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

217/782-5544

217/782-9143 (TDD)

October 25, 2010

Cheryl Newton, Director

Air and Radiation Division

United States Environmental

Protection Agency Region Y

77 West Jackson Boulevard, AR-18J

Chicago, Illinois 60604-3598

Attn: Jay Bortzer

DOUGLAS P. SCOTT, DIRECTOR

I

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_::)····~~~TPiIi~ ~~IL0152 3830

RETURN RECEIPT REQUESTED

Re: RI0-7: In the Matter of: Exemptions From the Definition of YOM, USEPA

Amendments (January 1,2009 through June 30, 2009)

C~1./1 Dear Ms. ,.Newton:

.//

Pursuant to Section 110(a)(2) ofthe Clean Air Act (CAA) (42 U.S.C. §7410 (a)(2)), and Section

28 ofthe Illinois Environmental Protection Act (415 ILCS 5/28), the Illinois Environmental

Protection Agency (Illinois EPA) submits the following amendments to the Illinois State

Implementation Plan (SIP). The amendment updates the definition for volatile organic material

(YOM) contained in 35 Ill. Adm. Code 211.7250 to reflect the United States Environmental

Protection Agency's (USEPA) most recent exemption of chemical compounds from regulation as

ozone precursors.

The rulemaking was docketed by the Illinois Pollution Control Board (IPCB) as R10-7. The Notice

of Proposed Amendments was published in the Illinois Register volume 33, issue 42, p. 14275,

published October 16,2009. On October 1,2009, the Illinois Pollution Control Board ("Board")

reserved a docket for the routine updating ofthe definition ofYOM. Notice ofHearing was filed on

the same day. A public hearing was held November 19,2009, in Chicago, Illinois. The Illinois EPA

filed post-hearing comments in support ofthe proposed amendments. On January 7, 2010, the Board

adopted a Final Opinion and Order.

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

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

Bureau of Land - Peoria. 7620 N. University St., Peoria, IL 61614. (309) 693-5462

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

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

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

Champaign. 2125 S. First St., Champaign, IL 61820. (217) 278-5800

Marion. 2309 W. Main St., Suite 116, Marion,1L 62959. (618) 993-7200

Printed on Recycled Papel
In order to assist with your review ofthis SIP submittal, the following documents are enclosed:

Attachment 1)

Attachment 2)

Attachment 3)

Attachment 4)

Attachment 5)

Attachment 6)

Attachment 7)

Attachment 8)

Attachment 9)

Attachment 10)

The Board's Proposal of Amendments, filed October 1,2009 and Proposed

rule.

Board Hearing Officer Order, Notice of Hearing, dated October!, 2009

Illinois Register Notice of Proposed Amendments, volume 33, issue 42, p.

14275, published October 16,2009

Appearance ofCharles E .Matoesian for the Illinois Enviromnental Protection

Agency, dated November 17,2009

Transcript of Hearing, filed December 11, 2009

Post-hearing comments ofthe Illinois EPA, filed December 7, 2009

Adopted Rule, Final Order, Opinion and Order ofthe Board by G.T.

Girard, dated January 7, 2010

Illinois Register Notice of Adopted Amendments, volume 34, issue 4, p.

1391, published January 22, 2010.

JCAR memorandum scheduling the Rule to be considered at its February 9,

2010 meeting.

JCAR Letter stating the proposed rulemaking was considered at JCAR's

February 9, 2010 meeting with the attached Certification ofNo

Objections, dated February 9,2010

The SIP Checklists are also enclosed to assist in your review.

If further information is required, please contact Shannon Bilbruck of my staff at 217/557-4261.

c.o.. r.di.ia;}Y: . .j/Yr~

Laurel L. Kroack, Chief

Bureau of Air

Attachments

bcc: Laurel Kroack- letter, checklists

Vicky Von Lanken- letter, checklists

Jim Ross- letter, checklists

AQPS- letter, checklists, attachments

Charles Matoesian- letter, checklists

Shannon Bilbruck- letter, checklists, attachments
STATE IMPLEMENTION PLAN CHECKLISTS

RlO-7: In the Matter of: Exemptions From the Definition of YOM, USEPA

Amendments (January 1,2009 through June 30, 2009)

Illinois Environmental Protection Agency

Bureau of Air

Division of Legal Counsel

1021 North Grand Ave. East

P.O. Box 19276

Springfield, Illinois 62794-9276
ADMINISTRATIVE CHECKLIST

Re: RI0-07 Attachment

1. The Submittal is accompanied by a formal letter of Yes, Cover

submittal from the Governor or designee. letter

The date ofsubmittal is

2. Evidence is provided that the revision has been adopted in Yes, Cover

the State Code or body ofregulations. letter, 8

• The date of adoption is January 22,2010.

