# A 14

# 0, --- --------



# Mostardi Platt
c. .c,"!('!'(/xo:-nff.C"!i..4t



# ---_.

Januury 15. 20 J ()



### John ThclTiilult Clerk Illinois Pollution ('ontrol Board I Of) W. 

### Randolph 

### SI.. SIC. I 1-500 

### Chicago. IL 6060 I ,520 Kensington Road. Sllile 204 Qar. SrilOk, IllrnOis 60523-2139 Phone 630-993·2'i,00

fa< 630·993·901 i www.mGstardiplatUmv.com 

### ReceiVED

CLERK'S 

### OFFICE



### JAN 

## I 3 2010

STATE OF 

### ILLINOIS 

### Pol/uto" Control Board

Alln: RI0-8 Rulemaking Air: Litho!!n\phie I'rioting .Rules

To whom it Illay concern.

I wish 10 

### withdrnw Illy recenlly subrnittcd commenls 10 

### the Illinois I'ollulion Cootrol Board (IPCB) rcgarding proposed changes 10 

### the Reasonably Available Control Technology m!\CTl fiJI' 

### Volatile Organic \-1"leri,,1 Fmissions Standards.

rVly 

### comJllents were h(1Scd on regulations listcd on the Illinois Em'ironmcntal I'rOlcctioll Agency ( IEPA) website. !\ 

### itcr rcviewing thc WeB docket. including amcnded filings incorporating the most recent IEI'Aehanges, I bcliCl'll Ihai thc rules. as eUiTclllly written.

nrc not umbiguDus with regurd 10 

### the Ikatsct Liihogmplric Printing eonlrnl (Ieviee requirements. Therciore I wi,h 10 

### wiHldnll\' 111V 

### comll1enls to the IPCB dnicd December 

## n, 2009.

IrYOll have cll1yqucslions regarding this wilhdrawdl requcsL please fcelli"cc 10 t:onlLlcl 111(' al «J30) 993-2138 or hy 

### e-mail at**jml~'I.·n_I1_:I_n_~m.!)ih!filipL.lll~Jl~:£.~lnL** 

### Thank YOl!o



# .s i Il(;('rc :
.

# A 15

### i 

# Volume 34, Issue 6 February 5, 2010 Pages 1762

-2371

### ILLINOIS REGISTER 1766 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

1) Heading of the Part: Definitions and General Provisions

2) Code Citation: 35 Ill. Adm. Code 211

3) Section Numbers: Proposed Action: 211.1000 New 211.1745 New 211.1878 New 211.1885 Amend 211.2355 New 211.2356 New 211.2368 New 211.2615 New 211.2830 Amend 211.2855 New 211.2965 New 211.3215 New 211.3305 New 211.3555 New 211.3705 New 211.3707 New 211.4065 Amend 211.5335 New 211.5535 New 211.5585 New 211.5860 New 211.5875 New 211.5885 New 211.6405 New 211.6425 New 211.6535 New 211.7290 Amend

4) Statutory Authority: Implementing Sections 21, 22, 22.01 and 22.9, and authorized by Section 27 of the Environmental Protection Act [415 ILCS 5/21, 22, 22.01, 22.9, 27]

5) A complete description of the subjects and issues involved: The Illinois Environmental Protection Agency (Agency) proposed this rulemaking to satisfy Illinois' obligation to submit a State Implementation Plan addressing Clean Air Act requirements for sources of

### ILLINOIS REGISTER 1767 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
volatile organic material (VOM) emissions in ozone nonattainment areas. The United States Environmental Protection Agency (USEPA) issued Control Techniques Guidelines (CTG) for Group II Consumer and Commercial Product Categories. In the CTG, USEPA recommended control measures that it believes constitute reasonably available control technology (RACT) for those product categories.
In Part 211, the Agency proposes adding twenty

-three new definitions and amending four existing definitions for terms employed in proposed amendments to Parts 218 and 219.
For a more detailed description of this rulemaking, see the Board's January 7, 2010, first

notice opinion and order: 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

-08).

6) Published studies or reports, and sources of underlying data, used to compose this rulemaking:
The Agency's regulatory proposal included a Technical Support Document, which stated that it relied on sources listed below. Copies of the documents the Illinois EPA relied upon are available for review with the Pollution Control Board.
Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.

### ILLINOIS REGISTER 1768 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
Technical Support Document for Controlling VOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency, Air Quality Planning Section, Springfield, IL, October 1994.
Control Techniques Guideline Series: Control of Volatile Organic Compound Emissions from Offset Lithographic Printing (DRAFT), United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 1993.

7) Will this rulemaking replace any emergency rulemakings currently in effect? No

8) Does this rulemaking contain an automatic repeal date? No

9) Does this rulemaking contain incorporations by reference? No

10) Are there any other amendments pending on this Part? Yes

Section Number: Proposed Action: Illinois Register Citation: 211.7150 Amend 33 Ill. Reg. 14275; October 16, 2009

11) Statement of Statewide Policy Objectives: This proposed rule does not create or enlarge a State mandate, as defined in Section 3(b) of the State Mandates Act. [30 ILCS 805/3(b) (2008)].

12) Time, place and manner in which interested persons may comment on this proposed rulemaking: The Board will accept written public comment on this proposal for a period of 45 days after the date of this publication. Comments should reference docket R10

-08 and be addressed to:

Clerk's Office Illinois Pollution Control Board State of Illinois Center, Suite 11

-500 100 W. Randolph St. Chicago, IL 60601
Address all questions to Tim Fox at 312

-814

-6085.

### ILLINOIS REGISTER 1769 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
Interested persons may request copies of the Board's opinion and order by calling the Clerk's office at 312

-814

-3620, or download them from the Board's Web site at www.ipcb.state.il.us.

13) Initial regulatory flexibility analysis :
A) Types of small businesses, small municipalities, and not

-for

-profit corporations affected: This rulemaking will impact any small business, small municipality, an not

-for

-profit corporation that falls within one of the Group III Product Categories and meets the applicability thresholds specified in the proposed rules.
B) Reporting, bookkeeping or other procedures required for compliance: The proposed rules require that the owner or operator of a subject source perform emissions monitoring, submit certifications, complete required tests, and maintain records and maker reports as required.

C) Types of professional skills necessary for compliance: No professional skills beyond those currently required by the existing state and federal air pollution control requirements applicable to affected sources will be required.

14) Regulatory Agenda on which this rulemaking was summarized: January 2009

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

### ILLINOIS REGISTER 1770 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

TITLE 35: ENVIRONMENTAL PROTECTION SUBTITLE B: AIR POLLUTION CHAPTER I: POLLUTION CONTROL BOARD SUBCHAPTER c: EMISSION STANDARDS AND LIMITATIONS

FOR STATIONARY SOURCES

PART 211 DEFINITIONS AND GENERAL PROVISIONS

SUBPART A: GENERAL PROVISIONS

Section 211.101 Incorporations by Reference 211.102 Abbreviations and Conversion Factors

SUBPART B: DEFINITIONS

Section 211.121 Other Definitions 211.122 Definitions (Repealed) 211.130 Accelacota 211.150 Accumulator 211.170 Acid Gases 211.210 Actual Heat Input 211.230 Adhesive 211.240 Adhesion Promoter 211.250 Aeration 211.270 Aerosol Can Filling Line 211.290 Afterburner 211.310 Air Contaminant 211.330 Air Dried Coatings 211.350 Air Oxidation Process 211.370 Air Pollutant 211.390 Air Pollution 211.410 Air Pollution Control Equipment 211.430 Air Suspension Coater/Dryer 211.450 Airless Spray 211.470 Air Assisted Airless Spray 211.474 Alcohol

### ILLINOIS REGISTER 1771 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.479 Allowance 211.484 Animal 211.485 Animal Pathological Waste 211.490 Annual Grain Through

-Put 211.495 Anti

-Glare/Safety Coating 211.510 Application Area 211.530 Architectural Coating 211.550 As Applied 211.560 As

-Applied Fountain Solution 211.570 Asphalt 211.590 Asphalt Prime Coat 211.610 Automobile 211.630 Automobile or Light

-Duty Truck Assembly Source or Automobile or Light

-Duty

Truck Manufacturing Plant 211.650 Automobile or Light

-Duty Truck Refinishing 211.660 Automotive/Transportation Plastic Parts 211.665 Auxiliary Boiler 211.670 Baked Coatings 211.680 Bakery Oven 211.685 Basecoat/Clearcoat System 211.690 Batch Loading 211.695 Batch Operation 211.696 Batch Process Train 211.710 Bead

-Dipping 211.730 Binders 211.740 Brakehorsepower (rated

-bhp) 211.750 British Thermal Unit 211.770 Brush or Wipe Coating 211.790 Bulk Gasoline Plant 211.810 Bulk Gasoline Terminal 211.820 Business Machine Plastic Parts 211.830 Can 211.850 Can Coating 211.870 Can Coating Line 211.890 Capture 211.910 Capture Device 211.930 Capture Efficiency 211.950 Capture System 211.953 Carbon Adsorber

### ILLINOIS REGISTER 1772 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.955 Cement 211.960 Cement Kiln 211.970 Certified Investigation 211.980 Chemical Manufacturing Process Unit 211.990 Choke Loading 211.995 Circulating Fluidized Bed Combustor 211.1000 Class II Finish 211.1010 Clean Air Act 211.1050 Cleaning and Separating Operation 211.1070 Cleaning Materials 211.1090 Clear Coating 211.1110 Clear Topcoat 211.1120 Clinker 211.1130 Closed Purge System 211.1150 Closed Vent System 211.1170 Coal Refuse 211.1190 Coating 211.1210 Coating Applicator 211.1230 Coating Line 211.1250 Coating Plant 211.1270 Coil Coating 211.1290 Coil Coating Line 211.1310 Cold Cleaning 211.1312 Combined Cycle System 211.1315 Combustion Tuning 211.1316 Combustion Turbine 211.1320 Commence Commercial Operation 211.1324 Commence Operation 211.1328 Common Stack 211.1330 Complete Combustion 211.1350 Component 211.1370 Concrete Curing Compounds 211.1390 Concentrated Nitric Acid Manufacturing Process 211.1410 Condensate 211.1430 Condensible PM

- 10 211.1435 Container Glass 211.1465 Continuous Automatic Stoking 211.1467 Continuous Coater 211.1470 Continuous Process

### ILLINOIS REGISTER 1773 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.1490 Control Device 211.1510 Control Device Efficiency 211.1515 Control Period 211.1520 Conventional Air Spray 211.1530 Conventional Soybean Crushing Source 211.1550 Conveyorized Degreasing 211.1570 Crude Oil 211.1590 Crude Oil Gathering 211.1610 Crushing 211 .1630 Custody Transfer 211.1650 Cutback Asphalt 211.1670 Daily

-Weighted Average VOM Content 211.1690 Day 211.1710 Degreaser 211.1730 Delivery Vessel 211.1740 Diesel Engine 211.1745 Digital Printing 211.1750 Dip Coating 211.1770 Distillate Fuel Oil 211.1780 Distillation Unit 211.1790 Drum 211.1810 Dry Cleaning Operation or Dry Cleaning Facility 211.1830 Dump

-Pit Area 211.1850 Effective Grate Area 211.1870 Effluent Water Separator 211.1875 Elastomeric Materials 211.1878 Electrical Apparatus Component 211.1880 Electromagnetic Interference/Radio Frequency Interference (EMI/RFI) Shielding

Coatings 211.1885 Electronic Component 211.1890 Electrostatic Bell or Disc Spray 211.1900 Electrostatic Prep Coat 211.1910 Electrostatic Spray 211.1920 Emergency or Standby Unit 211.1930 Emission Rate 211.1950 Emission Unit 211.1970 Enamel 211.1990 Enclose 211.2010 End Sealing Compound Coat

### ILLINOIS REGISTER 1774 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.2030 Enhanced Under

-the

-Cup Fill 211.2050 Ethanol Blend Gasoline 211.2070 Excess Air 211.2080 Excess Emissions 211.2090 Excessive Release 211.2110 Existing Grain

-Drying Operation (Repealed) 211.2130 Existing Grain

-Handling Operation (Repealed) 211.2150 Exterior Base Coat 211.2170 Exterior End Coat 211.2190 External Floating Roof 211.2210 Extreme Performance Coating 211.2230 Fabric Coating 211.2250 Fabric Coating Line 211.2270 Federally Enforceable Limitations and Conditions 211.2285 Feed Mill 211.2290 Fermentation Time 211.2300 Fill 211.2310 Final Repair Coat 211.2330 Firebox 211.2350 Fixed

-Roof Tank 211.2355 Flare 211.2357 Flat Glass 211.2358 Flat Wood Paneling 211.2359 Flat Wood Paneling Coating Line 211.2360 Flexible Coating 211.2365 Flexible Operation Unit 211.2368 Flexible Packaging 211.2370 Flexographic Printing 211.2390 Flexographic Printing Line 211.2410 Floating Roof 211.2420 Fossil Fuel 211.2425 Fossil Fuel

-Fired 211.2430 Fountain Solution 211.2450 Freeboard Height 211.2470 Fuel Combustion Emission Unit or Fuel Combustion Emission Source 211.2490 Fugitive Particulate Matter 211 .2510 Full Operating Flowrate 211.2530 Gas Service 211.2550 Gas/Gas Method

### ILLINOIS REGISTER 1775 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.2570 Gasoline 211.2590 Gasoline Dispensing Operation or Gasoline Dispensing Facility 211.2610 Gel Coat 211.261 5 General Work Surface 211.2620 Generator 211.2625 Glass Melting Furnace 211.2630 Gloss Reducers 211.2650 Grain 211.2670 Grain

-Drying Operation 211.2690 Grain

-Handling and Conditioning Operation 211.2710 Grain

-Handling Operation 211.2730 Green

-Tire Spraying 211.2750 Green Tires 211.2770 Gross Heating Value 211.2790 Gross Vehicle Weight Rating 211.2810 Heated Airless Spray 211.2815 Heat Input 211.2820 Heat Input Rate 211.2830 Heatset 211.2840 Heatset Web Letterpress Printing Line 211.2850 Heatset Web Offset Lithographic Printing Line 211.2870 Heavy Liquid 211.2890 Heavy Metals 211.2910 Heavy Off

-Highway Vehicle Products 211.2930 Heavy Off

-Highway Vehicle Products Coating 211.2950 Heavy Off

-Highway Vehicle Products Coating Line 211.2965 High Precision Optic 211.2970 High Temperature Aluminum Coating 211.2990 High Volume Low Pressure (HVLP) Spray 211.3010 Hood 211.3030 Hot Well 211.3050 Housekeeping Practices 211.3070 Incinerator 211.3090 Indirect Heat Transfer 211.3100 Industrial Boiler 211.3110 Ink 211.3130 In

-Process Tank 211.3150 In

-Situ Sampling Systems 211.3170 Interior Body Spray Coat

### ILLINOIS REGISTER 1776 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.3190 Internal

-Floating Roof 211.3210 Internal Transferring Area 211.3215 Janitorial Cleaning 211.3230 Lacquers 211.3250 Large Appliance 211.3270 Large Appliance Coating 211.3290 Large Appliance Coating Line 211.3300 Lean

-Burn Engine 211.3305 Letterpress Printing Line 211.3310 Light Liquid 211.3330 Light

-Duty Truck 211.3350 Light Oil 211.3355 Lime Kiln 211.3370 Liquid/Gas Method 211.3390 Liquid

-Mounted Seal 211.3410 Liquid Service 211.3430 Liquids Dripping 211.3450 Lithographic Printing Line 211.3470 Load

-Out Area 211.3475 Load Shaving Unit 211.3480 Loading Event 211.3483 Long Dry Kiln 211.3485 Long Wet Kiln 211.3487 Low

-NOx 

### Burner 211.3490 Low Solvent Coating 211.3500 Lubricating Oil 211.3510 Magnet Wire 211.3530 Magnet Wire Coating 211.3550 Magnet Wire Coating Line 211.3555 Maintenance Cleaning 211.3570 Major Dump Pit 211.3590 Major Metropolitan Area (MMA) 211.3610 Major Population Area (MPA) 211.3620 Manually Operated Equipment 211.3630 Manufacturing Process 211.3650 Marine Terminal 211.3660 Marine Vessel 211.3670 Material Recovery Section 211.3690 Maximum Theoretical Emissions

### ILLINOIS REGISTER 1777 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.3695 Maximum True Vapor Pressure 211.3705 Medical Device 211.3707 Medical Device and Pharmaceutical Manufacturing 211.3710 Metal Furniture 211.3730 Metal Furniture Coating 211.3750 Metal Furniture Coating Line 211.3770 Metallic Shoe

-Type Seal 211.3780 Mid

-Kiln Firing 211.3790 Miscellaneous Fabricated Product Manufacturing Process 211.381 0 Miscellaneous Formulation Manufacturing Process 211.3830 Miscellaneous Metal Parts and Products 211.3850 Miscellaneous Metal Parts and Products Coating 211.3870 Miscellaneous Metal Parts or Products Coating Line 211.3890 Miscellaneous Organic Chemical Manufacturing Process 211.3910 Mixing Operation 211.3915 Mobile Equipment 211.3930 Monitor 211.3950 Monomer 211.3960 Motor Vehicles 211.3965 Motor Vehicle Refinishing 211.3970 Multiple Package Coating 211.3980 Nameplate Capacity 211.3990 New Grain

-Drying Operation (Repealed) 211.4010 New Grain

-Handling Operation (Repealed) 211.4030 No Detectable Volatile Organic Material Emissions 211.4050 Non

-Contact Process Water Cooling Tower 211.4055 Non

-Flexible Coating 211.4065 Non

-Heatset 211.4067 NOx 

### Trading Program 211.4070 Offset 211.4090 One Hundred Percent Acid 211.4110 One

-Turn Storage Space 211.4130 Opacity 211.4150 Opaque Stains 211.4170 Open Top Vapor Degreasing 211.4190 Open

-Ended Valve 211.4210 Operator of a Gasoline Dispensing Operation or Operator of a Gasoline

Dispensing Facility 211.4230 Organic Compound

### ILLINOIS REGISTER 1778 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.4250 Organic Material and Organic Materials 211.4260 Organic Solvent 211.4270 Organic Vapor 211.4280 Other Glass 211.4290 Oven 211.4310 Overall Control 211.4330 Overvarnish 211.4350 Owner of a Gasoline Dispensing Operation or Owner of a Gasoline Dispensing

Facility 211.4370 Owner or Operator 211.4390 Packaging Rotogravure Printing 211.4410 Packaging Rotogravure Printing Line 211.4430 Pail 211.4450 Paint Manufacturing Source or Paint Manufacturing Plant 211.4470 Paper Coating 211.4490 Paper Coating Line 211.4510 Particulate Matter 211.4530 Parts Per Million (Volume) or PPM (Vol) 211.4550 Person 211.4590 Petroleum 211.4610 Petroleum Liquid 211.4630 Petroleum Refinery 211.4650 Pharmaceutical 211.4670 Pharmaceutical Coating Operation 211.4690 Photochemically Reactive Material 211.4710 Pigmented Coatings 211.4730 Plant 211.4740 Plastic Part 211.4750 Plasticizers 211.4770 PM

- 10 211.4790 Pneumatic Rubber Tire Manufacture 211.4810 Polybasic Organic Acid Partial Oxidation Manufacturing Process 211.4830 Polyester Resin Material(s) 211.4850 Polyester Resin Products Manufacturing Process 211.4870 Polystyrene Plant 211.4890 Polystyrene Resin 211.4910 Portable Grain

-Handling Equipment 211.4930 Portland Cement Manufacturing Process Emission Source 211.4950 Portland Cement Process or Portland Cement Manufacturing Plant

### ILLINOIS REGISTER 1779 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.4960 Potential Electrical Output Capacity 211.4970 Potential to Emit 211.4990 Power Driven Fastener Coating 211.5010 Precoat 211.5015 Preheater Kiln 211.5020 Preheater/Precalciner Kiln 211.5030 Pressure Release 211.5050 Pressure Tank 211.5060 Pressure/Vacuum Relief Valve 211.5061 Pretreatment Wash Primer 211.5065 Primary Product 2 11.5070 Prime Coat 211.5080 Primer Sealer 211.5090 Primer Surfacer Coat 211.5110 Primer Surfacer Operation 211.5130 Primers 211.5150 Printing 211.5170 Printing Line 211.5185 Process Emission Source 211.5190 Process Emission Unit 211.5195 Process Heater 211.5210 Process Unit 211.5230 Process Unit Shutdown 211.5245 Process Vent 211.5250 Process Weight Rate 211.5270 Production Equipment Exhaust System 211.5310 Publication Rotogravure Printing Line 211.5330 Purged Process Fluid 211.5335 Radiation Effect Coating 211.5340 Rated Heat Input Capacity 211.5350 Reactor 211.5370 Reasonably Available Control Technology (RACT) 211.5390 Reclamation System 211.5410 Refiner 211.5430 Refinery Fuel Gas 211.5450 Refinery Fuel Gas System 211.5470 Refinery Unit or Refinery Process Unit 211.5480 Reflective Argent Coating 211.5490 Refrigerated Condenser

### ILLINOIS REGISTER 1780 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.5500 Regulated Air Pollutant 211.5510 Reid Vapor Pressure 211.5530 Repair 211.5535 Repair Cleaning 211.5550 Repair Coat 211.5570 Repaired 211.5580 Repowering 211.5585 Research and Development Operation 211.5590 Residual Fuel Oil 211.5600 Resist Coat 211.5610 Restricted Area 211.5630 Retail Outlet 211.5640 Rich

-Burn Engine 211.5650 Ringelmann Chart 211.5670 Roadway 211.5690 Roll Coater 211.571 0 Roll Coating 211.5730 Roll Printer 211.5750 Roll Printing 211.5770 Rotogravure Printing 211.5790 Rotogravure Printing Line 211.5810 Safety Relief Valve 211.5830 Sandblasting 211.5850 Sanding Sealers 211.5860 Scientific Instrument 211.5870 Screening 211.5875 Screen Printing 211.5880 Screen Printing on Paper 211.5885 Screen Reclamation 211.5890 Sealer 211.5910 Semi

-Transparent Stains 211.5930 Sensor 211.5950 Set of Safety Relief Valves 211.5970 Sheet Basecoat 211.5980 Sheet

-Fed 211.5990 Shotblasting 211.6010 Side

-Seam Spray Coat 211.6025 Single Unit Operation 211.6030 Smoke

### ILLINOIS REGISTER 1781 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.6050 Smokeless Flare 211.6060 Soft Coat 211.6070 Solvent 211.6090 Solvent Cleaning 211.6110 Solvent Recovery System 211.6130 Source 211.6140 Specialty Coatings 211.6145 Specialty Coatings for Motor Vehicles 211.6150 Specialty High Gloss Catalyzed Coating 211.6170 Specialty Leather 211.6190 Specialty Soybean Crushing Source 211.6210 Splash Loading 211.6230 Stack 211.6250 Stain Coating 211.6270 Standard Conditions 211.6290 Standard Cubic Foot (scf) 211.6310 Start

-Up 211.6330 Stationary Emission Source 211.6350 Stationary Emission Unit 211.6355 Stationary Gas Turbine 211.6360 Stationary Reciprocating Internal Combustion Engine 211.6370 Stationary Source 211.6390 Stationary Storage Tank 211.6400 Stencil Coat 211.6405 Sterilization Indicating Ink 211.6410 Storage Tank or Storage Vessel 211.6420 Strippable Spray Booth Coating 211.6425 Stripping 211.6430 Styrene Devolatilizer Unit 211.6450 Styrene Recovery Unit 211.6470 Submerged Loading Pipe 211.6490 Substrate 211.6510 Sulfuric Acid Mist 211.6530 Surface Condenser 211.6535 Surface Preparation 211.6540 Surface Preparation Materials 211.6550 Synthetic Organic Chemical or Polymer Manufacturing Plant 211.6570 Tablet Coating Operation 211.6580 Texture Coat

### ILLINOIS REGISTER 1782 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.6590 Thirty

-Day Rolling Average 211.6610 Three

-Piece Can 211.6620 Three or Four Stage Coating System 211.6630 Through

-the

-Valve Fill 211.6650 Tooling Resin 211.6670 Topcoat 211.6690 Topcoat Operation 211.6695 Topcoat System 211.6710 Touch

-Up 211.6720 Touch

-Up Coating 211.6730 Transfer Efficiency 211.6750 Tread End Cementing 211.6770 True Vapor Pressure 211.6790 Turnaround 211.6810 Two

-Piece Can 211.6830 Under

-the

-Cup Fill 211 .6850 Undertread Cementing 211.6860 Uniform Finish Blender 211.6870 Unregulated Safety Relief Valve 211.6880 Vacuum Metallizing 211.6890 Vacuum Producing System 211.6910 Vacuum Service 211.6930 Valves Not Externally Regulated 211.6950 Vapor Balance System 211.6970 Vapor Collection System 211.6990 Vapor Control System 211.7010 Vapor

-Mounted Primary Seal 211.7030 Vapor Recovery System 211.7050 Vapor

-Suppressed Polyester Resin 211.7070 Vinyl Coating 211.7090 Vinyl Coating Line 211.7110 Volatile Organic Liquid (VOL) 211.7130 Volatile Organic Material Content (VOMC) 211.7150 Volatile Organic Material (VOM) or Volatile Organic Compound (VOC) 211.7170 Volatile Petroleum Liquid 211.7190 Wash Coat 211.7200 Washoff Operations 211.7210 Wastewater (Oil/Water) Separator 211.7230 Weak Nitric Acid Manufacturing Process

### ILLINOIS REGISTER 1783 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

211.7250 Web 211.7270 Wholesale Purchase − Consumer 211.7290 Wood Furniture 211.7310 Wood Furniture Coating 211.7330 Wood Furniture Coating Line 211.7350 Woodworking 211.7400 Yeast Percentage

211.APPENDIX A Rule into Section Table 211.APPENDIX B Section into Rule Table

AUTHORITY: Implementing Sections 9, 9.1, 9.9 and 10 and authorized by Sections 27 of the Environmental Protection Act [415 ILCS 5/9, 9.1, 9.9, 10, 27].
SOURCE: Adopted as Chapter 2: Air Pollution, Rule 201: Definitions, R71

-23, 4 PCB 191, filed and effective April 14, 1972; amended in R74

-2 and R75

-5, 32 PCB 295, at 3 Ill. Reg. 5, p. 777, effective February 3, 1979; amended in R78

-3 and 4, 35 PCB 75 and 243, at 3 Ill. Reg. 30, p. 124, effective July 28, 1979; amended in R80

-5, at 7 Ill. Reg. 1244, effective January 21, 1983; codified at 7 Ill. Reg. 13590; amended in R82

- 1 (Docket A) at 10 Ill. Reg. 12624, effective July 7, 1986; amended in R85

-21(A) at 11 Ill. Reg. 11747, effective June 29, 1987; amended in R86

-34 at 11 Ill. Reg. 12267, effective July 10, 1987; amended in R86

-39 at 11 Ill. Reg. 20804, effective December 14, 1987; amended in R82

- 14 and R86

-37 at 12 Ill. Reg. 787, effective December 24, 1987; amended in R86

- 18 at 12 Ill. Reg. 7284, effective April 8, 1988; amended in R86

- 10 at 12 Ill. Reg. 7621, effective April 11, 1988; amended in R88

-23 at 13 Ill. Reg. 10862, effective June 27, 1989; amended in R89

-8 at 13 Ill. Reg. 17457, effective January 1, 1990; amended in R89

- 16(A) at 14 Ill. Reg. 9141, effective May 23, 1990; amended in R88

- 30(B) at 15 Ill. Reg. 5223, effective March 28, 1991; amended in R88

- 14 at 15 Ill. Reg. 7901, effective May 14, 1991; amended in R91

- 10 at 15 Ill. Reg. 15564, effective October 11, 1991; amended in R91

-6 at 15 Ill. Reg. 15673, effective October 14, 1991; amended in R91

-22 at 16 Ill. Reg. 7656, effective May 1, 1992; amended in R91

-24 at 16 Ill. Reg. 13526, effective August 24, 1992; amended in R93

-9 at 17 Ill. Reg. 16504, effective September 27, 1993; amended in R93

- 11 at 17 Ill. Reg. 21471, effective December 7, 1993; amended in R93

- 14 at 18 Ill. Reg. 1253, effective January 18, 1994; amended in R94

- 12 at 18 Ill. Reg. 14962, effective September 21, 1994; amended in R94

- 14 at 18 Ill. Reg. 15744, effective October 17, 1994; amended in R94

- 15 at 18 Ill. Reg. 16379, effective October 25, 1994; amended in R94

- 16 at 18 Ill. Reg. 16929, effective November 15, 1994; amended in R94

-21, R94

-31 and R94

-32 at 19 Ill. Reg. 6823, effective May 9, 1995; amended in R94

-33 at 19 Ill. Reg. 7344, effective May 22, 1995; amended in R95

-2 at 19 Ill. Reg. 11066, effective July 12, 1995; amended in R95

- 16 at 19 Ill. Reg. 15176, effective October 19, 1995; amended in R96

-5 at 20 Ill. Reg. 7590, effective May

### ILLINOIS REGISTER 1784 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

22, 1996; amended in R96

- 16 at 21 Ill. Reg. 2641, effective February 7, 1997; amended in R97

- 17 at 21 Ill. Reg. 6489, effective May 16, 1997; amended in R97

-24 at 21 Ill. Reg. 7695, effective June 9, 1997; amended in R96

- 17 at 21 Ill. Reg. 7856, effective June 17, 1997; amended in R97

-31 at 22 Ill. Reg. 3497, effective February 2, 1998; amended in R98

- 17 at 22 Ill. Reg. 11405, effective June 22, 1998; amended in R01

-9 at 25 Ill. Reg. 108, effective December 26, 2000; amended in R01

- 11 at 25 Ill. Reg. 4582, effective March 15, 2001; amended in R01

- 17 at 25 Ill. Reg. 5900, effective April 17, 2001; amended in R05

- 16 at 29 Ill. Reg. 8181, effective May 23, 2005; amended in R05

- 11 at 29 Ill. Reg. 8892, effective June 13, 2005; amended in R04

- 12/20 at 30 Ill. Reg. 9654, effective May 15, 2006; amended in R07

- 18 at 31 Ill. Reg. 14254, effective September 25, 2007; amended in R08

-6 at 32 Ill. Reg. 1387, effective January 16, 2008; amended in R07

- 19 at 33 Ill. Reg. 11982, effective August 6, 2009; amended in R08

- 19 at 33 Ill. Reg. 13326, effective August 31, 2009; amended in R10

-7 at 34 Ill. Reg. 1391, effective January 11, 2010; amended in R10

-8 at 34 Ill. Reg. ______, effective ____________.

SUBPART B: DEFINITIONS

Section 211.1000 Class II Finish

"Class II Finish" means a finish that meets the specifications of Voluntary Product Standard PS

59

-73, as approved by the American National Standards Institute.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.1745 Digital Printing

"Digital Printing" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, the transfer of electronic files directly from a computer to an electronically driven output device that prints the image directly on the selected media (substrate). Printing using home and office equipment is excluded from this definition.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.1878 Electrical Apparatus Component

"Electrical Apparatus Component" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an internal component such as wires, windings, stators, rotors, magnets, contacts, relays, energizers, and connections in an apparatus that generates or transmits electrical energy
, including, but not limited to, alternators, generators, transformers, electric motors, cables, and circuit breakers, except for the actual cabinet in which the components are housed. Electrical

### ILLINOIS REGISTER 1785 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
components of graphic arts application equipment and hot

-line tools are also included in this category.
(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.1885 Electronic Component

"Electronic Component" means, for the purposes of 35 Ill. Adm. Code 218.182(f)
, and 219.182(f), 218.187, and 219.187, all portions of an electronic assembly, including, but not limited to, circuit board assemblies, printed wire assemblies, printed circuit boards, soldered joints, ground wires, bus bars, and associated electronic component manufacturing equipment such as screens and filters, except for the actual cabinet in which the components are housed

. (Source: Amended at 34 Ill. Reg. ______, effective ____________)
Section 211.2358 Flat Wood Paneling
"Flat Wood Paneling" means natural finish hardwood plywood panels, hardwood panels with Class II finishes, tileboard, exterior siding, and printed interior panels made of hardwood, plywood, or thin particleboard.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.2359 Flat Wood Paneling Coating Line
"Flat Wood Paneling Coating Line" means a coating line in which any protective, decorative, or functional coating is applied to flat wood paneling.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.2368 Flexible Packaging

"Flexible Packaging" means any package or part of a package, the shape of which can be readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination of these materials. Shrink

-wrap labels or wrappers (but not self

-adhesive labels) printed on or in

-line with a flexible packaging printing press are also considered to be flexible packaging. Flexible packaging does not include folding cartons, gift wraps, hot stamp foils, wall coverings, vinyl products, decorative laminates, floor coverings, or tissue products.

### ILLINOIS REGISTER 1786 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.2615 General Work Surface

"General Work Surface" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an area of a medical device or pharmaceutical manufacturing facility where solvent cleaning is performed on work surfaces, but for which cleaning specifications are not required to be maintained in accordance with criteria and procedures established to meet requirements of the United States Food and Drug Administration and/or other applicable regulatory agencies with authority over manufacturing operations for medical devices and/or pharmaceuticals. General work surfaces shall not include items defined under "Janitorial Cleaning"

. (Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.2830 Heatset
"Heatset" means a class of lithography or letterpress that which requires a heated dryer to solidify the printing inks.

