Title: Nissan Forklift Corp.; Marengo
Subject: Forklift Truck Assembly
Author: Robert Wayne Bernoteit
Last saved by: EPA
Company: IEPA
Category: Title V/CAAPP Permit

217/782-2113

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

PERMITTEE

Nissan Forklift Corp., NA
Attn.:  Andrew Scheele
240 North Prospect St.
Marengo, Illinois  60152

Application No.:  95110071			I.D. No.:  111065AAQ
Applicant’s Designation:			Date Received:  November 17, 1995
Operation of:  Forklift Truck Assembly Plant
Date Issued:  November 12, 1998			Expiration Date:  November 12, 2003
Source Location:  240 North Prospect, Marengo, McHenry County
Responsible Official:  Andrew Scheele, Manager Manufacturing Engineering

This permit is hereby granted to the above-designated Permittee to operate a Forklift Truck Assembly Plant, pursuant to the above referenced permit application.  This permit is subject to the conditions contained herein.

If you have any questions concerning this permit, please contact Robert Bernoteit at 217/782-2113.

Donald E. Sutton, P.E.
Manager, Permit Section
Division of Air Pollution Control

DES:RWB:psj

cc:	Illinois EPA, FOS, Region 1
USEPA

TABLE OF CONTENTS

| | | PAGE
1.0 | Source Identification | 4
| 1.1 | Source |
| 1.2 | Owner/Parent Company |
| 1.3 | Operator |
| 1.4 | General Source Description |
2.0 | List of Abbreviations/Acronyms Used in This Permit | 5
3.0 | Insignificant Activities | 7
| 3.1 | Identification of Insignificant Activities |
| 3.2 | Addition of Insignificant Activities |
4.0 | Significant Emission Units at This Source | 9
5.0 | Overall Source Conditions | 10
| 5.1 | Source Description |
| 5.2 | Applicable Regulations |
| 5.3 | Non-Applicability of Regulations of Concern |
| 5.4 | Source-Wide Operational and Production Limits and Work Practices |
| 5.5 | Source-Wide Emission Limitations |
| 5.6 | General Recordkeeping Requirements |
| 5.7 | General Reporting Requirements |
| 5.8 | General Operational Flexibility/ Anticipated Operating Scenarios |
| 5.9 | General Compliance Procedures |
6.0 | EMISSION REDUCTION MARKET SYSTEM (ERMS) | 15
| 6.1 | Description of ERMS |
| 6.2 | Applicability |
| 6.3 | Obligation to Hold Allotment Trading Units (ATUs) |
| 6.4 | Market Transaction |
| 6.5 | Emission Excursion Compensation |
| 6.6 | Quantification of Seasonal VOM Emissions |
| 6.7 | Annual Account Reporting |
| 6.8 | Allotment of ATUs to the Source |
| 6.9 | Recordkeeping for ERMS |
| 6.10 | Federal Enforceablility |
7.0 | Unit Specific Conditions | 21
| 7.1 | Units SPB2, 3, 5, & 6	Spray Paint Booths #2, 3, 5, & 6 Controls F2, 3, 5 & 6	Filters #2, 3, 5, & 6

| | | PAGE
| 7.2 | Unit PPL		Powder Paint Line Control PPLF	Powder Paint Line Filter
| 7.3 | Units GO, CO, DO	Powder Paint Line Parts Washers and Ovens
| 7.4 | Unit GHAF1 - 4	Gas Hot Air Furnaces #1, 2, 3, & 4
| 7.5 | Unit GT		Small Gasoline Storage Tank
8.0 | General Permit Conditions | 45
| 8.1 | Permit Shield |
| 8.2 | Applicability of Title IV Requirements |
| 8.3 | Emissions Trading Programs |
| 8.4 | Operational Flexibility/Anticipated Operating Scenarios |
| 8.5 | Testing Procedures |
| 8.6 | Reporting Requirements |
9.0 | Standard Permit Conditions | 49
| 9.1 | Effect of Permit |
| 9.2 | General Obligations of Permittee |
| 9.3 | Obligation to Allow Illinois EPA Surveillance |
| 9.4 | Obligation to Comply with Other Requirements |
| 9.5 | Liability |
| 9.6 | Recordkeeping |
| 9.7 | Annual Emissions Report |
| 9.8 | Requirement for Compliance Certification |
| 9.9 | Certification |
| 9.10 | Defense to Enforcement Actions |
| 9.11 | Permanent Shutdown |
| 9.12 | Reopening And Reissuing Permit For Cause |
| 9.13 | Severability Clause |
| 9.14 | Permit Expiration and Renewal |
10.0 | Attachments |
| 10.1 | Attachment 1 - Emissions of Particulate Matter from New Process Emission Units | 1-1
| 10.2 | Attachment 2 - Example Certification by a Responsible Official | 2-1

1.0	Source Identification

1.1	Source

Nissan Forklift Corp., NA
240 North Prospect
Marengo, Illinois  60152
815/568-0061

I.D. No.:  111065AAQ
Standard Industrial Classification:	3537, Trucks & Tractors - Industrial

1.2	Owner/Parent Company

Nissan Forklift Corp., NA
240 North Prospect St.
Marengo, Illinois  60152

1.3	Operator

Nissan Forklift Corp., NA
240 North Prospect Street
Marengo, Illinois  60152

Andrew Scheele
815/568-0061

1.4	General Source Description

Nissan Forklift corporation is located at 240 North Prospect Street in Marengo.  The source assembles electric and gas forklift trucks and manufactures structural steel components to produce such items as frames, platforms, and fork assemblies.  In addition, forklift trucks are painted on site.

2.0	List of Abbreviations/Acronyms Used in This Permit

ACMA | Alternative Compliance Market Account
Act | Environmental Protection Act [415 ILCS 5/1 et seq.]
AP-42 | Compilation of Air Pollution Emission Factors, Volume 1, Stationary Point and Other Sources (and Supplements A through F), USEPA, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27717
ASTM | American Society for Testing and Materials
ATU | Allotment Trading Unit
Btu | British thermal unit
CAA | Clean Air Act [42 U.S.C. Section 7401 et seq.]
CAAPP | Clean Air Act Permit Program
CFR | Code of Federal Regulations
CO | Carbon Monoxide
ERMS | Emission Reduction Market System
FIRE | Factor Information Retrieval System, Version 5.0, Source Classification Codes and Emission Factor Listing for Criteria Air Pollutants (EPA-454/R-95-012), USEPA, Office of Air Quality Planning and Standards, Research Triangle Park, NC 27717
gal | gallon
hr | hour
HAP | Hazardous Air Pollutants
IAC | Illinois Administrative Code
I.D. No. | Identification Number of Source, assigned by Illinois EPA
Illinois EPA | Illinois Environmental Protection Agency
kg | kilogram
kPa | kilopascal
l | liter
lb | pound
LEL | Lower Explosive Limit
m^3 | cubic meter
Mft^3 | Million cubic feet
Mg | Metric Tonnes or Megagrams
mmBtu | Million Btus
mo | month
MW | Megawatts
NESHAP | National Emission Standards for Hazardous Air Pollutants
NO_x | Nitrogen Oxides
NSPS | New Source Performance Standards

PM | Particulate Matter
PM_10 | Particulate matter with an aerodynamic diameter less than or equal to a nominal 10 microns as measured by applicable test or monitoring methods
ppm | parts per million
PSD | Prevention of Significant Deterioration
psi | pound per square inch
SCC | Source Classification Code
SIP | State Implementation Plan
SO_2 | Sulfur Dioxide
T | Ton
TANKS | USEPA Emission Estimating Program for Storage Tanks
TOC | Total Organic Compounds
USEPA | United States Environmental Protection Agency
VOL | Volatile Organic Liquid
VOM | Volatile Organic Material
VPL | Volatile Petroleum Liquid
Wt | Weight
yr | year

3.0	Insignificant Activities

3.1	Identification of Insignificant Activities

The following activities at the source constitute insignificant activities as specified in 35 IAC 201.210:

3.1.1	Activities determined by the Illinois EPA to be insignificant activities, pursuant to 35 IAC 201.210(a)(1) and 201.211, as follows:

Gas Driven Air Compressor

3.1.2	Activities that are insignificant activities based upon maximum emissions, pursuant to 35 IAC 201.210(a)(2) or (a)(3), as follows:

Welding Machines

3.1.3	Activities that are insignificant activities based upon their type or character, pursuant to 35 IAC 201.210(a)(4) through (18), as follows:

Direct combustion units designed and used for comfort heating purposes and fuel combustion emission units as follows:  (A) Units with a rated heat input capacity of less than 2.5 mmBtu/hr that fire only natural gas, propane, or liquefied petroleum gas; (B) Units with a rated heat input capacity of less than 1.0 mmBtu/hr that fire only oil or oil in combination with only natural gas, propane, or liquefied petroleum gas; and (C) Units with a rated heat input capacity of less than 200,000 Btu/hr which never burn refuse, or treated or chemically contaminated wood  [35 IAC 201.210(a)(4)].

Storage tanks of organic liquids with a capacity of less than 10,000 gallons and an annual throughput of less than 100,000 gallons per year, provided the storage tank is not used for the storage of gasoline or any material listed as a HAP pursuant to Section 112(b) of the CAA  [35 IAC 201.210(a)(10)].

Storage tanks of any size containing virgin or re-refined distillate oil, hydrocarbon condensate from natural gas pipeline or storage systems, lubricating oil, or residual fuel oils  [35 IAC 201.210(a)(11)].

3.1.4	Activities that are considered insignificant activities pursuant to 35 IAC 201.210(b).

3.2	Addition of Insignificant Activities

3.2.1	The Permittee is not required to notify the Illinois EPA of additional insignificant activities present at the source of a type that is identified in Condition 3.1, until the renewal application for this permit is submitted, pursuant to 35 IAC 201.212(a).

3.2.2	The Permittee must notify the Illinois EPA of any proposed addition of a new insignificant activity of a type addressed by 35 IAC 201.210(a)and 201.211 other than those identified in Condition 3.1, pursuant to Section 39.5(12)(b) of the Act.

3.2.3	The Permittee is not required to notify the Illinois EPA of additional insignificant activities present at the source of a type identified in 35 IAC 201.210(b).