• Test methods/rules are correctly incorporated by

reference

3. Evidence is provided that the State has the necessary legal Sections 28 of

authority under State law to adopt and implement the the Ill. Env.

reViSIOn Prot. Act

4. A copy ofthe actual regulation or document is included in 8

the submittal

5. Evidence is provided that the State followed all the 2, 3, 5, 6, 7, 8,

requirements of its Administrative procedures Act (or 9,10

equivalent) in conducting and completing

adoption/issuance ofthe revision.

6. Evidence is provided that public notice was given by the 2,7,8,10

State, including the date of publication.

7. Certification is provided that the public hearing was held in 2,5

accordance with the information provided in the public

notice.

The date ofthe public hearing was Nov. 19,2009

8. The submittal contains a compilation ofthe exhibits

entered into the record at hearing.

9. The submittal contains a compilation of public comments 7
TECHNICAL CHECKLIST

Re: RIO-07 Attachment

1. The regulated pollutants affected by revision are: sulfur

dioxide__; ozone ~; particulate matter__; I

nitrogen oxides ; carbon monoxide

2. Attaimnent status designation for the affected area is N/A

included in the submittal.

Status ofthe attainment plan for the affected area is N/A

included in the submittal.

The attainment date for the affected area is included in the N/A

submittal.

3. The locations and types of affected sources are identified. I

4. Changes in SIP-allowable emissions for affected sources N/A

are quantified or estimated.

Changes in actual emissions from affected sources are N/A

quantified or estimated.

5. Evidence is provided that the NAAQS will be protected if N/A

the revision is approved and implemented.

Evidence is provided that the PSD increment will be N/A

protected ifthe revision is approved and implemented.

Evidence is provided that the RFP demonstration will be N/A

protected ifthe revision is approved and implemented.

Evidence is provided that visibility will be protected ifthe N/A

revision is approved and implemented.

6. Modeling information is provided (if necessary) in support N/A

ofthe revision.

7. The proposed emission limitations are based on N/A

continuous emissions reduction technology.

8. The emissions limitations requirements are incorporated (if N/A

necessary) to ensure emission levels.

The work practice standards requirements are incorporated N/A

(if necessary) to ensure emission levels.

The recordkeeping/reporting requirements are incorporated N/A

(if necessary) to ensure emission levels.

9. The submittal contains enforcement/compliance strategies, N/A

including how compliance will be determined in practice

and at what frequency.
ENFORCEABILITY CHECKLIST

Re: RIO-07 Attachment

1. Applicability

What sources are being regulated? I

What are criteria for exemption? N/A

Is calculation procedure for exemption clearly specified? N/A

Is emission inventory listed in the background document of N/A

the attainment demonstration?

Are the averaging times used in the rule different from N/A

those ofthe ambient standard?

What are the units of compliance (lbs VOC per gallon of N/A

solids applied less water, grains per standard cubic foot)?

Is bubbling or averaging of any type allowed? If yes, state No

criteria. Could a USEPA inspector independently

determine ifthe criteria were met? Does EPA have to

approve each case?

Ifthere is a redesignation, will this change the emission N/A

limitations? If yes, which ones and how?

"-'.

') Compliance Dates

What is the compliance date? 8

What is the attainment date? N/A ,.,

-'. Specificity of Conduct

What test method is required? N/A

What is the averaging time in compliance test method? N/A

Is a compliance calculation or evaluation required? (i.e., N/A

daily weighted average for VOC)

If yes, list the formula, period of compliance, and/or N/A

evaluation period.

4. Incorporation by Reference

What is the state authority for rulemaking? Section 28 ofthe m

Env. Prot. Act

Are methods/rules incorporated by reference in the right N/A

manner?

5. Recordkeeping

What records are required to determine compliance? N/A

In what form or units (lbs/gal, gr/dscf, etc...) must the N/A

records be kept? On what time basis (instantaneously,

hourly, daily)?

Does the rule affirmatively require the records be kept? N/A

6. Exemption

List any exemptions allowed. N/A

Is the criteria for application clear? N/A