217/782-2113

CLEAN AIR ACT PERMIT PROGRAM (CAAPP) PERMIT

PERMITTEE

Navistar International Transportation Corp.
Attn.:  Jerry G. Mittlestaedt
10400 West North Avenue
Melrose Park, Illinois  60160

Application No.:  95080106			I.D. No.:  031186ABK
Applicant’s Designation:			Date Received:  August 25, 1995
Operation of:  Diesel Engine Manufacturing
Date Issued:					Expiration Date:
Source Location:  10400 West North Avenue, Melrose Park, Cook County
Responsible Official:  Edward J. Anesi, Plant Manager

This permit is hereby granted to the above-designated Permittee to operate a Diesel Engine Manufacturing 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	10	
			
5.0	OVERALL SOURCE CONDITIONS	14	
				
	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)	20	
				
	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 Enforceability		
			
7.0	UNIT SPECIFIC CONDITIONS	26	
			
	7.1	Unit PB1	Paint Booth #1
Control WC1	Water Curtain	

			PAGE	

	7.2	Unit PB2	Paint Booth #2
Control WC2	Water Curtain	
	7.3	Unit DOO	Dry-Off Oven	
	7.4	Unit 2SDO	Two Stage Drying Oven	
	7.5	Units B1, B2, & B3	Boilers #1, #2, and #3	
	7.6	Unit NGDDF	NGD Crankshaft Draw Furnace	
	7.7	Units SH	41 Space Heaters	
	7.8	Units ETC	79 Engine Test Cells	
	7.9	Unit COGEN	Cogeneration System
Control C3	3-Way Catalytic Converters	
	7.10	Units EETC	15 Engineering Engine Test Cells	
			
8.0	GENERAL PERMIT CONDITIONS	81	
				
	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	86	
				
	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 - Emissions of Particulate Matter from Existing Process Emission Units	2-1	
	10.3	Attachment 3 - Net VOM Emissions Increase Determination	3-1	
	10.4	Attachment 4 - Example Certification by a Responsible Official	4-1	

1.0	Source Identification

1.1	Source

Navistar International Transportation Corp.
10400 West North Avenue
Melrose Park, Illinois  60160
708/865-3729 or 708/865-4359

I.D. No.:  031186ABK
Standard Industrial Classification:	3519, Engines - Internal Combustion

1.2	Owner/Parent Company

Navistar International Transportation Corp.
455 North Cityfront Plaza Drive
Chicago, Illinois  60611

1.3	Operator

Navistar International Transportation Corp.
10400 West North Avenue
Melrose Park, Illinois  60160

Jerry G. Mittlestaedt or Sanjay Patel
708/865-3729 or 708/865-4359

1.4	General Source Description

Navistar International Transportation Corp. is located at 10400 West North Avenue in Melrose Park.  The source is an assembly plant for diesel engines.  After assembly each engine is tested for durability and performance in any of Navistar's 79 engine test cells.  In addition, Navistar operates a cogeneration system to supply energy for peak demand periods at the plant.

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	
ATU	Allotment Trading Unit	
Ave.	Average	
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	
g	gram	
gal	gallon	
HAP	Hazardous Air Pollutants	
hp	horsepower	
hr	hour	
IAC	Illinois Administrative Code	
I.D. No.	Identification Number of Source, assigned by Illinois EPA	
Illinois EPA	Illinois Environmental Protection Agency	
IPCT	Industrial Process Cooling Tower	
kg	kilogram	
kW	kilowatt	
kW-hr	kilowatt hour	
l	liter	
lb	pound	
Mft3	Million cubic feet	
Mg	Metric Tonnes or Megagram	
mmBtu 	Million Btus	
mo	month	
MW	Megawatt	
NESHAP	National Emission Standards for Hazardous Air Pollutants	
NOx	Nitrogen Oxides	
NSPS	New Source Performance Standards	
PM	Particulate Matter	
PM10	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	
SCC	Source Classification Code	
SO2	Sulfur Dioxide	
T	Ton	
USEPA	United States Environmental Protection Agency	
VOM	Volatile Organic Material	
wk	week	
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:

Wet Abrasive Saw
Wheelabrator with Dust Collector
Shot Blaster with Dust Collector
Carpenter Shop Woodworking Equipment with Rotoclones
NGD Machinery with Cycoils
Storage Tanks in Tank Farm Shed
Grinders with Rotoclones
Cooling Towers
Maintenance Paint Booth
Welding/Brazing
Three Stage Washer

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:

Process Machinery with Mist Collectors
Parts Washers
Maintenance Welding

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)].

Extruders used for the extrusion of metals, minerals, plastics, rubber, or wood, excluding extruders used in the manufacture of polymers, provided that volatile organic materials or class I or II substances subject to the requirements of Title VI of the CAA are not used as foaming agents or release agents or were not used as foaming agents in the case of extruders processing scrap material  [35 IAC 201.210(a)(5)].

Equipment used for filling drums, pails, or other packaging containers, excluding aerosol cans, with soaps, detergents, surfactants, lubricating oils, waxes, vegetable oils, greases, animal fats, glycerin, sweeteners, corn syrup, aqueous salt solutions, or aqueous caustic solutions  [35 IAC 201.210(a)(8)].

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)].

Loading and unloading systems for railcars, tank trucks, or watercraft that handle only the following liquid materials, provided an organic solvent has not been mixed with such materials:  soaps, detergents, surfactants, lubricating oils, waxes, glycerin, vegetable oils, greases, animal fats, sweetener, corn syrup, aqueous salt solutions, or aqueous caustic solutions  [35 IAC 201.210(a)(18)].

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	
PB1	Binks Paint Spray Booth (Paint Booth #1)	Prior to 1970	Water Curtain	
PB2	George Koch & Sons, Inc. Paint Spray Booth (Paint Booth #2)	February, 1995	Water Curtain	
DOO	George Koch & Sons, Inc. Dry-Off Oven (Dry-Off Oven)	February, 1995	None	
2SDO	George Koch & Sons, Inc. Two Stage Drying Oven (Two Stage Drying Oven)	February, 1995	None	
B1	Stone Johnson Boiler (Boiler #1)	October, 1988	None	
B2	Stone Johnson Boiler (Boiler #2)	October, 1988	None	
B3	Stone Johnson Boiler (Boiler #3)	October, 1988	None	
NGDDF	Lanley Draw Furnace (NGD Crankshaft Draw Furnace)	April, 1992	None	
L-3	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
L-6	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
L-9	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
L-13	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
BB-3	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
BB-8	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
BB-12	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
N-18	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
G-12	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	

Emission
Unit	

Description	
Date
Constructed	Emission Control 
Equipment	
G-8	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
G-4	Rapid Model 3073 Natural Gas Fired Space Heater (8.25 mmBtu/hr)	November, 1987	None	
BB-7	Rapid Model SR66 Natural Gas Fired Space Heater (6.25 mmBtu/hr)	November, 1987	None	
B-23	Rapid Model 3060 Natural Gas Fired Space Heater (4.25 mmBtu/hr)	November, 1987	None	
10-E	Rapid Model 3049 Natural Gas Fired Space Heater (3.25 mmBtu/hr)	November, 1987	None	
A-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
C-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
D-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
E-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
F-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
G-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
H-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
I-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
A-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
B-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	

Emission
Unit	

Description	
Date
Constructed	Emission Control 
Equipment	
C-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
E-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
F-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
G-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
I-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
G-24	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
K-15	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
K-18	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater (2.5 mmBtu/hr)	May, 1971	None	
AA-21-3	Hartzell Model G-2512 Natural Gas Fired Space Heater (2.5 mmBtu/hr)	November, 1970	None	
AA-21-4	Hartzell Model G-2512 Natural Gas Fired Space Heater (2.5 mmBtu/hr)	November, 1970	None	
D-2	Hartzell Model G-259 Natural Gas Fired Space Heater (2.5 mmBtu/hr)	November, 1970	None	
H-2	Hartzell Model G-259 Natural Gas Fired Space Heater (2.5 mmBtu/hr)	November, 1970	None	
L-9	Devilbliss Model ARG-50 Natural Gas Fired Space Heater (5.2 mmBtu/hr)	January, 1970	None	
AA-17	Devilbliss Model ARG-50 Natural Gas Fired Space Heater (5.2 mmBtu/hr)	January, 1970	None	
L-13-0	Devilbliss Model ARG-50 Natural Gas Fired Space Heater (5.2 mmBtu/hr)	January, 1970	None	