(Source: Amended at 34 Ill. Reg. ______, effective ____________)

Section 211.2840 Heatset Web Letterpress Printing Line
"Heatset Web Letterpress Printing Line" means a letterpress printing line in which a continuous roll of substrate is fed through the printing press and an oven is used to solidify the printing inks.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.2965 High Precision Optic

"High Precision Optic" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an optical element used in an electro

-optical device that is designed to sense, detect, or transmit light energy, including specific wavelengths of light energy and changes in light energy levels.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.3215 Janitorial Cleaning

### ILLINOIS REGISTER 1787 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

"Janitorial Cleaning" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, the cleaning of building or facility components, including, but not limited to, floors, ceilings, walls, windows, doors, stairs, bathrooms, furnishings, and exterior surfaces of office equipment, and

excludes the cleaning of work areas where manufacturing or repair activity is performed.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.3305 Letterpress Printing Line

"Letterpress Printing Line" means a web or sheetfed printing line that does not constitute a flexographic printing line, in which the image area is raised relative to the non

-image area and the ink is transferred to the substrate directly from the image surface.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.3555 Maintenance Cleaning

"Maintenance Cleaning" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, a solvent cleaning operation or activity carried out to ensure that general work areas where manufacturing or repair activity is performed remain clean, and to clean tools, machinery, molds, forms, jigs, and equipment. This definition does not include the cleaning of coatings, adhesives, or ink application equipment.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.3705 Medical Device

"Medical Device" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent or other similar article, including any component or accessory, that meets one or more of the following conditions:

a) it is intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, treatment, or prevention of disease;

b) it is intended to affect the structure or any function of the body; or

c) it is defined in the National Formulary or the United States Pharmacopeia, or any supplement to them.

### ILLINOIS REGISTER 1788 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.3707 Medical Device and Pharmaceutical Manufacturing

"Medical Device and Pharmaceutical Manufacturing" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, the collection of equipment and activities to prepare, utilize, maintain, and repair work areas, in order to accomplish one or more steps in preparing a medical device or pharmaceutical for its intended use. Manufacturing is typically, but not always, conducted in accordance with criteria and procedures established to meet requirements of the United States Food and Drug Administration and/or other applicable regulatory agencies with authority over manufacturing operations for global sales of medical devices and/or pharmaceuticals. Work areas and equipment shall include all machinery, tools, equipment, rooms, tables, countertops
, and facilities for maintaining employee health and safety that are subject to such criteria and procedures.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.4065 Non

-Heatset

"Non

-heatset" means a class of lithography or letterpress that which does not require a heated dryer to solidify the printing inks. Ultraviolet

-cured and electron beam

-cured inks are considered

non

-heatset.

(Source: Amended at 34 Ill. Reg. ______, effective ____________)

Section 211.5335 Radiation Effect Coating

"Radiation Effect Coating" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, a coating or coating system engineered to interact, through absorption or reflection, with specific regions of the electromagnetic energy spectrum, such as the ultraviolet, visible, infrared, or microwave regions. Uses include, but are not limited to, lightning strike protection, electromagnetic pulse protection, and radar avoidance. Coatings that have been designated

"classified" by the Department of Defense are not included in this definition.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.5535 Repair Cleaning

### ILLINOIS REGISTER 1789 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

"Repair Cleaning" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, a solvent cleaning operation or activity carried out during a repair process.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.5585 Research and Development Operation
"Research and Development Operation" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an operation whose purpose is for research and development of new processes and products, that is conducted under the close supervision of technically trained personnel, and that is not involved in the manufacture of final or intermediate products for commercial purposes, except in a de minimis manner.
(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.5860 Scientific Instrument

"Scientific Instrument" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an instrument, including the components, assemblies, and subassemblies used in their manufacture, and associated accessories and reagents that are used for the detection, measurement, analysis, separation, synthesis, or sequencing of various compounds.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.5875 Screen Printing
"Screen Printing" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, a process in which the printing ink passes through a taut screen or fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions of the imprint.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.5885 Screen Reclamation

"Screen Reclamation" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, a solvent cleaning activity carried out in a screen printing operation in which the screen is completely cleaned and the stencil removed for recycling or reuse of the screen for other production runs.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

### ILLINOIS REGISTER 1790 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

Section 211.6405 Sterilization Indicating Ink
"Sterilization Indicating Ink" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, an ink that changes color to indicate that sterilization has occurred. Such ink is used to monitor the sterilization of medical instruments, autoclave efficiency, and the thermal processing of foods for prevention of spoilage.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.6425 Stripping
"Stripping" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, the removal of cured coatings, cured inks, or cured adhesives.

(Source: Added at 34 Ill. Reg. ______, effective ____________)
Section 211.6535 Surface Preparation

"Surface Preparation" means, for purposes of 35 Ill. Adm. Code 218.187 and 219.187, the removal of contaminants such as dust, soil, oil, and grease prior to coating, adhesive, or ink applications.

(Source: Added at 34 Ill. Reg. ______, effective ____________)

Section 211.7290 Wood Furniture
"Wood furniture" means room furnishings
, including cabinets (kitchen, bath and vanity), tables, chairs, beds, sofas, shutters, art objects, wood paneling other than flat wood paneling, wood flooring and any other coated furnishings made of wood, wood composition or fabricated wood materials.

(Source: Amended at 34 Ill. Reg. ______, effective ____________)

### ILLINOIS REGISTER 1791 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

1) Heading of the Part: Organic Material Emission Standards and Limitations for the Chicago Area

2) Code Citation: 35 Ill. Adm. Code 218

3) Section Numbers: Proposed Action: 218.106 Amend 218.181 Amend 218.187 New 218.204 Amend 218.205 Amend 218.207 Amend 218.210 Amend 218.211 Amend 218.212 Amend 218.217 Amend 218.401 Amend 218.402 Amend 218.403 Amend 218.404 Amend 218.405 Amend 218.406 Repeal 218.407 Amend 218.408 Repeal 218.409 Amend 218.410 Amend 218.411 Amend 218.412 New 218.413 New 218.415 New 218.416 New 218.417 New

4) Statutory authority: Implementing Sections 21, 22, 22.01 and 22.9, and authorized by Section 27 of the Environmental Protection Act [415 ILCS 5/21, 22, 22.01, 22.9, 27]

5) A complete description of the subjects and issues involved: The Illinois Environmental Protection Agency (Agency) proposed this rulemaking to satisfy Illinois' obligation to submit a State Implementation Plan addressing Clean Air Act requirements for sources of

### ILLINOIS REGISTER 1792 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
volatile organic material (VOM) emissions in ozone nonattainment areas. The United States Environmental Protection Agency (USEPA) issued Control Techniques Guidelines (CTG) for Group II Consumer and Commercial Product Categories. In the CTG, USEPA recommended control measures that it believes constitute reasonably available control technology (RACT) for those product categories.
For a more detailed description of this rulemaking, see the Board's January 7, 2010, first

notice opinion and order: 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

-08)

6) Published studies or reports, and sources of underlying data, used to compose this rulemaking:
The Agency's regulatory proposal included a Technical Support Document, which stated that it relied on sources listed below. Copies of the documents the Agency relied upon are available for review with the Pollution Control Board.
Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006. Technical Support Document for Controlling VOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency, Air Quality Planning Section, Springfield, IL, October 1994.
Control Techniques Guideline Series: Control of Volatile Organic Compound Emissions from Offset Lithographic Printing (DRAFT), United States Environmental Protection

### ILLINOIS REGISTER 1793 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 1993.

7) Will this rulemaking replace any emergency rulemaking currently in effect? No

8) Does this rulemaking contain an automatic repeal date? No

9) Does this rulemaking contain incorporations by reference? No

10) Are there any other amendments pending on this Part? Yes

Sections Numbers : Proposed Actions: Illinois Register Citation: 218.106 Amended 33 Ill. Reg. 16399; November 20, 2009 218.204 Amended 33 Ill. Reg. 16399; November 20, 2009 218.205 Amended 33 Ill. Reg. 16399; November 20, 2009 218.207 Amended 33 Ill. Reg. 16399; November 20, 2009 2 18.210 Amended 33 Ill. Reg. 16399; November 20, 2009 218.211 Amended 33 Ill. Reg. 16399; November 20, 2009 218.212 Amended 33 Ill. Reg. 16399; November 20, 2009 218.218 Amended 33 Ill. Reg. 16399; November 20, 2009

11) Statement of Statewide Policy Objectives : This proposed rule does not create or enlarge a State mandate, as defined in Section 3(b) of the State Mandates Act [30 ILCS 805/3(b) (2008)].

12) Time, Place and Manner in which interested persons may comment on this proposed rulemaking: The Board will accept written public comment on this proposal for a period of 45 days after the date of this publication. Comments should reference docket R10

-08 and be addressed to:

Clerk's Office Illinois Pollution Control Board State of Illinois Center, Suite 11

-500 100 W. Randolph St. Chicago, IL 60601
Address all questions to Tim Fox at 312

-814

-6085.

### ILLINOIS REGISTER 1794 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS
Interested persons may request copies of the Board's opinion and order by calling the Clerk's office at 312

-814

-3620, or download them from the Board's Web site at www.ipcb.state.il.us.

13) Initial regulatory flexibility analysis :
A) Types of small businesses, small municipalities, and not

-for

-profit corporations affected: This rulemaking will impact any small business, small municipality, and not

-f or

-profit corporation that falls within one of the Group III Product Categories and meets the applicability thresholds specified in the proposed rules.

B) Reporting, bookkeeping or other procedures required for compliance: The proposed rules require that the owner or operator of a subject source perform emissions monitoring, submit certifications, complete required tests, and maintain records and maker reports as required.

C) Types of professional skills necessary for compliance: No professional skills beyond those currently required by the existing state and federal air pollution control requirements applicable to affected sources will be required.

14) Regulatory Agenda on which this rulemaking was summarized January 2009

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

### ILLINOIS REGISTER 1941 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

1) Heading of the Part: Organic Material Emission Standards and Limitations for the Metro East Area

2) Code Citation: 35 Ill. Adm. Code 219

3) Section Numbers: Proposed Action: 219.106 Amend 219.181 Amend 219.187 New 219.204 Amend 219.205 Amend 219.207 Amend 219.210 Amend 219.211 Amend 219.212 Amend 219.217 Amend 219.401 Amend 219.402 Amend 219.403 Amend 219.404 Amend 219.405 Amend 219.406 Repeal 219.407 Amend 219.408 Repeal 219.409 Amend 219.410 Amend 219.411 Amend 219.412 New 219.413 New 219.415 New 219.416 New 219.417 New

4) Statutory Authority: Implementing Sections 21, 22, 22.01 and 22.9, and authorized by Section 27 of the Environmental Protection Act [415 ILCS 5/21, 22, 22.01, 22.9, 27]

5) A complete description of the subjects and issues involved: The Illinois Environmental Protection Agency (Agency) proposed this rulemaking to satisfy Illinois' obligation to submit a State Implementation Plan addressing Clean Air Act requirements for sources of

### ILLINOIS REGISTER 1942 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

volatile organic material (VOM) emissions in ozone nonattainment areas. The United States Environmental Protection Agency (USEPA) issued Control Techniques Guidelines (CTG) for Group II Consumer and Commercial Product Categories. In the CTG, USEPA recommended control measures that it believes constitute reasonably available control technology (RACT) for those product categories.
For a more detailed description of this rulemaking, see the Board's January 7, 2010, first

notice opinion and order: 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

-08)

6) Published studies or reports, and sources of underlying data, used to compose this rulemaking: The Agency's regulatory proposal included a Technical Support Document, which stated that it relied on sources listed below. Copies of the documents the Agency relied upon are available for review with the Pollution Control Board.
Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006.
Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 2006. Technical Support Document for Controlling VOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency, Air Quality Planning Section, Springfield, IL, October 1994.
Control Techniques Guideline Series: Control of Volatile Organic Compound Emissions from Offset Lithographic Printing (DRAFT), United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Research Triangle Park, NC, September 1993.

### ILLINOIS REGISTER 1943 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

7) Will this rulemaking replace any emergency rulemaking currently in effect? No

8) Does this rulemaking contain an automatic repeal date? No

9) Does this rulemaking contain incorporations by reference? No

10) Are there any other rulemaking pending on this Part? Yes

Section Numbers: Proposed Action: Illinois Register Citation 219.106 Amend 33 Ill. Reg. 16460; November 20, 2009 219.204 Amend 33 Ill. Reg. 16460; November 20, 2009 219.205 Amend 33 Ill. Reg. 16460; November 20, 2009 219.207 Amend 33 Ill. Reg. 16460; November 20, 2009 219.210 Amend 33 Ill. Reg. 16460; November 20, 2009 219.211 Amend 33 Ill. Reg. 16460; November 20, 2009 219.212 Amend 33 Ill. Reg. 16460; November 20, 2009 219.218 Add 33 Ill. Reg. 16460; November 20, 2009

11) Statement of Statewide Policy Objectives : This proposed rulemaking does not create or enlarge a State mandate, as defined in Section 3(b) of the State Mandates Act [30 ILCS 805/3(b) (2008)].

12) Time, Place and Manner in which interested persons may comment on this proposed rulemaking: The Board will accept written public comment on this proposal for a period of 45 days after the date of this publication. Comments should reference docket R10

-08 and be addressed to:

Clerk's Office Illinois Pollution Control Board State of Illinois Center, Suite 11

-500 100 W. Randolph St. Chicago, IL 60601
Address all questions to Tim Fox at 312

-814

-6085.
Interested persons may request copies of the Board's opinion and order by calling the Clerk's office at 312

-814

-3620, or download them from the Board's Web site at www.ipcb.state.il.us

.

### ILLINOIS REGISTER 1944 10 POLLUTION CONTROL BOARD

NOTICE OF PROPOSED AMENDMENTS

13) Initial regulatory flexibility analysis :
A) Types of small businesses, small municipalities, and not

-for

-profit corporations affected: This rulemaking will impact any small business, small municipality, and not

-for

-profit corporation that falls within one of the Group III Product Categories and meets the applicability thresholds specified in the proposed rules.

B) Reporting, bookkeeping or other procedures required for compliance: The proposed rules require that the owner or operator of a subject source perform emissions monitoring, submit certifications, complete required tests, and maintain records and maker reports as required.

C) Types of professional skills necessary for compliance: No professional skills beyond those currently required by the existing state and federal air pollution control requirements applicable to affected sources will be required.

14) Regulatory Agenda on which this rulemaking was summarized: January 2009
The full text of the Proposed Amendments begins on the next page:

# A 16

## Electronic Filing

- Received, Clerk's Office, February 17, 2010

* * * * * PC #3 * * * * *

BEFORE THE ILLINOIS POI,LUTION CONTROL BOARD



### IN THE 

### MAITER OF:

REASONABLY AV AILABLE 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 ) ) ) ) 

### ) ) 

### ) 

### ) RIO-8 

### (Rulemaking-Air)

NOTICE



### To: John Therriault, Assistant Clerk Illinois Pollution Control Board James R. 

### Thompson Center 100 West Randolph, Suite 11-500 Chicago, Illinois 60601-3218

SEE ATTACHED SERVICE LIST



### PLEASE TAKE NOTICE that I 

### have today filed with the Office ofthe Pollution Control Board the FIRST NOTICE COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY, a copy ofwhich is herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By: 

## CZ\e,.rA

# rt'rd&cit~ Dana Vetterhoffer Assistant Counsel Di vision ofLegal Counsel

DATED: February 17,2010

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

## Electronic Filing

- Received, Clerk's Office, February 17, 2010

* * * * * PC #3 * * * * *

BEFORE THE 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 211,218, and 219 

### ) ) ) ) ) 

### ) ) 

### ) RIO-8 (Rulemaking-Air)



### FIRST NOTICE COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

The Illinois Environmental Protection Agency ("Illinois EPA"), by its attorney,

respectfully submits its comments in the above rulemaking proceeding regarding first notice,

published on February 5, 2010. (See 34 Ill. Reg. 1766-2086).

The Illinois EPA proposes the following clarifications and corrections to the first notice

version ofthe proposal:

1) 

### In Section 218.187(a)(l), the Illinois EPA recommends inserting the word "at" for

clarification purposes, as set forth below.

Section 218.187 Other Industrial Solvent Cleaning Operations

a)

. Applicability. On and after April 1, 201 I:

I) Except as provided in subsection (a)(2) ofthis Section, the requirements of this Section shall apply to all cleaning operations that use organic materials &sourees that emit a total of 6.8 kg/day (15 Ibslday) or more of YOM from cleaning operations at the source, in the absence ofair pollution control equipment. For purposes of this Section, "cleaning operation" means the process ofcleaning products, product components, tools, equipment, or general work areas during production, repair, maintenance, or servicing, including but not limited to spray gun cleaning, spray booth cleaning, large and small manufactured components cleaning, parts cleaning, equipment cleaning, line cleaning, floor cleaning, and tank cleaning, at sources with emission units;

## Electronic Filing

- Received, Clerk's Office, February 17, 2010

* * * * * PC #3 * * * * *

2) 

### In Section 218.205(b)(I), the first notice version of the proposal deletes a slash mark

between "kg" and "I" and inserts an open parenthesis that breaks up the unit ofmeasurement.

The Illinois EPA therefore proposes the following amendment.

b) No owner or operator of a miscellaneous metal parts and products coating line subject to the limitations of Section 2IS.204U) of this Subpart shall apply coatings
to miscellaneous metal parts or products on the subject coating line unless the requirements in subsection (b)(I) or (b)(2) ofthis Section are met.

I) For each coating line which applies multiple coatings, all ofwhich are subject to the same numerical emission limitation within Section 218.204(j) during the same day (e.g., all coatings used on the line are subject to 0.42 kgLfl (3.5 Ibs/gal)), the daily-weighted average YOM
content shall not exceed the coating YOM content limit corresponding to the category ofcoating used, or

3) The first notice version ofthe rule reformats Section 218/219.40] (c)(I), which changes

several internal cross references. The .first notice version, however, does not amend these

references in the appropriate locations. This omission results in references to subsections that no
longer exist (for example, the rule contains references to subsections (c)(I)(C) and (c)(I)(D),

which do not exist pursuant to the first notice format) and references to subsections that no
longer contain the pertinent information (for example, existing references to subsection (c)( I )(B)

should now reference subsection (c)(I)(A)(ii) pursuant to the first notice format). Incorrect

references appear in several fJexographic printing sections/subsections, including Sections

218/219.401 (c)( I), (c)(2), (c)(4), (c)(6), and 218/219.403. To avoid confusion, erroneous

references, and any unintended substantive changes to subsection (c), the Illinois EPA proposes

that the subsection be reformatted consistent with the 111inois EPA's original proposal.

Returning subsection (c) to its original format will resolve the issues set forth above, without

altering any substantive first notice revisions. Alternatively, if the formatting changes set forth

2

## Electronic Filing

- Received, Clerk's Office, February 17, 2010

* * * * * PC #3 * * * * *

in first notice are kept, the Illinois EPA recommends that the internal cross references be

corrected consistent with such changes.

4) In its Motion to Amend Rulemaking Proposal, the Illinois EPA proposed deleting certain

existing language in Section 218/219.404(b)(I)(B) and (d)(I)(D) in response to a request by

industryrepresentatives (See Motion to Amend Rulemaking Proposal, Item Number 6). Such

language still appears in the first notice version ofthe proposal, however. In the event that the

language was mistakenly left in the proposed rule, the Illinois EPA recommends that it be

deleted as follows:

Section 218/219.404(b)(l)(B):

B) Calculations which demonstrate that total maximum theoretical emissions of YOM from all flexographic and rotogravure printing lines at the source never exceed 90.7 Mg (100 tons) per calendar year before the application ofcapture systems and control devices. Total maximum theoretical emissions ofVOM for a flexographic or rotogravure printing source is the sum ofmaximum theoretical emissions ofVOM from each flexographic and rotogravure printing line at the

.
source. The following equation shall be used to calculate total maximum theoretical emissions ofVOM per calendar year before the application ofcapture systems and control devices for each flexographic and rotogravure printing line at the source:


### .Ep =AxB+I095(CxDxF}

where:



### .Ep = Total maximum theoretical emissions ofVOM from one flexographic or rotogravure printing line in units ofkglyear (Ibs/year);

A = Weight ofVOM per volume of solids ofthe coating or ink with the highest YOM content as applied each year on the printing line in units of kg VOMII (lbs YOM/gal) ofcoating or ink solids;

B = Total volume of solids for all coatings and inks that can potentially be applied each year on the printing line in units of I/year (gal/year). The instmment mlElter 

### method by which the owner or operator accurately

3

### Electronic Filing

- Received, Clerk's Office, February 17, 2010



## * * * * * PC #3 

## * * * * *

measured sr calculated the volume of each coating and ink as applied and the amount that can potentially be applied each year on the printing line shall be described in the certification to the Agency;

Section 2J8/2J9.404(d)(J)(D):

D) The iAslFlimeAt sr method by which the owner or operator will accurately measure <*-Calculate the volume, or weight of solids, as applicable, ofeach coating and ink

as applied each day on each printing line.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY



### BYG»;w

# ~. Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel DATED: February 

### 17, 2010

1021 N. Grand Ave. East 

### P.O. Box 19276 Springfield, 

### IL 62794-9276 (217) 782-5544

4

## Electronic Filing

- Received, Clerk's Office, February 17, 2010

* * * * * PC #3 * * * * *

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATIER OF:

REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP II CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 35 ILL. ADM. CODE 21 1,218, and 219 ) ) ) ) ) ) ) 

### ) 

### RIO-8 (Rulemaking-Air)



### CERTIFICATE OF SERVICE

I, the undersigned, an attorney, state that 

### I have served electronically the attached FIRST NOTICE COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY upon the following person:

John Therriault, Assistant Clerk Illinois Pollution Control Board James 

### R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Illinois 60601-3218

and electronically to the following persons:



### SEE ATTACHED SERVICE LIST.

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By: 

## 0>,. 11"'-

# )/d;ftdt~ Dana VetterhoffeT Assistant Counsel Division ofLega] Counsel

DATED: February 17,2010

1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (2 I 7) 782-5544

## Electronic Filing

- Received, Clerk's Office, 

## February 17, 2010

* * * * * 

## PC #3 * * * * *

Service List 

### RIO-8

Timothy 

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

Virginia Yang Deputy Legal Counsel llJinois Department ofNatural Resources One Natural Resources Way Springfield, IL 62702-i271 virginia. yang@illinois.gov

Matthew Dunn, Chief Division ofEnvironmental Enforcement Office of the Attorney General 69 W. Washington St., Suite 1800 Chicago, IL 60602 mdunn@atg.state.il.us

Katherine D. Hodge Monica 

### T. Rios Hodge Dwyer 

### & Driver 3150 Roland Ave. P.O. Box 5776 Springfield, IL 62705-5776 khodge@hddattorneys.com mrios@hddattorneys.com

Alec M. Davis General Counsel Illinois Environmental Regulatory Group 215 E. Adams St. Springfield, IL 62701 adavis@ierg.org

# A 17

# Mostardi Platt**&,~**

April 8,2010

### ~H:CEaVED CLERK'S OFFICe



## APR 09 2010

STATE OF IlliNOIS Pollutmn Control 

### Board 1520 Kensington Road, SUite 204 Oak Brook,llIinois 60523·2139 Phone 630-993-2100

fax 630-993-9017 ww\'v.mostardiplattenv.com

llIinois- Pollution Control Board John T. Therriault, Assistant Clerk James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, II. 6060 I 

# :' ORIGltv4L

# t~ RE: RACT for YOM from Group II Consumer & Commercial Products: Proposed Amendments to 35 IAC 211, 218, and 219

Dear Mr_ Therriault,
As a Chicago area consulting fIrm that provides environmental compliance assistance to several printing and coating operations within the State ofillinois, we hereby submit the following comments on the pending amendments to the Parts 211, 218, and 219 (Title 35, IAC) regulations_ We understand that the rule changes are in the final process ofapproval. We would like our comments to be included as part of the record, and hope that they are considered prior to taking final actions on the above referenced regulatory amendments_
In the proposed amendments to parts 218 and 219 there are several locations where the stated compliance date is listed as May 1,2010. We are not providing specific reference to each occurrence ofthis compliance date. Rather, this comment applies globally to each OCCurrence. We believe that the timing for the completion ofthe rule making process will most likely be after the proposed compliance date. We believe that the Board should consider an alternative compliance date. Considering the length oftime that has passed since the proposed rule making began, it may have been the intention ofthe Agency to build in

an adequate amount oftime for subject sources to comply with these rule changes. However, it appears that the rule making process will not be complete by the proposed compliance date for the various sections ofPart 218 and 219.
The adjusted date ofcompliance should allow time for sources to meet the new rule when it is fmalized. As the proposed rule amendments stand (TIlinois Register dated February 5, 2010), the sources that are subject to the various sections in the rule with a compliance date ofMay 1,2010, will have to be in compliance with the amended Parts 218 and 219 most likely the day that these rule changes become effective.
Thank you for considering these comments. Sincerely,
MOSTARDI PLATT ENVIRONMENTAL

# rc~';inS? Senior Consultant Rich Trzupek Principal Consultant Lauren Laabs Principal Consultant

# A 18

### Electronic Filing

- Received, Clerk's Office, April 26, 2010

* * * * * 

### PC #5 * * * * *

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVA1LABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP II CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS TO 351L1. ADM. CODE 211,218, and 219 ) 

### ) ) ) ) ) 

### ) ) R10-8 (Rulemaking-Air)



### NOTICE

To: John Theniault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, IlIino.is 60601·3218



### SEE ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control Board thc COMMENTS OF THE ILLlNOIS ENVJRONMENTAL PROTECTION AGENCY, a copy ofwhich is herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~-l~ Dana Vetterhoffer

. Assistant Counsel Division ofLegal Counsel

DATED: Apri126,2010

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

### Electronic Filing

- Received, Clerk's Office, April 26, 2010

* * * * 

### * 

### PC #5 * * * * *

BEFORE THE ILLINOIS POtLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY A

## vAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP 

## n CONSUMER & 

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

### ) ) 

### ) ) 

### ) ) 

### R10-8 (Rulemaking-Air)

COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

The Illinois Environmental Protection Agency ("Illinois EPA" or "Agency"), by its

attorney, respectfully submits its comments in the above rulemaking proceeding in response to

comments filed with the Illinois Pollution Control Board ("Board") on April 9, 2010, by

Mostardi PIau Envirorunental ("Mostardi Platt").

In its comments, Mostardi Platt points out that the compliance date set forth in the Illinois

EPA's rulemaking proposal, May 1,2010, will most likely occur before the proposal is adopted
by the Board. The Illinois EPA agrees. Consequently, the Illinois EPA proposes that the
compliance date for the proposed revisions be changed from May 1,2010, to August I, 2010.

As long as second notice begins near the beginning ofMay and ends mid-June, an extension of

the deadline to August I should allow sufficient time for the rule to be finalized. It 

### is important

that the deadline not be extended further, as the ozone season only runs from April through

October.

Such an extension ofthe compliance date should also provide sources enough time to

achieve compliance with the proposed revisions. Potentially affected sources have been on

'notice regarding the Agency's proposal since the rule was initially filed on July 9,2009 (and the
Agency posted a draft of the proposed rule on its website on November 5, 2008, almost a year

### Electronic Filing

- Received, Clerk's Office, April 26, 2010

* * * * * 

### PC #5 * * * * *

and a half ago). Sources have therefore had adequate opportunity to make any changes

necessary to comply with the Agency's proposal. Indeed, a national printers group has alrcady

been in contact with Agency staff and is preparing information to aid Illinois sources in

complying with this rule.

A short extension ofthe compliance date to August 1,2010, should provide sufficient

time both for the rule to be adopted by the Board, as well as for sources to reach compliance.

Respectfully submitted,



### lLLlNOIS 

### ENVIRONMENTAL PROTECTION AGENCY

By:

# crJ:n;Wtefi£~ Assistant Counsel Division ofLegal Counsel 

### DATED: April 26, 2010

1021 N. Grand Ave. East 

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

### Electronic Filing

- Received, Clerk's Office, April 26, 2010

* * * * * 

## PC #5 * * * * *

BEFORE THE 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 21 I, 218, and 219 

### ) ) ) ) ) ) ) 

### ) 

### RIO-8 (Rulemaking-Air)

CERTIFICATE OF SERVICE

I, the undersigned, an attorney, state that I have served electronically the attached COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY upon the following person:

John Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph, Suite 11-500 Chicago, Illinois 6060 1- 32 I8

and electronically to the following persons:

SEE ATTACHED SERVICE UST.

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By:C7h.i:lQ, Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel

DATED: April 26, 2010

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

### Electronic Filing

- Received, Clerk's Office, April 26, 2010

* * * * * 

### PC #5 * * * * *

Service List R10-8

Timothy 

### J. Fox Hearing Officer JIlinois Po.1!ution Control Board 100 

### W. Randolph SI., Suite 11-500 Chicago, IL 6060 I foxt@ipcb.state.il.us

Virginia Yang Deputy Legal Counsel Illinois Department ofNatural Resources One Natural Resources Way Springfield, lL 62702-1271 virginia.yang@illinois.gov

Matthew Dunn, Chief Division ofEnvironmental Enforcement Office ofthe Attorney General 69 

### W. Washington St., Suite 1800 Chicago, IL 60602 mdunn@atg.state.il.us

Katherine D. Hodge Monica T. Rios Hodge Dwyer & Driver 3150 Roland Ave. P.O. Box 5776 Springfield, IL 62705-5776 khodge@hddattomeys.com mrios@hddattorneys.com

Alec M. Davis General Counsel ll1inois Environmental Regulatory Group 215 E. Adams SI. Springfield, IL 62701 adavis@ierg.org

# A 19ILLINOIS POLLUTION CONTROL BOARD May 6, 2010

IN THE MAITER OF: ) ) REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP II CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE211, 218, and 219 )

Proposed Rule. Second Notice. RIO-08 (Rulemaking

- Air)

OPINION AND ORDER OF THE BOARD (by A.S. Moore):

On July 9,2009, the Illinois Environmental Protection Agency (Agency or Illinois EPA) filed a proposal under the rulemaking provisions of Sections 27, 28, and 28.2 ofthe Environmental Protection Act (Act). See 4151LCS 5/27,28,28.2 (2008). On January 7,2010, the Board adopted its first-notice opinion and order. See 34 

### Ill. Reg. 1766, 1791, 1941 (Feb. 5, 2010). Generally, the Board proposed air pollution regulations to reduce emissions of volatile organic material (VOM) from Group II Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above in order to meet Illinois' obligations under the Clean Air Act (CAA). Group II products include industrial cleaning solvents, flat wood paneling coatings, flexible packaging printing materials, lithographic printing materials, and letterpress printing materials.

In this opinion, the Board first reviews the procedural history ofthis rulemaking before briefly reviewing federal regulation ofVOM emissions. The Board then summarizes four firstnotice comments. The Board then addresses the issues ofpotentially affected sources, projected emission reductions, and technical and economic considerations. Next, the Board summarizes its second-notice proposal on a section-by-section basis. The Board concludes by adopting a proposal for second-notice review and directs the Clerk to file the proposal with the General Assembly's Joint Committee on Administrative Rules (lCAR). The order following the opinion then provides the proposed amendments.

PROCEDURAL HISTORY

On July 9, 2009, the Agency filed a rulemaking proposal to amend Parts 211,218, and 219 ofthe Board's air pollution regulations (Prop. 211, Prop. 2 

### J8, and Prop. 219, respectively). The Agency filed the proposal under the general rulemaking provisions of Sections 27 and 28 of the Act. See 415 ILCS 5/27, 28 (2008). Among other documents, a Statement of Reasons (SR) and a Technical Support Document (TSD) accompanied the proposal. The Agency also filed a motion for waiver of copy requirements and a motion for expedited review. In an order dated August 6, 2009, the Board accepted the Agency's proposal for hearing, granted the Agency's motion for waiver of copy requirements, and denied the Agency's motion for expedited review.2

In a letter dated August 6, 2009, the Board requcsted that the Department ofCommcrcc and Economic Opportunity (DCEO) conduct an economic impact study ofthc Agcncy's rulemaking proposal. See 415 ILCS 5/27(b) (2008). DCEO has not rcspondcd to thc Board's rcquest.

In an order dated August 12,2009, thc hearing officer scheduled a first hearing to begin

on October 27, 2009, in Edwardsvil]e and a second hearing to begin December 8, 2009, in Chicago. The order directed participants wishing to pre-file testimony for the first hearing to do

so no later than Scptember 15,2009. The order also directed participants to pre-filc questions based on pre-filed testimony no later than September 29, 2008. Finally, the order directed participants whosc pre-filcd testimony elicited pre-filed questions to pre-file written answers to those questions no later than October 13,2009. The order also provided that pre-filing deadlines for the second hearing would be set at a later date,

On September ]4,2009, the Agency prc-fiIed the testimony ofMr. David E. Bloomberg and a motion to amend its rulemaking proposal (Mot. Amend 1), No other participant pre-filed testimony for the first hearing, and no participant pre-filed questions based on Mr. Bloomberg's pre-filed testimony, No participant filed a response to the Agency's motion to amend its rulemaking proposal. In an order datcd October 15,2009, the Board granted the Agency's motion to amend.

The first hearing took place as scheduled on October 27, 2009, and thc Board receivcd the transcript ofthe first heating (Tr.l) on October 29, 2009, During the first hearing, thc hearing officer admitted into the record one exhibit, the pre-filed testimony ofMr. Bloomberg (Bloomberg Test.),

In an ordcr dated October 28,2009, the hearing officcr directed participants wishing to pre-file tcstimony for the second hearing to do so no later than November 

### J7,2009, See Tr.l at 25. The order also directed participants to pre-file questions based upon pre-filcd testimony no later than December 3, 2009, Id,' No participant pre-filed testimony or questions for thc sccond hcaring,

On December 7, 2009, the Agency filed a second motion to amend its rulemaking proposal (Mot. Amend 2),

The second hcaring took place as scheduled on Deccmber 8, 2009, and the Board received the transcript ofthe second hcaring (Tr.2) on Dccember 11,2009, No participant offered testimony at the second hearing. See Tr.2 at 7. Regarding the Board's rcquest that DC EO conduct an cconomic impact study ofthe Agency's proposal, no participant wished to offer testimony or comment. See Tr.2 at 8, In an order dated December 9, 2009, the hearing officer set a deadline ofDecember 28,2009, to file post-hearing comments. See 35 IlL Adm, Codc 102.J08(b).

