BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    TN
    THE
    MATTER
    OF:
    )
    I
    R9
    AMENDMENTS
    TO 35 ILL.
    ADM.
    CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    STANDARDS
    FOR
    THE CHICAGO
    AREA,
    )
    35 ILL.
    ADM.
    CODE
    219,
    ORGANIC
    )
    RKs
    OFFICE
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    )
    JUL
    (1
    )f(39
    THE
    METRO EAST
    AREA,
    AND
    )
    35
    ILL.
    ADM. CODE
    211
    )
    CO)tIol
    Board
    TABLE
    OF CONTENTS
    1.
    Notice of
    Filing
    2.
    Appearances
    of Dana
    Vetterhoffer,
    Assistant
    Counsel for
    the
    Illinois
    Environmental
    Protection
    Agency,
    and
    John
    Kim, Chief
    Legal
    Counsel
    for the Illinois
    Environmental
    Protection
    Agency
    3.
    Proposal of
    Regulations
    by
    Director
    Douglas
    P. Scott
    4.
    Certification
    of Required
    Rule
    5.
    Certification
    of Origination
    6.
    Agency
    Analysis
    of Economic
    and
    Budgetary
    Effects
    7.
    Motion
    for
    Waiver
    of
    Requirements
    8.
    Statement
    of
    Reasons
    9.
    ProposedAmendmentsto
    35111.
    Adm.
    Code Parts
    211, 218,
    and 219
    10.
    Technical Support
    Document
    for Controlling
    VOM
    Emissions
    from
    Lithographic
    Printing,
    Letterpress
    Printing,
    Flexible
    Package
    Printing,
    Flat Wood
    Paneling
    Coating,
    and Industrial
    Cleaning
    Operations,
    Illinois
    Environmental
    Protection
    Agency,
    June
    2009
    11.
    Documents
    Relied
    Upon:
    Control
    Techniques
    Guidelines
    for Offset
    Lithographic
    Printing
    and
    Letterpress
    Printing,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air
    Quality
    Planning
    and Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2006.
    1

    Control Techniques
    Guidelines
    for
    Flexible
    Package
    Printing,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air Quality
    Planning
    and Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2006.
    Control
    Techniques
    Guidelines:
    Industrial
    Cleaning
    Solvents,
    United
    States
    Environmental
    Protection
    Agency,
    Office of Air
    Quality
    Planning
    and
    Standards,
    Research
    Triangle
    Park,
    NC, September
    2006.
    Control
    Techniques
    Guidelines
    for
    Flat
    Wood
    Paneling
    Coatings,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air Quality
    Planning
    and Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2006.
    Technical
    Support
    Document
    for Controlling
    VOM
    Emissions
    from Lithographic
    Printing
    Operations,
    Illinois
    Environmental
    Protection
    Agency,
    Air
    Quality
    Planning
    Section,
    Springfield,
    IL,
    October
    1994.
    Control
    Techniques
    Guideline
    Series:
    Control
    of
    Volatile
    Organic
    Compound
    Emissions
    from
    Offset Lithographic
    Printing
    (DRAFT),
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air
    Quality
    Planning
    and Standards,
    Research
    Triangle
    Park,
    NC,
    September
    1993.
    Control
    ofvolatile
    organic
    compound
    emissions
    from
    industrial
    solvent
    cleaning
    operations
    (Proposed),
    Ohio
    Administrative
    Code
    3745-21-23
    (February
    2, 2009).
    12. Motion
    for Expedited
    Review
    13. Certificate
    of Service
    14. Notices
    of
    Proposed Amendments
    15. Disk in
    Microsoft
    WORD
    containing
    Agency’s
    Proposed
    Amendments
    to Parts
    211,
    218,
    and
    219,
    and Notices
    of Proposed
    Amendments.
    2

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    TN
    THE
    MATTER
    OF:
    AMENDMENTS
    TO
    35
    ILL.
    AIIM.
    CODE
    218,
    ORGANIC MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    CHICAGO AREA,
    35
    ILL.
    ADM.
    CODE
    219,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    METRO EAST
    AREA, AND
    35
    ILL.
    ADM.
    CODE
    211
    To:
    John
    Therriault,
    Assistant
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    100
    West
    Randolph,
    Suite
    11-500
    Chicago,
    Illinois
    60601-3218
    NOTICE
    JUL
    U
    9
    20Q9
    STATE
    oiiutj,,
    Matthew
    Dunn,
    Chief
    Division
    of
    Environmental
    Enforcement
    Office
    of
    the Attorney
    General
    188
    West
    Randolph,
    20t
    Floor
    Chicago,
    IL
    60601
    Virginia
    Yang
    Deputy
    Legal
    Counsel
    Illinois
    Department
    of Natural Resources
    One
    Natural
    Resources
    Way
    Springfield,
    IL
    62702
    PLEASE
    TAKE
    NOTICE
    that
    I
    have
    today
    filed with
    the
    Office
    of the
    Pollution
    Control
    Board
    the
    REGULATORY
    PROPOSAL entitled
    “AMENDMENTS
    TO
    35
    ILL. ADM.
    CODE
    218,
    ORGANIC MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    35
    ILL.
    ADM.
    CODE
    219,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    METRO
    EAST
    AREA, AND
    35
    ILL.
    ADM.
    CODE
    211,”
    MOTION
    FOR
    WAIVER,
    MOTION
    FOR
    EXPEDITED
    REVIEW,
    and APPEARANCES
    of the
    Illinois
    Environmental
    Protection
    Agency,
    a
    copy
    of
    which
    is herewith
    served
    upon
    you.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana
    Vetterhoffer
    //
    Assistant
    Counsel
    Division
    of Legal
    Counsel
    )
    (Rulemaking-Air)
    )
    )
    )
    )
    )
    )

    DATED:
    Ju’y
    8,
    2009
    1021 N.
    Grand
    Ave.
    East
    P.O.
    Box 19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544
    THIS
    FILING
    IS
    SUBMITTED
    ON
    RECYCLED
    PAPER

    BEFORE THE ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN THE
    MATTER OF:
    )
    R9’
    AMENDMENTS TO
    35 ILL. ADM. CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC MATERIAL
    EMISSION
    )
    STANDARDS
    FOR THE CHICAGO
    AREA,
    )
    35 ILL. ADM.
    CODE
    219,
    ORGANIC
    )
    FICE
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    )
    JUL
    (19
    2009
    THE METRO
    EAST AREA, AND
    )
    35 ILL.
    ADM.
    CODE
    211
    )
    PotId
    APPEARANCE
    The undersigned hereby
    enters
    her
    appearance
    as an
    attorney
    on behalf
    of
    the
    Illinois
    Environmental
    Protection
    Agency.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana Vetterhoffer
    //
    Assistant
    Counsel
    Division
    of Legal
    Counsel
    DATED: July 8,
    2009
    1021 N.
    Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544

    BEFORE THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    AMENDMENTS
    TO 35
    ILL.
    ADM.
    CODE
    218,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    35
    ILL. ADM.
    CODE
    219,
    ORGANIC
    MATERIAL EMISSION
    STANDARDS
    FOR
    THE
    METRO EAST
    AREA,
    AND
    35
    ILL.
    ADM.
    CODE
    211
    JUL.
    9
    2Uo
    DATED:
    July
    8,
    2009
    1021
    N.
    Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield, IL
    62794-9276
    (217)
    782-5544
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION A
    Chief
    Legal
    Counsel
    Division
    of
    Legal
    Counsel
    L0
    )
    (Rulemaking-Air)
    )
    )
    )
    )
    )
    )
    APPEARANCE
    The
    undersigned hereby
    enters
    his
    appearance
    as
    an
    attorney
    on behalf
    of
    the
    Illinois
    Environmental Protection Agency.
    By:

    BEFORE THE ILLINOIS
    POLLUTION
    CONTROL BOARD
    IN THE MATTER OF:
    AMENDMENTS TO 35 ILL. ADM. CODE 218,
    )
    (Rulemaking-Air)
    ORGANIC MATERIAL EMISSION
    )
    STANDARDS FOR THE CHICAGO AREA,
    )
    CLE,
    01
    D
    35
    ILL.
    ADM. CODE
    219,
    ORGANIC
    )
    MATERIAL
    EMISSION
    STANDARDS FOR
    )
    uL
    09
    jJfJ9
    35
    THE
    ILL.
    METRO
    ADM.
    EASTCODEAREA,
    211
    AND
    ))
    POllutionSTATE
    OF
    Control
    ILLINOiS
    Board
    ILLINOIS ENVIRONMENTAL
    PROTECTION
    AGENCY PROPOSAL
    OF
    REGULATIONS
    The Illinois Environmental
    Protection
    Agency moves
    that the Illinois Pollution
    Control
    Board adopt the attached regulations.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION AGENCY
    By:
    /i.&3
    Of
    2
    C’
    Dou
    as P. Scott
    Director
    DATED: June
    29
    , 2009
    1021 N.
    Grand Ave. East
    P.O.
    Box 19276
    Springfield,
    IL 62794-9276
    (217)
    782-5544

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    O6
    R9
    AMENDMENTS
    TO
    35
    ILL.
    ADM.
    CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    R
    E
    C
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    )
    CLERKIcYP
    35
    ILL.
    ADM.
    CODE
    219,
    ORGANIC
    )
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    )
    JUL
    0
    2009
    THE
    METRO
    EAST
    AREA,
    AND
    )
    STATE
    OF
    ILUNOIS
    35
    ILL.
    ADM.
    CODE
    211
    )
    Pollutbn
    Control
    Board
    CERTIFICATION
    OF
    REQUIRED
    RULE
    The
    Illinois
    Environmental
    Protection
    Agency
    certifies
    in
    accordance
    with
    35
    Iii.
    Adm.
    Code102.202(h)
    and
    102.500,
    and
    415
    ILCS
    5/28.2(b),
    that
    it
    believes
    that
    this
    proposal
    for
    amendments
    to
    35
    Ill.
    Adm.
    Code
    211,
    218,
    and
    219
    is
    a
    federally
    required
    rule
    under
    Sections
    172(c)(1)
    and
    182(b)(2)
    of
    the
    Clean
    Air
    Act
    (“CAA”).
    42
    U.S.C.
    §
    7502(c)(1)
    and
    751
    1a(b)(2).
    The
    proposal
    for
    amendments
    is
    needed
    to
    satisfy
    Illinois’
    obligation
    to
    submit
    a
    State
    Implementation
    Plan
    (“SIP”)
    for
    sources
    of
    volatile
    organic
    materials
    (“VOM”)
    emissions
    in
    areas
    designated
    as
    nonattainment
    with
    respect
    to
    the
    ozone
    National
    Ambient
    Air
    Quality
    Standard
    (“NAAQS”).
    Section
    172(c)(1)
    of
    the
    CAA
    provides
    that
    states
    must
    include
    in
    their
    SIPs
    for
    nonattainment
    areas
    “reasonably
    available
    control
    measures,”
    including
    “reasonably
    available
    control
    technology”
    (“RACT”),
    for
    sources
    of
    emissions.
    42
    U.S.C.
    §
    7502(c)(1).
    Section
    1
    82(b)(2)
    of
    the
    CAA
    provides
    that,
    for
    ozone
    nonattainment
    areas,
    the
    State
    must
    revise
    its
    SIP
    to
    include
    RACT
    for
    sources
    of
    VOM
    emissions
    covered
    by
    a
    control
    techniques
    guideline
    (“CTG”)
    issued
    between
    November
    15,
    1990,
    and
    the
    date
    of
    attainment.
    42
    U.S.C.
    §
    751
    la(b)(2).

    The
    proposed
    amendments
    are
    intended
    to establish
    RACT
    requirements
    for
    Group
    II
    Consumer
    and
    Commercial Product
    categories
    in response
    to
    CTGs
    issued
    by
    the United
    States
    Environmental Protection
    Agency
    for
    such
    categories,
    and
    thereby
    satisfy
    the CAA
    requirements
    described
    above.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    E2-
    Dana Vetterhoffer
    //
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    DATED:
    July 8,
    2009
    1021 N.
    Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    R9
    AMENDMENTS
    TO
    35 ILL.
    ADM.
    CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    )
    35
    ILL.
    ADM.
    CODE 219,
    ORGANIC
    )
    CLp<s
    MATERIAL
    EMISSION
    STANDARDS
    THE
    FOR
    )
    JUL
    u
    i
    METRO
    EAST
    AREA,
    AND
    )
    2Ug
    35
    ILL.
    ADM.
    CODE
    211
    )
    p,TtV
    ;‘ois
    CERTIFICATION
    OF
    ORIGINATION
    The
    Illinois
    Environmental
    Protection
    Agency
    certifies
    in
    accordance
    with
    35
    Ill.
    Adm.
    Code
    102.202(i)
    that
    this
    proposal
    for
    amendments
    to
    35
    Iii.
    Adm.
    Code
    211,
    218,
    and
    219
    amends
    the most
    recent
    version
    of
    the
    rules
    as
    published
    on the
    Illinois
    Pollution
    Control
    Board’s
    website.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana
    Vetterhoffer//
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    DATED:
    July
    8,
    2009
    1021
    N. Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544

    Agency
    Analysis
    of
    Economic
    and
    Budgetary
    Effects
    of
    Proposed
    Rulemaking
    Agency:
    Illinois
    Pollution Control
    Board
    Part/Title:
    Definitions
    and General Provisions
    (35 Ill. Adm.
    Code Part
    211)
    JUL
    U
    9
    2(109
    ..,
    Poiij
    01
    sTATE
    ILLINO,5
    Illinois
    Register Citation:
    Ofltrol
    Please
    attempt
    to provide as dollar-specific
    responses
    as possible
    and feel free to
    add any relevant
    explanation.
    Anticipated
    effect
    on State expenditures
    and revenues.
    (a)
    Current
    cost to the agency for
    this program/activity.
    $
    0 per year
    (approximately)
    (b)
    If this rulemaking
    will result in an increase
    or decrease
    in
    cost,
    specif’
    the
    fiscal year in
    which this
    change will first occur and
    the dollar
    amount of the effect.
    N/A
    (c)
    Indicate the funding
    source, including
    Fund
    and
    appropriation lines,
    for this
    program/activity.
    N/A
    (d)
    If an increase
    or decrease in
    the costs
    of another
    State agency
    is anticipated, specif’
    the
    fiscal
    year in which this
    change will first
    occur and the estimated
    dollar amount
    of the
    effect.
    N/A
    (e)
    Will this rulemaking
    have any
    effect on State revenues
    or expenditures
    not already
    indicated
    above?
    No
    2.
    Economic effect on
    persons affected
    by
    the
    rulemaking:
    (a)
    Indicate
    the economic effect
    and
    specifi the
    persons affected:
    Positive
    Negative
    No effect
    X
    Persons
    affected:
    Owners
    and operators
    of
    affected
    lithographic printers,
    letterpress
    printers, flexible package
    printers,
    flat
    wood
    paneling coaters, and
    sources
    using
    industrial cleaning
    solvents.
    Dollar
    amount per person:
    0
    Total statewide cost:
    0
    (b)
    If an economic
    effect is predicted,
    please
    briefly describe
    how
    the effect
    will occur.
    N/A

    (c)
    Will
    the rulemaking
    have
    an
    indirect
    effect
    that
    may
    result
    in
    increased
    administrative
    costs?
    No
    Will there
    be
    any
    change
    in
    requirements
    such as
    filing,
    documentation,
    reporting
    or completion
    of forms?
    No
    The
    proposed
    changes
    to
    Part
    211
    should
    have no
    indirect
    effect
    that may
    result
    in
    increased
    administrative
    costs.