Emission
Unit	

Description	
Date
Constructed	Emission Control 
Equipment	
L-13-3	Devilbliss Model ARG-50 Natural Gas Fired Space Heater (5.2 mmBtu/hr)	January, 1970	None	
ETC	79 Navistar International Transportation Corp. Engine Test Cells	Prior to 1970	None	
COGEN	12 Caterpillar Model G3516SITA Natural Gas Spark Ignition Reciprocating Engines	July, 1992	3-Way Catalytic Converters (12)	
EETC	15 Navistar International Transportation Corp. Engineering Engine Test Cells	1998	None	
Fugitive VOM
Emissions	Cold Parts Cleaning Operations	-----	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 CO, NOx, and 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 owner or operator so that the operating program is current.  Such amendments shall be consistent with the requirements set forth by Condition 5.2.2(b) and shall be submitted to the Illinois EPA pursuant to 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.

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

5.3.1	This permit is issued based on the source not being subject to the NESHAP for Industrial Process Cooling Towers 40 CFR 63, Subpart Q, because the industrial process cooling towers are not operated with chromium-based water treatment chemicals.

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:

5.4.1	No owner or operator of an IPCT shall use chromium-based water treatment chemicals in any affected IPCT [40 CFR 63.402].

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 (NOx)	336.860	
Particulate Matter (PM)	 34.360	
Sulfur Dioxide (SO2)	  7.770	
Volatile Organic Material (VOM)	 96.950	
HAP, not included in VOM or PM	  0.004	
TOTAL	475.944	

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

The annual emissions from the source shall not exceed the following limitations:

a.	Emissions and operation of the cold parts cleaning operation shall not exceed the following limits:

Cleaning Solvent VOM Usage	VOM Emissions	
(ton/mo)	(ton/yr)	ton/mo	ton/yr	
1.76	10.54	1.76	10.54	

These limits are based on representations of the maximum actual emissions resulting from the maximum cleaning solvent usage at the maximum VOM content of the cleaning solvents (100% by weight).

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 limits on VOM are limitations established in Construction Permit 98070033 pursuant to 35 IAC Part 203.  These limits ensure that the construction/modification addressed in the aforementioned Construction Permit does not constitute a new major source or major modification pursuant to 35 IAC Part 203.  See Conditions 7.2.6 and 7.10.6.

d.	The VOM emission units with contemporaneous VOM emissions are described in Table 1 of Attachment 3.  The emission units or activities used to decrease emissions are described in Table 2 of Attachment 3.  The net change in VOM emissions is described in Table 3 of Attachment 3.

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	General Records for IPCT's

To demonstrate continuing compliance with Condition 5.4.1 (see also 40 CFR 63.402), the owner or operator of each affected IPCT shall maintain copies of the initial notification and the notification of compliance status as required by 40 CFR 63.405 for a period of at least 5 years onsite [40 CFR 63.406(a)].

5.6.3	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)].

5.6.4	Records for Cold Parts Cleaning

a.	The amount of solvent added to the cold parts cleaning operation; lb/mo and ton/yr;

b.	The VOM content of the solvent to the cold parts cleaning operation; % by weight;

c.	The amount of solvent recovered from the cold parts cleaning operation for reclamation and recycling; lb/mo and ton/yr;

d.	The VOM content of the solvent recovered from the cold parts cleaning operation, % by weight; and

e.	The aggregate monthly and annual VOM emissions from the cold parts cleaning operation based on the solvent usage and the VOM content of the recovered solvent, with supporting calculations.

5.6.5	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:

a.	Annual emissions from the source in excess of the emission limits specified in Condition 5.5.1 based on the current month’s records plus the preceding 11 months within 30 days of such an occurrence.

b.	Emissions of VOM from the Cold Parts Cleaning Operation in excess of the limits in Condition 5.5.3 based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

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	Emissions of VOM from the Cold Parts Cleaning Operation

a.	Cold Parts Cleaning Solvent VOM Usage:

Cleaning Solvent VOM Usage (lb) = [(Weight of Solvent Added, lb) x (VOM Content of Solvent, % by Wt.)] - [(Weight of Solvent Recovered, lb) x (VOM Content of Recovered Solvent, % by Wt.)]

b.	VOM Emissions from Cold Parts Cleaning Solvent Usage:

Cleaning Solvent VOM Emissions (lb) = [(Weight of Solvent Added, lb) x (VOM Content of Solvent, % by Wt.)] - [(Weight of Solvent Recovered, lb) x (VOM Content of Recovered Solvent, % by Wt.)]

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 condition 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 November 30 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 144 ATUs per seasonal allotment period.

ii.	This allotment of ATUs reflects the Illinois EPA’s determination that the source’s baseline emissions were 15.16 tons.

This determination includes adjustment to actual emissions to account for voluntary over-compliance at the source, e.g., Paint Booth #1, pursuant to 35 IAC 205.320(d) 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)

Dry Off Oven
Three Stage Washer
Two Stage Drying Oven
Paint Booth #2
Cogeneration System

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	Unit PB1	Paint Booth #1
Control WC1	Water Curtain

7.1.1	Description

Paint is applied to an engine after it has been tested, washed, and dried.  This paint booth is equipped with a water curtain for control of particulate matter emissions.  The paint is heated in the drying oven, not included in this coating line, where the majority of the volatile solvents are evaporated and the paint is dried.

7.1.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	

Description	Emission Control
Equipment	
PB1	Binks Paint Spray Booth (Paint Booth #1)	Water Curtain	

7.1.3	Applicability Provisions and Applicable Regulations

a.	Paint Booth #1 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 212.322(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 process emission unit for which construction or modification commenced prior to April 14, 1972, which, either alone or in combination with the emission of particulate matter from all other similar process emission at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.322 (see also Attachment 2) [35 IAC 212.322(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 212.322 is 0.55 pounds per hour.

d.	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 Miscellaneous Metal Parts and Products/Extreme Performance/Baked Coating.  The following emission limitation is 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.  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 [35 IAC 218.204(j)(2)(B)]:

kg/l	lb/gal	
0.40	3.3	

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 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 PM10, 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 water curtain, including periodic inspection, routine maintenance and prompt repair of defects.

7.1.6	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.

7.1.7	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 the 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 water curtain:

i.	Records for periodic inspection of the water curtain 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.	Coating usage, gal/day and gal/yr;

e.	VOM content of coatings, % by Wt;

f.	Density of coatings, lb/gal; and

g.	The aggregate monthly and annual PM and VOM emissions from the affected coating line based on the operating schedule and the typical hourly emission rate, with supporting calculations.

7.1.10	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 7.1.3(d) (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 water curtain 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.

7.1.11	Operational Flexibility/Anticipated Operating Scenarios

The Permittee is authorized to make the following physical or operational change with respect to VARIABLE without prior notification to the Illinois EPA or revision of this permit.  This condition does not affect the Permittee’s obligation to properly obtain a construction permit in a timely manner for any activity constituting construction or modification of the source, as defined in 35 IAC 201.102:

The Permittee may switch vendor and/or color of the coating used on the affected coating line as long as VOM emissions do not exceed the limits specified in Conditions 5.5 and 7.1.3(d).

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 Condition 7.1.3(c) is assumed by proper operation of the water curtain, as addressed by Condition 7.1.5.