### 3

On Decembcr 28, 2009, thc Board received a post-hearing commcnt from Mr. Brucc Mcerman, Senior Environmental Consultant, Mostardi Platt Environmental (Mostardi Platt) (PC I). On January 19, 2010, Mr. Mecrman filed a second comment (PC 2), which withdrew his previous comment.

On January 7, 2010, the Board adopted its first-noticc opinion and order. 

### See 34 Ill. Adm. Code 1766, 1791, 1941 (Fcb. 5, 20 I0). Among other action, that opinion and order granted the Agency's second motion to amend the rulemaking proposal.

On February 17,2010, the Agency filed a first-notice commcnt (PC 3). On April 9, 20] 0, the Board received a comment signed by three consultants with Mostardi Platt (PC 4). On April 26, 2010, the Agency filcd an additional comment (PC 5). On April 30, 2010, the Agency submitted a supplemental comment (PC 6).

BACKGROUND OF FEDERAL YOM REGULATION

When it filed its rulemaking proposal, the Agency stated that the proposal intended to satisfy Illinois' obligation undcr the CAA to submit a State Implementation Plan (SIP) addressing requirements for sources ofVOM emissions in areas designated as nonattainment with the National Ambicnt Air Quality Standard (NAAQS) for ozonc. SR at I, citing 42 U.S.C. 

### §§ 7502, 7511 a.

The Agency characterized YOM 1 as "a primary precursor to the formation ofgroundIcvel ozone," which forms whcn YOM reacts with oxides ofnitrogen in the atmosphere in thc prcscncc of sunlight. SR at 2-3, citing 71 Fed. Reg. 58746 (Oct. 5, 2006); see TSD at 1-2. In 1997, thc Unitcd States Environmcntal Protection Agency (USEPA) reviscd thc NAAQS for

ozone by instituting an 8-hour standard. Id. at 3, citing 62 Fcd. Rcg. 38856 (July 18, 1997). Two Illinois arcas, Chicago and St. LouisfMetro East, have been designated as modcrate

non attainment areas for thc 8-hour ozonc standard 2 SR at 3.

Thcse nonattainment designations trigger CAA requirements "for adopting regulations that reduce emissions sufficiently to dcmonstrate attainment ofthe standard." Id. at 4, citing 42 U.S.c. 

### § 7502(c)(I); see Bloomberg Test at 3. Specifically, the Agcncy claimed that the CAA requires Illinois "to submit VOC regulations constituting RACT [reasonably available control technology] for Group II Consumer and Commercial Product Categories in ozone nonattainment

areas classified as moderate and above." SR at 5, citing 42 U.S.c. 

### §§ 7502(c)(I), 751Ia(b)(2);

see TSD at I. The Agency defined RACT "as the lowest emission limitation that a particular

1 The Agency stated that YOM and volatile organic compounds (VOC) are "effectively the same" as one another. SR at I.

2 The Chicago nonattainment area includes the following jurisdictions: Cook, DuPagc, Kane, Lake, McHenry, and Will Counties, Goose Lake and Aux Sable Townships in Grundy County, and Oswego Township in Kendall County. SR at 3, citing 40 C.F.R. 81.314; see TSD at I. The St. LouisfMetro East nonattainment arca includes the following Illinois counties: Jersey, Madison, Monroe, and St. Clair. SR at 3, citing 40 C.F.R. 81.314; see TSD at I.4

source can meet by applying a control technique that is reasonably available considering technological and economic feasibility." SR at 5, citing 44 Fed. Reg. 53762 (Sept. 17, 1979); see TSD at I, Bloomberg Test. at 3. The Agency stated that "Illinois was required to submit its SIP revisions by October 5, 2007." SR at 5.

The Agency stated that the CAA requires USEPA to "conduct a study ofthe emissions of VOC into the ambient air from consumer and commercial products in order to determine their potential to contribute to ozone levels which violate the ozone NAAQS and to establish criteria for regulating emissions ofVOC from those products." SR at 2, citing 71 Fed. Reg. 58746 (Oct. 5,2006). The Agency further stated that the CAA provides that "[t]he Administrator shall list those categories ofconsumer or commercial products that the Administrator determines, based

on the study, account for at least 80 percent ofthe VOC emissions

... from consumer or commercial products in areas that violate the NAAQS for ozone" and separate those categories into groups. SR at 3, citing 42 U.S.c. 

### § 75 II b(e)(3)(A).

The Agency claimed that "[t]he CAA requires that USEPA then either regulate VOC emissions from such categories or issue a CTG [control techniques guideline] in lieu of a national regulation ifthe Administrator determines that such guidance will be substantially as effective as regulations in reducing emissions ofVOC which contribute to ozone levels in ozone nonattainment areas." SR at 4, citing 42 U.S.c. § 7511 b(e)(3)(C). The Agency stated that "CTGs provide states with recommendations regarding what types ofcontrols could constitute RACT for VOCs for the applicable source categories." SR at 4, citing 71 Fed. Reg. 58745, 58747 (Oct. 5,2006). The Agency claimed that "[s]tates must either adopt regulations to implement the recommendations in the CTG or adopt alternative approaches that constitute RACT, either ofwhich must be submitted to the USEPA for review and approval as part ofthe SIP process." SR at 4, citing 71 Fed. Reg. 58745, 58747 (Oct. 5, 2006).

The Agency stated that, instead of national regulations controlling VOC emissions, "USEPA issued final CTGs for Group II Consumer and Commercial Product Categories" on October 5, 2006. SR at 4. The Agency further stated that, in developing the CTGs, "USEPA evaluated the sources of YOM emissions from the applicable industries, the available control possibilities to address the associated emissions, and the cost of such control measures." TSD at I. The Agency indicated that "USEPA required that states submit SIP revisions in response to the CTGs within one year." Id., citing 71 Fed. Reg. 58745-53 (Oct. 5, 2006). Specifically, the Agency stated that JIlinois must revise its SIP to include RACT for sources ofVOM emissions covered by a USEPA CTG issued between November 15, 1990 and the date of attainment. SR at 2, citing 42 U.S.c. 

### § 7511a(b)(2); see TSD at 1, Bloomberg Test. at 3.

The Agency stated that "Illinois is required to submit these SIP revisions before the USEPA can re-designate the Chicago and Metro East nonattainment areas as attaining the 1997

ozone NAAQS, regardless ofwhether the VOC reductions obtained by the SIP revisions are actually nccessary to achieve attainment ofthe NAAQS." SR at 6, citing Wall v. USEPA, 265 F.2d 426, 433, 440-42 (6th Cir. 2001); 42 U.S.C. 

### § 7407(d)(3)(E). The Agency noted that, on July 2,2007, it "submitted to the USEPA an attainment demonstration for the Metro East nonattainment area for the 1997 8-hour ozone NAAQS." SR at 7. The Agency further noted that, on March 19,2009, it submitted an attainment demonstration for the Chicago nonattainment

### 5

area. 

### ld. The Agency argued that "[t]hese areas cannot be re-designated to attainment of 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." 

### ld. The Agency claimed that its proposal seeks "to implement the recommendations contained in the CTGs to the extent that such recommendations are consistent with, and impose stricter requirements than, existing regulations." 

### ld.

The Agency also noted that USEPA recently strengthened the eight-hour ozone standard. SR at 7, citing 73 Fed. Reg. 16436 (Mar. 27, 2008); 

### see TSD at I. The Agency considered it "likely" that areas designated as nonattainment for the current standard will be designated nonattainment for the revised standard. SR at 7. The Agency argued that, "[w]hile attainment of the revised standard is not the purpose ofthis rulemaking, it should be noted that any reduction in VOM emissions in the nonattainment areas resulting from these proposed amendments will likely help Illinois achieve the revised NAAQS." 

### ld.; see TSD at I.

SUMMARY OF FIRST-NOTICE COMMENTS

Agency (PC 3)

On February 17, 20 I 0, the Agency filed a first-notice comment addressing four issues. First, the Agency recommended inserting the word "at" for clarification of proposed Section 218.187(a)(1). PC 3 at 1. Specifically, the Agency proposed that the first sentence ofthat subsection provide that, "[e]xcept as provided in subsection (a)(2) ofthis Section, the requirements ofthis Section shall apply to all cleaning operations that use organic materials at

sources that emit a total of6.8 kg/day (15 Ibs/day) or more ofVOM trom cleaning operations at the source, in the absence of air pollution control equipment." 

### ld.

The Board notes that its first-notice opinion and order includes this term (Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions from Group 

### Jl Consumer and Commercial Products: Proposed Amendments to 35 

## m. Adm. Code 21 I, 218, and 219, RIO-8, slip op. at 77 (Jan. 7,2010», although it is not reflected in first-notice publication in the 

### Illinois Register (34 III. Reg. 1806 (Feb. 5,2010». Accordingly, the Board readily concurs with the Agency's recommendation and amends proposed Section 217.187(a)(1)

as suggested. 

### See PC 3 at 1.

Second, the Agency's comment notes that, "[i]n Section 218.205(b)(1), the first notice version ofthe proposal deletes a slash mark between 'kg' and 

### 'I' and inserts an open parenthesis that break up the unit of measurement." PC 3 at 2. The Agency specifically proposes the following amendment for subsection (I):

I) For each coating line which applies multiple coatings, all ofwhich arc subject to the same numerical emission limitation within Section 218.2040) during the samc day, 

### (e.g, all coating used on the line are subject to 0.42 kglfl {3.5 Ibs/gal)), the daily-weighted average YOM
content shall not exceed the coating YOM content limit corresponding to the category ofcoating used, or

... ld.

### 6

The Board notes that its first-notice opinion and order is consistent with the Agency's
comment (Reasonably Available Control Technologv (RACT) for Volatile Organic Material Emissions from Group II Consumer and Commercial Products: Proposed Amendments to 35 III. Adm. Code 211, 21S, and 219, RI O-S, slip op. at 9S (Jan. 7, 20 I0)), Accordingly, the Board

concurs with the Agency's proposal and amends proposed Section 2IS.205(b)(]) as published for first notice (34 Ill. Reg. IS31 (Feb. 5, 2010)). 

### See PC 3 at 2,

Third, the Agency notes that "[t]he first notice version ofthe rule reformats Section 2ISI219.401(c), which changes several internal cross references," PC 3 at 2. The Agency argues that "[t]he first notice version, however, does not amend these references in the appropriate locations." Jd. The Agency claims that this failure to amend

results in references to subsections that no longer exist (for example, the rules contains references to subsections (c)(I)(C) and (c)(I)(D), which do not exist pursuant to the first notice format) and references to subsections that no longer contain the pertinent information (for example, existing references to subsection (c)(I)(B) should now reference subsection (c)(I)(A)(ii) pursuantto the first notice format). Jd.

The Agency also claims that "[i]ncorrect references appear in several flexographic printing sections/subsections, including Sections 21S/219.401(c)(I), (c)(2), (c)(4), (c)(6), and 

### 2ISI219.403," Id. The Agency suggests that Section 21S/2I9.401(c) follow the format in its original proposal "[t]o avoid confusion, erroneous references, and any unintended substantive changes to subsection (c)." Id. In the event that the Board maintains the first-notice reformatting, the Agency "recommends that the internal cross references be corrected consistent with such changes," Id, at 2-3.

The Board notes that its first-notice opinion and order is consistent with the Agency's original rulemaking proposal. 

### See Reasonably Available Control Technologv (MCT) for Volatile Organic Material Emissions from Group Jl Consumer and Commercial Products: Proposed Amendments to 35111. Adm. Code 21 I, 2]S, and 219, RIO-S, slip op, at 12S-29 (Jan, 7, 20 I 0); Prop. 21S at 62-63; Prop. 219 at 61-62. The Board further notes that first-notice publication reflects a re-formatting of Section 21S/2 I9.40 I(c)(I), 34 llJ. Reg. IS66-67, 2013 (Feb. 5, 2010), Although it notes the Agency's comment on this issue, the Board finds that this re-formatting clarifies the subsection. Accordingly, the Board in its order below corrects internal

cross references to Section 

### 2181219.40 I(c)(I) so that they are consistent with this re-formatting,

Fourth, the Agency notes that its motion to amend its rulemaking proposal "proposed deleting certain existing language in Section 2 I 8/219.404(b)(I )(B) and (d)(1 )(0) in response to a request by industry representatives," PC 3 at 3, citing Mot. Amend I at 4-5 ('iI6) (deleting references to measurement by instruments). The Agency states that "[s]uch language still appears in the first notice version ofthe proposal, however." PC 3 at 3; 

### see 34111. Reg. 1872-73, 1876, 20 I9-20, 2023 (Feb, 5, 20 I0). The Agency thus recommends a specific amendment to the key to the equation in proposed Section 2IS/219.404(b)(1 )(B):7

B Total voh.)me of sol ids for all coatings and inks that can potentially be applied each year on the printing Iine in units of lIyear (gal/year). The iAslrul11enl anEi/er method by which the owner or operator aceurately measureEi er calculated the volume ofeach coating and ink as applied and the amount that can potentially be applied each year on the printing line shall be described in the certification to the Agency. PC 3 at 3-4.

The Agency also recommends a specific amendment to subsection 218/21 9.404(d)( I)(0): "The iflstrulHenl or method by which the owner or operator will accurately measure or calculate the volume, or weight of solids, as applicable, of each coating and ink as applied each day on each printing line." PC 3 at 4.

The Board notes that its first-notice opinion and order is consistent with the Agency's proposed amendments (Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions from Group II Consumer and Commercial Products: Proposed Amendments
to 35 III. Adm. Code 21 1. 218, and 219, RIO-8, slip op. at 134, 137,250,252 (Jan. 7, 2010)). Accordingly, the Board concurs with the Agency's recommendations and amends proposed Sections 2I8/219.404(b)(1 )(B) and (d)(1 )(0) as published for first notice (34 Ill. Reg. 1873-73, 1876,2019-20,2023 (Feb. 5, 2010)). See PC 3 at 2.

Mostardi Platt Environmental Consultants (PC 4)

On April 9, 2010, the Board received a comment on behalfofMostardi Platt signed by three consultants: Timothy Kinsley, Senior Consultant; Rich Trzupek, Principal Consultant; and Lauren Laabs, Principal Consultant. The comment indicates that Mostardi Platt is "a Chicago

area consulting firm that provides environmental compliance assistance to several printing and coating operations within the State of Illinois

.... " PC 4 at 1.

The comment notes that the Agency's proposed amendments to Parts 218 and 219 include a number ofprovisions establishing a compliance deadline of May I, 2010. PC 4 at 1. The comment claims that "the sources that are subject to the various sections in the rule with a compliance date ofMay 1,2010, will have to be in compliance with the amended Parts 218 and 219 most likely the day that these rule changes becomes effective." Id.

Although the comment acknowledges that the Agency may have intended to allow sufficient time for affected entities to comply with the proposed rules, it suggests that final adoption ofthe rules cannot take place by the proposed compliance deadline ofMay 1,2010. Id. The comment claims that "the Board should consider an alternative compliance date." Id. Although the comment does not specifically propose one, it argues that an "adjusted date of compliance should allow time for sources to meet the new rule when it is finalized." Id.

Agency (PC 5, PC 6)

On April 26, 2010, the Agency responded to the comment filed on behalfofMostardi Platt. First, the Agency agrees that its proposed compliance deadline ofMay 1, 20 I0, "will most likely occur before the proposal is adopted by the Board." PC 5 at I. The Agency then8

"proposes that the compliance date for the proposed revisions be changed from May 1,2010, to August 1, 20 I0." ld. The Agency argucs that this 3-month extension "should allow sufficient time for the rule to be finalized." ld. The Agency further argues that "[i]t is important that the deadline not be extended further, as the ozone season only runs from April through October." ld.

The Agency also claims that such a 3-month extension should "provide sources enough timc to achieve compliance with the proposed revisions." PC 5 at 1. The Agency notes that it first posted a draft of its proposed regulations on its Web site on November 5,2008, nearly 18 months ago. 

### ld. The Agency further notes that "[p]otentially affected sources have been on notice regarding the Agency's proposal since the rule was initially filed on July 9, 2009

.... " ld. The Agency argues that "[s]ources have therefore had adequate opportunity to make any changes necessary to comply with the Agency's proposal." Jd. at 2. The Agency states that it has already communicated with a national printers group "preparing information to aid Illinois sources in complying with this rule." 

### ld.

On April 30, 2010, the Agency submitted to the Board a supplemental comment noting that the Agency had recommended extending the compliance deadline to August 1, 2010. PC 6
at I; see PC 5 at ]. The Agency stated that, "while May I is the compliance date for the majority ofthe rule revisions, the compliance date for the industrial cleaning solvent section (218/219.187) is April I, 2011." PC 6 at 1. The Agency sought to clarify "that the Agency's
comment was only intended to address references to the May I, 201 0, compliance date. In other words, the Agency is not recommending that the 2011 compliance date for solvents be shortened." ld. Accordingly, the Board concurs that the compliance deadlines ofMay 1, 2010 should be extended to August I, 2010, while the compliance date for the industrial cleaning solvent provisions at Section 218/219.187 should remain April 2, 2011.

AFFECTED SOURCES AND PROJECTED EMISSIONS REDUCTIONS

The Agency stated that its proposed regulations apply only within the Chicago and Metro East regions, the state's two areas designated as nonattainment for the eight-hour ozone NAAQS. SR at 9, citing 40 C.F.R. 81.3 I4. Specifically, the Agency stated that, within those two areas, the regulations "are generally expected to affect both new and existing sources that are covered by a Group II CTG" and that meet the proposed applicability criteria. SR at 9. In Appendix B to its TSD, the Agency listed 136 potentially affected sources itemized by category and then by NAA within those categories. TSD at 25-28 (Appendix B).

The Board addresses the record with regard to potentially affected sources and projected emission reductions on a category-by-category basis in the following subsections.

Industrial Cleaning Solvents

The Agency noted USEPA's estimate that 130 sources in Illinois' two nonattainment

areas emit a total of 15 pounds per day (PPD) or more of YOM from cleaning operations at the

source. TSD at 14 ('lf4.4), 20 ('lf6.4); see Prop. 218 at 4 (proposed Section 218.187(a)(I) addressing applicability). Responding to a question at the first hearing, the Agency indicated that its proposed regulations apply to "anybody who uses this amount of industrial cleaning9

solvents" and not only to the operations included in Group II Consumer and Commercial Product categories. Tr.1 at 10. The Agency argued that, because it does not generally seek specific information on solvent use and because that use may not be subject to a current permit, "there

was no good way to make an estimale as to who might be affected

... " Jd. at I I. Accordingly, the Agency stated that its "Appendix B does not list specific sources that are potentially affected by this rulemaking." Jd; 

### see TSD at 25-28 (Appendix B). The Agency stated that it intends to communicate with small business owners, industry representatives, and DC EO through the process of considering and implementing these proposed rules. Tr.1 at I I.

The Agency stated that baseline emissions from the 130 sources noted by USEPA are estimated to be 2293 MG/yr (2528 tpy) of YOM. TSD at 14, 20. The Agency further stated that this estimate includes "degreasing operations that are already impacted by existing state regulations and will not gain any further reductions." Jd. The Agency argued that "[i)t is not reasonably practicable to estimate emission reductions for the other impacted sources under the industrial clean-up solvent rule, as any source in either NAA that uses cleaning solvent is potentially affected, depending on the source's usage level." TSD at 20-21; 

### see Tr.1 at 9-11. The Agency also claimed that potentially affected sources may already be using solutions that comply with the proposed regulations. 

### !d. at 21. Accordingly, "the Agency believes that the environment will sec actual YOM emission reductions due to these proposed regulations, but calculation of such emission reductions cannot be accomplished without detailed information from every affected source." TSD at 2 I.

Flat Wood Paneling Coatings

The Agency's search ofthe 2005 source inventory maintained by its Bureau of Air indicated that four sources, all in the Chicago NAA, would become subject to the proposed flat wood paneling coating regulations. TSD at 21 (§6.5). The Agency stated that "[0)ne ofthese four sources would appear to fall below the proposed applicability threshold" and that "[t)he other three total 0.09 TPD of YOM emissions." Jd. The Agency claimed that the CTG projects YOM emission reductions averaging 60 percent from interior paneling and tileboard manufacturing. Jd. Stating that the Illinois sources appear to fall within these two categories, the Agency "estimates a YOM reduction of 0.05 TPD in the Chicago NAA

.... " Jd

Flexible Packaging Printing Lines

The Agency stressed difficulties in estimating emission reductions in this category. First, the Agency stated that "the Illinois source database does not generally specify the type of substrate being used by a flexographic or rotogravure printing operation." TSD at 20 (§6.3). The Agency further stated that the data also do not "specify the date of original installation ofthe printing press or the associated control device." Jd. Accordingly, the Agency listed as a potentially affected source each existing flexographic or rotogravure printing facility in the Illinois inventory and exceeding the proposed applicability threshold. Jd.; 

### see id. at 27-28 (Appendix B).

The Agency emphasized, however, that "all sources but one using flexographic or rotogravure printing of any type are already achieving greater control efficiency than required by10

the proposed regulation." TSD at 20. The Agency stated that the single remaining source "is required by its perm it to achieve 60 percent control efficiency, but will now need to achieve 65 percent." fd. The Agency claimed that this represcnts a reduction of 0.03 TPO in permitted emissions, "but a 0.0 I TPO rcduction according to em issions information in the inventory." 

### ld.

The Agency expected negligible emission reductions from proposed new ink limits. TSO
at 20. The Agency stated that, "[w]hile the inventory does not provide information regarding thc

use ofcompliant inks, it has becn the Agcncy's cxperience that sources printing on flexible packaging have had difficulty with the use ofcompliant YOM inks on such substrates." 

### ld. The Agency reported that "[s]ources cither relied on add-on controls or switched to water-based inks that should meet the newly proposed requirements as well as the existing ones." !d.

Regarding proposed work practice standards for cleaning materials, the Agency argued that they "do not lend themselves to a calculation of emission reductions." TSO at 20. Thc Agency claimed that actual YOM emission reductions will result from requiremcnts such as "storing ofcleaning materials and used shop towels in closed containers, as well as conveying cleaning materials in closed containers or pipes

.... " !d. The Agency argued, however, that "calculation of such emission rcductions cannot be accomplished without detailed infonnation from every affected source

-- both before and after such changes are made." fd.

Lithographic Printing Lines

The Agency first stated that it "does not expect any additional [emission] reductions from increasing the required control efficiency for heatset web lithographic printers from 90 to 95 percent, becausc that change will not affect existing control devices." TSD at 18 (§6.1). Thc Agency did expect "some small YOM reductions related to the addition of fountain and cleaning solution requircments for sources with IS PPO or more ofemissions." 

### ld. The Agency claimed that it is difficult to estimate these reductions because it is not possible to idcntify sources that may be excluded from thc proposed requirements. 

### ld. The Agency elaborated that its source invcntory "does not track information such as the number of gallons of cleaning solution used, the size of sheet-fed presses, or the fountain solution reservoir volume

.... " 

### ld.

The Agency's search ofthe 2005 source inventory maintained by its Bureau of Air indicated that 98 Iithographic printing sources in the Chicago NAA and three in the Metro East NAA have YOM emission over 15 PPO. TSD at 18. The Agency reported that 66 of the sources in thc Chicago NAA and all three ofthe sources in the Metro East NAA emit less than 100 PPO and are potentially affected by thc proposed regulations. 

### ld.

For these potentially affected sources, the Agency estimated potential cmission reductions attributable to reformulation of fountain solutions at between 25% and 90% for smaller sources. TSD at 19. Because this estimate is based on a 1993 draft CTG, and because the current CTG refers to steps reducing the YOM content offountain solutions, the Agency relied on the 25% estimate in calculating reductions. 

### ld. The Agency argued that "[c]Ieaning solutions can be calculated as a straight 30% reduction, since the regulation requires reformulation such that they cannot contain more than 70% YOM. " 

### ld. With regard to cleaning solutions emissions, the Agency claimed that they "make up a lower percentage of emissions

### 1I

compared to fountain solutions, ranging up to approximately 50% at certain facilities." Jd. The Agency argued that, "[a]ssuming that almost 50% ofnon-ink emissions come from cleaning solutions, which have 30% reduction, it is safe to use a 25% overall emission reduction to cover all YOM originating from the source." Jd.

The Agency stated that total YOM emissions from the 66 potentially affected sources in the Chicago NAA equal 1.455 TPD. TSD at 19. Accordingly, a 25% reduction represents 0.36 TPD of YOM. Jd. The Agency further stated that, in the Metro East NAA, a 25% reduction from total emissions of 0.0295 TPD represents a reduction of0.007 TPD. Jd.

Letterpress Printing

Because the Agency believed that there are no heatset web letterpress printing operations in the two NAAs, it expected no emission reductions from add-on controls for this category. TSD at 19 (§6.2). The Agency's search ofthe 2005 source inventory maintained by its Bureau ofAir indicated that there are two sources in the Chicago NAA using letterpress printing. Jd. The Agency stated that 

### "[0]nly one of these sources appears to emit more than 15 PPD from such operations, with less than 0.02 TPD ofYOM, including emissions from the letterpress as well as other printing operations." Jd. Thc Agency argued that, "[e]ven if all ofthe emissions originated from letterpress cleaning solutions, which are to be reduced by 30 percent, thc resulting reduction would be 0.005 TPD. !d. Accordingly, the Agency expccted only "negligible" emission reduction from proposed regulations for this category. Jd

TECHNICAL FEASIBILTY AND ECONOMIC REASONABLENESS

Technical Feasibility

Particularly in its Tcchnical Support Document, thc Agency addressed various approaches to controlling YOM emissions from Group II product categories. See TSD at 7-12 (Technical Feasibility of Controls). The Agency argued that "[a]ffcetcd sources can mcct the requirements in the proposed amendments through a number of readily available control techniques." SR at 9. In the subsections below, the Board addresses the record on the issue of thc tcchnical feasibility ofthose techniqucs.

Industrial Cleaning Solvents

Thc Agency noted the recommendation ofthe CTG that sources emitting more than 15 PPD ofYOM through industrial cleaning comply with various rcquirements. TSD at 10 (§3.4), citing Control Techniqucs Guidelines: Industrial Cleaning Solvents, Unitcd States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. The Agency stated that the various cleaning activities "use a multitude ofdifferent solvents with different styles ofapplications." TSD at 10. The Agency proposed regulations covering "a wide range ofproducts that remove contaminants from parts, products, tools, machinery, and other work production areas." Jd. The Agency stressed work practices, solvent substitution, and controls as the chieftcchniques for reducing YOM emissions in this category. Jd. at 10-11; SR at 10.12

Work Practices. The Agency indicated that solvent management practices can reduce YOM emissions. TSD at 10. The Agency stated that these practices "include keeping solvent containers and used applicators covered; properly storing and disposing of spent solvents and used cleaning rags; minimizing air circulation around all cleaning operations; and implementing equipment practices that reduce emissions, e.g., leak detection and repair practices." Jd.; see Prop. 218 at 9 (proposed Section 218.187(d)), Prop. 219 at 8 (proposed Section 219.187(d)).

Alternate Control. The Agency stated that add-on controls, equipment modification, and changing cleaning methods all can reduce YOM emissions. TSD at 11. The Agency further stated that "[t]he CTG recommends an overall control efficiency of 85 percent rcduction in emissions of YOM, which is reflected in the proposed rule." Jd.; see Prop. 218 at 8 (proposed Section 2l8.187(b)(3)), Prop. 219 at 8 (proposed Section 219.1 87(b)(3)).

Solvent Substitution. The Agency noted that the CTG recommends the use of low vapor pressure solvents because "the slower evaporation reduces the amount of YOM released into the atmosphere." TSD at 1 I. The Agency stated that its proposal reflects the recommended limit of 8 mm Hg at 20 degrees Celsius in place of 50 grams ofYOM per liter ofcleaning material. Jd.; see Prop. 218 at 8 (proposed Section 218.1 87(b)(2)), Prop. 219 at 8 (proposed Section 219.187(b)(2)).

The Agency claimed that sources can also reduce YOM emissions through the use of low-YOM or no-YOM solvents. TSD at 10. The Agency noted that "[t]he CTG recommends a content limit of 50 grams YOM per liter (0.42 Ib/gal) ofcleaning material for those industries that are not already covered, or to be covered, by a CTG." !d, citing Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. Specifically, the Agency stated that the CTG proposes to exclude "certain categories from the cleaning regulations, as these categories already have or will have their own recommended work practices and limitations." TSD at II. The Agency further stated that

[t]hese 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 packaging printing materials; lithographic printing materials; letterpress printing materials; fiberglass boat manufacturing materials; and miscellaneous industrial adhesives." Jd., see Prop. 218 at 5-6 (proposed Section 218.187(a)(2)(B)), Prop. 219 at 4-5 (proposed Section 219.1 87(a)(2)(B)).

The Agency also stated that, as a result ofdiscussions with industry, other states, and USEPA, it proposed to add additional "exemptions and higher YOM content limits for certain specific cleaning activities." TSD at 10. The Agency suggested that it offers these additional exemptions for categorics that may not be able easily to meet proposed YOM content limits. Jd. at 11. These exemptions13

include electrical and electronic components; precision optics; numismatic dies; stripping ofcured inks, coatings, and adhesives; cleaning of resin, coating, ink, and adhesive mixing, molding, and application equipment; research and development laboratories; medical device or pharmaceutical manufacturing; and performance or quality assurance testing of coatings, inks, or adhesives. Further exclusion recommendation include cleaning of paper-based gaskcts and clutch assemblies; cleaning of adhesive application equipment used for thin metal laminating; touch-up cleaning on circuit boards; cleaning ofcoating and adhesive application processes utilized to manufacture transdermal drug delivery product using less than three gallons per day of ethyl acetate; cleaning of application equipment used to apply coatings on satellites and radiation effect coatings; cleaning ofapplication equipment used to apply solvent-borne fluoropolymer coatings; cleaning of ultraviolet or electron beam adhesive application; and cleaning of electrical cables. [d. at 11-12; 

### see Prop. 218 at 6-7 (proposed Section 218. I 87(a)(2)(C)), Prop. 219 at 5-6 (proposed Section 219.187(a)(2)(C).

Flat Wood Paneling Coating Lines

The Agency stated that the CTG refers to three options for controlling YOM emissions from flat wood paneling coating operations: material reformulation, add-on controls, or work practices. TSD at 12 (§3.5); SR at 10.

Material Reformulation. The Agency stated that refonnulation involves replacing highYOM coatings with low- YOM coatings. TSD at 12. Citing the CTG, the Agency argued that "water-based coatings 'are generally available' and 'can lower [YOM] emissions greatly, and
most coatings operations are capable of converting to waterborne coatings.'" !d., citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency further argued that sources can reformulate by using "coatings that emit almost zero YOM and

are cured through the use of ultraviolet light or an electron beam." TSD at 12. The Agency acknowledged that "[t]he use of such systems are more limited than those for waterbased coatings, but they are available." 

### ld.

Add-On Controls. The Agency claimed that, when a source uses high-YOM coatings, it

can used add-on controls. TSD at 12. Citing its experience with a range ofcoating operations, the Agency agreed with the CTG that "an overall control and capture efficiency 01'90 percent is

a widely-accepted and readily available technique" [d., citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006.

Work Practices. The Agency noted that

[t]he CTG recommends specific work practice requirements for flat wood paneling coating operations: storing all [YOM] coatings, thinners, and cleaning materials in close containers, minimizing spills of [VOM] containing coatings, thinners, cleaning up spills immediately, conveying any coatings, thinners, and14

cleaning materials in closed containers or pipes, closing mixing vessels which contain [YOM] coatings and other materials except when specifically in use, and minimizing emissions of [YOM] during cleaning of storage, mixing, and conveying equipment." TSD at 12, citing Control Techniques Guidelines for Flat Wood Paneling Coatings. United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006.

The Agency stated that Illinois has already adopted some ofthese requirements through regulations for wood furniture coaters. TSD at 12. The Agency further stated that its proposal will apply those requirements and other specific requirements to flat wood paneling coaters in order to "minimize unnecessary YOM emissions from such operations." 

### !d.

Flexible Packaging Printing Lines

The Agency stated that YOM emissions from flexible package printing operations stem largcly from evaporation of inks, coatings, and adhesives, and from the use ofcleaning materials. TSD at 9 (§3.3). The Agency argued that these emissions can be controlled through material reformulation, add-on controls, and work practices. ld. at 9-10; see SR at 10.

Material Reformulation. This control substitutes high-YOM inks, coatings, and adhesives with low-YOM versions ofthose materials. TSD at 9. Citing the CTG, the Agency argued that "such reformulation 'has been achieved by any facilities in the packaging rotogravure and flexographic printing industries.'" ld., citing Control Techniques Guidelines for Flexible Package Printing, United State Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. The Agency acknowledged that "[w]hether a particular facility is able to use such reformulated material depends upon their specific activities, including the substrate(s) being used." TSD at 9.

Add-On Controls. The Agency stated that all flexible packaging printers can use add-on controls. TSD at 9. The Agency argued that "[t]he most common control devices used by these

sources are thermal oxidizers, catalytic oxidizers, and carbon adsorbers, with adsorbers probably being the least-used ofthe three." ld. The Agency agreed with the CTG that "[t]oday, these control devices can achieve at least 95 percent control device efficiency." ld., citing Control Techniques Guidelines for Flexible Package Printing. United State Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006.

