The undersigned, THE NEWS

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notice was published in said newspaper, on the following date(s);

12/24/2012 12/31/2012 01/07/2013

PCB 13-12

ILLINOIS POLLUTION CONTR

Said publisher further certifies that the date of the first paper containing

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The News-Gazette, Inc.

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161131



BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

V.

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY,

Respondent.

To: John Therriault, Assistant Clerk

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601-3218

Bradley Halloran, Hearing Officer

Illinois Pollution Control Board

James R. Thompson Center

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

Kathleen C. Bassi

Stephen J. Bonebrake

Andrew N. Sawula

233 South Wacker Drive, Suite 6600

Chicago, IL 60606

Christopher Foley

500 West Madison Street, Suite 2640

Chicago, Illinois 60661

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

Board the RECOMMENDATION ofthe Illinois Environmental Protection Agency, a copy of

which is herewith served upon you.

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

DATED: January 10, 2013

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544

By: Øe,~ -

Dana Vetterhoffer /

Assistant Counsel

Division of Legal Counsel

MIDWEST GENERATION, LLC,

Petitioner,

PCB 13-024

(Variance-Air)

)

)

)

)

)

)

)

)

)

)

NOTICE

Attachment 11
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MIDWEST GENERATION, LLC, )

) Petitioner, )

) PCB 13-024

v. ) (Variance-Air)

) ILLINOIS ENVIRONMENTAL )

PROTECTION AGENCY, )

) Respondent. )

RECOMMENDATION

The Illinois Environmental Protection Agency (“Illinois EPA” or “Agency”), by its

attorney, hereby responds to the Petition for Variance (“Petition”) of Midwest Generation, LLC

(“MWG” or “Petitioner”) from certain provisions ofthe Illinois Combined Pollutant Standard

(“CPS”) and from provisions in the Illinois Pollution Control Board’s (“Board”) Order in

Midwest Generation, LLC — Waukegan Generating Station v. Illinois Environmental Protection

Agency, PCB 12-121 (Aug. 23, 2012) (“Waukegan Order”). Pursuant to Section 37(a) of the

Illinois Environmental Protection Act (“Act”) [415 ILCS 5/37(a) (2010)] and 35 Ill. Adm. Code

104.2 16, the Illinois EPA neither supports nor objects to the Board granting MWG’s Petition as

specified in this Recommendation. In support of its recommendation, the Illinois EPA states as

follows.

I. PROCEDURAL HISTORY

1. On November 30, 2012, MWG filed its Petition with the Board, requesting a

variance from the system-wide sulfur dioxide (“SO2”) emission rates set forth in 35 Ill. Adm.

Code 225.295(b) from January 1, 2015, to December 31, 2016, with regard to the Crawford

Generating Station in Cook County (“Crawford”), the Joliet Generating Station in Will County

(“Joliet”), the Powerton Generating Station in Tazewell County (“Powerton”), the Waukegan
Generating Station in Lake County (“Waukegan”), and the Will County Generating Station in

Will County (“Will County”). To align with this requested relief, MWG also seeks a variance

from, or amendments to, portions of the Waukegan Order in which the Board ordered MWG to

comply with the Section 225.295(b) emission rates. Finally, MWG requests a variance from the

requirement set forth in 35 Ill. Adm. Code 225.296(a)(2) regarding installation of certain SO2

control equipment on Waukegan Unit 8 by December 31, 2014; MWG requests a five-month

delay in such requirement, to May 31, 2015.

2. Pursuant to the Board’s procedural rules, the Illinois EPA must provide public

notice of any petition for variance within 14 days after the filing ofthe petition. 35 Ill. Adm.

Code 104.214(a); See also, 415 ILCS 5/37(a) (2010). Additionally, the Illinois EPA must

provide written notice of a petition to the County State’s Attorney, the Chairman ofthe County

Board, each member ofthe General Assembly from the legislative district affected, and any

person in the county who has in writing requested notice of variance petitions. 35 Ill. Adm. Code

104.2 14(b). Pursuant to these requirements, the Illinois EPA published notice of MWG’s

Petition in the Joliet Herald News on December 12, 2012; the Peoria Journal Star on December

11, 2012; the Waukegan News-Sun on December 12, 2012; and the Lav~dale News/Westside

Times on December 13, 2012. Consistent with Section 104.214(b), the Illinois EPA mailed

notice of the Petition on December 11, 2012.

3. Section 104.214(f) of the Board’s procedural rules provides, “Within 21 days

after the publication of notice, the Agency must file with the Board a certification of publication

that states the date on which the notice was published and must attach a copy ofthe published

notice.” 35 Ill. Adm. Code 104.214(f). In accordance with this requirement, the Illinois EPA

filed a Certification ofPublication with the Board on December 13, 2012.

2
4. To date, the Illinois EPA has received one written comment regarding the

Petition. William Uhirnan submitted a comment dated December 13, 2012, on behalf of Uhlman

Farms in Morton, IL. A copy ofthe comment is attached as Exhibit A.

5. Unless otherwise ordered by the hearing officer or Board, the Illinois EPA is

required to make a recommendation to the Board on the disposition of a petition for variance

within forty-five (45) days of the filing ofthe petition or any amendment thereto, or at least thirty

(30) days before a scheduled hearing, whichever is earlier. 35 Ill. Adm. Code 104.2 16. On

December 17, 2012, the Illinois EPA agreed to file its recommendation by January 10, 2013.

II. BACKGROUND REGARDING AFFECTED FACILITIES

6. MWG explains in its Petition that as of 2013, it “will or legally could generate

electricity from coal-fired units at five electric generating stations in Illinois, all subject to the

CPS,” namely Crawford, Joliet, Powerton, Waukegan, and Will County. Petition at 11 ,footnote

omitted. The Illinois EPA accepts and incorporates by reference MWG’s description of its

facilities in Section II of its Petition. Petition at 11-15.

7. MWG states that the Board’s Waukegan Order required that MWG shut down the

coal-fired electric-generating unit (“EGU”) at Fisk by the end of 2012, and that Fisk is therefore

not affected by the requested variance. Petition at 11, footnote 5. The Waukegan Order also

required that Petitioner shut down the coal-fired units at Crawford by December 31, 2014.

Petition at 12. Petitioner asserts that, while it ceased operation of such units by the end of

August 2012, it maintains the permits issued to Crawford and could therefore “legally generate

electricity from these coal-fired units through the end of 2014.” Petition at 12.

8. MWG indicates that it intends to comply with the CPS SO2 rate standards, and

with requirements regarding the installation of flue gas desulfurization (“FGD”) equipment on

3
designated units, through the use ofultra-low sulfur coal and dry sorbent injection of Trona.

Petition at 15. MWG explains that it controls particulate matter (“PM”) emissions from its coalfired boilers via electrostatic precipitators (“ESPs”), a number ofwhich must be upgraded or

supplemented by other PM control measures, as injection of Trona increases the particulate

loading to ESPs. Petition at 15-16

9. To the best ofthe Illinois EPA’s knowledge, there are no state enforcement

actions against MWG cuffently pending before the Board.

10. Other pending permits associated with Petitioner’s facilities are set forth in detail

in Exhibit 2 to the Petition, incorporated by reference into the Agency’s Recommendation.

III. RELIEF REOUESTED

11. Petitioner requests relief from the following provisions ofthe CPS:

Section 225.295 Combined Pollutant Standard: Emissions Standards

for NOx and SO2

b) Emissions Standards for SO2. Beginning in calendar year 2013 and

continuing in each calendar year thereafter, the CPS group must comply

with the applicable CPS group average annual SO2 emissions rate listed as

follows:

Year lbs/mmBtu

2015 0.28

2016 0.195

Section 225.296 Combined Pollutant Standard: Control Technology

Requirements for NOx, SO2, and PM Emissions

a) Control Technology Requirements for NOx and SO2.

4
2) On or before December 31, 2014, the owner or operator must

either permanently shut down or install and have operational FGD

equipment on Waukegan 8;

35 Ill. Adm. Code 225.295(b) and 225.296(a)(2).

12. Consistent with the reliefrequested above, MWG also requests a variance from,

or adjustments to, Condition 1(a) ofthe Board’s Waukegan Order, which provides:

The Board grants Midwest Generation, LLC — Waukegan Generation Station

(Midwest Generation) a variance for Waukegan Unit 7. . . from the requirements of

Section 225.296(a)(l) and (c)(1) subject to the following conditions:

1. During the period of the variance, Midwest Generation must:

(a) comply with the system-wide SO2 emissions rate set forth in Section

225.295(b),

Waukegan Order at 20.

