BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: ) 

) 

REASONABLY AVAILABLE CONTROL ) 

TECHNOLOGY (RACT) FOR VOLATILE ) 

ORGANIC MATERIAL EMISSIONS FROM ) 

GROUP II AND GROUP IV CONSUMER & ) 

COMMERCIAL PRODUCTS: PROPOSED ) 

AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 

218,and219 ) 

To: John Therriault, Assistant Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph, Suite 11-500 

Chicago, Illinois 60601-3218 

NOTICE 

SEE ATTACHED SERVICE LIST 

R 11-23 

(Rulemaking-Air) 

PLEASE TAKE NOTICE that I have today filed with the Office of the Pollution Control 

Board the POST-HEARING COMMENTS OF THE ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY, a copy of which is herewith served upon you. 

DATED: May 16,2011 

1021 N. Grand Ave. East 

P.O. Box 19276 

Springfield, IL 62794-9276 

(217) 782-5544 

Respectfully submitted, 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

Assistant Counsel 

Division of Legal Counsel 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: ) 

) 

REASONABLY AVAILABLE CONTROL ) 

TECHNOLOGY (RACT) FOR VOLA TILE ) 

ORGANIC MA TERJAL EMISSIONS FROM ) 

GROUP II AND GROUP IV CONSUMER & ) 

COMMERCIAL PRODUCTS: PROPOSED ) 

AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 

218,and219 ) 

R11-23 

(Rulemaking -Air) 

POST-HEARING COMMENTS OF THE 

ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

The ILLINOIS ENVIRONMENTAL PROTECTION AGENCY ("Illinois EPA" or 

"Agency"), by its attorney, hereby submits its post-hearing comments in the above rulemaking 

proceeding. 

PH and SOIA Comments 

On April 15,2011, the Printing Industry of Illinois/Indiana Association and the Specialty 

Graphic Imaging Association ("PIIISGIA") submitted comments to the Board, suggesting 

several revisions to the Agency's proposal. On April 25, 2011, the Illinois EPA filed a Motion to 

Amend Rulemaking Proposal ("Motion to Amend"), which addressed two of PIIISGIA' s 

comments regarding testing requirements for lithographic printers that employ add-on control 

devices, set forth in Section 218/219.409(a). (In the Motion to Amend, the Illinois EPA opposed 

PIIISGIA's request tbat Section 218/219.409(a) be amended to eliminate testing requirements for 

printing lines that have previously conducted testing, as the USEP A requires the testing language 

contained in the Motion to Amend. The Illinois EPA also opposed PIIISGIA's request to 

increase the amount of time sources are given to perform testing. The Illinois EPA explained 

that 90 days has been the standard for many years, and PIIISOIA provided no compelling reason 

to double the time frame to 180 days. Further, it is unclear whether this change would be 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

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acceptable to the USEPA.) The Illinois EPA's responses to PIIISGIA's remaining comments are 

set forth below. 

First, PIIISGIA requests that cleaning of substrates prior to screen printing be added to 

the list of exemptions in Section 218/219.187(a)(2)(A). The Illinois EPA submitted PIIISGIA's 

proposed revision to the USEP A. USEP A indicated that there is not currently a sufficient basis 

for the exemption, and requested additional information in order to further evaluate the proposed 

amendment. The Illinois EPA communicated this request to PIIISGIA, and understands that 

PIIISGIA is in the process of responding. To date, however, the Illinois EPA has not received a 

response. Unless and until PIIISGIA submits the requested information and the USEPA 

approves the amendment, the Illinois EPA opposes adding the exemption. 

Next, PIlISGIA requests that the exemption set forth in Section 

21 8/219. 1 87(a)(2)(C)(xiv) regarding cleaning of metering rollers, dampening rollers, and 

printing plates be removed to avoid confusion. The Illinois EPA indicated at hearing that it 

would likely agree, but since that time, the Agency was contacted by al10ther industry group that 

may oppose such a change. The Illinois EPA needs to work with the other group and USEP A to 

determine the proper course of action, and thus does not have a specific response to this issue at 

the present time. 

PIIISGIA requests that Section 218/219 .1 87(a)(2)(C) be amended to exclude cleaning 

operations listed in sucb subsection from recordkeeping obligations. The USEP A has advised, 

however, that exempting such cleaning operations from the recordkeeping requirements in 

subsection (e) is not acceptable. USEP A further advised that sources with cleaning operations 

subject to subsections (a)(2)(C)(v) and (a)(2)(C)(xiii) must comply with the additional 

recordkeeping/reporting requirements set forth in Section 218/219.187( e )(7) of the Illinois 

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EPA's proposal. Given the USEPA's position, the Illinois EPA strongly opposes PIIISGJA's 

proposed changes, as the USEP A could once again disapprove this rule if such changes are 

made. 

PIIISGJA requests that Section 218/219.187(e) be revised to iuclude a fifty percent 

retention factor for cleaning solvents that have a vapor pressure of 10 mm Hg or less and that are 

kept in closed containers. The Illinois EPA does not object to this revision, but recommends that 

it be included in a different subsection, as set forth below. The USEP A has advised that the 

revision is acceptable, provided that the language clarifies that sources must demonstrate that the 

vapor pressure falls below the specified threshold. The Illinois EPA therefore recommends the 

following amendments: 

Section 218.187 Other Industrial Solvent Cleaning Operations 

e) Recordkeeping and Reporting Requirements 

I) The owner or operator of a source exempt from the limitations of this 

Section because of the criteria in Section 218.187(a)(l) of this Subpart 

shall comply with the following: 

A) By January 1,2012, or upon initial start-up of the source, 

whichever is later, submit a certification to the Agency that 

includes: 

i) A declaration that the source is exempt from the 

requirements of this Section because of the criteria in 

Section 218.187(a)(1); 

ii) Calculations that demonstrate that combined emissions of 

YOM from cleaning operations at the source, other than 

cleaning operations identified in subsection (a)(2) of this 

Section, never equal or exceed 226.8 kg/month (500 

Ibs/month), in the absence of air pollution control 

equipment. An emission adjustment factor of 0.50 shall be 

used in calculating emissions from used shop towels if the 

YOM composite vapor pressure of each associated cleaning 

solution is demonstrated to be less than 10 mmHg 

measured at 20°C (68°F) and the shop towels are kept in 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

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Section 219.187 

closed containers. For cleaning solutions with YOM 

composite vapor pressures of equal to or greater than 10 

mmHg.measured at 20"C (68°F) and for shop towels that 

are not kept in closed containers. no emission adjustment 

factor shall be used; 

Other Industrial Solvent Cleaning Operations 

e) Recordkeeping and Reporting Reqnirements 

I) The owner or operator of a source exempt from the limitations of this 

Section because of the criteria in Section 219.187( a)( 1) of this Snbpart 

shall comply with the following: 

A) By January 1,2012, or upon initial start-up of the source, 

whichever is later, submit a certification to the Agency that 

includes: 

i) A declaration that the source is exempt from the 

requirements of this Section becanse of the criteria in 

Section 219.187(a)(1); 

ii) Calculations that demonstrate that combined emissions of 

YOM from cleaning operations at the source, other than 

cleaning operations identified in subsection (a)(2) of this 

Section, never equal or exceed 226.8 kg/month (500 

Ibs/month), in the absence of air pollution control 

equipment. An emission adjustment factor of 0.50 shall be 

used in calculating emissions from used shop towels if the 

YOM composite vapor pressure of each associated cleaning 

solution is demonstrated to be less than 10 mmI-Ig 

measured at 20°C (68°F) and the shop towels are kept in 

closed containers. For cleaning solutions with YOM 

composite vapor pressures of equal to or greater than 10 

mmHg measured at 20°C (68°F) and for shop towels that 

are not kept in closed containers. no emission adjustment 

factor shall be used; 

Finally, PIIISGIA requests that Section 218/219.411 (b)(1 )(F) be amended to remove 

certain recordkeeping requirements contained in the Illinois EPA's proposal. Specifically, 

PIIISGIA recommends deleting the requirement that sources' material use records include the 

name, identification number, and YOM content of each cleaning solvent and fountain solution 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
additive used per calendar month. The USEP A, however, has indicated that these records are 

required in order to determine whether the material use thresholds are exceeded. (See USEPA's 

letter to the Agency, dated March 7, 2011, and submitted to the Board on April 14, 2011, as an 

Exhibit to the Testimony of David Bloomberg and Testimony ofYoginder Mahajan.) As the 

USEP A mandated these recordkeeping requirements, the Illinois EPA opposes PIIISGIA' s 

proposed deletion. 

