BEFORE
    THE ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    EN
    THE MATTER
    OF:
    )
    Petition
    of
    Royal
    Fiberglass
    Pools,
    Inc.
    )
    AS-
    J
    t
    for
    an
    Adjusted
    Standard
    from
    )
    (Adjusted
    Standard)
    APR
    032009
    35IAC215.301
    )
    STATEoFlINO
    PETITION
    FOR
    AN
    ADJUSTED
    STANDARD
    Pollution
    Control
    So
    Royal
    Fiberglass
    Pools,
    Inc.
    (“Royal”),
    through
    its
    attorneys,
    Bryan
    Cave LLP,
    and
    pursuant
    to
    35
    Ill. Adm.
    Code
    §
    104.400
    et
    seq.,
    submits
    this
    Petition
    to
    the
    Illinois
    Pollution
    Control
    Board
    (“IPCB”),
    seeking
    an
    adjusted standard
    from
    35
    Iii.
    Adm. Code
    §215.301
    (commonly
    known
    as
    the
    “8
    lb/hr
    Rule”)
    as
    it
    applies
    to
    the emissions
    of
    volatile
    organic
    material
    (“VOM”)
    at
    Royal’s
    Dix,
    Illinois
    swimming
    pool
    manufacturing
    facility.
    I.
    BACKGROUND
    Royal
    operates
    a
    fiberglass
    pool
    manufacturing
    facility
    located
    at
    312
    Duncan
    Road,
    Dix,
    Illinois
    (the
    “Dix
    Plant”).
    The
    facility
    has
    one
    large
    production
    building
    in
    which
    composite
    pooi
    manufacturing
    occurs
    in
    two
    production
    bay
    areas
    that
    each
    measure
    30’
    wide
    x
    60’
    long.
    The
    production
    bays utilize
    a
    50,000-cfm
    cross-flow
    ventilation
    system
    that
    exhausts
    air
    from
    the
    work
    areas
    to
    the
    outside
    atmosphere
    through
    a 36-foot
    tall
    vertical
    discharge
    stack
    in
    order
    to
    limit
    worker
    exposure
    to
    styrene.
    Levels
    of
    styrene,
    the
    VOM
    of
    concern
    at
    the
    Dix
    Plant,
    are
    within
    the
    OSHA
    permissible
    exposure
    limits.
    Royal
    has
    always
    strived
    to
    comply
    with
    environmental
    and
    other
    regulations
    that
    apply
    to
    operations
    at
    the
    Dix
    Plant
    and,
    until
    recently,
    has
    been
    able
    to
    demonstrate
    compliance with
    such
    rules.
    In
    keeping
    with
    its
    desire
    to
    comply
    with
    applicable
    rules,
    in
    November
    of
    2004,
    Royal
    submitted
    an
    application
    for
    a
    Clean
    Air
    Act Permits
    Program
    (“CAAPP”)
    operating
    permit
    from
    the
    Illinois
    Environmental
    Protection
    Agency
    (“Illinois
    EPA”).
    To
    date,
    a permit
    has
    not
    been issued.
    Royal
    is
    aware
    that Illinois
    EPA
    has
    rejected
    the
    use
    of
    averaging
    to
    demonstrate
    compliance
    with
    the
    8 lb/hr Rule.
    The
    Illinois
    EPA has
    stated
    that
    the
    8
    lb/hr
    Rule
    specifies
    a maximum
    hourly
    emission
    rate
    and,
    therefore,
    compliance
    with the
    rule
    would
    need
    to
    be
    demonstrated
    on
    a
    strict hourly
    basis,
    not
    on
    an
    average
    from
    any
    longer
    time
    period.
    On
    January
    10,
    2006, the
    Illinois
    EPA
    issued
    Violation
    Notice
    A-2005-00281
    to
    Royal.
    After
    receipt
    of
    this
    Notice,
    representatives
    of
    Royal
    met
    with
    Illinois
    EPA
    in
    person
    and
    also
    corresponded
    with
    Illinois
    EPA
    regarding
    the
    notice.
    As
    part
    of
    these communications,
    Royal
    provided
    a
    significant
    amount
    of
    information
    to
    Illinois
    EPA
    regarding
    the
    Dix
    Plant
    and
    the
    relevant
    industry.
    With
    assistance
    from
    its
    environmental
    consultant,
    Engineering
    Environmental
    (“EA”),
    Royal
    computed
    the
    VOM
    emitted
    during
    the
    manufacture
    of
    the
    various
    pools
    Royal
    constructs.
    Royal
    discovered
    that,
    based
    on
    Illinois
    EPA’s
    strict
    hourly
    interpretation
    of
    demonstrating
    compliance,
    the
    hourly
    VOM emissions
    from
    certain
    of
    its
    operations
    (gelcoat
    and
    resin
    application)
    did
    not
    appear
    to
    comply
    with IEPA’s
    interpretation
    of

    the
    8
    lb/hr
    Rule.
    After
    carefully
    examining
    its
    options
    for add-on
    controls
    and/or
    for
    changing
    manufacturing
    methods/equipment
    to
    reduce
    Royal’s
    levels
    of
    hourly
    VOM
    emissions,
    Royal
    realized
    that
    the
    cost
    for
    compliance
    via
    either
    of
    these options
    will neither
    allow
    it to
    remain
    competitive
    nor
    profitable,
    and
    may
    force
    closure
    of
    the
    Dix
    Plant. Royal
    met
    with
    Illinois
    EPA
    and
    presented
    evidence
    demonstrating
    why
    requiring
    Royal’s
    compliance
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly basis
    is
    unreasonable.
    After
    considering
    the information
    presented
    by
    Royal,
    Illinois
    EPA
    agreed
    that
    applying
    the
    8
    lb/hour
    Rule
    to
    Royal’s
    operations
    on
    a
    strict
    hourly
    basis
    would
    indeed
    impose
    an
    unreasonable
    burden.
    Royal
    and
    Illinois
    EPA
    agreed
    that
    Royal
    would
    apply
    for
    an
    adjustment
    from
    the
    8
    lb/hr Rule.’
    Accordingly,
    Royal
    offers
    the
    following
    summary
    of
    reasons
    as
    to
    why
    it
    should receive
    an
    adjusted
    standard
    with
    respect
    to
    the
    8
    lb/hr
    Rule:
    Royal
    is
    already
    subject
    to
    National
    Emission
    Standard
    for Hazardous
    Air
    Pollutants
    for
    reinforced
    plastic
    composite
    manufacturing
    facilities,
    found
    at
    40
    CFR
    Part
    63
    Subpart
    WWWW
    (the
    “Composites
    MACT”).
    EPA
    estimates
    that
    the
    annual
    cost
    for
    a
    facility
    to
    comply
    with
    the
    MACT
    is
    $2,800/tQn
    of
    hazardous
    air
    pollutants
    removed
    and
    will
    reduce
    styrene
    emissions
    by
    an
    average
    of
    43%.
    Royal
    is
    currently
    in
    compliance
    with
    the
    MACT
    emission
    limits.
    Royal
    has
    a
    very
    low
    overall
    emission
    rate.
    Royal’s
    emission
    rate
    is
    only
    elevated
    perhaps
    one
    hour
    per
    shift,
    but the
    emission
    rate
    average
    is
    relatively
    low
    during
    the
    entire
    workshift.
    Accordingly,
    technical
    and
    regulatory
    constraints
    (such
    as
    the
    high
    air
    flow
    needed
    to
    ventilate
    building
    air
    in
    order
    to
    comply
    with
    OSHA
    worker
    health
    &
    safety
    standards)
    make
    the
    cost,
    for
    Royal
    to
    comply
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis
    using
    emission
    controls
    unreasonably
    high.
    o
    The
    capital
    costs
    associated
    with
    tail-stack
    (end-of-pipe)
    controls
    for
    Royal
    to
    comply
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis
    would
    amount
    to
    approximately
    $636,000
    to
    install
    and
    over
    $360,000
    per
    year
    to
    operate.
    This
    equates
    to
    approximately
    $33,000
    per
    ton
    of
    pollutant
    removed.
    Although
    some
    alternate
    methods
    for
    manufacturing
    fiberglass
    reinforced
    plastic
    (“FRP”)
    products
    exist,
    none
    of
    them
    can
    be
    technically
    or
    economically
    applied
    to
    a
    swimming
    pool
    manufacturing
    operation
    such
    as
    Royal’s
    and
    none
    of
    them
    will
    actually
    allow
    Royal
    to
    fully
    comply
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis.
    The
    high
    cost
    of
    using
    either
    end-of-stack
    emission
    controls
    or
    very
    expensive
    alternative
    production
    methods
    (those
    requiring
    complete
    re-tooling
    and
    re-design
    of
    production
    ‘I
    To
    the
    extent
    the
    IPCB
    does
    not
    grant
    Royal
    an
    adjusted
    standard
    pursuant
    to
    this
    Petition,
    Royal
    reserves
    all
    rights
    and
    defenses
    it
    may
    have
    concerning
    the
    application
    of
    the
    8
    lb/hr
    Rule
    to
    Royal’s
    operations,
    and
    this
    Petition
    shall
    not
    act
    as
    a
    waiver
    of
    such
    rights
    or
    defenses,
    nor
    as
    an
    admission
    of
    positions
    taken
    by
    Illinois
    EPA.
    2

