December 2011 Issue             800-252-3998
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 Illinois Small Business  Environmental Assistance Program  
The Illinois Small Business Environmental Assistance Program (IL SBEAP) is a federally mandated program to assist small companies in understanding their environmental requirements and achieving compliance.  The program is located in the non-regulatory, business assistance agency, the Department of Commerce and Economic Opportunity to alleviate small business' fears in seeking assistance. Questions?  Call 800-252-3998
Illinois Small Business Environmental Assistance Newsletter
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In This Issue
Illinois Updates
Federal Updates
Training & Events
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Small Business Environmental Assistance Program
Illinois Dept. of Commerce
& Economic Opportunity
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Springfield, IL 62701
SBEAP Stacked
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   Registratin of Smaller Sources  (ROSS) Factsheet 

Illinois Updates 

Registration of Smaller Sources Rules Are Final


Rules for the Registration of Smaller Sources (ROSS) program, created under Public Act 097-0095, have been approved by the Illinois Pollution Control Board. The ROSS Program is believed to apply to more than 3000 permitted sources which combined produce less than 1% of the air pollution in the State of Illinois. The program is intended to simplify air regulatory requirements by requiring sources with lower emissions to register with the agency rather than acquiring an air permit. It is important to note that although the source may no longer be subject to permitting, the source must still comply with all applicable environmental requirements.


Permitted sources that reported emission levels on their Annual Emission Reports consistent with the ROSS eligibility criteria will be sent registration information directly regarding the ROSS program.


Under the program, sources meeting the following eligibility criteria must register with the Illinois EPA Bureau of Air:

  • Not required to get a Title V or Clean Air Permit Program (CAPP) permit
  • Not required to get a Federally Enforceable State Operating Permit (FESOP)
  • Not required to get a permit under the New Source Performance Standards (NSPS) or under the National Emission Standards for Hazardous Air Pollutants (NESHAP) or by USEPA.
  • Actual emissions from the source's emission units are less than the following limits for the prior calendar year*:
    • 5.0 Tons/yr of combined pollutants (particulate matter, carbon monoxide, nitrogen oxides, sulfur dioxide and volatile organic material)
    • 0.50 Tons/yr of combined Hazardous Air Pollutants (HAPs)
    • 0.05 Tons/yr of mercury air emissions
    • 0.05 Tons/yr of lead air emissions

* emission units that are exempt from the permitting requirements and can be found at 35 Ill. Adm. Code 201.146 or the publication "Does My Business Need An Air Pollution Control Permit?" are not included in actual emissions calculations.

  • If a new source, the sum of the anticipated estimated actual annual emissions from all non-exempt units associated with the source must meet the limits as stated above. If the source has been operating less than one calendar year, projected estimated emissions may be used for all of the remaining months in the prior calendar year.
  • Emission units or source is not subject to maximum achievable control technology under 40 CFR Part 61 or the NESHAP under 40 CFR Part 63 unless it is categorized as an area source
  • Emission units at the source are not used as thermal desorption systems pursuant to 35 Ill. Adm. Code 728 Table F or as an incinerator system.
  • The source is not subject to local siting review under Section 39.2 of the Act


If a source is ROSS eligible and has an existing state operating permit, ROSS registration and fee payment ($235) is required by the source's annual site fee payment date in state fiscal year 2013 (July1, 2012-June30, 2013). A source not holding a permit must register and pay fees no later than July 1, 2012 and a new source is required to register and pay fees at least 10 days before commencing construction or operation and may commence construction or operation 10 days after submittal to the Agency. The annual fee payment will serve as the owner or operator's verification that the source continues to meet the eligibility criteria each year.

Click Here for the final ROSS Rules.
Visit the Illinois Small Business Environmental Assistance Program (ILSBEAP)
website at for the ROSS Factsheet and additional guidance information as it becomes available. Questions regarding the ROSS Program can be directed to the ILSBEAP helpline at


2012 Dry Cleaner Compliance Workbooks


The 2012 Dry Cleaner Compliance Workbooks are currently being printed and will be shipped by the end of the year. If you have already called, faxed, or emailed your request you have been placed on the mailing list. If you have not yet ordered the 2012 workbook, please do so now to ensure you receive the new one by the end of the year!! You can call the Small Business Environmental Assistance Program helpline at 1-800-252-3998 or email us at to request your copy.  


You may use this workbook to keep records required by Rule for air program compliance. This workbook was designed for PERC dry cleaners, but it may satisfy the air recordkeeping requirements for Petroleum dry cleaners.


You can also view and print the calendar from our website at  


Changes in VOM Rules for the Nonattainment Areas Take Affect in 2012


Several changes to rules regulating Volatile Organic Materials (VOMs) emissions in the nonattainment areas take effect in 2012. The regulatory changes only impact stationary sources in the nonattainment areas including the Chicago area,

which is comprised of Cook, DuPage, Kane, Lake, McHenry and Will Counties and Aux Sable Township and Goose Lake Township in Grundy County and Oswego Township in Kendall County adopted under 35 Ill. Adm. Code Section 218, and the Metro East area, which is comprised of Madison, Monroe, and St. Clair Counties adopted under 35 Ill. Adm. Code Section 219. Some of these changes are briefly described below.


