ILLINOIS ENVIRONMENTAL PROTECTION AGENCY

1021 orth Grand Avenue Ea", P.O. Box 19276, Springfield, IllinoIS 62794-9276' (217) 782·2829

Jame, R. Thompson Center, 100 We" Randolph, Sulle 11·300, Chicago, II 60601 • (312) 814·6026

PAT QUI N, GO\TR"OR

217/782-5544

217/782-9143 (TDD)

November 8, 2010

Cheryl ewton, Director

Air and Radiation Division

United States Environmental

Protection Agency Region V

77 West Jackson Boulevard, AR-18J

Chicago, Illinois 60604-3598

Attn: Jay Bortzer

DOUGLAS P. Scan, DIRECTOR

CERTIFIED MAIL

RETURN RECEIPT REQUESTED

Re: AS 09-4: III the Matter of: Petition of Royal Fiberglass Pools, Inc. for all Adjusted

Standard from 35 III. Adm. Code Section 215.

Dear~jn:

Pursuant to Section 110(a)(2) ofthe Clean Air Act (CAA) (42 V.S.c. §741O (a)(2)), and Section

28 ofthe llIinois Environmental Protection Act (4151LCS 5/28), the lJIinois Environmental

Protection Agency (illinois EPA) submits the following amendments to the Illinois State

Implementation Plan (SIP). The amendment reflects an adjustment to the general rule due to the

extenuating circumstances of Royal Fiberglass Pools ("Royal'').

The petition for an adjusted standard was docketed by the Tllinois Pollution Control Board (IPCB) as

AS 09-4, A public hearing was held October 28,2009, in Mount Vemon, lJIinois. The Illinois EPA

filed post-hearing comments in support ofthe proposed adj usted standard. On February 18, 20 10,

the Board adopted a Final Opinion and Order.

In order to assist with your review ofthis SIP submittal, the following documents are enclosed:

Attachment I)

Attachment 2)

Attachment 3)

The petition ofRoyal for an adjusted standard, filed on April 3, 2009.

Board Hearing Officer Order, filed on June 4,2009.

Board Order, filed on June 4, 2009

Rockford. 4)(1~ N ""'oliO St Rockford, It bll0) • f81 SI 967·77&(}

EI&in • S9S 5 Slate, Ej~m. It b0121 • (847) 6()8.] 1.3 I

Burt'.u o( L.lnd - Peori.J. 'fl20 N UnlYerstly SI., Peoria. Il61614 elJ09lbc

B-S462

CoUinsville • ..200lJ Mdll Slrt'('1. Colhnsville. It 622.34 -16161 140..5120

Des Pl.JiMS. 951\ W H,lm'>(m <iI, De~ P1ol,nes, It 60016 -(847) lIJ4·4000

PeoN • 5415'" Unlvt'f\lly SI Pl:ona. IL 61614 • (]()<II 69]·540]

CMi~~n. 2125 S, Flf~1 51 , C.h.Jrnpalgn, IL 61620. (2171 276-~600

M~rion. 2]09 \IV Main SI, Sulle 11&, Mallon, Il &2959. (616199]·7100

PTlfll " It.,,-)< r I....
Anachmcnt -l)

'\nachmcnt 5)

Attachmcnt 6)

Attachmcnt 7)

Attachmcnt 8)

Attachment 9)

Attachmcnt 10)

Attachmcnt II)

Attachment 12)

Attachment 13)

Attachment 14)

Anachment 15)

Attachment 16)

Attachment 17)

Anachment 18)

Attachment 19)

Attachment 20)

Attachment 21)

Attachment 22)

Board Hearing Ofliccr Oroa. filed on June ~2. ~009

Petitioner's First Amcnded Pctition for an Adjusted ~tandard. filed Jul~

17,2009.

Board Hearing Officer Ordcr. filed on Jul) 27,2009

Board llearing Ollieer Order. filed on August 5.2009

Board Order. liled on j\ugust 6. 2009

Board Hearing Officer Order, filed on August 18.2009

Recommendation of the Illinois Em irorunental Protection Agenc). filed

August 20, 2009

Board llearing Officer Ordcr Setting Date for Hearing, filed on Septembcr

14.2009

Notice of Hearing set for October 29. 2009

Responses of Petitioner Royal Fiberglass Pools Lo Questions from the

Illinois Pollution Control Board

Board lIearing OOicer Order. filed on October 5, 2009

Illinois EPA's Response to Questions Posed by the Illinois Pollution

Control Board. filed October 14.2009

Board IIearing Oftieer Order containing Follow-up Questions to Parties

Answers, filed on October 21. 2009

Illinois EPA's Response to Follow-up Questions Posed by the Illinois

Pollution Control Board. filed October 27. 2009

Board Ilearing Officer Order assessing Credibility of Witnesses. filed

October 29. 2009.

Transcript of Ilearing Held on October 28. 2009.

Illinois EPA's Response to Questions Posed by the Illinois Pollution

Control Board at Hearing. filed ovember 16. 2009

Post-llearing BriefofPetitioner. filed December 7, 2009.

Illinois EPA Motion to File Instanter Post-Ilearing Commcnts and

Respondent's Posl-Ileming Briel: December 16,2009
Attachment ~3) Order ofIllinois Pollution Control Board Granting Petitioner's Adjusted

Standard, Filed February 18,2010.

The SIP Checklists are also enclosed to assist in your review.

If further information is required, please contact Shannon Bilbruck ofmy staff at 217/557-4261.

