DRAFT

8-HOUR OZONE ATTAINMENT DEMONSTRATION FOR THE METRO-EAST NONATTAINMENT AREA

AQPSTR 07-02

Illinois Environmental Protection Agency Bureau of Air 1021 North Grand Avenue, East Springfield, Illinois 62794-9276

April 3, 2007 Table of Contents

List of Tables ...... 3 List of Acronyms ...... 4 Executive Summary...... 6 1.0 Attainment Demonstration...... 9 2.0 Control Measures...... 12 3.0 Transportation Conformity ...... 16 4.0 Base Year (2002) Emissions Inventory ...... 22 5.0 Reasonable Further Progress (RFP)...... 23 5.1 Emission Inventories...... 24 5.1.1 Base Year Inventory ...... 24 5.1.2 Projected 2008 Inventory...... 25 5.2 Calculation of 15 Percent RFP Target Value...... 29 5.2.1 VOM Calculation...... 30 5.2.2 NOx Calculation ...... 30 5.3 Fifteen Percent Reasonable Further Progress Demonstration ...... 31 6.0 Reasonably Available Control Technology (RACT)...... 34 7.0 Contingency Measures...... 37 8.0 Legal Authority and Resource Commitments...... 39 Appendix A Transportation Conformity...... 41 Appendix B 2002 Emissions Inventory for the Metro-East Nonattaintment Area...... 53 Appendix C Summary of VOM RACT Implementation in Illinois ...... 64

2 List of Tables

Number Page

3-1 Metro-East 8-hour Ozone Draft Transportation Conformity Budgets...... 21 5-1 Base Year NOx Emissions for 2002 ...... 25 5-2 Base Year VOM Emissions for 2002...... 25 5-3 Projected Point Source Emissions for 2008...... 27 5-4 Projected Area Source Emissions for 2008 ...... 27 5-5 Projected On-road Mobile Source Emissions for 2008 ...... 28 5-6 Projected Off-road Mobile Source Emissions for 2008...... 28 5-7 Total Projected NOx Emissions for 2008 ...... 29 5-8 Total Projected VOM Emissions for 2008...... 29 5-9 Demonstration of RFP in Nonattainment Area...... 33

3 List of Acronyms

ADVMT Average Daily Vehicle Miles Traveled AER Annual Emissions Report ASWVMT Average Summer Weekday Vehicle Miles Traveled AIM Architectural and Industrial Maintenance AVER All Vehicle Emission Rate BART Best Available Retrofit Technology CAIR Clean Air Interstate Rule CFR Code of Federal Regulations CO Carbon Monoxide EGAS Economic Growth Analysis System EGU Electric Generating Unit EWGCOG East-West Gateway Council of Governments FAA Federal Aviation Administration FMVCP Federal Motor Vehicle Control Program IDOT Illinois Department of Transportation I/M Inspection/Maintenance IPM Implementation Planning Model LADCO Lake Michigan Air Directors Consortium MACT Maximum Achievable Control Technology MON Miscellaneous Organic NESHAP NAA Nonattainment Area NAAQS National Ambient Air Quality Standard NESHAP National Emission Standards for Hazardous Air Pollutants NOx Oxides of Nitrogen NSPS New Source Performance Standards OBD On-Board Diagnostics OTB On the Books OTC Ozone Transport Commission

4 PM2.5 Particulate Matter < 2.5 microns QA Quality Assurance QC Quality Control RACT Reasonably Available Control Technology RICE Reciprocating Internal Combustion Engine RFG Reformulated Gasoline RFP Reasonable Further Progress RVP Reid Vapor Pressure SCC Source Classification Code SIP State Implementation Plan TPD Tons Per Day U.S. EPA United States Environmental Protection Agency VISTAS Visibility Improvement State and Tribal Association of the Southeast VMT Vehicle Miles Traveled VOM Volatile Organic Material

5 Executive Summary

On April 15, 2004, the United States Environmental Protection Agency (U.S. EPA) designated portions of the St. Louis metropolitan area, including counties in both Missouri and Illinois, as nonattainment for the 8-hour ozone National Ambient Air Quality Standard (NAAQS). These designations became effective on June 15, 2004. Nine counties in the St. Louis area are designated as a “moderate” nonattainment area (NAA) for the 8-hour standard (based on 2001- 2003 observed ozone data). In Missouri, they are St. Louis City, Franklin, Jefferson, St. Charles, and St. Louis Counties. In Illinois, four counties are nonattainment -- Jersey, Madison, Monroe, and St. Clair.

As a result of the designation of these counties to nonattainment, the States of Illinois and Missouri are required by the Clean Air Act (CAA) to develop plans to attain the NAAQS by the specified deadline. For 8-hour ozone, the attainment plan must be submitted by June 15, 2007, and the plan must demonstrate attainment of the NAAQS by June 15, 2010. This document summarizes Illinois’ attainment plan. The attainment plan has been developed in cooperation with the Missouri Department of Natural Resources (Missouri DNR), and satisfies the requirements of Section 182(b) of the CAA. Additionally, this document contains: the transportation conformity budget for the Metro-East portion of the NAA pursuant to the requirements of Section 176 of the CAA; a summary of the required emissions inventory for the base year, 2002; Illinois’ demonstration of Reasonable Further Progress (RFP) for the Metro- East area; Illinois’ demonstration that it has fully implemented the requirements for Reasonably Available Control Technology (RACT) for volatile organic material (VOM); Illinois’ commitment to adopt and implement RACT on major sources of NOx in the nonattainment area; a demonstration that Illinois has met the requirements for contingency measures; and a demonstration that Illinois has the legal authority and is commiting the resources needed to implement this attainment plan.

The Illinois EPA and the Missouri DNR worked cooperatively to develop a photochemical model to simulate the formation and transport of ozone in the St. Louis metropolitan area. The modeling system is used to evaluate emissions reduction strategies for inclusion in the states’

6 attainment plans. The modeling was performed using the CAMx and CMAQ air quality modeling systems, which incorporated episodic emissions, meteorological, and ozone data using a nested grid covering the central U.S. and centered on St. Louis. The study focused on simulating three 8-hour ozone episodes from the summer of 2002. Note, the CMAQ modeling system never was able to meet the model performance evaluation goals using the final basecase inventory and was discarded from further consideration due to lack of acceptable performance.

After detailed performance testing of the 2002 basecase simulation, the CAMx modeling system was exercised with a 2009 On-the-Books (OTB) emissions control scenario aimed at assessing the effects of future year emission control strategies on ozone in the St. Louis NAA. The projected 8-hour ozone design values (using observed 2000-2004 5-year baseline 8-hour ozone design values) in the St. Louis NAA for the 2009 OTB emission scenario were all below 85 ppb, thereby demonstrating attainment. The modeling analysis is supplemented with a “weight of evidence determination” to provide additional confidence in the study results. The results of the supplemental analyses are consistent with the results of the photochemical modeling in predicting attainment for the St. Louis NAA by the 2009 attainment deadline.

This document describes the development of, and establishes, draft 8-hour ozone motor vehicle emissions budgets for VOM and NOx emissions in the for the years 2008 and 2009 for the four- county Metro-East St. Louis, Illinois area. A motor vehicle emissions budget is that portion of the total allowable VOM and NOx emissions allocated to highway and transit vehicle use and that are defined in the State Implementation Plan (SIP) for a certain date. The rules governing transportation conformity require certain transportation activities to be consistent with motor vehicle emissions budgets contained in control strategy implementation plans (40 CFR 93.118). In order to demonstrate conformity to the motor vehicle emissions budget, estimated emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to the budget level (40 CFR 93.118(a)). Transportation conformity will be based on these submitted motor vehicle emissions budgets after the U.S. EPA declares that the budgets meet the adequacy criteria of the transportation conformity rule under 40 CFR 93.118(e).

7 This document contains a summary of the base year 2002 emissions inventory compiled by the Illinois EPA, and also contains Illinois’ demonstration of RFP for the Metro-East area. The RFP demonstration shows the NAA will meet the required 15 percent net reduction in NOx and VOM emissions from 2002 to 2008, thus satisfying the RFP requirement.

The Illinois EPA has evaluated RACT and adopted regulations that require the application of RACT on the major sources of VOM in the Metro East ozone NAA. This report demonstrates that Illinois has fully implemented RACT regulations on VOM sources located in the Metro East NAA. Illinois also commits to implement RACT on major sources of NOx in the nonattainment area in the coming months.

Section 172(c)(9) of the CAA requires the adoption of contingency measures that must be implemented if the nonattainment area fails to achieve the RFP reductions or fails to attain the NAAQS within the CAA-specified time frame. The General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 states that the contingency measures, in total, must generally be able to provide for 3 percent reductions from the 2002 baseline emissions (57 FR 13507; April 16, 1992). While all contingency measures must be fully adopted rules or measures, states can use measures in two different ways. A state can choose to implement contingency measures before the June 15, 2008 RFP milestone deadline. Alternatively, a state may decide not to implement a contingency measure until an area has actually failed to achieve an RFP or attainment milestone. In the latter situation, the contingency measure emission reduction must be achieved within one year following identification of a milestone failure. Illinois’ contingency plan includes a mix of federal and state measures, some of which are required under the CAA, and some of which are state-specific measures. All of the measures that have been relied upon in this plan have been adopted and will provide emission reductions exceeding the 3 percent threshold by the June 15, 2008 RFP milestone deadline.

8 1.0 Attainment Demonstration

On April 15, 2004, U.S. EPA designated portions of the St. Louis metropolitan area, including counties in both Missouri and Illinois, as nonattainment for the 8-hour ozone NAAQS. These designations became effective on June 15, 2004. Nine counties in the St. Louis area are designated as “moderate” nonattainment area (NAA) for this new 8-hour standard (based on 2001-2003 observed ozone data). In Missouri, they are St. Louis City, Franklin, Jefferson, St. Charles, and St. Louis Counties. In Illinois, the nonattainment counties are Jersey, Madison, Monroe, and St. Clair.

The Illinois EPA and the Missouri DNR worked cooperatively to develop a photochemical model to simulate the formation and transport of ozone in the St. Louis metropolitan area. The modeling system is used to evaluate emissions reduction strategies for inclusion in the states’ attainment plans. A complete description of the modeling methodologies and results are contained in the document “St. Louis 8-Hour Ozone Technical Support Document” (April 26, 2007).

The St. Louis modeling study included episodic emissions, meteorological, and ozone simulations using a nested 36/12/4 km grid covering the central U.S. and centered on St. Louis. The modeling effort used SMOKE and supplemental EMS emissions, MM5 meteorological, and the CAMx and CMAQ air quality modeling systems for estimating ozone on the nested 36/12/4 km St. Louis grid during three 8-hour ozone episodes from the summer of 2002.

The 2002 Baseline CAMx and CMAQ modeling databases were evaluated against monitored ozone data from the St. Louis area in order to evaluate the fitness of the databases for use in the modeled attainment test. Initial simulations illustrated that the CMAQ modeling system exhibited a larger under-prediction ozone bias than CAMx. Given this large under-prediction bias, the higher computational efficiency of CAMx over CMAQ, and the resource constraints of the study, the Missouri DNR and Illinois EPA elected to proceed with CAMx as the primary air quality model. The CMAQ modeling system never was able to meet the model performance

9 evaluation goals using the final base year inventory and was discarded from further consideration due to lack of acceptable performance.

After several iterations of modeling inventories, meteorology, and modeling set-up, the modeling team reached a consensus regarding the appropriate inputs and model for the best and most accurate base case. On most episode days, the model achieved EPA’s model performance evaluation goals for surface layer 8-hour and 1-hour ozone concentrations. Many of the days that did not meet these goals exhibited low ozone concentrations. These days were included in the modeling because they were bounded by two periods of high ozone concentrations or were needed as “ramp-up” days for the study. In general, the 1-hour and 8-hour ozone performance statistics suggest a systematic underestimation of ozone that is related to the over-estimation of ozone suppression by NOx in the St. Louis urban core, and the model’s tendency to delay ozone formation in the St. Louis urban plume relative to observations. However, the St. Louis 2002 baseline model simulation exhibited sufficient skill in meeting most performance goals (especially on key days). Therefore, the modeling team decided that it may be used to project future-year ozone air quality and 8-hour ozone attainment, recognizing the inherent uncertainties in the atmospheric modeling process.

After detailed performance testing of the 2002 basecase simulation, the CAMx modeling system was exercised with a 2009 On-the-Books (OTB) emissions control scenario aimed at assessing the effects of future year emission control strategies on ozone in the St. Louis NAA. The projected 8-hour ozone design values (using observed 2000-2004, 5-year baseline 8-hour ozone design values) in the St. Louis NAA for the 2009 OTB emission scenario were all below 85 ppb, thereby demonstrating attainment. The states have also performed a weight of evidence determination to provide additional confidence in the study results. A complete description of the weight of evidence analysis is contained in the “St. Louis 8-Hour Ozone Technical Support Document” (April 26, 2007).

Based on the model’s response to sensitivity analyses, the final attainment demonstration, and an Ozone Source Apportionment Technology (OSAT) scenario, elevated ozone concentrations in

10 St. Louis are responsive to NOx emission control. Upwind and local NOx emission controls are beneficial to reduce ozone in the area and necessary to demonstrate attainment in St. Louis.

The weight of evidence analyses lead to a determination that the St. Louis area will be in attainment of the NAAQS by 2010. Every one of the supplemental analyses performed was consistent in predicting attainment for St. Louis; not a single study suggested that the St. Louis area will not reach attainment by 2010. Therefore, the evidence for attainment was overwhelming and conclusive.

11 2.0 Control Measures

The modeling analysis described in Section 1.0 determined that control measures that have already been promulgated at either the state or federal level should be sufficient to allow the St. Louis area to attain the 8-hour ozone NAAQS by 2009, the deadline established by U.S. EPA. The principle “on-the-books” emission reduction measures for demonstrating attainment of the 8-hour ozone standard in the Metro-East St. Louis NAA by 2009 are described in this section.

Tier 2 Motor Vehicle Emissions Standards and Gasoline Sulfur Control Requirements (65 FR 6697 (February 10, 2000)).

Through a combination of tailpipe emission standards (fully phased in by 2007 and 2009) for new passenger cars, light trucks, and “medium-duty passenger vehicles” and requirements for much lower sulfur levels in gasoline (fully phased in by 2006), motor vehicle emissions of NOx, non-methane organic gases, and sulfur compounds will be reduced. Vehicle NOx emission levels will be reduced to an average of 0.07 grams per mile. Most gasoline producers must meet a “corporate average gasoline sulfur standard of 120 ppm and a cap of 300 ppm beginning in 2004.” This cap will be reduced to 80 ppm and “most refineries must produce gasoline averaging no more than 30 ppm sulfur” by 2006.

On-Highway Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements (Federal Register: January 18, 2001, vol. 66, no. 12, pp. 5002-5193).

Through a combination of tighter engine emission standards phased in beginning in 2007, and the required sale of ultra low sulfur diesel fuel in 2006, VOM and NOx emissions will be reduced. The sulfur content of on-road diesel fuel will be reduced by 97 percent to 15 ppm beginning in June 2006. This will enable the use of advanced emissions control equipment on diesel vehicles. The program will result in vehicle NOx emissions levels that are 90 percent below year 2000 levels.

12 Tier 4 Nonroad Diesel Engines and Diesel Fuel Sulfur Content (69 FR 38957 (June 29, 2004)).

Through new emission standards and emission test procedures for nonroad diesel engines (phased in starting mid-2007), in combination with diesel fuel sulfur reductions (500 ppm cap starting June 2007; 15 ppm level by June 2010), nonroad engine emissions of NOx, non-methane hydrocarbons, fine particulate (PM2.5), and sulfur compounds will be reduced. The diesel fuel sulfur level of 15 ppm represents a 99 percent reduction from existing levels. Diesel engine particulate matter emissions will be reduced greater than 95 percent, and NOx emissions will be reduced more than 90 percent.

Reformulated Gasoline (RFG) (Illinois Governor Blagojevich’s letter to U.S. EPA Administrator Stephen Johnson, July 10, 2006;71 FR 77615 (December 27, 2006); 72 FR 4966 (February 2, 2007))

A formal request was made of U.S. EPA to extend the requirement for sale of RFG to Jersey, Madison, Monroe, and St. Clair counties beginning January 1, 2007. RFG implementation has associated emissions-based performance standards. Use of RFG will result in less evaporative and exhaust organic compound emissions, as well as less NOx emissions, relative to conventional gasoline usage.

NOx SIP Call (63 FR 57355 (October 27, 1988); 35 Il. Adm. Code Part 217)

The NOx SIP Call provided for a trading program and established a seasonal emissions cap based upon electrical generating units (EGUs) not exceeding 0.15 lb NOx/MMBTU heat input and non-EGU boilers and turbines reducing NOx emissions by 60 percent. The rule also required tightened emission limits on cement kilns (30 percent NOx reduction) and large stationary internal combustion engines by 82 percent. Illinois regulations that were promulgated to meet the requirements of the federal NOx SIP Call addressed the EGU and non-EGU (boilers, turbines, and combined cycle systems) NOx emissions within the federally proposed cap and allowance

13 trading framework and also placed specific emission limits on cement kilns (after May 30, 2004). The NOx SIP Call was implemented on May 31, 2004. The limits for engines and turbines were appealed and the new implementation date is May 1, 2007. Illinois EPA has proposed a rule to implement this emission limit that will be adopted on an expedited schedule.

