Attachment 11

Hearing Officer Order

dated May 17, 2013

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Attachment 12

List of Exhibits Submitted at Hearing of May 8, 2013 in 

Springfield, IL, dated May 17, 2013 

(All exhibits omitted. Exhibits 1 and 2 included as

Attachment 7. Exhibit 3 omitted as it is a USEPA document.) 

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 625
Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 626
ILLINOIS POLLUTION CONTROL BOARD 

May 17,2013 

IN THE MA TIER OF: ) 

) 

VAPOR RECOVERY RULES: ) 

AMENDMENTS TO 35 ILL. ADM. CODE ) 

PARTS 201,218, and 219 ) 

Rl3-18 

(Rulemaking - Air) 

EXHIBIT LIST 

First Hearing: May 8, 2013, Springfield 

Exhibit 1: Pre-filed Testimony of Darwin Burkhart of IEPA 

Exhibit 2: Pre-filed Testimony of Ross Cooper of IEPA 

Aeo·EIVEO 

CLERk•s OFFICE 

MAY 1 7 20f3 

STATE .OF IWNOI 

floflution Control B~ 

Exhibit 3: "Motor Vehicle Emission Simulator (MOVES)," User Guide for MOVES2010b, 

USEPA, Assessment and Standards Division, Office ofTransportation and Air Quality, EPA420-B-12-00lb (June 2012) 

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 627
Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 628
Attachment 13

Prefiled Testimony of 

Darwin Burkhart and Chuck Gebhardt

for June 5, 2013 hearing

dated May 24, 2013

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 629
Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 630
TO: John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

Richard R. McGill, Jr.

Hearing OfficerIllinois Pollution Control BoardJames R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

NOTICE OF FILING

Thomas Davis, Bureau Chief

Enviromnental Bureau

Office ofthe Attorney General500 South Second Street

Springfield, Illinois 62706

Mitchell Cohen, General Counsel

Office of Legal Services

Illinois Department ofNatural ResourcesOne Natural Resources Way

Springfield, IL 62702-1271

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

Board the TESTIMONY OF DARWIN BURKHART and TESTIMONY OF CHUCK

GEBHARDT of the Illinois Environmental Protection Agency, a copy of which is herewithserved upon you.

DATED: May24, 2013

1021 N. Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276

(217) 782-5544

(217) 782-9143 (TDD)

Respectfully submitted,

ILLINOIS ENVIRONMENTALPROTECTION AGENCYBy:

Kent E. Mohr Jr.

Assistant Counsel

Division of Legal Counsel

D OJ?Ic1jL

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 631
)

TESTIMONY OF DARWIN BURKHART

Good afternoon, my name is Darwin Burkhart and I am Manager ofthe Clean Air Programs in

the Bureau of Air at the Illinois Environmental Protection Agency (Illinois EPA). Part of my

duties is overseeing the Stage I and Stage II Gasoline Vapor Recovery program, as well as the

proposed rulemaking and the Technical Support Document that we are here to present today.

Other Illinois EPA staff with me today are Chuck Gebhardt, Mike Rogers, Jerry Clark, and Ross

Cooper. These gentlemen contributed various portions and levels of expertise to the Technical

Support Document and will be able to help answer any specific questions that the Board or

audience may have.

At the first hearing on May 8, 2013 in Springfield, Illinois EPA staffresponded to many ofthe

Illinois Pollution Control Board (Board) pre-filed staff questions and agreed to respond in

writing to the more technical questions regarding the modeling inputs and results. In addition,

the Board requested copies of draft forms regarding the notice that gasoline facilities will provide

the Illinois EPA prior to decommissioning, along with the form that includes the

decommissioning checklist. These draft forms are attached as Exhibits 1 and 2 to this testimony.

Mr. Chuck Gebhardt will address the remainder ofthe Board staff questions that we agreed to

respond in writing. This concludes my testimony.

