REGIONAL HAZE

STATE IMPLEMENTATION PLAN

FOR ILLINOIS

AQPSTR 10-08

May 10, 2011

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 NORTH GRAND AVENUE EAST

P.O. BOX 19276

SPRINGFIELD, ILLINOIS 62794-9276
2

Table of Contents

List of Acronyms........................................................................... 3

List of Figures............................................................................... 4

List of Tables................................................................................ 5

Executive Summary........................................................................ 6

1.0 Introduction........................................................................ 8

2.0 Regional Planning................................................................. 11

3.0 Assessment of Baseline, Current, and Natural Conditions in Class I

Areas.............................................................................. 14

4.0 Monitoring Strategy............................................................ 15

5.0 Emissions Inventory............................................................ 17

6.0 Best Available Retrofit Technology......................................... 19

7.0 Reasonable Progress Goals.................................................... 24

8.0 Long-term Strategy.............................................................. 31

9.0 Consultation...................................................................... 39

10.0 Summary.......................................................................... 48

References................................................................................. 50

Appendix A Draft List of Class I Areas Located Within (or Impacted by) Midwest 

RPO States, Lake Michigan Air Directors Consortium, June 26, 2007

Appendix B Regional Air Quality Analyses for Ozone, PM2.5, and 

Regional Haze: Final Technical Support Document, States of Illinois, 

Indiana, Michigan, Ohio, and Wisconsin, Lake Michigan Air 

Directors Consortium, April 25, 2008

Appendix C Illinois Air Monitoring Network - 2012
3

List of Acronyms

BART Best Available Retrofit Technology

CAA Clean Air Act

CAIR Clean Air Interstate Rule

CO Carbon Monoxide

CPS Combined Pollutant Standard

EGAS Economic Growth Analysis System

EGU Electrical Generating Unit

FGD Flue Gas Desulfurization

IPM Integrated Planning Model

LADCO Lake Michigan Air Directors Consortium

LNB Low NOx Burner

MRPO Midwest Regional Planning Organization

MPS Multi-Pollutant Standards

NH3 Ammonia

NOx Oxides of Nitrogen

OFA Over-Fire Air

PAMS Photochemical Assessment Monitoring Sites

PM Particulate Matter

PM2.5 Particulate Matter 2.5 microns in diameter

PM10 Particulate Matter 10 microns in diameter

PSD Prevention of Significant Deterioration

RPO Regional Planning Organization

SCR Selective Catalytic Reduction

SDA Spray Dryer Absorbers

SIP State Implementation Plan

SLAMS State/Local Air Monitoring Station

SNCR Selective Non-Catalytic Reduction

SO2 Sulfur Dioxide

SPM Special Purpose Monitors

U.S. EPA United States Environmental Protection Agency

VOC Volatile Organic Compounds

VOM Volatile Organic Material
4

List of Figures

Figure 1.1 Mandatory Class I Federal Areas ................................... 9

Figure 2.1 Regional Planning Organizations ...................................11

Figure 2.2 Class I Areas Impacted by Illinois ..................................13

Figure 4.1 Illinois Monitoring Locations .......................................16

Figure 6.1 Estimated NOx Emissions from Coal-Fired EGUs in Illinois... 22

Figure 6.2 Estimated SO2 Emissions from Coal-Fired EGUs in Illinois.....22

Figure 7.1 Reasonable Progress Factors ........................................28

Figure 9.1 Caney Uniform Rate of Progress Glidepath ........................42

Figure 9.2 Upper Buffalo Uniform Rate of Progress Glidepath ..............42

Figure 9.3 Hercules-Glades Uniform Rate of Progress Glidepath ...........43

Figure 9.4 Mingo Uniform Rate of Progress Glidepath .......................43

Figure 9.5 Sipsey Wilderness Uniform Rate of Progress Glidepath .........45

Figure 9.6 Great Smoky Mountains Uniform Rate of Progress Glidepath ..45

Figure 9.7 Mammoth Cave NP Uniform Rate of Progress Glidepath .......46
5

List of Tables

Table 5.1 Illinois Statewide Emissions for 2002 ....................................... 17

Table 5.2 Projected Statewide Emissions for 2018 .....................................18

Table 5.3 Comparison of Illinois Statewide Emissions, 2002 to 2018 ...............18

Table 6.1 List of Sources Subject to BART ............................................. 20

Table 6.2 Summary of 2018 BART Requirements in Illinois for 

Coal-Fired EGUs ................................................................21 

Table 6.3 Presumptive BART Emission Limits for Coal-Fired EGUs ...............21

Table 7.1 Estimated Cost Effectiveness for Potential Control Measures .......26-27

Table 7.2 Comparison between National Control Measures and Illinois’

Measures ..........................................................................30

Table 8.1 Ratios of Emission Rates and Distance (Q/D) for Emission 

Sources in Illinois................................................................33
6

Executive Summary

The Federal Regional Haze Rule was published by the United States Environmental 

Protection Agency (“USEPA”) on July 1, 1999 (64 Fed. Reg. 35714) to address visibility 

impairment in 156 protected parks and wilderness areas. The Clean Air Act (“CAA”) 

identifies these areas as “mandatory Class I Federal areas” (CAA Section 169A(a)(1)). 

Even though there are no Class I areas in Illinois, the Regional Haze Rule requires that 

each state submit a State Implementation Plan (“SIP”) to provide for reasonable progress 

toward improving visibility, with the eventual goal of achieving pristine visibility 

conditions in these protected areas by 2064. The states’ initial strategy must contain 

enforceable emission reduction measures that achieve the reasonable progress goals in 10 

to 15 years, with reassessment and revision of the goals in 2018 and every 10 years 

thereafter. 

The purpose of this document is to describe Illinois’ strategy for meeting the reasonable 

progress goals by 2018 for Class I areas where emission sources in Illinois have been 

shown to cause adverse visibility impacts. Technical analyses conducted by the Midwest 

Regional Planning Organization ("MRPO") and others have shown that sources in Illinois 

are causing or contributing to visibility impairment in several Class I areas in the eastern 

United States, including, but not limited to, Mammoth Cave National Park in Kentucky, 

the Mingo Wilderness Area in Missouri, and Isle Royale National Park in Michigan. 

Illinois is therefore required to submit revisions to its SIP to address the contributions 

made by emission sources located in Illinois. 

To address the Regional Haze Rule requirements, Illinois has developed a long-term 

emission reduction strategy to address visibility impairment in nearby Class I areas. This 

strategy is described in this document. An element of that strategy is the application of 

Best Available Retrofit Technology ("BART") for a specific subset of emission sources, 

as required by USEPA’s Guidelines for BART Determinations under the Regional Haze 

Rule (“BART Guidelines”) (70 Fed. Reg. 39104, July 6, 2005). The IEPA has 

determined that Illinois has 59 emission units located at 11 major emission sources that 
7

are subject to BART. These sources have committed to enforceable emission reduction 

measures that will meet or exceed the BART requirements on or before 2018. 

 

The Federal Regional Haze Rule requires consultation between the states, tribes, and 

Federal Land Managers (“FLMs”) responsible for managing Class I areas. This multistate and multi-agency consultation process has been facilitated by Regional Planning 

Organizations (“RPOs”) established specifically for this purpose. Illinois fully 

participated in the planning and technical development efforts of the Midwest Regional 

Planning Organization, which also includes the States of Indiana, Michigan, Ohio, and 

Wisconsin. States in other parts of the country participated in similar RPOs. Illinois has 

also participated in consultations with other RPOs and states that have requested Illinois’ 

participation in their planning process. 

The IEPA, in conjunction with the MRPO, has made adequate plans to meet the 

requirements of the Regional Haze Rule by performing the necessary modeling to 

determine its impact on visibility in Class I areas, setting goals to reduce the impact of 

Illinois sources on these areas, and achieving the identified emission reduction targets. 

Further, Illinois commits to implement the long-term strategy for meeting Regional Haze 

Rule goals and requirements. Illinois also commits to maintain adequate monitoring 

networks, and will continue to provide required progress reports, emissions inventories,

and future SIP revisions, as required, to meet the requirements of the Regional Haze 

Rule. 
8

1.0 Introduction

The purpose of this document is to describe Illinois’ strategy for meeting the 

requirements established by the Federal Regional Haze Rule, which was published by the 

United States Environmental Protection Agency (“USEPA”) on July 1, 1999 (64 FR 

35714) to address visibility impairment in 156 protected national and state parks and 

wilderness areas. The Clean Air Act (“CAA”) identifies these areas as “mandatory Class 

I Federal areas” (CAA Section 169A(a)(1), 42 USC §7491(a)(1)). The protected Class I 

areas are shown in Figure 1.1. As illustrated in Figure 1.1, there are no Class I areas in 

Illinois. However, the Regional Haze Rule requires that all states submit State 

Implementation Plans (“SIP”) to provide for reasonable progress toward improving 

visibility, with the eventual goal of achieving pristine visibility conditions in these 

protected areas by 2064. The states’ initial strategy must contain enforceable emission 

reduction measures that achieve the reasonable progress goals in 10 to 15 years, with 

reassessment and revision of the goals in 2018 and every 10 years thereafter. As 

specified in 40 CFR §51.308(f), Illinois commits to revise and submit its SIP by July 31, 

2018, and every ten years thereafter consistent with the national goal of continued 

improvement of visibility in these protected areas.

Specifically, the Regional Haze Rule provides several general planning provisions that 

states must address in the SIPs. Pursuant to 40 CFR §51.308, these requirements include: 

(1) setting reasonable progress goals; (2) calculating baseline and natural visibility 

conditions; (3) providing a long-term strategy for regional haze; (4) submitting a plan for 

the application of Best Available Retrofit Technology ("BART") for a specific subset of 

emission sources, as required by USEPA’s Guidelines for BART Determinations under 

the Regional Haze Rule (“BART Guidelines”) (70 FR 39104, July 6, 2005); and (5) 

providing a monitoring strategy and other implementation plan requirements.

The Illinois Environmental Protection Agency (“IEPA”), in conjunction with the 

Midwest Regional Planning Organization ("MRPO"), has made adequate plans to meet 

the requirements of the Regional Haze Rule by performing the necessary modeling to 

determine its impact on visibility in Class I areas, setting goals to reduce the impact of 
9

Illinois sources on these areas, and achieving the identified emission reduction targets. 

Illinois commits to implement the long-term strategy for meeting Regional Haze Rule 

Figure 1.1 Mandatory Class I Federal Areas

progress goals and requirements. Illinois has developed a long-term emission reduction 

strategy to address the requirements of the Regional Haze Rule, including the application 

of BART for a specific subset of emission sources in Illinois. Illinois will continue in its 

efforts to maintain monitoring networks and emissions inventories, and will continue to 

provide required progress reports and future SIP revisions for the Regional Haze Rule. 

The Federal Regional Haze Rule also requires consultation between the states, tribes, and 

Federal Land Managers (“FLMs”) responsible for managing Class I areas. This multistate and multi-agency consultation process has been facilitated by Regional Planning 

Organizations (“RPOs”) established specifically for this purpose. Illinois fully 
10

participated in the planning and technical development efforts of the MRPO, which also 

includes the States of Indiana, Michigan, Ohio, and Wisconsin. States in other parts of 

the country participated in similar regional planning organizations. Illinois has also 

participated in consultations with other RPOs and states that have requested Illinois’ 

participation in their planning process. 

Finally, 40 CFR §51.308(g) requires that each state submit a report to USEPA every five

years evaluating progress towards the reasonable progress goal for each mandatory Class 

I area which may be affected by emissions from within the state. The first progress 

report is due five years from submittal of the initial implementation plan addressing 

regional haze and BART. 40 CFR §51.308(h) also requires that at the same time the state 

is required to submit its five-year progress report to USEPA the state must either provide 

to the USEPA a negative declaration that further revision of the existing implementation 

plan is not needed, or revise its implementation plan to address the plan’s deficiencies 

within one year. Illinois commits that it will submit the progress report evaluating the 

adequacy of the state’s plan, as specified in 51.308(g) and (h), within five years, revise its 

SIP as needed, and will continue the consultation process with other states and FLMs in 

the development of the progress evaluation.
11

2.0 Regional Planning

The State of Illinois is a member of the MRPO, and has fully participated in the MRPO’s 

planning, analysis, and consultation efforts. In addition to Illinois, the MRPO includes 

the States of Indiana, Michigan, Ohio, and Wisconsin, and is one of five regional 

planning organizations funded by the USEPA to address regional haze requirements. 

Figure 2.1 - The Regional Planning Organizations 

The analyses conducted by the MRPO included preparation of regional emissions 

inventories, meteorological data, evaluation and application of regional chemical 

transport models, and collection and analysis of ambient monitoring data.

One of the analyses prepared by the MRPO identified the Class I areas that were 

impacted by each of the states in the MRPO. Using several technical approaches, 

including modeling and back trajectories, the MRPO prepared a list of Class I areas 

impacted by the five Midwestern states. This analysis, “Draft List of Class I Areas 

Located Within (or Impacted by) Midwest RPO States” (June 26, 2007), is included as 
12

Appendix A. According to the MRPO analyses, sources in Illinois are causing or 

contributing to visibility impairment in several Class I areas in the eastern United States, 

including Mammoth Cave National Park in Kentucky, the Mingo Wilderness Area in 

Missouri, and Isle Royale National Park in Michigan. These areas are listed below and 

are shown in Figure 2.2:

Sipsey Wilderness Area, Alabama

Caney Creek Wilderness Area, Arkansas

Upper Buffalo Wilderness Area, Arkansas

Mammoth Cave National Park, Kentucky

Acadia National Park, Maine

Moosehorn Wilderness Area, Maine

Isle Royale National Park, Michigan

Seney Wilderness Area, Michigan

Boundary Waters Canoe Area Wilderness, Minnesota

Voyageurs National Park, Minnesota

Hercules-Glades Wilderness Area, Missouri

Mingo Wilderness Area, Missouri

Great Gulf Wilderness Area, New Hampshire

Brigantine Wilderness Area, New Jersey

Great Smoky Mountains National Park, Tennessee and North Carolina

Lye Brook Wilderness, Vermont

James River Face Wilderness Area, Virginia

Shenandoah National Park, Virginia

Dolly Sods/Otter Creek Wilderness, West Virginia

Illinois is relying on the MRPO’s technical support document, “Regional Air Quality 

Analysis for Ozone, PM2.5, and Regional Haze: Final Technical Support Document”

(“MRPO TSD”), to address a number of the above-mentioned requirements of the 

Regional Haze Rule. The MRPO TSD is included as Appendix B to this document.
13

Figure 2.2 Class I Areas Impacted by Illinois

Class I areas that are in the southern Appalachians, particularly Cohotta, Shining Rock, 

and Joyce Kilmer/Slickrock, are such a great distance from Illinois that IEPA did not 

model them explicitly. Rather, IEPA modeled the Class I areas closer to Illinois, such as 

Sipsy Wilderness, Linville Gorge, and Great Smoky Mountains National Park, and 

assumed that impacts at these areas were conservatively representative of impacts at areas

that are farther from Illinois. This is consistent with the MRPO analysis, which used 

analyses from other RPOs, as well as their own analyses, to assess the impacts from 

sources in the Midwest on all Class I areas in the eastern U.S.
14

3.0 Assessment of Baseline, Current, and Natural Conditions in Class I Areas

To track progress toward the long-term goal of remedying impairment of visibility in 

mandatory Class I areas, the Regional Haze Rule requires states containing such Class I 

areas to establish baseline conditions representing visibility for the best and worst days at 

the time the regional haze program is initiated for each Class I area. The baseline 

represents the starting point from which reasonable progress is measured. Using 

available monitoring data from 2000 through 2004, states with Class I areas are to 

determine the average visibility for the 20% most impaired days, and for the 20% least 

impaired days. These values represent the baseline conditions for the worst and best 

days. Natural conditions are also determined based on the level of visibility on the least 

impaired days. 