4.0	Significant Emission Units at This Source

Emission
Unit

Description

Date
Constructed

Emission Control
Equipment

SPB2 | Binks Paint Spray Booth (Counterweight Spray Paint Booth #2) | Between 1988 and 1992 | Filter #2
SPB3 | Binks Paint Spray Booth (Frame Spray Paint Booth #3) | Between 1988 and 1992 | Filter #3
SPB5 | Binks Paint Spray Booth (Finish Spray Paint Booth #5) | Between 1988 and 1992 | Filter #5
SPB6 | Binks Paint Spray Booth (Prime Spray Paint Booth #6) | Between 1988 and 1992 | Filter #6
PPL | Nordson Powder Paint Spray Booth (Powder Paint Line) | June, 1997 | Filter
GO | 2 Therm-Tron-X Parts Washers (Powder Paint Line Parts Washers, Natural Gas-Fired, 2.0 mmBtu/hr, each) | June, 1997 | None
CO | Natural Gas-Fired Cure Oven (6.5 mmBtu/hr) | June, 1997 | None
DO | Natural Gas-Fired Dry Off Oven (4.4 mmBtu/hr) | June, 1997 | None
GHAF1 | Hartzell Model GR284 Make-up Air Furnace (Gas Hot Air Furnace #1, 2.9 mmBtu/hr) | 1991 | None
GHAF2 | Hartzell Model GR284 Make-up Air Furnace (Gas Hot Air Furnace #2, 2.9 mmBtu/hr) | 1991 | None
GHAF3 | Absolute Aire Make-up Air Furnace (Gas Hot Air Furnace #3, 4.9 mmBtu/hr) | August, 1995 | None
GHAF4 | Weather Rite Make-up Air Furnace (Gas Hot Air Furnace #4, 4.9 mmBtu/hr) | August, 1995 | None
GT | Small Gasoline Storage Tank (500 gallons) | Unknown | None

5.0	Overall Source Conditions

5.1	Source Description

5.1.1	This permit is issued based on the source requiring a CAAPP permit as a major source of VOM emissions.

5.1.2	This permit is issued based on the source not being a major source of HAPs.

5.2	Applicable Regulations

5.2.1	Specific emission units at this source are subject to particular regulations as set forth in Section 7 (Unit-Specific Conditions) of this permit.

5.2.2	In addition, emission units at this source are subject to the following regulations of general applicability:

a.	No person shall cause or allow the emission of fugitive particulate matter from any process, including any material handling or storage activity, that is visible by an observer looking generally overhead at a point beyond the property line of the source unless the wind speed is greater than 40.2 kilometers per hour (25 miles per hour), pursuant to 35 IAC 212.301 and 212.314.

Compliance with this requirement is considered to be assured by the inherent nature of operations at this source, as demonstrated by historical operation.

b.	The emission of smoke or other particulate matter from any emission unit shall not exceed an opacity of greater than 30 percent, except that an opacity of greater than 30 percent but less than 60 percent shall be allowed for a period or periods aggregating 8 minutes in any 60 minute period provided that such opaque emissions permitted during any 60 minute period shall occur from only one such emission unit located within a 305 meter (1000 feet) radius from the center point of any other such emission unit owned or operated by the Permittee, and provided further that such opaque emissions permitted from each such emission unit shall be limited to 3 times in any 24 hour period, pursuant to 35 IAC 212.123 and 212.124.

5.2.3	Operating Program for Particulate Matter

a.	This source shall be operated under the provisions of an operating program prepared by the Permittee and submitted to the Illinois EPA for its review.  Such operating program shall be designed to significantly reduce fugitive particulate matter emissions  [35 IAC 212.309(a)].

b.	The operating program shall be amended from time to time by the Permittee so that the operating program is current.  Such amendments shall be consistent with the requirements set forth by this Condition and shall be submitted to the Illinois EPA  [35 IAC 212.312].

c.	All normal traffic pattern roads and parking facilities located at this source shall be paved or treated with water, oils, or chemical dust suppressants.  All paved areas shall be cleaned on a regular basis.  All areas treated with water, oils, or chemical dust suppressants shall have the treatment applied on a regular basis, as needed, in accordance with the operating program [35 IAC 212.306].

d.	All unloading and transporting operations of materials collected by pollution control equipment shall be enclosed or shall utilize spraying, pelletizing, screw conveying or other equivalent methods [35 IAC 212.307].

5.2.4	The Permittee shall comply with the standards for recycling and emissions reduction of ozone depleting substances pursuant to 40 CFR Part 82, Subpart F, except as provided for motor vehicle air conditioners in Subpart B of 40 CFR Part 82:

a.	Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to 40 CFR 82.156.

b.	Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to 40 CFR 82.158.

c.	Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to 40 CFR 82.161.

5.3	Non-Applicability of Regulations of Concern

None

5.4	Source-Wide Operational and Production Limits and Work Practices

In addition to the source-wide requirements in the Standard Permit Conditions in Section 9, the Permittee shall fulfill the following source-wide operational and production limitations and/or work practice requirements:

None

5.5	Source-Wide Emission Limitations

5.5.1	Permitted Emissions for Fees

The annual emissions from the source, not considering insignificant activities as addressed by Section 3.0 of this permit, shall not exceed the following limitations.  The overall source emissions shall be determined by adding emissions from all emission units.  Compliance with these limits shall be determined on a calendar year basis.  These limitations (Condition 5.5.1) are set for the purpose of establishing fees and are not federally enforceable.

Permitted Emissions of Regulated Pollutants

Pollutant | Tons/Year
Nitrogen Oxides (NO_x) | 9
Particulate Matter (PM) | 3
Sulfur Dioxide (SO_2) | 1
Volatile Organic Material (VOM) | 11
HAP, not included in VOM or PM | --
TOTAL | 24

5.5.2	Emissions of Hazardous Air Pollutants

This permit is issued based on the emissions of HAPs as listed in Section 112(b) of the CAA not being equal to or exceeding 10 tons per year of a single HAP or 25 tons per year of any combination of such HAPs, so that this source is considered a minor source for HAPs.

5.5.3	Other Source-Wide Emission Limitations

Other source-wide emission limitations are not set for this source pursuant to either the federal rules for Prevention of Significant Deterioration (PSD), 40 CFR 52.21, Illinois EPA rules for Major Stationary Sources Construction and Modification, 35 IAC Part 203, or Section 502(b)(10) of the CAA.  However, there may be unit specific emission limitations set forth in Section 7 of this permit pursuant to these rules.

5.6	General Recordkeeping Requirements

5.6.1	Emission Records

The Permittee shall maintain records of the following items for the source to demonstrate compliance with Condition 5.5.1, pursuant to Section 39.5(7)(b) of the Act:

Total annual emissions on a calendar year basis for the emission units covered by Section 7 (Unit Specific Conditions) of this permit.

5.6.2	Records for Storage Vessels

Each storage vessel with a design capacity less than 40,000 gallons is subject to no provisions of 35 IAC Part 218 other than those required by maintaining readily accessible records of the dimensions of the storage vessel and analysis of the capacity of the storage vessel [35 IAC 218.129(f)].

5.6.3	Records for Natural Gas Usage

The Permittee shall maintain records of the following items for the units which combust natural gas so as to demonstrate compliance with Condition 5.5.1, pursuant to Section 39.5(7)(b) of the Act:

a.	Natural gas usage of the source, Mft^3/mo and Mft^3/yr; and

b.	Records of the monthly and annual aggregate NO_x, PM, SO_2, and VOM emissions from the combustion of natural gas at the source shall be maintained, based on fuel consumption and the applicable emission factors, with supporting calculations.

5.6.4	Retention and Availability of Records

a.	All records and logs required by this permit shall be retained for at least five years from the date of entry (unless a longer retention period is specified by the particular recordkeeping provision herein), shall be kept at a location at the source that is readily accessible to the Illinois EPA or USEPA, and shall be made available for inspection and copying by the Illinois EPA or USEPA upon request.

b.	The Permittee shall retrieve and print, on paper during normal source office hours, any records retained in an electronic format (e.g., computer) in response to an Illinois EPA or USEPA request for records during the course of a source inspection.

5.7	General Reporting Requirements

5.7.1	General Source-Wide Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance with the permit requirements as follows, pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken.

5.7.2	Annual Emissions Report

The annual emissions report required pursuant to Condition 9.7 shall contain emissions information for the previous calendar year.

5.8	General Operational Flexibility/Anticipated Operating Scenarios

N/A

5.9	General Compliance Procedures

5.9.1	General Procedures for Calculating Fuel Combustion Emissions

To determine compliance with Condition 5.5.1, emissions from the combustion of natural gas at the source shall be calculated based on the following emission factors:

Pollutant

Emission Factor
(lb/Mft^3)

NO_x | 100
PM | 11.9
SO_2 | 0.6
VOM | 2.8

These are the emission factors for uncontrolled natural gas combustion in commercial boilers (0.3 -< 10 mmBtu/hr), Tables 1.4-1, 1.4-2, and 1.4-3, AP-42, Volume I, Fifth Edition, October, 1996.  VOM emission factor based on TOC factor corrected for 52% methane contribution.

Natural Gas Fuel Combustion Emissions (lb) = (Natural Gas Consumed, Mft^3) x (The Appropriate Emission Factor, lb/Mft^3)

6.0	EMISSION REDUCTION MARKET SYSTEM (ERMS)

6.1	Description of ERMS

The ERMS is a “cap and trade” market system for major stationary sources located in the Chicago ozone nonattainment area.  It is designed to reduce VOM emissions from stationary sources to contribute to further reasonable progress toward attainment, as required by Section 182(c) of the Clean Air Act.

The ERMS addresses VOM emissions during a seasonal allotment period from May 1 through September 30.  Once the ERMS begins, participating sources must hold “allotment trading units” (ATUs) for their actual seasonal VOM emissions.  Each year participating sources are issued ATUs based on allotments set during initial issuance of the sources’ CAAPP permits.  These allotments are established from historical VOM emissions or “baseline emissions” lowered to provide the emission reduction from stationary sources required for further progress.

By December 31 of each year, the end of the reconciliation period following the seasonal allotment period, each source shall have sufficient ATUs in its account to cover its actual VOM emissions during the preceding season.  An account’s balance as of December 31 will include any valid ATU transfer agreements entered into as of December 31 of the given year, provided such agreements are promptly submitted to the Illinois EPA for entry into the account database.  The Illinois EPA will then retire ATUs in sources’ accounts in amounts equivalent to their seasonal emissions.  When a source does not appear to have sufficient ATUs in its account, the Illinois EPA will issue a notice to the source to begin the process for Emissions Excursion Compensation.

In addition to receiving ATUs pursuant to their allotments, participating sources may also obtain ATUs from the market, including ATUs bought from other participating sources and general participants in the ERMS that hold ATUs (35 IAC 205.630) and ATUs issued by the Illinois EPA as a consequence of VOM emission reductions from an Emission Reduction Generator or an Intersector Transaction (35 IAC 205.500 and 205.510).  During the reconciliation period, sources may also buy ATUs from a secondary reserve of ATUs managed by the Illinois EPA, the Alternative Compliance Market Account (35 IAC 205.710).  Sources may also transfer or sell the ATUs that they holds to other sources or participants [35 IAC 205.630].

6.2	Applicability

This source is considered a “participating source” for purposes of the ERMS, 35 IAC Part 205.