Consent Decrees---Dynegy Midwest Generation, ConocoPhillips (USA v. IL Power Co., et. al. 3:99-cv-833 Consent Decree, March 2005, U. S. District Court for the Southern District of Illinois ; ConocoPhillips Global Refinery Settlement, filed January 27, 2005, U.S. District Court for the Southern District in Texas)

The settlement reached with Dynegy Midwest Generation for alleged violations at the Baldwin Generating Station included the requirements to “commence operation of the SCRs installed at Baldwin Unit 1, Unit 2 . . . so as to achieve and maintain a 30-day rolling average emission rate from each such unit of not greater than 0.100 lb/mmbtu NOx and “maintain a 30-day rolling average emission rate of not greater than 0.120 lb/mmbtu NOx at Baldwin Unit 3.” Low NOx burners and Overfire Air Technology are required on Dynegy Midwest Generation’s Wood River Units #4 and #5. The ConocoPhillips settlement provides for near-term installation (no later than December 31, 2009) of Low-NOx Burners and Ultra Low-NOx Burners on combustion units at its “DistillingWest” operations. Other NOx emission reduction requirements are set forth in the consent decree, as are provisions for CO, SO2, and particulate matter reductions.

New Source Performance Standards, NESHAPS/Maximum Achievable Control Technology (MACT) Standards, Marine Compression-Ignition Engine Standards, and Locomotive Engine Standards (63 FR 18977 (April 16, 1998) (locomotives); 64 FR 73299 (December 29, 1999) (marine engines)

A broad range of emission sectors are subject to federal New Source Performance Standards, NESHAP/Maximum Achievable Control Technology standards, commercial marine vessel standards, and locomotive standards with compliance requirements which take effect post-2002 and prior to the St. Louis 8-hour ozone attainment date. Projected (2009) emission estimates for

14 affected stationary and mobile sources within and outside the St. Louis ozone nonattainment area have incorporated these federal rule requirements.

15 3.0 Transportation Conformity

This section describes the development of, and establishes, draft 8-hour ozone motor vehicle emissions budgets for VOM and NOx emissions for the years 2008 and 2009 for the four-county Metro-East NAA. A motor vehicle emissions budget is that portion of the total allowable VOM and NOx emissions allocated to highway and transit vehicle use and that are defined in the SIP for a certain date. The rules governing transportation conformity require certain transportation activities to be consistent with motor vehicle emissions budgets contained in control strategy implementation plans (40 CFR 93.118). 40 CFR 93.101 of the rule defines a “control strategy [state] implementation plan (SIP) revision” as a “plan which contains specific strategies for controlling the emissions of and reducing ambient levels of pollutants in order to satisfy CAA requirements of reasonable further progress and attainment.” This attainment demonstration is considered a control strategy SIP. In order to demonstrate conformity to the motor vehicle emissions budget, estimated emissions from the implementation of a transportation plan or a transportation improvement program must be less than or equal to the budget level (40 CFR 93.118(a)). Transportation conformity will be based on these submitted motor vehicle emissions budgets after the U.S. EPA declares that the budgets meet the adequacy criteria of the transportation conformity rule under 40 CFR 93.118(e).

As described in the following narrative, the St. Louis attainment demonstration incorporates year 2002 transportation demand modeling information supplied by the East-West Gateway Council of Governments (EWGCOG). This information includes estimates of average daily vehicle miles of travel (ADVMT) by road type, vehicle type, speed, and time of day for Madison, Monroe and St. Clair Counties in Illinois. These ADVMT data were then forecast to the 2009 attainment year using SCC-based growth factors provided by Alpine Geophysics and based on growth rates derived from VMT data assembled by the U.S. EPA for their Clean Air Interstate Rule (CAIR) rulemaking. The 2009 ADVMT forecast through this process for the three Illinois counties within the EWGCOG planning area was 19,156,510.

The RFP plan described in Section 5.0 incorporates county level base year 2002 ADVMT levels from the Illinois Department of Transportation (IDOT). The 2002 ADVMT total for Madison, Monroe and St. Clair Counties was 17,052,688. This total was projected to the attainment year

16 2009 using an annual growth factor of 1.5 percent. The projected 2009 ADVMT level for Madison, Monroe, and St. Clair Counties is 18,925,838. This level is within 2 percent of that projected using the attainment demonstration methodology described above, and since it results in a lower, more conservative VMT level, the Illinois EPA believes that basing the motor vehicle emissions on this lower total demonstrates consistency with the attainment demonstration.

Since Jersey County is outside of the jurisdiction of the EWGCOG, the attainment demonstration plan includes a year 2002 countywide ADVMT figure of 564,366 from IDOT. This figure was projected to the year 2009 using similar county- and SCC-based growth factors from Alpine Geophysics. For purposes of the RFP plan, the same 1.5 percent annual growth factor used for Madison, Monroe and St. Clair Counties, resulted in a year 2009 Jersey County ADVMT estimate of 626,359.

17 As the motor vehicle emissions budgets are based on average summer weekday VMT (ASWVMT), the average daily VMT figures were multiplied by factors from IDOT to account for the higher level of driving which occurs during the summer. The year 2009 ASWVMT level used to establish the motor vehicle emissions budgets for Madison, Monroe, St. Clair and Jersey counties was 20,095,332.

Following is a summary of the information and MOBILE6 model assumptions used included in the development of the draft motor vehicle emissions budgets.

Year: VMT estimates and motor vehicle emissions factors were developed representative of summer 2008 for the RFP demonstration, and for 2009 for the modeled attainment demonstration.

Typical Ozone Season Weekday: The 2002 Metro-East ozone precursor emissions inventory, which established the baseline for the CAA-required RFP emissions reductions, is based on activity on a typical ozone season weekday. The primary parameters affected by this choice of temporal time frame are the temperature and the adjustment of VMT to account for increased travel during the summer.

Temperature: U.S. EPA guidance for the use of the MOBILE6 model calls for the use of representative summer daily temperatures. National Weather Service climatological average minimum and maximum temperatures of 68 o F and 88 o F for June, July, and August for Lambert Airport, in St. Louis, MO were used.

Humidity: U.S. EPA MOBILE6 guidance calls for the use of the lowest absolute humidity on days corresponding to the summer climatological temperatures in the region as determined from local climatological data. An absolute humidity value of 102 grains of water (vapor) per pound of dry air was obtained from data from Lambert Airport in St. Louis, MO.

18 Motor Vehicle Emission Controls: The primary Metro-East area-specific motor vehicle emission control programs that will be in place in 2008 and 2009 are an OBD-II based vehicle emissions testing program and the required sale of reformulated gasoline.

Inspection and Maintenance (I/M): In 2005, the Illinois legislature amended the Illinois Vehicle Inspection law to drop dynamometer testing of vehicles and require an On-Board Diagnostics (OBD)-based program beginning in February 2007. The amendment also removed the requirement for testing for all compliant pre-1996 model year vehicles. The program now requires OBD-testing on all model year 1996 and newer light duty gasoline vehicles, and exhaust idle and gas cap testing on model year 1996 and newer heavy duty gasoline vehicles and gasoline-powered buses. The I/M program requires biennial testing and includes a 4 model year grace period for new vehicles. See Appendix A for more information. The Metro-East testing area is based upon urbanized areas and includes portions of western Madison County, western St. Clair County and northern Monroe County. Since not 100 percent of the VMT in a county comes from vehicles that are required to undergo emissions testing, estimates of I/M coverage for each county are used when calculating emissions by county, functional class and vehicle type. The I/M coverage factors are 90 percent for Madison and St. Clair Counties, 25 percent for Monroe County, and zero percent for Jersey County. These percentages were used to estimate average countywide emission factors from the I/M and no-I/M outputs.

Fuels: In July 2006, the Governor of Illinois petitioned the U.S. EPA to require the sale of reformulated gasoline in Jersey, Madison, Monroe, and St. Clair counties. The Clean Air Act allows the U.S. EPA one year from the petition to implement the fuel requirement, assuming eligibility and barring any serious fuel supply issues. In a Federal Register notice dated December 27, 2006, the U.S. EPA proposed an RFG implementation date of May 1, 2007, at the terminal/wholesale supplier level and June 1, 2007, at the retail level. However, adverse public comments required the U.S. EPA to hold a public hearing and extend the comment period which will likely delay the implementation of the program until mid-summer 2007. The attainment

19 demonstration and RFP plan both assume the required sale of southern grade reformulated gasoline in the Metro-East area in 2008 and 2009.

Gasoline Sulfur: Gasoline sulfur levels were assumed to be 30 parts per million (ppm) in 2008 and 2009 in accordance with the federal Tier 2 gasoline regulations which required the 30 ppm level beginning in 2006.

Diesel Sulfur: Diesel sulfur levels were assumed to be 15 parts per million in 2008 and 2009 in accordance with the U.S. EPA’s Highway Diesel Rule which was finalized in January 2001. This regulation required the sale of on-road diesel fuel with no greater than 15 ppm of sulfur beginning in June 2006.

Speeds: For Madison, Monroe and St. Clair Counties, the Illinois EPA assumed a vehicle speed distribution that appears in the VMT-by-Speed-Bin external file SVMTME04.DEF, which is described in more detail later in this document. The speed distribution in this file is for freeways and arterials only (local roads and ramps have a fixed speed in MOBILE6), and was based on transportation model output (modeled speeds on links of various classes of roads by modeling period) from EWGCOG for the year 2004 (the most recent available). This speed distribution is assumed valid for 2008 and 2009 as well. For Jersey County, the default SVMT.DEF file provided with the MOBILE model was assumed, since there is no transportation model output for Jersey.

VMT Mix: The regional VMT mixes used for 2008 and 2009 were based on 2005 VMT by vehicle type data supplied by IDOT modified to reflect the expected changes in the ratio of cars to light trucks. This information is used in the MOBILE model only to compute the All-Vehicle Emission Rate (AVER).

Registration Distribution: A Metro-East-specific vehicle registration distribution profile based upon 2003-04 information data was supplied by Illinois EPA’s Division of Mobile Source Programs from data provided by the Illinois Secretary of State’s Department of Motor Vehicles.

20 Emissions Computations: The following emissions estimation methodology incorporates the above assumptions. On a spreadsheet, ADVMT data by speed were entered for each county, and adjusted as noted above to give Adjusted EWGCOG ADVMT by speed and county. The non- I/M and I/M AVER for each pollutant (VOM, CO, NOx) were entered by speed. This is in accordance with EWGCOG practice. Then, using the I/M fractions mentioned above, an average all-vehicle emission rate was calculated for each of the counties thus: Avg AVER = (I/M AVER * I/M fraction + non-I/M AVER * [1 - I/M fraction]). For each pollutant, the county ADVMT at each speed was multiplied by the appropriate AD-to-ASW factor (to give ASWVMT) and the Avg AVER to give emissions for that pollutant in grams per day. These were converted to tons per day (TPD) using the factor 1.102, which converts millions of grams to 2000-lb tons. The same process was followed for each speed for which VMT data were available; and the totals by county and by pollutant were then calculated.

Motor Vehicle Emissions Budgets: Using the above assumptions and methodology, the year 2008 and 2009 draft motor vehicle emissions budgets for the four county Metro-East area for use in determining transportation conformity are shown in Table 3-1. See Appendix A for more detail on the use of the above described information.

Table 3-1: Metro-East 8-hour Ozone Draft Transportation Conformity Budgets (Emissions stated in tons per summer weekday day)

Pollutant / Analysis Year 2008 2009 Volatile Organic Materials 14.27 13.44 Oxides of Nitrogen 34.87 31.94

21 4.0 Base Year (2002) Emissions Inventory

A key element in the overall SIP planning process is an updated emission inventory. This Section provides a description of the methods used to compile the 2002 base year inventory for ozone. It includes CO, NOx and VOM emissions for point, area, on-road mobile, off-road mobile and biogenic emissions for the entire State of Illinois. The complete inventory is contained in Illinois EPA’s “Illinois BaseYear Ozone Inventory for 2002” (June 2006). Appendix B provides a summary of the emissions inventory for the Metro-East nonattainment area.

The primary source of data for point sources was the source-reported 2002 annual emission reports (AERs). Area source emissions are typically estimated by multiplying an emission factor by a known indicator of activity (e.g., population) for a source category. On-road mobile source emissions were calculated using the MOBILE6 computer model. Off-road mobile source emissions were calculated using the NONROAD model. Biogenic emissions, those from vegetation, were obtained from U.S. EPA’s running of the BEIS model.

To ensure this inventory is of the highest quality, Illinois EPA implemented quality assurance (QA) procedures and quality control (QC) checks throughout the inventory process. Illinois EPA specifically followed the procedures outlined in U.S. EPA’s guidance documents pertaining to inventory quality assurance and therefore believes the inventory to be complete, accurate and of high quality.

22 5.0 Reasonable Further Progress (RFP)

The Metro-East NAA is comprised of Jersey, Madison, Monroe and St. Clair Counties and is designated as a moderate NAA for the 8-hour ozone NAAQS. If an area with the same boundary as an area for which U.S. EPA approved a 15 percent Rate of Progress (ROP) plan for the 1-hour ozone NAAQS, that area has met the RFP obligations under subpart 2 of the Clean Air Act Amendments (40 CFR 51.910(a)(1)(ii)). For the 8-hour ozone NAAQS, such areas are required to submit a RFP plan under the general nonattainment provisions in Section172(c)(2) of the Clean Air Act subpart 1.

Madison, Monroe and St. Clair Counties were previously classified as a moderate NAA for the 1-hour ozone standard. These counties were subject to a ROP plan demonstrating a 15 percent reduction of VOM emissions between 1990 and 1996. This document was submitted to U.S. EPA on November 15, 1993, and its promulgation set forth at 40 CFR 52.726(q). Therefore, ozone NAA subpart 2 requirements for RFP have been met for this NAA and the general RFP requirements in subpart 1 apply for the 8-hour ozone NAAQS.

Jersey County was classified as a marginal NAA for the 1-hour ozone NAAQS. Notice of intent to redesignate Jersey County as attainment/maintenance was published in the Federal Register on November 25, 1994. Jersey County was designated attainment of the 1-hour NAAQS on April 13, 1995 (49 Fed. Reg. 3634, March 14, 1995). Moderate NAAs that include areas that were not in the original NAA have two options for demonstrating RFP per Section 182(b) of the CAA. First, the area previously not in the NAA can be treated separately from the rest of the NAA, 40 CFR 51.910(a)(1)(iii)(A), and therefore be subject to RFP. The second option, 40 CFR 51.910(a)(1)(iii)(B) is to include the area with the rest of the moderate NAA RFP requirements. With Jersey County having relatively small VOM emissions compared to the rest of the moderate NAA area, Illinois EPA is including Jersey County with the rest of the NAA area for demonstrating RFP.

The Metro-East area has an attainment date of June 15, 2010, which is six years from the effective date of the nonattainment designation. Because of this, the RFP plan must provide for a 15 percent reduction in emissions of VOM from the baseline year within six years after the

23 baseline year. The baseline year for the area is 2002, which makes the target year 2008. In other words, the RFP plan must demonstrate that VOM emissions in the Metro-East 8-hour ozone NAA will decrease by at least 15 percent from the 2002 base year through 2008. However, according to U.S. EPA’s NOx Substitution Guidance (December, 1993), NOx emission reductions may be substituted for VOM reductions on a percentage basis (i.e., one percent NOx reduction is equivalent to one percent VOM reduction), provided that the control strategies assumed in the RFP demonstration are consistent with the reductions required to demonstrate attainment of the ozone standard.

The remainder of this Section describes the methods used to establish the required reductions in emissions. This includes the base year inventory, future year inventory, target emissions and reductions not included in the projected 2008 inventory.

5.1 Emission Inventories

In order to determine if the area will achieve the required VOM emissions reductions, the target level of emissions in a future year must be calculated. First a base year inventory is compiled. This inventory is then “grown” to the year of interest. The base year is 2002 and the future year is 2008. The 15 percent reduction is calculated from the 2002 inventory. The future year inventory (2008) is then used with anticipated control strategies to identify the emissions in the future year to determine whether those emissions meet the reduction requirement.

5.1.1 2002 Base Year Inventory

The Illinois EPA submitted the 2002 base year inventory to U.S. EPA on June 1, 2006. This inventory was prepared consistent with U.S. EPA criteria and guidance documents and represents emissions estimates for ozone precursors (NOx and VOM) on a typical ozone season weekday during the peak ozone season (June, July, August) in 2002. More detailed information about the compilation of the inventory can be found in the document “Illinois Base Year Ozone Inventory for 2002” (June 2006).

24 In developing this RFP plan, it was discovered that a source in the NAA had its emissions included twice in the emissions inventory. This source was the Waterloo Light Plant. The duplicate NOx and VOM emissions were removed from the emissions inventory.

Tables 5-1 and 5-2 summarize NOx and VOM emissions in the NAA. Biogenic emissions are not shown in the tables.

Table 5-1: Base Year NOx Emissions for 2002 (tons/day)

Point Area On-road Off-road County Sources Sources Mobile Mobile Total Sources Sources Jersey 0.00 0.05 1.68 4.55 6.28 Madison 48.93 0.74 23.27 16.97 89.91 Monroe 0.77 0.07 2.55 7.71 11.10 St. Clair 3.54 0.54 19.57 7.56 31.21 Total 53.24 1.40 47.07 36.79 138.50

Table 5-2: Base Year VOM Emissions for 2002 (tons/day)

Point Area On-road Off-road County Sources Sources Mobile Mobile Total Sources Sources Jersey 0.04 2.20 1.02 0.72 3.98 Madison 13.41 13.73 10.83 5.89 43.86 Monroe 0.08 2.34 1.37 0.84 4.63 St. Clair 3.88 11.59 10.35 4.59 30.41 Total 17.41 29.86 23.57 12.04 82.88

5.1.2 Projected 2008 Inventory

Growth (or decline) in industrial activity, population, fuel consumption, vehicle miles traveled, etc., will generally cause emissions to increase (or decrease). The expected growth in NOx and VOM emissions from 2002 to 2008 for point, area and mobile sources must be accounted for in determining the emissions budget. The following sections describe the methodology used to project the base year inventory to 2008.

