# A9

## Electronic Filing

- Received, Clerk's Office, December 7, 2009

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

INTHE MAITER OF: REASONABL

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

### II CONSUMER & 

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

### ) ) 

### ) ) 

### ) ) 

### RIO-8 (Rulemaking-Air)

NOTICE To: John Therriault, Assistant Clerk l1linois Pollution Control Board Jamcs 

### R. Thompson Center 100West Randolph, Suite 11-500 Chicago, Illinois 60601-3218 SEE ATTACHED SERVICE UST PLEASE TAKENOTICE that Ihave today filed with thc Office ofthePollution Control Board the SECOND MOTIONTO AMEND RULEMAKING PROPOSAL ofthe Illinois Environmental Protection Agency, a copy ofwhich is herewith served upon you.

Respectfully submitted, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

By: 

### O)g;y;>..

# ibju.~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel
DATED: December7, 2009 1021 N. Grand

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

## Electronic Filing

- Received, Clerk's Office, December 7,2009

BEFORE THE ILLINOIS POLLUTION CONTROLBOARD

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

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



### SECOND MOTION TO AMEND RULEMAKING PROPOSAL The Proponent, the Illinois Envirorunental Protection Agency ("TlIinois EPA"), byits attorney, andpursuant to 35 Ill. Adm. Code I01.500 and 102.402, moves that the Illinois Pollution Control Board ("Board") amend Parts 218 and 219 ofthis ruJemakingproposal. In support ofits Motion, the Illinois EPA slates as follows:
I. On July 9, 2009, the Illinois EPA filed a proposal with the Board to amend 35 Ill. Adm. Code Parts 21 I, 218, and 219 to control the emissions ofvoJatile organic materials ("VOM") from Group II Consumer and Commercial Product categories. The proposal implements reasonably available control technology for such categories inresponse to control techniques guidelines issued by the United States Environmental Protection Agency. 2. On September 14, 2009, the Illinois EPA filed aMotion to Amend Rulemaking Proposal, which the Board granted on October 15, 2009. The Illinois EPAproposes an additional amendment to its proposal, as follows. 3. In response to arecent request for clarification from an industry representative, the Illinois EPA recommends amending Section 218/219.187(b)(I) to specify that the YOM content limitations set forth in slIch Section apply to as-used cleaning solutions, excluding water and

1

## Electronic Filing - Received, Clerk's Office, December 7, 2009

other compounds exempted from the definition ofVOM. This proposed amendment is
consistent with the JIIinois EPA's original intent and with existing YOM regulations. Seclioll 218/219.187(b)(1): b) Material and Control Requirements. No owneror operatorofa source subject to this Section shall perfoml any cleaning operation subject to this Section unless the owner or operatormeets the requirements in subsection (b)(1), (b)(2), or (b)(3): 1) The YOM content ofthe as-used cleaning solutions (minus water and any compounds which are specifically exempted from the definition ofYOM) does not exceed the following cmissions limitations: WHEREFORE, for the reasons set forth above, the JlIinois EPA moves that the Board
amendParts 218 and 219 as set forth herein. Respectfully submitted,
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

# BY:~~ Dana Vetterhoffer Assistant Counsel Division ofLegal Counsel DATED: December 7, 2009 1021 N. Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

2

## Electronic Filing

- Received, Clerk's Office, December 7,2009

BEFORE THE lLUN01S POLLUTION CONTROL BOARD

IN THEMATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY (RACT) FOR VOLATILE ORGAN1C MATERIAL EMISSIONS FROM GROUP ]] CONSUMER 

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

### ) ) ) ) ) ) RI0-8 (Rulemaking-Air)



### CERTlF1CATE OF SERV1CE I, the undersigned, an altomey, statethat 1 have served electronicallythe attached SECOND MOTION TO AMEND RULEMAKING PROPOSALupon the following person: John Therriault, Assistant Clerk Illinois Pollution Control Board James R. Thompson Center 100WestRandolph, Suite 11-500 Chicago, llIinois 60601-3218 and electronically to the following persons: 

### SEE ATTACHEDSERV1CE LIST.

lLLlNOlS ENVIRONMENTAL PROTECTION AGENCY

By: 

### Q\q <

# .£L~Z¥ Dana Vetterho er Assistant Counsel Division ofLegal Counsel

DATED: December 7, 2009 1021 N, Grand Ave. East P.O. Box 19276 Springfield, IL 62794-9276 (217) 782-5544

## Electronic 

## Filing - Received, Clerk's Office, December 1, 2009

Service List

### RI0-8 Timothy

### J. Fox Hearing Officer Illinois Pollution Control Board 100 W. Randolph St., Suite 11-500 Chicago, IL 6060 

### J foxt@ipcb.state.il.us Virginia Yang Deputy Legal Counsel Illinois Department ofNatural Resources One Natural Resources Way Springfield, 1L 62702-1271 virginia.yang@illinois.gov Matthew Dunn, Chief Division ofEnvironmental Enforcement Office oftheAttorney General 69 W. Washington St., Suite 1800 Chicago, IL 60602 mdunn@atg.state.iJ.us Katherine D. Hodgc MonicaT. Rios HodgeDwyer

### & Driver 3150 Roland Ave. P.O. Box 5776 Springfield, IL 62705-5776 khodge@hddattomeys.com mrios@hddattornevs.com Alcc M. Davis General Counsel Illinois Environmental Regulatory Group 215 E. Adams St. Springfield, IL 6270J adavis@ierg.org

# A 10

### Page 1

R10-8 

## ( ILLINOIS POLLUTION CONTROL DECEMBER 8, 2009 IN THE MATTER OF: REASONABLY AVAILABLE CONTROL TECHNOLOGY FOR VOLATILE ORGANIC MATERIAL EMISSIONS FROM GROUP TO CONSUMER AND COMMERCIAL PRODUCTS, PROPOSED AMENDMENTS TO 35 ILLINOIS ADMINISTRATIVE CODE 211, 218, and 219. BOARD 

### REeelVEJiI

CLERK'S OFFICE



## DEClj 2009 STATE OF 

### ILLlN_C S 

### Pollution Control Be 

### ard



# c

,( REPORT OF PROCEEDINGS at the hearing of the above-entitled cause, taken before Rebecca A. Graziano, Certified Shorthand Reporter within and for the County of Cook and State of Illinois, at the Thompson Center, Room 9-040, Chicago, Illinois, commencing at the hour of 9:00 a.m. on the 8th day of December, A.D., 2009.

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## A P PEA RAN C E S

ILLINOIS POLLUTION CONTROL BOARD Mr. Timothy J. 

## Fox Ms. Carrie Zalewski Mr. 

## G. Tanner Girard Ms. Andrea S. 

## Moore Mr. Anand Rao Mr. Gary Blankenship

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY Ms. Dana Vetterhoffer Mr. David Bloomberg

# A 11

### RI0-8 (Rulemaking

- Air) ILLINOIS POLLUTION CONTROLBOARD December 9, 2009 IN THE MATTER OF: ) ) 

### REASONABLY AVAILABLE CONTROL ) TECHNOLOGY (RACT) FORVOLATILE ) ORGANIC MATERIALEMISSIONS FROM) GROUPII CONSUMER & 

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

### HEARING OFFICER ORDER**~ECEIVED** CLERK'S OFFICE



## DEC 092009 STATE OF IWNOIS Pollution Control Board

The second hearing in this proceedingtookplace Tuesday, December 8, 2009, in Chicago. TheBoard expects to receive thetranscriptofthat secondhearing no laterthanFriday, December 11,2009. Upon receiving thetranscript, the Board will postit to the Board's Web site atwww.ipcb.state.il.us. Underthe Board'sproceduralrules, "[a]nypersonmaysubmitwrittencomments on any proposal within 14 days afterthe receipt ofthe hearing transcript in Board offices unless otherwise specifiedbythehearing officerorthe Board." 35 

### TIl. Adm. Code 102.108(b). Accordingly, the Board will hold open apost-hearing commentperioduntil Monday, December 

### 28,2009. See 35 Ill. Adm. Code 101.300(a) (accountingfor Stateholidays incomputingtimes). Anyparticipantinthis proceeding who wishesto file apost-hearing commentwiththe Board is directedto do so on orbeforeMonday, December28, 2009. Comments and other documents maybe filed electronicallythrough the Clerk's Office On-Line (COOL) from the Board's Web site. 

### In the event thatthe Board issues aproposal for first notice, the Board's procedural rules provide for an additionalperiod ofpublic comment. 35 Ill. Adm. Code 102.108(a), 102.604; 

### see 5 ILCS 100/5-40(b) (2006). IT IS SO ORDERED.

Timothy

### J. Fox Hearing Officer Illinois Pollution Control Board 100W. Randolph St., Suite 11-500 Chicago, llIinois 60601 312-814-6085 foxt@ipcb.state.il.us

# A 12

# Mostardli Platt**Z~'W!:6"trJ.7t#!efttaC ~~**  .**..,.r.~-,,"~._"**

December23, 2009

John ThelTiault Clerk Illinois Pollution Control Board 100 W. Randolph St., Ste. 11-500 Chicago, IL 60601 Attn: RIO-8 Rulemaking

- Air: Lithographic Printing Rules

To whom it may concern, 1520 Kensington Road, Suite 204 Oak Brook, Illinois 60523-2139 Phone 630-993-2100

fax 630-993'9017 www.mostardiplattenv.com 

# lFio:C

# CLERK~**l~lfl:J'**

DEC 282009 STATEQ POllUtion

## C~~tLLl'NO/S ro 

### Board

# .~y

I wish to submit comments regarding theproposed changes to the Reasonably Available Control Technology (RACT) for Volatile Organic Material Emissions Standards drafted bythe Illinois Pollution Control Board (!PCB) that incorporates United States Environmental Protection Agency (USEPA) Control Techniques Guideline (CTG) into Illinois regulations. I spccifically wish to request clarificationbe added in therule for control device destruction efficiencies.
I am an environmental consultant that represents aheatset offset lithographicprinterwho recently installed areplacement catalytic oxidizeron three (3) olderheatset lithographic printing lines. (Note: older heatset presses did not have integrated afterburners as the new presses do.) The control device efficiency was pelmitted at 90% as allowed by current regulations. When USEPA finalized the OffsetLithographic PrintingMaterials and Letterpress PrintingMaterials CTGthey allowed for existing printing lines with control devices to have minimum 90% destruction efficiency. Illinois has incorporated that language as follows: 218.407 (a)(1)(C) An afterburner is installed and operated so that VOM emissions (excluding methane and ethane) from the press dryer exhausts are reduced as follows: i) Priorto May 1,2010, by 90 percent, by weight, orto a maximum afterburner exhaust outlet concentration of20 ppmv (as carbon); and i) On and after May I, 20I0, by at least 95 percent, by weight, orto amaximum afterburner exhaust outlet concentration of20 ppmv (as carbon) We request that this language be a little clearerto show what is being addressed, the printing line, the afterburner, orboth. Also we request that the language be clearerthat it is the installation/operation date ofthe unitthat deternlines what percent efficiencymustbe achieved, and not that all control deviccs must perfonll at ahighcr destruction efficiency after May I, 20I

### O. The following section also requires similar clarification that it is the date ofinstallation of the control device that determines what control efficiencymust be attained: 218.407 (b) An owner or operator ofa heatset web offset lithographic printing line subject to the requirements of(a)(1 )(C) ofthis Section may use a control device othcrthan an afterburner, if: I) The control devicereduces YOM emissions from the press dryer exhaust(s) are reduced as follows: A) Priorto May I, 2010, by at least 90 pcrcent, by weight, or to amaximum afterburner exhaust outlet concentration 01'20 ppmv (as carbon); and B) On and afterMay I, 2010; i) By at least 95 percent, by weight; or ii) To amaximum control device exhaust outlet concentration 01'20 ppmv (as carbon)

Current heatset lithographic presses are designed with an integrated drying oven / thennal oxidizer control. These units easily achieve the proposed 95% destruction rate and are cost effectivewhen purchasing new heatset presses. Many existing olderunits, however, require stand alone control devices. They are not engineered for optimized (lower) dryer air flow rates. As control device operational costs (natural gas usage) are high for thcse olderpresses it is more cost effective to duct emissions to catalytic oxidizers for control. Catalyst efficiencymay slightlyreduce over time and we wish to ensure that it is clear in therules that these units will always be able to comply with the 90% destruction mlnUllunl. Please provide clarification whether it is the effective operation date ofthe printing line or the control device, orboth in relation to the May I, 2010 control efficiency requirement. Will existing printing lines installed and operated prior to May 1,2010 that require a stand alone control devicc bc allowed to install new control devices that meet the 90% minimum destruction efficiency? Orwill the control device installation / operation date determine what destruction efficiency is required? (thatthc 95% minimum destruction efficiency is for printing units "installed and operated" afterMay 1,2010). Ifthe control device installation/operation date is the determining factor, can it bemade clear that all existing units maintain their status (90% destruction) through all equipment maintenance and repair, includingreplacement ofcatalyst? This could create a financial burden on sources to replace control devices that were compliant with the lithographic printingrules when the printing units were installed.Please note that the bulk ofheatset lithographic printing emissions come from cleanup solvents, not the inks. Cleanup solvents are not controlled by the oxidizerwhen hand applied with rags. The destruction efficiency will not affect these emissions, as they are limited by the solvent vaporpressure and work practices. Ifyou have any questions regarding this clarification request, please feel free to contact me at (630) 993-2138 or bye-mail atbmcerman@mostardiplattenv.com. Thank you for your consideration ofourrequest.

Bruce 

### 1m SeniorEnvirom ental Consultant Mostardi Platt Environmental

# A 13ILLINOIS POLLUTION CONTROL BOARD January 7, 2010
IN THE MATTER OF: ) ) REASONABLY AYAILABLE CONTROL ) TECHNOLOGY (RACT) FOR YOLATILE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP II CONSUMER & COMMERCIAL ) PRODUCTS: PROPOSED AMENDMENTS ) TO 35 ILL. ADM. CODE 211, 218, and 219 ) Proposed Rule. First Notice. RIO-08 (Rulemaking

- Air)

OPINION AND ORDER OF THE BOARD (by A.S. Moore): On July 9, 2009, the Illinois Environmental Protection Agency (Agency or Illinois EPA) filed aproposal under thc general rulemaking provisions ofSections 27, 28, and 28.2 ofthe Environmental Protection Act (Act). 

### See 415 ILCS 5/27,28,28.2 (2008). In an order dated October 15, 2009, the Board granted the Agency's motion to amend theproposal. On December 7, 2009, the Agency filed a second motion to amend the proposal, which the Board addresses belowunderthe heading "Preliminary Marter." Generally, the Agency has proposed air pollution regulations to control emissions ofvolatile organic material (YOM) for Group II Consumer & Commercial Products in ozone nonattainment areas classified as moderate and above. Group IIproducts include industrial cleaning solvents, flat wood paneling coatings, flexible packagingprinting materials, lithographicprinting materials, and lerterpress printing materials. The first-notice amendments described below are intendedprimarily to reduce YOM emissions from the Group II product categories in orderto meetIllinois' obligations underthe Clean AirAct (CAA). Publication ofthese proposed amendments in the 

### lllinoisRegisterwill begin a45-daypublic commentperiod. In this opinion, the Board first reviews theprocedural history ofthis rulemaking before addressing a singlepreliminary matter and thenbriefly reviewing federal regulation ofYOM emissions. Next, the Board summarizes the Agency's amendedproposal on a section-by-section basis. The Board then summarizes singlepost-hearing commentit received before addressing potentially affected sources and projected emissionreductions and technical and economic considerations. The Board then concludes to adopt the amendedproposal for first notice under the illinois Administrative Procedure Act (5ILCS 100/1-1 

### etseq. (2008)). The order following the opinion then sets forth the proposed amendments for first-notice publication in the 

### lllinois Register. PROCEDURAL HISTORY

### 2

On July 9, 2009, the Agency filed arulemaking proposal to amend Parts 211, 218, and 219 ofthe Board's airpollution regulations (Prop. 211, Prop. 218, and Prop. 219, respectively). The Agency filed the proposal under the general rulemaking provisions ofSections 27 and 28 of the Act. See 415 ILCS 5/27,28 (2008). Among other documents, a Statement ofReasons (SR) and aTechnical Support Document (TSD) accompanied theproposal. The Agency also filed a motion for waiverofcopy requirements and amotion for expedited review. In an order dated August 6, 2009, the Board accepted the Agency's proposal for hearing, granted the Agency's motion for waiverofcopy requirements, and denied the Agency's motion for expedited review. In aletter dated August 6, 2009, the Board requested thatthe Department ofCommerce and Economic Opportunity (DCEO) conduct an economic impact study ofthe Agency's rulemaking proposal. See 415 ILCS 5/27(b) (2008). DCEO has notresponded to the Board's request.In an orderdated August 12, 2009, the hearing officer scheduled a first hearing to begin on October 27, 2009, in Edwardsville and a secondhearing to begin December 8, 2009, in Chicago. The orderdirectedparticipants wishing to pre-file testimony for the first hearing to do so no later than September 15,2009. The orderalso directedparticipants to pre-file questions based onpre-filed testimony no laterthan September 29, 2008. Finally, the order directed participants whosepre-filed testimony elicitedpre-filed questions to pre-file written answers to those questions no later than October 13,2009. The order also provided thatpre-filing deadlines for the second hearing would be set at a later date. On September 14, 2009, the Agency pre-filed the testimony ofMr. David E. Bloomberg and amotion to amend its rulemaking proposal (Mot. Amend I). No otherparticipantpre-filed testimony for the first hearing, and no participantpre-filed questions based on Mr. Bloomberg's pre-filed testimony. No participantfiled aresponse to the Agency's motion to amend its rulemaking proposal. In an order dated October IS, 2009, the Board granted the Agency's motion to amend. The first hearing took place as scheduled on October27, 2009, andthe Boardreceived the transcript ofthe first heating (Tr.I) on October29,2009. During the first hearing, the hearing officer admitted into the record one exhibit, the pre-filed testimony ofMr. Bloomberg (Bloomberg Test.).
In an orderdated October28, 2009, the hearing officerdirectedparticipants wishing to pre-filetestimony for the secondhearing to do so no laterthan November 17, 2009. See Tr.1 at 25. The order also directed participants to pre-file questions based uponpre-filedtestimony no laterthan December 3, 2009. ld. No participantpre-filed testimony orquestions forthe second hearing. On December7, 2009, the Agency filed a second motion to amend its rulemaking proposal (Mot. Amend 2). Thatmotion is addressed below under "Preliminary Matter." The second hearing took place as scheduled on December 8, 2009, and the Board received the transcript ofthe second hearing (Tr.2) on December 11, 2009. No participant

### 3

offered testimony at the second hearing. See Tr.2 at 7. Regarding the Board's request that DCEO conduct an economic impact study ofthe Agency's proposal, no participantwished to offertestimony or comment. See Tr.2 at 8. In an order dated December 9, 2009, the hearing officer set a deadline ofDecember28; 2009, to filing ofpost-hearing comments. See 35 Ill. Adm. Code 102.108(b) On December28,2009, the Board received apost-hearing comment from Mr. Bruce Meerman, SeniorEnvironmental Consultant, Mostardi Platt Environmental (PC I). Filing Public Comments First-notice publication ofthese proposed mles in theIllinois Registerwill start aperiod ofatleast45 days during which any personmay file apublic comment with the Board, regardless ofwhether theperson has already filed apublic commentin this proceeding. See 5 ILCS I00/5-40(b) (2008) (l1linois Administrative ProcedureAct). Public comments must be filed with the Clerk ofthe Board atthe following address: Pollution Control Board John T. Therriault, Assistant Clerk James R. Thompson Center 100W. Randolph Street, Suite 11-500 Chicago, IL 6060I The docket number for this mlemaking, RIO-8, should be indicated on any public commentin this proceeding. Please note that all filings with the Clerkofthe Board mustbe served on the hearing

.officerand on those persons on the Service List for this rulemaking. Before filing any document with the Clerk, please cheekwiththe the Clerk's Officeto verify the current version ofthe Service List. PRELIMINARY MATTER On December7, 2009, the Agency filed a second motion to amend its rulemaking proposal. The motion seeks a single amendment to Sections 218.187 and 219.187 concerning the YOM contentofas-used cleaning solutions. Mot. Amend 2 at 1-2. Section 100.500(d) ofthe Board's procedural rules provides in pertinentpart that, "[w]ithin 14 days after service ofa motion, aparty may file a response to the motion. Ifno response is filed, theparty will be deemed to have waived objection to the granting ofthe motion, but the waiver ofobjection does notbind the Board or the hearing officerin its disposition ofthe motion." 35 HI. Adm. Code 101.500(d). No participanthas filed a response to the Agency's second motion to amend. Having reviewed the Agency's secondmotionto amend, the Board grants the motion and amends the Agency's rulemaking proposal as requested. The4

Board addresses the substance ofthe amendment in addressing Sections 218.187 and 219.187 in its summary ofthe Agency's amended proposal below. See infra at 15. 