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

i.	Volatile Organic Material Emissions:

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

ii.	Particulate Matter Emissions:

PM (lb) = (Wt of Coating Used, lb) x (Wt % Solids) x [1 - (Transfer Efficiency* (%)/100)] x [1 - (Water Curtain Efficiency* (%)/100)]

*As specified by manufacturer or vendor of the spray booth and water curtain

7.2	Unit PB2	Paint Booth #2
Control WC2	Water Curtain

7.2.1	Description

Paint is applied to an engine after it has been tested, washed, and dried.  This paint booth is equipped with a water curtain for control of particulate matter emissions.  The paint booth is equipped with a make-up air heater, which uses natural gas as the fuel.

7.2.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	

Description	Emission Control
Equipment	
PB2	George Koch & Sons, Inc. Paint Spray Booth (Paint Booth #2)	Water Curtain	

7.2.3	Applicability Provisions and Applicable Regulations

a.	Paint Booth #1 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 106 pounds per hour, the allowable PM emission rate for the affected coating line set by 35 IAC 212.321 is 0.53 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 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 Miscellaneous Metal Parts and Products/Extreme Performance/Baked Coating.  The following emission limitation is 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.  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 [35 IAC 218.204(j)(2)(B)]:

kg/l	lb/gal	
0.40	3.3	

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 make-up air heater 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 make-up air heater is not by definition a fuel combustion emission unit.

c.	The make-up air heater 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 make-up air heater 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 PM10, 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 Permittee shall follow good operating practices for the water curtain, including periodic inspection, routine maintenance and prompt repair of defects.

b.	The make-up air heater shall only be operated with natural gas as the fuel.

c.	This permit is issued based on the cleaning solvents used on the affected coating line containing no VOM.

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 paint spray booth (Line #2) shall not exceed the following limits:

i.	Paint Usage and Emissions:

Paint Usage	VOM Content	VOM Emissions	
PM Emissions	
(gal/mo)(gal/yr)	(lb/gal)	(t/mo)(t/yr)	(lb/hr)(t/yr)	
6,007	36,044	1.35	4.05	24.33	0.42	0.25	

ii.	These limits are based on the maximum paint usage and the maximum VOM content of the coatings.  Note:  The above VOM content limit includes water and exempt compounds.

iii.	The above limitations were established in Construction Permits 94120009 and 98070033, pursuant to 35 IAC Part 203.  These limits ensure that the construction and/or modification addressed in the aforementioned Construction Permit does not constitute a new major source or major modification pursuant to 35 IAC Part 203.

iv.	The above limitations contain revisions to previously issued construction permit 94120009.  The source has requested that the Illinois EPA establish conditions in this permit (and in construction permit 98070033) that allow various refinements from the conditions of this construction permit (#94120009), 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 and/or 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 (#94120009) and the information in the CAAPP application contains the most current and accurate information for the source.  Specifically, the solvent usage and emission limits were removed and the VOM emissions resulting from the solvent usage were added to the paint usage emissions.

v.	The VOM emission units with contemporaneous VOM emissions are described in Table 1 of Attachment 3.  The emission units or activities used to decrease emissions are described in Table 2 of Attachment 3.  The net change in VOM emissions is described in Table 3 of Attachment 3.

b.	Emissions and operation of equipment shall not exceed the following limits:

Item of	Fuel Usage	NOx Emissions	CO Emissions	
Equipment	Mft3/mo	Mft3/yr	Ton/mo	Ton/yr	Ton/mo	Ton/yr	
Paint Booth	4.8	28.4	0.24	1.42	0.20	1.20	

i.	These limits are based on standard emission factors, the type of fuel, and the maximum fuel usage.

ii.	The above limitations contain revisions to previously issued construction permit 94120009.  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 and/or 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 emission limit for CO has been increased based on a revised AP-42 emission factor and the production limitations have been switched from the maximum firing rate and maximum hours of operation of the unit to the maximum monthly and annual fuel usage rates.

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).

7.2.7	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 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 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 water curtain:

i.	Records for periodic inspection of the water curtain 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.	Coating usage, gal/day and gal/yr;

e.	VOM content of coatings, lb/gal (including water and exempt compounds);

f.	Records of the fuel usage for the make-up air heater, Mft3/mo and Mft3/yr;

g.	The aggregate monthly and annual PM and VOM emissions from the affected coating line based on the operating schedule and the typical hourly emission rate, with supporting calculations; and

h.	Records of monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the make-up air heater shall be maintained, based on fuel usage and the applicable emission factors, with supporting calculations.

7.2.10	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 7.2.3(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 water curtain that may result in emissions of particulate matter in excess of limits in Condition 7.2.3(c) within 30 days of such an occurrence.

c.	The usage of any solvent containing VOM within 30 days of such an occurrence.

d.	Emissions of VOM in excess of the limits in Condition 7.2.6(a) based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

e.	Emissions of NOx and/or CO in excess of the limits in Condition 7.2.6(b) based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

7.2.11	Operational Flexibility/Anticipated Operating Scenarios

The Permittee is authorized to make the following physical or operational change with respect to VARIABLE without prior notification to the Illinois EPA or revision of this permit.  This condition does not affect the Permittee’s obligation to properly obtain a construction permit in a timely manner for any activity constituting construction or modification of the source, as defined in 35 IAC 201.102:

The Permittee may switch vendor and/or color of the coating used on the affected coating line as long as VOM emissions do not exceed the limits specified in Conditions 5.5 and 7.2.3(e).

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 by proper operation of the water curtain, as addressed by Condition 7.2.5.

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

c.	To determine compliance with Condition 5.5.1 and 7.2.6, emissions from the affected coating line shall be calculated based on the following:

i.	Volatile Organic Material Emissions:

VOM (lb) = (Coating Usage, gal) x (VOM Content of Coating, lb/gal)

ii.	Particulate Matter Emissions:

PM (lb) = (Wt of Coating Used, lb) x (Wt % Solids) x [1 - (Transfer Efficiency* (%)/100)] x [1 - (Water Curtain Efficiency* (%)/100)]

*As specified by manufacturer or vendor of the spray booth and water curtain

d.	To determine compliance with Conditions 5.5.1 and 7.2.6(b), fuel combustion emissions from the make-up air heater on the affected coating line shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
CO	84	
NOx	100	
PM	7.6	
SO2	0.6	
VOM	5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Make-Up Air Heater Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

7.3	Unit DOO	Dry-Off Oven

7.3.1	Description

The dry-off oven is used to dry the engines after they have been washed in the three stage washer.  Emissions from this unit will be due to the byproducts of natural gas fuel combustion.

7.3.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Emission Control
Equipment	
DOO	George Koch & Sons, Inc. Dry-Off Oven (Dry-Off Oven)	None	

7.3.3	Applicability Provisions and Applicable Regulations

a.	The dry-off oven is an “affected dry-off oven" for the purpose of these unit-specific conditions.

b.	The affected dry-off oven is subject to the emission limits identified in Condition 5.2.2.

c.	The dry-off oven 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 dry-off oven is less than 100 pounds per hour, the allowable PM emission rate for the affected dry-off 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 dry-off oven 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 affected dry-off oven is not by definition a fuel combustion emission unit.

b.	The affected dry-off oven 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 affected dry-off oven is not by definition a fuel combustion emission unit.

c.	The affected dry-off oven 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.3.5	Operational and Production Limits and Work Practices

The affected dry-off oven 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 dry-off oven is subject to the following:

a.	Emissions and operation of equipment shall not exceed the following limits:

Item of	Fuel Usage	NOx Emissions	CO Emissions	
Equipment	Mft3/mo	Mft3/yr	Ton/mo	Ton/yr	Ton/mo	Ton/yr	
Dry-Off Oven	1.4	8.8	0.07	0.44	0.06	0.36	

i.	These limits are based on standard emission factors, the type of fuel, and the maximum fuel usage.

ii.	The above limitations contain revisions to previously issued construction permit 94120009.  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 and/or 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 emission limit for CO has been increased based on a revised AP-42 emission factor and the production limitations have been switched from the maximum firing rate and maximum hours of operation of the unit to the maximum monthly and annual fuel usage rates.