Recent changes were also made to the "Other Industrial Solvent Cleaning Operations" rules under 35 Ill. Adm. Code 218.187 and 219.187. The applicability requirements, record keeping and reporting requirements were revised and now includes the submission of a certification that is due January 1, 2012 (see 218.187/219.187 (e)(1)(A) for exempted sources and (e)(2)(A) for sources that have to comply).


Changes will also impact coating/painting operations that will need to meet more stringent VOM limitations for several categories starting in May of 2012. These categories are automobile and light duty trucks (see 218/219.204 (a)), miscellaneous metal parts and products coating (see 218/219.204(j), plastic parts coating for automotive/transportation and business machines (see 218/219.204(n) and (o), respectively). With the exception of the automobile and light duty trucks category, all must follow 218/219.204 (q).


In addition, fiberglass boat and applicable fiberglass boat part(s) manufacturers must comply with 218/219 Subpart II beginning May 1, 2012. These rules apply to the owners or operators of sources that manufacture hulls or decks of boats from fiberglass, or that build molds to make hulls or decks of boats from fiberglass, and that emit 15 lbs/day or more of VOM. The rule includes: VOM limitations, record keeping, reporting with certification submission by May 1, 2012, for all sources, including exempt sources (see 218/219.894).    


Starting May 1, 2012, miscellaneous adhesive application operations must comply with 218/219 Subpart JJ. The definition of miscellaneous adhesive application operations is "... a regularly occurring industrial process consisting of one or more adhesive applicators and any associated drying area and/or oven in which an adhesive is applied, dried, and/or cured." These regulations affect those sources that have total actual VOM emissions from all such operations, including related cleaning activities, that are equal or exceed 15 lb/day. The rule includes VOM emission limitations, control requirements, monitoring, record keeping and reporting requirements, including certification submission by May 1, 2012 for all such sources, including exempted sources (see 218/219.904).


New "Small Container Exemption" for Pleasure Craft Surface Coating Operations

The Pollution Control Board adopted amendments to the state air rules in Parts 218 and 219 on October 20, 2011. This rulemaking amended both rules to allow for a "small container exemption" to the volatile organic material (VOM) regulations for pleasure craft surface operations. These amendments resulted from comments in a prior VOM rulemaking, where the American Coatings Association requested that the Board allow for small repairs and touch ups in order as part of on going maintenance - in order to avoid using larger amounts of coatings at a later time. The full text of the adopted amendments can be found at:


Hearing to be Held Regarding IL Uniform Waste Hauler Program


The Pollution Control Board is scheduling hearings in a rulemaking that will repeal the Illinois Uniform Waste Hauler program. The IEPA proposed the amendments to the Board in order to comply with recent statutory changes that ended the Uniform Waste Hauler program in Illinois (PA 97-220). Lack of other participating states and a large overestimation in generated revenue for Illinois were the main reason given for ending the program. You can get more information about this rule and the scheduled hearings at: 


Electronics Disposal Ban Takes Effect Jan. 1


Beginning January 1, it will no longer be legal for individuals to dispose of unwanted electronics in their regular trash. Discarded electronics, including computers, monitors, electronic keyboards, scanners, fax machines and many other electronic devices, must now be taken to a registered recycler for proper management. It will be illegal for the consumer to dispose of them in the trash and it will be illegal for Illinois landfills to accept them.


The Illinois Electronic Products Recycling and Reuse Act, which took effect in 2008, required manufacturers to establish a recycling program for discarded and unwanted electric products, if they sell their products in Illinois. This newest phase will include individual citizens in the effort to keep electronics, which contain a variety of potentially toxic contaminants, out of the state's 48 active landfills.


A 2007 report showed that electronic products were the fastest growing portion of the solid waste stream. That year, three million tons of electronic products became obsolete, yet only 14 percent of those products were recycled.


During calendar year 2011, electronics manufacturers are being required to collect and recycle or refurbish more than 28 million pounds of products. The reuse of these products, including metals, plastics and glass, conserves natural resources and saves energy. The law requires manufacturers of 17 electronic products, including televisions, computers, monitors, printers, keyboards, and DVRs, to recycle their percentage of a statewide recycling goal. Manufacturers typically hire local recyclers to help them meet their goal.


The metals, which include gold, cadmium, lead and silver, if landfilled can threaten groundwater. When the metals are reused, it eliminates some of the need for mining for new supplies and can also be valuable resources when reclaimed.


The Illinois EPA maintains a web site at:, which explains requirements for individuals and for manufacturers, a list of registered collectors, as well as a complete listing of all electronic items included in the ban.