25

The primary method of projecting point and area source emissions to 2008 from the 2002 inventory was to use growth factors. Growth factors relate a future year’s emissions to a previous year’s emissions by use of a multiplication factor. For example, if the growth factor is 1.05, this represents a five percent growth rate between the two years. As part of its inventory and modeling activities, the Lake Michigan Air Directors Consortium (LADCO) contracted with E. H. Pechan & Associates to develop growth factors for point and area sources in the 5-state Midwest Regional Planning Organization to support future year control strategy analyses for ozone, PM2.5 and regional haze. The factors that were developed were specific to each state and were based primarily on factors/data from U.S. EPA’s Economic Growth Assessment System (EGAS 5.0) model. The base year for these growth factors was 2002.

The growth factors supplied by LADCO were used to calculate 2008 emissions for all point sources except utilities. Emissions from EGUs were obtained from the 2005 “VISTAS run” of the Integrated Planning Model (IPM). This run is consistent with the run being using for the modeled attainment demonstration. The IPM model was run using the NOx SIP Call regulatory requirements (see 35 Ill. Adm. Code 217 Subpart U for Illinois specific information) and CAIR. The emissions output by the model are for 2009. To obtain 2008 emissions, a linear interpolation between 2002 and 2009 emission levels was used.

In Illinois, there are approximately 60 ethanol and biodiesel plants undergoing permitting. The large increase in the number of these types of plants is most likely not reflected in the growth factors supplied by LADCO. These plants are not in the 2002 base year inventory. They have the potential to be operating in 2008. The locations of these new plants were plotted and three were identified as being located in the NAA. These sources included in the projected inventory are:

• ABG North America – Madison • Center Ethanol Co – Sauget • Omni BioEnergy – Granite City

26 The emissions from these sources were calculated by using the allowable emission rates and anticipated operating hours identified in the permit and permit application. The sources were assumed to begin operation in 2008. The emissions increase associated with these sources is projected to be 0.26 tons NOx/day and 1.70 tons VOM/day.

Another planned new source is Gateway Energy and Coke Company in Granite City, Illinois. This source is a heat recovery coke manufacturing facility currently undergoing permitting. Planned emissions from this source were obtained from the permit application and were added to the inventory assuming operation beginning in 2008. This is an increase of 1.56 tons NOx/day and 0.10 tons VOM/day. This new construction will require reductions from US Steel Granite City (formerly Granite City Steel). These reductions were not included in the future year inventory.

The projected 2008 NOx and VOM emissions for point, area, and on-road mobile sources are shown in Tables 5-3, 5-4, and 5-5, respectively.

Table 5-3: Projected Point Source Emissions for 2008 (tons/day)

County NOx VOM Jersey 0.00 0.04 Madison 49.07 15.26 Monroe 0.22 0.08 St. Clair 3.53 4.63 Total 52.83 20.00

Table 5-4: Projected Area Source Emissions for 2008 (tons/day)

County NOx VOM Jersey 0.06 2.29 Madison 0.79 14.11 Monroe 0.08 2.42 St. Clair 0.57 11.82 Total 1.50 30.64

27 Table 5-5: Projected On-road Mobile Source Emissions for 2008 (tons/day)

County NOx VOM Jersey 0.97 0.66 Madison 16.84 6.52 Monroe 1.83 0.85 St. Clair 15.23 6.24 Total 34.87 14.27

U.S. EPA’s NONROAD model was used to calculate emissions form off-road mobile sources for 2008. Inputs used for the model are described in “Illinois Base Year Ozone Inventory for 2002” (June 2006). The NONROAD model does not calculate emissions for marine vessels, locomotives and aircraft. Projected emissions for 2008 for marine vessels and locomotives were calculated using the growth factors provided by LADCO. Aircraft emissions were also calculated using growth factors from LADCO. However, preference was given to data from the Federal Aviation Administration (FAA) showing the growth of landings and take-offs at airports with control towers. In anticipation of expanded use of Mid-America Airport and Scott Air Force Base, both VOM and NOx emissions were increased to 1.0 tons per day in 2008. Table 5- 6 summarizes projected 2008 NOx and VOM emissions from off-road mobile sources.

Table 5-6: Projected Off-road Mobile Source Emissions for 2008 (tons/day)

County NOx VOM Jersey 4.65 1.44 Madison 16.71 5.95 Monroe 8.22 1.57 St. Clair 8.25 5.12 Total 37.83 14.07

Table 5-7 and 5-8 summarize the 2008 projected NOx and VOM emissions in the Metro-East NAA from all man-made sources.

28 Table 5-7: Total Projected NOx Emissions for 2008 (tons/day)

Point Area On-road Off-road County Sources Sources Mobile Mobile Total Sources Sources Jersey 0.00 0.06 0.97 4.65 5.68 Madison 49.07 0.79 16.84 16.71 83.41 Monroe 0.22 0.08 1.83 8.22 10.35 St. Clair 3.53 0.57 15.23 8.25 27.58 Total 52.83 1.50 34.87 37.83 127.02

Table 5-8: Total Projected VOM Emissions for 2008 (tons/day)

Point Area On-road Off-road County Sources Sources Mobile Mobile Total Sources Sources Jersey 0.04 2.29 0.66 1.44 4.43 Madison 15.26 14.11 6.52 5.95 41.84 Monroe 0.08 2.42 0.85 1.57 4.92 St. Clair 4.63 11.82 6.24 5.12 27.81 Total 20.00 30.64 14.27 14.07 79.00

5.2 Calculation of 15 Percent RFP Target Value

This section details the calculations used to calculate the required amount of reductions required to meet an overall reduction of 15 percent.

• Step 1. Establish the emissions for the baseline year • Step 2. Identify any adjustments (non-creditable reductions such as FMVCP) • Step 3. Calculate the adjusted baseline (Step 1 – Step 2) • Step 4. Calculate mandated reductions (Step 3 x 0.15) • Step 5. Calculate total reductions (Step 4 + Step 2) • Step 6. Identify the target emissions for the future year (Step 1 – Step 5)

The result in Step 6 is the level of emissions that must be achieved to meet the 15 percent reduction. If the future year emissions are greater than the target emissions, the 15 percent

29 reduction has not been met. The value in Step 3 can be used in combination with the future year emissions to calculate the actual reduction.

5.2.1 VOM Calculation

Step 1. Total baseline emissions = 17.41 + 29.86 + 23.57 + 12.04 = 82.88 tons/day Step 2. Non-creditable reductions from FMVCP = 0.33 tons/day Step 3. Adjusted baseline emission = 82.88 – 0.33 = 82.55 tons/day Step 4. Mandated reductions = 82.55 x 0.15 = 12.38 tons/day Step 5. Required reductions = 12.38 + 0.33 = 12.71 tons/day Step 6. Target emissions for 2008 = 82.88 – 12.71 = 70.17 tons/day

This target level from Step 6 is the amount of emissions that would be necessary if the total reduction came from reductions in VOM alone. Since the 2008 target level of 70.17 tons/day is less than the 2008 projected VOM emissions shown in Table 5-8 (79.00 tons/day), Illinois’ RFP plan relies on substitution of NOx emission reductions expected in the NAA by 2008.

5.2.2 NOx Calculation

The calculation methodology for NOx substitution is exactly the same as described previously for VOM:

Step 1. Total base year emissions = 53.24 + 1.40 + 47.07 + 36.79 = 138.50 tons/day Step 2. Non-creditable reductions from FMVCP = 1.49 tons/day Step 3. Adjusted baseline emission = 138.50 – 1.49 = 137.01 tons/day Step 4. Mandated reductions = 137.01 x 0.15 = 20.55 tons/day Step 5. Required reductions = 20.55 + 1.49 = 22.04 tons/day Step 6. Target emissions for 2008 = 138.50 – 22.04 = 116.46 tons/day

This target level is the amount of emissions that would be necessary if the total reduction came from reductions in NOx alone. Since the 2008 target level of 116.46 tons/day is less than the

30 2008 projected NOx emissions shown in Table 5-7 (127.02 tons/day), Illinois’ RFP plan can not rely solely on NOx reductions to meet the RFP requirement. As described in the next Section, Illinois RFP plan relies on reductions of both VOM and NOx to meet the RFP requirement.

5.3 Fifteen Percent Reasonable Further Progress (RFP) Demonstration

The projected 2008 emissions summarized in Tables 5-7 and 5-8 do not account for certain emission reduction measures expected to occur by that year. The reductions not previously accounted for include shutdowns of sources, implementation of new regulations, and federal consent decrees affecting some sources in the NAA. Illinois EPA has carefully checked its emission reduction assumptions and analyses to make sure no double counting of source reductions has taken place.

The current point source inventory was reviewed to identify sources that were included in the 2002 base year inventory that had ceased operating after 2002. One source in the NAA was identified, “360 Networks” previously located in East St. Louis. This source shut down in January 2005 and represents 0.89 tons NOx/day and 0.07 tons VOM/day.

The ConocoPhillips refinery in Roxana is subject to a Federal consent decree regarding the source’s catalytic cracking units. A reduction in NOx of 99 percent is expected for Catalytic Cracker #1 by the end of 2008. Illinois EPA met with representatives of ConocoPhillips to discuss the activities, schedule and reductions in emissions that were planned at the source to achieve compliance with the consent decree. Additional information was also provided on additional reductions from combustion units at the refinery that are to be achieved by then end of 2008. All of these revisions were incorporated into the 2008 inventory and equate to a reduction of 2.82 tons NOx/day. A small reduction of 0.01 tons VOM/day is also realized.

Consumer and commercial products are currently regulated by the U.S. EPA under 40 CFR 59 Subpart D, promulgated on September 11, 1998. This national rule currently limits the VOM content of 24 product categories. These 24 categories are included in six larger categories: personal, household, automotive aftermarket, adhesive, pesticide and miscellaneous products.

31 Illinois EPA is developing a regulatory proposal, based on the OTC model rule, regulating VOM emissions from a wider range of consumer products than are currently covered by federal regulations. U.S. EPA is also expected to propose new regulations affecting these same products. Illinois expects these requirements will reduce VOM from this category by 14.2 percent, or a reduction of 0.80 tons VOM/day in the Metro-East NAA.

Similarly, architectural and industrial maintenance coatings are currently regulated by the U.S. EPA under 40 CFR 59 Subpart D, promulgated September 11, 1998. Proposed revisions to this national rule will reduce VOM emissions by an additional 31 percent. This reduction is over a two-year period (2008-2009). To estimate the reductions that will be achieved in 2008, a reduction of 15.5 percent, or one-half of the overall expected reduction, was used in this demonstration. This results in a reduction of 0.79 tons VOM/day.

In July 2006, the Governor of the State of Illinois petitioned the U.S. EPA to require the sale of reformulated gasoline in the Metro-East area. The Clean Air Act allows the U.S. EPA one year to implement the program. The RFG program will likely begin during the 2007 summer season.

TheT 2008 projected inventory summarized in Table 5-7 and 5-8 do not account for the use of RFG in Jersey County. However, RFG will be required in Jersey County, resulting in additional emission reductions of 0.03 tons NOx/day and 0.13 tons VOM/day.

Table 5-9 identifies the adjustments made to the projected 2008 inventory and demonstrates that the Metro-East area will meet the required fifteen percent reduction target. As shown in the table, the total reduction for the NAA is 6.48 percent (VOM) and 10.01 percent (NOx), or 16.49 percent below the baseline inventory. This value meets the requirement of a 15 percent reduction for RFP.

32 Table 5-9: Demonstration of RFP in Nonattainment Area

2002 2008 2002 VOM 2008 VOM Category NOx NOx (tons/day) (tons/day) (tons/day) (tons/day) Point 53.24 52.83 17.41 20.00 Shutdowns -0.89 -0.07 ConocoPhillips Consent Decree -2.82 -0.01

Area 1.40 1.50 29.86 30.64 Consumer Solvent -0.80 AIM Coatings -0.79 On-road Mobile 47.07 34.87 23.57 14.27 FMVCP -1.49 -0.33 RFG in Jersey County -0.03 -0.13 Off-road Mobile 36.79 37.83 12.04 14.07 Total 137.01 123.29 82.55 77.18 Percent Reduction 10.01 6.48

33 6.0 Reasonably Available Control Technology (RACT)

Pursuant to Sections 172, 182(b) and (f) of the CAA, RACT is required for all existing major sources of the applicable criteria pollutant and its precursors (VOM and NOx) located in NAAs. U.S. EPA defines RACT as the lowest emission limitation that a particular source is capable of meeting by the application of control technology that is reasonably available considering technological feasibility and economic reasonableness (70 FR 71612; November 29, 2005). The major source threshold for moderate NAAs is defined as 100 TPY. A source generally consists of several units that emit pollutants. The sum of emissions from all units at the source determines if a unit is major and thus subject to RACT requirements.

RACT is not a new requirement under the CAA. Illinois previously addressed RACT requirements in the Metro-East area in developing attainment plans for the 1-hour ozone standard. The RACT requirement for NOx was previously waived under the 1-hour ozone standard, and Illinois must adopt new regulations to implement NOx RACT in the NAA. However, Illinois has previously adopted RACT requirements for VOM emissions in the NAA. (See 35 Ill. Adm. Code Part 219) The Illinois EPA has evaluated the previously adopted regulations to determine if the RACT requirement is still being met for 8-hour ozone. It should be noted that there are no emission sources in Jersey County to which Illinois’ VOM RACT rules

apply.

Sections 172, 182(b)(2), and 182(f) of the CAA require implementation of RACT for sources that are subject to Control Techniques Guidelines (CTGs) that are promulgated by U.S. EPA. The U.S. EPA has issued CTGs defining RACT for those categories of sources that emit the greatest amounts of VOM emissions. Emissions sources covered by CTGs are referred to as CTG sources. Table A in Appendix C presents the CTG source categories, CTG reference documents, and the applicable Illinois rules promulgated in response to the CTGs. Table B in Appendix C presents CTG source categories where no sources located in the ozone NAA within that category were found. Based on this review, Illinois EPA has adopted rules addressing all CTG categories adopted by U.S. EPA.

34 Non-CTG sources are defined as major VOM sources which are not subject to CTGs, but for which RACT is required. All major sources of ozone precursors located in the ozone NAA that are not subject to individual RACT rules are subject to a generic RACT rule. These rules apply to non-CTG sources that have the potential to emit 100 tons or more per year of VOM. Thus, Illinois has met the obligation to implement RACT on non-CTG VOM sources in the NAA.

It should be noted that other regulatory requirements also affect VOM emission sources within the Metro-East ozone NAA. These include Maximum Achievable Control Technology (MACT), federal New Source Performance Standards (NSPS), and National Emission Standards for Hazardous Air Pollutants (NESHAPS). These programs satisfy the RACT requirements for specific source categories because these rules are more stringent than RACT.

It is concluded from this review that Illinois’ existing VOM RACT rules fulfill U.S. EPA’s RACT requirements for VOM sources in the NAA. As mentioned previously, however, the RACT requirement for NOx was previously waived under the 1-hour ozone NAAQS, so Illinois must adopt new regulations to implement NOx RACT in the NAA. With respect to the 8-hour

ozone NAAQS, Illinois will not pursue the NOx waiver because the local-scale, NOx disbenefit (i.e., the scavenging of ambient ozone by local NOx emissions) is not as important for the longer 8-hour averaging time. Also, the level of the 8-hour ozone NAAQS is closer to regional background levels in the Midwest, which argues for the application of controls on a regional basis. Illinois therefore intends to submit a SIP revision to implement NOx RACT requirements per Sections 182(b)(2) and 182(f) of the CAA.

The Illinois EPA has identified the following RACT categories: engines and turbines; industrial boilers; process heaters; glass melting furnaces; non-metal manufacturing processes (cement & lime kilns); primary, secondary, and fabricated metal products and machinery manufacturing (iron, steel, aluminum melting); EGUs; and other emission units. The Illinois EPA has recently

proposed as a fast-track rulemaking a proposal addressing NOx emissions from stationary

reciprocating internal combustion engines and turbines that will satisfy the NOx RACT requirements. Adoption is expected on an expedited schedule. With respect to the remaining

35 source categories, the Illinois EPA commits to proposing and implementing regulations that meet the NOx RACT requirement by the 2009 ozone season.

36 7.0 Contingency Measures

Section 172 (c)(9) of the CAA require states with ozone nonattainment areas classified as moderate and above to adopt contingency measures by June 15, 2007. Such measures must provide for the implementation of specific emission control measures if an ozone NAA fails to achieve required ROP reductions or fails to attain a NAAQS within the time-frames specified under the CAA. The CAA requires that the contingency measures take effect without further action by the state or by the U.S. EPA upon failure by the state to meet ROP requirements or attainment of the NAAQS by the required deadline.

