BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    iN
    THE
    MATTER
    OF:
    )
    REASONABLY
    AVAILABLE
    CONTROL
    ))
    RiO-
    (Rulemaking-Air)
    jO
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    ORGANIC MATERIAL
    EMISSIONS
    FROM
    )
    GROUP
    III CONSUMER
    &
    COMIvIERCLkL
    )
    CLERK’S
    OFFf
    CE
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    TO
    35
    ILL.
    ADM.
    CODE
    218
    and
    219
    )
    OCt
    232009
    TABLE
    OF
    CONTENTS
    pjJj
    1.
    Notice
    of Filing
    2. Appearance
    of
    Dana
    Vetterhoffer,
    Assistant
    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 Copy
    Requirements
    8.
    Fast
    Track
    Rulemaking
    Cover
    Sheet
    9.
    Statement
    of
    Reasons
    10. Proposed Amendments
    to 35
    Ill.
    Adm.
    Code
    Parts
    218
    and
    219
    11. Technical
    Support
    Document
    for
    Control
    of Volatile
    Organic
    Material
    Emissions
    in
    Non-Attainment
    Areas
    from
    Paper,
    Film,
    and
    Foil
    Coatings,
    Large
    Appliance
    Coatings,
    and
    Metal
    Furniture
    Coatings,
    AQPSTRO9-
    10,
    Illinois
    Environmental
    Protection
    Agency,
    July
    2009
    12.
    Documents
    Relied
    Upon:
    Control
    Techniques
    Guidelines
    for
    Paper,
    Film,
    and
    Foil
    Coatings,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of
    Air
    Quality
    Planning
    and
    Standards,
    Research
    Triangle
    Park,
    NC,
    September
    2007.
    1

    Control
    Techniques Guidelines
    for Metal
    Furniture Coatings,
    United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air Quality
    Planning
    and
    Standards,
    Research
    Triangle Park,
    NC, September
    2007.
    Control Techniques
    Guidelines
    for Large
    Appliance Coatings,
    United States
    Environmental
    Protection Agency,
    Office
    of Air Quality
    Planning
    and
    Standards,
    Research
    Triangle Park,
    NC, September
    2007.
    Illinois Environmental
    Protection
    Act
    (415 ILCS 5/et
    seq.)
    Clean
    Air
    Act (42
    U.S.C. 7401
    et seq.)
    13. Certificate
    of
    Service
    14. First Notice
    Forms
    15.
    Disk
    in
    Microsoft
    WORD containing
    Agency’s
    Proposed
    Amendments
    to Parts
    218
    and
    219, and First Notice
    Forms
    2

    BEFORE
    THE JLLINOIS POLLUTION
    CONTROL BOARD
    IN
    THE MATTER OF:
    REASONABLY AVAILABLE
    CONTROL
    TECHNOLOGY
    (RACT) FOR VOLATILE
    ORGANIC MATERIAL
    EMISSIONS FROM
    GROUP Ill CONSUMER
    & COMMERCIAL
    PRODUCTS:
    PROPOSED AMENDMENTS
    TO 35 ILL.
    ADM.
    CODE 218
    and 219
    To:
    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
    CLERK’S
    OFFICE
    OCT232
    009
    NOTICE
    STATE
    OF
    ILLINOIS
    POl1tjon
    Control
    Board
    Matthew
    Dunn, Chief
    Division
    of
    Environmental
    Enforcement
    Office of
    the
    Attorney
    General
    69
    W. Washington, Suite 1800
    Chicago, IL 60602
    PLEASE TAKE NOTICE that I
    have
    today filed with
    the Office
    of
    the
    Pollution
    Control
    Board
    the
    REGULATORY PROPOSAL entitled “REASONABLY AVAILABLE
    CONTROL
    TECHNOLOGY (RACT)
    FOR
    VOLATILE ORGANiC MATERIAL EMISSIONS FROM
    GROUP
    III CONSUMER & COMMERCIAL PRODUCTS: PROPOSED AMENDMENTS
    TO
    35 ILL.
    ADM.
    CODE 218
    and 219,”
    MOTION FOR
    WAiVER
    OF COPY REQUIREMENTS,
    and APPEARANCE
    of
    the
    Illinois Environmental Protection
    Agency, a
    copy of which is
    herewith
    served upon you.
    Respectfully submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION AGENCY
    By:2
    Dana Vet
    Assistant Counsel
    Division of
    Legal
    Counsel
    RiO-
    /0
    )
    (Rulemaking-Air)
    )
    )
    )
    )
    )