Since there are no Federal Class I areas located in Illinois, the state is not required to 

determine and submit baseline, current and natural conditions for any Class I areas. 

Illinois has participated, however, in the efforts of the MRPO to perform such analyses 

for Class I areas located in other MRPO states. A detailed description of these analyses 

can be found in Section 3.0 of the MRPO TSD (see Appendix B).
15

4.0 Monitoring Strategy

Pursuant to 40 CFR §51.308(d)(4) of the Federal Regional Haze Rule, Illinois currently 

maintains a monitoring network to measure and report levels of various pollutants, 

including those that contribute to impairment of visibility in Class I areas. The

monitoring program relies upon Illinois’ network of monitoring sites that include 

SLAMS (State and Local Air Monitoring Sites), SPM (Special Purpose Monitors), PM2.5

speciation sites (trend and State), and PAMS (Photochemical Assessment Monitoring 

Sites). Since there are no Class I areas located in the state, Illinois does not operate any 

monitoring sites under the Federal IMPROVE (Interagency Monitoring of Protected 

Visual Environments) program. However, the Illinois State Water Survey operates a 

monitoring site at Bondville, which is a rural location near Champaign in central Illinois, 

that conforms with the IMPROVE protocol. 

Figure 4.1 illustrates Illinois’ ambient monitoring network. Specific site information, 

including the pollutants measured, site locations (address and latitude/longitude), and the 

sampling schedule are included as Appendix C.

Illinois is required, pursuant to 40 CFR §51.308(d)(4)(iii), to establish procedures for using 

monitoring data, along with other information, to determine the contribution of emissions from 

Illinois sources to visibility impairment at all affected Class I areas outside of the state. These 

procedures were established in conjunction with the MRPO and are discussed in detail in Sections 

3.0 and 4.0 of the MRPO TSD (see Appendix B).

The monitoring network in Illinois will be maintained and will continue to measure 

pollutants that contribute to visibility degradation. In addition, Illinois will continue to 

determine its contribution to visibility impairment in mandatory Class I Federal areas, 

and to assess whether reasonable progress goals addressing regional haze are being 

achieved.
16

Figure 4.1 Ambient Air Monitoring Locations in Illinois
17

5.0 Emissions Inventory

Pursuant to 40 CFR §51.308(d)(4)(v), Illinois is required to provide a statewide inventory 

of pollutants that could reasonably be anticipated to cause or contribute to visibility 

impairment in Class I areas. These pollutants include volatile organic compounds 

("VOCs"), NOx (“nitrogen oxides”), PM (“particulate matter”), ammonia ("NH3"), and 

SO2 (sulfur dioxide). Table 5.1 is a summary of statewide emissions of the relevant 

pollutants from each emission source category based on the "Illinois Particulate Matter 

and Haze Inventory for 2002”.

3

 Note that point source emissions are separated into 

those from electric generating units (“EGUs”), and other non-EGU point sources.

Table 5.1 Illinois Statewide Emissions for 2002

Category CO NH3 NOx PM10 PM2.5 SO2 VOM

EGU

Non-EGU 

16,7968

75,042

99

521

182,377

84,944

9,027

27,546

4,637

6,751

369,082

138,015

1,666

75,002

Area 94,116 29,905 47,435 507,268 113,102 5,264 222,390

On-Road 2,165,756 10,773 309,868 7,854 5,760 8,934 143,495

Off-Road 884,602 108 209,361 13,334 12,295 9,304 92,609

Animal --- 44,180 --- --- --- --- ---

Biogenic 79,459 --- 38,772 --- --- --- 528,583

Total 3,315,774 85,590 872,760 565,031 142,548 530,600 1,063,747

The 2018 emission projections are listed in Table 5.2. Statewide emissions for 2002 were 

used to project 2018 emissions for the same categories using the Economic Growth 

Analysis System ("EGAS"). The projected emissions from EGUs reflect the 

implementation of Illinois Multi-Pollutant Standards (“MPS”), Combined Pollutant 

Standard (“CPS”), and agreements to implement BART. Table 5.3 provides a 

comparison of 2002 and 2018 statewide emissions for the same pollutants and emission 

categories.

From Table 5.3, it is expected that emissions of NH3 and PM (both PM10 and PM2.5) will 

increase from 2002 to 2018 due largely to increases in area source emissions of these 

pollutants. These increases are offset, however, by substantial decreases of the primary 

visibility impairing pollutants, SO2 and NOx, expected in Illinois by 2018. These 
18

Table 5.2 Projected Illinois Statewide Emissions for 2018

Category CO NH3 NOx PM10 PM2.5 SO2 VOM

EGU

Non-EGU

24,620

94,570

100

568

34,085

76,326

11,313

36,737

4,698

7,916

122,907

129,014

1,926

98,822

Area 106,716 42,958 54,162 744,042 162,256 5,968 230,151

On-road 1,000,229 11,757 61,019 3,686 1,820 1,155 41,882

Off-road 970,732 810 188,997 8,927 8,260 9,612 74,083

Animal --- 63,211 --- --- --- --- ---

Biogenic 79,459 --- 38,772 --- --- --- 528,583

Total 2,276,326 119,404 453,361 804,705 184,950 268,656 975,447

Table 5.3 Comparison of Illinois Statewide Emissions, 2002 to 2018

Category CO NH3 NOx PM10 PM2.5 SO2 VOM

2002 3,315,774 85,590 872,760 565,031 142,548 530,600 1,063,747

2018 2,276,326 119,404 453,361 804,705 184,950 268,656 975,447

Difference -1,039,448 +33,814 -419,399 +239,674 +42,402 -261,944 -88,300

reductions are largely due to Illinois’ MPS/CPS and BART regulatory requirements 

affecting coal-fired EGUs, as well as significant reductions from on-road and off-road 

mobile sources. Illinois’ regulatory programs for EGUs are more stringent than the 

Federal Clean Air Interstate Rule (“CAIR”), and do not rely on the CAIR interstate 

trading program. This ensures that Illinois will achieve its long-term strategy needed to 

meet the Reasonable Progress Goals established for eastern and midwestern Class I areas 

regardless of the outcome of litigation affecting CAIR. The Reasonable Progress Goals 

and Illinois’ Long-term Strategy are discussed in Sections 7.0 and 8.0.

Pursuant to 40 CFR §51.308(d)(4)(v), the IEPA commits to update the statewide 

emissions inventory periodically to ensure continued progress in meeting the visibility 

goals described in the document.
19

6.0 Best Available Retrofit Technology

The Regional Haze Rule requires stationary emission units that were constructed from 

1962 to 1977 that have not been subject to other provisions of the CAA to install and 

operate BART on those units, or implement another program that achieves greater 

visibility improvements. USEPA’s BART Guidelines1describe how BART 

determinations are made with regard to the cost of retrofit technology, the remaining 

useful life of an emission unit, alternative emission reduction strategies, and other factors 

to be considered in making BART determinations. 

Illinois has followed the BART Guidelines in meeting the requirements for emission 

sources subject to BART, as described in the IEPA’s report: “Technical Support 

Document for Best Available Retrofit Technology Under the Regional Haze Rule”

2

(“BART TSD”). The BART TSD describes the IEPA’s methodologies for determining 

BART-eligible sources, for modeling the visibility impacts of eligible sources, and for 

meeting the BART control requirements. 

Table 6.1 lists the 11 sources in Illinois that are subject to BART. Of the 11 sources, nine 

are EGUs and two are non-EGU sources. The two non-EGUs are petroleum refineries 

located near Chicago (CITGO and ExxonMobil). The nine power generation sources are 

spread geographically across Illinois. Table 6.1 provides a list of the sources in Illinois 

that are subject to BART.

To meet the BART emission reduction requirements for EGUs, Illinois is relying on the 

MPS/CPS requirements affecting all emission units at sources operated by Midwest 

Generation, Ameren, and Dynegy; and specific BART-related provisions to be included 

in federally enforceable permits for Dominion-Kincaid and the City of Springfield, Office 

of Public Utilities d/b/a City Water, Light, and Power (“CWLP”). The existing emission 

reduction requirements and commitments for coal-fired EGUs in Illinois that are subjectto-BART include: 
20

the Multi-Pollutant Standards (“MPS”) and Combined Pollutant Standard (“CPS”) 

codified in the Illinois Mercury Rule, 35 Ill. Adm. Code Part 225, that apply to 

Ameren, Dynegy, and Midwest Generation; 

a multi-pollutant agreement between the IEPA and Dominion Energy Services, as 

operator, and Kincaid Generation, LLC, as owner, of the Kincaid Generating 

Station (collectively “Dominion Kincaid”), to achieve BART-control levels; and

a similar agreement between the IEPA and the City of Springfield, Office of 

Public Utilities, d/b/a CWLP, to achieve BART-control levels and to shut down 

one of its existing subject-to-BART units.

Table 6.1 List of Sources Subject to BART

Source Name County Source ID Category

CITGO Petroleum Corp Will 197090AAI 11

Exxon Mobil Oil Corp Will 197800AAA 11

Dynegy Baldwin Randolph 157851AAA 1

Dominion Kincaid Christian 021814AAB 1

Ameren Coffeen Montgomery 135803AAA 1

Ameren Edwards Peoria 143805AAG 1

Ameren Duck Creek Fulton 057801AAA 1

Midwest Generation Powerton Tazewell 179801AAA 1

Midwest Generation Joliet Will 197809AAO 1

Midwest Generation Will County Will 197810AAK 1

Springfield CWLP Sangamon 167120AAO 1

Table 6.2 summarizes the BART requirements for coal-fired EGUs in Illinois for 2018, 

the progress-related milestone year under the Regional Haze Rule. It should be noted 

that NOx and SO2 reduction requirements will be phased in beginning in 2009 through 

2019. IEPA’s BART TSD provides a more detailed description of these requirements.

The BART Guidelines provide presumptive emission limits or control levels for coalfired EGUs, for various boiler types and coal types. The presumptive emission limits for 

coal-fired EGUs are shown in Table 6.3. The IEPA has compared these presumptive 

BART emission levels to existing emission reduction requirements and commitments for 
21

the subject-to-BART EGUs in Illinois. For coal-fired EGUs in Illinois, the system-wide 

emission limits required by the MPS/CPS for 

Table 6.2 Summary of 2018 BART Requirements in Illinois 

for Coal-Fired EGUs

Source Name

NOx Emission Rate 

(lb/mmBTU)

SO2 Emission Rate 

(lb/mmBTU)

2002 Base BART 2002 Base BART

Dynegy a0.32 0.10 0.63 0.19

Ameren a0.29 0.11 1.10 0.23

Midwest Generation a,b 0.36 0.11 0.52 0.13 

City Water, Light and Power 1.08 0.11 1.09 0.23

Dominion Kincaid 0.65 0.07 0.55 0.15

a 

Sources affected by MPS/CPS required to meet emission rates on a system-wide basis.

b

 Midwest Generation is required to meet a system-wide SO2 average emission rate 0.13 lb/mmBTU by 2018 and 0.11 lb/mmBTU by 

2019.

Table 6.3 Presumptive BART Emission Limits for Coal-Fired EGUs

Pollutant Boiler Type Coal Type Presumptive Limit 

(lbs/mmBTU)

SO2 All units All coal types 0.15 

(or 95% control)

NOx Dry-bottom wall-fired Bituminous 0.39

Sub-bituminous 0.23

Lignite 0.29

Tangential-fired Bituminous 0.28

Sub-bituminous 0.15

Lignite 0.17

Cell burners Bituminous 0.40

Sub-bituminous 0.45

Dry-turbo-fired Bituminous 0.32

Sub-bituminous 0.23

Wet-bottom tangentialfiredAll 0.62

Cyclone All 0.10

Midwest Generation, Ameren, and Dynegy, and the specific BART-related provisions for 

Dominion-Kincaid and the City of Springfield, Office of Public Utilities, d/b/a CWLP 

either meet or exceed the requirements for BART. As shown in Figures 6.1 and 6.2, 

Illinois’ requirements will provide significantly greater emission reductions for NOx and 
22

SO2 than will installation of BART controls on just the subject-to-BART emission units, 

and will provide greater emission reductions than implementation of CAIR.

Figure 6.1 Estimated NOx Emissions from Coal-Fired EGUs in Illinois

Figure 6.2 Estimated SO2 Emissions from Coal-Fired EGUs in Illinois

The two non-utility sources that have emission units that are subject to BART are both 

petroleum refineries located in the Chicago area. These sources are the CITGO refinery 

at Lemont and the ExxonMobil refinery at Joliet. To meet the BART emission reduction 

requirements, Illinois is relying on federal consent decrees affecting both sources. Both 

0

10,000

20,000

30,000

40,000

50,000

60,000

MWGen Ameren DynegyDominion CWLP

NOx Emissions (tons per 

year) 

2002 Base 

Year

Presumptive 

BART

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

160,000

180,000

MWGen Ameren DynegyDominion CWLP

SO2 Emissions (tons per year )

2002 Base 

Year

Presumptive 

BART
23

refineries have been the subject of litigation by USEPA that has resulted in legal 

settlements as set forth in consent decrees. The consent decrees establish federally 

enforceable emission limits for these sources that have resulted, or will result, in 

significant reductions in SO2 and NOx emissions. The IEPA considers the requirements 

of these consent decrees to be sufficient to meet the requirements for BART. IEPA’s 

BART TSD provides a more detailed description of these requirements.
24

7.0 Reasonable Progress Goals

The Regional Haze Rule does not establish presumptive targets for showing reasonable 

progress goals for Class I areas. Rather, the rule allows states the flexibility to determine 

reasonable progress goals for Class I areas that improve visibility on the most impaired 

days and ensure that no degradation occurs on the clearest days. The reasonable progress 

goals are intended as interim goals that represent incremental progress toward the 

national goal of mitigating all man-made visibility impairment. The national goal of no 

man-made impairment is intended to encompass several planning periods of 10 years 

duration. The first planning period spans from the beginning of the regional haze 

program until the year 2018.