Emission Adjustment Factor for Lithographic Printers 

The addition of an emission adjustment factor for cleaning materials in Section 

218/219.187 is based upon a similar provision in the existing rule for lithographic printing 

operations. To remain consistent with the language recommended by the Illinois EPA above for 

industrial cleaning solvents, and in compliance with a recommendation by the USEP A, the 

Illinois EPA proposes amending Section 218/219.411(b)(1) and (2) to specify that lithographic 

printing sources wishing to utilize the emission adjustment factor for cleaning materials must 

demonstrate that the vapor pressure falls below the specified threshold: 

Section 218.411 Recordkeeping and Reporting for Lithographic Printing 

b) Exempt Units on and after August 1, 2010 

1) Lithographic Printing Lines Exempt pursuant to Section 218.405(c)(2) 

B) Calculations that demonstrate that combined emissions ofVOM 

from all lithographic printing lines (including inks, fountain 

solutions, and solvents used for cleanup operations associated with 

the lithographic printing lines) at the source do not equal or exceed 

6.8 kg/day (15 lbs/day), before the use of capture systems and 

control devices, as follows: 

i) To calculate daily emissions ofVOM, the owner or 

operator shall determine the monthly emissions ofVOM 

from all lithographic printing lines at the source (including 

solvents used for cleanup operations associated with the 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
lithographic printing lines) and divide this amount by the 

number of days during that calendar month that 

lithographic printing lines at the source were in operation; 

ii) To determine the YOM content of the inks, fountain 

solution additives and cleaning solvents, the test methods 

and procedures set forth in Section 21S.409(c) of this 

Subpart shall be used; 

iii) To determine YOM emissions from inks used on 

lithographic printing lines at the source, an ink emission 

adjustment factor of 0.05 shall be used in calculating 

emissions from all non-heatset inks except when using an 

impervious substrate, and a factor of O.SO shall be used in 

calculating emissions from all heatset inks to account for 

YOM retention in the substrate except when using an 

impervious substrate. For impervious substrates such as 

metal or plastic, no emission adjustment factor is used. The 

YOM content of the ink, as used, shall be multiplied by this 

factor to determine the amount of YOM emissions from the 

use of ink on the printing lines; and 

iv) To determine YOM emissions from cleaning solutions used 

on lithograpbic printing lines at thc source, an emission 

adjustment factor of 0.50 shall be used in calculating 

emissions from used shop towels if the YOM composite 

vapor pressure of each associated cleaning solution is 

demonstrated to be less than 10 mmi-ig measured at 20°C 

(6S0F) and the shop towels are kept in closed containers. 

For cleaning solutions with YOM composite vapor 

pressures of equal to or greater than 10 mmi-ig measured at 

20°C (6S0F) and for shop towels that are not kept in closed 

containers, no emission adjustment factor is used; 

2) I-Ieatset web offset lithographic printing lines exempt pursuant to Section 

2IS.405(c)(l) but not exempt pursuant to Section 2IS.405(c)(2). 

B) Calculations that demonstrate that combined emissions of YOM 

from all lithographic printing lines (including inks, fountain 

solutions, and solvents used for cleanup operations associated with 

the lithographic printing lines) at the source never exceed 45.5 

kg/day (100 lbs/day) before the use of capture systems and control 

devices, as follows (the following methodology shalfalso be used 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
to calculate whether a source exceeds 45.5 kg/day (100 Ibs/day) for 

purposes of determining eligibility for the exclusions set forth in 

Section 218.415( c )(3), in accordance with Sections 

218.411 (g)(2)(A)(i): 

i) To calculate daily emissions of YOM, the owner or 

operator shall determine the monthly emissions of 

YOM from all lithographic printing lines at the 

source (including solvents used for cleanup 

operations associated with the lithographic printing 

lines) and divide this amount by the number of days 

during that calendar month that lithographic 

printing lines at the source were in operation; 

ii) To determine the YOM content of the inks, fountain 

solution additives and cleaning solvents, the test 

methods and procedures set forth in Section 

218.409(c) of this Subpart shall be used; 

iii) To determine YOM emissions from inks used on 

lithographic printing lines at the source, an ink 

emission adjustment factor of 0.05 shall be used in 

calculating emissions from all non-heatset inks 

except when using an impervious substrate, and a 

factor of 0.80 shall be used in calculating emissions 

from all heatset inks to account for YOM retention 

in the substrate except when using an impervious 

substrate. For impervious substrates such as metal 

or plastic, no emission adjustment factor is used. 

The YOM content of the ink, as used, shall be 

multiplied by this factor to detelmine the amount of 

YOM emissions from the use of ink on the printing 

lines; 

iv) To determine YOM emissions from cleaning 

solvents used on lithographic printing lines at the 

source, an emission adjustment factor of 0.50 shall 

be used in calculating emissions from cleaning 

solution in shop towels if the YOM composite 

vapor pressure of such cleaning solution is 

demonstrated to be less than 10 mmHg measured at 

200

e (68°F) and the shop towels are kept in closed 

containers. For cleaning solutions with YOM 

composite vapor pressures of equal to or greater 

than 10 mmHg measured at 200e (68°F) and for 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Section 219.411 

shop towels that are not kept in closed containers, 

no emission adjustment factor is used; 

Reeordkeeping and Reporting for Lithographic Printing 

b) Exempt Units on and after August 1,2010 

I) Lithographic Printing Lines Exempt pursuant to Section 219.405(c)(2) 

B) Calculations that demonstrate that combined emissions ofVOM 

from all lithographic printing lines (including inks, fountain 

solutions, and solvents used for cleanup operations associated with 

the lithographic printing lines) at the source do not equal or exceed 

6,8 kg/day (15 lbs/day), before the use of capture systems and 

control devices, as follows: 

i) To calculate daily emissions ofVOM, the owner or 

operator shall dctermine the monthly emissions ofVOM 

from all lithographic printing lines at the source (including 

solvents used for cleanup operations associated with the 

lithographic printing lines) and divide this amount by the 

number of days during that calendar month that 

lithographic printing lines at the source were in operation; 

ii) To determine the YOM content ofthe inks, fountain 

solution additives and cleaning solvents, the test methods 

and procedures set f01th in Section 219 .409( c) of this 

Subpart shall be used; 

iii) To determine YOM emissions from inks used on 

lithographic printing lines at the source, an ink emission 

adjustment factor of 0.05 shall be used in calculating 

emissions from all non-heatset inks except when using an 

impervious substrate, and a factor of 0.80 shall be used in 

calculating emissions from all heatset inks to account for 

YOM retention in the substrate except when using an 

impervious substrate. For impervious substrates such as 

metal or plastic, no emission adjustment factor is used. The 

YOM content of the ink, as used, shall be multiplied by this 

factor to determine the amount ofVOM emissions from the 

use of ink on the printing lines; and 

iv) To determine YOM emissions from cleaning solutions used 

on lithographic printing lines at the source, an emission 

adjustment factor of 0.50 shall be used in calculating 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
emissions trom used shop towels if the YOM composite 

vapor pressure of each associated cleaning solution is 

demonstrated to be less than 10 mmHg measured at 20°C 

(6SoF) and the shop towels are kept in closed containers. 

For cleaning solutions with YOM composite vapor 

pressures of equal to or greater than 10 mmHg measured at 

20°C (6SoF) and for shop towels that are not kept in closed 

containers, no emission adjustment factor is used; 

2) Heatset web offset lithographic printing lines exempt pursuant to Section 

219.405(c)(l) but not exempt pursuant to Section 219.405(c)(2). 

B) Calculations that demonstrate that combined emissions ofVOM 

from all lithographic printing lines (including inks, fountain 

solutions, and solvents used for cleanup operations associated with 

the lithographic printing lines) at the source never exceed 45.5 

kg/day (l00 Ibs/day) before the use of capture systems and control 

devices, as follows (the following methodology shall also be used 

to calculate whether a source exceeds 45.5 kg/day (100 Ibs/day) for 

purposes of determining eligibility for the exclusions set forth in 

Section 219.405(c)(3), in accordance with Section 

219.41 I (g)(2)(A)(i»: 

i) To calculate daily emissions ofVOM, the owner or 

operator shall determine the monthly emissions ofVOM 

from all lithographic printing lines at the source (including 

solvents used for cleannp operations associated with the 

lithographic printing lines) and divide this amount by the 

number of days during that calendar month that 

lithographic printing lines at the source were in operation; 

ii) To determine the YOM content of the inks, fountain 

solution additives and cleaning solvents, the test methods 

and procedures set forth in Section 219.409(c) of this 

Subpart shall be used; 

iii) To determine YOM emissions from inks used on 

lithographic printing lines at the source, an ink emission 

adjustment factor of 0.05 shall be used in calculating 

emissions from all non-heatset inks except when using an 

impervious substrate, and a factor of 0.80 shall be used in 

calculating emissions from all heatset inks to account for 

YOM retention in the substrate except when nsing an 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
impervious substrate. For impervious substrates such as 

metal or plastic, no emission adjustment factor is used. The 

YOM content of the ink, as used, shall be multiplied by this 

factor to determine the amount of YOM emissions from the 

use of ink on the printing lines; 

iv) To determine YOM emissions from cleaning solvents used 

on lithographic printing lines at the source, an emission 

adjustment factor of 0.50 shall be used in calculating 

emissions from cleaning solution in shop towels if the 

YOM composite vapor pressure of such cleaning solution is 

demonstrated to be less than 10 mmHg measured at 20°C 

(68°F) and the shop towels are kept in closed containers. 

For cleaning solutions with YOM composite vapor 

pressures of equal to or greater than 10 mmHg measured at 

20°C (68°F) and for shop towels that are not kept in closed 

containers, no emission adjustment factor is used; 

Pleasure Craft Surface Coatings 

On May 6, 2011, the American Coatings Association CACA") prefiled testimony with 

the Board, requesting revisions to certain definitions applicable to pleasure craft surface coatings, 

higher YOM limits for certain subcategories of pleasure craft coatings, and a "small container 

exemption." The Illinois EPA submitted the ACA's testimony to the USEPA. 

The USEPA advised that inclusion of a small container exemption in Section 

218/219.208, as set forth below, is acceptable. Likewise, USEPA indicated that the ACA's 

proposed revision to the definition of "extreme high gloss coating," which was proposed by the 

Agency in its Motion to Amend, is acceptable as well. USEPA advised that the ACA's proposed 

revision to the definition of "pretreatment wash primer" might be acceptable, but the USEP A 

needs more information regarding how the revision will impact YOM emissions. The Illinois 

EPA intends to work with the ACA and USEP A regarding this issue. 