13. In conjunction with these requests, MWG proposes to comply with a system-wide

SO2 annual emission rate of 0.38 ib/niniBtu in 2015 and 2016. Petition at 22. MWG also

commits to: 1) achieving a mass SO2 emission level no greater than 39,000 tons per year in 2015,

and no greater than 37,000 tons per year in 2016; 2) emitting no more than 57,000 tons of SO2 in

2013 and no more than 54,000 tons of SO2 in 2014; and 3) not operating the Crawford coal-fired

units in 2013 and 2014, the two years prior to the date of shutdown required by the Waukegan

Order. Petition at 22. MWG will then comply with the SO2 annual emission rate of 0.15

lb/mmBtu in 2017, as required by the CPS. Petition at 23.

14. Finally, MWG proposes a five-month delay of the requirement to either complete

installation of FGD equipment on Waukegan Unit 8 or shut down the unit by December 31,

2014. MWG “commits to not operate Waukegan Unit 8 after December 31, 2014, until

installation ofthe FGD equipment is complete.” Petition at 23.

5
IV. FACTS PRESENTED IN THE PETITION

15. Pursuant to 35 Ill. Adm. Code 104.216(a), the Illinois EPA conducted an

investigation ofthe facts alleged in MWG’s Petition, which included discussions with

representatives of MWG. To the extent ofthe information currently available to the Illinois EPA

and its level of expertise, the Illinois EPA does not disagree with the facts set forth in MWG’s

Petition, except as otherwise specified in this Recommendation.

16. As discussed supra, the Illinois EPA has received one public comment regarding

the Petition.

V. ENVIRONMENTAL IMPACT

17. Section 104.2 16(b)(2) ofthe Board’s rules requires that the Illinois EPA state the

location ofthe nearest air monitoring station maintained by the Agency, where applicable. 35 Ill.

Adm. Code 104.2 16(b)(2). The Illinois EPA confirms the locations of the air monitoring stations

relative to MWG’s facilities as set forth in Exhibit 1 ofthe Petition, as of 2010; however, in

2011, several monitors and/or sites included in Exhibit 1 were shut down. Specifically, in Lake

County, the ozone monitor and site in Waukegan and the PM2.5 monitor in Zion were

discontinued. In Will County, the SO2 monitor and site in Joliet and the PM,0 monitor in Joliet

were discontinued. Affidavit of Ernest Kierbach, attached as Exhibit B. The 2011 Illinois

AnnualAir Quality Report (“2011 Report”) reflects the current locations ofthe air monitoring

stations in Lake, Will, and Tazewell Counties. Affidavit ofErnest Kierbach. The Illinois EPA

attaches pertinent portions ofthe 2011 Report as Exhibit C.’

18. Petitioner states that the additional compliance commitments it proposes in

connection with its requested relief, as described above, will ensure a net environmental benefit;

1 The 2011 Report was most likely not available to Petitioner at the time the Petition for Variance was filed; it was

posted on the Illinois EPA’s website on or about November 30, 2012.

6
such commitments will ensure that total SO2 tons of emissions are less than projected under the

CPS. Petition at 2, 8-10.

19. Under MWG’s proposed mass emission limits for 2013-2016, total actual tons of

SO2 emissions from units permitted to operate during that period would be “less than expected

based upon historical average 2008-2011 heat input and the CPS rates.” Petition at 44. Meeting

such mass emission limits will provide a cumulative net reduction of 3,181 tons of SO2 over the

four-year tenm Petition at 44.

20. Additionally, MWG explains that the early shutdown of Crawford in August 2012

reduced SO2 emissions by approximately 1,249 tons in that year. Petition at 45. MWG proposes

“to commit to no further operation ofthe coal-fired units at Crawford.” Petition at 45.

21. MWG estimates that its proposed SO2 emission commitments will reduce other

pollutants as well, including nitrogen oxides (“NO~”) by approximately 8,503 tons; PM by 3,169

tons; mercury by 135 pounds; and carbon dioxide (“C02”) by 16 million tons. The early

shutdown at Crawford also resulted in reductions of these pollutants in 2012. Petition at 45.

22. MWG explains that the five-month delay in either installing FGD equipment on

Waukegan Unit 8 or shutting down the unit will have no adverse impact on emissions, as MWG

commits that it will not operate the unit during the deferral period. Petition at 45.

23. Petitioner indicates that system-wide reductions of mercury will not be negatively

impacted by the requested variance, and PM emissions will not increase; MWG will continue to

operate its activated carbon injection systems to control mercury emissions, and will continue to

operate its ESPs to control PM. Petition at 47-49.

24. The Illinois EPA notes that the calculated net environmental benefit is smaller

than that calculated for previous variances granted to Ameren Energy Resources on September

7
20, 2012, and to Midwest Generation, LLC on August 23, 2012. See Board Order inAmeren

Energy Resources v. Illinois Environmental Protection Agency, PCB 12-126 (Sept. 20, 2012)

(“Ameren Order”); Waukegan Order. These previously granted variances provided for a net

environmental benefit of 64,964 and 8,385 tons of SO2 reductions, respectively, whereas MWG

is proposing 3,181 tons of SO2 reduction in this variance request. Ameren Order at 25; Midwest

Generation, LLC — Waukegan Generating Station v. Illinois Environmental Protection Agency,

PCB 12-121, Petition for Variance at 21. As this is MWG’s second variance request in the same

year, it would be preferable that a stronger case be made to again amend a voluntary agreement

and expend the considerable resources required by numerous parties to review the merits ofthe

variance request.

25. However, the amounts of creditable SO2 emission reductions set forth by MWG

above are consistent with the data currently available to, and reviewed by, the Illinois EPA

during the course of its investigation of MWG’s Petition. In particular, the emission reduction

credits available as a result of MWG ‘ s proposed mass emission limitations are quantifiable and

creditable. Furthermore, the determination by MWG showing a net environmental benefit in

502 emissions over the term ofthe variance is consistent with the method utilized in similar

previous variance requests.

VI. ARBITRARY AND UNREASONABLE HARDSHIP

26. In considering whether to grant or deny a variance pursuant to Section 35(a) of

the Act, the Board is required to determine whether the Petitioner has shown that it would suffer

an arbitrary or unreasonable hardship ifrequired to comply with the regulation or permit

requirement at issue. 415 ILCS 5/35(a) (2010). The Board’s rules require that Illinois EPA

estimate the cost that compliance would impose on the petitioner and on others, as well as the

8
injury that the grant of the variance would impose on the public. 35 Ill. Adrn. Code

104.21 6(b)(5).

27. MWG claims, “The need for this variance arises from a combination of

circumstances that were not foreseen, and could not have been expected to be foreseen, when the

CPS was adopted in 2007.” Petition at 29.

28. First, MWG states that “the deregulated status of power generators in Illinois and

the uneven playing field created by the imposition of stringent Illinois requirements coupled with

the deferral of comparable federal requirements that would have helped to level the competitive

playing field” contribute to an arbitrary and unreasonable hardship. Petition at 29.

29. MWG indicates that Illinois has a deregulated energy market, placing Illinois

facilities at a competitive disadvantage with facilities located in regulated states, where

generators are allowed to recover the costs of capital projects from a consumer base through

rates. Petition at 31. Illinois electricity generators, on the other hand, are “entirely dependent on

wholesale prices in the competitive power price market for their revenue stream.” Petition at 31.

30. Further, Petitioner claims that certain Illinois emission reduction requirements,

including those set forth in the Illinois Clean Air Interstate Rule (“CAIR”) and Illinois Mercury

Rule, are significantly more stringent than those in other states, and that federal rules that would

have required MWG’s competitors to incur costs similar to those undertaken by MWG have been

remanded or vacated. Petition at 4-5, 29-3 0. For example, “the mercury reduction requirements

ofthe CPS continued to apply after vacatur of the [federal Clean Air Mercury Rule], and the

NON, SO2, and PM reduction requirements ofthe CPS . . . , not necessary for compliance with

current [National Ambient Air Quality Standards] or other federal requirements, continue to

apply in Illinois.” Petition at 30,footnote omitted.