The Agency also described capture systems, which collect air containing YOM "so it may be destroyed or reclaimed by the control device

... ." TSD at 9. The Agency noted that, "[ w]hile new presses may be able to obtain as high as 100 percent capture ifdesigned properly, older presses were not necessarily constructed with emissions capture in mind." ld. The Agency proposed a tiered approach to capture efficiency based on the construction date ofthe printing line and the control device. !d.; see Prop. 218 at 63-64 (proposed Section 21 8.401 (c)(3)), Prop. 219. at 62 (proposed Section 219.401(c)(3)).

Work Practices. The Agency noted that the CTG "recommends work practice requirements as the best means to control emissions from cleaning operations at flexible package15

printing sources." TSD at 10. The Agency listed some ofthese practices: "keeping solvent containers closed except when filling, draining or conducting cleaning operations, kceping used shop towels in closed containers, and conveying cleaning materials from one location to another in closed containers or pipes." 

### lei., citing Control Techniques Guidelines for Flexible Package Printing. United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006.

Lithographic Printing Lines

The Agency addressed three options for regulating YOM emissions from lithographic printing lines: add-on controls, fountain solution reformulation and process modification, and material reformulation or substitution for cleaning solutions. TSD at 7-8 (§3.1); see SR at 10.

Add-On Controls. The Agency stated that add-on controls apply only to heatset web offset lithographic printing and not to non-heatset or sheet-fed lithographic printing. TSD at 7. The Agency further stated that these add-on controls fall into two broad categories: combustion control devices "designed to destroy YOMs in the vent strcam prior to atmospheric discharge" and recovery devices that "limit YOM emissions by recovering material for reuse." 

### lei. The Agency indicated that heatset web offset lithographic printers use three add-on controls: thermal afterburners, catalytic afterburners, and condenser filter systems. /d. The Agency's experience led it to conclude "that the field is dominated by thermal and catalytic afterburners, which can often achieve 98 percent or greater YOM removal." 

### lei. The Agency also reported that condenser filter systems have been designed specifically for heatset wcb offset printers with efficiency as high as 97 percent removal. 

### lei.

Fountain Solution Reformulation and Process Modifications. The Agency argued that "[a] significant portion of YOM emissions from lithographic printing can be ascribed to evaporation from fountain solutions." TSD at 8. The Agency stated that substitutes reduce or replace alcohol in fountain solutions. 

### lei. The Agency further stated that the substitutes have lower volatility and reduce emissions. 

### lei.

The Agency characterized process modifications as "changes in operational methods or equipment resulting in improved YOM controL" TSD at 8. The Agency named cooling fountain solution to minimize evaporation as one process modification that reduces YOM emissions. 

### lei. The Agency claimed that the use of refrigerated circulators to cool fountain solution "has been shown to reduce consumption ofalcohol in the solution by as much as 44 percent." /d. Although process modification may involve retrofitting or rcplacing existing equipment, the Agency "does not expect retrofitting or replacement to be an issue with this rulemaking." 

### lei.

Material Reformulation or Substitution for Cleaning Solutions. The Agency described two reformulations to reduce YOM emissions from cleaning solutions. First, sources
can use solutions containing a smaller amount of YOM. TSD at 8. Current Illinois regulations

now limit these solutions to no more than 30 percent YOM by weight. 

### lei.; see 35 

### III. Adm. Code 218.407(a)(4)(A)(i); 35111. Adm. Code 219.407(a)(4)(A)(i). The Agency reported that, "[w]hile

no problems with this limit have been reported to Agency personnel in 1Ilinois, there have apparently been complaints on a national level." TSD at 8. The Agency noted that "the CTG16

now recommends limiting such solutions to 70 percent YOM." 

### ld., citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing. United States Environmental Protection Agcncy, Office of Air Quality Planning and Standards, September 2006. The Agency proposed to apply "this higher lim it for sources between 15 and 100 pounds per day (PPD), with the previous limit remaining in effect for larger sources," TSD at 8; see Prop. 218 at 88 (proposed Section 218.407(a)( 4)(A)); Prop. 219 at 87 (proposed Section 219.407(a)( 4)(A)).

Second, the Agency reported that sources can rely on cleaning solution with a low vapor pressure, TSD at 8. Citing the CTG, the Agency stated that "[c]leaning solutions with [YOM] composite vapor pressure less than I0 millimeters of mercury (mm Hg) at 20°C have been used successfully by many printers for blanket washing and other cleaning activities. Id., citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. The Agency further stated that, before I1Iinois adopted its previous lithographic printing rules, USEPA determined that the use of such materials results in emission reductions comparable "to using cleaning materials that contain less than 30 weight percent YOM." TSD at 8, Because the Agency believes that sources now use these materials without difficulty, it proposed not to amend the limit but to apply it to smaller sources. Id.; see Prop. 218
at 79 (proposed Section 218.405(c)(3)(C); Prop. 219 at 78 (proposed Section 219.405(c)(3)(C).

Letterpress Printing

The Agency stated that the sources of YOM emissions ITom letterpress printing are similar to those for lithographic printing, except "that letterpress operations do not use a fountain solution." TSD at 9; SR at 10, The Agency further stated that "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," particularly with regard to cleaning solutions. TSD at 9.

Having argued that "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." TSD at 9; see Prop. 218 at 115 (proposed Section 218.413(a)(2)), Prop. 219 at 115-16 (proposed Section 219.413(a)(2)). The Agency indicated on the basis ofcommunication with industry representatives "that Illinois does not currently contain any heatset web letterpress operations in either the Chicago or Metro-East NAA

.... " TSD at 9. The Agency argued, however, that "the regulation is necessary and technically feasible should a new such operation locate in one ofthe NAAs." Id.

Economic Reasonableness

In its Technical Support Document, the Agency addressed the economic reasonableness of various approaches to controlling YOM emissions from Group II product categories. See TSD at 13-15. The Agency argued that the control techniques dcscribed above "are economically reasonable, particularly as many ofthe techniques are already widely used by the17

affected industries." SR at 10. In the subsections below, the Board addresses the record on the issue of the economic reasonableness ofthose techniques.

Industrial Cleaning Solvents

The Agency cited USEPA's estimate that the proposed regulation would affect 130 Illinois sources with basel inc YOM emissions of2528 tons per year. TSD at 14 (§4.4) (referring
to 2002 National Emissions Inventory database). The Agency also noted USEPA's determination that "the cost effectiveness of meeting the 50 grams ofYOM per liter ofcleaning material limit for a parts cleaner at $1664/ton based on a study provided by the California Bay Area Air Quality Management District." TSD at 14. The Agency indicated that sources switching from high-YOM content solvents to low-YOM content solvents may realize savings of $ 1325/ton because ofIower disposal costs. !d.

Flat Wood Paneling Coating Lines

The Agency noted that USEPA relied upon data from the South Coast Air Quality Management District ofCalifornia to estimate cost effectiveness "of between $1,900 and $2,600 per ton of YOM reduced (in 2005 dollars)." TSD at 14 (§4.5). The Agency also cited the CTG
to indicate that Illinois sources subject to the proposed rule could incur costs to make their coatings compliant. Id. at 14-15, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. The Agency concluded that "the only significant cost is expected to be reformulation ofcoatings." TSD at 15.

Flexible Packaging Printing Lines

The Agency cited the CTG to claim that "[m]any facilities located in ozone nonattainment areas are already meeting the control levels being recommended in this CTG" TSD at ]4 (§4.3), citing Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agcncy argued that

this proposal does not expand the number of sources that will be subject to the ink

or control device portions ofthe flexible packaging rotogravure and flexographic printing regulations. It is expected that those sources currently able to use compliant inks and coatings will similarly be able to make use of inks 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 not be any additional add-on control costs for subject facilities. TSD at 14.

The Agency cited the CTG to state that sources installing add-on control devices will face costs that vary based on operating factors. Id. The Agency cited the CTG to estimate that "'a press exhausting approximately 5,800 cubic feet per minute, operating 2000 hours per year, and achieving 70 percent capture efficiency' would have a cost of between $1,300 and $2,800 per ton18

ofVOM removed." [d., citing Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. The Agency argued that factors including more operating hours would lower the cost per ton ofVOM removed. TSO at 14.

Addressing the cleaning provisions of its proposal, the Agency expected "minimal" costs for sources becoming subject to those regulations. TSO at 14. The Agency argued that "some

sources may see an overall costs savings as less cleaning solution is necessary." 

### !d.

Lithographic Printing Lines

The Agency argued that "[t]he 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 of sources for which this requirement is applicable, there is no foreseen additional cost due to add-on controls for existing sources." TSO at ] 3 (§4.1). Although the Agency acknowledged that new sources will be subject to a higher control efficiency, it expects new control devices to achieve that efficiency. [d. The Agency argued that "no additional cost is expected for this reason either." [d.

The Agency stated that its proposal could result in costs for newly-regulated sources emitting between] 5 and 100 pounds per day ofVOM. TSO at 13. The Agency reported that "USEPA estimated the cost for cleaning material reformulation at $855 per ton ofVOM removed (in 2005 dollars)." [d., citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, Unites States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006.

The Agency noted that USEPA projects a costs savings with fountain solutions because of reduced alcohol use. TSO at 13. The Agency indicated that, although USEPA has not specifically estimated the amount ofthese savings, it noted that "the TSO for the Illinois lithographic printing rule in 1994 put this savings at $920 per ton." [d. The Agency explained that, "while alcohol substitutes are more expensive, the cost is reduced because they are used in lower quantities." [d., citing Technical Support Document for Controlling YOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency, October 1994.

Letterpress Printing

The Agency cited the CTG to state that,

[b]ecause 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, it is reasonable to assume that the cost-effectiveness estimates

... for control of [YOM] from heatset inks and control of [YOM] from cleaning materials apply equally to the letterpress printing industry. TSO at 13 ('\14.2), citing Control Techniques Guidelines for Offset lithographic Printing and Letterpress Printing, United States Environmental19

Protection Agency, Office ofAir Quality Planning and Standards, September 2006.

The Agency acknowledged that, because III inois does not now regulate heatset web letterpress printing operations, "the reasoning behind the zero cost estimate for heatset web lithographic

. printing" does not apply to letterpress printing. TSD at 13. The Agency noted the CTG's

estimate of $2,0 I 0 per ton of VOM removed in 2005 dollars as the cost-effectiveness for this category. Id. However, the Agency emphasized that there are not now any heatset web letterpress operations in either ofthe Illinois NAAs. Id.

Summary and Findings

Although the Board in a letter dated August 6, 2009, requested that DCEO conduct an economic impact study on the Agency's amended rulemaking proposal (see 415 ILCS 5/27(b)(I) (2008)), the Board received no response to that request. At the second hearing, the Board received no testimony or comment regarding the absence of any response to the request. See Tr.2
at 8-9.

In his pre-filed testimony on behalfofthe Agency, Mr. Bloomberg states that "[t]he Agency agrees with USEPA that all ofthe proposed changes are technically feasible and economically reasonable." Bloomberg Test. at 8. No participant has offered evidence or arguments rebutting this position. Having reviewed the record on the issues of feasibility and reasonableness, the Board finds as it did in adopting its proposal for first notice that the proposed regulations are both technically feasible and economically reasonable.

SUMMARY OF BOARD'S SECOND-NOTICE PROPOSAL

Part 211

In its original proposal, the Agency sought to amend four definitions in and add 23 new definitions to the existing Part 211, Definitions and General Provisions. SR at I 1-15; see Prop. 2] ]; see generally 35 III. Adm. Code 211. For second notice, the Board summarizes each of its proposed amendments and additions separately in following subsections.

Section 211.1000: Class II Finish

The Board proposes to add a definition of "Class II Finish" necessitated by amendments
to Subpart F ofParts 218 and 219. SR at 11-12; see Prop. 218 at 17-57, Prop. 219 at 17-55. The proposed definition provides in its entirety that "'Class II Finish' means a finish that meets the specifications of Voluntary Product Standard PS-59-73, as approved by the American National Standards Institute." Prop. 21 I at 13.

Section 211.1745: Digital Printing

The Board proposes to add a definition of "Digital Printing" necessitated by amendments
to Sections 218.187 and 219.187. SR at 12; see Prop. 218 at 4-1 7, Prop. 219 at 4-17. The

### 20

proposed definition provides in its entirety that'" Digital Printing' means, for purposes of 35 III. Adm. Code 218.187 and 219.187, the transfer ofelectronic files directly from a computer to an electronically driven output device that prints the image directly on the selected media (substrate). Printing using home and office equipment is excluded from this definition." Prop. 211 at 13.

Section 211.1878: Electrical Apparatus Component

The Board proposes to add a definition of "Electrical Apparatus Component" necessitated by amendments to Sections 218.187 and 219.187. SR at 12; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that

'Electrical Apparatus Component' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, an internal component such as wires, windings, stators, rotors, magnets, contacts, relays, energizers, and connections in an apparatus that generates or transmits electrical energy including, but not limited to, alternators, generators, transformers, electric motors, cables, and circuit breakers, except for the actual cabinet in which the components are housed. Electrical components of graphic arts application equipment and hot-line tools are also included in this category. Prop. 211 at 13-14.

Section 211.1885: Electronic Component

Section 211.1885 ofthe Board's air pollution regulations now provides that "'Electronic Component' means, for the purposes of 35 III. Adm. Code 218.182(f) and 219.182(f), all portions of an electronic assembly, including, but not limited to, circuit board assemblies, printed wire assemblies, printed circuit boards, soldered joints, ground wires, bus bars, and associated electronic component manufacturing equipment such as screens and filters." 35 Ill. Adm. Code 211.1885. Proposed amendments to Sections 218.187 and 219.187 necessitate revision ofthis language. SR at 12; see Prop. 218 at 4-17, Prop. 219 at 4-17. The Board proposes to extend application ofthe definition to Sections 218.187 and 219.187 and to add an exception for cabinets housing components. SR at 12. Specifically, the revised definition provides that

'Electronic Component' means, for the purposes of35 Ill. Adm. Code 218.182(f), 2 I9. I 82(f), 2 I 8.187, and 219.187, all portions ofan electronic assembly, including, but not limited to, circuit board assemblies, printed wire assemblies, printed circuit boards, soldered joints, ground wires, bus bars, and associated electronic component manufacturing equipment such as screens and fi Iters, except for the actual cabinet in which the components are housed. See Prop. 211 at 14.

Section 211.2355: Flat Wood Paneling

The Board proposes to add a definition of "Flat Wood Paneling" necessitated by amendments to Subpart F of Parts 218 and 219. SR at 12; see Prop. 218 at 17-57, Prop. 219 at 17-55. The proposed definition provides in its entirety that "'Flat Wood Paneling' means natural finish hardwood plywood panels, hardwood panels with Class 

### 11 finishes, tileboard, exterior21

siding, and printed interior panels made of hardwood, plywood, or thin particleboard." Prop. 2] I
at 14.

Section 211.2356: Flat Wood Paneling Coating Line

The Board proposes to add a definition of "Flat Wood Paneling Coating Line" necessitated by amendments to Subpart F ofParts 218 and 219. SR at 12; see Prop. 218 at 17- 57, Prop. 219 at 17-55. The proposed definition provides in its entirety that '''Flat Wood Paneling Coating Line' means a coating line in which any protective, decorative, or functional coating is applied to flat wood paneling." Prop. 211 at 14.

Section 211.2368: Flexible Packaging

The Board proposes to add a definition of "Flexible Packaging" necessitated by amendments to Subpart 

### H of Parts 218 and 219. SR at 12; see Prop. 218 at 57-129, Prop. 219 at 55-130. The proposed definition provides in its entirety that

'Flexible Packaging' means any package or part of a package, the shape ofwhich

can be readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized

or coated paper or film, or any combination ofthese materials. Shrink-wrap labels or wrappers (but not self-adhesive labels) printed on or in-line with a flexible packaging printing press are also considered to be flexible packaging. Flexible packaging does not include folding cartons, gift wraps, hot stamp foils, wall coverings, vinyl products, decorative laminates, floor coverings, or tissue products. Prop. 211 at 14.

Section 211.2615: General Work Surface

The Board proposes to add a definition of "General Work Surface" necessitated by amendments to Sections 218.187 and 219.187. SR at 12-13; see Prop. 218 at 4-17, Prop. 2] 9 at 4-] 7. The proposed definition provides in its entirety that

'Genera] Work Surface' means, for purposes of35 III. Adm. Code 218. J 87 and 219.187, an area ofa medical device or pharmaceutical manufacturing facility where solvent cleaning is performed on work surfaces, but for which cleaning specifications are not required to be maintained in accordance with criteria and procedures established to meet requirements ofthe United States Food and Drug Administration and/or other applicable regulatory agencies with authority over manufacturing operations for medical devices and/or phamlaceuticals. General work surfaces shall not include items defined under 'Janitorial Cleaning.' Prop. 2]] at 14-15.

Section 211.2830: Hcatset

### 22

Section 211 ,2830 ofthe Board's air pollution regulations now provides that "'Heatset'

means a class oflithography which requires a heated dryer to solidify the printing inks." 35 Ill. Adm, Code 2 11.2830, Proposed amendments to Subpart H of Parts 2 18 and 2 I 9 necessitate revision ofthis language. SR at 13; see Prop. 2] 8 at 57-129, Prop. 219 at 55-130, The Board proposes to amend the definition "to include letterpress printing lines," SR at 13. The revised definition provides in its entirety that "'Heatset' means a class of lithography or letterpress which requires a heated dryer to solidify the printing inks," Prop, 21 

### I at 15.

Section 211.2855: Heatset Web Letterpress Printing Line

The Board proposes to add a definition of "Heatset Web Letterpress Printing Line" necessitated by amendments to Subpart H ofParts 218 and 219. SR at 13; see Prop, 218 at 57- 129, Prop, 219 at 55-130. The proposed definition provides in its entirety that "'Heatset Web Letterpress Printing Line' means a letterpress printing line in which a continuous roll of substrate is fed through the printing press and an oven is used to soliditY the printing inks," Prop. 21 

### I at 15.

Section 211.2965: High Precision Optic

The Board proposes to add a definition of "High Precision Optic" necessitated by amendments to Sections 218, I 87 and 219,187, SR at 13; see Prop, 21 8 at 4-17, Prop. 219 at 4- 17. The proposed definition provides in its entirety that "'High Precision Optic' means, for purposes of35 III. Adm. Code 218.187 and 219.187, an optical element used in an electro-optical device that is designed to sense, detect, or transmit light energy, including specific wavelengths of light energy and changes in light energy levels." Prop. 211 at 15.

Section 211.3215: Janitorial Cleaning

The Board proposes to add a definition of "Janitorial Cleaning" necessitated by amendments to Sections 218,187 and 219, 187, SR at 13; see Prop. 218 at 4-17, Prop. 219 at 4- 17, The proposed definition provides in its entirety that '''Janitorial Cleaning' means, for purposes of 35 III. Adm. Code 218,187 and 2I 9, 187, the cleaning of building or facility components, including, but not limited to, floors, ceilings, walls, windows, doors, stairs, bathrooms, furnishings, and exterior surfaces of office equipment, and excludes the cleaning of work areas where manufacturing or repair activity is performed." Prop. 211 at 15.

Section 211.3305: Letterpress Printing Line

The Board proposes to add a definition of "Letterpress Printing Line," necessitated by amendments to Subpart H ofParts 218 and 2 I 9. SR at 13; see Prop. 218 at 57-129, Prop. 219 at 55- 130. The proposed definition provides in its entirety that '''Letterpress Printing Line' means
a web or sheetfed printing line that does not constitute a flexographie printing line, in which the image area is raised relative to the non-image area and the ink is transferred to the substrate directly from the image surface," Prop. 2 I 1 at 16,

Section 211.3555: Maintenance Cleaning

### 23

The Board proposes to add a definition of "Maintenance Cleaning" necessitated by amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 219 at 4- ] 7. The proposed definition provides in its entirety that

'Maintenance Cleaning' means, for purposes of35 111. Adm. Code 218. J 87 and 219.187, a solvent cleaning operation or activity carried out to ensure that general work areas where manufacturing or repair activity is performed remains clean, and to clean tools, machinery, molds, forms, jigs, and equipment. This definition does not include the cleaning ofcoatings, adhesives, or ink application equipment.' Prop. 211 at ] 6.

Section 211.3705: Medical Device

The Board proposes to add a definition of "Medical Device" necessitated by amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that

'Medical Device' means, for purposes of35 III. Adm. Code 218.187 and 219.187,

an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent or other similar article, including any component or accessory, that meets

one or more ofthe following conditions

(a) it is intended for use in the diagnosis ofdisease or other conditions,

or in the cure, mitigation, treatment, or prevention ofdisease;

(b) it is intended to affect the structure or any function ofthe body; or
(c) it is defined in the National Fonnulary or the United States Pharmacopeia, or any supplement to them. Prop. 211 at 16.

Section 211.3707: Medical Device and Pharmaceutical Manufacturing

The Board proposes to add a definition of "Medical Device and Pharmaceutical Manufacturing" necessitated by amendments to Sections 218.187 and 219.187. SR at ] 4; see Prop. 218 at 4-17, Prop. 2] 9 at 4-17. The proposed definition provides in its entirety that

'Medical Device and Pharmaceutical Manufacturing' means, for purposes of35 

### 111. Adm. Code 2 J 8.187 and 219.187, the collection of equipment and activities to prepare, utilize, maintain, and repair work areas, in order to accomplish one or
more steps in preparing a medical device or pharmaceutical for its intended use. Manufacturing is typically, but not always, conducted in accordance with criteria and procedures established to meet requirements ofthe United States Food and Drug Administration and/or other applicable regulatory agencies with authority

over manufacturing operations for global sales of medical devices and/or pharmaceuticals. Work areas and equipment shall include all machinery, tools,24

equipment, rooms, tables, countertops, and facilities for maintaining employee health and safety that are subject to such criteria and procedures. Prop. 2 

### J I at 16- 17

Section 211.4065: Non-Hcatset

Section 211.4065 ofthe Board's air pollution regulations now provides that '''Nonheatset' means a class of lithography which does not require a heated dryer to solidify the printing inks. Ultraviolet-cured and electron beam-cured inks are considered non-heatset." 35 

### 111. Adm. Code 2] 1.4065. Amendments to Subpart 

### H ofParts 218 and 219 necessitate revision ofthis language. SR at 14; see Prop. 218 at 57-129, Prop. 219 at 55-130. Specifically, the Board proposes to revise this definition "to include letterpress printing lines." SR at 14. The revised definition provides in its entirety that '''Non-heatset' means a class of lithography or letterpress which does not require a heated dryer to solidify the printing inks. Ultraviolet-cured and electron beam-cured inks are considered non-heatset." Prop. 211 at 17.

Section 211.5335: Radiation Effect Coating

The Board proposes to add a definition of "Radiation Effect Coating" necessitated by amendments to Sections 218.187 and 2] 9.1 87. SR at 14; see Prop. 2 

### J8 at 4- I7, Prop. 219 at 4- 17. Thc proposed dcfinition provides in its entirety that

'Radiation Effect Coating' means, for purposes of 35 

### 111. Adm. Code 218.187 and 219.187, a coating or coating system engineered to interact, through absorption or reflection, with specific regions ofthe electromagnetic energy spectrum, such as the ultraviolet, visible, infrared, or microwave regions. Uses include, but are not limited to, lightning strike prevention, electromagnetic pulse protection, and radar avoidance. Coatings that have been designated 'classified' by the Department of Defense are not included in this definition. Prop. 211 at 17.

Section 211.5535: Repair Cleaning

The Board proposes to add a definition of "Repair Cleaning" necessitated by amendments
to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that "'Repair Cleaning' means, for purposes of35 

### Ill. Adm. Code 218.187 and 219.187, a solvent cleaning operation or activity carried out during a repair process." Prop. 21 I at 17.

Section 211.5585: Research and Development Operation

The Board proposes to add a definition of "Research and Development Operation" necessitated by amendments to Sections 218.187 and 2] 9. 1 87. SR at 14; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entircty that

'Research and Development Operation' means, for purposes of 35 

### 111. Adm. Code 218.187 and 219.187, an operation whose purpose is for research and25

development ofnew processes and products, that is conducted under the close supervision oftechnically trained personnel, and is not involved in the manufacture of final or intermediate products for commercial purposes, except in

a de minimlls manner. Prop. 211 at 17.

Section 211.5860: Scientific Instrument

The Board proposes to add a de.finition of "Scientific Instrument" necessitated by amendments to Sections 21 8.187 and 219.1 87. SR at 14; see Prop. 218 at 4-17, Prop. 219 at 4- 17. The proposcd definition provides in its entirety that '" Scientific Instrument' means, for purposes of 35 III. Adm. Code 218.1 87 and 219.187, an instrument, including the components, assemblies, and subassemblies used in their manufacture, and associated accessories and reagents that is used for the detection, measurement, analysis, separation, synthesis, or sequencing of various compounds." Prop. 211 at 18.

Section 211.5875: Screen Printing

The Board proposes to add a definition of "Screen Printing" necessitated by amendments
to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that '''Screen Printing' means, for purposes of35 

### Ill. Adm. Code 218.187 and 219.187, a process in which the printing ink passes through a taught [sic] screen or fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions ofthe imprint." Prop. 2 I I at 18.

Section 211.5885: Screen Reclamation

The Board proposes to add a definition of "Screen Reclamation" necessitated by amendments to Sections 218.1 87 and 219.187. SR at 14-15; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that '''Screen Reclamation' means, for purposes of35 III. Adm. Code 218.187 and 219.1 87, a solvent cleaning activity carried out in a
screen printing operation where the screen is completely cleaned and the stencil removed for recycling or reuse ofthe screen for other production runs." Prop. 211 at 18.

Section 211.6405: Sterilization Indicating 

### Ink

The Board proposes to add a definition of "Sterilization Indicating Ink" necessitated by amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 218 at 4-17, Prop. 219 at 4- 17. The proposed definition provides in its entirety that "'Sterilization Indicating Ink' means, for purposes of 35 Ill. Adm. Code 218. I 87 and 219.187, an ink that changes color to indicate that sterilization has occurred. Such ink is used to monitor the sterilization ofmedical instruments, autoclave efficiency, and the thermal processing of foods for prevention of spoilage." Prop. 211
at 18.

Section 211 ,6425: Stripping26

The Board proposes to add a definition of "Stripping" neccssitated by amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 218 at 4-17, Prop. 219 at 4-17. The proposed definition provides in its entirety that "'Stripping' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, the removal ofcured coatings, cured inks, or cured adhesives." Prop. 211
at 18.

Section 211.6535: Surface Preparation

The Board proposes to add a definition of "Surface Preparation" necessitated by amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 218 at 4-17, Prop. 219 at 4- 17. The proposed definition provides in its entirety that "'Surface Preparation' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, the removal of contaminants such as dust, soil, oil, and grease prior to coating, adhesive, or ink applications." Prop. 211 at 18-19.

Section 211.7290: Wood Preparation

Section 211.7290 ofthe Board's air pollution regulations now provides that '''Wood furniture' means room furnishings including cabinets (kitchen, bath and vanity), tables, chairs, beds, sofas, shutters, art objects, wood paneling, wood flooring and any other coated furnishings made ofwood, wood composition or fabricated wood materials." 35 Ill. Adm. Code 211.7920. Proposed amendments to Subpart F of Parts 218 and 219 necessitate revision ofthis language. SR at 15; see Prop. 218 at 17-57, Prop. 219 at 17-55. The Board proposes to revise the definition by excluding flat wood paneling from it. SR at IS. The revised definition provides in its entirety that '''Wood furniture' means room furnishings including cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, wood paneling other that flat wood paneling, wood flooring, and any other coated furnishings made ofwood, wood composition, or fabricated wood materials." Prop. 21 I at 19.

Part 218IPart 219

Subpart A: General Provisions

Existing Sections 218.1 06 and 219.106 establish general compliance dates for sources subject to Parts 218 and 219. See 35 Ill. Adm. Code 218.106, 219.106. The Agency proposed "adding a new subsection (e) to Section 218.106 and a new subsection (c) to Section 219.106

... ." SR at 15; see Prop. 218 at 4, Prop. 219 at3. The original proposal established "May 1, 2010,

as the compliance date for sources subject to the flat wood paneling emission limits." SR at IS. On the basis offirst-notice comments, however, the Board has concurred in extending this deadline to August 1,2010.

Subpart E: Solvent Cleaning

Introduction. Existing Subpart E of both Parts 218 and 219 addresses YOM emissions from solvent cleaning operations. See 35 Ill. Adm. Code 218.1 81-186, 219.181 -186. The Agency stated that industrial cleaning solvents include a number ofproducts "used to clean dirt, soil, oil, and grease as well as remove adhesives, paints, and inks." TSD at 5 (§2.4); see27

Bloomberg Test. at 6. The Agency further stated that "VOM emissions occur during the cleaning process while wiping, flushing, brushing, and from the storage and disposal of used solvents and rags." TSO at 6.

The Agency noted that USEPA has conducted studies ofVOM emissions focusing on six industries: "automotive, electrical equipment, magnetic tape, furniture, packaging, and photographic supplies." TSO at 6. The Agency claimed that these studies revealed nine major categories in which cleaning processes result in YOM emissions: "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." Id. The Agency argued that the first four account for a majority ofVOM emissions from these categories and that spray gun cleaning alone accounts for 50 percent. Id. The Agency stated that the CTG nonetheless "recommends coverage ofa wide range ofcleaning activities" and that its proposal reflected that recommendation. Id. The Agency emphasized, however, that the proposal does not cover "[g]eneral cleaning ofoffices, bathrooms, and otherjanitorial type services." Id.

Current Regulations. The Agency stated that "Illinois has current regulations for cold cleaning degreasing, open top vapor degreasing, and conveyorized degreasing operations as well

as some limitations and work practices on cleaning solvent uses in existing rules, e.g., regulations regarding auto body refinishing, wood furniture coating, and lithographic printing." TSO at 17 (§5.4).

Summary ofProposed Amendments to Subpart E. The Agency stated that its proposal follows the CTG by establishing an "applicability threshold of 15 pounds per day of YOM emissions and in most ofthe required YOM limits." Bloomberg Test. at 6; see TSO at 17. The Agency further stated that affected sources must follow work practice standards regarding solvent use and either comply with a limit on the YOM content ofcleaning solution, "usc a low vapor pressure cleaning solution, or utilize an emissions control system that provides 85 percent overall control of YOM emissions from cleaning activities." TSO at 17; see SR at 7, Bloomberg Test at 6-7, Tr.1 at 

### J 1-14 (addressing YOM content limit); see generally Prop. 218 at 5-17, Prop. 219 at 3-17.

The Board below summarizes proposed amendments to Subpart E on a section-by-section basis.

Section 218/219.181: Solvent Cleaning in General. The Board first proposes to amend the titles ofthese two sections to "Solvent Cleaning Oegreasing Operations." SR at 15-16; see Prop. 218 at 4, Prop. 219 at 3-4. The Board also proposes to amend these two sections "to specify that Sections 218/219.182 through 218/219.184 and Section 218/219.186 are appl icable
to cold cleaning, open top vapor, and conveyorized degreasing operations." SR at 16.

Section 218/219.187: Other Industrial Solvent Cleaning Operations. The Board proposes to add a new Section 218/219.187. SR at 16; see Prop. 218 at 4-17, Prop. 219 at 4-17. Below, the Board separately summarizes the subsections comprising it.28

Subsection (ll). The Board's proposed subsection (a)(I) establishes the section's applicability by providing that, on and after April 1,2011, "the requirements in Section 218/2 I9.187 apply to all cleaning operations which use organic materials at sources that emit 6.8 kg/day (15 Ibs/day) or more of YOM from cleaning operations at the source." SR at 16; see Prop. 218 at 4, Prop. 219 at 4. ]n addition, the subsection defines "cleaning operations" for the
purposes ofthis Section as

the process of cleaning products, product components, tools, equipment, or general work areas during production, repair, maintenance, or servicing, including but not limited to spray gun cleaning, spray booth cleaning, large and small manufactured components cleaning, parts cleaning, equipment cleaning, line cleaning, floor cleaning, and tanks cleaning, at sources with emission units. Prop. 218 at 4, Prop. 219 at 4.

Proposed subsection (a)(2) "exempts numerous types ofcleaning operations from some
or all ofthe limitations in Section 218/2]9.187." SR at 16; see Prop. 218 at 4-7, Prop. 219 at 4- 6; see also TSD at I ]-]2 (Exclusions). The Agency's first motion to amend stated that USEPA has notified the Agency that it "may exempt digital printing from the control requirements set forth in Section 218/219.187 of its proposal." Mot. Amend I at 1-2**(~2).** The Board granted the motion and includes digital printing in the list of exclusions in Section 21 8/219.1 87(a)(2)(C).

Subsection (bl. Proposed subsection (b) provides that no owner or operator of a source subject to this section shall perform subject cleaning operations unless the source complies with

one of three requirements. SR at 16. First, the source may comply with the applicable YOM
content limit. Id; see Prop. 218 at 7-8 (proposed Section 218.187(b)(1 )), Prop. 219 at 7-8 (proposed Section 219.] 87(b)(l). In its second motion to amend, the Agency responded "to a recent request for clarification from an industry representative

.... " Mot. Amend 2 at 1-2**(~3).** Specifically, the Agency proposed to amend this subsection to provide that the YOM content limitations "apply to as-used cleaning solution, excluding water and other compounds exempted from the definition ofVOM." Id. at 1-2. The Agency stated that "[t]his proposed amendment is consistent with the Illinois EPA's original intent and with existing YOM regulations." Id. at 2. The Board granted the motion and has included this language in subsection (b).

