1. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      2. NOTICE
      3. THIS FILING IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PETITION OF ROYAL FIBERGLASS POOLS,
)
INC. FOR AN ADJUSTED STANDARD FROM )
35 ILL. ADM.
CODE 215.301
)
AS 2009-04
(Adjusted Standard-Air)
TO:
John Theniault, Assistant Clerk
Illinois
Pollution Control Board
James
R. Thompson Center
100 West Randolph, Suite 11-500
Chicago, lllinois 60601-3218
Dale
A.
Guariglia
Brandon W. Neuschafer
Bryan Cave
LLP
)
NOTICE
Carol Webb, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph, Suite 11-500
Chicago, Illinois 60601-3218
One
Metropolitan Square, Suite 3600
211 N. Broadway
S1. Louis, MO 63102-2750
PLEASE
TAKE NOTICE that
I
have today filed with the Office of the Pollution Control Board
the ILLINOIS
EPA'S RESPONSE TO OUESTIONS POSED BY THE ILLINOIS POLLUTION
CONTROL BOARD
IN THE MATTER OF ROYAL FIBERGLASS POOLS' PETITION FOR
AN ADJUSTED STANDARD of the Illinois Environmental Protection Agency a copy of which
is herewith served upon you.
DATED:
October 14, 2009
1021
North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
217.782.5544
217.782.9143 (TDD)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By: /s/ Charles E. Matoesian
Charles E. Matoesian
Assistant Counsel
Division
of Legal Counsel
THIS FILING IS SUBMITTED
ON
RECYCLED PAPER
Electronic Filing - Received, Clerk's Office, October 14, 2009
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
)
)
PETITION OF ROYAL FIBERGLASS POOLS,
)
INC. FOR AN ADJUSTED STANDARD FROM )
35 ILL. ADM. CODE 215.301
)
)
AS 2009-04
(Adjusted Standard-Air)
ILLINOIS EPA'S RESPONSE TO OUESTIONS POSED BY THE ILLINOIS
POLLUTION CONTROL BOARD IN THE MATTER OF ROYAL FIBERGLASS
POOLS' PETITION FOR AN ADJUSTED STANDARD
NOW COMES Respondent, ILLINOIS ENVIRONMENTAL PROTECTION AGENCY ("Illinois EPA"
or "Agency"), by its attorney, Charles E. Matoesian, and files this response to the questions of the Illinois
Pollution Control Board's
("Board") attached to the Hearing Officer's Order of June 4, 2009.
28.
I.
e
2.
If
granted, will the adjusted standard be submitted to USEPA for inclusion in the Illinois SIP?
Yes.
104.406(d)
5. Please describe the area affected. What
is
the ozone attainment status of the county in which
the Dix Plant
is
located? Is the ozone attainment status poised to he changed in the near future?
The Dix Plant is in Jefferson County. This county is currently in attainment with the Ozone
NAAQS, and no change in the county's attainment status is imminent.
104.406(j)
19. Tllis question is addressed to botll tile petitioner and the Agency: The Air Quality Impact
Analysis
for ozone was performed based on the assumption that
25
tons per year would he the
maximum
VOM emitted and that the I-hour ozone standard is 120 ppb. However, there are no
limitations proposed
in the adjusted standard language.
(a) Would you please comment
on proposing a condition in the adjusted standard language that
would limit VOMs to
25
tpy or less.
IEPA has no objection to an annual YOM emission limit being included in the adjusted standard
language.
(b) Would you also please comment on proposing a condition that would require are-evaluation
of the adjusted standard
if
the ozone NAAQS
is
revised.