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 632
p

ss

oning

(mldd/yyyy)

Gasoline Dispensing Facility Information

Facility Name:

Facility Address:

(Street) (City) (Zip Code)

Owner Name:

Owner Address:

(Street) (City, State) (Zip Code)

Operator Name:

Operator Address:

(Street) (City, State) (Zip Code)

Owner/Operator Contact:____________________________ Phone: (__J______________ Email:IEPA Facility ID#_________________________________ Office of the State Fire Marshal Facility ID#_______________________

Decommissioning Contractor Information

Piping Contractor:

(company name)

Office of the State Fire Marshal license number:____________________________________________________________________

Illinois Department of Agriculture registration number:

Dispenser Contractor

(company name)

Office of the State Fire Marshal license number:

Illinois Department of Agriculture registration number:

Office of the State Fire Marshal license number:__________________________________________________________________

Testing Contractor:

(company name)

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 633
Signature of Owner or Operator Date

Printed Name:_______________________________________________ Title:

Company:

The Illinois EPA is authorized to recuire, and you shall disclose, the information requested on this form pursuant to 35 ill. Adm. Code

218.586. This information shall be provided using tnis form. Failure to disclose the reQuisite information may result in theincomplete submittal of this form, failure to comply with 35 Ill. Adm. Code 218.586. and/or penalties being imposed as provided for in

the Illinois Environmental Protection Act. 415 ILCS 5/42-45. Any person who knowingly makes a false, fictitious, or fraudulent

matenal statement, oraty or in wnnng. to the Illinois EPA commits a Cass 4 feiony. A secono or subsequent offense after

conviction s a Ciass 3 feony. (415 ILCS 5/44(h)).

Illinois Environmental Protection Agency

Date Received:

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 634
Owner Name:

Owner Address:

(Street) (City, State) (Zip Code)

Operator Name:

Operator Address:

(Street) (City, State) (Zip Code)

Owner/Operator Contact:____________________________ Phone: L_J______________ Email: — IEPA Facility lD#_________________________________ Office of the State Fire Marshal Facility ID#

Date of Decommissioning Stage II Equipment

(m/dd/yyyy)

PEI/RP 300 — Decommissioning Activity Completed?

09 Reference

14.61 Initiate safety procedures n Yes u NA14.6.2 Relieve pressure in the tank ullage C Yes C NA

14.6.3 Drain liquid-collection points Yes C NA

14.6.4 & 14.6.5 Disconnect all vapor pumping or processing units Yes ii NA14.6.4 Disconnect all electrical components of the Stage II Yes NA

system so that no electrical hazards are created

14.6.4 Reprogram the dispenser electronics to reflect that ci Yes ci NA

Stage II vapor recovery is no longer in service

14.6.6 Securely seal off the below-grade vapor piping at a ci Yes ci NA

height below the level of the base of the dispenser

14.6.7 Securely seal off the below-grade vapor piping at the ci Yes ci NA

tank_end_if_it_is_easily_accessible

14.6.8 Securely seal the vapor piping inside the dispenser ci Yes ci NA

cabinet

14.6.9 Replace the Stage II hanging hardware with ci Yes ci NA

conventional_hanging_hardware

14.6.10 Install appropriate pressure/vacuum vent valve(s) ci Yes ci NA

14.6.11 Remove any Stage II instructions from the dispenser ci Yes ci NA

cabinet

14.6.12 Conduct and pass the pressure decay test and tie-tank ci Yes ci NA

test;_attach_test_results

14.6.13 Verify that the visible components of the storage ci Yes ci NA

system are left in a condition that will reliably prevent

the release of any vapors or liquids from any

component_of the_storage_system

14.6.13 Restore the facility to operating status ci Yes ci NA

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 635
City/State Zip Code

Phone:

()____________________

Office of the State Fire Marshal license number:

Illinois Department of Agriculture registration number:

The undersigned hereby certifies that the statements contained herein are true, accurate and complete, and certifies that the decommissioning

procedures performed by the above-specified company were in accordance with 35111. Adm. Code 2 18.586 and PEI/RP 300-09, Section 14.6. By

affixing his/her signature hereto the undersigned further certifies that he/she is authorized to execute this form.

Signature of Lead Contractor or Technician Date

Name:____________________________________________________ Title:

Dispenser Contractor:

(Company name)

Address:____________________________________

Street City/State Zip Code

Phone:

()___________________

Office of the State Fire Marshal license number:

Illinois Department of Agriculture registration number:

Certified by Dispenser Manufacturer to work on its dispensers? C Yes U No Comment:

The undersigned hereby certifies that the statements contained herein are true, accurate and complete, and certifies that the decommissioning

procedures performed by the above-specified company were in accordance with 35 III. Adm. Code 2 18.586 and PEI/RP 300-09, Section 14.6. By

affixing his/her signature hereto the undersigned further certifies that he/she is authorized to execute this form.