Finally, the USEPA indicated that the YOM limitations for pleasure craft surface 

coatings can be amended as set forth below, provided that the existing emissions averaging 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
alternative for such coatings is eliminated. The averaging alternative was intended to satisfy the 

pleasure craft coating industry's need for higher emission limitations. If higher limits are instead 

implemented, there is no further need for an averaging option. The regulation may therefore 

contain either higher YOM limits or emissions averaging, but not both. Based on subsequent 

discussions with the ACA, in which the ACA expressed a preference for higher YOM 

limitations, the Illinois EPA proposes eliminating the emissions averaging alternative and 

amending celiain limits, as follows: 

Part 218: 

Section 218.204 Emission Limitations 

q) Miscellaneous Metal Parts and Products Coatings and Plastic Parts and Products 

Coatings On and After May 1,2012 . 

.. , ............................ 

5) Pleasure Craft Surface Coatings 

kg/I kg/I 

(lb/gal) (lb/gal) 

coatings solids 

A) Extreme high gloss coating - topcoat 0.60(M9 1.88-hW 

Q&)~ ill.§)~ 

B) High gloss coating - topcoat 0.42 0.80 

(3.5) (6.7) 

C) Pretreatment wash primer 0.78 6.67 

(6.5) (55.6) 

D) Finish primer/surfacer M;J, (}..W 

fBj E&.+l 

Prior to January 1,2014: 0.60 1.88 

(5.0) ill.§) 

On and after January I. 2014: 0.42 0.80 

(3.5) (6.7) 

E) High build primer/surfacer 0.34 0.55 

(2.8) (4.6) 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
F) Aluminum substrate anti foul ant 0.56 1.53 

coating (4.7) (12.8) 

0) Other substrate antifoulant coating 0.40(8; ~73~ 

(3.3)~ fl.[)(441 

ill Antifouling Sealer/Tie Coat 0.42 0.80 

ll2l (Q1} 

1M) All other pleasure craft surface 0.42 0.80 

coatings for metal or plastic (3.5) (6.7) 

Section 218.207 Alternative Emission Limitations 

a) Any owner or operator of a coating line subject to Section 218.204 of this 

Subpart, except coating lines subject to Section 218.204(q)(6), may comply with 

this Section, rather than with Section 218.204 of this Subpart, if a capture system 

and control device are operated at all times the coating line is in operation and the 

owner or operator demonstrates compliance with subsections (c), (d), (e), (f), (g), 

(h), (i), G), (k), (1), (m), or (n) of this Scction (depending upon the source 

category) through the applicable coating analysis and capture system and control 

device efficiency test methods and procedures specified in Section 218.1 05 of this 

Part and the recordkeeping and reporting requirements specified in Section 

218.211(e) of this Subpart; and the control device is equipped with the applicable 

mouitoring equipment specified in Section 218.1 05( d) of this Part and the 

monitoring equipment is installed, calibrated, operated and maintained according 

to vendor specifications at all times the control device is in use. A capture system 

and control device, which does not demonstrate compliance with subsection (c), 

(d), (e), (t), (g), (h), (i), (j), (k), (I), (m), or (n) of this Section may be used as an 

alternative to compliance with Section 218.204 of this Snbpart only if the 

alternative is approved by the Agency and approved by the USEP A as a SIP 

revision. The owner or operator of a pleasure craft surface coating operation 

subject to Section 218.204(q)(5)(A) through (G) of this Subpart may also comply 

with subsection (0) of :his Section, rather than with Section 218.204 of this 

Subpart. 

0) Emissions Averaging Alternative for Pleasure Craft Surfaee Coating Operations. 

The ovmer or operator ofa source with coating operations subject to the 

requirements of Section 218.204(q)(5)(A) through (G) may elect to include such 

operations in the emissions averaging alternative. Coating operations utilizing 

this alterna:ive shall comply with a source specific YOM emission limit on a 12 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
month rolling average basis, calculated at the end of each calendar month. 

gooject coating operations that do not utilize the emissions averaging alternative, 

and coating operations sabject to Section 21 8.201(q)(5)(H), shall comply with the 

requirements-tn-Seetien 218.201 (q)(5) or 218.205, or subsectiE>n-fn) of this 

Section, as applicable, as well as with all other applicable req~:irements in this 

Subpart. 

I) The total actual VOM emissions determined by htuaeion 2 shall be equal 

to or less than tl:e total allowable VOM emissions determined by Eqltatien 

1. The owner or operator of a source subject to this subsection (0) shall 

use Equati-en-1- to determine the total allowable source specific VOM mass 

emission limit for pleasure craft coatings included in the emissions 

average: 

Equation 1: 

G 

VOAI Allowahfe E LIJ.1/ Vi {=oA 

Total allowable-mass of VOM that CaR be emitted 

from the pleasure craft coating operations incbded 

in the average, expressed in kilograms pOl' 12 month 

period. 

btM; = The applicable ',10M content limit for a specified 

pleasure craft coating category from Section 

218.201 (q)(5)(A) throagh (0), expressed in 

kiillgrams per ]jeer. 

.vi = Volume of specified pleasure craft coating category 

from Section 218.201(q)(5)(A) through (0) used in 

the-past 12 months, excluding water aRd any 

corapounds that are exempt, expressed in liters. 

t = Subscript denoting a specific pleasure craft coating 

category from Section 218.201(q)(5)(lr) through (0). 

2) At the end of the first 12 month averaging period, and at the end ofoach 

subsequent month, the owner or operator of a somce subject to this 

subsection (0) shall ~:se Eqt:ation 2 to calculate the total actual VOM 

emissions from the pleasure craft coating operations included in the 

emiSSIOns average. 

Equation 2: 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
3) 

where: 

t 

-- uOH emissions calcaate 1 s . • US111g the uOH ~. content uah lffi • ~ u • lE olE A l thfth5'> II oatings from ScctlOn 218.201Eq J • i f 

a c CG) '. , d the "olume 0- that are inck:ded 111 the avcrage an • 

those coatings used, expresses III kllograms. 

11Te1'gh:ed average ofaclaal \TOM conlent for-a . - .~ . t e J' fFem Se-€--8-eH s ecified pleasure craft coat111g c~eg r. . 

2~ 8.201Eq)(5)EA) through (G), expressed 111 kll&gffiffi5 

per-{i\€r. 

~ &tal--voluFae-ofkjs ",e*c;tifit±,"ed~p""le8£ure craft coating = Total volame 0 p " 204 ( )f5)fAl thro::gh (G) category from SectIOJ:1c218. q", , 

= 

'1sed in the past 12 months, exc1udlllg water illld an) 

~ompounds that are exempt, cxpressed III hters, 

Sabscript donoting a speClfic 'I p easare Cl 'aFt ~ CO'l'i ~ ng EG) 

category from Section 2l8.201(q)C5)(A) Houg , 

For purposes of EquatIOn , ' . 3 t alcdatc the weinhted average . () h-II use EquatIon 0 C , b h 

' 2 'he mvncr or operator o~ f a source subject to 

this subsectIOn 0 sa" 1 s d in the emissions average for t e VOM content for each coat111g 111C u e 

previous 12 months, 

Equation 3: 

where: 

roOl 

= Weighted average ofaetllal VOM content for a specified 

leanrs craft coating category from SectIOn , 

~18,2'04(ql(5l(A) through (G), eKpresscd m kIlograms per 

titer. 

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Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Section 218.208 

¥GMt = ¥GM content of each pleasure craft coating used ovcr the 

previous 12 months within a specdic pleasure craft coating 

category, i. 

¥j ¥alume ofeach pleasure craft coating uscd in the prcvious 

12 months, excluding water and any-wmpounds that are 

excmpt, \vithin a specific pleasure craft coating category, i. 

t Subscript dcnoting a specifiB pleasure craft coating 

wteger), from Section 21 8.204(q)(5)(A) through (G). 

t Subscript denoting a specific pleasure craft coating within 

a spccified coating €ategory, i. 

= Number of coatings applicd within a specific coating 

category, i. 

Exemptions from Emission Limitations 

a) Exemptions for all coating categories except wood furniture coating. The 

limitations of this Subpart shall not apply to coating lines within a source, that 

otherwise would be subject to the same subsection of Section 218.204 (because 

they belong to the same coating category, e.g., can coating), provided that 

combined actual emissions ofVOM from all lines at the source subject to that 

subsection never exceed 6.8 kg/day (15 Ibs/day) before the application of capture 

systems and control devices. (For example, can coating lines within a source 

would not be subject to the limitations of Section 218.204(b) of this Subpart if the 

combined actual emissions ofVOM from the can coating lines never exceed 6.8 

kg/day (IS lbs/day) before the application of capture systems and control 

devices.) Prior to May 1,2012, volatile organic material emissions from heavy 

off-highway vehicle products coating lines must be combined with YOM 

emissions from miscellaneous metal parts and products coating lines to determine 

applicability. On and after May 1,2012, YOM emissions from heavy offhighway vehicle products coating lines shall be combined with YOM emissions 

from miscellm1eous metal parts and products coating lines and plastic parts and 

products coating lines to determine applicability. Any owner or operator of a 

coating source shall comply with the applicable coating analysis test methods and 

procedures specified in Section 218.1 05(a) of this Part and the recordkeeping and 

reporting requirements specified in Section 218.211 (a) of this Subpart if total 

YOM emissions from the subject coating lines are always less than or equal to 6.8 

kg/day (15 Ibs/day) before the application of capture systems and control devices 

and, therefore, are not subject to the limitations of Section 218.204 of this 

Subpart. Once a category of coating lines at a source is subject to the limitations 

in Section 218.204 of this Subpart the coating lines are always subject to the 

limitations in Section 218.204 of this Subpart. 

b) Applicability for wood furniture coating 

IS 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
1) The limitations of this Subpart shall apply to a source's wood furniture 

coating lines if the source contains process emission units, not regulated 

by Subparts B, E, r (excluding Section 218.204(1) ofthis Subpart), H 

(excluding Section 218.405 of this Part), Q, R, S, T (excluding Section 

218.486 of this Part), V, X, Y, or BB of this Part, which as a group both: 

A) I-lave a maximlm1 theoretical emissions of91 Mg (100 tons) or 

more per calendar year ofVOM ifno air pollution control 

equipment were used; and 

B) Are not limited to less than 91 Mg (100 tons) ofVOM per calendar 

year if no air pollution control equipment were used, through 

production or capacity limitations contained in a federally 

enforceable permit or SIP revision. 