Federal Updates


Boiler & Incinerator Updates 


U.S.EPA proposed a reconsideration of National Emission Standards for Hazardous Air Pollutants (NESHAP) regulations for boilers/process heaters (major and area source) and regulations concerning commercial and industrial solid waste incinerators (CISWI) and definition of non-hazardous solid waste on December 2, 2011. The final rules were issued in March 2011, but were then stayed shortly after in May, with the exception of area source boilers.


The area source rule for boilers (40 CFR 63 Subpart JJJJJJ) was revised to extend the time frame for tune ups on seasonal boilers to once every five years in lieu of every other year. EPA is also proposing the creation of additional subcategories and require initial compliance tune-ups after two years instead of after the first year. For further information concerning this rule or how to comment, please view:  


On the major source boilers (40 CFR 63 Subpart DDDDD) there are proposed emission limits based on the type of fuel and type of boiler used; work practice standards have been added to replace some of the emission limits for dioxin, new limits for carbon monoxide and particulates based on fuel and boiler type, increased flexibility in compliance monitoring, and to continue allowing work practice standards instead of numeric emission limits for burning of clean gases. EPA is also proposing to remove the hydrogen sulfide fuel specifications from the rule. For further information concerning this rule or how to comment, please view: 

NSPS for Commercial Institutional Solid Waste Incinerators Update  

The proposed revision to the New Source Performance Standard (NSPS) and the Emissions Guideline for CISWI includes revising what units fall under the definition of CISWI, emission limits for dioxins and mercury, and revising some of the monitoring requirements.


EPA is also proposing targeted revisions to the final rule for the definition of solid waste which identified which non-hazardous secondary materials can be burned in boiler or solid waste incinerators. Following the release of that final rule, the regulated community had expressed concerns regarding the regulatory criteria for a non-hazardous secondary material to be considered a legitimate, non-waste fuel, and how to demonstrate compliance with those criteria. EPA has re-examined the final rule and is proposing the following clarifications and amendments:

  • Clarify that certain materials are already included within the scope of biomass, that is considered a traditional fuel under those regulations;
  • Include a process for an owner or operator of a facility to petition EPA for a determination, based on a balancing of the legitimacy criteria and such other relevant factors, that such non-hazardous secondary material is not considered a solid waste when used as a fuel;
  • Identify a number of secondary materials, including resinated wood products, as nonwastes when used as a fuel; and
  • Revise the legitimacy criteria to expressly allow the comparison of groups of contaminants and clarify that contaminant comparisons may be made for any traditional fuel for which a combustion unit is designed to burn.
    • Identifies which non-hazardous secondary materials are, or are not, solid wastes when burned in combustion units, such that:
      • Non-hazardous secondary materials considered solid wastes under RCRA would be subject to the section 129 CAA requirements.
      • Non-hazardous secondary materials not considered solid wastes under RCRA would be subject to the section 112 CAA requirements
For more information concerning CISWI and the definition changes or how to comment, please view:



New Federal Regulations Impact Wood Furniture Manufacturing Operations


New rules adopted by the United States Environmental Protection Agency (USEPA) affect businesses that produce a range of wood products including: wood kitchen cabinets, wood residential furniture, upholstered residential and office furniture, wood office furniture and fixtures, partitions, shelving, lockers and other wood furniture not included in one of the categories listed above. However, these regulations only include wood furniture manufacturing operations that occur at facilities that are major sources of hazardous air pollutants (HAP) - meaning they emit more than 10 tons per year of a single HAP or more than 25 tons per year of a combination of HAP. In the proposal for this rule making, the USEPA proposed a formaldehyde emissions limit of 400 pounds per 12-month period. Because the USEPA received comments concerning potential impacts on facilities with high production volume they determined that the proposed limit would not be cost effective for all facilities in the source category. For this reason, the final rules adopted by the USEPA contain two alternative compliance options. Facilities can either limit their formaldehyde emissions by limiting formaldehyde content in coatings and contact coatings and contact adhesives to 1 percent by weight or they have the option to comply with a formaldehyde usage limit of 400 pounds per rolling 12-month period. 


 The USEPA also modified the regulations on the types of spray guns used to apply coatings to wood furniture. They stated that conventional spray guns tend to emit more HAP (generally through overspray), so this rule requires that facilities that use conventional spray guns may do so only if the emissions from the finishing station are filtered through a control device. High efficiency spray guns may be used without the control device (filter).  


For more information on the wood furniture regulations please see:  



Training & Events 


Lead RRP Seminars Coming in February & March

The Illinois Department of Public Health and Illinois Small Business Environmental Assistance Program are planning to hold informational sessions around the state regarding the USEPA Lead Renovation, Repair and Paint Rule.  Check the IL Small Business Environmental website for updates at


The Staff of the Illinois Small Business Environmental Assistance Program Wish You and Your Loved Ones a Wonderful Holiday Season
& Best Wishes for the New Year



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