CjJ)0~

Laurel L. Kroack, Chief

Bureau of Air

Attachments

bcc: Laurel Kroack- letter, checklists

Vicky Von Lanken- letter, checklists

Jim Ross- letter, checklists

AQPS- letter, checklists, attachments

Charles Matoesian- letter, checklists

Shannon Bilbruck- letter, checklists, attachments
STATE IMPLEMENTION PLAN CHECKLISTS

AS 09-4: In the Matter of: Petition of Royal Fiberglass Pools. Inc. for an Adjusted

Standard from 35 III. Adm. Code Section 215.301

Illinois Environmental Protection Agency

Bureau of Air

Division of Legal Counsel

1021 North Grand Ave. East

P.O. Box 19276

Springfield. Illinois 62794-9276
ADMINISTHATIVE CHECKLIST

Re: ;\S 09-4 Allachment

I. The Submittal is accompanied b~ a lunnalletler of Ycs. Co\cr

submittal from the (,0\ ernor or designee. ICller

'nle date ofsubmillal is November 8, 2010

2. Evidence is provided that thc revision has been adopted in ':-J/;\

the State Code or body ofrcgulations.

• The date of adoption is Februal} 18.2010.

• Test methods/rules are correctly incorporated by N/A

reference ,

J. Evidence is provided that the State has the necessary legal Sections 28 of

authority under Stale la\\ to adopt and implement the the III. Env.

reVISion Prot. ;\ct

·t A copy ofthe actual regulation or document is included in I

the submittal

5. Evidence is provided that the State followed all the 2.3.4.12,13.

requirements of its Administrative procedures Act (or 15.20.24

equivalent) in conducting and completing

adoption/issuance of the revision.

6. Evidence is provided that public noticc was givcn by the 3.12.24

State, including the date of publication.

7. Certification is providcd that the public hearing was held in 13.19,20

accordance with the information provided in the public

notice.

The date of the public hearing was October 28. 2009

8. The submittal contains a compilation ofthe exhibits 20.24

entercd into the record at hcaring.

9. The submittal contains a compilation of public comments N/A
TECHNICAL CHECKLIST

Rc: AS 09--1 .\llachmcnt

I. The regulated pollutant$ alTectcd b) rcvision are: sulfur

dioxide__: ozone ~: particulate matter__: I

nitrogen oxides ; carbon monoxide .., Attainment status designation lor the affected area is N'A

included in thc submittal.

Status ofthc attainment plan tor the arfected area is NIA

included in the submittal.

The attainment date for the afrected area is included in the N/A

submittal. ,

J. The locations and tYPC$ of affected sourCC$ are identified. 1.5

4. Changes in SIP-allowable emissions for affected sourccs 1.5

are quantified or estimated.

Changes in actual emissions from affected sources are 1.5

quantified or estimated.

5. Evidence is provided that thc NAAQS will bc protected if 24

the revision is approved and implemented.

Evidence is provided that the PSD incrcment will be N/A

protected ifthc rcvision is approved and implemented.

Evidcnce is provided that thc RFP dcmonstration will bc N/A

protected if thc revision is approvcd and implemented.

Evidence is provided that visibility will be protcctcd if the 24

revision is approved and implemented.

6. Modeling information is provided (if necessary) in support I. 5, 24

ofthe revision.

7. The proposed emission limitations are based on continuous N/A

emissions reduction technology.

8. The emissions limitations requirements are incorporated (if N/A

necessary) to ensure emission levels.

The work practice standards requirements are incorporated N/A

(if necessary) to cnsurc emission leyels.

The recordkeeping/rcporting requirements are incorporated 24

(if necessary) to cnsure cmission levels.

9. The submittal contain$ entorcementlcompliance trategies, N/A

including how compliance will be detennined in practice

and at what freq uenc),.
ENFORCEABILITY CHECKLIST

Re: AS 09-4 Attachment

I. Applicabilit\

What sources arc bcing rcgulatcd? I

What arc criteria Cor exemption'? N//\

Is calculation procedure for exemption c1earlv specified? N/A

Is emission inventory listed in the background document of N/A

the attainmcnt demonstration')

Are the averaging times used in the rule differcnt from N/A

those ofthe ambicnt standard?

What are the units of compliance (Ibs VOC per hour) N/A

Is bubbling or averaging of any typc allowed? If yes, state No

criteria. Could a USEPA inspcctor indepcndently

determine if the criteria were Illet? Does EPA have to

approve each case?

If there is a redcsignation, will this change the emission N/A

limitations? If yes, which ones and how?

2. Compliance Dates

What is the compliance date? 24

What is the attainment date? N/A

0

~. Specificity ofConduct

What test method is requircd? N/A

What is the averaging time in compliance test method? N/A

Is a compliance calculation or evaluation required? (i.e.. N/A

daily weighted average for VOC)

If yes, Iist the formula, period of compliance, and/or N/A

evaluation period.

4. Incorporation by Reference

What is the state authority for rulemaking? St:Cllon 28 of the III

Fnv Prot Act

Are methods/rules incorporated by reference in the right N/A

manner?

5. Recordkeening

What records are required to determine compliance? 24

In what form or units (lbs/gaJ. gr/dscf, etc...) must the Ibs/gal, annual

records be kept? On what time basis (instantaneously.

hourly, daily)?

Does the rule affirmatively require the records be kept? yes

6. Exemption

List any exemptions allowcd. N/A

Is the criteria for application clear? t\/A