    methods
    and procedures), will
    put Royal
    at a
    significant
    competitive
    disadvantage.
    This
    will
    result
    in
    one
    of the
    following
    scenarios:
    To remain
    competitive,
    Royal
    will
    be
    forced
    to
    move to
    another
    state
    which
    does
    not
    have
    an
    8
    lb/hr
    Rule
    (or any
    similar
    limitation);
    or
    Royal
    will
    eventually
    be forced
    out
    of business
    because
    it
    will not
    be
    able
    to
    compete
    for
    customers
    due to
    the high
    cost
    of its
    swimming
    pools
    and/or
    due
    to
    the
    diminished
    quality/durability
    of
    its
    swimming
    poois.
    The
    8
    lb/br
    Rule
    puts
    Royal
    at
    a competitive
    disadvantage
    to
    other
    swimming
    pooi
    manufacturers
    located
    in states
    without
    a
    similar
    8
    lb/hr Rule.
    Royal
    and
    its
    consultant
    are
    familiar
    with
    swimming
    pool
    manufacturing
    facilities
    in
    at least
    seven
    other
    states
    (Tennessee,
    West
    Virginia,
    Florida,
    Arizona,
    South
    Carolina,
    New
    York
    and
    Louisiana,
    where
    Royal’s
    other
    manufacturing
    facility
    is
    located),
    and
    none
    of
    those
    states
    have
    an
    8
    lb/hr
    Rule.
    Royal
    and
    its consultant
    are
    not
    familiar
    with
    any
    other
    swimming
    pool
    manufacturing
    operations
    within
    Illinois.
    II.
    35 ILL.
    ADM.
    CODE
    104.406
    REQUIREMENTS
    A.
    Standard
    From
    Which
    Relief
    is
    Sought
    --
    104.406(a)
    Royal
    requests
    an
    adjusted
    standard
    from
    35 Ill.
    Adm.
    Code
    §
    2
    15.301
    (Use
    of
    Organic
    Material,
    otherwise
    known
    as the
    “8 lb/hr
    Rule”).
    Illinois’
    organic
    material
    emission
    limitations
    were
    originally
    promulgated
    as
    Rule
    205
    in 1971.
    Section
    215.301
    now
    provides:
    “No person
    shall
    cause or
    allow
    the discharge
    of more
    than
    3.6
    kg/br
    (8 lbs/br)
    of
    organic
    material
    into
    the
    atmosphere
    from
    any
    emission
    source,
    except
    as
    provided
    in
    Sections
    215.302,
    215.303,
    215.304
    and the
    following
    exception:
    If
    no
    odor
    nuisance
    exists
    the
    limitation
    of
    this
    Subpart
    shall
    apply
    only
    to
    photochemically
    reactive
    material.”
    35
    Iii.
    Adm.
    Code
    §
    215.101
    states
    that
    “the
    definitions
    of
    35
    Ill.
    Admin.
    Code
    201
    and
    211
    apply
    to
    this
    part.”
    Pursuant
    to
    35 Ill.
    Adm.
    Code
    §
    201.102,
    “emission
    source”
    means
    “any
    equipment
    or facility
    of a type
    capable
    of emitting
    specified
    air
    contaminants
    to
    the atmosphere.”
    Additionally,
    §
    211.4250(b)
    defines
    “organic
    material”
    as:
    “Any
    chemical
    compound
    of carbon
    including
    diluents
    and
    thinners
    which
    are
    liquids
    at standard
    conditions
    and
    which
    are
    used
    as dissolvers,
    viscosity
    reducers,
    or cleaning
    agents,
    but excluding
    methane,
    acetone,
    carbon
    monoxide,
    carbon
    dioxide,
    carbonic
    acid,
    metallic
    carbonic
    acid,
    metallic
    carbide,
    metallic
    carbonates,
    and
    ammonium
    carbonate.”
    B.
    Nature
    of
    the Regulation
    of
    General
    Applicability
    — Section
    104.406(b)
    This
    regulation
    was
    promulgated
    to
    implement
    the
    federal
    requirements
    under
    the
    Clean
    3

    Air
    Act,
    42
    Usc
    §
    7401
    et
    seq.
    C.
    Level
    of
    Justification
    Section
    104.406(c)
    The
    regulation
    of
    general
    applicability
    from
    which
    Royal
    seeks
    an
    adjusted
    standard
    does
    not
    specify
    a
    level
    ofjustification
    for
    an
    adjusted
    standard.
    P.
    Facility
    and
    Process
    Description
    Section
    104.406(d)
    Royal
    operates
    a
    fiberglass
    swimming
    pool
    manufacturing
    facility
    in
    Dix,
    Illinois.
    Royal
    manufactures
    twenty
    different
    models
    of
    fiberglass
    pools,
    ranging
    from
    12’
    wide
    x
    16’
    long
    x
    3’
    10”
    deep
    to
    17’
    wide
    x
    40’
    6”
    long
    x
    8’
    deep.
    The
    Dix
    Plant
    began
    operations
    in
    the
    early
    1990s
    and
    during
    peak
    season
    employs
    approximately
    twenty
    individuals
    plus
    another
    five
    to
    ten
    contract
    haulers.
    The
    Dix
    Plant
    manufactures
    approximately
    240
    pools
    per
    year,
    averaging
    one
    pool
    per
    day
    in
    the
    spring
    and
    fall,
    two
    pools
    per
    day
    in
    the
    summer,
    and
    no
    pools
    per
    day
    in
    the
    winter.
    2
    Additional
    information
    regarding
    Royal’s
    history
    and
    operations
    (including
    photographs)
    are
    set
    forth
    Section
    1
    of
    the
    attached
    Technical
    Document.
    Composite
    Pool
    Manufacturing
    Procedure.
    The
    composite
    pool
    manufacturing
    at
    the
    Dix
    Plant
    consists
    of
    three
    basic
    process
    steps,
    all
    of
    which
    emit
    VOMs
    and
    would
    be
    subject
    to
    the
    requested
    adjusted
    standard:
    1.
    Gelcoat
    application.
    A
    thin
    layer
    of
    white
    gelcoat
    is
    applied
    to
    each
    bare
    waxed
    pool
    mold
    with
    a
    Magnum
    Venus
    Products
    (“MVP”)
    high-volume
    low-pressure
    (“HVLP”)
    fluid
    impingement
    technology
    (“FIT”)
    applicator
    gun.
    The
    gelcoat
    applicator
    has
    a
    2520
    gelcoat
    tipthat
    is
    operated
    as
    an
    atomizing
    gelcoat
    spray
    applicator.
    The
    white
    gelcoat
    used
    at
    Dix
    is
    made
    by
    HK
    Research
    and
    contains
    28%
    styrene
    monomer
    by
    weight
    and
    3%
    methyl
    methacrylate
    (MMA)
    by
    weight.
    This
    gelcoat
    is
    the
    state-of-the-art
    in
    low-HAP
    formulations
    for
    swimming
    pool
    production.
    2.
    Barrier
    coat
    resin
    application.
    A
    100
    to
    120
    mil
    (0.100
    to
    0.120”)
    laminate
    layer
    of
    three
    ounce
    glass
    mat
    and
    vinyl
    ester
    (“yE”)
    corrosion-resistant
    resin
    is
    applied
    to
    the
    cured
    gelcoat
    layer
    with
    the
    same
    MVP
    applicator
    that
    is
    used
    to
    apply
    gelcoat.
    However,
    the
    gelcoat
    tip
    is
    replaced
    with
    a
    5020
    VE
    tip
    and
    the
    pump
    pressure
    is
    adjusted
    to
    allow
    for
    the
    non-atomized
    application
    of
    the
    VE
    resin.
    The
    VE
    resin
    contains
    up
    to
    48%
    styrene
    content
    by
    weight.
    3.
    Isophthalic
    structural
    resin
    application.
    A
    series
    of
    consecutive
    laminate
    layers
    consisting
    of
    1
    V
    2
    oz.
    chopped
    glass
    strand
    mat
    (“CSM”),
    woven
    glass
    roving
    (“WR”),
    and
    isophthalic
    (“ISO”)
    corrosion-resistant
    resin
    is
    applied
    to
    the
    2!
    The
    CAAPP
    permit
    application
    submitted
    to
    Illinois
    EPA
    in
    November
    2004
    requested
    a
    maximum
    facility-
    wide
    annual
    production
    cap
    of
    400
    pools
    per
    year,
    which
    corresponds
    to
    full
    production
    (two
    pools
    per
    day)
    in
    spring,
    summer
    and
    fall.
    The
    CAAPP
    application
    estimates
    the
    Dix
    Plant’s
    maximum
    VOM
    emissions
    at
    about
    25
    tpy,
    approximately
    18.3
    tons
    of
    which
    relate
    to
    potential
    styrene
    emissions.
    4