    Agency
    Analysis
    of Economic
    and
    Budgetary
    Effects
    of
    Proposed
    Rulemaking
    Agency:
    illinois
    Pollution
    Control
    Board
    Part/Title:
    Organic
    Material
    Emission
    Standards
    and
    Limitations
    for
    the Chicago
    Area
    (35
    UI.
    Adm.
    Code
    Part
    218)
    illinois
    Register
    Citation:
    Please
    attempt
    to provide
    as
    dollar-specific
    responses
    as possible
    and
    feel free
    to add
    any relevant
    explanation.
    Anticipated
    effect
    on
    State expenditures
    and
    revenues.
    (a)
    Current
    cost
    to
    the
    agency
    for
    this
    program/activity.
    --S50,300
    per year
    (b)
    If
    this rulemaking
    will
    result
    in an increase
    or decrease
    in cost,
    specify
    the
    fiscal
    year in
    which this
    change
    will
    first
    occur
    and
    the dollar
    amount
    of
    the
    effect.
    N/A
    (c)
    Indicate
    the
    funding
    source,
    including
    Fund
    and appropriation
    lines,
    for
    this
    program/activity.
    N/A
    (d)
    If an
    increase
    or decrease
    in the
    costs
    of another
    State
    agency
    is anticipated,
    specify
    the
    fiscal year
    in
    which this
    change
    will
    first occur
    and
    the
    estimated
    dollar
    amount
    of
    the
    effect.
    N/A
    (e)
    Will this
    rulemaking
    have
    any
    effect
    on
    State
    revenues
    or
    expenditures
    not
    already
    indicated
    above?
    No
    2.
    Economic
    effect
    on persons
    affected
    by the
    rulemaking:
    (a)
    Indicate
    the
    economic
    effect
    and
    specify
    the persons
    affected:
    Positive
    Negative
    X
    No effect
    Persons
    affected:
    See list
    of potentially
    affected
    sources
    in
    TSD.
    Dollar
    amount
    per person:
    Affected
    lithographic
    printers:
    $0-85
    5/ton
    Affected
    letterpress
    printers:
    $0-855/ton
    Affected
    flexible
    package
    printers:
    $0-2800/ton
    Affected
    flat
    wood
    paneling
    coaters:
    $0-2600/ton
    Affected
    industrial
    cleaning
    solvent
    users:
    Probable
    cost
    savings
    Total
    statewide
    cost:
    Affected
    lithographic
    printers:
    $3
    08/day
    Affected
    letterpress
    printers:
    $4/day

    Affected
    flexible
    package
    printers:
    $84/day
    Affected
    flat
    wood
    paneling
    coaters:
    $13
    0/day
    Affected industrial
    cleaning solvent
    users:
    Probable cost
    savings
    (b)
    If
    an
    economic
    effect
    is
    predicted,
    please
    briefly
    describe
    how the effect
    will
    occur. Costs
    due to
    control
    measures
    for
    newly-affected
    sources, as
    described
    inTSD.
    (c)
    Will
    the
    rulemaking
    have an
    indirect
    effect
    that
    may
    result
    in increased
    administrative
    costs?
    Will
    there be
    any change
    in
    requirements
    such
    as
    filing, documentation,
    reporting
    or completion
    of
    forms?
    The rulemaking
    will require
    a smallamount
    of
    additional
    reporting
    but
    should
    have no
    more
    than a
    negligible
    indirect
    effect
    that may
    result
    in
    increased
    administrative
    costs.

    Agency
    Analysis of
    Economic and
    Budgetary
    Effects of Proposed Rulemaking
    Agency:
    Illinois Pollution
    Control Board
    Part/Title:
    Organic Material Emission
    Standards
    and Limitations for the Metro East Area
    (35 Ill. Adm.
    Code Part 219)
    Illinois
    Register Citation:
    Please attempt to
    provide as dollar-specific
    responses as possible and feel free to add
    any
    relevant
    explanation.
    Anticipated
    effect on State expenditures
    and
    revenues.
    (a)
    Current cost to the
    agency for this program/activity.
    —$5,50O
    per year
    (b)
    If this rulemaking will
    result in an increase or decrease in cost,
    specify the
    fiscal
    year in which this change will first occur and the
    dollar
    amount of the effect.
    N/A
    (c)
    Indicate the
    funding source, including Fund and appropriation lines, for this
    program/activity.
    N/A
    (d)
    If
    an increase
    or decrease in the
    costs
    of another State agency is anticipated,
    specifi the fiscal year in which this change will
    first
    occur and the estimated
    dollar amount of
    the effect. N/A
    (e)
    Will this rulemaking have any effect on State revenues or expenditures
    not
    already indicated
    above?
    No
    2.
    Economic effect on persons affected
    by
    the rulemaking:
    (a)
    Indicate the economic
    effect and
    specify
    the persons affected:
    Positive
    Negative X
    No effect
    Persons affected: See
    list
    of potentially affected sources
    in TSP.
    Dollar amount
    per
    person:
    Affected
    lithographic
    printers:
    $0-85
    5/ton
    Affected
    letterpress
    printers:
    $0
    (no
    affected
    sources)
    Affected flexible
    package
    printers:
    $0
    (no affected
    sources needing add-on
    control
    modification)
    Affected flat wood paneling coaters:
    $0
    (no
    affected
    sources)
    Affected industrial cleaning solvent users: Probable
    cost savings
    Total statewide
    cost:
    Affected lithographic printers: $6/day

    Affected
    letterpress
    printers:
    $0
    (no affected
    sources)
    Affected
    flexible
    package printers:
    $0
    (no affected
    sources
    needing
    add-on
    control
    modification)
    Affected
    flat
    wood paneling
    coaters:
    $0 (no
    affected
    sources)
    Affected
    industrial
    cleaning
    solvent users:
    Probable
    cost
    savings
    (b)
    If
    an
    economic
    effect
    is predicted,
    please
    briefly
    describe
    how
    the
    effect
    will
    occur.
    Costs
    due to
    control measures
    for
    newly-affected
    sources,
    as described
    in TSD.
    (c)
    Will
    the rulemaking
    have
    an indirect
    effect
    that may
    result
    in
    increased
    administrative
    costs?
    Will
    there
    be
    any change
    in requirements
    such
    as
    filing, documentation,
    reporting
    or completion
    of
    forms?
    The
    rulemaking
    will
    require
    a
    small
    amount of
    additional reporting
    but
    should have
    no more
    than
    a
    negligible
    indirect
    effect
    that
    may result
    in
    increased
    administrative
    costs.

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    R€Y9
    AMENDMENTS
    TO
    35
    ILL.
    ADM.
    CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    STANDARDSFORTHECHICAGOAREA,
    )
    35
    ILL.
    ADM.
    CODE
    219,
    ORGANIC
    )
    CLERKS
    OFFICE
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    )
    JUL
    n
    THE
    METRO
    EAST
    AREA,
    AND
    )
    ‘‘
    2O9
    35
    ILL.
    ADM.
    CODE
    211
    )
    STATE
    OF
    ILLINOIS
    Pollutgon
    Control
    8orj
    MOTION
    FOR
    WAIVER
    OFREQUIREMENTS
    The
    Proponent,
    theIllinois
    Environmental
    Protection
    Agency
    (“Illinois
    EPA”),
    by
    its
    attorney,
    and
    pursuant
    to
    35111.
    Adm.
    Code
    101.500,102.110,
    102.200,
    and
    102.402,
    respectfully
    moves
    that
    the
    Illinois
    Pollution
    Control
    Board
    (“Board”)
    waive
    the
    requirement
    that
    the
    Illinois
    EPA
    submitthe
    original
    and
    nine
    copies
    of
    the
    regulatory
    proposal
    including
    all
    documents
    relied
    upon.
    In
    support
    of
    its
    Motion,
    Illinois
    EPA
    states
    as
    follows:
    1.
    Section
    102.200
    of
    the
    Board’s
    procedural
    rules
    requires
    that
    the
    original
    and
    nine
    copies
    of
    each
    regulatory
    proposal
    be
    filed
    with
    the
    Clerk.
    2.
    Section
    27(a)
    of
    the
    Environmental
    Protection
    Act
    (“Act”)
    requires
    that
    the
    Illinois
    EPA
    provide
    information
    supporting
    the
    proposal.
    415
    ILCS
    5/27(a).
    In
    doing
    so,
    the
    Illinois
    EPA
    has
    provided
    documents
    which
    were
    directly
    relied
    upon
    when
    drafting
    the
    regulatory
    proposal.
    The
    documents
    relied
    upon
    are
    as
    follows:
    a.
    Control
    Techniques
    Guidelines
    for
    Offset
    Lithographic
    Printing
    and
    Letterpress
    Printing,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of
    Air
    Quality
    Planning
    and
    Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2006.
    b.
    Control
    Techniques
    Guidelines
    for
    Flexible
    Package
    Printing,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of
    Air
    Quality
    Planning
    and
    Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2006.
    1

    c.
    Control
    Techniques
    Guidelines:
    Industrial
    Cleaning
    Solvents,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air
    Quality
    Planning
    and
    Standards,
    Research Triangle
    Park,
    NC,
    September
    2006.
    d.
    Control
    Techniques
    Guidelines
    for
    Flat
    Wood
    Paneling
    Coatings,
    United
    States
    Environmental Protection Agency,
    Office
    of
    Air
    Quality
    Planning
    and
    Standards,
    Research Triangle
    Park,
    NC,
    September
    2006.
    e.
    Technical
    Support
    Document
    for
    Controlling
    VOM
    Emissions
    from
    Lithographic
    Printing Operations,
    Illinois
    Environmental
    Protection
    Agency,
    Air
    Quality
    Planning
    Section,
    Springfield,
    IL,
    October
    1994.
    f
    Control
    Techniques
    Guideline Series:
    Control
    of
    Volatile
    Organic
    Compound
    Emissions
    from
    Offset
    Lithographic
    Printing
    (DRAFT),
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of
    Air
    Quality Planning
    and
    Standards,
    Research
    Triangle
    Park,
    NC,
    September
    1993.
    g.
    Control
    of
    volatile
    organic
    compound
    emissions
    from
    industrial
    solvent
    cleaning
    operations
    (Proposed),
    Ohio
    Administrative
    Code
    3745-21-23
    (February
    2, 2009).
    3.
    This
    entire
    regulatory
    proposal
    consists
    of over
    700
    pages.
    Given
    the
    length
    of the
    proposal
    and
    the
    resources required
    to
    provide
    nine
    copies,
    Illinois
    EPA
    requests
    that
    the
    Board
    waive
    the normal
    copy
    requirements
    and
    allow
    Illinois
    EPA
    to
    file
    the
    original
    and
    four
    complete
    copies
    of
    the
    documents.
    WHEREFORE,
    the
    Illinois
    EPA
    moves
    that
    the Board
    waive
    the copy
    requirement
    and
    allow
    the
    Illinois
    EPA
    to
    provide
    the
    Board
    with
    an
    original
    and
    four
    copies
    of
    the proposal
    and
    the
    documents
    relied
    upon
    in
    the
    development
    of the
    proposal,
    as
    listed
    above.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:c.
    Dana
    Vetterhoffer/
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    2

    DATED:
    July
    8,
    2009
    1021
    N.
    Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544
    3

    BEFORE THE ILLINOIS
    POLLUTION
    CONTROL BOARD
    N
    THE
    MATTER
    OF:
    )
    4
    R9
    AMENDMENTS TO 35 ILL.
    ADM.
    CODE 218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL EMISSION
    )
    STANDARDS FOR THE CHICAGO AREA,
    )
    35 ILL. ADM. CODE 219, ORGANIC
    )
    MATERIAL EMISSION STANDARDS FOR
    )
    THE METRO EAST AREA, AND
    )
    JUL.
    ii
    &
    35 ILL. ADM. CODE
    211
    sr
    PoIIu’Tc
    OS
    STATEMENT
    OF REASONS
    I.
    INTRODUCTION
    The
    Illinois Environmental Protection
    Agency (“Illinois EPA”) submits this
    Statement
    of Reasons to the Illinois Pollution
    Control
    Board (“Board”) pursuant to
    Sections 27 and 28 of the
    Environmental
    Protection
    Act (“Act”) (415 ILCS 5/27 and 28)
    and 35 Ill. Adm. Code
    102.202 in support
    of the attached proposal of regulations.
    These
    regulations are proposed to control emissions of
    Volatile Organic Material (“VOM”),
    which is
    effectively the same as volatile
    organic
    compounds (“VOC”), from the
    following Group II
    Consumer and Commercial
    Product Categories: Industrial Cleaning
    Solvents, Flat
    Wood Paneling Coatings,
    Flexible Packaging Printing Materials,
    Lithographic Printing
    Materials, and
    Letterpress Printing Materials.
    This proposed
    rulemaking
    is intended to meet certain
    obligations of the State
    of
    Illinois
    under the federal Clean Air Act
    (“CAA”),
    42
    U.S.C.
    §
    7401 et seq.
    Specifically,
    the
    rulemaking is intended
    to satisfy
    Illinois’ obligation to submit
    a State Implementation
    Plan (“SIP”)
    to address requirements under Sections 172
    and 182 of the CAA
    for
    sources
    of
    VOM
    emissions in areas designated as
    nonattainment with respect to the
    ozone
    National
    Ambient Air Quality Standard
    (“NAAQS”) See 42
    U.S.C.
    §
    7502
    and
    7511a.
    1

    Section 1 72(c)(1)
    of
    the
    CAA
    provides
    that
    states
    must
    include
    in their
    SIPs for
    nonattainment
    areas “reasonably
    available control
    measures”
    (“RACM”),
    including
    “reasonably
    available
    control technology”
    (“RACT”),
    for sources of emissions.
    42
    U.S.C.
    §
    7502(c)(l).
    Section 182(b)(2)
    of the CAA provides
    that,
    for
    ozone
    nonattainment
    areas, the
    State must
    revise its SIP to include
    RACT for sources
    of VOC emissions
    covered by a control techniques
    guideline (“CTG”)
    issued
    between November
    15, 1990,
    and the date
    of
    attainment.
    42
    U.S.C.
    §
    7511a(b)(2).
    Illinois
    is
    proposing
    reasonable and
    cost
    effective
    VOM controls
    for Group II
    Consumer
    and
    Commercial
    Product
    Categories in response
    to
    CTGs
    issued for
    such
    categories. Included
    in this proposal
    are amendments
    to 35 Ill. Adm.
    Code Part 218,
    Organic Material
    Emission
    Standards
    and Limitations
    for the Chicago
    Area;
    35
    Ill. Adm.
    Code
    Part 219, Organic Material
    Emission Standards
    and
    Limitations
    for the Metro
    East
    Area;
    and
    35 Iii. Adm. Code
    Part 211, Definitions
    and General
    Provisions.
    II. STATEMENT
    OF
    FACTS
    The
    CAA establishes
    a comprehensive
    program for controlling
    and improving
    the
    nation’s
    air quality via state
    and federal regulations.
    The
    United
    States Environmental
    Protection
    Agency (“USEPA”)
    is charged
    with
    identifying air
    pollutants that endanger
    the public
    health
    and welfare
    and with formulating
    the NAAQS that
    specify
    the
    maximum
    permissible
    concentrations
    of those pollutants
    in the ambient
    air
    pursuant to
    Sections
    108 and 109 of the
    CAA.
    42
    U.S.C.
    §
    7408-7409.
    A.
    8-Hour
    Ozone
    NAAOS
    Ozone
    is a gas composed
    of three atoms
    of oxygen.
    Ozone occurs both in
    the
    Earth’s
    upper
    atmosphere and at
    ground
    level.
    VOC is a primary precursor
    to the
    2

