ILLINOIS ENVIRONMENTAL PROTECTION AGENCY 

1021 NORTH GRAND AVENUE EAST, P .0. Box 19276, SPRINGFIELD, ILLINOIS 62794~9276•(217)782-2829 

JAMES R. THOMPSON CENTER, 100 WEST RANDOLPH, SUITE 11-300, CHICAGO, IL 60601•(312)814-6026 

217/785-4140 

217/782-9143 (TDD) 

September 3, 2014 

PAT QUINN, GOVERNOR 

RECEIVED 

SEP 0 9 2014 

liSA BONNETT, DIRECTOR 

Certified Mail U.:::.. CO"!. l\.LU!UN) 

OFFICE OF REGIONAL ADMINISTRATOR Return Receipt Requested 

7012 0470 0001 3000 9514 

Dr. Susan Hedman 

Regional Administrator 

U. S. Environmental Protection Agency, Region 5 

77 West Jackson Boulevard (R-19J) 

Chicago, IL 60604-3507 

Re: State Implementation Plan Revision 

Dear Dr. Hedman: 

Pursuant to Section 169A of the Clean Air Act ("CAA'') (42 U.S.C. § 7491) and Section 4 of the 

Illinois Environmental Protection Act (415 ILCS 5/4), the Illinois Environmental Protection 

Agency ("Agency") submits the enclosed revision to the Illinois State Implementation Plan 

("SIP"). This revision has been prepared as a result ofthe Illinois Pollution Control Board 

("Board") granting a variance to Illinois Power Holdings, LLC ("IPH") and AmerenEnergy 

Medina Valley Cogen, LLC ("Medina Valley"), and the Agency is requesting that this variance be 

considered for approval as a revision to the Illinois SIP. 

On July 22, 2013, IPH and Medina Valley, along with Ameren Energy Resources, LLC ("AER"), 

filed a Petition for Variance with the Board. IPH and Medina Valley requested a variance for the 

electrical generating units in AER's Multi-Pollutant Standards ("MPS") Group from both the 2015 

and 2017 sulfur dioxide ("SOz") emission rate provisions of the Illinois MPS, 35 Ill. Adm. Code 

225.233, specifically the S02 emission standards set forth in Section 225.233(e)(3)(C)(iii) and 

(iv). 

IPH, an indirect subsidiary ofDynegy, Inc., acquired ownership of the operating merchant 

generating stations, namely the Coffeen Energy Center located in Montgomery County, the Duck 

Creek Energy Center located in Fulton County, the E.D. Edwards Energy Center located in Peoria 

County, the Joppa Energy Center located in Massac County, and the Newton Energy Center 

located in Jasper County, under a transaction agreement between Ameren Corporation and IPH. 

Medina Valley acquired the shuttered generating stations, the Meredosia Energy Center in Morgan 

County and the Hutsonville Energy Center in Crawford County. On November 21, 2013, the 

Board granted the variance to IPH and Medina Valley from the applicable requirements of35 Ill. 

Adm. Code 225.233(e)(3)(C)(iii) for a period beginning January 1, 2015, through December 31, 

2019, and 35 Ill. Adm. Code 255.233(e)(3)(C)(iv) for a period beginning January 1, 2017, through 

December 31, 2019, subject to certain conditions. Illinois Power Holdings, LLC and 

Rockford • 4302 N. Main St., Rockford, IL61103 • (815) 987-7760 

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

Bureau Of Land- Peoria • 7620 N. University St., Peoria. ll61614 • (309) 693-5464 

Collinsville • 2009 Mall Street, Collinsville, IL 62234 • {618) 346-5120 

Des Plaines • 9511 Harrison St., Des Plaines, IL 60016 • {847) 294-4000 

Peoria • 5415 N. University St., Peoria, IL 61614 • {309) 693-S463 

Champaign • 2125 S. First St., Champaign, IL 61820 • {217) 278-S800 

Marion • 2309 W. Main St., Suite 116, Marion, !L 62959 • (618) 993-7200 
AmerenEnergy Medina Valley Cogen, LLC, and Ameren Energy Resources, LLC v. Illinois 

Environmental Protection Agency, PCB 14-10. This variance supersedes the previously-granted 

variance from the MPS for the same units that AER held. Ameren Energy Resources v. Illinois 

Environmental Protection Agency, PCB 12-126. The Agency submitted the PCB 12-126 variance 

for approval as a revision to the Illinois SIP on May 16, 2013. 