The General Preamble for the Implementation of Title I of the Clean Air Act Amendments of 1990 (57 Fed. Reg. 13507, April 16, 1992) states that the contingency measures, in total, must generally be able to provide for 3 percent reductions from the adjusted 2002 baseline emissions. A 3 percent reduction in VOM emissions equates to 2.48 tons per day and a 3 percent reduction in NOx emissions equates to 4.11 tons per day. While all contingency measures must be fully adopted rules or measures, states can use measures in two different ways. A state can choose to implement contingency measures before the June 15, 2008, RFP milestone deadline. Alternatively, a state may decide not to implement a contingency measure until an area has actually failed to achieve an RFP or attainment milestone. In the latter situation, the contingency measure emission reduction must be achieved within one year following identification of a milestone failure.

To satisfy the requirements for contingency measures needed for the RFP plan and the attainment plan, Illinois is relying on a mix of federal and state measures, some of which were required under the CAA and some of which were state-specific measures. All measures relied upon in the plan have been adopted and will be implemented in the Metro-East NAA, or within 200 kilometers of the four county ozone NAA, during the 2002-2010 timeframe. Some of these measures will also provide further emission reductions beyond the 2010 attainment year.

Pursuant to U.S. EPA guidance document “Guidance on the Post-1996 Rate-of-Progress Plan and the Attainment Demonstration” (EPA-452/R-93-015), NOx reductions within 200 kilometers

37 and VOM within 100 kilometers may be used to demonstrate RFP. Although Illinois does not need to rely on upwind NOx reductions to demonstrate RFP, it is appropriate to consider the reductions occurring outside the NAA as contingency measures.

Illinois is relying on one or more of the following federal and state measures to satisfy the requirement for contingency measures: • Tier 2 Motor Vehicle Emissions Standards • Heavy-duty diesel engine standards • Federal railroad/locomotive standards • Federal commercial marine vessel engine standards • Phase II of the Clean Air Interstate Rule • Multi-Pollutant Strategy contained in Illinois’ Clean Air Mercury Rule • Best Available Retrofit Technology (BART) • Portable Fuel Containers

Although the Illinois EPA has not quantified the emission reductions expected from these control measures, the reductions within and upwind of the NAA will greatly exceed the reduction target needed to meet the contingency measure requirement. More importantly, these measures will help to ensure that the area, once it has attained the 8-hour ozone NAAQS, will continue to do so in future years.

38 8.0 Legal Authority and Resource Commitments

As set forth in earlier SIP revisions, the Illinois EPA has the necessary legal authority to implement the Attainment Demonstration that is being submitted. In brief, the legal authority for the State of Illinois to carry out its implementation plan is established in the Environmental Protection Act (Act) [415 ILCS 5/1 et seq]. The Act is a comprehensive piece of legislation designed to place the control and enforcement of every type of environmental problem under one body of law.

Pursuant to Section 4(l) of the Act, the Illinois EPA is designated as the air pollution agency for the State for all purposes of the CAA, including developing SIPs and proposing regulations. In accordance with and by the authority granted by the Act, the Illinois EPA will continue providing adequate funding and personnel to implement the provision of this plan for meeting the air quality standards.

The Illinois Pollution Control Board (Board) has been designated under the Act as the agency responsible for adoption of emission control regulations and has the authority necessary to adopt the type of regulations for the control of VOM emissions from consumer products and architectural and industrial maintenance coatings included in this plan (Section 5 of the Act).

The Illinois EPA is empowered to enforce the Act and applicable regulations promulgated thereunder (Title VIII of the Act). The Illinois EPA is directed to investigate alleged violations upon the request of the Board or upon receipt of information alleging a violation and may make such other investigations as it shall deem advisable. If such an investigation discloses that a violation may exist, the Illinois EPA shall bring an enforcement action against the violator before the Board in accordance with the Act and applicable State rules.

The Board’s orders may be enforced by the Illinois EPA or the State’s Attorney of the county in which the violation occurred, or by the Attorney General of Illinois (Sections 33(d) and 42 of the Act). Injunctive relief is specifically authorized under Section 43 and 45(b) of the Act. In addition, violation of the Act, or of regulations adopted pursuant to the Act, or knowingly

39 submitting any false information is a criminal misdemeanor (Section 44 of the Act). Section 44 of the Act also provides that it is the duty of every State and local law enforcement officer to enforce the Act and regulations and authorizes the issuance of citations for that purpose.

40

Appendix A

Transportation Conformity

41

External M6.2 Inputs: Vehicle Inspection and Maintenance (I/M) Program

The External I/M file giving the inputs used in the MOBILE6 model in this exercise were ILLOBDIM.D (for 2002 and through 2006) and IM07ON.D (for 2007 and later years). When evaluating I/M credits for 2008, the residual effect of the ILLOBDIM program in the summer of ’08 is taken into account by assuming that 75% of the vehicle fleet subject to I/M has been tested under the IM07ON program by that time, and that the other 25% have been tested under the ILLOBDIM in late 2006 and have not yet come up for retesting under IM07ON by summer 2008 (both programs are biennial). The effective I/M emission rate in 2008 is thus 25% of ILLOBDIM’s plus 75% of IM07ON’s. By summer 2009, all vehicles subject to I/M will have been tested under IM07ON, so this question does not arise: the I/M emission rate is simply that for the IM07ON program.

The IM07ON.D File, used for the 2008 and 2009 target year inventory

The external I/M file IM07ON.D is described below. It represents an I/M program with four components, chief of which is an OBD (on-board diagnostics) test for vehicles of model year (MY) 1996 and newer. The order in which the components appear in the external file is not significant, but they must be numbered consecutively. Illinois EPA begins IM07ON.D with identifying comments, and adds other comment lines or blank lines to make the file easier to read and understand. Programs after the first need comparatively few comments because the commands are largely self-descriptive.

* ILLINOIS ENHANCED I/M DESCRIPTION

* Filename: IM07ON.D

* External input file for Illinois' OBD-only I/M program * from 2007 on. * OBD-only applies to light-duty vehicles only; HDVs still get * an Idle Test & Gas Cap Check. * All program start years set to 1986 per U.S. EPA guidance in * "Frequently Asked Questions on MOBILE6" from U.S. EPA/OTAQ.

* This represents the NEW I/M program in which only 1996 & * newer vehicles are tested with an OBD test; and the OBD test * applies only to LDVs. * This program came into effect in February 2007.

*------* Program description for post MY'96 LDV OBD I/M *======

* FIRST I/M program--"Evap[orative]" OBD for MY 1996+ LDVs

42 *------I/M PROGRAM : 1 1986 2050 2 T/O EVAP OBD I/M MODEL YEARS : 1 1996 2050 I/M VEHICLES : 1 22222 11111111 1 I/M STRINGENCY : 1 20.0 I/M COMPLIANCE : 1 95.0 I/M WAIVER RATES : 1 0.5 2.2 '01 data I/M EXEMPTION AGE : 1 25 I/M GRACE PERIOD : 1 4

In each case, the first number after the colon (here, 1) refers to the I/M program’s component number.

I/M PROGRAM : 1 1986 2050 2 T/O EVAP OBD Testing began in 1986 and runs into the indefinite future (2050). The program is a biennial test-only (2 T/O, here and in other program components) program, in this case an Evaporative On-Board Diagnostics (OBD) test. The On-Board Diagnostic program in a vehicle’s engine computer records information from sensors in the engine and fuel system. Indications of malfunctions or out-of-specification operations of the engine or fuel and evaporative emission control systems are stored in the engine computer as “fault codes”. An OBD test consists of plugging a special scanner into an output jack from vehicle’s engine computer. The scanner queries the computer and records any fault codes that the computer’s OBD system has saved. OBD tests are quick, dependable, and clean, and, if a vehicle fails an OBD test, the fault codes that the scanner displays help mechanics diagnose the problem. The 4-year grace period means that only vehicles of MY1996 through MY2005 vehicles undergo the OBD test in 2009.

I/M MODEL YEARS : 1 1996 2050 This program component covers only vehicles manufactured between model year (MY) 1996 (start year) and the indefinite future (MY 2050, the end year). More and more vehicles are becoming subject to this test as new vehicles are bought and older (pre- MY-1996) ones are scrapped vehicles.

I/M VEHICLES : 1 22222 11111111 1 Only the five light-duty vehicle types (cars [LDGVs], and light trucks [LDGTs 1, 2, 3, and 4]) are covered by this program component (22222). Heavy-duty gasoline trucks (eight types) and gasoline buses are not covered by this program component (11111111 1), but rather by Programs 3 and 4, described below.

I/M STRINGENCY : 1 20.0 Stringency (exhaust inspection failure rate) is 20%. A Stringency entry is necessary for an Exhaust test, but not an Evaporative test, so this entry can be omitted or “commented out”. In this Evap test case, it will be ignored by the model, but is included for reference.

I/M COMPLIANCE : 1 95.0 Compliance rate (tested vehicles as percent of all vehicles subject to I/M) is 95%

43

I/M WAIVER RATES : 1 0.5 2.2 '01 data The Waiver Rate is the fraction of tested vehicles that get a waiver—i.e., do not pass the I/M test but, because repairs cost more than a specified amount, get a certificate of compliance. Waiver rate is 0.5% for MY 1980 and earlier vehicles (irrelevant now that pre-MY-96 vehicles are not tested), and 2.2% for MY 1981 and later vehicles. These figures are from VIM’s actual 2001 waiver statistics, and have been representative of the last few years, so are deemed representative of 2009. In this case the comment stating that fact is allowed in the same line as the data.

I/M EXEMPTION AGE : 1 25 Vehicles older than 25 years are not subject to this program. This will not happen until at least 2021. The default is 25, and the model does not calculate benefits for vehicles older than 25 years, so in essence this command has no effect. It could be omitted, but is included for completeness.

I/M GRACE PERIOD : 1 4 Vehicles less than 4 model years old—in this case MY2006, ’07, ’08, and ’09—are exempt from I/M testing.

Most of the inputs to the second and subsequent program components are the same as those for the first program, so the description of the components will be abbreviated and summarized as below, rather than after each command line as above.

* Second I/M program--"Exhaust" OBD for MY 1996+ LDVs *------I/M PROGRAM : 2 1986 2050 2 T/O OBD I/M I/M MODEL YEARS : 2 1996 2050 I/M VEHICLES : 2 22222 11111111 1 I/M STRINGENCY : 2 20.0 I/M COMPLIANCE : 2 95.0 I/M WAIVER RATES : 2 0.5 2.2 '01 data I/M EXEMPTION AGE : 2 25 I/M GRACE PERIOD : 2 4 *

The second program component is a biennial, test-only Exhaust OBD test for MY 1996 and later LDGVs and LDGTs. In this OBD test, the scanner queries the vehicle’s computer for fault codes concerning exhaust emissions. Stringency, Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the first program. An entry for I/M STRINGENCY (20%) is required for an Exhaust I/M program.

*------* Program description for post MY'96 HDV Idle & GC I/M *======

* Third I/M program--HDV IDLE for MY 1996+ HDVs *------

44 I/M PROGRAM : 3 1986 2050 2 T/O IDLE I/M MODEL YEARS : 3 1996 2050 I/M VEHICLES : 3 11111 22222222 2 I/M STRINGENCY : 3 20.0 I/M COMPLIANCE : 3 95.0 I/M WAIVER RATES : 3 1.2 1.5 '01 data I/M EXEMPTION AGE : 3 25 I/M GRACE PERIOD : 3 4

The third program component is a biennial, test-only Idle test for MY 1996 and later HDGVs and Gas Buses (22222222 2). Light-duty vehicles are not subject to this component (11111), but rather to components 1 and 2. Stringency, Compliance, Exemption Age, and Grace Period are the same as in component 1, but the pre- and post-MY 1981 Waiver Rates (1.2% and 1.5%, respectively), are slightly different from those in components 1 and 2. HDGVs are few in number, and most of them are commercial vehicles.

* Fourth I/M program--Gas Cap Check for MY 1996+ HDVs *------I/M PROGRAM : 4 1986 2050 2 T/O GC I/M MODEL YEARS : 4 1996 2050 I/M VEHICLES : 4 11111 22222222 2 I/M COMPLIANCE : 4 95.0 I/M WAIVER RATES : 4 1.2 1.5 '01 data I/M EXEMPTION AGE : 4 25 I/M GRACE PERIOD : 4 4

The fourth program component is a biennial, test-only Gas Cap Check for MY 1996 and later HDVs. Compliance, Waiver Rates, Exemption Age, and Grace Period are the same as in the third program. Since a Gas Cap Check is an evaporative I/M test, the I/M STRINGENCY command is not necessary and is not included here.

Illinois EPA includes further notes and comments in the I/M file to document it further, as shown below:

* NOTES

* This is a standard Illinois I/M input, describing the I/M * program with OBD Only as it is supposed to exist after * January 2007. It is the file to be used for regular M6 * I/M runs for 2007 and future years. * * This file was originally SB397.D, by Jim Matheny of * Illinois EPA/BOA/VIM, supplied to SL by JM 24.viij.05 and verified * by SL. JM's original SB397.D has been slightly revised by * the addition of comments such as this one. The actual * inputs have not been changed. This was done to put the two * LDV OBD programs (exhaust and evaporative) together, and the * two HDV programs together too. The order of the programs in * the I/M file is not significant and has no effect in M6, but * the programs must be numbered sequentially. * JM verified that this file as shown is correctly describes the * I/M program planned for introduction in January '07.

45 * ------* COMPARISON WITH ILLOBDIM.D: * The first three programs in ILLOBDIM.D, covering the idle * test for MY'68-'81 LDVs, IM240 for '81-'95 LDVs, and gas * cap check for MY'68-'95 LDVs have been eliminated from * IM07ON; and the two HDV programs now refer only to MY'96 * and later.

There is no “MYCUTS.D” file associated with IM07ON.D.

The Registration Distribution

The Registration Distribution (RD) is an indication of the fraction of the vehicle fleet that is made up of vehicles of a given age.

The following is part of the MERD01.D file, the external RD file used with the 2002 base year inventory. It and its contents are described in detail in the comments to the file. The RDs for all heavy-duty vehicles are the same as in the default REGDIST.D file, so only data for the first two HDV types are shown here.

REG DIST * * This file MERD01.D is derived from CHIRD01.D and REGDATA.D, the * default MOBILE6 RD file. This file was created 29.v.02 by SSL. * * It contains Registration Distribution fractions for the 16 vehicle * classes by age for July of any calendar year for the Metro-East NAA, * based on 2001 gasoline-vehicle age distribution data supplied to * SL by Jim Matheny of DVIM. * * The user is referred to REGDATA.D and to M6 Users Guide Section * 2.8.7.1 (p. 63 ff) for more detailed information about the nature * of RD files. See also Section 5.3.2 (p. 169 ff) for information * on converting M5b RDs to M6 RDs. See also \SOURCE\BD20.FOR * * In this file, the first number in each distribution is an integer * that indicates which of the 16 M6 vehicle classes are represented * by the RD in question. (1=LDV, 2=LDT1, etc) That number is * followed by 25 age fractions arranged in two rows of 10 values * and a third row with the last 5 values. The last value on the * third line is the fraction of vehicles 25 years old or older. * In this file, the first few values 1 0.045 0.075 ... means that * 4.5% of LDVs were 1 year old or less, 7.5% were 1-2 years old, etc. * (This is similar to the format of RDs in M5b.) * * RDs for all vehicle classes are given in this file. This is for * completeness, even though only those vehicle classes whose RDs * were changed from the REGDATA defaults need to be included in * this file. Those that were not changed, are so noted. * * See file RDAGE01.XLS for original '01 Age Distribution data

46 * from VIM, and also \AREASPEC\M5RD01.txt, which is a MOBILE5b-type * RD for the Chicago & Metro-East area for '01 derived from RDAGE01. * * LDVs and LDTs were assumed to have the same RDs as LDGVs and LDGTs * would have in M5b. HDVs were assumed to have the default RDs. * * As of May 2002, I have assumed Default RDs for the various HDV (& MC) * classes, since, although I have information on area-specific HDGV * age distributions, I do not have such information for HDDVs and * can only assume the default age distribution for heavy diesels.

* M6 LDV = M5 LDGV (Light-duty Vehicles--passenger cars--from * RDAGE01.XLS and M5RD01.TXT for Metro-East 1 0.045 0.075 0.081 0.083 0.081 0.070 0.075 0.065 0.058 0.053 0.051 0.042 0.043 0.038 0.029 0.026 0.023 0.014 0.010 0.006 0.004 0.003 0.005 0.004 0.016 * M6 LDT1 = (M5) LDGT1 as in RDAge01 for Metro-East 2 0.053 0.081 0.096 0.076 0.071 0.069 0.074 0.064 0.059 0.047 0.045 0.045 0.047 0.041 0.027 0.026 0.020 0.013 0.011 0.008 0.005 0.002 0.005 0.002 0.013 * M6 LDT2 = (M5) LDGT1 as in RDAge01 3 0.053 0.081 0.096 0.076 0.071 0.069 0.074 0.064 0.059 0.047 0.045 0.045 0.047 0.041 0.027 0.026 0.020 0.013 0.011 0.008 0.005 0.002 0.005 0.002 0.013 * M6 LDT3 = (M5) LDGT2 as in RDAge01 4 0.046 0.086 0.065 0.055 0.062 0.075 0.064 0.078 0.059 0.049 0.045 0.047 0.038 0.042 0.027 0.030 0.016 0.017 0.011 0.010 0.004 0.006 0.021 0.021 0.026 * M6 LDT4 = (M5) LDGT2 as in RDAge01 5 0.046 0.086 0.065 0.055 0.062 0.075 0.064 0.078 0.059 0.049 0.045 0.047 0.038 0.042 0.027 0.030 0.016 0.017 0.011 0.010 0.004 0.006 0.021 0.021 0.026 * HDV2B (Heavy-duty vehicles 2B--M6 Default RDs) 6 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167 0.0152 0.0138 0.0126 0.0114 0.0499 * HDV3 (Heavy-duty vehicles3, same RD as HDV2B, as in M6 Default RDs) 7 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167 0.0152 0.0138 0.0126 0.0114 0.0499

Here is the MERD03.D file, which was used in the future-year (2008 and 2009) forecasts, as being the most current available. Again, only the first two HDV RDs are shown because the RDs for all heavy-duty vehicles are the same as in the default REGDIST.D file. It is not very different from either the default RD file or the 2001 file above.