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).

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 dry-off oven to demonstrate compliance with Conditions 5.5.1, 7.3.3, and 7.3.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the fuel usage for the affected dry-off oven, Mft3/mo and Mft3/yr; and

b.	Records of monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected dry-off oven 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 dry-off 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:

Emissions of NOx and/or CO in excess of the limits in Condition 7.3.6 based on the current month's records plus the preceding 11 months 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 Condition 7.3.3 is assumed by the work-practices inherent in operation of a natural gas-fired dry-off oven.

b.	To determine compliance with Conditions 5.5.1 and 7.3.6, fuel combustion emissions from the affected dry-off oven shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
CO	84	
NOx	100	
PM	7.6	
SO2	0.6	
VOM	5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Dry-Off Oven Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

7.4	Unit 2SDO	Two Stage Drying Oven

7.4.1	Description

The two stage drying oven is used to dry the engines after they have been painted in one of the two paint booths.  Emissions from this unit will be due to byproducts of natural gas fuel combustion.

7.4.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	

Description	Emission Control
Equipment	
2SDO	George Koch & Sons, Inc. Two Stage Drying Oven (Two Stage Drying Oven)	None	

7.4.3	Applicability Provisions and Applicable Regulations

a.	The two stage drying oven is an “affected drying oven" for the purpose of these unit-specific conditions.

b.	The affected drying oven is subject to the emission limits identified in Condition 5.2.2.

c.	The affected drying oven 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 drying oven is less than 100 pounds per hour, the allowable PM emission rate for the affected drying 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].

7.4.4	Non-Applicability of Regulations of Concern

a.	The affected drying oven 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 affected drying oven is not by definition a fuel combustion emission unit.

b.	The affected drying oven 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 affected drying oven is not by definition a fuel combustion emission unit.

c.	The affected drying oven 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.4.5	Operational and Production Limits and Work Practices

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

7.4.6	Emission Limitations

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

a.	Emissions and operation of equipment shall not exceed the following limits:

Item of	Fuel Usage	NOx Emissions	CO Emissions	
Equipment	Mft3/mo	Mft3/yr	Ton/mo	Ton/yr	Ton/mo	Ton/yr	
Two Stage Drying Oven	
3.0	
17.2	
0.15	
0.88	
0.12	
0.72	

These limits are based on standard emission factors, the type of fuel, the maximum firing rate, and the maximum fuel usage.

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 contain revisions to previously issued construction permit 94120009.  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 and/or 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 firing rate has been increased from 1.00 mmBtu/hr to 2.00 mmBtu/hr and the emission limit for CO has been increased based on a revised AP-42 emission factor and the production limitations have been switched from the maximum firing rate and maximum hours of operation of the unit to the maximum monthly and annual fuel usage rates.

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 drying oven to demonstrate compliance with Conditions 5.5.1, 7.4.3, and 7.4.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the fuel usage for the affected drying oven, Mft3/mo and Mft3/yr; and

b.	Records of monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected drying oven shall be maintained, based on fuel usage and the applicable emission factors, with supporting calculations.

7.4.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of an affected drying 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:

Emissions of NOx and/or CO in excess of the limits in Condition 7.4.6 based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

7.4.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.4.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.4.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.4.3 is assumed by the work-practices inherent in operation of a natural gas-fired drying oven.

b.	To determine compliance with Conditions 5.5.1 and 7.4.6, fuel combustion emissions from the affected drying oven shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
CO	84	
NOx	100	
PM	    7.6	
SO2	    0.6	
VOM	    5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Drying Oven Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

7.5	Units B1, B2, B3	Boilers #1, #2, and #3

7.5.1	Description

Boilers are utilized to provide process steam and heat to the plant.  The boilers are each identical and are fired with natural gas.  The boilers have the capability to utilize distillate fuel oil, but are not normally operated with it.  Emissions from the boilers are the byproducts of fuel combustion from either natural gas or distillate fuel oil.

7.5.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Rated Heat Input	
B1	Stone Johnson Boiler 
(Boiler #1)	32.4 mmBtu/hr	
B2	Stone Johnson Boiler 
(Boiler #2)	32.4 mmBtu/hr	
B3	Stone Johnson Boiler 
(Boiler #3)	32.4 mmBtu/hr	

7.5.3	Applicability Provisions and Applicable Regulations

a.	Boilers #1, #2, and #3 are “affected boilers" for the purpose of these unit-specific conditions.

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

c.	No person shall cause or allow the emission of carbon monoxide (CO) into the atmosphere from any fuel combustion emission unit with actual heat input greater than 2.9 MW (10 mmBtu/hr) to exceed 200 ppm, corrected to 50 percent excess air [35 IAC 216.121].

d.	No person shall cause or allow the emission of particulate matter into the atmosphere in any one hour period to exceed 0.15 kg of particulate matter per MW-hr of actual heat input from any fuel combustion emission unit using liquid fuel exclusively (0.10 lb/mmBtu) [35 IAC 212.206].

e.	No person shall cause or allow the emission of sulfur dioxide in any one hour period from any new fuel combustion emission unit with actual heat input smaller than, or equal to 73.2 MW (250 mmBtu/hr), burning liquid fuel exclusively to exceed 0.46 kg of sulfur dioxide per MW-hr of actual heat input when distillate fuel oil is burned (0.3 lb/mmBtu) [35 IAC 214.122(b)].

7.5.4	Non-Applicability of Regulations of Concern

a.	The NSPS for Small-Industrial-Commercial-Institutional Steam Generating Units, 40 CFR 60, Subpart Dc, applies to units for which construction, modification or reconstruction is commenced after June 9, 1989 and that have a maximum design heat input capacity of 29 MW (100 mmBtu/hr) or less, but greater than or equal to 2.9 MW (10 mmBtu/hr).  The affected boilers were constructed in 1988, therefore, these rules do not apply.

b.	The affected boilers are not subject to 35 IAC 217.121, emissions of nitrogen oxides from new fuel combustion emission sources, because the actual heat input of is less than 73.2 MW (250 mmBtu/hr).

c.	Pursuant to 35 IAC 218.303, fuel combustion emission units are not subject to 35 IAC 218.301, Use Of Organic Material.

7.5.5	Operational and Production Limits and Work Practices

a.	The affected boilers shall only be fired with natural gas and distillate fuel oil.

b.	The Permittee shall not utilize distillate fuel oil (Grades No. 1 and 2) in the affected boilers with a sulfur content greater than the larger of the following two values:

i.	0.28 weight percent; or

ii.	The Wt percent given by the formula:  Maximum Wt percent sulfur = (0.000015) x (Gross heating value of oil, Btu/lb).

7.5.6	Emission Limitations

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

a.	Emissions and operation of equipment shall not exceed the following limits:

Emission	Firing
Rate	Fuel Oil Usage	
Annual Emissions (Tons/Year)	
Unit	(mmBtu/hr)	(gal/yr)	CO1	NOx1	PM2	SO22	VOM1	
Three
Boilers	
97.2	
2,000,000	
37.45	
44.58	
5.39	
39.90	
2.45	

1Natural gas firing
2Maximum allowed oil firing rate plus natural gas firing

These limits are based on compliance with 35 IAC 212.206 and 35 IAC 214.122(b), standard emission factors, the type of fuel, the maximum firing rate, and the maximum hours of operation (8,736 hr/yr).

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 contain revisions to previously issued construction permit 88080014.  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 and/or 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, CO, NOx, and PM emissions have been increased based on revisions to the standard emission factors.