    cured
    VE
    layer
    with the
    same
    MVP
    applicator
    that is
    used
    to apply
    the
    gelcoat
    and
    VE
    resin.
    However,
    the
    VE
    tip
    is
    replaced
    with
    a
    7025
    Iso
    resin
    tip and
    the
    pump
    pressure
    is adjusted
    to allow
    for
    the non-atomized
    application
    of the
    ISO
    resin.
    The
    other
    manufacturing
    steps
    include:
    (1)
    parts
    finishing, including
    trimming, grinding
    and
    sanding
    of
    finished
    pools
    parts;
    (2)
    gelcoat
    and
    resin
    cleanup,
    in which
    acetone,
    non-HAP
    and
    non-VOC
    cleaning
    solvent
    is used
    to
    clean
    gelcoat
    and
    resin
    residues
    from
    the
    application
    equipment
    and roller
    tools;
    and
    (3)
    mold
    repair
    and
    mold
    prep,
    in
    which
    very
    small
    amounts
    of
    tooling
    gelcoat
    and
    tooling
    resin
    are
    used
    to
    repair
    the
    molds
    and
    a
    small
    quantity
    of
    mold
    cleaner,
    mold
    sealer,
    and
    mold
    release
    (called
    mold
    wax),
    is
    used
    to prepare
    the
    bare
    mold
    for
    gelcoat
    application.
    These
    other
    steps
    do
    not
    have
    significant
    amounts
    of
    VOM
    emissions.
    VOM
    Emissions
    Estimates.
    The
    VOM
    emissions
    from
    the
    Dix
    Plant
    vary
    depending
    on
    the
    type
    and
    size
    of
    each
    swimming
    pool part.
    The
    facility
    emissions
    consist
    predominately
    of
    styrene,
    but
    also
    include
    small
    amounts
    of other
    VOM
    and volatile
    organic
    HAP
    species
    such
    as
    methyl
    methacrylate
    (“MMA”).
    The
    gelcoating
    process
    on the
    largest
    pool
    made
    by
    Royal
    results
    in
    about
    32.43
    lbs
    of
    VOM
    emitted
    per
    pooi
    during
    the
    one-hour
    gelcoating
    process.
    The
    resin
    process
    on
    the largest
    pooi
    results
    in about
    58.58
    lbs
    of
    VOM
    emitted
    during
    the eight-hour
    resin
    application
    process.
    The
    total
    VOM
    emitted
    during
    fabrication
    of the
    largest
    pool
    is about
    90.63
    lbs
    of
    VOM.
    Annual
    VOM
    emissions
    at the
    Dix
    Plant
    for 2006
    and
    2007
    were
    11.6
    tpy
    and
    14.8
    tpy,
    respectively.
    For
    more
    detailed
    information
    regarding
    Royal’s
    VOM
    emissions,
    see
    Section
    2
    of
    the
    Technical
    Document
    filed
    contemporaneously
    with
    this
    Petition.
    Compliance
    with
    the
    Composites
    MA
    CT.
    The
    Composites
    MACT,
    40
    C.F.R.
    63
    Subpart
    WWWW,
    requires
    that
    subject
    facilities
    similar
    to
    Royal’s
    be
    in compliance
    with
    the
    work
    practice
    standards
    contained
    therein
    by April
    21,
    2006.
    Royal
    was
    in
    compliance
    with
    the
    Composites
    MACT
    by
    February
    2006.
    To
    comply
    with
    the
    work
    practice
    standards
    in
    the
    Composites
    MACT,
    Royal
    adopted
    standards
    requiring
    that
    all resin
    containers
    are
    closed
    when
    not
    in use,
    and
    implementing
    the
    use
    of acetone,
    which
    has
    no
    HAP
    or VOM
    emissions.
    By
    complying
    with
    the
    Composites
    MACT,
    United
    States
    EPA
    estimates
    that
    industry-wide,
    reinforced
    plastic
    composite
    manufacturers
    will
    reduce
    HAP
    emissions
    by
    an average
    of 43%.
    Section
    2
    of the
    Technical
    Document
    contains
    spreadsheets
    identif’ing Royal’s
    monthly
    and
    annual
    VOM
    emissions
    for
    2006
    and
    2007
    and
    compares
    such
    emissions
    to the
    limits
    set forth
    in
    the
    Composites
    MACT.
    Section
    2
    of
    the
    Technical
    Document
    also
    contains
    Royal’s
    Initial
    MACT
    Notification
    Letter.
    Royal
    meets
    the
    MACT
    emission
    standards
    by
    using
    the HAP
    emissions
    factor
    averaging
    option
    (see
    40
    CFR
    63.58
    10(b))
    and
    Royal
    has
    continually
    been
    in
    compliance
    with
    the emission
    limits
    set forth
    in
    the
    Composites
    MACT.
    E.
    Investigation
    of Compliance
    Alternatives:
    Methods
    for
    Reducing
    VOM
    Emissions
    From
    Royal’s
    Swimming
    Pool Manufacturing
    Operations
    Section
    104.406(e)
    Royal
    investigated
    compliance
    alternatives
    that
    would
    help
    enable
    it to
    comply
    with
    the
    8
    lb/hr
    Rule
    on a
    strict
    hourly
    basis.
    Specifically,
    Royal
    investigated
    the
    following
    alternatives:
    5

    (1)
    reducing
    VOM
    content
    in
    production
    materials;
    (2)
    using
    alternative
    operating
    procedures
    and
    methods;
    and
    (3)
    installing
    add-on
    emission
    control
    technologies.
    It
    is
    important
    to
    note,
    however,
    that
    other than
    add-on
    emission
    controls,
    many
    of
    the
    alternatives
    investigated
    would.
    not
    allow
    Royal
    to
    comply
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis.
    In
    addition,
    Royal
    could
    not
    identify
    any
    feasible
    compliance
    alternatives
    to
    further reduce
    VOM
    emissions
    from
    Royal’s
    operations.
    1.
    Lower
    VOM
    Content
    Materials
    Royal
    has
    already
    reduced
    the
    VOM
    concentration
    in
    its
    production
    materials
    (gelcoat
    and
    resin
    materials)
    in compliance
    with
    the
    MACT.
    However,
    while
    complying
    with
    the
    MACT
    alone
    will
    not
    reduce
    Royal’s
    emissions
    to
    a
    level
    satisfactory
    to
    meet
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly basis,
    further
    reduction
    of
    styrene
    in
    the
    resins
    (below
    that
    needed
    to
    comply
    with
    MACT)
    is
    not
    currently
    technically
    feasible
    while
    still
    maintaining
    product
    integrity.
    This
    is
    discussed
    in
    further
    detail
    in Sections
    3,
    4
    and
    5
    of
    the
    Technical
    Document.
    2.
    Alternate
    Operating
    Procedure
    and
    Methods
    Royal
    carefully
    studied
    the
    gelcoating
    process
    at
    the
    Dix
    Plant,
    and
    considered
    every
    recognized
    alternative
    procedure
    or
    and
    method
    that
    might
    reduce
    the
    hourly VOM
    emissions
    rate.
    However,
    this
    study
    revealed
    inherent
    process
    limitations
    that
    precluded
    the
    use
    of
    any
    effective
    alternative:
    Composite
    swimming
    pools
    are
    produced
    with
    open
    molding
    processes
    on
    very
    large
    male
    molds.
    Composite
    pools
    are
    too
    large
    to
    use
    any
    closed
    molding
    process.
    Even if closed
    molding
    was
    feasible
    for
    the
    smallest
    pool
    model,
    the
    gelcoat
    layer
    must
    still
    be
    applied
    to
    the
    “open”
    closed
    mold
    with
    a gelcoat
    applicator.
    A
    high-quality
    gelcoat
    finish
    is
    an
    essential
    component
    of
    a
    commercially
    acceptable
    composite
    pooi.
    The
    pooi
    models
    are
    much
    too
    large
    to
    use
    a
    vacuum-formed
    thermoplastic
    shell
    finish,
    which
    is
    the
    only
    acceptable
    alternative
    finish
    that
    is
    used
    for
    smaller
    spa
    pools.
    Gelcoat
    must
    be
    applied
    to
    the
    pool
    mold
    in
    a single
    uniform
    layer.
    Gelcoat
    cannot
    be
    applied
    in
    separate
    strips
    or
    sections,
    because
    the
    lapped
    gelcoat
    seams
    would
    be
    structurally
    unsound
    and
    unsightly.
    Gelcoat
    must
    be
    applied
    to
    the
    mold
    with
    an
    atomizing
    mechanical
    applicator.
    Non
    atomizing
    gelcoat
    equipment
    is
    available
    that
    might
    reduce the
    gelcoat
    emission
    rate.
    However,
    the
    available
    non-atomizing
    equipment
    will
    not
    provide
    an
    acceptable
    surface
    finish
    and
    has
    failed
    to
    reduce
    gelcoat
    emissions
    as
    promised
    by
    the
    manufacturer.
    The
    gelcoat
    process
    takes
    about
    one
    hour
    for
    the
    largest
    pool
    model
    and
    the
    largest
    pool
    model
    requires
    at
    least
    220
    pounds
    of
    gelcoat.
    6