REG DIST * * This file MERD03.D is derived from CHIRD01.D, MERD01, and REGDATA.D, the * default MOBILE6 RD file. * * It contains Registration Distribution fractions for the 16 vehicle classes

47 * by age for July of any calendar year for the Metro-East NAA, based on * 2003/4 gasoline-vehicle age distribution data supplied by ERG, which * took registration data statewide from ISOS and turned it into the LDV/LDT * RDs shown below. * * The user is referred to REGDATA.D and to M6 Users Guide Section 2.8.7.1 (p. * 63 ff) for more detailed information about the nature of RD files. See * also Section 5.3.2 (p. 169 ff) for information on converting M5b RDs to M6 * RDs. See also \SOURCE\BD20.FOR, the default RD built into M6. * * In this file, the first number in each distribution is an integer that * indicates which of the 16 M6 vehicle classes are represented by the RD in * question. (1=LDV, 2=LDT1, etc) That number is followed by 25 age fractions * arranged in two rows of 10 values and a third row with the last 5 values. * The last value on the third line is the fraction of vehicles 25 years old * or older. In this file, the first few values 1 0.045 0.075 ... means that * 4.5% of LDVs were 1 year old or less, 7.5% were 1-2 years old, etc. This is * similar to the format of RDs in M5b.) * * RDs for all vehicle classes are given in this file. This is for * completeness even though only those vehicle classes whose RDs were changed * from the REGDATA defaults need to be included in this file. Those that * were not changed, are so noted. * * See file RDAGE01.XLS for original '01 Age Distribution data from VIM, * and also \AREASPEC\M5RD01.txt, which is a MOBILE5b-type RD for the Chicago * & Metro-East area for '01 derived from RDAGE01. * * It is assumed that the RDs for diesel vehicles are the same as the RDs for * the corresponding gasoline vehicles; in particular, LDDV and LDDT RDs are * assumed the same as LDGV and LDGT RDs. Since the (default) HDV RDs are * based more on diesel vehicles to start with, and HDGVs are many fewer than * HDDVs, especially in the higher weight classes, we feel the HDV RDs * represent both HDGV and HDDV reasonably well. * * Default RDs assumed for the various HDV classes. Good area-specific * HDV age distribution data are lacking--RD03ERG covered only LDVs--and * besides, much Metro-East-area HDV VMT is from vehicles registered outside * the Metro-East area. The best choice, then, was to go with the HDV * defaults; and similarly with MCs. *

* M6 LDV = M5 LDV (Light-duty Vehicles--passenger cars--from * RD03ERG.XLS for the 3-county Metro-East area 1 0.0512 0.0682 0.0755 0.0782 0.0807 0.0727 0.0606 0.0624 0.0565 0.0633 0.0511 0.0481 0.0412 0.0368 0.0310 0.0270 0.0211 0.0161 0.0136 0.0105 0.0073 0.0042 0.0025 0.0025 0.0177 * * M6 LDT1 = M5 LDT1 from RD03ERG.xls for Metro-East 2 0.0476 0.0634 0.0702 0.0437 0.0320 0.0305 0.0389 0.0315 0.0581 0.0561 0.0725 0.0564 0.0442 0.0595 0.0428 0.0500 0.0417 0.0425 0.0349 0.0249 0.0141 0.0099 0.0085 0.0070 0.0191

48 * * M6 LDT2 = LDT2 from RD03ERG.xls for Metro-East 3 0.0655 0.0874 0.0967 0.1007 0.1001 0.0889 0.0899 0.0773 0.0439 0.0440 0.0394 0.0364 0.0315 0.0226 0.0164 0.0147 0.0153 0.0048 0.0050 0.0041 0.0040 0.0026 0.0016 0.0010 0.0062 * * M6 LDT3 = LDT3 from RD03ERG.xls for Metro-East 4 0.0646 0.0861 0.0953 0.0831 0.0758 0.0821 0.0511 0.0479 0.0489 0.0632 0.0546 0.0369 0.0325 0.0192 0.0225 0.0219 0.0181 0.0143 0.0133 0.0112 0.0076 0.0055 0.0035 0.0021 0.0387 * * M6 LDT4 = LDT2 from RD03ERG.xls for Metro-East 5 0.0641 0.0855 0.0945 0.1084 0.0976 0.0986 0.0786 0.0701 0.0597 0.0527 0.0416 0.0137 0.0205 0.0067 0.0114 0.0053 0.0049 0.0062 0.0082 0.0102 0.0046 0.0032 0.0018 0.0003 0.0516

* HDV2B (Heavy-duty vehicles 2B--M6 Default RDs) 6 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167 0.0152 0.0138 0.0126 0.0114 0.0499 * HDV3 (Heavy-duty vehicles3, same RD as HDV2B, as in M6 Default RDs) 7 0.0503 0.0916 0.0833 0.0758 0.0690 0.0627 0.0571 0.0519 0.0472 0.0430 0.0391 0.0356 0.0324 0.0294 0.0268 0.0244 0.0222 0.0202 0.0184 0.0167 0.0152 0.0138 0.0126 0.0114 0.0499

There are similar RD files, not shown, for the Chicago area and for Downstate. The Downstate RD file is used for Jersey County; it is similar to the Metro-East file above.

External M6.2 Activity File Inputs: VMT by Facility Type, VMT by Hour, VMT by Speed Bin.

The following files were used in the 2002 base year and the 2008 and 2009 future year estimates.

VMT by Facility Type

The default file FVMT.D, provided with the MOBILE6 model, was used. EWGCOG model output for 2004 was not suitable for calculating data for an area-specific “FVMT-type” file. The default file was also used when evaluating Downstate counties including Jersey.

VMT by Hour of the Day

The default file is HVMT.D, used for Downstate counties including Jersey. EWCGOC model output was available for calculating a data for Metro-East-specific “HVMT-type” file. The VMT-by-Hour file for the three-county Metro-East area is HVMTME04.DEF, an extract of which is shown below. It represents 2004 transportation model output (the most recent available), deemed representative of 2009 as well.

VMT BY HOUR

49 * * Filename: HVMTME04.DEF * Fraction of all vehicle miles traveled by hour of the day. * First hour is 6 a.m. These data are for the Metro-East area * for 2004, derived from transportation model output from * Johnnie Smith of EWGCG in his NEWBUDGET.XLS file, and * calculated by SL in MESVMT.XLS, July '02, page "VMT by Hr". * 0.0518 0.0796 0.0704 0.0505 0.0491 0.0529 0.0553 0.0519 0.0544 0.0578 0.0967 0.0909 0.0624 0.0354 0.0280 0.0240 0.0176 0.0131 0.0098 0.0078 0.0074 0.0073 0.0089 0.0169

The HVMT default file, the HVMTME04 file above, and the HVMTCH7 file (for the Chicago area) all show similar hourly profiles, with morning and afternoon peaks, a noontime dip, and a minimum about 3AM - 4AM, which is to be expected.

For the purposes of calculating the HVMTME04 fractions, EWGCOG’s three transportation modeling periods: Morning Peak, Afternoon Peak, and Off-Peak were mapped to M6’s hourly periods as in the table below. The Off-Peak period has been here subdivided into Midday and Overnight.

EWGCOG Transportation Modeling Periods Mapped to M6.2 Hours Fraction of MOBILE6.2 M6.2 Period EGWCOG Period EGWCC Hours EGWCC VMT Period Hours Beginning Morning Peak (2 hr) 7 AM to 9 AM 15% 2 and 3 7 AM and 8 AM Off peak Midday (7 hr) 9 AM to 4 PM 37% 4 through 10 9 AM through 3 PM Afternoon Peak (3 hr) 4 PM to 7 PM 25% 11 thru 13 4 PM, 5 PM and 6 PM Off peak Overnight (12 hr) 7 PM to 7 AM 23% 14 through 1 7 PM through 6 AM

VMT by Speed Bin

The default file is SVMT.D, used for Downstate counties including Jersey. EWCGOC model output was available for calculating a data for Metro-East-specific “SVMT-type” file. The VMT-by-Hour file for the three-county Metro-East area is SVMTME04.DEF, shown below. It represents 2004 transportation model output (the most recent available), deemed representative of 2008 and 2009 as well.

SPEED VMT 1 1 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 2 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810 0.0000 1 3 0.0000 0.0108 0.0020 0.0146 0.0095 0.0710 0.0497 0.1262 0.0838 0.0676 0.1530 0.2308 0.1810 0.0000 1 4 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 5 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 6 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 7 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000

50 1 8 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 9 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 10 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 11 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 12 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 13 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 14 0.0000 0.0000 0.0000 0.0000 0 0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 15 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 16 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 17 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 18 0.0000 0.0092 0.0078 0.0017 0.0063 0.0727 0.0377 0.1349 0.0889 0.0574 0.1584 0.2814 0.1436 0.0000 1 19 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 20 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 21 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 22 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 23 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 1 24 0.0000 0.0000 0.0000 0.0000 0.0000 0.0191 0.0022 0.0665 0.0402 0.1210 0.0957 0.0735 0.5818 0.0000 2 1 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 2 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 3 0.0011 0.0025 0.0166 0.0664 0.1148 0.2216 0.2188 0.1577 0.0912 0.0910 0.0183 0.0000 0.0000 0.0000 2 4 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 5 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 6 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 7 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 8 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 9 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 10 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 11 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 12 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 13 0.0011 0.0006 0.0120 0.0847 0.1579 0.2560 0.1923 0.1588 0.1068 0.0298 0.0000 0.0000 0.0000 0.0000 2 14 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 15 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 16 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 17 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 18 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 19 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 20 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 21 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 22 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 23 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 2 24 0.0000 0.0000 0.0017 0.0197 0.0988 0.2301 0.2287 0.2461 0.0967 0.0782 0.0000 0.0000 0.0000 0.0000 * * Speed Bins: * 2.5 5.0 10.0 15.0 20.0 25.0 30.0 35.0 40.0 45.0 50.0 55.0 60.0 65.0+ * * Speed bins extend 2.5 mph on either side of the bin name (i.e., the 30 mph speed bin encompasses * speeds from 27.5 to 32.5 mph), except for the 2.5 mph bin (0 to 2.5 mph) and the 65+ mph bin (62.5 * mph or above) * * These data come from a spreadsheet supplied to SL by Johnnie Smith of EWGCC in July '02, titled * "Year 2004 VMT Results for New Budgets", being VMT output from EWGCC's transportation model * aggregated into the various speed bins by county and M6 road type for the AM Peak (7AM-9AM), * PM Peak (4PM-7PM), and Off-Peak (the other hours--9AM-4PM and 7PM-6AM). JS's data were read into * an Excel file MESVMT.XLS in which the actual calculations leading to the above numbers were * performed. See particularly page "Data for SVMTME04" of that spreadsheet for the derivation of * these numbers. * * The information in this file strictly speaking represent a speed distribution for 2004, but this * should be reasonably valid throughout the 2000-2010+ period. * * The above data are for the three Metro-East counties together, and for Freeways and Arterials only. * (VMT-by-speed factors for individual counties is have also been calculated from JS's data, but * SL feels that the regionwide factors are preferable for inventory and other purposes. * * See M6 User's Guide Sec. 2.8.8.2.c and Appendix B, Table 5: "Average Speed Ranges for Speed Bins * (SPEED VMT Command)" for further information about this file and its use. * * The first number in each line is roadway type: 1 = Freeways; 2 = Arterials. Locals and Ramps have * a fixed speed in M6, and therefore are not affected by this file. * The second number is the hour of the day, hour 1 being [hour beginning at] 6 AM, and hour 24 being * [hour beginning at] 5 AM the next day.

51 * The third and subsequent numbers are the fractions of VMT in that hour that occur within the * specified speed bins. These fractions were calculated from JS's file,which gave estimates of VMT * assigned to the AM Peak, PM Peak, and Off-Peak hours. * * Note that, for Freeways, most VMT is in the 45-50-55-60-mph speed bins, with lower speeds more * common during Peak hours (which is reasonable). Much the same holds for Arterials, where most * VMT is in the 25-30-35-mph speed bins (also reasonable). * * See also the default VMT-by-speed file SVMT.DEF for more information and comments. * * --SL, 1.viij.02 * Revisions: * 23.ix.02...Arterials Off Peak, which had been same as Freeway Off-Peak, corrected by SL. * 7.ix.06...Small changes made to text of these comments by SL. No changes to numerical data

52

Appendix B

2002 Emissions Inventory for the Metro-East Ozone Nonattainment Area

53 Table B-1: Metro-East NAA Emissions

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Point Sources External Fuel Combustion Electric Generation Coal 1.46 323.86 7.78 2,345.01 0.15 38.87 Natural Gas 2.65 20.16 6.61 136.88 0.08 1.73 Industrial Distillate Oil 0.01 2.77 0.22 11.00 0.00 0.14 Natural Gas 2.74 176.74 1.75 303.70 0.09 25.55 Residual Oil 0.19 36.22 0.56 143.94 0.01 2.65 Other 2.50 843.55 3.73 1,255.60 0.06 25.44 Commercial/Institutional Distillate Oil 0.00 0.26 0.09 1.15 0.00 0.01 Natural Gas 0.16 61.26 0.35 180.15 0.00 4.67 Other 0.91 227.63 0.16 41.72 0.34 85.90 Space Heating Natural Gas 0.00 0.05 0.00 0.27 0.00 0.01 Internal Fuel Combustion Electric Generation Distillate Oil 0.79 4.67 2.00 36.99 0.13 0.93 Landfill Gas 0.10 124.00 0.06 68.96 0.00 10.28 Natural Gas 1.49 8.16 1.43 37.20 0.04 1.36 Industrial Diesel 0.37 0.29 0.68 1.27 0.03 0.05 Distillate Oil 0.39 2.69 0.56 12.49 0.08 0.96 Natural Gas 0.09 1.06 0.21 1.38 0.00 0.01 Other 0.00 0.26 0.01 4.51 0.00 0.12 Commercial/Institutional Distillate Oil 0.14 0.65 0.26 1.99 0.00 0.01 Engine Testing Jet Fuel 0.00 0.33 0.00 0.90 0.00 0.14 Fugitives 0.00 0.14 0.00 0.53 0.00 0.01

54 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Industrial Processes Chemical Manufacturing Fixed Roof Tanks 0.00 0.37 Ink 0.02 3.00 Paint 0.03 7.89 Plastics 0.01 1.02 Varnish 0.00 1.54 Other 0.00 3.28 0.11 10.90 1.37 419.19 Fuel Combustion 0.00 0.08 0.00 0.16 0.00 0.00 Fugitives 0.05 19.98 Food/Agriculture Bakeries 0.00 0.41 0.05 3.27 Other 0.00 0.38 0.00 0.16 0.03 13.36 Primary Metal Production By-product Coke 0.07 15.75 0.01 3.12 0.21 85.37 Ferroalloy 0.02 6.19 Iron 0.04 16.60 0.33 125.49 Steel 35.08 12,296.97 1.66 164.55 0.15 45.53 Other 0.00 0.07 0.00 0.37 Fuel Combustion 0.00 0.24 0.01 1.03 0.00 0.01 Secondary Metal Production Aluminum 0.00 0.09 0.01 0.69 0.00 0.01 Copper 1.73 482.21 0.03 12.45 0.01 3.00 Gray Iron 0.00 0.11 0.00 2.19 0.08 17.38 Lead 0.00 0.77 0.01 6.49 0.00 0.00 Steel 0.00 0.10 0.09 12.40 0.57 29.88 Other 0.00 0.03 0.00 0.54 0.25 33.85 Fuel Combustion 3.80 1332.86 0.14 54.54 0.00 1.91 Fugitives 0.00 0.02 0.00 0.07 Mineral Products Asphalt Manufacturing 0.61 37.51 0.10 10.71 0.08 18.69 Brick 0.00 2.52 0.00 9.24 Bulk Materials 0.00 0.01 0.00 0.05

55 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Concrete Manufacturing 0.00 0.36 0.00 1.10 Other 0.00 0.45 Fuel Combustion 0.00 0.13 0.00 0.16 0.00 0.00 Petroleum Industry Cooling Towers 0.05 15.78 FCCU 0.00 0.04 2.90 1,060.68 0.00 0.02 Flares 0.84 196.41 0.07 36.13 0.08 41.48 Process Heaters 6.58 1,197.96 12.15 3,153.30 0.24 67.84 Waste Water 0.00 0.35 0.00 0.04 0.40 148.77 Other 0.17 46.73 0.24 0.00 0.10 0.01 Fugitives 0.84 352.87 Paper and Wood Products Pulpboard 0.01 0.81 Other 0.10 4.07 Rubber and Plastic Products Plastic Products 0.01 1.34 Fabricated Metal Products Other 0.01 0.40 0.01 0.81 0.01 5.48 Oil and Gas Production Natural Gas 0.00 0.08 0.00 0.43 0.00 2.31 Fuel Combustion 0.00 0.43 0.00 3.60 0.00 0.10 Miscellaneous Machinery 0.00 0.03 0.00 0.64 Transportation Equipment 0.00 0.81 Health Services Crematories 0.00 0.35 Sterilizers 0.00 0.30 Leather and Leather Products 0.00 1.04 Textile Products 0.00 1.95 Process Cooling 0.00 0.06 In-Process Fuel Use Natural Gas 0.48 126.21 5.32 1,246.51 0.02 2.46 Other 1.11 354.74 3.85 1,375.52 0.01 4.19