2) The limitations of this Subpart shall apply to a source's wood furniture 

coating lines, on and after March 15, 1996, if the source contains process 

emission units, which as a group, have a potential to emit 22.7 Mg (25 

tons) or more ofVOM per calendar year and have not limited emissions to 

less than 22.7 Mg (25 tons) ofVOM per calendar year through production 

or capacity limitations contained in a federally enforceable operating 

permit or SIP revision, and that: 

A) Are not regulated by Subparts B, E, F (excluding Section 

218.204(1) of this Subpart), H, Q, R, S, T (excluding Section 

218.486 of this Part), V, X, Y, Z or BB ofthis Part; and 

B) Are not included in any of the following categories: synthetic 

organic chemical manufacturing industry (SOCMI) distillation, 

SOCMI reactors, plastic parts coating (business machines), plastic 

parts coating (other), offset lithography, industrial wastewater, 

auto body refinishing, SOCMI batch processing, volatile organic 

liquid storage tanks and clean-up solvents operations. 

3) If a source ceases to fulfill the criteria of subsection (b)(I) or (b )(2) of this 

Section, the limitations of Section 218.204(1) of this Subpart shall continue 

to apply to any wood furniture coating line which was ever subject to the 

limitations of Section 218.204(1) of this SubpaJi. 

4) For the purposes of subsection (b) of this Section, an emission unit shall 

be considered to be regulated by a Subpart if it is subject to the limitations 

of that Subpart. An emission Lmit is not considered regulated by a Subpart 

ifit is not subject to the limits of that Subpart, e.g., the emission unit is 

covered by an exemption in the Subpart or the applicability criteria of the 

Subpart are not met. 

16 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
5) Any owner or operator of a wood furniture coating line to which the 

limitations of this Subpart are not applicable due to thc criteria in 

subsection (b) of this Section shall, upon request by the Agency or the 

USEPA, submit records to the Agency and the USEPA within 30 calendar 

days ii'om the date of the request that document that the coating line is 

exempt from the limitations of this Subpart. 

c) On and after March 15, 1996, the limitations ofthis Subpart shall not apply to 

touch-up and repair coatings used by a coating source described by Section 

218.204(b), (d), (t), (g), and-(i), and (q)J.i) of this Subpart; provided that the 

source-wide volume of such coatings used does not exceed 0.95 I (I quart) per 

eight-hour period or exceed 209 liyr (55 gallyr) for any rolling 12 month period. 

Recordkeeping and reporting for touch-up and repair coatings shall be consistent 

with subsection (e) of this Section. 

d) Prior to May I, 2012, the limitations of this Subpart shall not apply to touch-up 

and repair coatings used by a coating source described by Section 218.204(j), (n), 

and (0) of this Subpart, provided that the source-wide volume of the coatings USed 

does not exceed 0.95 I (I quart) per eight-hour period or exceed 209 lIyr (55 

gallyr) for any rolling 12 month period. Recordkeeping and reporting for touchup and repair coatings shall be consistent with subsection (e) ofthis Section. 

e) On and after March IS, 1996, the owner or operator of a coating line or a group of 

coating lines using touch-up and repair coatings that are exempted from the 

limitations of Section 218.204(b), (d), (f), (g), (i), Cj), (n), and-(o), and (q)(5) of 

this Subpart because of the provisions of subsection 21S.20S(c) or (d) of this 

section shall: 

I) Collect and record the name, identification number, and volume used of 

each touch-up and repair coating, as applied on each coating line, per 

eight-hour period and per month; 

2) Perform calculations on a daily basis, and maintain at the source records 

of such calculations, of the combined volume of touch-up and repair 

coatings used source-wide for each eight-hour period; 

3) Perform calculations on a monthly basis, and maintain at the source 

records of such calculations, ofthe combined volume of touch-up and 

repair coatings used source-wide for the month and the rolling 12 month 

period; 

4) Prepare and maintain at the source an annual summary of the information 

required to be compiled pursuant to subsections (e)(I) and (e )(2) of this 

Section on or before January 31 of the following year; 

17 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
5) Maintain at the source for a minimum period of three years all records 

required to be kept under this subsection (e) and make such records 

available to the Agency upon request; 

6) Notify the Agency in writing if the use of touch-up and repair coatings at 

the source ever exceeds a volume of 0.95 I (1 quart) per eight-hour period 

or exceeds 209 lIyr (55 gal/yr) for any rolling 12 month period within 30 

days after any such exceedance. Such notification shall include a copy of 

any records of such exceedance; and 

7) "Touch-up and repair coatings" means, for purposes of 35 Ill. Adm. Code 

218.208, any coating used to cover minor scratches and nicks that occur 

during manufacturing and assembly processes. 

Section 218.211 Recordkeeping and Reporting 

c) Any owner or operator of a coating line subject to the limitations of Section 

218.204 of this Subpart other than Section 218.204(a)(1)(B), (a)(I)(C), (a)(2)(B), 

(a)(2)(C), or (a)(2)(D) of this Subpart and complying by means of Section 

218.204 of this Subpart shall comply with the following: 

3) On and after a date consistent with Section 218.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 218.204 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance from Section 218.204 of this Subpart to Section 

218.205 or Section 218.207 ofthis Subpart, the owner or operator 

shall comply with all requirements of subsection (d)(1 )J21:, (e)(I), 

or (i)(l) of this Section, as applicable. Upon changing the method 

of compliance from Section 218.204 of this Subpart to Section 

218.205 of this Subpart or Section 218.207 of this Subpart, the 

owner or operator shall comply with all requirements of subsection 

(d) or, (e ),-Bf'-{i-) ofthis Section, as applicable. 

d) Any owner or operator of a coating line subject to the limitations of Section 

218.204 of this Subpart and complying by means of Section 218.205 of this 

Subpart shall comply with the following: 

18 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
3) On and after a date consistent with Section 2] 8.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 218.205 of this Subpart 

shall be repOlied by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 218.205 of this Subpart 

to Section 218.204 or Section 218.207 of this Subpart, the owner 

or operator shall comply with all requirements of subsection (c)(1) 

or, (e)(1 ), or (i)(l) of this Section, as applicable. Upon changing 

the method of compliance with this Subpart from Section 218.205 

to Section 218.204 or Section 218.207 of this Subpart, the owner 

or operator shall comply with all requirements of subsection (c) or, 

(e ),-&r-W of this Section, as applicable. 

j) Each owner or operator of a pleasure craft surface coating operation sabject to the 

limitations in Section 21 8.204(q)(5)(A) through (0) of this Subpart and 

complying by means of Section 218.207(0) of this Subpart shall comply with the 

fell&wing7 

1) By a date consistent with Section 21 8.106 of this Part, or upon initial start 

up-ofa new pleasure craft surface coating operation, whichever is later, or 

upon changing the method of compliance for an existing subject coating 

operation from Section 218.204, 218.205, or 218.207(n) of this Subpart to 

Section 218.207(0) of this Subpart, the owner or operator ofa subject 

ooati-ng operation shall perform all tests lmd calculations necessary to 

demonstrate that the subj cct coating line will be in compliance with 

Section 218.207(0) on and after a date consistent with Section 218.106 of 

this Part, or on and after the initial start up date. 

2) On and after a date consistent with Section 218.106 of this Part, or on and 

after the initial start up date, whichever is later, the owner or operator of a 

subject pleasure craft coating operation shall: 

A) Collect and record the following information each month: 

i) The amount of each pleasure craft surface coating used in 

each subject coating operation; 

19 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Part 219: 

ii) The 'lOM content and coating category of each pleasure 

craft surface coating used in each subjecH,oating operation; 

iii) Total-mon:hly YOM emissions for all subject pleas~:re craft 

s::rface coating operations; 

B) At :he end sf the first 12 month averaging period, and at the end of 

each subsequent month, colleet and record the fol1BWing 

information: 

i) The VOM mass emission limit for all sabject pleasure craft 

surface coating operations for the applicable 12 month 

averaging period, with supporting calculations; 

ii) Tho-total actual emissmns ofVOM from all sl:bject 

j3kasure craft surface coating operations for-.the applicable 

12 month averaging period; 

C) Notify the Agency in writing of any violation of the requirements 

of Section 21 8.207(0) within 30 days following the-eccurrence of 

the violation and provide records documenting-the violation upon 

reqaest by the Agency; 

D) Notify the Agency in writing at least 30 calendar days before 

changing the method of compliance with this Subpart from Section 

218.207(0) to Section 218.201,218.205, or 21 8.207(n). Upon 

changing the method of compliance, the owner or operator shall 

comply wi,h all rcq::irements set forth in subsection (c), Ed), or (e) 

of this Section, as applicable; 

E) Maintain at the source all records reql:ired by this subsection G) for 

a minimum of three years from the date the document was created, 

and provi de such records to the Agency apon request. 

Section 219.204 Emission Limitations 

q) Miscellaneous Metal Parts and Products Coatings and Plastic Parts and Products 

Coatings On and After May I, 2012. 