    formation
    of
    ground-level
    ozone,
    which
    is
    formed
    when
    oxides
    of nitrogen
    and
    VOC
    react
    in
    the
    atmosphere
    in
    the
    presence
    of
    sunlight.
    71
    Fed.
    Reg.
    58746
    (Oct.
    5,
    2006).
    Exposure
    to
    sufficient
    concentrations
    of
    ground-level
    ozone
    is
    associated
    with
    agricultural
    crop
    loss,
    damage
    to
    forests
    and
    ecosystems,
    and a
    variety
    of
    human
    health
    effects,
    including
    acute
    respiratory
    symptoms,
    increased
    susceptibility
    to
    respiratory
    infection,
    and
    pulmonary
    inflammation.
    71 Fed.
    Reg.
    58746.
    On
    July
    18, 1997,
    USEPA
    revised
    the NAAQS
    for
    ozone
    by replacing
    the
    1-hour
    standard
    with
    an
    8-hour
    standard.
    62
    Fed.
    Reg.
    38856
    (July
    18,
    1997).
    In
    Illinois,
    there
    are
    two
    areas
    designated
    as
    nonattainment
    (moderate)
    for
    the
    8-hour
    ozone
    standard:
    1)
    the
    Chicago-Gary-Lake
    County,
    IL-IN
    designated
    area,
    which
    includes
    Cook,
    DuPage,
    Grundy
    (partial-Goose
    Lake
    and
    Aux
    Sable
    Townships),
    Kane,
    Kendall
    (partial-Oswego
    Township),
    Lake,
    McHenry,
    and
    Will
    Counties; and
    2) the
    St.
    Louis,
    MO-IL
    designated
    area,
    which
    includes
    Jersey,
    Madison,
    Monroe,
    and
    St. Clair
    Counties.
    40
    CFR
    §
    81.3
    14.
    B.
    Consumer
    and
    Commercial
    Products,
    Group
    II
    Section
    183(e)
    of the
    CAA
    required
    that USEPA
    conduct
    a study
    of
    the
    emissions
    of VOC
    into
    the
    ambient
    air
    from
    consumer
    and
    commercial
    products
    in
    order
    to
    determine
    their
    potential
    to
    contribute
    to
    ozone
    levels
    which
    violate
    the
    ozone
    NAAQS
    and
    to
    establish
    criteria
    for
    regulating
    emissions
    of
    VOC
    from
    those
    products.
    71
    Fed.
    Reg.
    58746.
    Section
    183(e)
    provides,
    “[T]he
    Administrator
    shall
    list
    those
    categories
    of
    consumer or
    commercial
    products that
    the Administrator
    determines,
    based
    on the
    study,
    account
    for
    at least
    80
    percent
    of the
    VOC
    emissions.
    .
    . from
    consumer
    or commercial
    products
    in
    areas
    that
    violate
    the
    NAAQS
    for ozone”
    and
    shall
    divide
    the
    categories
    into
    groups.
    42
    U.S.C.
    §
    7511b(e)(3)(A).
    3

    The CAA
    requires
    that
    USEPA
    then
    either
    regulate
    VOC
    emissions
    from
    such
    categories
    or
    issue
    a
    CTG
    in
    lieu
    of a national
    regulation
    if the
    Administrator
    determines
    that
    such
    guidance
    will
    be
    substantially
    as
    effective
    as regulations
    in
    reducing
    emissions
    of
    VOC
    which
    contribute
    to
    ozone
    levels
    in
    ozone
    nonattainment
    areas.
    42
    U.S.C.
    §
    751
    lb(e)(3)(C).
    CTGs
    provide
    states with
    recommendations
    regarding
    what
    types
    of
    controls
    could
    constitute
    RACT
    for
    VOCs
    for
    the applicable
    source
    categories.
    71 Fed.
    Reg.
    58745,
    58747.
    States
    must
    either
    adopt
    regulations
    to
    implement
    the
    recommendations
    in
    the
    CTG
    or adopt
    alternative
    approaches
    that
    constitute
    RACT,
    either
    of
    which
    must
    be
    submitted
    to
    the USEPA
    for
    review
    and
    approval
    as
    part
    of the
    SIP
    process.
    71
    Fed.
    Reg.
    58745,
    58747.
    On
    October
    5, 2006,
    the USEPA
    issued
    final
    CTGs
    for
    Group
    II Consumer
    and
    Commercial
    Product
    Categories
    in lieu of
    national
    regulations
    for the
    control
    of
    VOC
    emissions.
    The
    USEPA
    required
    that states
    submit
    SIP
    revisions
    in response
    to
    the CTGs
    within
    one
    year.
    71 Fed.
    Reg.
    58745-58753.
    C.
    CAA’s
    RACT
    Requirements
    USEPA
    designated
    the
    Chicago
    and Metro
    East
    areas
    in
    Illinois
    as nonattainment
    (moderate)
    for
    the
    8-hour
    ozone
    NAAQS,
    which
    triggered
    requirements
    under
    the
    CAA
    for
    adopting
    regulations
    that
    reduce
    emissions
    sufficiently
    to
    demonstrate
    attainment
    of
    the
    standard.
    Section
    172(c)(l)
    of
    the CAA
    provides,
    in
    pertinent
    part:
    (c)
    Nonattainment
    plan
    provisions
    The
    plan
    provisions
    (including
    plan
    items)
    required
    to
    be submitted
    under
    this
    part
    shall
    comply
    with
    each
    of the
    following:
    (1)
    In
    general
    4

    Such plan
    provisions
    shall
    provide
    for
    the implementation
    of
    all
    reasonably
    available
    control
    measures
    as expeditiously
    as
    practicable
    (including
    such
    reductions
    in
    emissions
    from
    existing
    sources in
    the area as
    may be obtained
    through the
    adoption,
    at a
    minimum,
    of
    reasonably
    available
    control
    technology)
    and
    shall
    provide
    for attainment
    of the
    national
    primary
    ambient air
    quality
    standards.
    42
    U.S.C.
    §
    7502(c)(l).
    A subset
    of
    RACM
    is
    RACT,
    which
    is defined
    as the lowest
    emission
    limitation
    that a particular
    source
    can
    meet by applying
    a
    control technique
    that
    is reasonably
    available
    considering
    technological
    and economic
    feasibility.
    See 44 Fed.
    Reg.
    53762
    (September
    17, 1979).
    Additionally,
    Section
    182(b)
    of the
    CAA provides,
    in pertinent
    part:
    (b)
    Moderate
    Areas
    Each
    State
    in which
    all or part
    of
    a Moderate
    Area
    is located
    shall, with
    respect
    to
    the Moderate
    Area,
    make the
    submissions
    described
    under
    subsection
    (a) of this
    section
    (relating
    to Marginal
    Areas),
    and shall
    also submit
    the revisions
    to
    the
    applicable
    implementation
    plan
    described
    under
    this subsection.
    (2)
    Reasonably
    available
    control
    technology
    The
    State
    shall
    submit
    a
    revision
    to the
    applicable
    implementation
    plan to
    include provisions
    to
    require
    the implementation
    of
    reasonably
    available
    control
    technology
    under
    section 7502(c)(1)
    of this
    title with respect
    to each
    of
    the following:
    (A)
    Each category
    of VOC
    sources
    in the
    area
    covered
    by a
    CTG
    document
    issued
    by the
    Administrator
    between
    November
    15, 1990,
    and the
    date of
    attainment.
    42
    U.S.C.
    §
    75lla(b)(2).
    Sections
    172
    and
    182 of the
    CAA
    establish
    the
    requirement
    for
    Illinois
    to submit
    VOC regulations
    constituting
    RACT
    for
    Group
    II Consumer
    and Commercial
    Product
    Categories
    in
    ozone nonattainment
    areas classified
    as moderate
    and above.
    Illinois
    was
    required
    to submit
    its
    SIP revisions
    by October
    5,
    2007.
    5

    III. PURPOSE
    AND
    EFFECT
    OF
    THE
    PROPOSAL
    This
    rulemaking
    proposal
    has been
    prepared
    to
    satisfy
    Illinois’
    obligation
    to
    submit
    a SIP to
    address
    the
    requirements
    under
    Sections
    172 and
    182
    of the
    CAA,
    as
    described
    above,
    for
    sources
    of VOC
    emissions
    in areas
    designated
    as nonattainment
    with
    respect
    to the
    ozone
    NAAQS.
    See 42 U.S.C.
    §
    7502
    and
    7511a.
    Also,
    Illinois
    is required
    to
    submit
    these
    SIP revisions
    before
    the USEPA
    can
    redesignate
    the
    Chicago
    and
    Metro
    East
    nonattainment
    areas
    as
    attaining
    the
    1997 ozone
    NAAQS,
    regardless
    of whether
    the
    VOC
    reductions
    obtained
    by
    the
    SIP revisions
    are
    actually
    necessary
    to achieve
    attainment
    of
    the
    NAAQS.
    Section
    107(d)(3)(E)
    of the
    CAA
    provides
    that
    the
    Administrator
    may not
    redesignate
    a nonattainment
    area to
    attainment
    unless
    the State
    has
    a
    fully-approved
    SIP
    for the area
    seeking redesignation
    and the State
    has
    met
    all applicable
    requirements
    of
    Section
    110 and
    Part
    D (which
    includes
    the
    requirement
    that states
    adopt
    VOC RACT
    rules
    for categories
    covered
    by
    a
    CTG).
    42
    U.S.C.
    §
    7407(d)(3)(E).
    In
    a
    September
    17, 1993,
    guidance
    document
    from
    Michael
    H.
    Shapiro,
    Acting
    Assistant
    Administrator
    for Air
    and Radiation
    (“Shapiro
    Memorandum”),
    the
    USEPA confirmed,
    “[B]efore
    EPA
    can
    act favorably
    upon
    any
    State
    redesignation
    request, the
    statutorily-mandated
    control
    programs
    of
    section
    110
    and part
    D
    (that were
    due
    prior
    to the time
    of the
    redesignation
    request)
    must
    have
    been
    adopted
    by
    the State
    and
    approved
    by EPA
    into the
    SIP.”
    (Shapiro
    Memorandum,
    p.
    2).’
    See
    also Wall
    v. USEPA.
    In Wall, the
    United States
    Court of Appeals
    for
    the Sixth Circuit
    vacated
    the
    USEPA’s
    redesignation
    of a
    state to attainment,
    in
    part
    because the
    state
    failed to
    promulgate
    VOC
    RACT
    rules in response
    to
    CTGs. The
    USEPA
    argued
    that fully
    adopted
    VOC
    RACT
    rules were
    unnecessary
    because
    the state did
    not
    need
    the reductions
    from
    such
    rules
    to achieve attainment.
    The court
    rejected
    USEPA’s
    argument,
    holding
    that
    the CAA unambiguously
    requires that
    a SIP
    submitted
    with
    respect to
    a
    redesignation
    request
    contain
    fully
    adopted
    RACT
    rules required
    by
    Part
    D.
    Redesignation
    absent
    such
    rules
    was
    therefore
    improper.
    Wall
    v. USEPA,
    265
    F.2d 426,
    433,
    440-42
    (6th
    Cir.
    2001).
    6

    On
    July 2,
    2007,
    the
    Illinois
    EPA
    submitted
    to the
    USEPA
    an attainment
    demonstration
    for the
    Metro
    East
    nonattainment
    area
    for
    the
    1997
    8-hour
    ozone
    NAAQS.
    On March
    19, 2009,
    the
    Illinois
    EPA
    submitted
    an
    attainment
    demonstration
    for
    the
    Chicago
    nonattainment
    area as
    well.
    These
    areas
    cannot
    be
    redesignated
    to
    attainment
    of
    the
    ozone
    NAAQS,
    however,
    unless
    and
    until
    the
    Illinois
    EPA
    submits
    SIP
    revisions
    in
    response
    to
    the
    Group
    II
    CTGs
    and
    the USEPA
    approves
    such
    revisions.
    Finally,
    in
    March
    2008,
    USEPA
    strengthened
    the
    eight-hour
    ozone
    standard.
    73
    Fed.
    Reg.
    16436
    (March
    27,
    2008).
    It
    is likely
    that
    the
    same
    areas
    in
    Illinois
    that are
    currently
    designated
    as
    nonattainment
    for the
    present
    standards
    will
    soon
    be
    designated
    as
    nonattainment
    for the
    revised
    standard.
    While
    attainment
    of
    the
    revised
    standard
    is not
    the
    purpose
    of
    this
    rulemaking,
    it
    should
    be noted
    that
    any
    reduction
    in VOM
    emissions
    in the
    nonattainment areas
    resulting
    from
    these
    proposed
    amendments
    will
    likely
    help
    Illinois
    achieve
    the
    revised
    NAAQS.
    Generally, Illinois
    EPA’s
    regulatory
    proposal
    aims
    to
    implement
    the
    recommendations
    contained
    in
    the CTGs
    to
    the
    extent
    that
    such recommendations
    are
    consistent with,
    and
    impose
    stricter
    requirements
    than,
    existing
    regulations:
    Industrial
    Cleaning
    Solvents.
    The
    proposed
    regulations
    apply
    to
    cleaning
    operations at sources that meet
    the
    applicability
    threshold
    set
    forth
    in
    the
    CTG,
    subject
    to
    several
    partial
    and
    complete
    exclusions.
    Per the
    CTG,
    the
    proposed
    regulations
    require
    that
    subject
    sources
    comply
    with
    work
    practice
    requirements
    and
    with
    one
    of three
    alternative
    control
    requirements.
    Flat
    Wood
    Paneling
    Coatings.
    The
    proposed
    regulations
    require
    that
    flat
    wood
    paneling
    coating
    lines
    comply
    with
    the
    VOM
    content
    limitation
    specified
    in
    the
    CTG.
    As
    7

    an alternative to
    the
    VOM
    content
    limit,
    subject
    lines may comply
    with
    a daily weighted
    averaging
    limitation or utilize
    an add-on control
    device
    that meets a specified
    overall
    VOM reduction requirement.
    The
    proposed
    regulations
    also require
    that
    flat wood
    paneling coating
    lines comply
    with the existing
    cleaning
    and
    storage work practice
    requirements
    for
    wood
    furniture,
    as well
    as with the work practices
    set forth
    in the CTG.
    Flexible Packaging
    Printing Materials.
    The
    proposed regulations
    require that
    flexographic
    and rotogravure
    printing
    lines
    that
    print
    flexible packaging,
    or that print
    flexible
    packaging and
    non-flexible packaging
    on
    the
    same
    line, comply
    with
    the
    CTG
    recommended
    VOM content
    limit. Alternatively,
    such
    lines may comply
    with
    a
    weighted
    averaging
    limitation
    or install and
    operate
    a capture
    and control system
    that reduces
    VOM emissions
    by specified
    percentages.
    The proposed
    regulations
    also require that
    printing
    lines
    that
    meet the CTG’s
    prescribed applicability
    threshold
    comply with
    work
    practice
    requirements for cleaning
    materials.
    Lithographic
    Printing
    Materials. The
    proposed regulations
    provide
    that
    the
    existing
    requirements regarding
    fountain solutions
    and cleaning
    materials
    apply
    to
    sources
    that
    meet
    the applicability
    threshold specified
    in the
    CTG,
    subject to certain
    exclusions. Additionally,
    the
    proposed regulations
    require that afterburners
    or other
    approved control
    devices installed
    on
    heatset
    web
    offset
    lithographic
    printing
    lines reduce
    VOM emissions
    by specified percentages
    or to a maximum
    afterburner exhaust
    outlet
    concentration.
    Letterpress
    Printing Materials.
    The
    proposed
    regulations require
    that heatset
    web
    letterpress printing
    lines that meet the
    CTG’s
    prescribed
    applicability
    threshold
    install
    afterburners or
    other
    approved control
    devices
    that reduce
    VOM emissions
    by specified
    8

    percentages
    or to
    a maximum
    afterburner
    exhaust
    outlet concentration.
    All letterpress
    printing
    lines
    that
    meet
    the
    CTG’s
    lower
    applicability
    threshold
    must
    comply
    with
    work
    practices
    for
    cleaning
    materials.
    Such
    lines must
    also comply
    with either
    a VOM
    content
    limit
    or VOM
    composite
    partial vapor
    pressure
    limit
    for
    as-used cleaning
    solutions,
    subject
    to a CTG-recommended
    exclusion
    for up
    to 110
    gallons of
    cleaning
    materials
    per
    year.
    IV.
    GEOGRAPHIC
    REGIONS
    AND
    SOURCES
    AFFECTED
    The
    geographic
    regions
    subject
    to
    the proposed
    regulations
    are the
    two
    areas
    designated
    as nonattainment
    for
    the 8-hour
    ozone standard:
    1) the Chicago-Gary-Lake
    County,
    IL-IN
    designated
    area, which
    includes Cook,
    DuPage,
    Grundy
    (partial-Goose
    Lake
    and Aux
    Sable
    Townships),
    Kane,
    Kendall
    (partial-Oswego
    Township),
    Lake,
    McHenry,
    and
    Will Counties;
    and
    2)
    the
    St.
    Louis, MO-IL
    designated
    area,
    which
    includes
    Jersey, Madison,
    Monroe,
    and
    St.
    Clair Counties.
    40
    CFR
    §
    81.314.
    The
    proposed
    regulations
    are
    generally
    expected
    to affect both
    new
    and
    existing
    sources
    that are
    covered
    by
    a
    Group
    II CTG,
    are
    located
    in the Chicago
    or Metro
    East
    nonattainment
    areas,
    and meet
    the
    applicability
    criteria
    specified
    in
    the regulations.
    Appendix
    B to
    the
    TSD lists
    the sources
    potentially
    affected
    by
    the
    proposed regulations.
    V.
    TECHNICAL
    FEASIBILITY
    AND
    ECONOMIC
    REASONABLENESS
    The
    technology
    for
    controlling
    VOM emissions
    from
    Group
    II product
    categories
    is both
    technically
    feasible
    and economically
    reasonable.
    Affected
    sources
    can
    meet
    the
    requirements
    in
    the proposed
    amendments
    through
    a
    number
    of
    readily available
    control
    techniques.
    9