9
31. MWG cites “substantial uncertainty regarding future regulatory requirements that

apply to all coal-fired power generators.” Petition at 32. Petitioner states that the federal CAIR

“remains the operative transport rule controlling NO~ and SO2,” despite the D.C. Circuit Court’s

holding that such program is “fatally flawed.” Petition at 32. The program intended to replace

the CAIR, the Cross State Air Pollution Rule (“CSAPR”), has been vacated, and it is uncertain

whether the CSAPR will be reinstated or whether the United States Enviromnental Protection

Agency (“USEPA”) will promulgate a “second successor to the CAIR.” Petition at 32-3 3.

MWG argues that “many of [its] competitors that are not subject to the [CPS] can await certainty

before making some of the capital decisions and expenditures that Midwest Generation has

already begun to make.” Petition at 33. MWG goes to state that “the regulatory ambiguity

irtherent in knowing that the current program, i.e., the CAIR, is legally insufficient and not

knowing what will replace it creates significant uncertainty for funding pollution control work.”

Petition at 33.

32. Similarly, MWG explains that the Mercury and Air Toxics Standards (“MATS”),

which requires reductions of emissions of mercury, hazardous metals, and hydrogen chloride

from coal-and oil-fired EGUs, has been appealed. MWG argues, “The uncertainties inherent in

an appeal, including what changes in the relevant requirements might arise as a result ofthe

appeal, make planning more difficult. . . and suggest the need for control plan flexibility.”

Petition at 34-3 5.

33. Second, MWG states that its current financial condition necessitates the granting

of the variance. Petition at 36.

34. Petitioner explains that, to date, it has spent more than $170 million in capital

costs for CPS compliance, and that it incurs significant operating costs on an ongoing basis.

10
Petition at 36. MWG plans to spend approximately $230 million in 2013 and 2014, “including

for planned controls at Powerton Unit 6 and Waukegan Unit 7 to comply with the CPS 2013 and

2014 SO2 emission rates and the Waukegan Unit 7 control equipment requirements.” Petition at

5-6, 26, 36.

35. MWG estimates that an additional $210 million in capital expenditures in 2013

and 2014 is necessary to comply with the 2015 and 2016 CPS system-wide SO2 emission rates

and to install FGD equipment on Waukegan Unit 8. Petition at 37.

36. Petitioner explains that it is facing significant financial challenges, due in part to

steep reductions in the price of natural gas and the resulting lower energy prices. Petition at 37.

Additionally, MWG reports lower “capacity prices and revenues,” estimating an 85% decline in

capacity revenues in 2013, compared to 2010 and 2011 revenues. Petition at 37-38. MWG

expects capacity revenues to increase, however, in 2014 and 2015. Petition at 38.

37. MWG explains that it has also experienced substantial increases in fuel costs,

with as-delivered fuel costs 60% higher in the first nine months of 2012 than during the same

period in 2008. Petition at 38. With lower revenues and increased costs, MWG experienced a

net loss of $63 million during the first three quarters of 2012. Petition at 38. Petitioner estimates

that operating losses and deficits are likely to continue through 2014. Petition at 38.

38. MWG explains that thus far, it has been largely dependent on its indirect parent

corporation, Edison Mission Energy (“EME”), to “fund its cash flow deficits and environmental

retrofits,” but that EME’s own financial challenges “throw into question its ability to provide

funding to [MWG] to install additional controls required to comply with the CPS system-wide

rates in 2015 and 2016.” Petition at 39. Both MWG and EME may need to file for protection

under Chapter 11 ofthe U.S. Bankruptcy Code and/or engage in financial restructuring. Petition

11
at 39-40. MWG requests time to “work through its financial constraints and operating revenue

issues” so that it can comply with the CPS and satisfy its other obligations as well. Petition at 40.

39. MWG states that it has been unable to identify other sources of funding for the

capital needed to install controls necessary to achieve the 2015 and 2016 CPS system-wide SO2

emission rates. Petition at 40. Edison International, EME’s parent company, has stated that it

will not invest new funds in MWG, and MWG does not believe that “EME [or MWG] has a

reasonable likelihood of securing financing for these additional control costs from an unrelated

third party in time to comply with the current CPS schedule.” Petition at 40-41.

40. MWG asserts that, ifthe requested variance is denied, Petitioner would be faced

with two possible compliance alternatives. Petition at 42. MWG could attempt to fund in 2013

and 2014 the additional $210 million in control costs necessary to comply with the portions of

the CPS at issue. MWG explains that funding “would be uncertain at best and such a large

additional expenditure could threaten Midwest Generation’s viability and that of its Stations.”

Petition at 42. Alternatively, MWG could be forced to significantly curtail generation from other

coal-fired units in MWG’s fleet that do not have Trona injection systems installed. Petition at 42.

These curtailments could substantially reduce MWG’s revenues, result in penalties under

MWG’s capacity contracts, or require regulatory approval to address grid reliability concerns.

Petition at 42.

41. MWG indicates that either ofthese two scenarios could adversely impact its

employees, the providers of goods and services purchased by MWG, and state tax revenues.

Petition at 43.

42. On the other hand, Petitioner asserts that the effect of granting the variance would be

to shift $210 million in control costs out of 2013 and 2014 and into 2015 and 2016, when

12
electricity capacity markets are expected to improve and certain federal regulatory requirements

will go into effect that will help “level the competitive playing field.” Petition at 6. Deferral of

these costs also provides MWG time to “conduct its financial restructuring and benefit from

market recovery.” Petition at 6.

43. The Illinois EPA does not disagree that certain Illinois emission reduction

requirements are more stringent than those required by other states or under federal rules, but

notes that MWG was aware of several of these requirements when the CPS was promulgated and

that such provisions in fact formed the backdrop for negotiations between the Illinois EPA and

power generators.

44. Based on the information currently available to it and its level of expertise, the

Illinois EPA is unable to estimate the cost of MWG’s compliance with the CPS provisions at

issue. The Illinois EPA does not believe that any injury to the public will result from the

granting ofthe variance. The Illinois EPA, however, notes the uncertainty associated with the

Chapter 11 bankruptcy proceedings entered into by MWG and EME in December 2012. See

Information Regarding Midwest Generation ‘s Filing Under Chapter 1] ofthe Federal

Bankruptcy Code, PCB 13-24 (January 8, 2013). Such proceeding may aid MWG’s compliance

with current regulations, but it could also potentially hinder MWG’s ability to comply both with

the CPS and with any Board Order issued regarding MWG’s requested variance.

VII. CONSISTENCY WITH FEDERAL LAW

45. Pursuant to Section 35 of the Act [415 ILCS 5/35 (2010)] and 35 Ill. Adm. Code

104.208(a), all petitions for variances must be consistent with federal law. MWG states that the

requested variance satisfies this requirement. Petition at 50.

46. Petitioner states that it complies with the federal CAIR, and that it will continue to

13
do so as long as the rule is applicable. Petition at 50.

47. MWG also addresses potential concerns regarding consistency with portions of

Illinois’ federally-approved State Implementation Plan (“SIP”). On June 24, 2011, the Agency

submitted portions ofthe CPS, including Sections 225.295(b) and 225.296(a)(2), to USEPA for

inclusion in Illinois’ SIP addressing Best Available Retrofit Technology (“BART”) and regional

haze. Petition at 50. On July 6, 2012, the USEPA approved Illinois’ submittal. Petition at 50.

48. MWG asserts that states are required to comply with the limit reflecting BART no

later than five years after SIP approval; compliance for Illinois is therefore due by mid-2017,

approximately six months after the end ofthe requested variance period. Petition at 50. MWG

argues that by that time, it will be complying with the 2017 system-wide SO2 limit set forth in

the CPS. Petition at 51.

49. MWG also explains that the Illinois EPA “demonstrated that the system-wide

average SO2 emission rates included in the CPS provide greater reductions than applying the

presumptive BART rate to only BART-eligible units by applying the rates to average heat

input,” an analysis accepted by the USEPA. Petition at 51. Therefore, the increase in emissions

due to a higher emissions rate of 0.38 lb/mmBtu “still leaves Illinois compliant with presumptive

BART levels.” Petition at 51.

50. The Illinois EPA agrees that there is currently no federal authority that precludes

granting the instant variance request, and that if granted, the Illinois EPA will submit the

variance order to USEPA for approval as a SIP revision.