Since there are no Class I areas located in Illinois, the IEPA is not required to prepare and 

submit any analyses regarding the establishment of reasonable progress goals for any 

Class I areas. Illinois has participated in the efforts of the MRPO to perform such 

analyses for Class I areas located in other MRPO states. A detailed description of these 

analyses can be found in Section 5.0 of the MRPO TSD (see Appendix B). A summary 

of the MRPO’s findings is provided below.

Section 169A(g) of the CAA states that “...in determining reasonable progress there shall 

be taken into consideration the costs of compliance, the time necessary for compliance, 

and the energy and nonair quality environmental impacts of compliance, and the 

remaining useful life of any existing source subject to such requirements”. 42 USC 

§7491(g). Federal regulations also include visibility improvements as they relate to the 

Uniform Rate of Progress. 40 CFR §51.308(d)(1)(i)(A). The MRPO conducted analyses 

to determine reasonable progress based upon these five factors and determined that the 

implementation of the Clean Air Interstate Rule (“CAIR”) would be sufficient for the 

region to achieve reasonable progress toward the visibility goals of the Regional Haze 

Rule and CAIR. These analyses were based on reductions that would be achieved by 

2018 with the implementation of CAIR Phase I and Phase II by that time. The

assessment of the five factors was performed for the MRPO and the State of Minnesota 

by EC/R Incorporated (“EC/R”), as documented in their report, “Reasonable Progress for 
25

Class I Areas in the Northern Midwest” 4. Specifically, EC/R examined reductions in 

SO2 and NOx emissions from EGUs and industrial, commercial and institutional (ICI) 

boilers; NOx emissions from mobile sources and reciprocating engines and turbines; and 

ammonia emissions from agricultural operations. The impacts of “on the books” controls 

were also examined to provide a frame of reference for assessing the impacts of the 

additional control measures.

The results of EC/R’s analysis of the five factors are summarized below:

Factor 1 (Costs of Compliance): The average cost effectiveness values (in terms of $M 

per ton) are provided in Table 7.1. Two control levels were considered for EGUs (EGU1 

and EGU2) and for industrial, commercial, and industrial (“ICI”) boilers (ICI-1 and “ICI 

Workgroup”). For comparison, cost-effectiveness estimates previously provided for “on 

the books” controls include:

CAIR SO2: $700 - $1,200, NOx: $1,400 – $2.600 ($/T)

BART SO2: $300 - $963, NOx: $248 - $1,770

MACT SO2: $1,500, NOx: $7,600

Most of the cost-effectiveness values for the additional controls are within the range of 

cost-effectiveness values for “on the books” controls.

Factor 2 (Time Necessary for Compliance): All of the control measures can be 

implemented by 2018. Thus, this factor can be easily addressed.

Factor 3 (Energy and NonAir Quality Environmental Impacts): The energy and other 

environmental impacts are believed to be manageable. For example, the increased energy 

demand from add-on control equipment is less than 1% of the total electricity and steam

production in the region, and solid waste disposal and wastewater treatment costs are less 

than 5% of the total operating costs of the pollution control equipment. It should also be 

noted that the SO2 and NOx controls would have beneficial environmental impacts (e.g., 

reduced acid deposition and nitrogen deposition).
26

Table 7.1 Estimated Cost Effectiveness for Potential Control Measures

Emission category Control strategy Region

Average Cost Effectiveness ($/ton)

SO2 NOx NH3

EGU EGU1 3-State 1,540 2,037

9-State 1,743 1,782

EGU2 3-State 1,775 3,016

9-State 1,952 2,984

ICI boilers ICI1 3-State 2,992 2,537

9-State 2,275 1,899

ICI Workgroup 3-State 2,731 3,814

9-State 2,743 2,311

Reciprocating 

engines and turbines

Reciprocating engines 

emitting 100 tons/year or 

more

3-State 538

9-State 506

Turbines emitting 100 

tons/year or more

3-State 754

9-State 754

Reciprocating engines 

emitting 10 tons/year or 

more

3-State 1,286

9-State 1,023

Turbines emitting 10 

tons/year or more

3-State 800

9-State 819

Agricultural sources

10% reduction 3-State

31 -

2,700

9-State

31 -

2,700

15% reduction 3-State

31 -

2,700

9-State

31 -

2,700

Mobile sources Low-NOx Reflash 3-State 241

9-State 241

MCDI 3-State 10,697

9-State 2,408

Anti-Idling 3-State

(430) -

1,700

9-State

(430) -

1,700

Cetane Additive Program 3-State 4,119

9-State 4,119

Cement Plants Process Modification Michigan -

Conversion to dry kiln Michigan 9,848

LoToxTM Michigan 1,399

Glass Manufacturing LNB Wisconsin 1,041

Oxy-firing Wisconsin 2,833

Electric boost Wisconsin 3,426

SCR Wisconsin 1,054

SNCR Wisconsin 1,094
27

Table 7.1 Estimated Cost Effectiveness for Potential Control Measures (continued)

Emission category Control strategy Region

Average Cost Effectiveness ($/ton)

SO2 NOx NH3

Lime Manufacturing Mid-kiln firing Wisconsin 688

LNB Wisconsin 837

SNCR Wisconsin 1,210

SCR Wisconsin 5,037

FGD Wisconsin 128 - 4,828

Oil Refinery LNB Wisconsin 3,288

SNCR Wisconsin 4,260

SCR Wisconsin 17,997

LNB+FGR Wisconsin 4,768

ULNB Wisconsin 2,242

FGD Wisconsin 1,078

Factor 4 (Remaining Useful Life): It is not expected that the controls will be applied to 

units that will be retired prior to the amortization period for the control equipment. Thus, 

this factor can be easily addressed.

Factor 5 (Visibility Impacts): The estimated incremental improvement in 2018 visibility 

levels for the additional measures is shown in Figure 7.1, along with the costeffectiveness expressed in millions of dollars per deciview ($M/dv) improvement. 

Strategy 1 and Strategy 2, as shown in the figure, refer to the two control levels evaluated 

for EGUs and ICI boilers. These results show that although EGU and ICI boiler controls 

have higher cost-per-deciview values (compared to some of the other measures), the

potential for visibility improvements from these categories is also greater. However, the 

potential visibility improvements are small for all categories except for EGUs, and the 

EGU controls in Illinois exceed those required by either CAIR or the proposed Transport 

Rule (75 Fed. Reg. 45210 (August 2, 2010)).
28

Figure 7.1 Results of EC/R Analysis of Reasonable Progress Factors

Visibility Improvement (dv)

0.00

0.25

0.50

0.75

1.00

SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3 SO2 NOx NH3

Strategy 1 Strategy 2

EGUs ICI Boilers Rec.Eng. Mobile Ag

Cost Effectiveness ($M/dv)

0

1000

2000

3000

4000

5000

6000

SO2 NOx NH3 SO2NOx NH3 SO2 NOx NH3 SO2 NOxNH3 SO2 NOx NH3

Strategy 1 Strategy 2

EGUs ICI Boilers Rec.Eng. Mobile Ag
29

Subsequent to these analyses, the Federal CAIR rule has been remanded and USEPA has 

proposed Federal Implementation Plans to Reduce Interstate Transport of Fine Particulate

Matter and Ozone (“Transport Rule”) (75 Fed. Reg.45210 (August 2, 2010)). The IEPA

considers the emission reductions that were anticipated from CAIR Phase II to be 

Illinois’ “fair share” of reductions for achieving the progress goals set by the MRPO. 

Table 7.2 shows the EGU emission rates resulting from CAIR Phase II and the proposed 

Transport Rule Phase II for several Midwestern states, including Illinois. Also shown in 

Table 7.2 are the average emission rates expected from EGUs in Illinois as a result of the 

multi-pollutant control measures, including the MPS/CPS and agreements to meet BART 

requirements, which will be in place by 2018. As shown in the table, the emission limits 

on EGUs in Illinois are more stringent than CAIR Phase II and the Proposed Transport 

Rule Phase II, and are lower than the emission rates to be achieved from these programs 

in all other Midwestern states. If other Midwestern states were to achieve emission 

reductions comparable to those anticipated in Illinois, the region would likely exceed the

progress goals identified by the MRPO. 

Similar to the MRPO, the Mid-Atlantic/Northeast Visibility Union (“MANE-VU”) and 

Visibility Improvement State and Tribal Association of the Southeast (“VISTAS”) RPOs 

performed modeling to evaluate rate of progress goals at eastern Class I areas. In a 

stakeholder briefing in April 2008, MANE-VU concluded from their modeling that 

“...the Uniform Rate is achieved and exceeded at all MANE-VU Class I sites.” 9In the 

VISTAS Technical Support Document,

8 which was prepared to support their states’ 

regional haze SIPs, the 2018 modeling results (without international effects) shows that 

all VISTAS Class I areas show visibility improvements greater than the Uniform Rate of 

Progress. Both the MANE-VU and VISTAS studies assume CAIR control levels for 

EGUs in Illinois.
30

Table 7.2 Projected SO2 and NOx Emission Rates from National Control 

Programs for EGUs in Several Midwestern States

*The projected average SO2 emission rate in Illinois in 2018 is 0.19 lb/MMBTU and the 

projected NOx emission rate is 0.10 lb/MMBTU

State

SO2 Emission Rate

(lb/MMBTU)

NOx Emission Rate

(lb/MMBTU)

CAIR

Phase II

Proposed Transport 

Rule 

Phase II

CAIR

Phase II

Proposed Transport 

Rule 

Phase II

Wisconsin 0.25 0.27 0.14 0.18

Ohio 0.36 0.27 0.14 0.15

Missouri 0.24 0.39 0.13 0.14

Minnesota 0.18 0.24 0.14 0.21

Michigan 0.33 0.40 0.14 0.17

Kentucky 0.27 0.23 0.14 0.15

Indiana 0.28 0.31 0.14 0.18

Illinois* 0.26 0.28 0.12 0.10

Iowa 0.21 0.40 0.13 0.21
31

8.0 Long-Term Strategy

Pursuant to 40 CFR §51.308(d)(3), Illinois is required to submit a long-term strategy

addressing Regional Haze Rule requirements for visibility improvement for the Federal 

Class I areas impacted by Illinois sources. The long-term strategy is the compilation of 

enforceable emissions control measures needed to achieve the reasonable progress goals 

established for these Class I areas. As required, the Illinois plan details the emission 

control measures that Illinois is implementing, including measures to comply with 

BART, to achieve the reasonable progress goals established for Class I areas impacted by 

emissions sources located in Illinois.

The Regional Haze Rule also requires under 40 CFR §51.308(d)(3)(iv) that states identify 

all major and minor anthropogenic (stationary, mobile, and area) sources of visibility 

impairment that were considered by the state in preparing its long-term strategy. IEPA’s 

emissions inventory is described in Section 5.0 of this report and in Section 3.6 of the 

MRPO TSD (see Appendix B). Additionally, the Regional Haze Rule (40 CFR

§51.308(d)(3)(v)) requires that states consider the following factors in developing their

long-term strategy:

Emission reductions due to ongoing air pollution control programs, including

measures to address reasonably attributable visibility impairment;

Measures to mitigate the impacts of construction activities;

Emissions limitations and schedules for compliance to achieve the reasonable

progress goal;

Source retirement and replacement schedules;

Smoke management techniques for agricultural and forestry management

purposes including plans as currently exist within the State for these purposes;

Enforceability of emissions limitations and control measures; and

The anticipated net effect on visibility due to projected changes in point, area, and

mobile source emissions over the period addressed by the long-term strategy.

Illinois has considered each of these factors in developing its long-term strategy. As 

documented in the MRPO TSD (see Appendix B, Section 3.6), the reasonable progress 
32

goals for the Class I areas in the midwestern and eastern United States will be achieved 

by 2018 from implementation of “on-the-books” control measures in the states 

contributing to visibility impairment. “On-the-books” control measures include a number 

of controls that were modeled by the MRPO for power plants, other point sources, area 

sources, and off-highway and on-highway mobile sources. These control measures have 

already been adopted by USEPA and/or the states, are fully enforceable, and will be in 

place by 2018 (except for fleet turnover of certain mobile source measures).

8.1 Point Source Q/D Analysis

The IEPA has evaluated all SO2 and NOx sources in the state to determine if they could 

potentially affect visibility in Class I Federal areas using a methodology that is consistent 

with the BART Guidelines. The BART Guidelines state, in part:

“Based on our model plant analysis, EPA believes that a State could reasonably 

choose to exempt sources that emit less than 500 tons per year of NOX or SO2 (or 

combined NOx and SO2), as long as they are located more than 50 km from any 

Class I area; and sources that emit less than 1000 tons per year of NOX or SO2 (or 

combined NOx and SO2), as long as they are located more than 100 km away from 

any Class I area.” 1

This USEPA criteria is equivalent to a Q/D of 10, where Q is the emission rate in tons per 

year and D is the distance of the source from the nearest Class I area. Since there are no

Class I areas within 100 kilometers of any emission source in Illinois, the IEPA evaluated 

all sources with combined NOx and SO2 emissions greater than 1000 TPY. 

Table 8.1 lists the sources in Illinois that have combined NOx and SO2 emissions 

exceeding 1000 TPY that were not previously evaluated in the subject-to-BART analysis.