    DATED:
    October
    23,
    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:
    )
    )
    Rio-I
    REASONABLY
    AVAILABLE
    CONTROL
    )
    (Rulemaking-Air)
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    ORGANIC
    MATERIAL
    EMISSIONS
    FROM
    )
    ‘k’S
    PRODUCTS:
    GROUP
    III
    CONSUMER
    PROPOSED
    &
    AMENDMENTS
    COMMERCIAL
    ))
    Q(
    23
    2009
    TO
    35
    ILL.
    ADM.
    CODE 218
    and
    219
    )
    30
    iTE
    gFILLIN
    01
    APPEARANCE
    The
    undersigned
    hereby
    enters
    her
    appearance
    as
    an
    attorney
    on
    behalf
    of
    the
    Illinois
    Environmental
    Protection
    Agency.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    ByZ,-
    24
    Dana
    Vetterhoffer
    Assistant
    Counsel
    7/
    Division
    of
    Legal
    Counsel
    DATED:
    October
    15,
    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:
    )
    RiO-
    /0
    REASONABLY
    AVAILABLE
    CONTROL
    )
    (Rulemaking-Air)
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    GROTJP
    ORGANIC
    III
    MATERIAL
    CONSUMER
    EMISSIONS
    &
    COMMERCIAL
    FROM
    )
    )
    OC
    ‘3
    200,9
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    jT
    0
    TO 35
    ILL. ADM.
    CODE
    218
    and
    219
    )
    IL’
    Lillon
    Contrj01S
    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:_____________
    Dougl
    1
    P.
    Scott
    Direc6r
    DATED:
    ()Hber
    S
    ,
    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:
    )
    REASONABLY
    AVAILABLE
    CONTROL
    ))
    RE-
    (Rulemaking-Air)
    j0
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    ORGANIC
    MATERIAL
    EMISSIONS
    FROM
    )
    ERKS
    OFFICE
    GROUP
    III
    CONSUMER
    &
    COMMERCIAL
    )
    OCT
    23
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    g
    TO
    35
    ILL.
    ADM.
    CODE
    218
    and
    219
    )
    STATE
    OF
    I
    JJj
    COflfr
    0
    l
    Board
    CERTIFICATION
    OF
    REQUIRED
    RULE
    The
    Illinois
    Environmental
    Protection
    Agency
    certifies
    in
    accordance
    with
    35
    Ill.
    Adm.
    Code
    102.202(h)
    and 102.500,
    and
    415
    ILCS
    5/28.2(b),
    that
    it
    believes
    that
    this
    proposal
    for
    amendments
    to
    35
    Ill.
    Adm.
    Code
    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)(l)
    and
    751
    la(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.
    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.
    §
    7511
    a(b)(2).
    1

    The
    proposed
    amendments
    are intended
    to
    establish
    RACT
    requirements
    for
    Group
    III
    Consumer
    and
    Commercial
    Product
    categories
    in response
    to
    CTGs
    issued
    by the
    United
    States
    Environmental Protection
    Agency
    on
    October
    9,
    2007,
    and
    thereby
    satisfy
    the
    CAA
    requirements
    described
    above.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana
    Vetterhoffer
    Assistant
    Counsel
    Division
    of
    Legal
    Counsel
    DATED:
    October
    15, 2009
    1021 N.
    Grand
    Ave.
    East
    P.O.
    Box
    19276
    Springfield,
    IL
    62794-9276
    (217)
    782-5544
    2

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    )
    Rio-
    I
    REASONABLY
    AVAILABLE
    CONTROL
    )
    (Rulemaking-Air)
    TECHNOLOGY
    (RACT)
    FOR VOLATILE
    )
    ORGANIC
    MATERIAL
    EMISSIONS
    FROM
    )
    GROUP
    III
    CONSUMER
    & COMMERCIAL
    )
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    TO
    35
    ILL.
    M.
    CODE
    218
    and
    219
    )
    2009
    /
    o,
    CERTIFICATION
    OF
    ORIGINATION
    0
    ‘7troi
    Board
    The
    Illinois
    Environmental
    Protection
    Agency
    certifies
    in
    accordance
    with
    35
    Iii.
    Adm.
    Code
    102.202(i)
    that
    this
    proposal
    for
    amendments
    to
    35
    Ill.
    Adm.
    Code
    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:
    14i7124-
    Dana
    Vetterhoffer
    Assistant
    Counsel
    //
    Division
    of
    Legal
    Counsel
    DATED:
    October
    15,
    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
    TArp
    OF
    ILLINOIS
    Agency:
    Illinois
    Pollution
    Control Board
    Control
    Board
    Part/Title:
    Organic
    Material
    Emission
    Standards
    and
    Limitations
    for the Chicago
    Area
    (35
    Ill. 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.
    -$13,OOO
    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
    TSP.
    Dollar
    amount
    per ton
    of VOM emissions
    reduced:
    Affected
    paper, film
    and
    foil coaters:
    $0-i
    ,200/ton
    Affected
    large
    appliance
    coater:
    $0-500/ton
    Affected metal
    furniture coater:
    $0-200/ton
    Total
    statewide
    cost:
    Affected
    paper,
    film and foil
    coaters:
    $0-25,740/year
    Affected
    large
    appliance
    coater:
    $0/year
    (No affected
    source)
    Affected
    metal
    furniture coater:
    $0/year
    (No
    affected source
    is expected
    to
    need
    additional
    control)