5) Pleasure Craft Surface Coatings 

20 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
kg/I kg/I 

(ib/gal) (ib/gal) 

coatings solids 

A) Extreme high gloss coating - topcoat 0.601+49 1.88hW 

l2Jl.lM (l5.6)~ 

B) High gloss coating - topcoat 0.42 0.80 

(3.5) (6.7) 

C) Pretreatment wash primer 0.78 6.67 

(6.5) (55.6) 

D) Finish primer/surfacer ().4;6 G-,W 

I+..§..) f:€Hj 

Prior to January I. 2014: 0.60 1.88 

l2Jl.l .L!222 

On and after January 1. 2014: 0.42 0.80 

Qdl. &1.l. 

E) High build primer/surfacer 0.34 0.55 

(2.8) (4.6) 

F) Aluminum substrate antifoulant 0.56 1.53 

coating (4.7) (12.8) 

G) Other substrate antifoulant coating 0.40G-cH 0.73(h£ 

(3.3)~ ~f44) 

ill Antifouling Sealer/Tie Coat 0.42 0.80 

Qdl. &1.l. 

1M) All other pleasure craft surface 0.42 0.80 

coatings for metal or plastic (3.5) (6.7) 

Section 219.207 Alternative Emission Limitations 

a) Any owner or operator of a coating line subject to Section 219.204 of this 

Subpart, except coating lines subject to Section 219 .204( q)( 6), may comply with 

this Section, rather than with Section 219.204 of this Subpart, if a capture system 

and control device are operated at all times the coating line is in operation and the 

owner or operator demonstrates compliance with subsection (c), (d), (e), (t), (g), 

(h), (i), (j), (Ic), (I), or (m) of this Section (depending upon the source category) 

through the applicable coating analysis and capture system and control device 

efficiency test methods and procedures specified in Section 219.105 of this Part 

21 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
and the recordkeeping and reporting requirements specified in Section 219.211 ( e) 

of this Subpart; and the control device is equipped with the applicable monitoring 

equipment specified in Section 219.1 OS( d) of this Part and the monitoring 

equipment is installed, calibrated, operated and maintained according to vendor 

specifications at all times the control device is in use. A capture system and 

control device, which does not demonstrate compliance with subsection (c), (d), 

(e), (f), (g), (h), (i), (j), (k), (I), or (m) of this Section may be used as an alternative 

to compliance with Section 219.204 of this Subpart only if the alternative is 

approved by the Agency and approved by the USEP A as a SIP revision. +Be 

owner or operator ofa pleasure craft surface coating opcration subjec, to Sectiou 

219.204(q)(5)V,) through (0) of this Subpart may also comply with sabsection 

(n) of,his Section, rather than '""ith Section 219.204 of,his Subpart. 

n) Emissions ,\veraging Alternative far Pleasure Craft Surface Coating Operations. 

+he-ewner or operator of a source with coating operations subject to the 

requirements of Section 219.204(q)(5)(A) through (0) may elect to inelude such 

operations in the emissions averaging alternative. Coating operations utilizing 

this alternative shall comply ,<,{ith a source specific YOM emission limit on a 12 

meffih-rolling average basis, calculated at the end of each calendar month. 

Subject coating operations that do not utilize the emissions averaging alternative 

and coating operations subject to Sec,ion 219.204(q)(5)(H), shall comply witMhe 

rettUiFCflwnts in Section 219.204(q)(5) or 219.205, or sabsection (m) of this 

Section, as applicable, as well as with all other applicable requirements in fhis 

Subpart. 

1) The total ac,~;al 'lOM emissions determined by Equation 2 shall be equal 

to or less than the total allowable VOM emissions determined hy-Equation 

1. The owner or operator of a source sabj ect to this subsection (n) shall 

use Equation I to dctem1ine the total allowable source specific YOM mass 

emission limit far pleasure craft coatings included in this emissions 

average: 

Equation 1: 

G 

VO}J Alllnmhie E LJi~1 i r~ h=-A 

¥OMMlewab", = Total allowable mass ofVOM that can be emitted 

from the pleasure craft coating operations included 

in the average, expressed in kilograms per 12 month 

period. 

22 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
hlMi = The applicable VOM content limit for a spc€"ifioo 

pleasure craft coating category from Section 

219201(q)(5)(/\) through (G), expressed in 

kilograms pcr-±~ 

Vi = Volume of speciflcd pleasure craft coating category 

from Section 2l9"201(q)(5)(A) through"(Gj-w.;e&tn 

the past l-b months, cxcl uding viater and any 

compounds that are Olccmpt, expressed in liters" 

t = Subscript denBttng a specific pleasure craft-€"'*lting 

category from Section 219201(q)(5)(S)·through 

(Gfo 

2) At the end of the first 12 month averaging period, and at the end of each 

subsequent month, the owner or operator of a source subject to this 

subsection (n) shall ase Equation 2 to calculate the total actual VOM 

emissions from the pleasure craft coating operations included in the 

emISSIOns average" 

Equation 2: 

where: 

G 

FDA/Actual EVOAliV;· I",A 

¥GMA~l',"1 = VOM emissions calculated using the V()M.{;--efttent 

for all coatings from Section 2l9.204(q)(5)(A) 

through (G) tha, are included in the average and the 

velume of those coatings used, expressed in 

kilograms. 

¥GMt = Weigh,ed average of actual VOM content for a 

specified pleasure craft coating category from 

Section 219204(q)(5)(A) through (G), expressed in 

kilograms per liter. 

¥i = Total volume of specified pleasure crafE-coating 

category from Section 219.204(q)(5)(A) through 

(G) used in ,he past 12 months, elwluding water-aad 

any compounds that arc clwmpt, m[pressed in liters. 

t = Subscript dcnoting a specific pleasure craft coating 

category from Sectiou 21 9.204 (q)(5)(A) through 

E@} 

23 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
3) For purposes of Equation 2, the owner or operator ofa source suB:fcct-to 

this subsection En) shall use Equation 3 to calculaee-the-weighted average 

¥-GM content fo·reacl1 coating included in ,he emis&ions average for the 

previous 12 months. 

Section 219.208 

Eqtiation 3: 

" 

IVOMjV; 

VOM, 

",<,here: 

¥GMj Weighted average of actual VOM content for a 

specified pleasure craft coating category from 

Section 219.201(q)(5)(A) through (0), elcpressed in 

kilograms per liter. 

= VOM content of each plcasure craft coating ased 

over the previous 12 months within a specific 

pleasure craft coating category, h 

:Vi :Volumc of each pleasure craft coueing used in the 

previa as 12 months, eJwluding- water and any 

compounds that are Glcempt, within a specific 

pleasure craft coating category, i. 

1 Suhscript denoting a specific pleasure craft coating 

category from Soctien 219.201(q)(5)(A) ehtough 

(Gfr 

j 

n 

= Subscript denoting a specific pleasure craft coating 

within a specified coating category, i. 

}Jambor of coatings applied within a specific 

coating category;+-

Exemptions From Emission Limitations 

a) Exemptions for all coating categories except wood furniture coating. The 

limitations of this Subpart shall not apply to coating lines within a source, that 

otherwise would be subject to the same subsection of Section 219.204 (because 

they belong to the same coating category, e.g., can coating), provided that 

24 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
combined actual emissions ofVOM from all lines at the source subject to that 

subsection never exceed 6.8 kg/day (15 Ibs/day) before the application of capture 

systems and control devices. (For example, can coating lines within a source 

would not be subject to the limitations of Section 219.204(b) of this Subpart if the 

combined actual emissions ofVOM from the can coating lines never exceed 6.8 

kg/day (15 Ibs/day) before the application of capture systems and control 

devices.) Prior to May 2012, volatile organic material emissions from heavy offhighway vehicle products coating lines must be combined with YOM emissions 

from miscellaneous metal parts and products coating lines to determine 

applicability. On and after May 1,2012, YOM emissions from heavy offhighway vehicle products coating lines shall be combined with YOM emissions 

from miscellaneous metal parts and products coating lines and plastic parts and 

products coating lines to determine applicability. Any owner or operator of a 

coating source shall comply with the applicable coating analysis test methods and 

procedures specified in Section 219.105(a) of this Part and the recordkeeping and 

reporting requirements specified in Section 219.211 (a) of this Subpart if total 

YOM emissions from the subject coating lines are always less than or equal to 6.8 

kg/day (15 Ibs/day) before the application of capture systems and control devices 

and, therefore, are not subject to the limitations of Section 219.204 of this 

Subpart. Once a category of coating lines at a source is subject to the limitations 

in Section 219.204 ofthis Part the coating lines are always subject to the 

limitations in Section 219.204 of this Subpart. 

b) Applicability for wood furniture coating 

1) The limitations of this Subpart shall apply to a source's wood furniture 

coating lines if the source contains process emission units, not regulated 

by Subparts B, E, F (excluding Section 219.204(1) of this Subpart), H 

(excluding Section 219.405 ofthis Part), Q, R, S, T (excluding Section 

219.486 of this Part), V, X, Y, Z or BB of this Part, which as a group both: 

A) Have a maximum theoretical emissions of91 Mg (100 tons) or 

more per calendar year ofVOM if no air pollution control 

equipment were used, and 

B) Are not limited to less than 91 Mg (100 tons) ofVOM per calendar 

year if no air pollution control equipment were used, through 

production or capacity limitations contained in a federally 

enforceable permit or SIP revision. 