6.3	Obligation to Hold Allotment Trading Units (ATUs)

a.	Pursuant to 35 IAC 205.150(c)(1) and 205.720, and as further addressed by condtion 6.8, as of December 31 of each year, this source shall hold ATUs in its account in an amount not less than its VOM emissions during the preceding seasonal allotment period (May 1 - September 30) not including VOM emissions from the following, or the source shall be subject to “emissions excursion compensation,” as described in Condition 6.4.

i.	VOM emissions from insignificant units and activities as identified in Section 3 of this permit, in accordance with 35 IAC 205.220;

ii.	Excess VOM emissions associated with startup, malfunction or breakdown of an emission unit as authorized elsewhere in this permit, in accordance with 35 IAC 205.225;

iii.	Excess VOM emissions to the extent allowed by a Variance, Consent Order, or Compliance Schedule, in accordance with 35 IAC 205.320(e)(3);

iv.	Excess VOM emissions that are a consequence of an emergency as approved by the Illinois EPA, pursuant to 35 IAC 205.750; and

v.	VOM emissions from certain new and modified emission units as addressed by Section 6.7(b), if applicable, in accordance with 35 IAC 205.320(f).

b.	Notwithstanding the above condition, in accordance with 35 IAC 205.150(c)(2), if a source commences operation of a major modification, pursuant to 35 IAC Part 203, the source shall hold ATUs in an amount not less than 1.3 times its VOM emissions attributable to such major modification during the seasonal allotment period, determined in accordance with the construction permit for such major modification or applicable provisions in Section 7.0 of this permit.

6.4	Market Transaction

a.	The source shall apply to the Illinois EPA for and obtain authorization for a Transaction Account prior to conducting any market transactions, as specified at 35 IAC 205.610(a).

b.	The Permittee shall promptly submit to the Illinois EPA any revisions to the information submitted for its Transaction Account, pursuant to 35 IAC 205.610(b).

c.	The source shall have at least one account officer designated for its Transaction Account, pursuant to 35 IAC 205.620(a).

d.	Any transfer of ATUs to or from the source from another source or general participant must be authorized by a qualified Account Officer designated by the source and approved by the Illinois EPA in accordance with 35 IAC 205.620 and the transfer must be submitted to the Illinois EPA for entry into the Transaction Account database.

6.5	Emission Excursion Compensation

Pursuant to 35 IAC 205.720, if the source fails to hold ATUs in accordance with Condition 6.3, it shall provide emissions excursion compensation in accordance with the following:

a.	Upon receipt of an Excursion Compensation Notice issued by the Illinois EPA, the source shall purchase ATUs from the ACMA in the amount specified by notice, as follows:

i.	The purchase of ATUs shall be in an amount equivalent to 1.2 times the emissions excursion; or

ii.	If the source had an emissions excursion for the seasonal allotment period immediately before the period for the present emission excursion, the source shall purchase ATUs in an amount equivalent to 1.5 times the emissions excursion.

b.	If requested in accordance with paragraph (c) below or in the event that the ACMA balance is not adequate to cover the total emissions excursion amount, the Illinois EPA will deduct ATUs equivalent to the specified amount or any remaining portion thereof from the ATUs to be issued to the source for the next seasonal allotment period.

c.	Pursuant to 35 IAC 205.720(c), within 15 days of receipt of an Excursion Compensation Notice, the owner or operator may request that ATUs equivalent to the amount specified be deducted from the source’s next seasonal allotment by the Illinois EPA, rather than purchased from the ACMA.

6.6	Quantification of Seasonal VOM Emissions

a.	The methods and procedures specified in Section 5 and 7 of this permit for determining VOM emissions and compliance with VOM emission limitations shall be used for determining seasonal VOM emissions for purposes of the ERMS, with the following exceptions  [35 IAC 205.315(b)]:

No exceptions

b.	The Permittee shall report emergency conditions at the source to the Illinois EPA in accordance with 35 IAC 205.750, if the Permittee intends to deduct VOM emissions in excess of the technology-based emission rates normally achieved that are attributable to the emergency from the source’s seasonal VOM emissions for purposes of the ERMS.  These reports shall include the information specified by 35 IAC 205.650(a), and shall be submitted in accordance with the following:

i.	An initial emergency condition report within two days of the time when such excess emissions occurred due to the emergency; and

ii.	A final emergency condition report, if needed to supplement the initial report, within 10 days after the conclusion of the emergency.

6.7	Annual Account Reporting

a.	For each year in which the source is operational, the Permittee shall submit, as a component of its Annual Emission Report, seasonal VOM emission information to the Illinois EPA for the seasonal allotment period. This report shall include the following information  [35 IAC 205.300]:

i.	Actual seasonal emissions of VOM from the source;

ii.	A description of the methods and practices used to determine VOM emissions, as required by this permit, including any supporting documentation and calculations;

iii.	A detailed description of any monitoring methods that differ from the methods specified in this permit, as provided in Section 205.337 of this Subpart;

iv.	If a source has experienced an emergency, as provided in 35 IAC 205.750, the report shall reference the associated emergency conditions report that has been approved by the Agency;

v.	If a source’s baseline emissions have been adjusted due to a variance, consent order or CAAPP permit compliance schedule, as provided for in 35 IAC 205.320(e)(3), the report shall provide documentation quantifying the excess VOM emissions during the season that were allowed by the Variance, Consent Order, or Compliance Schedule, in accordance with 35 IAC 205.320(e)(3); and

vi.	If a source is operating a new or modified emission unit for which three years of operational data are not yet available, as specified in 35 IAC 205.320(f), the report shall specify seasonal VOM emissions attributable to the new emission unit or the modification of the emission unit.

b.	This report shall be submitted by October 31 of each year, for the preceding seasonal allotment period.

6.8	Allotment of ATUs to the Source

a.	i.	The allotment of ATUs to this source is 84 ATUs per seasonal allotment period.

ii.	This allotment of ATUs reflects the Illinois EPA’s determination that the source’s baseline emissions were 9.5133 tons.

This determination includes adjustment to actual emissions to account for non-compliance with requirements effective through 1996 that became applicable after the year selected as baseline year at the source, e.g., 35 IAC 218.204(j)(4)(A), pursuant to 35 IAC 205.320(e)(2) as further addressed in Section 7 of this permit.

iii.	The source’s allotment reflects 88% of the baseline emissions (12% reduction) except for the VOM emissions from specific emission unit excluded from such reduction, pursuant to 35 IAC 205.405 including units complying with MACT or using BAT, as identified in Section 7 of this permit.

iv.	ATUs will be issued to the source’s Transaction Account by the Illinois EPA annually.  These ATUs will be valid for the seasonal allotment period following issuance and, if not retired in this season, the next seasonal allotment period.

v.	Condition 6.3(a) becomes effective beginning in the seasonal allotment period following the initial issuance of ATUs by the Illinois EPA into the Transaction Account for the source.

b.	Contingent Allotments
(Pending construction)

There are no contingent allotments for this source.

c.	Notwithstanding the above, part or all of the above ATUs will not be issued to the source in circumstances as set forth in 35 IAC Part 205, including:

i.	Transfer of ATUs by the source to another participant or the ACMA, in accordance with 35 IAC 205.630;

ii.	Deduction of ATUs as a consequence of emission excursion compensation, in accordance with 35 IAC 205.720; and

iii.	Transfer of ATUs to the ACMA, as a consequence of shutdown of the source, in accordance with 35 IAC 205.410.

6.9	Recordkeeping for ERMS

The Permittee shall maintain copies of the following documents as its Compliance Master File for purposes of ERMS [35 IAC 205.700(a)]:

a.	Seasonal component of the Annual Emission Report;

b.	Information on actual VOM emissions, as specified in detail in Sections 5 and 7 of this permit and Condition 6.6(a); and

c.	Any transfer agreements for the purchase or sale of ATUs and other documentation associated with the transfer of ATUs.

6.10	Federal Enforceability

Section 6 becomes federally enforceable upon approval of the ERMS by USEPA as part of Illinois' State Implementation Plan.

7.0	Unit Specific Conditions

7.1	Units SPB2, 3, 5, & 6	Spray Paint Booths #2, 3, 5, & 6
Controls F2, 3, 5 & 6	Filters #2, 3, 5, & 6

7.1.1	Description

The source operates these solvent based paint spray booths to paint frames, guards, platforms, and other large structural components of forklift trucks.

7.1.2	List of Emission Units and Pollution Control Equipment

Emission
Unit

Description

Emission Control
Equipment

SPB2 | Binks Paint Spray Booth (Counterweight Spray Paint Booth #2) | Filter #2
SPB3 | Binks Paint Spray Booth (Frame Spray Paint Booth #3) | Filter #3
SPB5 | Binks Paint Spray Booth (Finish Spray Paint Booth #5) | Filter #5
SPB6 | Binks Paint Spray Booth (Prime Spray Paint Booth #6) | Filter #6

7.1.3	Applicability Provisions and Applicable Regulations

a.	Each Paint Spray Booth is an “affected coating line” for the purpose of these unit-specific conditions.

b.	Each affected coating line is subject to the emission limits identified in Condition 5.2.2.

c.	The affected coating lines are subject to 35 IAC 212.321(a), which provides that:

i.	No person shall cause or allow the emission of particulate matter into the atmosphere in any one hour period from any new process emission unit, either alone or in combination with the emission of particulate matter from all other similar process emission units for which construction or modification commenced on or after April 14, 1972, at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.321 (see also Attachment 1) [35 IAC 212.321(a)].

ii.	Because the expected process weight rate for each affected coating line is 100 pounds per hour, the allowable PM emission rate for each affected coating line set by 35 IAC 212.321 is 0.55 pounds per hour.

d.	Pursuant to 35 IAC 218.204, no owner or operator of a coating line shall apply at any time any coating in which the VOM content exceeds the following emission limitations for the specified coating.  The following emission limitations are expressed in units of VOM per volume of coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied at each coating applicator, except where noted.  Compounds which are specifically exempted from the definition of VOM should be treated as water for the purpose of calculating the "less water" part of the coating composition.  The emission limitations are as follows:

i.	Heavy Off-Highway Vehicle Products Coating/Extreme Performance Prime Coat [35 IAC 218.204(k)(1)]:

kg/l | lb/gal
0.42 | 3.5

ii.	Heavy Off-Highway Vehicle Products Coating/Extreme Performance Top-Coat (Air Dried) [35 IAC 218.204(k)(2)]:

kg/l | lb/gal
0.42 | 3.5

iii.	Heavy Off-Highway Vehicle Products Coating/Final Repair Coat (Air Dried) [35 IAC 218.204(k)(3)]:

kg/l | lb/gal
0.42 | 3.5

7.1.4	Non-Applicability of Regulations of Concern

a.	The affected coating line is not subject to the NSPS for Automobile and Light Duty Truck Surface Coating Operations, 40 CFR 60 Subpart MM because the affected coating line is not a prime coat operation, a guide coat operation, or a topcoat operation at an automobile or light-duty truck assembly plant.

b.	The affected coating lines are not subject to 35 IAC 212.324, Process Emission Units In Certain Areas, because the source is not located in a non-attainment area for PM_10, as identified in 35 IAC 212.324(a)(1).

c.	No owner or operator of a coating line subject to the limitations of 35 IAC 218.204 is required to meet the limitations of 35 IAC 218.301 or 218.302, Use of Organic Material, after the date by which the coating line is required to meet 35 IAC 218.204 [35 IAC 218.209].