    Control
    techniques
    for
    reducing
    VOM
    emissions
    from
    industrial
    cleaning
    solvents
    include
    work practices,
    material
    reformulation
    or
    substitution
    (namely,
    the use
    of low
    VOM
    cleaning
    solvents,
    no-VOM
    solvents,
    or
    low vapor
    pressure
    solvents),
    and add-on
    controls
    or modifying
    equipment.
    Similarly,
    material
    reformulation,
    add-on
    controls,
    and
    work
    practices
    for
    coatings
    and
    cleaning
    materials
    are available
    VOM
    reduction
    techniques
    for flat
    wood
    paneling
    coating
    lines.
    See Technical
    Support
    Document.
    VOM
    control
    approaches
    for flexible
    packaging
    printing
    lines
    include
    material
    reformulation,
    add-on
    controls
    such as
    thermal
    oxidizers,
    catalytic
    oxidizers,
    and
    carbon
    adsorbers,
    and work
    practices
    for
    cleaning
    materials.
    For lithographic
    printing
    lines,
    control
    options
    include
    add-on
    controls
    for
    heatset
    web
    offset
    lithographic
    printing
    lines,
    such
    as
    thermal
    afterburners,
    catalytic
    afterburners,
    and
    condenser
    filter systems,
    fountain
    solution
    reformulation
    (such
    as the
    use of alcohol
    substitutes),
    process
    modifications
    for
    fountain
    solutions,
    and
    material
    reformulation
    or substitution
    for
    cleaning
    solutions.
    Control
    approaches
    for letterpresses
    are
    similar
    to
    those available
    for lithographic
    printing
    lines
    (although
    letterpresses
    do
    not
    utilize
    fountain
    solutions).
    Technical
    Support
    Document.
    In
    the
    Technical
    Support
    Document,
    the
    Illinois
    EPA
    explains
    in
    detail
    that
    the
    above
    control
    approaches
    are
    economically
    feasible,
    particularly
    as
    many
    of the
    techniques
    are
    already
    widely
    used
    by the
    affected
    industries.
    VI. COMMUNICATION
    WITH
    INTERESTED
    PARTIES
    The
    Illinois
    EPA
    engaged
    in
    extensive
    outreach
    on
    this
    proposal.
    On
    November
    5,
    2008,
    the
    Illinois
    EPA
    posted
    a draft
    of
    the
    proposed
    rule
    and
    copies
    of the
    pertinent
    CTGs
    on
    its
    website
    for public
    comment.
    The
    Illinois
    EPA
    subsequently
    engaged
    in
    10

    numerous
    conference calls
    and exchanged
    correspondence
    with representatives of
    affected sources regarding the proposal.
    Illinois
    EPA received several
    comments
    on the draft rule, and this proposal
    incorporates many of the concerns and suggestions
    set forth
    in those
    comments. Such
    comments can generally be categorized into the
    following
    areas: appropriate applicability
    thresholds
    and
    exclusions,
    methods of calculating
    applicability
    thresholds,
    appropriate
    control
    requirements, simplification of
    recordkeeping
    and reporting requirements, and
    revisions to proposed
    definitions.
    These
    regulations
    are being proposed
    after the
    interested parties have had an opportunity to
    review the proposal
    and discuss any issues
    with the Illinois EPA.
    VII. SYNOPSIS
    OF TESTIMONY
    The Illinois EPA plans to call David
    Bloomberg,
    Compliance Unit Manager,
    Compliance Section,
    Bureau
    of Air, Illinois EPA,
    as a witness at hearing. Mr.
    Bloomberg
    will testify
    regarding the proposed
    amendments and
    will answer questions.
    Written testimony
    will be submitted prior
    to hearing in
    accordance with the Board’s
    procedural rules.
    VIII. THE ILLINOIS
    EPA’S
    PROPOSAL
    The following is
    a Section-by-Section
    summary
    of the Illinois EPA’s proposal.
    35 Ill. Adm.
    Code 211
    Subpart B:
    Definitions
    The Illinois EPA proposes amending current
    definitions in, and adding new
    definitions
    to, Part
    211.
    Section
    211.1000
    Class II Finish
    11

    The Illinois
    EPA
    proposes
    adding
    a
    definition
    for Class
    II
    finish.
    This
    definition
    is
    necessary
    for
    Subpart
    F.
    Section
    211.1745
    Digital
    Printing
    The
    Illinois
    EPA
    proposes adding
    a definition
    for digital
    printing.
    This definition
    is
    necessary
    for
    Section
    218/219.187
    of Subpart
    E.
    Section
    211.1878
    Electrical
    Apparatus
    Component
    The Illinois
    EPA
    proposes
    adding
    a definition
    for
    electrical
    apparatus
    component.
    This
    definition
    is necessary
    for
    Section
    218/219.187
    of
    Subpart
    E.
    Section
    211.1885
    Electronic
    Component
    The Illinois
    EPA
    proposes
    amending
    the
    definition
    of
    electronic
    component
    by
    extending
    the
    application
    of
    the
    definition
    to
    Section
    218/219.187
    and
    by
    adding
    an
    exception
    to
    the
    definition.
    These
    revisions
    are necessary
    for
    Section
    218/219.187
    of
    Subpart
    E.
    Section
    211.2355
    Flat
    Wood
    Paneling
    The
    Illinois
    EPA
    proposes
    adding
    a
    definition
    for
    flat
    wood
    paneling.
    This
    definition
    is
    necessary
    for Subpart
    F.
    Section
    211.2356
    Flat
    Wood
    Paneling
    Coating
    Line
    The
    Illinois
    EPA
    proposes
    adding
    a
    definition
    for flat
    wood
    paneling
    coating
    line.
    This
    definition
    is
    necessary
    for Subpart
    F.
    Section
    211.2368
    Flexible
    Packaging
    The
    Illinois
    EPA
    proposes
    adding
    a
    definition
    for
    flexible
    packaging.
    This
    definition
    is
    necessary
    for Subpart
    H.
    Section
    211.2615
    General
    Work
    Surface
    12

    The Illinois EPA
    proposes
    adding
    a
    definition
    for general
    work
    surface.
    This
    definition
    is
    necessary
    for
    Section
    218/219.187
    of Subpart
    E.
    Section 211.2830
    Heatset
    The
    Illinois EPA
    proposes
    amending
    the
    definition of “heatset”
    to
    include
    letterpress
    printing lines.
    This
    revision
    is necessary for Subpart
    H.
    Section 211.2855
    Heatset Web
    Letterpress
    Printing Line
    The Illinois
    EPA
    proposes adding
    a definition
    for heatset
    web letterpress
    printing
    line. This
    definition is
    necessary
    for Subpart H.
    Section
    211.2965
    High Precision
    Optic
    The Illinois
    EPA
    proposes
    adding a
    definition
    for
    high precision optic.
    This
    definition is
    necessary for
    Section 218/219.187
    of Subpart
    E.
    Section 211.3215
    Janitorial
    Cleaning
    The Illinois EPA
    proposes
    adding
    a definition
    for janitorial
    cleaning.
    This
    definition is necessary
    for Section
    218/219.187
    of Subpart E.
    Section 211.3305
    Letterpress
    Printing
    Line
    The
    Illinois
    EPA
    proposes
    adding
    a definition for letterpress
    printing
    line. This
    definition is necessary
    for
    Subpart H.
    Section
    211.3555
    Maintenance
    Cleaning
    The Illinois
    EPA
    proposes
    adding
    a definition
    for maintenance
    cleaning.
    This
    definition
    is
    necessary
    for
    Section
    218/219.187
    of Subpart
    E.
    Section 211.3705
    Medical
    Device
    The Illinois EPA
    proposes
    adding
    a definition
    for
    medical
    device.
    This definition
    is
    necessary
    for Section
    218/219.187
    of
    Subpart
    E.
    13

    Section 211.3707
    Medical Device
    and Pharmaceutical Manufacturing
    The Illinois EPA proposes adding
    a definition for medical device and
    pharmaceutical manufacturing.
    This definition is necessary for Section 218/219.187
    of
    SubpartE.
    Section 211.4065
    Non-Heatset
    The Illinois
    EPA proposes amending the definition
    of”non-heatset” to include
    letterpress printing lines. This revision
    is
    necessary
    for Subpart H.
    Section 211.5335
    Radiation Effect Coating
    The Illinois EPA proposes adding a
    definition for radiation effect coating. This
    definition is necessary for
    Section 218/219.187 of Subpart E.
    Section 211.5535
    Repair Cleaning
    The Illinois EPA proposes
    adding
    a
    definition for repair cleaning. This definition
    is necessary
    for
    Section
    218/219.187 of Subpart E.
    Section 211.5585
    Research and Development
    Operation
    The Illinois EPA proposes adding
    a
    definition for research
    and development
    operation. This definition is necessary for Section 218/219.187 of Subpart
    E.
    Section 211.5860
    Scientific Instrument
    The Illinois EPA proposes adding a definition for scientific instrument.
    This
    definition is necessary for Section 218/219.187 of Subpart E.
    Section 211.5875
    Screen Printing
    The Illinois EPA proposes adding a definition for screen
    printing.
    This definition
    is
    necessary for Section 218/219.187 of Subpart E.
    Section 211.5885
    Screen Reclamation
    The
    Illinois
    EPA proposes adding a
    definition for
    screen reclamation. This
    14

    definition
    is
    necessary
    for Section
    218/219.187
    of
    Subpart
    B.
    Section
    211.6405
    Sterilization
    Indicating
    Ink
    The
    Illinois
    EPA
    proposes
    adding
    a definition
    for sterilization
    indicating
    ink.
    This
    definition
    is necessary
    for
    Section
    2 18/219.187
    of
    Subpart
    B.
    Section
    211.6425
    Stripping
    The
    Illinois
    EPA
    proposes
    adding
    a definition
    for stripping.
    This definition
    is
    necessary
    for
    Section
    218/219.187
    of Subpart
    B.
    Section
    211.6535
    Surface
    Preparation
    The
    Illinois
    EPA
    proposes
    adding
    a
    definition
    for
    surface
    preparation.
    This
    definition
    is
    necessary
    for
    Section
    218/219.187
    of
    Subpart
    E.
    Section
    211.7290
    Wood
    Furniture
    The
    Illinois
    EPA
    proposes
    amending
    the
    definition
    of
    “wood
    furniture”
    by
    excluding
    flat
    wood
    paneling
    from such
    definition.
    This
    revision
    is necessary
    for
    Subpart
    F.
    35 Ill. Adm.
    Code
    218/219
    Subpart
    A:
    General
    Provisions
    Section
    218/219.106
    Compliance
    Dates
    The
    Illinois
    EPA
    proposes
    adding
    a new
    subsection
    (e) to Section
    2
    18.106
    and a
    new
    subsection
    (c)
    to Section
    219.106,
    which
    establish
    May
    1,
    2010,
    as the
    compliance
    date for
    sources
    subject
    to the
    flat
    wood
    paneling
    emission
    limits.
    Subpart
    E:
    Solvent
    Cleaning
    Section
    218/219.181 Solvent
    Cleaning
    in
    General
    15

    The
    Illinois EPA
    proposes
    changing
    the
    title
    of this
    Section to
    “Solvent
    Cleaning
    Degreasing
    Operations.”
    The
    Illinois
    EPA
    also
    proposes
    amending
    this
    Section to
    specify
    that
    Sections 218/219.182
    through 218/219.184
    and
    Section
    218/219.186
    are
    applicable
    to cold
    cleaning, open
    top
    vapor,
    and
    conveyorized
    degreasing
    operations.
    Section 218/219.187
    Other Industrial
    Solvent
    Cleaning
    Operations
    The
    Illinois
    EPA
    proposes
    adding
    Section
    218/219.187.
    Subsection
    (a)
    provides
    that the
    requirements
    in
    Section
    218/219.187
    apply
    to all
    cleaning
    operations
    which
    use
    organic materials
    at sources
    that
    emit 6.8
    kg/day
    (15 lbs/day)
    or
    more
    of VOM
    from
    cleaning operations
    at the
    source,
    in the
    absence
    of air
    pollution
    control
    equipment.
    Subsection
    (a)(2), however,
    exempts
    numerous
    types
    of cleaning
    operations
    from some
    or all
    of the
    limitations
    in Section
    218/219.187.
    Subsection
    (a) also
    defines
    “cleaning
    operations.”
    Subsection
    (b) provides
    that no
    source
    subject
    to Section
    218/219.187
    shall
    perform
    subject
    cleaning operations
    unless
    the
    source
    complies
    with
    the
    applicable
    VOM
    content
    limitation,
    uses cleaning
    materials
    with a
    composite
    vapor pressure
    of no
    more
    than
    8.0
    mmHg
    measured
    at 20 degrees
    Celsius,
    or installs
    and
    operates an
    emissions
    control
    system
    that reduces
    VOM
    emissions
    from the
    subject
    cleaning
    operation
    by
    at
    least
    85 percent
    overall.
    Subsection
    (c)
    provides
    that sources
    shall
    demonstrate
    compliance
    with this
    Section
    by using
    the
    applicable
    test
    methods and
    procedures
    in
    Section
    218/219.187(g)
    and
    by
    complying
    with
    all applicable
    recordkeeping
    and reporting
    requirements
    in
    Section
    218/219.187(e).
    16

