012) 

Post-Hearing Comments of the Illinois Attorney General's Office (August 10, 2012) 

Post-Hearing Brief filed by Ameren (August 15, 2012) 

Post-Hearing Comments ofthe Agency (August 20, 2012) 

Post-Hearing Comment filed by Ameren (August 23, 2012) 

Board Order Granting Variances (September 20, 2012) 

Certificate of Acceptance filed by Ameren (October 30, 2012) 

Notice ofPublic Information, 36 Ill. Reg. 17938 (December 21, 2012) 

No Public Hearing Requested Verification (January 25, 2013) 

Agency Response to Comments Submitted by Sierra Club (February 13, 2013) and 

Connnents Submitted by Sierra Club (January 19, 2013) 

If further information is required, please contact Gina Roccaforte at 217/782-5544. 

Sincerely, 

~~ Director 

Attachments