7.5.7	Testing Requirements

None

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 boilers to demonstrate compliance with Conditions 5.5.1, 7.5.3, and 7.5.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Natural gas fuel usage for the affected boilers, Mft3/mo and Mft3/yr; 

b.	Distillate fuel oil usage for the affected boilers, gal/mo and gal/yr;

c.	The sulfur content of the distillate fuel oil used in the affected engine test cells (% by Wt), this shall be recorded for any one shipment of oil delivered to the source each month; and

d.	Monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected boilers shall be maintained, based on fuel consumption and the applicable emission factors, with supporting calculations.

7.5.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected boilers 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.	Emissions of CO, NOx, PM, SO2, and/or VOM in excess of the limit specified in Condition 7.5.6; or

b.	The use of distillate fuel oil with a sulfur content in excess of the limit specified in Condition 7.5.5(b) with the length of time this fuel was used and the effect on emissions of SO2 within 30 days of this violation being detected.

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:

a.	Compliance with Conditions 7.5.3(c) and (d) is assumed by the work-practices inherent in operation of natural gas-fired and distillate oil-fired boilers.

b.	Compliance with Condition 7.5.3(e) is demonstrated by operation of the boiler with distillate fuel oil with a sulfur content meeting the specification of Condition 7.5.5(b).

c.	Compliance with the emission limits of Conditions 5.5.1 and 7.5.6 shall be based on the emission factors listed below:

i.	To determine compliance with Conditions 5.5.1 and 7.5.6, emissions from the affected boilers burning natural gas shall be calculated based on the following emission factors:

Pollutant	Natural Gas
Emission Factor
(lb/Mft3)	
CO	84	
NOx	100	
PM	7.6	
SO2	0.6	
VOM	5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Boiler Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

ii.	To determine compliance with Condition 5.5.1 and 7.5.6, emissions from the affected boilers burning distillate fuel oil shall be calculated based on the following emission factors:

Pollutant	Distillate Fuel Oil Emission Factor
(lb/1000 gal)	
CO	5	
NOx	20	
PM	2	
SO2	142 S	
VOM	0.216	

These are the emission factors for uncontrolled distillate fuel oil combustion in commercial/institutional/residential combustors, Tables 1.3-2 and 1.3-15, AP-42, Volume I, Fifth Edition, October, 1996.  S indicates that the weight % of sulfur in the oil should be multiplied by the value given.

Boiler Emissions (lb) = (Distillate Fuel Oil Consumed, gal)x (The Appropriate Emission Factor, lb/1000 gal)

7.6	Unit NGDDF	NGD Crankshaft Draw Furnace

7.6.1	Description

The next generation diesel (NGD) engine crankshaft draw furnace is used for heat treating metal.  Emissions from this unit will be due to byproducts of natural gas combustion.

7.6.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Emission Control
Equipment	
NGDDF	Lanley Draw Furnace (NGD Crankshaft Draw Furnace)	None	

7.6.3	Applicability Provisions and Applicable Regulations

a.	The NGD Crankshaft Draw Furnace is an “affected draw furnace" for the purpose of these unit-specific conditions.

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

c.	The affected draw furnace 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 draw furnace is 5,000 pounds per hour, the allowable PM emission rate for the affected draw furnace set by 35 IAC 212.321 is 4.14 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].

7.6.4	Non-Applicability of Regulations of Concern

a.	The affected draw furnace 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 affected draw furnace is not by definition a fuel combustion emission unit.

b.	The affected draw furnace 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 affected draw furnace is not by definition a fuel combustion emission unit.

c.	The affected draw furnace 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.6.5	Operational and Production Limits and Work Practices

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

7.6.6	Emission Limitations

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

a.	Emissions and operation of equipment shall not exceed the following limits:

Item of	Fuel Usage	NOx Emissions	CO Emissions	
Equipment	Mft3/mo	Mft3/yr	Ton/mo	Ton/yr	Ton/mo	Ton/yr	
Draw Furnace	3.2	19.4	0.16	0.97	0.13	0.80	

i.	These limits are based on standard emission factors, the type of fuel, and the maximum fuel usage.

ii.	The above limitations contain revisions to previously issued construction permit 91100096.  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 and/or 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 emission limit for CO has been increased based on a revised AP-42 emission factor and the production limitations have been switched from the maximum firing rate and maximum hours of operation of the unit to the maximum monthly and annual fuel usage rates.

7.6.7	Testing Requirements

None

7.6.8	Monitoring Requirements

None

7.6.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected draw furnace to demonstrate compliance with Conditions 5.5.1, 7.6.3, and 7.6.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the fuel usage for the affected draw furnace, Mft3/mo and Mft3/yr; and

b.	Records of monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected draw furnace shall be maintained, based on fuel usage and the applicable emission factors, with supporting calculations.

7.6.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected draw furnace 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:

Emissions of NOx and/or CO in excess of the limits in Condition 7.6.6 based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

7.6.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.6.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.6.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.6.3 is assumed by the work-practices inherent in operation of a natural gas-fired draw furnace.

b.	To determine compliance with Conditions 5.5.1 and 7.6.6 fuel combustion emissions from the affected draw furnace shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
CO	84	
NOx	100	
PM	7.6	
SO2	0.6	
VOM	5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Draw Furnace Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

7.7	Units SH	41 Natural Gas Fired Space Heaters

7.7.1	Description

Numerous natural gas-fired space heaters are located throughout the facility.  The heaters are used to retain a comfortable working temperature in the area.  Emissions from these units will be the byproducts of natural gas fuel combustion.

7.7.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Rated Heat Input	
L-3	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
L-6	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
L-9	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
L-13	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
BB-3	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
BB-8	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
BB-12	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
N-18	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
G-12	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
G-8	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
G-4	Rapid Model 3073 Natural Gas Fired Space Heater	8.25 mmBtu/hr	
BB-7	Rapid Model SR66 Natural Gas Fired Space Heater	6.25 mmBtu/hr	
B-23	Rapid Model 3060 Natural Gas Fired Space Heater	4.25 mmBtu/hr	
10-E	Rapid Model 3049 Natural Gas Fired Space Heater	3.25 mmBtu/hr	
10-W	Rapid Model 3049 Natural Gas Fired Space Heater	3.25 mmBtu/hr	
A-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
C-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
D-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	

Emission
Unit	
Description	
Rated Heat Input	
E-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
F-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
G-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
H-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
I-20	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
A-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
B-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
C-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
E-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
F-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
G-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
I-16	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
G-24	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
K-15	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
K-18	Buffalo Model C-25-210-GFU Natural Gas Fired Space Heater	2.5 mmBtu/hr	
AA-21-3	Hartzell Model G-2512 Natural Gas Fired Space Heater	2.5 mmBtu/hr	
AA-21-4	Hartzell Model G-2512 Natural Gas Fired Space Heater	2.5 mmBtu/hr	
D-2	Hartzell Model G-259 Natural Gas Fired Space Heater	2.5 mmBtu/hr	
H-2	Hartzell Model G-259 Natural Gas Fired Space Heater	2.5 mmBtu/hr	
L-9	Devilbliss Model ARG-50 Natural Gas Fired Space Heater	5.2 mmBtu/hr	
AA-17	Devilbliss Model ARG-50 Natural Gas Fired Space Heater	5.2 mmBtu/hr	
L-13-0	Devilbliss Model ARG-50 Natural Gas Fired Space Heater	5.2 mmBtu/hr	
L-13-3	Devilbliss Model ARG-50 Natural Gas Fired Space Heater	5.2 mmBtu/hr	

7.7.3	Applicability Provisions and Applicable Regulations

a.	The 41 natural gas fired space heaters are “affected space heaters" for the purpose of these unit-specific conditions.

b.	Each affected space heater 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].