    (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.

    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.
    —$1,2OO
    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
    ton of VOM
    emissions
    reduced:
    Affected
    paper,
    film and
    foil coaters:
    $O-1,200/ton
    Affected large
    appliance
    coater:
    $0-500/ton
    Affected
    metal furniture
    coater:
    SO-200/ton
    Total
    statewide
    cost:
    Affected
    paper,
    film
    and foil
    coaters: $0/year
    year
    (No affected
    source
    is
    expected to
    need additional
    control)
    Affected
    large appliance
    coater:
    $0/year (No
    affected source)
    Affected
    metal furniture
    coater:
    $0/year (No
    affected
    source)

    (b)
    If
    an economic
    effect
    is
    predicted,
    please
    briefly
    describe
    how
    the
    effect
    will
    occur. Costs
    clue
    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:
    )
    REASONABLY
    AVAILABLE
    CONTROL
    ))
    RiO-(Rulemaking-Air)
    JO
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    ORGANIC
    MATERIAL
    EMISSIONS
    FROM
    )
    GROUP
    III
    CONSUMER
    &
    COMMERCIAL
    )
    S
    °F7c
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    OCr
    TO35ILL.ADM.CODE218and219
    )
    2
    2
    09
    °11Ut(fl
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    MOTION
    FOR
    WAIVER
    OF
    COPY
    REQUIREMENTS
    The Proponent,
    the
    Illinois
    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
    submit
    the
    original
    and
    nine
    copies
    of
    the
    regulatory
    proposal
    including
    all
    documents
    relied
    upon,
    and
    waive
    the
    requirement
    that
    the
    Illinois
    EPA
    provide
    copies
    of
    certain
    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.
    This
    entire
    regulatory
    proposal
    consists
    of
    approximately
    400
    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.
    2.
    Section
    27(a)
    of
    the
    Environmental
    Protection
    Act
    requires
    that
    the
    Illinois
    EPA
    provide
    information
    supporting
    the
    proposal.
    415
    ILCS 5/27(a).
    Two
    of
    the
    documents
    relied
    upon
    by
    the
    Illinois
    EPA,
    the
    Illinois
    Environmental
    Protection
    Act
    and
    the
    Clean
    Air
    Act,
    are
    readily
    accessible
    to
    or
    are
    within the
    possession
    of
    the
    Board.
    Given
    the
    ease
    of
    accessibility
    of
    these
    documents,
    listed
    as
    items ‘d’
    and
    ‘e’
    below,
    the
    Illinois
    EPA
    moves
    that
    the
    Board
    waive
    1

    the
    requirement
    that the Illinois
    EPA provide
    copies
    of
    such
    documents.
    The
    Illinois
    EPA
    has
    otherwise provided documents
    which
    were
    directly
    relied
    upon
    when drafting the
    regulatory
    proposal. The
    documents
    relied
    upon
    are
    as follows:
    a. Control Techniques
    Guidelines
    for Paper,
    Film,
    and
    Foil Coatings,
    United States
    Environmental
    Protection
    Agency,
    Office
    of Air
    Quality Planning and
    Standards,
    Research
    Triangle
    Park,
    NC, September
    2007.
    b.
    Control
    Techniques Guidelines
    for Metal
    Furniture
    Coatings, United
    States
    Environmental
    Protection
    Agency,
    Office
    of Air
    Quality Planning
    and Standards,
    Research
    Triangle Park,
    NC, September
    2007.
    c.
    Control
    Techniques Guidelines
    for Large
    Appliance
    Coatings, United
    States
    Environmental
    Protection
    Agency,
    Office
    of
    Air
    Quality Planning
    and Standards,
    Research
    Triangle Park,
    NC,
    September
    2007.
    d.
    Illinois
    Environmental Protection
    Act
    (415 ILCS 5/et
    seq.).
    e.
    Clean Air Act (42
    U
    .S.C. 7401 et
    seq.).
    WHEREFORE,
    the Illinois
    EPA moves
    that the
    Board waive
    the requirement
    that
    the
    Illinois EPA
    provide copies of
    the documents
    listed as items
    ‘d’ and
    ‘e’ above, and waive
    the
    requirement that the Illinois
    EPA
    provide
    an
    original and
    nine copies
    of the remaining
    documents in its proposal.
    Respectfully
    submitted,
    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana Vetterhoffer
    Assistant
    Counsel
    Division
    of Legal
    Counsel
    2