    The
    white
    gelcoat
    used
    by
    Royal
    is state-of-the—art
    and
    contains
    the
    lowest
    feasible
    monomer
    contents
    of
    28%
    styrene
    and
    3%
    MMA.
    This
    gelcoat provides
    a
    flexible,
    durable,
    glossy
    finish
    that must
    resist
    impact, weathering,
    temperature
    extremes,
    UV
    radiation,
    and
    blistering.
    o
    The
    emissions
    from
    the
    current
    gelcoat
    process
    cannot
    be
    appreciably
    reduced
    with
    any
    additional
    workpractice
    improvements,
    pollution
    prevention
    techniques,
    or
    gelcoat
    material
    substitutions.
    The
    application
    of
    gelcoat
    takes
    place
    in
    large
    work
    bay
    areas
    that
    require
    significant
    amounts
    of
    ventilation
    airflow
    to
    protect
    the
    workers against
    styrene exposure.
    This
    ventilation
    is required
    by
    OSHA regulations.
    The
    relatively
    large
    airflow
    rate
    and
    low
    styrene
    exposure
    limits
    established
    by
    OSHA
    result
    in
    a
    large
    dilute
    exhaust
    stream
    that
    cannot
    be economically
    controlled
    with
    add-on
    air
    pollution
    control equipment.
    Further
    increasing
    the
    airflow,
    as
    might
    be
    recommended
    by
    an air
    flow
    study,
    would
    only
    serve
    to
    make
    add-on
    controls
    even
    more
    costly, not
    more
    feasible.
    The
    cost
    of
    the
    lowest-cost
    control
    equipment
    is
    detailed
    in
    the
    next
    section.
    3.
    Add-On
    Air
    Pollution
    Controls
    The
    cost
    and
    feasibility
    of
    add-on
    air
    pollution
    controls at reinforced
    plastic
    composite
    manufacturing
    facilities
    has
    been
    thoroughly
    studied
    and
    documented
    as
    part
    of
    the
    Composites
    MACT
    (40
    C.F.R.
    63
    Subpart
    WWWW).
    The
    Dix
    Plant
    is
    fully
    compliant
    with
    the
    HAP
    emission
    limits
    listed
    in
    the
    Composites
    MACT
    standard, averaging
    72%
    of
    the
    MACT
    emissions
    limit.
    See
    Sections
    4
    and
    5of
    the
    attached
    Technical
    Document
    for
    more
    information
    on
    Royal’s
    compliance
    with
    the
    Composites
    MACT.
    According
    to
    the
    Composites
    MACT,
    a
    composites
    facility
    such
    as
    the
    Dix
    Plant
    is
    not
    required
    to
    install
    add-on
    air
    pollution
    controls.
    During
    the
    promulgation
    and
    development
    of
    the
    Composites
    MACT,
    the
    United
    States
    EPA
    discovered
    that
    add-on
    air
    pollution
    controls
    are
    not
    cost
    effective
    at
    most
    existing
    composite
    facilities.
    The
    United
    States
    EPA
    also
    determined
    that
    add-on
    controls
    with
    95%
    control
    efficiency
    would
    only
    be
    cost
    effective
    for
    new
    composite
    facilities
    that
    emit
    more
    than
    100
    tpy
    of
    HAP
    or
    new
    facility
    that
    produces
    large
    parts
    such
    as
    swimming
    pools
    and
    emits
    more
    than
    250
    tpy
    of
    HAP.
    The
    Dix
    Plant
    emits
    less
    than
    12
    tpy
    of
    HAP,
    so
    add-on
    controls
    would
    not
    be
    cost
    effective
    by a
    very
    wide
    margin.
    A
    comprehensive
    study
    entitled
    “Feasibility
    and
    Cost
    of
    the
    Capture
    and
    Control
    of
    Hazardous
    Air
    Pollutant
    Emissions
    from
    the
    Open
    Molding
    of
    Reinforced
    Plastic
    Composites”
    prepared
    by
    Engineering
    Environmental
    was
    submitted
    to
    United
    States EPA
    in
    April
    2000
    as
    part
    of
    the
    promulgation
    of
    the
    Composites
    MACT
    rule. This
    report has
    377
    pages
    of
    information
    concerning
    the
    cost
    and
    feasibility
    of
    add-on
    controls
    at composites
    facilities.
    Very
    little
    has
    changed
    since
    the
    2000
    publication
    date,
    except
    that
    the
    cost
    of
    electricity
    and
    natural
    gas
    needed
    to
    operate
    add-on
    controls
    has
    risen
    dramatically.
    3
    Due
    to
    the
    size
    of
    this
    study,
    Royal
    is
    not
    including
    a
    copy
    with
    this
    Petition.
    It
    is
    part
    of
    EPA’s
    docket
    regarding
    the
    Composites
    MACT
    rule
    promulgation
    and
    adoption.
    Should
    the
    Board
    desire
    a
    copy
    of
    the
    study,
    Royal
    would
    be
    pleased
    to
    provide
    it
    to
    the
    Board.
    7

    An abbreviated
    summary
    of
    the
    air
    pollution
    control
    systems,
    which
    are detailed
    in
    the
    aforementioned
    study
    and
    are
    available
    for
    use,
    is
    contained
    in
    the
    following
    table:
    Commercially Available
    Air
    Pollution
    Controls
    .
    .
    Technology
    Applicability
    .
    Concerns
    Status
    at
    the
    I
    Plant
    Absorption
    Styrene
    is
    nearly
    insoluble
    in
    water
    infeasible
    Styrene
    polymerizes
    on
    sorbent
    media
    Adsorption
    Desorbed
    styrene
    is
    not
    reusable
    infeasible
    Desorbed
    styrene
    must
    be
    disposed
    as
    hazardous
    waste
    .
    Microbes
    are
    unreliable
    and
    must
    stay warm
    and
    moist
    Biodigestion
    .
    .
    Digestion
    beds
    must
    be
    huge
    to
    handle
    exhaust
    airflow
    .
    infeasible
    Styrene
    concentration
    in
    air
    too low
    to
    be
    economic
    Condensation
    Condensate
    is
    mostly
    water
    with
    trace
    styrene
    infeasible
    Condensate
    must
    be
    disposed
    as
    hazardous
    waste
    Flare
    Styrene
    concentration
    in
    air
    is
    too low
    to
    be
    economic
    infeasible
    TO
    costly
    Conventionalthan
    RTO
    recuperative
    oxidation
    is
    always
    more
    RTO
    is
    better
    Regenerative
    thermal
    oxidation
    is
    currently
    employed
    technically
    at
    one
    truck
    cap
    plant
    and
    several
    large
    bathware
    plants
    feasible
    that
    produce
    small
    parts
    on
    automated
    production
    lines,
    Oxidation
    RTO
    operate
    continuously
    (24
    hr/day,
    360 days/yr)
    and
    have
    economically
    uncontrolled
    styrene
    emissions
    >250
    tpy.
    A
    RTO
    infeasible
    system
    large
    enough
    to
    handle
    the 50,000
    cfm
    exhaust
    airflow
    at
    the
    Dix
    Plant
    would
    cost over
    $600,000
    to
    install
    and
    over
    $300,000
    per
    year to
    operate.
    CO
    Catalytic
    media
    has
    a
    relatively
    short
    lifetime
    and
    is
    infeasible
    unreliable
    Preconcentration
    is
    currently
    employed
    at
    four
    large
    technically
    bathware
    plants.
    The
    long-term
    performance
    of
    the
    questionable
    adsorber
    in
    questionable
    due
    to
    an
    unexpected
    failure
    Preconcentration
    of
    the
    activated
    charcoal
    sorbent
    media
    at
    one
    of
    the
    economically
    w/RTO
    sites.
    A
    preconcentrator
    system
    large
    enough
    to
    handle
    infeasible
    the
    proposed
    50,000
    cfm
    exhaust
    airflow
    at
    the
    Dix
    Plant
    would
    cost
    almost
    one
    million
    dollars
    to
    install
    and
    operate.
    A
    detailed
    add-on
    control
    cost
    estimate
    for
    a
    skid-mounted
    RTO
    system
    for
    the
    Dix
    Plant
    was
    previously
    submitted
    to
    Illinois
    EPA
    on
    February
    28,
    2006
    and
    is
    attached
    in
    the
    accompanying
    Technical
    Document
    at
    Section
    3.
    As detailed
    in
    this
    analysis,
    the
    skid-mounted
    RTO
    control
    option
    would
    cost
    approximately
    $33,300
    per
    ton
    of
    styrene
    and
    MMA
    removed
    per
    year.
    As
    such,
    the
    cost
    effectiveness
    of
    the
    RTO
    control
    option
    is
    more
    than
    three
    times
    greater
    than
    what
    is
    widely
    regarded
    as
    affordable.
    The
    annual
    operating
    cost
    of
    the RTO
    control
    8