7.1.5	Operational and Production Limits and Work Practices

The Permittee shall follow good operating practices for the paint booth filters, including periodic inspection, routine maintenance and prompt repair of defects.

7.1.6	Emission Limitations

In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected coating lines are subject to the following:

a.	Emissions and operation of the affected coating lines shall not exceed the following limits:

Coating Usage | Coating VOM Content | Cleaning Solvent Usage | VOM Emissions
gal/day | gal/yr | lb VOM/gal | lb/day | T/yr | lb/day | T/yr
70.80 | 5,280 | 3.5 | 21.24 | 0.76 | 269.04 | 10.00

These limits are based on the maximum coating usage, the maximum allowable content of the coating, the maximum cleaning solvent usage, and the maximum hours of operation.

b.	Compliance with annual limits shall be determined on a monthly basis from the sum of the data for the current month plus the preceding 11 months (running 12 month total).

c.	The above limitations were established based on a request by the Permittee in the CAAPP application.  These limits ensure that the construction and/or modification of the affected coating lines did not constitute a new major source or major modification pursuant to 35 IAC Part 203.

7.1.7	Testing Requirements

Testing for VOM content of coatings and other materials shall be performed as follows [35 IAC 218.105(a), 218.211(a), and Section 39.5(7)(b) of the Act]:

a.	On at least an annual basis:

i.	The VOM content of representative coatings "as applied" on the affected coating line shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a).

ii.	This testing may be performed by the supplier of a material provided that the supplier provides appropriate documentation for such testing to the Permittee and the Permittee's records pursuant to Condition 7.1.9(b) directly reflect the application of such material and separately account for any additions of solvent.

iii.	Upon written request from the Permittee, the Illinois EPA may waive this requirement on a year-by-year basis, if prior testing shows a margin of compliance and no significant changes in coating supplies have occurred.

b.	Upon reasonable request by the Illinois EPA, the VOM content of specific coatings and cleaning solvents used on the affected coating line shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a) [35 IAC 218.105(a) and 218.211(a)].

7.1.8	Monitoring Requirements

None

7.1.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for each affected coating line to demonstrate compliance with Conditions 5.5.1 and 7.1.3, pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the testing of VOM content of coatings and cleaning solvents pursuant to Condition 7.1.7, which include the following [Section 39.5(7)(e) of the Act]:

i.	Identification of material tested;

ii.	Results of analysis;

iii.	Documentation of analysis methodology; and

iv.	Person performing analysis.

b.	Pursuant to 35 IAC 218.211(c)(2), the Permittee shall collect and record all of the following information each day for the affected coating line and maintain the information at the source for a period of three years:

i.	The name and identification number of each coating as applied on the affected coating line; and

ii.	The weight of VOM per volume of each coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied each day on the affected coating line.

c.	Records addressing use of good operating practices for the paint booth filters:

i.	Records for periodic inspection of the paint booth filters with date, individual performing the inspection, and nature of inspection; and

ii.	Records for prompt repair of defects, with identification and description of defect, effect on emissions, date identified, date repaired, and nature of repair.

d.	Records of the coating usage for the affected coating line, gal/day, gal/mo, and gal/yr;

e.	The VOM content of coatings, % by Wt;

f.	Density of coatings, lb/gal;

g.	Records of the solvent usage for the affected coating line, gal/day, gal/mo, and gal/yr;

h.	Density of solvent, lb/gal; and

i.	The aggregate monthly and annual PM and VOM emissions from the affected coating line based on the material usage, with supporting calculations.

7.1.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected coating line with the permit requirements as follows, pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken:

a.	Pursuant to 35 IAC 218.211(c)(3)(A), the Permittee shall notify the Illinois EPA of any record showing violation of Condition 7.1.3(d) (see also 35 IAC 218.204) within 30 days following the occurrence of the violation.

b.	Continued operation of any affected coating line with a defect in the paint booth filters that may result in emissions of particulate matter in excess of limits in Condition 7.1.3(c) within 30 days of such an occurrence.

c.	Emissions of VOM in excess of limits in Condition 7.1.6 within 30 days of such an occurrence.

7.1.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.1.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.1.9 and the emission factors and formulas listed below:

a.	Compliance with Conditions 7.1.3(b) and (c) is assumed to be achieved by proper operation of the paint booth filters, as addressed by Condition 7.1.5.

b.	To determine compliance with Condition 5.5.1, PM and VOM emissions from the affected coating line shall be calculated based on the following:

i.	Particulate Matter Emissions:

PM (lb) = (Coating Usage, gal) x (Coating Density, lb/gal) x (Wt % Solids) x [1 - (Transfer Efficiency^* (%)/100)] x [1 - (Paint Booth Filter Efficiency^* (%)/100)]

^*As specified by manufacturer or vendor of the spray booths and paint booth filters

ii	Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, gal) x (Coating Density, lb/gal) x (VOM Content of Coating, % by Wt.) + (Cleaning Solvent Usage, gal) x (Solvent Density, lb/gal)

7.2	Unit PPL		Powder Paint Line
Control PPLF	Powder Paint Line Filter

7.2.1	Description

The source operates this powder paint spray booth to paint frames, guards, platforms, and other large structural components of forklift trucks.  The paint applied in this powder paint spray booth is cured in a natural gas-fired curing oven.

7.2.2	List of Emission Units and Pollution Control Equipment

Emission
Unit

Description

Emission Control
Equipment

PPL | Nordson Powder Paint Spray Booth (Powder Paint Line) | Filter

7.2.3	Applicability Provisions and Applicable Regulations

a.	The Powder Paint Line is an "affected coating line" for the purpose of these unit-specific conditions.

b.	The affected coating line is subject to the emission limits identified in Condition 5.2.2.

c.	The affected coating line is subject to 35 IAC 212.321(a), which provides that:

i.	No person shall cause or allow the emission of particulate matter into the atmosphere in any one hour period from any new process emission unit, either alone or in combination with the emission of particulate matter from all other similar process emission units for which construction or modification commenced on or after April 14, 1972, at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.321 (see also Attachment 1) [35 IAC 212.321(a)].

ii.	Because the expected process weight rate for the affected coating line is less than 100 pounds per hour, the allowable PM emission rate for the affected coating line set by 35 IAC 212.321 is 0.55 pounds per hour.

d.	No person shall cause or allow the emission of sulfur dioxide into the atmosphere from any process emission unit to exceed 2000 ppm, [35 IAC 214.301].

e.	Pursuant to 35 IAC 218.204, no owner or operator of a coating line shall apply at any time any coating in which the VOM content exceeds the following emission limitations for the specified coating.  The following emission limitations are expressed in units of VOM per volume of coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied at each coating applicator, except where noted.  Compounds which are specifically exempted from the definition of VOM should be treated as water for the purpose of calculating the "less water" part of the coating composition.  The emission limitations are as follows:

i.	Heavy Off-Highway Vehicle Products Coating/Extreme Performance Prime Coat [35 IAC 218.204(k)(1)]:

kg/l | lb/gal
0.42 | 3.5

ii.	Heavy Off-Highway Vehicle Products Coating/Extreme Performance Top-Coat (Air Dried) [35 IAC 218.204(k)(2)]:

kg/l | lb/gal
0.42 | 3.5

iii.	Heavy Off-Highway Vehicle Products Coating/Final Repair Coat (Air Dried) [35 IAC 218.204(k)(3)]:

kg/l | lb/gal
0.42 | 3.5

iv.	All other coatings are subject to the emission limitations for miscellaneous metal parts and products coating [35 IAC 218.204(k)(4)]:

A.	Miscellaneous Metal Parts and Products Coating/Extreme Performance Coating (Baked) [35 IAC 218.204(j)(2)(B)]:

kg/l | lb/gal
0.40 | 3.3

B.	Miscellaneous Metal Parts and Products Coating/All Other Coatings (Baked) [35 IAC 218.204(j)(4)(B)]:

kg/l | lb/gal
0.34 | 2.8

7.2.4	Non-Applicability of Regulations of Concern

a.	The affected coating line is not subject to the NSPS for Automobile and Light Duty Truck Surface Coating Operations, 40 CFR 60 Subpart MM because the affected coating line is not a prime coat operation, a guide coat operation, or a topcoat operation at an automobile or light-duty truck assembly plant.

b.	The curing oven on the affected coating line is not subject to 35 IAC 216.121, Emissions of Carbon Monoxide from Fuel Combustion Emission Units, because the actual heat input is less than 2.9 MW (10 mmBtu/hr) and the drying oven is not by definition a fuel combustion emission unit.

c.	The curing oven on the affected coating line is not subject to 35 IAC 217.121, Emissions of Nitrogen Oxides from New Fuel Combustion Emission Sources, because the actual heat input is less than 73.2 MW (250 mmBtu/hr) and the drying oven is not by definition a fuel combustion emission unit.

d.	The affected coating line is not subject to 35 IAC 212.324, Process Emission Units In Certain Areas, because the source is not located in a non-attainment area for PM_10, as identified in 35 IAC 212.324(a)(1).

e.	No owner or operator of a coating line subject to the limitations of 35 IAC 218.204 is required to meet the limitations of 35 IAC 218.301 or 218.302, Use of Organic Material, after the date by which the coating line is required to meet 35 IAC 218.204 [35 IAC 218.209].

7.2.5	Operational and Production Limits and Work Practices

a.	The affected coating line shall only be operated with coatings containing no organic materials or HAPs.

b.	The Permittee shall follow good operating practices for the dry filter system, including periodic inspection, routine maintenance and prompt repair of defects.

c.	The curing oven on the affected coating line shall only be operated with natural gas as the fuel.

7.2.6	Emission Limitations

In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected coating line is subject to the following:

a.	Emissions and operation of the powder paint booth shall not exceed the following limits:

Item of

Process
Rate

Operating
Hours

Particulate Matter
Emissions

Equipment | (lb/hr) | (hr/yr) | lb/hr | T/yr
Powder Paint Booth | 62.25 | 3,120 | 0.55 | 0.86

These limits are based on 35 IAC 212.321, the maximum powder coating usage, and the maximum hours of operation.  Compliance with annual limits shall be determined from a running total of 12 months of data.

b.	The above limitations contain revisions to previously issued construction permit 97050032.  The source has requested that the Illinois EPA establish conditions in this permit that allow various refinements from the conditions of this construction permit, consistent with the information provided in the CAAPP application.  The source has requested these revisions and has addressed the applicability and compliance of 40 CFR 52.21, Prevention of Significant Deterioration (PSD).  These limits continue to ensure that the construction and/or modification addressed in this construction permit does not constitute a new major source or major modification pursuant to these rules.  These limits supersede the limitations established in this construction permit and the information in the CAAPP application contains the most current and accurate information for the source.  Specifically, the limit on the hours of operation has been increased from 2,080 hours per year to 3,120 hours per year.