VIII. COMPLIANCE PLAN

51. Pursuant to Section 104.204(f) ofthe Board’s rules, the Petitioner is required to

present a detailed compliance plan in the Petition for Variance. 35 Ill. Adm. Code 104.204(f).

14
52. MWG’s proposed compliance plan entails: 1) limiting system-wide emissions of

SO2 to no more than 57,000 tons in 2013; 54,000 tons in 2014; 39,000 tons in 2015; and 37,000

tons in 2016; 2) reporting to the Agency its system-wide mass SO2 emissions for 2013, 2014,

2015, and 2016 with each applicable Annual Emissions Report; 3) not operating the coal-fired

boilers at Crawford in 2013 and 2014; 4) not operating Waukegan Unit 8 from January 1, 2015,

until completion of installation ofFGD equipment; 5) completing installation and having

operational FGD equipment on Waukegan Unit 8, or permanently shutting down such unit, by

May 1, 2015; 5) complying with system-wide annual SO2 emission rate of 0.38 lb/mmBtu in

2015 and 2016; and 6) complying with the CAIR, Acid Rain Program, and all other applicable

requirements during the term ofthe variance.

IX. RECOMMENDATION AND CONCLUSION

53. Section 37(a) of the Act and Section 104.2 16(b)(1l) ofthe Board’s rules require

that Illinois EPA make a recommendation to the Board as to the disposition ofthe petition. 415

ILCS 5/37(a) (2010) and 35 Ill. Adm. Code 104.216(b)(1 1). The burden ofproof in a variance

proceeding is on the Petitioner to demonstrate that compliance with the rule or regulation would

impose an arbitrary or unreasonable hardship. See, 415 ILCS 5/35(a) (2010) and 35 Ill. Adm.

Code 104.238.

54. For the reasons set forth above, the Illinois EPA neither supports nor objects to

the Board granting MWG’s Petition as specified in this Recommendation.

15
DATED: January 10, 2013

1021 North Grand Avenue East

P. 0. Box 19276

Springfield, IL 62794-9276

217 782-5544

Respectfully submitted,

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By:~~. ~

Dana Vetterhoffer

Assistant Counsel
EXHIBIT A
Morton, Illinois

December 13, 2012

Dear Mr. Vetterhoffer,

We recently read your Pollution Variance notice in the Peoria Journal Star.

We are agricultural producers in Tazewell County not far from the Powerton

Generating Station. In recent years we have had to apply Sulfur fertilizer to

our land to maximize yields. We would favor relaxing the sulfur emissions

from the Powerton facility to save expenses for our fertilizer and it would

probably save some expense for the generating station.

We will appreciate your consideration.

Sincerely,

William Uhlman

Uhlman Farms

16 Meadowbrook Lane

Morton, Illinois 61568
EXHIBIT B
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MIDWEST GENERATION, LLC, )

)

Petitioner, )

) PCB 13-024

v. ) (Variance-Air)

) ILLINOIS ENVIRONMENTAL )

PROTECTION AGENCY, )

) Respondent. )

AFFIDAVIT

I, Ernest Kierbach, under oath, depose and state as follows:

1. I am the Manager of the Monitoring Section in the Bureau of Air at the Illinois

Environmental Protection Agency (“Illinois EPA”).

2. Several changes to the Illinois EPA’s air monitoring network occurred from 2010

to 2011, including the following. In Lake County, the ozone monitor and site in Waukegan and

the PM25 monitor in Zion were discontinued. In Will County, the SO2 monitor and site in Joliet

and the PM10 monitor in Joliet were discontinued.

3. The 2011 Illinois AnnualAir Quality Report accurately reflects the current

locations of the air monitoring stations in Lake, Will, and Tazewell Counties.

(~Z~

Ernest Ki rbach

SUBSCRIBED and SWORN to

before me this JO day

of January, 2013.

/2 =j—,~-yj)~J

F~&LSEA~

CYNTHIA L. WOLFE

NOTARY PUBLIC STATE OF ILLINOIS

MY COMMISSION EXPIRES 11-17-2015
EXHIBIT C
State of Illinois

Illinois Environmental Protection Agency

Annual Air Quality Report

a

Illinois

2011

~AL p~

C~)

-

~C)

3

November 2012
ILLINOIS ANNUAL

AIR QUALITY REPORT

2011

Illinois Environmental Protection Agency

Bureau ofAir

1021 North Grand Avenue, East

P.O. Box 19276

Springfield, IL 62794-9276

Printed on recycled paper
APPENDIX A

AIR SAMPLING NETWORK

DESCRIPTION OF THE AIR SAMPLING NETWORK

The Illinois air monitoring network is

composed of instrumentation owned and

operated by both the Illinois Environmental

Protection Agency and by cooperating local

agencies. This network has been designed to

measure ambient air quality levels in the

various Illinois Air Quality Control Regions

(AQCR). Historically, each AQCR was

classified on the basis of known air pollutant

concentrations or, where these were not

known, estimated air quality. A map of the

AQCR’s in Illinois and overlapping into

surrounding states can be found at the end of

this section.

Many local agencies and volunteers cooperate

and support the operation of the Illinois air

monitoring network. The network contains

both continuous and intermittent instruments.

The continuous instruments operate

throughout the year, while noncontinuous

instruments operate intermittently based on

the schedule shown in Table Al. This is the

official noncontinuous sampling schedule

used by the Illinois EPA during 2011.

The illinois network is deployed along the

lines described in the Illinois State

Implementation Plan. An updated air

monitoring plan is submitted to USEPA each

year for review. In accordance with USEPA

air quality monitoring requirements as set

forth in Title 40 of the Code of Federal

Regulations, Part 58 (40 CFR 58), five types

of monitoring stations are used to collect

ambient air data (SLAMS, NAMS, PAMS,

SPMS and NCORE). The types of stations

are distinguished from one another on the

basis of the general monitoring objectives

they are designed to meet.

The SLAMS, NAMS, PAMS, SPMS and

NCORE designations for the sites operated

within the State of illinois are provided in the

Annual Network Plan

(epa. state. il.us/air/monitoring/index.html).

All of the industrial sites are considered to be

SPMS. Table A2 is a summary of the

distribution of pollutants through the years

along with total number of instruments and

total number of sites. The Site Directory is

listed in Table A3 and the Monitoring

Directory is listed in Table A4.

State/Local Air Monitoring Station (SLAMS) Network - The SLAMS network is

designed to meet a minimum of four basis monitoring objectives:

a. To determine the highest concentrations expected to occur in the area covered by

the network.

b. To determine representative concentrations in areas of high population density.

c. To determine the air quality impact of significant sources or source categories.

d. To determine general background concentration levels.

2. National Air Monitoring Station (NAMS) Network - The NAMS network is a subset of

stations selected from the SLAMS network with emphasis given to urban and multisource

areas. The primary objectives of the NAMS network are:

a. To measure expected maximum concentrations.

29
JANUARY

Table Al

2011 Noncontinuous Sampling Schedule

FEBRUARY MARCH

S

Mt

10

17

24

S

3

10

17

24

31

M

4

11

18

25

M

4

11

18

25

T

5

12

19

26

T

5

12

19

!~I~

J ~PRI:

w

6

13

20

IN

FUL~

w

6

-~n

R

7

14

—28

13

IN

27

R

7

IN

21

28

F

8

.~•I

22

29

S

2

I16

23

30

F

1

IN

15

22

29

S

•1

9

16

23

30

OCTOBER

SM T W R F S

2.~.3:~45j~J78

~910 TI

16 17 II 19 20 21 22

23 25 26 27 28 29

Irw~T—~———

S

5

12

19

l~

S

4

11

•i

25

M

6

13

M

5

•i

19

26

T

7

T

I.

13

20

27

JUNE

lii

27

IN

21

28

w

I—

15

22

29

SEP FEM

w

7

R

I.

9

16

23

30

14

21

28

F

3

10

17

24

S

4

11

18

25

3ER

R

8

15

22

29

F

2

9

16

23

IN

S

3

10

17

—a,,

~

DECEMBER

SM T W R F S

1 23

4 ~ 6 7 ~•S••~•..~ 9 10

II~ 12 13 14~ 15 16 lIt

18 ~ 20 21 22 24

25 26 27 28 II 30 31

Every 6 Day Sampling Schedule 22 Every 3 Day Sampling Schedule

SM T W R F S

2 ~ 4 5 6 7 8

~io 1T

~

16 1718 W20~22

30 31

SM T W R F S

1 ~ 3 4 ~

~ 7~JjJ~

1315 16 17 18 19

27 28

L~ ~

~T~:-~

67T~ ~i1~*

S

VIAY

M T w

2

R

IN

8

F

4

•g..~.