    Subsection (d)
    provides
    that,
    for
    each
    subject
    cleaning
    operation,
    subject
    sources
    shall
    cover
    open
    containers,
    minimize
    air circulation
    around
    the
    cleaning
    operation,
    properly
    dispose
    of
    used
    solvent
    and shop
    towels,
    and
    utilize
    equipment
    practices
    that
    minimize
    emissions.
    Subsection (e)
    establishes
    recordkeeping
    and
    reporting
    requirements
    for
    sources
    subject
    to
    or exempt
    from
    the limitations
    of
    this
    Section.
    Subsection
    (e)(1)
    provides
    that,
    by
    May
    1,
    2010,
    sources
    exempt
    from
    the
    limitations
    of
    Section
    218/219.187
    because
    of
    the
    criteria
    in
    Section
    218/219.187(a)(1)
    shall
    submit
    a certification
    to
    the
    Illinois
    EPA
    that
    includes
    a declaration
    that
    the
    source
    is exempt,
    as
    well
    as calculations which
    demonstrate
    that
    combined
    emissions
    of VOM
    from
    cleaning
    operations
    at
    the source
    never
    equal
    or
    exceed
    6.8 kg/day
    (15
    lbs/day).
    Such
    sources
    shall
    notify
    the Illinois
    EPA
    of
    any
    records
    that
    show
    that the
    combined
    emissions
    of
    VOM
    from
    cleaning
    operations
    at
    the source
    ever
    equal
    or
    exceed
    6.8 kg/day
    (15
    lbs/day).
    Subsection (e)(2)
    provides
    that,
    by
    May
    1,
    2010,
    all
    sources
    subject
    to
    Section
    218/219.187 shall
    submit
    a certification
    to
    the
    Illinois
    EPA
    that
    includes
    1)
    a declaration
    that
    all
    subject
    cleaning
    operations
    are
    in
    compliance
    with
    the requirements
    of this
    Section;
    2)
    identification
    of
    each
    subject
    cleaning
    operation
    and
    each
    VOM.-containing
    cleaning
    solution used
    in such
    operation;
    3)
    the
    limitation
    with
    which
    each
    subject
    cleaning
    operation will
    comply,
    and
    if complying
    with
    the
    emissions
    control
    system
    requirement,
    what
    type
    of
    emissions
    control
    system
    will
    be
    used;
    4)
    initial
    documentation
    that
    each
    subject
    cleaning
    operation
    will
    comply
    with
    the
    applicable
    limitation;
    5)
    identification
    of the
    method
    that
    will
    be
    used
    to demonstrate
    continuing
    compliance
    with
    the
    applicable
    limitations;
    6)
    a description
    of
    the practices
    and
    procedures
    that
    the source
    17

    will
    follow
    to ensure
    compliance
    with
    the
    limitations
    of Section 218/219.187(d);
    and
    7)
    a
    description
    of
    each
    cleaning
    operation
    exempt
    pursuant
    to Section 218/219.187(a)(2),
    if
    any,
    and
    a listing
    of the
    emission
    unit(s)
    on
    which
    the
    exempt
    cleaning
    operation
    is
    performed.
    Subsection
    (e)(3)
    provides
    additional
    recordkeeping
    and
    reporting
    provisions
    for
    sources
    complying
    with
    the
    VOM
    content
    limitations
    in
    subsection (b)(1)
    of
    Section
    218/219.187.
    Subsection (e)(4)
    provides
    additional
    recordkeeping
    and
    reporting
    provisions
    for
    sources
    complying
    with
    the VOM
    composite
    partial
    vapor
    pressure
    limitations
    in
    subsection
    (b)(2)
    of
    Section
    218/219.187
    Subsection (e)(5)
    provides
    additional
    recordkeeping
    and
    reporting
    provisions
    for
    sources
    complying with
    the
    emissions
    control
    system
    requirements
    in
    subsection
    (b)(3)
    of
    Section
    218/219.187.
    Subsection
    (e)(6)
    provides
    that
    all
    sources
    subject
    to
    the
    requirements
    of
    subsections
    (b)
    and
    (d)
    of this
    Section
    shall
    notify
    the
    Illinois
    EPA
    of
    any
    violation
    of
    such
    subsections
    by
    providing
    a
    description
    of the
    violation
    and
    copies
    of records
    documenting
    the
    violation
    to
    the
    Illinois
    EPA
    within
    30 days
    following
    the
    occurrence
    of
    the
    violation.
    Subsection
    (e)(7)
    provides
    that
    all
    records
    required
    by
    subsection
    (e)
    shall
    be
    retained
    by
    the source
    for
    three
    years
    and
    shall
    be
    made
    available
    to the
    Illinois
    EPA
    upon
    request.
    Subsection (f)
    establishes
    monitoring
    requirements
    for emissions
    control
    systems
    if
    such
    systems
    are used
    to demonstrate
    compliance.
    18

    Subsection
    (g)
    establishes
    requirements
    regarding
    testing
    to
    demonstrate
    compliance
    with
    Section
    218/219.187.
    Subpart
    F:
    Coating
    Operations
    Section
    218/219.204
    Emission
    Limitations
    The Illinois
    EPA
    proposes
    amending
    subsection
    (c) to
    provide
    that the
    paper
    coating
    limitation
    shall
    not
    apply
    to any
    owner
    or
    operator
    of a
    paper coating
    line
    on
    which
    lithographic
    or letterpress
    printing
    is performed
    if the
    paper
    coating
    line complies
    with
    the applicable
    emissions
    limitations
    in
    Subpart
    H of this
    Part.
    The
    Illinois
    EPA
    proposes
    adding
    subsection
    (p)
    to
    Section
    2
    18.204
    and
    subsection
    (o) to
    Section
    2
    19.204, which
    restrict
    the VOM
    content
    of flat wood
    paneling
    coatings
    to 0.25
    kg VOM/l
    coatings
    or 0.35
    kg
    VOMI1
    solids
    or less.
    Section
    218/219.205
    Daily-Weighted
    Average
    Limitations
    The
    Illinois EPA
    proposes
    amending
    subsection
    (a) of this Section
    to include
    flat
    wood paneling
    coating
    lines
    in the daily-weighted
    averaging
    alternative.
    Section
    218/219.207
    Alternative
    Emission
    Limitations
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (a)
    of this
    Section,
    adding
    subsection
    (1)
    to
    Section
    2 18.207,
    and
    adding
    subsection
    (k) to
    Section
    2 19.207
    to include
    flat
    wood
    paneling
    coating lines
    in
    the alternative
    emissions
    limitations
    option.
    The
    proposed
    subsections
    provide
    that a
    flat
    wood
    paneling
    coating
    line
    may
    utilize
    a capture
    system
    and
    control
    device
    if such system
    provides
    at
    least 90 percent
    reduction
    in
    the
    overall
    emissions
    of VOM
    from the
    coating
    line or the
    owner
    or
    operator
    of the
    flat wood
    paneling
    coating
    line complies
    with
    all requirements
    set
    forth
    in
    subsection
    (b)(2)
    of
    this
    Section.
    19

    The Illinois
    EPA
    also
    proposes
    amending
    Section
    218.207(h)(1)
    to
    correct
    the
    formatting
    of an
    equation.
    Section
    218/219.210
    Compliance
    Schedule
    The
    Illinois
    EPA proposes
    adding
    subsection
    (g),
    which
    provides
    that, on
    and
    after
    a date
    consistent
    with Section
    218/219.106,
    sources
    subject
    to
    the flat
    wood
    paneling
    coating
    emission
    limitations
    shall
    comply
    with
    the
    applicable
    provisions
    in
    Subpart
    F.
    Section
    218/219.211
    Recordkeeping
    and
    Reporting
    The
    Illinois
    EPA proposes
    amending
    subsections
    (c) and
    (d) to
    provide
    that,
    for
    flat wood
    paneling
    coating
    lines, VOM
    content
    information
    shall
    be
    maintained
    and/or
    reported
    in
    terms
    of
    weight
    of
    VOM
    per
    volume
    of coatings
    or
    solids,
    as applicable,
    as
    applied
    each
    day
    on each
    coating
    line.
    The
    Illinois
    EPA
    also
    proposes
    correcting
    a
    spelling
    error
    in
    Section
    218.21
    1(c)(3)(A).
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (e) to
    provide
    that
    flat wood
    paneling
    coating
    lines complying
    pursuant
    to
    Section
    218/219.207
    shall comply
    with
    the
    recordkeeping and
    reporting
    requirements
    set
    forth
    in
    subsection
    (e).
    The
    Illinois
    EPA proposes
    adding
    subsection
    (g),
    which
    establishes
    recordkeeping
    and
    reporting
    requirements
    for
    flat
    wood
    paneling
    coating
    lines
    subject
    to
    the
    work
    practice
    requirements
    set forth
    in Section
    218/219.217.
    Finally,
    the
    Illinois
    EPA proposes
    adding
    a space
    and deleting
    a space
    in Section
    218.21
    1(b)(1).
    Section
    218/219.212
    Cross-Line
    Averaging
    to
    Establish
    Compliance
    for
    Coating
    Lines
    20

    The Illinois EPA
    proposes amending
    this
    Section
    to provide
    that
    the cross-line
    averaging
    alternative
    is not available
    to flat wood
    paneling
    coating
    lines.
    Section 218/219.217
    Wood Furniture
    Coating Work
    Practice
    Standards
    The
    Illinois EPA proposes
    changing the title
    of this Section
    to “Wood
    Furniture
    Coating
    and
    Flat Wood
    Paneling Coating Work
    Practice
    Standards.”
    The Illinois EPA
    also
    proposes
    amending
    this Section
    to provide that
    flat wood paneling
    coating lines
    are
    subject to the
    existing cleaning and
    storage work
    practice requirements
    in this Section.
    The Illinois EPA
    proposes adding
    additional
    cleaning
    and
    storage
    requirements for
    flat
    wood paneling
    coating
    lines as well;
    specifically,
    the
    Illinois
    EPA
    proposes
    requiring that
    such
    coating lines minimize
    spills of VOM containing
    coatings,
    thinners,
    and cleaning
    materials, minimize
    emissions of VOM
    during cleaning
    activities,
    and keep mixing
    vessels which
    contain VOM
    coatings and
    other materials
    closed
    except
    when
    specifically
    in
    use.
    Subpart H: Printing
    and
    Pub1ishin
    Section 218/219.401
    Flexographic
    and Rotogravure
    Printing
    The Illinois
    EPA proposes
    amending
    this
    Section
    to separate requirements
    that are
    applicable prior to the
    new compliance
    date
    from
    those
    applicable
    after
    the new
    compliance date.
    The
    Illinois EPA
    proposes
    amending
    subsection
    (a)
    to provide
    that, on and after
    May 1, 2010,
    owners
    and operators of flexographic
    or rotogravure printing
    lines that
    do
    not print
    flexible
    packaging and that
    are complying
    with subsection
    (a) shall comply
    with
    the existing
    VOM
    content limitations.
    Owners
    and operators
    of flexographic or
    rotogravure
    printing
    lines that print
    flexible
    packaging
    or that
    print flexible packaging
    21

    and non-flexible
    packaging
    on the same
    line shall
    restrict the
    VOM content
    of
    coatings
    and inks to
    .8
    kg VOM/kg solids applied
    or .16
    kg VOM/kg
    materials
    applied
    or less.
    The
    Illinois EPA proposes
    amending
    Section
    218/219.401(b)
    to provide that, on
    and
    after
    May 1,
    2010, owners and
    operators
    of flexographic
    or rotogravure printing
    lines
    that do not
    print flexible packaging
    and
    that
    are complying
    with
    subsection
    (b) shall
    comply with
    the existing
    weighted
    averaging
    requirements.
    Owners
    and operators
    of
    flexographic
    or rotogravure
    printing lines that
    print flexible
    packaging,
    or that
    print
    flexible
    packaging
    and
    non-flexible packaging
    on the same
    line,
    and
    that are
    complying
    with subsection
    (b) shall
    not apply coatings
    or inks on the
    subject printing
    line
    unless
    the
    weighted
    average,
    by
    weight, VOM
    content of all coatings
    and inks as
    applied each
    day
    on the subject printing
    line
    does
    not
    exceed the
    VOM limitations
    specified in
    amendments
    to subsection (a) of this
    Section.
    The
    Illinois
    EPA
    proposes
    inserting
    equations
    for
    calculating the weighted
    average
    VOM
    content
    for
    such
    lines.
    2
    The Illinois
    EPA
    also
    proposes amending
    Section 2l8.401(b)(1)(A)
    to correct a
    typographical
    error in the existing
    equation, and
    Section
    219.401(b)
    to
    correct
    spacing
    errors
    in the
    existing equations.
    The
    Illinois
    EPA proposes
    amending
    subsection
    (c) to
    provide that, on and
    after
    May 1, 2010, the owner
    or operator
    of a flexographic
    or rotogravure
    printing line
    that
    does not print flexible
    packaging
    and
    that is complying
    with subsection
    (c) shall equip
    the
    printing line with a capture
    system
    and control device
    that complies
    with the existing
    control
    efficiency requirements.
    The
    owner
    or
    operator of a
    flexographic or rotogravure
    printing line that prints
    flexible packaging
    shall
    equip the printing
    line with a capture
    system and control device
    that provides
    an overall reduction
    in VOM
    emissions of
    65-80
    2
    For ease
    of reading, however, the
    equations are not
    underlined
    in
    the text
    of the proposed
    rule.
    22

    percent, depending on the dates
    that
    the printing
    line and control system were first
    constructed at the
    subject source. The owner
    or operator
    of a
    flexographic or rotogravure
    printing line that prints
    flexible packaging
    and non-flexible
    packaging on the same line
    shall comply
    with the overall control efficiency
    requirements set forth in either
    subsection
    (c)(1)(D) or subsection (c)(3) of this
    Section, whichever is more stringent.
    The
    Illinois EPA proposes
    amending
    subsection
    (c)(6) to specify the printing lines
    that are required to
    perform testing pursuant
    to this
    subsection.
    The Illinois EPA
    proposes
    adding subsection
    (d), which provides that VOM
    containing
    cleaning materials associated with
    flexographic
    or rotogravure printing lines
    that print flexible packaging
    or print
    flexible
    packaging
    and
    non-flexible packaging
    on
    the same line shall
    be
    kept, stored, and disposed
    of in closed containers, and conveyed
    from one
    location to another in closed containers
    or pipes.
    Section
    218/219.402
    Applicability
    The
    Illinois EPA proposes adding subsection
    (b), which provides that the
    limitations of
    Section 218/219.401(d)
    apply to all flexographic and rotogravure printing
    lines
    that print
    flexible packaging or print
    flexible
    packaging and non-flexible packaging
    on
    the same
    line at sources where the combined
    emissions
    of VOM from all flexographic
    and
    rotogravure printing
    lines total
    6.8 kg/day (15 lbs/day)
    or
    more, in the absence
    of air
    pollution
    control
    equipment.
    Section
    218/219.403 Compliance Schedule
    The Illinois
    EPA proposes adding
    subsections (e),
    (f),
    and
    (g),
    which
    establish
    May 1, 2010,
    as the
    compliance
    date for the requirements
    set
    forth in
    the proposed
    amendments.
    23