### BACKGROUND OF FEDERAL YOM REGULATION
The Agency states that its rulemaking proposal intends to satisfy Illinois' obligation under the CAA to submit a State Implementation Plan (SIP) addressing requirements for sources ofVOM emissions in areas designated as nonattainment with the National Ambient Air.Quality Standard (NAAQS) for ozone. SR at I, citing 42 U.S.C. 

### §§ 7502, 7511a. The Agency characterizes YOM 1 as "a primary precursorto the formation ofgroundlevel ozone," which is formed when YOM reacts with oxides ofnitrogen in the atmosphere in the presence ofsunlight. SR at 2-3, citing 71 Fed. Reg. 58746 (Oct. 5,2006); see TSD at 1-2. In 1997, the United Statcs Environmental Protection Agency (USEPA) revised NAAQS for ozone by instituting an 8-hour standard. !d. at 3, citing 62 Fed. Reg. 38856 (July 18, 1997). Two Illinois areas, Chicago and St. Louis/Metro East, have been designated as moderate nonattainment areas for the 8-hourozone standard. 2 SR at 3. These nonattainment designations trigger CAA requirements "for adopting regulations thatreduce emissions sufficiently to demonstrate attainment ofthe standard." Jd. at 4, citing 42 U.S.C. 

### § 7502(c)(J); see Bloomberg Testat 3. Specifically, the Agency claims thatthe CAA requires Illinois "to submit VOC regulations constituting RACT [reasonably available control technology] for Group II Consumer and Commercial Product Categories in ozone nonattainment areas classified as moderate and above." SR at 5, citing 42 U.S.c. §§ 7502(c)(J), 751Ia(b)(2); see TSD at I. The Agency defines RACT "as the lowest emission limitation that a particular source can meetby applying a control technique that is reasonably available considering technological and economic feasibility." SR at 5, citing 44 Fed. Reg. 53762 (Sept. 17, 1979); see TSD at I, Bloomberg Test. at 3. The Agency states that "Illinois was required to submit its SIP revisions by October 5, 2007." SR at 5. The Agency states that the CAA requires thatUSEPA "conduct a study ofthe emissions ofVOC into the ambient air from consumer and commercial products in orderto determine their potential to contribute to ozone levels which violate the ozone NAAQS and to establish criteria forregulating emissions ofVOC from thoseproducts." SR at 2, citing 71 Fed. Reg. 58746 (Oct. 5,2006). The Agency further states that the CAA provides that "[t]he Administrator shall list those categories ofconsumer orcommercial products thatthe Administratordetermines, based on the study, account for at least 80percent ofthe VOC emissions

... from consumeror

1 The Agency states thatYOM and volatile organic compounds (VOC) are "effectively the same" as one another. SR at 1. 2 The Chicago nOnattainment area includes the followingjurisdictions: Cook, DuPage, Kane, Lake, McHenry, and Will Counties, Goose Lake and Aux Sable Townships in Grundy County, and Oswego Township in Kendall County. SR at 3, citing 40 C.F.R. 81.314; see TSD at 1. The St. Louis/Metro East nonattainment includes the following Illinois counties: Jersey, Madison, Monroe, and St. Clair. SR at 3, citing 40 C.F.R. 81.314; see TSD at 1.5

commercial products in areas that violate the NAAQS for ozone" and separate those categories into groups. SR at 3, citing42 U.S.C. § 7511b(e)(3)(A). The Agency claims that "[t]he CAArequires that USEPA then eitherregulate VOC emissions from such categories or issue a CTG [control technology guideline] in lieu ofa national regulation ifthe Administrator detennines that such guidance will be substantially as effective as regulations in reducing emissions ofVOC which contribute to ozone levels in ozone nonattainment areas." SR at 4, citing42 U.S.c. 

### § 751 Ib(e)(3)(C). TheAgency states that "CTGs provide states with recommendations regarding whattypes ofcontrols could constitute RACT for VOCs for the applicable source categories." SR at4, citing 71 Fed. Reg. 58745, 58747 (Oct. 5,2006). The Agency claims that "[s]tates must either adoptregulations to implement the recommendations in the CTG oradoptalternative approaches that constitute RACT, eitherofwhich must be submitted to the USEPA for review and approval as part ofthe SIP process." SR at4, citing 71 Fed. Reg. 58745, 58747 (Oct. 5,2006). 'Ille Agency states that, instead ofnational regulations controlling VOC emissions, "USEPA issued final CTGs for Group II Consumer and Commercial Product Categories" on October 5, 2006. SR at 4. The Agency further states that, in developing the CTG's, "USEPA evaluated the sources ofVOM emissions from the applicable industries, the available control possibilities to address the associated emissions, and the cost ofsuch control measures." TSD at 1. The Agency indicates that "USEPA required that states submit SIP revisions in response to the CTGs within oneyear." 

### Id., citing 71 Fed. Reg. 58745-53 (Oct. 5,2006). Specifically, the Agency states that Illinois must revise its SIP to include RACT for sources ofVOM emissions coveredby aUSEPA CTG issued betweenNovember 15, 1990 and the date ofattainment. SR at 2, citing 42 U.S.C. 

### § 7511 a(b)(2); 

### see TSD at 1, Bloomberg Test. at 3. The Agency states that "Illinois is required to submit these SIP revisions before the USEPA can redesignate the Chicago and Metro East nonattainment area as attaining the 1997 ozone NAAQS, regardless ofwhetherthe VOC reductions obtained by the SIP revisions are actually necessary to achieve attainmentofthe NAAQS." SR at 6, citingWall v. USEPA, 265 F.2d 426, 433, 440-42 (6th Cir. 2001); 42 U.S.C. 

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

### !d. The Agency argues that "[t]hese areas cannotbe redesignated to attainment ofthe ozone NAAQS, however, unless and until the Illinois EPA submits SIP revisions in response to the Group I1 CTGs and the USEPA approves such revisions." !d. The Agency claims that its proposal seeks "to implement the recommendations contained in the CTGs to the extent that such recommendations are consistent with, and impose stricterrequirements than, existing regulations." 

### Id. The Agency also notes thatUSEPA recently strengthened the eight-hourozone standard

.. SR at 7, citing 73 Fed. Reg. 16436 (Mar. 27,2008); 

### see TSD at I. TheAgency considers it "likely" that areas designated as nonattainment for the current standards will be designated nonattainmentfor the revised standard. SR at 7. TheAgency argues that "[w]hile attainment of the revised standard is not the purpose ofthis rulemaking, it should be noted that any reduction

### 6

in YOM emissions in the nonatlainment areas resulting from these proposed amendments will likely help Illinois achieve the revised NAAQS." Jd.; see TSD at 1. SUMMARY OF AGENCY'S AMENDED PROPOSAL Part 211 The Agencyproposes to amend four definitions in and add 23 new definitions to the existing Part 211,Definitions and General Provisions. SRat 11-15; see Prop. 211; seegenerally 35 

### Ill. Adm. Code 211. The Board summarizes each ofthe proposed amendments and additions separately in the subsections below. Section 211.1000: Class II Finish The Agencyproposes to add a definition of"Class 11 Finish," stating thatit is necessitated byproposed amendments to SubpartF ofParts 218 and 219. SR at 11-12; see Prop. 218 at 17-57, Prop. 219 at 17-55. The Agency's proposed definition provides in its entiretythat '''Class 11 Finish' means a finish thatmeets the specifications ofVoluntary Product Standard PS59-73, as approvcd by thc AmericanNational Standards Institute." Prop. 211 at 13. Section 211.1745: Digital Printing The Agencyproposes to add a definition of"Digital Printing," statingthat it is necessitated byproposed amendments to Sections 218.187 and 219.187. SRat 12; see Prop. 218 at 4-17, Prop. 219 at4-17. The Agency's proposed definitionprovides in its entiretythat '''Digital Printing' means, forpurposes of35 Ill. Adm. Code 218.187 and 219.187, the transfer ofelectronic files directly from a computerto an electronically driven output device thatprints the image directly on the selectcd mcdia (substrate). Printing using home and office cquipment is excluded from this definition." Prop. 211 at 13. Section 211.1878: Electrical Apparatus Component The Agency proposes to add a definition of"Electrical Apparatus Component," stating that it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 12; see Prop. 218 at4-17, Prop. 219 at4-17. The Agency's proposed definition provides in its entirety that 'Electrical Apparatus Component' means, forpurposes of35 Ill. Adm. Code 218.187 and 219.187, an internal component such as wires, windings, stators, rotors, magnets, contacts, relays, energizers, and connections in an apparatus that generates ortransmits electrical energy including, but notlimited to, alternators, generators, transformers, electric motors, cables, and circuitbreakers, except for the actual cabinet in which the components are housed. Electrical components of graphic arts application equipment and hot-line tools are also included in this category. Prop. 211 at 13-14.7

Section 211.1885: Electronic Component Section 211.1885 ofthe Board's airpollutionregulations now provides that "'Electronic Component' means, for the purposes of35 Ill. Adm. Code 218.182(f) and 219.182(f), all portions ofan clectronic assembly, including, butnotlimited to, circuit board assemblies, printed wire assemblies, printed circuitboards, solderedjoints, ground wires, bus bars, and associated electronic component manufacturing equipment such as screens and filters." 35 

## m. Adm. Code 211.1885. The Agencyproposes to amend this definition by extending its application to Sections 218.187 and 219.187 and by adding an exception for cabinetshousing components. SR at 12. As proposed by the Agency, the revised definition would provide that 'Electronic Component' means, for the purposes of35111. Adm. Code 218.182(f), 219.182(f), 218.187, and 219.187, all portions ofan electronic assembly, including, butnot limited to, circuitboard assemblies, printed wire assemblies, printed circuitboards, solderedjoints, ground wires, bus bars, and associated electronic component manufacturing equipment such as screens and filters, except for the actual cabinetin which the components are housed. See Prop. 211 at 14. The Agency states thatthese revisions are necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 12; see Prop. 218 at 4-17, Prop. 219 at4-17. Section 211.2355: FlatWood Paneling The Agencyproposes to add adefinition of"FlatWood Paneling," statingthatit is necessitated byproposed amendments to SubpartF ofParts 218 and 219. SR at 12; see Prop. 218 at 17-57, Prop. 219 at 17-55. The Agency's proposed definition provides in its entirety that "'FlatWood Paneling' means natural finish hardwoodplywood panels, hardwood panels with Class II finishes, tileboard, exteriorsiding, and printed interiorpanels made ofhardwood, plywood, orthinparticleboard." Prop. 211 at 14. Section 211.2356: FlatWood Paneling Coating Line TheAgencyproposes to add a definition of"FlatWood Paneling CoatingLine," stating thatitis necessitated byproposed amendments to SubpartF ofParts 218 and 219. SR at 12; see Prop. 218 at 17-57, Prop. 219 at 17-55. The Agency's proposed definitionprovides in its entirety that '''FlatWood Paneling Coating Line' means a coating linein which any protective, decorative, orfunctional coating is appliedto flat woodpaneling." Prop. 211 at 14. Section 211.2368: FlexiblePackaging The Agencyproposes to add a definition of"FlexiblePackaging," statingthat it is necessitatedbyproposed amendments to SubpartH ofParts 218 and 219. SR at 12; see Prop_ 218 at 57-129, Prop. 219 at 55-130. The Agency's proposed definitionprovides in its entirety that

### 8

'Flexible Packaging' means any package orpart ofapackage, the shape ofwhich can be readily changed. Flexible packagingincludes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, or any combination ofthese materials. Shrink-wrap labels or wrappers (butnot self-adhesive labels) printed on or in-line with a flexible packagingprintingpress are also considered to be flexible packaging. Flexiblepackaging does not include folding cartons, giftwraps, hot stamp foils, wall coverings, vinyl products, decorative laminates, floor coverings, ortissue products. Prop. 211 at 14. Section 211.2615: General Work Surface The Agencyproposes to add a definition of"General Work Surface," statingthat it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 12-13; see Prop. 218 at4-17, Prop. 219 at 4-17. The Agency's proposed definitionprovides in its entirety that 'General Work Surface' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, an area ofa medical device orpharmaceutical manufacturing facility where solvent cleaningis performed onwork surfaces, butfor which cleaning specifications are notrequiredto be maintained in accordance with criteria and procedures established to meetrequirements oftheUnited States Food and Drug Administration and/or otherapplicable regulatory agencies with authority over manufacturing operations for medical devices and/orpharmaceuticals. General work surfaces shall not include items definedunder 'Janitorial Cleanihg.' Prop. 211 at 14-15. Section 211.2830: Heatset Section211.2830 ofthe Board's airpollution regulations now provides that "'Heatset' means aclass oflithography whichrequires a heated dryerto solidify the printinginks." 35 Ill. Adm. Code 211.2830. TheAgencyproposed to amendthe definition "to include letterpress printing lines." SR at 13. TheAgency states thatthis revisions is necessitatedbyproposed amendments to SubpartH ofParts 218 and 219. SR at 13; see Prop. 218 at 57-129, Prop. 219 at 55-130. As proposedby the Agency, the revised definition wouldprovide in its entiretythat "'Heatset' means aclass oflithography orletterpress which requires aheated dryer to solidify the printing inks." Prop. 211 at 15. Section 211.2855: HeatsetWeb Letterpress PrintingLine The Agencyproposes to add a definition of"HeatsetWeb Letterpress Printing Line," stating thatit is necessitated byproposed amendments to Subpart H ofParts 218 and 219. SR at 13;see Prop. 218 at 57-129, Prop. 219 at 55-130. The Agency's proposed definition provides in its entiretythat "'HeatsetWeb Letterpress Printing Line' means a letterpress printing line in which a continuous roll ofsubstrate is fed through theprintingpress and an oven is used to solidifytheprinting inks." Prop. 211 at 15.

### 9

Section 211.2965: High Precision Optic The Agencyproposes to add a definition of"High Precision Optic," stating that it is necessitated by proposed amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entiretythat '''High Precision Optic' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, an optical elementused in an electro-optical device that is designed to sense, detect, or transmit light energy, including specific wavelengths oflightenergy and changes in light energy levels." Prop. 211at15, Section 211.3215: Janitorial Cleaning The Agencyproposes to add a definition of"Janitorial Cleaning," stating that it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 219 at4-17. The Agency's proposed definition provides in its entiretythat '''Janitorial Cleaning' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, the cleaning ofbuilding or facility components, including, but not limited to, floors, ceilings, walls, windows, doors, stairs, bathrooms, furnishings, and exterior surfaces ofoffice equipment, and excludes the cleaning ofwork areas where manufacturing orrepairactivity is performed." Prop. 211 at IS. Section 21 I.3305: Lettcrpress PrintingLine The Agencyproposes to add a definition of"LetterpressPrinting Line," statingthat it is necessitatedbyproposed amendments to Subpart H ofParts 218 and 219. SR at 13; see Prop. 218 at 57-129, Prop. 219 at 55-130. The Agency's proposed definition provides in its entirety that "'Letterpress PrintingLine' means aweb orsheetfed printing line that does notconstitute a flexographic printing line, in which the image area is raised relative to the non-image area and the inkis transferred to the substrate directly from the image surface." Prop. 211 at 16. Section 21,1.3555: Maintenance Cleaning The Agencyproposes to add a definition of"Maintenance Cleaning," statingthat it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 2] 9 at4-17. The Agency's proposed definitionprovides in its entirety that 'Maintenance Cleaning' means, forpurposes of35 Ill. Adm. Code 218.187 and 219.187, a solvent cleaning operation oractivity carried out to ensure that general work areas where manufacturing orrepair activity is performed remains clean, and to clean tools, machinery, molds, forms,jigs, and equipment. This definition does not include the cleaning ofcoatings, adhesives, orink application equipment.' Prop. 211 at 16. Section 2II.3705: Medical Device10

The Agency proposes to add a definition of"Medical Device," stating that it is necessitated by proposed amendments to Sections 218.187 and 219.187. SR at 13; see Prop. 218 at 4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that 'Medical Device' means, forpurposes of35 JIl. Adm. Code 218.187 and 219.1 87, an instrument, apparatus, implement, machine, contrivance, implant, in vitro reagent or other similar article, including any componentQraccessory, that meets one ormore ofthe following conditions (a) it is intended foruse in the diagnosis ofdisease or other conditions, or in the cure, mitigation, treatment, orprevention ofdisease; (b) it is intended to affect the structure orany function ofthe body; or (c) it is defined in the National Formulary orthe United Statcs Pharmacopeia, or any supplement to them. Prop. 211 at 16. Section 211.3707: Medical Device and Pharmaceutical Manufacturing The Agency proposes to add a definition of"Medical Device and Pharmaceutical Manufacturing," stating that it is necessitated by proposed amendments to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that 'Medical Device and Pharmaceutical Manufacturing' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, the collection ofequipment and activities to prepare, utilize, maintain, and repairwork areas, in order to accomplish one or more steps inpreparing a medical device orpharmaceutical for its intended·use. Manufacturing is typically, but not always, conducted in accordance with criteria and procedures established to meetrequirements ofthe United States Food and Drug Administration andlorotherapplicable regulatory agencies with authority over manufacturing operations for global sales ofmedical devices andlor pharmaceuticals. Work areas and equipment shall include all machinery, tools, equipment, rooms, tables, countertops, and facilities for maintaining employee health and safety that are subjectto such criteria andprocedures. Prop. 211 at 16- 17. Section 211.4065: Non-Heatset Section 211.4065 ofthe Board's airpollution regulations now provides that '''Nonheatse!' means a class oflithography which does not require a heated dryerto solidify the printing inks. Ultraviolet-cured and electron beam-cured inks are considered non-heatset." 35 Ill. Adm. Code 211.4065. The Agency proposes to revise this definition "to include letterpress printing lines." SR at 14. The Agency states that this revision is necessitated by proposed amendments to Subpart H ofParts 218 and 219. SR at 13; see Prop. 218 at 57-129, Prop. 219 at 55-130. As proposed by the Agency, the revised definition wouldprovide in its entirety thatII

'''Non-heatset' means a class oflithography or letterpress which does notrequire aheated dryer to solidifythe printing inks. Ultraviolet-cured and electron beam-cured inks are considered nonheatsel."Prop. 211 at 17. Section 211.5335: Radiation Effect Coating TheAgency proposes to add a definition of"Radiation Effect Coating," stating that it is necessitated byproposed**amcndment~** to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at 4-17, Prop. 219 at4-17. The Agency's proposed definitionprovides in its entirety that 'Radiation Effect Coating' means, forpurposes of35 Ill. Adm. Code 218.187 and 219.187, a coating orcoating system engineered to interact, through absorption or reflection, with specific regions ofthe electromagnetic energy spectrum, such as the ultraviolet, visible, infrared, ormicrowave regions. Uses include, but are not limited to, lightning strike prevention, electromagneticpulse protection, and radar avoidance. Coatings that have been designated 'classified' by the Department of Defense are not included in this definition. Prop. 211 at 17. Section 211.5535: Repair Cleaning The Agency proposes to add a definition of"RepairCleaning," stating thatit is necessitated by proposed amendments to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that '''RepairCleaning' means, forpurposes of35 

### 111. Adm. Code 218.187 and 219.187, a solvent cleaning operation or activity carried outduring arepair process." Prop. 211 at 17. Section 211.5585: Research and Development Operation The Agency proposes to add a definition of"Research and Development Operation," stating that it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 14;see Prop. 218 at 4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that 'Research and Development Operation' means, for purposes of35 111. Adm. Code 218.187 and 219.187, an operationwhose purpose is forresearch and development ofnew processes and products, that is conducted underthe close supervision oftechnical1y trainedpersonnel, and is notinvolved in the manufacture offinal or intermediateproducts for commercial purposes, except in a de minimus manner. Prop. 211 at 17. Section 211.5860: Scientific Instrument The Agency proposes to add a definition of"Scientific Instrument," stating that it is necessitated by proposed amendments to Sections 218.187 and219.187. SR at 14; see Prop. 218 at 4-17, Prop. 219 at4-17. The Agency's proposed definition provides in its entirety that '''Scientific Instrument' means, forpurposes of35 