The Illinois MPS, which includes Section 225.233(e), is an approved rule of the Illinois SIP and 

was submitted to address the visibility protection requirements of Section 169A of the CAA, 42 

U.S. C.§ 7491, and the Regional Haze Rule, as codified in 40 CFR § 51.308. See, 77 Fed. Reg. 

39943 (July 6, 2012). Accordingly, since IPH and Medina Valley sought relief from provisions of 

the MPS and such relief was granted by the Board, the variance must be submitted for approval as 

a SIP revision addressing the visibility requirements under the CAA and the Regional Haze Rule. 

As evident from the approval of Illinois' Regional Haze plan, the MPS provides emission 

reductions well in excess of simply implementing Best Available Retrofit Technology ("BART") 

on subject units. Taking into account the variance granted to IPH and Medina Valley, the 

reductions from Illinois' plan continue to provide significantly greater emission reductions for S02 

than even very conservative defmitions of BART for the BART -subject units. 

The Agency provided public notice of the SIP revision, and a public hearing was held on May 20, 

2014. Public comments were submitted to the Agency and such comments are included herein, 

along with the Agency summary of comments and statement. 

In order to assist with your review of this plan revision submittal, the following documents are 

enclosed (one hard copy and one exact duplicate electronic copy on disc): 

Attachment 1) 

Attachment 2) 

Attachment 3) 

Attachment 4) 

Attachment 5) 

Attachment 6) 

Attachment 7) 

Attachment 8) 

Attachment 9) 

Attachment 1 0) 

Attachment 11) 

Attachment 12) 

Attachment 13) 

Attachment 14) 

Attachment 15) 

Attachment 16) 

Attachment 1 7) 

Attachment 18) 

Attachment 19) 

Attachment 20) 

Petition for Variance filed by IPH, Medina Valley, and AER (July 22, 2013) 

Certification of Publication by the Agency (July 30, 2013) 

Board Order (August 8, 2013) 

Notice of Hearing (August 8, 2013) 

Hearing Officer Order (August 14, 2013) 

Objection filed by Citizens' Groups (Exhibits Not Included) (August 15, 2013) 

Recommendation of the Agency (September 5, 2013) 

Agency Responses to the Board's Questions (Exhibits Not Included) (September 5, 2013) 

Petitioners' Responses to the Board's Questions (September 5, 2013) 

Hearing Officer Order (September 12, 2013) 

Agency Response to Board Question (September 16, 2013) 

Petitioners' and Co-Petitioner's Response to Board's Questions (September 16, 2013) 

Hearing Report (September 18, 2013) 

Post-Hearing Comments filed by Citizens' Groups (September 24, 2013) 

Waiver of Statutory Decision Deadline (September 24, 2013) 

Comments of the Illinois Attorney General's Office (September 24, 2013) 

AER's Brief in Response to Comments (October 7, 2013) 

Petitioners' and Co-Petitioner's Post-Hearing Brief(October 7, 2013) 

Petitioners' and Co-Petitioner's Post-Hearing Comment (October 17, 2013) 

Board Order Granting Variance (November 21, 2013) 

2 
Attachment 21) 

Attachment 22) 

Attachment 23) 

Attachment 24) 

Attachment 25) 

Attachment 26) 

Attachment 27) 

Attachment 28) 

Attachment 29) 

Attachment 30) 

Dissenting Opinion (November 21, 2013) 

Certificate of Acceptance filed by IPH and Medina Valley (December 20, 2013) 

Notice of Public Information, 38 Ill. Reg. 2464 (January 17, 2014) 

Request for Public Hearing (February 18, 2014) 

Public Comment (February 18, 2014) 

Notice of Hearing, 38 Ill. Reg. 7689 (April4, 2014) 

Hearing Transcript (May 20, 2014) 

Joint Public Comment of Illinois Power Holdings, LLC, and AmerenEnergy 

Medina Valley Cogen, LLC (June 20, 2014) 

Comments ofEarthjustice, Environmental Law and Policy Center, and Sierra 

Club (June 20, 2014) 

Agency Summary of Comments and Statement (August 19, 2014) 

The entire docket for this variance is located at the Board's website at 

http://www .ipc b. state.il. us/COO Ll external/ Case View. aspx?referer=results&case= 14665. 

If further information is required, please contact Gina Roccaforte at 217/782-5544. 

~ely, 

~~~ Director 

Attachments 

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