Also listed is the distance from each source to the nearest Class I area, and the Q/D ratio 

for each source.
33

Table 8.1 Ratios of Emission Rates and Distance (Q/D) for 

Emission Sources in Illinois 

Source Location

SO2 + NOx emissions 

(TPY)

Distance to nearest Class I 

area (km) Q/D (tons/km)

Electric Energy Joppa 31,487 115 274

Corn Products Bedford Park 22,050 523 42

Conoco-Phillips Roxana 17,994 207 87

Aventine Pekin 14,963 400 37

ADM Decatur 14,074 340 41

Southern Illinois Power Marion 11,700 128 91

SUEZ DEGS Tuscola 10,757 350 31

US Steel Granite City 9,718 191 51

ADM Peoria 8,737 414 21

CII Carbon Robinson 5,963 248 24

Tate & Lyle Decatur 5,022 337 15

Lone Star Oglesby 4,469 489 9

Oxbow Calcining Lemont 4,468 529 8

Lafarge Joppa 4,254 115 37

Emerald Materials Henry 4,106 468 9

St Marys Cement Dixon 3,997 546 7

Panhandle Eastern Tuscola 3,688 350 10

PPG Mt Zion 3,163 330 9

Prairie Power Pearl 2,922 278 10

Nat’l Gas Pipeline Hammond 2,475 340 7

Nat’l Gas Pipeline Herscher 2,241 465 4

Nat’l Gas Pipeline Geneseo 1,954 491 4

Marathon Petroleum Robinson 1,902 249 7

Panhandle Eastern Pleasant Hill 1,661 286 6

ADM Quincy 1,627 344 5

Rentech Energy E Dubuque 1,453 562 3

John Deere E Moline 1,414 507 3

Panhandle Eastern Glenarm 1,319 299 4

Trunkline Gas Grand Chain 1,291 117 11

Exolon Hennepin 1,274 486 3

U of Illinois Champaign 1,268 377 3

ANR Pipeline Sandwich 1,183 559 2

Nat’l Gas Pipeline Centralia 1,151 190 6

ANR Pipeline New Windsor 1,144 475 2

Carmeuse Lime Chicago 1,138 525 2

J’Ville Dev. Center Jacksonville 1,103 305 3

Western IL Univ. Macomb 1,087 392 3

St-Gobain Containers Dolton 1,059 533 2

Illinois Cement LaSalle 1,013 493 2
34

Most of the sources in Illinois with combined NOx and SO2 emissions have Q/D ratios 

less than 10, and will therefore not affect visibility significantly in any Class I areas. Of 

the 15 sources that have a Q/D ratio greater than 10, the IEPA believes that they are 

already subject, or will soon be subject to additional control measures that will provide 

additional emissions reductions that will ensure reasonable progress. These measures 

include:

Illinois Multi-Pollutant Standards and Combined Pollutant Standards for EGUs

Phase I and II of the proposed Transport Rule for EGUs

Federal consent decrees for petroleum refineries

National Emission Standards for Hazardous Air Pollutants (NESHAPs) for utility 

boilers

NESHAPs for industrial boilers

NESHAPs for iron and steel

NESHAPs for cement kilns

NESHAPs for combustion turbines at natural gas pipeline station

Reasonably Available Control Technology for NOx sources (“NOx RACT”) in

ozone nonattainment areas

NOx SIP Call requirements for turbines at natural gas pipeline stations

8.2 Prevention of Significant Deterioration

As to the construction of any new major stationary source or the major modification of 

any existing major stationary source, the visibility impacts of such sources will remain 

under the purview of existing requirements under Prevention of Significant Deterioration 

(“PSD”). 40 CFR § 52.21. The IEPA administers the PSD program in Illinois under 

authority provided by Section 9.1 of the Illinois Environmental Protection Act, 415 ILCS 

5/9.1 (2010), and a delegation agreement with USEPA authorizing Illinois to enforce the 

Federal PSD regulations.

 

Under the PSD program, if the emissions from a proposed new stationary source or the 

increase in emissions from a modification to an existing source meet the relevant criteria 

to be considered major, specific requirements apply to the project. These requirements 
35

include a control technology element or installation of Best Available Control 

Technology, an analysis of the air quality impacts of the project, an additional impacts 

analysis, which assesses the impacts of air, ground and water pollution on soils, 

vegetation, and visibility caused by any increase in emissions of any regulated pollutant 

from the source or modification under review, and from associated growth, and public 

participation. Furthermore, there are additional PSD requirements for sources impacting 

Federal Class I Areas, including notification to a Federal Land Manager (“FLM”) of a 

permit application for such a proposed source that may affect a Federal Class I Area that 

includes an analysis of the proposed source’s anticipated impacts on visibility in the 

Class I Area and the consideration of any visibility analysis performed by the FLM that 

demonstrates that such a proposed source may have an adverse impact on visibility in any 

Federal Class I Area. Permitting of new and modified sources in Illinois via the PSD 

process includes review by and input from the FLMs, who are charged with direct 

responsibility for management of Class I Areas and have an affirmative responsibility to 

protect the air quality related values including visibility. Determinations of adverse 

visibility impacts enable Illinois to reduce the impacts of any new and modified sources 

on visibility. Furthermore, in conformity with 40 C.F.R. § 51.307, in conducting such 

reviews, Illinois shall ensure that such sources’ emissions will be consistent with making 

reasonable progress toward the national visibility goal of preventing any future, and 

remedying any existing, impairment of visibility in Class I Areas.

8.3 Important Control Strategies in Illinois

“On-the-Books” Control Measures

Many of the aforementioned control programs, along with many others that affect smaller 

point sources, area, and mobile sources, will reduce emissions of the constituents that 

cause visibility impairment. The chemical constituents that cause the vast majority of 

visibility impairment in the northern Class I area are ammonium sulfate, ammonium 

nitrate, and organic carbon. According to a MRPO analysis of species that comprise the 

PM loading in the northern Class I areas, on the 20% worst visibility days, sulfates 

comprise 35-55%, nitrates 25-30%, and organic carbon 12-22% of the PM loading.

6

 On 

a seasonal basis, sulfate and organic carbon concentrations are generally higher in the 
36

summer, with nitrates having a larger contribution in the winter. Most of the visibility 

impairing particles in these Class I areas are due to emissions that have been transported 

from large urban and industrial areas far removed from these areas. Emission sources in 

these urban/industrial areas are expected to decrease due to various “on the books” 

control programs for on-road and off-road mobile sources, area sources, and industrial 

point sources. Following is a list of “on-the-books” control measures that are expected to 

further reduce visibility impairing pollutants in future years:

On-Road Mobile Sources

Federal Motor Vehicle Emission Control Program, low-sulfur gasoline and 

ultra-low sulfur diesel fuel

Inspection - maintenance programs, including Illinois’ enhanced vehicle 

inspection and maintenance program, Indiana’s vehicle emissions testing 

program, Ohio’s E-check program, and Wisconsin’s vehicle inspection 

program (Note: a special emissions modeling run was done for the 

Cincinnati/Dayton area to reflect the removal of the state’s E-check program 

and inclusion of low RVP gasoline)

Reformulated gasoline, including in Chicago-Gary-Lake County, IL,IN; and 

Milwaukee, Racine, WI

Off-Road Mobile Sources

Federal control programs incorporated into NONROAD model (e.g., nonroad 

diesel rule), plus the evaporative Large Spark Ignition and Recreational 

Vehicle standards

Heavy-duty diesel (2007) engine standard/Low sulfur fuel

Federal railroad/locomotive standards

Federal commercial marine vessel engine standards

Area Sources 

Consumer solvents

Architectural and Industrial Maintenance coatings

Aerosol coatings

Portable fuel containers
37

Electric Generating Units

Illinois Multi-Pollutant Standards and Combined Pollutant Standards for 

EGUs

Title IV (Acid Rain -- Phases I and II)

NOx SIP Call

Clean Air Interstate Rule – Phase I

Other Point Sources

VOC 2-, 4-, 7-, and 10-year Maximum Achievable Control Technology 

(“MACT”) standards

Combustion turbine MACT

Consent decrees (refineries, ethanol plants, and ALCOA)

NOx Reasonably Available Control Technology (“RACT”) in Illinois, 

Wisconsin and Ohio

It should be noted that some of the measures listed above that will yield significant 

additional emission reductions in Illinois that have not been included as “on the books” 

control measures in the MRPO analyses. These include the regulatory compliance 

options, such as the MPS and CPS codified in the Illinois Mercury Rule, which provide 

greater NOx and SO2 reductions than the Federal CAIR, as well as BART controls for the 

Dominion - Kincaid and the CWLP electric generation facilities. These additional 

agreements and emission reductions are discussed in detail in the Illinois BART TSD. 

Construction Activities

In consideration of construction activities and their effect on regional haze, construction 

activities in Illinois are subject to federal non-road standards for construction equipment 

and vehicles. Additionally, a number of large construction projects in Illinois, including 

the current airport expansion at Chicago’s O’Hare International Airport and recent work 

on the Dan Ryan expressway, have been conducted under contract restrictions requiring 

additional measures to mitigate environmental impacts. These measures include the 

following: the use of ultra low-sulfur fuels; idling restrictions for construction vehicles 

and equipment; USEPA-approved controls for off-road diesel equipment; use of newer, 
38

cleaner, and more fuel-efficient engines for equipment; and optimizing earthwork and 

excavation to limit haul trips to the maximum extent possible. IEPA anticipates that 

future construction projects will entail similar environmental considerations, and the 

IEPA will continue to work with other state and federal agencies to ensure that 

environmental impacts are given due consideration in contracting for similar construction 

projects. 

Smoke Management for Prescribed Fires

In consideration of smoke management techniques for conducting prescribed burns for 

ecological management and restoration, the IEPA has worked with land managers in the 

State to prepare the “Illinois Smoke Management Plan”

7

. This plan provides 

recommended approaches for minimizing smoke during prescribed burns. The plan is 

voluntary, and targets controlled ecological burns. The plan does require the 

implementation of best management practices for burns and also requires the use of the 

Air Quality Index to inform the decision to burn. The plan does not explicitly consider 

Class I areas as sensitive receptors, since the distance to the nearest Class I area from any 

point in Illinois is large (at least 100 km) and ecological burns are relatively small and 

short lived. 
39

9.0 Consultation

Illinois is required by the Regional Haze Rule to participate in a consultation process with 

states that have Class I areas that have identified emission sources in Illinois that 

contribute to visibility impairment. Illinois’ SIP submittal must also contain 

documentation of the consultation process.

Illinois has participated in meetings and conference calls with states within the MRPO 

and with the other RPOs outside the Midwest to discuss their assessments of visibility 

conditions, analyses of culpability, and possible measures that could be taken to meet 

visibility goals. The sections later in this document provide that information on a stateby-state basis. 

9.1 Coordination with Federal Land Managers

Title 40 of the Code of Federal Regulations, §51.308(i), requires coordination between 

Illinois and the Federal Land Managers (“FLMs”). Opportunities have been provided by 

the MRPO for FLMs to review and comment on each of the technical documents 

developed by the MRPO and included in this SIP. Illinois has provided agency contacts 

to the FLMs as required. In development of this plan, the FLMs were consulted in 

accordance with the provisions of 40 CFR §51.308(i)(2). 

During the consultation process, the FLMs were given the opportunity to address their

assessments of the impairment of visibility in any Class I areas, to provide 

recommendations on the development of reasonable progress goals, and to provide 

recommendations on the development and implementation of strategies to address 

visibility impairment. 

Illinois has consulted directly with FLMs by email and phone, during periodic MRPO 

calls and meetings, and during discussions with other states and RPOs with Class I areas 

(for example, the MANE-VU meeting August 6, 2007 in Chicago).
40

Illinois provided the FLMs an opportunity for review of the SIP, and in conformity with 

the federal regulations, it was at least 60 days prior to holding the public hearing for the 

SIP. Comments were received from the FLMs on this plan and have been summarized;

the responses are encompassed in the Responsiveness Summary for Public Questions and 

Comments on the State Implementation Plan Submittal to Address Regional Haze.

Illinois will continue to coordinate and consult with the FLMs during the development of 

future progress reports and plan revisions, as well as during the implementation of 

programs having the potential to contribute to visibility impairment in the Class I areas. 

The FLMs will be consulted during the development and review of implementation plan 

revisions and during the review of five-year progress reports.

9.2 Consultation with States with Class I Areas

As a result of the various analyses performed by the MRPO and other RPOs, Illinois was 

invited to participate in consultations with states with Class I areas where sources in 

Illinois were shown to cause or contribute to visibility impairment. These included

Arkansas and Missouri (as part of CENRAP), Kentucky, New Jersey, New Hampshire, 

and Vermont (each individually and together as part of MANE-VU), Minnesota, and 

Michigan. In addition, the MRPO consulted with VISTAS (the southeastern United 

States’ RPO) regarding impacts in a number of Class I areas in the southeastern United 

States.

IEPA assessed each of the Class I areas identified in the MRPO report as being impacted 

by Illinois sources. Information provided by the MRPO, technical documents from the 

other RPOs, and letters received from other states indicating their decisions regarding 

reasonable further progress goals were used to make these assessments.

In determining reasonable progress for regional haze, Section 169A of the Clean Air Act 

and USEPA’s visibility rule requires states to consider these factors in establishing their 

progress goals: costs of compliance; the time necessary for compliance; the energy and 

non-air quality environmental impacts of compliance; the remaining useful life of any 
41

existing source subject to such requirements; and the uniform rate of visibility 

improvement needed to attain natural visibility conditions by 2064.

Since Illinois has no Class I areas, the states with Class I areas took the lead in 

establishing reasonable progress goals. Illinois participated in the discussions and 

provided information to assist in setting the goals. The states developing the plans 

addressed the required factors and developed the uniform rate of progress glide paths.

In the following sections, these analyses are summarized for most of the Class I areas 

impacted by sources in Illinois. 

9.2.1 Voyageurs National Park and Boundary Waters Canoe Area National 

Wilderness Area, MN

Illinois sources have been shown to cause or contribute to visibility impairment in 

Voyageurs National Park and Boundary Waters Canoe Area National Wilderness Area in 

Minnesota. Illinois has participated in consultations with Minnesota and the MRPO in 

the development of the modeling analyses used by Minnesota to develop its reasonable 

progress goals. Minnesota has developed a long-term strategy sufficient to meet its 2018 

reasonable progress goals, and has not requested additional emissions reductions from 

Illinois. 

9.2.2 Caney Creek and Upper Buffalo National Wilderness Areas, AR, and 

Hercules-Glades and Mingo National Wilderness Areas, MO

Illinois sources have been shown to cause or contribute to visibility impairment in the 

Caney Creek and Upper Buffalo National Wilderness Areas in Arkansas and the 

Hercules-Glades and Mingo National Wilderness Areas in Missouri. Illinois was invited 

to participate in the consultation process for these areas, primarily through conference 

phone calls with other participating states. Arkansas and Missouri have both developed 

long-term strategies that meet Rate of Progress Goals by 2018. The results of their 

modeling for these Class I areas, showing improvements that exceed the Uniform Rate of 

Progress glide paths, are shown in Figures 9-1, 9-2, 9-3, and 9-4.