### 111. Adm. Code 218.187 and 219.187, an12
instrument, including the components, assemblies, and subassemblies used in theirmanufacture, and associated accessories and reagents that is used for the detection, measurement, analysis, separation, synthesis, or sequencing ofvarious compounds." Prop. 21 I at 18. Section 211.5875: Screen Printing. The Agencyproposes to add a definition of"Screen Printing," stating that itis necessitatedby proposed amendments to Sections 218.187 and 219.187. SR at 14; see Prop. 218 at4-17, Prop. 219 at 4-17. The Agency's proposed definitionprovides in its entirety that "'Screen Printing' means, for purposes of35lll. Adm. Code 218.187 and 219.187, aprocess in which the printing inkpasses through a taught [sic] screen or fabric to which a refined form of stencil has been applied. The stencil openings determine the form and dimensions ofthe imprint." Prop. 211 at 18. Section 211.5885: Screen Reclamation The Agencyproposes to add adefinition of"Screen Reclamation," stating that it is necessitatedbyproposed amendments to Sections 218.187 and 219.187. SR at 14-15; see Prop. 218 at4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that '''Screen Reclamation' means, forpurposes of35111. Adm. Code 218.187 and 219.187, a solvent cleaning activity carried outin a screen printing operation where the screen is completely cleaned and the stencil removed for recycling orreuse ofthe screen for otherproduction runs." Prop. 211 at 18. Section 211.6405: Sterilization Indicating Ink The Agencyproposes to add a definition of"Sterilization Indicating Ink," stating that it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 218 at 4-17, Prop. 219 at4-17. The Agency's proposed definition provides in its entiretythat "'Sterilization Indicating Ink' means, for purposes of35 Ill. Adm. Code 218.187 and 219.187, an ink thatchanges colorto indicate that sterilization has occurred. Such inkis used to monitorthe sterilization ofmedical instruments, autoclave efficiency, and the thermal processing offoods for prevention ofspoilage." Prop. 211 at 18. Section 211.6425: Stripping The Agency proposes to add a definition of"Stripping," stating that it is necessitatedby proposed amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 218 at4-17, Prop. 219 at4-17. The Agency's proposed definition provides inits entirety that '''Stripping' means, for purposes of35 

### Ill. Adm. Code 218.187 and 219.187, the removal ofcured coatings, cured inks, or cured adhesives." Prop. 211 at 18. Section 211.6535: Surface Preparation The Agencyproposes to add a definition of"Surface Preparation," stating that it is necessitated byproposed amendments to Sections 218.187 and 219.187. SR at 15; see Prop. 21813

at 4-17, Prop. 219 at 4-17. The Agency's proposed definition provides in its entirety that '''Surface Preparation' means, forpurposes of35111. Adm. Code 218.187 and 219.187, the removal ofcontaminants such as dust, soil, oil, and grease prior to coating, adhesive, or ink applications." Prop. 211 at 18-19. Section 211.7290: Wood Preparation Section 211.7290 ofthe Board' airpollution regulations now provides that "'Wood furniture' means room furnishings including cabinets (kitchen, bath and vanity), tables, chairs, beds, sofas, shutters, artobjects, wood paneling, wood flooring and any other coated furnishings made ofwood, wood composition orfabricated wood materials." 35 Ill. Adm. Code 211.7920. The Agency proposed to revise thatdefinition by excluding flat woodpaneling from it. SR at 15. The Agency states that this revision is necessitated by proposed amendments to Subpart F of Parts218and219. Id.; see Prop. 218 at 17-57, Prop. 219at 17-55. As proposed by the Agency, the revised definition would provide in its entirety that "'Wood furniture' means room furnishings including cabinets (kitchen, bath, and vanity), tables, chairs, beds, sofas, shutters, art objects, wood paneling other that flat wood paneling, wood flooring, and any other coated furnishings made ofwood, wood composition, or fabricated wood materials." Prop. 211 at 19.
Part ZI8/Part 219 Subpart A: General Provisions Existing Sections 218.1 06 and 219.106 establish general compliance dates for sources subject to Parts 218 and 219. See 35111. Adm. Code 218.106,219.106. The Agency "proposes adding a new subsection (e) to Section 218.106 and a new subsection (c) to Section 219.106

... ." SR at 15; see Prop. 218 at4, Prop. 219 at 3. The Agency states that these amendments "establish May 1, 2010, as the compliance date for sources subject to the flat wood paneling emission limits." SR at 15. SubpartE: Solvent Cleaning Introduction. Existing Subpart E ofboth Parts 218 and 219 addresses YOM emissions from solvent cleaning operations. See 35 Ill. Adm. Code 218.181-186, 219.181-186. The Agency states thatindustrial cleaning solvents include a number ofproducts "used to clean dirt, soil, oil, and grease as well as remove adhesives, paints, and inks." TSD at 5 (§2.4); see Bloomberg Test. at 6. The Agency further states that "VOM emissions occur during the cleaning process while wiping, flushing, brushing, and from the storage and disposal ofused solvents and rags." TSD at 6. The Agency notes that USEPA has conducted studies ofVOM emissions focusing on six industries: "automotive, electrical equipment, magnetic tape, furniture, packaging, and photographic supplies." TSD at 6. The Agency claims thatthese studies revealed nine major categories in which cleaning processes result in YOM emissions: "spray gun cleaning, spray booth cleaning, large manufactured components cleaning, parts cleaning, equipment cleaning, line cleaning, .floor cleaning, tank cleaning, and small manufactured components cleaning." ld.14

The Agency argues that the first four account for a majority ofVOM emissions from these categories and that spray gun cleaning alone accounts for 50 percent. Id. The Agency states that the CTG nonetheless "recommends coverage ofawide range ofcleaning activities" and that its proposal reflects that recommendation. Id. The Agency emphasizes, however, thatthe proposal does not cover "[g]eneral cleaning ofoffices, bathrooms, and otherjanitorial type services." Id. Current Regulations. The Agency states that "Illinois has currentregulations for cold cleaning degreasing, open top vapor degreasing, and conveyorized degreasing operations as well as some limitations and workpractices on cleaning solvent uses in existing rules, e.g., regulations regarding autobody refinishing, wood furniture coating, and lithographic printing." TSD at 17 (§5.4). Summary ofProposed Amendments to SubpartE

.. The Agency states that its proposal follows the CTG by establishing an "applicabilitythreshold of15 pounds per day ofVOM emissions and in most ofthe required YOM limits." BloombergTest. at 6; see TSD at 17. The Agency further states that affected sources must follow workpractice standards regarding solventuse and eithercomply with a limiton the YOM content ofcleaning solution, "use a low vaporpressure cleaning solution, orutilize an emissions control system thatprovides 85 percent overall control ofVOM emissions from cleaning activities." TSD at 17; see SRat 7, Bloomberg Testat 6-7, Tr.l at 11-14 (addressing YOM content limit); seegenerally Prop. 218 at 5-17, Prop. 219 at 3-17. The Board below summarizes each ofthe Agency's proposed amendments to SubpartE on a section-by-sectionbasis. Section 218/219.181: Solvent Cleaning in General. The Agency first proposes to amend the titles ofthese two sections to "Solvent Cleaning Degreasing Operations." SR at 15- 16;see Prop. 218 at4, Prop. 219 at 3-4. The Agency also proposes to amend these two sections "to specify that Sections 218/219.182 through 218/219.184 and Section218/219.186 are applicable to coldcleaning, open top vapor, and conveyorized degreasing operations." SR at 16. Section 218/219.187: Other Industrial Solvent Cleaning Operations. The Agency proposes to add anew Section 218/219.187. SR at 16; see Prop. 218 at4-17, Prop. 219 at4-17. Below, the Board separately summarizes the subsections comprising it. Subsection (a). The Agency's proposed subsection (a)(1) establishes the section's applicability byproviding that, on and afterApril 1, 2011, "the requirements in Section 218/219.187 apply to all cleaning operations which use organic materials at sources that emit 6.8 kg/day (15 Ibs/day) ormore ofVOM from cleaning operations at the source." SR at 16; see Prop. 218 at4, Prop. 219 at4. In addition, the subsection defines "cleaningoperations" for the purposes ofthis Section as the process ofcleaning products, product components, tools, equipment, or general work areas during production, repair, maintenance, orservicing, including but not limited to spray gun cleaning, spraybooth cleaning, large and small manufactured components cleaning, parts cleaning, equipment cleaning, line15 cleaning, floor cleaning, and tanks cleaning, at sources with emission units. Prop. 218 at4, Prop. 219 at4. The Agency's proposed subsection (a)(2) "exempts numerous types ofcleaning operations from some orall ofthe limitations in Section 218/219.1 87." SR at 16; see Prop. 218 at4-7, Prop. 219 at 4-6; see also TSD at 11-12 (Exclusions). The first motion to amend states that USEPA has notified the Agency that it "may exempt digital printing from the control requirements set forth in Section 218/219.187 ofits proposal." Mot. Amend I at 1-2 ('12). The Agency rccommended amending this subsection "by adding digital printing to the list of exclusions" in Section 218/219. I87(a)(2)(C). ld. Subsection (bl. Proposed subsection (b) provides that no owner or operator ofa source subject to this section shall perform subject cleaning operations unless the source complies with one ofthreerequirements. SR at 16. First, the source may comply with the applicable YOM content limit. ld; see Prop. 218 at7-8 (proposed Section2 I8.187(b)(1 », Prop. 219 at 7-8 (proposed Section 219.187(b)(1). In the second motion to amend, the Agency responds "to a recent request for clarification from an industry representative

...." Mot. Amend 2 at 1-2 (113). Specifically, the Agency proposes to amend this subsection to provide that the YOM content limitations "applyto as-used cleaning solution, excluding water and othercompounds exempted from the definition ofYOM." ld. at 1-2. The Agency states that "[t]hisproposed amendment is consistent with the Illinois EPA's original intent and with existing YOM regulations. !d. at 2. Second, the source may comply by using "cleaning materials with a composite vapor pressure ofno more than 8.00 mmHg measured at 20 degrees Celsius." SR at 16; see Prop. 218 at 8 (proposed Section 218.187(b)(2», Prop. 219 at 8 (proposed Section 219.187(b)(2)). Third, the source can complyby installing and operating an afterburneror carbon adsorber "that reduces YOM emissions from the subject cleaning operationby at least 85 percentoverall." SR at 16; see Prop. 218 at 8 (proposed Section 218.1 87(b)(3», Prop. 219 at 8 (proposed Section 219.187(b)(3). The Agency also proposes that [t]he owneroroperator may use an emissions control system otherthan an afterburneror carbon adsorber ifsuch device reduces YOM emissions from the subject cleaning operation by at least 85 percent overall, the owner or operator submits a plan to the Agency detailing appropriate monitoring devices, test methods,recordkeeping requirements, and operating parameters for such control device, and suchplan is approved by the Agency and USEPA within federally enforceable permit conditions. Prop. 218 at 8 (proposed Section 218.187(b)(3», Prop. 219 at 8 (proposed Section 219.187(b)(3). Subsection (cl. The Agcncyproposes thatthe owner oroperator ofa subject source "shall demonstrate compliance with this Section by using the applicable test methods and procedures in Section 218/219.187(g) andby complying with all applicable recordkeeping and reporting requirements in Section 219.187(e)." SR at 16; see Prop. 218 at 8 (proposed Section 218.187(c), Prop. 219 at 8 (proposed Section 219.187(c); see also infra at 18 (summarizing subsection g); infra at 16-18 (summarizing subsection (e).16

Subsection (d). The Agency proposes thatthe owner oroperatorofa subject source must comply with various operating requirements for each subject cleaning operation. SRat 17. First, the Agency seeks to require that they "[clover open containers and properly cover and store applicators used to apply cleaning solvents." Prop. 218 at 9 (proposed Section 218.l87(d)(I)); Prop. 219 at 8 (proposed Section 219.187(d)(I); 

### see SR at 17. Second, the Agency proposes that they "[m]inimize air circulationaround the cleaning operation." Prop. 218 at9 (proposed Section 218.187(d)(2)); Prop. 219 at 8 (proposed Section 219.187(d)(2); see SR at 17. Third, the Agency seeks to require that an owner or operator "[d]ispose ofall used cleaning solutions, cleaning towcls, and applicators used to apply cleaning solvents in closed containers" Prop. 218 at 9 (proposed Section 218.187(d)(3)); Prop. 219 at 8 (proposed Section 219.I87(d)(3); 

### see SR at 17. Finally, the Agency also proposes that they "[u]tilize equipmentpractices thatminimize emissions." Prop. 218 at 9 (proposed Section 21 8.1 87(d)(4)); Prop. 219 at 8 (proposed Section 219.187(d)(4); 

### see SR at 17. Subsection (e). The Agency proposes various reeordkeeping and reporting requirements for the ownerofoperatorofvarious sources. In subsection (e)(I), the Agency proposes that, by May 1,2010, sources exempt from the limitations ofSection 218/219.187 because ofthe criteria in Section 218/219.1 87(a)(I) shall submit acertification to the Illinois EPA that includes a declaration thatthe source is exempt, as well as

. calculations which demonstrate thatcombined emissions ofVOM from cleaning

operations atthe sourcenever equal orexceed 6.8 kg/day (IS Ibs/day). SR at 17; see Prop. 218 at 9 (proposed Section 21 8.I97(e)(I)), Prop. 219 at 9 (proposed Section 219.1 87(e)(I). The proposal also requires that "[s]uch sources shall notify the Illinois EPA ofany records that show thatthe combined emissions ofYOM from cleaning operations at the source ever equal or exceed 6.8 kg/day (l5Ibs/day)." SR at 17; 

### see Prop. 218 at 9 (proposed Section 218.197(e)(I), Prop. 219 at 9 (proposed Section 219.187(e)(I). Originally, the Agency sought to require that "[s]uch notification shall include calculations showing the daily emissions ofVOM from cleaning operations at the source for the day(s) in which emissions equaled orexceeded 6.8 kg/day (l5Ibs/day)." Prop. 218 at 9, Prop. 219 at 9. In its first motion to amend, the Agency responded to comment from industryrepresentatives byproposing to remove this requirement that a sourceprovide calculations showing an exceedance. Mot. Amend I at 2**(~3).** In proposed subsection (e)(2), the Agency seeks to require subject sources to submit a certification "[b]yApril I, 20II, orupon initial start-up ofthe sourcc, whichever is later.

..." Prop. 218 at 10 (proposed Section 21 8.1 87(e)(2)(A)), Prop. 219 at 9-10 (proposed Section 219.1 87(e)(2)(A»; butsee SR at 17 (indicating deadline ofMay I, 2010). The originalproposal required that the certification include I) adeclaration that all subjectcleaning operations are in compliance with the requirements ofthis Section; 2) identification ofeach subjectcleaning operation and each VOM-eontaining cleaning solution used 

### in such operation; 3) the limitation with which each subject cleaning operation will comply, and if complying with the emissions control system requirement, what type ofemissions17

control system will be used; 4) initial documentation that, cach subject cleaning operation will comply with the applicable limitation; 5) identification ofthe method that will be used to demonstratc continuing compliance with the applicable limitations; 6) a description ofthe practices and procedures that the source will follow to ensure compliance with the limitations ofSection 218/219.187(d); and 7) a description ofeach cleaning operation exemptpursuant to Section 218/219.187(a)(2), ifany, and a listing ofthe emissionunites) on which thc exempt cleaning operation is perfonned. SRat 17-18; see Prop. 218 at 9-10 (proposed Section 218.187(e)(2)), Prop. 219 at 9-10 (proposed Section 219.187(e)(2)).
In its first motion to amend, the Agency responded to commcnt from industryrepresentatives by proposing to delete "the requirement that a subject source certify the limitation with which each subjectcleaning operation will comply." Mot. Amend I at 2-3 ('14); see Prop. 218 at 10 (proposed Section 218.187(e)(2)(A)(iii), Prop. 219 at 10 (proposcd Section 219.187(e)(2)(A)(iii); see also Tr.1 at 18-19.
In proposed subsection (e)(2)(B), the Agcncy seeks to require that subject sources, "[a]t least 30 days before changing the method ofcompliancebetwccn subsection (b)(I), (b)(2), and (b)(3) ofthis Section, notify the Agency in writing ofsuch change." Prop. 218 at 10 (proposed Section 218.187(e)(2)(B), Prop. 219 at 10 (proposed Section 219.187(e)(2)(B). In its first motion to amend, the Agency responded to comment from industry representatives by proposing to delete "the requirement that a source notify the Illinois EPA at least 30 days in advance of changing its method ofcompliance between the YOM content limitation and vaporpressure limitation." Mot. Amend 

### I at 2-3**(~4).** In subsection (e)(3), the Agency proposcs recordkeeping provisions for sources complying with the YOM content limitations undcr subsection (b)(I). SR at 18; see Prop. 218 at 11-12 (proposed Section 21 8.1 87(e)(3)), Prop. 219 at 10-12 (proposed Section 219.187(e)(3)). In subsection (e)(4), the Agency proposes recordkeeping "provisions for sources complying with the YOM compositepartial vaporpressure limitations in subsection (b)(2)

...." SRat 18; see Prop. 218 at 12 (proposed Scction 218.187(e)(4)), Prop. 219 at 12 (proposcd Section 219.187(e)(4)). In subsection (e)(5), the Agency proposes recordkeeping "provisions for sources complying with the emissions control system requirements in subsection (b)(3)

...." SRat 18; see Prop. 218 at 12-14 (proposed Section 218.187(e)(5)), Prop. 219 at 12-14 (proposed Section 219.187(e)(5)).
In subsection (e)(6), the Agency proposes that [a]1I sources subjectto the requirements ofsubsection (b) [Material and Control Requirements] and (d) [Operating Requirements] ofthis Section shall notify the Agency ofany violation ofsubscctions (b) or (d) by providing a description ofthe violation and copies ofrecords documenting such violation to the Agency within 30 days following the occurrence ofthe violation. Prop. 218 at 14 (proposed Section 21 8.1 87(e)(6)), Prop. 219 at 14 (proposed Section 219.187(e)(6)); see SR at 18.18

In subsection (e)(7), the Agency proposes that "[a]1I records requiredby this subsection (e) shall be retained by the source for at least three years and shall be made available to the Agency upon request." Prop. 218 at 14 (proposed Section 21 8.1 87(e)(7)), Prop. 219 at 14 (proposed Section 219.1 87(e)(7)); see SR at 18. Subsection (0. In subsection 

### (I), the Agency proposes to establish monitoring requirements applicableto sources demonstrating compliance with emissions control systems. SR at 18. Subsection 

### (I)(l) establishes requirements applicable to sources employing an afterburnerorcarbon adsorber to demonstrate compliance. Prop. 218 at 14 (proposed Section 218.187(1)(1 )), Prop. 219 at 14 (proposed Section 219.187(1)(1)). Subsection (1)(2) addresses emissions control systems other an afterburner or carbon adsorber. Prop. 218 at 15 (proposed Section 217.187(1)(2)), Prop. 219 at 14 (proposed Section 219.187(1)(2)). Subsectioll (gl. In subsection (g), the Agency proposes to establish "requirements regarding testing to demonstrate compliance with Section 218/219.187." SR at 19; see Prop. 218 at 15-17 (proposed Section 218.187(g)), Prop. 219 at 15-17 (proposed Section 219.187(g)). In itsfirst motion to amend, the Agency proposed to amend this subsection "by clarifying when testing pursuant to such Section shall beperformed." Mot. Amend I at 3-4**(~5).** SubpartF: Coating Operations Existing Subparts F addresses YOM emissions from various coating operations. See 35 Ill. Adm. Code 218.204-217, 219.204-217. Forthese two subparts, the Agency proposes a number ofamendments, which largely address emission from flat wood paneling coating operations. See Prop. 218 at 17-57, Prop. 219 at 17-55. Introduction. The Agency cites the CTG to state that "[fllat wood panelingproducts arc used in construction and can be classified as three mainproduct types: decorative interior panels, exterior siding, and tileboard." TSD at 6 (§2.5), citing Control Techniques Guidelines forFlatWood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standard, September2006. The Agency states that "[d]ecorative interior panels are often embossed and usually grooved, having more decorative coatingrequirements than many otherproducts." TSD at 6. Forthesepanels, the Agency indicates that "[s]ubstrates include hardwood, plywood, medium density fiberboard, andparticleboard." Jd. Withregard to exterior siding, the Agency states that it "maybe coated at theproduction facility oron-site." TSD at 6. TheAgency indicates thaton-site coating "is not subjectto this proposed regulation." 

### Id. The Agency further states that, in addition to siding, "[e]xteriortrim is also generally manufactured at the same production facility and coated with the same coatings." In the classification, the Agency lists substrates including solid wood, hardboard, and waferboard. 

### Id. Withregard to tileboard, the Agency indicates that it "is used onhigh-moisture areas such as kitchens and bathrooms, and is considered apremium interior wall paneling." TSD at 6. The Agency states that "[t]ileboard meets the specifications for Class I hardboard according to the American National Standards Institute." Jd.19

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

atypical flat wood coating facility applies stains and varnishes to natural plywood panels used for wall coverings. Otherplants print wood grain patterns on particle board panels that were first undercoated with an opaque coating to mask the original surface. Coatings applied to flat wood surfaces include fillers, sealers, 'groove' coats, primers, stains, basecoats, inks and topcoats. TSD at 6, citing Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental ProtectionAgency, Office ofAir Quality Planning and Standard, September 2006. Addressing methods and techniques, the Agency cites the CTG to state that coating line processes typicallybegin "with mechanical alterations ofthe substrate (filing ofholes, cutting of grooves, sanding, etc.)