    options
    is
    several
    times
    greater
    than
    the
    annual
    profit
    for
    the
    Dix Plant.
    Hence,
    add-on
    controls
    are prohibitively
    expensive
    and
    not economically
    feasible
    for
    the
    Dix
    Plant.
    F.
    Royal’s
    Proposed
    Adjusted
    Standard
    Section
    104.406(f)
    As
    set
    forth
    above,
    the
    rule of
    general
    applicability
    from
    which
    Royal
    seeks
    this
    adjusted
    Standard
    prohibits
    Royal
    from
    emitting
    “more
    than
    8
    lbs/hr
    of
    organic
    material
    into
    the
    atmosphere
    from
    any
    emission
    source.”
    35 I.A.C.
    §215.301.
    Because
    IEPA
    will
    not
    allow
    averaging
    of
    emissions
    to
    meet
    this
    standard,
    Royal
    can
    not
    comply
    with
    the
    8
    lb/hr Rule
    as
    interpreted
    by
    IEPA.
    Accordingly,
    Royal
    proposes
    that,
    in
    lieu
    of
    being
    subject
    to
    35
    I.A.C.
    §215.301,
    Royal
    shall
    comply
    with
    the
    MACT
    Standard
    finalized
    at
    40
    C.F.R.
    Part
    63,
    Subpart
    WWWW
    (the
    “Composites
    MACT”).
    As
    discussed
    in
    Section
    II.D
    of
    this
    Petition,
    Royal
    has
    come
    into
    compliance
    with
    the
    work
    practice
    standards
    of
    the Composites
    MACT
    Standard.
    According
    to
    the
    Composites
    MACT,
    EPA
    estimates
    that
    compliance
    with
    the MACT
    will
    cost
    $2,800/ton
    annually
    and
    will
    reduce
    emissions
    by
    an
    average
    of
    43%.
    Royal
    proposes
    the
    following
    language
    for
    a
    Board
    order
    to
    impose
    the adjusted
    standard:
    1.
    Pursuant
    to
    Section
    28.1
    of
    the
    Environmental
    Protection
    Act
    (“Act”)
    (415 ILCS
    5/28/1),
    the
    Board
    grants
    Royal
    Fiberglass
    Pools
    (“Royal”)
    an
    adjusted
    standard
    from
    35
    Ill.
    Adm.
    Code.
    215.201
    (“8
    lb/hr
    Rule”),
    effective
    200_.
    The
    adjusted
    standard
    applies
    to
    the
    emissions
    of
    volatile
    organic
    material
    (“VOM”)
    into
    the
    atmosphere
    from
    Royal’s
    swimming
    pool
    manufacturing
    facility
    located
    in
    Dix,
    Illinois.
    2.
    35
    Ill.
    Adm.
    Code
    215.301
    does
    not
    apply.
    Royal
    remains
    subject
    to
    the following:
    a. Royal
    must
    continue
    to
    investigate:
    (a)
    swimming
    pool
    production
    methods
    that
    generate
    fewer
    VOM
    emissions,
    and
    (b)
    materials
    that have
    a
    reduced
    VOM
    content
    and/or
    are
    compliant
    with
    the
    Composites
    MACT
    HAP
    content.
    Where
    practicable,
    Royal
    must
    substitute
    current
    materials
    with
    lower
    VOM
    content
    materials
    as
    long
    as
    such
    substitution
    does
    not
    result
    in
    a
    net
    increase
    in
    VOM
    emissions.
    b. Royal
    must
    perform
    any
    reasonable
    test
    of
    new
    technologically
    or
    economically
    reasonable
    production
    methods
    or
    materials
    applicable
    to
    the
    open-mold
    swimming
    pooi manufacturing
    industry,
    which
    may reduce
    VOM
    emissions
    at
    Royal’s
    facility
    which
    the
    Illinois
    Environmental
    Protection
    Agency
    (Agency)
    specifically
    requests
    in
    writing
    they
    do. After
    performance
    of
    such
    tests,
    Royal
    must
    prepare
    and
    submit
    a
    report
    summarizing
    the
    activities
    and
    results
    of
    these
    investigatory
    efforts.
    The
    report
    must
    be
    submitted
    to
    the
    Agency,
    Bureau
    of
    Air,
    Compliance
    and Enforcement
    Section.
    c.
    Royal
    must
    operate
    in
    full
    compliance
    with
    the Clean
    Air
    Act,
    its
    Clean
    Air
    Act
    Permit
    Program
    permit
    (once
    issued),
    the National
    Emissions
    Standard
    for
    9

    Hazardous
    Air
    Pollutants
    for
    Reinforced
    Plastic Composite
    Manufacturing
    Facilities,
    set
    forth
    in
    40
    C.F.R.
    63,
    Subpart WWWW,
    as
    required
    by
    Section
    9.1(a)
    of
    the
    Act,
    and
    any
    other
    applicable
    regulation.
    G.
    Quantitative
    and
    Qualitative
    Description
    of
    Royal’s
    Impact
    on
    the
    Environment
    Before
    and
    After
    the
    Proposed
    Adjusted
    Standard
    — Section
    104.406(g)
    Air
    Quality
    Impact
    Analysis
    of
    Royal’s Operations.
    As
    indicated,
    the
    Dix
    Plant
    is
    already
    in
    compliance
    with
    the
    Composites
    MACT,
    and
    the
    proposed
    adjusted
    standard
    will
    not
    impact
    future
    compliance
    with
    the
    MACT.
    Additionally,
    attached
    at Section
    6
    of
    the
    Technical
    Document
    is
    an
    Air
    Quality
    Impact
    Analysis
    of
    the
    Dix
    Plant.
    This
    analysis
    presents the
    worst-
    case
    scenario
    for
    ozone
    emissions
    using
    the
    proposed
    adjusted
    standard.
    Based
    on
    the
    results
    of
    the
    analysis,
    the
    worst-case
    one-hour
    average
    ozone
    impact
    is
    still
    only
    74%
    of
    the
    one-hour
    ozone
    standard.
    Royal
    understands
    that
    in
    2005,
    EPA
    replaced
    the
    one-hour
    average
    ozone
    standard
    with
    an
    eight-hour
    average
    standard,
    but
    believes
    the
    hourly calculation
    presented
    in
    the
    attached
    Air
    Quality
    Impact
    Analysis
    is
    useful
    given
    the
    obvious
    concerns
    about
    hourly
    emissions
    that
    are
    reflected
    in
    the
    8
    lb/hr
    Rule.
    Should
    Royal’s
    petition
    be
    granted,
    there
    will
    not
    be
    any
    increase
    on
    a
    per
    unit
    basis
    over
    the
    current
    emissions
    from
    the
    Dix
    Plant.
    This
    petition
    merely
    seeks
    to
    allow
    Royal
    to
    continue
    manufacturing
    in
    the
    same
    manner,
    and
    granting
    the
    petition
    will
    not
    amount
    to
    an
    increase
    of
    per
    unit
    emissions.
    Cross-Media
    Environmental
    Impacts
    Resulting
    from
    an
    Adjusted
    Standard.
    None.
    The
    Dix
    Plant’s
    waste
    and
    wastewater
    generation
    is independent
    of
    VOM
    emissions,
    thus
    no
    change
    in
    the
    nature
    or
    volume
    of waste
    and
    wastewater
    generation
    is
    anticipated.
    H.
    Justification
    — Section
    104.406(h)
    Under
    Section
    28.1
    of
    the
    Environmental
    Protection
    Act
    (the
    “Act”),
    the
    Board
    may
    grant
    an
    adjusted
    standard
    for
    persons
    who
    can
    justify
    such
    an
    adjustment
    consistent
    with
    subsection
    (a)
    of
    Section
    27
    of
    the
    Act:
    415
    I.L.C.S.
    5/28.1.
    Moreover,
    if
    a
    regulation
    of
    general
    applicability
    does
    not
    specify
    a
    level
    of
    justification
    required
    of
    a
    petitioner
    to
    qualify
    for
    an
    adjusted
    standard,
    the
    Board
    may
    grant
    individual
    adjusted
    standards
    upon
    adequate
    proof
    that:
    (1)
    factors
    relating
    to
    that
    petitioner
    are
    substantially
    and
    significantly
    different
    from
    the
    factors
    relied
    upon
    by
    the
    Board
    in
    adopting
    the
    general
    regulation
    applicable
    to
    that
    petitioner;
    (2)
    the
    existence
    of
    those
    factors
    justifies
    an
    adjusted
    standard;
    (3)
    the
    requested
    standard
    will
    not
    result
    in
    environmental
    or
    health
    effects
    substantially
    and
    significantly
    more
    adverse than
    the
    effects
    considered
    by
    the
    Board
    in
    adopting
    the
    rule
    of
    general
    applicability;
    and
    (4)
    the
    adjusted
    standard
    is consistent
    with
    any
    applicable
    federal
    law.
    Significantly,
    the
    proposed
    adjusted
    standard
    is
    consistent
    with
    prior
    adjusted
    standards
    from
    the
    8
    lb/hr
    Rule
    issued
    by
    the
    IPCB
    for
    similar
    manufacturing
    processes.
    Specifically,
    on
    July
    22,
    2002,
    the
    IPCB
    granted
    Crownline
    Boats,
    Inc.’s
    (“Crownline”)
    Petition
    for
    Adjusted
    10