7.7.4	Non-Applicability of Regulations of Concern

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

b.	The affected space heaters are not subject to 35 IAC 217.121, emissions of nitrogen oxides from new fuel combustion emission sources, or 35 IAC 217.141, emissions of nitrogen oxides from existing fuel combustion emission sources in major metropolitan areas, because the actual heat input of each unit is less than 73.2 MW (250 mmBtu/hr) and the affected space heaters are not by definition fuel combustion emission units.

c.	This permit is issued based on the affected space heaters not being subject to 35 IAC 212.321 or 212.322 because due to the unique nature of this process, such rules cannot reasonably be applied.

d.	The affected space heaters 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.7.5	Operational and Production Limits and Work Practices

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

7.7.6	Emission Limitations

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

a.	Emissions and operation of the space heaters shall not exceed the following limits:

	Fuel Usage	NOx Emissions	
Emission Unit	Mft3/mo	Mft3/yr	Ton/mo	Ton/yr	
41 Space Heaters	111.85	755	5.60	37.75	

These limits are based on standard emission factors, the type of fuel and the maximum fuel usage.  The above limitations have been established at the request of the Permittee pursuant to 40 CFR 52.21, Prevention of Significant Deterioration (PSD).  These limits ensure that the construction/modification of these units does not constitute a new major source or major modification pursuant to the federal rules for Prevention of Significant Deterioration (PSD), 40 CFR 52.21.

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).

7.7.7	Testing Requirements

None

7.7.8	Monitoring Requirements

None

7.7.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected space heaters to demonstrate compliance with Conditions 5.5.1, 7.7.3, and 7.7.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Records of the fuel usage for the affected space heaters, Mft3/mo and Mft3/yr;

b.	Records of monthly and annual aggregate NOx, PM, SO2, and VOM emissions from the affected space heaters shall be maintained, based on fuel usage and the applicable emission factors, with supporting calculations.

7.7.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected space heaters 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:

Emissions of NOx in excess of the limits in Condition 7.7.6 based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

7.7.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.7.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.7.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.7.3 is assumed by the work-practices inherent in operation of natural gas-fired space heaters.

b.	To determine compliance with Conditions 5.5.1 and 7.7.6 fuel combustion emissions from the affected space heaters shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
NOx	100	
PM	7.6	
SO2	0.6	
VOM	5.5	

These are the emission factors for uncontrolled natural gas combustion in small boilers (< 100 mmBtu/hr), Tables 1.4-1 and 1.4-2, AP-42, Volume I, Fifth Edition, Supplement D, March, 1998.

Space Heater Emissions (lb) = (Natural Gas Consumed, Mft3) x (The Appropriate Emission Factor, lb/Mft3)

7.8	Units ETC	79 Engine Test Cells

7.8.1	Description

The engine test cells are operated to verify the operation of each of the assembled engines.  Emissions from these cells are the byproducts of fuel combustion.  The engine test cells were installed and operational since 1946.

7.8.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Emission Control
Equipment	
ETC	79 Navistar International Transportation Corp. Engine Test Cells	None	

7.8.3	Applicability Provisions and Applicable Regulations

a.	The 79 engine test cells are “affected engine test cells" for the purpose of these unit-specific conditions.

b.	Each affected engine test cell is subject to the emission limits identified in Condition 5.2.2.

c.	Pursuant to 35 IAC 214.122(b)(2) and 214.304, no person shall cause or allow the emission of sulfur dioxide into the atmosphere in any one hour period from the burning of fuel at process emission units located in the Chicago major metropolitan area with actual heat input smaller than, or equal to 73.2 MW (250 mmBtu/hr), burning liquid fuel exclusively to exceed 0.46 kg of sulfur dioxide per MW-hr of actual input when distillate fuel oil is burned (0.3 lb/mmBtu).

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].

7.8.4	Non-Applicability of Regulations of Concern

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

b.	The affected engine test cells are not subject to 35 IAC 217.141, emissions of nitrogen oxides from existing fuel combustion emission sources in major metropolitan areas, because the actual heat input of each unit is less than 73.2 MW (250 mmBtu/hr) and the affected engine test cells are not by definition fuel combustion emission units.

c.	This permit is issued based on the affected engine test cells not being subject to 35 IAC 212.322 because due to the unique nature of this process, such rules cannot reasonably be applied.

d.	The affected engine test cells 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.8.5	Operational and Production Limits and Work Practices

a.	The affected engine test cells shall only be operated with distillate fuel oil.

b.	Distillate fuel oil (Grades No. 1 and 2) with a sulfur content greater than the larger of the following two values shall not be used in an affected engine test cells:

i.	0.28 weight percent, or

ii.	The Wt percent given by the formula:  Maximum Wt percent sulfur = (0.000015) x (Gross heating value of oil, Btu/lb).

7.8.6	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.

7.8.7	Testing Requirements

None

7.8.8	Monitoring Requirements

None

7.8.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected engine test cells to demonstrate compliance with Conditions 5.5.1 and 7.8.3 pursuant to Section 39.5(7)(b) of the Act:

a.	Distillate fuel oil usage for the Engineering Test Cells, gal/mo and gal/yr;

b.	Distillate fuel oil usage for the Production Test Cells, gal/mo and gal/yr;

c.	The sulfur content of the distillate fuel oil used in the affected engine test cells (% by Wt), this shall be recorded for any one shipment of oil delivered to the source each month; and

d.	Monthly and annual aggregate NOx, PM, SO2, and VOM emissions from the affected engine test cells shall be maintained, based on the fuel usage of the affected engine test cells and the applicable emission factors, with supporting calculations.

7.8.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected engine test cells 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:

The use of distillate fuel oil with a sulfur content in excess of the limit specified in Condition 7.8.5(b) with the length of time this fuel was used and the effect on emissions of SO2 within 30 days of this violation being detected.

7.8.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.8.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.8.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.8.3(d) is assumed by the work-practices inherent in operation of distillate oil-fired engine test cells.

b.	Compliance with Condition 7.8.3(c) is assumed to be demonstrated by operation of the affected engine test cells with distillate fuel oil with a sulfur content meeting the specification of Condition 7.8.5(b).

c.	To determine compliance with Condition 5.5.1, emissions from the affected engine test cells shall be calculated based on the following emission factors:

Pollutant	Engineering Test Cell Emission Factor
(lb/gal)	Production Test Cell Emission Factor
(lb/gal)	
NOx	0.188	0.192	
PM	0.011	0.006	
SO2	7.1 S	7.1 S	
VOM	0.023	0.012	

These are the emission factors for uncontrolled diesel reciprocating engine testing at this source based on stack testing.  S indicates that the weight % of sulfur in the oil should be multiplied by the value given.

Engine Test Cell Emissions (lb) = (Distillate Fuel Oil Consumed, gal)x (The Appropriate Emission Factor, lb/gal)

7.9	Unit COGEN	Cogeneration System
Control C3	3-Way Catalytic Converters

7.9.1	Description

The cogeneration system is used to supply electricity to the plant during the peak operating hours and for emergency purposes when the facility experiences a loss of electrical service from the public utility company.  The system consists of 12 Caterpillar natural gas reciprocating engines producing a combined total of 9.4 MW.  Each engine has a 4160 volt generator to produce nominally 770 kW of self-generated power.  Each engine also has an exhaust heat recovery silencer and produces steam for heating and process as well as a three-way catalytic converter to reduce emissions.  The catalytic converter has temperature sensors to monitor operation.  In addition, an air/fuel controller is mounted to each engine set to maintain a rich fuel mixture.

7.9.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	
Description	Emission Control
Equipment	
COGEN	12 Caterpillar Model G3516SITA Natural Gas Spark Ignition Reciprocating Engines	3-Way Catalytic Converters (12)	

7.9.3	Applicability Provisions and Applicable Regulations

a.	Each engine is an “affected engine" for the purpose of these unit-specific conditions.

b.	Each affected engine 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].

7.9.4	Non-Applicability of Regulations of Concern

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

b.	The affected engines 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 engines are not by definition fuel combustion emission units.

c.	This permit is issued based on the affected engines 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 engines 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.9.5	Operational and Production Limits and Work Practices

a.	The 3-way catalytic converters shall be operated to control emissions of nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic material (VOM).

i.	The 3-way catalytic converters shall be operated to provide 92.5%, 83%, and 45% control efficiency for NOx, CO, and VOM respectively.

ii.	The Permittee shall follow good operating practices for the 3-way catalytic converters, including periodic inspection, routine maintenance and prompt repair of defects.

