ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 NORTH GRANO AVENUE EAST, P.O. Box 19506, SPRINGFIELD, ILLINOIS 62794··9506 ~ ( 217) 782-2113 

PAT QUINN, COVCRNOR 

217/785-4140 

217/782-9143 (TDD) 

September 16, 201 1 

Ms. Cheryl A. Newton, Director 

Office of the Air and Radiation Division 

U.S. Environmental Protection Agency, Region V (R18J) 

77 West Jackson Bonlevard 

Chicago, Illinois 60604-3507 

Re: Control Techniques Guidelines SIP Submittal and Redesignation Requests for 8-Hour 

Ozone and P 

The Illinois Environmental Protection Agency (Illinois EPA), on behalf of the State of Illinois, is 

making three requests regarding State Implementation Plan (SIP) requirements related to the 

1997 8-hour ozone and fine particle (PM25) National Ambient Air Quality Standards (NAAQS). 

First, the Illinois EPA hereby requests that the Illinois portion of the Chicago ozone 

nonattainment area be redesignated to attainment of the 8-hour ozone standard promulgated in 

1 997. The Chicago ozone nonattainment area consists of Cook, Lake, DuPage, McHemy, Kane, 

Will, and portions of Grundy and Kendall counties in Illinois, as well as Lake and P01ier 

counties in northwest Indiana. The Illinois EPA understands that the State of Indiana has already 

submitted a similar redesignation request. Ambient air monitoring data collected by the Illinois 

EPA in the Chicago nonattainment area, as well as data collected in northwest Indiana and 

southeast .Wisconsin, demonstrates that the area is c\liTently meeting the 1997 8-hour ozone 

NAAQS, and has been meeting the NAAQS since the 2006-2008 period. Note that U.S. EPA 

published a Clean Data Determination for the Chicago ozone nonattainment area on Aprill2, 

2010. 

Second, the Illinois EPA requests that the Illinois portion of the St. Louis ozone nonattainment 

area, known as the Metro-East area, be redesignated to attainment of the 8-hour ozone standard 

promulgated in 1997. The Metro-East portion of the ozone nonattainment area consists of 

Madison, Momoe, St. Clair, and Jersey counties in Illinois. The Illinois EPA understands that 

the State of Missouri is making a similar redesignation request. Ambient air monitoring data 

collected by the Illinois EPA in the Metro-East area, as well as data collected in Missouri, 

demonstrates that the entire St. Louis nonattainment area is currently meeting the 1997 8-hour 

ozone NAAQS, and has been meeting the NAAQS since the 2007-2009 period. Note that U.S. 

EPA published a Clean Data Determination for the St. Louis ozone nonattainment area on Jnly 

11, 2011. 

PRINTED ON RECYCLED PAPER 
Third, the Illinois EPA hereby requests that the Illinois portion of the Chicago PM2 5 

nonattainment area be redesignated to attainment of the fme particle standard promulgated in 

1997. The Chicago PM25 nonattainment area consists of Cook, Lake, DuPage, McHenry, Kane, 

Will, and portions of Grundy and Kendall counties in Illinois, as well as Lake and Porter 

counties in northwest Indiana. The Illinois EPA understands that the State ofindiana has already 

submitted a similar redesignation request. Ambient air monitoring data collected by the Illinois 

EPA in the Chicago nonattainment area, as well as data collected in northwest Indiana, 

demonstrates that the area is currently meeting the 1997 PM25 NAAQS, and has been meeting 

the NAAQS since the 2007-2009 period. Note that U.S. EPA published a Clean Data 

Determination for the Chicago PM25 nonattainment area on November 27, 2009. 

In support of these redesignation requests, the Illinois EPA submits the follovving amendments to 

Jllinois' SIP for ozone and PM2 5: 

• Reasonably Available Control Technology (RACT) for Volatile Organic Material 

(YOM) Emissions from Group II and Group IV Consumer and Commercial 

Products; Proposed Amendments to 3 5 Ill. Adm. Code 211, 218, and 219; 

• Final Maintenance Plan for the Illinois Portion of the Chicago Ozone 

Nonattainment Area for the 1997 8-Hour Ozone National Ambient Air Quality 

Standard; 

• Final Maintenance Plan for the Metro-East Ozone Nonattainment Area for the 

1997 8-Hour Ozone National Ambient Air Quality Standard; 

• Final Maintenance Plan for the Chicago Nonattainment Area for the 1997 PM2s 

National Ambient Air Quality Standards. 

The YOM RACT submittal is intended to meet the obligation of the State of Illinois under the 

Clean Air Act (CAA) to submit a revision to the SIP to address requirements under Sections 172 

and 182 for sources ofVOM emissions in areas designated as nonattainment with respect to the 

ozone NAAQS. This submittal addresses deficiencies identified by your staff in Illinois EPA's 

previous submittal dated July 29, 2010. We have worked closely with your staff in this regard 

and we believe this submittal is fully approvable. As you know, U.S. EPA did not identify 

deficiencies in Illinois EPA's July 29,2010 submittal with regards to the Group III Consumer 

and Commercial Product Categories, so these rules have not been amended and are not included 

in this submittal. 