7.2.7	Testing Requirements

Testing for VOM content of coatings and other materials shall be performed as follows [35 IAC 218.105(a), 218.211(a), and Section 39.5(7)(b) of the Act]:

a.	On at least an annual basis:

i.	The VOM content of representative coatings "as applied" on the affected coating line shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a).

ii.	This testing may be performed by the supplier of a material provided that the supplier provides appropriate documentation for such testing to the Permittee and the Permittee's records pursuant to Condition 7.2.9(b) directly reflect the application of such material and separately account for any additions of solvent.

iii.	Upon written request from the Permittee, the Illinois EPA may waive this requirement on a year-by-year basis, if prior testing shows a margin of compliance and no significant changes in coating supplies have occurred.

b.	Upon reasonable request by the Illinois EPA, the VOM content of specific coatings and cleaning solvents used on the affected coating line shall be determined according to USEPA Reference Methods 24 and 24A of 40 CFR 60 Appendix A and the procedures of 35 IAC 218.105(a) [35 IAC 218.105(a) and 218.211(a)].

7.2.8	Monitoring Requirements

None

7.2.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected coating line to demonstrate compliance with Conditions 5.5.1, 7.2.3, and 7.2.6, pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the testing of VOM content of coatings and cleaning solvents pursuant to Condition 7.2.7, which include the following [Section 39.5(7)(e) of the Act]:

i.	Identification of material tested;

ii.	Results of analysis;

iii.	Documentation of analysis methodology; and

iv.	Person performing analysis.

b.	Pursuant to 35 IAC 218.211(c)(2), the Permittee shall collect and record all of the following information each day for the affected coating line and maintain the information at the source for a period of three years:

i.	The name and identification number of each coating as applied on each affected coating line; and

ii.	The weight of VOM per volume of each coating (minus water and any compounds which are specifically exempted from the definition of VOM) as applied each day on each affected coating line.

c.	Records addressing use of good operating practices for the dry filter system:

i.	Records for periodic inspection of the dry filter system with date, individual performing the inspection, and nature of inspection; and

ii.	Records for prompt repair of defects, with identification and description of defect, effect on emissions, date identified, date repaired, and nature of repair.

d.	Records of the coating usage for the affected coating line, lb/mo and lb/yr;

e.	The VOM content of coatings, % by Wt;

f.	The solvent usage for the affected coating line, gal/mo and gal/yr;

g.	Density of solvent, lb/gal;

h.	The operating schedule of the affected coating line, hr/mo and hr/yr; and

i.	The aggregate monthly and annual PM and VOM emissions from the affected coating line based on the material usage, with supporting calculations.

7.2.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected coating line with the permit requirements as follows pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken:

a.	Pursuant to 35 IAC 218.211(c)(3)(A), the Permittee shall notify the Illinois EPA of any record showing violation of Condition 7.2.3(e) (see also 35 IAC 218.204) within 30 days following the occurrence of the violation.

b.	Continued operation of the affected coating line with a defect in the paint booth filters that may result in emissions of particulate matter in excess of limits in Condition 7.2.3(c) and/or 7.2.6 within 30 days of such an occurrence.

7.2.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.2.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.2.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.2.3(c) is assumed to be achieved by proper operation of the dry filter system, as addressed by Condition 7.2.5(b).

b.	Compliance with Condition 7.2.3(d) is assured by the work-practices inherent in operation of a natural gas-fired curing oven.

c.	To determine compliance with Condition 5.5.1, PM and VOM emissions from the affected coating line shall be calculated based on the following:

i.	Particulate Matter Emissions:

PM (lb) = (Coating Usage, lb) x [1 - (Transfer Efficiency^* (%)/100)] x [1 - (Dry Filter Efficiency^* (%)/100)]

^*As specified by manufacturer or vendor of the spray booths and dry filter system

ii.	Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, lb) x (VOM Content of Coating, % by Wt.) + (Cleaning Solvent Usage, gal) x (Solvent Density, lb/gal)

7.3	Units GO, CO, DO	Powder Paint Line Parts Washers and Ovens

7.3.1	Description

The source operates two three stage washers where a cleaning solution is to remove oil and dirt from the parts prior to coating.  The parts are then dried a drying oven.

7.3.2	List of Emission Units and Pollution Control Equipment

Emission
Unit

Description

Emission Control
Equipment

GO | 2 Therm-Tron-X Parts Washers (Powder Paint Line Parts Washers, Natural Gas-Fired, 2.0 mmBtu/hr, each) | None
CO | Natural Gas-Fired Cure Oven (6.5 mmBtu/hr) | None
DO | Natural Gas-Fired Dry Off Oven (4.4 mmBtu/hr) | None

7.3.3	List of Emission Units and Pollution Control Equipment

a.	The Powder Paint Line Parts Washers, the Cure Oven, and the Dry Off Oven are "affected parts washers and ovens" for the purpose of these unit-specific conditions.

b.	The affected parts washers and ovens are subject to the emission limits identified in Condition 5.2.2.

c.	The affected parts washers and ovens are subject to 35 IAC 212.321(a), which provides that:

i.	No person shall cause or allow the emission of particulate matter into the atmosphere in any one hour period from any new process emission unit, either alone or in combination with the emission of particulate matter from all other similar process emission units for which construction or modification commenced on or after April 14, 1972, at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.321 (see also Attachment 1) [35 IAC 212.321(a)].

ii.	Because the expected process weight rate for the affected washers and ovens is less than 100 pounds per hour, the allowable PM emission rate for each affected washer or oven set by 35 IAC 212.321 is 0.55 pounds per hour.

d.	No person shall cause or allow the emission of sulfur dioxide into the atmosphere from any process emission unit to exceed 2000 ppm, [35 IAC 214.301].

e.	No person shall cause or allow the discharge of more than 3.6 kg/hr (8 lb/hr) of organic material into the atmosphere from any emission unit, except as provided in 35 IAC 218.302, 218.303, 218.304 and the following exception:  If no odor nuisance exists the limitation of 35 IAC 218 Subpart G shall apply only to photochemically reactive material [35 IAC 218.301].

7.3.4	Non-Applicability of Regulations of Concern

a.	The affected parts washers are not subject to the NESHAP for Halogenated Solvent Cleaning, 40 CFR 63 Subpart T because the affected washer is not a batch vapor, in-line vapor, in-line cold, and batch cold solvent cleaning machine that uses any solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent by weight, as a cleaning and/or drying agent.

b.	The affected parts washers and ovens are not subject to 35 IAC 216.121, Emissions of Carbon Monoxide from Fuel Combustion Emission Units, because the drying oven for the affected parts washers and ovens are not by definition a fuel combustion emission units.

c.	The affected parts washers and ovens are not subject to 35 IAC 217.121, Emissions of Nitrogen Oxides from New Fuel Combustion Emission Sources, because the actual heat input of each of these units is less than 73.2 MW (250 mmBtu/hr) and the affected parts washers and ovens are not by definition fuel combustion emission units.

d.	The affected parts washers and ovens are not subject to 35 IAC 212.324, Process Emission Units In Certain Areas, because the source is not located in a non-attainment area for PM_10, as identified in 35 IAC 212.324(a)(1).

e.	The affected parts washers are not subject to 35 IAC 218 Subpart E:  Solvent Cleaning, because the affected parts washers are not cold cleaning operations, open top vapor degreasers, or conveyorized degreasers.

7.3.5	Operational and Production Limits and Work Practices

a.	The affected parts washers shall only be operated with cleaning solutions containing no solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent by weight, as a cleaning and/or drying agent.

b.	The affected parts washers and ovens shall only be operated with natural gas as the fuel.

7.3.6	Emission Limitations

In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected parts washers and ovens are subject to the following:

a.	i.	Emissions and operation of the parts washers shall not exceed the following limits:

Item of

Solvent
Usage

Operating
Hours

VOM
Content

VOM
Emissions

Equipment | (lb/hr) | (hr/yr) | (% by Wt) | (lb/hr)(T/yr)
Parts Washers | 74.18 | 3,120 | 1.51 | 1.12 | 1.75

ii.	These limits are based on the maximum parts cleaning solvent usage, the maximum amount of VOM in the solvent, and the maximum hours of operation.

iii.	The above limitations contain revisions to previously issued construction permit 97050032.  The source has requested that the Illinois EPA establish conditions in this permit that allow various refinements from the conditions of this construction permit, consistent with the information provided in the CAAPP application.  The source has requested these revisions and has addressed the applicability and compliance of 35 IAC Part 203, Major Stationary Sources Construction and Modification.  These limits continue to ensure that the construction and/or modification addressed in this construction permit does not constitute a new major source or major modification pursuant to these rules.  These limits supersede the limitations established in this construction permit and the information in the CAAPP application contains the most current and accurate information for the source. Specifically, the limit on the hours of operation has been increased from 2,080 hours per year to 3,120 hours per year.

b.	i.	Emissions and operation of the Cure Oven, the Powder Paint Line Parts Washers, and the Dry Off Oven shall not exceed the following limits:

Combined
Firing

Operating

E  M  I  S  S  I  O  N  S

Rate | Hours | NO_x                 CO           PM
(mmBtu/hr) | (hr/yr) | (lb/hr)(T/yr)(lb/hr)(T/yr)(lb/hr)(T/yr)
14.9 | 3,120 | 2.09  3.25   0.52   0.81  0.21  0.33

ii.	These limits are based on standard emission factors, the type of fuel(s), the maximum firing rate(s), and the maximum hours of operation.

iii.	The above limitations contain revisions to previously issued construction permit 97050032.  The source has requested that the Illinois EPA establish conditions in this permit that allow various refinements from the conditions of this construction permit, consistent with the information provided in the CAAPP application.  The source has requested these revisions and has addressed the applicability and compliance of 40 CFR 52.21, Prevention of Significant Deterioration (PSD).  These limits continue to ensure that the construction and/or modification addressed in this construction permit does not constitute a new major source or major modification pursuant to these rules.  These limits supersede the limitations established in this construction permit and the information in the CAAPP application contains the most current and accurate information for the source. Specifically, the limit on the hours of operation has been increased from 2,080 hours per year to 3,120 hours per year and the firing rate for natural gas has been increased from 14.0 mmBtu/hr to 14.9 mmBtu/hr.

c.	Compliance with annual limits shall be determined on a monthly basis from the sum of the data for the current month plus the preceding 11 months (running 12 month total).