Second, the source may comply by using "cleaning materials with a composite vapor pressure of no more than 8.00 mmHg measured at 20 degrees Celsius." SR at 16; see Prop. 218
at 8 (proposed Section 218.1 87(b)(2)), Prop. 219 at 8 (proposed Section 219.187(b)(2)). Third, the source can comply by installing and operating an afterburner or carbon adsorber "that reduces YOM emissions from the subject cleaning operation by at least 85 percent overall." SR
at 16; see Prop. 218 at 8 (proposed Section 218.187(b)(3)), Prop. 219 at 8 (proposed Section 21 9. I 87(b)(3). The Board also proposes that

[t]he owner or operator may use an emissions control system other than an afterburner or carbon adsorber if such device reduces YOM emissions from the subject cleaning operation by at least 85 percent overall, the owner or operator submits a plan to the Agency detailing appropriate monitoring devices, test methods, recordkeeping requirements, and operating parameters for such control29

device, and such plan is approved by the Agency and USEPA within federally enforceable permit conditions. Prop. 218 at 8 (proposed Section 218.187(b)(3)), Prop. 219 at 8 (proposed Section 219.187(b)(3).



### Subsection (c). The Board proposes that the owner or operator of a subject source "shall demonstrate compl iance with this Section by using the applicable test methods and procedures in Section 218/219.187(g) and by complying with all applicable recordkeeping and reporting requirements in Section 219.187(e)." SR at 16; 

### see Prop. 218 at 8 (proposed Section 218.187(c), Prop. 219 at 8 (proposed Section 219.187(c); 

### see also infra at 31 (summarizing subsection g); 

### infra at 29-31 (summarizing subsection (e).



### Subsection (dl. The Board proposes that the owner or operator ofa subject source must comply with various operating requirements for each subject cleaning operation. SR at 17. First, the Board proposes to require that they "[clover open containers and properly cover and store applicators used to apply cleaning solvents." Prop. 218 at 9 (proposed Section 218.187(d)(l )); Prop. 219 at 8 (proposed Section 2l9.187(d)(l); 

### see SR at 17. Second, the Board proposes that they "[m]inimize air circulation around the cleaning operation." Prop. 218 at 9 (proposed Section 218.187(d)(2)); Prop. 219 at 8 (proposed Section 219.1 87(d)(2); 

### see SR at 17. Third, the Board seeks to require that an owner or operator "[d]ispose ofall used cleaning solutions, cleaning towels, and applicators used to apply cleaning solvents in closed containers" Prop. 218
at 9 (proposed Section 218.1 87(d)(3)); Prop. 219 at 8 (proposed Section 219.187(d)(3); 

### see SR at 17. Finally, the Board also proposes that they "[u]tilize equipment practices that minimize emissions." Prop. 218 at 9 (proposed Section 21 8. I 87(d)(4)); Prop. 219 at 8 (proposed Section 219.187(d)(4); 

### see SR at 17.



### Subsection (el. The Board proposes various recordkeeping and reporting requirements for the owner or operator of various sources. In subsection (e)(I), the Board proposes that,

by May 1,2010, sources exempt from the limitations of Section 218/219.187 because of the criteria in Scction 21 8/219.1 87(a)(I) shall submit a certification to the Illinois EPA that includes a declaration that the source is exempt, as well as calculations which demonstrate that combined emissions of YOM from cleaning operations at the source never equal or exceed 6.8 kg/day (15 lbs/day). SR at 17;



### see Prop. 218 at 9 (proposed Section 218.197(e)(1 )), Prop. 219 at 9 (proposed Section 219.187(e)(1).

On the basis of first-notice comments, however, the Board has concurred in extending this May 1. 2010 deadline to August 1,2010.

The proposal also requires that "[s]uch sources shall notify the Illinois EPA ofany rccords that show that the combined emissions of YOM from cleaning operations at the source
ever equal or exceed 6.8 kg/day (15 Ibs/day)." SR at 17; 

### see Prop. 218 at 9 (proposed Section 2l8.197(e)(1 )), Prop. 219 at 9 (proposed Section 219.187(e)(1). Originally, the Agency sought
to require that "[s]uch notification shall include calculations showing the daily emissions of YOM from cleaning operations at the source for the day(s) in which emissions equaled or exceeded 6.8 kg/day (15 lbs/day)." Prop. 218 at 9, Prop. 219 at 9. In its first motion to amend,30

the Agency responded to comment from industry representatives by proposing to remove this requirement that a source provide calculations showing an exccedanee. Mot. Amend I at 2 ('13). The Board granted the motion, and subsection (e)(I) reflects this amendment.

In proposed subsection (e)(2), the Board proposes to require subject sources to submit a certification "[b]y April 1, 2011, or upon initial start-up ofthe source, whichever is later.

... " Prop. 218 at 10 (proposed Section 218.187(e)(2)(A)), Prop. 219 at 9-10 (proposed Section 219. 187(e)(2)(A)); 

### but see SR at 17 (indicating deadline ofMay 1,2010). The original proposal required that the certification include

I) a declaration that all subject cleaning operations arc 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 if complying with the emissions control system requirement, what type ofemissions control system will be used; 4) initial documentation that each subject cleaning operation will comply with the applicable limitation; 5) identification ofthe method that will be used to demonstrate continuing compliance with the applicable limitations; 6) a description ofthe practices and procedures that the

source will follow to ensure compliance with the limitations of Section 218/219.187(d); and 7) a description of each cleaning operation exempt pursuant to Section 218/219.187(a)(2), if any, and a listing ofthe emission unites) on which the exempt cleaning operation is perfonned. SR at 17-18; 

### see Prop. 218 at 9-10 (proposed Section 21 8.1 87(e)(2)), Prop. 219 at 9-10 (proposed Section 219.187(e)(2)).



### In its first motion to amend, the Agency responded to comment from industry representatives by proposing to delete "the requirement that a subject source certify the limitation with which each subject cleaning operation will comply." Mot. Amend 1 at 2-3**(~4);** 

### see Prop. 218 at 10 (proposed Section 218.1 87(e)(2)(A)(iii), Prop. 219 at 10 (proposed Section 21 9. I 87(e)(2)(A)(iii);



### see also TLI at 18-19. The Board granted the motion, and subsection (e)(2)(A)(3) reflects the amendment.

In proposed subsection (e)(2)(B), the Board proposes that subject sources, "[a]t least 30 days before changing the method of compliance between subsection (b)(I), (b)(2), and (b)(3) of this Section, notify the Agency in writing of such change." Prop. 218 at 10 (proposed Section 218. J 87(e)(2)(B), Prop. 219 at 10 (proposed Section 219.187(e)(2)(B). 

### In its first motion to amend, the Agency responded to comment from industry representatives by proposing to delete "the requirement that a source notify the Illinois EPA at least 30 days in advance ofchanging its method ofcompliance between the YOM content limitation and vapor pressure limitation." Mot. Amend 1 at 2-3**(~4).** The Board granted the motion, and the subsection reflects this amendment.

In subsection (e)(3), the Board proposes recordkeeping provisions for sources complying with the YOM content limitations under subsection (b)(l). SR at 18; 

### see Prop. 218 atll-12 (proposed Section 218.1 87(e)(3)), Prop. 219 at 10-12 (proposed Section 219.1 87(e)(3)). In subsection (e)(4), the Board proposes recordkeeping "provisions for sources complying with the31

YOM composite partial vapor pressure limitations in subsection (b)(2)

.... " SR at 18; 

### see Prop. 218 at 12 (proposed Section 218.1 87(e)(4)), Prop. 219 at 12 (proposed Section 21 9.1 87(e)(4)). In subsection (e)(5), the Board proposes rccordkeeping "provisions for sources complying with the emissions control system requirements in subsection (b)(3)

.... " SR at 18; 

### see Prop. 218 at 12-14 (proposcd Section 21 8.1 87(e)(5)), Prop. 219 at 12-14 (proposed Section 219.1 87(e)(5)).

In subsection (e)(6), the Board proposes that

[a)1I sources subject to the requirements of subsection (b) [Material and Control Requirements) and (d) [Operating Requirements) ofthis Section shall notify the Agency of any violation of subsections (b) or (d) by providing a description ofthe violation and copies of records documenting such violation to the Agency within 30 days following the occurrence ofthe violation. Prop. 218 at 14 (proposed Section 21 8.1 87(e)(6)), Prop. 219 at 14 (proposed Section 219.187(e)(6)); see SR
at 18.

In subsection (e)(7), the Board proposes that "[a)1I records required by this subsection (e) shall be retained by the source for at least three years and shall be made available to the Agency upon request." Prop. 218 at 14 (proposed Section 218.1 87(e)(7)), Prop. 219 at 14 (proposed Section 219.1 87(e)(7)); 

### see SR at 18.

Subsectioll (0. In subsection (f), the Board proposes to establish monitoring requirements applicable to sources demonstrating compliance with emissions control systems. SR at 18. Subsection (f)(I) establishes requirements applicable to sources employing an afterburner or carbon adsorber to demonstrate compliance. Prop. 218 at 14 (proposed Section 21 8.1 87(f)(l )), Prop. 219 at 14 (proposed Section 21 9.187(f)(1 )). Subsection (f)(2) addresses emissions control systems other an afterburner or carbon adsorber. Prop. 218 at 15 (proposed Section 217.187(f)(2)), Prop. 219 at 14 (proposed Section 219.1 87(f)(2)).

Subsectioll (gl. In subsection (g), the Board proposes to establish "requirements regarding testing to demonstrate compliance with Section 218/219.187." SR at 19; see Prop. 218
at 15-17 (proposcd Section 218.187(g)), Prop. 219 at 15-17 (proposed Section 219.187(g)). In its first motion to amend, the Agency proposed to amend this subsection "by clarifying when testing pursuant to such Section shall be performed." Mot. Amend I at 3-4**(~5).** The Board granted the motion, and subsection (g)( I) and (g)(2) reflect the amendment.

Subpart F: Coating Operations

Existing Subparts F addresses YOM emissions from various coating operations. 

### See 35 III. Adm. Code 218.204-217, 219.204-217. For these two subparts, the Board proposes a number of amendments, which largely address emissions fTom flat wood paneling coating operations. 

### See Prop. 218 at 17-57, Prop. 219 at ]7-55.

Introduction. The Agency cited the CTG to statc that "[f)lat wood paneling products are used in construction and can be classified as three main product types: decorative interior panels, exterior siding, and tileboard." TSD at 6 (§2.5), citing Control Techniques Guidelines

### 32

for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standard, September 2006. The Agency stated that "[d]ecorative interior panels are often embossed and usually grooved, having more decorative coating requirements than many other products." TSD at 6. For these panels, the Agency indicated that "[s]ubstrates include hardwood, plywood, medium density fiberboard, and particle board." 

### !d.

With regard to exterior siding, the Agency stated that it "may be coated at the production facility or on-site." TSD at 6. The Agency indicated that on-site coating "is not subject to this proposed regulation." Id. The Agency further stated that, in addition to siding, "[e]xterior trim is also generally manufactured at the same production facility and coated with the same coatings." In the classification, the Agency listed substrates including solid wood, hardboard, and waferboard. 

### !d. With regard to tileboard, the Agency indicated that it "is used on highmoisture areas such as kitchens and bathrooms, and is considered a premium interior wall paneling." TSD at 6. The Agency stated that "[t]ileboard meets the specifications for Class I hardboard according to the American National Standards Institute." Id.

The Agency stated that producers coat flat wood paneling in order "to provide protection from the environment, modify the surface, and present a desired appearance." TSD at 6. The Agency cited the CTG to state that

a typical flat wood coating facility applies stains and varnishes to natural plywood panels used for wall coverings. Other plants print wood grain patterns on particle board panels that were first undercoated with an opaque coating to mask the original surface. Coatings applied to flat wood surfaces include fillers, sealers, 'groove' coats, primers, stains, basecoats, inks and topcoats. TSD at 6, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standard, September 2006.

Addressing methods and techniques, the Agency cited the CTG to state that coating line processes typically begin "with mechanical alterations ofthe substrate (filing ofholes, cutting of grooves, sanding, etc.)

.... " TSD at 7, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standard, September 2006. Following this step,

[m]ost coatings are applied by direct roll coating. Filler is usually applied by

reverse roll coating. The offset rotogravure process is used where the coating and printing operation requires precision printing techniques. Other coating methods include spray techniques, brush coating and curtain coating. A typical flat wood paneling coating line includes a succession ofcoating operations. Each individual operation consists ofthe application ofone or more coatings followed by a heated

oven to cure the coatings. TSD at 6-7, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standard, September 2006.33

The Agency stated that, during these operations, "YOM emissions occur primarily during the coating process as the coatings dry and cure, but also as coatings are applied, and during mixture before application." TSD at 7.

Current Regulations. The Agency stated that "[t]here are currently no specific Illinois regulations covering flat wood paneling coating operations." TSD at 17 (§5.5), Bloomberg Test. at 7. The Agency argued that these operations would be addressed by regulations applicable to "Other Emission Units" (35 Ill. Adm. Code 218.980-988, 219.980-988) and possibly by regulations applicable to wood furniture coating (see 35 Ill. Adm. Code 218.204(1), 219.204(1», "depending on whether the operations fell into the definition related to that process." TSO at 17;

see Bloomberg Test. at 7,

Summary of Proposed Amendments to Subpart F. The Agency stated that its proposed amendments to Subpart F "will add coating YOM requirements and work practice requirements for both coatings and associated cleaning operations." TSO at 17; 

### see Prop. 218 at 17-57, Prop. 219 at 17-55, SR at 7-8. Although the Agency noted the option ofemploying addon emission controls, it added that "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." TSO at 18. The Agency claimed that "[t]he work practice requirements include several that are already required for wood furniture coaters, which have been accomplished without any problems known to the Agency." 

### Id.; see Bloomberg Test. at 7. The Agency characterized as "common sense" such requirements as "minimizing spills of YOMcontaining materials, minimizing YOM emissions during cleaning, and closing mixing vessels except when they are in use." Id.

The Board below summarizes on a section-by-section basis each of the proposed amendments to Subpart F.

Section 218/219.204: Emission Limitations. Existing Section 218/219.204 establishes emission limitations based upon YOM content for various categories ofcoating lines. 35111. Adm. Code 218.204,219.204. The Board below separately summarizes the proposed amendments to these provisions. 

### See Prop. 218 at 17-27, Prop. 219 at 17-26.

Subsection (cl. Existing subsection (c), which provides emission limitations applicable
to paper coating lines, includes a note stating in pertinent part that "[t]he paper coating limitation shall not apply to any owner or operator of any paper coating line on which flexographic or rotogravure printing is performed ifthe paper coating line complies with the emissions limitation in Section 218.401 ofthis Part." 35111. Adm. Code 218.204(c), 219.204(c). The Board proposes to amend this subsection by providing that the limitation also "shall not apply to any owner or operator of a paper coating line on which lithographic or letterpress printing is performed ifthe paper coating line complies with the applicable emissions limitations in Subpart H ofthis Part." SR at 19; see 35 Ill. Adm. Code 218.401-411, 219.401-411 (Subparts H), Prop. 2] 8 at 19, Prop. 219 at ]9.

Subsection (01/(01 The Board proposes to add a new subsection (p) to Section 218.204 and a new subsection (0) to Section 219.204, both of "which restrict the YOM content offlat34

wood paneling coatings to 0.25 kg YOM/I coatings or 0.35 kg YOMII solids or less. SR at 19;



### see Prop. 218at27, Prop. 219at26.

Section 218/219.205: Dailv-Weighted Average Limitations. Existing Section 2] 8/2] 9.205 contains provisions for daily-weighted average limitations on YOM content. 35 

### JII. Adm. Code 218.105,219.105. The Board proposes to amend subsection (a) "to include flat wood paneling coating lines in the daily-weighted averaging alternative." SR at 19; 

### see Prop. 218 at 28, Prop. 219 at 26-27.

Section 218/219.207: Alternativc Emission Limitations. Existing Section 218/219.207 contains provisions for alternative emission limitations. 35 III. Adm. Code 218.107,219.107. The Board below separately summarizes proposed amendments to these provisions. 

### See Prop. 218 at 33-37, Prop. 219 at 31-36.



### Subsection (al. The Board proposes to amend this subsection to include flat wood paneling coating lines as a source category eligible for the alternative emission limitations option. SR at 19; 

### see Prop. 2]8 at 33, Prop. 219 at 31-32.



### Subsection (h). The Board proposes to amend Section 218.207(h)(I) in order to correct the formatting ofan equation pertaining to emissions from can coating lines. SR at 20; 

### see Prop. 218at36.



### Subsection 

# m. (kl. The Board proposes to add a subsection (I) to Section 218.207 and a subsection (k) to Section 219.207 in order to include flat wood paneling coating lines in the alternative emissions limitations option. SR at 19; 

### see Prop. 218 at 37, Prop. 219 at 35-36. These proposed subsections "provide that a flat wood paneling coating line may utilize a capture system and control device if such system provides at least 90 percent reduction in the overall emissions ofYOM from the coating line or the owner or operator ofthe flat wood paneling coating line complies with all requirements set forth in subsection (b)(2) ofthis Section." SR at 

### 19; see Prop. 218 at 37, Prop. 219 at 35-36.

Section 218/219.210: Compliance Schedule. Section 218/219.210 establishes compliance schedules applicable to various coating lines. 35 III. Adm. Code 218.210, 219.210. The Board proposes to amend these sections by adding a subsection (g) providing that, on and after a date consistent with Section 218/219.206, sources subject to the flat wood paneling coating emission limitations shall comply with the applicable provisions in Subpart F." SR at 20; 

### see Prop. 218 at 39, Prop. 219 at 37.

Section 218.211/219.211: RecordkcCDin!! and Reporting. Existing Section 218/219.211 contains various recordkeeping and reporting requirements. 35 111. Adm. Code 218.11 

### J, 219.111. The Board below separately summarizes proposed amendments to these provisions. 

### See Prop. 218 at 39-50, Prop. 219 at 37-48.



### Subsections (c). 

### (dl. The Board proposes to amend these subsections "to provide that, for flat wood paneling coating lines, YOM content infonnation shall be maintained and/or reported in terms of weight of YOM per volume ofcoatings or solids, as applicable, as applied35

each day on each coating line." SR at 20; 

### see Prop. 218 at 42-46, Prop. 219 at 40-44. The Board also proposes to correct a spelling error in Section 218.211 (c)(3)(A). SR at 20; 

### see Prop. 218 at 43.



### Subsection (el. The Board proposes to amend this subsection "to provide that flat wood paneling coating lines complying pursuant to Section 218/219.207 [Alternative Emissions Limitations] shall comply with the recordkeeping and reporting requirements set forth in subsection (e)." SR at 20; 

### see Prop. 218 at 46-47, Prop. 219 at 44-45.



### Subsection (gl. The Board proposes to add a new subsection (g) establishing "recordkeeping and reporting requirements for flat wood paneling coating lines subject to the work practice requirements set forth in Section 218/219.217." SR at 20; 

### see Prop. 218 at 49-50, Prop. 219 at 48.

Section 218.2121219.212: Cross-Line Averaging to Establish Compliance for Coating Lines. Existing Section 218/2 I 9.212 contains provision for averaging across specified coating lines in order to establish compliance. 35 Ill. Adm. Code 218.212, 219.212. The Board proposes to amend subsection (a) "to provide that the cross-line averaging alternative is not available to flat wood paneling coating lines." SR at 21; 

### see Prop. 218 at 50-54, Prop. 219 at 48- 53.

Section 218.217/219.217: Wood Furniture Coating Work Practice Standards. Existing Section 218/2 I 9.217 establishes various work practice standards for wood furniture coating operations. 35 III. Adm. Code 218.217, 219.217. The Board first proposes to change the title ofthis Section to "Wood Furniture Coating and Flat Wood Paneling Coating Work Practice Standards." SR at 21; 

### see Prop. 218 at 54, Prop. 219 at 53. The Board below separately summarizes proposed amendments to the provisions ofthese sections. 

### See Prop. 218 at 54-57, Prop. 219 at 53-55



### Subsection rcl. In this re-designated subsection, the Board proposes an amendment providing that "the flat wood paneling coating lines are subject to the existing cleaning and work practice requirements in this Section." SR at 21; 

### see Prop. 218 at 55-56, Prop. 219 at 54.



### Subsection (dl. The Board proposes a new subsection "adding additional cleaning and storage requirements for flat wood paneling coating lines

... " SR at 21; 

### see Prop. 218 at 56, Prop. 219 at 54-55. Specifically, the Board proposes to require "that such coating lines minimize spills ofVOM containing coatings, thinners, and cleaners, minimize emissions of YOM during cleaning activities, and keep mixing vessels which contain YOM coatings and other materials closed except when specifically in use." SR at 21; 

### see Prop. 218 at 56, Prop. 219 at 54.

Subpart H: Printing and Publishing

Existing Subpart H of Parts 218 and 219 addresses YOM emissions from various printing and publishing sources. 

### See 35 111. Adm. Code 21 8.401-4 II, 219.401-4 11. For this subpart, the Board proposes a number ofamendments and the addition of new subsections addressing36

lctterpress printing lines. 

### See Prop. 218 at 57-129, Prop. 219 at 55-130. The Board separately addresses thcse amcndments and additions in the following subsections of this opinion.

Flexographic and Rotogravure 

### Printing.

lnlroduclio/l. The Agency stated that "[f]lexible packaging mcans any package or part of

a package, the shape of which can be readily changed." TSD at 4. The Agency further stated that this packaging "includes, but is not limited to, bags, pouches, lincrs, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination of these materials." Id. The Agency also indicated that "[s]hrink-wraplabels or wrappers (but not self-adhesive labels) printed on or in-line with a flexiblc packaging printing press are also considercd to be flexible packaging." Id. Thc Agency stated, however, that the following items

are not flexible packaging: "cartons, gift wraps, hot stamp foils, wall coverings, vinyl products, decorativc laminates, floor coverings, or tissuc products." ld. at 5.

The Agency characterized rotogravure printing as using "an image etched or engraved into a plate or cylinder." TSD at 5. The Agency stated that "[i]nks, coatings, and adhesives may be applied to a substrate through the rotogravure process." Id. The Agency described flexographic printing as the use of "an image raised above the level ofthe printing plate, with the image carrier made ofrubber or other flexible material." Id. The Agency distinguished the two in part by stating that "[f]lexographic printing is better suited to short production runs, in contrast to rotogravure printing, which is more useful for long runs." !d. The Agency claimed that "YOM emissions for both types of printing originate from the drying of inks as well as solvents used to clean presses and other components." Id.

The Agency citcd the CTG to state that "the use of waterbased inks is increasing." TSD
at 5, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. Howcver, the Agency also noted that "[m ]any facilities use hundreds ofdifferent 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." TSD at 5, citing Control Techniques Guidclines for Flexible Packaging Printing, United States Environmcntal Protection Agency, Office ofAir Quality Planning and Standards, Scptember 2006.

The Agency thus stated that "most YOM control for flexible package printing is achieved through the use of add-on control devices." TSD at 5. The Agency indicated that most ofthc YOM emitted through these processes "is captured through evaporation in a dryer, along with hoods and other collection devices for solvent that evaporates elsewhere in the printing process." ld. The Agency claimed that 

### "[0]lder presses frequently do not allow for the same level of capture as newer installations do." Id. However, the Agency cited the CTG to claim that "'[t]here have been significant improvements in capture cfficiency offlexographic presses and rotogravure presses' sincc USEPA's most recent review ofthose operations." Id., citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency further cited the CTG to state that, "[s]ince 

### J990, many vendors have guaranteed capture efficiency of37

85 to 90 perccnt without use of a permanent total enclosure." TSD at 5, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, Septembcr 2006. The Agency argued that control devices can now attain control efficiencies ofat least 95 percent." TSD at 5, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006.



### Current Regullltions. The Agency stated that Illinois regulations currently "cover all flexographic, packaging rotogravure, and publication rotogravure printing." TSD at 4, 17 (§§2.3, 5.3). The Agency further stated that these different printing operations have identical YOM content limits on ink but differ in their add-on control requirements: "flexographic printers are required to get 60 percent overall YOM reduction, packaging rotogravure are required to get 65 percent overall reductions, and publication rotogravure must achieve 75 percent overall reduction." 

### ld.; see 35 III. Adm. Code 21 8.401 (a)(1), (c)(4), 219.40J(a)(I), (c)(4).



### Summllry of ProposedAmendments Addressing Flexogmphic lind Rotogravure Priming. The Agency stated that 

### its proposal "separates out flexible packaging printing from the existing flexographic and rotogravure regulations" TSD at 17; 

### see id. at 4, Bloomberg Test. at 

### 5; see generally Prop. 218 at 57-76, Prop. 219 at 55-75. The Agency argued that "any flexographic or rotogravure operation that is not printing on flexible packaging will not see a change to the applicable regulations." 

### ld. The Agency indicated, however, that "[s)ources that print on flexible packaging will need to meet either a tightened ink YOM content or add-on control requirement." 

### ld.; see SR at 8. The Agency stated that the required efficiency ofthe add-on control "will depend on both the date of construction, at the source, ofthe press and the control device." TSD at 

### J7; 

### see Bloomberg Test. at 6. The Agency claimed that these factors reflect "that presses and control devices already installed at the souree might not have been designed to obtain capture and control effieiencies as high as are currently obtainable" TSD at 17. The Agency thus suggested that sources should not need to upgrade existing control devices. Tr.1 at 15-16.

The Agency stated that "[t)he proposcd regulations also require that printing lines that
meet the CTG's prescribed applicability threshold comply with work practice requirements for cleaning materials." TSD at 5; 

### see Bloomberg Test. at 6. The Agency further stated that these practices include "keeping solvent containers closed except when filling, draining or condueting cleaning operations, keeping used shop towels in closed containers, and conveying cleaning materials from one location to another in closed containers or pipes." TSD at 17, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency stressed that "the applicability level for such work practices in much lower, at 15 pounds per day, as compared to the applicability thresholds of25 tons per year potential to emit or 100 tons per year maximum theoretical emissions for the remainder ofthe rule." Bloomberg Test. at 6.



### Section 218.4011219.401: Flexogmphic and Rotogravure Printing. Existing Section 218/219.401 addresses YOM emissions from flexographic and rotogravure printing. 35111. Adm. Code 218.401, 219.401. The Board proposes to amend this provision "to separate the requirements that are applieable prior to the new compliance date from those applicable after the38

new compl iance date. SR at 21. Below, the Board summarizes those proposed amendments on a subsection-by-subsection basis.

Subsection (a). The Board proposes to amend this subsection to require that, "on and after May I, 2010, owners and operators of flexographic and rotogravure printing lines that do
not print flexible packaging and that are complying with subsection (a) shall comply with the existing YOM regulations" SR at 21; see Prop. 218 at 57, Prop. 219 at 55-56. On the basis of first-notice commcnts, however, the Board has concurred in extending this deadline to August I, 2010. The Board also proposes that "[0]wners and operators offlexographic and rotogravure printing lines that print flexible packaging or that print flexible packaging and non-flexible packaging on the same line shall restrict the YOM content ofcoatings and inks to .8 kg YOM/kg solids applied or .16 kg YOM/kg materials applied or less." SR at 21-22; see Prop. 218 at 57-58, Prop. 219 at 56.

Subsection (b). The Board proposes to amend this subsection to require that, "on and after May], 2010, owners and operators offlexographie and rotogravure printing lines that do
not print flexible packaging and that are complying with subsection (b) shall comply with the existing weighted averaging requirements." SR at 22; see Prop. 218 at 58-62, Prop. 219 at 56- 61. On the basis offirst-notice comments, however, the Board has concurred in extending this deadline to August 1, 2010. The Board also seeks to require that



### [0)wners and operators of flexographic and rotogravure printing lines that print flexible packaging, or that print flexible packaging and non-flexible packaging on the same line, and that are complying with subsection (b) shall not apply coatings

or inks on the subject printing line unless the weighted average, by weight, YOM
content ofall coatings and inks as applied each day on the subject printing line does not exceed the YOM limitations specified in the amendments to subsection (a) ofthis Section. SR at 22; see Prop. 218 at 58-62, Prop. 219 at 56-61.

The Board also proposes specific "equations for calculating the weighted average YOM content for such lines." SR at 22; see Prop. 218 at 58-62, Prop. 219 at 56-61. Finally, the Board proposes a number of non-substantive corrections to the existing language. See SR at 22 (noting typographical and spacing errors).

Subsectioll (c). The Board proposes to amend this subsection to require that, "on and after May I, 2010, the owner or operator of a flexographic or rotogravure printing line that does not print flexible packaging and that is complying with subsection (c) shall equip the printing line with a capture system and control device that complies with the existing control efficiency requirements." SR at 22; see Prop. 218 at 62-65, Prop. 2]9 at 61-64. On the basis offirst-notice comments, however, the Board has concurred in extending this deadline to August I, 20 IO. The Board seeks also to amend this provision by requiring that "[t)hc owner or operator ofa flexographic or rotogravure printing line that prints flexible packaging shall equip the printing line with a capture system and control device that provides an overall reduction in YOM emissions of 65-80 percent, depending on the dates that the printing line and control system were first constructed at the subject source." SR at 22-23; see Prop. 218 at 62-65, Prop. 219 at 61-64. The Board also proposes to require that "[t)he owner or operator of a flexographic or rotogravure39

printing line that prints flexible packaging and non-flexible packaging on the same line shall comply with the overall control efficiency requirements set forth in either [proposed] subsection (c)(I)(D) or [proposed] subsection (c)(3) ofthis Section, whichever is more stringent." SR at 23,

see Prop. 218 at 62-65, Prop. 219 at 61-64.

The Board also proposes to amend subsection (c)(6) "to specify the printing lines that are required to perform testing pursuant to this subsection." SR at 23; see Prop. 218 at 64-65, Prop. 219 at 63-64.

Subsectioll (d). The Board seeks to add a new subsection (d). The Board proposes "that YOM-containing cleaning materials associated with flexographic or rotogravure printing lines that print flexible packaging or print flexible packaging and non-flexible packaging on the same line shall be kept, stored, and disposed of in closed containers, and conveyed from one location
to another in closed containers or pipes." SR at 23; see Prop. 218 at 65, Prop. 219 at 64.

Sectioll 218.4021219.402: ApplicabiliD'. Existing Section 218/219.402 addresses applicability of various requirements to flexographic and rotogravure printing lines. 35 III. Adm. Code 218.402, 219.402. The Board proposes to add this section a subsection (b) providing that

the limitations of Section 218/2 I 9.40 I(d) apply to all flexographic and rotogravure printing lines that print flexible packaging or print flexible packaging and non-flexible packaging on the same line at sources where the combined emissions of YOM from all flexographic and rotogravure printing lines total 6.8 kg/day (15 Ibs/day) or more, in the absence of air pollution control equipment. SR at 23; see Prop. 2] 8 at 66, Prop. 2] 9 at 65.

Sectioll 218.4031219.403: Compliallce Schedule. Existing Section 2] 8/219.403 establishes a compliance schedule for owners and operators of various flexographic and rotogravure printing lines. 35 III. Adm. Code 218.403, 219.403. The Board proposes to add subsections (e), (t), and (g) to "establish May I, 2010, as the compliance date for the requirements set forth in the proposed amendments." SR at 23; see Prop. 218 at 67-68, Prop. 219 at 66. On the basis of first-notice comments, however, the Board has concurred in extending this deadline to August 1,2010.

Sectioll 218.404/219.404: Recordkeepillg alld Reportillg. Existing Section 218/219.404 addresses recordkeeping and reporting requirements applicable to various printing lines. 35 Ill. Adm. Code 218.404,219.404. The Board below separately addresses those amendments on a subsection-by-subsection basis.

Subsectioll (b). The Board proposes to amend the subsection to refer to "recordkeeping and reporting compliance dates for printing lines subject to the limitations in the proposed amendments to Section 218/219.40 I." SR at 24; see Prop. 218 at 68-70, Prop. 219 at 67-69. In its first motion to amend, the Agency responded to a request from industry representatives by proposing to amend subsection (b)(l )(B) "by deleting references to instruments by which owner[s] or operators may calculate the volume or weight ofcoatings and inks as applied each day on subject coating lines, as such instrumcntation is not currently available to sources." Mot.40

Amend I at 4-5**(~6);** see Tr.1 at 19-20. The Board granted the motion, and the amendment is reflected in the subsection.

Subsectiolls (ci, (d). The Board proposes to amend subsections (c) and (d) "to clarify that the owner or operator of a printing line subject to the requirements in Section 218/219.40 I(a)(2)(B)or (b)(3) shall certify in accordance with subsection (c)( I) or (d)(I), as applicable, even ifthe owner or operator of such line subm itted a certification prior to January I, 2010." SR at 24; see Prop. 218 at 70-73, Prop. 219 at 69-72. In its first motion to amend, the Agency responded to a request from industry representatives by proposing to amend subsection (d)(l)(D) "by deleting references to instruments by which owner[s] or operators may calculate the volume or weight of coatings and inks as applied each day on subject coating lines, as such instrumentation is not currently available to sources" Mot. Amend I at 4-5**(~6);** see Tr.1 at 19- 20. The Board granted the motion, and the amendment is reflected in the subsection.

Subsectioll (e). The Board proposes to amend subsection (e) "to provide that ifthe

owner or operator of a printing line is not required to perform testing of a capture system and control device pursuant to Section 218/219/40 I(c)(6), the owner or operator shall submit a certification to the Agency that includes specified information" listed in proposed subsection (e)(l)(B). SR at 24; see Prop. 218 at 73-74, Prop. 219 at 72-73.