Signature of Lead Contractor or Technician DateName:____________________________________________________ Title:

Testing Contractor:

(Company name)

Address:

Street City/State Zip Code

Phone:

(.............)__________________

Office of the State Fire Marshal license number:_______________________________________________________________________

The undersigned hereby certifies that the statements contained herein are true, accurate and complete, and certifies that the decommissioning

procedures performed by the above-specified company were in accordance with 35111. Adm. Code 2 18.586 and PEI/RP 300-09, Section 14.6. By

affixing his/her signature hereto the undersigned further certifies that he/she is authorized to execute this form.

Signature of Lead Contractor or Technician Date

Name:____________________________________________________ Title:

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 636
Corn pany

The Illinois EPA is authorized to recuire, and you shall disclose, the information requested on this form pursuartto 35 Ill. Adm. Code 218.586.

This information shall De provided using this form. Failure to disclose the requisite information may result in the incomplete submittal of tnis

form, failure to comply with 35 ill. Adm, Code 218.586, and/or penalties ben.g imposed as provided for in the iliinois Envconmentai Protection

Act, 415 LOS 5/42-45. Any person who knowingly makes a faise. fictitious, or fraudulent material statement, orally orin writing, to the Illinois

EPA commits a Class 4 felony. A second or subsequent offense after conviction is a Class 3 felony. (415 LOS 5/44(h))

Illinois Environmental Protection Agency

Date Received:

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 637
TESTIMONY OF CHUCK GEBHARDT

Good afternoon, my name is Chuck Gebhardt and I am Manager ofthe Technical Services

Section in the Bureau of Air at the Illinois Enviromnental Protection Agency (Illinois EPA). Part

of my duties is modeling mobile source emissions using the United States Environmental

Protection Agency’s (U.S. EPA) Motor Vehicle Emissions Simulator (MOVES) model. My

testimony consists ofresponses to Illinois Pollution Control Board (Board) staff questions from

the May 8, 2013 hearing where I agreed to respond in writing.

Board Staff Questions from First Hearing, Technical Support Document Section, and Responses

2. Please spell out the following acronyms appearing in the table entitled “Key Input Data

for the MOVES Model” on page 7 ofthe TSD: HPMSV; VMT; TM; and OBD. Also, please

explain what these terms mean in the context ofthe MOVES model.

RESPONSE:

“HPMSV” is not an acronym with respect to MOVES. We believe that the board is

referring to “HPMS” which refers to Federal Highway Performance Monitoring System.

U.S. EPA’s MOVES model requires that Vehicle Miles Traveled, or VMT, data is

distributed according to vehicle class as defined in the HPMS information. The MOVES

model uses the VMT and type of vehicles in the “HPMSvTypeYear” table with other

information to estimate emissions.

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Vehicle Miles Traveled in the Chicago nonattainrnent area. U.S. EPA expects model

users to provide local VMT data to accurately represent the miles traveled in the area

being modeled. Annual VMT is distributed by the vehicle source types described in the

Federal Highway Performance Monitoring System. VMT for previous years is obtained

from the Illinois Department of Transportation while VMT for future years is estimated

by growing the current year’s VMT at an annual rate of 1.5%.

“monthVMTFraction” is a MOVES table with imported data showing how the annual

VMT is distributed monthly.

“dayVMTFraction” is a MOVES table with imported data showing how the annual VMT

is distributed daily.

“hourVMTFraction” is a MOVES table with imported data showing how the annual

VMT is distributed hourly.

“zoneMonthHour” is a MOVES table with imported data providing average

meteorological data including hourly temperatures and relative humidity. Data used in

2

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 639
type of fuels are used in the Chicago nonattainment area.

“fuelFormulation” is a MOVES table with imported data defining attributes about the

fuel used in the Chicago nonattainment area.

“IMCoverage” is a MOVES table with imported data about the Chicago nonattaimnent

area emissions testing program. While the testing program is described, it should be

noted that an emissions testing program does not affect refueling emissions.

4. Attachment B to the TSD contains the MOVES input and output files in “MySQL

format” on a compact disc. To make this information more readily understandable, please

provide, if feasible, a written summary ofthe input and output files (not simply pages of

numbers) that would give ranges and averages for the key input data parameters listed on page 7

ofthe TSD, as well as output values other than those graphed in Figure 1 ofthe TSD.