56 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Miscellaneous Manufacturing Miscellaneous Manufacturing 0.00 0.10 0.00 0.10 0.03 7.66 Fuel Combustion 0.64 228.52 0.35 140.79 0.00 0.06 Organic Solvent Emissions Organic Solvent Use Cold Cleaning 0.00 0.01 Degreasing 0.15 46.48 Dry Cleaning 0.07 33.98 Fugitives 0.00 3.62 Surface Coating Operations Adhesives 0.04 21.29 Automobiles 0.00 6.55 Magnet Wire 0.13 38.72 Metal Coils 0.00 3.71 0.02 25.86 0.53 138.76 Miscellaneous Metal Parts 0.42 84.09 Ovens 0.03 2.02 0.03 2.42 0.01 1.07 Paper 0.26 38.76 Thinning Solvents 0.00 4.56 Other 0.00 0.07 Fuel Combustion 0.01 1.06 0.02 1.45 0.00 0.07 Fugitives 0.00 0.50 Petroleum Product Storage Fixed Roof Tanks 0.00 0.43 2.73 931.48 Floating Roof Tanks 0.46 132.19 Variable Vapor Space Tanks 0.00 0.07 0.00 0.04 0.00 0.12 Fugitives 1.43 449.80 Bulk Terminals/Plants Fixed Roof Tanks 0.19 70.35 Floating Roof Tanks 1.03 331.56 Losses 1.49 108.69 Printing/Publishing Cleanup 0.00 1.20 Flexographic 0.02 18.30

57 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Lithographic 0.03 8.26 Rotogravure 0.02 12.33 Other 0.03 9.99 Petroleum Marketing/Transport Stage I 0.01 4.54 Tank Cars 0.01 1.05 0.00 0.52 0.39 33.96 Transportation 0.57 228.81 Fugitives 0.05 14.94 Organic Chemical Storage Fixed Roof Tanks 0.00 0.01 0.00 0.50 0.22 19.33 Floating Roof Tanks 0.00 5.02 Pressure Tanks 0.00 0.11 Organic Chemical Transport Organic Solvent Evaporation Evaporation 0.00 17.43 Other 0.00 0.41 0.00 4.08 0.02 10.37 Solid Waste Disposal Government Landfills 0.17 69.97 0.15 61.70 0.06 9.98 Commercial/Institutional Incineration 0.03 11.19 0.00 6.80 0.00 3.97 Fuel Combustion 0.00 0.03 Industrial Incineration 0.00 5.06 0.06 12.62 0.00 0.47 Landfills 0.66 237.06 0.07 26.82 0.00 0.70 Other 0.00 1.53 Site Remediation Air Stripping 0.00 24.89 Soil Venting 0.03 18.51 Other 0.16 80.35 Point Source Total 66.21 18,493.16 54.24 12,057.17 17.47 4,775.20

58 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Area Sources Agricultural Pesticide Application 4.84 1,159.60 Aircraft Refueling 0.11 38.46 Architectural Coating 2.63 735.95 Asphalt Paving 3.35 523.00 Automobile Refinishing 0.50 159.77 Commercial Cooking 0.15 55.10 0.06 20.62 Consumer Solvent Use 5.66 2,056.50 Dry Cleaning 0.31 81.43 Forest Fires 0.07 12.98 0.00 0.28 0.00 0.61 Fuel Combustion – Commercial/Institutional Natural Gas 0.01 271.77 0.17 281.53 0.02 16.62 Distillate Oil 0.02 5.88 0.02 28.46 0.00 0.41 Residual Oil 0.00 0.04 0.00 0.45 0.00 0.01 Kerosene 0.00 0.13 0.00 1.45 0.00 0.02 LPG 0.00 1.32 0.03 9.75 0.00 0.21 Fuel Combustion – Industrial Natural Gas 0.01 338.07 0.02 377.28 0.00 17.66 Distillate Oil 0.00 1.01 0.01 4.06 0.00 0.03 Residual Oil 0.00 0.17 0.00 2.05 0.00 0.01 Coal 0.00 0.00 0.00 0.00 0.00 0.00 Fuel Combustion – Residential Natural Gas 0.16 379.96 0.84 892.92 0.04 52.24 Distillate Oil 0.01 2.53 0.02 9.09 0.00 0.35 Kerosene 0.00 1.27 0.00 4.60 0.00 0.19 LPG 0.02 27.70 0.10 112.54 0.00 4.32 Coal 0.00 18.62 0.00 0.62 0.00 0.68 Wood Fireplaces 0.00 2,162.33 0.00 46.31 0.00 4,665.92 Wood Stoves 0.00 2,954.65 0.00 35.84 0.00 664.93 Gasoline Marketing Stage I 0.51 144.41 Stage II 2.68 898.88

59 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Tank Truck Leaks 0.13 35.72 Storage Tank Breathing 0.04 11.27 Graphic Arts 1.29 335.47 Incineration 0.64 233.22 0.20 71.34 0.13 46.04 Industrial Surface Coating 2.41 627.24 Marine Vessel Loading and Transport 0.65 202.80 Open Burning Prescribed Burning 0.00 67.80 0.00 1.45 0.00 3.19 Residential Household Waste 0.02 9.61 0.00 0.68 0.01 3.40 Yard Waste 0.00 16.97 0.00 3.16 Pavement Markings 0.29 42.70 Portable Fuel Containers Commercial 0.19 46.30 Residential 1.64 411.46 Solvent Cleaning 1.36 423.85 Structure Fires 0.30 21.31 0.00 0.49 0.06 3.90 Waste Water Treatment POTWs 0.59 217.42 Industrial 0.35 130.92 Area Source Totals 1.41 6,582.45 1.40 1,881.19 29.85 13,787.68 On-road Mobile Sources HDDV 4.64 1,908.91 24.44 7,905.99 0.92 369.75 HDGV 13.61 5,320.93 3.26 1,101.28 0.96 407.01 LDDT 0.01 15.89 0.02 17.14 0.00 9.19 LDDV 0.00 9.20 0.00 8.19 0.00 3.95 LDGT12 94.70 42,161.21 6.84 2,846.45 7.11 2,540.33 LDGT34 41.15 17,209.10 2.87 1,224.80 3.40 1,218.27 LDGV 125.22 52,561.02 9.56 3,823.54 10.97 3,816.40 MC 1.68 556.98 0.08 55.99 0.21 81.10 On-road Mobile Source Totals 281.01 119,743.24 47.07 16,983.38 23.57 8,445.99

60 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Off-road Mobile Sources Agricultural Equipment 2-stroke 0.02 4.64 0.00 0.00 0.00 2.67 4-stroke 4.88 763.09 0.00 17.49 0.06 27.16 Diesel 4.72 757.75 8.29 1,310.65 0.93 158.23 Aircraft APUs 0.00 0.00 0.00 0.00 0.00 0.00 Air Taxi 0.22 63.21 0.01 4.22 0.03 10.44 Commercial 0.03 0.61 0.03 0.61 0.01 0.11 General Aviation 2.48 877.49 0.02 6.75 0.09 32.77 Military 0.61 320.52 0.15 80.13 0.16 88.55 Airport Ground Support Equipment 2-stroke 0.00 0.00 0.00 0.00 0.00 0.00 4-stroke 0.03 18.87 0.00 1.10 0.00 0.76 Diesel 0.01 9.14 0.04 19.70 0.00 1.68 Commercial Equipment 2-stroke 0.19 60.60 0.00 0.21 0.10 33.85 4-stroke 15.51 4,721.50 0.12 92.53 0.39 156.45 Diesel 0.11 66.35 0.26 98.11 0.00 17.75 Construction Equipment 2-stroke 0.40 78.04 0.00 0.67 0.20 36.69 4-stroke 3.06 586.48 0.00 8.07 0.00 16.54 Diesel 2.22 460.94 4.43 854.67 0.35 94.44 Construction and Mining Equipment 2-stroke 0.00 0.00 0.00 0.00 0.00 0.00 4-stroke 0.02 13.16 0.00 3.28 0.00 0.79 Diesel 0.00 0.81 0.00 0.00 0.00 0.00 Industrial Equipment 2-stroke 0.00 0.81 0.00 0.00 0.00 0.44 4-stroke 8.81 2,319.60 1.46 416.87 0.43 127.96 Diesel 0.28 93.24 0.67 204.82 0.03 22.45

61 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Lawn and Garden Equipment 2-stroke 4.82 1,300.50 0.00 5.80 2.79 740.68 4-stroke 80.65 12,338.38 0.76 192.26 2.52 544.70 Diesel 0.18 36.69 0.36 65.60 0.04 10.78 Locomotives 0.36 131.20 3.24 1,183.09 0.14 49.64 Logging Equipment 2-stroke 0.00 0.00 0.00 0.00 0.00 0.00 4-stroke 0.00 0.00 0.00 0.00 0.00 0.00 Diesel 0.00 0.00 0.00 0.00 0.00 0.00 Marine Vessels Commercial 3.16 646.56 16.77 3,432.73 0.38 77.17 Recreational 2-stroke 3.64 638.00 0.04 6.60 1.83 320.80 4-stroke 0.61 107.40 0.02 3.50 0.06 10.00 Diesel 0.00 0.70 0.02 3.60 0.00 0.10 Railroad Equipment 2-stroke 0.00 0.00 0.00 0.00 0.00 0.00 4-stroke 0.02 11.54 0.00 0.18 0.00 0.29 Diesel 0.00 6.05 0.02 7.07 0.00 1.37 Recreational Equipment 2-stroke 1.13 291.10 0.00 2.06 1.26 324.71 4-stroke 10.77 2,711.76 0.08 25.58 0.25 68.32 Diesel 0.00 2.80 0.00 2.08 0.00 0.66 Underground Mining Equipment 2-stroke 0.00 0.00 0.00 0.00 0.00 0.00 4-stroke 0.00 0.00 0.00 0.00 0.00 0.00 Diesel 0.00 0.00 0.00 0.00 0.00 0.00 Off-road Mobile Source Totals 148.94 29,438.72 36.78 8,050.03 12.04 2,978.95

62 Table B-1: Metro-East NAA Emissions (continued)

Category CO CO NOx NOx VOM VOM (tpd) (tpy) (tpd) (tpy) (tpd) (tpy) Biogenic Sources 16.56 3,214.65 4.95 1,207.20 135.62 24,741.85 Totals Point Source 66.21 18,493.16 54.24 12,057.17 17.47 4,775.20 Area Source 1.41 6,582.45 1.40 1,881.19 29.85 13,787.68 On-road Mobile 281.01 119,743.24 47.07 16,983.38 23.57 8,445.99 Off-road Mobile 148.94 29,438.72 36.78 8,050.03 12.04 2,978.95 Biogenic 16.56 3,214.65 4.95 1,207.20 135.62 24,741.85 Total 514.13 177,472.22 144.45 40,178.97 218.55 54,729.68

63

Appendix C

Summary of VOM RACT Implementation in Illinois

64

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rule.

CTG Source CTG/ACT Reference CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Document Date Coatings and Solvents Graphic Arts Control of Volatile Organic Applies to graphic arts operations that use 35 Ill. Admn. Code, Part August 16, 1991 September 27, 1993 Emissions from Existing the flexographic and rotogravure printing 219, Subpart H: Printing Stationary Sources, Volume processes as applied to both publication and Publishing, (Sections VIII: Graphic Arts – and packaging printing. 219.401-219.404) Rotogravure and Flexography (EPA-450/2-78-033, 12/78, NTIS PB 292-490). Offset Lithographic Printing Applies to graphic arts operations that use 35 Ill. Admn. Code, Part August 16, 1991 May 15, 2006 (EPA-453 R-94-054). the offset lithographic printing process. 219, Subpart H: Printing and Publishing (Sections 219.405-219.411)

Metal Furniture, Control of Volatile Organic Applies to surface coating of metal 35 Ill. Admn. Code, Part August 16, 1991 May 15, 2006 Surface Coating of Emissions from Existing furniture by metal furniture manufacturers. 219, Subpart F: Coating Stationary Sources, Volume III: Operations, Section Surface Coating of Metal 219.204(g) Furniture (EPA-450/277-032, 12/77, NTIS PB-278-257)

65

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Document Date Coatings and Solvents Metal Parts and Control of Volatile Organic Applies to industries that are not covered 35 Ill. Admin. Code, Part August 16, 1991 May 15, 2006 Products, Surface Emissions from Existing by specific CTG documents (Specific 219, Subpart F: Coating Coating of Stationary Sources, Volume VI: CTGs have been published for can, coil, Operations, Section Miscellaneous Surface Coating of automobile and light duty truck, metal 219.204(j) Miscellaneous Metal Parts and furniture, magnet wire, and large Products appliances). (EPA-450/2-78-015, 6/78, NTIS PB-286-157).

Solvent Metal Control of Volatile Organic Applies to cold cleaners, open top vapor 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Cleaning Emissions from Solvent Metal degreasers, and conveyorized degreasers 219, Subpart E: Solvent Cleaning (EPA-450/2-77-022, which use volatile solvents to clean metal Cleaning, Sections 11/77, NTIS PB-274-557). parts 219.181-1219.84

Wood Furniture Control of VOM Emissions from Applies to any facility that finishes wood 35 Ill. Admin. Code, Part August 16, 1991 May 15, 2006 Manufacturing Wood Furniture Manufacturing furniture, or performs cleaning or wash 219, Subpart F: Coating Operations (EPA-453/R-96-007, off associated with wood furniture Operations, Section 4/96, NTIS PB-96-178-769). finishing operations. 219.204(l)

66

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Coatings and Solvents AutoTransport— AutoTransport—Business Applies to surface coating of plastics used 35 Ill. Admin. Code, Part August 16, 1991 May 15, 2006 Business Machine Machine Plastic (EPA 453 R-94- in motor vehicles and business machines. 219, Subpart F: Coating Plastic Coatings 017). Operations, Section 219.204(n)

Cans, Coils, Paper, Control of Volatile Organic Applies to surface coatings for protection 35 Ill. Admin. Code, Part August 16, 1991 May 15, 2006 Fabrics, Emissions from Existing and decoration of cans, coils, paper, 219, Subpart F: Coating Automobiles, and Stationary Sources – Volume II: fabrics, automobiles, and light duty Operations, Sections Light Duty Trucks, Surface Coating of Cans, Coils, trucks. 219.204(a), (b), (c), (d), Surface Coating of Paper, Fabrics, Automobiles, and and (e) Light-Duty Trucks (EPA-450/2- 77-008, 5/77, NTIS PB-272-445).

67

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Coatings and Solvents Ink and Paint Control of VOM from Ink and Applies to products of the paint 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Manufacturing Paint Manufacturing (EPA 453 3- manufacturing industry, including 219, Subpart AA: Paint 92-013). architectural coatings, product coating for and Ink Manufacturing, original equipment manufacturers, and Sections 219.204(a), (b), special-purpose coatings. Also applies to (c), (d), and (e) ink manufacturing, including letterpress inks, lithographic and offset inks, gravure inks, and flexographic inks.

Large Appliances, Control of Volatile Organic Applies to the coating of large appliances, 35 Ill. Admin. Code, August 16, 1991 May 15, 2006 Surface Coating of Emissions from Existing such as doors, cases, lids, panels, and Section 219.204(h) Stationary Sources, Volume V: interior support parts of residential and Surface Coating of Large commercial washers, dryers, ranges, Appliances (EPA-450/2-77-034, refrigerators, freezers, water heaters, dish NTIS PB-278-259). washers, trash compactors, air conditioners, and similar products.

68

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Coatings and Solvents Magnet Wire, Control of Volatile Organic Applies to wire coating curing ovens. 35 Ill. Admin. Code, August 16, 1991 May 15, 2006 Surface Coating for Emissions from Existing Section 219.204(i) Insulation of Stationary Sources, Volume IV: Surface Coating of Insulation of Magnet Wire (EPA- 450/2-77-033, 12/77, NTIS PB-278-258), CTG. Petroleum Bulk Gasoline Control of Volatile Applies to bulk plants with daily 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Plants Organic Emissions from throughputs of 76,000 liters (20,077 gal.) 219, Subpart Y: Gasoline Bulk Gasoline Plants gasoline or less. Distribution, Section (EPA-450/2-77-035, 219.581 12/77, NTIS PB-276- 722), CTG.

External Floating Control of Volatile Applies to external floating roof 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Roof Tanks, Organic Emissions from tanks larger than 150,000 liters 219, Subpart B: Organic Petroleum Liquid Petroleum Liquid (~40,000 gal. Or 950 bbls.) storing Emissions from Storage Storage in Storage in External petroleum liquids. and Loading Operations, Floating Roof Tanks Section 219.122 (EPA-450-2/78-047, 12/78, NTIS PB-290- 579), CTG.

69

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Petroleum External Floating Volatile Organic Liquid Storage in Applies to storage tanks in all industries, 35 Ill. Admin. Code, August 16, 1991 September 27, 1993 Roof Tanks, Floating and Fixed Roof Tanks but primarily in the petroleum refineries, Section 219.124 Petroleum Liquid (EPA 453 R-94-00). pipelines, chemical plants, liquid Storage in terminals.