S

5

10

III

6 :

11

16

7

12

17

22

13

18

23

14

19

24

29

20

25

30

p

26

31

—~ 28

AJGU:T

S M T w

•1

R

2

II!

F

3

8

S

4

9

14

5

10

15

6

11

16

21

12

17

22

I..,~...,,

18

23

28

IN

24

29

20

lii,

30

26

•i•~•

27

NOVEMBER

S M TIW R F S

TIT~II -~- -~- -~-I_~_ ~~Li ~ 13 i4~ 15116 ~ 18 19

20 21 22)1124 25 26

27 28 I!t[ 30

30
b. To measure concentrations in areas where poor air quality is combined with high

population exposure.

c. To provide data useable for the determination of national trends.

d. To provide data necessary to allow the development of nationwide control strategies.

3. Photochemical Assessment Monitoring Station (PAMS) Network - The PAMS network

is required in serious, severe, and extreme ozone non-attainment areas to obtain detailed data

for ozone, precursors (NOx and VOC), and meteorology. VOC and NOx sampling is

required for the period June - August each year. Ozone sampling occurs during the ozone

season, April - October. Network design is based on four monitoring types. In Illinois

PAMS are required in the Chicago metropolitan area only.

a. Type 1 sites are located upwind of the non-attainment area and are located to measure

background levels of ozone and precursors coming into the area

b. Type 2 sites are located slightly downwind of the major source areas of ozone

precursors.

c. Type 3 sites are located at the area of maximum ozone concentrations.

d. Type 4 sites are located at the domain edge of the non-attainment area and measure

ozone and precursors leaving the area.

4. Special Purpose Monitoring Station (SPMS) Network - Any monitoring site that is not a

designated SLAMS or NAMS is considered a special purpose monitoring station. Some of

the SPMS network objectives are as follows:

a. To provide data as a supplement to stations used in developing local control strategies,

including enforcement actions.

b. To verify the maintenance of ambient standards in areas not covered by the

SLAMS/NAMS network.

c. To provide data on noncriteria pollutants.

5. National Core Station (NCore) Network - NCore is a multi pollutant network that

integrates several advanced measurement systems. It is anticipated that each state operate at

least one NCore site by 2011. In Illinois, Northbrook and Bondville will be considered

NCore sites. A few of the NCore network objectives are as follows:

a. Support for development of emission strategies and accountability of emission strategy

progress through tracking long-term trends of pollutants and their precursors.

b. Support of long-term health assessments that contribute to review of National

Standards.

c. Support to scientific studies ranging across technological, health and atmospheric

process disciplines.

d. Support to ecosystem assessments recognizing that national air quality networks benefit

ecosystems assessments.

31
Table A2

There were a number of changes to the

monitoring network from 2010 to 2011. Five

non-source oriented TSP/Lead monitors were

discontinued. The discontinued monitors

were: Alsip, Summit, Wood River, Peoria and

East St. Louis. A special purpose source

oriented TSP/Lead monitor was temporarily

installed at the Juarez school in Chicago.

Five PM25 monitors were discontinued or site

access was lost: Champaign, Chicago

Southeast Police Station, Zion, Oglesby and

Swansea. A replacement PM2.5 site in

Champaign was established. Twelve PM10

monitors were discontinued: Alsip, Chicago

Carver High School, Midlothian, Blue Island,

Summit, Oglesby, Nilwood, Wood River,

Peoria, East St. Louis, Joliet and Carbondale.

Four sulfur dioxide monitors were

discontinued: Chicago Southeast Police

Station, Chicago CTA, Joliet and Indiana

discontinued the Rural Wabash County

monitor. Two ozone monitors were

discontinued: Chicago Willis Tower and

Waukegan. A replacement ozone site was

established in Thomasboro for site access lost

in Champaign. An additional replacement

ozone site was established at the Springfield

Illinois Building in the State Fairgrounds for

access lost at the Springfield Blandco site.

Distribution ofAir Monitoring Instruments

2011 2010 2009 2008 2007

Pariculate Matter (PM2.5) 34 38 38 38 38

PM2,5 Air Quality Index 12 13 13 13 13

PM2,5 Speciation 5 5 5 5 6

Particulate Matter(PM10) 5 17 17 17 17

Total Suspended Particulates (TSP) 13 18 13 13 13

Lead 13 18 13 13 13

Continuous Mercury 1 1 1 1 1

Sulfur Dioxide 15 19 19 20 20

Nitrogen Dioxide 7 7 7 7 8

Ozone 34 36 36 36 37

Carbon Dioxide 1 1 1 1 1

Carbon Monoxide 9 9 9 9 9

Volatile Organice Compounds/Toxics 2 2 2 2 4

Wind Systems 17 18 18 18 19

Solar Radiation 2 9 9 9 9

Meteorology 3 3 3 4 4

Total Instruments 173 214 204 206 212

Total Sites 75 84 77 77 79

32
65 — Buliiigton—Keokuk Interstate (Iowa-Illinois)

66 — East Central Illinois Intrastate

6? — Metropolitan Chicago interstate (illinois—Indiana)

66 — Metropolitan Dubuque Interstate (lowa—Illinos--)Eisconsin)

69 — Metropolitan Quad Ci1i~ Interstate (illinois—Iowa)

70 — Metropolitan SL Louis Interstate (illinois—Missouri)

71 — North Central Illinois Intrastate

72 — Paducah—Cairo interstate (Kentucky—lllinos)

73 — Rockford—Janesviile—Beloil Interstate (Iilinois4isconsin)