10 CENRAP has
42

concluded that no further reductions are necessary from Illinois and has notified IEPA 

that they consider the consultation process completed. 

Figure 9.1 Caney Uniform Rate of Progress Glide Path

Figure 9.2 Upper Buffalo Uniform Rate of Progress Glide Path

Uniform Rate of Reasonable Progress Glide Path

Caney Creek Wilderness - 20% Data Days

26.36

25.38

22.91

20.45

17.99

15.52

13.06

11.58

21.48

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Uniform Rate of Reasonable Progress Glide Path

Upper Buffalo Wilderness - 20% Data Days

26.27

25.29

22.84

20.39

17.94

15.49

13.04

11.57

21.61

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction
43

Figure 9.3 Hercules-Glades Uniform Rate of Progress Glide Path

Figure 9.4 Mingo Uniform Rate of Progress Glide Path

9.4.4 Isle Royale National Park and Seney National Wilderness Area, MI

Illinois sources have been shown to cause or contribute to visibility impairment in Isle 

Royale National Park and in the Seney National Wilderness Area in Michigan. Illinois 

Uniform Rate of Reasonable Progress Glide Path

Hercules-Glades Wilderness - 20% Data Days

26.75

25.72

23.14

20.57

17.99

15.42

12.84

11.30

22.19

0

5

10

15

20

25

30

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction

Uniform Rate of Reasonable Progress Glide Path

Mingo - 20% Data Days

28.02

26.98

24.37

21.77

19.17

16.56

13.96

12.40

23.21

0

5

10

15

20

25

30

35

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Year

Haziness Index (Deciviews)

Glide Path Natural Condition (Worst Days) Observation Method 1 Prediction
44

and the other Midwestern states participated extensively in the MRPO modeling and data 

analysis efforts for fine particulates, ozone, and haze in these areas. Michigan 

determined that existing and on-the-books controls (those controls scheduled in response 

to regulatory actions within this time period) will be sufficient to meet its reasonable 

progress goals. Michigan has concluded that no further reductions are necessary from 

Illinois. Illinois will continue to work with Michigan through the MRPO to evaluate the 

progress in the Class I areas.

9.4.5 Mammoth Cave NP, KY; Sipsey Wilderness, AL; Great Smoky Mountains 

NP, TN/NC (VISTAS)

The southeastern states represented by VISTAS did not request Illinois’ participation in 

consultations to address visibility impairment in their Class I areas. The MRPO did 

consult with VISTAS in the development of their progress goals. During this process, 

VISTAS produced glide path plots for Sipsey Wilderness in Alabama (Figure 9.5), the 

Great Smoky Mountains National Park in Tennessee and North Carolina (Figure 9.6), and 

Mammoth Cave National Park in Kentucky (Figure 9.7).

8

The glide paths all show that 

on-the-books and on-the-way controls (including CAIR) will be more than sufficient to 

demonstrate reasonable further progress. Because of these results, none of the VISTAS 

states asked Illinois to take further action beyond the emissions reductions assumed in 

their modeling.

9.4.6 Wilderness Area, NH; Brigantine National Wilderness Area, NJ; and Lye 

Brook National Acadia National Park, ME; Moosehorn Wilderness Area, 

ME; Great Gulf Wilderness Area, VT (MANE-VU)

Illinois sources have been shown to cause or contribute to visibility impairment in several 

Class I areas in the Northeastern States represented by MANE-VU. Illinois, along with 

the other MRPO states, participated in consultations with MANE-VU. 

In July 2007, MANE-VU released its “Assessment of Reasonable Progress for Regional 

Haze in MANE-VU Class I Areas - Methodology for Source Selection, Evaluation of 

Control Options, and Four Factor Analysis” 11 that supported requests of states outside 

that area to examine controls for specific types of sources. 
45

Figure 9.5 Sipsey Wilderness Uniform Rate of Progress Glidepath

Figure 9.6 Great Smoky Mountains Uniform Rate of Progress Glidepath

29.03

27.52

24.80

21.78

18.76

15.74

12.72

10.90

26.43

23.53

0 

5 

10 

15 

20 

25 

30 

35 

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Haziness Index (Deciviews)

Year

Uniform Rate of Progress Glide Path

Sipsey - W20% Data Days

Glide Path Natural Condition (Worst Days)

30.28

28.67

25.79

22.59

19.38

16.18

12.97

11.05

26.72

23.50

0 

5 

10 

15 

20 

25 

30 

35 

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Haziness Index (Deciviews)

Year

Uniform Rate of Progress Glide Path

Great Smoky Mountains - W20% Data Days

Glide Path Natural Condition (Worst Days)
46

Figure 9.7 Mammoth Cave NP Uniform Rate of Progress Glidepath

In its “Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Concerning a Request for a Course of Action by States Outside of MANE-VU Toward 

Assuring Reasonable Progress” ( Appendix 3, pages 63 – 64)

12

, MANE-VU suggested 

that several control strategies should be pursued for adoption and implementation, 

including:

Application of Best Available Retrofit Technology

90% (or greater) reduction in SO2 emissions from each of the EGU stacks on 

MANE-VU’s list of 167 stacks (located in 19 states), which reflect those stacks 

determined to be reasonably anticipated to cause or contribute to visibility 

impairment in the MANE-VU Class I areas

28% reduction in non-EGU (point, area, on-road, and off-road) SO2 emissions 

relative to on-the-books, on-the-way 2018 projections

Continued evaluation of other measures, including measures to reduce SO2 and 

NOx emissions from coal-burning facilities and promulgation of new source 

performance standards for wood combustion

31.37

29.68

26.64

23.26

19.87

16.49

13.11

11.08

28.04

25.40

0 

5 

10 

15 

20 

25 

30 

35 

2000 2004 2008 2012 2016 2020 2024 2028 2032 2036 2040 2044 2048 2052 2056 2060 2064

Haziness Index (Deciviews)

Year

Uniform Rate of Progress Glide Path

Mammoth Cave - W20% Data Days

Glide Path Natural Condition (Worst Days)
47

Further reduction in power plant SO2 (and NOx) emissions beyond the current 

Clean Air Interstate Rule program

In "Recent MANE-VU Projections of Visibility for 2018" 9, MANE-VU concluded that 

the Uniform Rate is achieved and exceeded at all MANE-VU Class I sites based on the 

implementation of the above control measures. 

Of the 167 EGU stacks identified by MANE-VU, only one is from a source in Illinois. 

This stack (at Ameren-Coffeen) has an SCR (which will operate year-round) and a wet 

scrubber installed to comply with the MPS. The resulting level of control will satisfy the 

MANE-VU “ask” for this source. Illinois is implementing BART on subject sources, and 

through the on-the-books control measures listed previously in Section 8, Illinois has 

achieved sufficient reductions to satisfy the MANE-VU “ask”.
48

10.0 Summary

This document describes Illinois’ strategy for meeting the requirements established by 

the Federal Regional Haze Rule, which was published by the USEPA on July 1, 1999 (64 

Fed. Reg. 35714) to address visibility impairment in 156 protected Class I areas. Even 

though there are no Class I areas in Illinois, the Regional Haze Rule requires that Illinois 

prepare and submit a SIP to provide for reasonable progress toward improving visibility, 

with the eventual goal of achieving pristine visibility conditions in these protected areas 

by 2064. The states’ initial strategy must contain enforceable emission reduction 

measures that achieve the reasonable progress goals in 10 to 15 years, with reassessment 

and revision of the goals in 2018 and every 10 years thereafter. 

Specifically, the Regional Haze Rule provides several general planning provisions that 

states must address in the SIPs. Pursuant to 40 CFR §51.308, these requirements include: 

(1) setting reasonable progress goals; (2) calculating baseline and natural visibility 

conditions; (3) providing a long-term strategy for regional haze; (4) submitting a plan for 

the application of BART for a specific subset of emission sources; and (5) providing a 

monitoring strategy and other implementation plan requirements.

The IEPA, in conjunction with the MRPO, has made adequate plans to meet the 

requirements of the Regional Haze Rule by performing the necessary modeling to 

determine its impact on visibility in Class I areas, setting goals to reduce the impact of 

Illinois sources on these areas, and achieving the identified emission reduction targets. 

Illinois commits to implement the long-term strategy for meeting Regional Haze Rule 

progress goals and requirements. Illinois has developed a long-term emission reduction 

strategy to address the Regional Haze Rule requirements, including the application of 

BART for a specific subset of emission sources in Illinois. Illinois will continue in its 

efforts to maintain monitoring networks and emissions inventories, and will continue to 

provide required progress reports and future SIP revisions for the Regional Haze Rule. 

The Federal Regional Haze Rule also requires consultation between the states, tribes, and 

FLMs responsible for managing Class I areas. This multi-state and multi-agency 
49

consultation process has been facilitated by the MRPO. Illinois fully participated in the 

planning and technical development efforts of the MRPO, which also includes the States 

of Indiana, Michigan, Ohio, and Wisconsin. States in other parts of the country 

participated in similar regional planning organizations. Illinois has also participated in 

consultations with other RPOs and states that have requested Illinois’ participation in 

their planning process. 
50

References

1. Regional Haze Regulations and Guidelines for Best Available Retrofit 

Technology (BART) Determinations; Final , 69 Fed. Reg. 39104, July 6, 2005.

2. “Technical Support Document for Best Available Retrofit Technology Under the 

Regional Haze Rule”, Illinois Environmental Protection Agency, AQPSTR 09-06, 

April 29, 2011.

3. Illinois Base Year Particulate Matter and Haze Inventory for 2002, Illinois 

Environmental Protection Agency, AQPSTR 06-04, June 2006.

4. “Reasonable Progress for Class I Areas in the Northern Midwest-Factor 

Analysis,” EC/R Incorporated, July 18, 2007.

5. “Establishing Reasonable Progress Goals for the Northern Class I Areas: 

Treatment of Organic Carbon,” LADCO, April 2, 2007. 

6. “Regional Haze in the Upper Midwest: Summary of Technical Information,”

LADCO, February 22, 2008.

7. Illinois Smoke Management Plan, Illinois Environmental Protection Agency, 

AQPSTR 08-05, May 8, 2009.

8. “Technical Support Document for VISTAS Emissions and Air Quality Modeling 

to Support Regional Haze State Implementation Plans (Draft Final Report),”

Environ; November 14, 2007.

9. “Recent MANE-VU Projections of Visibility for 2018”; presented by Gary 

Kleiman, MANE-VU Stakeholder Briefing, April 4, 2008.
51

10. “Technical Support Document for CENRAP Emissions and Air Quality Modeling 

to Support Regional Haze State Implementation Plans (Draft Final Report),”

Environ; September 12, 2007.

11. “Assessment of Reasonable Progress for Regional Haze in MANE-VU Class I 

Areas - Methodology for Source Selection, Evaluation of Control Options, and 

Four Factor Analysis”, MANE-VU, July 2007.

12. “Statement of the Mid-Atlantic/Northeast Visibility Union (MANE-VU) 

Concerning a Request for a Course of Action by States Outside of MANE-VU 

Toward Assuring Reasonable Progress”, MANE-VU, June 20, 2007.
June 26, 2007

Draft List of Class I Areas Located Within 

(or Impacted by) Midwest RPO States

The purpose of this paper is to provide a draft list of Class I areas located within or impacted by 

a Midwest Regional Planning Organization (MRPO) State. A variety of technical analyses were 

considered in developing the draft list, including base year (2002) and future year (2018) 

modeling, back trajectories, and other data analyses. This information shows that every MRPO 

State impacts multiple Class I areas in the eastern U.S.

Regulatory Requirements

EPA’s regional haze rule requires a state to “address regional haze I each mandatory Class I 

Federal area located within the State and in each mandatory Class I Federal area located 

outside the State which may be affected by emissions from within the State.” (40 CFR Part 

51.308(d)) EPA has interpreted this provision as requiring a table identifying each mandatory 

Class I Federal area located within the State and each mandatory Class I Federal area located 

outside the State affected by emissions from within the State (see Draft EPA Checklist for 

Regional Haze SIPs Submitted Under 40 CFR 51.308 - 7/13/06 Staff Draft ).

Discussion

Technical analyses conducted by the RPOs were consulted to obtain information on areas of 

influence and culpability for Class I areas in the eastern U.S.1 A summary of this information is 

provided below and in Table 1.

For the MRPO analyses, a state was assumed to affect visibility impairment in a Class I area if it 

contributes 2% (or more) to total light extinction. This criterion was selected based on a review 

of the back trajectory and modeling results which showed that states contributing 2% (or more) 

make-up about 90-95% of total light extinction, whereas states contributing 5% (or more) makeup only about 75-80% of total light extinction. For the other RPO analyses, deference was 

given to the criteria established by each group to identify contributing states.

(1) MRPO Back Trajectory Analyses

An initial trajectory analysis was conducted using data for 1997-2001 (all sampling days), a start 

height of 200 m, and a 72-hour (3-day) trajectory period (Cite: “Quantifying Transboundary 

Transport of PM2.5: A GIS Analysis”, May 2003, LADCO). By combining trajectory frequencies 

with concentration information, the average contribution to PM2.5 mass and individual PM2.5

species was estimated (which, in turn, was used to estimate the average contribution to light 

extinction). The results for 17 Class I areas in eastern U.S. were examined to identify those

Class I areas where an MRPO state had at least a 2% contribution to total light extinction

(based on all days).

 

1 Back trajectories and modeling conducted by the WRAP indicate that the Midwest RPO States are not 

important contributors to visibility impairment due to sulfates and nitrates in western Class I areas (Cite: 

“Attribution of Haze Phase I Report, Geographic Attribution for the Implementation of the Regional Haze 

Rule”, March 14, 2005). The analyses show only five groups of western Class I areas with at least 5% 

contribution from states outside the WRAP. The outside-WRAP contribution is generally small (on the 

order of 0-15%), and is likely due mostly to nearby CENRAP states.
June 26, 2007

A second trajectory analysis was conducted using data for 2000-2003 (20% highest and lowest 

days), a start height of 200m, and a 120-hour (5-day) trajectory period (Cite: “Sensitivity 

Analysis of Various Trajectory Parameters”, June 2005, LADCO). Back trajectory plots were 

prepared for each of the four northern Class I areas in Michigan and Minnesota for the high 

extinction days (see Figure 1 – note: areas in orange are mostly likely upwind and the areas in 

green are least likely upwind on poor visibility days). Although somewhat qualitative, these 

results provide additional information in identifying states impacting the northern Class I areas.