Fixed Roof Tanks, Control of Volatile Organic Applies to storage vessels with capacities 35 Ill. Admin. Code, August 16, 1991 November 15, 1994 Storage of Emissions from Storage of greater than 150,000 liters containing Section 219.121 Petroleum Liquids Petroleum Liquids in Fixed Roof petroleum liquids with a true vapor in Tanks (EPA-450/2-77-036, 12/77, pressure greater than 10.5 KPa. Exempts NTIS PB-276-749) fixed roof tanks with capacities less than 1,600,000 liters used to store produced Organic Liquid Storage crude or condensate prior to lease custody (EPA 453 R-94-00). transfer.

Refinery Vacuum Control of Refinery Applies to non-condensables from 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Producing Systems, Vacuum Producing vacuum producing systems, wastewater 219, Subpart R: Wastewater Systems, Wastewater separators, and all pressurized process Petroleum Refining and Separators, and Separators, and Process Unit units. Related Industries; Process Unit Turnarounds (EPA-450/2-77-025, Asphalt Materials, Turnarounds 10/77, NTIS PB-275 662). Sections 219.442-219.444

70

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Petroleum Gasoline Stage II Gasoline Applies to gasoline dispensing into motor 35 Ill. Admin. Code, Part August 16, 1991 (repealed) Dispensing Stage II Dispensing Facilities vehicles at gasoline dispensing facilities. 219, Subpart Y: Gasoline Vapor Recovery (EPA 450 3-91-022a). Distribution, Section 586

Gasoline Service Design Criteria for Applies to filling of gasoline storage 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Stations Stage I Vapor Control Systems – tanks from gasoline tanker trucks. 219, Subpart Y: Gasoline Gasoline Service Stations, (11/75), Distribution, Section CTG. 219.584

Organic Liquid Volatile Organic Liquid Applies to storage tanks in all industries, 35 Ill. Admin. Code, Part August 16, 1991 November 15, 1994 Storage Storage in Floating and but primarily in the petroleum refineries, 219, Subpart B: Organic Fixed Roof Tanks (EPA 453 R-94- pipelines, chemical plants, and liquid Emissions from Storage 001). terminals. and Loading Operations, Section 219.120: Control Requirements for Storage Containers of VOL

71

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Petroleum Tank Trucks, Control of Applies to tank truck terminals with daily 35 Ill. Admin. Code, Part August 16, 1991 September 27, 1993 Gasoline Loading Hydrocarbons from throughputs greater than 76,000 liters 219, Subpart Y: Gasoline Terminals Tank Truck Gasoline (20,077 gal.). Distribution, Section Loading Terminals (EPA-450/2- 219.582: Bulk Gasoline 77-026, 12/77, NTIS PB-275-060); Terminals 10/77.

Tank Trucks, Control of VOM Leaks from Applies to gasoline tank trucks that are 35 Ill. Admin. Code, August 16, 1991 September 27, 1993 Gasoline, and Gasoline Tank Trucks and Vapor equipped with vapor collection systems Section 219.584:Gasoline Vapor Collection Collection Systems and the vapor collection systems at bulk Delivery Vessels Systems (EPA-450/2-78-051, 12/78, NTIS terminals, bulk plants and service PB-290-568). stations.

Stationary Source NOx Electric Utility NOx Utility Boilers Applies to electric utility boilers. 35 Ill. Admin. Code, Part April 14, 1972 April 17, 2001 Boilers (EPA 453 R- 94-023). 219, Subpart V: Electric Power Generation

72

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Category Date Stationary Source NOx Industrial Industrial Commercial Applies to boilers used in industrial, 35 Ill. Admin. Code, Part N/A: Applies only to N/A: Applies only to Commercial Boilers commercial, and institutional facilities. 217, Subpart U: NOx large sources that are large sources that are Boilers (EPA 453 R-94-022). Control and Trading greater than 250 mm greater than 250 mm Program for Specified BTU/hour, but for BTU/hour, but for NOx Generating Units sources smaller than sources smaller than 250 mm BTU, the 250 mm BTU, the RACT Proposal in the RACT Proposal in the development process development process

Stationary Gas Stationary Gas Turbines (EPA 453 Applies to stationary gas turbines. 35 Ill. Admin. Code, Part N/A: This rule applies N/A: Turbines R-93-007). 217, Subpart U: NOx only to large sources This rule applies only Control and Trading that are greater than 250 to large sources that are Program for Specified mm BTU/hour, but for greater than 250 mm NOx Generating Units sources smaller than BTU/hour, but for 250 mm BTU, the sources smaller than RACT Proposal in the 250 mm BTU, the development process RACT Proposal in the development process

73

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Date Last Amended Stationary Source NOx Stationary Stationary Reciprocating Applies to stationary 35 Ill. Admin. Code, N/A: Currently in the N/A: Currently in the Reciprocating IC Engines reciprocating internal proposed Part 217, development process to development process to Internal (EPA 453 R-93-032). combustion engines. Subpart Q: Stationary comply with U.S. EPA comply with U.S. EPA Combustion Reciprocating Internal CTG/ACT requirements CTG/ACT Engines Combustion Engines and requirements Turbines

Cement Cement Manufacturing Applies to the kilns used in 35 Ill. Admin. Code, Part March 15, 2001 March 15, 2001 Manufacturing (EPA 453 R-94-004). cement manufacturing. 217, Subpart T: Cement Kilns

Glass Glass Manufacturing Applies to glass manufacturing Currently in the process N/A N/A Manufacturing (EPA 453 R-94-037). processes. of developing regulations

Iron and Steel Iron and Steel Mills Applies to iron and steel Currently in the process N/A N/A (EPA 453 R-94-065). manufacturing processes. of developing regulations

74

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Date Last Amended Stationary Source NOx Nitric and Adipic Nitric and Adipic Acid Applies to nitric and adipic acid 35 Ill. Admin. Code, Part April 13, 1972 April 17, 2001 Acid Manufacturing Manufacturing Plants (EPA 450 3- manufacturing operations. 217, Subpart O, Section Plants 91-026). 217.381: Nitric Acid Manufacturing Processes

Other Cutback Asphalt Control of VOM from Applies to use of cutback asphalt 35 Ill. Admin. Code, Part August 16, 1991 May 15, 2006 Use of Cutback Asphalt used for roadway paving. 219, Subpart X, Section (EPA-450/2- 77-037, NTIS PB 278- 219.563: Cutback Asphalt 185).

Large Petroleum Control of VOM Applies to petroleum solvent dry 35 Ill. Admin. Code, Part August 16, 1991 (repealed) Dry Cleaners Emissions from Large cleaning facilities that consume 219, Subpart Z: Dry Petroleum Dry Cleaners (EPA-450/3- 123,000 liters or more of Cleaners, Section 82-009, 9/82, NTIS PB-83-124-875). petroleum solvent per year. 219.607: Standards for Petroleum Solvent Dry Cleaners

75

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Date Other Perchloroethylene Control of Volatile Applies to all dry cleaning systems 35 Ill. Admin. Code, August 16, 1991 (repealed) Dry Cleaning Organic Emissions from that use perchlorethylene. Subtitle B, Chapter Systems Perchloroethylene Dry Section 219.601: Cleaning Systems Perchloroethylene (EPA-450/2-78-050, 12/78, NTIS Dry Cleaners PB-290-13).

Synthetic Organic Control of VOM Emissions from Air Applies to synthetic organic chemical 35 Ill. Admin. Code, August 16, 1991 October 28, 1996 Chemical Oxidation Processes in Synthetic manufacturing operations. Part 219, Subpart Manufacturing Organic Chemical Manufacturing Q: Leaks from Industry (EPA-450/3-84-015, Synthetic Organic 12/84, NTIS PB-85-164 275). Chemical and Polymer Control of VOM Emissions from Manufacturing Plant Reactor Processes and Distillation Operations in SOCMI (EPA-450/4-91-031, 11/15/93, NTIS PB-92-180-009).

76

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Date Other Air Oxidation Air Oxidation Processes Applies to air oxidation processes 35 Ill. Admin. August 16, 1991 November 15, 1994 Processes in in SOCMI used in the synthetic organic Code, 219, SOCMI (EPA 450 3-84-015 VOM). chemical manufacturing industry. Subpart V: Air Oxidation Processes

Batch Processes Batch Processes Applies to processes used in 35 Ill. Admin. August 16, 1991 May 22, 1995 (EPA 453 R-93 017). producing plastic materials and Code, Part 219, resins, pharmaceuticals, gum and Subpart V: Batch wood chemicals, cyclic crudes and Operations and Air intermediates, industrial organic Oxidation chemicals, and agricultural Processes chemicals.

Commercial Bakery Oven Emissions Applies to commercial bakery 35 Ill. Admin. August 16, 1991 (repealed) Bakeries (EPA 453 R-92-017). operations. Code, Part 219, Subpart FF: Bakery Ovens

77

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Date Other Pharmaceutical Control of Volatile Applies to facilities and operations 35 Ill. Admin. August 16, 1991 September 27,1993 Products Organic Emissions from Manufacture that synthesize pharmaceutical Code, Part 219, of Synthesized Pharmaceutical products. Subpart T: Products (EPA-450/2-78-029, 1278, Pharmaceutical NTIS PB-290-580). Manufacturing

Pneumatic Rubber Control of Volatile Organic Emissions Applies to manufacturing processes; 35 Ill. Admin. September 27, 1993 October 21, 1993 Tires, Manufacture of from Manufacture of undertread cementing, tread-end CodePart 219, Pneumatic Rubber Tires (EPA-450/2- cementing, bead dipping, and green Subpart S: Rubber 78-030, 12/78, NTIS PB-290-557). tire spraying. and Miscellaneous Plastic Products, Section 219.461

78

Table C-1: Source Categories, CTG/ACT List, and Applicable Illinois Rules, cont’d

CTG Source Category CTG/ACT Reference Document CTG/ACT Applicability Illinois Rule Original Effective Date Last Amended Date Other Polyester Resin Control of VOM Emissions from Applies to the manufacturing of 35 Ill. Admin. September 27, 1993 October 21, 1993 Manufacture of High Density high-density polyethylene, CodePart 219, Polyethylene, Polypropylene, and polypropylene, and polystyrene. Subpart BB: Polystyrene Resins (EPA-450/3-83- Polystyrene Plants 008, 11/83, NTIS PB-84-134-600). Applies to emissions from equipment used in synthetic organic chemical Control of VOM Emissions from polymers and resins. Synthetic Organic Chemical Polymer and Resin Manufacturing Equipment Applies to polystyrene foam (EPA-450/3-83-006, 3/84, NTIS PB- manufacturing. 84-189-372).

Polystyrene Foam Manufacturing (EPA 450 3-90-020).

Synthetic Organic Control of VOM Applies to leaks of process fluids 35 Ill. Admin. August 16, 1991 September 27, 1993 Chemical and Fugitive Emissions from Synthetic (gaseous or liquid) from plant CodePart 219, Polymer Organic equipment such as pumps, Subpart Q, Section Manufacturing Chemical Polymer and compressors, in-line process valves, 219.428: Open Equipment, Resin Manufacturing pressure relief devices, open-ended Ended Valves Equipment Leaks Equipment (EPA-450/3-83-006, 3/84, valves, sampling connections, from NTIS PB-84-189-372). flanges, agitators, and cooling towers.

79

Table C-2 – Source Categories and CTG/ACT List for Which There Are No Applicable Illinois Rules

CTG Source CTG/ACT Reference Metro East CTG/ACT Applicability Category Document Sources? Coatings and Solvents Automobile Refinishing Automobile Refinishing (EPA 450 3-88-009). Applies to automobile refinishing operations which do not No involve an auto body shop.

Shipbuilding Shipbuilding and Ship Repair Operations (Surface Coating) (61 FR Applies to coatings and solvents used for building or maintaining No 44050, 8/27/96). metal marine or fresh-water metal hulled vessel used for military or commercial operations, including self-propelled vessels and those towed by other craft (barges). This definition includes, but is not limited to, all military vessels, commercial cargo and passenger (cruise) ships, ferries, barges, tankers, container ships, patrol and pilot boats, and dredges. Surface Coating Operations at Shipbuilding and Ship Repair Applies to any marine or fresh-water metal hulled vessel used for No Facilities (EPA-453/R-94-032, 4/94, NTIS PB-94-181-864). military or commercial operations, including self-propelled vessels and those towed by other craft. This definition includes, but is not limited to, all military vessels, commercial cargo and passenger ships, ferries, barges, tankers, container ships, patrol and pilot boats, and dredges. Pleasure craft, such as recreational boats and yachts, are not included.

80

Table C-2 – Source Categories and CTG/ACT List for Which There Are No Applicable Illinois Rules – cont’d

CTG Source CTG/ACT Reference CTG/ACT Applicability Metro East Category Document Sources? Coatings and Solvents Flat Wood Paneling, Control of Volatile Organic Emissions from Existing Stationary Applies to interior paneling made of wood products. No Surface Coating of Sources, Volume VII: Factory Surface of Flat Wood Paneling (EPA-450/2-78-032, 6/78, NTIS PB 286-199).

Petroleum Natural Gas/Gasoline Control of VOM Equipment Leaks from Natural Gas/Gasoline Applies to facilities engaged in the separation of natural gas liquids No Processing Plants, Processing Plants (EPA-450/2-83-007, 12/83, NTIS PB-84-161- from field gas and/or fraction of the liquids into natural gas Equipment Leaks from 520), CTG products, such as ethane, propane, butane and natural gasoline. It is not applicable to compressor stations, dehydration units, sweetening units, field treatment, underground storage facilities, liquefied natural gas units and field gas gathering systems unless they are located at a gas plant.

Other Agricultural Pesticides Control of VOM from the Application of Agricultural Pesticides Applies to pesticides used for agricultural purposes. No (EPA 453R-92-011).

Fuel Switching Fuel Switching to Meet RACT for NOx (EPA Memorandum, July Applies to switching to a cleaner burning fuel during ozone season. No 30, 1993).

Plywood Veneer Dryers Control Techniques for Organic Emissions from Plywood Veneer Applies to softwood plywood manufacturing operations. No Dryers (EPA 450 3-83-012 VOM).

81

Table C-3: Metro East Sources >= 100 Tons/Year Potential to Emit NOx or VOM

Source ID Source Name type county name NOX VOM

119010AAE Alton Steel Inc POTC Madison 4293.49938

119020AAE Dynegy Midwest Generation Inc POTC Madison 48327.68185 362.135867

119020AAG Olin Corp POTC Madison 518.240652 402.251478

119040AAC ASF-Keystone Inc POTC Madison 473.906984 770.079108

119040ADM Precoat Metals POTC Madison 136.30145

119040ATC Midwest Metal Coatings LLC POTC Madison 159.566466

119050AAA Premcor Refining Group Inc POTC Madison 2057.962542 2260.562656

119050AAK Conoco Phillips Hartford Lubricant Plant POTC Madison 1954.375072

119050AAN Conoco Phillips Co POTC Madison 118.92576

119055AAD Highland Electric Light Plant POTC Madison 3701.339088 528.8412

119090AAA ConocoPhillips Co POTC Madison 26683.85135 9411.17959

119090AAI Roxana Resource Recovery LLC POTC Madison 111.384

119105AAA Union Electric Co POTC Madison 11294.03542 162.255786

119115AAY BP Products North America Inc POTC Madison 220.213686

119801AAA Explorer Pipeline Co POTC Madison 951.734064

82 Source ID Source Name type county name NOX VOM

119813AAC Dynegy Midwest Generation Inc POTC Madison 3358.6716 275.502

119813AAI US Steel Granite City POTC Madison 11354.34097 1206.10277

119818AAA CenterPoint Energy POTC Madison 212.19348

133030AAO Waterloo City Light Plant POTC Monroe 2352.86398 120.7128

163010AEY Belleville Shoe Mfg. Co POTC St. Clair 268.1874

163020AAB Conoco Phillips Pipe Line Co POTC St. Clair 68253.54 760.272157

163045ADT Elementis Pigments Inc POTC St. Clair 888.24888

163045AFM Nuplex Resins LLC POTC St. Clair 104.580741

163050AAD Milam Recycling and Disposal Facility POTC St. Clair 155.58816

163060AAF Village of Freeburg POTC St. Clair 4041.2946 396.7404

163080AAC Mascoutah Power Plant POTC St. Clair 538.853232

163121AAB Afton Chemical Corporation POTC St. Clair 1339.957864

163121AAC Solutia Inc POTC St. Clair 1183.059505

163121AAM Cerro Flow Products Inc POTC St. Clair 253.8648 522.422229

163121AAU Joint American Bottoms & Sauget Trt Fac POTC St. Clair 241.270414

163121AAY Environmental Management Corp POTC St. Clair 250.098576

83 Source ID Source Name type county name NOX VOM

163806AAA Hexacomb Corporation POTC St. Clair 105.443202

84 Table C-4: Details of Metro East Sources Potentially Emitting >=100 tons per year

county id number name category Rule NOX VOM Madison 119010AAE Alton Steel Inc 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119010AAE Alton Steel Inc 102-Residual Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119010AAE Alton Steel Inc 303-Steel BART NOX VOM Madison 119010AAE Alton Steel Inc 390-Distillate BART or CD NOX VOM Madison 119010AAE Alton Steel Inc 390-Natural Gas BART or CD NOX VOM Madison 119010AAE Alton Steel Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM CAIR and Subpart V, Part 219: Electric Power Madison 119020AAE Dynegy Midwest Generation Inc 101-Coal Generation NOX VOM CAIR and Subpart V, Part 219: Electric Power Madison 119020AAE Dynegy Midwest Generation Inc 101-Natural Gas Generation NOX VOM Madison 119020AAE Dynegy Midwest Generation Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119020AAE Dynegy Midwest Generation Inc 403-zzzFugitives Subpart B: Sec. 219.123 VOM Madison 119020AAG Olin Corp 102-Distillate Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119020AAG Olin Corp 103-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119020AAG Olin Corp 103-xxxOther Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119020AAG Olin Corp 301-xxxOther BART NOX Madison 119020AAG Olin Corp 304-Copper BART NOX VOM Madison 119020AAG Olin Corp 304-Lead BART NOX VOM Madison 119020AAG Olin Corp 304-xxxOther BART NOX VOM Madison 119020AAG Olin Corp 304-yyyFuel Comb BART NOX VOM Madison 119020AAG Olin Corp 309-xxxOther BART or CD NOX VOM Madison 119020AAG Olin Corp 390-Coal BART or CD NOX VOM Madison 119020AAG Olin Corp 390-Natural Gas BART or CD NOX VOM Madison 119020AAG Olin Corp 399-Misc. Mfg BART or CD VOM Madison 119020AAG Olin Corp 402-Misc. Metal Subpart F: Sec. 219.204 VOM Madison 119020AAG Olin Corp 402-Paper Subpart F: Sec. 219.204 VOM Madison 119020AAG Olin Corp 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119020AAG Olin Corp 503-Incineration n/a NOX VOM Madison 119040AAC ASF-Keystone Inc 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119040AAC ASF-Keystone Inc 103-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119040AAC ASF-Keystone Inc 303-Ferroalloy BART VOM Madison 119040AAC ASF-Keystone Inc 303-Iron BART VOM Madison 119040AAC ASF-Keystone Inc 303-Steel BART NOX VOM