... TSD at 7, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAirQuality Planning and Standard, September2006. Following this step, [m]ostcoatings are applied by directroll coating. Filler is usually applied by reverse rol1 coating. The offsetrotogravure process is used where the coaling and printing operation requires precisionprinting techniques. Other coating methods include spray techniques, brush coating and curtain coating. A typical flat wood paneling coating line includes a succession ofcoating operations. Each individual operation consists ofthe application ofone ormore coatings fol1owed by aheated oven to cure the coatings. TSD at 7, citing Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental ProtectionAgency, Office ofAir QualityPlanning and Standard, September 2006. The Agency states that, during these operations, "YOM emissions occurprimarily during the coatingprocess as the coatings dry and cure, butalso as coatings are applied, and during mixture before application." TSD at7. Current RegUlations. The Agency states that "[t]here are currentlyno specific Illinois regulations covering flat woodpaneling coating operations." TSD at 17 (§5.5), BloombergTest. at 7. The Agency argues that these operations would be addressed by regulations applicable to "OtherEmission Units" (35 Ill. Adm. Code 218.980-988, 219.980-988) and possiblyby regulations applicable to wood furniture coating 

### (see 35 

### Il1. Adm. Code 218.204(1), 219.204(1)), "depending on whetherthe operations fell into the definition related to thatprocess." TSD at 17; 

### see Bloomberg Test. at 7. 

### Summary ofProposed Amendments'to SubpartF. The Agency states that its proposed amendments to SubpartF "will add coating YOM requirements and workpractice requirements for both coatings and associated cleaning operations." TSD at 17; see Prop. 218 at 17-57, Prop. 219 at 17-55, SR at 7-8. Althoughthe Agency notes the option ofemploying addon emission controls, it adds that "the flat wood paneling coating category will require an overall20

control of90 percentrather than the 81 percentoverall control required for existing coating categories." TSD at 18. The Agency claims that "[t]he workpractice requirements include several that are already required for wood furniture coaters, which have been accomplished without any problems known to the Agency." Id.; see Bloomberg Test. at 7. The Agency characterizes as "common sense" such requirements as "minimizing spills ofVOM-containing materials, minimizing YOM emissions during cleaning, and closing mixing vessels except when they are in use." !d. The Board below summarizes on a section-by-sectionbasis each ofthe Agency's proposed amendments to SubpartF. Section 218/219.204: Emission Limitations. Existing Section 218/219.204 establishes emission limitations based upon YOM content for various categories ofcoating lines. 35 Ill. Adm. Code 218.204, 219.204. The Board below separately summarizes the Agency's proposed amendments to these provisions. See Prop. 218 at 17-27, Prop. 219 at 17-26. Subsection Ccl. Existing subsection (c), which provides emission limitations applicable to paper coating lines, includes anote stating in pertinent part that "[t]he papercoating limitation shall not apply to any owneroroperator ofanypaper coating line on which flexographic or rotogravure printing is performed ifthe paper coating line complies with the emissions limitation in Section 218.401 ofthis Part." 35 Ill. Adm. Code 218.204(c), 219.204(c). The Agency proposes to amend this subsectionbyproviding that the limitation also "shall not apply to any owneroroperatorofapapercoating line on which lithographic orletterpress printing is performed ifthe papercoating line complies with the applicable emissions limitations in Subpart H ofthis Part." SR at 19; see 35 

### I1l. Adm. Code 218.401-411, 219.401-411 (Subparts H), Prop. 218 at 19, Prop. 219 at 19.
Subsection Col/Co). The Agency proposes to add a new subsection (p) to Section 218.204 and anew subsection (0) to Section 219.204, both of"which restrictthe YOM contentofflat wood paneling coatings to 0.25 kg VOM/l coatings or 0.35 kg VOMII solids orless. SR at 19; see Prop. 218 at 27, Prop. 219 at 26. Section 218/219.205: Daily-Weighted Average Limitations. Existing Section 218/219.205 contains provisions for daily-weighted average limitations on YOM content. 35 

## m. Adm. Code 218.105, 219.105. The Agencyproposes to amend subsection (a) "toinclude flat wood paneling coating lines in the daily-weighted averaging alternative." SR at 19; see Prop. 218 at28, Prop. 219 at 26-27. Section 218/219.207: Alternative Emission Limitations. Existing Section 218/219.207 contains provisions for alternative emission limitations. 35 ll1. Adm. Code 218.107,219.1 07. The Board below separately summarizes the Agency's proposed amendments to these provisions. See Prop. 218 at 33-37, Prop. 219 at 31-36. Subsection Cal. The Agency proposes to amend this subsection to include flat wood paneling coating lines as a source category eligible for the alternative emission limitations option. SR at 19; see Prop. 218 at 33, Prop. 219 at 31-32.21



### Subsection Oli. The Agency proposes to amend Section 218.207(h)(1) in order to correct the formatting ofan equation pertainingto emissions from can coating lines. SR at20; 

### see Prop. 218at36. 

### Subsection (l), 

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

### see Prop. 218 at 37, Prop. 219 at 35-36. Theseproposed subsections "provide that a flat wood paneling coating line may utilize a capture system and control device ifsuch system provides at least 90 reduction in the overall emissions ofVOM from the coating line orthe owner or operator ofthe flat wood paneling coating line complies with all requirements set forth in subsection (b)(2) ofthis Section." SR at 19; 

### see Prop. 218 at37, Prop. 219 at 35-36. Section 218/219.210: Compliance Schedule. Section 218/219.210 establishes compliance schedules applicable to various coating lines. 35 

### I1l. Adm. Code 218.210, 219.210. The Agency proposed to amend these sections by adding a subsection (g) providing that, on and after a date consistent with Section 218/219.206, sources subject to the flat wood paneling coating emission limitations shall comply with the applicable provisions in Subpart F." SR at 20;

### see Prop. 218 at 39, Prop. 219 at 37. Section 218.211/219.211: Recordkeellinl! and Reporting. Existing Section 218/219.211 contains various recordkeeping and reporting requirements. 35 Ill. Adm. Code 218.111,219.111. The Board below separately summarizes the Agency's proposed amendments to theseprovisions. 

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

### Subsections (eI, 

### Cdl. The Agency proposes to amend these subsections "to provide that, for flat woodpaneling coating lines, YOM content information shall be maintained and/or reported in terms ofweight ofVOM pervolume ofcoatings or solids, as applicable, as applied each day on each coatingline." SR at20; 

### see Prop. 218 at42-46, Prop. 219 at40-44. The Agency also proposed to correct a spelling errorin Section 218:21 I(c)(3)(A). SR at 20; 

### see Prop. 218 at43

.. 

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

### see Prop. 218 at46-47, Prop. 219 at44-45. 

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

### see Prop. 218 at49-50, Prop. 219 at 48. Section 218.212/219.212: Cross-Line Averaging to Establish Compliance 

### for Coating Lines. Existing Section 218/219.212 contains provision for averaging across specified coating lines in orderto establish compliance. 35 Ill. Adm. Code 218.212, 219.212. The22 Agency proposes to amend subsection (a) "to provide that the cross-line averaging alternative is not available to flat wood paneling coating lines." SR at 21; see Prop. 218 at 50-54, Prop. 219 at 48-53. Section 218.217/219.217: Wood Furniture Coating Work Practice Standards. Existing Section 218/219.217 establishes various workpractice standards for wood furniture coating operations. 35 Ill. Adm. Code 218.217, 219.217. The Agency first proposes to change the title ofthis Section to "Wood Furniture Coating andFlatWood Paneling CoatingWork Practice Standards." SR at 21; see Prop. 218 at 54, Prop. 219 at 53. The Board below separately summarizes the Agency's proposed amendments to theprovisions ofthese sections. See Prop. 218 at 54-57, Prop. 219 at 53-55 Subsectio/l (cl. In this re-designated subsection, the Agency proposes an amendment providing that "the flat woodpaneling coating lines are subject to the existing cleaning and work practice requirements in this Section." SR at 21; see Prop. 218 at 55-56, Prop. 219 at 54. Subsectio/l (dl. The Agency proposes anew subsection "adding additional cleaning and storage requirements for flat wood paneling coating lines

...." SR at 21; see Prop. 218 at 56, Prop. 219 at 54-55. Specifically, the Agency proposes to require "that such coating lines minimize spills ofYOM containing coatings, thinners, and cleaners, minimize emissions of YOM during cleanin·g activities, and keep mixing vessels which contain YOM coatings and other materials closed except when specifically in use." SR at 21; see Prop. 218 at 56, Prop. 219 at 54. Subpart H: Printing and Publishing Existing Subparts H address YOM emissions from various printing and publishing sources. See 35 Ill. Adm. Code 218.401-4II, 219.401-411. Forthese two subparts, the Agency proposes anumber ofamendments and the addition ofnew subsections addressing letterpress printing lines. See Prop. 218 at 57-129, Prop. 219 at 55-130. l11e Board separately addresses these amendments and additions in the following subsections ofthis opinion. Flexographic and Rotogravure Printing. I/ltroductiO/l. The Agency states that "[f1lcxiblepackaging means any package orpartof apackage, the shape ofwhich can be readily changed." TSD at4. The Agency further states that this packaging "includes, but is not limited to, bags, pouches, liners, and wraps utilizing paper, plastic, film, aluminum foil, metalized orcoatcdpaperor film, orany combination of these matcrials." !d. TheAgency also indicates that "[s]hrink-wrap labels orwrappers (but not sclf-adhesive labels) printed onorin-line with a flexible packaging printing press are also considered to be flexible packaging." !d. The Agency states, however, thatthe following items are not flexible packaging: "cartons, giftwraps, hot stamp foils, wall coverings, vinylproducts, decorative laminates, floor coverings, ortissue products." !d. at 5. The Agency characterizes rotogravure printing as using "an image etched or engraved into a plate or cylinder." TSD at 5. The Agency states that "[i]nks, coatings, and adhesives may be applied to a substrate through the rotogravure process." !d. The Agency describes23 flexographic printing as the use of"an image raised above the level ofthe printing plate, with the image carrier made oflUbber or othcr flexible material." ld. The Agency distinguishes the two in partby stating that "[fjlexographic printing is better suited to shortproduction IUns, in contrast to rotogravureprinting, which is more useful for long runs." 

### Id. The Agency claims that "YOM emissions for both typcs ofprinting originate from the drying ofinks as well as solvents uscd to clean presses and othercomponents." 

### Id. The Agency cites the CTG to state that "the use ofwater based inks is increasing." TSD at 5, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. However, the Agency also notes that "[m]any facilities use hundreds ofdifferent inks to print various custom colors required by theirpackaging customers. Low [YOM] inks, coatings, and adhesives may not be available to mcct all ofthe perfomlance requirements." TSD at 5, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir QualityPlanning and Standards, Septcmber 2006. The Agency thus states that "mostYOM control for flexible package printing is achieved through the use ofadd-on control devices." TSD at 5. The Agency indicates that most ofthe YOM emitted through these processes "is captured through evaporation in a dryer, along with hoods and other collection devices for solventthat evaporates elsewhere in the printing process." 

### !d. The Agency claims that 

### "[0]lderpresses frequently do not allow for the same level ofcapture as newerinstallations do." 

### Id. Howevcr, the Agency cites the CTG to claim that '''[t]here have been significantimprovements in capture efficiency offlexographic presses and rotogravure presses' since USEPA's most recent review ofthose operations." 

### Id., citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAirQuality Planning and Standards, September2006. The Agency further cites the CTG to statethat, "[s]ince 1990, many vendors have guaranteed capture efficiency of85 to 90 percent withoutuse ofa permanent total enclosure." TSD at 5, citing Control Techniques Guidelines forFlexible Packaging Printing, United States EnvironmentalProtection Agency, Office ofAirQuality Planning and Standards, September2006. The Agency argues thatcontrol devices cannow attain control efficiencies ofat least 95 percent." TSD at 5, citing Control Techniques Guidelines forFlexible Packaging Printing, United States Environmental Protection Agency, Office ofAir QualityPlanning and Standards, September 2006. CurrelltRegulatiolls. The Agency states that Illinois regulations currently "cover all flexographic, packaging rotogravure, and publication rotogravureprinting." TSD at 4, 17 (§§2.3, 5.3). The Agency further states that these differentprinting operations have identical YOM content limits on ink butdiffer in their add-on control requirements: "flexographic printers are required to get 60 percent overall YOM reduction, packaging rotogravure are required to get 65 percent overall reductions, and publication rotogravure must achieve 75 percent overall reduction." 

### Id.; see 35111. Adm. Code 218.401(a)(l), (c)(4), 2l9.401(a)(1), (c)(4). Summary o(ProposedAmelldmelltsAddressillgFlexograpllic amIRotogravure Prilltillg. The Agency states that its proposal "separates out flexible packagingprinting from the existing flexographic and rotogravure regulations." TSD at 17; see id. at4, Bloomberg Test. at

### 24
5; seegenerally Prop. 218 at 57-76, Prop. 219 at 55-75. The Agency argues that "any flexographic or rotogravure operation that is notprinting on flexible packaging will not see a change to the applicable regulations." Jd. The Agency indicates, however, that "[s]ources that print on flexible packaging will need to meet either atightened ink YOM content oradd-on control requirement." Jd.; see SR at 8. The Agency states that the required efficiency ofthe addon control "will depend on both the date ofconstruction, at the source, ofthe press and the control device." TSD at 17; see Bloomberg Test. at 6. The Agency claims that these factors reflect "thatpresses and control devices already installed at the source might not have been designed to obtain capture and control efficiencies as high as are currently obtainable." TSD at 17. The Agency thus suggests that sources should not need to upgradc cxisting control devices. Tr.latI5-16. The Agency states that "[t]heproposed regulations also require thatprinting lines that meet the CTG's prescribed applicability threshold comply with work practice requirements for cleaning materials." TSD at 5; see Bloomberg Test. at 6. The Agency further states that these practices include "keeping solvent containers closed exceptwhen filling, draining or conducting cleaning operations, keeping used shop towels in closed containers, and conveying cleaning materials from one location to another in closed containers orpipes." TSD at 17, citing Control Techniques Guidelines for Flexible Packaging Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September2006. The Agency stresses that "the applicability level for such workpractices in much lower, at 15 pounds per day, as compared to the applicability thresholds of25 tons peryearpotential to emitor 100 tons peryear maximum theoretical emissions for the remainderofthe rule." Bloomberg Test. at 6. 

### Sectioll 218.401/219.401: Flexograpltic alldRotogravurePrilltillg. Existing Section 218/219.401 addresses YOM emissions from flexographic and rotogravure printing. 35 111. Adm. Code 218.401,219.401. The Agency proposes to amend this provision "to separate the requirements that are applicable priorto the new compliance date from those applicable after thc new compliance date. SR at 21. Below, the Board summarizes those proposed amendments on a subsection-by-subsection basis. 

### Subsectioll (a). The Agency proposes to amend this subsection to require that, "on and afterMay I, 20I0, owners and operators offlexographic and rotogravure printing lines that do notprintflexible packaging and that are complying with subsection (a) shall comply with the existing YOM regulations." SRat 21; see Prop. 218 at 57, Prop. 219 at55-56. The Agency seeks also to require that "[o]wners and operators offlexographic and**rotogra~re** printing lines thatprint flexible packaging orthatprint flexible packaging and non-flexible packaging on the same line shall restrict the YOM content ofcoatings and inks to .8 kg YOM/kg solids applied or .16 kg VOM/kg materials applied or less." SR at 21-22; 

### see Prop. 

## i 18 at 57-58, Prop. 219 at 56. 

### Subsectioll (b). The Agency proposes to amend this subsection to require that, "on and afterMay 1,2010, owners and operators offlexographic and rotogravure printing lines that do notprint flexible packaging and that are complying with subsection (b) shall comply with the existing weighted averaging requirements." SR at 22; see Prop. 218 at 58-62, Prop. 219 at 56-

.61. The Agency also seeks to require that25
[0]wncrs and operators offlexographic and rotogravure printing lines thatprint flexible packaging, or thatprint flexible packaging and non-flcxiblepackaging on the same line, and that are complying with subsection (b) shall not apply coatings or inks on the subjectprinting line unless the wcighted averagc, by weight, YOM content ofall coatings and inks as applied each day on the subjectprinting line docs not exceed the YOM limitations specified in the amendments to subsection (a) ofthis Scction, SR at 22; see Prop, 218 at 58-62, Prop, 219 at 56-61. The Agency also proposes specific "equations for calculating the weighted average YOM content for such lines," SR at 22; see Prop, 218 at 58-62, Prop, 219 at 56-61. Finally, thc Agencyproposes a number ofnon-substantive corrcctions to the cxisting language, See SR at 22, 

### Subsection (c), The Agencyproposes to amcnd this subsection to require that, "on and afterMay 1,20I0, the owner or operator ofa flexographic orrotogravure printing line that does notprint flexible packaging and that is complying with subsection (c) shall equip the printing line with a capture systcm and control dcvice that complies with the existing control efficiency requirements," SR at 22; see Prop, 218 at 62-65, Prop, 219 at 61-64, The Agency seeks also to amend this provisionbyrequiring that "[t]he owneroroperator ofa flcxographic orrotogravure printing linethatprints flexible packaging shall equip theprinting line with a capture system and control device thatprovides an overall reduction in YOM emissions of65-80 percent, depending on the dates that the printing line and control system were first constructed at the subject source," SR at 22-23; see Prop, 218 at 62-65, Prop, 219 at 61-64, The Agency also proposes to require that "[t]he owner or operator ofa flexographic orrotogravureprinting line that prints flexible packaging and non-flexible packaging on the same line shall comply withthe overall control efficiency requirements setforth in either [proposed] subsection (c)(l)(D) or [proposed] subsection (c)(3) ofthis Section, whicheveris more stringent." SR at 23, see Prop, 218 at 62-65, Prop, 219 at 61-64, The Agency also proposes to amend subsection (c)(6) "to specify the printing lines that are required to perfonn testing pursuant to this subsection," SR at23; 

### see Prop, 218 at 64-65, Prop, 219 at 63-64, 

### Subsection (d), The Agency seeks to add anew subsection (d), The Agcncyproposes "that YOM-containing cleaning materials associated with flexographic orrotogravure printing lines that print flexible packaging orprint flexible packaging and non-flexible packaging on the same line shall be kept, stored, and disposed ofin closed containers, and conveycd from one location to another in closed containers orpipes," SR at 23; 

### see Prop, 218 at 65, Prop, 219 at 64, 

### Section 218.402/219.402: Applicability. Existing Section 218/219,402 addresses applicability ofvarious requirements to flexographic and rotogravure printing lines. 35 

### III. Adm. Code 218.402, 219.402. The Agencyproposes to add this section a subsection (b) providing that the limitations ofSection 218/219.401 (d) apply to all flexographic and rotogravureprinting lines thatprint flcxible packaging orprint flexible packaging and non-flexiblepackaging on the same line at sources where the combined26

emissions ofVOM from all flexographie and rotogravure printing lines total 6.8 kg/day (15 Ibs/day) or more, in the absence ofairpollution control equipment. SR at 23; 

### see Prop. 218 at 66, Prop. 219 at 65. 

### Sectioll 218.403/219.403: Compliallce Schedule. Existing Section 218/219.403 establishes acompliance schedule for owners and operators ofvarious flexographic and rotogravure printing lines. 35 Ill. Adm. Code 218.403, 219.403. TheAgency proposes to add subsections (e), (I), and (g) to "establish May 1,2010, as the compliance date for the requirements set forth in theproposed amendments." SR at 23; 

### see Prop. 218 at 67-68, Prop. 219 at 66. 

### Sectioll 218.404/219.404: Recordkeepillf! alldReportillg. Existing Section 218/219.404 addresses recordkeeping and reporting requirements applicable to various printing lines. 35 Ill. Adm. Code 218.404, 219.404. The Board below separately addresses those amendments on a subseciion-by-subsectionbasis. 