The Board also proposes to add a new subsection (e)(4) providing that, "by May 1,2010,

owners or operators of printing lines subject to Section 218/219.40 I(c)(3) or (c)(4) shall submit
to the Illinois EPA records documenting the dates each subject printing line and control device

were constructed at the subject source." SR at 24; see Prop. 218 at 75, Prop. 219 at 74. On the basis of first-notice comments, however, the Board has concurred in extending this deadline to August 1,2010.

Subsectioll (f). The Board also proposes to add a new subsection (f) to establish "record keeping and reporting requirements for any owner or operator ofa flexographic or rotogravure printing line that prints flexible packaging or prints flexible packaging and nonflexible packaging on the same line and which is exempt from the limitations of Section 218/219.401(d) because ofthe criteria in Section 21 8/21 9.402(b)." SR at 24; see Prop. 218 at 75-76, Prop. 219 at 74-75. In its first motion to amend, the Agency responds to comment from industry reprcsentatives by proposing to remove from subsection (f)(2) "the requirement that a
source include in its notification to the Illinois EPA calculations showing an exceedance ofthe applicability threshold." Mot. Amend I at 5-6**(~7).** The Board granted the motion, and the amendment is reflected in the subsection.

Subsectiofl (g). The Board also proposes to add a new subsection (g) to establish "recordkceping and reporting requircments for any owner or operator ofa printing line subject to the limitations of Section 218/219.401 (d)," which addresses YOM-containing cleaning materials. SR at 24-25; see Prop. 218 at 76, Prop. 219 at 75.

Subsectiofl (11). The Board also proposes to add a new subsection (h) providing in its entirety that "[a] 11 records required by subsections (f) and (g) shall be retained for at least three41

years and shall be made available to the Agency upon rcquest." Prop. 218 at 76, Prop. 219 at 75;



### see SR at 25.

Lithographic Printing.

Introduction. The Agency stated that "[I]ithography is a planographic method of printing; that is, the printing and nonprinting areas are essentially in the same plane on the surface ofa thin 'lithographic' plate." TSD at 3. The Agency further stated that the two areas
are distinguished chemically by rendering the image area water repellent and the nonimage arca watcr receptive." Id.

The Agency described the category of offset lithographic printing: "ink is transferred from the lithographic plate to a rubber-covered 'intermediate' or 'blanket' cylinder and then to the substrate." TSD at 3. The Agency stated that this "[t]ransfer ofthe ink from the lithographic plate to the blanket cylinder, rather than directly to the substrate, is the offset characteristic of this type ofprinting." Id.

The Agency stated that offset lithographic printing itself can be categorized by the

manner in which the substrate is fed to the press. TSD at 3. The Agency indicated that, "[i]n sheet-fed printing, individual sheets ofpaper or other substrate are fed to the press. In web printing, continuous rolls of paper are fed to the press and the paper is cut to size after it is printed." Id.

The Agency stated that pigments, vehicles, binders, and other additives comprise lithographic inks. TSD at 3. The Agency further stated that pigments include both organic and inorganic materials. 

### Id. The Agency indicated that "[I]ithographic inks may be heatset, where heat is required to set the ink, or non-heatset, where the inks are set by absorption into the substrate by oxidation or other methods not requiring added heat." Id. The Agency claimed that "[h]eatset inks may contain up to 45 percent YaMs." Id. The Agency also listed the characteristics of non-heatset inks: higher boiling points, less pastiness, and usually less than 35 percent YOM content. Id. The Agency also stated that "[mlost non-heatset inks used in sheetfed printing are below 25 percent YOM." Id.

The Agency stated that printing operations apply a fountain solution to a lithographic plate to render nonimage areas unreceptive to ink. TSD at 3. Thc Agency further stated that, "[s]ince printing inks are oil-based and oil is repelled by water, the fountain solution is waterbased." Id. The Agency indicated that these fountain solutions also contain "small quantities of gum arabic or synthetic resins, acids, and buffer slats to maintain the pH of the solution, and a wetting agent or 'dampening aid' to enhance the spreadability ofthe fountain solution across the print plate" Id. The Agency stated that the dampening aid reduces the surface tension ofwater and increases viscosity. Id.

The Agcncy stated that, since the 1950s, isopropyl alcohol, a YOM, "has been used as the primary dampening aid." TSD at 3. The Agency further stated that "[e]thanol and normal propyl alcohol have also been used in this capacity." Id. The Agency indicated that, "[b]efore the 1980s, concentration of alcohol in the fountain solution could range from 0 to 35 percent or42

higher, with most presses using between 15 and 20 percent." 

### ld. The Agency argued that printers have since reduced the alcohol content of fountain solution and have "often replaced alcohol completely with othcr dampening aids." 

### ld. at 4.

The Agency stated that printers use cleaning solutions "to remove excess printing inks, oils, and paper components from press equipment" and also "to wash the blankets, the rollers, the outside ofthe presses, and to remove excess ink residue between color changes." TSO at 4. The Agency further stated that these "solutions are petroleum-based solvents, often mixed with detergent and/or water." ld. The Agency indicated that "[t]he cleaning compound may be a single solvent, such as kerosene, or a combination of solvents." 

### Jd

..

Current Regulations. The Agency stated that Illinois now "has regulations covering all types of lithographic printing in the NAAs, with an applicability level of I 00 PPO (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." TSO at IS.

Regarding fountain solution, the Agency stated that current regulations applicable to heatset web presses in the two NAAs "require that subject sources use no more than 1.6 percent alcohol, or 3 percent ifthe fountain solution is refrigerated." TSO at 4; see 35 III. Adm. Code 218.407(a)(I)(A)(i), (ii); 219.407(a)(I)(A)(i), (ii). The Agency further stated that "fountain solution using only alcohol substitutes may use up to 5 percent YOM." TSO at 4; see 35 111. Adm. Code 218.407(a)(I)(A)(iii), 219.407(a)(I)(A)(iii). The Agency also stated that "[n]onheatset web presses cannot use any alcohol and are subject to the same 5 percent YOM limit." TSO at 4; see 35 

### III. Adm. Code 218.407(a)(2), 219.407(a)(2). Finally, "[s]heet-fed presses are limited to 5 percent YOM content or 8.5 percent ifthe solution is refrigerated." TSO at 4; see 35 III. Adm. Code 218.407(a)(3), 219.407(a)(3).

Summary of ProposedAmendments Addressing Lithographic Printing. The Agency stated that its "proposal does not reduce the applicability threshold for add-on control devices used by heatset presses." TSO at IS. The Agency thus argued that "no new lithographic printing units will need to add controls." 

### ld.; see SR at 8. The Agency indicated, however, that "new control devices on heatset web lithographic presses will need to meet a 95 percent control efficiency instead ofthe current 90 percent limit." TSO at 15; see Bloomberg Test. at 3. The Agency expressed the belief that "control devices in existence today can meet the 95 percent limit, but at the request of printing industry representatives, the Agency has agreed not to ask existing sources to meet the higher control efficiency." TSO at 15; see Tr.l at 14-15.

The Agency stated that its proposal establishes "a new applicability threshold of IS PPO for fountain solution and cleaning solution requirements for all lithographic printing operations." TSO at 15; see Bloomberg Test. at 3. The Agency further stated that "[t]he requirements are the

same as are already present in the Illinois regulations, other than a correction to the fountain solution limits that changes their measurement from 'by volume' to 'by weight.''' TSO at 15.

The Agency emphasized that "sources between 15 and 100 PPO will be able to take advantage of several new exclusions pertaining to fountain and cleaning solutions." TSO at IS.

### 43

The Ageney stated that "[ s]heet-fed presses that print substrates no larger than 11 inehes by 17 inches and any lithographic press with a fountain solution reservoir of no larger than one gallon

are not required to comply with the fountain solution requirements." Id.; see Bloomberg Test. at 4. The Agency further stated that "sourees in this [15 to 100 PPD] 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." TSD at 15. Finally, the Agency also stated that "[a] II sueh

sources will also be able to use up to 100 gallons ofcleaning solution per year that do not meet either the YOM content or vapor pressure requirements." Jd. at 15-16.

The Agency stated that, "[b]ecause ofthe new exclusions that apply only between 15 and 100 PPD, even subject sources in this group must continue to calculate emissions to ensure they do not exceed the 100 PPD threshold and lose the exclusions." TSD at 16. The Agency further stated that "[s]ources may opt out ofthe exclusions ifthey do not wish to make use ofthem, and thus would not need to calculate emissions in this fashion." Jd.; see Bloomberg Test. at 4.

The Agency stated that "[s]ources which fall below one ofthe applicability limits, and

are thus exempt from one or more control requirements, must eertify this exemption to the Illinois EPA through ealculations showing that their emissions will not exceed the applicable YOM threshold." TSD at 16. The Ageney further stated that "[t]hese ealculations must include all YOM emissions, including inks, fountain solution, and cleaning solvents, and are determined

on a monthly basis." Id.

The Agency emphasized that current regulations recognize "that the substrate retains

some ofthe YOM present in the ink, and thus a retention factor of0.95 is used when ealeulating emissions from non-heatset inks, and a factor of 0.20 is used when calculating emissions from heatset inks." TSD at 16; see Bloomberg Test. at 4. The Agency noted that current regulations also contain "a faetor recognizing that YOM remains on solvent-laden rags that are stored and disposed ofproperly" TSD at 16; see Bloomberg Test. at 4. The Ageney stated that "[t]hese factors continue to be allowed for determination ofapplicability." TSD at J 6. The Agency also noted that its "proposal adds emission adjustment factors to be used in other situations when not determining applieability (such as Annual Emissions Reports and permit limits)." Id. The Ageney claimed that "[t]hese factors take into account carryover ofVOM from automatie blanket wash and fountain solutions into the dryer and control device." Id., citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Ageney, Offiee ofAir Quality Planning and Standards, September 2006; see Bloomberg Test. at 5.

Section 218.405/119.405: Lithographic Printing: Applicability. Existing Section 218/219.405 addresses applieability ofvarious provisions to lithographic printing operations. 35 III. Adm. Code 218.405, 219.405. The Board below separately addresses those amendments on a sUbsection-by-subsection basis.

Subsections (a), (bi. The Board first proposes "to separate requirements that are applicable prior to the new compliance date from those applieable after the new compliance date." SR at 25; see Prop. 218 at 76-79, Prop. 219 at 75-78. On the basis of first-notice eomments, the Board has coneurred in extending this compliance date to August 1,2010. The44

Board also seeks to delete the current subsection (a), which establishes "requirements that were only applicable until March 15, 1996, and refonnatting/renumbering the remaining subsections accordingly." SR at 25; see Prop. 218 at 76-79, Prop. 219 at 75-78.

.
Subsection (c). The Board proposes to add a new subsection (c)(I) providing that, on and after May I, 20 10,

the requirements in Section 21 8/21 9.407(a)( 1)(B) through (a)(I )(E) and 218/219.407(b) and all appl icable provisions in Sections 218/219.408 through 218/219.411 ofthis Subpart shall apply to all owners or operators of heatset 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)) ever exceed 45.5 kg/day (100 Ibs/day), before the application ofcapture systems and control devices. SR at 25; see Prop. 218 at 78, Prop. 219 at 77.

On the basis of first-notice comments, however, the Board has concurred in extending this deadline to August 1, 2010. The Board proposes in new subsection (c)(2) that, on and after May 1,2010,

Sections 21 8/2 I9.407(a)(1 )(A), 218/219.407(a)(2) through (a)(5), and all applicable provision sin Sections 218/219.408 through 218/219.4 I 1, shall apply to all owners and operators of lithographic printing lines at sources where the combined emissions of YOM from all lithographic printing lines at the source (including solvents use for cleanup operations associated with the lithographic printing lines) cver total 6.8 kg/day (15 Ibs/day) or more. SR at 25; see Prop. 218
at 78, Prop. 219 at 77.

Again, on the basis of first-notice comments, the Board has concurred in extending this deadline
to August 1,20 I

### O.

Finally, the Board proposes in new subsection (c)(3) that,

at sources where the combined emissions of YOM from all lithographic printing line(s) at the source equal or exceed 6.8 kg/day (15 Ibs/day) but do not exceed 45.5 kg/day (100 Ibs/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. SR at 25-26; see Prop. 218 at 78-79, Prop. 219 at 77-78.

In its first motion to amend, the Agency proposed to correct cross-references in Sections 218/219.405(c) (1 ) and (c)(2) to Section 218/219.408, which the Agency seeks to repeal. Mot. Amend I at 6-7 (18); see Prop. 218 at 89, Prop. 219 at 88-89. The Agency states that the crossreferences had been "inadvertently left in the rule." Mot. Amend 1 at 6. The Board granted the motion, and the subsection reflects the amendments.45

Sectioll 218.406/219.406: Provisiolls Applvillg to Heatset Web Offset LitllOgraphic Prilltillg Prior to March 15.1996. The Board proposes to repeal this section, "as it contains requirements that were applicable prior to March 15, 1996." SR at 26; see Prop. 2 I8 at 79-86, Prop. 219 at 78-85.

Sectioll 218.407/219.407: Emissioll Limitatiolls lIml COlltrol Requiremellts (or Lithographic Prilltillg Lilies 011 alldAfter March 15, 1996. Existing Section 218/219.407 establishes various requirements applicable to lithographic printing lines on and after March 15, 1996. 35 III. Adm. Code 218.407,219.407. The Board first proposes to amend this section "by deleting references to the previous compliance dale ofMarch 15, 1996, and separating requirements that are applicable prior to the new compliance date from those applicable after the

new compliance date." SR at 26; see Prop. 218 at 86-89, Prop. 219 at 85-88. The Board also proposes to change "the YOM content limitations for fountain solutions fTom 'by volume' to 'by weight,' as USEPA has informed that Illinois EPA that this is the appropriate way to measure the limit." SR at 26; see Prop. 218 at 86-89, Prop. 219 at 85-88.

Subsectioll (a). The Board specifically proposes to amend subsection (a)(1 )(C) to provide that

on and after May 1, 2010, owners or operators of subject heatset web offset lithographic printing lines shall install and operate an afterburner

... so that YOM emissions from the press dryer exhaust are reduced by 90-95 percent, by weight, depending on the date that the afterburner

... was first constructed at the subject
source, or to a maximum afterburner exhaust outlet concentration of20 ppmv (as carbon). SR at 26; see Prop. 218 at 87, Prop. 219 at 86.

On the basis of first-notice comments, however, the Board has concurred in extending this deadline to August 1,2010. The Board also proposes to amend subsection (a)(1 )(D) in order "to delete references to monitoring requirements already set forth in Section 218/219.410." SR at 26; see Prop. 218 at 87, Prop. 219 at 86.

In addition, the Board seeks to amend subsection (a)(4) to provide that,

on and after May I, 2010, owners or operators of sources that meet the applicability criteria in Section 21 8/2 I9.405(c)(3) and do not certify pursuant to Section 2181219.4 

### JJ(g)(1 )(B) that the source will not make use ofany ofthe exclusions in Section 2 I 8/219.405( c)(3) shall not cause or allow the use of a 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 vapor pressure limitation. SR at 27; see Prop. 218 at 88, Prop. 219 at 87.

On the basis offirstcnotice comments, the Board has concurred in extending this deadline to August 1, 2010.46

The Board also proposes to amend subsection (a)(5) in order "to specify that the storage and disposal requirements for cleaning materials apply except when such materials are spccifically in use." SR at 27; see Prop. 218 at 88, Prop. 219 at 87

Subsection (b). The Board specifically proposes to amend subsection (b) to provide that

on and after May 1, 2010, owners or operators of subject 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 other control device was first constructed at the subject source, or to a maximum afterburner exhaust outlet concentration of20 ppmv (as carbon). SR at 26; see Prop. 218 at 88, Prop. 219 at 87-88.

On the basis offirst-notice comments, the Board has concurred in extending this deadline to August 1,2010.

Section 218.408/219.408: Compliance Schedule (or Lithof!raohic Printing On and After March 

### 15,1996. The Board proposes to repeal this section in its entirety, "as the pertinent compliance dates are set forth in Section 218/219.405." SR at 27; see Prop. 218 at 89, Prop. 219
at 88-89; see also Prop. 218 at 76-79, Prop. 219 at 75-78 (proposed Section 218/219.405).

Section 218.4091219.409: Testing (or Lithographic Prilltillg On lindAfter March 15, 

### 1996. Existing Section 218/219.409 addresses testing for lithographic printers. 35 

### llI. Adm. Code 218.409, 219.409. The Agency originally proposed to revise this section by "deleting a reference to the previous compliance date ofMarch 15, 1996 in the title

.... " SR at 27; see Prop. 218 at 89, Prop. 219 at 89.

In its first motion to amend, the Agency also proposed amending subsections (a) and (c) in order to clarify "when testing pursuant to such Section shall be performed" Mot. Amend I at 7-8 (19). In the same motion, the Agency also proposed to amend subsection (c) "by correcting

an internal cross-reference." 

### Jd. The Board granted the motion, and the subsection reflects the amendments.

Section 218.410/219.410: Monitoring Requirements (or Lithographic Prillting. The Agency's original rulemaking proposal did not seek to amend Section 218/219.410, which addresses monitoring requirements for lithographic printers. See SR at 27, Prop. 218 at 91, Prop. 219 at 91; see also 35111. Adm. Code 218.410, 219.410. In its first motion to amend, the Agency responded to a comment from industry representatives by noting "several incorrect internal cross-references within the current Section 218/219.410." Mot. Amend J at 8 (110). Accordingly, the Agency "proposes amending subsections (b)(J), (b)(2), (e)(J)(B), and (e)(2) to correct the cross-references." Jd. at 8-14. The Board granted the motion, included Section 218.410/219.410 in its first-notice opinion and order, and corrected the cross-references identified by the Agency.47

Section 218.411/219.411: RecordkeepinR and Reporting (or Lithographic Printing. Existing Section 218/219 All addresses recordkeeping and reporting requirements applicablc to lithographic printers. See 35 Ill. Adm. Code 218.411, 2190411. Generally, the Board proposes to amend "this Section by deleting references to the previous compliance date ofMarch 15, 1996, and clarifying the requiremcnts that apply to sources prior to the new compliancc date and those that apply on and aftcr the new compliance date" SR at 27-28; see Prop. 218 at 92-114, Prop. 219 at 91-114. On the basis of first-notice comments, the Board has concurred in extending the compliance date to August 1, 2010.

Subsection (a). Existing subsection (a) addresses lithographic printing lines exempt from the limitations of Section 218/2190407 on the basis of criteria in Section 218/2) 90405. See 35 III. Adm. Code 218.4II(a), 219AII(a). The Board proposes to add to this subsection "the equation for calculating maximum theoretic emissions of YOM, which was previously contained in Section 218/219.406." SR at 28; see Prop. 218 at 93-95, Prop. 219 at 92-94. In its first motion to amend, the Agency proposes to amend the key to that equation "by deleting refcrence to instruments by which owners or operators may calculate the volume of inks as applicd each day

on subject printing lines, as such instrumentation is not currently availablc to sources." Mot. Amend I at 14-15 ('\111). The Board granted the motion, and the subsection reflects the amendment.

Subsection (b). The Board proposes "adding a new subsection (b), which contains recordkeeping and reporting provisions for printing lines that are exempt on and after May I, 201 O

... " SR at 28. On the basis of first-notice comments, however, the Board has concurred in extending this date to August I, 2010. Proposed subsection (b)(l) specifically addresses printing lines exempt under Section 218.405(c)(2). In addition to standard recordkeeping and reporting rcquirements, thc Board in that provision

proposes an emission adjustment factor to be used when determining YOM 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 towcls ifthe YOM composite vapor pressure of each associated cleaning solution is less than 10 mmHg measured at 20°C (68°F) and the shop towels are kept in closed containers. SR at 28; see Prop. 218 at 95-100, Prop. 219 at 94-100.

At the request of industry representatives, the Agency also proposed in subsection (b)(l)(C) an alternative to the YOM emissions calculations in subsection (b)(J)(B): "a source may determine that it emits bclow 6.8 kg/day (l5Ibs/day) of YOM ifit complies with material use limitations during each month." SR at 28, Tr.1 at 21; see Prop. 218 at 97, Prop. 219 at 96-97. The Agency sought to provide that this material use alternative is limited to sources with only a single type of lithographic printing operation. SR at 28; see Prop. 218 at 97, Prop. 219 at 96. The Agency proposcd that, "[i]f a source exceeds the material use limitation in any given month, the source shall complete emissions calculations pursuant to subsection (b)(l )(B) within 

### J5 days ofthe end ofthat month." SR at 28; see Prop. 218 at 97, Prop. 219 at 96. The Agency further proposed that a source exceeding the limitations for six consecutive months is no longer eligible to rely on the alternative. SR at 28-29; see Prop. 218 at 97, Prop. 219 at 96-97.48

In its first motion to amend, the Agency noted that "USEPA prcviously recommended that material use thresholds for such lines be conservativcly based on the pound pcr day applicability threshold." Mot. Amend I at I5**(~12).** The Agency stated that "US EPA has now determined that a 90 percent emission equivalency level is acceptable for both lithographic and letterpress printing operations." Jd. The Agcncy sought to amend subsection (b)(I )(C)(i) and (b)(I )(C)(ii) of its proposal to reflect that subsequent USEPA determination. Jd. at 15- 16.

Also in its first motion to amend, the Agency respondcd to a comment by industry rcprcscntatives by proposing to amend subsection (b) (I )(E). Mot. Amend I at 16**(~13).** Specifically, the Agency sought to remove "the requirement that a source include in its notification to the Illinois EPA calculations showing an cxceedance ofthe applicability thrcshold." Jd at 16-17. Responding to a question at the first hearing, the Agency clarified that, when a source reports an exceedance under this provisions, "they do not have to tell us how much they exceeded it by." Tr. I at 22. The Agency emphasized that this requirement intends chicfly to detennine whether a source is subject to the rule and not to determine the precise
amount of an exceedance. See id. at 22-23. The Board granted the Agency's motion, and the subsection reflects the amendments.

The Board also proposes a new subsection (b)(2) addressing "heatset web offset lithographic printing lines exempt pursuant to Section 218/219.405(c)(I) but not exempt pursuant to Section 21812 I 9.405(c)(2). SR at 29; see Prop. 218 at 98- 100, Prop. 219 at 98- I00. In addition to standard recordkeeping and reporting requirements, the Board in that provision

proposes an emission adjustment factor to be used when determining YOM emissions from inks used on lithographic printing line(s) at the source, and 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°P) and the shop towels are kept in closed containers." SR at 29; see Prop. 218 at 98-100, Prop. 219 at 98-100.

In its first motion to amend, the Agency responded to a comment by industry representatives by proposing to amend subsection (b)(2)(D). Mot. Amend 1 at I 5-17**(~14).** Specifically, the Agency seeks to remove "the requirement that a source include in its notification to the Illinois EPA calculations showing an exceedances ofthe applicability threshold." Jd.; see Tr.! at 22. The Board granted the motion, and the subsection reflects the amendment.



### Subsection (c). The Board proposes to redesignate the existing subsection (a)(2) as subection (c). Prop. 218 at 100-02, Prop. 2I9 at 100-02; see 35 III. Adm. Code 218.4]] (a)(2), 219.411 (a)(2). Thc Board amends this provision "to provide that the rccordkeeping requirements in subsections (c)(I) or (c)(2) do not apply to sources utilizing the material use limitations alternative. SR at 29; 

### see Prop. 218 at 100-02, Prop. 219 at 100-02. The Board also proposes to delete subsection (c)(3). SR at 29; 

### see Prop. 218 at 102, Prop. 219 at ]02.



### Subsection (d). Existing subsection (b) establishes requirements applicable to heatset web offset lithographic printing line(s) subject to Section 218/219.407(a)(I )(C) or (b)(1). See 35 III. Adm. Code 218.411(b), 219.41 1 (b). 

### In the re-designated subsection (d), the Board adds a49

requirement "that sources complying with the add-on control device requirements shall include in their initial certification to the Illinois EPA the date that the device was first constructed at the subject source." SR at 29; see Prop. 2 18 at 

### J02-04, Prop. 219 at 102-04. The Board also proposes to amend subsection (d)(3 )(0) "to change the frequency that owners or operators of heatset web offset lithographic printing lines complying with the add-on control device requirements are required to check the air flow direction or air pressure ofthe dryer and press
room from once a day to once per calendar month." SR at 29; see Prop. 218 at 104, Prop. 2 I9 at 104.

Subsection (e). Existing subsection (c) establishes requirements applicable to lithographic printing lines subject to Sections 218/219.407(a)(I )(A), (a)(2), or (a)(3). See 35 

### 111. Adm. Code 218.411 (c), 2 I9.4 11 (c). In the re-designated subsection (e), the Board "proposes amending subsection (e)(I)(C) to provide that a source subject to fountain solution YOM content limitations shall include in its initial certification a statement that the fountain solution will comply with the YOM content limitations in Section 2181219.407(a)(I )(A), (a)(2), or (a)(3), as applicable." SR at 30; see Prop. 218 at 105, Prop. 219 at 104. The Board also proposes to amend subsection (e)(2)(C) "to provide that the weight of each component used in a fountain solution batch shall be recorded by sources, ifapplicable." SR at 30; see Prop. 218 at 106, Prop. 219 at 106. In addition, the Board "proposes deleting subsection (e)(4)." SR at 30; see Prop. 218 at 107, Prop. 219 at 107.

Subsectioll (f). Existing subsection (d) establishes requirements for lithographic printing lines subject to Section 218/2 I9.407. 35 Ill. Adm. Code 218.4 

### J I(d), 219.411 (d). In the redesignated subsection (f)(l), the Board proposes an amendment "to specify that lithographic printing line cleaning operations that are excluded pursuant to Section 2 I 8/2 I9.405(c)(3)(C) are not required to submit a certification pursuant to subsection (I)." SR at 30; see Prop. 218 at 108, Prop. 219 at 107-08. In addition, the Board "proposes deleting subsection (f)( I)(A), 

### (1)( I)(C), and (f)(4), and amending the re-Iettered subsection (f)(I)(A) to provide that a source subject to the cleaning requirements in Section 218/219.407 shall include in its initial certification a statement that the cleaning solution will comply with the limitations in Section 2] 8/2 I9.407(a)(4)." SR at 30; see Prop. 218 at 108-10; Prop. 219 at 108-10.

In its first motion to amend, the Agency responded to a request from industry representatives. Mot. Amend I at 17-18**(~15).** The Agency proposed amending subsections (f)(2)(B) and (f)(2)(C) "by specifying that, for cleaning solutions used as-purchased, sources may
use manufacturer's specifications to determine YOM content and YOM composite partial vapor pressure." 

### !d. at 18- I9. The Board granted the motion, and the subsection reflects the amendment.

Subsectioll (g). The Board proposes to add a new subsection (g). The Board seeks to establish "recordkeeping and reporting requirements for owners or operators oflithographic printing line(s) subject to one or more of the exclusions set forth in Section 218/219.405(c)(3)." SR at 30; see Prop. 218 at 111-12, Prop. 2 I9 at 110-12. Specifically, the Board proposes that

[s]uch owners or operators shall submit an initial certification to the Illinois EPA, collect and record specified information for cach subject printing line, notify the50

Agency ifthe printing line ever becomes ineligible for the exclusions set forth in Section 218/219.405(c)(3), and, ifchanging between opting out of such exclusions and utilization of the exclusions, submit an additional certification, informing the lIlinois EPA of the change. SR at 30-31; see Prop. 218 at 111-12, Prop. 219 at 110-12.

In responding to a question at the first hearing, the Agency indicated that, as a source, "you would not have to report the information under [subsection) (g)(2)(A) if you did state that you would not be using the exclusion." Tr.1 at 16-18.

In its first motion to amend, the Agency responded to a request from industry representatives by proposing to amend subsection (g)(2)(A)(ii) "to correct a grammar mistake." Mot Amend 1 at 20**(~16).** Also in the first motion to amend, the Agency responded to an industry comment by proposing to amend subsection (g)(2)(B) "by removing the requirement that a source include in its notification to llIinois EPA calculations showing an exceedances of the applicability threshold." Id. at 20-21**(~17).** The Board granted the motion, and the subsection reflects the amendments.

Subsectioll (i). The Board also proposes to add a subsection (i). The Board seeks to establish "emission adjustment factors that may be used when calculating YOM emissions from heatset web offset lithographic printing operations for purposes other than the applicability thresholds in Section 218/219.405." SR at 31; see Prop. 218 at 112-14, Prop. 219 at 112-14.

Letterpress Printing.

Illtroductioll. The Agency stated that "[I)etterpress printing involves the use ofa reverse-imaged raised surface that is inked and then pressed against a substrate to transfer the image." TSD at 4 (§2.2). The Agency further stated that, compared with lithographic, flexographic, and rotogravure printing, "[I)etterpress operation make up a vcry small percentage of the printing industry." Id. Based on its source inventory, the Agency indicated that "no Ictterpress printing facility could be found in the Metro-East NAA, with very few ofthese facilities found even in the Chicago NAA." Id.

In testimony on bchalfofthe Agency, Mr. Bloomberg indicated that "the State is still required to promulgate the CTG regulations for this category." Bloomberg Test. at 5. He further stated that "lctterpress printing presses are often operated at the same source as lithographic printing[,) and many ofthc control options for lettcrpress printing are thc same as the control options for lithographic printing as well. This is especially true in tenns ofcleaning solutions. As such, the proposed rule would adopt most ofthe RACT recommendations of the CTG." Id.

The Agency stated that letterpress and lithographic printing operations use inks that are "very similar" and may both be accomplished through sheet-fed and web presses. TSD at 4. The Agency thus argued that "ink emission sources are similar" to those of lithographic printing. Id. The Agency filrther argued that, although "[I)etterpress operations do not use fountain solutions," they use cleaning solutions similar to those used in lithographic printing operations." TSD at 4; see Bloomberg Test. at5.51



### Currellt Regulatiolls. The Ageney stated that "[t]here are no speeifie Illinois regulations covering letterpress printing operations; any such operations would therefore be covered by Subpart IT, Section 218/219.301, or paper coating regulations. TSO at 16 (§5.2); 

### see 35 III. Adm. Code 218.204(e), 218.301,218.980-988, 219.204(e), 219.301,219.980-988.



### Summary of ProposedAmelldmellts Addressillg Letterpress Prilltillg. The Agency stated that its proposal addresses "both heatset and non-heatset letterpress operations." TSO at 16; 

### see Prop. 218 at 114-129, Prop. 219 at 114-30. The Agency further stated that the proposal "would require that heatset letterpress printers use an add-on control device if they meet the applicability requirements of25 TPY PTE plantwide." TSO at 16; 

### see SR at 8-9. The Agency believed that no operation in either ofthe two NAAs would be subject to this requirement. TSO
at 16.

The Agency further stated that "[a]lIletterpress printing operations of 15 PPO or more will be also required to abide by cleaning material Iimitations equivalent to those" applicable to lithographic printing sources emitting between 15 and 100 PPO. TSO at 16; 

### see SR at 9. Specifically, such sources would be required to use cleaning solutions containing no more than 70 percent YOM or having a maximum composite partial vapor pressure or less than 10 mm Hg. TSO at 16. In his testimony on behalfofthe Agency, Mr. Bloomberg stated that, because letterpress printing operations have never specifically been regulated in Illinois, this 70 percent content limit represents no loosening ofexisting standards. Bloomberg Test. at 5.



### SectioIl218.412/219.412: Letterpress PrintillgLilles: Applicability. The Board proposes a new Section 218/219.412 addressing the applicability ofthe proposed letterpress printing provisions. SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. Below, the Board summarizes those proposed additions on a subsection-by-subseetion basis.



### Subsection (aj. The Board proposes a new subsection (a)(I) providing "that the limitations in Section 218/219.413 through 218/219.4 16 apply to all owners ofoperators of heatset web letterpress printing lines if such lines (including solvents used for cleanup operations associated with such lines) at the source have a potential to emit 22.7 Mg (25 tons) or more of YOM per year." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. The Board also proposes a
new subsection (a)(2) providing that "Sections 218/219.413 through 218/219.416 apply to all

owners or operators of letterpress printing lines at sources where the combined emissions of YOM from all letterpress printing lines at the source (including solvents used for cleanup operations associated with the letterpress printing lines) ever equal or exceed 6.8 kg/day (15 Ibs/day), in the absence ofair pollution control equipment." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114.



### Subsectioll (b). The Board proposes a new subsection (b) providing "that the requirements of Section 218/21 9.413(a)(2) shall not apply to up to 416.3 liters (100 gallons) per year ofcleaning materials used on letterpress printing lines at a subject source." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114.52

Subsection (c). The Board proposes a new subsection (c) providing that, "on and after May 1, 2010, the record keeping and reporting requirements in Section 218/219.417 shall apply
to all owners or operators of letterpress printing Iine(s)." SR at 32; see Prop. 218 at 114, Prop. 219 at 114. On the basis of first-notice comments, however, the Board has concurred in extending this deadline to August 1,2010.

Subsection (d). The Board proposes a new subsection (d) providing that, "if a letterpress printing line at a source is or becomcs subject to one or more ofthe limitations in Section 218/219.413, the letterpress printing lines at the source are always subject to the provisions of Subpart H." SR at 32; see Prop. 218 at 114, Prop. 219 at 114.

Section 218.4131219.413: Emission Limitations and Control Requirements (or Letterpress Printing Lines. The Board proposes to add a new Section 218/219.4 I3 establishing various requirements for letterpress printing lines. SR at 32; see Prop. 2I8 at I 15-16, Prop. 219
at 115-16.

Subsection (a). The Board proposes a new subsection (a)(I) providing in part that

heatset web letterpress printing lines that meet the applicability requirements of Section 218/219.412(a)(I) shall maintain the air pressure in the dryer lower than the air pressure ofthe press room and install and operate an afterburner that reduces YOM emissions by 90-95 percent, depending on the date that the afterburner was first constructed at the subject source, or to a maximum afterburner exhaust outlet concentration of20 mmpv (as carbon). SR at 32; see Prop. 218 at 115, Prop. 219 at 115.