RESPONSE:

The compact disc includes the input files required to run MOVES and the output files in

the format that complies with U.S. EPA State Implementation Plan revision requirements.

Providing a summary ofthe input data is not really feasible, but the response to question

number five is a summary ofthe output data that is relevant to refueling emissions.

3

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Chicago Nonattainment Area Refueling Emissions

Analysis Using MOVES

Refueling Emissions (Tons / day VOC)

Year ORVR ORVR + Stage II Emissions Gain/Loss

Only with lEE With Stage II

2007 14.52 4.39 10.13

2008 12.15 4.20 7.95

2009 11.66 4.42 7.23

2010 9.45 4.27 5.18

2011 8.12 4.31 3.81

2012 5.98 4.08 1.902013 4.92 4.08 0.84

2014 4.00 4.07 -0.07

2015 3.23 4.04 -0.81

2016 2.57 3.98 -1.41

2017 2.08 3.94 -1.852018 1.85 3.93 -2.08

2019 1.54 3.89 -2.35

2020 1.31 3.84 -2.54

6. The TSD refers to the “January 2014 cross-over point.” TSD at 9. Please clarify whether

the points graphed in Figure 1 correspond to January 1st of each year on the horizontal axis.

RESPONSE:

The points on the graph do not represent any specific date because MOVES estimates

VOC emissions for an average weekday in a selected month. The Illinois EPA modeled

July since it is generally considered the peak ofthe ozone season.

4

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 641
rather than an increase due to the incompatibility issue affecting more vehicles over time?

RESPONSE:

The Illinois EPA believes refueling emissions decrease because newer vehicles

with better gas mileage are replacing older vehicles with poor mileage. The

benefits in improving gas mileage exceed the emissions due to incompatibility.

c. The TSD states that “[a]fier this [cross-over] point, the difference between the

two lines represents the reduction in refueling emissions if Stage II is decommissioned.

This difference is 0.7 tpd in 2014 if Stage II is decommissioned increasing to 2.54 tpd in

2020 when an estimated 96% ofthe vehicle fleet will be ORVR equipped.” TSD at .Asthe cross-over point appears to be in 2014, at which point the difference would be zero,

when specifically is the 0.7 tpd difference expected?

RESPONSE:

Upon review ofthe data, 0.7 tpd for July 2014 is a typo and should read 0.07 tpd.

I apologize for the error.

This concludes my testimony.

5

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 642
OF DARWIN BURKHART and TESTIMONY OF CHUCK GEBHARDT of the Illinois

Environmental Protection Agency upon the following persons,

John Therriault, Assistant ClerkIllinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

Richard R. McGill, Jr.Hearing OfficerIllinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

Thomas Davis, Bureau ChiefEnvironmental BureauOffice ofthe Attorney General

500 South Second Street

Springfield, Illinois 62706

Mitchell Cohen, General Counsel

Office of Legal Services

Illinois Department ofNatural ResourcesOne Natural Resources Way

Springfield, IL 62702-1271

by mailing a true copy thereof in an envelope duly addressed bearing proper first classpostage and deposited in the United States mail at Springfield, Illinois on May 24, 2013.

DATED: May24, 2013

1021 N. Grand Avenue East

P.O. Box 19276

Springfield, Illinois 62794-9276(217) 782-5544

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCYBy:

Kent E. Mohr Jr. /

Assistant Counsel

Division of Legal Counsel

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Attachment 14

Hearing Officer Order

dated May 31, 2013

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PARTS 201, 218, and 219 ) ORIGINAL

HEARING OFFICER ORDER

On March 18, 2013, the Illinois Environmental Protection Agency (IEPA) filed a

rulemaking proposal to amend the Board’s air pollution rules at 35 Ill. Adm. Code 201, 218, and

219. The proposal includes the phase out of Stage II vapor recovery systems at gasolinedispensing operations in the Chicago ozone nonattainment area. First-notice publication of the

proposed amendments appeared in the Illinois Register on May 10, 2013. See 37 Ill. Reg. 6028,

6054, 6083 (May 10, 2013).