The Illinois EPA is also submitting Maintenance Plans for the Chicago and Metro-East 8-hour 

ozone nonattainment areas, and the Chicago PM2.5 nonattainment area pursuant to Sections 

107(d)(3)(E), 110(a)(2), and 175A of the CAA. Included with these plans are revised year 2025 

motor vehicle emissions budgets developed using the MOVES model. The Maintenance Plans, 

including the motor vehicle emissions budgets, are required as part of the Illinois EPA's 

redesignation request. The Maintenance Plans provide the supporting information for this 

request, consistent vv:ith the criteria for redesignation set forth in Section 175A of the CAA. 

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The Maintenance Plans constitute revisions of Illinois' SIP for ozone and PMz.s. Accordingly, 

the Illinois EPA held a public comment period and offered an opportunity for a public hearing. 

The Public Notice was published in local newspapers on July 8, 2011, aud also posted on the 

Illinois EPA's web site. Due to receiving no requests for a hearing a hearing was not held. 

However, the Illinois EPA did receive comments during the 30 day comment period. The 

enclosed Responsiveness Summary summarizes the connnents received and the Illinois EPA's 

revisions to the Final Maintenance Plan to address these comments. 

In order to assist with your review of these SIP submittals, two paper copies aud au electronic 

disk of all documents are enclosed. A list of the enclosed documents is also attached. 

The Illinois EPA believes that these submittals, in conjunction with other submittals made 

previously to the U.S. EPA, will allow the U.S. EPA to expeditiously take the necessary actions 

to redesignate both the Chicago and Metro-East areas to attainment for the 1997 8-hour ozone 

standard and to redesignate the Chicago area to attaimnent for the 1997 PM2 5 standards. 

If further information is required or should you have any questions, please feel free to contact 

Rob Kaleel, Air Quality Planning Section, at (217) 524-43 87. 

Sincerely, 

{<U~~ 

Laurel L. Kroack 

Chief, Bureau of Air 

Attaclm1ents 

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Illinois State Implementation Plan 

List of Enclosed Documents 

RACT for YOM Emissions from Group II and Group IV Consumer and Commercial 

Products; Proposed Amendments to 35 Ill. Adm. Code 211, 218, and 219 

1. Illinois EPA regulatory proposal, March 7, 2011 (certain documents omitted) 

2. Letter from Acting Chairman Girard to Director Ribley of the Department of Commerce 

and Economic Opportunity ("DCEO") regarding request for economic impact study, 

March 17,2011 

3. Order of the Board by A.S. Moore, accepting the Illinois EPA's regulatory proposal for 

hearing, granting the Illinois EPA's request for waiver of copy requirements, and 

ordering the clerk to tile the proposal for first notice publication in the Illinois Register, 

March 17,2011 (full text of rule omitted) 

4. Hearing Officer Order, Notice of Hearings, March 17, 2011 

5. Illinois Register Notice of Proposed Amendments, 35 Ill. Reg. 4887, April!, 2011 (full 

text of rule omitted) 

6. Prefiled Testimony of David Bloomberg and Prefiled Testimony ofYoginder Mahajan of 

Illinois EPA, April 14, 2011 

7. Comments of Specialty Graphic Imaging Association, April15, 2011 

8. Illinois EPA's Motion to Amend Rulemaldng Proposal, Apri125, 2011 

9. Record of Hearing, April27, 2011 (full transcript omitted) 

I 0. Prefiled Testimony of James Sell, American Coatings Association, May 6, 2011 

11. Post-Hearing Comments of the Illinois EPA, May 16,2011 

12. Comments of The Boeing Company, filed May 17,2011 

13. Record of Hearing, May 18, 2011 (full transcript omitted) 

14. Illinois EPA's Request to Cancel [Third] Hearing and Motion to Correct Transcript, May 

19,2011 

15. Hearing Officer Order cancelling third hearing, May 20, 2011 

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16. Post-Hearing Comments of the Illinois EPA, June 1, 2011 

17. Order of the Board by A.S. Moore, adopting the rule for second notice review by JCAR, 

June 16,2011 (full text of rule omitted) 

18. Letter from JCAR to Acting Chairman Girard and Certification ofNo Objection to 

Rulemaking Proposal, July 12, 2011 

19. Final Order of the Board by A. S. Moore, adopting the rule and ordering the clerk to file 

final rule for publication in Illinois Register, July 21, 2011 (full text of rule omitted) 

20.lllinois Register Notice of Adopted Amendments, 35 Ill. Reg. 13451, August 12,2011 

Maintenance Plans for the Chicago and Metro-East Ozone Nonattainment Areas for the 

1997 8-Hour Ozone NAAQS, and the Chicago PM2.5 Nonattainment Area for the 1997 

PM25 NAAQS 

1. Final Maintenance Plan for the Illinois Portion of the Chicago Ozone Nonattainment 

Area for the 1997 8-Hour Ozone National Ambient Air Quality Standard (Revised), 

AQPSTR 11-06, Illinois EPA, September 15,2011. 

2. Final Maintenance Plan for the Metro-East Ozone Nonattainment Area for the 1997 8-

Hour Ozone National Ambient Air Quality Standard (Revised), AQPSTR 11-05, Tilinois 

EPA, August 18, 2011. 

3. Final Maintenance Plan for the Chicago Nonattainment Area for the 1997 PM2.s National 

Ambient Air Quality Standards (Revised), AQPSTR 11-07, Illinois EPA, August 17, 

2011. 

4. Notice of Public Hearing and Comment Period, July 8, 2011. 

5. Notice of Cancellation of Public Hearing. August 12,2011. 

6. Comments of the Sierra Club, filed August 8, 2011. 

7. Responsiveness Summary, Illinois EPA, September 13, 2011. 

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