In addition, the Board proposes to require that "[s]uch printing lines shall also equip the afterburner with 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." SR at 32; see Prop. 218 at 115, Prop. 219 at 115.

The Board also proposes a new subsection (a)(2) providing that "no owner or operator of subject letterpress printing lines shall use cleaning solutions on such lines unless the YOM
content ofthe as-used cleaning solution is less than or equal to 70 percent, by weight, or the YOM composite vapor pressure ofthe as-used cleaning solution is less than 10 mmHg at 20 degrees Celsius." SR at 32; see Prop. 218 at 115-16, Prop. 219 at 115-16.

In proposed subsection (a)(3), the Board seeks to require that "[c]leaning materials must be kept, stored, and disposed of in closed containers, except when specifically in use." SR at 32;

see Prop. 218 at 116, Prop. 219 at 116.

Subsection (b). The Board proposes a new subsection (b) providing "that heatset web letterpress printing lines may use a control device other than an afterburner ifthe control device
meets the YOM emissions reduction requirements in subsection (a) and is approved by the Illinois EPA and USEPA as federally enforceable permit conditions." SR at 33; see Prop. 218 at 116, Prop. 219 at 116.53



### Section 218.415/219.415: 

### Testing (or Letterpress Printing Lines. The Board proposes to add a new section addressing testing requirements applicable to letterpress printing lines subject to Section 218/219.413. SR at 33-34; 

### see Prop. 218 at I] 6-] 9, Prop. 219 at 116-19.



### Subsection (a). In proposed subsection (a), the Board seeks to require "that testing to demonstrate compliance with [Section] 218/219.4] 3 shall be conducted at the expense ofthe

owner or operator within 90 days ofa request by the Illinois EPA, and the owner or operator shall notify the 1I1inois EPA 30 days in advance of conducting such testing." SR at 33; 

### see Prop. 218 at 116, Prop. 219 at 116. In its first motion to amend, the Agency responds to a request by industry representatives by seeking to amend this subsection to clarify when testing must be performed. Mot. Amend I at 21**(~18).** The Board granted the motion, and the subsection reflects the amendment.



### Subsection (b). In subsection (b), the Board proposes to describe "the methods and procedures in Section 218/219.1 05(d) and (t) that shall be used for testing to demonstrate compliance with the add-on control device requirements of Section 218/219.413(a)(I)(B) and (b)(I)." SR at 33; 

### see Prop. 218 at 117-18, Prop. 219 at 117-18.



### Subsection (c). The Board proposes a new subsection (c) providing "that testing to demonstrate compliance with the YOM content limitations in Section 218/219.413(a)(2)(A) and
to determine the YOM content ofcleaning solvents, cleaning solutions, and inks shall be conducted using the applicable test methods and procedures in Section 218/219.105(a)." SR at 33; 

### see Prop. 218 at 118, Prop. 219 at 1 

### J8. The Board also seeks to provide in subsection (c)(2) that "[t]he manufacturer's specifications for YOM content for cleaning solvents and inks may be used if such specifications are based on results oftests conducted in accordance with Section 218/2] 9.105(a)." SR at 33; 

### see Prop. 218 at 118, Prop. 219 at 118.

In its first motion to amend, the Agency responds to a request by industry representatives by seeking to amend this subsection to clarify when testing must be performed. Mot. Amend I at 21**(~18).** The Board granted the motion, and the subsection reflects the amendment.



### Subsection (d). The Board proposes a new subsection (d) providing "that testing to demonstrate compliance with Section 218/219.413(b) shall be conducted as set forth in the

owner or operator's plan approved by the lIlinois EPA and USEPA as federally enforceable penn it conditions." SR at 34; 

### see Prop. 218 at 118, Prop. 219 at 118.



### Subsection (e). The Board proposes a new subsection (e) providing "that testing to detennine the YOM composite partial vapor pressure 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." SR at 34; 

### see Prop. 218
at 118-19, Prop. 219 at 118-19.



### Section 218.416/219.416: 

### Monitoring Requirements (or Letterpress Printing Lines. The Board proposes to add a new section addressing monitoring ofemissions from letterpress printing lines. 

### See SR at 34, Prop. 218 at 119-20, Prop. 219 at 119-20.54

Subsectioll (a). The Board proposes a new subsection (a) providing "that, ifan afterburner is used to demonstrate compl iance, the owner or operator of a heatset web letterpress printing line shall install, calibrate, maintain, and operate temperature monitoring devices with

an accuracy 0[3° 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." SR at 34; see Prop. 218 at 119, Prop. 219
at 119. The Board also seeks to require in proposed new subsection (a)(1) that monitoring must be "performed at all times when the afterburner is operating

.... " Prop. 218 at 119, Prop. 219 at 1] 9; see SR at 34. In subsection (a)(2), the Board proposes to require that "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." SR at 34; see Prop. 218 at 119, Prop. 219 at 119.

Subsectioll (b). The Board proposes a new subsection (b) providing "that if a control device other than an afterburner is used to demonstrate compliance, the owner or operator of a hcatsct 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)" SR at 34; see Prop. 218 at 119, Prop. 219 at 119.

Subsectioll (c). The Board proposes a new subsection (c) setting "forth the monitoring requirements for owners or operators ofJetterpress printing lines relying on the YOM content of the cleaning solution to comply with Section 2181219.413(a)(2)(A), or relying on the vapor pressure ofthe cleaning solution to comply with Section 21 8/21 9(a)(2)(B)." SR at 35; see Prop. 218 at 119-20, Prop. 219 at 119-20.

Sectioll 218.417/219.417: Recordkeepillg alld Reportillg (or Letterpress Prilltillg Lilles. The Board proposes to add a new section addressing record keeping and reporting for letterpress printing lines. SR at 35; see Prop. 218 at 120-29, Prop. 219 at 120-30.

Subsectioll (a). The Board proposes a new subsection (a) providing

that the owner or operator of a heatset web letterpress printing line exempt from any ofthe limitations of Section 218/219.413 because ofthe criteria in Section 218/219.412(a)(1) shall submit a certification to the Illinois EPA that includes a declaration that the source is exempt and calculations that demonstrate that the source's total potential to emit YOM does not equal or exceed 25 tons per year. SR at 35; see Prop. 218 at Il9, Prop. 219 at 120.

Subsectioll (b). The Board proposes a new subsection (b) providing

that the owner or operator of a letterpress printing line exempt from any ofthe limitations of Section 218/219.413 because ofthe criteria in 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 of YOM from all letterpress printing lines at the source never equal or exceed 6.8 kg/day (15 Ibs/day), and a description and the results of all tests used55

to determine the YOM content of inks and cleaning solvents. SR at 35; see Prop. 218 at 120-23, Prop. 219 at 120-23.

In its proposed subsection (b)(1 )(D), the Board seeks to provide that, "as an alternative to the YOM emission calculations set forth in subsection (b)( I)(B), a source may determine that it emits below 6.8 kg/day (15 Ibs/day) ofVOM ifit complies with material use limitations during each calendar month." SR at 35-36; see Prop. 218 at 122, Prop. 219 at 122. The Board proposes language limiting the availability ofthis alternative to sources with only a single type of letterpress printing operations. SR at 35-36; see Prop. 218 at 122, Prop. 219 at 122. The Board also proposes to require that, "[i]fa source exceeds the material use limitation in any given month, the source shall complete emissions calculations pursuant to subsection (b)(1 )(B) within 15 days ofthe end ofthat month." SR at 36; see Prop. 218 at 122, Prop. 219 at 122. The Board also proposes that any source exceeding the limitation for six consecutive months is no longer eligible to rely upon the material use alternative. SR at 36; see Prop. 218 at 122, Prop. 219 at 122.

In its first motion to amend, the Agency proposed to change the material use thresholds for letterpress printing lines. Mot. Amend 1 at 22**(~19).** The Agency states that "USEPA previously recommended that material use thresholds for lithographic printing lines be conservatively based on 50 percent ofthe pound per day applicability threshold. USEPA has

now determined that a 90 percent emissions equivalency level is acceptable for both lithographic and letterpress printing operations." Jd. Accordingly, the Agency seeks to amend proposed subsections (b)(1)(D)(i) and (b)(1)(D)(ii) to reflect this 90 percent equivalency. Jd. The Board granted the motion, and the subsection reflects the amendment.

In proposed subsection (b)(2), the Board seeks to require that subject sources shall notify the Agency ifthe combined emissions ofVOM from all letterpress printing lines at the source
ever equal or exceed 6.8 kg/day (15 Ibs/day)." SR at 35; see Prop. 218 at 123, Prop_ 219 at 123. In its first motion to amend, the Agency proposed to amend subsection (b)(2) "by removing the requirement that a source include in its notification to the lllinois EPA calculations showing an exceedance ofthe applicability threshold." Mot. Amend 1 at 22-23**(~20).** The Board granted the motion, and the subsection reflects the amendment.

Subsection (c). The Board proposes a new subsection (c) providing "that, unless utilizing the material use alternative, the owner or operator ofa letterpress printing line subject to the requirements in subsection (a) or (b) ofthis Section shall collect and record either the specified standard recordkeeping information or the specified purchase and inventory recordkeeping information." SR at 36; see Prop. 218 at 123-24, Prop. 219 at 123-25.

Subsection (d). The Board proposes a new subsection (d)(1) providing

that the owner or operator ofa heatset web letterpress printing line subject to Section 218/219.413(a)( I)(B) or (b)(1) ofthis Subpart shall submit a certification
to the Illinois EPA that includes identification of each heatset web letterpress printing line at the source, a declaration that each such line is in compliance with Section 218/219.413(a)(1) or (b), the type ofafterburner or other approved control56

device being used and the date that such device was first constructed at the subject
source, the control requirements with which the printing I ine is complying, the results ofall tests and calculations necessary to demonstrate compliance, and a declaration that thc rcquired monitoring equipment has been properly installed and calibrated. SR at 36; see Prop. 218 at 125-27, Prop. 219 at 125-27.

Proposed subsection (d)(2) seeks to require that,

if the testing of an afterburner or other approved control device is conducted pursuant to Section218/219.415(b), the owner or operator shall submit a copy of all test results to Illinois EPA, as well as a certification that includes a declaration that all necessary tests and calculations have been performed, a statement whether the printing line is in compliance with Section 21 8/21 9.41 3(a)(I)(B) or (b)(I), and the operating parameters ofthe afterburner or other approved control device during testing. SR at 37; see Prop. 218 at 125-26, Prop. 219 at 126.

The subsection also proposes that an owner or operator changing its method ofcompliance "must certify compliance for the new method ofcompliance and perform all tests and calculations necessary to demonstrate compliance with such method." SR at 37; see Prop. 218 at 126-27, Prop. 219 at 127.

Subsection (d)(3) also proposcs to require that an owner or operator "collect and record specified information for each heatset web letterpress printing line and notify the Illinois EPA of any violation of Section 2181219.413(a)(I)(B) or (b)(I)." SR at 36; see Prop. 218 at 125-27, Prop. 219 at 125-27.

Subsectioll (e). The Board proposes a new subsection (e) establishing various recordkeeping and reporting requirements. See SR at 37, Prop. 218 at 127-29, Prop. 219 at 127- 30. The proposed provision "provides that the owner or operator ofa letterpress printing line shall certify to the Illinois EPA that all cleaning solutions, other than those excluded pursuant to Section 218.412(b), and the handling ofall cleaning materials will be in compliance with Section 218/219.4 I3(a)(2)(A) or (a)(2)(B) and (a)(3)." SR at 37; see Prop. 218 at 127, Prop. 219 at 127. The proposed certification must also include specific information regarding cleaning operations
at the subject printing line. SR at 37; see Prop. 218 at 127, Prop. 219 at 127. In addition, "[t]he

owner or operator shall collect and record specified information for each solution used on each letterpress printing line and notify the Illinois EPA ofany violation of Section 218/219.413." SR at 37; see Prop. 218 at 127-29, Prop. 219 at 127-30.

In its first motion to amend, the Agency responded to comment by industry representatives by proposing to amend subsections 218/219(e)(2)(B) and (e)(2)(C) "by specifying that, for cleaning solutions used as-purchased, sources may use manufacturer's specifications to determine YOM content and YOM composite partial vapor pressure." Mot. Amend I at 23-25**(~21).** The Board granted the motion, and the subsection reflects the amendment.57

Subsection (J). The Board proposes a new subsection (f) providing "that the owner or operator of a printing line shall maintain all records required by this Section for a minimum period ofthree years and shall make all records available to the Agency upon request." SR at 38;

see Prop. 218 at 129, Prop. 219 at 130.

CONCLUSION

The Board proposes for second notice rcview amendments to its regulations governing VOM emissions in Parts 211, 218, and 219 (35 III. Adm. Code 211, 218, 219). Substantivcly, the Board is adopting the Agency's amended proposal and incorporating comments received during first notice, as described above in this opinion.



### ORnER

The Board directs the Clerk to file the following proposed amendments with 

### lCAR for second-notice review. Proposed additions are underlined, and proposed deletions appear stricken.

TITLE 35: ENVIRONMENTAL PROTECTION SUBTITLE B: AIR POLLUTION CHAPTER I: POLLUTION CONTROL BOARD SUBCHAPTER c: EMISSION STANDARDS AND LIMITATIONS FOR STATIONARY SOURCES

PART 211 DEFINlTlONS AND GENERAL PROVISIONS

SUBPART A: GENERAL PROVISIONS Section 211.101 211.102

Section 211.121 211.I22 211.BO 211.150 211.170 211.210 211.230 211.240 211.250 Incorporations by Refcrence Abbreviations and Convcrsion Factors

SUBPART B: DEFINlTlONS

Other Definitions Definitions (Repealed) Accelacota Accumulator Acid Gases Actual Heat Input Adhesive Adhesion Promoter Aeration

# A 20

### JOINT COMMITTEE ONADMINISTRATIVE RULES ILLINOIS GENERAL ASSEMBLY

CO-CHAIR: SEN. MAGGIE CROTTY

CO-CHAIR: REP. ANGELO "SKIP' SAVIANO

EXECUTIVE DIRECTOR: VICKI THOMAS

700 STRAITON BUILDING SPRINGFIELD, ILUNOIS 62706 217/785-2254

MEMORANDUM SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN. MAHlE HUNTER SEN. DAN RUTHERFORD SEN. IRA SILVERSTEIN REP. JOHN FRITCHEY REP. LOU LANG REP. DAVID MILLER REP. DONALD MOFFITI REP. ROSEMARY MUlliGAN

TO:

FROM:

DATE:

RE: Tanner Girard, Chainnan Pollution Control Board

Vicki Thomas Executive Director

5/18/1 0

Definitions and General Provisions (35 

### Ill. Adm. Code 211) 34 Ill. Reg. 1766

- 2/5/1 0

The Office of the Joint Committee on Administrative Rules has accepted the Second Notice for the above-referenced rulemaking. The Second Notice period began on'31DWO' and ends no later than 7/1/10, unless extended pursuant to Section 5-40 ofthe IAPA.

This rulernaking is scheduled to be considered by JCAR at its 6/15/10 meeting, currently scheduled for 11:00 a.m., Room 16-503, James R. Thompson Center, Chicago, 

### IL. Staffwill be contacting you if they have questions concerning this rulemaking and will advise you of any change in time or location ofthe Committee meeting.

Please contact us if youhave any questions regarding the JCAR review procedure.

VT:DC:nn

cc: Tim Fox Adm. Code Div.

### JOINT COMMITTEE ONADMINISTRATIVE RULES ILUNOIS GENERAL ASSEMBLY

CO-CHAIR: SEN. MAGGIE CROTTY

CO-CHAIR: REP. ANGELO ·SKIP" SAVIANO

EXECUTIVE DIRECTOR: VICKI THOMAS SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN. MATIIE HUNTER SEN. DAN RUTHERFORD SEN. IRA SILVERSTEIN REP: JOHN FRITCHEY REP. LOU LANG REP, DAVID MILLER REP. DONALD MOFFITT REP. AOSEMARY MUlUGAN

TO:

FROM:

DATE: 700 STAATION BUILDING SPRINGFIELD, ILLINOIS 62706 217n85-2254

MEMORANDUM

Tanner Girard, Chainnan Pollution Control Board

Vicki Thomas Executive Director

5/18/10 

### RECEIVED CLERK'S OFFICE



## MAY 20 2010
STATE OF ILLINOIS Pollution Control 

## Board

RE: Organic Material Emission Standards and Limitations for the Chicago Area (35 Ill. Adm. Code 218) 34 Ill. Reg. 1791

- 2/5/10

The Office of the Joint Committee on Administrative Rules has accepted the Second Notice for the above-referenced rulemaking. The Second Notice period began on 5/18/1 0 and ends no later than 7/1110, unless extended pursuant to Section 5-40 ofthe IAPA.

This rulemaking is scheduled to be considered by JCAR at its 6/15/1 0 meeting, currently scheduled for 11:00 a.m., Room 16-503, James R. Thompson Center, Chicago, IL. Staff will be contacting you if they have questions concerning this rulemaking and will advise you of any change in time or location ofthe Committee meeting.

Please contact us if you have any questions regarding the JCAR review procedure.

VT:DC:nn

cc: Tim Fox Adm. Code Div.

### JOINT COMMITTEE ON ADMINISTRATIVE RULES ILUNOIS GENERAL ASSEMBLY

CO·CHAIR: REP, ANGELO ·SKIP" SAVIANO CO-CHAIR: SEN. MAGGIE CROlTY

EXEcunVE DIRECTOR: VICKlmOMAS

TO:

FROM:

DATE: 700 STRAITON BUILDING SPRINGFIELD,ILUNOIS6270G 217"85-2254

MEMORANDUM

Tanner Girard, Chairman Pollution Control Board

Vicki Thomas Executive Director

5/18110 SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN, MAITrE HUNTER SEN. DAN RUTHERFORD SEN. IRA SILVERSTEIN AEP, JOHN FRJTCHEY REP, lOU LANG REP. DAVID MILLER REP. DONALD MOFFrrr REP. ROSEMARY MULLIGAN


### RECEBVED

CLERl.<'S OFFICE



## MAY·20201O
STATE OF 

### lLUNOIS Pollution control 

### Bo8Id

RE: Organic Material Emission Standards and Limitations for the Metro East Area (35 

# m. Adm. Code 219) 34111. Reg. 1941- 215110

The Office of the Joint Committee on Administrative Rules has accepted the Second Notice for the above-referenced rulemaking. The Second Notice period began on 5/18/10 and ends no later than 7/1/10, unless extended pursuant to Section 5-40 ofthe 1APA.

This rulemaking is scheduled to be considered by JCAR at its 6/15/10 meeting, currently scheduled for 11:00 a.m., Room 16-503, James R. Thompson Center, Chicago, 11. Staff will be contacting you if they have questions concerning this rulemaking and will advise you of any change in time or location ofthe Committee meeting.

Please contact us if you have any questions regarding the JCAR review procedure.

VT:DC:rm

cc: Tim Fox Adm. Code Div.

# A 21

### Flexible Packaging Association

June 4, 2010

Tim Fox, Attorney Assistant to Member Moore Joint Committee on Administrative Rules Illinois Pollution Control Board 700 Stratton Building Springfield, IL 62706 foxt@ipcb.state.il.us

Ms. Vicki Thomas, Executive Director Joint Committee on Administrative Rules Illinois General Assembly 700 Stratton Building Springfield, Illinois 62706 jcar@ilga.gov 

## REcelVED CLERK'S OFFIce



## JUN 

## 0 '2010
STATE OF 

### tWNO Pollution ContrOl

Re: In the Matter of: Reasonably Available Control Technology (RACT) for Volatile Organic Matter Emissions from Group II Consumer 

### & Commercial Products: Proposed Amendments to ILL. Adm. Code 211, 218 and 219. R10-8 (Rulemaking

- Air)

Dear Mr. Fox and Ms. Thomas,

Introduction

- The Flexible Packaging Association (FPA) appreciates the opportunity to file comments on !PCB's Proposed Rulemaking concerning proposed amendments to VOM-RACT requirements for Group II Conswner & Commercial Products manufacturers. FPA's comments pertain specifically to proposed testing requirements applicable to owners or operators of flexographic or rotogravure printing lines that print flexible packaging and use a capture system and control device to meet emission limitations. FPA offers some alternative language to be considered in these comments.

FPA was established in 1950 and is a national trade association comprised of manufacturers and suppliers of flexible packaging. The industry's members are converters that produce packaging for food, healthcare, and industrial products using paper, film, foil, or any combination ofthese materials and include manufacturers in Illinois that would be subject to this rule iffinalized. Examples of flexible packaging include rollstock, bags, pouches, labels, liners, wraps, and tamper-evident packaging for food and medicine. Flexible packaging, a $25.6 billion iridustry, employs approximately 

# !!i

-

.. 

# .

--

# ..**~"** 

# .. source**~:reduction**

...**~. ItsIcwaslelntlxlrn:sr~'** 



# _

......... 97J Corporate Boulevard. Suite 403 • Limhicum. Maryland 21090 phone: 410.694.0800. fax: 410.694.0900.**e~mail:fpa@jlexpackorg.** web: wwwflexpackorg80,000 people in the United States and is now the second largest segment ofthe U.S. packaging market estimated at $135 billion.

In FPA's review ofthe agency's file on the proposed rulemaking, we recognized that the proposal closely followed US EPA guidance per document EPA 453/R-06-006 "Control Techniques Guideline for Flexible Package Printing" dated September 2006. FPA supported US EPA's use ofthe CTG for guidance on RACT requirements and largely supported the 2006 CTG as drafted. The Association and its member companies were actively involved in the CTG development and acted as a technical resource to EPA officials throughout the development ofthe eTG guidance particularly with regard to operational complexities of flexible packaging processes, pollution control equipment,
cost infonnation and insights regarding the operations ofthe industry, its capabilities and limitations.

THE IPCB PROPOSAL

- Notwithstanding the proposed rules reliance on the CTG, the proposed condition that concerns FPA relates to a condition that does not come from the CTG. Specifically FPA is concerned with the requirement under Part 218.401(c)(6) relating to capture system and control device requirements. Condition (c)(6) ofthis subsection states:

The owner or operator of a printing line subject to the requirements in Section 218.40I(c)(3) shall perform testing in compliance with this subsection (c)(6),

even if the owner or operator already performed such testing prior to August 

### 1,2010, unless the following conditions are met. Nothing in this subsection (c)(6), however, shall limit the Agency's ability to require that the owner or operator perfonn testing pursuant to Section 201.282:

A) On or after May I, 2000, the owner or operator ofthe subject printing line perfonned all testing necessary to demonstrate compliance with Section 218.401(c)(J)(B): B) Such testing also demonstrated an overall control efficiency equal to or greater than the applicable control efficiency requirements in Section 218.401(c)(3): C) The owner or operator submitted the results of such tests to the Agency, and the tests were not rejected by the Agency; D) The same capture and control device subject to the tests referenced in subsection (c)(6)(A) ofthis Section is still being used by the subject printing line; and E) The owner or operator complies with all recordkeeping and reporting requirements in Section 218.404(e)(J)(B);

While it is not totally clear ifthe intent ofthe condition was to include both capture and control device efficiency testing, it can certainly be inferred that both are included. FPA does support periodic retesting for control device efficiency (e.g. oxidizer destruction efficiency testing); however, FPA objects to retesting ofcapture system efficiency without cause. Although the CTG was silent as to testing requirements, US EPA



### 2guidance on its position regarding the need for recurrent testing was fully defined in the "Technical Support Document (TSD) for Title V Permitting of Printing Facilities" issued January 2005 and revised June 2007. http://www.epa.govlttnchiellmkb/documentsITSD.pdf.

With respect to Control Device Efficiency Testing, Section 5.5.1 ofthe TSD states:

5.5.1.2. As long as a printer does not change operations in a way that could affect control device efficiency. It is likely that the ongoing parameter monitoring, together with good operating, maintenance, and QAlQC procedures will generate data in the operating range(s) that assure compliance with applicable requirements. Therefore,

we believe that periodic retesting for control device efficiency

- typically once per title V permit term may be sufficient, but this would depend on the applicable requirement at issue.

With respect to Ongoing Capture Efficiency Testing, Section 5.5.3 ofthe TSD states:

5.5.3.1.

5.5.3.2. Permanent Total Enclosure

Provided that the conditions ofM204 are shown by ongoing monitoring to coritinue to be met, the capture efficiency ofa permanent total enclosure is assumed to be 100 percent (see M204
at 40 CFR 51, appendix M).

Other than Permanent Total Enclosure

For capture systems that are not permanent total enclosures, as long as the operating parameters continue to be maintained in appropriate ranges, and as long as physical changes to the air distribution system do not occur, we would expect any new capture efficiency testing would show similar results to the initial testing. Accordingly, we suggest that you consider reserving retesting for capture efficiency for those instances where operating parameters indicate that a fundamental change has taken place in the operation

or design ofthe equipment, unless more frequent retesting is required under an applicable requirement. A fundamental change may include any ofthe following;

o Adding print stations to a press;

• Increasing or decreasing the volumetric flow rate from the dryer (e.g. by changing the size ofpress fans/motors

or removal or de-rating of dryers); or

o Changing the static duct pressure.



### 3The proposed rule does offer an exception to the testing requirement under subsection (c)(6)(A), if a source had performed an applicable test on or after May 1,2000. FPA is uncertain of the rationale for this date, which appears to be arbitrarily selected at 10 years prior to the originally proposed effective date ofthe rule. If1PCB were to establish a sunset date for applicability of prior test, FPA would suggest the date of issuance ofthe US EPA policy memorandum from 

### J. Seitz (EPA, I 995e) and the "Guidelines for Determining Capture Efficiency" (EMC GD-035) (EPA, 19951), which include recommended procedures for capture testing. The documents represent EPA's last significant change to capture testing recommendations.

In addition, it would appear that the rule, if adopted, would require any mandated testing/retesting and certification be completed by August I, 2010. Where additional testing is needed, we do not think it would be feasible to accomplish the testing by August 1,2010 and receive the testing report back from a stack-testing consultant in order to make the necessary certification. To address this issue, we have proposed in the attached "FPA Proposed Changes" a 120 day period in which such testing and certification could be reasonably completed.

COSTS OF TESTING

- Aside from the technical relevancy considerations ofretesting, capture efficiency testing is very costly and highly disruptive to facility operations. Thus it should be reserved only for those instances where baseline data is required or where the base capture design has been changed. These costs were not identified or examined in IPCB's Technical Support Document identifying projected costs for the proposed rule.

Data is readily available on the substantial costs ofconducting these tests. EPA's Method 204 Temporary Total Enclosure (TTE) capture test protocol costs would range $100,000 to $250,000 to perform at a moderate sized site with multiple presses. One member company, performing TTE testing on three flexographic presses at a single site, experienced $135,000 in direct and indirect cost for the week long testing exercise. Another company performing TTE testing on two laminating/coating machines experienced (in 1998 dollars) direct costs 

### of$68,500jor each machine. In this respect, IPCB should note that even an average size facility would have four (4)-to- seven (7) process lines subject to this rule, including presses, coaters and laminators. Therefore, the cumulative costs oftesting under the proposed rule will be SUBSTANTIAL.

In addition to the expense associated with repeat capture testing, the disruption to manufacturing during week-long testing also is significant. Not only must the presses involved be taken out ofproduction, but significant additional disruption is caused by designing and constructing a temporary enclosure around a press to enable it to be tested. Additional disruption ofmanufacturing at that machine and nearby equipment is caused by removing the enclosure. The cumulative costs ofthe actual testing and the disruption ofmanufacturing makes capture testing one of the most disruptive requirements ever placed on the converting industry.

4While one might need to incur such cost and disruption to the manufacturing process to establish a capture efficiency baseline, it is notjustified only for the sake ofre-testing to verify a static process.

In summary, excluding presses with PTEs, the capture system is intrinsic to the drying mechanism for the press and therefore capture efficiency is inherently a design function ofprinting and coating equipment. Capture efficiency, as a practical matter, does not change unless the base design of the capture system is changed. Aqy adverse impacts on the dryingmechanism would be visible in the print quality (e.g. blowout in the between color stations would result in drying ofplates and poor print).

Given the need to properly maintain production equipment, the fact that capture efficiency is inherent to design, and the fact that design does not change over time unless affirmatively modified by the converter, FPA recommends that IPCB amend the testing provisions in the proposed rule and delete the requirement for retesting capture efficiency. FPA recommends that IPCB redraft the provision to follow the recommendations ofUS EPA as outlined in the "Technical Support Document for Title V Permitting ofPrinting Facilities (EPA. 2007 June)(. Retesting should be reserved for those instances where a fundamental change has taken place in the equipment's capture design or where parametric monitoring indicates that the capture characteristics ofthe equipment has fundamentally changed.

Attached is FPA's suggested changes to IPCB's Proposed Amendment to Section 21 8.401 (c)(6). Our proposed changes are underlined. FPA appreciates this opportunity
to comment and would be happy to provide additional information and resources to assist IPCB on this and related issues. Please do not hesitate to contact me at 410/694-0823 or RSinghal@flexpack.org ifour members or FPA can be of assistance.

Sincerely,

# fU-s~ Ram K Singhal Vice President Technology 

### & Environmental Strategy Flexible Packaging Association

Cc: John T. Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100 West Randolph Street, Suite 11-500 Chicago, IL 60601

5ATTACHMENT: FPA'S PROPOSED AMENDMENTS TO Section 218.401 (c)(6): (All changes proposed by FPA are underlined below.)

Section 218.401 Flexographic and Rotogravure Printing
c) Capture system and control device requirements
6) The car;lture system and control device are operated at all times when the subject printing line is in operation. The owner or operator shall demonstrate compliance with this subsection by using the applicable capture system and control device test methods and procedures specified in Section 218.105(c) through Section 218.105(f) of this Part and by complying with the record keeping and reporting requirements specified in Section 218.404(e) of this Part. The owner or operator of a printing line subject to**th~** requirements in Section 218.401 (c)(2) or 218.401(c)(1)(B) of this Section that performed all testing necessary to demonstrate compliance with Section 218.401 (c)(1)(B) prior to August 1, 2010, is not required to retest pursuant to this subsection (c)(6). Within 120 days of the effective date of this rule, the owner or operator of a printing line subject to the requirements in Section 218.401 (c)(3) shall perform testing in compliance with this subsection (c)(6), even 

### if the owner or operator already performed such testing prior to August 1,2010, except as provided below;
A) Retesting of destruction efficiency shall not be required provided: i) On or after May 1, 2000, the owner or operator of the subject printing line performed destruction efficiency testing of the affected control device using the applicable test methods and procedures specified in Section 218.105(d) through Section 218.1 05(f) of this Part; ii) The owner or operator submitted the results of such tests to the Agency, and the tests were not rejected by the Agency; and iii) The owner or operator complies with all record keeping and reporting requirements in Section 218.404(e)(1)(B);
B) Retesting of capture efficiency for a printing line using a permanent total enclosure to capture emissions shall not be required provided: i) The owner or operator has made a demonstration that the capture system meets the definition of a permanent total enclosure as demonstrated through use of US EPA Method 204; ii) Monitoring of the enclosure demonstrates that operating parameters continue to be maintained in appropriate ranges; andiii) The owner or operator complies with all record keeping and reporting requirements in Section 218.404(e)(1)(B).
C) Retesting of capture efficiency for a printing line using a capture system other than a permanent total enclosure to capture emissions shall not be required provided: i) The owner or operator of the subject printing line performed capture efficiency testing of the affected printing line using the applicable test methods and procedures specified in Section 218.105(c) of this Part; ii) The owner or operator submitted the results of such tests to the Agency, and the tests were not rejected by the Agency; iii) Operating parameters continue to be maintained in appropriate ranges; iv) No physical changes were made to the printing line that could affect the efficiency of the capture system (e.g. addition of print stations, increasing or decreasing the volumetric flow rate from the dryers or changing the static pressure in the exhaust duct); and v) The owner or operator complies with all record keeping and reporting requirements in Section 218.404(e)(1)(B);
Nothing in this subsection (cH6), however. shall limit the Agency's ability to require that the owner or operator perform testing pursuant to Section 201.282:

# A 22

## 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

PAT QUINN, GOVERNOR



### June 10,2010

Vicki Thomas, Executive Director .Toint Committee on Administrative Rules Illinois General Assembly 700 Stratton Building Springfield, IL 62706 DOUGLAS P. SCOTT, D,RECTOR



### Subject:

Ms, Thomas: Comments regarding R20l0-008. In the Matter ofReasonably Available Control Teclmology (RACT) for Volatile Organic Material Emissions from Group II Consumer & 

### Commercial Products: Proposed Amendments to 35 

### Ill. Adm, Code 211, 218, and 219

The Illinois Environmental Protection Agency' ("Illinois EPA" or "Agency") submits these comments regarding rulemaking proposal R20l 0-008 in response to comments submitted to the Joint Committee on Administrative Rules (".TCAR") and the Illinois Pollution Control Board ("Board") on June 4, 2010, by the Flexible Packaging Association ("FPA"). 

### In its comments, the FPA recommends changing the compliance date for testing required in Section 2l8/2l9.401(c)(6) of the rulemaking proposal from August 1, 2010, to a date "[ wJithin 120 days of the effective date of this rule." The FPA also recommends extensive and significant changes to the testing requirements set forth in such Section.

While the Agency acknowledges that, due to the length ofthe rulemaking process,
sources may need additional time to comply with the rule's testing requirements, and therefore has no objection to changing the required testing compliance date as recommended by the FPA, the Agency strongly opposes all other changes requested by the FPA.