7.3.7	Testing Requirements

None

7.3.8	Monitoring Requirements

None

7.3.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected washers and ovens to demonstrate compliance with Conditions 5.5.1, 7.3.3, 7.3.6 pursuant to Section 39.5(7)(b) of the Act:

a.	The name and identification number of each cleaning solution used in the affected parts washers;

b.	The identification of and the percentage by weight of each HAP in each cleaning solution used in the affected parts washers;

c.	Cleaning Solution Usage; lb/mo and ton/yr;

d.	VOM content of the cleaning solution; % by Wt;

e.	Records of the fuel usage for the affected parts washers and ovens, Mft^3/mo and Mft^3/yr; 

f.	The aggregate monthly and annual VOM emissions from the affected parts washers based on the material usage, with supporting calculations; and

g.	Records of monthly and annual aggregate CO, NO_x, and PM emissions from the affected parts washers and ovens shall be maintained, based on fuel usage and the applicable emission factors, with supporting calculations.

7.3.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected washer or oven with the permit requirements as follows pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken:

a.	The usage of any cleaning solutions containing any solvent containing methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon tetrachloride or chloroform, or any combination of these halogenated HAP solvents, in a total concentration greater than 5 percent by weight, as a cleaning and/or drying agent within 30 days of such an occurrence.

b.	Emissions of VOM in excess of limits in Conditions 7.3.3(e) and/or 7.3.6(a) within 30 days of such an occurrence.

c.	Emissions of PM in excess of limits in Conditions 7.3.3(c) and/or 7.3.6(b) within 30 days of such an occurrence.

d.	Emissions of NO_x and/or CO in excess of limits in Condition 7.3.6(b) within 30 days of such an occurrence.

7.3.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.3.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.3.9 and the emission factors and formulas listed below:

a.	Compliance with Conditions 7.3.3(b), (c) and (d) is assumed to be achieved by the work-practices inherent in operation of a natural gas-fired parts washers and ovens.

b.	To determine compliance with Conditions 5.5.1, 7.3.3(e), and 7.3.6(a), VOM emissions from the affected coating line shall be calculated based on the following:

VOM (lb) = (Cleaning Solution Usage, lb) x (VOM Content of Cleaning Solution, % by Wt.)

c.	To determine compliance with Condition 7.3.6(c), fuel combustion emissions from the affected parts washers and ovens shall be calculated based on the following emission factors:

Pollutant

Emission Factor
(lb/Mft^3)

CO | 21
NO_x | 100
PM | 11.9

These are the emission factors for uncontrolled natural gas combustion in commercial boilers (0.3 -< 10 mmBtu/hr), Tables 1.4-1, 1.4-2, and 1.4-3, AP-42, Volume I, Fifth Edition, October, 1996.

Natural Gas Combustion Emissions (lb) = (Natural Gas Consumed, Mft^3) x (The Appropriate Emission Factor, lb/Mft^3)

7.4	Unit GHAF1 - 4	Gas Hot Air Furnaces #1, 2, 3, and 4

7.4.1	Description

Four direct-fired natural gas furnaces are used to provide comfort heating for the source.  Emissions from these units will be the byproducts of natural gas fuel combustion.

7.4.2	List of Emission Units and Pollution Control Equipment

Emission
Unit

Description

Rated Heat Input

GHAF1 | Hartzell Model GR284 Make-up Air Furnace (Gas Hot Air Furnace #1) | 2.9 mmBtu/hr
GHAF2 | Hartzell Model GR284 Make-up Air Furnace (Gas Hot Air Furnace #2) | 2.9 mmBtu/hr
GHAF3 | Absolute Aire Make-up Air Furnace (Gas Hot Air Furnace #3) | 4.9 mmBtu/hr
GHAF4 | Weather Rite Make-up Air Furnace (Gas Hot Air Furnace #4) | 4.9 mmBtu/hr

7.4.3	Applicability Provisions and Applicable Regulations

a.	Gas Hot Air Furnaces #1, 2, 3, and 4 are “affected furnaces" for the purpose of these unit-specific conditions.

b.	Each affected furnace is subject to the emission limits identified in Condition 5.2.2.

c.	No person shall cause or allow the emission of sulfur dioxide into the atmosphere from any process emission unit to exceed 2000 ppm, [35 IAC 214.301].

d.	No person shall cause or allow the discharge of more than 3.6 kg/hr (8 lb/hr) of organic material into the atmosphere from any emission unit, except as provided in 35 IAC 218.302, 218.303, or 218.304 and the following exemption:  If no odor nuisance exists the limitation of 35 IAC 218 Subpart G shall only apply to photochemically reactive material [35 IAC 218.301].

7.4.4	Non-Applicability of Regulations of Concern

a.	The affected furnaces are not subject to 35 IAC 216.121, emissions of carbon monoxide from fuel combustion emission units, because the affected furnaces are not by definition fuel combustion emission units.

b.	The affected furnaces are not subject to 35 IAC 217.121, Emissions of Nitrogen Oxides from New Fuel Combustion Emission Sources, because the actual heat input of each unit is less than 73.2 MW (250 mmBtu/hr) and the affected furnaces are not by definition fuel combustion emission units.

c.	This permit is issued based on the affected furnaces not being subject to 35 IAC 212.321 because due to the unique nature of this process, such rules cannot reasonably be applied.

d.	The affected furnaces are not subject to 35 IAC 212.324, Process Emission Units In Certain Areas, because the source is not located in a non-attainment area for PM_10, as identified in 35 IAC 212.324(a)(1).

7.4.5	Operational and Production Limits and Work Practices

The affected furnaces shall only be operated with natural gas as the fuel.

7.4.6	Emission Limitations

There are no specific emission limitations for these units however, there are source wide emission limitations in Condition 5.5 that include these units.

7.4.7	Testing Requirements

None

7.4.8	Monitoring Requirements

None

7.4.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected furnaces to demonstrate compliance with Condition 5.5.1, pursuant to Section 39.5(7)(b) of the Act:

None

7.4.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected furnaces with the permit requirements as follows pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken:

None

7.4.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.4.12	Compliance Procedures

Compliance with Condition 7.4.3 is assumed to be achieved by the work-practices inherent in operation of natural gas-fired furnaces.

7.5	Unit GT	Small Gasoline Storage Tank

7.5.1	Description

The Small Gasoline Storage Tank is a 500 gallon above ground, portable tank used for the storage and dispensing of gasoline.  The gasoline powered forklift trucks manufactured at this source are sold with only a gallon or so of gas.

7.5.2	List of Emission Units and Pollution Control Equipment

Emission
Unit

Description

Emission Control
Equipment

GT | Small Gasoline Storage Tank (500 gallons) | None

7.5.3	Applicability Provisions and Applicable Regulations

a.	The Small Gasoline Storage Tank is an "affected tank" for the purpose of these unit-specific conditions.

b.	The affected tank is subject to 35 IAC 218.585, which provides that:

i.	No person shall sell, offer for sale, dispense, supply, offer for supply, or transport for use in Illinois gasoline whose Reid vapor pressure exceeds the applicable limitations set forth in Conditions 7.5.3(b)(ii) and (b)(iii) (see also 35 IAC 218.585(b) and (c)) during the regulatory control periods, which shall be May 1 to September 15 for retail outlets, wholesale purchaser-consumer, operations, and all other operations [35 IAC 218.585(a)].

ii.	The Reid vapor pressure of gasoline, a measure of its volatility, shall not exceed 9.0 psi (62.07 kPa) during the regulatory control period in 1990 and each year thereafter [35 IAC 218.585(b)].

iii.	The Reid vapor pressure of ethanol blend gasolines shall not exceed the limitations for gasoline set forth in Condition 7.5.3(b)(ii) (see also 35 IAC 218.585(b)) by more than 1.0 psi (6.9 kPa).  Notwithstanding this limitation, blenders of ethanol blend gasolines whose Reid vapor pressure is less than 1.0 psi above the base stock gasoline immediately after blending with ethanol are prohibited from adding butane or any product that will increase the Reid vapor pressure of the blended gasoline [35 IAC 218.585(c)].

7.5.4	Non-Applicability of Regulations of Concern

a.	The affected tank is not subject to the NSPS for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984, 40 CFR 60 Subpart Kb, because the affected tank has a capacity of less than 40 m^3.

b.	The affected tank is not subject to the limitations of 35 IAC 218.120, Control Requirements for Storage Containers of VOL, pursuant to 35 IAC 218.119, because the affected tank is used to store a petroleum liquid and the capacity is less than 151 m^3 (40,000 gal).

c.	The affected tank is not subject to the requirements of 35 IAC 218.121, Storage Containers of VPL, pursuant to 35 IAC 218.123(a)(2), which exempts storage tanks with a capacity less than 151.42 m^3 (40,000 gal).

d.	The affected tank is not subject to the requirements of 35 IAC 218.122, Loading Operations, because the affected tank is not a stationary tank.

e.	The affected tank is not subject to the requirements of 35 IAC 218.583, Gasoline Dispensing Operations - Storage Tank Filling Operations, because the affected tank is not a stationary storage tank.

f.	The affected tank is not subject to the requirements of 35 IAC 218.586, Gasoline Dispensing Operations - Motor Vehicle Fueling Operations, pursuant to 35 IAC 218.586(b), which exempts any gasoline dispensing operation which dispenses an average monthly volume of less than 10,000 gallons of motor vehicle fuel per month.  Pursuant to 35 IAC 218.586(a)(1), average monthly volume means the amount of motor vehicle fuel dispensed per month from a gasoline dispensing operation based upon a monthly average for the 2-year period of November, 1990 through October, 1992 or, if not available, the monthly average for the most recent twelve calendar months.  Monthly averages are to include only those months when the operation was operating.

7.5.5	Operational and Production Limits and Work Practices

The affected tank shall only be used for the storage and dispensing of gasoline.

7.5.6	Emission Limitations

There are no specific emission limitations for this unit, however, there are source wide emission limitations in Condition 5.5 that include this unit.

7.5.7	Testing Requirements

Upon reasonable request by the Illinois EPA, pursuant to Section 39.5(7)(b) of the Act, the Reid vapor pressure of gasoline and the ethanol content of ethanol blend gasolines shall be determine according to the methods specified below:

a.	Pursuant to 35 IAC 218.585(d), all sampling of gasoline required pursuant to the provisions of Conditions 7.5.7(c)(ii) and (c)(iii) (see also 35 IAC 218.585(e) and (f)) shall be conducted by one or more of the following approved methods or procedures:

i.	For manual sampling, ASTM D4057 [35 IAC 218.585(d)(1)];

ii.	For automatic sampling, ASTM D4177 [35 IAC 218.585(d)(2)]; or

iii.	Sampling procedures for Fuel Volatility, 40 CFR 80 Appendix D [35 IAC 218.585(d)(3)].

b.	The Reid vapor pressure of gasoline shall be measured in accordance with either test method ASTM D323 or a modification of ASTM D323 known as the "dry method" as set forth in 40 CFR 80, Appendix E.  For gasoline - oxygenate blends which contain water-extractable oxygenates, the Reid vapor pressure shall be measured using the dry method test [35 IAC 218.585(e)].

c.	The ethanol content of ethanol blend gasolines shall be determined by use of one of the approved testing methodologies specified in 40 CFR 80, Appendix F [35 IAC 218.585(f)].