85 county id number name category Rule NOX VOM Madison 119040AAC ASF-Keystone Inc 304-Gray Iron BART NOX VOM Madison 119040AAC ASF-Keystone Inc 304-Steel BART NOX VOM Madison 119040AAC ASF-Keystone Inc 304-xxxOther BART VOM Madison 119040AAC ASF-Keystone Inc 390-Natural Gas BART or CD NOX VOM Madison 119040AAC ASF-Keystone Inc 402-xxxOther Subpart F: Sec. 219.204 VOM Madison 119040ADM Precoat Metals 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119040ADM Precoat Metals 203-Distillate Section 217, Subpart Q in process NOX Madison 119040ADM Precoat Metals 402-Metal Coils Subpart F: Sec. 219.204 NOX VOM Madison 119040ADM Precoat Metals 402-Ovens n/a NOX VOM Madison 119040ADM Precoat Metals 402-yyyFuel Comb n/a NOX VOM Madison 119040ATC Midwest Metal Coatings LLC 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119040ATC Midwest Metal Coatings LLC 402-Metal Coils Subpart F: Sec. 219.204 VOM Madison 119040ATC Midwest Metal Coatings LLC 402-Misc. Metal Subpart F: Sec. 219.204 VOM Madison 119040ATC Midwest Metal Coatings LLC 402-Ovens n/a NOX VOM Madison 119040ATC Midwest Metal Coatings LLC 402-xxxOther Subpart F: Sec. 219.204 VOM Madison 119040ATC Midwest Metal Coatings LLC 402-yyyFuel Comb n/a NOX VOM Madison 119050AAA Premcor Refining Group Inc 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX Madison 119050AAA Premcor Refining Group Inc 102-Residual Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119050AAA Premcor Refining Group Inc 102-xxxOther Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119050AAA Premcor Refining Group Inc 103-xxxOther Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119050AAA Premcor Refining Group Inc 305-Bulk Materials Subpart Y, Sections 219.581-219.582 VOM 306-Cooling Madison 119050AAA Premcor Refining Group Inc Towers BART or CD VOM Madison 119050AAA Premcor Refining Group Inc 306-FCCU BART or CD NOX VOM 306-Process Madison 119050AAA Premcor Refining Group Inc Heaters BART or CD NOX VOM Madison 119050AAA Premcor Refining Group Inc 306-Waste Water Subpart R, Sections 219.442-219.444 VOM Madison 119050AAA Premcor Refining Group Inc 306-xxxOther BART or CD NOX VOM Madison 119050AAA Premcor Refining Group Inc 306-zzzFugitives BART or CD VOM Madison 119050AAA Premcor Refining Group Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119050AAA Premcor Refining Group Inc 403-Floating Roof Subpart B: Sec. 219.123 VOM Madison 119050AAA Premcor Refining Group Inc 403-Floating Roof Subpart B: Sec. 219.124 VOM Madison 119050AAA Premcor Refining Group Inc 403-zzzFugitives Subpart B: Sec. 219.123 VOM Madison 119050AAA Premcor Refining Group Inc 406-Stage I Subpart Y: Sec 219.5xx VOM

86 county id number name category Rule NOX VOM Madison 119050AAA Premcor Refining Group Inc 406-Tank Cars Subpart Y: Sec 219.5xx VOM Madison 119050AAA Premcor Refining Group Inc 406-Transportation Subpart Y: Sec 219.5xx VOM Madison 119050AAA Premcor Refining Group Inc 406-zzzFugitives Subpart Y: Sec 219.5xx VOM Madison 119050AAA Premcor Refining Group Inc 407-Fixed Roof Subpart B: Sec 219.123 VOM Madison 119050AAA Premcor Refining Group Inc 490-xxxOther Subpart B: Sec 219.1xx VOM Madison 119050AAA Premcor Refining Group Inc 504-Soil Venting Section 219, Subpart G VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 102-Distillate Subpart K, Part 217: Process Emission Sources NOX VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 306-Waste Water Subpart R, Sections 219.442-219.444 VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 306-xxxOther BART or CD VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 403-Fixed Roof Subpart B: Sec. 219.123 VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 403-zzzFugitives Subpart B: Sec. 219.123 VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 404-Floating Roof Subpart Y: Sec 219.583 VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 406-Tank Cars Subpart Y: Sec 219.5xx NOX VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 406-zzzFugitives Subpart Y: Sec 219.5xx VOM Conoco Phillips Hartford Lubricant Madison 119050AAK Plant 407-Pressure Subpart B: Sec 219.123 VOM Madison 119050AAN Conoco Phillips Co 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119055AAD Highland Electric Light Plant 201-Distillate Section 217, Subpart Q in process NOX VOM Madison 119055AAD Highland Electric Light Plant 201-Natural Gas Section 217, Subpart Q in process NOX VOM Madison 119055AAD Highland Electric Light Plant 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119090AAA ConocoPhillips Co 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Madison 119090AAA ConocoPhillips Co 102-xxxOther Subpart K, Part 217: Process Emission Sources NOX VOM 306-Cooling Madison 119090AAA ConocoPhillips Co Towers BART or CD VOM Madison 119090AAA ConocoPhillips Co 306-FCCU BART or CD NOX VOM Madison 119090AAA ConocoPhillips Co 306-Flares BART or CD NOX VOM 306-Process Madison 119090AAA ConocoPhillips Co Heaters BART or CD NOX VOM

87 county id number name category Rule NOX VOM Madison 119090AAA ConocoPhillips Co 306-Waste Water Subpart R, Sections 219.442-219.444 NOX VOM Madison 119090AAA ConocoPhillips Co 306-zzzFugitives BART or CD VOM Madison 119090AAA ConocoPhillips Co 385 BART or CD VOM Madison 119090AAA ConocoPhillips Co 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119090AAA ConocoPhillips Co 403-Floating Roof Subpart B: Sec. 219.123 VOM Madison 119090AAA ConocoPhillips Co 403-Floating Roof Subpart B: Sec. 219.124 VOM Madison 119090AAA ConocoPhillips Co 403-zzzFugitives Subpart B: Sec. 219.123 VOM Madison 119090AAA ConocoPhillips Co 406-Stage I Subpart Y: Sec 219.5xx VOM Madison 119090AAA ConocoPhillips Co 406-Tank Cars Subpart Y: Sec 219.5xx VOM Madison 119090AAA ConocoPhillips Co 406-Transportation Subpart Y: Sec 219.5xx VOM Madison 119090AAA ConocoPhillips Co 406-zzzFugitives Subpart Y: Sec 219.5xx VOM Madison 119090AAI Roxana Resource Recovery LLC 201-Landfill Gas Section 217, Subpart Q in process NOX VOM CAIR and Subpart V, Part 219: Electric Power Madison 119105AAA Union Electric Co 101-Natural Gas Generation NOX VOM Madison 119105AAA Union Electric Co 201-Natural Gas Section 217, Subpart Q in process NOX VOM Madison 119105AAA Union Electric Co 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119115AAY BP Products North America Inc 306-Waste Water Subpart R, Sections 219.442-219.444 VOM Madison 119115AAY BP Products North America Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119115AAY BP Products North America Inc 403-Floating Roof Subpart B: Sec. 219.123 VOM Madison 119115AAY BP Products North America Inc 403-Floating Roof Subpart B: Sec. 219.124 VOM Madison 119115AAY BP Products North America Inc 404-Fixed Roof Subpart Y: Sec 219.583 VOM Madison 119115AAY BP Products North America Inc 404-Floating Roof Subpart Y: Sec 219.583 VOM Madison 119115AAY BP Products North America Inc 404-Losses Subpart Y: Sec 219.583 VOM Madison 119115AAY BP Products North America Inc 406-Tank Cars Subpart Y: Sec 219.5xx VOM Madison 119115AAY BP Products North America Inc 406-zzzFugitives Subpart Y: Sec 219.5xx VOM Madison 119115AAY BP Products North America Inc 407-Fixed Roof Subpart B: Sec 219.123 VOM Madison 119115AAY BP Products North America Inc 503-xxxOther n/a VOM Madison 119801AAA Explorer Pipeline Co 404-Fixed Roof Subpart Y: Sec 219.583 VOM Madison 119801AAA Explorer Pipeline Co 404-Floating Roof Subpart Y: Sec 219.583 VOM Madison 119813AAC Dynegy Midwest Generation Inc 201-Natural Gas Section 217, Subpart Q in process NOX VOM Madison 119813AAI US Steel Granite City 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX Madison 119813AAI US Steel Granite City 102-xxxOther Subpart K, Part 217: Process Emission Sources NOX VOM 303-By-product Madison 119813AAI US Steel Granite City Coke BART NOX VOM

88 county id number name category Rule NOX VOM Madison 119813AAI US Steel Granite City 303-Iron BART NOX VOM Madison 119813AAI US Steel Granite City 303-Steel BART NOX VOM Madison 119813AAI US Steel Granite City 304-xxxOther BART VOM Madison 119813AAI US Steel Granite City 390-Natural Gas BART or CD NOX VOM Madison 119813AAI US Steel Granite City 390-xxxOther BART or CD NOX VOM Madison 119813AAI US Steel Granite City 399-yyyFuel Comb BART or CD NOX VOM Madison 119813AAI US Steel Granite City 403-Fixed Roof Subpart B: Sec. 219.123 VOM Madison 119813AAI US Steel Granite City 406-Tank Cars Subpart Y: Sec 219.5xx VOM Madison 119813AAI US Steel Granite City 503-xxxOther n/a VOM Madison 119818AAA CenterPoint Energy 202-Natural Gas Section 217, Subpart Q in process NOX VOM Madison 119818AAA CenterPoint Energy 403-Floating Roof Subpart B: Sec. 219.123 VOM Madison 119818AAA CenterPoint Energy 403-Floating Roof Subpart B: Sec. 219.124 VOM Monroe 133030AAO Waterloo City Light Plant 201-Distillate Section 217, Subpart Q in process NOX VOM Monroe 133030AAO Waterloo City Light Plant 201-Natural Gas Section 217, Subpart Q in process NOX VOM Monroe 133030AAO Waterloo City Light Plant 202-Diesel Section 217, Subpart Q in process NOX VOM Monroe 133030AAO Waterloo City Light Plant 202-Natural Gas Section 217, Subpart Q in process NOX VOM Monroe 133030AAO Waterloo City Light Plant 203-Distillate Section 217, Subpart Q in process NOX VOM St. Clair 163010AEY Belleville Shoe Mfg. Co 320 BART or CD VOM 306-Process St. Clair 163020AAB Conoco Phillips Pipe Line Co Heaters BART or CD NOX St. Clair 163020AAB Conoco Phillips Pipe Line Co 390-xxxOther BART or CD NOX VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 401-zzzFugitives Subpart E: Sec. 219.183, 184 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 403-Fixed Roof Subpart B: Sec. 219.123 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 403-Floating Roof Subpart B: Sec. 219.123 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 403-Floating Roof Subpart B: Sec. 219.124 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 403-zzzFugitives Subpart B: Sec. 219.123 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 404-Fixed Roof Subpart Y: Sec 219.583 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 404-Floating Roof Subpart Y: Sec 219.583 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 404-Losses Subpart Y: Sec 219.583 VOM St. Clair 163020AAB Conoco Phillips Pipe Line Co 504-Soil Venting Section 219, Subpart G VOM St. Clair 163045ADT Elementis Pigments Inc 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM St. Clair 163045AFM Nuplex Resins LLC 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM Subpart B, Section 219.121: Storage Containers of St. Clair 163045AFM Nuplex Resins LLC 301-Fixed Roof VPL VOM

89 county id number name category Rule NOX VOM St. Clair 163045AFM Nuplex Resins LLC 301-Plastics BART VOM St. Clair 163050AAD Milam Recycling and Disposal Facility 202-xxxOther Section 217, Subpart Q in process NOX VOM St. Clair 163050AAD Milam Recycling and Disposal Facility 390-xxxOther BART or CD NOX VOM St. Clair 163050AAD Milam Recycling and Disposal Facility 501-Landfill n/a NOX VOM St. Clair 163060AAF Village of Freeburg 201-Distillate Section 217, Subpart Q in process NOX VOM St. Clair 163060AAF Village of Freeburg 202-Diesel Section 217, Subpart Q in process NOX VOM St. Clair 163080AAC Mascoutah Power Plant 201-Distillate Section 217, Subpart Q in process NOX VOM St. Clair 163080AAC Mascoutah Power Plant 201-Natural Gas Section 217, Subpart Q in process NOX VOM St. Clair 163121AAB Afton Chemical Corporation 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM St. Clair 163121AAB Afton Chemical Corporation 103-Natural Gas Subpart K, Part 217: Process Emission Sources NOX Subpart B, Section 219.121: Storage Containers of St. Clair 163121AAB Afton Chemical Corporation 301-Fixed Roof VPL VOM St. Clair 163121AAB Afton Chemical Corporation 301-xxxOther BART VOM 306-Cooling St. Clair 163121AAB Afton Chemical Corporation Towers BART or CD VOM St. Clair 163121AAB Afton Chemical Corporation 402-zzzFugitives Subpart F: Sec. 219.2xx VOM St. Clair 163121AAB Afton Chemical Corporation 403-Fixed Roof Subpart B: Sec. 219.123 VOM St. Clair 163121AAB Afton Chemical Corporation 407-Fixed Roof Subpart B: Sec 219.123 VOM St. Clair 163121AAC Solutia Inc 288-xxxOther Section 217, Subpart Q in process NOX VOM St. Clair 163121AAC Solutia Inc 301-xxxOther BART NOX VOM St. Clair 163121AAC Solutia Inc 301-zzzFugitives BART VOM St. Clair 163121AAC Solutia Inc 309-xxxOther BART or CD VOM St. Clair 163121AAC Solutia Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM St. Clair 163121AAC Solutia Inc 407-Fixed Roof Subpart B: Sec 219.123 NOX VOM St. Clair 163121AAM Cerro Flow Products Inc 102-Natural Gas Subpart K, Part 217: Process Emission Sources NOX VOM St. Clair 163121AAM Cerro Flow Products Inc 303-yyyFuel Comb BART NOX VOM St. Clair 163121AAM Cerro Flow Products Inc 304-Copper BART NOX VOM St. Clair 163121AAM Cerro Flow Products Inc 304-yyyFuel Comb BART NOX VOM St. Clair 163121AAM Cerro Flow Products Inc 401-Degreasing Subpart E: Sec. 219.183, 184 VOM St. Clair 163121AAM Cerro Flow Products Inc 402-Magnet Wire Subpart F: Sec. 219.204 VOM St. Clair 163121AAM Cerro Flow Products Inc 403-Fixed Roof Subpart B: Sec. 219.123 VOM St. Clair 163121AAM Cerro Flow Products Inc 407-Fixed Roof Subpart B: Sec 219.123 VOM Joint American Bottoms & Sauget Trt St. Clair 163121AAU Fac 407-Fixed Roof Subpart B: Sec 219.123 VOM

90 county id number name category Rule NOX VOM Joint American Bottoms & Sauget Trt St. Clair 163121AAU Fac 504-xxxOther n/a VOM St. Clair 163121AAY Environmental Management Corp 103-Distillate Subpart K, Part 217: Process Emission Sources NOX St. Clair 163121AAY Environmental Management Corp 103-Natural Gas Subpart K, Part 217: Process Emission Sources NOX St. Clair 163806AAA Hexacomb Corporation 307-Pulpboard Section 219, Subpart F VOM St. Clair 163806AAA Hexacomb Corporation 307-xxxOther Subpart F, Section 219.204a-e, 219.204l VOM St. Clair 163806AAA Hexacomb Corporation 402-Adhesives Subpart F: Sec. 219.204 VOM St. Clair 163806AAA Hexacomb Corporation 402-Ovens n/a NOX VOM

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