The lIlinois EPA's Rulemaking Proposal

The IJlinois EPA began development of this rulemaking in early 2008 in response to Control Techniques Guidelines ("CTGs") issued by the United States Envirolll1Jental Protection Agency ("US EPA") concerning reasonably available control technology for volatile organic materials. Prior to filing the proposal with the Board, the Agency engaged in extensive outreach efforts with stakeholders. On November 5, 2008, the IJlinois EPA posted a draft ofthe proposed rule and copies ofthe pertinent CTGs on.its website for public comment. The IJlinois EPA subsequently engaged in numerous conference calls and exchanged correspondence with representatives of affected sources

Rockford. 430:! N. Maln 51., Rockford, IL (,110J. (815) 987-7760 Elgin. 595 S. Slale, Elgin. II 60123 • /847) 608-3131 Bureau of land -,Pe-oria. 7620 N. University St.. Peoria, IL 61614_ (309) 693·5462 Collinsville. -2009 Mall Street. Collinsville, Il 62234. (618) 346-5120 Des**Plajm:~.'9511** W. Hiuri.on St., Des**Plairle~,** IL 60016. (847) 294-4000 Ptooria. 5415 N. UniverSity St, Peoria, IL 61614. (309)693·5463 Ch<lmpaign. 2125 S. First 51., Champaign, IL 61820. (217) 27R·5800 Marion. 2309 W. M<lin St., Suite 116, Marion, IL 62959. (618) 993-7200

PrmlccI nn**R~q'<.:1e;d** P;lpe'l

### regarding the proposal, including both Ram Singhal of the FPA and Brian Galley, an employee of an affected source whose recent correspondence with Mr. Singhal appears to have resulted in FPA's Clm-ent comments.

The draft proposal that the Illinois EPA sent to stakeholders for outreach, comments, and discussion prior to submitting the proposal to the Board required that all subject flexible package printing sources complying with the mle via capture and control devices retest the efficiency of such devices. Retesting is necessary, as the proposal includes new and potentially stricter efficiency requirements, as set forth in the CTG. During the Agency's outreach efforts, however, the Agency received comments from flexible package printing representatives, who requested that retesting not be required if testing had already been completed that demonstrated compliance with the new efficiency requirements. 

### In response to such comments, the Illinois EPA amended its proposal to provide that, as long as a source performed pertinent testing within the previous ten years, such testing demonstrated compliance with the new efficiency requirements, and the same capture and control system subject to the prior tests is still being used by the printing line (among other requirements), the source was not required
to retest.

The Agency sent Ram Singhal of the 

### FPA a copy of such revisions on April 30, 2009, requested' that he circulate the changes to the FPA's member sources, and provided

an opportunity for such sources, or the FPA acting on behalf of such sources, to provide additional comments. Such language was also part ofthe proposal the Agency filed with the Board on July 9,2009.

The Agency never received any feedback from the flexible packaging industry regarding this testing revision. No one from the industry participated in the public hearings that subsequently took place on October 27, 2009, and December 8, 2009, nor did anyone from the industry submit comments to the Board during the first notice period. Additionally, the Agency was not served with a copy ofthe comments the FPA recently filed with the Board and JCAR; rather, the Agency located such comments on the Board's website. This was the first notice the Agency received regarding issues with the proposed language

- during second notice, over a year after the Agency sent a draft to the FPA and almost a year after the Agency filed the proposed mlemaking.

The FPA's Proposed ChanQes

The FPA's proposed changes are unwarranted and incomplete. From a technical perspective, the FPA has made a few claims regarding testing, but has avoided the Board's rulemaking process, which would have required them to provide the necessary information in support of these claims.



### Ten Year Deadlinefor Prior Tests

Despite the claim made in Mr. Singhal's comments to .TCAR, the ten-year period for prior testing was not "arbitrarily selected," but was actually chosen due to the very

### USEPA "Technical Support Document (TSD) for Title V Pennitting ofPrinting Facilities" quoted by Mr. Singhal. Notably, the TSD states, and Mr. Singhal quoted in his comments, "we believe that periodic retesting for control device efficiency

- typically

once per title V pern1it tenn may be sufficient

... " A Title V pern1it tenn is five years. However, in light of the negotiations and discussions that took place with industry prior
to the filing of this proposed rulemaking, the Agency set the requirement at ten yearstwice the length of time suggested by USEPA.

It should also be noted that ten years is as much as five times the length of time in other USEPA requirements, such as those found in National Emission Standards for Hazardous Air Pollutants (NESHAPs) for various source categories. For example, a very quick search found such requirements for gasoline distribution bulk tenninals, bulk plants, and pipeline facilities (testing required if such was not done within the past five years

- see 40 CFR §63.11092); reciprocating internal combustion engines (testing required if such was not done within the past two years

- see 40 CFR §63.6610); and stationary combustion turbines (testing required if such was not done within the past two years

- see 40 CFR §63.5991).

Capture Devices

The FPA made several statements claiming that capture efficiency likely would
not change and thus a previously-tested facility should not need to re-test, even after ten years or more. 

### In doing so, Mr. Singhal quoted the US EPA TSD discussed above, which states, "As long as a printer does not change operations in a way that could affect control device efficiency. It 

### is likely that the ongoing parameter monitoring, together with good operating, maintenance, and QAIQCprocedures will generate data in the operating range(s) that assurc compliancc with applicable requirements." (Emphasis added.)

This may be true, but the emphasized portions of these statements cannot be taken for granted. The Agency's capture and control testing expert, Kevin Mattison, has extensive experience in attending and reviewing such testing. In his experience, he has noted that many enclosures are not operated in the same manner ten years after their original testing was done. Over time, there is a turnover ofplant personnel and often the
current personnel are not operating the capture system in the same manner in which it

was tested ten years (or more) prior.

One recent example ofthis was seen in a USEPA inspection of a coating line that has a penn anent total enclosure ("PTE"). There was a large door in the PTE that needed
to be closed in order to enclose the area; however, the current operators were unaware of this need and operated routinely with the door open. In other cases, Mr. Mattison himself has encountered capture systems that needed patching due to poor maintenance, an issue that would never have been discovered or repaired without testing.

The intent oftesting is two-fold. First, it ensures the system complies with the requirements of the applicable regulations. Second, it ensures that the current owners and

### operators are operating the systems in the proper manner. That is why such testing is necessary under this proposed regulation.

Additionally, even if the FPA had provided sufficient technical support justifying

a change to the sunset date, the date suggested by the FPA is incorrect. The FPA 's
comments state, "If IPCB were to establish a sunset date for applicability ofprior test, FPA would suggest the date of issuance of the US EPA policy memorandum fromJ. Seitz (EPA, 1995e) and the 'Guidelines for Determining Capture Efficiency' (EMC GD035)(EPA, 1995f), which include recommended procedures for capture testing. The documents represent EPA's last significant change to capture testing recommendations." The FPA's final sentence, and thus their conclusion, is simply wrong. USEPA Reference Method 204 

### for capture efficiency testing, discussed in the USEPA policy memorandum,

was not fully promulgated until the effective date of June l6, 1997, when it appeared in the Federal Register (62 Fed. Reg. 

### 32500). While the Agency maintains that the date already present in the ru1emaking proposal should remain in the rule for the reasons discussed elsewhere in this response, under no circumstance should such date be made earlier than the effective date listed above. It 

### should also be noted that the FPA's suggested date appears nowhere in the FPA's proposed rule changes.

The Agency would have been happy to discuss all ofthis with the FPA had the FPA contacted Agency personnel with its concerns.
Incomplete Proposed Revisions

Another outcome resulting from the FPA's failure to contact the Agency is the incomplete nature ofthe changes they have suggested. From a technical standpoint, the changes are unacceptable because they do not require that testing previously done by a
source actually demonstrated compliance with the new limits contained within the proposed rule. The ruJemaking proposal recommends efficiency requirements ranging from 65% to 80%, depending on the dates the subject printing line, capture system, and control device were first constructed at the subject source. The efficiency requirements in the current regulations, on the other hand, only range from 60% to 75%, depending on the type ofprinting line being controlled. Some sources may therefore be subject to a
more stringent limitation under the CTG's recommendations. Thus, if the FPA changes

were incorporated, a source that showed compliance with the previous limits under the old rule would not have to demonstrate compliance with the new limits to which they are subj ect.

In addition, 

### in suggesting these changes, the FPA apparently failed to check the
rest of the rule to determine what cross-references would need to be altered. Furthennore, the FPA failed to indicate what regulatory language would need to be deleted, instead only indicating the language they would like to see added. The overall effect of making these changes is therefore unclear

- an issue that could have been appropriately addressed during the Board's rulemaking process.

### Timing of FPA's Comments



### As set forth above, the FPA's comments are untimely, The rulemaking process exists for a reason: to provide aU interested parties sufficient opportunity to review the proposed rule, present evidence in support of, or in opposition to, the proposal, express concerns, ask questions, etc. The post-filing rulemaking process in this case has taken approximately a year, with extensive Agency outreach occurring prior to that. At no time during that year did the FPA participate in the rulemaking or apprise the Illinois EPA or Board of its concerns with the language at issue. Consequently, neither the Agency nor any other party with an interest in the rulemaking has had an opportunity to question the FPA regarding the bases of its proposed revisions, request additional information, or otherwise discuss the changes with the FPA. 

### This occurred despite the fact that the FPA

- Mr. Singhal in particular

- was specifically contacted multiple times by the Agency to

ensure that the FPA and members of the FPA did not have any comments about the proposal before it was submitted to the Board.

The Agency recognizes that unanticipated issues occasionally arise late in the

course of a rulemaking. For example, the Agency recently learned of the necessity of an extension of the compliance date for the testing requirements set forth in Section 218/219.401 (c)(6) due to the amount of time it took to complete this rulemaking. On the other hand, when an issue can be anticipated, and is in fact clearly evident at the inception of a ruJemaking, such issue should be addressed before the eleventh hour. 

### It does not serve the purposes of the rulemaking process or the parties who actuaUy choose
to participate in such process to tolerate unjustified delay. The FPA had ample notice of the Agency's proposed testing requirements, and yet did not choose to express its

concerns at any time during the past year. Its untimely comments, which recommend substantive and technically unsupported changes to the rulemaking proposal, should therefore be disregarded.

Sincerely,

# i/~J/;~**~~IVL#7r** Dana Vetterhoffer Assistant Counsel Division of Legal Counsel

# A 23CO-CHAIR: SEN. MAGGIE CROTTY

CO-CHAIR: REP. ANGELO 'SKIP' SAVIANO

EXECUTIVE DIRECTOR: VICKI THOMAS 

### JOINT COMMITTEE ON ADMINISTRATIVE RULES ILLINOIS GENERAL ASSEMBLY

SEN. J. BRADLEY BURZYNSKI SEN, RANDALL HULTGREN SEN. MATTIE HUNTER SEN. DAN RUTHERFORD SEN. IRA SILVERSTEIN REP. JOHN FRITCHEY REP. LOU LANG REP, DAVID MILLER REP. DONALD MOFFITI REP ROSEMARY MULLIGAN

Tanner Girard, Chairman Pollution Control Board James R. Thompson Center 100 W. Randolph, Suite 11-500 Chicago, lllinois 6060 I

Dear Chairman Girard: 700 STRAITON BUILDING S?RINGFIELO,llliNOIS 62706 217f785-2254

June 15,2010 

# f \C) /Cb
RECEIVED

CLERK'S OFFICe



## JUN 23 2010
STATE OF ILUNDIS Pollution Control 

## Board

This is to notifY you that JCAR considered the following proposed rulemakings at its 6/15/10 meeting:

Definitions and General Provisions (35 

### Ill. Adm. Code 211) 34 111. Reg. 1766

- 2/5/10

Organic Material Emission Standards and Limitations for the Chicago Area (35 

### Ill. Adm. Code 218) 34 Ill. Reg. 1791

- 2/5/10

Organic Material Emission Standards and Limitations for the Metro East Area (35 111. Adm. Code 219) 34 Ill. Reg. 1941

- 2/511 0

If your agency has agreed to any substantive modifications during its discussions with JCAR, they are described in the "Agreements" attached to the certification. Based on these agreements,

as well as the other responses you have provided the Committee during the review of these rulemakings, JCAR has determined that No Objection will be issued. Enclosed you will find formal certification of this action.

These rulemakings may now be adopted upon filing with the Office ofthe Secretary ofState.

Please note that the fact that the Committee has not objected to these rulemakings does not necessarily constitute approval, expressed or implied, ofthe substance ofthe rulemakings.Thank you for the cooperation your agency has shown during our review ofthese issues.

Sincerely,

# :J/J~ 

# aJ(

Senator Maggie Crotty Co-Chairman

SMC:RBH:DC:rrn

cc: Tim Fox Ene. Representative Angelo "Skip" Saviano Co-ChairmanCO-CHAIR: SEN. t.".AGGIE CROTTY

CO-cHAIR; REP. ANGELO ·SKlp· SAVIANO

EXECUTIVE DIRECTOR: VICKI THOMAS 

### JOINT COMMiTTEE ONADMINISTRATIVE RULES ILLINOIS GENERAL ASSEMBLY

700 STRAnON BUILDING SPRINGFIELD, ILLINOIS 52706**2171785-225~** 

### JOINT COMMITTEE ON ADMINISTRATNE RULES

CERTIFICATION OF NO OBJECTION TO PROPOSED RULEMAKING SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN. MAITrE HUNTER SEN. DAN RUTHERFORD SEN. IRA SILVERSTEIN REP JOHN FAITGHEY REP: LOU LANG REP: DAVID MILLER REP. DONALD MOFFITI REP. ROSEMARY MULLIGAN



## RECEIVED

CLERK'S OFFICE



## JUN '23 2010

STATE OF IlliNOIS Pollution Control 

## Board

This is to certifY that the Joint Committee on Administrative Rules, at its 6/15/10 meeting, considered Definitions and General Provisions (35 Ill. Adm. Code 21 I), proposed by the Pollution Control Board and published in the 2/5/10 issue of the Illinois Register. After consideration, and based upon the agreements, if any, for modification of the rulemaking made by the agency and attached to this document, the Committee determined that no Objection will be issued to the above-mentioned rulemaking.

June 15,2010 Vicki Thomas Executive Director

Attachments: None

### Agency:
Rulemaking:

Changes: 

## SECOND NOTICE CHANGES

Pollution Control Board

Organic Material Emission Standards and Limitations for the Chicago Area (35 Ill. Adm. Code 218; 34 111. Reg. 1791)

1. In line 438, change the subsection label to (t).

2. In line 634, delete the period.

3. In lines 837 and 863, delete the period.

4. In line 958, change "Sections" to "subsections", strike "218.204" 4 times and strike "and".

5. In line 959, delete "218.204" and after "(ill" add "ofthis Section,".

6. In lines 1033 and 1054, strike "218.204".

7. In line 1060, strike "above".

8. In line 1076, strike ", below".

9. In line I 145, delete "or".

1 O. In line 1158, strike the 3 rd closing parenthesis.

II. In line 1160, strike the comma and add a semicolon.

12. In line 1167, after the closing parenthesis add a comma.

13. In the table after line 1184, in the 4th and 5 th where statements, strike "which" and add IIthat tt

•

14. In the table after line 1193, in the 4'h, 6th

, and 7th where statements, strike "which" and add "that".

15. In line 1205, strike the comma and add a semicolon.

### 16. In line 1212, after the closing parenthesis add a comma.

17. In 

### line 1226, strike the comma and add a semicolon.

18. In line 1233, after the closing parenthesis add a comma.

19. In line 1246, strike the comma and add a semicolon.

20. In 

### line 1301, strike the comma and add a semicolon.

21. In line 1337, strike "or" and change 

## "ill" to "(m)".

22. In line 1346, strike "or" and after 

### "(1)" add "or (m)".

23. In line 1355, strike the comma and add a semicolon.

24. In line 1377, strike "above".

25. In 

### line 1385, strike the 2nd "218.204" and before "and" add "ofthis Subpart".

26. In lines 1393, 1401, 1409-1410 and 1417, strike the brackets and add parentheses.

27. In 

### the table after line 1436:

in the 4 th 

### and 5th 

### where statements, strike "which" and add "that".

in the 5th 

### where statement, 4th 

### line, after the closing parenthesis add a semicolon.

28. In line 1478, change the subsection label to (m).

29. In 

### line 1495, strike "or" and change 

### "(g}" to 

## "ill".

30. In lines 1535 and 1538, strike the 2nd 

### and 3 m 

### "218.204".

31. In line 1542, change the subsection label to an (h).

32. In 

### line 1661, strike "which" and add "that".

33. In line 1667, delete "and".

34. In line 1672, strike "and".

35. In line 1675, strike "218.204".

### 36. 

### In line 1679, strike the period and add "; and".

37. In line 1681, change the subsection label to (F).

38. In line 1708, delete "and".

39. In line 1714, strike "and".

40. In line 1720, strike the period and add "; and".

41. In line 1722, change the subsection label to (G).

42. 

### In line 1738, strike "below".

43. In line 1779, strike "218.204".

44. In lines 1784-1796, change the subsection labels to (G) through (1).



### 45. In line 1824, strike "218.204".

46. In lines 1829 and 1833, change the subsection labels to (F) and (G).

47. In line 1857, strike "or" and change 

## "ill" to "fm}".



### 48. In lines 1955 and 1978-1979, strike "kg (lbs) per I (gal)" and add "kgll (1bslgal)".

49. In line 1998, strike "of' and add "after".

50. 

### In line 2020, change the subsection label to (h).



### 51. In line 2028, delete the 2nd 

### "218.217".

52. In line 2042, strike "or" and delete "Section".

53. Inline2043,delete"218.204".

54. In the table after line 2107, in the 4th 

### and 5th 

### where statements, strike "which" and add "that".



### 55. 

### In the table after line 2125, in the 4th

, 

### 6 th 

### and 7'h 

### where statements, strike "which" and add "that't.56. 

### In the table after line 2135:

in the 7th where statement, strike "and".

in the 8th and 9'h where statements, strike "which" and add "that".

57. 

### In line 2176, delete "218.204".

58. In line 2272, change the header to "Weighted Averaging Alternative".

59. In the table after line 2294, in the 1 st and 4th where statements, strike "which" and add "that",

60. In line 2312, delete the 2 nd "subsection".

61. In line 2353, change the header to "Capture System and Control Device Requirements".

62. In line 2427, delete the 2nd "subsection",

63. Change line 2444 to "subject to the requirements in subsection (c)(I)(B) or (c)(2)".

64. In lines 2446, 2448, 2457 and 2461, change "Section 218.401" to "subsection".

65. 

### In lines 2515 and 2517, strike "Sections" and add "Section",

66. 

### In line 2535, change "schedules 

### seheSllle" to "schedule or schedules" and add a comma after "(c)".

67. 

### In line 2770, strike the 3'" "218.401 ".

68. 

### In line 2936, after "subsection" add "(b)(I)(A)",

69. 

### In line 2967, delete the 2nd "218.407",

70. 

### In lines 2987 and 2988, delete the 2nd and 3'" "218.407".

71, 

### In line 3260, strike "exhaust(s)" and add "exhausts",

72. 

### In line 3261, after "follows" add a colon.

73. 

### In lines 3388, 3395 and 3400, strike "Appendix" and add "appendix".

74, 

### In line 3473, strike the period.

### 75. In line 3541, strike "For" and add "for".

76. In 

### line 3600, capitalize "units".

77. In line 3659, strike "TPY" and add "tons/yr".

78. In 

### line 3689, change the header to "Exempt Units on and after August 1.2010".

79. In line 3691, change the header to "Lithographic Printing Lines Exempt pursuant to Section 218.405(c)(2).".

80. In 

### lines 3706 and 3830, change "Part" to "Subpart".

8 I. 

### In line 3929, strike "Section 2I 8.4 I I" and add "subsection" and delete "218.411 ".

82. In line 3930, delete "218.411" and strike "Subpart" and add "Section".

83. In line 3960, strike "Section 218.411 " and add "subsection" and delete "218.411".

84. In line 3961, delete "218.411" and strike "Subpart" and add "Section".

85. In line 3971, change "lines" to "line".

86. In line 4012, strike "is" and add "are".

87. In line 4016, strike "is" and add "are" twice.

88. In line 4060, strike "(b)" 

### and add "@".



### 89. In line 4068, after "Subpart" strike the comma.

90. In line 4098, strike "Section" and add "subsection".

91. In line 4099, strike "218.411" and strike "Subpart" and add "Section".

92. In line 4163, strike "Sections" and add "Section".

93. In line 4177, strike the semicolon and add a period.

94. In line 4220, strike "Section" and add "subsection".

95. In line 4221, strike "218.411" and strike "Subpart" and add "Section".

96. In line 4258, strike "which" and add "that".

### 97. In 

### line 4362, change "Section" to "subsection".

98. In line 4363, delete "218.41 I" and change "Subpart" to "Section".

99. In 

### line 4395-4396, change the header to "Provisions for Calculation ofEmissions from Heatset Web Offset Lithographic Printing Operations.".

100. In line 4411, before "The" add an (A) subsection label.

101. In line 4420, before "For" add a (B) 

### subsection label.

102. In line 4433, before "The" add an (A) subsection label.

103. In the table after line 4440, in the 2nd 

### where statement after "wash" add a semicolon.

104. In line 4442, before "For" add a (B) 

### subsection label.

105. In lines 4568, 4575 and 4580, change "Appendix" to lower case.

106. In line 4651, change the header to "Afterburners for Heatset Web Letterpress Printing 

### Lines.".

107. In 

### line 4666, change the header to "Other Control Devices for Heatset Web Letterpress Printing Lines.".

108. In 

### line 4673, change the header to "Cleaning Solution".

I09. In line 4824, change "subsection" to "subsections".

110. In line 4849, change "Section 218.417" to "subsection" and change "Subpart" to IlS 

### ection".

III. In line 4876, change "Section 218.417" to "subsection" and change "Subpart;" to IlSection.'r.



### 112. In 

### lines 4922 and 4923, change 

## "12" to "are".

lB. In line 4983, change "Section" to "subsection".

114. In line 4984, delete "218.417" and change "Subpart" to "Section".

6/1110CO-GHAIR: SEN. MAGGIE CROTTY

CO-CHAIR: REP: ANGELO "SKIP' SAVIANO

EXeCUTIVE DIRECTOR: ViCKI THOMAS 

### JOINT COMMITTEE ONADMINISTRATIVE .RULES ILLINOIS GENERAL ASSEMBLY

.....

700 STRATTON BUILDING SPRINGFIELD. ILLINOIS 62706 217n85·2254
JOINT COMMITTEE ON ADMINISTRATIVE RULES

CERTIFICATION OF NO OBJECTION TO PROPOSED RULEMAKING SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN. MATIIE_HUNTER SEN. DAN RUTHERFOAD SEN. IRA SILVERSTEIN REP. JOHN FRITCHEY REP. LOU LANG REP. DAVID MIlleR REP. DONALD MOFFITI REP. ROSEMARV MULLIGAN



### RECEiveD

CLERK'S 

### OFFICE



## JUN '23 2010

STATE OF 

### ILLINOIS Pollution 

### Control 

### Board

This is to certify that the Joint Committee on Administrative Rules, at its 6/15/1 0 meeting, considered Organic Material Emission Standards and Limitations for the Chicago Area (35 Ill. Adm. Code 2I 8), proposed by the Pollution Control Board and published in the 2/5/10 issue of the Illinois Register. After consideration, and based upon the agreements, if any, for modification of the rulemaking made by the agency and attached to this document, the Committee determined that no Objection will be issued to the above-mentioned rulemaking.

June 15, 2010

Attachments: Agreements

# ,},.~**-Jl.A,~** 

# _ ..

_ Vicki Thomas Executive Director

### Agency:
Rulemaking:

Changes: 

## SECOND NOTICE CHANGES

Pollution Control Board

Organic Material Emission Standards and Limitations for the Metro East Area (35 Ill. Adm. Code 219; 34 Ill. Reg. 1941)

1. In 

### line 381, strike "below".

2. In 

### line 386, after "Section" add a comma.

3. In 

### line 394, change the subsection label to (d).

4. In line 585, delete the period.

5. In lines 788 and 814, delete the period.

6. In line 909, change "Sections" to "subsections" and strike "219.204" 4 times.

7. In line 910, delete "219.204" and after "(Q)" 

### add "ofthis Section".

8. After line 979, in subsection (j)(6), strike "219.204".

9. After line 980, in subsection (k)(4), strike "above".

10. In line 996, strike ", below".

II. In 

### line 1003, strike "Section 219.204" and add "subsection" and strike "Subpart" and add "Section".

12. In line 1006, strike "Section" and add "subsections".

13. In line 1007, strike "219.204" and strike "Subpart" and add "Section".

14. In 

### line I 056, delete "or".

15. In line 1069, after the closing parenthesis add "}".

16. In line 1071, strike the comma and add a semicolon.

### 17. In line 1078, after the closing parenthesis, add a comma.

18. In the table after line 1095, in the 4th 

### and 5th 

### where statements, strike "which" and add "that".



### 19. In the table after line 1104, in the 4th

, 

### 6th

, 

### and 7th 

### where statements, strike "which" and add "that".

20. In line 1116, strike the comma and add a semicolon.

21. In line 1123, after the closing parenthesis, add a comma.

22. In line 1135, after the closing parenthesis, add "}".

23. In line 1137, strike the comma and add a semicolon.

24. In line 1144, after the closing parenthesis add a comma.

25. In line 1155, after the closing parenthesis, add "}".

26. In line 1157, strike the comma and add a semicolon.

27. In lines 1175 and 1193, strike the comma and add a semicolon.

28. In 

### line 1229, change 

### "ill" to 

## "ill".

29. In line 1238, strike "or" and after "(k)" add 

### "Q[..Ql".

30. In line 1247, strike the comma and add a semicolon.

31. In line 1269, strike "above".

32. In line 1277, strike "Part" and add "Subpart".

33. In line 1285, after the closing parenthesis, add "}".

34. In 

### the table after line 1320:

in the 4th 

### and 5th 

### where statements, strike "which" and add "that".

in the 5th 

### where statement, after the closing parenthesis add a semicolon.

35. In line 1362, change the subsection label to (I).36. In line 1379, strike "or" and change "(g}" to "fh}".

37. In line 1409, strike "Sections" and add "Section".

38. In lines 1419 and 1422, strike the 2nd and 3n1 "219.204".

39. In line 1426, change the subsection label to an (h).

40. In the table after line 1466, in the 6th and 7th where statements, strike "which" and add "that".

41. In line 1545, strike "which" and add "that".

42. In line 1551, delete "and".

43. In line 1556, strike "and".

44. In line 1559, strike "219.204".

45. In line 1563, strike the period and add "; and".

46. In line 1565, change the subsection label to (F).

47. In line 1592, delete "and".

48. In line 1598, strike "and".

49. In line 1604, strike the period and add "; and".

50. In line 1606, change the subsection label to (G).

51. In line 1621, strike "below".

52. In line 1662, strike "219.204".

53. In lines 1667-1679, change the subsection labels to (G) through (1).

54. In line 1707, strike "219.204".

55. In lines 1712 and 1716, change the subsection labels to (F) and (G).

56. In line 1739, strike "or".

### 57. In line 1740, after "(k)" add 

## "..i!!..ill".

58. In lines 1838 and 1861-1862, strike "kg (Ibs) per I (gal) "and add "kg/I Clbs/gall".

59. In line 1881, strike "of" and add "after".

60. In line I 903, change the subsection label to (h).

61. In line 1911, change "Sections" to "Section" and delete the 2nd 

### "219.217".

62. In the table after line 1990, in the 4'h and 5th where statements, strike "which" and add 

### "that"
.

63. In line 1998, strike "subsection" and add "Section".

64. In 

### the table after line 2008, in the 4'\ 6th

, and 7th where statements, strike "which" and add "that".

65. In the table after line 2018, in the 8th 

### and 9th where statements, strike "which" and add "that",



### 66. In 

### line 2059, delete "219.204".

67. In 

### line 2155, change the header to "Weighted Averaging Alternative".

68. In the table after line 2177, in the 1st 

### and 4th where statements, strike "which" and add lIthatrl.



### 69. In 

### line 2I 95, delete the 2nd 

### "subsection".

70. In line 2236, delete the period.

71. In line 2265 and 2268, strike the comma and add a semicolon.

72. In 

### line 227 I, strike" and"

.
73. In lines 2327-2328, change "(c)m or (c)(I)(B)" to "(c)(I)(B) or (c)(2)".

74. In 

### line 2310, delete the 2nd 

### "subsection".

75. In line 2318, strike the comma and add a semicolon.

76. In lines 2327, 2329, 2331-2332,2341 and 2345, change "Section 219.401" to



### " subsection ll

•

### 77. In lines 2388 and 2392, change "line(s)" to "lines".

78. In lines 2396 and 2398, strike "Sections" and add "Section".

79. In line 24 I 7, change "schedules 

### S6Red\lle" to "schedule or schedules".

80. In line 2650, strike the 3'd "219.401".

81. In line 2816, after "subsection" add "(b)(])(A)".

82. In 

### line 2847, delete the 2nd "219.407".

83. In lines 2867 and 2868, delete the 2nd and 3 rd 

### "219.407".

84. In 

### line 3141, strike "exhaust(s)" and add "exhausts".

85. In 

### lines 3270, 3277 and 3282, strike "Appendix" and add "appendix".

86. In line 3355, strike the period.

87. In line 3373, strike "line(s)" and add "lines".

88. In line 3423, strike "For" and add "for".

89. In line 3481, capitalize "units".

90. In line 3529, strike "line(s)" and add "lines".

91. In line 3540, strike "TPY" and add "tons/yr".

92. In line 3570, change the header to "Exempt Units on and after August I, 

### 2010".

93. In 

### line 3572, change the header to "Lithographic Printing Lines Exempt pursuant to Section 2 19 .405(c)(2).".

94. In lines 3587 and 3711, change "Part" to "Subpart".

95. In line 3803, strike "Section 219.411" and add "subsection" and delete "219.411 ".

96. In line 3804, delete "219.411" and strike "Subpart" and add "Section".

97. In line 3835, strike "Section 219.411" and add "subsection" and delete "219.411 ".98. 

### In line 3836, delete "219.411" and strike "Subpart" and add "Section".

99. 

### In line 3846, change "Iine(s)" to "line".

100. 

### In line 3887, strike "is" and add "are".

101. 

### In line 3891, strike "is" and add ",!!IT" twice.

102. 

### In line 3935, strike "(b)" and add "@".

103. In line 3943, after "Subpart" strike the comma.

104. 

### In line 3973, strike "Section" and add "subsection".

1 05. 

### In line 3974, strike "219.411" and strike "Subpart" and add "Section".

106. In line 4038, strike "Sections" and add "Section".

107. 

### In line 4052, strike the semicolon and add a period.

108. 

### In line 4095, strike "Section" and add "subsection".

109. 

### In line 4096, strike "219.411" and strike "Subpart" and add "Section".

110. In line 4133, strike "which" and add "that".

111. In line 4237, change "Section" to "subsection".

112. In line 4238, delete "219.411" and change "Subpart" to "Section".

113. 

### In line 4270-4271, change the header to "Provisions for Calculation of Emissions from Heatset Web Offset Lithographic Printing Operations.".

114. In line 4286, before "The" add an (A) subsection label.

115. In line 4295, before "For" add a (B) subsection label.

116. 

### In line 4308, before "The" add an (A) subsection label.

117. 

### In line 4317, before "For" add a (B) subsection label.

118. In lines 4443, 4450 and 4455, change "Appendix" to lower case.

119. 

### In line 4526, change the header to "Afterburners for Heatset Web Lettemress Printing

### Lines.".

120. In line 4541, change the header to "Other Control Devices for Heatset Web Lettemress Printing Lines.",

121. In line 4548, change the header to "Cleaning Solution".

122. In line 4701, change the semicolon to a period.

123. 

### In line 4703, change "subsection" to "subsections",

124. In lines 4728 and 4755, change "Section 219.417" to "subsection" and change "Subpart"
to "S ection ll

•

125. In line 4755, change the semicolon to a period.

126. In lines 4801 and 4802, change**"~"** to "are".

127. In line 4862, change "Section" to "subsection".

128. In line 4863, delete "219.417" and change "SUbpart" to "Section".

5127110

### JOINT COMMITTEE ONADMINISTRATlVE RULES ILLINOIS GENERAL ASSEMBLY

CO-CHAIR: SEN. MAGGIE CROTTY'

CO-CHAlR: REP. ANGElO ·SKIP· SAVIANO

EXECUTIVE DIRECTOR; VICKI THOMAS SEN. J. BRADLEY BURZYNSKI SEN. RANDALL HULTGREN SEN. MATTIE HUNTER SEN. DAN AU1HERFOAD SEN. IRA SILVERSTEIN REp. JOHN FRITCHEY REP. LOU LANG REP. DAVID MILLER REP DONALD MQFFITI REP. ROSEMARY MULUGAN

CERTIFICATION OF NO OBJECTION TO PROPOSED RULEMAKING 700 STRATTON BUILDING SPRINGFlaD, ILUNDIS 62706 217((85-2254

JOINT COMMITTEE ON ADMINISTRATIVE RULES 

### FtECEUVED CLERK'S OFFICE



## JUN'232010
STATE OF ILLINOIS Pollution Control Board

This is to certify that the Joint Committee on Administrative Rules, at its 6/1 5/1 0 meeting, considered Organic Material Emission Standards and Limitations for the Metro East Area (35 111. Adm. Code 219), proposed by the Pollution Control Board and published in the 

### 2/5/1 0 issue of the Illinois Register. After consideration, and based upon the agreements, if any, for modification of the rulemaking made by the agency and attached to this document, the Committee determined that no Objection will be issued to the above-mentioned rulemaking.

June 15,2010

Attachments: Agreements 

### A 

## f 

# 'k :JJ.i1, 4lK Vicki Thomas Executi ve Director