7.5.8	Monitoring Requirements

None

7.5.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected tank to demonstrate compliance with Conditions 5.5.1 and 7.5.3 pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the testing of the affected tank pursuant to Condition 7.5.7, which include the following [Section 39.5(7)(e) of the Act]:

i.	The date, place and time of sampling or measurements;

ii.	The date(s) analyses were performed;

iii.	The company or entity that performed the analyses;

iv.	The analytical techniques or methods used;

v.	The results of such analyses; and

vi.	The operating conditions as existing at the time of sampling or measurement.

b.	Each storage vessel with a design capacity less than 40,000 gallons is subject to no provisions of 35 IAC Part 218 other than those required by maintaining readily accessible records of the dimensions of the storage vessel and analysis of the capacity of the storage vessel [35 IAC 218.129(f)].

c.	The throughput of the affected tank, gal/mo and gal/yr; and

d.	The annual VOM emissions from the affected tank based on the material stored, the tank throughput, and the applicable emission factors and formulas with supporting calculations.

7.5.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected tank with the permit requirements as follows pursuant to Section 39.5(7)(f)(ii) of the Act.  Reports shall describe the probable cause of such deviations, and any corrective actions or preventive measures taken:

a.	Upon request by the Illinois EPA, the owner or operator of a gasoline dispensing operation which claims to be exempt from the requirements of 35 IAC 218.586 shall submit records to the Illinois EPA within 30 calendar days from the date of the request which demonstrate that the gasoline dispensing operation is in fact exempt; and

b.	The storage of any VOL or VPL other than the material specified in Condition 7.5.5(a) within 30 days of becoming aware of the non-compliance status.  This notification shall include a description of the event, the cause for the non-compliance, actions taken to correct the non-compliance, and the steps to be taken to avoid future non-compliance.

7.5.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.5.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.5.9 and the emission factors and formulas listed below:

For the purpose of estimating VOM emissions from each affected tank, Version 3.1 of the TANKS program is acceptable.

8.0	General Permit Conditions

8.1	Permit Shield

Pursuant to Section 39.5(7)(j) of the Act, the Permittee has requested and has been granted a permit shield.  This permit shield provides that compliance with the conditions of this permit shall be deemed compliance with applicable requirements which were applicable as of the date the proposed permit for this source was issued, provided that either the applicable requirements are specifically identified within this permit, or the Illinois EPA, in acting on this permit application, has determined that other requirements specifically identified are not applicable to this source and this determination (or a concise summary thereof) is included in this permit.

This permit shield does not extend to applicable requirements which are promulgated after June 24, 1998 (the date of issuance of the draft permit) unless this permit has been modified to reflect such new requirements.

8.2	Applicability of Title IV Requirements (Acid Deposition Control)

This source is not an affected source under Title IV of the CAA and is not subject to requirements pursuant to Title IV of the CAA.

8.3	Emissions Trading Programs

No permit revision shall be required for increases in emissions allowed under any USEPA approved economic incentives, marketable permits, emissions trading, and other similar programs or processes for changes that are provided for elsewhere in this permit and that are authorized by the applicable requirement  [Section 39.5(7)(o)(vii) of the Act].

8.4	Operational Flexibility/Anticipated Operating Scenarios

8.4.1	Changes Specifically Addressed by Permit

Physical or operational changes specifically addressed by the Conditions of this permit that have been identified as not requiring Illinois EPA notification may be implemented without prior notice to the Illinois EPA.

8.4.2	Changes Requiring Prior Notification

The Permittee is authorized to make physical or operational changes without applying for or obtaining an amendment to this permit, provided that the changes do not constitute a modification under Title I of the CAA, emissions will not exceed the emissions allowed under this permit following implementation of the physical or operational change and the Permittee provides written notice to the Illinois EPA, Division of Air Pollution Control, Permit Section, at least 7 days before commencement of the change  [Section 39.5(12)(a) of the Act].  This notice shall:

a.	Describe the physical or operational change;

b.	Identify the schedule for implementing the physical or operational change;

c.	Provide a statement of whether or not any New Source Performance Standard (NSPS) is applicable to the physical or operational change and the reason why the NSPS does or does not apply;

d.	Provide emission calculations which demonstrate that the physical or operational change will not result in a modification; and

e.	Provide a certification that the physical or operational change will not result in emissions greater than authorized under the Conditions of this permit.

8.5	Testing Procedures

Tests conducted to measure composition of materials, efficiency of pollution control devices, emissions from process or control equipment, or other parameters shall be conducted using standard test methods.  Documentation of the test date, conditions, methodologies, calculations, and test results shall be retained pursuant to the recordkeeping procedures of this permit.  Reports of any tests conducted as required by this permit or as the result of a request by the Illinois EPA shall be submitted as specified in Condition 8.6.

8.6	Reporting Requirements

8.6.1	Monitoring Reports

A report summarizing required monitoring as specified in the conditions of this permit shall be submitted to the Air Compliance Section of the Illinois EPA every six months as follows  [Section 39.5(7)(f) of the Act]:

Monitoring Period | Report Due Date
January - June | September 1
July - December | March 1

All instances of deviations from permit requirements must be clearly identified in such reports.  All such reports shall be certified in accordance with Condition 9.9.

8.6.2	Test Notifications

Unless otherwise specified elsewhere in this permit, a written test plan for any test required by this permit shall be submitted to the Illinois EPA for review at least 60 days prior to the testing pursuant to Section 39.5(7)(a) of the Act.  The notification shall include at a minimum:

a.	The name and identification of the affected unit(s);

b.	The person(s) who will be performing sampling and analysis and their experience with similar tests;

c.	The specific conditions under which testing will be performed, including a discussion of why these conditions will be representative of maximum emissions and the means by which the operating parameters for the source and any control equipment will be determined;

d.	The specific determination of emissions and operation which are intended to be made, including sampling and monitoring locations;

e.	The test method(s) which will be used, with the specific analysis method, if the method can be used with different analysis methods;

f.	Any minor changes in standard methodology proposed to accommodate the specific circumstances of testing, with justification; and

g.	Any proposed use of an alternative test method, with detailed justification.

8.6.3	Test Reports

Unless otherwise specified elsewhere in this permit, the results of any test required by this permit shall be submitted to the Illinois EPA within 60 days of completion of the testing.  The test report shall include at a minimum  [Section 39.5(7)(e)(i) of the Act]:

a.	The name and identification of the affected unit(s);

b.	The date and time of the sampling or measurements;

c.	The date any analyses were performed;

d.	The name of the company that performed the tests and/or analyses;

e.	The test and analytical methodologies used;

f.	The results of the tests including raw data, and/or analyses including sample calculations;

g.	The operating conditions at the time of the sampling or measurements; and

h.	The name of any relevant observers present including the testing company’s representatives, any Illinois EPA or USEPA representatives, and the representatives of the source.

8.6.4	Reporting Addresses

a.	The following addresses should be utilized for the submittal of reports, notifications, and renewals:

i.	Illinois EPA - Air Compliance Section

Illinois Environmental Protection Agency (MC 40)
Bureau of Air
Compliance Section
P.O. Box 19276
Springfield, Illinois  62794-9276

ii.	Illinois EPA - Air Regional Field Office

Illinois Environmental Protection Agency
Division of Air Pollution Control
Eisenhower Tower
1701 First Avenue
Maywood, Illinois  60153

iii.	Illinois EPA - Air Permit Section (MC 11)

Illinois Environmental Protection Agency
Division of Air Pollution Control
Permit Section
P.O. Box 19506
Springfield, Illinois  62794-9506

iv.	USEPA Region 5 - Air Branch

USEPA (AR - 17J)
Air & Radiation Division
77 West Jackson Boulevard
Chicago, Illinois  60604

b.	Unless otherwise specified in the particular provision of this permit, reports shall be sent to the Illinois EPA - Air Compliance Section with a copy sent to the Illinois EPA - Air Regional Field Office.

9.0	Standard Permit Conditions

9.1	Effect of Permit

9.1.1	The issuance of this permit does not release the Permittee from compliance with State and Federal regulations which are part of the Illinois State Implementation Plan, as well as with other applicable statutes and regulations of the United States or the State of Illinois or applicable ordinances, except as specifically stated in this permit and as allowed by law and rule  [Section 39.5(7)(j)(iv) of the Act].

9.1.2	In particular, this permit does not alter or affect the following:

a.	The provisions of Section 303 (emergency powers) of the CAA, including USEPA's authority under that Section;

b.	The liability of an owner or operator of a source for any violation of applicable requirements prior to or at the time of permit issuance;

c.	The applicable requirements of the acid rain program consistent with Section 408(a) of the CAA; and

d.	The ability of USEPA to obtain information from a source pursuant to Section 114 (inspections, monitoring, and entry) of the CAA.

9.1.3	Notwithstanding the conditions of this permit specifying compliance practices for applicable requirements, any person (including the Permittee) may also use other credible evidence to establish compliance or noncompliance with applicable requirements.

9.2	General Obligations of Permittee

9.2.1	Duty to Comply

The Permittee must comply with all terms and conditions of this permit.  Any permit noncompliance constitutes a violation of the CAA and the Act, and is grounds for any or all of the following:  enforcement action, permit termination, revocation and reissuance, modification, or denial of a permit renewal application  [Section 39.5(7)(o)(i) of the Act].

The Permittee shall meet applicable requirements that become effective during the permit term in a timely manner unless an alternate schedule for compliance with the applicable requirement is established.

9.2.2	Duty to Maintain Equipment

The Permittee shall maintain all equipment covered under this permit in such a manner that the performance or operation of such equipment shall not cause a violation of applicable requirements.

9.2.3	Duty to Cease Operation

No person shall cause, threaten or allow the continued operation of any emission unit during malfunction or breakdown of the emission unit or related air pollution control equipment if such operation would cause a violation of an applicable emission standard, regulatory requirement, ambient air quality standard or permit limitation unless such malfunction or breakdown is allowed by a permit condition  [Section 39.5(6)(c) of the Act].

9.2.4	Disposal Operations

The source shall be operated in such a manner that the disposal of air contaminants collected by the equipment operations, or activities shall not cause a violation of the Act or regulations promulgated thereunder.

9.2.5	Duty to Pay Fees

The Permittee must pay fees to the Illinois EPA consistent with the fee schedule approved pursuant to Section 39.5(18) of the Act, and submit any information relevant thereto  [Section 39.5(7)(o)(vi) of the Act].  The check should be payable to "Treasurer, State of Illinois" and sent to:  Fiscal Services Section, Illinois Environmental Protection Agency, P.O. Box 19276, Springfield, Illinois  62794-9276.