74 — Southeast Illinois Intrastate

75 — l~’est Central Illinois Intrastate

AIR QUALITY CONTROL REGIONS

33
Qonooiy John Wood Cornooomioy C0110go 64222744 4419695,50 170010007

2 000mpni80 394297,72 444224468 7090006

3 Thomodoso 398939.77 4455622.22 170190007

4 lh.ndo’ilk SWSClnoolo Nolkon 382927.63 4434458.00 17019100

5 AloipVoIlo~oGoro6o 439028.14 4633506,98 170310001

6 Cl 80W ohmgl 119 45511670 461518398 1700100

10 000040 Spoiogfiold Poop 9603300 440063.88 464(3354.22 170310057

II E3oioops 1.~EA 8AJoog 447307.8 I 4606384.48 170310063

12 Chic60o UoivmooyofCloOo9o 450011.00 4626726.33 170310064

(3 Chico~o lo64000 Woloo P901 440590.78 4638386.72 17031(1072

4 Choo60oComm ED 440680.96 4622421.39 (703(0075

IS PorooElomoolnoy Sohool 44534800 4633988.90 170010110

6 Chioo4o ToO 11.0 43439000 4648367.48 370311003

7 Lyooo Tooooohip ‘Ollogo (loll 433(877.97 4628006.70 170311016

38 I.om003 EPA Tooiloo , 47538:46 46(3403.03 170311601

19 lOlon (shod Eimohoono 11.0 4420(5.58 46(2496.03 170312001

20 Sohillor Pork (EPA T~ilor 427390.48 4646283.31 170313103

I Essom 19 Elm oo~ Solo I 43313491 46 600 30 170113301

22 ‘ Cmoro (EPA Troilor 437539.20 4633977.22 170314002

23 Dos Plo’mon Roghool OIlioo 8416mg 428543.56 4656797.86 170314007

24 ‘ Nonhlnook WolorPlool 433953.24 4665668.78 170314201

25 Moy000d 500 MovJoook Dr’oo PIollorm 43(442.48 46359(7.35 170316003

26 MoyoroodCommEDMoiolonoooo 43119907 46359(0.07 170316004

27 Cionro LilmOy 609001 437852.27 4634984.05 170316005

28 Moyoood 41101030400 Cooor BoAldiog 43(466.96 4635994.08 170316000,

29 Eomm100 W010r Posmpmg A 000 4442298. 465685788 (703(7002

30 Noporodlo Co~ (loll 46426907 46 500766 70434002

SI Loil M0000 Arhnrrroro 41689026 462958292 170436001

32 EffmghnmCrnrrsllomoor lIE 36600019 432536906 170491001

53 Emoglm Prsom Tonroshop 35748972 421617700 170650002

14 lormyodlollhroolosooorllE 73(34900 4 ,2451 50 170831001

33 11gm 8900060> 630001 39407474 465616453 170890003

16 01gm (moon Jo000 lIE 394651 06 465601729 170890605

Aonom 110 lIE Dopmrmool 589528 (4 4626729 (6 170890007

ZmoCompl.ogoro 4140866 476201337 170971007

39 Oglorlro IEPA’Ermloo 32840131 457391160 170990007

40 Cooo 1.60001(0 39748049 407511016 171110001

43 001orooll911PloysooolPl0000 33083753 4487’5050 171132003

42 Em Ion IEPA Trmhr 3351(994 441476900 171150013

41 IlmolooMonllor 33198800 441430300 171150110

44 Nohoood ICPA Tosolor 238043 88 416449850 171170002

45 Alloo Cloro 800000 Elom000no> 500001 74735896 430845860 171190008

46 hnomlo Coos Ao Poodonls 74752288 4286713 50 171190010

47 &omlo Coo> Dolomo> Modoool 74836044 42874’6 50 171190024

48 hnomloCol> PiroA 10001 74872763 4’87873 00 171191067

49 Morvo 0110 5005100001 OsNo TV 242682.59 429059500 171191009

50 >oohlOoxmoslII 11500003 75535388 430(83650 171191010

SI EoloooodmollollAPSTroolor 75710144 429800700 171192007

52 Al1000AUD000 ICImo 74779494 430990000 171192009

53 Wood llooor Wolor Troolm000 P906 75112° 3 4 0529500 171191007

54 P00001090903,008 27970738 450732950 1714300’4

P0000 Co000000oool Sooldoog 279.03 50 450874850 171410016

56 Poon.r Coo> OlOoo DoMong 281616 ‘2 450831650 171430017

57 Borlom0110Posmp&sonvn 2765(560 456167400 171430110

98 Mopli100 Clboopolloo P14,01 26742900 44938400 171416210

50 Poono IloogloorIlO. 28(679 94 451372350 171431601

60 Iloom000 Iloldom POn 2 (CIA Trodor ‘55745.52 422904950 171570001

61 RooklnlondArsonol 70716975 459888660 171613002

62 EomA too llAl0STrooIor 74723869 4277551 00 171630010

63 E~snog0okI 6000080 T500lm003 P9001 27815803 460884050 171670006

64 ~onng6oD Fo&mI DoMong 2733(2.59 4408832 50 171670008

65 ~onogOo9 Ilh000o Ago000dboor Bmldoog 27372800 441244900 17167001’

66 S8onopfiokllfloooooBoldoop 27400378 441239553 171670014

67 Pokon Coo Aoloon 3 27527413 449289260 171790004

68 Moosol Connol Do loon 50001 432441 06 4250(7709 171850001

69 Aorlmg 9001. ModooolChoo 27508400 462982200 171950110

70 lolool P osloogE80000lml 601,001 40085446 459785320 171971002

71 IoroslovodCommEDMomloosoooo 400(7337 456403385 171971011

72 flookfordColyll 0 32781172 468160650 172910011

71 160 kford Wmnn90go Coo.oly 1104119 Dopor000000 327392 16 468310760 172910013

74 Rookfordl RoOrso orod Compony 32744000 467863766 172016110

24

29 29

L_i~169~ ‘3

2528 ~ II’~.

~26~22~~

co~72I 14

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Statewide Air Monitoring Site Locations

U) NAME 0000181) 00001(10 AQSCOI)E

7 Cloioogoo C000000 Poop Aolioo 446450.82 4635950,70 170310026

8 Chimgo 00,510 SEnIor FilI051ion 101001 45470237 4622802,04 170310632

9 Clo oogoM >1 loop >6 so 4378593 4646 1644 17011005

37

38

C 38 ‘.9 7

“\ 1010009000 STEPIIL\ 71 i

~ ‘EoAoo~~74 300o’lo6 ‘olCllE’,011 1.4410 1

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03101030001. 093.0 1 ~ I StOoP ~DUPAGE~

I 6’........-........DEKALDI .9 3 7 ~7 965 00009.9 ~‘ W11133961DE) LEE O......J...~J.L, J ‘~

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1489809 ~ ~ ~ 98900

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HAOCDGK IIICD0N0EG1~ 000250 2520991000 ~89l.0E0o 00 ‘9 I L~.._L_ _~ 3 1 MASON 1

S1III7VLER /0(”.~ ~Jo_,_._o06j ~ DEWITT / 2 10~ER,0lILI0N

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15100o697n’t3”°° CASh MCN~rJ0Di r PlANT IIOAMPSIGP0 I AESMS L..,..0~ 0.....~.J j_._f—’——i ~ 0L4C00~ 42

~~io~ (°“1 fOTT°73901ROAN 180960001~~3 \ s41’—~~I 1”—~] OLLT80”~” DOUOl~89 EDGAR

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ST C~R ~...~....—$

/ p”' VoAYOE 10~oBAS1I90 11 ‘~9... 07669619070W EI36100~P.I)N I,

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R.OoNDOLPII P1’RR’r° ,I 8~NOLTO55 W311T17 611

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619101310

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75 Lonos Pork Moplo Domo000ooy Sohool 332121.41 4688981.00 172012003

34
Table A3

2011 Site Directory

AQS ID County City Address MSA I Area Latitude Owner! Represented Longitude Operator

17-001-0007 Adams Quincy John Wood Comm. College IL EPA 1301 South 48th St. Quincy, IL-MO +39.91540937 -91.33586832

17-019-1001 Champaign Bondville State Water Survey Champaign- +40.05224171 Township Rd. 500 E. Urbana, IL -88.37254916 IL EPAISWS

17-019-0006 Champaign Champaign Ameren Substation Champaign- +40.1237962 904 N. Walnut Urbana, IL -88.229531 IL EPA

17-019-0007 Champaign Thomasboro North Thomas St. Champaign- +40.244953 IL EPA Urbana, IL -88.1881 76

Chicago17-031-0001 Cook Asp Village Garage Naperville- +41.6709919 4500W. 123rd St. Michigan City, IL- -87.7324569 CCDEC

IN-WI

Chicago17-031-2001 Cook Blue Island Eisenhower High School Naperville- +41.66210943 12700 Sacramento Michigan City, IL- -87.69646652 CCDEC

IN-WI

Chicago17-031-0026 Cook Chicago Cermak Pump Station Naperville- +41.87372041 735 W. Harrison Michigan City, IL- -87.64532569 CCDEC

IN-WI

Chicago17-031-0076 Cook Chicago Com Ed Maintenance Bldg. Naperville- +41.75139998 7801 Lawndale Michigan City, IL- -87.71348815 CCDEC

IN-WI

Chicago17-031 -0063 Cook Chicago CTA Building Naperville- +41.877628 320 S. Franklin Michigan City, IL- -87.635027 IL EPA

IN-WI

Chicago17-031-0072 Cook Chicago Jardine Water Plant Naperville- +41.89581227 1000 E. Ohio Michigan City, IL- -87.60768329 IL EPA

IN-WI

Chicago17-031-0052 Cook Chicago Mayfair Pump Station Naperville- +41.96548483 4850 Wilson Ave. Michigan City, IL- -87.74992806 CCDEC

IN-WI

17-031-0110 Cook Chicago Perez Elementar~’ School H.G. Kramer +41.855917 CCDEC 1241 19th St. -87.658419

Chicago17-031-0032 Cook Chicago South Water Filtration Plant Naperville- +41.75583241 3300 E. Cheltenham P1. Michigan City, IL- -87.54534967 CCDEC

IN-WI

Chicago17-031-0057 Cook Chicago Springfield Pump Station Naperville- +41.91286212 1745 N. Springfield Ave. Michigan City, IL- -87.72272345 CCDEC

IN-WI

Chicago17-031 -1 003 Cook Chicago Taft High School Naperville- +41.98433233 6545 W. Hurlbut St Michigan City, IL- -87.7920017 CCDEC

IN-WI

Chicago17-031-0064 Cook Chicago University of Chicago Naperville- +41.79078688 5720 S. Ellis Ave. Michigan City, IL- -87.601 64649 CCDEC