    Section
    218/219.404
    Recordkeeping
    and
    Reporting
    The Illinois
    EPA proposes
    amending
    this
    Section to reference
    recordkeeping
    and
    reporting
    compliance dates
    for
    printing
    lines
    subject
    to the limitations
    in
    the
    proposed
    amendments to Section
    218/219.401.
    The
    Illinois
    EPA
    also proposes
    amending
    subsections
    (c) and (d) to clarify
    that
    the owner
    or operator of a
    printing line subject
    to the requirements
    in
    Section
    218/219.401(a)(2)(B)
    or
    (b)(3) shall certify
    in accordance
    with subsection
    (c)(1) or
    (d)( 1), as
    applicable, even
    if the owner or
    operator of such
    line submitted
    a certification
    prior to January
    1, 2010.
    The Illinois EPA
    proposes
    amending
    subsection
    (e)
    to
    provide
    that if the owner or
    operator of a printing
    line is
    not required
    to perform
    testing of a capture
    system and
    control device pursuant
    to Section
    218/219.401
    (c)(6), the owner
    or operator shall
    submit
    a certification
    to the Agency that includes
    specified
    information.
    The Illinois EPA
    also
    proposes amending
    this subsection
    to provide that,
    by May
    1,
    2010,
    owners or operators
    of printing lines
    subject to Section
    218/219.401(c)(3)
    or (c)(4) shall
    submit to the
    Illinois
    EPA records documenting
    the dates
    each subject
    printing line and control
    device
    were
    constructed at the subject
    source.
    The Illinois EPA
    proposes
    adding subsections (f),
    (g),
    and
    (h).
    Subsection (f)
    establishes recordkeeping
    and reporting
    requirements for
    any owner
    or
    operator of a
    flexographic or rotogravure
    printing
    line that prints flexible
    packaging
    or prints flexible
    packaging
    and non-flexible
    packaging
    on the same line
    and which
    is
    exempt from the
    limitations of Section
    218/219.401(d)
    because of the criteria
    in Section
    218/219.402(b).
    Subsection
    (g)
    establishes
    recordkeeping
    and reporting requirements
    for any owner or
    24

    operator
    of a printing
    line
    subject to
    the
    limitations of Section 218/219.401(d).
    Subsection
    (h) provides that all records required by subsections (f) and
    (g)
    shall be
    retained
    for
    three years and shall
    be
    made available to the
    Agency upon request.
    Section
    218/219.405
    Lithographic Printing: Applicability
    The Illinois EPA proposes amending this Section to separate requirements that are
    applicable
    prior to the
    new compliance date
    from
    those applicable
    after
    the
    new
    compliance date. The Illinois EPA also proposes deleting requirements that were only
    applicable until March 15, 1996, and reformatting/renumbering the remaining
    subsections accordingly.
    The Illinois EPA proposes adding a new subsection (c) to provide that, on and
    after
    May 1, 2010, the requirements in Sections 2l8/219.407(a)(1)(B) through (a)(1)(E)
    and 218/219.407(b) and all
    applicable provisions
    in Sections 218/219.408 through
    218/219.411 of
    this Subpart shall apply to all owners or operators of heatset web offset
    lithographic
    printing line(s) if the
    combined emissions
    of VOM from all lithographic
    printing
    line(s) at the source (including solvents used for cleanup operations associated
    with the
    lithographic printing line(s)) ever
    exceed
    45.5 kg/day (100 lbs/day), before the
    application of capture systems and control devices. On and after May 1, 2010, Sections
    218/21 9.407(a)(
    1 )(A), 218/21 9.407(a)(2) through (a)(5), and all applicable provisions in
    Sections
    218/219.408 through 218/219.411, shall apply to all owners
    or
    operators
    of
    lithographic printing
    lines at sources where the combined
    emissions of VOM from all
    lithographic
    printing lines at the source (including solvents used for cleanup operations
    associated with
    the
    lithographic printing lines) ever total
    6.8 kg/day (15
    lbs/day) or more.
    Finally,
    subsection
    (c) provides that, at sources where the
    combined emissions of
    VOM
    25

    from
    all
    lithographic
    printing
    line(s)
    at the
    source
    equal
    or
    exceed
    6.8 kg/day
    (15
    lbs/day)
    but
    do
    not exceed
    45.5
    kg/day
    (100
    lbs/day),
    before
    the
    application
    of
    capture
    systems
    and
    control
    devices,
    certain
    specified exclusions
    apply
    unless
    the
    owner
    or operator
    of
    the
    source
    certifies
    that the
    source
    will
    not
    make
    use of
    any
    such
    exclusions.
    Section
    2 18/219.406
    Provisions
    Applying
    to
    Heatset
    Web
    Offset
    Lithographic
    Printing
    Prior
    to
    March
    15,
    1996
    The
    Illinois
    EPA
    proposes
    repealing
    this
    Section, as
    it
    contains
    requirements
    that
    were
    applicable
    prior
    to
    March
    15,
    1996.
    Section
    218/219.407
    Emission
    Limitations
    and
    Control
    Requirements
    for
    Lithographic
    Printing
    Lines
    On
    and
    After
    March
    15, 1996
    The
    Illinois
    EPA
    proposes
    amending
    this
    Section
    by
    deleting
    references
    to the
    previous
    compliance
    date
    of
    March
    15,
    1996,
    and
    separating
    requirements
    that
    are
    applicable
    prior
    to the
    new
    compliance
    date
    from
    those
    applicable
    after
    the new
    compliance
    date.
    The
    Illinois
    EPA
    also
    proposes
    changing
    the
    VOM
    content
    limitations
    for
    fountain
    solutions
    from
    “by
    volume”
    to
    “by
    weight,”
    as
    USEPA
    has
    informed
    the
    Illinois
    EPA
    that
    this
    is
    the
    appropriate
    way
    to
    measure
    the
    limit.
    The
    Illinois
    EPA
    proposes
    amending
    subsections
    (a)(1)(C)
    and
    (b)
    to
    provide
    that,
    on and
    after
    May
    1, 2010,
    owners
    or operators
    of
    subject
    heatset
    web offset
    lithographic
    printing
    lines
    shall
    install
    and
    operate
    an
    afterburner
    or
    other
    approved
    control
    device
    so
    that
    VOM
    emissions from
    the
    press
    dryer
    exhaust
    are
    reduced
    by
    90-95
    percent,
    by
    weight,
    depending
    on
    the
    date
    that
    the afterburner
    or
    other
    control
    device
    was
    first
    constructed at the
    subject
    source,
    or
    to a
    maximum
    afterburner
    exhaust
    outlet
    concentration
    of
    20
    ppmv
    (as
    carbon).
    26

    The
    Illinois EPA
    proposes amending
    subsection
    (a)( 1 )(D)
    to delete references
    to
    monitoring
    requirements
    already
    set forth
    in
    Section
    218/219.410.
    The Illinois EPA
    proposes
    amending
    subsection
    (a)(4)
    to provide that, on
    and
    after
    May
    1, 2010,
    owners
    or operators
    of sources that
    meet the applicability
    criteria in
    Section
    218/219.405(c)(3)
    and do not certify
    pursuant
    to Section
    218/219.41 1(g)(1)(B)
    that
    the source will
    not make
    use
    of any of the
    exclusions
    in Section 218/219.405(c)(3)
    shall not
    cause or allow the use
    of
    a cleaning
    solution
    on
    any lithographic printing
    line
    unless
    the
    VOM content of the
    as-used cleaning
    solution
    is less
    than
    or equal to 70
    percent,
    by
    weight,
    or
    shall satisfy the alternative
    VOM
    composite
    partial
    vapor pressure
    limitation.
    The Illinois
    EPA
    proposes
    amending
    subsection
    (a)(5)
    to specify that the storage
    and disposal
    requirements
    for cleaning materials
    apply except
    when such
    materials are
    specifically
    in use.
    Section 218/219.408
    Compliance
    Schedule for
    Lithographic
    Printing
    On
    and After
    March 15,
    1996
    The Illinois EPA
    proposes
    repealing
    this
    Section, as the pertinent
    compliance
    dates are set forth in Section
    218/219.405.
    Section 218/219.409
    Testing for
    Lithographic
    Printing
    On
    and
    After
    March
    15,
    1996
    The Illinois
    EPA
    proposes deleting
    a reference
    to the previous
    compliance
    date of
    March 15,
    1996,
    in the title to this
    Section.
    Section 218/219.411
    Recordkeeping and
    Reporting
    for
    Lithographic
    Printing
    The
    Illinois
    EPA proposes
    amending
    this Section
    by deleting
    references
    to the
    previous
    compliance
    date
    of March
    15, 1996,
    and clarifying
    the requirements
    that apply
    27

    to
    sources
    prior
    to the
    new compliance
    date
    and
    those
    that
    apply on
    and after
    the
    new
    compliance
    date.
    The Illinois
    EPA
    also
    proposes
    inserting
    into
    this Section
    the
    equation
    for
    calculating
    maximum
    theoretic
    emissions
    of
    VOM,
    which
    was previously
    contained
    in Section
    218/219.406.
    The
    Illinois
    EPA
    proposes
    adding
    a
    new
    subsection
    (b),
    which
    contains
    recordkeeping
    and
    reporting
    provisions
    for
    printing
    lines
    that
    are exempt
    on
    and
    after
    May
    1,
    2010,
    and
    relettering
    the
    remaining
    subsections
    accordingly.
    Subsection
    (b)(
    1)
    governs
    lithographic
    printing
    lines
    exempt
    pursuant
    to
    Section
    218/219.405(c)(2).
    Along
    with
    standard
    recordkeeping
    and
    reporting
    requirements,
    the
    Illinois
    EPA
    proposes
    an
    emission
    adjustment
    factor
    to
    be used
    when
    determining
    VOM
    emissions
    from inks
    used
    on
    lithographic
    printing
    line(s)
    at the
    source,
    as
    well as
    an
    emission
    adjustment
    factor to
    be used
    when
    calculating
    emissions
    from
    used
    shop
    towels
    if the VOM
    composite
    vapor
    pressure
    of
    each associated
    cleaning
    solution
    is less
    than 10
    mniHg
    measured
    at 20°C
    (68°F)
    and
    the shop
    towels
    are kept
    in
    closed
    containers.
    The
    Illinois
    EPA proposes
    that,
    as an
    alternative
    to
    the
    VOM emission
    calculations
    set forth
    in subsection
    (b)(1)(B),
    a
    source
    may
    determine
    that
    it emits
    below
    6.8
    kg/day
    (15
    lbs/day)
    of
    VOM
    if it complies
    with
    material
    use limitations
    during
    each
    calendar
    month.
    The
    Illinois
    EPA
    proposes
    that
    the material
    use
    alternative
    only
    be
    available
    to
    sources
    with
    only
    one type
    of lithographic
    printing
    operation
    (e.g., a
    source
    with
    only
    heatset
    web
    offset
    lithographic
    printing
    operations).
    If
    a
    source
    exceeds
    the
    material
    use
    limitation
    in
    any
    given
    month,
    the
    source
    shall
    complete
    emissions
    calculations
    pursuant
    to
    subsection
    (b)(1)(B)
    within
    15
    days
    of
    the
    end of
    that month.
    If
    28

    a source
    exceeds
    the
    material
    use
    limitations
    for
    six
    consecutive
    months,
    the
    source
    is no
    longer
    eligible
    for
    the
    material
    use alternative.
    Subsection
    (b)(2)
    governs
    heatset
    web
    offset
    lithographic
    printing
    lines
    exempt
    pursuant
    to
    Section
    218!219.405(c)(1)
    but
    not
    exempt
    pursuant
    to Section
    218/21
    9.405(c)(2).
    Along
    with
    standard
    recordkeeping
    and
    reporting
    requirements,
    the
    Illinois
    EPA
    proposes
    an emission
    adjustment
    factor
    to be
    used
    when
    determining
    VOM
    emissions
    from
    inks
    used
    on lithographic
    printing
    line(s)
    at
    the
    source,
    and
    an
    emission
    adjustment
    factor
    to
    be
    used
    when
    calculating
    emissions
    from
    used
    shop
    towels
    if
    the
    VOM
    composite
    vapor
    pressure
    of
    each
    associated
    cleaning
    solution
    is
    less
    than
    10
    mmHg
    measured
    at
    20°C
    (68°F)
    and
    the
    shop
    towels
    are
    kept
    in
    closed
    containers.
    The Illinois
    EPA
    proposes
    amending
    subsection
    (c)
    to
    provide
    that
    the
    recordkeeping
    requirements
    in subsections
    (c)(
    1)
    or
    (c)(2)
    do
    not
    apply
    tc sources
    utilizing
    the
    material
    use limitation
    alternative.
    The
    Illinois
    EPA
    also
    proposes
    deleting
    subsection
    (c)(3).
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (d)
    to
    provide
    that
    sources
    complying
    with
    the
    add-on
    control
    device
    requirement
    shall
    include
    in
    their
    initial
    certification
    to
    the Illinois
    EPA
    the
    date that
    the device
    was
    first
    constructed
    at
    the
    subject
    source.
    The
    Illinois
    EPA
    also
    proposes
    amending
    subsection
    (d) to
    change
    the
    frequency that
    owners
    or
    operators
    of heatset
    web
    offset
    lithographic
    printing
    lines
    complying with
    the
    add-on
    control device
    requirements
    are
    required
    to
    check
    the air
    flow
    direction
    or
    air pressure
    of the
    dryer
    and
    press
    room
    from
    once
    a
    day
    to
    once
    per calendar
    month.
    29

    The
    Illinois EPA
    proposes
    amending
    subsection
    (e)(1)(C)
    to provide
    that a source
    subject
    to fountain
    solution
    VOM content
    limitations
    shall
    include in
    its initial
    certification
    a
    statement
    that the
    fountain
    solution
    will
    comply with
    the VOM
    content
    limitations
    in Section
    21
    8/219.407(a)(1)(A),
    (a)(2),
    or (a)(3),
    as
    applicable.
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (e)(2)(C)
    to provide
    that
    the
    weight
    of
    each
    component
    used in a fountain
    solution
    batch
    shall be recorded
    by
    sources, if
    applicable.
    The
    Illinois
    EPA
    also proposes
    deleting
    subsection
    (e)(4).
    The
    Illinois EPA
    proposes
    amending
    subsection
    (f)(1)
    to
    specify that
    lithographic
    printing
    line
    cleaning operations
    that are
    excluded
    pursuant
    to
    Section
    218/21 9.405(c)(3)(C)
    are not
    required to
    submit
    a certification
    pursuant
    to
    subsection
    (f).
    The Illinois
    EPA also
    proposes
    deleting
    subsections
    (f)(1)(A),
    (f)(1)(C),
    and
    (f)(4),
    and
    amending
    the
    relettered
    subsection
    (f)( 1 )(A)
    to provide
    that a
    source
    subject
    to
    the
    cleaning
    requirements
    in
    Section 218/219.407
    shall
    include
    in its
    initial
    certification
    a
    statement
    that
    the cleaning
    solution
    will
    comply
    with
    the
    limitations
    in
    Section
    21
    8/219.407(a)(4).
    The Illinois
    EPA
    proposes adding
    subsection
    (g),
    which
    sets
    forth
    the
    recordkeeping
    and
    reporting
    requirements
    for owners
    or operators
    of
    lithographic
    printing
    line(s)
    subject
    to
    one
    or more
    of
    the
    exclusions
    set
    forth
    in Section
    218/219.405(c)(3).
    Such
    owners
    or
    operators
    shall
    submit an
    initial
    certification
    to the
    Illinois
    EPA,
    collect
    and
    record
    specified
    information
    for each
    subject
    printing
    line,
    notify the
    Agency if
    the
    printing
    line
    ever becomes
    ineligible
    for
    the
    exclusions
    set forth
    in Section
    218/21
    9.405(c)(3),
    and, if changing
    between
    opting
    out of such
    exclusions
    and utilization
    30

    of
    the
    exclusions,
    submit
    an
    additional
    certification,
    informing
    the
    Illinois
    EPA
    of the
    change.
    The
    Illinois
    EPA
    proposes
    adding subsection
    (i),
    which
    sets
    forth
    emission
    adjustment
    factors
    that
    may
    be
    used
    when
    calculating
    VOM emissions
    from
    heatset
    web
    offset
    lithographic
    printing
    operations
    for
    purposes
    other
    than
    the
    applicability
    thresholds
    in
    Section
    218/219.405.
    Section
    218/219.412
    Letterpress
    Printing Lines:
    Applicability
    The
    Illinois EPA
    proposes
    adding
    this
    Section,
    which
    addresses
    the
    applicability
    of the
    proposed
    letterpress
    printing
    regulations.
    Subsection
    (a) of
    this
    Section
    provides
    that
    the
    limitations
    in
    Sections
    218/219.413
    through
    218/219.416
    apply
    to all
    owners
    or
    operators
    of
    heatset
    web
    letterpress
    printing
    lines
    if
    such
    lines
    (including
    solvents
    used
    for
    cleanup
    operations
    associated
    with
    such
    lines)
    at
    the
    source
    have
    a
    potential
    to
    emit
    22.7
    Mg
    (25
    tons)
    or
    more
    of
    VOM
    per
    year.
    Subsection
    (a)
    also
    provides
    that
    Sections
    218/219.413
    through
    218/219.416
    apply
    to
    all
    owners
    or
    operators
    of
    letterpress
    printing
    lines
    at
    sources
    where
    the
    combined
    emissions
    of
    VOM
    from
    all
    letterpress
    printing
    lines
    at
    the
    source
    (including
    solvents
    used
    for
    cleanup
    operations
    associated
    with
    the
    letterpress
    printing
    lines)
    ever
    equal
    or
    exceed
    6.8
    kg/day
    (15
    lbs/day),
    in
    the
    absence
    of
    air
    pollution
    control
    equipment.
    Subsection
    (b)
    provides
    that
    the
    requirements
    of Section 218/219.4l3(a)(2)
    shall
    not
    apply
    to up
    to 416.3
    liters
    (110
    gallons)
    per
    year
    of cleaning
    materials
    used
    on
    letterpress printing
    lines
    at
    a subject
    source.
    3