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

7.9.6	Emission Limitations

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

a.	The operation of affected engines shall not exceed the following limits:

	Natural Gas Usage	
Emission Unit	(Therms/mo)	(Therms/yr)	
12 Engines	537,339	3,224,034	

b.	Emissions of nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic material (VOM) from the engines shall not exceed the following limits:

	E M I S S I O N S	
Emission	NOx	CO	VOM	
Unit	(T/Mo)	(T/Yr)	(T/Mo)	(T/Yr)	(T/Mo)	(T/Yr)	
12 Engines	6.27	37.56	14.55	87.60	0.57	4.20	

c.	These limits are based on emission factors supplied by the vendor, the type of fuel, and the maximum electric outputs of the affected engines.

d.	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).

e.	The above limitations contain revisions to previously issued construction permit 92080029.  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 and 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 limits for the operating hours and natural gas fuel usage have been replaced with monthly and annual limits of the natural gas usage for all 12 of the affected engines.

7.9.7	Testing Requirements

None

7.9.8	Monitoring Requirements

Monitoring of the fuel usage of the affected engines shall be performed as follows [Section 39.5(7)(b) of the Act]:

a.	The Permittee shall install and operate a continuous monitoring system to monitor and record the fuel consumption for the affected engines.

b.	The Permittee shall install and operate a continuous monitoring system to monitor and record the electrical output of the affected engines.

7.9.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected engines to demonstrate compliance with Conditions 5.5.1, 7.9.3, and 7.9.6 pursuant to Section 39.5(7)(b) of the Act:

a.	Records addressing use of good operating practices for the 3-way catalytic converters:

i.	Records for periodic inspection of the 3-way catalytic converters 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.

b.	Natural gas fuel consumption for each affected engine, Therms/mo, and Therms/yr;

c.	Monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected engines shall be maintained, based on the electrical output of the affected engines and the applicable emission factors, with supporting calculations.

7.9.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected engines 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.	Continued operation of an affected engine with a defect in a 3-way catalytic converter that may result in emissions in excess of limits in Condition 7.9.3(c) and/or 7.9.6(b) within 30 days of such an occurrence.

b.	Emissions of NOx, CO, and/or VOM in excess of the limits in Condition 7.9.6(b) based on the current month's records plus the preceding 11 months within 30 days of such an occurrence.

c.	Operation of the affected engines in excess of the limit for electrical output in Condition 7.9.6(a) within 30 days of such an occurrence.

7.9.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.9.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.9.9 and the emission factors and formulas listed below:

a.	Compliance with Conditions 7.9.3(b) and (c) is assumed by the work-practices inherent in operation of natural gas-fired engines.

b.	Compliance with Condition 7.9.3(c) is assumed to be demonstrated by operation of the 3-way catalytic converters as specified in Condition 7.9.5(a).

c.	Compliance with the emission limits of Conditions 5.5.1 and 7.9.6(b) shall be based on the emission factors listed below:

i.	To determine compliance with Conditions 5.5.1 and 7.9.6(b), emissions of CO, NOx, and VOM from the affected engines shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
CO	541	
NOx	233	
VOM	 21	

These are the uncontrolled emission factors for CO, NOx, and VOM for the Caterpillar Model 3516 SI natural gas reciprocating engine and were supplied by the vendor.  VOM emission factor is based on the nonmethane emission factor.

Engine Emissions (lb) = (Natural Gas Consumed, Therms) x (100 ft3/Therm) x (1 Mft3/1,000,000 ft3) x (The Appropriate Emission Factor, lb/Mft3) x [1 - (Catalytic Converter Efficiency* (%)/100)]

*As specified by Condition 7.9.5(a)(i).

ii.	To determine compliance with Condition 5.5.1 emissions of PM and SO2 from the affected engines shall be calculated based on the following emission factors:

Pollutant	Emission Factor
(lb/Mft3)	
PM	10.0	
SO2	0.6	

These are the emission factors for uncontrolled natural gas reciprocating cogeneration engines (SCC #20200204), FIRE Version 5.0 Source Classification Codes and Emission Factor Listing for Criteria Air Pollutants, August, 1995.  PM emission factor is based on the PM10 factor.

Engine Emissions (lb) = (Natural Gas Consumed, Mft3) x (100 ft3/Therm) x (1 Mft3/1,000,000 ft3) x (The Appropriate Emission Factor, lb/Mft3)

7.10	Units EETC	15 Engineering Engine Test Cells

7.10.1	Description

The engineering engine test cells are used to support new light duty engine development and testing.  These test cells include chassis emission cells, mileage accumulation stands, powertrain simulation test cells and performance dyno test cells.  Emissions from these cells are the byproducts of fuel combustion.

7.10.2	List of Emission Units and Pollution Control Equipment

Emission
Unit	

Description	Emission Control
Equipment	
EETC	15 Navistar International Transportation Corp. Engineering Engine Test Cells	None	

7.10.3	Applicability Provisions and Applicable Regulations

a.	The 15 engineering engine test cells are “affected engine test cells" for the purpose of these unit-specific conditions.

b.	Each affected engine test cell is subject to the emission limits identified in Condition 5.2.2.

c.	Pursuant to 35 IAC 214.122(b)(2) and 214.304, no person shall cause or allow the emission of sulfur dioxide into the atmosphere in any one hour period from the burning of fuel at process emission units located in the Chicago major metropolitan area with actual heat input smaller than, or equal to 73.2 MW (250 mmBtu/hr), burning liquid fuel exclusively to exceed 0.46 kg of sulfur dioxide per MW-hr of actual input when distillate fuel oil is burned (0.3 lb/mmBtu).

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].

7.10.4	Non-Applicability of Regulations of Concern

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

b.	The affected engine test cells are not subject to 35 IAC 217.141, emissions of nitrogen oxides from existing fuel combustion emission sources in major metropolitan areas, because the actual heat input of each unit is less than 73.2 MW (250 mmBtu/hr) and the affected engine test cells are not by definition fuel combustion emission units.

c.	This permit is issued based on the affected engine test cells 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 engine test cells 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 PM10, as identified in 35 IAC 212.324(a)(1).

7.10.5	Operational and Production Limits and Work Practices

a.	The affected engine test cells shall only be operated with distillate fuel oil.

b.	Distillate fuel oil (Grades No. 1 and 2) with a sulfur content greater than the larger of the following two values shall not be used in an affected engine test cells:

i.	0.28 weight percent, or

ii.	The Wt percent given by the formula:  Maximum Wt percent sulfur = (0.000015) x (Gross heating value of oil, Btu/lb).

7.10.6	Emission Limitations

In addition to Condition 5.2.2 and the source wide emission limitations in Condition 5.5, the affected engine test cells are subject to the following:

a.	The total fuel usage for all fifteen diesel engine test cells shall not exceed the following limits:

gallons/month	gallons/year	
53,625	321,750	

b.	The total emissions from all fifteen diesel engine test cells shall not exceed the following limits:

CO	NOx	PM	
(t/mo) (t/yr)	(t/mo) (t/yr)	(t/mo) (t/yr)	
43.76	16.41	82.37	30.89	4.72	1.77	

SO2	VOM	
(t/mo) (t/yr)	(t/mo) (t/yr)	
5.96	2.23	9.87	3.70	

c.	These limits are based on the maximum fuel usage for the engine test cells and representations of the maximum actual emissions resulting from the maximum fuel usage.  The emission factors for NOx (0.188 lb/gal), PM (0.011 lb/gal), SO2 (0.0139 lb/gal), and VOM (0.023 lb/gal) are based on stack testing and a standard emission factor for CO (102 lb/1000 gal).

d.	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).

e.	The above limitations were established in Construction Permit 98070033, pursuant to 35 IAC Part 203 and 40 CFR 52.21, Prevention of Significant Deterioration (PSD).  These limits ensure that the construction and/or modification addressed in the aforementioned Construction Permit does not constitute a new major source or major modification pursuant to 35 IAC Part 203 and the federal rules for Prevention of Significant Deterioration (PSD), 40 CFR 52.21.

f.	The VOM emission units with contemporaneous VOM emissions are described in Table 1 of Attachment 3.  The emission units or activities used to decrease emissions are described in Table 2 of Attachment 3.  The net change in VOM emissions is described in Table 3 of Attachment 3.