IN-WI

Chicago17-031-0022 Cook Chicago Washington High School Naperville- +41 .6871 6544 3535 E. 114th St. Michigan City, IL- -87.53931548 CCDEC

IN-WI

Chicago

17-031-4002 Cook Cicero Cook County Trailer Naperville- +41.85524313 1820S. 51st Ave Michigan City, IL- -87.7524697 CCDEC

IN-WI

35
Table A3

2011 Site Directory

MSA I Area Latitude Owner I AQS ID County City Address Represented Longitude Operator

ChicagoLiberty School Naperville- +41.86442642 17-031-6005 Cook Cicero CCDEC 13th St. & 50th Ave. Michigan City, IL- -87.74890238

IN-WI

ChicagoRegional Office Building Naperville- +42.06028469 17-031-4007 Cook Des Plaines IL EPA 9511 W. Harrison St Michigan City, IL- -87.86322543

IN-WI

ChicagoWater Pumping Station Naperville- +42.06185724 IL EPA 17-031-7002 Cook Evanston 531 E. Lincoln Michigan City, IL- -87.67416716

IN-WI

ChicagoCook County Trailer Naperville- +41.66812034 17-031 -1 601 Cook Lemont 729 Houston Michigan City, IL- -87.99056969 CCDEC

IN-WI

ChicagoLyons Village Hall Naperville- +41.80116701 IL EPA 17-031-1016 Cook Township 50th St & Glencoe Michigan City, IL- -87.831 9447

IN-WI

Chicago4th District Court Building Naperville- +41 .872201 58 17-031-6003 Cook Maywood 1500 Maybrook Dr. Michigan City, IL- -87.8261648 CCDEC

IN-WI

Chicago4th District Court Building Naperville- +41.8728972 17-031-6006 Cook Maywood 1500 Maybrook Dr. Michigan City, IL- -87.82587249 CCDEC

IN-WI

Chicago

Com Ed Maintenance Naperville- +41.87211684 CCDEC 17-031-6004 Cook Maywood 1505S. First Ave Michigan City, IL- -87.82908025

IN-WI

Chicago

Northbrook Water Plant Naperville- +42.13999619 IL EPA 17-031-4201 Cook Northbrook 750 Dundee Rd. Michigan City, IL- -87.79922692

IN-WI

Chicago

EPA Trailer Naperville- +41.96519348 17-031-3103 Cook Schiller Park IL EPA 4743 Mannheim Rd. Michigan City, IL- -87.87626473

IN-WI

ChicagoGraves Elementary School Naperville- +41.78276601 17-031-3301 Cook Summit CCDEC 60th St. & 74th Ave. Michigan City, IL- -87.80537679

IN-WI

ChicagoMorton Arboretum Naperville- +41 .81 304939 17-043-6001 DuPage Lisle Route 53 Michigan City, IL- -88.0728269 IL EPA

IN-WI

Chicago17-043-4002 DuPage Naperville City Hall Naperville- +41 .771 07094 IL EPA 400 S. Eagle St. Michigan City, IL- -88.15253365

IN-WI

Central Junior High School +39.0671 5932 17-049-1 001 Effingham Effingham Route 45 South Effingham, IL -88.54893401 IL EPA

Ten Mile Creek DNR Office +38.08215516 17-065-0002 Hamilton Knight Prairie State Route 14 Mt. Vernon, IL -88.6249434 IL EPA

Illini Junior High School +39.11053947 17-083-1 001 Jerse~rviIIe Jerse~’viIle Liberty St. & County Rd. St. Louis, MO-IL -90.32407986 IL EPA

Chicago

Health Department Naperville- +41.78471651 17-089-0007 Kane Aurora IL EPA 1240 N. Highland Michigan City, IL- -88.32937361

IN-WI

36
Table A3

2011 Site Directory

MSA I Area Latitude Owner! AQS ID County City Address Represented Longitude Operator

ChicagoLarsen Junior High School Naperville- +42.0491 4776 17-089-0005 Kane Elgin 665 Dundee Rd. Michigan City, IL- -88.27302929 IL EPA

IN-WI

Chicago

McKinley School Naperville- +42.050403 17-089-0003 Kane Elgin 258 Lovell St. Michigan City, IL- -88.28001471 IL EPA

IN-WI

Chicago17-097-1 007 Lake Zion Camp Logan Naperville- +42.4675733 IL EPA Illinois Beach State Park Michigan City, IL- -87.81004705

IN-WI

Ottawa-Streator, +41.29301454 17-099-0007 La Salle Oglesby 308 Portland Ave. IL -89.04942498 IL EPA

IEPA Trailer +39.86683389 17-115-0013 Macon Decatur Decatur, IL IL EPA 2200 N. 22nd -88.92559445

Mueller +39.862542 17-115-0110 Macon Decatur Mueller IL EPA 1226 E. Garfield -88.940894

IEPA Trailer +39.39607533 17-117-0002 Macoupin Nilwood St. Louis, MO-IL IL EPA Heaton & Dubois -89.80973892

Clara Barton School +38.8901 8605 17-119-0008 Madison Alton St. Louis, MO-IL IL EPA 409 Main St. -90.14803114

SIU Dental Clinic +38.90308534 17-119-2009 Madison Alton St. Louis, MO-IL IL EPA 1700 Annex St. -90.14316803

Air Products +38.69443831 17-119-0010 Madison Granite City 15th & Madison St. Louis, MO-IL -90.15395426 IL EPA

Fire Station #1 +38.70453426 17-119-1007 Madison Granite City 23rd & Madison St. Louis, MO-IL -90.13967484 IL EPA

Gateway Medical Center St. Louis, MO-IL +38.7006315 IL EPA 17-119-0024 Madison Granite City 2100 Madison Ave. -90.14476267

Southwest Cable TV +38. 72657262 17-119-1009 Madison Maryville 200 W. Division St. Louis, MO-IL -89.95996251 IL EPA

South Roxana Grade School +38.82830334 17-119-1010 Madison South Roxana St. Louis, MO-IL IL EPA Michigan St. -90.05843262

Water Treatment Plant +38.86066947 17-119-3007 Madison Wood River St. Louis, MO-IL IL EPA 54 N. Walcott -90.10585111

Chicago

Cary Grove High School Naperville- +42.221441 66 17-111-0001 McHenr~’ Cars’ 1st St. & Three Oaks Rd. Michigan City, IL- -88.24220734 IL EPA

IN-WI

ISU Physical Plant Bloomington- +40.51873537 IL EPA 17-113-2003 McLean Normal Main & Gregory Normal, IL -88.99689571

Pump Station Keystone Steel & +40.653703 17-143-0110 Peoria Bartonville IL EPA Sanitation Rd. Wire -89.643375

Residential Caterpillar- +40.562633 IL EPA 17-143-0210 Peoria Mapleton 9725 W. Wheeler Rd. Mapleton Plant -89.747114

+40.697007 17-143-0037 Peoria Peoria City Office Building Peoria, IL IL EPA 613 N.E. Jefferson -89.58473722

Commercial Building Peoria, IL +40.70007197 IL EPA 17-143-0036 Peoria Peoria 1005 N. University -89.61341 375

Fire Station #8 +40.68742038 17-143-0024 Peoria Peoria Peoria, IL IL EPA MacArthur & Hurlburt -89.60694277

Peoria Heights High School Peoria, IL +40.74550393 IL EPA 17-143-1 001 Peoria Peoria Heights 508 E. Glen Ave. -89.58586902

IEPA Trailer +38.17627761 17-157-0001 Randolph Houston Houston, IL IL EPA Hickory Grove & Fallview -89.78845862

37
Table A3

2011 Site Directory

MSA I Area Latitude Owner! AQS ID County City Address Represented Longitude Operator

Davenport- Rock Rock Island Arsenal +41.51472697 17-161-3002 Rock Island Moline-Rock IL EPA Island 32 Rodman Ave. -90.51735026 Island, IA-IL

Agricultural Building +39.83192087 17-167-0012 Sangamon Springfield State Fair Grounds Springfield, IL -89.64416359 IL EPA

Illinois Building +39.831522 17-167-0014 Sangamon Springfield State Fair Grounds Springfield, IL -89.640926 IL EPA

Federal Building Springfield, IL +39.7993092 17-167-0008 Sangamon Springfield 6th St. & Monroe -89.64760789 IL EPA