### Subsectioll (b). The Agency proposes to amend the section to referto "recordkeeping and reporting compliance dates for printing lines subjectto the limitations in the proposed amendments to Section 218/219.401." SR at 24; 

### see Prop. 218 at 68-70, Prop. 219 at 67-69. In its first motion to amend, the Agencyresponded to a request from industry representatives by proposing to amend subsection (b)(1)(B) "by deleting references to instruments by which owner[s] or operators may calculate the volume or weightofcoatings and inks as applied each day on subject coating lines, as such instrumentation is not currently available to sources." Mot. Amend I at4-5 ("6); 

### see Tr.1 at 19-20. 

### Subsectiolls (c), (d). The Agency proposes to amend subsections (c) and (d) "to clarify thatthe owner oroperator ofaprinting line subject to the requirements in Section 2181219.401 (a)(2)(B)or (b)(3) shall certify in accordance with subsection (c)(1) or (d)(l), as applicable, even ifthe owner oroperator ofsuch line submitted acertification prior to January I, 2010." SR at24; 

### see Prop. 218 at70-73, Prop. 219 at 69-72. In its first motion to amend, the Agency responded to a request from industryrepresentatives byproposing to amend subsection (d)(1)(D) "by deleting references to instruments by which owner[s] or operators may calculate the volume or weightofcoatings and inks as applied each day on subject coating lines, as such instrumentation is not currently available to sources." Mot. Amend I at4-5**(~6);** 

### see Tr.l at 19- 20. 

### Subsectioll (e). The Agency proposes to amend subsection (e) "to provide that ifthe owner oroperator ofaprinting line is notrequired to perform testing ofa capture system and control device pursuant to Section 218/219/401(c)(6), the owner oroperator shall submita certification to the Agency that includes specified information" listed in proposed subsection (e)(1)(B). SRat 24; 

### see Prop. 218 at 73-74, Prop. 219 at 72-73. TIle Agency also proposes to add anew subsection (e)(4) providing that, "byMay I, 2010, owners or operators ofprinting lines subject to Section 21 8/2I9.401(c)(3) or (c)(4) shall submit to the Illinois EPA records documenting the dates each subjectprinting line and control device were constructed at the subject source." SRat 24; 

### see Prop. 218 at 75, Prop. 219 at 74.27

Subsectioll (f). The Agency also proposes to add a new subsection (I) to establish "recordkeeping and reporting requirements for any owneror operator ofa flexographic or rotogravure printing line that prints flexible packaging orprints flexible packaging and nonflexible packaging on the same line and which is exempt from the limitations ofSection 218/219.401 (d) because ofthe criteria in Section 218/219.402(b)." SR at24; see Prop. 218 at 75-76, Prop. 219 at 74-75. In its first motion to amend, the Agencyresponds to comment from industry representatives by proposing to remove from subsection (1)(2) "the requirement thata source include in its notification to the Il1inois EPA calculations showing an exceedance ofthe applicability threshold." Mol. Amend I at 5-6**(~7).** Subsectioll (g). The Agency also proposes to add a new subsection (g) to establish "recordkeeping and reporting requirements for any owneroroperator ofaprinting line subject to the limitations ofSection 218/219.40I(d)," which addresses YOM-containing cleaning materials. SR at24-25; see Prop. 218 at 76, Prop. 219 at 75. Subsectioll ("). The Agency also proposes to add a new subsection (h) providing in its entiretythat "[a]1I records required by subsections (I) and (g) shall be retained for at least three years and shall be made available to the Agency upon request" Prop. 218 at 76, Prop. 219 at 75; see SR at25. Lithographic Printing. IlItroductiO/l. The Agency states that "[I]ithography is aplanographic method of printing; that is, the printing and nonprinting areas are essentially in the sameplane on the surface ofa thin 'lithographic' plate." TSD at 3. The Agency further states thatthe two areas are distinguished chemicallyby rendering the image area waterrepellent and the nonimage area waterreceptive." Id. The Agency describes the catcgory ofoffset lithographic printing: "inkis transferred from the lithographicplate to arubber-covered 'intermediate' or 'blanket' cylinderand then to the substrate." TSD at 3. The Agency states that this "[t]ransferofthe ink from the lithographic plate to the blanket cYlinder, rather than directly to the substrate, is the offset characteristic of this type ofprinting." /d. The Agency states that offset lithographic printing itselfcanbe categorized by the manner in which the substrate is fed to thepress. TSD at 3. The Agency indicates that, "[i]n sheet-fed printing, individual sheets ofpaper orothersubstrate are fed to the press. In web printing, continuous rolls ofpaperare fed to the press and thepaperis cut to size afterit is printed." ld. The Agency states thatpigments, vehicles, binders, and other additives comprise lithographic inks. TSD at 3. The Agency further states that pigments includeboth organic and inorganic materials. Id. The Agency indicates that "[l]ithographic inks maybe heatset, where heat is required to set the ink, ornon-heatset, where the inks are setby absorption into the substrate by oxidation orothermethods not requiring added heat" ld. The Agency claims that28
"[h]eatset inks may contain up to 45 percentVOMs." Jd. The Agency also lists the characteristics ofnon-heatset inks: higherboiling points, less pastiness, and usually less than 35 percent YOM content. ld. The Agency also states that "[m]ost non-heatset inks used in sheetfed printing are below 25 percent VOM." Jd. The Agency states thatprinting operations apply a fountain solution to alithographic plate to rendernonimage areas unreceptive to ink. TSD at 3. TheAgency further states that, "[s]inceprinting inks are oil-based and oil is repelled by water, the fountain solution is waterbased." ld. The Agency indicates that·these fountain solutions also contain "small quantities of gum arabic or synthetic resins, acids, and buffer slats to maintain the pH ofthe solution, and a wetting agcnt or 'dampening aid' to enhance the spreadability ofthe fountain solution across the printplate." ld. The Agency states thatthe dampening aid reduces the surface tension ofwater and increases viscosity. Jd. The Agency states that, since the 1950s, isopropyl alcohol, a YOM, "has been used as the primary dampening aid." TSD at 3. The Agency further states that "[c]thanol and normal propyl alcohol have also been used in this capacity" ld. The Agency indicates that, "[b]efore the 1980s, concentration ofalcohol in the fountain solution couldrange from 0 to 35 percent or higher, with mostpresses using between 15 and 20 percent." ld. The Agency argues that printers have since reduced the alcohol content offountain solution and have "often replaced alcohol completely with other dampening aids." !d. at 4. The Agency states thatprinters use cleaning solutions "to removc cxcess printinginks, oils, and papcrcomponents from press equipment" and also "to washtheblankets, the rollers, the outside ofthepresses, and to remove excess inkresiduebetween color changcs." TSD at4. The Agency further states that these "solutions arepetroleum-based solvents, often mixed with detergent and/orwater." Jd. The Agency indicates that "[t]he cleaning compound may be a single solvent, such as kerosene, or a combination ofsolvents." ld. CurrelltRegulatiolls. The Agency states that Illinois now "has regulations covering all types oflithographic printing in the NAAs, with an applicability level of100 PPD (calculated monthly). In addition, there is a secondary applicability level of100 tons peryear ofmaximum theoretical emissions for heatsetweb lithographic printing, which was carried over from the previous rule." TSD at 15. Regarding fountain solution, the Agency states that currentregulations applicable to heatset web presses in the two NAAs "require that subject sources use no more than 1.6 percent alcohol, or.3 percent ifthe fountain solutionis refrigerated." TSD at4; see 35 Ill. Adm. Code 218.407(a)(I)(A)(i), (ii); 219.407(a)(I)(A)(i), (ii). The Agency further states that "fountain solution using only alcohol substitutes may use up to 5 percentVOM." TSD at4; see 35 Ill. Adm. Code 218.407(a)(1)(A)(iii), 219.407(a)(1 )(A)(iii). The Agency also states that "[n]onheatset web presses cannot usc any alcohol and are subject to the same 5percent YOM limit." TSD at4; see 35 Ill. Adm. Code 218.407(a)(2), 219.407(a)(2). Finally, "[s]heet-fed presses are limited to 5 percent YOM contentor 8.5 percent ifthe solution is refrigerated." TSD at4; see 

### 35 Ill. Adm. Code 218.407(a)(3), 219.407(a)(3).

### 29
Summary of ProposedAmelldmelltsAddressing LithographicPrilltillg. The Agency states that its "proposal does notreduce the applicability threshold for add-on control devices used byheatsetpresses." TSD at 15. The Agency thus argues that "no new lithographic printing units will need to add controls." fri.; see SR at 8. The Agency indicates, however, that "new control devices on heatset web lithographic presses will need to meet a 95 percent control efficiency instead ofthe current 90 percent limit." TSD at 15; see Bloomberg Test. at 3. The Agency exprcsscs the beliefthat "control devices in existence today can meet the 95 percent limit, but at the request ofprinting industryrepresentatives, the Agency has agreed notto ask existing sources to meetthe higher control efficiency." TSD at 15; see TLI at 14-15. The Agency states that its proposal establishes "a new applicability threshold of15 PPD for fountain solution and cleaning solution requirements for all lithographic printing operations." TSD at 15; see Bloomberg Test. at 3. The Agency further states that "[t]he requirements are the same as are already present in the Illinois regulations, other than a correction to the fountain solution limits that changes their measurement from 'by volume' to 'by weight.'" Jd. The Agency emphasizes that "sources between 15 and 100 PPD will be able to take advantage ofseveral new exclusions pertaining to fountain and cleaning solutions" TSD at 15. The Agency states that "[s]heet-fcd presses thatprint substrates no larger than II inches by 17 inches and any lithographic press with a fountain solution reservoir ofno largerthan one gallon are not required to comply with the fountain solution requirements." ld.; see Bloomberg Test. at 4. TheAgency further states that "sources inthis [] 5 to 100 PPD] group will also needto meet only a 70 percentYOM content limit in cleaning solutions ratherthan the 30 percent limit that is applicable to sources over ]00 PPD." TSD at 15. Finally, the Agency also states that "[a]ll such sources will also be able to use up to I00 gallons ofcleaning solutionperyearthat do not meet eitherthe YOM contentorvaporpressure requirements." fri. at 15-16. The Agency states that, "[b]ecause ofthe new exclusions thatapply onlybetween 15 and 100 PPD, even subject sources in this group must continue to calculate emissions to ensure they do not excecd the 100 PPD thrcshold and lose the exclusions." TSD at 16. The Agency furthcr states that "[s]ources may opt outofthe exclusions ifthey do notwish to make use ofthem, and thus would notneed to calculate emissions in this fashion." fri.; see Bloomberg Test. at 4. TheAgency states that "[s]ources which fall below one ofthe applicability limits, and are thus exempt from one ormore control requirements, mustcertifythis exemption to the Illinois EPA through calculations showing thattheiremissions will notexceed the applicable YOM threshold." TSD at 16. TheAgency further states that "[t]hese calculations must include all YOM emissions, including inks, fountain solution, and cleaning solvents, and are determined on amonthly basis." fri. The Agency emphasizes that currentregulations recognize "thatthe substrate retains some ofthe YOM present in the ink, and this a retention factor of0.95 is used when calculating emissions from non-heatset inks, and a factor of0.20 is used when calculating emissions from heatset inks." TSD at 16; see Bloomberg Test. at 4. The Agency notes that currcntregulations also contain "a factor recognizing that YOM remains on solvent-laden rags that are stored and disposed ofproperly." TSD at 16; see Bloomberg Test. at 4. The Agency states that "[t]hese30

factors continue to be allowed for determination ofapplicability" TSD at 16, The Agency also notes that its "proposal adds emission adjustment factors to be used in other situations when not determining applicability (such as Annual Emissions Reports and permit limits)," 

### lei. The Agency claims that "[t]hese factors take into account carryover ofVOM from automatic blanket wash and fountain solutions into the dryer and control device." !d" citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006; see Bloomberg Test. at 5, Sectioll 218.405/219.405: LithographicPrilltillg: Applicability. Existing Section 218/2190405 addresses applicability ofvarious provisions to lithographic printing operations, 35 111, Adm, Code 2180405, 2190405, The Boardbelow separately addresses those amendments On a subsection-by-subsection basis, Subsectiolls (a), (b). The Agency firstproposes "to separate requirements that are applicable prior to the new compliance date from those applicable afterthe new compliance date," SR at 25; see Prop. 218 at 76-79, Prop. 219 at 75-78, The Agency also seeks to delete the current subsection (a), which establishes "requirements that were only applicable until March 15, 1996, and reformatting/renumbering the remaining subsections accordingly." SR at 25; see Prop, 218 at 76-79, Prop, 219 at 75-78, Subsectioll (c). TheAgency proposes to add a new subsection (c)(1) providing that, on and afterMay 1,2010, the requirements in Section 21 8/2I9A07(a)(1)(B) through (a)(1)(E) and 2 I8/2I9A07(b) and all applicable provisions in Sections 218/2190408 through 2 I8/219All ofthis Subpart shall apply to all owners or operators ofheatsetweb offset lithographic printing line(s) ifthe combined emissions ofVOM from all lithographic printing line(s) atthe source (including solvents used for cleanup operations associated with the lithographic printing line(s)) ever exceed 45.5 kg/day (100 Ibs/day), before the application ofcapture systems and control devices. SR at 25; see Prop. 218 at 78, Prop. 219 at 77,

. The Agency seeks to require in new subsection (e)(2) that, on and afterMay I, 2010, Sections 218/2I9A07(a)(1)(A), 2181219A07(a)(2) through (a)(5), and all applicable provision sin Sections 218/2190408 through 218/219041 I, shall apply to all owners and operators oflithographic printing lines at sources wherc thc combined emissions ofYOM from all lithographic printing lines at the source (including solvents usc for cleanup operations associated with the lithographic printing lines) evertotal 6.8 kg/day (15 Ibs/day) ormore, SRat25; see Prop, 2 I8 at 78, Prop, 219 at 77, Finally, the Agencyproposed in new subsection (c)(3) that,31

at sourccs where the combined emissions ofVOM from all lithographic printing line(s) at the source equal orexceed 6.8 kg/day (15 Ibs/day) but do not exceed 45.5 kg/day (100 Ibs/day), before the application ofcapturc systems and control devices, certain specified exclusions apply unless the owneror operator ofthe source certifies that the source will not make use ofany such exclusions. SR at 25-26; see Prop. 218 at 78-79, Prop. 219 at 77-78.
In its first motion to amend, the Agency proposed to correct cross-references in Sections 218/219.405(c)(1) and (c)(2) to Section 218/219.408, which the Agency seeks to repeal. Mot. Amend 1 at 6-7 ('lI8); see Prop. 218 at 89, Prop. 219 at 88-89. Thc Agency states that the crossreferences had been "inadvertently left in the rule." Mot. Amend 1 at 6. Section 218.406/219.406: ProvisionsArriving to Heatset Web OffsetLithographic PrintingPriorto March 

### 15,1996. The Agency states that it seeks to repeal this section, "as it contains requirements thatwere applicable prior to March 15, 1996." SR at26; see Prop. 218 at 79-86, Prop. 219 at 78-85. Section 218.407/219.407: Emission Limitations and ControlRequirements (or LithographicPrintingLines On andAfterMarcl. 

### 15, 1996. Existing Section 218/219.407 establishes various requirements applicable to lithographic printing lines on and afterMarch IS, 1996. 35 

### Ill. Adm. Code 218.407, 219.407. The Agency first proposes to amend this section "by deleting references to the previous compliance date ofMarch IS, 1996, and separating requirements that are applicable prior to the new compliance date from those applicable afterthe new compliance date." SR at26; see Prop. 218 at 86-89, Prop. 219 at 85-88. The Agency also proposes to change "the YOM content limitations for fountain solutions from 'by volume' to 'by weight,' as USEPA has informed that Illinois EPA that this is the appropriate way tomeasure the limit." SR at26; see Prop. 218 at 86-89, Prop. 219 at 85-88. Subsectioll (a). The Agency specificallyproposes to amend subsection (a)(1)(C) to provide that

on and afterMay 1, 2010, owners oroperators ofsubjectheatset web offset lithographic printing lines shall install and operate an afterburner

... so thatYOM emissions from thepress dryerexhaust are reducedby 90-95 percent, by weight, depending on the date that the afterburner

... was first constructed at the subject source, orto a maximum afterburner exhaust outlet concentration of20ppmv (as carbon). SR at 26; see Prop. 218 at 87, Prop. 219 at 86. The Agency also proposes to amend subsection (a)(l)(D) in order "to delete references to monitoring requirements already setforth in Section 218/219.410." SR at 26; see Prop. 218 at 87, Prop. 219 at 86.
In addition, the Agency seeks to amend subsection (a)(4) to provide that,

on and afterMay I, 2010, owners or operators ofsources that meet the applicability criteria in Section 218/219.405(c)(3) and do /lot certifypursuant to32

Section 218/219.41 1(g)(J)(B) that the SOurce will not make use ofany ofthe exclusions in Section 2181219.405( c)(3)'shall not cause or allow the use ofa cleaning solution on any lithographic printing line unless the YOM content ofthe as-used cleaning solution is less than or equal to 70percent, by weight, or shall satisfy the alternative YOM composite partial vaporpressure limitation. SRat 27; see Prop, 218 at 88, Prop. 219 at 87. The Agency also proposes to amend subsection (a)(5) in order "to specify thatthe storage and disposal requirements for cleaning materials apply except when such materials are specifically in use." SR at 27; see Prop. 218 at 88, Prop. 219 at 87 Subsection (b). The Agency specifically proposcs to amend subsection (b) to provide that

on and afterMay 1, 20I0, owners or operators ofsubjectheatsetweb offset lithographic printing lines shall install and operate an afterburner or other approved control device so thatYOM emissions from the press dryer exhaust are reduced by 90-95 percent, by weight, depending on the date that the afterburner or other control device was first constructed at the subject source, orto amaximum afterburnerexhaustoutlet concentration of20ppmv (as carbon). SRat26; see Prop. 218 at 88, Prop. 219 at 87-88.
Section 218.408/219.408: Compliance Schedule (orLithographicPrinting On and AfterMarch 15, 1996. The Agency proposes to repeal this section in its entirety, "as the pertinent compliance dates are set forth in Section 2181219.405." SR at27; see Prop. 218 at 89, Prop. 219 at 88-89; see also Prop. 218 at 76-79, Prop. 219 at 75-78 (proposed Section 218/219.405). Section 218.409/219.409: Testing (orLithographicPrinting On andAfterMarch 15, 1996. Existing Section 218/219.409 addresses testing for lithographic printers. 35 Ill. Adm. Code 218.409, 219.409. The Agency originallyproposed to amend this sectionby "deleting a reference to theprevious compliance date ofMarch 15, 1996 in the title

...." SR at27; see Prop. 218 at 89, Prop. 219 at 89.
In its first motionto amend, the Agency also proposed amending subsections (a) and (c) in orderto clarify "when testingpursuant to such Section shall beperformed." Mot. Amend 1 at 7-8 ('iI9). In the same motion, the Agency also proposed to amend subsection (c) "by correcting an internal cross-reference." 

### 1d.
Section 218.410/219.410: MonitoringRequirement .• (orLithographicPrinting. The Agency's original rulemaking proposal did not seek to amend Section 2181219.410, which addresses monitoring requirements for lithographic printers. See SR at 27, Prop. 218 at 91, Prop. 219 at 91; see also 35 

### III. Adm. Code 218.410, 219.410. In its first motion to amend, the Agency responded to a comment from industry representatives by noting "several incorrect internal cross-references within the current Section 218/219.410." Mot. Amend I at 8 ('ill0).33 Accordingly, the Agency "proposes amending subsections (b)(1), (b)(2), (e)(1 )(B), and (e)(2) to correct the cross-references." Id. at 8-14. 

### Section 218.4I1/219.4II: Recordkeepillg alldReporting (orLithographicPrilltill

### g. Existing Section 218/219.411 addresses recordkceping and reporting requirements applicable to lithographic printers. 

### See 35 III. Adm. Code 218.411, 219.411. Generally, the Agencyproposes to amend "this Sectionby deleting references to the previous compliance date ofMarch 15, 1996, and clarifying the requirements thatapply to sources prior to the new compliance date and those that apply on and afterthe new compliance date." SR at 27-28; 

### see Prop. 218 at 92-114, Prop. 219 at 91-114. 

### Subsectioll (a). Existing subsection (a) addresses lithographic printing lines exempt from the limitations ofSection 218/219.407 onthe basis ofcriteria in Section218/219.405. 

### See 35 JIl. Adm. Code 218.4II(a), 219.4II(a). TIle Agencyproposes to add to this subsection "the equation for calculating maximum theoretic emissions ofVOM, which was previously contained in Section 218/219.406." SR at 28; see Prop. 218 at 93-95, Prop. 219 at 92-94. In its first motion to amend, the Agencyproposes to amend thekey to that equation "bydeleting reference to instruments by which owners or operators may calculate the volume ofinks as applied each day on subjectprinting lines, as such instrumentation is not currently available to sources." Mot. Amend I at 14-15 ('111). 