    Subsection
    (c)
    provides
    that,
    on and
    after
    May 1,
    2010,
    the recordkeeping
    and
    reporting
    requirements
    in
    Section
    218/219.417
    shall apply
    to all
    owners
    or
    operators
    of
    letterpress
    printing
    line(s).
    Subsection
    (d) provides
    that,
    if a
    letterpress
    printing
    line
    at
    a source
    is or
    becomes
    subject
    to one
    or more
    of the limitations
    in Section
    218/219.413,
    the
    letterpress
    printing
    lines
    at the
    source
    are
    always
    subject
    to the applicable
    provisions
    of Subpart
    H.
    Section
    218/219.413
    Emission
    Limitations
    and
    Control
    Requirements
    for
    Letterpress
    Printing
    Lines
    The
    Illinois
    EPA
    proposes
    adding
    this
    Section.
    Subsection
    (a) provides
    that
    heatset
    web
    letterpress
    printing
    lines
    that
    meet
    the
    applicability
    requirements
    of Section
    218/219.41
    2(a)(1)
    shall
    maintain
    the
    air pressure
    in
    the
    dryer
    lower
    than
    the
    air
    pressure
    of the press
    room
    and
    install
    and operate
    an
    afterburner
    that reduces
    VOM
    emissions
    by
    90-95
    percent,
    by
    weight,
    depending
    on
    the
    date that
    the
    afterburner
    was first
    constructed
    at the
    subject
    source,
    or to
    a
    maximum
    afterburner
    exhaust
    outlet
    concentration
    of
    20
    ppmv
    (as carbon).
    Such
    printing
    lines shall
    also
    equip
    the afterburner
    with
    applicable
    monitoring
    equipment
    and
    operate
    the
    afterburner
    at
    all
    times
    when the
    printing
    line
    is in
    operation,
    except
    as provided
    in Section
    218/219.107.
    Subsection
    (a)
    further
    provides
    that
    no
    owner
    or operator
    of
    subject
    letterpress
    printing
    lines
    shall
    use
    cleaning
    solutions
    on
    such
    lines
    unless
    the
    VOM
    content
    of the
    as
    used cleaning
    solution
    is less
    than
    or equal
    to
    70 percent,
    by weight,
    or
    the VOM
    composite
    partial
    vapor
    pressure
    of the
    as-used
    cleaning
    solution
    is less
    than
    10
    mmHg
    at
    20
    degrees
    Celsius.
    Cleaning
    materials
    must
    be kept,
    stored,
    and
    disposed
    of
    in
    closed
    containers,
    except
    when
    specifically
    in
    use.
    32

    Subsection
    (b) provides
    that
    heatset
    web letterpress
    printing lines may
    use a
    control
    device other than
    an afterburner
    if
    the control
    device meets the
    VOM emission
    reduction
    requirements
    in
    subsection
    (a)
    and is approved
    by the
    Illinois
    EPA
    and
    USEPA
    as federally enforceable
    permit
    conditions.
    Section 218/219.415
    Testing for
    Letterpress
    Printing Lines
    The Illinois EPA
    proposes
    adding this
    Section,
    which sets forth
    the testing
    requirements that apply
    to
    owners
    or
    operators
    of letterpress printing
    lines subject to
    Section 218/219.413.
    Subsection
    (a) provides that
    testing to demonstrate
    compliance
    with 218/219.413
    shall be conducted
    at the expense
    of the owner
    or operator within
    90
    days
    of
    a request
    by
    the
    Illinois
    EPA,
    and
    the
    owner or operator
    shall notify the Illinois
    EPA
    30 days in advance
    of conducting
    such
    testing.
    Subsection
    (b) describes
    the
    methods and
    procedures in Section
    218/219.105(d)
    and (f)
    that shall
    be used for testing
    to demonstrate
    compliance with
    the add-on
    control
    device requirements
    of Section
    218/219.413
    (a)( 1 )(B)
    and
    (b)( 1).
    Subsection
    (c) provides
    that testing
    to demonstrate
    compliance with the
    VOM
    content limitations
    in Section
    2l8/2l9.413(a)(2)(A)
    and
    to determine the VOM
    content
    of
    cleaning
    solvents, cleaning
    solutions, and inks
    shall be conducted
    using the applicable
    test
    methods
    and procedures
    in Section 218/219.105(a).
    The manufacturer’s
    specifications for
    VOM
    content for cleaning
    solvents
    and
    inks may be used
    if such
    specifications are based
    on results
    of tests conducted in
    accordance
    with
    Section
    218/219.105(a).
    33

    Subsection
    (d) provides
    that
    testing
    to demonstrate
    compliance
    with
    Section
    218/219.413(b)
    shall
    be
    conducted
    as
    set
    forth
    in the
    owner
    or
    operator’s
    plan
    approved
    by
    the Illinois
    EPA
    and
    USEPA
    as
    federally
    enforceable
    permit
    conditions.
    Subsection
    (e)
    provides
    that
    testing
    to determine
    the
    VOM
    composite
    partial
    vapor
    pressure
    of cleaning
    solvents,
    cleaning
    solvent
    cOncentrates,
    and
    as-used
    cleaning
    solutions shall
    be conducted
    in accordance
    with
    the
    applicable
    methods
    and procedures
    specified
    in
    Section
    218/219.110.
    Section
    218/219.416
    Monitoring
    Requirements
    for
    Letterpress
    Printing
    Lines
    The
    Illinois
    EPA
    proposes
    adding
    this
    Section.
    Subsection
    (a) provides
    that,
    if
    an
    afterburner
    is
    used
    to demonstrate
    compliance,
    the
    owner
    or
    operator
    of a
    heatset
    web
    letterpress
    printing
    line
    shall
    install,
    calibrate, maintain,
    and
    operate
    temperature
    monitoring
    devices
    with
    an
    accuracy
    of 3°
    C or
    F on
    the
    afterburner
    in accordance
    with
    Section
    218/219.1
    05(d)(2)
    and
    in accordance
    with
    the
    manufacturer’s
    specifications.
    Monitoring
    shall
    be performed
    at all
    times
    when
    the
    afterburner
    is
    operating.
    Such
    owners
    or
    operators
    shall also
    install,
    calibrate,
    operate,
    and
    maintain
    in
    accordance
    with
    manufacturer’s
    specifications
    a
    continuous
    recorder
    on
    the
    temperature
    monitoring
    devices
    with
    at
    least
    the
    same
    accuracy
    as
    the
    temperature
    monitor.
    Subsection
    (b)
    provides
    that if
    a control
    device
    other
    than
    an afterburner
    is used
    to
    demonstrate
    compliance,
    the
    owner
    or
    operator
    of
    a heatset
    web
    letterpress
    printing
    line
    shall
    install,
    maintain,
    calibrate,
    and
    operate
    such
    monitoring
    equipment
    as
    set forth
    in
    the owner
    or
    operator’s
    plan
    approved
    by the
    Illinois
    EPA
    and USEPA
    pursuant
    to
    Section
    218/219.413(b).
    34

    Subsection
    (c) sets forth
    the monitoring
    requirements for
    owners or operators of
    letterpress
    printing lines relying
    on the VOM
    content
    of the cleaning
    solution
    to
    comply
    with Section
    218/219.413
    (a)(2)(A),
    or relying on
    the vapor pressure
    of the cleaning
    solution
    to comply with Section
    218/219.413(a)(2)(B).
    Section
    218/219.417 Recordkeeping
    and
    Reporting
    for
    Letterpress Printing
    Lines
    The
    Illinois EPA proposes
    adding this
    Section.
    Subsection
    (a) provides
    that the
    owner or operator
    of a
    heatset web letterpress
    printing line
    exempt from
    any of the
    limitations of Section
    218/219.413
    because
    of the criteria
    in Section
    2l8/219.412(a)(1)
    shall submit
    a
    certification
    to the
    Illinois
    EPA
    that
    includes a declaration
    that the source
    is exempt and
    calculations that demonstrate
    that
    the source’s
    total potential to emit
    VOM
    does
    not
    equal or
    exceed 25
    tons per year.
    Subsection
    (b) provides
    that
    the
    owner
    or
    operator
    of a letterpress
    printing line
    exempt
    from any
    of the limitations of
    Section 218/219.413
    because
    of the criteria in
    Section
    218/2l9.412(a)(2)
    shall submit
    a certification
    to the Illinois
    EPA
    that includes
    a
    declaration
    that the source is exempt,
    calculations
    that demonstrate
    that
    combined
    emissions
    of VOM from
    all letterpress
    printing lines
    at the source
    never equal
    or
    exceed
    6.8
    kg/day
    (15
    lbs/day),
    and a
    description and the
    results of all tests
    used
    to determine
    the
    VOM
    content
    of inks and cleaning
    solvents. Such
    sources shall
    also
    notify the
    Agency if
    the
    combined
    emissions of VOM
    from all letterpress
    printing
    lines at the source
    ever
    equal or
    exceed 6.8 kg/day (15
    lbs/day).
    Subsection (b)
    further provides that,
    as
    an alternative
    to the
    VOM
    emission
    calculations
    set forth
    in subsection
    (b)(l)(B), a source may
    determine
    that it emits below
    6.8
    kg/day
    (15 lbs/day)
    of VOM if it complies
    with material
    use limitations
    during
    each
    35

    calendar
    month.
    The
    material
    use
    alternative
    shall
    only
    be
    available
    to
    sources
    with
    only
    one
    type
    of
    letterpress
    printing
    operation
    (e.g.,
    a
    source
    with
    only
    heatset
    web
    letterpress
    printing
    operations).
    If
    a source
    exceeds
    the
    material
    use
    limitation
    in
    any
    given
    month,
    the
    source
    shall
    complete
    emissions
    calculations
    pursuant
    to
    subsection
    (b)(1)(B)
    within
    15
    days
    of
    the
    end
    of
    that
    month.
    If
    a source
    exceeds
    the
    material
    use
    limitations
    for
    six
    consecutive
    months,
    the
    source
    is
    no longer
    eligible
    for
    the
    material
    use
    alternative.
    Subsection
    (c) provides
    that,
    unless
    utilizing
    the
    material
    use
    alternative,
    the
    owner
    or operator
    of a
    letterpress
    printing
    line
    subject
    to
    the
    requirements
    in
    subsection
    (a)
    or
    (b)
    of
    this Section
    shall
    collect
    and
    record
    either
    the
    specified
    standard
    recordkeeping
    information
    or
    the
    specified
    purchase
    and
    inventory
    recordkeeping
    information.
    Subsection
    (d)
    provides
    that
    the
    owner
    or
    operator
    of a heatset
    web
    letterpress
    printing
    line
    subject
    to
    Section
    2181219.413(a)(1)(B)
    or
    (b)(l)
    of
    this
    Subpart
    shall
    submit
    a
    certification
    to
    the
    Illinois
    EPA
    that
    includes
    identification
    of
    each
    heatset
    web
    letterpress printing
    line
    at
    the
    source,
    a declaration
    that
    each
    such
    line
    is
    in
    compliance
    with
    Section
    218/219.413(a)(1)
    or
    (b),
    the
    type
    of afterburner or
    other
    approved
    control
    device
    being
    used
    and
    the
    date
    that
    such
    device
    was
    first
    constructed
    at the
    subject
    source,
    the
    control
    requirements
    with
    which
    the printing
    line
    is complying,
    the
    results
    of
    all tests
    and
    calculations
    necessary
    to
    demonstrate
    compliance,
    and
    a declaration
    that
    the
    required
    monitoring equipment
    has
    been
    properly
    installed
    and
    calibrated.
    The
    owner
    or
    operator
    shall
    also
    collect
    and
    record
    specified
    information
    for
    each
    heatset
    web
    letterpress
    printing
    line
    and
    notify
    the Illinois
    EPA
    of any
    violation
    of
    Section
    218/219.413(a)(1)(B)
    or
    (b)(1).
    36

    operator
    shall
    also
    collect
    and
    record
    specified
    information
    for
    each
    heatset
    web
    letterpress
    printing
    line
    and
    notify
    the
    Illinois
    EPA
    of
    any violation
    of
    Section
    218/219.413(a)(l)(B)
    or
    (b)(l).
    Subsection
    (d) further
    provides
    that
    if
    testing
    of
    an afterburner
    or
    other
    approved
    control
    device
    is
    conducted
    pursuant
    to
    Section
    218/219.415(b),
    the owner
    or operator
    shall
    submit
    a copy
    of
    all
    test
    results
    to
    the
    Illinois
    EPA,
    as
    well
    as
    a certification
    that
    includes
    a
    declaration
    that
    all
    necessary
    tests
    and
    calculations
    have
    been
    performed,
    a
    statement
    whether
    the
    printing
    line
    is
    in
    compliance
    with
    Section
    218/219.413(a)(1)(B)
    or
    (b)(
    1),
    and
    the operating
    parameters
    of
    the
    afterburner
    or
    other
    approved
    control
    device
    during
    testing.
    If
    changing
    its
    method
    of
    compliance
    between
    subsections
    (a)(1)(B)
    and
    (b)
    of Section
    218/219.413,
    the
    owner
    or
    operator
    must
    certify
    compliance
    for
    the
    new
    method
    of
    compliance
    and
    perform
    all
    tests
    and
    calculations
    necessary
    to demonstrate
    compliance
    with
    such
    method.
    Subsection
    (e)
    establishes
    recordkeeping
    and
    reporting
    requirements
    for
    letterpress printing
    line
    cleaning
    operations.
    Subsection
    (e)
    provides
    that
    the
    owner
    or
    operator
    of
    a
    letterpress
    printing
    line
    shall
    certify
    to
    the Illinois
    EPA
    that
    all
    cleaning
    solutions,
    other
    than
    those
    excluded
    pursuant
    to Section
    2 18.412(b),
    and
    the
    handling
    of
    all
    cleaning
    materials
    will
    be
    in
    compliance
    with
    Section
    218/219.413(a)(2)(A)
    or
    (a)(2)(B)
    and
    (a)(3).
    The
    certification
    shall
    also include
    specified
    information
    regarding
    the
    cleaning
    operations of the
    subject
    printing
    line.
    The
    owner
    or
    operator
    shall
    collect
    and
    record
    specified
    information
    for
    each
    solution
    used
    on each
    letterpress
    printing
    line
    and
    notify
    the
    Illinois
    EPA
    of
    any
    violation
    of Section
    218/219.413.
    37

