Illinois EPA Comment on the Proposed Approval of the Illinois VOC RACT rules

Thank you for the opportunity to comment on the United States Environmental Protection Agency’s (USEPA) proposed rule approving Illinois’ revisions to several of its volatile organic compound rules for Groups II, III, and IV Consumer and Commercial Products. (76 FR 74014, November 30, 2011). While the Illinois Environmental Protection Agency (IEPA) appreciates the USEPA’s approval of these rule revisions, the IEPA would like to bring USEPA’s attention to the following errors that appear in the proposed rule: 1. Page 74015, Section IV, Subsection (1): The title should reference Part 211 instead of Section 211. 2. Page 74015, Section IV, Subsection (3): The end of the first paragraph implies that Illinois’ surface coating regulations at 35 Ill. Adm. Code 218.208 and 219.208 allow an equivalent applicability threshold of 2.7 tons of VOM per 12 month rolling period. Illinois’ rules contain no such equivalent threshold. 3. Pages 74015-74016, Section IV, Subsections (3) and (5): In the titles, the second set of section references should be to Part 219, not 218. 4. Page 74016, Section IV, Subsection (6): In the title, Illinois’ regulations specific to fiberglass boat manufacturing materials are contained in 35 Ill. Adm. Code 218.890 to 894 and 219.890 to 894. Sections 895 to 899 are (unofficially) reserved, and Sections 900 to 904 regard miscellaneous industrial adhesives. Please see attached for complete detailed comments.