    DATED:
    October
    15,
    2009
    1021
    N. Grand
    Ave. East
    P.O.
    Box 19276
    Springfield,
    IL 62794-9276
    (217)
    782-5544
    3

    L
    18
    0cr2
    32009
    OfIUuIJfl
    g’4LLiNo,
    8
    8
    oard
    THIS
    IS
    A
    FAST
    TRACK
    R
    ULEMAKING
    FILED
    IN ACCORDANCE
    WITH
    SECTION 28e5
    OF THE
    ENVIRONMENTAL
    PROTECTION
    ACT
    (415
    ILCS
    5/28.5)

    BEFORE
    THE ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    IN
    THE
    MATTER
    OF:
    )
    REASONABLY
    AVAILABLE
    CONTROL
    )
    )
    RiO-(Rulemaking-Air)
    jO
    TECHNOLOGY
    (RACT)
    FOR
    VOLATILE
    )
    ORGANIC
    MATERIAL
    EMISSIONS
    FROM
    )
    GROUP
    III
    CONSUMER
    &
    COMMERCIAL
    )
    CLJIfb
    PRODUCTS:
    PROPOSED
    AMENDMENTS
    )
    °FIcE
    TO
    35
    ILL.
    ADM.
    CODE 218
    and
    219
    )
    OCT
    232009
    STATEMENT
    OF
    REASONS
    ‘OIIUtTo
    LINois
    I.
    INTRODUCTION
    The
    Illinois
    Environmental
    Protection
    Agency
    (“Illinois
    EPA”) submits
    this
    Statement
    of
    Reasons
    to
    the
    Illinois Pollution
    Control
    Board
    (“Board”)
    pursuant
    to
    Sections
    10,
    27,
    and
    28.5
    of
    the
    Environmental
    Protection
    Act
    (“Act”)
    (415
    ILCS
    5/10,
    27,
    and
    28.5)
    and
    35
    Iii.
    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
    III
    Consumer
    and
    Commercial
    Product
    Categories:
    Paper,
    Film,
    and
    Foil
    Coatings,
    Metal
    Furniture
    Coatings,
    and
    Large
    Appliance
    Coatings.
    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.
    §S
    7502
    and
    7511a.
    Section 172(c)(i)
    of
    the
    CAA provides
    that
    states
    must
    include
    in their
    SIPs
    for

    nonattainment areas
    (“NAAs”) “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
    NAAs,
    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.
    §
    7511a(b)(2).
    Illinois is proposing
    reasonable and cost
    effective
    VOM
    controls
    for
    Group III
    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,
    and 35 Iii.
    Adm.
    Code Part 219, Organic
    Material
    Emission
    Standards
    and
    Limitations
    for the
    Metro
    East
    Area.
    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.
    §sS
    7408-7409.
    A.
    8-Hour
    Ozone NAAQS
    Ozone
    occurs
    both in the Earth’s
    upper
    atmosphere
    and at
    ground
    level.
    VOM
    is
    a
    primary
    precursor
    to the formation
    of ground-level
    ozone,
    which
    is formed when
    oxides
    of
    nitrogen
    and VOM
    react in the atmosphere
    in the
    presence
    of sunlight.
    Ground-level
    2