    Subsection
    (f)
    provides that
    the
    owner
    or
    operator
    of
    a
    printing
    line shall maintain
    all records
    required
    by
    this
    Section
    at the
    source for
    a minimum
    period
    of three
    years and
    shall make
    all
    records
    available
    to
    the
    Agency
    upon
    request.
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    C2
    Dana
    Vetterhoffe’
    Division
    of
    Legal
    Counsel
    DATED:
    July
    8,
    2009
    1021
    N.
    Grand
    Ave.
    East
    P.O. Box 19276
    Springfield,
    IL
    62794-9276
    (217) 782-5544
    38

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    THEMATTEROF:
    )
    AMENDMENTS
    TO 35
    ILL. ADM.
    CODE
    218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    STANDARDS
    FOR THE
    CHICAGO
    AREA,
    )
    35 ILL.
    ADM.
    CODE
    219,
    ORGANIC
    )
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    )
    CLERK’S
    OFFICE
    THE
    35 ILL.
    METRO
    ADM.
    EASTCODE
    AREA,
    211
    AND
    ))
    JUL
    S
    fJQ9
    MOTION
    FOR
    EXPEDITED
    REVIEW
    The
    Proponent,
    the Illinois
    Environmental
    Protection
    Agency
    (“Illinois
    EPA”),
    by its
    attorney,
    and
    pursuant
    to 35
    Ill. Adm.
    Code
    101.512,
    respectfully
    submits
    this
    Motion
    for
    Expedited
    Review
    (“Motion”).
    In
    support
    of
    its Motion,
    the
    Illinois
    EPA
    states
    as
    follows:
    1.
    Expedited
    review
    of
    this
    proposal
    is
    necessary
    because
    the
    Chicago
    and
    Metro
    East
    nonattainment
    areas (“NAA”)
    cannot
    be
    redesignated
    to
    attainment
    of the
    1997
    8-hour
    ozone
    National
    Ambient
    Air
    Quality
    Standard
    (“NAAQS”)
    until
    these proposed
    amendments are
    submitted
    to
    and approved
    by the
    United
    States
    Environmental
    Protection
    Agency
    (“USEPA”)
    as
    State
    Implementation
    Plan
    (“SIP”)
    revisions.
    2. Redesignation
    is
    necessary
    to (a)
    ensure
    that any
    potential
    future violations
    of the
    1997
    ozone
    standard
    do not
    result
    in
    a
    reclassification
    of
    the ozone
    NAAs;
    (b)
    mitigate
    the
    requirements
    that Illinois
    will
    be obligated
    to
    meet
    under
    USEPA’s
    future
    transition
    policy
    from
    the
    1997
    ozone
    standard
    to
    the strengthened
    2008
    standard;
    and
    (c)
    avoid
    any
    complications
    that
    may
    arise
    from
    such
    transition
    policy.
    Proposed
    Rulemaking
    3.
    The
    Illinois
    EPA’s
    rulemaking
    proposal
    is
    intended
    to
    satisfy
    Illinois’
    obligation
    to
    submit
    a
    SIP to
    address
    requirements
    under
    Sections
    172
    and 182
    of
    the
    Clean
    Air
    Act
    (“CAA”)
    1

    for
    sources
    of
    volatile
    organic
    material
    (“VOM”) emissions
    in areas
    designated
    as nonattainment
    with
    respect
    to
    the
    ozone
    NAAQS.
    4.
    Section
    1 82(b)(2)
    of the
    CAA
    provides
    that,
    for
    ozone
    NAAs,
    the
    State
    must
    revise
    its
    SIP
    to
    include
    reasonably
    available
    control
    technology
    (“RACT”)
    for
    sources
    of
    VOM
    emissions
    covered
    by a control
    techniques
    guideline
    (“CTG”) issued
    between
    November
    15,
    1990,
    and
    the
    date
    of attainment.
    42
    U.S.C.
    §
    7511a(b)(2).
    5 On
    October
    5, 2006,
    the
    USEPA issued
    final
    CTGs
    for
    Group
    II
    Consumer
    and
    Commercial
    Product
    Categories.
    This
    rulemaking
    is
    intended
    to
    implement
    the
    RACT
    recommendations
    contained
    in the
    CTGs.
    Attainment
    of
    the 1997
    8-hour
    Ozone
    NAAQS
    6.
    The
    Chicago
    NAA
    is
    currently
    attaining
    the
    1997
    ozone
    NAAQS
    (“1997
    standard”),
    and
    the Metro-East
    NAA
    is
    on
    track
    to
    attaining
    the
    standard
    in 2009,
    as
    required.
    In July
    2007
    and
    March
    2009,
    the
    Illinois
    EPA
    submitted
    to
    the
    USEPA
    attainment
    demonstrations
    for
    the
    1997
    standard
    for the
    Metro
    East
    and
    Chicago
    NAAs,
    respectively.
    7.
    Section
    107(d)(3)(E)
    of
    the CAA,
    however,
    provides
    that
    the
    USEPA
    may
    not
    redesignate
    a
    NAA
    unless
    the State
    has
    a
    fully-approved
    SIP
    for
    the
    area
    seeking
    redesignation
    and
    the State
    has
    met
    all applicable requirements
    of
    Section
    110
    and
    Part
    D
    (which
    includes
    the
    requirement that
    states
    adopt
    VOC
    RACT
    rules
    for categories
    covered
    by
    a CTG).
    42
    U.S.C.
    §
    7407(d)(3)(E).
    8:
    The
    Chicago
    and
    Metro
    East
    NAAs
    therefore
    cannot
    be
    redesignated
    to
    attainment
    of
    the 1997
    standard
    unless
    and
    until
    the
    Illinois
    EPA
    submits
    SIP
    revisions
    in response
    to
    Group
    II
    CTGs
    and
    the USEPA
    approves
    such
    revisions.

    Strengthened
    Ozone
    NAAQS
    9. On
    March
    27,
    2008,
    the
    USEPA
    finalized
    a strengthened
    8-hour
    ozone NAAQS
    (“revised
    standard”).
    73
    Fed.
    Reg.
    16436
    (March
    27, 2008).
    10.
    Tn March
    of 2009,
    the
    Illinois
    EPA
    recommended
    to
    the USEPA
    that
    the
    same
    areas
    in Illinois
    that
    are
    currently
    designated
    as nonattainment
    for the
    1997
    standard
    be
    designated
    as
    nonattainment
    for
    the
    revised
    standard
    as
    well, with
    the
    exception
    of
    Jersey
    County.
    11.
    The
    USEPA
    is
    expected
    to finalize
    nonattainment
    designations
    by March
    2010.
    In
    conjunction
    with final
    designations,
    the
    USEPA
    will
    issue
    guidance
    for
    states
    transitioning
    from
    the
    1997
    standard
    to the
    revised
    standard.
    Necessity
    of
    Expedited
    Review
    12.
    As
    stated
    above,
    the
    Chicago
    NAA
    currently
    qualifies
    for
    redesignation
    to attainment
    of the
    1997
    standard
    based
    upon
    2008 data,
    and
    the
    Metro-East
    NAA
    is expected
    to
    qualify
    for
    redesignation shortly.
    13.
    If
    either
    NAA
    violates
    the
    1997
    standard
    prior
    to formal
    redesignation,
    however,
    it is
    possible
    that
    such
    area
    would
    be
    “bumped
    up” from
    its
    current
    “moderate”
    nonattainment
    classification
    to a
    “serious”
    or
    higher
    classification.
    42
    U.S.C.
    §
    751
    la(b)(2).
    14.
    Areas
    designated
    as “serious”
    are subject
    to
    more
    stringent
    requirements,
    including
    a
    lower
    major
    source
    threshold,
    enhanced
    monitoring
    requirements,
    and a
    stricter
    emission
    offset
    ratio.
    See42
    U.S.C.
    §
    7511a(c).
    15.
    Violations
    of the
    1997
    standard
    that
    occur
    subsequent
    to redesignation,
    on
    the
    other
    hand, do
    not
    trigger
    reclassification.
    The
    area
    in
    which
    the
    violation
    occurred
    would
    merely
    be
    required
    to
    implement
    targeted
    control
    measures
    pursuant
    to
    contingency
    provisions
    contained
    in
    the area’s
    maintenance
    plan.
    See
    42
    U.S.C.
    §
    7505
    a.

    16.
    Redesignation
    is
    therefore
    necessary
    to foreclose
    the risk
    that
    a future
    violation
    of
    the
    1997 standard
    will
    implicate
    reclassification
    and,
    in
    turn, heightened
    control
    measures.
    17.
    Further,
    the USEPA’s
    future transition
    policy
    between
    the 1997
    standard
    and
    the
    revised
    standard
    will most
    likely impose
    additional
    obligations
    upon
    areas that are
    still
    designated
    as
    nonattainment
    for
    the 1997 standard
    at the
    time final
    designations
    for the
    revised
    standard
    are made.
    (See,
    e.g., 40
    C.F.R.
    §
    51
    .905(a)(1),
    which
    sets
    forth
    added
    requirements
    for
    areas
    that
    were
    nonattainment
    for the 1
    -hour ozone
    NAAQS
    at the time
    nonattaimment
    designations
    for
    the
    1997
    standard
    were
    finalized).
    18. Any
    complications
    that arise
    in
    connection
    with
    the future
    transition
    policy,
    such
    as
    legal challenges,
    could
    potentially
    affect
    such NAAs
    as well.
    Illinois, for
    example,
    was
    attaining
    the
    1-hour ozone
    standard but
    had not
    yet been
    formally
    redesignated
    at
    the time
    the USEPA
    finalized
    nonattainment
    designations
    for the 1997
    standard.
    Consequently,
    Illinois
    was subject
    to
    the
    USEPA’s
    1-hour/8-hour
    transition
    policies,
    and
    is still
    dealing with
    the ramifications
    of
    several lawsuits
    that
    arose
    challenging,
    among
    other things,
    the transition
    portions
    of
    USEPA’s
    8-hour
    implementation
    rules.
    (See,
    e.g., South
    Coast Air
    Quality
    Mgt.
    Dist. v.
    Environmental
    Protection
    Agency,
    472
    F.3d 882 (D.C.
    Cir. 2006)).
    (One
    such ramification,
    for
    instance,
    is the
    continued
    possibility
    that
    the major
    source
    threshold
    for
    the Chicago
    NAA will
    be lowered
    from
    100
    tons per year
    (the threshold
    for
    moderate
    areas
    under the
    8-hour
    standard)
    to 25 tons
    per year
    (the
    threshold
    for
    severe areas
    under the
    1-hour
    standard)).
    19. ‘While
    the details
    of
    USEPA’s
    transition
    policy, and
    whether
    such
    policy will
    likely
    result
    in litigation,
    is
    uncertain,
    a timely
    redesignation
    to
    attainment
    (i.e., redesignation
    prior to
    the
    date
    the
    USEPA
    finalizes
    nonattainment
    designations
    for the revised
    standard)
    would
    render
    the
    above
    contingencies
    moot.
    4

    20. Redesignation
    is
    needed
    to
    ensure that
    Illinois
    avoids
    needless
    additional
    hurdles
    and
    reaps
    the benefits
    of the
    air quality
    planning
    efforts
    that
    led to
    attainment
    of the
    1997
    standard.
    21. In
    light
    of the
    foregoing,
    it
    is necessary
    to
    expedite
    review
    in
    this matter.
    22.
    As
    required
    by 35
    Iii. Adm.
    Code
    Section
    101.5
    12,
    this Motion
    is accompanied
    by
    an
    Affirmation
    attesting
    that
    the facts
    cited
    herein
    are
    true.
    WHEREFORE,
    for
    the
    reasons
    set forth
    above,
    the
    Illinois
    EPA
    respectfully
    requests
    that
    the
    Board
    grant
    this Motion
    and
    expedite
    review
    in
    this
    matter.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    (2
    Dana
    Vetterhoffer
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    DATED:
    July
    8,
    2009
    1021
    N. Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544
    5

    BEFORE THE
    ILLINOIS POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER OF:
    )
    )
    R09-
    AMENDMENTS
    TO 35 ILL.
    ADM. CODE 218,
    )
    (Rulemaking-Air)
    ORGANIC
    MATERIAL
    EMISSION
    )
    STANDARDS
    FOR
    THE
    CHICAGO AREA,
    )
    35 ILL.
    ADM. CODE
    219,
    ORGANIC
    )
    MATERIAL
    EMISSION STANDARDS
    FOR
    )
    THE METRO
    EAST AREA,
    AND
    )
    35 ILL. ADM.
    CODE
    211
    AFFIRMATION
    I, Dana Vetterhoffer,
    under oath, hereby
    state and
    affirm that I am
    an Assistant
    Counsel
    for the
    Illinois
    EPA
    and
    that the facts cited
    in the
    foregoing
    Motion
    for Expedited Review
    are
    true and correct to
    the best
    of
    my information and belief.
    c
    Dana Vetterhoffer
    Assistant
    Counsel
    Division
    of Legal Counsel
    SUBSCRIBED
    AND
    SWORN TO BEFORE
    ME
    thisayof
    Scj
    )
    ,2009
    Notary Public
    OFFICIAL
    SEAL
    ±
    :
    BRENDA
    BOENNER
    :
    ::
    NOTARY
    PUBLIC,
    STATE
    OF
    ILUNOIS
    MY
    COMMISSION
    XPIR6
    ii
    aouo
    6

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    )
    AMENDMENTS
    TO
    35
    ILL.
    ADM.
    CODE
    218,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    35
    ILL.
    ADM. CODE
    219,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    METRO EAST
    AREA,
    AND
    35
    ILL.
    ADM.
    CODE
    211
    CLERK’S
    OFFICE
    JUL
    u
    92009
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    B0rd
    I,
    the
    undersigned,
    an
    attorney,
    state
    that
    I
    have
    served
    the
    attached
    REGULATORY
    PROPOSAL
    entitled
    “AMENDMENTS
    TO
    35
    ILL.
    ADM.
    CODE
    218,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    CHICAGO
    AREA,
    35
    ILL.
    ADM.
    CODE
    219,
    ORGANIC
    MATERIAL
    EMISSION
    STANDARDS
    FOR
    THE
    METRO
    EAST
    AREA,
    AND
    35
    ILL.
    ADM.
    CODE
    211,”
    MOTION
    FOR
    WAIVER,
    MOTION
    FOR
    EXPEDITED
    REVIEW,
    and
    APPEARANCES
    of
    the
    Illinois
    Environmental
    Protection
    Agency
    upon
    the
    person
    to
    whom
    it
    is
    directed,
    by
    mailing
    it
    by
    first-class
    mail
    from
    Springfield,
    Illinois,
    with
    sufficient
    postage
    affixed, to
    the
    following
    persons:
    John
    Therriault,
    Assistant
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center
    100
    West
    Randolph,
    Suite
    11-500
    Chicago,
    Illinois
    60601-3218
    Virginia
    Yang
    Deputy
    Legal
    Counsel
    Illinois
    Department
    of
    Natural
    Resources
    One
    Natural
    Resources
    Way
    Springfield,
    IL
    62702
    Matthew
    Durm,
    Chief
    Division of
    Environmental
    Enforcement
    Office
    of
    the
    Attorney
    General
    188
    West
    Randolph,
    20
    th
    Floor
    Chicago,
    IL
    60601
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    C.n
    Dana
    Vetterhoffer
    //
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    )
    (Rulemaking-Air)
    )
    )
    )
    )
    )
    )
    CERTIFICATE
    OF
    SERVICE

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