The second oftwo scheduled hearings will be held in Chicago, beginning at 1:00 p.m. on

June 5, 2013. The deadline to pre-file testimony for the hearing was May 30, 2013. Only JEPApre-filed testimony. Attached to this order are Board staff questions for the witnesses of IEPA.These questions will be taken up at the second hearing. IEPA is not required to present written

responses to the attached questions before or at hearing. The hearing officer will, of course,provide opportunities for other participants attending the hearing to pose questions to IEPA.

ITISSOORDERED.

Richard R. McGill, Jr.

Hearing OfficerIllinois Pollution Control Board

100 West Randolph Street, Suite 11-500

Chicago, Illinois 60601(312) 814-6983

richard.mcgill@illinois.gov

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 647
IEPA ‘s draft form entitled “Notice of Intent to Decommission Stage II Vapor Recovery

Equipment” (Notice of Intent) is provided as Exhibit 1 to Darwin Burkhart’s pre-filed

testimony.

a. The top of page 1 ofthe Notice of Intent calls for the form to be “submitted to the

Illinois EPA at least 10 days prior to commencing Stage II decommissioning.”

This language is nearly identical to the rule language of proposed Section

21 8.586(i)(2)(A). In IEPA’s view, will an owner or operator comply with the rule

by simply sending the completed Notice of Intent to IEPA (e.g., placing in U.S.

Mail with sufficient postage) at least 10 days in advance, or must TEPA have

received the completed form at least 10 days in advance?

b. The first box to complete on the Notice of Intent calls for the “Proposed Date of

Decommissioning,” with “(m/dd/yyy)” provided. As decommissioning may take

more than one day to perform, should the form ask for the proposed date on which

decommissioning will commence or the proposed dates on whichdecommissioning will be performed?

2. IEPA’s draft form entitled “Stage II Decommissioning Checklist” (Checklist) is provided

as Exhibit 2 to Mr. Burkhart’s pre-filed testimony.a. The top of page 1 of the Checklist calls for the form tp be “submitted to the

Illinois EPA within 30 days after the completion of decommissioning.” This

language is similar to the rule language of proposed Section 218.586(i)(2)(C):“Within 30 days after completion of the decommissioning. . . ,the owner oroperator shall provide the completed [Checklist] to the Agency.” In IEPA’s view,

will an owner or operator comply with the rule by simply sending the completed

Checklist to IEPA (e.g., placing in U.S. Mail with sufficient postage) within 30

days after completing decommissioning, or must IEPA have received the

completed form within the 30 days?

b. The first box to complete on the Checklist calls for the “Date of

Decommissioning Stage II Equipment,” with “(m/dd/yyy)” provided. Asdecommissioning may take more than one day to perform, should the form ask for

the date on which decommissioning was completed or the dates on which the

decommissioning was performed?

Illinois Ozone SIP Revision - Vehicle Refuleing Vapor Recovery Program: Attachments Page - 648
1, 2014, to initiate the Stage II phase out rather than July 1, 2014.

2. On page 5 of Mr. Gebhardt’s pre-filed testimony, Mr. Gebhardt states that IEPA believes

refueling emissions would decrease over time even with ORVR plus Stage II “becausenewer vehicles with better gas mileage are replacing older vehicles with poor mileage.”Does the better gas mileage result in reduced refueling emissions because less time is

spent filling up at the pump and less fuel is dispensed?

Miscellaneous

If a company owns used Stage II vapor recovery equipment and opens, in the Chicago

nonattainment area, a “new gasoline dispensing operation that commences operating forthe first time on or after January 1, 2014,” might the company have any economicincentive to make use of its used Stage II equipment at the new operation? See proposed

Section 218.586(d)(2).

a. Ifthe new operation did make use of used Stage II vapor recovery equipment,

would the proposed rules require decommissioning of the Stage II equipment?See proposed Section 2 18.586(i) (“operation subject at any time to subsection (c)

above shall decommission”); see also proposed Section 218.586(d)(2)(“subsection (c) above shall not apply to any new gasoline dispensing operation”).

b. Should “any new gasoline dispensing operation that commences operating for the

first time on or after January 1, 2014,” be prohibited from using Stage II vapor

recovery equipment? See proposed Section 218.586(d)(2) (makes Stage II vaporrecovery requirement inapplicable to new operations).

2. Please provide references to programs for contractors to obtain “dispenser-manufacturer

certifications and training,” as this language is used in proposed Section 218.586(i)(2)(i).

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Attachment 15

Transcript of June 5, 2013 Public Hearing

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