### Subsectioll (b). The Agencyproposes "adding a new subsection (b), which contains recordkeeping and reporting provisions for printing lines that,are exempt on and afterMay I, 20IO

...." SR at 28. Proposed subsection (b)(I) specifically addresses printing lines exempt under Section 218.405(c)(2). In addition to standard recordkeeping and reporting requirements, the Agencyin thatprovision
proposes an emission adjustment factor to be used when determining YOM emissions from inks used on lithographic printing line(s) at the source, as well as an emission adjustmentfactor to be used when calculating emissions from used shop towels ifthe YOM composite vaporpressure ofeach associated cleaning solutionis less than 10mmHg measured at 20°C (68°F) and the shop towels are kept in closed containers. SR at 28; 

### see Prop. 218 at 95-100, Prop. 219 at 94-100. At the request ofindustryrepresentatives, the Agency also proposes in subsection (b)(I)(C) an alternativeto the YOM emissions calculations in subsection (b)(I)(B): "a source may determine that it emits below 6.8 kg/day (15Ibs/day) ofVOM ifit complies with material use limitations during eachmonth." SR at28, Tr.l at 21; 

### see Prop. 218 at 97, Prop. 219 at96-97. The Agency seeks to provide that this material use alternative is limited to sources with only single type of lithographic printing operation. SR at28; 

### see Prop. 218 at 97, Prop. 219 at 96. The Agency proposes that, "[i]fa source exceeds the material use limitation in any given month, the source shall complete emissions calculations pursuant to subsection (b)(1)(B) within 15 days ofthe end ofthat month." SR at 28; 

### see Prop. 218 at 97, Prop. 219 at 96. The Agency furtherproposes that a source exceeding the limitations for six consecutive months is no longer eligible to rely on the alternative. SR at28-29; 

### see Prop. 218 at 97, Prop. 219 at 96-97.34

In its first motion to amend, the Agency notes that "USEPA previously recommended that material use thresholds for such lines be conservatively based on the poundper day applicability threshold." Mot. Amend I at 15 ('il12). The Agency states that "USEPA has now deternlined that a 90 percent emission equivalency level is acceptable for both lithographic and letterpress printing operations." ld. The Agency sought to amend subsection (b)(l)(C)(i) and (b)(1)(C)(ii) ofits proposal to reflect that subsequent USEPA detennination. ld. at 15-16. Also in its first motion to amend, the Agency responded to a commentby industry representatives by proposing to amend subsection (b)(I)(E). Mot. Amend I at 16 ('il13). Specifically, the Agency seeks to remove "the requirement that a source include in its notification to the Illinois EPA calculations showing an exceedancc ofthe applicability threshold." ldat 16-17. Responding to a question at the first hearing, the Agency clarified that, when a sourcereports an exceedanceunder this provisions, "they do nothave to tell us how much they exceeded itby." Tr.1 at 22. The Agency emphasized that this requirementintends chiefly to determine whethera source is subjectto the rule and not to determine the precise amount ofan exceedance. See id. at 22-23. The Agency also proposes a new subsection (b)(2) addressing "heatset web offset lithographic printing lines exemptpursuantto Section 218/219.405(c)(1) butnot exempt pursuant to Section218/219.405(c)(2). SR at 29; 

### see Prop. 218 at 98-100, Prop. 219 at 98-100. In addition to standard recordkeeping and reporting requircments, the Agency inthatprovision
proposes an emission adjustmentfactorto be used when determining YOM emissions from inks used on lithographic printing line(s) at the source, and an , emission adjustment factor to be used when calculating emissions from used shop towels ifthe YOM compositc vaporpressure ofeach associated cleaning solution is less than 10 mmHg measured at 20°C (68°F) and the shop towels are kept in closed containers." SR at 29; 

### see Prop. 218 at 98-100, Prop. 219 at 98-100. In'its first motion to amend, the Agency responded to a commentby industryrepresentatives by proposing to amend subsection (b)(2)(0). Mot. Amend I at 15-17 ('il14). Specifically, the Agency seeks to remove "the requirementthat a source include in its notification to the Illinois EPA calculations showing an exceedances ofthe applicability threshold." 

### ld.; see Tr.1 at 22. 

### Subsection (c). The Agency proposes to redesignate the existing subsection (a)(2) as subection (c). Prop. 218 at 100-02, Prop. 219 at 100-02; 

### see 35 Ill. Adm. Code 218.41 I(a)(2), 219.4II(a)(2). The Agency seeks to amend this provision "toprovide thatthe recordkeeping requirements in subsections (c)(I) or (c)(2) do not apply to sources utilizing the material use limitations alternative. SR at 29; 

### see Prop. 218 at 100-02, Prop. 219 at 100-02. The Agency also proposes to delete subsection (c)(3). SR at 29; 

### see Prop. 218 at 102, Prop. 219 at 102. 

### Subsection (d). Existing subsection (b) establishes requirements applicable to heatset web offset lithographic printing line(s) subject to Section 21 8/2I9.407(a)(1)(C) or (b)(1). See 35 HI. Adm. Code 218.41 I(b), 219.4II(b) Inthe redesignated subsection (d), the Agency proposes to add arequirement "that sources complying with the add-on control device requirements shall include in their initial certification to the II1inois EPA that date that thc device was first35

constructed atthe subject source." SR at 29; see Prop. 218 at 102-04, Prop. 219 at 102-04. The Agency also proposes to amend subsection (d)(3)(D) "to change the frequency that owners or operators ofheatset web offset lithographic printinglines complying with the add-on control devicerequirements are required to checkthe air flow direction orairpressure ofthe dryer and press room from once a day to once percalendarmonth." SR at29; see Prop. 218 at 104, Prop. 219 at 104. Subsectioll (e). Existing subsection (c) establishes requirements applicable to lithographic printing lines subject to Sections 2181219.407(a)(J)(A), (a)(2), or (a)(3). See 35 

### Ill. Adm. Code 218.411 (c), 219.411 (c). ln the redesignated subsection (e), the Agency "proposes amending subsection (e)(1)(C) to provide that a source subjectto fountain solution YOM content limitations shall include in its initial certification a statementthat the fountain solution will comply with the YOM content limitations in Section 21 8/219.407(a)(J)(A), (a)(2), or (a)(3), as applicable." SR at 30; see Prop. 218 at 105, Prop. 219 at 104. The Agency also proposes to amend subsection (e)(2)(C) "to provide thatthe weight ofeach componentused in a fountain solution batch shallbe recorded by sources, ifapplicable." SR at 30; see Prop. 218 at 106, Prop. 219 at 106. In addition, the Agency "proposes deleting subsection (e)(4)." SR at 30; see Prop. 218 at 107, Prop. 219 at 107. Subsectioll (f). Existing subsection (d) establishes requirements for lithographicprinting lines subjectto Section 218/219.407. 35111. Adm. Code 218.4II(d), 219.4II(d). In the redesignated subsection (f)(J), the Agencyproposes an amendment "to specifythat lithographic printing line cleaning operations that are excludedpursuant to Section 218/219.405(c)(3)(C) are notrequired to submita certification pursuant to subsection (f)." SR at 30; see Prop. 218 at 108, Prop. 219 at 107-08. In addition, the Agency "proposes deleting subsection (f)(l)(A), (f)(I)(C), and (f)(4), and amending therelettered subsection (f)(I)(A) to provide that a sourcc subject to the cleaningrequirements in Section 218/219.407 shall include in its initial certification a statement thatthe cleaning solution will comply with the limitations in Section 21 8/2I9.407(a)(4)." SR at 30; see Prop. 218 at 108-10; Prop. 219 at 108-10. In its first motion to amend, the Agency responded to arequest from industry representatives. Mot. Amend I at 17-18 ("15). The Agencyproposed amending subsections (f)(2)(B) and (f)(2)(C) "by specifying that, for cleaning solutions used as-purchased, sources may use manufacturer's specifications to determine YOM contentand YOM compositepartial vapor pressure." Jd. at 18-19. Subsectioll (g). The Agencyproposes to add a new subsection (g). The Agency seeks to establish "recordkeeping and reporting requirements for owners oroperators oflithographic printing line(s) subject to one ormore ofthe exclusions set forth in Section 21 8/2I9.405(c)(3)." SRat 30; see Prop. 218 at 111-12, Prop. 219 at II0-12. Specifically, the Agency states that [s]uch owners oroperators shall submit an initial certification to the Illinois EPA, collect and record specified information for each subjectprinting line, notify the Agency iftheprinting line everbecomes ineligible for the exclusions set forth in Section 21 8/21 9.405(c)(3), and, ifchanging between opting out ofsuch exclusions and utilization ofthe exclusions, submit an additional certification,36 infonning the llIinois EPA ofthe change. SR at 30-31; see Prop. 218 at 111-12, Prop. 219 at 110-12.
In responding to a question at the first hearing, the Agency indicated that, as a source, "you would nothave to reportthe information under [subsection] (g)(2)(A) ifyou did statethat you would notbe using the exclusion." Tr.l at 16-18.
In its first motion to amend, the Agencyresponds to arequest from industry representative byproposing to amend subsection (g)(2)(A)(ii) "to correct a grammarmistake." MotAmend I at 20**(~16).** Also in the first motion to amend, the Agency responds to an industry commentbyproposing to amend subsection (g)(2)(B) "byremoving the requirement that a source include in its notification to Jl1inois EPA calculations showing an exceedances ofthe applicability threshold." !d. at 20-21**(~17).** Subsection (i). The Agency also proposes to add a subsection (i). The Agency seeks to establish "emission adjustment factors thatmay be used when calculating YOM emissions from heatset web offset lithographic printing operations for purposes other than the applicability thresholds in Section 218/219.405." SRat 31; see Prop. 218 at 112-14, Prop. 219 at 112-14. Letterpress Printing. Illtroductioll. The Agency states that "[I]etterpressprinting involves the use ofa reverseimaged raised surface that is inked and then pressed against a substrate to transfer the image." TSD at4 (§2.2). The Agency further states that, compared with lithographic, flexographic, and rotogravure printing, "[I]etterpress operationmake up a very small percentage oftheprinting industry." 

### Id. Based on its source inventory, the Agency indicates that "no letterpress printing facility could be found in the Metro-EastNAA, with very few ofthese facilities found even in the Chicago NAA." 

### Id.
In testimony onbehalfofthe Agency, Mr. Bloomberg indicated that "the State is still required to promulgate the CTG regulations for this category." Bloomberg Test. at 5. He further stated that "letterpressprintingpresses are oftenoperated at the same source as lithographic printing[,] andmany ofthe control options for letterpress printing are the same as the control options for lithographic printing as well. This is especiallytrue in terms ofcleaning solutions. As such, theproposed rule would adoptmost ofthe RACTrecommendations ofthe CTG." 

### Id. The Agency states thatletterpress and lithographic printing operations use inks that are' "very similar" and may both be accomplished through sheet-fed and web presses. TSD at 4. The Agency thus argues that "ink emission sources are similar" to those oflithographic printing. 

### Id. The Agency further argues that, although "[I]etterpress operations do notuse fountain solutions," they use cleaning solutions similarto those used in lithographic printing operations." TSD at4; see Bloomberg Test. at 5. CllrrelltRegulatiolls. The Agency states that "[t]here are no specific Jl1inois regulations covering letterpress printing operations; any such operations would therefore be covered by37 SubpartTT, Section 218/219.301, orpaper coating regulations. TSD at 16 (§5.2); 

### see 35 Ill. Adm. Code 218.204(c), 218.301, 218.980-988, 219.204(c), 219.301, 219.980-988 

### Summary of ProposedAmendmentsAddressing LetterpressPrinting. The Agency states that its proposal addresses "both heatset and non-heatset letterpress operations." TSD at 

### 16; see Prop. 218 at 114-129, Prop. 219 at 114-30. The Agency further states that the proposal "would require thatheatsetletterpress printers use an add-on control device ifthey meetthe applicability requirements of25 TPY PTE plantwide." TSD at 16; 

### see SR at 8-9. The Agency believes that no operation in either ofthe two NAAs would be subject to this requirement. TSD at 16. The Agency further states that "[a]ll letterpress printing operations of 15 PPD or more will be also required to abide by cleaning material limitations equivalentto those" applicable to lithographic printing sources emittingbetween 15 and 100 PPD. TSD at 16; 

### see SR at 9. Specifically, such sources would be required to use cleaning solutions containing no morc than 70 percentYOM orhaving a maximum composite partial vaporpressure orless than 10mm Hg. 

### Id. In his testimony onbehalfofthe Agency, Mr. Bloomberg stated that, because letterpress printing operations have never specificallybeen regulated in Illinois, this 70 percent content limit represents no loosening ofexisting standards. Bloomberg Test. at 5. 

### Section 218.412/219.412: 

### LetterpressPrinting Lines: Applicability. The Agency proposes a new Section 218/219.412 addressing the applicability oftheproposed letterpress printingprovisions. SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. Below, the Board summarizes thoseproposed additions on a subsection-by-subsection basis. 

### Subsection (aj. The Agency proposes anew subsection (a)(I) providing "thatthe limitations in Section 218/219.413 through 218/219.416 apply to all owners ofoperators of heatset web letterpress printing lines ifsuch lines (including solvents used for cleanup operations associated with such lines) at the source have apotential to emit22.7 Mg (25 tons) ormore of YOM peryear." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. The Agency also proposes a new subsection (a)(2) providing that "Sections 218/219.413 through 218/219.416 apply to all owners oroperators ofletterpress printing lines at sources where the combined emissions of YOM from all letterpress printing lines atthe source (including solvents used for cleanup operations associated with the letterpress printing lines) ever equal orexceed 6.8 kg/day (15 Ibs/day), in the absence ofairpollution control equipment." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. 

### Subsectioll (bj. The Agency proposes a new subsection (b) providing "that the requirements ofSection 218/219.413(a)(2) shall notapply to up to 416.3 liters (100 gallons) per yearofcleaning materials used on letterpress printing lines at a subject source." SR at 31; 

### see Prop. 218 at 114, Prop. 219 at 114. 

### Subsectioll (cj. The Agencyproposes a new subsection (c) providing that, "on and after May 1, 2010, the recordkeeping and reporting requirements in Section 218/219.417 shall apply to all owners oroperators ofletterpress printing line(s)." SR at 32; 

### see Prop. 218 at 114, Prop. 219at114.38

Subsectiou (d). The Agency proposes anew subsection (d) providing that, "ifa letterpress printing line at a source is or becomes subjectto one or more ofthe limitations in Section 218/219.413, the letterpress printing lines at the source are always subject to the provisions ofSubpart H." SR at 32; see Prop. 218 at 114, Prop. 219 at 114. Sectiou 218.413/219.413: Emissiou Limitatious aud ControlRequirements (or LetterpressPrintilzgLines. TheAgency proposes to add a new Section218/219.413 establishing various requirements for letterpress printing lines. SR at 32; see Prop. 218 at 115- lG, Prop. 219 at 115-16. Subsectiou (a). The Agency proposes a new subsection (a)(l) providing in partthat heatset web letterpress printing lines that meet the applicability requirements of Section 218/219.412(a)(l) shall maintain the airpressure inthe dryerlower than the airpressure ofthe press room and install and operate an afterburner that reduces YOM emissions by 90-95 percent, depending on the date that the afterburnerwas first constructed at the subject source, orto amaximum afterburner exhaust outlet concentration of20 mmpv (as carbon). SR at 32; see Prop. 218 at 115, Prop. 219 at 115.
In addition, the Agency proposes to require that "[s]uch printing lines shall also equip the afterburnerwith applicable monitoring equipment and operate the afterburnerat all times when the printing line is in operation, exceptas provided in Section218/219.107." SR at 32; see Prop. 218 at 115, Prop. 219 at 115.
In proposed subsection (a)(2), the Agency proposes to providethat "no OWller oroperator ofsubject letterpress printing lines shall use cleaning solutions on such lines unless the YOM content ofthe as-used cleaning solution is less than orequal to 70 percent, by weight, orthe YOM composite vaporpressure ofthe as-used cleaning solution is less than 10 mmHg at 20 degrees Celsius." SR at 32; see Prop. 218 at 115-16, Prop. 219 at 115-16.
Inproposed subsection (a)(3), the Agency seeks to require that "[c]leaningmaterials must bekept, stored, and disposed ofin closed containers, except when specifically in use." SR at 32; see Prop. 218 at 11G, Prop. 219 at 116. Subsectioll (b). The Agency proposes anew subsection (b) providing "thatheatsetweb letterpress printing lines may use acontrol device otherthan an afterburner ifthe control device meets the YOM emissions reduction requirements in subsection (a) and is approved by the Illinois EPA and USEPA as federally enforceable permit conditions." SR at 33; see Prop. 218 at 1IG, Prop. 219 at 11G. Sectioll 218.415/219.415: Testiug (orLetterpressPriutillgLilies. The Agency proposes to add a new section addressing testing requirements applicable to letterpress printing lines subjectto Section 218/219.413. SR at 33-34; see Prop. 218 at 116-19, Prop. 219 at 116-19.39

Subsectioll (a). In proposed subsection (a), the Agency seeks to require "that testing to demonstrate compliance with [Section] 218/219.413 shall be conducted at the expense ofthe owneroroperatorwithin 90 days ofa requestby the Illinois EPA, and the owner oroperator shall notify the Illinois EPA 30 days in advance ofconducting such testing." SR at 33; see Prop. 218 at 116, Prop. 219 at 116. In its first motion to amend, the Agency responds to a request by industry representatives by seeking to amend this subsection to clarify when testing mustbe perfonned. Mot. Amend I at 21 ('ll18). Subsectioll (b). In its proposed subsection (b), the Agency proposes to describe "the methods and procedures in Section 218/219.1 05(d) and 

### (f) that shall be used for testing to demonstrate compliance with the add-on control devicerequirements ofSection 218/2] 9.413(a)(1 )(B) and (b)(1)." SRat 33; see Prop. 218 at 117-] 8, Prop. 219 at 117-] 8. SubsectioJl (c). The Agency proposes a new subsection (c) providing "thattesting to demonstrate compliance with the YOM content limitations in Section 218/2]9.413(a)(2)(A) and to detennine the YOM content ofcleaning solvents, cleaning solutions, and inks shall be conducted using the applicable test methods and procedures in Section 218/219.105(a)." SR at 33; see Prop. 218 at 118, Prop. 219 at 118. The Agency also seeks to provide in subsection (c)(2) that "[t]he manufacturer's specifications for YOM content for cleaning solvents and inks may be used ifsuch specifications are based on results oftests conducted in accordance with Section 218/219.105(a)." SR at 33; see Prop. 2] 8 at 118, Prop. 219 at 118.
In its first motion to amend, the Agency responds to arequest by industryrepresentatives by seeking to amend this subsection to clarify when testing mustbe perfonned. Mot. Amend I at 21 ('ll18). SubsectioJl (d). The Agency proposes anew subsection (d) providing "thattesting to demonstrate compliance with Section 218/219.413(b) shallbe conducted as set forth in the owner or operator's plan approved by the Illinois EPA andUSEPA as federally enforceable pennit conditions." SR at 34; see Prop. 2]8 at] 18, Prop. 2]9 at 118. Subsectioll (e). The Agency proposes a new subsection (e) providing "that testing to detennine the YOM composite partial vapor pressure ofcleaning solvents, cleaning solvent concentrates, and as-used cleaning solutions shall be conducted in accordance with the applicable methods and procedures specified in Section 218/219.1 ]0." SR at 34; see Prop. 218 at 118-19, Prop. 219 at 118-19.
Sectio" 218.416/219.416: MoJlitoriJlgRequiremeJltsfOrLetterpressPriJltillgLilles. The Agency proposes to add a new section addressing monitoring ofemissions from letterpress printing lines. See SR at 34, Prop. 218 at 119-20, Prop. 219 at ] 19-20. Subsectioll (a). The Agencyproposes anew subsection (a) providing "that, ifan afterburner is used to demonstrate compliance, the owneroroperator ofaheatset web letterpress printing line shall install, calibrate, maintain, and operate temperature monitoring devices with an accuracy of3° C or 5° F on the afterburnerin accordance with Section 218/219.]05(d)(2) and in accordance with the manufacturer's specifications." SR at 34; see Prop. 218 at 119, Prop. 21940

at 119. The Agency also secks to rcquire inproposed new subsection (a)(I) thatmonitoring must be "perfonned at all times when the afterburner is operating

...." Prop. 218 at 119, Prop. 219 at 119; 

### see SR at 34. In subsection (a)(2), the Agency proposes to require that "owners or operators shall also install, calibrate, operate, and maintain in accordance with manufacturer's specifications a continuous recordcr on the temperature monitoring devices with at least the same accuracy as the temperature monitor." SR at 34; 

### see Prop. 218 at 119, Prop. 219 at 119. 

### Subsection (bj. The Agency proposes a new subsection (b) providing "that ifa control device otherthan an afterburner is used to demonstrate compliance, the owneroroperatorofa heatset web letterpress printing line shall install, maintain, calibrate, and operate such monitoring equipment as set forth in the owner or operator's plan approved bythe Illinois EPA and USEPA pursuant to Section 218/219.413(b)." SR at 34; 

### see Prop. 218 at 119, Prop. 219 at 119. 

### Subsection (cj. The Agency proposes anew subsection (c) setting "forth the monitoring requirements for owners or operators ofletterpress printing lines relying on the YOM contentof the cleaning solution to comply with Section 218/219.413(a)(2)(A), orrelying on the vapor pressure ofthe cleaning solution to comply with Section 21 8/21 9(a)(2)(B)." SR at 35; 

### see Prop. 218 at 119-20, Prop. 219 at 119-20.

. 