    Standard.
    Crownline
    operates
    a
    fiberglass
    boat
    manufacturing
    facility
    in West
    Frankfort,
    Illinois,
    using
    a
    gelcoat
    and
    resin
    application
    process
    very
    similar
    to
    that
    employed
    by
    Royal. Crownline
    was
    granted
    an
    exemption
    from
    compliance
    with
    the
    8
    lb/hr
    Rule
    because
    compliance
    with
    a
    MACT
    standard
    similar
    to the
    Composites
    MACT
    could
    be
    demonstrated.
    See
    Section
    7
    of
    the
    attached
    Technical
    Document
    for
    a
    copy
    of
    the
    IPCB’s
    opinion
    and
    order
    regarding
    the
    Crownline
    petition.
    The adjusted
    standard
    proposed
    herein
    is
    based
    on
    the
    adjusted standard
    approved
    by
    the
    IPCB
    in response
    to
    Crownline’s
    petition.
    1.
    Factors
    Relating
    to
    Royal
    are
    Substantially
    and
    Significantly
    Different
    The
    primary
    intent
    of
    the
    8 lb/hr
    Rule
    was
    to
    prevent
    ozone
    formation
    and
    odor
    nuisance.
    However,
    the
    Board
    did
    not
    contemplate
    the
    methods
    Royal Fiberglass
    Pools
    would
    use
    to
    manufacture
    swimming
    pools
    at
    the
    Dix
    Plant
    when
    it promulgated
    the
    8
    lb/hr
    Rule
    in
    1971.
    The
    manufacture
    of
    large
    composite
    parts
    such
    as
    swimming
    pool
    shells
    involves
    a batch-type
    process
    rather
    than
    a continuous
    application
    process
    typically
    used
    in
    manufacturing
    processes
    for
    other
    products.
    This
    fact,
    together
    with
    the
    ventilation
    system
    needed
    to
    comply with
    OSHA’
    s
    worker
    protection
    regulation
    at
    29
    C.F.R. Part
    1910,
    makes
    the
    use
    of
    add-on
    emission
    controls
    economically
    infeasible.
    Under
    OSHA
    health
    and
    safety
    standards
    for
    styrene,
    the
    Dix
    Plant
    must
    maintain
    large
    airflow
    to
    ventilate
    the
    work
    areas
    properly.
    The
    small
    emission
    rate
    and
    large
    airflow
    makes
    the
    cost
    of
    using
    add-on
    emissions
    controls
    unaffordable.
    Attached
    at
    Section
    8
    of
    the
    Technical
    Document
    is
    a
    February
    25,
    2008
    letter
    from
    Rob
    Haberlein
    to
    Dale
    Guariglia
    which
    discusses
    the
    costs
    of
    add-on
    controls
    and
    why
    a
    reduction
    in
    ventilation
    airflow
    at
    the
    Dix
    Plant
    would
    be
    prohibited
    by
    the
    OSHA
    requirements.
    In
    short,
    Royal
    Fiberglass
    Pools
    believes
    that
    the
    Board
    did
    not
    anticipate
    the
    requisite
    production
    methods
    for
    manufacturing
    large
    composite
    parts
    and
    the
    OSHA
    standard
    when
    adopting
    the
    8
    lb/hr
    Rule
    in
    1971.
    The
    factors
    relating
    to
    Royal’s
    operations
    are
    substantially
    and
    significantly
    different
    than
    the
    general
    factors
    relied
    upon
    by
    the
    Board
    in
    promulgating
    the
    8
    lb/hr
    Rule.
    The
    8
    lb/hr
    Rule
    was
    first
    promulgated
    in
    1971
    as
    Chapter
    2:
    Air
    Pollution,
    Rule 205.
    4
    PCB
    191,
    R71-23.
    Because
    it was
    adopted
    over
    30
    years
    ago,
    it is
    difficult,
    if
    not
    impossible,
    to know
    exactly
    what
    factors
    the
    Board
    relied
    upon
    in
    adopting
    this
    rule.
    However,
    based
    upon
    Illinois
    Pollution
    Control
    Board
    case
    law
    and
    a
    common
    sense
    reading
    of
    the
    rule,
    Royal
    believes
    that
    the
    factors
    primarily
    relied
    upon
    by
    the
    Board
    involved
    concerns
    about
    preventing
    ozone
    formation.
    In
    fact,
    it
    appears
    that
    the
    main
    intent
    of
    the
    rule
    was
    to
    ensure
    that
    operations
    emitting
    organic
    material
    utilized
    control equipment
    already
    in place
    to
    ensure
    that
    their
    facilities
    do
    not
    cause
    a
    violation
    of
    the
    one-hour
    ozone
    standard
    nor
    create
    an
    odor
    nuisance.
    For
    example,
    in
    Illinois
    v.
    Processing
    and
    Books,
    Inc.,
    the
    IPCB
    explained
    that:
    “Rule
    205:
    Organic
    Material
    Emission
    Standards
    serves
    both
    to
    achieve and
    maintain
    compliance
    with
    the
    federal
    air
    quality
    standard
    for
    photochemical
    oxidants
    (0.08
    ppm
    for
    one
    hour
    not
    to exceed
    more
    than
    once
    per
    year,
    36
    Fed.
    Reg.
    22385
    Nov.
    25,
    1971)
    and
    to
    prevent
    local
    nuisances.
    . .
    . the
    major
    purpose
    of these
    regulations
    is
    for
    control
    of
    photochemical
    oxidants.
    In
    addition,
    odor
    causing
    organic
    emissions
    were
    included
    if a
    local
    odor
    nuisance
    exits
    .
    .
    . these
    provisions
    are
    designed
    to
    require the
    use
    of
    11

    equipment
    that
    is already
    in
    use
    at
    numerous
    facilities
    .
    .
    1977
    WL
    9986,
    *4
    (Ill.
    Pol.
    Control.
    Bd.).
    From
    this
    explanation
    it
    is
    evident
    that
    the
    Board
    was
    most
    concerned
    with:
    (1)
    protecting
    ambient
    air
    quality
    by
    preventing
    any
    violation
    of
    the
    1-hour
    ozone
    NAAQS;
    and (2)
    controlling
    any
    odor
    nuisances
    from
    manufacturing
    operations.
    A
    review
    of
    Royal’s
    operations
    shows
    that
    the
    main
    purposes
    of
    this
    rule
    are
    not
    furthered
    through
    its
    application
    to
    Royal:
    first,
    as
    discussed
    in
    Section
    II.G
    of
    this
    Petition,
    the
    daily
    amounts
    of
    VOM
    emitted
    by
    Royal’s
    operations
    have
    a
    negligible
    impact
    on
    ambient
    ozone
    levels
    and
    would
    not
    cause
    a
    violation
    of
    the
    ozone
    NAAQS;
    and
    second,
    Royal
    has
    a
    tall
    stack
    in
    place
    to
    minimize
    odor
    nuisance
    from
    its
    operations.
    The
    above
    quote
    from
    the
    Illinois
    Pollution
    Control
    Board
    also shows
    that,
    when
    adopting
    the
    rule
    in
    1971,
    the
    Board
    most likely
    relied
    upon
    the
    fact
    that
    facilities
    would
    have
    no
    problem
    complying
    with
    the
    rule
    by
    utilizing
    equipment
    already
    available
    and
    in
    use
    by
    most
    facilities
    subject
    to
    the
    rule.
    It
    is
    clear
    that
    this
    rule was
    promulgated
    as
    a
    catch-all
    provision,
    intending
    to
    cast
    a
    wide
    net
    over
    all
    operations
    which
    emit
    organic
    materials.
    However,
    the
    Board
    could
    not
    possibly
    have
    contemplated
    all
    the
    circumstances
    in
    which organic
    material
    is
    emitted,
    and,
    in
    fact,
    there
    is no
    indication
    that
    the
    Board
    considered
    the
    factors
    peculiar
    to
    pool
    fabrication
    when
    adopting
    this
    rule.
    There
    are
    other
    substantial
    and
    significant
    factors
    which
    are
    inherent
    or
    otherwise
    necessary
    to
    Royal’s
    operations
    that
    the
    Board
    did
    not
    consider
    (nor
    could
    it
    have) when
    it
    adopted
    the
    8
    lb/hr
    Rule
    in
    1971.
    The
    building
    of
    a
    fiberglass
    swimming
    pooi
    involves
    a
    batch-
    type
    process
    (of
    applying
    layers
    or
    skins),
    rather
    than
    a
    continuous
    application
    process.
    This
    is
    an
    important
    distinction
    because
    compliance
    with
    the
    rule can
    be
    reasonably
    accomplished
    and
    demonstrated
    when
    manufacturing
    operations
    (that
    involve
    the
    use
    of
    materials
    that
    emit
    VOMs)
    are
    of
    a
    continuous
    nature
    or,
    are
    at
    least
    are
    distributed
    more
    evenly
    over
    a
    24
    hour
    period.
    For
    continuous
    or
    near-continuous
    operations,
    the
    use
    of
    emission
    controls,
    as
    provided
    by
    35
    I.A.C.
    215.302,
    is
    economically
    feasible.
    Due
    to
    the
    large
    size
    of
    the
    swimming
    pooi
    molds
    and
    necessary
    batch-type
    sequence
    of
    the
    gelcoat
    and
    resin
    application
    processes
    at
    the
    Dix
    Plant,
    they
    are
    neither
    continuous
    nor
    evenly
    distributed
    over
    a longer
    period
    of
    time.
    Additionally,
    the
    advent
    of
    OSHA’s worker
    protection
    regulation
    at
    29
    CFR 1910,
    requires
    manufacturers
    who
    use
    materials
    that
    contain
    and
    emit styrene
    to
    maintain
    an
    in-plant
    work
    area
    atmosphere
    (worker
    breathing
    air)
    of
    less
    than
    100
    ppm.
    To
    do
    so,
    Royal
    had
    to
    install
    a
    large
    ventilation
    system
    that exhausts
    approximately
    50,000
    cubic
    feet
    of
    plant
    air
    every
    minute.
    This
    makes
    the
    use
    of
    add-on
    emission
    controls
    for
    Royal’s
    operations
    fiscally
    impractical.
    See
    Section
    8
    of
    the
    Technical
    Document.
    The
    Board
    could
    not
    have
    possibly
    anticipated
    this
    OSHA
    requirement
    and
    its
    affect
    when
    it
    made
    its
    decision
    to
    adopt
    the
    8
    lb/hr
    Rule
    for
    all
    manufacturing
    facilities
    in
    the
    State.
    Finally,
    on
    June
    15,
    2005,
    EPA
    revoked
    the
    one-hour
    average
    ozone
    standard,
    which
    was
    replaced
    by
    an
    eight-hour
    average
    standard.
    See
    69
    Fed.
    Reg.
    23951
    (Apr.
    30,
    2005).
    As
    referenced
    by
    the
    Board
    in
    Illinois
    v.
    Processing
    and Books,
    Inc.,
    the
    8
    lb/hr
    Rule
    was designed
    in
    primary
    part
    to
    assist
    in
    achieving
    compliance
    with
    EPA’s
    one-hour
    average
    standard.
    12