 Voyageurs Boundary Waters

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

 Isle Royale Seney

S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA S#

S#

S#

S#

ISLE

VOYA

SENE

BOWA

Figure 1. Contoured trajectory plots for poor visibility days for Class I areas in northern 

Minnesota and Michigan

(2) MRPO PSAT Modeling

A photochemical grid model (CAMx) was applied to provide source contribution information for 

2018 conditions. Specifically, the model estimated the impact of 18 geographic source regions 

and 6 source sectors (EGU point, non-EGU point, on-road, off-road, area, and ammonia 

sources) at Class I areas in the eastern U.S. Example results for four Class I areas (Seney, 

Mammoth Cave, Mingo, and Shenandoah) are presented in Figure 2. The results for 13 Class I 

areas in eastern U.S. were examined to identify those Class I areas where an MRPO state had 

at least a 2% contribution to total light extinction.
June 26, 2007

Figure 2. Source region contributions to light extinction based on MRPO PSAT modeling for 

select Class I areas: Seney, Mammoth Cave, Mingo, and Shenandoah

(3) MANE-VU Contribution Assessment

A weight-of-evidence report was prepared by NESCAUM (on behalf of MANE-VU) to 

understand the causes of sulfate-driven visibility impairment at Class I areas in the northeastern 

and mid-Atlantic portions of the U.S. (cite: “Contributions to Regional Haze in the Northeast and 

Mid-Atlantic United States”, August 2006) The report provides information on the relative 

contribution of various emissions sources and geographic source regions. The analytical and 

assessment tools considered include Eulerian and Lagangian air quality models, and data 

analysis techniques, such as source apportionment analyses, back trajectories, and 

examination of emissions and monitoring data. Sulfate impacts were quantified using five 

analytical techniques based on 2002 conditions: REMSAD, Q/d, CALPUFF (w/ NWS data), 

CALPUFF (w/ MM5 data), and percent time upwind (based on trajectory analyses). Figure 3

summarizes the five sets of results for three MANE-VU Class I areas. Although no specific 

criteria were identified in the report to determine a significant contribution, the States of 

Vermont, New Hampshire, Maine, and New Jersey assumed a 2% sulfate impact in recent 

letters to other states inviting them to consult on reasonable progress goals. The MRPO States 

identified as contributing to a MANE-VU Class I area were Illinois, Indiana, Michigan, and Ohio 
June 26, 2007

Figure 3. Percent contribution results using different techniques for ranking state contributions 

to sulfate levels at MANE-VU Class areas (cite: “Contributions to Regional Haze in the 

Northeastern and Mid-Atlantic Portions of the U.S.”, August 2006)
June 26, 2007

(4) Missouri-Arkansas Contribution Assessment

The draft Consultation Plan for the two Missouri and two Arkansas Class I areas provides 

information on source regions affecting these Class I areas (i.e., areas of influence) using a 

variety of data and analyses. (cite: “Central Class I Areas Consultation Plan”, States of Missouri 

and Arkansas, February 2007) A decision on whether a given state is a contributor to visibility 

impairment in these Class I areas was based on the combined results of three approaches: 

areas of influence (see Figure 4), PSAT modeling (based on 2018 conditions), and monitoring 

data analyses (PMF and back trajectories). According to the draft plan, if a state was a major 

contributor for at least two of the three approaches (for either sulfate or nitrate), then it was 

determined to be a significant contributor. The MRPO States identified as contributing to a 

central CENRAP Class I area were Illinois, Indiana, and Ohio.

Figure 4. Areas of Influence for Central CENRAP Class I Areas (cite: “Central Class I Areas 

Consultation Plan”, States of Missouri and Arkansas, February 2007)

(5) VISTAS Area of Influence Analysis

Areas of influence (AOI) were identified for Class I areas in the southeastern U.S. using 

residence time plots based on wind trajectory direction and frequency, and weighted by visibility 

impact (light extinction by ammonium sulfate, ammonium nitrate, or elemental carbon).

(Cite: “VISTAS Areas of Influence Analysis”, Draft, February 28, 2007). These extinctionweighted residence time analyses were overlayed on gridded emissions (for both 2002 and 

2018) to define emission sources in the areas of greatest influence for each Class I area. 

Figure 5 shows the plots for two VISTAS Class I areas. AOIs were defined on the basis of 

residence times greater than 10%. The MRPO States identified as contributing to a VISTAS 

Class I area were Illinois, Indiana, and Ohio.
June 26, 2007

Figure 5. Areas of Influence for Shenandoah (left) and Mammoth Cave (right) for 2018 conditions 

(cite: “VISTAS Area of Influence Analyses” PowerPoint presentation, November 28, 2006)

Note: green circles indicate 100- and 200-km radii from Class I area, red line perimeter indicate 

AOI with residence time > 10%, and orange line perimeter indicate AOI with residence time > 5%
June 26, 2007

Table 1. Draft List of Class I Areas Impacted by MRPO States - References

AREA NAME IL IN MI OH WI

81.401 Alabama.

Sipsey Wilderness Area (1) (1)

81.404 Arkansas.

Caney Creek Wilderness Area (2), (4) (2), (4) (2), (4)

Upper Buffalo Wilderness Area (1),(2),(4),(5) (2), (4) (2), (4) (2)

81.408 Georgia.

Cohotta Wilderness Area

Okefenokee Wilderness Area

Wolf Island Wilderness Area

81.411 Kentucky.

Mammoth Cave NP (1), (2), (5) (1), (2), (5) (1), (2) (1), (2), (5)

81.412 Louisiana.

Breton Wilderness Area

81.413 Maine.

Acadia National Park (3) (3) (3) (3)

Moosehorn Wilderness Area. (3) (3) (3) (3)

81.414 Michigan.

Isle Royale NP. (1), (2) (1), (2) (1), (2) (1), (2)

Seney Wilderness Area (1), (2) (1), (2) (1), (2) (1), (2) (1), (2)

81.415 Minnesota.

Boundary Waters Canoe Area Wilderness (2) (2) (2) (1), (2)

Voyageurs NP (2) (2) (1), (2)

81.416 Missouri.

Hercules-Glades Wilderness Area (2), (4), (5) (2), (4), (5) (2), (4) (2)

Mingo Wilderness Area (2), (4), (5) (2), (4), (5) (2) (2), (4) (2)

81.419 New Hampshire.

Great Gulf Wilderness Area (3) (3) (3) (1), (3)

Pres. Range-Dry River Wilderness Area.

81.42 New Jersey.

Brigantine Wilderness Area (3) (3) (1), (3) (1), (3)
June 26, 2007

81.422 North Carolina.

Great Smoky Mountains NP{1} (1) (1) (1)

Joyce Kilmer-Slickrock Wilderness Area{2}

Linville Gorge Wilderness Area.

Shining Rock Wilderness Area.

Swanquarter Wilderness Area

81.426 South Carolina.

Cape Romain Wilderness

81.428 Tennessee.

Great Smoky Mountains NP{1}. (1) (1) (1)

Joyce Kilmer-Slickrock Wilderness{2}

81.431 Vermont.

Lye Brook Wilderness (2), (3) (2), (3) (2), (3) (1), (2), (3)

81.433 Virginia.

James River Face Wilderness. (2) (2) (2) (2), (5)

Shenandoah NP (2), (3) (1), (2), (3) (2), (3) (1),(2),(3),(5)

81.435 West Virginia.

Dolly Sods/Otter Creek Wilderness. (2), (3) (1), (2), (3) (1), (2), (3) (1),(2),(3),(5)

Key

(1) MRPO Back Trajectory Analyses

(2) MRPO PSAT Modeling

(3) MANE-VU Contribution Assessment

(4) Missouri-Arkansas Contribution Assessment

(5) VISTAS Areas of Influence
Regional Air Quality Analyses for

Ozone, PM2.5, and Regional Haze: 

Final Technical Support Document

April 25, 2008

States of Illinois, Indiana, Michigan, Ohio, and Wisconsin
Illinois

Ambient Air Monitoring

Network Plan - 2012

Illinois Environmental Protection Agency

Bureau ofAir

Air Monitoring Section

July, 2011
Illinois Ambient Air Monitoring Network Plan - 2012

Introduction

Federal Regulation 40 CFR Part 58 Subpart B 58.10 requires the States to submit to

USEPA an annual air monitoring network plan for the next calendar year. The plan is to

provide a detailed description ofthe monitoring network for all ofthe criteria pollutants:

carbon monoxide (CO), nitrogen dioxide (N02), sulfur dioxide (S02), ozone (03),

particulate matter (PM1 0 and PM2.5), and lead (Pb). The monitoring sites are categorized

by the following types: NCore (national trend sites), SLAMS (state and local air

monitoring sites), SPM (special purpose monitors), PM2.5 speciation sites (trend and

State), and PAMS (photochemical assessment monitoring sites). Specific site infOlmation

is to include locational information (address and latitude/longitude), site type, objectives,

spatial scale, sampling schedule, and equipment used. In addition, changes from the

previous network plan are to be listed. The proposed annual network plan is to be made

available for public inspection for 30 days prior to submission to USEPA.

Relevant supporting air quality data in past Illinois Annual Air Quality Reports are

available at the following link http://www.epa.state.il.us/air/air-quality-reportlindex.htrnl.

These data reports contain detailed monitoring data summaries from the network, show

comparisons to the applicable air quality standards, as well as, illustrate pollutant trends

over various time periods.

Network Design

Appendix D to Part 58 establishes the design criteria for the ambient air monitoring

network. The network is designed to meet three general objectives: provide air pollution

data to the public in a timely manner, support compliance with ambient air quality

standards and emissions strategy development, and support air pollution research studies.

Specific objectives for the monitoring sites are to determine the highest pollution

concentrations in an area (peak), to measure typical concentrations in areas of high

population density (population), to determine the impact ofsignificant sources or source

categories (source), to determine general background levels (background), and to

determine the extent ofregional pollutant transport among populated areas (transport).

Minimum site requirements are provided for ozone and particulate matter based on

metropolitan statistical area (MSA) population. There are no minimum site requirements

for carbon monoxide, nitrogen dioxide, or sulfur dioxide. Minimum site requirements for

lead only apply in areas where sources (facilities) emit more than one-halfton per year of

lead. The Illinois air monitoring network meets or, in most cases, exceeds the minimum

network requirements.

The 2012 annual monitoring plan has also incorporated the recommendations provided

within the Regional Network Assessment prepared by the Lake Michigan Air Directors

Consortium (LADCO) and submitted to US EPA in July, 2010. The Regional Network

Assessment was prepared in conjunction with all ofthe US EPA Region 5 states and
constitutes, not only an assessment of current state monitoring networks but also provides

a multi-year plan (3-5 years) for development ofstate/regional network modifications.

Network Implementation

Appendix E to Part 58 establishes the specific requirements for monitor/probe siting to

ensure that the ambient data represents the stated objectives and spatial scale. These

requirements are pollutant/scale specific and involve horizontal/vertical placement,

spacing from obstructions, spacing from trees, and spacing from roadways. The Illinois

air monitoring network meets these siting requirements. Illinois also operates a PAMS

network in Chicago that is part of an USEPA approved "Alternate Plan for the Regional

Lake Michigan PAMS Network". The PAMS network encompasses monitoring

requirements for both the Milwaukee and Chicago ozone nonattainment areas.

Monitoring Methods

Appendix C to Part 58 specifies that monitoring methods used for comparison to the

National Ambient Air Quality Standards (NAAQS) must be Federal Reference or

Equivalent Methods (FRM or FEM). All monitors listed in this network plan use either

FRM or FEM with the following exceptions. The carbon monoxide and sulfur dioxide

monitors at NOlihbrook are trace-level samplers which are not FEMs. Thus, these data

will not be used for compliance purposes. None ofthe continuous PM2.5 samplers used

are FRM or FEM. These samplers are intended to provide real-time particulate data for

the Air Quality Index (AQI) and AIRNOW mapping purposes rather than compliance.

Ouality Assurance

Appendix A to Part 58 establishes the minimum quality system requirements for the

criteria pollutant data submitted to EPA. There are two primary Quality Assurance

Organizations applicable to this network plan, the Illinois EPA (IEPA) and the Cook

County Department of Enviromnental Control (CCDEC). These two organizations meet

and in most cases exceed the minimum requirements ofAppendix A.

Network Changes for 2012

The proposed 2012 network is nearly the same as that approved by US EPA and operated

in 201 I. The main additions to the proposed network are new lead (Pb) source-oriented

sites required by the December 14, 2010 changes to 40 CFR Part 58 and which are to

begin operation January 1,2012. The design ofthe monitoring network for 2012 has also

been based upon the assumption that funding to support the monitoring program is likely

to be reduced in fiscal year 2012 and that all efforts would be made to keep as much of

the network intact as possible. Also, the assumption was made that complete funding

would be provided in 2012 to support the completion and continued operation ofthe two

NCore sites located in Northbrook and Bondville.
Proposed Monitoring Network Changes for 2012

A pollutant by pollutant discussion ofthe basis for the changes to the network, the

underlying rules and requirements, Illinois EPA's proposed actions in specific areas and a

detailed listing ofspecific sites that have proposed changes is provided on the following

pages.

Carbon Monoxide

There is no federal/state monitoring requirement for carbon monoxide. Nine sites were

operated in 2011 with no changes proposed for 2012.

Nitrogen Dioxide

There is no federal/state monitoring requirement for nitrogen dioxide. However, three

sites are required in the Chicago area as part ofthe USEPA approved "Lake Michigan

Alternate PAMS Plan". Seven sites were operated in 2011 with no changes proposed for

2012.

Sulfur Dioxide

There are eight sites required under federal/state rules, three sites in the Metropolitan

Chicago area, two in the Metropolitan St. Louis area and three areas where

concentrations were found to exceed the hourly sulfur dioxide air quality standard. A

total offourteen sites were operated in 2011 with no changes proposed for 2012.

Particulate Matter (PM10)

There are four sites required under federal/state rules, one in each ofthe four original

PMlO nonattainment areas. A total offive sites were operated in 2011 and no changes

have been proposed in 2012.

Particulate Matter (PM2.5)

There are five sites required under federal/state monitoring rules and two sites required as

part ofthe USEPA approved plan for NCore (National Trend Sites) monitoring bringing

the state total number ofrequired sites to seven. Thirty four sites were operated in 2011.