2) The limitations of this Subpart shall apply to a source's wood furniture 

coating lines, on and after March 15, 1996, if the source contains process 

emission units, which as a group, have a potential to emit 22.7 Mg (25 

tons) or more ofVOM per calendar year and have not limited emissions to 

less than 22.7 Mg (25 tons) ofVOM per calendar year through production 

or capacity limitations contained in a federally enforceable operating 

25 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
permit or SIP revision, and that: 

A) Are not regulated by Subparts B, E, F (excluding Section 

219.204(1) of this Subpart), H, Q, R, S, T (excluding Section 

219.486 of this Part), V, X, Y, Z or BB ofthis Part; and 

B) Are not included in any of the following categories: synthetic 

organic chemical manufacturing industry (SOCMI) distillation, 

SOCMI reactors, plastic parts coating (business machines), plastic 

parts coating (other), offset lithography, industrial wastewater, 

auto body refinishing, SOCMI batch processing, volatile organic 

liquid storage tanks and clean-up solvents operations. 

3) If a source ceases to fnlfill the criteria of subsection (b)(1) or (b )(2) of this 

Section, the limitations of Section 219.204(1) of this Subpart shall continue 

to apply to any wood furniture coating line which was ever subject to the 

limitations of Section 219.204(1) of this Subpart. 

4) For the purposes of snbsection (b) of this Section, an emission unit shall 

be considered to be regulated by a Subpart if it is subject to the limitations 

of that Subpart. An emission unit is not considered regulated by a Subpart 

if it is not subject to the limits of that Subpart, e.g., the emission unit is 

covered by an exemption in the Subpart or the applicability criteria of the 

Subpart are not met. 

5) Any owner or operator of a wood furniture coating line to which the 

limitations of this Subpart are not applicable due to the criteria in 

subsection (b) of this Section shall, upon request by the Agency or the 

USEP A, submit records to the Agency and the USEP A within 30 calendar 

days from the date of the request that document that the coating line is 

exempt from the limitations of this Subpart. 

c) On and after March 15, 1996, the limitations of this Subpart shall not apply to 

touch-up and repair coatings used by a coating source described by Section 

219.204(b), (d), (f), (g), aOO-(i), and (q)(5) of this Subpart; provided that the 

source-wide volume of such coatings used does not exceed 0.95 1 (l quart) per 

eight-hour period or exceed 209 lIyr (55 gallyr) for any rolling 12 month period. 

Recordkeeping and repOliing for touch-up and repair coatings shall be consistent 

with subsection (d) of this Section. 

d) Prior to May 1,2012, the limitations of this Subpart shall not apply to touch-up 

and repair coatings used by a coating source described by Section 219.204(j), (m), 

and (n) of this Subpart, provided that the source-wide volume of the coatings used 

does not exceed 0.95 I (l quart) per eight-hour period or exceed 209 l/yr (55 

gal/yr) for any rolling twelve month period. Recordkeeping and reporting for 

touch-up and repair coatings shall be consistent with subsection (e) of this 

26 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Section. 

e) On and after March 15, 1996, the owner or operator of a coating line or a group of 

coating lines using touch-up and repair coatings that are exempted from the 

limitations of Section 219.204(b), (d), (f), (g), (i), (j), (m), aHEl-(n), and (9)(5) of 

this Subpart because of the provisions of subsection (c) or (d) of this Section 

shall: 

I) 

2) 

3) 

4) 

5) 

6) 

7) 

Section 219.211 

Collect and record the name, identification number, and volume used of 

each touch-up and repair coating, as applied on each coating line, per 

eight-hour period and per month; 

Perform calculations on a daily basis, and maintain at the source records 

of such calculations of the combined volume of touch-up and repair 

coatings used source-wide for each eight-hour period; 

Perform calculations on a monthly basis, and maintain at the source 

records of such calculations of the combined volume of touch-up and 

repair coatings used source-wide for the month and the rolling 12 month 

period; 

Prepare and maintain at the source an annual summary of the information 

required to be compiled pursuant to subsections (e)(l) and (e)(2) of this 

Section on or before January 31 of the following year; 

Maintain at the source for a minimum period of three years all records 

required to be kept under this subsection (e) and make such records 

available to the Agency upon request; 

Notify the Agency in writing if the use of touch-up and repair coatings at 

the source ever exceeds a volume 01'0.951 (1 quart) per eight-hour period 

or exceeds 209 lIyr (55 gallyr) for any rolling 12 month period within 30 

days after any such exceedance. Such notification shall include a copy of 

any records of such exceedance; and 

"Touch-up and repair coatings" means, for purposes of 35111. Adm. Code 

219.208, any coating used to cover minor scratches and nicks that occur 

during manufacturing and assembly processes. 

Recordkeeping and Reporting 

c) Any owner or operator of a coating line subject to the limitations of Section 

219.204 of this Subpart other than Section 219.204(a)(l )(B), (a)(1 )(C), (a)(2)(B), 

27 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
(a)(2)(C), or (a)(2)(D) of this Subpart and complying by means of Scction 

219.204 of this Subpart shall comply with the following: 

3) On and after a date consistent with Section 219.106 of this Part. the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 219.204 of this Subpart 

shall be reported by sending a copy of such record to the Agcncy 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance from Section 219.204 to Section 219.205 or Section 

219.207 of this Subpart, the owner or operator shall comply with 

all requirements of subsection (d)(1) or, (e)(1), or (i)(l ), as 

applicable. Upon changing the method of compliance from Section 

219.204 to Section 219.205 or Section 219.207 of this Subpart, the 

owner or operator shall comply with all requirements of subsection 

(d)...QI, (e),.-er-(ij of this Section, as applicable. 

d) Any owner or operator of a coating line subject to the limitations of Section 

219.204 of this Subpart and complying by means of Section 219.205 of this 

Subpart shall comply with the following: 

3) On and after a date consistent with Section 219.106 of this Part, the owner 

or operator of a subject coating line shall notify the Agency in the 

following instances: 

A) Any record showing violation of Section 219.205 of this Subpart 

shall be reported by sending a copy of such record to the Agency 

within 30 days following the occurrence of the violation. 

B) At least 30 calendar days before changing the method of 

compliance with this Subpart from Section 219.205 to Section 

219.204 or Section 219.207 of this Subpart, the owner or operator 

shall comply with all requirements of subsection (c)(1) or, (e)(1), 

or (i)(l) of this Section, as applicable. Upon chauging the method 

of compliance with this Subpart from Section 219.205 to Section 

219.204 or Section 219.207 ofthis Subpart, the owner or operator 

shall comply with all requirements of subsection (c) or, (e),.-er-(ij 

of this Section, as applicable. 

28 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
j) Each r O'''fler 0 . ' '. ,:v ,r operator of a pleasure craft surfa .' , Imlta.lOns 111 Section 2l-90204(q)(S)(A) h ' co coatll1g operatIOn sabjectto the ~~==1 ',~ hu . n t fOdgh EGj-ef.thF "nh, 

v='Y'7'I1"l'i"'Tmoans following: of Sec cion 219 ,n 207( ) of thIS ,~'laJ't.aoo Subpart sball comply with the 

1) 

2) 

By a date consistent wich Section 219 106 fth' 

up of a ne',\' pleasure cnf! surfac ' , 0 IS Part, or upon initial start , c e coatlBg opera"o "'I' h ' 

upon changll1g the method of r ' "n, ~dlC ever IS later, or 

operation from Section 219.2;4o,~~~a;;; tor ~n eJUstll1g subject coating 

ScctlOn 219 ,207(n) of this S b ~' or ~ 19,207(lc) of thIs SUbpartto , u part t ,e o"'ner 0 ' watll1g operation shall perl) ll,>cr operator of a subject orm a tests and c I ' I I' ' deffie.n;ffi;xte-that th b'a cu tHOns neccssa=-'~ e su ject coating l' ,,,'II b ' " 'J = 

&eti&n-2-1*.207(n) on and af!e:a ;at

lBe 

"I:, ~e I~, ~omplianc&-with thIs Part, or on and after tho ' 'I' I e consIstent ,,'Ith SectIOn 219,106 of 

e 1m IU start up date, 

o .n an E! a4,:,r f a date consistent with Section 2 .' after the IBltml s,art up dat "eft' h" ,19,106 of thIS Part, or on and 

b' e," IC e" ens latcr the '" sU4cct pleasure craft coating op f !-' OHner or operator of a " eHuon s ,all: 

l\) Collect and record the following information each month: 

i) ::c~ as:~un: ~f each pleasure craft surface coating used in 

cc coatmg operatIOn: 

ii) The VOM content and coating t " 

craft surface coating used in :a::

e

,";:? of oa~h pleasure su joct coacmg operation; 

iii) Total monthly V OM emissions for a II ' b' I 

surface coatin" operat" sU4

cct 

p easure craft b IOns; 

B) At the eBEl-of the first 12 month a"era in ' each subsequent month II 'd g g penoE!, and at the en4-Bf 

information: ' co ect an record the following 

i) 

ii) 

+he VOM mass emission limit for II s' 

surface coating operations for the : tU1~ct pleasure craft 

averagin 'd' . PP lea e 12 month 

g peno , wI,h suppmiing calculations' , 

The total actual emissions of uOH fr II b: pleasure c ft Ii • ~ om a. su joct 

12 monH:r~: sur~ace coating operations for the applicable 

th eragmg penod; 

C) Notify tho Agency in \,'Fiting- of an : ,,: I ' ofSeetion 219 207( ) ,n' h'''' ) ,10 atlOn of the requiremoncs 

, n NIt m ,,0 days following the occurrence of 

29 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
the violation aJ~d provide records documenting the violation ~:pon 

request by the ""genc),; 

G-) Notify the Agency in writing at least 30 calendar days befure 

changing the method of compliance with :his Sl:bpart from Section 

2+97207(n) to Section 219.201, )19.205, or 219.207(m). Upon 

changing the method of eomplian€c, the owner or operator shall 

comply with all requirements set forth in subsection (c), (d), or (e) 

ofthis Seetion, as applicable. 