7.10.7	Testing Requirements

None

7.10.8	Monitoring Requirements

None

7.10.9	Recordkeeping Requirements

In addition to the records required by Condition 5.6, the Permittee shall maintain records of the following items for the affected engine test cells to demonstrate compliance with Conditions 5.5.1 and 7.10.3 pursuant to Section 39.5(7)(b) of the Act:

a.	Distillate fuel oil usage for the affected engine test cells, gal/mo and gal/yr (running total);

b.	The sulfur content of the distillate fuel oil used in the affected engine test cells (% by Wt), this shall be recorded for any one shipment of oil delivered to the source each month; and

c.	Monthly and annual aggregate CO, NOx, PM, SO2, and VOM emissions from the affected engine test cells shall be maintained, based on the fuel usage of the affected engine test cells and the applicable emission factors, with supporting calculations.

7.10.10	Reporting Requirements

The Permittee shall promptly notify the Illinois EPA, Compliance Section of noncompliance of the affected engine test cells 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 use of distillate fuel oil with a sulfur content in excess of the limit specified in Condition 7.10.5(b) with the length of time this fuel was used and the effect on emissions of SO2 within 30 days of this violation being detected.

b.	Emissions from the fifteen diesel engine test cells in excess of the limits in Condition 7.10.6(b) within 30 days of a record showing such an occurrence.

7.10.11	Operational Flexibility/Anticipated Operating Scenarios

N/A

7.10.12	Compliance Procedures

Compliance with the emission limits shall be based on the recordkeeping requirements in Condition 7.10.9 and the emission factors and formulas listed below:

a.	Compliance with Condition 7.10.3(d) is assumed by the work-practices inherent in operation of distillate oil-fired engine test cells.

b.	Compliance with Condition 7.10.3(c) is assumed to be demonstrated by operation of the affected engine test cells with distillate fuel oil with a sulfur content meeting the specification of Condition 7.10.5(b).

c.	To determine compliance with Condition 5.5.1, emissions from the affected engine test cells shall be calculated based on the following emission factors:

i.	NOx, PM, SO2, and VOM Emissions:

Pollutant	Emission Factor
lb/gal	
NOx	0.188	
PM	0.011	
SO2	7.1 S	
VOM	0.023	

These are the emission factors for uncontrolled diesel reciprocating engine testing at this source based on stack testing.  S indicates that the weight % of sulfur in the oil should be multiplied by the value given.

Engine Test Cell Emissions (lb) = (Distillate Fuel Oil Consumed, gal)x (The Appropriate Emission Factor, lb/gal)

ii.	CO Emissions:

Pollutant	Emission Factor
lb/1000 gal	
CO	0.102	

This is the emission factor for emissions of CO from Diesel/Kerosene Reciprocating Engine Testing (SCC 20400402), FIRE Version 5.0 Source Classification Codes and Emission Factor Listing for Criteria Air Pollutant (August, 1995).

Engine Test Cell Emissions (lb) = (Distillate Fuel Oil Consumed, gal)x (The Appropriate Emission Factor, lb/1000 gal)

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 ________{insert public notice start date} (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
Bureau of Air
Compliance Section (MC 40)
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 certifications shall include descriptions of means to monitor the compliance of the source including emissions limitations, standards, and work practices in accordance with applicable requirements and permit conditions.  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	Emissions of Particulate Matter from Existing Process Emission Units

10.2.1	Process Emission Units for Which Construction or Modification Commenced Prior to 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 process emission unit for which construction or modification commenced prior to April 14, 1972, which, either alone or in combination with the emission of particulate matter from all other similar process emission at a source or premises, exceeds the allowable emission rates specified in subsection (c) of 35 IAC 212.322 [35 IAC 212.322(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 212.322(b)]:

E = C + A(P)B

where:

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

i.	Up to process weight rates up to 27.2 Mg/hr (30 T/hr):

	Metric	English	
P	Mg/hr	T/hr	
E	kg/hr	lb/hr	
A	1.985	4.10	
B	0.67	0.67	
C	0	0	

ii.	For process weight rate in excess of 27.2 Mg/hr (30 T/hr):

	Metric	English	
P	Mg/hr	T/hr	
E	kg/hr	lb/hr	
A	25.21	55.0	
B	0.11	0.11	
C	-18.4	-40.0	

c.	Limits for Process Emission Units For Which Construction or Modification Commenced Prior to April 14, 1972 [35 IAC 212.322(c)]:

Metric		English		
P	E	P	E	
Mg/hr	kg/hr	T/hr	lb/hr	
  0.05	 0.27	  0.05	 0.55	
  0.1	 0.42	  0.10	 0.87	
  0.2	 0.68	  0.2	 1.40	
  0.3	 0.89	  0.30	 1.83	
  0.4	 1.07	  0.40	 2.22	
  0.5	 1.25	  0.50	 2.58	
  0.7	 1.56	  0.75	 3.38	
  0.9	 1.85	  1.00	 4.10	
  1.8	 2.9	  2.00	 6.52	
  2.7	 3.9	  3.00	 8.56	
  3.6	 4.7	  4.00	10.40	
  4.5	 5.4	  5.00	12.00	
  9.0	 8.7	 10.00	19.20	
 13.0	11.1	 15.00	25.20	
 18.0	13.8	 20.00	30.50	
 23.0	16.2	 25.00	35.40	
 27.2	18.15	 30.00	40.00	
 32.0	18.8	 35.00	41.30	
 36.0	19.3	 40.00	42.50	
 41.0	19.8	 45.00	43.60	
 45.0	20.2	 50.00	44.60	
 90.0	23.2	100.00	51.20	
140.0	25.3	150.00	55.40	
180.0	26.5	200.00	58.60	
230.0	27.7	250.00	61.00	
270.0	28.5	300.00	63.10	
320.0	29.4	350.00	64.90	
360.0	30.0	400.00	66.20	
400.0	30.6	450.00	67.70	
454.0	31.3	500.00	69.00	

10.3	Attachment 3	Net VOM Emissions Increase Determination

								Table 1
						Contemporaneous VOM Increases

Emission Unit/Activity	
Permit	
Date Issued	VOM
(Ton/year)*	
Paint Line #2	94120009	2/17/1995	24.33	
12 CAT 3516 Natural Gas Engines	92080029	11/8/1995	 0.35	
		Total	24.68	

								Table 2
						Contemporaneous VOM Decreases

Emission Unit/Activity	
Permit	VOM
(Ton/year)	
Cold Parts Cleaning	73030760	18.14**	
Cold Parts Cleaning (Special Condition No. 7 of Construction Permit 98070033)	
98070033	
10.54+	
	Difference	7.60	

								Table 3
						   Net VOM Emission Increase

	VOM
(Ton/year)	
Engine Test Cells (Special Condition No. 5(a)(ii) of Construction Permit 98070033)	
+ 3.70	
Contemporaneous Increases	+24.68	
Contemporaneous Decreases	- 7.60	
	+20.78	

*	Maximum emissions allowed by permit.

**	Based upon the actual VOM emissions from Cold Parts Cleaning, averaged over the last two years prior to implementation of pollution prevention projects (1994-1995).

+	Based upon pollution prevention projects designed to reduce VOM emissions, including substitution of cleaning solvent with aqueous cleaner, introduction of high flash non-hazardous solvent, and improving housekeeping.

10.4	Attachment 4	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