    ozone
    is a
    major
    component
    of
    smog.
    72
    Fed.
    Reg.
    57217
    (Oct.
    9,
    2007).
    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
    conditions,
    including
    acute
    respiratory
    symptoms,
    increased
    susceptibility
    to respiratory
    infection,
    and
    pulmonary
    inflammation.
    72
    Fed.
    Reg.
    57217.
    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.
    CAA
    Requirements
    1.
    Consumer
    and
    Commercial
    Products.
    Group
    III
    Section
    183(e)
    of the
    CAA
    required
    that
    USEPA
    conduct
    a
    study
    of the
    emissions
    of
    VOM 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
    VOM
    from
    such
    products.
    72
    Fed.
    Reg.
    57217. 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 VOM 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 VOM which
    contribute to ozone levels
    in ozone NAAs. 42
    U.S.C.
    §
    7511b(e)(3)(C).
    cTGs provide states
    with
    recommendations
    regarding what
    types of controls could
    constitute
    RACT for VOM for
    the applicable
    source categories.
    72 Fed. Reg. 572 17-
    572
    18.
    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. 72 Fed. Reg.
    57218.
    On October 9,
    2007, the
    USEPA issued final
    CTGs for
    three
    Group III Consumer
    and Commercial Product Categories. The USEPA required
    that
    states submit SIP
    revisions
    in
    response to the CTGs within one year. 72
    Fed. Reg. 57215-57218.
    2.
    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)(1)
    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
    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
    4

    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)
    Modetate
    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.
    §
    7511a(b)(2).
    Sections 172
    and
    182
    of
    the
    CAA
    establish
    the
    requirement
    for
    Illinois
    to
    submit
    VOM
    regulations
    constituting
    RACT
    for
    Group
    III
    Consumer
    and
    Commercial
    Product
    Categories
    in
    ozone
    NAAs
    classified
    as
    moderate
    and
    above.
    Illinois
    was
    required
    to
    submit its
    SIP
    revisions
    by
    October
    9,
    2008.

    C.
    Fast Track
    This regulatory proposal is properly
    submitted to the
    Board
    under
    Section 28.5 of
    the
    Act as a fast-track rulemaking. Section 28.5 provides,
    “When the [CAA] requires
    rules
    other than identical in substance rules
    to be adopted, upon request
    by
    the Agency,
    the Board must adopt rules under fast-track
    rulemaking
    requirements.”
    A
    rule
    is
    “required to be adopted” when the USEPA
    “is
    empowered
    to impose sanctions against
    the
    State for failure to adopt such rules.” 415 ILCS 5/28.5.
    This
    rulemaking proposal
    satisfies such
    criteria. First, the
    proposed rule is not
    identical in substance to any federal regulation.
    The CTGs at issue here are merely
    guidance documents which
    set
    forth recommendations
    that a state may utilize when
    making VOM RACT determinations for Group
    III product categories. See 72 Fed. Reg.
    57218. Second,
    the proposed rule is required
    to be adopted.
    As
    previously discussed,
    Sections 172 and 182 of
    the CAA require
    that Illinois submit
    as
    a
    SIP
    revision
    VOM
    RACT regulations for Group III
    categories
    in ozone NAAs.
    Pursuant to Section 179 of
    the CAA, two sanctions are
    available
    to USEPA if Illinois
    fails to do so: 1) the loss of
    highway funds; and 2) an
    increase in the emissions
    offset ratio
    for New Source Review.
    42
    U.S.C.
    §
    7509.
    Further, if Illinois fails to make
    an adequate SIP submission,
    USEPA
    has the
    authority to impose a Federal Implementation
    Plan pursuant to Section
    110(c)(1)
    of the CAA.
    42
    U.S.C.
    §
    7410(c)(1). Illinois EPA’s
    submittal of its
    proposal as a fast
    track rulemaking
    is therefore appropriate.
    III.
    PURPOSE AND
    EFFECT OF
    THE PROPOSAL
    As
    described in detail
    above,
    this rulemaking
    proposal has been prepared to
    satisfy Illinois’
    obligation
    to
    submit
    a SIP to address the requirements
    under Sections
    172
    6

    and
    182
    of the
    CAA
    for
    sources
    of VOM
    emissions
    in
    areas
    designated
    as
    nonattainment
    with
    respect to
    the
    ozone
    NAAQS.
    See
    42
    U.S.C.
    §
    7502
    and
    7511a.
    Additionally,
    Illinois
    is
    required
    to
    submit
    these
    SIP
    revisions
    before
    the
    USEPA
    can
    redesignate
    the
    Chicago and
    Metro
    East
    NAAs
    to
    attainment
    of
    the
    1997
    ozone
    NAAQS,
    regardless
    of
    whether
    the
    VOM
    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
    NAA
    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
    VOM
    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
    redesigriation
    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).
    On
    July
    2, 2007,
    the
    Illinois
    EPA
    submitted
    to
    the
    USEPA an
    attainment
    demonstration
    for
    the
    Metro
    East NAA
    for
    the
    1997
    8-hour
    ozone
    NAAQS.
    On
    March
    19,
    2009,
    the
    Illinois EPA
    submitted
    an
    attainment
    demonstration
    for
    the
    Chicago
    NAA
    as
    well.
    These
    areas
    cannot
    be
    redesignated
    to
    attainment
    of
    the
    ozone
    NAAQS,
    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
    Cu.
    2001).
    7