### Section 218.417/219.417: 

### RecordkeepingandReporting (orLetterpressPrinting Lines. The Agency proposes to add a new section addressing recordkeeping and reporting for Ictterpress printing lines. SR at 35; 

### see Prop. 218 at 120-29, Prop. 219 at 120-30. 

### Subsection (aj. The Agency proposes anew subsection (a) providing that the owner or operatorofa heatset web letterpress printing line exempt from any ofthe limitations ofSection 2181219.413 because ofthe criteria in Section

.218/219.412(a)(I) shall submit a certification to the Illinois EPA that includes a declaration that the source is exempt and calculations thatdemonstrate that the source's total potential to emit YOM does not equal orexceed 25 tons peryear. SR at 35; 

### see Prop. 218 at 119, Prop. 219 at 120. 

### Subsection (bj. The Agency proposes anew subsection (b) providing that the owneroroperatorofa letterpress printing line exempt from any ofthe limitations ofSection 2181219.413 because ofthe criteria in Section 21 8/21 9.412(a)(2) shall submit a certification to the Illinois EPA that includes a declaration that the source is exempt, calculations that demonstrate that combined emissions ofVOM from all letterpress printing lines atthe souree neverequal or exceed 6.8 kg/day (15 1bs/day), and a description and the results ofall tests used to detennine the YOM content ofinks and cleaning solvents. SR at 35; 

### see Prop. 218 at 120-23, Prop. 219 at 120-23.
In its proposed subsection (b)(1)(D), the Agency seeks to provide that, "as an alternative to the YOM emission calculations set forth in subsection (b)(I)(B), a source may detennine that it emits below 6.8 kg/day (I51bs/day) ofVOM ifit complies with material use limitations during41

each calendarmonth." SR at 35-36; see Prop. 218 at 122, Prop. 219 at 122. The Agency proposed language limiting the availability ofthis alternative to sources with only a single type ofletterpress printing operations. SR at 35-36; see Prop. 218 at 122, Prop. 219 at 122. The Agency also proposed to require that, "[i]fa source exceeds the material use limitation in any given month, the source shall complete emissions calculations pursuant to subsection (b)(I)(B) within 15 days ofthe end ofthat month." SR at 36; see Prop. 218 at 122, Prop. 219 at 122. The Agency also proposed that any source exceeding the limitation for six consecutive months was no longer eligible to rely upon the material use alternative. SRat 36; see Prop. 218 at 122, Prop. 219 at 122.
In its first motionto amend, the Agency proposed to change the material use thresholds for letterpress printing lines. Mot. Amend I at 22**(~119).** The Agency states that "USEPA

. previouslyrecommended thatmaterial use thrcsholds for lithographic printingJines be conservativelybased on 50 percent ofthe poundper day applicability threshold. USEPA has now determined that a 90 percent emissions equivalency level is acceptable for both lithographic and letterpress printing operations." !d. Accordingly, the Agency seeks to amendproposed subsections (b)(I)(D)(i) and (b)(I)(D)(ii) to reflect this 90 percent equivalency. 

### Id.
Inproposed subsection (b)(2), the Agency sought to require that subject sources shall notify the Agency ifthe combined emissions ofVOM from all letterpress printing lines at the source ever equal or exceed 6.8 kg/day (15 Ibs/day)." SR at 35; 

### see Prop. 218 at 123, Prop. 219 at 123. In its first motion to amend, the Agency proposed to amend subsection (b)(2) "by removing the requirement that a souree include in its notification to the Illinois EPA calculations showing an exceedancc ofthe applicability thrcshold." Mot. Amend 1 at 22-23**(~20).** 

### Subsectiou (c). Thc Agencyproposes anew subsection (c) providing "that, unless utilizing the material use alternative, the owneror operator ofa letterpress printing line subject to therequirements in subsection (a) or (b) ofthis Section shall collect and record eitherthe specified standard recordkeeping information or the specifiedpurchase and inventory recordkeeping information." SR at 36; 

### see Prop. 218 at 123-24, Prop. 219 at 123-25. 

### Subsection (d). The Agency proposes anew subsection (d)(I) providing thatthe owneroroperatorofaheatset web letterpress printing line subject to Section 218/219.413(a)(I)(B) or (b)(I) ofthis Subpart shall submit a certification to the Illinois EPA that includes identification ofeach heatset web letterpress printing line at the source, adeclaration thateach such line is in compliance with Section 218/21 9.4I3(a)(I) or (b), the type ofafterburner or otherapproved control devicebeing used and the date that such device was first constructed at the subject source, the control requirements with which the printing line is complying, the results ofall tests and calculations necessary to demonstrate compliance, and a declaration that the required monitoring equipmenthas been properly installed and calibrated. SR at 36; 

### see Prop. 218 at 125-27, Prop. 219 at 125-27. Proposed subsection (d)(2) seeks to require that,

### 42

ifthe testing ofan afterburner or other approved control device is conducted pursuant to Section 218/219.415(b), the owneroroperator shall submit acopy of all test results to I1linois EPA, as well as a certification that includes adeclaration thatall necessary tests and calculations have been performed, a statement whether the printing line is in compliance with Section 218/219.413(a)(I)(B) or (b)(I), and the operating parameters ofthe afterburner orother approved control device during testing. SR at 37; see Prop. 218 at 125-26, Prop. 219 at 126. The subsection also proposes that an owner oroperator changing its method ofcompliance "must certify compliance for the new method ofcompliance and perform all tests and calculations necessary to demonstrate compliance with such method." SR at 37; see Prop. 218 at 126-27, Prop. 219 at 127. Subsection (d)(3) also proposes to require that an owner or operator "collect and record specified information for each heatsetweb letterpress printing line and notify the I1linois EPA of any violation ofSection 2181219.413(a)(I)(B) or (b)(I)." SR at 36; see Prop. 218 at 125-27, Prop. 219 at 125-27. Subsection (e). The Agency proposes a new subsection (e) establishing various recordkeeping andreporting requirements. See SR at 37, Prop. 218 at 127-29, Prop. 219 at 127- 30. The proposed provision "provides that the owneror operator ofa letterpress printing line shall certifY to the I1linois EPA that all cleaning solutions, otherthan those excluded pursuantto Section 218.412(b), and the handling ofall cleaning materials willbe in compliancewith Section 218/2I9.413(a)(2)(A) or (a)(2)(B) and (a)(3)." SR at 37; see Prop. 218 at 127, Prop. 219 at 127. The proposed certification must also include specific informationregarding cleaning operations at the subjectprinting line. SR at 37; see Prop. 218 at 127, Prop. 219 at 127. In addition, "[t]he owneroroperatorshall collect and record specified information for each solution used on each letterpress printing line and notifY the lIlinois EPA ofany violation ofSection 218/219.413." SR at 37; see Prop. 218 at 127-29, Prop. 219 at 127-30.
In its first motion to amend, the Agencyresponded to commentby industry representatives byproposing to amend subsections 218/219(e)(2)(B) and (e)(2)(C) "by specifying that, for cleaning solutions used as-purchased, sources may use manufacturer's specifications to determine YOM content and YOM compositepartial vaporpressure." Mot. Amend 1 at 23-25**(~21).** Subsection 

### (f). The Agency proposed anew subsection (f) providing "that the owner or operatorofaprinting line shall maintain all records required by this Section for aminimum period ofthree years and shall make allrecords availableto the Agency upon request." SR at 38; see Prop. 218 at 129, Prop. 219 at 130. SUMMARY OFPOST-HEARING COMMENT (PC 1) A noted above under "Procedural History," the Board on December28,2009, received

# a timely post-hearing comment from Mr. Bruce Meerman, SeniorEnvironmental Consultant, Mostardi PlattEnvironmental. See PC 1. Mr. Merman states that he "represents aheatset offset43 lithographic printerwho recently installed a replacement catalytic oxidizerin three (3) older heatset lithographic printing lines." Jd. at I. He suggests thatpennits applicable to those lines allow the control devices to operatewith a minimum 90% destruction efficiency. See id. His comments address two subsections ofthe Agency's proposed regulations, each ofwhich is addressed in the following subsections ofthe opinion. Section 218/219.407(a)(l)(C) Mr. Meennan states that Illinois has proposed to incorporate the requirements ofthe CTG for lithographic and letterpress printing in a specific fashion. See PC I at I. Herequests thatthe Board clarify this proposed language to show whether it addresses "the printing line, the afterburner, orboth." PC I at I. He also requests thatthe Board clarify "that it is the installationloperation date ofthe unitthat detennines what percent efficiencymust be achieved, and notthat all control devices must perfonn at ahigher dcstruction efficiency after May I, 20J0" !d. at 1-2. The Board notes thatthe Agency's proposed Section 218/219.407(a)(I)(C) requires the installation and operation ofan afterburner "so that YOM emissions (excluding methane and ethane) from the press dryer exhaust(s) are reduced as follows:

... [oln and afterMay I, 2010. by at least 90 percent. by weight. for afterburners first constructed atthe source prior to January I, 2010; by at least 95 percent, by weight, for afterburners first constmeted at the source on or after January I, 2010; orto a maximum afterburnerexhaust outletconcentration of20 mmpv (as carbon)

..." Prop. 218 at 86-87, Prop. 219 at 86.

:me Board concludes thattherulemaking proposal submitted to the Board and cited in the precedingparagraph satisfactorily addresses the two requests for clarification. However, the Board invites comment during the 45-day first-notice commentperiod from any participant who wishes to address eitherofthose matters. Section 21812l9.407fb) Existing Section 218/219.407(b) addresses the use ofa control device other than an afterburnerby the owner or operator ofa heatset web offsetlithographic printing line. 35 Ill. Adm, Code 218.407(b), 219.407(b). Mr. Meennan states that [c]urrentheatset lithographic presses are designed with an integrated drying ovcnlthennal oxidizer control. These units easily achieve the proposed 95% destmction rate and are cost effective whenpurchasing new heatsetpresses. Many existing olderunits, however, require stand alone control devices. They are not engineered for optimized (lower) dryer airflow rates. As control device operation costs (natural gas usage) arehigh for these olderpresses[,] itis more cost effective to duct emissions to catalytic oxidizers for control. Catalyst efficiency may slightlyreduce overtimer,] and we wish to ensurethat it is clearin the rules that these units will always be able to comply with the 90 destruction minimum. PC I at 2.44

Mr. Meernlan first seeks clarification "whetherit is the effective operation date ofthe printing line orthe control device, orboth inrelation to the May I, 2010 control efficiency requirement." 

### !d. Second, ifthe control device is the dctermining factor, he seeks clarification "that all cxisting units maintain their status (90% destruction) through all equipment maintena,nce and repair, including replacement ofcatalyst." ld.
The Board notes that the Agency's proposed Section 218/219.407(b)(1 )(B) provides that [a]n owner or operator ofaheatset web offset lithographic printing line subjectto the requirements ofsubsection (a)(1 )(C) may use a control device other than an afterburner, if

... the control device reduces YOM emissions from the press dryer exhaust(s) as follows: 

## ill [o]n and after May 1, 2010: 

### il By at least 90 percent, by weight, for control devices first constructed at the source priorto January 1,2010; 

### ill By at least 95 percent, by weight. for control devices first constructed atthe source on or after January 1, 20I0: or 

### iii} To a maximum control device exhaust outlet conccntration of20 ppmv (as carbon). Prop. 218 at 88, Prop. 219 at 87-88. The Board concludes thatthe rulemaking proposal submitted to the Board and cited in the preceding paragraph satisfactorily address the two requests for clarification. However, the Board invites comment during the 45-day first-notice commentperiod from anyparticipantwho wishes to address either ofthose matters. AFFECTED SOURCES AND I'ROJECTED EMISSIONS REDUCTIONS The Agency states that its proposed regulations apply only withinthe Chicago and Metro Eastregions, the state's two areas designated as nonattainment for the eight-hourozone NAAQS. SR at 9, citing 40 C.F.R. 81.314. Specifically, the Agency states that, within those two areas, the regulations "are generally expected to affect both new and existing sources that are covered by a Group II CTG" and that meet the proposed applicability criteria. SR at 9, In Appendix B to its TSD, the Agency lists 136 potentially affccted sources itemized by category and thcnby NAA within those categories. TSD at 25-28 (Appendix B), The Board addresses the record with regardto potentially affected sources andprojected emission rcductions on a category-by-categorybasis in the following subsections. Industrial Cleaning Solvents The Agency notes USEPA's estimate that 130 sources in ll1inois' two nonattainment areas emit atotal of 15 PPD ormore ofVOM from cleaning operations at the source. TSD at 2045**(~6.4);** see Prop. 218 at 4 (proposed Section 218.1 87(a)(l) addressing applicability). Responding to a question atthe first hearing, the Agency indicated that its proposed regulations apply to "anybody who uses this amount ofindustrial cleaning solvents" and not only to the operations included in Group 11 Consumerand Commercial Productcategories. Tr.1 at 10. The Agency argues that, because it does not generally seek specific information on solvent use and because that usc may not be subject to a currentpermit, "there was no good way to make an estimate as to who might be affected

...." 

### !d. at II. Accordingly, the Agency states thatits "Appendix B does notlist specific sources that are potentially affected by this rulemaking." 

### Id; see ISD at 25- 28 (Appendix B). The Agency stated that it intends to communicate with small business owners, industry representatives, and DCEO through the process ofconsidering and implementing these proposed ru1es. Tr.1 at II. The Agency states thatbaseline emissions from the 130 sources noted by USEPA are estimated to be 2293 

### MG/yr (2528 tpy) ofVOM. TSD at 20. The Agency further states that this estimate includes "degreasing operations that are already impacted by existing state regulations and will not gain any further reductions." 

### Id. The Agency argues that "[i]tis notreasonably practicable to estimatc cmission reductions forthc other impacted sources underthe industrial clean-up solventrule, as any source in eitherNAA that uses cleaning solvent is potentially affected, depending on the source's usage leve1." TSD at 20-21; see Tr.1 at 9-11. The Agency also claims thatpotentially affected sources may alreadybe using solutions that comply with the proposed regulations. 

### Id. at 21. Accordingly, "the Agency believes thatthe environment will see actual YOM emission reductions due to these proposed regulations, but ca1eulation ofsuch emission reductions cannotbe accomplished without detailed information from every affected source." TSD at 21. FlatWood Paneling Coatings The Agency's search ofthe 2005 source inventory maintained by its Bureau ofAir indicates that four sources, all in the Chicago NAA, will become subjectto the proposed flat wood paneling coating regulations. TSD at 21 (§6.5). The Agency states that "[o]ne ofthese four sources would appcar to fall below the proposed applicability threshold" and that "[t]he otherthree total 0.09 TPD ofVOM emissions." 

### Id. The Agency claims thatthe CTa projects YOM emissionreductions averaging 60 percent from interiorpaneling and tileboard manufacturing. 

### Id. Stating that the Illinois sources appear to fall within these two categories, the Agency "estimates a YOM reduction of0.05 TPD in the Chicago NAA

...." 

### Id Flexible Packaging Printing Lines Thc Agency stresses difficulties in estimating emission reductions in this category. First, the Agency states that "the Illinois source database does not generally specify the type of substrate being used by a flexographic or rotogravure printing operation." TSD at 20 (§6.3). The Agency further states that the data also do not "specify the date oforiginal installation ofthe printing press or the associated control device." 

### Id. Accordingly, the Agency lists as a potentially affected source each existing flexographic orrotogravure printing facility in the Illinois inventory and exceeding the proposed applicability threshold. Id.; see id. at 27-28 (Appendix B).46

The Agency emphasizes, however, that "all sources butone using flexographic or rotogravure printing ofany type are already achieving greater control efficiency than required by the proposed regulation." TSD at 20. The Agency states thatthe single remaining source "is required by its permitto achieve 60 percent control efficiency, butwill now need to achieve 65 percent." !d. The Agency claims thatthis represents areduction of0.03 TPD in permitted emissions, "but a0.01 TPD reduction according to emissions information inthe inventory." !d. TheAgency expects negligible emission reductions from proposed ncw inklimits. TSD at 20. Thc Agency states that, "[w]hile the inventory docs notprovide information regarding thc use ofcompliant inks, ithas been the Agency's experience that sources printing on flexible

.packaging have had difficulty with the use ofcompliant YOM inks on such substrates." !d. The Agencyreports that "[s]ources eitherrelied on add-on controls or switched to water-based inks that should mcetthe newly proposcd requirements as well as the existing oncs." 

### Id. Regarding proposed workpractice standards for cleaning materials, the Agency argucs that they "do not lend thcmselves to a calculation ofemission reductions." TSD at 20. The Agency claims that actUal YOM emission reductions will result from requirements such as "storing ofcleaning materials and used shop towels in closed containers, as well as conveying cleaning materials in closed containers orpipes

...." 

### Id. The Agency argues, however, that "calculation ofsuch emission reductions cannotbe accomplished without detailed information from every affected source -- both before and after such changes are madc." 

### Id. Lithographic Printing Lines The Agency first states that it "does not expectany additional [emission] reductions from increasing the required control efficiency for heatsct web lithographic printers from 90 to 95 percent, because that change will not affectexisting control devices." TSD at 18 (§6.1). The Agency does expect "some small YOM reductions rclated to the addition offountain and cleaning solution requirements for sources with 15 PPD or more ofemissions." 

### Id. The Agency claims that it is difficult to estimate these reductions bccause it is notpossibleto identifY sources thatmay be excluded from the proposed requirements. !d. TheAgency elaborates thatits source inventory "does not track information such as the numbcr ofgallons ofcleaning solution used, the size ofsheet-fed presses, orthe fountain solution reservoirvolume

...." 

### Id. TheAgency's search ofthe 2005 source inventory maintainedbyits Bureau ofAir indicates that 98 lithographic printing sources inthe Chicago NAA and threc in the Metro East NAAhave YOM emission over IS PPD. TSD at 18. The Agencyreports that 66 ofthe sources in the Chicago NAA and all three ofthe sources in the Metro EastNAA emitless than 100 PPD and arepotentially affected by the proposed regulations. [d.
Forthcse potentially affected sources, the Agency estimated potential emission reductions attributable to reformulation offountain solutions atbetween 25% and 90% for smaller sources. TSD at 19. Because this estimate is based on a 1993 draft CTG, and because the current CTG refers to steps reducing the YOM content offountain solutions, the Agency relied on the 25% estimate in calculating reductions. 

### !d. The Agency argues that "[c]leaning

### 47

solutions can be calculated as a straight 30% reduct·ion, since the regulation requires refonnulation such that they cannot contain more than 70% YOM. " Ill. Withregard to cleaning solutions emissions, the Agency claims that they "make up alowerpercentage ofemissions compared to fountain solutions, ranging up to approximately 50% at certain facilities." Ill. The Agency argues that, "[a]ssuming that almost 50% ofnon-ink.emissions come from cleaning solutions, which have 30% reduction, it is safe to use a 25% overall emissionreduction to cover all YOM originating from the source." Ill. The Agency states thattotal YOM emissions from the 66 potentially affected sources in the Chicago NAA equal 1.455 TPD. TSD at 19. Accordingly, a25% reductionrepresents 0.36 TPD ofYOM. Ill. The Agency further state that, in the Metro EastNAA, a 25% reduction from total emissions of0.0295 TPD represents a reduction of0.007 TPD. Ill. Letterpress Printing Because the Agencybelieves that there are no heatsetweb letterpress printing operations in the two NAAs, itexpects no emission reductions from add-on controls for this category. TSD at 19 (§6.2). The Agency's search ofthe 2005 source inventory maintained by its Bureau ofAir indicates that there are two sources in the Chicago NAA using letterpress printing. Ill. The Agency states that "[0]nly one ofthese sources appears to emit more than 15 PPD from such operations, with less than 0.02 TPD ofYOM, including emissions from the letterpress as well as otherprinting operations." Ill. The Agency argues that, "[e]ven ifall ofthe emissions originated from letterpress cleaning solutions, which are to be reduced by 30 percent, the resulting reduction wouldbe 0.005 TPD. Jd. Accordingly, the Agency expects only "negligible" emission reduction from proposed regulations for this category. Ill. TECHNICAL FEASlBILTY AND ECONOMIC REASONABLENESS Technical Feasibility Particularlyin its Technical SuppqrtDocument, the Agency addresses various approaches to controlling YOM emissions from Group II product categories. See TSD at7-12 (Technical Feasibility ofControls). The Agency argues that "[a]ffected sources can meetthe requirements in the proposed amendments through a numberofreadily available control techniques." SR at 9. In the subsections below, the Board addresses the record on the issue of the technical feasibility ofthose techniques. Industrial Cleaning Solvents TheAgency notes the recommendation ofthe CTG that sources emitting more than IS pounds per day ofYOM through industrial cleaning comply with various requirements. TSD at 10 (§3.4), citing Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency states that the various cleaning activities "use a multitude ofdifferent solvents with different styles ofapplications." TSD at 10. The Agencyproposes regulations covering "a wide range ofproducts thatremove contaminants from parts, products, tools,

.48 machinery, and other work production areas." Id. The Agency stresses workpractices, solvent substitution, and controls as the chieftechniques for reducing YOM emissions in this category. !d. at 10-11; SR at 10. Work Practices. The Agency indicates that solvent managementpractices can reduce YOM emissions. TSD at 10. The Agency states that these practices "include keeping solvent containers and used applicators covered; properly storing and disposing ofspent solvents and used cleaning rags; minimizing air circulation around all cleaning operations; and implementing equipmentpractices thatreduce emission, e.g., leak detection and repairpractices." Id.; see Prop. 218 at 9 (proposed Section 218.187(d», Prop. 219 at 8 (proposed Scction 219.1 87(d». Alternate Control. The Agency states that add-on controls, equipmentmodification, and changing cleaning methods all can reduce YOM emissions. TSD at II. The Agency further states that "[t]he CTG recommends an overall control efficiency of85 percent reduction in emissions ofVOM, which is reflected in theproposed rule." Id.; see Prop. 218 at 8 (proposed Section 218.187(b)(3», Prop. 219 at 8 (proposed Section 219.187(b)(3». Solvent Substitution. The Agency notes that the CTG recommends the use oflow vapor pressure solvents because "the slowerevaporation reduces the amount ofVOM released into the atmosphere." TSD at II. The Agency states that its proposal reflects the recommended limit of 8 mm Hg at20 degrees Celsius in place of50 grams ofVOM perliter ofcleaning material. Id.; see Prop. 218 at 8 (proposed Section218.187(b)(2», Prop. 219 at 8 (proposed Section 2l9187(b)(2». The Agency claims that sources can also reduce YOM emissions with the use oflowYOM or no-YOM solvents. TSD at 10. The Agency notes that "[t]he CTG recommends a content limit of50 grams YOM per liter (0.42 Ib/gal) ofcleaning material for those industries that are not already covered, orto be covered, by a CTG." Id, citing Control Techniques Guidelines: Industrial Cleaning Solvents, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September2006. Specifically, the Agency states that the CTG proposes to exclude "certain categories fr<;>m the cleaning regulations, as these categories already have or will have theirown recommended workpractices and limitations." TSD at 11. The Agency further states that [t]hese categories include coating operations for aerospace, wood furniture, flat wood paneling, large appliance, metal furniture, plastic parts, paper film and foil, miscellaneous metal parts, auto and light-duty truck assembly, and shipbuilding and repair; flexible packagingprinting materials; lithographic printing materials; letterpress printing materials; fiberglass boatmanufacturing materials; and miscellaneous industrial adhesives." Id., see Prop. 218 at 5-6 (proposed Section 21 8. 187(a)(2)(B», Prop. 219 at4-5 (proposed Section 21 9. 187(a)(2)(B». The Agency also states that, as aresult ofdiscussions with industry, other states, and USEPA, it proposes to add additional "exemptions andhighcrYOM content limits for certain specific cleaning activities." TSD at 10. The Agency suggests that itoffers these additional exemptions

### 49

for categories that may not be able easily to meet proposed YOM content limits. 