9.3	Obligation to Allow Illinois EPA Surveillance

Upon presentation of proper credentials and other documents, the Permittee shall allow the Illinois EPA, or an authorized representative to perform the following  [Section 39.5(7)(p)(ii) of the Act]:

a.	Enter upon the Permittee's premises where an actual or potential emission unit is located; where any regulated equipment, operation, or activity is located or where records must be kept under the conditions of this permit;

b.	Have access to and copy, at reasonable times, any records that must be kept under the conditions of this permit;

c.	Inspect during hours of operation any sources, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under this permit;

d.	Sample or monitor any substances or parameters at any location:

i.	At reasonable times, for the purposes of assuring permit compliance; or

ii.	As otherwise authorized by the CAA, or the Act.

e.	Obtain and remove samples of any discharge or emission of pollutants; and

f.	Enter and utilize any photographic, recording, testing, monitoring, or other equipment for the purposes of preserving, testing, monitoring, or recording any activity, discharge or emission at the source.

9.4	Obligation to Comply With Other Requirements

The issuance of this permit does not release the Permittee from applicable State and Federal laws and regulations, and applicable local ordinances addressing subjects other than air pollution control.

9.5	Liability

9.5.1	Title

This permit shall not be considered as in any manner affecting the title of the premises upon which the permitted source is located.

9.5.2	Liability of Permittee

This permit does not release the Permittee from any liability for damage to person or property caused by or resulting from the construction, maintenance, or operation of the sources.

9.5.3	Structural Stability

This permit does not take into consideration or attest to the structural stability of any unit or part of the source.

9.5.4	Illinois EPA Liability

This permit in no manner implies or suggests that the Illinois EPA (or its officers, agents or employees) assumes any liability, directly or indirectly, for any loss due to damage, installation, maintenance, or operation of the source.

9.5.5	Property Rights

This permit does not convey any property rights of any sort, or any exclusive privilege  [Section 39.5(7)(o)(iv) of the Act].

9.6	Recordkeeping

9.6.1	Control Equipment Maintenance Records

A maintenance record shall be kept on the premises for each item of air pollution control equipment.  As a minimum, this record shall show the dates of performance and nature of preventative maintenance activities.

9.6.2	Records of Changes in Operation

A record shall be kept describing changes made at the source that result in emissions of a regulated air pollutant subject to an applicable requirement, but not otherwise regulated under this permit, and the emissions resulting from those changes  [Section 39.5(12)(b)(iv) of the Act].

9.6.3	Retention of Records

a.	Records of all monitoring data and support information shall be retained for a period of at least 5 years from the date of the monitoring sample, measurement, report, or application.  Support information includes all calibration and maintenance records, original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit  [Section 39.5(7)(e)(ii) of the Act].

b.	Other records required by this permit shall be retained for a period of at least 5 years from the date of entry unless a longer period is specified by a particular permit provision.

9.7	Annual Emissions Report

The Permittee shall submit an annual emissions report to the Illinois EPA, Compliance Section no later than May 1 of the following year, as required by 35 IAC Part 254.

9.8	Requirements for Compliance Certification

Pursuant to Section 39.5(7)(p)(v) of the Act, the Permittee shall submit compliance certifications annually or more frequently as specified in the applicable requirement or by permit condition.

a.	The certification shall include the identification of each term or condition of this permit that is the basis of the certification; the compliance status; whether compliance was continuous or intermittent; the method(s) used for determining the compliance status of the source, both currently and over the reporting period consistent with the conditions of this permit.

b.	All compliance certifications shall be submitted to USEPA Region 5 in Chicago as well as to the Illinois EPA.

c.	All compliance reports required to be submitted shall include a certification in accordance with Condition 9.9.

9.9	Certification

Any document (including reports) required to be submitted by this permit shall contain a certification by a responsible official of the Permittee that meets the requirements of Section 39.5(5) of the Act  [Section 39.5(7)(p)(i) of the Act].  An example Certification by a Responsible Official is included as an attachment to this permit.

9.10	Defense to Enforcement Actions

9.10.1	Need to Halt or Reduce Activity Not a Defense

It shall not be a defense for the Permittee in an enforcement action that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with the conditions of this permit  [Section 39.5(7)(o)(ii) of the Act].

9.10.2	Emergency Provision

a.	An emergency shall be an affirmative defense to an action brought for noncompliance with the technology-based emission limitations under this permit if the following conditions are met through properly signed, contemporaneous operating logs, or other relevant evidence:

i.	An emergency occurred as provided in Section 39.5(7)(k) of the Act and the Permittee can identify the cause(s) of the emergency.  Normally, an act of God such as lightning or flood is considered an emergency;

ii.	The permitted source was at the time being properly operated;

iii.	The Permittee submitted notice of the emergency to the Illinois EPA within two working days of the time when emission limitations were exceeded due to the emergency.  This notice must contain a detailed description of the emergency, any steps taken to mitigate emissions, and corrective actions taken; and

iv.	During the period of the emergency the Permittee took all reasonable steps to minimize levels of emissions that exceeded the emission limitations, standards, or regulations in this permit.

b.	This provision is in addition to any emergency or upset provision contained in any applicable requirement.  This provision does not relieve a Permittee of any reporting obligations under existing federal or state laws or regulations.

9.11	Permanent Shutdown

This permit only covers emission units and control equipment while physically present at the indicated source location(s).  Unless this permit specifically provides for equipment relocation, this permit is void for the operation or activity of any item of equipment on the date it is removed from the permitted location(s) or permanently shut down.  This permit expires if all equipment is removed from the permitted location(s), notwithstanding the expiration date specified on this permit.

9.12	Reopening and Reissuing Permit for Cause

9.12.1	Permit Actions

This permit may be modified, reopened, and reissued, for cause pursuant to Section 39.5(15) of the Act.  The filing of a request by the Permittee for a permit modification, revocation, and reissuance, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition  [Section 39.5(7)(o)(iii) of the Act].

9.12.2	Reopening and Revision

This permit must be reopened and revised if any of the following occur  [Section 39.5(15)(a) of the Act]:

a.	Additional requirements become applicable to the equipment covered by this permit and three or more years remain before expiration of this permit;

b.	Additional requirements become applicable to an affected source for acid deposition under the acid rain program;

c.	The Illinois EPA or USEPA determines that this permit contains a material mistake or inaccurate statement when establishing the emission standards or limitations, or other terms or conditions of this permit; and

d.	The Illinois EPA or USEPA determines that this permit must be revised to ensure compliance with the applicable requirements of the Act.

9.12.3	Inaccurate Application

The Illinois EPA has issued this permit based upon the information submitted by the Permittee in the permit application.  Any misinformation, false statement or misrepresentation in the application shall be grounds for revocation under Section 39.5(15)(b) of the Act.

9.12.4	Duty to Provide Information

The Permittee shall furnish to the Illinois EPA, within a reasonable time specified by the Illinois EPA any information that the Illinois EPA may request in writing to determine whether cause exists for modifying, revoking and reissuing, or terminating this permit, or to determine compliance with this permit.  Upon request, the Permittee shall also furnish to the Illinois EPA copies of records required to be kept by this permit, or for information claimed to be confidential, the Permittee may furnish such records directly to USEPA along with a claim of confidentiality  [Section 39.5(7)(o)(v) of the Act].

9.13	Severability Clause

The provisions of this permit are severable, and should any one or more be determined to be illegal or unenforceable, the validity of the other provisions shall not be affected.  The rights and obligations of the Permittee shall be construed and enforced as if this permit did not contain the particular provisions held to be invalid and the applicable requirements underlying these provisions shall remain in force  [Section 39.5(7)(i) of the Act].

9.14	Permit Expiration and Renewal

The right to operate terminates on the expiration date unless the Permittee has submitted a timely and complete renewal application.  For a renewal to be timely it must be submitted no later than 9 and no sooner than 12 months prior to expiration.  The equipment may continue to operate during the renewal period until final action is taken by the Illinois EPA, in accordance with the original permit conditions  [Section 39.5(5)(l), (n), and (o) of the Act].

10.0	Attachments

10.1	Attachment 1	Emissions of Particulate Matter from New Process Emission Units

10.1.1	Process Emission Units for Which Construction or Modification Commenced On or After April 14, 1972

a.	No person shall cause or allow the emission of particulate matter into the atmosphere in any one hour period from any new process emission unit, either alone or in combination with the emission of particulate matter from all other similar process emission units for which construction or modification commenced on or after April 14, 1972, at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.321 [35 IAC 212.321(a)].

b.	Interpolated and extrapolated values of the data in subsection (c) of 35 IAC 212.321 shall be determined by using the equation [35 IAC 212.321(b)]:

E = A(P)^B

where

P = Process weight rate; and
E = Allowable emission rate; and,

i.	Up to process weight rates of 408 Mg/hr (450 T/hr):

| Metric | English
P | Mg/hr | T/hr
E | kg/hr | lb/hr
A | 1.214 | 2.54
B | 0.534 | 0.534

ii.	For process weight rate greater than or equal to 408 Mg/hr (450 T/hr):

| Metric | English
P | Mg/hr | T/hr
E | kg/hr | lb/hr
A | 11.42 | 24.8
B | 0.16 | 0.16

c.	Limits for Process Emission Units For Which Construction or Modification Commenced On or After April 19, 1972 [35 IAC 212.321(c)]:

Metric | | English |
P | E | P | E
Mg/hr | kg/hr | T/hr | lb/hr
0.05 | 0.25 | 0.05 | 0.55
0.1 | 0.29 | 0.10 | 0.77
0.2 | 0.42 | 0.2 | 1.10
0.3 | 0.64 | 0.30 | 1.35
0.4 | 0.74 | 0.40 | 1.58
0.5 | 0.84 | 0.50 | 1.75
0.7 | 1.00 | 0.75 | 2.40
0.9 | 1.15 | 1.00 | 2.60
1.8 | 1.66 | 2.00 | 3.70
2.7 | 2.1 | 3.00 | 4.60
3.6 | 2.4 | 4.00 | 5.35
4.5 | 2.7 | 5.00 | 6.00
9.0 | 3.9 | 10.00 | 8.70
13.0 | 4.8 | 15.00 | 10.80
18.0 | 5.7 | 20.00 | 12.50
23.0 | 6.5 | 25.00 | 14.00
27.0 | 7.1 | 30.00 | 15.60
32.0 | 7.7 | 35.00 | 17.00
36.0 | 8.2 | 40.00 | 18.20
41.0 | 8.8 | 45.00 | 19.20
45.0 | 9.3 | 50.00 | 20.50
90.0 | 13.4 | 100.00 | 29.50
140.0 | 17.0 | 150.00 | 37.00
180.0 | 19.4 | 200.00 | 43.00
230.0 | 22.0 | 250.00 | 48.50
270.0 | 24.0 | 300.00 | 53.00
320.0 | 26.0 | 350.00 | 58.00
360.0 | 28.0 | 400.00 | 62.00
408.0 | 30.1 | 450.00 | 66.00
454.0 | 30.4 | 500.00 | 67.00

10.2	Attachment 2	Example Certification by a Responsible Official

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted.  Based on my inquiry of the person or persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete.  I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations.

Signature		______________________________________________

Name			______________________________________________

Official Title	______________________________________________

Telephone No.	______________________________________________

Date Signed		______________________________________________

RWB:psj

1-

2-