    Although
    Royal
    is not
    requesting
    that
    the
    Board
    revoke
    the 8
    lb/hr
    Rule,
    Royal
    asserts
    that
    the
    elimination
    of
    one of
    the fundamental
    purposes
    of
    the
    8 lb/h
    Rule
    supports
    this
    request
    for
    an
    adjusted
    standard.
    Because
    the
    IPCB
    could
    not
    (and
    did
    not)
    consider
    these
    factors
    relating
    to Royal’s
    operations,
    Royal
    contends
    that
    it is
    unreasonable
    to
    expect
    it
    to
    demonstrate compliance
    with
    the
    8
    lb/hr
    Rule
    on
    a strict
    hourly
    basis.
    2.
    The
    Existence
    of Those
    Factors
    Justifies
    an
    Adjusted
    Standard
    As
    discussed
    fully
    in Section
    II.E.
    of
    this
    Petition,
    Royal
    has
    investigated
    numerous
    compliance
    alternatives
    that
    have
    proven
    to be
    neither
    economically
    nor
    technically
    feasible
    due
    to
    the
    substantially
    different
    factors
    relating
    to Royal’s
    operations.
    The
    existence
    of these
    factors,
    coupled
    with
    JEPA’s
    endorsement
    of
    Royal’s
    efforts
    to obtain
    an adjusted
    standard
    justifies
    the
    granting
    of an
    adjusted
    standard.
    3.
    The
    Requested
    Standard
    Will
    Not Result
    in Adverse
    Environmental
    or
    Health
    Effects.
    As
    discussed
    previously
    in Section
    II.G
    of this
    Petition,
    the
    requested
    adjusted
    standard
    will
    have
    little,
    if any,
    adverse
    impact
    on
    the
    environment
    or
    health.
    By
    complying
    with
    the
    Composites
    MACT,
    Royal
    has
    limited
    its
    VOM
    emissions
    and
    also
    decreased the
    amount
    of
    solid
    and
    hazardous
    waste
    Royal
    generates.
    Even
    without
    these
    changes,
    Royal’s
    operations
    do
    not
    cause
    or
    contribute
    to
    any
    ozone
    exceedances.
    With
    respect
    to health
    effects,
    Royal
    notes
    that
    Illinois
    does
    not have
    a
    health
    standard
    for
    styrene
    emissions,
    and
    this manufacturing
    process
    is the
    same
    process
    used
    by
    swimming
    pool
    manufacturers
    in
    many
    other
    states.
    4.
    The
    Proposed
    Adjusted
    Standard
    is
    Consistent
    with
    Federal
    Law
    The granting
    of
    this
    proposed
    adjusted
    standard
    is consistent
    with
    federal
    law
    and will
    not
    violate
    any
    provision
    of the
    federal
    Clean
    Air
    Act.
    Specifically,
    there
    is no
    Clean
    Air
    Act
    equivalent
    rule
    or regulation
    prohibiting
    swimming
    poo
    1
    manufacturers’
    emissions
    of
    organic
    material
    in
    excess
    of
    8
    lbs/hr,
    on
    a strict
    hourly
    basis.
    Because
    Royal
    is proposing
    to
    comply
    with
    the
    Composites
    MACT,
    the
    proposed
    adjusted
    standard
    is
    consistent
    with
    federal
    law.
    I.
    Consistency
    with
    Federal
    Law
    — Section
    104.406(1)
    There
    is
    no
    Clean
    Air
    Act
    equivalent
    rule
    or regulation
    prohibiting
    VOM
    emissions
    from
    reinforced
    plastic
    composite
    manufacturing
    in
    excess
    of
    8 lbs/hr
    on a
    strictly
    hourly
    basis.
    Regardless,
    the
    facility
    must
    comply
    with
    the
    new
    federal
    NESHAP
    for
    reinforced
    plastic
    composite
    manufacturing.
    For
    these
    reasons,
    the
    proposed
    adjusted
    standard
    is
    consistent
    with
    federal
    law.
    13

    J.
    Hearing
    Section
    104.406(j)
    Royal
    requests
    a
    hearing
    in
    this
    matter.
    K.
    Supporting
    Document
    Section
    104.406(k)
    The
    Technical
    Document
    is
    filed
    contemporaneously
    with
    this
    Petition.
    III.
    CONCLUSION
    The
    requested
    adjusted
    standard
    should
    be
    granted
    as
    an
    alternative
    to
    Royal’s
    compliance
    with
    35
    IAC
    §215.301.
    Notwithstanding
    the
    technical
    impracticality
    of
    complying
    with
    the
    requirements
    of
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis,
    to
    require
    Royal
    to
    comply
    with
    the
    8
    lb/hr
    Rule
    would
    result
    in
    substantial
    economic
    hardship
    to
    Royal,
    and perhaps
    even
    closure
    of
    the
    Dix
    Plant.
    WHEREFORE,
    Royal
    Fiberglass
    Pools,
    Inc. respectfully
    requests
    an
    adjusted
    standard
    from
    35
    IAC
    §
    215.301
    as
    set
    forth
    herein.
    Respectfully
    Submitted,
    BRYAN
    CAVE
    LLP
    By:
    -‘
    /,
    Dale
    A.
    Guariglia,
    MO
    Ba #32988
    Brandon
    W.
    Neuschafer,
    MO
    Bar
    #53232
    One Metropolitan
    Square
    211
    North
    Broadway,
    Suite
    3600
    St.
    Louis,
    Missouri
    63102
    Tel.
    (314)
    259-2000
    Fax.
    (314)
    259-2020
    Attorneys
    for
    Royal
    Fiberglass
    Pools,
    Inc.
    14

    CERTIFICATE
    OF
    SERVICE
    The
    undersigned
    certifies
    that
    a
    copy
    of
    the
    foregoing
    Petition
    was
    served
    upon
    the
    following
    parties
    on
    the
    31st
    day
    of
    March,
    2009:
    Illinois
    Pollution
    Control
    Board,
    Attn:
    Clerk
    100
    West
    Randolph
    Street
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    Chicago,
    IL
    60601-3218
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    Attn:
    Charles
    Matoesian
    lDt
    .

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    Petition
    of
    Royal
    Fiberglass
    Pools
    Inc
    )
    AS-
    CEVE
    For
    an
    Adjusted
    Standard
    from
    )
    (AdjuedStaiidard)
    CLERK’S OFFICE
    35
    IAC
    §
    215.301
    )
    APR
    03
    2009
    MOTION
    FOR
    EXPEDITED
    REVIEW
    STATE
    OF
    ILUNOIS
    Pollution
    Control
    Board
    Royal
    Fiberglass
    Pools,
    Inc.
    (“Royal”),
    by
    and
    through
    its
    attorneys,
    Bryan
    Cave
    LLP,
    respectfully
    requests
    that
    the Illinois
    Pollution
    Control
    Board
    consider
    its
    petition
    for Adjusted
    Standard
    on
    an
    expedited
    basis.
    In
    support
    of
    its
    motion,
    Royal
    provides:
    1.
    Royal
    owns
    a
    fiberglass
    swimming
    pooi manufacturing
    facility
    in
    Dix, Illinois.
    2.
    On
    January
    10,
    2006,
    the
    Illinois
    Environmental
    Protection
    Agency
    (“IEPA”)
    issued
    Violation
    Notice
    A-2005-00281
    to
    Royal,
    alleging
    a
    violation
    of 35
    Ill.
    Adm.
    Code
    §215.301,
    which
    states
    in
    part that
    “[njo
    person
    shall
    cause
    or
    allow
    the discharge
    of
    more
    than
    3.6
    kg/hr
    (8
    lbs/br)
    of
    organic
    material
    into
    the
    atmosphere
    from any
    emission
    source.”
    This
    section
    is
    commonly
    known
    as
    the
    “8
    lb/hr
    Rule.”
    3.
    Royal
    determined
    that,
    based
    on
    IEPA’s
    strict
    hourly
    interpretation
    of
    demonstrating
    compliance
    with
    the
    8
    lb/hr
    Rule,
    the
    hourly
    volatile
    organic
    material
    (“VOM”)
    emissions
    from certain
    of
    its
    operations
    did
    not
    appear
    to
    comply
    with
    IEPA’
    s
    interpretation
    of
    the
    rule.
    Royal
    also
    realized
    that
    the
    costs
    associated
    with
    add-on
    controls
    and/or
    changing
    manufacturing
    procedures
    and methods
    were
    neither
    economically
    nor
    technologically
    viable,
    and
    could
    require
    the
    closure
    of
    the
    Dix
    Plant.
    4.
    However,
    Royal
    is
    subject
    to,
    and in
    compliance
    with,
    the National
    Emission
    Standard
    for Hazardous
    Air
    Pollutants
    for
    Reinforced
    Plastic
    Composite
    Manufacturing
    Facilities,
    found
    at
    40
    C.F.R.
    Part
    63
    Subpart
    WWWW
    (the
    “Composites
    MACT”).
    5.
    Royal
    met
    with
    IEPA
    and
    presented
    evidence
    demonstrating
    why
    requiring
    Royal’s
    compliance
    with
    the
    8
    lb/hr
    Rule
    on
    a
    strict
    hourly
    basis
    is
    unreasonable,
    especially
    considering
    Royal’s
    overall
    VOM
    emissions
    and
    the
    limited
    amount
    of
    time
    that
    Royal’s
    operations
    exceed
    the
    8
    lb/br
    Rule.
    After
    hearing
    and
    considering
    the
    information
    presented
    by
    Royal,
    IEPA
    agreed
    that
    applying
    the
    8
    lb/hour
    Rule
    to
    Royal’s
    operations
    on
    a
    strict
    hourly
    basis
    would
    indeed
    impose
    an
    unreasonable
    burden.
    Consequently,
    Royal
    has concluded
    to
    petition
    the
    Illinois
    Pollution
    Control
    Board
    for
    an
    adjusted
    standard.