+39.80061377 17-167-0006 Sangamon Springfield Sewage Treatment Plant Springfield, IL IL EPA 3300 Mechanicsburg Rd. -89.591 22532

RAPS Trailer +38.61203448 17-163-0010 St. Clair East St. Louis St. Louis, MO-IL IL EPA 13th & Tudor -90.16047663

Fire Station #3 +40.55646017 17-179-0004 Tazewell Pekin Peoria, IL IL EPA 272 Derby -89.65402807

Gibson County, +38.397276 17-185-0001 Wabash Mount Carmel Division St. Indiana IN-Mt. Carmel, IL -87.773631

Sauk Medical Clinic +41.788383 17-195-0110 Whiteside Sterling 705 West 3rd St. Sterling Steal Co. -89.706728 IL EPA

Chicago

Com Ed Training Center Naper-ville- +41.22153707 IL EPA 17-197-1011 Will Braidwood 36400 S. Essex Rd. Michigan City, IL- -88.19096718

IN-WI

ChicagoPershing Elementary School Naperville- +41.52688509 17-197-1002 Will Joliet IL EPA Midland & Campbell Sts. Michigan City, IL- -88.11647381

IN-WI

Maple Elementary School Rockford, IL +42.33498222 IL EPA 17-201-2001 Winnebago Loves Park 1405 Maple Ave. -89.0377748

+42.26767353 17-201-0011 Winnebago Rockford City Hall Rockford, IL IL EPA 425 E. State -89.08785092

Health Department +42.26308105 17-201-0013 Winnebago Rockford 201 Division St. Rockford, IL -89.09276716 IL EPA

J. Rubin & Company Gunite +42.240867 17-201-0110 Winnebago Rockford 305 Peoples Ave. Corporation -89.091 467 IL EPA

38
TableA4

2011 Monitoring Directory

AQS ID City

17-001-0007

c’4 C’) 0 0 0

C) C) z

Quincy

a)

0

N

0

0

C) a)

0.

U,

C”

0.

o

— c~

o_ o~

C”

0.

17-019-0004

17-019-0006

17-019-0007

Ca

0

Cl,

0

Ca

a)

.0

0~

0.

C/,

HE

0

>‘

U)

•0 c~ C)

0 0

U) >

0

Ci

1<

0

Iin

C-)

0)

0

0

0

a)

a)

H

17-019-1001 Bondville

17-031-0001 Alsip

1 7-031-0022 Chicago Washington High School

17-031-0026 Chicago

Cermak Pump Station

17-031-0032 Chicago South Water Filtration

17-031-0042

17-031-0050

17-031-0052 Chicago

Mayfair Pump Station

Chicago 17-031-0057 SpringfIeld Pump Station

17-031-0060

I

17-031-0063

17-031-0064

Chicago

cTA Building

Chicago

University of chicago

Chicago 17—031-0072 Jardine Water Plant —

Chicago 1 7-031-0076 com ~ Maintenance — —

I

17-031-0110 Chicago Perez Elementary

17-031-1003 Chicago Taft High School

17-031-1016 Lyons Township

17-031-1601

C = Continuous PM1O

T = Trace level monitor

39
Table A4

2011 Monitoring Directory

C

~.~ ~ 2 .2

AQSID City

< U) >‘ 0

~ 0 ~ ~- .~ 0 (‘4 (‘4 Q — (‘4 (‘1 (‘4 (‘4 C) ~ (5 5

0 0 0 N ~ Q Q

C) C) Z 0 Q~ Q. 0. 0~ U) > i- ~- U) ~

17-031-1901

17-031-2001 Blue Island

17-031-3103 Schiller Park

~-

17-031-3301 Summit

17-031-4002 Cicero cook County Trailer

17-031-6005 Cicero Liberty School

17-031-4007 Des Plaines

17031 4201 Northbrook1 T

1 7-031-6003 Maywood 4 District Court

1 7-031-6004 Maywood Corn Ed Maintenance

1 7-031-6006 Maywood 4 District Court

17031 7002 Evanston

17-043-4002 Naperville

1 7-043-600 1 Lisle

17-049-1001 Effingham

17-065-0002 Knight Prairie

----~ ----

1 7-077-0004

17-083-1001 Jerseyville

1 7-089-0003 Elgin Mckinley School

17-089-0005 21gm Larsen Jr. High School

17-089-0007

17-097-1002

C = Continuous PM1O

T = Trace level monitor

1 = Northbrook also measures NOy and black carbon

40
Table A4

2011 Monitoring Directory

AQS ID City

17-097-1007

C’) C’)

o 0 0 o e z

a)

t

0

N

0

0

C

0

a)

0

a)

0.

U)

B)

C’)

0~

Zion

C’)

a

B)

C’)

0~

C’)

0

U)

0

a)

a)

.0

0~

aU)

I0

0

>

S

a)

0

>‘

U)

C

0

0

><

0

a)

0

U)

a) C,

0

0

0

a)

a)

1 7-099-0007 Oglesby

17-111-0001 Cary

17-113-2003 Normal

17-1 15-0013 Decatur EPA Trailer

17-115-0110 Decatur Mueller

1 7-1 17-0002 Nilwood

17-119-0008

17-119-2009

Alton

Clara Barton Elementary

Alton

siu Dental Clinic

H

17- 119-00 10 Granite City

Air Products

L

Granite City 1 7-1 19-0024 Gateway Medical Center — — — —

Granite City 17-119-1007 Fire Station #1 — — —

17-119-1 009 Maryville

17-119-1010

17-119-2007

South Roxana

17-119-3007 Wood River

17-143-0024 Peoria Fire Station #8

17-143-0036 Peoria

Commercial Building

H -~

Peoria

City Office Building 17-143-0037

17-143-0110

17-143-0210

Bartonville

Mapleton

17-1 43-1 001 Peoria Heights

17-157-0001 Houston

C = Continuous PM1O

T Trace level monitor

41
Table A4

2011 Monitoring Directory

AQS ID City

17-161-3002

0

0

C”

0

0

0

to

0

a)

0.

U)

Co

a0

aC’)

0

z

a)

0

N

0

Rock Island

a

C’)

aCL)

a17- 1 63-0010

17-163-4001

East St. Louis

0

(0

a)

.0

a

U) I—

c~ 0

0 0

U) >

0

C,

0

I—

2

a)

0

>‘

U)

(0

C,

0

0

0

a)

a)

Cu

0

U)

17-167-0006

17-167-0008

Springfield

Sewage Treatment Plant

Springfield

Federal Building

17-167-00 12

17-167-00 13

17-167-00 14

17-179-0004 Pekin

17-185-0001 Mount Carmel

17-1 85-1 001

17-195-0110 Sterling

17-197-00 13

17-1 97-1 002 Joliet

Pershing Elementary

17-197-10 11 Bra idwood

17-201-0011 Rockford

city Hall

17-201-00 13

17-201-0110

Rockford Health Department

Rockford J. Rubin & company

17-201-2001

C = Continuous PM1O

T Trace level monitor

42
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

MIDWEST GENERATION, LLC, )

) Petitioner, )

) PCB 13-024

v. ) (Variance-Air)

) ILLINOIS ENVIRONMENTAL )

PROTECTION AGENCY, )

) Respondent. )

CERTIFICATE OF SERVICE

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

RECOMMENDATION of the Illinois Environmental Protection Agency upon the following

persons:

To: John Therriault, Assistant Clerk Kathleen C. Bassi

Illinois Pollution Control Board Stephen J. Bonebrake

James R. Thompson Center Andrew N. Sawula

100 West Randolph, Suite 11-500 233 South Wacker Drive, Suite 6600

Chicago, Illinois 60601-3218 Chicago, IL 60606

Bradley Halloran, Hearing Officer Christopher Foley

Illinois Pollution Control Board 500 West Madison Street, Suite 2640

James R. Thompson Center Chicago, Illinois 60661

100 West Randolph, Suite 11-500

Chicago, Illinois 60601

ILLINOIS ENVIRONMENTAL

PROTECTION AGENCY

By: ~ - If,dA.IIIf

Dana Vetterhoffer

Assistant Counsel

Division of Legal Counsel

DATED: January 10, 2013

1021 N. Grand Ave. East

P.O. Box 19276

Springfield, IL 62794-9276

(217) 782-5544