### Id. at II. These exemptions include electrical and electronic components; precision optics; numismatic dies; stripping ofcured inks, coatings, and adhesives; cleaning ofresin, coating, ink, and adhesive mixing, molding, and application equipment; research and development laboratories; medical device orpharmaceutical manufacturing; and performance orquality assurance testing ofcoatings, inks, or adhesives. Further exclusion recommendation include cleaning ofpaper-based gaskets and clutch assemblies; cleaning ofadhesive application equipmentused for thin metal laminating; touch-up cleaning on circuitboards; cleaning ofcoating and adhesive application processes utilized to manufacture transdermal drug delivery product using less than three gallons per day ofethyl acetate; cleaning ofapplication equipmentused to apply coatings on satellites and radiation effect coatings; cleaning ofapplication equipment used to apply solvent-borne fluoropolymer coatings; cleaning ofultraviolet or electronbeam adhesive application; and cleaning ofelectrical cables. 

### Jd. at 11-12; see Prop. 218 at 6-7 (proposed Section 2l8.187(a)(2)(C)), Prop. 219 at 5-6 (proposed Section 219.1 87(a)(2)(C). Flat Wood Paneling CoatingLines The Agency states that the CTG refers to three options for controlling YOM emissions from flat wood paneling coating operations: reformulation, add-on controls, orworkpractices. TSD at 12 (§3.5); SR at 10. Material Reformnlation. The Agency states thatreformulation involves replacing highYOM coatings with low-YOM coatings. TSD at 12. Citing the CTG, the Agency argues that "water-based coatings 'are generally available' and 'can lower [YOM] emissions greatly, and most coatings operations are capable ofconverting to waterborne coatings.'" 

### Id., citing Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental Protection Agency, Office ofAirQuality Planning and Standards, September2006. The Agency further argues that sources can reformulatebyusing "coatings that emit almost zero YOM and are cured through the use ofultraviolet light or an electron beam." TSD at 12. The Agency acknowledges that "[t]he use ofsuch systems are more limited than those for waterbased coatings, but they are available." 

### Id. Add-On Controls. The Agency claims that, when a source uses high-YOM coatings, it can used add-on controls. TSD at 12. Citing 

### its experience with a range ofcoating operations, the Agency agrees with the CTG that "an overall control and capture efficiency of90 percent is a widely-accepted and readily available technique." 

### Id., citing Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, September 2006. WorkPractices. The Agency notes that50
[t]he CTG recommends specific workpractice requirements for flat wood paneling coating operations: storing all [YOM] coatings, thinners, and cleaning materials in close containers, minimizing spills of[YOM] containing coatings, thinners, cleaning up spills immediately, conveying any coatings, thinners, and cleaning materials in closed containers orpipes, closing mixing vessels which contain [YOM] coatings and other materials except when specifically in use, and minimizing emissions of[YOM] during cleaning ofstorage, mixing, and conveying equipment." TSD at 12, citing Control Techniques Guidelines for Flat Wood Paneling Coatings, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September2006. TheAgency states thatIllinois has already adopted some ofthese requirements through regulations for wood furniture coaters. TSD at 12. The Agency further states that its proposal will apply those requirements and other specific requirements to flat wood paneling coaters. !d. Flexible Packaging PrintingLines The Agency states that YOM emissions from flexible package printing operations stem largely from evaporation ofinks, coatings, and adhesives, and from the use ofcleaning materials. TSD at 9 (§3.3). The Agency argues that these emissions can be controlled through material reformulation, add-on controls, and workpractices. 

### Id. at 9-10; see SR at 10. Material Reformulation. This control substitutes high-YOM inks, coatings, and adhesives with low-YOM versions ofthose materials. TSD at 9. Citing the CTG, the Agency argues that "such reformulation 'has been achieved by any facilities in the packaging rotogravure and flexographic printing industries. '" 

### Id., citing Control Techniques Guidelines for Flexible Package Printing, United State Environmental Protection Agency, Office ofAir Quality Planning and Standards, September2006. The Agency acknowledges that "[w]hetheraparticularfacility is able to use such reformulatedmaterial depends upon their specific activities, including the substrate(s) being used." TSD at 9. Add-On Controls. TheAgency states that all flexible packagingprinters can use add-on controls. TSD at 9. TheAgency argues that "[t]he most common control devices used by these sources are thermal oxidizers, catalytic oxidizers, and carbon adsorbers, with adsorbers probably being the least-used ofthe three." 

### Id. The Agency agrees with the CTG that "[t]oday, these control devices can achieve at least 95 percent control device efficiency." 

### Id., citing Control Techniques Guidelines for Flexible Package Printing. United State Environmental Protection Agency, Office ofAir QualityPlanning and Standards, September2006. The Agency also describes capture systems, which collect air containing YOM "so it may be destroyed orreclaimed by the control device

...." TSD at 9. The Agency notes that, "[w]hile new presses may be able to obtain as high as I00 percent capture ifdesignedproperly, older presses were not necessarily constructed with emissions capture in mind." 

### Id. The Agency proposes a tiered approach to capture efficiencybased on the construction date oftheprinting line and the control device. !d.; see Prop. 218 at 63-64 (proposed Section218.401 (c)(3», Prop. 219. at 62 (proposed Section 219.401(c)(3).51

Work Practices. 11le Agency notes thatthe CTG "recommcnds work practice requirements as thebest means to control emissions from cleaning operations at flexible package printing sources." TSD at 10. The Agency lists some ofthese practices: "keeping solvent containers closed except when filling, draining or conducting cleaning operations, keeping used shop towels in closed containers, and conveying cleaning materials from one location to another in closed containers orpipes." ld., citing Control Techniques Guidelines for Flcxible Package Printing, United States Environmental ProtectionAgency, Office ofAir Quality Planning and Standards, September2006. Lithographic Printing Lines The Agency addresses three options for regulating YOM emissions from lithographic printing lines: add-on controls, fountain solution reformulation andprocess modification, and material reformulation or substitntion for cleaning solutions. TSD at 7-8 (§3.1); 

### see SR at 10. Add-On Controls. The Agency states that add-on controls apply only to heatsetweb offset lithographicprinting and not to non-heatset or sheet-fed lithographic printing. TSD at 7. The Agency further states that these add-on controls fall into two broad categories: combustion control devices "dcsigned to destroy YaMs in the vent stream prior to atnlospheric discharge" and recovery devices that "limitYOM emissions byrecovering material for reuse." ld. The Agency indicates that heatset web offset lithographic printers use three add-on controls: thermal afterburners, catalytic afterburners, and condenserfilter systems. ld. The Agency's experience leads it to conclude "that the field is dominated by thermal and catalytic afterburners, which can often achieve 98 percent orgreaterYOM remova1." ld. The Agency also reports that condenser filter systems have been designed specifically for heatset web offsetprinters with efficiency as high as 97 percentremova1. ld. Fountain Solution Reformulation and Process Modifications. TheAgency argues that "[a] significantportion ofYOM emissions from lithographic printing canbe ascribed to evaporation from fountain solutions." TSD at 8. The Agency states that substitntes reduce or replace alcohol in fountain solutions. ld. The Agency further states that the substitntes have lowervolatility and reduce emissions. ld. The Agency characterizes process modifications as "changes in operational methods or equipmentresulting in improved YOM control." TSD at 8. The Agency names cooling fountain solution to minimize evaporation as one process modification thatreduces YOM emissions. ld. The Agency claims thatthe use ofrefrigerated circulators to cool fountain solution "has been shown to reduce consumption ofalcohol in the solution by as much as 44 percent." ld. Althoughprocess modification may involve retrofitting orreplacing existing equipment, the Agency "does not expectretrofitting orreplacement to be an issue with this rulemaking." ld. Material Reformulation or Substitution for Cleaning Solutions. The Agency describes two reformulations to reduce YOM emissions from cleaning solutions. First, sources can use solutions containing a smaller amount ofYOM. TSD at 8. CurrentIllinois regulations now limitthese solutions to no more than 30 percent YOM by weight. ld.; 

### see 35 Ill. Adm. Code52
218.407(a)(4)(A)(i); 35 Ill. Adm. Code 219.407(a)(4)(A)(i). The Agency rcports that, "[w]hile no problems with this limithave been reported to Agency personnel in Illinois, there have apparentlybeen complaints on a national level." TSD at 8. The Agency notes that "the CTG now recommends limiting such solutions to 70 percent VOM." !d., citing Control Techniques Guidelines for Offset Lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency proposes to apply "this higherlimit for sources between 15 and 100pounds per day (PPD), with the previous limit remaining in effect for larger sources." TSD at 8; see Prop. 218 at 88 (proposed Section 2l8.407(a)(4)(A»; Prop. 219 at 87 (proposed Section 219.407(a)(4)(A)). Second, the Agency reports that sources can rely on cleaning solution with a low vapor pressure. TSD at 8. Citing the CTG, the Agency states that "[c]leaning solutions with [YOM] composite vaporpressure less than I0 millimeters ofmercury (mm Hg) at20·C have been used successfullyby many printers for blanket washing and other cleaning activities. Jd., citing Control Techniques Guidelines for OffsetLithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office ofAir Quality Planning and Standards, September 2006. The Agency further states that, before Il1inois adopted its previous lithographic printing rules, USEPA determined that the use ofsuch materials results in emission reductions comparable "to using cleaning materials thatcontain less than 30 weightpercent VOM." TSD at 8. Because the Agency believes that sources now use these materials withoutdifficulty, it proposes not to amend the limitbut to apply itto smaller sources. Jd.; see Prop. 218 at79 (proposed Section 218.405(c)(3)(C); Prop. 219 at 78 (proposed Section219.405(c)(3)(C). Letterpress Printing The Agency states that the sources ofVOM emissions from letterpress printing are similarto those for lithographic printing, except "thatletterpress operations do notuse a fountain solution." TSD at 9; SR at 10. TheAgency further states that "letterpress printingpresses are often operated atthe same source as lithographic printing[,] and many ofthe control options for letterpress printing are the same as the control options for lithographic printing," particularly with regard to cleaning solutions. TSD at 9. Arguing that "letterpress operations have neverbeen specificallyregulated in Illinois before, thc Agency is proposing to use the 70 percent YOM content limit for all subject letterpress units." TSD at 9; see Prop. 218 at 115 (proposed Section 218.4I3(a)(2», Prop. 219 at 115-16 (proposed Section 219.413(a)(2». The Agency indicates on thebasis ofcommunication with industry representatives "thatIllinois does not currently contain any heatset web letterpress operations in eitherthe Chicago orMetro-EastNAA.

..." TSD at 9. The Agency argues, however, that "the regulation is necessary and technically feasible should anew such operation locate in onc ofthe NAAs." Jd. Economic Reasonableness
In its Technical Support Document, the Agency addresses the economic reasonableness ofvarious approaches to controlling YOM emissions from Group II product categories. See

### 53

TSD at 13-15. The Agency argues that the control techniques described above "are economicallyreasonable, particularly as many ofthe techniques are already widelyused by the affected industries" SR at 10. In the subsections below, the Board addresses the record on the issue ofthe economic reasonableness ofthose techniques. Industrial Cleaning Solvents The Agency cites USEPA's estimate that the proposedregulation would affect 130 Illinois sources withbaseline YOM emissions of2528 tons peryear. TSD at 14 (§4.4) (referring to 2002 National Emissions Inventory database). The Agency also notes USEPA's determination that "the cost effectiveness ofmeeting the 50 grams ofVOM per liter ofcleaning material limitfor aparts cleanerat $1 664/ton based on a studyprovided by the California Bay Area AirQualityManagement District." TSD at 14. The Agency indicates that sources switching from high-YOM content solvents to low-YOM content solvents mayrealize savings of $

### 1325/tonbecause oflower disposal costs. !d

.



### . Flat Wood Paneling Coating Lines The Agency notes that USEPA relied upon data from the South Coast Air Quality Management District ofCalifornia to estimate cost effectiveness "ofbetween $1,900 and $2,600 perton ofYOM reduced (in 2005 dollars)." TSD at 14 (§4.5). The Agency also cites the CTG to indicate that Illinois sources subjectto the proposed rule could incur costs to make their coatings compliant. 

### Id. at 14-15, citing Control Techniques Guidelines for FlatWood Paneling Coatings, United States Environmental ProtectionAgency, Office ofAir QualityPlanning and Standards, September 2006. TheAgency concludes that "theonly significant costis expectedto bereformulation ofcoatings." TSD at 15. Flexible Packaging Printing Lines The Agency cites the CTG to claim that "[m]any facilities located in ozone nonattainment areas are already meeting the control levels being recommended in this CTG." TSD at 14 (§4.3), citing Control Techniques Guidelines for Flexible Package Printing, United States Environmental Protection Agency, Office ofAir QualityPlanning and Standards, September2006. The Agency argues that this proposal does not expand the number ofsources thatwill be subjectto the ink or control device portions ofthe flexible packagingrotogravure and flexographic printing regulations. It 

### is expected that those sources currently able to use compliantinks and coatings will similarly be ableto make use ofinks and coatings meeting the new compliance limit, while those using add-on control devices will continue to do so as well. As such, the llIinois EPA expects that there will notbe any additional add-on control costs for subjectfacilities. TSD at 14. The Agency cites the CTG to state that sources installing add-on control devices will face costs that varybased on operating factors. 

### Id. The Agency cites the CTG to estimate that '''apress54

.exhausting approximately 5,800 cubic feet per minute, operating 2000 hours peryear, and

achieving 70 percent capture efficiency' would have acost ofbetween $1,300 and $2,800 per ton ofYOM removed." ld., citing Control Techniques Guidelines for FlexiblePackage Printing, United States Environmental Protection Agency, Office ofAir QualityPlanning and Standards, September 2006. The Agency argues that factors including more operating hours would lower the costper ton ofYOM removed. TSD at 14. Addressing the cleaningprovisions ofits proposal, the Agency expects "minimal" costs for sources becoming subject to those regulations. TSD at 

### J4. The Agency argues that "some sources may see an overall costs savings as less cleaning solution 

### 1S necessary." ld. Lithographic Printing Lines The Agency argues that "[t]he largest cost factor for lithographic printing

-- add-on controls

- is applicable to heatset web lithographic operations only. Since the Agency's proposal does not increase the number ofsources for which this requirement is applicable, there is no foreseen additional cost due to add-on controls for existing sources." TSD at 13 (§4.1). Although the Agency acknowledges that new sources will be subjectto ahigher control efficiency, it expects new control devices to achieve that efficiency. ld. The Agency argues that "no additional cost is expected for this reason either." ld. The Agency states that its proposal could result in costs for newly-regulated sources emittingbetween 15 and 100 pounds per day ofYOM. TSD at 13. The Agencyreports that "USEPA estimated the cost for cleaning material refonnulation at $855 perton ofYOM removed (in 2005 dollars)." ld., citing Control Techniques Guidelines for OffsetLithographic Printing and Letterpress Printing, Unites States Environmental Protection Agency, Office ofAir QualityPlanning and Standards, September2006. The Agency notes thatUSEPA projects acosts savings with fountain solutions because ofreduced alcohol use. TSD at 13. TheAgency indicates that, although USEPAhas not specifically estimated the amount ofthese savings, itnotes that "the TSD forthe Illinois lithographic printingrule in 1994 put this savings at $920 perton. ld. The Agency explains that, "while alcohol substitutes are more expensive, the cost is reduced because they are used in lower quantities." ld., citing Technical Support Document for Controlling YOM Emissions from Lithographic Printing Operations, Illinois Environmental Protection Agency, October 1994. Letterpress Printing The Agency cites the CTG to state that, [b]ecause ofthe similarities between offset lithographic printing and letterpress printing in tenns ofthe nature ofthe processes at issue, the sources of[YOM] emissions and available control approaches, it is reasonable to assume thatthe cost-effectiveness estimates

... for control of[YOM] from heatset inks and control of[YOM] from cleaning materials apply equally to the letterpress printing industry. TSD at 13 

### ('14.2), citing Control Techniques Guidelines for Offset55 lithographic Printing and Letterpress Printing, United States Environmental Protection Agency, Office ofAirQuality Planning and Standards, September 2006. The Agency acknowledges that, because Illinois does notnow regulate heatset web letterpress printing operations, "the reasoning behind the zero cost estimate for heatset web lithographic printing" does not apply to letterpress printing. TSD at 13. The Agency notes the CTG's estimate of$2,010per ton ofVOM removed in 2005 dollars as the cost-effectiveness for this category. 

### Id. However, the Agency emphasizes that there are not now any heatsetweb letterpress operations in either ofthe Illinois NAAs. 

### Id. Summarv and Findings Although the Board in a letter dated August 6, 2009, requested that DCEO conduct an economic impact study on the Agency's amended rulemaking proposal (see 415 ILCS 5/27(b)(1) (2008)), the Board to date has received no response to thatrequest. Atthe secondhearing, the Board received no testimony or commentregarding the absence ofany response to the request. See Tr.2 at 8-9. In his pre-filed testimony on behalfofthe Agency, Mr. Bloomberg states that "[t]he Agency agrees with USEPA that all ofthe proposed changes are technically feasible and economicallyreasonable." Bloomberg Test. at 

### 8. No participanthas offeredevidence or arguments rebutting this position. Having reviewed the record on the issues of feasibility and reasonableness, the Board finds itthat the Agency's proposal, as amended by two motions to amend, is both technically feasible and economically reasonable. CONCLUSION The Boardproposes for first notice amendments to its regulations governing YOM emissions in Parts 211,218 and 219 (35 Ill. Adm. Code 211, 218, 219). Substantively, the Board is adopting the Agency's proposal including changes reflected in two Agency motions to amend grantedby the Board. See Mot. Amend I, Mot. Amend 2. Publication ofthe proposed amendment in theIllinois Registerwill start aperiod ofat least45 days during which any person may file public comments with the Clerk ofthe Board at the address provided above in this opinion. As noted above, persons may also file comments electronically through COOL at www.ipcb.state:iJ.us. 

### ORDER The Board directs the Clerkto cause first-notice publication ofthe following proposed amendments to Parts 211, 218, and 219 ofthe Board's airpollutionregulations in theIllinois Register. Proposed additions to Parts 211, 218, and 219 are underlined, and proposed deletions appear stricken.