The 2012 plan also proposes thirty four sites with one site being relocated as follows:

170190004 Champaign 606 E. Grove Neighborhood

and moved to a new location at:

170190006 Champaign 904 N. Walnut Neighborhood

SLAMS discontinued

Scale SLAMS
Ozone

There are fifteen sites required under federaVstate monitoring rules and four sites

required as part ofthe USEPA approved "Lake Michigan Alternate PAMS Plan" bringing

the state total number ofrequired sites to nineteen. Thirty three sites were operated in

20 II. The 2012 plan proposes thirty four sites with a new site being added in Rockford

due to an increase in population and an associated requirement within Part 58 that

specifies a second site in Rockford area. An additional site change in Champaign and

Springfield has also been proposed. The 2012 network changes are as follows:

17201XXXX Rockford New site Urban Scale SLAMS

170190004 Champaign 606 E. Grove Urban Scale SLAMS discontinued

and moved to a new location at:

170190007 Thomasboro North Thomas St. Urban Scale SLAMS

171670013 Springfield 3050 Mayden Rd. Urban Scale SLAMS discontinued

and moved to a new location at:

170190014 Springfield State Fairgrounds Urban Scale SLAMS

There are ten sites required under federal/state rules, eight in areas where significant lead

industrial sources are located and two in large urbanized areas with populations greater

than 500,000 people (Chicago and St. Louis). There were thirteen lead sites operated in

20II. The 2012 plan proposes fifteen sites with two new source oriented sites being

proposed as follows:

171190008 Alton

17XXXXX Geneva

409 Main Street

Johnson Controls

Neighborhood Scale SLAMS

Neighborhood Scale SLAMS

These new lead sites are required under USEPA's revisions to Part 58 monitoring rules

adopted December 14,2010. While currently not expected, further analysis and

dispersion modeling ofidentified industrial sources oflead may dictate additional lead

monitoring requirements.
Metropolitan

Statistical Areas

lllinois EPA

BweauofAir

Legend

C] County Boundaries

D Springfield (Metro SA)

St. Louis (Metro SA)

Rockford (Metro SA)

Peoria (Metro SA)

o Davenport-Moline-Rock Island (Metro SA)

o Cbicago-Naperville-Michigan City (Consolidated SA)

Champaign-Urbana (Metro SA)

Metropolitan Statistical Areas (Metro SA)

Rockfj d

N

a to +20 30 40 50 Miles
ILLINOIS - ANNUAL MONITORING NETWORK PLAN - 2012

CARBON MONOXIDE

AQSSite County Cil)' t\lh.lrell Sile Dilcrill1ion Sile 0l.crnlor GeolO1'llPbic:11 Coordinates AI'('I1 Represented Moniloriul: Objeclivcl Spalial Scale Propoul to MOlliloring; Type Parameter

IdcnliliclIliull /1101'1' or CO Number Di'con'inue Code 42101

Analrsis&

Primary S«olldary Sam Ilin.l!.

L:Ilitllde Lou::illlde

_.

,., -.........jo

17-031-0063 Cook Chic:al'.o 321 S. ffllnlclin CTA 8uilo.1illll IEPA +41.8n628 -87.635027 Chical!o-Nallcwillc-Michillllll Ci",. 1l...IN.\Vl Hi llesl Conc. N/A Micro N/A SLAMS TE Hourly

17-031_3103 Cook Schiller Park 4743 M311llheim Rd. II!PA Trailer lEPA +41.96519348 -87.87626473 Chicallo-NaperviUc-Michillall Ci",. II....IN.WT Hi IIeSI Conc. N/A Middle NlA SLM'IS TE Hourlv

17-031-4002 Cook Cicero 1820S.51~lAye. Cook Counlv Troiter CCDEC +41.85524313 _111.1524697 Cllica o-Na rville-Michi an Cit .nAN-WT Po Illation NlA Nei hborllOod NlA SLM'IS API HourlY

11-031-420 I Cook Northbrook 750 Dundee Rd. Northbrook Water Plaut lEPA +42.13999619 .81.79922692 Cllical!o-Nanerville-Michil<an Cil .IL·IN·Wl PODlilMion NlA Nei hhorllood NlA NCORE TEl Hourlv

17-031-6004 Cook Mavwood 1505 S. Firsl Ave. Com Bd MainlclIllocc Bldll. ccoec +41.81211684 -81.82908025 Chic81!o-Naucrvillc-Michillau Ci",. IL·[N·WT Hi heSI Cone, NlA Micro N/A SLAMS API HOllrlv

11-143-0036 Peoria Peoria 1005 N. Unive~it Commercial Bid.':. lEPA +40.70001191 _89.61341375 Peoril. lL Hi IICStCOIlO, NlA Micro N/A SLAMS Tlj Hourlv

17.163.0010 51. Clair East St. Louis 13th & Tudor RAPS TTlliler !EPA +38.61203448 -90.16041663 St Louis. lL-MO Hi hest COIlO, NlA Nc:i hborllood N/A SLAMS TE Houri

17-161-0008 S30~amOll Sorin field 6th St. & MOllroe Fetler~1 BltllI.. lEPA +39.7993092 .89.64760789 SlIril1 field. 11. Hi hut COllO. NlA Micro N/A SLM'IS TE Iiouriv

11-201-0011 Winncba~o Rockford 425 E. State City Hnll JCPA +42.26767353 _89.08785092 Rockford. lL Hi host COIlO. N/A Micro N/A SLMlS DA Hourlv

A.tlalysi~Melhod· TE (TECO 48), API (API 300), DA (OASIDI3008), TEl(T.GCO 48J-TU!)

Sampling Schedule. Hourly (1 hour mnples)

CCDEC. Cook Counl1 Depertmenl 01 Environmental Control

IEPA • illinois Environmental I'rolee:tlon Agency
Carbon Monoxide

•
ILLINOIS - ANNUAL MONITORING NETWORK PLAN - 2012

NITROGEN DIOXIDE

AQS Sil~ County City AIlllreJl Sile I>i,cripl....n Sile Operalor Geotrllphitlll COllrdillat~. A",~ R~pr~JCIIICIl Moullor;111( ObJccli,'u Sp;.tial Scl.lc ProJ}OJallo Moniloriul Type Param~lft

Id~"tilkalio" l'I1o"c or NO.

Nurllber LJucollt;oue Code 42602

Analysis &

Primary Secondnry 5110111i02

Llltitooe Longitude -,- .. -

"'" .... 17.(l31..()063 Cook Chica II 321 S. Franklin CTA Buildin IEPA +41.877628 -87.635027 ChiCli o-N:I. NiIl.,..Michi Cilv, D..-IN·WJ Hi"hest Cone. Source Middle N/A SLAMS TE Houri

17.(l31..()072 Cook ChicaJlo 1000 E. Ohio Jmdine Water Planl IEPA +41.89581227 -117.60768329 Chica~o.NaJM'rvill.,..Michinn Cilv. D..-IN·W! POllulalion SOllfU Nti ·hborhood NlA PAMS TE HOllrl

17..()31..()076 Cook Chica 0 7801 Lawn(191~ Com Bd Mainl~mmco Bldll. CCDEC +41.15139998 -111.7134111115 ChiUl~o·NaJM'rville-Michi n Cilv,lL-m·WJ Po ulalion NlA Nei hborhood NlA SLAMS TE Hourt

17-0)1-3103 Cook Schiller ?ark 4143 Mannheim Rd, !EPA Trnilor mPA +41,96519348 -1I7.lI7626413 Chica"o-NanefViHe-Michipan Citv, !T..IN.WJ Hi hUI Cone, SOIII'CO Middk NlA SLAMS T' HOllrl

17-031-4002 Cook Cicero 1820S.5IslAvo. Cool: COlll1lv Tl1Iilcr CCDEC +41.85524313 -81.1524691 Chical!o-Naocrvillc-MichilGU\ Citv, It-IN-WJ Poolilation NlA Nei liOOrhood NlA SLAMS TE HOllrl

17-0)1-4201 Cook Northbrook 150 Dundee Rd, Northbrook Water Planl I!::VA +42,13999619 .81,79922692 Chicago-NallefViIle-MichiRan Ciry.lL·IN.Wr Po 1I10lion NlA Urball NlA PAMSINCORE TE Ho~rr

17·163-0010 SI. Clair Ea~t 51. LOlli, 131h & Tudor RAPS TTlli1~r IEPA +38,61203448 .9(),16047663 St Lo~is, IL.MO POOll10lion N/A N~i hoorhood NlA SLAMS TE Houri

Allal)"';, Method. TE (TECD 42)

S3mpling Schedule - Hourly (1 hour lamplc~)

CCDEC - Cook County Depertmenl of Environment~1 Control

IEPA· ~lIr'lOili E"vlro"m~ntal Protoction Agency
~. ' ...... \1

Nl

"trogen Dl"OXl"de (2:;; "'-'"""-,FC:f'=±=c-rfdr--.'71k)~.~~=1~1\

- ..... '0 1'0 -d.\ Chicago - Jardine

~_~=-i--=;::::::;""-'n---~r-. ~~hiCagO - CTAi-' I' res. ~' Chicago-CornEd

C-"'--'~"'rt~----~----~+-~+-i"" L) .~ lL'l----'

1----T--;-'----1

,),..r--rl'...... (

L

)
ILLINOIS - ANNUAL MONITORING NETWORK PLAN - 2012

SULFUR DIOXIDE

AQS Silf COUllI)' City ALllh"el~ Silt DiuripliQIl Sile 01)UOlor Gell~l'apbkal a.D,·Llillale. Arca Rept""'111eu Monilorin~ ObJe~li\'~1 Spalial Scale: PtllPlll1l110 1\1ouil0tlll: Type Pa""lllclcr

ILlfnlifjealioll MO\'t or SOl

l'iluubfr Dil~Olllimlf Colle 42401

AnDIYlil &

I'rimnl'J St~o"uary SlIm,liol[

Lalillltle Lo0l:ilutlf ....,. ._- -- 11-031-0076 Cool: Cbical!o 7801 Lawndalf Com Ed M~jlllenDlICll Bldl!. CCDEC -4-4],15139998 .87.71348815 Cbicol!OoNanerville-Mitllil!aI1 Citv.IIAN.W1 Pooularioll NIA U,ban NlA SLAMS API Hourlv

17..(l31_1601 Cool Lo_, n9HouS'lOll Cool: County Tmilc' CCOEC -+41.66812034 -87.9905691>9 Chicm:o-NapcJVine-Michi.~ Cltv. nAN-WI p" ulalion N/A NeiRhhor1lOOd NlA SLAMS API Hm>""

17..(l31-4002 Cool: Cicero 1820S.5Is,Ave. Cool: County Tmile' CCDEC -+-41.85524313 -87.7524697 Chi""l!o-NalleTVille-Michi"an Citv. Q...m·WJ Pooula,ion N/A Nci~hbo,hood NlA SLAMS API Hourlv

17-031-4201 Cool: Northbrool: 750 Dundee Rd. NOf1hblool: Wa,c. Plan' IE'A -+<12.13999619 ·87.799126'12 ChiClll!o-Na\lcJVillc-Michi~an Citv.lL-fN·WJ r ula,ion N/A U.han NlA NCORE DA Hm>rl,

17...(l99...(l007 laSalle 1000lesbv 30R Ponllllid A...., IEPA Traile. IEPA -+<11.29301454 _89.04942498 OlJawa-Sflcak>r. IL Hil:!l\MtCono. SoUM:f N~i~hllorhood NlA SLAMS DA Hourlv

17-115..0013 Macon "=",, 2200 N, 22m! Sl ffiT'A Traile. IEPA +39.86683389 _88,92559445 Decatur. iL , 1I1aooi N/A Nfi ·hborhood NlA SLAMS DA Houri

17_117-0002 Maccuoin Nilwood Henton &. Duboi1 IBPA Tr~ile. IEI'A 1'39.39607533 .89.80973892 SI Louis. ll.-MO BllCkll..Cl1l1d POPulation Rt ·iollnl NlA SLAMS DA Hourlv

17-119·1010 Madison Sollth Rox~n~ Michi an 51, S. ROXllnD Grnde School IE'A +38.82830334 ·90,05843262 51 Louis. IL-MO Hi heSl Cono. SouM:e Nel hoorhood NlA SLAMS DA 1lour!

17-119·3007 Madison Wood River 54 N, Walcott Wntcr T.oatme-nll'llUll mPA +38.86066947 .90,10585111 SI Lollis. U.....MO Po lllllriOIl N/A Nelllhborhood N/A SLA.~IS DA I·lomlv

17-14J..o024 Peori~ Peori~ Hurlhurt &. Ml\l)Arlhur lIi.a Station ItS IEPA +40.68742038 _R9,60694277 Peoria. IL Po ulalion N/A Nei hborhond N/A SLAMS DA 110url

17-157"()()()1 Randolph Hou.toll Hickorv GmVl! & Felivicw ral'ATrlliler JEPA +38.17627761 -89,78845862 N/A Back 'round N/A Neio.hbOlhood N/A SLAMS DA Hourlv

17-163..()(l10 SL Clair Easl St. Lllui. lJlh&TLldo. MAPS Trailer lEPA +38.61203448 .90,16047663 SI Louis.lL-MO POllulatiol1 N/A Neio.hborhood N/A SLAMS DA Hourlv

17-167.()()()6 Sanllamon ISorillll.lield HOO Mcchenicsbur Rd. Sewall" Tre~lme-nt Plml )EPA +39.80061377 -89.59122532 ISorinll.fic1d. IL HicllflitCOIlO. Source NeiohborbtlOd N/A SLAMS DA Hourlv

17-179.()004 Tazewell Pelin 272 D~rby Pekin Fire Stillion IfJ IEPA -+40,55646017 ·89.65402807 Peoria.lL Hilthe5t Cone. Source Neilthborhood N/A SLAMS DA Hourly

Analym Method -API (API 100). DA(DASIB14108)

SlmIflling Schedule. Hourly(1 hoursamp~)

CCOEC • Coot Comly Olpal1menl 01 Environm~nIal COlIlrol

IEPA ·lIllols Environmenllli Praleelion .-.oency
Houston

•
ILLINOIS - ANNUAL MONITORING NETWORK PLAN - 2012

OZONE

AQS Silt County City Alldrtlll SlIt DllCrlJlliou Silt Opnnlor Ctllltnphir.al Cllordinall':S Area ReprtSI'UltLl Mooilol'inl: Objecli,'U SpatiaJ ScaJe Prllllo.aJ 10 M011110riOlt Typt Parnnl~lft

Idtnlificatilln "to"ellr 0'

Numb~r Oisoo"li'Il.lt Code 44201

Analysis &

Primnry S!'clloilary 511n1,lin

Lalifude IAmgihtde

_.