Electronic Filing - Received, Clerk's Office, October 14, 2009
!EPA believes that a condition requiring re-evaluation is necessary in this rulemaking. If, in the
future, changes in the ozone
NAAQS status to non-attainment for the Dix Plant location, the
Illinois
EPA will conduct a re-evaluation of emission limits on all major sources in the
nonattainment area as part
of the SIP process. If changes are deemed necessary, the Illinois EPA
will initiate a rulemaking before the Board at that time.
l04.406(g)
21. This question is addressed to both petitioner and the Agency: The petition on page 10
states,
"Royal understands that
in
2005, EPA replaced the one-hour average ozone standard
with an eight-hour average standard, but believes the hourly calculation presented
in
the
attached Air Quality Impact Analysis
is
useful given the obvious concerns about hourly
emissions that are reflected
in the
8
lblhr Rule. "
As of March 2008, the primary ozone standard was strengthened from 0.08 parts per million
(ppm), set
in
1997
to a level of 0.075 ppm averaged over
8
hours
(73
FR16436; March 27,
2008).
(a) Since the Air Quality Impact Analysis presented in the Technical Document Section 6
is
based on the previous ozone standard, would you please provide an analysis of ozone impact
in terms of the current ozone NAAQS?
IEPA believes the air quality impact of the adjusted standard to be negligible. This is also
IEPA's response to the next three questions: (b), (c), and (d).
(b) Is the SchefJe (Sept.
1988)
procedure and table used in Royal Pool's Air Quality
Impact Analysis (TSD Sec.
6)
the same for determining the ozone increment for either I-hour as
well as 8-hour periods of time?
(c) Is the SchefJe (Sept.
1988)
procedure still the USEP A recommended procedure?
(d) Please comment on the results of the Air Quality Impact Analysis
if
the ozone
increment were added to the 8-hour background air quality reading
of the 4th highest measured
ozone concentration from the
past
4
consecutive years.
(e) Has the IEPA provided any guidance in conducting the Air Quality Impact Analysis
or indicated appropriate measures
if
the ozone increment appears to cause or be contributing to
a violation
of the ozone NAAQS?
IEPA provided no guidance to the petitioner in conducting the Air Quality Impact Analysis, but
the Illinois EPA still uses the Scheffe procedure to evaluate ozone impacts from single sources.
USEPA has not provided more recent guidance to address ozone impacts on an 8-hour basis.
22. This question is addressed to both the petitioner and the Agency: The Petition at page 12
states,
" ... the daily amounts ofVOM emitted by Royal's operations have a negligible impact on
ambient ozone levels and would not cause a violation
of the ozone NAAQS ... "Since Hamilton
County ozone monitoring stations already show exceedences
of the 8-hour ozone standard of
75
ppb, would you please comment on including a condition in the adjusted standard limiting Royal
Pools
VOM emilling operations on ozone action days where ambient conditions are likely to
exceed the
75
ppb 8-hour ozone standard?
Electronic Filing - Received, Clerk's Office, October 14, 2009
IEPA has no objection to a condition that would limit Royal Pools VOM emitting operations on
ozone action days.
DATED: October
14,2009
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
21717782-5544
(217)782-9807 Facsimile
Respectfully submitted,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
By:
/s/ Charles E. Matoesian
Charles
E. Matoesian
Assistant Counsel
Division
of Legal Counsel
STATE OF ILLINOIS
COUNTY OF SANGAMON
)
)
)
SS
CERTIFICATE
OF SERVICE
I, the undersigned, an attorney, state that I have served electronically the attached
ILLINOIS
EPA'S RESPONSE TO OUESTIONS POSED
BY
THE ILLINOIS POLLUTION
CONTROL
BOARD IN THE MA TIER OF ROYAL FIDERGLASS POOLS' PETITION FOR
AN ADJUSTED STANDARD, upon the following persons:
John Therriault, Assistant Clerk
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph St., Suite 11-500
Chicago, IL 6060 I
Dale
A.
Guariglia
Brandon
W. Neuschafer
Bryan Cave
LLP
One
Metropolitan Square, Suite 3600
211 N. Broadway
St. Louis,
MO 63102-2750
Dated: October 14, 2009
\021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
217.782.5544
217.782.9143 (TDD)
Carol Webb, Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center
100 West Randolph St., Suite 11-500
Chicago, IL 60601
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
/s/ Charles E. Matoesian
Charles
E. Matoesian
Assistant Counsel
Division
of Legal Counsel
Electronic Filing - Received, Clerk's Office, October 14, 2009

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