E) Maintain at tlle source all records req~:ired by :his subseetion Gl for 

a minimum of-three years from the date the document was created, 

aJ1d provide such records to the Agency upon reqaest. 

Corrected Equation for Fiberglass Boat Manufacturing Materials 

The Illinois EPA recently noticed that a plus sign ("+") is missing between the third and 

fourth terms of Equation 3 in Section 218.891(c). The Illinois EPA therefore recommends the 

following amendment: 

Section218.891 Emission Limitations and Control Requirements 

c) Emissions Averaging Alternative. The owner or operator of a source subject to 

the requirements of this Subpart may elect to include some or all of the subject 

resin and gel coat operations at the source in the emissions averaging alternative. 

Resin and gel coat operations utilizing the emissions averaging alternative shall 

comply with a source-specific monomer YOM mass emission limit on a 12-month 

rolling average basis, calculated at the end of each calendar month. All subject 

resin and gel coat operations that do not utilize the emissions averaging 

alternative shall comply with the requirements in subsection (b) or (d) of this 

Section, as well as with all other applicable requirements in this Section. 

2) At the end of the first 12-month averaging period, and at the end of each 

subsequent month, the owner or operator of a source subject to this 

subsection (c) shall use Equation 3 to calculate the monomer YOM 

emissions from the resin and gel coat operations included in the emissions 

average. The monomer YOM emissions calculated using Equation 3 shall 

not exceed the monomer YOM limit calculated using Equation 2. 

Equation 3: 

30 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Monomer (PV/i )(M II) I (PIL?" )(;.1 pc;) I (PVCG )(Ucc;) 

¥GM = 

Emissions 

Monomer 

YOM 

Emissions 

(PVI/ XMR )+ (PVp(; )(MI'G) + (PVu; )(McG) + 

(PVm XMm)+ (PI',,, )(M'G) 

where: 

Monomer = 

YOM 

Emissions 

PVPG 

PVCG 

MeG 

PVTR 

Mm 

PVTG 

Monomer YOM emissions calculated using the 

monomer YOM emission equations for each operation 

included in the average, expressed in kilograms; 

Weighted-average monomer YOM emission rate for 

production resin used in the past 12 months, expressed 

in kg/Mg, calculated in accordance with Equation 4 in 

subsection (c)(3); 

Mass of production resin used in the past 12 months, 

expressed in Mg; 

Weighted-average monomer YOM emission rate for 

pigmented gel coat used in the past 12 months, 

expressed in kg/Mg, calculated pursuant to Equation 4; 

Mass of pigmented gel coat used in the past 12 months, 

expressed in Mg; 

Weighted-average monomer YOM emission rate for 

clear gel coat used in the past 12 months, expressed in 

kg/Mg, calculated pursuant to Equation 4; 

Mass of clear gel coat used in the past 12 months, 

expressed in Mg; 

Weighted-average monomer YOM emission rate for 

tooling resin used in the past 12 months, expressed in 

kg/Mg, calculated pursuant to Equation 4; 

Mass of tooling resin used in the past 12 months, 

expressed in Mg; 

Weighted-average monomer YOM emission rate for 

tooling gel coat used in the past 12 months, expressed in 

31 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
kg/Mg, calculated pursuant to Equation 4; 

MTG Mass of tooling gel coat used in the past 12 months, 

expressed in Mg. 

DATED: May 16,2011 

1021 N. Grand Ave. East 

P.O. Box 19276 

Springfield, IL 62794-9276 

(217) 782-5544 

Respectfully snbmitted, 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

By: C20v-4r1t:t;&4ir~ Dana Vetterhoffer )II { 

Assistant Counsel 

Division of Legal Counsel 

32 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 

IN THE MATTER OF: ) 

) 

REASONABL Y AVAILABLE CONTROL ) 

TECHNOLOGY (RACT) FOR VOLATILE ) 

ORGANIC MATERIAL EMISSIONS FROM ) 

GROUP II AND GROUP IV CONSUMER & ) 

COMMERCIAL PRODUCTS: PROPOSED ) 

AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 

218,and219 ) 

RII-23 

(Rulemaking-Air) 

CERTIFICATE OF SERVICE 

I, the undersigned, an attorney, state that I have served electronically the attached POSTHEARING COMMENTS OF THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

upon the following person: 

John Therriault, Assistant Clerk 

Illinois Pollution Control Board 

James R. Thompson Center 

100 West Randolph, Suite 11-500 

Chicago, Illinois 60601-3218 

and electronically to the following persons: 

SEE ATTACHED SERVICE LIST. 

DATED: May 16, 2011 

1021 N. Grand Ave. East 

P.O. Box 19276 

Springfield, IL 62794-9276 

(217) 782-5544 

ILLINOIS ENVIRONMENTAL 

PROTECTION AGENCY 

BY:~~~ Dana Vetterhoffer , 

Assistant Counsel 

Division of Legal Counsel 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Timothy J. Fox 

Hearing Officer 

Illinois Pollution Control Board 

100 W. Randolph St., Suite 11-500 

Chicago, IL 6060 I 

j()xt@ipcb.state.ii.us 

Virginia Yang 

Deputy Legal Counsel 

Service List Rll-23 

Illinois Department of Natural Resources 

One Natural Resources Way 

Springfield, IL 62702-1271 

virginia. yang@illinois.gov 

Matthew Dunn, Chief 

Division of Environmental Enforcement 

Office of the Attorney General 

100 West Randolph St., Suite 1200 

Chicago, IL 60601 

mdunn({uatg.state.il. us 

Alec M. Davis 

General Counsel 

Illinois Environmental Regulatory Group 

215 E. Adams St. 

Springfield, IL 62701 

adavis@ierg.org 

James Sell 

American Coatings Association 

1500 Rhode Island Avenue, NW 

Washington, DC 20005 

isell@paint.org 

Katherine D. Hodge 

Monica T. Rios 

Hodge Dwyer & Driver 

3150 Roland Ave. 

P.O. Box 5776 

Springfield, IL 62705-5776 

khodge@hddattorneys.com 

mrios@hddattornevs.com 

Electronic Filing - Received, Clerk's Office, May 16, 2011 

 * * * * * PC # 2 * * * * *
Clerk’s Office

Illinois Pollution Control Board ‘:2James R. Thompson Center, Suite 1 1-500 C

Chicago, IL 60601Ref: Docket Ri 1-23, VOM Standards for the Metro East Area

Pollution Control Board Members:

The Boeing Company recently opened a small manufacturing facility near

Mascoutah, illinois, which is located in the metro east ozone nonattainment area.

This is our first Boeing manufacturing operation in Illinois. We look forward tobringing additional aerospace work to Illinois, both directly and through

promoting a local supplier network, but see some limitations because Illinois

VOM rules did not anticipate aerospace manufacturing in metro east.

Ordinarily, in an ozone nonattainment area, we would be regulated by anAerospace VOM RACT rule, usually based on the US EPA Control Techniques

Guideline (CTG) for Aerospace Manufacturing and Rework. However, Illinois

does not have an Aerospace VOM RACT rule. On October 11, 1996, Illinois

EPA submitted a negative declaration to US EPA, saying that an Aerospace

RACT rule was not needed at that time, because metro east did not have any

aerospace facilities with potential to emit greater than the Aerospace CTG

applicability threshold. Consistent with our hope to increase aerospace

manufacturing in Illinois, we intend to petition Illinois to consider adopting anaerospace RACT rule and/or amendments to existing rules to clarif’ applicabilityof metro east VOM rules to aerospace. We will do so tinder separate cover, with

more detail. However, a potentially applicable solvent cleaning VOM rule is

proposed for revision and open for comment now, so we are submitting comment

on that proposal to ensure timely consideration.On April 1,2011, the Illinois Register published proposed revisions to 35111.

Adm. Code 2 19.187, entitled “Other Industrial Solvent Cleaning Operations.”

Section 219.187(a)(2)(B) exempts certain cleaning operations that are covered by

other industry-specific RACT rules. The existing exemption for cleaningassociated with “i) aerospace coating” is proposed for deletion. Boeing requests

that this deletion be deferred until such time that aerospace solvent cleaning

operations can be subject to a regulation that is RACT for aerospace

manufacturing.
• Use aqueous cleaning solvent

• Use a low vapor pressure (7 mm Hg or less) hydrocarbon-based

solvent. There is no lb/gal VOM content requirement.

• Use a solvent with vapor pressure of 45 mm Hg, but follow

housekeeping measures, such as placing solvent wipes in bags or

other closed containers upon completing their use. There is no lb/gal

VOM content requirement.

There are limited aerospace applications where aqueous or 7 mm Hg vaporpressure solvents are effective, but most aerospace solvent cleaning in the U.S. is

performed with solvent blends that meet the 45 mm Hg vapor pressure limitdescribed in the Aerospace CTG and the Aerospace NESHAP. Also, someAerospace RACT rules exempt cleaning with cotton-tipped swabs for small

areas, a common practice at our metro east facility.

Please retain the aerospace exemption in Sec. 219.187(a)(2)(B) during thisrulemaking cycle. We will follow up with a separate rulemaking petition

regarding an Aerospace RACT rule for metro east and a request for interim

determination of RACT rule applicability, understanding that rulemaking does

take some time to complete. Feel free to contact me at (314) 777-9227 or

david.1.shanksboeing.com, if further information would be helpful.