, ~..:-

17-001-0007 Adams uin"" 13015. 481h SI John Wood Communitv Colle e IEPA +39,91540937 -91.33586832 lOuin . IL-MO Po ulo1ioll N/A Urbon NlA SLAMS TE HourI

CbamlXliJtl\ ChamlXlilUl 606 E, Grove WlI5hinllton ~Io:nnentorv !EPA +40.1237962 -311.2295]0911 ChamOO;Illl-Ur~ IL PODulotlon N/A !Jrb..l SLAMS TE Hnurly

Chamnaipn Thomasboro Nonh Thomas SI. Resident !EPA +40.144183 -88.111144 C"m , Urbana. JL Po ulatioll N/A Urban SLAMS TE HourI

17-031-0001 Cook AlsiD 4500 W. 123rd 51. VillllQe Garalle CCDEC +41.6709919 -81.7324569 Chic:l.lw-Naoerville-Michilllln Ciw, lL.-lN_WI POlllllalion N/A Uman NlA SLAMS OM Hourly

/7-0]1-0032 CMk ChiCBRO 3300 I.'.. Cheltenham Pl, Soulh Waler FiltT'lltion Plant CCDEC +41.75583241 _87.54534967 Chica 'o-Nnpervit1e.MichiRan Cily, IL·IN·WI Hi hesl Conc. Po ulalion Neillhbcrhood NlA SLAMS OM HourI

17-031_0064 Cook Chica '0 5720 S. Ellis Ave. Uniyersitv IlfChiClno CCD?C +41.79078685 -87.60164649 Chic.1~o-NlInerville-Michil!lInCitv, IL.IN-WI Pooulation N/A Neillhoorhood NlA SLAMS OM Hourly

/7-031-0072 Cook Chic3~0 1000 E. Ohio Jnrclinc Waler Planl )EPA +41.89581227 _87.60768329 Ch;C3 'o-Naoerville_Michill:3n City, IL·[N·WI Poculotion SOllrce Ncillhhorhorxl N/A I'AMS OA HourI

17-031-0076 Cook Chica 0 7801 Llwndale Com Ed Mainl~I1UllCC BId . CCOIlC +41.75139998 .87.71348815 Chic.1 o-Na erville-Michi '311 Cil •JL.TN.WI Pon\Jl~tiOIi N/A Utbun N/A SLAMS API HOllrl

/7-031-1003 Cook Chic3~0 6545 W, llurlbllt St 1nA Iii h St:hool CCDBC +41.98433233 _87,7920017 Chic3~O_NIIPerville_Michill:anCily, IL·IN·WI Pocnlatiol1 N/A Urban N/A SLAMS API HOllrly

17-031-1601 Cook Lemont 729 HOUSlon euok Counl Trnilcr CCDBC +41,66812034 .87.99056969 Chic3j1;o-Napervil1e-Michip;a.n Cily, IL·IN.WI Po ulation N/A Urban N/A SLAIIIS API Hour!

17-031-4002 Cook Cicero 1820S.5IstAve, Cook ('Ilunt Trailer CCDEC +41.85524313 _87.7524697 Ch;ea 'o-NlIocrville_Miehiunn City, JL·IN·WI Pooulation N/A Neiuhborhood N/A SLAMS API Hourly

17-031-4007 Cook Des Plaine~ 9511 W, Hnrri~on SI. Rellional Offico Iildll. IEPA +42.06028469 -37.86322543 Chic3lto-Naperville-Michil!.1I11 City, IL.-IN-Wl Population N/A Urb.n N/A SLAMS OA Hourly

17-031-4201 Cook Nonhbmok 750 Dundee Rd. NDrlhhrool.: Waler Pbnt lEPA +42.13999619 -87.79922692 Chiea o.Na""rvil1e-Miehi an Cil ,JL·LN·WI I'onul~lion NA Uman NlA I'AMS/NCQRE OA Hourl

17-031_7002 Cook EvansTon 531 E. Linooln EVIln!ton Wiler PI,1l1 IEPA +42.06185724 -37.67416716 Chic3lto-Naocrville-M ichillllH Citv, JL·lN-Wl POOlllllion NlA Ncill.hborhood NlA SLAMS DA Hourly

17-043-6001 DIIPa I' Li~le RouI'" 53 MOrlOll Arboretulll IEPA +41.81304939 -38.0728269 Chicn o.NI rville-Miehi 'an Citv, IL-lN.WJ Po ulltion NlA Uman NlA SLAMS OA IInutl

17-065-0002 Hamilton Kni hI Prairie Twn Roule 14 Ten Mile Ct«!k DNR OffiOll !EPA +38.08215516 -38.6249434 MTVcmon,lL Dack<''Tound NlA Kc i('lnal NlA SLAMS DA Houri

17-08)_1001 Jtrscv J=cvville Libenv SI. &. Counl Rd. llIini Junior ~Iil!h School IBPA +39.11053947 -90.32407986 St Louis, IL-MO TranSllOrl PODulation Rrlciollal NlA SLM.IS OA Hourlv

17-0119-0005 Kane EI in 665 Oumlee RIl. Larun Junior Hiuh School mPA <+42.04914n6 -SS.2730293 Chica~NaJ.ll'rvill~MichiWl.llCilY,lL-lN·WI Po ulalion NlA Urblll1 N/A SLAMS DA Hourly

17-097-1007 Lok. Zion Illinoi, Beach Slale I'ark Camn Leulln Tmiler IEPA <+42.4675733 -81.111004705 Chical!o-Naocrvillt:-Michil!3ll CiTY, JL.lN·WI Hi"hesf Cone. Trallsnorl Urban NlA PAMS DA Hourly

17-111-0001 McHenry C'N Pint SI. k Three Oaks Rd. Cllrv Grove Hi h School IEPA +42.22144166 -38.24220734 Chicasm-Nancrvillt:-MichilWl CiTV. JL-IN-WI 1'00ulaliol1 NlA Urban NlA NAMS OA Hourly

/7-113-2003 McLean Nonnal Main&:.G ISU Ph ielll Plant lEPA +40.511173537 .8K.99689571 Blonmin.<:ton-Nonnal. JL Po ulalion NlA Ur1llln NlA Sl.MIS re Hourly

17-115-0013 Macon Decntur 2200 N. 'l2lld SI. IEI'A Trniler IEPA +39.86683389 -118.92559445 Decatur.IL PODulation NlA Urban N/A SJ..MIS TE Hourly

17·117-0002 Macou in Nilwood Heaton &:. Dubois !EPA TJ1Iiler IIiI'A +39.39607533 -89.80973892 St Louis, IL-MO TrnnsllOrl l'Ollulntillll Re ional N/A SLAMS OA Huurly

)7-119-0008 Madison Altoo 409 Maio 51 Clam Barton School mPA +3B.89018605 -90.14803114 St Lvuis, IL-MO Hi"hest Cone. Po ulltiOn UrlJan N/A SLAMS DA Houri

17-119-1009 Madison Maryville 200 W. Division Southwesl Cablo TV tEPA +311.72657262 -89.95996251 ST Loui., JL-MO Ponulalion NlA UrlJan N/A SLAMS AJ'J Hourly

17-119-3007 Madison Wood River 54 N. Walcott Wiler Treatment PlanT Il!I'A +38.86066947 -90.10585111 St Louis. JL-MO Ponuialion NlA UrlJan N/A SLAMS OA Houri

17-143-0024 Peoria Peoria Hllrlbun &. MacArthur Fire Station 118 illPA +40,687420311 _89,60694277 Peorin,1L Pooulation N/A Noiahhorhood N/A SLAMS TE Hourlv

17-143-1001 Peoria Peoria Hei..hts 508 E, Glen Ave. Peoria Jloi hili JIi h School IEI'A +40.7455039] -89,58586902 Peoria. IL Hi heS! Conc, Po ulation Urban N/A SLAMS TE Hourlv

17-157-0001 Randolnh Houston Hickorv Gmvo &. Fallview tEPA Tmil~r IEPA +38,17627761 _89,78845862 N/A Bllck'r<)und N/A Re ional N/A SLAMS DA Hourlv

17-161-3002 Rock Island Rock Island 32 Rodman Ave, Rock Islllnd A:lICn.1 IEPA +4l.SJ472697 -90.51735026 Daven rt-MoJine-Rock Island, IA-IL Po Illation N/A Nei hborhood N/A SLAMS TE Houri

~'Cl'" Easl SI. Louis I3lh &. Tudor RAPS Tl1ilar IEPA +38,61203448 -90.16047663 St Loui., JL-MO I'onuillion N/A

N.,h'"hOO* SLAMS TE Hourly

SilO amon S rio 'field ]050 MI den Ril. Blandco Dldll, IEPA +39.84S356 -89.597457 ISprincl'leld.1L J'ollllialion N/A Urban SLAMS T£ Hourly

Slnl!.lllllon S mn.meld lIIino;. Buildillll SIRte rair roundl U!I'A +39.831522 -89.640926 S rill mehl. JL 1'0nulRli()n N/A Urban SLAMS re Hourly

17-197-1011 Will Bmidwood 36400 S. Esselt Rd. COin Ed Traininll Clr. lEIlA +<I1.22J53707 -88.19096718 Chical:!o-Naoervilie-Michillin CiTY, lL,'N-WJ Backllround N/A Re i01lll1 NIA I'AMS DA Hourlv

17-201-2001 Winneba"o LoV\!' Park 1405 Malle AvtI. Ma 10) P.1cmenta Sclml JEI'A +<12.33498222 -89.0377748 Rockford. JL Hi hesl Conc. Po 1I11ltion 0,,"" N/A I SLAMS DA Houri

Winoebago To Bo DClcrmincd To Be Dclonnined To Be Del~nnined mPA = = Rockford. IL Hi hesl Cone. Ponulalion Urban SLM.1S DA 1I0l>rlv

Analysis Method - DA (DASIDII003), DA8 {DASIDI 1(08). m (TECO 49), API (API 4(0)

Sampling 5clttdule - Hourly{l hour samples)

CCOEC - Cook County Oepartmenl or ErwIronmental Control

IEPA .llllrillil E~onm&lltal Protecliun .AQency
Rocklsllnd .......

Ozone

~~;=t::;:~Loves~P~Y~'-~·irOll' '-" RocKfo • ~___ 1\ .I~ k

) ) lJes; ... Evanston

rP".}-"'"'-:::::::~I:::::::;;;.~r--~~~S""~CI"'::"~icer~~ Chic·cagO-TaftH.S. ' --.... hicago - Jardine

Chicago - Univenlity

'" ' Chicago - South Water

~./f--,-_...L_---ii-.l----I ) ~i1'4 . go-CornEd

II

;

I

) •
ILLINOIS - ANNUAL MONITORING NETWORK PLAN ·2012

PARTICULATE MATTER - PM10

AQS Silf County City Alhlrfll SlIe Dileripllon SlIe Operator GUlrl\pb\cnl Coonlin"t"" Ana RcpUJtntt~ Moni!orinf: ObJtctl.'t, SI,DII/I] Sellle J""pDul til Monitol'in~ Type rnramtttr

Identilication MO\'eor J'MID

Number Dileonlinllt COdeHIID2

Allal,...iJ & SampUne

PriRlnry Second/lry

Lalilmle Lonliludt ,...,. - , ,_. 11-031-0022 Cook Chic.:lRo 3535 e. II'hh Sl WMhinl{ton Hildl School CCDEC +41.(,11716544 _87.53931548 Chicaeo-NDnen~ne-Michil!'lI1 Cih'.IL-IN_WI Hillhest Conc. Source Neil.'hborhood NlA SLAMS a""A Hourh'

11-031_1016 Cook Lnm.. To"nshi SOl" SI. &. Glencoe Vi11 eH:IlI /EPA '1'41.1I0116701 -~U319447 ChicDl.'o-NDller\'lIIe-Michi :lIl Ci..•. IL-IN_WT Hil!.hest CDrIC, Source Middle NlA Sl.AMS S""A Houri,·

17-031-4201 Cook Nonhbrook 750 Duudee Rd, No,'hbmol: WilIer Pl:ml IEPA +42.139'>9fiI9 .87.79922692 CbicD.,....NDoen~Ile-Michi..<lIl Cill·. IL-IN.WI POllUllliion NlA Um~ NlA NCORE Iii_vol 116 , 11_119-0010 M:ldi'on Gr.lIlileCil\' ISIh &:: Madison Air Producil IEPA +3~.fi'N4lR31 _I)O,15l95426 51 Loui•. IL-MO Hiehest COllI.'. Somte Nei hbOfhood NlA SLMIS Hi-vol 1/.

17-119-1007 M:ldisoll Gr.lIlileCil\, 2Jrd. &. Mooison Fire Slalion III IEPA +3~.70453426 _90,ll%74114 51 Loni•. IL_MO Hi~hoest Conc, Somee Nciwhborllond NIA SLAMS BETA Hou,h'

Analylls Melllod - Hi-voIIHlgh volume ,ampler), BETA (AridetID~ Bell Atle~ulllilln MDr1ltDr)

S'lmpling Schedule - HOllfly (I hour ~ample~), 1/6 (I • 24 hour snmple el'ery Gdo)'s)

CCDEC _Cook Cou~ty Departll14lnt or Envlronmlntal Colllrol

IEPA ·1~lnoll Enlllranmental Prolllolion A'Ienoy
PMlO

,

\ ...,
ILLINOIS - ANNUAL MONITORING NETWORK PLAN - 2012

PARTICULATE MATTER - PM2.5 AQS Site I COUnl)"

hIoMlir",,,Ciou

Cil,. ",hlr... Slt.I)I'''~'llon 5110 O""'or I (""'oJr.~h!<.1 C"."lln.'" Arco 1I.,n"".tod ~lollilorln~ObJ«U.... Sr~Il.1 s."..10 I Stud.,ll IrropolOl to I ""o.llorl"l: 1)',",

)10.-00<

1'."'lI>l'lor

r~u..~

NlI.IIIbcr D~.tlJl,", Code 88101, lIlI~1 (IIA~l

AlIlll..... & S.mrH.;

B<nl>';n.

""" A Cool; C)oc.

Cool: Chi••

Cool: Chie.

Cook t.1lic.""

11_119-Jlo(r1 Mt>Jisom Wrnl Ri."Cf

11-14]..{,tm P=i. Pcori.

17_1S7..{(,(ll lu"wl 1-1<"1St,,,,

I1_161_~OO2 RoctJ,hmd Rocl:I.:Iolld

17_16]-l~'l!' Sl..CI"ir E,!!{SI,lo,,"

17_1(,7-0012 Son 'lImon 'rin fidJ

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