    however, unless and until the Illinois
    EPA submits SIP revisions
    in response to the Group
    III 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 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 NAAs resulting from these proposed amendments
    will improve ozone air quality
    and
    will
    likely help Illinois
    achieve and
    maintain the newly revised
    NAAQS.
    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 III CTG, are located
    in the Chicago or Metro East
    NAAs,
    and meet the
    applicability
    criteria specified in the regulations.
    Table 11 in the
    Technical
    Support Document lists the sources potentially
    affected
    by
    the proposed
    regulations.
    V.
    TECHNICAL FEASIBILITY
    AND ECONOMIC
    REASONABLENESS
    8

    The
    technology
    for
    controlling
    VOM
    emissions
    from
    Group
    III
    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.
    Control approaches
    for
    reducing
    VOM
    emissions
    from
    paper,
    film,
    and
    foil
    coatings
    include
    work
    practices,
    material
    reformulation
    or
    substitution
    (namely,
    the
    use
    of
    low-VOM
    coatings
    or
    no-VOM
    coatings),
    and
    capture
    systems
    and
    add-on
    control
    devices
    such
    as
    oxidizers,
    carbon
    adsorption
    systems,
    and
    condensers.
    Similarly,
    VOM
    control
    techniques
    for
    metal
    furniture
    coatings
    include
    work
    practices
    for
    coating
    waste
    and
    cleaning
    materials,
    and
    material
    reformulationlsubstitution
    via
    low—VOM
    coatings
    such
    as
    higher
    solids
    coatings
    and
    waterborne
    coatings.
    Metal
    furniture
    coating
    lines
    can
    also
    control
    VOM
    emissions
    by
    utilizing
    capture
    systems
    and
    add-on
    control
    devices
    such
    as
    oxidizers,
    adsorbents,
    and
    absorbents,
    and
    more
    efficient
    coating
    application
    equipment,
    such
    as
    electrostatic
    or high
    volume/low
    pressure
    spray
    equipment.
    Control
    approaches
    for
    large
    appliance
    coatings
    are
    similar
    to
    those
    available
    for
    metal
    furniture
    coatings.
    See
    Technical
    Support
    Document.
    In
    the
    Technical Support
    Document,
    the
    Illinois
    EPA
    explains
    in
    more
    detail
    that
    the
    above
    control
    approaches
    are
    both
    technically
    feasible
    and
    economically
    reasonable.
    See
    also,
    CTGs.
    VI.
    COMMUNICATION
    WITH
    INTERESTED
    PARTIES
    The
    Illinois
    EPA
    engaged
    in
    outreach
    on this
    proposal.
    On
    July
    20,
    2009,
    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
    also
    contacted
    potentially
    affected
    sources
    9

    via
    email, soliciting feedback
    on
    the
    proposed
    nile.
    While
    the Illinois
    EPA did not
    receive
    any comments
    regarding its
    proposal, interested
    parties
    have
    nonetheless
    had an
    opportunity to
    review the rule and
    discuss any issues with
    the Illinois
    EPA.
    VII. SYNOPSIS
    OF TESTIMONY
    The
    Illinois EPA
    plans to call
    Yoginder
    Mahaj an, Environmental
    Protection
    Engineer, Air
    Quality
    Planning Section,
    Bureau
    of Air, Illinois
    EPA, as a witness at
    hearing. Mr.
    Mahajan will testify and
    answer questions
    regarding the
    proposed
    amendments.
    Written
    testimony will be
    submitted prior
    to hearing
    in
    accordance with the
    Board’s
    procedural rules
    and with Board
    orders.
    VIII. THE ILLINOIS
    EPA’S
    PROPOSAL
    Generally, Illinois
    EPA’s
    regulatory
    proposal
    aims
    to implement
    the
    recommendations
    contained
    in
    the
    CTGs to the extent that
    such
    recommendations
    are
    consistent with
    existing
    regulations.
    For all three coating
    categories,
    the Illinois
    EPA
    proposes amending
    VOM content limitations,
    adding
    CTG-recommended
    exclusions,
    and
    adding
    work
    practice requirements.
    For metal furniture
    and large appliance
    coating
    lines,
    the Illinois EPA
    also proposes
    adding
    limitations regarding
    coating
    application
    methods.
    The
    following
    is
    a Section-bySection
    summary
    of the Illinois
    EPA’s proposal.
    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
    218.106
    and a
    new
    subsection
    (c) to Section
    2
    19.106,
    which establish
    May
    1, 2011,
    as the compliance
    date
    for
    sources
    subject to
    the
    rulemaking
    proposal.
    10