Sincerely,

David Shanks

Boeing Environmental Policy Analysis

Boeing St. Louis

cc: Mark Schlueter, illinois EPA, 2009 Mall St., Collinsville, IL 62234

The Aerospace CTG is available at http://www.epa.gov/airtoxics/aerosp/ctg.pdf
Page 1

ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

REASONABLY AVAILABLE CONTROL ) Rll-23

TECHNOLOGIES (RACT) FOR VOLATILE ) (Rulemaking

ORGANIC MATERIAL EMISSIONS FROM ) Air

GROUP II AND GROUP IV CONSUMER ) IgO AND COMMERCIAL PRODUCTS:

PROPOSED AMENDMENTS TO 35 ILL.

ADM. CODE 211, 218 AND 219

REPORT OF THE PROCEEDINOS held in the

above entitled cause before Hearing Officer Tim

Fox, called by the Illinois Pollution Control

Board, taken by Steven Brickey, CSR, for the State

of Illinois, 100 West Randolph Street, Chicago,

Illinois, on the 18th day of May, 2011, commencing

at the hour of 9:15 a.m.

L.A. COURT REPORTERS, LLC. (312) 419-9292
Page 2

AP PEARANCE S

MR. TIM FOX, Hearing Officer

MR. ANAND RAO,

MS. ANDREA MOORE

ILLINOI S ENVIRONMENTAL PROTECTION AGENCY

1021 North Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

BY: MS. DANA VETTERHOFFER

MR. YOGINDER MAHAJAN

ALSO PRESENT: MR. SCOTT TOWNSEND

MS. LISA FREDE

REPORTED BY:

Steven J. Brickey, CSR

CSR License No. 084-004675

L.A. COURT REPORTERS, LLC. (312) 419-9292
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: )

) RIl-23

REASONABLY AVAILABLE CONTROL ) (Rulemaking-Air)

TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP II AND GROUP IV CONSUMER & ) COMMERCIAL PRODUCTS: PROPOSED ) AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 2l8,and2l9 )

NOTICE

To: John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601-3218

SEE ATTACHED SERVICE LIST

PLEASE TAKE NOTICE that I have today filed with the Office ofthe Pollution Control

Board the REQUEST TO CANCEL HEARING and MOTION TO CORRECT TRANSCRIPT

ofthe Illinois Environmental Protection Agency, a copy of which is herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:

Dana Vetterhoffer //

Assistant Counsel

Division of Legal Counsel

DATED: May 19, 2011

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

fNTHE MATTER OF: )

) Rl1-23

REASONABLY AVAILABLE CONTROL ) (Rulemaking-Air)

TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERIAL EMISSIONS FROM ) GROUP II AND GROUP IV CONSUMER & ) COMMERCIAL PRODUCTS: PROPOSED ) AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 218,and2l9 )

REQUEST TO CANCEL HEARING

The Illinois EPA, by its attorney, requests that the Illinois Pollution Control Board cancel

the hearing currently scheduled to take place on June 1, 2011, in this matter. The Illinois EPA

does not wish to introduce additional materials at such hearing, and believes that outstanding

issues can be resolved through post-hearing comments.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:(2

Dana Vetterhoffer1

Assistant Counsel

Division of Legal Counsel

DATED: May 19,2011

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544

1
BEFORE TUE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF: )

) R1l-23

REASONABLY AVAILABLE CONTROL ) (Rulemaking-Air)

TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERiAL EMISSIONS FROM ) GROUP II AND GROUP IV CONSUMER & ) COMMERCIAL PRODUCTS: PROPOSED ) AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 218,and2l9 )

MOTION TO CORRECT TRANSCRIPT

The Illinois EPA, by its attorney, and pursuant to 35 Ill, Adm. Code § 101.500, moves the

Board to correct errors in the transcript from the May 18, 2011, hearing in this matter as follows:

1. Page 19, Line 22: The transcript should read, “Mr. Townsend, you have haven-t

had a chance to review the Agency’s post hearing comments, but the ACA Ageney-doesn’t have

a formal position on them?”

2. Page 21, Lines 16-18: The transcript should read, “talk with them about the

submittal or for the Agency or for the ACA to act on that with the filing ethe Board.”

3. Page 22, Lines 23-24: Where the transcript indicates that Mr. Townsend said

“Yes,” Tim Fox asked if Yoginder Mahajan ofthe Illinois EPA should be sworn in to answer a

question posed by Anand Rao. Also, the following statement, on line 24, was not spoken by Mr.

Rao, but rather Dana Vetterhoffer ofthe Illinois EPA.

4. Page 23, Line 2: “group two” should read “Group II”.

1
Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

tz24y

Dana Vetterhofff

Assistant Counsel

Division of Legal Counsel

DATED: May 19, 2011

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(2 17) 782-5544

2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

IN THE MATTER OF:

) R11-23

REASONABLY AVAILABLE CONTROL ) (Rulemaking-Air)

TECHNOLOGY (RACT) FOR VOLATILE ) ORGANIC MATERLAL EMISSIONS FROM ) GROUP TI AND GROUP IV CONSUMER & ) COMMERCIAL PRODUCTS: PROPOSED ) AMENDMENTS TO 35 ILL. ADM. CODE 211, ) 218, and 219 )

CERTIFiCATE OF SERVICE

I, the undersigned, an attorney, state that I have served electronically the attached

REQUEST TO CANCEL HEARING and MOTION TO CORRECT TRANSCRIPT upon the

following person:

John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601-3218

and electronically to the following persons:

SEE ATTACHED SERVICE LIST.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

/,;J7_:t2,4;2_.

Dana Vetterhoffer 7

Assistant Counsel

Division of Legal Counsel

DATED: May 19,2011

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544
Service List R1i-23

Timothy J. Fox

Hearing officer

Illinois Pollution Control Board

100 W. Randolph St., Suite 1 1..500

Chicago, IL 6060 I

foxt@ipcb.state.il.us

Virginia Yang

Deputy Legal Counsel

Illinois Department of Natural Resources

One Natural Resources Way

Springfield, 1L 62702-1271

ygiayang(2i,il1inois.gov

Matthew Dunn, Chief

Division of Environmental Enforcement

Office ofthe Attorney General

100 West Randolph St., Suite 1200

Chicago, IL 60601

mdunn(atg.state.i1.us

Alec M. Davis

General Counsel

Illinois Environmental Regulatory Group

215 F. Adams St.

Springfield, IL 62701

adavisierg.org

James Sell

American Coatings Association

1500 Rhode Island Avenue, NW

Washington, DC 20005

i sellipaint.org

Katherine D. Hodge

Monica T. Rios

Hodge Dwyer & Driver

3150 Roland Ave.

P.O. Box 5776

Springfield, IL 62705-5776

khodge@hddattorneys.com

mrioshddattorneys. corn
O

G

N

C MATERIAL EMISSIONS FROM)

GROUP II AND GROUP IV CONSUMER &)

COMMERCIAL PRODUCTS: PROPOSED )AMENDMENTS TO 35 ILL. ADM. CODE )211,218,and2l9 )

HEARING OFFICER ORDER

The second hearing in this “fast-track” rulemaking proceeding took place as scheduled on

Wednesday, May 18, 2011, in Chicago, and the Board received the transcript (Tr.2) later that

day. The Board posted the entire transcript to the Clerk’s Office On-Line (COOL), which isaccessible through the Board’s Web site (www.ipcb.state.il.us).

In an order dated March 17, 2011, the hearing officer scheduled a third hearing beginning

on Wednesday, June 1, 2011, in Chicago and required the pre-filing of testimony for that hearingon or before Friday, May 20, 2011. See Public Act 96-0308, eff. Aug. 11,2009 (P.A. 96-0308)

(re-enacting repealed Section 28.5 and requiring pre-filing at least 10 days before hearing).

Section 28.5(f)(3) of the Environmental Protection Act (Act), provides that

[t]he third hearing shall be scheduled to commence within 14 days after the first

day of the second hearing and shall be devoted solely to the [Illinois

Environmental Protection] Agency response to the material submitted at the

second hearing and to any response by other parties. The third hearing shall be

cancelled if the Agency indicates to the Board that it does not intend to introduceany additional material. P.A. 96-0308 (emphasis added).

During the second hearing, counsel for the Agency indicated that it did not at that time wish to

address the issue of the third hearing. Tr.2 at 28. However, counsel agreed that, by Friday, May

20, 2011, the Agency would either pre-file testimony for the third hearing according to theoriginal deadline or file a request to cancel the hearing. See id. at 29.

On Thursday, May 19, 2011, the Agency filed a request (Req.) “that the Illinois Pollution

Control Board cancel the hearing currently scheduled to take place on June 1, 2011, in this

matter.” Req. at 1. The Agency stated that it “does not wish to introduce additional materials at

such hearing, and believes that outstanding issues can be resolved through post-hearing

comments.” Id.; see P.A. 96-0308 (Section 28.5(f)(3)). Accordingly, the third hearing in thisproceeding is cancelled.
The statutory 14-day comment period began Wednesday, May 18, 2011, and will close

Wednesday, June 1,2011. The “mailbox rule” (35 Ill. Adm. Code 101.300(b)(2)) does not applyto the filing of these post-hearing comments, and the Board’s Clerk must receive any posthearing comments before the close of business on Wednesday, June 1, 2011. Although

comments may be filed electronically through COOL, all electronic or approved fax filings must

be received by the Clerk’s Office no later than 4:30 PM on June 1,2011. Questions aboutelectronic filing should be directed to the Clerk’s Office at 312-814-3629.

IT IS SO ORDERED

Timothy J. Fox, Hearing Officer

Illinois Pollution Control Board

100 West Randolph St., Suite 11-500

Chicago, Illinois 60601312-814-6085312-814-3669 (fax)

foxt@ipcb.state.il.us