    6.
    Royal
    believes that
    its
    proposed
    adjusted
    standard
    is
    reasonable
    given
    that:
    (a)
    Royal’s
    VOM
    emissions
    meet
    the emissions
    limitations
    of the
    Composites
    MACT;
    (b)
    Royal’s
    proposed
    adjusted
    standard
    will
    not result
    in adverse
    environmental
    or
    health effects;
    and
    (c)
    IPCB
    has
    granted petitions
    for
    adjusted
    variances
    in situations
    similar
    to this
    in the
    past,
    notably
    in the
    petition
    of
    Crownline
    Boats, Inc.
    See Opinion
    and
    Order
    of the Illinois
    Pollution
    Control
    Board,
    In re:
    Crownline
    Boats,
    Inc.,
    Docket
    No. AS 04-01
    (July 22,
    2002).
    7.
    Royal
    believes
    that
    the
    information
    necessary
    for
    the
    Board to proceed
    with
    its
    review
    of
    this
    matter
    is
    contained
    in Royal’s
    petition.
    If more
    information
    is needed,
    Royal
    will
    fully
    cooperate
    to expeditiously
    provide
    such
    information
    to the Board
    and its hearing
    officer.
    8.
    This motion
    for
    expedited
    review
    is
    being
    filed
    at
    the
    request
    of Royal
    to
    allow
    Royal
    to
    continue
    operations
    in
    the state of
    Illinois
    without
    concern for
    IEPA
    intervention.
    WHEREFORE,
    Royal
    respectfully
    requests
    that
    the Board
    grant
    this
    motion and
    expedite
    review
    of
    its
    petition
    for
    adjusted
    standard.
    Respectfully
    submitted,
    BRYAN
    CAVE LLP
    By:
    Dale
    D
    A.
    Guariglia,
    MissouK
    Bar
    # 32998
    Brandon
    W. Neuschafer,
    Missouri
    Bar
    #53232
    One
    Metropolitan
    Square
    211 N.
    Broadway,
    Suite 3600
    St. Louis,
    Missouri
    63102
    Telephone:
    (314) 259-2000
    Telefax:
    (314)
    259-2020
    Attorneys
    for Royal Fiberglass
    Pools,
    Inc.

    CERTIFICATE
    OF
    SERVICE
    The
    undersigned
    certifies
    that
    a
    copy
    of
    the
    foregoing
    motion
    was served
    upon
    the
    following
    parties
    on
    the
    31st
    day
    of
    March,
    2009:
    Illinois
    Pollution
    Control
    Board,
    Attn:
    Clerk
    100
    West
    Randolph
    Street
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    Chicago,
    IL
    60601-3218
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    Attn:
    Charles
    Matoesian

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    flSl
    THE
    MATTER
    OF:
    )
    )
    Petition
    of
    Royal
    Fiberglass
    Pools,
    Inc.
    )
    for
    an
    Adjusted
    Standard
    from
    )
    35IAC215.30l
    )
    MOTION
    FOR
    ADMISSION
    PRO
    HAC
    VICE
    ON
    BEHALF
    OF
    ROYAL
    FIBERGLASS
    POOLS,
    INC.
    COMES
    NOW,
    Dale
    A. Guariglia,
    of
    the
    law
    firm
    of
    Bryan
    Cave
    LLP,
    and
    pursuant
    to
    Section
    101.400
    of
    the
    Rules
    of
    the
    Illinois
    Pollution
    Control
    Board,
    files
    this
    Motion
    for
    Admission
    Pro
    Hac
    Vice
    in
    this
    matter
    on behalf
    of
    Royal
    Fiberglass
    Pools,
    Inc..
    In
    support
    of
    this
    Motion,
    Dale
    A.
    Guariglia
    states
    as
    follows:
    1.
    Dale
    A.
    Guariglia
    is
    in
    good
    standing
    and admitted
    to
    practice
    before
    all
    state
    courts
    in
    the
    State
    of
    Missouri.
    Respectfully
    submitted,
    BRYAN
    AVE
    LLP
    By:
    Dale
    A:
    Guariglia,
    Missouri
    Bar
    #32998
    One
    Metropolitan
    Square
    211
    N.
    Broadway,
    Suite
    3600
    St.
    Louis,
    MO
    63
    102-2750
    Telephone:
    (314)
    259-2000
    Telefax:
    (314)
    259-2020
    Attorney
    for
    Royal
    Fiberglass
    Pools,
    Inc.
    AS-
    (Adjusted
    Standard)
    RCEV
    CLERKS
    OFRCE
    APR
    03
    2009
    STATE OF
    ILLINOIS
    Pollution
    Control
    Board
    2416020.1

    CERTIFICATE
    OF
    SERVICE
    The
    undersigned
    certifies
    that
    a
    copy
    of
    the
    foregoing
    motion
    was
    served
    upon
    the
    following
    parties
    on
    the
    31st
    day
    of
    March,
    2009:
    Illinois
    Pollution
    Control
    Board,
    Attn:
    Clerk
    100
    West
    Randolph
    Street
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    Chicago,
    IL
    60601-3218
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand
    Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    Attn:
    Charles
    Matoesian
    rz
    2416020.1

    MOTION
    FOR
    ADMISSION
    PRO
    HAC
    VICE
    ON
    BEHALF
    OF
    ROYAL
    FIBERGLASS
    POOLS,
    INC.
    COMES
    NOW,
    Brandon
    W.
    Neuschafer,
    of
    the
    law
    firm
    of
    Bryan
    Cave
    LLP,
    and
    pursuant
    to
    Section
    101.400
    of
    the
    Rules
    of
    the
    Illinois
    Pollution
    Control
    Board,
    files
    this
    Motion
    for
    Admission
    Pro
    Hac
    Vice
    in
    this
    matter
    on
    behalf
    of
    Royal
    Fiberglass
    Pools,
    Inc..
    In
    support
    of
    this
    Motion,
    Brandon
    W.
    Neuschafer
    states
    as
    follows:
    1.
    Brandon
    W.
    Neuschafer
    is
    in
    good
    standing
    and
    admitted
    to
    practice
    before
    all
    state
    courts
    in
    the
    State
    of
    Missouri.
    Respectfully
    submitted,
    BRYAN
    VELLP
    By:
    4
    don
    schafea53232
    One
    Metropolitan
    Square
    211
    N.
    Broadway,
    Suite
    3600
    St.
    Louis,
    MO
    63102-2750
    Telephone:
    (314)
    259-2000
    Telefax:
    (314)
    259-2020
    Attorney
    for
    Royal
    Fiberglass Pools,
    Inc.
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    iN
    THE
    MATTER
    OF:
    )
    I
    ECEUVE
    CLERK’S
    OFFICE
    )
    Petition
    of
    Royal
    Fiberglass
    Pools,
    Inc.
    )
    AS-
    DL1i’
    APR
    032009
    for
    an
    Adjusted
    Standard
    from
    )
    (Adjusted
    Standrd)
    35
    IAC
    §
    215.301
    )
    Pollution
    STATE
    OF
    Control
    IWNOIS
    Board
    2524351.1

    CERTIFICATE
    OF
    SERVICE
    The
    undersigned
    certifies
    that
    a
    copy of
    the
    foregoing
    motion
    was
    served
    upon
    the
    following
    parties
    on
    the
    31St
    day
    of
    March,
    2009:
    Illinois
    Pollution
    Control
    Board,
    Attn:
    Clerk
    100
    West
    Randolph
    Street
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    Chicago,
    IL 60601-3218
    Division
    of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    1021
    North
    Grand Avenue
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    Attn:
    Charles
    Matoesian
    2524351.1

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