    Subpart
    F:
    Coatin2
    Operations
    Section
    218/219.204
    Emission
    Limitations
    The
    Illinois
    EPA
    proposes
    amending
    the
    introductory
    paragraph
    to
    reference
    revised
    subsections
    of Section
    218/219.204.
    The
    Illinois EPA
    proposes
    amending
    subsection
    (c)
    to restrict
    the
    VOM
    content
    of
    paper
    coatings
    to
    the
    limitations
    set
    forth
    in
    the
    CTG,
    and
    to provide
    that
    such
    limitations
    shall
    not
    apply
    to
    coating
    performed
    on
    or
    in-line
    with
    digital
    printing
    presses,
    or to
    size
    presses
    and
    on-machine
    coaters
    on papermaking
    machines
    applying
    sizing
    or
    water-based
    clays.
    The
    Illinois EPA
    proposes
    amending
    subsection
    (g)
    to restrict
    the
    VOM
    content
    of metal
    furniture
    coatings
    to
    the
    limitations
    set
    forth
    in
    the
    CTG,
    and
    to
    provide
    that
    such
    limitations
    shall
    not
    apply
    to
    stencil
    coatings,
    safety-indicating
    coatings,
    solid-film
    lubricants,
    electric-insulating
    and
    thermal-conducting
    coatings,
    touch-up
    and
    repair
    coatings,
    or coating applications
    utilizing
    hand-held
    aerosol
    cans.
    The
    Illinois
    EPA
    also
    proposes
    amending subsection
    (g)
    to
    provide
    that
    coating
    lines
    shall
    comply
    with
    the
    application method requirements
    specified
    in
    the
    proposed
    rule
    revisions.
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (h)
    to restrict
    the
    VOM
    content
    of large
    appliance
    coatings
    to the
    limitations
    set
    forth
    in
    the
    CTG,
    and
    to
    provide
    that
    such
    limitations
    shall
    not
    apply
    to stencil
    coatings,
    safety-indicating
    coatings, solid-film
    lubricants, electric-insulating
    and
    thermal-conducting
    coatings,
    touch-up
    and
    repair
    coatings,
    or
    coating
    applications
    utilizing
    hand-held
    aerosol
    cans.
    The
    Illinois
    EPA
    also
    proposes
    amending
    subsection
    (h)
    to
    provide
    that
    coating
    lines
    shall
    comply
    with
    the
    application
    method
    requirements
    specified
    in
    the
    proposed
    rule
    revisions.
    11

    Section
    218/219.205
    Daily-Weighted
    Average
    Limitations
    The
    Illinois
    EPA
    proposes
    amending
    the
    introductory
    paragraph
    to
    reference
    proposed
    subsection
    (j).
    The Illinois
    EPA
    proposes
    amending
    subsection
    (a) to
    provide
    that such
    subsection
    only
    applies to
    paper coating
    lines until
    May
    1, 2011.
    The Illinois
    EPA
    proposes adding
    subsection
    (j),
    which sets
    forth
    the
    requirements
    for
    paper
    coating
    lines
    utilizing
    the
    daily weighted
    averaging
    alternative
    on
    and
    after May
    1,
    2011.
    Section
    218/219.207
    Alternative
    Emission
    Limitations
    The
    Illinois
    EPA proposes
    amending
    subsection
    (a)
    to
    reference proposed
    subsection
    (1).
    The
    Illinois
    EPA proposes
    amending
    subsections
    (c),
    (j),
    and
    (k) to provide
    that
    such
    subsections
    only
    apply to
    paper
    coating
    lines,
    metal
    furniture coating
    lines,
    and
    large
    appliance
    coating
    lines,
    respectively,
    until
    May 1, 2011.
    The Illinois
    EPA
    proposes, adding
    subsection
    (1), which
    sets
    forth the
    requirements
    for
    paper,
    metal
    furniture,
    and
    large
    appliance
    coating
    lines utilizing
    the
    alternative
    emissions
    limitation
    on and
    after
    May
    1, 2011.
    Section 218/219.2
    10 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
    proposed
    paper,
    metal
    furniture,
    or
    large
    appliance
    coating
    limitations
    shall
    comply
    with
    such
    limitations,
    as
    well
    as
    with
    all other applicable
    provisions
    in
    Subpart
    F. The
    Illinois EPA
    also
    proposes
    amending
    the introductory
    paragraph
    to reference
    proposed
    subsection
    (g).
    12

    Section
    218/219.211
    Recordkeeping
    and
    Reporting
    The
    Illinois
    EPA
    proposes
    correcting
    two
    spacing
    errors
    in subsection
    (b)(1)
    of
    Section
    218.211.
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (c)
    to
    provide
    that,
    for
    paper
    coating
    lines
    subject
    to
    the
    proposed VOM
    content
    limitations,
    VOM
    content
    information
    shall
    be
    maintained
    and/or
    reported
    in
    terms
    of
    weight
    of
    VOM
    per
    weight
    of
    solids
    or
    coatings,
    as
    applicable,
    as
    applied
    each
    day
    on each
    coating
    line.
    The
    Illinois
    EPA
    also
    proposes
    amending
    subsection
    (c)
    to
    provide
    that
    metal
    furniture
    and
    large
    appliance
    coating
    lines
    subject
    to
    the
    proposed
    VOM
    content
    limitations
    maintain
    and/or
    report
    VOM
    content
    information
    in
    terms
    of
    weight
    of
    VOM
    per
    volume
    of
    each
    coating
    or
    solids,
    as
    applicable,
    as
    applied
    each
    day
    on
    each
    coating
    line,
    and
    report
    theapplication
    method(s)
    used
    to
    apply
    coatings
    on
    each
    subject
    coating
    line.
    Paper,
    metal
    furniture,
    and
    large
    appliance
    coating
    lines
    shall
    also
    maintain
    and
    report
    certified
    product
    data
    sheets
    for
    each
    coating applied
    on
    each
    line.
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (d)
    to
    provide
    that,
    for
    paper
    coating
    lines
    utilizing
    the
    daily
    weighted
    averaging
    alternative,
    VOM
    content
    information
    shall
    be
    maintained
    and/or reported
    in
    terms
    of weight
    of
    VOM
    per
    weight
    of solids
    or
    coatings,
    as
    applicable,
    as
    applied
    each
    day
    on
    each
    coating
    line.
    The
    Illinois
    EPA
    also
    proposes
    amending subsection
    (d)
    to provide
    that
    metal
    furniture
    and
    large
    appliance
    coating
    lines
    utilizing the
    daily weighted
    averaging
    alternative
    maintain
    and/or
    report
    VOM
    content information
    in
    terms
    of
    weight
    of VOM
    per
    volume
    of
    each
    coating
    or
    solids,
    as
    applicable,
    as
    applied
    each
    day
    on
    each
    coating
    line.
    The
    Illinois
    EPA
    proposes
    amending
    subsection
    (e)
    to
    provide
    that
    coating
    lines
    1—,
    1.)

    complying
    pursuant to Section
    2
    18/219.207(1)
    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
    paper,
    metal
    furniture, and large appliance
    coating
    lines
    subject to
    the work practice requirements
    set
    forth in Section 218/219.218.
    Section
    218/219.212
    Cross-Line Averaging
    to Establish
    Compliance
    for Coating
    Lines
    The Illinois
    EPA proposes
    amending this Section
    to provide
    that the cross—line
    averaging
    alternative
    is not available to
    coating lines
    subject to the revised
    VOM content
    limitations.
    •Section 218/219.218
    Work Practice
    Standards
    for Paper Coatings,
    Metal Furniture
    Coatings,
    and Large Appliance
    Coatings
    The Illinois
    EPA
    proposes adding
    Section 218/219.218,
    which
    sets forth work
    practice
    requirements
    for cleaning materials
    and/or cleaning-related
    activities associated
    with paper,
    metal
    furniture,
    and large
    appliance
    coating
    lines. Generally,
    Illinois
    EPA
    proposes
    that
    subject
    coating
    lines
    store
    all VOM-containing
    materials
    in closed
    containers,
    ensure
    that mixing and
    storage containers
    used
    for VOM-containing
    materials
    are
    kept closed at
    all times except when
    in use,
    minimize
    spills
    of
    VOM-containing
    materials, convey
    such materials from one
    location
    to
    another
    in
    closed
    containers or
    pipes,
    and minimize
    VOM emissions
    from
    the
    cleaning
    of storage,
    mixing, and
    conveying
    equipment.
    14

    ILLINOIS
    ENVIRONMENTAL
    PROTECTION
    AGENCY
    By:
    Dana Vet
    ffer’
    Assistant Counsel
    Division
    of Legal
    Counsel
    DATED:
    October
    15, 2009
    1021
    N. Grand Ave.
    East
    P.O. Box 19276
    Springfield,
    IL 62794-9276
    (217) 782-5544
    15

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